CALL (812) 333-8888 FOR MORE INFORMATION OR E-MAIL info@copa.org

Library: Comments: Combined

Compilation of Comments Regarding the Westinghouse Fill Sampling Plan for Lemon Lane Landfill Preamble To facilitate a review of important comments on the proposed Lemon Lane sampling plan, COPA has compiled and inserted them where appropriate in Westinghouse's sampling plan. The following conventions are used: Text from the original Westinghouse Sampling Plan is shown in this font. Comments are shown in italics and within brackets [ ]. Commentors are defined as: EPA = Comments from Dan Hopkins, EPA Region 5 ET = Comments from Earth Tech, EPA's contractors IDEM = Comments from Indiana Department of Environmental Management City = Comments from the City of Bloomington Utilities department COPA = Comments from Citizen's Opposed to PCB Ash in Monroe County DISCLAIMER: Although great care was taken to ensure the accuracy of the information provided below, errors or omissions may exist. COPA strongly recommends that interested readers obtain copies of the original documents from the authors to ensure accuracy. Tables and Figures are not reproduced in the document that follows. Please report any errors to us. 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) General Comments that Apply to the Entire Document: EPA: Through the field sampling plan there are numerous references to the Lemon Lane Landfill being a large municipal landfill. Notwithstanding the word "landfill" in the site name, the site is actually a large dump where co-disposal of hazardous materials and municipal solid wastes occurred. The Lemon Lane Landfill is not distinguished from a dump by virtue of its design, construction, or management of the materials disposed there. In addition, the site is situated over a compound sinkhole, lending doubt about the stability of the site, and raising concerns about whether underlying native soil or waste materials can be wetted by subterranean drainage water during large storm events. Throughout the field sampling plan are references to "known" hot-spots. There are a number of guidance documents cited in the "References" list of the field sampling plan. In the field sampling plan you apparently rely on references for streamlining the fill sampling. I believe it is necessary to consider that: 1) the Lemon Lane Landfill is not an engineered landfill, as discussed above; and 2)that containment of PCBs at the site has not been and is not expected to be as simple a matter as capping the site. As you know, the site is already capped. From a review of historical PCB concentrations at the Illinois Central Spring, considering the concentration levels of PCBs in spring water before the cap was installed and also after the cap installation, one could argue that PCB concentrations at the spring have increased since the cap was installed in 1987. Certainly, the highest concentrations of PCBs in sediments at the Illinois Spring Stream (sufficient to cause two areas of the stream to be fenced) have been found approximately eight years after the cap was installed. Rather than focusing on streamlining investigations at the site, it is most appropriate to focus on what activities are necessary to mitigate the existing releases. The guidance document you refer to as "U.S. EPA 1991" provides a very good reference for the types of actions appropriate for the Lemon Lane Landfill. "U. S EPA 1991" contains a much more useful description for characterizing hot-spots. "U.S. EPA 1991" states that, "Hot-spots should be characterized if documentation and/or physical evidence exists to indicate the presence and approximate location of the hot-spots." Leave the word "known" out. Throughout the field sampling plan, there is reference to containment as the presumed remedy. Capping is not synonymous with containment. Containment refers to technologies that isolate the landfill contents and mitigate off-site migration through the use of engineering controls. Containment often includes capping, however, it may also require other controls (e.g. slurry walls, surface drainage controls, bottom liners, etc.). [COPA: Comments on the Overall Remediation Strategy. One of the opening statements of the Westinghouse sampling plan reads, "The industry standard and USEPA presumptive remedy for remediation of large municipal landfills with PCB or other hazardous contamination is containment." This is a partial truth that could lead unsuspecting readers to believe that containment is the only remedy that is expected, or required, at Lemon Lane Landfill. "Containment" means that the solid waste remains in its original location, but physical contact with contaminants is restricted and groundwater contamination is prevented. What this document does not convey to the reader is that government agencies and parties responsible for the cleanup are expected to select a different alternative at sites where substantial groundwater contamination cannot be prevented, and where there is no evidence that groundwater contamination will subside naturally within an acceptable time frame. There are alternatives to containment at Lemon Lane Landfill, and they must be explored. "Containment" at Lemon Lane Landfill cannot be appreciably improved beyond the current situation: a cap with groundwater and surface water sampling. This remedy has proven unsatisfactory. Widespread contamination of sediments, groundwater and surface water has already occurred, and appears to be worsening. Fish and wildlife impacts have been documented. Even with removal of "hot spots", the abundance of PCBs in the landfill suggest that PCB migration will continue indefinitely. "Presumptive remedies" have been identified for a few types of contaminated sites, including CERCLA municipal landfills, to expedite the Superfund Rl/FS process. At these types of sites, certain remedies are "presumed" to be appropriate unless site-specific conditions suggest otherwise. In the case of municipal landfills, containment in place is assumed to be adequately protective in most situations, and site characterization data can be limited. However, EPA clearly recognizes the need for site-specific variances from the presumptive remedy when, for example, the hydrogeology at a site makes effective containment of PCBs impossible. "Circumstances where a presumptive remedy may not be used include unusual site soil characteristics or mixtures of contaminants not treated by the remedy, demonstration of significant advantages of alternate (or innovative) technologies over the presumptive remedies, or extraordinary community and state concems... The presumptive remedy is simply an expedited approval process, not the only technically feasible altemative." (US DOE, Remediation Technologies Screening Matrix and Reference Guide, 1994) Other EPA guidance material includes the expectation that government agencies and parties responsible for cleanup will not select containment in cases where it is clearly inappropriate. For example, the 1990 EPA document titled, "Guidance on Remedial Actions for Superfund Sites with PCB Contamination" suggests that containment of landfills may be appropriate for even highly contaminated waste, but it also recognizes the need to remove even lower concentration PCB waste if containment is unreliable. The identification and verification of alternative remedies for Lemon Lane Landfill and other Bloomington PCB sites is specifically encouraged by EPA. An EPA OSWER Policy Directive titled "Promotion of Innovative Technologies in Waste Management Programs" (April 29, 1996) discourages the elimination of innovative technologies because they require testing to determine their applicability at a particular site. It encourages the consideration and use of innovative treatment and characterization technologies where they may have site-specific or program-wide benefits. Specific initiatives to eliminate impediments, simplify permitting and authorization, and introduce cost-sharing and risk-sharing are described in this document (attached). Revision of the overall remedial strategy for Lemon Lane