DSHW-2019-001306 - 0901a068809a964a

NORTHROP ORDIHJITAN
D v of waste Management
and Radiation Control
JAN 3 1 2019
January 31, 2019
8200-FY19-006 D3I-1-W-20( 9- ool3ok)
Rusty Lundberg, Acting Director
Department of Environmental Quality
Division of Waste Management and Radiation Control
ATTN: Jeff Vandel
P.O. Box 144880
195 North 1950 West
Salt Lake City, Utah 84114-4880
RE: Post-Closure Permit, ATK Launch Systems Inc. Promontory Facility, EPA ID#
UTD009081357, Response to DWMRC Comments on RFI Reports for SWMU Closures
Dear Mr. Anderson,
ATK Launch Systems Inc. Promontory facility is submitting with this letter responses to
comments provided by UDWMRC on December 5th and 28th, 2018. These comments are in
reference to ATK proposed closure of Solid Waste Management Units (SWMUs) and the
associated RFI reports. On January 24th, 2019 these responses were discussed with Jeff
Vandel and Kari Lundeen. Some of the responses include references to older documents that
may not currently be available to UDWMRC. These references can be provided on request.
If you have questions, or need additional information, please contact Paul Hancock at (435)
863-3344.
Sincerely,
Kris H Blauer, Manager,
Environmental Services
ATK Launch Systems, Inc. • P.O. Box 707 Brigham City, Utah 84321 • [phone]
December 5th 2018 DWMRC Comments to ATK SWMU Closure Request
DWMRC Comment: Based on EPA Guidance (Guidance on Choosing a Sampling Design for
Environmental Data Collection, December 2002), judgmental sampling (as opposed to simple
random) is appropriate for situations where there is "reliable historical and physical knowledge about
the feature under investigation." Furthermore, judgmental sampling is appropriate if "the objective of
the investigation is to screen an area (or SWMU) for the presence or absence of contamination at
levels of concern, such as risk-based screening levels."
The Division is concerned that the random sampling that was conducted at the drain field SWMUs,
particularly SWMUs #465 and #627, may not be adequate for determining the presence or absence of
contamination. According to Figure 465-1 (or Drawing No. M2-1) of the August, 2000 Phase I RFI
Report, the sampling grid laid out for SWMU #465 was over 500 feet long and 200 feet wide with
the random samples all being collected along the eastern edge of the grid and Figure 627-1 indicates
that the location of the SWMU #627 drain field is approximate.
Was the random sampling of the drain field SWMUs representative and adequate for determining the
presence or absence of contamination? Does ATK have any additional information regarding the
location and size of the drain fields at SWMUs #465 and #627? Could sample locations be reliably
selected that are more likely to represent the drain field discharges?
General Response to Stratified Random Sampling Compared to Judgmental Sampling: Stratified
random sampling was used to characterize the large septic drain fields at ATK. The sampling plans are
found in the May 1993 RFI Phase 1 Work Plan, and were later approved by the Utah Division of Solid and
Hazardous Waste.
ATK believes the stratified random sampling design is appropriate for these applications compared to
iudgmental sampling for the following reasons:
After leaving the septic tanks, drain fields use a series of long perforated pipes to disperse the waste
water into the soil. The perforated pipes are typically buried several feet underground and run at right
angles to the inflow pipe. As the waste water flows into the perforated pipes it saturates the
surrounding soil and bacterial mats form which restricts the additional flow of water at these initial
locations. The water then moves past these less permeable areas to unsaturated non-plugged areas
further along the pipe. This process continues during the life of the drain field until eventually the entire
drain field is saturated and has plugging bacterial mats making it no longer useful. The life is dependent
on flow volume, nutrients, size and how often solids are pumped from the tank. Since by design the
entire drain field sees an equivalent volume of flow and exposure to wastewater it is difficult to
determine which area would have seen the highest concentration of wastewater or where the highest
concentration of possible sporadic contamination may be found. So a statistical approach is appropriate
to quantify a level of confidence that the area is properly characterized. In addition using a stratified
design gives further confidence that possible contaminants with different soil absorption rates are also
characterized.
According to EPA (Guidance on Choosing a Sampling Design for Environmental Data Collection,
December 2002), iudgmental sampling is appropriate for relatively small-scale features and when there
is reliable historical and physical knowledge about the features or condition under investigation. It is also
subiect to unknown selection bias and is best used where an extremely small number of samples will be
collected due to limited budgetary constraints and schedule. Statistical sampling designs are usually
needed when the level of confidence needs to be quantified.
1. DWMRC COMIVIENT: SWMU 195 - Building M-174 - Old Open Burning Site
Although the analytical results appear to indicate that contamination at the SWMU isn't a concern, it
is unknown if the old burn trenches were actually sampled. The RFI Report indicates that the area
was graded prior to sampling and the sampling grid was laid out over the approximate location of the
burn trenches. In addition, sample locations were selected randomly.
