Indiana Department of Environmental
Management (IDEM) Comments on
the Westinghouse Field Sampling
Plan Lemon Land Landfill
Dottie Alke
Westinghouse Electric Corporation
Bloomington Project Gateway Center - MS 640
11 Stanwix Street
Pittsburgh, PA 15222-1384
October 17, 1996
Dear Ms. Alke:
Re: Draft Westinghouse Bloomington Project QAPjP Volume II Amendment
1 August 21, 1996 (Revised August 26, 1996)
The Indiana Department of Environmental Management (IDEM) staff have
completed their review of the Draft Westinghouse Bloomington Project QAPjP
Volume II Amendment 1 August 21, 1996 (Revised August 26, 1996).
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.
Specific Comments:
1. IDEM recommends that section one only include a brief site history
of the site and the objectives of the fill material sampling event.
a. Section 1, pages 4 and 5: paragraphs two, three, four, five, six,
eight, and nine are not appropriate for this plan.
b. Section 1, page 4, paragraph seven:
1) The second Sentence should be deleted. It is possible that the throats
of the landfill sink holes are being wetted during storm events contributing
to groundwater contamination.
2) Sentences three, four and five are not appropriate for this plan.
c. In paragraph ten, please include the title and date of the EPA conceptual
plan.
2. Section 2.1.2, page 5: The last paragraph needs to include a complete
description of the ground water flow. All springs that are associated with
this drainage area should be identified.
3. Section 2.1.3, page 6: Consider changing the first sentence to read,
"Drainage from the site and all adjacent areas is via sinkholes and
macropores to the karst solution features developed in the underlying bedrock."
4. Section 2.1.4, page 6:
a. Consider changing the third and fourth sentences to read, "Thirty-one
residential wells were sampled on a quarterly basis from September 1995
to June 1996 by Westinghouse and the U.S. EPA. Westinghouse samples were
analyzed for PCBs. The U.S. EPA sampled twenty-one residential wells for
analysis of inorganics (metals), volatile organic compounds (VOCs), semivolitile
organic compounds (SVOCs), pesticides/PCBs and Dioxins/Furans."
b. Consider including a summary of the U.S. EPA quarterly sample results.
5. The third paragraph of Section 2.1.6 (page 6) is not appropriate for
this plan.
6. Section 2.1.6.1, pages 6 and 7:
a. Consider changing the second paragraph to read:
"In June and July 1981, the U.S. EPA collected twelve soil samples
from seven locations with a sample depth range of surface to 5 feet (exhibit
A-3). PCBs were detected in the nine soil samples collected from four on-site
sample locations. In addition, one water and one sediment sample was collected
from Sargent's Pond."
This paragraph should also include a sentence that states fourteen samples
(12-soil, 1-sediment and 1-water) were analyzed for (?).
b. Exhibit A-3 Table should document all the sample results including
the off-site soil, water and sediment samples.
c. Please consult with the EPA regarding the text in the first Paragraph
on page 7 regarding the October 1984 sampling event.
* IDEM recommends this paragraph include text that explains how many
samples were collected from "x#" locations.
* The map included in Exhibit A-4 is difficult to read.
* This activity is not included on the Pre-CD Activities Table (Exhibit
A-1)
d. Paragraph 2, page 7: The March 11, 1987 EPA sampling event is not
included on either the Pre-CD or Post-CD Activities Tables (Exhibits A-1
and A-2).
The text and map included in Exhibit A-5 do not indicate where the background
sample was collected.
e. Paragraph 3, page 7: The early 1987 sampling conducted by the City
of Bloomington is not included on either the Pre-CD or Post-CD Activities
Tables (Exhibits A-1 and A-2).
7. Section 2.1.6.2, page 7:
a. The first sentence should read, "In March 1984, Westinghouse
drilled 3 borings in the landfill."
b. The last two sentences of paragraph one are confusing. Consider changing
them to read, "A total of eight samples were collected at depths ranging
from 4 to 32 feet. PCBs were detected at all three boring locations with
a concentration range of less than 1 to 22 ppm.
c. A map showing the March 1984, Westinghouse boring locations should
be included in Exhibit A-6.
d. The EPA November 1984 boring sampling event is not included on either
the Pre-Cd or Post-Cd Activities Tables (Exhibits A-1 and A-2).
* Consult with EPA regarding their November 1984 sample boring event.
Is it possible this boring event was part of the October 1984 EPA sampling
event?
* The Table included in Exhibit A-4 indicates composites were taken from
two landfill borings locations (samples 1339E-19 to 1339E-24). However,
the map included in Exhibit A-4 does not indicate the location for the two
borings.
* Should the map in Exhibit A-7 be included with Exhibit A-4?
* The sample results are not included in Exhibit A-7.
8. The Westinghouse April 1987 soil gas sampling event is not included
on either the Pre-CD or Post-CD Activities Tables (Exhibits A-1 and A-2).
9. Section 2.1.6.4 pages 7 and 8:
a. Consider changing the first paragraph to read:
"Twenty-two monitoring wells have been installed on the immediate
perimeter of the landfill. The Field Sampling Plan for the Lemon Lane Landfill
Groundwater Monitoring Investgation (Westinghouse 1995), included one year
of monthly sampling for PCBs from monitoring wells 4D, 4I, 6, 7 and 8D.
