COMMENTS TO MINI QUALITY ASSURANCE PROJECT PLAN 
FOR FIELD OVERSIGHT OF SITE INVESTIGATIONS 
AND REMEDY DEVELOPMENT ACTIVITIES 
AT THE LEMON LANE LANDFILL
BLOOMINGTON, INDIANA
MARCH 1995



     Pursuant to a Technical Assistance Grant (TAG) awarded to
Citizens Opposed to PCB Ash in Monroe County (COPA), a review by
independent oversight contractors ECO and MVA Consulting Inc., 
has been performed of the above entitled document, that was
prepared in anticipation of a major sampling effort at the Lemon
Lane Landfill facility.  The compiled comments, criticism and
questions noted by the various reviewers are presented below.

IN GENERAL:

     The Mini QAPP submitted by EPA oversight contractor
EARTHTECH, in response to the planned sampling at the Lemon Lane
Landfill does not appear to correlate with the Conceptual
Sampling plan , also prepared and submitted by EARTHTECH.

     For example, while dioxins and furans are not listed as
parameters that laboratory analyzed samples will be tested for in
the Conceptual Plan, there is discussion regarding such testing
in the QAPP, although the provided detail is insufficient to
provide clarification as to the quantity and quality of the
planned analyses.

     Additionally, while the Conceptual Plan relies heavily on
PCB field screening as a threshold for selecting samples to be
fully, laboratory analyzed, the Mini QAPP gives no  detail, and
states merely that EARTHTECH will be performing no field
screening tests.

     The lack of detail is further evident in failure of the
document to specifically outline how EARTHTECH plans to provide
adequate oversight of sample splits that are to be collected by
employees of Westinghouse, the Responsible Party for this site. 
If  EARTHTECH plans, as should be the case, to assign an observer
to each sampling team, and request that the observer immediately
retain custody of split samples, it should be explicitly stated.

     EARTHTECH further fails to list the EPA laboratory method
numbers by which samples will be analyzed.  ECO would suggest
that EPA Method 8081 be used in preference to the more standard
method 8080.  Method 8081 is a dual column analysis yielding
better results in the identification and quantitation of PCBs in
particular.  A listing of all lab methods and justifications for
any deviations from standard methods should be presented and
discussed.

     Finally, data presented in the Mini QAPP is insufficiently
referenced, and this makes it difficult to ascertain the original
source of the information and/or data being relied upon for the
Mini QAPP and the planned sampling effort.  As noted in comments
to the Conceptual Plan, there appears to be a trend of relying on
incomplete and suspect data which directs the sampling plan and
QAPP to premature and unsupported conclusions that should be the
result of, rather than a springboard for the planned field work.  


SPECIFIC COMMENTS


Section 1.1.5 -     Although, extensive written criticisms,
questions and concerns have been presented regarding the results
of recent dye tracer testing at this facility, EPA appears,
contrary to its public statements, to have adopted Westinghouse's
conclusions regarding the test results without equivocations. 
Because the dye tracer data has serious implications for future
groundwater testing and remediation, we believe that it is
inappropriate to entirely discount  previous commentary on these
issues without adequate debate or discussion.

 
Section 1.2 -       A continued use of undefined acronyms
seriously disadvantages this report, and its utility to the
affected public.

Through page 5 -    ECO notes the repeated statement that the
"majority of samples will be sent to (Contract Lab Program) CLP
laboratories".  All samples should routinely be sent to CLP labs
due to the consistency and familiarity of these organizations
with CERCLA parameters and methodologies, detection levels and
reporting formats, as well as the high quality of oversight
provided to program participants.  If all samples are not to be
handled and analyzed by CLP facilities, a detailed justification
of the reasons for deviating from program participants should be
provided.  


Section 4.3 -       As noted above, it is unclear from the
provided description of planned field activities the actual
degree to which oversight personnel will be accompanying and
observing Westinghouse samplers, and whether the chain of custody
for split samples will necessarily reflect transfer from
Westinghouse to the oversight contractor.


Sections 7.0 -11.0 -     No discussion is provided of the
critical, threshold PCB field sampling.  Even if as indicated by
the Mini QAPP, the oversight contractor will not be directly
performing the screening, a full discussion of how that work will
be observed and monitored, and eventually evaluated should be
provided at a minimum.

