Pi-Pa-TAG, Inc.
Pinellas & Pasco
Counties Technical Assistance Grant
1015
Wideview Ave.
Tarpon
Springs, FL 34689
___________________________________________________________________________________
Phone
(727) 937-2968 Email:
chimal@flasuncoast.net
Fax (727) 942-3978
December 11,
2000
John
Blanchard
Remedial
Project Manager
US
EPA, Region 4
61
Forsyth St., SW
Atlanta,
GA
30303
Dear
Mr. Blanchard,
Pi-Pa-Tag, Inc. received a copy of the Geophysical Studies Work Plan and
requested that it be reviewed by our Technical Advisors. The Board of Pi-Pa-Tag
has briefly reviewed
their report and appends
it hereto, thus submitting the report
as
Pi-Pa-Tag, Inc.’s official response to the Geophysical
Studies Work Plan.
PiPaTAG plans
a more in-depth review of the report and will notify you if there are any
points that we particularly want to emphasize.
Sincerely,
Heather Malinowski
Secretary, Pi-Pa-Tag Inc.
cc:
US Rep Mike Bilirakis
US Rep Karen Thurman
FL
Sen Jack Latvala
FL Rep Heather Fiorentino
John
Hankinson
(EPA)
David B. Struhs (FDEP)
Kevin Pegg (Technical Advisor)
Pat
Mulieri (Pasco County Commission)
Susan Latvala (Pinellas County Commission)
D. Michael Flanery (Pinellas County Health Dept.)
Robert Martin (EPA Ombudsman)
Carlene Hobbs (ACAG)
Geophysical
Studies Workplan Review
Region 4 of the Environmental Protection Agency and Stauffer Chemical Company together are advancing a cleanup at the Stauffer Management Company Superfund site in Tarpon Springs Florida. The cleanup plan involves in situ stabilization of subsurface elemental phosphorus and heavy metals that occur in some former ponds, plus consolidation of some remaining slag materials into mounds, possibly on top of the stabilized areas. EPA and SMC contend that the stabilization and consolidation cleanup are somehow safer than simply removing the material.
Portions of the site that require stabilization are near the banks of the Anclote River in an area that:
o historically has sinkholes;
o is subject to major rain storms and hurricanes;
o is known to have saltwater influx daily during high tide cycles;
o shows seasonal, diurnal, and diel changes in ground water flow direction;
o shows marked seasonal differences in groundwater levels;
o has apparent connections between the river and surficial aquifer;
o is in an area known for submerged cave systems;
o has apparent connections between the surficial and Floridan (municipal drinking water) aquifer;
o lacks a continuous geological confining layer, either of limestone or clay; and,
o has been substantially disturbed through past building and excavating activities.
The proposed stabilization remedy involves underground mixing of concrete formulations. To be successful in this application, the in situ stabilization may need to cure under saline hydraulic conditions, perhaps while water is flowing around and through the mixture. The cement will have to complex and stabilize highly reactive elemental phosphorus without forming subterranean voids. The stabilized mass will need sufficient compressive strength to support a mound of consolidated slag, cap, and landscaping. Also, the mound will have to have sufficient tensile strength to remain intact if minor sinkholes form beneath the stabilized mass during the next 500 years. There can be no caves or major fluid conduits beneath or laterally near the areas to be stabilized. Finally, the hydraulic properties of the cement must substantially exclude fresh and saltwater.
To date Region 4 EPA has not provided an example of an unambiguously successful use of in situ stabilization and has not provided data indicating that stabilization can provide long-term stability of elemental phosphorus materials. Accordingly, to address the highly experimental nature of the proposed cleanup EPA and SMC have proposed a series of geophysical studies at the site.
Received for review, the Geophysical Studies
Work Plan dated October 2000, contains descriptions of several experimental
techniques expected to provide information on the underlying geological strata
making up the Stauffer Chemical Superfund Site. This study is expected to
augment other studies for groundwater and in situ stabilization.
The study plan contains a number of very generalized figures and maps. Overall, more effort is expended in general description of the technologies to be used, rather than actual studies. The most relevant map, Figure 9, is little more than a preliminary sketch showing some potential areas for study superimposed over site borders and buildings. Figure 9 has little practical value for determining the relevance of the actual experiments to the study goals. Further, the figure contains diagrams of buildings and roads, but also contains marks purporting to indicate areas of studies, although not to any apparent scale. Based on the information provided, it did not appear that the studies’ authors have planned specific field data gathering activities at the SMC site.
This section describes the development of a survey grid to provide uniform reference marks for correlation of the data from different field data. Further the grid allows for equipment that requires parallel traverses to be aligned along common transects. The grid is described as being a “300-foot grid”, with some areas divided into 40-foot intervals.
No figures showing the grids are referenced in this section, and the “Figures” section does not show a grid system in any figure provided. Inexplicably, the last paragraph of this section launches into a discussion of microgravity measurements and elevation benchmarks, although no such description of elevation benchmarks is provided within the discussion, or, apparently, the document.