Landfill must be made before the scope and methods of sampling activities can be established. In the Spring of 1995, COPA presented reasons why the geology and groundwater flow system near Lemon Lane Landfill make it an unacceptable candidate for closure in place. Government parties to the CD responded by denying that closure in place was an appropriate remedy for Lemon Lane Landfill, and denying that they were supportive of this remedy. They failed, however, to require Westinghouse to characterize the landfill so that appropriate removal and treatment/disposal options could be examined. EPA's "conceptual sampling plan" for Lemon Lane, released for comment last year, amounted to limited sampling in search of "hot spots". When the CIC and community members requested that more comprehensive site characterization data be generated, this sampling plan was described as being an important first step. The Westinghouse sampling plan currently being circulated for approval by the CD parties is very similar to the EPA "conceptual sampling plan", but EPA has lost significant ground since last year. "Clean area" sampling has been eliminated, analyses for dioxin and other contaminants has been removed, and the PCB action level was increased. The Westinghouse sampling plan should not be approved until it is part of an overall remedial strategy that aims to provide acceptable protection to human health and the environment. The current remedial strategy - containment with hot spot removal - is unacceptable as presented.] [IDEM General Comments: 1. The first two sections have the tone of a Westinghouse "position paper." At the September 26, 1996 Bloomington technical meeting, you indicated that these sections will be rewritten. 2. Three additional sample borings are needed to properly address all of the potential hot spot locations (see attached map): a. One boring should be located on landfill property adjacent to the Griffin Property. High levels of PCB contamination have been confirmed off-site in the low spot in the back yard of the residence directly east of the landfill. b. A second boring should be located on landfill property adjacent to the area along Lemon Lane Street that floods during heavy rains. This location is needed to determine if rainwater is infiltrating into the landfill material which contains high levels of PCBs. c. The third boring should be located north of the landfill's northern sinkhole. This location is needed to determine if PCB contamination was transported with surface water runoff prior to the interim cap being installed in 1987. 3. The U.S. EPA should be given the opportunity to split samples during the investigation. 4. In section two, consider developing individual subsections for topography, geology and hydrogeology. 5. In the fill material sampling plan several references are made to the 1995 QAPjP. However since this 1995 QAPjP will be undergoing amendments, any revisions to the 1995 plan should have an approval date located at the bottom of the page.] Table of Contents 1.0 Background and Summary 2.0 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 2.1.6.5 Electromagnetic 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 for Field Surveys and Sampling 7.1 Procedures for Mapping and Surveying 7.2 Borehole Drilling and Abandonment 7.3 Soil Sampling Procedures 7.3.1 Types of Soil Samples 7.3 2 Collection of Soil Samples 7.3.3 Collection of 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 and 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 1.0 Background and Summary of Sampling The Lemon Lane Landfill is a large closed municipal landfill. [ET: Rewrite to say "The Lemon Lane Landfill is a large, closed, municipal dump. During several years of its operation as an uncontrolled open dump,"... The site was not an engineered landfill and lacks sufficient containment tobe considered as a landfill.] During several years of its operation, polychlorinated biphenyl (PCB)-contaminated capacitors were disposed al this site. After the PCBs were classified atoxic substance and the CERCLA legislation became law the site wasinvestigated and placed on the National Priority List (NPL) due to PCBcontamination. The industry standard and USEPA presumptive remedy for remediation of large municipal landfills with PCB or other hazardous contamination is containment (USEPA 1990a). In addition to containment, removal of known hot spots may also be considered. [EPA: It is unclear whether the rationale for a presumptive remedy of containment described in this paragraph is either the industry's standard, U.S. EPA's presumption, or Westinghouse belief. U. S. EPA considers that, in general, the remedial actions implemented at most CERCLA municipal landfill sites will include: containment of landfill contents remediation of hot spots control & treatment of contaminated & leachate control and treatment of landfill gas EPA's rationale for presuming containment at municipal landfill sites assumes that waste materials pose a relatively low low-level threat or where treatment is impracticable. For these sites, containment is identified as the most likely response because: 1) CERCLA municipal landfills are primarily composed of municipal, and to a lesser extent, hazardous wastes; therefore they often pose a low-level threat rather than a principal threat; and 2) the volume and heterogeneity of wastes within CERCLA municipal landfills will often make treatment impractical. The National Contingency Plan also contains an expectation that treatment should be considered for identifiable areas of highly toxic and/or mobile material (hot-spots) that pose potential principal threats, which do exist at the Lemon Lane Landfill. If you must portray EPA's rationale underlying its presumptive remedy as part of this field sampling plan, then I suggest that you also identify the types of sites that EPA considers appropriate for the presumptive remedy (i.e. CERCLA municipal landfills whose wastes pose a relatively low low-level threat), which incidentally, does not describe the Lemon Lane Landfill. I suggest the following: U.S. EPA considers (use reference U.S. EPA 1991) that, in general, the remedial actions implemented at most CERCLA municipal landfill sites will include one or more of the following actions: containment of landfill contents remediation of hot spots control and treatment of contaminated and leachate, and control and treatment of landfill gas] The reasons for choosing containment include: The heterogeneous nature of the material The difficulty characterizing the site The large volumes of material [EPA: (the 4 paragraphs that follow) relate to why characterization of landfill wastes should not be conducted. These three paragraphs are irrelevant to the purpose or background for the sampling effort to be undertaken.] Site characterization activities are generally performed to provide information for risk assessment and site remedial evaluation. Within the broad area of she characterization two of the more common sampling strategies are to define average values of the material (physically and chemically characterize the material) 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 conducting remedial investigations of municipal landfill sites(USEPA 1991). The guidance recommends limiting site characterization activities to those required to support the presumed remedy. A limited site investigation is warranted 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 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 determine average representative concentration of the PCB contaminated material. (ATSDR 1994). The other typical sampling 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. [ EPA: there is insufficient basis to determine the validity of the second sentence of this paragraph I believe that all of the parties acknowledge the view that ponded water in the area of monitoring well # 7 is related to elevated PCB concentrations found at Illinois Central Spring during storm events. Where in the landfill (or underneath the landfill) the water picks up the PCBs is not known. It is