United Slates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAlROciFms,87/055
September 1987'
3EPA
Superfund
Record of Decision:
Marion/Bragg Landfill, IN
U.S. .Environmental Protection Agent!
Region III Information Resour~ .
Center (3PM52) . . ~ . " ~
841 Chestnut Street ~(...~./f,:~
Philadelphia, PA lSlQl ",i¥:;:"-'"-
.~
Hazardous Waste Collection
Information Resource Center
US EP A Region 3
Philadelphia, PA 19107
EPA R9pm1 ~@~~~lG~D@fii1
Inf(lU'malti~fI ~~~@Mcr'~~ ~0:m~(IDfi'
US EP~ ~~~~@~ ~
P~!~tID~(iJ~lQ)nu~@~ ~[Q\ ~@~@11
-------
TECHNICAL REPORT DATA
(PI- t8d /1I'","liDIfI 011111. tr/nR '-{Ole co",pI.tbt6J
1. "IPO"T NO. 12. 3. "ICI~tINT'S ACCISSION NO.
EPA/ROD/R05-81/0C;C;
.. TIT~I ANO 'U8TIT~. I. "I~O"T OATI
SUPERFUND RECORD OF DECISION - er .n 1981
Marion/Bragg Landfill, IN I. ~I"'O"MING O"GANtZATION COOl
IFirst ~"'meni a 1 Action
7. AUTHO"'S' e. PI..'O..MING O"GANIZATION REPORT NO.
[£ ~I"'O"MINO O..GANIZATION NAMI AND AOOAISS 10. ~"OGAAM .I.EM.NT NO.
11. ..gNT..A"II~..ANT NO.
12. S~ON80"INO AOINCY NAMI AND AOO..lsa 13. TY~I OP ..IPOAT AND PI..IOO COVERED
U.S. Environmental protection Agency t:'~...",1 ~nD ~ennr'"
401 M Street, S.W. 1.. S~ONSOAING AGINCY COOl
Washington, D.C. 20460 800/00
11. SU~~IMINTA"'" NOTIS
18. A8ST"ACT
The Marion/Bragg Landfill is a 12-acre site located near the southeastern city limits
of Marion, Indiana. The site is bordered on the north and east by the Mississinewa
River. Main features of the site include a 4S-acre landfill and a lS-acre pond. From
1935 to 1961 the site was used as a sand and gravel quarry, and from 1949 to 1970
portions of the site, leased by Radio corporation of America and Bragg Construction
Company, were used for industrial and municipal waste disposal, respectively.
Throughout this period, the Indiana state Board of Health (ISBH) noted the disposal of
acetone, plasticizers, lacquer thinner and enamels. Drummed wastes were also accepted
and contents were allegedly emptied from the drums and worked into the landfill waste
. with a bulldozer, causing several fires on site. Drums were allegedly rinsed and
resold. In 1975 Bragg Construction company ceased operation of the landfill. In 1915,
Waste Reduction systems constructed a transfer station to properly transfer solid wastes
to an approved landfill. The transfer station was closed in 1971., The landfill
contains approximately 1,100,000 yd3 of waste. primary contaminants of concern
include: DCE, TCE, vinyl chloride, other VOCs including: Bis(2-ethylhexyl)phthalates
and numerous heavy metals.
The selected interim remedial action for the Marion/Bragg landfill includes: capping
with regrading; providing and maintaining flood control measures to protect the portion
; c:! .... . - _.~ ,
'~7. KI'" WO..OS ANO OOCUMINT ANAl. VStS
~ OISC..IPTO..S b.IOINTltlll"S/O~EN ENOIO TS"MS C. COSATI Field/Croup
Record of Decision
~arion/Bragg Landfill, IN .
First Remedial Action
contaminated Media: gw, soil
Key contaminants: TCE, DCE, VOCs,
heavy metals
,.. 0IST..18UTION STATIMINT 18. SECU..ITY CLASS (TltU R.portJ 21. NO. OF PAGIS
None 66
20. SICU..tTV CLASS (Tltu tJGp, 22. P..ICI
None
IPA ,- 2220-1 (I... .-77)
~".VIOU. .OITtON ,. O..OI..T.
.;'i:;:,~}~~.:;~'.j.,\:/.£~.: :;,::;~. ;::-~;:;T;';'i:,;:;;';~?i-i:.~~;'~"j~.~~ij:;V~;;:~.f~::~~~~(:;Si~~~i.;~-~~!~;~-~~i;:~~~~~.~<~:~~.-;'7:.~~,~~:~;~~'i.i~:":'-::;;~~;;'",.~~;.:::;'>.;.~~;;; ~;:;':;.~-:.~~:i:~-;::;;.~
-------
INSTRUCTIONS
1.
"IPO"T NU"I"
Insm tile IiPA I8pCIf1 number II it Ippan 011 the cower 01 elle publk-aeioft.
LlAVI 8I.M1C
2.
3.
RIC"'INTS ACCIaIGlil NUM8I"
R......a (Of 11M by ,"h ftpOf1 m:i,inll.
nTLI AND SU8TITLI
Tiele shouJd indicace I:lcarJy and brieny tile subj«e I:ovcnp: ",( elle n:port. ;and .lIi"f'by.:IJ prulllin.:nlly. ~t 'lUlttill~. 11"""'11. 111 ~nl;alk:r
type Of otlterwise subordinate it eo main eiele. Wlwn a report is PftIIII,Ied in lIIOI\' th;an "III: yulume. rl:po:It 1111: prmlU)' lit"", ;alld y,II:lIl1'"
number and iIIducIe subtie.. Cor ehe specitIc tiele. ,
RIPO"T DATI ,
Each I8pCIf1 shall carry 1 da.e incUcatiql. _e month and ycar.
tip"", ." 01 ~tioIt, 'Ir,}.
""PO".NO O"GANIZAnGlil COOl
La.. bIIaJL
Indk-aev tl.- It. un ..-hkh il ,,;a~ ",'i«tL-d (",/t,. .18/., III ;:uu... Jill.. lit
4.
I.
I.
7.
AUTHORC..
Give !WIIe«,) in l:o)nvcneionaJ order (JoII" R. Dtw, J, Rolwn Dtw. dC.). Li..e ;authur'l ;al"lili;allun i( it .JiI'l"~rl frum IhL' I"Irfur01inll ...pni-
ution. '
I. '..RPORMING O"GANIZATION "IPORT NUM81R
11118& it pedormi... orpniza.ion WiJha eo wi.,. this number.
..
""PO".NO ORGANIZATION NAMI AND ADDRISS
Gi.. fI8IDI. sine.. ci.y, scare. and ZIP code. Lise no more ehan IWO levels o( ;an urpnizaliun;al hirean'hy.
10. 'ROGIIAM ILIMINT NU"''' ,
Use ebe propun "'mene number under whil:h ehe report WI.' prepared. SuborIJin.IlC numb\:" 1l1iI)' be illL'ludL'1I 111 1".U':IIII1.:",...
11. CONTRACT/G"ANT NU"I"
Insert COfttrICt Of pane number under which repon WII prepared.
