FIELD SAMPLING PLAN FOR THE FILL MATERIAL AT LEMON LANE LANDFILL 



Westinghouse Bloomington Project QAPjP Volume II Amendment 1 August 21, 1996 (Revised August 26, 1996) 

[This document has associated charts and graphs. These can be obtained through the COPA office by calling 333-8888 or email to mitch@copa.org] 

Table of Contents 



1. Background and Summary 
2. Sample Network and Rationale 
2.1 Site Description and History 
2.1.1 Location Description 
2.1.2 Geology and Hydrogeology 
2.1.3 Topography and Hydrology 
2.1.4 Groundwater Use 
2.1.5 History of Site Operations 
2.1.6 Previous Site Investigations 
2.1.6.1 Surface and subsurface Soil Sampling and Analysis 
2.1.6 2 Soil Boring and Analysis 
2.1.6.3 Soil Gas Sampling and Analysis 
2.1.6.4 Groundwater and Surface Water 
2.1.6.5Electromagnetic Survey 
2.1.6.6 Air Photo Analysis 
2.1.7 Interim Remedial Measures 
2.1.8 Analysis of Previous Site Investigations and Remedial Measures 
2.2 Project Approach 2 3 Contaminants of Concern 
2.4 Sampling Locations 
2.4.1 Hot spot investigations 
2.4.2 Sinkhole Investigations 
2.4.3 Electromagnetic Anomaly Investigations 
3.0 Sample Custody Procedures 
3.1 Sample Identification System 
3 2 Initiation of Field Custody Procedures 
3.3 Field Activity Documentation and Logbook 
3.4 Sample Shipment and Transfer of Custody 
4.0 Sample Container Preparation, Sample Preservation and Maximum Holding Times 
4.1 Bottle Requirements 
4.2 Sample Preservation and Hold Times 
5.0 Sample Handling, Packaging, and Shipment 
6.0 Decontamination Procedures 
6.1 Personnel Decontamination 
6.2 Sampling Equipment Decontamination 
7.0 Procedures and Equipment tbr Field Surveys amd Sampling 
7.1 Procedures for Mapping and Surveying 
7 2 Borehole Drilling and Abandonment 
7.3 Soil Sampling Frocedures 
7.3.1 Types of Soil Samples 
7.3 2 Collection of Soil Samples 
7.3.3 Collectionof Soil Samples for Volatile Organic Analyses 
7.3.4 Sample Mixing 
7.3.5 Special Precautions for Trace Contaminant Soil Sampling 
8.0 Field Measurements amd Screening 
9.0 Preventative Maintenance Procedure and Schedule 
10.0 Investigation Derived Waste 
10.1 Types of Investigation Derived Waste 
10.2 Management of NonHazardous Investigation Derived Waste 
10 3 Management of Hazardous Investigation Derived Waste 
References 1. Background and Summary of Sampling 



The Lemon Lane Landfill is a large closed municipal landfill. During several years of its operation, polychlorinated biphenyl (PCB)-contaminated capacitors were disposed al this site. After the PCBs were classified a toxic substance and the CERCLA legislation became law the site was investigated and placed on the National Priority List (NPL) due to PCB contamination. 



The industry standard and USEPA presumptive remedy for remediation of large municipal landfills w0ith PCB or other hazardous contamination is oontaimment (USEPA I 990a). In addition to containment removal of known hot spots may also be oonsidered. The reasons for choosing containment include: 



*The heterogeneous nature of the material *The difficulty characterizing the site. *The large volumes of matetial 



Site characterization activities are generally performed to provide information for risk assessment amd site remedial evaluation. Within the broad area of she characteriztion two of the more common sampling strategies are to define average values of the material (physically and chemically characterize the matenal) or to sample in search of hot spots. These strategies have been found to be ineffective for municipal landfills. 



The EPA has published guidance for conductng remedial investigations of municipal landfill sites(USEPA 1991). The guidance recommends limiting site characteraztion activities to those required to support the presumed remedy. A limited site investigation is warrented not only because of the inherent difficulties of obtaining and evaluating sample data, but also because containment does not require such information. 



The futility in attempting to characterize the heterogeneous material found in municipal landfills has been recognized by other federal agencies as well. The Agency of Toxic Substances and Disease Registry (ATSDR) commented that "It is difficult to fully characterize any landfill matrix (mixture of waste). For example core sampling might indicate the concentration of a discrete batch of non-PCB contaminated waste material that was deposited at that location which could yield a non-detect upon analysis for PCBs. Similarly a sample might also indicated that an intact capacitor was penetrated during the boring operation for the sample collection process yielding an extremely high concentration of PCBs. Neither sample could be used to detirmine average representative concentration of fhe PCB contaminated material. (ATSDR 1994). 



The other typical samplmg strategy of searching for hot spots has also been rejected by the EPA for municipal landfill sites. EPA explicitly recommends sampling only known hot spots (USEPA 1990a). These are hot spots for which documentation and or physical evidence exist to show their presence and location. 



Lemon Lane Landfill received an interim cap in 1987. There is no current exposure to fill material for any receptor. The most likely future land use for this site is as a closed municipal landfill. Risk assessment and remedial alternatives evalualions are currenty in progress for permament closure of fhe site. In conducting this work there remains considerable debate among the consent decree parties about the need to perform additional characterization activities in the fill at Lemon Lme Landlill. 



In the course of this debate several conceptual level sampling programs for the fill have been put forward. 0ne plan called for a site wide search for hot spots. This would result in a large number of borings and would cause great damage to the existing site controls as well as be diametriclly opposed to EPA guidance. A later plan called for a more focused search for new hot spot in areas that indicate high metallic content and areas that could be wetted by groundwater(Earth Tech 1995 USEPA 1996a). This plan a so called for additional evaluation of the known hot spot at the site. 



The parties have failed to reach consensus on the need for any additional information, even that represented by the more focused hot spot search plan. However, in an effort to move the project forward, Westinghouse is proposing the sampling effort. The plan focuses on the following areas: 



*Known hot spot areas *Areas of potential mobile materials (the existing sinkhole areas) *Areas of high potential metallic content as detemmined by EM survey 



A single-phase field investigation consisting of 25 borings will be conducted to further evaluate the above areas for PCB concentrations. The sample locations proposed are in most cases the same as those identified in the most recent EPA conceptual plan. 