How was the sampling grid located? Does ATK have any additional information on the number of
burn trenches, their size and location? A no further action determination is not appropriate at this
time since it is unknown if the burn trenches were actually sampled.
Response: The old burning site wa's located by scaling from aerial photographs, using historical
records, and employee interviews. (Reference 1993 RFI Work Plan Vol 4). This is the best
information available to determine the location that was graded and spread out. The description
states that the burn area had short limited use. These results are consistent with sampling in the old
burn trenches at M-136 and M-225 which showed similar very low contamination levels, likely due
high propellant burns temperatures (approx.5000 degrees F).
2. DWMRC COMMENT: SWMU 625 - Building M-153 - Septic Drain Fields A, B &C
Are the random samples that were collected adequate for determining the presence or absence of
contamination? Could sample locations be reliably selected that are more likely to represent the
drain field discharges?
Response: See general response to stratified random sampling compared to judgmental sampling at
septic drain fields.
3. DWMRC COMMENT: SWMU 626 - Building M-002-2 - Laundry Drain Field
Are the random samples that were collected adequate for determining the presence or absence of
contamination? Could sample locations be reliably selected that are more likely to represent the
drain field discharges?
Response: See general response to stratified random sampling compared to judgmental sampling at
septic drain fields. It was discussed during the January 24th 2019 meeting with Jeff Vandel, that
building M-002 is a laundry, large change house (with showers and rest rooms), and a cafeteria.
The likelihood of significant contamination in the drain field from COPCs used at the facility is
remote.
4. DWMRC COMMENT: SWIVIU 465 - Building M-002-1 - Septic Drain Field
The Division is concerned that the random sampling that was conducted at SWMU 465 is not
adequate for determining the presence or absence of contamination. Based on Figure 465-1 (or
Drawing No. M2-1), the sampling grid laid out was over 500 feet long and 200 feet wide with the
random samples all being collected along the eastern edge of the grid.
Does ATK have any additional information regarding the location and size of the drain field at
SWMU 465? What do the rectangles and lines shown within the sampling grid on Figure 465-1
represent? Could sample locations be reliably selected that are more likely to represent discharge
from the drain field?
Response: See general response to stratified random sampling compared to judgmental sampling at
septic drain fields. During the January 24, 2019 meeting with DWMRC, a facilities map was
discussed that identifies the rectangles within the grid as septic tanks and an old tile drain field, see
Figure 1. It also identifies some unrelated surface structures and later installed sewer pipe to the
other drain fields M-002-2 and M-002-3 discussed in this document. It was also discussed during the
meeting that building M-002 is a laundry, large change house (with showers and rest rooms), and a
cafeteria. The likelihood of significant contamination in the drain field from COPCs used at the
facility is remote.
5. DWMRC COMMENT:SWMU 621 - Building M-055-W — Building Surface Discharge
The units for the semi-volatile organics laboratory data for the two-foot depth samples at the point of
discharge and 25 feet down-gradient are reported as ug/L, but in the RFI Report text (Table 621-1)
the units are shown as mg/kg. The report discusses collecting soil samples, but not water samples.
Bis(2-ethylhexyl)phthalate was reported at 3600 ug/L in the point of discharge, two-foot sample and
8040 ug/L in the 25 feet down-gradient, two-foot sample. Both of these results were also qualified
with the letter "B." This compound was identified as a COPC for the SWMU apparently based on
sampling of the wastewater discharge. Response: The 1992 wastewater sample detected 3.1 DPm
Bis(2-ethylhexyl)phthalate (UPDES Permit Application Appendix D 1993)
It appears that the compound was detected in a blank, but data for the blank isn't included in the
report and the "B" flag is not discussed in the text. Please clarify these results.
Chromium was also identified as a COPC in the RFI Report, but there are no results for chromium
included with the data. Were the soil samples analyzed for chromium?
Response: Scott Fraser (ATK Lab QA/QC) reviewed the data, and said based on the higher detection
limits the values should have been reported as ua/Ka so the units were correctly reported in the RFI
report. The data is too old to find lab blank data, however since the residential RSL for Bis(2-
ethylhexyl)phthalate in soil is 390,000 uq/Ka it should not be a concern. In the original approved RFI
Work Plan (April 1993) Cr was not identified as a COPC, therefore, it was a typo to list chromium in
the RFI report.
6. DWMRC COMMENT:SWMU 627 — Building M-002-3 — Septic Drain Field
Based on Figure 627-1 of the Phase I RFI Report (August, 2000), the location of the drain field at
SWMU #627 is approximate. Are the random samples that were collected adequate for determining
the presence or absence of contamination? Could sample locations be reliably selected that are more
likely to represent the drain field discharges?
Response: The location of the drain field is obvious as the distribution boxes are still visible and can
be seen in google earth. The locations are as precise as possible for a subsurface structure although
possibly not exact therefore the term approximate was used. It was discussed during the January
24th meeting with Jeff Vandel that building M-002 is a laundry, large change house (with showers
and rest rooms), and a cafeteria. So the likelihood of significant contamination in the drain field
from any COPCs used at the facility is remote. See general response to stratified random sampling
compared to iudgmental sampling at septic drain fields.
