EPA Superfund
Record of Decision:
PB96-964103
EPA/ROD/R05-96/297
June 1996
Douglas Road/Uniroyal, Inc.
Landfill, Mishawaka, IN
5/3/1996
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Declaration for the Record of Decision
Douglas Road Landfill
Groundwater Operable Unit
Site Name and Location
Douglas Road Landfill
Mishawaka, Indiana
Statement of Basis and Purpose
This decision document presents the selected remedial action for the groundwater operable unit at
the Douglas Road Landfill Site (the Site) in Mishawaka, Indiana. This remedial action was
selected in accordance with CERCLA, as amended by SARA, and, to the extent practicable, the
National Contingency Plan. The selection of this remedy is based on the Administrative Record
for the Site.
The State of Indiana concurs with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to human health, welfare, or the environment.
Description of the Selected Remedy
This final action is the last of three planned for this Site. It specifically outlines an action to
address contaminated groundwater, which has been determined by the remedial investigation to
pose unacceptable risks to human health and the environment.
The major components of the selected remedy include:
Groundwater extraction using extraction wells or collection drains to contain groundwater
in the downgradient direction of the groundwater plume;
Groundwater treatment through construction of an artificial wetland;
Re-infiltration of a portion of the extracted groundwater that has undergone treatment in
the constructed wetland;
Discharge to Juday Creek of a portion of the treated groundwater, in compliance with
NPDES substantive and administrative requirements developed for the site by IDEM;
Groundwater and source area monitoring to ensure that the goals of this action are met
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and that downgradient water supplies are not adversely impacted by groundwater
contamination;
Long term operation and maintenance of the remedy to ensure protection of public health
and the environment;
Declaration
The selected remedy is protective of human health and the environment, complies with Federal
and State applicable or relevant and appropriate requirements for this final action, is cost
effective, and consistent with achieving a permanent remedy. This final action utilizes permanent
'solutions and alternative treatment technologies to the maximum extent practicable for this site.
Because this action will result in hazardous substances remaining on-site above health based
levels, a review will be conducted to ensure that the remedy continues to provide adequate
protection of human health and the environment within five years after commencement of this
remedial action.
Date y*~^ Valdas V. Adamkus
Regional. Administrator
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Decision Summary
Douglas Road Landfill
Mishawaka, Indiana
Site Name and Location
Douglas Road Landfill
Mishawaka, Indiana
The Douglas Road Landfill site (the Site) is located in St.
Joseph County just north of Mishawaka, Indiana. The site is
approximately 16 acres in size and is located near the northwest
corner of Douglas and Grape Roads. The Site.is bounded by the
right-of-way for the Indiana State Toll Ro
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in which Uniroyal agreed to perform a RI/FS at the site. Before
completion of this work, Uniroyal filed for bankruptcy and
discontinued work at the site (November 1991).
Following the bankruptcy, it was determined that U.S. EPA should
regain the site lead and the RI/FS was begun in early 1994, using
Superfund money. These investigations were completed in the fall
of 1994.
Highlights of Community Participation
Public participation .requirements under CERCLA Sections 113
(k) (2) (B) (I-v) and 117 were 3atisfied during the RI/FS process.
U.S. EPA has been primarily responsible for conducting the
community involvement program for this Site, with the assistance
of the Indiana Department of Environmental Management1 (IDEM).
The following public participation activities, to comply with
CERCLA, were conducted during the RI/FS.
A Community Involvement Plan was developed in 1994, to
assess the community's informational needs related to the Site
and to outline community involvement activities to meet these
needs. Residents and community officials were interviewed and
their concerns were incorporated into this plan.
'A public information repository*was established at the
Mishawaka-Penn public library, located at 209 Lincoln Way East,
Mishawaka, Indiana.
A mailing list of interested citizens, organizations, news
media, and elected officials in local, State and Federal
government was developed. Fact sheets and other information
regarding site activities were mailed periodically to all persons
or entities on this mailing list. This mailing list has been
updated on a continual basis as more individuals have become
aware of the contaminated residential well problem.
A fact sheet was mailed to the public in April, 1994, that
announced a public meeting to discuss the upcoming Remedial
Investigation and-answer site related questions-from the public.
A public meeting was held on April 20, 1994, at the Walt
Disney School in Mishawaka, Indiana, that announced the beginning
of the Remedial Investigation and provided details regarding its
conduct.
A fact sheet was mailed to the public in September 1994,
that announced an availability session to be held on September
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28, 1994, to discuss sampling results from the Remedial
Investigation.
An availability session was held on September 28, 1994 at
the Walt Disney School to discuss RI progress and answer
questions from the public regarding residential well
contamination discovered during the RI sampling.
A fact sheet was mailed to the public in March 1995 that
announced an availability session to be held on March 8, 1995, to
discuss the solution to the residential well contamination
problem.
An availability session was held on March 8, 1995, at the
Walt Disney School, to discuss the solution to the residential
well contamination problem.
- A fact sheet was mailed to the public in April 1995 that
summarized EPA's recommended alternative for the landfill capping
portion of the cleanup in a proposed plan for the site. The EPA
approved feasibility study fox the landfill cap was also released
at that time. This fact sheet announced a p'ublic comment period-
for the proposed remedial action and was accompanied by newspaper
advertisements in local newspapers.
A public meeting was held on Apfil 5, 1995, at the Walt
Disney School, to present EPA's proposed plan for the landfill
capping phase of the site cleanup and to receive formal public
comment.
An availability session was held on September 13, 1995 at
the Walt Disney School to assist homeowners in the completion of
the paperwork necessary to receive hookup to the city waterline
extension.
A fact sheet was mailed to the public in November 1995 that
summarized EPA's recommended alternative for the groundwater
portion of the cleanup in a proposed plan for the Site. The EPA
approved feasibility study for the groundwater portion of the
cleanup was also released at that time. This fact sheet
announced a public comment period for the proposed remedial
action and was accompanied by newspaper advertisements in local
newspapers.
A request for an extension to the public comment period was
received during the public comment period. The comment period
was extended for an additional thirty days to January 25, 1996,
making the comment period a total of sixty days.
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A Responsiveness Summary addressing comments and questions
received during the public comment period on the RI/FS and the
proposed plan is included with this Record of Decision as
Appendix A.
This Record of Decision presents the selected remedial action for
the groundwater phase of the cleanup at the Douglas Road Landfill
Site in Mishawaka, Indiana, chosen in accordance with CERCLA, as
amended by SARA, and the National Contingency Plan. The decision
for this Record of Decision at the Site is based on the
Administrative Record.
Scope and Role of the Selected Remedy
As with many Superfund sites, the problems at the Douglas Road
Landfill Site are complex. An RI/FS was performed including
activities to determine the nature and extent of contamination at
the Site and evaluating the feasibility of various remedial
alternatives to clean up the Site. The RI/FS determined that
soil and waste materials at the site and groundwater in the site
area had become contaminated because of past disposal activities.
at the Site.
This Record of Decision (ROD) addresses the second operable unit,
contaminated groundwater, at the Site. This was determined to
pose' risks to human health and the environment due to inhalation
and ingestion of area .groundwater.
This is the final of three planned response actions at the Site.
Previous actions at the Site include the selection of a multi
layer landfill cap (operable unit 1) to remediate contaminated
surface soils and waste materials at the Site and the
installation of a city waterline extension to residential
properties affected by site contamination (performed as a time
critical emergency removal action). This final action will be
designed to be consistent with any and all previous cleanup
actions at the Site.
Site Characteristics
The RI/FS was conducted to identify the types, quantities, and
locations of contaminants at the site and to develop alternatives
that best address these contamination problems. The nature and
extent of actual or potential contamination related to the site
was determined by a series of field investigations, including:
development of detailed information regarding
historical site operations;
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on-site surface soil sampling;
performance of a geoprobe survey to aid in the
optimal placement of groundwater monitoring wells,
by collection and field screening of selected
groundwater samples;
installation and sampling of groundwater
monitoring wells, both on and off-site;
identification and sampling of existing
residential wells in the site area;
preparation of a site-wide human health and
ecological risk assessment;
contaminant fate and transport modeling and
analysis;
Site Geology
The Site is underlain by unconsolidated glacial deposits ranging
from 30 to 200 feet thick. The glacial deposits consist of sand
and gravel outwash, inter-bedded with clayey tills formed by the
Saginaw Lobe of the Wisconsinan glacial event. In the Site area,
an intermediate deposit of clay till "separates the sand and
gravel outwash into upper -and lower units. This clay unit has an
irregularly sloping scoured surface, dipping northwest, with a
bottom elevation ranging from 600 feet msl near the Michigan
state line'to 675 feet msl near Mishawaka, Indiana.
A basal clay till unit is also observed throughout the area,
directly overlying the bedrock. Soils on the landfill surface
consist of a well drained sandy loam material, intermixed with
areas of gravel/ fly ash, coal and sand.
Site Hydrogeology
Within the St. Joseph River Basin, the sand and gravel outwash
deposits described above form the St. Joseph aquifer system.
Recharge to the aquifer is generally from direct precipitation
and losses from surface water bodies. The intermediate clay till
deposit separates the aquifer system into upper and lower zones.
South Bend and Mishawaka, Indiana, are the primary users of
groundwater in the county, with a combined average of 34 million
gallons per day (mgd). Private water supplies rely exclusively
on the aquifer, with an estimated use of 3.7 mgd. Other uses,
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such as industrial and agricultural, total about 2 mgd.
Groundwater at the Site was detected between 15 and 20 feet below
ground surface with the intermediate clay till separating the
aquifer into upper and lower zones across much of the site.
Groundwater use in the Site vicinity is private residential, with
the exception of a nearby nursery, which uses groundwater for
irrigation.
Soil Contamination
Surficial soil samples collected at the Site were found to be
contaminated with volatile organics up to levels of 20,000 parts
per bill-ion (ppb) , semi-volatiles up to levels of 160,000 ppb,
PCBs up to levels of 16,000 ppb, dioxin up to levels of 1.3 ppb,
pesticides up to levels of 68 ppb, and metals up to levels of
1920 ppb. Risks associated with exposure to these contaminants
were addressed in the selection of a remedial alternative for
landfill capping, which is outlined in a July, 1995 ROD, that
calls for the installation of a multi-layer cap at the site.
