PB96-964113
                                 EPA/ROD/R05-96/310
                                 December 1996
EPA  Superfund
       Record of Decision:
       Continental Steel Corp. Superfund Site,
       Kokomo, IN
        8/16/1996

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       Main Plant Buildings
    INTERIM REMEDY
  RECORD OF DECISION
AND RESPONSIVENESS SUMMARY
          JULY 1996
   Continental Steel Superfund Site
  Kokomo, Howard County, Indiana

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                                   Interim Remedy Record of Decision
                                   Continental  Steel Superfund Site
                                   Kokomo,  Howard County,  Indiana
                                   July  1996

TABLE OF  CONTENTS

SECTION                                                             EAS

DECLARATION                                                            1

SUMMARY                                                                5

    I.    Site Name, Location,  and Description                           5

    II.   Site Operational History                                       6

    III.  Site enforcement Activities                                    6

    IV.   Community Relations Activities                                 7

    V.    Scope and Role of Response Action                              9

    VI.   Summary of Site Characteristics                                10

    VII.  Summary of Site Risks                                         17

    VIII. Description of Alternatives                                    23

    IX.   Summary of the Comparative Analysis of Alternatives             27

    X.    The Selected Remedy                                            35

    XI.   Statutory Determinations                                       36


FIGURE 1                                                               41

FIGURE 2                                                               42

TABLE 1                                                                43

TABLE 2                                                                52

APPENDIX A  - RESPONSIVENESS SUMMARY

APPENDIX B  - ADMINISTRATIVE RECORD INDEX

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                             Acknowledgment
The Interim Remedy Record of Decision was prepared with the support  of
individuals from the staff of the Indiana Department  of Environmental
Management and the U.S. Environmental Management Agency.  The principal
authors  and major contributors for this version are:

                           Arthur C.  Garceau
                           Krista E.  Duncan
                       Patricia E.  Carrasquero
                           Gregg D. Romaine
                            John J.  O'Grady
                           Thomas J.  Krueger
                                   11

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   DECLARATION FOR THE INTERIM REMEDY RECORD OF DECISION
SITE NAME AND LOCATION
Continental Steel Superfund Site
Kokomo, Howard County, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected  interim  remedy  for
the Continental Steel Superfund site in Kokomo, Howard  County,
Indiana, which was chosen in accordance with  the  Indiana  State
Cleanup Law, Indiana Code 13-25-4 et. seg.  (formerly  13-7-8.7 et.
seq.), the Comprehensive Environmental Response,  Compensation,
and Liability Act  (CERCLA) of 1980, as amended by the Superfund
Amendments and Reauthorization Act  (SARA) of  1986 and the
National Oil and Hazardous Substances Pollution Contingency  Plan
(NCP).  This decision is based on the administrative  record  for
this site.

This decision document also serves as the Indiana Department of
Environmental Management's (IDEM) concurrence with and  adoption
of the interim remedy decision for the Continental Steel
Superfund site, as approved by the United States  Environmental
Protection Agency  (U.S. EPA), pursuant to sections 104(d) and 117
of CERCLA, the NCP and the Cooperative Agreement  (V005072-01-7)
between the U.S. EPA and the IDEM.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Interim Remedy Record of Decision, may present
an imminent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE REMEDY
This remedial action is an interim remedy for the Continental
Steel Superfund site.  This interim remedy addresses the
contamination detected inside the deteriorated Main Plant
buildings and in the Main Plant building basements.  As this is
an interim remedy, the remaining surface and sub-surface
contamination will be addressed in a future final remedy.
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Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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The major components  of  the selected interim remedy include:

•    Gross removal  of lead dust from contaminated building
     interiors  using  vacuuming and/or pressure washing with
     disposal of dust as hazardous waste in a permitted facility;

•    Management and proper disposal of rinsate collected from
     decontamination.  Rinsate water will be managed as hazardous
     waste until receipt of waste characterization analyses;

•    Asbestos abatement  by removal and disposal at a permitted
     facility of exposed friable asbestos-containing materials
     and asbestos containing building insulation;

•    Confirmation sampling to ensure proper decontamination;

•    Removal of PCB-contaminated wood block floors and disposal
     as hazardous waste;

•    Demolition of  all building superstructures,  tanks, and
     equipment  to grade,  leaving floor slabs;

•    Salvaging  of structural steel as scrap unless it can be
     decontaminated and  reused as originally intended;

•    Disposal of all  debris and demolition rubble as hazardous,
     special or non-hazardous waste  as determined by waste
     characterization;

•    Use of water spray  for dust control during demolition.   Dust
     control water  runoff  will be contained and managed properly
     to prevent the transport of contaminants from the immediate
     demolition site;

•    Pumping out flooded basements,  removal of equipment and
     residue from basements,  and filling of basements.  The
     pumped water will be  managed as hazardous waste until
     receipt of waste characterization analyses;

•    Filling or covering of pits;

•    Confirmational sampling to verify effectiveness of
     decontamination;

•    Finishing  of unpaved  areas with crushed stone;  and

•    Securing of the  site  after the  interim remedy is completed.
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Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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 DECLARATION
 The  selected  Interim Remedy (IR) is protective of human health
 and  the  environment,  complies with Federal and State requirements
 that are legally  applicable or relevant and appropriate to the
 IR,  and  is  cost effective.   This IR utilizes permanent solutions.

 This IR  will  leave  hazardous substances above health-based levels
 remaining on-site in the groundwater and in the surface and sub-
 surface  soils.  The IR will be consistent with the final remedy
 proposed plan that  is anticipated to be completed by June 1997.
 Removal  of  the buildings will increase the efficiency of the
 remediation of the  surface  and subsurface soils, foundation areas
 and  basements by  removing contamination and hazardous materials
 prior to the  final  remedy implementation.  The final remedy will
 ensure that the whole site  will be remediated to provide adequate
 protection  of human health  and the environment.

 Based on the  information described above, the IDEM with the U.S.
 EPA  in the  exercise of their authority have selected this interim
 remedy under  an agreement between the IDEM and the U.S. EPA
 pursuant to section 104(d)  of CERCLA.
\Michael O'Connor, Commissioner
 andiana Department of  Environmental Management
           >O
                                                    Date
ValdOs V. Ada
U.S. Environmen
                   , Regional Administrator
                   l Protection-Agency
Date
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Interim Remedy Record of Decision • Continental Steel Superfund Site * July 22,1996

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     SUMMARY FOR THE INTERIM REMEDY RECORD OF DECISION


I.  Site Name, Locationf and Description


The Continental Steel Superfund Site  is located on West Markland
Avenue in  the City of Kokomo,  Howard  County,  Indiana.   The total
site encompasses about  183  acres  and  consists of an abandoned
steel manufacturing  facility  (Main  Plant),  pickling liquor
treatment  lagoons  (Lagoon Area),  a  former waste disposal area
(Markland  Avenue Quarry), and  a former waste  disposal  and slag
processing area (Slag Processing  Area).  The  components of the
site are shown on the site  location map on  Figure 1.  The Main
Plant is the portion of  the facility  south  of West Markland
Avenue and east of Wildcat  Creek.   The Main Plant includes 25
buildings, many of which are severely deteriorated.  The Main
Plant building locations and designations are shown on Figure  2.

Waste pickle liquor,  used to remove by-products such as scale  and
rust from  cooling steel, was stored in the  Lagoon Area.   In 1984,
1985 and 1986, IDEM  identified chromium, cadmium,  lead and iron
in the on-site ground water.   The Lagoon Area was then proposed
for inclusion on the National  Priorities List (NPL)  in June 1988.
The site was formally placed on the NPL in  March 1989.   Further
investigation of the Markland  Avenue  Quarry and the Main Plant
Area confirmed additional contamination attributable to
Continental Steel.   The  water  in  the  quarry contained  traces of
organic solvents,  low levels of copper, zinc  and mercury,  and  had
a pH range from 11.5 to  12.6.   The  Main Plant area was
contaminated with PCBs,  baghouse  dusts (a listed waste containing
chromium and lead) and sludge  contaminated  with trichlorethylene.
The Markland Avenue  Quarry  and the  Main Plant were proposed for
aggregation to the site  and were  added to the site in  May 1990.

The area surrounding the facility is  a mixed  residential,
commercial, and industrial  area and is zoned  for general use,
except for the Main  Plant which has an industrial-use-only deed
covenant.  Residential properties are located to the east of the
Main Plant, a mix of residential  and  industrial properties exist
to the north and west, and  industrial properties are located to
the south.  The closest  residents to  the plant are located within
100 feet east of the site,  near the property  fence line  along
South Leeds Street,  and  south  of  the  Main Plant across Kokomo
Creek.  Highland Park, a public recreation  area for  area
residents, lies to the south of the Main Plant just  across Kokomo
Creek.

The Main Plant consists  of  about  94 acres and includes abandoned
buildings with floor areas  ranging  from 10,000 square  feet to
400,000 square feet.   Many  buildings  have basements, some  of
which are  flooded with ground  water.   A network of  underground
sewers and utility lines are also located on-site.   Some
processing equipment has been  removed from  the facility.


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II. Site Operational History


The Continental Steel Corporation  was  founded as the Kokomo Fence
Machine Company in  1896.   In  1899,  the Kokomo Fence Machine
Company was consolidated with other interests to form the Kokomo
Nail & Wire Company.  In 1900,  the company was reorganized under
the name of the Kokomo Steel  &  Wire Company.   Two 75-ton open-
hearth furnaces were erected  in 1914,  and a third open-hearth
furnace was placed  in service in 1917.   In 1927,  the Kokomo Steel
& Wire Company merged with two  other steel companies to form the
Continental Steel Corporation.   By 1947,  the other two steel
companies were divested, and  the Continental Steel Corporation
manufacturing facilities were centered in Kokomo.

In 1969, the Continental Steel  Corporation was acquired by New
York-based Penn-Dixie Industries,  Inc.  which officially dropped
the Continental Steel name for  the Kokomo facility in 1974.
Penn-Dixie Industries, Inc. filed  for  Chapter 11 reorganization
bankruptcy in 1980, and emerged from bankruptcy in 1982 as the
reorganized Continental Steel Corporation.   The main offices were
then moved from New York to Kokomo.  Continental Steel
Corporation filed for Chapter 11 bankruptcy in 1985.   The
facility closed in  February 1986 when  the bankruptcy filing was
converted to Chapter 7 liquidation.

Throughout its history, the plant  produced nails,  wire, and wire
fence from scrap metal.  Operations included reheating, casting,
rolling, drawing, pickling, annealing,  hot-dip galvanizing,
tinning, and oil tempering.   The steel manufacturing operations
at the plant included the  use,  handling,  treatment,  storage, and
disposal of hazardous materials.
III.  Site Enforcement Activities


The U.S. EPA and the IDEM filed claims  in  the  Continental Steel
Corporation bankruptcy, seeking funds to be  used for
environmental cleanup of the site.  Under  a  settlement approved
by the Bankruptcy Court on July 12, 1989,  over time Continental
Steel paid approximately $2.5 million into a trust fund to be
used by the IDEM to help fund cleanup of the lagoon area.  In
exchange for those payments, the  agencies  agreed not to sue the
bankrupt company for any additional funds  or cleanup.   The
remainder of the available funds  were used to  make partial
payment on the company's pension  obligations to its employees.

The Main Plant area and two other portions of  the former
Continental Steel facility were purchased  by Matthew L. Gentry
through the bankruptcy proceedings for  ten dollars each.  The two
other portions are not considered part  of  the  Superfund site.


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The two  other portions are the former engineering building on the
north  side  of Markland Avenue,  across from the Main Plant, and
the corporate offices located at 1111 South Main Street in
Kokomo.   The  U.S.  EPA,  through the U.S.  Department of Justice,
objected to the  sale of the property to  a private individual.
Mr. Gentry  executed a stipulation on January 24,  1991,  in which
his personal  liability for the full extent of cleanup costs were
carefully detailed.   Since this person accepted the liability and
obligation  to cleanup the  site,  there was no further legal basis
to object to  the sale.

On January  23, 1992,  the U.S.  EPA issued a Unilateral
Administrative Order to the owner to insure that any material on-
site would  not be moved about the site or transported off-site,
unless conditions of the Order were met.   The conditions included
the submission and approval of the requisite plans necessary to
complete the  work and the  proper documentation that any material
moved  off-site would be properly handled,  transported,  and
disposed of as required by federal and State law.

On February 2, 1993,  the U.S.  EPA filed  a lien on the Continental
Steel  Superfund  site property that,  in the event the property is
later  sold, may  enable the U.S.  EPA to recover monies expended in
the removal and  remedial actions conducted at the site.

IDEM and the  U.S.  EPA,  in  order to protect the public health and
safety,  have  accomplished  significant cleanup of some of the most
severe health threats at the site.   The  owner has cooperated in
providing the necessary access  to his property for performing
these  activities.   The activities both before and after the site
was sold to Mr.  Gentry are shown on Table 1.
IV.  Community Relations Activities
Community concern about the site began prior  to  the  company's
bankruptcy in February 1986.  Neighbors near  the site  complained
of airborne dust  (believed to be iron oxide)  produced  during the
periods of operation which damaged aluminum siding on  houses and
automobile finishes.  Many former employees still live in the
area and are very familiar with the waste handling and disposal
practices at the plant.  Local environmental  activists,  neighbors
of the site, and the business community have  been most interested
parties, and would like to see the property contribute to the
local community again.

The inclusion of the site on the NPL and the  subsequent removal
actions have received continuous media and community attention.

The first fact sheet explaining the Superfund process  and
describing the site and Remedial Investigation activities was
produced and mailed to local residents, local officials,  the
media, and other interested parties circa April  1990.   The next
fact sheet, distributed in June 1990, described  the  U.S.  EPA

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removal program,  site  history,  technical terms,  and the U.S.  EPA
and IDEM contacts.   It also advertised a public  meeting that was
held on June 28,  1990,  at  7:00  pm in the Kokomo  High School South
Campus Auditorium.   The last fact sheet of 1990  gave an update on
the removal and remedial programs,  memorialized  the two public
availability sessions  held by IDEM on August 13  and August 29,
1990, and advertised another public availability session that was
held on November  14, 1990,  at the Kokomo High School South
Campus.

Community Relations  interviews  were conducted during May 1992.
Fourteen people,  representing a cross sample of  interested
parties, were interviewed.   A fact sheet was distributed in May
1992, explaining  that  a community relations plan was being
developed and requesting that the community provide suggestions
for items to be included in the plan.   Another fact sheet was
distributed in December 1992.   It gave an update of the removal
and remedial actions,  and  advertised a two session public
availability meeting that  was held on December 8,  1992,  at the
Community Meeting Room of  the United Way of Howard County
building.

A fact sheet distributed in May 1993,  continued  the community
involvement by providing an update of activities at the site  and
advertising a Remedial Investigation/Feasibility Study "Kick Off"
meeting.  The meeting  was  held  on May 6,  1993, at 7:00 pm in  the
Council Chambers  at  the Kokomo  City Hall.   The first phase of
sampling was completed by  November 1993.

Indiana State Representative Jon R.  Padfield held a Town Meeting
on June 10, 1995, in the Auditorium of Indiana University/Purdue
University at Kokomo.   IDEM staff presented a project update  and
participated in a question and  answer period.

Congressman Steve Buyer and Congressman Mike Oxley held a public
meeting on August 10,  1995,  in  the Conference Room of the Howard
County Government Building.   IDEM and U.S.  EPA staff conducted a
site tour before  the meeting and provided a project update at the
meeting.

A meeting to discuss the redevelopment of the site was held on
August 31,  1995,  in  the Lake Superior Room of the Ralph H.
Metcalfe building in Chicago, Illinois,  which was requested by
Howard County officials, Kokomo City officials and local
community leaders.   U.S. EPA and IDEM staff provided a project
update,  program perspective,  and future project  schedule.

The Kokomo/Howard County Business/Labor Alliance sponsored the
creation of a Community Action  Group.   The purpose of the group
was to form a community consensus  for  the cleanup and
redevelopment of the site.   The consensus-building meeting was
held on October 10,  1995,  in the Conference Room at the  Howard
County Government building.   Eighteen  leaders representing most
aspects of the community formed the  group,  and fifty-two people
attended.  A consensus  on  the role  of  community  involvement was

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developed and  approved by all in attendance.

A fact sheet was  distributed in November 1995,  during the second
phase of sampling at  the site.   This fact sheet provided an
update of activities  and advertised another two session public
availability meeting  that was held on November  16,  1995 at the
United Way building.

The Community  Action  Group sponsored a meeting  of the Continental
Steel local neighborhood area residents on January 11,  1996,  at
the Ivy Tech State College.   Over 973 invitations to attend this
meeting were mailed,  and 21  local residents attended.  IDEM staff
presented a site  update and  answered questions.

The requirements  of CERCLA regarding public participation in the
interim remedy selection process were met by issuing the proposed
plan fact sheet to the public February 28,  1996.   The public
comment period commenced March 1,  1996 and ended March 30,  1996.
A public meeting  was  held March 14,  1996 at the Ralph W.  Neal
Council Chambers,  Kokomo City Hall to accept written and oral
public comments on the proposed plan.   A court  reporter was in
attendance to  provide a transcript of the public meeting.
Seventy-eight  people  were in attendance.
V. Scope and Role of Response Action


The interim remedy addresses  all of the Main  Plant buildings
which are part of the  larger  Main Plant source area,  as well as
debris and waste that  have been stored on  site since  the removal
actions.   Other contaminated media at the Main Plant,  such as
surface soil, subsurface soil and ground water will be  addressed
by a final remedy document prepared for the entire site.

IDEM is currently conducting  a Focused Remedial Investigation and
Feasibility Study (RI/FS) of  the entire site  in accordance with
CERCLA.  The entire site is comprised of four source  areas and
two affected media.  In order to facilitate the Focused RI/FS,
these areas were designated as Operable Units (OUs).  OUs are
areas that can be studied individually and then can be  included
as a part of the Focused RI/FS for the entire site.   A  list of
the OUs is as follows:

     OU1 - Ground water - affected media;
     OU2 - Lagoon Area - source area;
     OU3 - Kokomo and  Wildcat Creeks - affected media;
     OU4 - Markland Avenue Quarry - source area;
     OUS - Main Plant  Area -  source area;  and
     OU6 - Slag Processing Area - source area.

The Focused RI/FS will evaluate the nature and extent of
contamination and assess the  human and environmental  risks posed
by the contaminants associated with the entire site.  The Focused
RI/FS will evaluate potential alternatives for remediation of the

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source  areas.

This  interim remedy focuses on the buildings at the Main Plant
source  area  as  investigation work has indicated that they pose an
imminent  threat to  public health and the environment.  This
interim remedy  is  intended to address the Main Plant buildings
independently of the Focused RI/FS.   The purpose of the interim
remedy  is to reduce the risks to public health and the
environment  and eliminate the physical hazards posed by all the
structures.

