PB96-964106
EPA/ROD/R05-96/301
October 1996
EPA Superfund
Record of Decision:
Reilly Tar and Chemical (O.U. 3 and 4),
Indianapolis Plant, Indianapolis, IN
9/27/1996
-------
-------
Declaration for the Record of Decision
Reilly Tar & Chemical
Operable Units 3 and 4
Site Name and Location
Reilly Tar and Chemical
Indianapolis, Indiana
Statement of Basis and Purpose
This decision document presents the selected remedial action for operable units 3 and 4 at the
Reilly Tar & Chemical site (the Site) in Indianapolis, Indiana. These remedial actions were
selected in accordance with CERCLA, as amended by SARA, and, to the extent practicable, the
National Contingency Plan. The selection of these remedies are based on the Administrative
Record for the Site.
The State of Indiana concurs with the selected remedies.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response actions selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of the Selected Remedies
These operable units are the third and fourth of five planned for the Site They specifically outline
actions to address two onsite areas of soil and groundwater contamination, which have been
determined by the Remedial Investigation to pose unacceptable risks to human health and the
environment.
The major components of the selected remedies for operable units 3 and 4 include:
Operable Unit 3
Placement of a soil cover over those portions of the kickback area that are not currently
covered with gravel. Gravel covers the majority of the kickback area and maintenance of
these soil and gravel covers will be formally required.
Future land use in the kickback area will be limited to industrial uses by deed
restrictions.
Groundwater and source area monitoring to ensure that the goals of this action are met.
-------
Operable Unit 4
Construction of an asphalt or concrete cover over hot spot area C, the Tank 66 area.
•• i
Soil vapor extraction will be performed at hot spot areas A and B to remove organic
contamination from the soils.
Treatment of condensate generated from the soil vapor extraction in Reilly's onsite
wastewater treatment plant.
An institutional control to maintain gravel covers in hot spot areas A and B following
treatment which may be added to Reilly's operating permit.
Future land use will be restricted to industrial by the use of deed restrictions.
Groundwater and source area monitoring to ensure that the goals of this action are met.
Declaration
The selected remedies are protective of human health and the environment, comply with Federal
and State applicable or relevant and appropriate requirements for these operable unit actions, are
cost effective, and consistent with achievement of a permanent remedy. These operable unit
actions fully address the statutory mandate for permanence and treatment to the maximum extent
practicable. These actions also satisfy the statutory preference for remedies that employ treatment
that reduces the toxicity, mobility, or volume as a principal element. Subsequent actions at the
site will be taken to address other threats posed by conditions at this site. Because these remedies
will result in hazardous substances remaining onsite 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 the remedial action. Because these
are the third and fourth of five operable unit actions at the site, review of this site and of these
remedies will be continuing as EPA continues to develop other remedial alternatives for this site.
Date William E. Muno, Du4ctor
Superfund Division
-------
Decision Summary - Operable Unit 3 and 4
Reilly Tar and Chemical
Indianapolis, Indiana
Site Name, Location and Description
Reilly Tar and Chemical
Indianapolis, Indiana
The Reilly Tar and Chemical site (the Site) is located at 1500
South Tibbs Avenue in the southwest quadrant of Indianapolis.
Minnesota Street divides the 120 acre site into two parcels. The
Oak Park property, occupying approximately 40 acres, is located
north of Minnesota Street. The Maywood property occupies
approximately 80 acres, and is located south of Minnesota Street
(see Figures 1 and 2). The Oak Park property contains the
majority of Reilly1s operating facilities, including above-ground
storage tanks, distillation towers, and above- and below-ground
utilities. The Oak Park property also contains one area formerly
used for disposal of hazardous wastes, the Lime Pond, a surface
impoundment which received hazardous wastes. Drams containing
hazardous wastes were also buried in the soils adjacent to the
Lime Pond. The Maywood property contains operating facilities on
its northern end. This property was formerly the site of
chemical process and wood preserving activities and currently
contains four other areas used in the past for hazardous waste
disposal. These four former hazardous waste disposal areas
include the Abandoned Railway Trench, the Former. Sludge Treatment
Pit, the Former Drainage Ditch, and the South Landfill/Fire Pond.
The majority of the operating facility buildings are located
north of Minnesota Street; approximately 75% of the Oak Park
property is covered by buildings, pavement and above-ground tank
farms. Approximately 20% of the Maywood property is covered by
buildings, pavement and above-ground storage, tanks. The
remainder is primarily unpaved and vegetated.
The Reilly Tar site is surrounded by a mix of residential,
industrial and commercial properties. Residential neighborhoods
are located immediately adjacent to the eastern boundary (on the
east side of Tibbs Avenue) of the Oak Park property. Two
-------
-------
VD
U
-------
DAPPROXWATe
SITE BOUNDARY
-------
residences are also located abutting the northern property
boundary near the Lime Pond in the northwest corner of the site.
Commercial and industrial properties are located south and west
of the site.
Site History and Enforcement Activities
Industrial development of the Reilly site began in 1921 when the
Republic Creosoting Company (which later became Reilly Tar &
Chemical, which in turn became Reilly Industries, Inc.) started a
coal tar refinery and a creosote wood treatment operation on the
Maywood property. On-site wood treatment operations occurred
from 1921 until 1972. Beginning in 1941, several chemical plants
were constructed and operated on the Oak Park property.
Environmental problems at the site are related to the management
and disposal of creosoting process wastes and to wastes
associated with and substances used in the process of
manufacturing custom synthesized specialty chemicals.
The earliest recorded complaint about odors and,disposal
practices at the site was in 1955, which referenced the fact that
a chemical manufactured at Reilly (alpha picoline) had been found
in nearby residential wells. In 1964, three contaminants from
Reilly were detected in off-site groundwater samples and on-site
surface-water samples. In 1975, State investigations revealed
several on-site problems which were believed to have been
contributing to groundwater contamination with organic chemicals.
In 1980, an on-site soil sample collected by State personnel was
found to contain various organic chemicals including toluene and
trichloroethylene. In 1987, 60,000 gallons of waste fuel,
containing primarily pyridine and pyridine derivatives, benzene,
xylene, and toluene, were accidentally spilled on the Oak Park
property. Some, but not all, of the fuel oil was recovered and
some, but not all, of the contaminated soil was excavated by
Reilly.
In 1984, Reilly Tar was listed on U.S. EPA's National Priorities
List (NPL), a roster of the nation's worst hazardous waste sites,
making it eligible for cleanup under the Superfund program. In
1987, the potentially responsible party (Reilly) agreed to
conduct a remedial investigation (RI) to characterize the "nature
and extent of contamination at the.site, and a feasibility study
(FS) to evaluate and compare remedial alternatives according to
the terms of an Administrative Order on Consent between the U.S.
EPA and Reilly Tar & Chemical. •
In 1989, Reilly Tar & Chemical changed their corporate name to
Reilly Industries, Incorporated, under which they operate today.
-------
In June, 1992, a Record of Decision was signed by the Regional
Administrator for the first operable unit at the site, calling
for a groundwater extraction/treatment/discharge system to be
installed to contain the migration of groundwater contaminated by
the site at the site boundary.
In September, 1992, Reilly agreed to incorporate RCRA corrective
action requirements into existing site studies according to the
terms of an amendment to the existing Administrative Order on
Consent between the U.S. EPA and Reilly Tar & Chemical. Operable
unit actions outlined in this Record of Decision"address areas
incorporated into site studies by the 1992 Amendment to the 1987
Administrative Order on Consent.
In September, 1993, A Record of Decision was signed by the
Regional Administrator for the second operable unit at the site,
calling for the excavation and thermal desorption of soil at four
on-site source areas and the solidification of sludge and
placement of a soil cover over a fifth on-site source area.
Consent Decrees have been negotiated and entered for operable
•units 1 and 2. The consent decree for operable unit 1 was
entered on August 19, 1993. The consent decree for operable unit
2 was entered on February 1, 1995.
The perimeter groundwater extraction system has been in operation
since October 1994, containing contaminated groundwater at the
site boundary. The sludge accumulation at the South Landfill
portion of OU 2 has been solidified and a soil cover has been
placed over the area. The thermal desorption of the four
remaining areas addressed under OU 2 will commence shortly and be
completed in the spring of 1997. ;-
Highlights of Community Participation
Public participation requirements under CERCLA Sections 113
(k)(2)(B)(I-v) and 117 were satisfied during the RI/FS process.
U.S. EPA has been primarily responsible for conducting the
community relations program for this site, with the assistance of
the Indiana Department of Environmental Management (IDEM). The
following public participation activities, to comply with CERCLA,
were conducted during the RI/FS.
- A Community Relations Plan was developed in August 1987 to
assess the community's informational needs related to the
Reilly site and to outline community relations activities to
meet these needs. Residents and community officials were
interviewed and concerns were incorporated into this plan.
-------
A public information repository was established at the
Indianapolis/Marion County Public Library-Certral Branch.
A mailing list of interested citizens, organizations, news
media, and elected officials in local, county, 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 was also updated from time to time as persons
approached EPA for information about the site.
A Fact Sheet was mailed to the public in August 1987, that
announced a public meeting to discuss the upcoming Remedial
Investigation and answer site related questions from the
public.
A public meeting on September 2, 1987, at the Indianapolis
City-County Building announced the initiation of the Remedial
Investigation and provided details about its conduct.
A Fact Sheet was mailed to the public in Winter 1988, that
announced the beginning of Phase 1 RI sampling and the release
of the EPA approved Phase 1 RI workplan.
A Fact Sheet was mailed to the public in Fall 1988, that
summarized the findings of the Phase 1 investigation and
provided a preview of proposed Phase 2 sampling activities.
A Fact Sheet was mailed to the public in January 1990, that
announced the findings of the Phase 2 investigation and
provided a preview of propo.sed Phase 3 sampling activities. •
Two availability sessions were held on September 6, 1990, at
the Stout Field School to discuss site.progress and discuss
results of completed sampling activities.
A Fact Sheet was mailed to the public in August 1991, that
summarized results of the completed Remedial. Investigation.
The EPA approved Remedial Investigation Report was also
released at this time.
A Fact Sheet was mailed to the public in January 1992, that
summarized EPA's recommended remedial alternative in a
proposed plan for the groundwater operable unit. The EPA
approved Focused Feasibility Study was also released at that
time. This fact sheet also announced a public comment period
for the proposed remedial action and was accompanied by paid
newspaper advertisements in the Indianapolis Star and the
Indianapolis News.
-------
A Public Meeting was held on January 23, 1992, at the South
Wayne Junior High School to present EPA's proposed plan for
the groundwater operable unit and to receive formal public
comment.
Paid newspaper advertisements announced the RI public meeting,
the availability sessions, and the OU 1 FS and proposed plan
public meetings.
Periodic news releases announced results of studies at the
site. _
i.-- .
A public comment period of thirty days was originally planned,
running from January 16, 1992, to February 14, 1992. Based on
a written request during the original comment period, the
comment period was extended until March 31, 1992, for a total
comment period of 76 days. The extension was announced by
letter to the requestor and in a newspaper advertisement in
the Indianapolis Star.
A Record of Decision was signed by the Regional Administrator
on June 30, 1992,' for the groundwater operable unit.
Two availability sessions were held on November 19, 1992, at
the Stout Field School to discuss site progress and discuss
results of completed sampling activities, including drum
removal activities near the Lime Pond.
A Public Meeting was held on August 4, 1993, at the Indiana
Government Center-South to present EPA's proposed plan for
the Comprehensive Environmental Response, Compensation and'
Liability Act (CERCLA) Areas operable unit (OU 2) and to
receive formal public comment. V
A public 'comment period of thirty days for the CERCLA Areas
proposed plan was originally planned, running from July 22,
1993, to August 22, 1993. Based on a written/request during
the original comment period, the comment period was extended
until September 7, 1993, for a total comment period of 45
days. The extension was announced by letter to the requestor
and in newspaper advertisements in the Indianapolis Star. The
comment period was further extended until September 22, 1993,
for a total comment period of 60 days. The extension was
announced by phone and confirmed by letter to the requestor
and announced to the general public by a newspaper
advertisement in the Indianapolis Star.
A Public Meeting was held on July 24, 1996, at the South
Wayne Junior High School to present EPA's proposed plan for
-------
operable units 3 and 4 and to receive formal public comment.
Paid newspaper advertisements announced the OU 3 and 4 FS and
proposed plan public meetings.
A public comment period of thirty days for operable units 3
and 4 ran from July 15, 1996, to August 14, 1996.
There were no substantive comments received by U.S. EPA during
the aforementioned public comment period on the proposed remedy
for operable units 3 and 4.
