june?, 1991barefoot landfill site ,^, work plan ypf june 7,1991^..^% page3-7:%,

29
WVRZYN - -%-hj . y - \ •y'^^yy- 'y SDMS DocID \ ••.June 7,1991 V..'^- •.• ''-''y'--:'''.yiy'--'-.''-iiyyi^.'yyiyyy '•:;,,^',Mr;GleTi,S:L^psleyv-OSC:. •••, ' ^^^^^^^^^^ '•;..'• ^- - - - : Y ;Eniforcenient and Title iu Sectidri ~ ~; • - ^ . ; '^ , \ ^ ;• United States EnvironinentalProtectioii'Agiiricy ^' ^^ V . : ,' • ••'•..••-'•. y'-y. .-'.'^ ••••v,''K.egionTn •:;".••;'• . / •',-• -•'' •: [^'•--' ^y •'"' y'.'-''• .-•'.'•y' ' '/•.'. •'•.••::;-':-.•. '"'••'•' 'y.. ..y " .:/'-;;841C:hesmut-Euiiding:,--:•'•'•.-;• '.•';,'; y'-.y'-^y-^y: - •: \y-.'i = ••-•;•'.••_"--V..-."-,. ;,.; ' , Philadelphia, Pennsylvania 19107, /f.^^ ' '-;.^ • .' ':••'•'.. • ' y ":. \ ..;• .:'RE: :'/B.arefoot Landfill. Site-•• ' .i'- ••••.."\" •;;":-• V " ••""''•,,':'-^.^- '''^^i '' ' Hyi^'iy ' .-••• '.'.^••,.'':Hollidaysbiirg,'PA.'..'v '.: "':•,' y-yy.;.':-' y;•'.••'. y- .yy-yy''- '.y.?'. '^'.'- y ••\, / Dear:Mr;^Japsley:-.-r';;'-^•..';•' y'---''''-: ..' ^•:. -.'':••"''•'.>;''•,.•,'' - •••'•^'•'•••"•'.'.' •; Tills letter and enclosures is a complete aiid tiineiy respoiiseto your June py 1.991 'request, regarding rnodificationof the;-'T/ork.Pl^^ CERCLA Section 106 'y -^Order, .Barefoot Laindnil Site, Hollidaysburg, Pemisylvariia,'^'.May, •.1991,; ^prepared by Warzyn Inc. As we discussed on May2S, 1991,,pages of the above:; ; referenced document,.revise(rpursuant to;your requests are .enclosed,' Upon'. ; ypurapprbyal of the enclosed pages, I wiH forward you a bound version L, ;; incorporatirig.the approved revisions for.your convenienc . •. ;.;,-: ; If you have.any; questions or; need rfurtlier cla^iifiGatioh, please contact me at '...(215)^964-0808 for asiistai^^ '^^ '• ;-•; ^:; ;/,j;:\ •"::;-•;:' :y'.y'- ; •:, "; 2107281 nM^yy ^/Pet^r L V^gt, ,PhO. I '\ .' -1,: Senior.Mariager; /^ ' Enclosure' •; ;•' . ^^^ cc: p. Bartlett,,Esq; (with ehcl.) THE PERhECT.liALANGE; • BETWEEN TECHNOLOGY .'• AND.CKEATiVITTl'.. , CHICAGO 2iOO''eOKPOR/\TE DKPv'E .- • .WDISON. II. 60101.' .- • (7dS)-69l-5000 , •••- - 'FA.XO,708) 691'-5lis- ten J 106 88! AR101547

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Page 1: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

WVRZYN - -%-hj . y - \

• y ' ^ ^ y y -

' y

SDMS DocID

\ ••.June 7,1991 • V..'^- •.• ' ' - ' ' y ' - - : ' ' ' . y iy ' - - ' - . ' ' - i iyy i^ . 'yy iyyy

'•:;,,^',Mr;GleTi,S:L^psleyv-OSC:. •••, '̂̂̂^̂̂̂^̂̂ '•;..'• -̂ - - - : Y ;Eniforcenient and Title i u Sectidri ~ ~; • - ^ . ; '̂ , \ ^ • ;• United States EnvironinentalProtectioii'Agiiricy '̂ ^̂ V . : ,' • ••'•..••-'•. y ' - y . .-'.'̂

••••v, ' 'K.egionTn •:;".••;'• . / •',-• -•'' •: [̂ '•--' ^y • ' " ' y ' . ' - ' ' • .-•'.'•y' ' '/•.'. •'•.••::;-':-.•. '"'••'•' 'y.. . .y " . : / ' - ; ; 8 4 1 C : h e s m u t - E u i i d i n g : , - - : • ' • ' • . - ; • '.•';,'; y ' - . y ' - ^ y - ^ y : - •: \ y - . ' i • = ••-•;•'.••_"--V..-."-,. ;,.; ' , P h i l a d e l p h i a , P e n n s y l v a n i a 1 9 1 0 7 , /f.^^ ' '-;.^ • . ' ':••'•'.. • ' y ":. \

..;• . : ' R E : : ' / B . a r e f o o t L a n d f i l l . Site-•• ' . i ' - ••••.."\" •;;":-• V " ••""''•,,':'- .̂̂ - ' ' ' ^ ^ i '' ' H y i ^ ' i y ' • .-••• '.'.^••,.'':Hollidaysbiirg,'PA.'..'v '.: "':•,' y-yy. ; . ' : - ' y;•'.••'. y- . y y - y y ' ' - '.y.?'. '̂ '.'- y

••\, / Dear:Mr;^Japsley:-.-r';;'-^•..';•' y'---''''-: ..' •̂:. -.'':••"''•'.>;''•,.•,'' - •••'• '̂•'•••"•'.'.'

•; Tills letter and enclosures is a complete aiid tiineiy respoiiseto your June py 1.991 ' r e q u e s t , regarding rnodificationof the;-'T/ork.Pl^^ CERCLA Section 106

'y -^Order, .Barefoot Laindnil Site, Hollidaysburg, Pemisylvariia,'^'.May, •.1991,; ^prepared by Warzyn Inc. As we discussed on May2S, 1991,,pages of the above:; ; referenced document,.revise(rpursuant to;your requests are .enclosed,' Upon'.

