EPA-700/8-88-041
Hazardous Waste Ground-Water
Task Force
Evaluation of
SCM-Adrian Joyce Works
Baltimore, Maryland
&ERA
UNITED STATES ENVFONMENTAL PROTECTION AGENCY

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                            April      ,    1988

           Update of the Hazardous Waste Ground-Water Task Force

                    Evaluation of SCM-Adrian Joyce Works

                            Baltimore, Maryland


      The United States Environmental  Protection Agency's Hazardous Waste
 Ground-Water Task Force (Task  Force) conducted an evaluation of the ground-
 water monitoring program  at  the SCM-Adrian Joyce Wbrks (SCM-AJW) hazardous
 waste treatment and storage facility in Baltimore, Maryland.  Ihe onsite
 SCM-AJW field inspection was conducted during the period of June 9-13,
 1986.  SCM-AJW is one of 58 facilities evaluated by the Task Force.  Tne
 purpose of the Task Force evaluations was to determine the adequacy of a
 facility's grondwater monitoring progran in regard to the applicable
 State and Federal ground-water requirements.   The Task Force effort came
 about in light of recent concerns as to whether operators of hazardous
 waste treatment,  storage,  and disposal facilities were complying with
 State and Federal ground-water monitoring regulations.

      The evaluation of the SCM-AJW facility focused on determining (1) if
 the facility was  in compliance with applicable regulatory requirements
 and policy,  and (2)  if hazardous waste constituents were present in the
 groundwater.   The inspection  revealed  that SCM-AJW was  not fully complying
 with applicable interim status ground-water monitoring  requirements and
 that ground-water samples  from onsite  wells contained hazardous  waste
 constituents.

      As  a result  of a May  7,  1987 inquiry from SCM-AJW,  EPA  reviewed the
 operations at the  plant.   It  concluded that the plant was processing
 ilmenite ore.  By letter of July  7,  1987,  it notified SCM-AJW that the
 wastes from such processing were temporarily excluded from regulation
 under Subtitle C of RCRA by the "Bevill Amendment"  to the Act, sections
 3001(b)(c) (A) (ii)  and  8002(p).  "Assailing  the wastes from  this processing
 are the  only wastes  in the Batch Attack Lagoon  (BAL), EPA stated,  "the
 lagoon is not subject  to Subtitle C requirements."  It added, however,
 that Subtitle C requirements  could be  imposed at a  later date if EPA
 determined, after studying the wastes from ilmenite processing under
 RCRA § 8002(p), that regulations under Subtitle C is appropriate.

      The State is applying the  Bevill amendment in a manner consistent
 with EPA's interpretation.  Therefore, the State does not currently
 consider the wastes managed in  the BAL to be hazardous.  Tne facility is
 being regulated under Maryland's Solid Waste regulations.  The pending
 Part B application is no longer valid and has  been returned to the facility.
 SCM-AJW will be required to file a solid waste permit application since
 the existing hazardous waste permit has expired.  Tnis  update provides
 information on ground-water related activities conducted by SCM-AJW,
EPA, and the Maryland Department of the Envirorment since the Task Force
Inspection.

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                                    -2-
      From July 9-16, 1986,  SCM-AJW conducted several punp tests of
 monitoring wells to assess the structural integrity of the  asphaltic
 slurry wall installed in 1984.  The tests had  two major goals:  (1)  to
 determine whether the wall was leaking by observing the effects of
 hydraulic comnunication between wells on either side of the slurry  wall,
 and (2) to determine variations in the concentrations  of chemical
 constituents in monitoring wells during a period of continuous puttping.
 To determine the effectiveness of the BAL and  pumping well system  in
 containing/preventing contaminants  from reaching the river, SCM-AJW
 collected sanples from the Patapsco River (Glidden  Cove) at predetermined
 locations.   This was  conducted during  the  sane  time period as the pump
 tests.   The results  of pump tests and  surface water monitoring were
 submitted to EPA on July 22,  1986.   The results are the subject of an
 ongoing review by EPA.

     On November 4 and 5, 1986,  EPA Region III performed a punp test on
monitoring well 3 to determine whether the slurry wall separating  the BAL
 and the Patapsco River was  leaking.  The 24 hour pump  test proved
 inconclusive  in that the aquifer could not be sufficiently stressed due
 to the  limited  capacity of  the punping apparatus.   However,  sanpling of
monitoring well 3 did provide further evidence  of  low  pH conditions on
the river side of the slurry wall.

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                                 CONTENTS
EXECUTIVE SUMMARY

Introduction	 1

Summary of Findings and Conclusions	 6

     Ground-Water Monitoring During Interim Status	 6
     Ground-Water Sampling and Analysis Plan	 7
     Sampling and Analysis Procedures	 7
     Monitoring Well Network	9
     .Assessment Program Outline and Plan	10
     Task Force Sampling and Monitoring Data Evaluation	11

TECHNICAL REPORT         '

Investigation Methods.	 .14

     Records/Documents Review	14
     Part B Evaluation - Ground Water Monitoring	15
     Facility Inspection	 .18
     Laboratory Evaluation	<..	18
     Sample Collection and Analysis	18

Facility Description	26

  Process Operation	26
  Solid Waste Management Units	29
     Upper Settling Basin	29
     Middle Settling Basin	31
     Lower Settling Basin	31
     Batch Attack Lagoon	31
     Batch Attack Mud Treatment System	31
     Batch Attack Mud Treatment and Storage Area	.32
     Spent Solvent Storage Areas	.32
     Neutralization Tanks at the Cloride Area	32
     Aragonite Pit System	..	33
     Primary and Secondary Waste Acid Neutralization Systems......33
     Primary Gypsum and Secondary Gypsum Storage Piles	34
     Closed Copperos Storage Area	34
     Closed Chloride-Clay Area	35
     001 Neutralization System	35
     002 Neutralization System	36
     Triple Tank Neutralization System	36

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                                 CONTENTS
Site Hydrogeology	37
  Hydrogeologic Units	38

Ground-Water Monitoring During Interim Status	41
  Regulatory Requirements	43
  Ground-Vfeter Sampling and Analysis Plan	44
  Monitoring Wells	45
    Well Construction	48
    Well Locations	51

SCM-AJW Sampling Procedures	51
  Water Level Measurements	52
  Purging..	53
  Sample Collection	54
  Shipping and  Chain-of-Custody	55

Ground -Water Quality Assessment Program Outline  and Plan	56
  Assessment Outline	56
  Assessment Program Plan	57

 Evaluation of Monitoring Data for Indications  of Waste Release....58

 APPENDICES

  A.  Boring Logs for P-series, M-series and Recovery Wells
  B.  Analytical Techniques  for Task Force  Samples

 FIGURES

   1.  S ite Location Map	  2
   2.  Waste Management Area and Adjacent Wells	 .12
   3.  Task Force Sampling Stations.	19
   4. SCM-AJW Facility Layout	27
   5. Solid Waste Management  Units.	30
   6. P-series Monitoring Wells....	46
   7. M-series Monitoring Wells	47

 TABLES

   1. Selected Inorganic Data frcm Task Force Samples	13
   2.  Decontamination Procedures	21
   3.  Purging and Sampling Data	23,24
   4.  Order of Sample Collection, Bottle Type and Preservation
        List	25
    5.  Depth to Water Data	40
    6.  State and Federal  Counterpart Interim Status Regulations	43
    7.  Construction Details  for Interim Status  Wells	49
    8.  Data Summary of Waste Components in  Wells	63
    9.  Selected Organic and  Inorganic Compounds Detected in Task
         Force Samples	64,65

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                               INTRODUCTION


     Concerns have been raised about whether hazardous waste treatment,

storage and disposal facilities (TSDFs) are complying with the ground-

water monitoring requirements promulgated under the Resource Conservation

and Recovery Act (RCRA)*.  In question is the ability of existing or

proposed ground-water monitoring systems to detect containment releases

fron waste management units.  To evaluate these systems and determine the

current compliance status, the Administrator of the Environmental Protec-

tion Agency (EPA) established a Hazardous Waste Ground-Water Task Force

(Task Force).  The Task Force comprises personnel from the EPA Office of

Solid Waste and Emergency Response, Office of Enforcement and Compliance

Monitoring, National Enforcement Investigations Center (NEIC), Regional

Offices and State regulatory agencies.  The Task Force is conducting in-

depth, onsite investigations of TSDFs with the following objectives:


     o    Determine compliance with interim status ground-water monitoring
          requirements of 40 CFR Part 265, as promulgated under RCRA or
          the State equivalent (where the State has received RCRA
          authorization).

     o    Evaluate the ground-water monitoring program described in the
          RCRA Part B permit application, submitted by the facility, for
          compliance with 40 CFR Section 270.14(c).

     o    Determine if the ground water at the facility contains hazardous
          waste or constituents.


     SCM-Adrian Joyce Works (SCM-AJW) is located in Baltimore, Maryland

[Figure 1].  The on-site inspection was conducted from June 9 through 13,

1986 and was coordinated by the EPA Region III personnel.
     Regulations promulgated under RCRA address TSDF operations, including
     ground-water monitoring to ensure immediate detection of any hazardous
     waste or constituents released to the environment.

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                          Figure 1




                     Site Location Map
                        SCALE
                                                             I MILE
1000
             1000    ZOOO
                                4QOQ    SOOO    6000
                                                    7000 FECT
 I
-N-

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                                   -3-





     SCM-AJW stores process wastewater in two waste management units



(surface impoundments), one of which, the sulfate process, is subject to



RCRA groundwater monitoring requirements.  The chloride process unit



qualifies for a waste exemption under 40 CFR Part 261.  The Company



plans to continue to operate these units and has submitted a Part B



permit application (dated October, 1984).





     The Part B identifies the facility's regulated units to be one drum



storage area, one treatment tank, one waste pile and the batch attack



lagoon (surface impoundment).  In addition, hazardous wastes have previ-



ously been landfilled in a open dumpsite, which has been cleaned up.



Hazardous waste solvents are stored in the drum storage area.  The re-



maining hazardous waste management units either store or treat batch



attack mud (BAM), containing chromium and up to eight percent sulfuric



acid.  During the inspection, Task Force personnel evaluated compliance



with the interim status ground-water monitoring requirements of 40 C.F.R.



Part 265 and Maryland equivalent regulations (COMAR 51.10.05.06-.07).



Note:  Maryland does not have interim status nor any equivalent; all



facilities are required to meet 264 standards.  Requirements for initial



quarterly sampling as set forth in Part 265 are incorporated in the



COMAR.  For the purpose of simplicity, this task force evaluation utilizes



the Federal interim status and Part 265 standards since they are techni-



cally, if not procedurally, equivalent to COMAR.

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                                   -4-





     The adequacy of the ground-water sampling and analysis plan, moni-



toring well construction and location, analysis of samples taken from



the monitoring wells and the ground-water quality assessment program



outline and plan were evaluated.  Information was also obtained on present



and past solid waste management units to aid in evaluating the well net-



work and interpreting ground-water monitoring data.  The evaluation



involved a review of State, Federal and facility records; facility and



laboratory inspections; and collection and analysis of samples from



ground-water monitoring wells and one of the surface impoundments.





     SCM manufactures titatium dioxide; a non-hazardous, non-toxic white



pigment used in paints, toothpaste and Oreo Cookies (TM), etc. at the



Adrian Joyce Works, Baltimore Maryland.  The plant property was purchased



by the company in 1955.  The plant area was purchased from the Army



Corps of Engineers.  The site of the surface impoundment had been used



as a dredge spoil dewatering area by the Corps.  The plant area was



subsequently, developed into a 135 acre industrial facility and is now



surrounded by the Patapsco River to the east, the Fort Armstead State



Park to the north, and industrial uses on the remaining sides.





     The sulfate process surface impoundment, known as the batch attack



lagoon, covers 14 acres and stores acidic wastewaters prior to treatment



and discharge (NPDES Permit # 7AD1P164) to the Patapsco River.






     Interim authorization was delegated to the Maryland Waste Management



Administration (WA) in July 1981.  Final authorization was delegated in



February 1985.  Consequently, the surface impoundment has been operated



under State interim status requirements (State and EPA ID No. MOD 00 309



3515).

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                                   -5-





     In February, 1982, a ground-water monitoring program was implemented



by SCM-Mrian Joyce.  The monitoring system during this time consisted of



seven wells designated as P-5 through P-ll.  Ground-water monitoring at



the P-series wells continued until August, 1984.





     In July, 1984, SCM-AJW and the WMA entered into a consent order and



agreement.  This order and agreement required the installation of an



asphaltic slurry wall between the batch attack lagoon and the Patapsco



River to prevent the migration of contaminants being released fron the



lagoon.  Also required in the order was the installation of a groundwater



recovery system and a ground-water monitoring system.  The ground water



recovery system was installed in and consist of seven wells designated



as R-l through R-7.  These wells are located between the lagoon and the



slurry wall and are used to recover contaminated groundwater which is



pumped back into the lagoon.  A ground-water monitoring system was



installed in November, 1984 and consist of seven wells designated as



M-l through M-7.  The M-series wells replaced the out of service P-series



wells, and are used to monitor groundwater quality on the Patapsco River



side of the slurry wall.  SCM-AJW resumed interim status groundwater



monitoring in January, 1985 when the first quarter samples were collected



from the M-series wells.

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                                   -6-






                   Summary of Findings and Conclusions





     The findings and conclusions presented reflect conditions existing



at the facility in June, 1986.  Actions taken by the State, EPA Region



III and SCM-AJW subsequent to June are summarized in the accompanying



update.



              Ground-Water Monitoring During Interim Status





     Task Force personnel investigated the interim status ground-water



monitoring program at SCM-AJW for the period between July 8, 1981,



when applicable provisions of the Maryland regulation became effective,



and June, 1986.  The investigation revealed that an interim status moni-



toring program was implemented in February, 1982.  A groundwater sampling



and analysis plan, specifically for interim status requirements, was



submitted to WMA, in September, 1981.  Although the plan was not evaluated



or approved, it was implemented on the P-series wells.





     In November, 1984, a new ground water monitoring system was installed



as required by the consent order and agreement signed in July, 1984.



This new system, designated as the M-series wells had replaced the now



out of service P-series wells.  Quarterly samples were first collected



from the M-series wells in January, 1985.  The sampling and analysis plan



implemented in 1982 had not been revised to adapt to the new monitoring



system.  The Task Force evaluated the program implemented in January,



1985 and determined it to be inadequate.  Some program components, in-



cluding the ground-water sampling and analysis plan and procedures,



monitoring well network and the assessment program outline and plan, did



not comply with WMA requirements.

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                                   -7-





Ground-Water Sampling and Analysis Plan





     The Task Force evaluated the ground-water sampling and analysis plan



submitted in September, 1981 and implemented on the P-series wells in



February, 1982.  A new ground-water monitoring system was installed in



November, 1984 as required by the consent order and agreement signed in



July, 1984.  Although generally acceptable, the sampling and analysis



plan was never revised or updated to address the new monitoring system.



Consequently, the plan does not adequately detail the procedures for



sampling and analysis of the new monitoring wells.  For example, the plan



did not specify methods and equipment used for purging and sampling the



wells; disposal of purge and decontamination water; making field measure-



ments for temperature, pH and specific conductance; and calibration of



the field meters.  The plan indicates that some sample aliquots will be



preserved by adding acid until a specified pH is achieved, but does not



explain how the pH will be determined.





Sampling and Analysis Procedures





     SCM-AJW personnel demonstrated interim status sampling techniques



during the Task Force inspection.  Although the demonstration generally



followed the sampling and analysis plan submitted in 1981, some proce-



dural discrepancies exist.  For example, the plan states that the sample



should be transferred from the well sampling device to the designated



sample containers in the field.  During the demonstration, it was



observed that the groundwater was transferred from the sampling device



to a common container (1 gallon PVC bucket) and taken to the on-site



laboratory where it was transferred to the designated sample containers.



This procedure increases the potential for foreign contaminants to enter



the sample and allows for unnecessary agitation causing volatilization

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                                   -8-





to occur.  Other observations during the field demonstration include the



dropping of the bailer down the well column when the well was being



purged allowing for severe agitation within the column.  Although dedi-



cated bailers were used for each well, neither the bailers or the carry-



ing tubes were marked to identify which bailer belongs to an individual



well.





     Sampling records indicate that inconsistencies exist in sampling



procedures since quarterly sampling was initiated on the M-series wells



in January, 1985.  For example, purge volumes change fron removing one-



volume during a quarterly sampling event to removing over three volumes



the following quarterly sampling event.  Equipment used to purge the



wells changes as bailers are used during one quarter and air displacement



methods are used durinq the next.  Sample volumes removed from each well



have changed fron collecting one-gallon during the four quarters of 1985



to over three gallons for the first quarter of 1986 to two quarts for



the second quarter of 1986.  Finally, field measurements for pH, specific



conductivity and temperature were not collected during the first quarterly



sampling period for the M-series wells.