7. DWMRC COMMENT:SWMU 628 — Building M-019A —Septic Drain Field
What is the suspected source of the high perchlorate concentrations that have been detected in the
nearby monitoring well M39B1? The RFI Report states that COPCs for the SWMU were identified
based on the results of samples of the waste water from the building that were collected during a
sampling event in 1988. Were VOCs or perchlorate detected in the samples? Are the random samples
that were collected adequate for determining the presence or absence of contamination? Could
sample locations be reliably selected that are more likely to represent the drain field discharges?
Response: In the 1988 sample (UPDES Permit Application Appendix D 1993), no VOC's were
detected, no semi-vols were detected; perchlorate was not sampled but is less of a concern in a
septic system as it will biodegrade. M-19A was used for X-ray photo developing, no rocket motors
were processed there as at other photographic sites. The well M-3981 is in a perched aguafer with
the static water level approx. 100 ft. higher compared to well .1-2 by M-19A. Contamination at the
well is likely from the processes at M-39, similar to wells at other X-ray facilities M-114 and M-636
where entire rocket motors were processed.
December 28th 2019 DWMRC Comments
1. DWMRC COMMENT: SWMU #630 — M-72 Drain field
Lab data for the soil sample that was collected from Grid #31, the 10 foot depth, is not included in
the RFI Report. Can a copy of this data be found? Please submit it, if possible.
Response : From Field Log Book: Auger refused to advance beyond 6-7 feet due to large rock possible
bedrock, moved 5 ft to NW also refusal at 5.5 ft. Tried next random grid.
The maximum amount of arsenic detected at the SWMU slightly exceeds the maximum background
concentration (but the UCL95 concentration for the SWMU does not exceed the maximum
background). Is there any reason to believe that arsenic was released at the SWMU? Was arsenic
detected in the waste water sample that was collected, as discussed in the RFI Report, "Waste
Characteristics" section?
Response: Arsenic was non-detect in the 1991 waste water discharge sample(UPDES Permit
Application Appendix D 1993). Arsenic is not a constituent of solid rocket motor propellant or case
manufacturing. It is assumed this is naturally occurring and varies on the facility. See general
response to stratified random sampling compared to iudgmental sampling at septic drain fields.
2. DWMRC COMMENT: SWMU #483 - Building M-197 — Building Surface Discharge
The COPCs identified for this SWMU were VOCs although the discharge is characterized as BAC
cooling water. Also, analytical results are included in the RFI Report for metals but not VOCs. In
addition, the Report states that the lab analyzed the samples as a liquid matrix and reported the
results in ug/L, but the metals results are reported in ug/g.
NFA appears appropriate based on the metals analysis results for the two-foot depth samples and the
statement in the RFI Report that no VOCs were detected at levels above the reporting limit, but
please clarify the discrepancies identified above. Does a copy of the VOC analytical results still
exist?
Response: Liquid matrix reported for only VOC analysis; COPCs identified were pH and VOCs. Yes,
VOC analysis is available and is included in the attachment with this response.
3. DWMRC COMMENT: SWMU #673 - Building M-120 — Building Surface Discharge
It is stated in the RFI Report that Building M-120 was a propellant ingredient premix preparation and
polymer building, and the discharge consisted of cooling tower bleed-off water. Was building wash-
down water included with the discharge?
Response: No, there is a sump at the building for wash down water (SWMU 129)
Drawing No. M673-1 shows "Grid #1" located 32 feet downgradient from the end of the culvert and
"Grid #2" 25 feet beyond that, which appears to be consistent with the Sample IDs shown on the lab
report, but the text in the RFI Report states that the samples were collected at the point of discharge
and 25 feet downgradient.
There is no mention of sample grids in the text of the RFI. Do the "Grids" referred to in the Drawing
represent sample locations? Response: yes. "Grids" are sampling points
Was the point of discharge sampled? Response: No, field book says there were overhead
obstructions preventing it (electric wires)
4. DWMRC COMMENT: SWMU #632 — M-193-N Septic Drain Field
Please see the general comment above regarding the random sampling method that was used at the
drain field SWMUs.
The UCL95 arsenic concentration calculated for SWMU #632 slightly exceeds the maximum
background concentration. Was there a potential source of arsenic discharge at Building M-193-N?
Was arsenic detected in the waste water sample that was collected in 1992, as discussed in the RFI
Report, "Waste Characteristics" section?
Response: Arsenic was detected at 0.079 ppm in the 1992 waste water sample (UPDES Permit
Application Appendix D 1993). Arsenic is considered a naturally occurring metal, it varies in
concentrations around the facility with higher values typically found closer to Blue Creek where the
M-193 facility is located.
