UNITED S \S ENVIRONMENTAL PROTECTION A \CY

June 21, 1983

Mr. Dick KarkkalnenDirector of Envlrorment A SafetyVertac Ch—lcal Corporation24th Floor* 9100 PoplarMemphis, Tennessee 38137

Dear Mr. Karkkalnen:

The Environmental Protection Agency has reviewed your Section VIII Proposal \0

of February 21, 1983, for onslte remedial work. In brief, we see that you 0\

have proposed the following actions: r--<M

1. Reasor Hill Disposal Area - groundwater monitoring. Q

2. North Waste Burial Area - extend existing cap; groundwater monitoring^

3. Cooling Hater Pond - place sediments on the east shore of the pond;contain sediments with a barrier wall and a cap.

4. Central Ditch - remove sediments to cooling pond sediment disposalarea; backfill with compacted clay.

5. East Ditch - bury contaminated sediments in place and Install a newditch nearby.

6. Groundwater Monitoring - monitor ten wells seal-annually.

Upon examining the Vertac onslte remedial proposals, and after reviewing govern-ment and Vertac data regarding the site, we have determined that many of theVertac proposals do not provide the environmental safeguards that are appro-priate for the extremely toxic contamination existing on the Vertac Jacksonvillesite. They are Inadequate to protect against damage to human health or theenvironment. Your proposals and our concerns about their Inadequacies arediscussed below.

Reasor-mn and North Waste Burial Areas

According to your correspondence dated February 15» 1983, the Reasor-HIII andNorth Waste Burial Areas contain 30,000 and 100,000 cubic yards of waste material,respectively. According to evidence from a number of sources, both TCDD contami-nated materials and organic solvents, which can mobilize TCDD, are containedin these waste burial areas and are migrating from these areas. These sourcesof information Include the following: 0310733JL

CONCURRENCESSYMBOL k

SURNAME k

DATE k

E PA Form 1320.1 (12-70) OFFICIAL FILE COPY

VT3.1.11

1. According to an April 18, 1980 deposition of Arthur L. Treisback, aformer plant engineer and plant manager of the Vertac Jacksonvillefacility when It was owned and operated by Hercules, toluene stillbottoms and uncontalnerlzed liquid wastes froa the equalizationbasin were placed In the North Waste Disposal Area (see depositionpages 21 and 22).

2. According to testimony of Arthur Treisback during the hearing on thePreliminary Injunction on April 28, 1980, various solid, mushy, andliquid wastes, some including toluene still bottoms, were placed inin drums or barrels which were dumped into excavations In the NorthDisposal Area and then crushed, allowing some of the waste materialsto run out of those containers (see testimony pages 102 to 105).

3. According to groundwater monitoring well samples acquired monthlyfrom mid-1980 through the end of 1981 by the Arkansas Departmentof Pollution Control and Ecology and analyzed by EPA contract ^~labs, chlorinated phenols, chlorinated benzenes, and toluene were (Mfrequently found in wells 4, 6, and 8 in the North Disposal Area. oChlorinated phenols, chlorinated benzenes and toluene are organic Qsolvents.

4. According to samples acquired in October 1979 by EPA and analyzedby Wright State University, TCDD was detected in a number of soilcores and monitoring well samples on the Vertac site. Thesesamples include the following (see map. Attachment I).

a. In well #3, north of Reasor Hill, TCDD was found at 2.61 partsper billion (ppb) in a soil core from a depth of six inches toone foot three inches.

b. In well M, west of Reasor Hill, TCDD was found at 23.5 ppb ina soil core from a depth of zero to two feet and at 69 parts pertrillion (ppt) in a water sample.

c. In well j?6, southwest of the former barrel storage area in theNorth Waste Burial Area. TCDD was found at 0.184 ppb in a soilcore from one foot to one foot six inches, at 0.097 ppb in asoil core from nine feet to ten feet six inches, and in awater sample at 81 ppt.

d. In well jS'8. west of the old burial site in the North WasteBurial Area, TCDD was found at 37 ppt in a soil core from zeroto ten inches.