     Task Force personnel inspected the onsite and off-site laboratories,



which conducts the interim status analyses on ground-water samples.





    ' Currently, only metals are analyzed at the SCM-AJW on-site labora-



tory.  Several deficiencies were found at the SCM-AJW laboratory.  All



metals data generated for the well monitoring should be considered highly



questionable.  The laboratory does not digest samples before analysis.



Total metals for flame analysis should be digested according to Method



3010 of "Test Methods for Solid Waste", SW-846.  Further, there exists no



written instrument calibration procedure and no written quality control



manual.  Duplicate samples are not collected.  Duplicate and spiked



samples are not analyzed.

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                                   -9-





     SCM-AJW use a contracted laboratory for Total Organic Carbon (TOC)



and Total Organic Halogen (TOX) analysis.  The Task Force evaluated this



laboratory and identified some deficiencies.  SCM-AJW does not currently



follow proper chain-of-custody procedures for samples sent to this



laboratory.  An adequate chain-of-custory program should allow for the



tracing of possession and handling of individual samples from the time



of individual samples from the time of field collection through laboratory



analysis.  Also, more stringent quality control methods need to be



incorporated into the TOX preparation and analysis scheme.  Data for TOX



should be considered suspect until these procedures are implemented.





Monitoring Well Network





     Installation procedures for the seven monitoring wells installed in



November, 1984 were adequate; however, some deficiencies were found in



the completed wells.  Upgradient monitoring well P-5 and monitoring wells



M-l through M-7 were not surveyed to common data point (mean sea level)



at the time of the inspection.  Consequently, ground-water surface



elevations, at each monitoring well, have not been measured during



quarterly sampling events.  The concrete collar installed around the well



head at monitoring well M-7 had been raised about two feet from the ground



surface.  Monitoring well M-l did not produce any water when sampled by



Task Force personnel and well M-2 produced very turbid water at extremely



slow rates, thereby suggesting deficiencies in the placement of the well



screen and well development.  Well construction details submitted by SCM



indicate that well M-l is screened partially in a sand zone and partially



in a silty clay zone and well M-2 is screened entirely in a silty clay



zone.

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                                   -10-


     The adequacy of the well locations (vertical and areal) have been

evaluated using information made available during the inspection.  Boring

logs for the M-series wells indicate that beach sand material along the

Patapsco River is being monitored.  However, the vertical extent of this

monitoring system terminates at the upper portion of a clay zone, immedi-

ately beneath the water bearing sand.  Consequently, the extent of

the underlying clay zone has not been determined and the uppermost aquifer

has not been adequately defined.  Ground-water flow directions have not

been appropriately identified because surveyed elevations for the moni-

toring wells have not been measured at the time of the inspection.  The

lack of these elevations hinders in verifying the validity of monitoring

well P-5 as being upgradient.


Assessment Program Outline and Plan


     An outline for a ground-water quality assessment program was required

[10.51.05.06 D(l)] by November 18, 1981.  SCM submitted an outline in

September, 1981 to satisfy the interim status requirements for the P-

series wells.  This outline was never revised or updated to address the

monitoring system (M-series wells) installed in November, 1984 and

presently used in the ground-water monitoring program.  This outline did

not receive a written approval fron WMA.


     State regulations require that the outline describe a more compre-

hensive ground-water monitoring program capable of determining:


     0    Whether hazardous waste or hazardous waste constituents have
          entered the groundwater;

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                                   -11-
          The rate and extent of migration of hazardous waste or hazardous
          waste constituents in the groundwater; and

          The concentration of hazardous waste or hazardous waste
          constituents in the groundwater.
     The outline does not comply with State regulations [10.51.05.06 D(l)]

because:
          It has not been updated or revised to address the groundwater
          monitoring program (M-series wells) presently in operation at
          the facility.  Although the outline describes a more comprehen-
          sive monitoring program, it is focused on the P-series wells
          which have been out of service since February, 1985.
     SCM-Adrian Joyce begun semi-annual sampling at the P-series wells in

June, 1983.  A statistical evaluation of the data was performed at this

time and the results indicated significant decreases in pH values for

certain downgradient P-series wells.  SCM continued to conduct semi-

annual sampling and perform statistical evaluations of the data.  Although

these evaluations indicated ground-water contamination, SCM did not enter

into a groundwater quality assessment program.  As a result, a groundwater

quality assessment plan was not prepared.


Task Force Sampling and Monitoring Data Evaluation


     During the inspection, Task Force personnel collected samples from

eight ground-water monitoring wells, four ground-water recovery wells and

the batch attack lagoon [Figure 2].  The well samples were collected to

determine if the ground water contained hazardous waste or constituents.

The batch attack lagoon was sampled because it is a potential contaminant

source.  Monitoring data from Task Force samples were evaluated with

previous SCM-AJW data.

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                                  -12-
                           ASPHALTIC SLURRY WALL
                                                    QMC
 COMPLIANCE

MONITORING POINT
                                                                          001
                                                                       'OUTFALL
                              BATCH ATTACK LAGOON
 O
P-5
                                   FlfMC t

                               Location Map

                   Waste Management Area and Adjacent Wells

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                                     -13-


         Task Force and SCM-AJW historic data indicate the presence of chro-

    mium with high concentrations (i.e., greater than 1000 ug/1) in seven of

    the eight monitoring wells sampled by the Task Force (M-2, 3, 4, 5, 6,

    7', and P-9).  The batch attack lagoon and recovery wells R-2, 3, 5, and

    7 have similar concentrations of chromium.  Task Force pH values in the

    monitoring wells and recovery wells range from less than 0.5 to 3.0

    units.  The pH of the batch attack lagoon was less than 1 unit.  Task

    Force data for upgradient monitoring well P-5 did not reveal any detect-

    able levels of chromium and had a pH value of 4.7 units.  The high chro-

    mium levels and low pH values in the lagoon and adjacent wells indicate

    that the lagoon is the source of contamination.


         In Table 1, selected inorganic data is presented for respective

    wells.  The pattern of concentration from the upgradient well to the M-

    series wells indicate leakage from the batch attack lagoon.


                                   TABLE I

               Selected Inorganic Data from Task Force Samples*

Parameter
Chromium***
Lead***
Magnesium***
pH
P-5
(upgradient) B.A.L.
ND** 75000
5.5 414
12800 1820000
4.7 <1.0

R-2
63200
1400
1810000
0-0.5

R-5
64300
3160
1800000
0-0.5

M-2
98300
1770
2280000
<0.5

M-4
96500
2600
2520000
<0.5
*  Data are from wells adjacent to the batch attack lagoon.
** ND - non-detected
***Concentrations are in micrograms per liter (ug/1)

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TECHNICAL REPORT

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                                   -14-


                          Investigation Methods


     The Task Force investigation of the SCM-Mrian Joyce facility con-

     prised:


     0    Reviewing and evaluating records and documents from EPA Region
          III, WMA and SCM-Adrian Joyce.

     0    Conducting an onsite facility inspection June 9 through
          June 13, 1986.

     0    Evaluating the onsite and offsite analytical laboratories.

     0    Sampling and analyzing data from ground-water monitoring wells.


Records/Documents Review


     Records and documents from EPA Region III and the MDHMH offices were

reviewed prior to and during the onsite inspection to obtain information

on facility operations, construction details of waste management units

and.the ground-water monitoring program.  Onsite facility records were

reviewed to verify information in Government files and supplement Govern-

ment information where necessary.  Selected documents requiring further

evaluation were copies by the Task Force during the inspection.


     Specific documents and records that were reviewed included the

groundwater sampling and analysis plan; outline and plan for the ground-

water assessment program; analytical results from past ground-water

sampling; monitoring well construction data and logs; site geologic

reports; site operations plans; facility permits; waste management unit

design and operation reports; and operating records showing the general

types, quantities, and locations of process waste sources at the facility

and the State/SCM-AJW Consent.Order.

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                                   -15-
Part B Evaluation - Ground-Water Monitoring


     The groundwater monitoring section of the Part B permit application

dated October, 1984 has been reviewed for completeness.  This version of

the Part B was selected since it was current as of the June, 1986 Task

Force Inspection.  The review consists of a comparison of information

requirements under 40 C.F.R. 270.14(c) and Maryland Hazardous Waste

regulations (COMAR 10.51.07.02) with key elements of the section.


     For easy reference, information requirements are listed in the left

hand column of the chart by regulatory citation followed some indication

as to whether or not the requirement has been met in the right hand

column.  Any Turther explanation is provided below the response.
Information Request

270.14(c)(l)/OOMAR 10.51.07.02A(6)(a)
A summary of the groundwater
monitoring data obtained during the
interim status period.

270.14(c)(2)/10.51.07.02A(6)(b)
Identification of the uppermost
aquifer and aquifers hydraulically
interconnected beneath the facility
property including ground water flow
direction and rate and the basis for
such identification.

270.14(c)(3)/10.51.05.07.02A( 6)(c)
On a topographic map...a deliniation
of the waste management area, the
property boundry, the proposed point
of compliance, the proposed location
of ground-water monitoring wells and
to the extent possible information
required under C(2).

270.14(c)(4) 10.51.07.02A(6)(d)
(e) and (h)
A description of any plume of contami-
nation that has entered the groundwater
frcm a regulated unit at the time the
application was submitted that:
Is Requirement Satisfied (yes/no)

Yes (Appendix S)




Yes (Appendices J and R)
Yes
No (None to be found in Application)

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                                   -16-
Information Request

(i)  Delinates the extent of the plume
     of the topographic map.

(ii) Identifies the concentration of
     each Appendix III constituent
     throughout the plume or identifies
     the maximum concentration of each
     Appendix VIII constituent in the
     plume.

270.14(c)(5)
Detailed plans and engineering report
describing the proposed groundwater
monitoring program to be implemented
to meet requirements of 264.97.
270.14(c)(6)
If the presence of hazardous
constituents has not been detected
in the groundwater at the time of
permit application, the 0/0 must
submit sufficient information,
supporting data and analysis to
establish a detection monitoring
program.

(i)  A proposed list of indicator
     parameters...

(ii) A proposed ground-water
     monitoring system...

(iii)Background values of each
     proposed monitoring parameter
     or constituent...

(iv) A description of proposed
     sampling, analysis and
     statistical comparison
     procedures...

270.14(c)(7)
If the presence of hazardous con-
stituents has been detected in the
ground-water at the point of compliance
of the time of permit application.
the o/o must submit sufficient infor-
mation, supporting data and analyses
to establish a compliance monitoring
Is Requirement Satisfied (yes/no)

No (Not completed)
No.  At time of Application
submission, Appendix VIII
analysis had not been performed.
No specific plan submitted with Part B
application.  However, facility does
briefly mention that present system
consisting of "P" series wells will be
supplemented by M-series in accordance
with June, 1984 order requirements.

N/A - Hazardous constituents have
been detected in the groundwater.
N/A - Hazardous constituents have
been detected in the groundwater.

N/A - Hazardous constituents have
been detected in the groundwater.

N/A - Hazardous constituents have
been detected in the groundwater.
N/A - Hazardous constituents have
been detected in the groundwater.
No.  No specific plan for a compliance
monitoring program is presented.  How-
ever, an engineering plan for a
corrective action program is presented
in accordance with order requirements.
At the time of application submission
the program had been implemented.

-------
                                   -17-
Information Request

program which meets requirements of
264.99.  The o/o must also submit an
engineering feasibility plan for a
corrective action program necessary
to meet requirements 264.100.  To
demonstrate compliance with 264.99,
the o/o must address the following:

(i)  A description of wastes previously
     handled at the facility.

(ii) A characterization of the
     contaminated groundwater,
     including the concentration of
     hazardous constituents.

(iii)A list of hazardous constituents
     for which compliance monitoring
     will be undertaken...

(iv) Proposed concentration limits
     for each hazardous constituent.

(v)  Detailed plans and an engineering
     report describing the proposed
     groundwater monitoring system.
Is Requirement Satisfied (yes/no)

The plan briefly states that the new
(m) series wells will monitor the
effectiveness of the corrective action
program.
Yes*.  A description of wastes handled
at the batch attack lagoon is presented.

Yes*.  Interim status groundwater
results are presented.  Concentrations
of detected hazardous constituents
(Chromium and lead are included).
No.
No.
No.
(vi) A description of proposed sampling,
     analysis and statistical com-
     parisons procedures to be utilized
     in evaluating groundwater monitoring
     data.

270.14(c)(8)
If hazardous constituents have been
measured in the groundwater which
exceed the concentration limits under
264.94 Table I or if ground water
monitoring conducted at the time of
permit application under 265.90 through
265.94 at the waste boundry indicates
the presence of hazardous constituents
from the facility in groundwater over
be:"1'.ground concentrations, the o/o
must submit sufficient information,
supporting data and analyses to
establish a corrective action program
which meets the requirements of 264.99.
Yes,
At the time of permit application
submission, the corrective action
program had been initiated (July,
1984) although it was not operational.

Supporting data and information
concerning the corrective action
program are presented under Appendices
J, 0, and A.

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                                   -18-





Facility Inspection






     An onsite facility inspection was conducted to identify waste sources,



waste transport, waste management units (past and present), pollution



control practices, surface drainage routes and to verify the location of



groundwater monitoring, recovery, and other wells.  Company representatives



and contractors provided information on and explained: (1) facility opera-



tions (past and present); (2) site hydrogeology; (3) the groundwater moni-



toring system, and; (4) the groundwater sampling and analysis plan.





Laboratory Evaluation





     The onsite and offsite laboratory facilities analyzing ground-water



samples were evaluated regarding their ability to produce quality data



for the required analysis.  Analytical equipment and methods, quality



assurance procedures and records were examined for adequacy.  Laboratory



records were inspected for completeness, accuracy and compliance with



State and Federal requirements.  The sample handling, analysis and docu-



ment control procedures followed were discussed with laboratory personnel.





Sample Collection and Analysis





     The sampling portion of the investigation involved three activities:



(1) measuring water levels in all monitoring wells onsite, (2) installing



automatic water level records on certain wells, and (3) sampling wells



and one active surface impoundment (batch attack lagoon) [Figure 3].



Water level measurements were taken in an attempt to determine the direc-



tion of ground-water flow, as well as calculations of purge volumes.



Automatic water level recorders were placed on certain wells in an attempt



to determine the extent of hydraulic head change in response to tidal



Quotations.  Those wells, designated by the "P" prefix, are monitoring

-------
               -19-
  BATCH ATTACK LAGOON •
              FIGURE 3
TASK FORCE SAMPLING STATIONS

-------
                                   -20-





wells installed in 1981 to initiate the interim status ground-water



monitoring program.  Wells designated by the "R" prefix are recovery



wells associated with the contaminated ground-water recovery program



which is a result of the consent order and agreement (CO&A) signed



in July, 1984.  The remaining wells are designated by the "M" prefix and



are currently used as the RCRA monitoring wells.  These wells were in-



stalled in 1984 and are situated on the Patapsco River side of the



asphaltic slurry wall.  The wells were sampled to determine if and to



what extent the groundwater contains hazardous waste or constituents.



The surface impoundment was sampled because of the potential to release



hazardous waste or constituents to the groundwater.





     Splits of all sanples including duplicate volatile organic samples



were provided to SCMr-Adrian Joyce.  EPA Region III did not request split



samples.





     The groundwater recovery wells at the facility are equipped with



submersible pumps that are activated by a float mechanism.  When water



levels on the lagoon side of the asphaltic slurry wall rise to a specified



level, the float triggers the pump which begins to withdraw the groundwater.



The recovery wells have a discharge rate of approximately 13 gallons per



minut (gpm).  The recovered groundwater is pumped back into the lagoon.



Samples were collected by an EPA contractor for the Task Force and SCM-



AJW using the following procedures:





Recovery Wells



     1.   EPA contractor monitored discharge part for chemical vapor


                       ®
          (Photovac Tip ) and radiation.
     Photovac Tip and Interface Probe are registered trademarks and will

     appear hereafter without ®.

-------
                                   -21-
     2.   EPA contractor collected a sample aliquot and made field
          measurements for turbidity and pH.  Due to the acidic nature of
          the groundwater, pH measurements were obtained using pH paper.
          For the same reason, conductivity values were not measured.

     3.   EPA contractor filled sample containers using both the methods
          and order specified in Tables 3 and 4.

     4.   Samples were placed on ice in an insulated cooler.

     5.   EPA contract personnel took the samples to a staging area where
          the total metals, TOC, phenols, cyanide and nitrate/ammonia
          samples were preserved [Table 4].
Monitoring Wells
     1.   SCM personnel unlocked the well head.

     2.   EPA contractor monitored open wellhead for chemical vapor,
          using the Photovac Tip, and radiation.

     3.   EPA contractor measured depth to ground water using an oil/water
          sonic Interface Probe  (Oil Recovery Systems, 100 feet model).

     4.   EPA contractor lowered the Interface Probe through the water
          column until total depth was reached.

     5.   EPA contractor retrieved the Interface Probe from the well bore
          and decontaminated the cable and probe using procedures outlined
          in Table 2.

