Remedial Planning Activitiesat Selected UncontrolledHazardous Waste Sites-Zone II

f^ Environmental Protection Agency$3^ Hazardous Site Control Division

Contract No. 68-01-7251

INDUSTRIAL WASTE CONTROL SITE•TECHNICAL MEMORANDUM ON

FIELD OVERSIGHT ACTIVITIESWA NO. 101-6637.0/W68520.TI

NOVEMBER 23. 1987

ICFPRCEcology and Environment

005003

B L A C K & V E A T C HENGINEERS-ARCHITECTS TEL. 19131 339-2000

RLM IVIndustrial Waste Control

1500 MEADOW LAKE PARKWAY

h MUNG ADDRESS PO BOX NO BdQS

KANSAS CITV. MISSOURI 641 -4

B&V Project 68520.OT1November 23 , 1.987

Mr . M. S. Rameshl'SE?A - Region VI1-+45 Ross Avenue, 10th FloorDallas, Texas 75202-2733

Dear M r . Ramesh:

Enclosed ^re f ive (5) copies of the Final T)ra:t Technical Memorandum f o rthe Field Oversight of the s tudy conducted by IT Corporat ion fo r theP R P s .

Please forward a copy of this Technical Me-ioranduii to '-Ir. Larry W r i g h t ,Section C h i e f , Region V I , E:P-\ . In addition, please send a copy of theme'no*'andu:n t -3 '•lr. Jack. Taylor , E P ^ , Headquar ters .

Following ou'- s tandard repor t d i s t r i bu t ion protocol , I have also sentcopies of the report :3 Mr . Richard Moos, SP^, CH2M rilLL; Mr. BradHe'-manson, RKM, CK2M 4ILL; and a copy to the CH2M HILL projectmar.age-nLint o f f i c e in Wash ing ton , D . C .

Very truly yours,

BLACK & VEATCH

( /^^- J^^^^^^^

Clyde L . iutchi.sonA S P M , IWC Si te

rmc£nc Lo^u*'es

cc; Larry rt'r.'.ght/SECTION CHIEF. RPA Region V:Jack Taylor/EPA HDQSRichard Mooq/SPM. CH2M 4ILL. DENVERBrad Ke^ianson/REM. CH2M liILL, n,\I.LASVicki Kohonoski/^ZPM-REM, CH2M HILL, WOC

005004

TWC FIELD OVERSIGHTTECHNICAL MEMORANDUM

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 SITE LOCATION AND STATUS

1 . 2 rwC PRP SUPPLEMENTAL INVESTIGATION1 . 3 . 1 Authorization and Scope1 . 2 . 2 Object ives of the Supplemental Investigation

1.3 I'SEPA O V E R S I G H T R E Q U I R E M E N T S1 . 3 . 1 On-site Rep re sen t a t i ve1 . 3 . 2 In te rac t I-on Between the Concerned Par t ies1 . 3 . 3 Spl i t Sampling Program

-? ,n ]:T C^.POFATION KO°K PLAM SUMMARY

2 .1 " O B I L I Z A T I ^ M2 . 1 . 1 Work "lan Scope2 . 1 . 2 deviations fron Proposed Scope2 . 1 . 3 Observations

">..Z n^ 'SirE BOPIVG PROGRAM2 . 2 . 1 T'ork P lan Scope2 . 2 . 2 Deviations f r o m Proposed Scope2. 2 .3 Observations

2 . 3 ^TnrE BOR.NG PROGRAM2 . 3 . 1 ^ork Plan Scope3 . 3 . 2 Deviat ions f rom Proposed Scope2 . 3 . 3 Observa t ions

2.^ TRENCHING FOR WASTK PROFILING/DRUM INSP[;CTI<''N2 , ^ . 1 Work °lan Scope2 . ^ . 1 Deviations froa Proposed Scope2 . ^ . 3 Observations

2 . 5 ^r'E "^l'^ CTESTIGATION2 . ^ . 1 Uork Plan Scope2 . 5 . 2 Deviations froi-n Proposed Scope3. '5. 3 Observations

2.^ I^STALI^TIOK' OF MONITORING l^LLS2 . 6 . 1 Work "lan Scope2 . 6 . 2 deviation?? from Proposed Scope2 . 1 . 3 Observations

005005

r-WC F I E L D OVERSIGHTTECHNICAL ^MOPANDL'M

TABLE OF CONTENTS ( .Continued)

2 . 7 FYDROLOGIG TESTING PROGRAM2 . 7 . 1 Work Plan Scope2 . 7 . 2 Deviations f rom Proposed Scope2 . 7 . 3 Observations

2.» MONITORING WELL SAMPLING PROGRAM2 . ^ . 1 ^'ork Plan Scope2 . " . 2 Deviations f rom Proposed Scope2 . . ^ , 3 Observations

3.° C^'O'l^AL ^ATA ANALYSES OF SPLIT SAMPLES

3.1 SPLIT SAMPLING RESt^^TS

1,? "'-''•lATlONS FEW PROPOSED '/OP.K PLAN ANDSPLIT SAMPLING PLAN

3.3 CO^PA'^ISO" OF R E S U L T S3.3.! '.:ater3 . 3 . ? Soil

3 . 3 . 2 . 1 Organic A n a l y s i s3 . 3 . 2 . ? Inorganic Analys i s

^n f-ryrp^J^ CO^f•-'K\;TC AND SUMMARY

4.1 1'NRESOLV!-:") ISSrE'^

4 . 2 n l^CLSSIO"; 'W TECHNrOl 'ES4 . 2 . 1 ' - ieal th and S a f e t y4 . 7 . 2 Sample ProceJures

A P ^ r ' ^ I Y A. K P A SPJ,IT S A M P L I N G PROGRA;-!

AP?1'':')!/ r, P H O T O G R A P H ? OF B O R I N G PROGRAM

Ap^ ' -o^y ." P H O T O G R A P H S HF r H E N C H I N G O P E P A T L O N S

A o? rr r ^)ry "' ANALY' r i rAj , pEs '^ . r? FPOM s p L r r S A M P L I N G

005006

IWC FIELD OVERSIGHTTECHNICAL MEMORANDUM

TABLE OF CONTENTS (Continued)

3-3

2-4

2-5

2-i^

3-\

3-2

3-3

3-4

LIST OF TABLES

Page

SPLIT SAMPLE REQUIREMENTS 1-6

TRENCHES ANn PITS EXCAVATED ONSITE 2-17

SPLIT SAMPLES DURING TRENCHING ACTIVITIES 2-30^—

WATER LEVELS FOR MONITORING WELLS 2-44 0"r-

HYDROLOGIC TEST PERFORMEP 2-^9 ^

WATER LEVEL MEASUREMENTS 2-50 _0

MONITORING WELL SAMPLES 2-54

PROPOSED VS. ACTUAL NUMBER AND LOCATION 3-2OF SAMPLES

SPLIT SAMPLES AT IWC 3-3

DISTRIBUTION OF ORGANIC DATA WITH A LOW DEGREE 3-8OF COMPARABILITY ACCORDING TO SAMPLE TYPE

DISTRIBUTION OF INORGANIC DATA WITH A LOW DEGKEE 3-9OF COMPARABILITY ACCORDING TO SAMPLE TYPE

68520.OT1 TC-?

005007

XWC FIELD OVERSIGHTTECHNICAL MEMORANDUM

TABLE OF CONTENTS (Continued^

LIST OF FIGITRES

SITE LOCATION

SUSPECTED WASTE AREA

SUSPECTED WASTE DISPOSAL AREAS

ONSITE BORING PROGRAM

OFFSITE BORING PROGRAM

TRENCHING PROGRAM

TRENCHING IN SITE DECON AREAS

MINE VOID INVESTIGATION'

MONITORING WELLS INSTALLED

HYDROLOGIC TESTING PROGRAM

MONITORING l- LL SAMPLING PROGRAM

^520.on -rc-/i

005008

1.0 INTRODUCTION

1.1 SITE LOCATION AND STATUS

The Industrial Waste Control (IWC) site. shown on Figure 1-1, is a

closed and covered industrial landfill about 8 miles southeast of FortSmith, and approximately one mile west of Jenny Lind. Arkansas. The

site is an abandoned coal strip mine, unfilled remnants of the strip

mine are still evident east of the site. extensive underground coal

mining also occurred immediately north of the site.

Landfi l l ing operations at the IWC site began in the late 1960's or early

1970's wi th the disposal of municipal or construction refuse . Records ^

are vague concerning what material was disposed of during the initialyears. From l97-'i through mid-197 8, the site was a state-permitted

industr ia l J a n d f U l and industries in and around the Fort Smith area 0

used the site for the disposal of a wide variety of liquids, solid

Wc--.yte.-i, and sludges. During the U7^ to 1978 period, at least f o u r

impound ments for disposal of bulk liquid wastes were constructed on the

site (Henson versus IWC, 1979) . Drummed wastes were also reported to

have been buried at the site, and magnetometer durveys indicate severa*areari of high magnetic anomalies which confirms the presence of magnetic

objects (EPA, 19f lS) , Additional background and historical information

can be found in the Remedial Ac t ion Master Plan (EPA, 1983J. The site

was covered and closed in 1978. Subsequent to the closure, field

inveatigations were conducted which included analysis of soil and water

samples f rom the area. The results of these investigations and other

historical da ta provided the basis for including the site on the

'•latlonal "r iori t ies List of abandoned hazardous waste sites.

1.2 IWC POTENTIALLY RESPONSIBLE PARTY SUPPLEMENTAL INVESTIGATION

^ • ^ • ^ A u t h o r i z a t i o n and Scope

The U. S. Environmental '''rotection Agency (EPA) recently initiated

enforcement action against a number of Potentially Responsible Partiesf P R P s ) f o r cleanup of the IWC site,

^520.OT1 [-1

005009

1-2

FIGURE 1 - 1SITE LOCATIONIWC SITEPRP OVERSIGHTTECHNICAL MEMORANDUM

005010

Several studies and investigations of the IWC facility have been conduc-

ted by a number of organizations. The last series of studies was funded

by the FPA and were conducted by the E P A ' s Zone II Contractors (CH2M

"ILL and Black & Veatch) .

Wi th enforcement action pending, mos t , but not all of the PRP» organized

a group represented by a steering committee and requested, through the

EPA, that they be allowed to conduct an independent supplemental

investigation so that they could have a better understanding of the

site. The request was granted and the PRP steering committee hired an

independent consultant (IT Corporation) to conduct a Hydrogeologic andWaste Quan t i f i ca t ion Studv (HWQSJ . The field investigation s tar ted

0^March 1^, 1987 and ended May 29. 1987. The project was divided into ^

six, 10 day work periods. A report presenting the results of the ff\

supplemental investigation is being prepared by the PRPs . C0

^ • 2 . 2 Objectives of the Supplemental Invest igat ion

The objectives of the Supplemental Investigation as reported in the HWQSFork Plan are to obtain the additional data necessary to:

o "Characterize the dis t r ibut ion and levels (quant i t ies ) ofhazardous const i tuents on and o f f the IWC site. Determine ifburied drums containing waste materials at concentrationss igni f icant ly greater than the surrounding soil/waste matrixexist at the site. A concentrated e f f o r t may be made to morethoroughly determine the specific areas where contamination hasoccurred and to develop accurate est imates of the volume ofwaste and contaminated materials."

o "Fill in gaps in the existing hydrogeologic profi le of thesite, allowing a more comprehensive and less speculativequan t i f i c a t i on o f :

a. Site surface geology and shallow hydrogeology.

b. The relationship and possible interconnections betweenthe site and we coal mine voids.

c. Examine the possibility and extent of communicationbetween various subsurface zones and the f i l l area.

d. T>etermine t h s potent ia l for horizontal and ver t icalcontaminant n-ilgratlon via ground water from the site."

68520.nn i-3

HtL,, .[», .; ...•,-,.- i.u. J. ,^....--_ .»dKn^ ii.l. , ••iBt au,fcu.»]- ^n_>feI.aUl- «ll« •lik* l >,l

005011

o 'Describe the approximate configuration (height , width, voidto pillar ratio, e tc . ) of subsurface voids related to old mineshafts along the north side of the site."

o "Better def ine the ground water quali ty in the perched groundwater north of the site and evaluate the marginal impact of anypotential site associated contamination to background waterquali ty."

o "Develop a bet ter def ini t ion of the vertical and horizontalextent of contamination where the original RI indicates thatsurface soils adjacent to the site may be contaminated."

1.3 USEPA OVERSIGHT REQUIREMENTS

\01.3.1 Onsite Representative a\

r-The EPA requested that an oversight representative from E P A ' s Zone II

Contractor be onsite dur ing the supplemental investigation. The ooversight representative would be onsite for four primary reasons: 0

o Maintain a logbook of daily field activities.

o Act as liaison between the EPA, EPA's Zone II Contractors, andthe P R P ' S Consultants.

o Document f ield activities as compared to the HWQS work planand communicate compliance and deviations to EPA.

o Collect split samples and submit samples for lab analysis.

1 .3 .2 In teract ion Between the Concerned Part ies

The EPA oversight representat ive was the liaison between EPA» the EPAZone II Con t rac to r s , and the P R P ' a consultants. Three consul tants were

hired by the PRPs to p e r f o r m various tasks dur ing the supplemental

Inves t iga t ion . The three consul tants , their major responsibilities, and

the interact ions wi th the oversight representat ive to coordinate

ac t iv i t i e s are described below. In addi t ion , the responsibilities ofthe E P A ' f i Regional Project Manager and the applicable coordinationact ivi t ies are also provided.

o EPA Regional Project Manager ( R P M ) - The RPM represents EPAand is ul t imately responsible for project management andexecution. The oversight representative informed the RPM of

6S52n.nTl 1-^

...... .t^t fcilw.U»J^^a. i»A',ltL -W- tt W^^ ;lJUt*l i<A«tf!lril *»ni! ^

005012

site activities on a regular basis and passed along informa-tion between EPA and I ts Zone II Contractors, CH2M-HILL andBlack & Veatch.

o IT Corporation (IT) - IT Corporation conducted the supplemen-tal HWQS study on behalf of the PRPs . The work plan for theproject and any requests for additional work had to beapproved by the EPA. The oversight representative observedand logged IT field activities. The representative did notat tempt to Instruct IT Corporation on how to conduct theirs tudy. EPA split sampling activities were coordinated by theoversight representative with IT Corporation. This facili-tated the gathering of samples on a timely basis to complywith EPA contract laboratory program (CLP) schedulingrequirements.

0 Environmental Resources Management (ERM) - The FRPs hired ERM f"^to monitor the activities of IT Corporation to assure the PRPs (7-.that a comprehensive s tudy of the site was being conducted in ^a cost e f fec t ive manner. The ERM representative kept a dailylogbook and took site act ivi ty photographs. The oversightrepresentative had no off ic ia l in teract ion with this con-sultant ,

00

o Gera^hty & Mil ler , Inc. Groundwater Consul tants ( G & M ) - ThePPPs originally discussed the project with G&M. IT Corpora-tion was later retained as a prime consultant as a result ofrecommendations f rom personnel on the IWC steering committee.G&M became a subcontractor to IT Corporation and was respon-sible for installing monitoring wells and conducting theKydrologic Testing Program. To aid G&M during the HydrologicTesting Program, sampling activities were coordinated inadvance with IT Corporation to avoid interfer ing with thetesting program. The oversight •"epresentative observed andlogged G&M field activit ies.

