DATA ACQUISITION REPORT LEMON LANE LANDFILL BLOOMINGTON, INDIANA AUGUST, 1995 PREPARED FOR: Citizens Opposed To PCB Ash In Monroe County (COPA) PREPARED BY: ECO 106 Robinson Street Ashland, Virginia 23005 (804) 798-4305 TABLE OF CONTENTS PAGE 1.0 - EXECUTIVE SUMMARY 1 2.0 - DATA ORGANIZATION RATIONALE 2 3.0 - LEMON LANE LANDFILL DATA 4 4.0 - DATA GAPS NOTED 4 5.0 - CONCLUSIONS 5 6.0 - RECOMMENDATIONS 7 7.0 - DATA SUMMARY CHARTS 8 THIS DOCUMENT PRINTED ON POST-CONSUMER RECYCLED PAPER UTILIZING NON-TOXIC INKS 1.0 - Executive Summary Pursuant to a Freedom Of Information Act (FOIA) Request submitted by Citizens Opposed to PCB Ash in Monroe County (COPA), the United States Environmental Protection Agency, (EPA), Region V has released numerous boxes of documents utilized as functional equivalents for remedial investigation and feasibility study data normally produced in the course of a Comprehensive Emergency Response and Liability Act (CERCLA, commonly referred to as Superfund) site clean-up. The information released relates to five Superfund sites located in the vicinity of Bloomington, Indiana that were contaminated with Polychlorinated Biphenyls (PCBs) through disposal of electrical capacitors, and associated waste and debris. These sites are being remediated under a Consent Decree that specifies incineration as the preferred remedial alternative, rather than being subjected to normal Superfund decision-making and clean up processes. Because all work proceeding at the sites is governed by the standing Consent Decree rather than relevant federal law and process, no Remedial Investigation (RI) or Feasibility Study (FS) reports have been produced in accordance with normal protocol or EPA guidance. COPA has tasked ECO, its Technical Advisor with organizing and reviewing the FOIA documentation to determine the nature and quality of the available data for each of the Consent Decree sites. 2.0 - Data Organization Rationale EPA's response to the COPA FOIA was extremely voluminous, consisting of approximately eighteen file boxes of paper. All documents provided were randomly packed in the boxes, and were not segregated or organized. Bundles of unrelated information were packed together, numerous duplicate documents and paperwork that could not be logically related to any of the sites was included. At COPA's direction, ECO has preliminarily organized the information by named site, and in chronological order. General documents are filed by subject (i.e., Dioxin, Interviews, PCB information etc.) and chronology. Documents and paper fragments that are undated, illegible or which appear to bear no relation to the sites has been inspected, bundled together and set aside. After having completed general organization of the data, ECO has begun review of the provided information. This data acquisition report is specific to the Lemon Lane Landfill, and was prioritized for review because the site is due to undergo further sampling work. 3.0 - Lemon Lane Landfill Data FOIA information reviewed for this report includes every document and major reference in general documents related to the Lemon Lane site, or its off-site impact areas. ECO staff completely read and summarized each document provided in this regard. ECO's summation of these extensive data reviews includes date, type of document, title if supplied, author, subject and notes as to document content for each piece of information provided subsequent to the FOIA request. All data is entered into information tables in chronological order. 