February 1987 EPA-330/2-87-006 Hazardous Waste Ground-Water Task Force Evaluation of Sikorsky Aircraft Division, United Technologies Corporation Stratford, Connecticut UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING EPA-330/2-87-006 GROUND-WATER MONITORING EVALUATION SIKORSKY AIRCRAFT DIVISION, UNITED TECHNOLOGIES CORPORATION Stratford, Connecticut February 1987 Eugene Lubieniecki Project Coordinator National Enforcement Investigations Center ------- CONTENTS WASTE MANAGEMENT UNITS AND OPERATION Wastewater Sources and Treatment RCRA Units SITE HYDROGEOLOGY HYDROLOGIC UNITS AND GROUND-WATER FLOW DIRECTION WATER LEVEL MEASUREMENTS/TIDAL INFLUENCES . GROUND-WATER MONITORING PROGRAM UNDER INTERIM STATUS REGULATORY REQUIREMENTS MONITORING WELL NENORK . . Well Construction . Number and Location GROUND-WATER SAMPLING AND ANALYSIS PLAN SIKORSKY SAMPLE COLLECTION AND HANDLING PROCEDURES Water Level Measurements . Purging Procedures Sampling Methods Chain-of—Custody and Shipping Procedures IPC Sampling Procedures Inconsistent with Sampling and Analysis Plan 1 6 6 7 7 8 9 10 10 12 12 13 13 13 22 22 24 24 25 EXECUTIVE SUMMARY INTRODUCTION SUMMARY OF FINDINGS AND CONCLUSIONS GROUND-WATER MONITORING DURING INTERIM STATUS Monitoring Well Network Ground-Water Sampling and Analysis Plan Sampling and Analysis Procedures Ground-Water Assessment Outline and Program Plan GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT TASK FORCE SAMPLING/ANALYSIS AND MONITORING DATA EVALUATION . . TECHNICAL REPORT INVESTIGATIVE METHODS RECORDS/DOCUMENTS REVIEW FACILITY INSPECTION LABORATORY EVALUATION SAMPLE COLLECTION AND ANALYSIS FACILITY DESCRIPTION PROCESS OPERATIONS PETROLEUM PRODUCTS STORAGE . Underground Fuel Tanks . . . Oil/Antifreeze Storage Area . . • 25 25 28 33 35 36 41 • . . . . 42 42 44 46 47 49 49 50 53 54 55 1 ------- CONTENTS (cont.) SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT 56 Initial Year of Monitoring 57 Semiannual Monitoring in 1985 and 1986 60 TIDAL INFLUENCES ON GROUND-WATER MONITORING 62 GROUND-WATER QUALITY ASSESSMENT OUTLINE AND PROGRAM PLAN 63 GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT 66 EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE RELEASE . . 69 Volatile Organic Sampling Results 69 Inorganic Sampling Results 72 APPENDICES A SAMPLE PREPARATION AND ANALYSIS TECHNIQUES AND METHODS B ISCO METER VERIFICATION DATA C NPDES EFFLUENT LIMITATIONS D WATER LEVEL RECORDING STRIP CHARTS E TIDE DATA FOR PREVIOUS SAMPLING DATES F SUMMARY OF WELL SAMPLING RESULTS G TASK FORCE ANALYTICAL RESULTS FIGURES 1 Sikorsky Aircraft Facility Location Map . . . 3 2 Sikorsky Facility Map 5 3 Task Force Sampling Locations 14 4 Cross Section and Aerial View of Impoundments and Monitoring Wells 30 5 100 Year Flood Level, Wastewater Treatment Area 34 6 Water Levels in River and Monitoring Wells . . . . . . . 39 7 Sikorsky Ground-Water Monitoring System 43 8 Typical Well Construction 45 9 Sikorsky Water Level Measurements and Corresponding Tidal Phase 52 TABLES 1 Total Well Depth and Water Levels in Sikorsky Wells as Determined by the Task Force on May 5, 1986 16 2 Purging and Sampling Data 18 3 Order of Sample Collection, Bottle Type and Preservatives . . . . 19 4 Major Chemical Solutions Used in Sikorsky Manufacturing Processes 23 5 Major Chemicals Used in Sikorsky Paint and Resin Coating Processes 24 6 Tides During the Week of May 6, 1986 for the Housatonic River 37 7 Sampling Order, Constituents and Preservatives - IPC . . . 54 8 Proposed Indicator Parameters for RCRA Permit 67 9 Appendix VIII Compounds Used at Sikorsky 67 10 Selected Volatile Organic Constituents Present in Task Force Samples 70 11 Summary of Well Water Sampling Results, Volatile Organics . .•. . 71 12 Selected Inorganic Constituents Present in Task Force Samples 73 13 Specific Conductance, lOX and pH Values Reported for Task Force Samples 74 11 ------- EXECUTIVE SUNMARY ------- 1 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),* as amended.** In question is the ability of existing or proposed ground-water monitoring systems to detect contaminant releases from waste management units at TSDFs. The Administrator of the Environmental Protection Agency (EPA) established a Hazardous Waste Ground-Water Task Force (Task Force) to determine the current compliance status. The Task Force comprises personnel from the Office of Solid Waste and Emergency Response (OSWER) Office of Enforcement and Compliance Monitoring (OECM), the National Enforcement Investigations Center (NEIC), EPA regional offices and State regulatory agencies. The Task Force is conducting in-depth inves- tigations of TSDFs with the following objectives. • 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) • Evaluate the ground-water monitoring program described in the facility’s RCRA Part B permit application for compliance with 40 CFR Part 270. 14(c) • Determine if the ground water at the facility contains hazardous waste or ha2ardous waste constituents. Each Task Force evaluation will determine if: • Designated RCRA and/or State required monitoring wells are properly located and constructed * Regulations promulgated under RCRA address hazardous waste management facility operations, including ground-water monitoring, to ensure that hazardous waste or hazardous waste constituents are not released to the environment. ** Includes Hazardous Solid Waste Amendments of 1984 (HswA) ------- 2 • The facility has developed and is following an adequate ground-water sampling and analysis plan • Required analyses have been properly conducted on samples from the designated RCRA monitoring wells • The ground-water quality assessment program outline or plan (as appropriate) is adequate • The ground-water monitoring plan submitted in the facility’s RCRA Part B application meets the requirements of 40 CFR Part 270.14(c) • The ground water at the facility contains hazardous waste or hazardous waste constituents The Task Force investigated the Sikorsky Aircraft Division, United Technology Corporation Facility (Sikorsky), located in Stratford, Connecticut [ Figure 1). The onsite inspection was conducted from May 5 through 9, 1986 and was coordinated by NEIC personnnel. In general, the investigation involved review of State, Federal and facility records; facility inspec- tion; ground-water sampling and analysis; water level measurements; waste- water treatment plant effluent sampling and analysis and an evaluation of the contract laboratory. The 250-acre Sikorsky facility has manufactured helicopters and heli- copter components since 1955. The facility is a hazardous waste generator and has RCRA interim status (CTDOO].449784) for hazardous waste storage in two surface impoundments (about 50,000 gallons each) and acid storage in four 2,500-gallon (approximate) tanks. Additionally, Sikorsky receives up to 4,000 gallons per day of chromium wastewater from a companion manufac- turing plant located in Bridgeport, Connecticut for treatment in the onsite wastewater treatment plant (WWTP). The Sikorsky WWTP generates metal containing sludges (RCRA Waste Codes F006 and F019) through precipitation and sedimentation. These sludges are ------- 3 Sikorsky Aircraft Location Map Figure 1 Milford ------- 4 discharged to the onsite surface impoundments for dewatering. Dewatered sludge is typically removed yearly for offsite disposal. From 1955 to 1980 the sludge was disposed in an onsite landfill of about 5 acres. The facility also generates hazardous wastes which are containerized and accumulated for less than 90 days prior to offsite disposal. These wastes include spent solvents and acid, alkaline, plating and cleaning solutions. A waste nitric and hydrofluoric acid solution is collected, stored and used in the treatment plant for pH adjustment. The locations of the sludge dewatering surface impoundments, the land- fill and the hazardous waste accumulation area are shown in Figure 2. Based on the 100-year flood plain map submitted with the facility’s Part B appli- cation, both the landfill and surface impoundments are within the flood plain. Sikorsky was operating under both State and Federal hazardous waste management regulations during the Task Force inspection. The Connecticut Department of Environmental Protection (CTDEP) received RCRA Phase I interim authorization in April 1982 and Phase II interim authorization in June 1983. The program reverted back to EPA on January 31, 1986, as required by RCRA Section 3006(c), because the state did not have a fully authorized program at that time. The Company submitted a RCRA Part B permit application to CTDEP on November 8, 1985. The application was under review by both EPA and CTDEP during the Task Force inspection. The Company indicates that studies are being conducted to determine the feasibility of replacing the surface impoundments with a mechanical dewatering unit. If the impoundments are replaced, the application will be withdrawn and Sikorsky will be classified as a generator. ------- Approx. Boundary Landfill Area Test Pad control dike .. ! mor.h “ ‘... ! I 1/ I 4/ I Surface I Impoundounts .; .• ! .‘ f Wastewateir Treatment’ ! Area Stock Chemical Storage I ‘ I I i I ‘ I I i I / lestlng Areal I ID Oil/Antifreeze orags Area Hazardous Waste Accumulation Area Manufacturing Building Approx. Scale (ft) - I I 0 100 200 300 400 — — -, — — -. —_— — E — —— • — . . . . . — . — • — . — . . . . • . . . . —. FIGURE 2 ‘1 4 ’ , I I I I I I I U, SIKORSKY FACILITY PLAN ------- 6 SUMMARY OF FINDINGS AND CONCLUSIONS The findings and conclusions presented in this report reflect conditions existing at the facility in May 1986. The Task Force evaluation indicated that the interim status ground-water monitoring program does not comply with regulatory requirements. The compliance status of the monitoring well network could not be determined because of inadequacies of the available information. The ground-water sampling and analysis plan, sampling and analysis procedures and the quality assessment outline and program plan are inadequate. Water levels in the monitoring wells are tidally influenced, but water quality effects of tidal fluctuations are unknown. Finally, the evaluation determined that the RCRA Part B application does not comply with regulatory requirements. In addition, the surface impoundments are leaking hazardous waste or hazardous waste constituents into the ground water. GROUND-WATER MONITORING DURING INTERIM STATUS Task Force personnel investigated the interim status ground-water mon- itoring program for the period between November 1981 (the effective date of applicable RCRA regulations) and May 1986. The RCRA ground-water monitoring system consists of four wells which were installed in 1983 after the CTDEP denied the Company’s request for a ground-water monitoring waiver. The Company submitted a ground-water sampling and analysis plan to CTDEP in June 1983. The CTDEP approved the plan in September 1983 follow- ing revision by Sikorsky. A ground-water quality assessment outline was submitted to CTOEP with the 1983-1984 Ground-Water Monitoring Program Annual Report. Semiannual interim status ground-water sampling for 1985 showed significantly higher levels of specific conductance and total organic halides (lOX) in downgradient wells when compared to the data from the upgradient well. As a result, the Company was required to submit a quality assessment program plan. The latter plan was submitted on January 13, 1986. ------- 7 Monitoring Well Network The Task Force was unable to determine the adequacy of the monitoring well network because of uncertainties regarding the accuracy of monitoring data, insufficient construction records and tidal effects. Although the facility has an adequate number of wells for a detection monitoring system. (40 CFR 265.91), the upgradient well may be effected by facility operation and, thus, not be properly located to yield ground-water samples representa- tive of background water quality. Tidal effects (ground-water level fluctu- ations) observed in all of the wells and the effects of the leaking impound- ments may, at times, combine to influence water quality of the upgradient well. Further studies are necessary before a complete determination of the adequacy of the current monitoring well network can be made. Ground-Water Sampling and Analysis Plan The ground-water sampling and analysis plan does not meet the applicable Federal (40 CFR 265.92) and State* regulations. Specifically, the plan does not list all of the drinking water parameters which must be monitored quarterly during the first year of interim status sampling. Subsequently, analyses were never completed for endrin, lindane, methoxychior, toxaphene, 2,4-0, 2,4,5-TP, radium, gross alpha, gross beta, turbidity and coliform bacteria. In addition, the plan was deficient because (1) it did not include decontamination procedures for reuseable sampling equipment, (2) purge vol- umes were calculated using assumed rather than the actual water levels in the wells and (3) specific methods for analysis of each parameter were not identified. * State regulations, Section 22a-449(c)-28, requires that facilities meet the interim status requirements of 40 CFR 265.90 to 265.94 inclu- sive; therefore, only specific Federal regulations will be cited here. ------- 8 Finally, the data obtained from implementation of the Sikorsky monitoring plan has been inadequate to establish initial background concen- trations or values for all parameters required by Federal (40 CFR 265.92(c)] and State regulations. Facility ground-water monitoring data obtained since 1983 shows wide concentration variations for numerous parameters. Because such wide variations observed in the upgradient well are probably caused by factors such as tidal influences, surface impoundment loading, sampling inadequacies or laboratory inaccuracies, this data can not be confidently used to determine background water quality. Further study is necessary to identify the cause(s) of the wide variation(s) observed in the data and the plan must be modified to address the(se) cause(s). Sampling and Analysis Procedures Sikorsky contractor personnel conducting the interim status sampling did not follow the sampling and analysis procedures specified in the facil- ity ground-water sampling and analysis plan, as required by State and Federal regulations (40 CFR 265.92(a)]. The contractor did not use the sampling equipment or follow some of the sampling procedures specified in the plan. Specifically, bailers were used to purge two of the wells while the plan indicates that peristaltic pumps be used. The volume of well water purged prior to collecting analytical samples was not consistent with the volume specified in the plan (3 casing volumes) and the quantity of sample taken for some parameters was not consistent with the plan. The sampling procedures used by the Sikorsky contractor may be causing contamination in the monitoring wells. For example, sampling equipment is allowed-to contact the ground as well as the transporting vehicle and is not adequately decontaminated prior to each use. The Sikorsky contract laboratory is not using the methods specified in the sampling and analysis plan, as required by State and Federal regulations [ 40 CFR 265.92(a)]. Although the plan specifies that SW-846 methods be used for all analyses, the laboratory uses other techniques for many parameters. ------- 9 Some of the ground-water monitoring analytical data reported to CTDEP are inaccurate and of poor analytical quality. Recommended holding times have been exceeded and inappropriate and inconsistent analytical procedures were used for some parameters. Quality assurance procedures are deficient in enough areas that validation of the analytical results is difficult. Ground-Water Assessment Outline and Program Plan The ground—water quality assessment outline submitted to CTDEP on October 7, 1984 does not meet all of the requirements of 40 CFR 265.93. Although it included construction of additional monitoring wells, the out- line limited the circumstances which would require further investigation and did not include provisions to determine the rate and extent of any con- taminant migration beyond the property boundaries. The quality assessment program plan does not meet the requirements of 40 CFR 265.93. The plan was required after results from the second year of ground-water monitoring indicated a significant difference between upgra- dient and downgradient wells for specific conductance and total organic halides (TOX). It was submitted to CTDEP on January 13, 1986, but is not based on the previously submitted outline. The plan Is simply a continua- tion of the current interim status monitoring program, even though the out- line specified construction of additional wells and analysis of additional water quality parameters. The plan (interim status program) is inadequate to identify the rate and extent of migration of any hazardous waste or hazard- ous waste constituents due to the limited number of wells and their locations. In addition, it does not contain procedures for determining the concentra- tions of specific hazardous waste constituents, particularly organic halides. Also, the plan does not contain procedures to determine whether hazardous waste constituents have been released from the impoundments and the concen- trations of those constituents found in the ground water. Finally, the facility did not obtain the additional ground-water samples required to determine if elevated TOX and specific conductance levels in downgradient wells, which triggered assessment, were the result of labor- atory error or contamination [ 40 CFR 265.93(c)(2)]. ------- 10 GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT The RCRA Part B permit application, submitted to CTDEP on November 8, 1985, does not include the ground—water monitoring requirements specified in 40 CFR 270.14(c),* which includes describing any plume of ground-water contamination. Additionally, because the RCRA application was submitted after assessment was triggered (October 1985), it must include a description of a compliance monitoring system and submittal of an engineering feasibil- ity plan for a corrective action program [ 40 CFR 270. 