Woodward-ClydeEngineering s sciences applied to the earn 4 ,is environment

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December 15, 1994 Submitted via Facsimile86C3609P-213

United States Environmental Protection AgencyRegion V (HSRM-6J)Ohio/Minnesota Remedial Branch77 West Jackson Blvd.Chicago, IL 60604-3590

Attention: Mr. Ed Hanlon

Subject: Response CategoriesUSEPA's October 24, 1994 LetterComments Regarding Hydraulic ScourSediment Operable UnitFields Brook Site - Ashtabula, Ohio

Dear Mr. Hanlon:

In response to your letter dated November 17, 1994 requesting an update of efforts bythe FBPRPO, the attached response categories and annotated copy of yourOctober 24, 1994 letter are being submitted.

As indicated in correspondence received by Mr. Joe Heimbuch on December 12, 1994,these responses will be discussed during our December 19 and 20, 1994 review meetingsin Cleveland, Ohio.

If you have any questions, please do not hesitate to contact me at (216) 349-2708 orMr. Joseph Heimbuch at (313) 261-0280.

Sincerely,

Martin L. Schmidt, Ph.D.Senior Project Manager

cc: L. Weyer (CH2M Hill)S. Golyski (USAGE)R. Williams (OEPA)P. Delahunt (WCC -Chicago)J. Sikora (WCC - Denver)T. Wolfskili (WCC - Waterwood)J. Heimbuch (de maximis, inc.)FBPRPO Technical Committee

Woodward -Clyde Consultants • A subsidiary of Woodward-Clyde Group, Inc.30775 Bainbridge Road, Suite 200 • Solon, Ohio 44139216-349-2708 • Fax 216-349-1514

KK766/FB18/86C3609P/HANLON.001

Woodward-Clyde

RESPONSE CATEGORIESUSEPA OCTOBER 24, 1994 LETTER

COMMENTS REGARDING HYDRAULIC SCOURSEDIMENT OPERABLE UNIT

FIELDS BROOK SITE -ASHTABULA, OHIO

1. Comment requires significant additional work that was not previously agreed to.

2. Comment acknowledged. Response and requested change will be included in theDraft SQDI Report.

3. Comment acknowledged. Modifications and/or clarifications to the test will beincluded in the Draft SQDI Report.

4. FBPRPO does not agree with comment. FBPRPO will discuss during themeeting scheduled with the USEPA on December 19 and 20, 1994.

5. Comment does not require a response.

KK767/FB18/86C3609P/RESPONSE.CAT 12-15-94

SEV,: 10-24-94 - 8 o ; OFFICE OF SLFERRM^ 216 349 1514:* 2/10

Uffiz UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 5

Via Facsimile 77 WEST JACKSON BOULEVARDCHICAGO, IL 60604-3590

October 24, 1994Joseph A. Heimbuch REPLY TO THt ATTENTION OF:DeMaximis, Znc.33300 Five Mile RoadLivonia, Michigan 48154

REs Comments Regarding Hydraulic Scour; Sediment OperableUnit; Fielda Broolc Super fund Site

Dear Mr. Heimbuch:

This letter provides EPA comments to FBPRPO's 8/31/94"Hydrologic and Scour Analysis" documents which estimatespotential depths of hydraulic scour per reach within FieldsBrook. This document responded to EPA's 2/11/94 letterrequirements regarding this issue.

As noted in the general comments below, for EPA andUSAGE to complete its review, additional informationregarding the model's assumptions and input data isrequired. EPA requests that FBPRPO please forward thisinformation directly to EPA, USAGE'S Steve Golyski and RonHeath, and Laura Weyer aa soon as possible. Once thisinformation is received and reviewed, EPA will forward anyadditional comments immediately.

EPA expects the revised scour analysis to incorporateall of these comments. As has previously occurred, aconference call or meeting may occur to discuss any ofthese comments with FBPRPO prior to incorporation. As wasdone for EPA's comments to 3/28/94 Source Control RemedialInvestigation, if such a discussion or meeting occurs, EPArequests that a separate letter report be first submittedas soon as possible, within thirty days of receipt of thisletter, providing Iragreed-torr numerical categories for howand where each comment will be addressed.

If you have any questions concerning these comments,please contact me at (312) 353-9228.