                                 TABLE 2

                        Decontamination Procedures
         Equipment*
Decontamination Method
Submersible pump, tubing, ropes
and wire
Interface probe
Filtering apparatus
Cleaned after each use with
a non-phosphate soap and
rinsed with tap water.

Cleaned after each use with
a pesticide grade hexane
wipe, followed by a rinse
with distilled water and
wiped dry.

Cleaned with 1:1 nitric acid
diluted with distilled water
and rinsed with distilled
water.
* Teflon bailers were pre-cleaned before the inspection; none were reused
  during the inspection, therefore, none had to be decontaminated.

-------
                                   -22-
     6.   EPA contractor sealed the well with a custody seal.  (The water
          levels were taken during a high and low tide cycle).

     7.   Task Force personnel calculated water-column volumes using
          height of water column and well casing radius.

     8.   When the Task Force was ready to sample the well, the EPA
          contractor purged three water-column volumes using a Jacuzzi
          1/2 horsepower submersible pump.  Table 3 indicates the method
          of purging each well.  Purge water was discharged directly
          into the surface impoundment*.

     9.   EPA contractor collected an equipment blank for SCM-AJW.
          Equipment blanks were collected only for monitoring well
          samples.

     10.  EPA contractor collected a sample aliquot and made field
          measurements for pH and turbidity.

     11.  EPA contractor filled sample containers using both the methods
          and order specified in Tables 3 and 4.  Split samples were
          collected by filling one-third of each bottle for the Task
          Force and facility bottles, respectively.  This process was
          repeated until each bottle was filled.  (The batch attack
          lagoon was. sampled by immersing the sample bottles below the
          water surface and allowing the bottles to fill to the required
          level).

     12.  Samples were placed on ice in. an insulated cooler.
     13.  EPA contract personnel took the samples to a staging area where
          the dissolved metals aliquot was filtered.  In addition, total
          metals, TOC, phenols, cyanide and nitrate/ammonia samples were
          preserved [Table 4].


     When the batch attack lagoon was sampled, steps 9, 10, 11, and 12
were followed in their respective order.  The sample was taken at the
northeastern corner of the lagoon, between the discharge ports of recovery
wells 2 and 3.
® Jacuzzi is a registered trademark and will appear hereafter without the
* Permission was granted by SCM-Adrian Joyce for the disposal of purge
water in this manner.  This was also approved by the WMA and the Task
Force.

-------
                                                             -23-
MW-6
MW-7
                                                           TABLE 3

                                                  PURGING AND SAMPLING DATA

Well
Number
Recovery
Well 2

Recovery
Well 3

Recovery
Well 5

Recovery
Wall 7
PURGING
Total
Volume
Date Time (Gal.) Method/Remarks
6/9/86 N/A N/A N/A

6/9/86 N/A N/A N/A

6/9/86 N/A N/A N/A

6/9/86 N/A N/A N/A
SAMPLING
Date Time Method/Remarks
6/9/86 1410-1430 Sample collected
directly from
discharge pipe.
Green colored
water.
6/9/86 1445-1500 Sample collected
directly from
discharge pipe.
Green colored
water.
6/9/86 1510-1545 Sample collected
directly from
discharge pipe.
Green colored
water.
6/9/86 1600-1630 Sample collected
directly frcrn
6/10/86   1010-1014       54
6/10/86   1112-1115       48
Submersible pump;
purge water to
B.A.L.

Submersible pump;
purge water to
B.A.L.
6/10/86
6/10/86
1205-1300
1230-1305
discharge pipe.
Water is clear.

Teflon bailer.
Teflon bailer;
partial sample,
inorganics only.

-------
           -24-

         TABLE 3

PURGING AND SAMPLING DATA

Well
Number
P5
MW-2
MW-3
MW-5
MW-4
P-9
PURGING
Total
Volume
Date Time (Gal.)
6/10/86 1620-1730 20
6/11/86 1025-1120 6.5
6/11/86 1040-1110 22
6/11/86 1546-1551 54
6/12/86 1020-1045 28.5
6/12/86 1236-1257 5

Method/Remarks
Teflon bailer;
water extremely
turbid.
Teflon bailer;
purge water to
D • A • J-» •
Teflon bailer;
purge water to
B.A.L.
Submersible pump;
purge water to
B.A.L.
Teflon bailer;
purge water to
D.A.LI.
Teflon bailer;
SAMPLING
Date Time Method/Remarks
6/11/86 0820-0915 Teflon bailer.
6/11/86 1258-1635 Teflon bailer;
sample collected
by sets of para-
meters due to
slow recharge.
6/11/86 1125-1140 Teflon bailer;
partial sample,
inorganics only.
6/11/86 1617-1650 Teflon bailer;
partial sample,
inorganics only.
6/12/86 1128-1340 Teflon bailer;
duplicate
sample.
6/12/86 1420-1715 Teflon bailer;
    purge water to
    B.A.L.
thunderstorm
delay approxi-
mately 15 mins.

-------
                                        -25-
                                      Table 4

                             ORDER OF SAMPLE COLLECTION
                         BOTTLE TYPE AND PRESERVATIVE LIST
         Parameter
    Bottle
Preservative*
Volatile organic analysis (VOA)

  Purge and trap
  Direct inject

Purgeable organic carbon (POC)

Purgeable organic halogens (POX)

Extractable organics

Pesticide/Herbicide

Dioxin

Total metals

Dissolved metals

Total organic carbon (TOC)

Total organic halogens (TOX)

Phenols

Cyanide

Ammonia

Sulfate/chlor ide/n i trate
2 40-ml VOA vials
2 40-ml VOA vials

2 40-ml VOA vials

2 40-ml VOA vials

4 1-qt. amber glass

2 1-qt. amber glass

2 1-qt. amber glass

1 1-qt. plastic

1 1-qt. plastic

1 .4-oz. glass

1-qt. amber glass

1-qt. amber glass

1-qt. plastic

1-qt. plastic

1-qt. plastic
     HN03

     HN03

     H2S04



 Sulfuric Acid

     NaOH

     H2S04
*A11 samples were stored on ice after collection and during transport to the
 analytical laboratories.

-------
                                    -26-





                            Facility Description





     Task Force personnel obtained information on past and present manu-



facturing and waste treatment operations to identify potential sources



of hazardous waste releases.  The information is identified in this section.





Process Operation



     SCM manufactures titanium dioxide, a non-toxic, non-hazardous white



pigment used in paints, toothpaste and Oreo Cookies, etc. at the Adrian



Joyce Works (AJW), located on Hawkins Point, Baltimore, Maryland.  This



facility has been in operation since 1955.  The plant operates two separate



and distinct production process systems [Figure 4]; the chloride process



(which qualifies for a hazardous waste exclusion under 40 CFR Part 261),



and a sulfate process, which generates regulated hazardous wastes.





     The two hazardous wastes generated in the sulfate process are Batch



Attack Mud (BAM) and spent sulfuric acid.  Batch Attack Mud (BAM) is the



residual waste sludge resulting from the extraction of the titanium



dioxide from the rutile ore.  It is hazardous due to corrosivity (pH<2)



and EP Toxic chromium content >5ppm.  This waste is stored and treated at



the Batch Attack Mud Storage and Treatment Pad.  After rendered non-hazar-



dous, it is landfilled at a dedicated off-site facility owned by SCM (the



SCM-Quarant ine Landf ill).





     Two spent sulfuric waste streams (20% and 8% spent acid, hazardous



respectively) are generated in the "Moore Floor" process.  These waste



streams are comingled and stored in the 14 acre Batch Attack Lagoon



prior to treatment in the primary waste acid neutralization (PWAN) and



secondary waste acid neutralization (SWAN) systems and discharge, under



NPDES permit 79 0164, to the Patapsco River.

-------
         FIGURE 4
SCM-AJW FACILITY LAYOUT
                                             NJ
                                             ^J
                                             I

-------
                                    -28-





     The neutralization in the PWAN system utilizes calcium carbonate



(aragonite) and generates synthetic gypsium (calcium sulfate dihydrate)



which is sold to U.S. Gypsum for wallboard and other gypsum products.






     The neutralization in the SWAN system also utilizes calcium carbonate



(aragonite) and also generates synthetic gypsum, however, this material



is too high in iron hydroxide content to be used in wallboard so it is



disposed of in the SCM-Quarantine Road Landfill.  It is a non-hazardous



waste.





     The Batch Attack Lagoon is an unlined surface impoundment which



receives approximately 1.4 million gallons per day of wastewaters.





     On October 14, 1981, State inspectors sampling the wastewater outfalls



were informed of a suspected underground leak from the Batch Attack Lagoon.



On November 18, 1981, the State issued Designated Hazardous Substances



Facility Permit A-109, which required compliance with groundwater monitoring



requirements upon receipt of the permit.  On February 10, 1982, State



inspectors sampled monitoring wells down-gradient of the lagoon and found



pH <1.0.





     On July 9, 1984, the State and SCM signed a Consent Order to install a



slurry wall down-gradient of the lagoon to block the flow of leachate from



the lagoon and to install recovery wells between the wall and the lagoon to



recovery leachate and return it to the lagoon.  Installation of this recovery



system was completed in November, 1984.

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                                   -29-


Solid Waste Management Units


     SCM-AJW identified sixteen  (16) solid waste management units (SWMUs)

[Figure 5].

          Unit No. 1 - upper settling basin;
          Unit No. 2 - middle settling basin;
          Unit No. 3 - lower settling basin;
          Unit No. 4 - Batch Attack Lagoon;
          Unit No. 5 - Batch Attack Mud treatment system;
          Unit No. 6 - Batch Attack Mud treatment and storage area;
          Unit No. 7A and 7B - spent solvent storage areas;
     0    Unit No. 8 - neutralization tanks at the chloride area;
     0    Unit No. 9 - previously existing aragonite pit system (closed
                       unit);
     0    Unit No. 10 - primary and secondary waste acid neutralization
                        system;
     0    Unit No. 11- - primary gypsum and secondary gypsum storage piles;
     0    Unit No. 12 - previously existing copperas storage area (closed
                        unit);
     0    Unit No. 13 - previously existing chloride-clay area (closed
                        unit);
     0    Unit No. 14 - 001 neutralization system;
     0    Unit No. 15 - 002 neutralization system;
     0    Unit No. 16 - triple tank sump.
     The RCRA Part B permit application includes Units 4, 5, and 6.  Units

1, 2, 3, 7A, 8, 10, 11, 14, 15 and 16 are RCRA regulated.  Units 7B, 9, 12,

and 13 were closed prior to RCRA.


No. 1 - Upper Settling Basin


     This 11.7 acre surface impoundment has been in operation since 1955.

It receives wastewaters from the chloride titanium-extraction process

which is excluded from RCRA regulation by Part 261.


     This basin serves to mix and store and equalize the flow of non-

contact cooling water, a neutralized waste stream and neutral product

rinsewater from the chloride process, neutralized weak acids from the

sulfate process during upsets (normally weak acids flow to the Batch

Attack Lagoon, and leachate from the SCM Quarantine Road landfill.  These

wastes are not hazardous.  No releases have been identified from this unit.

-------
                                                                            1 - upper settling basin;
                                                                            2 - Middle settling I
                                                                            ) - lower settling I
                                                                            4 - Batdi Attack !
                                                                            5-1
                                                                             - Batch Atuck Hud tr«*Mnt and storage area)
                                                                            7A and 7B - spent solvent storage areasi
                                                                            6 - neutralization tanks at the chloride areai
                                                                            9 - previously existing aragonite pit system (cloead
                                                                              unit))
                                                                            10 - primary and oecondary waste acid neutralization

                                                                            11 - prijnary gypsun and aeoondary gypctn storage pilasj
                                                                            12 - previously existing copperas storage area (closed
                                                                              unit);
                                                                            1) - previously existing chloride-clay area (closed
                                                                              unith
                                                                            14 - 001 neutralization system;
                                                                            IS - 002 neutralization systeni
                                                                            16 - triple tank sunf).
                                       FIGURE   5
LOCATION MAP  SOLID  WASTE MANAGEMENT UNITS

-------
                                   -31-
No. 2 - Middle Settling Basin





     This 6.2 acre surface  impoundment has been in operation since 1970.



This unit received dredge spoils from the lower settling basin.  Once



dewatered, these spoils are disposed in the SCM-Quarantine Road landfill.



The spoils are not a hazardous waste.  There is no record of a release



fron the unit.






No. 3 - Lower Settling Basin





     This 21.6 acres surface impoundment has been in operation since



1955.  This unit receives wastewater from the Upper Settling Basin.



Wastewater is discharged from this unit through a NPDES permitted outfall.



Settled solids are dredged and placed in Middle Settling Basin.  Neither



the solids nor wastewater is a hazardous waste.  There is no record of a



release.





No. 4 - Batch Attack Lagoon





     This 16 acre surface impoundment has been in operation since 1955.



This unit receives spent sulfuric acid waste streams which are hazardous



for corrosivity.  This unlined unit was identified as releasing its wastes



to the groundwater shortly after ground-water monitoring wells were



installed.  The facility installed a system of monitoring wells, an



asphaltic slurry wall and pumping wells in response to a Consent Order



signed by the State and SCM on July 9, 1984.  The rate, extent and



attenuation of seepage is, in part, addressed later in this report.






No. 5 - Batch Attack Mud Treatment System






     The Batch Attack Mud treatment system is an existing hazardous



management waste, used to treat batch attack mud since 1984.  This unit



is addressed in the Part B Permit application.  There is no record of any



releases from this unit.

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                                   -32-





No. 6 - Batch Attack Mud Treatment and Storage Area






     The Batch Attack Mud Treatment and Storage Area is an existing



hazardous waste management unit.  It has been in operation since 1977.



This unit is addressed in the Part B permit application.  There is no



record of any releases from this unit.





No. 7(A & B) Spent Solvent Storage Areas





     Drums of spent solvents have been stored at two locations at the



facility, designated 7A and 7B.





     Unit 7A is an existing SWMU which has been in use since 1985.  This



unit has a 12 x 12 foot concrete pad and complies with the RCRA storage



requirements.  Spent solvents from the facility's laboratories are stored



here for less than 90 days prior to shipment.





     Unit 7B is the prior solvent storage area.  This unit, addressed in



the Part B permit application, was used for less than 90 days storage of



spent solvents from the facility's laboratories prior to construction of



Unit 7A and this unit's closure.





     There are no records of any releases from these units.





No. 8 - Neutralization Tanks at the'Chloride Area





     The neutralization tanks at the chloride area, in operation since



1983, neutralize certain process wastes streams from the chloride process



(average 90 million gallons per year); they are exempt from the hazardous



waste permitting requirement because they qualify as "elementary neutrali-



zation units".  Waste acids containing unreacted ore, coke particles and



metal chlorides are mixed with in the three 2000 gallon tanks with alkaline



material and the wastewater is neutralized and discharged through a NPDES

-------
                                   -33-






permitted outfill.  Solids generated through treatment exhibit no hazar-



dous characteristics.  This waste, also exempted from regulation (ore



benefi ciation 40 C.F.R. § 261.4(b)(7)), is disposed of by landfilling.



There is no record of any releases frcra this unit.





No. 9 - Aragonite Pit System





     Prior to 1982, the waste stream is now processed through the



neutralization tanks at chloride unit was neutralized through a system



called the "aragonite pit".  The facility began using the pit in 1977.



The wastestream was injected into a bed of aragonite (calcium carbonate)



the neutral, non-hazardous mixture to a settling basin (see Unit No. 1,



Upper Settling Basin).  Dewatered solids were sent to the SCM Quarantine



Road landfill.





     Since replacement with the chloride tanks, the Aragonite Pit is used



for settling-out non-hazardous solids.  There is no record of any releases



from this unit.





No. 10 - Primary and Secondary Waste Acid Neutralization Systems






     This system known as PWAN and SWAN treats acidic wastestreames,



stored in the Batch Attack Lagoon, from the sulfate process with calcium



carbonate.  The primary treatment, or PWAN, consists of six, 20,000



fiberglass tanks.  The settled solids, calcium sulfate is sold for



synthetic gypsum.





     The secondary treatment, or SWAN, further treats this wastestream



with calcium carbonate in ten concrete reactors.  The wastewater is



discharged from an outfall with NPDES permit.  The settled solids are



landfilled at the SCM Quarantine Road site.

-------
                                    -34-





      There is no record of any releases from this unit.






 No.  11 - Primary Gypsum and Secondary Gypsum Storage Piles





      The Primary Gypsum Storage Pile holds this non-hazardous material



 prior to sale to U.S.  Gypsum for use in gypsum products.





      The secondary gypsum storage pile holds this non-hazardous waste



 prior to disposal in the SCM Quarantine Road landfill.





      Both storage piles have impervious concrete pads.





      Occasionally, spills occur when transferring these materials.  These



 spills are reported to be promptly cleaned up.  There is  no record  of any



 significant unrecovered releases from these storage pads.





