EPA-7OO 8-87-O3O
Hazardous Waste Ground-Water
Task Force
Evaluation of
CHEMICAL WASTE MANAGEMENT, INC.
CARLYSS, LOUISIANA
&EPA
U.S. Environmental Protection Agency
Louisiana Department of Environmental Quality
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
HAZARDOUS WASTE GROUNDWATER TASK FORCE
GROUNDWATER MONITORING EVALUATION
CHEMICAL WASTE MANAGEMENT, INC.
CARLYSS, LOUISIANA
SEPTEMBER 1987
THOMAS E. AALTO
PROJECT COORDINATOR
U.S. EPA REGION VI, DALLAS, TEXAS
-------
UPDATE TO THE GROUNDWATER TASK FORCE REPORT
FOR
CHEMICAL WASTE MANAGEMENT, INC.
CARLYSS, LOUISIANA
The Task Force report discusses conditions that were present at
the site at the time of the April 1987 inspection. Listed below are
selected items pertaining to events which transpired after the
inspection during the period April 1987 to September 1987.
0 On April 24, 1987, the facility submitted a proposal to modify
the placement of additional monitoring wells. The proposal called
for the placement of additional monitoring wells immediately
downgradient of landfill cells 5 and 14, and was subsequently
approved by the State on May 5, 1987.
0 On July 14, 1987, after statistically triggering RCRA indicator
parameters for the first quarter 1987 sampling event, the facility
submitted a certified groundwater quality assessment plan to
the State. This plan includes provisions for performing priority
pollutant scans on all facility RCRA monitoring wells.
0 During the period July-September 1987, the facility began
implementation of the plan to install additional monitoring
wells at the site.
-------
CONTENTS
EXECUTIVE SUMMARY Page
INTRODUCTION 1
SITE BACKGROUND 4
SUMMARY OF FINDINGS AND RECOMMENDATIONS 8
TECHNICAL REPORT
INVESTIGATION METHODS 11
HAZARDOUS WASTE MANAGEMENT UNITS AND OPERATIONS 14
SITE HYDROGEOLOGY 25
GROUNDWATER MONITORING PROGRAM DURING INTERIM STATUS 30
GROUNDWATER MONITORING PROGRAM PROPOSED BY FACILITY FOR
FINAL PERMIT 44
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES 48
TASK FORCE MONITORING DATA ANALYSIS FOR INDICATIONS OF
WASTE RELEASE 53
REFERENCES 56
APPENDICES
A TASK FORCE ANALYTICAL RESULTS
B FACILITY RCRA MONITORING WELL LOGS
C CWM PETITION FOR REGULATORY MODIFICATIONS.
D SELECTED LANDFILL CONSTRUCTION DIAGRAMS...
FIGURES
1 SITE LOCATION MAP 5
2 FACILITY SOLID WASTE MANAGEMENT UNITS MAP 15
3 GENERALIZED STRATIGRAPHIC COLUMN 26
4 MAP OF EXISTING FACILITY GROUNDWATER MONITORING NETWORK.. 31
5 SELECTED FACILITY GROUNDWATER LEVEL DATA 32
6 MAP OF FACILITY-PROPOSED GROUNDWATER MONITORING NETWORK.. 42
TABLES
1 GENERAL WASTE - TYPES LANDFILLED AT CWM 16
2 GROUNDWATER MONITORING WELL INFORMATION 36
3 TASK FORCE GROUNDWATER LEVEL MEASUREMENTS 49
4 PARAMETER, BOTTLE TYPE, AND PRESERVATIVE LIST
FOR TASK FORCE SITES 51
-------
EXECUTIVE SUMMARY
-------
INTRODUCTION
Recently, concerns have been raised about whether hazardous waste
treatment, storage and disposal facilities (TSDFs) are in compliance
with the ground-water monitoring requirements promulgated under the
Resource Conservation and Recovery Act of 1976 (RCRA)*. Specifically,
the concerns focus on the ability of ground-water monitoring systems to
detect contaminant releases from waste management units at TSDFs. In
response to these concerns, the Administrator of the Environmental
Protection Agency (EPA) established a Hazardous Waste Ground-Water Task
Force (Task Force) to evaluate compliance at TSDFs and address the
cause(s) of noncompliance. The Task Force is comprised of personnel
from EPA headqjarters, EPA regional offices, and State regulatory
agencies. To determine compliance, the Task Force is conducting in-
depth onsite investigations of TSDFs. The objectives of these
evaluations are to:
0 Determine compliance with ground-water monitoring requirements
of 40 CFR Part 265, Suhpart F, "Interim Status Standards for
Groundwater Monitoring", as promulgated under RCRA or the State
equivalent (where the State has received RCRA authorization);
0 Evaluate the ground-water monitoring program described in the
facility's RCRA Part B permit application for compliance with
40 CFR Section 270.14(c), "Additional Information Requirements";
and potential compliance with the rules set forth in 40 CFR
Part 264, "Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities";
* Regulations promulgated under RCRA address hazardous waste
management facility operations, including ground-water monitor-
ing, to ensure that hazardous waste constituents are not released
to the environment.
-1-
-------
0 Determine if the ground water at the facility contains hazardous
waste or hazardous waste constituents;
0 Provide information to assist the Agency in determining if the
TSDF meets EPA ground-water monitoring requirements for waste
management facilities receiving waste from response actions
conducted under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA)*; and
0 Assist in the development of vigorous, nationally consistent
methods for conducting groundwater evaluations and implementing
follow-up actions.
To address these objectives, each Task Force evaluation will determine
if:
0 The facility has developed and is following an adequate ground-
water sampling and analysis plan;
0 Designated RCRA-re quired and/or State-re quired monitoring wells
are properly located and constructed;
0 Required analyses have been conducted on samples from the
designated RCRA monitoring wells;
0 The groundwater quality assessment program outline (or plan
as the case may be) is adequate; and whether
0 Recordkeeping and reporting procedures for groundwater monitoring
are adequate.
* EPA policy, stated in the May 6, 1985 memorandum from Jack McGraw
on "Procedures for Planning and Implementing Offsite Response",
requires that TSDFs receiving CERCLA wastes he in compliance
with applicable RCRA ground-water monitoring requirements.
-2-
-------
The Chemical Waste Management, Inc. facility of Carlyss, Louisiana
(hereinafter, "CWM") Task Force evaluation was conducted by EPA Region
VI in cooperation with EPA Headqiarters and the Louisiana Department of
Environmental Quality. The evaluation included an extensive review of
State, Federal and facility records, a one-week onsite facility sampling
inspection, and subsequent review of analytical data results. The
onsite inspection was conducted from April 20 through April 24, 1987.
It involved sampling, as well as extensive interviews with facility
management and personnel concerning site operations and the facility's
groundwater monitoring system.
Disclaimer:
The mention of any trade names in this report does not constitute
endorsement.
[Note: Unless otherwise stated, all Figures, Tables, and Diagrams
presented in this report were obtained from facility records.]
-3-
-------
SITE BACKGROUND
The CWM facility is a 280-acre commercial hazardous waste land
disposal site located approximately eight miles south-southwest of Sulphur
and ten miles west of Lake Charles, Louisiana, near the town of Carlyss,
(See Figure 1). Access to the site is along John Brannon Road. The
current mailing address, telephone number and EPA facility identification
number are:
Address: Chemical Waste Management, Inc.
Route 2, P.O. Box 1955
Sulphur, Louisiana 70663
Telephone Number: (318) 583-2169
EPA Identification Number: LAD000777201
The site General Manager is Mr. William Kitto.
CWM is a major operating division and wholly owned subsidiary of
Waste Management, Inc., which specializes in the processing and disposal
of waste materials. CWM currently operates a network of chemical waste
process disposal centers from coast to coast.
The site is located in a flat, low-lying (5-10 feet above mean sea
level) agricultural area which is thinly wooded, except along water-courses.
The surrounding area is sparsely populated, containing an estimated 400
people within a 2 mile radius, all of whom utilize private wells for
drinking water. According to the facility, most drinking water wells in this
area are screened at a depth of from 200 to 460 feet in the Chicot Aquifer.
Currently, the facility utilizes a 160 acre area west of John Brannon
Road for the management and disposal of hazardous waste. This area, which
is enclosed by a 40-foot deep slurry wall, contains the following RCRA-
regulated hazardous waste management units which are subject to groundwater
monitoring requirements under 40 CFR §265 Subpart F: an active landfill
cell known as cell 14, a closed landfill cell known as cell 5, a former
surface impoundment, and a landfill cell under construction known as
cell 6. This area also contains other RCRA hazardous waste management
units such as site mixing, treatment, drum storage, and tank storage units.
-4-
-------
r
/^^~cT,VTJ-T~ £
/ • /-^V-jH ";
/BEAu«G*VVlAL\EN
-N-
UNITED STATES
(1972)
Figure 1
-5-
-------
East of John Brannon Road is approximately 120 acres that were
formerly used for landfarming and sanitary landfilling operations. The
CWM site office is located near the former landfarm area, just off John
Brannon Road.
The site operates under RCRA interim status regulations and a
State hazardous waste disposal permit which was issued hy the Louisiana
Environmental Control Commission (now the Louisiana Department of Environmental
Quality) on July 26, 1982. The facility has applied for final operating
permits under State and Federal authorities, and plans to continue
using the site for landfilling activities until around the year 2030.
Hazardous waste management activities began at the site in 1975
under the ownership of Sediment Removers Inc. (SRI). In November 1975,
SRI received authorization to operate an industrial waste landfill from
the Louisiana Office of Health Services and Environmental Quality.
This authorization included landfarming operations which were begun the
following year.
CWM aquired the site from SRI in December 1979 and initiated
several activities to upgrade disposal operations. These activities
included construction of a perimeter slurry wall around landfilling
operations (west of John Brannon Road) and the excavation and removal
of certain formerly buried wastes. Also, in 1980 CWM terminated
landfarming activities.
Since 1984, the site has received hazardous wastes from Federally-
mandated clean-up operations under CERCLA ("Superfund") on a periodic
basis. Beginning in May 1985, this has required that the facility meet
the requirements of EPA's "Off-Site Policy" (which in part requires that
the site has no Class I violations). Due to these requirements, and
certain violations in operating procedures that were discovered during
a September 1986 State inspection, the site was not eligible to receive
Superfund wastes during the period December 8, 1986 to February 13, 1987
(as per notification from EPA).
At the time of the Task Force inspection, the facility was reported
to he compliance with applicable requirements under the Off-Site Policy
-6-
-------
and was receiving wastes from the Highland Acid Pits Superfund site in
Texas. These wastes were disposed in the active landfill (cell 14).
[According to facility personnel, former landfill cell 5 also received
Superfund wastes during its active life].
Between 1978 and the present, a number of groundwater monitoring
wells have been installed around the perimeter of the site (the deepest
of which extend to a depth of around 80 feet) to check for contaminants
migrating from disposal units. Historically, these wells have shown
significant variations in RCRA indicator parameters (pH, specific
Conductance, Total Organic Carbon, and Total Organic Halogens) using
the Student's t-test. CWM has contended that the RCRA indicator paramters
and Student's t-test do not always yield reliable results and has
performed annual priority pollutant scans on selected monitoring wells
to demonstrate that contamination has not occurred at the site. As a
result of the priority pollutant scans (and quarterly scans of
facility indicator parameters - benzene, phenol, lead, chromium, cyanide),
the facility reports that groundwater contamination has not occurred at
the site and, therefore, considers itself to he in a detection monitoring
mode.
As required by HSWA, CWM submitted a certification by November 8,
1985 that it was in compliance with applicable RCRA groundwater monitoring
and financial assurance requirements. This allowed the site to continue
operations under RCRA interim status (as long as interim status was
maintained) pending a final permit determination.
CWM has received occasional attention from local media and citizen
groups in the last few years concerning site operations. This attention
was heightened during the 1982 public hearings that were held regarding
the draft state permit. The primary concerns that have been expressed
by citizen groups include facility characterization of site hydrogeology,
and the possibility of contamination from site disposal activities.
These concerns include the potential vulnerability of a shallow permeable
zone known as the "Channel Sand" near the north end of landfill cell 5,
and the occasional occurrence of phenols at low concentrations in
certain groundwater monitoring wells.
-7-
-------
SUMMARY OF FINDINGS AND RECOMMENDATIONS
The findings and recommendations presented in this report reflect the
conditions existing at the facility and practices used by facility
personnel at the time of the Task Force investigation in April 1987.
Subsequent actions taken by the facility, the State, and Region VI since
the investigation are summarized in the accompanying report update.
As a result of the Task Force evaluation at CWM, no definitive
indication of groundwater contamination was discovered. Also, no
groundwater samples showed values which exceeded the "Maximum Concentration
of Constituents For Ground-Water Protection" in 40 CFR §264.94.
The Task Force determined that CWM had at least two regulatory deficiencies,
and at least two technical deficiencies in its groundwater monitoring
program. These findings are discussed below along with selected Task
Force recommendations (for a complete listing of all Task Force recommendations,
the reader is referred to the appropriate sections in the text of the
technical report).
Regulatory Deficiencies
1. The facility has historically shown statistically significant
variations in RCRA groundwater monitoring indicator parameters and has
not submitted a certified groundwater quality assessment plan as required
by 40 CFR §265.93, and LHWR Section 23.37.
2. The current facility groundwater monitoring system does not
ensure that potential contaminants emanating from the regulated units
will be detected immediately as required by 40 CFR §265.91, and LHWR
Section 23.35.
Technical Deficiencies
1. The facility has not delineated the full vertical and horizontal
extent of the Channel Sand (underlying the northeast corner of the
current waste management area).
2. The facility has not performed aquifer-testing (pump tests or
slug tests) of the 60-Foot Sand and Channel Sand to empirically verify
insitu permeabilities and flow rates.
-8-
-------
Tas_k__Fprce Recommendations Concerning Regulatory Deficiencies Cited
1. The facility should be required to submit a certified groundwater
quality assessment plan to the State to satisfy the requirements of
LHWR §23.37. This plan should describe the procedures used by the
facility to demonstrate that groundwater contamination has not
occurred, and should include the following provisions:
a) Priority pollutant scans should be run on all RCRA monitoring
wells;
b) Routine quarterly sampling for RCRA indicator parameters (TOC,
(TOX, pH, and specific conductance) and facility - proposed
indicator parameters (VOCs, phenol, lead, chromium, and arsenic)
should continue; and
c) A schedule for implementationn and reporting should be
established.
2. Additional monitoring wells should be installed around the
west and south sides of landfill cells 5 and 14 as soon as
possible. These wells should screen the entire thickness of
the 60-Foot Sand (i.e., should screen the interval between 60
and 70 feet deep) and should be located as shown in Figure 6.
Task Force Recommendations Concerning Technical Deficiencies Cited
. 1. The facility should delineate the full vertical and horizontal
extent of the Channel Sand by conducting a comprehensive soil
boring and sampling program. This should include drilling and
sampling near the north end of landfill cell 5 and near the
southwest corner of the former sanitary landfill. Based on the
results of this investigation, additional monitoring wells may be
required in the Channel Sand near the north end of landfill
cell 5 to monitor for dense phase contaminants.
2. The facility should perform aquifer pump tests or slug tests
on the 60-Foot Sand and Channel Sand to verify insitu values
of hydraulic conductivity, and flow velocities.
-9-
-------
Additional Task Force Recommendations
1. The facility should drill and sample borings into the top of
the Chicot Aquifer to obtain additional site hydrogeologic
information.
2. The facility should increase the number of facility indicator
parameters (VOCs, cyanide, lead, chromium, phenol) to include
other parameters that could be indicative of waste migration
(such as high chloride or low pH values).
3. The facility should provide further justification for its proposed
groundwater monitoring statistical procedures. The burden of
proof lies with the facility that its proposed procedures will
minimize false negative results while reducing false positive
results.
4. The facility should ensure that landfill leachate levels are
maintained below the Lower Pervious Zone. If leachate levels rise
to the Lower Pervious Zone (or above) additional monitoring of
this zone may be necessary.
5. The facility should continue to monitor the landfill leachate
detection and pressure relief systems for indications of waste
migrating from these disposal units.
6. The facility should minimize ponding of surface water within the
current waste management area to minimize induced hydraulic head
in this area.
7. The facility should install additional upgradient monitoring wells
in the 60-Foot Sand and Channel Sand along the north boundary of
the current waste management area.
-10-
-------
TECHNICAL REPORT
-------
INVESTIGATION METHODS
The objective of the Task Force was to evaluate the facility's
groundwater monitoring system for RCRA hazardous waste management units.
An evaluation of each solid waste management unit was performed during
an EPA RCRA Facility Assessment, Visual Site Inspection during the
period April 30 to May 1, 1987.
The Task Force evaluation of the CWM site included the following:
0 A review and evaluation of records and documents
from EPA Region VI, DEQ, and CWM;
0 An onsite inspection (April 20-24,1987) which
included interviews with site personnel, and sampling
of selected groundwater monitoring wells; and
0 Subsequent analysis of groundwater sampling results.
Records and documents from EPA Region VI and DEQ offices, compiled
by an EPA contractor, were reviewed prior to the onsite inspection.
Onsite facility records were reviewed to verify information currently
in government files and to supplement this information where necessary.
Selected documents requiring in-depth evaluation were copied by the
Task Force during the inspection. Records were reviewed to include
evaluation of facility operations, construction of waste management
units, and ground-water monitoring activities.
Specific documents and records reviewed and evaluated included the
ground-water sampling and analysis plan, analytical results from past
groundwater sampling, monitoring well construction data and logs,
site geologic reports, site operations plans, facility permits, unit
design and operation reports, and operating records showing the general
types and quantities of wastes disposed at the facility.
-11-
-------
The facility inspection included identification of waste management
units, identification and assessment of waste management operations and
related practices for ground-water protection, and verification of
location of groundwater monitoring wells and leachate collection/detection
systems.
Company representatives were interviewed to answer questions,
identify records and documents of interest and to discuss facility
operations (past and present). The principal facility contacts were
Mr. William Kitto, General Manager, and Mr. Kenneth Anderson, District
Engineer. Topics discussed during the interviews included, (1) waste
disposal practices, (2) site hydrogeology, (3) groundwater monitoring
system rationale, (4) the groundwater sampling and analysis plan,
(including sample handling and document control) and (5) laboratory
procedures for obtaining data on groundwater quality.
An in depth evaluation of the contract laboratory used by CWM (ETC
Laboratories of Edison, New Jersey) was conducted by the EPA National
Enforcement Investigations Center (NEIC) for an other Task Force evaluation.
Therefore, the Task Force evaluation for CWM did not include an
evaluation of this laboratory.
During the onsite inspection, the Task Force collected ground-
water samples from selected ground-water monitoring wells and from
landfill leachate detection and pressure relief systems. All samples
were taken by an EPA contractor (VERSAR) and sent to EPA contract
laboratories for analysis. (See: "Task Force Sample Collection and
Handling Procedures"). Data from sampling analysis were then reviewed
for the presence of hazardous waste constituents. (See: "Task Force
Monitoring Data Analyses For Indications Of Waste Release").
The procedures used by the Task Force followed the EPA "Hazardous
Waste Groundwater Task Force Protocol for Groundwater Evaluations"
(1986), and the EPA "RCRA Groundwater Monitoring Technical Enforcement
Guidance Document" (1986). These procedures included the use of individual
log books to record information obtained in the field and information
with site personnel. No photographs were taken by the Task Force during
the inspection.
-12-
-------
Due to interest shown by local citizens, and as part of a public
information program, an informal presentation was made by the Task
Force at Carlyss High School on April 22, 1987, regarding the general
objectives and activities of the Task Force at CWM. Also, at the
request of local media (Channel 7 News), a brief on-camera interview
was given on April 24, 1987.
-13-
-------
HAZARDOUS WASTE MANAGEMENT UNITS AND OPERATIONS
This section focuses on the facility's hazardous waste management .
units which are subject to the RCRA groundwater monitoring requirements.
For an indepth discussion of all solid waste management units at the
facility, the reader is referred to the EPA "CWM RCRA Facility Assessment
Report" (September 1987).
Currently, three disposal units at the facility are subject to the
RCRA groundwater monitoring requirements. These are (1) an active
landfill cell designated as cell 14, (2) a closed (not RCRA closed) landfill
cell designated as cell 5, and (3) a closed (not RCRA closed) leachate
lagoon. All of these units are located west of John Brannon Road in a
160 acre waste mangement area which is surrounded by a 3-feet wide 40-
feet deep bentonite slurry wall which serves to reduce lateral hydraulic
communication. Also in this area is landfill cell 6 which is currently
under construction, and proposed landfill cell 7 which will he subject
to RCRA groundwater monitoring requirements when activated.
A map depicting all solid waste management units at the facility
is shown in Figure 2.
Table 1 is a generalized listing of waste types landfilled at CWM.
Landfill Cell 14
Landfill cell 14 is located in the northwest corner of the waste
management area. It is the only active disposal cell at the site. The
cell contains 3 modules - modules 1 (1A and IB),, 2, and 3 and occupies
an area of approximately 600x900 feet. Modules 1 and 2 were constructed
in 1985, and received wastes until 1986 when module 3 was completed and
began operations.
According to the facility, each module is constructed to meet the
EPA minimum technology requirements currently in effect. This includes
a pressure relief system (which underlies the entire cell) two compacted
clay liners, two 60 mil HOPE synthetic liners, a leachate detection
system, and a leachate collection system. In order to minimize infiltration,
modules 1 and 2 have been capped with clay. After module 3 has been
filled to capacity (which may occur within one year) it will also he
capped with clay; then a final cap will he constructed over the entire cell.
-14-
-------
FIGURE 2 8WMU LOCATION MAP
SMI
II
It
11.11
}l
II
300 FEET
i j
lt«4MII Ctll «o. 14
linOill Ctll Ho. i
loimt' tlMIMI (fill lot. I.I.I
»0r««r Infill tilt •! IVMIftlMrlC »CU tl »l««r\
letilk locwr l»*«ttrm ••*•
llfOO*
l««lll|«lio* IllUl
mil HIM SlMIt
SiMI
ItickiU Mort«c l«»k I-M
8
,N»Oft 00*
II
II
Ik
ll.lt
loi«r SulUlllt«llo«
loidlit Ittlo I* ri
Inullx litUt So««k ol
Landfill cell 6
(under construction)
i
I
-------
TABLE 1
WASTES LAKDPILLED AT THE CVMI. LAKE CHARLES FACILITY*
Waste Stream
Basis for RCRA
Hazard Designation
Approximate
Annual Quant.
Kettle Bottoms
Stormwater Basin
Sludge
Electric Arc
Furnace Dust
Tank Bottoms
Contaminated
Dirt and Debris
Tank Bottoms
(MLE)
API Separator
Sludge
NPDES Sludge
DMP Tar
Contaminated Oil
Caprolactura**
Mixed organics**
EP Toxic, D006, D007
D002. Corrosive
Contaminated with one
or more of MCB. BDC,
DNT, TDI. TDA. Formalde-
hyde. DCHA, Toluene,
Ana line. D007, D008,
D009
Oil**
Olefinic and diolefinic
polymers, pyrolosis
gasoline and caustic**
3500 cub. yds.
2500 cub. yds.
2000 cub. yds.
2000 cub. yds.
1000 cub. yds.
1000 cub. yds.
1000 cub. yds.
D007, trace nitrobenzene. 150 cub. yds.
chlorobenzene, O-dichloro-
benzene. aniline, dinitro-
toluene, toluene and
diamine
Dimethyl formamide,
butadiene polymer,
vinyl cyclohexene
Heavy oils**
acids**
700 cub. yds.
500 cub. yds.
*Informal ion obtained from August 8, 19B5, CVMI Exposure
Assessment Report.
**No further detail provided in Exposure Assessment Report
-16-
-------
CWM reportedly maintains the leachate levels in the leachate
collection and detection systems below the Lower Pervious Zone, and
samples these systems on a quarterly basis for priority pollutants.
The underlying pressure relief system is in contact with all three
modules and serves to connect the Upper Pervious Zone and Lower Pervious
Zone. It is also sampled on a quarterly basis for priority pollutants.
(Selected construction diagrams for landfill cell 14 are presented in
Appendix 0).
As a result of sampling these systems, CWM has reported these
contaminants are either not present, or present at very low-levels in
the leachate detection and pressure relief systems. Contaminant levels
in the leachate collection systems have also been relatively low.
Leachate levels are maintained within one foot of the corresponding
liner by submersible stainless steel GRUNFOS® pumps which are dedicated
to each riser pipe (16 in all) in the system. According to CWM a
constant inward hydraulic gradient is exerted by the surrounding pervious
zones which necessitates continual pumping on the lower systems. Leachates
which accumulates in the collection systems is probably influenced more
by infiltration than by the inward gradient. [Note: the existence of
an inward gradient on the landfill cell may not necesarily prevent
dense phase contaminants from moving downward to the 60-Foot Sand if
the liners are breached.]
