December 1986 EPA 700-8-87-007
Hazardous Waste Ground-Water
Task Force
Evaluation of Fondessy Enterprises, Inc.
Oregon, Ohio
&EPA ON0ER&
US Environmental Protection Agency
Ohio Environmental Protection Agency
U.S. Environmental Protection Agency
Region V. Ub'-af/
230 South Dearborn Street
Chicago, Illinois 60604
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DECEMBER 1986
UPDATE OF THE HAZARDOUS WASTE GROUNDWATER
TASK FORCE EVALUATION OF FONDESSY
ENTERPRISES, INC.
The United States Environmental Protection Agency's Groundwater Task Force
("Task Force") conducted an evaluation at the Fondessy Enterprises. Inc.
hazardous waste disposal facility located on Otter Creek Road, in Oregon,
Ohio. The Task Force was comprised of personnel from United States
Environmental Protection Agency (U.S. EPA) Headquarters, U.S. EPA Region V
offices, and the Ohio Environmental Protection Agency (OEPA). The Fondessy
Enterprises, Inc. facility is located in Oregon, Ohio, near its western
boundary with the City of Toledo, Ohio. The onsite inspection was conducted
from January 27 through February 6, 1986, and was coordinated by personnel
from U.S. EPA Region V.
The purpose of the Task Force evaluation was to determine the adequacy of the
groundwater monitoring system in regard to Federal groundwater monitoring
requirements under the Resource Conservation and Recovery Act (RCRA).
Specifically, the objectives of the evaluation at Fondessy Enterprises, Inc.
were:
0 To determine compliance with 40 CFR Part 265 interim status groundwater
monitoring requirements;
0 To evaluate the groundwater monitoring program described in the RCRA
Part B permit application for compliance with 4n CFR Part 270.14(c); and
• r •
0 To determine if hazardous waste constituents have entered the groundwater
at the facility.
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Fondessy Enterprises, Inc. (FEI) currently has monitoring wells screened in
three distinct zones: (1) Greenfield dolomite bedrock, (2) the contact zone
between the upper till and lower till units, and (3) lacustrine deposits
overlying the upper till zone. The facility currently utilizes only the
monitoring wells screened in the bedrock to address the interim status ground-
water monitoring requirements. Downgradient bedrock wells are separated by as
much as 700 feet. The Task Force recommends that additional wells be added to
the bedrock monitoring system to decrease the spacing between wells located
along the downgradient limit of the waste management area.
The Task Force considers the contact zone between the upper till and lower
till units, and the lacustrine deposits overlying the upper till zone to be
preferential pathways for contaminant migration. FEI has proposed to monitor
these two zones in conjunction with the groundwater monitoring system proposed
for use in their application for a final RCRA permit (Part B). The Task Force
recommended that the monitoring of these zones be included in the 40 CFR Part
265 groundwater monitoring system.
All four laboratories used by FEI were evaluated by the Task Force. It was
found that one of the laboratories, CEP, accepts samples that do not arrive at
the laboratory under a custody seal, which is contrary to the FEI's sampling
and analysis plan. The Task Force recommends that this practice cease
immediately and that FEI ensure that the chain-of-custody procedures addressed
in its facility sampling and analysis plan be followed rigorously by whatever
laboratory is used.
On October 3, 1986, U.S. EPA informed FEI that the Region V RCRA Enforcement
Section had reviewed the Task Force comments concerning the groundwater
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monitoring system and requested a meeting to discuss these concerns. This
letter initiated a series of informal discussions between FEI, U.S. EPA, and
OEPA. The purpose of these discussions was to inform FEI of the Task Force
recommendations and to develop a written document memorializing an agreement
between FEI and U.S. EPA that would involve upgrading the existing groundwater
monitoring system to address the Task Force concerns.
On December 5, 1986, U.S. EPA sent a proposed Consent Agreement and Final Order
(CAFO) to FEI. The major issues addressed in the proposed CAFO are as follows:
(1) FEI shall comply with 40 CFR 265.92 by ensuring that all chain-of-custody
procedures identified in its sampling and analysis plan are followed;
(2) FEI shall submit a written report that explains the bedrock ground water
monitoring system including a description of the extent to which the current
system monitors the bedrock aquifer;
(3) FEI shall submit a plan for the installation of a minimum of one bedrock
monitoring well located along the facility's northern perimeter between
existing wells R3 and R9; and
(4) FEI shall submit a plan for the installation and implementation of a shallow
groundwater monitoring system capable of monitoring groundwater from the
shallow lacustrine zone and the contact zone between the upper and lower till
The December 5, 1986, proposed CAFO addressed Task Force concerns with respect
to the existing interim status groundwater monitoring system. U.S. EPA and
FEI are currently discussing the details of the proposed CAFO.
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On December ?, 1986, U.S. EPA sent FEI a Notice of Deficiency (NOD) following
another completeness review of the Part B of the RCRA permit application.
Included in the NOD was a summary of the missing procedures or information
that the Task Force determined to be necessary contents of the permit
application. FEI has sixty (60) days from December 2, 1986, to respond to
the NOD.
During the FEI inspection, Task Force personnel collected samples from six
bedrock wells, thirteen shallow lacustrine wells, ten deep till wells, two
water line trenches and two leachate sumps. The Task Force reviewed the results
of this sampling event and past monitoring data collected by the facility.
This review revealed the presence of 8.3 ppb of PCBs in well R6, 17 ppb of
1,1, dichloroethane in well F2s, 15 ppb of l-formyl-2-piperidinecarboxylic
acid in well SD6-2, 0.58 ppb of 4,4'- DDT in well Fid, and 13 ppb of 2-methyl-
cyclopentanone in well M4d. The Task Force recommended that additional
monitoring begin immediately to establish the source of the detected constituents,
As a result of these recommendations, U.S. EPA requested in the December 2,
1986, Notice of Deficiency that FEI resample and retest wells R6, Fid, F2s,
M4d, and SDG-2 for parameters in Appendix VIII of 40 CFR 261. If retesting
indicates groundwater contamination, FEI must define the extent of the plume
of contamination of the groundwater in the manner required by 40 CFR 270.14(c)(4)
This completes the Hazardous Waste Groundwater Task Force evaluation of the
Fondessy Enterprises, Inc. facility in Oregon, Ohio.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUND WATER TASK FORCE
GROUND WATER EVALUATION
FONOESSY ENTERPRISES, INC.
OREGON, OHIO
DECEMBER 1986
JOSEPH J. FREDLE
PROJECT COORDINATOR
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V
ENVIRONMENTAL SERVICES DIVISION
EASTERN DISTRICT OFFICE
WESTLAKE, OHIO
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TABLE OF CONTENTS
Page
I. EXECUTIVE SUMMARY 1
A. Introduction 1
B. Summary of Findings and Conclusions 7
1. Compliance with Interim Status Ground Water 7
Monitoring Requirements - 40 CFR 265 Subpart P
2. Ground Water Monitoring Program Proposed 8
for RCRA Permit
3. Task Force Sampling and Monitoring Data Analysis .... 9
4. Compliance with Superfund Offsite Policy 10
II. TECHNICAL REPORT 11
A. Investigative Methods 11
1. Technical Review Team 11
2. Laboratory Evaluation Team 12
3. Sampling Team 13
B. Facility Operations, Design, and History 16
1. Background - Information Sources 16
2. History 17
3. Operations 22
4. Hazardous Waste Management Units 25
a. Cell H 25
b. Cell I 27
c. Future Cells G and M ?9
d. Cell F 29
e. Land Treatment Area 30
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TABLE OF CONTENTS (continued)
Page
5. Solid Waste Management Units 32
a. Early Operations 32
b. Landfill Area 1 36
c. Landfill Area 2 37
C. Hydrogeology 38
1. Surficial Geology 38
2. Subsurface Geology 39
3. Ground Water Conditions in the Bedrock 41
4. Ground Water Conditions in the Unconsolidated 44
Sediments
D. Ground Water Monitoring 45
1. Pre-RCRA Monitoring 45
2. Interim Status Ground Water Monitoring 46
3. Other Ground Water Monitoring During Interim Status ... 51
a. Ground Water Monitoring Wells ......... 51
b. Monitoring Trenches 52
4. Ground Water Monitoring Proposed for RCRA Permit .... 55
a. Point of Compliance 55
b. Well Locations - Bedrock Wells 57
c. Well Locations - Leak Detection Wells 59
d. Constituents for Analyses - Bedrock Wells 6\
i. Proposed Indicator Parameters 62
ii. Proposed Ground Water Quality Parameters ... 62
iii. Proposed Waste Constituents 63
e. Constituents for Analysis Leak Detection Wells ... 63
i i
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TABLE OF CONTENTS (continued)
Page
5. Sampling and Analysis Plan (SAP) 63
a. Water Level Determination 64
b. Well Evacuation 64
c. Sample Withdrawal 66
d. Field Analysis 67
e. Laboratory Analysis 67
E. Ground Water Quality Data Interpretation 68
1. Task Force Analysis 68
2. Interpretation of Data From Bedrock Wells 68
3. Interpretation of Data from Deep Till Wells 71
4. Interpretation of Data from Shallow Lacustrine Wells . . . 73
5. Interpretation of Data from Water Line Trenches .... 75
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LIST OF TABLES Page
1. Order of Sample Collection, Bottle Type and Preservative List .... 15
2. Technical Reports Available for the Task Force
Evaluation of Fondessy 18
3. Summary of Fondessy Waste Management Units 26
4. Summary of Waste Disposed of within Cell F 31
5. Analyses of Leachate from Fred C. Hart, Borings 35
6. Sample Preparation and Analysis Techniques and Methods 69
LIST OF FIGURES
1. Location of Fondessy and Nearby Facilities 3
2. Fondessy Waste Management Units 4
3. Past Waste Disposal Activities 6
4. Typical Cross Section and Construction Details of
Hazardous Waste Cel 1 H 28
5. Fondessy Land Parcels North and South of York Street 33
6. USEPA Ground Water Elevation Measurements from January 23, 1986 ... 43
7. Interim Status Ground Water Monitoring System, January, 1986 .... 49
8. Bedrock Well R-l Construction Details 50
9. FEI's Proposed Point of Compliance 56
10. FEI's Proposed Bedrock Monitoring Wells 58
11. FEI's Proposed Leak Detection Wells 60
12. Maximum TOX Values in Shallow Lacustrine Wells 74
LIST OF APPENDICES
A. Low Pressure Raw Water! ine Security Agreement - March 22, 1984.
B. Sample Collection Data
C. Laboratory Evaluations
D. Quality Assurance - Quality Control Summary of Task Force
Analytical Results
E. Analytical Results from Task Force Samples
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I. EXECUTIVE SUMMARY
A. INTRODUCTION
Concerns have recently been raised as to whether the commercial hazardous
waste treatment, storage, and disposal facilities (TSDFs) are in compliance
with the ground water monitoring regulations to detect contaminant releases
from waste management units at TSDFs. In response to these concerns, the
Administrator of the U. S. Environmental Protection Agency (EPA) established a
Hazardous Waste Ground Water Task Force (Task Force) to evaluate the level of
compliance at TSDFs and address the cause(s) of noncompliance. The Task Force
is comprised of personnel from EPA Headquarters, including the Office of Solid
Waste and Emergency Response (OSWER), EPA Regional Offices and State regulatory
agency personnel. To determine the status of facility compliance, the Task
Force is conducting in-depth facility investigations, including onsite in-
spections, of TSDFs. The objectives of these investigations are to:
- Determine compliance with interim status ground water monitoring require-
ments of 40 CFR Part 265 as promulgated under RCRA or the State equivalent
(where the State has received RCRA authorization),
- Evaluate the ground water monitoring program described in the facility's
RCRA Part B permit application for compliance with 40 CFR Part 270.14(c),
- Determine if the ground water at the facility contains hazardous waste
constituents, and
- Provide information to assist the Agency in determining if the TSDF meets
EPA ground water monitoring requirements for waste management facilities
receiving waste from response actions conducted under the Comprehensive Envi-
ronmental Response, Compensation and Liability Act (CERCLA, Public Law 915-10)*.
* EPA policy, stated in the May 6, 1985 memorandum from Jack McGraw on
"Procedures for Planning and Implementing Offsite Response", requires that
TSDFs receiving CERCLA wastes be in compliance with applicable RCRA ground water
monitoring requirements.
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To address these objectives, each Task Force investigation will determine if:
- The facility has developed and is following an adequate ground water sampl-
ing and analysis plan,
- Designated RCRA and/or State required monitoring wells are properly located
and constructed,
- Required analyses have been conducted on samples from the designated RCRA
monitoring wells, and
- The ground water quality assessment program outline (or plan, as approp-
riate) is adequate.
The twelfth TSDF investigated by the Task Force was the Fondessy Enter-
prises, Inc. site (FEI) located in Oregon, Ohio, near its western boundary with
the City of Toledo, Ohio (Figure 1). The onsite inspection was conducted from
January 27 through February 6, 1986, and was coordinated by personnel from the
EPA Region V. In general, the investigation involved review of State, Federal,
local, and facility records; facility inspection; laboratory evaluation; and
sampling and analysis of ground water and landfill leachate.
The geographic coordinates of the site are 41°40.00'N, 83°28.06'W in Lucas
County, Ohio. The property is owned by FEI which is an operating subsidiary
of Envirosafe Services, Inc. of Horsham, Pennsylvania. FEI presently has
interim status under RCRA for landfill/land treatment of hazardous waste at its
876 Otter Craek Road facility (ID No. OHO 045243706); however, land treatment
has been discontinued here. There are also leachate storage tanks located at
this facility, as well as physical/chemical stabilization operations.
The waste management areas of this facility are designated as Landfill
Areas 1 and 2, and cells F, G, H, I, and M (Figure 2). Landfill Areas I and 2
are inactive, pre-RCRA landfills. Landfill Area 1 is approximately 1250 x 700
feet in area and the southeast portion of the cell is now the site of the
leachate storage tank farm. Landfill Area 2 is currently used for clay
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FIGURE 1 , .
Location of Fondessy and Nearby Facilities
Fondessy Enterprises, Inc.
Oregon, Ohio
January, L986 •
.*
FONoessr ENTERPRISER
LANDFILL
/HAZARDOUS WASTE
1. Fondessy Enterprises, Inc.
2. Standard Oil Co. (Ohio): Land Treatment and Lagoons
3. Commercial Oil Inc. H.W. Solvent Reclamation
4. C and W Tank Cleaning H.W. Transportation
INDUSTRIAL FACILITIES
5. Westover Sanitary Landfill (Open) ...
6. Westover Landfill (Closed)
7. Liquid Carbonic Inc.
Heist Corporation
Toledo Edison Properties
American Wire Company
Marathon Pipeline
Globe Industries
Buckeye Pipeline
Norfolk S Western Homestead Yard
15. City of Oregon Sludge Disposal Area
16. Safety-Kleen
17. Bill's Road Oiling Service (closed)
3
9
10
11
12
13
14
Note
Drawing taken from United States
Department of the Interior Geologica"
Survey-Oregon Quadrang'e, Qhio-Micn::
(N4 137.5-W8322.5/7.5;
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FfGURE 2
MANAU~£MCNT JN
FONOESSY £NT£RPflIS£S, INC.
OREGON, OHIO
JANUARY.
S0
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stockpiles and is about 700 x 500 feet in area. Cell F is currently at capacity,
and a partial closure plan for this cell has been approved by the Ohio EPA.
Cell F has received industrial and hazardous wastes and is about three acres in
area. Cell H is the present active site receiving industrial and hazardous
waste, and was constructed with a single 60-mil., high density polyethylene
(HOPE) liner. Cell I is planned to be the site next used for industrial and
hazardous waste disposal. This cell is to have a double synthetic liner and an
approximate area of 850 x 500 feet. A portion of this area has also been used
for land treatment of hazardous waste prior to construction of the hazardous
waste cell (Figure 3). An area west of Cell I was designated as the "Old Oil
Lagoon". A container storage building which lias not yet been placed into
service is located near the west end of the former lagoon. Other features of
interest include two closed oil lagoons to the north of a waterline which is
owned by the City of Toledo, and an ash disposal area in the borrow pit
(Figure 3). Future cells are designated areas G and M (Figure 2). Cell M is
located on the south side of York Road, and is included in FEI's Part B permit
application as part of the expanded hazardous waste TSO facility. This cell
was not included in the RCRA Part A application, thus it does not have interim
status.
Two low-pressure raw water transmission lines cross the facility in an
east/west direction, mostly north of York Road. These lines conduct raw Lake
Erie water to the City of Toledo Collins Park water treatment plant. An
agreement exists between FEI and the City of Toledo, establishing the distances
at which surface storage and hazardous waste cells may be located with respect
to the water!ines. This agreement has affected the development of various
waste management units. Landfill Area 1 and cells G and H are located north of
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FIGURE 3
PAST WASTE DISPOSAL ACTIVITIES
FONOESSY ENTERPRISES, INC.
OREGON, OHIO
JANUARY, 1986
( CLOSED
\ I
Oil Lagoon
'FACILITY P«O*»€«TY UNI
Land Treatment Area
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the waterlines, and cell I is located to the south. The arrangement of the
waste management cells to the north and south of the waterlines creates a
corridor for an on-site roadway.
B. SUMMARY OF FINDINGS AND CONCLUSIONS
1. Compliance with Interim Status Ground Water Monitoring Requirements -
40 CFR 265 Subpart F
The interim status Ground Water Monitoring System has changed signif-
icantly since its inception in 1982. Changes in the designation of certain
wells have complicated the analysis of historical data from these wells. There
has also been a change in the ground water flow direction designation. Other
changes have involved improvements, such as the addition of more wells in the
monitoring system, which are generally better constructed and more strategically
located. The Sampling and Analysis Plan (SAP) has changed frequently and has
been under continuous development. Due to these changes, insufficient infor-
mation exists to perform more than a few statistical analyses to determine
significant differences between upgradient and downgradient wells. Background
ground water quality data for radium-226, radium-228 and TOC may be suspect due
to the unacceptable performance evaluation results of the laboratories used to
analyze these parameters for FEI and deficiencies within the chain-of-custody
procedures at their radiological laboratory. The SAP should be updated to
include the recommendations listed in Section II.D.5 of this report.
Downgradient bedrock wells are separated by as much as 700 feet. The Task
Force recommends that additional wells be added to the bedrock monitoring system
to decrease the downgradient spacing along the point of compliance.
The till zones under the facility are considered by the Task Force to be
preferential pathways for contaminant migration. It is recommended that the
monitoring of these zones be included in the 40 CFR Part 265 ground water
monitoring system for this facility.
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2. Ground Water Monitoring Program Proposed for RCRA Permit
FEI proposed in a February 20, 1986, revised Part B application to monitor
the bedrock as the uppermost aquifer, and the Lacustrine/Upper Till contact
and Upper Till/Lower Till contact through a leak detection system of wells.
The Task Force fully agrees with monitoring of these zones. The shallow
zones are considered by the Task Force to be preferential pathways for
contaminant migration. FEI contends that the dolomite and limestone bedrock,
principally the Greenfield and Lockport formations, are the uppermost aquifer
under the facility. The zones identified by the Task Force as pathways of
migration, in addition to the bedrock, are the Lacustrine, Lacustrine/Upper
Till contact, and the Upper Till/Lower Till contact. The Task Force reviewed
FEI's proposal and has the following recommendations:
- The Task Force recommends that monitoring of zones, other than bedrock,
be implemented as soon as possible and agrees that they be included in the
RCRA permit monitoring system. The Task Force also recommends that the
analytical results of samples from these shallow zones be evaluated to identify
contamination and ground water degradation.
- The point of compliance should be at the downgradient limit of the
hazardous waste management area. FEI's proposed point of compliance is
generally along the northern and eastern property boundary. However, the
downgradient limit of future cell M is distant and upgradient from other waste
management units and the point of compliance. The Task Force recommends that
the downgradient limit of future disposal cells be included in the monitoring
system.
- The rationale for the horizontal spacing of downgradient bedrock wells and
all shallow till wells should be included in the Part 3 application. It is
recommended by the Task Force that additional downgradient bedrock wells be
installed. It is also recommended that additional shallow till wells be
installed to circumscribe all waste management units.
- Due to the low ground water flow gradient, the recent seasonal variations
in ground water flow directions, and the effects of the Standard Oil Company's
pumping on ground water flow directions, the determination of the ground water
flow direction should be monthly at a minimum.
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- The proposed statistical evaluation to be used in determining the
significant differences between individual upgradient and downgradient wells
along the point of compliance is inappropriate. Another method must be proposed.
- The proposed semiannual monitoring frequency for contaminants is unaccep-
table and should be increased to at least quarterly. Also, the list of waste
constituents to be analyzed should be expanded, as stated in Section II.D.4.d.
of this report. Detection limits for the chosen waste constituents need to be
specified.
- The extent of past solid waste disposal activities at the northern boundary
of Landfill Area 1 is not clearly defined. The Task Force recommends that the
extent of past solid waste disposal activities be clearly defined.
- The effect of the proposed construction of the Mi Hard Road overpass at
the northern boundary of the facility is as yet unknown. The Task Force
recommends that the Ohio EPA, and USEPA and the facility monitor any developments
in this area.
3. Task Force Sampling and Monitoring Data Analysis
During the inspection, Task Force personnel collected samples from six
bedrock wells, thirteen shallow Lacustrine wells, ten deep till wells, two
water line trenches and two leachate sumps. The purpose of this sampling was
to determine if any hazardous waste constituents or other indicators of
contamination could be found in the ground water at the FEI site. One problem
the Task Force encountered in making this determination was that many of the
wells were slow producing. Sixteen of the twenty-three deep till and shallow
Lacustrine wells did not produce enough water to sample for a full set of Task
Force parameters. Thus, gaps exist in the Task Force data. The facility's
past monitoring data were also reviewed for this evaluation. The Task Force
review of these data produced the following findings and recommendations:
- The Task Force data show 8.3 ppb of PCB's in upgradient well 36. It
is recommmended that the source of the PCB's be further investigated and that
TOX results from this bedrock aquifer be tracked closely during interim
status monitoring.
- The Task Force data from the shallow lacustrine wells show 17 ppb of 1,1-
dichloroethane in well F2s and 15 ppb of 1-formyl-2-piperidinecarboxyl ic acid
in well SOG-2. It is recommended that additional monitoring of this zone begin
immediately in order to establish the source of the detected constituents.
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- The Task Force data from the deep till wells show 0.58 ppb of 4,4'-DDT
in well Fid and 13 ppb of 2-methyl -cycl opentanone in well M4d. It is recommended
that additional monitoring of this zone begin immediately in order to establish
the source of the detected constituents.
- The Task Force did not find any indication of contamination in the water-
1ine trenches.