14(c)(7)]. The permit application does not describe any plume of contamination, even though assessment was triggered indicating ground-water contamination. The ground-water monitoring program proposed in the permit application is a detection monitoring program rather than the required compliance monitoring program. The proposed program does not address compliance monitoring system requirements (i.e., characterization and concentration of waste constituents). In addition, the permit application does not include the required feasibility plan for a corrective action program. Finally, the proposed program specifies the use of the current interim status monitoring well network. As discussed earlier, a number of factors have prevented Sikorsky from establishing adequate background characteriza- tion of the site ground water with this network. Without further investiga- tion, it is unknown whether these wells, as they are currently used, can provide acceptable ground-water data. TASK FORCE SAMPLING/ANALYSIS AND MONITORING DATA EVALUATION Results of the Task Force sampling/analysis and monitoring data evalua- tion indicate that the active surface impoundment is leaking hazardous waste constituents to the ground water. * State regulation, Section 22a-449(c)-16, requires that facilities meet the permit application requirements of 40 CFR 270; therefore, only specific Federal regulations will be cited here. ------- 11 Analysis of samples collected from the facility ground-water monitoring wells,* the operating surface impoundment and effluent from the onsite waste- water treatment plant, shows that volatile organics and metals are present in the three designated downgradient wells at levels greater than those found in the upgradient well. Furthermore, most of the volatile organics and metals present in the downgradient wells were also found in the surface impoundment liquid and wastewater treatment plant effluent samples. These results generally verify Company data and indicate that hazardous waste or hazardous waste constituents are leaking from the surface impoundments and entering the ground water. Furthermore, results of the continuous ground-water level monitoring conducted by the Task Force also suggest that liquids are leaking from the active surface impoundment. Sludge added to the impoundment appears to influence the water level in an adjacent downgradient well. * Ground—water samples were obtained at or near low tide to limit water qualitg effects that a high tide might create. ------- TECHNICAL REPORT ------- 12 INVESTIGATIVE METHODS The Task Force evalution of Sikorsky consisted of: • Reviewing and evaluating records and documents from EPA Region I, CTDEP and Sikorsky • Conducting an onsite facility inspection May 5 through 9, 1986 • Evaluating the offsite contract analytical laboratory • Recording ground-water levels at four wells • Sampling and analyzing data from four ground-water wells, liquid from the surface impoundment and effluent from the wastewater treatment plant (W’WTP) RECORDS/DOCUMENTS REVIEW Prior to the onsite inspection, records and documents from EPA Region I and CTOEP offices were reviewed to obtain information on facility operations, construction details of waste management units and the ground—water monitor- ing program. Onsite facility records were reviewed to verify information currently in government files and supplement government information where necessary. Selected documents requiring further evaluation were copied during the inspection. Specific documents and records that were reviewed included the ground- water sampling and analysis plan; ground-water quality assessment outline and plan; 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 location of waste sources at the facility. ------- 13 FACILITY INSPECTION The facility inspection was conducted from May 5 through 9, 1986 to identify waste sources, waste management units (past and present) and pollution control practices and to verify the location of ground-water monitoring wells. Company representatives and contractors provided information on: (1) facility operations (past and present), (2) site hydrogeology, (3) ground- water monitoring system, (4) the ground-water sampling and analysis plan, and (5) sampling and laboratory procedures for obtaining data on ground-water quality. LABORATORY EVALUATION Baron Consulting Company in Milford, Connecticut analyzes ground-water samples for Sikorsky and was evaluated in May 1986 regarding sample handling and analyses as part of the Task Force investigation. Analytical equipment and methods and quality assurance procedures were examined for adequacy. Laboratory records were reviewed for completeness 1 accuracy and compliance with State and Federal requirements. York Laboratories analyzed ground-water samples for Sikorsky only in 1985, but was not evaluted by the Task Force. SAMPLE COLLECTION AND ANALYSIS Sampling activities during the investigation included the following: • Measuring total depth and water levels in the four Sikorsky designated RCRA interim status monitoring wells • Collecting ground-water samples from the four monitoring wells, active surface impoundment and effluent from the Sikorsky WWTP (outfall 03) [ Figure 3] ------- Housatonic River Tidal Flat Control bldg. ‘ + Fence lIne_ 40 80 FIGURE 3 TASK FORCE SAMPLING LOCATIONS Upgradient monitoring well • B-i /NPDES Outfall O3 1 NPDES Outfall 02 radlent monitoring wells Wa stew ate r treatment plant area / Scale in feet: Manufacturing building ------- 15 Recording water levels in the monitoring wells continuously for about 48 hours Samples were collected to determine if the ground water contains hazard- ous waste or hazardous waste constituents and well water levels were measured to determine if the Company monitoring wells are affected by water fluctuation in the adjacent tidal flats. Wells designated by Sikorsky for interim status monitoring are numbered B-i through B-4. In addition to these four wells, the Task Force sampled liquid from the southern surface impoundment and the effluent from the industrial wastewater treatment plant. Surface impoundment liquid and t TP effluent samples were collected to determine if hazardous waste or hazardous waste constituents were present. Continuous water level recordings were conducted and compared with tidal data collected by the National Oceanic Survey to determine whether the monitoring wells are affected by tidal fluctuations in the adjacent Housatonic River. All samples were collected by an EPA contractor, Versar, Inc., Springfield, Virginia and sent to EPA contract laboratories for analysis. Analytical techniques and methods are presented in Appendix A. Duplicate volatile organic samples and splits of other sample parameters were provided to Sikorsky. The Company declined aliquots for extractable organics, dioxin, pesticide/herbicide and quality control field blanks. Neither Region I nor CTDEP requested or received split samples. NEIC received and analyzed one additional replicate of split samples for well B-4. None of the Sikorsky designated RCRA wells are equipped with pumps, therefore, the EPA contractor supplied purging and sampling equipment for each well sampled. Sample collection procedures were as follows;* 1. Sikorsky personnel unlocked the wellhead. 2. The®open welihead was monitored for chemical vapors (‘Photovac TIP ) and radiation.** * Unless specified, the EPA sampling contractor conducted the work. ** Using Ludlum Survey Meter model M.44-9 @ Photovac TIP is a registered trademark and appears hereafter without ------- 16 3. The depth to gr und-water was measured using an oil/water sonic Interface Probe (Moisture Control Co., Inc. Model No. B2220-3) [ Table 1]. Table 1 TOTAL WELL DEPTH AND WATER LEVELS IN SIKORSKY WELLS AS DETERMINED BY THE TASK FORCE ON MAY 5, 1986 Well Number Time Water Level (TOC)* (ft.) Total Well Depth* (ft.) Screened Interval (ft.) B-i 1052 18.00 27.06 17.1-27.1 8-2 1122 10.33 19.85 9.8-19.8 B-3 1105 10.71 19.85 9.8-19.8 B-4 1115 11.51 19.81 9.9-19.9 Credit 1042 12.77 ND** Union * Measured from top of casing by the Task Force. ** Not determined 4. The Interface Probe was lowered through the water column until the bottom of the well was reached. 5. The Interface Probe was retrieved from the well bore. The cable and probe were decontaminated after each use with a pesticide-grade hexane wipe, followed by a distilled water rinse and wiped dry. 6. The well was relocked. The water levels were taken at each well on the first day of sampling and then sealed until sampled later in the inspection. 7. When Task Force personnel were ready to sample, Sikorsky personnel reopened the weliheads. 8. Water level measurements were made, as discussed in steps 3 and 5 above. 9. Task Force personnel calculated water column volumes using the height of the water column, well casing radius and a constant, then converted to gallons-per-foot of casing for purged volumes. 10. Three water column volumes were purged with dedicated telfon bailers using a 4-gallon plastic bucket (marked in quarts) to measure ® Interface Probe is a registered trademark and will appear hereafter without ®. ------- 17 volume purged. Table 2 presents the purging information for each well. Purged water was discharged into the wastewater treatment plant tanks. 11. A sample aliquot was collected for temperature, turbidity, specific conductance and pH measurement. Table 2 presents information on sample collection. 12. Sample containers were filled in the order specified in Table 3 using dedicated teflon bailers . All samples collected from the monitoring wells were filled directly from the Teflon bailers. The surface impoundment and W 1TP effluent samples were filled from 5-gallon composite jugs. Split samples were collected by filling one—third of each sample bottle for Sikorsky and Task Force, respectively, from the bailer or composite jug, until each bottle was filled. If the volume in the bailer could not fill one-third of each bottle, the bailer was divided equally between the bottles. 13. Samples were placed on ice in an insulated cooler. 14. EPA contract personnel took the samples to a sta9ing area where the samples for total metals, TOC, phenols, cyanide and ammonia were preserved [ Table 3]. When additional samples were collected for quality control purposes [ NEIC duplicate (well 8-4) and contract laboratory triplicate (well B-2)], step 12 above was modified. Containers for the NEIC samples were filled in series following collection of Sikorsky and Task Force aliquots. The labora- tory triplicate was filled in series following the facility sample. In each case, the outlined procedures for collecting split samples were followed (using one—third or one—fourth of a bailer per bottle). When the surface impoundment liquid and WWTP effluent were sampled, chemical vapors and radiation were determined and steps 11, 12, 13 and 14 of the monitoring well sampling procedures were followed in their respective order. These samples were taken by the EPA contractor at the eastern edge of the southern impoundment and the effluent discharge pipe (03), respec- tively. All sample bottles were filled in series [ Table 3] from a 5-gallon composite bottle. ------- Table 2 PURGING AND SAMPLING DATA Calculated Three Water Column Volume Method of Volumes Purged Method of Well # Purge Dates Time (gal.) (gal.) Comments Sample Date Time Comments B-i Baj ler* 05/06/86 0940-0950 4 85 5 Turbid Bailer 05/06/86 0950-1046 Turbid B-2 Bailer plus 05/06/86 0631-0644 4 18 4 5 - Bailer 05/06/86 0646-083 Triplicate, two sections turbid 8-3 Bailer 05/05/86 1725-1730 - 4.5 Bailer 05/06/86 1221-1310 - 05/06/86 1207-1220 4 29 4.5 8-4 None 05/05/86 1445-1455 3.96 4 Turbid Bailer 0S/05/86 1500-1630 NEIC sam- ples, turbid Surface N/A** N/A N/A N/A - Composite 05/5/86 1158-1305 Impoundment jar Discharge N/A N/A N/A N/A - Composite 05/7/86 1632-1653 #03 jar * Dedicated teflon bailers were used for purging. ** Not applicable ------- 19 Parameter 1. Volatile organic analysis (VOA) Purge and trap Direct inject 2. Purgeable organic carbon (POC) 3. Purgeable organic halogens (POX) 4. Extractable organics 5. Pesticide/herbicide 6. Dioxin 7. Total metals 8. Dissolved metals 9. Total organic carbon (TOC) 10. Total organic halogens (TOX) 11. Phenols 12. Cyanide 13. Ammonia 14. Sul fate/chloride/nitrate 15. Radionuclides (NEIC only) 2 60-rn.Q VOA vials 2 6O-cn VOA vials 2 60-m2 VOA vials 2 60-m2 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 1-qt. amber glass 1 1-qt. amber glass 1 1-qt. plastic 1 1-qt. plastic 1 1-qt. plastic 1 1-gal. cubic container Table 3 ORDER OF SAMPLE COLLECTION, BOTTLE TYPE AND PRESERVATIVE Bottle Preservati ve* HNO 3 HNO 3 H 2 SO 4 H 2 SO 4 NaOH H 2 S0 4 * All samples cooled to 4 °C. ------- 20 During collection, preservation and shipment of all samples, chain-of- custody procedures were followed by the EPA contractor. A Sikorsky represent- ative was given a receipt for all samples taken by the Task Force, in accord- ance with RCRA regulations. A receipt was also provided for the transfer of split samples from the Task Force to the Sikorsky contractor. Following collection of all ground-water samples, the EPA contractor installed (ISCO®) meters to continuously record the water levels in each of the four monitoring wells. The procedures listed below were followed when assembling, calibrating and operating the ISCO water level meters. 1. EPA contract personnel assembled the ISCO meters using Model 1870 meters and one-quarter-inch ID stainless steel tubing. 2. The meters were calibrated as follows: a) Chart recorder was set to a speed of 4 inches per hour b) The bubbler was adjusted to release one air bubble per second c) The end of the stainless steel tubing was lowered into a graduated cylinder containing distilled water. The tip of the tubing was moved up and down in the water column while the LED display on the ISCO meter was calibrated for depth of immersion. 3. The tubing was lowered into the well to a depth approximately one-half foot below the water surface as indicated by the calibrated display (.500). 4. The date, time and ISCO display were recorded on the strip chart. 5. The water level was verified with the Interface Probe and recorded. The probe was decontaminated according to the same procedures identified previously. 6. The welihead was sealed with a plastic bag around both the well and the ISCO meter and taped. The tape was signed by the EPA contractor to verify security between water level measurements. 7. Steps 4, 5, and 6 above were repeated three times daily to verify the accuracy of the ISCO meters [ Appendix B). ® ISCO is a registered trademark for Instrumentation Specialties Company and will be shown hereafter without ® ------- 21 The ISCO meters operated with only minor difficulties which were subsequently remedied. The ISCO meter on well B-i recorded relatively short cyclic water-level fluctuations throughout the investigation, presumed to be caused by electrical interference. The meter was verified to be running properly, and overall trends in the recorded curve were consistent with other wells. The ISCO meters were all shown to be accurate through repeti- tive water level measurements using the Interface probe. ------- 22 FACILITY DESCRIPTION Task Force personnel obtained information on past and present manufacturing and waste management activities to identify potential sources of hazardous waste releases to the ground water and aid in interpreting ground-water monitoring data. This information is summarized below. PROCESS OPERATIONS In general, there are five manufacturing areas at Sikorsky where waste- water is generated: process department, gear processing, blade department, anodizing department and welding department. Major process operations include cleaning, plating, etching, rinsing, molding and painting of metallic and nonmetallic (fiberglass) aircraft components. Many of the processes involve a series of tanks in which components are treated with chemical solutions [ Table 4]. Wastewaters from the manufacturing areas are generated from tank overflows, cleanings and dripping solutions when components are moved between tanks. Process floors are generally grated so that any solution dripping from the components falls through the grate into the open wastewater collection system. Painting is done in spray booths where water curtains entrain paint overspray. The water curtains drain to sumps where the paint particles are screened and removed for disposal. The water is reused until it becomes unacceptably contaminated, at which time the sumps are discharged to either the onsite !MTP or the municipal sewer. The major chemicals present in the paints and resins used are listed in Table 5. ------- Table 4 MAJOR CHEMICAL SOLUTIONS USED IN SiKORSKY MANUFACTURING PROCESSES Process Department Gear Processing Anodizing Depart i ent Blade Department Welding Department Cleaners Copper cyanide Nitric acid Hydrofluoric acid Hydrofluoric acid Sulfuric acid Sodium hydroxide Sodium cyanide Silver cyanide Hydrofluoric acid Sodium sulfate Nitric acid Tetrachloroethylene Chromic acid Sodium nitrate Sodium gluconate Hydrochloric acid Potassium fluoride Sodium sulfide Nitric acid Ammonium bifluoride ALOO INE* Cleaners Cleaners Nitric acid Sodium dichromate Copper oxide Sodium hydroxide Dye solutions Tetrachloroethylene Tin Sulfamic acid Chromic acid Potassium hydroxide Ammonium hydroxide Phosphoric acid Cadmium oxide Sodium perchlorate fluoride Sulfuric acid Sodium cyanide Ammonium hydrogen fluoride Copper cyanide Chromic acid Sodium dichromate Sulfuric acid Tin stripper Sodium carbonate Tetrachioroethene Wax Nickel sulfamate Hydrochloric acid Alkaline paint Stripper * Propriatoz-y chrome solution I ’ ) (A) ------- 24 Methylene chloride* 2-Butoxyethanol Trichiorodi fi uoroethane Diethylene triamine Toluene diisocyanate* Petroleum oil Petroleum distillate Ethylene glycol monoethyl ether acetate Ethyl acetate lead Ethylene glyco] phenyl ether Methyl alcohol Propylene glycol ether Methyl ethyl ketone (MEK)* Xylene Acetone Isobutyl alcohol Ethyl alcohol Cresol s Sodi urn pentachiorophenate Ethylene glycol Cresylic acid Butoxytethoxy propanol Ethoxytri gi ycol Tn chi orobenzene* Oleic acid Sodium borisilicate Silicon dioxide Zinc chromate Methyl oxitol Phenol * n-Butyl acetate* Toluene * Isopropanol Amines (various) * 40 CFR 261 Appendix VIII compounds PETROLEUM PRODUCTS STORAGE The petroleum products storage areas may be sources of ground-water contamination. These areas include the underground fuel storage tank system and the oil/antifreeze drum storage area (including the adjacent empty drum area) [ Figure 2]. Underground Fuel Tanks There are eight underground fuel storage tanks located north of the Sikorsky manufacturing building, four 10,000-gallon jet fuel tanks (steel with fiberglass lining), two 4,000-gallon regular gasoline steel tanks, one 4,000-gallon diesel steel tank and one 10,000-gallon unleaded gasoline fiber- glass tank. Petrochemical odors were present during excavation south of these tanks as a part of a construction project in 1983. A water sample from the excavated area indicated °gasoline was present. Subsequent pressure testing/visual inspection of the tanks indicated that various pipes/fittings on the jet fuel tanks required replacement. Following repair, the system Table 5 MAJOR CHEMICALS USED IN SIKORSKY PAINT AND RESIN COATING PROCESSES ------- 25 was retested and found to be sound. The gasoline storage tanks were also tested and found to be sound. The exact source of the petrochemical odor (gasoline) was never established and the construction was completed, as planned, over this area. Oil/Antifreeze Storage Area This filled area, north of the manufacturing building, is used to store cutting, transmission and other oils, antifreeze and empty drums. All drums are stored directly on the ground. During the Task Force inspection, the soil in this area was discolored indicating that material had been spilled. Seepage to the adjacent marshland from the fill beneath the storage area was also discolored and formed an oily sheen. Sand bags had been placed in the marshland in an attempt to contain any seeping floating material. WASTE MANAGEMENT UNITS AND OPERATION The waste handling and disposal operations including the design, con- struction and operation of waste handling units are discussed below. Emphasis is placed on the wastewater treated at the onsite WWTP which generates the hazardous sludge treated/stored in the RCRA regulated surface impoundments and the RCRA regulated units. Wastewater Sources and Treatment Wastewater Sources The metal finishing and electroplating operations generate wastewater from the following processes. • Chrome anodizing • Chemical milling • Immersion coating • Titanium process operation • Anodizing, etching, cleaning and painting • Tin, cadmium, chrome, nickel, copper and silver plating ------- 26 These wastewaters are collected in two open, lined trench systems which segregate alkaline (normally containing cyanides) from acidic wastewaters. These two wastewater streams are sewered separately to the WWTP and treated on a batch basis in separate tanks. Inspection of the manufacturing areas revealed potential cross connections between the acid and alkaline (cyanide) sewer systems because the trenches are open and overflows between trenches are possible. Also, because the trenches are located beneath the open grating of the process area flooring, any material used in these areas can enter the wastewater trenches and subsequently the WWTP. For example, it was noted that parts dipped in solvent tanks are allowed to dry over open process floor grating, introducing tetrachloroethene into the sewer system. Paint operations also generate wastewater which is treated in the onsite WWTP. Water curtains used to remove paint overspray in some* spray booths periodically discharge to the WTP. Components of these paints include solvents such as ketones, acetates, alcohols, toluene and xylene, thus, solvents and other paint components are periodically sent to the WWTP. Another source of wastewater is the chromium plating rinse waters from Sikorsky’s Bridgeport, Connecticut plant. This wastewater is transferred by tank truck at an average volume of 4,000 gallons per day to the WTP where it is treated with the alkaline wastes described above. Wastewater Treatment The WWTP is operated on a batch basis. Wastewater arrives by in-plant sewers and periodically by tank truck from the Bridgeport facility. WWTP personnel route the incoming wastewater to an available acid or alkaline (cyanide) tank for treatment. Operators only test the incoming wastewater for the major constituents in each type of wastewater (cyanide in alkaline waste, chromium in acid waste). Even though cross-contamination may occur * Some of the spray booths discharge this wastewater to the sanitary sewer for of fsite treatment. ------- 27 between acid and alkaline lines due to cross-connections, no attempt is made to determine the complete composition of each batch treated. A bench scale study is done to determine the approximate amount of treatment chem- icals needed. At various points in the treatment process further testing is conducted to determine the extent of treatment achieved. The WWTP chemically destroys cyanides, reduces chrome, precipitates metals and adjusts pH of the wastewater. Cyanide is destroyed by alkaline chlorination. Commercial swimming pool chlorine at high pH (from lime addition) converts cyanide to cyanate. Waste acid from Sikorsky processes is then added to lower the pH to convert cyanate to nitrogen and carbon dioxide. Chrome is reduced by adding sodium bisulfate and/or sodium hydrosulfate to the wastewater. Metals are precipitated through the addition of lime and/or caustic and a polymer (to assist in settling). The waste acids used to adjust pH at the wastewater treatment plant are a product of Sikorsky manufacturing processes and include nitric and hydroflouric. These waste acids also contain dissolved metals from the various manufacturing processes. Analytical equipment used at the wastewater treatment plant consists of prepackaged reagents and colormetric comparison equipment. When waste- water analysis indicates that chromium levels in the treated wastewater are below NPDES effluent limitations, the wastewater is discharged to the adja- cent tidal flats through outfall 03 and 02. Appendix C contains the effluent limitations