The interim  remedy  identified for the Main Plant buildings may be
implemented  in  an expedited fashion,  in accordance with interim
remedial  measure and removal action regulations identified in the
NCP,  40 CFR  300.  The need for an interim remedial measure at the
Main  Plant source area is based on the extent of risk/hazard
posed by  all the Main Plant buildings.   The interim remedial
measure would be implemented in conjunction with the ongoing
Focused RI/FS program for the Main Plant source area.  It is also
anticipated  that the interim remedy will aid in more efficient
performance  of  the  final remedy.
VI. Summary of Site Characteristics
Surrounding Areas and Populations

Kokomo and Wildcat Creeks run  along  the borders of the Main Plant
source area and the Lagoon Area.   The creeks have received water
from the plant's wastewater  recycling and filtration system,  as
well as neutralized pickle liquor  from the Lagoon Area and storm
water runoff from the site.

The total site is located in a mixed residential,  commercial,  and
industrial area and is zoned for general use.   The owner of the
Main Plant area which is covered by  this interim remedy placed a
covenant for industrial-use-only on  the property deed.  Therefore,
the area covered by this interim remedy can only be used for
industrial purposes.

Residential properties are located to the east  of the Main Plant,
a mix of residential and industrial  properties  exist to the north
and west, and industrial properties  are located to the south.
The closest residents to the plant are located  within 100 feet
east of the site along South Leeds Street and south of the Main
Plant source area across Kokomo Creek.   Highland Park,  a public
recreation area for the residents  of Kokomo,  lies to the south of
the Main Plant just across Kokomo  Creek.

Structures and Topography

The Main Plant formerly consisted  of two tracts of land bisected
by West Markland Avenue.  However, the Main Plant source area
listed under the Superfund designation and covered by this

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interim remedy  consists  of  about 94 acres located south of West
Markland Avenue.   The  Main  Plant source area includes more than
25 abandoned  buildings with floor areas ranging from 10,000
square feet to  400,000 square  feet.   Many of the buildings
contain basements,  some  of  which are flooded with groundwater.
Some processing equipment has  been removed from the facility.

The IDEM and  the U.S.  EPA conducted a site reconnaissance on
August 23, 1995, to assess  the feasibility and probable costs  of
demolishing the buildings.   Obvious structural deficiencies were
observed in some of the  buildings as follows:

•     Severely corroded structural steel in Buildings 11 and 70;
     and,

•     Rotten and disintegrating wooden roofs in Buildings 8, 9,
     10, 11,  12, 20, 112B,  114,  and 122.

In general, the structural  condition of the buildings varies
considerably  with  the  age and  former use of each building.   The
reconnaissance  team also noticed that,  in general,  any building
with corrugated siding suffered from missing or damaged siding
panels.  This includes buildings adjacent to the residential back
yards along the west side of South Leeds Avenue.   The degree of
deteriorated  siding varies  depending on the building.   Specific
instances of  damaged siding panels were observed in Buildings  5,
24, 40, 42, 68, 69,  70,  and 110.

Many windows  were  observed  to  be broken and the fencing at  the
site had been violated.  The fence has  been repeatedly
vandalized.

Topography across  the  site  is  generally level  with an average
ground surface  elevation of 800  feet above sea level.

Sensitive Ecosystems

Preliminary data suggest that  there  are no endangered,
threatened, or  rare species existing on or near the Main Plant
source area.  A preliminary search for  site-specific biological
or ecological data  revealed little useful data for the Main Plant
area.  Few ecologically  critical,  sensitive, threatened,  or
endangered terrestrial species are likely to occur on-site,  and
no significant  impacts to important  terrestrial populations or
communities are expected from  the interim remedy.

Meteorology

Climate is uniform  throughout  the Kokomo  area.   Average monthly
precipitation ranges between 2.2  and 4.2  inches (U.S.  Dept.  of
Agriculture,  December  1971).   Temperatures are relatively mild
throughout the  year.   During the  fall and winter months,  average
monthly temperatures range  between 25 and 70 degrees Fahrenheit.
During the spring and  summer,  average monthly  temperatures  range
between 50 and  75 degrees Fahrenheit.   Prevailing winds blow from


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the southwest,  but  for  a  few months  during the winter, winds blow
from the northwest.

Location of Hazardous Substances

The U.S. EPA divided the  Main Plant  into Areas A through H, as
shown on Figure 2.  Soil  samples  and unknown slag materials were
analyzed on-site by the U.S.  EPA  Field  Analytical Support Program
Laboratory  (FASP Lab) for metals,  PCBs,  and polycyclic aromatic
hydrocarbons  (PAHs).  Samples from inside and outside the Main
Plant buildings were collected, including dust/sediment samples
from floors and beams,  liquid samples from flooded basements and
unknown drums,  and soil samples from stained areas around the
buildings.  Soil and dust will be referred to collectively as
soil/dust, since residual dust from  former activities resides in
soil.  Fifty-five tanks and  34 drums were also identified.

Based on the results of the  U.S.  EPA screening investigation, the
following contaminants  were  detected at the Main Plant source
area and remain on-site:

     Metals;
     PCBs ;
     PAHs;
     Asbestos;  and
     Acids.

Additional sampling (Phase II sampling)  of all media throughout
the entire site was conducted from October through December 1995.
The objective of the additional sampling was to obtain sufficient
data to complete the Focused RI.   The data has been analyzed and
has confirmed the previous sampling  results.   The nature and
extent of contamination has  been  characterized and the
information to  confirm  and implement the selected interim remedy
is available.

Quantity, Volume, Size, or Magnitude of  Contamination

Several types of contaminants, contaminated soil/dust,  and waste
were identified in and  around the  Main  Plant buildings and
currently exist on-site.   Table 2  presents sampling results from
removal actions and screening investigation performed at the Main
Plant.  These concentrations  are  compared to the U.S.  EPA soil
screening values (1994) to determine if  further investigation is
required.  The  soil screening values are health-based guidelines
and are appropriate for screening  soil/dust media at the Main
Plant.

Metals
Several metals  detected in soil/dust may pose a human health or
environmental risk.  The  highest  lead contamination,  inside the
buildings for example,  ranged from 14,000 mg/kg to 730,000 mg/kg
in Buildings 11, 112A,  24, 29A, and  71B,  corresponding to Areas
B, A,  F,  and H, respectively.  These concentrations were 35 to
about 2,000 times greater than the screening value for lead,

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which  is 400 mg/kg  (EPA,  1994) .   All  areas  of the Main Plant
source area that were  sampled  contained  an  indoor average lead
concentration greater  than  400 mg/kg.

One pile of lead-contaminated  soil/dust  south of Building 7IB
contained 88 percent lead (880,000 mg/kg).   This material was
detected outside of Building 7IB  in the  surrounding surficial/
unconsolidated material,  and was  subsequently moved inside the
building.  Other metals,  such  as  arsenic, chromium, silver, and
zinc,  were also present  in  this residual dust material.   All the
metals exceed their respective screening value.   As seen in
Table  2, arsenic ranged  from 62 mg/kg to 695 mg/kg, chromium
ranged from 223 mg/kg  to 8,493 mg/kg,  silver ranged from 85 mg/kg
to 3,071 mg/kg, and zinc ranged from  95  mg/kg to 279,500 mg/kg.
These  metal concentrations  exceed their  respective screening
values of 0.4 mg/kg, 390 mg/kg, 390 mg/kg,  and 23,000 mg/kg.

A U.S. EPA removal action began in Area  A and proceeded  into
other  areas as funds allowed.  Only Area A  and most of Area B,
along  with portions of Areas E, F, and H, were grossly
decontaminated before  removal  efforts  ceased due to budget
restrictions.  The Main  Plant  buildings  112A,  112,  112B,  11, 12,
8, 10, and 122, were grossly decontaminated by the U.S.  EPA by
removal of dust and debris, which primarily contained lead.
After  the major debris was  removed, these   buildings were
decontaminated using a HEPAVAC to vacuum the lead dust into bags.
Because further cleanup  was anticipated, no post-decontamination
verification sampling  has been conducted to evaluate the
effectiveness of the gross  decontamination.

Due to the presence of residential housing  immediately east of
the site, U.S. EPA determined  that an  immediate  threat to human
health existed from possible exposure  to metals  transported by
windblown dust.  The pile of lead-contaminated soil/dust south of
Building 7IB was therefore  stockpiled  inside the southern portion
of the building and covered with  visqueen.   At the conclusion of
the removal, stockpiles  of  potentially lead-contaminated dust and
debris that were not placed in bags were covered with visqueen.
Approximately 75 cubic yards of lead-contaminated soil/dust was
stockpiled in Buildings  12, 71B,  and 11B (Areas  B,  H and B).
U.S. EPA did not conduct  final disposal  of  debris and waste.   The
material remains on-site  and is proposed for disposal as part of
the interim remedy.

PCBs
According to the March 24,  1994,  U.S.  EPA Action Memorandum,
PCBs,  in concentrations up  to  8,700 mg/kg,  were  reported around
the electrical substation on West Markland  Avenue in Area C.
Approximately 120 cubic yards  of  soil  was excavated and
stockpiled immediately west of the substation and covered with
visqueen.  This concentration  is  8,700 times greater than its
screening value of 1 mg/kg  (EPA,  1994).

An estimated one cubic yard of PCB-contaminated  soil was  removed
from the area east of  Building 112C in Area E.   All of this PCB-

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contaminated  soil  stockpiled  on the Main Plant was disposed off-
site upon receipt  of  analytical data and completion of necessary
disposal arrangements.

PCB-contaminated woodblock  floors  were found in Area B,  Buildings
14 and  14A.   The woodblock  floors  were removed with a bobcat,
stockpiled  in their respective  buildings,  and covered with
visqueen.   These materials  remain  on-site and are proposed for
disposal as part of the  interim remedy.

PAHs
PAHs detected at the  Main Plant source area are associated with
the oily wastes formerly produced  on-site.   PAHs were located in
all the building areas A through H,  both inside and outside of
the buildings.  Area  D detected PAHs inside the buildings only,
and Area G  detected PAHs outside of the buildings only.   All
other areas contained PAHs  both inside and outside of the
buildings.  PAHs are  a group  of compounds formed during the
incomplete  combustion of coal,  oil,  gas,  or other organic
substances, and are found in  substances such as crude oil or coal
tar pitch.  The PAHs  detected are  summarized in Table 2.   Eight
PAHs out of 17 detected  exceed  their respective screening value.
The higher  molecular  weight PAHs,  such as Benzo(a)pyrene (BAP),
are more persistent in the  environment and are carcinogenic.   All
PAHs that exceed their respective  screening value,  except for
Pyrene, are carcinogenic.   They therefore present a significant
hazard following release to the environment.   BAP was found
inside and  outside all building areas at the Main Plant  in soil
and/or dust.  PAHs inside the buildings are proposed for disposal
as part of  the interim remedy.

Asbestos
Ten samples of pipe insulation  were  collected from buildings in
Areas B, C, and F, and were analyzed for asbestos content.   Of
the ten samples collected,  five were found to contain asbestos.
Two of the  five samples  containing asbestos were collected from
Area B, Buildings 42  and 54.  The  remaining samples containing
asbestos were taken from Area F, Building  1.   Buildings  112,
112A, 112B, and 112C  are insulated with  an asbestos containing
material.   No other actions regarding asbestos abatement and/or
decontamination were  taken.   Because there is no maintenance of
the Main Plant buildings, asbestos materials  on-site are expected
to deteriorate and some  materials  could  become friable.   Friable
asbestos will release respirable asbestos  fibers;  the latter have
been shown  to cause lung cancer, including mesothelioma,  in
humans.  These asbestos  materials  remain on-site and are proposed
for disposal  as part  of  the interim  remedy.

Acids
Tank T-18,   containing acid  with a  pH of  less  than 1,  was located
in Area C.   Acid was  drained  from  the tank  and placed into five
55-gallon poly drums  and stored in Building 123A.   A sample of
the unidentified acid was sent  for Total Organic Carbon  (TOC)  and
Toxicity Characteristic  Leaching Procedure  (TCLP)  metals
analyses.  The acid was  disposed of  off-site  during the  1993

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removal  actions.

Contaminated Soil On-site
Prevalent site contaminants include lead and other metals, such
as arsenic,  as well as PCBs and PAHs.   PCBs and PAHs have been
detected at  various locations around the Main Plant source area.
Sampling results  indicate that contamination is present in
outdoor  surface soils.   As presented above, a few removal actions
have occurred,  mainly focusing on PCBs.  However, minimal
confirmatory sampling was conducted.

Contaminants are  clearly present in the on-site soil.  However,
the vertical extent of these contaminants in the subsurface is
unknown  and  these past releases may have migrated beneath the
buildings themselves.   Contaminants present in the buildings and
surface  soils  are elevated throughout the Main Plant.  It is
likely that  wind, surface runoff,  and past spills have caused
general  contamination.   The Phase II sampling results have
further  characterized the contamination and will provide
information  for the interim remedy design.  Surface soil,
subsurface soil and ground water contamination are widespread,
long term concerns  that will be addressed as parts of the final
remedy,  and  are beyond the scope of the present interim remedy
decision.

Finally, trace to moderate levels of chlorinated and aromatic
hydrocarbons were reported in field analyses of soil samples
collected in or adjacent to the buildings.  Because these are
volatile compounds,  surface contamination may be minimal, but
there may be substantial subsurface contamination.   Such
contamination  could be a threat for vapors migrating into
adjacent indoor residential air spaces, or for contamination of
groundwater  or nearby Wildcat and Kokomo Creeks.

Other Contaminated Material On-site
During the U.S. EPA and the IDEM inspections,  a total of 55
tanks, ranging in capacity from 5,000  gallons to 12 million
gallons, were  identified.   Thirty-three vats were also noted.
These aboveground and underground storage tanks were
predominantly  used  for oil storage.  The contents of most of the
tanks were removed  and disposed during the removal action.

The U.S. EPA cleaned four large fuel oil tanks in a removal
action in the  Fall  of  1994.   The status of the remaining tanks,
vats and hoppers  will  be confirmed via a detailed inventory
during the Remedial  Investigation  and  prior to implementation of
this interim remedy.

Chemical Attributes  of  the Hazardous Substances

Many of  the  hazardous  substances remain on-site in the form of
contaminated soil/dust.   Some waste materials were containerized
and stored at the Main  Plant buildings in select locations.   Some
of the containers have  burst and the contents have spilled within
the buildings.  Stockpiles of lead-contaminated dust and debris

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were placed in Building  7IB  and covered with visqueen.   Buildings
12 and 116 also contain  lead-contaminated soil/dust.  PCB
contaminated woodblock floors  in Area  B (Buildings 14 and 14A)
are stockpiled and covered with visqueen.   Asbestos was sampled
in Area B  (Buildings  42  and  54)  and  Area F (Building 1), but was
not removed and remains  on-site.   Mercury,  from broken
thermometers or switches, was  found  on the floor of the pump
house in Area B and collected  in a bucket.   The bucket containing
mercury waste was stored inside this building,  and disposal of
mercury contamination is proposed as part of the interim remedy.

The buildings are in  various stages  of deterioration and present
a chemical and physical  hazard to trespassers.   Some areas have
deep pits and crevices as well as loose debris,  weak building
structures, and poor  lighting.   The  Main Plant  source area
perimeter is surrounded  by fencing,  but the fencing is
continually vandalized and does not  curtail access.   Access to
hazards, therefore, cannot be  controlled or prohibited.

Targets Potentially Affected by the  Site

The likely primary on-site targets affected by  the buildings are
workers and trespassers.  As noted previously,  evidence of
trespassing has been  persistent.   Most trespassers include older
children and young adults who  may be exposed to extreme
concentrations of metals and organic contaminants while
trespassing on the site.  Secondary  on-site targets  include the
City of Kokomo public safety personnel (i.e., firefighters,
emergency medical technicians,  police  officers)  who  would be on-
site to respond to emergency situations or  accidents.

The likely primary off-site  target would be nearby residents in
the neighborhood adjacent to the  site.   Homes in this area abut
the buildings within  100 feet  of  the east property line.   These
residents can be affected by materials in the buildings  that may
migrate from the site in the form of surface water runoff or
windblown dust.  Of particular  concern in this  area  are  children,
since lead is a primary  chemical  of  concern,  and children are
considered the most sensitive  sub-population for exposure to this
metal.  Groundwater is not an  immediate issue as most residents
of Kokomo receive drinking water  from  a public  water  supply.
Groundwater could discharge  to  the creeks,  however,  and  may
affect surface water, sediment, and  biota.

An off-site environmental target  includes the resident  species  in
Kokomo and Wildcat Creeks.   These creeks have the potential of
being affected by the residual  contamination migrating  in storm
water runoff and/or windblown dust.  Organisms  that  feed on these
species could be targets for contaminants,  such as PCBs,  that
bioaccumulate.
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VII.  Summary of Site Risks
Site-Specific Problems

Based on the information available regarding the amount of
contamination on-site,  the Main Plant source area poses a
significant health  hazard.   Residual dust known to contain lead
and other metals  are  present on-site and have the potential to
migrate off-site  to the nearby residential area.  The dust
presents the highest  concentration of mass of metals at the site.
Contaminated wastes in  drums or piles are also on-site and are a
potential source  of contamination to human and environmental
receptors.  The potential for off-site migration of contaminated
dust increases as the buildings continue to deteriorate.  Dust
has already been  observed in surface soil outside of the
deteriorated buildings.   Also,  the high concentrations of some
contaminants on-site  (e.g.,  metals and PCBs)  and the potential
for friable asbestos  to release respirable asbestos fibers makes
potential exposures for workers and trespassers on-site
significant.  An  interim remedy focusing on the Main Plant
buildings would reduce  the potential for continual migration of
contaminants associated with dust and materials from the site.

The buildings have  not  been maintained and structural integrity
is poor.  Basements have been flooded and the depth and content
of standing water is  not known.   Such basements may present both
an exposure and a drowning hazard.   It is known that young adults
frequent the site,  and  the facility is clearly an attractive
nuisance in the local community.   Without significant
rehabilitation, these structures will continue to deteriorate,
causing increased risk  of injury and release of pollutants into
the environment.  The perimeter fence has deteriorated and easy
access into the buildings is available.   The lack of site
restriction makes physical  and  chemical hazard exposure to the
public likely.  Fencing has been repaired,  but is repeatedly
vandalized.  The  property owner has periodically been requested
to provide adequate site security,  but has been unable or
unwilling to do so.   The site is abandoned and covers a large
area.  These exposures  present  a risk as they are not controlled
and the level of  exposure is unknown.