J. Hanlon

Enclosure

cc: R. Williams, OEPA (via fax) M. Herman, EPA-ORCP. Felitti, EPA-ORC S. Golyski, USACEL, Weyer, Hill M. Schmidt, WCC (fax)C. McConnel, Bechtel (fax) P. Delahunt, WCC (fax)

vVV

SENV BY: aO-24-943;28̂ M7: OFFICE OF SLFERFLT̂ 216 349 1514;* 3/10

9

Enclosure 1:EPA Commenta Regarding Hydraulic Scour;

Sediment Operable Unit; Fields Brook Superfund Site

General Comments!

1) As noted in EPA's 2/11/94 letter, FBPRPO was requiredto reassess scour from a 100-year storm using the USAGEscour method described on the 2/2/94 call and providedwithin the 2/11/94 letter. FBPRPO's letter report wasrequired to provide a description of all of FBPRPO's inputand output (backup, calculations and assumptions)information used, including those used within the flowmodels (e.g., calculations, flow verification field tests,descriptions of cross sections, tables of 100-year stormvelocities for each cross section). All additional fieldinformation gathered and used as input information into theflow models, including information on Atterberg Limits,grain size analysis, and moisture content,'was requested tobe provided.

Review of the 8/31/94 document indicates that all ofthe above input information was not provided, and isessential to conduct a proper review. Also, Appendices Athrough D (i.e., sketches of hydraulics and supportingcalculations for hydrology, hydraulics and scour) were notsubmitted with the draft document and must be.Furthermore, disks of the models were not provided. EPArequests that FBPRPO please forward this informationdirectly to EPA, USAGE'S Steve Golyski and Ron Heath, andLaura Weyer as soon as possible. Specifically, all HEC-1,HEC-2 and HEC-6 input data files {i.e., the models) arerequested, with a clear listing of all input parametersused and the basis for such use, and identify which valueswere derived from tests and which from literature/experience. Calculations must be provided for all derivedinput data. Once this information is received andreviewed, EPA will forward any additional commentsimmediately.

It is also not clear upon review of the 8/31/94document that FBPRPO used the 2/11/94 methodology which EPAprovided to estimate potential scour, FBPRPO must makeclear whether another method was used. If so, FBPRPO muststate why another method was used, and provide an analysiswhich makes clear that the other method would minimally beequivalent to the 2/11/94 method.

2) The model must be re-run using more a conservativeprecipitation event. FBPRPO used the TP-40 data, and it iswell known that 100-year precipitation depths estimated byTP-40 are, in general, too low to be realistic. The

SENT BY:U.S. EPA ;10-24-943:28832̂ f' OFFICE OF SLPERFLM^ 216 349 1514;* 4/10

weather data used as a basis for TP-40 were collectedduring several dry decades. Since the publication of TP-40in 1961, 100-year precipitation depths have been revisedupwards throughout the midwest. Presently, the MidwestClimate Data Center Bulletin 71 (1992), entitled RainfallFrequency Atlas of the Midweat by P.A. Huff and J.R. Angel,provide the best estimates for large recurrence intervalprecipitation events. Table 1 enclosed below indicates thedifferences between TP-40 and Bulletin 71. Bulletin 71also has recommendations regarding the time distribution ofrainfall during an event. FBPRPO must revise computationsand use the more realistic 100-year rainfall depthspublished in Bulletin 71 in a re-run of the model.

3) PBPRPO must also conduct and provide a sensitivityanalysis which provides the range of acceptable parametersfor the following assumptions used in the model (listed inorder of importance): critical shear stress, sedimenttransport function, sediment inflow, and the roughnesscoefficient (i.e., Mannings n),

These several key parameters significantly affect theanalysis and appear to be estimated in an unverified andpotentially unacceptably unconservative manner (e.g.,critical shear stress and erosion rate constant estimatebased on 60% clay, but an average of 10V clay exists in thesediment). FBPRPO must justify why these parameters wereestimated as such.

4) Since FBPRPO did not collect field data from FieldsBrook to field-verify the acceptable parameter to be usedfor each of the above-noted assumptions, EPA requires thatthe model be re-run using the most conservative parameterindicated from the above effort for each of the aboveassumptions.