4. Compliance with Superfund Offsite Policy
Under current EPA policy, if an offsite TSDF is to be used for land
disposal of waste from a Superfund financed cleanup of a CERCLA site, the TSDF
must be in compliance with the applicable technical requirements of RCRA.
Interim status facilities must have adequate monitoring data to assess whether
the facility poses a threat to ground water. The Task Force identified some
concerns in the ground water monitoring system at FEI, as described above. The
Regional Administrator of USEPA Region V should take these concerns, and any
corrective actions taken by the facility, into consideration when determining
compliance with this policy.
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II. TECHNICAL REPORT
A. INVESTIGATIVE METHODS
The Hazardous Waste Ground Water Task Force (referred to hereafter as the
Task Force) investigations of Fondessy Enterprises, Inc. (FEI) consisted of:
- Reviewing and evaluating records and documents from the USEPA Region V,
the Ohio EPA, the Lucas County Health Department, and files maintained
by FEI.
- Conducting an onsite facility inspection from January 27 through
February 6, 1986.
- Evaluating the offsite laboratories contracted by FEI for analysis of
ground water samples.
- Sampling and analyzing data from selected ground water monitoring wells
and leachate.
The onsite facility inspection began on January 27, 1986, and was con-
ducted by three teams: the Technical Review Team, the Sampling Team and the
Laboratory Evaluation Team. The investigative methods used by these teams are
described below.
1. Technical Review Team
The technical review team was responsible for conducting an evaluation of
the facility with respect to applicable ground water monitoring requirements,
and to determine compliance with 40 CFR 265 Subpart F, potential compliance
with 40 CFR 264 Subpart F and 40 CFR 270.14(c), and Ohio Administrative Code
3745-65-90 through 3745-65-94. The evaluation was divided into the six princi-
pal areas:
- waste characterization and operations,
- site history and design,
- site hydrogeology,
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- ground water monitoring,
- ground water sampling and analysis, and
- ground water quality data and interpretation.
The Task Force core team in Washington O.C. contracted Planning Research
Corporation (PRC) of Chicago, Illinois to prepare a document package of pertinent
background information from public information sources, such as agency files.
The information collected by PRC primarily concentrated on events since about
1982, and projected future activities. Lacking from the PRC documents were
design plans, correspondence, and inspection reports prior to about 1982;
however, the PRC documents did contain logs for wells drilled prior to 1982.
To fill information gaps, files from the Lucas County Board of Health and the
Ohio EPA were reviewed by the Technical Review Team for historical information.
Aerial photographs of the site were also reviewed to supplement information in
the files. During 1985, a substantial amount of hydrogeologic information was
generated by FEI in response to an apparent ground water flow reversal in the
bedrock and a USEPA Notice of Deficiency with respect to the facility's
August 15, 1983, Part 3 permit application. Several reports and documents on
the subject facility became available during and after the field investigation
and were included in the evaluation. Combining these information sources, the
technical review team performed a thorough evaluation of the facility with
respect to ground water.
2. Laboratory Evaluation Team
The offsite laboratories that analyze water samples for the facility were
evaluated by the Region V Quality Assurance Office. FEI uses Biological and
Environmental Control Laboratories (BEC) of Toledo, Ohio, to collect ground
water samples and perform analyses for most 40 CFR Part 265 parameters. Clow
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Corporation of Pontiac, Michigan, and Environmental Testing and Certification
(ETC) of Edison, New Jersey, analyze organic samples, and Controls for Environ-
mental Pollution (CEP) of Santa Fe, New Mexico, performs radiological analyses.
An onsite inspection was made of each of these laboratories and a copy of the
full laboratory evaluations appear in Appendix C.
3. Sampling Team
Samples for the Task Force evaluation were collected by Versar, Inc.,
hereafter called Versar, an EPA contractor, under the continuous supervision of
an EPA Task Force member. Sampling procedures followed those outlined in the
January 1986 Quality Assurance Project Plan for this site. FEI personnel also
accompanied the sampling team at all times and video tapes were made of most of
the sampling activities. Dedicated sampling equipment owned by the facility
(Well Wizards® and Brainard-Kilman hand pumps) was used for sampling all wells.
Bailers provided by Versar were used to sample waterline trenches. Leachates
were pumped into dedicated 55-gallon drums by the facility; sample aliquots
were drawn from these drums. The hand pumps and bailers were operated by
Versar personnel. All samples and blanks (one per day) were split with the
facility. All sample bottles and preservatives were provided by Versar for
Task Force samples and split samples distributed to FEI.
Prior to purging, Versar personnel monitored the open well heads for
chemical vapors using an HNU® photo-ionizer. Task Force personnel then measured
the depth to water using an electronic water level indicator provided by either
Versar or the facility. This measurement was used to calculate purge volumes,
with a goal of purging three volumes of water from the well before sampling.
Purge volumes were measured in a calibrated container. Purging three volumes
was seldom possible because many shallow wells exhibited slow recovery rates.
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If this occurred, the well was purged dry (if three volumes could not be
obtained) and was revisited on the following day to begin sampling. If three
volumes could be obtained for the purge and there was liquid remaining in the
well, sampling was conducted immediately. If the well ran dry, it was revisited
the following day to complete sampling. A number of the wells were revisited
as many as three times (see Appendix B), without complete success in obtaining
the full range of samples. Appendix 3 details the purging and sampling infor-
mation. There was no purge conducted for the leachate or waterline trench
samples. Samples were collected in the parameter sampling order shown in
Table 1.
Volatile organic, Purgeable Organic Carbon (POC) and Purgeable Organic
Halogen (POX) samples collected for analysis by the EPA contract laboratory
and the FEI contract laboratory were first poured into a 250 ml beaker for
transfer into 60 ml glass vials sealed with caps having Teflon® septa. Each
beaker was dedicated to the well sampled. Remaining sample containers were
filled directly from a dedicated 2 1/2 gallon glass container, parameter by
parameter, to obtain exact splits. The samples were placed in ice-filled
coolers immediately after collection for storage and custody purposes.
After sampling was completed at a well, Versar personnel took the samples
to a central staging area, where field measurements for turbidity, pH, and
specific conductance were taken and one of the two sample aliquots for metals
analysis was vacuum filtered. In addition, metals, TOG, phenols, cyanide,
nitrate and ammonia samples were preserved as shown in Table 1. Leachate
samples were not preserved. For each day of sampling, Versar prepared field
blanks for each parameter group (e.g., volatile organics, metals) in the field.
14
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TABLE 1
ORDER OF SAMPLE COLLECTION
BOTTLE TYPE AND PRESERVATIVE LIST
Parameter
Volatile Organic Analysis (VOA)
Purge and trap
Direct inject
Purgeable Organic Carbon (POC)
Purgeable Organic Halogens (POX)
Extractable Organics
Total Metals
Dissolved Metals
Total Organic Carbon (TOC)
Total Organic Halogens (TOX)
Phenols
Cyanide
Nitrate/ammonia
Sul fate/chloride
Bottle
2 60-mL VOA vials
2 60-mL VOA vials
1 60-mL VOA vial
1 60-mL VOA vial
4 1-qt. amber glasses
1 qt. plastic
1 qt. plastic
4 oz. glass
1 qt. amber glass
1 qt. amber glass
1 qt. plastic
1 qt. plastic
1 qt. plastic
Preservative
HN03
HMOs
NaOH
5 mL
5 mL
5 mL
5 mL
5 mL
5 mL
15
-------
At the end of each day, samples were packaged and shipped to the two EPA
contract laboratories according to applicable Department of Transportation
regulations (40 CFR Parts 171-177). Aqueous samples from monitoring wells and
surface locations were considered "environmental" while those from leachate
collection system sumps were considered "hazardous" for shipping purposes.
B. FACILITY OPERATIONS, DESIGN. AND HISTORY
1. Background - Information Sources
The technical review team spent considerable time and effort researching
FEI's operational history. Information contained in the documents retrieved
and compiled by PRC, and learned during interviews of facility personnel,
provided minimal information on site activities prior to 1983. Detailed infor-
mation is available in agency files for site activities beginning with Cell H,
active since December 1983. The facility was in existence on and before
November 19, 1980, and has received interim status for the portion of the Otter
Creek Road property that is located north of York Road (see description of
facility to follow). Information concerning waste management units active
during interim status, and potential prior release areas, was used to evaluate
the ground water monitoring system.
The Lucas County Board of Health was responsible for inspecting land
disposal sites of solid waste in the 1960's, 1970's, and early 1980's. The
Board of Health files were reviewed and found to contain detailed plans of
FEI's Landfill Area 1 and Landfill Area 2, and inspection reports from the
mid-19601s to the present. Ohio EPA files also contained plans for Landfill
Area 2 and inspection reports similar to those in the Board of Health files. A
substantial amount of information on the types of waste received was also
16
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available in these files in the form of waste stream approval applications.
Toledo Environmental Services Agency (TESA) personnel were interviewed and
files reviewed for information on the raw waterlines that traverse the site.
Aerial photographs (some in stereoscopic coverage) from the U.S. Geological
Survey (USGS) and the Soil Conservation Service (SCS) were also reviewed. Many
investigations have been performed at the FEI Otter Creek Road Facility to
determine the suitability of the site for landfilling. Table 2 lists most of
the reports made available for Task Force review. Combining the various
information sources, a more complete history of the site operations is
presented below.
2. History
FEI began operations in the early 1950's as a salvage and reclamation
business. The facility obtained interim status in 1980 for landfill ing,
storage, and land treatment of hazardous waste. Conversion Systems, Inc.,
acquired FEI in June 1983. In January 1985, the ownership reorganized to form
Conversion Systems, and Envirosafa Services, Inc, with FEI as an operating
subsidiary of the latter. Envirosafa also operates a hazardous waste landfill
in Idaho. FEI owns and operates another facility in Oregon, Ohio, known as the
Wynn Road land treatment area. The FEI facility studied during this investi-
gation is commonly referred to as the Otter Creek Road facility, which is 124
acres in area. On November 7, 1985, Region V of the U.S. EPA received a letter
from FEI certifying compliance with the financial liability and ground water
monitoring requirements of RCRA at the Otter Creek Road facility.
Within the main portion of the Otter Creek Road property are two major
waterlines that convey water from Lake Erie to the Collins Park potable water
treatment plant of the City of Toledo. These waterlines pass through FEI in an
17
-------
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east to west direction between hazardous waste Cells H and I, with a 80 to 105
foot easement. The 78-inch line can deliver up to 110 million gallons of water
per day. This 9/16-inch thick bituminous coated steel pipe was installed in
1940. In 1973-1974, a half-inch cement grout lining was added to the interior
of the pipe. The pipe is located between eleven and twenty one feet below
ground level, and the invert level ranges east to west from 578.8 to 569.9 feet
above MSL.
The second water!ine, installed in 1964, is of sixty-inch diameter 16-
gauge steel encased in 3/8-inch thick precast, prestressed concrete pipe. The
pumping capacity of the pipe is 80 million gallons of water per day, and it is
located between 9 and 18 feet below ground level. The invert level within
the FEI site is between 580.6 and 572.0 feet above MSL (east to west). Both
lines are operated under constant low pressure ranging between 8.5 and 10.5 psi .
According to the Woodward-Clyde report (Reference 13, Table 2) the 78-inch line
was visually inspected in 1984 by the Toledo Department of Public Utilities.
Although spalled linings were found at two joints, the overall condition of
the interior of the pipe was considered to be good. FEI and City of Toledo
recognized the importance of protecting the waterlines from contamination in a
water!ine security agreement signed by both entities on March 22, 1984. The
agreement (see Appendix A) outlines design conditions and requires installation
of a monitoring system to insure protection of the waterlines from potential
contamination. The design conditions and nonitoring system are discussed later
in this report.
In the immediate vicinity of FEI are several facilities which may have an
impact on the area ground water quality. Figure 1 shows the property surrounding
FEI. The Westover landfills (solid waste disposal) are immediately north and
west of the facility.
20
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The newer Westover landfill (#5 in Figure 1), west of Otter Creek Road,
has received solid waste from 1974 through the present. Commercial , industrial ,
and household waste have been disposed at this landfill. Wastes are indicated
on design plans in Lucas County Board of Health files to be buried to depths of
65 feet below ground level .
The older Westover landfill (#6) and Commercial Oil, Inc. (#3) are located
immediately north of FEI. These two inactive facilities are related by operating
within the same borrow pit area; the pit was excavated prior to activity by
either facility, and appears to be as deep, about ten feet, as other borrow
pits visible in 1950 photographs reviewed by the Technical Review Team. The
northern portion of the pit was filled in by Commercial Oil to form holding
lagoons in the middle 1950's and early 1960's. The southern portion of the pit
was filled with solid waste in the early to middle 1970's as the Westover
landfill .
Commercial Oil was a waste oil recycling facility utilizing the lagoons for
oil storage. PCS levels as high as 160 ppm were found in samples of the lagoons
collected by U.S. EPA Region V personnel in April 1985. Commercial Oil has
been a CERCLA immediate removal site in the past and is presently undergoing
another removal action to stop the lagoons from overflowing.
A refinery of The Standard Oil Company (#2 on Figure 1) is also north of
the FEI property. Another waste oil dealer, William Rubin, operated "Bill's
Road Oil Service" (#17) during the 1970's and early 1980's on a portion of the
property that FEI currently owns, located south of York Road as a portion of
Area M. The waste oil operations included two storage lagoons which were
fil 1 ad in.
21
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During 1984, the City of Oregon, Lucas County, and the Port of Toledo
proposed constructing an overpass at Mi Hard Avenue which would be located
along the boundary between FEI and the old Westover landfill and would have
possible significant impacts on FEI's ground water monitoring system. Present
plans call for the proposed road and berm to pass over existing monitoring
wells, and would limit FEI's ability to construct wells in the future. Prelimi-
nary borings indicate that the roadway would cross over solid waste disposal
areas filled in the past by FEI and Westover. The regulatory agencies and FEI
will need to follow developments concerning construction of this overpass to
insure that compliance with RCRA ground water monitoring requirements can be
maintained.
3. Operations
Operations at the site during the Task Force investigation consisted of
disposal of hazardous waste by landfilling. FEI handles a large quantity of
RCRA-regulated hazardous waste including characteristic wastes (ignitable,
corrosive, EP Toxic); listed wastes; halogenated solvents; non-halogenated
solvents; metal treating process wastes; petroleum refining wastes; coking
wastes; and commercial or chemical manufactured products or off-specification
products. FEI is prohibited by the Ohio EPA from accepting the following
general categories of material for disposal: PCS, radioactive, reactive,
infectious, or shock-sensitive Class A explosive wastes, and pressurized gases.
FEI's procedures for waste handling have been developed over time. In
general, much simpler internal controls were used prior to 1983. Since 1983,
waste handling procedures were stated by FEI to be similar to those observed
during the Task Force inspection. Specific procedures for handling waste are
detailed and documented in FEI's internal Standard Operating Procedures (SOP).
22
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FEI's standard procedure for accepting a waste stream for disposal starts
with the generator's completion of the FEI form, "Application for Acceptance of
Waste Product" for each waste stream. The application identifies the generator,
the physical and chemical properties of the waste, the hazardous and DOT shipping
class, and the shipping frequency, volume, and condition. The application is
approved or disapproved by FEI and subsequently the Ohio EPA Northwest District
Office. The Ohio EPA may place conditions on the acceptance of the waste, such
as requiring a particular analytical test during characterization. Once a
waste stream is approved and given a Product Code Number (PCN), it is allowed
to be received in the frequency specified in the application.
Waste that arrives at the facility is stopped at the gate. The guard
assigns each truck a number for internal tracking, and visually inspects each
truck for liquids leaking from the bed. The truck is directed to the scales,
where its weight is determined. The manifest is checked for completeness and
the waste stream application is retrieved from the PCN file for comparison. A
composite sample of the bulk load is obtained with a spade by taking an aliquot
from each quadrant of the bed. The sampler also looks for abnormalities and
containers within the load.
The containerized loads are inspected in a different manner. All
containers are opened and checked for free liquid and void space. A composite
sample from 20 to 30 percent of the containers bearing identical PCN's are
obtained for analysis. The samples are placed in labeled plastic bags and
taken to the onsite laboratory for analysis.
Waste characterization (fingerprinting) done by the laboratory varies with
the type of waste received. The analyses may consist of, but are not limited
to, flash point, pH (of a 10% solution), chloride, cyanide, photoionization
23
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detection, thermoconductivity detection, alkalinity, metals, radioactivity,
moisture, and paint filter test. All wastes approved for disposal are assumed
compatible; compatibility screening is done during the initial waste stream
application review process. Generally, the facility accepts waste with a pH
greater than 5.0 s.u. and a flash point above 100°F.
Provided that there are no discrepancies with the manifest or load
characteristics, the truck is directed to the disposal area. Sulk loads and
containerized loads are handled differently. Bulk loads are directed to a
stone access road that leads to the waste cell. The vehicle enters the cell,
proceeding along the stone road to a ramp. The stone road provides access into
the cell without allowing direct contact of the truck with the waste in the
cell, minimizing the potential for tracking out waste. The truck is backed up
on the ramp and emptied. The driver remains inside the vehicle throughout this
process. FEI personnel perform all work required to empty the truck (opening
the tailgate, raising the bed, and cleaning residual material from the end of
the truck). The truck then leaves the cell and returns to the scale area for
an empty weight measurement. Final load weight is determined and checked with
the manifest. The manifest is signed and the transporter allowed to leave.
The scales are tied into a computer which is programmed to track the volumes of
waste received daily, by PCN. A data entry clerk uses data from the manifest
and daily scale records to generate information to be used in the facility's
annual disposal report to the U.S. EPA.
After the truck leaves the cell, a front end loader cleans the ramp. This
loader remains on the stone road with only the blade contacting any waste. A
second loader dedicated to the cell pushes the load into the active disposal
24
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area. The area is determined by survey markers on the edge of the cell and
five-foot vertical lifts. The coordinates of each load ara relayed to the
facility office and recorded on the daily record and a grid map.
After the containerized loads are opened and sampled, the truck proceeds
to the edge of the cell but does not enter it. Once approval is received for
disposal, FEI personnel fill any void spaces within the drums with kiln dust.
The drums are resealed, rolled onto a truck bed, transported by crane into the
cell, and gently rolled off. A bulldozer is used to push the edges of the
drums in place. The drums are not compacted or ruptured. The locations of the
drums within the cell are also noted on the aforementioned grid map. The grid
system has been developed over time with earlier grid systems being less
detailed. Containerized load locations are also noted on these grid maps.
During the Task Force inspection, both a bulk load and containerized load
were followed through the facility to observe waste handling procedures. The
procedures observed conformed with the facility's SOPs mentioned above. These
SOPs were in effect at the time of the Task Force inspection but have since
been upgraded by the facility.
4. Hazardous Waste Management Units
a. Cell H
The only hazardous waste unit receiving waste for disposal during the
investigation was landfill Cell H (see Figure 2), which was placed into service
to receive hazardous wastes on December 20, 1983 (see Table 3), and is located
in the northeast corner of the property. The cell has a surface area of
approximately 9 acres, with dimensions of about 490 feet by 760 feet, and 50
feet below ground level.
25
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Table 3
SUMMARY OF
FONDESSY WASTE MANAGEMENT UNITS
FONDESSY ENTERPRISES INC.
OREGON, OHIO
JANUARY, 1986
Unit Description
Approximate
Date(s) Active
Ash Disposal Area 1950's to late
1960's
Old Oil Pond
Current Oil Pond
Area H Oil Pond
Central Sanitary
Landfill
Northern Sanitary
Landfill
Mi Hard Avenue
Landfill
Cell F
Cell H
Landfarm Area I
Cell I
Area G
Area M
Surface
Impoundments
1950's to late
1969
Early 1960's to
1980
Mid 1970's to
1983
1969-1974
1974-1983
1976-1981
1980-1983
December, 1983
1980-1984
Under
construction
Future
Future
Future
* Solid waste refers to industrial , commercial
waste which may now be defined as hazardous
Use
Oil storage,
ash and sol id
waste* disposal
Use oil storage
and sol id waste*
disposal
Used oil storage
Used oil storage
Sol id waste* disposal
Solid waste* disposal
Oemol ition debris
solid waste* disposal
Sol id waste* and
hazardous waste disposal
Hazardous waste disposal
Hazardous waste treatment
Hazardous waste disposal
Hazardous waste disposal
Hazardous waste disposal
Hazardous waste disposal
and household waste, including
under 40 CFR Part 261.
26
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The construction of Cell H began in the spring of 1983 and was performed
in three phases, beginning in the northeast, and continuing to the west and
finally to the south and east. These phases were developed because of the
immediate need for disposal area. Wastes were disposed in the phase I portion
of the cell while the phase II and III sections were being excavated and
completed. The cell was excavated through Lacustrine deposits and into the
Upper Till. A ten-foot setback from the edge of the cell into the Lacustrine
was removed and replaced with recompacted clay during the construction. The
cell bottom and side slopes were lined with a 60-mil High Density Polyethylene
(HOPE) liner. A leachate collection system with two collection sumps was also
installed in the cell. Specific details about the design and construction are
contained in the Part 3 application and in FEI's internal QC/QA (Quality
Control and Quality Assurance) documents for Cell H. Figure 4 shows a typical
cross section and details of the base and cap construction. At the time of the
Task Force inspection, Cell H was nearly filled to ground level. Plans
indicate that the cell is to be finished at 40 to 45 feet above grade.
The aforementioned waterline security agreement between FEI and the City
of Toledo contains criteria for waste area locations, design, and construction
applicable to Cell H and any other future hazardous waste areas. These
conditions are presented in Appendix A.
b. Cell I
The next cell to be used for Hazardous Waste disposal is planned to be
Cell I. The excavation of this cell was underway during the Task Force inspec-
tion. Cell I is to cover an area of approximately 500 by 850 feet. The
designed base of the cell is planned at about 50 feet below ground level and
27
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Figure 4
Typical Cross Section and Construction
Details of Hazardous Waste Cell H
Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
SECTION £-6 (LC-2)
• CAll- H- 1'«««'
p- if' sou tr ro* so*, ir
(GCOC
r- acorcxT>i(
TOP COVSR 3Y3TEM
OCTAH. } (TYP.)