Groundwater Contamination
Groundwater samples collected at various locations during the RI
at the Site were found to be contaminated with volatile organics
up to levels of 15,000 ppb, semi-volatile organics up to levels
of 29 ppb, and metals up to levels of 15 ppb. Groundwater
samples collected from residential wells were found to be
contaminated with volatile organics up to levels of 110 ppb.
Summary of Human Health Risks
This Record of Decision is written for an operable unit action to
address -the contaminated groundwater at the Site. The RI report
contains a Risk Assessment, prepared by CH2M Hill using the Risk
Assessment Guidance for Superfund and approved by EPA as a
portion of the RI report, that calculated the actual or potential
risks to human health and the .environment that may result from
exposure to Site contamination.
Risks associated with exposure to contaminated groundwater at the
site are as high as 3.8 x 10"3. The principal carcinogenic
contributors to this risk are bis(2 ethyl hexyl) phthalate,
arsenic, dibenzo(a,h) anthracene, vinyl chloride and indeno
(l,2,3-c,d) pyrene. Risks associated with exposure to
contaminated groundwater off-site are as high as 3.2 x 10"4. The
principal carcinogenic contributors to this risk are vinyl
chloride, arsenic and TCE.
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Actual or threatened releases of hazardous substances from this
site not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health or the environment.
Toxicity Assessment
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)(-1)
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day/ to provide an upper bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal to human extrapolation and uncertainty factors have been
applied (e.g. to account for the use of animal data to predict
effects on humans).
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g. the
amount of a-chemical ingested from contaminated drinking water)
can be compared to the RfD. RfDs are derived from human
epidemiological.studies or animal studies to which uncertainty
factors have been applied (e.g. to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The following hazardous substances were -found to be of principal
concern at the site.
Arsenic Short term exposures to arsenic or arsenic compounds may
cause effects in the gastrointestinal tract, heart, vascular
system, blood, nervous system*, eye, nose and skin. Arsenic
compounds are reported to act as skin allergens in humans.
Exposure to arsenic has also been reported to cause depression of
the bone marrow and disturbances in the blood cell and tissue
forming system and has been associated with kidney and liver
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disorders. Arsenic has been found 'to be a lung carcinogen when
inhaled and to cause skin cancer when ingested. Arsenic and its
compounds may have potential reproductive and developmental
effects in humans. Teratogenic effects have been demonstrated in
animal species exposed to arsenic via oral administration or
intraperitoneal injection. Damage to genetic material has been
reported in humans. ,
Vinyl Chloride Acute occupational exposure to high
concentrations of vinyl chloride can produce symptoms of narcosis
j_n humans. Respiratory tract irritation, bronchitis, headache,
and memory disturbances may also occur. At high doses,
excitement, contractions, convulsions,, and an increase in
respiration followed by respiratory failure precede death. Vinyl
chloride is a known human carcinogen causing liver angiosarcomas
and possibly increasing incidence of tumors of the brain and
lung.
Trichloroethylene (TCE) Exposure to TCE can cause depression of
the central nervous system, including dizziness, headaches,
uncoordination similar to that induced by alcohol, nausea,
vomiting, and unconsciousness. Long'term inhalation exposure can
affect liver and kidneys in animals. In humans, changes in liver
enzymes have been associated with TCE exposure. Exposure of mice
(orally and by inhalation) have produced increases in liver or
lung or kidney tumors.
Bis(2-ethyl hexyl) phthalate Exposure to bis(2-ethyl hexyl
phthalate can cause retarded growth and there is evidence that
teratogenic and fetotoxic effects on animals can occur under
chronic conditions. Reproductive effects, decreased fertility
and testicular damage have been noted in rodents. Classified by
EPA as a B2 carcinogen.
Dibenzo(a,h) anthracene There is sufficient evidence that
dibenzo(a,h) anthracene is carcinogenic to laboratory animals.
In lab experiments, oral doses have caused tumors in mice, lung
tumors in rats by intratracheal distillation and skin cancer
following dermal application. Higher doses in lab animals have
produced fetal deaths.
Indeno (l,2,3-c,d) pyrene PAHs are absorbed through the skin
gastrointestinally. There is very limited information on human
toxicity for PAH. No information is available concerning the
possible teratogenicity of PAH in humans. From numerous
epidemiological studies, of humans (primarily occupational
exposure), a clear association has been found between exposure to
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PAH containing materials and increased cancer risk. Indeno
(l,2,3-c,d) pyrene has been classified as a B2 carcinogen.
Risk Assessment
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g. 1 x 10~6 or 1E-6). An excess lifetime cancer risk of 1 x
1CT6 indicates that, as a plausible upper bound, an individual
has a one in one million chance of developing cancer as- a result
of site related exposure to a carcinogen over a 70 year lifetime
under the specific exposure conditions at site, in addition to
the chances of developing cancer in everyday life.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ)(or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
Carcinogenic risks described in the risk assessment for exposure
to contaminated groundwater at the Site were computed for several
potential- exposure scenarios, including residential child,
residential adult, teenage trespasser, and occupational adult
exposures. The combined pathways carcinogenic risk for all
groundwater exposure at the site exceeds 1 x 1CT6 for all
receptor groups, ranging from 1.3 x 1CT3 for residential children
to 3.8 x 10"3 for residential adults. The principal carcinogenic
risk contributors are bis (2 ethyl hexyl) phthalate, arsenic,
dibenzo(a,h) anthracene, vinyl chloride, trichloroethylene, and
indeno (l,2,3-c,d) pyrene (See Table 1) .
The non-carcinogenic risks associated with future exposure to
contaminated groundwater at the site were computed for the same
exposure scenarios as were used for the carcinogenic risks.
Generally, total Hazard Indices (HI) are used to calculate non
carcinogenic risks and must be below a value of 1.0; otherwise
U.S. EPA policy requires remedial action. The assessment of
future non-carcinogenic risks shows a combined ingestion, dermal,
and inhalation hazard index ranging from 2.06 for occupational
adults to 11.72 for residential children. The most significant
non-carcinogenic risk contributor is manganese for all receptor
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groups (See Table 1) .
Summary of Environmental Risks
An ecological risk assessment determined whether the contaminants
present at the site can pose a potential threat to ecological
receptors in the absence of any remedial actions.
The results of this assessment, as summarized in the risk
assessment portion of the RI, determined that, due to exposure to
site contaminants, ecological damage from groundwater
contamination is likely in the absence of any remedial actions.
Description of Alternatives
A Feasibility Study (FS) was completed for this Site to evaluate
potential remedial actions for addressing the groundwater
contamination problem. During the FS, a list of alternatives was
developed that could be used.to address the threats and/or
potential threats identified for the groundwater at the Site.
The list of alternatives was screened based on criteria for
effectiveness (i.e. protection of human health and the
environment, reliability), implementability (i.e. technical
feasibility, compliance with applicable Federal and State
regulations) and relative costs (i.e, capital and operation and
maintenance).
Following this initial screening, the list of alternatives was
further evaluated and only alternatives that met the nine
criteria, listed below in the comparative analysis section, were
submitted for detailed analysis. The Quickflow groundwater model
was used to estimate extraction rates necessary to contain the
contaminated groundwater plume.
All of the alternatives include groundwater monitoring, both at
the site and downgradient of the site, which will be designed to
monitor area groundwater to assess the effectiveness of the
alternatives.
Alternative 1 No Action
Under this alternative, no active remediation would occur and the
site would remain in its present condition. This alternative
will not reduce any potential public health or environmental
risks currently associated with the site. The inclusion of the
no action alternative is required by law to give U.S. EPA a basis
for comparison.
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Present Worth Cost: $949,000
Time to Implement: 2-3 weeks
Alternative 2 Institutional Controls
Under this alternative, a restrictive covenant would be placed on
the property deeds of the areas currently affected by the
groundwater contamination problem that would prevent future
groundwater use until the groundwater meets regulatory standards.
This will be determined by.periodic groundwater monitoring. The
restrictive covenants would be in effect for more than 30 years,
perhaps even permanently. Groundwater contamination would be
allowed to attenuate naturally.
Present Worth Cost: $1,552,000
Time to Implement: 2-3 months
Alternative 3 Oxygen Enhancement with Air Sparging for Onsite
Plume
Under this alternative, air would be injected below the water
table using a series of sparging wells or horizontal perforated
pipes to increase groundwater oxygen concentrations to promote
contaminant degradation and immobilization. Air sparging would
not be used for the off-site plume because the depth of
contamination is too deep for this technology to work effectively
with appropriate control over the organics sparged from the
groundwater. Remediation of the off-site plume will need to be
accomplished by one of the other remaining alternatives.
Present Worth Cost: $4,200,000
Time to Construct: . 2 months
Alternative 4 Groundwater Extraction and Discharge to Mishawaka
POTW
Under this alternative, groundwater would be extracted via
extraction- wells or collection drains and sent directly to the
Mishawaka Publicly Owned Treatment Works (POTW) for treatment.
No pretreatment of the groundwater prior to discharge to the POTW
is anticipated due to the low contaminant -concentrations in
samples collected during the RI.
Present Worth Cost: $13,300,000
Time to Construct: 3 months
Alternative 5 Groundwater Extraction, Air Stripping Treatment
and Discharge to Juday Creek
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Under this alternative, groundwater would be extracted via
extraction wells or collection drains from both the on-site and
off-site contaminated groundwater plume. Extracted groundwater
would be treated via air stripping. Treated groundwater would
meet NPDES substantive and administrative requirements and be
discharged to Juday Creek. Air monitoring of the air stripper
emissions will be performed to protect public health and the
environment.
