33

Eli Lilly and Company

Lilly Corporate CenterIndianapolis. Indiana 46265

(317)276-2000

October 28, 1987

REGISTERED MAILRETURN RECEIPT REQUESTED

U.S. Environmental Protection Agency230 S. Dearborn StreetChicago, Illinois 60604

Attention: Mr. Tim Conway

Dear Mr. Conway:

Re: Pristine, Inc., Superfund Site, Reading, Ohio

Attached for your information is a report by Dames and Moore on theirobservation of EPA's contractor's operations in the Pristine Phase IIRemedial Investigation Field Program. The report identifies wherefield data collection procedures were inconsistent with the supplemen-tal Quality Assurance Project Plan (QAPP) dated April, 1987. ThePristine Group feels that these inconsistencies will have an impact ondata interpretation, particularly where the data are compromised bycontaminated drilling tools and insufficient field wash blank samples.

Please include this report in the Administrative Record for this site.

Yours truly,

Donald L. Sullivan, ChairmanThe Pristine Group

DLS:pw

cc: Mr. Joseph Duff icy, EPA (w/enclosure)Ms. Mary Tyson, EPA (w/enclosure)Ms. Lynn Peterson, EPA (w/enclosure)Ms. Gloria McKinley, General ElectricMr. Fred Erdmann, Dames & MooreMr. David Ross, Procter & Gamble EPA Region S Recorfs Ctr.Ms. Jane Hessler, Eli Lilly -------

223903

REPORT ON OBSERVATION OFPRISTINE PHASE II REMEDIALINVESTIGATION FIELD PROGRAM

OCTOBER 26, 1987JOB NO. 15784-003-17

Dames & Moore

REPORT ON OBSERVATION OFPRISTINE PHASE II REMEDIALINVESTIGATION FIELD PROGRAM

OCTOBER 26, 1987JOB NO. 15784-003-17

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L I N N STRI-.LT. Mm VI . I ' lS l ' lNNATI. O I I K ' 4=>.\M nMi M = . | . »44.'

October 26, 1987

Pristine Groupc/o Eli Lilly &. Company307 East McCarty StreetIndianapolis, IN 46285

Attention: Mr. Donald L. Sullivan, Chairman

Gentlemen:

Re: Final Report on Observation of PristinePhase n Remedial InvestigationField Program

This letter accompanies one copy of Dames & Moore's report on observation of theEPA's Pristine Phase n Remedial Investigation field program. We enjoyed conducting thisinvestigation. If there are any questions regarding the report and its findings, please do nothesitate to contact us.

Very truly yours,

DAMES & MOORE

Dennis P. ConnairGeologist

Jennifer D. JohnsonProject Geologist

W. Erdmann, P.E., C.P.G.Associate

JDJ/FWE:P/R4(m)

1.0 INTRODUCTION

Following completion of Phase I of the Remedial Investigation (RI) at the Pristine,

Inc. site, the U.S. Environmental Protection Agency (EPA) developed a plan for a Phase n

RI study, designed to provide additional information in support of a feasibility study (FS)

for the Pristine site. The scope of work for the Phase n RI study was presented as part of

the supplemental Quality Assurance Project Plan (QAPP), dated April 1987 that was

prepared by Camp Dresser and McKee Inc.

Dames & Moore has been involved with the Pristine, Inc. site as a technical

consultant to the Pristine Group, and recently completed a detailed critique of the Phase I

RI report. The Pristine Group approached Dames & Moore to monitor the field activities of

the EPA REM n contractor, Roy F Weston, Inc., (Weston) during the Phase n RI Field

Investigations.

The Phase U RI field program was conducted from July 13, 1987 to August 2,

1987. Dames & Moore was notified of the field team's arrival by Dr. Riley Kinman on

July 15,1987 and was on site on July 16,1987 to monitor Weston's activities.

