EPA541-R98-071
1999
EPA Superfund
Record of Decision Amendment:
American Chemical Service Inc. Site
Griffith, IN
7/27/1999
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
RECORD OF DECISION
AMENDMENT
for the
American Chemical Service, Inc. Superfund Site
Griffith, Indiana
July 1999
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CONTENTS
Section Page
I. Declaration ii
II. Administrative Record Index iv
III. State Letter of Concurrence . .* xii
IV. Decision Summary 1
Introduction 1
Background 1
Figure 1 2
Site History Post-1992 ROD 4
Proposed ROD Amendment - Public Participation 6
Detailed Description of ROD Amendment 7
Evaluation of Proposed ROD Amendment (The Nine Criteria) 8
Statutory Determinations 12
V. Responsiveness Summary ' 13
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DECLARATION
SELECTED REMEDIAL ALTERNATIVE FOR THE
American Chemical Service, Inc., Site
Griffith, Indiana
Statement of Basis and Purpose
This decision document presents the amendment to the remedial action for the
American Chemical Service, Inc. (ACS) site, Griffith, Indiana, which was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on
the administrative record for the site. The attached index identifies the items that
comprise the administrative record upon which the amendment determination is based.
Description of the Amended Remedy
This decision document amends the 1992 ACS Record of Decision (ROD) to change
the previously-selected cleanup method, consisting of a full treatment remedy that
would have achieved residential-use cleanup levels, to a combined containment and
treatment remedy that preserves the current use of the site as industrial use. The
treatment of polychlorinated biphenyl (PCB) and volatile organic compound (VOC)-
contaminated soil using low temperature thermal treatment (LI I I) and soil vapor
extraction (SVE) systems will be replaced by the following remedial actions:
• Soil contaminants will be hydraulically and physically contained on site by
surrounding the site with a subsurface barrier wall (a slurry wall modified by
adding a vertical flexible membrane liner into the middle of the bentonite/soil
slurry mixture), capping the site to reduce infiltration, and withdrawing
groundwater inside the barrier wall to effect an inward groundwater gradient,
where practicable.
• Volatile organic compound-laden soils within the containment system will be
treated by installing and operating an SVE system in certain areas of the site that
contain very high levels (greater than 10,000 mg/kg) of VOCs. The SVE system
will be operated with the goal of reducing the very high VOC levels to prevent the
possible degradation of the barrier wall by high VOC levels and the subsequent
movement of VOCs off site into the groundwater.
PCB-laden sediments in site wetlands will be excavated to achieve a cleanup
level of 1 mg/kg to depth. Excavated sediments containing less than 50 mg/kg
PCBs may be consolidated on site beneath the cap. Excavated sediments
containing greater than 50 mg/kg PCBs will be disposed of off site at a TSCA-
compliant facility. The wetlands area will be restored.
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A deed restriction will be maintained on the site so that the future use(s) of the
property will be restricted to those activities which do not interfere with the
performance of any cleanup activities or disturb the integrity of the completed
containment system. Should a zoning change to residential use be made, such
a change must be accompanied by the proper cleanup effort needed for the new
site-use assumption.
For the time period ending approximately one year from the date of signature on this
ROD Amendment, U.S. EPA will be gathering data from certain areas of the off-site
groundwater contaminant plume to determine whether contaminants of concern may be
addressed through monitored natural attenuation. In other discreet areas, U.S. EPA is
testing the application of oxygen releasing compounds into the affected portion of the
aquifer to ascertain whether bioremediation of the organic contaminants in the plume is
enhanced. Should either of these alternative groundwater cleanup methods prove to
be successful (as defined by agency guidance documents for the processes), U.S. EPA
may initiate a second ROD Amendment proceeding so that the conventional pump and
treat method denoted in the 1992 ROD may be modified as appropriate.
The groundwater cleanup standards identified as part of the selected remedy in the
1992 ROD remain unchanged, as well as the remaining aspects of the 1992 ROD
remedial action not specifically addressed by this ROD Amendment.
Declaration Statement
The selected amended remedy is protective of human health and the environment,
attains Federal and state requirements that are applicable or relevant and appropriate
for this remedial action, is cost-effective, and is otherwise in compliance with CERCLA.
This remedy satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element and utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on-site above
health-based levels, a review will be conducted every 5 years after commencement of
remedial action to ensure that the remedy continues to provide adequate protection of
human health and the environment.
State Concurrence
The State of Indiana concurs with the amended remedy.
William E. Muno, Director
Superfund Division
Date
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
.AMERICAN CHEMICAL SERVICE, INC. SITE
GRIFFITH, INDIANA
UPDATE #3
JULY 21, 1999
NO.
DATE
04/00/93
AUTHOR
Canonie
Er.vi r tr.menta 1
RECIPIENT
U.S. EPA
TITLE/DE SCRIgTION
Bench Scale Tre = -.-
ea O A. -L L . j v , UC '•/ " £*O
Anaerobic Thermal
for the .-.^riran c
Service S i ~ -s
PAGES
OC6S5
ner;:al
Q4/0C/33
t n v i
In c.
U.S. EPA
Soil Vac-
Treatant
the rj.e:
Service :
i
04/00/93
Vacex
En v i r c nir.en t a 1
"la jhr. sissies.
Inc.
U.S. EPA
Der.ch St
iixirac;:.'
Study fc
Chemi nai
i.e v ap-r
T r a a t a i
Service i
• 4 :*
04/15/93
Pereiiis, A.;
C=£fiela,
Up. era r j? zz i
L Karris
Siegel, S.
U.S. SPA
Letter re: Analyses
cf the Tr«a^stbiLi-y
Studies ; ;-r ;ri? Arr.ericar.
Chemical Service Site
w/ AtCic:.:*en:s
37
06/21/93
B C W i •
Erv/i'
naniper,
War:yn,
Ip.c .
J .ft f fOJ" f ~
Attached
Ext ract:-
Study ;Z:
Results;
Cherr.i ca 1
rwa
•c 1
- T
-.:.e
v'spor ^ ^
^tafci-tty
ir.n
~,z tne African
irvice Site
06/00/94
sn,
I'.S . LPA
Technics
Ana lysis
Contanir,
Select,
America."
Site
:«.er.cranau^:
r i" E x i *9 r* 11 f
;:cr. ar.d ?.C3
04/03/95
Adams, J. ,
Hont ^ T.-i ry
Hat scr.
Bianchin, S.,
U.S. EPA
1'echn ica . Memorandum for
Expedite-; jrour.dwater
Sampling P.esulto for
the ?eri;c December 1334
January 1 «*5 "or rh-i
American >,f»rr.j Servi-:
Site
99
11/07/95
31ac< •.
Vest cn
Specia 1
Corpc:.';!*, ion
U.S. EPA
Overstgr.:
for the .
Tour and
Survey a..
Cheryl ca 1
jurxn.i ry ,-«epcrt
__y 15, 19 95 Site
r.-tcber 2, 1995
- h
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American Chemical Service AR
Update #3
Page 2
HO. DATE AUTHOR RECIPIENT
9 11/21/95 Black S U.S. EPA
Veatch
Special
Projects
Corporat ion
10 12/00/95 Montgomery U.S. EPA
Watson
11 12/00/95 Montgomery U.S. EPA
Watson
12 01/22/96 Montgomery U.S. EPA
Watson
13 01/25/36 Montgomery U.S. EPA
Watson
14 G2/22/96 Black £ U.S. EPA
Veatch
Special
Projects
Corporation
03/00/96 Montgomery U.S. SPA
Watson
16 C 3/00/96 Montgomery U.S. EPA
Watson
1? 0 3/00/ S 6 Montgomery U.S. EPA
Watson
TITLE/DESCRIPTION PAGES
Oversight Summary Report 2-;
for the Period October
20 - November 14, 1953
for the American Chemical
Service Site
Report: Lower Aquifer "I
Investigation SOW and
SOPs for the American
Chemical Service Site
Report: Uppec Aquifer 21
Investigation SOW and
SOPs for the American
Chemical Service Site
Report: Upper Aquifer ZZ
Investigation SOW and
SOPs for the American
Chemical Service Site
(REVISED)
Report: Lower Aquifer 7Z
Investigation SOW and
SOPs for the American
Chemical Service Site
(REVISED)
Oversight Summary Report 51
for the Period January 1c-
February 14, 1996 for the
Barrier Wall Alignment/
Construction Field Work
at the American Chemical
Service Site
501 Design Submittal 321
for the Perimeter Ground-
water Containment System
for the American Chemical
Service Site w/Attached
Replacement Pages
Technical Memorandum:
Oewatering/Barrier Wall
Alignment Investigation
Report for the American
Chemical Service Site
Technical Memorandum: n•
Upper Aquifer Investiga-
tion for the Monitoring
Well and Sampling Pro-
posal (Text, Tables,
Figures and Appendix A'¦
for the American Chemical
Service Site
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HO. DATE ' AUTHOR RECIPIENT
18 G3/00/96 Montgomery U.S. EPA
Watson
i •)
03/27/96
Black &
Veacch
Special
Projects
Corporation
U.S. hJPA
PC
>3/27/96
Vagt, P.,
Montgomery
Watson
Addressee:
21
C4/19/96
Vagt, P.,
Montgomery
Watson
Bianchin,
U.S. SPA
22
05/03/96
Montgomery
Watson
U.S. EPA
¦6/00/96
Montgomery
Watson
ft^ericas,
Inc.
EPA
23
07/00/96
Montgomery
Watson
"PA
24
f/ii/96
Black &
Veatch
Special
Projects
Corporat ior
11. c .
American Chemical Service AR
Update #3
Page 3
TITLE/DESCRIPTION PAGES
Technical Memorandum: 52 3
Upper Aquifer Investiga-
tion for the Monitoring
Well and Sampling Pro-
posal (Appendix R: Field
GC Printouts and Plots)
for the American Chs-nica 1
Service Site
Oversight Summary for 14J
the Upper Aquifer
Investigation at the
American Chemical
Service Site
Memorandum Forwarding !3~
Attached Information
Concerning Past Ground-
water Modeling Reports
for the American Chemical
Service Site
Letter Forwarding 31
Attached Correction Pages
for the Dewatering/Barriar
Wall Alignment Investiga-
tion Report for the
American Chemical Service
Site
Technical Memorandum: 10™
Upper Aquifer Invesrica-
tion Monitoring Well and
Sampling Proposal for
the American Chemical
Service Site {REVISED;
50 Percent Design Sub- 87
mittal for the Barrier
Wall and Associated
Groundwater Extraction
System and Pilot Study .
Test Cell for the Amer-
ican Chemical Service
Site
Technical Memorandum: 339
Wetland Investigation,
for the American Chemical
Service Site
Oversight Summary Report
and Photographs for the
Wetlands Sampling at the
American Chemical Service
Site
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American Chemical Sarv2.ce AR
Update #3
Page 4
NO- DATE
25 07/25/96
AUTHOR
Montgomery
a'at son
RECIPIENT
U.S. EPA
TITLE/DESCRIPTION PAGES
Technical Memorandum: r-;
'Jpper Aquifer Investiga-
tion Monitoring Weil and
Sampling Proposal for
the American Chemical
Service Site ;REVISED)
26
58/00/96
¦3/06/96
Montgomery
Watson
3Iack S
Veatch
Special
Projects
Corporation
U.S. EPA
U.S. EPA
Technical Memorandum:
Cewatering/Harrier Wall
Alignment Investigation
Report for the American
Chemical Service Site
Field Oversight Summary
Report for July 1996 for
the Upper Aquifer Inves-
tigation Monitoring Well/
Piezometer Installation
at the American Chemical
Service Site
28
09/00/96
Montgomery
U.S.