 No.  12 - Closed Copperos Storage Area





      The closed Copperos Storage Area was built to provide a temporary



 storage area for ferrous sulfate heptahydrate, which was  a by-product



 fran the old sulfate process; used prior to January 1981.  This material,



 which exhibited none of the four hazardous characteristics, was stored  on



•an impervious 10,000 square foot, 6 inch thick concrete pad. Excess



 copperas was stored in a pile near the Upper Settling Basin.





      Most of it sold as a material for primary drinking waster treatment.



 When this process was  replaced with the current sulfate process,  the



 facility sold most of  this material and 21,660 tons of copperas was



 disposed at the SCM Quarantine Road landfill.





      "At the State's request, SCM disced the soil underlying the  overflow



 storage area, and ensured that the area was in a condition to be  suitable



 for general plant use." (from page 28 of the SWMU response letter from



 SCM-AJW dated May 28,  1985).

-------
                                   -35-





     Runoff frcm the storage pad was collected in a sump and discharged



to the Batch Attack Lagoon.  Run-off frcm the overflow storage pile



generally drained into the Upper Settling Basin.





No. 13 - Closed Chloride-Clay Area






     The chloride-clay area is a closed 375' x 200' storage area which,



beginning in 1970, was used to store plant debris (wooden pallets, building



siding, discarded hose, etc.) and in 1979 received Batch Attack Mud for ,a



brief period during a strike.





     "At the request of the State of Maryland, in 1982 SCM removed the



surface trash from the chloride-clay area.  The area was then graded.



Also, after discussions with the State, in September 1983, SCM removed



frcm the chloride-clay area a localized spot of low-pH batch attack mud



and transported this material to Quarantine Road and disposed of the



material in the hazardous waste cell.  The remaining material is not



hazardous" (from page 30 of the SCM-AJW SW1U response letter dated May



28, 1985).





     Core soil samples taken frcm around this area confirmed the absence



of any materials with a pH less than 2.0.





     There is no record of any other releases from this unit.





No. 14 - 001 neutralization System






     This existing SVMU began operation in 1976.  This unit consists of



three caustic storage tanks with a total capacity of 200,000 gallons, two



mixing boxes with agitators and a settling box.  An average of 3.65

-------
                                   -36-





billion gallons per year of non-contact cooling water, surface storm



wastes run-off and the batch attack scrubber water is neutralized with



caustic pads prior to discharge via a NPDES permitted outfall.





     There is no record of any releases from this unit.





No. 15 - 002 Neutralization System





     This existing SVMU began operation in 1976.  This unit consists of a



caustic storage tank and a mixing area which receives wastewater from the



Upper Settling Basin and neutralizes it to a pH range of 6 to 9.  The



treated wastewater is discharged to the Lower Settling Basin.





     There is no record of any releases from this unit.





No. 16 - Triple Tank Neutralization System





     The Triple Tank Neutralization System is an existing SVMJ, which



began operation in 1976.  This unit serves as an "upset" backup system to



pumps for weak acids and to the Batch Attack Lagoon consists of three



caustic storage tanks with a combined capacity of 70,000 gllons.  Excur-



sions of weak acid flows fron the weak acid sump and leachate from the



Quarantine Road landfill are neutralized.  Treated wastewater is discharged



to the Upper Settling Basin.





     There is no record of any releases from this unit.

-------
                                   -37-


                            Site Hydrogeology


     Information regarding the hydrogeology of the SCM-Adrian Joyce

facility is limited.  Site specific information was developed by Garaghty

and Miller, Inc. and Century Engineering, Inc. during (1) the installation

of monitoring wells in 1981, (2) the construction and installation of an

asphaltic slurry wall in October, 1984 and (3) the installation of seven

groundwater recovery wells and seven monitoring wells in November, 1984.

The following information was derived from the above information unless

otherwise noted.


     The SCM-AJW site is underlain by geologic formations which consist

of lower Cretaceous sediments of the Potomac Group.  The uppermost

member of the Potomac Group is the Patapsco formation which consist

primarily of unconsolidated interbedded deposits of clay and sand, which

serve as confining beds and aquifers, respectively.  The Patapsco formation

has an upper and lower section which, when combined is reportedly about

500 feet thick.  SCM-AJW reports that the formation is about 250 feet

thick at the site.  Underlying the Patapsco formation is the Arundel

Clay, which is the middle member of the Potomac Group.  This formation

consist of red, brown, and gray clay and contains some iron nodules and

plant remains.  The Arundel clay is reportedly 250 feet thick and is the

confining bed between the Patapsco formation and the Patuxent formation.

The Patuxent formation is the bottom member of the Potomac Group and

consist of gray and yellow sand with interbedded clay.  The Potomac Group

is underlain by a basement complex of bedrock predominantly consisting of

gneiss, granite, gabbro, metagabbro, quart diorite, and grantized schist.*
* Frederick K. Mack and Grufron Achmad, "Evaluation of the Water - Supply
Potential of Aquifers in the Potomac Group of Anne Arundel County,
Maryland", Maryland Geological Survey, Report of Investigations No. 46,
1986, pp.5-8.

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                                   -38-





Hydrogeologic Units



     Information collected during the installation of the M-series



monitoring wells in 1984 indicates that the upper most aquifer at the



facility has been identified.  However, recovery.wells installed adjacent



to the M-wells and during the same time period reveals conflicting



information about the lithology of the sub-strata.  The following describes



hydrogeologic conditions at the site as interpreted from site characterization



work done to date.





     Under RCRA interim status requirements, the uppermost aquifer must



be monitored (265.90(a)].  An "aquifer" is defined [260.10] as a "geologic



formation, group of formations, or a part of a formation capable of



yielding a significant amount of ground-water to wells or springs".  The



"uppermost aquifer" is defined as "the geologic formation nearest the



natural ground surface that is an aquifer, as well as lower aquifers that



are hydraulically interconnected within the facility".





     State regulations [10.51.05.06 A(l)] require a "monitoring program



capable of determining the facility impact on the quality of groundwater



in the uppermost aquifer underlying the facility".





     During the construction of the P-series wells in 1981 and the M-



series wells in 1984, unconsolidated sediments were penetrated to a depth



of 50 feet in some borings.  Ground water was encountered in all borings



in a sand zone at a depth approximately equal to near sea level.  Logs of



the borings are presented in Appendix A.





     The major water bearing zone penetrated during the installation of



the monitoring wells consist of an unconfined alluvial, beach sand unit



which has been identified and monitoried as the uppermost aquifer.  This

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                                   -39-





saturated sand layer ranges  in thickness from about 15 to 30 feet along



the shoreline of the Patapsco River and thins in a westerly direction to



where it does not exist in the vicinity of the Batch Attack Lagoon.



Underlying these alluvial deposits a clay to silty clay zone has been



penetrated and identified as the Patapsco formation.  The formation grades



from silty clay along the eastern section of the Batch Attack Lagoon to



clay in the vicinity of upgradient monitoring well P-5.





     Monitoring well P-5 penetrated approximately 50 feet of brown clay



before being completed in a thin layer of clean sand.  Ground water was



encountered within this sand layer and the ground-water, elevation in P-5



is higher than the elevations measured in the M-series wells.  Hydraulic



communication between this sand layer within the Patapsco formation and



the batch attach lagoon liquids and beach sands has not been determined.



Therefore upgradient well P-5 may not be monitoring the same water bearing



unit as the downgradient M-series wells.





     Ground water elevations measured by the Task Force during low and



high tide stages indicate a change in head in the M-series wells ranging



from .26 feet in well M-6 to .71 feet in well M-4.  Ground-water elevations



in monitoring well P-5 did not respond to the change in tides.  Water



levels slightly decreased in monitoring wells P-6 through P-ll during



high tide and increased during low tide.  Recovery wells 3, 4, 5, 6, and



7 were pumping at intervals during tide changes and water level measure-



ments.  The changes in head within the M-series wells indicates ~ connec-



tion between the Patapsco River and the beach sand aquifer.  The volume



of water entering the beach sand aquifer during tide changes has not



been determined.  Despite the connection between the Patapsco River



and the beach sand aquifer, acidic conditions still exist in the ground



water on the River side of the slurry wall.

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        -40-




       TABLE 5




DEPTH-TO-WATER DATA1
                                        Task Force Data
Well Number
M-l
M-2
M-3
M-4
M-5
M-6
M-7
P-5
P-6
P-7
P-8
P-9
P-10
P-ll
Total Well Depth Top of Surface Water-Level Elevation Z'J
(ft.) 6/13/86 Casing Elevation3 6/9/86 (Low Tide) 6/10/86 (High Tide)
20.00
24.40
13.93
20.99
33.70
33.10
28.34
49.80
33.63
50. OO4
31.57
31.94
27.66
32.35
1. All measurements are reported from
2. Measured with a tape calibrated to
3. Elevations referenced in feet above
4. This value is
* WA! 1 facinn Vv
from original boring
»nf- . fif»1H mf^aejiiKprnonl-
23.4
23.2
6.7
6.7
6.8
6.6
6.7
26.80
25.40
24.4
24.40
23.70
23.80
23.60
the top of the surface casing.
1/16 inch and converted to feet for
or below mean sea level.
log.
<5 r-oiilrl not- Ho m3r1f».
6.35
1.88
0.79
0.10
-0.30
0.20
-0.10
17.95
0.64
*
-0.16
0.40
-5.46
-0.05
table.

6.35
1.78
1.1
0.81
0.03
0.46
0.59
17.96
0.55
*
-0.17
0.34
-5.64
-0.22



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                                    -41-






               Ground-Water Monitoring Daring Interim Status





     Ground-water monitoring at the SCM-AJW facility has been conducted



entirely under State regulations.  The State of Maryland was authorized by



the U.S. EPA to carry out a hazardous waste program equivalent to the RCRA



Federal program of regulation codified in 40 C.F.R.  124, Part 260-270.



Maryland obtained Phase One authorization on July 8, 1981, Phase Two Compo-



nent A in November 1983 and Components B and C on July 9, 1984.  Final



authorization was received on February 11, 1985.  RCRA treatment, storage,



and disposal (TSD) facilities in Maryland are thus subject to the Maryland



hazardous waste management regulations in lieu of Federal regulations,



excepting statutory authorities of the RCRA amendments.





     SCM-AJW implemented an interim status ground water monitoring program



in February, 1982, five months after a ground water sampling and analysis



plan was submitted.  Samples were collected from the P-series wells on a



quarterly basis from February 17, 1982 (1st quarter) until November 5,



1982 (4th quarter).  Records submitted by SCM indicate that complete repli-



cate measurements for the indicator parameters as required by COMAR



10.51.05.06 C(3) were not made.  For example, sampling records for the



first quarter reveal no replicate measurements for pH, TOC and TOH indicator



parameters and no measurement at all for specific conductance.  Subsequent



quarterly sampling events revealed replicate measurements only for pH and



specific conductance.  After the first quarterly sampling period, SCM sent



a letter to the State requesting a waiver of the following parameters from



the sampling program:  phenols; endrin; lindane; methoxychlor; toxaphene;



2,4, D; 2, 4, 5TP (silvex); coliform bacteria; gross   and gross B; radium



226 and radium 228.  The basis for the waiver, as explained by SCM, was



that the above materials are not manufactured, have never been manufactured



and are not planned to be manufactured at the SCM-AJW Facility.

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                                    -42-





Although there are no records of correspondence from the State to SCM



granting this waiver request, the above parameters have not been sampled for



since the first quarter sampling event.  Finally, sampling records indicate



that the determination of ground water elevations during each sampling



event, as required by COMAR 10.51.06.06C(3), have not been made.





     In June, 1983 SCM-AJW began semi-annual sampling and performed a



statistical evaluation of the data.  The results of the student "t" test



revealed significant decreases in pH values for downgradient monitoring



well P-6, P-8, and P-^IO.  SCM continued to conduct semi-annual sampling in



February and August, 1984.  Statistical evaluations were also performed on



the data collected from these sampling events and significant differences



in indicator parameter values were identified.  Although statistical evalu-



ations of the data indicated ground-water contamination at the facility,



SCM did not enter into a groundwater quality assessment program.





     In November, 1984 a new groundwater monitoring system was installed in



response to the consent order and agreement signed .in July, 1984.  This new



system, designated as the M-series wells, consist of seven downgradient



wells installed on the River side of the asphaltic slurry wall.  A new



upgradient well was not installed as part of this system.  Quarterly sampling



for the M-series wells began in January, 1985 and includes the same parameters



that were sampled for in the P-series wells.  Although a new monitoring



system was installed, an updated sampling and analysis plan was not prepared



nor was the original plan revised.  Samples were collected from the new



(RCRA) wells using methods outlined in the original plan.

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                                         -43-


         The following is an evaluation of the monitoring program between

    February, 1982 and June, 1986, when the Task Force investigation was

    conducted.  This section addresses:


         0    Regulatory requirements

         0    Ground-water sampling and analysis plan

         0    Monitoring wells

         0    Sample collection and handling procedures

         0    Ground-Water Quality Assessment Program CXitline and Plan


    Regulatory Requirements


         The Maryland requirements for ground-water monitoring during interim

    status are contained in Section 10.51.05.06 of Regulation counterparts are

    shown in Table 6.


                                       TABLE 6


              STATE AND FEDERAL COUNTERPART INTERIM STATUS REGUALTIONS
                                    Maryland State
                                      Regulation                      RCRA Regulation
Subpart Title	Section 10.51.05.06	40 C.F.R. Part
Applicability
Ground-water Monitoring
System
SampKAg and Analysis
Preparation, Evaluation
and Response
Reporting and Recordkeeping
A.
B.
C.
D.
E.
265.90
265.91
265.92
265.93
265.94

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                                     -44-





Ground-Water Sampling and Analysis Plan





     The regulations require an owner/operator to develop and follow a sampling



and analysis plan which includes procedures and techniques for: (1) sample



collection, (2) sample preservation and shipment, (3) analytical procedures



and (4) chain-of-custody control.  The Task Force evaluated the ground-water



sampling and analysis plan submitted by SCM in September, 1981 and found it



to be inadequate as necessary details are emitted.  Also, the plan was devel-



oped, for and implemented on the p-series wells which have been placed out of



service since the m-series monitoring wells were installed in November, 1984.



The plan was not revised or updated to address the new monitoring system.



The findings of this plan are presented below.





     In general the plan discusses equipment and procedures that should be



used during sampling and analysis instead of what will be used.  For example,



the section on sample collection does not specify methods and equipment used



to purge and sample the wells.  The plan does not indicate whether the sampling



equipment is dedicated to individual wells, nor does it address disposal of



the purge water and the method of filtering samples.  Procedures for decon-



tamination of purging and sampling equipment and the disposal of decontami-



nation water are not adequately addressed.  Although the section addresses



making field measurements for temperature, specific conductivity and pH,



procedures for making these field measurements or for calibrating the instru-



ments are not included.  Also, no procedures are described for making the



required quadruplicate measurements for the indicator parameters.





     The sample preservation methods in the plan are contrary to EPA recom-



mended methods for the preservation of TOC samples.  The plan indicates that



sulfuric acid is used rather than hydrochloric acid to a pH of less than 2.



The samples taken for chloride require cooling to 4°C, yet the table listing

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                                     -45-


preservation in the plan does not require any preservative.  Also, preser-

vation methods for TOX, Radium, Gross Alpha and Gross Beta are not mentioned

in the table and reference is made to EPA guidelines and regulations.  The

plan does not indicate the method of verifying that samples have been preserved

to the appropriate pH.  Quality assurance and quality control procedures are

not discussed in the plan.


     In summary, the plan needs to be updated to address the current ground

water monitoring system consisting of the M-series wells.  Also, revisions

are needed to ensure consistent sampling methods and collection of representative

samples.

Monitoring Wells


     SCM initiated RCRA ground-water monitoring in February, 1982.  The

monitoring network consisted of seven monitoring wells installed in December,

1981 [Figure 6].


          Upgradient           P-5

          Downgradient         P-6
                               P-7
                               P-8
                               P-9
                               P-10
                               P-ll


     Interim status monitoring was conducted at the P-series wells fron

February, 1982 until August, 1984.  During this period it was determined,

through statistical evaluations, that ground-water contamination had occured

at the facility.  As a result  a new ground-water monitoring system was

installed as part of a consent order and agreement between SCM and the State

of Maryland.  This new system was installed in November, 1984 and consisted

of seven downgradient monitoring wells designated as M-l through M-7 [Figure

7].  Monitoring well P-5 was not replaced and remains as the upgradient

well.

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             -46-
        FIGURE 6
P-SOTES MONITORING WELLS

-------
            -47-
BATCH ATTACK LAGOON
         FIGURE 7
M-SEHES MOMTOriING WBLJLS

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                                     -48-





Well Construction





     The M-series RCRA monitoring wells were constructed between November 12



and 15, 1984 with a mud rotary rig;.  Records of well installation were



maintained by Century Engineering; copies of these records are in Appendix A.