All leachate is pumped to intermediate storage tanks subsequent to
being pumped or hauled to the facility's onsite one million gallon
leachate storage tank. In all, up to several hundred gallons of leachate
may be produced from landfill cell 14 each day. Periodically, the
leachate is removed from the main storage tank and is transported offsite
for disposal (the leachate is usually deep-well injected at the CWM
Port Arthur, TX or Corpus Christi, TX, facilities).
Landfill Cell 5
Closed landfill cell 5 is located along the east boundary of the
waste management area. Its dimensions are approximately 300x1800 feet.
The landfill was operated from 1980 to 1985, and was also used for
treatment operations for wastes to be disposed.
-17-
-------
The cell consists of ten separately constructed, filled and covered
modules. The design and construction techniques utilized for cell 5
represent a continual upgrading of the landfill from the first modules,
at the north end of the cell, to the last modules at the south end of
the cell. Module 1 is 30 feet deep, and has a natural clay bottom and
a final clay cover four feet thick. Modules 2, 3, and 4 were excavated
to a depth of around 40 feet and are lined with three feet of compacted
clay. These modules also have leachate collection system, and a four
foot thick clay cover. Modules 5 through 10 were also excavated to a
depth of around forty feet, are lined with a three foot (or greater)
compacted clay liner, and have leachate collection and detection system,
and a four foot clay cover.
Until 1984, liquid wastes were also placed in cell 5 in a "moving"
solidification trench located just ahead of the modules in use. These
liquids were solidified with kiln dust or fly ash prior to being
landfilled.
An inward hydraulic gradient is also reported to exist at cell 5.
As previously mentioned, however, an inward gradient may not
necessarily prevent dense phase contaminants from moving downward to
the 60-Foot Sand if the liner is breached. Also, dense phase contaminants
that breach the liner at the north end of cell 5 could potentially
migrate downward to the Channel Sand depending on the Channel Sand
boundaries (see: SITE HYDROGEOLOGY). [If the Channel Sand underlies
the north end of cell 5, and deepens to the northeast, the potential
exists for dense phase contaminants to enter the Channel Sand and
migrate to the northeast (against groundwater flow).]
A total of one leachate detection and three leachate collection
risers are installed in landfill cell 5. The leachate operational
controls and handling procedures are the same as discussed for landfill
cell 14. In all, up to several hundred gallons of leachate may he
produced from landfill gallons of leachate may he produced from landfill
cell 5 each day.
-18-
-------
Lear.hate Lagoon
The former lear.hate lagoon, also referred to as the lear.hate pit,
and lear.hate storage pond was used to store lear.hate and contaminated
stormwater from the landfill areas. It was located in the northeast
corner of the waste management area (northwest of cell 5).
The lagoon was operational from 1979 to 1984 (when it was replaced by
the one million gallon lear.hate storage tank). It occupied an area of
approximately 150x150 feet and was excavated into natural clay to a depth
of around 10 feet. The sides and bottom were prepared with minimal compaction
(construction details were not available). Leachate was periodically
pumped from the lagoon and transported offsite for deep-well disposal.
The leachate lagoon was closed by pumping as much liquid as
practicable from it, and solidifying the residual sludge with cement
and fly ash. The solidifed material and approximately three feet of
native clay was then removed and disposed in landfill cell 5. The
areas was then graded to reduce the potential for ponding of rainwater.
According to the facility, certain heavy metals were detected in soils
samples taken from the bottom and sides of the lagoon at the time of closure.
In places, the concentrations of these metals may have exceeded background
levels by a factor of three. No priority pollutant organics or phenols
were detected in these soil samples. No other information concerning
any other potential contaminants in the native clay underlying the former
surface impoundment were available at the time this report was prepared.
[Also, as with landfill cell 5 the exact areal relationship of this
unit and the Channel Sand has not been established by the facility.]
Future Landfill ing Operations
CWM plans to begin utilizing landfill cell 6 for the disposal of
solidified hazardous wastes after construction on the first module is
completed and landfill cell 14 reaches capacity. This is expected to
occur during late 1987 or 1988.
Landfill cell 6 is located west of landfill cell 5, and will
roughly parallel its areal form. The construction of landfill cell 6,
however, will closely follow that utilized in landfill cell 14 to
satisfy the EPA minimum technology requirements for hazardous waste landfills.
-19-
-------
Eventually, CWM plans to utilize almost all of the area within the
160 acre waste management area for landfilling operations. This will
include the construction of landfill cell 7 to the west of landfill
cell 6 near the west slurry wall. Current CWM plans call for landfilling
operations to continue at the site for around 50 years.
Along with the addition of these landfills, CWM plans to greatly
expand its groundwater monitoring system. This includes the installation
of monitoring wells around the perimeter of each landfill cell on an
approximate spacing of 200 feet (See: GROUNDWATER MONITORING DURING
INTERIM STATUS).
Other Hazardous Waste Management Units
Other hazardous waste management units in the current waste
management area include the following:
1. Former landfill cells 1, 2, and 3 which were located in the
north portion of the current waste management area, and
were operational from 1979 to 1980 (wastes reported to have
been exhumed and placed in landfill tells 5, and 14 during
1984 and 1985);
2. Active, open-top sludge solidification tanks (2) which are
constructed of steel, and are sunk in the ground (these
tanks serve as mixing basins for wastes to be landfilled,
and have an underlying leak detection system);
3. An active one million gallon, steel leachate storage tank,
which began operations in 1984;
4. Other hazardous waste management units including a truck
weighing and sampling station, tank farms, and related
operations.
Prior to the implementation of RCRA (November 19, 1980) a landfarming
(land-treatment) operation was also conducted for the disposal of
hazardous waste. This operation, however, was conducted outside of the
current waste management area - east of John Brannon Road.
-20-
-------
Landfarnring
Landfarming (land application) of hazardous waste was begun by SRI
in 1975 and continued under CWM until November 1980 when the RCRA
regulations became effective. The former 60-acre landfarm is located
outside the current waste management area near the CWM site office.
The landfarm received wastes from oil refineries, rubber manufactures,
chemical plants, and wastewater treatment plants. These wastes consisted
largely of oily material and sludges.
Operational controls at the landfarm included a perimeter dike to
prevent runoff and runon, and variable application rates, which were
determined according to loading limitations. Also, disking was performed
to increase the efficiency of biological break-down of the waste
materials. These operations also included the use of sludge solidification
basins (excavated in native clay) for waste stabilization prior to
land application. All runoff from the landfarm, was diverted to holding
basins prior to batch discharge under an NPDES permit.
During closure of the landfarm, contaminated soils were redistributed
and graded to facilitate drainage. Also, vegetation was promoted to
reduce erosion.
"Non-Hazardous" Waste Management Units (Sanitary Landfill and Rainwater
Retention Pond)
Sanitary Landfill
The former sanitary landfill is located north of the former landfarm
area, of John Brannon Road, and occupies an area of approximately 15
acres. It was operated from 1975 to 1985 for the disposal of municipal
wastes.
According to the facility, wastes were placed at least 3 feet
above the groundwater table in clay-lined trenches. Underlying the
sanitary landfill a leachate collection system was installed (with four
risen pipes) to remove excess leachate on a periodic basis.
-21-
-------
Rainwater Retention Pond
In the southwest corner of the current 160 acre waste management
area is a rainwater retention pond which may cover several acres during
periods of heavy precipitation. This water is discharged from the
facility under a Federal surface water discharge permit (NPDES permit
no. LAD0054828) issued on August 8, 1984. [A total of 4 NPDES outfalls
are located throughout the facility which are regulated according to
this permit.]
Hazardous Waste Tracking Procedures
CWM checks all in-coming wastes and waste manifests prior to
acceptance for onsite disposal. Wastes accepted for disposal are then
tracked through specified waste handling procedures (which includes
solidification for all liquids) to final landfill disposal location (by
module, coordinates, and lift level). The tracking system procedure
documentation includes a receiving ticket, an electronic scale ticket,
a receiving checklist, an accounting of treatment procedures used (as
applicable), and a disposal ticket.
"Tagging" of Superfund Wastes
During the Task Force inspection, information concerning tracking
and disposal locations of Superfund wastes was requested from CWM. CWM
was able to locate this documentation for Superfund wastes that were
being received at the time of the inspection (from the Highlands Acid
Pits in Texas), but was not able to readily locate this information for
previously disposed Superfund wastes. This is because the facility
does not "earmark" wastes that are specifically from Superfund sites.
The Task Force recommended to the facility tha.t a file "tagging"
procedure be implemented so that information concerning the disposal of
Superfund wastes is more readily available.
-22-
-------
Potential Influence of Site Operations on Groundwater Quality
The potential impact of all solid waste management units (SWMUs)
on groundwater at the facility - inside and outside the current waste
management area - is discussed in the EPA "CWM RCRA Facility Assessment
Report" (September 1987). At the time of the Task Force inspection,
the facility reported that groundwater had not been impacted by the
operation of any of the SWMUs. Some monitoring wells, however, have
shown occasional low-level occurrences of phenol. The source of this
phenol has not been identified and, according to the facility, may be
naturally occurring. Also, the current downgradient RCRA monitoring
wells may not be capable of detecting contaminants in places due to their
locations (See: GROUNDWATER MONITORING DURING INTERIM STATUS).
Regulatory Background
Initial site operations (1975 to 1979) were approved and regulated
by the Louisiana Office of Health Services and Environmental Quality.
From August 1, 1979 to Novebmer 19, 1980, the facility operated under
the requirements of the Louisiana Hazardous Waste Management Plan
(HWMP). The State amended the HWMP on September 5, 1980 so that it was
compatible with EPA hazardous waste management regulations promulgated
on May 19, 1980. From November 19, 1980 to December 19, 1980, the
facility was subject to Louisiana interim status regulations contained
in the HWMP and EPA interim status regulations. On December 19, 1980,
Louisiana was authorized to administer and enforce the interim status
provisions of RCRA including applicable groundwater monitoring requirements
As of September 1987, the State had been authorized to Implement
the changes in the Federal Register up to and including those contained
in the March 20, 1984, publication.
A hazardous waste disposal permit (No. DT-507-P) was issued by the
Louisiana Environmental Control Commission (now the Louisiana Department
of Environmental Quality) to CWM on July 26, 1982. This State permit
is based on the Louisiana HWMP (as amended) and was in effect at the
time of the Task Force inspection. As discussed in the section entitled
"Site Background", the public hearings held during the permitting
process received attention from local media and citizens groups.
-23-
-------
The facility submitted a Part II (Part B) application to the Louisiana
Department of Environmental Quality on November 13, 1984. This application
was subsequently revised on February 15, 1985, and July 31, 1985. Also, in
response to HSWA, the facility submitted an "Exposure Information Report"
on August 8, 1985, and certified compliance with applicable groundwater
monitoring and financial assurance requirements on November 8, 1985. A
final determinatiion on the facility's permit application is expected
during 1988.
-24-
-------
SITE HYDROGEOLOGY
The CWM facility is located in the Gulf Coastal Plain physiographic
provence of southwestern Louisiana. The geology of this area is
characterized hy many thousands of feet of unconsolidated to semi consolidated
deltaic deposits of clay, silt, sand, and occasional gravel. These
deposits vary from tens to hundreds of feet in thickness and occur as
interfingering beds and lenses with occasional slump features. The
regional dip of these units is to the south, toward the Gulf of Mexico.
The site rests on unconsolidated deposits of Pleistocene age known
as the Prairie formation. This formation is characterized in order of
predominance hy clay, silt, and sand. These units are interlayered and
interfingering to a depth of approximately 200 feet to the top of the
Montgomery formation. No active faulting is reported in the immediate
vicinity of the site.
The Montgomery formation, also of Pleistocene age, extends from a
depth of approximately 200 to 500 feet heneath the site. This formation
represents the uppermost member of the regional Chicot Aquifer System,
and contains a thick sequence of sands (and lesser silts) at its top
known as the "200 Foot Sand".
Beneath the Montgomery formation are found, in order of increasing
depth the Bentley formation and Williana formation, which are also of
Pleistocene age. These formations contain the "500 Foot Sand", and
"700 Foot Sand" respectively which comprise the remainder of the Chicot
Aqnfer System. Each member of this aquifer system is separated from
the others hy sequences of clay and silt.
The Chicot Aquifer System is used locally to supply large quantities
of water for domestic and industrial usage. It is also used as a
source of irrigation water for croplands, and is a proposed Sole Source
Aquifer (as defined under the Safe Drinking Water Act).
The shallow subsurface in the landfill area is characterized by the
following generalized sequence of sedimentary layers: A clay layer
is found from the ground surface to a depth of approximately 10 feet.
From a depth of approximately 10 to 20 feet is found a zone of silt,
clay and minor fine sand which is referred to hy the facility as the "Upper
Pervious Zone". Another clay layer is found heneath the Upper Pervious
Zone at a depth interval of approximately 20 to 30 feet. From
-25-
-------
FIGURE 3
•UPPER PERVIOUS ZONE*
I SANDY AND CLAYEY SILTS
f OCCASIONAL CLAY AND
SAND LENSES
'LOWER PERVIOUS ZONE*
SANDY SILTS AND VERY FINE
GRAINED SANDS WITH
INTERLAYERED CLAY BEDS
THICK CLAY BEDS WHICH SEPARATE THE
DIFFERENT PERVIOUS ZONES.
*60 FOOT SAND*
FINE GRAINED. CLEAN SAND
PEAT - 1 TO 2 FOOT THICK ORGANIC LAYER
WOOD FRAGMENTS AND SHELLS ARE PRESENT
-100
LEGEND
[ [ VCNV FINE DRAINED SANOS
[•~'| INTERLAYERED SILTS CLAYS AND SANDS
|j^| CLAY- WITH MINOR SILT LENSES
PM PEAT LAYER
LAKE CHARLES FACILITY
CHEMICAL WASTE
MANAGEMENT INC.
Woodwnrd-Clyde Comullanls
NCTEO
•••I ••
(MfCItt
•/'?
Mil 2-t
••M- r-x
GENERALIZED STHATIGRAPHIC
COLUMN UPPER PRAIRIE
FORMATION-C.W.M.I. SITE
-------
approximately 30 to 40 feet is found another zone of silt, clay and
fine sand. This zone is referred to by the facility as the "Lower
Pervious Zone." Beneath the Lower Pervious Zone there exists yet
another clay layer which extends to approximately 60 feet deep.
The Upper Pervious Zone and Lower Pervious Zone are not capable of
producing water on a sustained basis and are not considered aquifers.
Wells in these zones generally go dry after yielding only a few gallons
of water (monitoring well B-5A, in the Upper Pervious Zone is frequently
dry and unable to yield any water). CWM has performed limited testing
of these zones and has estimated that insitu values of hydraulic conductivity
range from approximately IxlO"5 to 1x10 cm/sec, (oral communication).
The clay layers present to a depth of 60 feet are estimated by the
7 Q
facility to have permeabilities ranging from 1x10 cm/sec, to 1x10 cm/sec.
(these are laboratory estimates). These clay layers, however, contain
inter-bedded sand and silt seams, pockets, and partings, in addition to
slickensides and microfractures. These features almost certainly act
to increase the degree of hydraulic communication between the pervious
zones and the underlying zones.
At a depth of approximately 60 feet is a zone of fine sand which
is referred to by the facility as the "60-Foot Sand". This zone averages
about 5 feet in thickness and occasionally grades to silts and clay
in certain localized areas in the central portion of the site (e.g.,
west of landfill cell 5 at borehole B-603). This zone is capable of
producing more water than the overlying zones, and is the first pervious
zone which occurs below the bottom of the slurry wall and landfill
cells. Therefore, the facility has designated this zone as the uppermost
RCRA aquifer. Another pervious zone known as the "Channel Sand" is in
direct hydraulic communication with the 60-Foot Sand and also is considered
to be part of the uppermost aquifer.
The Channel Sand is an abandoned river channel consisting of fine
sand which is found in the northeast corner of the landfill area. The
exact extent of the Channel Sand has not been determined by the facility,
but it is known to encompass.the area north of landfill cell 5 up to
and beyond the slurry wall. It may extend beneath the north end of
landfill cell 5 and the former sanitary landfill. The Channel Sand
varies in thickness from approximately 10 to 30 feet and appears to
bridge the confining layer between the Lower Pervious Zone and 60-Foot
-27-
-------
Sand. Its depth interval therefore may range from approximately 35 to
65 feet.
Underlying the 60-Foot Sand and Channel Sand to a depth of
approximately 90 feet is a zone of clay with minor silt lenses. Within
this zone at a depth of approximately 75 feet is a peat layer which
averages one to two feet in thickness. Figure 3 depicts a generalized
stratigraphic sequence to a depth of approximately 100 feet (excluding
the Channel Sand).
The facility has not performed field aquifer testing on the 60-
Foot Sand or Channel Sand. However, CWM estimates that these zones have
hydraulic conductivity values of around 1x10 cm/sec, and flow rates
of around 3 feet per year (oral communication). Actual flow rates,
however, may be much higher and should be field-checked.
Based on water-level measurements CWM has determined that groundwater
flows to the southwest in the 60-Foot Sand and Channel Sand. A typical
gradient is approximately 6 feet per mile. Groundwater flow in the
Upper Pervious Zone and Lower Pervious Zone is variable and appears to
be affected by landfill construction activities and the presence of the .
slurry wall (which extends into the clay layer which separates the
Lower Pervious Zone and 60-Foot Sand).
In all, CWH has drilled and sampled over 77 borings to characterize
the subsurface at the site. This includes 14 boreholes that were
drilled to a depth of approximately 100 feet. Most boreholes, however,
do not penetrate the 60-Foot Sand or Channel Sand. Additional information
concerning shallow subsurface conditions has also been obtained from
exploratory test pits and landfill excavations.
Landfill excavations, which extend below the base of the Lower
Pervious Zone, require only occasional pumping to remove water that has
accumulated in low-lying collection areas. According to CWM, the Upper
Pervious Zone is typically moist and the Lower Pervious Zone is typically
damp to seeping in these excavations. The amount of inflow from these
zones has undoubtedly been curtailed by the presence of the slurry wall
which reduces lateral hydraulic communication.
As landfill construction operations continue, the hydrogeologic
conditions of the Upper Pervious Zone and Lower Pervious Zone will
-28-
-------
r.hange. Groundwater flow in these zones will undoubtedly move toward open
excavations, and the overall influence of these zones on the site's
hydrogeologic regime will deminish as these zones are removed by excavation.
Generally, an inward gradient across the slurry wall exists in these zones
(as shown hy piezometric data from monitoring wells on opposite sides of the
slurry wall). This may he reversed, however, where ponding of surface
water or high rates of infiltration occur.
The CWM facility is located on a natural drainage divide for
surface water discharges. This divide roughly parallels John Brannon
Road and causes surface water to drain to the east and southeast in the
area of the former sanitary landfill, and to the west or south in most
other areas of the site. Eventually, all runoff from the facility enters
the nearby Bayou Choupique which is located within 1/2 mile of the west
side of the facility and 1 mile of the south side of the facility (and
flows toward the Gulf).
Task Force Recommendations For Additional Site Characterization
1. The facility should conduct field aquifer testing of the 60-Foot
Sand and Channel Sand to determine actual insitu hydraulic
conductivity values and flow rates.
2. The facility should further delineate the extent of the Channel
Sand. This should include additional drilling and sampling
of boreholes to a depth of at least 70 feet in the following
locations:
(a) along the north perimeter of landfill cell 5;
(h) near the southwest portion of the inactive sanitary
landfill, northeast of facility monitoring wells
MW-1, MW-2A, and B-4; and
(c) near the former leachate lagoon.
3. The facility should drill and sample borings into the top
of the Chi cot Aquifer to obtain information on the degree of
interconnection of this aquifer with the overlying pervious
zones (including the Channel Sand and 60-Foot Sand).
4. The facility should determine infiltration rates inside the slurry
wall around existing and proposed landfills.
-29-
-------
GROUNDWATER MONITORING DURING INTERIM STATUS
GENERAL
The current groundwater monitoring program at the CWM facility
consists of 31 active monitoring wells (of which, six are RCRA wells).
Of this total, 7 monitoring wells are located east of John Brannon Road
around the perimeter of the former sanitary landfill and landfarming
operations (non-RCRA units) and 24 monitoring wells are located west of
John Brannon Road around the perimeter of the current waste management
area. The facility uses these wells to obtain groundwater samples and
water-level measurements from the Upper Pervious Zone, Lower Pervious
Zone, 60-Foot Sand, and Channel Sand. The locations of these wells is
shown in Figure 4. Seventeen other monitoring wells were formerly used
by the facility hut have been plugged and abandoned due to damage or
inefficient operation. Six RCRA monitoring wells are used to monitor the
uppermost RCRA aquifer (the 60-Foot Sand and Channel Sand) at the facility.
These wells are designated as MW-1 and B-4 (upgradient), and MW-2A, D-1B,
E-3, and D-2A (downgradient), and are located along the slurry wall (west
of John Brannon Road). Monitoring well MW-2A is upgradient, of the RCRA
units, hut the facility has designated it as a downgradient well due to
the fact that it is located downgradient of the former landfarm. Monitoring
wells MW-1 and B-2 are used as background wells against which RCRA
statistical comparisons are made for MW-2A, D-1B, E-3, and D-2A on a
quarterly basis. Selected facility water level data is shown in Figure 5.
The facility utilizes the Cochran's Approximation of the Behrens-
Fisher (CABF) Student's t-test at the 0.05 level of significance for
performing statistical comparisons of RCRA indicator parameters.
For comparative purposes, the facility also calculates sampling results
using the Average Replicate (AR) Student's t-test.
The facility began collecting RCRA background data on monitoring
wells beginning in 1982. Due to CWM dissatisfaction with results,
background data was again obtained during 1983. During the first three
quarters of 1984, the facility applied statistical test to all wells.
This resulted in frequent triggerring of the RCRA indicator parameters.
Beginning with the fourth quarter of 1984, the facility has applied
statistical comparison only to monitoring wells penetrating the uppermost
-30-
-------
L
U22O
M ur*m
• io«* mtwow
O w VM«
^ OOMNO. IAM>
ZOMC
i
800 400
_| I
SCALE IN
•Mxxtward-Oyde Consultants
Figure 4
NOTED
1087 ANNUAL REPOR1
LAKE CHARLES FACILI
•*">• EXISTINU FACILITY
OROUNOWATER
NETWORK
-------
I
u>
N)
I
LEGEND
MW- I
MW-2
MW
Q
A
0-18(5-13-84)*
O 02
D-2A(5-3I 83)
A F.-J
K 8-4
• New Well Installed (dale)
I960
1981
1982
I98J
198-1
1985
1986
Figure 5
1S| 1986 ANMII/VL
L«KE CHflRLES FACILITY
CHEMICAL WAS IE
MANAGEMENT, INC.
Oyite Const'Unla
Kit! |<**of ••
NOT to
GBOUNOWATEH LEVEL DATA
CHANNEL SAND/GO FT SAND
-------
aquifer. This however, has not eliminated the triggering of certain
RCRA indicator parameters during each subsequent quarter. The facility's
procedure is to sample all monitoring wells for RCRA indicator parameters
and groundwater quality (including non-RCRA wells) quarterly regardless
of statistical results. Also, a priority pollutant scan is run on
selected wells (including MW-2A, D-1B, and D-2A) on an annual basis.
This includes a priority pollutant scan on all wells that have triggered
the RCRA indicator parameters.
In addition to performing the required analyses, CWM performed
trend analyses of facility - specific indicator parameters, benzene, phenol,
cyanide, lead, and chromium on all wells from the fourth quarter of
1984 until the first quarter of 1987. These facility indicator parameters
are intended to he representative of waste types received at the facility.
Results of these analyses indicate that these constituents were present
at very low concentrations, or were present at levels below the minimum
detection limit.
Beginning with the first quarter of 1987, the facility proposes to
utilize a Tolerance Interval Test for volatile organics, chromium,
cyanide, lead and total phenolics. The facility goal is the eventual
replacement of the Student's t-test and RCRA indicator parameters with
the Tolerance Interval Test and these facility-specific parameters.
As a result of its sampling program, the facility has determined
that groundwater contamination has not occurred at the site. Therefore,
despite triggerring RCRA indicator parameters, the facility considers
itself to he in a detection monitoring program. Clearly, this approach
does not follow the letter of existing regulations.
The facility has reported the results of its quarterly sampling
events to the State but has not performed the following procedures
under 40 CFR §265.93:
1) Resampling does not appear to be performed immediately after
triggering the RCRA indicator parameters; instead, the facility
samples quarterly regardless of statistical results.
2) The State does not appear to he notified within the prescribed
time-frame (7 days) when significant variations in the indicator
parameters are verified; instead, the facility submits quarterly
sampling reports.
-33-
-------
3) The facility has not submitted a certified groundwater quality
assessment plan to the State.
The facility explains its approach for detecting groundwater
contamination at the site by the following arguments:
1) The facility does not feel that the RCRA indicator parameters
and required statistical comparisons are valid for determing
if groundwater contamination has occurred. The facility
contends that natural conditions in the Gulf Coastal Plain
precludes the effective use of this approach.