of the facility’s NPOES permit. Following wastewater discharge, sludge may be drawn from the bottom of the tank and sent to the RCRA regu- lated surface impoundments for dewatering. Observations by Task Force personnel indicate that sludge particles settle in the tank discharge weir boxes, allowing sludge to be discharged through the effluent outfall with the first flush of treated wastewater. During the inspection, a valve in a treatment tank was left open allowing untreated chromium wastewater to be discharged. ------- 28 The WWTP is basically a chemical treatment facility and is not designed or operated to treat solvents, paint components or other organic materials. Chlorination of solvents and other organics may occur since chlorine is used in the cyanide reduction/destruction process. This may account for the chloroform and other chlorinated organics found by Sikorsky in W’WTP effluent even though these chemicals are not used in the Sikorsky manufac- turing process. RCRA Units The RCRA regulated units at Sikorsky include two sludge dewatering surface impoundments associated with the wastewater treatment facility, waste accumulation areas and an inactive landfill [ Figure 2]. The impound- ments are used for dewatering WWTP sludges prior to offsite disposal. Sikorsky also operates at least three waste accumulation areas where waste in drums is accumulated until they are either moved to the central drum accumulation area or offsite for disposal. Sikorsky operated an onsite landfill for the disposal of WWTP sludge prior to November 19, 1980. This area is subject to RCRA Section 3004(u), which addresses continuous releases for past waste disposal operations. RCRA Interim Status Units Surface Impoundments Sikorsky uses two surface impoundments to dewater metal hydroxide sludge generated by the WWTP, prior to offsite disposal. The sludge is classified as a hazardous waste under 40 CFR 261.31 (waste codes F006 and F019). The unlined impoundments, located at the facility’s eastern boundary, approximately 15 feet from the Housatonic tidal flats, were built in 1955. They were excavated approximately 5 feet below grade into the artificial fill and sand/gravel sediment. ------- 29 The northern impoundment is approximately 30 feet wide and 70 feet long. The southern impoundment is approximately 30 feet wide and 90 feet long. Although the impoundments are unlined, portions of the side walls are made of severely cracked concrete. The remaining wall portions and bottom are of earthen materials [ Figure 4]. The impoundments contain a liquid collection system consisting of a perforated pipe running along the bottom of each impoundment. Liquid generated by physical separation during the sludge dewatering process was collected in this pipe and discharged to local surface waters via the effluent WWTP discharge pipe. The liquid col- lection system is reportedly “plugged”, apparently with metal hydroxide sludges, and is no longer in use. The Sikorsky RCRA Part B permit application indicates that dikes around the impoundments protect the impoundments from surface water runon; however, no protective dikes were observed during the Task Force inspection. Further- more, because the impoundments are located at the base of a hill, surface runoff from the hillside could easily flow into the units. There are no permanent freeboard markers at the impoundments. During the Task Force inspection, the freeboard of the southern (active) impoundment was less than 2 feet, as measured at the eastern wall. Sikorsky refers to the impoundments as evaporation ponds. Precipita- tion in southeastern Connecticut exceeds evaporation by more than 16 inches per year and, thus, evaporation in this area is not necessarily a viable means of liquid reduction. Because the units are unlined and constructed in relatively permeable fill material, liquid may move easily out of the impoundments into the surrounding fill and sand/gravel deposits. Sikorsky personnel have observed apparent seepage from the impoundments along the approximately 5- to 7-foot-high earthen slope which descends to the adjacent river tidal flat [ Figure 4]. ------- Cro u Section A. LEGEND Cement Soil Sludge High Tide Drainage Culvert NPDES Diechorge Point Monitoring Well Fence x I AAAI AAAAt .N N A UXUUAAAAAAAAAA) 92 M, AMAMAMNVWVVVVVVVVYYYYYYYYYYT ‘ South Surface Impoundment’ 10I• fvVyVVVVVvVVYYVYYYYYYTYII !!II 11 IIILUAAAAAAAAA ..%,.FI.% .%A IhJ1. VVvVVYV fYYYYYYY I 494 55. B2 b3 j 21 _ 5 IF 78 Figure 4 76 Cross Section and Aerial View of Impoundments and Monitoring Wells A 38 B2 t 14. 5 10 A .- o a. . 20 m xxx ES acelmPOUndJ] 30 B4 (A, ------- 31 Waste Accumulation Areas Waste solvent and paint residue generated at Sikorsky are placed in drums at satellite accumulation areas at or near the process area until they are removed to the main drum accumulation area. Two satellite accumula- tion areas used for paint waste, residue and waste solvents are located outside the Sikorsky process building and accessible to anyone on the plant premises. Periodically, drums are removed from the satellite accumulation areas and transported to the main waste accumulation area in the western portion of the plant [ Figure 2]. This main accumulation area consists of an asphalt pad with asphalt berms. Drums can be stored here for up to 90 days before being shipped for offsite disposal. During the Task Force inspection, por- tions of the berms were broken. There was evidence of waste leakage from the drums and precipitation could easily wash waste from this area into the surrounding surface drainage areas and possibly into the ground water. In 1983, for a period of about 3 months, the Company had also used the area just north of the wastewater treatment facility for temporary storage of hazardous waste. The area is now used for stock chemical/paint storage. Non—Interim Status RCRA Units Sikorsky used an area north of the manufacturing building for disposal of WWTP sludge prior to November 19, 1980 [ Figure 2]. While this area is not subject to RCRA interim status regulations, it is subject to RCRA Section 3004(u) and must be addressed prior to issuance of the RCRA Part B Permit. The landfill, located in the flood plain, was in use beginning in 1955 and reportedly contains sludge generated by Sikorskys WWTP as well as miscel- laneous fill and debris. Drums of waste material may also have been disposed of here. The boundary of the area is not clear and the specifics of landfil- ling activity in this area are unknown. In May 1981, Sikorsky submitted a ------- 32 Notification of Hazardous Waste Site to EPA. The notification described the landfill site as a general disposal area from 1955 to 1980. Because the hydrology of the area near the landfi11 has not been defined, the impact of hazardous waste constituents leaching from the landfill area on ground- water monitoring near the surface impoundments cannot be determined without further study. ------- 33 SITE HYDROLGEOLOGY Two major reports have been prepared on the hydrogeologic conditions of the Sikorsky site. The first is in a Company request for a waiver of ground-water monitoring requirements prepared by Dames & Moore in January 1982. The second is a report prepared for the RCRA permit application by the Company’s current consultant, IPC. The report is included in the ground- water monitoring plan submitted to CTDEP in May 1983 and updated in July and August 1983. Unless otherwise noted, the information which follows comes from these reports. The facility was built on a sand and gravel deposit and partially filled marshland. Borehole data is not available for the waste treatment and surface impoundment area; however, the uppermost geologic unit consists of sand and gravel (glacial drift) ranging from approximately 20 to 70 feet in thickness, underlain by up to 10 feet of dense glacial till. The till overlays an orange phyllite* bedrock. Surface waters in the vicinity of the plant are the Housatonic River, east of the site (which is influenced by tides from Long Island Sound) and its tributary, the Far Mill River, north of the site. The confluence of these rivers is at the northeast corner of the property. The topography of the property is generally level, but gently slopes toward the Housatonic and Far Mill rivers. The average elevation of the main plant is approximately 18 feet above mean sea level (msl). According to the 1978 Federal Insurance Administration Flood Boundary and Floodway Map for the town of Stratford, the 100-year flood level on the Housatonic River, adjacent to the Sikorsky property, is approximately 14 feet above msl. Most of the property is above this elevation; however, the two surface impoundments lie within the 100-year floodplain [ Figure 5]. The top of the impoundment walls are at an elevation of about 10 feet above msl, 4 feet below the 100 year flood level. * Metamorphosed rock which is coarser grained and less perfectly cleaved than slates, but finer-grained and better cleaved than mica schists ------- 10 foot contour at tiore line — — . — _ — . — C C — S — ilousatonic River Tidal Flat / ., 14 foot contour 100 year flood line S 6 80 FIGURE 5 100 YEAR FLOOD LEVEL-WASTEWATER TREATMENT AREA Manufacturing building 10 foot contour at shore line ! / — a S a . — — • 1 -r S l• S S _____ bldg. I \ Contro I W a stew a $ e r treatment plant area Fence / Scale in feet: \ ------- 35 HYDROLOGIC UNITS AND GROUND-WATER FLOW DIRECTION There is relatively little data available on the characteristics of the aquifers underlying the facility. The site is reportedly underlain by two aquifers which may or may not be hydraulically connected. They are identified as (1) a saturated sand and gravel (upper) aquifer and (2) an underlying more impervious glacial till/bedrock aquifer. The saturated thickness of the upper aquifer ranges from zero on the west side of the property to at least 80 feet beneath the eastern portion of the property. The presence of brackish water in both the sand/gravel aquifer and the upper portion of the bedrock aquifer (as stated by Dames & Moore) suggests a hydraulic connection between the aquifers and the Housatonic River. The Dames & Moore report states that ground-water flow is slower in the more impervious glacial till/bedrock aquifer than in the sand and gravel aquifer and that the glacial till/bedrock tends to act as a barrier to limit the yield of wells completed in the upper aquifer. The ground water in the upper aquifer is stated to flow more readily toward the Housatonic River than downward into the underlying glacial till/bedrock. The Sikorsky request for a waiver (Dames and Moore report) of the RCRA ground-water monitoring requirements (discussed later), was based on the premise that any seepage from the surface impoundments would go directly to the river rather than into the deeper, drinking-water aquifer, so monitoring of the impoundments was not necessary. The Dames & Moore report did not adequately establish the potential for migration of hazardous waste or hazard- ous waste constituents entering the ground water to the surface water, as required by Section 265.90(c)(2). In addition, the available hydrogeologic reports do not adequately characterize the area hydrogeologic units and the ground-water flow direc- tion. The rate of flow through the aquifers has not been defined and tidal effects on the ground-water flow have not been addressed. Tidal fluctuations influence water levels in the monitoring wells and may also effect the migra- tion of any hazardous waste or hazardous waste constituents which enter the ground water through leaking surface impoundments. ------- 36 WATER LEVEL MEASUREMENTS/TIDAL INFLUENCES The Sikorsky monitoring well network, located within the flood plain of the tidally-influenced Housatonic River, is affected by tidal fluctua- tions. Water level measurements reported by Sikorsky are highly variable from one quarter to another and Task Force monitoring showed water level variations correlating with tidal phases. In addition, sludge discharged to the active surface impoundment appears to affect the water level in an adjacent downgradient monitoring well (B-2). The EPA Task Force contractor installed ISCO flow meters in each of the four monitoring wells following completion of all the Task Force sam- pling. The method of calibration and operation of the water level recorders was discussed in the Sampling and Analysis section of the report. The ISCO meters continuously recorded water levels in the wells over an approximate 48-hour period. Appendix 0 presents copies of the recording strip charts from each well. The National Oceanic Survey maintains surface water level records for the Housatonic River at gauging stations located in Shelton, 5½ miles upriver, and Stratford, 4 miles downriver from Sikorsky as well as Bridgeport Harbor on Long Island Sound. Each of the four monitoring wells showed regular water level variations with amplitudes ranging from an average of 1/10th of a foot (B-i) to 2/lOths of a foot (B-2) during the tidal phases. Table 6 shows surface water fluctua- tions on the Housatonic River during daily tides, as reported by the National Oceanic Survey for the week of the Task Force inspection. This data shows tidal fluctuations as a function of distance from Long Island Sound. The ISCO meters recorded periodic water level fluctuation in the monitoring wells which correlate with the surface water tidal changes. ------- 37 Tab’e 6 TIDES DURING THE WEEK OF MAY 6, 1986 FOR THE HOUSATONIC RIVER* Date Time Height** §ri e May 6, 1986 Harbor, Connecticut 0334 -.3 0939 65 1544 .1 2152 7.1 May 7, 1986 0416 - 4 1021 64 1622 2 2230 72 May 8, 1986 0453 -.5 1058 6.3 1659 3 2309 71 May 9, 1986 0531 -.4 1134 6.3 1735 -4 2341 71 Stratford, Connecticut May 6, 1986 0435 - 3 1005 5.2 1645 1 2218 5.8 May 7, 1986 0517 -.4 1047 51 1723 2 2256 59 May 8, 1986 0554 - 5 1124 5.0 1800 3 2330 58 May 9, 1986 0632 - 4 1200 5.0 1836 .4 2407 5.8 Sheldon, Connecticut May 6, 1986 0618 -.3 1130 4.7 1828 1 2327 5.3 May 7, 1986 0700 - 4 1156 4.6 1906 2 2405 5.4 May 8, 1986 0737 - 5 1233 45 1943 .3 2439 5.3 May 9, 1986 0815 - 4 1309 4.5 2019 4 2516 5.3 * All data received from the National Oceanic Survey ** All heights measured in feet relative to mean sea level (uzsl) ------- 38 The rise and fall of water levels in the wells followed the tidal highs and lows of the Housatonic by approximately 2 hours. This lag time is attributed to the hydraulic differences between open channel flow in the river and ground-water flow. ISCO meters on wells B-i, B-3 and B-4 recorded similar water level curves throughout the period of operation [ Figure 6]. The curve recorded for well B-2 deviated from the others. Wells B-2 and B-3 recorded similar water level changes from 1800 hours on May 6 until 0700 hours on May 7. During this time, two low and one high tide events took place in the river (ISCO meters were only operating in these two wells during this time). After 0900 hours on May 7, well B-2 began to deviate from the the other wells (by this time ISCO meters were also operating on wells B-i and B-4). All the wells, with the exception of B-2, recorded water level changes correlated to tidal fluctuations. The deviation in ground-water levels recorded for well B-2 was probably due to a sludge discharge to the adjacent surface impoundment. Well B-2 is located within 5 feet of the active southern surface impound- ment. The portion of the impoundment adjacent to the well has earthen sides [ Figure 4]. On May 7, at approximately 0915 hours, WTP sludge was discharged to the impoundment. This was the only sludge discharge observed during the time the [ SCO meters were operating. The water level recorded by the ISCO meter for well B-2 remained relatively constant for a period of approximately 8 hours (from 0900 to 1800 hours) on May 7 even though one tidal cycle was completed. During this same time period the impoundment had free standing liquid in it. From 1800 hours on May 7 until approximately 2100 hours on May 8, well B-2 had a steadily decreasing water level even though two tidal cycles were completed. The water level in well B-2 during this period was apparently affected by two components, tidal action and the hydraulic head created by the liquid in the adjacent impoundment. Liquid draining from the surface ------- Tides Week of Nay $I S0 39 — — $rId .po ,t Sirsiford • Skelto. * : / Ti.. 1200 2400 1100 2400 1200 2400 1200 2400 Dat. 5/0 5/7 S / I 5/0 Well $1 0 .. .... .. ... is 0 1200 2400 1200 2400 1200 2400 1200 2400 Date 5/ . 5/7 5/I 5/0 Well 51 I I ’ • 75 ..* 150 .... 25 0 Tl,e 1200 2400 1200 2400 1200 2400 1200 2400 Date S/S 5/7 s’s i,, — Well $3 I I ’ I:: ...................... ........................................ . 0 Tt.e 1200 2400 1200 2400 1200 2400 1200 2400 Date 5/0 5/7 5/ 5 5/0 Well $4 S U. A ....••••••...........•••••••..* •50 2$ 0 TI.. 1200 2400 1200 2400 1200 2400 1200 2400 Dat. 5/7 5/5 5, FIGURE 6 Water Levels In River and Monitoring Well. * Water level recorder reset or replaced bacace. the unit was Jarred during manual water level determinations ------- 40 impoundment apparently masked the tidal influence and resulted in steadily dropping water levels as the impoundment drained, even though two tidal cycles were completed. In other words, the water level drop in well 8-2 corresponds directly to the dewatering of the impoundment. The water level in B-2 did not follow the tidal cycle until the sludge was fairly dry. When dry, there would be no contributing hydraulic head from the impoundment and tidal effects would once again dominate. The curve recorded by the ISCO meter on well B-2 from May 7 through May 8 represents the impoundment liquid draining through its sand and gravel bottom and earthern sides into the uppermost aquifer. From 2100 hours on May 8 until 0700 hours on May 9, well B-2 had water level changes similar to those in the other three monitoring wells. By the morning of May 9, dessication cracks were observed in the dewatering sludge adjacent to the earthen area indicating that the sludge was drying. Based on the continuous water level recordings, water levels in all of the monitoring wells are influenced by tidal action. Furthermore, the water level in at least one well (B-2) appears to be affected by liquid draining from the active surface impoundment. This latter observation suggests that liquid is leaking from the surface impoundment and entering the ground water. The other downgradient wells may be expected to show similar water level changes when the northern impoundment is loaded. At this time it is unknown if the ground-water quality of the monitor- ing wells is affected by tidal influences. It is also not known to what extent the impoundment is leaking and the effects of leakage on the ground- water quality. Additional study is necessary to properly identify effects of tidal fluctuation and leaking impoundments on the monitoring wells includ- ing delineation of any hazardous waste constituent plume. Identification of these effects is critical because they may influence water quality of the upgradient well, B-i, since hazardous waste or hazardous waste constit- uents from the surface impoundments may, as a result of tidal action, reach the well. Because of this, the adequacy of B-i to properly identify back- ground ground-water quality is questionable. ------- 41 GROUND-WATER MONITORING PROGRAM UNDER INTERIM STATUS Ground-water monitoring at Sikorsky has been conducted under the requirements of State and Federal interim status regulations. Because the State of Connecticut incorporated 40 CFR Part 265, Subpart F, into their regulations by reference, the ground-water monitoring requirements for Sikorsky have remained constant even though the Agency, having the primary authority (EPA or CTDEP), has changed. Sikorsky submitted a ground-water monitoring waiver demonstration to EPA Region I in January 1982. In general, the waiver submittal concluded that contamination of a nonpotable ground-water supply presumably discharging to the Housatonic was not a serious problem. The uppermost aquifer is not a potable water supply source because it is brackish. It was further reasoned that the sludge leachate was similar in quality to the W’WTP effluent discharged under NPDES; hence, no serious contamination problem would occur that would endanger human health. CTDEP (who recieved interim authorization in April 1982) denied the waiver on November 23, 1982 because Sikorsky had not demon- strated a low potential for migration of contaminants from the regulated units into ground or surface waters. The facility installed and began sam- pling ground-water monitoring wells in 1983. The following is an evaluation of the interim status monitoring program between November 1981, when the ground-water monitoring provisions of the RCRA regulations became effective, and May 1986, when the Task Force investi- gation was conducted. This section addresses: 1. Regulatory requirements 2. Ground-water sampling and analysis plan 3. Monitoring wells 4. Sikorsky sample collection and handling procedures 5. Tidal influences on monitoring results 6. Ground-Water Quality Assessment Program ------- 42 REGULATORY REQUIREMENTS Ground-water monitoring at the site has been regulated by both EPA and CTDEP. EPA had jurisdiction for interim status requirements (40 CFR Part 265, Subpart F) from