12. SPON8O"'NG AGINCY NAMI AND ADD""
Inctude ZIP c:ocI8. .
13. r"l 0' "IPORT AHO ""100 COVIRID
Indicaee ineerim f1aaI. ek.. and if applicable. daea covered.
14. SIJON8O"ING AGI8NC't COOl
Insert appropriate code.
1S. SUM.8MlNTARY NOTa
EDeer iftIonnaeion noe included elsewhere bue uselul. such ...:
To be published in. Supenedn. Supplemenu. eec.
11. A88T"ACT
Include a brier (200 wonb 01' IIUI faccual summary or tile mOle .ipilkane Int'urlllilti"n -,unl;aIft\:,I", 'I... ",,,"'1, II 111,' ".,""1 '"''''';1'''' ;a
sipiftc:ant bibliopaphy or lielnnue survey. mention it here.
Prepared ill .:uopcnatiun willi. I"r..n!OlaIl.... "'. I'rL"'L'III.:1I ;al '""111""'11'" It'.
17. KEY WORDS AND DOCUMINT ANAL VIIS
(a) DESCRIPTORS. Selecc flom the The!lUlUS or t:nainccrin, ;and S4:i.:nlit'i~ II/ran!> 11111 prupcr ;aulhuralClJ l.:rll1~ I/I;&t III.:nlll"l' Ih.: m;aj..,
c°llCelle 01 the lesellch and ant suCrlc:iendy specltic and Pfe\o'iM: to be Wll:1J ;&~ Indu I/nrrle. I"ul \;4ItaIU\llnll.
(b) IDENTInERS AND OPEN.ENDED TERMS. U. idaneillas Cor projcl:e n;a1l1\,~. I.:ude n..ml:~, .:qulpmenlll':"lIn;alur~, .:11;. Uw",lIIn.
endad eerms wriuen in descripeor (orm (Of Ihose subjects (or which no _nplol lI~islL
"
(c) COSA TJ HELD GROUP. Field and poup aJlipuaenlJ... eo be takun flom lhe I96S ('OSI\ 1"1 Suh;.:.:t (';aI&:II"'Y List. Sine:1I Ihe ma-
jorilY or doc:uDMIIIJ an mulUcUsc:iplinuy in nature. the Primary field/Group as.'iiplflll:nth. will be: 'Ik'Llli-, lJi'L'II'linl:. "rllll III" hum;an
endaavor. 01 eype or pllysic:a1 object. Tbe apptic:ationcs) wiD be ClQaWCi,,-n:nc:cd with ""'un"",, I wld/( iruuf' ."'llInlllllnl\ Ih:ll will hIli"...
ehe primary poseinats).
11. DIITRI8UTION STATIMINT
Denote relnsabilit). eo Ihe publil: ollimitacion fOI"reasons othel than "",\:urity for CJlilmpk: "RII"II/;a'C 1:lIhlllll&:II," ("II&: ;all!' ..~;ailalllhl)' I..
the public. wllh address and pnc:c.
1.. Ii 20. SICU"ITY CLASSI"CAnON
DO NOT submit <:lassifled reports to the NaUonal Tcc:hnicalln(olmaeion !ll:f¥k-c,
21. NUMBIR 0' 'AGIS
losen tile lotal nu!"bel or paps. inc:ludinllhis one and unnumbered pIIp:~. but Ul:ludll di\trlbutiun 1a\I, I' ;any,
2Z. MICI
Insen the price SIIe by the Naeional fechnicalln(ormation SI:rvic:u UI tllll Govc:rnmene Printin.Omc:c:. il" knuwn,
IPA ,- 2220-1 (R... .-m (It._..)
. . . . .
~. ,:-::~~~~~~:~.:./~: -:::;('!::.~,; t?;,~.:'~:f~::-f!:~;~~f:-'£?';',{'~~~'.~H~:1;f.~:f.:~~~',;~:~:i~.Nt.~.~'i:7~:'~t,;.~~::~~?-;jtf:~,:~~!.~:~~~~{t;>,"",
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EPA/ROD/R05-87/055
Marion/Bragg Landfill, IN
First Remedial Action
16.
ABSTRACT (continued)
of the site within the 100-year flood plain: fence construction: providing
three private wells for drinking water: sealing shallow wells: and
monitoring ground water to determine effectiveness of the interim remedy.
Additional studies will be conducted to determine remedies for ground water
and the onsite pond. The estimated capital cost of the selected interim
remedy is $5,800,000, with present worth O&M of $1,000,000.
-------
Declaration for the Record of Decision
Site Name and Location:
Marion/Bragg Landfill
Mari on. I ndi ana
Statement of Basis and Purpose:
This decision document represents the selected interim remedial action for
the Marion/Bragg Landfill developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA). and to the extent practicable, the National Contingency Plan (NCP).
This decision is based upon the administrative record for the Marion/Bragg
Landfill. The attached index identifies the items which comprise
the administrative record and the public comments upon which the selection
of an interim remedial action is based.
The State of Indiana, through the Department of Environmental Management,
has concurred on the selected remedy.
Description of the Selected Remedy:.
This landfill has three operable units:
the ground water and the on-site pond.
surface soils and the on-site wastes.
remedy i nc 1 ude:
the surface soils and on-site wastes.
This operable unit addresses the
The major components of the selected
o Regrade and cap the site to promote rain runoff. reduce..;nfi1tration,
eliminate leachate seeps and contaminated seep sediments, and prevent
direct contact with contaminated surface soils and exposed waste.
Provide and maintain flood control measures to protect that portion of
the site which lies within the 100 year flood plain.
o Construct aAd maintain a fence around the site perimeter to protect the
landfill cover and restrict access to the site and the on-site pond.
o
o
Provide three private use drinking water wells within the deep aquifer
for water users who drink from the affected aquifer within the site
boundary. Seal the existing shallow wells (if possible. keep one as a
monitoring well.)
Monitor the ground water to determine the effectiveness of the interim
. reme~ and conduct additional studies, as necessary. to complete the
remaining ground water and on-site pond operable units.
o
---..----....--- -.-..-.~'- -- -~ --..- -. --..-. '4-
-------
-
- 2 -
Dec larat ion:
The selected interim remedy is protective of human health and the environment,
attains Federal and State requirements that are appropriate. and is cost-
effective for those elements addressed by this interim remedy. The statutory
preference for treatment is not satisfied because treatment was found to be
impractical and not cost-effective. Incineration was the only treatment
technology considered beyond the initial screening stage. Based on the
lack'of off-site incineration capacity, anticipated duration of such remedial
action (30 to 100 years), high inorganic content of the waste and ash
disposal problems, incineration was. not considered a feasible alternative
for the landfill contents.
Concurrent with the implementation of the interim measures, the United
States Environmental Protection Agency (U.S. EPA) will further study the
nature of groundwater contamination on fish consumption and potential
impacts to aquatic life and the environment. Implementation of these
actions is appropriate now, pending a future determination of the need for
any other remedial actions.
t
~~~ ~;,~g1
iaJJa, v.
