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Overhead/Lodi Door Company -2- 3 October 1990 <br /> ,The other alternative suggested was to run WET's on the samples from quadrants E and <br /> J, using the de-ionized (DI) water extraction solution, and analyze for nickel . This <br /> should more closely estimate the potential for leaching nickel from the impoundment, <br /> providing their backfill material is clean and the pH is neutral to alkaline. Mr. <br /> Schweizer stated that they have not yet located the fill material . Sample results will <br /> also have to be submitted for the fill material , to ensure it is free of contamination. <br /> It was agreed that the fill material will be sampled and analyzed for pH and metals. <br /> If the results of the DI-WET are acceptable, the Board will be satisfied that the <br /> concentrations of nickel remaining in the impoundment do not pose a significant threat <br /> to ground water quality. Mr. Schweizer stated that the labs still have the samples <br /> from 16 May 1990. It was agreed that DI-WET's will be run for composite samples from <br /> quadrants E and J and for one other quadrant, as a check. The extract will be analyzed <br /> for nickel only. Ms. Hogg said she would check with DHS's lab and run the DI-WETS on <br /> the split samples she collected, if they had been retained. <br /> We also discussed the need to confirm that other wastes have been removed from the <br /> surface impoundment, other than the indicator parameters nickel and zinc. Nickel and <br /> zinc were the hazardous constituents in the original pond sludges. Therefore, we have <br /> been using them as indicator parameters. Concentrations of chromium and lead were also <br /> elevated in the original pond waste, although not at hazardous concentrations. Mr. <br /> Vaughn stated that the only other constituent that needs to be tested for is chromium, <br /> since chromium was in the original waste and there is significant concentrations of <br /> chromium in the ground water. We need to confirm that the soils remaining in the <br /> impoundment do not contain levels of chromium that would be of concern. It was agreed <br /> that the same samples that will be analyzed using the DI-WET (E, J, and one other) will <br /> also be run for total chromium. <br /> (On 5 September 1990, I collected samples from quadrants E and J of the impoundment on <br /> 5 September 1990. The samples were analyzed for both total and chromium VI. Brian <br /> Pletcher from RSI collected split samples for duplicate analysis. ) <br /> Once the sample results are received and approved by DHS and the Board, the impoundment <br /> can be backfilled as proposed in the closure plan. DHS will then write a letter <br /> certifying that the impoundment is closed and the contamination that remains in the <br /> impoundment is insignificant and poses no threat to human health or water quality. The <br /> sample results should provide that assurance. Ms. Hogg stated that after the <br /> impoundment is backfilled, DHS would consider the impoundment closed and the 0/LDC will <br /> no longer be considered a disposal facility. That will mean no more DHS disposal <br /> facility fees. The ground water investigation will continue under the Board's <br /> direction. <br /> GROUND WATER MONITORING SYSTEM <br /> We also discussed the adequacy of the current ground water monitoring system at the <br /> facility. I had prepared a memorandum discussing the subject and distributed it at the <br /> meeting. One of the Board's concerns is that chromium has generally remained above the <br /> drinking water standard of 0.05 mg/l in monitoring well MW-1 and periodically in MW-2. <br /> While it appears that nickel in the ground water has dissipated, chromium has not. <br /> Since the ground water has been impacted by chromium and it does not seem to be <br /> dissipating after almost five years of monitoring, a more aggressive approach is <br /> needed. The memorandum explained that we need to know the size, shape, and velocity <br /> of the plume and more refined S,T, and K values for the shallow water bearing zone. <br />