United States        Science Advisory B«id     EPA-SAB-EC-94-010
Environmental        1400          September 19S4
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
V-
                                                               OFFICE OF THE ADMINISTRATOR
                                                                 SCIENCE ADVlSQftY 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 (QSWER).  The following
 summarizes our responses to the Panel's Charge.

 1)     For screening purposes, what types of temporal and spatial sampling and
 analyses are sufficient to test a hypothesis that radioactive contamination is
 prtstnt?

       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 dear
 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.
                                                                      Prfitod «n j«»p*rfl*l cartitn*
                                                                      a IUB 75* iwaRW But

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2}    What radiological parameters, e.g., gross alpha plus alpha spectrometry,,
gross beta, gamma spectrometry, tritium, and earbon-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 likeiy to  have to be
modified based on site characteristics. The guidelines for sampling and analytic
methods could under certain site conditions be adapted to locai 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 welis
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 National
 Institute of Standards and Technology (MIST) traceable reference radionudide
 standards.

      Validation inciudes; reviewing the results and data from planning stages through
 sample collection, togging in, receiving, sample preparation, analysts, 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 the
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 (EL site as  a result of disposal at the site.  White 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 atf ftoc 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,
<4.
 r. Genevieve Matanoski, Chair
Executive Committee
Science Advisory Board
Dr/DarW\.J, 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 1EL 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, Cutshali, Oak Ridge National Laboratory, Oak 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 Pubiic
      Policy,  Carnegie Mellon University, Pittsburgh,  PA

Dr, Michael Stein, Department of Statistics, The University of Chicago, Chicago, IL

Dr. Myint Theft, 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. Hyggett 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
                                      II!

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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 EL Site	   6

2.  INTRODUCTION	.		   8
      2.1   Charge to the Pansi	,,,.,.......	   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
           3.13 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 Superfuncf 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 3 partial listing cf the review materials available for the ad hoc Panel's review, please refer to Appendix A.  Th&
includes materials provided by the US EPA as part of the lormal review process, as well as relevant listings from the Ohio EPA, which
supptenwnttha us EPA materials. Information on materials and eampwnts from othersaurces, including other government agencies
and interested parties is contained in the archives of the SAB.


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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 lEL
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 likeiy 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
      2 EPA, 1390,  Letter from SPA Region 5 Administrator Vgldus Adarnkys to Senator John Glenn, transmitting EPA's
justification for not characterizing the waste material by toil core sampling with analysis for radionuelld**. December 18,1990,

      3 EPA, 1991.  Letter from EPA Region 5 Administrator Valdus Adamkys la Senator John Glenn, transmitting EPA'a
ground water modeling report which was used tp estimate the concentration of three potential radioactive sources downgradlent
from the lEL landfill at selected periods. March 23,1991.

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presence and potential heaith 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  background 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 radionuctides 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 radiochemicai 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 welts 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-Mueiler 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 opinions
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 IEL
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 dear 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 such
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.

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                             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?
                                      8

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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 Landlli (iEL)
Superfund site in Uniontown,.0hio. Citizens residing near the  IEL site were
concerned that radioactive wastes had been illegally disposed  at the site.
Administrator Reilly tasked Mr. Thomas Grumbly, 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 (Grumbly, 1992)4 to
the Administrator contained several recommendations.  With respect to radiation
sampling, Grumbly 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 arid 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 Gyfmond,
Deputy Assistant Administrator for the Agency's Office of Soiid 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 tht Adminisfrotof United Stated Envirvnrn&ntal Protection Agwtey - Concerning ffto /wdusftfa/ Exemss
Landfill Superfund $«to. Uniantown, OWo. Thomas P. Grumbly, President, Clean Ste*, Inc.  March 4,1S92. 36 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).
                                     10

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       3.  RESPONSE TO THE CHARGE TO THE ad 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 Getger-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
      burled  at greater depths.  Despite this high "faise 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 radtonuelldes.  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

                                      11

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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 Corings - 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
                                       12

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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 radionucJides 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,  dose enough
to ensure that the same geologic formation is captured, with similar soli and rock types
contributing to the natural radioactivity, yet far enough away to ensure that the
background wells ate 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 givtn to the decision to remove the
suspected wells from the background set,  and initiate further studies to determine
      5 See Rents 18.b), 13,e), 18J) and 13.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)8, 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 site3.  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 Gsoiogteai Survey (USGS), Water Resources Division, 975 We«t third Street, Columbus, OH 43212-3192.
     to Ms. Linda Kem, Remedial Project Manager, Region 5, USEPA. Rtvtow of wafer-level data and interpretations by PRC
Environmental Management, fne., in (wo mpoets: (1) Draft Ground Water Modeling Rapoit Industrial Excess Landfill $Ue, Uniantown,
Ohio (U.S. £PA, 1392), and (2) Pmtlmlnary f>»rrtedM Design - Industrial Excess Landilt SO*, UniantQWrt, Ohio, Draft Report, Volume
I, Chapters 1-10 and Appendix A {U.S. EPA. «93J,  Document dated August 13, 1993.

       T
       Due to site constraints which prevented installation of additional background monitoring wells, MW 12 and MW20 were
supplemented with two irrignttofi wtlte east of th* IEL landfill and several residential wells seme distance from the site,


       9 The usability of the MW2O cluster and other off-site wells for both chemical and radlocnemtcal background data will be
discussed by the Technical Information Committee and decided based on the conclusions in USGS (1993).


                                         14

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.provides an extensive data base on radioactivity in drinking-water.  White some are
 near nuclear facilities, others are not.  Comparing the radioactivity levels in the
 residential wells around the 1EL 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  I EL 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,
 #143, 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 10e 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.


