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Mclinton, Raymond
From: Wangerud , Ken Sent: Thursday , Ju ly 03 , 2014 1 :41 PM
To: David Abranovic Cc: Mark Ransom; R. David Gibby (dg
ibby@usmagnes ium.com); Jus t in Burn ing; Kevin
Lundmark; Cather ine D. LeCours ; Dor thea L. Hoyt ; Wangerud ,
Ken Subject : Re Sal t -Cap Accumula t ion Tes t : EPA fo l low-up
to ERM's Response to EPA Technica l
Comments on Sa l t Cap TM
David, etal:
Thank you for addressing EPA's June 11, 2014 comments on the
Salt Accumulation Test Plan Technical Memorandum (Test Plan).
ERM's responses and suggested revisions for the next revision of
the Test Plan are acceptable— with the following questions and
clarifications. Please address the comments below as appropriate in
your next revision/submittal of the Test Plan.
1. To clearly document the details of the salt cap accumulation
test, please provide drawings or figures for the test pond and the
associated monitoring devices. The drawings should be appropriately
scaled to clearly delineate the following information: a. The final
selected location of the test pond. Based on discussions with you,
I understood that consideration has
been given to revising the location of the test pond from that
shown on the figure included in the May 12, 2014 Test Plan (as we
reviewed on-site on June 19).
b. Dimensions of the test pond and impoundment berm. c.
Locations of the water inlet, staff gauges, and Piezometers. d. A
cross-section of the test pond including the berms and monitoring
devices. e. Details of the piezometers and berms.
2. Please explain and/or show on a drawing how the source water
will be pumped or piped from Pond 1 North to the test pond.
3. The Test Plan will be revised to include additional
monitoring; however, ERM does not believe it is practical or
necessary to conduct monitoring after storm events. The EPA agrees
that it may not be practical to inspect the salt cap after every,
relatively minor, storm. However, dissolution of the accumulated
salt from precipitation is important to understanding the overall
salt accumulation dynamics and characteristics. Please include a
discussion of how the salt cap will be inspected after a storm
event that results in 1.5 inches of precipitation within a 24-hour
period (approximately a 2-year, 24-hour storm event). The EPA
recognizes that access may be difficult in muddy conditions, so the
post-storm event inspection of the test pond may be conducted
sometime within a 48 hour period after the storm.
4. The Test Plan will be revised to include additional
monitoring to be conducted during the non-evaporation seasons
(November through April). The addition of year-round monitoring is
appreciated and should provide valuable information; however, it is
not completely clear from ERM's responses to EPA's comments which
monitoring will be conducted during the evaporation season (May to
October) versus the non-evaporation season. Please include a table
(example provided below) to clarity and summarize the monitoring
elements and timing:
Monitoring
Evaporative Season Weekly
Monitoring
Non-evaporative Season
Monthly Monitoring
Water level measurements at all staff gauges and piezometers X X
Detailed and consistent photographs documenting observations X X
Inspection of berms for integrity, including indications of seepage
or piping X X Inspection of accumulated salt for desiccation
cracks, impacts from freeze/thaw cycles, or other cracks or
dissolution features X X
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mailto:[email protected]
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Monitoring
Evaporative Season Weekly
Monitoring
Non-evaporative Season Monthly
Monitoring Observation and documentation of detritus, dust,
organic matter, or other impurities in the test pond X X
Collection of salt cores - 6 locations • Log and photograph core
material • Measure thickness of salt cap • Evaluate
homogeneity/heterogeneity and characteristics of accumulated salt •
Inspect for layering, impurities, detritus dust, organic materials,
or other
non-homogeneities • Classify precipitate material(s) as
crystalline, microcrystalline, or
amorphous.
End of evaporation
season.
End of non-evaporative
season (prior to first pumping at
the start of evaporation
seasons 2 and 3)
5. ERM explains the berm construction method will be provided in
the test pond as-built figures. While this is acceptable, the
construction criteria for building the berms should be defined
prior to construction to ensure that the berms are built of
suitable integrity and consistency. Please revise the test plan
and/or a drawing showing the test pond berm detail to specify the
required construction criteria or method for the benn (e.g.,
density requirement or compaction method, lift thickness, moisture
content) and to identify the material type and material source that
will be used to construct the berms.
6. ERM explains that Shelby tube samples will be collected of
the berm material for permeability testing by ASTM D2434 or D5084.
The EPA agrees these tests will provide very useful information on
the berms. Please confirm that a grain size analysis test per ASTM
D422 will also be conducted to aid in determining which of the
permeability/hydraulic conductivity tests is appropriate. In
addition, ERM indicates that visual observations of the berm should
be adequate for the salt accumulation test to indicate the presence
of saturation or water flow through the berms. It is agreed that
the monitoring proposed in the response is suitable for salt
accumulation test. However, during the larger scale
demonstration/treatability test, the EPA will require more thorough
and quantitative monitoring of the berms and substrate for
percolation, infiltration, and flow.
Please feel free to contact me or Catherine LeCours, PWT, if you
have follow-up questions. EPA understands USM would like to get
this test underway ASAP, and EPA supports that goal.
Ken Wangerud, Remedial Project Manager Superfund Remedial
Program Office of Ecosystems Protection and Remediation USEPA
Region 8 - EPR/SR 1595 Wynkoop, Denver CO 80202-1129
ofc. tel. 303-312-6703 fax 303-312-7151 [email protected]
From: David Abranovic [mai l to :David [email protected]] Sent:
Tuesday , June 24 , 2014 5 :52 PM To: Wangerud , Ken Cc: Mark
Ransom; R. David Gibby (dg ibby@usmagnes ium.com); Jus t in Burn
ing; Kevin Lundmark Subject : RE: Response to EPA Technica l
Comments on Sa l t Cap TM
Ken,
P lease f ind a t tached ERMs responses to your 11 June 2014
comment le t te r on the Sa l t Cap Accumula t ion TM submi t ted
on 12 May 2014. Also p lease no te tha t g iven EPA's concern tha t
the sa l t cap tes t a rea tha t we v is i ted on 19 June does no t
s t r ic t ly adhere to the spec i f ica t ions in the draf t Sa l
t Cap Accumula t ion TM, ERM and US Mag have dec ided to abandon
tha t loca t ion and cons t ruc t a new tes t a rea . The new loca
t ion wi l l have 'mud-f la t ' condi t ions s imi la r to
those
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mailto:[email protected]:[email protected]
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within PRIs 5,6 and 7, and adhere to all specifications in the
final Salt Cap Accumulation TM. Please feel free to contact me or
Kevin Lundmark if you have any questions regarding the attached
responses, we look forward to finalizing this TM as soon as
possible and initiating the treatability study.
david -
David J. Abranovic P.E. Partner
ERM West, Inc. 7272 E. Indian School Road, Suite 100 Scottsdale,
Arizona 85251 General: 480-998-2401 Direct: 480-455-6070 FAX:
480-998-2106 Cell: 602-284-4917 [email protected]
www.erm.com
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