1 • 3 • 3 ^D1 it- -^n1?-1 "g prog rAm

A representat ive number of samples taken by IT Corporat ion were split

and analyzed by the EPA (CLP) program to provide a check on analyticalresul ts . The EPA Split Sampling Plan was developed f r o m the IT Corp-oration work plan of sampling events. A representative amount of each

med ia , i . e . , soil and water samples, were planned for split sampling.

Thesa Inc luded samples f rom each [raj or phase of the supplemental site

investigation as listed in Table l-l:

1-5

005013

TABLE 1-1SPLIT SAMPLE REQUIREMENTS

ProposedNo. of Samples by

IT CorporationLocation

Onsite soil boringsOffs i te soil boringsTrenching waste samplesBarrels ( i f encountered)Coal (if encountered)Existing monitoring wellsNew monitoring wells

44421220

112

-11

1 4 2TOTAL

ProposedEPA SplitSamples

338214

11.32

The split samples obtained for EPA were submit ted to the CLP fo r

laboratory analyses. IT Corporation uti l ized their own laboratories forsample analyses.

Spec i f i c information on the proposed EPA Split Sampling Program is

contained in the memorandum to EPA dated February 26 , 1987 which Isincluded as Appendix A.

68520.OH 1-6

005014

2.0 IT CORPORATION WORK PLAN SUMMARY

This chapter describes the scope of the IT Corporation work plan,

deviations from the proposed scope, and observations made by the EPA

oversight representative daring execution of the proposed work. The

descriptions of the work plan scope were taken directly from the HWQS

Work Plan prepared by IT Corporation. The discussion is divided into

eight disc"ete areas of work which include;

• Mobilization

• Onsite borings

• Offs i te borings

• Trenching for waste profiling/drum inspection

« Mine void investigation

& Monitoring well installation

• Hydrologic testing program

• Monitoring well sampling program

2 . 1 MOBILIZATION

2 . 1 . 1 Work Plan Scope

a-o'r-a-o0

IT Task 6 Mobilize all materials, equipment and personnelto the site.

2 . 1 . 2 'Deviations from Proposedjc.ope

The firat few d.ays of the project were spent organizing the site. Heavy

rains pre'/enfced additional work from being accomplished. IT Corporation

had a site access liability concern. They were concerned that people

living around the site could walk on site and be injured during their

investigation activities. As a result a 6 foot high chain link fence

was erected around the site.

The original work plan schedule way inodifled to adapt to the site and

weather conditions. Two factors prevented IT from following the

scheduled outline of tasks aa defined in the work plan. First, the rain

W20.OTI 2-1

005015

l e f t the site inaccessible for the dri l l rig (CME-75) in certain areas.

Second, site access permission from the property owners of Area A was

not secured prior to arrival onsite. The recent death of the owner,Mrs. Clark, resulted in this property being divided among several heirsof the estate. IT Corporation had d i f f icu l ty in getting timely approvalfrom all the heirs for access to the property.

Due to poor site drainage, IT installed a drainage pipe at grade to

divert surface water flow to the west part of the site. During theinstallation of this drainage pipe, metal debris and some possiblecontaminated soil was uncovered. This area is designated as Area 0 onFigure 2-1. At the time the contamination and metal was found, IT held <^an informal discussion with the EPA oversight representative and the PRP

COrepresentat ive, ERM. IT Corporation did not try to hide the fact that /^

there was possible contamination under their equipment storage and decon 0area . The primary concern at the time was the health and safety of theworkers installing the pipe. IT explained these concerns to the PRP

representat ive. The PRP representat ive recommended proceeding with theinstallation of the pipe with proper health and safety monitoring. TheEPA oversight representative suggested that vehicle tires contacting the

soil in this area dur ing the culvert installation should be decon-taminated before leaving the site.

0

2 . 1 . 3 Observations

Mobil izat ion s tar ted '^arch 16, 1987 and lasted through March 26, I 0 3 " .Key personnel were introduced 'including:

Bob Kent - IT - Project ManagerBob Monk - IT - Project EngineerSteve Forbes - IT - Site ManagerPhil Bullock - IT - Site Geologist:<ristin Baksa - IT - Health and Safe tyPaul Kopydlowski - ERM - PRP RepresentativeDick Gibbs - B&V - EPA Oversight Representat iveDril l Crew - Southwestern Laboratories

68530.OT1 2-2

005016

The time for initial site organization provided the EPA oversight

representative an opportuni ty to coordinate the split sampling programon behalf of EPA. It was decided the EPA oversight representative wouldcoordinate with CH2M HILL in Denver for bottle and paperwork requests,scheduling, and lab requests. In turn, CH2M HILL would contact the

appropriate EPA and Sample Management personnel to keep them informed o£sample shipments.

All materials required for the EPA split sampling program was supplied

through the CH2M-HILL equipment coordinator. This included sample con-tainers, sample coolers, and sample paperwork.

0CO

2.2 ONSITE BORING PROGRAM

The IT Corporation work plan described the Onsite Boring Program. Figure a>2-2 shows areas of suspected waste disposal. Figure 2"3 shows locations r~)of the onsite borings. All borings were to be drilled to the bottom of 0

fill material (if encountered) , or to auger r e fusa l . The f i rs t onsiteborings were drilled in the southeastern area of the site to be t t e rcharacterize the "fill" area and to collect additional data for design

of remedial actions. The remainder of the borings were drilled to

determine waste characteristics and to collect information for trench

excavation. Seven borings were planned along the central axis of themagnetic high in Area A as identified in the Electromagnetic s tudy of

the original R I . Three borings were planned along the axis of themagnetic high in Area C. Five borings were planned in Area B. The

purpose of these borings was to collect in format ion on the subsurfaceenvironment in the area proposed for trenching. The boring program wasto provide information on the depth to the water table, the probabi l i tythat a trench would stay open, the potential for odor problems, and the

presence/ absence of ferrous mater ia ls . The boring program also o f f e r e dthe oppor tun i ty to collect samples of the waste/soil mat r ix .

2 • 2 . 1 Work Plan Scope

9 j_T Task 8 Install 7 borings to approximately 50 feet (bottomof fill) or auger refusal along the central axis

68520.OT1 2-3

005017

2-4

005018

2-5

005019

2-6

005020

of the magnetic high identifiedthe original RI within Area A.be used to collect samplesinformation on the subsurfacearea proposed for trenching.

in the EH study ofThese borings willfor analysis andconditions in the

IT Task 9 Install 5 borings in Area B , to the approximatebottom of the fill material or auger refusal. Anestimated 10 representative samples of thewaste/soil matrix encountered by the borings willbe collected and analyzed.

IT Task 10 Install 3 borings in Area C, to the approximatebottom of the fill material or auger refusal . Anestimated 6 representative samples of thewaste/soil matrix encountered by the borings willbe collected and analyzed.

IT Task 11 Install 7 borings in the area east of Area C andsouth of Area A, to the bottom of any fillmaterial encountered (but not greater than 30fee t ) , or auger refusal. An estimated 1^ repre-sentative samples of any waste/soil matrixencountered by the borings will be collected andanalyzed.

IT Task 12 Grout all borings not in trench areas with bent-onite to prevent any possibility of verticalcontaminant t ransport .

2 . 2 . 2 Deviat ions from Proposed Scope

The FT Corpora t ion work plan was followed except for the number ofborings that were drilled in Area A and C and the sequence in which the

onsite boring tasks were performed. The weather and sita accesspermission problems prevented IT Corporat ion f rom following the sequence

in which the onsite boring tasks were per formed. Task 8 called f o r7 ^o r i r iRS in Area A; however , 9 borings were installed. Task 10 called

for 3 borings in Area C; however, ^ borings were installed.

2 . 2 . 3 Observations

IT Task 8 The borings in this task were drilled during thesecond 10-day work period (March 31-April 9) bySouthwestern Laboratories. The Site Geotechnical

2-7

005021

engineer f rom Black & Veatch was present £oobserve the Area A borings, with the exception ofB121. He made a list of observations which areincluded in Section 4 .2 of this memorandum.Boring B121, located close to existing monitoringwell MW09» was installed before the rest of theArea A borings and was listed as being in Area Afor convenience. The Area A borings are numberedas B121 to B123A and B133 to Bt37 aa shown inFigure 2--3. During this task. the HNU formeasuring organic vapors did not operate properlyand a replacement was not secured by IT Corpora-tion during the rest of the work period. AppendixB contains photographs of the Area A borings.The oversight representative took a split sampleof soil f rom Boring B13A between 0 and 3.5 feet .The boreholes were grouted at the conclusion ofthe borings. The boring program is described onpages 20 through 25 in the field logbook.

The Task 9 borings were installed by SouthwesternLaboratories during the f i rs t 10-day work period(March 16-26). IT Corporation installed fiveborings in Area B. The five borings, designated3107 through B i l l , are shown in Figure 2-3. Asplanned, one soil sample from a boring in Area B(B109 at c. depth of U to 19 fee t ) was splitsampled for EPA. The HNU registered greater than20 ppm in the borehole and on the sample. ITselected samples for analysis that appeared to becontaminated. IT Corporation took two samplesper borehole. The boreholes were grouted at theconclusion of the borings. This task is describedon pages 6 and 7 in the field logbook.

The Task 10 borings were completed by the South-western Laboratories dur ing the f i r s t 10-day workperiod (March 16-26). IT Corporation installedfour borings designated B112 through Bl15 , asindicated in Figure 2-3. Pieces of metal werebrought up by the auger at Boring B112 at 5-10feet depth . A large pliable mater ia l whichlooked like dried paint was also brought to thesurface. The dril l ing became d i f f i c u l t and thedri l l chat ter was greater than at other bore-holes. This may have indicated the presence ofmore substantial rubble and metals at this loca-tion. Appendix B contains photographs of mat-erials brought up by the auger at B112.

005022

clean, was dry and did not register elevatedreadings on the HNU. IT then drilled Boring B114without decontaminating the sample equipment.The EPA oversight representative took a samplefrom Boring B114 and would have preferred to sendthis sample for analyses. The sample taken fromB114 looked contaminated and had a reading ofgreater than 20 ppm on the HNU. Appendix B showsphotographs of Borings B112, B113 and B114,

Decontamination of the drill rig by the drillcrev was done between major areas such as betweenArea B and Area C. The augers and sa . Ie tubeswere decontaminated between each hole. Usuallytwo samples were taken at various depths fromeach bortug. None of the drilling equipment was -^decontaminated between samples taken from thesame borehole. The augers and samplers were notdecontaminated between Borings B113 and B114. ^°Because the sample materials were not decontami- C^nated the EPA oversight representative elected to 0send the sample from B113 f o r a split sample and ^>not the sample from B114. B115 was added to theArea C boring program. The borings were groutedwhen completed. Page 9 in the logbook detailsevents of Task 10.

* ir Task 11 The drill crew f rom Southwestern Laboratoriesinstalled these seven borings during the f irst 10day work period (March 16-26) in the area east ofArea C and south of Area A. These borings weredrilled in one day. The borings were drilled tothe bottom of any fi l l material encountered (butnot greater than 30 fee t ) . or auger refusal .Figure 2-3 shows these borings, designated B100through B106. IT took two samples per borehole.The borings had no visible contamination exceptfor B106 wh.'ch had high HNU readings. Drillcutt ings were darker than the other borings.Boring B106 had a reading on the HNU of 160 ppmin the borehole hut there was no indication ofcontamination in the brea th ing zone. As plannedno split sample was taken f o r EFA. At the con-clusion of these borings, the holes were filledwith g rou t . This work is described on page 5 inthe field logbook.

2-9

005023

The following EPA split samples were taken during the onsite boring

program:

Date ShippedSample Loc at ion/Pep th PgJ^J'J-.P^1-011 to Laboratory

B109 Area B Soil was dark 3-23-871^-19 feet deep with odor present.

B I 1 3 Area C Soil looked clean and 3-23-875-10 feet deep was dry.

Bl3^ Area A Soil material was black. 4-8-870-3.5 feet deep Some ptecea of metal,

Landfill type odor present.

CODuring the site visit on April 7, 1987 by the Site Geotechnical Engineer o

from Black & Veatch. the Artesian Wells ^34 and ^52 were observed. The a^

wells were found to be flowing at about the same t-ate as during theV^rf

Phase II Remedial Investigation (Summer 1985) . Also during this site Q

visit, water levels were measured in the following existing monitoring

wells;

Well

MW 23R - Phase II RI WellMW 2 3 S - Phase II RI WellWJ /(OS - Phase n RI WellMW O^S - Phase II RI WellMW 3^R - Phase II RI WellMW 30S - Phase II RI Well

Depth froE". Top ofWell Casing to Water

66.50 feetOry18.10 fee tDry40.55 feetIry

2 . 3 OFFSITE BORING PROGRAM

The objective of the supplemental Investigation offsi te boring program

was to better determine the vertical and horizontal extent of soil

contamination in offsite areas to the west, northwest, and immediately

north of the site (Figure 2-^). These o f f site areas of contamination

were designated by EPA for excavation and consolidation onsite. Four-

teen borings were drilled to the water table or bedrock, whichever was

shallower, and cont inuously sampled. Three soil samples from each

Soring were to be analyzed to define contaminant concentration versus

''.epth.

f t 8 5 2 n , r i T l 2-10

005024

2-11

005025

Four additional borings were drilled outside the fenced area near the

site o f f i c e trailers, IT Corporation made a special request to EPA to

do exploratory borings and additional trenching in this area during the

f i f t h and sixth work periods, respectively. Contamination was found

during installation of draining pipe and construction of a gravel bass

equipment storage and decon area at the beginning of IT'S field program.

The additional borings vere drilled to determine the extent of this con-

tamination.

2 - 3 - 1 Work Plan Scope

« IT Task 26 Install a series of 14 borings as shown on Figure o2-4, in the areas to the west and northwest of ^_the site.

o Continuous samples will be collected during <J\

the investigation. Samples representing ^approximately the surface, to I foo t depth , 0the 3 to 4 foot depth and the 6 to 8 footdepth will be collected for laboratoryanalysis.

o The remainder of the cores will be retainedshould addit ional , more extensive profi l ingseesi worthwhile at a later time. These coreswill be stored in an Austin-based repos i to ry .

• IT Task 2^ Grout all borings with bentonite to prevent anypossibility of vert ical contaminant t r anspo r t .

2 . 3 . 2 Deviations f rom Proposed Scope

Deviation f rom the proposed scope of work included dri l l ing additional

borings during the last work period and per forming the boring program

out of sequence. The weather and site access problem influenced thesequence In which the o f f s i t e boring program was accomplished. Part of

the program was completed dur ing the f i rs t ten day work period (March

16-26), the remainder was completed in the second ten day period (March

31-April 9 ) .

68520.OT1 2-12

005026

2 . 3 . 3 Observations

IT Task 26 Southwestern Laboratories installed 5 of 14borings in the area to the west of the siteduring the f irst 10 day work period (March16-26). Figure 2-4 shows these borings as B116through B120. A soil sample from boring B116 at0-4 feet depth was split sampled by the EPAoversight representative. The soil was dark andappeared to have coal spoils in it. Appendix Bshows photographs of B116. These borings weredrilled in a day and grouted at completion. ITtook two samples from each borehole. Theremaining 9 of 14 borings were drilled in theareas of fs i te to the west and northwest of thesite during the second 10 day work period bySouthwestern Laborator ies . The borings areindicated on Figure 2-4. Five of the borings,B124 through B128, were located near the coal;Jiles in the o f f s i t e area to the northwest of thesite. The other four borings, B129 through B132,were located in the middle of the o f f s i t e areajus t nor th of the site boundary. IT Corporationtook two samples per boring. EPA split soilsamples were taken from Boring B125 at 0-5 fee tand f rom Boring B130 at 5 to 12.5 feet.

