DATA REVIEW RE: EPA RI TECHNICAL REPORT 07/08/1987feO "000004 DATA REVIEW RE: U.S. EPA Rl TECHNICAL...
Transcript of DATA REVIEW RE: EPA RI TECHNICAL REPORT 07/08/1987feO "000004 DATA REVIEW RE: U.S. EPA Rl TECHNICAL...
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DATA REVIEW
RE: U.S. EPA Rl TECHNICAL REPORTJuly 8, 1987
O&H Landfill,Uttea Michigan
EPA Region 5 Records Ctr.
PRINTED ON
AUG 2 9 1987
Consulting Engineers
CONESTOGA-ROVERS & ASSOCIATES LIMITED651 Colby Drive.Waterloo. Ontario. Canada N2V 1C2(519)884-0510
August 27, 1987 Reference No. 1989
Ms. Joan CalabreseUnited States EnvironmentalProtection AgencyRegion V230 South Dearborn StreetChicago, Illinois60604
Dear Ms. Calabrese:
Re: G & H Sanitary Landfill_ RI Technical Report _
Conestoga-Rovers & Associates (CRA), on behalf of Ford, Chryslerand TRW, has reviewed the RI Technical Report, G & H Landfill,Utica, Michigan, July 8, 1987. As a result of that review and ourreview of previous reports and technical memorandums relative tothe Site, CRA has identified several additional data gaps, notidentified in the RI Technical Report and three items of specificconcern .
The data gaps and suggested supplemental work plan tasks aredescribed in the attached report entitled, "Data Review re:USEPA RI Technical Report - July 8, 1987". We request that boththis letter and the accompanying report be included in theAdministrative Record for the G & H Landfill.
Items of specific concern are identified in the followingenumerated paragraphs.
1. Of particular concern is the apparent lack of substantiatedevidence to link the disposal of oil in Oil Pond No. 1 to theseepage of oil from the embankment south of the railroadright-of-way. This lack of substantiated evidence isillustrated by the following contradicting points of technicaldata :
a) The chemical fingerprint of oil from the Oil Pond No. 1area does not match the chemical fingerprint of oilsamples from the seepage area.
b) The absence of a continuous oil plume from Oil Pond No. 1to the seepage face as demonstrated by the absence of oilin test pits TP1, TP16A, TP17 and TP25 is inconsistentwith oil seepage originating from Oil Pond No. 1 .
cont inued ....
August 27, 1987 Reference No. 1989
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c) The presence of oil substantially above the elevation ofthe water table and above the operating elevation of OilPond No. 1 in test pits TP14, TP22, TP29, TP31, TP32 andTP34 can not be accounted for by migration of oil fromPond No. 1 and suggests multiple oil sources.
d) Test pits TP32 and TP34 have been reported on page 32 ofthe RI Technical Report to define a second oil source.A third oil source may be defined by TP14.
e) The original reporting of oil seepaae is inconsistentwith travel times expected on the basis of averagegradients and permeabilities.
2. Figure 2 of the RI Technical Memorandum describes OilPond No. 1 as extending too far eastward. The eastwardextension overlaps an area previously known as a solvent pitthat should be separately identified. Test pits TP18, TP21and TP23 may have been completed in the former solvent pit asindicated by drum remnants and strong paint odors reported onthe test pit logs and by the photography obtained fromMichigan Department of Natural Resources (Attached).
3. There is no acknowledgement in the report of the large numberof QA flags in the analytical data. QA flags, particularly onlow concentrations reported in the data, should beacknowledged in the data interpretation especially when morethan one interpretation of the data can be made.
It is necessary that all of the identified data gaps at this sitebe addressed to produce a complete Remedial Investigation thataccurately defines site conditions. A complete RemedialInvestigation will permit the most effective Feasibility Studyevaluation of alternatives and generate confidence in the mostefficient site remedy.
