United States Science Advisory Board EPA-SAB-EC-94-010
Environmental 1400 September 1994
Protection Agency Washington, DC
AN SAB REPORT: REVIEW OF
ERA'S APPROACH TO
SCREENING FOR RADIOACTIVE
WASTE MATERIALS AT A
SUPERFUND SITE IN
UNIONTOWN, OHIO
PREPARED BY THE ad hoc INDUSTRIAL
EXCESS LANDFILL PANEL OF THE
SCIENCE ADVISORY BOARD
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
Octobers, 1994
Of FIGS Of THE ADMINISTRATOR
SCIENCE AOVISOflY 3CAflO
Memorandum to Interested Parties
SUBJECT: Release of the Final Report of the Science Advisor/ Board's 3d hoc
industrial Excess Landfill Panel
FROM: Robert FlaaK, Assistant Staff Director
Science Advisory Board
Attached is a copy of the final Science Advisory Board (SAB) report:
AN SAB REPORT: REVIEW OF EPA'S APPROACH TO SCREENING FOR
RADIOACTIVE WASTE MATERIALS ATA SUPERFUND SITE IN UNIGNTOWN,
OHIO, EPA-SAB-EC-94-010, September 1994.
Additional single copies are available at no charge from the Science Advisory Board.
Please provide your name and mailing address, citing the above report title and
number, to: USEPA, Science Advisory Board (1400), Attn: Publication Requests, 401
M Street, SW, Washington, DC 20460, or via Fax at (202) 260-1889.
Attachment
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/*^\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
5 ->•—'- \ WASHINGTON, D.C. 20460
OFFICE OF THE ADMINISTRATOR
SCIENCE ADVISORY BOARD
September 30, 1994
EPA-SAB-EC-94-010
Honorable Carol M. Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Subject: Review of issues related to the Agency's approach to screening
for radioactive waste materials at Superfund sites, focusing on the
Industrial Excess (IEL) Landfill Site in Uniontown Ohio.
/"! Dear Ms. Browner:
The ad hoc Industrial Excess Landfill Panel of the Science Advisory Board
(SAB) has completed its review of issues related to the Agency's approach to
screening for radioactive waste materials at the Industrial Excess Landfill (IEL)
Superfund Site in Uniontown, Ohio. This review was conducted at the request of the
Office of Solid Waste and Emergency Response (OSWER). The following
summarizes our responses to the Panel's Charge.
1) For screening purposes, what types of temporal and spatial sampling ana:
analyses are sufficient to test a hypothesis that radioactive contamination is
present?
Screening for radioactivity can be accomplished by analyzing drilling cores
and/or well clusters on or near a site. Ground water analysis is effective in detecting
radioactivity leaving the site, allowing corrective actions to be taken. There is no clear
evidence that ground water monitoring is more sensitive in detecting the presence of
radioactive material in the landfill than would be a soil core sampling program.
However, the ground water monitoring program serves the additional purpose of
protecting public health through corrective action, should radioactivity later be found to
leak into the ground water. We see no basis for substantial additional radiation testing
at the IEL site; however, it would be prudent after remediation to test a sample of the
pump and treat water flow for radiation at least each calendar quarter until the
successive quarterly samples have produced a constant level of near-basal gross
alpha and beta activity.
PiM*d on paper that comalnt
* teati 75% ncydrt Ox*
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2) What radiological parameters, e.g., gross alpha plus alpha spectrometry,
gross beta, gamma spectrometry, tritium, and carbon-14, are sufficient to
determine the possible existence/extent of potential sub-surface radiological
contamination? Are the methods employed by EPA for analysis of radioactive
contamination adequate and appropriate for analyses of samples from
hazardous waste sites?
The set of radiological parameters identified by EPA (gross alpha, alpha
spectrometry, gross beta, gamma spectrometry, tritium, and carbon-14) is appropriate
and sufficient for screening surveys to determine the possible existence and/or extent
of potential sub-surface radiological contamination. The analytical methods identified
by EPA for radionuclide analyses at hazardous waste sites are time-tested and
appropriate. Some of the documentation on procedures presented to the ad hoc
Panel, however, was several years old and sometimes did not reflect recent advances.
Therefore, we recommend that EPA review and update its procedures in order to
remain current and state-of-the-art.
3) There are generic guidelines for sampling and analytic methods and chain
of custody protocols to ensure that cross contamination or tampering with
samples does not occur when dealing with radioactive contaminants. If
appropriate, these guidelines may be modified on a site-specific basis
depending on the characteristics of the site in question. What modifications are
scientifically justified while still assuring accurate, precise and valid data?
Generic guidelines for chain of custody protocols are not likely to have to be
modified based on site characteristics. The guidelines for sampling and analytic
methods could under certain site conditions be adapted to local conditions. Soil
hydrology and geology could suggest that a standard protocol for sampling be
modified. If radioactivity is a concern then well samples containing suspended solids
should be appropriately separated and dissolved and suspended radioactivity
assessed quantitatively. We also recommend the following: a) that surface monitoring
for radioactivity be undertaken using a survey monitor very early in the
characterization of a Superfund site; b) that during the remedial investigation of a
Superfund site one round of gross alpha and gross beta activity in the monitoring wells
be included in the protocol at the time the wells are investigated for other constituents.
This would serve to establish whether special consideration should be given to
radioactive deposits; c) that the cores collected at the time of the development of
monitoring wells be subjected to a radiological survey by gamma analysis, and the
results should be made a part of the remedial investigation record; and d) that if
pump-and-treat is implemented at a site for non-radioactive clean-up and radioactive
contamination is suspected, we recommend consideration of monitoring of the pump
and treat flows for radioactivity for some period of time as a useful addition to any
remedial plan.
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4) What factors need to be considered in the development and application of
data validation criteria for evaluation of radioactive contaminants at hazardous
waste sites?
Verification should insure that: all contractual agreements, as outlined in the
"Statement of Work" are in compliance for a given project; a pre-award audit of the
laboratory is done by a team of experts before a contract is initiated; the lab is
consistently performing well by submitting to the lab blind samples with known
quantities of spikes disguised as real samples; the laboratory providing radiochemical
analysis services must use agreed-upon and approved Standard Operating
Procedures (SOPs), including software that is verified, validated and documented for
approved instruments; and the equipment calibrations are performed using Natic—1.!
Institute of Standards and Technology (NIST) traceable reference radionuclide
standards.
Validation includes: reviewing the results and data from planning stages through
sample collection, logging in, receiving, sample preparation, analysis, radiation
measurements, calculation of results with associated propagated errors, and
documentation; reviewing results of a given batch of samples along with quality control
samples (Quality Control (QC) spiked samples, blanks, duplicates, blinds, etc.) for
contractual requirements and technical correctness to validate the results; insuring that
documentation is available if corrections are made and qualifiers added to the data
(the same for rejected results); and reviewing all data to ensure that the data are of
the level of accuracy and precision required, defensible, and complete.
5) What practices and organizational changes could lead to improved
credibility for the U.S. EPA and constructive public participation at hazardous
waste sites with potential radioactive contamination?
Good risk communication practices are vital to effective Superfund site
management. Broadly construed, such practices entail: a) establishing an
organizational structure that enables all stakeholders to inform, be informed and
observe the total risk management process including risk identification; b) establishing
some shared understanding of the goal of the risk assessment and management
process; c) recognizing and respecting differences in language and searching for a
common understanding of the site characterization; d) clearly specifying and agreeing
on who has the authority and responsibility to make final decisions; and e)
designating and agreeing on how differences will be arbitrated should that be
necessary.
6) Presence of Radioactive Materials at the IEL Site
Historical evidence for the presence of radioactive materials is limited to
anecdotal reports of "midnight dumping" at the site by vehicles alleged to have been
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marked with radiation symbols. Disposal records and a search of the records of tha
identified landfill users have not indicated the probability of disposal of radioactive
materials. In addition, the available analytical data do not indicate that radioactive
contamination is present at the IEL site as a result of disposal at the site. While there
are a small number of analytical values that are unexpectedly high relative to the
associated uncertainty estimates, the occurrence of such high values follows a pattern
that is more characteristic of analytical errors or accidental contamination in the
laboratory than of a positive identification of the occurrence of radioactivity at a field
site.
Based on all the evidence presented to the ad hoc Panel, we judge it to be
highly unlikely that radioactive contamination is, or was, present. Of course it is not
(and never will be) possible to unequivocally establish the absence of contamination.
Nonetheless, as noted in the response to the Panel Charge, the tests performed were
appropriate and adequate to detect the occurrence of radionuclides that might be
expected based on experience at sites that are contaminated with the most common
radionuclides. Thus, the current weight of evidence argues that the issue of
radioactive contamination should not be pursued further and the confirmed issue of
chemical hazards and remediation thereof should proceed expeditiously.
Although the Board does not normally undertake site-specific reviews, we felt
that there was merit in looking at this site and applying our responses to the questions
raised in the charge broadly to include the generic methodology the Agency applies to
evaluating the presence of radioactive waste at hazardous waste sites. We wish to
express the Panel's appreciation for the excellent cooperation and assistance we
received from all parties involved at IEL. While we felt the review exercise was
valuable, it does require a large commitment of time and resources. In general, we
will consider site-specific reviews on a case-by-case basis. We are pleased to have
participated in this process and look forward to your response to our report.
Sincerely,
"75tf ^
r. Genevieve Matanoski, Chair
Executive Committee
Science Advisory Board
Dr/3arWU. Stolwijk, Chair
aa hoc Industrial Excess
Landfill Panel
Science Advisory Board
Enclosure
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NOTICE
This report has been written as a part of the activities of the Science Advisory
Board, a public advisory group providing extramural scientific information and advice
to the Administrator and other officials of the Environmental Protection Agency. The
Board is structured to provide balanced expert assessment of scientific matters related
to problems faced by the Agency. This report has not been reviewed for approval by
the Agency; and hence, the contents of this report do not necessarily represent the
views and policies of the Environmental Protection Agency or other agencies in the
Federal government. Mention of trade names or commercial products does not
constitute a recommendation for use.
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ABSTRACT
The ad hoc Industrial Excess Landfill Panel of the Science Advisory Board
reviewed issues related to the USEPA's screening criteria and procedures for
radioactive waste materials, using the Industrial Excess Landfill Superfund site in
Uniontown, Ohio as a test case. The Panel was asked: a) For screening purposes,
what types of temporal and spatial sampling and analyses are sufficient to test a
hypothesis that radioactive contamination is present? b) What radiological parameters
are sufficient to determine the possible existence/extent of potential sub-surface
radiological contamination? Are the methods employed by EPA for analysis of
radioactive contamination adequate and appropriate for analyses of samples from
hazardous waste sites? c) What modifications to generic guidelines for sampling and
analytic methods and chain of custody protocols are scientifically justified while still
assuring accurate, precise and valid data? d) What factors need to be considered in
the development and application of data validation criteria for evaluation of radioactive
contaminants at hazardous waste sites? e) What practices and organizational changes
could lead to improved credibility for the U.S. EPA and constructive public participation
at hazardous waste sites with potential radioactive contamination? The Panel
responded to these and other questions in their report. Many of the Panel's
conclusions and recommendations concerning issues such as sampling protocols,
laboratory selection, data validation and verification, chain of custody, and risk
communication should be taken broadly to apply to EPA's actions concerning
Superfund sites in general, and not just the Industrial Excess Landfill which is featured
in this report.
KEY WORDS: Industrial Excess Landfill; Superfund; Ohio; Radioactive Contamination
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U.S. Environmental Protection Agency
Office of the Administrator
Science Advisory Board
ad hoc IEL Advisory Panel
Chair*
Dr. Jan Stolwijk, School of Medicine, Department of Epidemiology and Public Health,
Yale University, New Haven, CT
Panel Members
Dr. Ann Bostrom, School of Public Policy, Georgia Institute of Technology, Atlanta, GA
Dr. Norman H. Cutshall, Oak Ridge National Laboratory, Jak Ridge, TN
Dr. Robert Morrison, R. Morrison & Associates, Valley Center, CA
Dr. Oddvar Nygaard, Division of Radiation Biology, Department of Radiology,
Case Western Reserve University, Cleveland, OH
Dr. Mitchell Small, Departments of Civil Engineering and Engineering and Public
Policy, Carnegie Mellon University, Pittsburgh, PA
Dr. Michael Stein, Department of Statistics, The University of Chicago, Chicago, IL
Dr. Myint Thein, Oak Ridge National Laboratory, Oak Ridge, TN
*NOTE: Dr. Robert J. Huggett, Virginia Institute of Marine Science, School of Marine Science,
College of William and Mary, Gloucester Point, VA, initially served as the Chair of this ad hoc Panel. At the
time the report was being finalized he was selected by President Clinton as Assistant Administrator Designee
for EPA's Office of Research and Development. Consequently, Dr. Huggett resigned from his position on the
Science Advisory Board and this Panel.
Science Advisory Board Staff
Mr. A. Robert Flaak, Assistant Staff Director, U.S. EPA, Science Advisory Board
(1400F), 401 M Street, SW, Washington, DC 20460
Ms. Janice Cuevas, Management Analyst, U.S. EPA, Science Advisory Board
(1400), 401 M Street, SW, Washington, DC 20460
in
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TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
1.1 Temporal and Spatial Sampling and Analyses 2
1.2 Radiological Parameters and Analytical Methods 4
1.3 Guidelines for Sampling 4
1.4 Data Validation Criteria 5
1.5 Risk Communication 6
1.6 Radioactive Materials at the IEL Site 6
2. INTRODUCTION 8
2.1 Charge to the Panel 8
2.2 Panel Review Process 9
3. RESPONSE TO THE CHARGE TO THE ad hoc PANEL 11
3.1 Temporal and Spatial Sampling and Analyses 11
3.1.1 General Findings 11
3.1.2 Adequacy of Information to Characterize Background
Concentrations at the IEL Site 12
3.1.3 Adequacy of Methods used to Evaluate the Effectiveness of
Possible Core Sampling and Ground Water Monitoring
Programs 16
3.2 Radiological Parameters 19
3.2.1 Laboratory Analytical Methods 20
3.2.2 Analytical Methods and Procedures 21
3.2.3 Field Sampling and Analytical Methods 22
3.3 Guidelines for Sampling and Analytic Methods 22
3.3.1 Considerations for other Superfund Sites in the Future 23
3.4 Criteria for Data Validation 24
3.4.1 Recommendations for Verification 25
3.4.2 Recommendations for Validation 25
3.5 Communicating Risk 26
3.5.1 Information 26
Appendix A - Summary of Review Materials
IV
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1. EXECUTIVE SUMMARY
The ad hoc Industrial Excess Landfill (IEL) Panel of the Science Advisory Board
(SAB) has reviewed issues1 related to the Agency's approach to screening for
radioactive waste materials, using the IEL Superfund site in Uniontown, Ohio as a test
case. Even though a specific site was investigated, the ad hoc Panel was asked to
respond to a number of questions which addressed concerns that were applicable to
Superfund sites in general. The Panel held three public meetings on July 20-21, 1993
(in Akron, Ohio), September 21-22, 1993 (in Washington, DC) and December 14, 1993
(in Uniontown, Ohio).