KOM t« TO
! — IMMt »* IXCAVATtOM -
LEACHATE CCH.LECTIQN ZONg
06TAJL 4 (TYPJ
28
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the final fill grade is about 50 feet above ground level. The cell is designed
to have a recompacted clay bottom and sides, HOPE liners on the bottom, top,
and sides, a leachate collection system, and a surface drainage system.
c. Future Cells G and M
Plans as presented in the facility's Part B application include hazardous
waste landfill cells designated as G and M, two surface impoundments, landfarm-
ing in the area of cell M, and treatment and storage of hazardous waste. Cell
G is located on the main Otter Creek Road property over the oldest disposal
areas. This area has interim status and is approved for use prior to final
approval of the RCRA Part 8 permit application. Cell G measures 375 by 900
feet and is designed to be about 70 feet deep and 50 feet above grade. Cell M
is south of York Road. The property south of York Road does not have interim
status and cannot be used for waste disposal until the RCRA Part B permit
application is approved. Cell M is planned to cover an area of approximately
1000 by 1500 feet. Both Cells G and M have been designed to include synthetic
liners, leachate collection systems, and surface drainage.
d. Cell F
Cell F was used for disposal of hazardous waste prior to Cell H. Cell F
is reported by FEI to have been active prior to November 19, 1980, and
until December 1983.. Little is known about its design and construction. The
first reference to Cell F was found in the June 1984 closure plan for the cell.
Historically, FEI has used several different systems to name the disposal
units, and as will later be discussed, the monitoring wells. Interpretation of
records is hampered by the changes of names. Often, the same designation is
applied to Tiore than one area.
29
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County and state inspection reports from the late 1970's and early 1980's
and aerial photographs from October 1980 indicate that Cell F was constructed
in phases, excavated and filled at different times during its useful life. A
1980 aerial photograph showed a north-south trench on the eastern side of cell
F. A mound, presumed to be a soil stockpile, is present in the northwest
corner of the Otter Creek Road property, and what appears to be undisturbed
land is located between the stockpile and the trench.
The combined area considered to be included in Cell F is about 320 by 500
feet. The depth of the cell is about 50 feet below ground level. The limit of
waste disposal is at 598 feet above MSL, or about 10 feet above ground level .
The cover currently ranges between 5 and 8 feet. This cell was finished at a
lower elevation to permit a vertical clearance easement to the Toledo Edison
Company for electrical powerlines which cross over the cell. The closure plans
for Cell F indicate that a leachate collection system is present within the
cell and show a vertical standpipe leading to a radial pattern of gravel drains
at the base of the cell. Approval for partial closure of Cell F was received
from the Ohio EPA in January 1986. Table 4 presents a summary of the wastes
disposed of in Cell F.
e. Land Treatment Area
Another hazardous waste management unit used at the site was the land
treatment area at the location of current Cells H and I consisting of a large
diked area covering portions of both cells. It appears to have been placed in
service in 1980 to receive petroleum wastes and to aid in the elimination of
the aforementioned oil lagoons. FEI reduced the area of the landfarm during
the excavation of landfill Cell H. The surface soils within the landfarm area
30
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TABLE 4
SUMMARY OF WASTE DISPOSED OF
WITHIN CELL F
(FROM CELL F'S CLOSURE PLAN)
FONOESSY ENTERPRISES INC.
OREGON, OHIO
JANUARY, 1986
Waste Type
D000(mixture
D001
D002
D003
D004
0005
0006
D007
0008
0009
D010
0011
D014
0015
D016
F001
F002
F003
F004
F005
F006
F007
F009
F010
Total Tons
rule) 5,392.10
8,403.91
976.39
941.67
1,274.38
576.93
4,053.37
3,531.02
24,486.63
61.18
74.36
33.01
0.25
0.58
93.18
105.21
352.20
175.58
156.01
44.29
22,305.01
17.77
22.39
9.10
Waste Type
Total Tons
F011
F017
F018
F019
K027
K048
K049
K051
K052
K061
K087
U051
U070
U122
U165
U188
U223
U226
Asbestos
Soil from Landfarm
CKD
Non-haz Industrial
Cover
Rubbish (est.)
0.90
13,419.85
223.91
231.18
386.68
10,662.94
10,503.24
10,272.42
530.37
5,411.37
248.16
1,090.77
2.70
59.84
501.23
18.30
17.02
0.23
2.17
1,945.70
567.90
7,919.41
5,228.00
100.00
31
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were removed and placed in disposal Cell F. Approximately 2000 tons of soil
were removed when the landfarm was taken out of service.
5. Solid Waste Management Units
a. Early Operations
FEI reports in a Part B application that operations began on January 1,
1954, as a salvage and reclamation business. Disposal of waste and storage of
oil in lagoons were a part of the operations at this time. The original opera-
tions occurred on a portion of the Otter Creek Road property designated in the
Part B application as parcels A, B, and C (see Figure 5). At that time, a
borrow pit dominated the area, extending from the aforementioned City of Toledo
waterlines to the northern and eastern edges of the parcels, and west, nearly
to Otter Creek Road. Within the borrow pit, a pond was present, appearing to
be fed by a northeast to southwest drainage ditch through parcel 0. The outlet
of the pond was a drainage ditch which flowed west into Otter Creek. A second
drainage ditch flowed into the borrow pit at its northeast corner. Between the
waterlines and York Road, a small depression also existed. This depression
became what is now called the "Old Oil Lagoon".
Aerial photographs from 1950, 1957, 1963, 1969, 1977, 1980, and 1985,
supported by county and state files, show the progression of disposal operations
at the site. Up to 1969, operations were limited to parcels A, B, and C. The
pond within the borrow pit was reduced in area and appeared to contain oil in
the 1957 and 1963 photographs. Area landfilling within the pit eliminated the
pond and filled most of the pit by 1969. An oil lagoon was constructed in the
eastern portion of the parcel by 1963, and operated until about 1980. This
lagoon was designated as the "Current Oil Lagoon" by the Fred C. Hart (Hart)
report of 1983 (Reference 8, Table 2). Based on the City of Toledo's 1986
32
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W wo' W
FIGURE 5
Fondessy Land Parcels North and South of
York Street
33 Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
-------
Woodward Clyde report (Reference 13, Table 2) on the waterlines, the lagoon was
phased out in the early 1980's by removing all liquids, stabilizing the bottom
with kiln dust, and backfilling. Samples collected by FEI prior to closure
showed detectable concentrations of cyanide, several polynuclear aromatic hydro-
carbons, and several chlorinated hydrocarbons. This lagoon covered approxi-
mately 1.6 acres and was between 12 to 15 feet below ground level. The area
south of the waterlines, known in the Hart report as the "Old Oil Lagoon",
appeared to occasionally contain water in the aerial photographs reviewed by the
Technical Review Team. No oil was noticeable in any of the photographs. The
"Old Oil Lagoon" was eliminated in 1969 by filling it with solid waste.
Leachate samples obtained from boreholes drilled by Hart within the "Old Oil
Lagoon" in 1983 showed detectable concentrations of arsenic, cadmium, lead,
silver, oil and grease, phenanthrene, phenols, and cyanide. The Hart leachate
sampling results were obtained from a summary in the City of Toledo's "Independ-
ent Technical Evaluation of the Waterlines Security Agreement", a public
document by Woodward Clyde (Reference 13, Table 2). These results are summar-
ized in Table 5.
A conical or tepee incinerator is visible only in the 1969 photographs.
The incinerator is reported in Lucas County Health Department inspection
reports from that period to have been used for the burning of dunnage, packing
used to protect cargo, from ships calling at the Port of Toledo. The incinera-
tor, rated at 100 cubic yards daily, was used from the mid-1960's to the early
1970's. Burning of waste was discontinued in 1969 with the adoption of
regulations in Ohio prohibiting open burning.
34
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TABLE 5
Analysis of Leachate from Fred C. Hart Borings
Fondessy Enterprises, Inc. - Oregon, Ohio
Area
Ash Disposal Area (closed)
Old Oil Pond
Current Oil Pond (closed)*
Central Sanitary Landfill (closed)
(Central portion of
Landfill Area 1)
Northern Sanitary Landfill (closed)
(Northern portion of
Landfill Area 1)
Leachate Contaminant(s) Found (mg/L)
No samples collected.
Arsenic 0.45
Cadmium 0.12
Lead 11.0
Silver
Oil 4 Grease
Content
Phenanthrene
Phenols
Cyanide
PCS
pH
0.16
165,000
975
7.6
0.048
<0.1
7.6
Mil lard Avenue Landfill (closed)
Cell F (to be closed)
Cell H (active)
Cell I (under construction)
Rain Water Pond (current)
Area G (future use)
Area M (future use)
Surface Impoundment (future use)
Lagoon and Storage Tank
Area H Oil Lagoon
Landfarm
* Samples were obtained by FEI while the
No concentrations were reported.
Cyanide
PCS
Several polynuclear aromatic hydrocarbons
Chlorinated hydrocarbons
Barium 5.9
Mercury 0.0075
Oil & Grease 4600
PCB <0.1
pH 8.2
Barium 3.5
Lead 1.5
Cyanide 0.833
Oil & Grease 1200
PCB <0.1
pH 8.1
No leachate was recoverable
No sampl es col 1 ected
No samples collected
No samples collected
No samples collected
No sampl es collected
No sampl es col 1 ected
No sampl es collected
No sampl es collected
No samples collected
No sampl es coll ected
unit was being taken out of service.
35
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b. Landfill Area 1
In 1969, FEI was first licensed for solid waste disposal and opera-
tions expanded north into parcel 0. Based on aerial photographs, design plans,
and inspection reports, approximately 10 trenches were located in FEI's
Landfill Area 1. These trenches were filled primarily between 1969 and 1983.
Deposited in these trenches were household, industrial, and commercial wastes,
demolition debris, and incinerator residue. The facility's response to a 1974
solid waste disposal questionnaire from the Ohio EPA indicated that approxi-
mately 700 yards of waste were received on an average operating day.
The trenches were excavated to an average base elevation of 570 feet above
MSI or between about 15 to 30 feet below ground level. The older trenches,
those under the southern mound of Landfill Area 1, were each about 60 feet
wide. Approximately six of these trenches were filled between 1969 and 1974.
Ohio EPA records show that in 1974 FEI received approval for the expansion
of the landfill as it existed at that time. The plans submitted with the
application indicated that the trench widths were to be increased to about 120
feet. Three of these trenches appeared to be under the northern mound of
Landfill Area 1. The larger trenches were used from 1974 to 1983. The plans
for trench construction showed a 10-foot separation between trenches and a
50-foot setback from the property lines. However, the separation and setback
practices actually followed by FEI are not documented. Shallow garbage deposits
have been identified in borings by the county in 1984 along the northern property
line, north of the northern mound of Landfill Area 1. Once a trench was filled
to ground level, waste disposal occurred above ground in area fills. While an
area was being filled, a trench in a different area would be excavated. The
southern mound of Landfill Area 1, also known as the Central Sanitary Landfill,
36
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was covered to an elevation of 638 feet above MSL at the peak. The northern
fill was finished at 640 feet above MSL. The area between the two mounds was
not filled above ground level because of the easement for the Toledo Edison
powerlines which cross the site.
Leachate samples were obtained from boreholes drilled in both mounds as a
part of the Hart investigation of 1983 (see Table 5). The samples from the
southern mound showed detectable concentrations of barium, mercury, and oil and
grease. The northern mound leachate samples exhibited detectable concentra-
tions of barium, lead, cyanide, and oil and grease.
c. Landfill Area 2
The Mi Hard Avenue Landfill, also known as Landfill Area 2, was operated
between 1976 and 1982. This landfill was located west of Otter Creek Road,
east of Otter Creek, and north of Mi Hard Avenue. The approximate area of
this triangular shaped landfill was 320,000 square feet. The maximum depth of
the cell was 45 feet below ground level. The waste was filled to approximately
30 feet above ground level. The design plans stated that because the Mil lard
Avenue Landfill is adjacent to Otter Creek, disposal was limited by the Ohio
EPA to demolition debris within a 200-foot setback from Otter Creek. The area
«
east of the setback was filled with a mixture of demolition debris and solid
waste. The design plans showed a gas vent and leachate monitoring system
installed in the cell. A partially perforated riser pipe is connected to a
perforated pipe that runs along the bottom of the cell parallel to Millard
Avenue. FEI personnel indicate no knowledge of any leachate removal from this
cell. During the Hart investigation, two borings were drilled into the cell.
An oily fluid was detected in one of the boreholes, but there was not enough
volume of leachate available to collect a sample.
37
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C. HYDROGEOLOGY
Many investigations have been performed at the FEI Otter Creek Road facil-
ity to determine the suitability of the site for landfilling (see Table 2). In
addition to reviewing the reports listed in Table 2, and agency files, the Task
Force viewed cores from some of the 1985 soil borings, observed fresh excava-
tions into the Upper Till within future Cell I, and interviewed FEI consultants
and representatives to characterize the geologic and hydraulic units at this
site.
1. Surficlal Geology
Prior to FEI's activities at this site, the topography of this area was
relatively flat, gently sloping toward Otter Creek and Lake Erie. The FEI site
is located on a drainage divide between Otter Creek and Oriftmeyer Ditch. Old
aerial photographs and topographic maps indicate that a portion of the site was
a borrow pit. Within the pit was a pond connected with Otter Creek by a drain-
age ditch. The pond is fed by another drainage ditch from the northeast. A
drainage ditch located on the western side of the Otter Creek Road facility
flowed south-southwest into Otter Creek. The second drainage ditch has been
filled in over the years and an underground pipe installed for drainage. The
northwesternmost portion of this drain is reported in Lucas County Health
Department files to have been sealed because of contamination from a nearby
landfill trench on FEI's property. The pond appears to have been used as a oil
storage lagoon and was eliminated as the borrow pit was filled. The current
major topographic features are the two mounds of FEI's Landfill Area 1. These
mounds are shown to peak at nearly 640 feet above MSL or about 40 feet above
the natural ground surface on recent topographic maps of the site prepared by
FEI consultants. Cell I was under construction during this investigation and
38
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constituted the major depression in the area, approximately 50 feet below
ground level. Unaltered by the site activity, the stratigraphic units from
surface to bedrock are topsoil, Lacustrine deposits, Upper Till, Lower Till,
and bedrock.
2. Subsurface Geology
The topsoil, ranging between two and four feet thick, is a silty clay or
silty clay loam derived from the underlying Lacustrine deposits. The majority
of topsoil, except for future cell M, has been disturbed or removed by activity
at the site.
The Lacustrine materials, also known as "yellow clay", were deposited by a
series of post-glacial lakes. The Lacustrine deposits can be described as a
yellow to brown to tan, varved silt and clay with isolated sand inclusions.
The unit is generally 10 to 20 feet thick, sloping toward the north-northwest.
In a 1985 Ohio Groundwater Consultants study (Reference 12, Table 2), a ten-foot
sand zone was identified at the base of the Lacustrine in boring Gl, near the
intersection of Otter Creek Road and Mil lard Avenue. Soil borings north,
south, and east of Gl do not indicate the presence of this sand zone. The
extent of this sand to the west is unknown. This sand does not extend over the
entire site, but may exist as a channel which was undetected by other borings.
Two till units identified on the site represent at least two Wisconsin
Age glacial advances. The Upper Till, also known locally as blue clay, was
deposited during a late Wisconsin glacial readvance approximately 13,000
years ago. This till can be described as a medium dense gray silty clay rang-
ing in thickness between 35 and 50 feet. The Upper Till has a finer texture
than the Lower Till, primarily due to the available source materials. The
Upper Till was derived from previous glacial materials and interstitial lake
39
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sediments, while the Lower Till was derived directly from bedrock or earlier
glacial deposits. Several soil borings show a sand, silt, or gravel zone
between the Upper and Lower Till. However, the zones between the tills are not
continuous across the site. Occasional sand zones were found with the Upper
Till, but also are not continuous over the site.
The Lower Till, described as "Hardpan" by local water well drillers, is
a very dense sandy silty clay with isolated sand deposits. The Lower Till
ranges in thickness between 12 and 30 feet. Both till units are present over
the entire FEI site and surrounding area. The Lower Till is often located
directly on top of bedrock, as indicated by most of the soil borings on the
site. Several borings show a sand and gravel zone between the Lower Till and
bedrock. The top of the bedrock was also noted to be weathered in several
borings. The uppermost unit of bedrock is the Silurian Age Greenfield member
of the Bass Islands formation. The Greenfield is a dolomite deposited as a
shallow marine evaporite approximately 410 million years ago. The Greenfield
can be described as a brown, microcrystal1ine, medium bedded dolomite contain-
ing stylolites and stromatolites. The Greenfield is present over the entire
site and most of Lucas County. The dolomite can be found at depths beginning
at 70 to 90 feet below ground surface and continuing for 32 to 65 feet in
thickness. Based on permeabilities, FEI consultants estimate recharge of the
bedrock from the tills on the site to be on the order of 92 gallons per day per
acre.
The Greenfield dolomite is underlain by the Lockport formation, approxi-
mately 175 feet of white to light gray, or brown dolomite and limestone.
Commonly, this formation is coarsely crystalline, vuggy, and fossiliferous.
40
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3. Ground Water Conditions in the Bedrock
The Greenfield and Lockport formations, the uppermost units of bedrock,
are present over the entire site and Lucas County and are the primary source of
domestic and industrial ground water in the area. The amount of ground water
used from these units has decreased dramatically in the past forty years.
Heavy industrial pumpage in Toledo during the mid-1940's and 1950's created a
large cone of depression in which ground water in the dolomite and limestone at
the FEI site flowed in a southwest direction toward the cone of depression.
Pumping was reduced in 1958 and ground water levels subsequently stabilized and
then slowly began to recover. During the latter part of 1984, FEI installed
continuous water level recorders in five bedrock wells to resolve confusing
water level measurements and to determine if there had been a change in ground
water flow directions. The initial recorder data indicated a flat potentio-
metric surface. The facility also contends that barometric pressure changes
can be responsible for changes in water levels over time which are greater than
the gradient across the site. Ground water in the dolomite at FEI is now
reported to flow in a north-northeast direction.
The Standard Oil Company refinery, located immediately north-northeast of
FEI, has numerous production and monitoring wells in the bedrock. Ground water
pumping is greatest during the summer, creating a cone of depression. Inter-
mittent pumping occurs year-round. The ground water flow rate toward the
north-northeast is increased when pumping occurs.
The U.S. Geological Survey (USGS) in Columbus, Ohio was contacted to
obtain additional information about the Greenfield and Lockport Formations.
The USGS is conducting a regional ground water study for the Toledo area in the
summer and fall of 1986, including the area of FBI's Otter Creek Road facility.
41
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A preliminary evaluation of water level measurements obtained by the USGS
during 1986 indicate the regional ground water flow direction in the Greenfield
and tockport formations under eastern Toledo and Oregon to be toward the south-
east. Preliminary USGS findings indicate the ground water flow direction
differs from that reported by FEI; however, this may be attributed to local
influences such as The Standard Oil Company's pumping. The ground water flow
direction at FEI is best indicated by water level measurements at the site.
As a part of the Task Force investigation, U.S. EPA personnel obtained
water level measurements from all FEI monitoring wells on January 23, 1986,
prior to purging or sampling any of the wells. Ground water elevations in the
bedrock wells were plotted to identify the local ground water flow direction.
Figure 6 shows a flat potentiometric surface over the FEI site. The maximum
difference in elevation is less than 0.25 feet. No uniform flow direction is
indicated by these measurements. However, the water level indicator used for
these measurements malfunctioned during use, and may have reduced the accuracy
of some of the measurements.
A core of the upper 115 feet of bedrock from the northeast intersection
of Otter Creek Road and York Street was obtained by FEI in August 1985, and a
performance test of the limestone and dolomite was conducted in October 1985.
From these two events, some characteristics of the dolomite and limestone were
qualified by FEI in reports included in the Part B application (see Reference
14, Table 2).
The porosity of the dolomite and limestone was visually estimated by FEI
consultants from the rock core. The range of porosity within the Greenfield
ranges between 0 and 25 percent and averages 8 percent. The Lockport Formation
ranges in porosity between 5 and 40 percent and averages 22 percent. The
42
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Figure 6
Ground Water Elevation Measurements
from January 23, 1986. (Bedrock Wells'
Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
43
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transmissivity was observed to range widely, from 10,000 to 66,000 gpd/foot,
because of variations in the water holding capacities of the units. A
transmissivity of 27,000 gpd/foot was determined by FEI consultants to be a
representative average for the units. This value was estimated from the average
transmissivity, 25,000 gpd/foot, and the transmissivity determined by a
distance-drawdown plot as 27,582 gpd/foot. The coefficient of storage determined
from the distance drawdown was 9.37 x 10~5. A hydraulic conductivity of
32 feet/day was calculated from the performance test. Utilizing Darcy's
equation, the ground water velocity in the dolomite and limestone averages 6
feet per year in the winter and 45 feet per year in summer when the Standard
Oil Company's pumping is maximum. The net flow averages 28 feet per year. The
ground water flow direction in the dolomite and limestone is toward the north-
northeast.
4. Ground Water Conditions in the Unconsol idated Sediments
The hydraulic zone identified nearest to the surface is the Lacustrine
deposits and the Lacustrine and Upper Till contact. FEI performed laboratory
tests on samples in 1985 and determined the vertical permeabilities to be on
the order of 10~7 to 10~8 cm/second. The hydraulic conductivities, average
values over the length of the sand pack, were determined by slug tests and
found to be between 10~5 and 10~? cm/second.
Similar tests were conducted on the hydraulic zone at the Upper Till/Lower
Till contact. Vertical permeabilities were determined by laboratory tests to
be on the order of 10~8 to 10"9 cm/second, while hydraulic conductivities
determined by slug tests were about 10~6 to 10-? cm/second.
The ground water flow directions and rates within these two zones have not
been determined. Potential horizontal flow is indicated due to the changes in
44
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static head with distance. No pattern of head distribution was discernible
from the water level measurements obtained by the U.S. EPA on January 23, 1986.
Potential vertical flow from shallow zones to lower zones is indicated by the
decreasing static head with depth observed in water level measurements obtained
by the U.S. EPA and FEI. In 1985, FEI installed wells within the till units
but not at the contacts, to confirm if water is moving vertically through the
tills to bedrock. No data are yet available from these new tills wells at this
writing.
All of the wells in the unconsolidated sediments contained some water.
However, only 3 of 23 wells sampled were capable of yielding three times the
standing water volume for the purge. Seven of 23 wells produced a sufficient
volume of water (about 8 gallons) for all Task Force samples and splits
provided to FEI. Most of the wells required more than one day to purge and
sample.
D. GROUND WATER MONITORING
1. Pre-RCKA Monitoring
The history of ground water monitoring well installation is directly
related to the hydrogeologic studies conducted at the site. Typically, mon-
itoring wells were installed in some of the borings drilled as a part of the
hydrogeologic investigations conducted by the facility. The first ground water
monitoring wells were constructed in 1974. Eight 2-inch diameter PVC wells were
installed around the main Otter Creek Road property. These wells were
constructed at depths of about 20 feet below ground level. Four additional
wells near the Millard Avenue Landfill were added to the monitoring system in
1978; little is known about their construction. Five additional wells were
added in January 1981.