2) The facility has proposed and is utilizing site - specific
parameters for detecting groundwater contamination.
3) The facility has proposed and is utilizing statistical tests
to determine if contamination has occurred.
4) The facility samples its monitoring wells quarterly. This is
more often than required by regulation.
5) The facility contends that no significant levels of contamination
or indications of contamination have been observed from sampling
results including priority pollutant analyses.
In a letter dated May 13, 1986, to Mr. Lee Thomas, Administrator of
EPA, CVIM submitted a petition for modification of 40 CFR §264 and §265
regarding existing requirements for indicator parameters, statistical
procedures, and Appendix VIII testing requirements. This petition
includes the following provisions:
1) Increased flexibility for the use of alternative statistical
procedures including Tolerance Interval Tests;
2) Replacement of current RCRA indicator parameters with selected
volatile organic constituents;
3) Reduction in the number of contaminants to be sampled if an
assessment monitoring program is triggered to include only
contaminants which are likely to occur; and implementation
of a tiered testing system which triggers further testing if
-34-
-------
specific pollutants are discovered hy the initial tests. The facility's
proposal (without attachments) is given in Appendix C.
Facility trend analyses indicate occasional low-level "hits" of
phenol in all RCRA monitoring wells. These occurrences of phenol seem
to he randomly occurring and are usually at levels around the detection
limit. The highest levels of phenol are seen in monitoring well MW-2A
at concentrations ranging from approximatley 0.01 mg/1 to 0.03 mg/1.
Also as presented hy facility trend analyses, monitoring well D-1B
has shown an increase of specific conductivity from around 1000
micromhos/cm in 1984 to around 3000 micromhos/cm in 1987. The facility
contends that this increase in specific conductivity is due to natural
conditions.
Results of facility annual priority pollutant analyses on selected
wells (including D-1B) has not indicated the presence of contaminants
at significant levels. Usually, priority pollutants are either not
detected or are detected at very low levels (e.g. around the detection
limit). Methylene Chloride has heen detected at levels above the detection
limit, however this may he due to laboratory interference.
Well Construction
Monitoring wells are constructed of schedule 40 or 80 PVC casing with
an inside diameter of 3 or 4 inches. Well depths generally range from
15 to 25 feet for wells in the Upper Pervious Zone, 35 to 40 feet for
wells in the Lower Pervious Zone, and 75 to 85 feet for wells in the 60
Foot Sand/Channel Sand. Monitoring well B-4 is an exception to this
generalization on that it appears to he located at the top of the
Channel Sand at a depth of around 38 feet (it may also he in close
hydraulic communication with the Lower Pervious Zone).
Each well is surrounded hy a 6 or 8 inch steel protective casing
with locking cap. This casing is set in concrete several feet helow
ground level and usually extends to around 30 inches ahove ground level.
A concrete apron surrounds each well at the surface.
Wells were drilled using either auger or rotary wash techniques.
The boreholes were generally 6 to 8 inches in diameter in order to
-35-
-------
TABLE 2
ACTIVE GROUNDWATER MONITORING WELL NETWORK
CWMI - LAKE CHARLES, LA
Well //
MW01
MW08
MW09
MWIO
B01
B03A
B05A
B06
B07
BOS
EOI
MW03A
MW05A
MW06
MW07
MW1IA
MWI2B
MWI3A
MWI1A
B02
B09A
BIO
COIA
C02B
E02
MWOI//
MW02A//
B01*«
DOIB
D02A
E03
Northing
8665.73
8671.06
7595.84
6213.53
6061.38
6060.95
8669.88
6116.73
7360.12
9982.1<»
8015.17
8671.10
6579.32
6081.88
6836.31
6556.07
6151.11
6816.13
8601.92
6058.21
7298.78
9981.28
7711.89
7739.00
8065.93
8670.27
8121.11
8651.15
6062.26
7190.58
6170.23
Easting
9873.39
8617.56
9959.63
7503.62
11311.58
10068.80
7369.93
7657.98
11317.12
10312.31
9519.06
7820.08
9967.70
8667.31
7357.52
9891.79
8676.15
7135.12
7830.68
11311.56
10051.99
10350.19
9960.23
9878.00
9526.20
9311.29
9959.39
9928.88
9361.30
7361.69
7573.02
Ground
Elev. «
8.0
8.6
8.1
9.1
1.1
6.2
6.9
9.5
5.7
8.5
10.3
8.3
7.3
8.0
7.1
11.8
13.8
10.8
9.3
1.5
6.7
8.6
9.3
15.3
10.6
9.1
9.3
8.3
7.6
7.5
9.3
Casing
Elev.«%
10.65
11.08
10.00
11.52
6.25
8.03
9.27
10.58
8.10
10.16
12.31
10.09
9.19
10.08
9.73
15.81
15.18
13.00
9.83
6.83
8.70
10.06
10.18
18.58
13.39
11.81
11.16
10.08
9.38
8.77
10.02
* Feet (MLS)
% Top
6 Top
of casing at
of casing to
saw mark
bottom of screen
Total
Depth*
33.5
20.0
20.0
20.0
11.0
18.0
19.0
16.0
16.0
16.0
22.0
31.0
36.5
39.5
38.5
39.0
50.0
35.0
33.0
25.0
58.0
21.0
35.0
15.0
30.0
81.0
83.0
38.0
80.0
75.0
77.0
// Wells
two
Well
Depth
20.7
19.7
19.7
19.1
15.8
17.2
20.1
15.1
18.1
18.0
21.5
31.0
38.0
39.3
37.2
12.6
18.0
35.0
31.7
25.1
57.1
25.5
31.9
15.3
30.6
81.7
85.2
37.8
79. 1
76.1
78.3
Casing
Size
3 in.
3 in.
3 in.
3 in.
3 in.
1 in.
1 in.
3 in.
3 in.
3 in.
1 in.
1 in.
1 in.
3 in.
3 in.
1 in.
1 in.
1 in.
1 in.
3 in.
1 in.
3 in.
1 in.
2 in.
1 in.
3 in.
1 in.
3 in.
1 in.
1 in.
1 in.
to be removed and
Top of Bottom of
Screen*
-5.0
-3.6
-1.7
-2.6
-1.5
-1.2
-1.2
0.5
-5.3
-2.5
-I.I
-18.9
-18.8
-21.2
-22.5
-21.8
-27.5
-17.0
-19.9
-11.6
-38.1
-10.1
-11.1
-16.7
-15.2
-32.9
-31.0
-22.7
-60.0
-63.0
-58.3
replaced with
Screen*
-10.0
-8.6
-9.7
-7.6
-9.5
-9.2
-11.2
-1.5
-10.3
-7.5
-9.1
-23.9
-28.8
-29.2
-27.5
-26.8
-32.5
-22.0
-21.9
-18.6
-18.1
-15.1
-21.1
-26.7
-17.2
-72.9
-71.0
-27.7
-70.0
-68.0
-68.3
^Ground
Screen
Total
5.0
5.0
5.0
5.0
5.0
5.0
10.0
5.0
5.0
5.0
8.0
5.0
10.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
10.0
5.0
10.0
10.0
2.0
10.0
10.0
5.0
10.0
5.0
10.0
surface to
wells each with shorter screens
* * Well scheduled
Unit
UPZ
UPZ
UPZ
UPZ
UPZ
UPZ
UPZ
UPZ
UPZ
UPZ
UPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
LPZ
Channe 1
Channel
Channel
60' Sand
60' Sand
60' Sand
bottom of boring
for removal and replacement
-------
accomodate the PVC rasing to he used and to provide for sufficient
annular spare to allow efficient placement of rement (hy tremie pipe)
in the wellhore - casing annulus.
PVC srreen with no. 10 or no. 12 slot size against a sand hackfill
was used in all wells in the zone to he monitored. Ahove the sand hackfill
(which is always ahove the top of the srreen hy at least 1 foot), a
hentonite pellet seal several feet thirk was normally implared prior to
sealing the casing-wellhore annulus to the surface with a portland
cement/ hentonite grout. No hentonite seal was placed in monitoring
well E-3 prior to the implacement of cement.
Generally, screen lengths are around 5 feet in length. Screen
lengths of around 35 feet in length are present in monitoring wells MW-1
and MW-2A.
Some wells, such as D-2A, E-3, and MW-2A are constructed with an
additional few feet of casing helow the screen. This feature is intended
to serve as a sediment trap.
A total of 18 monitoring wells were constructed with glued joints.
These wells are designated as MW-1, MW-4, MW-6, MW-7, MW-8, MW-9, MW-
10, B-l, B-2, B-4, B-6, B-7, B-8, B-9, B-10, E-l, and E-3. All other
wells were reported to he constructed with flush threaded joints.
Well construction diagrams for all RCRA wells are shown in Appendix
B. These diagrams were prepared hy a facility contractor and depict
general well construction and suhsurface features. Tahle 2 provides
selected information on all facility monitoring wells.
All monitoring wells are equipped with WELL WIZARD® air-actuated
hladder pumps. Some monitoring wells contain more that one pump
(including MW-1, MW-2A, 0-2A, and E-3). These pumps are operated using
portahle automatic controller/driver units. The WELL WIZARD® pumps are
dedicated to each well and are used for purging and sampling.
Groundwater Sampling Procedures
The facility's groundwater monitoring activities are detailed in a
two part document entitled "Groundwater Program Information". The
first part of the document, Part A, is entitled "Waste Management, Inc.
-37-
-------
Groundwater Monitoring Program" (1983, 1985, 1986, 1987). This
part contains (1) general information regarding groundwater monitoring
activities for Waste Management, Inc. (WMI) facilities nationwide, (2)
a copy write WMI document entitiled "Manual for Groundwater Sampling"
(1985), and (3) the facility's outline of a groundwater quality assessment
program.
Part B of the "Groundwater Program Information" document contains
a groundwater monitoring plan entitled "Site Specific Monitoring For The
Lake Charles, Louisiana Facility" (1985). This document contains site
specific data including information on site hydrogeology, monitoring wells,
sampling parameters, and schedules. It also contains the petition
(with attachments) that CWM submitted to EPA on May 13, 1986 regarding
modification of RCRA requirements concerning indicator parameters,
statistical methods, and Appendix VIII testing (for plume delineation).
The CWM groundwater sampling protocol is outlined helow:
0 Dedicated WELL WIZARD® pumps are used in all wells;
0 Wells are pumped prior to sample collection to purge at least three
well volumes of water (wells are usually purged one day and sampled
the next);
0 Purging time is calculated based on flow rates;
0 Purge volumes are generally obtained from well construction details,
and water-level measurements (total well depth is checked annually);
0 Purged water is disposed on the ground;
0 Water-level measurements are made using a slope indicator;
0 Samples are collected in order of decreasing volatility using
EPA recommended containers and preservations;
0 Samples for dissolved metals are filtered in the field using an
8-micron MICROPORE® filter;
0 Specific conductance, pH, and temperature are measured in the field
using a CAMBRIDGE® combined pH, specific conductance, temperature probe;
0 Samples are packed in ice in insulated shuttles (provided
by the facility's contract laboratory) along with appropriate
chain-of-custody forms and shipped offsite for analysis;
-38-
-------
0 Non-dedirated equipment including the CAMBRIDGE® prohe and MICROPORE®
filter are cleaned with deionized water between wells;
0 Three field and equipment blanks are prepared for each full round of
of sampling;
0 The facility currently utilizes Environmental Testing and Certification
(ETC) laboratories of Edison, New Jersey for all groundwater sampling
analyses.
CWM utilizes a trained two-man crew, which is supervised by the
District Engineer, for all groundwater sampling procedures. In order
to verify that CWM followed its sampling protocol, the Task Force requested
that CWM perform a mock sampling event (since an actual facility sampling
event was not scheduled to occur for several weeks). CWM demonstrated to
the Task Force that it followed its sampling protocol, and the
applicable regulatory requirements in a mock sampling event held in the
field at monitoring wells D-1B and MW-11A on April 23, 1987.
Additional Groundwater Monitoring
In addition to monitoring wells, CWM utilizes a landfill pressure
relief system to monitor for indications of groundwater contamination
at cell 14. The pressure relief system is located beneath the landfill
leachate detection systems and is in contact with the Upper Pervious
Zone and Lower Pervious Zone. Contaminants migrating from the landfill
cells would pass into the pressure relief system prior to entering the
natural subsurface environment. The facility obtains samples on a
quarterly basis from riser pipes which access this system.
As a result of priority pollutant scans of groundwater samples
taken from the pressure relief system, the facility has indicated that
no significant levels of contaminants have been detected beneath
landfill cell 14. Due to the effects of dilution and degassing (from
the submersible pumps), however, it is conceivable that not all
contaminants would he detected in this system.
-39-
-------
Effectiveness of Current Groundwater Monitoring System
The current groundwater monitoring system consists of a number of
monitoring wells in the Upper Pervious Zone, Lower Pervious Zone, 60-
Foot Sand, and Channel Sand which are located in and around the current
waste management area. Many of these monitoring wells, however, may
not he located in areas where contaminants would he immediately
detected. For example, monitoring well E-3, a downgradient RCRA
monitoring well, is located over 1000 feet from landfill cell 5 and the
former leachate lagoon. Also, monitoring well D-2A, another downgradient
RCRA monitoring well, is located over 500 feet from the northwest corner of
landfill cell 14, and may not he capahle of detecting any potential
contamination from that area. In order to increase the effectiveness
of the current groundwater monitoring system, therefore, additional wells
should he installed in the uppermost aquifer immediately downgradient
of the landfill cells and former leachate lagoon.
Also, the effectiveness of the current groundwater monitoring
system cannot he fully assessed until the full extent of the Channel
Sand is known. For example, if the Channel Sand underlies the north
end of landfill cell 5 and the former leachate lagoon, the potential
exists for dense phase contaminants to enter this zone and move toward
upgradient monitoring wells.
Task Force Recommendations
1. The facility plans to enhance its existing groundwater monitoring
system hy installing a significant numher of additional wells
in the 60 Foot Sand (see section entitled "Groundwater Monitoring
Program Proposed for Final Permit"). This should he accomplished
as soon as possible, and should include increased coverage of
the 60 Foot Sand immediately downgradient of landfill cells 5
and 14. Specifically, these additional wells should he installed
along the south and west perimeters of the landfills, as shown
in Figure 6.
2. The facility should follow the existing requirements for groundwater
quality assessment under 40 CFR §265.93. This should include
the suhmittal of a certified groundwater quality assessment plan.
-40-
-------
This plan should include provisions for sampling all RCRA monitoring
wells for priority pollutants, RCRA indicator parameters, and
facility indicator parameters.
The facility should further delineate the extent of the Channel
Sand. This should include drilling and sampling deep boreholes
in (a) the southwest area of the inactive sanitary landfill, and
(b) the area near the north end of landfill cell 5 (see section
entitled "Site Hydrogeology"). Based on the results of this
investigation additional monitoring wells should probably be
installed in the Channel Sand, especially near the north end of
landfill cell 5 and the former leachate lagoon. The primary focus
of these wells should be to monitor for dense phase contaminants.
For all newly constructed wells, the facility should ensure that
well screens are no more than ten feet in length, and that glued
joints are not used. Also, the facility should consider using
EPA-recommended well casing materials such as TEFLON® or stainless
steel instead of PVC.
Priority pollutant scans should probably be run semiannually
on all wells that trigger RCRA indicator parameters.
The facility should run an initial priority pollutant scan on all
newly installed monitoring wells to further verify the CWM position
that groundwater contamination has not occurred at the site.
The facility should continue to monitor the landfill pressure
relief systems for the presence of contaminants, and should attempt
to minimize the effects of degassing on all leachate samples.
The facility should ensure that leachate levels in the facility
landfill leachate collection and detection systems are maintained
below the Lower Pervious Zone.
The facility should minimize ponding of surface water and infiltration
within the confines of the slurry wall to minimize hydraulic
head levels. If possible, the head within the slurry wall
should be maintained at a level less than the head outside the
slurry wall so that an inward gradient exists. This will help
to ensure that any contaminants that might enter these zones will
not cross the slurry wall.
-41-
-------
r
L
LEGEND
Proposed Phase I Well
Additional Proposed
Phase I Well
Proposed Phase II Well
To Be Constructed
Under Phase I
Existing Wei 1
Note: All proposed wells
are to he constructed
in the 60-Foot Sand
or |Channel Sand.
400
SCALE IN
Figure 6
(Modified By EPA)
Woodward Cfyd« Consultants
MOTtO
l»ni ANNUAL ntPOOT
IAI.I CHAHHS »ACUI1J*
PROPOSED MONITORING
Nf 1WORH AfltH PM»St I
Will INS1AI I A1IONS
?6
-------
10. The facility should measure total well depths at least annually
on all monitoring wells to ensure that excessive siltation is not
occurri ng.
11. The facility should continue to use existing monitoring wells in the
Lower Pervious Zone (and may continue to use existing monitoring wells.
in the Upper Pervious Zone) for supplemental monitoring (for non-
statistical comparisons) above the uppermost aquifer.
12. The facility should use a 0.45 - micron membrane filter for dissolved
metals analysis.
-43-
-------
GROUNDWATER MONITORING PROGRAM PROPOSED FOR FINAL PERMIT
CWM has proposed to enhance its existing groundwater monitoring
system by installing a number of additional monitoring wells in the
60-Foot Sand and Channel Sand. These wells are planned to he located
primarily along the downgradient perimeter of each landfill cell on a
spacing of approximately 200 feet. The point of compliance is proposed
to he represented hy the line of these wells around each individual
landfill cell. The locations of these proposed wells is shown in Figure
6.
Also, the facility has proposed to discontinue the use of the
monitoring wells in the Upper Pervious Zone. The facility bases this
proposal on the following arguments:
1. The Upper Pervious Zone (and Lower Pervious Zone) is not an
aquifer; it does not have any likely potential for water use.
2. The Upper Pervious Zone (and Lower Pervious Zone) will he largely
removed during landfill excavation.
3. The bottom of the landfill cells is below the Upper Pervious Zone
(and Lower Pervious Zone)..
4. The leachate levels in the landfill leachate collection, and
detection systems are planned to he maintained below the Upper
Pervious Zone (and Lower Pervious Zone).
5. The facility plans to continue monitoring the pressure relief
systems of all landfill cells for contaminants. This system
underlies the leachate detection system and may serve to indicate
if contaminants are migrating from the landfill cells.
CWM plans to continue monitoring the Lower Pervious Zone with
existing monitoring wells. These wells are intended to provide for
supplemental monitoring above the uppermost aquifer, and will not he
used for making statistical comparisions.
All monitoring wells are proposed to be sampled on a quarterly
basis for the following facility indicators: volatile organic
constituents, cyanide, lead, chromium, and total phenolics. These
indicators were selected hy the facility primarily because of their
-44-
-------
quantity in wastes disposed, and their mobility in the groundwater
envi ronment.
In order to determine if statistically significant increases in
facility indicator parameters have occurred, CWM proposes to use a
Tolerance Interval test as referenced in Appendix C. If significant
increases in the indicator parameters are ohserved using the Tolerance
Interval test, CWM proposes to expand the number of parameters for
which it samples up to and including all the priority pollutants until
the exact nature of any contamination is verified. This tiered approach,
CWM feels, will allow for the identification of contamination in the
groundwater, and will avoid unnecessary and expensive analysis.
All contaminant concentration levels are proposed to he set at
background levels as the facility contends that no groundwater
contamination has occurred. The groundwater protection standard,
therefore, would he at the detection limit for most of the priority
pollutants.
Task Force Recommendations
1. The facility should complete installation of all proposed
60-Foot Sand and Channel Sand monitoring wells prior to
final permit determination. This should include the installation
of monitoring wells in the 60-Foot Sand along the south and west
perimeters of landfill cells 5 and 14 as shown in Figure 6.
2. The facility should complete initial priority pollutant scans on
all monitoring wells prior to final permit determination.
3. The facility should install monitoring wells in the Channel
Sand or 60-Foot Sand along the north perimeter of landfill
cell 5, and near the former leachate lagoon. The primary
focus of these wells should he to monitor for dense phase
contaminants. In no case should screen lengths he greater than
10 feet in length.
4. The facility should install at least one monitoring well in the
60-Foot Sand on the east side of landfill cell 5 near existing
monitoring well MW-11A.
-45-
-------
5. The facility should increase the number of proposed facility
indicator parameters. The currently proposed indicator parameters
(VOCs, cyanide, lead chromium, and total phenolics), may not
provide sufficient indication of contamination. For example, the
facility should continue to use pH as an indicator parameter since
it handles low pH wastes. Also, the facility should continue to
monitor trends of specific conductance since substantial increases
in the RCRA indicator parameter have been observed (especially
in monitoring well D-1B).
6. The facility should provide further justification for its proposed
statistical procedures. The burden of proof lies with the facility
that its proposed procedures will minimize false negative results
while reducing false positive results.
7. If indicator parameters are triggered, the facility should resample
and perform additional analyses, if necessary, immediately (in
addition to fulfilling other applicable requirements).
8. The facility should ensure that leachate levels in the landfill
leachate collection and detection systems are maintained below
the bottom of the Lower Pervous Zone. If leachate levels rise
to the Lower Pervious Zone (or higher) additional monitoring of
this zone should be implemented.
9. The facility should continue to monitor the landfill pressure
relief system of landfill cell 14 (and future landfills) for indications
of contamination.
10. The facility should prevent ponding of surface water and reduce
infiltration as much as possible within the confines of the
slurry wall to minimize hydraulic head levels. This effort
should be designed to yield a constant inward gradient across the
slurry wall. This will help to ensure that any contaminants that
might enter the Upper Pervious Zone or Lower Pervious Zone will
not cross the slurry wall.
-46-
-------
11. The facility should install additional upgradient monitoring wells
in the 60-Foot Sand and Channel Sand along the north boundary
of the current waste management area (along the point of compliance)
12. The facility should utilize TEFLON® or stainless steel for
well casing and well screen materials in all new monitoring
wells, or provide justification for not using these
materials. Generally EPA does not recommend the use of PVC
for monitoring well construction as it may affect analytical
results.
13. The facility should measure the total depth of each monitoring
well at least annually to ensure that excessive siltation is
not occurring.
14. The facility should continue to use existing monitoring wells
in the Lower Pervious Zone for supplemental monitoring (for
non-statistical comparisons) ahove the uppermost aquifer.
-47-
-------
TASK FORCE SAMPLE COLLECTION AND HANDLING PROCEDURES
All Task Force sample collection and handling procedures followed the
procedures recommended in the EPA "Hazardous Waste Ground Water Task Force
Protocol For Ground-Water Evaluations" (September 1986), and the EPA "RCRA Ground-
Water Monitoring Technical Enforcement Guidance Document" (September 1986).
These procedures were performed by an EPA Contractor (VERSAR, Inc. of
Springfield, Virginia) with EPA oversight, and are discussed below.
A total of 18 facility monitoring wells were sampled by the Task Force
for hazardous waste constituents: MW-1, MW-2A, B-4, 0-1B, D-2A, E-3, MW-3A,
MW-11A, MW-14A, C-1A, MW-4, MW-8, E2, E-l, MW-13A, MW-7, C-2B, MW-9. These
wells are all located west of John Brannon Road, in and around the current
waste management area. As shown above, all wells penetrating the 60-Foot
Sand and Channel Sand (the facility designated uppermost RCRA aquifer) were
sampled.
For quality control purposes, a trip blank and two field blanks were
prepared in addition to the groundwater samples to check for possible cross-
contamination. Also, two monitoring wells (MW-3A, and C-1A) were used to
obtain duplicate samples to demonstrate sample representativeness.
In addition to monitoring wells, the Task Force also sampled five
landfill leachate detection, or pressure relief systems: 141-BD, and 143-ED
(cell 14 detection systems), 141-BPR and 143-EPR (cell 14 pressure relief
systems), and SL05D (cell 5 detection system). The purpose in obtaining
samples from these points was to check for potential contaminations migrating
from the landfill cells to the natural groundwater system. The leachate
samples (and the groundwater samples) were considered to below concentration
(appreciable levels of contaminants were not known to exist).
Groundwater Level Measurements
In order to check facility - reported groundwater flow directions, and
to determine the volume of water to he purged from each well prior to
sampling, the Task Force measured water level in all monitoring wells using a
FISHER M-SCOPE® slope indicator. The probe and calibrated tape of this
instrument were lowered into the well through a small diameter access port
-48-
-------
TABLE 3
TASK FORCE GROUNDWATER LEVEL MEASUREMENTS*
Upper Pervious Zone
MW-4
MW-3
MU-9
MW-10
B-l
B-3A
MW-3A
MW-5A
MW-6
MW-7
MM -11 A
MU-12B
MW-13A
Channel
MW-1
MW-2A
B-4
4.18
4.78
2.55
4.09
0.69
2.53
Lower
-8.22
1.27
-4.52
-2.09
-0.88
-4.9
5.19
Sand
-11.73
-11.72
-11.46
B-5A
B-6
B-7
B-8
E-l
Pervious Zone
MW-1 4 A
B-2
B-9A
B-10
C-1A
C-2B
E-2
60
D-1B
D-2A
E-3
Dry
3.61
0.54
4.48
-7.04
-8.92
-0.61
-4.45
-6.36
-4.58
-9.9
-7.02
- Foot Sand
-15.68
-17.46
-18.53
*A11 measurements are expressed in feet relative to mean sea level.