This Record of Decision presents the selected remedial action for
operable units .3 and 4 at the Reilly Tar and Chemical site in
Indianapolis, Indiana. Operable unit 3 addresses the "kickback
area", the area of former wood treatment operations. Operable
unit 4 addresses the "north process area", the area of current
specialty chemical production. This remedial action was chosen
in accordance with CERCLA, as amended by SARA, and the National
Contingency Plan. The decisions for these operable units at the
site are based on the Administrative Record.
Scope and Role of the Operable Unit
As with many Superfund sites, the problems at the site are
complex. The Remedial Investigation (RI) investigated five
distinct on-site source areas and groundwater. The RI determined
that groundwater had been contaminated by the site and is
migrating away from the site at levels that were determined by
the site Risk Assessment to pose unacceptable threats to human
health. The first operable unit action was selected by EPA to
stop further off-site migration of contaminated groundwater by
installing a groundwater extraction system/treatment system.
This action provided adequate time to study and remediate on-site
source areas as well as to prevent the further contamination of
area groundwater resources by contaminants migrating from the
Reilly site.
The second operable unit at the site addressed the five distinct
on-site source areas that were contributing to contamination of
both soils and groundwater. These areas were initially
investigated in the RI. The selected remedy for this operable
unit was the excavation and thermal treatment of soils from four
of these areas and the solidification of sludge with .placement of
a soil cover for the fifth area.
This Record of .Decision encompasses the third and fourth of five
operable unit remedial actions to be taken at the Site. A
-------
subsequent action will be taken which will be the final remedial
action taken at the site to address contaminated groundwater.
This final action will include an action to remediate groundwater
contaminated by the site that has migrated to off-site areas.
These operable units will be designed to address the direct
contact threats from potential exposure- to contaminated soils in
these areas as well as prevention of potential future leaching of
site contaminants to groundwater from these areas. These
operable units will be designed to be consistent with any and all
potential future 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. Because of the
size and complexity of the site, the RI was performed in three
distinct phases. The first phase focused on sampling off-site
commercial, industrial and residential wells to determine the
presence of and extent of off-site contamination. The second
phase concentrated on sampling activities to determine the extent
of contamination onsite so that site contributions to areal
contamination could be determined. The third phase concentrated
on collecting additional'on-site and off-site data to complete
the investigatory picture so that a Feasibility Study could be
started to address 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
- on-site geophysical surveys
- surface soil sampling, both onsite and off-site
- exploratory test pit excavation and sampling
- installation and sampling of groundwater
monitoring wells, both onsite and off-site
- surface water sampling, both onsite and off-site
- identification and sampling of existing
groundwater wells in the site vicinity
-------
- installation and sampling of soil borings
- a -surface water drainage study
- a water level monitoring program, both on-site
and off-site
- identification of groundwater contamination
sources within a one-mile radius of the Reilly
site
- hydraulic conductivity testing and the performance
of a short-term continuous water level monitoring
program
- preparation of a site-wide human health and
ecological risk assessment
Geology/Hydrogeology:
The Reilly site lies within the White River drainage basin,
located approximately three miles to the east of the river.
Eagle Creek is an attendant tributary and flows in a
southeasterly direction approximately 4000 feet to the east of
the site. Topography in the site area is relatively flat with a
gentle downward slope in an easterly direction. Other surface
water bodies in the site area include Blue Lake (a former gravel
pit) located approximately 2000 feet northeast of the site,
several small ponds or surface water impoundments located 2000 to
4000 feet east of the site, and one surface-water impoundment
located immediately southwest of the Maywood property (see Figure
2). The westernmost extension of Blue Lake has been filled in
since 1979.
The sand and gravel deposits that underlie almost all of the
White River drainage basin form the principal aquifer in the
area. There are three industrial well fields located to the east
of the site that have a reported combined pumping rate of 10
million gallons per day, or approximately 7000 gallons per minute
(see Figure 2). In the vicinity of the site, upper and lower
zones have been identified within the sand and gravel outwash
aquifer. At some locations, especially directly underneath the
site, these zones are separated by one or more till units which,
because of their silt content, are less permeable layers and may
impede flow vertically. . The lack of a continuous, fine grained
unit and similar groundwater levels in shallow and'deep wells
suggest that the upper and lower zones of the outwash sand and
gravel deposits are hydraulically connected and that the till
-------
units do not act as a barrier to contaminant flow in groundwater.
Regional hydrogeologic data indicate that groundwater in the
unconsolidated material in the area of the Reilly site flows east
towards Eagle Creek with a southerly component. Water level data
from the RI indicate that ground-water flow is generally from the
northwest to the southeast and that withdrawals from neighboring
industrial production wells significantly impact the flow of
groundwater east of the site. Hydraulic conductivities for wells
tested during the RI range from 10 (-2) to 10 (-3) centimeters per
second. An average linear groundwater velocity'of 0.68 feet per
day was calculated for the area that is not influenced by the
industrial pumping to the east of the site. An average linear
groundwater velocity of 2.0 feet per day was calculated for the
area that is influenced by the industrial pumpin'g.
SOIL CONTAMINATION
Operable Unit 3 addresses on-site areas of contamination in the
kickback area which have been designated as RCRA Solid Waste
Management Units (SWMUs) requiring investigation and corrective
actions pursuant to the 1992 amendment to -the 1987 administrative
order on consent requiring site studies. The Kickback area
consists of the northern portion of the Maywood property where
wood was treated with coal tar distillate and stored on the
ground prior to transport to customers. Tanks 17 and 18 are
located in the northwestern portion of the kickback area and are
used for wastewater accumulation and treatment as part of
Reilly's process water treatment system. The drum steam-out area
consists of a concrete area 80 feet by 80 feet with a six inch
high asphalt curb located south of th'e Tarpet building. This
area, which is used for steam cleaning drums, is located within
the northwest quadrant of the kickback area. The South API area
is located near the center of the Maywood property, northeast of
the former sludge treatment pit and within the kickback area.
The South API consisted of a concrete settling basin constructed
partially below grade and was used to remove solids from Reilly's
wastewater discharge (See Figure 3). These areas' have been
identified as either Areas of Concern or SWMUs under RCRA, and
investigations and corrective actions at these areas are required
under the 1992 amendment to the 1987 administrative order on
consent requiring studies at the site.
Soils in the kickback area are contaminated with volatile organic
contaminants to levels of 383,600 parts per billion (ppb).
Contaminants include pyridine and pyridine derivatives which
reach levels of up to 600,500 ppb, and polynuclear aromatic
hydrocarbons which reach levels of 10,683,000 ppb. It was
-------
FORMER
DRAINAGE
DITCH
ABANDONED RAILROAD
TRENCH (ALONG BLOG.)
"-FORMER Si
PIT (AROUl
TREATMENT
D PANS)
KICKBACK AREA
AREA OF FORMER WOOD
TREATING CYLINDERS
ENSR CONSULTING k ENCINEF.KIN
LEGEND
?00
200
SCALE IN FEET
1" - 200'-0"
400
KICKBACK AREA LAND THAT IS COVERED
WITH BUILDINGS. PAVEMENT, OR GRAVEL.
KICKBACK ADEA FEATURES
REILLY INlH 'i TRIES, INC.
INDIANAPOLIS. IN
K.P.B.
9/94
5660-024
-------
determined during the Remedial Investigation that these soils did
not pose a significant threat of leaching contaminants to the
groundwater.
Operable unit 4 addresses the following on-site source areas: the
north process area, Tank 66, and the process sewers. The north
process area is the area where specialty chemicals are currently
being manufactured. The area is occupied with structures such as
buildings, piping, and tanks associated with the manufacturing
operations. Open areas are either paved as roadways or covered
with gravel. The Tank 66 area is located within the north
process area along the west fence line of the Reilly property.
Tank 66 is a permitted hazardous waste storage tank. Several
pipe racks and two rail spurs are located within this area. The
process sewers are located under the entire facility and have
been found through prior investigations to be leaking.
Soils in the north process area are contaminated with volatile
organics which reach levels up to 19,010 ppb, pyridine and
pyridine derivatives which reach levels of 42,300 ppb, ammonia at
levels of 287 ppb, and cyanide at levels of 2.1,ppb. It was
determined during the Remedial Investigation that these soils did
pose a significant threat of leaching contaminants to the
groundwater.
GROUND WATER CONTAMINATION
Benzene concentrations in the groundwater found at the kickback
area and north process area range from below detection limits to
9400 ppb, with the highest levels detected on the Oak Park
property. Pyridine and pyridine derivative concentrations, which
were summarized in the RI as total pyridine derivatives, were
found in the groundwater ranging from below detection limits to
94,950 ppb, with the highest levels detected on the south-central
portion of the Oak Park property. Ammonia concentrations in the
ground water ranged from 0.1 parts per million (ppm) to 53.3 ppm
with concentrations greatest in the northwest portion of the Oak
Park property (see Figure 4 for a map of the benzene contaminant
plume).
SUMMARY OF SITE RISKS
This Record of Decision is written for two operable unit actions
to address the kickback area and the north process areas within
the site boundaries. The RI report includes a risk assessment,
prepared by Reilly 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.
10
-------
Benzene Plume
Minnesota St. \
Reilly Tar &
Chemical
Shallow Zone Concentrations
(Phase ill)
Deeper Zone Concentrations
(Phase III)
Contour line density does not permit
contouring of more elevated
concentrations
oEPA
js
-------
Risks from exposure to contaminated groundwater were summarized
in the ROD for the groundwater operable unit. Risks associated
with exposure to contaminated soils and sludges at the five
CERCLA areas were summarized in the ROD for the second operable
unit.
The risk assessment determined that the majority of risks
associated with exposure to soil contamination at the site were
attributed to- carcinogenic PAHs, pyridine and pyridine,
derivatives and volatile organics, such as benzene. Other
chemicals that were detected in site soils are also of concern,
but were not found at the same frequency as the above mentioned.
Concentrations of these chemicals in the groundwater have
resulted in unacceptable risks to human health and the
environment.
i ~
Exposure Assessment
The exposure assessment conducted as a part of the RI concluded
that several media are impacted by site contaminants, and that
there are several potential exposure routes for contamination.
These routes of exposure were identified for both current and
future scenarios (as is commonly done in EPA risk assessments) so
that all potential pathways can be evaluated. The baseline risk
assessment computed risks from exposure to these contaminants
using the upper 95% confidence intervals of the arithmetic mean
of the Phase II and III sampling data concentrations of the above
contaminants. The use of the confidence intervals is suggested
in the Risk Assessment Guidance for Superfund and represents a
conservative step towards assessing risks associated with
potential exposures. In some cases where sample results vary
widely or sample size is small, these confidence intervals may
exceed maximum detected concentrations.
Due to the proximity of the site to the surrounding neighborhood
and major streets, and its size, the following potential
receptors were identified in the risk assessment, and risks were
computed for their exposure.
Under the current land-use scenario, on-site workers could
potentially be exposed through ingestion and dermal contact with
surface soils, and inhalation of vapors from the contaminated
soils. On-site construction workers could potentially be exposed
through ingestion and dermal contact with surface and subsurface
soils, and inhalation of vapors from the contaminated soils.
A trespassing teenager could potentially be exposed through
ingestion and dermal contact with surface soils, and inhalation
of vapors from the contaminated soils.
11
-------
Under the future-use scenario, on-site workers could potentially
be exposed through ingestion and dermal contact with surface
soils, and inhalation of surface soil and dust (Maywood) and
subsurface soils (all areas) (workers may be exposed to on-site
dust generated during intrusive construction activities). On-
site construction workers could potentially be exposed through
ingestion and dermal contact with surface and subsurface soils
(industrial facility construction on the Maywood property).
Toxicity Assessment
Benzene is classified as a known human carcinogen (Class A) and
has been associated with hematologic effects on humans as well as.
anemia (decreased red blood cells), leukopenia (decreased white
blood cells), and thrombocytopenia (decreased platelets).
Chronic exposure has been shown to cause pancytopenia (decrease
in all circulating cells) and aplastic anemia (failure to
manufacture blood.cells). Exposure by inhalation has been shown
to cause leukemia. Benzene has been shown to be a growth
inhibitor in utero; however, it has not been shown to be
teratogenic (causing birth defects). Animal studies have shown
preliminary evidence of carcinogenicity; a link-to leukemia via
inhalation has also been suggested. Benzene has been shown to be
nonmutagenic (not causing mutations); benzene oxide, the presumed
initial metabolite of benzene, is mutagenic (causing mutations).
r.'