:pa
Technical Memorandum:
Lower Aquifer Investiga-
tion Report for the
American Chemical Service
Site
•'00/96
30
:?/00/96
Montgomery
Watson
Montgomery
Watson
U.S. EPA
U.S. EPA
Technical Memorandum:
Lower Aquifer Investiga-
tion Report for the
American Chemical Service
Site (REVISED)
Technical Memorandum:
Upper Aquifer Investiga-
tion CPhase II) Well
Installation and Sampling
for the American Chemical
Service Site
33i
. / 0 0 / 9 6
:15/96
3 ^'
. / DO/9"
Black &
Veatch
Special
Projects
Corporation
Black h
Veatch
Special
Projects
Corporation
Montgomery
Watsen
U.S. EPA
U.S. EPA
U.S. EPA
Field Oversight Summary
Report for the Period .
November 18 - November 21,
1596 for the American
Chemical Service Site
Field Oversight Summary
Report for the Period
October 20 - November 4,
1996 for the American
Chemical Service Site
Technical Memorandum:
1996 Groundwater Sampling
Results Report for the
American Chemical Service
Site
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NO. DATE AUTHOR RECIPIENT
34 02/00/9' 3iack & U.S. EPA
Veatch
Special
Projects
Coraoration
35 02/00/97 Montgomery U.S. F.PA
Wats on
36 03/00/57 Black & U.S. EPA
'/eatch
Special.
Proj ects
Corporation
37 03/CC/37 Montgomery U.S. EPA
Watson
38 03/00/97 Montgomery U.S. EPA
Watson
39 03/11/9" 'Slack i U.S. EPA
Veatch
Special
Projects
Corporation
<10 05/00/37 Montgomery U.S. FPA
Watson
41 05/00'?7 Montgomery U.S. HIPA
Wat son
American Chemical Service AR
Update #3
Page 5
TITLE/DESCRIPTION PAGES
Field Oversight Summary 11c
Report for the Period
December 28, 1.996 -
February 5, 1997 for the
American Chemical Service
Site
Technical Memorandum: 15b
Phase II Wetland Inves-
tigation for the Araerican
Chemical Service Site
Field Oversight Summary 1 ;
Report for the Period
February 6 - March 28,
1997 for the American
Chemical Service Site
Technical Memorandum: 62
Lower Aquifer Investiga-
tion. Keport for the
American Chemical Service
Site
Technical Memorandum: 33
Upper Aquifer Investiga-
tion (Phase II) Well
Installation and Sampling
for the American Chemical
Service Site
Field Oversight Summary i 1
Report for the Period
November 22 - December 27,
1996 for the American
Chemical Service Site
Technical Memorandum: i1
March 1997 Groundwater
Sampling Results Report
for the American Chemical
Service Site
Technical Memorandum: .1 • ?
Wetland Investigation
(Volume I of II: Text,
Tables, Figures and
Appendix A) for the
American Chemical Service
42
Montgomery
Watson
CJ. S
EPA
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American Chemical Service AR
Update #3
Page 6
MO. DATE AUTHOR RECIPIENT
43 0 6/13/ 97 Biack-f» U.S. EPA
v c — —h
Special
?rr:act5
Ccrporat ion
44 C1 / 22 / '?"¦' r.zzLZontai U.S. EPA
?~ chr.oloqies,
-35 09/12/97 Black S U.S. EPA
a •• r»
S p 5 C 1 3 I
?r:}e:ts
Ccrporation
4 6 10/00/9? rerjs U.S. EPA
Environmental,
47 10/00/97 Kcr.tgomery U.S. EPA
»'» S. " 3 c r.
4:3 1C ,'00/97 X::.:;ir.tEy U.S. EPA
sen
49 10/00/97 Xcr.t-gomer y U.S. EPA
Wat 5 on
50 01/00/93 Forus U.S. EPA
Zr."L rcr.nenta I,
51 01/00/9S Mi,.-.-? ornery U.S. EPA
'•¦'a t sen
TITLE/DESCRIPTION PAGES
Field Oversight Summary 129
Report for che Period
March 29 - May 31, 19 9"
for the t\neti:=n Cneni,:al
Service Sice
Information Package; Ar. 1C?
Introduction to Tren.chea
Horizontal Weils for Water
Supply, Linear Containment
Remediation Systems and
the Polywall Barrier
System
Field Oversignt Summary 1C5
Report for the Period
June 24 - July 11, 1397
for the American Chemical
Service Site
Pretzeatmer.t/Materials 35"?
Handling Study Report
for the American Chemical
Service Site
Quarterly Monitoring 167
Report: Perimeter Ground-
water Containment Sysceni
for the Groundwater Treat-
ment System at. the Amer-
ican Chemical Service Site
Technical Memorandum: 270
June 19 97 Groundwater
Sampling Results Report
(Volume 1: Text, Tables,
Figures and Appendices
A-Bjfor the American
Chemical 3erv_ Site
Technical Memorandum: 500
June 1997 Groundwater
Sampling Results Report
(Vo 1 u_tio 2 : Append i .res
C-F! for the ,-.T.eri;an
Chemical Servije Site
Thermal Treatability 423
Study Report f:-r the
American C'nen. .w 1 Service
Si te
Quarterly Monitoring 52
Report: Groundwater
Treatment System for the
American Chen: :a 1 Service
Site
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NO. DATE AUTHOR RECIPIENT
52 01/00/98 Montgomery U.S. EPA
»Ju"5on
53 01/00/98 Montgomery U.S. EPA
Watson
54 02/10/98 Black o U.S. F.PA
Veatch
Special
Projects
Ccrporation '
55 06/00/98 Black 6, U.S. EPA
Veatch
Special
r roj oct s
C"rporation
56 07/21/98 Montgomery U.S. EPA
Matson
57 07/21/98 Montgomery U.S. EPA
Watson
American Chemical Service AR
Update #3
Page 7
TITLE/DESCRIPTION PAGES
Technical Memorandum: 269
September 1997 Ground-
water Sampling Results
Report and Proposed
Groundwater Konitoring
Plan(Volume 1: .Text,
Tables, Figures and
Appendices A-H) for the
American Chemical Service
Site
Technical Memorandum: <5 5 7
September 1997 Ground-
water Sampling Results
Report and Proposed
Groundwater Monitoring
Plan(Volume 2: Appen-
dices D-H) for the
American Chemical Service
Sita
Field Oversight Summary 10
Report for the December
9-1B, 1997 Fifth Quarterly
Sampling Round for the
American Chemical Service
Site
rield Oversight Summary 56
Report for the Period
June 3-10, 1998 for
the American Chemical
Service Site
Technical Memorandum: 302
September 1997 Ground-
water Sampling Results
Report and Proposed
Groundwater Monitoring
Plan(Volume 1: Text,
Tables, Figures and
Appendices A-H) for the.
.-.Tsricar, Chemical Service
cite [REVISED]
T-,;.:hnieal Memorandum: 457
September 1997 Ground-
water Sampling Results
Report and Proposed
¦Iroundwater Monitoring
rLan(Volume 2: Appendices
r-H! for the American
.."r.^micai Service Site
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American Chemical Service AJR
Update #3
Page 8
DATE AUTHOR RECIPIENT
C 9/2 9 /9 3 Black & U.S. EPA
Veatch
Special
Proj ects
Corporation
12/00/98 Hor.tcomery U.S. EPA
Watson
.2/00/9B Montgomery U.S. EFA
Wat son
12/02/93 Vagt, P., Blanch in,
Montgomery U.S. EPA
Watson
b..
0-1 /00/99
U.S. EPA
Public
05/13/99 U.S. EPA Public
TITLE /DESCRIPTION PAGES
Field Oversight Summary LA
Report for the Period
September 14-19, 1993 fcr
the American Chemical
Service Site
June 1998 Groundwater
Treatment System Monitor-
ing Report for the Amer-
ican Chemical Service
Site
Technical Memorandum: •'•""t
June 1998 Groundwater
Monitoring Report for the
American Chemical Service
Site
Letter re: Presence of 34
Arsenic in the October
28, 1998 Groundwater
Treatment Plant Discbarge
Sample and Status of
Measures taken at the
American Chemical Service
Site
Fact Sheet: U.S. EPA 11
Proposes Changes to tne
Record of Decision for
the American Chemical
Service Site
Transcript of the May I'S
13, 1999 Public Meeting
re: the American Cher.ical
Service Site
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SEP-14
14 i 44
f't'wik O'Btuuwtt
Go^ifo'
Lan f\ Kaplan
Cu^mujio*^
P. 02
Indiana Department of Envtronmeni alManagement
We make Indiana a cleaner, healthier place to live
September 14, 1999
\ OO North Senate Avenue
P.O. Boa 6015
Irwiamjpolii, Indhzno 46206-6015
(317)232-0603
(QOQJ 45 J -602?
Mr. Frank Lyons
Regional Administrator
U.S. EPA, Region V
77 West Jackson Blvd.
Chicago] IL 60604
Dear Mr Lyons:
Re: Record of Decision (ROD) Amendment
American Chemical Services (ACS)
Superfond Site, Griffith, IN
Slaff of the Indiana Department of Environmental Management (IDEM) have reviewed .
the UnitcM States Environmental Protection Agency's (U.S. EPA) draft Record of Decision
Amendnint for the American Chemical Services Superfiind Site. The ACS Site was listed on the
National Priorities List (NPL) September 21,1984. IDEM is in full concurrence with the
selected remedial alternative presented in this document
I
The major components of the selected remedy include:
» Sail contaminants will be hydraulically and physically contained on-site by surrounding
the site with a subsurface barrier wait (a slurry wall modified by adding a vertical flexible
membrane liner into the middle of the bentonitc/soil slimy mixture), capping the site to
reduce infiltration, and withdrawing groundwater inside the barrier wall to affect an
inward groundwater gradient,
• Volatile organic compound (VOC) laden soils within the containment system will be •
treated by installing and operating a Soil Vapor Extraction (SVE) system in certain areas
oflhc site that contain very high levels (greater than 10,000 mg/kg) of VOCs. The SVE
sy|tem will be operated with the goal of reducing the very high VOC levels. Reduced
VOC levels will prevent the possible degradation of the harrier wall and the subsequent
movement of VOCs off-site into the groundwater.
• Polychlorinatcd biphenyl (PCB) laden sediments in site wetlands will be excavated to
achieve a cleanup level of 1 mg/kg to depth. Excavated sedimenLs containing less than SO
nig 'kg PCBs may be consolidated on-site beneath the cap. Excavated sediments
coi taining greater than 50 mg/kg PCBs will be disposed of off-site at « Toxic Substances
Co it-ol Act (TSCA) compliant facility. 'Hie wetlands area will be restored.
Utl ©
Art Lqual Dpf>o*mmiy Erapkiycr
-------
Mr. Frank Lyons t
Page 2
• A deed restriction will be maintained on the site so that the future use(s) of the property
will be restricted to those activities thai do not interfere with the performance of any
cleanup activities or disturb the integrity of the completed containment system. Should a
zoning change to residential use be made, such a change must be accompanied by the
, proper cleanup effort needed for the new site-use scenario.