-49-
-------
in the PVC well cap. When the prohe contacted the water surface in the well,
the depth reading from the top of the PVC well casing (known elevation) was
recorded. Also, the distance from the top of the casing to the ground was
measured and recorded. The Task Force water level measurements agreed with
facility data which indicated a general southwest flow direction in the 60-Foot
Sand and Channel Sand. All Task Force groundwater level measurements are
shown in Table 3.
Monitoring well B-5A was the only dry well encountered hy the Task
Force. This well is located northwest of landfill cell 14, outside the
slurry wall in the Upper Pervious Zone.
Prior to measuring water levels, each wellhead was monitored for organic
vapors and radiation. As a result, it was determined that background levels
of organic vapors and radiation existed at each well. Therefore, only
minimal safety equipment was required ("level D") for purging and sampling.
Well Purging
The volume of water standing in the well was calculated (only for wells
to he sampled) based on well diameter, well depth (from well schematics) and
standing water elevation. Total well depths were not measured hy the Task
Force due to the presence of dedicated WELL WIZARD® pumps in the wells, and
due to the fact that the LDEQ had verified well depths at CWM during an
earilier inspection. At least three casing - volumes of standing water were
then removed hy the facility using the dedicated pumps to ensure that
representative formation water was recovered for sampling. The purging time
required to remove three casing volumes of water was based on the rate of pumping.
All purge water was poured on the ground hy the facility.
Two monitoring wells went dry prior to the calculated purge volume
being removed. These were monitoring wells E-l and E-2.
Groundwater Sample Collection
Groundwater sample collection was performed hy VERSAR while CWM
operated the WELL WIZARD® pump controller/driver equipment (portable gas
powered compressor). Samples were collected at the wellhead through a 1/2
inch hose into the containers shown in Table 4 in order of decreasing volatilization
-50-
-------
TABLE 4
PARAMETER, BOTTLE TYPE, AND PRESERVATIVE LIST
TASK FORCE SITES
Parameter
Bottle Type
Preservative
Volatile Organ!cs
Purgeable Organic Carbon
(POC)
Purgeable Organic Halogen
(POX)
Extractable Organics:
Base/Neutral/Acids
Pesticide/PCBs
Herbicides
Dioxins/Furans
Total Metals
Dissolved Metals
Total Organic Carbon
(TOC)
Total Organic Halogens
(TOX)
Phenols
Cyanide
Anions
Sulfide
2 40-ml vials
1 40-ml vial
1 40-ml vial
2 1-liter amber glass
2 1-liter amber glass
2-1-liter amber glass
2 1-liter amber glass
1 1-liter plastic
1 1-liter plastic
1 4-oz. glass
1 1-liter amber glass
1 1-liter amber glass
1 1-liter plastic
1 1-liter plastic
1 4-oz. glass
Cool 4°C
Cool 4°C
Cool 4°C
Cool 4°C
Cool 4°C
Cool 4°C
Cool 4°C
Cool 4°C, HN03
Cool 4°C, HN03,
filtered
Cool 4°C, H2S04
Cool 4°C, no
headspace
Cool 4°C, H2S04
Cool 4°C, NaOH
Cool 4°C
Cool 4°C, Zinc
Acetate, NaOH
-51-
-------
(samples for volatile organic.s were taken first) after purging was completed
(or, in the r.ase of E-l and E-2 after the wells had sufficiently recharged
from purging).
Field measurements for pH, specific conductance, and temperature were
recorded for each well at the time of sampling. The presence of any sediment
or any unusual color or odor were also noted for each sample. This
information was recorded on individual well data sheets along with other
pertinent information including time, location, and general wellhead condition.
Field blanks were poured near monitoring well MW-2A (sample number
MQA952), and monitoring well C-2B (sample number MQB999) on the third and
fifth day, respectively, of the inspection. These locations were generally
leeward of facility oeprations at the time the blanks were poured.
The water level probe was washed between sampling events to prevent
possible cross-contamination. This involved the use of hexane, and deionized water,
Splits of all samples were offered to CWM. CWM elected not to split
samples with the Task Force as they had recently completed their first
quarter sampling event.
After collection, samples were labeled, placed in an ice chest, and then
transported to a temporary onsite holding area set up by VERSAR near the
truck weighing station (in the northeast corner of the current waste
management area). Here, samples were preserved and packed in the ice chests
for shipment (via Federal Express) to EPA contract laboratories.
Landfill "Leachate" Collection
The procedures used to collect samples from the landfill leachate
detection systems and pressure relief system were basically the same as
sample collection procedures used for the monitoring wells. The main
differences in the procedures used are as follows:
1. No depth readings were taken.
2. Leachate was removed from the riser pipes using dedicated
stainless steel GRUNFOS® impellor pumps.
3. Purge water was not poured on the ground; it was contained
. and transported to the onsite million gallon storage tank.
-52-
-------
TASK FORCE MONITORING DATA ANALYSIS FOR INDICATIONS OF WASTE RELEASES
As a result of Task Force groundwater sampling and analysis, no
definitive indication of groundwater contamination was discovered at
CWM. Also, none of the samples taken from facility monitoring wells
showed any constituents at levels above the "Maximum Concentration of
Constituents For Ground-Water Protection" in 40 CFR §264.94.
The results for the pressure relief system underlying cell 14 (141-
BPR, and 143-EPR) were, likewise, non-indicative of contamination.
Also, analytical results from landfill leachate detection systems
generally indicated very low concentrations of most constituents with
the following exceptions (not inclusive):
1) The leachate detection system for landfill cell 5 (SL05D) showed
chromium at 939 ug/1 , and lead at 250 ug/1.
2) The leachate detection system for the west side of module 1,
cell 14 (141-BD) showed TOX at 44,350 ug/1.
3) The leachate detection system for the east side of-module 3,
cell 14 (143-ED) showed vinyl chloride at 2,300 ug/1,
1,2-Dichloroethane at 6,000 ug/1, arsenic at 134 ug/1, and
TOX at 10,780 ug/1.
A complete listing of all constituents found in groundwater and
leachate sample taken hy the Task Force is shown in Appendix A. All values
shown in this table are in micrograms per liter (ug/1).
The contract laboratories utilized hy the Task Force were EMSI of
Newhury Park, California (organic analysis), Centec Laboratories of Salem,
Virginia (inorganic and indicator analyses), and Compuchem Laboratories, Inc.,
of Research Triangle Park North Carolina (dioxin/dihenzofuran analyses).
All analytical data was subjected to a data useahility assessment
hy an EPA contractor (Lockhead Engineering and Management Services
Company, Inc. of Las Vegas, Nevada). This assessment was designed to
assist the user in interpreting the analytical data, and is also provided
in Appendix A.
-53-
-------
The Task Force observed near-neutral pH values in all monitoring wells.
However, a pH reading of over 10 was observed in monitoring well D-2A
prior to purging. This value was rer.her.ked after purging and found to
he near pH 7. It is suspected that the initially high pH reaing was
due to groundwater in the well casing being influenced by the cement/hentonite
grout which fills the welIbore-casing annul us.
A number of the monitoring wells sampled showed specific conductivity
values of over 2000 umhos/cm. Four wells had values of specific
conductivity of over 3,400 umhos/km (MW-4, MW-7, D-1B, and E-2). Higher
than usually chloride values were also associated with MW-4 (580 mg/1),
and E-2 (700 mg/1) and may he contributing to elevated specific conductance.
Monitoring wells MW-11A and E-l showed TOX readings of 546 ug/1
and 592 ug/1 respectively. Also, a minor amount of foam was produced from
MU-11A as purging was begun. As already stated, however, no known
contaminants were identified in these wells.
At least seven monitoring wells were noted as having a strong sulphur
odor. These wells are E-l, E-2, MW-1, MW-4, C-1A, C-2B, and D-1B. Task
Force analytical results show sulfate (which is believed to he naturally
occurring) ranging from 29 mg/1 (MW-1) to 1690 mg/1 (MW-4) in these wells.
One monitoring well, MW-8, was noted as having an odor similar to coal
tar. The source of this odor has not been identified.
Most well samples exhibited low turbidity (high turbidity values may
indicate excessive well siltation). The wells with the highest levels of
turbidity were C-1A (18 NTU), E-l (11.9 NTU), MW-11A (9.6 NTU), and E-2 (7.9
NTU). All wells in the uppermost aquifer exhibited low turbidity values.
No appreciable levels of phenol (which as discussed previously has been
a constituent of interest at the site) was detected by the Task Force in any
of the monitoring wells samples. Analytical results show that very low-
levels of phenol was detected in two wells: monitoring well MW-3A, and
monitoring well E-2. The levels of phenol detected in these wells (as total
phenols) was 53 ug/1 in monitoring well MW-3A. These values are near the
contractor-required detection limit of 50 ug/1.
At the time this report was written, the analytical results for dioxins/
dihenzofurans were not available. The results for these parameters are
expected to he available in the near future.
-54-
-------
TASK FORCE RECOMMENDATION
The facility should verify the levels of contaminants (including (TOX)
in the leachate detection systems of landfill cells 5 and 14 and take
remedial steps as necessary to ensure groundwater protection.
-55-
-------
REFERENCES
1. U.S. EPA, "Hazardous Waste Ground Water Task Force Protocol for
Ground-Water Evaluations", September 1986
2. U.S. EPA, "RCRA Ground-Water Monitoring Technical Enforcement
Guidance Document", September 1986
3. Woodward-Clyde Consultants, "Chemical Waste Management, Inc.
Lake Charles Facility, Annual Report To The Louisiana Department
Of Environmental Quality, January 1986 - December 1986",
February 1987
4. Woodward-Clyde Consultants, "Chemical Waste Management, Inc.,
Lake Charles Facility, Annual Report To The Louisiana Department
Of Environmental Quality, July 1985 - December 1985", February 1986
5. Woodward-Clyde Consultants "Chemical Waste Management, Inc.,
Lake Charles Facility "Annual Report To The Louisiana Environmental
Control Commission, July 1984 - June 1985", July 1985
6. Chemical Waste Management, Inc., "Louisiana Hazardous Waste
Regulations Part II Application, Chemical Waste Management, Inc.,
Lake Charles Facility, Carlyss, Lousiana", November 1984 [Revised
February 1985, and July 1985]
7. Chemical Waste Management, Inc., "Exposure Information Report For
The Chemical Waste Management, Inc. Lake Charles Facility, Carlyss,
Louisiana", August. 1985
-56-
-------
APPENDICES
-------
APPENDIX A
TASK FORCE ANALYTICAL RESULTS
-------
pro
PRC Environmental Management, Inc.
Suiie 500
Planning Research Corporation
Chicago. IL 6060'
312-856-8700
FAX# 938-0118
EVALUATION OF QUALITY CONTROL ATTENDANT
TO THE ANALYSIS OF SAMPLES FROM THE
CHEMICAL WASTE MANAGEMENT (CARLYSS), LOUISIANA
FINAL MEMORANDUM
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Waste Programs Enforcement
Washington, D.C. 20460
Work Assignment No.
EPA Region
Site No.
Date Prepared
Contract No.
PRC No.
Prepared By
Telephone No.
EPA Primary Contact
Telephone No.
549
Headquarters
N/A
September 11, 1987
68-01-7331
015-05492203
PRC Environmental
Management, Inc.
(Ken Partymiller)
(713) 292-7568
Rich Steimle
(202) 382-7912
-------
MEMORANDUM
DATE: September 1, 1987
SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
from the Chemical Waste Management, Carlyss, Louisiana Facility
FROM: Ken Partymiller, Chemist
PRC Environmental Management, Inc.
TO: HWGWTF: Richard Steimle, HWGWTF*
Paul H. Friedman, Chemist*
Gareth Pearson, EMSL/Las Vegas*
Tom Aalto, Region VI
Michael Daggctt, Region VI/Houston
Brian Lewis, HWGWTF
This memo summarizes the evaluation of the quality control data generated by
the Hazardous Waste Ground-Water Task Force (HWGWTF) contract analytical
laboratories (1). This evaluation and subsequent conclusions pertain to the data
from the Chemical Waste Management, Carlyss, Louisiana sampling effort by the
Hazardous Waste Ground-Water Task Force.
The objective of this evaluation is to give users of the analytical data a more
precise understanding of the limitations of the data as well as their appropriate use.
A second objective is to identify weaknesses in the data generation process for
correction. This correction may act on future analyses at this or other sites.
The evaluation was carried out on information provided in the accompanying
quality control reports (2-5) which contain raw data, statistically transformed data,
and graphically transformed data.
The evaluation process consisted of three steps. Step one consisted of
generation of a package which presented the results of quality control procedures,
including the generation of data quality indicators, synopses of statistical indicators,
and the results of technical qualifier inspections. A report on the results of the
performance evaluation standards analyzed by the laboratory was also generated.
Step two was an independent examination of the quality control package and the
performance evaluation sample results by members of the Data Evaluation
Committee. This was followed by a meeting (teleconference) of the Data Evaluation
Committee to discuss the foregoing data and data presentations. These discussions
were to come to a consensus, if possible, concerning the appropriate use of the data
within the context of the HWGWTF objectives. The discussions were also to detect
and discuss specific or general inadequacies of the data and to determine if these
are correctable or inherent in the analytical process.
Preface
The data user should review the pertinent materials contained in the
referenced reports (2-5). Questions generated in the interpretation of these data
relative to sampling and analysis should be referred to Rich Steimle of the
Hazardous Waste Ground-Water Task Force.
HWGWTF Data Evaluation Committee Member
-------
I. Site Overview
The Carlyss facility is located in Louisiana and is owned by Chemical Waste
Management. The facility covers an area of 280 acres of which less than 100 acres
are being or have been used. The facility is a commercial hazardous waste facility
and, due to its location near the Texas-Louisiana border, it has accepted waste from
the petroleum refining and drilling industries as well as other industries. These
wastes include API separator sludge, tank bottoms, contaminated dirt and debris,
electric arc furnace dust, storm water sludge, contaminated oil, etc. The facility
previously operated a landfarm upgradient from the hazardous waste landfill. The
facility presently operates a solid waste municipal landfill which is also located
upgradient from the hazardous waste landfill. The facility is presently using a
double lined landfill for hazardous wastes.
The geology under the site consists of silts and clays with some sand
stringers. The deposits are deltaic deposits which are neither homogeneous nor
continuous. All the excavated facilities at the site are below the water table and
thus the water table exerts an upward pressure on the landfills. The groundwater
under the facility is brackish.
Twenty-eight field samples were collected at this facility. The samples
included two field blanks (MQA952 and 999), a trip blank (MQB602), and two sets of
duplicate samples (MQA922/951 and 996/997). All samples were designated as low
concentration ground-water samples except samples MQB604, 605, 606, and 607 which
were low concentration Icachate water samples. All samples were analyzed for all
HWGWTF Phase 3 analytcs with the following exceptions. Sample MQB604 was not
analyzed for organics compounds and sample MQB605 was not analyzed for volatile
compounds. All samples were analyzed for dioxins and furans but that information
was not received in time to be included with the teleconference for this facility or
with this memorandum. Those results will be made available as an addendum to this
memorandum.
II. Evaluation of Quality Control Data and Analytical Data
1.0 Metals
1.1 Metals QC Evaluation
Total metal average spike recoveries were calculated for twenty-four metals
spiked into samples MQA998 and MQB606. Twenty-one total metal average spike
recoveries from these samples were within the data quality objectives (DQOs) for
this Program. The average spike recoveries of total mercury (60 percent), thallium
(20 percent), and zinc (74 percent) were below the DQO range of 75 to 125 percent.
Nine individual total metal spike recoveries were outside DQO and will be discussed
in the following Sections. The total metal spike recoveries for arsenic, calcium,
magnesium, and manganese from sample MQB606 were not calculated because the
amounts of these metals in this sample were greater than four times the amount of
the spike. This information is listed in Tables 3-la and 3-2a of Reference 2 as well
as in the following Sections.
Samples MQA998 and MQB606 were also analyzed for twenty-four dissolved
metals. Twenty-two of the twenty-four dissolved metal average spike recoveries
were within the data quality objectives (DQOs) for this Program. The average spike
recoveries of dissolved manganese (72 percent) and selenium (50 percent) were below
the DQO range of 75 to 125 percent. Four individual dissolved metal spike
recoveries were outside DQO and will be discussed in the following Sections. The
-------
dissolved metal spike recoveries for magnesium and manganese from sample MQB606
were not calculated because the amounts of these metals in this sample were
greater than four times the amount of the spike. This information is listed in
Tables 3-lb and 3-2b of Reference 2 as well as in the following Sections.
The calculable average relative percent differences (RPDs) for all metallic
analytes were within Program DQOs. RPDs were not calculated for approximately
three-quarters of the metal analytes because the concentrations of many of the
metals in the field samples used for the RPD determination were less than the
CRDL and thus were not required, or in some cases, not possible to be calculated.
Required metal analytc determinations were performed on all samples submitted
to the laboratory.
Laboratory blanks showed no contamination involving the metallic analytes.
Sampling blank contamination was reported and will be discussed in the following
Sections.
1.2 Furnace Metals
The quality control results for the metals analyzed by graphite furnace atomic
absorption analyses (antimony, arsenic, cadmium, lead, selenium, and thallium) were
generally acceptable.
The matrix spike recoveries of total thallium (21 percent), total selenium (70
percent), and dissolved cadmium (132 percent) for spiked sample MQA998 were
outside the DQO. The matrix spike recoveries of total thallium and the dissolved
selenium (each 19 percent) for spiked sample MQB606 were below DQO. All results
for total thallium and dissolved selenium should be considered unusable due to the
low spike recoveries. All results for total selenium and dissolved cadmium should be
considered semi-quantitative unless otherwise qualified.
Several continuing calibration verifications (CCVs) for total antimony and total
and dissolved arsenic were outside DQO limits. The rccalibration data for the CCV
and the continuing calibration blank (CCB) which should have been run after the
recalibration had not been rerun. Total antimony results for samples MQA886, 887,
888, 889, 953, 958, 959, 960, 962, 963, MQB602, 606, and 607, total arsenic results
for samples MQA887, 888, 922, and 951, and dissolved arsenic results for samples
MQA886, 887, 888, 889, 922, 955, 996, 997, 998, and 999 were affected and should be
considered semi-quantitative.
The correlation coefficients for the method of standard addition (MSA)
determination of total arsenic in samples MQB604 and 606, of total cadmium in
sample MQA953, and of total selenium in sample MQB604 were below DQO. The
correlation coefficients for the MSA determination of dissolved arsenic in samples
MQA998D (duplicate sample) and MQB607 were also below DQO. The results for
these analytes in the indicated matrices and samples, except for total arsenic in
sample MQB606, should be considered unusable. Results for total arsenic in sample
MQB606 should be considered qualitative.
The analytical spike recoveries of total thallium in samples MQA886, 887, 889,
954, 955, 959, 960, and 961 and of dissolved thallium in samples MQA954, 960, 961,
MQB601, and 607 ranged from 14 to 38 percent. These results should not be used.
The analytical spike recoveries of total antimony in sample MQB604 and dissolved
selenium in samples MQA961, MQB606, and 606 (duplicate sample) ranged for 17 to
34 percent. These results should not be used.
-------
The double burn precision for total thallium in sample MQA962 and dissolved
selenium in samples MQA955, MQB603, and 604 was above DQO. Results for these
analytes in these samples should be considered semi-quantitative unless otherwise
qualified.
The dissolved arsenic result for sample MQB607 (2886 ug/L) was initially
reported as being significantly greater than the total arsenic result for the sample
(14 ug/L). This sample was reanalyzed at a much later date and determined to have
1460 ug/L of dissolved arsenic and 990 ug/L of total arsenic. (The concentration of
arsenic may be reduced over time because of adsorption to the container walls.)
The HWGWTF does not normally require a dissolved metals analysis because EPA
does not have a standardized field procedure for separating dissolved from total
metals. The original dissolved arsenic result for sample MQB607 should be
considered quantitative while the original total arsenic result should not be used.
The results for the rerun total arsenic should be assumed to be qualitative.
Duplicate field precision results for total lead in sample pair MQA996/997 was
poor with 6 ug/L of total lead reported for sample MQA996 and 12 ug/L reported
for sample MQA997. The comparative precision of field duplicate results is not used
in the usability evaluation of sample results. It is not possible to determine the
source of this imprecision. The poor precision may be reflective of sample to
sample variation rather than actual analytical variations.
The usability of all graphite furnace analytes is summarized in Sections 4.0 and
4.1 at the end of this Report.
1.3 ICP Metals
The matrix spike recoveries for total chromium (126 percent) and dissolved
manganese (72 percent) in sample MQA998 were outside DQO. The matrix spike
recoveries for total chromium (68 percent), cobalt (70 percent), tin (72 percent), and
zinc (68 percent) in sample MQB606 were below DQO. The trend of low spike
recoveries indicate a low bias in the data. All results for these analytes in the
appropriate matrices should be considered semi-quantitative unless qualified for
other reasons.
The low level (twice CRDL) linear range checks for all total chromium samples
except MQA962, 963, MQB606, and 607 exhibited recoveries which were high by
about 30 percent. The low level (twice CRDL) linear range check results for all
total nickel, silver, and tin samples, all total zinc samples except MQA962, 963,
MQB606, and 607, and total chromium for samples MQA962, 963, MQB606, and 607
exhibited low recoveries ranging from 5 to 50 percent. The low level linear range
check results for dissolved chromium and tin for samples MQA886, 887, 888, 889,
922, 951, 952, 954, 955, 958, 962, 963, 999, MQB601, 603, 604, 605, 606, and 607
exhibited low recoveries of approximately 15 to 20 percent. The low level linear
range check results for dissolved nickel, silver, and zinc for samples MQA959, 953,
960, 961, 995, 996, 997, 999, and MQB602 exhibited low recoveries of approximately
5 to 18 percent. The data user should refer to Comment B7 of Reference 3 for a
detailed listing of analysis dates, samples affected, and biases. The low level linear
range check is an analysis of a solution with elemental concentrations near the
detection limit. The range check analysis shows the accuracy which can be
expected by the method for results near the detection limits. The accuracy
reported for these metals at these concentrations is not unexpected. Low
concentration results for metals with high recoveries would be expected to be biased
high while those with Tow recoveries would be expected to be biased low.
-------
Dissolved zinc contamination was reported in both of the field blanks (MQA952
and 999) and the trip blank (MQB602) at concentrations of 41, 85, and 119 ug/L.
The zinc CRDL is 20 ug/L. As a result of this contamination, all dissolved zinc
results, except those for samples MQA952, 953, 999, MQB602, and 604, should not be
used. Dissolved zinc results for samples MQA952, 953, 999, MQB602, and 604 should
be considered quantitative unless otherwise qualified.
The serial dilution RPD results for dissolved calcium, magnesium, and
manganese in sample MQA998 were outside DQO. All results for these analytes
should be considered semi-quantitative unless otherwise qualified.
The third CCV for all dissolved metals (by ICP analysis) run on 6/26/87 was
outside DQO. All dissolved metal results for samples MQA999, MQB601, 603, 604,
605, and 606 were affected and should be considered semi-quantitative unless further
qualified. The third continuing calibration blank (CCB) for dissolved aluminum was
outside DQO. The instrument detection limit of 400 ug/L should be used for
dissolved aluminum in samples MQA999, MQB601, 603, 605, and 606.
In some samples the dissolved results for an analyte were greater than the
total results for that same analyte. This was true for aluminum in samples MQA886,
889, calcium in samples MQA953, 960, 962, MQB601, 605, and 607, iron in sample
MQA960, magnesium in samples MQA953, 960, MQB601, and 607, manganese in
samples MQA953, 960, 962, MQB601, 605, 606, and 607, potassium in samples
MQA960, MQB601, and 605, sodium in samples MQA959, 960, 962, 963, MQB601, and
605, and zinc in samples MQA886, 887, 889, 922, 951, 952, 954, 955, 958, 959, 960,
961, 962, 963, 995, 996, 997, 999, MQB601, 602, 603, 605, and 607. The data
usability results for the above samples range from semi-quantitative to unusable.
The data user is referred to Comment B6 of Reference 3 or Sections 4.2 and 4.3 at
the end of this Report. The HWGWTF docs not normally require dissolved metal
determinations because EPA docs not have a standard field protocol for separating
dissolved from total metals.
The usability of all total and dissolved ICP metal analytes is summarized in
Sections 4.2 and 4.3 at the end of this Report.
1.4 Mercury
The matrix spike recoveries for total (no recovery) and dissolved mercury (52
percent) from sample MQB606 were below DQO. All results for total mercury should
not be used and all results for dissolved mercury should be considered semi-
quantitative with raised (by a factor of 2) detection limits.