Addi t ional The addit ional borings were drilled during theO f f s i t e f i f t h 10-day work period (May 12-21) by IT 'SBoring drilling crew. The borings were located closeProgram to the o f f i ce trailers and were numbered B138

through B141, as indicated on Figure 2-4.Samples were taken by pushing a sbelby tube withthe IT dri l l rig (Gardner-Denver 1500)„ Theborings are described on page 52 of the logbook,details fo r the borings are discussed below:

B138 - The ahelby tube was pushed to a depth of 7feet and a composite soil sample was takenbetween 4-7 feet depth . The soil was light brownoverburden material with coal spoils mixedthroughout . The boring was wet but did notproduce water between 5-7 feet depth. The HN"Ushowed no readings above background.

B139 - IT drillers pushed the Shelby tube to adepth of 6 feet and took a composite soil samplef rom 4-6 feet depth. The soil consisted of clay,spoils, and black, broken shale. The soils wered r y . The soil sample taken by IT was silty clay.

68520.OT1 2-13

005027

B140 - The Shelby tube could not be pushed past adepth of 3 feet because an obstacle was encoun-tered. From 0-1 foot depth coal spoils wereencountered and from 2-3 feet depth, silty claywas encountered. IT took their sample at 2 feet.The KNf reading on the soil sample was greaterthan 10 ppm.

B141 - The depth of this boring was 7 .5 feet. ITtook a sample at 7 .5 feet . Coal and shale spoilswere found in the hole. No readings above back-ground were recorded on the HNU.

The follosing EPA split soil samples were taken during the of fs i te

boring program:

Sample Location/Depth

B116 Far west side ofsite in o f f s l t earea. 0-4 feet

B125 O f f s i t e boringn o r t h of siteby coal pile.0 - 5 feet

R13Q O f f s i t e boringnorth of sitein middle .5-12.5 feet

Description

Soil was dark andparts looked likecoal spoils.

Soil sample lookedlike containedsome coal.

Soil sample lookedlike containedsome coal.

Date Shippedto Laboratory

.....—.__>.,...——————————_——-*_

3-23-87

4-8-87

4-8-87

1.'^ TRENCHING FOR WASTE PROFIUNG/DW I N S P E C T I O N

According to the IT Corporat ion work plan, the completion of the wc'rk

plan t renching tasks were dependent upon several areas of concern wnich

m i g h t a f f e c t the safety of the workers and the community surrounding the

site. If any of these areas of concern would have sur faced , IT Corpora-

tion would have mod i f i ed or t e rmina ted the trenching studies.

The completion of the t renching operations were also dependent upon the

abi l i ty to complete the tasks involved while excavating at sideslopea ofnot greater than one to one. Greater slopes would have resulted in

excavation of an unacceptably large portion of the site, magni fy ing pro-

blemd w i t h potential emissions, surface water control, and wastehandling.

2-14

005028

The work plan outlined in general terms, trenching operations which

would be initiated in Areas A and C. The scope of trenching to be donein these areas was refined by IT during the boring program, and con-

tinued to be modif ied throughout the site s tudy . For the purpose of

this memorandum trenching operations will be classified into two

categories. The planned trenching activities which were located inAreas A and C and exploratory trenching which was done as site condi-

tions allowed and as IT determined the need for additional trenching tofu r the r the i r inves tiga t ion.

The system for labeling the trenching activities on the site map was

developed by IT Corporation as the work progressed. Trenches were

ident i f ied as large trenching activit ies and pits as relatively small

trenching act ivi t ies . As a resul t , an act ivi ty which was initially Q\

labeled a trench may have later been designated a pi t . Some of the <^

split soil samples taken from the trenching activit ies are labeled withd i f f e r e n t trench numbers than the final designation used by IT which is

shown on Figure 2-5. A list of the trenches and pi ts , including the

corresponding split sample des igna t ion , is presented in Table 2-1,

^V-

CO

0

2.4. \ Work ^lan Scope

• IT Task 13 Based on the results of Tasks 8 and 10, selectthe exact areas and depths for installation oftrenches in Areas A and C.

• rT Task ^ Install 2-foot high dikes and plastic linercovered with soil around selected areas tocontain removed waste materials and fluids and toprevent runon / runo f f of liquid wastes andprecipi ta t ion .

• IT Task 15 Hxcavate t renches in Area A and C (as describedin Section 4 of the IT Corporation work plan) .Collect samples from all drums/containersencountered. In addition collect 8 samples inArea A and 4 samples in Area C of waste/ mat r ixmaterial from the trench vail or bottom foranalysis. Any intact barrels encountered duringthe trenching will be removed, overpacked, and

6R52n .OTl 2-15

005029

2-16

005030

SECTION 1TABLE 2-1

TRENCHES AND PITS EXCAVATED ONSITE

TRENCHES

Number Date

T-l

T";

T-3

T-4

T-5

T-6

T--1

T-P

T-Q

P-l

P-2

P-3"-^

P-5

P-6

0-7

p-aP"9

p-in

3-25-87

3-26-«7

3-26-87

3-26-87

4-15-87

^.-16-87

4-17-87

4-18-87

4-20-^7

3-26-87

3-26-87

3-26-87

4-10-87

4-19-87

4-19-87

5-27-R7

5-27-87

5-27-87

5-27-87

Location Planned Exploratory

Area C xSW of Area B

SW of Area B

SW of Area T!

Area A (middle)

Area A (middle

Area A (middle)

Area A (weat

side)

Area A (east

side)

PITS

Area C

Area C

West of Area ?Area ^

Area AArea A

Area HArea I)

Area D

Area D

Split SampleID Number **

Trench C

Trench A

Trench A

Trench A

6852^.OTI 2-17

005031

SECTION 1TABLE 2-1

TRENCHES AND PITS EXCAVATED ONSITE(con t 'd )

Number Date Location Planned Exploratory

PITS(cont 'd)

Split SampleID Number A*

P-

P-

P-

P-

P"

P~

P-I

p-

iL

12iJ.

t

1

f1-

1

1L

3

^

5

ft•7

tl

s"5-

5-

5-

5-

5-

5-28-

."'"'-

'28-

-27-

.27-

-27-87

•2R-S7

*

^7

-87

-87

-87

-87

Area r1

Area D

Area D

Area T)

Area ^

Area D

Area D

Area D

* RPA ove r sLRh t representat ive did not observe** nnly four split saniplea were planned

2-18

005032

stockpiled with investigation-derived cat-er ials. Bulky and sludge materials removedduring the trenching operations will beplaced back in the excavations and coveredwith a natural soil cap. The intent is toconduct this work and not increase the pre-sent level of surface contamination.

2 . ^ . 2 Tieviations from Proposed SconeI -^---.-..^ • — - - mrr——-— -——-a-Jl_I 1 -—-—-Ti -MI - —t»r-»

The IT work plan gave a general overview of trenching activities. The

work plan called for trenching in Areas A and C. The trenching planned

ror Area A was to be done first followed by Area C. The permission for

si te access to Area A and the initial weather conditions at the site t .

influenced the order that trenching activities could be conducted. T"

Init ial ly, four exploratory trenches were dug outs ide of Areas A and C0^

in the west part of the site and technically could be listed as a devia- /-s

tion from the work plan. These trenches and the trenching in Area C 0

were completed dur ing the f i r s t 10 day work period (March 16-26^.

The Area A t r e n c h i n g took place dur ing the th i rd 10 day work period

(April 1^-23). This work consisted of several trenches and pits

excavated in Area A.

During the f i n a l work period (May 16-29) IT excavated twelve addi t ional

pits in the v ic in i ty of the equipment storage and -lecon area (Area 0.' .

These addit ional t renching a c t i v i t i e s , i den t i f i ed as the additional

trenching program were approved by EPA at the t ime the additional boring

program was approved. This t renching work was requested as a result of

some contamination found during the f i rs t 10 day work period and

described in Section 2 . 1 . 2 of this memorandum. The locations of tnr i

addi t ional pi ts an'l trenches are shown on Figure 2-6.

D e c e n t l y , Black & Veatch received a map of the IWF site activities from

IT Corporat ion. A discrepancy was noticed on the number of trenches in

tie eouipment storage and decon area (Area D ) . It appears that IT

Corporation excavated one more pit a f ter the EPA oversight

representat ive was released f r o m oversight of the project . The

additional p i t is designated as P-lfl and is shown by a dashed line inFigure 2-6,w^n.nn 2-19

005033

FIGURE 2-6TRENCHING INStTE DECOIM AREAS1 W C SET£PRP OVERSIGHTT E C H N I C A L MEMORANDUM

005034

2 . A . 3 observations

0 IT Tasks Trenching activities for the site are divided13~ 15 into trenches and pits and will be discussed

according to those two categories.

Trench 1 - March 25, 1987. This trench, locatedin Area C and labeled T-l on Figure 2-5, wasexcavated during the f i rs t 10 day work period.The RPM from EPA was onsite Cor the intitialtrenching activities. As IT set up for thetrenching operation the RPM and the EPA oversightrepresentative questioned them on a Health andSafety concern. The operator of the backhoe hadno respiratory protection. It was suggested thata fu l l face respiraraior or escape pack be onhand. IT felt the operator was safe with theHealth and Safety person from IT monitoringconditions at the trenching location.

The trench was dug in a southwest direction.Trench T-l was approximately 50 feet long by 5feet wide hy 15 feet deep. In fo rmat ion on whatwas found in the trench can be found on Pages 12and 13 of the f ie ld logbook. Appendix C conta insphotographs of the Area C trenching operations.

The following is a brief summary of the items inthe trench:

Barbed wire and metal fence posts.

Several crushed and part ial ly crushed drumswi th in 5 feet or tne sur face .

—- D i f f e r e n t type& of solid mater ia l were foundin the d r u m s , it was not mixed wi th sur-rounding soil Materials .

-- Material found in one drum looked like thepi tab Ie dried paint found in Boring 112.

Material found In some other dru.ns includedsmall lignt green beads that appeared vet anda sol idif ied foam like material , which mighthave been dried paint. Another type ofmaterial found in the druma was a gray pow-der. This could have been some type of pol-ishing compound.

^"520. n-ri 2^21

005035

-'- At one point during trenching a water seepagezone was encountered at 12 feet. The backhoeexcavating the trench disturbed the sidewalland water jetted into the trench filling itfull of water in 5 minutes.

Trench 2 - March 26, 1987. This exploratorytrench was located in the southwest part of thesite as shown on Figure 2-5. This trench was notin Area A or C. The trench was 15 feet long by 5feet vide by 5 feet deep. Black material.possibly coal spoils, was encountered. Somepieces of metal were also evident. The materialexcavated was dry. Photographs of thisexploratory trenching activity are contained inAppendix C. Q

(MTrench 3 " March 26, 1987. This trench waslocated in the southwest part of the site asshown on Figure 2-5. The trench was 30 fee t long ^by 5 feet wide by 5 fee-t deep- A black granular 0material was found in the trench along with 0pieces of metal. The material f rom the trenchwarf dry and looked similar to the material inTrench 2. Photographs of Trench 3 can be foundin Appendix C,

Trench ^ - March 26, 19fi7. The trench waalocated in the southwest part of. the site asshown on Figure 2-5. The trench was 30 feet by 5feet wide by 5 feet deep. The material in thetrench was similar to that found in Trenches 2and 3. Photographs of this trench are found inAppendix C.

Trench S - April 15, 1987. This was the f i rs ttrench in Area A as shown on Figure 2-5- Thetrench was dug in a nor th-south di rect ion in thecenter of the high magnetic anomoly (reported inthe RI - Figure 5-10[EPA 1985]) . The trench ranperpendicu lar to the site fence located on then o r t h . There were large amounts Jf woodenCrash-like material in the tre-ch and a strongodor present. Crushed or partially c.-u'^hed drumswere found in the trench. A gray powder-likematerial was found in several of the drums and anERA split sample wad taken of this so1 Id materialand labeled - Trench A, Barrel 1. Analyticalresults for this sample can be found inAppendix 0. In one drum a solidified foam

2-22

005036

mater ia l witr i a mixing paddle running through themiddle was found. The RPM from ERA and the SiteGeotechnical Engineer from Black & Veatch wereonslte for this trenching activity. Also arepresentative from Whirlpool, one of the PRPs,was present. Trench 5 was 80 feet long by 5 feetwide by 20 feet deep and is deacribed on pages 29and 30 of the field logbook. Photographs ofTrench 5 are included in Appendix C.

Trench 6 - Apri l 16» 1987. Trench 6 was locatedju s t west. of Trench 5 as depicted on Figure 2-5.This trench was dug in an east-west directionlocated in the high magnetic anomaly (reported inthe RI - Figure 5-10) parallel to the north sitefence. The trench was 120 feet long by 5 feet ,—wide by 20 feet deep. Reference in the logbook -,,is made to Trench A - vest on paees 31 and 32. mTrench A-west was later renamed Trench 6. Allreference to Trench A-west on the sample names ^are referring to Trench 6. 0

0during the t renching , IT Corporation found drumsregularly, about 30 total. These barrels werefound a u n i f o r m distance apar t . Some were closeto the sur face ( w i t h i n 2 feet) and others wereabout 20 f ee t in depth. None of the dru^s foundwere fu l ly intact . Four separate, dis t inct ,types of mater ia ls were found in the drums. Noneof these mater ia ls were mixed together in any ofthe druir.s. The following is a list of materialsfound in the d r u m s .

Gray powder

-- Light green granular material

Solidified foaci material

"- Pink and yellow semi-solid mater ia l . . Thismaterial looked like dried paint and had notbeen seen in any of the other trenches.

The pink and yellow material was split sampledfor EPA (labeled Trench A - West d r u m 6).Analytical results for this sample are found inAppendix T).

The Health and Safe ty person from IT directed thebackhoe operator and site geologist from IT towear respirators half way through the trenching

2-23

i uJtkJ^kJl te^iA UAMA iau^ A. rk:.. 4&J

005037

activity because of high readings on the HNU. APRP representative f rom Whirlpool was onsltealong with the Site Geotechnical Engineer fromBlack & Veatch.

The trench was continued west another 10 feet onApril 17, 1987. Nothing of particular signific-ance was found in the small extension of Trench6. The trench contained trash and pieces ofwood. A total of four split soil samples weretaken by IT for EPA from Trench 6. (A-l throughA-4) . Analytical results for these samples arefound in Appendix D. Photographs of Trench 6 canbe found in Appendix C.

Trench 7. April 17, 1987. This trench ran westto east jus t to the east side of Trench 5 in thehigh anomaly as shown on Figure 2-5. Trench 7contained 10-15 crushed drums. These drumscontained materials similar to that found indrums within Trench 6. However, there was not asmuch mater ial in the drums. More wood was foundin this trench than in the other trenches. Trashand refr igerator bodies were also f o u n d . Thetrench dimensions were 120 feet long by 5 fee twide by 20 feet deep. Trend] 7 is described onpage 33 of the field logbook.

Trench 8. April 1.S. 1987. This trench waslocated in the west part of the site (Figure2-5) . in the v ic in i ty of Borings BI23 and B123A.This trench contained a few crushed drums andlarge amounts of wood and trash. The material inthe drums was similar to that encountered in theother trenches. The m a j o r i t y of material foundin the drums was the solidified foam mater ia l .One black plastic d r u m was also found; it wascrushed and was empty. It is possible that theplastic d rum had contained some kind of l iquid.There was a small seep on the side of the t renchat about 10 f ee t . The trench was located nearS123A which had water in the borehole. AppendixC conta ins photographs of the t renching activi-ties.

