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Library: Comments: Hailer | |||||||||||||||
Environmental Geochemistry Joseph G. Hailer November 22, 1996 Mr. Michael Baker Mike: I have looked over the documents sent to me over the Internet and in the mail from Mitch Rice. I have not concentrated on the details of the sampling plan. Too many larger issues are apparent in what is planned. I have tried to summarize them as succinctly as possible, but they are the recurring issues surrounding waste location in a karst environment and the resistance of the investigators to adequately address the real problem. Much of what is being done qualifies as window-dressing. It gives the appearance of energy and effort being applied to a problem, yet is little more than marching in place. Work being done, but little forward progress. Issues of Concern - Lemon Lane Sampling Plan 1. Study Objectives - The overall objectives of the investigation do not appear to be suitable to meet the intent of a remedial investigation. A remedy (containment) has been selected despite that the intent of an RI is to characterize the extent and degree of contamination. Nothing in the plan addresses the containment issue and yet the analyses, for example, for TCLP, focus on regulatory requirements surrounding removal of the waste and disposal in a RCRA hazardous waste landfill. Investigation for containment would focus on location of contamination and routes of its escape off-site. 2. Sampling Points - The selection of sampling points does not appear to support study objectives addressing either containment, or understanding the extent of contamination. Sampling will duplicate previous investigations of "hotspots". By duplicating previous work and staying away from relatively unknown areas, this effort avoids producing new evidence of contamination. Little new information will be collected. 3. Compositing - The homogenization of samples from multiple locations is inconsistent with accumulation of data indicating the levels and distribution of contamination. Compositing always reduces the maximum levels from an individual point by dilution with less contaminated materials. Additionally, the resulting lower average value is then applied to a larger volume of material than the result for the individual sample. AHotspots@ get damped out. This reduces the information on contaminant distribution. The resulting effect is to decrease the perceived level of a hazard, but it does not reduce the reality. 4. Addressing Containment - Controlling the impact of a hazardous waste by containment requires an understanding of the location of the contamination and the potential routes of off-site movement. The sampling plan, as noted above, does not increase our information on the distribution of contamination, and does not address escape pathways. Our awareness of the complexity of ground water flow inherent to the location of the Lemon Lane landfill in a karst sinkhole was reinforced by the dye trace studies. A study focusing on containment should be collecting information on the water flow and contaminant transport pathways. This would include sediment-sorbed and dissolved loads of contamination under all levels of flow conditions at the springs and streams around the site. For a sinkhole at the apex of a structural dome with radial flow paths, every surrounding spring is a potential escape route. The need for a water budget study for the site is even more relevant if the containment approach is seriously considered. Note: There is a paragraph in the original sampling plan that begins AThere have been no borings performed in this area.@ The paragraph addresses the critical issue of escape pathways investigation rather than site sampling as the direction to go. This paragraph is loaded with critical points including the inadvisability of working on the landfill because of possible cap damage. It is worth reviewing. 5. Field Analyses - The use of field screening is very poorly explained. Although the usability of the immunoassay kit for PCBs has improved significantly over the years, some deficiencies in its use and quality of results are known. First, calibration is essential, yet was not discussed. It is important to use the same PCB mix for calibration as expected in the field. Second, the type and degree of interferences to be encountered can distort the results. Soil moisture and carbon content affect both field and laboratory analyses. The chaos of waste material in a landfill makes field analyses extremely unreliable. This requires targeted selection of sampling points at close intervals in the cores. Additionally, laboratory confirmation of both high and low field results allows a transferred calibration from the more reliable laboratory method to the less-expensive field data. 6. Vertical Sampling - The coring and selection of samples at pre-selected depths is a statistically random sampling procedure referred to as "stratified". It is applicable when there is indication that some vertical stratification makes the occurrence of contamination more likely to occur at a particular layer or level. Within that layer sampling points are selected randomly. The horizontally targeted sampling planned for Lemon Lane overrides the conceptual basis for a random sampling program. Drilling will be at targeted or "hotspot" points. What is seen in the cores should similarly target vertical sampling. By sampling at pre-set depths, the study increases the probability of missing significant concentrations of contamination. Again, this approach gives the appearance of gathering information, but it actually obscures the potential for obtaining valuable data. 7. Karst Water Flow - Although it is apparent that wells in the area do not show contamination (and this is frequently cited), this situation is to be expected from the flow conditions in karst. While it is usually true that water flows down-gradient in the subsurface, in karst it is more complicated. So much so, that flow violates the usual rules of movement in "normal" subsurface materials by flowing in subsurface channels or conduits. The conduit flow of karst is rapid and complex. The conduit flow resulting from solution of the limestone is more similar to that of pipes than to the slow, diffuse seeping of ground water through the pores and interstices between the mineral grains of most aquifers. The complexity of the conduits can be extreme. As already observed in the dye tracer work at Lemon Lane, depending on the magnitude of precipitation, flow will move in different directions as the system is filled internally. How water moves through the system is not a simple function of the apparent gradient based on the contact point on the ground surface along a smooth, predictable subsurface flowpath. The conduits are more often like cooked spaghetti. Inlets and outlets interconnect and twist. Sampling at Lemon Lane does not address the contaminant escape routes. 8. Electromagnetic Survey - The application of this type of geophysical technique to delineate sampling points for PCB contamination suggests a misunderstanding of the technique. Electromagnetic surveys for hazardous waste detection are best when the detectable metallic component in the waste is either massive, or close to the surface, and only detectable when the matrix surrounding the source is non-magnetic. The PCB capacitor casings were often removed from the waste during scavenging. The remnant casings are relatively small in mass (and, only weakly magnetic). They are buried to some depths (and, the landfill itself has additional cover added to prevent infiltration). The landfill also contains huge quantities of metallic debris including food cans and industrial waste from local electronics and metal fabricators. Running this survey gives the impression that something potentially useful is underway, but little of practical benefit is likely to result. I recommend that we review the cited USEPA documents supporting municipal landfill containment. I believe that they will not support the developing plan to contain the hazardous material in place. Hazardous waste landfills in karst are unlikely to be allowed by Indiana regulations. I would like to review the data gathered in this effort for quality and relevance to site issues. I would also recommend sending the water and sediment sampling plan and data. It is that work that is more crucial to understanding contamination at Lemon Lane in terms of release and impact on human health and the environment. If you have any additional questions, please contact me at 210-633-1308 or at 210-348-9366. Sincerely, |
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