5. In a sample of dirt from below a seep at Reasor Hill collected byEPA in May 1979 and analyzed by Wright State University, TCDD wasfound at a concentration of 342 ppb.

6. In samples collected by an EPA contractor in April 1981 and analyzedby Wright State University, TCDD was found in two apparent seeps atReasor Hill at 1.2 ppb and 0.045 ppb, and in a seep near the coolingwater pond JA. 5.5 ppb. Chlorinated herbicides were also found intwo apparent seeps at Reasor Hill at 1,348 ppb and 1 ,139 ppb.

031.07312'»-<<c^ -< ".t-*»-i,»^ ' ^ .-:•• ' -v, -——-.' .^^^••^••St-sx-^'^ ':. • - '.y1 '-^S*^^ -TI)- '- i-mniliiirii—'- r ^ ' -.>

Chlorinated herbicides were also found in the seep near the coolingpond at 5,690 ppb, chlorinated benzenes were found there at 240ppb, and chlorinated phenols were found there at 3,920 ppb.

7. In monitoring well samples acquired by a Vertac contractor in thesuffliner of 1982, chlorinated organics were found at concentrationsof up to 400.000 ppb.

8. In samples acquired in February 1983 by an EPA contractor from thesame wells as mentioned in item 7 above, a variety of organic con-taminants were again found. This contamination is summarizedbriefly below:

Well Number Tota 1 Organic Containi nati on (ppb)CO

28 0NONO

3,878174

r^-(M0

414 010

678910111213141516171819

14,9841025ND

4,21719N078N0N0344N0

9 . Samples collected from the intercept ditch downgradient of theformer equalization basin have shown the presence of both TCDOand other organics contaminants. These samples are summarizedbriefly below.

Date of Sample Description Contaminant ConcentrationMay 1 6 , 1979 Liquid sample from surap 1 6 , 9 6 0 ppn total organics

below equalization basinMay 1 6 , 1979 Sediment from sunp below 676 ppb TCDD

equalization basinThe above samples show that organic contaminants can and do migratethrough soil structures high in clayey materials. Further, if thismigration can occur in areas such as downgradient of the formerequalization basin, it can also occur in areas such as ReasorHi 11 or the North Waste Disposal Area.

0310^313

^^;^^^^ • ^y

' •• ••» -t' -C'" •'•'•••*• ••(•».£ ".;,; ^^• - ' 'i - ' • '•fc-'-yt'"" ?• :.. ;:'. •;: *- •y^-'-

£• - -^ •'• ''<';/- J><•>:-: ^ ".^-^

•* t. 1 -a- '-'T^rf • • • ' *''\<3S<^^^^e^

- .•A;<p^:..< .-'- .•''c* a-A- -••a?'iS^'-ft"-* '• ••* • .'. -7~ ' • •e 'E-3fc?';! "'*' - '^^3(^.

. :^•^!,ara's.lW l ^<

, -.---. . -.JN^^^^^^, . Itt ; cp*M lib(w^ ttriM£tfl ^ »MU^he i l Miiti f h ^ ^

- ; • ; ooslfcr ^^grat r tcroa^c>ty^^^^^.,.. .

' l s«fip1es cotT.tcted.'iby the-tPA contrairfbr 1|i Ja^aT^NS^w> tftH bns l rflanic cheatcal $ than iafflpT»», coTltctefl •froa ttw' laewtJ<*^ at^rTW^«t<». These lo»»er concefl ratlohs.'cotfTd] t( di<Eatil' l*'»?«^u ;l

rate of migration or the»e contaiiitfiahtr. ^rJre<^^#iat ^exactly what weNere trying to achieve With ^e^otfcp iii aiureilB^Iiearlier at th^tHe. Thes? Measures Ne»^ the result-Man- lnlst 'i ^^®^^Order by the Arkansas Department of/Pollution Cont|CoT,1lnd Ccolbgy^an^Ji^^''^-'^-'^.-

-Prellaloary Ifljunttton by. he United StatCT^ts^r^^Dar^^^lttT^'f^'wbtc^ reqolHd^rtac to plact clay taps^ttw O^oi ihe Itortft Matte^a^^fe^^fiposa^ 'Area <hd asor HI ,11 ^ .and to nstair cutofr- wall I uparadlent ffot %3?%. the Reasor/fifl I <!lspo$a1^aCaa ."'KHeft: the ADPCSE: and iP .sotfghf these a^W^'^^

\ •L ^ , 'actions xc- did so because we expected the® to provide an Interia reduc'tt^^.?.^,? ' .';; ^y'conta«^naht iBigratton.^ ''iRie'febniary •l983,win1tor1og well safflpTes'lieciR^^ - s ' / '

to indicate thai this eduction, at.least' for.the present tlBe» has ocCMrred.