                                      15


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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 widtft, 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.  It 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.
                                      17

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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 Roport on 0» Probability of Detection of Hypothetical Radloehamie§l Contamination of
Grwndwator at th* Industrial Excess Landfill- Unfontawn, Ohio, March 11, 1991. Prepared far the U.S. EPA by PRC. Submitted
is an attachment to SPA (1991).

                                       18

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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 tow, 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 tow 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, 19S1) 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.
                                     19

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3,2.1  Laboratory Analytical Methods

      3) Gross alpha analyses  are relatively rapid and low-cost. They are
      semi-quantitative methods that will detect unusual levels of high atomic weight
      radionuciides 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 of
      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-quantitative
      methods that will assist in detecting the presence of a large number  of
      radionuciides 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-iQ, 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 vaiue.
      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 spectrometry is a relatively low-cost quantitative  method
      suitable for screening for a  large number of radionuciides and can be applied to
      targe-volume samples.  Naturally occurring environmental radionuciides 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 rareiy gamma spectrometry will detect
                                     20

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      cesiun>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 radionudide
      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 radioehemtcal 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
                                     21

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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 targe 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 iike 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 1EL 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?
                                     22

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3.3.1  Considerations for other Superfund Sites in the 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,remed!ation 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 gross
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 ted 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.
         Qnjy one complete round of invalid results we« available for review (December 1390 data from Control* for
Environmental Pollution). The only results that were available (or review from the August 1990 round of invalidated data were the
carbon-14 results. The other results of the August 1990 round were returned to th* laboratory after the data was declared invalid
by EPA.

                                       24

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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 radlochemist and a Quality Control (QC) specialist) before a
      contract is initiated.

      c) The Agency shall verify that the lab 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 radionyclide
      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 level
      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 ciergy, 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 the 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 in 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. Grumbly (1992) states clearly in his report13 that EPA has been slow to
respond to legitimate concerns from thetcommunity around IEL  He attributes this to a
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
         Hie'scope of tie IEL radlochemical characterization project ha* baart taiga. Data presentation in a timely fashion
In i format preferred by the Panel may not have been a failure on the part of any agency but rattier i consequence dictated by
th« timing of the inquiry and the shorter timetable on whicn the SAB Panel member* were conducting their inquiry. Nevertheless,
the Panel still felt that data must be presented in a format that is clear and understandable to ad readers, particularly trios* with
the least technical expertise.
      13  Grumbly, 1992. Op Cit Py.9.'
                                       27

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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  Ftschoff (1993)16 predict that
individuals within any group with strong prior commitments will be iess 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 what those concerns are.  A
formal advisory board, such as  the TIC that EPA eventually implemented at lELf 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, 1892. O(» Ot. Pfl, 12.

      15 Bailee, R.P, and H,C, Jenkins-Smith, 1993. Politics snti ScmrttMe Sxptrtlso: Scientists, Risk Perception, and
Waste Policy.  Risk Analyst*, vol. 13, No. 4., pp 425-439.

      16 Maharik, M, and B. Fitchoff, 1993. Risk Knowledge arrtf Risk Attitude* Regarding Nwtoat Energy Sources in Spac».
*!»k Analysis, Vol. 13, No,, 3, pp 345-353,

      17 Lynn, F. and G, iusenberg, 1S94, Ctfz*/> Adv/sory Co/n/mttvw am* Environmental Polhsyi What wo know, whafs bit
to discover. Dept. of Environmental Selane** and Engineering. 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 l&7.n

      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 teamed 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 acf rtoe Panel on September 21,1993 by Norman FL NeWerpnfl. Associate Division Director fer
the Waste Management Division, Raaton g, USEPA.

                                      29

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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 iikeiy 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 US 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 Transmitta! of Radiochemicat 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
                                   RSG1ON 5
                          77 WEST JACKSON BOUtEVAHD
                             CHlCAGO.il  60604-3S90
MEMOBANPTJM
                                                              Z£PVt TO TW6 A77EKT1CH Of:
DATE;

SUBJECT;



FROM:


TO:
                  August 10, 1993

                  Industrial Excess Landfill
                  Catalogue of Materials for Review by the
                  Science Advisory Board
                  Usda A.
                  Remedial Project Manager

                  A, Robert Flaak
                  Assistant Staff Diiector
                  Science Advisory Boaid
At &e reqaest of the ad |o£ subcommittee of the Science Advisory Board (SAB), attached
please find a Catalogue of Materials regatdmff the Industrial B&cess Laadfil (rgT-)
site in Uniootown, Ohio. I Iiave included in tte ctialogQe of ffiaienals, a.
de^cripdon of asck docum-snt to assist la dissemiaatioa of the maicnala to the subcommittee
rnerabers.  Also included is a documentation listing- wMch. may be used as an abbreviated
form of die catalogue,
Tfiis traasmfttal of matedal laclodes is i
                                               was reepesced by th& SAB jjj. |jgj£
snticotnnattee during the course of the pn&Hc beating oa My 20-21, 1993
following: axceptious:
            p^x^ to your office a^sooit ask becomes available,
      2)
            taJteattay (BfAlEL) IbrtheMay 1992 aud August 1992: roond of
            coniftstieaawe- grooBd water saa|feg & isalyses witt be|oovided to year
           ...office- by. dM? week of Angast 1^. 1993. Iktte.iittesim^iliaMcsipyof the.
            radiological data results is included la tins, transmittaL

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      3)     As was indicated by USEPA during the SAB meetings last month, dhe 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
IEL site, please feel free to contact me at (312) 886-7341.
Attachments
      Robert Huggett (w/attachnieEts, w/out documents)
      Dorothy Canter (w/artachments, w/out documents)

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rl
                                               INDUSTRIAL EXCESS LAMDEELL
                                                 DOCUMENTATION LISTING
                 L      Report on the Initial Sampling Performed at IEL (April, 1983) .