The types of information collected by Dames & Moore included the following:

• Dates and times of activities observed

• Deviations from the work plan and procedures specified in the QAPP

• General notes on observed procedures

• Description of subsurface conditions, general air monitoring results, siteconditions

Information and details of the items we consider to be significant arc presented in

this report. The first section describes the work plan, the stated scope of work and the

supplements that were made to it during the course of the field program. The next section

details the observations made during the performance of the Phase II activities (soil

sampling, ground water sampling, borehole drilling, well installation, and soil gas

monitoring), and quality control procedures observed by the contractor. There is a brief

P/R(4)(m) .j. Privileged and ConfidentialPrepared for Counsel

section on geologic conditions and lastly, the report gives a brief description of how the

Phase n RI data may impact the FS.

2.0 FIELD PROGRAM

Work activities scheduled for the field program, according to the supplemental

QAPP included the following:

• Ground water sampling of 18 existing wells (GW45-GW62) for volatileorganic compound analysis.

• Installation of two additional monitoring wells (GW66 and GW64) in the upperoutwash lens and two monitoring wells (GW63 and GW65) in the loweroutwash lens.

• Ground water sampling of the four new wells for CLP (Contract LaboratoryProgram) organics, inorganics and SAS (Special Analytical Services) flourideanalysis.

• Hydraulic conductivity testing of the four new wells by either bail down or slugtests.

• Five surface soil samples collected near the "magic pit" for CLP organic andinorganic compound analysis.

• Ten subsurface soil samples from two soil borings near the "magic pit"analyzed for CLP organic and inorganic compounds.

• Six subsurface soil samples collected during the installation of GW63 andGW65 for CLP organic and inorganic compound analysis.

• Eleven composited surface soil samples for dioxin/furans analysis.

• Two sediment samples for dioxin/furans analysis.

• Two incinerator residue samples for dioxin/furans analysis.

Activities supplemental to the work plan that were performed during the field

program include the following:

• Drilling, sampling, and installation of an additional monitoring well (GW67)screened in the lower aquifer.

• Drilling and sampling of an additional borehole (SB44) near the northeastcorner of the site.

P/R(4)(m) -2- Privileged and ConfidentialPrepared for Counsel

I

1

• Soil gas monitoring in the vicinity of the "magic pit".

• Hydraulic conductivity tests in the 18 existing wells.

The surface soil samples, sediment samples, and incinerator residue samples

intended for dioxin analysis were sampled well in advance (early June 1987) of the

remaining field activities. Dames & Moore did not monitor the June sampling activities.

3.0 FIELD OBSERVATIONS

Proper and consistent performance of field activities and maintenance of quality

control measures were often found lacking during the Phase II field program.

Observations to this effect are detailed here and grouped according to the type of field

activity.

3.1 SURFACE SOIL SAMPLING

Five surface soil samples were collected for source characterization in the vicinity of

the "magic pit" as shown schematically on Figure 1. Each sample was obtained in

accordance with REM JJ site investigation procedure manual from within two inches of the

surface in an area of approximately two-feet-square. One sample location was directly

beneath the ventilation exhaust fan from the interior of a Cincinnati Drum Service building.

This sample is likely to reflect a combination of source characteristics rather than solely the

characteristics of the "magic pit".

3.2 SUBSURFACE SOIL SAMPLING

Subsurface soil was sampled during the drilling of SB42 through SB44 and GW63

through GW67 (see Figure 1) for the purpose of lithologic description of the soils. The

original QAPP specified that subsurface sampling should be continuous to a depth of 15

feet, proceed at 2.5-foot intervals to a depth of 35 feet, and subsequently proceed at 5-foot

intervals to the planned final depth of the boring. The supplemental QAPP does not specify

a separate sampling scheme for the Phase II borings, but each of the originally scheduled

borings (SB42 and SB43 and GW63 through GW66) were sampled using a scheme of

sampling at 2.5-foot intervals to a depth of 35 feet, followed by 5-foot intervals to the final

P/R(4)(m) -3- Privileged and ConfidentialPrepared for Counsel

depth of the boring. This scheme was altered in the sampling of both SB44 and GW67.