Data Evaluation and Chemicals of Concern

An initial data evaluation  was  completed for the site in the COM
Work Plan (October  1995).   Table 2  identifies contaminants that
are present at levels greater than  the screening values.   The
chemicals of concern  (COCs)  at  the  Main Plant source area are
primarily metals, PCBs,  and PAHs.   The data are of Level III
quality, which adequately identifies  the COCs at the site.

Exposure Pathway  Evaluation

A number of receptor  groups  could be  exposed to contamination at
the currently abandoned  Main Plant.   Workers involved in building

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maintenance,  site  security,  remedial investigations,  or other
efforts could be exposed  to  contamination and hazards during the
course of their work.   The buildings are encompassed by a fence
along the majority of  the perimeter.  In several locations noted
during the March 15, 1995, site visit,  the perimeter fence was
breached and  in poor repair.   Trespassers are expected to find
all areas of  the Main  Plant  source area easy to access.  Building
24  (Area F) contained  evidence of a recent visitation, including
footprints and bicycle tracks.   Animal tracks were also noted in
the same area.

The following is a list of some of the recent episodes of known
trespassing:

•    In the early  1990s,  the fire department was called to rescue
     a trespasser  who  had fallen into a pit;

•    In the Fall of 1993, the wheels and tires were stolen from
     the U.S.  EPA  project trailer;

•    In the Fall of 1994, a  Bobcat was removed from the site
     while U.S. EPA staff were present;

•    In the Fall of 1994, a  U.S.  EPA computer was stolen from the
     on-site  field trailer;

•    In the Fall of 1994, IDEM repaired approximately 100 feet of
     damaged  security  fencing;

•    In the Spring of  1995,  IDEM repaired several holes in the
     security fencing;

•    In November and December of 1995,  staff witnessed
     trespassers on-site  on  three different occasions;

•    In December 1995,  staff  witnessed  local police in the
     buildings without  health and safety protective equipment.
     The police were responding to  a call of trespassing; and

•    In March 1996, the fire  department was called to extinguish
     a fire inside a power supply building.

Residential development abuts the eastern boundary.   Prevailing
westerly winds suggest  that  these residential areas could have
received or may currently receive windblown contamination from
the Main Plant source area.   On the west and south, the Main
Plant source  area  is bordered by Kokomo  and Wildcat Creeks,
respectively.  The plant  may  be a continuing source of
contamination to sediments adjacent to  and downstream from
drainage areas and other  release points.   Specifically,  if the
on-site buildings  were  on fire  due  to vandalism or other causes,
there would be increased  exposure potential for on-site workers
and off-site  residents.

The exposure  pathways are expected  to be currently complete


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since:

•    Trespassers are known to frequent areas of contamination,
     sometimes  to salvage parts of the structures or for
     recreational purposes;

•    On-site  workers are frequent known areas of contamination;

•    City  of  Kokomo  public safety personnel would be on-site to
     investigate reports of trespassing,  for emergency situations
     or accidents at the site;

•    Residential areas  are located downwind and immediately
     adjacent to the site;

•    Materials  on-site  are found in forms likely to be
     transported by  winds;

•    Drainage exists to carry contaminants into nearby creeks;

•    Site-related contamination has been  found in creek sediments
     down  gradient of suspected release points; and

•    The buildings pose a physical hazard and may contain
     potentially friable asbestos.

The potential receptor  groups (i.e.,  on-site workers,
trespassers,  residents)  could be exposed  to contaminants via one
or more of the  following pathways:

•    Inhalation of suspended dust particles from contaminated
     sources  or soils;

•    Dermal contact  with contaminated soil or dust particles;

•    Ingestion  of contaminated  soil or dust particles;

•    Ingestion  of garden vegetables grown in contaminated soils
     (or,  in  the case of children,  ingestion of contaminated
     soil) due  to the migrating particles;  and

•    Inhalation of asbestos fibers.

Currently, on-site workers could inhale contaminants re-suspended
by winds or mechanical  disturbances.   Workers might also ingest
small amounts of soil and dust  or asbestos fibers via  hand-to-
mouth activity.   Dermal contact with contamination is  also
likely, although such exposures should be minimal for  many
chemicals  of  concern, including arsenic and metals.

Evidence of trespassing includes footprints and bicycle tracks
that implicate  children as the  important  site users.    It can be
expected that trespassing also  occurs in  other source  areas and
along the  creeks.  Children,  adolescents,  and adults might also
be expected to  consume  contaminated fish  from the creeks,


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although  there  is  little information on fishing in the creek, and
the creek banks contain warnings posted to warn against fish
consumption.

Children  and young adults trespassing would be exposed to
entrained dust  and soil in the same manner as construction
workers.   Bicycling at the site might provide mechanical
disturbance to  re-suspend contaminated materials in the air
during site visits.   Trespassers might also be exposed via
ingestion of contaminated soil/dust and contact contaminated
waste.  Children especially may be less fastidious about hand
washing,  and may be more likely to play in stockpiled materials
and/or other contaminated areas.   Children might also venture
into flooded basements in some buildings where exposure via
incidental ingestion of and dermal contact with water might
occur.

Residents living near the site may be exposed via inhalation of
contaminants migrating off-site in wind.   These receptors might
also be exposed secondarily to contaminants deposited from air to
residential soils.   These exposures might occur by incidental
ingestion of soil,  inhalation  of re-suspended soils and dust, and
dermal contact  with contaminated soils and dusts.   In addition,
residents could be exposed to  contaminants taken up into garden
vegetables.  This  might be particularly important for COCs like
PCBs, which can bioaccumulate  to a significant degree.

Toxicity  of the Chemicals of Concern

Preliminary data review indicates that high concentrations of
lead are  present both in surface wastes and in the dust located
inside buildings.   These wastes also contain significant
concentrations  of  other metals,  such as arsenic,  as well as PAHs
and PCBs.  Based on the review of the available data,  the
following information is provided regarding the COCs at the Main
Plant.

Metals and Arsenic
Metals and arsenic  are absorbed very poorly through the skin and
little exposure is  expected via this route.   Significant routes
of exposure for metals and arsenic are via inhalation of
particulate (dust)  or incidental  ingestion of soil or dust.   Lead
is likely to be the  metal of greatest concern due  to the usually
high concentrations  detected on-site,  and the sensitivity of
young children  to the toxic effects of this metal.   Increased
blood lead levels  in children,  in the absence of obvious
symptoms,  result in  a decrease in cognitive abilities (Casarett &
Doull,  1991).    Low  level exposures may also cause  slight increase
in adult  blood  pressure.

PAHs
PAHs are  not expected to be efficiently absorbed through the
skin,  although  chronic high level dermal  exposure  to high
molecular  weight PAHs  such as  Benzo(a)Pyrene has been shown to
cause skin cancer  in laboratory animals.   Absorption from the

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lung and  intestine  is  expected to be much more efficient.
Reports in humans show that individuals exposed by inhalation or
skin contact  for long  periods of time to mixtures of compounds
and PAHs  may  develop cancer (ATSDR,  1989).   Studies in laboratory
animals have  confirmed carcinogenesis when PAHs are ingested,
applied to skin, or breathed in the  air for long periods of time.


PCBs
Animal studies with rats  and mice have shown liver effects
following ingestion of PCBs orally or less directly by
consumption of tainted foods via the diet.   Data concerning human
exposure  to PCBs is limited,  but occupational exposures
demonstrate dermal  effects  such as chloracne and irritation of
the eyes  if exposure is via PCB-contaminated mist.  PCBs have
also been shown to  bioaccumulate to  a significant degree,
especially in aquatic  systems.   Bioaccumulation could be
significant where local fish are consumed and/or where local
vegetables are grown in contaminated soils.

Asbestos
Asbestos  fibers have been shown to cause cancer in humans
following inhalation.   The  mechanism for this carcinogenicity is
not clearly defined, but  it is  clear that there is some risk even
when the  numbers of fibers  present per cubic meter of air is very
small.  It is not thought that  asbestos presents a significant
hazard following ingestion  or dermal contact.

The above chemicals are present in mixed wastes and exposures are
expected  to combinations  of chemicals.   There is uncertainty in
evaluating chemical mixtures and little data are available to
accurately characterize such effects.   However,  it is known that,
for example,  cigarette smoking  can exacerbate carcinogenesis
caused by asbestos.  Since  PAHs are  found in substantial
concentrations in cigarette smoke, it is possible that co-
exposure  to PAHs and asbestos might  be associated with greater
risk.  Effects of exposure  to mixtures of  chemicals could be
significant,  especially considering  the very high levels of
contamination found.   The potential  for such effects provides
additional support  for the  proposed  interim  remedial action.

Streamlined Risk Evaluation Conclusion

The results of the  streamlined  risk  evaluation indicate that the
Main Plant source area and  associated buildings are a source of
immediate health risks due  to both physical  and chemical hazards,
and that  it is reasonable and effective to address these health
risks as part of an interim remedy remedial  action.

The streamlined risk evaluation identified the following issues:

•     Metals,  including arsenic,  PCBs,  and PAHs have been
     identified as  COCs.  These contaminants contain levels
     significantly  greater  than each contaminant's respective
     screening value;

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•    Friable  asbestos,  a  known hazardous material,  is present on-
     site  in  some  buildings.   There is the potential for this
     material to be  released  to the environment and migrate off-
     site;

•    The most prevalent mobile exposure route at the buildings is
     through  dust, compared to soil,  which is found in,  around,
     and about the buildings.   Dust is also the most toxic
     medium,  based on lead levels;

•    A number of human receptor groups could be exposed  to
     contamination.   These receptors  include nearby residents,
     trespassers,  (who are known to access the site),  and on-site
     workers  (including emergency response personnel);

•    Physical hazards are associated  with the Main  Plant
     buildings due to the deteriorating structures  which can
     cause physical  injury, such as slips,  trips, and falls.   The
     buildings are not being  maintained and continue to  be a
     physical hazard to trespassers and on-site workers,  as well
     as other safety personnel,  such  as police officers,
     emergency medical technicians,  and firefighters who may
     respond  to incidents at  the site;  and

•    As the Main Plant buildings continue to deteriorate,  there
     will be  increased risk of release of the contaminants
     contained therein, especially  lead dust.

The Main Plant source area, which covers about 94 acres  of the
183-acre site,  could be a source for  approximately  50  percent of
site-wide risk based on land  area alone.   Other sources,  such as
the Markland  Avenue  Quarry, Lagoon  Area,  and Slag Processing
Area, would collectively  make  up the  remainder of site risk.
Current exposures  at these three areas are expected to be smaller
because of the nature of  the  contamination at these areas.   For
example, much of the slag processing  area is slag material,  which
does not release significant metal  concentrations.   The  Markland
Avenue Quarry is effectively  fenced and most contamination is
found at the  bottom  of  the quarry,  underwater and below  vegetated
areas.  The Lagoon Area is also  fenced and does not contain any
structures that would serve as  an attractive nuisance.
Therefore, the Main  Plant source area poses the most  significant
current risks,  based on the likely  short-term exposure scenarios.

Furthermore,  the chemical and  physical  hazards presented by the
Main Plant buildings pose the  bulk  of risks at the  Main  Plant
source area.   Overall,  the majority of  contamination at  the Main
Plant source  area  is primarily due  to the buildings and  the
residual materials they contain.  Also,  the buildings themselves
pose serious  physical hazards  to several  on-site and off-site
receptors.  Based on the  results of previous investigations,  the
lead dust associated with the  buildings  is  the most toxic  medium
at the Main Plant source  area.
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VIII. Description of Alternatives


Alternatives  were  developed based on a streamlined approach to
the traditional process  of  development and screening that would
normally be done under a full-scale feasibility study.   The
streamlined process  uses engineering judgment to identify the
more appropriate and feasible alternatives for meeting the
interim remedial objectives.   Once identified, a systematic and
qualitative comparison of each alternative is performed to
identify the  most  effective and appropriate interim remedial
action.

The streamlined development of alternatives is justified in this
case for the  following reasons.

•    The remedial  action under consideration is an interim
     action.  The  remainder of the Main Plant source area, and
     any unmitigated risks  from the buildings that remain after
     the interim remedy, are  within the scope of study of the
     ongoing  Focused RI/FS  and would be addressed under future
     remediation efforts; and

•    The objectives  of the  interim remedy  are contaminant-related
     and limited to  a single-media source.   The objectives
     include  pollutant source and migration control.

Both source control  and  management of migration alternatives were
considered in the  development process.   Source control  measures
meeting the remedial objectives  would consist of eliminating the
source of risks on-site  (contaminated dust,  PCBs,  PAHs  and
asbestos).    Management  of  migration consists of preventing human
contact with  the site risks (prevent direct contact with
contaminated  dust; prevent  windblown dust  and asbestos;  and
prevent interaction  with physical hazards)  and reducing adverse
impacts to groundwater,  surface  water,  and sediment.

The alternatives considered also involved  disposition of wastes
and debris which have been  stored in the buildings and  debris
from the building  demolition.  The final determination  of the
fate of these materials  has not  been made,  but there are a
limited number of  alternatives.   First,  the Final  Remedial Action
for the site  may include an on-site landfill.   Some wastes could
be disposed of on-site in a land disposal  unit,  if the  unit
selected in the final remedy  and construction of the unit could
be completed  to coincide with this interim remedy.   If  the final
remedy does not coincide with construction of a land disposal
unit, waste materials and construction  debris which are
contaminated  will  be disposed of off-site  at a compliant facility
which is permitted to accept  the material.   Floor  blocks
contaminated  with  PCBs will be disposed off-site at a compliant
hazardous waste facility which is permitted to accept PCB waste.
Demolition debris  and rubble  will be characterized,  and,  if
hazardous,  will be disposed at a hazardous  waste facility.
Special waste and  non-hazardous  waste will  be disposed  at a solid

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waste  facility permitted to accept special waste or non-hazardous
waste  as  is  appropriate.

Four alternatives  were identified using this streamlined
development  process.   These alternatives include a "no action"
alternative  for baseline comparison purposes.  Each alternative
is outlined  in the following section.

Identification of  Alternatives

The four  potential alternatives include two source-control
alternatives which are gross decontamination and subsequent
demolition of  the  buildings and decontamination only of the
buildings.   One alternative intended to manage migration of
contaminants was developed.   This alternative is a limited action
alternative  consisting of securing the buildings and postponing
remedial  activities concerning the buildings until after the
site-wide Focused  RI/FS is complete.  A fourth alternative, no
action, is included to ensure a complete evaluation and serves as
a baseline comparison.   A summary of the major components of each
alternative  is provided below.

Alternative 1: No Action
Estimated Present  Worth Cost:  $0
Estimated Time Frame:  Indefinite

This alternative would leave the Main  Plant area in its current
state  until  the site-wide Focused RI/FS is completed and
appropriate  actions undertaken for the site in its entirety.  Any
potential remediation  of  the buildings would be evaluated as part
of the site-wide Focused  RI/FS.

Alternative 2: Immediate Decontamination and Demolition of the Main Plant
Buildings
Estimated Present  Worth Cost:  $8,160,000
Estimated Time Frame:  12-18  months

This alternative would include  a gross decontamination followed
by demolition  of all building  structures.   The major components
of this alternative remedy include:

•     Gross removal of  lead dust  from contaminated  building
     interiors using vacuuming  and/or  pressure washing with
     disposal  of dust  as  hazardous waste in a permitted facility;

•     Management and proper disposal of rinsate collected from
     decontamination.   Rinsate water will  be managed as hazardous
     waste until receipt  of  waste characterization analyses;

•     Asbestos  abatement by removal and disposal  at a permitted
     facility  of exposed  friable asbestos-containing materials
     and  asbestos  containing building  insulation;

•     Confirmation  sampling to ensure proper decontamination;


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•    Removal  of  PCB-contaminated wood block floors and disposal
     as hazardous  waste;

•    Demolition  of all building superstructures, tanks, and
     equipment to  grade,  leaving floor slabs;

•    Salvaging of  structural steel as scrap unless it can be
     decontaminated and reused as originally intended;

•    Disposal of all debris  and demolition rubble as hazardous,
     special  or  non-hazardous waste as determined by waste
     characterization;

•    Use of water  spray for  dust control during demolition.   Dust
     control  water runoff will be contained and managed properly
     to prevent  the transport of contaminants from the immediate
     demolition  site;

•    Pumping  out flooded  basements,  removal of equipment and
     residue  from  basements,  and filling of basements.  The
     pumped water  will  be managed as hazardous waste until
     receipt  of  waste characterization analyses;

•    Filling  or  covering  of  pits;

•    Confirmational sampling to verify effectiveness of
     decontamination;

•    Finishing of  unpaved areas with crushed stone;  and

•    Securing of the site after the  interim remedy is completed.

The decontamination required for this option will be to remove
gross accumulations of  contaminated  materials.   This will improve
the effectiveness  of dust control  measures  during demolition.
The scope of this  alternative includes containment of dust and
rinsate runoff water to prevent the  transport of building
contaminants from  the site.   These measures will include features
such as collection troughs and/or  plugging  of storm drains.  The
collection troughs will empty into a concrete or similar
impervious material sump.  The sump  design  and sump capacity will
allow for rain events.  The  sump water will be characterized and
properly disposed  of, at  a minimum,  every 90 days.

The objective for  finishing  the site after  demolition will be  to
eliminate the physical  hazards posed by the remaining pits and
cellars, where feasible.  These areas  will  be filled or otherwise
secured from entry.

All material and debris will  be treated and/or decontaminated  in
a manner consistent with  the  requirements of the ultimate
disposal location  including  40  CFR 268.45.   Waste
characterization will determine the  waste stream disposal
location.   Some wastes  could  be disposed of on-site  in a land


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disposal unit  if  that were selected in the final remedy Record of
Decision and construction of such a land disposal unit could be
completed to coincide with this interim remedy.  Otherwise, the
waste will be  disposed of off-site in an appropriate RCRA
landfill based on the waste characterization.
Upon completion of decontamination and disposal activities, the
site would be  properly secured to protect human health and the
environment.

Alternative 3: Immediate Decontamination of the Main Plant Buildings
Estimated Present Worth Cost:  $7,700,000 up to $9,400,000
Estimated Time Frame:  12 months to 3.5 years for site security

This alternative  is intended to eliminate contaminants that are
mobile  in air  and to  secure the site to restrict access.   The
components of  this alternative are as follows.

•    Thoroughly remove dust in contaminated building interiors
     using vacuum methods followed by pressure washing;

•    Dispose of dust  as hazardous waste;

•    Manage and properly dispose of rinsate collected from
     decontamination;

•    Remove and dispose of stored contaminants in all buildings,
     including drums,  bags and piles of  lead dust,  and personal
     protective equipment;

•    Remove PCB contaminated wood block  floors and dispose as
     hazardous waste;

•    Conduct confirmational sampling to  ensure proper
     decontamination;  and

•    Provide 24-hour  security  patrol.