Limited data exists on the oral absorption of pyridine; data on
the pulmonary and dermal absorption of the chemical was not
located. Available evidence indicates that pyridine is well
absorbed rapidly from the GI tract and is not expected to
accumulate in the body. Available information from animal
testing does not suggest that lethality is a human health concern
for exposure to pyridine by inhalation or ingestion. The major
human health -concern is for liver damage, based "on recent studies
with laboratory rats. Other human health concerns include the
potential for neurologic effects and kidney effects. Pyridine
has been administered to mice and rats in order to evaluate the
potential carcinogenicity of pyridine. The studies have
concluded that pyridine did not produce increases in the
incidence of tumors with respect to controls. EPA has decided
that increased liver weight in female rats is the most sensitive
toxic endpoint.
Ammonia has been shown to cause deleterious effects in acute
exposures. Irritation of the eyes, nose, throat and chest are
associated with exposure to ammonia. Ingestion can cause
gastritis and corrosive esophagitis. Exposure to high
concentrations of ammonia gas can cause pulmonary edema or death.
12
-------
Ammonia has also been shown to cause negative effects to the
respiratory tract, labored breathing, eye irritation,
inflammatory lung changes, and death to many animal species.
Both the Integrated Risk Information System (IRIS-1989) and the
Health Effects Assessment Summary Table (HEAST-1990) were used as
sources for this contaminant toxicity data.
Polynuclear Aromatic Hydrocarbons (PAHs) are absorbed
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
PAH containing materials and increased cancer risk. The
following PAHs have been classified as potentially carcinogenic -
Class B2: benzo (a) pyrene; benzo (a) anthracene; dibenzo (a,h)
anthracene; benzo (b) fluoranthene; benzo (k) fluoranthene;
indeno (1,2,3-cd) pyrene; chrysene.
Risk Assessment
Carcinogenic risks described in the risk assessment for exposure
to contaminated soil at the north process area were computed for
several potential exposure scenarios (See Tables 1 and 2). These
include onsite worker (current risk - 7.3 x 10(-7)), on-site
worker (future risk - 1.29 x 10(-4)), construction worker
(current risk - 5.5 x 10 (-7)), construction worker (future risk -
1.29 x 10(-4)). The chemical class causing the majority of the
estimated cancer risks was carcinogenic PAH (See Tables 1 and 2).
During the RI, it was determined that there was no significant
risk to the environment from site contamination. The absence of
a suitable habitat for wildlife and the absence of any
significant onsite surface water accumulations provided the
justification for this conclusion. By implementation of-the
remedies in this ROD, impacts to the environment*will also be
minimized or eliminated.
Description of Alternatives
During the Feasibility Studies for Operable Units 3 and 4 (FS),
Reilly identified and evaluated alternatives that could be used
to address the threats and/or potential threats to human health
and the environment posed by the site. These alternatives have
several components including site preparation, institutional
controls, such-as fencing, deed restrictions, and groundwater
monitoring, and surface controls, such as surface water
.13 ' •
-------
TABLE 7-14
SUMMARY OF TOTAL ESTIMATED INCREMENTAL CARCINOGENIC RISKS ASSOCIATED WITH THE KICKBACK - PRODUCTION AREA
CURRENT SCENARIO
REILLY - INDIANAPOLIS
HUMAN HEALTH RISK ASSESSMENT
IS3
cn
Compound
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZENE
BENZO(G.H,I)PERYLENE
DIBENZOFURAN
ETHYLBENZENE
FLUORANTHENE
FLUORENE
3,4-DIMETHYL PHENOL
NAPHTHALENE
PHENANTHHENE
PYRENE
TOTAL PYRIDINES
TOLUENE
XYLENES
1 -METHYLNAPHTHALENE
2-METHYLNAPHTHALENE
TOTAL BAP-TE
TOTAL CPAH
TOTAL
: Total Potential Carcinogenic Risk tor
..: . :.:;•..';• -:•:':'.'• .^ ; ; , : ; ' I; «i» Curnnt On-Slt» Work«
NC
. NC
NC
2.1E-10
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
2.1E-07
NC
2.1E-07
Total Potential Carcinogenic Rl*k tor
••-..:' ..... . ....;: :...; . tho Curr»nt Con»tructlon Worktr
NC
NC
NC
7.3E-1 1
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
7.9E-07
NC
7.9E-07
Notes:
NC - Not Calculated.
R.N.: 2
Source: ENSR 1994
23-Mar-94
CSKTOT.WQ1
N
-------
TABLE 7-16
SUMMARY OF TOTAL ESTIMATED INCREMENTAL CARCINOGENIC RISKS ASSOCIATED WITH THE KICKBACK - NON-PRODUCTION AREA
CURRENT SCENARIO
REILLY - INDIANAPOLIS
HUMAN HEALTH RISK ASSESSMENT
Compound
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZENE
BEN2O(G,H.I)PERYLENE
DiBENZOFURAN '
ETHYLBENZENE
FLUORANTHENE
FLUORENE
3,4-DIMETHYL PHENOL
NAPHTHALENE
PHENANTHRENE
PYRENE
TOTAL PYRIDINES
TOLUENE
XYLENES
1 -METHYLNAPHTHALENE
2-METHYLNAPHTHALENE
TOTAL BAP-TE
TOTAL CPAH
TOTAL
Total Potential Carcinogenic Rl«k for
the Current On-Slte Worker
NC
NC
NC
2.0E-10
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
7.3E-07
NC
7.3E-07
Total Potential Carcinogenic Risk for
the Currant Construction Worker
k
NC
NC
NC
1.8E-10
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
1 .OE-07
NC
1. OE-07
Total Potantlal Carcinogenic Risk tor
the Current Trespassing Teenager
NC
NC
NC
3.9E-11
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
3.7E-07
NC
3 7E-07
Notes:
NC - Not Calculated. •
RN :0
Source: ENSR 1994
25-Mar-94
CSKNPTOT.WQ1
-------
TABLE A-1
INDUSTRIAL WORKER: SUMMARY OF POTENTIAL CARCINOGENIC RISK FROM INCIDENTAL INGESTION OF AND DERMAL CONTACT WITH ON-SITE SURFACE SOIL
FUTURE SCENARIO
REILLY - INDIANAPOLIS
HUMAN HEALTH RISK ASSESSMENT
Compound
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZENE
BENZO(G,H.I)PERYLENE
DIBENZOFURAN
ETHYLBENZENE
FLUORANTHENE
FLUORENE
3.4 DIMETHYL PHENOL
NAPHTHALENE
PHENANTHRENE
PYRENE
TOTAL PYRIDINES
TOLUENE
XYLENES
1 METHYLNAPHTHALENE
2 METHYLNAPHTHALENE
TOTAL BAP-TE
TOTAL CPAH
TOTAL
Tar* 17 til .ATM
Ourfaccdot
RMt
NC
NC
NC
1.46E-09
NC
NC
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
NC
7.40E-05
NC
7.40E-05
South API &»pirat6r
Surf ac* Sol
RWt
NC
NC
NC
1.01E-11
NC
NC
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
NC
1.40E-05
NC
1.40E-05
Drum 8t*arn Out
Surf ac* Sol
Rtok
ND
ND
ND
ND
NC
ND
NC
NC
ND
ND
NC
NC
NC
NC
NC
NC
ND
* NC
5.34E-07
NC
5.34E-07
:' Kickback -Produitton
8urMc«6ol
NC
NC
NC
8.78E-11
NC
NC
NC
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
NC
1.29E-04
NC
1.29E-04
" ! Kickback - Mon-Produetfon
w*k
NC
NC
NC
2.B3E-10
NC
NC
ND
NC
NC
ND
NC
NC
NC
NC
NC
NC
NC
NC
1.19E-05
NC
1.19E-05
North Proc*«» Area
8urfao«8ol
Nik
NO
ND
ND
3.79E-08
ND
ND
NC
ND
ND
ND
ND
ND
NO
NC
NC
NC
ND
ND
ND
NO
3.79E-08
Tank ec Area
8urr*c*8ol
fltok
ND
ND
ND
607E-10
ND
ND
NC
NC
ND
ND
ND
NC
NC
NC
NC
NC
ND
ND
6.55E-07
NC
S.BSE-07
Noies: . .
NC - Not Calculated. ,
RN.:0 09-Sep-94 ' " L.
Source: ENSR 1994 TOnABLE.WQI 09-S«p-94
^_
J
0
r
§
-------
TABLE A 2
INDUSTRIAL WORKER: SUMMARY OF POTENTIAL NONCARCINOGENIC HAZARD INDEX
FUTURE SCENARIO
REILLY - INDIANAPOLIS
HUMAN HEALTH RISK ASSESSMENT
FROM INCIDENTAL INQESTION OF AND DERMAL CONTACT WITH ON-SITE SURFACE SOIL
Compound
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZENE
BENZO(G,H.I)PERYLENE
DIBENZOFURAN
ETHYLBENZENE
FLUORANTHENE
FLUORENE
3.4 DIMETHYL PHENOL
NAPHTHALENE
PHENANTHRENE
PYRENE
TOTAL PYRIDINES
TOLUENE
XYIENES
1 METHYLNAPHTHALENE
2 METHYLNAPHTHALENE
TOTAL BAP-TE
TOTAL CPAH
TOTAL
Tank 17 Ai« ATM
HI
3.22E-06
5.27E-07
1.33E-06
NC
3.42E-05
466E05
201E^)B
3.52EO5
8 31 E 06
ND
2.34E-06
5.29E46
4.60E05
1.50E-03
1.85E-08
7.00E-08
1.40E46
1.77E-06
NC
1.57E-04
1.85E-03
South API 8»p*r«t«r
HI
3.81E06
6.34E-08
4.86E-06
NC
9.60E-05
6.19E-05
3.71 E 09
1.02E-04
7.74E-06
ND
7.25E-06
7.36E-06
1.43E-04
4.50E-03
5.57E09
1.34E09
2.91E-06
5.87E-06
NC
6.92E-04
5.64E-03
DrumdUamOuk
Ml
ND
ND
ND
ND
3.81 E-06
ND
2.60E-OB
5.B2E-06
ND
ND
1.38E-05
5.52E-07
B.54E-06
2.74E-03
2.79E-08
7.66E-09
ND
1.18E-4B
NC
2.75E-05
2.81E-03
Kickback •Production
8urfac»8o*
HI
3.62E04
1.12E05
4.20E-05
NC
1.78E-04
3.40E-03
1.07E-07
8.00E04
5.55E-04
ND
1.47E-03
2.09E-04
7.14E-04
9.14E-03
3.95E-08
525E-08
1.95E-04
3.54E-04
NC.
1.22E-03
1.87E*2
11 Rlckback - Hon-ProducUon
8Ufac«6ol
Ml
5.13E-07
2.17E-06
5.91 E-07
NC
3.19E-05
1.88E-05
ND
2.22E-O5
8.58E07
ND
503E-06
1.77E06
3.67E05
6.98E-04
1.39E08
1.90E-09
1.06E-08
1.60E-06
NC
1.64E-04
9.85E-04
North Proem* ATM
Surrae* Sol
HI
ND
ND
ND
NC
ND
ND
1.52E-06
ND
ND
ND
ND
ND
ND
3.92E4)2
1.00E07
6.51 E-07
ND
ND
ND
ND
3.92E-02
HI
ND
ND
ND
NC
ND
ND
929E08
306E-06
ND
ND
ND
296E-07
315E06
366E-02
1.30E08
2.68E-OB
ND
ND
NC
2.57E-05
366E-02
Noies:
NC - Not Calculated.
Source: ENSR 1994
TOTTABLE.WQ1
09 S«p-94
2
CJj>
-------
Phase 4
North Process Area
Phase 3
Kickback Area
&EPA
-------
collection and soil erosion control measures. The purpose of the
groundwater monitoring is to monitor the performance of the
remedial action over time and its effectiveness at remediating
contamination present in the operable unit areas.
The kickback area and the north process area have been further
subdivided into smaller areas based on the results of RI
sampling. These smaller areas are highlighted on Figure 5 and
represent localized areas of elevated soil contamination referred
to as hot spot areas. However, these smaller areas have been-
identified and segregated based on results from single sampling
points. Consequently, they cannot be classified as true hot spot
areas, because contamination is not present in discrete, large
volume, concentrated areas. The difference between the kickback
area and the north process area is that soils in the latter area v
pose a significant threat to groundwater through leaching while
the soils in the kickback area do not pose a significant threat
to groundwater through leaching. Soils in both areas do pose
significant threats through direct contact with contaminated
soils. .....'
The alternatives evaluated for site cleanup for operable units 3
and 4 address some or all of these smaller areas due to
differences in subsurface conditions present in the sampling
areas and different depths of contamination. The alternatives
evaluated for operable units 3 and 4 are presented below.
hi
OPERABLE UNIT 3
Eight alternatives were evaluated during the detailed analysis of
alternatives in the FS (See Table 3). These included no action;
permeable (soil and gravel) cover; asphalt/concrete cover;
excavation and thermal desorption; in-situ and ex-situ land
farming; in-situ solidification; multi-layer cover; and soil
vapor extraction, as described below (See Table 3).