As reflected 'paragraph. VII: ot the Consent. Decree, when the ADPC&E antf^ ; -ERA sought^heaforeHientlopedciay caps and cutoff wall s» It was not intendedthat these 'Teatures Would constitute ft naT' reoedles^ for disposal of the wastesIn the Reasor M<n^ari4,Nbrfh; Waste-pispesaf Areas. -Instead, we did so -with the Intention that. these (Steasures would provide Interim abatement; of ^ -a serious envfronBental threat:' 'seepage of TCDD and other organic contawinants ~,'.from onulte waste disposal areas t(> groundwater, surface soils, and surface J,..waters. They also provided time to evaluate the nature and extent of the ",* '^',threat posed by the wastes burled on the Vertac site.' - :'

As a result of studies and evaluations performed by Vertac and Its contractorsand by the government j)artie^ and their contractors as contemplated by the / ,Consent Decree» we now have a ffiiore thorough understanding of the contain!- f' ';nant problems on the Vertac site than prior to the filing of our Consent-;^,.Decree. These studies and evaluations lead us to the following conclusions: ' :•-

The wastes present In'and around the Reasor Mill and North WasteOliposai'Areas are not now burled In a manner that provides adequateassurance of containment and protection of human health and the envt-

^ronreent.:'"" ..:'. ' • • . • ' - , . , • - ' . . " • - ;\ ' - ; • - ' • •

1)

• > ' '.«•-»'2) The Vertac proposal to merely monitor, for,aTlpractical purposes,*

these.disposal areas Is unacceptable. Two basic concerns are not

addressed by the proposal. First, It provides little or no enhancedcental raaent of wastes and second. It provides no assurance thatall possible routes of migration (1.e.» downward vertical migrationof contaminants to deeper subsurface layers) will be mitigated.

3) Due to the extreme toxicity of TCDD and the potential for migrationof TCOD and other organic contaminants through the subsurface,a secure form of containment or disposal of these materials 1sessential.

In our view, the choice of remedies at these sites should focus on adequafpermanent containment, or destruction of the wastes. Adequate containmentmay prove extremely difficult due to the presence of organic solvents andthe inadequate disposal practices employed In the past at the site. 0

0Also concerning containment, we note that EPA's RCRA regulations require cocertain stringent control measures (i.e., liners, leachate collection ,-„systems, prohibition of liquid wastes, etc.) in hazardous waste landfills.The reasoning behind these requirements is simple: EPA feels that lesser °control measures do not provide the degree of assurance of containment that 0is appropriate for the extremely hazardous materials put in these landfills*

It is our position, therefore, that if the wastes at the Reasor Hill andNorth Waste Dispoal areas could be contained onsite, then that containmentmust be effective. The containment must be carried out in a manner whichprovides a degree of protection at least as stringent as that contemplatedby RCRA.

We also note that our concerns about landfilling dioxin contaminated wastesat the Vertac site have been conveyed to Vertac in the past, most parti-cularly in correspondence dated July 13, 1982, concerning disposal of the coft"tainerized wastes now stored on the site. This correspondence, which perfi"*"to facilities which EPA believed to be appropriate to for handling those w*»t*1*included a copy of a memorandum dated Hay 13, 1982 from Suzanne Rudzinski,Acting Chief, Special Regulation Branch, Office of Pesticides and ToxicSubstances, concerning the containerized wastes at the site. Ms. Rudzinskistated:

"Me advise against landfill disposal of any of Vertac's wastes intheir current form and therefore have not Included any landfill sitesas potentially appropriate. This recommendation is based on: 1 )uncertainty about the leaching of dioxins from soils when organicsolvents are present; 2) recent Resource Conservation and Recovery Act(RCRA) regulations preventing landfilling of free-standing liquids;and 3) the high concentration of TCOD in the 2,4,5-T wastes."

