EPA - COMMENTS ON 2/22/99 REVISED SUPPORT SAMPLING … · with OSHA regulations found at 29 CFR Part 1910 and U.S. EPA guidance document Standard Operating Safety Guides (Publication

/(p^>^\^/^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

\ REGIONS| 77 WEST JACKSON BOULEVARD

?* CHICAGO, IL 60604-3590

RE PLY TO THE ATTENTION OF

March 19. 1999(SR-6J)

Mr. D. Michael LightManager, Remedial ProjectsSolutia, Inc.10300 Olive BoulevardP.O. Box 66760St. Louis, Missouri 63166-6760

RE: Comments on February 22, 1999, Revised Support Sampling PlanSauget Area 1 Site, Sauget and Cahokia, Illinois

Dear Mr. Light:

The U.S. Environmental Protection Agency (U.S. EPA) and the Illinois EPA have reviewedSolutia's February 22, 1999, revised Support Sampling Plan for the Sauget Area 1 Site.Solutia's revised Support Sampling Plan does not adequately address all comments from U.S.EPA and Illinois EPA as outlined in our January 27,1999, list of comments. Further, Solutia'srevised Sampling Plan does not comply with the requirements of the January 21, 1999,Administrative Order by Consent (AOC) for the Sauget Area 1 Site. Therefore, U.S. KPA isdisapproving your February 22, 1999, Support Sampling Plan. Additional comments on thesubject document from U.S. EPA, including those from the U.S. Army Corps of Engineers, andthe Illinois EPA are attached to this letter. Please revise the Sampling Plan in accordance withthe comments and provide U.S. EPA and Illinois EPA with a final plan on or before April 9,1999.

Please note that failure to provide U.S. EPA with an approvable Support Sampling Plan thatincorporates all attached comments and is in compliance with the AOC will be considered aviolation of the AOC. In such event, U.S. EPA will consider its enforcement options including,but not limited to, completing the Support Sampling Plan with no further input from Solutia. Forthis reason, it is important that you contact me if you have any questions regarding the attachedcomments so that all parties can be assured of finalizing the Support Sampling Plan withoutdelay.

Sincerely,

Michael McAteerRemedial Project Manager

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 50% Recycled Paper (20% Postconsumer)

cc: Bruce Sypniewski, USEPAThomas Martin, USEPAPaul Takacs, Illinois EPATim Gouger, USAGEKevin de la Bruere, USFWS

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 5

COMMENTS ON FEBRUARY 22,1999, REVISED SUPPORT SAMPLING PLANSAUGET AREA 1 SITE

GENERAL COMMENTS:

1. Health and Safety Plan: Section V, subsection 2.1.1 of the AOC, and Section D of Task 1 _of the SOW require the submittal of a Health and Safety Plan as part of the Support Sampling */ ** /r*Plan. Solutia has failed to provide this plan as part of the February 22,1999, Support SamplingPlan submittal. The revised Sampling Plan must include a Health and Safety Plan that complieswith OSHA regulations found at 29 CFR Part 1910 and U.S. EPA guidance document StandardOperating Safety Guides (Publication 9285.1-03, PB92-963414, June 1992).

2. Quality Assurance and Sampling: Section V, subsection 2.1.2 of the AOC, Section C ofTask 1 of the SOW, and comments provided by U.S. EPA in our January 27,1999, list ofcomments on Solutia's draft Support Sampling Plan (see USAGE General Comment No. 3)requires the inclusion of all Quality Assurance and Quality Control (QA/QC) methods to be usedduring the sampling effort as part of the Support Sampling Plan. Solutia has failed to provideany QA/QC descriptions in the February 22,1999, Support Sampling Plan submittal. Therevised Sampling Plan must include a QA/QC plan that conforms to U.S. EPA QA/QCprocedures.

3. Ecological Assessment and Human Health Risk Assessment; Section B, subsection vi ofthe SOW and comments provided by U.S. EPA in our January 27,1999, list of comments onSolutia's draft Support Sampling Plan (see USAGE General Comments No. 1,7, and 8 andWeston Specific Comments No. 1,2, 3,6,7, 8, and 9) require the inclusion of a full descriptionof objectives and uses for gathering data relating to the human health risk assessment andecological risk assessment. The revised Sampling Plan must include these descriptions inaccordance with comments provided by U.S. EPA and in accordance with the SOW.

4. Sign-Off Sheets: Throughout the revised Support Sampling Plan Solutia has included astatement that "All sampling locations will be selected in the field with the concurrence of theUSEPA or its designee. A sign off sheet will be used to record the fact that the Agency, or itsdesignee, approved each sampling station location." This statement is not acceptable forinclusion in the Support Sampling Plan. As discussed at our February 17,1999, meeting, U.S.EPA plans to conduct oversight of all field activities and U.S. EPA's expectation is that Solutiawill consult with U.S. EPA on all proposed sampling locations and, where necessary, U.S. EPAor its designee will point out methods or locations that the Agency believes may be preferable toSolutia's choices. However, U.S. EPA or its designee will not "sign off' on any forms.

SPECIFIC COMMENTS:

1. Section 3.1, Extent of Cover Over Fill Areas: Solutia states that "Current to-scale aerialphotographs will be obtained for the Dead Creek watershed and used to determine current extentof cover on Sites G, H, I, L and N and prepare a contour map of the Dead Creek watershed."U.S. EPA agrees that this method will, in part, assist in determining the extent of cover, however,this work should be included in the Support Sampling Plan. If this is not possible at this time, itis Solutia's responsibility to provide written notice to U.S. EPA that it cannot complete thisportion of the required work and then provide the Agency with a schedule for completion of thiswork as part of the Support Sampling Plan.

2. Section 3.2.2, Local Uses of Groundwater: Solutia states that "A summary of all identifiedusers will be prepared and included in the EE/CA and RI/FS Support Sampling Plan Report."However, the document this in which this statement is printed is in fact the Support SamplingPlan Report. This information should be included as part of the revised Support Sampling Plan.

3. Section 3.2.2, Fill Area Groundwater: Solutia's proposal to collect only one groundwatersample from fill areas G, H, I and L from wells that are not even known to exist is inadequate todefine current groundwater conditions in these fill areas. Solutia needs to evaluate if any ofthese wells still exist and if they are still able to be sampled. The Support Sampling should theninclude the sampling of all wells on-site (EE-01, EE-02, EE-03, EE-04, EE-05, EE-12, EE-13,EE-14, EE-15, EE-20, EEG-101, EEG-102, EEG-103, EEG-104, EEG-105, EEG-106, EEG-107,EEG-108, EEG-109, EEG-110, EEG-111, and EEG-112) in order to update the data on currentgroundwater conditions. If some, or all, of the wells no longer exist or are no longer able to besampled, then Solutia needs to provide a proposal in the Sampling Plan for installing new oradditional monitoring wells in and near the fill areas.

4. Section 3.2.3, Undeveloped Areas: Not collecting any dioxin samples in subsurface soilsamples will leave a data gap in the area of risk evaluation for the potential future workerexposure pathway. Therefore, at least 20% of subsurface soil samples should include analysisfor dioxins.

5. Section 3.2.3, Developed Areas: From previous discussions between U.S. EPA and Solutia itis U.S. EPA's understanding that samples from residential properties in the areas near DeadCreek would be part of any soil sampling plan. While U.S. EPA agrees with Solutia's proposalto collect soil samples from open/commercial properties before collecting from residentialproperties, it still appears from the text that Solutia is predicating the sampling from residentialproperties on whether or not "COCs are present in floodplain soils at concentrations higher the(sic) TACO Tier I residential standards..." The Support Sampling Plan must include a proposalfor collecting samples from residential properties despite what is found on open/commercialproperties.