The Charge to the Panel asked: a) For screening purposes, what types of
temporal and spatial sampling and analyses are sufficient to test a hypothesis that
radioactive contamination is present? b) What radiological parameters, e.g., gross
alpha plus alpha spectrometry, gross beta, gamma spectrometry, tritium, and
carbon-14, are sufficient to determine the possible existence/extent of potential sub-
surface radiological contamination? Are the methods employed by EPA for analysis of
radioactive contamination adequate and appropriate for analyses of samples from
hazardous waste sites? c) There are generic guidelines for sampling and analytic
methods and chain of custody protocols to ensure that cross contamination or
tampering with samples does not occur when dealing with radioactive contaminants. If
appropriate, these guidelines may be modified on a site-specific basis depending on
the characteristics of the site in question. What modifications are scientifically justified
while still assuring accurate, precise and valid data? d) What factors need to be
considered in the development and application of data validation criteria for evaluation
of radioactive contaminants at hazardous waste sites? e) What practices and
organizational changes could lead to improved credibility for the U.S. EPA and
constructive public participation at hazardous waste sites with potential radioactive
contamination?
The Panel has responded to its Charge as well as addressed other issues it felt
warranted further attention. It should be noted that many of the Panel's conclusions
and recommendations concerning issues such as sampling protocols, laboratory
selection, data validation and verification, chain of custody, and risk communication
should be taken broadly to apply to EPA's actions concerning Superfund sites in
For a partial listing of the review materials available for the ad hoc Panel's review, please refer to Appendix A. This
includes materials provided by the US EPA as part of the formal review process, as weil as relevant listings from the Ohio EPA, which
supplement the US EPA materials. Information on materials and comments from other sources, including other government agencies
and interested parties is contained in the archives of the SAB.
1
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general, and not just the Industrial Excess Landfill Superfund site in Uniontown, Ohio
which is featured in this report.
1.1 Temporal and Spatial Sampling and Analyses
Principal methods for determining the presence of radioactive contamination at
a site include ground surveys, ground water monitoring and soil coring studies.
Ground surveys should be routinely conducted as an initial screening method, though
they are only able to detect radiation near the immediate surface of a landfill.
Furthermore, it is difficult or often infeasible to implement a ground survey at a site
once it has become significantly overgrown with vegetation, as is the case at the IEL
site. A groundwater monitoring program is effective at identifying the presence of
soluble radioactive materials, since the goundwater provides as integrated measure of
the materials in the landfill, but only if the resulting concentrations are high enough to
be detected and are distinguishable from background concentrations in the area.
Core sampling is more effective at identifying small quantities of immobile wastes, but
only if the core borings encounter the wastes. If radioactive materials have been
spread broadly over a wide horizontal area, then such an encounter is likely to occur
with a limited and feasible number of core borings. However, if the waste is confined,
then the probability of encounter is very low, unless an extraordinary (often infeasible)
number of borings is made.
The scientific studies used by the Agency to support the selection of a ground
water monitoring program, and not a soil core sampling program, are summarized in
correspondence from EPA Region 5 Administrator Valdas Adamkus to Senator John
Glenn (EPA, 19902; EPA, 19913). Each letter includes a technical report; the first
demonstrating the infeasibility of the core monitoring program, the second supporting
the adequacy of ground water monitoring. Both of these reports include technical
flaws and provide no clear evidence that ground water monitoring is more sensitive in
detecting the presence of radioactive material in the landfill than would be a soil core
sampling program. However, the ground water monitoring program serves the
additional purpose of protecting public health by allowing for corrective action, should
radioactivity later be found to leak into the ground water. A groundwater monitoring
program is thus an effective and appropriate method for determining both the
EPA, 1990. Letter from EPA Region 5 Administrator Valdus Adamkus to Senator John Glenn, transmitting EPA's
justification for not characterizing the waste material by soil core sampling with analysis for radionuclides. December 18, 1990.
3 EPA, 1991. Letter from EPA Region 5 Administrator Valdus Adamkus to oenator John Glenn, transmitting EPA's
ground water modeling report which was used to estimate the concentration of three potential radioactive sources downgradient
from the IEL landfill at selected penods. March 25, 1991.
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presence and potential health implications of radioactive contamination at a site such
as IEL.
An effective groundwater sampling program requires the use of a sufficient
number of monitoring wells to detect multiple possible pathways from the landfill, and
a adequate number of properly located background wells to describe the distribution of
naturally occurring radiation at the site. The background wells must be located at
sufficient distances upgradient from the site to ensure that they have not been
influenced by leakage from the site. Given the radial pattern of groundwater flow at
the site identified by USGS, and the uncertainty this creates in identifying upgradient
vs. downgradient wells, the two current background well clusters at the IEL site are
not adequate to reliably characterize the backgrounu condition. More background
wells are needed at moderate and further distances from the landfill. In addition, the
Agency should consider a special monitoring program during or following storm events
at seepage faces near the landfill. This type of sampling program involves a proactive
search for evidence of contamination where it is most likely to be found, and has been
effective at locating wastes which are periodically mobilized at other sites.
Despite these problems, we believe that EPA has looked hard for signs of
radioactive contamination and has not found clear evidence to support a claim of past
radioactive dumping. That does not imply that such dumping did not occur, only that
presently there is little or no evidence for it. We see no basis for substantial additional
radiation testing at the IEL site; however, it would be prudent after remediation to test
a sample of the pump and treat water flow for radiation at least each calendar quarter
until the successive quarterly samples have produced a constant level of near-basal
gross alpha and beta activity.
With the recommendations presented above and additional recommendations
discussed later concerning sampling methodology to provide a full accounting of both
particulate and dissolved radiation, the current groundwater monitoring program is
deemed adequate to indicate the presence of radioactive contamination at IEL and
provide future protection for public health. However, should the Agency decide to
consider a soil coring program, it should be recognized that it will likely be effective
only for determining the presence of contamination which is widely spread over a
significant horizontal area. Such a program should thus be limited to this particular
objective, and be very limited in scope.
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1.2 Radiological Parameters and Analytical Methods
The set of radiological parameters identified by EPA (gross alpha, alpha
spectrometry, gross beta, gamma spectrometry, tritium, and carbon-14) is appropriate
and sufficient for screening surveys to determine the possible existence and/or extent
of potential sub-surface radiological contamination. If there is concern about possible
radiological contamination at a particular site, then all available information should be
reviewed (e.g., site characterization) to determine whether specific radionuclides might
reasonably be expected at the site. Obviously, if it were known (or there were
adequate reason to suspect) that specific radionuclides have been disposed of at the
site, analyses for those contaminants should be conducted.
The analytical methods identified by EPA for radionuclide analyses at
hazardous waste sites are time-tested and appropriate. Some of the documentation
on procedures presented to the ad hoc Panel, however, is several years old and
sometimes does not reflect recent advances. Therefore, we recommend that EPA
remain cognizant of, and responsive to, advances in radiochemical procedures and
analytical technology as they may apply to the characterization of hazardous waste
sites for radiochemical materials.
1.3 Guidelines for Sampling
Guidelines for sampling and analytic methods and chain of custody protocols
may be modified on a site-specific basis depending on the characteristics of the site in
question. Very early in the characterization of a Superfund site we recommend that
surface monitoring be undertaken using a survey monitor. Even though a surface
survey likely will not detect any radioactive material at depths greater than several
inches (depending on the amount of radionuclide present and the characteristics of
radiation emitted), it will provide a helpful record of the pre-remediation state. During
the remedial investigation one round of gross alpha and gross beta activity in the
monitoring wells at the time the wells are investigated for other constituents would
serve to establish whether special consideration should be given to radioactive
deposits. The drinking water protocol as used at IEL, without separate determination
of the activity in suspended solids, should suffice for this first determination. The
cores collected at the time of the development of monitoring wells should be subjected
to a simple radiological survey (with a Geiger-Mueller counter), and the results should
be made a part of the remedial investigation record. If pump-and-treat is implemented
at a site for non-radioactive clean-up and radioactive contamination is suspected,
monitoring of the pump and treat flows for radioactivity for some period of time would
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be a necessary addition to any remedial plan. Such monitoring could reasonably be
restricted to gross alpha and beta analysis.
1.4 Data Validation Criteria
The goal of any quality-oriented measurement program is to establish credibility
and to maintain the quality of results within established limits of acceptance. A good
laboratory that provides analytical services of high integrity will gain customer and
public confidence. Meaningful and reliable results generated by the laboratory will
also be legally defensible in a court of law. In order to achieve the goal of obtaining
quality data, verification and validation must be carried out for the sample collection,
analysis, and measurement processes.
Verification exercises should insure that: a) all contractual agreements, as
outlined in the "Statement of Work" are in compliance for a given project; b) a pre-
award audit of the laboratory is done by a team of experts before a contract is
initiated; c) the lab is consistently performing well by submitting to the lab blind
samples with known quantities of spikes disguised as real samples; d) the laboratory
providing radiochemical analysis services must use agreed-upon and approved
Standard Operating Procedures (SOPs), including software that is verified, validated
and documented for approved instruments; and e) the equipment calibrations are
performed using National Institute of Standards and Technology (NIST) traceable
reference radionuclide standards.
Validation exercises include: a) reviewing the results and data from planning
stages through sample collection, logging in, receiving, sample preparation, analysis,
radiation measurements, calculation of results with associated propagated errors, and
documentation; b) reviewing results of a given batch of samples along with quality
control samples (Quality Control (QC) spiked samples, blanks, duplicates, blinds, etc.)
for contractual requirements and technical correctness to validate the results; c)
insuring that documentation is available if corrections are made and qualifiers added
to the data (the same for rejected results); and d) reviewing all data to ensure that the
data are of the level of accuracy and precision required, defensible, and complete.
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1.5 Risk Communication
Good risk communication practices are vital to effective Superfund site
management. Broadly construed, such practices entail: a) establishing an
organizational structure that enables all stakeholders to inform, be informed and
observe the risk assessment and management process; b) establishing some shared
understanding of the goal of the risk assessment and management process; c)
recognizing and respecting differences in language and searching for a common
understanding of the site characterization; d) clearly specifying and agreeing on who
has the authority and responsibility to make final decisions; and e) designating and
agreeing on how differences will be arbitrated should that be necessary.
At the IEL site, both disagreements about prior knowledge and expectations
about the site and disagreements about how to interpret new information have
contributed to conflicting judgments about risk, and consequent differences in opinic, j
between various stakeholders and EPA about appropriate management of the site.
Conflicts are likely to continue until the public and the U.S. EPA find some common
ground.
Invalidation and non-release of data from the first round of IEL sampling and
the subsequent growth of suspicion and distrust provides an important object lesson.
Data, once collected, should not be withheld. Even when results must be weighted
with qualifying statements or even totally discounted, it is ultimately wise to release
them. Obviously, appropriate qualifiers should accompany the data, just as the
uncertainty terms should accompany data from radionuclide analyses. However, even
with qualifiers, misuse or misinterpretation of the results should be anticipated.
Nonetheless, the use of unreliable data is a less serious problem than the overall loss
of credibility that results from apparent data suppression. This conclusion for the !EL
experience is borne out by the much larger experience relating to radioactive
discharges at sites operated by or for the Department of Energy (DOE).
1.6 Radioactive Materials at the IEL Site
Although not part of the stated charge to the Panel, it is clear that one of the
important issues which the ad hoc Panel needed to address is the possibility of
radioactive contaminants at the Industrial Excess Landfill. Historical evidence for sucn
presence is limited to anecdotal reports of "midnight dumping" at the site by vehicles
alleged to have been marked with radiation symbols. Disposal records and a search
of the records of the identified landfill users have not indicated the probability of
disposal of radioactive materials. In addition, the available analytical data do not
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indicate that radioactive contamination is present at the IEL site as a result of disposal
at the site. While there are a small number of analytical values that are unexpectedly
high relative to the associated uncertainty estimates, the occurrence of such high
values follows a pattern that appears more characteristic of analytical errors or
accidental contamination in the laboratory than of a positive identification of the
occurrence of radioactivity at a field site.
While significant evidence of contamination is not found in the current data,
neither is it possible from these data to preclude the possibility that some radioactive
contamination is present. Indeed, it is not now (and never will be) possible to
unequivocally establish the absence of contamination. The current groundwater
monitoring, with the recommended modifications of including more background wells,
full accounting of dissolved and particulate phase radioactivity, and a proactive wet-
weather survey, is adequate for the intended radioactive screening and protection of
public health. Should this program conclude that there is no evidence of
contamination, ongoing radiological screening of area drinking water and groundwaters
pumped as part of the site remediation plan would then be adequate over the longer
term. If the Agency elects to supplement the program with additional soil core
sampling, it should be of limited scope, aimed only at detecting the presence of a
widely dispersed waste. While some screening effort to detect radioactive
contamination should continue, the current lack of evidence of contamination is such
that no further delay in planned remediation is warranted. This additional monitoring
should thus be conducted in concert with planned efforts to remediate the confirmed
chemical hazards present at the site.
7
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1
2. INTRODUCTION
2.1 Charge to the Panel
The Agency's Office of Solid Waste and Emergency Response (OSWER)
requested that the Science Advisory Board (SAB) conduct a review of issues related
to screening criteria and procedures for radioactive waste materials at Superfund sites,
using the Industrial Excess Landfill Superfund Site in Uniontown Ohio as a test case.