; y p u r a p p r b y a l of the enclosed pages, I wiH forward you a bound version L, ;; incorporatirig.the approved revisions for.your convenienc . •. ; . ; , - :

; If you have.any; questions or; need rfurtlier cla^iifiGatioh, please contact me at '...(215)^964-0808 for asiistai^^ '̂ ^ '• ;-•; ^:; ; / , j ; : \ •"::;-•;:' : y ' . y ' - ; •:, ";

2107281

nM^yy ^ / P e t ^ r L V^gt, ,PhO. I '\ .' -1,:

Senior.Mariager; /̂ '

Enclosure' •; ;•' . ̂ ^̂ •

cc: p . Bartlett,,Esq; (with ehcl.)

• THE PERhECT.liALANGE; • BETWEEN TECHNOLOGY .'•

• AND.CKEATiVITTl'.. ,

CHICAGO 2iOO''eOKPOR/\TE DKPv'E .-

• .WDISON. II. 60101.' .- • (7dS)-69l-5000 ,

•••- - 'FA.XO,708) 691'-5l is­ten J 106 88! AR101547

Page 2: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

Barefoot Landfill Site , Work Plan y

June?, 1991 ,, Page 3-6 -

will be recorded in a field log book. The augers will be cleaned between boring locations with the rinse water collected, drummed and stored on-Site. Waste cuttings will be left within the waste disposal areas.

Samples will be collected from each phase (i.e. liquid, sludge, soil) in each waste area for analysis. It is estimated that 11 samples will be analyzed for Resource Conservation and Recovery Act (RCRA) Characteristics of Hazardous Waste (ignitability, corrosivity, reactivity, and toxicity) and other routine disposal permitting parameters (Table 2). Up to 12 samples will be collected for treatability testing (Table 2).

A boring will be drilled at one location within each waste area. The boring will be drilled with HSA and continuously split-spoon sampled. Soils beneath the wastes will be visually examined and field screened with a PID. Samples will be analyzed at two depths beneath the waste to determine a profile of contamination in the soils. The total of 18 soil samples are divided between two areas as described below. Ten samples will be collected from the waste areas north of the access road and the area south of the access road identified by TAT as the "Sewage Sludge and Tomato Crop Residue" area, and will be analyzed for VOCs, Cd, Cr, Pb, Hg, and CN. Up to eight samples will be collected from the other areas south of the access road, and will be analyzed from Cd, Cr, Pb, Hg, and Cn, since the U.S. EPA has identified these areas south of the access road as contaminated with metals only (Table 2).

Upon completion of the soil and waste sampling, the waste areas will be temporarily covered with plastic to reduce the potential for infiltration of precipitation into wastes, reduce the potential for contact of precipitation with wastes and associated runoff, and further minimize the potential for people and wildlife to contact the wastes.

Potential Overflow Area. This Potential Overflow Area (identified on Figure 10 as "Excavated Area to Collect Lagoon Leakage") is suspected to have received overflow from the lagoons located immediately to the east (Figure 10). The Potential Overflow Area will be investigated to determine if wastes or contaminated soils are present. If wastes are observed during the investigation, they will be characterized consistent with the approach outlined above in Waste Areas, Task D. The procedure is described below. If contaminated soils are encountered in Potential Overflow Area, the extent will be estimated consistent with the approach outlined under Task C. The procedure to determine the extent of contaminated soil is described below.

AR101548

Page 3: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

Barefoot Landfill Site ,̂ , Work Plan y p f

June 7 , 1 9 9 1 ^ . . ^ % Page3-7:%,<t^

Auger probes using a truck-mounted drill rig will be performed within the area in approximately 50 ft intervals to determine if wastes or contaminated soils are present. The actual location and spacing may be varied in response to Site conditions. The probes will be drilled through the waste, if present, or to a depth of two ft, whichever is greatest. The probes will be performed similarly to the soil probes discussed under Task C, Soil (i.e., drill rig, etc.).

If wastes are observed in the field in the Potential Overflow Area, one sample will be collected from each phase (i.e., liquid, sludge, soil) and analyzed for RCRA characteristics of Hazardous Waste and other routine disposal parameters (Table 2).

If wastes are observed in the field in the Potential Overflow Area, one boring will be drilled and continuously split-spoon sampled as described above under Waste Areas, Task D. Soils beneath the wastes will be visually examined and field screened with a PID. Samples will be analyzed at two depths beneath the waste to determine a profile of contamination in the soils. The soil samples will be analyzed for VOCs, Cd, Cr, Pb, Hg, and Cn.

If wastes are observed in the field in the Potential Overflow Area, the extent of soil contamination around the wastes will be defined as described under Task C, Soil.

If wastes are not observed in the field in the Potential Overflow Area, but areas of suspected soil contamination are observed within the area, these will be further evaluated following the procedures under Task C, Soil.

Task E- A plan to remove and properly dispose of materials contaminated with hazardous substances located at the Site. Because the volume, character and treatability of the waste and soils has not yet been determined, the appropriate alternative for the wastes and soils at the Site caimot be determined at this time. Under Task D, the volume, character, and treatability of the waste and soils at the Site will be evaluated. Based upon the Task D results, alternatives for response action at the Site will be evaluated. While the soil and waste samples collected under Task D are being analyzed, the remediation alternatives to be evaluated based upon the field data include:

AR101549

Page 4: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

y^4' ' -

TABLE2 SAMPLE TYPE AND ESTIMATED SAMPLE NUMBERS

BAREFOOT LANDFILL SITE

Sample Matrix !

Soil areas north of access road plus Crop Residue Area

Soil areas south of access road except Crop Residue Area

Soil Beneath Waste

Soil Beneath Waste

Waste (5) Disposal Characteristics,

TreatabiUty (5)

Groundwater (6) Private Well

No. of Samples

26 26 26

18 18

12 12 12

8 8

14

12

40 40

Field (1) Duplicates

3 3 3

2 2

2 2 2

1 1

~

-

4 4

(2) Blanks

~ ~

~ -

~ ~

-

-

~

8 4

MS/MSDm

4 -~

~ ~

2 — -

..

