Response to Comments Provided by Indiana Dept. of Environmental Mgmt. for RCRA Closure of General Electric facility, Tell City, Indiana 5-18-17

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Comments Provided for RCRA Closure of General Electric facility, Tell City, Indiana 3-29-17

Chris Myer

 

Hazardous Waste Permit Section (IGCN 1101)

 

Indiana Department of Environmental Management

 

Office of Land Quality, Permits Branch

 

100 N. Senate Avenue, Room IGCN 1154

 

Indianapolis, IN  46204

 

 

 

Subject: Re: RCRA Closure Plan, General Electric Facility, Tell City, Indiana

 

Dear Mr. Myer:

 

Electronic Review for the Environment, Inc. has reviewed documentation related to the site and have the following comments:

 

  1. The “Public Notice of RCRA Closure” dated 2-9-17 was extended from 3-16-17 to 3-30-17. In the interim on 3-10-17, you issued a request for a workplan to conduct additional investigation. However, the later public notice did not mention the investigation request. Since the investigation may affect the closure plan, shouldn’t the public notice title have been modified to include “and notice of request for additional investigation”? And/or shouldn’t the public comment period be re-noticed at a later time? Please clarify the steps you anticipate, for example, will you require the closure plan to incorporate the findings of the investigation in a revised document or amendment? Wouldn’t that be required prior to approval of the closure plan?

  2. The Arcadis 12-23-16 report for the site - Further Site Investigation section 3.2 discussed that a potential discharge may occur at the creek. Therefore, please request that the workplan includes screening values for ecological receptors which may be present for the workplan to specify what detection limits will be ordered upon submittal of samples to the laboratory.

  3. Regarding the requested investigation workplan: a) please require the investigation workplan to address how to target optimal depths for soil vapor sampling since discontinuous soil types shown on the boring logs. For example, a continuous boring(s) should be advanced to identify sandy units where soil vapor samples should be collected. b) Since a contaminant discharge to a creek from groundwater may be occurring, please require aquifer testing to determine the groundwater velocity, transmissivity, and contaminant mass flux.

  4. Regarding the Closure Plan, please require that section 3.2 Conceptual Site Model (SCM) be presented in more detail. For example, USEPA examples of SCMs use infographics and/or table(s) showing the source(s), secondary source(s), media (soil, groundwater, air), routes of transport/exposure pathways, and considers the range of contaminants which include volatile organic compounds (VOCs) and polychlorinated biphenyls (PCBs).

  5. Regarding Discussion of Results, references should be provided for local background arsenic concentrations. While the document provides various resources to support the plan, it does not provide a reference list for the supporting studies. If no local background studies are available, a site-specific background evaluation should be conducted.

Sincerely yours,

 

By: Jungho Ahn - Project Manager

 

ELECTRONIC REVIEW FOR THE ENVIRONMENT, INC.

 

P.O. Box 2756

 

Berkeley, CA  94702