Present Worth Cost: $6,000,000
Time to Construct: 3-4 months
Alternative 6 Groundwater Extraction, Constructed Wetland
Treatment and Discharge to Juday Creek
Under this alternative, groundwater would be extracted via
extraction wells or collection drains from both the on-site and
'off-site plume. Extracted groundwater would be treated in a
constructed wetland. Treated groundwater would meet NPDES
substantive and administrative requirements and be discharged to
Juday Creek. Air monitoring-of the wetland;emissions will be
performed to protect public health and the environment.
Present Worth Cost: $6,100,000
Time to Construct: 31-4 months
Alternative 7 Groundwater Extraction, Fluidized Carbon Bed
Treatment, and Discharge to Juday Creek for On-Site Plume
Under this alternative, groundwater would be extracted via
extraction wells or collection drains from the on-site plume.
Extracted groundwater would be treated via fluidized carbon bed
treatment, which use biological and physical treatment processes
to treat the contaminants. Treated groundwater would meet NPDES
substantive and administrative requirements and be discharged to
Juday Creek. This alternative will not be used for the off-site
plume because it is not as effective at treating some of the
higher levels of organic contaminants detected in the off-site
groundwater to the appropriate cleanup levels as the other
alternatives. Remediation of the off-site plume will need to be
accomplished by one of the remaining alternatives.
Present Worth Cost: $4,900,000
Time to Construct: 2-3 months
Summary of the Comparative Analysis of Alternatives
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The nine criteria used by U.S. EPA to evaluate remedial
alternatives, as set forth in the NCP, 40 CFR Part 300.430,
include: overall protection of human health and the environment;
compliance with applicable or relevant and appropriate
requirements (ARARs); long-term effectiveness; reduction of
toxicity, mobility or volume through treatment; short-term
effectiveness; implementability; cost; State acceptance; and
community acceptance.
THRESHOLD CRITERIA
Protection of Human Health and the Environment
Addresses whether a remedy provides adequate protection of human
health and the environment and describes how risks posed through
each exposure pathway are eliminated, reduced, or. controlled
through treatment, engineering controls, or institutional
controls.
Alternative 1 would not protect human health and the environment
because it does not reduce risks associated with exposure to
contaminated media at the site. Therefore, since it has been
determined that Alternative 1 would not be protective of human
health and the environment or meet ARARs, it will no longer be
considered in the nine criteria evaluation.
All of the other alternatives would reduce the threats to human
health and the environment to varying degrees. Alternatives 3,
4, 5, 6, and 7 are superior to Alternative 2 due to their ability
to reduce the contaminant concentrations. Alternatives 4, 5, and
6 are superior to Alternatives 3 and 7 because of their ability
to remediate the entire plume, rather than portions of the plume.
Therefore, Alternatives 4, 5 and 6 are functionally equivalent
with respect to this threshold criterion and are superior to
Alternatives 2, 3, and 7 due to increased protection from site
contaminants and more complete remediation of the groundwater
plume.
Compliance with ARARs
Addresses whether a remedy will meet all of the ARARs of other
Federal and State environmental laws and/or justifies a waiver of
those laws
All of the remaining alternatives are capable of meeting their
respective ARARs (See Table 2). Alternative 2 may meet Federal
and State ARARs regarding groundwater quality after an extended
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Table 3-2
Potential Federal ARARs for the DHL
Groundwater Operable Unit
Law, Regulation, or Standard
Executive Orders 1 1988 and 1 1990
40CFR6,SubpaitA
Endangered Species Act
SOCFR402
Description
Requires federal agencies to avoid whenever possible,
adversely affecting flood plains or wetlands and to evaluate
potential effects of actions in these designated areas.
Requires remedial agency to consult with Fish and Wildlife
Service if action may affect endangered species or critical
habitat.
Comment
Applicable to Juday Creek and associated wetlands
Applicable if Fish and Wildlife Service deems area a
critical habitat. Juday Creek is not known to be a critical
habitat.
Clean Air Act
Section 101
Calls for development and implementation of regional air
pollution control programs
Section 101 of the Clean Air Act delegates primary
responsibility for regional air quality management to the
states. The rules for implementation of regional air quality
plans are contained in 40 CFR 52. Regulations
promulgated under the Clean Air Act may apply to
possible actions at the site that generate air emissions, but
are most applicable to stationary sources such as air
strippers.
Federal Water Pollution Control Act as amended by the Clean Water Att of 1977
Section 208(b)
Section 304
The proposed action must be consistent with regional water
quality management plans as developed under Section 208
of Clean Water Act.
Establishes water quality criteria for specific pollutants for
the protection of human health and for the protection of
aquatic life. These federal water quality criteria are non-
enforceable guidelines used by the state to set >vatcr quality
standards for surface water.
Substantive requirements adopted by the state pursuant to
Section 208 of the Clean Water Act would be applicable to
direct discharge of treatment system effluent or other
discharges to surface water.
Water quality criteria may be relevant and appropriate to
groundwater or treatment system effluent or other
discharges to surface water.
MKEIOOISB6EDOC
Page 1 Of 5
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Af
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Table 3-2
Potential Federal ARARs for the DRL
Groundwater Operable Unit
Law, Regulation, or Standard
Description
Comment
U.S. EPA Regulations on Approval and Promulgation of Implementation Plans
40CFR52 1^
Clean Air Act
40 CFR 50 and 52
Requires the filing of a notice with the state regarding intent
to install a new stationary source of air pollution.
program. Establishes Ambient Air Quality Standards.
40 CFR 52 concerns the installation of stationary sources
of air emissions, including air strippers. Provisions
enforceable by the state follow the federal Prevention of
Significant Deterioration (PSD) program with
modifications to conform with regional and local ambient
air quality standards. A CERCLA response action is not
required to obtain permits under the PSD program, but
must comply with the substantive requirements of a PSD
review.
Applicable to discharges of toxic substances to the
atmosphere during waste handling or treatment.
U. S. EPA National Pollutant Discharge Elimination System (NPDES) Permit Regulations
40 CFR 122.44
Federally approved state water quality standards. These
may be in addition to or more stringent than federal water
quality standards under the CWA.
All substantive requirements under the cited sections of 40
CFR 122 would be applicable to the direct discharge of
effluent to an onsite or offsite surface water body.
Administrative requirements, such as permitting and
reporting procedures, would be applicable only for effluent
discharged to an offsite location (such as a discharge into a
stream flowing offsite). Therefore, at the DRL site these
requirements would be applicable to proposed discharges
to Juday Creek.
MKE100I5B6E.DOC
Page 2 Of S
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Table 3-2
Potential Federal ARARs for the DRL
Ground water Operable Unit
Law, Regulation, or Standard
40CFRI22.44(a)
40CFR122.44(e)
40 CFR I22.4l(i)
40 CFR 122.21
Description
Requires the use of the Best Available Technology (BAT)
for toxic and nonconventional wastewaters or the Best
Conventional Technology (BCT) for conventional
pollutants. The nature of the wastewater and the
technology-based limitations will be determined by the state
on a case-by-case basis.
Discharge limits must be established for toxics to be
discharged at concentrations exceeding levels achievable by
the technology-based (BAT/BCT) standards. The
limitations would be evaluated on a case-by-case basis
depending on the proposed treatment system and the
receiving water.
Requires monitoring of discharges to ensure compliance.
Monitoring programs shall include data on the mass,
volume, and frequency of all discharge events.
Permit application must include a detailed description of the
proposed action, including a listing* of all required
environmental permits.
Comment
Administrative requirement applicable only for discharges
to offsite surface water (Juday Creek).
Administrative requirement applicable only for discharges
to offsite surface water (Juday Creek).
U.S. EPA Regulations on Criteria for the NPDES
40 CFR 125 100
The site operator shall develop a best management practice
(BMP) program and shall incorporate it into the operations
plan or the NPDES permit application if required.
Substantive requirements of 40 CFR 125 would be
applicable to the direct discharge to treatment system ^
effluent to an onsite or offsite surface water body. The
permitting requirements would be applicable only if the
effluent is discharge to Juday Creek.
MKE10015B6E.DOC
Page 3 of 5
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Table 3-2
Potential Federal ARARs for the DRL
Groundwater Operable Unit
Law, Regulation, or Standard
Description
Comment
U.S. EPA Procedures for Approving State Water Quality Standards
40CFRI31
States are granted enforcement jurisdiction over direct
discharges and may adopt reasonable standards to protect or
enhance the uses and qualities of surface water bodies in the
state.
Applicable to direct discharge of treatment system effluent
or other process waters. Such a discharge into Juday
Creek would activate the administrative requirements of
this rule because it would affect offsite surface waters.
U.S. EPA Regulations on Test Procedures for the Analysis of [Water] Pollutants
40 CFR 136.1-136.4
These sections require adherence to sample preservation
procedures including container materials and sample
holding times.
Applicable to direct discharge of treatment system
effluent.
Safe Water Drinking Act
40CFR14I
Establishes maximum contaminant levels (MCLs) and
maximum contaminant level goals (MCLGs) for specific
chemicals to protect drinking water quality.
»
MCLs and nonzero MCLGs may be applicable or relevant
and appropriate as groundwater contaminant concentration
goals depending on whether the water in question is to be
used for drinking water supply. MCLs are applicable if
the water is or will be used for drinking. MCLs are
relevant and appropriate if the water could be used for
drinking. MCLGs set above zero levels are relevant and
appropriate for current or potential sources of drinking
water.
Resource Conservation and Recovery Act (RCRA)
Subtitle D, 40 CFR 257
Sets standards for land disposal facilities for nonhazardous
waste.
Applicable to groundwater treatment residuals and to
transport and disposal of any nonhazardous waste offsite.
MKE1001SB6E.DOC
Page 4 Of 5
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Table 3-2
Potential Federal ARARs for the DHL
Groundwater Operable Unit
Law, Regulation, or Standard
Subtitle C, 40 CFR 260 through 264
40 CFR 262 and 263,
49 CFR 100 through 199
Description
Regulates the generation, transport, storage, treatment, and
disposal of hazardous wastes generated in the course of a
remedial action. Regulates the construction, design,
monitoring, operation, and closure of hazardous waste
FfttaftilithfHi n*«nmifiiliilitifift for transporters of hazardous
waste in handling, transportation, and management of the
waste. Sets requirements for manifesting, recordkeeping,
and emergency response action in case of a spill
Comment
Requirements under these regulations may be relevant and
appropriate to storage of certain non-hazardous wastes or
treatment system residuals if the risk they present are
similar to those associated with hazardous wastes. The
criteria and limitations used to identify wastes as being
hazardous or nonhazardous are applicable to groundwater
treatment residuab.