2. Sample Network and Rationale 



2.1 Site Description and History 



2.1.1 Location and Description of Surrounding Land Areas Lemon Lane Landfill is located on the nonhwest side of the City of Bloomington in Monroe County Indiana. Thelandfill location is shown on the area map in Exhibit 2-1. The landfill includes about 10 acres and is bounded by Lemon Lame and residential property on the east by the L&N Railroad on the south residential property on the north and by undeveloped land on the west. The Indiana State Route 37 Bypass is approxanatcly 900 feet northwest of the landfill entrance 



2.1.2 Geology and Hydrogeology The overburden at the site consists of fill material and native soils ranging in thickness from about 10.5 to 43 feet. An analysis of historical aerial photographs of the site show that the fill thickness varies from 2 to 30 feet. It is estimated that the average fill thickness is 20 feet. 



Thc overburden is underlain by Mississippian age bedrock units. The St. Louis Limestone of the Blue River Group underlies the overburden layer, amd beneath this unit lies the Salem Limestone of the Sanders Group. The St. Lnuis Limestone has formed a regional geology characterisic of karst terrane. 



The groundwater flow system associated with the site is composed of recharge areas flow areas and discharge areas. Recharge to the groundwater flow system occurs primarily through sinkholes and swallowholes typical of karst terrane. Groundwater flows primarily through solution-enlarged fractures and joints to the southeast and eventually discharges at fhe Illinois Central Spring. 



2.1.3 Topography and Hydrology 



The Lemon Lame Landfill is situated in a surrace depression associated with a regional trend of compoumd sinkholes. This regional surface depression or compound sinkhole trends northeast to southwest and extends to the southwest of the Lemon Lane and beyond the L& N Railroad. The topography across most of the moderately slopes to the west. The surface of the landfill ranges in elevation from 850 hp 890 feet above mean sea level (AMSL). The site is located near topographic divides between the headwaters of Clear Creek to the southeast Stout's Creek to the northwest and Griffy Creek to the northeast. 



The site is located along the eastern margin of the Mitchell Plain physiographic region which is a low plateau developed on limestones of the Mississippian Blue Rhver and Sanders Group. The Mitchell Plain surface is relatively flat with moderate slopes and karst topography. Topographic features in the vicinity of Lemon Lane Landfill include sinkholes, caves, three surface streams (Clear Creek, Stout's Creek, and Griffy Creek) and associated tributaries, perennial apd intermittent springs and at least one sinking stream. A sinkhole pond (Sargents Pond), is located northwest of the site. 



Drainage from the site and all adjacent areas is via sinkholes to the karst solution features developed in the underlying bedrock. Approximately half of the site runoff drains to a depression southwest of the site and the other half drains to Sargent's Pond to the north west. The water in Sargent's Pond is believed to slowly drain to the subsurface via small pores in the clay bottom. The water in the southwest depression more rapidly drains to the subsurface via larger macropores. 



2.1.4 Groundwater use 



Most residences and businesses in the immediate vicinity and downgradient of the landfill are served by the municipal water supply. A well user survey was conducted in 1985 and was updated in 1995. The survey located 20 residences with operational water wells within one mile of the site. Tbese wells were sampled for PCBs quarterly from September 1995 to June 1996. No PCBs were detected. 



2.1.5 History of Site Operations 



The Lemon Lane Landfill opened as a privately owned and operated refuse dump in 1933. The City of Bloomington operated the landfill from 1950 to 1964 as a municipal waste landfill. The earliest dumping was into the sinkholes located on the site but later refuse was deposited throughout the site. 



It was also used as a repository for industrial debris and waste. Electrical capacitors from Westinghouse's Bloomington Plant were deposed in Lemon Lane. Landfill from 1958 to 1964 by contracted local haulers. 



Landfill operations were typical of the period with an abscence of controls and design features now commonto today's facilities. No liner or cover was used and dumping was not controlled. Scavenging and burning were common daily practices. No records of types or quanities of waste disposed of at this site were kept during its operation. In addition, there were no landfill closure plans. 



Information obtained in depositions of former operators and nearby residents indicated that in cases where disposal items such as capacitors were popular with salvage activities such item s would be placed at the edge of the landfill to ensure salvagers would not interfere with dump operations. One such area that contained a large accumulation of capacitor parts that were visible on the surface (prior to removal and capping) is located along the southwest slope of the landfill. 2.1.6 Chronology of Site Investgations and Remediation to Date 



In preparation of this plan a review ws conducted of the previous sampling investigations and remediation conducted at the landfill . There have been numerous invistigations associated with the Lemon Lane site. Appendix A, exhibits A I and A2 provides a list of the previous investigations. Also included in Appendix A are figures of sampling locations and summaries of the sampling results in the order that they are discussed below. 



Initial site investigations began 1981 and culminated in a series of interim remedial measures (IRM) in 1987. Additional investigations concerning groundwater in the vicinty of the site continue to this day. 



Because surface capacitors were removed and a synthetic membrane instal led as part of the IRM; the preIRM sample results for surface soils are not necessaily representative of the current site condtions. 



2.1.6.1 Surface Sampling and Analysis. 



Onsite soil was collected at the site by the Indiana State Department of Health and the City of Bloomington in June 1981. Surface samples were near capacitors on the south and west landfill boundary. The samples contained PCBs ranging from 1,700 to 330 000 ppm. 



In June and July 1981, onsite soil samples were collected by USEPA at the site and were analyzed for PCBs, VOCs, SVOCs and pesticides. Soil samples were collected from nine locations with sample depth range of surtace to 5 feet (exhibit A3). Two sample locations with capacitor areas. PCBs were detected at all nine locations with a concentration range of 0.1 to 57,000ppm. No other chemicals were reported at detectable levels. 



In October 1984, two onsite amd several off site soil samples were collected by USEPA and were analyzed for dioxins and dibenzof urans (exhibit A4). Polychlorinated dibenzodioxins and furans were detected in only one of the onsite samples at 0.002 and 0.001 ppm, respectively. 



On March 11,1987, the Technical Assistance Team (TAT) collected soil samples at Lemon Lane for the USEPA. A sampling plan had been developed by the USEPA to determine the presence of PCB and other contaminants. The purpose of sampling was to provide information on other potential contaminants to determine if the safety procedures proposed for the interim remedial measures would be adequate. Samples were collected from 45 locations (exhibit A 5). Every three samples were accumulated in the field and the resulting 17 composites (including 2 duplicates and and offsite background sample were analyzed for full scan organic analysis including acid/base/neutrals and volitiles. PCBs were detected in all samples and the levels varied from 4.2 to 2300 ppm. 