4.0 - Data Gaps Noted Although the sheer volume of information supplied in response to this FOIA request is impressive, the actual quality and utility of the data is not. Of particular concern is the fact that a twelve sample dioxin analyses for Neal's and Lemon Lane Landfills are cited repeatedly, but no sample analyses documenting this dioxin characterization could be located. This is extremely significant in that it appears to be the only dioxin characterization ever performed at Lemon Lane Landfill to date. Likewise, the results of residential well testing performed in the vicinity of Lemon Lane Landfill are cited, but not supplied. Of additional concern, much critical information in the form of well and boring logs, field notes, and laboratory quality assurance/quality control data is illegible in the copies provided. No risk assessment calculations for long term exposure pathways could be located. Also of note, is the total lack of any information on various remedial alternatives for treating the wastes identified at Lemon Lane. Neither is the Consent Decree alternative of solid waste fired incineration discussed, or adequately justified as required by the National Contingency Plan. 5.0 - Conclusions Although the documentation and paperwork supplied in response to COPA's FOIA was to have constituted a functional equivalent of information routinely gathered and published in Superfund Remedial Investigation and Feasibility Study reports, the data provided does not meet even a minimum threshold for quantity, quality or sufficiency. This has implications for the future of this site in that sufficient information and data is absolutely pre- requisite to choosing and designing a clean up strategy for Lemon Lane Landfill. The planned sampling effort for Lemon Lane is being criticized as seriously inadequate for characterization and remedial design purposes. Review of previously reported information vividly demonstrates that inadequacies in the planned sampling event cannot be remedied by reliance on previous work. In conclusion, there is no documentation to suggest that Lemon Lane Landfill has been subjected to either the quality or quantity of investigation that is required and performed at every other Superfund site in America. This cannot be justified. The wastes likely present at this site are extremely toxic to human and animal receptors at extremely low concentrations. These toxic substances are readily available at Lemon Lane Landfill through groundwater contamination, surface water run-off and dust migration to residential areas that directly abut the site. Furthermore, there has been continual evidence that numerous areas of concern have not been enclosed by the existing security fence. Finally, non-thermal, on-site technologies that destroy the waste types at the site are now commercially available. It is irresponsible to continue to fail to document relevant remedial options in a full scale, EPA prepared and approved Feasibility Study required to move the Superfund process towards the overdue and required goal of total remediation. 6.0 - Recommendations * The community should demand immediate work to facilitate preparation of both a Remedial Investigation and a Feasibility Study fully in accord with EPA technical guidelines * The community should question EPA policy decisions to limit work that is reimbursable to the government because of pending budget cuts * The community should demand that the Consent Decree which is obsolete, be dissolved, with immediate adherence to normal Superfund process * Comprehensive dioxin and furan characterization must be performed at both Lemon Lane Landfill and related off- site areas * Periodic sampling of all residential drinking water wells must be instituted * Baseline risk calculations must be