C|ur staff have been working very closely with U.S. EPA Region V staff in the selection
of an appropriate remedy and are satisfied with the selected alternative. We believe the remedy
adequately addresses public health and environmental issues at the American Chemical Services-
site. In addition, we are pleased that you have taken steps to address the off-site buried drums in
the victn^y of the barrier wall by assigning an On-scene Coordinator.
Please be assured that IDEM is committed to accomplishing the remediation of all
Indiana sites on the National Priorities List and intends to fulfill all obligations required by law
to achieve that goal.
Sincerely,
Lori F. Kaplan
Commissioner
SKG:mg
cc: Rac Osborn, IDEM
Mary Beth Tuohy, IDEM
Sean Grady, IDEM
""Im Method, IDEM
Ke«vm Adler, U.S. EPA
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Record of Decision Amendment
American Chemical Service, Inc., Site
Griffith, Indiana
Introduction
This Record of Decision (ROD) Amendment describes changes to the 1992 ROD for
the American Chemical Service (ACS), Inc., Superfund site, Griffith, Indiana. The
United States Environmental Protection Agency (U.S. EPA) is making these changes to
the 1992 ROD as part of its responsibilities under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended.
The ROD Amendment includes modifications to the 1992 ROD to perform a
combination of certain cleanup remedy elements that were previously evaluated in the
1992 ROD document, but portions of which were not selected as the 1992 cleanup
remedy. The ROD Amendment consists of: 1) a revision to the assumed future use of
the ACS property from residential use to industrial use; 2) a modification of the site
cleanup approach from full treatment of contaminated materials to a combination of
containment (using subsurface barrier wall and capping technologies) and partial
treatment of mobile contaminants; 3) a modification to the wetlands cleanup method; 4)
a modification to the groundwater contaminant plume cleanup method; and, 5) the
placement of deed restrictions on the future uses of the site. The details of the ROD
Amendment are described below.
Background
The ACS Site is located at 420 S. Colfax Ave., Griffith, Indiana, (see Figure 1) and is
comprised of 19 acres of American Chemical Service Corporation-owned or leased
property which includes the so-called "Off-Site Containment" and the "On-Site
Containment" areas, the 2-acre property known as the "Kapica-Pazmey" property, and
a 15-acre portion of the Griffith Municipal Landfill. Groundwater contaminant plumes
emanate from the ACS site (as demonstrated in Figure 1) and site wastes have
impacted certain nearby wetland areas.
The American Chemical Service Corporation (ACSC) began a solvent recovery
business on the ACS property in May 1955. ACSC past waste handling, storage, and
disposal practices led to the contamination of the site (except for the Town of Griffith
Landfill area and the Kapica-Pazmey area), to the extent described in the 1992 ROD
and other documents. ACSC ceased its solvent reclaiming activities upon losing its
interim (authorization to operate) status under the Resource Conservation and
Recovery Act (RCRA) in 1990, although it continues its specialty chemical
manufacturing operations to this day.
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PERIMETER GROUNDWATEI
CONTAINMENT SYSTEM
PCB-
IMPACTED SOILS
GROUNDWATER
TREATMENT
PLANT
BmRRIER WALL
EXTRACTION SYSTEM
BARRIER WALL
BURIED DRUMS IN
ON-SITE CONTAINMENT
AREA
STILL BOTTOMS
POND AREA
OFF-SITE CONTAINMENT
REA
^KAPJCA-PAZMEY
AREA
. APPROXIMATE EXTENT OF
SHALLOW GROUNDWATER
CONTAMINATION
north
0 BOO
LTLTLT"
SCALE (N FEET
MOO
1
American Chemical Service, Inc.
Superfund sit*, Griffith, Indiana
nowtti
-------
-3-
The ACS Site has been extensively studied and tested to determine the nature and
extent of chemical contamination in and around the site. The Remedial Investigation
(Rl) report shows that there are large areas on site with numerous types of buried
contaminants that are both sources of groundwater contamination and potential contact
hazards for site workers. Major waste categories include volatile organic compounds
(VOCs) and semi-volatile organic compounds (SVOCs), polychlorinated biphenyls
(PCBs), and heavy metals. These contaminants are found at variable concentrations
within the Off-site Containment area, the Kapica/Pazmey area, and in the On-site
Containment area. Volatile organic compounds such as benzene and chloroethane
are a concern in area groundwater.
The 1992 ROD detailed U.S. EPA's determination that the purpose of the selected
remedy was to restore the contaminated property using cleanup levels that would allow
the future unrestricted use of the property, i.e., for residential use. U.S. EPA
contemplated the use of groundwater-use restrictions for areas beyond ACSC property
boundaries until the groundwater quality was restored to drinkable status. U.S. EPA
would also restrict the future use of groundwater directly under the site. The following
methods were to be used to perform the cleanup at the ACS site:
1. The excavation of buried wastes and up to 135,000 cubic yards of
contaminated soils and debris, with subsequent on-site treatment of
organic contaminants using low-temperature thermal desorption (LTTD)
on soils and other methods such as steam-cleaning on the debris.
Metals-containing residuals may have required a further immobilization
step.
2. The off-site disposal of miscellaneous debris.
3. The excavation of approximately 400 drums in the On-site Containment
area with shipment off site for incineration of the contents.
4. The implementation of soil vapor extraction (SVE) of VOC-contaminated
soils, including the performance of a SVE pilot study in the buried waste
in the On-site Containment area.
5. The construction of a groundwater extraction and treatment system
capable of dewatering the site and also containing the off-site
groundwater contaminant plume. Treated water would be discharged to
the wetlands.
6. The further evaluation and monitoring of the impacted wetlands with
possible cleanup of the wetlands.
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7. The placement of a security fence around the site to prevent access to
contaminants and the implementation of deed restrictions on the property.
8. The implementation of long term groundwater monitoring, including
private well sampling. Impacted wells would be subjected to closure or
the owner would receive groundwater-use advisories.
(Note: The Town of Griffith is separately addressing the 15-acre portion of the Griffith
Municipal Landfill, through the Indiana State Solid Waste closure/post-closure
program.)
The 1992 ROD also called for the LTTD and SVE systems to undergo treatability
testing to determine if these cleanup methods would be able to attain final cleanup
levels.
Based on a combined estimated volume of 135,000 cubic yards of impacted soil and
debris, the 1992 ROD estimated that the selected cleanup remedy would cost between
$38 million and $47 million to construct and implement over a 6-year to 8-year time
frame.
Site History Post-1992 ROD
In selecting the remedial action for the ACS site, U.S. EPA had relied upon, among
other factors, waste-treatment volume estimates drawn from the Rl report. After
releasing the 1992 ROD, and in preparation for implementation of the cleanup, U.S.
EPA conducted both additional sampling at the site and site-waste materials handling
and treatability studies in 1997 to ascertain the accuracy of the soil volume estimate
and to determine if LTTD was a viable cleanup remedy for the ACS site. The reports
entitled "Pretreatment/Materials Handling Study Report" (1997) and "Thermal
Treatability Study" (1998) contain the results of these testing efforts.
Results of the Materials Handling Study indicate that an estimated volume of 150,000 to
200,000 cubic yards of contaminated waste, soils, and debris would have to be
excavated and treated using LTTD alone to remove VOCs, in order to meet the
residential cleanup levels contained in the 1992 ROD. U.S. EPA found that municipal
waste and other debris was not treatable using the steam cleaning method chosen in
the 1992 ROD. Thus, the estimated volume of soils to be treated using the resource-
intensive LTTD method had greatly increased. Moreover, much of the material could
not be treated effectively using LTTD, since some of the waste stream was municipal
waste and the VOC-mass was undercalculated. Municipal waste is not amenable to
LTTD, and new disposal methods will have to be found. The waste handling study
results project the need for an extra high level of safety requirements for site workers
due to the high levels of VOCs that would be encountered when contaminated soils,
wastes, and debris were excavated for treatment. The high levels of VOCs could
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constitute an explosion hazard as well as an exposure hazard to site cleanup workers,
and plausibly to area residents.
U.S. EPA also concluded that other management options may be necessary for ACS
site wastes, because LTTD would not be a practicable treatment alternative, and on-site
incineration, which would be required to properly treat the excavated wastes, is more
expensive and perhaps not allowable under Indiana State law. Based upon the
findings of the materials handling studies, the recalculated cleanup cost estimate for the
1992 ROD remedy is now $150 million to $246 million (present worth-1997), a
substantial increase from the original $38-47 million (present worth -1992) cost
estimate.
U.S. EPA also performed sampling of wetland soils/sediments during 1996 to delineate
the extent of PCB-impacted soil/sediment. Some areas contain PCBs in soil/sediment
above 1 ppm, with values exceeding 50 ppm in some cases. U.S. EPA, in consultation
with IDEM and wetlands experts, has determined that wetland soil/sediments containing
greater than 1 ppm PCBs should be excavated and managed on-site or disposed of
properly off-site.
During 1996-1997, U.S. EPA performed further sampling work to more fully delineate
the off-site groundwater contaminant plumes. As seen in Figure 1, groundwater
contaminant plumes, defined as those areas at which the groundwater exceeds
contaminant cleanup levels, are present in the northern and southern areas of the site.
Aquifer characteristics are such that it may be impracticable to implement a plume-wide
groundwater pump-and-treat program to restore groundwater quality. U.S. EPA is
evaluating the use of a combination of active restoration methods, such as groundwater
pump-and-treat and in-situ oxidation strategies, and monitored natural attenuation to
effect cleanup of the groundwater. Monitored natural attenuation consists of the
monitoring of natural processes in the aquifer which act to biodegrade, dilute, or adsorb
groundwater contaminants so as to make them immobile, dilute, or break down into less
harmful compounds to prevent exposure to harmful levels of contaminants.
Additionally, as the above studies were being performed, certain cleanup work was also
being performed at the ACS site. A subsurface barrier wall was installed around the
ACSC property in 1997 in an effort to contain the wastes on site. Further, a
groundwater extraction system was installed inside the barrier wall to dewater the area
to prevent movement of groundwater over and outside of the wall. Lastly, a
groundwater extraction system was installed in the northern area of the site to control
the movement of the more highly impacted groundwater in this area. Water pumped
from both systems is being routed to an on-site treatment plant to remove the chemical
contaminants before the cleaned water is discharged into the wetland areas.
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Proposed 1999 ROD Amendment
U.S. EPA issued a proposed plan for ROD amendment in April 1999, based upon the
new information created by the Material Handling Study work described above, and a
request from the ACS PRP Group that U.S. EPA reconsider the future site-use
assumption in making a cleanup decision. The new cost estimate information shows
that the 1992 ROD cleanup method would not be cost effective in comparison to other
cleanup or waste management methods. Moreover, U.S. EPA now assumes the future
use of the site property will be industrial, in concert with the current zoning designation
assigned by the Town of Griffith. U.S. EPA would have concerns regarding the health
and safety of site cleanup workers, ACSC workers, and the surrounding public should
widespread waste excavation occur, since the high levels of VOCs could create a
health hazard. Lastly, the treatability studies show that the selected treatment
method, LTTD, would not be effective in treating a majority of site wastes.