Trench Q - Apri l 20. 1987. Trench 9 was locatedin the fa r east part of the at te as dhown onFigure 2-5. A few crushed drums were found. Oneof the drums contained the solidified foam Uk6mater ial . The PRPs were represented by a person

005038

from Whirlpool. The trench dimensions were 80feet long by 5 feet wide by 20 feet deep. Thistrench is discussed on page 36 of the fieldlogbook and photographs are contained in AppendixC.

Pit 1 - March 26. 1987, Pit 1 was located jus twest of the old impoundment in Area C as shown onFigure 2-5. The dimensions of the pit were 6feet long by 5 feet wide by 5 feet deep. A smallamount of black solvent type liquid was found inthe pit. A general location photograph can befound In Appendix C.

Pit 2 - March 26. 1987. Pit 2 (.Figure 2-5) waslocated in the same general area as P it 1, J u s t ^north of the old impoundment in Area C. The p^idimensions of Pit 2 were the same as Pit 1. no00Strong odors with high HNL1 readings were evidentduring the excavation of Pit 2. Appendix C shows ^the general location of this p i t . 0

0Pit 3 - March 26, 1987. Pit 3 shown on Figure2-5 was located west of Area B. The dimensions ofthe pit were 8 reet long by 5 feet wide by 5 fee tdeep. The pit contained mostly wood debris. Aphotograph of the general location of this pi t iscontained in Appendix C,

^it 4 - April 19, 1987. The pit was located 80feet east of the west fence and 30 feet south ofthe nor th fence as depicted on Figure 2-5.Although designated a pit , this act iv i ty was morelike other trenches with dimensions of 40 f e e tlong by 5 feet wide by 20 feet deep. Pit 4 ranin a north-south direct ion perpendicular to thesite fence. In previous trenching activi t ies, itwas easy to see where the trench came out of theold strip p i t area. This was not well defined onthe south for Pit A . Pit 4 had less trash andwood and more fill material than uther trenches.A strong burned odor was present and the materialwas deep black in color, unlike what was seen inother trenches. The pit had a tendency to sloughof f the sides because of lack of materials tohold the dirt together. Pit ^ was discontinuedfor safety reasons a f te r a large section of thepi t wail collapsed, Thp, field logbook diacussesthis on page 35.

2-25

. ii liilto-tltiu ,' i m.DI.HAkVkJyiltVSftl-t Hilll-Alnl'iC'fi'Bl

005039

^it_5 " April 10. 1987. Pit 5 was located jus tsouth of P i t ^ as shown on Figure 2-5. This pitwas started a f te r Pit A was discontinued forsafety reasons. It was actually an extention ofPit A . The material was the same as that foundin Pit ^. The pit dimensions were 30 feet longby 5 feet wide by 15 feet deep. This pit isdescribed on page 35 of the field logbook.Photographs of this pit are contained in AppendixC.

Pit 6 - April 19, 1987. Pit 6 was started in theeast part of the site close to well cluster rf2 asshown on Figure 2-5. Nothing notewor thy wasfound in the pit . IT dug down to 18 feet whereshale was found . The pit dimensions were 20 feetlong by 5 feet wide by 18 feet deep. The pit isdescribed on page 35 of the field logbook-

This trenching activity was requested by IT Corp-orat ion to be conducted inside the equipmentstorage and decon area. This was the result ofgome suspected contamination which was foundduring the f i rs t in day work period as discussedin Section 2 . 1 . 2 of this memorandum. IT Corpora-tion made a special request to do this additionaltrenching and received permission from EPA at thesame time they were granted permission to conductthe addit ional boring program. The Site Managerfrom the EPA ^one II contractors was onsite f o rthe m a l o r i t y of this act ivi ty . These additionalpits are discussed below:

Pi t 7 - May 27 , 1987. The p i t was located para-llel to the drainage pipe installed dur ing thef i r s t 10 day work period as shown on Figure 2-6.The approximate dimensions of the pit were 10feet long by A feet wide by 5 feet deep. Ten tof i f t e e n crushed, part ial ly crushed, and Intactdrums were found in this area. Not all of thedrums viaahle were removed because IT Corporat ionpunc tu red a drum during excavation. The drumcontained .3 l iquid that had a strong solvent-likeodor. Respira tors were worn dur ing the reat ofthis trenching activity. The Health end Safetyperson from IT used an organic vapor te.'it pump totest for organic vapors close to the liquid inthe d r u m . The organic vapor test pump waa muchlike the drager pump but had a d i f fe ren t manu-fac tu re . This test indicated that the vapor f rom

2-26

005040

the drum had toluene present at a concentrationof 30-^0 ppm. IT Corporation did not have ade-quate overpacking capabilities present to containthe liquid. They did remove as much of theliquid as possible by bailing and put it in a 55gallon drum. IT also removed much of the sur-rounding soil from around the ruptured drum andcontained it in another 55 gallon drum. IT triedto remove another drum that looked intact. Thedrum ruptured and had to be contained like thef i rs t one. One crushed drum of solidified foammaterial was also found and removed. The solid-ified foam material was not as dry as some thathad been seen in previous trenching activities.The material was more pliable and looked morelike paint than similar material found earlier inthat was dr ier . More details on this pit can be (VJfound in the field logbook on pages 65-66. IT QQtook a soil sample for analyses from this p i t . /-^Appendix C contains photographs of Pit 7.

Pit 8 - This pit was located just east of Pit 7 c^and the approximate dimensions were 5 feet longby 2 feet wide by 2 feet deep. The location ofPi t ^ is shown in Figure 2-6. IT Corporat ionimmediate ly found and accidently rup tured a d rum.The d r u m appeared to contain the same solventtype of liquid as the drums in Pit 7. The pitwas discontinued to prevent the ruptur ing of moredrums . Some liquid in the d rum was later bailedout and IT at temped to solidify the remainingl iquid by adding dry cement. This was relayed tothe onsite representative for EPA by IT Corpora-tion. This pit is described on page 66 of thefield logbook. Appendix C contains site photo-graphs of the trenching activities in this area.

Pi ts Q and 10 - IT moved 10 feet eas'. of the Pit8 location to start Pi ts ° and 10 as shown onFigure 2-6. The dimensions of the pits were 8feet long by 2 feet wide by 4 feet deep and werethe mirror image of each other. Two pieces ofmetal and no crushed drums were found in thepits . These pits are described on page 67 of thef ie ld logbook. Appendix C contains site photo-graphs of the trenching activities in this area.

^ i t 11 - The dimensions of Pit 1!. were 8 feetlong by 2 feet wide by A feet deep. The pit waslocated near the entrance to the equipment stor-age and decon ari=a as a "own -in Figure 2-6. IT

005041

Corporation took HNU readings near the soil andrecorded readings between 5-10 ppm. No drumswere found in this pi t . IT Corporation took asoil sample for analysis between 3-4 feet . Thispit is described on pages 67-68 of the fieldlogbook.

^t 12 - Pit 12, shown on Figure 2-6, had approx-imate dimensions of 6 feet long by 2 feet wide by4 feet deep. A rup tu r ed drum containing liquidwas round close to the surface. The HNU regis-tered 30 ppm at the surface of the solvent typeliquid. The trench was discontinued to avoidrup tu r ing more drums. This trench is describedon page 68 of the field logbook.

\cCMCO

Pit^j_3 - Fit 13. shown on Figure 2-6, hadapproximate dimensions of 3 feet by 2 feet by ^feet . Like other p i t s it was discontinued when acrushed drum was found, to avoid puncturing any 0s

ful l drum underneath. Also, ground water later cflowed into this trench. This trench is Qdescribed on page 68 of the field logbook.

Pit 1A •- Pit 14, shown on Figure 2-6, hadapproximate dimensions of 6 feet long by 2 feetwide by 4 feet deep. One crushed drum was foundin the p i t . It was not evident whether there wasany material inside the drum. The significanceof this pit was that IT Corporation took a breakafterwards to discuss what to do next. Theirgoal in the trenching activity was to identifythe extent of contamina t ion . They did not wantto keep rup tu r ing drums w^iie trying to do this.This act ivi ty is described on Page 68 of thef ield logbook.

Pit 15 - Pit 15 is shown on Figure 2-6. Twocrushed drums were found in the trench and therecould have been more underneath. No material wasevident in the crushed drums. IT Corporationdiscontinued the trench to avoid puncturing moredrums. They decided that any drums found would bereason enough to stop the trenching activities.Trench 15 is described on page 69 in the logbook.

Pit 16 and 17 - These two pi ta , shown on Figure2-6, had approximate dimensiona of 8 feet long by2 feet wide by 5 feet deep. They were locatednorth of the equipment storage and the decon area

2-2H

005042

running parallel to the buried drainage pipe.These pits did not have any crushed drums orpieces of metal in them. However, the soil hadhigh HNU readings which would indicate thatcontamination was leaking f rom the barrelsdiscovered in the equipment storage and deconarea and moving nor th . The purpose of the pitsin this area, according to IT, vas to identifythe northern extent of the drums in the deconarea. The pits were limited to one general areaand it would be hard to make a judgement aboutthe extent of the contamination to the northbased upon the limited coverage of these twopits. These pits are discussed on page 71 of thefield logbook. Photographs showing the generallocations for these pits are contained inAppendix C. t^"

C\i^t IS * The location for this pit is shown on CQFigure 2-6, jus t east of the equipment storage r^trailer. The EPA oversight representative didnot observe the excavation of this pit . ITCorporation told the EPA oversight representativethat Pit 17 was the last of the trenchingact iv i t ies . Since this was the final ac t iv i typlanned at the site, other than demobilization,the f ield oversight activity was terminated atthat time.

00

This concluded the t renching act i-vi ties onsite. The trenches and pits

were general ly hack filled the same day they were dug. A considerable

a.-.cunt of tir"e was spent by IT Corporation smoothing out the ground

a f t e r t r ench ing act ivi t ies were completed. This Included bringing in

nat ive f i l l dir t fron the Fort Smi th area from an o f f s i t e vendor to placeover the t renched areas.

Spli t samples t aken d u r i n g trenching act ivi t ies are aummari^cl t:i Table')-*'1

^520.DT1 2-29

005043

TABLE 2-2

SPLIT SAMPLES DURING TRENCHING ACTIVITIES

Sar-.nie

C-l

C"2

C-3

C-4

Trench C^ru"' 1

A-l

A-2

A-3

A-4

Location

NE section ofTrench T-l about0-5'

SU section ofTrench T-l about0-5*

Middle of TrenchT-l about 0-5'

Middle of TrenchT-l about 5-10*

SW section ofTrench T-l about0"5' f rom crasheddrum.

East end ofTrench 6

Middle ofTrench ^

West end ofTrench 6

West end ofTrench 6

Description

Dark brown and blackcolored soil. Strongodor of garbage.

HNU 10-15 ppm. Soilhad black aateri'.1visable.

Soil containeddark blackmaterial

Soil containeddark brownmaterial

Pliable material likedried paint. Smalllight green bea'Js.Dried foam material.

The soil was f rommater ial thit wasexcavated by thebackhoe taken out ofthe shovel.

The soil was f rommaterial that wasexcavated by thebackhoe taken outof the shovel.

The soil was fromtpaterial that wasexcavated by thebackhoe taker, outof the shovel.

The sc'il waa frommaterial that: waaexcavated by thebackhoe taken outof the shovel.

Date Shippedto^ Laboratory

3-26--87

3-26-87

3-26-87

3-26-87

3-26-37

4-14-87

4-17-87

4-17-87

68520.nn 2-30

005044

TABLE 2-2SPLIT SABLES DURING TRENCHING ACTIVITIES

(cont 'd)

Sample

Trench ADrum 1

Location

South end ofTrench 5

DescriptionDate Shippedto Laboratory

Gray puwder material 4-22-87

Trench ADrum ^

West end ofTrench 6

Light pink and yellow ^-22-87solid material.

2-31

005045

2.5 "INE VOID INVESTIGATION

The objective of this investigation waif to obtain intonaation on the

approximate configuration of voids related to previous underground coal

mine workings adjacent to the site (i.e., void configuration, height,

pillar spacing, e tc . ) .

during the fourth 10 day work period (April 28-May 7) IT Corporation

conducted a portion of their mine void investigationa. A total ofeleven borings were drilled by IT drillers and siore would have been

drilled during this work period except priorities were switched to other

site activities.

T»urin& the f ifth 10 day work period (May 1 2 - 2 1 . ) t'ne mine void boring

program was continued and an additional five borings were drilled.

Thus, a total of sixteen borings were drilled as part of the mine void

investigation.

2 . S . I Work Plan Scope

o IT Task 1'S

o IT Task 17

o IT Tasi/ I f l

In the location selected for monitor wellCluster 3 use mud or air rotary drilling tech-niques to drill up to 5 pil-^t holes to locate asine void for investigation.

A f t e r locating the void» install a series ofborings (up to ten) on either side of the p i lo thole in an east-west and north-south d i rec t ion ,spaced 5 to 10 feet apart. These borings willbe drilled wi th air or mud rotary (see BoringProcedures of Section 4 - Field Program for adetailed description of the procedures to beused for this task).

Grout back all borings (above mine voLi» to thesurface except for the pilot hole selected forinstallation of the deep we 1.1 at monitor wellCluster 3.

2 . 5 . 2 Deyla_t ions J^rom Proposej_j?cope

A general description of She Kline void investigation is provided since

the actual work was different than what was outlined in the IT Corpora-

tion work plan. figure 2-7 shows the location of the .-nine void borings.

2-32

005046

2-3 3

005047

ZT drilled the fir^t boring MVB-1 in the general area where Well Cluster

3 was to b<; located (see IT Work Plan-Phase V). They found a mine void.

Ground water p^rltally fllied the void zone. IT later installed the

deep rtonitur well for Cluster 3 (W03D) In this first borehole.

The second mine void boring (HVB-2) vaa off-net 20 feet to the south ot

the first boring and a small amount of coal vas found. No mine void was

encountered in the boring.

At this time, IT deviated from the work plan as they did not of fset the

next boring on either aide o( the pilot hole. IT stated they thought

there would be nore benefit to the project if they moved to a different CMarea completely, since a void had been found with the first boring. The K^

next boring MVB-3 was located in the cr fs i te area approximately 100 feet

to the northwest of MVB-1.

000-00

The next mine void boring, MVB-^i, was drilled in an entirely different

area than the first three. This area was later identified as Well

Cluster 5. The shallow monitoring well for Cluster 5 CMW105J way

eventually installed in MVB-4.

The rest of the mine void borings installed during the fourth 10-day

wcr'< period (April 2S-May 7 ) were in a different location in the offsite

area just north of Well 09B as indicated on Figure 2-7. These borings

were designated ^'3-5 through MVB-II. These borings were o f fse t 20 feet

fror. one another in a pattern si:nil.ar to that described in the ori.gi.nal

vor'-' plan.

The final set of (pine void borings were installed during the f i f th 10

day work period by IT drillers 'May 1 2 - 2 1 ) . This set of additional

borings, a continuation from t'ne previous work period, were drilled in

the northwest of fs i te area just beyond the north fence line. The fifth

mine void boring was offset to the north. Figure 2-7 depicts these

additional mine void borings as MVB-12 through MVB-16,

W2"'. OTI 2-3^

005048

In summary, four d i f ferent areas o f f s i t e were investigated instead c6 a

single area, which was outlined by the IT Corporation work plan. The

investigation in two of these areas consisted of only a single bor ing.