                 2.      Remedial Investigation, (July, 1983)                                             " *

                 3,      Fsaabffily Study (December, 1983}

                 4.      ATSDR's  Health. Assessment (My, 1989)  Note:  Included as an appendix to this document is the
                        U.S. Geological Survey's 19SS Report rtgardkg ground water flow within, and i*o«nd the IEL site,

                 5.      Rscoril of Decision (My, 1589)

                 6.      Record of Decision - Alternate Water Supply (September,  |9t1)

                 7.      Final Work Plan. for Design Studies and Remedial. Design (April, 19SQ)

                 3.      QuaEty Awwanca Project Plan (Wy, 1991)

                 9,      Field Sampling Plan (My, 1991)

                 10,     Draft 30$ Remedial Design Docuawat (Febeuaiy,  1993)

                 L 1.     Diaft Ground Water Modeling Ruport (Fefereaiy, 1993)

                 12.     May 1992 Ground Water Monitoring and Residential Well SaotpinglibsuUs Technical Memoraadamt
                               , 1993)
                 13.     Tafafe of Moaitocns Wisfl Water Level* (Mama, 1993)
                 14.    :iUdb£ogic*lAi!afy!ic^R^tsJhmtte
                       Samples ColIiGiBd Dudfl^theRD
                                                                3t

                                                                saxs{Qen^
"•4                 .            c)      KacHodwmic^ Aojiyticit
 «

                 IS,    Radiological Analytical Result* tesKMEL." Staples Collected. Doiiflj t&e Qoattedy GrorawL Water
                                     flli.                                  *

                                      Ganptclleiasim Gruond Witcr Sampling: Roo*il Sidioietciad
                              b)      CgmpKhcaavc Gtoond Witter Sts^lkg Roond 2 l»&ffibsniktl Analytical laate
                                                1

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                                 c)      Comprehensive Ground Water Sampling Round 3 Radjochemical Analytical Results -
                                        December 19921J

                                 d)      Comprehensive Ground Water Sampling Round 4 Radiochemicai Analytical Results -
                                        Much. 1993 ^

                  16,     Contract Laboratory Prpgram Invalidated Radiological Results

                                 a)      August 1990 Inviildated Radiological Results

                                b)      December 1990 Invalidated Radiological Results


                  17.     EEL Technical Infofiaadoa, Committee Position Papers

                                a)      TIC Positions With. Respect to the Radiological Sampling at IEL

                                b)      TIC Positions with Respect to the Request to Perform Additional Soil Borings at the
                                        LaadfiE

                  18.     lafommtioa Collected to Date OR Backgioand Radieanciide Concentrations (August 1993)

                         a)      lafonnatioa
                         b)      U.S. Geological Sorvey's Ragionasl Aquifer Stoly Analysis Data Baas summarizes tritium
                                             found in aortiieaat Ohio
                         o)      U,S, Qeobgicai S«r»ey'§ Wsto-lesoaflMs Bjvestigttioa Report Ahsttact on. Geohydroiogf sad
                                   lity of water in Lucas, Sandusk/, and Wood Counties in north_w«ttm Ohio
                         d)      Occyoeica of Radon, Radian, ind. Uicauiam, in Groaudwaler, Jottraal AWWA, 1983: A
                                paper based OQ the Nfiiionai tucrjanitj and RftcUoauelides Srti JV^Wro-afrMitii; jjnm ggginfiffi AHffiirttjdrJtBr VaMaA
                         V. Adanlku*                        •                     ».                *

                         s>     Decanter IS, 1990

                         b)     Mraek 25,

                 20,
                 'Daia. will be madft ivailafal* on •annpottr dL»Jc as weH as 9. haul ccpjr
                 ^Dao. wil b? transmitted a* sooft as they an
s

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                                INDUSTRIAL EXCESS LANDfTLL
                                  CATALOGS OF MATERIALS
                                            FOR THE
                                  SCIENCE ADVISORY BOARD
1.      Raggrt_on the Initial Sampling Performed at IEL (April, 1583}

        USBPA*8 Environmental Response Team (£8.1) collected gas samples from the Methane Venting
        System at die IEL site ia January of 1988-  Tfi* results of these analyses were used to develop * target
        list for a soil gas and. indoor ak sampling program.

        Tie gas was tested da-site utilizing a, portable radiation survey octet, as well as detectons for hydnjen.
        stiin.de tad pdosgtQe, One soil gas Smarrja, canister and cbe background Summa canister we» seat to
        Che IP A eastern Environmental Radiation Facility in Montgomery , AJabam* for aaalysea for the
        presence of radioactive parameters including Radon.

        This analytical results of this sampling Is summarized in this report.

        This document consists of 5 pages*


2.      Remedial Investigation (July, 13S3)
       The Remedial Investigation. (RI) summari-™ the ds& collected to diaiacteaze the site in order to assess
       the Immediate or sotsntial threats EQ kumsn. health aad the aavitoaiDjcat pcs^ by the IEL site. TMs
                was fuuiized La 193$, tber«fom tbe following: infommtioii is compiled only thzotigh, 19SS
               Lafotnmdon U ptovided in the Draft 30S Remedial D«ign Dootsmt, dated February 1993):

               Sectioa I provides sits backpound informaa'os Inciuding_ i ate description, sU» history,
               fitonoUjgy of events, and i mmrnajy of prmoiiaiy obtain^ dati sad informatioa oa ^e site.
               T&» sectioa al»y pjovjde* tsnrnmaiy of fl» nature and attemt of tk* o»eajiBaJiaOiOfobfcax
               andimmmary af tae remedial Invesfigatioapiocess^ » well as aa overview of d» rcmcdiai
               iafesdgatioa report
               Seefieft % of tb> Deport desedfees- sjl» feanite* infilodfajdeniDgfaplif, land TWC,
                                                                             tfH P?f ^** *»fa» a-rga:
               dtedlnthatezL.
                                                                                    Eaciuded in
              this sectioa i* t. docription of th» geologic