1) A proper figure showing the
40-foot grid and 300-foot grid should be provided.
2) The elevation benchmarks should
be clarified.
Figure 9 is referenced in this section as showing the “general area” of electromagnetic (EM) survey. However, the marks on Figure 9 cover the entire site, which cannot be a correct statement. Further, the orientation of the lines on Figure 9 do not match either the orientation or scale of the grid described under Section 2.2 for the survey. The “detailed survey” referenced in Appendix B is not a description of a survey as suggested by the text; rather it is a discussion on preparing the instrument for use and some very general remarks on the use of the instrument. This section contains a qualifier in line 2 second paragraph: “depending on the effectiveness of the instrument…” however, there is no explanation as to how ineffective measurement may impact the study as a whole, nor is there an explanation of alternatives if the technique fails to produce useful data.
3) This
entire section contains no useful information for evaluation.
4) Provide a
Figure referencing the areas of the EM survey relative to the grid described
under Section 2.2.
5) Clarify
the remarks on lack of effectiveness of the technique relative to the effect on
the outcome of making valid decision regarding in situ stabilization using the
data, or of its lack.
Figure 9 is referenced in this section as showing the “general area” of the Ground Penetrating Radar (GPR) survey. However, the marks on Figure 9 cover the entire site, consequently the description is inadequate. Appendix C contains no specific information on the survey to be conducted at SMC, instead it is a general protocol related to operation of the instrument with no practical information to evaluate. The description describes 10-foot survey lines, however it is unclear how the survey relates to the grid system described under Section 2.2, which describes 40-foot intervals.
6) This
entire section contains no useful information for evaluation.
7) Provide a
Figure referencing the areas of the GPS survey relative to the grid described
under Section 2.2.
8) Clarify the survey lines confusion from the incomplete references to the grid system.
Figure 9 is referenced in this section as showing the “general area” of the resistivity survey. However, the marks on Figure 9 cover the entire site, consequently the description is inadequate. Appendix D contains no specific information on the survey to be conducted at SMC, instead it is a general protocol related to operation of the instrument with no practical information to evaluate. Further, the text in this section describes the electrode spacing as 20-foot apart on 100-foot resistivity lines. This does not match the 300-foot and 40-foot spacing of the grid system described in Section 2.2, or the 40-foot traverses of the GPR study. It is unclear how the data can be compared as is claimed in Section 2.2.
9) This
entire section contains no useful information for evaluation.
10) Provide
a Figure referencing the areas of the resistivity survey relative to the grid
described under Section 2.2.
11) Clarify the survey lines confusion from the incomplete references to the grid system.
Figure 9 is referenced in this section as showing the “general area” of the microgravity survey. However, the marks on Figure 9 cover the entire site, consequently the description is inadequate. Appendix E contains no specific information on the survey to be conducted at SMC, instead it is a general protocol related to operation of the instrument with no practical information to evaluate. The description of the survey lines of 40-foot spacing along survey lines of 200-feet does not match the description of the grid system described in Section 2.2, which uses 300-foot spacing.
12) This
entire section contains no useful information for evaluation.
13) Provide
a figure referencing the areas of the resistivity survey relative to the grid
described under Section 2.2.
14) Clarify the survey lines confusion from the incomplete references to the grid system.
15) No
figures or charts are provided for any of the bathymetry or sub-bottom seismic
reflection studies. Please provide figures.
16) This entire section is devoid of description of the survey and its relevance to the project as a whole. Please provide description.
Apparently, magnetometer studies are only called for if buried drums or other buried metal objects are found by other studies. The magnetometer detects buried ferrous metal objects.
The in situ stabilization technique requires underground mixing of concrete formulations and waste containing elemental phosphorus. The presence of large chunks of material can interfere with the efficiency of the mixing process.
17) The technique should be
applied to all pond areas regardless of the outcome of other techniques.
This section references Figure 9. However, the description of the technique in this section is “MFEM” for multi-frequency electromagnetic survey and no such legend occurs on Figure 9. Figure 9 does reference a “VFEM” but it could not be determined if these are the same or different studies.
18) Clarify
both the areas to be studied and the orientation to the grid system described
under Section 2.2.
No information is provided on where the 20 geophysical logs will be conducted. An earlier study is referenced, however that study makes no references to these logs. It is not practical to evaluate the usefulness or relevancy of these studies with the information provided.
19) Provide bona fide description
of the areas to be logged.
There is no information in this section at all. There is no indication of how many studies will be done, how these correlate with other studies, or when the study will occur.
20) Provide bona fide description of the areas to be logged.
Conclusions
There have been a number of previous site characterizations, including magnetometer studies, test pits, and soil borings. Nevertheless, there is no practical use of this early data in any planning of these studies. Accordingly, the information here is vague and generalized. Overall, what is described in this work plan is a data “fishing expedition” that should result in only limited conclusions. It is unclear if any useful data relating to the remedy can be produced with these studies.
There is no reason a thorough study could not be planned given the amount of data previously collected. Without more information and a genuine figure showing where studies will be conducted, this work plan should not be approved.