The intent of  this  alternative is to secure the site on an
interim basis  to protect the surrounding  community from the
threat of windblown transport  of contaminants  by removing the
source of contamination.   While gross decontamination is
sufficient for Alternative 2 because the  building and any
residual contamination would be removed,  Alternative 3 would
require a more thorough decontamination.   With  the buildings
remaining, complete removal of contaminated dust from all
accessible surfaces will be necessary to  achieve the protection
stated.  In addition,  all materials  currently  stored in the
buildings will  be disposed of  properly.   The majority of  these
materials include various drums,  bags and piles of lead dust,  and
protective equipment.   Any  contamination  from the basements and
pits will not  be addressed  in  this  alternative,  nor will  asbestos
abatement be performed.   The majority of  the asbestos material in
the buildings  consists  of transite  and galbestos which is
contained in the building walls.  Therefore, this material could
not be removed  until the buildings walls  are demolished.

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Demolition  activities for the buildings under this alternative
would be  evaluated as part of the final remedy.  The enhanced
security  measures  are intended to prevent unauthorized access to
the Main  Plant  source area and to prevent trespassers from
encountering  the physical hazards on-site.  As part of this
alternative,  the site will be secured to protect human health
(i.e., trespassers and on-site workers) and the environment until
site remediation is complete.

Alternative 4: Securing of the Main Plant Buildings as an Interim Action (Limited
Action)
Estimated Present  Worth Cost:  $8,327,000
Estimated Time  Frame:  12 months to 3.5 years for site security

This alternative consists of  enhancing security on-site and
performing  physical repairs and modifications to the buildings to
prevent windblown  contamination from exiting the buildings or
humans from entering the buildings.   The components of this
alternative are as follows.

•     Secure all contaminated  buildings to prevent windblown dust;
     repair or  cover broken windows,  siding and roofs;

•     Enclose  semi-open structures;

•     Repair and/or replace site perimeter fence;

•     Implement  regular maintenance  of buildings and enclosures
     and  regular maintenance  of security fencing; and

•     Provide  24-hour security  patrol.


The intent  of this alternative is to  secure the site on an
interim basis to protect the  surrounding community from windblown
contaminant transport and to  eliminate the potential risks to
trespassers,  on-site workers  and the  environment until site
remediation is  completed.   This alternative defers actual
contaminant removal actions,  if needed,  until implementation of
the site-wide remediation.
IX.  Summary of the Comparative Analysis of Alternatives


The National Contingency  Plan requires  evaluation of alternatives
based on nine criteria by which  technical,  economic, and
practical factors associated with  each  remedial alternative must
be judged.  The nine criteria are  categorized into three groups:
threshold criteria, primary balancing criteria, and modifying
criteria.  The nine evaluation criteria are summarized below
along with a comparative  analysis  of the alternatives.

Threshold Criteria must be satisfied in order for an alternative


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to be eligible  for  selection.   The two threshold criteria are: 1)
overall protection  of  human  health and the environment; and 2)
compliance with applicable or  relevant and appropriate
requirements:

     1)   Overall 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.

Under Alternative 1, no measures would be taken to control or
remediate the contamination  in the Main Plant buildings during
the  interim time frame.   This  alternative provides a basis of
comparison for  evaluating other proposed  remediation
alternatives.   The  no  action alternative  does not preclude future
demolition or decontamination  of the  Main Plant buildings as part
of future site  remediation work.

The  no action alternative is a feasible alternative when
contaminant concentrations are already within levels that
correspond to an acceptable  risk.   Presently,  this is not the
case, where lead contaminant levels currently present risks to
human health from ingestion  and other chemical constituents and
asbestos are present.   In addition, the current deteriorated
condition of the building structures  also presents a physical
hazard.  There  is the  potential for falling  building material
from some areas  of  the buildings and  there are open pits  that
trespassers may  slip on,  trip  on,  or  fall into.

As the residual  dust contamination within the buildings migrates
off-site, natural processes  (dilution)  act to reduce contaminant
levels in the various  environmental media.   The no action
alternative depends solely on  these natural  processes to
significantly reduce contaminant levels to where no significant
risk is present.  Since the  no action  alternative does not
satisfy the threshold  criteria,  no further criteria evaluations
are  considered.

Alternative 2 is immediately protective of both human health and
the  environment, since it reduces  the  potential for residents to
be exposed to contaminated windblown  dust, and for on-site
trespassers to be exposed to the contamination within the
buildings.  Demolition of the  buildings would also provide two
additional benefits.   First, the demolition  of the buildings
would eliminate  the attraction of  trespassers  to gain access to
the  site.  Secondly, the  demolition of the buildings would make
future remediation activities  in the building basements and
underlying soils more  efficient  and effective.   Previous  field
investigations have identified potential  contamination in the
basements of some of the  buildings, as well  as in pits within the
buildings, that may require remediation.   It is reasonable to
conclude that subsurface  soil  contamination  in these areas may
exist,  requiring eventual demolition of the  affected buildings


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prior to  remediation.

Alternative  3 would be protective of human health and the
environment  since  contamination in buildings would be reduced
significantly.   However,  lack of structural integrity of some
building  areas  would still  be a safety concern for the public.

Alternative  4 could be considered somewhat protective to human
health and the  environment  since the site would be secured and
access to the public restricted.   However,  control of access must
be maintained.   In addition,  enhancing security at the site would
not prohibit migration of contamination down gradient to
residential  areas  or the  creeks.   However,  physical repairs made
on some buildings  would prevent some migration of windblown
contamination from exiting  the buildings or humans from entering
the buildings.

     2)   Compliance with Applicable or Relevant and Appropriate
     Requirements  (ARARs) addresses whether a remedy will meet
     all  of  the ARARs of  other Federal and State environmental
     laws and/or justifies  a  waiver.   The selected remedy must
     meet this  criteria or  waiver of the ARAR must be attained.

The remedies for the site are subject to Applicable or Relevant
and Appropriate Requirements  which are federal and more stringent
state regulations.   ARARs have been determined in accordance with
121(d)(2) of CERCLA,  as amended by the Superfund Amendments and
Reauthorization Act (SARA)  of 1986.   These ARARs are also
consistent with the National  Contingency Plan (NCP)  40 CFR Part
300, amended March 8,  1990.   ARARs are federal or state
requirements that  the  remedial alternative(s)  must achieve,  that
are legally  applicable to the substance,  or that are relevant and
appropriate  under  the  circumstances.   Administrative requirements
such as agency  approvals, record  keeping and reporting,  and
obtaining permits  for  on-site activities such as waste disposal
regulated by states or municipalities would not be considered
ARARs.

Alternative  2 would meet  or exceed all ARARs for contamination
due to the buildings (see pages  36-40,  ARARs numbered 1-28)V

Alternative  3 would comply with all  ARARs.   However,  asbestos may
become more  friable in the  future and cause a release which would
be in violation of  326  IAC  14.

Alternative  4 would not comply with  all  ARARs.   This  alternative
would not prevent  all  migration of contamination associated with
or stored inside the building structures and would,  therefore,
not be in compliance with 329  IAC 3.1  or 40  CFR 256.

Primary Balancing  Criteria are used  to weigh major tradeoffs
among alternatives:

     3)    Long-term Effectiveness  and  Permanence refer to
     expected residual risk and the  ability  of  a remedy to

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     maintain  reliable protection of human health and the
     environment over time,  after cleanup goals have been met.

Alternative  2  would provide  the greatest long-term effectiveness
and permanence.   The windblown dust risk would be eliminated
because the  gross decontamination and demolition of the buildings
would remove the source of contamination.   The deteriorated
condition of the buildings poses a constant threat of collapse
and resultant  release of contaminants.   This alternative holds a
secondary benefit in that it would eliminate physical hazards due
to the lack  of building structural integrity.   Also,  pits and
basements would  be filled or secured.   This alternative is
integral to  the  final remedy since the buildings will need to be
removed or substantially reinforced to remediate the source area.

Alternative  3  would also provide significant effectiveness in
preventing human contact with the contaminants over the long-
term, but not  to the same extent as Alternative 2.   The lack of
complete long-term effectiveness is due to the fact that
decontamination  of the buildings,  however  thorough,  would only
remove contaminants from accessible areas.   Some contaminants in
the form of  dust would remain in cracks,  small spaces,  between
wall panels, and other inaccessible areas.   Trapped dust will
eventually be  released during demolition of the buildings in the
future.  This  recontamination will reduce  long-term
effectiveness.

Building decontamination is  unlikely to be completely permanent
over the long-term.   It is likely that  contaminants existing in
the soils outside of the buildings would migrate back into and
onto the buildings.   This recontamination  could occur by human
activity (trespassers and/or site workers)  or  via transportation
as wind-blown  dust.   The likelihood of  wind-blown recontamination
of the buildings is especially high in  the buildings  that have
large openings to the outside.

The long-term  effectiveness  of alternative 4 would depend on the
propejr maintenance of the building enclosures,  and on security
measures, which  may be difficult to implement  at the  site.

     4)   Reduction of Toxicity,  Mobility/  or  Volume  through
     Treatment is the anticipated performance  of the  treatment
     technologies a remedy may employ.

Alternative  2, gross  decontamination and demolition of  the
buildings,  will  eliminate mobility of contaminants  associated
with the buildings.   The  gross  decontamination of  the buildings
would reduce the potential for  contaminants to migrate  off-site
during demolition.  The  final  demolition of the buildings would
eliminate any  future  contaminant migration  from the building due
to further deterioration  (i.e.,  asbestos deterioration).   The
demolition would also reduce the physical  hazards  associated with
the dilapidated  buildings and  eliminate an attraction for
trespassers to gain access to  the  site.
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Alternative  3 would  remove contamination from the buildings and
therefore should  significantly reduce toxicity,  mobility,  and
volume of contamination to residual levels.   Asbestos may still
become more  friable  in the future.   The risk to physical hazards
would increase with  time.

Alternative  4 would  not reduce toxicity and  volume of
contamination since  no remedial measures would be taken to remove
or reduce this contamination.   However,  by securing the site from
unauthorized access  and making repairs on some buildings,
mobility to  trespassers and nearby  residents would be
significantly reduced.   Security personnel would be protected by
protective equipment as necessary.

     5)   Short-term Effectiveness  addresses the period of time
     needed  to achieve protection and any adverse impacts  on
     human health and the  environment that may be posed during
     the construction and  implementation period  until cleanup
     goals are achieved.

Alternative  2 can be readily implemented by  standard construction
means and equipment.   Dust control  measures  and  protective
equipment may protect workers.   Also,  dust control measures could
protect and  not affect off-site residents.   Therefore,  this
alternative  would be considered effective in the short-term.   The
objective of remedial actions  for the buildings  are interim and
therefore, must be effective in the short-term to be considered
appropriate.

Alternative  3, would significantly  reduce the short-term
potential for the spread of contamination from the buildings  due
to windblown transport of  dusts.  The decontamination would
consist of the complete removal of  all accessible accumulated
dust from the interiors of the  buildings  and disposal of the
collected material at an appropriate  RCRA facility.   However,  due
to lack of structural integrity of  some  buildings,  it would not
be possible  to complete decontamination  activities in these areas
without some structural bracing.

This alternative  would also significantly reduce the potential
for direct contact with the contaminants  by  trespassers  and
workers.  Both dust  and PCB contaminated  flooring would  be
removed from potential  human contact.  It is anticipated that the
decontamination operation  could allow future non-intrusive
investigative activities within the buildings  to be  performed
without respiratory  protection.   Workers  could be protected on-
site by dust control  and protective equipment, and off-site
residents could be protected by dust  control measures implemented
at the site.

This alternative  does  not  address the  risk of  the physical
hazards within the buildings due  to the deterioration of the
structures or due to  the physical features (i.e.,pits and  flooded
basements).
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Alternative  4 would  be effective in reducing public exposure to
the risk of  windblown contaminants migrating from the buildings.
It would also be  effective in preventing trespassers from
contacting contaminants and from encountering physical hazards
inside the buildings.   Securing the buildings would not be
effective in protecting on-site workers from these same risks or
residents from  exposure to windblown dust in soils outside the
buildings.

     6)   Implementability is the technical and administrative
     feasibility  of  a remedy,  including the availability of
     materials  and services needed to implement a particular
     option.

Alternative  2 would  be implementable and would require no special
technology.

Alternative  3 can be accomplished using readily available
equipment and techniques.   It is anticipated that all accessible
interior surfaces would be cleaned of accumulated dust using HEPA
vacuums.  Pressure washing of the interiors using fire hoses or
power washing equipment would follow.   Man-lift equipment would
be used to reach  the upper interiors of the buildings.   Some
structural rehabilitation  may be required to allow for
decontamination in a safe  environment.

Alternative  4 is  technically feasible.   Practical implementation
of this alternative  would  be difficult since fences around the
site have continually  been breached.   However,  security personnel
would help to prohibit unauthorized access.

Enclosing the various  buildings  to prevent the  escape of
contaminated dust would essentially require "weatherproofing" the
structures.  The  type  and  size of the repairs and/or new
construction required  to accomplish the weatherproofing would
vary depending  on the  building.   Most of the buildings  would
require repairs to the roofs,  windows,  siding,  and doorways to be
sufficient.  Due  to  the dilapidated condition of  several
buildings, it is  questionable  whether these repairs can be made
safely and effectively.  Building No.  11,  for example,  is  typical
of many buildings.   It has a built-up asphalt roof over wooden
planks.  The wood roof is  rotten and has collapsed in several
locations.  Covering the collapsed portions of  this roof would be
difficult to accomplish safely,  and would probably cause
additional areas  to  collapse.

Several larger buildings are either semi-enclosed (e.g., Building
No. 5)  or have expansive openings (e.g.,  Building No.  125).
These buildings would  require  a  significant construction effort
to enclose.  Maintaining the integrity  of the building  enclosures
is expected to be an ongoing effort.  The age and nature of the
plant's construction will  constantly result in  new breaches in
the exterior skin of the buildings.   As  an example,  evidence of
the loss of building siding  was  noted  in a recent site
reconnaissance conducted on  September  13  and 14,  1995.


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Practical  implementation  of  the security enhancements identified
under this alternative  would also be difficult.   Currently,  the
Main Plant source area  is protected by a security fence around
the perimeter of the  site.   This fence is regularly breached by
trespassers, despite  efforts to maintain the fence.  Construction
of a new fence around the site  or repair of  the  existing fence is
unlikely to remedy this situation.   Evidence of  bicycle tracks
and footprints indicates  that trespassing is being committed by
local children and adolescents.   The attractiveness of the site
to this age group will  only  increase as investigative and
remedial activities commence.

Security patrols are  a  component of this alternative and would be
the most effective means  of  deterring unauthorized entry.   The
characteristics of the  Main  Plant,  however,  would make security
patrols difficult to  implement  completely.

     7)   Cost includes estimated capital and O&M costs,  also
     expressed as net present worth costs assuming 3.5 years of
     O&M until a final  remedy for the site can be implemented.

Costs for Alternative 2 are  based on the site reconnaissance
performed on August 23, 1995.   The  demolition-related costs  are
outlined as follows:

Demolition and Gross  Decontamination Cost     $  8,500,000
Salvage Value                                  $   -960,000
Design Engineering Allowance                  $    200,000
Construction Management Allowance             5    420fOOO
         Total Demolition Cost                 $  8,160,000

This cost is given in 1995 dollars.   This estimate considers
decontamination, demolition,  dust suppression, waste treatment,
basement and rinsate  water collection and treatment and scrap
steel salvage prices  as of August 1995.

Costs for Alternative 3 were derived from the decontamination
components of the demolition costs.   Accounting  for the fact that
decontamination efforts would be more thorough under this
alternative than under  the demolition alternative,  it is
estimated that immediate  decontamination of  the  Main Plant
buildings would cost  between $3.9 million and $5.6 million.

If significant structural modifications  are  required to allow
decontamination, the  estimated  cost  would be at  the high  end of
this range.  Collection and  treatment of rinsate and dust
suppression water are required;  therefore, the estimated  cost
could exceed this range.

As stated earlier, the  most  likely ultimate  fate of the buildings
is demolition due to  subsurface  and  foundation contamination.   It
is assumed that this  action  would be necessary even if immediate,
thorough decontamination  of  the  buildings is performed.
Decontamination work  required for future demolition under  this
alternative would consist only of asbestos abatement work,

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because the  gross  removal  of  contamination dust,  included in
Alternative  2,  would not be required.   The present worth cost of
future demolition  and asbestos  abatement is calculated to be
approximately  $3,760,000.  Thus,  the total long-term cost of
addressing the buildings,  if  Alternative 3 is used, would be in
the range of $7.7  million  to  $9.4 million.

Costs for Alterative 4 corresponds with commencement of
anticipated  final  remedy remedial activities and  the end of the
"interim" period.   Additionally, as in Alternative 3, the present
worth cost of  future demolition should be considered in
evaluating the true  long-term cost of  addressing  the buildings
under this alternative.  This cost also includes  approximately
8,000 feet of  new  security fencing and security patrols for a
3.5-year period.   The remaining sum consists of an estimated cost
for repairs  and modifications required to weatherproof the
buildings, and for engineering  during  design and  construction.
This estimate  is considered approximate,  because  an accurate
scope of the work  required to weatherproof the buildings would
require an extensive inspection of each building.

A summary of the costs for this alternative is as follows:

Repairs and  modifications  to  secure
         buildings                            $1,337,000
Security fencing                               $  200,000
Security patrols                               $  350,000
Present worth  cost of future  demolition       $6, 440f OOP
                Total cost                    $8,327,000

The cost of  this alternative, for comparison purposes,  is
$8.3 million.

Modifying Criteria are usually  taken into account after public
comment is received  on the Feasibility Study report and the
Proposed Plan.  These criteria  are:

         8)  Support  Agency Acceptance reflects aspects of the
         preferred alternative  and other alternatives that the
         support agency favors  or objects to, and any specific
         comments  regarding ARARs or the proposed use of
         waivers.

The U.S. EPA and the IDEM  have  been involved throughout the site-
wide Focused RI/FS and the Interim Risk Assessment/Feasibility
Study - Main Plant Buildings.   The Agencies concur with the
selected remedy which is Alternative 2.

         9)  Community Acceptance

The attached Responsiveness Summary summarizes the public's
general response to  the alternatives described in  the Proposed
Plan and in  the Feasibility Study report  and addresses  questions
and concerns expressed during the public  comment period.  The
commentors were generally  very  supportive of the proposed remedy.