In early 1987, the city took 30 surface samples from the landfill, composited them into 10 samples and had them analyzed for isomers of dioxin/furans, and total PCBs. The locations of each sample was not reported. In addition, the lab reported major interferences that affected the quantitation portion of the Dioxin/Furan analysis. PCB values ranged from .05 to 62,889 ppm. Dioxin isomers were found in 4 samples and Furan isomers were found in 3 samples. 



2.1.6.2 Soil boring Sampling and Analysis. 



In March 1984, Westinghouse drilled 8 borings in the I amdtill. The purpose of the sampling was to evaluate the depth of fill and collect a limited number of samples for PCB analyses. Soil samples from three boring locations (B-l,B-2, and B-3, exhibit A-6) in the fill material of the Lemon Lane Landfill site wer analyze for PCBs. A total of eight samples were collected at depths ranging from 12 to 24 feet at B-1, 4-32 feet at B-2, and 6 to 12 feet at B-3. he Letnon Lame Lamdfill site were amalyzed tor PCBs. A PCBs were detected at all three boring locations with a concentration range of less than 1 to 22 ppm at depths from 4 to 6 feet. 



In November 1984, additional onsite sampling was conducted by USEPA. Three samples were collected from each of two different boreholes (exhibit A-7). Sampling also included one blank sample. All six samples were analyzed for dioxins amd dibenzofurans. Dioxins were detected in one sample at 0.002 ppm Dibenzmfurans were detected in three other samples with a concentration range ot 0.0002 to 0.002 ppm. 



2.1.6.3 Soil Gas Sampling and Analysis. 



Onsite soil gas sampling was conducted by Westinghouse at the site in April 1987. The purpose of the sampling was to detect and characterize vapors in the soil pore space at the site. A square grid pattern was establisbed at the site at 75f oot intervals. At each node, a boring was made to 5 foot, then the soil gas was sampled with a photo ionization detector (PID). The 15 highest PLD locations had gas samples withdrawn in TEDLAR bags for laboratory analysis of VOCs. A total of 23 samples were collected from 15 locations. VOCs were not detected in any samples. 



2.1.6.4 Groundwater and Surface Water Sampling 



A number of wells have been installed on the immediate perimeter of the landfill.. These were installed during initial investigations at the site prior to 1984. These wells have been sampled. The most recent sampling events were performed as a part of the Field Sampling Plan for the Lemon Lane Groundwater Monitorng Investigation (Westinghouse 1995). The data collected as a part 0f this plan includes one year of monthly sampling at 5 wells on the periphery of the site. These samples showed PCB contamination at the wells from less than .l ppb up to1.4 ppb. 



In addition to PCB concentrations, these wells are also continuously monitored for water level. Data collected shows that the highest groundwater elevation ever recorded is 842 feet AMSL. This level corresponds to an elevation just above the upper surface of the bedrock at the site in the overlying natural soils, but below the general fill depths. While these wells are not in the fill areas, it is believed that the well showing the highest ground water levels (MW-7) is well connected to the main conduit beneath the site and thus is a good indicator of maximum water level potential in the site. 



Dye traclng to determine the resurgance of groundwater potentiatly impacted by the site was conducted in 1987, 1989 and 1990. These traces showed that the majority of the groundwater flows to the Illinios Central Spring southeast of the site. Some water may also travel to the Slaugherhouse Spring system to the northwest during high flow events. 



The potentialIy impacted springs were also sampled extensively as part of the same field sampling plan referenced above. These samples show that the Illinois Central Spring(ICS) has PCBs in it's waters during both low and high flow periods. Based on both the dye tracing and recent PCB analyses, this spring appears to be the major outlet for impacted waters. 



The USEPA and State of Indiana performed sampling of this spnng for other contamninants in 1995 and in earlier years durng both low and high flow events. The only other contaminant found was trichloroethylene. 



2.1.6.5 Electromagnetic Surveys 



In June of 1995, the USEPA conducted an electromagnetic (EM) survey at the site (USEPA 1995). The purpose of the survey was to find major EM anomalies at the site. EPA contends that these anomalies could represent major concentrations of capacitors. The EM data is represented on exhibit 2-2. EM surveys can show major pockets of metallic objects from the surface to a maximum depth of about 15 feet. The EPA concluded that most of the anomalies found in July 1995 are near surface materials. 



2.1.6.6 Air Photo Analysis 



Historical photos depicting the stages of landfill development have been analyzed (Westinghouse 1983). The analysis has shown the depth of refuse across the site and also specifically noted the depth as of 1958 when capacitor disposal began. Of particular note is that the southwest sinkhole was filled prior to the arrival of capacitors at the site. The depth of refuse along the southwest corner has been estimated to be 2 to 10 feet. Much of this refuse was placed prior to 1958. Therefore, it is unlikely that capacitors placed in this area extend beyond a few feet below the surface. 



2.1.7 lnterim Remedial Measures Interim remedial measures were implemented at Lemon Lane Landfill in two phases. Phase I begam in June 1983 and included the installation of a security fence around the entire perimeter of the site. This8-foot-high, locked chain-link fence with barbed wire strung across the top was installed for the USEPA and is maintaimed by Westinghouse The USEPA also installed a fence around nearby Illinois Central Spring and posted warning signs m the area. 



In May 1987, Phase II began following approval of the Lemon Lane Grading Plan. During Phase II, interim removal and remedial measures were implemented by Westinghouse. The site was first cleared of all trees and vegetation and 403 exposed capacitors were removed and transported to the Interim Storage Facility. The capacitors were properly disposed of in a commercial incinerator in 1990. The eroded south slope grade was stabilized with fill mater ial and the entire site was coveredwith TYPAR geotextile, followed by 30,000 tons of clean fi11 and a 36 mil HYPALON geomembrane ccover. The synthetic membrame was installed to minimize rainwater infilltration into the landfill, prevent the erosion of soils from the site, and minimize any potential air emissions. Silt control fences were installed to minimize the erosion of site materials beyond the boundries of the landfilll durng the preparation and capping of the site. 