Generally, the well borings were drilled to the top of the clay zone, directly



beneath the beach sands.  The borings were then advanced one to three feet



into the clay and stopped.





     The wells were completed using 4-inch diameter PVC casing with PVC well



screens ranging from 5 to 20 feet in length.  All casing and screens had



threaded connections; adhesives were not used.  The annular space around the



screen was filled with a filter sand that extended from the bottom of the



well to a level even with the top of the screen to about 1.5 feet above the



top of the screen.  The remainder of the annular space was filled with a



cement grout to the surface.  A bentonite seal was not used.  A 6-inch dia-



meter steel surface casing, 8.7 feet long, was set1 into the grout around the



outside of the PVC well casing..  The upper portion of the surface casing was



equipped with a wood box, with a locking hood to prevent unauthorized access.



Following construction the wells were developed using compressed air.





     Upgradient monitoring well P-5 was installed on December 8, 1981.  This



well was completed using 2-inch diameter PVC casing with a 5 foot PVC well



screen.  The annular space around the screen was filled with a filter sand



that extended from the bottom of the well to a level about 30 feet above the



top of the screen.  A 1-foot thick bentonite seal was placed above the filter



pack.  The remainder of the annular space was filled with cement grout to



the surface.  An outer cast iron surface casing, about 1.65 feet above the



ground surface and equipped with a locking cap, was set into the grout around



the outside of the PVC well casing.  Additional construction details for



well P-5 and the M-series wells are presented in Table 7.

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                                       -49-
                                     TABLE 7

                  CONSTRUCTION DETAILS FOR INTERIM STATUS WELLS*
WELL
NUMBER
P-5
M-l
M-2
M-3
M-4


M-5
M-6
M-7
DATE
COMPLETED
12/08/81
11/12/84
11/12/84
11/14/84
11/15/84


11/15/84
11/14/84
11/13/84
TOTAL
DEPTH*
(ft.)
50
17
25
17
17


37
37
35
SCREENED**
INTERVAL
(ft.)
45.0-50.0
11.0-16.0
18.8-23.8
3.0-13.0
7.0-17.0


11.0-31.0
10.0-30.0
10.0-30.0
FILTER PACK
INTERVAL**
(ft.)
15.0-50.0
9.5-17.0
18.0-25.0
3.0-17.0
6.0-17.0


10.0-37.0
9.5-37.0
9.7-35.0
STRATA
MONITORED
Sand
Sand, silty
clay, red clay
Tan, silty clay
red clay
Beach sand
Beach sand,
red-brown
clay
Beach sand
Beach sand
Beach sand
*  All Data from Century Engineering Record of Well Installation [Appendix B].
** All depth referenced in feet below ground surface.

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                                     -50-





     Althoiigh the construction was generally adequate, seme problems were



found during the onsite inspection and records review.  The total depth of



seme of the M-series wells, measured during the inspection, was shallower



than what was reported in the construction details suggesting possible silting



in of these wells.  State regulation [10.51.05.06 B(3)] requires all monitoring



wells to be cased in a manner that maintains the integrity of the monitoring



well bore hole.  The PVC casing in monitoring well P-5 was very loose, possibly



cracked, near the ground surface.  The concrete aprons around the wellheads,



which are supposed to drain surface water away, did not exist at monitoring



well P-5 and were completely uprooted frcm the ground surface at monitoring



wells M-3 and M-7.





     The Task Force attempted to sample well M-l during the inspection, but



this well was not developed after construction and did not contain any



significant amount of water.  Monitoring well M-2 was sampled and produced



very turbid water at an extremely slow rate.  This suggest possible defici-



encies in the sand pack, screen or well development.  These problems need to



be identified and corrected.

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                                     -51-



Vfell Locations





     The location of the downgradient RCRA monitoring wells (M-series) was



based on the location of the asphaltic slurry wall.  Ground water flow



direction was interpreted as being east, towards the Patapsco River and the



M-series wells are located on the beach between the slurry wall .and the



Patapsco River.  Upgradient monitoirng well P-5 is located west of the



batch attack lagoon.





     Although monitoring well P-5 is hydraulically upgradient, boring logs



indicate that this well may be monitoring a different lithologic unit than



the downgradient wells.  Well P-5 is screened in a sand lense within the



Patapsco formation and the M-wells are screened in beach sand materials



considered to be the uppermost aquifer.  The beach sand materials form a



wedge thinning to the west to where it is not present in the subsurface at



well P-5.  It has not been determined if the sand layer penetrated in P-5



is hydraulically connected to the beach sand aquifer.  State regulation



10.51.05.06 B(l)(i) requires an upgradient monitoring well sufficient to



yield ground water samples that are representative of background groundwater



quality in the uppermost aquifer near the facility.  The sand lense within



the Patapsco formation may not represent the uppermost aquifer and P-5 may



not be an appropriate upgradient well.  Also, dust clouds are generated from



truck traffic in the vicinity of well P-5 which could affect groundwater



quality.  Further investigation is necessary before a suitable location for



a background well can be identified.






SCM Sampling Procedures






     Personnel from the SCM-AJW facility collect samples for the required



interim status monitoring.  SCM was asked to demonstrate their sampling



procedures, and on June 13, 1986 a demonstration was provided at monitoring



well M-3.

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                                     -52-
Water Level Measurements





     Prior to entering measuring, purging or sampling equipment into the



well, a plastic sheeting was placed on the ground surface around the base



of the well to protect sampling equipment and prevent contaminated ground



water from spilling on the ground surface.  To determine the volume of



water in the well casing for calculating purge volumes, water level measure-



ments are taken at each well.  A weighted measuring tape, that sounds



the water surface, is used to make water level measurements and to measure



total depth of the well.  The tape is lowered into the well and a sound is



made when the weight hits the water surface.  At this point, the measurement



on the tape at the top of the casing, is recorded.  The tape is marked in



foot increments.  The total depth of the well is then measured by allowing



the weighted end of the tape to rest on the bottom of the well.  The depth



to water is subtracted fron the total depth of the well to determine the



length of the water column and volume of water in the well.  As the tape



retrieved frcm the well it is decontaminated with deionized water and dried



with kim wipes.  The elevation of the ground water surface, as required by



State regulation 10.51.05.06 C(5), was not determined.





     Using this method for water level measurement is not acceptable as the



use of a sound measuring tape requires some interpretation of where the



water level is located.  The tape must be lowered in a manner that causes an



impact on the water surface sufficient enough to make a sound.  This can be



influenced by the ability of the sampling personnel to stop lowering the



tape at this moment.  The precision and accuracy of the water level measure-



ments is questionable.

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                                    -53-






Purging



     Monitoring records indicate that before sampling,  the M-series wells



are usually purged of about three volumes, although on at least one occasion



only one volume was removed.  IXiring the demonstration three volumes were



removed.  As discussed in the previous section, the volume of water in the



casing is determined by first calculating the height of the standing water



in the well casing by substracting the depth-to-water measurement from the



total well depth measurement.  Next, the volume is calculated by multiplying



the water column height by a gallon-per-foot-of-casing conversion factor.





     Monitoring records indicate that SCM-AJW personnel uses a teflon bailer



to purge water from wells P^-5 and M-2 and pumping methods to purge wells M-



3 through M-7.  A teflon bailer was used during the demonstration and was



decontaminated will distilled water.  SCM uses a stainless steel submersible



pump that is lowered into the well using polypropylene rope.  The rope



is discarded after each well is purged.  The pump is decontaminated by



placing it into a drum of tap water and allowing it to run for a few minutes.





     The volume of water purged is calculated from the volume capacity of



the bailer and the estimated pump discharge rate and length of pumping



time.  The pump discharge rate is reportedly calculated from the time



required to fill a 5-gallon container; however, this is not indicated on



the monitoring records.  Purged water is collected in a 55-gallon drum,



when bailing, and pumped or hand-carried to the batch attack lagoon where



it is discharged.  When pumping, the purge water is pumped directly to the



lagoon.





     In summary, some aspects of the sampling and analysis plan were not



followed.  The plan suggest that either a bailer or perestaltic pump be



used to purge the wells.  For most of the wells, a submersible pump is



used.  SCM decontaminates the pump with tap water and the plan suggest



distilled water.

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                                    -54-
Sample Collection





     After purging the wells, each is sampled using a 12-feet long, 2-inch



diameter pvc bailer with a volume capacity of approximately 7 gallons.  The



bailer is lowered into the well using a polypropylene rope, which is dis-



carded between wells.  During the demonstration, the bailer was observed



to be rapidly lowered into the well, causing agitation of the water column.



Dedicated bailers are used for each well and the bailers are placed in



individual carrying tubes; however, the bailers and the tubes are not marked



to identify which bailer is to be used for individual wells.  The bailers



are decontaminated on-site using deionized water.  Additional decontamination



occurs in the on-site laboratory.





     Generally, the monitoring records indicate a time period during which



the wells are sampled.  Specific sampling times for individual wells are



not recorded.  SCM indicated that upgradient well P-5 is sampled first



followed by the down-gradient wells.  There is no specific order for



sampling these wells.  The groundwater sample is collected in a one-gallon



pvc bucket; individual containers are not used at the wells.  The one-gallon



bucket is taken to the laboratory where samples to be analyzed at the of f-



site laboratory are transferred to designated containers.  The preservatives



for metals are added at this time.  Samples to be analyzed on-site are



withdrawn from the bucket.  The pvc buckets are disposed of after each



sampling event.





     Field data forms indicate that measurements for temperature, specific



conductance, and pH are made in the field.  The physical appearance of the



sample is also recorded.  Field measurements were not made during the



demonstration.

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                                    -55-





     The sample collection methods need improvement.  Samples should be



transferred from the sampling devise directly into designated sampling



containers containing the appropriate preservative, if necessary.  Collecting



the samples in a common container and transferring to individual containers



allows for the potential of the sample to be exposed to foreign materials.



Also, unnecessary agitation of the sample occurs while transferring the



sample twice.  The sample is not representative of what is removed from the



well during the sampling.  Decontamination methods need to be improved and



the bailers and carrying tubes need to be marked in order to determine



which bailer is to be used at a specific well.  The bailers need to be



lowered into the well column in a manner that doesn't allow for agitation



of the water.  Finally, the collection of field blanks should be described



and recorded in the field data forms and include procedures and types of



blank water used and volumes collected.






Shipping and Chain of Custody



     Chain-of-custody forms are filled out before submission of samples to



the contracted laboratory.  Custody forms are not filled out for samples



analyzed by the SCM-AJW on-site laboratory.  Chain-of-custody procedures



described in the sampling and analysis plan are vague and the plan refers



to EPA guidance when additional information is needed.  Samples for off-



site analysis are packed in coolers with ice and shipped to the laboratory.



Copies of completed chain-of-custody forms were not available during the



Task Force inspection.

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                                    -56-
          Ground-Water Quality Assessment Program Outline and Plan


     State regulations [10.51.05.06 D(l)] require a facility to prepare an

outline of a ground-water quality assessment program effective November 18,

1981.  The outline must describe a more comprehensive ground-water program

than the one for routine interim status monitoring and be capable of

determining:


     1.   Whether hazardous waste of hazardous waste constituents have
          entered the groundwater.

     2.   The rate and extent of migration of hazardous waste or hazardous
          waste constituents in the groundwater.

     3.   The concentrations of hazardous waste or hazardous waste constituents
          in the groundwater.


Assessment Outline


     A ground-water quality assessment outline was submitted to the WMA in

September, 1981.  This outline did not receive a written approval from WMA

nor was it revised or updated to address the monitoring system (M-series

wells) installed in November, 1984 and presently used in the ground water

monitoring program.  Although the outline describes a more comprehensive

ground-water monitoring program, it needs to address the following items

which are either omitted or are not clearly indicated:


     0  How volume/concentrations of released contaminants would be
        determined.

     0  How a monitoring plan would be developed and the projected sampling
        frequency.

     0  Which aquifer(s) would be monitored.

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                                    -57-
Assessment Program Plan






     State regulations [10.51.05.06 D(4)(b)] require an assessment plan to



be submitted, based on the assesment outline, which specifies: (1) the



number, location, size and depth of wells; (2) sampling and analytical



methods for those hazardous wastes or hazardous waste constituents in the



facility; (3) evaluation procedures, including any use of previously gathered



ground-water quality information; and (4) a schedule of implementation.





     In June, 1983, SCM-AJW performed a statistical evaluation of ground-



water monitoring data and the results indicated significant decreases in pH



values for certain downgradient P-series wells.  Subsequent semi-annual



statistical evaluations were performed and the results also indicated



significant differences in indicator parameters.  Although these evaluations



indicated ground-water contamination SCM-AJW did not prepare and submit a



ground-water quality assessment plan to the WMA.  It was not until over a



year after the first statistical evaluation was performed that the ground-



water situation was addressed.  In July, 1984 SCM-AJW and the WMA entered



into a consent order and agreement which required the implementation of a



corrective action program at the facility.

-------
                                    -58-






       KVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE RELEASE





     This section presents an analysis of Task Force data regarding indica-



tions of apparent leakage from the waste management unit.  Analytical



results from and methods used on samples collected by Task Force personnel



are presented in Appendix B.





     VOA data are quantitative, all other organic data are deficient to



some degree.  Quantitative inorganic data is available for the following



parameters Al, Sb, As, Cd, Cr, Cu, Fe, Mg, Mn, Hg, K, Ag, Na, V, and Zn.



Reliable qualitative data includes Be, Ca, Co, Pb, Ni, NH4, CN POX and TOX



were used to evaluate the batch attack lagoon at SCM-AJW for waste release.



Table 8 lists the relative concentrations of each of these parameters for



the various monitor and recovery wells at the site.





     Monitor well P-5 is upgradient relative to the batch attack lagoon.



No VOAs, Sb, As, Cd, Cr, Ag, or V were detected in well P-5.  Low concen-



trations (relative to the lagoon's) of Al, Ca, Co, Cu, Fe, Pb, Mg, Mn, Ni,



K, and Zn were detected.  Na and Be in all of the wells and the lagoon



were detected at relatively similar concentrations.  Well P-5's pH of 4.7



was relatively low but was assumed to represent background levels for the



area due to its location.





     Monitor well P-9 is located adjacent to the lagoon on the berm.  No



Sb, Cd, or As were detected.  Be, Ca, Co, Cr, Mg, Mn, Ni, Ag, and V



concentrations and pH were similar to those detected in the lagoon.  Acetone,



benzene, Al, Cu, Fe, Pb, K, Na, and Zn concentrations were at least one



order of magnitude higher than those detected in the lagoon.

-------
                                    -59-






     All recovery wells are located between the lagoon and the asphaltic



slurry wall.  No As or \KDAs were detected in recovery well R-2.  All other



parameters of interest were detected at levels comparable to those found in



the lagoon except Al, Cu, and Pb.  These parameters occurred in concentra-



tions at least one order of magnitude greater than in the lagoon.  All



recovery wells showed a pH of several units below that found in Well P-5



(0.5-3).





     Recovery well R-3 contained no detectable VDAs or Cd.  All other



parameters of interest occurred at levels comparable to those encountered



in the lagoon except Al, As, Cu, K, Na, and Pb.  These parameters occurred



in concentrations at least one order of magnitude greater.





     Recovery well R-5 contained no detectable VDAs.  All other parameters



of interest occurred at levels comparable to those found in the lagoon



except Al, As, Cu, K, Na, and Pb.  These parameters occurred in concentra-



tions at least one order of magnitude greater.





     Recovery well R-7 contained no detectable Sb, Cu, or Pb.  Co, Cr, Mn,



Ni, Ag, V and a pH of 2.3 was measured which is greater than the concentra-



tions and pH of the lagoon but significantly lower than monitor well P-5.



Benzene, Al, As, Be, Ca, Cd, Fe, K, and Zn occurred at concentrations



comparable to those found in the lagoon.  Acetone, Mg, and Na were detected



in concentrations at least one order of magnitude greater.  Carbon disulfide



was also detected in well R-7.

-------
                                    -60-
     All monitor wells are located between the asphaltic slurry wall and



the river.  Monitor well M-2 contained no detectable benzene.  All other



parameters of interest occurred at levels comparable to the lagoon's except



Alf As, Cu, Fe, Pb, and K.  These parameters occurred at concentrations at



least one order of magnitude greater.  The pH of all monitor wells was



significantly lower than the pH measured in well P-5.





     Monitor well, M-3 contained no VOAs Sb, or Cd.  Co, Mn, Nif Ag, and V



occurred in concentrations at least one order of magnitude less than those



found in the lagoon but significantly greater than in monitor well P-5.



Al, Be, Ca, Cr, Cu, Fe, Pb, Mg, K, Zn, and pH were present in levels



comparable to those found in the lagoon.  As and Na were detected in



concentrations at least one order of magnitude greater.