Valdas V. Adamku
Regional Admin;
Regi on V
.,...'" ".",.' ,,~"'>;, ~~:...:~::_- :~.~..=::: !~'~:~'::<:.~~,~:. -~...~;... ;.:-: ." ~ .:.:;'--~ ~ . ,.:" ;~'I.:: -~-: :::..':., -..: ,-,'~., [';'-" .::~. < _:'..:~.......:. ,;::. :" l.'-; ~.- ... '.-~~- ,.:.i, ~ . 'f': .~:.. '~::"-""~:::;"r-: ,.;. .;~.::; :':"""''''::';-;~~~:';'' :. " "'-':. ... ....
- .. -, .. .--
: ; '" .',.. ".' ." "; . ':" ,"..... ....- ....<:' ",.",,-, '... ~. -
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Record of Decision Summary
Marion/Bragg Landfill
I.
Site Description
The Marion/B~~gg Landfill site is located just outside the southeastern
city limits of Marion. Indiana. (Figure 1) The landfill occupies approxi-
mately 45 acres of a 72-acre site along the west bank of the Mississinewa
.River. The northern end of the site is within the estimated 100 year
Iflood p 1 a in. I .
The site is bordered on the north and east by the Mississinewa River.
(Figure 2) A cemetery is located along the western border and the.
Eastside Cove recreational area is located along the site's southern
border. A residence and two businesses are located on the southwest
corner of the site. The two businesses are Marion Paving Company and
Dobson Construction Company. Both companies are asphalt plants. A
large (15 acre) pond formed from sand and gravel quarry operations is
in the center of the site. The on-site pond is occasionally used for
recreational purposes. such as boating and fishing. The on-site pond
receives discharges associated with gravel washing operations from the
Marion Paving Company asphalt plant. A large pond of similar size is
located off-site on the Eastside Cove recreational area. adjacent to
the southern site boundary. This large pond on the Eastside Cove
recreational area is used for fishing.
Site History and Current Status
I.
A.
History and Waste Types
1. Hi story
The Marion/Bragg site was used as a sand and gravel quarry from 1935
until approximately 1961. During the period from 1949 through 1970,
Radio Corporation of America (RCA) leased and used portions of the
site for industrial refuse disposal. Concurrently, during the period
from 1957 to 1975, Bragg Construction leased and used the site for a
municipal landfill. Periodic inspections by the Indiana Sta~e Board
of Health indicated that operations at the landfill were continually
conducted in an unacceptable manner. Indiana State Board of Health
(ISBH) specifically noted the disposal of hazardous or prohibited
wastes including acetone, plasticizers, lacquer thinners and enamels.
Drummed wastes were allegedly emptied from the drums and "worked" into
the landfill waste with a bulldozer. Fires created from this co-disposal
operation destroyed two bulldozers. Drums were allegedly rinsed and
resold. Other typical violations included lack of daily cover, placing
waste in standing water (pond encroachment) and the burning of refuse.
In 1975 Bragg Construction ceased operation of the landfill. The landfill
was covered with a sandy/silty material and seeded. The landfill was
never formally closed through ISBH.
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N
.
MAR 'Ofill
INDIANA
FIGURE 1
-
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.01
&",.OX. SCALE IN MILEI
'SITE lOCATION
-------
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Legend
- Site Boundlry
~ Marion Paving Co.. 'nc.
f:J;:;!;!; Dobson Construction Co" 'nc,
"" Private Residence'
- - IJnII Ar8I
~~. \
! i
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FIGURE
2
SITE MAP. MARION/BRAGG LANDFILL
(. j
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-2-
In 1975, Waste Reduction Systems, a division of Oecatur Salvage,
Inc., constructed a transfer station on the premises in order to
transfer solid wastes to an approved landfill. The transfer
station was closed in 1977. In January 1980, ISBH issued a letter
stating that~~he transfer station had been closed in an acceptable
manner. . .'
.In December, 1982 the Marion/Bragg Landfill was proposed for the
~ational Priorities List (NPL) with a score of 35.25.
2.
Waste Types
During the reMedial investigation, wastes from 3 boring locations were
analyzed to confirm the presence and relative concentrations of
hazardous contaminants. (Table 1) Leachate wells were constructed
in these borings. These wells were screened within the waste material
in order to provide information on the relative concentration of
contaminants leaching from the landfill to the ground water at the
present time.
B.
Present Site Conditions
The final cover applied to the landfill is a very permeable silty
sand material which varies in thickness from three to 24 inches.
There are numerous areas where debris, including drum carcasses,
protrude from the fill. The surface is vegetated in most areas and
four to five inch diameter trees are also predominant surface features.
The on-site pond was at one time stocked for recreational fishing,
but is no longer used as such. Teenage children have been seen fishing
occasionally from the on-site pond, otherwise the site is not typically
used. At the southwest edge of the pond is an intake pipe and effluent
ditch froM the Marion Paving Company. Marion Paving has an expired
permit issued for IIprivate use water.1I The permit allows water
withdrawal and discharge to the on-site pond for the gravel washing
operation.
Another asphalt company, Dobson Paving Company and a private residential
home.are also located within the property boundary. All three have
shallow wells which are in the upgradient, uncontaminated portion of
the aquifer.
C.
Site Stratigraphy and Hydrogeology
The stratigraphy at the Marion/Bragg Landfill is very simple. It
consists of landfill wastes (0-32 feet thick), outwash deposits
(6-64 feet thick), glacial till (54 to 63 feet thick) and bedrock
(thickness unknown, surface is 89 to 125 feet below ground surface).
-------
T8ble ~
~,.., of Weste lori". S~l!". "..ul ts
Marionllrlil Llndflll -I/FS
IIVISTIGATIVI SAMPLESCI) IAClCGlQ./IID WCPLESCb)
........................ ....................-
IIIO~-.or POSITIVI 110. Of! POSITIVI
DmCTlCIISI DETECTICIISI "' I CAL CCIIC. EXCEEDS
110. OF VALID WGlOf 110. or VALID WGlOf II U.S. SOILS "'ICAL CO
CCIIlTjTUEITS OISI-VATlCIISCc) DETECTICII OISE-VATlCIISCc) DETECTICII CEPA,1983) II u.s. SO
[[[
VOLATtLES, CUI/kg)
..................
1,1-Dfchloroethene 1/11 12 017 . lane Est8b11 aIled U
t,tot-Trichloroethene 4/11 15'46 0/7 . .ane Es t 8Ib li "'ed IIA
Acet0"8 "" 53 . 824 417 ".15 .0"8 Established U
Benzene 5/11 5 . 11 01" . lane Establl."ed U
C.rbon Cllsulflde 1/11 , 017 . lane EstIDlI"'ed U
Ethylbenz- 5/11 13 . 344 0/1 . lIoN Est8b1 I aIled 'U
~ethyl- Chloride 10/11 ,. . 240 ZI1 1.5 . 9.5 lane !stabll."ed U
Styr- 1/11 17 017 . lane !staDll"'ed U
Tetrlcnloroeth- 3/11 36 . " 0/7 . lIoN I!ItaDII."ed U
Toluene 5/11 5 . Z1 011 . IkIN EUabll."ed .. U
Total ICylenn 3'" 40 . 100 0/1 . ... EUaDl!"'ed U
Trans",Z-dlchloroeth8n8 4/11 10 . 4745 011 . IaN htabl; ahld U
Tr;chloroeth- "" 5 . 414 017 lID ... EltaDll"'ed IIA
nyl Chloride 3/11 az . 341 011 . ... EUabl! aIled U
SEMI-YOLATILES,CUl/kg)
. ......................
b;s(Z-ethylhexyl>phthlllte 11/11 S31 . 9,040,000 117 97'0 lane Est8bllshed leA
DI-n'butylphthallte 1/11 1.,000 117 441 IICIN Establl aIled U
Di'n'octylphthilite 1/11 450,000 017 . -- I!ItaDIlshed leA
PESTICIDES, CUl/kg)
...................