                                                      . ami t  i
              ^^ncflf anoi

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                Section 6 presents the results of the air investigations conducted at aad around the site, and in
                the Uoioatowa community,

                Section, 7 describes the geophysical investigation that was earned out at the site.  This section
                discusses the techniques used aad the results of each of the types of surveys performed*

                Section 3 Is the public health evaluation.  This section discusses and svtiuation of the public
                health aad eaviroMoeatel concerns posed by the conditions & the site,

        The document consists of 2 volumes.
3.      FeasjhJJIfaLStMjfa (December, 198S)

        The Feasibility Study (FS) provides a detailed evaluation of the remedial alternatives and screening of
        the remedial pcoce^g options applying environmental, sagkweriflg, ind economic factors in accordance
        with (ho NCP and CES.CLA,

        This document, coupled with, the SI, provides Che basis for EPA"} selection, of the fui^l remedy for the
        DSL site.

        Tie document consists of I volume.
4.      ATSDR's. Health A&essment (July, 1389)

        The Agency fof Toxic Su&stanea and Disease Registry (ATSDR) Is nsandated by Congress to
        a Health A^seaarQcni for «ddt hazardous vssts site on tlie N"anooal Prioritia List CN?L).  A Health.
                  !A the ev&hialioo. of daii and infoonalioa oa Che release of hxzatddiis suhstancas Into ihe
                   in order to (1) asses any t^xrai£ or future kDp*ct3 on public health, (2) develop health
        idvisorie* or other health, rscoimnendatiotw, ud (3) identify jtsdks or icdoo* needed, to
        mitigate or prevent human health ilfccta.
        Inoiuded a* m appendix to this docameu* i» ic I9SS U.S. Greoiogical Survey (USGS) Kepott
        Evaluated, geologic md hydrogeolope date amukblc fironi the RI/FS^ and. Sflm U.S. Geological Survey
        data. (3*503, witb smpdiiaij oat haw weH ths ivailabia i<*ft« daseobo' jHKnid water flow within ami irouad.
        Tiiadwanient consist* of 1 TOtaaft.      '                  ^                *


5.      Recprrf of Pecsioir flRODV (Jaly^ 1583)

        TKi dociQBcaC cofltuflt t&0 RflCQttx OE TViM«Mw» md the Rf^oiisimicssi StnniDsiiy too USEPA ptcparco-
        for ttuk IHL jdbh. Tfi* ROD descrifac* IISEFA's ovendt appnaK
        problems aaaxdited. w^ tf» »|&  l^RespoDss^^
                            naaa^iML faant rfut pahH^ ami aduM- faflMnsateA tattiea att PsfeFA,*a ?ropoaed.
        Ptso, md prs»eixE* USE?A** jsspoma to those

        TIlB

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                  6.      ttaord of Decision (10P) > Alternate Water Sapplv (September, 1987)
;
                              documents describes USEPA's approach for providing an Alternate Water Supply to aa axea
                          comprised of approximately 100 homes oa Uaieatowfl, Olio,  This aetioa constituted an. operable unit
                          of the overall remedy for the site.

                          The document consists of 1 volume.
                  t,      HnaLWpA.Han_forT.'p!eslg!i,.Studies and "Remedial. Design (April,
                              work plan defines tb» scops and rational* of activities for the Remedial Design CRD) foe the Tyr.
                          site.  la addition, the work plan, dascribis ths activities necessary to complete the ED and provides a
                          detailed exphoatioa of the design activities.

                                 Section  1 provides die overall scope of the Remedial Design.

                                 Section 2 presents (he site background information.

                                 Section 3 presents tbs ID data needs and investigative approach, to obtain cfais data.

                                 Section 4 discssses tbe prelimioary activities that needed to b« conducted prior to die initiation
                                 of the ID.

                                 Section 5 describes the design studies necessary to obtain the *<«** needed to complete die RD.
                                 The nmjor slemeata of the design studies an ground water and aquifer
                                 landfill gas enaiacteiizittion; auriaca water, sedlmeiu, and. soil santamiaaQt oharactcrizaiioc;
                                 «d landfill eap svtlmiicut,

                                 Sectiett S describe* tb» semedM desiga aetivitie*.  TtLs section includes, a diacussicaioa the
                                 jW^ntfariQi^ af a. Aaafl^ii n»rt»jrfi]tl A*rigrt w*fr ^fart, tha
                                 dcagn, the ptofkui/flad. design, md accessary tonstructioa cootract jnppctt

                                                  thft TTC meeting
                               (
                                 B»rti»aiD«siil

                                 SectioaS deacnlra the ptqect jtaaag^^                                             for-
                                 the RD acsivitiei.
                                                               *
                         TMs docunraJ: deacxtb« ll» p*oo^^
                                  wttvitic* thatTJSHFA'i contractors, foflowoi to adricvo th» 4«t» qoali^ goal* tsfcujaaacd- for
                                         nh
                         TM* docomeat eoo«ot» of 2 volume

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                   ?.      Field Sampling P!an (YS7) Qvly,

                          The field sampling plan (FSP) deseift>« the sajnpliag procedures and collection methods that
                          fallowed by USEPA's contractors during the design studies phase of ths RD,

                          "His four principal ures of the Held investigation, consisted of the ground water and aquifer
                          characterization, the landfill gas eiaracterizatioa, the surface water, sediment, and solid
                          characterization, and the geotechnioi evslumtioa.  Tie FSP describes the sampling activities associated
                          with each of these ares.

                          Otter sections of the FSP provide laforcoatioa oa the site-specific objectives, sample liandUng,
                          disposal, 2nd proposed project scheduling.