The SAB established an ad hoc panel to conduct this review. In general, at
hazardous waste sites where radioactive contamination is suspected, EPA first
performs a screening round of sampling. If the screening round data indicate that
there is a problem, the Agency performs more extensive investigations. If the
screening round data indicate no radiological contamination, further radiological testing
is eliminated. What kind of sampling and analytic protocol is adequate to determine
the presence/extent of soil and groundwater contamination at a site which may
incorporate radioactive wastes? The specific items of the Charge were:
a) For screening purposes, what types of temporal and spatial sampling and
analyses are sufficient to test a hypothesis that radioactive contamination is
present?
b) What radiological parameters, e.g., gross alpha plus alpha spectrometry,
gross beta, gamma spectrometry, tritium, and carbon-14, are sufficient to
determine the possible existence/extent of potential sub-surface radiological
contamination? Are the methods employed by EPA for analysis of radioactive
contamination adequate and appropriate for analyses of samples from
hazardous waste sites?
c) There are generic guidelines for sampling and analytic methods and chain of
custody protocols to ensure that cross contamination or tampering with samples
does not occur when dealing with radioactive contaminants. If appropriate,
these guidelines may be modified on a site-specific basis depending on the
characteristics of the site in question. What modifications are scientifically
justified while still assuring accurate, precise and valid data?
d) What factors need to be considered in the development and application of
data validation criteria for evaluation of radioactive contaminants at hazardous
waste sites?
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e) What practices and organizational changes could lead to improved credibility
for the U.S. EPA and constructive public participation at hazardous waste sites
with potential radioactive contamination?
To address this charge, the ad hoc Panel reviewed a specific site where sub-
surface radioactive contamination could be present, the Industrial Excess Landfill (IEL)
Superfund site in Uniontown, Ohio. Citizens residing near the IEL site were
concerned that radioactive wastes had been illegally disposed at the site.
Administrator Reilly tasked Mr. Thomas Crumbly, President of Clean Sites, Inc., to
perform an independent evaluation of the Agency's management of the IEL site, with
emphasis on the radiation sampling being conducted. His report (Crumbly, 1992)4 to
the Administrator contained several recommendations. With respect to radiation
sampling, Crumbly recommended that the Agency request that the Science Advisory
Board (SAB) perform specific tasks to resolve data analysis issues at the IEL site.
Although these issues arose from this one site, they are of concern to other Superfund
sites at which radioactive contamination is suspected and could be used to develop
generic guidelines for dealing with such sites. Past, present, and anticipated activities
and data collected at this location were used as source materials for the ad hoc Panel
in its deliberations.
2.2 Panel Review Process
On July 27, 1992, the Science Advisory Board was asked by Richard Guimond,
Deputy Assistant Administrator for the Agency's Office of Solid Waste and Emergency
Response (OSWER) to consider a review of radiological sampling and data validation
issues at Superfund sites where contamination by radiological wastes is suspected.
To do this, Mr. Guimond asked that the Board conduct a site-specific review using the
Industrial Excess Landfill (IEL) Superfund Site in Uniontown, Ohio. After discussion,
the Board agreed to take on this site-specific review as a test case to determine if
such reviews were a good use of the Board's resources and if such a review could
provide useful input to the Agency's management of Superfund sites in general. The
Board formed an ad hoc subcommittee to perform this review, using several SAB
Members and Consultants with pertinent expertise.
The Panel held three public meetings. The first was held in Akron, Ohio on
July 20-21, 1993. This was a two-day meeting with an evening session on July 20th
devoted to public comment. Although public comment at SAB meetings is normally
Report to the Administrator United Stated Environmental Protection Agency - Concerning the Industrial Excess
Landfill Superfund Site, Uniontown, Ohio. Thomas P. Grumbly, President, Clean Sites, Inc. March 4, 1992. 38 p.
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arranged in advance of the meeting, this public comment period was designed (and
advertised) to permit walk-in commentors. A total of four members of the public
provided comments. The bulk of the meeting was devoted to presentations by
representatives of the US Environmental Protection Agency (USEPA), Ohio
Environmental Protection Agency (Ohio EPA) and the Agency for Toxic Substances
and Disease Registry (ATSDR) concerning site background and procedures used.
The second meeting was held in Washington, DC on September 21-22, 1993.
The primary purpose of this meeting was to lay out the volumes of material (data,
procedural documents, correspondence, comments, etc) concerning the IEL site so
that the Panel members could review them publicly and obtain guidance from USEPA
and Ohio EPA Staff concerning the materials. The public was also invited to
participate and did so actively. Following this meeting, Panelists were provided with
copies of those documents they identified as requiring further study. The Chairman
assigned questions from the Charge to each panelist for discussion at the next
meeting.
The third meeting was held on December 14, 1993 in Uniontown, Ohio. This
meeting was designed to obtain additional public comment and to discuss responses
to the questions in the Charge.
In January 1994, a working paper describing the responses to the Charge was
developed by the Chairman and SAB Staff based on comments provided by the
Panelists. A brief discussion of the progress of the project was presented to the SAB
Executive Committee at its public meeting on January 27, 1994. A telephone
conference link at that meeting was provided for the USEPA Region V, Ohio EPA and
the Concerned Citizens of Lake Township (CCLT), a local citizens group from the
Uniontown, Ohio area. The Executive Committee reviewed the final draft report of the
ad hoc Panel subsequently through its vetting process (that is, by appointing a subset
of its members to review and approve, on behalf of the Executive Committee, any
subsequent edits to the final Panel report).
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3. RESPONSE TO THE CHARGE TO THE dd hoc PANEL
3.1 Temporal and Spatial Sampling and Analyses
Charge Question a): For screening purposes, what types of temporal and
spatial sampling and analyses are sufficient to test a hypothesis that
radioactive contamination is present?
3.1.1 General Findings
There are three principal types of studies that can be conducted to test for the
presence of radioactive contamination at landfills: a) ground surveys; b) ground water
monitoring; and c) soil coring studies.
a) Ground Surveys - Ground surveys involve a walkover of the site with simple
monitoring equipment, such as a scintillation or a Geiger-Mueller counter, to
check for gross radiation emissions. This type of survey is only effective for
detecting significant radiation sources near the surface, typically in the top
several inches (depending on the amount of radionuclide present and the
characteristics of radiation emitted). It is likely to miss contamination which is
buried at greater depths. Despite this high "false negative" characteristic of the
ground survey, it should be conducted at all suspect sites since it is relatively
quick and inexpensive, and can identify major, near surface contamination.
Thus, while a negative ground survey (i.e., one that detects no radiation) does
not preclude the presence of radioactive material at the site, it is a worthwhile
first step in any investigation.
b) Ground Water Monitoring - Ground water monitoring involves sampling
subsurface waters at or near the site to test for the presence of gross radiation
and/or specific radionuclides. Therefore It can be used to assess the presence
of radioactive contamination in a landfill, so long as this material is leaching into
the ground water at the site and the resulting concentrations in monitoring wells
are high enough to be distinguished from background levels. Ground water
monitoring is particularly appropriate for testing whether there has been any
off-site migration of radioactive material from a landfill that could lead to
exposure of the surrounding population.
Two approaches can be taken to sampling ground water for the presence
of radionuclides, involving different temporal and spatial strategies. The first is
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the standard approach for ground water monitoring at Superfund sites, whereby
a number of fixed monitoring wells are placed at locations in the aquifer,
upgradient and downgradient of the site. Wells are sampled on a periodic
basis, typically once every three months. This type of routine ground water
monitoring program is designed to test for long-term, major impacts on the
aquifer. The second approach involves specific studies designed to search for
possible radioactive contamination when and where it is more likely to occur.
For instance, monitoring during, or immediately following, storm events could
detect intermittent contamination as it is mobilized and transported. These
studies can focus on particular locations near the site where surface or
subsurface water is present that has recently traveled through the landfill such
as springs or seepage points along slopes down-gradient from the landfill.
These types of special study have not normally been conducted at Superfund
sites, but have been proven effective in identifying sources of contamination at
sites with known radioactive waste problems.
c) Soil Corinqs - The third general approach for identification of radioactive
contamination at landfills involves soil corings. Borings are drilled into the
landfill on a predetermined grid or using a directed search strategy. The soil
corings and/or landfill gases in the borehole are tested for gross radiation and,
if necessary, specific radionuclides. Soil coring studies are directed at
determining whether, radioactive materials are present in the landfill, rather than
whether off-site migration has occurred. If radioactive materials are present in
small, confined volumes, it is difficult to detect their presence unless a dense,
often prohibitively expensive search grid is used. If however, radioactive
materials are present in a more diffuse (e.g., horizontally spread) pattern, then
relatively rapid and efficient detection can be expected. A negative result in a
soil coring study can thus be used to preclude the presence of such a diffuse,
wide spread waste, but not the presence of a small, confined waste.
3.1.2 Adequacy of Information to Characterize Background Concentrations at
the IEL Site
Prior to considering the adequacy of the information used to establish
background concentrations of radionuclides and indicators of radioactivity in ground
water for comparison with measured values at IEL, it is important to recognize the two
principal, but very different reasons for making such a comparison. The first is to
determine whether the measured levels of radioactivity at IEL are significantly different
from those found at other locations, and as a result of this difference, pose a public
health concern. The second is to determine whether there is any evidence that
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leakage from the site has impacted the local ground water, resulting in concentrations
that are measurably higher than would have been present had the site never existed.
The principal information presented by the Agency to establish ground water
background concentrations include data from:5
a) The USGS Regional Aquifer System Analysis (RASA) database, which
includes a number of samples from northern Ohio.
b) The US Geological Survey's (USGS) intensive studies of ground water in
Lucas, Sandusky, and Wood counties, located in northwestern/ northcentral
Ohio; and
c) The US EPA National Inorganics and Radionuclides Survey (NIRS), which
addresses radionuclides in water supplies taken from ground water, including
27 samples from Ohio;
d) The US EPA Environmental Radiation Ambient Monitoring System
(ERAMS), which represents data from finished drinking water systems,
including five sampling stations in Ohio;
Since none of these datasets involve samples from the groundwater from near
the IEL site, they can be used as part of a public health evaluation, but not for
rigorously determining whether leakage from the IEL site has affected the local
aquifer. To provide an indication of whether ground water monitoring wells at IEL are
detecting levels of radioactivity significantly higher than would have been measured
had the landfill not existed, background data are needed that can serve as an
estimate of, or surrogate for, this "no-landfill" condition. This can only be
accomplished using data sampled from the local ground water aquifer, close enough
to ensure that the same geologic formation is captured, with similar soil and rock types
contributing to the natural radioactivity, yet far enough away to ensure that the
background wells are not themselves impacted by leakage from the site. This is not
an easy task, and multiple wells are required to capture and determine the magnitude
of the natural variability from one location to another, and to allow an assessment of
whether levels in one or more of the background wells are too dissimilar to those in
the rest of the assumed background set to safely ascribe this difference to natural
variation. If so, consideration can then be given to the decision to remove the
suspected wells from the background set, and initiate further studies to determine
5 See items 18.b), 18.c), 18.d) and 18.e) of the USEPA listing in Appendix A.
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whether leakage from the site may have in fact reached these locations. To provide
this type of information and flexibility for sequential evaluation and reassessment, at
least four or five (though preferably on the order of 5-10) background wells are needed
at intermediate and varying distances from the site. To the extent that the regional
ground water flow is adequately characterized, the large majority of the background
wells should be located upgradient of the site (a few background wells may be located
downgradient, though at significant distances from the site).
The ground water monitoring plan for the IEL site currently includes two well
clusters designated as background monitoring wells (MW): MW20, immediately east of
the Metzger Ditch boundary, screened at shallow, intermediate, and deep depths; and
MW12, approximately 1000 feet north of the northeast corner of the landfill, screened
at intermediate and deep depths. Even if the ground water flow patterns at the landfill
were simple and predominantly from east to west, these two wells, alone, would not
be adequate to characterize the mean and variability of background radionuclide
concentrations for estimating the "no-landfill" condition, based on the criteria given
above. Given the complex, partly radial nature of ground water flow at the IEL site, as
described in the recent USGS report (USGS, 1993)6, the two wells are clearly
inadequate for characterizing background7. Data from MW20 are particularly suspect,
given the site flow patterns and immediate proximity of the well to the site8. Data from
MW12 may be appropriate for inclusion in the background dataset, but this could only
be determined through collection of data at a number of other offsite wells which are
located at different orientations and distances relative to the site. A reliable,
scientifically credible characterization of the mean and variability of the background
radionuclide conditions at the site, for comparison with data collected within and
immediately adjacent to the site, will require such a larger dataset. It may be possible
to gather such data from existing residential wells.
Currently lacking an adequate background dataset at the site for rigorous
comparison with the monitoring well samples, the previously cited datasets can be
used for a preliminary evaluation and exploration of public health concerns. ERAMS
6 United States Geological Survey (USGS), Water Resources Division, 975 West Third Street, Columbus, OH 43212-3192.
Report to Ms. Linda Kern, Remedial Project Manager, Region 5, USEPA. Review of water-level data and interpretations by PRO
Environmental Management, Inc., in two reports: (1) Draft Ground Water Modeling Report, Industrial Excess Landfill Site, Uniontown,
Ohio (U.S. EPA, 1992), and (2) Preliminary Remedial Design • Industrial Excess Landfill Site, Uniontown, Ohio, Draft Report, Volume
I, Chapters 1-10 and Appendix A (U.S. EPA, 1993). Document dated August 13, 1993.
7Due to site constraints which prevented installation of additional background monitoring wells, MW 12 and MW20 were
supplemented with two irrigation wells east of the IEL landfill and several residential wells some distance from the site.
3 The usability of the MW20 cluster and other off-site wells for both chemical and radiochemical background data will be
discussed by the Technical Information Committee and decided based on the conclusions in USGS (1993).
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provides an extensive data base on radioactivity in drinking water. While some are
near nuclear facilities, others are not. Comparing the radioactivity levels in the
residential wells around the IEL site to the levels observed in ERAMS, there is no
evidence of unusual concentrations in the residential wells. There are occasional
slightly elevated readings, in monitoring wells, most often in the gross beta counts at
shallow depths. However, the average of all gross beta counts at shallow monitoring
wells is 10 pCi/L, which is not out of range relative to the ERAMS data. In comparing
ERAMS data to IEL data, it is important to note that the ERAMS figures are averages
of data over four quarters. Therefore, they are less likely to show occasional high
values than the measurements on single samples such as available at IEL. One well,
#14S, does have somewhat elevated beta counts during all four rounds, although the
observed levels are not at all alarming as the counts are not high relative to possible
background levels.