The sine void investigation is described on pages 40-51 in the f ieldlogbook.

2 . 5 . 3 Observations

IT Tasks16-18

A brief description of each mine void boringis provided to sumr.arize what was found in iheI'l borings.

^[YB-I - This mine void boring was located atCluster Well 3 as indicated 11 the IT workplan. From 0-10.5 fee1, overburden material •-•asfound. FrOKi 10.5 to ^0 feet the shale bedrc=kwas d f y . Wa te r vas found in the borehole at 60fee t . A iiiine void vas located between 66-"!.f ee t . The IT site geologise used the followlr.gcriteria for identifying the extent of a minevoid ^

Stead^' dril l ing to d sudden drop of f-edrill ro^.

— Ra-eatabl l^hing drilling in solid siateria...

The vertical extent of the mine void wgg^atLmate ' i to be approximately 5 f ee t . Grou'-.ri-w^ter was f i r s t found at 60 feet and wa'3i d e n t i f i e d between 60-71 f e e t . The IT s i t egeologist had the drill crew core below themine void f rom 71-75 fee t , where shale wa-irecovered. IT decided later to install Wel lC-3-D (MW103D) in this boring.

MVB-2 - This mine void boring was o f f s e t 20feet south of MVB-1. The f i rs t 13 feet of th isboring wa.-: overburden mater ia l . Moisture wasfound at 60 feet in the boring. Coal waaencountered at 67 feet . Not enough coal wasrecovered to take a sample making it d i f f i c u l tto predict the actual thickneaa of the coalseam. The site geologist had the drill crewcore f rom 67.5 "71.5 feet. No mine void wasfound in this boring.

WZ^.PT! 2-35

005049

MVB-3 - The boring uas located in the offs i teAraa northwest of the site. Clay overburdenmaterial was foand in the boring from 0-9.5feet . The first sign of moisture in the bore-hole was found at 70 feet . Water was flowinginto the hole at 72 feet and there was a minevoid between 73-74 fee t . Another series ofvoids were found between 74-79.5 feet. Thiswas determined by the IT site geologist as heobserved the criteria for establishing a minevoid. The drill/drop sequence was observedseveral times in this boring.

KVB-4 - The boring was located offs i te , northof existing monitoring well 04 and 50 feetnorth of MVB-1. From 0-6 feet the boring wentthrough overburden material. Moisture was ^found in the hole f rom 15 to 35 feet . The hole 1produced water at 40 feet . A mine void was CQfound between 80-83 feet and drilling was ^stopped. This borehole was the only one of ail —of the mine void borings to identify water inthe bedrock above the coal seam. Monitor ing ~well C-5-D (MW104S) was later installed in thisborehole.

0

MVB-5 - This was the beginning of a series ofborings in the o f f s i te area nor th of monitoringwell O ^ B . Overburden was found in the boreholef rom 0-15 feet . Shale was encountered at 15feet into the boring. A niine void was locatedf r o m 47-54.5 feet . The site geologist for ITsaid there way an hydrogen sulf ide odorpresent. Water was not encountered in theboring. IT returned two days a f t e r the boringwas completed and photographed the hole bylowering a camera on a PVC pipe into the hole.Copies of the photos were provided to theoversight representative.

MVB-6 - The boring was located 20 feet south ofMVB-5. Clay overburden way found in the boringbetween 0-15 f ee t . Shale was encountered at15 fee t . A mine void was found betwen 43.5 -47 .5 feet . The borehole remained dry, no waterwas found . This borehole was also photographedby IT and copies provided to the oversightrepresentative.

MVB-7 - The boring was located 20 feet south ofMVR-6. Clay overburden was found in the hole

2-36

005050

between 0 and 16 feet.. The shale layer s ta r tedat 16 fee t . Coal was found in the borehole at41 fee t , The boring was cored and the coalseam was cont inuous between 41-48 fee t . The ITsite geologist took a split sample of the coalfor EPA. The oversight representative Labeledthis sample MVB--7.

MVB-8 - This boring was located 20 feet southof MVB-7 and had overburden between 0-20 feet.Shale was encountered at 20 fee t . At 40-45feet there appeared to be a mine void or atleast some kind of d i s tu rbance at this depth.This was determined by the [T site geologist.The borehole was dry and no water was found.

MVB-9 - This boring, located 20 feet south ofMVB-8, was the f a r thes t to the south andclosest to the pit area. The boring went to 22feet where the dr i l l ing became d i f f i c u l t and ITdecided to discontinue the hole at that t ime.Trash-like material and wood scraps werebrought up from the hole.

MVR-lO - The boring was located 20 feet east ofMVB-8. Silty clay and refuse along with woodscraps wre found from 0-10 fee t . From 10-15feet in the borehole overburden mater ia l wasfound. At a dep th of 40-42 feet the dri l l ingbecame easier and sample re turns were lost. TheIT site geologist thought that a mine voidstarted at approximately 38 f ee t .

MvB-11 - This boring was located 20 reet westof MVB-8. In this boring silty clay was foundup to 17 feet . At 36 feet the dri l l ing becameeasier and the IT site geologist identified amine void between 36-42 feet . Specific mentionwas made by the IT site geologist that thisvoid was clay filled baaed on observation ofthe dr i l l cut t ings .

MVB-12 - This boring was located approximately160 feet east of the west fence and about 50feet no r th of the north fence. From 0-1.2 feetdry overburden material was found. At a depthof 1-2-51 feet shale was present. A mine voidwas located between 51-55 feet and was dry. ITCorporation took picturea of the borehole bylowering a camera attached to a PVC pipe intothe hole. Copies of these photos will he madeavailable if requested by EPA.

005051

'<VB-l3 - This mine void boring was o f f s e t30 feet south of MVB-12. The f i rs t L 2 feet ofthe boring waa a dry overburden material . From12-50 ffiet shale was present in the borehole.A mine void was located between 50-59 feet andwas dry. While drilling MVB-13 air was blownback out o£ the hole at MVB-12. This wouldindicate that the mine vcid was continuousbetween these two boreholes,

MVB-1^ - The boring was located 50 feet west ofMVB-13. From 0-12 feet a dry overburdenmaterial was found. Shale was found in theborehole from 12-51 f ee t . A mine void wasfound at a depth of 51-56 feet and waa dry. ITtook pictures of this borehole and copies willbe made available on request.

WB-15 - The mine void boring vas located 50feet west and 30 feet south of MVB-14. A dryoverburden material was located down to 1.4feet . Shale was encountered f rom 14-42 f e e t ,This -naterial was dry. A coal seam was locatedat '•2 feet and the coal was cored f rom 43-46feet with good sample recovery. The coal wasdry. IT did not sample the coal, but saved thecoal core. No mine void was encountered inthis boring and drilling was stopped at A6f ee t .

MVB-16 - The boring was located 80 faet east ofthe east fence and 140 feet west of M V B - L 5 .The f i r s t 13 fee t was overburden materi?.! whichwas dry. Shale was encountered f r o m 13-54feet . Coal was encountered at 54 feet where thedri l l ing crew began to core. The coringstopped at 55 feet where a dry mine void wasfoucid between 55-62 feet . The drill cut t ingsf r o m the mine void looked like dark black shalewith nieces of coal mixed in.

concluded the mine void investigation for IT Corporation.

2-38

005052

2.6 INSTALLATION OF MONITORING TO-LS

There were five additional clustery of moni tor ing wells installed ac the

site to collect water quali ty data and to define site geology and hydro-

logy. Cluster 1. WW-102S and MW-102I. adjacent to exist ing well 01, waa

intended to measure vertical hydraulic gradients and communication, if

any, between shallow and deeper r.onea. Shallow and deep wells wereinstalled at two clusters in the fill area - Clusters 2 and 4. Moni-

toring wells W-IOOS and "W-IOIS, shallow wells, were designed to docu-ment water levels and hydrologic propert ies of the f i l l . The deeper

wells at these two clusters, MW-1000 and MW-IOIO, were to document

whether leachate from the f i l l had migrated to underlying sediments/

bedrock and/or to document the existence of a hydrologic barr ier to

vertical flow. Veils were also installed In two clusters nor th of the

site. Clusters 3 and 5. At Cluster 3 three wells were installed. The

shallow well, MV-103S, was Installed to examine the character is t ics of

the shallow, weathered sediments dowgradient f r o m the site. The inter-

mediate depth well, MW-103I, was to examine the section indicated ao dry

In the RI report. The deep well, W-L03D, was completed In the mine vo id

and was intended to examire the mine hydrologic proper t ies and water

qual i ty . Shallow and deep wells, MW-WS and MW-104D. were installed at

Cluster 5. Their purposes were similar to the shallow and ee? weLls

Installed at Cluster 3. T^e locations of these moni to r ing wells are

shown in Figure 2-3.

2 . 6 . 1 Work Plan Scope

IT Task 10 Install Monitor Wells at Cluster 1 .

a. A ahallow A-Inch diameter well into thef i r s t saturated zone at an approximatedepth of fo r ty feet with the bot tom 20 feetscreened.

b. A deep 4-inch diameter (double-cased) wellat an approximate depth of 70 feet with th^bottom 20 feet screened.

68520.OTI 2-39

005053

FIGURE 2-8MONITORING WELLSINSTALLED1WC SfTEPRP OVERSIGHTTECHNICAL MEMORANDUM

005054

[T Task 20 Install Moni tor Veils at Clusters 2 and 4 .

a. A shallow 4-Inchbottom of the fillfeet screened.

dLa.-neter well to thearea with trie bottom 20

IT Task 21

b. A double-cased 4-inch diameter well intothe format ion below the f i l l a rea .

Install Monitor Wells at Cluster 3

a.

b.

A shallow 4-inch diameter well into theupper weathered portion of McAlester Shaleat an apptoxL-nate depth of f i f ty feet wi^.hthe bottom 20 fstit screened.

Install an intermediate ^epth 4-inch dia-meter double-cased well at an approximatedepth of 80 feet wi th the bottom 20 fee tsc ceened.

c . A 6-inch monitor well, with ascoping screen, into the mineat an approximate depth ofscreened in the mine void.

•'4-inch tele-void system

90 to 150 feet,

IT Task 22 Install Monitor Wells at Cluster 5.

a. \ shallow 4-inch diameter well into theweathered por t ion of ^cAleater ^bale a? anapproximate depth of 50 feet with thebot tom 20 feet screened.

b. A 6-inch monitor well, w i t h a --inch tele-scoping screen into the i .- ine void systeti atan appro ixmate depth of 90 to 150 feet ;screened in the nine void .

1 . 6 . 2 ^eviaticna from Proposed Scope

The installation of the monitor wells was slow at rhe start because IT

Corporation used the (CKE-75J drilling rig from Southwestern Labor-

atories. Some of the shallow wells were installed 'ising this equipment.

but the rig could not drill through the bedrock to install the deeper

wells. Cluster I proved very time consuming for the drillers. As it

005055

turned oat , the deep veil W-IOZ, could not be completed by the small

auger rig. The deeper wells needed to be Installed by an air dri l l ingtvpe r i f t . IT Corporation brought in their own drilling crew and rig tofinish the well InstalL^t ions.

Aside from veil installation being slowed initially and IT having to get

another drill crew to complete the project , there were no major devia-

tions from tii£ work plan.

During well installation in the mine voids, there way a alight change inprocedures. The work plan called for installat ion of 6-inch rocnUor

0wells at W 103 and Hk' 104. The diameter of the well was reduced f rom 6 .<^rinch to 4 inch. IT Corporation did not feel that 6 inch wells would ^Qimprove the intended results and the casing mater ia ls for 6 inch wells 0^

0were not readily available.0

2 . 6 . 3 Observations

0 IT Task 1Q The moni to r ing well installations at Cluster Ibegan during the second 10 day work period.Work was completed dur ing the thi rd 10 day workperiod.

IT Corporation star ted out by t ry ing to installthe shallow veil (MV 102S) at the locationshown on Figure 2-3 dur ing the second 10 daywork period (March 31 - April 9 ) . The dr i l l ingwaa being done by Southwestern Laboratoriesusing the (.CME-75) rig and supervised andlogged by Geraghty & Miller ,

Af ter a few days of hard drilling IT Cocpora-t ion determined that the bedrock way too hardto drill with the rig on hand. The hole wasdiscontinued at 30 fee t .

IT Corporation switched drilling crews duringthe third 10 day work period (April 14-23) toinstall the wells at Cluster I. The drillingcrew was f rom IT and they used their own(Gardner-Denver 1500) drill rig. This waylarger than the previous rig froy. SouthwesternLaboratories and was set up for air drilling.

W20.0T1 2-42

005056

The Task 19 wells were completed during thiswork period. The bot tom of the screen for theshallow well was set at 40.5 feet; the bot tomof the screen for t^e deep well vas set at 75 .5f e e t .

During the second 10 day work period ('•'arch 31-April 9) the drill crew f r o m SouthwesternLaboratories encountered d i f f i c u l t y t ry ing toaccomplish Task 19. The crew was moved toCluster 4 (Task 20) where the shallow well wasinstalled. The bo t tom of the well screen wasat 20 feet .

From MW-100S the Southwestern Laboratoriesdrill ing crew moved to Cluster 2 and installedthe shallow well. The bo t tom of the screen wasat l.'5.5 fee t .

Dur ing the third 10-day period work continuedon Cluster 2. The ou te r casing for the deepwell was set dur ing this work period but thewell was not installed.

The outer casing and well casing fo r the deepwell at Cluster 4 was also installed dur ing thethird 10-day work period. The p ro tec t ive metalcasing was not placed over the well b e f o r eleaving the site at the end of the work period.This well was finished dur ing the f o u r t h 10 daywork period (April 2^ - May 7 ) .

All well installations d u r i n g Tasks 19 and 20ware supervised and logged by a representa t ivef r o m Geraghty and Miller , the GroundwaterConsul tant fo r IT Corpora t ion .

The remainder of the moni tor ing wells wereinstalled by the drill crew f rom IT Corporationwi thout incident during the f o u r t n 10 day workperiod (Apri l 28 - ^ay 7 ) .

The following wells were installed dur ing thefour th 10 day work period:

— MW 101 deep well (Cluster 1)

~- MW 103 shallow, intermediate, and deepwells (Cluster 3)

•-- MW 104 shallow and deep wells (Clus ter 5)

2-43

005057

A representative f o e Geraghty and Mil ler waaonsite to supervise and log the well install-ations.

Table 2-3 lists pert inent data related to the m o n i t o r i n g wel ls instal led

during the field investigation.

TABLE 2-3WATER LEVELS FOR MONITORING KELLS

Cluster^»esiKnat ion

Cluster 1C-l-Sc-l-n

Clus te r 2C—t .—Sc-2-n

Cluster 3L> ~ .J"'Oc-3-ic-3-n

Cluster 4C-4-SC-^-D

Clus te r 5C-5-Sc-5-n

(void)80-83

Monitoring WellDesignations

102S10-21

101Sin iD

103S1031103D

100Sloon

lo^s1.04D

DrilledTo

De p th( E t J

40.575.5

2243 .5

305067

2 4 . 55R

4283

W a t e r Levelt .?t)

19.5619.34

12.:^37.58

DryDry62.09

16 .4240.35

3 5 . b 756.31

ScreenInterval" ( E t ) ^

0025-40 0^55-75Q

0

y . ^ - i 9 . 533-43

L^- ' JU40-5057-67

10-2044 .5 -54 .

Z/-'+275-83

(I) Water levels were measured by IT Corporat ion on May 6, 1987apd are s^iven in f t below the top of the PVC veil pipe.

