NCD980602163_19961028_Warren County PCB Landfill_SERB C_Data Gaps in the PCB Landfill Documentation-OCR

To: Bill Meyer
From: Patrick Watters ~ W.
Date: l 0-28-96
Subject: DAT A GAPS IN THE PCB LANDFILL DOCUMENTATION
I reviewed the Landfill "Conditions" (copy attached) versus what was found in the files at DWM.
The files I had as resources to review were the Division files, the files in your office (two
cardboard boxes) and the personal files of Larry Rose. I checked with Sharron Rogers, Bobby
Lutfy, Pat Williamson, the Solid Waste Fileroom and the Hazardous Waste Fileroom to see if
they had any relevant files on the landfill and they did not. I wanted to ask Pete Doom and Bob
Glaser but they were not available. I left an e-mail for Jimmy Carter to look and see what files
he may have relevant to this task. He will not be back in the office until Monday.
Based on my review on Saturday and Sunday l 0/26 and I 0/27 here is what I have been able to
determine.
Evidence of monthly inspections and landfill leachate monitoring (Conditions A and D) are as
follows:
I 996 -Complete through September
1995 -Complete
I 994 -Complete
I 993 -Complete
I 992 -Complete
1991 -Complete
I 990 -Complete
1989 -Missing January and February
1988 -Missing October, November, and December
I 987 -Missing April, June, July, August, September, October, and December***
I 986 -Complete
I 985 -Complete
1984 -Complete
1983 -Did not find ANY monthly inspection records, I did find leachate analysis sheets for May,
June, July, November and December
I 982 -Nothing found.
*** I did find monthly inspection cover memos for April, July, August and September of 1987
but not the actual inspection form.
I did not find any documentation in the files that records were submitted to the EPA Regional
Administrator 90 days after closure. (Condition 11.C)
Mr. Al Hanke at EPA Region IV was sent copies of analyses of PCB Landfill environmental
samples as they were performed.
Since 1983, the following amounts ofleachate (in gallons) was documented to have been
removed from the landfill.
I 983 -5297
I 984 -1550
1985-1012
1986 - I 00
I 987 -Unknown
I 988 -Unknown
1989 -Unknown
1990 -652
1991 -1220
1992 -1780
I 993 -800
TOTAL - I 2,41 I Gallons
Groundwater and Surface Water Sampling:
I did not find any evidence of the Background sampling that was required by Landfill conditions
11.H.2.a and 11.H.3.a
I did not find any evidence that all wells and surface water locations were sampled monthly
during operation as required by Landfill conditions 11.H.2.b and 11.H.3.b
I did find documentation for the semi-annual Post-closure groundwater and surface water
sampling (Conditions 11.H.2.c and 11.H.3.c) for the dates listed below. The earliest I found was
November 29, I 982. The last semi-annual sampling event was in May 1995. All other years
prior to I 995 except for I 987 had the required two sampling events.
May 24-25, 1995
November I 6-17, I 994
May I 8-I 9, 1 994
November 18-19, 1993
May 20-2 I, 1993
November 24, 1992
May 29, 1992
October 28-29, 1991
April 24, 1991
October 25 , 1990
April 18-19, 1990
October 25, 1989
March 21 , 1989
July 5, I 988
February 2, I 988
June 4. I 987
November I 8, I 986
May 6, 1986
November 13, 1985
May 24, 1985
December 11, 1984
June 6, 1984
November 21, 1983
May 5, 1983
November 29, 1982
I did not find any evidence of samples taken of the soil liner prior to disposal as required by
Landfill Condition I.
Overall Comment: These records are scattered between different people and in different
locations. Some are in a filing cabinet. Others are in cardboard boxes. I would strongly suggest
that ALL of the analytical and inspection records be collected and put in one location so they
don't get lost. A back up copy of these wouldn't be a bad idea either.
Landfill Approval Conditions Dated December 14, 1981:
II
A -Landfili leachate will be monitored monthly and collected leachate will be disposed of
properly. Records will be maintained on file at a designated State office.
B -Operation plan will be followed.
C -Records will be submitted to the Regional Administrator 90 days after closure.
D -Fence, gate and access road maintained in good working order.
E -Report to region IV any instance of PCB detection.
F -Designate a State departmental person responsible for operation and for post closure
monitoring before construction.
H .1 Ground and surface water monitoring collected and analyzed per EPA approved procedures.
H.2 -Groundwater
H.2 .a Background -Each well sampled 3 times and data submitted to EPA prior to
disposal. At least one week between samples. Minimum of 2 replicate measurements
made for each value or concentration.
H.2.b During Operation -All wells sampled monthly.
H.2 .c Post Closure -Each well sampled on a semi-annual basis.
H.3 -Surface water
H.3 .a Background -At least two sampling points per surface water body (upstream and
downstream) sampled at the same time as the background groundwater samples.
H.3.b During Operation -All surface water locations sampled monthly.
H.3.c Post Closure -All surface water locations sampled semiannually.
I -Undisturbed samples of the soil liner will be taken and the laboratory permeability
determined and submitted to EPA Region IV prior to any disposal (1 sample/ 25,000 sq. ft. of
liner)
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