                          This document is Appendix A of the QA?P» as described above, and consists of I volume.
                  10.     Draft. 30 fl Remedial Djsfeo Pocmnent (February, 1993)

                          Tie objective of this preliminary design report :* to present conceptual plans and specifications for
                          implementing USEPA's selected UamedM Action. ORA) at the site,

                          Prior to the inidadoa of the design of the RA cocttpoaeiits, 0SEPA sampleted desipi studies and field
                          testing in 1991  aad IP92 to suppiemeot infonoatioa obtained during the 198S 81. Ti* document it
                          organized ag follows:

                                  Chapter 1 introduces the pfsilmiouy design, report,

                                  Chapter 1 provides site background biformadoa.

                                         3 describes the design, stadia and field testing completed in 1991 asd 1992 to
                                            data- obtained during Jw Rcmediai, rnvtsUgadoQ,
                                 Chapter 4 identifies the design sttalegtes md the basis for th« design.

                                 Chapter 5 describe* tha lamipfl cap iid tb* sxpaaded. J^i^ffir gj^ ejtttactiatt
                                 Ciapter 4 de*ezib«» the jnmnd. water sdiactjoa tad t&ntmst system*
•*"*                              r^»|ite^ y jfjyaiff^. ifap flfonffttf. nf {f^p. Q|***ltfa|t -fr Mum1*?1 ""'I?

                                 Caapter f diactase* tho Omstroctiott Qoali^- ^ys»wi»»Plaii(CQA?) wfai
                                 during, contttocaoa of theRenediai Action for tjyrsitc.
                                                                           fef *tlf l«'^finr ^fp, the landfiH
                                 and treatment system, in

-------
        The analytical results of the design studies and field testing are detailed in this report. These
        summarize the following b forma tioai

               o      Landfill Gas Generarioo Rate and Chemical Composition
               o   _   Landfill Gas Migration
               o      Surface Soil Contamioattoo
               o      Sediment and Sarfkfis Water Contamination.
               o      Hydcogeologfc Coaaetmzstioii aad Mooitoriag WeE Installation
               o      Ground Water Contamination '
               o      Slug Testing and 0tound Water Modeling
               o      Geotechaiai Investigation
               o      Landfill Cap

        The document consists of 6 volumes.
U.     V^JSmmM&Wjte£M9deB.iie Tteport (February, 1553}

        THs, report snatnatizes USEPA's approaca to computoiied qaptttt* sooe modeling at IHL.  Tht
        purpose of the modeling was to provide information to support cbs preliminary RD of the ground -voter
        extraction and treatment system.

        Tbe fspott ptovidea MoaniJion. OB site history, »«olo§y, aad groond water hydrology,  A smnmaiy of
        the results of the capture zooo and Theis drawdowu oiodding, as weU as a. dbcosdoa of the model
        limitations is protrided. His dccument also presents nconimeadadoDS for i grooad waier
       USHPA'3 1939 ROD established design, ccteri*. chat j^qoired (1) sxtacting, and, toeadng. sonaTnfnated
       ground wxter beneath and near the landfill antil cleanc^ levels aro achieved, nul (2) pumping gfoond
       water to mamtam thfi q^atgr fetlda k-ite*A t>M» waata ia o^Au to pmteet ^mnmL water from atJdirioaat
       eanuminalioii, T3ii» sepoit addresses these critcri* and prMam infotmalioa related, io dw grocmi «stcr
       ixtracdon syitenit. including the aumber and locatioft of auracdom weili and pumping

          s docomcnt consists of 1 votane.
12.    May 1992 Grotnid Watq* Moiritaring and l^^t^pi^l Weil Sampling ttesrfte Technical
       Manofandont (Fgfactt«ryf 1MSI
                                 .                                              *
                                                              ••
                                                       lad^
                *; pfntfniffrt twi p^iyf MiftiJtittTt
       A compunscm of ^roond wnw nii^tici|jeinlt». fbc mspfe* cofliected Sonr nionitoriag-'vtlli ia Aagost
       139^ D«embcr 159^ I>cemb« im» in43^1992!»pi

       TSft xsults of the Aagast iSStDecaaAer 199& aadMascii

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13.     Table of Monitoring Wet! Water Levels (March, 1393)

       Tois table preseats monitoring well water level measurements takea it the EEL site during ssch ground
       water sampling event from August 1990 through March. 1993,

       TMs document Is summarized in 3 pages.
14,     Radiological Analytical Resute from the National Air and Enyiranmenta] Laboratory
       Samples Collected "Dunns the RP FMdwork Activities

       *)     Report p/j?adon_Meastirement?_ it ttX. (August 21, 1592)

              Tats report presents the foEowing kJonoation;

                      a      Radon CcMcentrstioas ta IEL Soil Gas Estracdon Wella;
                      a      M«isarB»eat of Sadoa-222 in MVS md Pilot Extractian Wells;
                      o      Mot Laodlil G« Eetrtttion Wells;
                      o      Landfill Gaseous Monitoring Well Radon Concentrations;
                      o      ladoa, k Water,
                      a      Bidaa Measurements in Explorator/
                      Q      Pylon Radon Detectors; and
                      a      Sadoa Flux
              Tliis document consists of 2S

       b)      gagortj>|_PartSculate Fl!tftr.Meaaagr»eflts from TEL (August 2S,
                  report ptesean toa for the partfctilate aaiapling of the Methane Vesting System and die
              thres pilot ess»ctiott wefl» for radiotetiw materiali.
                Js teport is summarized IB 3" pages,

       c)      Radlochemicai Analytical. Keaate for Samples from TEL (August 2S, 1992)
            5*

              Tic &st totOQ iD-fiBtsKoaDd. water samples from esck borehol* drilled on 2itB were
              and ni*lya*d for radiochemicai pafuwteo at HA&EL*  TS& results of these malyaci ar
              provided in tBbolMrfbcia.
                                                              *•
                                                               Tho result* af cbeso- malyse*
              Hew roall* a» |«es*at«d im t. total of 11

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15.     Radiological AnalyttoLlMaltS from jhg National Me and En-nroruraental Laboratory
       Samples Collected Pttdrjiglhe Quarterly Ground Wtter SampKng Program
       a)      Corop«.heniiy^ficOMfa
-------
        b)     December 1990

               The invalidated results of the December 1990 sampling event are contained La 2 boxes.  These
               data, are in the original form as received from the Contract Laboratory.