CMordMe 3/4 300 . 640 0/1 . ... EUaDll."ed U
" tNo.GANICS,Cmg/kg)
..................
Ant i.."". 3/11 21," 017 . Z . 10 ,
- ..,,1\8 "'" 10 . 40Z 111 11.15 100 . 3000 I
C"'\8 "" 4.J' 4G3 117 J .01 . 0.1 ,
Ch"08I\8 11/11 6.J . Z5 111 1 . 11 1 . 1000 I
Coppe" 11/11 13 . SI50 717 11'42 Z . 100 ,
Leed 11/11 '.f . 587'0 111 5.5 . 18 Z'ZOO ,
Mercury 8111 .10 . .35 017 . 0.01 . 0.3 .
Sodf \8 11/11 1410 . 3060 611 680 . 1960 ... E8t1b~ I"'ed u
Tf" 10,11 ".73 311 ",22 2 . ZOO I
Zfrte 11/" 32 . 2910 111 29.11 10 . 300 ,
a) 'lute Iorf", S..~.. . WlG1, ..oz, ard was
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- 3 -
The landfill contains approximately 1.1 million cubic yards of waste.
At least 4 percent of the total volume is perennially saturated in the
upper aquifer. The saturated areas are to the east. west. and north
of the pond. South of the pond a water filled gravel pjt was allegedly
filled with demolition debris. The saturated volume of this pond has
not been estimated. (Figures 3 & 4)
~utwash deposits (sands and gravel) constitute the surficial aquifer.
The average hydraulic conductivity is 4.27 x 10-2 em/sec. The aquifer,
gradient is toward the Mississinewa River. The Mississinewa River is a
hydraulic barrier causing the contaminated groundwater beneath the
site to discharge to the river, without allowing flow to pass beyond
the river. The estimated flow velocity is 2.78 ft./day. At this rate,
the aquifer beneath the site purges every 2.2 years, or 7 times in the
last 15 years.
.
The on-site and off-site ponds are hydraulically connected to the
groundwater. The presence of the large on-site and off-site ponds
creates a hydraulic anomaly in that water flows from the off-site
pond, discharging to the aquifer, recharging the on-site pond from
the south. The on-site pond discharges radially from the west,
north and east sides of the pond. The predominant discharge area
is to the north, to the Mississinewa River.
The outwash deposits are underlain by a very low permeability glacial
till. This till is approximately 54 to 63 feet thick. The hydraulic
conductivity ranges from 1.0 x 10-7 cm/sec to 2.88 x 10-8 cm/sec.
This till layer is considered an aquiclude.
The glacial till layer is underlain by limestone bedrock. The thickness
of this layer is uncertain, but it was first encountered at 88 feet
below ground surface. This bedrock layer constitutes a second aquifer.
This confined aquifer has an upward vertical " gradient, toward the
glacial till.
D.
Public Health Evaluation:
Hazardous Compounds, Pathways and Risks
Numerous exposure pathways were considered in the Public He~lth
Evaluation. These include direct contact with surface soils, leachate
seeps, swimming and fish consumption from the on and off-site ponds
and consumption of groundwater beneath the site. The field work was
completed in two phases; spring (March) and summer (July). This
offered some seasonal variability as well as providing two rounds of
samples (in most matricies) for data evaluation.
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..~ ~ n H g.
MW 181 "'I 6: i o'Z-:'.~.{J
. LJ. -- . [] ~
l8gInct ~ --.!:. ;;: ~
I' - Site Boundary ~ ~i' ~..:: : ~ 0 250 500
1,'--LandfiIlAreas °0 "'(~~h b ~----J"MW.1~ ,::~I: . Scale in feet
-2- Depth 0' Fill Below Water Table ti -----. -, .~- -, < ~ S1 IF.,. Contour InI8n8l
,~ 8 MW - Groundwaler Monitoring Well (REM II) . -~-,' ~;i" 0' ('
I A FIT - Groundwaler Monllorlng Well (FIT) - - -' ~S>
---- "
. LW -leachate Well (REM II) 8 MW.13 FIT.3.14r'MW.12" II ~ ".D .
J 0 LFW - Old landfill Well "" '~'!:'~J! '.::-' 1? S!p [f
-1- "Filled Pond - th tJn}o-JlOW11, '" \ ~ '--''-~'ff~- ~
8lW.2 MW.1 -, :;
<, n~a" dd~ 3.5 Ft. '\ Gd:
" 1j1;-~ 2 ~ o'(~
..1 m'm~_-_~~ ,,===:~..=::::r::_M.~-7, i: - - -I' .--~: -~ ~ ~ \' \. , ".
~ ! -~-m!n-.~._.~....~ ...~w) ---- 1\ l ~3 FI. F MW.9
:1 .1 j ,I T ; ,~~ .3 ", ~
"1' 'f -'-t---i.;~--.'"tjl~... '-----"-""'~:;. MW-2 6 ~ 7.3 FI. On-81'. Pond I' \'-.
\: =. F . "'/,~ '
'. r-:, . . : ~ MW-1' ~ 4''/' i
~~, '~~, ':. ., ~.. . '11 "? "2
~.,....' ',-~, \. . \ 1,.:- A I ~..J. '\. .,
-: ~,:~'~~~.h""'~",,,,_-,>-\,\. ...:~:-~-i f v ;;dr~][ \\ J~ MW-4,,,MW-;J
.\E "..... ...7-" 't . .,.- a --1(Q ~+, '- '- - :~
''''-I. ..'. \~. .'.. . . \" :.:::-~ ", .- ., \\
\ " ." '\'--'..' I, . 0 .,. - - ~.~ \\
' CS "','. ~.~".. :
-------
F W..,
140
1
IL
740
-
W." TabIt
MW-3--~
-SM.
MW-2
MW-3
MW-2
MW-1
LW-3
0..-1... P.."
Upper Aquller - Outwa.h Depotll.
Sand and Gravel
ConfInIng La,.. - Glacial TII
SUt, Cia,
MW-1-
MW-8
MW-'
-SM-SC-
- - ------ --- - - ---- ------
Low.. Aquller - Bedrock
Limestone
Waldron Formation
Groundwa'" Elevations .re From 7/23/86 Meaauremenll
o
.
250
"
.'f'
.