Applicability depends on waste classification of
groundwater treatment residuals.
U.S, EPA Pretreatment Standards
40 CFR 403
Establishes pretreatment standards for controlling pollutants
discharged to a publicly-owned treatment works (POTW).
Applicable to groundwater or treatment system effluent
that is conveyed to a local POTW.
MKE100ISB6E.DOC
Page 5 Of 5
a
fV
M
j*
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14
period of time. Alternative 3 may meet Federal and State ARARs
regarding groundwater quality for the on-site plume only.
Alternative 7 would meet Federal and State ARARs for the on-site
plume and would meet NPDES requirements. Alternatives 4, 5, and
6 would comply with all Federal and State ARARs for groundwater
quality.
Therefore, Alternatives 4, 5, and 6 are functionally equivalent
with respect to this threshold criterion and are superior to
Alternatives 2, 3, and 7, due to their addressing the entire
contamination plume.
PRIMARY BALANCING CRITERIA
Long Term Effectiveness
Addresses any expected residual risk and the ability of a remedy
to maintain reliable protection of human health and the
environment over time, once cleanup standards have been met.
Alternative 2 has the greatest long term risk for exposure to
contaminated groundwater for those residences not hooked up to
the water line extension. Alternatives 3 and 7 do not provide
for .complete remediation of the groilndwater plume, therefore,
their effectiveness in thet long term is low. Alternatives 4, 5,
and 6 provide similar levels of permanence with respect to
groundwater containment. However, Alternatives 4 and 6 provide
for greater removal of the organic contamination present (are
more effective at treating the high levels of tetrahydrofuran and
methyl ethyl ketone, several major components of the plume) in
the groundwater plume than Alternative 5.
Therefore, Alternatives 4 and 6 are functionally equivalent with
respect to this balancing criterion, are slightly more effective
in the long term than Alternative 5, and are superior to
Alternatives 2, 3, and 7.
All of the. alternatives require long term operation and
maintenance to ensure complete groundwater containment and to
maximize the contaminant treatment efficiency.
Reduction of Toxicity, Mobility or Volume (TMV) through Treatment
Addresses the anticipated performance of the treatment
technologies a remedy may employ.
All of the treatment alternatives will reduce the toxicity of
groundwater contamination to varying degrees. Alternative 2 will
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15
not reduce TMV through treatment. Alternatives 3 and 7 will not
treat the entire groundwater plume therefore, they do not fully
satisfy this criterion.
Alternatives 4, 5 and 6 will reduce TMV through treatment.
Alternatives 4 and 6 will more completely remove the organic
contamination than Alternative 5, as described previously.
Therefore, Alternatives 4 and 6 have been determined to be
functionally equivalent with respect to this balancing criterion
are slightly better than Alternative 5, and are superior to
Alternatives 2, 3, and 7.
Short Term Effectiveness
Addresses the period of time needed to achieve protection and any
negative effects on human health and the environment that may be
posed during the construction and implementation period, until
cleanup standards are achieved.
All of the remaining alternatives include site fencing to
restrict site access to effectively prevent or reduce risks to
potential trespassers. None of the alternatives create
significant risks to the community while they are constructed.
Alternative 2 prevents exposure to contaminated groundwater and
is primarily an administrative action. No environmental impacts
from construction activity are expected for Alternatives 3 and 4.
No significant additional risk to the community is anticipated
from Alternative 5fs air stripper emissions due to low
contaminant concentrations in air stripper emissions. No.
environmental impacts are expected from construction activities
or the discharge of treated groundwater to Juday Creek.
Alternative 6 would result in the creation of a valuable wetland
habitat for wildlife.
Alternative 6 would also result in less of an impact to the local
community through its construction and operation, resulting in
less noise and greater aesthetic impacts on the surrounding areas
than the other alternatives. Also, the construction of this
alternative, when combined with the multi-layer landfill cap
already proposed for the site, will result in much lower amounts
of truck traffic along Douglas Road, which will again benefit the
local community and lower the impacts of its construction on the
surrounding area.
Therefore, it has been determined that all of the alternatives
are functionally equivalent with respect to this balancing
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16
criterion, however, Alternative 6 is slightly better because of
the tangible environmental and community benefits resulting from
the creation of a wetland.
Implementability
Addresses the technical and administrative feasibility of a
remedy including the availability of materials and services
needed for a particular option to be put in place.
Alternative 2 may be difficult to implement because of individual
negotiations with landowners and unfavorable public opinion
regarding deed restrictions. Alternative, 4 requires a permit
from the Mishawaka POTW, which may involve delays in obtaining
the necessary approvals. Alternatives 5-7 require discharge
authorization from IDEM in order to meet the substantive
requirements of a NPDES permit. Potential delays may occur in
obtaining the necessary approvals. Alternative 6 will also
require the acquisition of land to construct the wetland, which
may Involve delays due to negotiations with landowners. Services
and materials are available for all alternatives. Alternatives 3
and 7 would need to be combined with another action to completely
address the contaminated groundwater plume.
Therefore, it has been determined that Alternatives 2, 4, 5, and
6 are functionally equivalent with respect to this balancing
criterion and are superior to Alternatives 3 and 7.
Cost
Included are capital costs, annual operation and maintenance
costs
The FS presented -net present worth cost estimates for each of the
seven alternatives brought forward for detailed analysis. These
estimates were derived from literature, vendor quotations, actual
costs from similar projects, and standard cost information
sources. Cost estimates are provided primarily for the purpose
of conducting a comparative assessment between remedial options,
in order to assess the economic feasibility of the different
alternatives.
Where limited or insufficient information was available regarding
site-specific hydrogeological characteristics or contaminant
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17
specific treatability efficiencies, assumptions were made based
on literature and professional judgment where necessary to
develop costs associated with different processes. The cost
estimates provided in the FS are expected to provide an accuracy
of +50/-30 percent (See Table 3).
Therefore, based onfan analysis of the costs associated with all
of the alternatives analyzed in the FS, Alternative 2 is the
least expensive of all of the alternatives and Alternative 4 is
the most expensive. Alternatives 3, -4, 5,6, and 7 have costs
which are moderate and range from approximately four to six
million dollars.
MODIFYING CRITERIA
State Acceptance
Addresses whether or not the State Agency agrees to or objects to
any of the remedial alternatives, and considers State ARARs.
The Indiana Department of Environmental Management (IDEM) has
been intimately involved with the Site throughout the RI/FS, has
attended all.technical progress meetings, has been provided
opportunity to comment on all technical decisions, and concurs
with the selection of Alternative 6 "as the selected remedy for
the Site.
Community Acceptance
Addresses the public's general response to the remedial
alternatives and proposed plan.
Throughout the RI/FS at the Site, community involvement has
increased significantly as the extent of the contamination
problem in area residential wells was identified. U.S. EPA has
been accessible and responsive to community concerns throughout
the study. This has been accomplished by a community relations
program consisting of periodic fact sheets highlighting site
progress and availability sessions with the community to
communicate site information and to answer questions regarding
site progress.
At the public meeting and subsequent meetings, the majority of
those in attendance, as well as the majority of those who
submitted formal written comments regarding the proposed plan,
did not support the proposed Alternative 6 as the most
appropriate choice for this action. However, the main objections
to this selection were for the proposed Juday Creek discharge,
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Alternative
1
2
3A
3B
4A
4B
5A
5B
6A
6B
7A
7B
Alternative 3 C
A I*«MM*S«IM ^ f\
Alternatives 4-
Ahernatives 4-
Onsite
Onsite
Onsite
Offiite
Onsite
Offiite
Onsite
Offiite
Onsite
Offiite
Onsite
Offiite
Onsite
Offiite
Onsite
Onsite
Capital Cost
$117,000
$720,000
$1011,000
$1,954,000
$818,000
$1048,000
$1,811,000
$2311,000
$1,045,000
$895,000
$2,034,000
$2,134,000
$1,113,000
$1,513,000
$2303,000
$2,503,000
$2,028,000
$2,721,000
Table 6-2"
Relative Cost
Aaaoal Operation aad
Maiatenaoee
$49,000
$49,000
$150,000
$150,000
$325,000
$325,000
$308,000
$353,000
$79,000
$86,000
$115,000
$115,000
$86,000
$86,000
$81,000
$81,000
$153,000
$140,000
Total PreseatWortk
«g 4% dfecowrt rate mcr 39 yon
$949,000
$1,552,000
$3,849,000
$4,591,000
$6,600,000
$7,030,000
$6033,000
$6,834,000
$2,494,000
$2094,000
$3,530,000
$3,630,000
$2000,000
$2,695,000
$3,654,000
$3,854,000
$4,600000
$5037,000
IptiooA: Air Sparging Wells
tptionB: Air Sparging Perforated Pipe
7 Option A: Extraction Weils
7 Option B: Collection Trendies
MKE10016257.XLW
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18
not for the proposed constructed wetlands treatment, component.
U.S. EPA has made several modifications to the proposed remedy in
response to these comments, as outlined in the Section of this
ROD entitled Explanation of Significant Differences. Specific
comments on the proposed cleanup plan are addressed in Appendix
A, the Responsiveness Summary.
Comparative Analysis of the Alternatives
In summation, Alternative 1 is unacceptable for protection of
human health and the environment. Alternative 2 does not
completely satisfy the criterion of protection of human health
and the environment because it does not remediate the groundwater
plume, nor does it prevent its migration from the site.
Alternatives 3 and 7 are not fully protective of human health and
the environment because they do not remediate the entire
groundwater plume and would have to be combined with another
alternative to completely address the groundwater contamination
problem.