68520.OT1 2-44

005058

2 . 7 HYPROLOGIC TESTING PROGRAM

Wells Installed durinp, the investigation were to be tested to develop

estimates of aqu i fe r propert ies . The pump tests were tc use e i therelectrical submersible pumps or bail ing. If the well yields were very

low, a specially designed a i r l i f t pump was used. Pr ior to conducting a

test. the veil was pretested to endure that the correct size pump was

used to maximize the drawdown but not break suction for the duration. o£the test.

Grundfos stainless electrical submers ibie pumps , which were cleaned

a f t e r each use with a weak acid solution followed by distilled wa te r ^

rinses, were used. All rinse waters were to be stored in 55 gall'in "COdrums or the contaminated water storage faci l i ty . Due to expected low0^

flow rates from the shallow sediments and possibly from the in te rmedia te —

sediments/bedrock as well, a Grundfos SPl-9 pump was to be used as the 0test pump. This pump has a maximum discharge o£ 7 gpm at total head of

100 fee t .

Pump tests were proposed at each of the f ive well c lusters , Figure 2-9.P.ach well cluster was to have a pump test conducted that was specif ic to

that c lus ter . The objective of the teats at veil Cluster 1 was to

measure vertical gradients and communicat ion, if any, between the

shallow and deeper zones at the nor thern end of the site. It was

anticipated that the shallow well probably would not yield s u f f i c i e n t

f luids to conduct a sustained pumping test; t he re fo re , a bailer test was

to be conducted on this well a f t e r s ta t ic water level measurements and

water qua I4 ty sampled were obtained. The work plan indicated that an

a i r l i f t pump might also be used to run a longer test.

The deeper well at Cluster 1 was to be tested a f t e r the completion of

the bailer test. It was anticipated that this teat would probably

require the use of an air l i f t pump or a bailer, aince the sediments/

bedrock in which this well was completed would be capable of low-yieldonly. Water level measurements covering the duration of the teat were

to be made in the deep well, the shallow well MW-102S and the existing

6fl520.0Tl 2-45

005059

005060

Mon- 'or Well 01. During the pump test the discharge was to be directed

to 55 gallon barrels. Field pH and conductivity measurements were to bemade every 10 minu te s for the f i r s t hour . then at half hour intervals to

the completion of the test.

At onsite Clusters 2 and 4, a pump test was to be conducted in the

shallow wells completed in the fill materials . During the pumping of

each shallow well, water level measurements were to be raade in the

pumped well and the deeper well of the cluster. Bailer tests or a i r l i f ttests were anticipa 'ed in the deeper wells completed beneath the ''ill,

since it is antictpatec1. that they would contain little or no water . Theremoved fluids were to be stored in 55 gallon barrels.

At o f f s i t e Cluster 3, a bailer teat or a i r l i f t test was to be conducted

on the shallow and intermediate monitor wp.lls as it was an t i c ipa ted that

these wells would be completed in low yielding sediments.

2.7.1. Work Plan Scone

IT Task 23

IT Task 24

Complete pump test on selected wells .

a. During each pump test the conductivi ty andpH of the water removed will be mon i to r ed .

b. during each pump test the other wells inthe cluster and any nearby exist ing moni to rwells (Well 01 at Cluster I and Well 05 atCluster 3} will he monitored for waterlevel changes.

c. At the completion of the pump test , collecta water sample for Laboratory analysis.

Survey in all moni tor well and boring locationsand well elevations (both new and existing)which are used in this study. ^

2 . 7 . 2 Deviations from Proposed Scope

The first deviation From the work plan occurred when IT Corporation and

Geraghty & Miller decided not to conduct a pump test at Cluster 3. The

68520.OTI 2-47

005061

deep well at this cluster was loc^r-sd in a mine void and it -/ray decided

that the large amount of water produced by the test would not bepractical for storage onsite.

Although it was not a deviation from the work plan the moni tor ing for

water level changes during each pump test could have been expanded.

Tluring the pump teats the other wells in the cluster as well as any

nearby existing monitor wells were to be moni tored for water level

changes or evidence of drawdown. Water level changes in other nearby

we LIs were not checked. An example would be moni to r ing the changes at

M ^ 09 or other contaminated wells to see if there were hydrologic inter-

connections when pump teats were performed in the nearby well Clus ter 2 .

2 7 .3 Observations

o IT Tasks23 & 24

Complete pump tests on selected wells.Geraghty and Mil ler , g roundwate r consul tants ,were onsite to conduct the i-iydr'ilogic test ingprogram. The following '.eats wee 3 p e r f o r m e d onsome of the wells installed d u r i n g the f ieldprogram.

0 P re-Test - A fou r hour pre-test was per-formed in steps on wells that were to bepumped to de te rmine the pumping rate priorto a pucp tes t ,

0 Bail Tast - The bail test required theevacuation of the water f rom the well asfas t as possible and the moni tor ing of itsrecovery for 3-15 hours. This was done onwells that did not produce enough water f o ra pump test.

Pump Test - The pumping rate determined inthe pre-test was used to set thy pump. Th&well way pumped foe 12 hours and recoverywas monitored for the next 12 hours. Waterlevels were monitored in wells in the samewell cluster as the well being pumped.Adjacent wells outside of the cluster wherethe well was being tested were notmonitored.

005062

The tea ting lasted the fu l l 10 days of the f i f t h work period (May

12-21). The following table l iyts the tests performed and the wells in-

volved in the test.

Results were not ava Liable from these well tests. Ceragh ty & Mil ler

wanted to review the data and results before making it available to IT

Corporation or the EPA.

TABLE 2-4HYDROLOCICAL TESTS PERFORMED

Clusternesignation

C-l-SC-l-I

C-2-Sc-2-n

MW i'no

C-A-SC-^-D

C-3-Sc-3-iC-3-D

C-5-SMW 104S

C-5-D

MonitoringWell

MW 102SW 1021

MW I O I SMW 10 in

W IOCSMW 1000

MW L03SMW 1031:MW 10 3D

MW 104S

Ml-; 1043

Pre-Test

xx

K < °x

(redone)

(1)xx

(Dry)(Dry)- (Located in mine

(redone)

Bail. Test

xx

xxx

x

void - tests

xxx

Pump Test

x

not pe r fo rmed . '

i—^-co0^00

Attempted but not enough water to complete test .

Water levels in the moni tor ing wells were measured by IT Corpora t ion on

May 20. These meaaurements are lifted in Table 2-*3.

2-49

005063

TABLE 2-5WATER LEVEL MEASUREMENTS

(MAY 20, 1 9 8 7 ^

**monitoring Well

MW 10 OSMW 1000

MW IOISMW 1 0 ID

MW 102SMW 1 0 2 1

MW 103SMW 1031MW 10 3D

MW lO^SMW 104n

nepth From PVC To Water(Ceet)

22.30^43.80

15.2038.40

20.0 (approximate.)20.0 (approximate;

DryDry6 2 . 4 3

3 5 . 8 55 7 . 6 7

Stick L'ps( r e e t )

2.802.80

2.702 ,80

3.103.20

2 . 7 02 . 4 02.10

2. 702 .20

* Water level lower than normal because of react ion to pumping tes t .

** S t i c ^ u p = distance f rom ground to top of PVC well caaing.

6.3520. OH 2-50

005064

2 . 8 M O N i r O R l M G WELL SAMPLING PROGRAM

The sampling of r.onitoring wells at hazardous waste disposal sites is a

cr i t ica l ly Impor tan t ope ra t ion . The analytical resul ts obtained from

the samples and cbe subsequent decisions based upon Che analytical data

are dependent upon the validity of the samples obta ined. The primary

consideration is to obtain a representat ive sample of the ground water

by guarding against mixing the sample with s tanding water in the well

casing and cross contamination by sampling equipment. Figure 2-10 showswells which were sampled at the IWC site.

2.15.! Work Plan Scope

o IT Task 23

o IT Task 25

Complete pump tests on selected wells.

— At the completion of the pump tes t , collecta water sample for laboratory analysis.

Purge existing MonU-or Wells 01. 03, 04, 05,06. 08. 09. 23R. 23S. 38R, 39R and .',OS bypumping or bailing extensively. Dur ing thewell cleanup, monitor the removed water forconduct ivi ty and pK to evaluate whether thewater quali ty (as indicated by conduct iv i ty andpH) has stabilised. A f t e r the purg ing programindicates s t ab i l i ty , obta in a water sample fo rlaboratory analyses f rom each well.

2 . q . ?. 'deviations j[r_oni Proposed Scone

The IT '"orporatlon work plan specifics that 12 of the existing wellswhich were instal led by £PA would be sampled. These are l is ted in the

previous section (2 .8 .1 ) . There were two of these wells that were notdanpled. The f i rs t well, 2 3 R , had a bent casing and it was d i f f i c u l t to

remove the bailer f rom the well . The other well, 23S, was dry and couldnot be sampled.

Two new wells» installed by IT Corpora t ion , MW-103S and MW-103I:, wero

dry and also could not be samp lad.

68520.OT1 2-51

005065

005066

nuring sampling of the wells the work plan called for checking pH and

conduct iv i ty . IT was to uti.ll.ze these readings to check for well

s tabi l i ty d u r i n g purg ing of the well and p r io r to sampling. Typical ly,

pH aiid conduct ivi ty was checked once for each moni to r ing veil. This

occurred dur ing the sampl ing event ind was not used to determine thestability of the wells.

2. fl . 3 Observations

o IT Tasks By prior ag r eeme n C £ T Co rpo ra t io n and t^. e EPA2? & 25 had decided that four exist ing m o n i t o r i n g wells

and all eleven of the new wells would be spli tsampled, LT Corporat ion was provided wi th the "•split sampling requirements and was requested COby the RPM f rom EPA to establish a schedule and 0provide this to EPA so lab space could be Qreserved. This allowed IT Corpora t ion the ^flexabi.l i ty to coordinate wi th Geraghty &Miller to sample a round the pump tests beingc o n d u c t e d . Once the lab space way reserved byEPA for the split samples it could not bechanged.

Four existing uells were split sampled d u r i n g atwo day sampl ing event May 14-15. The fo l lowingexis t ing wells ware split sampled;

—- MW 01"- W 06— MW 098— MW 08

The following new wells were spli t sampleddur ing two days of sampling on May 2^ and 23:

— MW IOOS & IOOD— w mis & I O I D— - MU 102S & 1021— MW 10 3D"" MW 104S & l^D

Two of the new wails were dry and two existingmonitoring wells had to be auh- iCJLtuted . 1'heaewells wore:

— W 03—" MW ^OS

6fl520.0ri 2-53

005067

The FPA split samples f rom the wells were submi t ted to the Cont rac tLab Program (CLP) for the fol lowing analyses:

o Extrac table rirganicso Volatile Organics

o Inorganics - Total Petals

The samples taken by IT Corporation were analyzed at their ownlaboratory.

The following table shows the veils which were split sampled fo r EPA andthe other wells which IT Corpora t ion sampled fo r the i r own analyse?.

c\iinTABLE 2-6

MONITORING WELL SAMPLES COo^o

^oni tor Sp l i t IT Date CWell Existing _New for EPA Sampled ^''^PJ.ed

xxxxxxxxx

xx

xxx

xxxxxxxxxx

xxxxxxxxxxxxxxxxxxx

5 / 1 ^ / 8 75 / 2 8 / 8 75 / 2 9 / 8 75 / 2 8 / 8 75 / 1 5 / 8 75 / 1 5 / 8 75 / 1 5 / 8 75 /29 /875 /29 /875 / 2 9 / 8 75 /20 /875 / 2 0 / 8 75 / 2 0 / 8 75 /20 /875/20 /875 /28 /875 /28 /875 /28 /875 /28 /87

MW 01 xMW 03 xMW O-'i xMW 05 xMW 06 xw oa xMW O P R xW 3RP xMW 39K xWJ 40S xMW IOCS^•J lonnMW 10 isw i oinMW 1.02SMW 1021MW 103DMl-/ 104SMW 104D

C8520.0T1 2-54

005068

3.0 CHEMICAL HATA ANALYSIS OF SPLIT SAMPLES

3.1 SCOPE OF THE SPLIT SAMPLING PLAN

As described In Section 1.3.3 and Appendix A. following the preparat ion

of the PWOS Work Plan, a Supplemental Investigation Sampling Plan was

prepared to establish the number and approximate location of split

samples. A total of 142 samples were proposed to be taken by IT Corpo-

ration and 32 of those samples were proposed to be split with EPA.

Split samples were analyzed to provide an independent check on thequa l i ty of da ta .

l t

3 .2 DEVIATIONS FROM PROPOSED WORK PLAN 'D SPLIT SAMPLING PLAN ln

00Table 3-1 indicates the actual and proposed number and type of samples -^

taken by IT Corporat ion and E P A . While 142 samples were proposed to be Q

taken by IT Corporat ion, ! 52 samples were actually taken. Deviations

from the proposed work plan and the reasons for the deviations are

described in Chapter 2.

0

Thir ty- three samp lei were split with E P A » one more than the proposed 32

fc-plit samples. The location of the split samples also varied. These

deviations are described in Chapter 2.

Table 3-2 indicates the IT Corporation Sample Number, the Location where

the split sample was taken, and a physical description cf the sample.

The split sampling techniques are described in Appendix 0.

3.3 CO^PAJUSON OF RESULTS

The chemical analysis results from split sampling are tabulated in

Appendix D. Separate tables are provided for organic wd inorganicanalyses of vater and organic and inorganic analyses of soil.

Notations are provided on the tables to indicate when the analytical

results of the split samples taken by EPA:

• vary by at least a factor of 10 from the value reported in theHWQS report, or

68520.on 3"l

005069

• Vary such that analysts by one Lab indicates that the compoundor element was either not detected or detected but below thedetection limit (BDL) < h i l e analysis by the second lab indicatesthat the compound or element was at least 5 times greater th'-.nthe detection l imit .

These notations indicate that the var ia t ion in values are too great and

the use of the data may be questionable.

TABLE 3-1PROPOSED VS. ACTUAL WMBER

AND LOCATION OF SA.4PLRS^in

Number of Samples COTaken by IT_Coj-poration EPA Spli t Samples o

Location Proposed Actual Proposed AcuTal (-^

Onsi te Soil Borings ^ 47 3 3 °

O f f a i t e Soil Borings Ul U1 3 3

Trenching Wasce Samples 12 12 8 8

Barrels ( i f encountered} 20 10 2 3

Coal (i" anountered) 1 1 I I

Exis t ing yonitoring W^ 12 10 ^ 6

( 1 ) ( 2 )New ^nitoring ^'ells \\ I I 11 9

Other 9

Ouplicates __ 5

TOTAL K*2 152 32 33

All samples were to be water samples.(2)

Nine water samples, two soil samples.

68520.OTI 3-2

005070

TABLE 3-2

SPLIT SAMPLES AT IWC

IT CorporationSarrple No.

Location/Depth Descr ipt ion Date Shipped

SOIL BORINGS (QNSITE):

B-109 Area B Onsite14-19 feet

B-113 Area C Onsite5-10 feet

B-134 Area A Onaite0-3.5 feet

SPIL BORINGS (OFFS[T£):

B-U6 Far west side ofsite in o f f a i t earea 0-4 f ee t ,

B-130 Offsite boringnorth of siteIn middle, *i -1 2 . 5 feet

B-125 Offsi te boringnorth of site bycoal pile0-5 feet

3-23-87

3-23-87

Soil way dark withodor present.

Soil looked clean andwas dry .