     Monitor well M-4 contained no detectable Cd.  All other parameters of



interest occurred at levels comparable to those found in the lagoon except



acetone, Al, As, Ca, Fe, and Pb.  These parameters occurred in concentrtions



at least one order of magnitude greater.  Carbon Disulfide and methylene



chloride were also detected.





     Monitor well M-5 contained no detectable VOAs or Sb.  Co, Mn, Ni, Ag,



and V were detected at concentrations at least one order of magnitude less



than in the lagoon but significantly greater than in monitor well P-5.  All



other parameters of interest occurred at levels comparable to those found



in the lagoon except As, Mg, and Na.  These parameters occurred in



concentrations at least one order of magnitude greater.

-------
                                    -61-






     Monitor well M-6 contained no detectable Sbf Cd, or Ag.  Co, Pb, Mn,



and Ni were detected in concentrations comparable levels in to monitor well



P-5.  Al, Cr, Fe, V, and Zn were detected in concentrations at least one



order of magnitude less than in lagoon but significantly greater than in



monitor well P-5.  All other parameters of interest occurred in levels



comparable to those found in the lagoon except Cd, Mg, Ag, and Na.  These



parameters occurred in concentrations at least one order of mignitude



greater.  Carbon disulfide was als detected.





     Monitor well M-7 contained no detectable VQAs or Sb.  Cr, Co, Fe, Mg,



Mn, Ni, Ag, and V were detected in concentrations at least one order of



magnitude less than in the lagoon but significantly greater than in monitor



well P-5.  All other parameters of interest occurred at levels comparable



to those found in the lagoon except As and Na.  These parameters occurred



at concentrations at least one order of magnitude greater.





     The results of the chemical analyses indicate that a release frcm the



batch lagoon has occurred (Table 9).  Recovery wells R-2, R-3, and R-5 and



monitor well P-5 contained all of the parameters of interest, with two or



three exceptions each, at concentrations at least as high as those found in



the lagoon.  Recovery well R-7 contained half of the parameters in



concentrations at least as high as in the lagoon.  Monitor well M-2 and M-4



contained all of the parameters of interest, with one exception each, at



concentrations at least as high as in the lagoon.  Monitor wells M-3, M-5,



M-6 and M-r7 contained all of the parameters of interest with three or four



exceptions each.  Approximately 75% of the parameters detected in monitor



wells M-3 and M-5, and approximately 60% of the parameters detected in

-------
                               -62-





monitor wells M-6 and M-7, were detected in concentrations at least as



great as in the lagoon.  The pH measured in all of the wells, with the



exceptions of recovery well R-7 and monitor wells P-5 and M-7, was identical



to that reported for the lagoon.  The pH for wells R-7 and M-7 was inter-



mediate to well P-5 and the lagoon.





     The distribution and relative level of each parameter for the wells



indicate waste release to ground water beyond the confines of the asphaltic



slurry wall.  Parameters listed in Table 9, except Be and Na, are all



components of the wastes in the lagoon.  The pattern of contaminants



indicates waste migration primarily to the north and east and somewhat to



the southeast.  The pattern of contaminants indicates waste migration



primarily to the north and east and somewhat to the southeast.  The anoma-



lous occurrence of methylene chloride and carbon disulfide may suggest



that the reported lagoon sample is not representative of all wastes in the



lagoon.  Concentrations of Pb, Mg, Mn, and Ni reported for monitor well



P-5 are high enough to suggest an influence from the lagoon or another



potential upgradient source.

-------
                             -63-
                                 TABLE 8

             DATA SUMMARY  OF WASTE COMPONENTS  IN WELLS
WASTE COMPONENTS   PS
P9
R2    R3
R5    R7
                                                    M2
                                 M3
                                  M4
MS
                                                                          MS
                                                        M7
Acetone
Carbon Dlsulflde
Methyl ene
Chloride
Benzene
Al
Sb
As
Cd
Cr
Cu
Fe
Mg
Mn
K
Ag
Na
V
In
Be
Ca
Co
Pb
N1
pH
0
0

0
0
-
0
0
0
0
-
-
-
-
-
0
-
0
-
-
-
-
-
-
-
+
0

0
+
+
0
0
0
a
+
+
•
-
•».
m
•f
.
+
-
.
«'
•f
. '
•
0 0
0 0

0 0
0 0
+ +
.
0 +
0
a
•f >
•
•
-
. .
-
a a
a a
'a a
a a
a a
• a
•f +
• a
a •
0
0

0
0
•f
-
+
a
-
+
.
.
a
•f
a
+
a
a
a
a
a
+
•
•
«• +•
x 0

0 0
0
a +
0
• +
a a
a
0 +
+
+
a
a +
-
•f a
-
a a
a +
a
a
0 «•
a
-
0 +
0 x

0 x
0
a +
0
•»• +
0 0
• a
a +
m *
a a
- a
a a
- a
+ a
• a
a a
a
a a
a
a +
a
a m
0
0

0
0
a
0
+
a
a
a
a
+
-
a
-
+
-
a
a
a
-
a
-
a
a
X

0
a
-
0
a
0
-
a
.
•f
-
a
0
•f
.
-
-
a
.
-•
-
a
0
0

0
0
a
0
+
a
-
a
.
-
-
a
-
+
.
a
a
a
-
a
.
-
Symbols denote levels of waste components  In wells relative to the lagoon.

 + at least one order of magnitude greater
 • same order of magnitude
 - at least one order of magnitude less than
 0 not detected
 x present  In well but not  lagoon

Data  for Table 8 derived  from  Table 9.

-------
                                  -64-
                                TABLE 9




SELECTED ORGANIC AND INORGANIC COMPOUNDS DETECTED IN TASK FORCE SAMPLES
PARAMETER
(in ppb)
Acetone
Carbon
Disulf ide
Methylene
Chloride
Benzene
Al
Sb
As
Cd
Cr
Cu
Fe
Mg
Mn
Hg
K
Ag

P5
ND

ND

ND
ND
1780
ND
ND
ND
ND
15
4860
12800
1240
-
5870
ND
Na 171000
V
Zn
Be
Ca
Co
Pb
Ni .
pH
ND
49
16
14900
23
5.5
63
4.7

P9
230

ND

ND
220
2510000
ND
ND
ND
110000
26900
13700000
2340000
312000
-
115000
515
1540000
288000
16600
68
323000
2280
4980
2350
<0.5

IAGOON
45

ND

ND
7.7
910000
10.4
35.1
4.4
75000
904
1540000
1820000
110000
0.6
40600
260
352000
200000
1750
33
109000
2500
414
1170
<1.0

R2
ND

ND

ND
ND
1230000
7.5
ND
1.7
63200
2160
7480000
1810000
119000
-
60200
197
800000
184000
3320
38
441000
1430
1400
1600
0-0.5

R3
ND

ND

ND
ND
1460000
7.8
662
ND
74300
3330
9160000
2040000
125000
•
64700
253
431000
219000
4350
61
339000
1860
2460
1730
0-0.5

R5
ND

ND

ND
ND
1470000
4.6
156
5.4
64300
5650
8840000
1800000
150000
-
108000
289
118000
176000
7940
60
332000
1510
3160
1460
0-0.5

R7
140

12

ND
20
1960000
ND
20.2
1.8
2610
ND
2190000
302000
36200
.
79300
8
1750000
86.40
4580
49
520000
173
ND
418
2-3

-------
                                    -65-
                             TABLE 9 (Continued)
SELECTED ORGANIC AND INORGANIC COMPOUNDS DETECTED IN TASK FORCE SAMPLES
PARAMETER
(in ppb)
Acetone
Carbon
Disulfide
Methylene
Chloride
Etenzene
Al
Sb
As
Cd
Cr
Cu
Fe
Mg
Mn
Hg
K
Ag
Na
V
Zn
Be
Ca
CO
Pb
Ni
pH

M2
960

ND

ND
ND
4120000
25
322
18
98300
6530
1240000
228000
215000
-
20000
272
545000
249000
14900
108
427000
2010
1770
2460
<0.5

M3
ND

ND

ND
ND
390000
ND
346
ND
17300
490
1920000
670000
36200
-
74100
56
1580000
53500
1210
20
364000
458
655
454
0.5-1.0

M4
410

20

20
34
2350000
15
1000
ND
96500
2900
1050000
2520000
152500
-
93000
295
424500
278500
4935
99
*
1995
2600
1895
<0.5

M5
ND

ND

ND
ND
384000
ND
450
2.5
10200
275
2120000
394000
32600
-
93000
42
1880000
25500
4590
24
156000
427
475
507
0.5-1.0

M6
55

14

ND
38
46100
ND
50
ND
1160
150
200000
188000
3790
-
68500
ND
1560000
2700
428
2
183000
60
28.8
65
-

M7
ND

ND

ND
ND ,
127000
ND
198
1.8
3260
839
685000
290000
9300
-
895000
12
2130000
8420
1420
11
169000
134
186
193
1.7

-------
                      APPENDIX A




Boring Logs For P-series, M-series and Recovery Wells

-------
ATEC Associates, Inc.
             c ueotecrnicai i .Matenais Ercrneers
             Geraghcv & Miller
RECORD OF SOIL EXPLORATION
            SORING , CM-1 (Page 1 of 3)
COW IWAW 1
PROJECT N
LOCATION



tMt SCM - Lasoon Site at Plant
Baltimore County, Maryland
SAMPLER
•_... 140 LW. . MJU.BI 	

12/p/fli »•—»!- . .„ 2. , "-- •— -——


8"
^
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31-11423

ru. C. Franz

	 12/8/81

CL,r
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to 15 feet. Installed"
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-------
ATEC
                                  ,  Inc.
                                      P-6

         ttCORD OF  SOIL  EXPLORATION
CONTRACTED *IT>«
                   Geoiecnmcai i Materials =ro:neers
                  Geraehtv  &  Miller
        ^..    SCM  - Lasoon  Site ac  Plane
                                                                    BORING .  GM-I  (Page 2 of 3)
                                                                    ,n«.      31-11423	
LOCATION .
              Baltimore County. Maryland
                             SAMPLER
                            •.   UP

         1?/fi/8l
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3-aiJiNTEC»ATEO
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                        SAMPLER TYPE
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                   CA-CONTINUOUS FLIGHT AUGEB  *•*"***
                   RC-aocx CORE
     GBOUNO WATER OEPTM
AT CO»«PL£TION ^_____^
       BORING METHOD

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                   RC-aocx CORE              AFTER       1* HRS.         «T.   "0 -M.« 0«n.«t
 i  AMOARO PENETRATION TEST.ORIVINC ?•• oo SAMPLER r WITH uo« HAAIMER FALLING 10". COUNT MADE AT 4- INTERVAL*

-------
ATEC Associates, Inc.
               i? Geotecrnicai i Materials z~c:neers
                                                BZC080  OF  SOIL CXPLORAT10N
                Geraehcv & Miller
CONTRACTED WITH 	    	
      NA_.j    SCM - Lagoon Site at Plane
                                                              BORING , GM-1   (Page 3 of 3)
                                                                       31-11423	
             Baltimore Councv. Maryland
                           SAMPLER
_*(. CU*..
                .Pt.
                                                       8'
                                                                       C.  Franz
                     Pip. S4-» .
                                     ,i«.    *•.. c-» c
                                     .U.    In i ii| -MM
                                                      J_S_.
                                                                OOT.C.
                                                                            12/8/81
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trace silt













Test Boring Terminated @ 5C


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                                        A*TER

                                        AFTER
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                                                    «BS.
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  -WOABO 'ENETBATION TEST.ORIVINC 7" OD'SAnPLEB I' WITH UO* MAAUtSR ^AUUINC JO". COUNT MADE AT 6" iNTERVAti
      aORIMC MCTHOO
.CT.   MSA -M*
-------
ATEC Associates, Inc.
                                                       P-fe

                                      OF SOIL EXPLORATION
        Cjnsumnc oeoteenmcai i Materials £nc:ne-rs
CONTRACTED »ITM
      NAMC __
                 Geraghcy & Miller
SCM-_Lagoon Sire ac Plane
          CORING , GM-2  (Page 1 of 2 )
                31-11623	
;J CATION .
              Anne Arundel Councv. Maryland
                        SAMPLER
                                                                  C. Franz
                                    HSA
                                                                    _l 2/10/81

• ELJV.

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-------
ATiC Associates, Inc.
         Ijnsuitmc -jeoteertntcai i Materials Ero:ne*rs
                             RECORD OF SOIL EXPLORATION
CONTRACTED
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                   - La»oon Sit"  ar
                                           SORINO ,GM-2  (Page 2 of 2 )
                                           JQ..    31-11423	
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-------
^KcC Associates, Inc.
                                    RECORD Of SOIL EXPLORATION
             Geotecnmcai i Matenais rn
               Geraghcv & Miller
                                              SORING ,GM-3D  (Page 1 of 3 )
• •Ml l»/"^ MAAiff SCJM " '
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-------
        Associates,  Inc.
             ? Siotecrnicai i Materials engineers
                                 7
*EC08D Of SOIL EXPLORATION
                                                      SORIMC .CM-3D (Page 2 of 3 )
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-------

ATI
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^ o.-^— RICORD OF SOIL EXPLORATION
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-------
Associates, Inc.
     jtJOtecrnicai A Materials Enginee
«ICO«D OF SOIL EXPLORATION




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-------
^
Associates, Inc.
                                 22CORD  OP SOIL
*cnsuinnc Geoiecrriicai i Materials Engineers

        Geraghty  *. Miller
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-------
AJEC Associates, Inc.
        :cnsumnc 3*ofec.rntcai i Materials sr
                                                                        <=/
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                               20 —

-------
£TEC Associates, Inc.
                            RECO«0 OF SOIL
•jnsuitmc vijotecmicai i Materials =ne:neers
       Geraghty & Miller
                                                      (Page 2 of 2)
^"'l^lntt SCM - T**"°" Str* at Plant .«. . 31-11423
' Anne Arundel Councv. Marvland
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-------
   g|C Associates,  Inc.
           :jnsu.nnc •5*ctecmicai i Matenais Enome
                                                                    P-IO'
                                         2ECOBD  OF  SOIL  EXPLORATION
             Geraghcv &  Miller
 • MAMf
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                    SAMPLER
                                                            BORIMG• CM"*0 (Page 1 of 3)
                                                            JOB*    -31-11623   ~~"
   12/21/81
                                         • flu.
                                                               C. Franz
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-------
*fgC Associates, Inc.
^*^~ ^™*^    ^•^••••••FMi
                                                                      P-/0
                                           RECORD OF SOIL EXPLORATION
                Geotecnmcai i Materials zrsgines
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-------
        Associates, Inc.
                                                              p-io
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                                       8HCORO OF SOIL
SwTtACTEO "IT*
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.3 CATION
BORING jGM-4D  (Page 3 of 3)
joa,   31-IU23       "
                                   CBOUMO »*Teff Of PTM
                               AT COMPLETION

-------
ATEC Associates, inc.
           Geotec.Tnrcai i Materials Engineers

             Geraghty & Miller
                   P- //
MCORO OF SOU. W?tO«ATiON
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Installed bentonite
seal from 15 to 16'.
Cement grouted annulus
to surface. Pipe 3'
above ground surface
with locking protectiv
steel cover.