5) FBPRPO must verify which version of HEC-6 was used; ifthe version 4.1, which is the most recently revisedversion, was not used, EPA requires that the model be re~run using this version (since it is more suitable forcohesive sediment transport analysis)'.

6) As noted within comment #10 of USACE-WES's 10/4/94enclosed comments (see Enclosure 2), the bed-load equationused is not the best sediment transport function for finesand. Other equations related to the sediment transportfunction used within FBPRPO's model will change based onthe varying field data present. FBPRPO must asseas whichequations are inappropriate based on known fieldconditions, and re-run the model using the most appropriateequations indicated from this effort. FBPRPO should referto the HEC-6 manual for guidance on use of the mostappropriate sediment transport function to be used.

SENT BY-U-T'HPA ^ = 10-24-94^ ̂̂ Sf: OFFICE OF SLPERFL̂ 216 349 1514;* 5/10

Specific Commentgt

Page 4-3. Land Use. Some of the land use and vegetativecover data are based on mapping almost 25-years old;significant changes have occurred since that time withinthe watershed, including increased areas which are pavedand covered, which would tend to increase releases duringrain events, FBPRPO must provide a verification effort tothe land use data provided, identify which areas haveundergone significant changes since the mapping, revise theland use and vegetative estimates accordingly, and re-runthe calculations using the verified information.

Page 4-4. Rainfall Depth and Distribution. FBPRPO usedthe TP-40 data/ and it is well known that 100-yearprecipitation depths estimated by TP-40 are, in general,too low to be realistic. Refer to general comment #2 abovefor specific comment and followup requirements on thisissue.

Page 4-5 and 4-6. September 6-7, 1990 Rainfall Event.Based on Bulletin 71, 2.25-inches of rainfall is between a25- and 50-year event, so a 35-year recurrence interval isin the correct range for the first hour of the measuredevent. The 3.95-inches of rainfall measured over 18-hoursis less than a 25-year event, according to Bulletin 71.The HEC-1, HEC-2 and HEC-6 models must be reviewed andamended to ensure that the estimated discharges for the100-year flood are consistent with Bulletin 71.

Page 4-6. High Water Levels. Verify whether the staffgage readings taken approximately 2-hours after thebeginning of the storm event concur with observed highwater marks. Provide the basis for the assumption thatthese readings represent the highest water levels.

Page 4-6. Calibration. FBPRPO must verify whether the 15cfs base flow reflects the industrial discharge.

Page 4-9 and Figure 4*6. Bridge 13. Figure 4-8 indicatesalmost the entire cross-section of the culverts is filledwith silt. The Reach 8-2-4 cross-section, immediatelydownstream of Bridge 13 has a higher thalweg elevation thanthe Bridge 13 culvert inverts, which indicates whysiltation is a problems. Discuss how the reduced culvertcapacity caused by siltation was modeled.

Page 4-11. Methodology. FBPRPO must verify which versionof HEC-6 was used; if the version 4.1, which is the mostrecently revised version, was not used, EPA requires thatthe model be re-run using this version (since it is moresuitable for cohesive sediment transport analysis).

10/24/94SENT BY:U.S. EPA

09:41 312 8864071;10-24-94 : 8=33AM ; OFFICE OF SLFERFLND- !16 349 1514:# 6/10

Page 4-12. Field Sampling. Provide the bridge number ofthe 15th St. bridge (i.e., is it Bridge #27). Provide theapproximate station of the sampling location. It isdifficult to locate the site identified by a street namewhen all the figures reference channel station and bridgenumbers.

Page 4-13 and Figure 4-11. Sediment Rating Curve. FBPRPOmust provide an extrapolation of the sediment rating curveparallel to the observed data in Figure 4-11, since thisextrapolation would be much more justifiable (especiallyconsidering the mixed land uses in the watershed). Table 2below indicates the difference in suspended sedimentdischarge using the different extrapolation techniques.

Page 4-15 and 4*16. Parameter Selection. FBPRPO mustprovide additional discussion and listing of all HEC-1,HEC-2, and HEC-6 input parameters used and the basis forsuch use, and identify which values were derived from testsand which from literature/experience. Calculations must beprovided for all derived input data.