45
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Samples are known to have been collected semiannually since 1978 and
analyzed for:
- pH
- Total Alkalinity
- Total Hardness
- Total Iron
- Chloride
- Sulfate
- Nitrate
Sampling of all twelve wells and selected other points (domestic wells,
creeks, city drinking water) continued until 1982 for an expanded list of
components which included:
Total Iron - Total Kjeldahl Nitrogen
Total Lead - Nitrate
Total Magnesium - Sulfate
Conductivity - Chloride
Total Organic Carbon - Non Filterable Residue
Total Dissolved Calcium - Total Residue
Total Alkalinity - pH
Ammonia-nitrogen - Oil and Grease
The reliability of these data for use in determining the existence of
contamination at this site is limited. This is due to the lack of a documented
sampling and analysis program, including provisions for quality assurance, and
several changes in well designations during this period.
2. Interim Status Ground Water Monitoring
The initial RCRA ground water monitoring system as it existed during 1982
consisted of four wells designated as 1, 5, L, and H. Each of these has
subsequently been known by other designations:
Well 1 is still known as well 1 and also SUG-1.
Well 5 is currently known as well 10 or SDG-2.
46
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Well L has also been known as DEB 9, Well 5, and DDG-3. This is not the
same well as ODNR well 615064 or the well currently known as DDG-3. FEI
reported that well L was apparently destroyed and replaced by ODNR well
615064 on June 23, 1983. No new background data were developed for the
replacement we!1 .
Well H has also been known as MH 13, Well 7, and DDG-2. Although DDG-2
and well H appear on different well location diagrams to be hundreds of
feet apart, FEI contends that Well H and DDG-2 are the same and that the
older diagrams are inaccurate.
Changing of well designations was common until recently, when FEI
acknowledged the confusion these changes caused. Two of these wells, 1 (SUG-1)
and 5 (SDG-2), are the original 1974 shallow wells. The other two wells used
for RCRA monitoring at this time, Well L and Well H, are converted domestic
wells completed in the bedrock. Well 1 was designated upgradient by FEI and
wells 5, L, and H were designated downgradient. These wells are not completed
in the same stratigraphic zone. The data generated during 1982 indicate that
FEI generally sampled and analyzed ground water from these wells at the frequency
and for the constituents specified in 40 CFR Part 265.92. Replicate samples
for the indicator parameters were not collected in 1982. Only one value is
presented per quarter for each of the indicator parameters.
In 1982, the Ohio EPA received an alternate ground water monitoring system
proposal from FEI. This plan proposed monitoring of eight Lacustrine and till
wells, and one bedrock well. This plan was not approved.
Four additional bedrock wells were drilled in 1982 and 1983. The wells
were cased to the top of the bedrock with 4-inch inside diameter carbon steel
casing. The annul us, the area between the casing and the strata, is reported
on the well logs to have been backfilled with cuttings. No seal is reported on
the logs at the base of the casing. These wells are designated as OUG-1,
DUG-2, DDG-1, and DOG-3. A new ground water program utilizing these wells was
47
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received by the Ohio EPA on March 1, 1983. Well OUG-2 was not included in the
plan, but was installed shortly afterward (May 1983). Monitoring wells
designated as DUG-1 DUG-2, DOG-1, DDG-2, and DDG-3, were sampled for RCRA
monitoring purposes during 1983 and 1984. Wells SUG-1, SDG-1, and SDG-2 were
also sampled during this time. Wells DUG-1 and OUG-2 were designated upgradient
and ODG-1, DDG-2, and DDG-3 designated downgradient.
As stated in the Section II.C., FEI reported a ground water flow direction
change to the regulatory agencies in January 1985. Subsequently, a new moni-
toring systan was developed by FEI. Eight new wells designated Rl through R8
were drilled between about April 1985 and September 1985. The new monitoring
system consisted of thirteen bedrock wells (see Figure 7). This monitoring
system was in use during the Task Force inspection. The first sampling of
these monitoring wells in 1985 was during September. One year of quarterly
background is required by RCRA for the new monitoring wells. FEI reports-that
the DOG and DUG wells have been replaced since the Task Force inspection by
bedrock wells designated R9 through R13. All "R" series wells are constructed
similarly to Well Rl, illustrated in Figure 8. The installation methods and
construction materials indicate these wells to be capable of yielding samples
representative of ground water. The description of well installation below was
taken from Volume 4 of Reference 14, listed in Table 2.
"Well construction started with a 6-inch diameter borehole drilled by
cable tool. The outer protective casing was advanced as the hole was
drilled. The boreholes penetrated 10 to 18 feet, as an average, into the
bedrock aquifer. Drilling was terminated when the volume of ground water
encountered was determined to be sufficient for sampling purposes.
"The 6-inch diameter borehole was flushed for several hours to remove all
rock cuttings and any extraneous water that had been added during the
cable tool drilling. The inner casing, consisting of 2-inch diameter 316
stainless steel casing and a 5-foot section of stainless steel screen with
0.010-inch slots, was then set into the bedrock. A filter pack of Ottawa
48
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Figure 7
Interim Status Ground Water Monitoring
System, January 1986
Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
49
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Figure 8
Bedrock Well R-l Construction Details
Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
EECOeCL
SJTE
COORDINATES
DATE COMPUTED
SUPERVISED BY HdflTZELL
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ELEV.4T/CN Of REFERENCE POINT
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'GROUND SURFACE
OP
TYPE CF 5€a:RlTY
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!;D. OF RISER RPE
OF RISER RPE
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L EL EVAT;CN/ DEPTH OF TOP OF SCREEN -
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I.a OF SCREEN SECTION
fELFVATION / DEPTH OF BOTTOM OF
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: ELEV./DEPTH OF BOTTOM OF PACK -T.
•lELEV./DEPTH OP BOTTOM OF PLUGGED
BLANK SECTION
(TYPE OF FILLER BELOW PLUGGED
ELEV./DEPTH OF BOTTOM OF BOREHCLf -
50
WELL CONSTRUCTION SUMMARY
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sand was placed around the screen and filled the borehole to a height of
2 to 6 feet above the top of the screen. The well screen and sand pack were
sealed into the bedrock with a layer of bentonite pellets several feet
thick. The remainder of the annular space between the inner and the outer
casings was pressure-grouted with a bentonite slurry that extended from
the top of the bentonite seal up to ground surface.
"All the tools and well materials were steam cleaned prior to use. The
wells have locking caps and dedicated stainless steel and Teflon® sampling
pumps. All the wells have locking caps, and their water level measurement
reference points have been surveyed to the nearest 0.01 foot by a licensed
surveyor."
3. Other Ground Water Monitoring During Interim Status
a. Ground Water Monitoring Wells
In late 1984 and continuing into 1985, FEI conducted a hydrogeologic
study of the site to characterize the geologic and hydraulic properties of the
lacustrine and till deposits. Nearly twenty five borings were drilled and
logged during this study, with two piezometers installed in the vicinity of
each boring.
These piezometers are generally nested, with wells completed at the
Lacustrine/Upper Till contact and the Upper Till/Lower Till contact. Typical
well construction consists of 2-inch diameter Schedule 40 PVC with PVC screens,
5 feet long, having 0.010-inch slots. The screens have sand packs extending
from the bottom of the boring to a level 2 to 9 feet above the top of the
screen. The sand pack is sealed from the remainder of the borenole by a
bentonite pellet layer or slurry, 3 to 10 feet thick, and the remainder of the
annulus is filled with a bentonite slurry up to the ground surface. Initially,
a bentonite-cement grout was used (wells F-l and G-l), but the subsequent wells
were grouted with bentonite only.
Each of these piezometers are equipped with dedicated 1.7-inch Brainard-
Kilman hand pumps. FEI uses these wells for water level measurements to
51
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determine ground water flow potentials and to obtain ground water samples for
use in determining ground water quality and the presence of hazardous waste
constituents in the ground water.
b. Monitoring Trenches
As referenced previously, the City of Toledo and FEI signed a Waterlines
Security Agreement on March 22, 1984. This agreement is designed to safeguard
the two raw waterlines which cross the site from possible contamination by
FEI's waste disposal landfill. The agreement (Appendix A) addresses six general
topics which include:
Survey and monument installation - Monitoring system
Waste area location - Site inspection
Waste area design/construction - Termination agreement
The monitoring system (and site inspection and testing program) is
discussed below based on the written agreement, diagrams made while the
monitoring system was built, a technical evaluation of the agreement by
Woodward Clyde Consultants (Reference 13, Table 2), and information reviewed
during the Task Force survey.
The agreement states that waste cells shall be offset a minimum of 40 feet
from the closest watarline and that monitoring trenches will be installed
within this 40' buffer zone. Each areas monitoring trench shall be installed
after the construction of the waste cell liner and prior to waste reaching a
level of the lowest limit of the waterline on the side closest to the waterline.
To date, two monitoring trenches have been constructed. These trenches
are located north and south of the water lines, adjacent to Cells H and I.
These will be referred to as trench H (north) and trench I (south) hereafter.
Cell H is currently active and Cell I is under construction as indicated
previously.
52
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The location of the water!ines has been marked on the ground surface above
the lines with iron stakes and the offset boundaries are marked with concrete
monuments (as the agreement specifies). A distance greater than 40 feet
(approximately 45 feet) is maintained between the waterlines and the current
disposal cells. The monitoring trenches (both H and I) parallel the waterlines
and maintain a 20-foot offset from the lines.
The bottom of trench H was excavated to a depth of 578 to 580 feet above
MSL which maintains a minimum depth of one foot and maximum depth of 2.5 feet
beneath the bottom of the northern water line. The bottom of trench I was
excavated to a depth of 574 to 575.5 feet above MSL and maintains a minimum
depth of 2 feet and maximum depth of 3.5 feet beneath the bottom of the
southern 78-inch waterline. The trench bottoms are sloped toward sumps that
are spaced approximately 250 to 300 feet apart.
Trench H is approximately 2.5 feet wide from top to bottom. Trench I is
3.5 feet wide at the base, becomes 4.8 feet wide throughout the middle half,
and the uppermost 4.5 feet is 14 feet wide. Trench H is filled with gravel to a
level 2 feet from the surface. Trench I has a five to 6-inch pipe in the bottom
and is filled with gravel up to 4.5 feet from the surface. Both trenches have
been sealed with recompacted blue clay above these gravel packs to prevent
infiltration of surface water.
Three sumps along both trenches are located at the low points within the
trenches. The bottoms of the sumps are 2.5 feet beneath the bottom of the
trench. These sumps are packed with gravel and have a riser pipe, slotted
within the sump, connecting the sump with the surface. Trench H has 6-inch PVC
riser pipes, and trench I has 12-inch PVC riser pipes. The integrity of the sump
is maintained using a two to 3-inch diameter pipe set vertically within the
sump hole.
53
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Weekly inspections of all boundaries, liners, and trench caps is specified
in the agreement to detect erosion or damage to the monitoring system. If
liquid is found, samples will be taken and tested (at least semi-annually) for
40 Part CFR 265 indicator parameters. Additional testing protocols are to be
employed should the indicator parameters results indicate significant levels.
In 1985, the City of Toledo hired Woodward-Clyde Consultants to perform an
Independent Technical Evaluation of the Water!ine Security Agreement (Reference
13, Table 2). This evaluation concluded that, proper implementation of the
Security Agreement should result in maintenance of continued acceptable per-
formance of the pipelines. The consultants recommended the following to
enhance the technical security of the pipelines:
Summary of Primary Recommendations
To provide ample warning time to take corrective measures, the depth of
the future monitoring trench should be no less than 3 feet below the
Lacustrine Clay-Glacial Till interface, or 5 feet below the invert level
of the nearest waterline, whichever is deeper. The width of the trenches
should be no less than 2 1/2 feet.
The recompacted blue clay cap for all trenches should be no less than
3 feet thick.
Monitoring the raw water in the pipelines, upstream and downstream of the
site, should be conducted as described in the text.
Analysis of roadways crossing the pipeline should be conducted to verify
the pipelines' likely structural integrity.
Moisture contact control, as well as density, should be part of compaction
specifications.
The interior of the pipelines, and the outside (if possible) should be
monitored every five years for corrosion.
54
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4. Ground Water Monitoring Proposed for RCRA Permit
FEI was in the process of preparing a revised Part 8 application to meet
the requirements of 40 CFR Part 270.14(c) and 40 CFR Part 264 Subpart F during
the January 1986 field evaluation. The Task Force deferred review of the
proposed ground water monitoring system until the revisions were available.
The revised ground water monitoring system proposal was completed by FEI in
February 1986, and partially revised again in July 1986. FEI provided a copy
of the revised Part B application pertaining to ground water to the Task Force.
Discussed below are the point of compliance, proposed bedrock and leak detection
wells, and constituents for analysis.
a. Point of Compliance
In the revised Part 3 application, FEI proposes to represent the point of
compliance by a line starting at the northwest corner of the property near
Landfill Area 2, following the northern and eastern property boundaries to a
point near the northeast corner of Cell I (see Figure 9). The point of compli-
ance as described by FEI crosses Otter Creek Road between Landfill Area 2 and
Cell F. The waste management area of FEI is not delineated on a topographic
map as required by 40 CFR Part 270.14(c)(3).
The waste management area is defined in 40 CFR Part 264.95(b) as " the
limit projected in the horizontal plane of the area on which waste will be
placed during the active life of a regulated unit." Since "the facility
contains more than one regulated unit, the waste management area is described
by an imaginary line circumscribing the several regulated units." The point of
compliance at which the ground water protection standard of 40 CFR Part 264.92
applies and at which monitoring ,nust be conducted is "a vertical surface
55
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Figure 9
FEI's Proposed Point of Compliance
Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
56
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located at the hydraulically downgradient limit of the waste management area
that extends down into the uppermost aquifer underlying the regulated units,"
as provided in 40 CFR Part 264.95.
The regulated units at FEI which received hazardous waste after July 26,
1982, are Cells F and H. As additional units are used for hazardous waste
disposal, FEI will be required to ensure that the ground water monitoring
system fulfills the appropriate regulatory requirements. Of particular
concern to the Task Force was future Cell M. Area M is distant from the point
of compliance (greater than 1000 feet). The Task Force recommends that Area M
should be monitored at its downgradient limit.
b. Well Locations - Bedrock Wells
FEI contends that the bedrock, principally the Greenfield and Lockport
formations, is the uppermost aquifer under the facility. The proposed monitor-
ing system consists of thirteen wells; all are composed of stainless steel,
equipped with dedicated sampling devices, and constructed in a similar manner
(see Section II.D.2.). The "DUG-DOG series" wells have been retired and
replaced with "R series" wells as proposed in the February 1986 Part B applica-
tion revision. The proposed bedrock monitoring system consists of six wells
designated as upgradient; R-2, R-6, R-7, R-ll, R-12, R-13, and seven wells
designated as downgradient R-l, R-3, R-4, R-5, R-8, R-9, and R-10 (see Figure
10). The continuous water level recorders remain in the "DUG-DOG series" wells
for use in determining ground water flow directions.
The downgradient wells are spaced at an average of 500 feet along the
northern and eastern property boundaries. The rationale for well placement is
not shown in FEI's 1986 Part B application revision. The Technical Review Team
used Table 2-1 of the August 1985 draft of the Technical Enforcement Guidance
57
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Figure 10
FEI's Proposed Bedrock Monitoring Wells
Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
58
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Document (TEGD) published by USEPA, to evaluate well spacing. The results of
the evaluation indicate that the wells should be more closely spaced than they
were at the time of this review. Using the final TEGD (September, 1986) the
Task Force came to the same conclusion.
All bedrock wells are screened near the top of the bedrock. The facility
presents no discussion or information on the vertical movement of the ground
water within the bedrock.
c. Well Locations - Leak Detection Wells
FEI proposes to monitor nine well cluster locations, generally along the
facility's defined "point of compliance" for leak detection (see Figure 11).
Each well cluster consists of two wells, one screened at the Lacustrine/Upper
Till contact, and the other screened at the Upper Till/Lower Till contact.
Each leak detection well has similar construction (see Section II.D.3) and a
dedicated sampling device.
The Task Force determined several concerns with respect to the sampling
equipment in the leak detection wells, which, as described previously, were
hand pumps manufactured by Brainard-Kilman. The main concerns with the pump
are summarized below:
- The bottom of the well cannot be measured without removing the pump.
Bottom measurements can be used to determine if the well is silting up.
- The operation of the PVC pump may allow volatile compounds to escape.
Laboratory testing is recommended to demonstrate if the pumps retain volatile
compounds under low-yield conditions.
Since ground water movement directions or potentials within the uncon-
solidated sediments are not known, placement of detection wells only along the
northern boundaries of the site is inadequate. The detection wells should
circumscribe the waste management areas.
59
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Figure 11
EEI's Proposed leak Detection Wells
Fondessy Enterprises, Inc.
Oregon, Ohio
January, 1986
60
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The spacing of the detection wells proposed by FEI is generally 500 feet.
However, the interval between two of the wells, F-l and H-2, is about 1000
feet. The rationale for horizontal spacing of leak detection wells is not
presented in the Part B application. The consensus reached by the Technical
Review Team is that the vertical spacing of the wells, in the unconsolidated
materials at the Lacustrine/Upper Till contact and the Upper Till/Lower Till
contact, appears adequate.
d. Constituents for Analyses - Bedrock Wells
FEI's revised Part B application presents a discussion concerning the
choice of constituents for analysis. To choose the constituents, FEI addressed
the following areas:
Presence in the leachate
Geologic, physical, and chemical
characteristics of the soil
Transformation
Degradation
Immobilization
Ground water flow rate and direction in the bedrock is to be determined
annually by analysis of ground water elevations, and/or pump or slug test. The
Task Force recommends that the ground water flow rate and direction be
determined more frequently than annually due to the observed flat potentiometric
surface, the documented recent seasonal ground water flow reversals, and local
influences on ground water flow directions such as the Standard Oil Company's
pumping. The Task Force also recommends that ground water levels in all wells
on the site be used to determine the ground water flow rate and any localized
variations.
The facility will establish background data for any parameter for which
there is no previously established background data, by sampling quarterly for
one year. The constituents were divided into the three sections below.
61
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i. Proposed Indicator Parameters
The facility proposes to sample and analyze on a semiannual basis the
following parameters:
- pH
- specific conductance
- total organic carbon
Statistical analyses are proposed to be performed on the analytical data
on a semiannual basis. FEI proposes to use analyses of covariance to determine
the presence of a statistically significant difference between upgradient and
downgradient water quality. An Ohio EPA evaluation of this method has found
it to be inappropriate; thus, the Task Force recommends that this statistical
evaluation not be used to determine significant differences between upgradient
and individual downgradient wells along the point of compliance.
11. Proposed Ground Water Quality Parameters
The six constituents proposed by the facility for monitoring ground water
quality on a semi-annual basis are:
- Sodium - Chloride
- Manganese - Sulfate
- Iron - Phenol
Statistical analyses consistent with those performed for the indicator param-
eters are proposed to be performed on these data. When one or more of the six
constituents are detected, the frequency of monitoring for that constituent is
proposed to be increased to quarterly. If concentrations are found to increase
for three consecutive quarters, then the provisions of 40 CFR 264.98(h) are to be
implemented. The detection limits should be presented with the constituents
in the Part B application. Appropriate detection limits will aid in determina-
tion of offsite migration. The Task Force also recommends that 40 CFR Part
264.98(h) be implemented as soon as a constituent is found to statistically
increase.
52
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i i i. Proposed Waste Constituents
The following thirteen Appendix VIII compounds were proposed by the facil-
ity for semiannual monitoring:
- Cyanide - Hexavalent chromium
- Xylene - Cadmium
- Toluene - Benzene
- 1,1-dichloroethane - 1,1,1-trichloroethane
- Chloroform - Trichloroethylene
- Ethyl benzene - 1,2-dichloroethane
- Lead
Compliance monitoring is proposed to be implemented only if three or more of
these thirteen compounds are detected in samples taken on two sequential sampl-
ing events.
The Task Force recommends that detection limits be presented with the
constituents listed in the Part B application. Appropriate detection limits
will aid in the determination of offsite migration. The Task Force recommends
that a determination be made of the effect of halogenated organic compounds on
present TOX values, and that any compounds found be added to the above list. It
is also recommended that methylene chloride and methyl ethyl ketone be added to
the list.
e. Constituents for Analysis Leak Detection Wells
The leak detection system is to be sampled on an annual basis for the
13 waste constituents listed in Section d.iii. above. FEI proposes to tabulate
the results and use them to determine offsite migration. No details concerning
how this will be done are presented in the revised Part B application.
5. Sampling and Analysis Plan (SAP)
On January 8, 1986, sampling procedures were demonstrated by BEC, FEI
contractors, for Task Force personnel. Some difficulty was encountered due to
63
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extreme cold weather conditions, which caused Well Wizard® hose lines to freeze.
Each stage of the sampling process is discussed below. Specific details of
ground water sample collection are contained in FBI's internal "Standard
Operating Procedures." These SOPs are not discussed here because FEI asserted
RCRA confidentiality.
a. Water Level Determination
This determination according to the facility SAP is made using the Well
Wizard® Water Level Meter, model 6000. The SAP states readings are to be
recorded to the nearest hundredth (0.01) foot. The tape accompanying this
device, as described in current literature, is graduated in twentieths (0.05)
of a foot. The actual water level probe used for the observed sampling
demonstration appeared to be equipped with a different tape than described in
current Well Wizard® literature. The tape used was round instead of flat and
was graduated in tenths (0.10) of a foot. The SAP suggests the use of a
chalked tape in the absence of a properly operating electronic water level
probe, this method is not recommended. The field demonstration effort
indicated field personnel did not rinse the level sensor probe or tape between
wells. This is recommended procedure and should be documented in the SAP.
b. Well Evacuation
Several different procedures are followed for well evacuation at FEI.
These procedures depend on the presence of various dedicated pumping devices
which, in turn, are correlated to well construction and the zone in which the
well is finished. One general procedure used with all types of well evacuation
equipment was the disposal of purge water. The standard practice for disposal
was to dump purge water on the ground near the well being purged. This procedure
should be specified in the SAP. Should a well be determined to be contaminated,
an alternative method for purge water disposal is recommended to be specified.
