n^MGROUP SDMS Document

65393

Holzmacher, McLendon and Murrell, P.C. • Holzmacher, McLendon and Murrell, Inc. • H2M Labs, Inc. Engineers, Architects, Scientists, Planners, Surveyors

575 Broad Hollow Road, Melville. N.Y. 11747-5076 (.516) 756-8000 • ('201)575-5400 F.\:v 516-694-4122

A u g u s t 7 , 199 0

Ms. Caroline Kwan USEPA Region II 26 Federal Plaza New York, New York 10278

Re: Response to USEPA comments for North Sea Municipal Landfill Operable Unit Il/Phase II RI Work/Quality Assurance Plan SHMP 89-05

Dear Ms. Kwan:

This letter transmits H2M's response to the U.S. Environmental Protection Agency's comments pertaining to North Sea Municipal Landfill Operable Unit Il/Phase II Remedial Investigation Work/Quality Assurance Plan.

A response to General Comment No. 9 on the determination of baseline air emissions will be forthcoming within one week.

If you should have any questions or comments, please do not hesitate to contact us at (516)756-8000 ext. 400. Thank you.

Very truly yours,

HOLZMACHER, McLENDON & MURRELL, P.C.

-A

Paul W. Grosser, Ph.D., P.E.

PWG/MNG/bf Enclosure o

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cc: George Stavropoulos, Town Supervisor ^ Marietta Seaman, Town Counselwoman o Patrick Heaney, Town Counselman Michael Walsh, Esq., Town Attorney Craig Kravit, Esq.,. Beveridge & Diamond c5 o

ANBRCANa3f«JING .Melville, N.Y. • Riverhead, N.Y. • Fairfield, N.J. ENIEFBCCUa.

H2HGR0UP ENVIRONMENTAL PROTECTION AGENCY COMMENTS OPERABLE UNIT II - REMEDIAL INVESTIGATION

WORK/QUALITY ASSURANCE PLAN

GENERAL

Comment

The plan does not mention which wells are to be sampled, nor does it give a rationale for sampling only eleven of the possible 23 stainless steel wells. At a minimum, all Rl/FS wells must be redeveloped and sampled. If MW2 cannot be redeveloped, then MW5A, B and C should be redeveloped and sampled.

Response

All of the RI/FS wells will be redeveloped and sampled. These RI/FS monitoring wells include MW-1 cluster (3 wells), MW-2, MW-3 cluster (3 wells), MW-4 cluster (3 wells) and MW-6 (a total of 11 wells) . If MW-2 cannot be redeveloped (turbidity level of 50 NTU's or less), then MW-5A, B and C will be redeveloped and sampled.

Comment

The plan does not address the need for new upgradient monitoring wells as previously requested. Although the Town's consultants have previously presented their rationale for excluding the requested wells, a further review of the analytical data shows that there are leachate indicators in the existing upgradient wells. Since the landfill is the only logical source of these contaminants, the conclusion can be drawn that the landfill is impacting groundwater in MWIA, IB and IC.

Should the Town choose not to install new upgradient wells, EPA and NYSDEC will compare all downgradient well data to New York State and Federal Standards.

Response

The Town of Southampton has decided not to install new upgradient wells, therefore, EPA and NYSDEC should compare all downgradient well data to New York State and Federal Standards. The Town does not agree that wells lA, IB, and IC are impacted by the landfill.

Comment ;o

The work plan does not state that volatile organics will be 2 analyzed for; this omission is unacceptable. Both earlier groundwater monitoring and soil gas analyses have shown the o

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H2MGR0UP presence of volatile organics at the site. The concentration and extent of this contamination needs to be determined during this phase of the investigation.

At a minimum, all samples should be analyzed for Target Compound List (TCL) metals, TCL-volatiles and phenols.

Response

Groundwater samples collected from the eleven (11) RI/FS wells will be analyzed for Target Compound List (TCL) metals, TCL volatile organics, leachate indicator compounds (ammonia, nitrate/nitrite, total dissolved solids, chlorides) and phenols.