This memo went on to say that "all parties consulted during preparation ofthis response are agreed that incineration is the only technically feasibleprocess at present for destroying these wastes."

Although that memorandum pertained to the barrelled wastes, information aboutthe landfilled wastes, such as set forth in the ten items enumerated above»raises precisely the same thrae concerns mentioned in the Rudzinski memoranda*that is:

1) both dioxins and organic solvents have been shown to be present1n subsurface soils on the Yertac site;

2) freestanding liquids have been dumped 1n one or more of thedisposal areas on the Vertac site; and

3) toluene still bottoms from 2,4,5-T production have been stated bya Hercules representative to have been dumped 1n the North WasteDisposal Areas, and toluene still bottoms contain high concentrationsof TCOD.

While we recognize that there may be additional factors to consider whendealing with the buried, as opposed to containerized wastes, we nonethelessbelieve that the conclusions presented in our July 13, 1982, correspondenceare applicable here; that is, utilization of landfills for the wasteson the Vertac site is likely to be ill-advised, and incineration maywell be the preferred method for handling there. '~

0Consequently, it is our position that the remedial measures suggested by GOVertac are insufficient to provide the stringent environmental safeguards c\lnecessary for wastes of this nature. We also believe that further evalua- Qtions of alternative remedial measures, beyond what is now before theAgency, are necessary to provide a sound basis for selection of the most 0effective remedy at the site.Cooling Water Pond, Central Ditch, and East DitchAs mentioned earlier, the Vertac remedial proposal for the Cooling WaterPond is to place its sediments on its eastern shore and then to attemptto contain them with a barrier wall and a cap. The Vertac proposal forthe Central Ditch is to remove its sediments to the cooling pond sedimentarea and then to backfill the Central Ditch area with compacted clay. TheVertac proposal for the East Ditch is to bury its contaminated sedimentsin place and to install a new ditch nearby.After consideration of these proposals, we have determined that theygenerally do not provide the environmental safeguards we deem appropriatefor the hazardous conditions they attempt to remedy. We are concernedthat the Vertac proposal for the Cooling Water Pond sediments would leavethem vulnerable to washout from heavy rains and floods. Further, due tothe extremely hazardous nature of these sediments (TCDD concentrations of2.826 to 9.981 parts per billion (ppb) in four samples, with the averagebeing roughly 5 ppb, were found by Vertac's contractor, although an EPAsample acquired in April 1981 showed a concentration of 892 ppb; seven EPAsamples acquired in September 1979 showed TCDD concentrations ranging from2.15 ppb to 102 ppb, with the average being roughly 29 p p b ) , we feel thatmaximal care should be used in disposing them.Consistent with the above discussion on the ultimate disposition of materialsin the Reasor Hill and North Waste Dispoal Areas, it is the Agency's positiontnat adequate containfnent of the Cooling Water Pond wastes may difficult,if not impossible, and that incineration may be the preferred remedy.Also consistent with our earlier discussion, if some torn of onsite contain-

roent 1 s determined to be sufficient, then we recommend that RCRA requirementsbe used as guidelines, at a minimuia, for disposal of these sediments.

Since the levels of contanination In both the Central Ditch and the EastDitch appear so similar to the sediments of the Cooling Water Pond, werecommend that wastes froro both ditches be handled In the same manner asthe Cooling Water Pond.

