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Russell w. Bartley, P.E. TRC Environl"'ental Consultants 800 Connecticut Blvd. East Jfartford, CT OHOR

near Russell: l> 0

EPA has received the •pre-design Workplan and Project Operation 3

Plan• for Beacon Heights. EPA has reviewed the plan and would Zl'l~"' ~]>

Hke to incorporate the following comments and additions before <1'0 -<0approval can be given. :oz l>

Gene.ral Comments ""'" ~"' <~

1. A greater emphasis should be placed on defining the boundries ,"'" :J:...of the landfill. Additional hand auger locations, test pits, and seismic profiles could be used to define the areal extent n "'"' 0 of the waste.

0 "' 2. The evaluation and design of the leachate collection sy1te111

will require an understanding of the bedrock surface and water table. To better define these, an additional borehole should be located to the south of the landfill betveen CP-1 and A-10. Also, 11onitoring welll should be installed in all boreholes to identify the water table and the vertical extent of the leachate. To acc011plish this all Jlonltoring wells should be sanapled.

Groundwater /Geotechnical comments

3. section 3.0. Clarify whether 3 total leachate umplea are to be analyzed or whether this refers to 3 locations with numerous samples ta!ten from each. Rec0111mend that numerous samples be gathered from these locations for analysis throughout the period of the pre-design study. This will be required in order to determine if wide variations in contaminants or concentrations occur over this ti•e frame. These variations, if they exist, may be required for design of the leachate treatment system.

4. section 3.0. verify what pilot or bench scale studies will be required and performed on the selected leachate treatJtent scheme prior to actual design.

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5. Sect ion 3.1.1. Test pit sampling should occur every 3 feet anrl at major stratigraphic and compositional changes ,

li, section 3.1.2. All boreholes should he monitoring wells,

1. Section ),},), !=ieismic survey should be developed to def ine the extent of waste and the bedrock surface. 200 to 400 foot profiles should be considered perpendicular to the estimated exte nt of the waste.

8 . Sec tion J.l.S. The number of seep samples nems limited compared to the number of seeps historically identified . Flex ibility should be incl uded to sample additional seePs if encountered during field investigations,

9. Section 3.1.1\, Groundwater sampling should also occur to help define if leachate has b@en introduced into the ground­wa .:e r , This will help define the vertical extent of the leachate collection system.

10. Section 3.1.7. Concern is expressed over the ability to hand auger into the material at Beacon Heights. seie•ic ahould 'be used to support this effort.

11. Sectio~ 3.2.1. Groundwater samples should be analynd for organics.

12. Section 3.2.3. Permeability testing of the cap •ateriah should include lab packed aamplea and field patch •••plea. Mended aoi 1 samples should be analyzed for a range of percent COftlllercial clay additiona. Final teating of per11eabili ty should include field testing ua.t.ng a double ring infiltrometer.

13. Section 3 .2. 3. Geotechnical testing should include estimation of slope stability. •

14. Section 3.2.3. Alternative cap materials ahoul'd be analyzed and considered.

15. Section 3.2.4. Method 5020 should be conaidered as the beat · 11ethod to extract the sample from the aoil.

16. Section 3.2.4. Screening the auger aa)!lplea should occur usi ng a head apace analysis using ei ther an OVA or a field GC.

17 . section 3.3. The cap evaluation should also include alope stability and settlement problems.

18. section 3 . 3 . 2 . Evalua t ion of borrow J!laterial should include an estimation of volume available.

19. Section 3.4. Special concern should be given to defining the necessary depth of the leachate collection system.

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20. section 4.1. Chemical analysis of soil samples is described as not being the pril"'ary mei!lnS of defining the exte nt of contamination. Whtit will be the primary means? Recommend that chemical analyais and visual inspection be the primary 111eans of ide ntifying landfill areas.

21. Section 4.1.1. Test boring should be cored at least 5 feet into the bedrock.

22. Section 4 .1.3 . Specify how deep hand augered holes will be dug and at what depth soil samples will be taken.

23 . Section 4.1.5.2. The use of ASTM n 2434 for the permeilbility of drainage materials is acceptable but is not acceptable for dete rmining the permeab ility of cap materiala due to the lower. hydraulic conductivity range. A triaxial permeability t est should be used as suggested by the US Army CORPS in Brown Book, EM 1110-2-1901).

24. ·Monitoring well screen length should be approximately 10 feet and located at the water table such that the screen will i ntercept the water table during seasonal flucuations. Ground seal should extend below frost zone which is 3 feet below the land surface. ·

oual i ty Assurance Comments

25 . General. All samples except al!lbient air •ust be analyzed "V by the llethods described in SW-84.6, third edition. 40 CFR

136 Methods can only be used for those analytes which are not included in SW-846's methods.

26. General. In addition to the quality control procedures in each .analytical method, the quality control procedures described in chapter one, SW-846, third edition must be performed and reported with the data set.

21. General. Include the laboratory policy for rejecting samples that were not properly cooled or preserved.

2f'. section 4.3. 2 . Acetone or methanol can only be used to decontam i nate the sampling equ i pment if they are not one of the interested analytes .