2.0 Inorganic and Indicator Analvtcs
2.1 Inorganic and Indicator Analvte QC Evaluation
The average spike recoveries of all of the inorganic and indicator analytes,
with the exception of that for chloride, were within the accuracy DQOs. Accuracy
DQOs have not been established for the bromide, fluoride, nitrite nitrogen, and
sulfide matrix spikes.
The calculable average RPDs for all inorganic and indicator analytes were
within Program DQOs. RPDs were not calculated if either one or both of the
duplicate values were less than the CRDL. Precision DQOs have not been
established for bromide, fluoride, nitrite nitrogen, and sulfide.
-------
Requested analyses were performed on all samples for the inorganic and
indicator analytes.
No laboratory blank contamination was reported for any inorganic or indicator
analyte. TOC contamination was found in the trip blank (MQB602) and the field
blank (MQA952). This contamination will be discussed below.
2.2 Inorganic and Indicator Analvte Data
All results for bromide, fluoride, sulfate, sulfide, total phenols, and POX should
be considered quantitative with an acceptable probability of false negatives.
Cyanide sample MQB604 was analyzed 3 days in excess of the 14 day cyanide
holding time. Results for this sample should be considered semi-quantitative.
Cyanide results should be considered quantitative with the exception of sample
MQB604 which should be considered semi-quantitative.
The chloride matrix spike recoveries from samples MQA998 (130 percent) and
MQB606 (120 percent) were above their DQO range of 90 to 110 percent. The trend
of high spike recoveries indicate a high bias in the data. All results for chloride
should be considered semi-quantitative.
The holding times for the nitrate and nitrite nitrogen determinations ranged
from 20 to 28 days from receipt of the samples which is longer than the
recommended 48 hour holding time for unpreserved samples. All nitrate and nitrite
nitrogen results should be considered semi-quantitative.
Duplicate field sample precision for sulfide in both duplicate sample pairs,
MQA922/951 and MQA996/997, was poor with 18,000 and 8800 ug/L of sulfide
reported in the first pair of samples and no sulfide and 7200 ug/L of sulfide
reported in the second sample pair. The comparative precision of field duplicate
results is not used in the preparation of the usability evaluation of sample results.
It is not possible to determine the source of this imprecision. The poor precision
may be reflective of sample to sample variation rather than actual analytical
variations. All sulfide results should be considered quantitative.
Duplicate field sample precision for total phenols in duplicate sample pair
MQA922/951 was poor with no total phenols reported in one sample and 59 ug/L
reported in the second sample. The comparative precision of field duplicate results
is not used in the preparation of the usability evaluation of sample results. It is
not possible to determine the source of this imprecision. The poor precision may be
reflective of sample to sample variation rather than actual analytical variations. All
total phenols results should be considered quantitative.
TOC contamination was reported in field blank MQA952 at a concentration of
3700 ug/L and in trip blank MQB602 at a concentration of 1500 ug/L. The TOC
CRDL is 1000 ug/L. As a result of this contamination, TOC results should not be
used with the exception of result for sample MQB606 which should be considered
qualitative and results for samples MQA887, 888, 951, 953, 959, 962, 995, 998, 999,
MQB602, 603, and 607 which should be considered quantitative. Duplicate field
sample precision for TOC in duplicate sample pair MQA922/951 was poor with 1500
ug/L of TOC reported in one sample and no TOC reported in the second sample.
The comparative precision of field duplicate results is not used in the preparation
of the usability evaluation of sample results, ft is not possible to determine the
source of this imprecision. The poor precision may be reflective of sample to
sample variation rather than actual analytical variations.
-------
Calibration verification standards for POC were not analyzed. A POC spike
solution was run during the analytical batch but the "true" value of the spike was
not provided by the laboratory. EPA needs to supply the inorganic laboratory with
a POC calibration verification solution. Until then, the instrument calibration can
not be assessed. The matrix spike recovery of POC from sample MQA998 was above
DQO with a value of 114 percent. The POC holding time ranged from 9 to 13 days.
Although the EMSL/Las Vegas data reviewers recommend a 7 day holding time, the
EPA Sample Management Office (SMO) has instructed the lab that a 14 day holding
time is acceptable. The POC results for all samples should be considered
qualitative.
The TOX results for several samples were greater than the largest (100 ug/L)
TOX calibration standard. These samples should have been diluted and rerun.
Results for these samples (MQA889, 955, 963, MQB601, 604, 605, 606, and 607) were
assigned by extrapolation and should be assumed to be semi-quantitative.
The POX holding time for samples MQA953, 954, 955, 958, 959, 960, 961, and
MQB602 was 9 days. Although the EMSL/Las Vegas data reviewers recommend a 7
day holding time, the EPA Sample Management Office (SMO) has instructed the lab
that a 14 day holding time is acceptable. The POX results for all samples should be
considered quantitative.
3.0 Organics and Pesticides
3.1 Organic OC Evaluation
All matrix spike average recoveries were within established Program DQOs for
accuracy. Individual matrix spike recoveries which were outside DQO limits will be
discussed in the appropriate Sections below.
All required surrogate spike average recoveries were within DQOs for accuracy.
Individual surrogate spike recoveries which were outside the accuracy DQO will be
discussed in the appropriate Sections below.
All reported matrix spike/matrix spike duplicate average RPDs were within
Program DQOs for precision. Individual matrix spike RPDs which were outside the
precision DQO will be discussed in the appropriate Sections below.
All average surrogate spike RPDs, with the exception of the pesticide
dibutylchlorendate, were within DQOs for precision. Surrogate standard were
neither required nor used for the organo-phosphorous herbicide determination.
Requested organic compound analyses were performed, with one exception, on
all.samples submitted to the laboratory. Sample MQB604 was not analyzed for the
organic compounds. The dioxin and furan results were neither received nor
analyzed in time to be included in the teleconference on this facility.
Laboratory (method) and sampling blank contamination was reported for
organics and is discussed in Reference 4 as well as the appropriate Sections below.
Detection limits for the organic fractions are summarized in Reference 4 as
well as the appropriate Sections below.
-------
3.2 Volatiles
Samples MQB604 and 605 were not analyzed for volatile organic compounds.
The analytical laboratory exceeded the volatile holding time of seven days for
samples MQA992MS (matrix spike), 922MSD (matrix spike duplicate), and MQB606.
Volatile results for these samples should not be used because they exceeded the
holding time. Volatile results for all other samples should be considered semi-
quantitative.
Acetone contamination was found in laboratory (method) blanks MB-1 through
MB-8 at concentrations of 1 to 4 ug/L. Acetone contamination was also found in
the field and trip blanks at concentrations ranging from 2 to 9 ug/L. The acetone
CRDL is 10 ug/L. Laboratory contamination is the probable source of this
compound. Positive acetone results for all samples were judged to be unusable due
to this blank contamination.
Laboratory (method) blanks MB-1, MB-2, MB-3, MB-5, MB-6, and MB-7
contained methylcne chloride contamination at concentrations ranging from 1 to 4
ug/L. Mcthylene chloride contamination was also found in the field blanks at
concentrations of 1 and 6 ug/L. The methylcne chloride CRDL is 5 ug/L.
Laboratory contamination is the probable source of this compound. No positive
methylene chloride results (all samples except MQA886, 888, 889, 951, 953, 955, 958,
998, and MQB602) should be used due to this blank contamination.
In their standards, the analytical laboratory confused the cis- and trans-1,3-
dichloropropcne isomers and the 4-methyl-2-pcntanonc and 2-hexanone isomers. As
none of these compounds were found in the samples, the data quality was not
affected.
Erratic percent differences between the average response factors for initial
calibrations and daily calibration check standards were observed for various
Appendix IX compounds. This would affect the quantitative usability of the
compounds which are listed in Comment A8 of Reference 4.
Estimated method detection limits were CRDL for all samples, except MQB606
which was 50 times the CRDL. Dilution of this sample was required due to the
high concentrations of 1,2-dichloroethane and vinyl chloride. The volatile results,
with exceptions listed below, should be considered semi-quantitative. Volatile
results for samples MQA922MS, 922MSD, and MQB606 should not be used due to
excessive holding times. No positive acetone and methylene chloride results should
be used due to laboratory (method) blank contamination. The probabilities of false
negative and positive results are acceptable with the exception of samples
MQA922MS, 922MSD, and MQB606 due to the lengthy holding times and/or dilution
of these samples.
3.3 Semivolatiles
The semivolatile holding time between sample receipt and extraction was
exceeded for samples MQA888, 995, 996, 997, 998, 999, MQB601, 603, 605, 606, and
607 by 2 to 8 days.
The surrogate spike recoveries of 2-fluorophenol from samples MQA888, 888RE
(reanalysis), 922, 922RE, 951, 951RE, 959, 959RE, 960, 960RE, 961, 961RE, 995, 998,
998RE, MQB601, 605, and 605RE were below DQO. The surrogate spike recoveries
of phenol-d5 from samples 922RE, 959, 959RE, 960, 960RE, 961, 961RE, 998RE,
-------
MQB605, and 605RE were below DQO. The surrogate spike recovery of phenol-d5
from laboratory (method) blank MB-4 was above DQO. The surrogate spike
recoveries of 2,4,6-tribromophenol from samples MQA959, 959RE, 960, 960RE, 961,
961RE, MQB605, and 605RE were below DQO. Although all other acid surrogate
recoveries were within DQO, the acid surrogate recoveries for samples MQA959, 960,
961, and MQB605 were generally low and thus the acid fraction results for these
samples are expected to be biased low and should not be used.
Semivolatile laboratory (method) blanks, MB-1 through MB-4 contained
contamination including several unknown compounds at estimated concentrations
ranging from 10 to 2000 ug/L as well as bis(2-ethylhcxyl)phthalate at concentrations
of 3 to 4 ug/L and unknown alkylamines. The field and trip blanks also contained
bis(2-ethylhexyl)phthalate at concentrations ranging from 3 to 8 ug/L. The CRDL
for bis(2-ethylhexyl)phthalatc is 10 ug/L. No positive bis(2-ethylhexyl)phthalate
results should be used due to this contamination. Positive results for semivolatile
unknowns whose standards arc found at approximate scan numbers 347, 359, 463,
476, 515, 1397, 1500, 1511, 1607/1608, and 1713 should also not be used due to
laboratory blank contamination.
Standards for all Appendix IX semivolatile compounds have not been obtained
by the analytical laboratory. All results for these compounds, which were analyzed
by using extracted ion current profiles for major ion quantitation, should be
considered qualitative. The laboratory must obtain standards for these compounds.
The misidentification of bcnzoic acid and bis(2-chlorocthoxy)methane and 2-
chloroaniline and S^-dimcthylbcnzidcnc is possible due to their co-clution. As
these compounds were not detected, data usability was not affected.
Chromatographic peaks in laboratory (method) blank MB-4 at scans of 216 and
366 were not completely addressed by the laboratory. They were neither confirmed
as ethyl methacrylate and N-nitroso-diethylaminc nor were they listed as tentatively
identified compounds.
Due to a dilution factor of two for all samples, the estimated detection limits
for the semivolatiles were approximately twice the CRDL. The semivolatile data are
acceptable and the results should be considered semi-quantitative with the following
exceptions. The acid-fraction results for samples MQA959, 960, 961, and MQB605
should not be used due to low recoveries of acid surrogates in those samples. The
results for the Appendix IX compounds mentioned above should be considered
qualitative due to the lack of standards. All positive bis(2-ethylhexyl)phthalate
results, as well as all results for unknowns at the scan numbers listed above, should
not be used due to method and field blank contamination.
3.4 Pesticides
No laboratory (method) blank contamination was detected for the pesticides.
The 5 day holding time until extraction was exceeded by 2 days for samples
MQA995, 996, 997, 998, 999, MQB601, 603, 605, 606, and 607.
Several of the BHCs, plus heptachlor, isodrin, and dieldrin, may be present at
low levels in samples MQA889, 960, 997, MQB605, and 606. The data user is
referred to Comment C6 of Reference 4 for a list of these compounds and their
concentrations and sample numbers.
-------
The pesticide surrogate retention time shift was outside of DQO for sample
MQB607 and standard INDAII.
The estimated method detection limits for all pesticides analyses, with the
exception of samples MQB606 and 607, are the CRDLs. Samples MQB606 and 607
were diluted by 1000 for quantitation on the OV-101 column. The pesticides results
should be considered quantitative with the exceptions samples MQB606 and 607.
Results for samples MQB606 and 607 should not be used due to dilution and the
possible presence of BHCs mentioned above and in Comment C6 of Reference 4.
3.5 Herbicides
The herbicides for which the laboratory analyzed include only 2,4-D, 2,4,5-T,
2,4,5-TP, chlorobcnzilate, phorate, disulfoton, parathion, and famphur.
The allowable holding time prior to extraction was exceeded by 2 days for all
herbicide samples. The 40 day holding time prior to analysis was exceeded by 15
days for samples MQA888, 889, 922, 951, 952, 953, 954, 955, 958, 959, 960, 961, 962,
and 963.
2,4-DB was used as a surrogate for the chlorohcrbicidc fraction. No
surrogates were included for the organo-phosphorous herbicides.
Recovery of the 2,4-DB surrogate was not reported for samples MQA955,
MQB605, 606, and 607. The analytical laboratory cited background interference as
the problem.
Various chloroherbicidcs, which could not have been detected, may have been
present in samples MQA963 and 998. The responses for these analytcs would have
fallen outside the laboratory's established retention time window.
GC/MS analysis was performed on sample MQB606 and on the associated
laboratory (method) blank. The 2,4-DB surrogate was not found in the sample
although 2,4,5-TP was and chlorobcnzilate was found in the laboratory (method)
blank. Also, the presence of a large peak at scan number 1208 would mask the
presence of 2,4,5-T.
Samples MQA889, 963, 995, MQB601, 606, and 607 were diluted by factors
ranging from 5 to 200 times prior to analysis.
The estimated method detection limits were the CRDL for the organo-
phosphorous herbicides with the exceptions of the diluted samples. The organo-
phosphorous herbicide results should be considered qualitative due to the lack of a
surrogate. The results for chloroherbicides should not be used.
3.6 Dioxins and Furans
All samples were analyzed for dioxins and furans. The Dioxin/Furan Usability
Audit Report was not prepared in time to be included in the teleconference
discussion of data from this facility or to be included with this memorandum. The
dioxin and furan results will be issued as an addendum to this memorandum at a
later date.
-------
III. Data Usability Summary
4.0 Graphite Furnace Metals. Total (See Section 1.2)
Quantitative: all lead results; antimony, arsenic, and cadmium results
with exceptions
Semi-quantitative: selenium results with exceptions; antimony results for
samples MQA886, 887, 888, 889, 953, 958, 959, 960, 962,
963, MQB602, 606, and 6fr7; arsenic results for samples
MQA886, 888, 922, and 951
Qualitative: the arsenic result for sample MQB606 and the reanalyzed
arsenic result for sample MQB607 (990 ug/L)
Unusable: all thallium results; the antimony, arsenic, and selenium
results for sample MQB604; the original arsenic result
(14 ug/L) for sample MQB607; the cadmium result for sample
MQA953
4.1 Graphite Furnace Metals. Dissolved (Sec Section 1.2)
Quantitative: all antimony and lead results; arsenic, cadmium, and
thallium results with exceptions
Semi-quantitative: arsenic results for samples MQA886, 887, 888, 889, 922,
995, 996, 997, 998, and 999; the cadmium result for sample
MQB606
Unusable: all selenium results; thallium results for samples MQA954,
960, 961, MQB601, and 607
4.2 ICP Metals. Total (See Section 1.3)
Quantitative: all barium, beryllium, copper, nickel, silver, and vanadium
results; aluminum, calcium, iron, magnesium, manganese,
potassium, and sodium results with exceptions
Semi-quantitative: all cobalt and tin results; chromium and zinc results with
exceptions; aluminum results for samples MQA886 and 889;
calcium results for samples MQA962, MQB601, 605, and 607;
potassium results for samples MQ601 and 605; sodium results
for samples MQA959, 962, 963, MQB601, and 605
Qualitative: calcium, iron, magnesium, manganese, potassium, and sodium
results for sample MQA960; calcium, magnesium, and
manganese results for sample MQA953; chromium results for
samples MQA996 and MQB604; zinc results for samples MQA952,
954, 995, 997, and MQB607
Unusable: zinc results for samples MQA886, 963, 996, MQB601, 602,
603, and 605
4.3 ICP Metals. Dissolved (Sec Section 1.3)
Quantitative: aluminum, barium, beryllium, chromium, cobalt, copper,
iron, nickel, potassium, silver, sodium, tin, and vanadium
results, all with exceptions
Semi-quantitative: calcium, magnesium, and manganese results, all with
exceptions; aluminum results for samples MQA886 and 889;
zinc results for samples MQA953 and MQB604; aluminum,
barium, beryllium, chromium, cobalt, copper, iron, nickel,
potassium, silver, sodium, tin, and vanadium results for
samples MQA999, MQB601, 603, 604, 605, and 606
-------
Qualitative: calcium, iron, magnesium, manganese, potassium, and sodium
results for sample MQA960; calcium, magnesium, and
manganese results for sample MQA953; the zinc results for
sample MQA952
Unusable: zinc results with exceptions
4.4 Mercury (See Section 1.4)
Semi-quantitative: all dissolved mercury results
Unusable: all total mercury results
4.5 Inorganic and Indicator Analvtes (Sec Section 2.2)
Quantitative: all bromide, fluoride, sulfate, sulfide, total phenols, and
POX results; cyanide and TOX results with exceptions; TOC
results for samples MQA887, 888, 951, 953, 959, 962, 995,
998, 999, MQB602, 603, and 607
Semi-quantitative: all chloride and nitrate and nitrite nitrogen results;
the cyanide result for sample MQB604; TOX results for samples
MQA889, 955, 963, MQB601, 604, 605, 606, and 607
Qualitative: all POC results; the TOC result for sample MQB606
Unusable: TOC results with exceptions
4.6 Organics (See Sections 3.2 through 3.5)
Quantitative: pesticide results with exceptions
Semi-quantitative: volatile results with exceptions; semivolatile results with
exceptions
Qualitative: results for semivolatile Appendix IX compounds determined
by use of extracted ion current profiles; organo-
phosphorous herbicide results
Unusable: volatile results for samples MQA992MS, 922MSD, and MQB606;
all positive acetone and methylcne chloride (both
volatiles) results; semivolatile acid fraction results for
samples MQA959, 960, 961, and MQB605; all bis(2-
ethylhexyl)phthalate (a semivolatile) results; positive
semivolatile unknown compound results at scans 347, 359, 366,
463, 467, 515, 1397, 1500, 1511, 1607/1608 and 1713; pesticide
results for samples MQB606 and 607; all chloroherbicide results
4.7 Dioxins and Furans (See Section 3.6)
Usability not yet determined.
IV. References
1. Organic Analyses: CE-EMSI
4765 Calle Quetzal
Camarillo, CA 93010
Inorganic and Indicator Analyses:
Ccntec Laboratories
P.O. Box 956
2160 Industrial Drive
Salem, VA 24153
(703) 387-3995
-------
Dioxin and Furan Analyses:
CompuChem Laboratories, Inc.
P.O. Box 12652
3308 Chapel Hill/Nelson Highway
Research Triangle Park, NC 27709
(919) 549-8263
2. Draft Quality Control Data Evaluation Report (Assessment of the Usability of
the Data Generated) for Case O-2363HQ, Site 54, Chemical Waste Management,
Carlyss, LA, Prepared by Lockheed Engineering and Management Services
Company, Inc., for the US EPA Hazardous Waste Ground-Water Task Force,
7/21/1987.
3. Draft Inorganic Data Usability Audit Report, for Case O-2363HQ, Chemical
Waste Management, Carlyss, LA, Prepared by Laboratory Performance
Monitoring Group, Lockheed Engineering and Management Services Co., Las
Vegas, Nevada, for US EPA, EMSL/Las Vegas, 7/21/1987.
4. Draft Organic Data Usability Audit Report, for Case O-2363HQ, Chemical Waste
Management, Carlyss, LA, Prepared by Laboratory Performance Monitoring
Group, Lockheed Engineering and Management Services Co., Las Vegas, Nevada,
for US EPA, EMSL/Las Vegas, 7/21/1987.
5. Draft Dioxin/Furan Usability Audit Report, for Case O-2363HQ, Chemical Waste
Management, Carlyss, LA, Prepared by Laboratory Performance Monitoring
Group, Lockheed Engineering and Management Services Co., Las Vegas, Nevada,
for US EPA, EMSL/Las Vegas, not yet released.
V. Addressees
Gareth Pearson
Quality Assurance Division
US EPA Environmental Monitoring Systems Laboratory - Las Vegas
P.O. Box 1198
Las Vegas, Nevada 89114
Richard Steimle
Hazardous Waste Ground-Water Task Force, OSWER (WH-562A)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Brian Lewis
c/o Department of Health Services
1219 K Street, 1st Floor
Sacramento, CA 95814
Thomas Aalto
US Environmental Protection Agency
1201 Elm Street
Dallas, TX 75270
Michael Daggett
US Environmental Protection Agency
6608 Hornwood Drive
Houston, TX 77074
-------
Paul Friedman
Room 413-W
Science Policy Branch (PM-220)
US Environmental Protection Agency
401 M Street S.W.
Washington, DC 20460
Sujith Kumar
Laboratory Performance Monitoring Group
Lockheed Engineering and Management Services Company
1051 East Flamingo Drive, Suite 257
Las Vegas, Nevada 89119
Ken Partymillcr
PRC EMI/Houston
10716 Whisper Willow Place
The Woodlands, TX 77380
-------
APPENDIX A
SUMMARY OF CONCENTRATIONS FOR COMPOUNDS FOUND
IN GROUND-WATER AND SAMPLING
BLANK SAMPLES AT SITE NO. 54, CHEMICAL WASTE MANAGEMENT,
CARLYSS, LA
The following table lists the concentrations for compounds analyzed for
and found in samples at the site. Table A.-1 is generated by listing
all compounds detected and all tentatively identified compounds reported
on the organic Form 1, Part B. All tentatively identified compounds
with a spectral purity greater than 850 are identified by name and
purity in the table. Those with a purity of less than 850 are labeled,
unknown.
-------
TABLE KEY
A value without a flag indicates a result above the contract
required detection limit (CRDL).
Indicates an estimated value. This flag is used either when
estimating a concentration for tentatively identified compounds
where a 1:1 response is assumed or when the mass spectral data
indicated the presence of a compound that meets the identification
criteria but the result is less than the specified detection limit
but greater than zero. If the limit of detection is 10 pg and a
concentration of 3 pg is calculated, then report as 3J.
This flag is used when the analyte is found in the blank as well as
a sample. It indicates possible/probable blank contamination and
warns the data user to take appropriate action.
GW = ground-water
SW = surface-water
low and medium are indicators of concentration.
TIC = Tentatively identified compound.
A -2
-------
sin: cui t«0u5S: n !?•
f «u KM on i/n
tenii( »n; ?.9*!n2 hn!-g?? !
CSHMC inrtnnu! I'll M tut find u t» 1
?"1!ll UK! W-IW Of IW '
"9A *r!ln« 1 ) .'•' ? .'M
f'.";'.H{ 1 1 1
C"K»( HVAMK -1 1 1
M PIH".™ w.l'Kt* 1 1 1
h! I"!!!"! O'.OHIt 1 1 » »
l'Jl«r'".0"?tl"(.l!t 1 1 i
IMfHlW.1V'.1* 1 1
!"!'.<('( 1 1
VIHTl ClOflK 1 1
(".'!'. HW.» \ 1
""• !•• l'l?""< 1 1
ISmHOfWlWOIHIH** 1 1
110- lUO'HW?: f'.t") 1 1
<"!H <.'.( MMtl «»ft»M».H 1 1
IIMI 'I/HIU i I
I'lt "O'.IH 1 I
S'.")- H5'2 OH!0('™ IH'l ".I'*B 1 1
linft ?I5(T {If" Hl'T'.l!H!u»l*l£ 1 * ! 1 3 J
HS'2 »!l*inMl^l||Tllulul\ | |
7.4 |, ii m mni.iiur» | |
P! » f'.'ltllHIM'l'.U 1 1
I'"I"«U!* 1 1
M'C"?l 1 1
pntoi')' (.n&e^i/
•ni^o'.j W"??1? "na?Ml5 P"4"!!
IllllitllUI mil |"|-U till) HU.I4 Ulll Ml
r-u.^HM r.u (nu |JIP ru (i^ u« r.p iny
J .'H ? .'•! ? .'M
1 1 1
1 1 1
1 1 '
III!
Ill
1 1 'H 1 'M 1
1 1 1 1
III!
III!
1 1 1 1
III)
1 1 1 1
III!
Ill)
(III
1 1 1 1
1 1 1 1
1 1 1 1
»l 1 .'»! / .'MO » 1 « !•'* .'?!