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The selected  remedy is the same remedy that was proposed in the
Interim Remedy Proposed Plan fact sheet.
X. The Selected Remedy
Based on consideration of  the  requirements of CERCLA,  the
detailed analysis  of  the alternatives,  and public comments, IDEM
and U.S. EPA,  Region  V have  selected Alternative 2 as  the most
appropriate  interim remedy remedial action for the Main Plant
buildings of the Continental Steel  Superfund site in Kokomo,
Howard County,  Indiana.

Alternative  1  is not  protective  of  human health or the
environment.   Alternatives 2,  3  and 4 meet the threshold criteria
for overall  protection of  human  health.   However,  because the
buildings would be left standing, safety of trespassers and on-
site workers would still be  a  concern for Alternatives 3 and 4.
Alternatives 2  and 3  would be  compliant  with ARARs.  Only
Alternative  2  would achieve  long-term effectiveness and
permanence.

Alternatives 2  and 3  would reduce contaminant toxicity,  mobility,
and volume through decontamination  and removal of  contaminants,
have short-term effectiveness  and be implementable.  Alternative
4 does not achieve any of  these  balancing criteria.

Short-term costs of Alternative  3 and 4  are smaller than
Alternative  2.  When  considering, however,  that additional
demolition costs are  very  likely to be incurred in the future if
Alternative  3  or 4 is selected now,  the  long term  costs of
Alternative  2  and  4 are about  the same.   Even evaluating long-
term costs,  Alternative 3  could  cost slightly less that the other
two alternatives,  but this cost  advantage could prove  illusory,
because it most likely will  cost up to $1 million  more than the
FS estimate  due to anticipated building  repair and/or
reconstruction.

The U.S. EPA and the  IDEM  concurrence and community acceptance
further support the decision that Alternative 2 -  Immediate
Decontamination and Demolition of the Main Plant Buildings
provides the best  balance  of trade-offs  with respect to the nine
criteria used  for  remedy selection.

The selected interim  remedy  for  the Main Plant buildings is the
same preferred  alternative presented in  the Interim Remedy
Proposed Plan developed and  issued  by IDEM.   Details of  the
components of the  remedy may be  altered  as  a result of the
remedial design and field  conditions encountered during
construction.   As  viable potentially responsible parties have not
been identified to date, IDEM  will  submit an application for a
Cooperative  Agreement  with the U.S.  EPA  to  complete  construction
of the interim  remedy  action and any modifications necessary to

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implement  the  selected interim remedy.

The  selected interim remedy is a physical remediation or source
control method.   Gross decontamination and demolition of the
buildings  would  be  conducted.   The contaminated dust would be
collected  during gross decontamination and disposed of as
hazardous  waste  along with the other waste from prior cleanups
which has  been temporarily stored in some of the buildings on-
site.  The building demolition material would be disposed of as a
non-hazardous  waste where possible and as a special or hazardous
waste where required.   The gross decontamination of the buildings
would provide  the greatest opportunity to optimize the amount of
demolition material that can be recycled or re-used.
XI. Statutory Determinations
The selected remedy must  satisfy the requirements of Section 121
of CERCLA to protect  human health and the environment and Comply
with ARARs.  CERCLA also  requires that the selected remedial
action be cost effective;  utilize permanent solutions and
alternate treatment technologies to the maximum extent
practicable; and  satisfy  the  preference for treatment as a
principle element of  the  remedy.   Below is a summary of how the
selected remedy meets these statutory requirements:

Protection of Human Health and  the Environment

Implementation of the selected  interim remedy will eliminate
potential risk to human health  from exposure to contaminates of
concern shown on  Table 2.

No unacceptable short-term risk or cross-media impacts will be
caused by implementation  of the selected interim remedy.

Compliance with ARARs

The selected interim  remedial action will meet all identified
applicable or relevant and appropriate Federal and more stringent
State requirements.   The  ARARs  are classified as chemical,  action
and location-specific.  The ARARs are listed below:

Chemical-Specific Requirements

(1)      Clean Air Act (42 USC  7401 et seq.), National Primary
         and Secondary Ambient  Air Quality Standards  (40 CFR 50)
         [EPA Regulations on  National Primary and Secondary
         Ambient  Air  Quality  Standards].

(2)      Clean Air Act (42 USC  7401 et seq.), National Emission
         Standards for Hazardous Air Pollutants (40 CFR 61),
         Subpart  M, National  Emission Standards for Asbestos.
         [Standards for demolition and renovation, asbestos


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          waste disposal].

 (3)       Solid Waste Disposal Act, as amended  (42 USC  6901,  et
          seq.)/ Land Disposal Restrictions  (40 CFR  268)  Subpart
          D, Treatment Standards [Sets the treatment standards
          for waste extract, specified technology, hazardous
          waste debris].

 (4)       Solid Waste Disposal Act, as amended  (42 USC  6901,  et
          seq.), Identification and Listing  of Hazardous  Waste
          (40 CFR 261) Subpart B, Criteria for Identifying  the
          Characteristics of Hazardous Waste and for Listing
          Hazardous Waste [Sets criteria for identifying  a
          hazardous waste].

 (5)       Solid Waste Disposal Act, as amended  (42 USC  6901,  et
          seq.)/ Identification and Listing  of Hazardous  Waste
          (40 CFR 261) Subpart C, Characteristics of Hazardous
          Waste [Identifies the characteristics of a hazardous
          waste].

 (6)       Solid Waste Disposal Act, as amended (42 USC  6901,  et
          seq.)/ Identification and Listing  of Hazardous  Waste
          (40 CFR 261) Subpart D, List of Hazardous  Waste [List
          of hazardous waste from sources].

 (7)       Toxic Substances Control Act, (15 USC 2601, et  seq.),
          PCB use prohibitions (40 CFR 761).   [Identifies storage
          and handling requirements for PCBs].

 (8)       Air Pollution Control Board (Title 326),  Article  6  -
          Particulate Rules, Fugitive Dust Emissions  (326 IAC 6-
          4) [Sets emission  limitations for particulate].

 (9)       Air Pollution Control Board (Title 326),  Article  14 -
          Emission Standard  for Hazardous Air Pollutants,
          Emission Standards for Sources of Asbestos Listed in
          Section 1 of this  Rule (326 IAC 14-2)  [Presents a list
          of asbestos sources subject to federal standards].

 (10)      Solid Waste Management Board (Title 329),  Article 2 -
          Solid Waste Management, Solid Waste Facility
          Classification  and Waste Criteria  (329 IAC 2-9)
          [Describes construction/demolition sites  waste criteria
          and restricted  waste sites waste criteria].

 (11)      Solid Waste Management Board (Title 329),  Article 2 -
          Solid Waste Management, Special Waste (329 IAC 2-21)
          [Defines what qualifies as a special waste, including
          asbestos containing waste,  and waste characterized as
          hazardous waste; describes the technical  criteria for
          characterizing  special waste and generator
          responsibility  for special waste disposal].
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 (12)      Solid Waste Management Board  (Title  329), Article 3.1 -
          Hazardous Waste Management Permit Program and  Related
          Hazardous Waste Management, Identification  and Listing
          of Hazardous Waste (329 IAC 3.1-6) [Sets list  and
          exemptions of hazardous waste].

 (13)      water Pollution Control Board  (Title 327),  Article 2  -
          Water Quality Standards (327 IAC 2-1-7 and  2-1-1.5)
          [Sets requirements for Water Quality Effluent  and
          includes Interim Groundwater Quality Standards].

Location-Specific Requirements

 (14)      Solid Waste Disposal Act,  as amended (42 USC 6901,  et
          seq.), Guideline for the Land Disposal of Solid Wastes
          (40 CFR 241),  Part B - Requirements and Recommended
          Procedures [Solid, nonhazardous wastes generated  as a
          result of remediation must be managed in accordance
          with federal  and state regulations; this is applicable
          to waste generated by the remedial action].

 (15)      Air Pollution Control Board (Title 326), Article  2  -
          Permit Review,  Construction Permits  (326 IAC 2-1)  [Sets
          substantive requirements for obtaining a permit prior
          to construction or modification].

Action-Specific Requirements

 (16)      Noise Control  Act, as amended (42 USC 4901, et seq.);
          Noise Pollution and Abatement Act (40 USC 7641, et
          seq.), Noise  Emission Standards for Construction
          Equipment (40  CFR 204)  [The public must be protected
          from noise that jeopardize health and welfare].

 (17)      Solid Waste Disposal Act,  as amended (42 USC 6901,  et
          seq.), Standards for Hazardous Waste Generators (40 CFR
          262)  and Standards for Hazardous Waste Transporters (40
          CFR 263); [General requirements for packaging,
          labeling, marking, and manifesting hazardous wastes for
          temporary storage and transportation off-site].  Any
          residues determined to be  RCRA hazardous waste destined
          for off-site disposal are  subject to manifest
          requirements.   Remedial actions involving off-site
          disposal of RCRA listed wastes will be subject to this
          requirement.

 (18)      Solid Waste Disposal Act,  as amended (42 USC 6901, et
          seq.), Land Disposal Restriction-RCRA (40 CFR 268)
          [RCRA Land Disposal Restriction, defines hazardous
          waste debris.   This requirement is applicable to those
          RCRA hazardous  wastes that will be disposed off-site].

(19)      Solid Waste Disposal  Act,  as amended (42 USC 6901, et
          seq.), Solid Wastes (40 CFR 264),  Subpart B, General


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          Facility Standards; Subpart C, Preparedness and
          Prevention; Subpart D, Contingency Plan and Emergency
          Procedures; Subpart E, Manifest System, Record Keeping
          and Reporting [Establishes general requirements for
          waste compatibility determination, emergency
          contingency plans, preparedness plans, and worker
          training].

 (20)      Solid Waste Disposal Act, as amended  (42 USC 6901, et
          seq.)/  Solid Wastes (40 CFR 264), Subpart I, Use and
          Management  of Containers; Subpart J, Tank Systems;
          Subpart L,  Waste Piles.  [Containers used to store
          hazardous waste must be closed and in good condition.
          Tank systems must be adequately designed and have
          sufficient  structural strength and compatibility with
          the wastes  to be stored or treated to ensure that it
          will not collapse, rupture,  or fail, including
          secondary containment.  Waste piles must be designed to
          prevent migration of wastes out of the pile into
          adjacent subsurface soil or groundwater or surface
          water at any time during its active life].

 (21)      Solid Waste Disposal Act, as amended (42 USC 6901, et
          seq.),  Solid Wastes (40 CFR 264), Subpart D, [Hazardous
          waste and debris may be placed in units known as
          containment buildings for the purpose of interim
          storage or  treatment].

 (22)      Air Pollution Control Board (Title 326), Article 14 -
          Emission Standard for Hazardous Air Pollutants,
          Emission Standards for Asbestos; Demolition and
          Renovation  Operation (326 IAC 14-10)  [Sets the
          notification requirements ,  procedures for asbestos
          emission control and demolition fees for demolition
          projects where asbestos may be present].

 (23)      Water Pollution Control Board (Title 327), Article 5 -
          Storm Water Run-off Associated with Construction
          Activity (327 IAC 15-5)  [Sets requirements for managing
          storm water during construction activities,  including
          sediment and erosion control].

 (24)      Solid Waste Management Board (Title 329),  Article 3.1 -
          Hazardous Waste Management Permit Program and Related
          Hazardous Waste Management,  Standards Applicable to
          Generators  of Hazardous Waste (329 IAC 3.1-7)  [Lists
          those standards applicable to generators of hazardous
          waste,  including manifesting].

 (25)      Solid Waste Management Board (Title 329),  Article 3.1 -
          Hazardous Waste Management Permit Program and Related
          Hazardous Waste Management,  Standards Applicable to
          Transporters of Hazardous Waste (329  IAC 3.1-6)  [Same
          standards as 40 CFR 263].
                             Page 39
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 (26)      Solid waste Management Board (Title 329), Article  3.1  -
          Hazardous Waste Management Permit Program and Related
          Hazardous Waste Management, Interim Status Standards
          for Owners and Operators of Hazardous Waste Treatment,
          Storage,  and Disposal Facilities (329 IAC 3.1-10)  [Same
          standards as 40 CFR 256].

 (27)      Solid Waste Management Board (Title 329), Article  3.1  -
          Hazardous Waste Management Permit Program and Related
          Hazardous Waste Management, Land Disposal Restrictions
          (329 IAC 3.1-12) [Sets standards for land disposal
          restrictions and the adoption of federal land disposal
          restrictions].

 (28)      Solid Waste Management Board (Title 329), Article  9 -
          Underground Storage Tanks, Corrective Action (329  IAC
          9-5)  [Sets standards for release response, and
          corrective action,  including abatement measures,
          characterization,  and free product removal].

Cost Effectiveness

Cost effectiveness  is  determined  by evaluating  the overall
effectiveness proportionate  to  costs,  such that the selected
interim remedy  represents a  reasonable value  for  the money to be
spent.  The estimated  cost of the selected interim remedy is
comparable to the expected costs  of the  other two alternatives in
the long run.

Utilization of  Permanent  Solutions and Alternative Treatment
Technologies or Resource  Recovery Technologies  to the Maximum
Extent Practicable

The selected interim remedy  provides the most effective  and
permanent long-term solution to the threat of the Main Plant
buildings and materials inside  them.

Preference for  Treatment  as  a Principal  Element

The selected interim remedy  utilizes removal  and  treatment of
wastes and wastewater  as  its principal elements.

Documentation of Significant Changes

IDEM determined that no significant changes to  the  interim remedy
as it was identified in the  Interim Remedy Proposed Plan  are
necessary.
                             Page 40
Interim Remedy Record of Decision * Continental Steel Superiund Site • July 25, 1996

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                                                         Qril/xj
                                          y   , —^.-i+, -.     -v. ^l
                                          [	K : Foster Park   . J
                                          : — ~'r f^js^ijsasv?' ' =.iilii^
   SLAG PROCESSING
   CHAFF1N QUARRY
                               MAIN PLANT
                                               MARKLAND AVE
                                                  QUARRY
iflc\  i -r
                       TAKEN FROM THE
                       KOKOMO. INDIANA 7.5'
                       SERIES TOPOGRAPHIC
                       QUADRANGLE
           APPROXIMATE
           BOUNDARIES
                       CONTINENTAL STEEL SUPERFUND SITE
                              KOKOMO, INDIANA
                          SITE LOCATION MAP
                                FIGURE 1
                               Page 41
Interim Remedy Record of Decision * Continenul Steel Superfund Site * July 25,1996

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                              WEST MARKLAND AVENUE
NO SCALE
  CONTINENTAL STEEL SUPERFUND SITE
         KOKOMO, INDIANA


       MAIN PLANT AREA
BUILDING IDENTIFICATION MAP


             FIGURE 2
                            Page 42
Interim Remedy Record of Decision * Continent*! Steel Superfimd She * July 22,19%

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                              TABLE 1
                 Continental Steel Superfund Site
                  Kokomo, Howard County/ Indiana

                 Summary of Environmental Actions
      Date
                     Action
  July 1975
Continental  Steel  reported a fuel oil spill from
a storage tank  at  the  treatment lagoon area.
The  fuel oil had entered a treatment plant
sewer,  a storm  sewer,  and Wildcat Creek.
Continental  Steel  was  issued a Notice of
Violation for exceeding  their NPDES permit
discharge limits.	
  1976
An NPDES compliance  inspection conducted by IDEM
revealed that the pH of  the  outfall from the
lagoon system  (Outfall 004)  was out of
compliance.  A subsequent  inspection revealed
that the lagoon system outfall contained
elevated levels of sulfates,  total solids and
dissolved solids
  November
  1980 to
  September
  1983
Between November  1980 and  September 1983,  9,000
tons of electric  arc furnace  dust stockpiled at
the Dixon Road Quarry were transferred to  a
landfill.  During that period,  an additional
1,000 tons of "as generated"  waste was placed in
the landfill.  According to Continental Steel,
no materials were disposed of in the guarry
after April 1983.  Direct  landfilling of the
baghouse dust was apparently  practiced after
that date.
  November
  1980
Continental Steel submitted a U.S.  EPA RCRA Part
A Hazardous Waste Permit for treatment,  storage
and disposal related to the handling  of pickling
liquor.  By submitting the document,  and by
virtue of being an existing hazardous waste
facility, Continental Steel achieved  "interim
status" as a hazardous waste treatment,  storage
and disposal facility.	
  June 1984
IDEM collected groundwater samples  from
monitoring wells located around the treatment
lagoon area.  Chromium, iron, sulfate and
manganese concentrations and pH values were
measured in the samples above the Safe Drinking
Water Act (SDWA) standards.  The IDEM concluded
that Continental Steel should conduct a
corrective action to delineate contamination and
assess the extent and rate of migration of
contaminants from the laaoons.	_____
                             Page 43
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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                              TABLE 1
                 Continental Steel Superfund Site
                  Kokomo, Howard County, Indiana

                 Summary of Environmental Actions
      Date
                     Action
  September
  1984
IDEM  inspected  the  treatment lagoon area as part
of the U.S.  EPA RCRA  Permit Approval Process.
Wells were  installed  by  Continental Steel to aid
in the investigation  of  elevated pH values in
groundwater at  the  site.	
  June 1985
IDEM collected groundwater  samples from
monitoring wells  located  at the treatment lagoon
area.  The results confirmed that chromium,
iron, sulfate, manganese  and pH values exceeded
SDWA standards.
  August 1985
IDEM performed a U.S. EPA Potential Hazardous
Waste Site Preliminary Assessment at the
Continental Steel site.  The  assessment focused
on the treatment lagoon area.
  November
  1985
Continental Steel lost its  interim RCRA permit
status after being cited  in October 1985 for
improper containment of baghouse wastes and PCB-
containing materials and  for the lack of fencing
around the lagoon area.   The facility continued
to deposit wastes in the  lagoon area.	
  February
  1986
U.S. EPA referred the Continental  Steel  case to
the Department of Justice for the  filing of a
civil case in the Federal District Court.
During May 1986, because Continental  Steel
continued to deposit wastes in the lagoon area
after having lost its interim RCRA status,  IDEM
issued a complaint, Notice of Opportunity for
Hearing and Proposed Final Order to Continental
Steel.  In September 1986, Continental Steel
provided IDEM with a Closure/Post-Closure Plan
for the facility which included neutralizing,
testing, and covering the surface  impoundments.
  March 1986
An IDEM Model Facility Management Plan was
prepared for the Continental Steel treatment
                laaoons.
                             Page 44
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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                              TABLE 1
                 Continental Steel Superfund  Site
                  Kokomo, Howard County, Indiana

                 Summary of Environmental Actions
      Date
                      Action
  April 1986
IDEM reinspected the  lagoons  and noted the
presence of untreated pickle  liquor,  lime-
stabilized waste pickle  liquor sludge,  and
treated effluent.  Waste piles near the
impoundments were  sampled and EP toxic levels of
cadmium and lead were detected.   Several samples
contained high concentrations of total cadmium,
chromium and lead.
  May 1986
IDEM performed a Compliance  Evaluation
Inspection of the treatment  lagoons.   The IDEM
documented that Continental  Steel was not
monitoring storm water discharges as  required by
their NPDES permit.	
  July 1986
U.S. EPA Technical Assistance Team  (TAT)
conducted a site investigation of the  Markland
Avenue Quarry.  More than  400 drums were
observed, most of which were empty.  Four drums
and two soil samples were  analyzed and found to
contain elevated concentrations of volatile
organic compounds, phenols, phthalates and PCBs.
Two samples, collected from the lagoons south of
Markland Road, contained low levels of PCB
(Aroclor 1248).