The information provided by EPA does not address radioactivity in suspended
sediment, so it is more difficult to address whether or not the levels observed in the
filtrate are within background levels. There is one high reading at monitoring well #4S
during the May 1992 round of measurements. The gross beta reading is 358
pCi/sample or a 157 pCi/gram, which in either case makes it the highest observed
value. With the information at hand, one cannot say whether or not these values
should be considered unusual. Certainly they are not evidence of substantial
radioactive contamination (i.e., a consistent pattern, continuous in time and space, of
concentrations that are well (>2 standard deviations) above the detection limit or
regional background, whichever is higher).
There was one extremely high tritium reading of 1 x 106 pCi/L reported once at
a residential well, which is 50 times the current Federal drinking water standard.9 This
reading, if correct, could not plausibly be due to background radiation. However,
repeated retesting of the water from this well has failed to produce any high tritium
levels, which suggests that this anomalous measurement was faulty.
While no other tritium measurements were above the drinking water standard,
there were several other measurements that were somewhat elevated, and while not
direct evidence for harmful levels of radiation, could be viewed as evidence of past
radioactive contamination. When considering whether the occasional elevated
measurements provide evidence of radioactive dumping, it is essential to consider how
often such measurements would be obtained if there had been no radioactive dumping
at the site. Many hundreds of radiation measurements have been made on IEL water,
9 The current Federal Drinking Water Standard for tritium is 20,000 pCi/L.
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and considering the difficulties in measuring radiation accurately, the observed level:.
do not support the contention of past dumping of radioactive waste.
We offer several suggestions in future Superfund site characterization activities.
The Panel heard that there is no mechanism for lessons learned at one site to be
widely disseminated to other sites. The obvious outcome will be a repetition of errors
whether in approach or interpretation. With the current trend toward increased public
participation in decision-making on environmental management issues, agencies such
as EPA need to learn from errors and incorporate those lessons into future efforts.
It is the Panel's feeling that site characterization guidance by EPA should be
more process oriented and less prescriptive. A sense of reliance on procedures and
prescriptions has pervaded the presentations to the IEL panel. Site characterization
planning and conduct should be based on iterative examinations of the site dynamics.
Hydrogeology at the IEL site does not appear to be especially complex.
Eastward flow from the site toward Metzger's Ditch should be expected at some
elevation from even the simplest examination. A topographic map would suggest that
any surface flow that occurred would be eastward. Interflow (lateral flow in the
unsaturated zone during periods of high infiltration) could be presumed to follow the
surface contour. An eastward slope to the water table shown by USGS (1993) implk .;
some eastward flow even in the saturated zone. Characterization ought to address
the lateral extent of such flow (e.g., does it terminate at Metzger's Citch?) and the
depth to which it occurs. Screening for the presence of radioactive contaminants
should have included sampling of seeps along the west bank of Metzger's Ditch
adjacent to the IEL site.
3.1.3 Adequacy of Methods used to Evaluate the Effectiveness of Possible Cor;
Sampling and Ground Water Monitoring Programs
The methodology used by the Agency to assess the potential of a core
sampling program to detect radioactive contamination was evaluated by reviewing
documents which were attached to letters sent to Senator John Glenn by EPA Region
5 Administrator Valdas Adamkus (EPA, 1990; EPA, 1991).
One of these documents (EPA, 1990) examines the probability of detecting a
10-cubic yard waste source as a function of the number of corings. In this exercise, it
is assumed that the probability that each core detects the radioactive waste is equal to
this 10-cubic yards divided by the volume of the landfill. The detection probability for
many corings is then computed from the binomial probability, assuming each coring is
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independent. The coring program is thus assumed to be random, and completely
nonsequential. The resulting calculations indicated only a 0.22 probability of detection
with 50,000 boreholes. The technical assumptions of this calculation are wholly
inappropriate for a real core sampling program, and the estimate is thus flawed. The
problem with this calculation is the assumption that the ratio of volume of
contaminated waste to volume of landfill gives the probability of a single core
containing radioactive waste. The problem with this assumption is that it attempts to
calculate this probability without making any assumptions about the geometry of the
waste. It is easy to see that such an approach is doomed to failure by comparing two
possible configurations of a given volume of waste. In the first, suppose the waste is
spread out over a thin horizontal layer. In this case, it would be relatively easy to
detect it with vertical boreholes. On the other hand, if the same volume of waste is
located within a narrow vertical shaft, then it is obviously much harder to detect. For
example, suppose there is a single source that is literally a cube with volume 10-cubic
yards and one face parallel to the ground. Then a triangular lattice of boreholes
spaced 2.15 yards apart will necessarily intersect the source. To cover 30 acres in
this manner requires about 36,000 boreholes. Suppose, however, that this same 10-
cubic yards of waste is in the shape of a box with vertical dimension 0.1 yards and
other dimensions of 10 yards. Then a triangular grid spaced 10 yards apart will
necessarily intersect the waste. Such a grid requires about 1670 cores. When the
source, if one exists, is assumed to be in a particular section of the landfill, then the
number of holes required goes down proportionately.
On the other hand, the calculations reported on in the middle of page 2 of EPA
(1990) are much more appropriate. However, even these seem somewhat
pessimistic. Consider detecting a single unshielded source. If bores are put on a
triangular lattice, which is the most efficient possible, then to ensure that every point in
a 30-acre plot is within 4 feet of the center of a borehole requires about 31,000 holes.
Since an unshielded source must have some physical extent and the borehole itself
has a positive width, using the 4 foot distance is reasonable. Even so, the cost of
31,000 boreholes, in dollars, time and possible exposure to toxic chemicals of field
workers and nearby residents, would be unacceptably high compared with the
alternative strategy of ground water surveillance.
It is obvious that the ability to detect a radiation source by coring depends
critically on the horizontal extent of the source. !t is true that a single shielded source
of little horizontal extent would be difficult to find even if one had a general idea as to
where such a source might be. However, even a moderate amount of horizontal
spreading of the source makes the detection problem much easier.
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A second report on ground water monitoring (EPA, 1991) is more detailed and
complex, using ground water models to evaluate the likelihood of plume detection. On
the basis of the studies presented in this reference, EPA concluded that, "U.S. EPA is
confident that the extensive groundwater and soil gas testing that is planned at IEL will
identify any contamination that may exist at levels of concern." However, the studies
show no such thing. What they show is that under some range of assumptions about
the nature of the contamination and using a simple model for the hydrogeology of the
site, that the exposure of any one individual will be very small. They also show that
under these same assumptions, the chances of the network of wells detecting
radiation from radioactive waste at the site may not be large. It certainly does not
follow that the network of wells would detect the radiation with high probability if
enough waste had been dumped to cause a threat to human health. This may in fact
be true, but the analyses presented, even if correct, are only indirectly related to this
question of interest.
The reports themselves have serious problems. In particular, Section 5 of the
follow-up Final Report on the Probability of Detection of Hypothetical Radiochemical
Contamination of Groundwater at the Industrial Excess Landfill (PRC, 1991)10 is in
error. Specifically, the assumption that the event of one well overlapping the plume
being independent of the other wells overlapping the plume is incorrect. It is easy to
visualize this by looking at Figure 2 of that document and noting that if the plume
overlaps MW-18 it cannot overlap MW-6. Moreover, it is straightforward to do the
correct calculation that takes into account this lack of independence by directly
calculating the fraction of the time the plume overlaps at least one monitoring well.
The effect of this error is to give a lower probability of the wells detecting the radiation
than would the correct calculation.
Another problem with this study (PRC, 1991) is that the probabilities are based
on what might happen at a single point in time, rather than what would happen over
some schedule of monitoring times. The effect of using a more realistic monitoring
schedule is unclear. If there are multiple releases or if the interval between monitoring
times is small relative to the movement of the plume, the model used in EPA (1991)
could underestimate the probability of detection. Again, it would have been straight-
forward to do a simulation study that would have taken into account possible
monitoring schedules.
10 PRC, 1991. Final Report on the Probability of Detection of Hypothetical Radiochemical Contamination of
Groundwater at the Industrial Excess Landfill - Uniontown. Ohio. March 11, 1991. Prepared for the U.S. EPA by PRC. Submitted
as an attachment to EPA (1991).
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The part of this study (PRC, 1991) that attempts to model total exposure of an
individual is hard to judge because of its critical dependence on assumptions about
the nature and amount of radioactive waste. However, unless the estimates of
possible levels of radioactive waste at the site are much too low, it is hard to see how
the simulated exposures could be off by more than an order of magnitude or so. One
possible problem is that for a highly mobile radionuclide, a slow and steady release
could lead to a considerably higher lifetime exposure than an instantaneous large
release. However, since the simulated exposures in excess of background are small
in comparison to the background exposures, the threat to human health is likely to be
negligible if levels of contamination are as low as presumed in this study. The Panel
recognizes that both of these reports are based on a large number of assumptions
that have not been validated for the IEL site.
In summary, the studies EPA (EPA, 1990; EPA, 1991) carried out to support
ground water monitoring rather than coring are poorly done and should not be used as
models for future studies. Nevertheless, for a coring program to have a substantial
probability of detecting radioactive contamination not found by ground water
monitoring, it is necessary that the radioactive waste has considerable horizontal
extent, but does not contaminate the ground water during the times ground water
monitoring is done.
3.2 Radiological Parameters
Charge Question b): What radiological parameters, e.g., gross alpha plus
alpha spectrometry, gross beta, gamma spectrometry, tritium, and
carbon-14, are sufficient to determine the possible existence/extent of
potential sub-surface radiological contamination? Are the methods
employed by EPA for analysis of radioactive contamination adequate and
appropriate for analyses of samples from hazardous waste sites?
The set of radiological parameters identified in the charge is appropriate and
sufficient for screening surveys. In addition, all available information should be
reviewed to determine if specific radionuclides might reasonably be expected at a site.
Obviously, if it is known (or there is adequate reason to suspect) that particular
radionuclides have been disposed of at a site, analyses for those contaminants should
be conducted. In cases such as IEL where there was no indication of the presence of
specific radionuclides, the use of the set of screening analyses listed in the charge
was appropriate.
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3.2.1 Laboratory Analytical Methods
a) Gross alpha analyses are relatively rapid and low-cost. They are
semi-quantitative methods that will detect unusual levels of high atomic weight
radionuclides from both naturally occurring and anthropogenic sources.
Principal naturally occurring nuclides are the isotopes of uranium and thorium,
and radium-226. The most commonly encountered anthropogenic alpha
emitters in the environment are isotopes of plutonium, Pu-239 and Pu-240 from
atmospheric weapons tests and Pu-238 from reentry and atmospheric burnup cf
an isotopic power source. Americium-241 is also present in global fallout as a
product of plutonium-241 decay. All of the alpha emitters identified above occur
in the global environment so that there is a "background" level to be expected.
b) Alpha spectrometric analyses to determine which specific alpha emitters are
present are both quantitative and labor-intensive, hence expensive. Such
analyses are poor screening tools but form a very important adjunct to the
gross alpha analyses. Where gross alpha results exceed a previously selected
threshold, alpha spectrometry should be applied. Identification of specific alpha
emitters is important a) to assist in the recognition of excess contamination and
its sources; and b) for radiological risk assessment.
c) Gross beta analyses are also relatively rapid and low-cost, semi-quantitativs
methods that will assist in detecting the presence of a large number of
radionuclides that are not found by gross alpha measurements. Common
naturally occurring beta emitters include radium-228 and potassium-40.
Anthropogenic beta-emitters in the environment are the fission products from
atmospheric weapons tests and include cesium-137, strontium-90, and others.
Where gross beta results exceed a previously selected threshold, an evaluation
should be carried out to determine the principal contributors to the high value.
Results of gamma-ray spectrometry may identify the contributors (e.g.
cesium-137) or specific radionuclide analyses may be required for beta-emitters
that do not reveal themselves by emitting gamma-rays (e.g. strontium-90).
d) Gamma-ray spectrometrv is a relatively low-cost quantitative method
suitable for screening for a large number of radionuclides and can be applied to
large-volume samples. Naturally occurring environmental radionuclides typically
identified by gamma-ray spectrometry are potassium-40, members of the
uranium and thorium decay series, and beryllium-7 produced in the atmosphere
by cosmic rays. Anthropogenic gamma-emitters that are widespread are
cesium-137 and cobalt-60. More rarely gamma spectrometry will detect
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cesium-134, iodine-131, manganese-54, and antimony-125. Computer-based
data reduction methods in general use for gamma spectrometry, when applied
to environmental samples, can result in a large number of tentative radionuclide
identifications (false positives). Naturally occurring gamma emitters produce
gamma rays at energies that may lead to these tentative identifications but
analysts familiar with environmental samples can identify the interferences.
Therefore, it is exceedingly important that an experienced analyst participate in
the data verification and validation to ensure that proper qualifiers are affixed.
e) Tritium and Carbon-14 analyses are appropriate as screening methods
because tritium and carbon-14 are relatively common radionuclides and none of
the preceding tests will indicate their presence. Each of them has a naturally
occurring background level which has been significantly elevated by global
fallout. Tritium and carbon-14 are also candidates for screening gas-phase
samples since they may be present in gaseous components such as water
vapor, tritium gas, or organic compounds. In fact, gas-phase monitoring can be
an extremely sensitive test for the presence of these nuclides.
3.2.2 Analytical Methods and Procedures
The analytical methods identified by EPA for radionuclide analyses at
hazardous waste sites are time-tested and appropriate. Some of the documentation
on procedures presented to the ad hoc Panel, however, is several years old and
sometimes does not reflect recent advances. Therefore, we recommend that EPA
remain cognizant of, and responsive to, advances in radiochemical procedures and
analytical technology as they may apply to the characterization of hazardous waste
sites for radiochemical materials. An interagency approach involving EPA, DOE, and
possibly the Department of Defense (DOD) might be appropriate.