In addition, the RFI indicates that the wastewater discharge from SWMU #632 included building
wash-down. Was the wastewater sample that was collected in 1992 analyzed for perchlorate?
Response: Perchlorate was not sampled in the 1992 waste water sample. This is a casting building
there are strict safety and "clean room" protocols to contain and prevent propellant contamination
outside of the rocket motor cases. See general response to stratified random sampling compared to
judgmental sampling at septic drain fields.
5. DWM RC COMMENT: SWMU #631 — M-191-S Septic Drain Field
Please see the general comment above regarding the random sampling method that was used at the
drain field SWMUs.
The RFI indicates that the wastewater discharge from SWMU #631 included building wash-down.
Was the wastewater sample that was collected in 1992 analyzed for perchlorate?
Response: Perchlorate was not sampled in the 1992 waste water sample (UPDES Permit Application
Appendix D 1993). This is a casting building there are strict safety and "clean room" protocols to
contain and prevent propellant contamination outside of the rocket motor cases. See general
response to stratified random sampling compared to judgmental sampling at septic drain fields.
6. DWMRC COMMENT: SWMUs #451 and #560 Building A-002 Building Surface Discharges
Based on the RFI Report, SWMUs #451 and #560 were two separate surface water discharges, both
from Building A-002. The SWMU #451 discharge was characterized as waste water from a sink and
the SWMU #560 discharge was characterized as rinse and developer waste water from a small photo
lab.
Sampling was conducted at the point of discharge, 25 feet downgradient from the point of discharge
and at a third point further downgradient below the confluence of the two discharges.
The waste water discharge for SWMU #560 was sampled, and the results are shown in Table 3-K,
Appendix 7.1, of the RFI Report. Constituents that were detected in the discharge include toluene,
methylene chloride, cadmium and boron. Drawing No. A2-1 in the RFI Report doesn't show the
location of the two discharges from the building. Was the point of discharge where the soil sample
was collected for the sink or photo lab waste water?
Response: From Field Log Book. SWMU 560 was sampled first at the point of discharge and then 25
ft. down gradient. SWMU 451 was down gradient in the same ditch and was sampled at the point
of discharge which also was mixed with 560 as it flowed down and was called the "combined flow
point of discharge"
Attachment
SWMU 483 Building M-72
RFI VOC Analytical Results
a
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aliNFil DR. SUMACS
le ID:
Test Codes and Names MEd
CN WI2 Told Cyalide PH S pH (Soil)
Test Codes and Names
SW-846, 9010 SW-846, 9045
1 A 14- PT. OF DD. 2 Fr. CN WI2 Told Cyanide SW-846, 9010 PH-8 pH (Soil) SW-846, 9045
1.4b Test Codes and Names 12A WW2; 25FT. DN. GRAD. 81111 $W-846, 9010 CN WT2 Tolrido P11-11 pli SW-846, 9045
bib ID: L. ID
7 41 IV . DN. GRAD. 25T Test Codes and Names MAW 73= CN W12 Total Cyanide PH S pH (Sod) SW-S46, 9010 SW-846, 9045
Workorder Comma
SW-846, 8240 67-64-1
107-02-8 107-13-1
71-43-2 75-27-4
75-25-2 74-83-9 78-93-3
75-15-0 56-23-5
108-90-7 75-00-3 110-75-8 67-66-3
74-87-3