64
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Evacuation of two-inch inside-diameter bedrock wells is accomplished by
dedicated bladder pumps (Well Wizards®) installed two feet above the well
screen. The pumps are composed of Teflon® and the well casing and screen are of
stainless steel construction. The SAP indicated these types of wells are
equipped with inflatable packers to reduce the purge volume required. This
device was not used in the demonstration to the Task Force. The total volume
of the well was calculated and three times that volume was planned to be evacu-
ated. The actual volume evacuated was based on the pump rats as supplied by
the manufacturer. Using the demonstrated method of evacuation the Task Force
observed a high potential for error in the recorded purge volume. The collec-
tion and actual physical measurement of the purge volume is recommended. It is
suggested the facility document repeatable pump rates for measured purged
volumes for each well.
Evacuation of four-inch inside-diameter bedrock wells is accomplished by
dedicated submersible stainless steel centrifugal pumps with polypropylene
tubing. These pumps are removed from the wells between sampling events, marked
to be returned to the same well, and steam cleaned prior to use. A generator
is required for the pump operation. These wells were retired from RCRA monitor-
ing after the Task Force inspection.
Evacuation of two-inch PVC wells is performed by a dedicated PVC hand
pump. These wells are shallow and finished in glacial tills or lacustrine
silts. Operation of tha pump requires the addition of a handle and an up-and-down
pumping motion. Water flows from the pump continuously and at a rate compatible
with sample bottle filling. Almost all of these wells were found to be slow
producing, going dry before three volumes could be evacuated. As evacuation
approaches dryness the flow is reduced to spurts or sprays of water. Two
65
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alternate methods of evacuation for these shallow wells are discussed in the
SAP. A peristaltic pump and stainless steel bailer are referenced, but it was
not determined if this equipment was available for use.
c. Sample Withdrawal
All wells have dedicated pumps of some variety that are used for well
evacuation and sample withdrawal. The designated RCRA wells had either Well
Wizard® or submersible centrifugal pumps for sampling purposes. Both sampling
systems require a gasoline-driven generator as a power source. During the
demonstration sampling effort the generator was placed in a position such that
the exhaust drifted through the area in which sample bottles were being filled.
Sampling personnel also did not appear to be aware of other events such as
traffic, fumes, or dust that could possibly have affected the samples being
collected. Weather conditions at the time may have influenced this aspect of
sample collection. Thorough event observations were noted on field log sheets
in the past; the need for such observations are recommended to be added to the
sampling protocol in the SAP.
Volatile samples are sampled first in most protocols. However, at
FEI they were sampled toward the end of the sampling sequence. Volatile samples
also were not closely checked for the presence of trapped air. Specific
directions for VOA sampling are included in the SAP. These directions are
recommended to include a requirement for checking for bubbles in VOA samples.
Preservatives were added to some samples midway through filling the sample
bottle, with the bottle then being allowed to overflow. This should in most
cases require a pH check to insure adequate preservation. Care should be taken
to prevent significant overflow of preserved sample bottles.
66
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d. Field Analysis
The SAP specifies field analysis protocols for temperature, pH and conduc-
tivity. The procedures observed during the demonstration to the Task Force did
not exactly follow these protocols. Presently the facility removes the samples
to the FEI laboratory area for analysis. This is an acceptable procedure, but
the SAP is recommended to be updated to reflect this change. The collection of
all four field parameter aliquots before any other parameters is questioned. A
better evaluation of sample variability would be obtained if the four aliquots
could be distributed throughout the sampling sequence.
e. Laboratory Analysis
As mentioned in Section II.A.2 of this report, all four laboratories used
by FEI were evaluated by the Laboratory Evaluation Team. The quality of
the data from the ETC laboratory was found to be acceptable. The data from the
CEP and 8EC laboratories were also found to be acceptable, with the exception
of analyses for Radium 226 and 228 from CEP and TOC from BEC. The results for
these parameters were considered questionable due to unacceptable performance
by the laboratories in performance evaluation samples sent to the laboratories
by EPA. Certain data from Clow were also considered questionable. Individual
reports on each laboratory can be found in Appendix C.
The chain of custody procedures were found to be acceptable for RCRA
sample tracking purposes at BEC, ETC, and Clow. However, at CEP the samples do
not arrive at the laboratory under a custody seal, which is contrary to the
facility's SAP.
67
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E. GROUND WATER QUALITY DATA INTERPRETATION
1. Task Force Analysis
Samples were analyzed by the EPA contractor laboratories for the parameter
groups shown in Table 1, except for parameters which were not obtainable from
poorly producing wells, as indicated in Appendix B. Laboratory analytical
results were obtained from two EPA contractor laboratories participating in the
Contract Laboratory Program (CLP). One laboratory, CompuChem of Research
Triangle Park, North Carolina, analyzed the samples for specified organic com-
pounds, while the other, Centec of Salem, Virginia, analyzed for metals
and indicator parameters. Standard quality control measures were observed
incl uding:
the analysis of field and laboratory blanks to allow distinction of possi-
ble contamination due to sample handling,
analysis of laboratory spiked samples and performance evaluation samples,
analysis of laboratory and sample duplicates to estimate precision, and
the review and interpretation of the results of these control measures.
These procedures can be found in the Quality Assurance Project Plan (QAPP) for
this site dated January 1986.
The performance evaluation samples were samples of known analyte concen-
trations prepared by the USEPA Environmental Monitoring Systems Laboratory,
Cincinnati, Ohio. The QA/QC summary can be found in Appendix D. Table 6
provides a summary, by parameter, of the analytical techniques used and the
reference methods for the sample analyses. Appendix E is a table of the positive
analytical results found above detection levels.
2. Interpretation of Data From Bedrock Wells
The analytical data interpreted in this section were obtained from wells
Rl, R2, R3, R4, R5, R6, R7, R8, DUG-1 (19), DUG-2 (21), DOG-1 (20), DDG-2 (7A
68
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and 7B), DOG-3 (5) and 8. The Task Force sampled wells R2, R4, R5, R6, R7 and R8,
and both Task Force and past facility data were used in this evaluation. A
review of the Task Force data shows the following:
Well Parameter Concentrations
R2 Acetone 11.0 ppb
R4 Acetone 10.0 ppb
K6 Aroclor 1260 (PC8) 8.3 ppb
The Task Force disregarded the findings of acetone in wells R2 and R4, as
acetone was also detected in corresponding blanks.
It should be noted that TOX (total organic halogens) values in the past
facility monitoring data vary between non-detectable levels to 120 ppb. In the
opinion of the Task Force these results do not indicate definite leakage of
hazardous waste from this facility into this aquifer. However, it is recom-
mended that TOX be monitored closely by FEI during future interim status sampling
to establish if any trends exist.
While 8.3 ppb of PC8 is a concentration of concern, its presence in well
R6 is not felt to be attributed to leaking waste cells at the facility because
well R6 is an upgradient well. Also, no other analytical data from this well
indicate contamination. These results are felt to be anomalous because PCB's
are not known to readily migrate through clay to ground water. A possible
explanation for this finding would arise if the well were contaminated during
construction, since it is located on the property of the former Bill's Road
Oiling Service facility referenced previously, and adjacent to a major rail
yard. The Task Force recommends that FEI determine if the PCS contamination
found in R6 is due to well construction, or if the ground water is in fact
contaminated.
70
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3. Interpretation of Data from Deep Till Wells
The analytical data interpreted in this section were obtained from wells
Fld-F3d, Gld, G3d, Hld-H4d, Ild-I5d, Mld-M8d, MRld-MR3d, 4, 11, 14, and 18.
The Task Force sampled wells Fid, F2d, Gld, Hid, H2d, H4d, M4d, M7d, MR2d, and
MR3d (see Figure 12) . Both Task Force and past facility data were used in
this evaluation. A review of the Task Force data shows the following:
Well Parameter Concentrations
Fid
Hid
H2d
H4d
4,4'-DDT
pH
Total As
Total Cr
Dissolved Cr
Total Pb
Turbidity
TOX
Total As
Total Cd
Total Cr
Total Pb
Turbidity
Total As
Total 3a
Total Cd
Total Cr
Total Pb
Turbidity
0.58 ppb
10.7 s.u.
53 ppb
327 ppb
78 ppb
69.6 ppb
170 JTU
133 ppb
221 ppb
22 ppb
253 ppb
160 ppb
off seal e
301 ppb
1820 ppb
35 ppb
325 ppb
88.8 ppb
5 JTU
M4d Methyl - 13 ppb
Cyclopentanone
Total As 84.5 ppb
Total Cd 10 ppb
Total Cr 84 ppb
Turbidity >1000 JTU
MR3d Total Cr 70 ppb
Turbidity 240 JTU
All of the metals results listed above exceed the Interim Primary Drinking
Water Standards; however, these metals are found naturally in clay. Low
concentrations of dissolved metals and high turbidity were found in many of the
71
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samples. Dissolved metals are felt to be better indicators of contamination
from the site, and very low concentrations were found. The high turbidity
results were thought by the Task Force to indicate the presence of clay parti-
cles in the total metals samples, thus explaining the high metal concentrations
found. Also, there are no background data available to determine if these
parameters are increasing in concentration over time. Thus, the Task Force does
not consider these results to be an indication of contamination from the site.
The high pH in well Fid is due to the use of cement grout in the well and is
not felt to be an indication of contamination from the waste cells.
The Task Force sampling found very small amounts of organics in two wells,
specifically, DOT in well Fid and 2-methyl-cyclopentanone in well M4d. Of the
ten deep till wells sampled, four did not produce enough water to sample for
all organic parameters; thus, the Task Force was not able to obtain data suffi-
cient to fully evaluate the groundwater in this zone for contamination by the
facility. During a review of the facility's past data, the single set of
results available from an October 1985 sampling event for well F3d (SWld) did
show TOX at 860 ppb, TOC at 105 ppm, BOD at 59 ppm, COD at 340 ppm and nitrogen/
NH3 at 69 ppm. The log of well F3d indicates that the well was drilled through
six feet of organic clay fill near the surface; thus, the Task Force felt this
indicated a probable construction contamination problem in this well.
The Task Force could not conclude that there is contamination of this zone,
based on the available organic data. Thus, further sampling of the zone is
recommended for organic parameters. Also the construction records of well F3d
should be further investigated to determine if the existence of contamination
of the sample is attributable to well construction practices.
72
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4. Interpretation of Data from Shallow Lacustrine Wells
The analytical data interpreted in this section was obtained from wells
Fls-F3s, Gls-G3s, Hls-H4s, Ils-I5s, Mls-M8s, MRls-MR3s, SUG-1 (1), 2, 6, 9,
SDG-2 (10), SDG-1 (12), 13, and 17. The Task Force sampled Fls, F2s, Gls, G3s,
His, H4s, M4s, M7s, MR2s, MR3s, SUG-1, SOG-1 and SOG-2. Both Task Force and
past facility data were used in this evaluation. A review of the Task Force
data shows the following:
Well Parameter Concentration
F2s
M7S
1,1 Dichloroethane
Total
Total
Total
Total
As
Cd
Cr
Pb
17
108
15
155
103
ppb
ppb
ppb
ppb
ppb
SDG-2 1 Formyl-2-
Piperidinecarboxylic acid 15 ppb
The Task Force does not consider the high total netal concentrations found
in well M7s as indications of contamination for the same reasons stated in the
previous section concerning the deep till wells.
Both facility and Task Force values for TOX, as shown in Figure 12, show
increased concentrations of TOX in areas of early landfill ing activity. These
areas are near well SDG-1, SDG-2, SUG-1, and H2.
It should be noted that of the thirteen wells sampled by the Task Force
in this zone, only two were able to produce enough water to analyze for the
full range of organic parameters. Thus, the organic data available to the Task
Force are incomplete. It should also be noted that an October 1985 facility
sample of well F3s did show TOC at 165 ppm, BOD at 110 ppm and COD at 560 ppm,
but it is suspected that this well was constructed in refuse and is not
73
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Figure 12
Maximum TOX Values in Shallow Lacustrine Wells
Fondessy Enterprises, Inc.
Oregon, Ohio
NOTE: Results are indicated as ug/1 Task Force TOX Value/ Max. Facility TOX Value
^ I
^vs. - 'i
k-. -I
• «la==i-5r-«=sr==.JJ
74
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representative of ground water. More information is needed regarding the
source of constituents in this zone. The Task Force recommends further
sampling of the zone for organic parameters.
5. Interpretation of Data from Water Line Trenches
The Task Force found some total metals concentrations to exceed drinking
water standards in an analysis of water contained in monitoring trenches.
These results (see Appendix E) were not considered to indicate contamination
from the site for the same reasons stated in the interpretation of data from
deep till wells. No organics were found in the Task Force samples. A review
of the facility's existing monitoring data also found no indication of
contamination. Thus, the Task Force concludes that there is no current basis
to indicate contamination from the site in the area surrounding the water lines
in the vicinity of Cells H and I.
75
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|
-
1
FONDE55Y ENTERPRISES, INC
ASSOCIATED CHEMICAL AND ENVIRONMENTAL SERVICES
A76 OTTI* CfcCEK HOAD P.O. BO* 7 571 OREGOH. OHIO
(419) 726-1521 (24 HOURS)
I
I
*
I
KXJDESSY ENTERPRISES, H1C.
Cm OF TOLEDO
LOW pncssurz PWJ
AGREEMENT
22, 1934
, .
VATS UH& 1M OHIO 1^00-472-0414 ; OUTSIOC OHIO 1400-537-0426
' '
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• ,*
FONDE55Y ENTERPRISES, INC
ASSOCIATED CHEMICAL AND ENVIRONMENTAL SERVICES
676 OTTER CREIK ROAD f.O. OCX 7571 OREGON, OHIO 43616
(419) 726-1521 (24 HOURS)
TABLE OF OCNTENIS
I SURVEf AND *m*EKT INSTALLATION Page 1
XI KRSTE AREA IXXAHCKS Page 2
HI KASIE AKEA DESIQ^/OCNSIKXTICN Page 3
IV M30TORJNG SYSTEM Page 5
V SJl'lTJ UJSPBCnCN Page 8
VI TERMZHKTICN OF AGREEMENT Page 9
I
VAJS UNE: IN OHIO 1^00-472X5414 J , OUTSIDE OHIO 1-400-537-0426
'
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b
I
FONDES5Y ENTERPRISES. INC
) ASSOCIATED CHEMICAL AND ENVIRONMENTAL SERVICES
I- 676 OTTCR CREIK KOAD P.O. COX 7571 OMGON. OHIO 43616
(419) 726-1521 (24 HOUM)
I. SURVEY AM) MCNWEKT INSTALLATION
Fondessy Enterprises, Inc. agrees to clearly mark the City of Toledo's
easemsnt and the agreed forty (40) foot setback from the centerline of the
waterlines as follows:
ftndessy Enterprises, Inc. (FEI) will contract a Professional
Engineering/Surveyor firm at FET's sole expense to conduct the following tasks*
I. Vlaterline Easement Survey
(1) The centerline of the City of Toledo's easemsnt win be
established. Iron pins at 100 foot intervals will be
set along the easement's centerline.
(2) The easement's boundaries will be measured and laths set along
the easements limits;,
(3) Concrete mcrasnents will be placed at the easement's l^nits
(4) Additional concrete monuments will be placed parallel to the
«
easement at a distance of 40 feet from the centerline of
the closest waterline.
-1-
VAJ5 LINE: IN OHIO 1-400-472-0414 OUTSIDE OHIO 1-600-537-0426
B.2-6
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FONDESSY ENTERPRISES. INC
ASSOCIATED CHEMICAL AND ENVIRONMENTAL SERVICES
676 OTTER CREEK *OAD P.O. 6OX 7371 OREGON. OHIO
(419} 726-1521 G* HOUM)
H KASTE
IXOTION5
FEI agrees to modify its Part B Application to include setbacks for all
regulated waste areas as follows:
Cell boundaries will be at least forty (40) feet from the centerline
of the water lines.
1. Cell boundari*** will be forty (40) feet from the
centerline of the water lines.
2. All above ground storage areas will be located at least
100 feet froa the centerline of the water lines.
-2-
UN& IN OHIO 1400-472-0414 OUTSIDE OHIO 1-400-537-OX26
^ B.2-7
2§$ £ A
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FONDE5SY ENTERPRISES, INC
ASSOCIATED CHEMICAL AND ENVIRONMENTAL SERVICES
676 OTIC* CWEK ROAD P.O. OCX 7571 OREGON. OHIO 43616
(419) 726-1321 (24 HOUW)
HI KASTE AREA DESIGNAXKSTRXTICN
Ftndcssy Enterprises, Inc. agrees to incorporate, at FEX*s sole expense,
systems the City has deemed desirable into the waste area's design/construction
to provide additional safeguards to the City's raw water lines.
The design and construction of all future (including Cell H) waste
placement cell areas contiguous to the waterline easement will include the
following:
1. All npll walls will consist of Ohio Blue Clay.
2. Yellow clay around the top portion of the cplls will be
removed to a width of at least ten feet and replaced with
recorapacted Ohio Blue day. (Compaction of 95% SID Proctor,
ASTM D 698.)
3. An new «.n« will be lined with 60 mil EDPE liner (or equivalent)
^ and capped at closure with a cap consisting of clay end 20 nil
I3DPE (or equivalent).
4. All new «-~*n«« will consist of a leachate collection system
• designed and constructed to direct leachate away from the cell's
closest side to the waterline,
5, All new cell limits win be at least forty (40) feet from the
centreline of the water lines.
6. Surface drainage of the cell area will be collect and directed away
from the City's easement.
7. Ccnpaction testing of the cell's base, slope and reconpacted
areas will be conducted. (Ccnp&ction of 95% SID Procter,
ASTM,D 698.) -3-
VAJ3 UNfc IN OHIO 1 -600-472-0414 OUTSIDE OHIO 1 -400-507-0426
B.2-8 >7.
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a
!
• i
» FONDESSY ENTERPRISES. INC
ASSOCIATED CHEMICAL AND ENVIRONMENTAL SERVICES
676 OTTtt CM£K ROAD P.O. 6OX 7571 OMGOM. OHIO 4361*
(419) 724-1521 (24 HOURS)
C. Cbnpaction data and Hm*r installation quality control data will be
documented on all "as built" drawings for future cells as previously
demonstrated and reviewed with the City. These drawings will be
available for open review at the FEZ- facility.
9. Facility roadways crossing the City's waterlines will be of
adequate design to protect these from damage. Testing
and design criteria will be developed by FEE and submitted to
TESA.
10. In the event a waterline leak occurrs within 10 feet of
the facility's roads, FEZ wiJl contract a nutually acceptable
structural engineering f*™ to detesnine the cause. If the
cause is determined to be directly related to FET's use of the
roadway, FEX will reisturse the City those reasonable and custcnary
costs related to the repair of the waterline.
-4-
V>JS UNE: IN OHIO 1-AOO-472-O414 OUTSIDE OHIO 1^00-537^)426
B.2-9
1 j»*>"
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FONDE5SY ENTERPRISES, INC
ASSOCIATED CHEMICAL AND ENVIRONMENT. SERVICES
676 OTTER CREEK ROAD P.O. OOX 7571 OREGON. OHIO 43616
(419) 726-1521 (24 HOURS)
IV MCNTTOKD'Xj SYSTEM
Fondessy Enterprises, Inc. agrees to install at its expense a lateral
migration detection trench, and to monitor the trench periodically.
Ihe ncnitoring system is described as follows:
1. Monitoring trenches win be installed along both eides of the City's
waterlines in phases with installation corresponding with the
facility's development of the waste disposal areas, These ncnitoring
trenches will be installed within the 40* buffer zone between the waste
areas' closest side to the waterline and the waterline. Each area's
monitoring trench will be installed after the cell's constructicn and
lining has been ccopleted, and/or prior to waste reaching the level of
the lowest limit of the waterline on the side closest to the
waterlines.
- Cell H; A monitoring trench will be install^ upon ccnpletion
of the call's south wall and prior to waste placement
on the south wall above the lowest limit of the
waterline,
- Cell GJ A ncnitoring trench will be installed upon ccnpletion
of *n G's south wall and prior to the placement of
waste on the south wall above 'the lowest- limit of the
waterline.
- Cell I: A ncnitoring trench wi.11 be installed upon ccnpleticn
of the cells north wall and prior to the placement of
waste on the north wall above the lowest limit of the
waterline. _-
VATS UKEj IN OHIO 1-600-472-0414 OUTSIDE OHIO 1-600-537-0426
B.2-10 . i -..£-
. • ' ' *• ' • '",*•.•
r • . . • . :.<*••
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FONDESSY ENTERPRISES. INC
ASSOCIATED CHEMICAL AND ENVIRONMENTS SERVICES
676 OTTER CW£K *OAD P.O. BOX 7571 OMGON. OHIO 43016
726-1321 (24 HOVJKS)
- Area K and water iirpoundwent area: A monitoring trench will
be installed upon the completion of Cell M's northwest wall and
prior to placement of waste on the northwest wall above the
lowest limit of the waterline or prior to the use of the water
impoundment..
- Past storage areas: monitoring trenches will be installed
along the north side of the vaterlines in these areas in the
spring-sunner of 1985. Installation of a monitoring trench
along the south side of the waterlines in these areas will be
done in the spring-sunner of 1986.
2. Monitoring trench design will include:
- depth of at least 12* below the adjacent waterline.
/ - width adequate to intercept and collect laterally
migrating fluids for collection and analysis.
• - Trenches will be sloped to collection SUDDS located at
approximately 200* intervals.
- Trenches will be harVfUlpd with a permeable media (stone/sand}
from its lowest depth to approximately one foot below surface •
grade.
- Trenches will be can*^ and mounded with recoipacted clay to
prevent, surface infiltration.
- Trench caps will be routinely inspected for their integrity and
the collection sunps will be examined for the presence of
liquids.
VATS UNL IN OHIO 1-400-472-0414 OU7S1DC OHIO 1 -«00-507-0426
B.2-11
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FONDESSY ENTERPRISES, INC
ASSOCIATED CHEMICAL AND ENVIRONMENTAL SERVICES
676 OTTER CREEK ROAD P.O. BOX 7371 OREGON, OHIO 40*16
(419)726-1521(24 HOURS)
• If liquid ie found, sanples will be taken end tested (at least
semi~annually) for 40 CFR 26-4 indicator parameters. Additional
testing protocols will be esplcyed should the indicator
parameter results indicate significant levels of atypical
constituents.
• *
• If contamination as a result of FEZ operations is detected, FEZ
will take immediate and appropriate corrective actions in
cooperation with TESA.
- TESA will be provided design drawings for review and
approval prior to the installation of the monitoring trench.
I
I
I
I
I
1
IS
-7-
VATS UNE: IN OHJO l.fiOO-472-0414 OUTSIDE OHIO 1-AOO-507-0426
B.2-12
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FONDE5SY ENTERPRISES. INC.