Radiochemical analyses, although potentially highly reliable and accurate,
require painstaking attention and effort from the analyst. For such analyses to be
reliable it is necessary that the analyst be trained and experienced not only with the
procedures and instruments being used but also with the matrix types (soil, water,
tissue) being analyzed. Experienced analysts are familiar with specific interference
problems and can either avoid them or at least recognize and make qualifying
notations.
Data reporting for radioactive components should include the propagated
counting error terms identified either as 1-sigma or 2-sigma level of confidence. Good
practice reporting also includes the minimum detectable activity (MDA) value for the
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nuclide and sample. Consideration of these confidence parameters is essential to any
responsible interpretation of results and either reporting or interpretation that does not
take the confidence estimates into account should be discounted as not credible.
3.2.3 Field Sampling and Analytical Methods
Sampling protocols and media need to be defined after the purpose for
screening is clear. It is essential that the goals of the screening be clearly established
and agreed upon in the earliest stages of planning. Whether to filter water samples or
not depends on the questions posed for the screening test. For example, filtered
waters will provide the best estimate of transport of contaminants by water. If direct
personnel exposure is of greater interest, unfiltered tap water is probably more
appropriate to analyze. On the other hand, unfiltered water samples taken from
unlined wells are likely to contain large volumes of suspended matter that does not
represent either transport or personnel exposure. To detect the presence of
contaminants that are very insoluble, such as thorium or plutonium isotopes, analyses
of particulate phases are much more sensitive than analyses of filtered water.
If samples are to be filtered and analyses of the material that is filtered out are
to be made, it is important to record the volume of water passed through the filter and
to determine the dry weight of the collected solids. It should be assumed that
investigators examining the data will want to be able to compute particle bound
radionuclide concentrations both per unit volume of water filtered and per unit mass
collected on the filter. Investigators must exercise caution to ensure that comparisons
among samples are made on like samples, that is filtered water to filtered water, etc.
The failure to record the volume of water passed through the filter and the dry weight
of collected solids for filtered samples at the IEL site was such that a full accounting of
the dissolved and particulate concentrations of radioactive constituents could not be
made. This should be corrected in the future.
3.3 Guidelines for Sampling and Analytic Methods
Charge Question c): There are generic guidelines for sampling and
analytic methods and chain of custody protocols to ensure that cross
contamination or tampering with samples does not occur when dealing
with radioactive contaminants. If appropriate, these guidelines may be
modified on a site-specific basis depending on the characteristics of the
site in question. What modifications are scientifically justified while still
assuring accurate, precise and valid data?
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3.3.1 Considerations for other Superfund Sites in tr/3 Future
The experience at the IEL site is an indication that the standard procedures
used for Superfund sites in terms of site characterization are inadequate in the face of
concerns of the surrounding community. With the hindsight of the IEL experience it is
possible to suggest measures that could have dealt with situations where there is
concern about possible radioactivity on site.
Very early in the characterization of a Superfund site it is recommended that a
surface monitoring be undertaken using a survey monitor. At other sites (Love Canal)
measurements were made at 10 meter or 20 meter centers, recorded in
microrads/hour. For example, at Love Canal values between 6 and 40 microrads/hour
were recorded, and a few soil samples exceeded background levels of cesium-137
levels of 30 pCi/gram. Even though a surface survey will not detect radioactive
material at depths greater than a foot or so, it will provide a helpful record of the
pre-remediation state.
During the remedial investigation one round of gross alpha and gross beta
activity in the monitoring wells at the time the wells are investigated for other
constituents would serve to establish whether special radioactive deposits exist. For
this first determination, the drinking water protocol as used at IEL for the residential
wells, without separate determination of the activity in suspended solids should suffice.
The cores collected at the time of the development of monitoring wells should be
subjected to a simple radiological survey, and the results should be made a part of the
remedial investigation record. Such survey monitors are used whenever radioactive
materials are used in a laboratory.
In the case of the Industrial Excess Landfill, much of the concern of the
surrounding community has been focused on the possibility that unknown amounts of
radioactive materials may have been deposited at some time during the active
operation of the landfill. This concern has resulted in considerable efforts to
characterize the landfill in terms of the levels of radioactivity on-site and in the
immediate surroundings. Routine measurements were made of the levels of
radioactivity in the boring cores of the monitoring wells to assure the radiological
protection of the field personnel, and a number of rounds of samples of water at
different depths in the monitoring wells were analyzed. Analyses were made for gror,;
alpha and beta activity, as well as tritium and carbon-14 activity. Where higher
activities were encountered the contributions by a number of specific isotopes were
determined with alpha and gamma spectroscopy. The initial rounds of sampling and
analysis suffered from imperfections in the chain of custody of the samples and
23
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questions about counting methodologies, and these imperfections led to the
invalidation of the results from these initial rounds.
In retrospect it would have been desirable if the processes of contracting and
validation had been better coordinated. The appropriate use of protocols designed
specifically for drinking water characterization for the characterization of a hazardous
waste site also has led to confusion. Once a breakdown in the chain of custody
occurs it is often difficult to ascertain precisely where the breakdown occurred, and it
becomes difficult to rely on the results of such a study. From the records of the early
rounds of IEL testing it is not always possible to determine from which well and at
what depth a sample was drawn. Based on our observations, it is extremely unlikely
that samples from another site found their way into the analysis of the first rounds.
Nevertheless, any unusual findings could not be interpreted with confidence, nor could
they be compared with values in another round of sampling. It is also not possible to
determine whether any unusual values were lost in the early rounds. The invalidation
decision thus becomes necessary and inevitable when breakdowns in the chain of
custody occur, and USEPA was correct in invalidating such rounds. It should be
noted that although the first rounds could not be validated, the round that was
available for review did not contain any readings that were so high as to give reasons
for serious concern.11
3.4 Criteria for Data Validation
Charge Question d): What factors need to be considered in the
development and application of data validation criteria for evaluation of
radioactive contaminants at hazardous waste sites?
The goal of any quality-oriented measurement program is to establish credibility
and to maintain the quality of results within established limits of acceptance. A good
laboratory that provides services of high integrity will gain customer and public
confidence. Meaningful and reliable results generated by the laboratory will also be
legally defensible in a court of law. In order to achieve the goal of obtaining quality
data, verification and validation must be carried out for the sample collection, analysis,
and measurement processes.
Only one complete round of invalid results were available for review (December 1990 data from Controls for
Environmental Pollution). The only results that were available for review from the August 1990 round of invalidated data were the
carbon-14 results. The other results df the August 1990 round were returned to the laboratory after the data was declared invalid
by EPA.
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3.4.1 Recommendations for Verification
a) The Agency shall verify that ALL contractual agreements, as outlined in the
"Statement of Work" are in compliance for a given project. It is essential to
verify that the Performance Evaluation (PE) samples for the radionuclides-
of-interest for the desired matrices are performed by the vendor laboratory and
that the reported results on the PE samples are well within the agreed upon
limits of accuracy and precision.
b) A pre-award audit of the laboratory shall be done by a team of auditors
(including a radiochemist and a Quality Control (QC) specialist) before a
contract is initiated.
c) The Agency shall verify that the !ab is consistently performing well by
submitting to the lab blind samples with known quantities of spikes disguised as
real samples unknown to the lab, and by reviewing the results on a periodic
basis.
d) The laboratory providing radiochemical analysis services must use
agreed-upon and approved Standard Operating Procedures (SOPs) . The lab
must also use software that is verified and validated and documented for
approved instruments. Calibrations of equipment are performed using National
Institute of Standards and Technology (NIST) traceable reference radionuclide
standards. The laboratory shall also meet the prescribed Minimum Detectable
Activity (MDA) for each radionuclide.
3.4.2 Recommendations for Validation
a) Radiochemical analysis data are validated by reviewing the results from
planning stages through sample collection, logging in, receiving, sample
preparation, analysis, radiation measurements, calculation of results with
associated propagated errors, and documentation.
b) Results of a given batch of samples should be reviewed along with quality
control samples (QC spiked samples, blanks, duplicates, blinds, etc.) for
contractual requirements and technical correctness to validate the results.
c) If corrections are made, add qualifiers to the data and document. If results
are rejected, a statement of explanation must be included in the document as to
why the results are rejected.
25
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d) Finally, ALL data must be reviewed to ensure that the data are of the !
of accuracy and precision required, defensible, and complete.
3.5 Communicating Risk
Charge Question e): What practices and organizational changes could
lead to improved credibility for the U.S. EPA and constructive public
participation at hazardous waste sites with potential radioactive
contamination?
Good risk communication practices are vital to effective Superfund site
management. Broadly construed, such practices entail: a) establishing an
organizational structure that enables all stakeholders to inform, be informed and be
knowledgeable of the risk assessment and management process; b) establishing
some shared understanding of the goal of the risk assessment and management
process; c) recognizing and respecting differences in language and searching for a
common understanding of the site characterization; d) clearly specifying and agreeing
on who has the authority and responsibility to make final decisions; and e) designating
and agreeing on how differences will be arbitrated should that be necessary. In Mr.
Grumbly's words, USEPA needs a credible process, without which little can be
accomplished.
A detailed evaluation of how the communication of risks did or did not occur in
the IEL situation serves to point out the weaknesses of the Agency's risk
communication process and how it may be improved. At IEL, both differences in prior
knowledge and expectations about the site, as well as disagreements about how to
interpret new information have contributed to conflicting judgments about risk, and
consequent differences in opinions among various stakeholders about appropriate
management of the site. Conflicts are likely to continue until the public and the
Agency find some common ground.
3.5.1 Information
In 1990 the EPA established the IEL Technical Information Committee (TIC) as
part of the Record of Decision (ROD) for the IEL site to ensure the continued active
participation of the community in the characterization and remediation of the site.
Members of the TIC include local clergy, local elected officials, representatives from
the Concerned Citizens of Lake Township (CCLT) and their technical experts,
members from the community at large, representatives for the potentially responsible
parties, and members of the various agencies involved at the site. Although, the TIC
26
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has met at least 13 times, the Panel cannot judge 'he breadth of participation by the
public or various groups of the TIC. The Agency has also provided two Technical
Assistance Grants (TAG) totalling $100,000 to CCLT to fund the hiring of technical
experts, become educated on the issues, provide the financial resources to inform and
solicit opinions and support from of the community at large, and impact the
decision-making process at the site. In spite of these efforts the citizens do not
consider that their concerns have been adequately considered and dealt with.
In 1989 the Agency for Toxic Substances and Disease Registry (ATSDR)
recommended that a computerized system for storage, retrieval, and spatial analysis
of all pertinent environmental and demographic information gathered at IEL be made
available for use by all interested parties (ATSDR, 1989). In communicating with the
interested parties, it is important to present the raw data in an aggregated manner that
is clear and understandable so as to provide comprehensive insights into site
implications. Even ira the case of the Panel, it was only during the latter portion of it's
review that the IEL sample data was available in a format that was relatively easy to
use.12 Graphic information and clearly labelled tables including the relevant standards
and background (comparison) information are very useful. This kind of system should
be provided at all sites, if feasible, from the time that data are first collected. Use of
such a system (on a personal computer) could be facilitated at advisory committee
meetings, or by appointment with the EPA site manager. Such a system would also
enable EPA to more easily prepare and produce graphic and tabular data
presentations for the community.
USEPA needs to address what people know and what they need and want to
know. Crumbly (1992) states clearly in his report13 that EPA has been slow to
respond to legitimate concerns from the community around IEL. He attributes this to j
desire in the beginning to treat IEL as a standard site with a standard solution.
Subsequently, EPA has been more responsive to the Uniontown community.
According to Grumbly (1992) "Almost all of the technical experts employed by
the state and the EPA believe that there are no significant hot spots, based upon
inferences from data. Accordingly, while it may be highly probable that no hot spots
The scope of the IEL radiochemical characterization project has been large. Data presentation in a timely fasN-
in a format preferred by the Panel may not have been a failure on the part of any agency but rather a consequence dictated by
the timing of the inquiry and the shorter timetable on which the SAB Panel members were conducting their inquiry. Nevertheless,
the Panel still felt that data must be presented in a format that is clear and understandable to all readers, particularly those with
the least technical expertise.
13 Grumbly, 1992. Op Cit. Pg. 9.
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exist, it is not a fact."14 Expert perceptions of risk differ significantly between
scientists from different fields of risk. Independent of field research, risk perceptions
are significantly associated with the type of institution in which a scientist is employed
(Barke and Jenkins-Smith, 1993).15 Maharik and Fischoff (1993)16 predict that
individuals within any group with strong prior commitments will be less responsive to
evidence. Hence, it is very unlikely that concerns of the community will be adequately
addressed or resolved after testing or sampling has already taken place. The
information seeking and sharing process has to be one that the community finds
legitimate and agrees to in advance; the community needs to be in the process.
Testing - in this case, sampling - is information seeking. The community has a
set of concerns that relate to the tasks of information seeking, which are not
necessarily the concerns EPA has. It is better to deal with these concerns BEFORE
one deals with testing, and to design protocols that respond to those concerns in as
much as the involved agencies are willing to understand wh'at those concerns are. A
formal advisory board, such as the TIC that EPA eventually implemented at IEL, is
probably more appropriate than a completely negotiated settlement, to enable EPA to
deal with the range of concerns up front. Disputes based on uncertainty cannot be
ignored, and are unlikely to be resolved by reaching consensus. EPA is likely to gain
legitimacy and credibility if it deals with such disagreements up front and directly, to try
to reduce the gaps between parties. Dialogue with and outreach to the larger
community is essential. The effectiveness of an advisory committee might be
improved by (1) taking steps to ensure the independence of the advisory committee
from the sponsor (EPA), (2) trying explicitly to have the committee be representative of
the community (which EPA appears to have done, to some extent, although they state
that active participation of non-Agency representatives other than those from the
CCLT ceased several years ago), and (3) considering the use of an independent
facilitator or mediator (Lynn and Busenberg, 1994).17
14 Crumbly, 1992. Op Cit. Pg. 12.
l5 Barke, R.P. and H.C. Jenkins-Smith, 1993. Politics and Scientific Expertise: Scientists, Risk Perception, and Nuclear
Waste Policy. Risk Analysis, vol. 13, No. 4., pp 425-439.
16 Maharik, M. and 8. Rschoff, 1993. Risk Knowledge and Risk Attitudes Regarding Nuclear Energy Sources; in Space.
Risk Analysis, Vol. 13, No., 3, pp 345-353.