1 1 1 1
1 1 1 1
1 1 1 1
1 1 '? 1 1 '? ) 1
1 1 1 1
1 1 1 1
1 1 1 1
*'•!!*!
5!-I
cm]- l9!*.?C
"OA IIC 'Ol^'t!?!*'^1^™. I?0"'J5
lOW-l-'CIHIl; !".'!•*
!C!?"[*»MOl
• i pi-Hiimmwi 1 501". f
vr^niH TAUII^
l-l P!".t.luTm«.«?l I5
2-S-M-llH K'lTl-
i HI \mi ryn m* VAurv |cnM
7 n'.!H9»t!« IHTl I (HP
1.1 r»l«H!PIH
'"". l"Mt
1
1
1
1
1
1
1
1 1
1 1
1 1
1 1
|
|
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
f'.'R
"•.'.! f-M
Of 19V
I
I
I .' I
M r
V.1.1. C-
O'J ICH
!*<
1 .'H
01 '.I P"
Cl1 IW
IHIAOOf
Ulll ("I |
OH t"«
*? *l
tn -1!1!
1 .'VI
! .'H
A -3
-------
si't:
ci*i|( lOC
I* 1^
II"! lmi«l \K I.-l
?!!!'?
pn<\»?i' rn»»M'
„. (.nk.ni (mtooo «»»«•.} hi"«7>{ Rn»«l«{ I""1'!! 1"™'^ Hn»««4 W981 R'l41??! I"1""1?'
nrtupu; \f\rptut | i|i » M tpr (inrifi.w. V'.!ll|c; KM l«i r.u inu r.u inu r.ii.(r«j.w«> »i (ny, )«*• OM 1 OM
l.Vt-ieiHtlUTl II111
(ririi i«|M»|l!> MH^t 1 1
>HMIull-? "I'lSl*!?!? 1 1
-1 "Mf H0"!r? ' '
|f!-V!H4'!". 2-4 !'!"l!l*. -i-
riinrnu.ii.ii. \f il|HH
IINt'lfVttJ 01 } AU£
iiHiuniju H)l\*»\'1.
'.""•""i »!>n»»".K
i»»««W >'.M!MX
1'utunil MMl
SWIIIIMH' l!**^
ntAitn^iM (pcitnvyl |C |tr|ft
ni.uiivu rpi Trmr4|H»|ip
ii,i, unn.| iri( i((f oplujun
nn-H^H S'J'SIII'JiP hR»™-
1 i
| |
| |
1 1
1 I
1 1
I
I
I
|
I
1
1
tA 111
l.«i»un,ii) Jft if |
nutuiujif )nn 11* l1^ 1^1
miuniiu •)
nut unuu . . t .
hut imntf
(iu| umii)
(tut nnnt|
[tut unqii
',IM! fi"nu
nut tini^ti
ll|lt Uf <|lkl
nut i*tu,4
nut tifviu
it" "OHM
nm un^iti
nut unyu
|
1
1
1
41? '»
|AAA |
1 '
1 1 1
1 1 1
1 1 1
1 1
1 1
'10 .'M 1
1 /?ft .'?!
i i
i i
i i
i i
i i i
iii
inaoys n'"""3 • -• •
Ml "I !•• '!•-'. 1 C-IO V.ll ?-!» *K'.'. »u 4 '
fli (r« C-u IW M I'.1* C-u I'.'K '
III!
III!
III!
till
ill!
(Ill
Illl
1 1 1
10 IM 1? .'H 1
Illl
III*
Illl
III)
Illl
till
I 1 1
i i i i
".!'. "'I 1
.U | l.^l
t
1
1
1
1
1
i i i i i i *
! ;« a| |n ik| 71) ik| )n | | »« .'H ?* .'H IP 'H 70 '!•
1 |n i | in )«| ("n ,i>| <" I I IOC .'H 9? )M ^A .'M '.n 'V
1 »0 '»| lnw) 'H 1 !0 'H 1 '
1 '(" '!! MAA<1 )| | | | |
. - . .
1 ' ?v / 1 ':"..! 1 1
1 /in ifc| /> ii| 1 |
« 1
1 /!"" .'H '9 '*! 1 •
1 / T\ Ift 1 /T^ It 1 1 I
1 /)» .'H /?<"> 'H 1
II / IA Ib 1 1
I .... 1 1
II I*
1 II
1 1 '
II II
II II
II II
i |
II •
1 I
1 1
I
1
1
1
1
1
I I
1 I
1 1
1 1
« ) i m a
inn a)
1
l
i
1
1
|
1
I
1 1
1 |
1 1
1 1
• i
! 1
I
III.
II II
' 1 1
ri'.i'
"l!
(ruun
ftp nni' uni f ?.."•!>
Ml I
|uit|H.>'HC" f ?.'''?
«'•
101H Ml"W-K
«rcrui[
>'> I1."
•irniiM
4«
|Ain
!0 I
I?8"
(Sin
A -I.
-------
t«. t
(Cms
IM.'H
U'P
ifti uiciim
""—•"*-•'
rt'C'Jtt
H'..t5l
IPi*?5!'."(
V'.UHIWI
Sll't'R
S'JM'.'fl
mil'.'!1
US
IMP * »fl
1
1
1
t
1
1
1
1
1
1
1
1
1
1
i m
i
i
i
i
i
i
i
1 ?!
1
1
1
1
1
1
1
1
1
1
1
1 10"?
1
1
1 MO
1
1
WUOQQ
(I'.IP »'.ftH»
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1 4!
1
1
1 ?«!
1
1
1
1
1
1
1
1
1
1
1
1
i ^«^
i
i
(insoli; pqnoM /
*n*°"? H?ag?>{ *na'VI!{ ("""(? •oaoos pnieo) fmitj qnxiot
Mi'.!) •!•'* w. 1 1 C" !* u'.'l >u M U!'.( P.' !M 'Ml CJ M« M" CM ""1 t 1^ V" "'14
C-u IOM t-'l-t'.V !'.f tS I'.V H.f C'M'.'U Of ('.HI CWI'.'d C-V-10« Ofl"U
1 1 1 1 1 1 1 1
1 1 i!!'1? 1 t?!00 1 l«iAfl | MOAfl | IIAA/I | QI'.AA | II'.AAA
" i i i ' i " " i H i i
* 1 1 1 1 1 1 I
1 1 1 1 1 1 1 I
1 1 1 JO 1 !M 1 1 'M 1 lO'O 1
1 * * 1 1 1 i 1 1? 1
1 1 ^1 1 VI 1 ?' 1 )"> I »4 | .)? | \]
1 1 1 1 1 1 0 1 i 1
1 1 1 1 1 1 1 I
1 1 V.'O 1 '.-MO 1 M10 1 ^°?0 1 ??'0 1 IT* \ ~"»n
' 1 1 1 1 III"
1 1 1 1 1 1 1 |
1 IPS 1 If.'!"") 1 mO"9 1 ?V~) 1 ?"IOnO 1 JMOOO 1 J^nAAft | >;AAAA
1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1
' ' « 1 1 1 1 1
1 1 1 1 1 1 1 1
1 1 M) 1 1 I «1 | | 1 140
1 1 1 1 1 1 1 I
' 1 1 1 1 1 1 1
i n i PJ i «? i MI pi i i> i *« | ,i
' 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1
1 1 !?*00 1 f*-?A0 1 4 IAAA | ".^OO 1 P^JOO f P!1^ 1 ii(AAA
1 1 " 1 1 II I
1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 I
1 1 ?« 1 1 1 1 I |
1 II 1 1 1 1 |
1 1 M000 1 4!^n/> 1 IIAAA | »?;00 1
1 1 Ml 1 VI 1 I0« 1 <»J I « I s? | IA
1 1 1 1 II II
1 1 II 1 | | |
1 1 Wll 1 i?'0 1 t?40 1 M!0 1 !040 1 •<)
1 1 1 1 1 1 1 I
' 1 1 1 1 1 1 I
1 ?>5 1 l"000 1 ?0!000 1 l??000 1 ^"OO 1 j'.iAni) | OMAAA | 7S(AAn
1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1
hltAOQI
V.". »" 1
r.u i ng
I i
i i
1 JS'.nn |
| |
1 1
1 "« 1
I i
i i
| 1 1 "*rvA \
1 I'O 1
1 1
(
i ?.':<> i
i i
| | IQAAA |
1 I
1 1
1 1
1 1
1 l>! 1
1 |
1 1 M 1
1 1
! ?!'M 1
( (
1 1
1 <« 1
1 ' (
1 I'""" 1
1 IM 1
1 1
, ,
1 ??(? 1
, ,
| | IOAAA |
1 1
A -5
-------
5IU! CMI". «!!ISSi l» 154
r»t.f INI--MIJ/Q
canil.l pn;
SMI! I IPCMIW
51*11 Ml'!
""••Mil
11 '1C
lM!fO. tlO"!K
IHHC. C'BP'IPt
n»u!M
ni".'f in
CIIMU CIIFOC-'.N
HIIHIf NIUPC.-IH
I9T
IP'
S'JIIMl
5". Ill*
IOC
WH. mms
jnj(
IW03
I'!P *l»l»
r.y 194
II*
:j
'
1500
•01.009 Wg52 HO"??1?
fl!'.» K»'* M'.lf KMR H«.U H-M
tH IOH C*'1W C-V IW-P-.V
1 1
•5 1 Ml 1»
1 1
1 1 10*000
1 1
1 1 1000
1 1
1 1
'9i MI n
1 1
1 1 l(>0"0
1 1 ISO"?
1 ."00 1 |5W
1 1
1 1 M
HAAO^|ti pnftoi^ ftnAOO^ f^nAQOi pnAQO'
v.u p'i !» w.H n> IH «ii n iu «i!i r-u w.i t-u
c^ i ON ivf rv i nu *-v t °w fu i w '•y i °v
1 1 1 1
i? i e; i 50 i n i 50
1 1 1 1
|AiAAA \ JIAAA | ||*.AAA | ||QAAA | ||AAAA
1 1 1 1
1100 1 l!0" 1 3100 1 1
1 1 1 1
1 1 1 1
59 1 HI ?I 1 71 1 4)
1 1 1 1
I!?0A0 1 ::0"00 1 IArt
1 1104 1 1 I!™ 1 |}00
5« 1 1 1 1
10 1 5ti 1 ' 1 4} 1 45
»n
tf.'.l l"'-4 w.U CM 1
C-H IOU CM !'.'V
1 1
«! 1 2» 1
1AAA | |
SOAAArt | JIAAA |
1 1
1 1
1 1
1 1
I? 1 (91
1 1
|(OAAA(t | ICAAl} |
•.^AAA | MA) |
1100 1 1
1 1
I? 1 1
A -6
-------
sin:
tivi no
t«M-l It
c«|i i r
$•!".{
"OA
.,,;,,
iin^
I'.C-
Vn»
m|ii(
U»>N"«H
PIS'3-CH! OK*l!"t '(("C*
•I5<3-IIMIIH(MI HHIHW«!t
H?'3 MIHtlH?«n'IH!HS(AK
3:4 r i "i itt ni '<"(«.
}.\ lilfM( nfftl n(i«i(
M "-PMHIHIHA'.ME
CA''?-*^
ri'i foi
HOAQDOtC finAOOO ftHAO*. ]
ycil ( ( u(ii «n Q gin «u
r.u-^n|j r.u j nu r.u-^i*^
1 »l J .'M
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
M (" !f\ «. .'M
1 1
1 1
1 1
'3 J 1 1
1 1
1 1
"•"••!• 4
3* VM f-3
2 .'PI
1
1
1
1
1
1
1
1
1
1
,
1
1
1
1
1
1
1
• .'PI
1
1
1
1
1
1
KM 51 VIH t 3A
C-U 1 nV r-V 1 W
3 .'"I « .'H .'
1 1
1 1
1 1
1 1
1 1
2 .'»! 1
1 3 ! 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 J! 1 '.".
1 1
1 1
1 1
1 1
1 1
1 1
V.'.l "M !!«. 'S .'M l"ll M Ml !? •'< .'•!
1 1 1 1 1 1
1 1 1 1 1 1
1 1 1 1 1 1
1 .'3 ." 1 1 '3)1 1 '? 1 1
1 1 1 1 1 1
1 1 1 1 1 1
#!•!>
1-OA5
'«?» DC
lr2,«-5 •
i-i?ro-! ic. urn. i
|iis g}g on J
!•! I'll*'. IHT'.II' "0". ISOfCfS
- -PI-»»ITl-
1-4
2 *l"9>H»!Htl [IHt»
1.1 -ItO? AIR I- Ml
3;3 !'!«[IHTL
!.! (I
1
(1C QQI 1A |
/P'.iC 9?« I 1
/f A 1
"* «M 10 .'P
/ inn i
A -T
-------
sue:
i* IM
?*"' I! IT! I!
2-?r«
Kit f 4 VII f 9 V.!'. I*" -2* WT'l ! ? V'.'.l (1 V.'l f ?A V.1.! C'l-l!*.
r.u i n|j fo inu ru (i>« r.p (11^ f-^i |i^ r.ii | ny r.i) |iig
l»!1f?«Tl II III
i»ifH> w«uf *mK it iii
1M".IIHU-I CTC'.OC.ill1* II III
• 1
I.'-J-IPM'!!1
CHI (MO
lift ufiiw £i p v
i«f H'wi />i i ri
fl I5»«r5 II III
PI! |« 1 | I
(II III
**lt* 1 'I? .'*! 1 10 IH 1 '19 '*
IJH>MJIIU. tmiPMIi | /(/> if| | | |p ii. | |
fl^NH V»l!
U'fWfl *IHl
I'I II 1 1 1 1
Wl1"*" f™. TCH!9MM»HP II 1 1 1 1
ij'it|M)MM pni »r
l»"H"|JM «'.•»« I
luit until)
ijni imijM,
'•.yi-4'IP II 1 1 1 1
II'AP (IKNII II 1 I 1 I
uo I MI./ y 1 1 f if v"' f * yt* f 'f
r-M 1 "M C-u I "V rf 1 nU r4 1 "V
1 1
1 '» J 1
1 1
1 1
1 i
1 1
i /y> 1 1
'19 !•! /• i 1
/.9 .'fl /I9 IK
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 !« 'fl l« 'H !"9 .'M «0 'M 59 'fl ln 'H V> .'fl
1 !9 )?l 49 .'•! !" J 1 J* 'fl 1" II *9 .''I '.* J'l 19 .'! 1 M '•! ?9 'M !•>" .'•!
|i>*|iniii| | |n i | |«iw) iii ttrj) ) | gAi) in '0 'M | ri 'fl 4"9 .'M }9 'H 8"0 lkl !" 'H
nui unyu
IIIM IMIUM,
mi) uni^u
ll|* UOIIU
MU) UO*|W
IIUI WII^JU
l"» H'tl"
|ll» UOHU
i'i» H"yi
ii>i> unuif
IMHnyU
iwl unHu
W "C'yi
IIUI UO^IIf
riii/ -M m«'i>
• (•
f|. nt)>/ un 1 (ImvP
H!1!
1 1 5 I
1 1 1 1 1 1 1
1 /!» .'M 1 1
II II
1 1 1
II II
1 1 1
II II
1 1 1
II II
III)
III!
Ill)
1 l'«9 1 1?" 1 1
III!
Ill)
1 Jl 1 I4« 1 .'P 1
III)
A -0
-------
sin: cvi
CAMft f
5AIM 1 i
5V 11
1-15
HIM 5
Iff!
r»l"l!'.1l
c'iri1."!
("»'."• I'.'H
f W. 1
tP!!t?
II PH
[f AA
""I-111. 5 11.1*
pfillT.AflC C£
HI « CUff
wrm
f'»«55H1
5S!t"!l!.1
511 '.IF
SOH'.'I
it"1! i nn
H«
IIMI«r.|lw
'INC
Wl't!**!
AUJ IMftVy
AICI u|r
Mf !'.*
ft? rilll*
rAf'NHM
fC'CI1."!
C'*nM'.'ll
C!'f "'. f
t'-H"
1 "t
1 A[l
» l:"IS(:H
h ur.tiui r
.1 Kit l
- »!l
1 'l«5i !'.'!!
5tl!»K'!1
simr
M!'!'J!1
IHAUIL'fl
UN
•nsooo*
NflABBOlf IfQAQQO
BMW DM IOW
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
{7IAA | HIAAA
1
1
1
2'* 1 "
1
?l?ftA 1 '!!"*
i!" 1 !-'?
1
1
]?•«, | |*M
1
I
2AA | ivitvA | |OAAAA
1 1 1 1 1
1 1 1 1 1
1 1 1 1 1
1 1 J.M 1 I».B 1 1 •?
1 1 1 1 1
| ?I1A | • JI1AAA | ^|AAA | t«*.AA f pAAAA
1 HI 2?l 1 l!5 1 l!» 1 t'.>
1 1 1 1 1
1 1 II 1
1 1 mO 1 4A40 1 IB IA f M >A 1 ^faA
1 1 1 1 1
1 2S 1 1 1 1 i
1 VA3 1 {?>AAA | 2°°AAA | |^AAAA | 10AAAA
1 1 1 1 1
1 1 1 1 1
(HI 1 1 1
1 1 1 1 1
1 f! 1 1 1 1 M
1 1 1 1 1
1 1 1 1 1
1 l!9 1 !•? 1 '? 1 !J! 1 «!
1 1 1 1 1
1 1 1 1 1
| 4A|)AAA
1 1 1 1 1
1 1 1 1 1
1 1 1 1 1
1 H 1 1 1 1 H*
1 1 1 1 1
1 I^IAA I |*,flAArt | \\ )AA | 1 1 IftA 1 1 f Sftftft
1 2'2 1 !I5 1 I'A 1 I!1) 1 IA<"
1 1 1 1 1
1 1 II 1
| ^ l*vrt | 1Q|A f DMI | *.*.ft/> | Ql |A
1 1 1 1 1
1 I I l 1
| |QIAAA | ^}9AAA | IfJAAA | plAAA | 104AAA
1 1 1 1 1
1 1 1 1 1
pmAQjA/ |in^9ti/
(fa^ftAi'r ttpAyijef ffnaQj?
if({( fui-I yi ii p- |f l" 1 1 | - 1
t-tfiw cu tow c-mw
1 1 1
1 ?2l(uy> 1 2I?1)"* 1 MW
1 1 1
1 1 1
1 1 1
1 2 '9 1 17?" 1
1 1 1
1 I.''/>AA 1 H!"*) 1 '!">
1 ?!«0 1 ll.'C 1 III
1 1 1
1 1 1
1 ?I20 1 |IAAA | ??!A
1 1 1
1 11 1 1 »
I IbfAAA 1 14AW) | ^M'^O
1 1 1
1 1 1
1 1 1
1 1 1
1 IM 1 1
1 1 1
1 1 1
1 29 1 «' 1 2"8
1 1 1
1 1 1
| 1IIAAA | 7UAAA | |OIAA
1 1 1
1 1 1
1 1 1
1 •?' 1 1
1 1 1
| 22?AAA 1 t4'An* 1 9IAA
1 «i« 1 1MO 1 l«
1 1 1
1 1 1
| P?*** 1 | OnA | 4.QIA
1 1 1
1 1 1
| JA9AAA | |w i
i i
i i
A.---9
-------
silt: tw {*«!«» u i: 4
««W(f
*«"M!
|unt r.
I"HC.
HQAQQg/
MQ! pfUOpgig
IOfM!?H! <*U M
iw: w-iw
WM'IWI 1
/IMC 1 !4
fin n(>| (rf | MftArt
rffcuii>£ |
P.'**!!'! 1
p||ii|{ |i||inr.t)i |
HIIPIIE CiirOCfH 1
IOC 1 *(>
»P» 1
5'JiMIC 1 })!""?
f'.HMM 1 lft?ftnl>
toe i
IOIH r*«s i
19« I
W.It •"••
»
yiil pu i»
t-H t'.U
44
V'.U C-2 V«.ll t! !'!'.! f 3A W.I f» l)» V.U !•'-/ Kll I1 If «!l ! ! V.M f ?•
t-« iw OH 191 iv i'.'y CM i"« cviw C-H iw c-mnii c-ii'.v
1 1 1 1 1 1 1 1
J« | Ji | ?! 1 }• 1 !9 1 !? 1 !« 1 4! 1
??:«» i i i i i i i i
^AAAAA | 1IDAAA | ^ftAAA | 1 40AAJ] | 1\AAAA f |ftift/Vt | OIAAA | fJAAAA |
1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1
1 1 1 1~> 1 1 1 1 1
1 1 1 1 1 1 1 1
}i) 1 24 1 !8 1 Ml ??4 1 V4 1 ??A 1 >9 1
1 1 1 1 1 1 1 1
| | (HA)} | | pJAAA | | ( t\ irtArt |
OAA^ | UA^ ) ?9AA | | ?!nn 1 24^ 1 1 1
Ml 1 1 1 1 1 1 M 1
14 1 ??? 1 I1) 1 1^1 II 1 * 1 1 i I
A -10
-------
fllC
I"-.'. H
CftHI|(
*'"!!!
ft!'?.
l!t-
""4
Cf If | .
CM". CWYSS. I A 154
*>!
irv»|in)i>
lift:
f(«!C"C
1.! l'!"« OfHIH'MC
I-? !'ICUO"H!H«!t
|.| |'|ri^ of nr |ur iif
*t M'*! ft CI* ty I!1!
j ( ii^rfk nf nc | |if M£
]p |i i* nint )M£fi|
|.» >• Ul
'.'ICft CUP IK
HFC* I If
1,4 !'!!"•*
IFICHIOf'PMWfVU'HM*
?Cr ''.'III HKWIMt
MI* unuif
i|cit rwi none i(iv[ if fi*fr
FIS!2 1 INU K'Tl UH'H61 *ll
Pfc*2 f! M'*l K! *?t *l HIH'H A!t
2.4 MMIMIII'I'.''"!
1 '«. mi
yijt M*-MF "C'i *u fl V(l1 c< n^n
OH -t'.V C-V (?V C-V l'"V
j if| 1 .fl"1? ™C?'!IC
| |ftiiai fCK
| |f (KM M ft
1 1
1 1
2 .' 1 1
1 .'II 2 .'H
1 1
2 J 1 1
1 1
i J 1 1
l< 1 1
1 1
2 J 1 1
1 1
1 1
1 1
1 1
1 1
4 .'Fl 4 i>!
1
1
1
1
1
1
pftt!A<;
Rr)ptqMf iffliifti MfiiiiA)
«!'! MI-l!P 'I!!'. MM" "M H! H'
fU i ny t-\f i"U r.u.i ii^
I") ''««lltt 1 ?4 !H •> .'PI
lllf!«l".l> 1 1 J M
1 1 •:'. 1 \ 15 1
| | JfWU) | .|
(III
1 1 l?0 'H 14 F 1
III!
(Ill
1 1 ?! J 1 2 J 1
1 1 2!n9 1 1
III!
1 1 1 4>" 1 1
(III
1 1 !'"• •'« y 1 1
1 1 II"1 ?55 10 .' 1
III)
III!
1 1 10 1 1
i ;i?'? .'•) t at 5 .fi
III!
1 1 Ml 1
1 1 42 1 1
1 M j 1 1 1
1 1 •> 1 1 1
1 1 1 t ! 1
•I'?
?t"l
'.*?•!$
li2r4t5-Hlr«C*OfPK|i.'»« I
11
Mi'V'.1l ISWF'S 1 1
(,i.Hnr,iinil(»(. (j| |cn»i(.« | |
1 "W ! »!H> . K'lA"! 1 1
f j i mil *. 110^ | |
1- !'!"( Ht'.ll fl I5~«F5 1 1
(^ 1 n*«_ » M0( |fif 015 M ^l
J. |.|N|IMf||l. 4(^ ICfAMff-C | |
2- !'l-l-«l 1" «- 1 1
]., pi »nii iwuf | |
} .. |**(i*!t IHvi ' HUP 1 1
7 N( ii^jfi f |r^rtii£ «^Hn |cn.4[CC | |
2 "U'F.'MlflHH £I«R 1 1
!•! MW'H'.PIM 1 1
2-2-l'l«IHft 1 1
1.1 ItHlfWIM. 1 1
1
1
1
1
1
1
1
1
HI* ;n it i
i
i
i
i
i
i
i
i
i
i
i
i
|| ie pM |rt i
1
1
(fllO 71 1 Jl) j
\
flf{ 00^ JM j |
1 1
IIW ?!? »0 .'H
1 1
A -11
-------
SMI: CM" c»°it55f u
5"W!{ ICT'IIOH! V.'.l Ul-HF y'.'.l l*»-y tf.'.>. c.\n':t
5»1l!l !T«C! C-M IMI W-IW «-l!!«
IiJ-l-WPHTL 1 1 1
IFIflH(*IHA|[P "Wl 1 1 1
l?l"!IHn-3-CH!(«lMHH£ 1 1 1
-I-O" IS01'.« 1 I 1
lil-VIH'HMl-M-PM!1!1*-!- 1 1 1
fa\ pen-it.)!,)!. |f \f mil | | |
UM N0|i>4 A1 k0Mt | | |
iimpnyu tytyt ^"U't | | |
ijut uniii) qi>T| >»!!•[ 1 I I
l'H""NH "M1P191. 1 1 1
nuiui)UH »(f»i | | |
«U9?lll»lfP f'lCfl. 1 1 I
i"*!"*1* rift"»tiic «•!!•! i i
nut ungij F9tTCK?f I*!MIP 1 1 1
huiMo|i|f IOL fCK O^IM^HP 1 1 I
niituwu ci'ISIII'.fP riKH™. 1 1 1
HMpnvi| | |M j | in i).|
I|.»«MH | |A )l.| M II)
ijuuryii | 10 J 1 TON) J 1
l''»*»« I 70 JH |
I.«.»OM« | 1 1C! JO .' 1
1 1 31 I I
I I !0 I I
I I l"0 1 1
1 1 (Oil
1 1 1*0 1 1
1 1 «0 'M
1 1 I1) .'M
1 1 40 1 1
1 1 l~) ) 1
1 1 1
1 1 1
1 1 1
1 1 l!f
1 1
1 1 IH
1 M 1 >2
1 1
M
| II -f h
»«i V) J 1
1
1
01 !0 J 1
1
1
1
1
1
1
1
1
?•) } 1
30 J 1
"» 1 1
?ft .'M
11 .'M
10 ! 1
10 i 1
3« J 1
3" ) 1
3n ) 1
?0 1 1
}" 1 1
}" 1 1
^ J 1
:n 1 1
!n 1 1
«" JH
\M .'H
inn 11 1
1
1
1
1
1
3'« 1
1
1
191 1
1
A -12
-------
5115! CM WT55.