November 1981 through April 1982. The State received interim authorization in April 1982 and maintained jurisdiction [ 25-54cc(c)- 33] through January 1986. On January 31, 1986 the RCRA interim status author- ity reverted back to EPA Region I since the State of Connecticut had not received Final Authorization by that date, as required by RCRA Section 3006 (c)(1). On February 16, 1986, the State of Connecticut modified and recodi- fied their hazardous waste regulations. State ground-water monitoring regu- lations are now found in State of Connecticut Regulation of Department of Environmental Protection 22a-449(c)-29. The State was seeking Final Authorization at the time of the Task Force investigation. The State regulations requiring ground-water monitoring are the same as 40 CFR Part 265, Subpart F, except the State added the additional require- ment that the ground-water monitoring plan is to be submitted and approved by the CTDEP. Because the State incorporated Federal regulations by reference, Federal regulations will be cited in the following discussions. MONITORING WELL NETWORK Four wells have been installed by Sikorsky for their designated RCRA interim status ground-water monitoring system. Installation was delayed until 1983 because of a waiver request submitted in January 1982 to EPA Region I. The waiver request was subsequently reviewed by CTDEP when the state recieved RCRA Phase I authorization in April 1982. The waiver was denied in November of 1982 and CTDEP required interim status monitoring wells to be installed by Febraury 1, 1983. Sikorsky requested further time to study the option of impoundment removal, but notified CTDEP on March 10, 1983 that the wells would be installed. The wells were completed in September 1983 and include one upgradient (B-i) and three downgradient (B-2 through B-4) wells [ Figure 7]. There have been no subsequent modifications to this original well network. ------- Housatonic River Tidal Flat , . / . / .,• \ -9 14 foot contour 100 year flood line 40 80 FIGURE 7 Upgradlent monitoring well • B-i SIKORSKY GROUND-WATER MONITORING SYSTEM Manufacturing building foot contour at shore line Downgradient monitoring wells C- 10 loot contour at shore line . — a S a — — a . — • — • • _____ — • — a I I ‘a a a_zr • I \ Control 1 I bldg. Waste water treatment plant area Fence 7 Scale in feet: \ C A ) ------- 44 Well Construction Sikorsky reported that the monitoring wells were drilled on September 20, 1983 with a 4-inch hollow stem auger to a total depth of 26.5 feet for well B-i (upgradient) and 17.5 feet for wells B-2 through B-4. After the drill auger was pulled out and the 2-inch polyvinyl chloride (PVC) pipe installed, the screened portion of the borehole was packed with a course sand and fine gravel mix. A 2-foot section of the annular space just above the static water level was sealed with a plug formed from bentonite pellets. The remainder of the hole was filled with earthen material and tamped [ Figure 8]. The sampling and analysis plan indicated that the drilling contractor was required to prepare a geological log and record including the actual borehole depth, screened casing length, depth to the top of the screened casing and ground-water depth before the auger was removed; however, these records were not maintained by Sikorsky as only a generic well diagram was available during the inspection. The wells were constructed with 2-inch diameter schedule 80 PVC pipe with a 10-foot slotted section at the bottom. Although contract personnel indicated that the top of this 10-foot slotted pipe was installed 2 feet below the seasonal low water level, actual water levels measured by the facility [ Appendices B and F] indicate that the well was not installed as reported. Water levels of less than 2 feet were reported for two quarters of monitoring. Therefore, the wells could not have been constructed with 10 feet of screen set two feet below the “seasonal low water level”, as descri bed. A 5-foot section of 3-inch diameter steel surface casing pipe was fitted over the PVC casing and set into a 1-foot concrete cap. The top of the steel surface casing was threaded with a protective cap and equipped with a lock. Each of the wells was permanently marked with an identification number. After completion, each well was developed using a portable pump to evacuate the well until the water was visably free of suspended sediment. The general construction procedures reportedly used in the monitoring wells, as described by IPC, may be inadequate. Although construction ------- 45 3fl dia srw’d, Iron pipe cap with padlock tab 3 dia. sch. 40, cs. pipe 5’O” 1g. threaded one end, with padlock tab ,. - Backfill with ..— excavated materials 2’O” bentonite seal (pellets) 2’-O ” Elevation in respect to datum ,.- for top of 3” dia. protective pipe, to be determined by owner 1’-O” Existing grade 2” dia. sch. 80 PVC flush threaded joint, well pipe, length as required 2 dia. sch 80 PVC flush threaded joint, slotted well screen and plug .10’-0” 1g. with #10 slot, with nylon filter cloth cover (celanse mirafi #140) fitted and heat tacked to screen pipe PVC plug 4— lop of screen section II II II II II II II — Seasonal low water table Figure 8 Well Construction Concrete plug dia. at grade 1 -0” deep . -_4 ” dia. augered borehole Course sand gravel mix backfill this section Typical ------- 46 procedures outlined by the contractor did not mention the use or installation of filter cloth, the construction diagram provided by Sikorsky [ Figure 8] indicates that “celanse mirafi #140” filter cloth was installed over the well screen. The 1986 RCRA Ground-Water Monitoring Technical Enforcement Guidance Document* states that fabric filters should not be used as filter pack material. The use of this fabric filter could not be verified because well construction details were not available; however, if this fabric was used, the wells may not provide representative ground-water samples. Records should have been maintained for individual wells indicating lithology and exact location of screens and casings as well as thickness, type and location of cement and filter packs. Without these details, it is not possible to determine whether these wells are properly constructed to monitor the uppermost aquifer. Number and Location The number and location of Sikorsky-designated RCRA wells was based on both regulatory requirements [ 40 CFR 265.91] and regional ground—water flow directions. Although the number of monitoring wells complies with require- ments for detection monitoirng, the upgradient well may not be properly located to monitor background water quality. If sampled properly, the cur- rent system of wells may be adequate to identify waste entering the upper- most aquifer from the surface impoundments but because of tidal influences, the upgradient well may be affected by the facility and, thus, it may not be capable of providing ground-water samples to accurately identify back- ground water quality. Values obtained for ground-water monitoring parameters by Sikorsky for B-i have varied widely, making identification of background levels suspect. The downgradient wells are at the downgradient limit of the waste man- agement areas and have identified statistically significant amounts of haz- ardous waste constituents in the ground water (TOX and specific conductance). * Page 83 September 1986, OSWER-9950. ------- 47 This determination, however, is complicated by the previously discussed tidal effects. Further study is necessary to determine the extent of the tidal influences on these wells (i.e., water quality effects). GROUND-WATER SAMPLING AND ANALYSIS PLAN A single ground-water sampling and analysis plan was prepared for the site in June 1983. It had undergone revisions before it was approved by the CTDEP in September 1983. The plan is still being used but does not meet the requirements of 40 CFR 265.92. The plan did not require sampling and analysis of all the required drinking water parameters. Endrin, lindane, methoxych]or, toxaphene, 2,4-D, 2,4,5-TP, radium, gross alpha, gross beta, turbidity and choloform bacteria were omitted. According to the plan, well water level measurements are made using a chalked tape measure; however, the plan did not indicate if different tapes would be used for each well and there are no tape decontamination procedures if a single tape is to be used for all wells. Use of an unweighted measuring tape can lead to inaccurate water level results due to bending of the tape. The monitoring plan also did not discuss whether dedicated pumps would be used to purge and sample each well. If a single pump is used, decontam- ination procedures need to be described. The lack of decontamination proce- dures for reuseable sampling and monitoring equipment can lead to cross- contamination of wells. Contamination of a well, caused by improperly cleaned equipment, will generate inaccurate data. Purge volumes were calculated in the plan using a single assumed water level of 7 feet for each well. Three casing volumes are required to be purged prior to sampling (3.15 gallons using the assumed 7 feet of well water); however, because this purge volume does not reflect the actual water level in the well at the time of sample collection it may be insufficient to ensure that representative formation water is being sampled. In fact, ------- 48 had the Sikorsky contractor sampled at the same time as the Task Force, when well water levels were greater than 7 feet [ Table 1], their calculated purge volume would have been substantially less than three actual casing volumes. Each time the well is sampled, the purge volume should be calcu- lated based on the actual water level at that time. This will help ensure comparable sample analysis results. The monitoring plan does not describe procedures to handle and dispose of purge and excess sample water. If this water is not properly handled, contaminants can be introduced into the well(s) and affect sample analysis results. The plan does not list specific analytical methods for each parameter. Although reference is made to two analytical method sources, SW-846, 1982, “Test Methods for Evaluating Solid Wastes, Physical Chemical Methods” and “Standard Methods for the Examination of Water and Wastewater”, no specific edition is cited. The plan indicates that all analysis would be conducted by SW-846 methods. This is inadequate to describe the methods to be used in cases where the reference document contains two or more methods for the same parameter. For example, there are three SW-846 methods for phenols and four for sulfates. Different methods can result in different analytical results. The plan does not describe a quality assurance/quality control program (QAIQC). The failure to require standard operating procedures to ensure accurate calibration curves, fresh reagents, equipment calibration procedures, equipment cleaning procedures, etc. can result in erroneous data. Finally, the data obtained from implementation of the Sikorsky plan is inadequate to establish initial background concentrations or values for all parameters required by Federal [ 40 CFR 265.92(c)] and State regulations. Facility ground-water monitoring data obtained since 1983 shows wide concen- tration variations for a number of parameters. Because these variations are probably caused by factors such as tidal influences, surface impoundment loading, sampling inadequacies or laboratory inaccuracies, this data cannot ------- 49 be confidently used to determine background water quality. Study is necessary to identify the exact cause(s) of the wide variations observed in the data and the plan must be modified to address the(se) cause(s). SIKORSKY SAMPLE COLLECTION AND HANDLING PROCEDURES A Sikorsky contractor, IPC, samples the wells for the required interim status monitoring. CTDEP requested Sikorsky delay collection of their quarterly monitoring samples to coincide with the Task Force inspection so that IPC sampling protocol could be evaluated by the Task Force. In general, some of the IPC methods may not yield representative results and IPC did not use the sampling equipment or follow some of the sampling procedures specified in the plan. A description of the IPC protocol and an evaluation follows. Water Level Measurements The method used by IPC for measuring ground-water level in the wells is inadequate because it can cause contamination of the well water and may not be accurate. IPC lowers a 25-foot metal tape, the end of which is coated with a blue carpenter’s chalk, into the well to the approximate water level (expected to be 8 to 10 feet below the surface). The length lowered is noted relative to a casing reference point (at the top of the outer protec- tive pipe) at the surface. The tape is withdrawn to determine the wetted chalk length. The wetted length is subtracted from the total length lowered, to determine the depth to water from the surface. IPC reduces each measure- ment to a common datum (ground surface elevation related to mean sea level) to account for varying casing heights. The casing reference elevation was determined after well installation by surveying, and is a fixed value related to the number of feet above sea level. The use of an unweighted metal tape may not produce accurate or repro- ducible results since the tape can bend in the well. The total depth of the well was also never measured for determination of the total height of the water column in the well. When IPC demonstrated the above procedures ------- 50 they did not decontaminate the metal tape either before or after taking water level readings. In addition, the tape had to be rechalked or run into a well several times because either the chalk had been washed away or the chalk had not reached the water. When withdrawing the tape from each well, the tape was pulled out of the well and laid on the ground until the end was retrieved. The ground was not covered with plastic or any other covering and there were a variety of contaminants picked up by the tape during the demonstration including rabbit fur and dried sludge particles (apparently blown from the impoundments). Purging Procedures IPC does not purge consistent volumes of water prior to sampling (the plan requires 3.15 gallons per well), nor do they use similar methods to purge each well. The number of casing volumes purged during each sampling event is not consistent. IPC does not calculate the standing water in the well at the time of sampling, rather, they assume 7 feet of water in each of the wells. Using a 2-inch casing diameter and the assumed 7 feet of standing water, one purge volume is 1.05 gallons. The plan specifies the purging of three casing volumes before sampling a well. Therefore, 3.15 gallons is supposed to be removed from each well during the purging process. Differences in water levels between up and downgradient wells and for the same wells during different periods of the year are not accounted for in the calculations. IPC used two different methods of purging wells. The first two wells (B-i and B-2) were purged using a 2-foot-long Timko 1¼-inch-diameter schedule 40 bottom-filling PVC bailer. The bailer was removed from the back of a pickup truck where it had not been covered by protective wrapping. The bailer was not decontaminated prior to use and it was visibly dirty from debris in the truck or from previous use. The bailer was lowered into the well using a nylon rope until the rope went slack (bailer hit bottom). The rope and bailer were then withdrawn from the well and the rope coiled on the ground. While the bailer was being emptied into a five-gallon bucket, the sampler often stepped on the rope. The bailer was lowered and retrieved ------- 51 repeatedly until the bucket was filled to a point marked at 3 gallons. The bailer was reused on well B-2 after the sampler’s hands, and the bailer, were rinsed with distilled water. Purge water was dumped from the bucket into a tank at the MTP after purging well B-i and dumped into the southern surface impoundment after purging well B-2. Wells B-3 and B-4 were purged with a DC motor-driven peristaltic pump* with silicone tubing. The tubing was rinsed with distilled water and then laid on the ground, unprotected. The tubing is dedicated to an individual well. The contractor determined the purging time by timing the filling of a 500-mL beaker (21.7 seconds). IPC determined the pump should operate for 8.7 minutes to purge 3½ gallons (although the plan calculated three casing volumes was 3.15 gallons). The purge water was not collected in a bucket as before. Instead, the water was allowed to run onto, and percolate into, the ground. At well B-3, the pump tubing was inadvertently pinched follow- ing determination of pumping time but compensation was never made for the lower pumping rate and a volume less than 3½ gallons was probably purged. The inconsistent and inadequate methods of purging and equipment decon- tamination make these methods unacceptable. IPC should have used the water level measurements and current total well depth to calculate the standing water in the well and required purging volume. Water level measurements over the six quarters monitored by the facility show 2- to 3-foot water level fluctuation. IPC’s assumption of 7 feet of standing water is not accurate and their procedure of removing three casing volumes of water from each well is not accurate given the variation between water levels in the wells [ Figure 9, also see Appendices B and F]. All equipment placed into the well casing should be properly decontam- inated prior to each use and the ground should be covered so equipment does not pick up contamination from the soil. Purge water should be uniformly collected in a graduated bucket and disposed of in an environmentally sound manner (not discharged to the ground). * Masterfiex Pump Model #7533-30 which z,ms of f of a 2.5 amp car battery ------- Figure 9 Water Level Measurements Reported by Sikorsky and Corresponding Tidal Phase Hig 1 ,,/ Legend I_ Low.. U Well Bi I * Well B2 * Well B3 • Well B4 Direction of Tidal Flow a 4 I. . a • a U • I * a 4 • * * . * £ A 2 e U * 4 I 0 1 2 3 4 5 6 7 8 MonItoring Quarters ------- 53 Sampling Methods As with the purging methods, IPC personnel did not use the same sampling methods for all wells. They used a PVC bailer to sample wells B-i and B-2 and withdraw the volatile organic samples from wells B-3 and B-4 and peristal- tic pump for the other sampling at wells B-3 and B-4. The purpose of taking ground-water samples is to obtain information representative of water quality. The use of uniform methods to obtain all samples is necessary to enable comparison of analytical results. Following purging, IPC uses the first bailer or pumped water to measure the field parameters of temperature, pH* and specific conductivity.