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Review of "Field Sampling Plan
for the Fill Material at Lemon
Lane Landfill," Westinghouse
Bloomington Project
Volume III, Amendment 1
21 August 1996
by Earth Tech
October 1, 1996
Dan Hopkins
U.S. EPA Region V
77 West Jackson Blvd. HSRC-6J
Chicago, IL 60604
The following comments are listed as per page, section, and line(s) within
each section.
4-1.0-1 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
to be considered as a landfill.
4-1.0-30 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.
4-1.0 last paragraph
Investigation of waste characteristics is not contrary to EPA guidance.
5-2.2.1-2 The map location of Exhibit 2-1 is not accurate.
5-2.1.1-3 The site covers 11.5 acres
4 CSXT Railroad on South, not L&N Railroad
5-2.1.2 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.
5-2.1.2.6 This sentence makes no sense. Are you trying to say "several
small to large size sinkholes are present in the immediate area"?
-7 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.
-9 Add: Some soil water associated with the bedrock surface and water in
solution enlarged joints and fractures also drains to the conduits.
5-2.1.3-1 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.
-4 The surface of the site ranges from 860 to 888 feet amsl, not 850 to
890.
-8 The upland surface of the Mitchell Plain is relatively flat and in part
charcterized by karst topography, but some surface streams are deeply entrenched.
6-2.1.3-1 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.
6-2.1.5-2 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".
-6 Rewrite to say "The open dumping operations were typical..."
-13 Rewrite to say "...(prior to partial removal to facilitate installation
of the interim cap)..."
6-2.1.6-3 The list of previous investigations is incomplete, so say "partial
list of previous investigations up to 1985."
6-2.1.6.1-5&6 The table in A-3 gives sample results from four locations,
not nine.
7-2.1.6.1-1to3 Units must be consistent with data on Table in Exhibit A4,
and, do not round off numbers.
7-2.1.6.1-8&9 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..."
-11 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.
-13 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.
7-2.1.6.2-3 Exhibit A-6 lacks a map showing locations of borings.
7-10 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?
7-2.1.6.3 Where and how many PID samples were taken: Need a location map
and table of results for PID samples.
7-2-1.6.4-1 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.
-7 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.
-8 Delete the word "ever" from "ever recorded", inasmuch
as it over states the case, try "recorded to date".
-9 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.
-10 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.
8-2.1.6.4-1 Replace "potentially impacted by" with "in the
vicinity of"...
-5 Rewrite to say "These springs were sampled as part of..."
-10 Not true-1,1,1,-trichlorethene, 1,2-transdichloroethylene, and trichlorofluoromethane
were found, see 1982 and 1983 EPA data.
8-2.1.6.6-5 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.
8-2.1.7-4 Westinghouse installed a fence around Illinois Central spring
in 1995.
9-2.1.8-1 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.
-4 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.
9-2.1.8-7 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.
-7to9 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.
-10 Not all visible surface capacitors were removed from the site in 1987
-13 Change to read "...are the only known open pathways..."
-15 What is "anedoctal" sampling? Delete the word.
-16 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.
9-2.2-3to5 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.
-8 Neither this plan by Westinghouse, nor any other scheme presented to
date, addresses stability or containment of wastes or solid in the sinkholes
-9 The site was an open dump, not a landfill
10-2.2-3 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)
-6 There are environmental receptors for the high amounts of PCBs exiting
Illinois Central Spring.
-7 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".
-11 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.
-14 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).
-16 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.
-18 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.
-21 There is less disagreement between the governmental parties regarding
sampling the wastes than there is between them and Westinghouse.
-22 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).
-27 Rewrite to say "modification also", not "to" (which
should be spelled "too")
-38 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.
-39 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.
11-2.2-1 20% of samples or one sample from each boring should be sent to
lab for confirmation PCB analyses.
11-2.2-3 What does "also" refer to? What else does limiting the
number of borings accomplishing other than damage the cap?
-7 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.
-9 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.
11-2.3-3 Rewrite first two sentences to say that the containment of concern
is PCBs.
11-2.4.1-1 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.
11-last line Results should be expressed on dry weight basis.
12-2.4.2-1 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 ...".
12-2.4.2-12 Composite samples should be for each 2-foot interval not 4-foor
intervals to be consistent with studies under section 2.4.1.
12-2.4.3-4 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 ...".
12-2.4.3-17 Composite samples should be for each 2-foot interval to be consistent
with studies under section 2.4.1.
13-3.1-5 The sample number should include the boring location number designation.
16-7.2-2 Rewrite to say "...Continuously split-spooned and sampled
as 2-foot increments for logging and ...".
-3 Rewrite to say "The borings will be advanced through the waste and
two feet into the underlying soil unless halted by refusal".
16-7.3.1-3 Not a sentence!
17-7.3.2.2-16 Say that sampling equipment "will" be decontaminated,
not "should" be.
FP-16
1-3.0-4 Change to read that "information must be ... and on the
sampling forms", not "should" and "in"
-8 Change to read "analytes must be", not "should" |
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