Comment

One shallow and one intermediate well must be installed north west of Cell #1. Currently, there are no wells in this area. In addition, after evaluating all rounds of groundwater sampling results, MW-3B exhibited low levels of organics (i.e., 1,1-dichloroethane, trichloroethene and tetrachloroethene) in all three groundwater sampling rounds. The consistent results may indicate that MW3B is located at the edge of a plume.

Response

One shallow and one intermediate well will be installed northwest of Cell #1. This monitoring well couplet will be installed approximately 750 ft. north east (see Figure 1) of the existing MW-3 cluster, with the same materials of construction and methodology used at the other on-site wells.

Comment

More details need to be given regarding level of effort to be applied during well development. All monitoring wells should be developed to a level of 50 nephelometric turbidity units or less. This goal should only be abandoned after several methodologies have been tried and all field parameters (including turbidity) have stabilized. Also, please specify what type of instrumentj will be used to determine turbidity and how often during development it will be checked. No wells are to be sampled prior to three (3) days period following well development.

Response

All monitoring wells will be redeveloped by pumping and surging using a 4-inch submersible pump (flow rate of o approximately 20 gpm). Development will continue until the "̂

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naHo^oup monitoring well purge water exhibits a level of 50 nephelometric turbidity units (NTU) or less.

A Nephelometer will be field calibrated and utilized to determine the NTU's of the development water. Field parameters (pH, conductivity and temperature) along with turbidity units, will be measured every ten (10) minutes until all parameters have stabilized. Once all field parameters have stabilized and the development water exhibits a turbidity of 50 NTU's or less, the well will be considered properly developed. If upon stabilization of field parameter, a turbidity of 50 NTU's is not achieved, additional purging will be performed until turbidity stabilizes. The monitoring wells will be allowed to reach equilibrium for a period not less than three (3) days prior to sampling.

Comment

Samples for metals analysis must be immediately preserved to a pH of 2. Under no circumstances should the sample be allowed to settle in an unpreserved jar prior to decanting and acidifying.

Response

All aqueous samples obtained for metal analysis will be collected in 500 ml. plastic polyethylene bottles. Two (2) milliliters of nitric acid will be immediately added to adjust the pH to less than 2.0 to preserve the sample. The pH of each sample will be checked using litmus paper immediately after collection.

Comment

Detection limits to be used must be specified for all analytical procedures.

Response

Table 1 shows all parameters for which groundwater will be analyzed for and the detection limit for each.

Comment

A minimum of two weeks notice prior to any field activities associated with this plan should be given so that field oversight arrangements may be made. z

Response

Two weeks notice prior to any field activities will be given so that field oversight arrangements can be made.

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iiZMGROUP Comment

9. The methodology to be used to determine the baseline air emissions estimate must be specified prior to acceptance of this plan.

Response

Response to this comment will follow in later correspondence.

SPECIFIC

7.D - Monitoring Parameters and FrequencY of Collection

Comment

1. One field duplicate assigned a separate sample number (or blind duplicate) is required. Do not prepare a field spike. The laboratory will prepare a matrix spike duplicate as part of the laboratory QC.

Response

One field duplicate (blind duplicate) will be collected and assigned a separate sample number. A field spike will not be prepared. H2M Labs will prepare a matrix spike duplicate as part of the laboratory QC.

Comment

2. A daily rinse blank for the dissolved metals fraction is required. This is collected by pouring analyte-free deionized water through the bailer and into the filtering apparatus. Then the sample is acidified with HNO3 to pH <2.

Response

A daily rinse blank will be collected by pouring analyte-free deionized water through the bailer and into the filtering apparatus. The rinse blank will then be acidified with HNO3 to a pH of <2.