** The next bailer or pumped volume is collected for metals analysis and is poured into a 500 mL disposable “Nalgene filter (.45 micron) and beaker (one dedi- cated to each well). Once the sample is filtered, the sampler pours deionized water through a funnel arid then pours the filtered sample through the funnel into a glass sample bottle containing nitric acid. In each of the bottles used for the metals samples, the nitric acid had vaporized and a brown puff of nitric acid escaped the bottle as the sample was poured in. The contract laboratory prepares all the bottles with preservatives and labels. The remaining samples were filled directly from the bailer or pump tubing and preserved in accordance with Table 7. A bailer was used to col- lect all volatile organics samples. The inside and outside of the bailer was rinsed with distilled water before being lowered into the well. The 60 mL amber vials for volatile organic samples were filled to the top and examined to ensure that no air bubbles remained after the teflon-lined lid was screwed on. * pH meter-YSI Model #33 S-C-T. Buffers used to calibrate at 4.7 and 10 units. New buffers from lab each sampling date. ** Specific conductivity meter Macalister Scientific, no model number. ------- 54 Table 7 SAMPLING ORDER, CONSTITUENTS AND PRESERVATIVES - IPC Order Bo ttle Type Volume (m2) Parameters Preservative 1 2 1 qt. 1 qt. clear glass clear glass 500 750 SO 4 , Cl, pH, specific conductivity Dissolved Fe, Mn, Cr, Cu, Cd, Na and Ni None HNO 3 3 4 5 1 qt. 1-60 1-60 clear glass m2 amber glass m amber glass 750 60 60 Phenols, TOC TOX VOC (1, 1,1-Trichloroethene tn chi oroethyl ene, tetrachioroethene, methyl ethyl ketone, chloroform) H 2 S0 4 None None 6 1 qt. clear glass 500 CN None The sampling procedures may not generate representative samples because of the potential variability introduced by not utilizing the same type of samplers at each well. In addition, the pH was never checked for the pre- served metals samples to ensure that they had been acidified to a pH less than 2, as recommended. Decontamination and excess sample water were both poured on the ground rather than collected and disposed of at the treatment system. This can result in contamination. Chain-of-Custody and Shipping Procedures Once each sample bottle was filled and the cap replaced, a plastic custody tag was affixed to the bottle indicating the well number, sampling quarter, date, person sampling, analysis required, etc. The sampler does not sign the custody tag. The tag is signed by the lab and returned to the sampler along with the analytical results to be filed with the monitoring record. The field sheets including the sampling data, time, ground-water levels and field parameters are kept by IPC and included in their report to Sikorsky. Statistical analysis of the analytical results is included in these reports. ------- 55 After all of the samples are taken and the custody tags are secured to each sample, the bottles are packed into an ice chest and delivered by the sampler to the analytical lab on the same day. These procedures are generally acceptable, except the samples were not put on ice, although they were put into ice chests. EPA methods recommend that samples be refrigerated or packed on ice following collection. Although the analytical laboratory is reportedly near the Sikorsky facility, the samples should be iced, as it takes several hours to collect all the samples. IPC Sampling Procedures Inconsistent with Sampling and Analysis Plan IPC did not follow all of the provisions of the CTDEP approved ground- water monitoring sampling and analysis plan, as follows: Sampling equipment specified in the plan was not always used. The plan specifies the use of a peristaltic pump for purging and sampling; however, a bailer was used on the first two wells sampled (B-i and B-2) reportedly because IPC had observed the Task Force contractors using bailers rather than pumps. IPC used the pump on wells B-3 and B-4. • IPC personnel did not completely fill all of the sample bottles, as specified in the plan. The monitoring plan indicates that all bottles are to be filled to the top and tightly capped. Only total organic halogen (TOX) and volatile organic carbon (VOC) sample bottles were filled to the top. • IPC personnel did not always collect the quantity of samples specified in the plan. The plan requires one liter of sample for sample #1 (pH, specific conductance, sulfates and dissolved metals); however, only 500 mL of sample was taken. Likewise, the plan specifies 500 mL each for TOX and VOC, although only 60 mL vials were filled for each of these samples. Although, the volumes taken were probably adequate for the required analysis (if quality ------- 56 control samples are not run), the plan should be modified to reflect the actual quantities taken. The wells are not always purged of three well casing volumes, as specified in the plan. The method used to calculate casing volume does not account for the observed ground-water level fluctuations, rather it always assumes a water column of 7 feet. For most, if not all sampling dates, there was less than a 7-foot water column (between 0.2 and 5 feet) in the wells so that more than three casing volumes were probably purged. The plan should require a more accurate calculation of purging volume using actual rather than an assumed water column height. Also, variations in purging techniques resulted in variability in the actual number of casing volumes purged from each well. To enhance the reliability and comparibility of sample results, purging methods should be standardi zed. SAMPLE ANALYSIS AND DATA QUALITY ASSESSMENT This section provides an evaluation of the quality of interim status ground-water monitoring data gathered by Sikorsky between October 1983 and March 1986. Baron Consulting Company of Milford, Connecticut (Baron) per- formed the analytical testing of ground-water samples from Sikorsky between October 1983 and September 1984 (the initial year of monitoring) and 1986, through a contract with IPC. The 1985 ground-water samples were analyzed by York laboratories. The Baron laboratory was visited in early May 1986 as part of the Task Force evaluation. The laboratory procedures used at Baron include those identified in U.S. EPA Publication SW—846, 1982 (SW-846), “Standard Methods for the Exam- ination of Water and Wastewater”, WPCF-AWt 1A, and EPA Publication 600/4-79-020, “Methods for Chemical Analysis of Water and Wastes”. The Sikorsky ground- water sampling and analyses plan states that all analyses will be conducted following SW-846; however, SW-846 analytical methods were not used for chlor- inated organic compounds, mercury, arsenic, sulfate and fluoride. ------- 57 The evaluation also revealed that data from 1983 to 1984 were often of poor analytical quality and incomplete. Data derived from present (1986) laboratory procedures are somewhat improved although procedural inadequacies still exist. Initial Year of Monitoring In October 1983, Sikorsky initiated quarterly monitoring, of the RCRA well network pursuant to 40 CFR 265.92(c). Four quarterly monitoring reports and associated laboratory records were reviewed for this well network. The monitoring lacked analysis of some of the required parameters and contained reporting errors. The laboratory maintained no raw data records of the analyses performed during this period and the present. staff did not have knowledge of the procedures and practices used during this time. The present staff indicated that no standard set of quality assurance or quality control procedures were followed. Common control measures such as the analysis of laboratory blanks, replicates, spiked samples and internal check samples could not be verified to have been analyzed. Evaluation, based on the results of these control measures, could not be conducted. Other means of data evaluation, however, indicate that some data are acceptable, while others are unreliable or biased. Quadruplicate measurements were reported to CTDEP for the four indicator parameters (pH, specific conductance, TOC and lOX) for both the upgradient and downgradient well samples. IPC measured pH for all quarterly samples and specific conductance for the fourth quarter samples in the field; however, the results reported to CTDEP in the quarterly monitoring reports for pH and specific conductance were those obtained in the laboratory by Baron and not in the field as the samples were taken. The validity of the p11 measure- ments made by Baron are suspect since the measurements were probably made well after the former recommended holding time of 2 hours and substantially after the present recommended holding time of 15 minutes. Comparing the field pH measurements made by IPC to the results reported by Baron, large differences are observed. For example, IPC obtained a pH ------- 58 of 6.7 for well B-3 in the third quarter while Baron reported a pH of 8.02. This suggests that the pH values reported in the monitoring report are not reliable. Similar comparison of field and Baron specific conductance measurements for the fourth quarter samples shows that values reported by Baron were always greater than the field measured values; the differences were approxi- mately 20%. Total organic carbon (TOC) results are suspect. TOC concentrations were determined using a method that was inappropriate for the organic carbon levels present. The organic carbon was calculated from the difference between total carbon and inorganic carbon determinations. When the inorganic carbon makes up most of the total carbon, the analysis variability becomes a signif- icant factor and results in large systematic biases. TOC should have been determined by measuring nonpurgeable organic carbon and purgeable organic carbon. This appears to be substantiated by the large fluctuation of the TOC values between quarters for the wells and lack of correlation between changes in TOC and total organic halide (lOX). For example, TOG values decrease by a factor of fourteen (from 22.3 mg/L to 1.6 mg/L) for well B-i between the third and fourth quarters, while the lox value more than doubled. Similarly, the ratio (mg/L per mg/L) of TOC to lOX for well B-4 in the first quarter was about 62 while in the second quarter the ratio was 1.8. lox values for the second and third quarters of 1984 were improperly reported to CTDEP in units of ug/L when they should have been in mg/L. Comparison of the iox calculated from the results for the four chlori- nated organic compounds analyzed as part of additional required monitoring indicates that the measured lOX results are reliable to within about 30% of the actual TOX concentration. The measured lOX values are greater than the calculated TOX values. The first quarter results differed by the greatest amount with the ratio of the measured TOX to the calculated lOX ranging from 1.24 to 1.34 for the four wells. The ratios for the later quarters ranged from 1.05 to 1.19. The fact that the measured lOX was always greater ------- 59 than the calculated value could indicate the presence of other chlorinated organics or inappropriate blank correction for the measured TOX values. The specific chlorinated organic compounds including chloroform, 1,1,1trichloroethane, trichioroethene and tetrachioroethene were determined using a liquid/liquid extraction and gas chromatography with an electron capture detector. This method states that analyses for trichloroethane, trichloroethene and tetrachioroethene should be confirmed by an alternate gas chromatography column or by gas chromatography/mass spectroscopy. No confirmational analyses were performed. Because of the lack of laboratory records, the only measure suggesting that the results for these compounds are reliable is the good correlation with the measured lOX results. Cyanide was determined by an inappropriate method for the levels that may be expected in ground water. The laboratory used a titration method which is recommended for waters containing cyanide in excess of 1 mg/L. Since cyanide was not found at concentrations greater than 1 mg/L, any reported cyanide concentrations below 1 mg/L are not reliable. Samples collected for the eight metals an the drinking water parameter list (40 CFR 265, Appendix III) and for the two additional metals (copper and nickel) specified in the RCRA permit application were handled in such a manner that comparisons between quarterly data are not reliable. Mercury samples were never digested causing the results to be biased low. The first quarter samples for the other metals were not filtered or digested, while the second and third quarter samples were digested with a nitric acid and perchioric acid solution. The fourth quarter samples were acidified and then filtered; they were not digested. The inconsistency in the handling procedure invalidates comparisons between quarters. The metals data pre- sented in the monitoring reports are not adequate for characterizing the suitability of the ground water as a drinking water supply. The flame atomic absorption spectroscopy method used by Baron for all metals, except mercury, does not achieve reliable results near the drinking water limits for arsenic, cadmium, lead and selenium. Furnace atomic ------- 60 absorption spectroscopy techniques, which are capable of achieving reliable results at low levels, should have been used for these elements. Fluoride results may not be reliable as samples were not distilled prior to measurement. Distillation may be required to eliminate possible interferences. Laboratory records do not indicate whether the recommended holding time for nitrate was exceeded. Furthermore, the nitrate method followed did not incorporate any steps to eliminate positive interference from nitrite. Sulfate data may also be unreliable. Indication of the unreliability of the sulfate results is found in comparison of the specific conductance to sulfate values. For example, for well B-i in the third quarter, the conductance measured in quadruplicate (which was in agreement with the field measurement) was 361 umhos/cm, while the sulfate was reported as 303 mg/L. In consideration of the concentrations of the other anions and cations, this large sulfate value is not substantiated by the relatively low conductance. Several of the required drinking water analyses were not performed during the initial year of monitoring including analysis for endrin, lindane, methoxychior, toxaphene, 2,4-0, 2,4,5-TP, radium, gross alpha, gross beta, turbidity and coliform bacteria. Semiannual Monitoring in 1985 and 1986 In 1985, samples were collected on a semiannual basis. IPC changed analytical laboratories, subcontracting the work to York Laboratories. Although this laboratory was not inspected by the Task Force, selected data submitted to CTDEP during this period was evaluated and portions were found to be unreliable. Large variations in quadruplicate measurements for pH were observed. For example, in July 1985, replicate pH measurements on the same sample ------- 61 ranged from 5.31 to 6.34. Good replicate pH measurements should differ by less than 0.1 units. Comparison of specific conductance measurements made in the field and in the laboratory are not always in agreement. For example, the laboratory values for the July 1985 samples for the conductance measure- ments for wells B-2 and B-4 were 50% and 44% higher than the field measurements. Inconsistencies exist between the measured lox values and the specific organic compound results. For example, a measured lOX of 2,570 pg/L was reported for well B-2 while the calculated lOX from the specific organics was less than 100 ig/L. A calculated iox of over 4,000 .ig/L was obtained for well B—3 for the second semiannual data while the measured lOX was only 1,540 ig/L. These inconsistencies suggest that either the measured lOX, which was measured in quadruplicate, or the specific organic analysis results are in error. In 1986, semiannual ground-water monitoring samples were analyzed by Baron. Although instrumentation and personnel have changed, many inade- quacies in the data quality and methods identified for Baron in the initial year of monitoring still exist. Flame atomic absorption spectroscopy is still used for most of the metals. Based on recent calibration curve data, the detection limits reported for many of the metals were not achieved. For example, a detection limit of 20 pgJL was claimed for lead while calculation of the detection limit by Baron personnel at the time of inspection gave a detection limit of 100 pg/L. Similarly, a detection limit of 10 pg/L was claimed for selen- ium; however, a detection limit of 200 pg/L was calculated from the calibra- tion data. The drinking water standards for lead and selenium are both 50 pg/L. More sensitive methods are needed for most of the metals and both total and dissolved metals should be determined. To enhance the quality of data at Baron, standard quality control measures need to be used for all the analyses and better recordkeeping ------- 62 practices should be implemented. Also, the method for specific conductance needs to include cell constant and temperature corrections. Measurements of pH should be performed in the field (within 15 minutes of collection) using appropriate calibration procedures. Calibrations for nitrate and fluoride should be more frequent. Nitrate determinations in the spring of 1986 were performed using a calibration curve developed in February 1985 while fluoride was being determined with a calibration curve developed in October 1985. The colorimetric method should be used for cyanide determin- ations instead of the insensitive titration method. TIDAL INFLUENCES ON GROUND-WATER MONITORING Tidal influences were observed in each of the four ground-water moni- toring wells during the inspection. Due to the observed water level fluc- tuation in the monitoring wells and potential water quality effects, tidal fluxes must be addressed when scheduling sampling. Tidal influences could alternately introduce brackish water into the wells (high tide) or wash away contaminants leaching from the impoundments (low tide). IPC always samples between 0800 and 1200 hours. Well sampling order is always the same with well B-i sampled first, followed by wells 8-2, B-3 and B—4. The Sikorsky sampling plan does not currently account for tidal fluctuations such as always requiring sampling at low tide. A review of the dates and times of historic quarterly sampling at Sikorsky indicates the samples were taken at a variety of tidal stages [ Figure 9]. Appendix E shows the tidal phases for the sampling dates and the corresponding times when samples were taken. Field data sheets do not indicate the exact times for sampling each well. Information is not avail- able on the sludge discharges to the impoundments which, as mentioned earlier, may affect water levels and probably affects water quality in the downgradient well 5. The variability in the ground-water elevations and sample results, coupled with the inconsistency in tidal stages during sampling, indicate ------- 63 the need to modify sampling procedures. Appendix F includes both data and graphs of the analytical results reported to CTDEP for interim status mon- itoring. There is a wide variability in values. Some results such as specific conductance, sodium and chloride, could be directly related to brackish water intrusion into the wells from the river. The heavy metals concentrations in ground water may be influenced by both brackish water intrusion and leakage from the impoundment. Further site characterization is needed to evaluate these effects. Standardization of sampling during a common tidal phase should be considered. Effects of both tidal influences and sludge discharge to the surface impoundments should be addressed when determining sampling dates/times. GROUND-WATER QUALITY ASSESSMENT OUTLINE AND PROGRAM PLAN State regulations 22a-449(c)-28 require that a facility meet the require- ments of 40 CFR 265.93 and prepare and submit a ground-water quality assessment program outline describing a more comprehensive ground-water monitoring program capable of determining: 1. Whether hazardous waste or hazardous waste consituents have entered the ground water 2. The rate and extent of migration of hazardous waste or hazardous waste consituents in the ground water 3. The concentrations of hazardous waste or hazardous waste constit- uents in the ground water If analyses conducted under the interim status program indicates that the facility may be affecting the ground water, additional samples are to be taken immediately to determine if the original analytical results were biased by laboratory error. If ground-water effects are still suspected, an assessment program is to be developed based on the outline and specifying: 1. Number, location, and depth of wells 2. Sampling and analytical methods for those hazardous wastes or hazardous waste consituents in the facility ------- 64 3. Evaluation procedures, including any use of previously gathered ground-water quality information 4. A schedule of implementation The Sikorsky assessment program outline, submitted on October 7, 1984 in the 1983-1984 Ground-Water Monitoring Program annual report,* does not meet the requirements of 40 CFR 265.93. Although it included construction of additional monitoring wells, the outline limited the circumstances which would require further investigation and did not include provisions to deter- mine the rate and extent of any contaminant migration beyond the property boundary. Semiannual interim status sampling for 1985 indicated significantly higher levels of specific conductance and TOX in the Sikorsky downgradient monitoring wells. As a result of this, CTDEP requested (December 3, 1985) that an assessment program plan be prepared and submitted. Sikorsky sub- mitted a program plan on January 13, 1986. The plan basically indicated that no additional work would be completed as “the intent of a ground-water quality assessment program at this monitoring site has been satisfied by the present ongoing monitoring and evaluation program. As a consequence, the present monitoring and evaluation program will be continued, using exist- ing procedures. No additional well installation, monitoring or analytical work has been planned for 1986 or beyond”. This “assessment program plan”, which is simply a continuation of the interim status monitoring program, is inadequate because it does not address any of the regulatory requirements for such a plan, as identified above. Also, Sikorsky did not follow the assessment program outline in prepar- ing the assessment program, as required. The outline indicates that “two additional sets of two cluster wells, screened at 25 to 35 feet and 50 to 60 feet” would be installed if an assessment program was required. * The same outline was submitted with the 1985 Ground-Water Monitoring Program annual report (september 30, 1985) and the RCPJi Part B permit application. ------- 65 The assessment program plan submitted does not mention additional monitoring points. Finally, the facility did not obtain additional ground-water samples to determine if the elevated lOX and specific conductance levels of the downgradient wells were the result of laboratory error, as required by 40 CFR 265.93 (c)(2). Rather, Sikorsky sent a letter (October 25, 1985) to CTDEP indicating that they did not feel additional work was necessary. ------- 66 GROUND-WATER MONITORING PROGRAM PROPOSED FOR RCRA PERMIT The ground-water monitoring program proposed in the Sikorsky RCRA Part B permit application, submitted to CTDEP on November 8, 1985, does not meet the requirements of 40 CFR 270.14(c).