Alternative 1; No Action
Under this alternative, no remediation would occur and the site
would remain in its present condition. Future land use at the
Kickback Area would be limited to industrial use by institutional
controls consisting of deed restrictions and access controls.
Existing gravel covers would be maintained by monthly inspections
and replaced as needed. Quarterly monitoring of groundwater
quality is currently being performed both upgradient and
downgradient of the Kickback area to monitor the perimeter
groundwater extraction system. In addition, groundwater within
the Kickback area would be monitored annually. This alternative
14 • .-. - :
-------
ALTERNATIVES FOR
PHASE 3 f Kickback AreaJ
Alternative I No Action fAII AreasJ
Alternative 2 Permeable Cover
fSoil & Gravel - All AreasJ
Alternative 3 Asphalt/Concrete Cover f Areas F & GJ
Alternative 4 Excavation & Thermal Desorbtion
f Areas B, C, D, E, F 8e Gj
-
rr\
-------
\
ALTERNATIVES FOR
PHASE 3 ("Kickback flreaJ
Alternative 5 In-Situ and Ex-Situ Land Farming
f Areas A, B, C, D, F & GJ
Alternative 6 (n-Situ Solidification fArea Ej
Alternative 7 Multi-Layer Cover f Areas A & Cj
Alternative 8 Soil Vapor Extraction
f Areas A, C, F & GJ
C:
•h
-------
would apply to all areas in the kickback area shown on Figure 5.
Present Worth Cost $200,000
Time to Complete Immediate
Alternative 2; Permeable (Soil and Gravel) Cover
Under this alternative, a vegetated soil cover would be
constructed over the portion of the Kickback Area that is not
currently covered with gravel. The existing gravel layer covers
approximately 80 percent of this area. This layer would consist
of six inches of topsoil with vegetation established to minimize
erosion. Gravel cover in areas that are currently covered with
gravel would be maintained with this requirement formally stated.
Future land use would be limited to industrial use by deed
restrictions. Quarterly monitoring of groundwater quality is
currently being performed at upgradient (west to northwest) and
downgradient (east to southeast) wells for monitoring of the
perimeter extraction system. In addition, groundwater within the
Kickback area would be monitored annually.
Present Worth Cost $ 460,000 ,
Time to Complete 4 months
Alternative 3: Asphalt/Concrete Cover (Hot Spot Areas)
Under this alternative, an asphalt or concrete cover would be
constructed over Hot Spot Areas F and G. The FS also analyzed
this alternative for placement over the entire kickback area,
including the rest of the identified hot spot areas. This
discussion is not included due to the impracticality of
constructing a cover over the entire kickback area. These areas
would be covered with six inches of gravel and then covered
either with asphalt or concrete. Future land use would be
limited to industrial uses by deed restrictions. Quarterly
monitoring of groundwater quality is currently being performed, at
upgradient and downgradient wells for monitoring of the perimeter
groundwater extraction system. In addition, groundwater within
the Kickback Area would be monitored annually.
Present Worth Cost $ 1,140,000
Time to Complete . 3 months
Alternative 4: Excavation and Thermal Desorption (Hot Spot
Areas)
Under this alternative, soil from Hot Spot Areas A, B, C, D, E,
F, and G within the Kickback area would be excavated and
15
-------
thermally treated to remove contaminants. Thermal desorption
units separate organic contaminants from soil by increasing
volatilization through heating. Thermal desorption is currently
planned for the second operable unit of the Reilly cleanup.
Future land use would be limited to industrial uses by deed
restrictions. Quarterly monitoring of groundwater quality is
currently being performed at upgradient and downgradient wells
for monitoring of the perimeter groundwater extraction system.
In addition, groundwater within the Kickback Area would be
monitored annually.
Present Worth Cost $5,500,000
Time to Complete 8 months
Alternative 5; In-Situ and Ex-Situ Land Farming (Hot Spot Areas)
Land farming is a solid phase bioremediation method that consists
of treatment of contaminants in soils either in-situ, where the
soil is treated in place, or ex-situ, where the soil is excavated
and treated in a different location. In-situ land farming
consists of deep tillage of the surface soils in.the designated
area to a depth of two feet to aerate the soil and add nutrients
to the soil as necessary; monitoring of soil moisture; with
irrigation if needed to maintain optimal biodegradation
conditions. In-situ land farming would be implemented at Hot
Spot Areas A, B, C, D, F, and G.
Ex-situ land farming is performed in the same manner as in-situ
land farming, except the soil undergoing treatment is excavated
and moved to an unlined treatment cell. Ex-situ. land farming is
appropriate for contamination that is too deep to be treated in
place, which is present in Hot Spot Area E. Once excavated, the
soil can'be spread out in a two-foot thick layer and treated in
the manner described for in-situ land farming. The unlined
treatment cell would be situated on the southern half of the
Maywood property. Ex-situ land farming would be implemented in
Hot Spot Area E.
Present Worth Cost $ '4,500,000
Time to Complete 3 to 4 years
Alternative 6; In-situ Solidification (Hot Spot Areas)
•Under this alternative, subsurface soils in Hot Spot Area E would
be treated by a method referred to as shallow soil mixing. This
alternative was selected for analysis for this hot spot area due
to the depth of contamination present. Shallow soil mixing
utilizes a crane-mounted drill attachment which turns a single
16
-------
shaft, large diameter augur. As the augur head is advanced into
the soil, grout is injected into the soil. The cutting edges and
mixing blades blend the soil and grout in place. The grout
solidifies the soil making the contaminants in the soil immobile.
Present Worth Cost $ 1/160,000
Time to Complete . 3 months
Alternative 7; Multi-Layer Cover (Hot Spot Areas)
Under this alternative, a multi-layer cover consisting of a sand
bedding layer, a high density polyethylene geomembrane, a
drainage layer, and a topsoil layer would be installed over Hot
Spot Areas A and C. Future land use would be limited by deed
restrictions. This alternative was determined to be not
applicable in the other hot spot areas due to the presence of
chemical manufacturing process equipment that would interfere
with cap installation and potentially compromise the long term
reliability of the cover.
Present Worth Cost $920,, 000
Time to Complete 4 weeks
Alternative 8; Soil Vapor Extraction l
Soil vapor extraction (SVE) is an in-situ treatment which
consists of one or more extraction wells installed for the
purpose of withdrawing soil gas. The air flow enhances the
volatilization of contaminants dissolved in pore water and the
movement of contaminants from the surfaces of the soil particles
allowing contaminants to be extracted from the soil. SVE would
be used at Hot Spot Areas A, C, F and G. This alternative was
not applicable to the other hot spot areas due to the presence of
contaminants in the soils that are not amenable to soil vapor
extraction treatment and the presence of chemical manufacturing
process equipment. -
Present Worth Cost $1,180,000
Time to Complete 4 years
OPERABLE UNIT 4
Three alternatives were evaluated during the detailed analysis of
alternatives in the FS/CMS (see Table 4). These included no
action; asphalt/concrete cover; and soil vapor extraction as
described below.
Alternative 1: No Action
17
-------
ALTERNATIUES FOR
PHASE 4 fNorth Process AreaJ
Alternative 1 No Action fAll areasj
Alternative 2 Asphalt/Concrete Cover fArea CJ
Alternative 3 Soil Vapor Extraction fArea A & Bj
-------
Under this alternative, future land use at the North Process Area
would be limited to industrial use by institutional controls
consisting of deed restrictions. Qua'rterly monitoring of
groundwater quality is currently being performed at upgradient
and downgradient wells for monitoring of the perimeter
groundwater extraction system. In addition, groundwater within
the North Process Area would be monitored annually.
Present Worth.Cost $ 110,000
Time to Complete Immediate
Alternative 2; Asphalt/Concrete Cover (Hot Spot Areas)
Under this alternative, an asphalt or concrete cover would be
constructed over Hot Spot Area C. The North Process Area is
already partially paved with asphalt roads and concrete
foundations. The remaining areas have an existing gravel cover
which would be graded and paved to match existing pavement.
Quarterly monitoring of groundwater quality is currently being
performed at upgradient and downgradient wells for monitoring of
the perimeter groundwater extraction system. In addition,
groundwater within the North Process Area would be monitored
annually. This alternative was also analyzed in the FS for Hot
Spot Areas A and B.
Present Worth Cost $ 460,000
Time to Complete 6 weeks
Alternative 3: Soil Vapor Extraction
Soil vapor extraction (SVE) is an in-situ treatment which
consists of one or more extraction wells installed for the
purpose of withdrawing soil gas. The air flow enhances the
volatilization of contaminants dissolved in pore water and the
movement of contaminants from the surfaces of the soil particles
allowing contaminants to be extracted from the soil. SVE would
be used at Hot Spot Areas A and B. This alternative was also
analyzed in the FS for Hot Spot Area C.
Present Worth Cost $ 760,000
Time to Complete 4 years
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES FOR OPERABLE
UNIT 3
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;
18
-------
compliance with applicable or relevant and appropriate
requirements (ARARs); long-term effectiveness; reduction of
toxicity, mobility, or volume; short-term effectiveness;
implementability; cost; state acceptance; and community
acceptance. Based on evaluation of the alternatives with respect
to these nine criteria, U.S. EPA has selected Alternative 2 -
Permeable (soil and gravel) Cover as the alternative for the
cleanup for Operable Unit 3 at this Site.
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.
All of the alternatives would reduce the potential impacts of
contamination on human health and the environment. Alternatives
1, 7, and 8 would not be fully protective because- they do not
address all of the contaminated areas. Alternatives 2 and 3
would reduce the threats to human health and the environment
through the placement of a cover over the contaminated soils,
Alternatives 2 and 3 would reduce contaminant mobility via
erosion and fugitive dust emissions.
Pilot testing is needed before a final determination can be made
regarding Alternative 5; however, it appears that Alternative 5.
provides similar levels of protection as Alternatives 4 and 6.
Alternative 4, because it separates contaminants from the soils
would the most protective because it provides the greatest
reduction in -the toxicity, mobility and volume of contaminants.
The reduction in contaminant toxicity and volume is provided
through offsite disposal of treatment residuals. However, this
alternative would also increase risks in the short term due to
the excavation and treatment of the contaminated soils.
Alternative 6 does not provide for destruction of contaminants
through treatment. However, the solidification process
immobilizes the contamination in the soil, thus reducing
contaminant mobility.
Alternative 1 does not protect human health and the environment
because it does not reduce risks associated with exposure to
contaminated,soils.
Therefore, since it has been determined that Alternative 1 would
19
-------
not be protective of human health and the environment or meet
ARARs, it will no longer be considered in the nine criteria
evaluation. Alternatives 2, 3, 4, 5, and 6 are considered
functionally equivalent with respect to this threshold criterion.
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 alternatives are capable of meeting ARARs. ARARs for
Alternatives 2, 3, 5, 6, and 7 are similar to ; one another and
relate to health and safety, erosion control, dust emissions, and
storm water discharge. ARARs for Alternatives 4 and 8 include the
above as well as those specific to the thermal treatment
technology, including ARARs relative to the treatment, storage,
transportation and disposal of hazardous waste, and air emission
requirements (See Table 5).
Therefore, it has been determined that Alternatives 2, 3, 4, 5, 6,
7, and 8 are functionally equivalent with respect to this threshold
criterion, because of their individual ability to meet the ARARs
appropriate to each alternative.
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.
Alternatives 4, 5, and 8 would provide the greatest long term
effectiveness and permanence; however, Alternative 4 would
generate significant quantities of hazardous waste in the' form of
condensed organics and filter media which would need to be recycled
or disposed off-site. Alternatives.2, 3, 6, and 7 would be capable
of effectively controlling site risks over the long term. However,
these alternatives would leave the contaminated soils in place.
The relative long term effectiveness of Alternatives 2 and 3 would
be dependent on the durability of the covers and caps. Alternative
6 would be effective over the long term; however, it would leave
'contaminated soils in place. Alternative 6 would be effective over
the long term considering the strength of the concrete matrix which
would isolate contaminants from potential human exposure. However,
the long term- reliability of this technology Is questionable
without extensive long term monitoring and operation and
20
-------
TABLE 3-1
Federal and State ARARs for Soil Remedies
CO
CO
00
f ype of R«(wlreii)«n||ip!^ AP^^^h> Air«metJve« ,
Waste Classification for Treatment Residues from
Thermal Desorption
On-Site Packaging and Storage of Hazardous
Treatment Residues from Thermal Desorption
Transportation of Hazardous Treatment Residues from
Thermal Desorption
Disposal of Hazardous Treatment Residues from
Thermal Desorption
Erosion Control for Containment
Point Source Discharge Requirements for Containment
Federal ARAB
T '•>•}<. * '> -. ft
40 CPR, Part 261: Identification and Listing of
Hazardous Waste, Subparts A (General), B
(Criteria), C (Characteristics), and Appendices.