C»H N«:2!'.."0
?VPIf HP!
• OCftllO"!
-
Hi-" £-"
5*11 u im: C-M i?w CY IUM
C«W!WI 1 1 1
fd(r;iM | IJi'yy) 1 i!.1^ 1
CHfO«l'»t 1 1 1
fOUl 1 III
vll IV* vr iv.
1 1
li'nAn | l*lr"V) I
1 ?«• 1 1
1 «« 1 1
1 1
4i<«w | noAAn |
1 1 1
1 1 1
1 1 1
coins
HO*
I'.'!'
r'.H'.fi
HICHI
J?i>55H'S
C[l ipllf
ill'.I*
soi'ivn
IH'lll'.l
111
MS M'»IM"I1
KIMS ffll'W
ff^'.HIC
>«'!'.«
KHUI'JH
nf \m\IU\
t'.1? 'I I
CO! IS
If."
1C '
I"-' 'I?!'".
f.V »UI.5C.
HI1 WT
HI' «.!
O: ??!'-'«
en (ulnn
51! '.»P
1IWIIUH
IIH
„.,
l!9
Tl
I
IH1 I
I
I
11 AMI) |
I I
;M i
BnA |
:» i
M i
I!?? I
i ItAAA
"2W
I'M 1
121
IIQ |
:? i
oionni) |
A -13
-------
snt: cvi
i*
5*1! 1 1
1 unl 0 .
p'cir.
MO:
I'.TMIOH!
in1.;
»*MM'I'J1
MMC
pi nil Hit
CH'.nfM'l
f 1 '."." I M.
MII'Ml HHF«C-!N
Nimit HIim-lM
(•"C
rc<
5'
4"?
•.OAAAA
I!n0
W)
KH f"' » V.U ?'.C'f «ll 141-llf V.\>. I'MP »U l4!-f»
OK 1 lH CV lew (-11 !','« fV ICV !•• i :•• i j« i
! 1 1 !l"" 1 '.""0 1
IIAA1 | OQAArt | TS'A/1'J | HAAAA | 1 IQ^AAi^ |
1 1 1 1 1
1 I 1 1 I
I 1 1 1 1
I 1 1 1 1
!4 1 ?« 1 » 1 4!»1 1 II! 1
1 14 1 1 JI"" 1 4" 1
??!'>« i i^y'o i ww \ J:O«""D i levw) i
I I ."u™ I J!"n I I
I ll"'") I HOC I Wl 1 44«?1 I
I I I ?95 1 l!° 1
1' 1 ?IO 1 ISO 1 I0'°0 1 M"0 1
A -111
-------
APPENDIX B
FACILITY RCRA MONITORING WELL LOGS
-------
MONITORING WELL LOG
DRILLER C-'"-- COAST CORING
ALTITUDE *7-5' XSL
MONITORED UNIT 60 FT SAND
DATF IHflTM 1 FO 5-^l- = 3
QEOLOQIC DESCRIPTION
Gray CLAY
Fine sar.cy SILT
Gray CLAY
Red brown CLAY
Gray CLAY
-silt layer at 21'-21.5'
Sandy SILT
Total Depth 75 ft.
SAMPLE TYPE
QEOLOQIC
SYMBOL
^
Y/
\
• , '
LAKE CHARLES FACILITY Woodward-Qyds
F°" CHEMICAL WASTE SCALE.
MANAGEMENT INC. NOTED
K
U
Ul
u.
2
X
a.
Ul
o
» ,r<
"40"
* 5>j*
» 60,
- 7S-
WATER LEVEL
T
i
i
r\i
A3 BUILT DIAGRAM
1.27 f
Consultants ^
, 7 in.
•t
!**•"•
.* • *»
' D- , . '
**•••'
*" * "
* • • ' **
,* ' ' * '
4. .? a ."i
•*'*-. •
".* • • c
* o* '
o , ./ .
*•*•".
0 . » '*
.*'*•* '
J • o . •
1 . •' ' '*
• ••*'."
1 • ' "
.'•° V
* • • "
• . ' c.
p$
r^
k
i
execute f-K/Hb oni.J.~2-?-&$r
-__ —
~_r:
• * ' • •"
o .* . -
o." ".',
o t **
-"•"*.,
• .'o- •
. • , .0
• * *o •
i » *. V '
• o" • 0
'c *." o
* • O * " '
1 •
' . ft • *.
• • .' o •
O ." o'*
•o t .' -"
, ' ' * <
>..'* *
• \' t •
0 .' . "•
•*"»;'"
i
»
ft
Cement/Eentonite croui
4
4" I .0. PVC casinc
a
,
Eentonite seal
Coarse Sand Backfill
PVC screen =10 slot
Backwash Valve
t±/^ —
MONITORING WELL wcssie
No. '^1£28
-------
MONITORING WELL LOG
DRILLER =~ED & MOrP.IS
ALTITUDE -"-7.61 M£l
MONITORED UNIT CO ft SA:."'
PATF INSTALLED 5/13/54
GEOLOGIC DESCRIPTION
Gray & brown CLAY
-w/silt and sand lenses at
25 ft to 30 ft
-shell layer at 34 ft to 35 ft
Fine SAND
-silty clay seams
Blue CLAY
Total Depth 80 ft.
SAMPLE TYPE
OEOLOOIC
SYMBOL
f/
UJ
Ol
Ik
2
Z
o.
UJ
Q
0.
> 1 5«i
* 4 E-i
"TS"
^90"
WATER LEVEL
i
T
i
AS BUILT DIAGRAM
_
1.78 i
\ 10 in.
•t
,"*.'"* *
".'.' ***
• o'. • "
* ." V°
>•.**."
' -1 ". &' .
°. ' o .
• ' • '
**.*'"
'o •
O.' • '
0 * *
o . . •. '
. . o
• • *
.'•'•.«'.*
• *
• * ' c
li
*.'.'.•.'.•.•
LAKE CHARLES FACILITY Woodverrd-dycta Consuttants ^7
'°" CHEMICAL WASTE SCA(-£-
MANAGEMENT INC. NOTED
r^^f^\lL^z
"-_-
m-—.
. o ' •' •
o ". .+'
>• *"°'
."'•.*"
, * • •
3*_ '_ •
V-'tv
,'• •«'
*.o, '
• * '• t
1 -o'-.
•'I'-'-'-'liilil
yyjffti
•:••:•:•:••:•:'•
Cement/
Bentonite Grout
4
-1" I .D. PVC Casing
Bentonite
Pellet Seal *
PVC Screen
M r\ TO ^ 1 r~j t
Sand Backfill (NO. 2)
4
MONITORING WELL secsaie
No. p-1E F'gll27
-------
MONITORING WELL LOG
DRILLER ----F COAST CORING
ALTITUDE -9.2' MSL
MONITORED UNIT G - ft S.-J;D
OATE IHBTiM 1 Ft? 5/7/82
GEOLOGIC DESCRIPTION
Red and gray CLAV
-w/silt layers at 11-18 ft
Gray silty CLAV
-sand layer 27- 3£ ft
Gray CLAV
-iron nodules
-slickensides
SAHD
-w/blue clav at 77 ft
Total Depth 77 ft
SAMPLE TYPE
NAME
LAKE CHARLES FACILITY WooctwW^C
r°" CHEMICAL WASTE SCAt-£
MANAGEMENT INC. NOTED
OEOLOQIC
•YMBOL
I
t y
* \
S v
\
UJ
Ul
Ik
2
Z
0.
Ul
o
0.
» 4 5'4I
» 4f
» 41
WATER LEVEL
c •
i — •
•=?•
i
o
1
A3 BUILT DIAGRAM
_
0.72 f
i 7 in .
,*o • •
• - o • '
a* • 0.
* *• v°.
• o * _»'
• •*.*',
° ' ' *
. • O • ' •
* o
« • »' "
•>';**
* '.' -°
• . o * ' '
o ' ' »
'o • • *
•:•:•:•:•:•:
x:::::;:;:
_ —
-2"
o" - 0.
• o « .»
. . 0 •'
• • o •
c s" .' ' '
' ' -O '
o • « • «
'. * •
• o
*• o . *.
' ° *
'*.*•*;
• O *
**'.-'
'-*.''-'-''
?$$•
"\
H
Cement/
Bentonite Grout fl
4
4" I .D. PVC Casing
^Top of Sand Fill
PVC Screen -|
No. 10 Slot
Coarse Sand Back fi 13?
^•Backwash Valve
' 41
Syria Consultants © MONITORING WELL secVsie
c»ec«to |T-
-------
MONITORING WELL LOG
DRILLER SOIL TESTI51G ENG . , INC
ALTITUDE +S. 3' HSL
MONITORED UNIT -^:':~L SA::D
PATF IkSTAILED 11/30/79
GEOLOGIC DESCRIPTION
Tan-light gray CLAY
-calcareous nodules
-sand pocket lenses
Ul
a.
>
t-
Ul
JL
2
«
r
I
Tan- light gray sandy CLAY P"*
-very sandy |
IE
Tan- light gray CLAY
-sand lenses
Tan-licht cray sand-,- CLAY
'
Blue-gray CLAY
-frequent sand layers
-very sandy at 32'
Total Depth 33'
I
C
«_.
0 O
o o
S2
s«
1
I
1
1
LAKE CHARLES FACILITY Woodward-Oyda
F°" CHEMICAL WASTE 5C41-£
MANAGEMENT INC. NOTED
K
Ul
Ul
u.
z
x
H
&
Ul
o
0.
,.10.,
,.20,
» 30*
"40-
» 4
» ^
» «
WATER LEVEL
w
f— 1
c
1
T
1
~*J
1
^H
A3 BUILT DIAGRAM
1.73 f
Coneu^Larrts %
•p
t
; » « • •
»'.;.'.'
;«. '.o'.
'. .»_• .-
r ' c ' .
• a ' \ '
. •' o .
•'".".•'
°' '. *
'.°' • '
' '. '• °
*•'!'' c
•'.-«.'.-
, ' o • .' •
.*• " '
»' -°'*
0 • ' '
. . f- *
SI
— T"
77_-
• —
• \o' , •
* -0 • • .
" °
*a . * «
'••'.'<
*<>•»"
•;•';•
!''.-^.
> * '.* •*
• .'a •'
, • i* C
* r • " .° *
Q . V '
-'• "°
**'*•».
•.'o'/ «•
WXv'v
S?. .".'
£
>
Portland Cement
3" I.D. PVC Casing
°*Tl-'A~
NO. _B,1_ '«« 8
-------
MONITORING WELL LOG
DRILLER FOV.-IER DRILLING CO.
ALTITUDE +5-4 '••'•SL
MONITORED UNIT CHANNEL SAND
DATF IMflTAl 1 FD 4,-'7/30
QEOLOQIC DESCRIPTION
Green-brown sandy CLAY (CD
-slightly plastic
-fine sand
-filled worm holes
Bluish-creer. SAND (SC)
-interstitial clay and silt
Elue-greer. SA.-;D (S?)
-dense
-fine grained
-interstitial silt
Total Depth 84 ft
•AMPLE TYPE
ma
OEOLOQIC
SYMBOL
f-f'
&
H
UJ
UJ
u.
z
z
a
UJ
0
0.
»:o-i
^0-
»6C«
N.S^
» «l
WATER LEVEL
• t"
•^ £
T
•
_i
i
i
AS BUILT DIAGRAM
2.4 f
t
I
. 4
*
» •
* (
0,
O
0
O
»
• c
> .
fl*.
d
• •
6 i ". -
f \5
• 0
•
.
D
", (
, •
O '_
•ffi'l'S?
"*"' f^
LAKE CHARLES FACILITY Woodwerd'Oyd* Consultants ^L7
F0" CHEMICAL WASTE SC*L£
MANAGEMENT INC. ' NOTED
• »ot n-dC*£ OAU.2.-ZJ-**
CHtcKtD •f-|£/}ft om.£-J7-£>C
_- -
-~-
_~^_
• o ' ', '
. ." o .
° '. "
• o- , •
• '. *• o
* 1 •
) °"»*
. *o-; •
.*•*" '
V"-'0-"
o •
S?S'W
11
Cement
Bentonite Grout
2' I .D. PVC Casinc ^
Ber.tonite
-^Pellet Seal "
FVC Screen
No. 10 Slot • j
1
Sand Backfill (;:o.:'T|
i
r
1
•i
4
<•
MONITORING WELL wcssie
No. Nnv-i "^'^
-------
MONITORING WELL LOG
DRILLER GULF COAST CORING
ALTITUDE +9.3 MSL
MONITORED UNIT CHANNEL SAND
PATF INSTALLED 6/2/83
GEOLOGIC DESCRIPTION
Dark gray CLAY (CD
Gray CLAY (CL)
Red CLAY (CL)
Gray and CLAY (CL)
-shells at 21'
Gray to tan o^_.D
- fine Drained
-interstitial silt on
occasion
Total De::th 83 ft
SAMPLE TYPE
OEOLOQIC
SYMBOL
' s X
Ul
Ul
u.
z
X
a.
Ul
O
0_
-40*
"60"
WATER LEVEL
• in
T
i
r~
i
AS BUILT DIAGRAM
7 in.
"
L.86 ft
C
- *
O
'o
c "
_<
Mt&
LAKE CHARLES FACILITY Woodw*ard-CJyd» Consultants ^7
f°" CHEMICAL WASTE SCAL£
MANAGEMENT INC. NOTED
e-"«V ."f^te "iVl-iC/f
L- ~
-{j-
g
• . o • '
:?:•'.'
* " t . o
ffife
Cement/Eentonite
Grout
4 ' I .D. ?VC Casing
Eentonite Seal
PVC Screen
No. 1C Slot
Coarse Sand Backfill
*
— Backwash Valve ]
MONITORING WELL Bessie
NO. MK-2A "g*2
-------
APPENDIX C
CWM PETITION FOR REGULATORY MODIFICATIONS
-------
Kay 13, 19t6
Tli* Hccorable Lee M. Tfcoeas
Adr i zis t ra t or
U.S. Eovirciaectal Protection Agency
iCl H Street, S.V.
Washington, DC 20fc60
Dear Mr. Tbosat:
Is acccrdance with the Adritisl rat ive Procedure Act, Waste Mana gecer.t,
Inc. submits the enclosed Ff.iticn for codification of 40 CfR P»rt» 264
acd I6S, Sutpart F, which s^ecsfy procedures for groundwaler Bonitoring
at hazirdcus watte facilities. Waste ^ar.ageTteot ii filing tbit Petition
tc offer ccr.st ruct ive approaches for correctici itatistical, procedural
a:.*: i::e:.I:;jc S..DT*. c :.T^:.:S .z '.ie f^;kl:z£ re ^'.: rt- :*'.:.
T.'.e key rreblerj in the E?A rZrJ( grousd^ater re£ulat:oos asd juidizce
dccu^ecti cer.ter on: (1) lie u>e of iavalid statistical testiaj rethods
ar.d parare;ers which falsely predict coatarinaol leaks iato grouidwa ter,
and (2) excessive sarplir.f a = d testic| requ-.rececti for deterriruni
wtether or net leakage bas occurred.
ID seerir.g limited regulatory relief. Waste Mana|eaent it proposing
substaotive change* io:
1. Statistical Testing Hetheds - Current EPA regulations only permit
the use of variations on * Studect's t*test--tbe Cocbrao's
Apptoucj 11 on of the £ebrecs-Fisber uoder Fart 26C, and other
t-tests such as the Average Replicate test uader Part 265. Tbese
tests yield artificially bigh levels of error (ibowiog oon-rxistent
leaks), vhicb in turn trigger additional ncoitoriog it tbese
facilities. Because tbese tests require the comparison of data for
which botb an tpgradiecl acd dovsgradicot oean and variance are
assumed, they are inappropriate for comparisons of sicgle down-
gradient values to upgradient pooled Beasureccats.
Recognizing EFA's ceed fcr reliable data, our Petition proposes
other, core flexible statistical tests vbicb can better aeasure the
nitural variability of groundwater. Applying the concept of toler-
ance intervals, which were originally developed for application in
industrial quality control, applied to selected conitoricg data would
produce acre accurate testing results and a statistically rigorous
nrlbod for the control of groundwater Quality.
2. Indicator Parameters - The current indicators are unacceptable
prones for costannalion because they fail to reasonably predict
any real instances of leaks. The Petition advocates replacing tbese
paraaeters vi tb the volatile organics scan. Tbese cocpoucds are
relatively sobile, frequently present in hazardous; waste, and
detectable through nacdard laboratory analysis.
-------
P«|t 2
Letter te HOD. Let
VSEPA
B.y 13, 1986
Ar;tsdi» VI II P»r»ne'.en - Stttpliot ind letting o»er 360 indiridu»l
CCL j'. H.UCLU , e»cy cf »ajch «re oticure tod/or nocAe«tur»ble , it «n
expesuve «L£ unproductive titk. The Petition prcpciti •
two-ft«ied i;;:cjch de>i|r.ed to: (1) reduce the cumber of
jJiirelen to cc:nc:de v;th ccati = io>ati cost lately to occur ID
letchite, ni (2) to institute * r.clti-t iered totict procedure
which tr:f[trj further tettir.g \i ipecific pcilu*. ire detected
ty the \i:::tl te»t».
"ir.ijrrer.; , Ir.c ::-t: *.c ir.'.'.-.ate • ;rcsjci;ve -:r-.-.r.f i'-ii-j-e -i::h
vili «r;ecit ;c.» lv resclve these iis.es. Js -articulir, Wute f.inter
» «c_x;cui '. o r.rtv v.-.h yr-jr stiff to d-.scuji the iiiuel contained in
our Petiticc. We look fcrvi.-d to your reply.
Sincerely,
Ctry A.
Director of Ecvircccenttl Cocjlutce
CAV:»1
Inc.
-------
VAST! ."AVACt.'avT , :vc.
• PITITICV 70 MODIFY
RDiC RIGIT>TIOKS:
A S
Tie existing RCF.A requjrer.er.ts governing groufdtf.er ccoitorisg practices
at hazardous waste facilities (40 CfR Farts 264 ted 2654) contain aajer
statistical acd scientific ibcrtccrings vbicb scbieve little eaviroa-
swztal irrproverer.l acd ispcse needless «nd expensive burdcei oo the
rt(u}«ted conr.unj ty .
Thor prcbltci cctrr cs the use of icicruritc ititiiticjl tcitiot
cxlbodj jnd cc:l<;.:zicr ir.d;fitcri which Itlitiy predict lt»V.» into
grc'.r.i. j-.rr i;i txceu:vr »«r;;:.-.i ird tutitj r«<;uir«.-t£ti vtic
f '. i '. : • '. : '. • '. ~. n : : r. t * t : '• r i « - i?A'» dnit «.-.: crcert:: ;u;car.:e
s.;;cr*. s '. i • taje cl v ^ t ;;.~es cf St'j^e«t's t-trit •• the Cochrjn's
^7;rc»i-.«::cc e'. t^.e Jt hre:s-f :».w.rr teit «cd tte Avenge Replicate
test. jets leiti frodtc* «a «rt:J;c:»i:y high ouiber of f«iie
j, i.e., they predict leikt wheo none bive occurred.
Ritber tbJO coctinuir.f lie uie of cetbod> vbicb produce uoreliible
d«t<, tbe ff.iticn prcpctei the u»e of tltercitive, core flexible
• tatittirtl teitt vbicb c
-------
> PE.JTKV TOR RIGVLA7CRT RIUET OS
FCRA C?:VS-.A7ER .-.OS170R1XC RICLOATJO
IX7RC5l.'C710S
Pursuant to Sect;ct TCCi of the reiource Ccaservat :os and Recovery
Act ("RCRA") and 40 C.F.R. Section 260.20. Viste Kir.a(»eot, Inc.
petilic&s the Er.vircirestal Protection Aieocy to codify key
prcvn:cc> c! FC?.Vs if c-jr.dvue r aocitenat reflations.
5; ec: i i c <". 1 y , i^tte ?*.«zi(e=e^t. propose* cb*&|es i&:
" •.t»:ir.t
v.j'.t .^i^jge-cr.'.. !r.c. t*i ccr.c.c-.ed t '.torcvt- reviev oi PCKA
iH\jli'.:c:j »r.i ic'.i-.cd ecfcrcerrat ^ricticei >:d bti coaclutfed
th»t |.-ovjr.Ck.»t tr r:r.-.ier-.:j reqv. rczer.ii sfcciild be reviled
iTC-.eisitely. Cjrrer.t re(ul«ticr.i require private ind federjl RCKA
htztrdsus ».«jif {jc:l:ty c^itrv/cftrJXcrj to ic^lezest ocnitorir,{
prc[rirs in order to delect ccr.'.irir.icit reletied to troundvjt.tr.
Vote ^ ire critically flived. These procedure* (roisly
over-predict ics'.»ccei of jroundvjt.tr coctteiDitioc, fill to protect
tbe envircuest, *;d ire of little uiefulcess to tbe reflated
cecrucity and EPA. Our proposed chicgei ixo it correcti£( tbete
fljvs, vhile crettint t core sound scientific buis for jroundviter
nonitoriot.
ii. SIAT;STICAX IXST - STVDE-VT'S T-TEST
A. Viste ^< r.i g e*:er.t' s Interest in the Proposed Action
Currently, most KCF.A owcer/opersiors use tbe Cochrao't Approxi-
otion cf the lehres' s-fisher (CA£T) version of tbe Student's
t-leit to sKtssticilly detect sitcifictot increise* in (round-
v»ter iodicnor pirtreters. Tbe principil problea viuh tbis
test is tbit it produces «o artificitll; bi^b. ouaber of false
positive results because it is b»ed on replicate sacrples
vbicb clearly violate tbe assumption cf independence tbal is
critical to tbe validity of tbese test statistics. Such
results force an o*-er/opentor to btjin an erpensive atsess-
oent ex>oitoricg pro|raa even tbou(b DO actual leak_a(e has
occurred.
-------
fi . P. c r u ? »* r ry HjcVyreund
Tte irttrjn status grou.idw«ter coniloring regulations (at 10
C.7.R. Part Jt5, Sut-psrt 7) require tie use of a Student's
t-teit «'. the C.C1 level of si(=ificasce to detercine
statistically significant increases ia grev^idwater
cecta;;r.a'.ics indicator para.Tt'.ers -0 C.F.P.. S If5.93. This
reflation dees ret specify • particular t)7>e of Student'*
l-le«t. lo centrist, tte F»rt 26« RCRA ptrcit requireser.li
require tte ute cf the CUT Studest'i t-teit it the 0.05 level
ef tiir.:'. icitcr unleft • stiver it iricted by the Re|ion. ....... , _ , /.-,' .. .]
ic ;frf:r- •:;:: s-.1: :••.::»! tejtj ^.::;-. ::'. ?r:cr
«r;.*;v»l c:' :r.e -.ti.-.r.ii Acr.ir.:$lr»ier.
• t?A ihcu'.d cer.jidtr esubli$hi:g tolernce i:ten.-jlj V«»ed
cr. tr.e d: « t r : t'Jt: en cf ctiiurer.e.it i otliiced for u?f,r«£: er.t
wel!>. Th.e l;ke!;hccd of dei-T.jrJdjer.t veils fjllicj vjthin
these ic!er«r.ce lir.itf c»n be cccputed through itindird
tiitifticjl evjluii:oo netbcds ori|in*lly developed fcr
quality control profraa&.