Gas collection and filter systems were installed to allow any remaining decomposition gases to escape after the installation of the TYPAR geotextile. Special granular grading matetial was installed over chipped vegetation to allow for any gases to migrate to the absorbent carbon gas venting units. To date, sampling results indicate that no gas emissions have been detected. 



Phase 11 was completed in September 1987. All remedial measures, implemented to remove any immediate threat to public health and the environment, were designed and implemented with oversight and approval from the USEPA, State of Indiana (IDEM), City of Bloomington (Utilities Service Boardd), and Monroe County (County Health Board). 



Westinghouse has maintained the site since 1985. Westinghouse personnel regularly inspect the site to assure there has been no disturbance of the site and to veify that the security fence and cap are intact. 



Access to Lemon Lane Landfill is via an access road from Vemal Pike. All government parties have keys to the security fence and have unlimited access. 



2.1.8 Analysis of Site History, Previous Site Sampling and Remedial Measures 



The site received an unspecfied amountt of municipal and industial waste and meets the EPA's definition of large municipal lanfill with mixed municipal amd industrial wastes (EPA 1991). 



The site received PCB laden capacitors from 1958 to 1964. Visual inspection of the site along with account from site operators and residents indicate that most of the capacitors were concentrated along the southwest corner ot the landfill These capacitors were dismantled by local residents to recover scrap metallics. 



Surface samples taken at the site confirm that the southwest corner could be classified as a known hot spot based on file use of a 500 ppm principal threat criteria (USEPA 1990b). There are no other locations at the site that would classify as a known hot spot for PCBs or other contaminants based on documentation or physical evidence. 



The site was fenced in 1983. This fence prevents access to the site materials. Additionally, surface capacitors were removed and an impermeable cap placed on the site in 1987. 



The most recent sampling conducted shows that groundwater in the immediate vicinity of the site and surface waters (primarily the Illinois Central Spring) that receive site groundwater are the only open pathways for contaminanttransport and exposure to human and ecological receptors. A significant amount information has been collected on the site by a combination of geophysical, anecdotal intrusive and non-intrusive sampling In aggregate t he information is consistent with or exceeds EPA guidance for investigation of such sites and is sufficient to support a presumed remedy of containment. . 2.2 Project Approach and Objectives 



Current project activities include risk assessment and evaluations of remedial alternatives. The U.S. Environmental Protection Agency has published guidance for the investigation and remediation of sites such as the Lemon Lan Landilll (USEPA 1991). Based on extensive experience on municipal landfill sites, this guidance recognizes the inherent difficulties and futility of performing detailed investigations into the nature and extent of contamination. This is due to: * the heterogeneous nature of the material which makes obtaining representative samples problematic * the difficulty in physically obtaining the samples in a refuse enviromment * the presumed remedy (containment) does not require such information 



Because of 'the above, the guidance recommends that the charcterization of municipal landfills be streamlined and focused. Information concerning the nature and extent of contamination in the general till is not sought. Rather, information to characterize the offsite exposure pathways such as groundwater and surface waters is developed. The only situation that may warrant obtaining samples in the fill areas are those samples that are focused on known hot spots if the hot spot presents a principal threat and is accessible. 



Hot spots are deemed as highly mobile or highly toxic material that pose a principal threat to human health or the enviromment. Principal threats for PCB industrial sites has been generaIy set as material contaminated at levels greater than 500 ppm (USEPA 1990b). This definition is based on calculated risk from cancer utilizing the existing cancer slope factor or 7.7. The EPA has recently proposed a revised cancer slope factor of from .3 to 2.(USEPA 1996b) If this proposed slope factor is accepted, the threshhold concentration of PCBs that determines a hot spot should signifigantly increase. 



At the Lemon Lane Landfill, there is one known PCB hot spot at the surface of the southwest corner. Neither previous sampling or anecdotal informaton shows a significant potential for any othe rhot spots containing PCBs or other contaminants. The site has been capped the PCB contaminated material at the surface of the sothhwest corner is no longer accessible tn human or environmental receptors. Additionally, this material is well above groundwater levels at the site and thus cannot be mobilized in this manner. 



While the known hot spot was remediated in 1987 and presents no threat, one of the remedial alternatives that continue to be evaluated is site contaimment with removal of the known hot spot. Consideration of removal requires an estimate of the volume to be removed. The previous visual records and surface sampling have shown the approximate areal extentt of this material. 



There have been no borings performed in this area. Rather, the current estimate of depth of the hot spot have been based on historical air photo analysis.These photos show that the southwest sinkhole and corner received some of the earliest waste placed at the site, and that the layer of waste that could conntain capacitors at this location is limited to the upper layer and ranges from 2 to 10 feet deep. . Since the known hot spot has been remediated by capping and there are no other known hot spots to investigate, under the guidance (USEPA 1991 ) no other sampling in the flll should be performed. Rather sampling of contaminant pathways such as the Illinois Central Spnng water can provide information needed for both risk assessment and remedial alternatives development. Tbis is especially the case when sampling can damage the cap and is inherently difficult and risky operation in a mixed refuse industnal waste environment 



However, there is considerable disagreement among the Consent Decree parties conerning the need for additional sampling in the fill. To move the processt along in spite of these disagreements several conceptual level sampling plans have been proposed. In April 1995 the EPA presented a conceptual level plan based on a total of 25 borings. The locations for these borings was later modified based on the results of an EM survey conducted in June 1995. The results of this survey and the proposed EPA sample locations are shown in exhibit 2 -2. 



This plan is a modification to but is largely based on the most recent EPA proposal. All locations proposed by the EPA are utilized with the exception of 3. The reasons for modifying these 3 locations are detailed in section 2.4 



The overall objective of this plan is to screen specific locations for PCB concentrations in the range of 500 ppm. The specific purposes of the sampling proposed by this plan are to: 



*Collect additional data relevant in the horizontal and vertical extent of PCB contamination in theknown hot spot along the southwest corner of the landfill. 



*Collect additional data relevant to PCB contamination in the two sinkholes at the site 



*Evaluate the electromagnetic survey anomalis at the site for PCB contamination 



*Evaluate the potential for known hot spot material to be RCRA characteristic waste 



To accomplish the above goals a maximum of 25 borings will be used. The specific Iocation for each of the 25 borings is detailed in section 2.4. The data obtained will be used in assessing final site altematives per the guidamce provided in references USEPA 1990a, USEPA 1990b, USEPA 1991 and USEPA 1996. The data will not be used in risk analysis. Current envisioned uses include helping refine volume estimatesof contaminated materials. 