certainly possible that the ponded water ultimately contacts the PCB contaminated waste materials as the water moves toward the sinkhole. Whether fill material or PCBs from the fill material in the area of MOO-7 is ultimately carried to the spring with drainage water is not known.] [ET: Statement regarding no current exposure to "fill material" for any receptor is not known to be true. Sediment from the site is presumed to be the main carrier of PCBs to Illinois Central Spring. A possible future land use for this site might be as closed open dump.] The most likely future land use for this site is as a closed municipal landfill. Risk assessment and remedial alternatives evaluations are currently in progress for pertanent closure of the 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 Lane Landfill. [EPA: last sentence - leave out the entire sentence. This sentence is irrelevant to the purpose or background for the sampling effort to be undertaken.] In the course of this debate several conceptual level sampling programs for the fill have been put forward. One 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 diametrically 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. [EPA: this paragraph is sufficient for background related to the U.S. EPA sampling plans. Please eliminate the first sentence of the paragraph and replace it with the following, "During the course of discussions related to sampling the fill material at the site, the U. S. EPA proposed two different conceptual sampling plans."] [ET: Investigation of waste characteristics is not contrary to EPA guidance.] 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 determined by EM survey [EPA: eliminate the first two sentences (of the preceding paragraph). Begin the paragraph with, "This field sampling plan...."] 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. [EPA: leave out the reference to "a single-phase field investigation". Westinghouse may wish to limit any investigation of the fill material, however, U.S. EPA will not agree to such a limitation up-front. Given the scope of the combined Westinghouse and U. S. EPA sampling effort, it may be that no further fill sampling is necessary. However, such a determination should be made only after an evaluation of the analytical data is performed.] 2.0 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 northwest side of the City of Bloomington in Monroe County Indiana. The landfill location is shown on the area map in Exhibit 2-1. [ET: The map location of Exhibit 2-1 is not accurate.] The landfill includes about 10 acres [ET: The site covers 11.5 acres] and is bounded by Lemon Lane and residential property on the east by the L&N Railroad on the south [ET: CSXT Railroad on South, not L&N Railroad] residential property on the north and by undeveloped land on the west. The Indiana State Route 37 Bypass is approximately 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. [ET: Rewrite to say "Fill material (waste) and native solid at the site range from about 8 feet to 43.5 feet or more. The air photo study by Westinghouse consultants determined that the fill or waste materials are more than 10 feet thick in places. The thickest waste shown on B-2, one of eight boring logs, is 30 feet.] The overburden is underlain by Mississippian age bedrock units. The St. Louis Limestone of the Blue River Group underlies the overburden layer, and beneath this unit lies the Salem Limestone of the Sanders Group. The St. Louis Limestone has formed a regional geology characteristic of karst terrane. [ET: This sentence makes no sense. Are you trying to say "several small to large size sinkholes are present in the immediate area"?] 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 swallow holes typical of karst terrane. [ET: Rewrite to say "The uppermost groundwater flow system associated with the site consists of surface run-off into sinkholes and soil water that infiltrates into solution enlarged conduits that resurfaces at springs.] [ET: Some soil water associated with the bedrock surface and water in solution enlarged joints and fractures also drains to the conduits.] Groundwater flows primarily through solution-enlarged fractures and joints to the southeast and eventually discharges at the Illinois Central Spring. [EPA: groundwater flows primarily to the Ill. Central Spring but not exclusively. Please reword so that it is clear that most of the uppermost groundwater flow eventually discharges to the Ill. Central Spring.] 2.1.3 Topography and Hydrology The Lemon Lame Landfill is situated in a surface depression associated with a regional trend of compound 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. [ET: Review to say "The Lemon Lane Landfill is for the most part situated in two sinkholes that are along an alignment of compound sinkholes that extends southwestward from the site to beyond the CSXT Railroad tracks.] The topography across most of the moderately slopes to the west. The surface of the landfill ranges in elevation from 850 to 890 feet above mean sea level (AMSL). [ET: The surface of the site ranges from 860 to 888 feet amsl, not 850 to 890.] 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 River and Sanders Group. The Mitchell Plain surface is relatively flat with moderate slopes and karst topography. [ET: The upland surface of the Mitchell Plain is relatively flat and in part charcterized by karst topography, but some surface streams are deeply entrenched. 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 and intermittent springs and at least one sinking stream. A sinkhole pond (Sargents Pond), is located northwest of the site. [ET: Delete the word "karst". "Solution features" in the underlying bedrock are just that. They are not karst features because they are not at the surface.] 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 macro pores. [EPA: there has been no evidence presented that the water in Sargent's pond drains slowly to the subsurface via small pores. Is this Westinghouse's speculation or is there information available to you that has not been presented in the technical meetings? If the description of Sargent's pond drainage is Westinghouse's belief, please identify it that way.] 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. These wells were sampled for PCBs quarterly from September 1995 to June 1996. No PCBs were detected. [EPA: what is meant by the immediate vicinity? Are you referring to the "catchment" area? This section does not account for the possibility that under some conditions some of the residential wells could get PCBs by the "ripping" of PCB containing water during certain high water events, potentially affecting residences outside of the "catchment" area. Also, this section should indicate the likelihood of environmental contamination, through the groundwater route, at Ill. Central Spring and potentially the Slaughterhouse spring.] 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. [ET: Rewrite to say "The City of Bloomington operated the open dump from 1950 to 1964. The earliest dumping was along the road. (What is now Lemon Lane) and in the two sinkholes on the site. Refuse was deposited over the entire site after the southern sinkhole was filled and the site expanded into the northern sinkhole".] 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 absence of controls and design features now common to today's facilities. [ET: Rewrite to say "The open dumping operations were typical..."] No liner or cover was used and dumping was not controlled. Scavenging and burning were common daily practices. No records of types or quantities 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. [EPA: the description does not fully identify that capacitors were found in other areas of the site and that the limited sampling conducted in 1987 shows other potential hot-spot areas (exhibit #7 of the Consent Decree)] [ET: Rewrite to say "...(prior to partial removal to facilitate installation of the interim cap)..."] 