Table 1-3 -    ECO notes that the planned detection limits for
dioxins are set for ppb amounts, which is magnitudes of order too
high to detect contamination of regulatory and health
significance.

Figure 1-3 -   Some written explanation should be provided,
either in the Conceptual Plan, or the QAPP, of the rationale for
omitting sampling in all monitoring wells located Northwest and
Southeast of the site.

Additionally, it is noted that residential well data was also
generated utilizing a detection level sensitive only to
contamination in the parts per billion concentration.  This is an
insufficient screening in that the federal Maximum Contaminant
Level for dioxin in drinking water is 30 parts per quadrillion. 
Therefore, no past sampling efforts have  adequately quantified
the potential human health risk posed by the groundwater
associated with this site. 


     This information directly touching on potential exposure
pathways for the surrounding community must be addressed by
subjecting all samples to the high sensitivity detection method,
developed by Research Triangle Labs and now commercially
available.


ADDITIONAL COMMENTARY
     
     Melissa Valentin of MVA Consulting, Inc. has also reviewed
the conceptual plan and provided ECO with a memorandum detailing
questions and concerns regarding the planned field event.  The
information contained in that memorandum is provided here in its
entirety.

     Section 1.1 Site History and Background

EarthTech extracted the Site History and Background section of
this document directly from the Westinghouse QAPP without a
disclaimer, which conveys the endorsement of both EPA and
EARTHTECH.

     Section 1.1.1 Site Background

This section does not provide any background information and
should be titled Site Location.

     Section 1.1.2 Waste Disposal

On what basis is the statement "Landfill operations were typical
of the period" being made? Has EPA completed a review of trade
journals, professional society guidelines, etc. to establish that
indiscriminate dumping of industrial waste in unlined sinkholes,
with open burning and no cover, operating policies or records was
typical landfill operation in the 1950s and l960s?

The last sentence describes how capacitors and other items
"popular in salvage activities" were "placed at the edge of the
landfill." If the intention is to describe capacitor disposal
locations within the landfill, Earth Tech should expand this
section and refer the reader to the accompanying maps. The
location of the edge of the landfill varies with time during the
period of capacitor disposal, and since "they did not control 
dumping with regard to waste content, site security or records,"
capacitors may be located throughout the landfill. Further, no
sampling or physical testing data have been produced to confirm
capacitor disposal locations.

     Section 1.1.4 Site Geology

The report should note that although no site characterization has
been performed, there are perhaps 13,000 capacitors in the
landfill in addition to soil, ash, cinders, glass, plastic, etc.

     Section 1.1.5 Hydrogeology
   
The sentence describing two groundwater intervals "separated by a
shale unit" should note that the shale layer is not continuous
and does not effectively separate the shallow and deep
groundwater units near the landfill.

Please include the references for the statement, "Basin studies
have indicated a maximum flow depth in the Illinois Central Basin
between 150 and 185 feet," and expand on this important concept
in the text. Were these basin studies performed in an area where
St. Louis Limestone is the surficial unit followed by Salem
Limestone? What were the objectives and methods of these basin
studies?  Specifically what monitoring well data from Lemon Lane
Landfill supports this theory? Failure to intercept solution
features, cracks or joints could account for the low yield of the
tested wells at Lemon Lane. Does the "maximum flow depth" refer
to water, or DNAPLs that largely ignore groundwater flow paths
and move downward until they can go no farther? How was the
"maximum flow depth" determined in the basin studies referred to?

The summary of flow paths based on the 1987, 1989 and 1990 tracer
tests is incomplete. In the 1987 Low Flow dye trace study,
Westinghouse made positive detections of dye in springs northeast
and southeast of the landfill. The mini-QAPP states  only that
during low flow conditions, groundwater flows to the southeast.
  During the two high flow tracer tests, they made detection of dye
  and/or tracer in all directions around the landfill. The mini-QAPP reports only flow to the southeast and northwest.
  
      Section 1.1.6 Groundwater Use
     
  Please define the term "near" as used in this section to describe
  private well locations.
  