* These regulations require that any plume of ground-water contamination be described in the application. Addi- tionally, because the RCRA application was submitted after assessment was triggered (October 1985), the application must address the additional requirements of 40 CFR 270.14(c)(7). This includes establishment of a compliance monitoring system and submittal of an engineering feasibility plan for a corrective action program. The November 8, 1985 Sikorsky RCRA Part B permit application does not describe the plume of contamination, even though assessment was triggered suggesting ground-water contamination. The ground-water monitoring program proposed in the permit application is a detection program and not a compliance monitoring program, as required. The proposed program does not address the compliance monitoring program requirements for characterizing contaminated ground water and proposed concentration limits for identified constituents. The permit application does not include the necessary engineering feasibil- ity plans for a corrective action program. Although not appropriate, the detection program that is proposed does not meet the requirements of 40 CFR 264.97 because it does not specify the analytical procedures to be used to analyze over half of the proposed indicator parameters. The ground-water level determination procedures are inadequate since there are no provisions to decontaminate the equipment reused for each well. The proposed program calls for the use of the existing interim status monitoring program. As discussed earlier, this program has not provided * State regulation Section 22a-449(c)-16 generally requires that facili- ties meet the permit application requirements of 40 CFR 270 and thus, only specific Federal regulations will be cited here. ------- 67 adequate background characterization of the site’s ground water. Without further study it is unknown whether these wells, as they are currently used, are capable of yielding consistently acceptable ground—water data. The proposed list of monitoring parameters [ Table 8] omits the following metals used in the manufacturing processes: cadmium, chromium, lead, silver and their related compounds. Sikorsky’s characterization of organic compounds may also be incomplete given the range of solvents, paints and primers used. Cresols, alcohols and toluene are major solvents used in the painting processes. They were identified as part of the facility’s Appendix VIII scan, yet were dropped from further monitoring consideration. Table 9 identifies some of the Appendix VIII compounds which may enter the surface impoundments. Table 8 PROPOSED INDICATOR PARAMETERS FOR RCRA PERMIT pH Cyanide Specific conductance Chloroform Total organic carbon Tetrachioroethylene Total organic halides 1,1,1-Trichioroethane Copper Trichioroethylene Nickel Methyl ethyl ketone (MEK) Table 9 APPENDIX VIII COMPOUNDS USED AT SIKORSKY Benzene Methyl ethel ketone (MEK) Cadmium and compounds Siver and compounds Chromium and compounds Silver cyanide Copper cyanide Sodium cyanide Cresols Tetrachioroethane Cyani des Tetrachl oroethene Hydrocyanic acid (Perchioroethylene) Hydrofluoric acid Toluene Hydrogen sulfide Toluene diisocyanate Isobutyl alcohol 1,1,1-Trichloroethane Lead and compounds Phenol ------- 68 Finally, the proposed plan does not specify analytical methods to be used for all parameters and does not contain a QA/QC program. Methods for copper, nickel, cyanide, chloroform, tetrachioroethene, 1,1,1-trichioroethane, methyl ethyl ketone and trichioroethylene analyses were not included in the plan. ------- 69 EVALUATION OF MONITORING DATA FOR INDICATIONS OF WASTE RELEASE Analytical results for the samples collected by Task Force personnel are presented in Appendix G. In general, the data indicates that hazardous waste constituents from the surface impoundments have leaked into the ground water. Although the Task Force samples were collected at low tide in attempts to minimize tidal influence on ground-water quality, the effects of the tides are currently unknown. Volatile Organic Sampling Results Volatile organic results from the Task Force samples indicate leakage from the impoundments. The data shows the presence of volatile organic compounds at concentrations well above the detection limits in the three downgradient monitoring wells [ Table 1O . The upgradient well, B-i, was found to contain fewer volatile organic compounds and these were present at concentrations very near or below the limits of quantification. The Task Force sample results generally agree with previous Sikorsky sampling results. That is, both data sets showed the presence of volatile organics in the downgradient monitoring wells at concentrations well above those found in the upgradient well [ Table 11]. - Volatile organics present in the downgradient monitoring wells were also found in the samples taken of both the liquid from the southern surface impoundment (active unit) and the wastewater treatment plant effluent. This is further indication that these constituents are leaking from the impoundments and entering the ground water. The presence of volatile organics in the surface impoundment and effluent was expected because several of the constituents identified are used in Sikorsky processes, especially tetrachioroethene [ Table 4]. Some of the chlorinated solvents, such as chloroform, although not used in the process plant, are thought to be derived as a result of wastewater chlorina- tion prior to discharge. ------- Table 10 SELECTED VOLATILE ORGANIC CONSTITUENTS PRESENT IN TASK FORCE SAMPLES* South Constituent Well Bi Well B2 (Orig) Well B2 (Dup) Well B2 (Trip) Well B3 Well B4 Impoundment Liquid Effluent Pipe Chloroform ND** 30 30 30 60 4*** 10 15*** Tetrachloroethene ND 220 220 210 420 220 190 260 Trichioroethene ND 60 60 50 110 33 10 18 Methylene Chloride 1,1,1,-Trichloroethane ND 8 11 ND 8*** ND 6*** ND 80 8*** ND 6 4*** ND 60 ND Trans-1,2-Dichloroethene ND ND ND ND 40 48 ND ND Phenol ND ND ND ND ND ND 20 30 Acetone ND ND ND ND ND ND 30 480 2-Butanone ND ND ND ND ND ND ND 530 (Methylethyl ketone) . * Concentrations are expressed in micrograms per liter (pg/L). ** Not detected Estimated value or below detection limit ------- Table 11 SUMMARY WELL WATER SAMPLING RESULTS VOLATILE ORGANICS ( ig/ ) Sample Date 12/83 03/84 06/84 09/84 03/86 05/86 12/83 03/84 06/84 09/84 03/86 05/86 Compound Well 1 Well 2 Chloroform 10 2 4 <2 <2 ND’ 20 25 15 200 17 30 1,1-Dichioroethane NA 2 NA NA NA NA 4 NA NA NA NA ND 1,1,1-Trichloroethane <2 <2 24 58 8.3 8 <2 3 4 35 8.8 ND Trans-1,2-Dichloroethene NA NA NA NA ND NA NA NA NA ND ND Trichioroethene <2 <2 <2 <2 <2 ND 14 12 6 15 72 60. Tetrachloroethene 3 <2 <2 4 <2 ND 60 175 82 135 1000 220 Methylene chloride Methyl ethyl ketone 4 NA NA NA NA NA NA NA NA NA <200 ND ND NA NA NA NA NA NA NA NA <200 8 ND Well 3 Well 4 Chloroform 7 10 17 163 47 60 115 10 46 38 49 4 1,1-Dichloroethane NA NA NA NA NA ND NA NA NA NA NA ND 1,1,1-Trichioroethane 3 5 12 17 20 8 3 3 6 14 9.2 6 Trichioroethene 25 30 76 32 55 110 14 37 150 84 60 33 Tetrachioroethene 53 145 750 312 875 420 50 1075 1050 1500 220 220 Methylene chloride NA NA NA NA NA 80 NA NA NA NA NA ND Methyl ethyl ketone NA NA NA NA <200 ND NA NA NA NA <200 ND Trans-1,2-Dichloroethene NA NA NA NA NA 40 NA NA NA NA NA 48 Not detected 2 Not analyzed Estimated value at or below detection limit ‘ 2-Butanone ------- 72 Inorganic Sampling Results Total Metals The inorganic data from the Task Force samples also indicate that liquid is leaking from the surface impoundments. In general, total metals concentrations in the three downgradient well samples were well above those found in the upgradient well [ Table 12]. In some cases the concentrations were over an order of magnitude greater in the downgradient wells. Further- more, some of the metals were present in the downgradient wells at levels well above current drinking water standards. For instance, chromium (a metal used in Sikorsky’s manufacturing processes) was present at 18 pg/L in the upgradient well (B-i) but was at levels ranging from 750 ig/L to over 1400 pgIL in the downgradient wells. The drinking water standard for chromium is 50 pg/L. Many of the inorganics present in the designated downgradient wells were also present in the samples of both the liquid from the southern (active) surface impoundment and effluent discharge [ Table 12]. For example, chromium was present in concentrations of 3,000 pg/L and 276 pgIL for the impoundment and discharge, respectively. The presence of many of these inorganic constit- uents in the impoundment and discharge was expected since many of the metals are used in Sikorsky’s manufacturing processes. Specific Conductance and lOX Results Specific conductance and lox results from Sikorsky’s last sampling in 1985 triggered assessment. The Task Force results for these parameters are given in Table 13. Reported levels for both specific conductance and TOX are substantially higher in the downgradient wells than in the upgradient well. Because samples were taken during low tide, it is suspected that the higher readings in the downgradient wells reflect leaking from the surface impoundments rather than effects of salt water instrusion on the wells. ------- Table 12 SELECTED INORGANIC CONSTITUENTS PRESENT IN TASK FORCE SAMPLES* Constituent Well 8-1 Well B-2 Well B_2** Well B_2k* Well B-3 Well B-4 Impoundment Pipe Effluent Al 4,140 42,500 18,600 20,300 32,300 39,000 3,100 502 Ba 61 349 218 225 316 380 14 9 Ca 22,900 214,000 225,000 229,000 148,000 90,800 234,000 130,000 Cr 18 1,280 1,380 1,420 750 925 3,000 276 Cu <12 68 33 34 58 92 63 38 Fe 5,320 47,600 19,100 20,000 36,800 46,000 1,200 95 Pb <5 48.4 20.2 22 39.6 30 7.8 2 Mg 10,100 25,100 17,500 17,800 60,000 69,600 7,740 2,850 Mn 541 679 315 325 747 684 38 15 Ni <20 54 31 39 40 45 35 <20 K 4,800 44,500 40,000 40,000 49,800 43,000 40,800 6,330 Na 37,600 259,000 298,000 290,000 189,000 196,000 382,000 99,200 V <21 78 27 34 63 76 85 <21 Zn 24 109 63 54 133 107 104 27 * Concentrations are expressed in micrograms per liter (pg/L) ** Results of duplicate and triplicate samples for this well ------- Table 13 SPECIFIC CONDUCTANCE, lox AND pH VALUES REPORTED FOR TASK FORCE SAMPLES Well B-i Well B-2 Well B_2* Well B_2* Well B-3 Well B-4 Value Value Value Value Value Value 6.08 6.47 6.46 6.47 6.55 6.55 380 1800 1800 1800 2400 1900 * Parameter Units pH Units Conduct- ance umhos/ cm lox pg/L Cl 19 633 478 396 573 4600 199 37 Results of duplicate and triplicate samples for this well Impoundment Effluent Value Value 4.6 8.11 ------- APPENDICES A SAMPLE PREPARATION AND ANALYSIS TECHNIQUES AND METHODS B ISCO METER VERIFICATION DATA C NPDES EFFLUENT LIMITATIONS D WATER LEVEL RECORDING STRIP CHARTS E WATER DATA FOR PREVIOUS SAMPLING DATES F SUMMARY OF WELL SAMPLING RESULTS G TASK FORCE ANALYTICAL RESULTS ------- APPENDIX A SAMPLE PREPARATION AND ANALYSIS TECHNIQUES AND METHODS ------- Table A-i Sample Preparation and Analysis Techniques and Methods Parameter a. a.. Specific Organic Volati les Semi—volatiles Pestlcides/PCB Herbicides Dioxins and Dl benzofurans Gas Gas Gas Gas Gas Gas Gas Chromatography Chromatography Chromatography Chromatography Chromatography Chromatography Chromatography Method Reference ann CLP Method (a) CLP Method CIP Method CLP Method CIP Method Method 8150 (b) Method 8280 (b) Elemental Constituents Mercury Wet digestion Sb. As, Cd, Pb, Acid digestion Se and Ti Other Elements Acid digestion Cold Vapor Atomic Absorption Spectroscopy Furnace Atomic Absorption Spectroscopy Inductively Coupled Plasma Emission Spectroscopy CLP Method CLP Method CLP Method Field Measurements Conductance pH Turbidity Non-specific Organic Parameters POX None TOX Carbon absorption POC None NPOC Acidify and purge General Constituents Ammonia Particulates settled Bromide Particulates settled Chloride Particulates settled Nitrate Particulates settled Nitrite Particulates settled Sulfate Particulates settled Cyanide Manual distillation Phenol Automated distillation an nnflnana= aS n a a= = an nnn na = n= ===== ==.= a) Contract Laboratory Program. IFB methods. b) Test Methods for Evaluating Solid Wastes, SW—846. c) Methods for Chemical Analysis of Water and Wastes, EPA—600/4—79—02O. Preparation Technique asa.na.aaaaaaa Constituents Purge and trap Oirect Injection Methylene chloride extraction Methylene chioride/hexane extraction Diethylether extraction/methylatlon Methylene chloride/hexane extraction a a naaa.a . :._._. aanaaaaaa — Mass Spectroscopy - Mass Spectroscopy or with Flame Ionization Detection - Mass Spectroscopy with Electron Capture Detection with Electron Capture Detection - Mass Spectroscopy None None None Electrometric Wheatstone Bridge Potentiometry Nephelometric Purgable combusted, Microcoulometry Carbon combusted, Microcoulometry Purgable combusted, Non—dispersive Infrared UV Persulfate, Non—dispersive Infrared Ion Selective Potentiometry of supernatant Ion Chromatography of supernatant Ion Chromatography of supernatant Ion Chromatography of supernatant Ion Chromatography of supernatant Ion Chromatography of supernatant Pyridine Pyrazolone Colorimetry Ferricyanide 4-Aminoantipyrine Auto—Calorimetry sCan an = fl S Sn a fl flaa na n nasa =n= a = ass Method 120.1 (c) Method 150.1 (c) No reference EPA 600/4—84—008 Method 9020 (b) No reference Method 415.1 (c) Method 350.3 (C) CLP Method CLP Method CIP Method CLP Method CLP Method CIP Method Method 420.2 (c) = Ca a.. = a=====aaa ------- APPENDIX B ISCO METER VERIFICATION DATA ------- Appendix B ISCO METER VERIFICATION Well B-i Well B-2 Water ISCO Water ISCO Level Date Time Display Level* Date Time Display (ft.) 5/7/86 0925 .520 N 5/6/86 1748 .499 N 5/7/86 1140 .550 18.05 5/7/86 1059 .501 10.59 5/7/86 1312 .597 18.01 5/7/86 1320 .499 10.60 5/7/86 1823 .553 18.04 5/7/86 1640 .508 N 5/8/86 0905 .504 18.14 5/7/86 1830 .482 10.62 5/8/86 1124 .498 18.08 5/8/86 0911 .184 10.90 5/8/86 1440 .526 18.11 5/8/86 0915 .180*** 10.90 5/9/86 0745 .486 18.12 5/8/86 5/8/86 5/8/86 5/8/86 5/9/86 1130 1132 1447 1449 0755 .134 * . 132 .138*** .133 .067 10.93 N 10.87 N 10.95 Well B-3 Well B-4 5/6/86 1807 .499 N 5/7/86 0945 .494 5/7/86 1106 .562 10.87 5/7/86 1112 .501 11.51 5/7/86 1325 .614 10.75 5/7/86 1333 .608 11.44 5/7/86 1838 .601 10.85 5/7/86 1850 .536 11.53 5/8/86 0918 .443 10.98 5/8/86 0925 1000 .54 . 486 11.50 11.51 5/8/86 1135 .455 10.95 5/8/86 1138 .464 11.52 5/8/86 1459 .572 10.86 5/8/86 1456 .556 11.43 5/9/86 0803 .511 11.00 5/9/86 0808 .542 11.45 * Taken with the Interphase Probe; water level recorded from top of cas- ing and measured in feet. ** N = no water level taken at the time of reading ISCO meter ISCO line bumped while verifçjing the water level with the Interphase Probe and the ISCO was reset. ------- APPENDIX C NPDES EFFLUENT LIMITATIONS ------- C-i Appendix C WASTEWATER TREATMENT PLANT NPDES PERMIT EFFLUENT LIMITATIONS* (OUTFALLS 002, 003, 003A) Limitations Maximum Average Daily Monthly Parameter Units Conc. Conc. Chromium - total mg/l 2 1 Chromium - hexavalent mg/l 0.2 0.1 Copper mg/l 2 1 Iron mg/l 5 3 Titanium mg/i 2 1 Zinc mg/i 2 1 Total Suspended Solids mg/l 30 20 Total Toxic Organics mg/l 2.13 NA * For all effluent discharges, pH must not be less than 6.0 nor greater than 10. ------- APPENDIX D WATER LEVEL RECORDING STRIP CHARTS ------- Appendix D Well Level Recording Strip Charts ___________________ - ____________________ ___________________ . — , ________ U— - — ‘00 _ _ ‘00 4 00 0C t . -. -- J ____________ — — -r QU 1— - - -=9Q —__ co . _ _ _ o _ - L•- - - ——— - -I- L’ ____ - - •- -. = - ‘9. —63- - -60 ----— —4 t ô - 40 -- - -— -. - SO. -- - - — so - s ’o—— - - —- - — J—_ -— I — - —— - — — -c— := - = -4- 40:_-_ _io - - - Q - —. - - ‘ - —4-—— -- -- - - ta.—- o - - - -- - — - L - - - - -- -—- - - - — - -- — H 20 — - —_- — - - : - - 3 O --L -; - - - — p - - - 0-1 ------- 100 Co _ _ 100 - = - — — — ______________ 90 - - . - 9Q_L 9Q :9O— - - - ___ - -- ± - 60 OQ.. : - so - ______ _________ _________ ___________________ _ 70 4 _ ” 1 =io= _ _ o * - - --- -- - - -- - - - ., —— too - •- 00- — — 90 r- 90_— - - —::- -= : — : - 1= - -- - 60 — — — - - 4 _:: := - ---f-- SO — S0 —— = — —u - - 54 =Ji :: 1 -- j ZiiTTh - I00. --i - _ p.100 - - - - — —co—=--—---=-——- 4o---—— — * fl ._ -:- —— = 1IE --i — c — - 1= _s — - -- - — -- 5G— -. - -- -• - -:_ — — T1 - - ji - EI - —c.; - ZT E - - - = U- - - —- - - - -- — r__ -- - —— _____ —— -- — - —____ -i — p- - - ; - - I -T._- -- -_ :-- - - ------- 0-3 ________ :00 __ T; Z : ___ E-* - _ == -Y ____ - E — i — -- j4 ___ - — - ____________ ____ TQ0-.- -.-1 - - 00-- - - 10 — T - -; o :. so. j r- - J : -:- -1t - - -__- -. sq - - — - . - — .i: —- : N - - . - __ # :_-4— 70— 70 — 30 - — ) 0 - — —— _30 - -- - 1 — op — — so— - _.... - - - - - -— so— — - —— 60 - ———— 60 Sc— —---50-— 5q_ _ -: —= 0—.———- --—— - 5 - — 1 -- -— 4 -i; 4. - a: 1 ± : -: 4 r - -— -==-i-- - -- - — ?° k - - - - - - - — I— - — — -.- --q_ — - - -Zo — . 2D — — 20 1 — . - :j - — - — L - — iO- _ - — - - --— - - -= - - -- -r - -- I -. . - p_ - - -- : L=- _ - ------- • - -, _—.: - Ø_ H - L- — ____________ _ : _ 1L i ! - - ______ ___________ .. — - — ——:= -- — _ -=- -- - — — — LL: c1gI1W! - -TT iI - : - - I U jj - T -TH- : -- ___ _____ _____ ___ ______ =— - T ___ - - __ -i - - _ - - —== -= - =- ;;—— .: - —— i= -- - - --_- - - — .‘ . .- LY. :S1CS3 9O— - %J I O — IQO — OO - -90- -: L-::-- ec— - — — - — - -$O——— - ,.- - -- - 80 :- - 80 — --I- - - -. • - ——-i t 4 -:. 4 :- t -: i - i ti: - - i- _ —± - -- - —1-!- -- - _-- • _______ • -. 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S I • D- 18 ------- = L:— I______ IE T - 4 — I _J 11515155115 !_!_!l I$i II I $ 1_ I_I__I 11111 SillS lull ui_i_1_’ Ill f_I_I I - — r----- O0 - - 00 - 0 no - r — no — ! - - - 90 1 90 - j IITT — — I I I C I — — I - I —i- I-a_I ‘° = LÔIO i - F; — -1 L 4 ) T ‘ - Jr ’J -r --’ huLl 1 1111_I • • I I iillllhS lulls iSiiIlSSSIh 1 Ills 5 5 I I 1 5 5 $ 5 I 5 5 0 5 5 S S 5 5 5 5 5 5 5 I _ I _ i _ I —S — I 5 5 5 II S 5 S I 5 5 S 5 5 5 S 5 5 5 I 5 5 5 I S I I S S S I I I — — — _ 0 T _ — —— — - - ± _ -y ---————— - ____ ------- uuussusus,’ s us ussIssessusSI _!_s ,! 11s 1 1 1 1 5 1h0 lulls.. ______ - - 00 _}_-____ . - __ __._--f -- -- -- - - I slIlsu I • • • !!‘ I I I I S 5 11 I I I I I I u 1115 1 • • 0-20 I a I uiii ’ I I I I I I I I I I a,’’iS’II’u’s’ISI,Ssl — Ills lull I15II1 • l III. ., ------- - I - —- -- .==-i — == - — .::: =_=:: hv : _ - --== - --——— -- —=---- T: - ,n = — 1 i tt - $k j _ —= _ 2 C ____== E __ L o — - - --- _ - _____________ ____________________ — - — —--—-O 0 ____________________ II I S I I SI, U Sill I I I IlIllIlil I 51111 SIll IIIIIISI ISI S I S_!.i_!.I_!_I_S I 11111 — — - - 3C— -‘ -: - — — - - T1 -- ________ — r — —-—-—-- u c — - - ___ - •. lIII II 111.1 lilulIlsi IsuuIllul uululuul 5.ISSSIS uuuuiususi sal --: - - - - :- - oo — : -- -= 90 10 __— 4i J - —=- ; f — - - -- - - - -= t: = :ii =- ,3 __ — — — _ — —i — _ - o z . o --.—. r- o -= — - —- - --— — -j - • — —= = =- ±! -I== ------- 0-22 — ==°J — -° _ ___ ________ _____________I =J- LI + ___ IiiIfiI i pups s p ships shill i I_a IllIllill 11111111 ‘‘sisi sips isis is isisis iii 00 - E .’ 00 eo - I - I 4 -s - ii: ____— - _____________________ 70 _______________________________________________________________ ( 10 i t’ = -1I -1--=3 i;---:---- ____ J__j $ I I $ I U P I $ S I S U $ I P 1 S U S $ • • ‘ - - - 5- T= = Th— - _____ - = S ± - — ________ — — - 1— -- 111—----- —f - ii, 5 ii I ii I $ I I I I I I I U I • _ 1 _ l _ i 5555 isis i isis s sushi S 51551555 5 i _ Pi .!! ___ - - - — — “ - — — i..,upslSus u.II IS PUSS UISUSIP ISS ------- ±E _ —: ; : i — 11111111 SSS ISSI ISIS, 111111 I I 11111111111111 1101111 111111 S SI _____________________________________________________________________________ — 00 — --- -. 0— — 100 w 00 - —---4 c i ___ _____ - J __________ S — 50 —i S0 I -. -. - — - •= • — SC ? -=--- - - -- — ____ 3c’ - ____________ - 30 - - - - ______ C ‘ — I - C ______ — . i • • $ S S • • S S S I S S S S S S S S I I I I S SItL_L I I L _ I _ I I il _ Il _ I I I I I 1 1 1 5 I S — --—ii - -- - 7r • S3- o : ± =: - — :: : - -- __ z __ :0= ___ ==- -+- Q —= V - SISIIIIIIIISIISIIIIIIIIIIIIIIIIIIIIIIIIIJIIIIISIII1 1IIII 1 1III 1 I — - I I --____________ —4 - - i - f l - — --—— I U S U S U I I I I S I S S I I I U I I I S I I S I U I I S I I S U • _ = __ ‘ I I f I S I S I..I S S S I I I S S I I S ___________I ______ ------- 0-24 ___ I s a lu a a a a u iliSs ii a sousa a siasass ass •iti a ‘ ii ii a a a a liii . ------- - - _____ ____________________ . -k- 4- 4TT t± ___ ± IT L-, j t : ;4— ______ ______ - — - W - I ___ _______________ I t ; _________ -- - T T I L t4- - 1 TL T _ - 1 — - 00 - - - ¶O0 -— — 0O — ‘00 i0.-- - -J - - -_ - - --- -- 4 - —— - - — — - --;t — - - - 50 — = $6 —i_ .a t — ° o- j — - 2— 1— - i —so . - $o =L -A0 i ±— - —-:: -t L tz ç — - -- - _ - - -- - —7 0 - - — — - —- - 70 — — - - -I- —60 . 6O — 6O — — = ‘0 — T — — — — 20 1 I!__J 1 —T - -uu ff — -i - I - EE T = - -- — -e : - ‘ T E’ i - c I liii ____________________ . ,. q, — 4 : -1 - - — - - ‘00 -- U0 — j ‘ 00 100 _ - - _ ‘0 - 4 -= — - ‘ -J 1:- t t- jEE - — : __ =Z €E — ___ ____________ - 63 = _ — oo . I I 60 . -—j 6 —— - : : 1 : T T: - ___ - 3— - . 30— 3 — ‘0- ------- _______ L ______ - ___________ - L.11I Si l lS 1$ _ U _ I 11111 5 U SI S U .S U S US IS S S I IS! U I IS I 551515 I IL ___________ ___ - == __ D-26 ass. a asia a ass asusa s i 5J is •ilS •SuulSS, alias . us ia sass.... IIISI si ------- __________ - . — 70-:—--— —7 — ___ _i _______ — - - - - -. —— _____ ------- 0-2 - — X. . - _______ _______ _______ _______________ - - — - - — - - - ‘ — C — -= _ = iO=—-=-- _ ——. I0 -— — - — — - 4 ±- -- - - ! - o o : - = - -_o - - - - o____________ — =-7 0 _ ——.