Rock and Rubble Repository

Vertac has proposed to build a rock and rubble repository atop the NorthHaste Burial Area In its approximate center. Since traffic to and fromthis repository would Interfere with maintenance of the clay cap on theNorth Waste Burial Area, and since this repository would have to be removedand relocated should the North Waste Burial Area ever have to be exhumed,we request that Vertac not dispose of its rock and rubble as proposed. Weinstead recommend that these materials be placed in a properly permittedlandfill or that they be stored in the clay borrow area to the north end of °the Vertac property. 00

CM

(MGroundwater Monitoring Q

If the buried wastes and sediments are disposed of offsite or destroyedby incineration then little or no waste materials capable of migrationwill remain onslte and provide a need for long-term monitoring. We wouldtherefore propose that Vertac monitor the wells they proposed to monitor,and that they Include well 18, on six month intervals for a period of atleast several years subsequent to cleanup activities. This monitoring shouldverify that the remedial work has eliminated or greatly reduced any migrationof contaminants, and it will establish If any further monitoring or remedialwork is appropriate. Should some form of onslte containment be employedthen modifications of Vertac's monitoring proposal may be warranted. At aminimum, well 18 should be sampled with the other wells Vertac proposed tomonitor. Should continued offsite migration of contaminants be disclosed, thecompany must undertake whatever additional remedial measures are appropriate.

Former Equalization Basin Area

This area, highly contaminated with TCDD and a variety of organic solvents,was closed pursuant to the Preliminary Injunction. Closure consistedof draining the basin liquids, solidifying the sediments, and installingan upgradient cutoff wall, a clay cap, and a downgradient trench drain.Closure was required because of the highly hazardous nature of the wastesin the basin and because of the substantial migration occurring from thebasin as evidenced by contamination from a surap below the equalizationbasin (see EPA analytical report dated July 25. 1979, sample y7. Attachment II).

In your proposal of February 21, 1983, you presented no remediation for thisarea. Since migration of contaminants appears to be occurring from this area(your tetter of February 15, 1983, indicates that leachate collected in thefrench drain downgradient of this area has averaged two gallons per day overthe life of the installation), and due to the highly hazardous nature of thesewastes, the EPA feels that the only ultimate solution to the contaminant migrationproblems in this area is to remove these hazardous materials and incinerate

03107317

them. Ons-ite containment of these wastes In their present location shouldprovide socoe degree of Immobilization, but the presence of organics in thesewastes will make complete iamobilization unlikely. Onsite containment ofthese wastes will therefore provide only a delay of problem manifestation,rather than an elimination of that problem.As before, however. If onslte containment 1s eventually chosen as theappropriate remedy, then the EPA recommends use of its RCRA Regulations asguidelines, at a minimum, for containment of these wastes.Lake DupreeThe report from Environmental and Toxicological Consultants, Inc.. dated - _March I, 1983» presents two remedial options for Lake Dupree. These optionsinvolve inverting some of the contaminated sediments with removal ofcontaminated f1sh and monitoring of restocked fish. In a Vertac letter r<dated March 22, 1983, a third option is presented. This third option oInvolves fining Lake Dupree with dirt and municipal garbage and then QQconverting it to either a golf driving range or an archery range.To date we are aware of no written statements from Vertac regarding which 0option It prefers. The EPA agrees, on a conceptual basis, to the third 0option for Lake Oupree. A detailed design will of course have to becompleted before the EPA will approve actual implementation of this plan.The EPA win consider delaying implementation of tne Lake Dupree remedialwork until after remedial work at the Vertac site is complete in order toprevent recontamination of the Lake Dupree area prior to the end of theVertac site cleanup.Concluding RemarksWe have indicated above our view that adequate containment may be extremelydifficult and that incineration may prove to be the preferred remedy fordisposing many of the contaminated materials on the Vertac site. Clearly,before choosing any remedy, it is essential that a detailed evaluation of anappropriate remedial alternatives and their expected effectiveness be completed.Vertac"s contractor. Developers International Services Corporation ( D I S C ) , intheir reports of October 1982 and December 1982, presented an environmentalstudy of the Vertac site and very brief descriptions of a few remedial alter-natives for various problem areas on the Vertac site. Their descriptionspresented little or no assessment of the effectiveness of their remedialalternatives. Further, their assessment of various onsite containmentstrategies was superficial at best, and their evaluation of offsite optionswas nonexistent. Incineration was not even mentioned as a possible alternative.The Court in this case has found that an imminent and substantial endangementnay be presented by the Vertac site. The Consent Decree contemplated thatremedial measures which would protect against that endangerroent to humanhealth or the environment, including protection against migration of pollu-tants from the Vertac site into the environment, would be studied. Theinformation concerning the site indicates that migration of pollutantscontinues and will continue in the future. It is the Agency's position thatVertac's proposal to implement minimal remedial measures is inconsistentwith the goals of the Consent Decree, since it would not adequately protect

0310»7318

against endangennent to human health or the environment. Morever, becauseof limited discussion of remedial alternatives by Vertac and DISC, It IsImpossible to confidently determine which alternatives would be most appropriatefor the site.