124-48-1 75-34-3 107-06-2 75-35-4
591-78-6 156-60.-5
78-87-5 10061-01-5
10061-02-6
95-50-1 541-73-1 106-46-7 100-41-4
75-09-2 108-10-1
67-63-0 100-42-5
79-34-5 127-18-4
108-88-3 71-55-6
79-00-5 79-01-6 75-69-4 108-05-4
75-01-4 95-47-6
540-36-3
363-72-4 1110
1
11
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11
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111
1
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INNuanber21,1993 13:55 CERTINCATE OF ANALYSIS Page 2 RESULTS BY SAMPLE
Sampk ID: M-197-BP;FT. OF DIS. SUR. Lab ID: 9311022-05A Collected: 11/17/93 11:15:00
TEST RESULT UNITS LIMIT ANALYZED BY METHOD/CRS#
Volatile Organics
Acetone U ug/L 500 12/02/93 Acrolein U ug/L 100 12/02/93 ACrylonitrile U ug/L 100 12/02/93 Benzene U ug/L 30 12/02/93 Bromodichloromethane U ug/L 30 12/02/93 Bromoform U ug/L 30 12/02/93 Bromomethane U ug/L 50 12/02/93 2-Butanone U ug/L 500 12/02/93 Carbon disulfide U ug/L 30 12/02/93 Carbon tetrachloride U ug/L 30 12/02/93 Chlorobenzene U ug/L 30 12/02/93 Chloroethane U ug/L 50 12/02/93 2-Chloroethy1vinyl ether U ug/L 50 12/02/93 Chloroform U ug/L 30 12/02/93 Chloromethane U ug/L 50 12/02/93 Dibromochloromethane U ug/L 30 12/02/93 1,1-Dich1oroethene T3 ug/L 30 12/02/93 1,2-Dichloroethane • U ug/L 30 12/02/93 1,1-Dichloroethente U ug/L 30 12/02/93 2-Hexanone U ug/L 250 12/02/93 Trans 1,2-Dichloroethene U ug/L 30 12/02/93 1,2-Dichloropropane U ug/L 30 12/02/93 Cie 1,3-Dichloropropene U ug/L 30 12/02/93 Trans 1,3-Dichloropropene U ug/L 30 12/02/93 1,2-Dichlorobenzene U ug/L 30 12/02/93 1,3-Dichlorobenzene U ug/L 30 12/02/93 1,4-Dich7.orobenzene U ug/L 30 12/02/93 Bthylbenzene U ug/L 30 12/02/93 Hathylene Chloride U ug/L 30 12/02/93 4-Bethy1-2-Pentanone U ug/L 250 12/02/93 2-Propano1 (IPA) U ug/L 2500 12/02/93 Styrene U ug/L 30 12/02/93 1,1,2,2-Tatrach1oroethane U ug/L 30 12/02/93 Tetrachloroethene U ug/L 30 12/02/93 Toluene U ug/L 30 12/02/93 1,1,1-Trich7.oroethane U ug/L 30 12/02/93 1,1,2-Trichloroethane U ug/L 30 12/02/93 Trichloroethene U ug/L 30 12/02/93 Trichlorofluoromethane U ug/L 30 12/02/93 Vinyl Acetate U ug/L 250 12/02/93 Vinyl Chloride U ug/L 50 12/02/93 o-Xylene U ug/L 30 12/02/93 Chlorobenzene-d5 Int. Std. ug/L 12/02/93 1,4-Difluorobenzene Int. Std. ug/L 12/02/93 1,4-Dichlorobenzene-d4 Int. Std. ug/L 12/02/93 Pentafluorobenzene Int. Std. ug/L 12/02/93
Surrogate/Recovery Data For Volatile Organics 8240
Surrogate %Recovery Recovery Limits
Dibromofluoromethane 101 75 TO 125
Tbluene-88 99.2 75 To 125
4-Bromofluorobenzene 103 75 To 125
pi (Soil) 7.8 pH Mit 11/18/93 AA SW-846, 9045
Deambar21,1993 1315 CERTMCATE OF ANALYSIS RESULTS BY SAMPLE Page 3
Sample 1D: M-197-BP;FT. OF DIS. DUP. Lab Et 9311022-06A Collected: 11/17/93 11:17:00
TEST RESULT UNITS II33QT
Volatile Organics Acetone 102J ug/L 500 Acrolein U ug/L 100 Acrylonitrile U ug/L 100 Benzene U ug/L 30 U ug/L 30 Bromodichloromethane