ASSOCl/JED CHEMICAL AND ENVIRONMENTAL SERVICES
676 OTTE* C*££K *OAD f.Q. DOX 7571 OACGON, OHIO 43616
(419)724-1521 (24 HOURS)
V SITE INSPECTION
Pondessy Enterprises agrees to ensure that the water line monitoring systems
are routinely inspected and if necessary repaired eolely at F£Z*s expense.
FEZ will conduct the following inspections;
1. At least weekly the cell boundaries and Unor will be routinely
inspected for degradation and damage,
2. At least weekly the monitoring trench cap will be routinely
inspected for erosion or damage.
3. At least monthly collection sunps will be inspected routinely
for damage and presence of liquids.
4. At least monthly the City's easement will be routinely inspected
for evidence of leakage frcm the waterlines.
5. TESA will have access to the site to conduct appropriate
monitoring during all normal and customary
%
operating hours.
-8-
VAXS UHE: IN OHIO 1-400-472-0414 OUTSIDE OHIO 1-600-537-0426
" ;- - •••1&riB.2-l3
M.I
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FONDESSY ENTERPRISES. INC
ASSOCIATED CHEMICAL AND ENVIRONMENT SERVICES
676 OTTEK CMC* ROAD P.O. BOX 7571 OMGOH, OHIO 43616
(419) 726-1521 (24 HOURS)
VI
OF AGKEIMPET
This agreement, and all of its terms and conditions,, will
automatically terminate and beccce null and void upon written notification
to FEZ that the City, City entities and/or their authorized representatives
deem this agreement to be inadequate for the intended purpose of resolving
the i«rs»v? of the security of the City's water lines.
Dpon termination, F£I vill immediately ceff.se all tasks pertaining to
this agreement and vill not reisplenent such tasks until issues are
resolved with the City.
The two parties undersigned agree to the terns and conditions of
this agreement..
For City of Toledo:
For Fcndessy Enterprises, Inc.j
T.
Director of Public Utility DepaiUuent
R. Chestnut
General Manager
VAJ5 LINE: IN OHIO <-«00-472-O414~9~ OU751DC OHIO 1^00-507-0426
-.-B.2r
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE- May 16, 1986
SUBJECT: On-Site Evaluation of the Environmental Testing
and Certification Corporation, Edison, New Jersey
: James H. Adams, Jr., Chief
Quality Assurance Office
TO: Alfons R. Winklhofer, Chief
Eastern District Office
ATTENTION: Joseph Fredle
On April 17 and 18, 1986, the Quality Assurance staff conducted an on-site
evaluation of the Environmental Testing and Certification (ETC) Corporation,
Edison, New Jersey pursuant to Resource Conservation and Recovery Act ground-
water monitoring activities at the Fondessy site. The purpose of the visit
was to evaluate the suitability of the laboratory's standard operating proce-
dures for the analysis of Appendix VIII organic constituents of 40 CFR 141.
The laboratory was not required to analyze USEPA performance evaluation
samples to demonstrate its analytical capabilities.
The evaluation team has observed many excellent aspects of laboratory proce-
dures. The ETC personnel are highly qualified to perform trace analysis of
organics in RCRA groundwater samples.
The evaluation team wishes to thank the laboratory staff for their courtesy
and cooperation during the on-site evaluation.
Since no deficiencies were observed and since the evaluation team has no
recommendations to offer to the laboratory to improve its data quality, this
memorandum describes the observations that were made during the evaluation of
ETC's organic analysis capabilities. The evaluation covered the following
areas: Personnel, Laboratory Equipment and Instrumentation, Analytical Me-
thodology and Quality Assurance/Quality Control.
PERSONNEL
The laboratory staff is competent to perform complex analyses of waste-site
samples for Appendix VIII organic constituents. A majority of the staff
members are college graduates and the senior staff members have several years
of experience in trace organic analysis of environmental samples. The labora-
tory staff has spent a considerable amount of time in developing analytical
techniques suitable for the characterization of Appendix VIII constituents.
EPA POBM 133M 'REV 3-78)
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-2-
LABORATQRY EQUIPMENT AND INSTRUMENTATION
The laboratory has several gas chromatography (GC) instruments equipped with
detectors such as flame ionization (for the analysis of solvents), electron
capture (for the analysis of chlorinated hydrocarbon pesticides and herbi-
cides) and flame photometric (phosphorus mode - for the analysis of organo-
phosphorus pesticides). It has 17 gas chromatography/mass spectrometry (GC/
MS) instruments (for the analysis of volatile and semi-volatile organics).
The laboratory has highly sophisticated computers to process the vast amounts
of data it produces from various instruments. The laboratory evaluation team
was highly impressed by the laboratory's sample tracking, analytical data
processing and management systems.
ANALYTICAL METHODOLOGY
The laboratory has analyzed several samples for Appendix VIII constituents
using analytical instruments such as GC, GC/MS and High Performance Liquid
Chromatography. The laboratory standard operating procedures are based on EPA
methods manual, SW-846. The laboratory is in the process of obtaining data on
method detection limits and method performance (precision and accuracy) cri-
teria for the Appendix VIII constituents.
QUALITY ASSURANCE/QUALITY CONTROL
The laboratory has a well documented quality assurance plan. With each batch
of samples the laboratory analyzes, it obtains data on method detection
limits and on method precision and accuracy. In addition, the laboratory
spikes samples that require GC/MS analysis with surrogate spike compounds to
monitor the matrix effects and performance of analytical systems.
The laboratory frequently participates in interlaboratory comparison studies
and in the system (on-site) evaluations conducted by several program offices
such as EPA/EMSL-LY, and the New York Department of Public Health. The labor-
atory provided copies of the interlaboratory comparison study results and
copies of the system evaluation reports to the evaluation team at the time of
on-site visit. The performance and system audit results are acceptable.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
DATE: September 10, 1986
SUBJECT: Fondessy Enterprises, Inc., Oregon, Ohio - System Audit Results
of B.E.C. Laboratories, Toledo, Ohio
FROM: James H. Adams, Jr., Chief
Quality Assurance Office
T0: Alfons R. Winklhofer, Chief
Eastern District Office
ATTENTION: Joseph Fredle
3n January 30, 1986, Donald Booker and Maxine Long, Laboratory Evaluation Team,
Quality Assurance Office, Region V performed an on-site evaluation of the Bio-
logical & Environmental Control Laboratories, (BEC), Inc., Toledo, Ohio pur-
suant to RCRA Groundwater Monitoring activities for Fondessy site.
The purpose of the evaluation was to establish whether or not BEC's standard
operating procedures produce data of acceptable quality. BEC was required to
analyze U.S. EPA Performance Evaluation to demonstrate its analytical capabil-
ities.
Based on the system audit, it was determined that BEC had an acceptable quality
assurance/quality control program and it produced data of acceptable quality
with the following exceptions (see Observations and Recommendation's).
The evaluation team wishes to thank the laboratory staff for their courtesy
and cooperation during the on-site evaluation.
A list of the parameters analyzed for and the methods used by the laboratory
are provided as Attachment I.
The following are the observations that were made during the evaluation and
the recommendations of the Quality Assurance Office to BEC to improve the data
quality.
INORGANIC ANALYSIS
- Observation: The intended use of the data is not known which dictates
the appropriate chain-of-custody and necessary level of precision and accuracy.
- Recommendation: The laboratory should know the intended use for the
data so that the appropriate chain-of-custody and the necessary level of
precision and accuracy can be accomplished. If the intended use of data is
privileged information, then appropriate chain-of-custody and necessary level
of precision and accuracy should be specified.
- Observation: The chain-of-custody of the subject laboratory does not
address all the concerns of proper chain-of-custody.
EPA FORM 13204 (REV. 3-76)
-------
-2-
- Recommendation: Sample control procedures are necessary in the lab-
oratory from the time of sample receipt to the time the sample is discarded.
The custody log book should show the movement of each sample within the lab-
oratory, i.e., who removed, when it was returned, and when it was destroyed.
Procedures must be established for audits of sample control information.
Records should be examined to determine traceability, completeness, and accur-
acy. For the purposes of litigation, it is necessary to have an accurate
written record which can be used to trace the possession and handling of
samples from the moment of collection through analysis.
- Observation: There is no systematic approach to accepting or rejecting
a standard calibration curve for metals by atomic absorption.
- Recommendation: The laboratory should have a systematic acceptance
criterion for the linearity of the standard calibration curve for metals by
atomic absorption. The correlation coefficient should be calculated and docu-
mented after calibration. The correlation coefficient should meet a specific
criterion (e.g.r >0.995). The laboratory should establish this specific cri-
terion based on their past standard calibration data. A copy of this data
and acceptance criterion should be forwarded to the Quality Assurance Office.
- Observation: Results of performance evaluation study WP 016 are
generally acceptable for most parameters. Data for arsenic is biased low; data
for COO is high and data for TOC is low. A copy of WP 106 is provided as
Attachment II.
- Recommendations: The laboratory should review its analytical quality
assurance data to determine the cause of the unacceptable results, then a
decision should be made whether to accept or reject other analytical data for
these parameters.
-------
ATTACHMENT 1
analysis:
results:
Drinking Water Quality
Analyte
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Si 1 ver
Endrin
Lindane
Methoxyclor
Toxaphene
2,4 - D
2,3,5 TP (Silvex)
Radi urn
Gross Alpha
Gross Beta
Nitrate-N
Fluoride
Method Result
SW-846, Method 7061
SW-846, Method 7080
SW-846, Method 7130
SW-846, Method 7190
SW-846, Method 7420
SW-846, Method 7470
SW-846, Method 7741
SW-846, Method 7760
SW-846, Method 8080
SW-846, Method 8080
SW-846, Method 8080
SW-846, Method 8080
SW-846, Method 8150
SW-846, Method 8150
EPA Method 304
EPA Method 302
EPA Method 302
SW-846, Method 9200
EPA Method 304.2
-------
ATTACHMENT 1
analysis:
results :
Ground Water Quality
Analyte
Iron
Manganese
Sodium
Chloride
Phenols as CfiH^OH
Sulfate
Method Result
SW-846, Method 7380
SW-846, Method 7460
SW-846, Method 7770
EPA-600, Method 325.3
SW-846, Method 9065
SW-846, Method 9037
-------
ATTACHMENT 1
analysis: Indicators
results: pH (S.U.) in quadruplicate (SW-846, Method 9040)
Specific Conductance (umhos/cm) in quadruplicate (EPA-600, Method 120.1)
Total Organic Carbon (mg/L) in quadruplicate (SW-846, Method 9060)
Total Organic Halogen (mg/L) in quadruplicate (SW-846, Method 90?0)
-------
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To: EDO/REG.V (EPA9531)
From: ESO/REG.V (EPA9581) Posted: Tue 5-Aug-86 10:18 EOT Sys 63 (160)
Subject: Fondessy Enterprises, Inc., Clow Corp., MI
DATE: April 3, 1986
SUBJECT: Fondessy Enterprises, Inc., Toledo, Ohio - System Audit
Results of Clow Corporation, Pontiac, Michigan
FROM: James H. Adams, Jr., Chief
Quality Assurance Office
TO: Alfons R. Winklhofer, Chief
Eastern District Office
ATTENTION: Joseph Fredle
On February 21, 1986, Babu Paruchuri and Donald Booker, Chemists, Quality
Assurance Office, Region V conducted an on-site evaluation of the Hydro
Research Services (MRS) of the Water Management Division, Clow Corporation,
Pontiac, Michigan pursuant to RCRA Groundwater Monitoring activities for
Fondessy site.
The purpose of the evaluation was to establish whether or not HRS's standard
operating procedures produce data of acceptable quality. MRS was not required
to analyze U.S. EPA Performance Evaluation samples to demonstrate its analyt-
ical capabilities.
The evaluation team has observed many good aspects of laboratory procedures.
The HRS personnel are well qualified to perform trace analyses of environ-
mental samples for chemical contaminants and they maintain the instruments in
good operating condition. However, the laboratory has deficiencies in docu-
mentation, particularly for methods and precision and accuracy. In order for
data produced by the laboratory to be fully acceptable, these deficiencies
should be addressed. Details are provided in the following recommendations.
The evaluation team wishes to thank the laboratory staff for their courtesy
and cooperation during the on-site evaluation.
The following are the observations that were made during the evaluation and
the recommendations of the Quality Assurance Office to HRS to improve the
data quality:
ORGANIC ANALYSIS:
- Observation: The Laboratory does not have a well documented standard
operating procedures manual.
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-2-
Recommendation: The Laboratory analyzes complex matrices for various
pollutants using instruments such as gas chromatography/mass spectrometry
(GC/MS), gas chromatography equipped with flame ionization, Hall Electrolytic
Conductivity, photoionization, electron capture detectors, etc. But the Lab-
oratory does not have a manual that describes several steps involved in trace
analysis of environmental samples, such as sample preservation, extraction,
clean-up and analysis. The Laboratory should document its organic procedures
in formats similar to EPA 600 methods series, if possible.
- Observation: The gas chromatography analysis results are not con-
firmed on a second GC column.
Recommendation: Whenever the Laboratory uses GC instrument as the
primary analytical tool for pollutant analysis, such as pesticides analysis,
it should support the analytical results by providing data obtained from a GC
column of different polarity.
- Observation: The Laboratory does not determine accuracies of the
stock standard solutions.
Recommendation: As soon as the Laboratory prepares fresh stock
standard solutions in-house, it should determine their accuracies by analyzing
standard solutions that are traceable to a known source such as EPA. Also,
the Laboratory should, periodically, determine the stability of the working
standard solutions.
- Observation: The Laboratory does not provide GC/MS data on "tenta-
tive" identification and estimation of concentrations of unknown peaks.
Recommendation: The Laboratory should, if resources permit, attempt
to provide "tentative" identification of unknown peaks in environmental
samples through mass spectral library searches and estimate their concentra-
tions by comparing the peak areas to the nearest internal standard areas.
- Observation: The Laboratory analyzes a variety of matrices for
organic pollutants but it does not have summary reports of performance accept-
ance criteria (precision, accuracy and sensitivity) for any of the analytical
methods.
Recommendation: The Laboratory should provide the method performance
criteria for each matrix-type and for each method. The Laboratory should refer
to EPA Methods 608, 624 and 625 for guidance to establish the quality control
acceptance criteria for the organic test procedures.
INORGANIC ANALYSIS
- Observation: The intended use of the data is not known which dic-
tates the appropriate chain-of-custody and necessary level of precision and
accuracy.
-------
-3-
Recommendation: The Laboratory should know the intended use for the
data so that the appropriate chain-of-custody and the necessary level of
precision and accuracy can be accomplished. If the intended use of data is
privileged information, then appropriate chain-of-custody and necessary level
of precision and accuracy should be specified.
- Observation: The chain-of-custody of the subject Laboratory does not
address all the concerns of proper chain-of-custody.
Recommendation: Sample control procedures are necessary in the labor-
atory from the time of sample receipt to the time the sample is discarded. The
custody log book should show the movement of each sample within the laboratory,
i.e., who removed the sample from the custody area, when it was removed, when
it was returned, and when it was destroyed. Procedures must be established
for audits of sample control information. Records should be examined to deter-
mine traceability, completeness, and accuracy. For the purposes of litigation,
it is necessary to have an accurate written record which can be used to trace
the possession and handling of samples from the moment of collection through
analysis.
- Observation: The procedures used for RCRA Groundwater Samples were
not thoroughly documented pursuant to the Fondessy site.
Recommendation: The Laboratory should document specifically the pro-
cedures used for RCRA Groundwater Samples because there are no regulatory pro-
cedures.
- Observation: There is no systematic approach to accepting or rejecting
a standard calibration curve for metals by atomic absorption.
Recommendation: The Laboratory should have a systematic acceptance
criterion for the linearity of the standard calibration curve for metals by
atomic absorption. The correlation coefficient should be calculated and docu-
mented after calibration. The correlation coefficient should meet a specific
crtierion (e.g. r>0.995). The Laboratory should establish this specific cri-
terion based on their past standard calibration data. A copy of this data
and acceptance criterion should be forwarded to the Quality Assurance Office.
-------
To: EDO/REG .V (EPA9531)
From: ESO/REG.V (EPA9581) Posted: Tue 5-Aug-86 10:31 EOT Sys 63 (135)
Subject: On-Site Eval. Controls for Env. Pol.(CEP), Inc., Santa Fe, N.M.
DATE: July 8, 1986
SUBJECT: On-Site Evaluation of Controls for Environmental Pollution
(CEP), Inc., Santa Fe, New Mexico
FROM: James H. Adams, Jr., Chief
Quality Assurance Office
TO: William Harris, Chief
Central District Office
Attention: Joseph Fredle
On April 22, 1986, the Quality Assurance Office (QAO) staff conducted an on-
site evaluation of Environmental Pollution (CEP), Inc., Santa Fe, New Mexico
pursuant to the National Groundwater Task Force groundwater monitoring activ-
ities at the Fondessey and Peoria Disposal facilities. The purpose of this
evaluation was to evaluate the laboratory's facilities, personnel equipment,
chain-of-custody, analytical methodology, recordkeeping, and quality control
program for the measurement of gross alpha, gross beta, Radium-226 and Radium-
228 in groundwater samples from the waste disposal facilities.
The QAO would like to acknowledge the cooperation and courtesy of the staff
of the CEP during the on-site evaluation.
The results of the on-site evaluation are described below. Deficiencies are
summarized by function and are to be considered present at the time of the on-
site evaluation and not necessarily present at this time. The QAO wishes to
to emphasize that because of it's nature, this report highlights deficiencies
rather than the many excellent things that were observed during the evalua-
tion.
FACILITY
The facility is divided into the main space categories of Office, shipping
and receiving, wet chemistry laboratory and counting rooms. Lighting, venti-
lation, bench space, electrical hoods, etc. are adequate. Building security
is adequate. The facility has a warning system in place which will detect
undesirable levels of radioactivity in the laboratory.
Deficiency - None.
PERSONNEL
The laboratory staff is adequate and competent to perform the gross alpha,
gross beta, radium-226 and radium-228 analysis of groundwater samples from
hazardous waste sites.
Deficiency - None.
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-2-
EQUIPMENT
The laboratory has adequate general equipment such as analytical balances, pH
meters, drying ovens, desiccators, hotplates, glassware furnaces and centri-
fuges for the preparation of groundwater samples for counting. The equipment
was found to be satisfactory for sample preparation steps for which it was
used. The laboratory uses gas flow proportional counting systems for the
measurement of gross alpha and gross beta activities, radium-226 and radium-
228. The laboratory has 5 gas-flow proportional counting systems. The sensi-
tivity of these systems meet the requirements of Section 141.25 of the National
Interim Primary Drinking Water Regulations. All 5 counters were in good work-
i ng conditions.
Deficiency - None.
CHAIN-OF-CUSTODY
Samples do not arrive at the laboratory under custody. Custody is not
maintained for samples, since the 2 clients have not requested custody.
Deficiency - N/A
ANALYTICAL METHODOLOGY
The laboratory has documented analytical methodology for gross alpha, gross
beta, radium-226 and radium 228. Sample preparation protocol is essentially
the same as depicted in Standard Methods (15 Edition) for gross alpha and
gross beta. Sample preparation protocol is essentially the same as depicted
in EPA 600/4-80-032 for radium-226 and radium-228. Written protocols were
being followed by the bench analyst.
Deficiency - None.
RECORDKEEPING
The laboratory has a formal paper trail for each sample. Log books are main-
tained at the receiving room, preparation bench and the counting instruments.
A final data file is maintained for each client. The file for Peoria Disposal
was reviewed for traceability of paper trail. The file was found to be com-
plete. Fondessy had requested that the laboratory not make available their
files for review; therefore, no review for traceability of paper trail was
made. Analyst do not initial bench sheets for loading and unloading counting
instruments, nor do they initial bench sheets when recording activity counts.
Deficiency - Analyst do not initial bench sheets in counting room.
-------
-3-
QUALITY CONTROL PROGRAM
The laboratory has a documented QA plan. A Quality Assurance Office is also
in place. Quality control records were also available for review. The
laboratory participates in the EPA radiochemistry cross check and Performance
(Blind) sample program. Results of last performance of record at time of the
on-site is listed in Table I.
Deficiency - The laboratory had unacceptable performance for Radium-228
in the August 9, 1985 Performance Study. The laboratory also had unacceptable
performance in the Radium-226 December 12, 1985 cross check study.
-------
TABLE I
Gross Alpha
Gross Beta
Gross Alpha
Gross Beta
Radium-226
Radium-228
Radium-226
Radium-228
Cross
DATE
08/09/85
08/09/85
11/22/85
11/22/85
08/09/85
08/09/85
12/13/85
12/13/85
Check
RESULT
(pCi/1)
31
64.33
9
14
3.56
3.16
10.63
5.8
and Performance (Blind)
KNOWN
VALUE
(pCi/1)
32
72
10
13
4.1
6.2
7.10
7.3
DEVIA-
TION
- .34
- 2.65
- .34
+ .34
- 1.54
- 5.84
+ 5
- 2.36
Sample Results
PERFORM-
ANCE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
ACCEPTABLE
UNACCEPTABLE
UNACCEPTABLE
ACCEPTABLE
TYPE
STUDY
PERFORMANCE
PERFORMANCE
CROSS CHECK
CROSS CHECK
PERFORMANCE
PERFORMANCE
CROSS CHECK
CROSS CHECK
-------
pro
PRC
Suite SCO
3C3 East Wacker Drive
Chicago. IL 60601
312-938-0300
TWX 9i0-2215112
Cable CONTQWENG
Planning Research Corporation
MEMORANDUM
DATE: July 9, 1986
SUBJECT:
FROM:
THRU:
TO:
Evaluation of Quality Control Attendant to the Analysis of Samples
from the Fondessey Enterprises, Inc. Facility, Oregon, Ohio
Ken Partymiller, Chemist
PRC Engineering
Paul H. Friedman, Chemist*
Studies and Methods Branch (WH-562B)
GWMTF: Ed Berg (EPA 8214)*
Michael Kangas (ICAIR)*
Tony Montrone*
Gareth Pearson (EPA 8231)*
Richard Steimle*
James H. Adams, Jr., Region V
This memo summarizes the evaluation of the quality control data generated
by the Hazardous Waste Ground Water Monitoring Task Force contract analytical
laboratories (1). This evaluation and subsequent conclusions pertain to the data
from the Fondessey Enterprises, Inc. Facility, Oregon, Ohio sampling effort by the
Hazardous Waste Ground Water Monitoring Task Force.
The objective of this evaluation is to give users of the analytical data a
more precise understanding of the limitations of the data as well as their appro-
priate use. A second objective is to identify weaknesses in the data generation
process for correction. This correction may act on future analyses at this or other
sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-4) which contain raw data, statistically transformed
data, and graphically transformed data.