Alternatives 4, 5 and 6 fully satisfy the nine evaluation
criterion. Alternatives 4 and 6 are slightly more effective in
the long term and at reducing the toxicity, mobility and volume*
of contaminants through treatment than Alternative 5 because they
remove more of the organic contamination*present (principally
tetrahydrofuran-due to the high levels detected at the site, and
methyl ethyl ketone) in the groundwater plume. Alternatives 4, 5
and 6 are similar at protecting the community and on-site workers
during the remedy construction, however, because Alternative 6
provides the tangible environmental benefit of construction of a
wetland habitat, those environmental benefits make Alternative 6
slightly better with respect to short term effectiveness.
Alternatives 4, 5 and 6 are equivalent with respect to
implementability. Finally, Alternative 6, while providing
similar levels of effectiveness, is more cost effective than
Alternative 4.
Therefore, : the best balance among the seven'alternatives, while
providing for protection of human health and the environment and
attainment of Federal and State requirements and long term
effectiveness and permanence, is Alternative 6, Groundwater
Extraction, Constructed Wetland Treatment, and Discharge to Juday
Creek.
Selected Remedy
U.S. EPA has selected Alternative 6 - Groundwater Extraction,
Constructed Wetlands Treatment, and Discharge to Juday Creek, as
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- . 19
the appropriate groundwater cleanup remedy at the Douglas Road
Site. This alternative was selected because it is the most
appropriate alternative for this final action and is compatible
with the operable unit remedy selected for the landfill cap,
because the soil excavated for the wetland construction can be
used for cover material for the landfill cap, saving the expense
and disturbance to the community from bringing the material to
the site from an off-site location, and the time required to
import this material to the Site.
The objective of this final action is to remediate contaminated
groundwater, both on-site and off-site. The FS contains a'
detailed description of Alternative 6. The components of this
alternative include site preparation, institutional controls,
groundwater monitoring, groundwater extraction, construction of
an artificial wetland for groundwater treatment, re-infiltration
of the majority of the extracted groundwater, and discharge of a
small portion of the treated groundwater to Juday Creek.
Constructed wetlands are a proven technology for polishing of .
municipal wastewater effluent and for adsorption of trace metalsi
Trom mining operations. However, minimal data exists regarding
che effectiveness of constructed wetlands at removing trace
organics. Although there is minimal data regarding trace
organics removal, removal mechanisms are -thought to be similar to
the mechanisms that make constructed wetlands effective at
polishing municipal wastewater effluent and water contaminated
during mining .operations. A constructed wetland would provide an
environment in which organics and inorganics are adsorbed by, and
the organics oxidized by microorganisms attached to plant roots
and stems, and soil deposits. This process will be designed to
achieve similar results at the Site. The wetlands would be
constructed to operate with a free water surface at depths of 2
feet in the emergent marsh zones and 4 to 6 feet in the open
water zones (See Figures 2 and 3).
The constructed wetland would consist of a 1/4 inch bentonite
liner, modified to include the provision for re-infiltration of
extracted groundwater, - 1 foot of soil to support plant roots,
influent distribution piping, and effluent piping. Plants such"
as cattails would be seeded to expedite plant development (See
Figures 2 and 3).
Discharge to Juday Creek would comply with NPDES substantive and
administrative requirements. Indiana water quality criteria
-ould dictate discharge limits for the Site. The treated
groundwater is expected to meet Indiana effluent discharge water
quality criteria. IDEM has established effluent limits for the
discharge of treated water to Juday Creek for this Site (See
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FHIMtMAOWl
Transformation
and
Volaltoalion
(C,N)
Outflow
Figure 2
Wetland Treatment Processes
-------
I154C 8/95 GNV
Approximate
Scale in Feet
100 200
Plan View
Buried Inflow Pipe
Extraction Well
or Drain
Open Water
Zone
Transverse Section
Cross Section
Off-Site Flow to
Judy Creek
e
Figure 3. Douglas Road Landfill Constructed
Treatment Wetland Conceptual Ran.
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Table 5-1
Effluent Discharge Criteria
Parameter
CA
Acetone
Isophorone
THF
Benzene
4 MethyI-2-pentanooe
Toluene
Cnlorobenzene
Ethylbenzene
Xyienes
1,1 OCA
UDCA
4-Metfaytpfaenoi
BEP
U-DCB
) \jf«*hxjl*%k«nM
6-Memyipnenoi
Iron
Arsenic
di-n-butiyphthalate
VC
ICE
c-UDCE
Manganese
Onsite
Influeat
Cone.
(«/L)
15.8
35.9
0.2
2,351.20
102
40.6
93.S
2.8.
20.3
31.3
0.03
2J
2.8
52
1
0.8
7,062.7
12.7
0.8
ND
ND
ND
ND
Offcite
Influent
Cone.
(W^)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10.7
1.4
ND
3.6
8.7
02
13.3
Combiaed
Influent Cone.
(W/L)
7.9
17.95
0.1
1,175.6
5.1
20.3
46.9
1.4
10.15
15.65
0.015
1.25
L4
2.6
0.5
0.4
3,536.7
7.05
0.4
1.8
4J5
0.1
6.65
Effluent Discharge
Criteria (uf/L)
NA
109
50
25
5
15
50
50
700
10
90
5
296
343.8
NA
420
1,000
BGO-5)
12.7
2
5
70
NA
Total flow - 832 gpm (wells option) or 560 gpm (drains option)
BG * Background concentration
MKE10016256.XLS
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20
Table 4). Monthly monitoring of the effluent from the wetland
will be performed to ensure compliance with the NPDES .substantive
and administrative requirements developed for the Douglas Road
Site.
Arsenic removal before discharge to Juday Creek may be necessary
for the on-site plume based on the RI data. However, the
landfill cap proposed for the Site is expected to reduce the
quantity of arsenic leaching into the groundwater. The arsenic
concentration in the extracted groundwater will be monitored for
a 6 month period to determine if arsenic control measures are
required. If they are required, then this remedy will be
modified to include these measures.
Groundwater monitoring would be conducted as a part of this
alternative. This monitoring shall consist of semi-annual
monitoring of existing monitoring wells, new monitoring wells to
be installed, and selected residential wells. Semi-annual
monitoring would be conducted for the first two years after which
the wells would be sampled annually until preliminary remediation
goals (PRGs) are met, unless site conditions indicate that a morfe
frequent sampling program is necessary. This will be determined
during the remedial design process, as data is collected to
support the wetlands design.
Long term operation and maintenance of the extraction system ,
would consist of monthly inspections cfrid routine maintenance of
the system, including routine pump maintenance. Long term
operation and maintenance of the constructed wetland would
consist of monthly inspections and annual fertilizer
applications.. It would also consist of daily to weekly checking
of water depths and conveyance structures. Replacement of
wetland materials is not anticipated to be necessary but would be
performed, if determined to be necessary. Occasional burning of
growth would control plant/peat accumulation.
In addition/ the long term operation and maintenance plan would
outline procedures for monitoring these issues as well as issues
such as insect control and the need for dredging of the wetland
to maintain the proper water depths and provisions .for disposal
of the dredged sediments.
During remedial design of the constructed wetland, the need for
biological monitoring will be assessed. If biological monitoring
of the wetland discharge to Juday Creek is determined to be
necessary, plans for this monitoring will be developed as a part
of the design of the wetland..
Because hazardous substances will remain in place at the Site,
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1
21
U.S. EPA will review the remedial aqtion every five years to
determine its effectiveness.
Documentation of Significant Changes
The Proposed Plan for this final action was released for public
comment on November 27, 1995. At the public meeting and in
written comments on the proposed remedy, numerous commentors
objected to the quantity of water to be discharged into Juday
Creek as a result of implementation of this alternative. The FS
estimated that approximately 830 gallons per minute of treated
groundwater would be discharged to Juday Creek under the proposed
alternative. This amount of discharged water was a concern to
area residents. The main reasons for the concern expressed to
U.S. EPA was that the volume of discharged water would adversely
impact the ecological balance in the Creek.
It was communicated to U.S. EPA that area residents are
attempting to re-establish trout population in the Creek and that
existing surface drainage was adversely impacting this effort by~
increasing bank erosion, sediment load, and water temperature in:
the Creek. The concern was that the discharged water would
amplify these adverse impacts because'of the greatly increased
volume of water in the Creek.
U.S. EPA understands these concerns and will modify the proposed
remedy to address these concerns, as was communicated to the
public at the proposed plan meeting. U.S. EPA will modify the
treated groundwater discharge component of Alternative 6.
Instead of discharging all of the treated groundwater to Juday
Creek, U.S. EPA will design the wetland so that the majority of
the treated water will be allowed to reinfiltrate into the
aquifer rather that being discharged to Juday Creek. The
contaminated groundwater will still be contained at the Site so
that migration away from the Site is eliminated. It is estimated
that approximately 90% of the water can be dealt with in this
manner with the rest being discharged to Juday Creek. This will
significantly reduce the amount of discharged water so that the
aforementioned detrimental impacts on the Creek can be avoided.
The conveyance structures for the discharge to Juday Creek will-
be designed so as to minimize or eliminate any adverse impacts to
the Creek associated with the greatly reduced discharge.
A pump test will be performed as a part of remedialdesign so
that the amount of water actually required to be discharged can
be determined.
If it is determined during the remedial design of the constructed
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22
wetland that the amount of discharge to Juday Creek is
significantly higher than currently anticipated, U.S. EPA will
reassess discharge options for the treated groundwater. This
reassessment process- will include all options evaluated during
this remedy selection process.
Statutory Determinations
In accordance with the statutory requirements of Section 121 of
CERCLA, as amended, remedial actions taken pursuant to Sections
104 and 106 must satisfy the following:
1. Be protective of human health and the environment.
2. Comply with all ARARs established under federal and
state environmental laws (or justify a waiver).
3. Be cost effective.
4. Utilize permanent solutions and alternative
technologies or recovery technologies to the maximum
extent practicable.