17 Lynn, F. and G. Busenberg, 1994. Citizen Advisory Committees and Environmental Policy: What we know, whafs left
to discover. Dept. of Environmental Sciences and Engmeenng, School of Public Health, University of North Carolina at Chapel Hill.
June 1994.
28
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Even those unfamiliar with risk communication are likely to agree that much
new, often complex and technical information is created and disseminated in the risk
management process. This fundamental aspect of risk communication can create
serious gaps in trust and credibility if it is mishandled. At IEL, this has happened.
Lack of trust in EPA was fueled by the invalidation of two consecutive rounds of
sampling for radioactive contamination and the non-release of the data gathered,
followed by the slow release of subsequent data in a format that discouraged
comparisons and contextual interpretations. It is also unfortunate that reanalyses in
the earlier data focused on false positives, with much less discussion of possible false
negatives.
EPA has in several circumstances at IEL used hypothetical models. Poor
communication practices can contribute to the impression that such models are being
used inappropriately as "evidence" by the Agency. For example:
A very conservative, hypothetical analysis performed by the National Air and
Radiation Environmental Laboratory, dated January 29, 1991, concluded that
even if 100 drums of uranium sludge, like that found at the Department of
Energy facility in Fernald, Ohio, were buried at IEL, the maximally exposed
individual would receive an amount of radiation equal to that received by an
average individual in about one hour from natural background. This would
correspond to a little less than a lifetime risk of 7<77.18
The hypothetical model referred to here makes many assumptions (e.g.,
location of sludge) that could be challenged. In this context it would be appropriate to
present some form of uncertainty analysis that acknowledges the effects of those
assumptions. Also, risk comparisons are among the most alluring and potentially
damaging mechanisms used to try to explain risks. Comparison on a single
dimension (such as severity of harm) may invoke comparisons on other dimensions of
risk (such as voluntariness or controllability).
Technicalities are best explained promptly by acknowledged experts with a firm
grasp of the facts, the uncertainties about the facts, any preconceptions the recipients
of the information hold, and an understanding of good communication practices.
However, only the best experts are likely to understand the uncertainties well, and of
them only a handful are likely to have learned what kinds of beliefs may prevail among
non-experts. Rarer yet is such an expert who also understands the basics of good
18 Statement to the SAB ad hoc Panel on September 21,1993 by Norman R. Neidergang, Associate Division Director for
the Waste Management Division, Region 5, USEPA.
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communication. Communication efforts are likely to fail if they are not informed by a
thorough empirical characterization of the beliefs and knowledge held by those living
near the site. Close collaboration between managers, communicators, technical
specialists, and the public at an early stage can help overcome these likely deficits: in
the case of conflicts, facilitation may help.
30
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APPENDIX A
PARTIAL LISTING OF REVIEW
MATERIALS MADE AVAILABLE
TO THE
SCIENCE ADVISORY BOARD
FROM THE U3 EPA AND OHIO EPA
Contents:
1. Aug 10, 1993 - USEPA Catalogue of Materials for Review by the Science
Advisory Board (13 pages)
2. Aug 11, 1993 - OhioEPA documentation regarding radiochemical issues and
sampling results (3 pages)
3. Sep 7, 1993 - USEPA Radiological Ground Water Sampling Results Dec 92
and Mar 93 (2 pages)
4. Oct 5, 1993 - OhioEPA radiochemical data from ground water sampling
(submission on disk) (2 pages)
5. Oct 15, 1993 - USEPA Transrr''*al of Radiochemical Data on Disk (1 page)
6. Nov 16, 1993 - USEPA Transmittal of Radiochemical Data on Disk (2 pages)
7. Dec 1, 1994 - USEPA Transmittal of Mapping Program for Radiological Data (1
page)
A- 1
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO. IL 60604-3590
MEMORANDUM
agfVT TO THE ATTHWPCN O=:
DATE:
SUBJECT:
FROM:
TO:
August 10, 1993
Industrial Excess Landfill
Catalogue of Materials for Review by the
Science Advisory Board
Linda A.
Remedial Project Manager
A. Robert Flaak
Assistant Staff Director
Science Advisory Board
At the request of the ad hoc subcommittee of the Science Advisory Board (SAB), attached
please find a. Catalogue of Materials regarding: the Industrial Excess Landfifl (TEL) Superfund
site in Uniontown, Ohio. I have included in the catalogue of materials, a. narrative
descriodon of each document to assist in dissemination of the material*? to the subcommittee
members. Also included is a. documentation listing which may be used as art abbreviated
form of the catalogue. A copy of each document is also being transmitted.
This transmntal of TOtmal includes in information that was requested by the SAB ad, hoc
subcommittee during the course of the public hearings on July 20-21, 1993 with the
following, exceptions:
1) The Final TT.S. Geological Survey (USGS) Rejfcct. The USGS estimates that
their report of their review of the recent ground water investigations wig be-
transmitted to Region 5 by the end of August. I Witt forward * copy of this
report to jour office as soon as it becomes available.
2) The spread sheets and the associated computer disk which- presents the
majyricat fg«nlt* fmnt TT.5T BPV.t National Air anri Tfrtttfatrnfi Fnvfmnmentai
Laboratory (NAREL) for the May 1992 and August 1992 round of
comprehensive- ground water sampling & analyses Witt be provided to your
office by the week of August I6r 1993. In the intBrfm, a, hard copy of the
radiological data results is included in thi* transmittaL
L
Printed on Zacrdad Pace
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3) As was indicated by USEPA during the SAB meetings last month, the results
of the December 1992 and March 1993 rounds of ground water sampling and
analyses will be transmitted to your office as soon as they are available. A
hard copy, spread sheets, and computer disk will be transmitted to your office,
If you have any questions, or if you should need any additional documentation regarding the
EEL site, please feel free to contact me at (312) 886-7341.
Attachments
cc: Robert Huggett (w/attachments, w/out documents)
Dorothy Canter (w/attachments, w/out documents)
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INDUSTRIAL EXCESS LANDFILL
DOCUMENTATION LISTING
1. Report oa the Initial Sampling Performed at EEL (April, 1988)
2. Remedial Investigation (July, 1983)
3. Feasibility Study (December, 1983)
4. ATSDR's Health Assessment (July, 1989) Note: Included as an appendix to tnis document la the
U.S. Geological Survey's 1988 Report regarding ground water flow within and around the TFT. sits.
5. Recora of Decision (July, 1989)
6. Record of Decision - Alternate Water Supply (September, 1987)
7. Final Work Plan for Design Studies and Remedial Design (April, 1990)
3. Quality Assurance Project P!an (July, 1991)
9. Held Sampling Plan (July, 1991)
10. Draft 30% Remedial Design Document (February, 1993)
11. Draft Ground Water Modeling Report (February, 1993)
12. May 1992 Ground Water Monitoring and Residential Well Sampling Results Technical Memorandum
(February, 1993)
13. Table of Monitoring Well Water Levels (March, 1993)
14. Radiological Analytical Results from the National Air and Environmental Laboratory (NAREL) -
Samples Collected Daring the RD Heldworic Activities
a) Report of Radon. Measurements at IEL (August 21, 1992)
"} b> Report of PaiticuUte F3ter Measutoneats-SMnvJEL (August 28,19$2)
i
-a c) Radiochemkal Analytical Results for Samples from EEL (August IS, 1992)
, 4
<3
15. Radiological Analytical Results from NAREL- Samples Collected. Doting the Quarterly Ground. Water
nn2 Program
a) Comprehensive Ground. Water Sampling. Round 1 Radiochemicai Analytical Result*. -
May, 1992.1
b) Comprehensive Ground. Water S*mplinns Round 1 Radiochemicai .Analytical Results -
August 19921
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c) Comprehensive Ground Water Sampling Round 3 Radiochemical Analytical R»-uIts •
December 199214
d) Comprehensive Ground Water Sampling Round 4 Radiochemical Analytical Results -
March 1993'-
16. Contract Laboratory Program Invalidated Radiological Results
a) August 1990 Invalidated Radiological Results
b) December 1990 Invalidated Radiological Results
IT. EEL, Technical Information Committee Position Papers
a) TTC Positions With Respect to the Radiological Sampling it IEL
b) TIC Positions with Respect to the Request to Perform Additional Soil Boiings at ie
Landfill
13. Information Collected to Date on Background Radionuciide Concentrations (August 1993)
a) Information Sheets
b) U.S. Geological Survey's Regional Aquifer Study Analysis Data Base summarizes tritium
concentrations found in aortheast Ohio
c) U.S. Geological Survey's Water-Resources Investigation Report Abstract oa Geohydrology and
quality of water in. Lucas, Sanduslcy, and Wood Counties in northwestern Ohio
d) Occurrence of Radon, Radium, ind Uranium in Groundwater, Journal AWWA, IS 83: A
paper based on the National Inorganics and. Radionuclides Survey (KIRS).
«) ( Environmental Radiation Ambient Monitoring System (ERAMS): An overview of the ERAMS
and radionuclide concentration* are-provided for tritium, gross alpha and beta, strontium-90.
19. r*.-M i'Miirmrt^n
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INDUSTRIAL EXCESS LANDFILL
CATALOGUE OF MATERIALS
FOR THE
SCIENCE ADVISORY BOARD
1. Report on the Initial Sampling Performed at IEL (April, 1533)
USEPA's Environmental Response Team (ERT) collected gas samples from the Methane Venting
System at the TTTT. site in January of 1988. The results of iese analyses were used to develop a target
list for a soil gas and indoor air sampling program.
The gas was tested on-site utilizing a portable radiation survey meter, as well as detectors for hydrogen.
sulfide and phosgene. One soil gas Summa canister and the background Summa canister were sent to
the EPA eastern Environmental Radiation Facility in Montgomery, Alabama for analyses for the
presence of radioactive parameters including Radon.
The analytical results of this sampling is summarized in this reoort.
This document consists of 5 pages.
Remedial Investigation duly, 1983)
The Remedial Investigation (RI) tumma-nyM the data collected to characterize the site in order to assess
the immediate or potential threats a human health and the environment posed by the TEL site. This
document was ftnali-wt io. 1988, therefore the following information is compiled only through 1988
(current information is provided in the Draft 30% Remedial Design Document, dated February 1993):
Section 1 provides site background information including, a site description, site history,
chronology of events, and i summary of previously obtained data, and information on the site.
Thi.* section also provides a. summary of the nature and extent of the contamination problem
and a summary of the remedial investigation process, as well as an overview of the remedial
investigation report.
Section 2 of the report describes site features including demography, land use, natural
resources, and climatology. These descriptions ire based oa published data, for the site area as
the text,
Section- T summarizes, the waste* and their respective characteristics and behavior. This
section addresses waste cniantitiesv I"****!**** <*TU^ mnt*mmrmr mA their •*"Tiii«inT^f
Section 4 provides a summary of the geology xod hydrogeology of the site are*. Tnchuiffi ur
this section L» a. description. of the geologic features, the hydrogeclogic framework and. the
jmiin/4 "vater How T^ttTT*T- fa addition, the yrtiion 'H^nHffc^ «mfeimfn*nf levels determined,
in the
Section 5 addresses the hydrolozio investigation conducted ac 3tv^ around tha
section ire ^iy?'frifm of drainage p^tt*r^* JTV* the investigation and results of the surface
water and -a^mvgit sampling program*.
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Section 6 presents the results of the air Investigations conducted it and around th« site, and in
the Uniontown community.
Section 7 describes the geophysical investigation that was carried out at the site. This sectioa
discusses the techniques used and the results of each of the types of surveys performed.
Sectioa 3 is the public health evaluation. This section discusses and evaluation of the public
health and environmental concerns posed by the conditions at the site.
The document consists of 2 volumes.
3. Feasibility Study (December, 198S)
The Feasibility Study (FS) provides a detailed evaluation of the remedial alternatives and screening of
the remedial process options applying environmental, engineering, and. economic factors in accordance
with the NCP and CERCLA.
This document, coupled with the RI, provides the basis for EPA'j selection of the final remedy for the
DEL site.
The document consists of I volume.
ATSDR's Health Assessment (July, 1989)
The Agency for Toxic Substances and Disease Registry (ATSDR) is mandalwi by Congress to perform
a Health Awtttmrnt for each, hazardous waste site on the National Priorities List (NPL). .A Health.
Assessment is the evaluation, of ^«^ and information on the release of hazardous substances into the
environment in order to (1) assess any current or future impacts on public health, (2) develop health
advisories or other health recommendations, and. (3) Identify studies or actions seeded to evaluate- and
mitigate or prevent human health effects.
Included as m appendix to this document is the 1988 U.S. Geological Survey (USGS) Report which
evaluated geologic and hydrogeo logic data, available from the RI/FS, and from U.S. GeoiO'gical Survey-
data. bases, with, emphasis oa how well the available <**** describe- ground water flow within and. around.
the IEL site.
TTlia. Aviinnuit ivm«i«t« nf 1
5. Record of Decision (ROD> (July, 1989)
Has document contains the Record of Decision and the Responsiveness Summary the USEPA- prepared,
for the i frig- ritg. T^ ROD describe* USSPA's. overall 'piV'^'H for addressing; the cantandnacatt
problems associated, wid* the ats. The-Responsivenett Summary, t requirement of Supetfuod Law, ,
summarize* M»mm>»it« received, front the. pabfic m4 other interested parties oa USEPA'J Proposed.
Ptaa, and presents USEPA's response to those comments.
document consists of 1 volume.
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6. Record of Decision fROD) - Alternate Water Supply (September, 1987)
This documents describes USEPA's approach for providing an Alternate Water Supply to an area.
comprised of approximately 100 homes in Unioatown, Ohio. This action constituted an operable unit
of the overall remedy for the site.
The document consists of 1 volume.
7. Final Work Ptan for Design Studies and Remedial Design (April, 1590)
The work plan defines the scope and rationale of activities for the Remedial Design (RD) for the TFL
site. In addition, the work plan describes the activities necessary to complete the RD and provides a
detailed explanation of [he design activities.
Section 1 provides the overall scope of the Remedial Design.
Section 2 presents the site background information.
Section 3 presents the RD data needs and investigative approach to obtain this data.
Section 4 discusses die preliminary activities that needed to be conducted prior to the initiation
of the RD.