Therefore, in order to fully evaluate alternative remedial measures as contempiatecby the Consent Decree, and in order to remedy the deficiencies in the proposalsby Vertac and DISC. we are initiating work by an EPA contractor, CHgM-Hill,in which additional remedial alternatives will be examined. CHgH-Hin winconduct a Remedial Investigation and Feasibility Study (RI/FS) which will buildupon the information developed by DISC.

Of course, if Yertac agrees to have contaminated materials on tneir Jacksonvillesite incinerated, then there will be no need to complete the RI/FS that weare Initiating. We are therefore prepared to terminate CRgM-Hill's RI/FSat any time. It is only to prepare for a possible need, not a certain ^one, that we are initiating CH^M-Hill's RI/FS, and we are doing so know1ngC>that our negotiations with Vertac could render it unnecessary. 00

CMAdditionally, if Vertac incinerates their contaminated materials themselves^or if they hire a contractor to do so, a detailed safety plan will have tobe developed before any burns are conducted. Should the government proceed^with the RI/FS, then that study will address safety issues which would beimplemented during the ensuing cleanup.

The anticipated schedule of CHgM-HUTs RI/FS is that CHgM-HHI willbegin their studies immediately upon completion of EPA contracting pro-cedures, and they should complete them within twelve months of theirinitiation. Their final product will contain an evaluation of potentialremedial options; it will present an assessment of the effectiveness,feasibility, and costs of the various options. The RI/FS is expected tocost $750,000.00, for which we intend to seek reimbursement from eitherVertac or Hercules, or both.

Should we proceed with the RI/FS described above, there are several workitems that can be undertaken while the RI/FS is being completed. Thesetasks include the construction of the cooling towers which will replacethe cooling water pond, repair of any eroded portions of the existingclay caps, efforts to find disposal options for the barrelled wastes,and cleanup of Lake Dupree. Further, in order to temporarily collectany subsurface migration while the RI/FS is being conducted, we recommendthat frenchdrains be installed downgradient of the burled wastes at boththe North Disposal Area and at Reasor Hill. Detailed plans for any suchinterim measures undertaken while the RI/FS is being completed must besubmitted to and approved by EPA and the AOPC&E, prior to their implementation.

If you would like to discuss any of the issues presented herein, please donot hesitate to contact me, and we will arrange a meeting at our earliestconvenience.

Sincerely,

Dennis Guild 03107319; - - - • • • • * ~ 1 r.' n " i n .1 r- f

"'TT,•'•'•^WVi^ v-":': -•'-.; ».]«., -.' .<:• .^ ^•'^~•\-t-t/^^o^'^^^».^^''^^-•;'•^.sS2^^^^''^^ •''^"•'•v^-; --•„—.-?• -.-.. .-??-

UNITED ITES ENVIRONMENTAL PROTECTION ENCY

10

cc: Dr. PhyUls Garnett. ADPCSEDoug Kellman, HerculesAllan Gates, EsquireN. M. Norton, Jr., EsquireGus 8. Nalton. Jr.. Esquire

bcc: Doice Hughes, ADPC&EAnn Gailis, DOJMike Kilpatrick, WH-527Ann Strickland, EN-329Roger Meacham, 60PA

m000(N00

-ffd U^60RC:GUILD:dt:x9704:6/21/83 03107320^ CONCURREMCES

SYMBOL \

SURNAME ^

DATE \

•••• te.....Ka ..'

!r -?^

W--DEP--,"tthaway.flM.^

^^y/yvc^'

® Soil Test Boring Location• Rocky Branch Elevat ion Locat ion

i^OTE: This plan is a copy of areduction of a drawing providedby the USEPA.