40 CFR, Part 264: Standards for Owners and
Operators of Hazardous Waste Treatment, Storage,
and Disposal Facilities
40 CFR, Part 262; Standards Applicable to
Generators of Hazardous Waste
40 CFR, Part 262; Standards Applicable to
Generators of Hazardous Waste
40 CFR, Part 263; Standards Applicable to
Transporters of Hazardous Waste
40 CFR Part 268; Land Disposal Restrictions
Governed by the U.S. Dept. of Agriculture
State ARAR
329 IAC Article 3.1 , Rules 1 , 4-6.
329 IAC Article 3.1, Rule 9.
329 IAC Article 3.1, Rule 7.
329 IAC Article 3.1, Rule 7.
329 IAC; Article 3.1. Rule 8
Indiana Code Sections 8-2.1-18-36:
Transportation of Hazardous Materials
329 IAC Article 3.1, Rule 12.
327 IAC Article 15, Rule 6: Stormwater
Discharge Associated with Industrial
Activity
H \PUBS\PROJECTSaa80024\230A 3T
M«y. !»««
-------
TABLE 3-1 (Cont'd)
Federal and State ARARs for Soil Remedies
fyp» of fttK}
-------
TABLE 3-1 (Cont'd)
Potential Federal and State ARARs for Soil Remediation
CO
l^«fW^fH$ ^
AppU0$b1#: AttBfilttt jv$& %
% * "5 • ' ' :
Air Emissions Requirements (all
alternatives)
Air Emissions Requirements for SVE
Wastewater Discharge Requirements
for SVE
Health & Safety (all alternatives)
f«*fer«| AfJAR
40 CFR 50.6
Particulate Emission Standards
Code of Federal Regulations:
CFR 1910, 1926, 1904
Occupational Safety and Health
Worker Health and Safety Requirements
State ARAR
326 IAC; Air Pollution Control Board
Regulations Article 6-4, 6-5
Fugitive Dust Emissions Standards.
326 IAC Article 2-1: Permit Review Rules
327 IAC Article 2, Rule 1-7: Indiana Water
Quality Standards
327 IAC Article 5: NPDES Permits
327 IAC Article 8; Rules 1 & 2: Public
Water Supply
\r\
R \PUBS\PHOJECTS\5660024\230.3T
May, t»8t
-------
maintenance activities. Alternatives 7 and 8 would not be entirely
effective in the long term due to the fact that they do not address
all of the contamination present in soils in the kickback area.
Therefore, it has been determined that Alternatives 2, 3, 4, 5, and
6 are equivalent with respect to this balancing criterion and are
superior to Alternatives 7 and 8 because they address more of the
contaminated soils present in the kickback area.
Reduction of Toxicity, Mobility or Volume
Addresses the anticipated performance of the treatment technologies
a remedy may employ.
Alternatives 4 and 8 provide the greatest reduction in the
toxicity, mobility and volume of contaminants present in kickback
area soils. Alternative 4 provides a high degree of contaminant
removal, with contaminants being transferred to condensate or
filter media, which would be recycled or disposed of off-site.
Alternative 5 would provide for on-site, permanent destruction of
contaminants but its effectiveness would need to be documented
following treatability studies. Alternatives 2,-3, and 7 would not
reduce the toxicity or volume of contaminants but would reduce
mobility resulting from erosion or airborne dust. Alternatives 2,
3, and 7 would be effective at reducing the mobility of
contaminants by reducing groundwater infiltration. However, this
reduction would be achieved through the use of engineering
controls, not through treatment. Alternative 6 would reduce the
mobility of contaminants through solidification of the contaminated
soil but would not reduce the toxicity, and would increase the
volume through the mixing process.
Therefore, it has been determined that Alternatives 4 and 8 are
functionally•equivalent with respect to this balancing criterion
and superior to Alternatives 2, 3, and 7 because of the contaminant
reduction capabilities. .
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 implementatibn period, until
cleanup standards are achieved.
Alternatives 4 and 5 result in significantly higher short term
exposures when compared to the other alternatives due to their
extensive materials handling components. Excavation and tilling of
contaminated soil would release volatile and semi-volatile
21
-------
chemicals to the air. Contaminants could also be released to the
air on dust particles which could contact site workers and area
residents. Alternative 5 could result in higher short term
exposures than Alternative 4 because larger areas of soil would be
exposed at any one time. Alternative 6 may result in higher short
term exposures as a result of workers being involved in the shallow
soil mixing process and coming into contact with contaminated soil.
These increased short term risks could be lessened through the use
of engineering controls, worker safety procedures, and access and
land use restrictions.
Alternatives 2, 3, 7, and 8 result in the least p-dtential exposure
to human health and the environment becaus'e the remedial actions
call for covering contaminated soils, which minimized potential
contact with surface and subsurface soils.
Therefore, it has been determined that Alternatives 2, 3, 7, and 8
are functionally equivalent with respect to this balancing
criterion and are superior to Alternatives 4, 5, and 6, because
their implementation would result in the least potential exposure
to contaminated soils during construction.
Implementabi1i ty
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.
Alternatives 2 and 3 would be easy to implement. The necessary
materials, equipment and specialists for each of the cover/capping
alternatives would be readily available. Numerous vendors would be
available to perform the work. The implementability of Alternative
5 would need to be determined following treatability studies
necessary to establish treatment parameters. Alternatives 4 and 5
would be more difficult to implement, mainly due to excavation and
materials handling requirements. Alternative 6 would be relatively
easy to implement, although a treatability study should be
performed to determine optimum types and quantities of reagents for
solidification. Alternative 7 and 8 would be more difficult to
implement. Traffic in Reilly's manufacturing areas would have to
be rerouted and access controls maintained to prevent damage to the
multi-layer cover. Pilot scale tests would be necessary to confirm
the feasibility of SVE for each remediation area, and offsite
'disposal of hazardous wastes might have to be arranged.
Alternatives 7 and 8 require more careful engineering and
construction, but the necessary technologies, specialists, and
equipment would be readily available.
22
-------
Therefore, it has been determined that although Alternatives 2, 3,
4, 5, 6, I, and 8 are functionally equivalent with respect to this
balancing criterion, Alternatives 2 and 3 are slightly easier to
implement because they use readily availabl technology and
materials and do not involve handling contaminated soil or cause
potential interferences with Reilly's operations.'
Cost
Included are capital costs, annual operation and maintenance costs
(assuming a 30 year time period) , and net present value of capital
and operation and maintenance costs. The selected remedy must be
cost effective.
The present worth costs of Alternatives 2, 3, 6, 7, and 8 are low,
ranging from $460,000 for the permeable cover to $1,180,000 for
soil vapor extraction. Present worth costs for Alternative 4 and
5 are higher than those for the other alternatives, ranging from
$4,500,000 for Alternative 5 to $5,500,000 for Alternative 4.
Therefore, based on analysis of the costs associated with all of
the alternatives analyzed in the FS, it appears that Alternative 5
has the lowest present worth cost for the treatment alternatives,
and Alternative 2 has the lowest present worth cost for the
containment alternatives.
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 technical decisions, and concurs with the
selection of Alternative 2 as the selected remedy for this operable
unit soil cleanup at the site.
Community Acceptance
Addresses the public's general response to the remedial
alternatives and proposed plan. • Ł
Throughout the RI/FS at the site, community involvement has been
moderate, U.S.'EPA has been accessible and responsive to community
concerns throughout the study. At the public meeting for the
23
-------
proposed plan, the majority of those in attendance were in favor of
Alternative 2 as the most appropriate choice for the soil'cleanup.
Protection from contaminated soil in the most unobtrusive manner
possible was the primary reason for the citizen support for this
remedy. These same citizens also understood that the primary risk
associated with soils in the kickback area were from direct contact
with contaminated soils and that the there was not a significant
threat to groundwater from contaminant leaching.
In summation, Alternative 1 is unacceptable for protection of human
health and the environment. Alternatives 2 and 3 would not reduce
the toxicity or volume of contaminants through treatment, however,
soil contamination would decrease naturally over many years.
Alternatives 4 and 5 would increase risks in the short term due to
soil excavation and operation of the thermal treatment system.
Alternatives 6, 7, and 8 are not entirely effective because they do
not address all of the contamination present in the hot spot areas
of the kickback areas. Alternatives 2 and 3 are much more cost
effective than Alternatives 4 and 5, while, providing similar levels
of protection against direct contact with soils and providing less
risk in the short term because they cover the contamination rather
than excavating and treating it. Alternatives 2 and 3, when
combined with the perimeter groundwater extraction system currently
in operation, will provide complete protection of human health and
the environment. Finally, Alternative 2 is more cost effective
than Alternative 3, and when combined with an enforceable
institutional control, will provide complete protection from
contaminants present in the kickback area.
Therefore, the best balance among the eight alternatives is
Alternative 2, Permeable (Soil and Gravel) Cover.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES FOR OPERABLE
UNIT 4
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; short-term effectiveness; implementability; cost; state
acceptance; and community acceptance. Based on evaluation of the
alternatives with respect to these nine criteria, U.S. EPA has
selected Alternative 2 - Asphalt/Concrete Cover, for hot spot area
C, and Alternative 3 - Soil Vapor Extraction, for hot spot' areas A
and B, as the alternatives for the cleanup for Operable Unit 4 at
this Site. .
24
-------
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 3 is the most protective because it treats soils to
permanently remove contaminants, thus eliminating the potential for
exposure to contaminated soil and eliminating the migration pathway
to groundwater. Alternative 2 would effectively reduce exposure to
contaminated soil and migration of contaminants into the
groundwater. Since this alternative would not include removal of
contaminants, adverse impacts to human health and the environment
during implementation would be less than for SVE. Alternative 1
would not be protective of human health and the environment because
it does not reduce the risks associated with exposure to
contaminated soil.
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. It has been determined that Alternatives 2 and 3 are
functionally equivalent with respect to this threshold criterion.
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.
Both of the alternatives are capable of meeting ARARs. ARARs for
Alternative 2 relate to health and safety, erosion control, dust
emissions, and storm water discharge. ARARs for Alternative 3
include the above as well as those specific to the treatment
technology, including ARARs relative to the treatment, storage,
transportation and disposal of hazardous waste, and air emission
requirements (See Table 5).
Therefore, it has been determined that Alternatives 2 and 3 are
functionally equivalent with respect to this threshold criterion.
BALANCING CRITERIA P
Long Term Effectiveness
25
-------
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 3 would provide the greatest long term effectiveness
and permanence. Alternative 3 would remove contaminants from soils
as a concentrated solid or liquid waste for disposal. Alternative
2 would leave contaminated soils in place. Maintenance of the
cover materials and groundwater monitoring would be required. The
relative long term effectiveness of Alternative 2 is dependent on
the durability and maintenance of the cover.
Therefore, although it has been determined that Alternatives 2 and
3 are functionally equivalent with respect to this balancing
criterion, Alternative 3 offers slightly greater long term
protection due to its contaminant destruction capabilities.
Reduction of Toxicity, Mobility or Volume
Addresses the anticipated performance of the treatment technologies
a remedy may employ.
Alternative 3 is the only alternative which would provide complete
reduction in toxicity, mobility and volume of contaminants through
treatment. Contaminants would be transferred from the soils to
solid or liquid wastes for treatment or disposal. Alternative 2
would reduce the mobility of contaminants by reducing groundwater
infiltration, erosion, and fugitive air emissions. Natural
degradation, leaching, and dispersion processes would reduce
concentrations over many years.
Therefore, it has been determined that Alternative 3 is superior to
Alternative 2- with respect to this balancing criterion.
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.
Alternatives 2 and 3 may result in slightly higher short term
exposures compared to no action as a result of workers being
involved in grading or drilling activities. Alternative 3 could
also result in short term exposures if the off-gas treatment
equipment and process control system failed during operation. With
proper maintenance and monitoring, the likelihood of equipment
26
-------
failure resulting in a significant release is low. These increased
short term risks could be lessened through the use of engineering
controls, worker safety procedures, and access and land use
restrictions.
Therefore, it has been determined that Alternatives 2 and 3 are
functionally equivalent with respect to this balancing criterion.
Implementabi1i ty
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 would be easy to implement. The necessary materials
and equipment for the cover alternative would be readily available.
Numerous vendors would be available to perform the work.