The S'eed for the Pre?o»rd Action
• The prcpcsed action is required became:
1. Par*. 165 interim itatus regulationn do cot specify a
particular l-leit. Many ow-ners and operators of
haiirdous waste facilities cov use the CAJF t-test in
ar.l:c:pitico of eventual coTpliioce vita the Part 26£
pereittini regulation. This test is cot a legitimate
applicaticc of statistical oethods for the purposes EPA
intends to use it.
•
2. The flaws associated with using the CAEF t-teit to
evaluate grour.dvater cocitoricg data are well dccuaeat-
ed. For exar.ple, aa EPA contractor conducted a series ef
siculatioos which revealed the difference between the
assessed versus the actual false positive rate of the CAJF
t-test |J73 Associates, "Evaluation of Statistical
Procedures," December 22, 19B3). These findings reported
false positive levels ranging froa 10 to 50 percent for the
CAJF tens CD the first eonitoring round, and fro* 2-2 to S3
percent by the third round. L'sicg these actual false
positive rales, after * few roucds, every veil at a typical
facility would fail the test, even though no leak baa
-------
occ-.rred. Althi-.-gh tit sirulatica study i« instruct iv* ,
theie retulu are directly ripened frca statistical
theory due to the specific violation ef model assumptions.
Tlis errcr.'in turn, icrcrs PCF> facilities to
ccrpltx a;d colly astesir.ezt ocnjtcric|
Tie purpose cf de'.ectics eciilcritf,, tbe first state cf
icven:: status r-oc;ict-.r.| , •. » to deterrr.ne if > ccotaii-
nar.t (res i lied di»;ctil f«c-.litj hn leaked icto «n
u:derlyict aquifer. Eectutc the CAtF t-tett (alitl?
i«7ert» leaV.5, it ftvtrely licitt the utility of detec-
tion rci-.-.cr-.r.j. At>e«s=rr.t c:nilori&l i> automatically
trjffered, ncce the CAIT t-'.t>t v-.ll incorrectly indicate
ItaVt at r::;tcrict. vtlli iclely as a function of tot
def ifo, net cont»rrin»tioa.' •' ••.''• •
•.:.« '..r;c-5 jrcc'.erj •-::- •.>.< C.^IT '.ell ,e j., ".r.e r.u.-ifr
c: Ja'.«e ;ctit>vc>) azd ;tr=;f.ee the u»e of another t>7e
•: '.-test -• '.he Avtrajt ?.t;'.icite (AS) test. lu
;rc7cnc£ to allcv thit cod-.fitalics, ETA itated ...
The A3 l-lejl ii a renewable teft for c».tier/oper-
aicra to apply lo their inleria ttatut detection
ac-ner-.r-t data beciuie il reeovet t_h« exce»ive
vei(bt that the a:alyiical or tplit tackle repli-
caief have on ihe bacVirouad variability and may
eel; reduce tlaiittically-cauted falae potilives.
The evner/operator e»y perforo the t-teit ef
chcice, but the rtiulti eust be ;re>ected acd
actioa laken bateti en tte reiulit of only oae iy?e
cf t-test ISrait TtCD. Aut.u»t 19BJ, p. i-2].
This ttalemrnt ttrcr.tly tut(estt that UA is {averi&g
or eovir.f towards treaitr reliaace on the Ajt test. This
test elicinaies the prcbleo aisociated vith tbe assuarptioos
of independence, but it still assur.es coeparison to a
dovn[radieni set cf data v.th a ocas aad standard devia-
tion, whea in actuality linjle dcvT.fiac'ieol values are
cczpared to tbe upt:a£:tnl set of back|rocad data. Tbus, a
yroblee persists vith the AA lest in iedicatict coctaKin-
• tico based on a set of false assue?tiou.
Tbe Student's t-test is not effective for indicatiei
changes in trousdwaier quality due to conlaff.inact tniralion.
This prcblen canaot be corrected sirply by switcbint to
another test such as the AX test. Talse positive rates
are hifh because of the lar[e nucber of individual
cospariscos requited for each ncplitf event. Multiple
con?arisoos iCkherently creale a bit,hcr rate of false
positives solely as a result of test design.
-------
SucS prcb'.esi v;th the itatittieal teiticg, hovever, c«n
be corrected by telec'.ed rcvmer.i to tbe RCRA rc(uSalice>.
Specifically, the ccrrest statiitical testicf rec,uire»ecti
In Ftrti :6i acd I6i thculd allcv (or alternative
approachei which acceust for tbe tstural variability of
gr oiifldwa te r.
Tte focus of cur reeonr.eadatioat it oo the operation of
"toleta:ce ioten.'«lf," vbicb itltrsice the probtbility Uiit
i tew dcv— |r«iient obtervfvioo it coaiiittnt vjtb crptclt-
lic:t btied CD • lirg-r ftc;le of icdepec^cet uy|r»(Jie:t
ctjiu:t-ccl> . ^"itn the rcancrict ;>riceVcrs in qucttioa
t»vc i :cmi diiirib.i^ca, Ctunita tolcrince liititt
ijryly ;:.::j^
jc'.-',::i :j retire:. ^''•t~ '.-t lieirec cf '.r.icatico :i
lot tttr. bC, (i.e. i'.\ or cere cf the cita are above *.he
cf.eclica lis:'.}, ~'l'.a tcitriicc ioterrals provide a
F«rtscjlarly attractive tciu'.-.cr.. Vita vbr percent of
ncn-detects exceeds iC*., u>e of tcleraocc iDlervalt bated
on the ditcrete Foitsoo dittribulica arc recocneaded.
The critical feituret of tbe approach are tint: 1) the
ttatittical cede) it coaiitte^t vith tie practice of
ircur.cVattr rscitorir.g, ntr.ely ve are coerparict • tinjle
cew do^-jradieat obtervition to a larter hittorical t«»ple
of uptradieat obtervation, aod 2) tbe eboice ot tpxcific
tolerince icterval (i.e. Xorcal, Lojoomil, Delua, Poiiton
or cor.;traretnc) can be activated by the empirically
obtervahle dittributioo of tbe coaitoriaf paraseter io
c,ueition and not arbitrarily selected at • *ic|le decition
rule ucder vhicb all data, re(ardlet( of the ipecific
characteristics, Butt, be tcrutioix*d.
Models that ate bated oo tbe Pcincn dittributioa, for
example, bave beea ttov-o to be veil suited to isolated or
rare eveatt data, e.g.., r.utatioo frequeociet and radio-
active cou£tt vhere ritks are tenured ID parti per
billioa. Tbe Pcittoa dittiibutioo i* tbe lutitinj fora of
the bicccial dittributioa vhich can take into account t_he
pretecce of as event evea vhen the probability of occur-
rence it extrer.ely tcall. la evaluatinj troucdvater dau,
the Foittoc dittribution offers sucb advaot_ajet at:
-------
1) testing for tbe rssdor.r,ess of detectable levels of
volatile or|an;c cccpousis 10 upgradiesl veils, 2) develcp-
icg internal estiEaies viicb show vhen the ouaber of parts
per billion el a specific corpoccd in • cew dov-agradiest
observation are coexistent vjtb ratdca ezpectatioci, and
3) allowing possible cecparucr.s cf upgradie:t cbservavicrs
!rc- difftrtri files so :tti i-.--.ljr mes can be cocbir.ed
to er.lart< a nrple of upirxi-.ei*. or back[rcusd ob»erN-as.icr.s
«ni tbereby iE?rov< the precisioo of tbc
V'as'.e ^ar.» te^er.t' s Interest ia '.be Prepcsed Acties
Ccf rer.'.ly, federal i^d private owr.er/cpe rat crs cf RCR> intend
c i -.:-.: • : -: -. ; < ; .- r 11 g ;t;:-.:.::.: IT.;: :.... _ ; e ; . -
Theie -.ti:cj-.:r ;>rt=etert are supposed to serve as surrcgi'.es
for broad classes of ccr-pc-r.ds.
The indicator parane'.ers, particularly TOC »sd TOX, ha»e been
shovn to be ineffective ccsiters. These paraceters bave
little correlation to the presence or absence of ccntaaination
frcr. the waste unit, causing cor.fusicn and unnecessary
enpense, while failing to recognize actual grousdwater charges
vbicb nay be occurring.
P.egulatcry Back|round
Part Ifci regulations require ov-aer/operators cf interia status
facilities to routinely nocitor for a select set of indicator
paraceters -- pH, specific conductance, total organic carbon
(TOC) and total organic halogeas UCX) 40 C.F.R. 5 265.92(c).
Fart 26<> regulations, in contrast, pereit i-be design of * set
of site-specific paraeeters corresponding to a facility's
vaite streaa.
Tbe ligited Relief Requested
Tbese four parar.etert should be elieinated at indicators. The
concept cf indicator paraselert it cot without cent, however.
Indicator parameters can greatly reduce the cost of Bonitoring
and can detect initial pluve cigralion before environaental
problees occur. Indicators should be selected on the basis of:
(a) presence in the waste, and
(b) nobility.
-------
Vhere present, volatile erfanics are nore Bobile than stost
ether or|»r.;c ccr-cur.il . Selection of • sublet froe this
I re up, such ar.::atioa and trifter usoecessary
assess:eit ecr.itcriit . In revievitg field data frco over
30 Clr.CLA ar.d F.C-.X 'si tes , an IFA contractor reperf
cbserxed: the' trreliabi lily. of-TOC »od TCX-tc indicat-iny -
crr.ti-:r.aticr. <.:-'.•--':, R. H., and Fitisicrcns, C. K.,
"f'-r. • •-•-?• ~va '.-!'.: cr cf ?C?.'. Tr.diotcr Para-fters."
:••:-. -.-.;. : 0 : '. :• ;.rs: ^i :.;;::•. .-^. •.:.:. r. ^: :.:'«: tr. ; t :-.
-.•::-:\'.:'.:t-; , .•::. :.-.ii »'ater Veil Asi :c;if.cr. ,
'
7^.:s re;:rt cer;ired charges in the ioiicater par«=eters
vith charges :r. cotrmincusly oeasured analyses tnat
should have beer, detected via tbe indicator paraoettrs.
The results rev»al that the fcur parameters successfully
detected cor.tariitat icn jr. less than 50 percent of the
cc-r«r-.»cri • lo particular. IOC aod TCX correctly
predict ccr.ttr.icatioo only 3S« and \1\ of tbe tisw, ^-hile
obibitict false positive rates of I-T, aod 48^ respect-
ively. Such percentages of error offer stront evidence
that the current indicator parameters do cot function as
effective BCBiiers.
such bi|b false positive ratei »s detereined by
Pluzb (at approx-.r.itely SO percent), even a second test,
dcce in order to verify contamination, will falsely show
that cent acir.a t i ca exists in approximately 23 percent of
tbe reasureeents . If these Deasureeenls are independent
(as few as four tests), lestisf, on averaie, will
ir.dic*te conlacication even vbeo tbere is none.
Since the Part. 2iS indicator paraneters are not effective
in assessing potential eitratioa of leacbate, tbere is
clearly an itsediate need for an alternative, core
systematic tecnitorici >p;;oacb vbicb could detect a lar(e
cumber of checicals. Recent CPA-tponsored research bas
evaluated the usefulness cf one such alternative approach
for eonitoring organic ccntizinatioo io groundvatez which
involves the use of volatile organic scans to screen for
possible leaks into grou=dwaler. (See Plusb, R. H. and
Pitcbford, A. M. "Volatile Organic Scant: Implications
-------
for Grou.Tjvit.tr ^csitervei," V.S. tPA, tnvircnmental
Kcr.itcr ::g Systers LiVc ra'.ery , Las Veias, Nevada ,
October. IStS; «cd, Flu=, R. H., "Ditpcul Site Mon-.tor-
ir.j Data: Cbservitier.i and Jtratejy Icplications ,"
preitr.ted to the Eeccnd A,-.£uil Cacidian/Ajierican
Ccs'trer.ce en >!> ircifilcgy , spocicred by Alberta Research
C:cr.:: I /Sat : era! Vj-.tr Veil Allocation, July ISti.)
This Pel-tic: proposes tcasaini for «el«tilc or|ioic
ccepcur.^i, brciuit of tbfir frequent prutoce and bifh
ttfttt ef cctil:ty :o irousdw«ttr. The tbove EPA »tudiei
ccr,-::c<; dubitisces in the
grcur.dwuer in the v-cisily of these tites. Al'.houtb the
'e'crjr rer.ce' ci ir.di'?'-. 4u«T cr[itic ccnttzistsli Jn-tb^'' • '•
( rc-.r.j;-. t'.r r v»i f.;|My vir:atie. votililf Co.— eucii vert
'. ...... i -••' «..-•.-•'-• -^-- •-.'••r --••r:f..' TO:*. «-:-•-•
';r:.r:. r .:- ;j :jst.ri.-. r^'. c:-. ;:p.r.:j, i r; - t:.". :i :'. : .
;•; ; t; •- : c:c't s . ;j!ti ;r. fre;.ency of tfe;e:'.;:r. ;'. Uj
»:•-«>, 5 of t!-.f I: r.iil fteq-jetlly detected ccf.*i:n»r.-.»
<..d 1J of the top li were ve!«tile co=pou=d>.
In about (^ percer.l of the tiles reviewed, volatile
ccrrcur.dj were t.w.e moil frequently detected clasi
of ccrpour.ds. Mere ir7crtantly, the potential for
volatile! lo icdictle ccotafinalion appeared to rise vnh
the level of cost aeinatioo. l*hen only two cbeaicalt or
fever vere idectified at a tite, volatile! predoainatcd
ij percest cf the t;ee. Tbe predoeioaoce, however, rose
to 90 percent when tea s'^bilacces were delected, and 100
percent vhea 23 or o>ore subitaaces were detected.
t. Eecause volatile oi|icics are hi|bly detectable, the
alternative approach prcpoted bere would replace the four
ir.dicalcr parameters vitb selected tcans for volatile
orfanics. 7bis approach would conduct detection tonilor-
ing in iwo tiered phases. Tbe first ttafe would screen
for the presence of volatile compounds in tee aonitorxnt
sacples. If positive eeasureoenls are confimed, a
second rouad of sarplet would be analyzed for those
adc'iiiccal paracettrs vtjcb were disposed is the site and
are present in the leacbate.
S. Tbe advantates of usir.| volatile scans for (rouadvater
nonitoring are:
volatile ort*nics are hitb vclune and very mobile
compounds; if they are not detected by preliminary
screening, then the presence of lest abundant and lest
•obile compounds in the {.roundvater is unlikely;
-------
• the volatile scan it *or» aeaiitlve tb«a the •ethers
fcr TOC and TCX indicator paraacters by several order*
of aa[nitude;
• tie analytical procedures for volatile cocpouads ire
e;re sophisticated asd better established Lias tiose
fcr TOC a:d TCX, to sarplicg results will be mere
cctsiitecl aid reliible a=:c{ testing laboratories ;
.Icnitoriog for (elected volatile organics does not
(•jirtc'.ee t. however, the volatile! BOVC vith froucdvaur af
fatl or faster this acy otter or(«oic coctaaioaotf . Tfcii
can be >rrs :o the work by FZu^b acd Fitcbford, in vtich
thty itcvti tbat, 10 OLTI viere coatacinatioD cxiiled,
vclatilei terve a> dedicators of that codification. If
'.oce'cf tlric vo!iii!e< was- detected, s'everil' olten »1»V.
v».-e 'iii.e!'. yreser.t. Fectkit the vclatzles cove thrc^gt
-t.'.Ti.i. cr its j:: : -.••..-.• :t:'titi , '.r;: ITT^IH i .-.;'. : :
jr.-/ ; c li.ti.v.s *:t ;stecit: i:r::ca:i:j tr.j". a piurt c'
cc.-.;i-^zn ICL ea:iti), '--* vola'.iles a:e =ot likely to be
detected fint.
6. The current ir.dicitcr paraceteri have beea ibovn to be
iceffective cc;:tc:». Tbeir continued uie not only
produces flawed results, but ceedlessly forces hundreds
of Lcc-pcl] uucg facilities into costly aisessaxnt
eoniloric(. This petition proposes Lbat title parameters
be replaced by a detection/screening system tilt would
allov for core icr:tdiale identification of specific
centarioir.ts and would virtually eliminate tbe probability
of false results (both positive and negative) at coo-
pollutint facilities.
IV. AJPE.VD1X VJJI PAJU.1TOS
A. V'aste ?1aaatfmf ct ' s Interest in the Proposed Action
Pereilled facilities vbich detect possible coctaeination and
therefore Bust initiate assessoeat oonitorini are required lo
saeple nearly 36S individual constituents (the Appendix VIII
para=eters listed in the Part 261 regulations). Tbe cjjor
problecs with t-bis xequirejsent arc:
1. An ow-ser/eperator if iccediately forced into an
expensive, unnecessary assessment monitoring process
which fails to consider site-specific factors; and
2. Tbe testint cf Appendix VIII paraaeters is excessive and
without scientific cent; cany of these paraneters are
unstable in water, exotic, cot present in • landfill
environment, or cave no available or standard Lest
netbods .
-------
F.oit pernitted RCF.A facilities where bazirdovi vaste ii
d-.ipcied are requited to eccv*.or jroucd^attr quality ('0 C.F.F.
J :tt. ??(•), 26«.SS). If that "detection cocitorioj protean"
ti~.ii a statistically s:r,s:ficaat iscreate io tie parueten
ecr.itered, 'he c^-t r/cjentcr r-»t. attest otter tbicg*,
";:=ecs»l*ly" »»=?i« tit irouidn'.er xo *U ccoi'.orioi vellt
ted dctrrr-.De Xbc cccc t;'.T»'-icn c{ <11 co:tt.ilucstf lilted in
Appcodix VJI1 ot 40 C.F.R. P»rt 261. <-0 C.F.R. i 26<-.98(b)(2) .
A}*e, f «c i 1 : tic t v.th ietcrin itatut cutt tttlyze
fcr «H A;pen^:x.V"l cct»t.ix.-f ixt tad iccludc tuch d»t» in
l!if. r «;pHotica fcr • l'.r.»l ;trr;l if * plust .of
tccv»r.!.-c»vlcr. i»» e'lterfd thr jrC'jndv.-»Vef • f res * r-«|3lirt.e'd '
L:U 40 C.r.R. J ':?0.1i(cH'). ' ' ..-.•••
Ai ;:c;cjeii -.= :»c'.:c; !!*. '.t» iour iLi;:»'.cr pi7i=et«rt uiti
in de'.fC'ics rc::'.cr::t itc-;ld be reyliced Vy *.he <;ecified
;f fcr vci«t:lr ot|»c;e ccrpcuadi. Cot>iite£t vnh
ofcicd ct»ig», tte A;;etiix V11I cer;oucdi oov t»c.pled
for durirf •iteiir.ect re-•-Icrir.g tbculd be re;l«ced by i Bucb
mere iclrcf.ve zur^tr cf ptrieetert b«ed oo tbeir freience in
le>cb*t.e «nd cniy n — ltii vbtcb >ia to identify
the >pecific p>rioeter> likely to eifrtte fro* » hazttdout
vnte facility.
The tiered approach prcpoied bere would Bcasure:
• (elected coopoucdi which are acalyzed by Method 626
(volatile or|*aici) and RCr> cetali;
• cor^oucda which are aoalyzed by Rethod 6!S (acidi and ba>e-
Deutrala); and
• otbet coc?oucd« cot aoalyzed by Method! fc2<. aad 621 which
art prelect in leacbate aad which are eot exotic or
unstable in water.
D. The Keed for the Prepeted Action
1. Once in auetinent oonitoriot, an owner/operator it
required to identify and deteruice the extent of.each
•utpected pluvt. For facilitiea acexi&i pereiti under
-------
Pirt Z6i,' «n Apptr.dix Vlll ir.ilytit it retired. Field
e»;enencr, boever, bn i.'.cvn tin few, if ir.y, Appeadix
Vlll pirisetert ciber thia voiililc or(iaict ire ever
found .
2. Fcr ec-ercu» reii::t. the lesll£| of ill Appeedix Vlll
;.»r*r«-.ert cleirly :.» without tc:e;t:rie eerit:
• Kiry Appendix Vlll cccpoundt ire cot cbeaicilt viich
cecr-ccly «re in * l»nifill or c-.j-^ poteotitlly be
relrord to |rou-id».'»ter free a lisdfill; X^tiBj lor
the»e ibculd r.ct be required. ^^
• f;«3y'Appendix VI^l corpocr.di ire uaititie ia viler inJ
~'-" th.ut b'o^ld cever be. found*A£ i (rou£d.viiei tickle,.•• >.*•
these ihculi te drefyfd f:crr fL'.jre tnX : 3^ requi re^er.t s .
:.c*. :*:;•-::.:. :: r r: *; r. c s ; utie c'.:»; c. a 1~. c -1 - -*
rep^itri ty i specific rcpre»cstit:ve et^pound from
etch elm .
• Cihfr Apper.iix V]ll »r.tr:e» ire low-vcluse, ipeciilty
cher.icili v:th very lisjted icduilriil usige; ihr:r
pretence io * lindfill eavircr^ieal it ron-eintent..
3. Furiherwore, it the SA3 review of tie drift TECD cleirly
ttited, the Apper.dix V]ll tntioj it oot cott-ef fective:
"The tr.ilyiictl effort ihould rininize the cuaber of
full Appendix Vlll icilytet. Civea itt bi(b cotv,
'ipeculitive' Appendix Vlll coaililueot inilytit
j.".cu".d be ivo;ded on ill ticplet. Appeodix Vlll
icilyiet tees ippropriiie on • few ticplex, vitb the
plune tben defined u
-------
A tiered tesliet, approach, at prcpcsed in IV. C above,
vcuid eliminate ra.-.y cf the correct difficulties
associated with the Appeodi* VII! paracxttrs. After tie
icdica'.cr parameters ate charted •> proposed ie Sectieo
II, the first nep to detect ccctasieatioa would be to
eeasvre for veil*. -.'. e or|i:: c» *r.d the RCRA EC Oil. Tbe
f icttico Ccrpcrjtica thevs thtt Ike bicV(rou£d levels
of tte volf.ilet occur to the range of xero le 30-iO
parti per billioo (ppb). That ii, levels of t_bt
cber.icalt in the r»0{( froo zero Vo SO ppb are detected
rccjhly ihree to five percer.t cf the tir.e. Thi> i> true
vhethe: cf«i-::r| tacKjrcuzd veils, dovajradieot y
trip blar.kt or ccstroltj cr cccta^icated veils.
The'ii?e cf a t:ered approach vc-jld take into »ecount O.e
_.,,....-.-• ......... c( th.je v:'. i'.i les . Obvieusiy, rare
;'5i! -'..I ..t.t re::r.e :.:.. i ;::te:.::.^ ays'.-.r. .". •.
leve
ccr;:Lr.is in trc-.;;--Her are r.uT.e
:cr, to fir.fle, r.cs-rey*titive instances of positive
rest '.s in the rar.[e cf a fev parts per tillicc creates
ur.r.ecessary alarr.. A syiter.atic, structured systes
desifned to verify tr.f evaluate both the presence ar.i
aiscciatetf r:si- cf ccntar.ir.at i on is oecessary to effect-
ively utilize jr^fc- ;.«ter esnitoriDt data for ecviron-
rectally protective action.
-------
APPENDIX D
'SELECTED LANDFILL CONSTRUCTION DIAGRAMS
-------
Ctf/S
C*~tinJ uiafC/Ctt re Ctl:
/:
Lift
.* l~.~-.
-------
,-W W,__..J.
• *• j. L.O r
-------
tf.5 A/
I
/- JO A/
I
tf OO A/
i
-/5f-
-30
-35
-50t~
?0
•30
-35
-40
1986 ANNUAL REPORT
LAKE CHARLES FACILITY
CHEMICAL WASTE
MANAGEMENT, INC.
WtoocKrant-Ctytt* ConnrfUnta
NOTED
• •»!•• .7 /'/V. •*'• ? "l
MODULE IA AS -BUILT
COLLECTION SUMPS
EAST-WEST CROSS-SECTION
.•*)•»
A-7
-------
J *•
/• J0J
\
40S
/ » 60 3
I
/ » 70 S
I
•fS
L
V.
-SO
-/S
•ff
I
-SO
Cfii
1986 ANNUAL REPORT
L/VKE CHARLES FACILITY
CHtMlCAL WASTE
MANAGEMENT, INC.
Woodwwtl-Ctyd* ComutUml*
"•01 •• £> ,
NOTED ,„,,.,„ ., r>
MODULE IB SUMP AS BUILT
NORTH-SOUTH CROSS - SECTION
A-8
-------
IV / » 6O
I
H// • so
I
IV / • Jff
I
VV / » JO
I
w /
IV/ .
I
!
i
\
-30
Ci
I986 ANNUAL REPORT
LAKE CHARLES FACILITY
CHF.MICAL WASTC
MANAGEMENT. INC.
NOTED
MODULE 2 AS RUILT SUMPS
EAST-WEST CROSS-SECTION
A-9
------- |