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

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                           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.

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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

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            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

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DAPPROXWATe
SITE BOUNDARY

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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.

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 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.

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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.

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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

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   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

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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

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             - 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

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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

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                                                                                                    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

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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.

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                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

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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.


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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

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                                                                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. !»««

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                                                          TABLE 3-1 (Cont'd)


                                              Federal and State ARARs for Soil Remedies
fyp» of fttK}
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                                                        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

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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

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 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

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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

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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

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                        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

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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

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 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

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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

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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

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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

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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

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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

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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

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     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

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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

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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

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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

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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

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      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

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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

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     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

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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

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                                                                                                            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

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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

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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)

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