-

~

-

8 —

Total No. Samples

33 29 29

20 20

16 14 14

9 9

14

12

60 48

Test (4) Parameters

TCL VOCs Cd, Cr, Pb, Hg CN

Cd,Cr,Pb,Hg CN

TCL VOCs Cd, Cr, Pb, Hg CN

Cd, Cr, Pb, Hg CN

RCRA Routine Disposal Parameters

TCLP VOCs TCLP Metals

TCL VOCs Lead

Notes:

1. Field dupUcates collected at a rate of 1 per 10 samples.

2. There are no field or trip blanks for soUd matrices. A trip blank for VOC analysis will be included with each cooler of groundwater samples shipped.

3. Extra volume is required for the TCL organic MS/MSD quality control requirement (triple volume for VOC). MS/MSD analysis performed at a rate of one MS/MSD set of two samples per 20 samples.

4. See Appendix D of the Work Plan for TCL analyte Ust.

5. Waste samples will be considered mid or high level samples.

6. Based upon four quarters of sampling 10 private water supply wells per quarter.

ICHI-600-89b] 52018 Table 2 MJH/mp/PJV/JAH

AR101550

Page 5: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

Backhoe Pit Trench

Into Rock Full of

Oil Sludge

MOTES 1. BASE MAP TAKEN FROM SITE SKETCH. BAREFOOT SANITARY

SERVICES, HOLLIDAYSBURG, PA. PROVIDED BY WESTON-MPD.

LEGEND

PERIMETER SOIL AUGER PROBE LOCATION

EXAMPLE DIRECTION FOR ADDITIONAL SOIL AUGER PROBE LOCATIONS BASED ON SITE TOPOGRAPHY AND OTHER SITE CONDITIONS.

north

100 200

SCALE IN FEET

FIGURE 8

WARZYN PERIMETER SOtU AUGER PROBE LOCATION MAP

Drown 3 ^ ^ Checkec

CERCLA 106 ORDER BAREFOOT LANDFILL SITE HOLLIDAYSBURG, PENNSYLVANIA

Revisions

A p p ' d . ' ^ 1 , : ; ^

Dote < / - • • •

52018 AR101551

Page 6: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

sinkhole

Sinkhole

%T

g ,_ 'vt u

- •> £ I 5 O

Potential Overflow Area

" a

Oil Sludge

Backhoe Pit Trench

Into Rock Full of

Oil Sludgo

Sludge and

Tomato "Crop" Residue

Oil Sludge

NOTES

1. BASE MAP TAKEN FROM SITE SKETGK BAREFOOT SANITARY SERVICES, HOLLIDAYSBURG, PA. PROVIDED BY WESTON-MPD.

LEGEND

WASTE AUGER PROBE LOCATION

north 100 200

SCALE IN FEET

FIGURE 10

WARZYN WASTE AUGER PROBE LOCATION MAP

C C R C L J M 06 ORDER BAREFOOT LANDFILL SITE HOLLIDAYSBURG, PENNSYLVANIA

Drawn S ^ ^

Revisions

Checked y ^ f ^ App'd. . ' p S \ , ^

° ° ' ' ^//3i/^l

52018 A 9 AR101552

Page 7: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

Figure 11. Project Schedule

Notes:

Field Activities & Reports

I I Laboratory Analysis

[ l l Agency Review (estimated)

H Deliverable Date

Work Item

Draft Work Plan

, EPA Review & Comment

Re-draft Work Plan

EPA Review & Approval

Apply for Waste Generator Number

Mobilization

Waste Area Delineation

Soil/Waste Sampling

Groundwater Sampling

Draft Response Action Plan

EPA Review & Comments

Secure Site

Re-draft Response Action Plan

EPA Review & Approval

Site Response Action

Draft Final Report

EPA Review & Comment

Re-draft Final Report

Bi-Weekly Reports

Week

1 2 1 2

M

*

1 2 3 4

w

mm

* *

5 6 7 8

iii

* *

9 101112

* *

13141516

* *

17181920

• III

* *

1 2 3 1

ia 11

* *

2 3 4 5

* *

6 .7 9 1011 1 2 3

11

mmmmM

* *

i l i i i l

* *

4 5 1 2

* *

3 4 5 6

ii

1 * *

7 9 1011

* *

/. Schedule may need to be modified if Agency review times are different.

2. Response Action sctiedule may vary, depending on selected remedy, and volume of waste defined. % , ^

3. Week numbers re-start after Agency review periods and after response action. y ^ -' v

SCHEDULE2PJV/MJH/DA W AR101553

Page 8: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

Field Sampling Plan, Barefoot Landfill s i t e ' ^

June 7,1991 P a g e 3 | ^

SECTION 3 SAMPLING LOCATIONS AND NUMBERS OF SAMPLES

Waste Area Sampling Waste hand-augering. Hand-auger waste probes will be performed at 20- to 50-ft intervals within the waste areas to determine the lateral and vertical extent of wastes and contaminated soils beneath the waste areas. It is estimated that up to 85 hand auger probes will be performed to an estimated depth of two ft. The approximate locations are shown on Figure L

Potential Overflow Area Auger Probes. It is estimated that up to 15 auger probes will be performed at 50-foot intervals in the Potential Overflow Area with a truck mounted drill rig as shown in Figure L

Waste Characterization. Up to 14 samples of waste for characterization of the waste for treatment and disposal will be collected from the waste areas. These are estimated to consist of nine sludge and two liquid phases. Up to 12 waste samples will be collected to be used in treatability testing. These are estimated to consist of four samples of each of the three expected phases (e.g., liquid, sludge, and soil).

Soil beneath the waste. One soil boring will be drilled using hollow-stem augering (HSA) to collect two samples from each waste area for a total of 20 soil samples to determine a profile of contamination beneath the waste areas (i.e., soil beneath the waste samples). The total of 20 samples are divided between two areas as described below. Up to twelve samples will be collected from the waste areas north of the access road and the area south of the access road identified as the "Sewage Sludge and Tomato Crop Residue" area, and analyzed for Target Compound List volatile organic compounds (VOCs), cadmium (Cd), chromium (Cr), lead (Pb), mercury (Hg), and total cyanide (CN). If it is determined in the field that wastes are not preserit in the Potential Overflow Area, "soil samples beneath the waste" will not be collected. See Appendix D of the Work Plan for the list of VOCs. Up to eight samples will be collected from the other areas south of the access road, and analyzed for Cd, Cr, Pb, Hg, and CN, since the U.S. EPA has identified these areas as contaminated with metals only.

