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