U.S. EPA proposed that wastes be contained by using a combination of cleanup
alternatives evaluated in the 1992 ROD, including containment-type alternatives and
treatment alternatives. Specifically, U.S. EPA proposed using applicable portions of
Alternative 2 in the 1992 ROD — subsurface barrier wall and surface capping—, and
Alternative 5 — soil vapor extraction of VOC-laden soil and debris-- along with the
excavation and incineration of the contents of buried drums in the On-site Containment
area. Under plans and specifications developed in accordance with Alternatives 2 and
5 of the 1992 ROD, some groundwater would be extracted and treated. However,
U.S. EPA also proposed the testing of in-place cleanup alternatives and of monitored
natural attenuation.
Other portions of the alternate remedy include the excavation of PCB-laden wetland
soil/sediment. Excavated material with total PCB levels less than 50 ppm would be
consolidated under the cap, and materials containing greater than 50 ppm would be
disposed off-site in a TSCA-compliant facility. Deed restrictions would be placed on
the property to ensure that should a zoning change to residential use be made, such a
change is accompanied by the proper cleanup effort needed for the new site-use
assumption. (Note: deed restrictions are now in place and can only be removed from
the property with U.S. EPA concurrence.)
U.S. EPA released a Proposed Plan for ROD Amendment for public comment on
April 19, 1999. The comment period was scheduled to run from April 19, 1999, through
May 21, 1999. U.S. EPA hosted a public meeting at the Griffith Township Hall, Griffith,
Indiana, on May 13, 1999, at 7:00 pm, and presented the proposed 1999 ROD
Amendment and took official public comments from the audience. The comments have
been addressed in the Responsiveness Summary attached to this ROD Amendment.
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Detailed Description of 1999 ROD Amendment
The ROD Amendment provides for the protection of human health and the environment
through a combination of the following:
1. Limitations on the potential for future exposure to contaminants
U.S. EPA determined that two methods would be used to isolate contaminated areas to
prevent future exposure to site contaminants:
a. Barrier Technologies
U.S. EPA would construct a subsurface barrier wall (sometimes termed a "slurry wall"),
on the ACS site to minimize the movement of site contaminants off-site and to impede
groundwater flow into the site, as described by Alternative 2 of the 1992 ROD. The
barrier wall would be keyed into a clay confining layer approximately 25 feet below the
surface. The pumping of groundwater from within the area surrounded by the slurry
wall would maintain an inward groundwater gradient across the wall, where technically
practicable. Contaminant source areas would be covered with a soil cap to reduce the
infiltration of rainwater and snowmelt into the area enclosed by the slurry wall, and to
prevent workers from directly contacting site contaminants. (Note: a barrier wall
consisting of high-density polyethylene plastic and a bentonite-soil slurry was installed
on the ACS site in 1997, see Figure 1.)
b. Deed Restriction
A deed restriction will be maintained on the ACS property so that the future use of the
property will be restricted to those activities which do not interfere with the performance
of any cleanup activities listed in the 1992 ROD and this ROD Amendment, or disturb
the integrity of the soil cap to be placed over the site.
2. Treatment of subsurface soils through soil vapor extraction
As described in Alternative 5 of the 1992 ROD, U.S. EPA would dewater the area
behind the barrier wall, using a series of groundwater pumping wells, to allow for the
excavation of intact drums containing hazardous wastes. Intact buried drums in the
On-site Containment Area would be incinerated off-site. An in-situ vapor extraction
(SVE) system would then be installed in certain areas of the site to treat both soils and
buried wastes to remove VOCs and to also help to biodegrade VOCs and SVOCs in the
ground. Removal of VOCs helps to prevent failure of the slurry wall and removes the
explosion hazard associated with excavation of the soils. Collected VOCs and SVOCs
would be destroyed on-site using catalytic oxidation equipment or captured on activated
carbon for off-site destruction or disposal.
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3. Extraction and treatment of contaminated ground water
Groundwater pumping and treatment would be performed in certain areas outside the
barrier wall to restore groundwater quality. Treated groundwater would be discharged
to the wetlands. Monitored natural attenuation and in-ground treatment methods may
also be tested and used if successfully proven to restore groundwater quality. Natural
attenuation is the general process of monitoring water quality over a period of time to
demonstrate that natural processes are causing contaminant levels to fall due to a
combination of dilution, biodegradation, and sorption forces within the groundwater
aquifer. Should dilution, biodegradation, and sorption forces cause water quality to
improve in a reasonable time frame versus active treatment methods, then monitored
natural attenuation can be considered to be a viable cleanup alternative for
groundwater. In ground treatment methods could include the introduction of oxygen-
releasing compounds into the contaminant areas to aid in the biodegradation of organic
compounds, and improve water quality.
U.S. EPA is currently collecting all appropriate data for the above alternatives to the .
groundwater pump and treat remedy selected in the 1992 ROD, to determine whether
they could be used effectively at the ACS site. The agency expects to conclude its
evaluation by Summer 2000. By that time, U.S. EPA will have examined all data and
performed an analysis to determine whether the alternative methods would be expected
to achieve the 1992 ROD cleanup goals in a reasonable timeframe for area
groundwater. If the alternative methods appear to be viable, then U.S. EPA will
consider a further amendment of the 1992 ROD by releasing another proposed plan for
public comment.
4. Excavation of impacted wetlands soils
To remove direct contact hazards, the excavation of PCB-laden wetland soil/sediment,
with the consolidation under the on-site cap of materials with less than 50 ppm, and the
disposal off-site of material containing greater than 50 ppm, would be performed.
Evaluation of ROD Amendment
U.S. EPA has evaluated the 1999 ROD Amendment in comparison to the 1992 ROD '
remedy, using the nine criteria below:
Overall Protection of Human Health and the Environment - addresses whether or not a
remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced, or controlled through treatment, engineering controls,
or institutional controls.
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Compliance withrARARS (Applicable or Relevant and Appropriate Requirements) -
addresses whether or not a remedy will meet all of the applicable or relevant and
appropriate requirements (ARARs) of Federal and State environmental laws.
Long-Term Effectiveness and Permanence - refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup goals
have been met.
Reduction of Toxicity. Mobility, or Volume - refers to the anticipated performance of the
treatment technologies a remedy may employ.
Short-Term Effectiveness - involves the period of time needed to achieve protection,
and any adverse impacts on human health and environment that may be posed during
the construction and implementation.
Implementabilitv - is the technical and administrative feasibility of a remedy, including
the availability of goods and services needed to implement the chosen solution.
Cost - includes estimated capital and operation and maintenance costs, and estimated
present worth costs.
Support Aaencv Acceptance - indicates whether, based on its review of the Proposed
Plan, the support agency concurs, opposes, or has no comment on the preferred
alternative. This acceptance is typically assessed from support agency comments
received during the public comment period.
Community Acceptance - will be assessed following a review of any public comments
received on the Proposed Plan for ROD Amendment.
The nine criteria outlined above are commonly divided into three groups: threshold
criteria, balancing criteria, and modifying criteria. The first two criteria are threshold
criteria, and any proposed remedial action under consideration must satisfy them. The
rest are balancing and modifying criteria, and are used to evaluate the strengths and
weaknesses of those alternatives that satisfy the threshold criteria, leading to the
selection of a cleanup alternative.
Overall Protection of Human Health and the Environment
The site cleanup remedies set forth in both the 1992 ROD and in this ROD Amendment
will protect human health and the environment. Potential routes through which humans
and/or environmental receptors could be exposed to site contaminants (pathways)
include ingestion of contaminated groundwater, direct contact with contaminants in the
subsurface soil, and the movement of VOC contaminants from the subsurface soil into
the groundwater.
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The 1992 ROD remedy addressed the soil exposure pathway through the excavation of
contaminated soil to cleanup levels, with the subsequent treatment of contaminated
soil using LTTD and the solidification of soil contaminated with heavy metals. The
ROD Amendment addresses the soil pathway through the placement of a soil cap and
barrier wall, plus the implementation of SVE to remove VOCs and, to a lesser extent,
SVOCs, from the ground. Excavation of PCB-laden soil in the wetland area, and the
placement of deed restrictions on the property, would also prevent exposures to
contaminants.
Thus, while the 1992 ROD cleanup remedy relied solely on the destruction and/or
solidification of soil contaminants, the ROD Amendment relies on a combination of
treatment and containment methods to minimize exposure pathways.
Compliance with ARARs
The 1992 ROD cleanup methods would have complied with the ARARs listed in that
document. This ROD Amendment will comply with the ARARs listed in the 1992 ROD,
and any state and federal laws that may have since been updated. The ROD
Amendment requires that the remedial actions comply with the current versions of the
ARARs listed in the 1992 ROD.
Long-Term Effectiveness and Permanence
The 1992 ROD remedy achieved long-term effectiveness and permanence through the
removal and destructive treatment of groundwater, subsurface soil, surface soil
contaminants (except heavy metals, which cannot be destroyed).
The ROD Amendment achieves a lower level of long-term effectiveness and
permanence for the soil, although some treatment of VOCs would occur. Residuals
would be managed over the long term by containment within the barrier wall and cap
structure.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Both the 1992 ROD and the ROD Amendment utilize permanent treatment technologies
to address soil contaminants. The 1992 ROD would treat the entire soil contaminant
mass. The ROD Amendment would only treat the VOCs and the SVOCs to a lesser
extent. However, the SVE treatment would remove the more mobile compounds so
that they are not a future source of groundwater contamination.
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Short-Term Effectiveness
U.S. EPA estimates that short-term impacts due to site cleanup work will be lower
under the ROD Amendment than under the 1992 ROD. Short-term impacts typically
associated with large-scale excavation activities (such as the release of dust and of
vapors from wastes with high levels of VOCs) and the methods to alleviate the impacts
(extensive vapor-control methods), would be of concern under the 1992 ROD. A
significantly lower volume of contaminants will be excavated under the ROD
Amendment than under the 1992 ROD, and U.S. EPA expects the duration of impacts
to be much shorter.
In addition, U.S. EPA estimates that the length of time of the cleanup activities under
the ROD Amendment is much shorter than under the 1992 ROD, due to other factors
besides the soil volume difference. U.S. EPA estimates that it will take about 3 years to
complete construction work under the ROD Amendment, from the time equipment is
brought to the site to begin work, to the time the soil cap is completely in place,
although the SVE equipment will likely operate for 2-10 years afterwards before it can
be turned off. The 1992 ROD remedy would have required about 6-8 years to
complete the excavation and LTTD process. U.S. EPA estimates that the duration of
the groundwater cleanup effort would be the same under the 1992 ROD or the ROD
Amendment.
Implementability
The ROD Amendment will be less difficult to implement than the 1992 ROD.
Construction and operation of SVE equipment at the site would be less difficult
logistically than construction and operation of the LTTD technology. SVE technology
is readily available on a commercial scale and have been previously used for the
treatment of VOCs at other sites.
Cost
The ROD Amendment will cost significantly less to implement than the 1992 ROD
cleanup (as revised due to the results of the materials handling and treatability studies):
The estimated cost for completing the ROD Amendment, using one or more of the
various cleanup methods, ranges from $45 million to $50 million (in addition to the
estimated $13 million spent to date implementing the limited remedial actions now in
place and performing the treatability and materials handling studies). This cost
estimate includes an $18 million capital cost plus $27 million (present net worth at a 5%
discount rate) in operation and maintenance (O&M) costs over 30 years. The revised
cost estimate for implementing the 1992 ROD is $150 million to $246 million, including
O&M costs.