The monthly sampling, which was initiated in October 1995, has shown PCB
contamination in these monitoring wells to range from less than 0.1 ppb
to 1.4 ppb."
b. Please consider changing the first sentence of the second paragraph
to:
"As part of the Field Sampling Plan for the Lemon Lane Landfill
Groundwater Monitoring Investigation (Westinghouse 1995), eight monitoring
wells (4I, 4D, 5, 6, 7, 8S, 8D and 9) are also being continuously monitored
for water level and temperature."
c. Paragraph 3 (first paragraph on page 8):
* The first sentence does not include the dye tracer study conducted
in April 1988 which is listed on the Post-CD Table included in Exhibit A-2.
* The last sentence should read, "Some water does also travel to
the Slaughterhouse Spring system to the northwest during high flow events."
d. The accuracy of paragraph five should be confirmed. For example, the
IDEM water samples collected on March 22, 1995 detected antimony and cadmium
(MW-12), lead (MW-2) nad trichlorethene (Illinois Central Spring) in levels
that exceeded their respective maximum contaminant levels (MCLs) and a sediment
sample from Illinois Central Spring contained beryllium in a level that
exceeds the action level. EPA should be consulted regarding their quarterly
sample results.
10. Section 2.1.6.5, sentence 4, page 8:
* Exhibit 2-2 does now represent the EM date. The map does show proposed
EPA boring locations that were selected after analyzing aerial photos and
EM data.
* Please confirm with the EPA about the accuracy of the last sentence.
11. Section 2.1.7, paragraph 1, page 8: Please consider changing the
third sentence to read, "The 8-foot-high, locked chain-link fence with
barbed wire across the top, which was installed by the U.S. EPA, is maintained
by Westinghouse."
12. Section 2.1.8, paragraph 2, page 9:
a. Change the title of this section to, "Analysis of Site History,
Previous Site Sampling and Interim Remedial Measures."
b. The second sentence should read, "At this time, there are no
other known locations at the site that would classify as a hot spot for
PCBs based on documentation or physical evidence."
c. The sixth paragraph is not appropriate for this sampling plan.
13. Section 2.2, pages 9 to 11 are not acceptable. This section as it
is presently written has the tone of a Westinghouse "position paper"
which is not appropriate for this sampling plan.
* The title of this section should be changed to, "Sampling Plan
Objectives."
* This section should include only the objectives of the sampling plan.
* While the fill material may be above the water table, the landfill
material could still be receiving rainwater from the flooding which occurs
around MW-7 and along the eastern edge of the site. Information has not
been collected to confirm or deny the presence of perched water in the landfill
material.
* The interim cap should not be considered remediation of a hot spot
located in the southwest corner of the landfill.
* The parties have not discussed the locations or numbers of piezometers
needed. Standard operating procedure for the piezometer installation need
to be developed. IDEM recommends installing at least one piezometer per
sinkhole beneath the site.
* Exhibit 2-4 was not included in the draft plan IDEM received.
14. Section 2.3, page 11; Since the parties agreed to try to merge the
EPA and Westinghouse plans, this paragraph should be revised to include
other contaminants of concern (i.e. TCE).
15. Section 2.4.1, pages 11 and 12:
a. Since the parties agreed to try to merge the EPA and Westinghouse
plans, this section should include the additional borings and analysis that
will be conducted by EPA.
b. Westinghouse needs to explain why only intervals that have PCB screening
results in excess of 1000 ppm PCB will be selected for inclusion in the
RCRA characteristic waste samples. EPA guidance suggests that the principal
threats for PCB industrial sites has been generally set as material contaminated
at levels greater than 500 ppm.
c. Boring 20 is listed as being selected for the purpose of defining
the known hot spot and as an EM location boring (section 2.4.3).
16. Section 2.4.2, page 12:
a. Boring 14 has been selected for the purpose of the sinkhole location
and as an EM location boring. However, this is noted later in the last sentence
of paragraph two of section 2.4.3.
b. As discussed at the September 26, 1996 Bloomington technical meeting,
criteria need to be developed for when the retained 2-foot composite samples
will need to be analyzed.
17. Section 2.4.3, page 12:
a. The U.S. EPA electromagnetic survey is not listed on the Post-CD Activities
Table (Exhibit A-2).
b. As discussed at the September 26, 1996 Bloomington technical meeting,
criteria need to be developed for when the retained 2-foot composite samples
will need to be analyzed.
18. Section 6.1, page 15:
a. Number 5: Unless workers are going to be taking a shower before they
leave the work site, workers should wash their hands and face after their
inner gloves have been removed and discarded.
b. An additional step should be added that states, "Cleaning fluids,
spent solvents, washwater and disposable PPE will be contained until proper
disposal.
19. Section 6.2, page 15: An additional step should be added to the soil/sediment
sampling equipment subsection and all other sampling equipment subsection
that states, "Cleaning fluids, spent solvents, washwater and disposable
PPE will be contained until proper disposal.