We look forward to receipt and review of a Work Plan detailing thedata collection programs.
cont inued
August 27, 1987
CONESTOGA-ROVERS & ASSOCIATES LIMITEDConsulting Engineers
Reference No. 1989
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We would be very pleased to discuss any of the identified datadeficiencies with you and your staff at your convenience. We willbe contacting you on September 15, 1987 to arrange a technicalmeeting. In the interim please do not hesitate to contact us withany questions that may arise.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES
Alan W. Van Norman, P. Eng.
AVN/mmEncl.
MACOMB COUNTY
Photograph ol Solvent. Pit (Designated as "4" on the previous map)
DATA REVIEW
RE: U.8. EPA RI TECHNICAL REPORTJuly B, 1987
G&H Landfill,Utksa Michigan
August 1987R«f. No. 1989 CONESTOQA-ROVERS ft ASSOCIATES
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
2.0 DATA DEFICIENCIES 2
2.1 IMMISCIBLE OIL PLUME 2
2.1.1 Supplemental Work Plan Tasks 3
2.2 GROUNDWATER CHEMISTRY AND HYDRAULICS 4
2.2.1 Supplemental Work Plan Tasks 4
2.3 GROUNDWATER MOUND WITHIN WASTE AND
GROUNDWATER QUALITY EAST OF G & H 6
2.3.1 Supplemental Work Plan Task 7
2.4 OIL POND 2 8
2.4.1 Work Plan Task . 9
2.5 CHARACTERIZATION OF COVER SOIL 9
2.5.1 Supplementary Work Plan Task 10
2.6 CHEMICAL SOURCES 12
3.0 SUMMARY OF DATA DEFICIENCIES 13
LIST OF FIGURES
F o 11ow i n gPage
FIGURE 2.1 DEFINITION OF OIL DISTRIBUTION
BOREHOLE LOCATIONS
FIGURE 2.2 PROPOSED SURFACE WATER
ELEVATION MONITORING STATION
FIGURE 2.3 DEFINITION OF GROUNDWATER MOUND
1.0 INTRODUCTION
The United States Environmental Protection
Agency (USEPA) has released for review a report entitled "RI
Technical Report G & H Landfill, Utica, Michigan" dated July
8, 1987. The report, consisting of four separate volumes,
describes the remedial investigation conducted at the Site
since 1983. Data collected and interpretations made with.
respect to environmental contaminant releases are presented.
Conestoga-Rovers & Associates (CRA) and Wang
Engineering, Inc. has reviewed the P.I Technical Report. As a
result of that review CRA has identified several areas where
alternate postulations can be advanced from the existing data
base. In order to ensure that the Feasibility Study is most
effectively completed and the most appropriate remedy is
ultimately implemented it is necessary to evaluate the
alternative postulations to a single accurate description of
existing conditions.
To complete the RI, CRA recommends the
collection of additional data. A brief explanation of why
additional data is required to clarify data interpretation
and a suggested plan to collect that data is presented in
Section 2 of this report. The description is followed by a
recommendation for additional data to be collected.
2.0 DATA DEFICIENCIES
2.1 IMMISCIBLE OIL PLUME
Chapter 7 of the RI Technical Report advances
the hypothesis that there is a continuous immiscible oil
plume originating at Oil Pond No. 1 and discharging to the
surface seeps south of the Conrail right-of-way. A second
plausible hypothesis at this point is that there is a second
source of oil between Oil Pond No. 1 and the seepage area.
This second hypothesis is advanced on page 37 of the RI
Technical Report by the description of oil in test pits 32
and 34.
The second hypothesis is supported by the
absence of oil reported in test pits 7, 16A, 17 and 25, all
of which are located between Oil Pond No. 1 and the seepaae
area. In addition oil was reported at elevations much higher
than the interpreted, practical operating level of Oil Pond
No. 1 in test pits 22, 29, 31 and 34. As the hypothesized
immiscible oil plume could not flow uphill, oil at the hioher
elevations suggests an alternate source.
It is to be noted that a third source of oil
may exist in the area around TP 14.
2.1.1 Supplemental Work Plan Tasks
Additional boreholes installed to five feet
below the water table should be installed at the locations
presented on Figure 2.1. The location of these boreholes has
been selected to determine whether oil is continuously
distributed between the Oil Pond No. .1 and the seepage face
and to determine the possibility of alternate oil disposal
locations. Boreholes should be sampled continuously. The
presence of oil should be determined by visual inspection and
recorded in the borehole log. From this visual record up to
a total of ten selected soil samples should be analyzed to
determine the PCB and VOC content in any oil encountered.