Comment

3. The analyte-free deionized water used to create field rinse blanks, and used as the final decontamination rinse, is to be proven analyte-free by analysis for all analytes of concern. This data must be available prior to the sampling -̂ event. This information is to be kept on-site for auditing o

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H2MQ^0UP Response

Manufacturing specifications of the analyte-free deionized water used for the field rinses and the final decontamination rinse is available through H2M Labs. These specifications will be kept on site during the entire sampling episode for auditing purposes.

Comment

4. Since organics are required, the plan will need additional modifications in sections 12.C, 12.D and the tables.

Response

Groundwater sampling procedures specified in section 12.C are amended to include sampling for volatile organics compounds. After purging, the first samples to be collected will be volatile organics.

Table 1 "Groundwater Sampling Sununary" has been modified, accordingly.

ll.D - DATA VALIDITY

Comment

1. Identify the data validator, and list his/her qualifications.

Response

Attached is a document of Qualifications for Laboratory Data Validation submitted by H2M Labs, Inc.

Comment

2. Current copies of Region II data validation SOP's are attached. Cite these SOP's as the ones to be used by the data validator.

Response

The Region II Standard Operating Procedures (SOP's) which were attached will be utilized by the data validator.

12.C - GROUNDWATER SAMPLING PROCEDURE

Comment o

1. During the well purging process, temperature, pH, and ^ conductivity are to be monitored. Take readings before purging and after each well volume. Purge a minimum of 3 9̂

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li2HG?OUP well volumes (at least 4 sets of readings) and begin to sample only when readings stabilize.

Response

During the well purging process, temperature, pH and conductivity will be monitored. These readings will be monitored before purging and after each well volume removed. A volume of water equal to three times that standing in the casing will be pumped from the well. The groundwater will be sampled after monitored readings stabilize. If the monitoring well has a low yield, standing water will be evacuated and the groundwater samples will be collected upon recovery.

Comment

2. If a submersible pump is used to purge wells, it must be housed in stainless steel, with Teflon or polyethylene fittings and hoses. If a centrifugal pump is used, the down-hole pipe must be stainless steel. Purge from the top of the water column, and lower the apparatus if the water level drops. This ensures that the water at the top of the water column, from which the bailer will sample, is fresh.

Response

A stainless steel submersible pump will be used to purge the monitoring wells. This pump and hose fittings are interior lined with inert material such as polyethylene or teflon. The monitoring wells will be purged from the top of the water column and the pump will be lowered if the water level drops. This will ensure that the water at the top of the water column, from which the bailer will sample, is fresh.

Comment

3. Please note that when sampling, only the stainless steel leader attached to the bailer is to come in contact with the water, and not the nylon cord. Please clarify the last sentence in the third paragraph.

Response

During groundwater sampling, only the 10 foot long section of the stainless steel leader line attached to the bailer, will come in contact with the water. The nylon cord will not come in contact with the water.

Comment

4. Do not use pre-preserved sample bottles. Have the laboratory supply the chemical preservatives separately, and

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tUHGRdP add to samples in the field after collection. Use pH paper to ensure the correct pH is achieved.

Response

Pre-preserved sample bottles will not be used. The chemical preservatives will be added to the samples in the field after collection. The pH of each sample will be checked using litmus paper to ensure the proper pH is achieved.

12.D - FIELD DECONTAMINATION PROCEDURE

Comment

1. The pumps are to be decontaminated before and between uses by passing a non-phosphate and potable water solution through the pump and any pipe or tubing, and thoroughly washing the outside of all down-hole equipment, including the submersible pump housing, power and support cords, tubing, and pipe for the centrifugal pump. Then rinse the same inner and outer components with approximately 10 gallons of potable water, then 2 gallons of analyte-free deionized water.

Response

The decontamination protocols, as addressed above, will be followed during field activities in order to minimize the possibility of introducing contaminants and to ensure the samples and data collected are representative of the actual conditions.

12.E - SAMPLE CUSTODY PROCEDURES

Comment

1. Describe, the sample packing and shipping procedures. Samples are to be packed with enough ice to maintain a constant temperature of 4 C inside the cooler. Samples are to be shipped to the laboratory within 24 hours of sampling via overnight courier.