Also, if TACO, or any other standards are used for comparison/evaluation purposes, a copy of

2

these standards must be included in the Support Sampling Plan.

6. Section 3.2.6, Reference Area: A reference area needs to be established in advance of anyecological assessment work and included (including identification on a map) in the SupportSampling Plan.

7. Section 3.2.7, Pilot Tests: U.S. EPA prefers that any off-site facilities being considered forpilot tests be contacted and arrangements made for conducting the tests before approval of theSupport Sampling Plan. However, if this cannot be done expeditiously, it is Solutia'sresponsibility to provide written notice to U.S. EPA that it cannot complete this portion of therequired work and then provide the Agency with a schedule for completion of this work as partof the Support Sampling Plan.

8. Section 5.0, Schedule: The schedule should be laid out so that each work element begins andends within a set number of days following the beginning or end of another task. For example,instead of providing a date for commencing sediment sampling, the schedule should state thatthis work element will begin 7 days following Agency approval of the Support Sampling Plan.

Also, as stated above in the General Comments, the QAPP and Health and Safety Plan must beincluded with the Support Sampling Plan.

It is U.S. EPA's Opinion that the proposed schedule for completing work under this AOC/SOWdoes not demonstrate a full commitment fqr expediting the investigatory work at the Site. Itshould be noted that U.S. EPA's earlier stated expectation for completing the bulk of the workunder this AOC/SOW by the end of 1999, included the submittal of at least a draft EE/CA andRI/FS, not just the Data Report. U.S. EPA reiterates its earlier concern that several of the tasksare not being overlapped and seem excessive in their duration. U.S. EPA urges Solutia toprovide a more ambitious schedule with the goal of finishing both sampling work and a draftEE/CA and RI/FS by the end of 1999.

9. Figure 5: The location for the upstream sample in Old Prairie du Pont Creek should be at anappropriate distance from the confluence with Dead Creek so that the possible previous effects offlooding and flow reversals in both creeks would not demonstrate adverse effects from chemicalcontamination (in other words, please make sure a representative "clean" background sample iscollected).

U.S. EPA COMMENTS ON SOLUTIA'S RESPONSE TO AGENCY COMMENTS(FEBRUARY 22f 19991

1. Response to USEPA Comment 1 and Comment 2: In Solutia's responses reference is madeto the analysis of historical air photos "so that the Agency can select the center sampling point."

Please understand that U.S. EPA's role will be t.j evaluate any historical air photos provided bySolutia and provide comments on assumed center points and extent of fill after Solutia and itscontractors have made an attempt to do the same. Also, this work should be included as part ofthe Support Sampling Plan.

2. Response to USAGE Gomment 3: U.S. EPA is concerned about statements made by Solutiain this response regarding cost effective remedies and "most appropriate remedy." Anydiscussions about what is appropriate for remediation of Sauget Area 1 should be made after wehave completed all sampling efforts, pilot tests, and evaluated all possible remediationalternatives using a balanced approach. U.S. EPA expects that Solutia will work cooperativelywith the Agency while being open to evaluating a variety of remedial/removal options for theSite without prejudice to any remediation technologies.

3. Response to USAGE Gomment 24: The types of vegetation to be sampled should first beproposed by Solutia and then U.S. EPA will review and approve.

DEPARTMENT OF THE ARMYOMAHA DISTRICT. CORPS OF ENGINEERS

FORT CROOK AREAP.O. BOX 13287

OFFUTT AFB. NEBRASKA 08113-O287

BEPLY TOATTENTION OF - . , , o , _ - _March 18, 1999

Fort Crook Area

Mr. Michael McAteerUS Environmental Protection Agency, Region V77 West Jackson BlvdChicago, \L 60604

Mr. McAteer,

On February 17, 1999, representatives from U.S. Environmental Protection Agency, U.S. ArmyCorps of Engineers, Roy F. Weston Inc., and Solutia Inc. convened in Chicago, Illinois to discuss ourcomments to the Solutia Inc. Support Sampling Plan, dated November 19, 1998. After the meeting,USAGE anticipated the February 22, 1999 submittal would include a Support Sampling Plan (modified toaddress the many issues generated by our comments), a Quality Assurance Project Plan, and a Site Safetyand Health Plan. However, only the Support Sampling Plan has been submitted to date. While Solutia Inc.has changed sampling and analyses activities and added some narrative to address our comments, the Planremains a data collection document, with no rationale for data usage, which is needed to determine theadequacy of the Plan. Until all planning documents are provided and address the issues generated by ourcomments, in general site history, data quality objectives, and risk assessment information, we can notfinalize our review nor recommend approval.

As per your request, we have reviewed Solutia Inc.'s Support Sampling Plan, dated February 22,1999, and have reviewed Solutia's responses to comments on the Sampling Plan, dated November 19,1998. Our comments to both are provided in the attachments.

If you have any questions or comments, please call me at (402)293-2514.

Sincerely,

Attachments

Timothy P Gouger, PERapid Response Project Engineer

USAGE COMMENTS

USAGE RAPID RESPONSE COMMENTSto

SOLUTIA'S RESPONSE TO AGENCY COMMENTSand

SOLUTIA SUPPORT SAMPLING PLAN

March 18, 1999

USAGE COMMENTS TO:SOLUTIA'S RESPONSE TO AGENCY COMMENTS

Page 4, US EPA Specific Comment 4. While the source of contamination for Site M may indeed beDead Creek (CSA-B) as described in Solatia's response, inferring final characterization within thisarea from adjacent characterization is not satisfactory. Modify plan to include Site M for the followingreasons: The E & E report describes zinc and copper concentrations as percentages of the sediment inthree out of the three samples analyzed for metals. Degradation to the environment and wildlife frommetals is well documented. Also, the report describes PCB concentrations in exceedance of CSA-B,the reported source area. As the report describes dig depths to 14 feet, with the creek being close tograde surface, the hydraulics not only facilitate transferor sediments/contamination to this area butalso groundwater intrusion from adjacent areas.

Page 8, US EPA Specific Comment 10. The disposal of F020-F028 Dioxin Wastes is limited toSafety Kleen in Coffeyville, KS. If the evaluation of 104E and other site information indicates othersources of dioxins (e.g. PCB's, incomplete combustion products, unidentified sources), then thedioxins in the wastes are not regulated for disposal under RCRA, and other RCRA and /or TSCApermitted facilities are viable alternatives.

Page 9, US EPA Specific Comment 12. US EPA acknowledgement for site sampling locations isappreciated, but plan the work such that a clear, rationale understanding for proposed samplinglocations and the intention for data usage are provided in the narrative to guide field decisions.

Page 10, USACE Specific Comment 1. Though Solutia provides explanation for not samplingorganophosphates, the response illustrates the need to compile 104E information and other siteinformation in a historical section of the plan prior to finalization of the proposed analytical parameterlist.

Page 11, USACE Specific Comment 2. Review of 104E submittals after completion ofcharacterization work is not satisfactory. Providing a historical section in the Sampling Plan basedupon 104E, 103C review and other pertinent information is necessary to provide defensibility for datacollection, to streamline review of plans and reports and work execution. Providing historicalinformation in the EECA or RI\FS, as proposed by Solutia, creates an incentive to make historicalconclusions consistent with the completed characterization work.