A series of boreholes north of and parallel
to the railway tracks should be installed to five feet below
the water table to investigate the possibility that oil in
the seepage area originated along the north side of the
tracks.
As indicated on Figure 2.1, seven of the
borehole locations should have monitoring wells installed.
The monitoring wells will be used to provide additional
hydraulic and groundwater quality data. These wells would be
included in the additional well sampling program proposed by
EPA .
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DEFINITION OF OIL DISTRIBUTIONBOREHOLE LOCATIONS
G£H Landfill
- I
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2.2 GROUNDWATER CHEMISTRY AND HYDRAULICS
Contaminant distribution in the upper sand
aquifer is expected to closely parallel groundwater flow.
The RI Technical Report advances the hypothesis that there is
a drainage divide north of the 23 Mile Road (p.13) and that
contaminants will "probably discharge to the Clinton River"
(p.98). While both of these hypotheses may be correct,
better definition of the details of the relationship between
upgradient groundwater, downgradient groundwater and surface
water would add an additional degree of reliability to the
understanding of groundwater flow and the potential extent of
future contaminant distribution.
2.2.1 Supplemental Work Plan Tasks
Surface water elevation monitoring stations
should be established at the locations presented on
Figure 2.2. A surface water monitoring location consist of
an iron bar installed at an accessible location within the
surface water feature. The top of the bar is surveyed to
establish a measuring point elevation which is used as a
reference point for surface water elevation measurements.
In order to provide a complete set of
concurrent groundwater and surface water elevations,
background wells GH14A, GH15A and GH15B, which were not
monitored during July/August 1986, should be re-established.
The GH14A well has a seized cap and the GH15 well nest has
been destroyed.
Attempts should be made to repair GH14A and
if unsuccessful, GH14A should be replaced. GH15A and GF.15B
should be replaced. Each of the present GH15 well nest wells
should be located, and properly abandoned.
The proposed second round of groundwater
Quality sampling should be supplemented with monitorina of
the repaired/replaced background wells and with concurrent
surface water quality samples at the locations presented on
Figure 2.2.
After the surface water elevation monitoring
stations are established, a complete set of concurrent
groundwater and surface water elevations should be measured.
These measurements would be used to assess the influence of
surface water features on groundwater flow direction and
velocity.
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f igure 22
PROPOSFO SURFACE WATER ELEVATIONMONITORING STATION
G £> H t and fill
2.3 GROUNDWATER MOUND WITHIN WASTE ANDGROUNDWATER QUALITY EAST OF THE SITE
The hypothesized groundwater mound is defined
by a single groundwater elevation in Well RL10. The size,
shape and the actual existence of this mound are not clearly
defined by the current data base. The bottom of the well
screen for Well RL10 is 2.7 feet above the expected
groundwater elevation at this point. In addition the change
in water level with time in this well is much less than the
change measured at other upper sand aguifer monitoring wells.
This well may be measuring a perched water table condition in
the waste. If actually present, the size and extent of this
mound should be better defined so that its local effect on
groundwater flow can be understood and related to potential
contaminant migration.
The RI Technical Report hypothesies that the
groundwater mound may explain the presence of groundwater
contamination reported in industrial and private water supply
wells east of the G & H Site. An alternate hypothesis is
that the groundwater contamination reported east of the Site
is a result of historic and current land use on those
properties.
To determine which hypothesis is correct and
what the source of contamination really is, CRA recommends
the additional data collection described in Section 2.3.1.
In addition and to the extent practicable,
the construction details of industrial wells installed along
Ryan Road east of the Site should be determined. The wells
that are properly constructed and can be accessed without
causing contamination or damage should then be surveyed and
groundwater elevations measured concurrently with on-site
groundwater elevation measurements. This data would better
define the potential for flow and contaminant migration
eastward from the site. Alternatively, monitoring wells
could be installed on private property east of the site to
obtain similar information.
