Comments to Conceptual Sampling
Plan for Lemon Lane Site
The following comments are excerpted from COPA's comments to EPA regarding
the Conceptual Sampling Plan for Lemon Lane in which Immunoassay Test Kits
are proposed for rapid-turnaround PCB results in the field. The full text
can be found under the Lemon Lane Landfill heading, COPA information.
May, 1995
Environmental Compliance Organization (ECO), in its capacity as technical
advisor to Citizens Opposed to PCB Ash in Monroe County (COPA), has reviewed
a memorandum from Richard Flores of Earth Tech to Dan Hopkins of U.S. EPA,
dated April 11, 1995. The subject of the reviewed memorandum is the conceptual
sampling plan for the Lemon Lane site. After reviewing the memo and accompanying
documents ECO offers the following comments:
...Of additional concern is the proposed field measurement of PCBs as
a threshold for further laboratory testing. While field screening can prove
an economical and rationale way of limiting samples sent on for costly analyses,
we cannot concur with the selected threshold of 400 ppm. PCB contamination
at 400 ppm is well above all regulatory action levels, and also exceeds
levels generally considered to negatively impact both human health and the
environment. ECO is uncomfortable with the lack of detail concerning who
will actually be performing the field tests, and more importantly the crucial
review and determination of results. Additionally, given the uncertainties
and inaccuracies inherent to all field screening methodologies, it would
seem more prudent to rely on mobile laboratory analytics for accurate, but
time and cost efficient screening methods.
...Toward that end, ECO urges that all samples submitted for analyses
be tested for dioxin/furan utilizing the ultra-sensitive laboratory method
developed by, and available from Triangle Laboratories, located in the EPA
complex at Research Triangle Park, North Carolina. This extremely sensitive
testing is capable of detecting dioxins and furans in the parts per quadrillion
concentrations that represent the regulatory thresholds for these extremely
toxic substances.
...ECO firmly believes that all the foregoing comments must be considered
and incorporated into the planned sampling at Lemon Lane in order to produce
the quantity and quality of information that will further the eventual remediation
of this site. Our staff is available, upon request to further discuss these,
or any other issues related to the Bloomington PCB sites.
Additional Commentary
Melissa Valentin of MVA Consulting, Inc. has also reviewed the conceptual
plan and provided ECO with a memorandum detailing questions and concerns
regarding the planned field event. The information contained in that memorandum
is provided here in its entirety.
Field Screening
I encourage the use of immunoassay field test kits for PCBs. They provide
useful results quickly, and at a fraction of the cost of performing lab
analyses. But they can provide misleading results if not interpreted correctly,
and they have not been validated for use on landfill material.
According to ENSYS a test that is calibrated to detect 400 ppm of Aroclor
1254, will require 2,000 ppm of Aroclor 1242 or 4,000 ppm of Aroclor 1016
to trigger a positive result. Similarly, if the test is calibrated to detect
400 ppm of Aroclor 1016, Aroclor 1242 will test positive at 80 ppm and Aroclor
1254 will test positive at 40 ppm. Millipore provides conservative results
by calibrating the detection limit to the least sensitive Aroclors. The
calibration standard must be defined in the sampling plan. Further, any
sample that is visibly stained should be automatically sent to the laboratory
for analysis because more than 5% oil in the sample can produce unreliable
results. High moisture content also leads to under-reporting of the PCB
content of the sample, and samples with more than 20 - 30% moisture content
should be dewatered prior to testing. In addition, the herbicide divron
can cause false positives.
The PCB test kits for soil have been validated for soil, not landfill
material, and a validation work plan must be prepared. We request an opportunity
to review and comment on the test kit validation work plan. Neither ENSYS
nor Millipore were aware of applications of the PCB test kits to landfill
material. Millipore suggested that the test kits could be used as screening
tools in the field but that all results should be verified in the lab.
Test kits are available at custom-set detection limits, and more than
one detection limit can be used for a single sample. I recommend that a
two tiered screening be used: first 400 ppm (as proposed) to identity samples
with gross contamination, followed by 50 ppm for samples that pass the initial
screening. This will provide useful information regarding the extent of
PCB contamination in the landfill.
I also encourage the consideration of immunoassay test kits for dioxins.
ENSYS offers dioxin test kits for use in the laboratory: unlike the PCB
test kit where extraction and testing occurs in the field, the dioxin extraction
is performed in the laboratory using standard methods and then the immunoassay
test kit is applied. It can detect 2378-TCDD in the part per trillion to
parts per quadrillion range and costs only $ 120 per test. Millipore expects
to have a dioxin test kit on the market in 6 months. |