2.1.6 Chronology of Site Investigations 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 investigations associated with the Lemon Lane site. Appendix A, exhibits A1 and A2 provides a list of the previous investigations. [ET: The list of previous investigations is incomplete, so say "partial list of previous investigations up to 1985."] 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 vicinity of the site continue to this day. Because surface capacitors were removed and a synthetic membrane installed as part of the IRM; the pre-IRM sample results for surface soils are not necessarily representative of the current site conditions. [EPA: The last statement in the section is speculative and does not add value to the section. The pre-IRM samples were of soil not capacitor constituents. Does Westinghouse know whether the dump surface in the southwest corner of the landfill area was graded during the IRM activities? Unless there is specific information about soil removal or grading of the 1987 surface in the areas represented by the sample data, leave the statement out.] [City: Our inspection of the "hot spot" areasjust prior to closure in 1987 indicated a substantial quantity ofcapacitors and capacitor parts remaining just below the geomembrane linerfabric placed during the IRM. Therefore, as opposed to this statement, itis highly likely that the pre=IRM concentrations discovered at the sitestill exist. The plan should state or estimate the volume ofliquid PCB believed to have been placed at the site between 1958 and 1964] 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. [ET: Units must be consistent with data on Table in Exhibit A4, and, do not round off numbers.] 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 surface to 5 feet (exhibit A3). [ET: The table in A-3 gives sample results from four locations, not nine.] Two sample locations with capacitor areas. PCBs were detected at all nine locations with a concentration range of 0.1 to 57,000 ppm. No other chemicals were reported at detectable levels. In October 1984, two onsite and several off site soil samples were collected by USEPA and were analyzed for dioxins and dibenzofurans (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). [ET: Rewrite to say "Fifteen composite samples, each consisting of samples from three separate locations, and two duplicate samples, as well as an offsite background sample were analyzed..."] Every three samples were accumulated in the field and the resulting 17 composites (including 2 duplicates and an offsite background sample were analyzed for full scan organic analysis including acid/base/neutrals and volatiles. PCBs were detected in all samples and the levels varied from 4.2 to 2300 ppm. [ET: Rewrite to read "...from 4.2 to 4,300ppm." The total for composite 5-41, locations 19, 20 & 21 is 4,300 ppm, not 2,300 ppm. Again, units must be consistent with Table.] 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. [EPA: xylene at 36 ppm (locations 19 through 21) and 460 ppb dibenzofuran(locations 4, 5, and 10) was also reported by the TAT (refer to the March 11, 1987 TAT sampling attachment to your field sampling plan).] [EPA: Paragraph 5 does not report the values of City's dioxin data. Even if the data has quality control problems, the values should be reported and appropriately qualified. I understand that the City intentionally located "burn" areas of the fill and selected those areas to represent maximum dioxin/furan concentration in the fill. Simply stating that the lab reported major interferences that affected quantitation is too limited] [ET: Location of each sample, not locations. What does "in addition" refer to? Delete the phrase. The lack of a location map has been explained, but where is a statement or a table to indicate the amounts of Dioxins and Furans reported? The amounts of PCBs found should be the last sentence.] 2.1.6.2 Soil boring Sampling and Analysis. In March 1984, Westinghouse drilled 8 borings in the landfill. 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) [ET: Exhibit A-6 lacks a map showing locations of borings.] in the fill material of the Lemon Lane Landfill site were 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. at the Lemon Lane Landfill site were analyzed for 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 and dibenzofurans. Dioxins were detected in one sample at 0.002 ppm dibenzofurans were detected in three other samples with a concentration range of 0.0002 to 0.002 ppm. [EPA: Wasn't the purpose of the Westinghouse boring effort primarily to determine quantity of the fill material and BTU value of the waste material? The PCB sampling certainly was not done in areas where elevated PCB concentrations were expected.] [ET: Where is a table to show depth sampled and results for each sample? Values given in text should be given as ppb and not rounded off, if origianlly reported as ppb. Is tabular data given in A-4?] [City: 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?] 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 established at the site at 75f foot 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 PID 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. [ET: Where and how many PID samples were taken: Need a location map and table of results for PID samples.] 2.1.6.4 Groundwater and Surface Water Sampling A number of wells have been installed on the immediate perimeter of the landfill.. [ET: Say how many monitoring wells, not "a number", and some are not on the immediate perimeter. A figure is needed to show locations of all monitoring wells, a text designation for the five sampled in 1995-96 and table of results for each well, for each month is needed. The text presented ignores all historical data and is false in that it implies that all wells, including MW-12, were sampled for PCBs prior to 1995. A table and text is neede to exhibit results of pre 1995 sampling for PCBs.] 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 Monitoring 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 to 1.4 ppb. [EPA: Why hasn't any of the previous sampling results (prior to the last four quarters) been at least briefly described? At least a range of values should be reported here. The IDEM's sampling results of approximately 1995 for two of the monitoring wells should also be summarized here.] In addition to PCB concentrations, these wells are also continuously monitored for water level. [ET: Rewrite to say..., "These five wells and three others are..." These two sentences are very misleading. These eight wells may or may not be monitoring ground water levels at any given time, and the data may not be available (lost in retrieval from Data Logger) for any given well. The earliest sampling interval for a possibly correct "continuous" water level in Monitoring Wells 4I, 6, 7, 8S and 9 was June of 1995. The subsequent record is not continuous at all of the monitoring wells, especially MW-7.] Data collected shows that the highest groundwater elevation ever recorded is 842 feet AMSL. [ET: Delete the word "ever" from "ever recorded", inasmuch as it over states the case, try "recorded to date".] 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. [ET: State that the 842 water level is at MW-7. Rewrite to say, "This water level is about nine feet above the depth of refusal, perhaps at the bedrock surface, in a soil boring within the area of the southern wastefilled sinkhole on the site and about five feet above bedrock at MW-7". The so-called "highest-ever" recorded water level at 842 feet AMSL occurred on 29 April 1996 as a result of about two inches of rainfall about five days following about two inches of rainfall. MW-7, prior to June 1995, therefore, they failed to record a water level for the 17 to 19 June 1995 storm event during which about six inches of rain occurred. As a consequence, we still have only a vague idea as to how high the water level can rise in the sinkholes near MW-7. We can see that it flooded on the surface to a level above 862 feet, sufficient to saturate waste on the southwest part of the site.] [City: 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?] 