EPA Re Amended PCB notification - Former Studebaker Foundry 1100 Prairie Avenue South Bend Indiana

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From: Gmitro.Todd@epamail.epa.gov Sent: Monday, October 24, 2011 12:16 PM To: Stefanek, Ed Cc: gritchot@idem.in.gov Subject: Re: Amended PCB notification - Former Studebaker Foundry 1100 Prairie Avenue South Bend Indiana Mr. Stefanek: The U.S. Environmental Protection Agency has reviewed your change notice, dated October 21, 2011 which included additional characterization data and areas for bulk-PCB remediation waste removal at the above referenced property. The EPA is approving this request under 40 CFR 761.61(a)(3)(ii). After the extent of PCB contamination has been delineated, self-implementing bulk-PCB remediation waste removal should continue, and a Cleanup Completion Report prepared which documents the cleanup verification sampling required under 40 CFR 761 Subpart O. Unless there are significant changes in remediation plans, a separate EPA approval from the June 20, 2011 letter is not required. As for sidewall sampling requirements, the regulations are not clear, but EPA recommends following the 1.5 meter grid requirement as close as possible on the sidewalls and taking 9 point composites. Todd Gmitro, Project Manager Remediation and Reuse Branch Corrective Action Section 1 Tel: (312) 886-5909 From: "Stefanek, Ed" <estefanek@weaverboos.com> To: Todd Gmitro/R5/USEPA/US@EPA Cc: <gritchot@idem.in.gov> Date: 10/21/2011 08:51 AM Subject: Amended PCB notication - Former Studebaker Foundry 1100 Prairie Avenue South Bend Indiana Mr. Gmitro, This email is being forward to you as discussed in our earlier telephone conversation a couple weeks ago. Please reference the Self-Implementing Cleanup and Disposal Correspondence, dated May 5, 2011 and submitted to the USEPA, and your reply, dated June 20, 2011 as you review the following information. Also reference the attached figures and tables. During the demolition activities, Weaver Boos encountered elevated PCB concentrations in the soils adjacent to Transformer Room C (Area C) and at a separate location (Area D). Areas A and B were discussed in the May notification and have not changed. These impacted soils were encountered during screening of the soils beneath the entire footprint of the building. Sample locations identified as TP-44 and TP-71 were part of that overall screening sampling program. Weaver Boos subsequently completed characterized the extent of the PCB contamination both horizontally and vertically as noted in the attached table by collecting additional samples outside of TP-44 and TP-71. Results indicate that PCB concentrations greater than 50 ppm were isolated near the surface adjacent to transformer room in Area C and a 15 foot deep tunnel in Area D. (Note, samples were collected east of the transformer room but were OK). The PCB-contaminated soil adjacent to the location of Transformer Room C will be removed after the results of the confirmation soil sampling has been completed beneath the floor slab of the transformer room (as discussed in the earlier notification). Should the results of the confirmation sampling beneath the floor slab indicate that removal and disposal of underlying impacted soil be necessary, the impacted soil will be removed at the same time as the adjacent impacted soil described in this email. Once the PCB-impacted soil has been removed, then additional confirmation sampling will be completed in accordance with Subpart O of the PCB Regulations. The PCB-impacted soil identified as Area D will also be removed. Confirmation sampling will also be completed. The possible extent of excavation is indicated on the attachments. The PCB-contaminated soil that equals or exceed 50 ppm will be removed and disposed of at a licensed RCRA Subtitle C hazardous waste landfill. The PCB-contaminated soil that exceeds the Indiana 1996 VRP Tier II nonresidential cleanup goals but below 50 ppm will be disposed of at a licensed RCRA Subtitle D disposal facility. Cleanup goals will remain the same as indicated in the original notification. The results of the cleanup will be included with the overall Cleanup Completion Report. We request that this correspondence be reviewed by EPA as soon as possible. You indicated you could review this in a day or two. Landfill approval has been obtained so we are standing by. One question – How many sidewall sampling points are required? These excavations will at least be 3 feet in depth. I assume the floor sampling must follow the 1.5 meter grid sampling protocol but what about the sidewalls. If you have any questions or comments, feel free to contact me. Ed Stefanek Edward B. Stefanek | Sr. Project Manager Weaver Boos Consultants 4085 Meghan Beeler Court | South Bend, IN 46628 t. 574-271-3447 | f. 574-271-3343 | m. 574-302-0614 www.weaverboos.com | estefanek@weaverboos.com DISCLAIMER Designs, plans, specifications, technical documentation and other information in AutoCAD, PDF or JPG file format or other electronic format are provided by Weaver Boos Consultants AS IS, WITH ALL FAULTS, WITHOUT ANY DUTY TO RECIPIENT AND WITHOUT RECOURSE, are provided without corrections, updates or other support, and are provided solely for the internal convenience to recipient of being able to read and analyze its content via computer and to share the same internally with its personnel for the same purpose. The recipient understands that such electronic material/information can possibly be modified, unintentionally or otherwise, and that it might be incompatible with computers, software or devices used by recipient or others. 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If it appears you have received this email message in error, please notify the sender immediately and then delete; any other use of this email message is prohibited. Thank you. [attachment "SCAN2686_000.pdf" deleted by Todd Gmitro/R5/USEPA/US]