The evaluation process consisted of three steps. Step one consists of gener-
ation of a package which presents the results of quality control procedures, includ-
ing the generation of data quality indicators, synopses of
* GWMTF Data Evaluation Committee Member
-------
statistical indicators, and the results of technical qualifier inspections. A
report on the results of the performance evaluation standards analyzed by the
laboratory is also generated. Step two is independent examination of the quality
control package and the performance evaluation sample results by members of the data
evaluation committee. This was followed by a Committee meeting (teleconference) of
the Data Evaluation Committee to discuss the foregoing data and data presentations.
These discussions were to come to a consensus concerning the appropriate use of the
data within the context of the GWMTF objectives. The discussions are also to detect
and discuss specific or general inadequacies of the data and to determine if these
are correctable or inherent in the analytical process.
Preface
The data user should review the pertinent materials contained in the accompany-
ing reports (2-4). Questions generated in the interpretation of these data relative
to sampling and analysis should be referred to Rich Steimle of the Hazardous Waste
Ground Water Monitoring Task Force.
I. Site Overview
Fondessey Enterprises, Inc., located in Oregon, Ohio, is a land disposal
facility. The waste cells at the facility which are presently permitted under
RCRA interim status cover approximately 100 to 120 acres. The facility accepts
most types of non-flammable organic as well as inorganic waste. The State of
Ohio must approve all wastes before the facility may accept them. The geology
at the facility consists of several shallow clay layers under the site. The facility
owners do not consider these to contain the upper aquifer. The owners consider an
aquifer over 100 feet deep to be the true aquifer which they use for monitoring.
This sampling effort sampled monitoring wells in this deep aquifer as well as
monitoring wells around the facility which are in the clay layers in the first 100
feet. Most of the samples collected were very turbid. There was no historical
indication of contamination in any of the wells. The deep wells, into the 100 foot
deep, artesian aquifer, were not expected by EPA to be contaminated due to positive,
upward pressure in the aquifer. Forty seven samples were collected at the facility
including 18 field blanks, one set of trip blanks, and one set of equipment blanks.
Samples were split with the facility owners.
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metals
1.1 Performance Evaluation Standards
Seven elements (arsenic, barium, chromium, lead, selenium, vanadium, and
mercury) were in the metals performance evaluation standard. The laboratory ident-
ified all but one (chromium) of these within the 95 percent confidence interval
limits. Chromium was identified as being present at 34 ug/L when its "true' concen-
tration was 50 ug/L and the 95 percent confidence interval was 36.7 to 60.6 ug/L.
Thus, the laboratory was close but outside the confidence interval for chromium. The
overall laboratory performance on metals was judged to be acceptable.with a score of
90 out of 100 possible points. The "true" concentrations of the individual metals in
the PE sample ranged from 5.0 to 500 ug/L.
-------
1.2 petals QC Evaluation
Nine of the 24 total metal average spike recoveries were within the data
quality objectives (DQO) for this program. Barium, beryllium, calcium, magnesium,
manganese, potassium, selenium, sodium, tin, and zinc spike average percent recov-
eries were high and above the DQO, ranging from 111 to 120 percent. Total arsenic,
chromium, lead, silver, and thallium all had slightly low, and below DQO, average
percent recoveries ranging from 56 to 87 percent. Fifteen of 20 metals were within
the DQO for dissolved metals. Manganese, sodium, and vanadium were all above the
dissolved metals DQO with recoveries ranging from 112 to 113 percent while antimony
and tin were below the DQO with average percent recoveries of 81 and 47 percent,
respectively. No spike sample recoveries were reported for dissolved arsenic, lead,
selenium, or thallium. The average relative percent difference (RPD) for total tin
was the only total or dissolved average RPD outside the DQO. No blank contamination
above the contract required detection limit (CRDL) was reported for laboratory
blanks. Trip, equipment, and field blanks show contamination involving a variety of
total and dissolved metals. Required analyses were performed on all metals samples
submitted to the laboratory. Reported detection limits (DL) are CRDL or lower for
all metal parameters except total and dissolved mercury in several samples. The -
reported DL exceeded the CRDL for total mercury in samples MQ0404, 407, 410, 412,
420, 422, 423, 426, 433, and 437 and for dissolved mercury in samples MQ0408, 409,
423, and 424 by factors of two to five.
1.3 Furnace Metals
The metals analysis lab was asked to recalculate their graphite furnace metals
results but the recalculated data was not received in time to be incorporated into
the data review reports. The recalculated data will probably be based upon a two
point standard addition which may result in variability of the data and may result in
an increased percent recovery for some elements. A cursory review of the recal-
culated data indicated no significant trends, i.e. some values increased while others
decreased.
The aluminum concentration in samples MQ0420, 423, 433, 435, 436, and 437
was high (above JO 10,20 mg/L). This would be expected to result in signal enhance-
ment and false positives for arsenic and thus arsenic data for those samples is
biased high and suspect Although Zeeman background correction will be used to
prevent this problem in later cases, these samples could be reanalyzed in Phase 3
without resampling. High iron (above approximately 1 mg/L) in various samples will
cause a suppression of selenium signal (negative bias). Chloride concentrations
above 200lng/L in samples MQ0407, 409, 422, 440, and 441 can cause interferences with
graphite furnace results and would be expected to bias the results low. The selenium
results for sample MQ0421 should have been rerun by the method of standard addition
(MSA) but were not, rendering the selenium result questionable for this sample.
A procedural problem exists with the graphite furnace metals data. The labora-
tory recalibrated their instrument prior to the analysis of the continuing calibra-
tion blank and continuing calibration verification. This obscured any drift in
instrument calibration which occurred during the analysis of samples run before the
calibration. This practice is not permitted. This procedure reduces the quanti-
tative value pf the data as the reference samples have an unknown correlation with
the actual field samples and they will no longer show changes in calibration with
time.
-------
Spike recoveries for total arsenic, lead, and thallium were low while recovery
for selenium was high. Overall, the graphite furnace analytical results can be
considered acceptable for total metals. The arsenic and lead data should be consi-
dered semiquantitajive except for the samples (MQ0420, 423, 433, 435, 436, and 437)
with high aluminum causing interferences of arsenic. The resulting arsenic data from
these samples should be considered to be biased very high and questionable. The
thallium and selenium (with exceptions listed below) data as well as the lead data
from sample MQ04IO should be considered qualitative. The selenium results from
sample MQ0421 (which, as previously mentioned, should have been run by MSA) should be
considered questionable as insufficient data are available to adequately assess them.
The dissolved metals data (which are not generally being used by the GWMTF) should
all be considered qualitative.
1.4 ICP Metals
The data from samples with high dissolved salt concentrations (MQ0410, 423, 435,
436, 440, and 441 and possibly MQ0401 and others with lower dissolved salt concentra-
tions) indicate unacceptable serial dilution results which are an indication of
possible physical interferences affecting the ICP spectrometer. The chromium and tin
results were outside control limits on various spike samples. Sample MQ042S had
eleven spike elements above the control limits which appear to indicate a consistent
error. This may be a problem with dilution of the predisgestion spiking solution.
Data from sample MQ042S should be considered qualitative. In some samples calcium,
magnesium, and sodium were present at high enough concentrations to cause signal
suppression in the ICP. The results of the analyses of these samples are expected to
be biased low. High sulfate was present in some samples (MQ0404, 412, 415, 426, 427,
428, 430, 431, 432, 435, 436, 440, and 441) which would be expected to bias the
barium results slightly low. ICP analysis of the PE sample yielded acceptable
results for barium, vanadium, and mercury but unacceptable results for chromium. All
sample results for chromium and tin and medium concentration water samples of
silver should be considered qualitative. Aluminum, antimony, silver (low concentra-
tion), and vanadium data should be considered semiquantitative. Data for all other
elements, with certain exceptions (see above discussion and reference 4), should be
considered quantitative.
2.0 tndicajor Parameters
2.1 Performance Evaluation Standard
The laboratory encountered problems with six of the 10 indicator parameters.
The sample vial for sulfate and chloride was lost and thus not analyzed. The lab
results were high and out of the 95 percent confidence interval for ammonia nitrogen,
nitrate nitrogen, and POX. The results were low and out of the 95 percent confidence
range for TOC. None of the above mentioned results were especially close to the 95
percent confidence range. The laboratory did acceptably on TOC, TOX, POC, and POX.
The laboratory received a score of 48 out of 100 possible points.
2.2 Indicator Parameter OC Evaluation
For the indicator parameters, the average percent recoveries were within
the DQO's except for total phenols (44%) and cyanide (35%) which were outside
their respective DQO's. This indicates generally good recoveries of these analytes
except for total phenols (poor) and cyanide (slightly low). Seven individual sample
recoveries for these two parameters were also outside the accuracy DQO signifying
poor recovery for total phenols and slightly low recovery for cyanide. Laboratory
control standard recoveries reported for all indicator parameters were within program
-------
DQO's. Average relative percent differences for all parameters were within program
DQO's. All analyses were performed as requested except POX in sample MQ0411, POC in
sample MQ0439, TOX in sample MQ0440, sulfate and chloride in samples MQ0768 and 769
(the previously mentioned PE sample as well as the trip blank), and ammonia nitrogen,
nitrate nitrogen, and total phenol in sample MQ0769 (the trip blank). No laboratory
blank contamination was reported for any inorganic or indicator parameter except the
POC analyses. In all samples, initial and continuing calibration blanks contained
POC at levels greater than CRDL. All reported detection limits are CRDL or lower
except for the POC analyses of all samples except MQ0768 (DL an order of magnitude
above CRDL),
2.3 Inorganic and Indicator Parameter Data
Data from the facility indicate the presence of significant levels of TOC
but generally no organics (of the type measured by the test procedures). High
levels of chloride (samples MQ0407, 409, 440, and 441) which may cause interferences
in the detection of TOX, thus data for TOX may be biased high.
The indicator parameter data, except for TOC, corroborate the general lack
of organics found in the field samples. Medium to high levels of TOC were found in
almost all samples which probably indicates the presence of organics other than those
that the Task Force is measuring or detecting in its analyses.
The inorganic and indicator parameter data should be considered acceptable
and quantitative for nitrate nitrogen (except samples MQ0407, 412, 422, and 440
which should be considered qualitative due to the presence of high levels of iron
which could bias the results high), chloride, and TOX (except samples MQ0407, 409,
440, and 441 which had high chloride), semiquantitativej'or cyanide, POC, and POX
(poor PE quantitation),and qualitative for ammonia nitrogen (poor PE quantitation),
total phenol (poor spike recovery), sulfate (poor spike recoveries), and TOC (poor PE
quantitation). " ~~ '
3.0 Organics and Pesticides
3.1 Performance Evaluation Standard
Twenty eight compounds were included in the organics PE sample. The lab
did acceptably on all six of the volatiles (chloroform, bromodichloromethane,
dibromochloromethane, bromoform, toluene, and chlorobenzene). Concentrations
of volatiles in the PE sample ranged from 50.0 to 100 ug/L. No false positives
were reported. The laboratory failed to detect, within the 95 percent confidence
interval, three of the ten semivoiatiles in the PE sample although one of these, 2-
methylphenol, was detected within the program DQO (but outside 95 percent acceptance
interval). For two others from the list of ten semivolatiles a 95 percent confidence
interval has not yet been established. The "true" concentrations of the semi-
volatiles in the PE sample ranged from 50.0 to 500 ug/L. The laboratory did not
detect any of the seven pesticides, two herbicides, or two dioxins and a dibenzofuran
which were present in the PE samples. This problem has been attributed the manner in
which the PE sample bottles were prepared and shipped to the laboratory and to the
manner in which the laboratory sampled them. For the organics, the laboratory
received a score of 42.6 out of 100 possible points.
-------
3.2 Organic OC Eviluttloa
All organic parameters were within program DQO for accuracy and for precision
(except for 2,4-D, 2,4,5-T, the dioxins, and various surrogates where DQO's have not
yet been established) for both matrix spikes and surrogates except for 2-fluoro-
biphenyl (samples Q0434 and 442) and 2-fluorophenol (samples Q0407 and 434) which are
below percent recovery DQO. Blanks, generally, were free of contamination although
acetone was reported in one instrument blank at 19 ug/L (this blank was not
associated with any samples). All organic analyses were performed as requested. All
detection limits were CRDL or lower except for the semivolatiles which were all
reported at two times CRDL. Dioxin analyses were performed on 33 of the samples,
including all blanks. The percent recovery for dioxin spikes ranged from SO to 119
percent but no dioxin target compounds were found in any samples. No contamination
was reported in any of the dioxin blanks. Overall, the QC data looks very good and
is acceptable.
3.3 Volatile
Recoveries on several of the matrix spikes are a bit higher than usual but
still acceptable. This may be due to a spiking problem. Internal and external
quality control data indicate that volatile organics are run acceptably. The
chromatograms appear acceptable. The surrogates are acceptable. Few voiatiles
were detected in the actual samples (which is consistent with POC and POX results).
Acetone, methyiene chloride, and 2-butanone were detected in addition to the spiked
compounds in the PE sample. This raises questions about sample contamination and
makes positive results pertaining to these compounds (samples Q04.40 and 441.contained t
2-butanone) unreliable. Additionally, methyiene chloride,1 acetone', chloroform, and
carbon tetrachloride found in the^E blank should be considered contamination.
Overall, the voiatiles data are acceptable, the probability of false negative
results are low. The volatile compound results should be considered quantitative
with achievable CRDL's.
3.4 Base/Neutrals and Acids
Although recoveries are low on the base/neutrals and acids, the data are
acceptable from a quality control view point. Matrix spikes and surrogates are
acceptable although the relative percent difference (RPD) for pentachlorophenol
was outside DQO in the matrix spike/matrix spike duplicate for sample Q0425.
All surrogate spikes in samples Q0440 and 441 (leachate samples) were out of DQO due
to dilutions. The chromatographic quality is acceptable. Very few base/neutrals and
phenols were found in the samples from this facility. Overall, the acids and
base/neutral data are acceptable and should be considered semiquantitative for the
base/neutrals and qualitative for'the acids, (due to predictably low recoveries"on
phenols). Detection limits were twice CRDL on the semivolatiles because the labora-
tory did not completely concentrate the samples to the required volume.
3.5 Pesticides and Herbicides
Other than the previously mentioned problem with the detection of pesticides and
herbicides in the PE sample, there were few obvious laboratory analytical problems
with the pesticides or herbicides other than poor surrogate recoveries for the
herbicides. The chromatographic quality for both pesticides and herbicides look
clean and acceptable. The lab standards results are generally acceptable with the
exception of the herbicide surrogates. The internal spike and matrix spike data are
within acceptable limits. Dilutions/concentrations appear to be properly performed.
The duplicate precision and the average percent recovery for the matrix spike
-------
compounds in the ground water samples are acceptable. The surrogate percent
recoveries were outside DQO for pesticides in leachate samples Q0440 and 441 and for
herbicides in samples Q0415, 424, 434, 440, 441, and 768 as well as blank *74733.
The required detection limits were achieved. DDT (sample Q0422) and an aroclor
(PCB mixture, sample Q0432) were each detected in a single well sample at this
facility and these positive results are considered to be reliable. The pesticides
data, or lack of it, should be considered usable with a low probability of false
negatives. The herbicides, and to a lesser extent the pesticides, data quality
should be considered unknown due to insufficient information to properly assess the
data quality. This data should not, however, be considered unusable.
3.6 Dloxlns and Dibenzofurans
Recoveries of the dioxins from the PE sample by the referee laboratories
(and in the past by the organics lab) appear to be low (IS to 30 percent).
Recoveries of dioxin spikes by the organics laboratory, however, appear to be
quantitative (80 to 119 percent). A significant problem, possibly adsorption
of the dioxins and dibenzofurans to the walls of the sample bottle, is affecting
(diminishing) the concentration of the dioxins in the PE sample and probably, if any
dioxins are present, in the field samples. As no dioxins or dibenzof urans were
detected in the field samples, this problem increases the probability, if the
compounds were initially present in the environmental samples, of false negatives for
these compounds. Based upon data from past facilities, the detection limits for the
dioxins, in field samples, should be considered to be approximately 500 ppt and it is
probable that no dioxins were present above this level in the samples from this
facility. The dioxins data should be considered unreliable.
-------
III. Reference*
1. Organic Analyses: CompuChem Laboratories
Research Triangle Park, NC
Inorganic and Indicator Analyses:
Centec Laboratories
2. Memo: Raymond J. Wcsselman and Edward L. Berg, EMSL/Cincinnati to Review
Committee, GWMTF, 5/16/1986, <3round Water Monitoring Task Force (GWMTF) Evaluation of
Contract Laboratory Program (CLP) Laboratory - Site *12 - Fondessey, Ohio.
3. Hazardous Waste Ground-Water Task Force Laboratory Data Quality Control Evalu-
ation Report for Fondessey Enterprises, Inc. Facility, Oregon, Ohio, 6/3/1986,
Prepared by Life Systems, Inc., Contract No. 68-01-7037, Work Assignment No. 549,
Contact: Timothy E. Tyburski; Prepared for US EPA, Office of Waste Programs Enforce-
ment, Washington, DC.
4. Inorganic Data Usability Audit Report and Organic Data Usability Report,
Prepared by Laboratory Performance Monitoring Group, Lockheed Engineering and
Management Services Co., Las Vegas, Nevada, for US EPA, EMSL/Las Vegas, 6/20/1986 and
6/23/1986.
-------
SUMMARY OF CONCENTRATIONS FOR ORGANIC, INORGANIC AND
INDICATOR PARAMETERS FOUND IN GROUND-WATER AND LEACHATE SAMPLES
AT THE FONDESSY ENTERPRISES, INC. FACILITY, OR£GON, OHIO
Sample
Number
2/4
PE blank
Compound
Carbon tetrachloride
Concentration, ug/L
5. 1
401
Well Gld
402
Field Blank
1-27-86
Acetone
Aluminum (T)
Barium (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Zinc (T)
Aluminum (D)
Barium (D)
Mercury (D)
TOC
Total phenols
Ammonia nitrogen
Sulfate
Chloride
Acetone
Mercury (D)
10
7,600
104
44,700
11
6,540
8,370
117
12,200
75,300
41
30
64
0.4
2,000
106
210
108,000
32,400
10
0,6
403
Well MR2d
Aluminum (T)
Barium (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
1,400
105
86,600
11
1,360
33,400
199
4,820
144,000
continued-
E-l
-------
Sample
Number
403 (cone.)
Compound
Well R4
405
Well MR2s
Zinc (T)
Barium (D)
Calcium (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium (D)
TOC
TOX
Acetone
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Sodium (T)
Antimony (D)
Calcium (D)
Chromium (D) -
Iron (D)
Magnesium (D)
Manganese (D)
Mercury (D)
Potassium (D)
Sodium (D)
TOC
Total phenols
Ammonia nitrogen
Sulfate
Chloride
Methylene chloride
Barium (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Concentration, ug/L
11
99
87,000
34,300
193
4,720
146,000
2,800
8.0
10B
350,000
22
1,040
118,000
11
46,900
66
417,000
15
899
140,000
12
1.0
3,010
55,500
1,000
42
280
1,320,000
29,400
6.3
48
247,000
11
1,640
70,100
772
2,750
133,000
continued-
E-2
-------
Sample
Number
405 (cone.)
Compound
406
Field Blank
1-28-86
407
Well MR3d
Tin (T)
Antimony (D)
Barium (D)
Calcium (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium (D)
Tin (D)
TOC
Aluminum (T)
Iron (T)
Aluminum (D)
Mercury (D)
Total phenols
Aluminum (T)
Barium (T)
Calcium (T)
Chromium (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Nickel (T)
Potassium (T)
Sodium (T)
Tin (T)
Vanadium (T)
Zinc (T)
Barium (D)
Calcium (D)
Iron (D)
Magnesium (D)
Manganese (D)
Mercury (D)
Potassium (D)
Sodium (D)
Zinc (D)
Concentration, ug/L
131
49
262,000
74 , 600
823
2,510
146.000
U;
9,700
90
45
157
0.6
38
22,000
197
307,000
70
44
45,000
. 16.8
85.500
1,620
46
8,380
136,000
51
26
119
115
202,000
108
68,300
1,010
0.6
3,570
143,000
38
E-3
continued-
-------
Sample
Number
Compound
407 (coat.)
408
Well MR3s
409
Well SUG1
TOC
TOX
local phenols
Ammonia nitrogen
Nitrate
Sulfate
Chloride
Aluminum (T)
Antimony (T)
Barium (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Tin (T)
Antimony (D")
Barium (D)
Cadmium (D)
Calcium (D)
Iron (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium (D)
Tin (D)
Zinc (D)
TOC
TOX
Total phenols
Aluminum (T)
Antimony (T)
Barium (T)
Calcium (T)
Chromium (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Concentration, ug/L
4,900
16
18
3,350
430
162,000
240,000
679
70
51
170,000
14
2,880
62,900
551
4,760
104,000
72
71
55
4
177,000
2,140
65,400
606
5,120
109,000
103
22
3,800
17
14
467
153
28
202,000
13
90
2,820
14.2
95,700
E-4
continued-
-------
Sample
Number
Compound
409 (cont.)
410
Well H2d
Manganese (T)
Sodium (T)
Tin (T)
Zinc (T)
Antimony (D)
Barium (D)
Cadmium (D)
Calcium (D)
Chromium (D)
Copper (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium (D)
Tin (D)
Zinc (D)
TOC
TOX
Total phenols
Sulface
Chloride
Aluminum (T)
Antimony (T)
Arsenic (T)
Barium (T)
Beryllium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Cobalt (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Nickel (T)
Potassium (T)
Sodium (T)
Tin (T)
Vanadium (T)
Zinc (T)
Aluminum (D)
Barium (D)
Calcium (D)
Concentration, ug/L
309
59,000
81
260
76
88
k
212,000
10
31
101,000
310
2,640
61,700
75
325
7,500
50
28
3,390
284,000
172,000
358
221
934
5
22
662,000
253
80
153
239,000
160
142,000
3,340
233
39,500
107,000
175
290
489
1,220
422
19,400
concinued-
E-5
-------
Sample
Number
Compound
410 (cont.)