20. Section 6.4, page 16: An additional step should be added that states,
"Cleaning fluids, spent solvents, washwater and disposable PPE will
be contained until proper disposal.
21. Section 7, pages 16 to 18: Please include a new subsection regarding
sampling procedures for water that may be found in the bottom of the boreholes
(i.e. at the soil/landfill interface). Standard operating procedures will
need to be developed.
22. Section 10.2, page 19: Because of the heterogeneous nature of the
fill material, additional sampling analysis other than PCBs may be required
in order to determine appropriate disposal.
23. Section 10.3, page 19:
a. Paragraph 1: The last sentence is not needed in this plan.
b. Paragraph 3: The second sentence is not needed in this plan.
24. Pre-CD Activities Chronology (Exhibit A-1) indicates that Westinghouse
conducted a dioxin sampling event. This sampling event is not included in
the text of section 2.1.6.1 and results of this event are not included in
this plan.
25. Post-CD Chronology (Exhibit A-2):
a. Listed date is not complete (i.e. 11/8) for the well user sampling
and analysis conducted by the City of Bloomington Utilities/Indiana University.
b. The 3/95 sampling of MW-2, MW-12 and Illinois Central Spring conducted
by IDEM is not listed.
c. The EPA 1995 quarterly groundwater sampling conducted by EPA are not
listed.
26. Site-Specific Health and Safety Plan, Revision 1 (August 20, 1996):
a. When a contractor is selected the contact names, employee sign off
pages and etc. will need to be provided
b. Page 1: Site address should be revised. Consider stating, "Refer
to site access, paragraph one."
c. Page 2: Site map with noted information needs to be provided.
d. Page 4, paragraph 3: Please change the second sentence to read, "The
site interim removal and remedial measures were completed in 1987."
e. Section 3.3, pages 8 to 10: The IDW drum sampling and disposal task
indicates there should be a footnote "a." However, the table does
not define "a."
f. Section 3.3, page 9: Consider including "Fire prevention and
control continued" in the first block of the "Hazard" column.
g. Section 3.7, page 14: The PIP (eV) indicates a footnote of "4."
Please confirm if the "4" should be changed to "d."
h. Section 6, page 18:
1) The Air Monitoring Specifications table indicates the action level
for the FID and PID is 4 ppm. However in the last paragraph it is stated
that if the concentration is above 5 ppm work will stop. This needs to be
corrected.
2) There is a footnote "5" in the PPE column for the Noise-Level
Monitor. Please confirm if the "5" should be changed to "d."
i. Page 21: HS-SOB 08 is referenced in the APR or SCBA step. This SOP
should be included in the plan.
j. Section 10.2, page 23: The second bullet refers to subsections 3.7
and 6.2. Subsection 6.2 was not included in this plan.
k. Section 11.7, page 26: A site map which includes evacuation routes
and assembly areas needs to be provided.
l. Section 12.1, page 27: Please consider including non-emergency phone
numbers in this section. It is possible using 911 on a cellular phone will
not connect you to the appropriate dispatcher.
27. QA Project Plan Revision 1 (August 26, 1996):
a. Section 3.2, page 2 of SEction 3: The first sentence refers to procedures
specified in Section 7.0. However there are two section 7s: 1) Field Sampling
Plan for the Fill Material at Lemon Lane, Section 7 is the procedures and
equipment for field surveys and sampling (page 16) and 2) QA Project Plan
(August 26, 1996) Section 7 is analytical procedures (page 1 of Section
7). It may help to locate the referenced Section 7 by including the name
of the plan. Consider creating a new volume number for the fill material
sampling QAPjP (i.e. Volume III).
b. Section 4, Table 4-1, page 3 of Section 4: Please review the attached
table which includes handwritten notes.
c. Appendix A-1, table of Contents: This should be named :VOLUME 1, APPENDIX
B."
d. FP-17, page 4 of 4: Section 9.1 appears to be incomplete.
e. FP-18, page 2 of 3, Section 8.2.6: The last sentence should read,
"In areas where an impermeable layer ("cap") has been installed
a neat cement/bentonite mixture shall be used to repair the cap."
f. FP-19, page 1 of 3, Section 3.0: While the test kits may have performed
adequately with soil as a matrix, there may be some difficulty calibrating
to the non-homogenous mixture of materials likely to be encountered in the
landfill. An addendum, which deals with the difficulties of sampling the
landfill materials should be added to the field procedure FP-19.
g. FP-20, page 2 of 3, Section 8.1, number 4: It is not a safe practice
to glance briefly into the end of the Hnu PID. The text for number 4 should
be changed. As noted in number FP-20, Section 8.2, number 4, The Hnu PID
can be quickly checked for operability by holding a felt tip pen adjacent
to the probe to induce a response in the deflection needle.
h. FP-20, page 3 of 3, Section 8.2, number 4: It is not a safe practice
to glance briefly into the end of the Hnu PID. The text for the first two
sentences of number 4 should be changed.
If you have any questions, please contact me at 317/308-3118.
Sincerely,
Resa L. Ramsey
Superfund Section Office of Environmental Response
Indiana Department of Environmental Management |