Section 5 describes the design studies necessary to obtain the data needed to complete the RD.
The major jlements of the design studies are ground water and aquifer characterization;
landfill gas characterization; surface water, sediment, and soil contaminant characterization;
and [amifin ^an evaluation.
Section 6 describes the r*rtw*i"i design activities. This section includes a. discussion on the
preparation of i detailed remedial design work plan, the preliminary design, the intermediate
design, the ptefinal/fuial design, and necessary construction contract support.
Section T describes the TIC meeting: support provided by EPA'i contractor for design, PRC
Environmental Vfanagmmntj Incorporated.
Section S describes the project management activities and level of quality control necessary for
the RD activities.
I
Section. ? present $ the icheduls- of activities aui deliverable*.
TTri^ ^hff pfx^^i1!!'* -9 oojoctives* *iv\ fixxififf ousjitsr amn jm<^ *yi oualiftr cooficol
(QA/QQ activities that USEPA's contractors followed to achieve toe data, quality goals established for
the design studies phase of the 3D atlEL.
Tltis document consists, of Z vo tomes.
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9. Field Sampling Plan (FSP) (July, 1591)
The field sampling plan (FSP) describes the sampling procedures and collection methods that were
followed by USEPA's contractors during the design studies phase of the RD.
The four principal ares of the field investigation consisted of the ground water and aquifer
characterization, the landfill gas characterization, the surface water, sediment, and solid
characterization, and the geotechnical evaluation. The FSP describes the sampling activities associated
with each of these ares.
Other sections of the FSP provide information on the site-specific objectives, sample handling, waste
disposal, and proposed project scheduling.
This document is Appendix A of the QAPP, as described above, and consists of 1 volume.
10. Draft 30% Remedial Design Document (February, 1993)
The objective of this preliminary design report is to present conceptual plans and specifications for
implementing USEPA's selected Remedial Action (RA) at the site.
t
Prior to the initiation of the design of the RA components, USEPA completed design studies and field
testing in 1991 and 1992 to supplement information obtained during the 1983 RL The document la
organized as follows:
Chapter 1 introduces the preliminary design report.
Chapter 2 provides site background Information.
Chapter 3 describes the f***igff studies and field testing completed in 1991 and 1992 to
supplement data, obtained during the Remedial Investigation.
Chapter 4 iriffltiffcar the j^jgn strategies ind the basis for the design.
Chapter 5 describes the landfill cap; and the expanded landfill gas extraction and treatment
system.
Qxpter & describes, th^ ground water extraction and ^>«»tui«ir system.
_ "jf-
Chapter T discusses insrifufiocai controls.
CSspter $ discasM* the element* of the Operation Se. MainteojB>cft(O^ti/Mt of *h*fr ?*"*»<•«. for the T«ytfnt cap, the I«tyifiTT gas extraction
xnA treatment lystemv "yt the ground water ixmcaoa and treatment system.
-------
The analytical results of die design si Juic-* >•• rteld testing are detailed in this recoct. These results
summarize the foilowing information:
o Landfill Gas Generation Ra'r. and Chemical Composition
o Landfill Gas Migration
o Surface Soil Contamination
o Sediment and Surface Waier Contamination
o Hydrogeologic Characterization and Monitoring Well Installation
o Ground Water Contamination
o Slug Testing and Ground Water Modeling
o Geotechnical Investigation
o Landfill Cap
The document consists of 6 volumes.
11. Draft Ground Water Modeling Report {February, 1593)
This, report .qnnmariraa USEPA's approach to computerized capture zone modeling at TFT.. The
purpose of the modeling was to provide information to support ;he preliminary RD of the ground water
extraction and treatment system.
The report provides information on site history, geology, and ground water hydrology. A summary of
the results of the capture zone and Theis drawdown modeling, as well as a. discussion of the model
limitations is provided. The document also presents recommendations for a ground water extraction
system.
USEPA's 1989 ROD established design criteria, that required (1) extracting, and treating, contaminated.
ground water beneath, and near the landfill until cleanup levels are achieved, and (2) pumping ground.
water to m^intai^ the water table beneath, the waste in order to protect ground, water from additional
contamination. This report addresses these criteria, and presents information related to the ground water
extraction system, including '.he number and location of extractions, wells and pumping rates.
This document consists of 1 volume.
12. May 1992 Ground Water Monitoring and ^ffi*jffl^al Weil Sampling Results Technical
(February^ 1993)
This, document presents, the. results of. the inaiyse* foe volatile: orgamc cxraipcravisi semwolatfle organic
A comparisoa of ground water analytical results Sot sample* collected 5rom inomtorinjweils 'in August
199(^. December 1990, December 1991, and May 1992 is presented.
Tie result* of the Angsst 199X December 1992, and Modi 199? wiH be made ivailable for
distribution to the SAB, if requested, a» tbey become cvailabls.
Tii* r|
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13. Tible of \fonitoring Well Water Levels (March, 1993)
This table presents monitoring well water level measurements taken at the EEL site during each ground
water sampling event from August 1990 through March 1993.
This document is summarized in 3 pages.
14. Radiological Analytical Results from the National Air and Environmental Laboratory fNARET.) -
Samples Collected During the RD Fieldwork Activities
a) Report of Radon Measurements at IEL (August 21, 1P92)
This report presents the following information:
o Radon Concentrations in EEL Soil Gas Extraction Wells;
o Measurement of Radon-222 in MVS and Pilot Extraction Wells;
o Pilot Landfill Gas Extraction Wells;
o Landfill Gaseous Monitoring Well Radon Concentrations;
o Radon in Water;
o Radon Measurements in Exploratory Boreholes;
o Pylon Radon Detectors; and
o Radon Flux Measurements.
This document consists of 23 pages.
b) Report of Particulate Filter Measurements from IEL (August 28, 1592)
This report presents data for the particuiate sampling of the Methane Venting System and the
three pilot extraction wefls for radioactive materials.
This report is summarized in 3 pages.
c) RadTochemica] Analytical Resute for Samples from IEL (August 2$, 1992)
; first three in-ata ground water samples Scorn. f^f~h borehole- drilled on. site were- collected
. analyzed for radiochemicai parameters at NAREL. Hie results, of thffL analyses are
provided in. tabular form.
.'•3 »
,;"j Re-analyse* wwecooioctedoa several of these samples. The results of these-analyse* are-
Lia a February 5,. 1993 memoiaadumt fkint Jba Broadway of NAREL toLiod*
Sent.
These results are presented a a. toed of 31 pages.
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15. Radiological Analytical Results from the National Air and Environmental Laboratory (NASET.)
Sarr .'3 Collected During the Quarterly Ground Water Sampling Program
a) Comprehensive Ground Water Sampling Round 1 Radlochemical Analytical
(May, 1592)
Radiochemical results are presented for ground water and filter samples collected from.
monitoring wells, irrigation wells, and residential wells collected in May 1992.
Also included is a copy of USEPA's Fact Sheet which summarizes the results obtained during
this sampling event.
Re-analyses were conducted on samples which exceeded EPA's screening criteria for gross
alpha activity of 15 pCi/L in ground water or 3 pCi/sample on filters.
These results consist of 1 volume.
b) Comprehensive Ground Water Sampling Round 2 Radtochanical Analytical Result^
(August, 1592)
Radiochemical results are presented for ground water and filter samples collected from
monitoring wells, irrigation wells, and residential wells collected in August 1992.
Also included is a copy of USEPA's Fact Sheet which summarizes the results obtained during
this sampling *vent.
These results consist of 1 volume.
c) Comprehensive Ground Water Sampling Round 3 Radiochemical Analytical Results
(December, 1592)
Results will be transmitted as soon as they are available.
d) Comprehensive Groond Water Sampling Round 4 Radiochemical Analytical Ressits
' ' (March, 1993)
Results wiE bo transmitted as soon as they are available.
.
Contract TLaboratorv l^mram Invalidated Radiological Results
*^^*"** **^*^ j-*i.m^w» «».•«*» ^ «. », ^^^ «»*»» fcM • «M*>«l«»-»««^ «-M«*»«-«J.^«»MH^» *-»^«J-^.«M
a> August 1999
Toe only analytical results which, were- acceptable for this round of ground water sampling
were the Carbco-14- r**"!**
These results- ire presented ia 54 datx shceta.
A November 21, 1990 Memorandum from Gregg Donpsey to Cards Ros» of theCsnttal
Regional Laboratory summarizes ftv* Aozust. 1990 A*t* reviev.
-------
b) December 1990
The invalidated results of the December 1990 sampling event are contained in 2 boxes. These
data are in the original form as received from the Contract Laboratory.
A September 17, 1991 Memorandum from Gregg Dempsey to Curtis Ross of the Central
Regional Laboratory summarizes the December 1990 data review.
17. IEL Technical Information Committee Position Papers
a) TTC Positions With Respect to the Radiological Sampling at TEL (May, 1992)
In a April 23, 1992 correspondence to the TFT. TIC, Linda Kern requested that the members of
the TIC provide a written statement outlining their technical opinions with respect to the
radiological sampling at rFT. (!.«., frequency of sampling, parameters, etc.). Responses were
received in May, 1992 from the Ohio EPA, ATSDR, and the Concerned Citizens of Lake
Township (CCLT).
b) TTC Positions With Respect to the Request to Perform Additional Soil Borings at the
Landfill (July, 1993)
During the May 19, 1993 meeting of the H-T- TIC, the committee agreed to draft position
papers regarding the issue of performing additional landfill coring during Che RD phase at
Position papers were received from, the Ohio EPA, ATSDR, CCLT, and the Potentially
Responsible Parties (PRPs).
18. Information Collected to Date on Background Radionuclide Concentrations (August 1993)
a) Information Sheets have been compiled summarizing properties, health, risks, production and.
use, release*, fate in the savixoomeot, monitored levels in. this environment, and analytical
methods, for the following isotopes: thorium, plutnnhim, uranium, radium, tritium, carbco-K,
and cesium.
b) U.S- Geological Survey's Regional Aquifer Study Analysis Data. Base mmmati-r**. tritium
Ohio*
,-4 c) U.S. Geological Sorvey's Witet-Re*xrce» Investigation-Report Abstract on tSeobydroiogy and.
^•_i
•i
d> Occurreacgof RadonvR*diumwaiidUgmmnitt(jcoaaigater>rc^niJl AWW.\^ 1988:
process of attempting to obtain *. copy of ch* actual data base, ponibly oa disk.
e) BiynqmngtfBi Kyffifk^t Aa^Hi*^feTifa^B£^yT*«n (EgAMSfe Aa overview of the ERAMS
2MQBMU
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19. Correspondence to Senators John Glenn and Howard Metaenbaum From Regional Administrator
Vaidas V. Adamlois
a) December 18, 1990 correspondence from Regional Administrator Vaidas V. Adamkus to
Senators John. Glenn and Howard Metzenbaum transmitting U.S. EPA's justification Of
reasoning for not characterizing the waste material by soil core sampling with analysis for
radionuclides. Attachments include a statistical analysis for the probability of locating
radioactive wastes based on the number of boreholes and samples to be taken, potential
radiological contaminants and estimated volumes, and a discussion of the 198S ERT testing of
the Methane Venting System for radon.
b) March 25, 1991 correspondence from Regional Administrator Vaidas V. Adamkus to Senators
John Glenn and Howard Metzenbaum transmitting U.S. EPA'j ground water modeling report
which was used Co estimate the concentration of three potential radioactive sources (cesium-
137, tritium, and uranium-234/238) downgradient from the landfill at selected time periods.
The input parameters chosen for the model were based on available site data (prior to the
installation of Che new RD monitoring wells) and accepted modeling practices. Also included
an the results of Che expanded calculations using U.S. EPA's PRESTO waste burial computer
model. PRESTO is used to model long term impact associated with low level radioactive
waste sites. The calculations, based on hypothetical radionuclide inventory data, were made
for a 1000 year period following closure of the landfill.
20. Questions & Answer? About the Industrial Excess Landfill Surerfund Site (December, 1992)
This document is a Fact Sheet which addresses questions concerning the TKT. site. It was distributed to
the community and members of Che TKT, TIC in December 1992.
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State of Ohio Environmental Protection Agency
Northeast District Office
2110 =. Aurora 3oad
Twinsburg. Ohio 44087-1969
(216)425-9171
FAX (216) 437-0759
August 11, 1993
Georga V. Voinovich
Govwnor
Donald H. Schrega.-dus
0(r»ctar
RE: Industrial kxcess LandtUI
Stark County
OHD OCO 377 911 (276-0416)
Submission to the U.S. EPA
Science Advisory Board
Mr. Robert A. Flaak
Assistant Staff Director
U.S. Environmental Protection Agency
Office of the Administrator
Science Advisory Board
401 M Street, SW (A-101F)
Washington, D.C. 20460
Dear Mr. Flaak:
In accordance with requests made by the Science Advisory Board ad hoc Industrial Excess
Landfill Advisory Panel during the meetings held in Akron, Ohio, during July of 1993, Ohio
EPA is submitting the enclosed documentation regarding radiochemical issues and sampling
results for this site.
A catalog of the documents contained in the submission is provided as Attachment I to this
letter. Copies of all radiochemical sampling results obtained by Ohio EPA are included;
however, a. disk copy of the Ohio EPA data, organized into the spreadsheet format being;
employed by U.S. EPA for their radiochemical data, will be provided by U.S. EPA during
the week of,August 16, 1993. Please note that Item D oo Attachment I should accompany
both paper copies of the radiochemical data (Items E through15) and disk copies of the data,
when distributed to Panel members.
If the members of the Panel have any questions about this sutjprission, or if additional
documents are required, please do not hesitate to- contact me (216-963*1126).
Sincerely,
&HJ&W<~J
JuEeL. Corkrair
Project Coordinator
Division of Emergency and Remedial Response
JLClt
enclosures
cc: Rod Seals,
Fran Kbvac, CO/Legai
Bob Princic,
Linda Kern, U.S. EPA/Region V
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Attachment I Industrial Excess Landfill SA3 Submission
Document Catalog
The documents have been organized into a two-volume set with
lettered dividers for reference purposes. This catalog provides
the location of each document, document title, and a brief
description of the document where appropriate.