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Support Agency Acceptance
The State of Indiana concurs with the ROD amendment.
Community Acceptance
U.S. EPA has evaluated community acceptance of the ROD Amendment in the
attached Responsiveness Summary.
Statutory Determinations
The Superfund law (CERCLA), requires U.S. EPA to clean up NPL sites ta achieve the
protection of human health and the environment in compliance with Federal and state
environmental laws and policies (ARARs). Selected cleanup remedies must also be
cost-effective and utilize permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable, with an emphasis on
cleanup remedies that employ treatment to permanently and significantly reduce the
toxicity, mobility or volume of the hazardous substances, pollutants or contaminants.
Based upon the evaluation of the nine criteria, U.S. EPA believes that the ACS site
ROD and ROD Amendment satisfy these requirements of CERCLA, in that the ROD
and ROD Amendment would be protective of human health and the environment, would
attain ARARs, would be cost-effective, and would use treatment technologies to
permanently and significantly reduce the toxicity, mobility or volume of the hazardous
substances, pollutants or contaminants to the maximum extent practicable.
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RESPONSIVENESS SUMMARY
American Chemical Service, Inc. Site
Griffith, Indiana
The public participation requirements of CERCLA §113(k)(2)(B)(l-v) and CERCLA §117
have been met during the 1999 Record of Decision (ROD) Amendment process for the
American Chemical Service, Inc. (ACS), site. Sections 113(k)(2)(B)(iv) and 117(b) of
CERCLA require U.S. EPA to respond "...to each of the significant comments,
criticisms, and new data submitted in written or oral presentations" on a proposed plan
for a remedial action. This Responsiveness Summary addresses those concerns
expressed by the public, potentially responsible parties (PRPs), and governmental
bodies in written and oral comments received by U.S. EPA regarding the proposed
1999 ROD Amendment for the ACS site.
Background
U.S. EPA issued a fact sheet/proposed plan for this ROD Amendment in April 1999 to
the public in the Town of Griffith, Indiana, prior to the start of the public comment
period. U.S. EPA placed an advertisement announcing the availability of the proposed
plan and the start of the comment period in the Hammond Times (Ridge Zone), on April
15, 1999.
U.S. EPA maintained information repositories at the three following locations: U.S. EPA
Region 5, 77 W. Jackson Blvd., Chicago, IL; Griffith Branch Library, 940 N. Broad St.,
Griffith, IN; and at the Griffith Township Hall, 111 N. Broad St., Griffith, IN. The Agency
made the Administrative Record available to the public for review at each of these
locations as well.
The public comment period ran from April 19, 1999, to May 21, 1999. U.S. EPA
received no timely requests for an extension to the 30-day comment period.
The Agency hosted a public meeting at the Griffith Township Hall on May 13, 1999, to
provide background information on the Site, provide details of the proposed 1999 ROD
Amendment, and to take oral public comments regarding the proposed amendment to •
the Site cleanup action. U.S. EPA answered questions about the Site and the 1999
ROD Amendment proposal under consideration. A court reporter documented formal
oral comments on the Proposed Plan and U.S. EPA has placed a verbatim transcript of
this public meeting in the information repositories and in the Administrative Record.
Written comments were also accepted at this meeting, although none were submitted.
Approximately 18 persons attended the meeting, including local residents, agency
representatives and potentially responsible party (PRP) representatives.
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During the comment period, U.S. EPA received 2 sets of written comments and 7
people provided oral comments during the public hearing concerning the proposed
plan. This Responsiveness Summary includes comments received during the public
comment period and the U.S. EPA's responses to those comments, and is a part of the
1999 ROD Amendment.
Summary of Significant Comments
A. Written
Comment 1A: Mr. George E. Smolka, Griffith, IN
Mr. Smolka mailed a set of 21 comments to the agency on May 21, 1999, some of
which were also given during the public hearing:
"My commentary concerning the superfund site known as American Chemical Service
(ACS) located in Griffith, IN is divided into three sections:
I. Commentary on statements made during the May 13th public meeting by EPA,
IDEM, and the PRP representatives in the persons of their consultant, Montgomery
Watson, Inc.;
II. Commentary on the technical efficacy of the proposed containment method; and
III. Commentary on the long term probabilities of the proposed ROD and questions
about technologies which might apply but were not mentioned at the meeting.
1. 'The most telling statement made during the hearing was made by Kevin Adler of
EPA in the introductory comments of his part of the presentation. He state[d] that the
EPA had grave concerns about the safety of the ACS personnel if the buried toxic
materials on site were exhumed and processed. If EPA has concerns about" the casual
transitory exposure of above ground personnel how can it ignore the long term effects
of such obviously dangerous chemicals on the air and drinking-water of the town of
Griffith?
2. "Furthermore, since migration of the toxic plume may already have reached the
retired old Griffith landfill site and since the leachate of this site is simply being pumped
out into the adjacent legal drain without treatment, how can the EPA ignore [that] this
continues exposure of the adjacent lands and people to the toxics at ACS for the
indefinite period of the containment?
3. "The statement was made [during the public hearing] by Mr. [Peter] Vagt [of
Montgomery Watson] that the ground level aquifer rests on a clay bed of glacial origin
of some 3.05 m deep. While this is clearly an adequate barrier for water, no evidence
was presented that this is an adequate barrier to one or all of the toxic organics
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permeating the ACS site. The time span for the proposed containment is indefinite,
and therefore even very slow migration of toxics through this layer poses a long term
potential hazard.
4. "Mention was made by several participants that some if not a majority of the existing
toxics are contained in buried drums. If this is the case, careful handling of those still
intact, poses little no hazard except for the surface contamination from adjacent
ruptured drums. To leave these potentially hazardous but to this date processable
components in contact with wet earth until they too rust through and rupture is nothing
less than criminal negligence. Furthermore, the simplest student will be able to
calculate that processing intact drums is far less costly than thousands of cubic meters
of contaminated wet soil.
5. "Mr. Adler indicated that no attempt was made to ascertain the extent of migration of
the ACS plume into the abandoned Griffith landfill. The reason given was that there
was no way of knowing what materials were already present in the landfill and
identification of the isolated ACS components might be impossible. By the same
reasoning additional toxics may be percolating from the Griffith landfill onto the ACS site
which may be more difficult to deal with or may interact chemically with ACS wastes to
produce even more toxic products. Ignorance may be bliss but it is also frequently
deadly. The probability may be low, but would you risk your children or grandchildren to
this numbers game?
6. 'When queried about heavy metals none of the regulatory personnel or those from
Montgomery Watson had much information about heavy metal contamination at the
ACS site. Since I made my living as a chemist and biochemist in industrial settings for
many years, I know that various heavy metals are used in industrial synthesis,
reformation, oxidation and other processes of the chemical industry. Since also, the
solvents used for processing final products come in contact with these catalysts and are
contaminated by them, I find it very strange indeed that so little knowledge about heavy
metals is available. Some of these are highly toxic. Moreover, they may react in an
acidic environment to give very deadly products which may be volatile or very water
soluble.
7. "When asked about the monitoring system currently being used at ACS, the
response from regulators and consultants seemed to indicate that no material specific
sensors were in use, other than pH sensors. Neither gas-specific detectors nor
compound specific electrodes, nor redox detectors, to mention but a few, were in use.
Considering the advanced state of statistical process control devices and other
analytical methods available "off the shelf the lack of automated, computer controlled
monitoring leaves me puzzled. The tenants of Murphy's law should teach you that
things will go wrong at the most inopportune time. As one example, what will you say if
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a dangerous, let-alone deadly, outgassing occurs during a long week end and there is
no one on site to monitor?
"Two major aspects of the ACS site lead me to believe that the proposed changes to
the ROD are categorically the wrong choices. 1. The hydrology of this area is both
pervasive and dynamic and 2. The volume and mass of the contaminants is potentially
so large as to pose a threat for even innocuous materials:
8. Clean water leaking down from the upper aquifer to the lower of course poses no
threat but more importantly would not be detectable easily. That any natural layer is
imperfect and filled with flaws, weak spots, cracks and fissures is known to any
geologist. To assume that the clay layer under ACS is intact and flawless, without
thorough testing, is ridiculous Once the lower aquifer is contaminated it will be
impossible to reverse. Even with adequate monitoring of the lower aquifer and the
future ability to detect leakage at an early stage, the outlay of money for capping and
monitoring would be wasted if as a result of future leakage the site has to be dug up
anyway.
9. "Furthermore even a very low contamination with some materials, where the health
hazard level is close to the limit of detection, would make the lower aquifer unusable.
That is a blatant wastage of resources. On this basis alone the material must be dug
up and destroyed before irreversible contamination occurs.
10. "What will be the effect of hydrostatic pressures and subterranean streaming on the
containment barrier? Are these dynamics understood for this site?
11. "My understanding of the monitoring system currently in place seems inadequate to
the needs of the site. I respectfully request a complete set of protocols for this site to
more fully evaluate the proposed methods.
12. "No attention seems to have been paid to the potential for chemical reactions
occurring underground at the site. Of particular concern to me is the well known effect
of some solvents to act in synergy with others to mobilize materials that are not soluble
in either neat solvent (multitudinous examples exist in the literature). Furthermore it is
a well known fact that anaerobic oxidations lead to significantly changed materials in
landfill types of environments (e.g., the formation of large quantities of methane in
landfills). Not only degradation reactions occur but reformation reactions also. In this
vein, toxic, explosive, and solvency problems may arise at this site which are not
expected and will be very costly and difficult to deal with. To avoid this class of
problems, the only logical answer is separation, removal and destruction of the
materials at this site. I do not wish to imply that the probability for such problems is in
my estimation high, but if they occur, the cost for remediation will be enormous.
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13. "The barrier erected suffers from a lack of in-ground experience. These types of
[high density polyethylene] HDPE layers backed by bentonitic clays have only been in
use for some fifteen years, at most. I have some experience with accelerated testing
and know that in most cases it is a poor predictor of stability of containers. Under
accelerated testing, some things fail that won't under simple time testing and others
survive that completely fail under time testing. I will not bore you with the rational,
reasons and chemistry for this since it is very complex. It is already known that under
the time-dependent impact of organic solvents, a bentonitic barrier begins to increase in
permeability. Since it is clear that the site will be in existence for many years, it is a bad
place to test this technology; failure will be very costly.
14. "Has the cost of pollution of the upper and lower aquifer as lost resources and
added costs for water to the town of Griffith been included in the +$47 million estimate?
Is someone prepared to accept these costs should they occur?
15. "Is the long term cost of years of monitoring included in the $47- $50 million price
tag? Has there been provision for Hazmat costs associated with an emergency
generated at the site. Is there a Hazmat team and all the necessary equipment
available for an unforeseen emergency? Are the costs for this included?
16. "I feel that both EPA and the PRP's (Principally Responsible Parties) are in too
much of a hurry to bring this problem to a conclusion in the cheapest way possible.
You run the risk of never enough time (or money) to do it right, but always enough time
(or money) to do it over. The "do it over" costs will far exceed the current high estimate
both in current and inflated dollars.
17. "The continued existence of the hazardous materials at the site and the increasing
time dependent risk of mixing, chemical and physical interaction, percolation, diffusion
and dispersal overtime by many mechanisms other than water flow; make this
[proposed] ROD [amendment] seem a very poor excuse for a solution.