All samples will initially be analyzed for total PCBs by use of immunoassay field screen ing analysis. The purpose in using field screening kits is to allow for the rapid choice in selecting splits of samples for other analyses (either RCRA characteristic tests or samples for other contaminants that the parites may have an interest in.) A minimum of 10% of the samples will also be split and analyzed by conventional PCB analyses (methodSW-846 8081). The kits would be initially set for a range fo approximately 50 to 1000 ppm based on Aroclor 1248. This is the Aroclor identified in previous samples of fill material. 



Limiting the number of borings will also limit the damage to the existing site cap. Great care must be taken in operating drilling equipment on the landfill surface. All penetrations made in the existing cap will be recapped using a solvent welding technique. Methods such as the use of protective sheeting will be used to limit the potential to tear the cap during equipment movements.. All borngs will be closed immediately upon completion. A piezometer is to be left in place at one of the boring locations, a special proposal to do this will be made. 



For a summery of reference of field procedures, please refer to Exhibit 2-4. The use of direct push technology is preferred to minimize the potential of damage to the cap and the generation of cuttings. However, it is recognized that adequate recoveries to perform all the analyses that may be desired by the parties is a potential problem with direct push techniques. The actual method of sampling may include both direct push and conventional dri11ing and will he selected based on conditions encountered in the field. Hand coring and or use of hand held power augers may be requiredon the steep slopes of the southwest corner where machine access may be limited. The depth obtainable by hand boring may be limited. 



2.3 Contaminants of Concern 



Contaminants of concern are defined as those most likely to have been contributed as a result of Westinghouse activities These contaminants are limited to PCBs. In order to evaluate disposal options, Westinghouse will analyze selected samples for RCRA characteristic wastes, includingTCLP, reactivity, corrosivity and ignitablity. The list of parameters is shown in Table 3-1 of fhe QAPjP (Westinghouse 1995). 



2.4 Sampling Locations 



2.4.1 Hot Spot Investigation 



Boreholes will be advanced through the landfill and into the natural soil underlying the landfill and sampled within the general area defining the known hot spot on the southwest cornerof the landfill. Eleven locations are shown in Exhibit 2-3. (Boring numbers SB-I, 9,12,13,19, 20, 21,22, 23, 24 and 25). All boring locations are approximate and will be located in the field based on field conditions. It is the intentt of locations 1,12 and 19 to provide information relative to the depth of the PCB contamination on the slope of the southwest corner. The purpose of location 13,20, 21, and 22 is to provide information relative to the extentt of the hot spot inwards from the corner. Locations 23, 24 and 25 are placed to evaluate the eastern extent of the known hot spot. Location 9 provides information on the northern reach of the hot spot. 



Note that the locations numbered 1,12, and 19 were originally placed in different locations in the proposal made by EPA in July 1995 (exhibit 2-2). Their purpose was to verify that areas thought to be free of PCBs were in fact free. This proposal relocates those borings to an area of known contamination based on guidance (USEPA 1991). 



Boreholes will be advanced using hollow stem auger drilling and two foot split-spoon techniques, or with a hydraulic direct push device and or hand auger depending on field conditions.Samples will be collected at each 2-toot-depth interval starting at the top of the landfill and continuing until natural soil or refusal is encountered. The deptth of refuse/fill material in the southwest corner of ranges between 1 to 20 feet. The borehole will be completed 2 feet into the soil below the refuse/fill material. If refusal is encountered prior to reaching natural soil or bedrock, another borehole will offset from the first by 5 feet. In cases where an offset boring is begun due torefusal at the prior boring, sampling in the offset boring will not begin until the depth interval below the refusal in the previous boring. 



For each 2-foot sample, the material recovered from the split spoon will be homogenized and placed into a container. A 10 gram subsample will be analyzed for total PCB at an onsite laboratory using immunoassay kits. Onsite laboratory results will be expressed in wet weight equivalence. Verbal results will be provided to the Field Activities Manager within approximately 24 hours ofsample receipt. The 2-foot samples will be retained for additona analysis, if necessary. 



To assess whether the material is a RCRA characteristic waste, four composites will be made and analyzed. Two composites will be formed from equal aliquots of samples from locations 1, 12 and 19. The other two composites will be formed from the remaining hot spot locations. Only intervals that have PCB screening results in excess of 1000 ppm will be selected for inclusion in the composites. 



2.4.3 Elecbromagnetc Anomaly investigation 



The USEPA performed an electromagnetic survey in June 1995. The goal of the survey was to identify amomalies that may be indicative of major capacitor caches. As a result of the survey, USEPA has identified areas that they recommend to be investigated. 



Boreholes will be advanced through the landfill and into the natural soil underlying the landfill and sampled wlthin areas of high meatllic content as indicated by electromagnetic survey . These are shown as eight locations on Exhibit 2-3 (boring numbers SB-06, 07, 08,10, 14,17,18, and 20). Note that location 14 serves as both as a sinkhole boring and an EM location boring. 



Borings will be advanced using hollow stem auger drilling and 2-foot split-spoon techniques or direct push methods. Samples will be collectd at each 2-foot-depth interval starting at the top of the landfill andcontinuing until natural soil material or refusal is is encountered. The refuse/fill in the electromagnetic amomaly areas may be up to 20 feet in depth. The borehole will be completed 2 feet into the natural soil below the retuse/fill. Every attempt will be made to reach the base of the landfill, based on a visual examination fo the split spoon samples, including offsetting and redrilling if an obstruction (e.g., auto body or refrigerator) is encountered. 



For each 2-foot sample, the material recovered from the split spoon will be homogenized and placed into a container. Equal aliquots of material will be taken from consecutive 2-foot-depth intervals and a compostie created that represents a 4-foot interval. The composite will be analyzed for total PCB at an onsite laboratory using immunoassay kits. Onsite laboratory results will be expressed in wet weight equivlaence. Verbal results will be provided to the Field Activities Manager within 24 hours of sample receipt. The 2-foot samples will be retained for addtional analysis, if necessary. . 