Page 11, USACE Specific Comment 3. The E & E report identified Dioxin containing waste (F020-F028) as being managed by Monsanto in Site R. This information was provided, I believe, throughMonsanto disclosure in a 103C submittal and RCRA Part B permit. Solutia should declare either noother dioxin containing waste was disposed of in Sauget Area One sites or identify those additionalimpacted areas.

Page 12, USACE Comment 4. The intent of the comment is to allow for additional characterizationin the event compounds, possibly different from previous reports, are identified in significantconcentrations; data gaps may warrant additional characterization.

Page 13, USAGE Specific Comment 1. The Schedule in the Scope of Work describes streamlinedcharacterization work such that reports are provided approximately one year after data collectionbegins. The subsequent work activities (baseline risk assessments, EECAs, removal actions) becomestreamlined only if the planning documents, or at least subject matter described in this comment andothers, are proactively submitted well in advance of those work execution phases. If plans, or at leastthe subject matter described in our comments, are submitted as scheduled, then there is much greaterrisk the post characterization work becomes the traditional, time-consuming, reiterative CERCLAprocess that we all wish to streamline in the first place.

Page 15, USACE Specific Comment 10. The E & E report describes Site N as being poorly defined.Only two borings were drilled to characterize the site, with one boring showing visible staining at 6-10ft bgs and detectable concentrations of PAHs. As such, the waste characterization for Site N shouldinclude sufficient sampling and analysis for ecological, human health risk assessment, not just theproposed analyses for leachable organics and metals.

Page 19, USACE Specific Comment 16. Representative sampling is the intent of the comment.Trenching provides greater opportunity to identify representative waste material when compared to asingle 4-8 inch bore. Thus, waste depth trenching in source areas is desirable compared to a boring.

Page 21, USACE Specific Comment 23. A few points of clarification for the USACE comment arewarranted. The PUFF samples for dioxins and furans should be analyzed at high resolution to reducedetection limits.

SUPPORT SAMPLING PLAN COMMENTS

General. Throughout the Sampling Plan, Solutia states: "All sampling locations will be selected inthe field with the concurrence of the USEPA or its designee. A sign off sheet will be use to record thefact that the Agency, or its designee, approved each sampling station location." While thiscoordination effort is an excellent method to document understanding between Solutia and USEPA,the signature does not constitute a determination as to the acceptability of the sampling activities norlessen obligation or responsibility Solutia may otherwise have under CERCLA .

Page 2, Site Background. Site background information (e.g. past characterizations) for each siteshould be included in this plan.

Page 2, Past Disposal Practices. Include 103C submittal responses when researching historicalinformation.

Page 8, Fill Area Groundwater. Well log information needs to be included in the plan for existingwells: EEG-106, EE-01, EE-14, and EEG-103.

Page 9, Oowngradient Alluvial Aquifer Groundwater. Justify the use of push technologies tosample to approximately 100 foot depths. Any sampling beyond 30 feet bgs has required drillingtechnologies, based upon past experiences.

Page 14, Undeveloped areas. The soilsample collection plan now includes obtaining a surface samplefrom 0 to 0.5 ft bgs and the subsurface samples from 3 to 6 feet. The revised sampling strategyeliminates sample collection between 0 and 3 ft bgs, the soil interval most likely to be contaminated.Increase interval of subsurface sample from 0.5-6 ft bgs and take sample from area of highestcontamination.

Page 16, Leachate Samples from Fill Areas. Identify the quantity of water to be removed and atwhat rate before leachate sampling commences. Well descriptions are lacking in this section.

CENWO-ED-GI 12 Mar 99

MEMORANDUM FOR CENWO-CD-FC (Tim Gouger)

SUBJECT: Review of Revised Support Sampling Plan (February 22, 1999) andResponse to Agency Comments, Sauget Area 1 EE/CA AND RI/FS, Sauget and Cahokia,Illinois

1. The responses to comments indicate several times that a Human Health RiskAssessment Plan and an Ecological Risk Assessment Plan will be developed afterthe Support Sampling Plan is accepted as final. The responses to comments andRevised Support Sampling Plan still do not provide enough informationconcerning ecological risk assessment or any information at all about humanhealth risk assessment. The concern remains that the Support Sampling Plancannot be adequately evaluated without also having additional site backgroundinformation and planned risk assessment information available. A clearerdescription of the site and its background, the uses of the data, and theassessments to be performed is necessary to justify the sampling plan and is keyin determining if the plannedf sampling strategy is adequate. Recommendation foracceptance of the Support Sampling Plan cannot be provided without submissionof the information that has already been requested. If there are futuredisagreements about the risk assessment strategies, or the adequacy of thesampling to support risk assessment objectives, changes to the sampling strategy-may be reqirrrei, resettling in ieiays. Attempting to frnaiize me "Support "SamplingPlan without sufficiently detailing the uses of the data is detrimental to projectstreamlining and to achieving an aggressive schedule.

2. Some of the information provided by Solutia appears to be only in the responsesto comments and was not incorporated into the Support Sampling Plan itself. Alladditional information which was requested in the original set of commentsshould be included in the plan.

3. Response to USAGE Specific Comment 19 - In response to a previous comment,Solutia has revised the soil sampling plan to take surficial samples at 0 to 0.5 feetand subsurface samples at 3-6 feet. The concern now is that a gap exists for the0.5 to 3 foot interval. Considering the potential sources being evaluated(contaminant deposition via overbank flow and wind blown dust), the 0.5 to 3foot interval seems more significant than the 3 to 6 foot interval. Suggest addingsamples at this depth or replacing some of the 3 to 6 foot samples with 0.5-3 footor 0.5-6 foot samples.

4. Response to USAGE Specific Comment 25 - The USAGE comment addressedthe number of bioassay and benthic organism samples to be taken from each creeksector. The response to the comment primarily addresses the number of sedimentsamples to be taken. It still appears that only one bioassay, benthic organism and

vegetation sample will be collected from each sector. Again, at least 3 of thesetypes of samples from each creek sector are recommended.

5. Support Sampling Plan Section 3.2.5 - Please specify the TO method(s) to beused to analyze the air samples and ensure appropriateness of the method(s) forthe particular contaminants of concern at this site.

6. Support Sampling Plan, General - The plan states that all sampling locations willbe selected in the field. Although there may be a need to move some samplinglocations in the field, the plan should contain some reasonably accurate drawingsshowing proposed sampling locations. This allows for evaluation of possiblesampling locations before going to the field and minimizes the amount of timespent on this task while in the field.

If you have any questions, please contact Patti Thomason.

Parti ThomasonIndustrial Hygienist

WESTON COMMENTS

Confidential - Internal Review Draft

Comments/Suggestions on the February 22,1999 Draft of

Solatia's Sauget and Cahokia, IL Support Sampling Plan

The EE/CA and RI/FS for the site are to be expedited. Expedited refers to the time frame within

which the activities are to be completed. In order to meet an expedited schedule, many of the

planning documents, which oftentimes have overlapping data (e.g., the background and sitehistory sections of the sampling plan and risk assessment work plans) need to be combined and

presented before field activities begin. To meet an expedited schedule, the study plan must be

completed prior to any fieldwork, and does not allow for documents to be furnished in series or

iteratively.

WESTON provided Solutia with comments on the first draft of the sampling plan via and along

with the Army Corps and EPA in January 1999. First, it was expected that the comments were to

be incorporated into the sampling plan document, not just responded to in a "response to

comments" submittal. Any rationale or changes provided in the response to comments need to

be provided in the SSP. Second, WESTON disagrees with or finds many of the responses

provided inadequate. Presented below are WESTON's original comments, along with Solutia's

responses, and WESTON's reply to the responses. Also presented are a few replies to responses

to USAGE comments.