AR101554

Page 9: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

%

% ^ Field Sampling Plan

Barefoot Landfill site ^ June 7, 1991 •§> '

Page 4

Soil Sampling Soil auger probes. Soil auger probes utilizing a drill rig will be performed around the waste areas to delineate the horizontal extent of contaminated soils (Figure 2). At a given waste area, soil auger probes will be performed at approximately 20- to 50-ft intervals along the perimeter of the waste area. If visual contamination or elevated PID readings are detected, the auger probes will be performed at approximately 5- to 10-ft intervals away from the waste area along lines perpendicular to the waste area until no visual contamination or elevated PID readings are detected. When the field screening indicates that the extent of contaminated soils has been determined, soil auger probes will cease at that location (see Section 5). The number of soil auger probes is estimated at 75, but may vary based upon Site conditions.

Soil sampling. The extent of soil contamination as estimated by field screening above will be verified with split-spoon samples collected from selected HSA borings for laboratory analysis. Up to a total of 44 split-spoon soil samples will be collected to verify the estimated extent of soil contamination. The sample depths will be selected in the field based upon visual examination and PID screening. The sarnples will be collected from auger probe locations which are expected to represent "clean" conditions around the perimeter of the waste areas. The total of 44 samples is divided between two areas as described below. Up to 26 samples in the vicinity the waste areas north of the access road, and the waste area south of the access road identified by TAT as the "Sewage Sludge and Tomato Crop Residue" area will be analyzed for VOCs, Cd, Cr, Pb, Hg, and CN. Up to 18 samples around the other waste areas south of the access road will be analyzed for Cd, Cr, Pb, Hg, and CN, since the U.S. EPA has identified those waste areas as contaminated with metals only.

Groundwater Investigation Private Well Sampling. Ten private wells will be sampled on a quarterly basis. The ten private wells are Rl, R2, R5, R6, RIO, R14, R16, R21, R25, and R26 (Figure 3).

AR101555

Page 10: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

#

Field Sampling Plan , -^ Barefoot Landfill site •S'!^

June 7, 1991 4 Page 9 '^^^r^.y^iP

Personnel and Responsibilities. The borings will be performed by a drill crew of two individuals supervised by a geologist. The geologist will collect the soil samples and function as the SSO.

Methods. The borings will be drilled using a drill rig and 3.25 in. inside diameter (ID) hollow-stem augers (HSA). Continuous spUt-spoon samples will be collected below the waste to the base of the boring. The soil samples will be screened with a PID. The samples wiU be logged in the field following American Society for Testing and Materials (ASTM) D2488-84. The locations will be surveyed to the existing Site grid. The actual location will be chosen in the field based upon the waste hand-augering results. The borehole will be grouted with a bentonite grout. The results will be recorded on a field log book. Waste and soil cuttings will be left in the waste area. The spHt spoon will be cleaned between samples. The auger will be cleaned between locations.

Auger Probes in Potential Overflow Area Objective: The objective of the auger probes is to determine if wastes or contaminated soils are present in the Potential Overflow Area. If wastes are observed ih the field, then determine the volume, character and treatability of the waste.

Personnel and Responsibilities: The borings will be performed by a drill crew of two individuals supervised by a geologist. The geologist will log samples and function as the SSO.

Methods: The borings will be drilled using a drill rig and 3.25 ID HSA. The augers will be advanced a depth of 2 feet or the base of waste if present (whichever is deeper) and immediately stop turning the augers. The augers will then be withdrawn with the cuttings held in the flights. The cuttings held in the flights will be visually examined and field screened with a PID. The soils will also be field classified following ASTM D2488-84. The auger holes will be backfilled with bentonite grout. The augers will be steam-cleaned between boring locations. Waste cuttings, if any, will be left in the waste area. Soil cuttings with PID measurements greater than 5 ppm will be drummed and stored on-Site if the area does not appear to be a waste area based upon field observations.

AR101556

Page 11: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

TABLE 1 SAMPLE TYPE AND ESTIMATED SAMPLE NUMBERS

BAREFOOT LANDFILL SITE

Sample ] Matrix I

Soil areas north of access road plus Crop Residue Area

Soil areas south of access road except Crop Residue Area

Soil Beneath Waste

SoU Beneath Waste

Waste (5) Disposal Characteristics,

Treatability (5)

Groundwater (6) Private Well

No. of Samples

26 26 26

18 18

12 12 12

8 8

11

12

40 40

Field (1) Duplicates

3 3 3

2 2

2 2 2

1 1

~

~

4 4

(2) Blanks

-~

-—

~ ~

-

-

~

8 4

MS/MSDr3^

4 ~ -

-—

2 ~ ~

-

~

-

8 —

Total No. Samples

33 29 29

20 20

16 14 14

9 9

14

12

60 48

Test (4) Parameters

TCL VOCs Cd, Cr, Pb, Hg CN

Cd, Cr, Pb, Hg CN

TCL VOCs Cd, Cr, Pb, Hg CN

Cd, Cr, Pb, Hg CN

RCRA Routine Disposal Parameters

TCLP VOCs TCLP Metals

TCL VOCs Lead

Notes:

1. Field dupUcates collected at a rate of 1 per 10 samples.

2. There are no field or trip blanks for sohd matrices. A trip blank for VOC analysis will be included with each cooler of groundwater samples shipped.

3. Extra volume is required for the TCL organic MS/MSD quality control requirement (triple volume for VOC). MS/MSD analysis performed at a rate of one MS/MSD set of two samples per 20 samples.

4. See Appendix D of the Work Plan for TCL analyte Ust.

5. Waste samples will be considered mid or high level samples.

6. Based upon four quarters of sampling 10 private water supply wells per quarter.

[CHI-600-89e] 52018 Table 2 MJH/mp/PJV/JAH

AR101557

Page 12: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

o ^ *vt t ;

2 •> £ £ 0 0

"̂ .9 C n O v>

o ? a c .- o

i : T ) •-=• 0 0 0 V- t j V Q _i l/>

sinkhole

Sinkhole

Bockhoc Pit Trench

Into Rock Full of

Oil Sludge

Sewage Sludge

and Tomato "Crop" Residue

Oil Sludge

N O T E S

1. BASE MAP TAKEN FROM SITE SKETCH, BAREFOOT SANITARY SERVICES, HOLUDAYSBURG. PA. PROVIDED BY WESTON-MPD.

LEGEND WASTE AUGER PROBE LOCATION

north 0 100 200

SCALE IN FEET

FIGURE 1

WARZYN WASTE AUGER PROBE LOCATION MAP ^ ' ° ' ^ ' ' S ^ ^ C h e c k e d < * ^

CHRCl^ 106 0RD=R BAREFOOT LANOFILL SITE HOLLIDAYSaURG. PENNSYLVANIA

Revisions

A p p ' d . • " " " > /

Dote 57;.;/-,(

52018 A 1 0 AR101558

Page 13: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

a. Q O

•o . 9 C in o tn

^ 'O -^ • C u i. u V O _l to

Potential Overflow Area

Trench into Rock Full of

Oil Sludge

Oil Sludge

NOTES 1. BASE MAP TAKEN FROM SITE SKETCH, BAREFOOT SANITARY

SERVICES. HOLLIDAYSBURG. PA. PROVIDED BY WESTON-MPD.