18. "Accidental and catastrophic exposure and dispersal are only possible if the
hazardous material is still in place. Should such an event or events occur, you will not
have the luxury of debate and consideration. Action will have to be immediate and
concentrated. Such actions are both very costly and have an increased risk of failure
(crash programs tend to crash). In a political climate of increased accountability do you
[EPA] and the PRPs want to answer for such an avoidable disaster?
19. "While you address the possibility of oxygen donor enrichment you do not mention
any of the currently experimental and or foreign bioremediation methods available in
the literature and as articles of commerce. Single-celled organisms (both selected and
engineered) of various types have been tested by inoculation and injection in situ under
varying conditions all over the world for bioremediation of ACS-types of problems.
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Have either EPAror the PRP's looked at the possibility and applicability of such
solutions to the ACS problem?
20. "The plans for the remediation of the affected adjacent wetlands has not been
addressed. Could you please send me a complete plan with protocols for this phase of
the restoration?
21. "A conceptual problem exists with an indefinite monitoring period. As time
proceeds and the people involved in the original decision retire or die, the seriousness
of the problem, its potential effect on the community will fade from conscience and the
mounting cost will all exert pressure to discontinue monitoring. If a long period of years
of problem-free operation precede such a decision, all involved will be lulled into
complacency and wishful thinking. All other factors not withstanding, human nature will
push for such a decision. Many of the most serious consequences may occur
imperceptibly slowly and take many years to become apparent. We live in a society
with a very short memory and little appreciation of history. To leave a potential problem
in place, like a sleeping monster, is at best foolish."
Response 1A:
1. U.S. EPA regrets that the commenter may have misinterpreted Mr. Adler's remarks
made during the public hearing. Through the proposed plan for ROD Amendment,
U.S. EPA expressed its concern for the safety of site cleanup workers should low
temperature thermal treatment (LTTT) or incineration be implemented as an ACS site
cleanup remedy. According to site studies, soil and debris heavily laden with volatile
organic compounds (VOCs) could lose up to 60% or more of the contaminant mass due
to volatilization during handling, which could pose an explosive hazard as well as a
toxic exposure problem to cleanup workers. These potential exposures would certainly
not be "casualty] transitory." Nearby the cleanup site, ACS, Inc., workers and local
residents would also be potentially at risk should uncontrolled emissions occur during
the widespread excavation and materials handling operations needed to support either
LTTT or incineration treatment methods.
Further, U.S. EPA discussed during the public hearing the nine criteria that the agency,
uses to evaluate potential cleanup alternatives at Superfund sites. Two of those
criteria were "short term effectiveness" and "long term effectiveness," which suggest
that the agency must consider the short term effects of cleanup alternatives (such as
exposure to very high levels of toxins or unsafe working conditions during a cleanup
action) in conjunction with the long term effects of cleanup actions (such as the
potential for future exposures to much lower levels of toxins, if any, over a long period
of time) and try to determine the most feasible cleanup route to take. In this case, it is
clear to the Agency that unacceptable short term risks couid occur if site-wide
excavations were necessary during the cleanup action. Conversely, the containment
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with treatment remedy would prevent off-site exposures to site contaminants over the
long term so as to reduce the potential for exposure to site contaminants in those
areas.
U.S. EPA also disagrees with the commenter's assertion that the agency is 'ignoring the
long term effects of site contaminants on the air and drinking water' of Griffith, IN.
Implementing the 1992 ROD, as modified by the 1999 ROD Amendment, will clean up
groundwater to drinking water standards and provide protectiveness over the long term.
Site-related contaminants are not being released to the air in sufficient quantities to
cause measurable risks at this time. The performance of the cleanup remedy, as
amended, will help prevent both short term and long term uncontrolled air emissions
from the site by removing a great part of the mass of VOCs using the SVE treatment
systems and by placing a barrier between the ground and the atmosphere (cap) that
will help to prevent VOC emissions to the atmosphere.
2. U.S. EPA again disagrees with the commenter's assertion that the agency is
'ignoring continued exposure of ACS contaminants to adjacent lands and people.' As
explained in the 1992 ROD, the town landfill was originally added to the ACS site
listing; however, investigations showed that:
"The Baseline Risk Assessment did not identify any completed exposure pathways from
the landfill. Additionally, the [Remedial Investigation] Rl did not indicate that the landfill
was causing any downgradient ground water contamination. This could be due in part
to the dewatering activities at the landfill. As part of the Rl, it was determined through
[groundwater] modeling, that if the current dewatering system was discontinued the
ground water flow patterns would not change significantly. Given these facts, this ROD
does not require remedial action at the Griffith Municipal Landfill." [1992 ROD, p. 31]
Further, the proposed containment-with-treatment remedy would prevent contaminants
from moving off site into the landfill area. Thus, the landfill area would not be a
concern in terms of the ACS site cleanup action under either the 1992 ROD or the 1999
ROD Amendment cleanup methods. The town of Griffith must address any
contaminants which users of the landfill place in the town landfill, under its landfill
closure agreement with the state of Indiana.
Furthermore, results of recent groundwater monitor well sampling in the town landfill
show that little or no ACS-type contaminants are found there, confirming the Agency's
decision in the 1992 ROD to delete the landfill from the site. (Note: U.S. EPA has
placed this information in the information repository.)
3. U.S. EPA agrees with the commenter that the movement of "toxins" through the clay
layer could be a long term concern at the site, but only if nothing was done about the
site contamination. The Agency recognizes that the volatile organic compounds
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(VOCs) beneath^he ACS site are the most mobile contaminant fraction, and that semi-
volatile organics (SVOCs) and, to an extent, heavy metals are less likely to move off-
site, since SVOCs and metals tend to sorb onto clay particles very tightly. Also,
SVOCs are less soluble in water than VOCs, and thus will not tend to move with the
groundwater as readily as VOCs will.
The Agency will use several active treatment methods to prevent VOC-contamination
from reaching the lower aquifer by removing the more mobile contaminant fraction from
beneath the site. The soil vapor extraction (SVE) systems will be installed to remove
the VOCs from the ground, and groundwater from within the barrier wall will be pumped
out to create an inward gradient, reducing the potential for contaminants to move off
site through the barrier wall. The removal of the mobile VOCs lowers the possibility of
their later movement through the clay layer.
However, the Agency recognizes that groundwater levels in the upper aquifer within the
barrier wall cannot be lowered enough to produce an upward gradient from the lower
aquifer, through the clay layer, to the upper aquifer. The upward gradient would help
prevent the downward movement of VOCs through the clay layer. Therefore, there will
be periodic monitoring of the groundwater beneath the site, to ensure that the lower
aquifer remains free of site contaminants. This monitoring will detect any break-
throughs, which will then be handled appropriately by, for example, pumping and
treating the impacted groundwater. Even so, the Agency believes that handling
potential lower aquifer contaminants, if any, in this manner will be safer than digging up
the contaminant mass for treatment above ground.
4. The Agency agrees that the removal of intact drums of contaminants is highly
desirable. Such a removal is an integral portion of the overall ACS site cleanup plan.
Note that the 1992 ROD called for the removal of about 400 drums of waste from the
site, and that this number has since been raised to perhaps as high as 2500 after
further testing was performed at the site. However, during the public hearing a few
people questioned whether it was true that over 80,000 drums of waste may be buried
at the site and if so, why aren't we removing them.
The Agency acknowledges that there are quite a few drum carcasses disposed of in the
"Off-site Containment" area, but test pits dug into the ground in that area showed that
many were damaged and therefore incapable of holding any liquids. It would be safer
to remove the VOC contaminants from the ground using SVE rather than digging up the
highly contaminated soil and debris for processing in a thermal treatment device. If the
great majority of the (estimated) 80,000 drums were intact, then the cleanup alternative
more than likely would have contemplated a drum removal component.
5. (See also response to comment 2., above.) Previous investigations ruled out the
need to further ascertain the extent of ACS site contamination into the town landfill.
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Moreover, the barrier wall containment system is designed to both prevent the
movement of ACS contaminants off-site and the movement of off-site contaminants on
site. Should that happen, however, the containment system is designed to capture
and remove them by pumping out groundwater to maintain an inward gradient.
6. Heavy metals are not the primary contaminants of concern at the ACS site.
According to the 1992 ROD, certain heavy metals are found in the soil and debris
beneath the ACS site. These metals include varying concentrations of lead (as
mentioned at the hearing), antimony, thallium, arsenic, cadmium, beryllium,
manganese, barium, and chromium (+6 valence). However, lead was identified in the
1992 ROD as indicator metal (that is, if you clean up lead-containing soils then the rest
of the metals would be cleaned up as well). Groundwater in the lower aquifer appears
to contain naturally occurring levels of arsenic. The containment system is designed
to contain these compounds as well as the VOCs and other organic compounds
mentioned at the public hearing. Any volatile compounds created by heavy metal
catalysts would be removed by the SVE treatment system. Soluble metals would be
removed by the groundwater pumping system inside the barrier wall.
7. The monitoring systems and sensors used are standard for the water treatment
industry. Computer controls are adequate to monitor the pumping and treatment
systems on a day-to-day basis, also, a trained operator is present 5 days per week to
perform necessary maintenance and upkeep. Should a standard parameter become
off-specification, the computer automatically shuts down the pumping system until the
human operator can fix the problem. "Deadly" outgassings would not occur since the
concentrations of contaminants in the water being treated do not approach levels at
which a "toxic cloud" would be created upon treatment equipment failure.
The effluent is monitored on a routine basis in accordance with the National Pollutant
Discharge Elimination System (NPDES) requirements for water treatment plants under
the Clean Water Act. Under the NPDES requirements, the ACS PRP Group has
received a permit from the state of Indiana to discharge treated water from the plant as
long as it meets allowable discharge standards. The routine monitoring is performed to
demonstrate compliance with the discharge permit and to also show that equipment is
functioning properly.
8. Enough monitor wells have been placed into the site area to delineate the extent of
the clay layer between the upper and lower aquifers such that the Agency is more than
comfortable with the assumption that it is continuous beneath the site in the
containment area. Installation of the barrier wall also verified the extent of the clay
layer, as the barrier wall is keyed into the clay layer. Monitoring water quality is thus an
adequate measure to ensure containment.
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Additionally, if leakage was discovered, the situation would not automatically cause the
site to be dug up as the commenter assumes. In-place cleanup measures, if needed,
using such technologies as grout injection, could be performed to mitigate leakage
through the clay layer or barrier wall.
9. The Agency agrees with the commenter that some chemical compounds (such as
vinyl chloride and benzene, to name but two) may demonstrate long term health effects
at very low levels. However, a detection of low levels of compounds in the lower
aquifer does not preclude its use as a drinking water source. The safety of site cleanup
workers and local residents must be taken into account before stating that the material
must be dug up as the only solution to the problems at the site.
10. The hydrostatic dynamics for site soil types (sand) are well documented in the
geotechnical literature and have been taken into account for the construction of the
barrier wall. Hydrostatic pressure is one reason why complete dewatering of the area
within the barrier wall (to expose all VOCs to SVE) cannot occur. The barrier wall could
well collapse if complete dewatering occurred. Also, barrier walls such as the one
installed on the site are routinely "keyed" into an underlaying clay layer to guard against
"subterranean streams" breaching the containment system.
11. The protocols for the site groundwater monitoring system are available in the
information repositories listed above. The Agency believes the amount of monitoring is
adequate to protect human health and the environment.