5. Satisfy the statutory preference for remedies that
utilize treatment and also significantly reduce the
toxicity, mobility and volume of the hazardous
substances, pollutants, or contaminants.
In addition, CERCLA § 121(c) requires five year reviews to
determine if adequate protection of human health and the
environment is being maintained where remedial actions result in
hazardous substances remaining on-site above health-based levels.
The selected remedy for the Douglas Road Landfill Site achieves
these requirements as discussed in detail below.
A. Protection of Human Health and the Environment
The selected remedy will eliminate risks posed by the
contamination of the groundwater through the collection and
treatment system and the removal action that placed local
residents on municipal water supply for home water needs.
Baseline cancer risks from the site exceed the 10(-4) to
10(-6) acceptable risk range established by EPA in the NCP.
Deed restrictions will ensure that future land use of the
source area will not impose an unacceptable risk. Non-
carcinogenic risks will be reduced to levels less than the
EPA standard of 1.0, through institutional and source
control measures.
Short-term risks from the groundwater treatment system are
minimal and relate to construction site risks that will be
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1
23
addressed in the Site Health and Safety Plan.
B. Compliance with ARARs
The selected response action for the groundwater involves
the long term treatment of the groundwater in a wetland with
reinfiltrationrof the majority of the treated water at the
Site. It also involves a small amount of surface water
discharge. Surface water discharge from the Site will meet
chemical specific effluent discharge criteria developed for
the Site by the State of Indiana. These effluent discharge
criteria were developed to be protective of Juday Creek (See
Table 4).
The Agency has not identified any location specific ARARs
for this final action at the Site.
Action Specific ARARs will be met for the Site. The list of
Action Specific ARARs which apply to this Site are listed
in Table 2.
C. Cost Effectiveness
The selected remedy is cost effective. It is protective of
human health and the environment, attains ARARs and provides
long-term protectiveness. The long-term effectiveness is
achieved by the treatment of the contaminated groundwater.
The selected remedy is less expensive than Alternative 4,
while achieving comparable results. The selected remedy is
the same cost as Alternative 5, achieves a slightly better
result, and creates a beneficial wetland. The selected
remedy is somewhat more costly than Alternatives 3 and 7,
but the selected remedy achieves better results, treats the
entire contaminated groundwater plume rather than a portion
of it, and creates a beneficial wetland. The selected
alternative is more expensive than Alternatives 1 and 2, but
achieves substantially superior results in terms of speed of
cleanup and reaching cleanup objectives. The selected
remedy minimizes the long-term operation and maintenance
costs that will be borne by the State.
D. Utilization of Permanent Solutions, and Alternative
Treatment Technologies to the Maximum Extent
Practicable
The selected remedy was determined to be the most
appropriate solution to remediate the contamination at the
Site. Groundwater collection and treatment will eliminate
risks posed to the public within 20 to 60 years, eliminate
toxicity, mobility and volume of the contamination in the
groundwater and will maximize protection of human health and
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24
the environment. The time fra^ne of 20 to 60 years to treat
the groundwater is based on the estimated time to collect
the contamination in the current groundwater plume.
The selected remedy uses an alternative treatment method by
treating the collected contamination in a created wetland.
This treatment approach not only effectively treats the
contaminants, but adds an important habitat to the Juday
Creek ecosystem. While this treatment approach is a unique
alternative, implementation should not pose any substantive
difficulties.
E. Preference for Treatment as a Principle Element
The selected remedy uses treatment as a principal element to
remediate risks posed by the groundwater contamination. The
groundwater will be collected using wells or collection
drains into the aquifer and a pumping system will transport
it to the wetland where it will be treated. Following
treatment, the water will be returned to the ecosystem
through direct infiltration, with a portion being discharged
into Juday Creek.
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APPENDIX A
Douglas Road Landfill
Mishawaka, Indiana
Responsiveness Summary
I. Responsiveness Summary Overview
In accordance with CERCLA Section 117, a public comment period
was held from November 27, 1995 to January 25, 1995, to allow
interested parties to comment on the United Stated Environmental
Protection Agency's (U.S. EPAfs) Feasibility Study (FS) and
Proposed Plan -for the Douglas Road Landfill Superfund site. At a
December 5, 1995, public meeting, EPA and Indiana Department of
Environmental Management (IDEM) officials presented the Proposed
Plan for remediation at the Douglas Road site, answered questions
and accepted comments from the public. Written comments were
also received through the mail.
II. Background of Community Concern
The Douglas Road Landfill operated from 1954 to 1979 as a
repository for Uniroyal plant wastes. From 1954 to 1971,
solvents, fly ash, paper, wood stock, rubber and plastic scrap
were disposed of at the landfill. Only fly ash was disposed of
from 1971 through 1979.
The Site was nominated for inclusion of the NPL on June 10, 1986
and placed-on the NPL on March 31, 1989. In September, 1989, the
State of Indiana and Uniroyal signed a consent decree in which
Uniroyal agreed to perform a Remedial Investigation/Feasibility
Study (RI/FS) at the Site. Before completion of this work,
Uniroyal filed for bankruptcy and discontinued work at the Site.
Following the bankruptcy, it was determined that U.S. EPA would
implement and finance an RI/FS which was begun in early 1994,
using Superfund money.
During the SI, it was discovered that residential wells in the
vicinity of Douglas Road and State Route 23 were contaminated
with vinyl 'chloride and trichloroethylene (TCE) , contaminants
that had been identified as coming from the Site. These
residents received the following temporary measures to provide
protection until a permanent remedy could be implemented for the
affected wells: for those with vinyl chloride contamination,
residents received portable air strippers and for those with TCE
contamination, residents received in-line filters.
Community involvement has increased as the extent of the off-site
groundwater plume and the number of wells impacted by site
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contamination has been determined. This has led to more people
becoming aware of activities at the Site and attending the
informational meetings.
Ill* EPA's Proposed Remedy and its Relation to the Final ROD
In a Proposed Plan that was issued on November 26, 1995, U.S. EPA
(EPA) proposed Alternative 6, Groundwater Extraction, Constructed
Wetland Treatment, and Discharge to Juday Creek for the
groundwater phase of the cleanup. This remedy was based on the
information presented in the FS, prepared by CH2M Hill and
reviewed and approved by EPA. During the public comment period,
EPA received numerous comments regarding the proposal of
Alternative 6, most of which objected to the Juday Creek portion
of the proposal. The majority of the comments recommended that
EPA either discharge to the Mishawaka POTW or to the St. Joseph
River.
As a result of the public comments, EPA has modified the portion
of Alternative 6 that involved discharge of waters treated by the
wetland, as is outlined in the Record of Decision (ROD).
EPA will attempt to provide information relative to these
modifications that the ROD contains, demonstrating that public
concerns play a large role in Superfund remedy selection, as well
as answering the concerns that the public has voiced regarding
the components of this ROD.
IV. Summary of Significant Comments Received During the Public
Comment Period and EPA Responses
The comments are organized into the following categories:
A. Summary of comments concerning the overall effectiveness of
the proposed remedy and its impacts on Juday Creek.
1. Comments were raised concerning the effectiveness of the
constructed wetland at treating the contaminated groundwater.
U.S. EPA response 1: U.S. EPA understands the concerns regarding
the effectiveness of the wetland to treat the contaminants in the
groundwater. This remedial technology has been used with good -
results by wastewater treatment plants to effectively polish the
water, or to remove contaminants. Additionally, the wetland can
be designed so that retention time, or the amount of time spent
in the wetland which is where the actual biological .breakdown of
the contaminants occurs, can be increased to a point where
maximum contaminant treatment can occur.
2. Comments were raised concerning the construction of the
wetland and the desire not to create a "bathtub" by lining the
bottom of the wetland.
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U.S. EPA response 2: U.S. EPA understands the intent of this
comment as being the concern that a completely lined wetland
would seem to have the potential to overflow during rain events,
which could detrimentally impact the surrounding area. As is
explained in the ROD, the design of the wetland will include a
liner as a component, which will allow the water to remain in the
wetland long enough to allow sufficient treatment. However, the
wetland will also be designed to allow direct re-infiltration of
water at one end. This will accomplish the objective of limiting
the amount of treated water discharged to Juday Creek. Also, the
wetland will be designed so that the height of the sidewalls will
allow the wetland to store excess rainwater without overflowing.
3. Comments were raised supporting the selection of Alternative
6 as the most appropriate alternative for the groundwater
treatment, provided Juday Creek was protected.
U.S. EPA response 3: U.S. EPA appreciates the positive comments
regarding the selection of Alternative 6. U.S. EPA believes that
this remedy is the most appropriate for this cleanup phase, and
has made modifications so that Juday Creek is protected to the
maximum extent possible. EPA will continue to involve the
interested citizens in the design and construction of the wetland
by meeting frequently with the groups trying to protect Juday
Creek.
4. A* commentor raised the concern that the wetland design not
include standard design retention ponds that discharge warmer
waters from the top of the pond. The commentor suggested a
design that would discharge cooler waters from the bottom, which
would not impact creek temperatures as drastically.
U.S. EPA response 4: U.S. EPA will factor this concern into the
design of the wetland. It is U.S. EPA's intent to minimize the
impacts of. this remedy on Juday Creek.
5. A commentor stated that the proposed wetland should be placed
on 25 acres of property located south of Douglas Road. The
commentor stated that this was an appropriate location for the
wetland.
U.S. EPA response 5: U.S. EPA appreciates the suggested wetland
location. During the remedial design process, this location and
others like it in the area, will be closely studied and the most
appropriate location will be selected. U.S. -EPA appreciates the
commentor1s information and any other information to assist U.S.
EPA in selecting the most appropriate site.
6. Several commentors expressed concern that, during periods of
heavy precipitation if discharge to Juday Creek was halted with
some type of shutoff mechanism, that water would overwhelm the
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containment structures, resulting in flooding of nearby areas.