29. section 6.0. The Project Manager/QA coordinator needs to be identified .

30. Section 6.2.2. Change the following sentence fro111 •eenerally, ten percent of the samples gathered... will be duplicates to evaluate field precision• to •Ten percent of the samples or one sample whichever is greater gathered ••• will be duplicates to evaluate field precision.

-·­31. Sectio n 3.2.2. Add: The dup l icate samples . whic h will be

picked at random must contain the a na l ytes of interest.

32 . Secti on 6.4 . The person who validates the data needs to be ident i fied.

33 . Sectio n 6.6. At least one AUdit should be conducted hy Canonie personnel who are not connected to the project plan heing fol lowed.

34 . Section 6 . 1i . l . System aud i ting cannot occur as sta t ed if Project Manager a nd Oil. Coordi nator are the s ame penon,

:t>35 . Section 6.6.4. Change: •oA audit !!.!1_ be p repared• t o 0

•oA audit .!!.ll. be pr epared•, ~!D :r Zl'l ~:t>36. Table e. De fin e composi t e. <1>0 -40 ;oz

Ai r Mon itori ng Commen ts :t> -<:t ~"' <~

37. Section 3 . 1.4 Ambi ent air monitoring being conducted at "'" :t :0-4the perir~eter of the site for identifyinq if organic

contiminants are migrating off-site and for eltabliahing "'"' n ba.se:Une conditions should not only focus on identifying

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and quantifying benzene, but also the other prbary 0

contaminants identified during the RI. Section 5.1 . 2 Chemical Hazards, pages 3, c, and 5 of 17 identTlithe primary contam1nant1 present at the site. All but benzoic acid should be considered for ambient air uapling and analyses. Furthermore, benzene is not the only contaainant for which Connecticut has established a hazard li•it value .

38. Section 3.1.4 Considering an ambient air baseline study is to be conducted at the perimeter of the site where low levels (micrograms per cubic meter) will probably be encountered, recommend using more sensitive aa111pling and analytical techniques than those specified by :nosH. Recommend utiliz i ng methods T-01 for primary contaminants benze ne, ch l or o be nzene, ethyl benze ne, C-llethyl-2-pentanone, toluene , and bia( 2-chloroethyl) ether and method T-02 for 2-butanone, 1, 2-d i chloroethane, and chloroethane aa descr i bed in the Com end i um of Methods for the Deteraination

.o f Toxic Org a nic Compoun s n Am e nt A r, EPA- 600 C-BC-OU, Sep t ember 1986 . This woul d r equire the use of both Tenax and c a rbon molecula r s ieve ad s o r ben t tubes at e ac h of t he f our sampling l ocations . Duplicate sa111ples , back-up car t ridges, and bla nks would still have t o be fi g ured i nto the sampling plan.

39. Section 3.l.C EPA Test Method IV-7 should be corrected to IV-6 •sampling for Volatile Organics in Ambient Air Using Solid sorbe nts.• The document Characterization of Hazardous Waste Sites - A Method Manual, volume II Available sampling Mitii'Ods in wh1ch this method appears needs to be referenced. ~ethod IV-6 does point out useful calibration and sampling procedures, it is not an all-i nclusive sampling Jnethod.

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It should be usett in conjunction with methods T0-1 and T0-2 . Hethods T0-1 and T0-2 discuss specific sampling techn iq ues, analytical procedures, and appropriate QA/QC procedures.

• 40. Section 3.1.4 nuring a site visit on July 1, 1987, five vent pipes were observed on top of the landfill, recommend saMpling all these vents rather than focusing on just the three vents as described on the top of page 5 of 18 and nn Figure 3.

U. Section 3.1.4 Reference the EPA test methods presented on page 5 of 19. See comment 39. •

The following changes in text need to be fllade s

EPA Test Method IV 10 - Monitoring Gas and vapors from Wells

EPA Test ·Hethod IV 9 - Monitoring Gas and Vapors 'from Test Hole

EPA Test Method lV 6 - Sampling for Volatile Organics in Ambient Air Using Solid SOrbents

• EPA Test Method IV 5 - Stain Protector Tube Method for Sampling Gaseous Compounds

42. section 3.2.2 Again, referring back to c011•ent 40, aore than two sa111ples of landfill gases should be collected frOftl vents. At least one aa11ple fr011 each of the five vent pipes should be collected and analyzed along with duplicates, blanks , and backup cartridges.