'BORING PLANV E R T A C - CPA C O N T R A C T NO. 6S -06 -0015J A C K S O N V I L L E , ARKANSASSCALE: Vs ^00' SWL JOB NO. 79082 S

A T T A C H M E N T I.SOUTMWCSTC' 'M LABOB *rOR)( • .

03107321

A T T A C H M E N T I I

Also observea at low tevs'is (concentrations no: calculated) weresevera'i Cp, and Cy hyarocaroons sucn as cyc'ionexanfc, metnylcyclopen-tane, anQ'methy'lcyclonexane. A Cp HI- nyarocarDon was observed intne base/neutral extract a.t about"! 500 ug/',.

6. HNB Sample No. 2042. Field Sample No. 7

Sump below Equalization Basin. Taken at 1400 hours, 5 /16 /79 .Liquid sample.

Parameter Analyzed Concentration Found

Antimony, Sb <20 ug/1 (ppb)Arsenic, As <20Beryllium, Be <20 " p.r-Cadmium, Cd " 30 "Chromium, Cr 7.700Copper, Cu 80 " c0

Lead. Pb 780 " C^Mercury, Hg 460 " 0N i c k e l , N1 530 " oSelenium, Se <10Silver, Ag ' 40Thalliurn, T1 <20Zinc, Zn 380Cyanide, Total as CN <10Phenols, Total by 4AAP 557,000

Chlorinated Pesticides and Herbicides by GC/ECD

Extract analyzed for pesticides required 1 5 X 10^ /1 dilution to over-come interferences. No pesticides detected. D.L. = 30 mg/1 (ppm).

*2,4-D 3 , 1 9 0 ing/I (ppm)1

2,4,5-T 4,7402,4,5-TP (Si lvex) 8,471

*Note: Units of reporting for herbicides in this sample are mg/1(ppm), not ug/1 (ppb) .

Organics by GC/MS

Volatile organics fraction sample could not be located by theanalyst. Compounds reported below are those identif ied in the base/neutral and/or acid extracts.

Chlorototuene 1 ,900 ug/1 (ppb)Trichlorobenzene 1 , 5 0 0 "Tetrach1oroben;sne, isoTer 1 4,200 "

, 1 sorer 2 1 2 , 0 0 0

03107322

(HNS 2042 - Oroamcs Dy GC/yS.i - Continue:

Tnch'ioromeuioxv oenzene 1 ,20CDicniorodimetnoxy oenzens, isomer 1 27C

, isomer 2 680 "Cg ester of 2,4-D 50,000Cg ester of 2,4,5-TP (Ester of s i l v e x ) 3,500Cg ester of 2.4,5-T, isomer 1 7,500

, isomer 2 34.000Chtoropnenol ' 8,200Dichlorophenot, isomer 1 50,000 "

, isomer 2 302,000Trichlorophenol, Isomer 1 13,000 "

" , Isomer 2 64,000Phenol (specific compound) 2..300 " Q-)

0CO

7. HNB Sample No. 2043, Field Sample N o . 9Cooling Pond Discharge. Taken at 1445 hours, 5 / 16 /79 . Liquid ^\j

sample. 00

Antimony, Sb <20 ug/1 (ppb)Arsenic, As ' ' <20Berynium, Be <20 "Cadmium, Cd <20 "Chromium, Cr <20 "Copper, Cr <20Lead, Pb <20Mercury, Hg < 0.2 "Nickel, Ni <20Selenium, Se <10 "Silver, AS <20Thallium, T1 • <20Zinc, Zn <20Cyanide, Total as CN < 1 0 "Phenols, Total by 4AAP 26

Chlorinated pesticides and herbicides by GC/ECD

Dieldrin 0.006 ug/1 (PPb2,4-D 20.22,4,5-T 1 7 52,4,5-TP 506

Orgam'cs by GC/MS

No organic compounds were observed in any of the fractions analyzedby GC/MS other than a trace of bis (2-ethylhexyl) phthatate, aprobable extract contaminant.

03107323