               A September 17, 1991 Memorandum from Greg* Dcmpsey to Curtis Rosa of the Central
               Regional Laboratory summarizes the December 1990 data review.
17.     IEL Technical Information Committee Position Papers

        a)      TIC Positions With Respect to the Radiological Sampling at TEL (May, 1592)

               In a April 2Sf 1992 con*spondenes to the EEL 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 IEL (I.e,, frequency of sampling, parameters, etc.).  Responses were
               received in May, 1992 ftora the Ohio EPA, ATSDR, and the Contained Citizens of Lako
               Township (CCLT).

        b)      TTC Poatfoia With Respect to the Request to Perform \d jftional Soil Borings at the
               During the May 19, 1993 meeting of the EL TIC, the eqjrnmittee agreed IB draft position.
               papers regarding the issue of performing additional landfill coring during the RD phase at IEL,
               Position, papers were received ftom the Ohio EPA, ATSDR, CCLT, and the Potentially
               Responsible Parties (PRPs).
13.    Information Collectgrf^tgjjatg qn Background ^j^onudidje^QgngaitjatiQn^ (August 1993)

       4)      Infoctiaiioii Sheets hac?e: b«ea compiled, sornrnarizing. properties, health osksr productiott and
               use, rcteaaes, :al& ia the envjjoniruat, monitored levels ia th& environment, and analytical
               methods fb* the following, isotopes:  thorium* plotooiunit maniamv rvJi'mii- critimii» carboa-14^.
       b)      U.S- GeoiogbaL Survey' j Rigional Aquifer Stody Aaalysii Dact Base anmmiiaet sid
       c>      U.S. Geologkii Sorvcy'i Wttcc-Raoorccft lomstipdioojtfipoie Abstract aa**eobfdraJes? ami
                                               and Wood Comdc»:ii

                                                      iaScw^^
                      of ittemptinj to obtain i. eo|iy of th* actotk dactbaaav poasfiity on disk.

               ErmrmniaiMR»dI«ncftAjnbia^                            An overview of trw ESAMS

-------
                    19,     Correspoodtnge .to .Senators John Glenn .and Howard Meteenbaum from Ttagfonal Administrate?
                            Vaidas
                            a)      December L8» 1S90 correspondence from Regional Administntot Valdas V. Adamkus to
                                   Sftoatocs John. Gleaa and Howard Metzeabaum transmitting U.S. HPA's jastifieafioa of
                                   reasoning for not eteaeteriziiig the waste material by soU core sampling with analysis foe
                                   fadjomielldes. Attachjaeats include a statistical analysis for the probability of locating
                                   jadtoafitive wastes based on the number of boreholes and samples to be taken, potential
                                   radiological contaminants agd estimated volumes, and a discussion of the 19SS ER.T testing of
                                   the Methane Venting System for radon.
                           b)      March. 25, 1991 conespondence from Regional Administrator Vildaa V. Adambia to
                                   John Glean and Howard Metzenbsum transmittuig U.S. EPA' a ground water modeling
                                   which was used to estimate the cocccatration of three potendal radioactive sources (cesium-
                                   137, tritium, and tnaunim-234/238) dcwngiadiitat trom the landfill 3l selected time periods.
                                   The bput fAianeteta chosen for the model wets based on avalhbi* site daa (prior to the
                                   imtiUatka of the new KB monitoring wells) sod accepted modeling practices, Abo- included
                                   ws th* faults of the- stpanded calculations usinj U.S. EPA's PSESTO waste burial computer
                                   model,  PRESTO is used to siodil long tenn impact associated with low level radioactive
                                   waste sited. The calculations, based on nypothedcai odioauclide inventory data, were made
                                   foe a. 1000 year period following closure- of the landfill.
                    20.     Questions & .^nsweff About the Industrial Tfecess Landfill Saperfjm.
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ONsEfft
Slite of Ohio Envirentpfintal Protection Agency

Northeast District Office
2110 E. Aurora ftoad
Twinsburg, Ohio 44087-'969
(215)423-9171
FAX (216)487-0798
                                Georga V, Voinovicr


                              Donald H.
                                                                                         Dlf e-etd ,•
      August 11, 1993                              RE;   Industrial Excess Landiuf'     ~—
                                                        Stark County
                                                        OHD 000 377 911 (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, FlaaJc.

      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 radioehemical issues and sampling
      results for this site,

      A catalog of Lhe documents contained in the submission is provided as Attachment I to this
      letter. Copies of all radiocheinicai 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 rtdiochetnicai data, will be provided by U.S. EPA during.
      the week of August 16, 1993.  Please note that Item D on Attachment I should accompany
      both paper copies of the radioehemical daGi (Items E through K) and disk copies of the data.
      when distributed to Panel members.

      If the members of the Panel have any questions, about this subjmasioa, or if ad&tionat
      documents are- required, please do not hesitate' to contact me (216-963-1126).
      Stacecdy,
             CorJoiE"
     Project Coopfinator
     Division of Emergency and Remedial Response

     JLC:!t
     enclosures

     cc;    Rod Seals, N
            Fran Kovacr CQ/LegaL
Bob Priacicr N1DO/DERR
Linda. Ka», U.S. EPA/Region V

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Attachment I:   Industrial  Sxcess  Landfill SAB 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  eacti  document,   document   title,  and  a  brief
description of  the  document  where appropriate.