3. Sample Custody Procedures 



3.1 Sample Identification System 



A sample numbering system used by Westinghouse will be used to identify each sample including duplicates and blanks. A listing of sample identification nuubers will maintained in the sampling logbook by the Field Activity Mamager. Each sample number will consist of two components which are described below. Each sample will have a tow digit porject iedetification code (identifyin LL as Lemon Lane Landfill), and a four digit sequential sample number. Sample numbers will not be repeated. Duplicate samples will not be distinguished within the sample numbers, but will be distinguished through the subsample identification with in the sample numbers, but will be distinguished through the subsample identification within the sample tracking and data management systems. This is done so that no bias is given to the samples during analysis. 



3.2 Initiation Of Field Custody Procedures 



For samples collected for analysis, the USEPA Region V chain-of-custody protocols, as descnbed in the National Enforcement Investigations Center (NEIC) Policies and Procedures, USEPA-330/9-78-DDI-R Rev. June 1985, will be followed. Custody procedures are described in Section 5.0 of the QAPjP(Westinghouse 1 995). 



3.3 Field Activity Documentation and Logbook 



A field logbook, as discussed in field procedure FP-I of the QAPjP, will be initiated at the start of the first onsite activity and maintained to record onsite activities during the investigation. The field logbook is acontrolled document that becomes part of the permanent site file The following activities and events will be recorded in the field logbook: Arrival and departure of site visitors Arrival and departure of equipment Sample pickup including chain-of-custody form number, carrier, date, and time Start of completion of borehole and sampling activities Healt and safety issues 



The field logbook will consist of a bound notebook with consecutively numbered pages that cannot be removed. The loghook cover will indicate the following: 



Project name Field Activity Manager's name Sequential book number Project tart date Project end date 



Daily entries will be made during periods of site activity Entries will be recorded in ink, and no erasures are permitted. Each page will be initialed. 



Incorrect entries will be sticken with a single line and initialed. At the beginning of each entry, the date, start time, weather conditions, and name of site personnel and visitors present will be recorded. Entries will include the following: 



Summeries of daily site activities and levels of personal protection 



References to other project notebooks kept onsite 



Photographic records including a description of each record and points of interest.. Videotapes, slides or photographs taken onsite or at monitoring stations will be numbered to correspond to loghook entries. Photographic records will also include the photographer's name, date, name, site location, site description, and weather conditions. Refer to Section 5.1.2 and FP-I of the QAPjP for a discussion on field logbook record keeping. 



3.4 Sample Shipment and Transfer of Custody 



Sample handling, shipping procedures and transfer of custody procedures are in Section 5 of the QAPj P. 



4 Sample Container Preparation, Sample Preservation, and Maximum Holding Time 



4.1 Bottle Requirements 



The contaminant-free sample containers(bottles) used for this sampling effort will be prepared according to the procedures specified in USEPA's Specifications and Guidancef for Obtaining Contaminant-Free Sample Containers, April 1990. Bottles used for the sampling activity will not contain target organic or inorganic contaminants exceeding the level specified in the above mentioned document. Specifications for the bottles will be venfied by checking the supplier's ceritified statement and analytical results for each bottle lot, and will be documented on a continuing basis. This data will be maintained in the project evidence file and will be available, if requested, for USEPA review. 



In addition, the data for field blanks trip blanks esc. will be monitored for contamination. Corrective action will be taken as soon as a problem is identified and include discontinuing the use of a specific bottle lot, contacting the bottle supplier(s) for retesting retesting the representative bottle from a suspicious lot, resampling the suspect lot, and validating the data taking into account that the contaminants could be introduced by the laboratory (i.e, common lab solvents, sample handling artifacts, etc ). If a bottle QC problem arises, a determination of whether the bottles and data are still usable must be made. 



4.2 Sample Preservation and Holding Time 



Exhibit 4-1 summerizes the requirements for sample containers, preservatives, and sample holding times. Sample containers will be certified by the laboratories as precleaned. Preservatives will be prepared using reagent-grade chemicals. Samples will be stored ice to 4¿C for preservation. 



5. Sample Handling, Packaging, and Shipment Sample handling, packaging, and shipping procedures are dcscribed in field procedure t P-12 of the QAPi P. 6. Decontamination Procedures 



This section provides the general guidelines for the decontamination of personnel, sampling and monitoring equipment, and sample bottles 



The following equipment will be onsite: 



High-pressure liquid chromatography (HPLC)-grade or ASTM Type grade- water 



2.5 percent by weight trisodium phosphate (TSP) and water solution 



10 percent by volume methanol (MeOH) or isopropanol (IPA) and water solution (only reagent-grade is to be used) 



Large plastic pails or tubs for TSP and water; scrub brushes; squirt bottle forTSP, methanol, and water, plastic bags and sheets 



Department of Transponation (DOT)-approved 55 gallon drum for disposal of waste 



Solutions of TSP and HPLC or ASTM Type 2-grade water will be used for decontamination. 



6.1 Personnel Decontamination 



The following deconteminatinn procedures will be performed by site personel after completion of tasks whenever the potential for contamination exists when leaving the cotraminated area: 



1. Wash boots in TSP solution, then rinse with water. If disposable latex booties are worn over boots in the work area rinse with TSP solution, remove, and discard. 



2. Wash outer gloves in TSP solution, rinse, remove, and discard. 



3. Remove respirator if worn. 



4. Remove disposable overalls (e.g., Tyveks) and discard. 



5. Remove inner gloves and discard. 



6. At the end of the work day, shower entirre body, including hair, either at the work site or at home. 



7. Sanitize respirator if worn. 



6.2 Sampling Equipment Decontamination 



The sod/sediment sampling equipment will be decontaminated between each sample collection using the followtug procedures: 



1. Scrape soils from sampler. 



2. Wash sampler in a 2.5 percent by weight solution of nonphosphate detergent, such as Liquinox or equivalent, in tap water. 



3. Rinse with tap water 



4. Spray rinse with 10 percent MeOH solution 



5. Spray rinse with hpLC or ASTM Type 2-grade water. 



6. Place on plastic aand allow to air dry. 



All other sampling equipment will be decontaminated between sampling locations by the following procedures: 



1. Wash contaminated equipment contact sufaces with nonphosphate detergent. 



2. Rinse with potable water. 



3. Spray rinse with 10 percent MeOH solution. 



4. Rinse with hpLC or ASTM Type 2-grade water and air dry. 



6.3 Monitoring Equipment Decontamination 



Monitoring equipment will be decontaminated between sampling loacations, (borings, wells, etc.) by the following procedures: 



1. Wipe all contaminated surfaces that had possible contact with contaminated materials with a paper towel damped with TSP solution. 