LEGEND

PERIMETER SOIL AUGER PROBE LOCATION

EXAMPLE DIRECTION FOR ADDITIONAL SOIL AUGER PROBE LOCATIONS BASED ON SITE TOPOGRAPHY AND OTHER SITE CONDITIONS.

north 0 100 20C

SCALE IN FEET

FIGURE 2

W A R Z Y N PERIMETER SOIL AUGER PROBE LOCATION MAP

Drown C , ^ ^ Checked ^

CERCLA lOe ORDER BAREFOOT U^NDFILL SITE HOLLIDAYSBURG, PENNSYLVANIA

Revisions

A P D - d : ^ ^ ^ ^ ; , , ^ -

Dole ^ / . : I h M

52018 A11 AR101559

Page 14: June?, 1991Barefoot Landfill Site ,^, Work Plan ypf June 7,1991^..^% Page3-7:%,

JOSEPH M. MANKO... MARC E.GOLD BRUCE S. KATCHER* KENNETH J . WARREN KERMITL RADER • MICHAEL M. MELOY ROBERT D. FOX STEVEN T. MIANO DEANE H. BARTLETT JILLM.HYMAN MARGIE BANET JONATHAN E.RINDE'

'ALSOADMITTED IN D.C. •AL50ADMITTEDINN.J.

LAW OFRCES

MANKO. GOLD & KATCHER SUITE 500

401 CITY AVENUE BALA CYNWYD. PA 19004 (215)660-5700

FAX (215) 660-5711

A p r i l 2 5 , 1991

VIA HAND DELIVERY

Glen S. Lapsley On-Scene Coordinator U.S. Environmental Protection Agency Enforcement and Title III Section (3HW33) 841 Chestnut Building Philadelphia, PA 19107

RE: Administrative Order for Removal Response Activities; Docket No. III-91-32-DC

Dear Glen:

On behalf of GTE Service Corporation ("GTE") and SKF USA Inc. ("SKF") I am hereby notifying you, pursuant to Paragraph 8.2 of the above-referenced Administrative Order that Warzyn Inc. has been retained to prepare a Work Plan pursuant to Paragraph 8.3 of the Order. I have enclosed for your reference some materials on Warzyn's qualifications, including information on the personnel who will be directly involved. Please call me should you have any questions with respect to Warzyn's qualifications.

Assuming Warzyn is approved by EPA, Peter Vagt, Ph.D., C.P.G. of Warzyn will replace me as Project Coordinator for the site.

As we indicated in our April 17, 1991 letter to Dean Jerrehian, we intend to submit a proposal for securing site access shortly. We have a quote from a contractor to provide fencing around the affected areas of the site as well as a commitment to follow site health and safety procedures as set forth in the Health and Safety Plan which will be developed by Warzyn.

€>

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i

Glen S. Lapsley April 26, 1991 Page 2

to call me. Again, should you have any questions please feel free

Very truly yours.

Deane H. Bartlett For MANKO, GOLD & KATCHER

DHB/dmw/10305-001

Enclosure

cc: Vincent Gallogly, Esq. (w/o end. - via regular mail) Allen Belenson, Esq. (w/o end. - via regular mail) Peter Vagt (w/o end. - via regular mail) Dean Jerrehian, Esq. (w/o end. - via hand delivery)

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fagc 4-1 ^^^, '%^,!.,

SECTION 4 PRO.TECTTEAM

Continuity of consulting services is a critical element in this project. That means that key to this project is the commitment of experienced staff throughout the entire project. At Warzyn, the same Project Manager oversees a project from investigation, remedial design, and remedial implementation, providing continuity of management throughout the process. The staff assignments presented below represent the most experienced management and technical expertise Warzyn has to offer. The team was selected based on the specific educational background and field experience of each staff member as they relate to the project needs.

Project Executive:

Project Manager:

Mr. .Toseph D. Adams .Tr.. P.E.. Vice President of Warzyn will be the Project Executive for the Barefoot Landfill Site project. Mr. Adams has a B.S. and M.S. in Civil Engineering. He has more than 13 years of experience in the investigation, design and construction of environmental projects.' He has managed more than a dozen CERCLA projects in recent years.

Mr. Adams will be responsible for assuring that adequate staff are available to work on the project and will function in the role of providing peer review of work plans and cleanup procedures.

Dr. Peter Vagt. C.P.G.. will be the Project Manager for the Barefoot Landfill Site project. Dr. Vagt has a B.S. in Geology and both a M.S. and Ph .D. in Hydrogeology. He has more than six years of experience in environmental project management from planning and implementing groundwater problem assessment and mitigation to conducting geological and hydrogeological characterizations for the development of disposal siting proposals. It is important to note that Dr. Vagt's has had great success negotiating with federal and state agencies based on his technical reputation.

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Proposal - Barefoot Landfill Site Work Plan Development

April 19,1991 Page 4-2 & :

SUPPORT STAFF

For tjiis^project. Dr. Vagt will be your singIe_2ointi3f contact. He will be respoTl5ib"leTor~overall project management, the technical excellence of all project deliverables, meeting project schedules and ibudgets, and management of staff assigned to the project.

Hydrogeologist/ Field Supervisor:

Geochemistry:

Mr. Martin Hamper will be the team hydrogeologist and field supervisor. Mr. Hamper has both a B.S. and a M.S. in Geology. He has over six years of experience conducting geological and hydrogeological field investigations for a variety of environmental projects in response to enforcement actions under CERCLA and RCRA.