Soil material was black. 4-9-87

Soil was dark and pa r t s 3-23-87looked like coal spoils.

Soil sample looked like 4-3-87it contained some coal.

Soil sample appeared to 4-3-87contain sorae coal.

COAL:

MVB-7 ^ine voidBoring 741-48 feet

Coal

C-l

C-2

C-3

C-4

A8520.0T1

ME section ofTrench T-l about0-5'

SW section ofTrench T-l about0-5(

Middle of TrenchT-l abouC 0-3'

Middle of TrenchT-l about 5-10'

Dark brown and blacksoil* Strong odor ofgarbage.

HNU 10-15 ppm. Soil hadblack material visable.

Soil contained darkblack material

Soil contained darkbrown material3-3

3-26-87

3-26-87

3-26-87

3-26-87

005071

TABLE 3-2 (Continued.)SPLIT SABLES AT IWC

IT CorporationSample M o .

East end ofTrench 6

A-1

Middle ofTrench 6

A-2

West end ofTrench 6

A-3

West end ofTrench 6

A-4

Location/Depth Descr ip t ion

The soil was sampledfrom material that vasexcavated by the backhoetaken out of the shovel.

The soil was sampled frommaterial that was excavatedby the backhoe taken outof the shovel.

The soil was sampled frommaterial that was excavatedby the backhoe taken outof the sho'/el.

The soil was sampled frommaterial that was excavatedby the backhoe taken outof the shovel.

Date Shipped

4-14-87

4-17-87

4-17-87

BARRELS:

Trench C SW section ofnrun I Trench T-I about

0-5' f rom cr^aheddrum.

TrenchADrum 1

TrenchADrum 6

'^rFmndwa t e r

KW 01

^W 03

South end ofTrench 5

West end ofTrench 6

South Part ofsite

Offsi te north ofsite boundary

Pliable mater ial likedried paint. Smalll ight green beads.:)rLed foam mater ia l .

Gray powder mater ia l

Light pink and yellowaolid material.

Existing w'ell

Existing Well

3-26-87

4-22-87

4-22-87

5-14-87

5-28-87

005072

TABLE 3-2 (Cont inued)SPLIT SAMPLES AT [WC

f T Corporation location/Sample No. Depth Description

MW 06 Upgradient , south Exist ing Wellof site

MM 08 Located tn north Exist ing Well.central part ofa i te

MW 09B Located j u s t Exis t ing Welleast of the northcentral part ofaite

MW IOOS Located close to Mew WellMW08

MW 1.000 Located close to New WellMW08

t O l S Located close to ^ew WellMW 093

I O I D Located close to New WellW 09B

MW L02S Located in south New Wellpart of site inthe vicinity ofMW 01

MW 1021 Located in south New Wellpart of site inthe vicinity ofW 01.

MW 103D Located of fs i te New Wellnorth of thea i te boundary inthe vicinity ofMW 04

MW 104S Located o f f s i t e Mew Wellnorth of NW 04

MW 104D Located offs i te Mew Wellnorth of MW 04

68520.OT1 3_5

005073

Of the 33 split samples taken, results could be compared for only 29

split samples. Reasons for the differences in the number of split

sampling analyses results are:

o Soil samples numbered 1, 2» 3 and A from Trench T-l were splitby EPA, but results from IT Corporation included soil samplesnumbered 2. 4, 5 and 6 from Trench T-l. This means IT took atotal of six soil samples and only numbers 2 and 4 can becompared with the split sample data.

o Sam-pies were split for d r u m I of Trench C by the EPA. ITCorporation did not analyze th is sample so no data isavailable to compare.

CDmCONo laboratory quality assurance (OA) data of samples collected by IT o

Corporation was provided to ^lack & Veatch, therefore , the sample /--*results were not checked against the OA data. Significant addit ional 0

tine and e f f o r t would be required to check the split sample results

aaainst the QA d a t a .

Addit ional discussions comparing data according to site medium (soil and

water) and inorganic and organic analyses follow.

3 .3 .1 Kater .

3 . 3 . 1 . 1 Organic Analysis . EPA samples were analyzed for all compounds

indicated in Table D-l (Appendix D) . IT Corporation samples were

analyzed for all compounds listed in Table n-1 except I,2-dichloro"

ethane; 2-methylphenol; 4-methylphenol; phenol; and benzoic acid. Of

the 435 pairs of data points which can be compared, only 4 pairs fall

outside the established limits of variability. These 4 pairs of data

po'.nts are all in the sample from MW-09B. Therefore , only about L

percent of the reported data has a low degree of comparability. The

split sar.plcs in general indicate that the same contaminants are present

and in the same order of magnitude.

3.3.1.2 Inorganic Analysis. Both EPA and IT Corporation samples were

analyzed far all inorganic elements listed in Table D-2 except tin which

fi8520.0Tl 3-6

005074

was not analyzed for tn the XT Corporation samples. Of the 322 pairs of

data which can be compared, only 17 pairs of data fal l outside the

established limits of variability. The remaining 95 percent of the data

have a high degree of comparabil i ty. The split samples in general

indicate that the same contaminants are present and in the same order of

magni tude .

Of 17 pairs of data which have a low degree of comparabili ty, 7 pairs

are analysis of iron and 5 pairs are analysis of a luminum. The

remaining 5 pairs of data with a low degree of comparabil i ty are

scattered among d i f f e r e n t samples and d i f f e r e n t elements. In each /^

instance when comparing the 17 sets of this data , the EPA data indicates 1T\a higher value than the IT Corporation data . ^0

0^r->

3.3 .2 Soil Q

Data from split samples of soil or solid material normally vary more

than data from split samples of water because water samples generally

has 10 re un i fo rm character is t ics than soil, Soil samples included

samples of solid materials from soi-L borings, barrels, open excavation

trenches and mine void borings (coal ) .

3 . 3 . 2 . 1 Organic Analysis. EPA samples w'ere analyzed for al l compounds

indicated in Table D-3. IT Corporation samples were analyzed fo r all

compounds listed in Table D-3 except 1,2-dichloroethane; 2-methylpheno1;

•ii-aethylphenol; phenol; and benzole acid. Of the 449 pairs of data

which can be compared. 31 pairs f a l l outs ide the established l imits of

variabili ty. Therefore, about 7 percent of the pairs of data have a low

degree of comparabi l i ty . The remaining 93 percent have a high degree of

comparabil i ty. The split samples in general indicate that the same

contaminants are present and in the same order of magnitude.

In 16 of the 31 pairs o£ data with a low degree of comparability, com-

pounds were detected in the EPA sample which were not detected in the

68520.OT1 3-7

005075

FT Corporation sample. The major i ty of the remaining 15 pa i rs of data

indicate that the compound was found in both samples bu t in quantit ies

that varied by an order of magnitude. Of the 31 pairs, 8 pairs are from

analysis of rotal xylenes and 4 pairs are from analysis of toluene. The

remaining 19 pairs of data are scattered among d i f f e r en t compounds.

Table 3-3 indicates how the data with a low degree of comparabil i ty is

divided asong the various types of soil samples.

TABLE 3-3DISTRIBUTION OF ORGANIC DATA

WITH A LOW DEGREE OF COMPARABILITY 0ACCORDING TO SAMPLE TYPE \c

CO0^

lype of ScU No. of Total No. Data Points with < )Sample Samp Ie s of Data Pairs High Variability Percentage /-.

Soil Borir.g 6 180Barrels 3 60Trench 8 180Mire Void 3oring I 29

68

161

3.313.38.93.5

TOTAL 18 449 31 6 . 9

3 . 3 . 2 . 2 anorganic Analysis . EPA samples were analyzed for the 24

elements indicated in Table D-4. IT Corporat ion samples vere analyzed

f o e the fo-l-oving 13 elements:

AntimonyArsenicBerylliumCadmiumChromiumCopperLead'-'ercury

« Nickel« Selenium• Silvera Thailium• Zinc

68520.OT1 3-8

005076

Of the 195 pairs of data which can be compared, 41 pairs of data fa l l

outside the established limits of var iabi l i ty . There fore , for the in-

organic- soils data, 21 percent of the reported data has a iow degree ofcomparabi l i ty .

Of the 41 pairs of data with a low degree of comparabi l i ty , 9 pairs

occurred when comparing bery l l ium, 6 pairs occurred when comparing

arsenic and 5 pairs each occurred when comparing antimony and copper.

Table 3-4 indicates how the data with a low degree of comparabil i ty is

divided among the various types of soil samples:

TABLE 3-4D I S T R I B U T I O N OF INORGANIC DATA

WITH A LOW DEGREE OF COMPARABILITYACCORDING TO SAMPLE TYPE

Type ofSoil Sample

Soil BoringsBarrelsTrenchesMine Void Boring

No.Samples

of

638I

Total No.Data Pairs

78267813

DataHigh

PointsVar iabi l i ty Percentage

124

178

with

15.415.42 L . 861.5

TOTAL 18 195 41 21

Study of the inorganic analysis of soil samples indicates that the

degree of comparabili ty follows more of a pa t t e rn than the other

a^alyses. Four of the 13 elements analyzed contain a inajority of the

data with a low degree of comparabil i ty and the mine void boring (coal )

sample analysis contains a high percentage of data with a low degree ofcomparability.

6SS20.0T1 3-9

005077

•'(.0 GENERAL COMMENTS AND SUMMARY

4.1 UNRESOLVED ISSUES

Drill cu t t i ngs , protect ive clothing, and some Liquids derived from the

supplemental investLgatIon require disposal bat are current ly stored

onsite in 55 gallon drums. Oecontamination water is stored onsite in

tvo frac tanks. The total volume of water which needy to be disposed of

is approximately 30,000 gallons. IT Corporat ion took samples of the

decontaninatton water to determine what type of disposal will be

required. OJ'.0CO

A.: DISCUSSION OF TECHNIQUES

0^ . 1 . 1 Health ;-.nd Safety Q

IT Corporation was responsible for ita employees health and safety on

the IWC site. Although strict procedures were out l ined in the Health &

Sa fe ty Plan for IT Corporation, they were not always fol lowed. Certain

events took place that caused EPA to advise to IT Corporat ion that these

events could result in possible adverse e f f e c t s to their employees.

The f i r s t time that EPA advised IT Corpora t ion on health and safety

concerns was at the start of trenching act ivi t ies in Area C. The RPM

and the EPA oversight representat ive questioned IT about the personnel

projection they had provided the backhoe operator who dug the trenches.r?.\ suggested to IT that the operator should have a respirator or escape

pack available in the event that high concentrat ions of hazardous sub~

stances were encountered.

The second time that IT Corporation was counseled on health and safety

followed a site visit by the Site Oeotechnical Engineer f r o m Black &

''eatch aa a result of the site visit, the following items were discussed

with IT Corporation;

• The IT geologist f i rs t smelled soil samples then used the KNUto monitor the sample.

ft85;O.OTl 4-1

005078

The HNV became inoperat ive and IT decided not to repair thispiece of e^'ilpment unti l the fol lowing work per iod.

The personnel decontaminationtruck decontaminat ion area;decontaminat ion, they had tocontaminated by the drill rig.

area was located ahead of thethe re fo re , following personnelwalk through areas potent ial ly

Respirators ware available to IT Corporation personnel butwere not carried onsite. The HNU reading for one sample wasgreater than 15 ppm over background which requires Level Bpersonal protection.

IT reviewed these comments with the RPM and took action on some i tems,

but disregarded others. IT Corporation had u l t imate responsibility f o r

their workers protect ion.

^.1.1 Sample Procedures

Every organizat ion has Its own methods f o r accomplishing work. The

procedures used by H that will be addressed here are compared to the

methods tha t EPA requires Its cont rac tors to abide by to ensure that

possible cross contamination or sampled does not occur. The following

procedures were suspect according to EPA ope ra t ing procedures. Thes-3

conmenta or iginated from the EPA oversight representat ive and the Sice

f-eotechnical Engineer From Black & Veatch dur ing the onsite bor ing

program. The cofunents are addressed below under three major items of

work.

Drilling No plastic ground protect ion was providedunder the drill rig to prevent sur face con-tamination due to borehole cut t ings andfluids.

No depth measurements were made as theborings were dri l led. The driller esti-mated depths by Kelley penetration.

68520.OTi 4-2

005079

Soil Samples

ChemicalSamples

The dri l l rig was decontaminated betweeneach ir-ajor area such as between Area A andC; however, the drill rig way not deconta-minated between borings in the same majorarea.

IT did not always indicate on the boringlogs when groundwater was f i rs t encoun-tered.

Boring logs were not prepared onsite as thedrilling was taking place. Ail notes werewri t ten in the site geologist 's logbook andthe drilling logs were made up later .

No split or thin wall tube samples weretaken as indicated in the sampling plan.

No measurement of sample recovery was made.

The CME Sampler was always advanced fivefeet and no catcher was used.

When a sample was lost the dZ inner sampletube was used again without decomtaminatingthe tube.

Samples were bounced out of the inner tubetnto a split PVC pipe which was sometimesused for more than one sample.

Samples were taken wi th a gloved hand, butthe sampler did not change gloves betweensamples.

Samples were visually monitored rather thanwith an KNU or other equipment.

IT was not if ied of these observations at the same time they werenot i f ied about the health and safety concerns. IT took note of these

and changed some of their procedarey, for example during chemicalaanpling '•hey changed gloves before each sample was collected.

68520.OH 4-3

005080

APPENDIX A

EPA SPLIT SAMPLING PROGRAM

005081

B L A C K & V E A T C HENGINEERS-ARCHITECTS TEL. <9l3t 339-2000

t500 MEADOW LAKE PARKWAY

MAILING ADOfteSS PO BOX NO a-tOS

KANSAS CITY. MISSOURI 6*114

CH2M-HILL/EPARFY IVIndustrial Waste Control St te

B&V Project 68520B&V File 3060February 26 , 1987

Mr. Anthony Gardner•JSSPA • Region VI1201 EL"' S t ree t , 28th Floor ^Pallas. Texas 75270 \0

000^

Dear *lr. Gardner : 0

Re: Draft Split Sanpling Memorandum

Encloser* for your review is a aemorandum outlining the proposed splitsao^ling program for the upcoming field investigation at the IWC site.The menorandum wi\l provldt; general guidance to our field representativein selecting the samples which will bo aant Eo the CLP for analysis.

^leaae call nick ^003 or mysel^ if you have any queationa. After yourreview ve will finalize the aeraorandun and finalize arrangenents vit^t'ie ^L°.

Very truly yours.