No samples were obtained from SB44 and GW67 before depths of 28.5 and 38.5 feet,

respectively. Both were then sampled at 5-foot intervals to final depth. This amended

sampling procedure eliminated the opportunity of using the supplemental borings to further

define the character and extent of the upper outwash lens.

Samples for chemical analysis were taken from SB42, SB43, GW63, and GW65

as indicated in the supplemental QAPP.

3.3 BOREHOLE DRILLING

For use in onsite drilling of SB42, SB43, and GW63 the driller's augers and split

spoon samplers were decontaminated using a water rinse and steam cleaning. In offsite

drilling of GW64, GW65, and GW66 the augers were not decontaminated between uses

and in the sampling of GW64, GW65, GW66, GW65, and SB44 the split spoon samplers

were not decontaminated between uses, thus introducing the possibility of cross-

contamination.

According to the original QAPP, wastes generated by offsite drilling should have

been drummed for later disposal. During the Phase n RI field program, the drilling

wastes, both onsite and offsite, including hydraulic fluid discharged by the drilling rig

during the drilling of SB44 (onsite) were left in place without treatment.

3.4 GROUND WATER SAMPLING

The ground water sampling technique of some members of the field team involved

filling the sample bottles by pouring from the top of the well bailer, while for others it was

common practice to use a gloved hand to push back the bailer ball to start a flow of water

from the bottom of the bailer. The second technique could have led to contamination from

the glove and volatilization of the sample if the water flowed too forcefully from the bailer.

Conductivity, temperature, and pH readings were obtained at the time of sampling

for some of the ground water samples, including those from GW64, GW65, and GW67.

P/R(4)(m) -4- Privileged and ConfideniialPrepared for Counsel

However, for the majority of the remaining samples these readings were taken after the

sample was removed to another work site.

Sampling of GW63 was stopped on July 29,1987 and resumed after re-purging on

July 30,1987 allowing a time interval of 15 hours to pass between collection of portions of

the total sample.

Extra quantities of water (as much as 500 gallons) used in the installation of GW65

and GW67 should have warranted additional well development efforts to purge the

formation of the introduced water before sampling for chemical analysis. However, the

normal development procedures of bailing the well dry 24-hours before sampling was

followed for both wells.

A two-inch O.D. teflon bailer was used to sample all of the wells except for GW67

which was sampled with a polypropylene bailer. Dedicated, woven nylon cord was used

to lower and raise the bailers.

3.5 AIR MONITORING

Air quality onsite and offsite was monitored using an Organic Vapor Analyzer

(OVA) during activities such as soil sampling and borehole drilling. The purpose of air

monitoring was to maintain an assurance of safe working conditions and to screen samples

for gross contamination. Performance of air monitoring was in accordance with the

supplemental QAPP except on August 1,1987 when the OVA operator failed to notice the

improper functioning of the meter during the drilling of the first 10 feet of SB44.

3.6 HYDRAULIC CONDUCTIVITY TESTS

The Phase II RI workplan specified the use of the newly installed wells for aquifer

hydraulic conductivity tests. Baildown tests were conducted at three of the new wells,

GW63, GW64, and GW66. GW65 was too dry for use and the testing of GW67 was put

off until after the initial Phase II field work was completed.

P/R(4)(m) -5- Privileged and ConfidentialPrepared for Counsel

Supplemental to the Phase E workplan, conductivity tests were conducted at the 16

of 18 Phase I wells that contained measurable quantities of water. At least 5 of the 16 wells

were tested using a Hermit® probe slug test rather than a baildown test Slug tests using a

Hermit® probe involve the recording of pressure changes near the bottom of the well as a

solid slug of known volume is lowered into the water column or raised out of it. A

baildown test is considered a type of slug test, but in this case the volume removed from

the well is a quantity of water and the aquifer reaction is measured as the recovery of the

water level in the well rather than a return to equilibrated pressure within the well as

detected by an electronic pressure transducer. The potential for discrepancies between the

two types of tests should be given full consideration.