500
Scale.in Feet
13.75 . Vortlcal Exaggeration
FIGURE 4
GEOLOGIC CROSS SECTION F-F' MARION/BRAGG LANDFILL
F' E..,
140
120
-
780
760
740
720
700
..0
-------
- 4 -
1)
Surface Soils and landfill Contents
a) Contaminants and Pathways of Exposure
Surface"-~oi1 samples were collected to determine if hazards
exi st because of the contami nants present. Five" samp1 es were
taken from the landfill surface, and one sample was taken adjacent
to the asphalt plant, off of the landfill area. Each sample was
a composite of five grab samples in a 50-foot radius. These data
were evaluated relative to background soil concentrations.
The contaminants of concern were Bis (2-ethylhexy1) phth1ate,
cadmium, lead, mercury and several polycyclic aranatic hydrocarbons
(PAHs). The presence of PAHs is likely due to both the landfill
and the existing asphalt plants. PAH concentrations were highest
in the sample near the asphalt plant. Only one other sample had a
significant concentration. This was located on the northern part
of the landfill, away from both asphalt plants. Cadmium and lead
were also present at low levels in at least five of the six locations.
Two leachate seeps are present on the landfill surface. One
leachate seep discharges directly into the on-site pond. The
other leachate seep is on the south center section of the site.
It is present most of the year. The seep follows the surface
.drainage direction off-site to the south and toward the large
off-site pond on the East Side Cove property. The contaminants
of concern are arsenic and most of the other inorganic metals.
Because the surface soil is contaminated, receptors (wildlife and
human) may inhale, ingest and contact hazardous compounds directly.
Contaminated soils may also be transported off-site during rain events.
This action, over time, could result in greater exposure of landfill
contents as well.
b) Risk to Receptors
Risks above 1 x 10-6 are associated with direct contact with soils
due to PAHs in the surface soils (average:. 2 x 10-7, maximum: 5 x 10-5)
and arsenic in the leachate seep (average: 4 x 10-7, maximum: 8 x 10-6).
The hazard indicies for these matrices for noncarcinogenic effects are
less than one.
2) On-Site and Off-Site Pond Water and Sediments
a) Contaminants and Pathways of Exposure
Eleven samples were taken from on-site and off-site ponds. Seven
sediment samples were collected. These data were compared to
background samples. Chlorofonn (13 ppb) and bis(2-ethylhexyl)
phthalate (11 ppb) were detected once in the on-site pond. Many
inorganics were detected in the on-site pond above background
levels. The only sample which exceeded water quality criteria
-------
- 5 -
represented a leachate seep which discharges directly into the
on-site pond. Chromium and mercury were each detected once in
the off-site pond below acute water quality criteria. The mercu~y.
however, was not reproducible in the sample duplicate, nor
did sub~:quent sampling confirm its presence. . .
Pond sediments contained several inorganic constituents, phthalates
and some PAH compounds. Two on-site pond sediment samples had'
low levels of some PAH compounds. Individua'l PAH were present at
concentrations ranging from 65 to 170 parts per billion (ppb).
One off-site pond sediment sample contained a trace amount of two
PAH compounds. The off-site pond is hydraulically upgradient of
the landfill. It may be somewhat under the influence of the
landfill from the ground water pathway, however, it is likely
that surface run-off from the landfill is the greater influence
on water quality. Although the southern portion of the landfill
is well vegetated, it does slope toward the south and the leachate
seep flows off-site toward, and likely into, the off-site pond.
b) Risk to Receptors
Risks were considered for swimming in the on-site pond and fish
ingestion for both ponds (the off-site pond is not used for
swimming). The risks presented for these activities were not
above the 1 x 10-6 point of departure, and the hazard index for
noncarcinogenic effects, was less than one. There are two possible
weaknesses in this assessment. First, the risk assessment did not
rely on actual fish data. Instead, bioaccumulation factors from
available literature values were used. Such bioaccumu1ation
pathways are not well studied and the modeling of fish contaminant
uptake has a high degree of uncertainty. The risks (or lack of
risk) estimated at this time mayor may not reflect actual or
potential risks due to the site.
PAHs and inorganics present in the pond sediments, in general,
do not tend to bioaccumu1ate. The predominant method for the
accumulation of chemicals by fish is presumed to be absorption
through the gills from the water, not from the sedimen~s or
through the food chain. Sediments may be a critical source of
chemicals for aquatic life that dwell or feed primarily on the
bottom. There is very little information on the relative contri-
bution of sediments to chemical residues in aquatic life. Literature
values do not exist for sediment uptake by fish, therefore it can
not be modeled.
Second, the surface waters (with the exception of the leachate
seep flowing into the on-site pond) met water quality criteria to
the extent that this criteria was above detection limits. However,
the difficulty with the water quality criteria is that many of
the inorganic constituents have levels set for protectiveness of
either the aquatic life or human consumption which are well below
-------
- 6 -
analytical detection limits. Therefore, it is conceivable that
bioaccumulation could be occurring either from the sediments or the
water, which is not evident based on existing data. Bioassay work
is needed to determine if a risk is present to humaR health from
this sur~~ce water/sediment pathway.
.- ,
Sediment data, in general, are difficult to evaluate because
there are no criteria. Region V has developeq a database for
inorganics from the Great lakes Harbor sediments. This provides
a relative concentration range for comparing non-polluted, moderately
polluted and heavily polluted sediments. In comparing the inorganics
to the pollutional classification suggested in this database, .
only one sediment location was noted to be a potential concern by
the U.S. Fish and Wildlife service. This was at the leachate seep
in the on-site pond.
3)
Ground Water
a)
Contaminants and Pathway of Exposure
The ground water beneath the site discharges to the river.
Ground water exposure is an incomplete pathway because no one is
currently using the aquifer beneath the site as a water supply.
The risk estimate was based on potential future use.
Thirteen wells,were drilled around the site perimeter, eight of
the wells were drilled through the landfill. Since this site
borders the river, there is no plume or downgradient area to
sample, except for the river. Therefore, the monitoring wells
had to be drilled through the fill material and screened in the
aqui fer below.
Since any release from a facility is a potential problem, all
chemicals present are of concern. Benzene, trichloroethylene and
bis-(2-ethylhexyl) phthalate are present most frequently and above
criteria. Most of the heavy metals were detected only once in
the ground water beneath the site. These are generally below the
MCl, where available, but above the fresh water aquatic .life
criteria. Arsenic is an exception. It is above the MCL in three
of the samples, but detected at lower levels frequently. In
general, the contaminants were detected at low levels. (Table 2)
b)
Risk to Receptors
The public health evaluation presumed future land use as a recre-
ational area, where drinking water wells would be required. Exposure
would be infrequent, but would occur over at least a lO-year
period. This resulted in a lifetime risk range of 7xlO-o to 5xlO-4
due to arsenic. Without the arsenic, the maximum risk was estimated
at 3xlO-7. The hazard index for noncarcinogenic effects was less
than one.
--, ~ -----:-' ~',~'.-,:.:..:-::~;~:,-:;-.:.:. -:":,,_'~:I~;'~:':_-_:~':' ~~..~ :~~.:;= :. .:: "-:.p -.~ : . " ~ .;", ,.- .~... ....~.: . . :.-.:.:,:: :~~ n ""'1-' '," :.- .~~'_.,- ~\,.., .. .
