EPA Contractor Performing Tests at Superfund Site Has Mistake-Laden Past
New groundwater tests are being performed at the Industrial Excess Landfill (IEL) Superfund site in Uniontown, Ohio. These tests are being repeated as a result of numerous concerns raised regarding the EPA's previous testing. However, the validity of the current round of water testing being performed is already suspect due to the firm's previous involvement in this case. The EPA's continued use of the firm PRC/Tetra Tech, which has compromised earlier rounds of testing, goes against all logic and common sense.
According to documents available from POGO, PRC's earlier work at IEL consisted of:
- U.S. EPA found the samples "collected by PRC Corporation from IEL in Ohio" to have "several problems."
- PRC used plastic rather than glass jars in the samples taken at IEL. ". . . The . . . request specifies glass containers. . . Controls should be exercised over the performance of work not in conformance with the Quality Assurance Project Plan." The impact of using plastic containers with tritium samples is that tritium will bond to the sides of the plastic container, biasing the results.
- The EPA Ground Water Samples Protocols recommend that "groundwater samples shall not be field-filtered prior to laboratory analysis. . . [that] unfiltered samples should be used to estimate exposure concentrations. . . [and] does not recommend field filtration of samples used for leak detection." Yet PRC field-filtered when sampling the groundwater monitoring wells at IEL. There are a number of possible effects that could have had on the data: "information [is provided] on only the dissolved constituents that are present , because suspended materials are removed by the filtration process", exposure to the atmosphere due to field filtering is "very likely" to cause the exposed sample "to undergo chemical reactions that alter constituent concentrations", some "constituents migrating from the waste management unit to ground water are lost through field filtering, because they are unable to pass through a standard 0.45 micron field filter", and "field filtration of ground-water samples that will be used for metals analysis may not provide accurate information concerning the mobility of metal contaminants."
- PRC "accidentally" field-filtered two out of the four rounds of residential well testing. This procedure is not consistent with EPA's own guidelines: "Samples from drinking water wells should not be filtered since an individual would actually drink the unfiltered water."
- The Science Advisory Board concluded that the two background well clusters used by PRC are too close to the site and "are not adequate to reliably characterize the background condition."
- According to the EPA, PRC "made numerous mistakes in the chain-of-custody forms, among them duplications, mark-outs, and write-overs. This is not permitted and brings into reasonable uncertainty chain-of-custody on those samples."
- PRC lost or did not sample three of the monitoring wells at IEL: "Field sampling logs and chain of custody documentation should be reviewed to determine why filters from . . . three of the 13 sampling locations . . . from which both filtered water and filters should have been submitted to NAREL for analysis . . . were not submitted to the laboratory."
Because of the mistakes outlined above, the question then needs to be asked as to why the EPA is turning to PRC once again to conduct critical field tests that may be used in court to justify an inadequate clean-up plan. Working in good faith with the citizens at Uniontown requires that field tests be performed by an independent and qualified firm, one which has no previous involvement in IEL's mistake laden past.
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