Baildown and Hermit® probe test procedures were appropriately performed at each

well with the exception of GW64. At GW64 the field personnel compromised the value of

a baildown test by introducing the Hermit® slug to the water column between the 60 and

120 minute baildown recovery readings, thus disturbing the natural recharge of the well

3.7 DECONTAMINATION

During the field activities prior to July 22, 1987 some members of the field team

were using an acetone rinse as part of decontamination procedures while others were not

In addition, the grade of acetone (reagent grade) was not up to standards required in

standard professional practice (pesticide grade), the acetone container was made of plastic,

which is known to dcsorb certain compounds when in contact with acetone, and there were

no field wash samples taken to verify the quality of the decontamination procedures. After

the Dames & Moore representative raised concerns on the subject on July 22,1987, the use

of acetone in decontamination procedures was stopped.

Procedural inconsistencies such as those observed in the decontamination

procedures for sampling equipment were, in part, caused by the lack of a complete QAPP

document for the second phase RI and the resultant need to consult rwo or more documents

to reference proper procedures. Another factor was a lack of communication between

members of the field team. This problem was compounded by a change of personnel rwo

days before the end of the field program.

P/R (4 )i m) .5. Privileged and ConfidentialPrepared for Counsel

4.0 GEOLOGIC CONDITIONS

The addition of GW67 and SB44 (Rgure 1) to the list of field activities was advised

by the Weston office after the drilling of GW65 to a depth of 77 feet failed to reveal the

lower boundary of the lower outwash lens and the glacial till unit that was expected to

underlie it Drilling of SB44 revealed the till at a depth of approximately 40 feet but no

trace of till was found in GW67. The effort to find the location of the glacial till was made

in order to determine the feasibility of placing a slurry wall along the eastern boundary of

the site to contain contaminants. The feasibility of a slurry wall depends on the ability to tie

into an underlying impermeable layer such as the till.

At GW67, materials that are believed to be part of the lower outwash lens of the

upper aquifer system are much thicker than similarly designated deposits to the west and

north. In addition, they are in direct contact with deposits that are believed to represent the

middle outwash lens above and, because of the absence of the till layer, the lower aquifer

(public water supply aquifer) below. A rapidly drawn conclusion about this condition is

that at the southeast comer of the site (in the vicinity of GW65 and GW67) water draining

through the middle and lower outwash lenses of the upper aquifer will reach the lower

aquifer many times faster than at other locations onsite.

5.0 CONCLUSIONS

The problems described in Section 3.0 above should be addressed in the final

analysis of data generated by the Phase IIRI. Procedural inconsistencies in sampling and

decontamination constitute the most serious problems with the Phase H field investigation.

Without back-up information such as field wash blank samples and complete

documentation of procedures, the value of analytical data generated from the samples is

compromised.

The impact of the geologic conditions revealed at GW65 and GW67 should involve

significant changes to the original modeling of the site geology and consequently

modifications to the calculations of contaminant movement and the assessment public health

risk. In addition, the construction of a slurry wall containment system around the Pristine

site no longer appears to be a feasible atemative.

P/R(4)(m) -7- Privileged and ConfidentialPrepared for Counsel

III APPENDIX A

SAMPLING ACTIVITIES

II

Sample Location

SS01 through SS05SB43GW63GW65GW67

Sample Medium

Surf ace soilSubsurface soilSubsurface soilSubsurface soilSubsurface soil

Time

17:0010:0015:008:308:30

Date

07/16/8707/22/8707/22/8707/29/8707/31/87

GW52GW48 and GW57GW61GW59GW60GW58GW54GW56GW62GW50,GW51andGW53GW66GW63

GW 65 and GW67

GroundGroundGroundGroundGroundGroundGroundGroundGround

waterwaterwaterwaterwaterwaterwaterwaterwater

Ground waterGround waterGround water

Ground water

16:309:3015:3016:3017:3011:2015:3013:3015:15

11:0016:0020:0011:0010:00

07/16/8707/17/8707/20/8707/20/8707/20/8707/21/8707/21/8707/21/8707/21/87

07/23/8707/29/8707/29/8707/30/8708/02/87

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