      Section 1.1.7 Surface Water Hydrology
     
  The list of eight springs in the area is incomplete. A complete
  listing of the thirty-eight springs definitely or potentially
  connected to groundwater at Lemon Lane Landfill, according to
  Westinghouse hydrogeologic studies and supplemented by the 1992
  tracer test performed by J. Fitch at Indiana University, is
  provided in Table 1:
  
  ________________________________________________________________
      Table 1: Springs in the Lemon Lane Landfill Study Area
   
   Location Relative to                            Spring
   Lemon Lane Landfill
  _________________________________________________________________
  
       North and Northwest      The following 9 springs located
                                  northwest of the landfill                       discharge to Stouts Creek West:
                                  Detmer A, Detmer B, Robertson,
                                  Walcoll A and B, Abrams, W2, W3 and
                                  W5 Wet Weather.
  
                                The following 7 springs located
                                  north-northwest of the landfill                      discharge to Stouts Creek East:
                                  Snoddy A, Snoddy B, Packinghouse
                                  Plant, Slaughterhouse, PH Road,
                                  Hinkle Wet Weather Rise and Bypass
                                  37.
  
                                Discharge from the following two
                                  springs situated northwest of the
                                  landfill flows to the northwest:
                                  Defeat East and Defeat West.
  
       West and Southwest       Sinking Creek Spring is at the
                                  headwater of Sinking Creek west-southwest of the site, and flows
                                  south.
  
                                Kirby Road Spring is located
                                  further west of the site, and its                         discharge flows to the west-southwest.
  
       South and Southwest      The following 3 springs discharge
                                  to Twin Lakes, which discharges
                                  into a tributary of Clear Creek:
                                  Stoney West A, Stoney West B and
                                  Stoney East.
                                    
                                The following two springs discharge
                                  into a tributary of Clear                       Creek: WN-l and WS-2.
  
       Northeast                The following 5 springs discharge
                                  into a north-flowing tributary of
                                  Griffy Creek: Urban, 17th Street,
                                  Pumping Station, Crestmont A and
                                  Crestmont B.
  
       East and Southeast       The following 7 springs discharge
                                  into an unnamed tributary of                         Clear
                                  Creek: Illinois Central, Quarry,
                                  ICG-1, ICG-2, ICG-3, ICG-6 and ICG-7.
  
                                A stream originating at Illinois
                                  Central sinks before reemerging                      at
                                  Quarry Spring.
  
                                The Fell Iron Spring east of the
                                  landfill is believed to discharge                         to Clear Creek.
  _________________________________________________________________
  
  
      Section 1.1.9 Past Data Collection Activities
     
  The entire second paragraph misrepresents existing data. Under no
  circumstances could the sporadic sampling performed at Lemon Lane
  be considered "site characterization," contrary to the assertions
  in the first and second sentences of paragraph two. In the last
  sentence, they should clarify that only some hot spots were
  remediated, and the data referred to may not be representative of
  existing site conditions.
  
  The data included in Appendix A is incomplete, inadequately
  referenced, and does not support the claims made in the text of
  this document. Is this the "characterization" data referred to in
  this Section?
  
    Section 1.2 Summary of Oversight Activities
  
  How will the sampling events be scheduled? It would be more
  beneficial to sample during
  predetermined flow conditions (e.g., high and low flow) rather
  than at arbitrary times during the first and third quarters.
  
  The sampling radius shown on Figure 1-4 is too small. At a
  minimum, it should be large enough to include all springs at
  which PCBs, dye or tracer were detected, at any time. Preferably,
  it should extend well beyond that to confirm the maximum extent
  of contamination.
  
     Section 1.3 Project Schedule
     
  No project schedule is included.
  
     Section 4.2 Sampling Procedures
     
  The analyses are ranked in order of priority as follows: VOAs,
  PCBs, dioxins and furans, inorganics, SVOCs, pesticides. Why is
  this sequence so different from the one proposed in the Lemon
  Lane Landfill Conceptual Sampling Plan?
  
    Figure 1-2
     
  Please define the boundary line shown, and explain its meaning in
  the text. Since EPA reportedly objects to this "groundwater
  basin," it should not be included in this document.