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. [ET: Whether or not the groundwater at MW-7 is connected to a conduit draining the site is certainly questionable in consideration of the new data available, even though there is about a years worth of usable data. First, it it somewhat obvious from two tape down measurements prior to 1988, when the hypolon cap had been installed and MW-7 was plugged back from a greater depth, that water levels in this well better reflected a concept of the highest and lowest water levels at the site. However, subsequent to installation of the cap, the partially waste filled sinkhole at MW-7 is subject to flooding caused by the almost total and rapid run-off from several acres of the capped site. For that reason alone, the water level recorded at MW-7 cannot be demonstrated to clearly represent free flowing water in the conduit system. Subsequent to back filling in 1988 (from about 756 feet amsl to 796 feet amsl), the water levels recorded at MW-7 have not dropped to the pre-plug levels represented by three tape downs; that is down to about 812 feet AMSL, and similar low altitudes recorded "continuously" by B&B in June of 1988, two months after the well was backfilled. It is obvious that current water levels in that well do not accurately reflect the water levels in the conduit system, that is, the former low period levels are not being recorded, as is indicated by the irregular decline below an altitude of about 822 to 823 feet AMSL documented in August to December 1995. The abrupt flattening of the tail on the water level decline at MW-7 demonstrated by recent monitoring is proof that either the transducer arrangement is incorrect or malfunctioning, or that the well or adjacent rock has been affected by some artificial condition subsequent to plugging back the well. Regardless of the reason, the recent data from MW-7 is inadquate to demonstrate what is happening in the conduit system. In other words, data from MW-7 is no longer useful for that purpose, but probably is a fair indicator of what is happening in the sinkhole at MW-7 and materials in the adjacent corner of the site. Perhaps a new shallow monitoring well to an altitude of about 810 AMSL is needed in the vicinity of the southwest corner of the site that is beyond the effects of flooding in the sinkhole. A functional monitoring well or wells in the waste filled wouthern sinkhole would provide some information on the effects of infiltration of flood waters in the sinkhole on the waste and fill, and/or the back flooding in the conduit system.] [City: Is this statement accurate given the recently discovered ponding in the area of MW7?] Dye tracing to determine the resurgence of groundwater potentially impacted by the site was conducted in 1987, 1989 and 1990. [ET: Replace "potentially impacted by" with "in the vicinity of"...] These traces showed that the majority of the groundwater flows to the Illinois Central Spring southeast of the site. Some water may also travel to the Slaughterhouse Spring system to the northwest during high flow events. The potentially impacted springs were also sampled extensively as part of the same field sampling plan referenced above. [ET: Rewrite to say "These springs were sampled as part of..."] 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 spring for other contaminants in 1995 and in earlier years during both low and high flow [ET: Not true-1,1,1,-trichlorethene, 1,2-transdichloroethylene, and trichlorofluoromethane were found, see 1982 and 1983 EPA data.] [EPA: Tracer chemicals in storm water related to the site was shown to resurface at the Slaughterhouse Spring during an earlier tracer study. In fact, Westinghouse identified a "breakthrough" of tracer at Slaughterhouse. The last sentence of paragraph 3 of this section implies a more tentative conclusion. In the last paragraph of this section include that a low level of octa-dibenzofuran was also found in Illinois. Central sediment during the third quarter sampling. Also, earlier sampling by U. S. EPA found other chemicals (see Powell comment 8-2.1.6.4-10 (ET comment shown above)) in spring waters at the Illinois Central Spring.] [ET: Rewrite to say "These springs were sampled as part of..."] [City: 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.] 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. [EPA: There should be included, in this discussion, that the boring locations identified in the sampling plan coincide with or are located near the EM survey anomalies.] 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. [City: What is the source of this photo? What are the dates for photos relied upon for making this statement?] 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. [EPA: Include that Earth Tech also provided an analysis of air photos.] [ET: If the depth of refuse in the southwest corner is 2 to 10 feet it is just as likely that capacitors will be found to that depth. Delete the last sentence or change the depth to ten feet.] 2.1.7 lnterim Remedial Measures Interim remedial measures were implemented at Lemon Lane Landfill in two phases. Phase I began in June 1983 and included the installation of a security fence around the entire perimeter of the site. This 8-foot-high, locked chain-link fence with barbed wire strung across the top was installed for the USEPA and is maintained by Westinghouse The USEPA also installed a fence around nearby Illinois Central Spring and posted warning signs in the area. [ET: Westinghouse installed a fence around Illinois Central spring in 1995.] [City: 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.] 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 material and the entire site was covered with TYPAR geotextile, followed by 30,000 tons of clean fill and a 36 mil HYPALON geomembrane cover. The synthetic membrane was installed to minimize rainwater infiltration 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 boundaries of the landfill during the preparation and capping of the site. [City: To our knowledge, the effectiveness of the site silt fencing was never verified by analysis for PCBs.] 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 material 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. [EPA: Please describe how Westinghouse monitors gas emissions. Let people know how you conclude that "the sampling results indicate that not gas emissions have been detected." In July 1991, EPA monitored PCB concentrations at the landfill perimeter and found PCBs in air (on a hot day) at 38 nanograms per cubic meter. This should be mentioned.] Phase II 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 Board), 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 verify that the security fence and cap are intact. Access to Lemon Lane Landfill is via an access road from Vernal 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 unspecified amount of municipal and industrial waste and meets the EPA's definition of large municipal landfill with mixed municipal and industrial wastes (EPA 1991). [EPA: What is the point of the 1st sentence? As discussed in the general comments, the site is, more appropriately, a dump.] [ET: The Lemon Lane Landfill was operated as an unpermitted open dump, that is, it was operated and maintained without cover and without regard to the possibilities of contamination of surface or subsurface water resources (329 IAC 10-2-128, 1995). Under federal regulations (40CFR Ch.1, p263) an open dump received wastes in a manner that does not protect the environment.] 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 of the landfill. [ET: The reference to "most of the capacitors" could simply mean slightly more than half were dumped in the southwest corner of the dump. The southwest corner of active dumping would not always have been at the southwest corner of the site.] [City: We are unaware of any special granular materials being applied in the area where chipped debris were placed.] 