Mr. .Tohn Dadisman will be the team Environmental Chemist. Mr. Dadisman has a B.S. in Water Resources and a M.S. in Environmental Chemistry. He hasseven years of experience interpreting and evaluating soil, water and air quality conditions associated with hazardous waste site remediation.

Karst Geologist:

Field Support:

Mr. Donald Penniman will be the team karst geology advisor. Mr. Penniman has a B.S. in Geology and graduate studies towards a M.S. in Geology. He has ten years of experience conducting hydrogeological investigations in a variety of geological settings, including being the lead hydrogeologist for a CERCLA Remedial Investigation at a former uranium processing plant. His responsibilities included design of an extensive monitoring well system and aquifer testing program in fractured limestone (karst terrain).

Mr. .Tohn Woodruff will provide field support for work plan implementation. Mr. Woodruff has both a B.S. and M.S. in Geology. He has over four years of experience conducting geological and hydrogeological field investigations for a variety of environmental projects.

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•TOSEPH D. ADAMS .TR.. P.E. Vice President

I Education

M.S., 1978, Cornell University, Civil Engineering

B.S., 1975, Worcester Polytechnic Institute, Civil Engineering

Specializations

RI/FS Environmental Audits :

W i y ^

ii AM

Registrations

Illinois Professional Engineer Michigan Professional Engineer

Experience

Mr. Adams has more than thirteen years of experience in the investigation, design and construction of multi-disciplinary civil and environmental projects. He has been responsible for the engineering of projects ranging m construction cost from $50 thousand to $17 million and has been the manager of 25 engineers and scientists. Mr. Adams has a broad range of experience in the civil and environmental area and is qualified to perform work related to:

Large Earthmoving Projects Remedial Investigations/Feasibility Studies (RI/FS) Environmental Audits Closure of Pits, Ponds and Lagoons , Land Reclamation Underground Tank Management Decontamination of Buildings, Equipment and Tanks

Specific project experience includes:

Field Project Engineer at a completed $17 million environmental clean-up project for a large chemical company in western Michigan. Project tasks included the design of a clay lined vault; supervision of earthmoving activities consisting of 500,000 cu yd of clay and over 1,000,000 cu yd of waste materials; development of the site air quality monitoring program; operation of the onsite environmental and soils laboratories; engineering for the construction of leachate treatment facilities; and coordination of activities with appropriate regulatory agencies.

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f l

Project Engineer for the design, permitting, construction and reclamation of an 80 acre clay mine in western Michigan.

Project Engineer for site restoration of abandoned acid stripping ponds at an oil refinery in central Pennsylvania including design runoff controls, watershed modeling and preparation of permits for regulatory review.

Manager of the clean-up of an abandoned sewer and storm water retention pond which contained sludges contaminated with organic solvents. The project involved excavation, bulking to a solid state, loading, transportation and offsite disposal of over 16,000 tons of waste.

Involved in more than ten RI/FS projects in EPA Regions III, V and VII. Mr. Adams was the Project Manager for six RI/FS projects in EPA Region V. Project tasks included negotiation of Work Plans with state and federal agencies; preparation of Work Plans, QA Plans, Health and Safety Plans, and Site Operation Plans; conductance of field work including geophysical surveys, well installations, test pits, pumping tests, and collection of samples of air, water and soil; development of Feasibihty Studies; and preparation of RI and FS reports.

Project Manager of the groundwater assessment at a major midwest hazardous waste landfill. Mr. Adams directed more than $450,000 of engineering, drilling, and analytical testing that was completed in less than four months. The work scope included the drillings of 20 monitoring wells, conductance of a pumping test, review of more than 100 years of analytical data, and development of a feasibility study to determine the indst cost-effectiVe solution for the site.

Project Manger for the investigation and remediation of more than 25 underground storage tank projects in the Chicago area.

Project Manager of the decontamination of a plant contaminated with Polychlorinated Biphenyls (PCBs) from a spill of hydraulic oil. The work scope included definition of the contaminated areas, preparation of a cleanup plan, supervision of remediation, verification of cleanup and negotiation with the Toxic Substance Control Act (TSCA) Section of U.S. EPA Region V.

, ' 1

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m.

.TOHN D. DADISMAN Environmental Chemist

Education

M.S., 1985, University of Wisconsin-Stevens Point, Natural Resources-Environmental Chemistry Emphasis B.S., 1980, University of Wisconsin-Stevens Point, Water Resources-Limnology Emphasis

Specializations

Environmental Chemistry Groundwater Contamination Air Toxics Assessment

^Bt

I

Experience

Mr. Dadisman has over seven years of experience ih environmental chemistiy. As a project chemist with Warzyn's Hazardous Waste Business Unit, he is primarily responsible for the interpretation and evaluation of soil, water, and air quality conditions associated with hazardous waste site remediation.

He is involved in a wide range of tasks associated with CERCLA activities including evaluation of project specific data needs and data quality objectives for Work Plan, Sampling Plan and Quality Assurance Project Plan development. Mr. Dadisman also performs assessment of data sufficiency, interpretation of chemical results, and evaluation of potential chemical fate and migration for Remedial Investigation, Endangerment Assessment, Feasibility Study, and Remedial Design activities.

Relevant project experience includes:

Remedial Investigation, Feasibility Study, and evaluation of the Proposed Remedial Action Plan for the Wheeler Pit Superfund Site, LaPrairie Township, Wisconsin.

Remedial Investigation, PRP-lead RI/FS for the Wayne Reclamation and Recycling Superfund Site, Columbia City, Indiana.

Remedial Investigation, Endangerment Assessment,and Feasibility Study, PRP-lead RI/FS for- the American Chemical Services NPL Site, Griffith, Indiana.

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• ' i

Remedial Investigation, PRP-lead RI/FS for the Muskego Sanitary Landfill NPL Site, Muskego, Wisconsin.

• Remedial Investigation, State Disposal Landfill, Michigan 307 Site, Kent County, Michigan.

Mr. Dadisman also has experience in conducting environmental assessments and compliance audits of commercial and industrial clients, with specific experience in the assessment of air toxic emission air permit applications.