provided and presented in EPA approved format * Community must utilize information resources such as the public information repository and COPA Computer Bulletin Board 7.0 - DATA SUMMARY CHARTS Each document is presented as follows: DATE TYPE AUTHOR/RECIPIENT TITLE/SUBJECT/NOTES ________________________________________________________________ 07/27/81 letter from R. Peoples, City of Bloomington RE: 2 SOIL SAMPLES TAKEN FROM MULLIS PROPERTY LOCATED AT 1204 LINDBERG DRIVE LOCATED NEAR LEMON LANE LANDFILL NOTES: SAMPLES ANALYZED AT 330,000 ppm AND 1700 ppm PCB 1242 ________________________________________________________________ 08/15/81 memo to W. Minor, EPA NOTES: REGARDS SAMPLING EFFORT AT LEMON LANE FROM 6/30- 7/1/81; DESCRIBES THE SOIL SAMPLING EFFORT, BUT NO ANALYTICAL RESULTS FROM THE SAMPLES ARE INCLUDED OR ATTACHED ________________________________________________________________ 08/26/81 memo to G. Vanderlaan NOTES: RECOMMENDS WIDESPREAD SAMPLING EFFORT FOR LEMON LANE ________________________________________________________________ 04/23/82 contract between EPA and State of Indiana NOTES: STATES THAT EPA IS CURRENTLY PERFORMING EXTENT OF CONTAMINATION STUDIES AT NEAL'S LANDFILL AND DUMP AND LEMON LANE ________________________________________________________________ 11/00/82 report FIELD INVESTIGATION OF UNCONTROLLED HAZARDOUS WASTE SITES NOTES: CONTAINS SPRING SAMPLING DATA; NO DATA REPORTED FOR PCBs; DIOXIN/FURAN CONTAMINATION NOT ANALYZED ________________________________________________________________ 11/08/82 letter to J. Highland RE: BOUNDARY SURVEY FOR LEMON LANE LANDFILL NOTES: BOUNDARY PLAT IS ATTACHED ________________________________________________________________ 11/17/82 memo from O'Brien & Gere RE: GEOLOGICAL INVESTIGATION AND SELECTION OF MONITORING WELL LOCATIONS NOTES: 5 WELL LOCATIONS SELECTED; DOCUMENT CONTAINS BORING LOGS; STATES THAT CONTAMINATION AT ILLINOIS CENTRAL SPRING DUE TO PEOPLE MOVING THE CAPACITORS TO THAT AREA TO SCAVENGE THEM FOR SALVAGE; STATES THAT 7/82 SAMPLING OF SPRINGS IN THE VICINITY OF LEMON LANE WERE ALL NON-DETECT; SUPPORTING ANALYTICAL DATA NOT PROVIDED ________________________________________________________________ 01/16/83 letter to B. Magel RE: TRANSMITTING COPIES OF O'BRIEN & GERE FIELD NOTES NOTES: WELL INSTALLATION LOGS - MANY ILLEGIBLE ________________________________________________________________ 01/26/83 report RE: PRELIMINARY ASSESSMENT OF LEMON LANE LANDFILL NOTES: PROVIDES COPY OF ORIGINAL EPA PAPERWORK EVALUATING THE SITE; NO SUPPORTING DATA SUPPLIED ________________________________________________________________ 04/06/83 document ANALYTICAL RESULTS OF LEMON LANE GROUNDWATER SAMPLING NOTES: INCLUDES ONLY PCBs AND GENERAL WATER QUALITY PARAMETERS; HIGH CONCENTRATION AT 2.4 ppb NOTED AT WELL 4- D; NO WELL LOCATION MAP IS PROVIDED; DETECTION LEVEL SET ABOVE LEVELS OF REGULATORY CONCERN; NO TRIP LOG OR NARRATIVE PROVIDED; NO SAMPLE LOCATION MAP PROVIDED; NUMEROUS QA/QC PROBLEMS ARE NOTED WITH THE DATA REPORTED ________________________________________________________________ 05/06/83 document DRAFT BASELINE INITIAL REMEDIAL ACTION (IRM) NOTES: REVIEWED IN FINALIZED FORM AS 06/08/84 ENTRY ________________________________________________________________ 05/18/83 letter to J. Highland RE: DRAFT PROTOCOL FOR HOT SPOT TRENCHING PROGRAM NOTES: PROTOCOL FOR IDENTIFYING AREA OF VISIBLE CAPACITOR DISPOSAL; PROVIDES FOR BACK-FILLING OF WASTE; NO TREATMENT OR DISPOSAL ________________________________________________________________ 05/20/83 letter to O'Brien & Gere RE: DISPUTED SAMPLING PROTOCOL NOTES: PAGE 3 QUOTE " CERTAINLY, WE WOULD NOT WISH TO CREATE A