- 70 - 20 _ L — —70 — 54 - =- - ; ________________ — 50 -2 -- -: SC - e——- 5 t :i & _ — __ - ;o0 - : i - -j +_____ 5C = — 1—- 40 - —- - - 1 -9 _.__i r L __________ - - - — - _J. - -- : ——----- H:: - — : 1 - 4 H c- ‘0• - 0-28 So-- 40 T __________ __________ _______ - - - - ioç - -- -. —= ¶00 2 - =2- - — - - -—- -;;-_- - ===- - S0 - - _______ ‘‘UI.. — - - -- - - - -- ? —- - - - - = ------- ____ L --t: - -- - ii L T LT : i - _____ ________ 4 - - - - - - i - = _50____r — — — I _ o —- _______ - L = F=--: — ____________________ 1,. 4 . ____________________ -‘ .3 - --. - : -.:- : - O &-— — = =— o = _ = er I J — = _ jtTi ________ — 4— -=1 _ L - - -- 1 I — . z± T3o _ E _ i _ .L-. - o = - t -J: - __ -j _ __ i -I 2 E - f ! 1L3 -=- - -t-- - - L T - o O-- _______ ! r ------- - - - — F — - -- - _______________ 4 :: ; - I L— 0 -f - — -- : - T 0 - - — = -- F= - - 00 - - - --= - - = — — — —-t—--— - -r— - :t — __________ I ________ ii . : - -—r - 0-30 - 0 I00 - ________ - — -- - 90 - - - - F -- -: — 1- ; _ • — - - . - -‘ °: - -- -. . - —90 -. - ____ ____ ii _ •o : 4 T Ei - ‘0— -- ________ — ==-r-t . - - k-= 1 - - : -- - 4 -- ------- APPENDIX E WATER DATA FOR PREVIOUS SAMPLING DATES ------- Tide Data for January 30,1983 1 —.‘1 D ’ o 6 C I -I 0. (D a, (-p 0 - .5 -D D -s - (D CD 1. r limo in Hours I—- 10 12 1 $6 $8 20 22 24 T I . ------- Tide Data for October 25,1983 I I I 2 4 6 8 $0 12 $4 Time ii Hours I I 16 IS 20 22 24 o T N) .,- I! C 8- 6 4 2- 0- —2- 0 ------- Tide Data for April 26,1984 L *‘ . — O3 .rd -2 ,- - 0 2 4 I — — r 6 8 I I I 10 12 14 Time in Hours Sa.ipMng flm 8 6 4- 2- C I - T i 1 16 18 20 22 24 T ------- Tide Data for July 19,1984 L.gen o gI o T 8 6 C 2 Time in Hours $2 $4 22 ------- Legend A rt o ________________ - _______ o n kw Tide Data for January 24,1985 C I 2 4 6 8 $0 $2 Time in Hours 14 *6 18 20 22 24 T U, ------- C I Legend L 1 ld orI Q n o Tide Data for July 11,1985 6- 4 2 —2 I I I I — I I I I I 2 4 6 a so $2 $4 16 18 20 22 24 0 Time in Hours ------- Tide Data for March 21,1986 10 B Sainplin 9 ‘I If C 6 4 2 0 —2 Time in Hours Legend 1] R 0 rn —4 ------- Tide Data for May 6,1986 Legend o T 8 11m 6 Q) C 4 2 0 - I-- I I I I 4 6 8 10 12 $4 16 I a 20 22 4 Time in Hours ------- APPENDIX F SUMMARY OF WELL SAMPLING RESULTS ------- Appendix F SUMMARY OF WELL SAMPLING RESULTS (p/L) Sample Date 12/83 03/84 06/84 09/84 03/86 05/86 12/83 03/84 06/84 09/84 03/86 05/86 05/861 Compound Well 1 Well 2 Chloroform 10 <2 4 <2 <2 ND 2 20 25 15 200 17 30 1,1-Dichioroethane NA 3 NA NA NA NA 44 NA NA NA NA ND 1,1,1-Trichloroethane <2 <2 24 58 8.3 8 <2 3 4 35 8.8 P40 Trans-1,2-Dichloroethene NA NA NA NA ND NA NA NA NA ND ND Trichioroethene <2 <2 <2 <2 <2 ND 14 12 6 15 72 60. Tetrachloroethene 3 <2 <2 4 <2 ND 60 175 82 135 1000 220 Methylene chloride NA NA NA NA NA ND NA NA NA NA 8 Methylethyl ketone 5 NA NA NA NA (200 ND NA NA NA NA <200 ND Well 3 Well 4 Chloroform 7 10 17 163 47 60 115 10 46 38 49 4 PBL 6 1,1-Dich loroethane NA NA NA NA NA ND NA NA NA NA NA ND ND 1,1,1 Trichloroethane 3 5 12 17 20 8 3 3 6 14 9.2 6. 6. Trichloroethene 25 30 76 32 55 110 14 37 150 84 60 33. 13. Tetrachloroethene 53 145 750 312 875 420 50 1075 1050 1500 220 220 130 Methylene chloride NA NA NA NA NA 80 NA NA NA NA NA ND ND Methyl ethyl ketone NA NA NA NA <200 ND NA NA NA NA (200 ND ND Trans-1,2-Dichloroethene NA NA NA NA NA 40 NA PIA NA NA NA 48 10 1 Duplicate analysis 2 Not detected Not analyzed Estimated valve at or below detection limit 2-Butanone 6 Probable T ------- F— 2 WELL 9 MONITORING WELL 11 SAMPLE QIR. 1 2 3 WATER LEVEL 3.56 1.11 4.64 3.75 47.50 21.30 25.74 13.99 50.20 0.16 0.26 0.21 7.13 1.38 0.29 0.06 MONITORING WELL$2 4 5 6 7 8 1 2 2.34 2.96 3.21 3.17 2.78 0.20 3.20 2.99 0.10 0.06 0.06 0.12 0.082 0.005 0.01 0.01 0.01 0.01 0.05 0.10 0.05 0.05 0.01 0.01 0.01 0.03 0.02 0.05 0.01 0.02 7.30 8.70 10.90 0.05 0.05 0.10 0.02 0.05 0.001 0.001 0.001 0.001 1.00 14.80 9.60 13.80 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 94.60 48.50 39.60 209.62 9.8 177.7 66.00 0.21 0.27 0.39 0.12 0.29 0.05 0.05 0.05 0.25 0.44 0.68 0.31 0.33 0.09 0.16 0.25 0.10 0.06 0.06 0.16 0.058 0.005 0.59 1.00 268.80 463.20 294.10 241.01 218 128 114.70 246.00 414.30 429.50 388.10 202.00 660 279 818.40 0.01 0.01 0.01 0.01 0.05 0.25 0.05 0.05 0.01 0.01 0.01 0.01 0.01 0.06 0.05 0.05 0.15 0.05 0.01 0.11 31.90 33.50 29.80 27.75 0.05 0.10 0.02 0.05 0.001 0.001 0.001 0.001 36.00 2.40 26.40 4.00 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 3 4 5 6 7 8 1.58 2.78 3.16 2.91 7.59 6.90 6.90 6.71 pH 6,37 6.60 6.34 5.90 6.45 6.32 6.67 6.74 7.19 7.54 7.96 7.42 t: ! : 8 t: :t t: :3 :1 3:lg 1: 8 1: ? 6.37 6.58 6.34 5.94 6.39 5.31 6.68 6.75 7.20 7.54 7.96 7.45 7.62 6.94 6.92 6.72 MEAN pH 6.37 6.60 6.34 5.93 6.18 6.06 6.68 6.74 7.19 7.54 7.96 7.44 7.60 6.94 6.92 6.72 SPEC. COND 512 510 505 510 383 385 380 384 362 360 360 360 310 315 315 315 365 365 370 370 400 400 400 425 410 415 415 415 348 348 350 350 2040 2050 2050 2045 2145 2152 2147 2138 1980 1985 1988 1975 1790 1780 1785 1785 2250 2250 2300 2200 1350 1350 1350 1375 955 960 960 965 1950 1950 1950 1950 MEAN SPEC. CON. 509 383 361 314 368 406 414 349 2046 2146 1982 1785 2250 1356 960 1950 TOC 11.55 11.58 11.50 11.55 1.65 1.68 1.63 1.66 23.1 21.9 22.2 22.0 1.5 1.7 1.6 1.5 4.7 4.7 4.7 4.8 3,9 3.8 3.4 3.5 26.3 26.5 27.0 V.2 23.2 24.6 25.8 24.1 18.15 18.18 18.15 18.14 15.65 15.75 15.60 15.60 14.9 15.2 15.2 14.9 9.9 10.0 10.1 9.8 9.0 8.9 8.8 9.1 9.8 9.0 8.8 9.2 68.9 69.5 70.2 72.4 22.6 23.7 21.3 22.1 MEAN TOC 11.55 1.66 22.30 1.58 4.73 3.65 26.8 24.4 18.16 15.65 15.05 9.95 8.95 9.20 70.3 22.4 TOX 0.015 0.015 0.013 0.016 0.010 0.010 0.010 0.010 26 27 26 28 60 56 54 61 49.1 52.6 54.0 58.6 66.8 57.0 68.8 58.0 15.0 15.0 15,0 15.0 15.0 15.0 15.0 15.0 0.100 0.104 0.095 0.101 0.200 0.220 0,200 0.200 105 102 109 107 360 391 386 377 519 514 535 549 2590 2560 2560 2550 1100 1130 1140 1150 369 371 379 381 MEAN lOX 0.015 0.010 27 58 53.6 62.7 15.0 15.0 0.100 0.205 106 379 529 2565 1130 375 5.16 23.40 5.56 0.84 0.80 1.08 62.04 0.05 0.73 0.14 0.47 0.06 0.00 Cl Fe Mn PHENOL Na 504 Cu Ni I. liv •1 h 27V 29V MEK Ba Cd Cr F Pb Hg N03 Ag Se 40.00 37.60 24.71 30.22 32.00 39.50 36.47 39.00 5.00 76.40 303.00 49.30 68.90 41.50 46.87 0.02 0.46 0.03 0.06 0.02 0.02 0.05 0.05 0.02 0.08 0.07 0.05 0.03 0.02 0.05 0.05 0.02 0.40 0.10 0.10 0.005 0.005 0,10 0,10 10 2 4 2 10 10 2.00 2.00 3 2 2 4 10 10 2.00 2.00 2 2 24 58 10 10 8.30 3.80 2 2 2 2 10 13 2.00 2.00 200.00 200.00 0.02 0.15 0.03 0.05 0.02 0.10 0.13 0.05 0.02 0.10 0.10 0.10 20 25 15 200 60 175 82 135 2 3 4 35 14 12 6 15 0.02 0.02 0.05 0.02 0.02 0.005 550 14 10 76 10 10 10 10 0.05 0.05 0.05 0.05 0.10 0.10 17 36 1000 276 8.8 4.4 72 49 200 200 0.01 0.01 0.05 0.60 ------- WELL I MONITORING WELL $3 SAMPLE OTR. 1 2 3 4 5 6 7 8 MONITORING WELL $4 F- 3 1 2 3 4 5 6 7 8 WATER LEVEL 2.77 0.21 3.12 2.92 1.65 2.44 2.54 2.68 3.27 0.97 3.58 2.90 2.07 2.28 2.34 2.43 PHENOL 0.10 0.06 0.06 0.15 0.106 0.005 0.01 0.01 0.01 0.01 0.05 0.38 0.05 0.05 0.01 0.01 0.01 0.06 0.09 0.05 0.04 0.08 30.90 50.50 31.00 25.25 0.05 0.10 0.02 0.05 0.001 0.001 0.001 0.001 4.04 5.60 8.00 13.75 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 50.00 31.00 60.72 50.42 1.03 1214.3 235.49 0.07 0.35 0.26 0.13 0.11 0.68 0.05 0.05 0.31 0.81 0.70 0.32 0.10 0.26 0.08 0.20 0.10 0.06 0.06 0.17 0.075 0.005 0.06 0.50 378.10 352.90 241.20 176.26 132 346 91.20 152.50 232.10 211.90 330.50 179.30 763 154 209.34 0.02 0.05 0.06 0.06 0.03 0.02 0.05 0.05 0.02 0.08 0.13 0.05 0,03 0.02 0.05 0.05 0.02 0.10 0.10 0.10 0.074 0.005 0.10 0.10 115 10 46 38 160 15 49 15 50 1075 1050 1500 220 73 220 126 3 3 6 14 10 10 9.2 7.8 14 37 150 84 55 10 60 16.00 200 200 0.01 0.01 0.01 0.01 0.05 0.20 0.05 0.05 0.01 0.01 0.01 0.01 0.01 0.05 0.05 0.40 0.13 0.05 6.00 0.02 40.50 36.80 46.40 33.00 0,05 0.10 0.02 0.05 0.001 0.001 0.001 0.001 160.00 0.80 7.80 28.40 0.01 0.01 0.01 0.01 0.01 0,01 0.01 0.01 7.46 7.66 7.48 1.66 7.47 7.65 7,48 1.66 MEAN pH 7.47 7.66 SPEC. COND 1889 1680 1880 1670 1885 1685 1875 1685 MEAN SPEC. CON. 1882 1680 bC 11.75 5.05 11.70 5.08 11.77 5.03 11.77 5.04 MEAN TOC 11.75 5.05 TOX 0.092 0.180 0.090 0.160 0.090 0.200 0.095 0.190 MEAN lOX 0.092 0.183 8.05 7.30 9.03 1.31 8.00 7.29 8.00 7.28 8.02 7.30 1359 1350 1375 1370 1375 1365 1365 1365 1369 1363 6.60 11.60 7.00 12.00 7.10 11.50 7.10 11.70 6.95 11.70 800 512 795 515 805 496 805 521 801 511 7.00 7.00 7.02 7.04 7.02 1120 1135 1140 1140 1134 48.6 49.9 51.2 51.5 50.3 913 928 929 941 928 6.96 6.97 6,97 6.97 6,97 1500 1520 1520 1520 1515 27.8 25.4 25.6 26.9 26.4 435 439 441 450 441 7.38 7.24 7.42 7.25 7.45 7.29 7.39 7.30 7.41 7.27 1420 1625 1450 1650 1400 1690 1400 1690 1418 1664 6.60 8.00 6.60 7.70 6.60 7.80 6,50 7.90 6.58 7.85 936 1510 884 1590 951 1530 904 1540 919 1543 1.03 139.4 0.17 0.07 0.21 0.20 7.03 7.05 7.03 7.02 7.05 7.05 7.04 7.06 7.04 7.05 2510 2040 2500 2040 2510 2042 2510 2039 2508 2040 13.20 1.95 13.21 1.95 13.18 1.98 13.22 1.91 13.20 1.95 0.212 1.080 0.220 1.080 0.210 1,100 0.209 1.070 0.213 1.083 7.81 7.79 7.93 7.80 7.81 1920 1925 1925 1920 1923 9.90 9.80 9.80 9.80 9.83 1200 1210 1210 1195 1204 7.07 7.00 6.99 7.06 6.95 7.00 6.98 6.98 7.00 7.01 1325 1945 1310 1945 1315 1930 1320 1940 1318 1940 6.50 11.0 7.00 11.0 7.10 11.0 6.80 11.1 6.85 11.03 1500 1060 1415 1120 1475 1010 1450 1080 1460 1068 7.02 7.03 7.08 7.09 7,06 2900 3000 3000 3000 2975 3.1 3.6 7 V. 3.2 3.33 508 777 852 838 744 6.82 6.85 6.85 6.85 6.84 870 875 875 875 874 48.4 49.2 49.5 50,0 49.3 315 325 J 322 6.86 6.87 6.87 6.88 6.87 1370 1380 1390 1380 1378 42.1 39.2 42.2 42.0 41.4 150 150 151 159 153 Cl Fe Mn 73.30 57.80 56.10 73,33 0.25 0.41 0.23 0.29 0.21 0,20 0.35 0.21 192.42 0.05 0.05 0.25 0.31 0.05 1.10 Na 262.40 544.10 197.10 165.47 172 176 161.80 170 504 535.80 302.30 382,40 191.10 307 452 369.69 0.02 0,05 0.02 0.05 0.02 0.02 0.05 0.05 0.02 0.08 0.10 0.21 0.03 0.02 0.05 0.05 0.02 0.35 0.10 0.10 0.03 0.005 0.10 0.10 7 10 17 163 500 4100 47 60 53 145 750 312 10 370 975 277 3 5 12 17 10 10 20 5 25 30 76 32 10 38 55 93 200 200 Cu Ni Cn liv 24V 27V 29V MEK As Ba Cd Cr F Pb Hg N03 Ag Se 0.01 0,01 0.05 0.06 ------- —., I 1 i . 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[ T:.1.4: .Jit ;,j’’j f T1 Ii -T -. : 1 ----- ----- - - — . —- -- ---— — -- - -- i - — — _____ - —1 - TII 1 -- -- :1 1 4 k1 1i11 N U j: c. ”. .4PT a ““ LL — I LE r 2 [ L’ b—4 ------- :E . I : ‘..ii) F’ :E . [ : 1 L [ L . :: .‘E 1’. I j •:t i 1• 1 k1 ’ ’t iR •i: c1.J.4f .T J r— 7. C WELL — 1 - WELL •—2 W L1L h - .4 [ —.—I- -r I-a -j •/ i _____ 1- q ------- APPENDIX G TASK FORCE ANALYTICAL RESULTS ------- G- 1 pr c PRC E iglne.rlng Planning Research CQrporation EVALUATION OF QUALITY CONTROL ATTENDANT TO THE ANALYSIS OF SAMPLES FROM THE SIKORSKY AIRCRAFT FACILITY, STRATFORD, CONNECTICUT FINAL MEMORANDUM Prepared for U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Waste Programs Enforcement Washington, D.C. 20460 Work Assignment No. : 548 EPA Region : Headquarters Site No. : N/A Date Prepared : September 23, 1986 Contract No. : 68-01-7037 PRC No. : 15-5480-11 Prepared By : PRC Environmental Management, Inc. (Kenneth Partymiller) Telephone No. : (713) 292-7568 EPA Primary Contacts: Anthony Montrone & Barbara Elkus Telephone No. : (202) 382-7912 • . — r’ — CON FID EN I AL .• p 1 T E? t :J. .lF j1hT 1 ------- G-2 p(’C PRC Engineering Planning Research Corporation MEMORANDUM DATE: September 23, 1986 SUBJECT: Evaluation of Quality Control Attendant to the Analysis of Samples from Sikorsky Aircraft, Stratford, Connecticut FROM Ken Partymiller, Chemist PRC Engineering 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)’ Barbara Hughes, NEIC Eugene Lubinenky, Region I 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 Sikorsky Aircraft facility, Stratford, Connecticut 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 laboratory was also generated. Step two was an independent examination of the quality control package and the * HWGWTF Data Evaluation Committee Member ------- G- 3 MEMO September 23, 1986 Page 2 quality control package and the performance evaluation sample results by members of the Data Evaluation Committee. This was followed by a meeting (teleconference) the Data Evaluation Committee to discuss the foregoing data and data e esentations. These discussions were to come to a consensus, if possible, çQncerning the appropriate use of the data within the context of the HWGWTF bjectives. The discussions were also to detect and discuss specific or general i nadequacies 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 rçlative to sampling and analysis should be referred to Rich Steimle of the Hazardous Waste Ground-Water Task Force. I. Site Overview The Sikorsky Aircraft facility, located in Stratford, Connecticut, produces Ircraft, including helicopters, and aircraft parts. Wastes generated at the facility a e from electroplating and metal finishing operations. Process wastes include ç4’fluent from anodizing, conversion coating, titanium processes, and other processes. Waste streams containing cyanides are kept separate from the other waste streams. Both waste streams are treated and create sludges. The sludges are sent to unlined surface impoundments for drying. The facility has been in operation since 1955. The semi-annual ground-water monitoring results show statistical differences from background for specific conductance and TOX parameters. The wells also contain metals and organics. The ground water under the site is under the influence of tidal effects. The geology of the site consists of sands and clays. Eleven field samples including one field blank, one trip blank, and one equipment blank were collected at this facility. Two of the samples were surface water samples, one taken from an impoundment (sample MQ0714) and one from an effluent pipe (sample MQ0723). Three of the six ground-water samples (MQO719, 720, and 721) were triplicate samples. All blanks were used for spikes and/or duplicates. H. Evaluation of Quality Control Data and Analytical Data 1.0 Metals 1.1 Performance Evaluation Standards Performance evaluation standards were not evaluated in conjunction with the samples collected from this facility. ------- G- 4 MEMO September 23, 1986 Page 3 1.2 Metals OC Evaluation Seventeen of the twenty-three total metal average spike recoveries were within the data qu 1ity objectives (DQO) for this Program. No spiked sample recoveries were reportcd for tin. Total cadmium and zinc average recoveries were above DQO with recoveries of 180 and 112 percent, respectively. Total antimony, arsenic, lead, and thallium average recoveries were below DQO with recoveries of 72, 74, 85, and 74 percent, respectively. All reported laboratory control standard (LCS) recoveries were within Program DQOs. The average relative percent difference (RPD) for all metal parameters were within the DQO except for chromium. Requisçd analyses were performed on all metals samples submitted to the laboratory. Analyses of samples for dissolved metals were neither requested nor performed. rNO samples were analyzed for tin. No con amination was reported in laboratory blanks. Equipment, trip, and field blanks show slight contamination involving a variety of metals including calcium, chromium, irçn, sodium, and/or zinc (see samples MQ0713, 715, and 724, Appendix 1, Reference 2b The reported detection limits (DL5) are the contract required detection limits (CR.DLs) or lower for all metal analytes. 1.3 Furnace Metals The correlation coefficient for the method of standard addition (MSA) was less than 0.995 for antimony in sample MQ0720, cadmium in sample MQO72I, and lead in sample MQO7I4. The results for cadmium should be considered unreliable due to the low correlation coefficient while the results for antimony and lead should be considered qualitative in their respective samples. As mentioned in Section 1.2, average spike recoveries for some furnace metals were outside DQO. Several individual spike recoveries of furnace metals were also outside DQO. These included the antimony spike in sample MQ0723 (43 percent recovery), the arsenic spike in sample MQO7I6 (58 percent recovery), the cadmium spike in sample MQO716 (220 percent recovery), and the thallium spike in sample MQ0723 (68 percent recovery). Metals with a low spike recovery would be expected to have a low bias in their data while metals with a high spike recovery would have a high bias in their data. Thus, the antimony, arsenic, and thallium data should be considered to be biased low and, due to spikes being below DQO, semi-quantitative. The cadmium spike recovery results are biased high and, due to the spike being above DQO, semi-quantitative with the exception of the cadmium sample mentioned in the previous paragraph which was considered unreliable. The lead and selenium spike results were within DQOs. ------- G- 5 MEMO September 23, 1986 Page 4 Samples MQO7I9,- 2O, and 721 were triplicate samples. The relative standard deviation (RSD) was 27.9 percent for cadmium and 52.3 percent for lead for the triplicate samples. This- is above the DQO for both and, therefore, the cadmium data should be considered semi-quantitative with the previously mentioned exception, and the lead data qua9tative. The selenium results should be considered quantitative. 1.4 ICP Metals As mentioned in t-he previous Section, triplicate field samples were analyzed for this facility. The 1uminum (49.1 percent RSD), calcium (74.2), iron (56.0), manganese (47.0), and znc (39.2) percent RSDs were significantly out of DQO making data for these èkements qualitative. The magnesium (21.4 percent RSD) data was less significantly ó it of DQO and should be considered semi-quantitative. Chromium and manganese percent recoveries on the low level linear range checks were unacceptable. As a result, chromium concentrations of less than 230 ug/L may be biased high by 10 to 50 percent. Samples MQ0722 and 724 are affected. Sample MQ0424 was the equipment blank and had chromium present at 13 ug/L. Manganese data &f less than 300 ug/L should be considered to be semi- quantitative and biased thw by approximately 30 percent. Affected samples are MQ0713, 714, 715, 723, and 724. Serial dilution results were acceptable for all elements although one of the serial dilutions was do e on a trip blank which produced no quantifiable results. No samples had high dissolved solids concentrations so physical interferences of the ICP analysis is unlikely. No sulfate interference of the barium results was indicated. Barium, beryllium, chromium, cobalt, copper, nickel, potassium, silver, sodium, and vanadium data, with exceptions mentioned above, should be considered quantitative. Chromium data for samples MQ0722 and 724, manganese data for samples MQ0713, 714, 715, 723, and 724, and all magnesium results should be considered semi-quantitative. Aluminum, calcium, iron, manganese, and zinc results should be considered qualitative. 1.5 Mercury Triplicate sample results for mercury were all below the DL. Mercury contamination was not a problem in the field or laboratory blanks. Mercury data for this facility should be considered quantitative although no mercury was found in field samples from the facility. ------- G- 6 MEMO September 23, 1986 Page 5 2.0 Inorganic and Indicator Anal tes 2.1 Performance Evaluation Standard Inorganic and indicator anal9te performance evaluation standards were not evaluated in conjunction with the samples collected from this facility. 