WESTON Specific Comment 1: For each of the media to be sampled (sediment, surface water,

groundwater, biological tissue), a clear statement of how the data are to be used in theEcological Risk Assessment is needed.

Solutia Response: A(n) Ecological Risk Assessment Plan addressing these issues will be

submitted to the Agency when the SSP is final.

WESTON Reply: The submittal of an "Ecological Risk Assessment Plan" after thefinalization of the SSP is unacceptable. To help expedite the EE/CA and RI/FS

processes, the EPA RPM deemed that there would be no separate work plan submittal.

1 03/18/99 2:57 PM


Since no work plan is to be developed for the EE/CA or RI/FS activities, the Support

Sampling Plan (SSP) must include some details normally found in a work plan.

WESTON will not recommend approval of the SSP without the requested details. Howsoil data are to be used in the Ecological Risk Assessment (ERA) will be required as well

as the aforementioned sediment, surface water, groundwater, and biological tissue data.

WESTON Specific Comment 2: An appropriate reference site must be included in the

sampling.

Solutia Response: After discussions with the Agency or its designee, a reference site will be

selected in the Dead Creek watershed or in a watershed that includes industrial, commercial,residential, and farming land use comparable to that in the Dead Creek watershed. Fish

tissue samples will be collected from three locations at this reference area for comparison tothe fish tissue samples collected from Dead Creek.

WESTON Reply: A reference location should be sampled for all of the media that are

collected at site (e.g., soil, sediments, surface water, groundwater, biological tissue) and

analyzed for the same components. The reference location also should be included as alocation for any bioassay or community structure analyses performed for the site.

In addition, please justify the number of locations and the number of samples for each

medium within each location to be collected from the reference area. It is unclear why

samples would be collected from three locations at the reference area, and seems

inadequate to collect just one sample from each location selected.

WESTON Specific Comment 3: Data quality objectives should be provided for each of thesampling and testing efforts proposed for this assessment. Or at the very least, reference should

be made to a QAPP that has this information in it.

03/18/99 2:57 PM


Solutia Response: A Field Sampling Plan will be submitted once the SSP is accepted asfinal by the Agency.

WESTON Reply: The streamlined process will not be effective if reports are submitted

piecemeal. These reports should be submitted concurrently to ensure that the DQO's are

appropriate.

WESTON Specific Comment 4 - For sediment sampling, in addition to the analytical samples,

total organic carbon (TOC) and grains size also should be evaluated.

Solutia Response: TOC and grains size will be performed for each sediment sample.

WESTON Reply: Acceptable.

WESTON Specific Comment 5 - As with sediment, there are several conventional parametersthat should be monitored in surface water.

Solutia Response: Hardness and pH will be determined for each surface water sample.

WESTON Reply: In addition to hardness and pH, total suspended solids and totaldissolved solids should be measured for each surface water sample.

WESTON Specific Comment 6 - For the sediment bioassay, please provide a clear statementregarding how these data are to be used in the ecological risk assessment.

Solutia Response: A(n) Ecological Risk Assessment Plan addressing these issues will be


WESTON Reply: The submittal of an "Ecological Risk Assessment Plan" after the

fmalization of the SSP is unacceptable. To help expedite the EE/CA and RI/FS

3 03/18/99 2:57 PM


processes, the EPA RPM deemed that there would be no separate work plan submittal.

Since no work plan is to be developed for the EE/CA or RI/FS activities, the SupportSampling Plan (SSP) must include some details normally found in a work plan.

WESTON will not recommend approval of the SSP without the requested details.

WESTQN Specific Comment 7 - For the sediment bioassay, please provide a more

comprehensive discussion of the proposed testing including the monitoring organism(s), testduration, type (chronic vs. acute), sediment collection method, sample preparation, treatment of

the resulting data, etc. Based on the limited discussion, the extent to which the bioassay providesinsight to the risk of sediment contamination is not clear.

Solatia Response: A(n) Ecological Risk Assessment Plan addressing these issues will be


WESTON Reply: See reply to WESTON Specific Comment #6.

WESTON Specific Comment 8 - Macroinvertebrate analysis - please provide detail on how the

collection is to be performed, the number of replicates, the level of taxonomic identification, etc.

Further clarification on why the benthic sampling is being performed - for tissue analysis, for

community analysis, for both? If community analyses are being performed, the approach shouldbe presented here.

Solatia Response: A(n) Ecological Risk Assessment Plan addressing these issues will besubmitted to the Agency when the SSP is final.

WESTON Reply: See reply to WESTON Specific Comment #6. In addition, upon furtherreview of the SSP, it appears that no benthic community structure sampling is planned.

This is an integral part of determining stress on an ecosystem and should be included inthe ERA.

03/18/99 2:57 PM


WESTON Specific Comment 9 - Fish Tissue - Please provide detail regarding the target

species of fish and the size range of fish that are to be collected for tissue analysis and therationale for that collection. Whole body fish from species and size class expected to be part of

the diets of the receptors used in ecological modeling should be collected and analyzed. Filletand offal are insufficient to reconstruct fish for ecological risks. Fillet and remaining carcass

data can be used to reconstruct fish as long as the weight of each portion is provided along with

the concentration data. Also, please include reference to a QAPP that provides the sample

quantitiation limits addressing data quality objectives for both the human health and ecological

risk assessments. Also, please include lipid analysis and provide the analytical method for that

analysis. Finally, why are no fish being collected from Creek Sections B, C, D, and E?

Solutia Response: A(n) Ecological Risk Assessment Plan addressing these issues will besubmitted to the Agency when the SSP is final. Lipid analysis will be added to the fish tissue

parameter list using the method specified by the Agency. Fish sampling was focused on

Creek Sector F because the borrow pit lake appears to be the best habitat area for fish and

wildlife, it is most likely to be the primary depositional area for sediments transported fromthe upper reaches of Dead Creek and recreational fishing is most likely to occur at this

location. Fish sampling was not proposed for Creek Sectors B, C, D, and E because thesesectors are essentially a storm water drainage channel in a densely settled area where

streamflow is intermittent and habitat is limited.

WESTON Reply: See reply to WESTON Specific Comment #6. Most labs automaticallyperform lipid analysis on any tissue sample. Please incorporate the rationale forcollecting fish at only Sector F into the SSP.

WESTON Specific Comment 10 - All tissues (general comment) - It is not clear why tissuesare being analyzed for SVOCs and the media samples are not. For example, why aren't SVOCs

being analyzed in sediments? Please explain or modify the sample strategy.

03/18/99 2:57 PM


Solutia Response: Fish sampling stations are co-located with sediment sampling stations so

both are being analyzed for SVOCs.

WESTON Reply. Acceptable.

WESTQN Specific Comment 11 - In addition to fish, a number of the target species also forage

on invertebrates, for example heron on crayfish. It might be worthwhile to add a few samples of

crayfish or other large invertebrate prey, if they occur there, to the tissue analysis.

Solutia Response: Fish were considered to be higher trophic level organisms that (than)

crawfish and, therefore, likely to have higher constituent concentrations because of

biomagnification. In addition, a large fraction of the food source for the piscivorous bird

selected for evaluation (Great Blue Heron) is fish. As a result, crawfish were not included in

the tissue analysis program.

WESTON Reply: Assuming that fish will have a higher concentration of constituents

because of biomagnification is incorrect. First, not all of the contaminants of potential

concern biomagnify. Second, for those that do biomagnify, concentrations in fish are

dependent upon the age of the fish and trophic level (i.e., dietary composition) of the fish.