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     tiNUIINhbKING, INC.  | CONSULTING ENGINEERS • PLANNERS
Monitoring Well fl

Date Completed
Drilling Method
Depth of Hole
Diameter of Hole
Length of 4" PYC Screen
Length of 4" PVC Casing
Length of 6" Steel Casing
Filter Sand Depth
Cement Grout Depth
PVC Casing Above Ground
Soil Profile
        November 12
        MUD ROTARY
        17.0 feet
         8 Inches
         5.0 feet
        11.0 feet
         8.7 feet
 9.5 to 17.0 feet
   0 to  9.5 feet
         1.5 feet
         0 to 15 ft
             1984
             - Sand
15 to 16 ft. - Tan, SUty Clay
16 to 17 ft. - Red Clay
Monitoring Well 12

Date Completed
Drilling Method
Depth of Hole
Diameter of Hole
Length of 4M PVC Screen
Length of 4" PVC Casing
Length of 6" Steel Casing
Filter Sand Depth
Cement Grout Depth
PVC Casing Above Ground
Soil Profile
        November 12,
        MUD ROTARY
        25.0 feet
         8 Inches
         5.0 feet
        19.0 feet
         8.7 feet
18.0 to 25.0 feet
   0 to 18.0 feet
         1
             1984
   5 feet
 0 to 16 ft. - Sand
16 to 24 ft. - Tan, S1lty Clay
24 to 25 ft. - Red Clay
Monitoring Well 13

Date Completed
Drilling Method
Depth of Hole
Diameter of Hole
Length of 4" PVC Screen
Length of 4" PVC Casing
Length of 6" Steel Casing
Filter Sand Depth
Cement Grout Depth
PVC Casing Above Ground
Soil Profile
        November 14, 1984
        MUD ROTARY
        17.0 feet
         8 Inches
        10.0 feet
         3.0 feet
         8.7 feet
 3.0 to 17.0 feet
   0 to  3.0 feet
         4.0 feet
         0 to 14 ft. - Sand
        14 to 17 ft. - Red-Brown Clay
                                                                           D-T5

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CENTURY ENGINEERfNG, INC.  | CONSULTING ENGINEERS • PLANNERS


     Monitoring Well  #4

     Date Completed                         November 15,  1984
     Drilling Method                         MUD ROTARY
     Depth of Hole                          17.0 feet
     Diameter of Hole                        8 Inches
     Length of 4"  PVC Screen                 10.0 feet
    length of 4"  PVC Casing                  7.0  feet
   /Length of 6"  Steel  Casing               8.7  feet
  /  Filter Sand Depth               6.0 to  17.0- feet
 /   Cement Grout  Depth                0 to   6.0  feet
 •'".  PVC Casing Above Ground                  4.0  feet
     Soil  Profile                             0 to 14 ft.  - Sand
                                            14 to 17 ft.  - Red-Brown Clay


     Monitoring Well  #5

     Date  Completed                          November 15,  1984
     Drilling  Method                         MUD ROTARY
     Depth of  Hole                          37.0  feet
     Diameter  of Hole                        8 Inches
     Length of 4"  PVC Screen                 20.0  feet
     Length of 4"  PVC Casing                 11.0  feet
     Length of 6"  Steel  Casing               8.7  feet
     Filter Sand Depth              10.0 to  37.0  feet
     Cement Grout  Depth                0 to  10.0  feet
     PVC Casing Above Ground                  4.0  feet
     Soil  Profile                             0 to 36 ft.  - Sand
                                            36 to 37 ft.  - Red Clay
    Monitoring Well #6

    Date  Completed                         November 14, 1984
    Drilling Method                        MUD ROTARY
    Depth of Hole                          37.0 feet
    Diameter of Hole                        8 Inches
    Length of 4" PVC Screen                20.0 feet
    Length of 4" PVC Casing                10.0 feet
    Length of 6" Steel  Casing               8.7 feet
    Filter Sand Depth               9.5 to 37.0 feet
    Cement Grout Depth                0 to  9.5 feet
    PVC Casing Above Ground                 4.0 feet
    Soil  Profile                            0 to  37 ft. - Sand
                                                                               D-1S

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'CENTURY ENGINEERING, INC.  j CONSLLTING ENGINEERS • PLANNERS
      ' nitorlng Well ¥1

     Date Completed                         November 13, 1984
     Drilling Method                        MUD ROTARY
     Depth of Hole                          35.0 feet
     Diameter of Hole                        8 Inches
     Length of 4" PVC Screen                20.0 feet
     Length of 4" PVC Casing                TO o feet
     Length of 6" Steel Casing               8.*7 feet
     Filter Sand Depth              '9.7 to 35.0 feet
     Cement Grout Depth                0 to  9.7 feet
     PVC Casing Above Ground                 4.0 feet
     Soil Profile                           0 to 35 ft.  - Sand
                                                                               D-17

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                          RECORD OF WELL INSTALLATION

                                SCM CORPORATION
                    ADRIAN JOYCE WORKS-BATCH ATTACK LAGOON
Recovery Wei 1 fl

Date Completed
Drilling Method
Depth of Hole
Diameter of Hole
Length of 6"  PVC Screen
Length of 6"  PVC Casing
Length of 10" Steel  Casing
Filter Sand
Cement Grout
PVC Casing Above Ground
Soil Profile
November 9, 1984
MUD ROTARY
35.0 feet
12 Inches
10.0 feet
16.5 feet
 8.7 feet
13.5 to 35.0 feet
 0 to 13.5 feet
 1.5 feet
 0 to 2 tt. - Red Clay
 2 to 13 ft.- Sand
13 to 28 ft.- Tan SUty Clay
28 to 35 ft. - Red-Brown Clay
Recovery Hell  *2

Date Completed
Drilling Method   '
Depth of Hole
Diameter of Hole
Length of 6" PVC Screen
Length of 6" PVC Casing
Length of 10"  Steel Casing
Filter Sand
Cement Grout
PVC Casing Above Ground
Soil Profile
November 12, 1984
MUD ROTARY
32.0 feet
12 Inches
 9.0 feet
17.5 feet
 8.7 feet
15.0 to 32.0 feet
 0 to 15.0 feet
 1.5 feet
 0 to 2 ft. - Red Clay
 2 to 12 ft.- Sand  /
12 to 29 ft.- Tan SUty Clay
29 to 32 ft.- Red-Brown Clay
                                                                           0-12

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CC|NIUIVI ClNUUNCCKliNO, 1;NC. j  CONSULTING ENGINEERS • PLANNERS
    Recovery Veil #3

    Date Completed
    Drilling Method
    Depth of Hole
    Diameter of Hole
    Length of 6" PVC Screen
    Length of 6" PVC Casing
    Length of 10" Steel Casing
    Filter Sand
    Cement Grout
    PVC Casing Above Ground
    Soil Profile
                           November 6, 1984
                           MUD ROTARY
                           20.0 feet
                           UJuches
        - -6.2 feet
          8.7 feet
  4.0 to 20.3 feet
    0 to  4.0 feet
          4.1  feet
          0 to 16  ft.
         16 to 20  ft.
                                          Sand
                                          Red Clay
    Recovery Well  #4

    Date Completed
    Drilling Method
    Depth of Hole
    Diameter of Hole
    Length of 6"
    Length of 6"
    Length of 10
    Filter Sand
    Cement Grout
    PVC Casing Above Ground
    Soil Profile
PVC Screen
PVC Casing
 Steel Casing
                          November 7,  1984
                          MUD ROTARY
                          20.5 feet
       Q2.5 feei)
         4.1 feet
         8.7 feet
 4.0 to 20.5 feet
   0 to  4.0 feet
         4.1 feet
         0 to 19 ft. - Sand
        19 to 20.5 ft. -Red Clay
    Recovery Well  ffS

    Date  Completed
    Drilling Method
    Depth of Hole
    Diameter of Hole
    Length of  6" PVC Screen
    Length of  6" PVC Casing
    Length of  10"  Steel  Casing
    Filter Sand
    Cement Grout
    PVC Casing Above Ground
    Soil  Profile
                          November 8, 1984
                          MUD ROTARY
                          37.0 feet
                             Inches
        11.0 feet
         8.7 feet
11.0 to 37.0 feet
   0 to 11.0 feet
         5.2 feet
         0 to 14.5 feet
        14.5 to 37 feet
                                            Sand
                                            Tan, Silty Clay
                                                                               D-13

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CENTURY ENGINEERING, INC.  | CONSULTING ENGINEERS • PLANNERS
    Recovery Well 16

    Date Completed
    Drilling Method
    Depth of Hole
    Diameter of Hole
    Length of 6" PVC Screen
    Length of 6" PVC Casing
    Length of 10" Steel  Casing
    Filter Sand
    Cement Grout
    PVC Casing Above Ground
    Soil Profile
        November 8, 1984
        MUD ROTARY
        37.0 feet
        12 Inches
        20.0 feet
        12.0 feet
             feet
             feet
         8.7
11.0 to 37.0
   0 to 11.0 feet
         4.2 feet
         0 to 16 ft.  - Sand
                                           16 to 37  ft.  - Tan.  SUty  Clay
    Recovery Well  17

    Date Completed
    Drilling Method
    Depth of Hole
    Diameter of Hole
    Length of 6" PVC  Screen
    Length of 6" PVC  Casing
    Length of 10"  Steel  Casing
    Filter Sand   •
    Cement Grout
    PVC Casing Above  Ground
    Soil Profile
11
        November 13.  1984
        MUD ROTARY
        37.0 feet
        12 Inches
        20.0 feet
        11.0 feet
         8.7 feet
  ,0 to 37.0 feet
   0 to 11.0 feet
         5.1 feet
         0 to 15 ft,  - Sand
        15 to 37 ft.  - Tan. Sllty Clay
                                                                                D-14

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                 APPENDIX B




Analytical Techniques for Task Fbrce Samples

-------
                                 prc
PRC Engineering
Su'te 600
V',.3 East Wacker Drive
•'„- cago. IL 60601
i ^-938-0300
-Y/X 910-2215112
Cac-e CONTOWENG
Planning Research Corporation
               EVALUATION OF QUALITY CONTROL ATTENDANT
                  TO THE ANALYSIS OF SAMPLES FROM THE
                  SCM ADRIAN JOYCE FACILITY, MARYLAND
                           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.
                 548
                 Headquarters
                 N/A
                 November 7, 1986
                 68-01-7037
                 15-5480-01
                 PRC Environmental
                 Management, Inc.
                 (Ken Partymiller)
                 (713) 292-7568
                 Anthony Montrone/
                 Barbara Elkus
                 (202) 382-7912
                                         rmm ma PRODUCT PREPARED
                                         IN MnaiWISl OF UIKAHH
                                           ENFORCEMENT
                                           CONFIDENTIAL

-------
MEMORANDUM

DATE:    November 5,  1986

SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples
          from the SCM Adrian Joyce, Maryland Facility

FROM:    Ken Partymiller, Chemist
          PRC Environmental Management

THRU:    Paul H. Friedman, Chemist*
          Studies and Methods Branch (WH-562B)

TO:       HWGWTF:  Tony Montrone*
          Gareth Pearson (EPA 8231)*
          Richard Steimle*
          Ed Berg (EPA 8214)*
          Eugene Dennis, Region III
          Pat Krantz, Region  III


     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 SCM Adrian Joyce, Maryland 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 (2-3) 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 presents  the results of quality control
procedures, including  the generation of data quality indicators, synopses of
statistical indicators, and the results of technical qualifier inspections. A
report on the results of the performance evaluation standards analyzed by the
* HWGWTF Data Evaluation Committee Member

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laboratory was also generated.  Step two was an independent examination of the
quality control package and the performance evaluation sample results by
members of the Data Evaluation Committee.  This was followed by a meeting
(teleconference) of the Data Evaluation Committee to discuss the  foregoing data
and data presentations. These discussions were to come to a consensus, if
possible, concerning  the appropriate use of the data within the context of the
HWGWTF objectives. The discussions were also to detect and  discuss specific or
general inadequacies of the data and to determine if these are correctable or
inherent in the analytical process.

Preface

     The data user should review the pertinent materials contained in  the
accompanying reports (2-3). Questions generated in the interpretation of these
data relative to sampling and analysis should be referred to Rich  Steimle of
the Hazardous Waste Ground-Water Task Force.

I.    Site Overview

     The SCM Adrian Joyce facility is a manufacturing plant which produces
titanium dioxide  from titanium ores for paint manufacturing. Due to the
acidification process used to prepare and purify the titanium dioxide, large
quantities of acidified ore residuals are produced. Large lagoons  are utilized
to  neutralize the acid waste and to physically separate (settle)  the solids.
The liquid in the lagoons generally  remains quite acidic. Acidic ground-water
contamination is recognized.  The ground water in some sampling locations near
the lagoons is at a pH of one.  The site is adjacent to the Chesapeake Bay and
some of the monitoring wells are approximately ten feet from the edge of the
Bay. Low pH samples containing minimal organics and high levels of metals are
expected from the wells.

     Seventeen field samples including one field blank (MQO388/QO388), one trip
blank (MQO370/QO370), one equipment blank (MQO371/QO371), and one pair of
duplicate samples (well M-4, MQO389/QO389 and MQO390/QO390) were collected at
this facility. All  samples were  low concentration  ground water samples. Only
eleven  of the samples were analyzed for organics  and five of the samples for
dissolved metals.  Traffic reports indicated which  samples were blanks and
which  were duplicates.

II.   Evaluation of Quality Control  Data and Analytical Data

1.0  Metals

1.1   Performance Evaluatio'n Standards

     Metal analyte performance evaluation standards were  not evaluated in
conjunction with  the samples collected from this facility.

1.2  Metals OC Evaluation

     Total metal spike recoveries were calculated for twenty-three metals
spiked  into  three  field samples  (MQO375, 380, and 390). Dissolved metal spike
recoveries were calculated for seventeen metals spiked  into a  field sample
(MQO379).   Ten of the total metal and sixteen of  the dissolved metal average

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spike recoveries were within the data quality objectives (DQO) for this
Program.  The total aluminum, chromium, iron, magnesium, manganese, sodium,
vanadium, and zinc and the dissolved sodium spike recoveries were not required
to be calculated because the analytical results for those metals in all samples
were greater than four times the concentration of the spike added. Dissolved
metal spike  recoveries for the six furnace metals were not required to be
reported.  The total barium, lead, and thallium average spike recoveries were
below DQO  with recoveries of 4, 32, and 61  percent,  respectively. The total
cadmium and selenium average spike recoveries were above DQO with recoveries of
215 and 838 percent, respectively.  Various individual total metal spike
recoveries were also outside DQO. These are listed in Table 3-2 of Reference 2
as well as in the following Sections.  All reported laboratory control sample
(LCS) and all calibration verification standard (CVS) recoveries were  within
Program DQOs.

      All seventeen reportable total metal and ten of eleven reportable
dissolved metal average relative percent differences (RPDs) were within the
precision DQOs. Dissolved aluminum was outside the precision DQO.
Noncalculable RPDs were reported for many total and dissolved  metals because
one or both  of the duplicate values were below  the CRDL.

     Required analyses were performed on all metals samples submitted to  the
laboratory.  Dissolved metals analyses were required on only five samples
including  the three field blanks.

     No contamination was reported in  the laboratory blanks.  Equipment, field,
and trip blanks show contamination at concentrations above the CRDL involving a
variety of total and dissolved metals. These contaminants are summarized in
Appendix  2  of Reference 2 and are discussed in appropriate Sections below.
They include total aluminum at a concentration of 4000 ug/L, dissolved iron at
a concentration of 3110 ug/L, and lesser amounts of total iron, manganese, and
vanadium and dissolved aluminum, manganese,  vanadium, and zinc in the field
blank, dissolved aluminum and  iron in the trip blank, and dissolved aluminum in
the equipment blank.

1.3   Furnace Metals

     One additional continuing calibration verification (CCV) and one
continuing calibration blank (CCB) should have been run for selenium.

     Matrix spike recoveries for antimony (68 percent recovery), lead (32
percent), and thallium (22 percent) from sample MQO37S, selenium (2100 percent)
and thallium (61 percent) from sample MQO380, and  cadmium (240 percent) and
selenium (292 percent) from sample MQO390 were outside DQO.  Analytical spike
recoveries for selenium were below DQO for diluted  samples MQO372, 373, 374,
375,  376, 377, 389, 390, and MQO391Dup (duplicate sample).

     The method of standard addition (MSA) correlation  coefficients for arsenic
in samples MQO374, 374Dup, 380, 380DM (dissolved metal), and 390 were below DQO
rendering  the appropriate total or dissolved arsenic results for all of these
samples except MQO380 unreliable. Arsenic  results for sample MQO380 should be
considered qualitative. MSA correlation coefficients  for antimony  in samples
MQO380DM and 389 were below DQO.  Dissolved antimony results for sample MQO380
should be  considered unreliable and total antimony results for MQO389 should be

-------
considered qualitative.  MSA correlation coefficients for cadmium in sample
MQO374Dup was below DQO and the cadmium results for this sample should be
considered qualitative.

     Duplicate injection relative standard differences (RSD) for many samples
(SR) and/or spiked sample (SSR) including antimony in sample MQO374Dup, arsenic
in sample MQO380Spk (spiked sample),  and selenium in samples MQO370, 371,
374Dup, 378, 380, 380DM, and 391 were outside DQO.  The percent RSD for these
metals in these samples is listed in Reference 3.

     Field duplicate result differences  for arsenic and thallium in duplicate
pair MQO389/390 were greater than expected. The comparative precision of  the
field duplicate results is not used in the evaluation of sample data as it is
not possible to determine the source of  this imprecision.  Field duplicate
precision is reported for informational  purposes only.

     Antimony and arsenic results, both with exceptions, all  cadmium results,
dissolved selenium  results for samples MQO370, 371, 379, 381, and 388, total
selenium results for samples MQO379, 381, and 388, and all thallium results for
samples MQO373 and 389 should be considered semi-quantitative.  All lead
results, total and dissolved arsenic results  for sample MQO380, and total and
dissolved antimony results for sample MQO389 should be considered qualitative.
Total and dissolved selenium and thallium results with the above noted
exceptions, total and dissolved arsenic results for sample MQO390, and
dissolved antimony results for sample MQO380 should be considered unreliable.

1.4  ICP Metals

     Individual spike recoveries were outside DQO for total  barium (11  percent)
and  lead (32 percent) in sample MQO375, total barium (zero percent) and
beryllium (72 percent) in sample MQO380, and total barium (zero percent) and
beryllium (62 percent) in sample MQO390.  All the low recoveries are expected
to result in data that  are biased low and the high recovery is expected to
result in data that are biased high.  The high levels of sulfate present appear
to be interfering with the barium analysis as all barium results are biased low
by nearly 100 percent (barium spike recoveries were 0, 0, and 11 percent,
barium was only detected in three samples). As positive results were reported
for barium, these barium results should  be considered qualitative.  False
negative results for barium have a significant probability.