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. [EPA: Even if a 500 ppm value is chosen, there is at least one other potential hot-spot fitting the criteria of a 500 ppm concentration value. Both of the areas demonstrating elevated PCB concentrations (in excess of 500 ppm) were where piles of surface level capacitors were found. There were also other areas of the site where piles of surface level were found, but where sampling did not occur. The usage of "known" to describe hot-spots has been discussed in the general comment section of these comments.] [ET: The known "hot spots" extended almost entirely along the south side of the site and halfway north from the southwest corner (See Figure 1-7, Exhibit A-5 of Westinghouse report). This margin was the area not covered with soil and road waste materials during the 1964-66 closure of the site (Powell, R.L., 1995, Review of Selected Aerial Photography at Lemon Lane from 1958 to 1967). Thus capacitors most likely are present at a shallow depth adjacent to the areas exposed in the 1980s.] [ET: Area 5-5-10 on figure 1-7 in exhibit A-5 shows 2,200 ppm PCBs that are not in the southwest corner of the site.] 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. [ET: Not all visible surface capacitors were removed from the site in 1987] The most recent sampling conducted shows that groundwater in the immediate vicinity of the site [EPA: What does the description "in the immediate vicinity of the site mean"?] and surface waters (primarily the Illinois Central Spring) that receive site groundwater are the only open pathways for contaminant transport and exposure to human and ecological receptors. [ET: Change to read "...are the only known open pathways..."] A significant amount information has been collected on the site by a combination of geophysical, anecdotal intrusive and non-intrusive sampling. [ET: What is "anedoctal" sampling? Delete the word.] In aggregate the information is consistent with or exceeds EPA guidance for investigation of such sites and is sufficient to support a presumed remedy of containment. . [ET: The site is not now contained. Contaminated groundwater is leaving the site to affect a surface stream. How is this water or materials in the bottoms of the sinkholes to be contained? This workplan presumes a viable remedy is available that negates the need for additional site data, (see page 1 of Westinghouse plan), but no means of containment or stabilization of leachate, soils and wastes in the sinkholes is presented.] [EPA: this paragraph has no relevance to the sampling plan. Rather, this paragraph might possibly be relevant in a letter explaining why the company does not believe that additional sampling is necessary. The information gathered to date for this site (at least as is known to EPA) is not sufficient to examine the feasibility of removing PCB hot-spots from the landfill. On the other hand, if the company has information that describes the areal and vertical extent of contamination sufficient to describe hot-spots, it should come forward with that information. Perhaps, the company has presumed (as is indicated by the paragraph) that the sole remedy for this site is containment. U.S. EPA does not agree with that presumption. Also, as previously discussed, capping is not synonymous with containment. Therefore, the sampling described in this paragraph is not sufficient to support a remedy of containment.] [City: 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.] 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 Lane Landfill (USEPA 1991). [EPA: The first two paragraphs of this section are irrelevant to the purpose or objectives of the sampling to be undertaken.] 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. [ET: Lemon Lane Landfill operated as an open dump sited in two sinkholes, thus, is atypical of the type of landfill depicted in the US EPA, 1991, guidance document. There is no reference in the document to suggest any experience with wastes in sinkholes.] 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 environment * the presumed remedy (containment) does not require such information [ET: Neither this plan by Westinghouse, nor any other scheme presented to date, addresses stability or containment of wastes or solid in the sinkholes] Because of the above, the guidance recommends that the characterization of municipal landfills be streamlined and focused. [ ET: The site was an open dump, not a landfill] 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 environment. Principal threats for PCB industrial sites has been generally 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 threshold concentration of PCBs that determines a hot spot should significantly increase. [EPA: The discussion concerning cancer slope factors is moot for the purpose of this plan. The comments concerning the possibility of changing threshold PCB concentrations based on new cancer slope factors are speculative and moot for the purpose of this sampling effort.] At the Lemon Lane Landfill, there is one known PCB hot spot at the surface of the southwest corner. [ET: More than the one hotspot located in the southwest corner of the site has been documented (see Westinghouse figure 1-7 in Exhibit A-5)] Neither previous sampling or anecdotal information shows a significant potential for any the hot spots containing PCBs or other contaminants. The site has been capped the PCB contaminated material at the surface of the Southwest corner is no longer accessible to human or environmental receptors. [ET: There are environmental receptors for the high amounts of PCBs exiting Illinois Central Spring.] Additionally, this material is well above groundwater levels at the site and thus cannot be mobilized in this manner. [EPA: The discussions provided in this paragraph have been previously discussed. Please remove the entire paragraph.] [ET: The concept that the material in the southwest corner is above groundwater levels is speculative. Flood water in the sinkhole at MW-7 probably wets contaminated wastes materials. Not all capacitors were removed from the southwest corner in 1987, so at best that area was "partially remediated".] 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 containment with removal of the known hot spot. [City: 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. ] [EPA: Because the author of this document has apparently not even referred to a dictionary definition for "remediated", let me offer a definition of "remedy": To restore to the natural or proper condition; put right. Covering over contaminated material is not synonymous with "remedy" or "remediated". Although restoration to the natural or proper condition may not be the criteria for a final remedy, it is likely that containment will be a component of a final remedy.] Consideration of removal requires an estimate of the volume to be removed. The previous visual records and surface sampling have shown the approximate areal extent of this material. [ET: The reference to the airphoto study by Westinghouse (1983) is to the interpretive work by Ta Liang (see Blasland & Bouck, Jan. 1987, Reference cited ...Lemon Lane). The work of reference is at best a generalized approximation and is not a thorough and detailed study (draft, no author, May 1983). Several items related to the Ta Liang study are questionable. Foremost, perhaps, is the fact that the original work by Ta Liang consisted of a crude outline of the dump area within which estimates of thickness of fill were made at random points as one of three gross categories (Shallow <2, Medium 2 to 10, and deep >10 feet thick). Ta's work was apparently redrawn by B & B by adding lines between the designated random points and shading the areas. However, B & B failed to both scale and to register accurately the work by Ta, such that they show the extent of the landfill about 80 feet too far west for the 1958 to 1967 interval grossly too small a scale for the 1967-1983 interval. A sketch topographic map (7/26/58) included in the report shows the altitude in the southwest corner as at about 860 feet, but shows a depression about three feet deep at a location above the filled southern sinkhole (871 feet -868 feet=3feet). This same sketch map shows an open sinkhole about 12 feet deep (about 865 feet to lower than 855 feet) in the position of the northern sinkhole at a general location that shows more than ten feet of refuse during the 1958-1967 time interval.] 