Concentrations are expected to be higher in older, larger, and/or higher trophic level fish,

such as a largemouth bass that is a few years old. Since crayfish and other larger

invertebrates are intimately associated with the sediment, which tends to be a "sink" for

most contamination, concentrations in larger invertebrates may very well equal or surpassthose in younger, smaller, and/or lower trophic level fish. This is particularly important

because there are size limitations to the prey that piscivorous birds will take. For

example, a heron generally will not take fish greater than 30 cm (approximately 12

inches).

WESTON Specific Comment 12 - The purpose behind vegetation collection must be presented.Is there to be tissue analysis? If this concentration data is to be used for the modeling of

03/18/99 2:57 PM


exposure intakes for the mallard, vegetation species comprising a large part of their diet should

be the species collected for analysis.

Solutia Response: Vegetation sampling is designed to provide input to the Ecological Risk

Assessment which includes evaluation of a vegetation and benthic macroinvertebrate-eating

bird (mallard duck) and a vegetation-eating mammal (muskrat). Types of vegetation to be

sampled will be selected through discussions between Solutia's and the Agency's ecological

risk assessment specialists unless the Agency or its designee would prefer to specify the type

of vegetation.

WESTON Reply: Please incorporate the rationale for vegetation collection into the SSP.

In addition, some generalizations can be made about the type of vegetation to be collected

without choosing particular species. For example, a major part of the diet for both the

mallard and the muskrat is aquatic vegetation. However, the mallard generally eats seeds

while the muskrat eats the roots and basal parts of the plants (U.S. EPA, 1993: Wildlife

Exposure Factors Handbook).

WESTON Specific Comment 13 - It is assumed that no PCB congener data are being collected

in any of the media to be sampled. The absence of these data may underestimate the risk to

exposure to coplanar PCBs principally the non ortho-substituted congeners that are

lexicologically similar to the more potent dioxin. This is problematic for both the human health

and the ecological risk assessments. Because of the cost associated with these analyses, it may

be prudent to submit a couple of samples for this analysis to determine the extent to which the

dioxin-like PCBs may affect the estimation of risk.

Solutia Response: Method 8082, which includes Aroclor formulations and PCB congeners,

will be used to determine PCB concentrations in all media sampled.

03/18/99 2:57 PM


WESTON Reply: Method 8082 is appropriate; however, the list of congeners that will be

analyzed for should be presented either in the SSP or in the QAPP. These congenersshould include those with TEF values.

USAGE Specific Comment 25 - If the creek segments will be evaluated sector by sector, one

bioassay and one benthic organism sample from each sector doesn't seem like much to go on.

Suggest 3 samples from each creek sector.

Solutia Response: Sediment sampling (Section 3.2.3. of the SSP) will result in chemical

analyses of 50 samples:Creek Sector B 11 SamplesCreek Sector C 9 SamplesCreek Sector D 6 SamplesCreek Sector E 24 Samples

Total 50 SamplesMean and 95% confidence interval concentrations will be calculated for each creek sector

using this analytical data. Bioassay, benthic organism and vegetation samples will be

collected at the sediment sampling location in each creek sector with concentrations closestto the 95% C.I. value.

WESTON Reply: The method used to determine the sampling locations within the creeksector seems acceptable; however, taking only one sample from each sector still is not.

At least three samples from each location selected should be collected.

USAGE Specific Comment 26 - For fish samples, clarify what is meant by "offal." These

should be whole body samples for ecological evaluation offish-eating organisms.

Solutia Response: Offal means everything but the fillet. Whole fish analyses were not

proposed because fish fillet data is needed for the human health risk assessment (recreational

fishing). Whole fish concentrations will be determined from fillet and offal data by

weighting the whole fish, the fillet and the offal.

03/18/99 2:57 PM


WESTON Reply: Proposed fish samples appear to be inadequate to assess human health

and ecological risks. Although whole body fish concentrations can be calculated from

fillet and offal concentrations (provided the weight of each sample is available), it is

unlikely that ecological receptors will be taking prey the size of fish consumed by

humans, and vice versa, particularly since only one sample is proposed within each

feeding guild. Why fish are being sampled needs to be addressed, then appropriate

species, sample numbers, and sample type (fillet/offal or whole body) can be determined.

In addition to replies to Solutia responses, WESTON offers the comments below on the February

1999 draft of the SSP. Also provided are suggestions as to what would be expected to be

provided in the SSP.

1) The current SSP is generally of insufficient detail to determine if the sampling strategy is

adequate to support a risk assessment - either human health or ecological. In many cases,

the proposed sampling is inadequate to support risk assessments.

2) A section regarding the sampling strategy to fill the data needs of thehuman health risk assessment must be added.

3) The scope of work for the EE/CA and the RI/FS indicated that "The

EE/CA shall evaluate alternatives for conducting removal action on the Sauget Area 1source areas (Sites I, H, G, L, M, and N) and the impacted portions of Area 1 (Dead

Creek Segments CS-A, CS-B, CS-C, CS-D, CS-E, and CS-F and any possibly

contaminated residential/commercial properties near these creek segments)." Creek

segment CS-A is not mentioned in the SSP. Rationale need to be provided for the

exclusion of this creek segment, or it must be included in the media collection efforts ofthe SSP. Text from the response to comments to USAGE General Comment 2 would be

appropriate.

03/18/99 2:57 PM


4) Why are VOCs not being analyzed for from the environmental media thatis listed under the ecological risk assessment? Please explain why a full suite of

chemicals (including VOCs, SVOCs, PCBs, dioxins/furans) is not being analyzed for

within sediment for the focused analyses (page 18) and the borrow pit lake analyses (page

19), and air (page 21)? No descriptions of past site activities or a rationale for

eliminating chemicals of concern are presented in the SSP to justify this exclusion. It

seems particularly odd to eliminate VOCs from air sampling without justification and to

not sample metals when metal refining operations existed in the area. In addition, the text

on page 21 states that "All detected organic and inorganic constituents will be compiled

into a database." Inclusion of the inorganics in the database is impossible if analyses for

these constituents is not performed.

5) Surfical and subsurface soil and sediment depths should be continuous.

For example, surficial = 0-0.5 feet; subsurface = 0.5-6.

6) The "Evaluation of Toxicity" section does not address toxicity. Please

reorganize the text.

7) Under "Evaluation of Toxicity", page 22, the creek sector heading

erroneously lists sector F instead of E.

8) Pages 22-25, "Creek Sectors B, C, D, and E", "Creek Sector F", and"Reference Area". Because of the lack of physical description of the areas and the lack of

rationale for the sample numbers, WESTON cannot agree that one sample/location issufficient.

9) Pages 22-25, vegetation sampling. As stated in the reply to the response tocomment #16, ducks and muskrat eat different parts of aquatic vegetation; and therefore,discreet samples of each diet item must be taken.

10 03/18/99 2:57 PM


10) Benthic organism samples, vegetation samples, and fish samples should,

to the extent possible be co-located with sediment and surface water samples and

indicated as such in the text.

11) Under "Assessment of Endpoint Organisms", the only thing presented is

the receptor species and for some, to which dietary guild they belong. This is

unacceptable. The assessment of endpoint organisms must address which ecological

values of concern at the site will be addressed in the risk assessment. How are benthic

macroinvertebrate communities going to be assessed when no community structure

analysis has been proposed? How are largemouth bass to be assessed?

12) For "Exposure Pathways", it is not acceptable to reference "Assessment of

Endpoint Organisms" as the text now exists. No exposure pathways are discussed in that

text, except for the feeding guild of some of the receptors. In addition, exposure from

sediment and surface water ingestion should be addressed within the models as well as

dietary exposure.