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H^

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I

H

MARTIN .T. HAMPER Senior Hydrogeologist

Education

M.S., 1987, University of Illinois at Chicago, Geological Sciences B:S., 1981, University of Illinois at Chicago, Geological Sciences

Specializations

RCRA CERCLA

T

f

s s

Experience

Mr. Hamper has more than six years of experience in the environmental field focusing on both RCRA and CERCLA permitting and enforcement issues. Mr. Hamper's regulatory expertise compliments his technical skill to enable him to be a strong client advocate before the regulatory agencies.

• Preparation of a CERCLA Rlreport discriminating the boundaries of two separate groundwater contaminant plumes on the basis of groundwater chemistry reducing our client's groundwater clean-up responsibilities.

• Preparation of RCRA closure plans, personnel training plans, contingency plans and waste characterization plans for a resin manufacturer, paint manufacturer and foundry sand reclamation site, which were timely approved by the state agencies with few modifications.

• CERCLA and Illinois SRAPL Sites. Development of Quality Assurance Project Plans for both. The QAPP for the Illinois SRAPL site was timely approved with very few modifications.

• Illinois SRAPL Site. Field Supervisor for the implementation of an RI at a solid waste landfill. The project included water quality sampling and permeability testing during drilling in order to determine the best vertical location for well intake placement in a fractured dolomite aquifer.

Served as Project Hydrogeologist at gasoline UST investigation verifying the successful soil clean-up by Warzyn and compliance with Illinois groundwater standards without further remediation.

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i > ^ ,

m ^ DONALD E. PENNIMAN

Senior Hydrogeologist

Education

B.A., 1977 Hope College, Geology Graduate Studies, 1978-1981 Western Michigan University, Geology

Specializations

Design and Implementation of Hydrogeological Investigations Remedial Investigation/Feasibility Study

Training

Hazardous Waste Health and Safety Training CPR/First Aid Training Program Short Courses in Groundwater Modeling and Flow in Fractured Rock

Experience

Mr. Penniman has ten years experience in the area of hydrogeologic investigations. He has been the principal investigator for hydrogeologic investigations at several major sites of contamination, including CERCLA and Michigan 307 sites. As a Senior Hydrogeologist for Warzyn, Mr. Penniman's responsibilities include development of hydrogeologic investigation programs, cost estimation and budget tracking, coordination of field work, and review and consultation on hydrogeologic aspects of investigation and remediation projects. Specific project experience includes:

• As a Lead Hydrogeologist for a site investigation at a CERCLA landfill site in Michigan, Mr. Penniman is responsible for the development and implementation of field activities to gather data on groundwater contamination which may be emanating from the site and impacting public water supply wells. Mr. Penniman will utilize the data collected in the field in a groundwater computer model to determine niigration pathways and contaminant transport.

• As a Lead Hydrogeologist for a remedial investigation at a Michigan 307 site, Mr. Penniman is directing field activities designed to characterize the extent of groundwater contamination by volatile organic compounds at an operating industrial facility. A variety of investigative techniques, including a soil gas survey, geophysics, and installation of groundwater monitoring wells were utilized in the characterization of the site.

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IL

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'Mi^

Data review and analysis to assist attorneys in third party litigation related to groundwater contamination. Mr. Penniman has reviewed an extensive amount of data assembled by state agencies and consultants for other litigants. He has prepared summaries of sources and migration of contaminants and is advising attorneys in strategy for resolution of the client's role in litigation.

Review and technical assistance for hydrogeologic study in support of a closure plan for a landfill in a region of thin glacial deposits overlying impermeable bedrock.

As a Lead Hydrogeologist for remedial investigation at a former uranium processing plant and disposal sites under U.S. Department of Energy Administration, Mr. Penniman's responsibilities included design of extended monitoring well system and aquifer testing in fractured limestone, coordination of work plans and subcontracts and coordination of dye-tracing studies in karst terrain.

^c'f

As a Project Geologist for an international environmental consulting firm, he was responsible for complete planning and execution of hydrogeologic projects including proposal writing, work plan prepariation, monitoring well installation, sampling, aquifer testing, data interpretation and report writing. Mr. Penniman also gained RI/FS experience on (CERCLA sites and military installations in midwestern, western and southern states. He was Project Manager for field investigations and monitoring well installations for industrial clients.

:vty

' S H ' - I .

As Project Geologist for the environmental consulting subsidiary of a civil engineering firm, he worked on projects for industrial clients and gGvernmental agencies including studies of known or suspected groundwater contamination, hydrogeologic studies for RCRA facilities and wastewater treatment facilities and participated in a major aquifer restoration project.

: ' ^ \

'WM As an Assistant Geologist, Mr. Penniman assisted in hydrogeologic studies, background research, compilation and analysis of data and report writing and drafting.

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"i 1 f .,11

%

PETER .T. VAGT. Ph.D. Senior Project Manager

Education

Ph.D., 1986, Northern Illinois University, Geology M.S., 1982, Northern Illinois University, Geology

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£5.b., iy/1, Wheaton College, Wheaton, Illinois

^ecializations

SARA/CERCLA RCRA

Training

U.S. EPA Health and Safety Training Program

Experience

Dr. Vagt has worked in hydrogeologic consulting for over six years in a variety of groundwater and environmental projects. With Warzyn, Dr. Vagt is a project coordinator, responsible for projects ranging from planning and implementing groundwater problem assessment and mitigation (RI/FS) to conducting geologic and hydrogeologic characterization for the development of disposal siting proposals.

Dr. Vagt's dissertation research included a detailed hydrogeologic study of a leaking landfill, and the application of a flow and transport model to aid in evaluating the environmental impact of the landfill on the local and regional aquifers.

Much of Dr. Vagt's recent work has been focused in development and implementation of remedial investigations in the SARA/CERCLA and RCRA environments. He has taken a leading role in negotiating with U.S. EPA representatives to develop work plans for investigations which are both thorough and cost effective. His relevant experience includes:

• Remedial Investigation Team Leader for SARA/CERCLA investigations in Indiana and Wisconsin, and for remedial investigation at Illinois EPA listed hazardous waste site.

• Project Manager, conducted groundwater assessment and monitoring system evaluation at two private landfills in Illinois.

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Project Manager, developed work plans and interfacing with lEPA and U.S. EPA for several NPL and SRAPL sites.

Project Manager, evaluated existing data base and developed interim sampling to complete data requirements for a risk assessment.