Bromoform U ug/L 30 Bromomethane U ug/L 50 2-Butanone U ug/L 500 Carbon disulfide U ug/L 30 Carbon tetrachloride U ug/L 30 Chlorobenzene U ug/L 30 Chloroethane U ug/L 50 2-Chloroethylvinyl ether U ug/L 50 Chloroform U ug/L 30 Chloromethane U ug/L 50 Dibromochloromethane U ug/L 30 1,1-Didhloroathane U ug/L 30 1,2-Dichloroethane U ug/L 30 1,1-Dichloroathene U ug/L 30 2-Hemanone U ug/L 250 Trans 1,2-Dichloroethene U ug/L 30 1,2-Dichloropropane U ug/L 30 Cis 1,3-Dichloropropene U ug/L 30 Trans 1,3-Dichloropropene U ug/L 30 1,2-Dichlorobensene U ug/L 30 1,3-Dichlorobenzene U ug/L 30 1,4-Dichlorobenzene U ug/L 30 Rthylbenzene U ug/L 30 Methylene Chloride U ug/L 30 4-Methy1-2-Pentanone 0 ug/L 250 2-Propanol (Ium) u ug/L 2500 Styrene U ug/L 30 1,1,2,2-Tetrachloroethane U ug/L 30 Tetrachloroethene U ug/L 30 Tbluene U ug/L 30 1,1,1-Trich1oroethane U ug/L 30 1,1,2-Trichloroethane U ug/L 30 Trichloroethene U ug/L 30 Trichlorofluoromethane U ug/L 30 Vinyl Acetate U ug/L 250 Vinyl Chloride U ug/L 50 o-Xylene U ug/L 30 Chlorobenzene-d5 Int. Std. ug/L Int. Std. ug/L 1,4-Difluorobenzene 1,4-Dichlorobenzene-d4 Int. Std. ug/L Pentafluorobenzene Int. Std. ug/L
ANALYZED ET
12/02/93 12/02/93
12/02/93 12/02/93 12/02/93 12/02/93 12/02/93
12/02/93 12/02/93
12/02/93 12/02/93 12/02/93
12/02/93 12/02/93 12/02/93
12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93
12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93
12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93 12/02/93
NETBOD/CESii
SW-846, 8240 67-64-1 207-02-8 107-13-1 71-43-2 75-27-4 75-25-2 74-83-9
78-93-3 75-15-0 56-23-5 108-90-7 75-00-3 110-75-8 67-66-3 74-87-3 124-48-1 75-34-3 107-06-2 75-35-4 591-78-6 156-60-5 78-87-5 10061-01-5 10061-02-6 95-50-1 541-73-1 106-46-7 100-41-4 75-09-2 108-10-1 67-63-0 100-42-5
79-34-5 127-18-4 108-88-3 71-55-6 79-00-5 79-01-6 75-69-4 108-05-4 75-01-4 95-47-6
540-36-3
363-72-4 101
11
1
11
11
1
1
11
1
1
1
1
1
11
1M1
1
1
1
1
11
1
11
1
1
1
B
1
11
1
1
1
1

Surrogate/Recovery Data For Volatile Organics 8240
Surrogate Dibromofluoromethane Tbluene-da 4-Broacf1uorobenzene
0 (soil) 8.0 pH Ubit 11/18/93 AA .SW-846, 9045
%Recovery Recovery Limits 75 10 125 99.4 99.8 75 To 125
103 75 To 125
December 21, 1993 13:55 CERTIFICATE OF ANALYSIS Page 4 RESULTS BY SAMPLE
Sample ID: M-197-BParr. OF DIS. 2Fr. Lab ID: 9311022-07A Collected: 11/17/93 11:22:00
TEST RESULT ways LIMIT ANALYZED DT METEOD/CAS#
Volatile Organics Acetone TJ Ug/L 500 12/02/93 Acrolein ug/L 100 12/02/93 Acrylonitrile ug/L 100 12/02/93 Benzene ug/L 30 12/02/93 Bromodichloromethane ug/L 30 12/02/93 ug/L 30 12/02/93 Bromoform Bromomethane ug/L 50 12/02/93 2-Butanone TJ ug/L SOO 12/02/93 Carbon disulfide TJ ug/L 30 12/02/93 Carbon tetrachloride ug/L 30 12/02/93 Chlorobenzene ug/L 30 12/02/93 Chloroethane ug/L 50 12/02/93 2-Chloroethylviayl ether ug/L. 50 12/02/93 Chloroform ug/L 30 12/02/93 Chloromethane ug/L 50 12/02/93 Dibramochloromethane ug/L 30 12/02/93 1,1-Dichloroethane ug/L 30 12/02/93 1,2-Dichloroethane ug/L 30 12/02/93 ug/L 30 12/02/93 1,1-Dichloroethene 2-Hexanone ug/L 250 12/02/93 Trans 1,2-Dichloroethene ug/L 30 12/02/93 1,2-Dich1oropropane ug/L 30 12/02/93 Cis 1,3-Dichloropropene ug/L 30 12/02/93 Trans 1,3-Dichloropropene ug/L 30 12/02/93 1,2-Dichlorobenzene ug/L 30 12/02/93 1,3-Dichlorobenzene ug/L 30 12/02/93 1,4-Dichlordbenzene ug/L 30 12/02/93 Rthylbenzene Ug/L 30 12/02/93 Methylene Chloride ug/L 30 12/02/93 4-1ethy1-2-Pentanone ug/L 250 12/02/93 2-Propano1 (IPA) ug/L 2500 12/02/93 Styrene ug/L 30 12/02/93 1,1,2,2-Tetrachloroethane ug/L 30 12/02/93 Tetrachloroethene ug/L 30 12/02/93 Tbluene ug/L 30 12/02/93 1,1,1-Trichloroethane ug/L 30 12/02/93 1,1,2-Trichloroethane ug/L 30 12/02/93 Trichloroethene ug/L 30 12/02/93 Trichlorofluoromethane ug/L 30 12/02/93 Vinyl Acetate ug/L 250 12/02/93 Vinyl Chloride ug/L 50 12/02/93 o-Xylene TJ ug/L 30 12/02/93 Ch3.orobenzene-d5 int. Std. ug/L 12/02/93 1,4-Difluorobenzene Int. Std. ug/L 12/02/93 1,4-Dichlorobenzene-d4 Int. Std. ug/L 12/02/93 Pentafluorobanzene Int. Std. ug/L 12/02/93 Il