411
His
Chroaium (D)
Copper (D)
Iron (D)
Magnesium (D)
Manganese (D)
Mercury (D)
Potassium (D)
Sodium (D)
Zinc (D)
TOC
TOX
Aluminum (T)
Antimony (T)
Arsenic (T)
Barium (T)
Calcium (T)
Chromium (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Tin (T)
Zinc (T)
Aluminum (D)
Antimony (D)
Barium (D)
Calcium (D)
Chromium (D)
Iron (D)
Magnesium (D)
Manganese (D)
Sodium (D)
Tin (D)
Zinc (D)
TOC
Concentration, ug/L
9
28
837
6,910
49
0.3
2,920
108,000
139
2,900
133
9,750
98
5.5
100
155,000
19
7,930
6.5
80,800
179
4,220
75,400
110
46
78
74
58
140,000
13
53
76,000
179
95,300
103
46
2,100
continued-
E-6
-------
Sample
Number Compound Concentration, ug/L
412 Actton* 11
Well Hl-d
Aluminum (T) 54,700
Antimony (T) 58.9
Arsenic (T) 53.0
Barium (T) 267
Calcium (T) 330,000
Chromium (T) . 327
Cobalt (T) 18
Copper (T) 31
Iron (T) 54,000
Lead (T) 69.6
Magnesium (T) 95,300
Manganese (T) 1,610
Nickel (T) 55
Potassium (T) 20,500
Sodium (T) 141,000
Vanadium (T) 87
Zinc (T) 112
Aluminum (D) 88
Barium (D) 182
Calcium (D) 88,000
Chromium (D) 78
Magnesium (D) 39,100
Manganese (D) 57
Mercury (D) 1.1
Potassium (D) 2,690
Sodium (D) 157,000
Ziac (D) 58
TOC 2,800
Total phenols 68
Ammonia nitrogen 110
Nitrate 790
Sulfate 320,000
Chloride 48,700
413 Aluminum (T) 5,510
Arsenic (T) 4.2
Barium (T) 92
Cadmium (T) 4
Calcium (T) 48,400
Chromium (T) 15
Iron (T) 4,470
Magnesium (T) 21,800
Manganese (T) 175
continued-
E-7
-------
Sample
Number
413 (coat.)
Compound
414
Well F2s
Potassium (T)
Sodium (T)
Tin (T)
Zinc (T)
Barium (D)
Calcium (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Silver (D)
Sodium (D)
Tin (D)
Zinc (D)
TOC
1,1-Dichloroethane
Aluminum (T)
Antimony (T)
Barium (T)
Calcium (T)
Chromium (7)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Tin (T)
Zinc (T)
Antimony (D)
Barium (D)
Cadmium (D)
Calcium (D)
Chromium (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium
Tin (D)
Zinc (D)
TOC
Concentration, ug/L
7,470
103,000
40
14
76
41,100
20,600
120
6,060
10
108,000
40
22
3,100
17.0
272
123
30
209,000
14
728
130,000
327
3,260
114,000
87
16
179
30
5
221,000
22
140,000
318
5,410
121,000
73
18
3,500
E-8
continued-
-------
Sample
Number
Compound
415
Well Gls
416
Field blank
1-31-86
417
Well SDG1
Aluminum (I)
Barium (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Zinc (T)
Aluminum (D)
Barium (D)
Calcium (D)
Magnesium (D)
Manganese (D)
Mercury (D)
Sodium (D)
Zinc (D)
TOC
TOX
Total phenols
Ammonia nitrogen
Sulfate
Chloride
Sodium (T)
Tin (T)
Silver (D)
Tin (D)
TOX
Aluminum (T)
Antimony (T)
Arsenic (T)
Barium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Concentration, ug/L
3,690
58
246,000
20
3,000
94,800
329
2,480
83,800
17
132
37
266,000
109,000
330
0.3
94,100
13
3,400
12
56
5,000
342,000
165,000
570
53
12
55
8.0
12,700
115
10
129
5
125,000
19
8,610
28.5
105,000
1,470
6,430
64,600
continued-
E-9
-------
Sample
Number
Compound
(cent.)
418
Well G3s
Tin (T)
Zinc (T)
Aluminum (D)
Antimony (D)
Barium (D)
Cadmium (D>
Calcium (D)
Chromium (D)
Iron (D)
Lead (D)
Magnesium (D/
Manganese (D)
Potassium (D)
Sodium (D)
Tin (D)
Zinc (D)
TOC
TOX
Antimony (T)
Barium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Tin (T)
Barium (D)
Cadmium (D)
Calcium (D)
Chromium (0)
Iron (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium (D)
Tin (D)
TOC
Concentration, ug/l
99
108
326
147
79
5
130,000
23
1,180
11.9
106,000
1,510
2,470
65,300
95
83
3,400
37
133
31
4
240,000
22
421
92,000
691
5,430
31,400
72
33
4
261,000
29
62
100,000
765
6,560
33,700
108
1,500
E-10
continued-
-------
Sample
Number
419
Field blank
1-29-86
Compound
420
Well H4s
421
Well Fls
Aluminum (T)
Chromium (T)
Sodium (T)
Aluminum (D)
Mercury (D)
Sodium (D)
Total phenols
Sulface
Aluminum (T)
Arsenic
Barium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Iron (T)
Le*d (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Tin (T)
Vanadium (T)
Zinc (T)
Barium (D)
Calcium (D)
Chromium (D)
Magnesium (D)
Manganese (D)
Sodium (D)
Tin (D)
TOC
TOX
Aluminum (T)
Antimony (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Potassium (T)
Sodium (T)
Tin (T)
Concentration, ug/L
156
112
615
114
0.6
525
10
500
35,600
12.5
233
6
182,000
40
27,600
U.5
62,600
499
13,600
33,000
148
48
90
(71)
130,000
18
48,100
49
32,300
102
1,900
8.0
535
101
173,000
16
397
131,000
196
6,510
363,000
55
E-ll
continued-
-------
Sample
Number Compound Concentration, ug/L
421 (coat.) Zinc (T) 19
Antimony (D) 100
Cadmium (D) 4
Calcium (D) 186,000
Magnesium (D) 142,000
Manganese (D) 205
Potassium (D) 6,560
Sodium (D) 395,000
Tin (D) 92
Zinc (D) 21
TOX 13
422 4,4'-DDT 0.58
Well Fid
Aluminum (T) 41,900
Arsenic (T) 20.0
Barium (T) 377
Calcium (T) 187,000
Chromium (T) 48
Cobalt (T) 19
Copper (T) 30
Iron (T) 53,400
Lead (T) 18.5
Magnesium (T) 33,100
Manganese (T) 847
Nickel (T) 57
Potassium (T) 18,600
Sodium (T) 85,400
Vanadium (T) 85
Zinc (T) 135
Aluminum (D) 327
Barium (D) 29
Calcium (D) 2,690
Iron (D) 155
Mercury (D) :1.1
Potassium (D) 5,560
Sodium (D) 90,100
TOC 2,600
Total phenols 60
Ammonia nitrogen 540
Nitrate 1,250
Sulfate 40,000
Chloride 233,000
r , p continued-
-------
Sample
Number
Compound
423
Well H4d
424
Field blank
1-30-86
Aluminua (T)
Antimony (T)
Arsenic (T)
Bariun (T)
Beryllium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Cobalt (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Nickel (T)
Potassium (T)
Sodium (T)
Vanadium (T)
Zinc (T)
Aluminum (D)
Arsenic (D)
Barium (D)
Calcium (D)
Iron (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium (D)
Zinc (D)
TOC
TOX
Total phenols
Ammonia nitrogen
Sulfate
Chloride
Copper (T)
Iron (T)
Sodium (T)
Aluminum (D)
Total phenol
Nitrate
Concentration, ug/L
294,000
226
301
•1,820
11
35
1,060,000
• 325
141
243
372,000
88.8
225,000
5,390
381
90,300
87,900
649
761
705
4.9
513
16,900
461
6,200
25
3,980
97,100
26
2,600
5.0
48
240
33,000
22,300
(23)
(58)
(524)
(125)
26
400
E-13
continued-
-------
Sample
Number Compound Concept rat ion, ug/L
425 Acetone 11
Wel1 R2 Calcium (T) 173,000
Chromium (T) 13
Iron (T) 526
Magnesium (T) 72,400
Manganese (T) 5
Sodium (T) 61,400
Tin (T) 55
Calcium (D) 190,000
Iron (D) 318
Magnesium (D) 78,200
Manganese (D) 5
Sodium (D) 67,200
Tin (D) 49
TOC 1,300
TOX 8.0
Total phenols 18
Ammonia nitrogen 190
. Sulfate 69,000
Chloride 27,300
426 Antimony (T) 134
Well R2 (Dup.) Calcium (T) 170,000
Chromium (T) 11
Iron (T) 525
Magnesium (T) 69,800
Manganese (T) 5
Sodium (T) 59,800
Tin (T) 48
Calcium (D) 191,000
Chromium (D) 12
Iron (D) 307
Magnesium (D) 79,900
Manganese (D) 6
Sodium (D) 64,900
Tin (D) 55
TOC 1,300
TOX 5.0
Total phenols 18
Ammonia nitrogen 220
Sulfate 620,000
Chloride 35,500
continued-
E-14
-------
Sample
Number
Compound
427
R-8
428
R-8
429
Field blank
2-3-86
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Potassium (T)
Sodium (T)
Tin (T)
Antimony (D)
Calcium (D)
Chromium (D)
Magnesium (D)
Potassium (0)
Sodium (D)
Tin (D)
TOC
Ammonia nitrogen
Sulfate
Chloride
Cadmium (T)
Calcium (T)
Chromium (T)
Iron (T)
Magnesium (T)
Sodium (T)
Tin (T)
Cadmium (D)
Calcium (D)
Chromium (D)
Magnesium (D)
Potassium (D)
Sodium (D)
Tin (D)
TOC
TOX
Total phenols
Ammonia nitrogen
Sulface
Chloride
Chromium (T)
Chromium (D)
Total phenols
Concentration, ug/L
155,000
15
121
66,900
2,560
59,700
78
145
167,000
19
70,300
3,070
64,000
146
1,000
150
540,000
22,300
4
151,000
17
120
64,100
58,000
75
4
170,000
13
71,800
2,920
66,200
66
1,000
6.0
106
160
580,000
13,200
10
14
10
cootinued-
E-15
-------
Sample
Number Compound Concentration, ug/L
430 Antimony (T) 182
R-5 Calcium (T) 233,000
Chromium (T) 19
Iron (T) 395
Magnesium (T) 89,500
Manganese (T) 6
Antimony (D) 118
Calcium (D) 25,000
Chromium (D) 17
Magnesium (D) 98,300
Manganese (D) 6
Sodium (D) 51,300
Tin (D) 99
TOC 1,000
TOX 8.0
Total phenols 28
Ammonia nitrogen 150
Sulfate 850,000
Chloride 22,300
431 Antimony (T) 85
R-7 Cadmium (T) 5
Calcium (T) 408,000
Chromium (T) 23
Iron (T) 1.140
Magnesium (T) 108,000
Manganese (T) 7
Potassium (T) 2,470
Sodium (T) 58,300
Tin (T) 99
Antimony (D) 133
Cadmium (D) 5
Calcium (D) 451,000
Chromium (D) 21
Iron (D) ' 438
Magnesium (D) 117,000
Manganese (D) 7
Potassium (D) 3,020
Sodium (D) 59,900
Tin (D) 75
E-16
continued-
-------
Saaple
Number Compound Concentration, ug/L
TOC 1,100
local phenols 14
Ammonia nitrogen 190
Sulfate 1,310,000
Chloride 40,600
432 Aroclor-1260 8.3
R-6
Aluminum (T) 142
Calcium (T) 90,800
Chromium (T) 8
Magnesium (T) 37,500
Sodium (T) 46,900
Tin (T) 74
Calcium (D) . 96,600
Chromium (D) 11
Magnesium (D) 41,200
Manganese (D) 5
Mercury (D) 0.3
Sodium (D) 51,200
Tin (D) 59
TOC 1,200
Total phenols 62
Ammonia nitrogen 120
Sulfate 284,000
Chloride 13,200
433 Aluminum (T) 90,800
Well M7s Antimony (T) 230
Arsenic (T) 108
Barium (T) 568
Beryllium (T) 5
Cadmium (T) 15
Calcium (T) 812,000
Chromium (T) 155
Cobalt (T) 35
Copper (T) 94
Iron (T) 119,000
Lead (T) 103
Magnesium (T) 211,000
Manganese (T) 3,830
Nickel (T) 118
Potassium (T) 21,600
Sodium (T) 59,600
Tin (T) 118
continued-
E-17
-------
Sample
Number
433 (cone)
Compound
434
SDG2
Vanadium (T)
Zinc (T)
Aluminum (0)
Barium (D)
Calcium (D)
Chromium (D)
Magnesium (D)
Manganese (D)
Sodium (D)
Tin (D)
TOC
TOX
Total phenols
Sulfate
Chloride
Aluminum (T)
Antimony (T)
Barium (T)
Calcium (T)
Copper (T)
Iron (T)
Uad (T)
Magnesium (T)
Manganese (T)
Mercury (T)
Potassium (T)
Sodiua (T)
Tin (T)
Zinc (T)
Antimony (D)
Barium (D)
Cadmium (D)
Calcium (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium (D)
Tin (D)
Zinc (D)
TOC
TOX
Concentration, ug/L
179
366
126
54
182,000
12
64,100
360
59,800
70
9,300
12
69
201,000
23,300
1,530
80
35
234,000
22
4,450
26.7
139,000
695
0.2
3,950
57,900
40
186
119
29
4
258,000
155,000
743
3,510
65,200
54
11,000
50
E-18
continued-
-------
Sample
Number Compound Concentration, jg
*35 Aluminum (T) 141,000
TB2 Antimony (T) 567
Arsenic (T) 52.5
Barium (T) 1,870
Beryllium (T) 7
Cadmium (T) 62
Calcium (T) 1,740,000
Chromium (T) 664
Cobalt (T) 61
Copper (T) 572
Iron (T) 179,000
Lead (T) 1,680
Magnesium (T) 826,000
Manganese (T) 2,940
Mercury (T) 7.5
Nickel (T) 525
Potassium (T) 44,600
Sodium (T) 43,200
Tin (T) i29
Vanadium (T) 3L4
Zinc (T) 3,190
Antimony (D) 86
Barium (D) 38
Calcium (D) 203,000
Chromium (D) 18
Magnesium (D) 146,000
Potassium (D) 5,230
Sodium (D) 46,300
Tin (D) 94
TOC 6,800
TOX 9.0
local phenols 52
Sulfate 520,000
Chloride 79,100
*36 Aluminum (T) 162,000
TB1 Arsenic (T) 38.0
Barium (T) 943
Beryllium (T) 7
Cadmium (T) 19
Calcium (T) 438,000
Chromium (T) 247
Cobalt (T) 62
Copper (T) 116
Iron (T) 166,000
concinued-
E-19
-------
Sample
Number
436 (cone)
Compound
Concent rat iun
,'T
437
Well M4d
Lead (T)
Magnesium (T)
Manganese (T)
Sickel (T)
Potassium (T)
Sodium (T)
Vanadium (T)
Zinc (T)
Antimony (D)
3arium (D)
Calcium (D)
.Chromium (D)
Iron (D)
Magnesium (D)
Manganese (D)
Potassium (D)
Sodium
Tin (D)
Zinc (D)
TOG
TOX
Total phenols
Ammonia nitrogen
Sulfate
Chloride
Aluminum (T)
Antimony (T)
Arsenic (T)
Bariim (T)
CadmiuB (T)
Calcium (T)
Chromium (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Nickel (T)
Potassium (T)
Sodium (T)
Tin (T)
Vanadium (T)
Zinc (T)
Aluminum (D)
17.6
108,000
2,710
188
55,300
68 , 000
404
404
104
55
299,000
22
3, 190
216,000
401
i:,3oo
54,400
96
45
5,600
20
14
150
710,000
90,200
49,500
140
84.5
224
10
407,000
84
28
61,300
39.1
224,000
959
59
27,700
52,300
113
79
293
282
E-20
continued-
-------
Sample
Sumb«r
Compound
437 (cone.)
418
Well M4s
439
Field blank
2-4-86
440
Call F
leachate
Barium (D)
Calcium (D)
Iron (D)
Magnesium (0)
Manganese (D)
Potassium (D)
Selenium (D)
Sodium (D;
TOC
TOX
Total phenols
Ammonia nicrogen
Sulfate
Chloride
Aluminum (T)
Antimony (T)
Barium (T)
Calcium (T)
Iron (T)
Magnesium (T)
Manganese (T)
Sodium (T)
Zinc (T)
Antimony (D)
Barium (D)
Calciua (D)
Magnesium (D)
Manganese (D)
Sodium (D)
TOC
TOX
Aluminum (T)
Acetone
2-3utanone
4-Methyl-2-pencanone
Acrylonitrile
Phenol
Benzyl alcohol
Benzoic acid
Isobutvi alcohol
Concentration, ,g L
108
16,000
152
6,760
56
2,980
3.1
68,200
3,300
8.0
20
150
23,600
17,700
650
60
38
117,000
793
56,900
20
18,900
11
81
36
124,000
63,500
9
20,600
1,400
7.0
210
6.2E+C5
l.OE+6
71,000
2.6
93,000
28,000
1.9E-HD5
1,000
E-21
continuec-
-------
Sample
Number
439 (cone.)
Compound
441
Cell H
leachate
Aluminum (T)
Antimony (T)
Arsenic (T)
Barium (T)
Cadmium (T)
Calcium (T)
Chromium (T)
Cobalt (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Nickel (T)
Potassium (T)
Selenium (T)
Sodium (T)
Tin (T)
Zinc (T)
POC
POX
TOG
Total phenols
Ammonia nitrogen
Nitrate
Sulfate
Chloride
Cyanide
Methylene chloride
Acetone
2-Butanone
4-Methyl-2-pentanone
Acrylonitrile
4-Methylphenol
Benzoic acid
1,4 Dioxane
Acrylonitrile
Aluminum (T)
Arsenic (T)
Barium (T)
Cadmium (T)
Calcium (T)
Concentration, ug/L
744
513
39,900
270
490
1,100,000
1,360
1,730
480
12,900
11,600
81,200
1,250
38,900
14,200,000
248
18,800,000
2,080
22,100
810,000
3,700
30,400,000
296,000
460,000
460
6,580,000
14,400,000
340
1.31+05
4.4E-HD5
4.6E+05
68,000
6.3
4,100
2.0E+05
400
6.3
2,100
15,900
680
120
891,000
continued-
E-22
-------
Sample
Number
Compound
441 (coat.)
442
Field blank
2-6-36
443
Well M7d
444
Field blank
2-5-86
Chromium (T)
Cobalt (T)
Copper (T)
Iron (T)
Lead (T)
Magnesium (T)
Manganese (T)
Nickel (T)
Potassium (T)
Selenium (T)
Sodium (T)
Tin (T)
Vanadium (T)
Zinc (T)
POC
POX
TOC
TOX
Total phenols
Ammonia nitrogen
Sulfate
Chloride
Cyanide
Silver (D)
Total phenols
TOC
TOX
Concentration, ug/L
675
240
1,040
19,800
635
215,000
4,060
6,090
4,610,000
172
7,560,000
488
175
15,500
470,000
70,000
11,410,000
49,500
62,000
500,000
3,740,000
7,550,000
96
22
3,300
9.0
445
Equipment
blank
Selenium (T)
TOC
Total phenols
4.6
6,500
18
continued-
E-23
-------
Sample
Number
Compound
768
PE sample
769
Trip blank
Methylene chloride
Acetone
Chloroform
2-Butanone
Bromodichloromethane
Dibromochloronethane
Bromoform
Toluene
Chlorobenzene
2-Methylphenol
4-Chloroaniline
Acenaphthylene
Phenanthrene
Benzo(a)anthracene
Benzo(b)fluoranthene
3enzo(k)fluoranchene
Oibenz(a,h)anthracene
Benzo(g,h,1)perylene
Arsenic (T)
Barium (T)
Chromium (T)
Lead (T)
Mercury (T)
Selenium (T)
Vanadium (T)
Antimony (D)
Arsenic (D)
Bariua (D)
Chromium (D)
Lead (D)
Manganese (D)
Mercury (D)
Selenium (D)
Vanadium (D)
POC
POX
TOC
TOX
Total phenols
Aamonia nitrogen
Cyanide
Chromium (T)
Aluminum (D)
Concentration, ug/L
8.9
36
49
31
43
36
35
78
78
31
32
230
170
21
20
20
29
26
161
497
34
82
4.7
24.4
80
71
166
498
61
84.5
6
4.7
37.2
103
634
37
23,000
50
14
8,000
105
8
178
E-24
-------
TENTATIVELY IDENTIFIED COMPOUNDS REQUIRING
CONFIRMATION USING AUTHENTIC STANDARDS
Sample
N'umbe r
Q0434
Q0437
Q0439
Q04L6
Q0274
Q0440
Compound
Q0441
2-Piperidinecarboxylic Acid, 1-Fonnyl-
Cyclopentanone, 2-Methyl-
1,3-Cyclopentanedione, 2-Chioro-
1,3-Cyclopentan«dione, 2-Chioro-
1-Decene, 9-snethyl-
Ethanol
2-Butanone
1-Butanol
Echanol,2,2-Oxybis-
Echanol, 2-butoxy-
Hexanoic Acid, 2-methyl-
Oxirane, (Butoxymethyl-
1,3-Propanediol, 2,2-Dimethyl-
Ethanol,2-(2-e choxyechoxy)-
2-Pyrrolidinone, 1-oechyl-
Heptanoic Acid
Pentanoic Acid, butylester
Hexanoic Acid, 2-«thyl-
1,3-Pentamediol, 2,2,4-trimethyl-
Ethanol, 2-(2-butoxyethoxy)-
Ethanol, 2-(2-(2-m«thoxyethoxy)ethoxy)-
(scan aumber 605)
Ethanol, 2-(2-(2-«thoxyethoxy)ethoxy)-
(scan number 644)
Cyclohexanemethanol, 4-hydroxy-. Alpha.,
Alpha., 4-tri
1,3-Isob«Q2ofurandione
Ethanol, 2-(2-(2-butoxyethoxy)ethoxy)-
7-Octen-2-01, 2-methyl-6-methylene-
Ethanol
Methane, dichloro-
2-Propanooe
2-Butanone
1-Butanol
2-Propanol, L-mechoxy
Propane, 1,2-dimethoxy
Ethanol, 2-butoxy-
Hexanoic Acid, 2-methyl-
Cyclopentanol, 2-methyl-cis-
Oxirane, (Butoxymethyl)-
2-Pyrrolidinone, 1-aethyl-
Hexanoic Acid, 2-ethyl
Ethanol, 2-(2-Butoxyethoxy)-
7-Octen-2-01, 2-methyl-6-methylene-
Concentration, ug/L
15
13
12
61
8
1,000
1,200
2,500
2,500
3,000
28,000
90,000
16,000
85,000
860,000
290,000
11,000
71,000
53,000
11,000
24,000
48,000
21,000
28,000
27,000
52,000
700
360
910
1,100
270
130
2,400
1,300
28,000
80,000
280,000
25,000
140,000
64,000
13,000
E-25
------- |