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 contain capacitors at this location is limited to the upper layer and ranges from 2 to 10 feet deep. . [EPA: Paragraphs 6 and 7 are irrelevant to the objectives of this sampling plan.] [ET: Most of the site, but excluding most steep edges, was covered with several feet of soil, waste road debris and perhaps ash or cinders during the period of closure by the city of Bloomington. These materials covered any wastes, including capacitors, that may underlie them. Most likely more capacitors are present beneath the cover emplaced by the city, considering the high concentration of PCBs found in the composite sample at 4-5-10 (figure 1-7, Exhibit A-5, Westinghouse plan), where capacitors were exposed through the cover (see same figure).] Since the known hot spot has been remediated by capping [EPA: A final remedy for this site may include capping, however, as previously discussed, capping is not synonymous with containment. Visual records and surface sampling have neither defined the approximate areal extent nor the vertical extent of PCB contamination.] [City: Placement of a temporary cover does not constitute "remediation."] and there are no other known hot spots to investigate, under the guidance (USEPA 1991 ) no other sampling in the fill should be performed. [ET: Sentence is not true, capping is not the same as containment, it is at best partial drainage control. There are several known hot spots aside from the southwest corner. There is no reason to assume that the 1991 EPA guidance document applies to sinkholes.] Rather sampling of contaminant pathways such as the Illinois Central Spring water can provide information needed for both risk assessment and remedial alternatives development. This is especially the case when sampling can damage the cap and is inherently difficult and risky operation in a mixed refuse industrial waste environment [ET: If Westinghouse is aware of some risk and difficulty of sampling of wastes at Lemon Lane as a result of previous experiences with boring at the site this information should be shared with Consent Decree parties.] However, there is considerable disagreement among the Consent Decree parties concerning the need for additional sampling in the fill. [ET: There is less disagreement between the governmental parties regarding sampling the wastes than there is between them and Westinghouse.] To move the process along in spite of these disagreements several conceptual level sampling plans have been proposed. [ET: Only one sampling plan has been proposed, not "several", the Westinghouse plan in no more than a modification of the EPA plan, as admitted in the next paragraph (line 26).] 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. [EPA: the discussion of previous conceptual sampling plan has already been described. As a matter of fact, much of the information presented on this page has been repeated in (or reworded from)prior sections of the sampling plan.] 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 the known 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 anomalies at the site for PCB contamination Evaluate the potential for known hot spot material to be RCRA characteristic waste [EPA: One aspect of this plan has changed from a screening level sampling based on immuno-assay testing. By agreement with the other parties, the samples will now be analyzed by a laboratory.] To accomplish the above goals a maximum of 25 borings will be used. The specific location for each of the 25 borings is detailed in section 2.4. The data obtained will be used in assessing final site alternatives per the guidance provided in references USEPA 1990a, USEPA 1990b, USEPA 1991 and USEPA 1996. [ET: The statement "guidance provided in references USEPA..." is too vague as to have any meaning. Please be specific, cite paragraph and page numbers as to specific documents.] The data will not be used in risk analysis. Current envisioned uses include helping refine volume estimates of contaminated materials. [ET: The phrase "...helping refine volume estimates..." is grossly misleading. Please show the existing Westinghouse estimate and the data on which that estimate was derived. What are "envisioned" uses of the data other than "helping to refine volumes"? Please mention the other uses.] [EPA: The paragraph should be changed to reflect that U.S. EPA will samples from seven additional boring locations.] [City: EPA contractors initially submitted a plan which contemplated 47 samples as being statistically valid.] All samples will initially be analyzed for total PCBs by use of immunoassay field screening analysis. [City: What reliability factor is expected with the use of immunoassay sampling? This should be stated in some way.] 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 parties may have an interest in.) A minimum of 10% of the samples will also be split and analyzed by conventional PCB analyses (method SW-846 8081). [ET: 20% of samples or one sample from each boring should be sent to lab for confirmation PCB analyses.] The kits would be initially set for a range of approximately 50 to 1000 ppm based on Aroclor 1248. This is the Aroclor identified in previous samples of fill material. [EPA: The paragraph should reflect the change in analytical protocol, discussed above.] [City: 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-dibenzofrans) 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.] Limiting the number of borings will also limit the damage to the existing site cap. [ET: What does "also" refer to? What else does limiting the number of borings accomplishing other than damage the 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 borings 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. [ET: The condition that only one boring is to be completed as a monitoring well, in light of the previous statement that all borings will be closed immediately, states clearly that only one monitoring well will be installed regardless of conditions found by boring, even if more wells are needed. At a minimum, two wells should be completed, one each in the bottom of the waste at the two sinkholes on site.] [EPA: Please include that Westinghouse will relocate the relocated U.S. EPA borings in the event that hand coring or power auger techniques do not provide samples down to the native soil.] For a summary of reference of field procedures, please refer to Exhibit 2-4. [ET: Exhibit 2-4 is not a summary of reference field procedures, thus this so-called sentence is a bunch of words thrown together in a meaningless manner. Exhibit 2-4 is a list of field procedures.] 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 drilling and will he selected based on conditions encountered in the field. Hand coring and or use of hand held power augers may be required on 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, including TCLP, reactivity, corrosivity and ignitablity. The list of parameters is shown in Table 3-1 of the QAPjP (Westinghouse 1995). [City: 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.] [EPA: I recognize that Westinghouse does not, at least at this time, acknowledge responsibility for contaminants other than PCBs at the site. It is acceptable to describe that Westinghouse will limit its sampling to PCBs and the RCRA characteristic parameters, however, the responsibility for dioxins and furans remains an open question at this conjuncture.] [ET: Rewrite first two sentences to say that the contaminant of concern is PCBs.] 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 corner of the landfill. [ET: Rewrite to say "All boreholes will be advanced and sampled continuously through the waste material and into the natural soil underlying the site within the ...". Sampling is discussed in the third paragraph. The need for a description of each split sample prior to mixing for analysis seems to be omitted.] 