BLACK & VEAFCH

Civde L. ^utchison

VT*

^nclosur0

cc; Mr. lick ^001^r . John Edwards/Central File

^520.011 A-l

0

005082

B w A C K a V E A T C M

MEMORANDUM

RE" IVIndustrial Waste Control

B&V Project 68520February 26» 1987

To; Tony GardnerEPA Region VI

Fro®: Clyde Hutchtson, Black & VeatchDick Moos. CH2M HILL

Subject: Supplemental Investigation SplitSampling Plan

The contractor for tha IWC Steering Committee, IT Corporation, will beconducting their independent investigations at the IWC site starting in ' "early Marc^. EPA has indicated their desire to ouiain a limited number \0

of split samples during the investigation. The purpose of this memorandum COi9 to identify the number and location of samples, to determine bottle 0s'and paper work requirements and to provide a rationale for sample Qselection to guide our site representative in making field adjustments. _

?PLn SAMPLE SELECTIW

The work plan for the Hydrogeologic and Waste Quantification Study (HWQSJproposes sampling from the following areas of investigation:

ProposedLocation No. of Samples Samples

Existing Monitoring yellsMew Monitoring WellsOn-Site Soil BoringsOff-?ite Soil BoringsTrenching Waste SamplesBarrels ( i f encountered^Coal (if encountered)

121144^212201

^1133821

W 32

The recommendation for split samples from each area is based on pre-li-inary discussions uith EPA (Tony Gardner^ and the members of theproject team (Moos, Hutchlson. Herzog). The primary pu-pose of obtainingsplit samples is to provide an independent check on the quality of data.Thus, split samples are recommended from each area of investigation.The rationale for sample selection in each area is further deaccibedhelcw:

^52Q.^T1 A-2

005083

B L A C K & V E A T C H

MEMORANDUM 2

REM FV B&V Project 68520Industrial Uaste Control February 26, 1987Supplemental Investigation Split Sampling Plan

o Existing Monitoring Wells. Wells which yielded enough water forsamples, and wells where contaminants were found in previousinvestigations will he sampled. The suggested '.ells for samplingare 08, 09B, 38R, and 06.

o New "gnJLtorinj. Uells. Eleven new monitoring wells will beinstalled. A split sample is planned from each well. However,it is likely that some of these wells will not produce adequatewater for sampling. If this occurs, samples from the existing ^wells should be substituted in the following order (if adequate -water is available); ^OS, 39R. 23S, 01. On-site soil samplescould also be subs t i tu ted . (^

0^o 0"-Stt_e_ Soil Borings. Samples are planned from borings in on- 0

site areas A, B, and C identified in the RI report. A split- ospool sample will not provide adequate soil for a split sample.IT Corporation will be requested to push a Shelby tube for thesplit sample to provide adequate recovery. The field represen-tative will use his discretion in determining which samples canhe split based on observed recovery. The goal will be to obtainone split in each of the three areas.

o Of f -S i t e Soil Borings. Three off-sice areas have been proposedfor sampling. One split sample will be obtained from each area.Fielrl discretion will be exercised as in the on-site samples.

o Trenching Waste Sanples. Two areas will be trenched on-site -Area A and Area C. The trenching operation will. make an ade-quate volume of soil available for split sampling. Four samplerwill ^e selected in each trench area for splitt ing.

o Barrels. The work plan indicates that up to twenty barrelswill Se sampled if encountered during the trenching. It issuggested that one split sample be planned for every 10 barrelssampled. However, I? barrels are sampled at least two splitswill be taken.

0 Coal Samples. A split will be taken if coal is encounteredand if there is adequate volume for a split sample. Thissarple is recommended to provide additional informptlon onthe native coal material .

'W20.0T1 A-3

005084

B L A C K a V E A T C H

MEMORANDA 3

REM IV B&V Project 68520Industrial Waste Control February 26, 1987Supplemental Investigation Split Sampling Plan

SAMPLE PROCEDURES

A sample numbering system will be established by the field representativeand recorded in the field logbook. The samples will be taken by IT Corpo-ration samplers and placed in bottles provided by the field representative.Following sampling, it will be the responsibility of the field representativeto complete chain-of-custody paperwork, to coordinate with the contractlaboratory, to prepare the samples for shipment, and to ship the samples, rv^

\0CO

SA^LE ANALYSIS

All samples will be analyzed for the following priority list compounds: a\

o Volatile Organics 0o Extractable Organics 0o Inorganics

This analysis parallels the analysis planned in the work plan with oneexception. The "standard groundwater analysis" to be performed on thewate r samples will not be conf i rmed by split sampling.

IT Corporation has agreed to provide a schedule of field and samplingactivities in early March. The f ield representative will finalizelaboratory scheduling with the EPA Sample Management O f f i c e (SMO) .It will he the responsibility of the field representative to not i fySM^ if there id any deviation from the sampling schedule,

SAVPLE CONTAINER REriYIRE^F.NTS

The sample bottle requi rements for the split sampling program aresurTTiarized in Tables 1 and 2.

^ttle and forms requests will go through the Black & Veatch Regionalequipment Coordinator ( R F C ) , Scott Anderson. According to the REM I"^one Management Plan, the RFC will contact Reth Baruth in Denver tocoordinate for bottle and forms shipment to the on-site representative.Lot nun^ers for the sample bott les will be the same when possible.

6R520.OT1

005085

a _ r t ^ f \ a v t, A i fc; M

MEMORANDUM 4

REM IVIndustr ial Waste ControlSupplemental Investigation Split ^arcpling Plan

TABLE 1SPLIT SAMPLING PROGRAM

B&V Project 68520February 26. 1987

Area of Investigation

existing Monitoring Wells(OP, OQR, 3P?, 06}

New Monitoring Uells

^n-aite Soil Borings

O f f - s i t e Soil Borings

Trenches

barrels

Coal ?ar.ple

No.Sam]

4

1 1

3

3

R

2

i

oflies

VolatileOreanics.,.i i^,-- -•^.^,^—^

1

1

4

4

4

4

4

ParametersExtractableOrganics

2

2

4

4

4

4

4

HeavyMetals

3

3

4

4

4

4

4

0r-CO0^C0

2 x 40 ml ^lass ^ ' i a l R .

1 x 8n 02. Amber c;lass Bott les

1 x Liter Polyethelene.

? 02:. L'irle M o n t ^ '"lass Jar .

68520.OY1 A-5

005086

B L A C K ft V E A T C H

MEMORANDUM 5

REM F7 B&V Project 68520Industrial Waste Control February 2 6 , 1987Supplenental Investigation Split Sampling Plan

TABLE 2BOTTLE REQUIREMENTS

Required No. ofBottle Type Bottles Bottles/Case Cases

^0 ml Class "ials 30 72 1 "'"f~-

80 oz. Amber C.lass Bottles 30 6 6 c0

0^1 Liter Polyethene 15 ^2 1 0

08 o2. Class Jar 5 1 96 I

68520.OT1 A-6

005087

APPENDIX B

PHOTOGRAPHS OF BORING PROGRAM

005088

Drill crew fromSouthwesternLaboratoriesworking on Area Aboring located justnortheast of existingwell MW08.

h"\r-oco^oo

Working or BeringIn Ares A wh^rewastes wcrf suspectedtc be burled.

Boring Prog rain

LOCATION: Area A , close to North Site Boundary, just northeast of existingwell HWOfi. Figure 2-3 in the text indicates the location ofthese borings.

B-l

005089

Boring B116 locatedIn the o f f s l t e areajust west of origin;site boundary. Sot;sample was dark andparts of It lookedlike coal spoils.Depth of sample 0-4feet.

<a-r-COc^00

Boring B l 1 6 wassplit sampled forEPA. Analyticalresults of thissample are found tntables D-3 and D-;-,contained in Appendi?

Boring Program

LOCATION: Boring B 1 1 6 la located offaite in the area just west of thesite boundary. Figure 2-4 in the text indicated the locationfor thia boring.

B-2

005090

Chunks of (petal andpllable-like piateriawere brought upbetween 0-12 feel byauger while drillingB112.

inc-00(

00

Possible mixing pad<nused for -nixing 'Irumsof pa in t wa& brouehtup by augor whi ledrill ing B i l 2 .

."'' "g. PrQEr<'lt^

LOCATION: Area C, onslte boring B 1 1 2 .location for B 1 1 2 .

Figure 2-3 in the cext Indicates the

B-3

005091

B113 looked cleanand dry. Therewere no readingsabove backgroundon HNU. This boringwas split sampledfor EPA at a depth fr^m5-10 feet. The materialwas dark black shale.

r-^Wt . u' ^^^y^^ l ' ' ^^^

^^Q Tw< •^•^w 'lk' i ^^ '^y^WS^S^'^^^ ' ^^^^^^A^^^^S^/^ (^VfY/^^ty^'-*-^^^ ^^« s><-

^r--co0 .00

- "-p 'v1- lt ^^^^§v;?^-^. ,

,^^^^- - ^^^^^^^'^^^^^^ ^fe^^r^^"^r^^^ ' fe^ i-rv s-*.4^ ^^^•^A.-'*"';»' .^^^r^^-

^^'^ > . •S^^^ /^? • '

Boring B.;.'- »a^drilled in-.medistel^after S 1 I 3 -•iT.hoiiidecc-niaffina'irig theequl-pnent. The-sample hcic high •iNi.readings And a str>s' i&odor. Th? ^oilwas moist and ver'-pliable.

Boring Program

LOCATION: Area C. onn i t e boi lnp,a B l ' 3 and B l l / t . Figiire 2-3 in the textIndicates the locations oE these borings.

B-4

005092

IT Corporatlor.puahing shelby tubtfor aacpl« BIAO inauppieaental o f f a l c cboring prograa. Ata depth of 1 footcoal spoils wereencountered. IT tooktheir Baeple at 2 fftet,the HHL reading wasgreater than 1C pp«

r^h-COer'oo

Boring Bi/t: flanplewas ta^en i'. 7 , 1 fetf*.by IT Corporatlcr.Coal and lha^ ipoll?werft found in th*anBpte. Me reading-above bAckgroiiRR w^r»sacorded or. the nyi,

Supplemental Borings

LOCATION: Areas B and D. offaitfc borings B140 and Bl^l, 'ocated In theveatern part of the site. Figure 2-^ In the text indicates thelocation of these borlnga.

B-5

005093

APPEKarX C

PHOTOGRAPHS OF TREHCHIKG OPSRATIOKS

005094

Trench T-l In Area Cwas located aoutheaaof olc impoundaent.Several crushed andpartially crusheddruwa were foundwithin ? feet of th»fturfsce. D i f ferenttypea of solid 'naiarvare found In th»drums. A completedeecripti-or. sf Chl.6trench la gsvenpwpage 2-20. ^

0^00

Trer.chtn^ Ac t iv i t i e s

LOCATION1 Area C t r ench ing , t rench T- i ,the location sf this trerich.

Figure 2-- tr tne text inalcate^

C-l

005095

Pliable material(similar in appearancto dried paint) foundin a drum excavatedfrom trench T-i inArea C .

0COCOa-oo

Dried fear-likemateri^ •"'•'-•"'trench 7-^ ir: Ar&3

Trenching Activtties

LOCATION: Area C trenching, trench T " «the location of thig trench.

Figure 2-5 ir. the text Ir^lcaEea

£—'»"•*

005096

Explorator-y pi*-P-3 located ir. the-west part of site.

COCOC^00

Explora-ccrv trenchesT-3 ar.c l-^.. Tre re-trenches •rfe-- locatedIP. the s^tr-west.part o;' sir.fc ir ':h^background I? pi? -'-Iccstcd Ir; .".rK^ ^

Trenching Ac t ivj_tjles

LOCATION: Pit P-3 Is in west part of site north of Aree D. TrenchesT-3 . nd T"^ <ire In the southwest pflr': of the site-. Figure2-5 In the text indicates the location of these excavations

005097

Trench T-5, AreA A .Drum with dr ied foan-like mater ia l orpa in t . Shaf t r u n n i n gthrough drur'1 apparen t lywas for mixing.

<MCOCO(T-00

Barrel sa^-^ '-'frotr: rrer.c^- T-^pcwder-liKe ^,';':e--i-;.Sample wa^ ^abele.- Tren-A ^ Barre.1 \. T5';...e-D"3 and D-- :,-.Appendix r. ll^" t1-?-ar.alyic^'; ri.'ica frr"-thifi saiT.p-lE-

T^renching Act iv i t j . es

LOCATION: Area A t r ench ing , trench T-5.the location of thia t rench.

Figure 2-5 in the text indicates

C-4

005098

Was te s e x c a v a t e ^frora trench T-6 inArea A. Solidifiedfoam, enisled iru"-^.wood debris and othertrash were fcunc' inthe trench.

r^CO03a-o0

Daring the trenchi.nE-In T-6, IT Con-or^ t ioround about 3C- dr^TS-Scune '-'ere ^Ic,^ ti-tbe SGrrai't •'v;t-lr2 feet' ' a-,c 3tS»-' '"were foun.-: 2^ f'eezdfPF. Ncri- ^ f r thedrunis fo'-ir.r. •>7i3refully ^:- :T . Prigb2-2? ^; tr.- ^o,: de-scrlhep the i'aterl.a2in these drunis. Asplit samplf- for £?Awa? takpr, rtn^ La^^lec'Trench A-West dr'.;r '•;The analytical rebultcf this saiT-ple arecontal-ned •in Appprc f-';D in tables D"3 AndD-^.

Trench inf1, activities

LOCATION: Ar".i A trenrhl'tg. loc'.rited war ronter of trench T-^. Figure2-5 In the text indicates tnc loc.itinn of this trench -

005099

A cr is'--ed p qst icdrufr. was f"'Jr.<i Inteener T->i. Thedrun* may hn'-^coiitained cT^e typeof li-qui^ =;l-'er-"-.

<3-CCCO0^00

;Jri," h . re ^ .-• ihi.i^s -me •-debris WCL'^fro^. Trench '

Trenching Act iv i t tcs

LOCATION: Arna A tr<?nchtnE, trench T-.8.the location of thia t rench.

Figure 2-^ In trie text tnrilcaE-es

C"6

005100

A few crushed dr..r<were found ir. ?r';pch T-QOne of the drumscontained thfc solidifiedfoam-like materi;!:.Some refrigerator hulksand a lot of woodwere also fcunr1 :.r.the trench..

ir\OCCO0^00

Trench T-^ \^'.".ie s s ' Sc-- ' / '<-- '.-grounc ; cwc: ,

Trenching Activities

005101

Equlpprenr ^ t c r ^ e ^and dfrconta-lri,-.:!-•'•area (Area D ) . CoRSari".| at lon was foun/l '?urina; Instal lat ion nf a

firainage cu lve r t atthe s ta r t of the pro jec t

^0OC0)(00

Bur:?'1 /-.rur6 *<= - - ::^i^ip - • • ^ - ; ^ -i '1-^a h f l ^ 'I'-'- *k -. - • «•Pr^'.'-•--•»••''• • - • — • • . . - •:-?df""'.; -.^l,-.-,' : - - r i-../-*•.?<'.- D. :-• - ;drL1^*- ." '•r. •••"-.'-• •*i- :• -?-.---\ --?. - 1'- . -' -^; r; • •-, (. - , - . ' -«; - - ^-.^ft1- -t;*' r*---:.-.-.

Trenching Activities

LOCATION: Area T! trenchinR. pit numbers P-7 throuph P"lfi. Figure ;-«iIn the text indicates the location of these pits.

c-a

005102

Liquid whicr. wapexposed curingexcavation of pit p-fis baing tested toIdentify what typeof liquid IB prenant.Toluene was Identifiedat 30-^0 ppfr. duringth6 test. The liquidhad a strong odcr andhigh HM readlr.g'.,

r-CD000^00

During the ev'^ •a'l'-.'of pi: P~!-i. a ruT. '.terd'lp •Jp Ir. Arpa T'-.Sofne of the - 'n.teria,Soun^ Ir Are,'; : W A ^slrt!;»ii :^ v^.i; 'acbepp e<*'>', lr ' (^P'tr»r.<"r<*6. ^i"?."r • * ' ' . ' •wa? (nt ^civt-r: '• tvptflir;'.!- w^ icr rfasunique tc Area -

Supplementa l TrcnclilnB A c t i v i t i e s

Are.i R trenchlnR. pitn P-7 and P-l/n vcre located in the equipmcr.tetornge and decontainlnatlon area. Figure 2-6 Ir.dl-cates thelocations of theae pits.

C-9

005103

APPENDIX D

ANALYTICAL RESULTS FROM SPLIT SAMPLING

005104

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