l
Y
B
M
1
1
0
Y
1
$0
0
1
11
0
M
1
1
1
1
1
1
0
1
1
1
1
0
M
0
1
1
1
1
1
1

SW-846, 8240 67-64-1 107-02-8 107-13-1 71-43-2 75-27-4
75-25-2 74-83-9 78-93-3 75-15-0 56-23-5 108-90-7 75-00-3 110-75-8 67-66-3 74-87-3 124-48-1 75-34-3 107-06-2 75-35-4 591-78-6 156-60-5 78-87-5 10061-01-5 10061-02-6 95-50-1 541-73-1 106-46-7 100-41-4 75-09-2 108-10-1 67-63-0 100-42-5 79-34-5 127-18-4 108-88-3 71-55-6 79-00-5 79-01-6 75-69-4 108-05-4 75-01-4
95-47-6
540-36-3
363-72-4
Surrogate/Recovery Data For Volatile Organics 6240
%Recovery Recovery Limits
101 75 TO 125 101 75 To 125
104 75 To 125
11/18/93 AA S1S-846, 9045
Surrogate
Dibromofluoramethane Toluene-d8 4 -Branofluorobenzene
pi (ioil) 7.7 pH Unit
SW-846, 8240 67-64-1
107-02-8 107-13-1 71-43-2 75-27-4
75-25-2 74-83-9 78-93-3 75-15-0 56-23-5 108-90-7 75-00-3 110-75-8 67-66-3 74-87-3 124-48-1 7534-3 107-06-2 75-35-4 591-78-6 156-60-5 78-87-5 10061-01-5 10061-02-6 95-50-1 541-73-1 106-46-7 100-41-4 75-09-2 108-10-1 67-63-0 100-42-5 79-34-5 127-18-4
108-88-3 71-55-6 79-00-5 79-01-6 75-69-4 108-05-4 75-01-4 95-47-6
540-36-3
363-72-4 BI
I
I
B
O
O
P
O
IO
RO
Y
Y
M
O
O
M
B
O
BO
M
I
O
M
M
0
0
1
1
0
0
1

December 21, 1993 13:55 CERTIFICATE OF ANALYSIS Page 5 EMUS BY SAMPLE
Sample ID: M-197-BP;25FT. DN.GRAD.SUR Lab ID: 9311022-08A Colby** 11/17/93 11:25:00
TEST RESULT UNITS LIMIT ANALYZED BY METHONCRSit
Volatile Organics Acetone 100J ug/L 500 12/02/93 Acrolein ug/L 100 12/02/93 Acrylonitrile U ug/L 100 12/02/93 Benzene U ug/L 30 12/02/93 Bromodichloromethane U ug/L 30 12/02/93 Bromoform U ug/L 30 12/02/93 Bromomethane U ug/L 50 12/02/93 2-Butanone U ug/L 500 12/02/93 Carbon disulfide U ug/L 30 12/02/93 Carbon tetrachloride U ug/L 30 12/02/93 Chlorobenzene ug/L 30 12/02/93 Chloroethane U ug/L 50 12/02/93 2-Chloroethylvinyl ether U ug/L 50 12/02/93 Chloroform U ug/L 30 12/02/93 U ug/L 50 12/02/93 Chloromethane Dihromochloramethane U ug/L 30 12/02/93 1,1-Dichloroethane U ug/L 30 12/02/93 1,2-Dichloroethane U ug/L 30 12/02/93 1,1-Dichloroetheme U ug/L 30 12/02/93 2-Hexanone ug/L 250 12/02/93
Trans 1,2-Dichloroethene U ug/L 30 12/02/93 1,2-Dichloropropane U ug/L 30 12/02/93
Cis 1,3-Dichloropropene U ug/L 30 12/02/93 Trann 1,3-Dichloropropene U ug/L 30 12/02/93 1,2-Dichlorobenzene U ug/L 30 12/02/93
1,3-Dichlorobenzene 17 ug/L 30 12/02/93 1,4-Dichlorobenzene U ug/L 30 12/02/93 Ethyl:benzene U ug/L 30 12/02/93
Methylene Chloride U ug/L 30 12/02/93
4-Methy1-2-Pentanone U ug/L 250 12/02/93 2-Fropanol (IPA) U ug/L 2500 12/02/93
Styrene U ug/L 30 12/02/93 1,1,2,2-Tetrach3.oroethane U ug/L 30 12/02/93 Tetrachloroethene u ug/L 30 12/02/93
noluene U ug/L 30 12/02/93 1,1,1-Trich1oroe4-hane U ug/L 30 12/02/93 1,1,2-Trichloroethane U ug/L 30 12/02/93
Trichloroethene U ug/L 30 12/02/93
Trichlorofluoromethane U ug/L 30 12/02/93
Vinyl Acetate U ug/L 250 12/02/93 Vinyl Chloride u ug/L 50 12/02/93
o-Xylene 11 ug/L 30 12/02/93