2.2 Inorganic and Indicator Parameter OC Evaluation The average recoveries for the inorganic and indicator analytes were all within the accuracy DQOs (accuracy DQOs have not been established for bromide and nitrite nitrogen but their recoveries were an acceptable 96 and 95 percent, respectively). This indicates gene?ally excellent recoveries for all the analytes. All individual sample recoveries for all analytes were within DQO. All LCS recoveries reported for inorganic and indicator analytes were within Program DQOs. Average RPDs for all analytes were within Program DQOs. Precision DQOs have not been established for bromIde and nitrite nitrogen. Analyses for all inorganic and indicator analytes were performed on all samples except for one POC analysis. ThetPOC bottle for sample MQ0713 was empty when received by the laboratory. No laboratory blank contamiWation was reported for any inorganic or indicator analyte except for POC. The POC concentration in all blanks was above CRDL. Contamination in equipment, field, and trip blanks is reported in Appendix I, Table Al-l of Reference 2. The major blank contamination was TOC in samples MQ0713, 715, and 724 where concentrations of 1300, 1100 and 1200 ug/L were reported. High concentrations of organics were not found in any of the field samples so this result is probably not due to contamination from other field samples. All reported inorganic and indicator analyte detection limits are CRDL. 2.3 Inorganic and Indicator Analvte Data The relative standard deviation (RSD) on the field triplicate samples (MQ0719, 720, and 721) for cyanide was 39.8 percent versus a 14.1 percent DQO. Due to this poor performance the cyanide data should be considered qualitative. The RSD for the nitrate nitrogen triplicate samples was 20.4 percent versus the DQO of 14.1 percent. The holding times for the nitrate nitrogen analyses were approximately 15 days from receipt of samples which is significantly longer than the recommended 48 hours for unpreserved samples. There are no analysis dates reported in the raw data for the nitrate nitrogen chromatograms. This information is important to correlate the analysis dates of the samples with the QC information. The nitrate nitrogen data should be considered semi-quantitative primarily due to the poor triplicate precision. ------- G- 7 MEMO September 23, 1986 Page 6 The ammonia nitrogen data should be considered quantitative. Performance on the triplicate samples was within the RSD DQO of 7.07 percent (2.46 percent). The RSD on the field triplicate samplcs.for total phenols was 58.4 percent versus a 14.1 percent DQO. Due to this poor performance the total phenols data should be considered quail tative. The high level chloride initial calibration verification recovery was outside DQO. The percent RSD for chloride on the triplicate samples was 54.4 percent which was significantly poorer than the DQO of 7.07 percent. The chloride data should be considered qualitative due to the poor precision on the triplicate samples. The percent RSD for sulfate on the field triplicate sample was 54.4 percent which was significantly poorer than the DQOrOf 14.1 percent. The sulfate data should be considered qualitative due to poor triplicate performance. The percent RSD for TOC on the triplicate sample was 15.2 percent which was poorer than the DQO of 7.07 percent. All three field blanks (MQ0713, 715, and 724) had TOC present at above the CRDL. The concentrations of TOC in the three blanks was 1300, 1100, and 1200 ug/L respectively while the CRDL is 1000 ug/L. TOC results below about 1200 ug/L are expected to be biased high. No instrument calibration data for TOC was found with the raw data. The contract requires daily instrument calibrations with standards that encompass the expected concentration range of the samples. The TOC data should be considered semi-quantitative due to poor triplicate performance. Initial and continuing calibration standard runs were not reported with the POC data. It is recommended that such calibration verifications be analyzed at the beginning, end, and at a frequency of every 10 samples within the run. Without this information the accuracy of the calibration could not be confirmed. Spike standards were analyzed within the run but they were not identified and percent recoveries were not reported. No calibration curve was reported with the raw POC data and thus there is no means to determine the accuracy of the results. Because of the lack of instrument calibration data, the POC data should be considered to be unreliable. No final continuing calibration blank (CCB) or verification (CCV) was analyzed for the TOX data. It is recommended that CCBs and CCVs be analyzed at the beginning, end, and at a frequency of every 10 samples within the run. Samples MQ0723 and 724, which were analyzed at the end of the run, were most effected. The percent RSD for TOX on the field triplicate sample was 24 percent which was poorer than the DQO of 14.1 percent. The lOX data should be considered qualitative due to poor triplicate performance. ------- G-8 MEMO September 23, 1986 Page 7 No calibration curve was reported with the POX data for either of the two days’ analyses and no calibration verification was reported for the second day’s analysis as is recommended. The percent RSD for the field triplicate sample was 38.6 percent which was poorer than the DQO of 14.1 percent. The POX data should be considered qualitative. All bromide CCV recoveries (three) were 112 percent. No accuracy DQO is specified but a range of approximately 90 to 110 percent has been recommended by the EPA/EMSL Las Vegas data reviewers. The bromide data should be considered quantitative. The holding times for the nitrite nitrogen samples were approximately 15 days from sample receipt. The recommended holding time for unpreserved samples is 48 hours. The nitrite nitrogen data should be considered semi-quantitative. 3.0 Organics and Pesticides 3.1 Performance Evaluation Standard Organic performance evaluation standards were not evaluated in conjunction with the samples collected from this facility. 3.2 Oraanic OC Evaluation All analytes were within established Program DQOs for accuracy for recoveries of matrix spike compounds (DQOs have not yet been established for 2,4-D and 2,4,5- T). All analytes were also within DQO for accuracy for average recoveries of surrogates (DQOs have not yet been established for pyrene and 2,4-DB). One individual surrogate spike recovery was outside accuracy DQO limits for 2- fluorobiphenyl in sample Q0717. All other individual surrogate recoveries were within DQO for all other samples and laboratory blanks. All analytes were within precision DQOs for average RPDs for matrix spike/matrix spike duplicate analyses (DQOs have not yet been established for 2,4-D and 2,4,5-T) and for duplicate surrogates spike recoveries (a DQO has not yet been established for 2,4,5-TP). Two volatile laboratory blanks (CD860430B14, associated with no samples, and CC860512C14, associated with samples Q0722 and 724) contained acetone contamination at concentrations of 10.2 and 14.6 ug/L (the acetone CRDL is 10 ug/L). All other volatile blanks contained acetone at concentrations of 4.5 to 8.1 ug/L. All pesticide and herbicide blanks and one semivolatile blank contained di-n- butylphthalate at 1.3 ug/L (CRDL equals 20 ug/L). One semivolatile blank (GH084654, associated with sample QO723) contained three tentatively identified compounds (TICs) at levels ranging from 9 to 13 ug/L. All organic analyses were performed as requested. ------- G- 9 MEMO September 23, 1986 Page 8 Laboratory reported detection limits were CRDL or tower except for five volatile samples (Q07l7, 719, 720, 721, and 723) requiring additional dilution due to high organics concentrations for which the DL ranged from 1.7 to 3.3 times CRDL and all the semivolatile samples where the DL was twice the CRDL. Dioxin analyses were performed on all of the samples. The recovery of the dioxin compounds in the spiked sample ranged from 97 to 117 percent. No dioxins were found in any samples (except the spike). No contamination was reported in any of the dioxin blanks. Overall, the organic QC data are acceptable. 3.3 Vplptiles Quality control data indicate that volatile organics were run acceptably. The chromatograms appear acceptable. The matrix spike, matrix spike duplicate, and surrogate spike recoveries were acceptable. Initial and continuing calibrations, tunings, blanks, and holding times were acceptable. No unusual dilutions were made. The laboratory ran a blank sample prior to the continuing calibration standard on one instrument on one date. Volatile chemicals were the only organics that were found in the triplicate samples. The quantitation of the four volatiles found (methylene chloride, chloroform, trichloroethene, and tetrachloroethenc) was acceptable. Acetone was detected in a method blank at a concentration of 8.1 ug/L. The sample associated with this blank was reported to contain acetone at a concentration of 510 ug/L which is significantly greater than the value in the blank and thus the blank contamination was insignificant. The estimated method detection limits were CRDL for samples Q0713, 714, 715, 716, 722, and 724, 1.67 times CRDL for sample Q0719, 2 times CRDL for samples Q0720 and 721, 2.27 times CRDL for sample Q0717, and 3.33 times CRDL for sample Q0723. The volatiles data are acceptable. The probability of false negative results is acceptable. The volatile analyte results should be considered quantitative. 3.4 Base/Neutrals and Acids Initial and continuing calibrations, tuning, blanks, holding times, and chromatography for the semivolatiles were acceptable. Matrix spikes, matrix spike duplicate, and surrogate spikes for the base/neutrals and acids were acceptable. No semivolatiles were found in the triplicate samples. ------- G-1O MEMO September 23, 1986 Page 9 The surrogate spike recovery for 2-fluorobiphenyl was 42 percent and the DQO range is 43 to 116 percent. The semivolatile data are acceptable and should be considered semi- quantitative. The probability of false negatives for the semivolatiles is acceptable for all samples. Estimated method detection limits are twice CRDL for all samples except Q0724 which is 2.5 times CRDL. 3.5 Pesticides and Herbicides The calibrations, blanks, holding times, and chromatographic quality for both pesticides and herbicides are acceptable. The matrix spike, matrix spike duplicate, and surrogate data are within acceptable limits. The pesticides trip and field blanks (Q0713 and 715) appear to be contaminated. The same pattern of contamination appears in sample Q07l4. The data for the pesticides should be considered unreliable with a significant probability of false negatives. The estimated method detection limits for the pesticides fraction were CRDL for all samples. The herbicides data quality should be considered qualitative. The estimated method detection limit for the herbicides fraction was CRDL. 3.6 Dioxins Recoveries of the dioxin spike by the organics laboratory appear to be quantitative with values of 97 to 117 percent for the congeners. 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 samples, the probability of false negatives 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. 3.7 Tentatively Identified ComDounds One or more tentatively identified compounds were found in all but one of the samples, including all blanks, from this facility. Concentrations of these compounds ranged from about 10 to 100 ug/L. ------- G- 11 MEMO September 23, 1986 Page 10 ilL 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. Hazardous Waste Ground-Water Task Force Laboratory Data Quality Control Evaluation Report for Sikorsky Aircraft, Stratford, Connecticut, 7/31/1986, Prepared by Life Systems, Inc., Contract No. 68-01-7037, Work Assignment No. 549, Contact: Timothy E. Tyburski; Prepared for US EPA, Office of Waste Programs Enforcement, Washington, DC. 3. Draft Inorganic Data Usability Audit Report and Draft Organic Data Usability Report, for the Sikorsky, CT site, Prepared by Laboratory Performance Monitoring Group, Lockheed Engineering and Management Services Co., Las Vegas, Nevada, for US EPA, EMSL/Las Vegas, 8/19/1986. ------- G- 12 MEMO September 23, 1986 Page 11 IV. Addressees Ed Berg Chief, Project Management Section, Quality Assurance Branch, EMSL/CI US Environmental Protection Agency 26 West St. Clair Street Cincinnati, Ohio 45268 Michael Kangas ICAIR, Life Systems, Inc. 24755 Highpoint Road Cleveland, Ohio 44122 Anthony Montrone Hazardous Waste Ground-Water Task Force, OSWER (WH-562A) US Environmental Protection Agency 401 M Street S.W. Washington, DC 20460 Gareth Pearson Quality Assurance Division US EPA Environmental Monitoring Systems Laboratory - Las Vegas P.O. Box 1198 Las Vegas, Nevada 89114 Richard Steimle Hazardous Waste Ground-Water Task Force, OSWER (WH-562A) US Environmental Protection Agency 401 M Street S.W. Washington, DC 20460 Barbara Hughes NEIC US Environmental Protection Agency Building 53, Box 25227 Denver, CO 80225 Eugene Lubinecky US Environmental Protection Agency John F. Kennedy Federal Building Room 2203 Boston, MA 02203 ------- G- 13 MEMO September 23, 1986 Page 12 Paul Friedman Characterization and Assessment Division, OSW (WH-562B) US Environmental Protection Agency 401 M Street S.W. Washington, DC 20460 Chuck Hoover Laboratory Performance Monitoring Group Lockheed Engineering and Management Services Company P.O. Box 15027 Las Vegas, Nevada 89114 ------- Table G-1 Specific Organic Constituent Analysis Results Station: Well B-i Well B—2 Well 8—2 Well 8—2 Well B—3 Well 8—4 Impoundment Effluent SilO.No.: 110—0722 110-0719 110-0720 110—0721 110-0717 110-0116 110-0714 110-0723 Compounds Detected Value, ugh Value, ugh Value, ug/L Value, ugh Value, ugh Value, ugIL Value. ug/L Value, ug/L Ilethylene chloride ND a ii. 8. b 6. b 80. ND 4. b 60. Chloroform ND 30. 30. 30. 60. 4. b tO. 15. b 1,1—Dlchioroethane 4. b ND ND ND ND ND ND ND 1,1,1—Trichloroethane 8. ND ND ND 8. b 6. ND ND trans—i ,2-Dich loroethene ND ND ND ND 40. 48. ND ND Trichioroethene ND 60. 60. 50. 110. 33. 10. 18. Tetrachloroethene ND 220. 220. 210. 420. 220. 190. 260. Toluene ND ND ND ND ND ND ND 39. Acetone ND ND ND ND ND ND 30. 480. 2- Butanone ND ND ND ND ND ND ND 530. Benzyl alcohol ND ND ND ND ND ND ND 12. b Naphthalene ND ND ND ND ND ND ND 2. b 2-Ilethylnaphthalene ND ND ND ND ND NO NO 9. b Phenol ND ND ND ND ND ND 20. 30. 2-Chioropheno l ND ND ND ND ND ND ND 20. b Pentachiorophenol ND ND ND ND ND ND ND 30. b 2-Hethyiphenol ND ND ND ND ND ND ND 50. 4-Hethyiphenol ND ND ND ND ND ND ND 14. b LOQ Factors (c) Volatile IX 2X 2X 2X 2X 1X IX 3X Sem lvolatl le l x lx ix ix 1X IX 1X 1X Pesticide 1X lx 1X 1X 1X 1X 1X 1X Herbicide 1X lx lx lx lx IX 1X lx flaa.aaa a = annanfl= = a nn = == —_nn—_ na n = == = ===nn == = a== =n n f l flanfl=a=== finn = can = nn = n= a n=s = ==nan a== = a) Compound was not detected. b) Estimated concentration. Compound was detected but the concentration was below the Limit of Quantlation (L0Q). c) LOQ Factor is the factor that the LOQs given in TableG—3 must be multiplied by to correct for dilutions. ------- Table (1-2 LIMITS OF QUANTITATION FOR ORGANIC COMPOUNDS SIKORSKY AIRCRAFT Stratford, Connecticut Limit of Quarititation (pg /I) Limit of Quanti tation (pg/I) Limit of Quantitation (pg/I) Volatile Compounds (Purge & Trap) Semi-Volatile Compounds Semi—Volatile Cor,çounds (cont. ) Bromomethane 10 Aniline 20 N-nitrosodiethylamine 20 Chloromethane 10 4-Chloroaniline 20 Acetophenone 40 Bromodichlorcmethane 5 2-Nitroaniline 100 N-nitrosodipiperidine 40 Dibrouiochlorcmethane 5 3-Nitroanil lne 100 Safrole 40 Bromoform 5 4-Nltroariiline 100 1,4—Napthoquinone 40 Chloroform S Bentidine 100 2,3,4,6-Tetrachiorophenol 40 Carbon tetrach loride 5 3,3’-Oictilorobenzidine 40 2-Napthylamine 40 Carbon disulfide 5 Benzyl alcohol 20 Pyridine 40 Chioroethane 10 Benzyl chloride 40 Pentach loroethene 40 1,1-Dichloroethene 5 1,2-Dichlorobenzene 20 1,3,5—trinitrobenzene 40 1,2-Dichloroethane S 1,3- Oichlorobenzene 20 Ethylmethacrylate 40 1,1,1-Trichloroetharie S 1,4-Dichlorobenzene 20 o—Toluidine hydrochloride 40 1,1,2-Trichloroethane S 1,2,4-Trichlorobenzene 20 2,6—Dichlorophenol 40 1,1,2,2- Ietrachloroethane 5 1,2,4,5-Tetrachlorobenzene 40 p—Oirnethylaminoazobenzene 40 1,1-Oichloroethane S 1,2,3,4-Tetrachlorobenzene 40 1,2,3—Trichlorobenzene 40 trans-1,2- Oichloroethene S Pentachlorobenzene 40 1,3,5—Trichlorobenzene 40 Trichloroethene 5 Kexachioroben iene 20 1,2,3,5-Tetrachlorobenzere 40 Tetrachloroethene 5 Pentachloronitrobenzene 40 Ethyl-methanesulfonate 40 Methylene chloride 10 Nttrobenzene 20 alpha, alpha- Vinyl chloride 10 2,4-Dinitrotoluene 20 Dimethylphenethylamine 40 1,2—D ich loropropane 5 2,6-D lnitrotoluene 20 Methapyrilene 40 cis—1,3-Dichloropropene S N-Nttrosadirnethylamine 20 7,12-Dimethylbenzanthracene 40 trans-1,3-Dichloropropene 5 N-Ni trosodiphenylaminea 20 Benzal chloride 40 Benzene 5 N-Ni trosodipropylamine 20 Zinophos 40 Chlarobenzene S bis(2-Chloroethyl) ether 20 4—Aminobiphenyl 40 Ethylbenzene S 4-Chlorophenyl phenyl ether 20 Tetraethyldithiopyro— Toluene S 4-Bromophenyl phenyl ether 20 phosphate 40 Xylenes S bis(2-Chloroisopropyl) ether 20 3,3’-Dimethylbenzidine 40 Acetone 10 bis(2-Chloroethoxy) methane 20 Pronamide 40 2—Butanone 10 Nexachioroethane 20 Chlorobenzilate 40 2-Nexanone 10 Hexachlorobutadiene 20 o-Phenylenediamine 40 4-Methyl-2-pentanone 10 Mexachlorocyclopentadiene 20 m-Phenylenediamine 40 2—Chloroethyl vinyl ether 10 bis(2-Ethylhexyl) phthalate 20 p-Phenylenediamine 40 Styrene 5 Butyl benzyl phthalate 20 Isosafrole 40 Vinyl acetate 10 di-n-Butylphtha late 20 N-Nitrosopyrrolidine 40 Crotonaldehyde 50 di-n-Octylphthalate 20 Aramite 40 1,2-Dibrono-3—chloropropane 20 Diethylphthalate 20 Diallate 40 1,1,1,2-Tetrachloroethane 20 Dimethylphthalate 20 Dimethoxybenzidine 40 1,2-Dibromoethane 5 Acenaphthene 20 Benzotrichloride 40 1,2,3-Trichioropropane 5 Acenaphthylene 20 Nitrosmethylethylamine 150 1,4— Dichloro—2—butene 20 Anthracene 20 N-Nitroso-di-N-butylamine 40 Trichlorofluoromethane 5 Benzo(a)anthracene 20 Cyclophosohamide 150 Acrolein 50 Berizo(b)fluoranthene and/or llexachloropropene 40 Acrylonitrile 50 Benzo(k)fluoranthene 20 Phenacetin 40 Benzo(g,h,i)perylene 20 Resorcinol 40 Volatile Compounds (OAI)b Benzo(a)pyrene 20 Diirethoate 40 Chrysene 20 4,4’Methylene-bis Acrylorntrile 50 Dibenzo(a,h)anthracene 20 (2—chloroaniline) 40 1 ,4—D ioxane 100 Dibeniofuran 20 Paraldehyde 40 Ally! alcohol 50 Fluoranthene 20 Methyl methane sulfonate 40 Ethyl cyanide 100 Fluorene 20 N-nitrosomorpholine 40 Isobutyl alcohol 100 Indeno(1,2,3-c,d)pyrene 20 1-Naphthylamine 40 Nethacrylonitrile 25 Isophorone 20 1,2-D iphenylhydrazine 40 2-Propyn-1-ol 100 Naphthalene 20 8enzoic ac Id 100 Acrolein 100 2-Chloronaphthalene 20 Phenol 20 Methyl Methacrylate 50 2-Methyl naphthalene 20 2-Chlorophenol 20 Phenanthrene 20 2,4-Oichlorophenol 20 Pyrene 20 2,4,5—Trichlorophenol and/or 5-Nitro-o-toluidine 40 2,4,5—Trichlorophenol 100 ------- a eesured as diphenylamine b Direct aqueous injection G- 16 Table 3—2 (cont.) Limit f Limit of Limit of Quanti tati ( ag/L) Quanti tati on ( g/L) Quanti tati on ( g/L) Semi-Volatile Co oundS (cont.) PentachioropheflOl 100 4-Ch loro-3-methYlPhefl ol 20 2-Methy pheflO l 20 4-Methyiphenol 20 2 ,4-DieethylpheflOl 20 4 ,6-Dinitro-2-methylpheflOl 100 2-Nitrophenol 20 4-Nitrophenol 100 2,4-Dinitrophenol 100 Pesticides/PCBS Aldr In alpha-BHC beta-BHC gamna-BMC delta-BHC Chlordane 4,4-DOD 4,4-DDE 4,4’IDT Dieldrin Endosulfan I Endosulfan tI Endosulfan sulfate Endrin Endrin aldehyde Heptachlor Heptachior epoxide Toxapherie Methoxychior Endrin ketone PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Kepone 0.05 0.05 0.05 0.05 0.05 0.5 0.1 0.1 0.1 0.1 0.05 0.1 0.1 0.1 0.1 0.05 0.05 1 0.5 0.1 0.5 0.5 0.5 0.5 0.5 1 1 0.1 Herbicides Olcamba Dalapon MCPP MCPA Dichioroprop 2,4-Dichlorophenoxy acetic acid 2,4,5-1 2,4DB Dinoseb Dioxins & Dibenzofurans TCDD (Tetra) PeCDD (Penta) HxCDD (Hexa) HpCDD (Hepta) OCOD (Octa) ICOF (Tetra) PcCDF (Penta) HxCOF (Hexa) HpCDF (Hepta) OCDFF (Octa) 1 2 ioo 100 2 4 1 4 1 (ng/L) 1 5 6 4 44 1 3 3 17 13 ------- Table 6-3 Total Metals Analysis Results Station: Well B—i Well B-2 Well 8-2 Well B-2 Well 83 Well 8—4 SMO No.: 140-0122 1IQ-0719 MQ0720 MQ—072 1 140-0111 IIQ—07 16 Element Value, ug/L Value, ugh Value. ugh Value, ugh Value, ugh Value, ugIL Al 4,140. 42,500. 18,600. 20,300. 32,300. 39,000. Sb C 3 a,b ‘ 60. b 7.1 b 6.1 b < 60. b c 60. b As < 10. b 34.8 b 16. b 17.1 b 24.8 b 35.7 b Ba 61. 349. 218. 225. 316. 380. Be < 4. < 4. < 4. ‘ 4. < 4. 4. Cd .5 b 30. b 23. b 17. b 5.1 b 19. b Ca 22,900. 214,000. 225,000. 229,000. 148,000. 90.800. Cr 18. 1,280. 1.380. 1,420. - 150. 925. Co ‘ 16. 21. C 16. < 16. 21. 25. Cu ‘ 12. 69. 33. 34. 58. 92. Fe 5,320. 47.600. 19,100. 20.000. 36,800. 46.000. Pb C 5• 48.4 20.2 22. 39.6 30. 14g 10,100. 25,100. 17,500. 17,800. 60,000. 69,600. Mn 541. 679. 315. 325. 747. 684. Hg ‘ .2 ‘ .2 < .2 ‘ .2 C .2 C .2 NI C 20. 54. 31. 39. 40. 45. K 4,800. 44,500. 40,000. 40.000. 49,800. 43,300. Se <3. ‘5. (5. (5 (5. <5. Ag <10. ‘10. ‘10. (10. <10. <10. Na 37,600. 259,000. 298,000. 290,000. 189,000. 196,000. Ti ‘10. b ‘10. b <10. b <10. b <10. b <10. b V < 21. 78. 21. 34. 63. 76. Zn 24. 109. 63. 54. 133. 107. a) Sample concentration was less than the given concentration. b) Batch spike recovery was not within control limits indicating possible bias. G ------- Table G-3 (continued) Total Metals Analysis Results C, Station: Impoundment Pipe Effluent SMO No.: IIQ-0714 MQ—0723 Element Value, ugh Value, ugh Al 3,100. 502. Sb 9.6 b 10.9 b As < 10. a,b < 6. b Ba 14. 9. Be <4. <4. Cd 32. b 40. b Ca 234,000. 130,000. Cr 3,000. 276. Co < 16. < 16. Cu 63. 38. Fe 1,200. 95. Pb 7.8 2. Mg 7,740. 2.850. Mn 38. 15. Hg < .2 C .2 NI 35. < 20. K 40,800. 6.330. Se < 5. < 5. Ag < 10. < 10. Na 382.000. 99,200. 11 < 10. b < 10. b V 85. 21. Zn 104. 27. a) Sample concentration was less than the given concentration. b) Batch spike recovery was not within control limits Indicating possible bias. ------- Table G-4 Field Measurements and General Analysis Results Station: Well 8—1 Well 8-2 WetI 8-2 Well 8-2 Well 8-3 Well 8—4 Impoundment Effluent S140 No.: IIQ-0722 MQ-0719 14Q-0720 MQ-0721 140-0717 IIQ-0716 MQ-0714 NQ-0723 Parameter Units Value Value Value Value Value Value Value Value pH UnIts 6.08 6.47 6.46 6.4! 6.55 6.55 4.6 8.11 Conductance umhoslcm 380. 1800. 1800. 1800. 2400. 1900. 2300. 980. Turbidity NTU 12. 125. 125. 125. 185. 82. 2.8 2.2 POX ugh Cl 12. 225. 225. 419. 609. 257. 192. 396. TOX ug/L Cl 19. 633. 478. 396. 573. 4600. 199. 37. POC mg/I C ‘ .1 a C .1 < .1 < .1 c .1 < .1 < .1 < .1 NPOC mg/L C 3.9 9.9 8.5 7.3 7.6 7.2 8.6 14. Aiivnonia mgIL N .27 1. 1.05 1.03 < .1 .6 .9 1.4 Bromide mg/L .16 C .05 ( .05 ‘ .05 C .05 C .05 C .05 < .05 Chloride mg/I 70. 220. 55. 47.5 215. 308. 35. 85. Nitrate mg/I II .9 50. 75. 70. 50. 15. 100. 2. Nitrite mg/L N C .05 C .05 C .05 ‘ .05 C .05 C .05 .34 .52 Sulfate mg/I S04 74. 325. 1150. 813. 325. 273. 1110. 350. Cyanide ugh C 10. 90. 40. 60. 40. 20. 20. < 10. Phenol ugh. C 10. 60. 16. 37. 22. C 10. 60. 267. a) Sample concentration was less than the given concentration. 9 ) ------- |