Principal Investigator for site investigation and groundwater assessment at illegal dump site in DuPage County, Illinois. Using aquifer time series sampling and groundwater modeling to evaluate the existing monitoring well system. Dr. Vagt showed that apparent contamination in a deep aquifer was actually local contamination in the gravel pack and screen of the well.

Project Hydrogeologist, major private landfill in the Midwest; responsible for logging borings, field supervision of monitoring well installation, conducting field studies of aquifer characteristics by packer testing, pump tests and bail/slug tests.

Groundwater Modeler, used contaminant transport modeling at site of leaking underground tank to reconstruct the formation of contaminant plume, then evaluated the efficiency of several alternate remediation approaches.

Conducted a detailed hydrogeologic characterization of the Blackwell Forest Preserve Landfill (DuPage County, Illinois). Project included planning and supervising placement of new monitoring wells, conducting iri-situ aquifer tests, and defining the extent and character of contaminant plume.

Consulting hydrogeologist, implemented design of a flood control basin; supervised the field study and adapted a numerical flow model to analyze the surface and groundwater interaction which would result from dewatering and flooding conditions.

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.TOHN M. WOODRUFF Geologist

Education

M.S., 1984, Duke University, Geology B.A., 1981, Eariham College, Geology

Specializations

Risk Assessments Geology

Training U.S. EPA 40 hour Health and Safety Training

Experience

Mr. Woodruff has over four years of experience in environmental geology. He has performed environmental audits at bulk petroleum terminals, steel plants, solvents and petroleum recyclers, landfills, and environmental cleanup contractors. He has underwritten pollution insurance policies valued up to $6 million for hazardous and industrial facilities.

Mr. Woodruff has performed environmental field work at uncontrolled hazardous waste sites, chemical manufacturing and storage facilities, and various industrial facilities. He has installed, developed and tested numerous groundwater monitoring wells. Mr. Woodruff also has overseen the sampling of groundwater, surface water, surface impoundment water and sediment for environmeatal analysis. He has interpreted laboratory results and determined the magnitude and extent of site contamination at numerous facilities.

Mr. Woodruff has performed the following duties:

Project Geologist; Consultant for international cleanup of hydrocarbons at a bulk petroleum terminal. Reviewed existing information, delineated plume boundaries, investigated the influence of tidal cycles on product recovery systems, reviewed proposals, and assisted in contract negotiations.

Senior Staff Geologist; Performed Environmental Risk Assessment Surveys (ERAS) at bulk petroleum terminals, solvent and petroleum recyclers, steel plants, landfills, incinerators, and environmental cleanup contractors.

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Pollution Underwriter; Underwrote pollution insurance policies valued up to $6 million for hazardous and industrial facilities. This included evaluating environmental and financial risks, reviewing ERAS reports, performed onsite inspections, met with clients and brokers, and advised senior EPA officials in creating guidelines for insuring Response Action Contractors.

Staff Geologist; Field operations manager for a hazardous waste site, site geologist for installation of monitoring wells, managed computerized databases, interpreted and correlated geophysicallogs, supervised formation pressure testing of wells, and analyzed data and presented results in numerous technical reports.

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TABLE 7 RCRA Characteristics of Waste Barefoot Landfill Site

Hollidaysburg, PA

TCLP VOCs (rriQ/l)

Benzene

Carbon Tetrachloride

Chlorobenzene

Chloroform

1,2-Dichloroethane

1,1-Dichloroethene

Methyl Ethyl Ketone

Tetrachloroethene

Trichloroethene

Vinyl Chloride

TCLP Metals (mq/l)

Cadmium

Chromium

Lead

Mercury

Parameter

Corrosivity (pH)

Ignitability (flash point) *

Reactivity a) Cyanide

bl Sulfide

WA-A1

<0.25

<0.25

<50.0

<3.00

<0.25

<0.35

<100

<0.35

<0.25

<0.10

WAA-1

0.052

<0.01

<0.10

<0.002

WA-A-1

5.42

>200

<50.0

<10.0

WA-AA-1

<0.25

<0.25

- <50.0

<3.00

<0.25

<0.35

<100

<0.35

<0.25

<0.10

WA-AA-1

<0.005

0.04

<0.10

<0.002

WA-AA-1

6.49

>200

91.7

54.4

WA-C-1

<0.25

<0.25

<50.0

<3.00

<0.25

<0.35

<100

<0.35

<0.25

<0.10

WA-C-1

<0.005

0.05

<0.10

<0.003

WA-C-1

5.73

>200

<50.0

<10.0

WA-D-1

<0.25

<0.25

<50.0

<3.00

<0.25

<0.35

<100

<0.35

<0.25

<0.10

WA-D-1

<0.005

0.20

<0.10

<0.002

WA-D-1

5.72

>200

<50.0

<10.0

WA-E-1

<0.25

<0.25

<50.0

<3.00

<0.25

<0.35

<100

<0.35

<0.25

<0.10

WA-E-1

<0.005

0.22

<0.10

< 0.002

WA-E-1

6.79

>200

<50.0

43.4

WA-F-1

<0.25

<0.25

<50.0

<3.00

<0,25

<0.35

<100

<0.35

<0.25

<0.10

WA-F-1

<0.005

0.03

<0.10

<0.002

WA-F-1

7.08

>200

<50.0

<10.0

WA-G-1

<0.25

<0.25

<5C.O

<3.00

<0.25

<0.35

<100

<0.35

<o.;:5

<o.-;o

WA-G 1

<0.005

<0.01

0.11

<0.002

WA-G-1

5.45

>200

<50.0

<10.0

WA-H-1

<0.25

<0.25

<50.0

<3.00

<0.25

<0.35

<100

<0.35

<0.25

<0.10

WA-H-1

<0.005

0.06

<0.10

<0.003

WA-H-1

6.18

>200

<50.0

<10.0

WA-l-1

<0.25

-<0.25

<50.0

<3.00

<0.25

<0.35

<100

<0.35

<0.25

<0.10

WA-l-1

<0.005

<0.01

<0.10

<0.002

WA-I-1

6.24

>200

<50.0

<10.0

Regulatory

Limits

0.5

0.5

100

6.0

0.5

0.7

200

0.7

0.5

0.2

Regulatory

Limits

1.0

5.0

5.0

0.2

Regulatory

Limits

pH <2.0; or >12.5,

<140

250

500

Notes: * Ignitability (flash point) measured in degrees F

WARCRA JCQ/MJS

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AR101575