13) For "Toxicity Testing or Trapping", it is not acceptable to reference"Evaluation of Toxicity" since that section does not describe any toxicity testing or

trapping. It only presents the number of samples to be collected.

Suggestions for the Soiutia, Sauget and Cahokia, IL Support Sampling Plan

In reiteration, since no work plan is to be developed for the EE/CA or RI/FS activities, theSupport Sampling Plan must include some details normally found in the work plan. Presentedbelow are suggested changes or additions to the sampling plan minimally needed to achieve anacceptable level of detail. These comments are provided in addition to the comments above andto those WESTON provided regarding the ecological risk assessment sections on 11 January 99.

11 03/18/99 2:57 PM


Comments Regarding Section 2.0 - Site Background

1. The site history should be reported here. Included should be available information

regarding the history of ownership, activities performed on-site, and potentialcontaminant releases.

2. A site description should be provided. This description should include size of source

areas and creek sectors, current land use, and an ecological description. The ecological

description should present all currently known habitat types and species known to occur.

3. The text currently states that a description of the data already available will be included in

the Support Sampling Report. The available data should be included in the Support

Sampling Plan so that it may be determined if the PRP identified all of the data gaps.

4. Readable figures (perhaps even in color) should be provided of the investigation site,

delineating the source areas and creek sectors. With all of the computer technology

available and the ability to include paper larger than 81/2 by 11 in a report, there is no

excuse for illegible maps. If possible, maps showing land use and ecological habitat

(e.g., vegetation, wetlands, surface water bodies) also should be provided.

Comments Regarding Section 3.0 - Data Gap Description

1. Once again, readable figures would be appropriate in this section. At this point, one

cannot tell where the creek is on most of the figures for proposed sampling locations.

2. If a particular source area or creek sector will not be sampled during a particular task

(e.g., sediment sampling), rationale for the omission must be presented. In, several places

throughout the text, only certain source areas or creek sectors are proposed for sampling.

One cannot ascertain from the text if the omission was accidental, or if there is a reason

for not sampling a particular area.

12 03/18/99 2:57 PM


3. All through the plan it is stated that "up to" X number of samples will be collected. For

characterization, it should be in the "at least" format.

4. Data quality objectives should be presented for each sampling effort, or the QAPP mustbe referenced.

Comments Regarding Section 3.2.6 - Ecological Assessment

Since there will be no formal "work plan" for the ecological assessment, the justification for the

sampling must be presented here in the sampling plan. To this end, a preliminary problem

formulation should be developed. Although in-depth information may not be available, a

description of the site history, brief ecological characterization, known and potential sources of

contamination, potential contaminants, potential transport mechanisms, migration pathways, and

potential ecological receptors must be presented. All of the data can be presented in the "SiteBackground" section. The known information must culminate in a site conceptual exposure

model from which assessment endpoints and measures of effects will be determined. Only then

can it be determined if the environmental sampling and proposed biological surveys and assays

are sufficient to support the ecological risk assessment. The sections reported in the Ecological

Risk Assessment Data Gaps should be reordered as follows:• Affected Ecosystem Description• Assessment of Endpoint Organisms• Exposure Pathways• Toxicity Testing and Trapping• Evaluation of Toxicity

Comments regarding each section are presented below.

1. Affected Ecosystem Description is listed as a data gap. The data that are available should

be included in the background section. EPA protocols and procedures to be used in the

ecosystem assessment need to be identified within this section. Included in the

assessment should be, at a minimum, wetlands delineation; other special habitats present;

13 03/18/99 2:57 PM


indication of cover types and areal extent; lists of vegetation and fauna (terrestrial and

aquatic) present; and a rare, threatened, and endangered species search.

2. Assessment of Endpoint Organisms Need to present an Assessment Endpoint/Measures

of Effects table (see Attachment 1 as an example). What are largemouth bass being

assessed for and how? What are mallards, herons, eagles, otter, and muskrats being

assessed for and how? In addition, organisms other than avian and mammalian species

are endpoint organisms, e.g., benthic macroinvertebrates and fish.

3. Exposure Pathways. It is not sufficient to state "see Assessment of Endpoint

Organisms." These two sections are not equivalent. What type of vegetation (aquatic?)

and which part (shoots, seeds, roots) are the mallards and muskrats eating? Also, need to

consider that there are other pathways of exposure than just food intake. Receptors can

be exposed through ingestion of surface water and incidental ingestion of soil/sediment.

A simple site conceptual model here could clarify many points.

4. Toxicity Testing or Trapping. It is not sufficient to state "see Toxicity Evaluation."

These two sections are not equivalent. Protocols of the sediment bioassays, invertebrate

community analyses, vegetative sampling and any other appropriate bioassays or tissue

sampling must be included. Justification for their use in the risk assessment must also

accompany the proposed studies. In addition, as with comment #2 under "Data Gap

Description", this section needs to present why no sediment toxicity assays or benthic

macroinvertebrate sampling activities or fish collection are planned for CS-A or CS-F.

5. Evaluation of Toxicity. What is currently discussed in the "Evaluation of Toxicity" section

should be discussed under "Toxicity Testing or Trapping". For the "Evaluation of

Toxicity" section, how toxicity will be determined for each measure of effects should be

discussed. Examples:

Surface Water - Discuss applicable federal (e.g, AWQC) and state environmental

water quality guidelines.

14 03/18/99 2:57 PM


Sediment - Discuss use of sediment toxicity values (e.g., Long et al. values,

OMEE values, EqP values), sediment toxicity test results. Discuss metrics to be

evaluated for the benthic community surveys, and endpoints for sediment toxicity

tests. The sediment triad approach should be used. To facilitate this approach,

sediment chemistry samples, benthic community surveys, and sediment samples

for the toxicity testing must be co-located.

Exposure Modeling - Discuss how modeled exposure models will be evaluated

should be discussed. Example comparing modeled dietary intake of a COPC to

reference toxicity values. Explain from where toxicity values are to be obtainedor how they will be derived.

Within these sections, assessment endpoints and measures of effects, can be used to

justify the sampling and bioassays.

Comments Regarding the Human Health Risk Assessment

No mention is made of the human health risk assessment (HHRA) within the "Support SamplingPlan". Since the proposed data collection in the "Support Sampling Plan" are to be used to

support the human health risk assessment, some details of the HHRA should be presented as a

justification for the sampling. This is especially important since, as previously mentioned, no

work plan is to be developed for the EE/CA or RI/FS activities. As suggested for the ecologicalrisk assessment, although in-depth information may not be available, a description of the site

history, land use, known and potential sources of contamination, potential contaminants,potential transport mechanisms, migration pathways, and potential human receptors must be

presented. Some of the information needed (e.g., site history, land use) will overlap with

ecological risk assessment needs, and can be presented in the "Site Background" section. The

known information must culminate in a site conceptual exposure mndel Ctam. wbJ/J?, vfiyuoiEK.

pathways, human receptors, and routes of exposure will be determined. A section regarding the

HHRA must be added that is analogous to the suggested "Ecological Risk Assessment" section

format. A suggested outline is as follows:

• Hazard Identification

15 03/18/99 2:57 PM


• Dose-Response Assessment• Exposure Assessment

Comments regarding each section are presented below.