                Document
Volume I

A              Correspondence  from J*.  Corkran  (OEPA)  to i».  ICern
                (USEPA) *  July  13,  1993.   Subject:'  Position paper-
               on  core  sampling  for radiochemical  lfhot  spats"
               during  Remedial Design activities.

B              Correspondence  from J. Corkrau to L. Kern, May 2s,
               1992,   Subject;  Position paper regarding the scope
               and  frequency  of  radiochemical sampling  at  TEL
               during  pre-design studies.

C              Correspondence  from J, Corkran to L. Kern, May 26,
               1993.     Subject:    Ohio  SPA  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.

0        ^      summary  of  Data  Qualifiers- for  Ohio SPA  IEL.
               HadicciLemical Data.

               'Shis, iten includes a chronological summary  of any
               data? point, correction* and invalidations^ deviances-
               from the? Quality 'Assurancer-Project.' Plait sampling
               protocol* and: relevant: correspondence required for-
               propec-.intsrpretatlott oC the;  cadiocbemicaL
                      not
                      oC tit* radioclt*«icAl, iattai (rtamat 5 Usrouglt ITA
                      and: Aisle copi**. oC tit*
E              01PA Qro«nd, Water- Split-Sampling:
               OBFJL Sround: Water- Split-*Sajipling:
               -Jtoe

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Attachment  I,  continued.
Location,

Volume I

G



H
Volume II

X
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
QSPA, Ground. »ater Split-Sampling Results:
March, 1993 (Draft) .

The  Model State  Information  System  (MSIS)  is  a
datmba.se that  organizes the results of radioctiemical
sampling  and  analysis  performed by  Public  Water
Supplies. (PWS) that rely on ground water and surface
water sources.  Gross alpha, and gross beta analyses
are typically reported.  The database,  organised by
county, is current through. 1992  and dates baclc to
1980 for a. limited number of public water systems.

Ofaio EPA, will be providing the MSIS data to- the ZEL.
Technical Inf tarnation Coiamittee for consideration, as
a  possible local database far  use  irt.  defining
              background  levels  for the? IEL site*
     to th* gcogrmpkicr location  off ISL. near-  the^
          of  three-  eoentias,  MSIS ifstrinigs:  for1
         Starte, and S«aiait Counties; are* pro.vide<±.
tills submission^  Only grouc<± water: source data
inclucledr*        :
                           InfoEmatiorr System,. Sadiological
                        Grooswi 5lat«r System&i
               Model State Inforaatioa System , Radiological
               Listing Ground Hater Systems:
               Stark. County f Ohio*

               JfodeL State rufomatrion Systeia, Sadiolag/icaO. Sample
               Listing, Grotuid Water Systems:
               Sunmit County, Ohio.

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION 5
                          77 WEST JACKSON BOULEVARD
                             . CHICAGO, IL 60604-3S80
 MEMORANDUM
                                                           SEPLY TQ TUg ATTENTION Cf-
 DATE:

 SUBJECT;



 FROM:


 TO;
September 7, 1333

industrial Exeass Landfill
Radiological Ground Water Sampling Results
December 1992 and March 1933
Linda A.
Remedial Project Manager  './"

Addressees-
         pitas* find, copies of the fatfowing materifls-for the tndustriat Excess
 LandfiU WEU Superttin tft* wpc9sawadSv*TschsHcafc In«5€mattcir Qjcofrtttsas CTTQ
members Ifstect belo wt as addrassaes: and ta incttvidcais- wha havft mad« specsff^
requests for copies ot thet data*

-------
In addition, copies of the data are being sent to the two SEL information
Repositories located at the Lake Township Clerk's Office and the Hartviile Branch
Library for availability to the pubHc.  If you did not  receive a copy of the data, but
wouid like to, please cai! me at {312) 886-7341 or toll-free at 1-800-621-8431.

The resuits of the December 1992 and March  1993 ground water results for the
inorganic, organic, and metal analysis will be transmitted under a separate caver.
Enclosures
Addressees:
Juiie Corkran, Ohio EPA  .,  ...  ;  *
Uura Barr, ATSDR     .  ^ .--.-• • »   ••••'•
Larry  Sweeney, Burlington Environmental
Christina Boreilo, CCLT
Henry Cole, CCLT         -  • --   -
Marvin Resnikoff, CCLT.;.   .....---     -   •   •    	
Steven James, Ohio Department of Health
information Repositories (Hartviile Branch Library &, Lake
Township Clerk's Office),
A, Robert Raak, SAB  .   ,      	 -  . •      ••."'.••
IEL Technical informatjon Dtetrifoutfon Ust (w/Fact Sheet,, w/out
data)  .                 ;•*; •.;, ----- •-, -•'- •-•  "  ••'   '"•r
Morrrr Niedergang,. USEPA {w/Fact Sneerr w/out data)
TTm Reids, USEPA tw/Fact Sheet,  w/out data)
                                                                                         r
                                                                                        - - r

-------
OftsEHV
Stale of Ohio Environmental Protection Agency
Northeast District Office
2110 E, Aurora Road
TwirtsbutI, Ohio 44087-1569
(216)425-9171
FAX (218) 487-0769
                              George V. Voinovic;
                                     Govsrnc
      CERTIFIED MAIL
      October 5t 1993
RE;   Industrial Excess Landfill
      Stark County
      OHD 000 377 911 (276-0416)
      Radiochemical Data Submission
      to the tJ.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, B.C.,
      Ohio EPA is submitting in disk format the radiochemical data generated by this agency
      during ground water sampling at this Superfimd 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 Lotas 1-2-3 (Release 3.0) format,
            ii.     Spreadsheet printout.
            Hi,    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/Eberllne Laboratory Analytical Methods and Reference table.