Alternative 3 would be more difficult to implement. Pilot scale
tests would be necessary to confirm the feasibility of SVE for each
remediation area. A significant amount of monitoring would be
required but the necessary technologies, specialists, and equipment
would be readily available, and the SVE system could be easily
constructed. SVE is not as easily implemented in hot spot area C
due to tightly compacted soil conditions present there. The high
degree of soil compaction as well as the presence of chemical
manufacturing process equipment in hot spot area C would not allow
for the proper implementation of soil vapor extraction because the
soil would prevent the proper injection of the yapor probes and
would prevent the extraction of soil gas for treatment.
Therefore, although it has been determined that Alternatives 2' and
3 are functionally equivalent with respect to this balancing
criterion, Alternative 2 is slightly easier to implement,
especially in hot spot area C.
Cost
Included are capital costs, annual operation and maintenance costs
(assuming a 30 year time period), and net present value of capital
and operation and maintenance costs. The selected remedy must be
cost effective.
The present worth cost of Alternatives 2 is $460,000 for hot spot
area C. The present worth cost of Alternative 3 is $760,000 for
hot spot areas A and B.
MODIFYING CRITERIA
27
-------
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 an
opportunity to comment on technical decisions, and concurs with the
selection of Alternatives 2 and 3 as the selected remedy for this
operable unit soil cleanup at 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 been
moderate. U.S. EPA has been accessible and responsive to community
concerns throughout the study. At the public meeting for the
proposed plan, the majority of those in attendance were in favor of
Alternatives 2 and 3 as the most appropriate choices for the soil.
cleanup. Permanent contaminant destruction was the primary reason
for the citizen support for this remedy.
In summation, Alternative 1 is unacceptable for protection of human
health and the environment. Alternatives 2 and 3 are functionally
equivalent with respect to most of the nine criteria. Alternative
3 provides for greater reduction in the toxicity, mobility and
volume of contaminants than Alternative 2. Alternative 2 is more
implementable in hot spot area C than Alternative 3. Therefore,
the best balance among the three alternatives for the hot spot
areas in the north process area is Alternative 2, Permeable (Soil
and Gravel) Cover for hot spot area C and Alternative 3, Soil Vapor
Extraction, for hot spot areas A and B.
Presumptive Remedy Use at OU 3 and OU 4
The U.S. EPA has published presumptive remedy guidance to assist in
the remedy selection process at wood preserver sites such as
Reilly. Operable unit 3 deals with wastes from historical wood
preserving operations and Operable unit 4 deals with organics in
soils. The presumptive remedy for wood preserver sites is thermal
desorption, incineration, or bioremediation. EPA did not select
any of these presumptive remedies for operable unit 3. Soil
contamination is not present in discrete areas, causing the amount
of soil to be treated and the associated costs to be unreasonable
given the anticipated future land use. The contamination is
28
-------
widespread and does not appear to be concentrated in large enough
areas for treatment technologies to provide measurable benefit,
either in reduction of contamination in soils or in groundwater.
Because the contamination is widespread and not isolated in
discrete areas, the use of the presumptive treatment technologies
would not provide tangible reductions in soil contamination site
wide. Finally, the operation of the groundwater extraction system
at the site perimeter will prevent any groundwater contaminated by
the site from migrating away from the site.
The preferred presumptive remedy for VOCs in soil is soil vapor
extraction. EPA did select the presumptive remedy for VOCs in
soils, which wi'll provide for immediate and measurable reductions
of VOCs in soil, reducing risks associated with contact with soil
and decreasing contaminant leaching into groundwater. Benzene was
named in the presumptive remedy guidance as the primary VOC that
SVE is most effective treating. Pyridine has similar properties as
other VOCs named in the presumptive remedy guidance; therefore, SVE
would also treat them effectively. These are the primary
contaminants in the north process area that will be removed by SVE
treatment. This will maximize the performance of the perimeter
groundwater extraction system, while assisting in addressing
unacceptable risks in this area.
Finally, the FS evaluated alternatives for groundwater cleanup in
the OU 3 and OU 4 areas. EPA did not select an alternative for
groundwater cleanup for OUs 3 and 4 because-; the groundwater
extraction system designed for OU 1, when operating properly,
contains contaminated groundwater from migrating off-site,
preventing potential exposure to off-site groundwater users. This,
coupled with the actions taken in this ROD for source control and
the provision for the establishment of permanent deed restrictions
to prevent future development of the site, precludes the need for
additional groundwater extraction and treatment in the interior of
the site.
SELECTED REMEDY FOR OPERABLE UNIT 3
As was discussed in previous sections, EPA has selected Alternative
2 - Permeable (Soil and Gravel) Cover as the appropriate cleanup
remedy for operable unit 3 at the Reilly Tar and Chemical site.
This alternative was selected because it is the most appropriate
alternative for this operable unit action and is compatible with
the final remedial alternatives anticipated for the Site.
The FS contains a description of this alternative. A vegetated soil
cover will be constructed and maintained over the portion of the
kickback areas"which is currently not covered with gravel. The
29
-------
existing gravel layer covers, approximately 80 percent of the
kickback area. Prior to installation, any vegetation will be
cleared, large debris at the surface will be .removed, and the
remaining material will then be compacted and graded. Grading will
establish low slopes to reduce run on and minimize the effects of
runoff on adjacent areas. Following this site preparation, six
inches of topsoil will be spread across the graded area and seeded.
A vegetation layer will be established to minimize erosion.
Gravel cover in areas which are currently covered with gravel will
be maintained. The requirement to maintain the gravel cover will
be an institutional control that may be formally required as part
of Reilly's operating permit. The gravel cover will be inspected
monthly and necessary repairs will be made as needed. A minimum of
12 inches of gravel will be present in all areas of the kickback
area currently covered with gravel at all times. Future land use
in the kickback area will be limited to industrial uses by deed
restrictions. Quarterly monitoring of groundwater quality is
currently being performed at wells located ,upgradient' and
downgradient of the kickback area, -in accordance with the OU 1
consent decree. Groundwater samples from the contaminated areas
will be collected and analyzed annually for chemicals of concern.
The soil and gravel covers would be visually inspected monthly to
determined the need for repair. Damaged portions of the covers
will be promptly replaced (and the soil revegetated) as necessary.
Vegetation on the soil cover will be mowed as needed for
inspections and routine maintenance.
The.point of compliance for this action only, will be the kickback
area boundary, as is defined on Figure 3.
Because hazardous substances will remain in place at the site, U.S.
EPA will review .the remedial action every five years to determine
its effectiveness.
SELECTED REMEDY FOR OPERABLE UNIT 4
As was discussed in previous sections, EPA has selected
Alternatives 2 - Asphalt/Concrete Cover for hot spot area C and
Alternative 3 - Soil Vapor Extraction for hot spot areas A and B as
the appropriate cleanup remedies for operable unit 4 at the Reilly
Tar and Chemical site. These alternatives were selected because
they are the most appropriate alternatives for this operable unit
action and are compatible with the final remedial alternatives
anticipated for the site, which will mainly encompass source-area
remediation.
30
-------
The FS contains descriptions of these alternatives. An asphalt or
concrete cover will be constructed over hot spot area C identified
on Figure 5. The north process area is already partially paved
with asphalt roads and concrete foundations for tanks and
production areas. The remaining areas have an existing gravel
cover which will be graded and paved to join up with any existing
pavement. Future land use in the north process area will be
limited to industrial use by deed restrictions. Quarterly
monitoring of groundwater quality is currently being performed at
wells located upgradient and downgradient of the north process
area, as long as the OU 1 groundwater control is implemented.
Groundwater samples from the north process area will be collected
and analyzed annually for chemicals of concern.
Asphalt is comprised of specific percentages of asphalt, mineral
filler, and aggregate of several sizes'. Cement concrete is
composed of specified proportions of portland cement, aggregate of
several sizes, and water. The asphalt is heated during mixing, but
both types of cover materials are generally mixed off-site and
delivered to the project site. These covers will be rolled or
poured to smoothly join and blend with any existing paving
surrounding the remediation areas. ' . . .
The asphalt will be spread in nominal 2 inch thick layers. The
first layer will be rolled to compact the asphalt^with the subgrade
material before spreading the second layer. The total thickness of
the final asphalt cover will be approximately 4 inches. The life
expectancy of the asphalt cover will range from 15 to 30 years
depending on the effects of weathering, site use, and natural
degradation of the organic materials beneath the cover.
The cement concrete will be poured in a checkerboard pattern in
squares about 20 feet in length. A 6 inch slab with reinforced
fabric or welded wire mesh will be poured and cured. The life
expectancy of the concrete cover will range from 30 to 50 years,
depending on the effects of weathering, site use, and natural
degradation of the organic materials beneath the cover.
The asphalt and cement covers will be constructed with drainage
controls to convey precipitation runoff from production areas to
the onsite wastewater treatment plant.- These controls, including
slopes, catch basins, and piping, will be designed to tie into
existing drainage controls for the surrounding area. Drainage
controls for nonproduction areas will convey runoff to infiltration
galleries or surrounding unpaved areas. Controls will be designed
to prevent flooding of. the cover during a storm event having a 10
year frequency.
Soil vapor extraction (SVE) will be used to remediate hot spot
31
-------
areas A and B. SVE is an in-situ treatment method which consists
of one or more extraction wells screened in the unsaturated zone
for the purpose of withdrawing soil gas. Air injection wells are
often combined with extraction wells as a means of optimizing air
flow in the unsaturated zone by increasing the pressure gradient.
The air flow enhances the volatilization of contaminants dissolved
in pore water and the desorption of contaminants from the surfaces
of the soil particles.
SVE has been identified as a presumptive remedy for VOCs in soils
by U.S. EPA. The effectiveness of SVE depends on the volatility of
the target VOCs in the soils, and the rate and uniformity of air
circulation through the soils, which in turn depend on soil
permeability, moisture content, and the degree of soil
heterogeneity. At each hot spot area, air would be extracted from
site soils through a series of extraction wells installed to a
depth just above the water table, as indicated on Figure 6.
Individual extraction wells will be connected through a manifold to
one or more exhaust blowers that would pull air through the soils
(See Figure 6).
Hot spot area C is not considered to be well suited to SVE
application because the soils are of a finer texture from which
soil vapor samples could not be extracted due to tight and/or wet
soil conditions.
Natural biodegradation of the soil contaminants will occur in-situ
in addition to removal by SVE. The SVE system will treat emissions
which do not meet current air regulations by directing the
collected contaminants from the exhaust blower or pump to a control
such as a vapor phase activated carbon unit. The used carbon from
this unit will be regenerated onsite or disposed of offsite in full
compliance with all appropriate federal and state standards. Air
emission monitoring will be conducted of the emissions from the
soil vapor extraction system to ensure that the unit emissions are
in full compliance with all federal and state regulations. The
control unit will be preceded by a trap to minimize water entering
the emission unit. The SVE condensate will be treated in the
onsite wastewater treatment plant. The SVE system-^will be operated
until it can be determined that the contaminated soils no longer
pose a threat of leaching contaminants to the groundwater at levels
above those listed in Table 6 (for hot spot areas A and B). The
consent decree for operable unit 2 remediation activities is using
these performance standards to determine if treated soils pose
unacceptable threats to groundwater, and their use will ensure that
contributions of groundwater from the North Process Area will be
reduced or eliminated.
Following the completion of soil vapor extraction activities in hot
32
-------
i
!
i
]
}
Ground Surface
3 1
3 J
Water Table T °
To Atmosphere
A
(Hi— ,^ Granular
y • l^ Activated Carbon
Vacuum
Blower
J Vapor/Uquid
n Separator
>
Air Compressor
= ^ =
Facility Wastewater
Treatment System
i
S
"rtnritnr^n ^atQO
Vadose
Zone
^
] Soil Vapor Air Soil Vapor
Extraction Well Injection Extraction Well
Well
•* Source: USEPA, 1991
1
* . FIGURE 3-1
Soil Vapor Extraction Process Row
%
M940846
3-12
ScptanitMr 199<
\
-------
6
Table B
Performance Standards for
Soil Vapor Extraction System
TCLP
Standards
Total
Analysis
Benzene
5 PPB
Pyridine
35 PPB
510 PPM
Toluene
1000 PPB
cPAH (1)
200 PPT
20 PPM
(1) cPAH is the sum of seven carcinogenic PAHs,
-------
spot areas A and B, Reilly will install or maintain a gravel cover
of a minimum of 12 inches over hot spot areas A and B. This
requirement will be an institutional control that may be formally
required as a part of Reilly's operating permit. The gravel cover
will be inspected monthly and necessary repairs will be made as
needed.
The point of compliance for this action only, will be the north
process area boundary, as is defined on Figure 3,
Because hazardous substances will remain in place at the site, U.S.
