Response to EPA Comments: RCRA Facility Investigation Phase I ...

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OTi 27 Naek Road Vernon Connecticut 06066 860-875-7655 FAX 860-872-2416 A Subsidiary of GZA GeoEnvironmental Technologies, Inc. GZA Engineers and GeoEnvironmental, Inc. Scientists June 24, 1997 File No. 41875 U.S. Environmental Protection Agency Office of Site Remediation and Restoration Corrective Action Section - HBT J.F.K. Federal Building Boston, Massachusetts 02203-2211 Attention: Mr. Raphael J. Cody Project Manager Re: Response to EPA Comments RCRA Facility Investigation Phase I Report T r\r\ 1 09 T Envirite Corporation: RCRA Docket No. 1-90 Thomaston, Connecticut Dear Mr. Cody: At the request of our Client, Envirite Corporation, we are submitting the attached data validation report for the UST interim measure and additional response comments to issues raised by the Town of Thomaston and outlined in the EPA Comments appearing in theu- April 25, 1996 letter to Envirite Corporation, regarding the report: RCRA Facility Investigation. Phase I Report, Thomaston. Connecticut RCRA Docket No. 1-90-1032. We note that the validation for the August, 1996 soil gas survey performed at Envirite is not complete at this time because the analytical laboratory has not provided the necessary documentation. We have attached a copy of Envirite's June 10, 1997 monthly status repon which provides additional information on the status of this project element. The following sections present additional discussion of select issues raised by information in reports submitted by the Town of Thomaston. Potential migration of contaminants from Envirite's landfills: The difference in groundw^ater table gradient between the Envirite property and the Town of Thomaston POTW is likely due to difference in the permeability of the materials which comprise the overburden aquifer rather than the presence of the Envirite Landfill. The Branch Brook channel was formerly located in the southwest portion of the Envirite Site (Page 21 of the RFI Work Plan), The former Branch Brook channel An Lqu.il Opportunity Employer M/F/V/H
az\ the also appears to represent the town line between Thomaston and Watertown and is shown on the Site Plan (Figure 1-2) of the RFI. Formerly, the stream flowed south across the southwest portion of the Envirite Site, turned east at the POTW property line and then turned south again. The presence of the former Branch Brook channel in the southwest portion of the Site would be expected to create a zone of higher permeability within the overburden aquifer. A zone of higher permeability on the POTW property would create a lesser gradient or flatter piezometric surface. Consistent with this prediction, Figure 3-1, April 1994 Shallow Overburden Head Contours of the RFI report depicts a steeper gradient in the southwestern portion of Envirite site with a lesser gradient to the south on the POTW property. While a groundwater mound under the landflll might also result in this pattern we do not anticipate that the landflll will result in the formation of such a mound. As discussed in Section 3.0 of the RFI supplement document, the permeability of the landfllled treatment residues is signiflcantly lower than the surrounding materials and the cap on cells 4 and 5 serves to limit recharge to the overburden aquifer. For these reasons the presence of the Envirite Landflll is not likely to create a groundwater mound that would affect the piezometric gradient or groundwater flow patterns. Regarding the presence of dissolved phase metals in site groundwater. A comparison of the RFI report. Figure 1-2 and the Acid Spill locations presented on Plate 7 of the RFI Work Plan reveals that seven of the wells (MW-42S, MW-43S/D, MW-44/D/B, MW-50S, MW-51D, MW-52D, MW-61S/D, and MW-62) noted in the EPA comments are located downgradient or sidegradient of the acid spill areas. Monitoring wells MW-30, MW-31D/B and MW-63 are located upgradient of acid spill areas. We did not assert that the acid spills are the sole cause of elevated dissolved metals in site groundwater, nor that dissolved metals in upgradient wells are due to acid spills. The RFI report states: ... Groundwater data also indicate that concentrations of copper, nickel, and zinc are highest in wells MW-43D, MW-44D and MW-44B, located at the downgradient property line. Data for pH levels in these wells are typically one to one and a half units lower than the rest of the site as well. These wells are located immediately downgradient of areas impacted by an on-site acid spill event which occurred in 1983. The spill is likely a source of these constituents in the wells since the observed metal constituents and depressed pH are consistent with the material released and constituent concentrations are decreasing over time (as reported in Envirite's last several Annual Monitoring Reports), which indicate that impacts are from a historic release rather than an on-going source.
Page 1: PREPARED FOR: Envirite Corporation
Page 5 and 6: "-fyiiAKK EnviRir e coRPORario n TE
Page 7 and 8: EnviRiTE coRPORarion TECHNOLOGY FOR
Page 9 and 10: -04/18/87 FRI 12:04 PAI 4109920347
Page 12 and 13: Data Validation Report for Envirite
Page 14 and 15: Mr. Tom Stark GZA GeoEnvironmental,
Page 16 and 17: Listed below are the Region I EPA r
Page 18 and 19: VOA The sample was analyzed well wi
Page 20 and 21: Inorganics Listed in the table belo
Page 22 and 23: Analyte Rec. (mg/kg) QC Limits Acti
Page 24 and 25: lAELES
Page 26 and 27: Table II - Overall Evaluation of Da
Page 28 and 29: Data Summary Table - Volatiles Samp
Page 30 and 31: Data Summary Table - PCBs/Pesticide
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