U.S. EPA response 6: U.S. EPA understands this concern. There
are several alternatives for dealing with this problem. The
sidewalls for the wetlands currently being contemplated would
easily be able to accommodate storm events. They will be at least
several feet high. ^During storm events, the extraction rate
could be slightly decreased so that the total amount of water in
the wetland remains at a manageable level. Also, the design of
the wetland will include sufficient size so that excess water
from storms could easily be accommodated.
7. Several commentors raised the issue of whether a subsurface
flow wetland would be more appropriate for this site than a
surface flow wetland because they felt that it would be less
weather dependent, thus allowing for better groundwater
treatment.
U.S. EPA response 7: U.S. EPA understands the concerns raised by
this comment. While the surface water in the wetland may freeze
during longer periods of colder weather, the lower portions will
not. The reason for this is that there will be continual water
flow through the wetland, this will prevent freezing. Because
the bottom of the wetland is where the majority of groundwater
treatment occurs, freezing should not adversely impact
groundwater treatment.
8. A commentor asked whether the design of the wetland could
include extra aeration of the treated water before discharge.
U.S. EPA response 8: This concern will be investigated during
remedial design and, if appropriate, incorporated into the design
.of the wetland.
9. A commentor asked for an additional monitoring location be
added to the area near State Road 23 and McErlain Street to
assist in off-site monitoring.
U.S. EPA response 9: This concern will be investigated during
remedial design andf if appropriate, incorporated into the design
of the wetland.
B. Summary of comments regarding discharge of treated
groundwater to Juday Creek.
10. Comments were raised with concern that the discharged water
would be contaminated.
U.S. EPA response 10: The water that is discharged from the
wetland to Juday Creek is required to meet stringent NPDES
discharge criteria developed and regulated by the Indiana
Department of Environmental Management. These criteria are
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listed in the FS. There will be procedures for monitoring the
discharged water to ensure that these standards are met. If the
discharge exceeds these standards, then U.S. EPA and IDEM will
take the appropriate steps to correct the exceedance. These may
include stopping the discharge until it can be assured that the
criteria can be met. Other measures may also include increasing
the amount of time that the water spends in the wetland, thus
increasing the treatment efficiency.
11. Comments were raised regarding potential detrimental impacts
on Juday Creek because of discharge from the wetland (large
discharge volume, increased temperature, increased bank erosion,
increased sedimentation).
U.S. EPA .response 11: U.S. EPA understands these concerns and
has modified the proposed remedy so that only a small percentage
of the water would need to be discharged to Juday Creek. The
design of the wetland, as was outlined at the proposed plan
meeting, will include an area where water can be recharged
directly to the aquifer. The water that is recharged would
continue to be collected and retreated in the wetland, so the
entire system would contain the contaminated groundwater at the ,
site. The outfall on Juday Creek can be designed so that erosion
problems from discharge can be avoided. This can be done with
the installation of rip rap, or rocks and stones, to help to
decrease the discharge velocity. The water being discharged into
the Creek will be relatively sediment free, because groundwater
typically contains limited sediment. .The temperature of the'
discharged water' will be similar to the Creek temperature, as
both will be standing bodies .of water.
12. Comments were raised concerning the potential discharge of
the treated water directly to the St. Joseph River, instead of
Juday Creek.
U.S. EPA response 12: U.S. EPA will look into this possibility
during remedial design. The St. Joseph River is approximately 4
miles from the site. The cost of installing piping and pumping
the water to the River would be approximately $1.5 to $2 million
over the estimated $6 million currently estimated for the
wetland. It appears that this-option would significantly
increase the cost of the remedy without a commensurate gain in
remedy effectiveness.
13. Comments were raised that the discharged water should be
sent to the Mishawaka POTW instead of Juday Creek, and that cost
was no object when it came to cleaning up the site and protecting
Juday Creek.
U.S. EPA response 13: Cost -effectiveness is a statutory
requirement for the remedy selection process. Costs for sending
the water to the POTW were more than twice as expensive as any of
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4
the Juday Creek discharge options. If two remedies provide
similar levels of protection, then EPA is required to select the
most cost effective one. Another consideration is whether the
POTW treatment efficiency will be detrimentally impacted by this
discharge. Historically, treated (or clean) water is not usually
accepted for treatment at local POTWs because it would affect
their ability to treat wastewater. The Mishawaka POTW has
indicated this to EPA as well as to the Juday Creek Task Force at
a recent meeting.
EPA has investigated the idea of sending the reduced amount of
discharge to the POTW. Based on the estimated surcharge that
Mishawaka is applying to the site discharge, it would cost over
$1 million to send this water to the POTW. Also, the POTW does
not have the current capacity to be able to accept this discharge
without potentially violating portions of their operating permit.
14. Comments were raised concerning the potential on-site
treatment of contaminated water, if the POTW option proved too
costly.
U.S'. EPA response 14: EPA investigated this possibility during
the early stages of the FS. Because of the levels of
contaminants present in Site groundwater and'the size of the
Site, it was determined that the zone of treatment wasnft large
enough to treat the contaminants effectively. This would result
in much greater treatment costs which would drive the overall
remedy costs to a level where they would not be cost effective.
Please keep in mind that the construction of wetlands is a viable
groundwater treatment technology that will remove the
contaminants from the groundwater.
15. Comments were raised that asked whether the water could be
completely contained in the on-site wetland with no discharge to
Juday Creek.
U.S. EPA response 15: The system that the commentcrs are asking
about is called a closed loop system and it is impossible to
construct. If the only water that was entering the system was
the extracted groundwater, then this would be possible. . In a
closed loop system, the only water being recirculated or treated
would be the extracted groundwater. But, rainwater and other
unpredictable sources of surface water runoff will add additional
volume to the system. Consequently, the system would have to
accommodate an unspecified amount of water.
An analogy would be two 5 gallon buckets of water, one full and
one empty. If the contents of one bucket was poured into the
other, you'd completely fill it. If you tried to pour 6 gallons
into the empty five gallon bucket, it would overflow -you need to
find another place for the extra 1 gallon.
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This concept applies at the site. It is impossible to completely
contain all water onsite without some requirements for discharge
of the excess water.
16. A commentor raised the issue of several local groups that
are currently voicing objection to the proposed Juday Creek
discharge and that these local groups did not object to previous
projects that used Juday Creek in a similar fashion.
U.S. EPA response 16: U.S. EPA cannot comment on previous
decisions allegedly made by these groups. These local groups
have made their concerns known regarding this project and U.S.
EPA is responding to them in this responsiveness summary. U.S.
EPA thanks the commentor for this information.
17. Several commentors asked if the discharge to Juday Creek
could be stopped during periods of heavy rains so that creek
flooding could possibly be circumvented.
U.S. EPA response 17: U.S. EPA understands the concerns raised
by this comment. The design of the wetland can include
provisions that will prevent discharge to the Creek if the water?
level in the Creek rises above a certain level. The design can "
also include provisions for lowering the extraction rate for
short periods of time so that actual discharge needs are lessened
temporarily. The design will contain options such as these to
ensure that any impacts to the Creek are minimized.
18. A commentor raised the issue that during periods of heavy
rains, rainwater will be allowed to "shoot through the wetland"
and discharge directly into Juday Creek without any treatment by
the wetland.
U.S. EPA response 18: The design of the constructed wetland is
forthcoming. Any rainwater that falls into the wetland will be
much cleaner than what is present in the wetland. This will
serve to further dilute any contaminant concentrations present in
the wetland, further increasing treatment efficiency. The
wetland will be designed with sufficient space to accommodate
temporary storm surges. Also, the accumulated rainwater will
remain in t&e wetland long enough to allow the sediment to drop
out, thus decreasing the impacts on the Creek. The retention -
time can also be increased, ensuring that the commentorfs
concerns are adequately addressed.
19. Several commentors stated that at the Amoco site in Granger,
Indiana, the State had initially proposed a remedial option that
included discharge to Juday Creek and after public input, had
instead opted for on-site treatment of the site contaminants.
These commentors stated that they wanted a similar remedy at
Douglas Road.
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1
8
U.S. EPA response 19: U.S. EPA has contacted Mr. Ken Gill, the
IDEM Project Manager for the Amoco site, to discuss Amoco's
remediation plan. These discussions indicated that the Amoco
remedial plan is different from the one proposed for Douglas
Road. Mr. Gill stated that retention ponds are currently being
used for reinfiltration of treated groundwater. According to Mr.
Gill, the location of these retention ponds is OUTSIDE of the
contaminated plume. This is a situation which is different than
at the Douglas Road site where treatment would be occurring
inside the plume. At Douglas Road, the plan is to have treatment
occur within the groundwater plume by extracting groundwater at
the downgradient end of the plume-west of the site and
reinjecting it at the upgradient end -east of the site. By doing
this, some of the extracted water will not be able to be
reinjected because of added volume to the system from rainwater.
At the Amoco site, treated groundwater is reinjected outside of
the plume, as a result, containment of treated water is not a
concern. However, during .remedial design, U.S. EPA will
investigate the possibility of reinjecting .downgradient of the
extraction wells so that the amount of excess water to be
discharged may be minimized. One potential limiting factor is
that the NPDES limits provided by IDEM may preclude this option
for this site.
20. Several commentors raised concerns that the wetland
treatment would not be completely effective at removing the
contaminants present in the contaminated groundwater.
U.S. EPA response 20: U.S. EPA acknowledges these concerns.
Please be assured that the quality of the discharged groundwater,
before it is discharged, will consistently meet the NPDES
discharge limits set by the State of Indiana. The means for
accomplishing this lies in the retention time for treatment in
the wetland. The retention time for treatment can be increased
so that contaminant levels are further reduced to meet NPDES
levels.
21. Several commentors asked for biological monitoring in
addition to the NPDES monitoring in order to assess the impacts
of this discharge on aquatic life in the Creek.
U.S. EPA response 21: U.S. EPA will investigate this issue
during remedial design. If discharging to Juday Creek remains
necessary, biological monitoring both up and downstream of the
discharge point can be done.
22. A commentor raised concerns regarding PCBs and dioxin and
their detrimental impact as a discharge to Juday Creek. The
commentor also asked for monitoring for these compounds to ensure
that these contaminants are not being discharged into Juday
Creek.