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 intent 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 extent 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). [ET: last line Results should be expressed on dry weight basis.] 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 depth 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 to refusal 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 of sample receipt. The 2-foot samples will be retained for additional 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 aliquot 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. 2.4.2 Sinkhole Investigation [This section missing from our copy of Westinghouse text. To be replaced ASAP] [EPA: Compositing of the sinkhole samples (two 2 foot samples) is acceptable provided that the action level is halved. If the analytical results of any of the four foot composites exceed 250 ppm PCBs, then each of the 2 foot samples must be reanalyzed and the results reported.] [ET: Rewrite to say "All boreholes will be advanced and sampled continuously through the waste material and into the natural soil underlying the site within the ...".] [ET: Composite samples should be for each 2-foot interval not 4-foor intervals to be consistent with studies under section 2.4.1.] 2.4.3 Electromagnetic Anomaly investigation The USEPA performed an electromagnetic survey in June 1995. The goal of the survey was to identify anomalies that may be indicative of major capacitor caches. As a result of the survey, USEPA has identified areas that they recommended be investigated. Boreholes will be advanced through the landfill and into the natural soil underlying the landfill and sampled within areas of high metallic content as indicated by electromagnetic survey . [ET: Rewrite to say "All boreholes will be advanced and sampled continuously through the waste material and into the natural soil underlying the site within the ...".] 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 collected at each 2-foot-depth interval starting at the top of the landfill and continuing until natural soil material or refusal is encountered. The refuse/fill in the electromagnetic anomaly areas may be up to 20 feet in depth. The borehole will be completed 2 feet into the natural soil below the refuse/fill. Every attempt will be made to reach the base of the landfill, based on a visual examination of 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 composite created that represents a 4-foot interval. The composite will be analyzed for total PCB at an onsite laboratory using immunoassay kits. [ET: Composite samples should be for each 2-foot interval to be consistent with studies under section 2.4.1.] Onsite laboratory results will be expressed in wet weight equivalence. Verbal results will be provided to the Field Activities Manager within 24 hours of sample receipt. The 2-foot samples will be retained for additional analysis, if necessary. [EPA: Same comment as for the sinkhole investigation (Section 2.4.2)] 3.0 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 numbers will maintained in the sampling logbook by the Field Activity Manager. Each sample number will consist of two components which are described below. Each sample will have a two digit project identification code (identifying 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 described 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 a controlled 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 Health and safety issues The field logbook will consist of a bound notebook with consecutively numbered pages that cannot be removed. The logbook cover will indicate the following: Project name Field Activity Manager's name Sequential book number Project start 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 stricken 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: Summaries 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 logbook 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. 4.0 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 Guidance for Obtaining Contaminant-Free Sample Containers, April 1990. Bottles used for the sampling activity will no contain target organic or inorganic contaminants exceeding the level specified in the above mentioned document. Specifications for the bottles will be verified by checking the supplier's certified 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 etc. 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 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 summarizes 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. 5.0 Sample Handling, Packaging, and Shipment Sample handling, packaging, and shipping procedures are described in field procedure t P-12 of the QAPi P. 6.0 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 for TSP, methanol, and water, plastic bags and sheets Department of Transportation (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 decontamination procedures will be performed by site personnel after completion of tasks whenever the potential for contamination exists when leaving the contaminated 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 entire 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 following 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 and allow to air dry. All other sampling equipment will be decontaminated between sampling locations by the following procedures: 1. Wash contaminated equipment contact surfaces 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 locations, (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 specified in Section 10 of the FSP. 6.4 Drill Rig and Equipment Decontamination The drill rig and drilling equipment, such as augers and drill rig, 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 pressurized steam cleaner. 7.0 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. Horizontal control will be established at the site to within 0.l foot, and vertical control to within 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 procedures 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 with 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 generally 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 container. Large pebbles and cobbles should be excluded from samples taken for chemical analysis. 7.3.2.2 Han-augured Sampling Methods: 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 crossbar 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 sample. 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. 8.0 Field Measurements and Screening Standard operating procedures (HNu and OVA) for the field measurement and screening technique are provided in field procedure FP-20. 9.0 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. 10.0 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 [EPA: Drill cuttings may be replaced with the borehole. Grouting of the bottom of the borehole may be required to prevent waste materials from being introduced below the current waste level. Suitable containers for storage of drill cuttings should be anticipated, however, in the event that not all of the waste material can be returned to the borehole. More specific protocol concerning grouting and containers will be provided at a later time.] 10.3 Management of Hazardous Investigation derived 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)

| The Cast | The Tragedy | The Comedy | The Ending | News | Library | Seating Plan | Top | Home |

CALL (812) 333-8888 FOR MORE INFORMATION OR E-MAIL info@copa.org

The Coaltion Opposed to PCB Ash in Monroe County, Inc. is a nonprofit organization. 205 N. College Ave. - Ste. 713 - P.O. Box 665 - Bloomington, IN 47402-0665 USA Voice: +1.812.333.8888 - Fax: +1.812.332.8511 - BBS: +1.812.333.8822 For more info, e-mail info@copa.org. Please send site input to webmaster@copa.org. Copyright © 1990-98 COPA, Inc. All rights reserved. See legal page for terms of use and disclaimers. All trademarks belong to their respective owners. Subscribe to the COPA Mailing List and stay informed on PCBs.