EPA will review the remedial action every five ye'ars to determine
its effectiveness.
Documentation of Significant Changes
EPA published a proposed plan for this operable unit action on July
15, 1996, that proposed the selection of Alternative 2 - Permeable
(Soil and Gavel) Cover for operable unit 3 and Alternative 2 -
Asphalt/Concrete Cover and Alternative 3 -Soil Vapor Extraction for
operable unit 4.
There were no significant public comments received during the
public comment period, and the remedies recommended in the proposed
plan were not changed.
STATUTORY DETERMINATIONS
,i'
U.S. EPA's primary responsibility at Superfund sites is to
undertake remedial actions that protect human health and the
environment. Section 121 of CERCLA has established several other
statutory requirements and preferences. These include the
requirement that the selected remedy, when completed, must comply
with all applicable, relevant and appropriate requirements
.("ARARs") imposed by Federal and State environmental laws, unless
the invocation of a waiver is justified. The selected remedy must
also provide overall effectiveness appropriate to its costs, and
use permanent solutions and alternative treatment technologies, or
resource recovery technologies, to the maximum extent practicable.
Finally, the statute establishes a preference for remedies which
employ treatment that significantly reduces the toxicity, mobility,
or volume of contaminants.
The selected remedy for both operable units addressed by this ROD
will satisfy the statutory requirements established in Section 121
of CERCLA, as .amended by SARA, to protect human health and the
environment, will comply with ARARs (or provide grounds for
33 *"
-------
invoking a waiver) , will provide overall effectiveness appropriate
to its costs, and will use permanent solutions' and alternative
treatment technologies to the maximum extent practicable. The
statutory preference for treatment is satisfied by that component
of the selected remedy which requires the use of Soil Vapor
Extraction ("SVE") to remove Volatile Organic Chemicals ("VOCs")
from soils in the North Process Area of the Site.
1. Protection of Human Health and the Environment
Implementation of the selected remedy will protect human health and
the environment by reducing the risk of drrect exposure to
hazardous substances present in surface and subsurface soils at the
site in the areas addressed by .this Record of Decision; the
selected remedy will provide further protection of human, health and
the environment by removing and destroying hazardous substances
located in soils at the site which might otherwise have the
potential to leach to groundwater and increase further the
concentrations of hazardous substances already present in
groundwater at the site-at elevated levels. /
Those components of the selected remedy which require the placement
of final covers of soil or concrete over certain portions of the
North Process Area and the Former Kickback Area will provide
additional protection by^preventing direct exposure to hazardous
substances present in surface and subsurface soils at these areas.
These final covers will also serve to reduce infiltration of
precipitation through contamination left in place,, reducing thereby
the potential for these hazardous substances to leach to
groundwater.
Institutional controls will also be imposed to restrict uses of
those portions of the site where waste is left in place, to prevent
exposure to the hazardous substances covered there. No
unacceptable short term risks will be caused by.implementation of
the remedy. Mitigative measures will be taken during remedy
construction activities to minimize impacts upon the surrounding
community and the environment. Ambient air monitoring will be
conducted and appropriate safety measures will be taken during
remedy implementation. ,,•,
2. Compliance with ARARs
The selected remedy will comply with all identified applicable or
relevant and appropriate federal requirements and with those State
or local requirements that are more stringent, unless a waiver is
invoked pursuant to Section 121 (d) (4) (B) of CERCLA. The ARARs for
the selected, remedy are listed below:
34
-------
A. Federal ARARs
Chemical-Specific Requirements
Chemical-specific ARARs regulate the release to the environment of
specific substances having certain chemical characteristics.
Chemical-specific ARARs typically determine the standard for
cleanup.
Resource Conservation and Recovery Act (RCRA)
Although the RCRA hazardous waste in the source areas addressed by
the remedy selected for these operable units was placed in those
units before the effective date of the requirements established by
RCRA's implementing regulations, the facility is an operating RCRA
facility engaged in the management of hazardous wastes; therefore,
the RCRA statute and its implementing regulations are applicable in
some areas and relevant in other areas for purposes of Corrective
Action. As the contaminated soils at the source areas which are
the subject of the selected remedy are highly contaminated by
hazardous substances similar to RCRA hazardous substances which
have been demonstrated to be contributing sources to groundwater
contamination, the chemical-specific requirements of RCRA are also
relevant and appropriate. 40 CFR 141 requires that ground water
used as drinking water meet Maximum Contaminant Levels ("MCLs") for
contaminants of concern.
RCRA groundwater protection standards are codified at 40 CFR
264.94. That regulation establishes the concentration levels which
must be met for contaminants of concern in site ground water.
Safe Drinking Water Act
40 CFR 141
Federal Drinking Water Standards promulgated under the Safe
Drinking Water Act ("SDWA") include both Maximum Contaminant Levels
("MCLs") and, to a certain extent, non-zero Maximum Contaminant
Level Goals ("MCLGs"), that are applicable to municipal drinking
water supplies servicing 25 or more people. At. the Reilly Site,
MCLs and MCLGs are not applicable, but are relevant and
appropriate, because the unconfined aquifer below the site is a
Class II aquifer which has been used in the past for drinking water
•by residents bordering the site, and could potentially be used as
a drinking water source. Furthermore, individual residents have
informed EPA that unplugged residential wells are still in use,
emphasizing the possibility of their potential future use for
drinking water purposes.
35
-------
The National Contingency Plan ("NCP") at 40 CFR 300.430
(e) (2) (I) (B) provides that MCLGs established under the Safe
Drinking Water Act that are set at levels above zero shall be
attained by remedial actions for ground waters that are .current or
potential sources of drinking water. The point of compliance for
federal drinking water standards is at the boundary of the
solidified/stabilized waste, because this is the point at which
humans could potentially be exposed to ground water. Because the
source areas addressed by this action will have final covers, the
point of compliance for each unit addressed will be at the boundary
of the final covers. Groundwater monitoring wells will be
installed at the points of compliance to ensure that the
contribution to groundwater contamination from these source areas
has ceased. Existing groundwater wells in the aquifer will also be
monitored, and additional wells may also be drilled and monitored,
if necessary to ensure compliance.
Location-Specific Requirements
Location-specific ARARs are those requirements that derive from the
physical nature of the site's location and features of the local
geology and hydrogeology such as wetlands and floodplains.
The physical nature of the site's location does not appear to
implicate any additional ARARs for this selected remedy beyond
those already identified above and below as specific to the
chemical composition of the hazardous substances addressed and
those specific to the action required by the selected remedy.
Action-Specific Requirements
OPERABLE UNIT 3 (KICKBACK AREA)
The remedy selected for OU 3 includes a final cover and groundwater
monitoring. Ambient air monitoring to control particulate
emissions may be required during some phases of' construction.
The Federal and State ARARs for OU3 are presented below: .
FEDERAL ARARs
Clean Air Act (CAA) •••'-
40 CFR 50.6
This rule regulates particulate emissions standards.
Occupational Safety and Health Act
36
-------
29 CFR 1910, 1926 and 1904
Resource Conservation and Recovery Act ("RCRA")
The Resource Conservation and Recovery Act ("RCRA") is applicable
at some areas of this site and relevant at other areas. The site
is an operating RCRA facility subject to Corrective Action and
these RCRA Corrective Action obligations have been integrated into
the ongoing Superfund investigation and remediation program for
this facility, pursuant to a Consent Order amendment signed and
issued in September of 1992. Contaminated soils in the source
areas addressed by the selected remedy are RCRA wastes and/or
wastes similar' to RCRA wastes either because they exhibit
characteristics of RCRA wastes, are RCRA listed wastes, and/or are
similar to wastes exhibiting RCRA characteristics or RCRA listed
wastes.
The wastes in the kickback area were disposed prior to the
effective date of the RCRA regulations.. Therefore the closure
requirements of Subtitle C of RCRA are not applicable to the OU 3
area. Because the soil contamination found here involves wastes
similar to RCRA hazardous waste (including, but not limited to
wastes attributable to historical contamination from the creosote
operations referred to in previous sections of this ROD, above) the
requirements of Subtitle C regarding the components of a final
cover are relevant. However, because the previous CERCLA actidns
taken at this site included the installation of a perimeter
groundwater pump and treat system designed to prevent any further
migration of ground water off-site, and because the area in
question will be the subject of use restrictions, and because the
selected remedy includes groundwater monitoring at the unit
boundary, the requirements of Subtitle C of RCRA regarding final
cover components are not deemed appropriate. Requiring a Subtitle
C cover then, is not necessary from a technical standpoint, and any
incremental environmental benefit from such a cover requirement
would certainly not justify the substantial cost of installing such
a cover. The requirements considered both relevant and
appropriate in this area include, but are not necessarily limited
to:
40 CFR 264.117-120
These regulations require 30-year post-closure care and groundwater
monitoring.
Post-Closure Care
40 CFR 264.117 (a)
37
.r
-------
The requirements for post-closure care are set. forth at 40 CFR
264.117- through 40 CFR 264.120. '.
The Regional Administrator may revise the lenj.th of the post-
closure care period pursuant to 40 CFR 26.4.117 (a)(2)(I) if he finds
that a reduced period is sufficient to protect human health and the
environment; or extend the length of the post-closure care period
pursuant to 40 CFR 264.117 (a) (2) (ii) if he finds that the extended
period is necessary to protect human health and the environment.
40 CFR 264.117(c)
The remedy selected for this site requires U.S. EPA to restrict
post-closure use of this property as necessary to prevent damage to
the cover systems.
STATE ARARs Identified for OU3
The State of Indiana has identified the following regulations as
ARARs with which the selected remedy for OU 3 must comply:
327 IAC Article 15, Rule 5
This regulation governs the storm water run-off associated with
construction.
327 IAC Article 15, Rule 6
This rule governs the discharges associated with industrial
activity.
326 IAC; Air Pollution Control Board Regulations: Articles 6-
4, 6-5
These regulations govern Fugitive Dust Emissions Standards.
OPERABLE UNIT 4 (NORTH PROCESS AREA)
FEDERAL ARARs
Clean Air Act
40 CFR 50 and 52
Occupational Safety and Health Act
29 CFR 1910, 1926 and 1904
38
-------
Resource Conservation and Recovery Act ("RCRA")
The Resource Conservation and Recovery Act ("RCRA") is applicable
at some areas of this site and relevant at other areas because the
site is an operating RCRA facility subject to Corrective Action and
these RCRA Corrective Action obligations have been integrated into
the ongoing Superfund investigation and remediation program for
this facility, pursuant to a Consent Order amendment signed and
issued in September of 1992. Contaminated soils in the source
areas addressed by the selected remedy are RCRA wastes and/or
wastes similar to RCRA wastes either because they exhibit
characteristics of RCRA wastes, are RCRA listed wastes, and/or are
similar to wastes exhibiting RCRA characteristics or RCRA listed
wastes.• - •
For Soil Vapor Extraction in Operable Unit 4 (North Process
Area) •
The component of the selected remedy requiring Soil Vapor
Extraction ("SVE") for contaminated soils in hot spot areas A and
B of the North Process Area will require compliance with action-
specific ARARs related to the treatment technology selected as well
as ARARs related to the generation and disposal of hazardous
wastes. The selected remedy requires that the volatiles and
semi-volatiles extracted from the soil by the SVE process shall be
passed through a vapor/liquid separator. The liquid and vapor
phase contaminants extracted thereby must be disposed of in
accordance with applicable RCRA regulations. In the case of the
liquid phase, liquids separated may be passed to the facility
wastewater treatment system. The vapor phase treatment residuals
will be passed through a control unit, such as granular activated
charcoal, to remove hazardous substances. The charcoal itself,
after use, must be disposed in a manner cbnslstent with RCRA
regulations for the disposal of hazardous substances. Treatment
and recycling of the charcoal itself may be an appropriate option.
Air monitoring of the air emissions from the SVE unit will .be
required.
Although the National Contingency Plan ("NCP") does not require a
permit for actions which take place wholly on-site, the use of SVE
treatment unit will require that the substantive (rather than
procedural) requirements for what would ordinarily be viewed as a
RCRA regulated treatment unit be followed for this unit. This
means that the SVE treatment unit must comply with the standards
set forth at 40 CFR Part 264, Subpart X—Miscellaneous Units.
If RCRA hazardous wastes are generated by the treatment process,
the following RCRA ARARs will apply:
39
-------
40 CFR Part 261: Identification and Listing of Hazardous Waste
40 CFR Part 262 : Standards Applicable to Generators of
Hazardous Waste
40 CFR Part 264: Standards Applicable to Owners and Operators
of Hazardous Waste Treatment, Storage and disposal Facilities.