SITUATION IN WHICH WESTINGHOUSE FELT IT WAS INAPPROPRIATE TO CONTINUE THIS INVESTIGATION BECAUSE THE EXTENT OF CONTAMINATION WAS POSSIBLY TOO GREAT. WE WOULD WISH TO AVOID SUCH A SITUATION AND BELIEVE WE CAN TAKE STEPS TO DESIGN THE FIRST PHASE TO PRECLUDE SUCH A POSSIBILITY." ________________________________________________________________ 06/06/83 document DRAFT REMEDIAL ACTION MASTER PLAN (RAMP) NOTES: RAMP PREPARED WITHOUT ALL DATA; GROUNDWATER MONITORING IS LIMITED TO 4 WELLS; EXTENT OF CONTAMINATION IS NOT DEFINED; AIR QUALITY UNDEFINED, BIOACCUMULATION NOT STUDIES OR MEASURED; PG.1-3 RAMP DOSE NOT PROVIDE FOR SPECIFIC REMEDIAL ACTIONS DUE TO LACK OF INFORMATION NECESSARY TO CONDUCT FEASIBILITY STUDY; PG.1-4 BEFORE ALTERNATIVES FOR REMEDIAL ACTION CAN BE ANALYZED, THERE MUST BE SUFFICIENT INFORMATION AVAILABLE TO EVALUATE THEM - GATHERING OF THIS INFORMATION WILL BE COMPLETED IN THE RI/FS; PG. 1-6 REQUIRED TASKS INCLUDE RESIDENTIAL WELL MONITORING, INSTALLATION OF ADDITIONAL GROUNDWATER MONITORING WELLS, GROUNDWATER SAMPLING, SOIL SAMPLING, AIR SAMPLING, SURFACE WATER SAMPLING AND PCB BIOACCUMULATION STUDY; PROVIDES SCHEDULE FOR PERFORMING RI/FS; STATES THAT MAGNETOMETER SURVEY OF THE SITE MAY BE INSUFFICIENT TO LOCATE CAPACITORS THAT ARE BURIED DUE TO THEIR RELATIVELY SMALL SIZE; PG. 2-6 NOTES THE BURNING OF PCBS AT THE SITE THAT COULD LEAD TO THE FORMATION OF HIGHLY TOXIC DIOXINS/FURANS ________________________________________________________________ 06/10/83 letter to J. Highland RE: RESPONSE TO LETTER REGARDING SAMPLING PROTOCOL ________________________________________________________________ 06/20/83 letter to J. Karaganis RE: ASSURING CITY OF BLOOMINGTON CONTINUED ACCESS TO FENCED LEMON LANE LANDFILL SITE ________________________________________________________________ 07/08/83 letter B. Magel to Westinghouse legal counsel NOTES: LETTER ASKS WESTINGHOUSE IF THEY WISH TO ENTER INTO NEGOTIATIONS REGARDING LEMON LANE ________________________________________________________________ 07/11/83 memo from O'Brien & Gere RE: O'BRIEN & GERE'S ACCESS TO LEMON LANE LANDFILL HAS BEEN ELIMINATED BY THE FENCE ________________________________________________________________ 09/13/83 comments to RAMP State of Indiana NOTES: INDIANA TAKES THE POSITION THAT NO NEED FOR DOOR TO DOOR ADVISORY REGARDING POTENTIAL DANGERS AT LEMON LANE; NO NEED FOR EXTENSIVE STREAM SAMPLING ________________________________________________________________ 12/12/83 phone memo Barbara Magel (EPA Region V attorney) NOTES: BASED ON A CONVERSATION WITH A DR. WELTY, MAGEL WANTS NEAL'S LANDFILL DATA EXCLUDED FROM LEMON LANE DATA DUE TO POSSIBILITY OF NEGATIVE RESULTS ________________________________________________________________ 01/25/84 position paper Westinghouse NOTES: STATES THAT THE LOCATION AND VOLUME OR REFUSE HAVE BEEN DETERMINED - THIS CONTRADICTS 1/27/84 POSITION PAPER ; PROPOSES 25 ADDITIONAL BORINGS AT LEMON LANE TO 30' DEPTH, PCB ONLY SAMPLING PARAMETERS ________________________________________________________________ 01/27/84 Position paper Westinghouse POSITION PAPER RELATED TO REMOVAL ISSUES NOTES: SUGGEST A SITE INVESTIGATION TO DETERMINE THE HORIZONTAL /VERTICAL LOCATION OF ORIGINAL REFUSE SURFACE, AND EXCAVATION AND REMOVAL OF ONLY DEBRIS ASSOCIATED WITH 1958 FORWARD WESTINGHOUSE DISPOSALS ________________________________________________________________ 03/14/84 report Blasland & Bouck Engineers RE: PRELIMINARY INVESTIGATION PROTOCOL NOTES: CALLS FOR 3 TEST BORINGS; 3 SAMPLES FROM THESE BORINGS TO BE ANALYZED FOR PCBs ONLY ________________________________________________________________ 03/20/84 document Westinghouse PRIVATE