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Neal's Landfill
Conceptual Approach
for Hot Spot Removal
1. Hot Spots will be evaluated for removal at Neal's Landfill based upon
the following:
- Hot spots will be delineated by U.S. EPA and submitted to the parties
by June 1, 1998. Hot spots are defined as an area with PCB levels greater
than 500 ppm. Areas susceptible to backflooding are excluded from this
concept.
- Isolated hits of PCBs at 500 ppm or greater are not considered hot
spots. U. S. EPA will delineate hot spot areas for discussion purposes.
2. Areas Susceptible to Backflooding
- Hot spot areas susceptible to backflooding will be defined as areas
of 50 ppm PCBs or greater. Areas susceptible to backflooding will be delineated
in the June 1, 1998 submittal by U.S. EPA.
3. Confirmation Sampling
- Confirmation sampling will be completed on a 50 foot grid with 4 grabs
per grid composited together. Backflooding areas will be subjected to confirmation
sampling and a determination will be made regarding confirmation sampling
at non-backflooding areas at a later date.
4. Visible contamination within Hot Spot Areas
- Visible capacitors, capacitor parts , including paper will be removed
from the designated hot spot areas. Areas which show oily stained material
will also be excavated for disposal. If capacitors, capacitor parts or
oily stained material are outside the designated areas of excavation, then
those materials must be removed until they are not visibly present. If
a capacitor is whole or partially intact and holds free liquids, then the
capacitor must be incinerated. If no free liquids are present, then the
capacitor can be landfilled.
5. Segregation of Materials
- Material found in the excavation areas that are impermeable and or
large and appear impermeable can be set aside for reinterment. Material
which is visibly contaminated must be decontaminated prior to reinterment.
- Additional material such as the cap may be segregated without confirmation
sampling. Sampling with additional segregation within the excavated areas
may be appropriate based upon data developed duriug the excavation.
6. Consolidation Within the Area of Contamination
- Based upon the results from the sampling program, consolidation may
be appropriate for some material, such as areas that are subjected to backflooding
or subsidence.
- Consolidation would consist of placing the material on the existing
landfill and at locations not subjected to historical high groundwater
levels and known sinkholes. If consolidation is appropriate, further details
on the approach will be required, especially to prevent releases during
excavation.
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