1. Hazard Identification — This section should present potential contaminants of concern

based on past site-activities, known releases, fate and transport of contaminants, andpotential contaminant migration. Current and potential future land use should also bepresented. Most of this information can be referenced to the "Background" section of the

plan. In addition, the site conceptual model must be developed here, identifying potential

receptors and pathways of exposure. In this section, justification for researching the

number and locations of private wells in the area can be brought out. Examples of

potential exposure scenarios that may be applicable to the site include:

• Resident (adult and child) - groundwater ingestion, inhalation of volatilesindoor water uses, dermal contact with groundwater, inhalation of volatiles

from groundwater to indoor air, inhalation of particulates, incidental ingestion

of surficial soil, dermal contact with surficial soil, incidental ingestion of

sediments, dermal contact with sediments, dermal contact with surface water,

ingestion of homegrown vegetables/fruit, inhalation of volatiles whilewatering the lawn/garden.

• Industrial workers - incidental ingestion of surface soils, dermal contact with

surface soils, inhalation of particulates, inhalation of volatiles form

groundwater to indoor air.

• Site trespassers - inhalation of particulates, incidental ingestion of surficialsoil, dermal contact with surficial soil, incidental ingestion of sediments,

dermal contact with sediments, dermal contact with surface water, ingestion offish from Dead Creek.

• Landscaper/Maintenance Person - inhalation of particulates, incidentalingestion of surficial and subsurface soil, dermal contact with surficial and

16 03/18/99 2:57 PM


subsurface soil, incidental ingestion of sediments, dermal contact with

sediments, and dermal contact with surface water.

• Construction/Utility Worker - inhalation of particulates, incidental ingestionof surficial and subsurface soil, dermal contact with surficial and subsurface

soil, incidental ingestion of sediments, dermal contact with sediments, and

dermal contact with surface water.

A site conceptual model flow chart would probably suffice for addressing the exposure

pathways.

1. Dose-Response Assessment - Assessment of carcinogenic and non-cancer effects should

be noted. This section should then briefly present the proposed sources from which

toxicological information regarding the contaminants of concern will be obtained.

Sources should include IRIS, HEAST, and if needed, ECAO documents.

2. Exposure Assessment - Within this section, reference to the site conceptual model should

be made and the environmental data required for each of the receptors/exposure pathways

should be presented. Not only should the media that are required be listed, but the

sampling strategy, depth of samples (if appropriate), and minimum number of samples

for each receptor/pathway be noted. This may be most easily accomplished in table form

(see Attachment 2 as an example).

Adding this information to the "Support Sampling Plan" should give justification for the

sampling performed in support of the HHRA, and help to determine if the planned sampling

strategy is adequate.

17 03/18/99 2:57 PM


Attachment 1

Example of Ecological Assessment Endpoints and Measures of Effects

Receptor

BenthicInvertebrates

Fish

Piscivorous Birds

Omnivorous Birds

HerbivorousMammal

PiscivorousMammal

AssessmentEndpoint

Survival, Growth,and Reproduction

CommunityStructure andFunction






Measures of Effects

Sediment macro in vertebrate toxicity testing using Hyalella azteca and Chironomustentans.

Comparison of sediment chemistry with EPA SQC, Ontario LELs and SELs, andNOAA ER-Ls and ER-Ms.

Community composition, species diversity, richness, species density, and othermetrics compared with similar metrics at comparable reference locations.In addition, community metrics will be compared with co-located stressorconcentrations.

Comparison of surface water chemistry with AWQC and state surface waterregulations.

Compare stressor concentrations in adult fish tissue with reference concentrationsand Maximum Allowable Tissue Concentrations from literature.Toxicity Quotient based on dietary intake of stressors using site-specific fish tissueconcentrations and comparison with literature-based effect values.

Toxicity Quotient based on dietary intake of stressors using site-specific stressorlevels in vegetation and comparison with literature-based effect values.

Toxicity Quotient based on dietary intake of stressors using site-specific stressorlevels in vegetation collected in the impacted area, and comparison with literature-based effect values.

Toxicity Quotient based on dietary intake of stressors using site-specific fish tissueconcentrations and comparison with literature-based effect values.

18 03/18/99 2:57 PM


Attachment 2

Example of Sampling in Support of the Human Health Ecological Risk Assessment

Receptor/Pathway

Resident:IncidentalIngestion of Soil

EnvironmentalMedia

Surficial soil - 0 to 6inches

Sampling Strategy

Sample floodplainsoils parallel to DeadCreek every 50 feetwith a minimum of 1sample/residentialparcel.

Number of Samples

27 samples (with aminimum of 1 perresidence)

19 03/18/99 2:57 PM

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST, P.O. Box 19276, SPRINGFIELD, ILLINOIS 62794-9276I

THOMAS V. SKINNER, DIRECTOR |217/785-3912

Refer to: LI630200005 -- St. Clair CountySauget Area 1 Sites - SaugetSuperfund/Technical Reports

March 12,1999

Mr. Michael McAteerRemedial Project ManagerU.S. EPA Region 5, SR-6J77 West Jackson BoulevardChicago, Illinois 60604-9276

Dear Mike:

As requested, the Illinois Environmental Protection Agency (Illinois EPA) has reviewed Solutia's"Support Sampling Plan" O'SSP") dated February 22,1999. In general, there hasn't been muchimprovement over previous drafts that have been reviewed by Illinois EPA. Issues that relate tothe inadequacies of efforts to sample residential areas have not been addressed, nor has there beenany attempt to improve techniques to characterize the nature and extent of groundwatercontamination.

Illinois EPA passed the enforcement and technical lead on this project to U.S. EPA in hopes that anNCP-compliant environmental investigation would be performed at the Sauget Area 1 Sites. Itgoes without saying that Solutia is not making any reasonable attempt to give U.S. EPA anacceptable work product that complies with the NCP by guaranteeing that the nature and extent ofcontamination will be characterized (see 40 CFR 300.430(dX2)). Illinois EPA has never beenhesitant in voicing its concerns that residential areas near Dead Creek need to be sampled withoutany preconditions and that any investigation that does not lead to a remedy that guaranteesprotection of human health and the environment is unacceptable. These concerns were repeatedlystated to Solutia during negotiations that preceded the referral of this site to U.S. EPA, duringnumerous meetings with Solutia and U.S. EPA and in two sets of written comments on earlierdrafts of this document. As these concerns appear to have been overlooked again, Illinois EPAcannot guarantee that it will support a soil/sediment remedy that U.S. EPA may select at the SaugetArea 1 Site unless the extent of contamination in these residential areas is sufficientlycharacterized. In addition, Illinois EPA cannot guarantee support for a groundwater remedy,because the currently proposed RI/FS workplan does not guarantee that the nature and extent ofgroundwater contamination would be characterized.

PRINTED ON RECYCLED PAPER

Specific comments on this document are noted below. Contrary to Solutia's allegations, IllinoisEPA's previous comments (see November 13,1998 and December 17,1998 letters) on earlierversions of this document have been largely unaddressed.

1. Section 2: The site background section should contain a statement or acknowledgment that pastsite data taken by Illinois EPA and others is considered valid. This is very important in light of thefact mat conclusions based on this data will be used to justify a remedy.

2. Section 3: The data gap description should include an evaluation of the existing monitoringwells. As the SSP notes that some of these wells will be sampled for leachate analyses, thepossibility that there could be later disputes over leachate data validity should be resolved now.

3. Section 3.1, "Past Disposal Practices" (page 2): Although U.S. EPA 104(e) request responsescontain a large amount of disposal practice history, the writeup shouldn't be restricted to only thesedocuments and prior reports. Also, a list of chemicals handled by generators, transporters anddisposers (last sentence of this paragraph) should be prepared for Dead Creek as well as for fillareas. The source of this information should not be restricted to 104(e) responses only.

