f e O " 0 0 0 0 0 4

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

- 2 -

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

- 3 -

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