FBPRPO must also conduct and provide a sensitivityanalysis which provides the range of acceptable parametersfor the following assumptions used in the model (listed inorder of importance): critical shear stress, sedimenttransport function, sediment inflow, and the roughnesscoefficient (i.e., Mannings n). Refer to general comment#3 above.

Figure 8. 100-Year Profile. FBPRPO must provide thebridge low chord and roadway sag elevation on the profileplot, as is standard when plotting flood profiles.

Table 1Extreme Precipitation Depths Expected in Aehtabula, Ohio

TP-40

Bull, 71

100 -Year24 -Hour4.8"

5.89"

100-Year12 -Hour4.3"

5.12"

100-Year6 -Hour3.6"4.42"

10 •'24/34 09:41SEAT B Y : U . S . EPA

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Table 2Sediment Rating Curve Extrapolation

Water Flow Rate(cfs)

500

1,000

5,000

10,000

WCC ExtrapolationTSS Discharge(Tons /day)

300

1,200

20,000

50,000

ParallelExtrapolationTSS Discharge(Tone/day)

700

4,300

120,000

700,000

Enclosure 2:10/4/94 USACE-WES Comments Regarding Hydraulic Soour;Sediment Operable Unit; Fields Brook Superfund Site

Three pages provided within Enclosure 2.

10/24/94SENT BY:U.S. EFA

09:42 312 8864071;10-24-94 ; 8:34AM ; OFFICE OF SLFERFUND- 216 349 1514;# 8/10

REPLY TOATTENTION OF

DEPARTMENT OF THE ARMYWATERWAY* EXPHIMENT STATION. COMF* OF ENOMEERS

MCN HALLS FtRNV ROAD, MISSISSIPPI

CBWES-HR-M (1110-2-HSOa) 4 October 1994

MEMORANDUM FOR Commander, U.S. Army Engineer District, Buffalo,ATTN: CBNCB-PB-PT/Mr.Steven Golyski, 1776 Niagara Street,Buffalo, NY* 14207-3199

SUBJECT: Fields Brook Superfund Site, Ashtabula, Ohio

1. Reference is made to the letter of 1 September 1994 from Mr. Edward J.Hanlon, U.S. Environir-ental Protection Agency. Region r», to Mr. Steve Golyskiregarding "Fields Brook Superfund Site, Aahtabula, Ohio," (copy furnishedMr. Ronald Heath of the U.S. Army Engineer Waterways Experiment Station (WES)via facsimile) . Members of the Hydraulics Laboratory of WES have reviewed the31 August 1944 draft of Section 4.0 of the Sediment Quantification DesignInvestigation, Phase II Report for the Fields Brook Site in Ashtabula, Ohio/as requested by Mr. Hanlon. The results of the review are documented in theenclosed memorandum.

2. Questions concerning the above should be directed to Mr. Ronald Heath at601 634-3592.

End F. A. HERRMANN, JR.EngineerDirector, Hydraulics Laboratory

HYDRAULICSLABORATORY

GEOTECMNICAiLAftORATOnV

STRUCTURESLAAORATQMV

ENVIRONMENTALLABORATORY

COASTAL ENGINEERINGCENTER

INFORMATIONTECHNOLOGY LABORATORY

10/24/94 09:42 312 8864071SENT BY:U.S. EPA ; 10-24-94 ; 8:34AM ; OFFICE OF SIPEKFUND-' 216 349 1514:# 9/10

ncn.v TOATTtNTION OF

DEPARTMENT OF THE ARMYWATBIWAVf EXPERIMENT fTATION. COUPS Of

MM KALI* FERRY ROADvtCKMuna. uissittim ati«o-6i«9

CKWES-HR-M (1110-2-1150a) 29 September 1994

MEMORANDUM FOR RECORD

SUBJECT: Fields Brook Superfund Site. Ashtabula, Ohio

1. At the request of Mr. Edward J. Hanlon of the U.S. EnvironmentalProtection Agency, Region 5, members of the Hydraulics Laboratory havereviewed the 31 August 1944 draft of Section 4.0 of the Sediment Quantifi-cation Design investigation, Phase II Report for the Fields Brook Site inAshtabula, Ohio. The material supplied for review consisted of the reporttext, tables, figures, and photo journal. Appendices A-D were not suppliedfor review. The following comments were provided by Dr. Ronald R. Cop el andand Dr. Trimbak (Nana) Parchure.