WESTINGHOUSE DOCUMENT NOTES: COMPANY POSITION THAT A CLAY CAP IS UNNECESSARY AT LEMON LANE, AND THAT WESTINGHOUSE MAY PETITION EPA TO FOREGO CAPPING BASED ON SAMPLING RESULTS PROVIDED BY THE COMPANY ________________________________________________________________ 03/22/84 letter from Westinghouse to U.S. Dept. of Justice RE: PROCEDURE FOR SAMPLING TO CHARACTERIZE LEMON LANE AFTER DEBRIS REMOVAL TO ESTIMATED 1957 LANDFILL SURFACE NOTES: THIS DOCUMENT IS PARTIALLY ILLEGIBLE DUE TO VERY POOR COPY QUALITY; CONCLUDES THAT 4 SAMPLES/ACRE WILL BE SUFFICIENT TO FULLY CHARACTERIZE REMAINING AREAS OF LANDFILL ________________________________________________________________ 04/26/84 letter to T. O'Mara from Daily & Associates Engineering Inc. NOTES: REGARDS THE SURFACE WATER RUN-OFF FROM LEMON LANE AND STATES THAT PONDING IN THE SOUTHWEST CORNER MAY HAVE TO BE ACCEPTED ________________________________________________________________ 04/30/84 document WESTINGHOUSE SOIL BORING RESULTS NOTES: BASED ON 3 BORINGS; INCLUDES BORING LOGS AND NUMEROUS ILLEGIBLE PAGES OF HANDWRITTEN NOTES ________________________________________________________________ 05/11/84 letter from G. Lee, Jr. to U.S. Dept. of Justice RE: 1958 TOPOGRAPHIC SURFACE OF LEMON LAND LANDFILL NOTES: STATES THAT WOULD BE USEFUL TO DETERMINE ACTUAL FILL DEPTH ________________________________________________________________ 05/21/84 memo to J. Highland RE: METHODOLOGY WITH REGARD TO 1958 LANDFILL SURFACE DETERMINATION NOTES: DEPTH TO SURFACE ESTIMATED USING AERIAL PHOTGRAMM TECHNIQUES; SEQUENTIAL AERIAL PHOTOS WERE USED IN STEREOSCOPIC FROM TO ESTIMATE THICKNESS AT VARIOUS TIME INTERVALS AND TO CREATE TOPOGRAPHIC MAPS; MANY PHOTOS INCLUDED IN THIS DOCUMENT ARE TO INDISTINCT TO BE REVIEWED ________________________________________________________________ 06/08/84 document SUMMARY REMEDIAL ALTERNATIVE SELECTION - LEMON LANE LANDFILL NOTES: MARKED ENFORCEMENT CONFIDENTIAL; 11 PAGES ONLY PROVIDED; FINAL UNDATED VERSION SUPPLIED SEPARATELY RECOMMENDS EXCAVATION AND INCINERATION FOR THE SITE AS PER THE CONSENT DECREE; STATES THAT LEMON LANE WAS NOT INCLUDED IN 1/93 JUSTICE DEPT. COMPLAINT AGAINST WESTINGHOUSE; PAGE 11 STATES " OFF-SITE REMEDY ACHIEVED BY THE CONSENT DECREE HAS BEEN DEVELOPED CONSISTENT WITH THE OBJECTIVES OF 300.68 E-J OF THE NATIONAL CONTINGENCY PLAN." - HANDWRITTEN COMMENTS REFERRING TO THE FOREGOING " CAN WE SAY THIS?"; NO DISCUSSION OF POSSIBLE REMEDIAL ALTERNATIVES IS PROVIDED ________________________________________________________________ 06/30/84 memo Dr. T. Hauser, EPA NOTES: $ 35,000.00 PROJECT SHORTFALL AND SUGGESTS CURTAILING LEMON LANE MONITORING AS COST SAVING MEASURE ________________________________________________________________ 08/01/84 memo from P. LaMoreaux, Sr. NOTES: STATES THAT PUMPING AND TREATING GROUNDWATER AT THE CONSENT DECREE SITES IS NOT ECONOMICALLY FEASIBLE ________________________________________________________________ 08/09/84 position paper Westinghouse POSITION PAPER FOR REMEDIAL ISSUES IN WESTINGHOUSE CASE PROPOSED SETTLEMENT NOTES: WELL DATA AT LEMON LANE INDICATED 3 DIFFERENT DIRECTIONS OF GROUNDWATER FLOW; WESTINGHOUSE OPPOSES GRIDDING, SAMPLING AND REMEDIATION TO 1 ppm, THEREFORE AGREEMENT TO EXCAVATE TO 1958 LANDFILL SURFACE AND REMOVE ALL WASTE AND DEBRIS TO THAT POINT CONTAMINATED AT CONCENTRATION ABOVE 50 ppm PCB ________________________________________________________________ 10/15/84 memo Region V FIT Team DRILLING AND SOIL SAMPLING AT NEAL'S AND LEMON LANE LANDFILLS NOTES: SCOPE OF WORK CALLS FOR ONE COMPOSITE DIOXIN SAMPLE TO BE COLLECTED FROM BENNETT'S QUARRY ________________________________________________________________ 