.3-..- - - ' -. ~--'.'
. _..: ....' ..-._._.ii,..:....~'~- ...,... -'.. ..-.,
-------
.NIt....1I Ulftl...)
(
Table 2
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IIlIyl......- 41l' I.S . , ."
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-------
- 7 -
The risk present in the ground water beneath the source is likely
to vary from one area to another due to varying waste types and
resultant ground water concentrations. The maximum'risk was
estimated,~y usin9 the highest concentrations of all contaminants
found. rrab1e 3)
Parameters other than the priority pollutants, are also a concern
because they can indicate unacceptable water quality. Parameters
of concern here are ammonia and chemical oxygen demand (COD).
Ammonia is a product of degrading organic material. The ammonia
ranged from 0 to 24 milligrams per liter (mg/l) and the average'
ground water COD was about 600 mg/l. There are no drinking water
standards for these parameters.
Since the ground water discharges to the river, several parameters
are of potential concern for protection of fresh water and aquatic
life. These are discussed below.
4)
The Mississinewa River
a)
Contaminants and Pathway of Exposure
The Mississinewa River is the major ground water receptor. During
the winter, river water levels were slightly higher than the summer.
In both phases of field investigati'on, the river was at average
flow (about 600 cfs). Ten water samples and six sediment samples
were collected. The river did not show signs of being impacted
by priority pollutants. Sodium was detected in the river water
north of the site at levels above background. This is likely to
be landfill related. Beryllium and silver were detected in one
sediment sample downstream of the site. This may be a result of
off-site migration of surface soils, due to the flood pathway
between this sample location and the site. This is uncertain
since these contaminants were found only once, at a low level.
Certain water quality indicator parameters were ana1yzed.for in
order to evaluate whether or not the landfil~ may be impacting
water quality in a way which is not characterized by priority
pollutants. Ammonia and chemical oxygen demand (COD) were again
the key indicator parameters. The COD did not vary significantly
between upstream, near-site or downstream. Ammonia was present
above water quality criteria in two samples taken north of the
site. One sample was taken from a backwater channel (5.6 ppm)
and the other was taken at the river edge (3.2 ppm). Ammonia was
also detected above background, but below water quality criteria
east of the site (.6 ppm). The State of Indiana river standard
for ammonia is .8 ppm in the summer and 1.13 ppm in the winter.
This standard is pH and temperature dependent.
North of the site there is a backwater channel which flushes when
the river is at a high level, but otherwise exists as a stagnant
pool. The extent to which samples north of the site represented
an impact from the landfill versus the backwater channel is
uncertain. Ammonia is toxic to aquatic life, and the criteria
represent the minimum conditions necessary to support aquatic life.
. _..~. .-- -. ." ,.' _-._.0. . '-- - '----.
-------
II8f J.
EJIUIIES ,. IUIS ASD:lAtID "III IUSTI(18 Of UftI IWllfII CJDJD "'111(8)
0IrcI\i~ Dlity 1mb--1O-k8
'P' AlPf.. Irdivic18I, Prorated 4Mf' 8
"""nticn (IuIUt..) 10-,... Ltfet- C8III'W.) 11* (~
en.- fUtlRY
CIte""" Awn8I "'''' '''''' II1II1- f-=tor -I AwngI II1II'-
(lglqfd¥)
.. "
,,'
~C 0." 0.018 4.5110'7 ,5 1 1)(10-6 5110'4
).51110'6 l.bID_Z ~)
..... (b) 0.012 18 5.41&10 Z.6111O ~) .. ..10- 7
'iI(Z-~) 5..10.7 .4 6.81110-' (12) 1110-10 31110-1
J'alhatet8 O.DS 1.10) 4.51110_,
trldllOll~1t*8 (b) 0.001 .. )."10-7 1.I.ID:~ (Il) .. 31110-.
t8tl'8d\10II0IttIIrw (II( 0.CD1 18 4.51110 S.I.lO (Il) .. 21110-.
teal 1)(10 ' 511104
0Ircn1~ Dally""" -10-"
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11* Ie"-~
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...1uI O.D 1.a 1.51110-4 .) 511lO-Z 1110') 1.10:;
5.11110'5
IIrtIUUI (b) 0.006 18 U8I1O 5110') .. 41&10
'Ia(Z'~) ).51110" -) 2I&lO'Z 21110"' -1
J'a1hat8t8 G.DS 1.10) ).1.10.5 '.1O_Z
c.iliUl (b) o.em 811 1.61110.5 311'0'4 811 5810
I 1h1arci11in188 (b) G.016 811 5..10.5 31110'Z 811 21110')
1,4'DldllOII~". (b) G.014 18 4.41&10 2I&10-Z 811 21110')
1CD'I,Z-Dldllaro- ,5 "lO-Z 61110-)
..... (b) 0.0i!D 811 6.51110.4 811
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letradllCi 0IttIIrw (b) 0.001 811 ).1.'0'6 21110'1 ID 21110'4
-5
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..... (b) 0.006 811 1.91110.) 1.41110'1 2111~ bI0.)
IIirUiI88 .w 0.44' )_21110-4 1.11110'4 Z.bI0'1 61110.)
Zire (b) 0.11. 811 UklO Z.1II10 811 21110
teal C1(58lO') Ic(JIIIO-1)
"b1Iy d..araa. of CIIn8n *tected In ... 'fPII' .'" 8"d for IIIIdI CJ8'Iitatlw 1Ie8I... effeeta c:rh..18 .. _HIIII. ....
InctuW In ...1. 1 T T _. "'Ic -=Id. 1111\ ......~ 8"d 80diUl .... lilt ..hat'" Sea t.t 8"d ,l1li. 5.5, 5-20, .-d 5-2'l
~~~ ..'
"-- .... flit celueted "-' cnly ... 8111pte ... pIIltlw ... .... fIJC nprted tIIen ... celajated...... 1- ...... the
delattlcn Il8It. 1... d¥8imla WIn! _Iwted in the pI_ible _1- --10 cnly.
I
-------
- 8 -
b)
Risk to Receptors
No curren~ human health risk is estimated for recreational use of
the river~.flear the site. However. the FS did examine ground
water discharge concentrations which would allow protection
of the river. its uses and the biota. This i.s based on possible
low river flow conditions. This approach is typically used under
the National Pollutant Discharge Elimination System (NPDES) to
establish discharge limits. The impact of a discharge on a
river's water quality is based on minimum dilution which is
represented by the lowest seven consecutive day flow occurring
statistically once every 10 years (Q7/10) in a specific reach of
the river. Limits developed using minimum dilution provide
maximum protection of aquatic communities.
Given the groundwater contamination flow from the site. and the
river flow. the resulting contaminant concentration in the river
can be estimated. This is a simple dilution equation. Taking a
slightly different approach. the on-site concentration allowed to
protect the river at the low flow can be estimated. This NPDES
approach is not required. but provides a logical means for estimating
potential risk to the river. Under this scenario, two potential
problems became apparent. the inorganics and ammonia. Aquatic
species are very sensitive to low concentrations of some inorganics.