12. The Agency is aware that chemical reactions take place underground at cleanup
sites such as the ACS site. For instance, common dry cleaning solvents found in
groundwater break down into different chemical compounds under differing
underground conditions. These compounds are a concern. If the solvents encounter a
reducing or anaerobic (oxygen-poor) environment, such as that found beneath landfills,
vinyl chloride could form in the groundwater. Aerobic (oxygen-rich) conditions
generally would preclude the break down of the solvents into vinyl chloride.
At the ACS site, the SVE system will be employed to remove mobile VOCs from
beneath the site. Additionally, the SVE system will help to introduce oxygen into the
underground areas, which will facilitate the aerobic degradation of many semi-volatile
organic compounds into smaller compounds that would be recoverable by SVE.
Furthermore, the groundwater pumping system will also remove soluble compounds
formed underground for treatment in the groundwater treatment plant. Thus, complete
excavation and treatment of the site soils and debris is not the only answer.
13. The Agency disagrees with the commenter's implication that the barrier wall
technology is merely being "tested" at the site. Subsurface barrier walls are proven
technologies in use at many cleanup sites throughout the nation. Although the Agency
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agrees with the eommenter' that bentonite clay can become more permeable over time
when exposed to high levels of VOCs, the barrier wall is a combination of high density
polyethylene (HDPE) plastic and bentonite clay. These two materials in concert help to
guard against wall failure. Also, SVE is being used to remove or bioremediate the
high levels of VOCs found in the ground, so that less pressure is placed on the
bentonite clay to remain as impermeable as when the barrier wall was first installed. In
addition, the containment system uses the groundwater pumping system as a
safeguard against wall leakage. Should a leak occur, the inward gradient across the
barrier wall serves to help direct water flow into the site area through a leak and not out
through the leak. Standard technologies would then be used to repair any leaks in the
barrier wall upon discovery.
14. The loss of use of the ACS site portion of the upper and lower aquifers is
categorized as "natural resource damage" by state and federal officials. The U.S. Fish
and Wildlife Service and the Indiana Department of Environmental Management (the
natural resource trustees) may bring a natural resource damage claim against all
potentially responsible parties to compensate for the loss of natural resources. The
natural resource damage estimate is not included in the site cleanup cost estimate,
however. To date, no burden has been placed on the town of Griffith water supply and
none is foreseen. Should the site impact the water supply, the town of Griffith could
have legal recourse against the parties involved at the site (although it would be a
matter for the courts to decide).
15. The cost of long term groundwater monitoring is included in the future response
cost estimate given in the proposed plan. These costs are included in the long term
"Operation and Maintenance" costs for the site.
The Agency has responsibility for ensuring "Hazmat" teams are available for
deployment at all emergency cleanup sites. Such teams can be comprised of
members of local fire departments, state personnel, or federal personnel and
associated cleanup contractors. The estimated response costs at the site do not
include future Hazmat response costs (if any). Moreover, the ACS PRP Group or its
contractor(s) would be responsible to react to emergency situations which they cause.
16. The Agency and the ACS PRP Group have been studying the site problems in
different capacities for some time. With the information we now have, it is time to stop
studying the problem and to start implementing a solution. Although the "do it over"
cleanup costs may exceed the current cleanup estimate, the Agency believes that the
potential human cost of loss of life of a cleanup worker due to hazardous working
conditions that may occur during an excavation, is higher than any "do it over" cost.
Moreover, cost is one of the nine criteria the Agency uses to evaluate cleanup methods.
Although not as important a criterion as overall protection of human health, cost is an
important issue at all cleanup sites.
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17. (See also response to comment #12, above.) Based upon the nine criteria for
evaluating a cleanup remedy, the Agency believes that the ROD amendment proposal
is a strong one.
18. As demonstrated by the materials handling study performed on site wastes,
"accidental and catastrophic exposure and dispersal" is also possible if the material at
the site is excavated and handled for treatment as required under the 1992 ROD. It is
much safer to address the contaminants in the manner presented in the proposed plan
for ROD amendment. The Agency is assuming accountability at any site for which it
issues a Record of Decision, as required under Superfund law.
19. The Agency has not pursued the inoculation of site soil and debris with selected or
engineered organisms to assist in the bioremediation of site soils. However, the ROD
amendment does not preclude such a plan. (Note that the ACS PRP Group is testing
groundwater cleanup through the injection of a non-organic oxidizer (trademark name:
"Oxygen Releasing Compound" (ORC)) into the upper aquifer in limited locations. The
ORC slowly releases oxygen into the groundwater to assist naturally-occurring aerobic
bacteria in the water to use the organic compounds present as food, and therefore
clean up the water.)
20. The Agency has approved the excavation plans for the wetlands contamination,
and placed them in the information repository. Restoration plans are subject to review
by the natural resource trustees at the site, the U.S. Fish and Wildlife Service and the
Indiana Department of Environmental Management. The restoration plans are not yet
completed, but will be placed into the information repositories when completed.
21. The costs of long term groundwater monitoring are included in the estimated
(present worth) cleanup costs for the site. Moreover, the decision to monitor is in
keeping with closure requirements for municipal landfills (such as the adjacent town
landfill). It is not unusual to expect the level of monitoring to fall as conditions allow as
the years progress, although increased monitoring could occur as well. The SVE
system will have removed a large part of the principal threat (the VOCs) at the site so
that the need to monitor at a high rate may lessen, but until the site is no longer
potentially harmful to human health or the environment, monitoring will continue.
Comment 2A: The ACS RD/RA Executive Committee and Members ("PRPs"), through
Karaganis & White, Ltd., Chicago, IL. The ACS RD/RA Executive Committee
("Committee") submitted the comments below as well as supporting information from
the administrative record:
1. "The Committee supports the amendment of the ACS Site ROD to eliminate the
requirement for low temperature thermal treatment at that Site. As the Agency is
aware, the Committee developed the Material Handling Study and Low Temperature
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Treatability Study which clearly demonstrate the such technology is not technically
appropriate or cost-effective for the ACS Site. These studies have now been cited as
part of the EPA's basis for amending the ROD.
2. "The Committee also supports the modification of the ROD to include soil vapor
extraction systems as the treatment technology for the ACS Site. The combined
treatment/containment remedy now proposed for the amended ROD is the remedial
approach advocated by the Committee through the 1992 Feasibility Study and its 1994
Petition to Amend the ROD. We continue to support the modified remedial approach
as the most technically sound and cost-effective for this Site.
3. "....Members of the public raised concerns with respect to the Town of Griffith
ground water quality and the involvement of Town officials in the determination of the
Site future use scenario. With respect to the first concern, the Committee has sampled
the Town's monitoring wells for the organic constituents found in ACS Site ground
water. As the monitoring results show, the [Town] Landfill has not been impacted by
organic constituents similar to those [detected] beneath the ACS Site.
4. "... Town officials were involved in the Agency determination to adopt an industrial
use scenario. Town officials were asked about their anticipated plans for the relevant
area of Griffith, and consistently stated that the area was designated for
commercial/industrial uses. In fact, the Town indicated that residential uses had been
"grandfathered in" and as housing was vacated, new residential use would not be
allowed in the area.
5. "It is also useful to note that the materials used to construct the barrier wall were
tested prior to their installation to make sure they would withstand contact with high
concentration solvents. The materials were exposed to solvents and tests were
performed to show that the bentonite clay and HDPE plastic did not deteriorate."
Response 2A.
1. The Agency acknowledges the Committee's support for the proposed ROD
amendment, and agrees that the Agency evaluated the results of the above-cited
studies and used them as a basis for the ROD amendment.
2. The Agency acknowledges the Committee's support for the proposed ROD
amendment and agrees that the proposal is both "technically sound and cost-effective
for this site."
3. (See response to comment #2 from the previous commenter.)
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4. The proposed plan assumes that future use of the property will be
commercial/industrial. Should that change, it is likely that further cleanup would be
necessary to achieve residential standards for protectiveness. However, in the interim,
the deed restriction placed on the property will help prevent the unauthorized use of the
property not in accordance with the cleanup method enacted.
5. The Agency acknowledges that the Committee tested the barrier wall materials prior
to installation in an effort to show that the barrier wall materials would likely withstand
attack by the chemical contaminants beneath the site. However, as the previous
commenter pointed out, very long term data is lacking. Thus, the inward gradient and
the removal of VOCs using SVE are an important part of the site cleanup proposal.
B. Oral
Note: The following comments were taken from the official transcript of the public
meeting held to discuss the proposed plan and receive public comments on the
proposal. The entire transcript is a part of the administrative record for the ACS site.
Comment 1B: Rick Malmquist, address unknown
"...if there's 80,000 drums and you're only going to take out 400, it seems to me that
you could filter the ground for a hundred years and not get all this contamination out
unless you were to get out all those drums."
Reply 1B:
U.S. EPA discussed during the public meeting that the number of intact drums in the
Off-site Containment area is hard to quantify. As noted by the commenter, the 400-
2500 intact drums in the northern portion of the site (near the ACS facility) will be
removed for proper disposal as the agency estimates that these drums are able to be
handled safely. Although there may be a very large number of drum carcasses in the
Off-site Containment area, test pits dug into several of the drum disposal areas in the
Off-site Containment area show that perhaps only a very few are still able to hold their
contents. Thus, the agency believes that wholesale excavation of the off-site
containment area to find a few intact drums among the thousands of carcasses is not
conducive to a safe or cost effective cleanup action. Further, the agency believes it is
much safer to remove the spilled contents of the drums using soil vapor extraction
equipment. Lastly, the agency estimates that the soil vapor extraction equipment [used
to "filter the ground"] will be operated for 5-15 years to remove a large percentage of
soil VOC contamination, but the goal is not necessarily the complete removal of all
contaminants. The containment system is designed to handle residual contaminants
and prevent them from moving off site.
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Comment 2B: J©e Thomas, address unknown
1. "I think that there is completely inadequate information being given to the public prior
to this public comment period."
2. "If there is a question about the number of drums on the site, the EPA should come
up with an estimate that is dependable relative to the number of drums that were on the
site and how many, in fact, degraded and deteriorated over time and how many are still
out there. It doesn't seem to me that there's very much certainty about the number of
drums that can be removed intact. And it certainly isn't clear to me how many drums, in
fact, have deteriorated on the site."
3. "....I object to the assumed future use used in developing the amendment to the
ROD. I believe that it's unclear, at least it's unclear in answering the questions in this
setting, what the reason was for changing that assumed future use. It appears to be
that the polluters, that is the potentially responsible parties pushed the EPA into it. And
it was a way to get them to revise the ROD so that they could reduce the cost of the
cleanup. Now, if that's the case, then it's backwards."
4. "Regarding the assumed future use, it should go back to what it could be rather
than what EPA wants it to be if, in fact, it was a different future use, then it would
change the remedy of the ROD. And, on that basis, it's not clear to me that there's
been adequate information about that assumption of future use. And I object to them
changing the assumed future use."
Reply 2B:
1. The Agency believes that it made available to the public an adequate amount of
information for review to allow comment on the ACS site proposed plan for ROD
amendment. The proposed plan itself is not intended to contain every bit of information
gathered at a site, for it would be impossible to summarize all available site information
in a short, readable format. Rather, the proposed plan is a summary of the matters at
hand at the site, and it refers the reader to the information repositories, which contain
all site-derived information, for further information on which to base their comment(s).