     Serial dilution recovery results for total beryllium, calcium, cobalt,
copper, nickel, potassium, silver, and zinc .in sample MQO391, total calcium,
cobalt, copper, nickel, and zinc in sample MQO374, and dissolved  calcium and
sodium in sample MQO379 were not within control limits of the original
determination. Poor serial dilution results can be an indication of physical
interferences in the analytical determination.  Such interferences are most
prevalent in samples such as these with  high dissolved solids  concentration?.
Such interferences usually  result in low bias in the results. All sample
results from this facility, with the exceptions of samples MQO370, 371, and 388
(the  sampling blanks) would be affected by these  interferences.

     The field blank  (MQO388) contained total and dissolved aluminum, iron, and
manganese, and total vanadium at concentrations  above the CRDL. The equipment
blank (MQO371) contained dissolved aluminum at a concentration above the CRDL.

-------
The trip blank (MQO370) contained dissolved aluminum and iron at concentrations
above the CRDL.

     The low level (twice CRDL) linear range checks for total copper and
dissolved nickel had low recoveries and the total chromium  had varying
recoveries. All total nickel results except MQO380 should be considered to be
biased low.  Total copper results for sample MQO379 should also be considered
to be biased low.

     All chromium, iron, magnesium, manganese, sodium, and  vanadium results,
and all  aluminum results with exceptions, listed below, should  be  considered
quantitative.  All copper, potassium, silver, and zinc results  should be
considered semi-quantitative. Total iron results for sample MQO379 and all
barium, beryllium, calcium, cobalt, and nickel results should be considered
qualitative.  Total and dissolved aluminum and dissolved iron  results for
sample MQO379 should be considered unreliable due to blank contamination at
similar  concentrations.

1.5  Mercury

     One spike recovery for mercury was above DQO (130 percent). No other
analytical problems were identified with the mercury results.  All total and
dissolved mercury results should be considered  quantitative.

2.0- Inorganic and Indicator Analvtes

2.1  Performance Evaluation Standard

     Inorganic and indicator analyte  performance evaluation standards were not
evaluated in  conjunction with the  samples collected from this facility.

2.2  Inorganic and Indicator Analvte OC Evaluation

     The average spike recoveries of  all of  the inorganic and indicator
analytes were within the accuracy DQOs for all analytes (accuracy  DQOs  have not
been established for bromide and nitrite nitrogen matrix spikes but their
average recoveries were 98 and 100 percent). This indicates acceptable
recoveries for all these analytes.  All LCS and CVS recoveries  reported in  the
raw data for inorganic and indicator  analytes were within Program DQOs except
for two CCVs reported for ammonia nitrogen.

     Average RPDs for all inorganic and indicator analytes were within Program
DQOs.  Precision DQOs have not been established for bromide and nitrite
nitrogen.

     Requested inorganic and indicator analyte analyses were  performed on all
samples.

     No laboratory blank contamination was reported for any  inorganic or
indicator analyte.  Total phenol was detected in the trip blank at  a
concentration of 38 ug/L and TOC was detected in both the trip blank and an
equipment blank at concentrations of 6300 and  12000 ug/L,  respectively.  TOC
concentrations in the field samples ranged from 7000 to 213,000 ug/L with most
values between 24,000 and 125,000 ug/L.

-------
2.3   Inorganic and Indicator Analvte Data

      The quality control results for the cyanide, chloride, and sulfate data
are acceptable.  The results for these analytes should be considered
quantitative.

      The holding times for the nitrate nitrogen analyses ranged from  19 to 22
days  from receipt of samples which is significantly longer than  the recommended
48 hour holding time for unpreserved samples. The nitrate nitrogen results
should be considered semi-quantitative.

      The chloride RSD for the field duplicate pair MQO389/390 was large.  The
comparative precision of the field duplicate results is not used in the
evaluation of  sample data as it is not possible to determine the source of this
imprecision.  Field duplicate precision is reported for informational purposes
only.  The chloride results should be considered quantitative.

      The laboratory did not analyze an initial calibration verification (ICV)
standard at the beginning of the nitrite nitrogen run.  An EPA or independent
ICV standard  should be analyzed at the beginning of the nitrite nitrogen run.
The holding times for the nitrite nitrogen  analyses were 19 to 22 days from
receipt of samples which is significantly longer than the recommended 48 hour
holding time for unpreserved samples. Nitrite nitrogen data for all samples
was acceptable and the  results should be considered to be semi-quantitative.

      The laboratory did not analyze an ICV standard at the beginning of the
bromide run.  An EPA or independent ICV standard should be analyzed at the
beginning of the bromide run.  Bromide  data  for all samples were acceptable and
the results should be considered semi-quantitative.

      The CCVs for ammonia nitrogen were outside DQO for accuracy. All three
ammonia nitrogen matrix spike recoveries  were outside DQO although the average
of the three was within DQO.  The ammonia nitrogen results should be considered
semi-quantitative.

      The trip blank contained 38 ug/L of  total phenols.  All samples, except
MQO372, 380, and 391,  contained total phenols in this concentration range and
their  results should be considered unreliable.  Results  for samples MQO372,
380, and 391 should be considered qualitative. The difference in total phenols
results for field duplicate pair MQO389/390 was greater than expected. The
comparative precision of the field duplicate results is not used in the
evaluation of  sample data as it is not possible to determine the source of this
imprecision.  Field duplicate precision is reported for informational purposes
only.

      The field and equipment blanks (MQO370 and 371) contained TOC at
concentrations above the CRDL (6300 and  12000 ug/L, respectively).  As a HWGWTF
data reviewer  convention, all TOC results greater than ten times the highest
blank concentration  should  be considered quantitative (samples MQO370, 371,
374, 380, 388,  389, 390, and  391).  All TOC results four times greater that the
highest blank  concentration should  be considered qualitative (samples MQO372,
373, 379, and 381).  All other TOC results should be considered unreliable
(MQO375, 376, 377, 378, and 382).

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     No instrument calibration curve information was reported with the raw POC
data.  ICVs and CCVs were not analyzed for POC.  Spiked solutions of
unspecified concentrations were run but since the true concentrations of these
spike were not provided, the  instrument calibration could not be assessed.  One
of six POC matrix spike recoveries was below DQO. The POC results should be
considered qualitative.

     Instrument calibration data for each day's TOX analyses were not found in
the raw data for any of the analytical batches. Initial and final calibration
verifications and initial and  final calibration blanks were not analyzed
consistently  at the beginning  and end of each day's analytical batches.
Calibration verification standards and blanks should be analyzed every 10
samples and at the beginning and end of each day's analyses.  The TOX samples
were highly  diluted due to the high chloride concentrations present.  The  high
levels of chloride found in the samples  from this facility  can cause positive
interference with the TOX analysis. Since TOX was not detected at the elevated
detection limits, this interference is not suspected. The TOX-results should
be considered semi-quantitative except for samples MQO381 and 382 which should
be considered quantitative as adequate calibration verifications and blanks
were run for those two samples only.  False negatives are  possible due to the
high dilutions required for the TOX analysis.

     Spike recovery for one of four POX spikes was below Program DQO. No
instrument calibration curve  information was reported with the raw POX data,  A
final CCB was not run on one date and a final CCB and a final CCV were not run
on another date.  The POX results for samples MQO370, 371, 379, 380,  381, and
382 should be considered quantitative.  All other POX results should be
considered semi-quantitative  due to an insufficient number of calibration
verifications.

3.0  Oreanics and Pesticides

3.1  Performance Evaluation Standard

     Organic performance evaluation standards were not  evaluated in  conjunction
with the samples collected from this facility.

3.2  Organic OC Evaluation

     All matrix spike average recoveries were within established Program DQOs
for accuracy except for 2,4-dinitrotoluene and 4-nitrophenol which were not
recovered from either the matrix spike  or matrix spike duplicate samples.
Individual matrix  spike recoveries which were outside the accuracy DQO will be
discussed in the appropriate Section below.  Accuracy DQOs have not been
established for the pesticides 2,4-D and 2,4,5-T.  All average 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 Section below.

     The matrix spike/matrix spike duplicate RPDs for 1,4-dichlorobenzene, 2,4-
dinitrotoluene, and 4-nitrophenol were outside Program DQOs.  All other matrix
spike/matrix spike duplicate  average RPDs were within Program DQOs for
precision. Program DQOs for precision have not  been  established for the

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herbicides 2,4-D and 2,4,5-T. Individual matrix spike RPDs which were outside
the precision DQOs will be discussed in the appropriate Section below.  All
average surrogate spike RPDs, except nitrobenzene-DS, were also within Program
DQOs for precision. Surrogate, precision DQOs have  not been established  for
2,4-DB.

     All organic analyses were performed as requested.

     Laboratory blank contamination was reported for organics and is  discussed
in the appropriate Sections below.

     Detection limits for the organic fractions are summarized in the
appropriate Sections below.

3.3  Volatiles

     Quality control data indicate that volatile organics were determined
acceptably.  The chromatograms appear acceptable. Initial and continuing
calibrations, tunings, blanks, matrix spikes, matrix spike duplicates, and
surrogate spikes are acceptable.

     Acetone was detected in two of the  laboratory blanks (CC860617A19 and
CB86061SB19) at approximately 2 and 4 ug/L (the acetone CRDL is 10  ug/L).

     The volatiles data are acceptable. The probability of false negative
results for  the volatiles is acceptable.  The estimated  detection limits for
the volatiles is CRDL except for sample QO391 which is 1.4 times CRDL, samples
QO389 and  390 which are 2.9 times CRDL, and sample QO380 which is 6.7 times
CRDL.  The volatile compound results should be considered to be quantitative.

3.4  Semivolatiles

     Calibrations,  tunings, blanks, holding times, and chromatograms were
acceptable  for the  semivolatiles.

     A substituted alkane (unidentified tentatively identified compound)  was
found in a semivolatile method blank (GH092566B15) at an estimated
concentration of 14 ug/L..

     The relative percent difference (RPD) between  matrix spike and matrix
spike duplicate results for 1,4-dichlorobenzene (30 percent) was above DQO (28
percent)  for sample QO375.

     2,4-Dinitrotoluene and 4-nitrophenol  were spiked but not recovered from
the matrix  spike/matrix spike duplicate for sample QO375.

     The surrogate percent recovery for nitrobenzene-D5 (DQO equals  35 to  114
percent recovery) in samples QO375, 375MS (matrix spike), 375MSD (matrix spike
duplicate),  375RE (reanalysis), 378, and 378RE (no recovery in any of these),
phenol-DS (DQO equals 10 to 94 percent recovery) in samples  QO379 and  379RE  (0
and one percent recovery), and 2-fluorophenol (DQO  equals 21 to 100 percent
recovery) in samples QO379 and 379RE (1 and 3  percent) were outside DQO.  Based
upon the poor recoveries of these phenolics, false negative results for acid
fraction compounds are possible.

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     The semivolatile data are acceptable and the results should be considered
semi-quantitative with the exceptions of the compounds mentioned above which
had low  or no recovery.  The probability of false negatives is acceptable.
Estimated detection limits were twice CRDL for all samples.

3.5   Pesticides

     The initial and continuing calibrations, blanks, chromatographic quality,
and holding times for pesticides were acceptable. The matrix spike, matrix
spike duplicate, and surrogate data were within acceptable limits.

     The pesticide instrument blank chromatograms associated with columns Pack
03 and Pack 07 indicate contamination.

     Table 1  of Reference 3 (for organic analyses) lists peaks contained in the
pesticide chromatograms  which were in the retention time window of pesticide
HSL compounds but which were not addressed by the laboratory in their data
workup.

     The estimated method detection limits for the pesticides fraction were
CRDL for all samples.  The pesticides data should be considered to be
unreliable due to the lack of identification by the organic laboratory  of
possible pesticide peaks in the chromatograms. There  is an enhanced
probability of false negatives for pesticides.

3.6  Herbicides

     The initial and continuing calibrations, blanks, chromatographic quality,
and holding times for the herbicides were acceptable.  The matrix spike, matrix
spike duplicate, and surrogate data were within acceptable limits.

     Table 2 of Reference 3 (for  organic analyses) lists peaks contained in two
herbicide chromatograms which were at or near the retention time window of
Dalapon  but which were  not addressed by the laboratory in their data workup.
Dalapon  was  also labeled at two different retention times on standard
chromatograms run on  the same column and both peaks appeared in all standard
chromatograms run on  this column (see herbicide Section of Reference 3). The
same two herbicides samples (QO380 and 391) were affected.  The herbicides data
quality should be considered to be unreliable.  The estimated method detection
limits for the herbicides fraction  were CRDL for all samples.

3.7  Dioxins

     Recoveries of dioxin spikes  by the organics laboratory appear to be nearly
quantitative (112 to 129 percent recoveries). The 15 day holding time until
extraction was exceeded by 16 or more days for all samples except QO371.  No
contamination was found  in the dioxin blanks and no dioxins were found in any
sample.

     Based upon past PE samples, a significant problem, possibly adsorption of
the dioxins and dibenzofurans to  the walls of the sample bottle, is probably
affecting (diminishing) the concentration of the dioxins, if any dioxins are
present, in the field samples.  Although no dioxins were detected in the field

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samples, the probability of false negative; is unacceptably high. Based upon
data from past facilities, the detection limits for the dioxins in field
samples should be considered to be approximately 500 ppt and it is probable
that no dioxins were present above this level in the samples from this
facility. The dioxins data should be considered unreliable.

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III.  Data Usability Summary

4.0 Graphite Furnace Metals, total

Semi-quantitative:   antimony and arsenic results with exceptions listed below,
               all cadmium  results, selenium results for samples MQO371, 380,
               and 388, and thallium results for samples MQO373 and 389
Qualitative:    all lead results, arsenic results for sample MQO380, and
               antimony results for sample MQO389
Unreliable:     selenium and thallium results with the above exceptions and
               arsenic results for sample MQO390

4.1   Graphite Furnace Metals, dissolved

Semi-quantitative:   antimony and arsenic results with exceptions listed below,
               all cadmium results, selenium results for samples MQO370, 371,
               379, 381, and 388, and thallium results for MQO373 and        389
Qualitative:    all lead results, arsenic results for sample MQO380, and
               antimony results for sample MQO389
Unreliable:     selenium and thallium results with exceptions, arsenic results
               for sample MQO390, and antimony results for sample MQO380

4.2  ICP Metals, total  and dissolved

Quantitative:   aluminum results with exceptions, all chromium, iron, magnesium,
               manganese, sodium, and vanadium results
Semi-quantitative:   copper,  potassium, silver, and zinc
Qualitative:    total iron results for MQO379, all barium, beryllium, calcium,
               cobalt, and nickel results
Unreliable:     total and dissolved aluminum and dissolved iron results for
               sample MQO379

4.3  Mercury, total and dissolved

Quantitative:  , all mercury data

4.4  Inorganic and Indicator Analvtes

Quantitative:   all cyanide, chloride, and sulfate results, TOC results for
               samples MQO370, 371, 374, 380, 388, 389, 390, and 391, POX
               results for samples MQO370, 371, 379, 380,  381, and 382, and TOX
               results for samples MQO381 and 382
Semi-quantitative:   all nitrate, and nitrite, and ammonia nitrogen and bromide
               results and POX and TOX results with exceptions
Qualitative:    total phenols results for samples MQO372, 380, and 391, TOC
               results for samples MQO372, 373, 379, and 381, and all POC
Unreliable:     TOC results for samples MQO375, 376, 377, 378, and 382 and total
               phenols results with e .options

4.5  Oreanics

Quantitative:   volatile purge and trap data
Semi-quantitative:   all semivolatiles data
Unreliable:     all pesticides, herbicides, and dioxins data

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IV.  References

1.   Organic Analyses:    CompuChem Laboratories, Inc.
                         P.O. Box 12652
                         3308 Chapel Hill/Nelson Highway
                         Research Triangle Park, NC 27709
                         (919) 549-8263

     Inorganic and Indicator Analyses:
                         Centec Laboratories
                         P.O. Box 956
                         2160 Industrial Drive
                         Salem, VA 24153
                         (703) 387-3995

2.   Revised draft Quality Control Data Evaluation Report for SCM Adrian Joyce,
Maryland, 10/20/1986, Prepared by Lockheed Engineering and  Management Services
Company, Inc., for the US EPA Hazardous Waste Ground-Water Task Force.

3. Revised draft Inorganic Data Usability Audit Report and Draft Organic Data
Usability Report, for the SCM Adrian Joyce, Maryland site. Prepared by
Laboratory Performance Monitoring Group,  Lockheed Engineering and Management
Services Co., Las Vegas,  Nevada, for US EPA, EMSL/Las Vegas, 10/15/1986,
inorganic report revised  10/20/86.

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