Most inorganics of concern were not detected more than once
on-site. Only longer term monitoring could determine their
significance. Arsenic. however, is high on-site and has the
potential to affect humans consuming fish. The aquatic life
criteria for protection of fish ingestion is .0175 ppb. Since
this level cannot be analytically detected in the surface water,
arsenic released from the site could be bioaccumulating at a very
low level. In addition, the on-site ground water ammonia levels
have the potential to adversely impact aquatic life in the river.
This is particularly a concern since elevated ammonia concentration
have been detected in the river. In two samples, it was above
- the State of Indiana water quality criteria. .
Based on this assessment. the Remedial Investigation (RI) and
Feasibility Study (FS) conclude that there is no currently identfied
risk to the river, but the potential for such risk does exist.
Asphalt Plant Effluent
5.
The asphalt plant operates about half of the year. Effluent from
the Marion Paving Company asphalt plant is discharged to the on-site
pond via a surface drainage ditch. The effluent is a result of gravel
washing. It was sampled to determine whether or not contaminants
found in the on-site pond could logically be attributed to this
source. The discharge contained a significant amount of inorganic
contaminants, mostly associated with the high total solids content
of the water. This source is not expected to contribute significantly
to the inorganic contaminants within the on-site pond. The COD
-------
-9-
in the effluent was high and likely contributes some oxygen demand
within the pond, however, pond COD values were not significant.
Public Health Evaluation Summary
" ,
Table 4 summarizes the potential risks associated with the Marion/Bragg
Landfill. These potential risks are above the 1 X 10-6 point of departure.
for ~arcinogenic risk for two pathways: surface soils and ground water
consumption. As noted before, the PAHs causing the risk in the surface
soils are a result of both the landfill and the asphalt plants. The hazard
index for noncarcinogenic effects is less than one in all matrices.
II I.
Enforcement Summary (see appendix 1)
IV.
Alternatives Evaluation
Remedial action goals were presented in the Marion/Bragg FS report to
address each of the site hazards or exposure pathways identifed. They
were identified for each of the following operable units: surface soils,"
and on-site wastes, ground water, and on-site pond and sediments. "
The alternatives were also designed to comply with 9 121 of SARA.
The extent to which each alternative meets the remedial action goals
and complies with SARA is discussed relative to the evaluation criteria
provided by Section 121(b)(1).
A.
Remedial Action Goals
1)
Surface Soils (incl. Leachate Seeps) and On-Site Wastes
(Landfill Contents)
Minimize Direct Contact - Minimize risk to public health and
environment from direct contact or ingestion of landfill contents,
contaminated surface soil, surface leachate seeps or seep sediments.
Control Migration Off-Site and to Surface Waters - Min~ize and
mitigate the overland migration of contaminants from leachate
seeps and contaminated surface soils which may flow or be washed
off-site or to the surface waters.
Minimize Migration to Ground Water - Minimize the leaching of
contaminants from contaminated soi15 and landfill contents into the
ground water to adequately protect the surface water receptors.
2)
Groundwater
Minimize Direct Contaminant Consumption - Minimize possible future
risk to public health from direct consumption of contaminated
ground water.
If .:..:~.~::;,'. t:\"~~::;~-t~~...,~';~~;::::7:;~7'~:'~'~":;'.:"~~~~;~:~:;t: fE;,::';Q:::~].. ~~:;~~'i:.~~~,::~:.~:~~'~ ':':11 .;.~.~...7::;:-,":~ ::';"! .".. :~- ":..~-::.-;'.:: .'...-..~:"_:'~ :.~';::;;"". ,,~:,:,,~,,:~, ':.~L-:...-..:r'~~~~.-'~,; ~.:.; _..:: ':':::..;-:;:'>:"! ....,..:..~....:.~:.; ,~-; ':1;~~::".':..~.:~...-...,..i.; ...:::.~:a... -: ..~-\..:..:~~~~~:~ :.i. .~"~~-- ",'
-------
TASIE 4 .
...~~ OF POInlI'IAL JUS1lS ~~ WI'IH(a)
EXPCSURE 'It) JWUCN;mw:::G QiDo!ICAlS OF CDNa:RN
Hazard In:lex for
Na-carci.ncgenic
Effects
LifetiJlW! ~e!
Cancer Risk
~)
Pathway/~c::al
Direct O:mtact with SOils
T .;IIchate See!p Area
Frequency of
Cetecticn Average KaYi1ftl'llll
Average
)tay~ 1ft! ""
Arsenic 1/1 !f:2- 3 !f:2-2 4Xl0-7 BxlO-6
Total 4xl0 9xl0 4Xl0-7 BxlO-6
SUrface Soils
PAHs (Carci.ncgenic) 13/42 (b) NQ-3 NQ-l 2xlO-7 SxlO-S
'l'otal ,- 2xlO 6xlO 2xlO-7 !xl 0 -S
Sw'iJnrnin: in on-si te PI::n:1
~ 6.4Xl0-3 2.3xl0-3 NQ 3xl0-e
~on of Fish trc:m
On-Site Pond
'1'otal 3.7xl0-2 2.2xl0-1 NQ 2.10-7
~a1 ot Fish
traD Off-Si te Pcn:1
~ - NQ 7xl0 -4 NQ ' NQ
~a1 of GraJn!wa~~
tran nr-.,. Aq;1ifer
~ 1/'19 NQ-3 NQ-1 7xl0-6 5xl0-4
~ - 5xl0 3xl0 7X10-6 5xl0-4
8.n. 1n1ividual c:Naicala of ccn:em prasented in this table are these that may
p:88 . potIInt.ial r18k: they are defined as dwmicals e:xtUbit.inq ncn:arcincgenic
ett8Cta tar Vdc:h th8 hazard :1zD!x ot exposure is greater than ene, ar the
ct.Dicals 8Xhibitin; ~ eftects tar 1Ihic:h the '~m1 risk tran
exposure 18 grMt.8r than 10 .
~ of th8 individual c:arci.ncgenic PARs were detected mare trequently than
2/6 ID'lital:'in; II81II>1-.
NQ . Net 0Jantiti8:t.
-------
- 10 -
Control Migration to Surface Water - Manage migration of contaminated
groundwater to the on-site pond and the Mississinewa River to
provide adequate protection of surface water quality and aquatic
life hab~~ats, and the human ingestion of aquatic organisms.
3)
On-Site Pond and Sediments
Minimize Direct Contact - Minimize the human exposure potential to
the on-site pond from swimming and ingestion of aquatic organis~s.
B.
Alternatives Considered
Six alternatives (plus No Action) were developed to meet the
above remedial action goals. These are described in detail in
the FS. The alternatives were assembled in a building block manner
so that any or all of the operable unit components could be addressed
(i.e.: cap, cap and ground water). A wide range of suba1ternatives
were provided because there are several ways of achieving the remedial
action goals in a cost-effective way. Each alternative has four
suba1ternatives based on two cost sensitive variables. The first
variable concp.rns regrading of the existing landfill surface prior to
capping. Both capping alternatives have minimum grade requirements
to promote rain run-off and prevent erosion. This requires that
either a significant amount of off-site borrow material be used on
the existing surface to bring it up to grade, or that the existing
surface be regraded to achieve the required grade before capping.
