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
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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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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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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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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].
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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
-------
-------
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;
Page 1
Kttpamvenem Summary * Interim Remedy Record of Decision * Continental Steel Superfund Site M»y 16,1996
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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
Page 2
Ropoofivtnea Summary * Interim Remedy Record of Decision * Continental Sled Superfund Site * May 16,1996
-------
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.
Page 3
Raponnvenm Summary Interim Remedy Record of Decision « Continental Steel Superfund Site * May 16,1996
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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
-------
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
Page 5
* Interim Remedy Record of Decision * Continental Steel Superfund Site * May 16,1996
-------
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
Page 6
Rqpomiveoeg Summary * Interim Remedy Record of Decision* Continental Steel Superfund Site * May 16,1996
-------
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
-------
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
Page 8
Suaaury Interim Remedy Record of Decision * CooJinenttl Sted Superfund Site Mty 16,1996
-------
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%
-------
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
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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 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
-------
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
-------
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
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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 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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