4. Section 3.1, "Waste Depths" (page 2): One soil boring at the "center" of each site is notadequate to determine the maximum depth of contamination, especially with regard to sites thathave not been fully characterized. This includes areas outside of the Site G fenced area U.S. EPAdiscovered during the removal action, areas between Site H and Site I on Queeny Avenue, and SiteN (see 40 CFR 300.430(d)(2)(iv)). Since the SSP "assumes" 40 feet below grade, is 40 feet themaximum depth Solutia is willing to go? Obviously there should be no limit. The second sentencestates that sampling locations will be selected in the field and the third sentence says that U.S. EPAmust approve each sampling location in writing - is this acceptable? U.S. EPA had already made itclear in one meeting that this would not be acceptable. These issues surface everywhere in the SSPwhere sampling is proposed. Also, the last sentence in the first paragraph says that Site M isadequately characterized and that no further sampling/analyses are necessary - does U.S. EPAagree with this?

5. Section 3.1, "Extent of Cover Over Fill Areas" (page 3): Are four trenches adequate to definethe boundaries of the landfills? A limited set of borings around the perimeter of each landfillshould give a better indication of where the boundaries lie. This is especially true for the areasaround the sites mentioned in the above comment.

6. Section 3.1, "Waste Volumes" (page 4): A credible waste volume at each site cannot bedetermined using historical air photos and the depth of fill information from the "Waste Depths"section. The methodology proposed here is inconsistent with 40 CFR 300.430(d)(2Xiii).

7. Section 3.2.2, "Horizontal and Vertical Distribution of COCs" (page 7): The statement thatEcology & Environment (E&E) defined the areal extent of VOCs/SVOCs in shallow groundwateris not accurate. The intent of what E&E was supposed to do was to characterize what the leachateconcentrations were around Site G, H, I and L. Illinois EPA has only limited information as towhat degree contaminants are migrating in "shallow" groundwater system from Sites G, H, I andL. It goes without saying that groundwater around Site N is completely uncharacterized. Themethodology proposed here is inconsistent with 40 CFR 300.430(d)(2)(ii).

8. Section 3.2.2, "Fill Area Groundwater"(page 8): It is not known if the "EE series" wellsmentioned still exist. The condition of these wells is also unknown (see Comment #2).

9. Section 3.2.2, "Downgradient Alluvial Aquifer Groundwater" (page 8/9): These paragraphsshould indicate what technique would be used to sample groundwater if push technologies don'twork. The sample locations noted in Figure 3 would not define the southern extent of groundwatercontamination (see 40 CFR 300.430(d)(2)(ii)). Also, Illinois EPA recommends the placement ofmonitoring wells in lieu of proposed hydropunch efforts in these paragraphs.

10. Section 3.2.2, "Bedrock Groundwater" (page 10): Two samples will not define the nature andextent of groundwater contamination in the bedrock. 40 CFR 300.430(d)(2)(i) states that thephysical characteristics (e.g. bedrock characteristics) be identified and 40 CFR 300.430(d)(2)(ii)states that field investigations to characterize the groundwater be performed.

11. Section 3.2.2, "Domestic Wells" (page 11): Is the 20-40 foot depth interval actually the sameof the domestic wells on Walnut Street and Judith Lane? There should be some attempt to findwhat depths the domestic wells are screened. Which four domestic wells are going to be samplednear the bottom of page 12?

12. Section3.2.2, "Upgradient Samples" (page 13): Solutia should propose upgradientgroundwater sampling locations. How can it be justified that groundwater concentrations fromtwelve-year old background data be compared to data taken in 1999?

13. Section 3.2.2 should provide for potentiometric maps for the shallow, intermediate andbedrock groundwater zones. 40 CFR 300.430(d)(2)(ii) states that field investigations tocharacterize the groundwater (e.g determining groundwater flow directions) be performed.

14. Section 3.2.3 "Undeveloped Areas/Developed Areas" (page 14-16): As noted in the preambleto these comments, Illinois EPA has serious objections in allowing Solutia to make the sampling ofdeveloped areas contingent on what is found in undeveloped areas. The language at the beginningof the "Developed Areas" writeup notes that sampling can be performed in developed areas ifCOCs are present in floodplain soils at levels above TACO Tier 1 and/or creek sediments show"hot spot" concentrations adjacent to residential areas. How are "floodplain soils" defined? Therealso seems to be a strong probability that the trigger for residential sampling are going to be Tier 1exceedences and exceedences of some arbitrary "hot spot" sediment concentration in Dead Creek.What are the "hot spot" concentrations?

As there are no concrete guarantees that residential areas would be sampled, exposure pathwaysand routes (e.g. ingestion/inhalation) cannot be reasonably evaluated. This is inconsistent withNCP (see 40 CFR 300.430(d)(2)(v) and 40 CFR 300.430(d)(2)(vi)).

15. Section 3.2.3, "Leachate Samples from Fill Areas" (page 16): Why are samples only collectedat Site G and Site I? In any case, it is arguable that only one leachate sample per site willadequately characterize the leachate.

16. Section 3.2.3, "Extent and Depth of Contamination in Sediments" (page 17-19): Illinois EPAdoes not agree that 100 total samples in Dead Creek will determine a credible waste volume (see40 CFR 300.430(d)(2)(iii)) as a 200 foot interval is probably too great. Is sampling in CS-B

necessary since it was already done at a 150 foot interval?

17. Section 3.2.4 (page 20): It still unclear as to whether surface water would be sampled at thetop 0.6 or bottom 0.6 of the water column.

18. Section 3.2.5 (page 21): Why aren't PCBs and heavy metals being sampled?

19. Section 3.2.6 (page 22): There should be two sediment bioassay/benthic organism/vegetationsamples taken in CS-E since the highest concentration of PCBs south of CS-B (60ppm) was foundthere. This concentration was found at the northern portion of CS-E.

20. Section 3.2.6 "Creek Sector F" (page 23): Why isn't there anything proposed in CS-Fbetween Route 3 and the western part of the wetland CS-F flows into (see Figure 7)?

21. Section 3.2.6 "Reference Area" (page 24): This writeup should note the location of thereference area.

22. Section 3.2.7 "Pilot Test Sampling Plan" (page 26): Does U.S. EPA have opinions on any ofthe vendors noted on pages 26 and 27?

23. Section 5.0 "Schedule" (page 28): The schedule notes that the SSP was submitted on11/19/98. Officially, the date should be 2/22/99. Also, it isn't reasonable to assume that the QAPPand HASP would be finalized in fifteen days - these dates should be changed.

24. Figure 3: This map allegedly shows the "shallow groundwater plume extent". This ismisleading since there is no coverage outside of the blackened area. Also modeling performed byE&E (Expanded Site Investigation, 1988 - Chapter 5) shows a much larger groundwatercontaminant plume.

If you have any questions or concerns, please let me know.

Paul E. Takacs, Project ManagerNational Priorities UnitDivision of Remediation ManagementBureau of Land

cc: Terry AyersClarence SmithChris PerzanTom Martin, U.S. EPADivision File

10=3128864071 M P R 19'99 1 4 = 2 6

TRRNSMIT CONFIRMRTION REPORT017NO.

RECEIVERTRANSMITTERDflTEDURPTIONMODEPflGESRESULT

314 694 62623128864071

MflR 19'99 14=2619'21

STD37OK

Documents

EPA - COMMENTS ON 2/22/99 REVISED SUPPORT SAMPLING … · with OSHA regulations found at 29 CFR Part 1910 and U.S. EPA guidance document Standard Operating Safety Guides (Publication