2. Wipe all surfaces that may have had contact with contaminated materials with a paper towel dampened with potable water. 



3 Wipe with a towel dampened with hpLC-grade or ASTM Type 2-grade water. 



4. Dispose of all used paper towels as specif ied in Section 10 of the FSP. 



6.4 Drill Rig and Equipment Decontamination 



Thedrill rig and drilling equipment, such as augers and drill rpd, will be decontaminated between boring locations by the following procedures: 



1. Move drill rig and associated equipment to the temporary decontamination pad. 



2. Wash rig surfaces and equipment that have been in contact with potentially contaminated materials using a pressunzed steam cleaner. 



7 Procedures and Equipment for Field Surveys and Sampling 



7.1 Procedures for Mapping and Surveying 



Benchmarks will be set to establish horizontal and vertical control. Honzontal control will be established at the site to within 0.l foot, and vertical conttrol to wihtin 0.01 foot. The benchmarks will be used to locate boreholes following the field investigation activities. Recoverable elevation reference marks will be established at each of the grid points. 



7.2 Borehole Drilling and Abandonment 



The boreholes will be advanced using hollow-stem auger drilling techniques in accordance with FP-I 7. The borings will be continuously spooned, and sampled at 2-foot intervals the logging and onsite analysis of PCB. The borings will be advanced to the base of the landfill. Each borehole will be drilled to completion the same day drilling is initiated. Before leaving the site at the end of the day, drill cuttings will be scaled in 55 gallon drums tor temporary storage in accordance with prcecures prescribed in Section 10. Every attempt will be made to reach the base of the landfill, based on visual examination of the split spoon samples, including offsetting and redrilling if an obstruction (e.g., auto body or large home appliance is encountered. (These borings will be abandoned immediately upon completion in accordance wifh FP- 18. 



7.3 Soil Sampling Procedures 



7.3.1 Types of Soil Samples 



An individual sample collected from single location at a specific time or period of time generalIy not exceeding 15 minutes is a grab sample. Grab samples are associated with surface water, groundwater, wastewater, waste, contaminated surface, soil, and sediment sampling. A sample collected from individual grab samples collected on an area or cross sectional basis Composite shall be made up of equal volumes of grab samples. Each grab sample shall be collected in c identical manner. 



7 3.2 Collection of Soil Samples 



Procedures for collection of soil samples are described in field procedure FP-16. The following text summaries those procedures 



7.3.2.1 Split-Spoon Sampling: Split-spoon samples are usually obtained in conjunction with hollow stem auger drilling techniques. The split-spoon is retrieved the the borehole and opened with the air around the sample monitored with an HNu portable photoionization detector or other appropriate instrument. 



Samples for volatile organics are collected immediately, containerized and labeled. Samples for analysis other than volatile organics are placed in a stainless steel bowl, homogenized, and placed in the appropriate conainer. Large pebbles and cobbles should be excluded from samples taken for chemical analysis. 



7.3.2.2 Han-augured Sampling Methhods: Decontaminated equipment will be used to collect the soil sample. A hand-auger consists of a sample bucket attached to the bottom of a length of pipe that has a rossbar at the top. A hole is drilled by turning this crossbar at the same time the operator presse the auger into the ground. The hand-auger is driver to the desired depth which is usually within a few feet of the surface. A hand drive sampler with a 6 inch steel shoe utilizing brass or stainless steel 1iners will be used to collect soil samples. The liners will be 2, 4, or 6 inches in length. 



Sample for volatile organics are collected immediately, containerized and labeled. Soil samples that are not to be analyzed for volatile organics are placed in a stainless steel bowl and homogenized with a stainless steel spoon or Teflon spatula. Large pebbles and cobbles should be removed from the sample. The composite sample for chemical analyses are placed in appropriate containers. 



Place the samples on ice in a cooler maintained a 4 degrees Centigrade or below. 



Note the sample identification, sample location (provide sketch), sampling time, and sampling personsel in the field logbook. 



After augering and sampling are completed, the borehole will be filled using granulated bentonite. The ground surface will be restored to its original configuration. 



Sampling equipment should be decontaminated by following field procedure FP 2. 



7.3.3 Collection of Soil Samples for Volatile Organic Analyses 



Samples should be collected in a manner that minimizes disturbance of the sawple. For example, when sampling with a split spoon, the analysis sample may be collected directly from the split spoon or immediately after a split spoon is emptied into the bowl. The sample should be placed in the appropriate container with no head-space, if possible. Samples for VOA are not mixed. 



7.3.4 Sample Mixing It is extremely important that soil samples from non-VOC analysis be mixed as thoroughly as possible to ensure that the sample is representative of the interval sampled. After collection, all sample handling should be minimized. Personnel should use extreme care to ensure that samples are not contaminated. If samples are placed in a ice chest, personnel should be sure that melted ice cYnot cause sample containers to become contaminated, as this may result in sample cross-contamination. Plastic bags, such as Zip-Lock bags, should be used when small sample containers (e.g., VOA samples) are placed in ice chests tn prevent cross-contamination. 



Once a sample has been collected, it may have to be split into separate containers for different analyses. A true split of soil, sediment, or sludge semples is almost impossible to accomplish under field conditions. Thc higher the moisture content, the more difficult it is to limit the sample. It is extremely important that soil samples be mixed as thoroughly as possible to ensure that the sample is as representative as possible of the sample interval. The most common method of mixing is referred to as quartering. The soil in the sample pans is divided into quarters. Each quarter is mixed then all quarters are mixed into the Center of the pan. This procedure is repeated several times until the sample is adequately mixed. If round bowls are used for sample mixing, adequate mixing is achieved by stirring the material in a circular fashion and occasionally turning the material over. Soil and sediment samples collected for purgeable organic compounds analysis should not be mixed. The sample container should be filled completely; no head space should reamain in the sample containers. 



7.3.5 Special Precautions for Trace Contaminant Soil Sampling 



All soil sampling equipment used for sampling for trace contaminants should be constucted of stainless steel where possible. Pans used for mixing shall be made of stainless steel, Pyrex or equivalent glass. In no case will chromium, cadmium, or galvanized plated or coated equipment be used for soil sampling operations. Similarly, no painted or plastic equipment shall be used. All paint and primer must be removed from soil sampling equipment by sandblasting or other means before such equipment can be used for collecting soil samples. 