S.

2- (Paoe 4-9). A Manning's roughness coefficient of 0.20 was used atsta 16+30 and 172+00 to account for losses due to severe bends. This mayproduce appropriate water-surface elevations in the vicinity of the bend, butit does not correctly reproduce velocities at the cross section and may affectsediment calculations.

3. (Page 4-141 . Sediment inflow must be defined by size class in HEC-6. Thereport does not state how the sediment inflow curve was developed for eachsize class. Thic is especially important for the sand size classes. Thecomparison of the extrapolated total load curve to load curvee from the U.S.Geological Survey <USGS) Water Supply Paper No. 2045 indicates that FieldsBrook has a higher sediment concentration than the other Ohio streamsmeasured* What is the bed-material-load/wash-load breakdown in the total loadfor the USGS streams and for Fields Brook? The bed-material load is the onlyportion of the total load that is important in the aggradation and degradationcalculations.

4. (Paoe 4-i4>. Tributary inflows that were "10 percenc of the values usedat the upper end of the watershed* were used in the HEC-6 model. Unless thetributary watersheds are significantly different from the upstream watershed,the tributary inflow concentrations should be similar at comparabledischarges*

5. (Page 4-15). The critical shear stress for erosion was estimated by usingthe relationship given by Kamphuis (1983) . it may be noted that the sedimentused for his tests had (0 percent clay content, whereas the Fields Brook bedsamples had clay content varying between 7 and 21 percent. Hence the criticalshear strength for erosion for Fields Brook sediment is expected to be muchsmaller. Consequently, the depth of erosion estimated in the report is likelyto be underestimated.

HYDRAULICSLABORATORY

G£0 TECHNICALLA&C4UTORV

STRUCTURESLABORATORY

ENVIRONMENTALLABORATORY

COASTAL £NaiNEERIN<»RESEARCH CENTER

INFORMATIONTECHNOLOGY

10/24x94 09:43 312 8864071SENT 3Y:U.S. EPA ;10-24-94 ; 8:35AM ; OFFICE OF SIPERFIMH 216 349 1S14;#10/10

CBWES-HR-MSUBJECT: Fields Brook Superfund Site, Ashtabula, Ohio

6. JPaqe 4-15). The erosion rate constant, assumed to be 0.3687 pound*/sq ft/hr, is also likely to be different for the same reason as above. If so,this will influence the rate of erosion and depth of scour.

7. f̂acra 4-16) . Shear stress threshold for deposition for the active layershould be less than or equal to the critical shear stress for particle andmass erosion. This value is the same for both the active and inactive layerin HBC-6 (the inactive value is not used) . Active layer critical shearstresses are outside the range proposed by Kamphuia (1983) presented on theprevious page (page 4-15}. The reasoning used should be explained.

0. (Page 4-16) . The unit weight of sediment deposit! in HEC-6 should beinput as dry weight, not submerged unit weight.

*• (Page 4-16) . The HEC-S model requires definition of the bed by sizeclass; gradations of the active layer and inactive layer are not presented inthe report. The only data presented are in Table 4-6 which defines theaand/silt break and the percent finer than 2 microns. Which of these data areactive layer, and which are inactive?

ID. (Page 4-161 . As stated in the report, the Meyer-Peter Muller equation isa bed-load equation and is not the best sediment transport function to use forthe fine sand fraction in the bed. The sand fraction will move primarily assuspended-load at high flows. The Meyer-Peter Muller equation is usedprimarily for gravel-bed streams. Applicability of a sediment transportequation should be confirmed using measured data on the subject stream whenpossible, or on similar streams in the vicinity.

11. As is typical of sediment studies, available data are insufficient toaccurately define all the critical variables that influence sedimentationprocesses in Fields Brook, Data are also insufficient to circumstantiate thenumerical model at high flood discharges. For this reason it is essentialthat a sensitivity study be conducted to determine the uncertainty associatedwith model results due to the range of reasonable values for key inputvariables. Important variables include sediment transport function, sedimentinflow, critical shear stresses and erosion rates of the cohesive sediment,bed-material gradation, and Manning's roughness coefficient.

RONALD K. HSATHResearch Hydraulic EngineerMath Modeling Branch

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