Versar, Inc. inspected the treatment lagoons for
the U.S. EPA Office of Waste Programs
Enforcement.  A gap was observed in the wall of
a lagoon containing spent  pickle liquor,  though
the gap terminated against accumulated sludge
and did not appear to compromise the integrity
of the lagoon system.  Empty drums and cinder
piles were also observed.  No major areas of
contaminated soils or seeping drums were
observed near the surface  impoundments.
  September
  1986
IDEM conducted a survey of residences that were
subject to potential groundwater contamination
from the Continental Steel lagoons.  None of the
homes surveyed used private wells, and the IDEM
concluded that homes were not impacted by the
notential aroundwater contamination at the site.
                             Page 45
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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                              TABLE 1
                 Continental Steel Superfund  Site
                  Kokomo, Howard County/  Indiana

                 Summary of Environmental Actions
      Date
                     Action
  January
  1987
IDEM conducted a site  inspection following U.S.
EPA regulations to  score the Lagoon Area
according to the Hazard  Ranking System.   The
lagoons were scored at 31.85 and as a result
were placed on the  NPL in March 1989.  Shortly
thereafter, the Main Plant and the Markland
Avenue Quarry were  aggregated to the Continental
Steel Superfund Site because they were owned and
operated by Continental  Steel Corporation and
had similar contaminants from the same
manufacturing processes  that threatened the same
resources.
  October
  1987
IDEM sampled Wildcat Creek  near  the  Continental
Steel treatment lagoons.  Sediment samples
contained elevated levels of total cadmium.
Tetrachloroethylene  (PCE) was detected  in two
creek water samples.	
  November
  1987
EDI Engineering and Science  sampled  the
Markland Avenue Quarry and the' treatment lagoon.
Water in the quarry had an elevated  pH level
(11.45 - 12.69) and contained  93 to  1,600 Mg/1
TCE.  The acid lagoon wastewater had a pH of 1.8
and contained heavy metals.  Low concentrations
of organics were observed in the lagoon
sediments.
  March 1988
Analyses of fish tissue samples collected  by
IDEM in 1988 from stations located along Wildcat
Creek near the City of Kokomo were completed.
The results indicated that fish downstream of
Kokomo contained PCS concentrations  in  excess  of
Federal Food and Drug Administration action
levels.  As a result, an immediate consumption
fish advisory was issued.	
  April 1988
A final settlement between Continental  Steel  and
its creditors was approved by the U.S.
Bankruptcy Court.  The settlement provided  for  a
$1.5 million clean-up fund to be set up and
distributed^ bv the IDEM.	
                             Page 46
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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                              TABLE 1
                 Continental steel Superfund site
                  Kokomo, Howard County, Indiana

                 Summary of Environmental Actions
      Date
                     Action
  May 1988
                        a  site assessment of the
Markland Avenue  Quarry.   The TAT observed
hundreds of  drums  grouped near the quarry,  a
tank, and  a  pile of  slag,  ash and ore factory
brick in the central and  eastern portion of the
site.
  October
  1988
IDEM conducted  fish,  sediment and water sampling
in Wildcat and  Kokomo Creeks.   PCBs were not
detected  in water  samples.   PCBs were detected
in sediment samples with  concentrations ranging
between 92 and  12,000 //g/kg.	
  February
  1989
IDEM conducted  follow up  sediment sampling of
Wildcat Creek and Kokomo  Creek for PCBs and
heavy metals.   Results  indicated that there were
at least three  possible sources for the PCBs,
including the Continental site.	
  August 1989
U.S. EPA TAT inspected the  Continental Steel
site for a possible removal action.   The TAT
observed the treatment lagoons,  and  drums stored
in the Markland Avenue Quarry.	^^
  October
  1989
Under the RCRA Program, source  control  was
implemented at the Lagoon Area  in  1989.   The
pickle liquor was treated and discharged to the
Kokomo Wastewater Treatment Plant  between the
fall of 1989 and the summer of  1990.
  1989
During 1989, IDEM completed a Preliminary
Assessment of the Dixon Road Quarry.  The
collected information indicated that  the quarry
had contaminants similar to those  at  the
Continental Site, the waste in the quarry
originated from the Continental Steel
Corporation manufacturing operations, and  the
quarry was owned and operated by Continental
Steel Corporation.  Moreover, contaminants in
the quarry appeared to threaten the same
resources as the Continental Site  (i.e., the
limestone aquifer and Wildcat Creek).  Based
upon these criteria, the quarry was proposed for
aggregation to the Continental Site in November
1990.	
                             Page 47
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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                              TABLE 1
                 Continental Steel Superfund Site
                  Kokomo, Howard County, Indiana

                 Summary of Environmental Actions
      Date
                      Action
  February
  1990
U.S. EPA  began  removal  actions at the Main Plant
and Markland Avenue  Quarry in February 1990.
During  1990, drums at the  quarry and Main Plant
were collected,  staged,  characterized and
disposed.   Capacitors and  transformers were
removed.  Some  tank  liquids were characterized
and disposed, and seven underground storage
tanks were  removed.  Various chemicals were also
removed from a  laboratory  facility at the Main
Plant.  PCB-contaminated surface soils were
removed from the former drum staging area at the
quarry.   Surface drums  were over packed,  sampled
and disposed of.  A  berm was also constructed.
  March 1990
U.S. EPA and IDEM conducted  an  assessment at the
Continental Steel main plant.   During this visit
and subsequent visits, approximately 700  55-
gallon drums were found  scattered throughout the
facility.  Also observed were 55  tanks, ranging
in capacity from 5,000 to  2  million gallons
each, and 33 vats of unknown materials.
Capacitors and transformers  were  also noted.	
  April 1990
During April 1990, U.S. EPA conducted an
underwater investigation of the Markland Avenue
Quarry using a remotely operated vehicle.
Approximately 1,000 drums and  five  storage tanks
were identified.  In the summer of  1991,  U.S.
EPA removed over 1,100 drums and several tanks
from the quarry bottom.
  May 1990
U.S. EPA staged and sampled drums at  the main
plant.  Tank content samples were also  collected
and the liquids disposed.  Capacitor  and
transformer oils were analyzed and disposed.
Drum disposal is on-going.    	
  June 1990
WW Engineering and Sciences, Inc. completed
discharge of the treated pickle liquor.	
  September
  1990
Soil sampling and analysis for metals, PCBs  and
VOCs at Fence Plant bv ERM-Midwestj
                             Page 48
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 23,1996

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                                  TABLE  1
                   Continental Steel Superfund Site
                     Kokomo,  Howard  county/  Indiana

                   Summary of Environmental Actions
Date
November
1990
November
1991
January
1992
May 1992
June 1992
July 1992
September
1992
Action
In 1989, IDEM completed a preliminary assessment
of the Dixon Road quarry. The collected
information indicated that the quarry has
similar contaminants to those at the Continental
Site, the waste in the quarry originated from
the Continental Steel manufacturing operations,
and the quarry was owned and operated by
Continental Steel. Moreover, it appears to
threaten the same resources as the Continental
Site (i.e., the limestone aquifer and Wildcat
Creek) . Based upon these criteria, the quarry
was proposed for aggregation to the Continental
Site in November, 1990. The aggregation,
however, was never finalized.
ADCO removed uranyl nitrate and uranyl acetate
bottles from a main plant laboratory for
disposal at U.S. Ecology.
IDEM completed a Management Plan in which
manageable areas (OU's) were identified and
prioritized. Preliminary scopes, schedules, and
budgets were prepared for each OU. Available
information related to the site was also
obtained and summarized.
U.S. EPA removal actions at the Main Plant and
Markland Avenue Quarry were completed.
IDEM discovered buried drums along the south
side of the Lagoon Area.
IDEM conducted further soil sampling and
analysis for Fence Plant area.
IDEM began remedial investigations of the
groundwater lagoon area, and Kokomo and Wildcat
Creeks .
                                 Page 49
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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                              TABLE 1
                 Continental Steel Superfund Site
                  Kokomo/ Howard County, Indiana

                 Summary of Environmental Actions
      Date
                      Action
  December
  1992
Between December  1992  and February 1993,  U.S.
EPA removed an estimated 1,350 buried drums from
the southwest side  of  the Lagoon Area (U.S. EPA,
1993).  The majority of the drums contained oil,
grease, slag, scale, dirt and garbage.   U.S. EPA
also  removed 1,000  cubic yards of TCE-
contaminated fill soils from an area of the
excavation where  several drums of TCE were
encountered.  An  additional 250 cubic yards of
oil-stained soils were removed from another area
of the excavation that contained oil drums.
  April 1993
Major field investigation  for  the RI  took place
between April and August of  1993.	
  August 1993
During August 1993, the U.S.  EPA initiated a
site assessment of the main plant area.   The
area was sampled extensively  for PCB's,  PAH's,
asbestos content, and lead.   Throughout  the
removal effort until November 1993,
approximately 90 cubic yards  of  lead-
contaminated dust were removed from  the  plant.
Hundreds of cubic yards of lead-contaminated
debris were separated, stockpiled, and covered
for future disposal.  Lead dust  and  debris were
removed or contained on-site  in  Buildings 112,
112B, 11 & 12, 8, 10, 122, 34, 69, 112A,  123,
123A, 24, 29A, and 71B.  Asbestos presence was
confirmed for Buildings 42, 54 and 1.  U.S.  EPA
also sampled sewers and drained  the  acid from
tank T-18.  Acid was stored in Building  123A.
  October
  1993
During October 1993, approximately  120  cubic
yards of PCB-contaminated soil were excavated
from the Markland Avenue electrical substation.
The soil was stockpiled next to the excavation
area and covered.  An additional cubic  yard of
PCB-contaminated soil was excavated from the
western portion of the main plant area  and added
to the stockpile.

Various drums that were collected from  around
the site throughout the removal effort  were
stored in Building 123A to await disposal
arrangements.  Drums of compatible  materials had
been combined and samoled.	
                             Page 50
Interim Remedy Record of Decision * Continenul Steel Superfund Site * July 25,1996

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                                  TABLE  1
                   Continental Steel Superfund Site
                    Kokomo,  Howard  County,  Indiana

                   Summary of Environmental Actions
Date
Fall 1994
November
1994
December
1994
March 1995
Action
U.S. EPA removed contents and cleaned above-
ground storage tanks numbered T-20, T-l, T-2,
and T-21. Tanks T-14 and T-15 were emptied, but
not cleaned. U.S. EPA removed 1 cubic yard of
PCB-contaminated soil from east of Building
112C.
IDEM accepted draft of a remedial investigation
report Sections 1-4 for the groundwater, lagoon
area, and Kokomo and Wildcat Creeks.
During December 1994, IDEM reported to the U.S.
EPA that one residential well had been affected
by the Continental Steel trichlorpethene (TCE)
groundwater contaminated plume. The U.S. EPA
test on December 10, 1994 confirmed
contamination with vinyl chloride levels as high
as 8.8 Mg/1-
EPA installed an air stripper on the residential
well.
                                 Page 51
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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TABLE 2
Continental  steel superfund  site
Kokomo, Howard County, Indiana

Summary of Sampling Results  from  Removal  Actions  at  the
Main  Plant Buildings  and  Screening Values for Each Contaminant
Contaminant
METALS
Arsenic
Chromium
Lead
Silver
Zinc
PCBs
PAHs
acenaphthene
acenaphthylene
anthracene
Benz (a) anthracene
Benzo (a) pyrene
Benzo(b&k) f louran
thene
Benzo (b) fluoranth
ene
Benzo(g,h, i)peryl
ene
Benzo (k) fluoranth
ene
chrysene
dibenzo ( a , h) anthr
acene
fluoranthene
f luorene
indeno(l,2,3-
cd) pyrene
naphthalene
phenanthrene
pyrene
Range of Results
(ing/kg)

62-695
223-8,493
14,000-880,000
85-3,071
95-279,500
8,700*
0.96-51
0.72-300
0.37-190
1-2,700
0.65-2,200
0.43-1,400
4.7-16
0.86-8,700
6.1-36
1.2-2,900
1.2-6,700
0.49-2,000
0.31-500
0.87-1,000
0.73-460
3.3-4,000
0.51-5,500
U.S. EPA Screening
Value
(mg/kg)

0.4
390
400
390
23,000
1
4,700
na
23,000
0.9
0.09
na
0.9
na
9
88
0.09
3,100
3,100
0.9
3,100
na
2,300
 *  - Maximum detected concentration
na  - not available
Results are the summary of surface soil samples collected from inside and outside of the buildings at the Main Plant (March 24,1994 - EPA).
Reference. EPA, 1994.
                                    Page  52
Interim Remedy Record of Decision * Continental Steel Superfund Site * July 25,1996

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Interim Remedy Record of Decision
      APPENDIX A
  Continental Steel Superfund Site
 Kokomo, Howard County, Indiana

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                    RESPONSIVENESS SUMMARY
               CONTINENTAL STEEL SUPERFUND SITE
               KOKOMO, HOWARD COUNTY, INDIANA
RESPONSIVENESS SUMMARY OVERVIEW

The Indiana Department of Environmental Management  (IDEM) and the
United States Environmental Protection Agency  (U.S. EPA) in
accordance with CERCLA Section 117, 42 U.S.C.  Section 9617 held a
public hearing on March 14, 1996, and a public comment period from
March lr 1996, through March 30, 1996, to allow interested parties
to comment on the Interim Remedy Proposed Plan for the Continental
Steel Superfund Site.

This action is an interim remedy (IR) that addresses the
contamination detected inside the deteriorated main plant
buildings and in the main plant building basements.  As this is an
IR, the remaining on-site contamination will be addressed in a
future final remedial action.

The selected IR is Alternative 2 - Immediate Decontamination and
Demolition of the Main Plant Buildings.  The major components of
the selected IR include:

•    Gross removal of lead dust from contaminated building
     interiors using vacuuming and/or pressure washing with
     disposal of dust as hazardous waste in a  permitted facility;

•    Management and proper disposal of rinsate collected from
     decontamination.  Rinsate water will be managed as hazardous
     waste until receipt of waste characterization analyses;

•    Asbestos abatement by removal and disposal at a permitted
     facility of exposed friable asbestos-containing materials and
     asbestos containing building insulation;

•    Confirmation sampling to ensure proper decontamination;

•    Removal of PCB-contaminated wood block floors and disposal as
     hazardous waste;

•    Demolition of all building superstructures, tanks, and
     equipment to grade, leaving floor slabs;

•    Salvaging of structural steel as scrap unless it can be
     decontaminated and reused as originally intended;

•    Disposal of all debris and demolition rubble in a solid waste
     landfill;


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•    Use of water  spray for dust control during demolition.  Dust
     control water runoff  will be contained and managed properly
     to prevent the transport of contaminants from the immediate
     demolition site;

•    Pumping out flooded basements,  removal of equipment and
     residue from  basements,  and filling of basements.  The pumped
     water will be managed as hazardous waste until receipt of
     waste characterization analyses;

•    Filling or covering of pits;

•    Confirmational sampling to verify effectiveness of
     decontamination;

•    Finishing of  unpaved  areas with crushed stone; and

•    Securing of the site  after the  interim remedy is completed.

The selected IR is protective of human health and the environment,
complies with Federal  and  State requirements that are legally
applicable or relevant and appropriate to the IR,  is cost
effective, and utilizes permanent solutions.

This IR will leave hazardous substances above health-based levels
remaining on-site  in the groundwater and the surface and sub-
surface soils. A final remedy will address the remaining site
contamination to provide adequate protection of human health and
the environment.

Other alternatives that were presented and considered were
Alternative 1 - No Action,  Alternative 3 - Immediate
Decontamination of the Main Plant Buildings and Alternative 4 -
Securing of the Main Plant Buildings.   Alternative 4 is a limited
action with no decontamination.   Both  Alternative 3 and
Alternative 4 require  24-hour site security until a final remedial
action can be implemented.   No new alternatives were presented by
the public either  at the public meeting or in the written
comments.
BACKGROUND OF COMMUNITY INVOLVEMENT

Community concern about the site began prior  to  the company's
bankruptcy in February 1986.  Neighbors near  the site complained
of airborne dust believed to be iron oxide produced during the
periods of operation.  This dust damaged automobile finishes and
aluminum siding on houses.

Thousands of jobs were lost, and pensions and other benefits were


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denied as a result of plant's  closing and bankruptcy.  This
remains a concern for former workers,  and has provided the basis
for legal actions over  the  years.   The money distributed by the
bankruptcy court went primarily  to  pay for employee benefits and
for environmental cleanup,  though the amount of money remaining
did not adequately fund either area.

Many former employees still live in the area and are very familiar
with the waste handling and disposal practices at the plant.  The
former employees have offered  information that has been helpful in
understanding where contamination could be found and, in some
cases, why contamination was found  in certain locations.  This
dialogue is an ongoing  process.  These former workers have
maintained a strong interest in  the cleanup of the site.

The Main Plant area, including the  buildings,  was sold during
January 1991 to Mr. Matthew L. Gentry of Kokomo,  Indiana,  for ten
dollars.  The sale was  conducted by the Continental Steel
bankruptcy trustee and  approved  by  the bankruptcy court.  The
private ownership of the Main  Plant area has been a complicating
factor for cleaning up  the  site.  The Superfund process requires
that the owner clean up the contamination.   If the owner does not
do the clean up, then the IDEM or the U.S.  EPA must do it and try
to recover the costs.

The inclusion of the site on the National Priorities List and the
subsequent U.S. EPA removal actions have received continuous media
and community attention.  It was noted that the U.S. EPA's removal
actions were communicated well to the public,  but some citizens
and community leaders stated that they would have liked additional
information on a more regular  basis.

Since April 1990, the IDEM  has distributed seven fact sheets and
held  seven public meetings.   The purposes of the fact sheets and
meetings were to describe the  Superfund process,  the site,  the
removal activities and  the  remedial investigation activities to
local residents, local  officials, the media,  and other interested
parties.  Community Relations  interviews were conducted during May
1992. Fourteen people,  representing a cross sample of interested
parties, were interviewed.  A  Community Relations Plan which
included these interviews was  released in March 1993.   The IDEM
participated in Indiana State  Representative Jon R.  Padfield's
Town Meeting on June 10, 1995, and  Congressman Steve Buyer's
public meeting on August 10, 1995,  that included Congressman Mike
Oxley.