If the RCRA hazardous wastes generated by this unit must be
transported off-site for disposal, the following regulations will
apply:
40 CFR Part 263: Standards Applicable to Transporters of
Hazardous Waste
If RCRA hazardous wastes generated by the treatment process must be
disposed, the following regulations apply:
40 CFR Part 268: Land Disposal Restrictions
40 CFR 264.1032: Organic Air Emission Standards for Process
Vents
This rule may apply if air emissions from SVE of Total Organics are
at 10 ppm by weight or greater.
For Final Covers in the North Process Area
The selected remedy requires that hot spot area C will be covered
with an impermeable concrete or asphalt cover. Groundwater
monitoring will be required as the contamination there will be left
in place. Deed restrictions will restrict the future use in this
area. For hot spot areas A and B, an institutional control will be
imposed to require that a gravel cover is maintained in these
areas. These measures will assist in satisfying RCRA regulations
for these areas. The requirements include, but .are not
necessarily limited to:
40 CFR 264.117-120
These regulations require 30-year post-closure care and
groundwater monitoring.
• Post-Closure Care
P
40 CFR 264.117(a)
The requirements for post-closure care are set forth at 40 CFR
264.117 through 40 CFR 264.120.
40
-------
The Regional Administrator may revise the length of the post-
closure care period pursuant to 40 CFR 264.117(a)'2)(i) if he finds
that a reduced period is sufficient to protect human health and the
environment; or extend the length of the post-closure care period
pursuant to 40 CFR 264.117 (a) (2) (ii) if he finds that the extended
period is necessary to protect human health and the environment.
40 CFR 264.117(c)
The remedy selected for this site requires U.S. EPA to restrict
post-closure use of this property as necessary to prevent damage to
the cover systems.
STATE ARARs Identified for OU 4
The State of Indiana has identified the following regulations as
ARARs with which the selected remedy for OU 4 must comply:
Chemical Specific
329 IAC Article 3.1, Rules 1, 4-6
These rules govern the classification of treatment residues from
SVE.
329 IAC Article 3.1, Rules 7 and 9
These rules govern the on-site storage and packaging of hazardous
treatment residues from SVE.
Indiana Code Sections 8-2.1-18-36
and 329 IAC Rules 7 and 8
These Code sections and rules govern the transportation of
hazardous treatment residues from SVE.
329 IAC Article 3.1, Rule 12
This regulation governs disposal of hazardous treatment residues
from SVE.
327 IAC Article 15, Rule 6: Stormwater Discharge Associated
with Industrial Activity
This rule governs point source discharge requirements for
containment by the final cover.
41
-------
326 IAC; Air Pollution Control Board Regulations, Articles 6-
4, 6-5
These rules govern fugitive dust control emissions standards.
326 IAC Article 2-1: Permit Review Rules
These rules govern air emissions requirements for SVE.1
327 IAC Article 2, Rule 1-7: Indiana Water Quality Standards
327 IAC Article 5: NPDES Permits2
327 IAC Article 8; Rules 1 and 2: Public Water Supply
The rules cited above govern Wastewater discharge from SVE and
discharges associated with the final cover required.
3. Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative in
providing environmental benefit in proportion to the cost required
to achieve that benefit. The FS discusses the costs of the
alternatives considered, and a comparison of those costs is
presented in the section of this ROD summarizing the analysis of
the relevant criterion, above.
The selected remedies for these operable unit actions are cost
effective because they provide the greatest overall effectiveness
proportionate to their cost when compared to the other alternatives
evaluated, the net present worth of the selected remedies for both
operable units addressed in this document being estimated at
approximately $1,750,000. The estimated cost of the selected
remedies is reasonable when compared with the other alternatives
evaluated, and they assure to a high degree of certainty that the
remedy will be effective in the long term.
4. Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource recovery to the Maximum Extent
The CERCLA statute does not require compliance with the
procedural requirements of permit regulations, and permits need
not be obtained for actions implemented wholly on-site, but
compliance with the substantive provisions of such regulations is
required. -
See footnote 1, above.
42
-------
Practicable
The selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be used in a
cost-effective manner at this site. Of those alternatives that are
protective of human health and the environment and that comply with
ARARs, U.S. EPA has determined that the selected remedy provides
the best balance in terms of long term effectiveness and
permanence, reduction of toxicity, mobility, or volume of
contaminants, short term effectiveness, implementability, and cost,
taking into consideration State and community acceptance.
The extraction and treatment of hazardous substances in soils in
the North Process area through Soil Vapor, Extraction, with
imposition of appropriate final covers at Hot Spot Area C in the
North Process Area and in the former Kickback Area, together with
institutional controls restricting future use of the entire
property will provide the most permanent solution practical,
proportionate to the cost.
5. Preference for Treatment as a Principal Element
The statutory preference for selection of remedial actions in which
treatment is a principal element is satisfied by the selection of
Soil Vapor Extraction for Hot Spots A and B in the North Process
Area. These operable unit actions will permanently reduce the
toxicity, mobility, and volume of contamination at the site, and,
in conjunction with past and future operable unit actions will
reduce risks at the site through treatment of the principal threats
at the site. Hot Spot Areas A, B, and C in the North Process Area
have been identified as the principal threats addressed by these
remedial actions. Soil conditions in Hot Spot Area C preclude
effective treatment; therefore a final cover has been selected for
this area. Hot Spot Areas A-G in the Kickback Area have not been
identified as principal threats; therefore, final...covers have been
selected for these areas rather than treatment qptions.
EPA and IDEM believe, that the selected remedies satisfy the
statutory requirements specified in Section 121 of SARA to protect
human health and the environment, attain ARARs (or provide grounds
for invoking a waiver) and utilize permanent solutions to the
maximum extent practicable.
43
-------
-------
AR
U.S. EPA ADMINISTRATIVE RECORD
REILLY TAR & CHEMICAL CORPORATION
OPERABLE UNIT #3/OPERABLE UNIT #4
INDIANAPOLIS, INDIANA
UPDATE #2
09/23/96
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
1 09/15/94 Giordano, H., ENSR Novak, D., U.S. EPA Letter re: ENSR's Response to U.S. EPA's 12
Consulting and Couents on the Huian Health Risk Assessment
Engineering Docuient
2 09/19/94 Grant, H. and J. Novak, D., U.S. EPA Cover Letter Forwarding the Draft FS/CHS 1
Lennon; ENSR Reports for Operable Units 13 and 14
Consulting and
Engineering
3 10/00/94 ENSR Consulting and U.S. EPA Huian Health Risk Assessient Report (Voluie 1 186
Engineering of 2: Text, Tables and Figures)
4 10/00/94 ENSR Consulting and U.S. EPA Huian Health Risk Assessient Report (Voluie 2 539
Engineering of 2: Appendices A-E)
5 10/04/94 Barnett, C., CH2H Novak, D., U.S. EPA Cover Letter Forwarding CH2H's Couents on 1
Hill the Draft FS/CHS for Operable Units 13 and 14
& 10/11/94 Breier, S., IDEH Novak, D., U.S. EPA Letter re: IDEH's Coiients on ENSR's 2
September 1994 FS Report for Operable Units
13 and 14
7 10/21/94 Grant, H., ENSR Novak, D., U.S. EPA Letter re: Reilly's Recoiiendations for 11
Consulting and Revisions to the Draft FS/CHS for Operable
Engineering Units 13 and 14
8 10/25/94 Novak, D., U.S. EPA Bratina, L, Reilly Letter re: U.S. EPA's Couents on the Draft 7
Industries, Inc. FS/CHS for Operable Units 13 and 14
9 11/15/94 Novak, D., U.S. EPA Bratina, J., Reilly Letter re: U.S. EPA's Approval of Separate 2
Industries, Inc. Subiittals for the FS/CHS Reports for
Operable Units 13 and 14
10 11/28/94 Grant, H. and J, Novak, D., U.S. EPA Cover Letter Forwarding the Final FS/CHS for 1
Lennon; ENSR Operable Unit 14
Consulting and
Engineering
11 12/16/94 Barnett, C., CH2H Novak, D., U.S. EPA Letter re: CH2H's Couents on the Final 4
Hill FS/CHS for Operable Unit 14
12 01/04/95 Novak, D.,-U.S. EPA Bratina, J., Reilly Letter re: U.S. EPA's Cowents on the Revised 7
Industries, Inc. FS Report for Operable Unit 14
13 02/U/95 Hansen, S., IDEH Novak, D., U.S. EPA Letter re: IDEH's Couents on the Final 2
FS/CHS for Operable Unit »4
-------
DOCI DATE AUTHOR RECIPIENT ' TITLE/DESCRIPTION PAGES
14 02/21/95 Barnett, C., CH2H Novak, D., U.S. EPA Letter re: CH2H's foments on the Final 3
Hill FS/CHS for Operable Unit 14
15 03/07/95 Hansen, S., IDEH Novak, D., U.S. EPA Letter re: IDEM's foments to the Final 2
FS/CHS for Operable Unit 14
16 03/15/95 Barnett, C., CH2H Novak, D., U.S. EPA Letter re: CH2H's foments on the February 4
Hill 1995 Final FS/CHS for Operable Unit t3
17 03/22/95 Hansen, S., IDEH Novak, D., U.S. EPA Letter re: IDEH's foments on the Final 3
FS/CHS for Operable Unit 13
18 03/30/95 Novak, D., U.S. EPA Bratina, J., Reilly Letter re: U.S. EPA's Review of ENSR's 11
Industries, Inc. Responses to U.S. EPA foments on the Revised
FS Report for Operable Unit 14 H/Attachsent
19 03/31/95 Novak, D.,.U.S. EPA Bratina, J., Reilly Letter re: U.S. EPA's foments on the Revised 5
Industries, Inc. FS/CHS for Operable Unit 13 (UNSIGNED)
20 05/05/95 Bratina, J., Reilly Novak, D., U.S. EPA Letter re: Request for U.S. EPA Approval for 1
Industries, Inc. a Response Date of Hay 26, 1995 for Subcittal
of the Revised FS Reports for Operable Units
13 and 14
21 06/05/95 Bratina, J., Reilly Novak, D., U.S. EPA Letter re: Reilly's Recouendations for 3
Industries, Inc. . Actions to be Taken to Address Site
Contaiinants in the Operable Unit 13 SHHU
Areas
22 06/05/95 Bratina, J., ENSR Novak, D., U.S. EPA Letter re: Reilly's Recouendations for 2
Consulting and Actions to be Taken to Address Site
Engineering Contaminants in the Operable Unit 14 SHHU
Areas
23 06/27/95 Barnett, C., CH2H Novak, D., U.S. EPA Letter re: CH2H's foments on the Final 4
Hill FS/CHS Reports for Operable Units 13 and 14
24 07/10/95 Novak, D., U.S. EPA Bratina, J., Reilly Letter re: U.S. EPA's foments on the Revised 4
Industries, Inc. FS Reports for Operable Units 13 and 14
25 07/13/95 Hansen, S., IDEH Novak, D., U.S. EPA Letter re: IDEH's foments on the FS/CHS 2
Reports for Operable Units i3 and 14
26 05/00/96 ENSR Consulting and U.S. EPA Final FS/CHS Report for Operable Unit 13 215
Engineering
27 05/30/96 Novak, D., U.S. EPA Addressees Heiorandui Fomarding Attached Draft Proposed 9
Plan for Operable Unit 13 and 14 for Review
-------
DOCf DATE
ssss r==r
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
28 06/00/96 ENSR Consulting and U.S. EPA
Engineering
Final FS/CHS Report for Operable Unit 14
133
29 06/11/96 Hansen, S., IDEM Novak, D., U.S. EPA Letter re: IDEH's Couents to the Proposed
Plan for Operable Unit 13 and 14
30 06/12/96 Harrero, J., U.S. Novak, D., U.S. EPA Heiorandui re: Review of the Proposed Plan
EPA
31 07/00/96 U.S. EPA/OPA
Public
32 07/24/96 Accurate Reporting U.S. EPA
of Indiana
for Operable Units 13 and 14 and Potential
Air Eiissions
Fact Sheet: 'Proposed Plan for Reiedial 8
Action (Operable Units 13 and 14) for the
Reilly Tar Superfund Site'
Transcript of July 24, 1996 Public Meeting 117
re: the Proposed Plan for Reiedial Action for
Operable Units 13 and 14
33 07/27/96 Concerned Citizen U.S. EPA
Public Coiient Letter re: Cleanup
Alternatives Presented in the Proposed Plan
for Operable Units 13 and 14 (PORTIONS OF
THIS OOCUNENT HAVE BEEN REDACTED)
1
34 00/00/00 U.S. EPA
Record of Decision (PENDING)
-------
-------
-------
------- |