Chlorobenzene-d5 Int. Std. ug/L 12/02/93 Std. ug/L 12/02/93 1,4-Difluorobenzene 1,4-Dichlordbenzene-d4 Int. Std. ug/L 12/02/93 Pentafluordbenzene Int. Std. ug/L 12/02/93
Surrogate/Recovery Data For Volatile Organics 8240
Surrogate Dibromofluoromethane Toluene-d8 4-Bromofluorobenzene
PR (Soil) 7.6 pH Unit
%Recovery Recovery Limits 106 75 To 125
99.7 75 TO 125
104 75 TO 125
11/18/93 SW-846, 9045
December 21, 1993 13:55 CERTIFICATE OF ANALYSIS Page 6 RESULTS BY SAMPLE
Sample ID: M-197-BP;25FT. DN.GRAD.2FT LAM: 9311022-09A Collected: 11/17/93 11:33:00
TEST RESULT U111113 rimarr ANALYZED HT maiscm/cas#
Volatile Organics SW-846, 8240 Acetone U ug/L SOO 12/02/93 JIUA 67-64-1 Acrolein U ug/L 100 12/02/93 J1lA 107-02-8 Acrylonitrile U ug/L 100 12/02/93 JMA 107-13-1 Benzene U ug/L 30 12/02/93 JIUA 71-43-2 U ug/L 30 12/02/93 JMA 75-27-4 Bramodichloromethane
Bromoform U ug/L 30 12/02/93 JNA 75-25-2 Bromomethane U ug/L 50 12/02/93 JMA 74-83-9 2-Rutanone U ug/L 500 12/02/93 JMA 78-93-3 Carbon disulfide U ug/L 30 12/02/93 JMA 75-15-0 Carbon tetrachloride U ug/L 30 12/02/93 JMA 56-23-5 Chlorobenzene U ug/L 30 12/02/93 JMA 108-90-7 Chlorcethane U ug/L 50 12/02/93 75-00-3 2-Chloroethylvinyl ether U ug/L 50 12/02/93 JMA 110-75-8 Chloroform U ug/L 30 12/02/93 JMA 67-66-3 Chloromethane U ug/L 50 12/02/93 JNA 74-87-3 Dibromochloromethane U ug/L 30 12/02/93 J 124-48-1 1,1-Dichloroethane U ug/L 30 12/02/93 JMA 75-34-3 1,2-Dich1oroethane u ug/L 30 12/02/93 JMA 107-06-2 1,1-Dich1oroethene U ug/L 30 12/02/93 JMA 75-35-4 2-Hezancoe U ug/L 250 12/02/93 i1MA 591-78-6 Trans 1,2-Dichloroethene U ug/L 30 12/02/93 JMA 156-60-5 1,2-Dichloropropene U ug/L 30 12/02/93 JMA 78-87-5 Cis 1,3-Dichloropropene U ug/L 30 12/02/93 JIUA 10061-01-5 Trans 1,3-Dichloropropene U ug/L 30 12/02/93 JMA 10061-02-6
1,2-Dichlorobensene u ug/L 30 12/02/93 JNA 95-50-1 1,3-Dichlorobensene U ug/L 30 12/02/93 JMA 541-73-1 1,4-Dichlorobensene U ug/L 30 12/02/93 JMA 106-46-7
ithylbensene U ug/L 30 12/02/93 JNA 100-41-4
Methylene Chloride U ug/L 30 12/02/93 JMA 75-09-2
4-Methy1-2-Pentanone U ug/L 250 12/02/93 JMA 108-10-1 2-Propanol am U ug/L 2500 12/02/93 JMA 67-63-0
Styrene 0 ug/L 30 12/02/93 JMA 100-42-5
1,1,2,2-Tetrachloroethane U ug/L 30 12/02/93 JNA 79-34-5
Tetrachloroethene U ug/L 30 12/02/93 J1lA 127-18-4 TOluene U ug/L 30 12/02/93 JIUA 108-88-3
1,1,1-Trich1oroethane U ug/L 30 12/02/93 JNA 71-55-6 1,1,2-Trich1oroet1iane U ug/L 30 12/02/93 JNA 79-00-5 Trichlorcethene U ug/L 30 12/02/93 JMA 79-01-6
Trichlorofluoromethane U ug/L 30 12/02/93 75-69-4
Vinyl Acetate u ug/L 250 12/02/91 JIlA 108-05-4
Vinyl Chloride U ug/L 50 12/02/93 JIlA 75-01-4
o-Mylene U ug/L 30 12/02/93 JMA 95-47-6
Chlorobenzene-d5 Int. Std. ug/L 12/02/93 JNA -
1,4-Difluorobensene Int. Std. ug/L 12/02/93 JNA 540-36-3
1,4-Dichlorobensene-d4 Int. Std. ug/L 12/02/93 JIUA -
Pentafluorobensene Int. Std. ug/L 12/02/93 JMA 363-72-4
Surrogate/Recovery Data For Volatile Organics 8240
lerrogate %Recovery Recovery Limits
Dibromoflucromethene 103 75 TO 125
TOluene-d8 100 75 To 125
4-Bramofluordbenzene 103 75 TO 125
PI (Soil) 7.7 pH Unit 11/18/93 AA SW-846, 9045
Perforated tile field
Septic tanks
SWMU 1465
_SAMPLE GRID NO,S
9, 19, 22, 30. 54
Septic tank
Newer Drain
Line to drain
fields M002-2
and M-002-3
Figure 1
fv1189 M2