Field Sampling Plan for the Fill
Material at Lemon Lane Landfill
August 21, 1996 (amended August 29, 1996)
The May 15, 1995, CBU comments (copy attached) in re Earth Tech's "Mini
QAP Plan for Field Oversight of the Site Investigation and Remedy Development
Activities at the Lemon Lane Landfill" dated March 1995, and Earth
Tech's "Conceptual Sampling Plan for Lemon Lane site (dated April 11,
1995) are incorporated herein with the following exception: Borings CBU
27, CBU 31 and CBU 32 are relocated to correspond with locations IDEM 3,
IDEM 2 and IDEM 1 (respectively).
It is our understanding that Sections 1 & 2 of the August 21, 1996,
version of the sampling plan are to be rewritten and either appended to
the plan or filed with the Consent Decree Parties as a stand alone document.
We support this decision by the corporation. However, the sections being
revised did contain some factual inaccuracies. Therefore, some comments
on the issues Westinghouse raises in those sections are presented:
Page 6, Section 2.1.6, Paragraph 3: Our inspection of the "hot spot"
areas just prior to closure in 1987 indicated a substantial quantity of
capacitors and capacitor parts remaining just below the geomembrane liner
fabric placed during the IRM. Therefore, as opposed to this statement, it
is highly likely that the pre=IRM concentrations discovered at the site
still exist.
Page 6, Section 2.1.6: The plan should state or estimate the volume of
liquid PCB believed to have been placed at the site between 1958 and 1964.
Page 7, Section 2.1.6.2: Our review indicates that borings B 1, B2, and
B3 are not physically located in or even near, known hot spots. While this
data may be useful for predicting the depth of PCB concentrations in non-hot
spot areas of the dump, it should not be viewed as an accurate depiction
of PCB concentrations in the hot spot and sinkhole areas.
Does data for PCB concentrations at the other five locations exist?
Page 7, Section 2.1.6.4, Paragraph 2, Sentence 2: Given the past problems
with transducer function and reliability, are we now sure that the 842 feet
AMSL is the highest recorded water elevation ever recorded at the site?
Page 7, Section 2.1.6.4, Paragraph 2, Sentence 3: Is this statement accurate
given the recently discovered ponding in the area of MW7?
Page 8, Section 2.1.6.4, Paragraph 5: Substantial quantities of trichloroethylene-impacted
soils were removed from the ABB site. The fact that trichloroethylene was
detected at ICS, which is believed to be directly connected to the MW7 conduit,
indicates the need to sample for other constituents.
Page 8, Section 2.1.6.6, Sentence 3: What is the source of this photo?
What are the dates for photos relied upon for making this statement?
Page 8, Section 2.1.7, Paragraph 1, Last Sentence: Due to vandalism and
natural deterioration, the fence installed by EPA at Illinois Central was
noted by government inspectors as being ineffective at controlling site
access as early as Spring 1990. This area was resurveyed, expanded, and
re-fenced in 1996 by Westinghouse.
Page 8, Section2. 1.8, paragraph 2, second sentence: We are unaware of
any special granular materials being applied in the area where chipped debris
were place.
Page 8, Section 2.1.7, Paragraph 3, Last Sentence: To our knowledge,
the effectiveness of the site silt fencing was never verified by analysis
for PCBs.
Page 9, Section 2.1.8, Last Sentence: Westinghouse's verbal description
inaccurately depicts the horizontal and vertical, extent of the known hot
spot in the southwest corner of the landfill. Personal observation (Langley,
Karwath, Dean, and Creech, 1987) and photographic evidence indicate the
presence of capacitors and capacitor parts as far as 200 feet from the southwest
corner along the south fence of the landfill and as far as 80-100 feet north
of the southwest corner of the landfill along the western landfill border.
The horizontal extent of contamination is especially important given the
existing natural drainage toward the MW7 area and the suspected underground
conduit associated with it.
Page 10, Section 2.2, Paragraph 6: The notion that the hot spot area
was remediated in 1987 and therefore poses no threat is patently false.
The purpose for removing some surface capacitors during interim remedial
measures was to prepare the surface of the dump for placement of the temporary
membrane cover, to protect the cap from puncture and to achieve the surface
contours necessary for site drainage. Large numbers of whole and broken,
leaking capacitors and capacitor parts remain in the southwest corner hot
spot. The parties anticipated excavation would take place within ten years.
Page 10, section 2.2, Paragraph 8: Placement of a temporary cover does
not constitute "remediation."
Page 10, Section 2.2, Paragraph 11: EPA contractors initially submitted
a plan which contemplated 47 samples as being statistically valid.
Page 10, Section 2.2, Paragraph 13: What reliability factor is expected
with the use of immunoassay sampling? This should be stated in some way.
Pages 10,11, Section 2.2, Paragraph 13 (cont.): The CBU supports the
collection of samples for RCRA characterization because of their obvious
usefulness when hot spots are later removed for off-site disposal. Likewise,
we encourage the collection of samples and analyses for all priority Clean
water Act pollutants (including dioxins and 2-dibenzofurans) now to accomplish
the goal of limiting the number of borings (as expressed by Westinghouse
in Section 2.2, Paragraph 14 and Page 10, First Paragraph). While this information
may not be immediately useful in RCRA disposal decision-making, it is certainly
relevant in determining potential risk during hot spot excavation.
Page 11, Section 2.3, Paragraph 1: Care should be taken to identify all
chemical constituents encountered at the ABB site because of the likelihood
that they too were disposed of at Lemon Lane Landfill. Page 11, Section
2.4.1, Paragraph 3: The CBU encourages analysis of any interval of soil
which exhibits properties (visual staining, the presence of oil, or odor)
regardless of whether the off-set boring was necessary. |