Kokomo Against Pollution, a community  group,  was  formed to follow
the investigation and cleanup  of the  site.   This  group has
followed the activities at  the site very closely,  and the IDEM has
attended many of their  monthly meetings.
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Other groups that have identified the site as a concern are the
Kokomo/Howard County Chamber of Commerce, Leadership Kokomo,
Beautification Issues Group, Kokomo/Hovard County Business/Labor
Alliance, and the Community Action Group.  The Community Action
Group consists of eighteen leaders of different community groups
representing a cross-section of the community.

The requirements of CERCLA regarding public participation in the
interim remedy selection process were met by issuing the proposed
plan fact sheet to the public February 28, 1996.  The public
comment period commenced March 1, 1996 and ended March  30,  1996.
A public meeting was held March 14, 1996 in the Ralph W. Neal
Council Chambers at the Kokomo City Hall to accept written  and
oral public comments on the proposed plan.  A court reporter was
in attendance to provide a transcript of the public meeting.
Seventy-eight people were in attendance.


SUMMARY OF COMMENTS AND AGENCY RESPONSES

Listed below are summaries of the public comments received  from
oral comments at the public meeting and written comments received
during the comment period for the Interim Remedy Proposed Plan.

Five oral comments were given at the public meeting.  Four
comments (including comments from the Mayor and from a  City
Councilman) supported tearing down the buildings or Alternative 2,
the selected remedy.  One comment suggested that Howard County
would benefit more from keeping some of the heavy-structured
buildings and tearing the rest down.  This comment seems to be
associated more with Alternative 3, immediate decontamination of
the buildings, than with Alternative 2, because determination of
which buildings should stay would have to be made during a  final
remedy for the site.

The total number of written comments postmarked within  the  30-day
comment period was 1,167.  An additional 46 written comments were
postmarked after March 30, 1996, which was the end of the comment
period.  A review of these 46 written comments revealed that the
comments were similar to the other comments received, and no new
information was presented.  Therefore, these 46 written comments
will not be addressed in this responsiveness summary.

A breakdown of the written comments is as follows; 1,097 agree
with Alternative 2 (including written comments from Congressman
Buyer, the Kokomo Common Council, and Mr. Gentry and his agent
Fortune Management); three agree with Alternative 1; 13 agree with
Alternative 3; none agree with Alternative 4; three comment forms
were signed, but were blank; and 51 forms offered comments, but
did not identify a preferred alternative.  The percentage of all
responses in favor of the selected IR equals 94.0%.  The next


                              Page 4
             Interim Remety Record of Deciiion*C^                  1996

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greatest number of responses,  4.4%,  did not state a preferred
alternative.  Alternative  3  received 1.1% of the responses and
Alternative 1 received  0.3%  of the  responses.

Three of the oral comments and 508  of the written comments that
supported the recommended  alternative included additional comments
or concerns.  The agreement  to the  remedy was  in the form of
several phrases which included "agree with Alternative 2",
"decontaminate and demolish," "tear down the  buildings," and "clean
it up."  Comments included with the agreement to the remedy
expressed several categories of concern.   The  categories were
cost/funding of clean up,  danger/sampling of site,  timing,
ownership, property values and visual appearance,  and use.

A response to each of the  comment categories follows:

Cost/Funding

The comments concerning cost/funding included  "owners should pay,"
"no cost to taxpayers,"  "sell bricks as  fund  raiser," "use local
resources," "use surplus tax  money," "use welfare recipients as
labor," "use correctional  inmates as labor,"  and "any profit should
go to the former Continental Steel  employees."

Agency Response:  The Superfund process requires  the
owner/operator to pay for  any  clean  up.   Any owner or operator of
the site is called a potentially responsible party or PRP.  If the
PRP does not or cannot  do  the  clean  up,  then the  U.S.  EPA or the
IDEM will clean up the  site  using monies from  the Federal
Superfund trust fund or the  State Hazardous  Substance Response
Trust Fund.  The U.S. EPA  or the IDEM will then try to recover the
costs.  Cost recovery necessitates complete, detailed
documentation of the clean up  decision-making  process.   When
Superfund monies are used, the cost  recovery process generally
occurs after the final  clean up action  is complete or well
underway.  At that time, actual costs of the clean up action and
ongoing operation and maintenance,  if any, will be known.  The
total cost of the clean up and the documentation  of the  decision
process form the basis  of  recovering  costs from the owner.  The
IDEM is continually assessing  the probability  of  cost recovery and
documenting the decision process in order to recover costs at the
appropriate time.

Local resources, and reuse or  resale  of material  salvaged during
the cleanup will be utilized to the  extent this is  possible  given
the nature and extent of contamination  at the  site,  the  cleanup
requirements,  and the applicable government  contracting
regulations and requirements.

Danger/sampling of the  site
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             * Interim Remedy Record of Decision * Continental Steel Superfund Site * May 16,1996

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The comments concerning danger/sampling of the site included
"dangerous to children," "it's a hazard," "it's a rat trap,"
"dangerous site,"  "sample soil,"  "clean up soil and water," "test
water within five-mile radius," "don't believe it's contaminated,"
and "does not believe any information, but wants  it  cleaned  up."

Agency Response:  The U.S. EPA sampling of the main plant area has
shown that on-site contamination  exists.   The IDEM agrees that the
Main Plant buildings pose a danger,  are hazardous, and certainly
could harbor rodents.  The IDEM recommended this interim remedy to
the U.S. EPA because of the hazards  present at the site.  Further
testing of the soil and water in  the area was completed during the
Fall of 1996,  and will be evaluated in the forthcoming draft
Remedial Investigation Report.  The  next step is to complete a
draft of the Feasibility Study.   The Feasibility Study will
suggest further sampling, if needed,  and alternatives for a final
remedial action for the whole site.

Timing

The comments concerning timing of the clean up of a site included
"should have been done sooner," and "time  line serves no one  other
than bureaucrats."

Agency Response:  Many removal actions have already been conducted
to eliminate the  most immediate threats to the public health and
the environment.  This recommended alternative is an interim
action that will  speed up the final  remediation of the site.  A
final remedy that is protective of the public health and the
environment must  be made with a full understanding of the entire
site.  Therefore, the final remedy needs extensive sampling and
careful thought which takes time  to  complete.  The IDEM and the
U.S. EPA are moving as quickly as possible to come to a
recommended final remedy for this site.

Ownership

The comments concerning ownership of the site included
"city/county should own it" "do not want the  city/county involved,"
and concern about the private ownership of the buildings.

Agency Response:  The owner/operator or PRP of a  superfund  site
has the liability to clean up the site.   However,  the Superfund
process does allow that, if a municipality involuntarily acquires
a site, the municipality is not liable for past contamination or
its clean up.  The IDEM makes no  recommendation or statement on
ownership of the  site other than  to  identify PRPs that may  be able
to pay for the cost of the clean  up.   The private ownership  of the
buildings does complicate the process.   If the owner will not
decontaminate and remove the buildings properly,  then the IDEM and
the U.S. EPA must do so and try to recover the costs.   To date the


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owner of the Main  Plant Site has cooperated in providing access to
the Agencies for their  cleanup and investigatory work.  The owner
has asserted that  he  does not have the resources to do the cleanup
himself.


Property values and visual appearance

The comments concerning property values and visual appearance
around the site included "property values suffer" and "it's an
eyesore."

Agency Response:   The property values around the site may be
depressed and the  old,  deteriorating buildings do not look good.
However, these are not  criteria of the Superfund process when
considering the threat  of on-site contamination and alternatives
to reduce that threat.   A possible side benefit of any clean up
would be to enhance the value and appearance of the site to the
surrounding community.   It is the policy of the IDEM and the U.S.
EPA to encourage return of Superfund Sites  to productive use to
the extent it is safe and feasible after cleanup activity is
completed.

Use

The comments concerning use of the site included "leave  vacant,"
"plant trees," "redevelop  site," "wildlife habitat," "parking lot,"
"recreational park," "industrial  park," "build homes," build "low
income apartments," "turn into certified waste facility," "shopping
mall," "prison," "museum/memorial," "horse track," "senior  citizens'
lodge," "golf course," "hotel/convention center," and "ball park."

Agency Response:   The future use of  the Main Plant area  is a
concern when determining the final clean up goals for the whole
site.  The property deed for the Main Plant area has a covenant
that requires the  use of the property to be "industrial  use only."
This recommended interim remedy does not set a final action clean
up level, and it did  not intend to do so.   The future use of the
whole site is a local issue,  and the final  clean up levels will be
determined, in part,  by the reasonably anticipated future use of
the property, taking  into consideration local zoning and deed
covenants on the property.   Community input and public comment
will be sought on  the decision establishing final cleanup levels.

The number of written responses that did not state a preferred
alternative was 51.   Several phrases included in this group were
"take whatever action is necessary," "example of bad  things done to
our environment," "trash it"  and  "please do something now."
Comments expressed similar categories of concern that were
discussed previously.   The categories were  cost/funding  of clean
up, danger, timing, ownership,  visual appearance,  and use.


                               Page 7
 ReqMosiveneH Summary * Interim Remedy Recced of Decision * Continental Steei Superiund Site * May 16,1996

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A response to  each of  the comment categories follows:

Cost/Funding

The comments concerning  cost/funding included "owners should pay,"
"no cost to taxpayers," "use volunteers," "use private industry,"
"want federal help," "let  community take  loose scrap," and "profit
put back  into  pension  plan."

Agency Response:   The  Superfund process  requires the
owner/operator or  PRP  to  pay  for any clean up. If the PRP does not
or cannot do the clean up, then the U.S.  EPA or the IDEM will
clean up  the site  using monies  from the  Federal Superfund trust
fund or the State  Hazardous Substance Response Trust Fund.   The
U.S. EPA  or the IDEM will then  try to recover the costs.  Cost
recovery  necessitates  complete,  detailed documentation of the
clean up  decision-making  process.   When  Superfund monies are used,
the cost  recovery  process occurs after the final clean up action
is complete.   At that  time, actual costs of the clean up action
and ongoing operation  and maintenance, if any, will be known.  The
total cost of  the  clean up and  the documentation of the decision
process form the basis of recovering costs from the owner.   The
IDEM is continually assessing the probability of cost recovery and
documenting the decision  process in order to recover costs  at the
appropriate time.

Danger

The comments concerning danger  of the site included "bad for
kids," "hazard," "unsafe,"  "dangerous," "don't believe it's
contaminated," and "overreacting to hazards."

Agency Response: The U.S.  EPA sampling of the Main Plant area has
shown that on-site contamination exists.   The IDEM agrees that the
Main Plant buildings pose a danger,  and  are hazardous.   This
agreement is the reason the IDEM recommended the interim remedy of
decontamination and destruction of the buildings.

Timing

The comments concerning timing  of the clean up of the site
included  "should have been done sooner."

Agency Response:   Many removal  actions have already been conducted
by the U.S. EPA to eliminate threats to  the public health and the
environment.   This recommended  alternative is an interim remedy
that will speed up the final remediation  of the site and be
consistent with the final remedy.   A final remedy that is
protective of  the  public  health and the  environment must be made
with a full understanding of the entire  site.   Therefore, the
final remedy needs extensive sampling and careful thought which


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        Suaaury • Interim Remedy Record of Decision * CooJinenttl Sted Superfund Site • Mty 16,1996

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takes time to complete.   The IDEM is moving as quickly as possible
to come to a final  remedy for this site.
Ownership

The comments concerning ownership of the site included "bring in
the government  superfund," "IDEM/EPA should take control" and "urge
government agencies to  step  out of loop."

Agency Response:  The owner/operator or PRP of a superfund site
has the liability to clean up the site.  However,  the Superfund
process does allow that,  if  a municipality involuntarily acquires
a site, the municipality is  not liable for past contamination or
its clean up.   The IDEM makes no recommendation or statement on
ownership of the site other  than to identify PRPs that may by able
to pay for the  cost of  the clean up.   It is not the role of the
IDEM or the U.S. EPA to dictate who can own private property.  The
IDEM is not a property  holding entity and cannot take title to a
Superfund site.

Visual appearance

The comments concerning visual appearance around the site included
"unsightly" and  "eyesore."

Agency Response:  The old, deteriorating buildings do not look
good; however,  this is  not a criterion of the Superfund process
when considering the threat  of on-site contamination and
alternatives to reduce  that  threat.   A side benefit of any clean
up would be to  enhance  site  appearance to the surrounding
community.

Use

The comments concerning use  of the site included "unproductive,"
"redevelop," "park,"  "factory," "homes,"  "recycling business,"
"shopping area," "memorial," "general store/grocery,"  "golf course,"
and "factory."

Agency Response:  The future use of the Main Plant area is a
concern when determining the final clean up goals  for the whole
site.  The property deed for the Main Plant area has a covenant
that requires the use of the property to be "industrial use  only."
This recommended interim remedy does  not set a final action clean
up level, and it did not intend to do so.   The future use of the
whole site is a local issue,  and the  final clean up levels will be
determined, in  part, by the  local zoning and deed  covenants on the
property.
                               Page  9
 Reqxnciveaea Summary * Interim Remedy Record of Decision * Continental Steel Superfund Site * May 16,19%

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Thirteen comments  expressed that the buildings could be
decontaminated and some  could be reused.   The comments fit into
two categories, cost/funding and use.   The cost/funding comments
included "use tax dollars" and "use prisoners  to clean up site."
Suggested uses of  the  site included  "paint ball facility/
"redevelop a steel plant," "recycling center," "park,"
"manufacturing," "storage," "ski slope," "school bus facility," and
"use buildings to block smell  from the waste water treatment
plant."

Agency response:   These  comments are analogous to Alternative 3.
Alternative 3 is intended to protect the  surrounding community
from the threat of wind  blown transport of contaminants by
removing the source of contamination.   The possibility of
retaining some of  the  most potentially  useful large buildings was
considered, but was rejected.   Structural deficiencies including
severely corroded  structural steel were observed in buildings 11
and 70, and the wooden roofs on buildings 8,  9, 10,  11, 12,  20,
112B, 114 and 122  were rotten and disintegrating.   All buildings
with corrugated siding,  such as buildings 5,  24, 40,  42, 68, 69,
70, and 110, were  missing or had damaged  siding panels.  Buildings
112, 112A, 112B, and 112C are insulated with  an asbestos
containing material that would need  either to be encapsulated or
to be removed.  Significant structural  modifications could be
required to allow .for  decontamination,  and could drive the cost of
this alternative higher.

Over the long-term,  this  alternative would not be completely
effective in preventing  human contact with the contaminants.  The
lack of complete long-term effectiveness  is due to the fact that
decontamination of the buildings, however thorough,  would only
remove contamination from accessible areas.   Some contaminants in
the form of dust would remain in cracks,  small spaces,  between
wall panels, and other inaccessible  areas.  Trapped dust will
eventually be released,  either during demolition of the buildings
or during future use of  the buildings.  It is  likely that
contaminants existing  in  the soils outside of  the buildings would
migrate back into  and  onto the buildings.  This recontamination
could occur by human activity such as trespassers and/or site
workers or via transportation as wind-blown dust.   The likelihood
of wind-blown recontamination of the buildings is especially high
in the buildings that  have large openings to  the outside.   This
alternative does not address the risk of  the  physical hazards
within the buildings due  to the deterioration  of the structures or
due to the physical features,  such as machinery pits and flooded
basements.  Accounting for the fact  that  decontamination efforts
would need to be more  thorough under this alternative than under
the demolition alternative,  it is estimated that this alternative
would cost at least one million dollars more  than the selected
interim remedy.  The comments  about  cost/funding and use have
already been addressed previously in this responsiveness summary*


                              Page 10
 Rttpamvmat Summaiy * Interim Remedy Record of Decision * Continental Steel Superfiind Site * May 16,1996

-------
Three comments suggested that  nothing should be done.  These
comments agree with the no  action alternative.   The comments
included "let it rot to the ground" and "oppose  doing anything to
the Continental site."

Agency Response: The no-action alternative is a feasible
alternative only when contaminant concentrations are already
within levels that correspond  to  an acceptable risk.  Presently,
this is not the case at the Main  Plant buildings,  where lead
contaminant levels currently present risks to human health from
ingestion and other chemical constituents and asbestos are
present.  The no-action alternative depends solely on natural
processes to significantly  reduce contaminant levels to where no
significant risk is present.   The no-action alternative does not
provide any significant protection to human health and the
environment.   The no-action alternative  will allow contaminated
dust and friable asbestos to continue migrating off-site via wind
blown dust.  This alternative  does not reduce the risk of physical
hazards within the buildings.   In addition,  the contamination that
is present beneath the buildings  in the basements may not be as
efficiently or effectively  remediated if  the buildings are left in
place.

While it is true that these conditions have been present for some
time, the Agencies have limited cleanup resources and previously
have focused those resources on threats that were even more
imminent than those posed by contamination present in and around
these buildings.  The IDEM  believes it is important to address
these buildings now.
                              Page 11
            * Interim Remedy Record of Decision * Continental Steel Superfund She * May 16,1996

-------
                     This  page  intentionally  left  blank
                                       Page  12
Re*poarivene« Summary • Interim Remedy Record of Decision * Continental Steel Superfund Site * May 16,1996

-------
Interim Remedy Record of Decision
      APPENDIX B
  Continental Steel Superfund Site
 Kokomo, Howard County, Indiana

-------

-------
            ADMEMISTRATIVE RECORD INDEX FOR THE
              CONTINENTAL STEEL SUPERFUND SITE
              KOKOMO, HOWARD COUNTY, INDIANA
The Comprehensive Environmental Response,  Compensation, and
Liability Act of 1980  (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), requires the
establishment of an Administrative Record  (AR)  upon which the
President shall base the selection of a response action (SARA;
Sec. 113(k)(l)).  IDEM has compiled the following official
Administrative Record Index for the Continental Steel Superfund
site, Kokomo,  Howard County, Indiana.  This index with associated
actual file will be updated by IDEM periodically.

-------

-------
.>i/iii.t«xui.iuil4. vt. Ki^OlUJ INUkA M
CONTINENTAL STEEL SUPERFUND SITE M.
KOKOMO. INDIANA *
PC'S
294









DATE
1-1992









TITLE
Final Management Plnn for Contin-
ental Steel Site Remedial Investi-
gation/Feasibility Study, Kokomo.IN









AUTHOR
AIJIJ Environmental
Services, Inc.