Some contaminants can be detected in the parts per billion and parts per trillion range. Extreme care must be taken to prevent cross contamination of the samples.. The following precautions shall be taken when trace contaminants are of concern: 



A clean pair of new, disposable gloves will be worn each time a different location is sampled and gloves should be donned immediately prior to sampling. 



Sample containers for source samples or supplies suspected of containing high concentrations of contaminants shall be placed in separate plastic bags immediately after collecting, preserving, tagging, etc. 



Samples of waste or highly contaminated samples shall never be placed in the same ice chest as environmental samples. It is good practice to enclose waste or highly contaminated samples in a plastic bag before placing them in ice chests. Ice chests or shipping containers for source samples or samples suspected to contain high concentrations ot contaminants shall be lined with new, clean, plastic bags 



When sampling surface waters, the water sample should always be collected before the sediment sample is collected. 



Sample collection activities should proceed progressively from the suspected least contaminated area to the suspected most contaminated area. 



Personnel should use equipment constructed of Teflon, stainless steel, or glass that has been properly precleaned for collecting samples for trace metals or organic compounds analyses. Teflon or glass is preferred for collecting samples where trace metals are of concern. Equipment constructed of plastic or PVC shall not be used to collect samples for trace organic compounds analyses. 



8. Field Measurements and Screening 



Standard operating procedures (HNu and OVA) for the field measurement and screening technique are provided in field procedure FP-20. 



9. Preventive Maintenance Procedure and Schedule 



Field team members will refer to the field procedures or the manufacturers' instrument manuals for the appropriate preventive maintenance procedures for the field equipment used at the site. 



10. Investigation-derived Waste The waste materials generated durag a field investigation are known as Investigation-derived Waste (IDW). Some of the waste materials may be hazardous wastes which must be properly disposed in accordance with USEPA regulations. 



10.1 Types of Investigation-Derived Waste Materials which may become IDW requiring proper treatment, storage and disposal are: 



Personnel protective equipment (PPE). This includes disposable coveralls, gloves, booties, respirator canisters, etc. 



Disposable equipment (DE). This includes plastic ground and equipment covers, aluminum foil, Teflon tubing, broken or unused sample containers, sample container boxes, tape, etc. 



Soil cuttings from drilling or hand augering. 



Cleaning fluids such as spent solvent and washwater. 



10.2 Management of Non-hazardous Investigation-derived Waste 



Non-hazardous IDW such as PPE, DE may be double-bagged and disposed in the trash containers. Matenerals may be placed into municipal trash bins, with the permission of the owner. They may be taken to a pemmitted landfill local to the site. Waste hauling services may be obtained and a trash bin located at the study site. They may also be buried on site near the contamination source with the burial location noted in the field logbook. 



Disposal of non-hazardous IDW such as drill cuttgs, decontamination fluids, etc. may not be placed into trash bins. Permission will be sought to place the liquid IDW into fee local municipal treatment system after it is all collected in a l,500-gallon holding tank and analyzed for PCBs. Drill cuttings will be drummed and stored at the interim storage facility. They will be tested tbr PCBs and disposed of properly. 



10.3 Management of Hazardous Investigationderived Waste 



Hazardous IDW must be disposed of in accordance with USEPA regulations. Wastes may also be disposed of in the source area from which they originated if doing so does not endanger human health and the environment. Hazardous IDW are not expected at The Lemon Lane Landfill site. 



If onsite disposal is not feasible, and if the wastes are suspected to be hazardous, appropriate analysis wi11 be conducted to make that determination. If they are determined to be hazardous wastes, they will be properly contained amd labeled. They may be stored or the site until they are manifested and shipped to a permitted treatment or disposal facility. Generation of hazardous IDW must be anticipated, it possible, to permit arrangements for proper containerization, labeling, transportation, and disposal or treatment in accordance with USEPA regulations. 



Hazardous IDW should be kept to a minimum. None of the IDW is likely to be hazardous. Many of the above PPE and DE wastes can be deposited in municipal trash bins if care is taken to keep them segregated from hazardous waste contaminated materials. Disposable equipment can often be cleaned to render it nonhazardous, as can some PPE, such as splash suits. The volume of spent solvent waste produced during equipment decontamination can be reduced or eliminated by applying only the minunum amoumt of solvent necessay. 



References 



ATSDR 1994. Public Health Assessment of Bloommgton PCB Sites Volume 11. US Public Heaith and Humam Services, Public Health Service, Agency for Toxic Substances and Disease Registry, Atlanta Georgia. September 29, 1994 



EarthTech 1995. Conceptual Sampling Plan for lemon Lane Site. Memo from Richard Flores to Dan Hopkins Earth Tech Bloomington Indiana. April 11,1995 



USEPA. 1990a. Streamlining the Ri FS for CERCLA Mumicipal Landfill Sites. U.S. EnvironmentaiProtection Agency, Of fice of Solid Waste amd Emergency Response, Washington D.C. Directive :9355 3-llFS September 1990 



USEPA. 1990b. Guidance on Remedial Actions for Supetfund Sites with PCB Contamination. U.S. Environmatal Protection Agency, Office of Emergency and Remediat Response, Washington D.C. EPA/ 540/G-90/007 August 1990 



USEPA. 1991. Conducting Remedial Investigations Feasibility Studies for CERCLA Municipal Landilil Sites, U.S. Environmental Protection Agency, Office of Emergency and Remedial Response, Washingdon D.C. EPA 540 P-91/011 February 1991 



USEPA 1996a. Memo trom Dan Hopkins to Distribution. This memo includes Electromagnetic Time Domainn Metal Detection Geophysical Survey Lemon Lane Landfill June20, 21 1995 results and modified boring location drawings. U.S. Envirommentai Protection Agency Region V, Chicago, Ill. February 5, 1996 



USEPA I 996b. PCBs: Cancer Dose Response Assesment and Application to Envirommental Mixtures. External Rewiew Draft. U.S. Environmental Protection Agency, Nationai Center for Environmental Assessment, Office of Research amd Development, Washmgton D.C. NCEA-W-059. January 1996 



Westinghouse 1983. Dran Air Photo Analysis, Monroe County, Indiana. Landfill Site C lnvestgsation. Ta Liang Cornell University, performed for Westinghouse May 1983 



Westinghouse 1995. Field Sampling Plan for the Lemon Lane Groundwater Monitoring Investigation March 1995 (revised June 21,1995)