      The additional information required by the Panel regarding specific Ohio EPA radiochenucal
      data values has been requested of TMA/Eberlme and will be forwarded to the Science
      Advisory Board upon receipt by this office.

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Page 2
October 5, 1993
Robert Flaak
If the members of the Panel have any questions about this submission, please contact me
directly at (216) 963-1126.
Sincerely,
Julie L. Corkran
Project Coordinator
Division of Emergency and Remedial Response

XLC:lt

enclosures

cc:    (with enclosures)
      SAB ad hoc EL Advisory Panel Members
      Linda Kern, U.S. EPA/Region V
      Laura Ban, ATSDR
      Stephen James, ODH
      Chris Borello, CCLT
      Larry Sweeney, Burlington Environmental
      Mary Clark, NAREL
      Todd Fisher, NHDG/DDAGW   •

      (without enclosures)
      Bob Princic, NBDO/DERH.
      Rod Seals, NEDG/DERR
      Fran Kovac, CO/Legal

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           UNITED STATES SSVIlOMHSHTAL 1ROT2CTIOH
                             REGION V
    DATE;   October IS,  1993

 STJBJECT:   Industrial Excess Landfill (IBL)
           Transntittal of Radiochemical Data on Disk

    FROM-.'   Tinka G.  Hyde, Chief
           MN/QH Section £3

      TQj   Science Advisory Board (SAB)  ad hoc IEL Panel

 The purpose of this memo is to transmit information to the SAB ad,
 hoc IBL 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 0SEPA:   1}  Eadiochemical
 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  fallowing format:

 1.    MKr-w.iaCL - May 19S2 WATER* Rad, data- w/o QA/QC data
 2.   .AOG-W.WC2. « August 1992 mTSR Rad data w/o  QA/QC data
 3.    DlC-ff.iaCL » December 1S92 WATER Rad data w/o QA/QC data
 4.    Man-tf.ipa - March. 1993  WATER Rad. data w/o QA/QC data
 5.    Mir-F.WKi * May 1992 FILTERS Sad data w/o QA/QC data
 6-,    MRS-P.ina. • August 1952 FILTERS Ra& data w/o QA/QC data.
 7.    DBC-F.wci - December 1992 FILTERS  Rad. data w/o  QA/QC data
 3.    MAR.-F.WK1 - March 1993  FILTERS  Sad data w/o QA/QC data
 9.    VQA.WK1.   » 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  o£ the VQ& distributions
 10.  . SS-AH.WJCL » Samples requiring' reanalyaia from May 1952 round
      QNI.T.  Presented  separately due co mapping  constraints-.

 12.   QH-QC.-F.Wa - All FILTSIt QA/QC data (i.el,  blanks i MS/MSD)

Finally,  I1 ant  including- well location maps  and ait explanation  of
 the well numbering' system to assist you in,  youxr  review.  If you
have  any (|uestions»  please call me at (312)  S3€-929'fi.

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      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                REGION V
MEMORANDUM
DATE;

SUBJECT;


FROM;


TO;
November 16, 1993

Industrial Excess Landfill (!EL)
Transmittai of Radiochernicai Data on Disk
Linda A.
Remedial Project Manager  /

Science Advisory Board
gd, hoc Industrial Excess Landfill
Advisory Panel Members
The purpose of this memorandum is to transmit a set of maps depicting the
radiocnemica! data at the Industrial Excess Landfill |I£L) 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 transmtttal art a set of maps depicting the radiochernica! 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 all of tha information
requested. A map set represents 2 maps: 1) ana map, of the landfill propen and 2J
one map which presents the off-site wells.  This configuration results in 20
individual maps. The fallowing is a brief description of how the map  sets are
organized!

     Tritium daita:  All 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.

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1
f •/
                 Gross Alpha. Gross Beta. Uranium, Radium in Groundwater:  There ara 4
                 sets of maps which present this data. Each sat represents ah individual
                 round (May 1992, August 1992, December 1992, and March 1993). The
                 data are presented in small tables located adjacent to the corresponding weH
                 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 ara
                 presented for each well location sampled, Jf a weil is missing from a map,
                 assume that it was not sampled.

                 Gross Alpha, Gross Beta. Uranium. jjadlurriJn Filter Sampies: There are 4
                 sets of maps which present this data. Each set represents an individual
                 round (May 1992, August 1992, December 1i92, and March 1993). The
                 data are presented in the same manner as was described for the
                 groundwater.

                 Volatile Organfcs; 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 ware detected above  the Maximum Contaminant Level {MCU 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 hocLUEL Ador
          Dr. Robert Huggett* Chairperson
          or* Ann Bostrom
          Dr. Norman H. Cutshali
          Dr. Robert Morrison
          Dr. Oddvar Nygaard:
          Dr. Mitchell Smalt
          Dr. Michael Stein
          Dr. Jan Stolwijfc
          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)
Trangmittal of Mapping Program for Radiological Data

                         /*/""*
Linda A. KBm^^sprfgfrt&n^i1^7/r^'^f
Remedial Project Manager     }~/

Scienca Advisory Board
ad hog industrial Excess Landfill
Advisory  Panel Members
The purpose of this memorandum Is to transmit supplemental material to tha ad. hoc Industrial
Excess Landfill (IEU Science Advisory Board (SAB! panel members,

U.S. EPA's National Air and Radiation Environmental Laboratory (NAHEL! has developed a computer
mapping program which can ot utiiiied to display the radio-analytical 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 ths supporting documentation which will assist you in
the operation of tha program.

If you have any questions, please feel free to contact ma at (3125 388-7341.
SAg ad hoc IBt, Advisory Panat Members

Dr. Robert Huggett
Or, Ann Bostrom
Dr. Norman H. Cutshall
Dr, Robert Morrison
Or. Qddvar Nygaard
Dr. Mitcheil Small
Dr. Michael Steiit
Or, Jan Stolwijk
Or, Myint Thein

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