RECIPIENT
Cabrieli* llauur,
IDEM









DOCUMENT TYPE
IM.ANS/iJTUDJliS/
REPORTS









DOCUMENT NO.
I









1 of  1

-------
NOVEMBER 1994
                                ADMINISTRATIVE RECORD INDEX
                        (CONTINENTAL STEEL) Superfund Cleanup Site
                                  KOKOMO,  HOWARD COUNTY,  INDIANA
UPDATE #1
Pgs
17
3
3
12
17
13
57
DATE
1-23-94
4-14-94
8-26-94
8-15-94
10-26-93
10-26-93
May 1993
TITLE
Continental Steel Site
Unilateral
Administrative Order
Amendment of the (ROD)
Dates for Continental
Steel
Letter of comments for
Site Review and Update
For Continental Steel
Site Review and Update
for Continental Steel
Proposed Bioslurry
Tests at T&E,
Continental Steel Site
Field Studies for
Biological
Characterization
Technical Memorandum
#3 RI/FS for
Continenal Steel Site
AUTHOR
USEPA
Region 5
Pat
Carrasquero
IDEM
Bernard
Schorle
USEPA
USPHS
Edward
Opatken
USEPA
Norman
Richardson
ABB. Inc
ABB
Environmental
Services
RECIPIENT
Matthew
Gentry
Romona
Smith
USEPA
Louise
Fabinski
USPHS
Bernard
Schorle
USEPA
Subhas
Sikdar
USEPA
USEPA
IDEM
DOCUMENT TYPE
Orders
Decrees
Correspondence
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
DOC
NO
1
2
3
4
5
6
7
                                        Page 1 of 3

-------
NOVEMBER 1994
                                ADMINISTRATIVE RECORD INDEX
                         (CONTINENTAL STEEL) Superfund Cleanup Site
                              KOKOMO, HOWARD COUNTY, INDIANA
UPDATE #1
Pages
717
38
218
2
6
8
14
DATE
May 1993
May
1993
May
1993
7-12-94
10-5-93
8-26-93
4-30-93
TITLE
Sampling and Analysis
Plan Revision #3 for
Continental Steel
Work Plan Revision #4
for Continental Steel
RI/FS
Health and Safety Plan
for Continental Steel
Letter about the
cleanup by EPA at
Continental Steel
Letter with questions
about Continental
Steel
Conference Report for
Continental Steel
Public Meeting plus
Quest ions /Answers for
Continental Steel
AUTHOR
ABB
Environmental
Services
ABB
Environmental
Services
ABB
Environmental
Services
Clayton
Duncan Sr.
William
Muno
USEPA
ABB
Environmenta 1
Services
IDEM
RECIPIENT
IDEM
IDEM
IDEM
IDEM
Gayl
Catt
IDEM
General
Public
DOCUMENT
TYPE
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
Community
Relations
Community
Relations
Community
Relations
Community
Relations
DOC
NO
8
9
10
11
12
13
14
                                        Page 2 of 3

-------
NOVEMBER 1994
                                ADMINISTRATIVE RECORD INDEX
                        (CONTINENTAL STEEL) Superfund Cleanup Site
                              KOKOMO, HOWARD COUNTY, INDIANA
UPDATE #1
Pages
22






DATE
March
1993






TITLE
Community relations
Plan for Continental
Steel






AUTHOR
ABB
Envir onmenta 1
Services






RECIPIENT
IDEM






DOCUMENT TYPE
Community
Relations






DOC NO
15






                                       Page 3 of 3

-------
PAGE
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY, INDIANA
FEBRUARY 1996 UPDATE #2
PC'S
25
2
1
1
4
1
1
1
J)ATE
3-1-95
6-19-95
9-5-95
10-13-95
10-19-95
12-7-95
12-8-95 '
12-20-95
TITLE
Initial Scoping Meeting focused RI/FS
Amendment Of The ROD Dates For Continental Steel
Request For RA/FS - Building Demolition Costs
Approval Of Technical Memorandum - Background Contaminate Levels
Conditional Approval Of QAPP For Focused Remedial
Investigation/Feasibility Study
Approval Of Site Work Plan
Approval Of Focused RI/FS Work Plan, Figures, And Appendices A And B
Approval Letter For Documents For The Continental Steel Superfund
Site
AUTHOR
John J. O'Grady, USEPA
Pat Carrasquero, IDEM
Arthur C. Garceau, IDEM
Arthur C. Garceau, IDEM
John J. O'Grady, USEPA
Romona R. Smith, USEPA
Arthur C. Garceau, IDEM
Romona R. Smith, USEPA
RECIPIENT
Arthur C. Garceau,
IDEM
Romona Smith,
USEPA
Mark A. Burgess,
Camp, Dresser &
McKee, Inc.
Mark A. Burgess,
Camp, Dresser &
McKee, Inc.
Arthur C. Garceau,
IDEM
Pat Carrasquero,
IDEM
Mark A. Burgess,
Camp, Dresser &
McKee, Inc.
Pat Carrasquero,
IDEM
DOCUMENT TYPE
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
DOC NO.
1
2
3
4
5
6
7
8

-------
PAGE 2
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY, INDIANA
FEBRUARY 1996 UPDATE #2
PC'S
1
2
2
1
1
7
7
6
DATE
1-9-96
1-29-96
1-30-96
1-30-96
2-6-96
8-2-95
8-31-95
9-22-95
TITLE
Approval Letter, Documents For The Continental Steel Superfund Site
Formal Request And Support To Demolish Buildings At Continental Steel
Superfund Site
Formal Request And Support To Demolish Buildings At Continental Steel
Superfund Site
Approval Letter Of The QAPP For The Continental Steel Superfund Site
Approval Of Phase II Quality Assurance Project Plan
Continental Steel/Superfund Site Visit/Meeting (8/10/95)
Continental Steel Redevelopment Meeting (Chicago 8/31/95)
IDEM Continental Steel Superfund Site RI/FS Background Contaminant
Levels
AUTHOR
Arthur C. Garceau, IDEM
James E. Trobaugh,
Mayor of Kokomo
Dave Griffey, Howard
County Commissioner
Romona R. Smith, USEPA
Arthur C. Garceau, IDEM
Heather Johnson,
Congressman Steve
Buyer1 Office
John O'Grady, USEPA
Mark A. Burgess, P.E.
RECIPIENT
Mark A. Burgess,
Camp, Dresser &
Mckee, Inc.
Kathy Prosser,
Commissioner
IDEM
Kathy Prosser,
Commissioner,
IDEM
Pat Carrasquero,
IDEM
Mark a. Burgess,
Camp, Dresser &
McKee, Inc.
Art Garceau, IDEM
Art Garceau, IDEM
Art Garceau, IDEM,
John O'Grady,
USEPA
DOCUMENT TYPE
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Memoranda
Memoranda
Memoranda
DOC NO.
9
10
11
12
13
14
15
16

-------
PAGE 3
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY, INDIANA
FEBRUARY 1996 UPDATE JZ
PC'S
14
67
11
12
403
264
78
220
DATE
1-30-96
3-7-95
8-28-95
2-1-96
11-95
10-20-95
10-20-95
10-20-95
TITLE
Continental Steel Treatabilily Studies
Remedy Selection Level Bench-Scale Bioslurry Study On Contaminated
Soil From The Continental Steel Superfund Site
Continental Steel Superfund Site Technical Memorandum-Building
Demolition Costs
Gravity Dewatering Testing Results
Phase II Quality Assurance Project Plan
Focused RI/FS Work Plan
Focused RI/FS Work Plan Figures
Focused RI/FS Work Plan Data Summary Tables and Preliminary
Feasibility Study
AUTHOR
Edward R. Bates, USEPA
Douglas W. Grosse, TSAP
Coordinator, USEPA
Mark A. Burgess, P.E.,
Camp, Dresser & McKee,
Inc.
Mark A. Burgess, P.E..
Camp, Dresser & McKee,
Inc.
Camp, Dresser & McKee,
Inc.
Camp, Dresser & McKee,
Inc.
Camp, Dresser & McKee,
Inc.
Camp, Dresser & Mckee,
Inc.
RECIPIENT
Art Garceau, IDEM
Bernard Schorle,
USEPA
Arthur C. Garceau,
IDEM
Mr. Ed Bates,
USEPA
IDEM
IDEM
IDEM
IDEM
DOCUMENT TYPE
Memoranda
Plans/ Studies
/ Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
DOC NO.
17
18
19
20
21
22
23
24

-------
PAGE 4
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY, INDIANA
FEBRUARY 1996 UPDATE #2
PC'S
225
214
23
78
2
1
1
1
1
DATE
10-20-95
10-6-95
10-95
2-96
5-14-95
5-17-95
6-13-95
6-21-95
9-15-95
TITLE
Phase II Field Sampling Plan
Focused RI/FS Health And Safety Plan
Community Relations Plan
Interim Risk Assessment/ Feasibility Study - Main Plant Buildings
News Article
News Release - IDEM Undertakes Investigation And Study At Continental
Steel Superfund Site
News Article
Appreciation Letter - Town Meeting (6/20/95)
News Release - IDEM Warns Public Not To Trespass On Continental Steel
Superfund Site In Kokomo
AUTHOR
Camp, Dresser & Mckee,
Inc.
Camp, Dresser & Mckee,
Inc.
Camp, Dresser & McKee,
Inc.
Camp, Dresser & Mckee,
Inc.
H.W. Peabody, and Boyd
Jenkins
IDEM
Jeff Parrott, Kokomo
Tribune - Staff Writer
Jon R. Padfield, State
Representative
IDEM
RECIPIENT
IDEM
IDEM
IDEM
IDEM
Kokomo Tribune
News Media
Kokomo Tribune
Art Garceau, IDEM
News Media
DOCUMENT TYPE
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Community
Relations
DOC NO.
25
26
27
28
29
30
31
32
33

-------
PAGE 5
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY, INDIANA
FEBRUARY 1996 UPDATE §2
PC'S
1

1

6

2

1


4

12

4



DATE
10-10-95

10-12-95

11-15-95

11-17-95

1-9-96


1-11-96

2-28-96

10-30-95



TITLE
News Release - IDEM Begins Site Investigation At Continental Steel
Superfund Site In Kokomo
News Release - IDEM Announces Community Action Group Meeting For
The Continental Steel Superfund Site In Kokomo
Fact Sheet - Public Availability Sessions

Community Action Group - Meeting (10/25/95)

News Release - IDEM And Community Action Group Announce
Neighborhood Meeting For The Continental Steel Superfund Site In
Kokomo
Residents Surrounding Continental Steel Mill Site Meeting (1/11/96)

Fact Sheet - Interim Remedy Proposed Plan - Building Demolition

ARAR's



AUTHOR
IDEM

IDEM

IDEM

Shannon Christiansen, IVY
Tech State College
IDEM


Shanon Christiansen, IVY
Tech State College
IDEM

Arthur Carter, IDEM
George Oliver, IDEM
Tena Hopkins, IDEM

RECIPIENT
News Media

News Media

Public & News
Media
Art Garceau, IDEM

News Media


Public

Public & News
Media
Art Garceau, IDEM



DOCUMENT TYPE
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Community
Relations

Community
Relations
Community
Relations
ARAR's



DOC NO.
34

35

36

37

38


39

40

41




-------
                           APPENDIX B-2
            ADMINISTRATIVE RECORD SAMPLING/DATA INDEX

Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE 1
DATE
5-4-94
4-6-94
3-17-94
3-11-94
3-4-94
2-10-94
2-2-94
1-27-94
TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
QUALITY
ASSURANCE REPORT
PACKAGE f 15 8 1.1
QUALITY
ASSURANCE REPORT
PACKAGE #1548
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
HERITAGE
LABORATORIES
HERITAGE
LABORATORIES
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELE
HAUER
MANUELA
JOHNSON
MANUELA
JOHNSON
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE
SAMPLING
DATA
REPORT
REPORT
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA

-------
                           APPENDIX B-2
            ADMINISTRATIVE RECORD SAMPLING/DATA INDEX

Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE 2
DATE
1-13-94



12-27-93



12-20-93



12-13-93



12-3-93



12-9-93



12-3-93



TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


RECIPIENT
GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


DOC/TYPE
SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA



-------
                           APPENDIX B-2
            ADMINISTRATIVE RECORD SAMPLING/DATA INDEX

Documents not copied,  may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE 3
DATE
11-29-93



11-15-93



11-9-93



11-5-93



10-27-93



10-20-93



10-14-93



TITLE
CONTINENTAL .
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


RECIPIENT
GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


DOC/TYPE
SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA



-------
                           APPENDIX B-2
            ADMINISTRATIVE RECORD SAMPLING/DATA INDEX

Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE 4
DATE
10-12-93



10-8-93



9-29-93



9-22-93



9-15-93



9-13-93



9-10-93



TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
.LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


RECIPIENT
GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


DOC/TYPE
SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA



-------
                          APPENDIX B-2
            ADMINISTRATIVE RECORD SAMPLING/DATA INDEX

Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Off ice--Indianapolis, Indiana
                                                          PAGE 5
DATE
9-10-93
9-3-93
8-28-93
8-24-93
8-17-93
8-13-93
8-13-93
8-11-93
TITLE
CONTINENTAL
STEEL CORP FAS
LAB RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELS
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA

-------
                           APPENDIX B-2
            ADMINISTRATIVE RECORD SAMPLING/DATA INDEX

Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE 6
DATE
8-11-93



8-10-93



8-6-93



8-5-93



8-4-93



7-30-93



7-28-93



TITLE
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


BERNARD J
SCHORLE


RECIPIENT
GABRIELE
HAUER .


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


GABRIELE
HAUER


DOC/TYPE
SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA


SAMPLING
DATA



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                           APPENDIX B-2
            ADMINISTRATIVE RECORD SAMPLING/DATA INDEX

Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE 7
DATE
7-27-93




















TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS




















AUTHOR
BERNARD J
SCHORLE




















RECIPIENT
GABRIELE
HAUER




















DOC/TYPE
SAMPLING
RESULTS





















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                         APPENDIX B-2
            ADMINISTRATIVE RECORD,  CONTINENTAL  STEEL
               FIELD DOCUMENTATION/DELIVERABLES
Documents not copied, may be reviewed at the Indiana Department
  of Environmental Management's Office--Indianapolis, Indiana
                                                         PAGE 1
DATE
3-14-95
11-3-93
9-10-93
8-5-93
10-29-93
3-11-94
3-15-93
6-14-93
11-3-93
10-29-93
9-16-93
3-17-94
10-29-93
8-5-93
8-5-93
8-6-93
8-5-93
11-17-93
9-10-93
TITLE
OU1/TASK 3 A
OUl/TASK 3C
OU1/TASK 3C
OUl/TASK 3D
OU1/TAKS 3D
OUl/TASK 3D, 3G,
3M
OUl/TASK 3D, 3G,
3M
OUl/TASK 3F
OUl/TASK 3F
OUl/TASK 3G
OUl/TASK 3G
OUl/TASK 3H, 31,
'3K
OUl/TASK 3H, 31,
3K
OUl/TASK 3H
OUl/TASK 31
OUl/TASK 3J
OU/TASK 3K
OUl/TASK 3L
OUl/TASK 3L
AUTHOR
DON WALSH
DON WALSH
DON WALSH
DON WASLH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
RECIPIENT
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
DOC/
TYPE
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR

-------
                          APPENDIX B-2
            ADMINISTRATIVE RECORD,  CONTINENTAL STEEL
                FIELD DOCUMENTATION/DELIVERABLES
Documents not copied, may be reviewed at the Indiana Department
  of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE 2
DATE
9-10-93
6-8-94
8-5-93
10-19-93
10-29-93
11-1-93
6-21-93
2-15-94
8-5-93
11-3-93
3-18-93
10-19-93
10-29-93
9-22-93
11-3-93
6-21-93
6-21-93
11-3-93
6-22-93
11-3-93
TITLE
OUl/TASK 3L
OU1/TASK 3M
OUl/TASK 3M
STEPPED DISCHRGE
TEST RESULTS
OUl/TASK 3M
OUl/TASK 14
OUl/TASK 14
OU2/TASK 3 A
OU2/TASK 3 A
OU2/TASK 3 A
OU2/TASK 3B, 3F,
7B
^OU2/TASK 3F
OU2/TASK 3B, 3F
OU2/TASK 3B, 3F
OU2/TASK 3C
OU2/TASK 3C
OU2/TASK 3D
OU2/TASK 3D
OU2/TASK 3E
OU2/TASK 3E
AUTHOR
DON WALSH
DON WALSH
DON WALSH
K HEWITT & D
WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
RECIPIENT
G HAUER
ART GARCEAU
G HAUER
B DAVIS & G
HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER & B
SCHORLE
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
DOC/
TYPE
LTR
LTR
LTR
MEMO
LTR
LTR
LTR
LTR
LTR
LTR
LTR
MEMO
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR

-------
                         APPENDIX B-2
           ADMINISTRATIVE RECORD, CONTINENTAL STEEL
                FIELD  DOCUMENTATION/DELIVERABLES
Documents not copied,  may be reviewed at the Indiana Department
  of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE  3
DATE
9-28-93
3-18-94
10-29-93
8-5-93
10-29-93
6-10-94
11-1-93
8-5-93
9-28-93
11-1-93
8-6-93
8-31-93
11-1-93
11-23-93
10-18-94
9-14-94
11-22-93
6-2-94
TITLE
OU2/TASK 7B
OU3/TASK 3A, 3B,
3C, 3D
OU3/TASK 3A, 3C
OU3/TASK 3B, 3D
OU3/TASK 3B, 3D
OU3/TASK 3E
OU3/TASK 3E
OU3/TASK 3E
OU3/TASK 7B
OU3/TASK 7B
OU4/TASK 3 A
OU5/TASK 3C
OU5/TASK 3C
OU5/TASK 3B
ANALYTICAL
DATABASE
OU1, OU2, OU3
FIELD
DOCUMENTATION
OU1,2,3, TASK 3
OU1/TASK 3 A
RADIONETIVITY
VALIDATION
AUTHOR
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
RECIPIENT
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
A GARCEAU
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
A GARCEAU
A GARCEAU
G HAUER
A GARCEAU
DOC/
TYPE
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR

-------
                          APPENDIX B-2
           ADMINISTRATIVE  RECORD, CONTINENTAL STEEL
               FIELD  DOCUMENTATION/DELIVERABLES
Documents not copied,  may be reviewed at the Indiana Department
  of Environmental Management's Office--Indianapolis, Indiana
                                                          PAGE  4
DATE
2-21-94
5-20-93



















TITLE
OU1/TASK 3M
AQUIFER TESTING
OU3/TASK 3A, 3C
INITIAL SEDIMENT



















AUTHOR
K HEWITT




















RECIPIENT
G HAUER




















DOC/
TYPE
LTR





















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