2. The Agency estimates that there are between 400 and 2500 drums in the northern
part of the site that are intact and able to be removed for proper disposal off site. An
answer to the question of how many drums are degraded or deteriorated in the
southern portion of the site is not inexpensively or easily obtained, given the sheer
number of drum carcasses that have reportedly been placed in that area. The best
evidence indicates that only a very small percentage of drums are removable intact.
Based upon photographs taken at the site of test pits dug into the southern area of the
site, it is clear that a great number of the drums are deteriorated and cannot be
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removed intact. Moreover, the results of the material handling study show that it could
be very unsafe for site cleanup workers to handle the highly contaminated materials.
Given the high risks of removal and that there is clearly a high number of deteriorated
drums that will not be removed, the precise number of intact drums is thus not a very
useful figure to obtain.
3. U.S. EPA believes that assuming future industrial use of the ACS site is appropriate,
given that Town officials have indicated that the zoning in the area is not likely to
change in the future. Moreover, the potentially responsible parties have provided
material handling and treatability study data to U.S. EPA that show that the 1992 ROD
remedy could be unsafe for cleanup workers to implement, that low temperature
thermal treatment was not technically sound for use on much of the waste mass
(incineration would have to be used instead), but was overly costly to perform. All these
reasons supported the proposal to amend the ROD, not just the economic reason.
4. As the commenter points out, should the site zoning change in the future, then the
cleanup remedy may have to be revisited to accommodate that change. U.S. EPA
agrees with that assumption. However, U.S. EPA does not have a say in property
zoning matters, as that is for the Town to decide. The commenter is referred to the
Town to discuss zoning matters for the site.
Comment 3B: George Smolka, Griffith, Indiana
"I see a great many problems."
1. "Number one, the types of materials and the numbers of materials that were listed in
your proposal is woefully inadequate. The efficacy of the barrier wall depends in great
part on the types of materials you're going to be trying to retain and contain."
2. "Secondly, you're making an assumption that a clay layer is going to impede the
percolation of the organics. I would be more than willing [to say] .... yes, you will
contain it for a period of time, but we're talking an indefinite period of time. Unless that
material is removed over some reasonable period of time, it will eventually percolate
through everything. Once it reaches the second aquifer, I think you're going to have a.
very serious problem because you've got people that do have wells and are still using
wells for drinking water and other things."
3. "Once that second aquifer is contaminated, it is my humble opinion that cleaning that
up will be extremely, extremely expensive. Therefore, containment does not look to me
to be the best procedure because all you're doing is postponing the inevitable. And
since costs generally tend to go up, the overall costs are going to continue to go up."
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4. "... the nature of the materials that are down there including toxic metals really
needs to be addressed. Those things have a percolation or distribution rate quite
different from the organics you're trying to contain."
5. "....you're using ultraviolet. I have a question with respect to that. That's a free
radical initiative reaction which means that any chlorinated or I should say halogenated
organics have a potential for producing dioxin. It means that your destructive
technique, unless you're enriching it with oxygen as part of the system, it may be
causing as much harm as good."
6. ".. .since the last estimate of the plume was in '96, quite a lot of things could have
happened since then. You really need to have some idea of where this material is right
now and you don't. And that, as far as I'm concerned, is unacceptable."
7. 'There is a serious problem with an assumed future use with respect to property
rights. If that property at some long time in the future is acquired by somebody else
and they wish to use it in some other way, by assuming an industrial use, you lock them
into that use because these materials are not going to spontaneously disappear. That
infringes on their right to use the lands. I have a problem with that."
8. "The problem is that some time in the future will the people have forgotten what was
there and then retroactively we have to start this whole....mess all over again? I don't
think it's a very good idea. I think the material needs to be removed and destroyed
either and or both. And to beg the question simply on the basis of immediate costs
differing the total cost to some future generation is totally unfair....it's also not wise."
9. "Until and unless that contamination is completely removed, it serves as a source of
continued contamination. The barrier that you're putting up, no have no history to show
that the barrier will last more than 15 years. So I think it's essentially futile and
misleading. You say you're putting up a barrier but because this technology has only
been in use for a relatively limited period of time, you cannot say with any degree of
certainty that this thing will last more than 15 years. Since that is the case your remedy
is seriously flawed. Now, when you have an hundred years of history....and it worked,
then fine. But as of right now, I see an awful lot of technical problems. And you don't
have the answers. And if you pretend you have the answers, I think you're misleading '
the public."
Reply 3B:
1. The proposed plan document is not intended to contain every bit of information
gathered at a site, for it would be impossible to summarize all available site information
in a short, readable format. Rather, the proposed plan is a summary of the matters at
hand at the site, and it refers the reader to the information repositories, which contain
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all site-derived information, for further information on which to base their comment(s).
The chemical compounds discovered at the site are listed in many site documents,
including the Remedial Investigation (Rl) Report and the 1992 ROD. In addition, as
noted above (see Reply 2A, #5) the ACS Executive Committee tested the barrier wall
materials prior to installation in an effort to show that the barrier wall materials would
likely withstand attack by the chemical contaminants found beneath the site. However,
as the commenter pointed out in his written comments, very long term data is lacking.
Thus, the inward gradient and the removal of VOCs using SVE are an important part of
the site cleanup proposal.
2. U.S. EPA agrees that contamination of the lower aquifer would be a situation to
avoid. Thus, while the clay layer between the aquifers will likely impede the movement
of VOCs (the most mobile class of compounds) out of the upper aquifer for some period
of time, the Agency notes that the SVE system will be operated to remove a large
percentage of the VOCs, which will lessen the threat that they pose to the lower
aquifer.
3. U.S. EPA agrees that it would be expensive to clean up site-derived contamination
in the lower aquifer should it become necessary to do so. However, the proposed
ROD Amendment calls for using both treatment (SVE) and containment to protect
human health and the environment. The combination of the two is predicted to prevent
contamination of the lower aquifer by removing the mobile (VOCs) fraction of
contaminants from the ground.
4. The level of heavy metals at the site are not as high as the VOC levels and thus
have a lesser impact on the site cleanup action versus the VOCs. However, clay
layers tend to adsorb metals and prevent their movement through the clay, not unlike
many organic compounds, so that the heavy metals will be prevented from moving into
the lower aquifer during the implementation of the cleanup action.
5. As noted during the public meeting, the groundwater cleanup system uses an
ultraviolet (UV) light treatment system to remove organic compounds from the water by
destroying them. The UV system also uses hydrogen peroxide as an oxidation source
to prevent the production of dioxin.
6. As noted during the public meeting, the graphics that contained the most readable
information for all the audience to see, happened to be those produced in 1996. While
it is unfortunate that the graphics were not updated for the public meeting, the range of
the contaminant plume is well known and is monitored on a frequent basis. Also,
movement of the plume is very slow, so that the 1996 graphics essentially still give a
good idea as to where contaminants are today.
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7. Property rights belong to the current owner(s) and are impacted by zoning decisions
made at a Ibcal level. The Town has indicated to the ACS Executive Committee that it
will keep the property zoned industrial well into the future, thus U.S. EPA's assumption
that the property is an industrial parcel is valid. Should the ACS property be acquired
by another party (who then may acquire all the cleanup liability associated with it) and
that party wishes to use it in some other way, then the party will have to perform a
cleanup action appropriate for the desired use of the property.
8. U.S. EPA has placed a deed restriction on the ACS property to alert potential future
owners of the fact that a contaminant containment system is (to be) erected on the
property and needs to be maintained. A new owner may have to implement a different
cleanup process at the site should the future owner decide that it wants to use the
property in an inconsistent manner with the containment system.
9. U.S. EPA agrees that until the entire cleanup action is constructed and the
containment and treatment systems are operating, the site serves as a source of
continued contamination to the groundwater. However, once the remedy is in place,
the source will be contained and prevented from moving off site. (Although the barrier
wall may only have a "15 year" history, the cleanup remedy includes the removal of
groundwater from within the barrier wall enclosure, creating an inward gradient to help
prevent movement of chemicals off site. Also, the SVE system will be operated to
remove a large amount of VOCs from beneath the ground, both to help prevent
destruction of the barrier wall materials and prevent the movement of chemicals off site.
Lastly, groundwater monitoring will be performed to demonstrate that all systems are
working; if found not to be the case, then repairs will be made to restore them to the
required state.
Comment 4B: Howard Anderson, address unknown
"There is contamination going into the Town dump..." 'but it is not shown on the map
and you are not doing anything about it.'
Reply 4B.
With the installation of the barrier wall, the probability of site contaminants entering the
Town landfill (in sufficient quantity to differentiate them from landfill contaminants)
becomes very small. Inward groundwater gradients will also prevent the movement of
contaminants off site, whether into the landfill area or elsewhere.
The Agency notes that the graphics used at the public meeting were intended to give a
general view of the location of site contaminants. Prior to that meeting, information
was available to show that site contaminants are not a concern in the Town landfill
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area. (See alsorthe original 1992 ROD for a discussion of the landfill's impact on the
ACS site.)
Comment 5B: Arnold Stassin, address unknown
'I am concerned that you limited testing to a certain area, and not a half-mile or more or
the other side of Coifax Street and in other areas. There is a lot of cancer in a two
block area and it is uncertain as to whether site contamination caused the cancers.'
(Note: the area was not identified by the commenter.]
Reply 5B:
Sampling of area soil and groundwater has delineated the nature and extent of ACS
site contamination, which has been well documented. Data gathered to date show tha
sampling soil in areas a half-mile away will not show evidence of contaminants derived
from the ACS site because the contaminants have not moved off site that far, except fo
as documented in the upper aquifer contaminant plume moving off site in a
southeasterly direction.
The commenter is referred to U.S. EPA's sister agency, the Agency for Toxic
Substance and Disease Registry (ATSDR) for assistance in determining whether
exposure to site contamination contributed to the neighborhood health problems
alluded to in his comment. A local (Chicago) telephone number for ATSDR is (312)
886-7476.
Comment 6B: Bob Hanchar, address unknown
"At the....different time periods when those barrels were supposedly buried was it
legal?"
Reply 6B:
As discussed at the public meeting, the disposal of materials on site may be described
as being "inappropriate," given the facts today regarding environmental impacts of the"
dumped chemicals, but it was not necessarily illegal at the time the materials were
dumped. The legality of the disposal is not an issue with regards to remedy selection,
however.
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Comment 7B: Unidentified Speaker, address unknown
"I'd rather go in there and dig up everything....! would like to get it cleaned up as quick
as I could...." 'but where would you (directed to members of the audience) put it? In
your back yard? A lot of people do not want it in their yards.'
Reply 7B;
U.S. EPA agrees with the commenter that the materials at the ACS site should not be
dug up and disposed of off site (in someone else's "back yard"), but the agency
disagrees that the material should be dug up for processing and treatment "as quick as"
possible. As U.S. EPA presented at the public meeting and in the proposed plan for
ROD amendment, the results of the materials handling and treatability studies show
that it may be unsafe for cleanup workers to attempt to dig up the materials and then
process them before placing them into a treatment device. Also, low temperature
thermal treatment may not be appropriate for use on much of the material that would be
excavated. The proposed treatment (using SVE) and containment remedy is
appropriate for the ACS site, as it is protective of human health and the environment.
VOCs will be removed from the ground (without excavating the area) and destroyed,
while at the same time other materials are contained on site and prevented from moving
off site.
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