12/04/84 document ENFORCEMENT DECISION DOCUMENT ________________________________________________________________ 01/16/87 memo from R. Kinerson, EPA RE: EXPOSURE AND RISK ESTIMATES FOR PCBs, DIOXIN/FURAN FOR ANDERSON ROAD AND LEMON LANE LANDFILL SUPERFUND SITES NOTES: RISK VALUES ARE ADMITTED TO BE CALCULATED ON EXTREMELY LIMITED DATA - ACTUAL RISK MAY BE SERIOUSLY UNDERESTIMATED ________________________________________________________________ 11/24/87 document LEMON LANE SAMPLING AND EMERGENCY ACTION PLAN NOTES: PROVIDES LIMITED ANALYTICAL RESULTS FOR PCB 1248 SHOWING HIGHEST CONCENTRATION OF 4,300,000 PPB AT SAMPLE LOCATION S-41 LOCATED AT THE SOUTHERN MEDIAL BOUNDARY OF THE SITE, PHTHALATES AND PAH'S AND LOW-LEVEL CYANIDE WERE ALSO DETECTED; DOCUMENT RECOMMENDS EMERGENCY RESPONSE TO THE SITE ________________________________________________________________ 00/00/00 deposition transcript DEPOSITION OF J. KARAGANIS NOTES: PG. 18 - 12 TOTAL TEST FOR DIOXIN/FURAN FOR NEAL'S AND LEMON LANE LANDFILL; PG. 62 - DIOXIN AND FURAN STATED TO HAVE BEEN FOUND IN RESIDENTIAL SOILS; INDICATES THAT REGULATORY STANDARDS DO NOT INCLUDE CONCENTRATIONS IN THE PPB RANGE; PG. 127 - FURTHER NOTES EVIDENCE OF DIOXIN CONTAMINATION AT LEMON LANE ________________________________________________________________ 00/00/00 document EPA, Region V MAJOR OUTSTANDING ISSUES NOTES: STATES THAT SOIL SAMPLING TO DEVELOP AIR RISK CRITERIA IS UNNECESSARY ________________________________________________________________ 00/00/00 hand - written notes HANDWRITTEN RESULTS OF 1983 SAMPLE ANALYSES FOR LEMON LANE NOTES: NO QA/QC PROVIDED; NOTES HIGH CONCENTRATION ON SITE OF 57,000 ppb OF PCB, HIGH OF 12.2 ppb PCB 1248 AT ILLINOIS CENTRAL SPRING; HIGH CONCENTRATION OF 1.0 ppb PCB 1248 IN MONITORING WELL-4; NO DIOXIN /FURAN ANALYSIS PROVIDED ________________________________________________________________ 00/00/00 paper Noel C. Krothe FRACTURE TRACE ANALYSIS FOR LEMON LANE LANDFILL REFUSE AREA NOTES: INCONCLUSIVE EXCEPT TO NOTE THAT SUBSURFACE DRAINAGE DOES OCCUR AT THE SITE ________________________________________________________________ 00/00/00 appendix D TDD FOR TAT SUPPORT NOTES: $ 600.00 ALLOCATED FOR MONITORING ERECTION OF LEMON LANE SECURITY FENCE ________________________________________________________________ 00/00/00 appendix E POLREPS NOTES: MATERIAL PROVIDED IS ILLEGIBLE, NO DEFINITION OF POLREP IS PROVIDED ________________________________________________________________ 00/00/00 appendix F CERCLA CLEAN UP FORMS NOTES: PERSONNEL ENTRY/EXIT FORMS; EQUIPMENT ENTRY/EXIT FORMS; DAILY DIRECTION TO FENCE INSTALLATION COMPANY (SUNSET HILL FENCE CO.) ________________________________________________________________ 00/00/00 appendix G 1900-55 FORMS NOTES: CONTRACTOR STATUS REPORT INCLUDING HOURS WORKED BY SUNSET HILL FENCE CO. WORKERS ________________________________________________________________ 00/00/00 appendix H INCIDENT OBLIGATION LOG NOTES: ACCOUNTING OF EXPENDITURE TO SUNSET HILL FENCE CO. ________________________________________________________________ 00/00/00 appendix M SITE PHOTOGRAPHS ________________________________________________________________ 00/00/00 appendix N SITE SAFETY PLAN NOTES: LEVEL D ONLY PERSONAL PROTECTION REQUIRED ________________________________________________________________ 00/00/00 ON-SCENE COORDINATOR'S REPORT LEMON LANE LANDFILL NOTES: ACCOMPLISHED ERECTION OF SECURITY FENCE; PLACEMENT OF 11 WARNING PLACARDS ________________________________________________________________ (end of document) DATA ACQUISITION REPORT LEMON LANE LANDFILL - AUGUST, 1995 PAGE 18 E NVIRONMENTAL C OMPLIANCE O RGANIZATION