Response

H2M Labs, Inc. has a standard operating procedure for documenting the receipt, tracking and compilation of sample data. Sample custody related to sampling procedures and sample transfer are described below:

1 - Prior to Sampling o

Sample bottles are individually wrapped and packed at o H2M Labs. ^

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li2MGR0UP Chain of custody form filled out by H2M personnel.

Each cooler is sealed with strapping tape and custody seals.

Samples relinquished by H2M Labs to H2M sampling personnel via chain of custody.

Samples are then collected and packed into coolers with the associated chain of custody form. Each cooler is wrapped with strapping tape and custody seals signed by H2M sampling personnel. The samples are packed with ice to maintain a constant temperature of 4° C inside the cooler.

2 - Deliverv of Samples to H2M Lab

The same day, after sampling, coolers are hand delivered to H2M Labs, Inc., in Melville, N.Y..

Coolers are then relinquished by H2M sampling personnel to the Receiving Department of H2M Labs.

12.F - SAMPLE BOTTLES

Comment

1. If I-Chem bottles are being purchased, obtain series - 300 bottles. These bottles come with a certificate of cleanliness by chemical analysis. Keep these certificates on-site for auditing purposes.

Response

H2M Labs, Inc. will utilize either the I-Chem sample bottles or the Eagle Richer Level I sample bottles. In either case, these bottles will come with a certificate of cleanliness by chemical analysis. These certificates will be kept on site during sampling for auditing purposes.

ADDITIONAL COMMENT

Comment

1. Identify in the plan the laboratory performing the chemical analyses.

Response

H2M Labs, Inc. Environmental Testing Laboratories ^ 575 Broad Hollow Road, Melville, New York o

TABLE 1 - GROUNDWATER SAMPLE ANALYSIS o o

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H2Ha?0UP Comment

1. The latest CLP-SOW is dated 7/88, not 12/89.

2. The holding time for mercury is 26 days, not 6 months.

3. There is no need to re-analyze iron and manganese as leachate indicators, as these analytes are already included in .the TCL.

4. Ammonia - State which MCAWW method will be used to analyze; 350.1, .2 or .3.

5. Nitrate/Nitrite - State which MCAWW method will be used to analyze; 353.1, .2 or .3. The holding time is 28 days, not 4 8 hours.

6. Chloride - The CLP-SOW does not analyze for chloride, use an MCAWW method. State which MCAWW method will be used to analyze; 325.1, .2 or .3. Do not use nitric acid preservation, nothing is to be added to the sample.

7. TDS - The holding time is 7 days, not 28 days.

Response

The incorporation of the above comments can be found in the revised Table 1.

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NOR 001 0363

TCL VOLATILE PARAMETER

Chloromethane Bromomenthane Vinyl Chloride Chloroethane Acetone Methylene Chloride Carbon Disulfide 1,1-Dichloroethene 1,l*Dichloroethane 2-Butanone vinyl Acetate Chloroform 1,2-Dichloroethane 1,1,1-Trichloroethane Carbon Tetrachloride Trans-1,3 -Dichloropronene Trichloroethene 1,2-Dichloropropane Bromodichloromethane 4-Methyl-2 pentanon 1,1,1-Trichoroethane 2-Hexanone Benzene Cis-1,3 Dibromochloromethane Tetrachloroethene +1,1,2,2-Tetrachorothane Toluene Chlorobenzene Ethylbenzene Bromoform Styrene Xylene (Total) 1,2-Dichloroethene

METHOD REFERENCE CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW

CLP SOW

CLP SOW

CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW

CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW CLP SOW

2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88

2/88

2/88

2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88 2/88

2/88 2/88 2/88 2/88 2/88 2/88 2/88

TJ

GROUNDWATER

SAMPLE PRESERVATION Cool Cool Cool Cool Cool Cool' Cool Cool Cool Cool Cool Cool Cool Cool