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1
U.S. EPA response 22: U.S. EPA understands these concerns and
will investigate this issue during remedial design. It will be
determined during remedial design if long term monitoring is
appropriate for these chemicals.
23. A commentor asked that the accumulated sediment in the
wetland be sampled for PCBs and dioxin, as these were present in
the landfill surface soils. The commentor was concerned that
these contaminants might adversely impact discharge to Juday
Creek.
U.S. EPA response 23: PCBs and dioxin were detected in the
surface soil samples taken from the landfill. However, these
contaminants were not detected in any groundwater samples
collected at or near the site. This demonstrates that they are
not presently leaching into the groundwater. The. wetland is
treating groundwater, not soils. By placing a cap over the
landfill, any contact with surface soils or extensive leaching of
contaminants into groundwater will be eliminated. Thus, it is
not anticipated that these contaminants will pose a future
problem inhibiting wetland performance. Groundwater will be
monitored for these contaminants during operation and maintenance
activities at the Site so that the remedy's performance can be
continually evaluated.
C. Summary of comments regarding other remedial alternatives.
24. A commentor raised the issue that in all the years that the
landfill has been around, that there were no instances where
anyone had suffered because of dumping at the site. This
commentor further stated that Alternative 1 was the most
appropriate because "the problem does not exist."
U.S. EPA response 24: U.S. EPA disagrees with the commentor. A
problem DOES exist, there is contamination in the groundwater.
Samples of wells that residents were using for their water supply
are contaminated with chemicals that cause cancer. This is a
serious problem that U.S. EPA is addressing with its actions at
the Site. Without any further action to clean up the
contamination, the potential exists for the contamination to
migrate further away from the Site, perhaps into or past Juday
Creek, or potentially to the St. Joseph River. The proposed
wetland will prevent this from happening and actually treat the
water to remove the dangerous chemicals.
25. A commentor stated at the public meeting that Alternative 2
should be selected. They.stated that the land should be
restricted somewhat, with the contaminated plume being allowed to
migrate unrestricted, and city water continuing to be extended
indefinitely.
U.S. EPA response 25: U.S. EPA disagrees with this approach.
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10
The current city water extension was very difficult to fund in
these uncertain budget times. In fact, it was delayed for months
until funding was obtained. Additionally, extending city water
to local residents does not solve the problem of cleaning up
contaminated groundwater. EPA will conduct monitoring of the
groundwater after the remedy is implemented. At this time, it is
difficult to predict where the groundwater will migrate to once
the residential wells are no longer used. The commentor is
asking for EPA to continually extend city water indefinitely,
which is not the most effective way to deal with contaminated
groundwater. The most effective method is to clean up the
source, which is what this action will do. Not doing so will
potentially endanger residential wells to the south and west.
Area residents have indicated that their biggest concern is the
potential for drinking water to become contaminated. With
Alternative 2, this concern is not met.
These comments have been paraphrased in order to effectively
summarize them in this document. The reader is referred to the
public meeting transcript which is available in the public
information repository, which is located at the Mishawaka-Penn
Public Library, 209 Lincoln Way East, Mishawaka. Written
comments received at EPAfs regional office are on file in the
Region 5 office. A copy of these written comments has also been
placed in the aforementioned repository.
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
DOUGLAS ROAD LANJDFILL
MISHAWAKA, INDIANA
UPDATE *i
04/17/96
DOC! DATE
ssss zsss
AUTHOR
srssrs
1 00/00/00 U.S. EPA
2 00/00/94 U.S. EPA
3 02/24/95
Novak, 0. and H.
Fontt, U.S..EPA
4 05/15/95 Concerned Citizen
RECIPIENT
sssssssss
File
File
Residents
Roeter, T., U.S.
Congress
5 06/02/?5 Cancirned Citizen Novak, D.f U.S. EPA
6 06/05/95 Novak, 0., U.S. EPA Ploeb, D., CH2H Hill
1 07/31/95 ' Likins, A., IDEB Novak, D., U.S. EPA
9 08/01/95 Novak, D., U.S. EPA Addressees
9 08/08/95 Likins, A., IDEM
10 08/16/95 PIoil, D., CH2H Hill
Nova, 0., U.S. EPA
Novak, 0., U.S. EPA
11 08/22/95
nackiMiifc, K., St.
Joseph River Basin
Comssion
Novak, 0., U.S.
EPft/OPfl
TITLE/DESCRIPTION PASES
rrsssssssssssssss ==rss
Figures: Hydrographs froi the Creek and Well 3
12 at the Lake Inflow and Notre Date Sites
/Attached Handwritten Notes
Excerpts frot SJRBC's FY 1992-1994 Juday 5
Creek Sutury Report (HANNRITTEN
ANNOTATIONS)
Letter re: Construction of a City Waterline 2
Extension
Letter re: Installation of City Water to 3
Areas Affected by Contaminated Mater
(HANDWRITTEN)
Letter re: Proposed Boundaries of the Dougles* 2
Road Site
Letter re: U.S. EPA's Gottents on the 6
Feasibility Study Report for the Sroundwater
Operable Unit
Letter re: Discharge Limitations for Treated 2
Sroundwater frot the Douglas Road Landfill
Site
Cover Letter re: Review of the Draft Proposed 1
Plan
Letter re: ID Ell's Comnts on the Draft 2
Proposed Plan for Operable Unit 13
Letter re: CH2H Hill's Responses to U.S. 11
EPA's CoMtnts on the Agency Review Draft of
tht Feasibility Report
Letter re: Discharge of Water into Juday 3
Creek
12 08/23/95 Likins. A.f IDEH
Novak, D., U.S. EPA Letter re: IDEN's Gottents on the Feasibility 5
Study for the Srcund Water Operable Unit
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OOCI DATE
rsss ssss
AUTHOR
rsrrrz
RECIPIENT
TITlE/OESCRiPT10N
PAGES
13 08/28/95 Novak, j. ar? D. "rcperty Owners
Sanlrs*.:, u.S. EpA
Letter re: Extension of Water Supply to Those
Residents Current!/ Affected by Ground Hater
Contamination
14 09/00/95 CH2H Hill
U.S. EPA
15 09/06/95 Novak, D., U.S. EPA Concerned Citizen
16 09/28/95 Rase, J., IDEM Novak, 0., U.S. EPA
17 11/00/95 U.S. EPA
18 11/23/95 U.S. EPA
Public
Public
19 11/28/95 Novak, D., U.S. EPA Property Owners
Public Coitent Feasibility Report w/August 9 204
and September 25, 1995 Cover Letters
Letter re: Extension of City Water South of 2
Juday Creek
Letter re: IDEfl's Comments on the Proposed 2
Plan
Proposed Plan for Remedial Action (Ground 6
Miter) at the Douglas Road Superfund Site
Public Notice: Announcement of December 5, 1
1995 Public fleeting and the November 27-
December 26, 1995 Public Comment Period
(Rishawka Enterprise)
Letter re: Construction of the Haterline 2
Extension
20 12/05/95 Rummel Reporting U.S. EPA
Service
21 12/14/95 Davis, D. and J. Novak, DM U.S.
Sporleder, Izaak EPA/QPA
Maiton League of
America
Transcript of December 5, 1995 U.S EPA Public 82
Hearing
Letter re: Request for a 30-Day Extension to 2
the Public Comment Period
22 12/15/95 Novak, 0., U.S.
EPA/OPA
Novak, D., U.S. EPA
Nemorandum re: Request for a 30-Day Extension
to the Public Comment Period
23 12/17/95 U.S. EPA
24 12/20/95 Plain, 6., St.
Joseph County
25 12/29/95 Raittmt, P.,
lOMI/lmsioA of
Fish and ttildlife .
24 01/10/96 Davis, D., Juday
Creek Task.Force
Public
South Bend Resident
Novak, D.9 U.S.
EPA/OPA
Novak, D., U.S.
EPA/OPA
Public Notice: Announcement of an Extension
to January 25, 1996 of the Public Comment
Period (IlishawaU Enterprise)
Letter re: Connection to the Men Hater System
(IMBIBED)
Letter re: IDMTs Comments on the Proposed
Cleanup
Letter re: JCTF's Comments on the Proposed
Plan
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OOCI DATE
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AUTHOR
RECIPIENT
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TITLE/DESCRIPTION
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PASES
1
:T 01/22/96 Concerned Citizens J.3. EPA
28 01/22/96 Wright, I., St. Novak, D., U.S.
Joseph County EPA/OPA
Drainage Board
29 01/25/96 Studer, S., Studer I Novak, D., U.S.
Associates EPA/OPA
30 01/25/96 Plain, S. et al.;
St. Joseph County
Health Department
31 03/12/96 Kleiaan, J., U.S.
EPA
32 03/15/96 Likins, A., IDEH
Novak, DM U.S.
EPA/OPA
Novak, D., U.S. EPA
Novak, D., U.S. EPA
33 03/15/96 Harrero, J., U.S. Novak, D., U.S. EPA
EPA
34 03/28/96 Lovelace, K., U.S. Novak, 0., U.S. EPA
EPA/ARC
35 04/11796 Likins, A., IDEM Novak, 0., U.S. EPA
Fifteen Letters/One Petition re: Pu:i:c
Coaients on the Proposed Plan Received
September 9, 1995-January 22, 1996
Letter re: Discharge of Water into Juday
Creek
Letter re: Public Coaaents on Alternative Use
16-Sroundwater Extraction, Constructed
Wetland Treataent and Discharge to Juday
Creek
Letter re: SJCHD's Coaaents on the Proposed
Plan
Neaorandua re: RCRA's Review of the Draft
Record of Decision for ARARs
Letter re: IDEIf's Coaaents on the Draft
Record of Decision for the Ground Mater
Operable Unit
Heaorandua re: Review of the Draft Record of
Decision for Operable Unit 12
Reaorandua re: ARC'S Review of the February
28, 1996 Draft Record of Decision for
Qperablp Unit 12
Letter re: IDBTs Coaaents to the Revised
Record of Decision
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