43. Section 3.2.2 Unlike ambient air 11onitoring where low levels in the Micr09ram per cubic meter range are typically detected, landfill gases from vents tend to have •uch higher levels in the rdlligrama per cubic 1teter range. Therefore NIOSH sampling and analytical methodologies would be su i table for this aampling scenario. However, because NIOSH methods are compound specific or specific to groups of compounds, a singular method would not be cond!,!Ctive to the compounds of interest specified in com•ent 38. A de tailed sampling and analytical plan specific to then compounds of interest should be submitted for revi e w. The proposal to collect gas samples using Tenax is fine for certain compounds but not necessarily a good choice for all the compounds identified at this site. Purther•ore, Tenax needs to be thermally desorbed not cheWiically desorbed using disulfide prior to GC/MS analysis as is the case with the NIOSH methods.

u. Section 3.2.2 As stated on page 11 of 18, the four perhaeter air samples obtained with charcoal tubes will be analyzed for benzene for a one-day reading 1 refer to comments 37, 38, and 39. Also, analyses will be performed so as to conform

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with NIOSH method 5311 (nethod 5311 for your informaiton has been revi sed to methods 1500 and 1501 in the NIOSH Hanu&l of Analytical Uethods, third edition , February 1984) . Analyses shoul~ be performed in accordance with the Me thods specified in methods T0-1 and T0-2, refer to comflle nt lR and 39.

45 . Section 4.4.1 There are other contaminants known to exist at the site besides benzene, refer to comment 38. The

. State of Connecticut has established 8-hour HLV'a for some of the other primary contaminants identified at the site besides benzene.

~ 346. Section 4.4.1 Recommend an 8-hour time weighted average HIIl

concentration for the compounds identified in comment 38 Zf'l H])

be determi ned at each of the four perbleter sampling locations V>n for establishing ambient air quality baseline da ta and :oz

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for comparison to Connecticut • a HLV's. ])

Hf'l ""'"' < H run duri ng the 8-hou r sampling eve nt to document wind "' "' speed, wind direction, ambie nt tempera tur e, at111ospheric :0 "' -i

pressure, and relative hunid i ty. This i nformation is "'"' n necessa ry for air quality data interpretation, particularly 0

:0 wind direct i on for determin i ng which sa111pling locations 0

were upwind for background data and downwind for a1seeeing emissions migrating off-site . Meteorological infor•ation should be documented for any type of air 1110nitoring study conducted at the site.

47. section 4.4.1 A continuous meteorological s ys t HI must be

48. section 4.4 . 1 'Recoau~end that the baseline air study and vent sampling be conducted during a period when • • bient te•peratures are at least above 6s•r, at1110spheric press ure is low, wind speeds are ae asurably low, and not during periods . of precipitation or high relative humidity. 'l'he pur pose is to have conditions wh ich will increase the chances of collect i ng worse case data by 111uimizi ng off gasing from la nd fill a nd decreasi ng rapid dispersion and mixing of pollutant s .

49. section 4.1.1 Recomme nd referring to Methods '1'01 and T02 for establishing a flow rate wh ich conforms to an 8-hour sampling event and satisfies the requirements of these

· methods. With the proposed flow rate of 100 cc/min, a sample time of 8-hours, t he sample volu11e calculates out to be approximately 48 liters, too high for vent sampling and even for a baseline ambient study. A backup cartridge ia an excellent idea for determining breakthrough.

so. section 4.1.1 DOcument the laboratories ability to perfon air analysis on Tenax and carbon molecular sieve adsorbent tubes by supplying percent recovery data as well as preci­sion and accuracy data for the primary compounds at the site and others which are routinely analyzed. Provide laboratories standard operating procedures for sample tube preparation and analysis. Prior to the field study, sampling

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tubes and adsorbent material must be tho r oughly cleaned and screened down to a mininul'l detectable 1 imi t which conforms to a level" which meets the needs of the 'air study (refer to comment 38),

' '51. Sect ion 4, 4. 2 The purpose of vent sampling should not only identify gases being produced by the landfill, but also determine the concentration of these '.gasea .

52. Sect ion 4. 4. 2 lnd icate the number and frequency of gas detection tube samples to be collected at each vent for carbon dioxide, carbon monoxide, and 111et hane .

53 . Section 4.4.2 Indicate the number a nd freq ue nc y of COJIIbua­tible gas meter r e adings tha t wil l be obta i ned from e ac h ve nt .

54. Sec t i o n 4.4.2 For additional comments regard i ng vent a ampling a nd t esting fo r volati le orga n ics , r efe r to comment s U, ·c2 ., C3, CS, U, CA, and 50 .

55. ,!;ect i on 7 , 5. Inc lude ana lyt i cal me thods and procedures for air analyses. Appendix c should also include detection limi ts for air a.nalyses reported by canonie.

Por questions regarding these co11111ents, please contact •e at (617) 573-9663. Specific questions regarding Quality Aaaurance (It••• 25-36) can be taken by Charlea Porfert at Ul7) 860-4300. Specific queations regarding Air Monitoring (Ite•• 37-55) can be taken by Peter "Kahn at (617) 860-B92. Plene address all written vdtten r e sponaes to me.

since rely 1

1--;. ,; I I A/1. ~ (/)~. 1.-t. t. h .ft ... . I~ Karl W. NOvak, P.E . Proj ec t Manager

Olive r Wesley, Canonie Charles Porfert, EPA Region 1 Peter Kahn, EPA Region 1 Margaret Leshen, EPA Region 1 John Zannos, EPA Region 1 Richard Pease 1 Connecticut DEP