2.3.1 Supplemental Work Plan Task
An additional shallow upper sand aquifer well
should be installed at the location near Well RL10 presented
on Figure 2.3. This location was chosen to evaluate if Well
RL10 is measuring a local perched groundwater condition.
The well would be completed to a depth of
approximately 20 feet so that the screen is installed in
native soils just below the base of waste at this location.
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figure 23
DEFINITION OF GROUNDWATER MOUNDG G H Landfill
It is expected that 1.5 feet of cover soil and approximately
13.0 feet of waste will be present at this location. The
location is selected to determine if a groundwater mound is
actually present. If the presence of the mound is confirmed
by the additional well, one other well should be installed
further east to provide additional definition of the size and
shape of the groundwater mound. The location of the second
well, if required, is also presented on Figure 2.3.
Soil borings for soil sample collection and
analysis should also be completed at each of the industrial
properties east of the Landfill to identify potential off
site sources .
CRA understands that a public water supply is
available to residents east of Ryan Road. It is recommended
that an investigation be undertaken to determine how many
connections have been made to the public water supply. In
addition, selected monitoring for groundwater elevation and
VOC should be completed in order to define the potential for
an alternate source of VOC contamination.
2.4 OIL POND 2
The RI Technical Report advances two
hypotheses about Oil Pond No. 2. The first, presented on
8
page 88 of the report suggests that there is little effect on
groundwater quality resulting from Oil Pond No. 2. The
second, presented on page 98 suggests that Oil Pond No. 2 is
a potential source area. Very little data is available to
support either hypothesis.
The summary of additional data needs
presented in the RI Technical Report includes additional
subsurface investigation near Oil Pond No. 2. However, to
determine which hypothesis most accurately describes existing
conditions CRA recommends the specific work task described in
Section 2.4.1 be completed.
2.4.1 Work Plan Task
Six additional test borings should be
drilled around Oil Pond No. 2 as indicated on Figure 2.1 in
order to determine the extent of any oil migration from the
pond. The boreholes will be sampled continuously. The
presence of oil will be determined visually and recorded on
the borehole log. Up to a total of six selected soil samples
should be analyzed to determine the PCB and VOC content in
any oil encountered. If borehole conditions are appropriate,
upto four of the boreholes should be converted into
monitoring wells to provide additional groundwater data.
Subsequently these wells would be included in proposed
monitoring programs for water quality and hydraulic
def init ion.
2.5 CHARACTERIZATION OF COVER SOIL
The physical characterization of cover soil
was not specifically addressed in the RI Technical Report.
Insufficient grain size distribution analysis
data is available for the cover soil materials which
currently cover the Site. The cover soil material properties
are required to more accurately estimate the effectiveness of
the cover in reducing infiltration. The properties of the
cover soil are most important around the perimeter of the
landfill where little or no additional fill is reauired to
produce topographic contours which promote drainage of
surface water. The grain size data may also be used to
determine the ability of the cover to support vegetation.
Collection of samples could be combined with determination of
cover soil thickness.
2.5.1 Supplementary Work Plan Task
Samples of the cover soil should be collected
at fifteen locations with the majority located around the
perimeter of the Site. Suggested locations are presented on
Figure 2.1. Samples should be collected from the surface or
10
near surface by a grab sampling method. A hand auger could
be used to uncover the sample and to determine cover soil
thickness at the sample location.
2.6 CHEMICAL SOURCES
The landfill can be studied and evaluated in
one of two ways:
1) A single Site with multiple poorly defined chemical
sources; and
2) Multiple chemical sources each of which adequately
defined.
The work proposed by EPA and amended herein
by recommendations for additional work, would allow for the
evaluation of remedial alternatives for specific on-site
chemical sources.
Furthermore, the additional data will allow
for the evaluation of environmental impact apportionment
between various sources. This data is required to ultimately
apportion costs for remedial work.
11
All of Which is Respectfully Submitted,
CONESTOGA-ROVERS & ASSOCIATES
Frank A. Rovers, P. Eng.
Alan W. Van Norman, P. Eng,
14