Location Document
Volume I
A Correspondence from J. Cor)cran (OEPA) to L. Kern
(USEPA). July 13, 1993. Subject: Position paper
on core sampling for radiochemical "hot spots"
during Remedial Design activities.
3 Correspondence from J. Corkran to L. Kern. May 23,
1992. Subject: Position paper regarding the scope
and frequency of radiochemical sampling at IEL
during pre-design studies.
C Correspondence from J. Corkran to L. Kern. May 25,
1993. Subject: Ohio EPA comments on the
Preliminary (30%) Remedial Design Document for IEL.
This letter provides an overview of the current
technical status of the site as the involved parties
enter into the design phase of the proposed remedy,
including narrative on the issue of defining
background for radiochemical contaminants of
concern.
D t Summary of Data Qualifiers for Ohio EPA IEL
Radiochemical Data.
Tnis- item; includes a chronological summary of any
data point correction* and invalidations^ deviance*
fron* the Quality- Assurance-^Project Plan sampling?
protocol, and relevant correspondence required. Coir
proper- interpretation off the radiochemical data.
Pleas* not* that Item i> should accompany botl* paper
copies off th* radiochemical data (Items & througlr JC/.
below} aad disk copies off th* data, when distributed.
to* Panel members*.
OEPA Ground Water Split-Sampling Results:
March: 1991.
OEPA. Ground Water- Split-Sampling- Results:
June- 1991.
-------
Attachment I, continued.
Location
Volume I
G
H
I
J
Volume II
K
.-A
;2
Document
OEPA Ground Water Split-Sampling Results:
December 1991/January 1992.
OEPA Ground Water Split-Sampling Results:
May 1992.
OEPA Ground Water Split-Sampling Results:
August 1992.
OEPA Ground Water Split-Sampling Results:
November/December 1992
OEPA Ground Water Split-Sampling Results:
March, 1993 (Draft) .
The Model State Information System (MSIS) is a
database that organizes the results of radiochemical
sampling and analysis performed by Public Water
Supplies- (PWS) that rely on ground water and surface
water sources. Gross alpha and grrss beta analyses
are typically reported. The database, organized by
county, is current through, 1992 and dates baclc to
1980 for a limited number of public water systems.
Ohio EPA will be providing the MSIS data to the
Technical Inf oraation Committee for consideration: as
a possible local database for use iit definino;
radiochemical background levels for the ISL. site.
Due to the geographic location? of rEL. near the
juncture off three counties, MSIS listings for
Portage* StarJc, anct Summit Counties are provided; in
this submission.. Only ground water* source data: are
include**.
Model State Information: System, Radiological Sample
Listing-, Ground Water Systems:
Portage County, Ohio. f
Model State Information: System, Radiological Sample
Listing-, Ground Water Systems:
StarJc County, Ohio.
Model State Information System, Radiological Sample
Listing-, Ground Water Systems:
Summit County, Ohio.
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UNITED STATES ENVIRONMfr iTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, !L 50604-3590
THE ATTENTION CF
MEMORANDUM
DATE:
SUBJECT:
FROM:
TO:
September 7, 1993
Industrial Excess Landfill
Radiological Ground Water Sampling Results
December 1992 and March 1993
Linda A.
Remedial Project Manager /
Addressees
Enclosed please find copies of the following materials for the Industrial Excess
Landfill (IEU Superfund site in Uniontown, Ohio:
i i
1 ) A Fact Sheet (September,. 1 9931 which: summarizes the results of the
radiological ground water sampling/analyses performed on samples
collected during: the December 1992 and March 1993 sampling; events
at the IEL site; -
21 Radicchemicak Analytical Results for samples colfectad itt December
1992; and
3} Radiochemicai Analytical Results for samples collected irt Maccir
Due to the? volume* of material whictt comprises the radfochemicafc analytical resuitsv
copies of the data for the* December T392 and Marcit T993; gcoundfwatar sampling^
events are beings sent ta the* representativa-Technicak Inforrnatiorf ComnutMei (TTCJ
members, listed below as- addressees and tc individuals whe have made* specific
requests for copies ot the data.
-------
In addition, copies of the data are being sent to the two IEL Information
Repositories located at the Lake Township Clerk's Office and the Hartville Branch
Library for availability to the public. If you did not receive a copy of the data, but
would like to, please call me at (312) 886-7341 or toil-free at 1-800-621-8431.
Tne results of the December 1992 and March 1993 ground water results for the
inorganic, organic, and metal analyses will be transmitted under a separate cover.
Enclosures
Addressees:
Julie Corkran, Ohio EPA . . . -
Laura Barr, ATSOR ...-.•- • • ,
Larry Sweeney, Burlington Environmental
Christine Borello, CCLT
Henry Cole, CCLT - -
Marvin Resnikoff, CCLT. ._.._- - - " "
Steven James, Ohio Department of Health
Information Repositories (Hartville Branch Library & Lake
Township Clerk's Office)
A. Robert Ffaak, SAB .
IEL Technical Information- Distribution List (w/Fact Sheet, w/out
data) .---•-,-.-•- -- '
Norm Nfedergang, USEPA (w/Fact Sheet; w/out data)
Tim Reids, USEPA {.w/Fact Sheet, w/out data)
— r
- 2
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State of Ohio Environmental Protection Agency
Northeast District Office
2110 E.Aurora Road
Twmsburg, Ohio 44087-1969
(216)425-9171
FAX (216) 487-0769
George V. Voinc
Govs
CERTIFIED MAIL
Octobers, 1993
RE: Industrial Excess Landfill
Stark County
OHD 000 377 911 (276-0416)
Radiochemical Data Submission
to the U.S. EPA Science Advisory
Board *
Mr. Robert Flaak
Assistant Staff Director
U.S. Environmental Protection Agency
Office of the Administrator
Science Advisory Board
401 M Street, SW (A-101F)
Washington, D.C. 20460
Dear Mr. Flaak:
In accordance with requests made by the Science Advisory Board ad hoc Industrial Excess
Landfill Advisory Panel during the September 21-22, 1993, meetings in Washington, D.C.,
Ohio EPA is submitting in disk format the radiochemical data generated by this agency
during ground water sampling at this Superfund site.
The following items are enclosed with this cover letter and have also been submitted directly
to each Panel member:
i. Ohio EPA radiochemical data in Lotus 1-2-3 (Release 3.0) format,
ii. Spreadsheet printout,
iii. Memorandum: Summary of Data Qualifiers for Ohio EPA IEL Radiochemical
Data (originally submitted to the SAB on 8/11/93 as Item D in the Ohio EPA
document catalog),
iv. TMA/Eberline Laboratory Analytical Methods and Reference table.
The additional information required by the Panel regarding specific Ohio EPA radiochemical
data values has been requested of TMA/Eberline and will be forwarded to the Science
Advisory Board upon receipt by this office.
PrinMO on mcyOwJ pacar
-------
Page 2
October 5, 1993
Robert Flaak
If the members of the Panel have any questions about this submission, please contact me
directly at (2 16) 963- 1126.
Sincerely,
Julie L. Corkran
Project Coordinator
Division of Emergency and Remedial Response
JLC:lt
enclosures
cc: (with enclosures)
SAB ad hoc EEL Advisory Panel Members
Linda Kern, U.S. EPA/Region V
Laura Barr, ATSDR
Stephen James, ODH
Chris Borello, CCLT
Larry Sweeney, Burlington Environmental
Mary Clark, NAREL
Todd Fisher, NEDO/DDAGW
(without enclosures)
Bob Princic, NEDO/DERR
Rod Seals, NEDO/DERR
Fran Kovac, CO/Legal
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
MEMORANDUM
DATE: October 15, 1993
SUBJECT: Industrial Excess Landfill (IEL)
Transmittal of Radiochemical Data on Disk
FROM: Tinka G. Hyde, Chief / V; ^7 ' ' I
TO: Science Advisory Board (SAB) ad hoc ISL Panel
The purpose of this memo is to transmit information to the SAB ad.
hgc ISL Panel which was requested during the September 21 - 22,
1993 meeting in Washington, D.C. You may remember that the
following information was requested from USEPA: 1) Radiochemical
data on disk; 2) List of monitoring wells which were pumped/
bailed; and 3) Set of Maps depicting the radiochemical data.
Included in this package are the radiochemical data on disk.
Unfortunately, the task of mapping all of the radiochemical data
and a subset of the volatile organic data was larger than I had
originally expected. Therefore, the maps are not yet complete.
I anticipate having the complete set of maps and the list of
monitoring wells which were bailed/pumped ready for distribution
by the end of next week.
The data was entered into Lotus 123 spreadsheets and is arranged
on the disk in the following format:
1. MAY-W.W3C1 » May 1992 WATER Rad data w/o QA/QC data
2. AUG-W.WX1 * August 1992 WATER Rad data w/o QA/QC data
3 . DEC-W.WK1 » December 1992 WATER Rad data w/o QA/QC data
4. MAR-W.WX1 - March. 1993 WATER. Rad data w/o QA/QC data
5. MAY-7.W3C1 » May 1992 FILTERS Rad data w/o QA/QC data
6. AUG-P.WK1 » August 1992 FILTERS Rad data w/o QA/QC data
7. DEC-P.WX1 - December 1992 FILTERS Rad data w/o QA/QC data
8. MAS.-P.WK1 » March 1993 FILTERS Rad data w/o QA/QC data
9. VOA.wm. » 4/5 Volatile Organic compounds from May 1992
round. These compounds were provided per SAB request to
compare general volatile distribution in groundwater with.
radiochemical distribution in groundwater. A separate map
will be provided of the VOA distribution.
10. RB-AST.WXl - Samples requiring reanalysis from May 1992 round
ONLY. Presented separately due to mapping constraints.
11. QA.-QC-W.WX3L - All WATER QA/QC data (i.e., blanks & MS/MSD)
12. QA.-QC-F.WX1 - All FILTER. QA/QC data (i.e., blanks & MS/MSD)
Finally, I am including well location mapa and an explanation of
the well numbering system to assist you in your review. If you
have any questions, please call me at (312) 386-9296.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
MEMORANDUM
DATE:
SUBJECT:
FROM:
TO:
November 16, 1993
Industrial Excess Landfill (IEU
Transmittal of Radiocnemical Data on Disk
Linda A.
Remedial Project Manager /
Science Advisory Board
ad. hoc Industrial Excess Landfill
Advisory Panel Members
The purpose of this memorandum is to transmit a set of maps depicting the
radiochemical data at the Industrial Excess Landfill (IEL) Superfund site. These
maps were prepared in accordance with requests made by the ad hoc IEL Advisory
Panel of the Science Advisory Board (SAB) during the September 21-22, 1993,
meetings in Washington, D.C. • •
Included in this transmittal are a set of maps depicting the radiochemical results for
each well. Due to the large volume of data points and map reproduction
limitations, 10 sets of maps were made to graphically present ail of the information
requested. A map set represents 2 maps: 1) one map of the landfill proper; and 2}
one map which presents the off-site wells. This configuration results in 20
individual maps. The following is a brief description of how the map sets are
organized:
Tritium data: AH 4 rounds of tritium data are presented on one set of maps.
The data are presented in small tables located adjacent to the corresponding
well location. A matrix which defines the data points within these small
tables is located at the bottom of each map. The activity, error, and MDA
are presented for each well location sampled. If a well is missing from a
map, assume that it was not sampled.
-------
, i
Gross Alpha, Gross Beta, Uranium, Radium in Groundwater: There are 4
sets of maps which present this data. Each set represents an individual
round (May 1992, August 1992, December 1992, and March 1993). The
data are presented in small tables located adjacent to the corresponding weil
location. A matrix which defines the data points within these small tables is
located at the bottom of each map. The activity, error, and MDA are
presented for each well location sampled. If a well is missing from a map,
assume that it was not sampled.
Gross Alpha. Gross Beta, Uranium. Radium in Filter Samples: There are 4
sets of maps which present this data. Each set represents an individual
round (May 1992, August 1992, December 1992, and March 1993). The
data are presented in the same manner as was described for the
groundwater.
Volatile Orqanics: May 1992 round of volatile organic data is presented on
one set of maps. The volatile organic data presented on the map is a subset
of a larger data set. As requested, this data is expected to serve as a
general indicator of the direction of chemical transport in groundwater. The
six most prevalent volatile organic contaminants from the May 1992 round
which were detected above the Maximum Contaminant Level (MCI) were
used to create this map. If a well is missing from this map, assume that the
six contaminants were not detected above the MCL during the May 1992
sampling round.
If you have any questions regarding this transmittal, please feel free to contact me
at (312) 886-7341.
SAB ad hoc I EL Advisory Panel Members
Dr. Robert Huggett, Chairperson
Dr. Ann Bostrom
Dr. Norman H. Cutsnail
Dr. Robert Morrison
Dr. Oddvar Nygaard
Dr. Mitchell Small
Dr. Michael Stein
Dr. Jan Stolwijk
Dr. Myint Thein
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
MEMORANDUM
DATE:
SUBJECT:
FROM:
TO:
December 1, 1993
Industrial Excess Landfill (IEL)
Transmirtal of Mapping Program for Radiological Data
Linda A.
Remedial Project Manager
Science Advisory Board
id hoc Industrial Excess Landfill
Advisory Panel Members
The purpose of this memorandum is to transmit supplemental material to the 3d, hoc Industrial
Excess Landfill (IEL) Science Advisory Board (SAB) panel members.
U.S. EPA's National Air and Radiation Environmental Laboratory (NAREL) has developed a computer
mapping program which can be utilized to display the radioanalytical results obtained for the IEL
site. I have enclosed a computer disk which contains the programs and data files necessary to run
the mapping program, as well as a copy of the supporting documentation which will assist you in
the operation of the program.
If you have any questions, please feel free to contact me at (312) 386-7341.
SAB ad hoc IEL Advisory Panat Members
Dr. Robert Huggett
Dr. Ann Bostrom
Dr. Norman H. Cutshall
Dr. Robert Morrison
Dr. Oddvar Nygaard
Dr. Mitchell Small
Dr. Michael Stein
Dr. Jan Stolwijk
Dr. Myint Thein
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DISTRIBUTION LIST
Deputy Administrator
Assistant Administrators
EPA Regional Administrators
EPA Laboratory Directors
Deputy Assistant Administrator for Office of Solid Waste and
Emergency Response
EPA Headquarters Library
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EPA Laboratory Libraries
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