Cool

Cool

Cool Cool Cool Cool Cool Cool Cool Cool Cool Cool Cool

Cool Cool Cool Cool Cool Cool Cool

--------------

-

-

----- •

------

_ ------

4" 4° 4° 4° 4° 4° 4° 4° 4° 4° 4° 4° 4° 4°

4°

4°

4° 4° 4° 4° 4° 4° 4° 4° 4° 4° 4°

4° 4° 4° 4° 4° 4° 4°

C C

c c C

c c c c c c c c c

c

c

c c c c c c c c c c c

c c c c c c c

VBLE 1

SAMPLE ANALYSIS

HOLDING TIME . 10 10 10 10 10 10 10 10 10 10 10 10 10 10

10

10

10 10 10 10 10 10 10 10 10 10 10

10 10 10 10 10 10 10

Days Days Days Days Days Days Days Days Days Days Days Days Days Days

Days

Days

Days Days Days Days Days Days Days Days Days Days Days

Days Days Days Days Days Days Days

40 40 40 40 40 40 40 40 40 40 40 40 40 40

40

40

40 40 40 40 40 40 40 40 40 40 40

40 40 40 40 40 40 40

CONTAINER ml ml ml ml ml ml ml ml ml ml ml ml ml ml

ml

ml

ml ml ml ml ml ml ml ml ml ml ml

ml ml ml ml ml ml ml

vial vial vial vial vial vial vial vial vial vial vial vial vial vial

vial

vial

vial vial vial vial vial vial vial vial vial vial vial

vial vial vial vial vial vial vial

w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap

w/teflon cap

w/teflon cap

w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap

w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflon cap w/teflbn cap

DETECTION LIMITS ( V G / I J )

1.22 0.62 0.48 80 35 64 89 31 74 14 33 75

1.36 0.47

1,05

0,93

0,70 1.52 1.34 1,45 54 06 23 10 10 10

0.87

,90 1,28 1,39 1.33 ,86

1,14 0.53

TCL PARAMETER Aluminum Antimony Arsenic Barium Berrylium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Mercury Nickel Potassium Selenium Silver Sodium Thallium Vanadium Zinc

METHOD REFERENCE

CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88 CLP SOW 7/88

TABLE 1

GRODNDWATER SAMPLE ANALYSIS

SAMPLE PRESERVATION HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3 HNO3

pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2 pH<2

HOLDING

6 6 6 6 6 6 6 6 6 6 6 6 6 6

TIME Months Months Months Months Months Months Months Months Months Months Months Months Months Months

26 Days 6 6 6 6 6 6 6 6

Months Months Months Months Months Months Months Months

CONTAINER 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene 1 Liter Polyethylene

NOR 001 0364

DETECTION LIMITS f UG/H

1 5 , 3 3 8 , 1

3 , 0 9 , 6 0 , 6 3 .

2 3 2 . 7 . 6 . 2 . 8. 3 .

249 1 . 0 . 8 .

459 1 . 1 2 , 7

5 8 7 . 0 1 ,0 4 , 5 1 ,5

.9 ,0 .8 .0 .4 ,4 .0

,8 ,2 . 1

LEACHATE INDICATORS; Ammonia

Nitrate/Nitrite

Chloride

TDS

MCAWW EPA Method 350.1 3/83 MCAWW EPA Method 353.2 3/83 MCAWW Method 325, 3/83 2 09 BStD Methods (16th Ed.)

H2SO4, pH<2,4°C

H2SO4, pH<2 4°C

28 Days

28 Days

6 Months

7 Days

1 Liter Polyethylene

1 Liter Polyethylene

1 Liter Polyethylene

1 Liter Polyethylene

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DIRECVON OF GROUNDWATER FLOW

FIGURE 1

NORTH SEA LANDFILL

= STAINLESS STEEL MONITORING WELL = EXISVNG PVC WELL

+ = LANDFILL SUPPLY WELL ® = PROPOSED MONITORING WELL 12 A A B

H2HGROUP

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