The second subalternative considers whether the on-site pond operable
unit component is addressed. The pond water is a receptor for the
contaminated groundwater. Since this pathway is a concern, options
for minimizing potential exposure were evaluated. In leaving the
pond open, long-term monitoring and site access restrictions are
presumed. The other approach would be to eliminate the pathway by
backfilling, and thereby eliminate the need for monitoring and access
restrictions.
These two variables are assembled as suba1ternatives.
i )
i i )
i i i)
Cap installed over existing fill with pond remaining
open
Cap installed over existing fill with pond backfilled
Cap installed after regrading existing fill with the
pond remaining open
Cap installed after regrading existing fill with the
pond backfilled.
i v)
In total, there are 24 suba1ternatives to consider. All alternatives,
except no action, include replacement of shallow wells, fencing and
flood protection. Deed restrictions will also be sought from the land
owner, regardless of the alternative selected. The components of the.
six alternatives are presented below.
-------
-11-
Alternative 1 -- Indiana Sanitary Landfill Cap and Monitoring
Alternative 1 includes fencing, a two-foot clay-type cap and six
inches of,~opsoil to reduce infiltration, promote runoff and
eliminate off-site migrati~n of contaminated soils and leachate
seeps. This alternative addresses all of the operable unit goals
except one. It does not aggressively manage the migration of
groundwater to the surface water(s). The exposure pathway from
groundwater to surface water is still present in this alternative.
This alternative reduces infiltration through the landfill from
13.0 to 4.13 inches (70%). It meets the technical requirements
for Subtitle 0 landfill capping under the State of Indiana regulation.
This alternative minimizes, but does not eliminate, leaching of
contaminants to the ground water. The alternative relies upon
monitoring to ensure that levels protective of the surface water(s)
and their uses is still achieved. If protective levels are
exceeded then additional remedial actions would be indicated.
Alternative 1 would cost between $6.8 million and $19.7 million
in present worth (cost variations due to regrading and backfilling
the pn-site pond).
Alternative 2 -- Multi-layer (RCRA) Cap and Monitoring
Alternative 2 is the same as alternative 1 except that the cap
is a RCRA multi~layer cap. This reduces infiltration to zero
and meets the technical requirements for landfill capping for
site closure under RCRA. This alternative does not address
the groundwater and monitoring is still needed to ensure that
levels protective of the surface water(s) and their uses is still
achi eved. Addi tional remedi al action would be needed if protect i ve
levels are exceeded. Alternative 2 would cost between $11.2 and
$25.6 million in present worth (cost variation due to regrading
and backfilling the on-site pond).
Alternative 3A -- Indiana Sanitary Landfill Cap, Slurry and On-Site
Ground Water Treatment
Alternative 3A includes the sanitary landfill cap, a slurry wall
to minimize off-site migration and groundwater pumping, and
on-site groundwater treatment. The on-site treatment facility
would consist of activated carbon adsorption for low level
organics and COO removal, and an air stripping system for
ammonia removal. Pilot studies would be required before implemen-
tation of the remedy for slurry wall/waste compatibility and to
ensure that the carbon adsorption ground water treatment system
can remove the low level of inorganic contaminants. Since the
landfill is not supported on the river's edge, the slurry wall
would need to be installed 70 to 95 feet from the edge (i.e.,
through the landfill material). This would result in some portion
of the landfill remaining outside the slurry wall (approximately
1.6% of the total waste volume).
,--,-__~'-~r_--'.-~-- .---- ---.--.--.-"--
-------
-12-
Neither the slurry wall or the cap are impermeable. The ground
water inside the wall would need to be pumped and treated. Sufficient
water would be pumped to maintain an inward gradient, thus preventing
any contaminants from seeping out.
This aJternative would meet all of the remedial action goals.
Monitor~ng would still be required to ensure effectiveness of
remedy and to comply with the NPDES discharge permit from the
on-site treatment facility. Alternative 3A is estimated to cost
between $12.4 million and $25.1 million in present worth (cost
variation due to regrading and pond backfilling).
Alternative 38 -- Indiana Sanitary Landfill Cap, Slurry Wall and
Discharge of Ground Water to Marion POTW
This alternative contains all the same technical considerations as
described for alternative 3A except that the Marion Publicly
Owned Treatment Works (POTW) would provide the treatment and
discharge under their NPDES permit. Alternative 38 is estimated
to cost between $11.8 million and $24.5 million in present worth
(variation in cost due to regrading and pond backfilling).
Alternative 4A -- Multi-layer (RCRA) Cap, Slurry Wall and On-Site
Ground Water Treatment
Alternative 4A combines the RCRA cap discussed in alternative 2
with groundwater treatment. This alternative would meet the
remedial action goals to the maximum extent practicable. The
RCRA cap reduces the amount of ground water requiring treatment.
The water which passes through the slurry wall or enters the pond
from rainfall (if the pond is left open) would require treatment.
The on-site treatment system would consist of carbon adsorbtion
and air stripping. The cost for implementation of this alternative
ranges from $16.7 million to $30.9 million in present worth (cost
variations due to regrading and pond backfilling).
Alternative 48 -- Multi-laber (RCRA) Cap, Slurry Wall and Discharge
of Groundwater to Marlon P TW
Alternative 48 is similar to 4A except that the ground water would
be treated at the Marion sewage treatment plant. This alternative
meets the remedial action goals and costs between $16.1 million and
$30.2 million in present worth (cost variation due to regrading
and pond backfilling).
, .
.:.~:..:~. ~~ ~. "~'.. ~~'l ::! -:..:.i::';~.~,~"!:..<,j:-.....~5.~;~":.~ii..~f'.'::':"\.::' .;ji~~ :':'~~::'::.4:;,3:.~:~~"".; :~.'.:~;~;;-; y~. .:~:.;' :;,;,:=£:::,,~~;..:.-.~;. ..:;_::~ ~:~::i: :::2-: ':"".,:.- ;';';;;; ~ ~:;1-i ":"';f.-: ''''~:';'.;'':".;' ~ 4.-~:".;;:; ...,.(\. ,:-:,":...;,.,..; .....;..':::. ~.'~ :~,.; ,.;~: -~ ::.:~ ......~:'''.:'~..:.~.:.....~~.:. ~ "::..i:' .~';-;::u.~. ..
-------
- 13 -
Alternative 5 -- No Action
-.---
The No Action Alternative is required by the National Contingency
Plan. I~,~provides a baseline for comparison of other alternatives.
Evaluation Criteria
c.
f Table 5 presents a brief qualitative summary of how the alternatives
were evaluated against the human health and environmental goals
expressed in Section 121 of the SARA amendments. The costs presented
in this table presume the site will be regraded. This reduces the'
presentation of costs. Appendix 2 contains the cost summary for all
24 subalternatives.
Evaluation Summary
Capping alternatives 1 and 2 provide protection of public health
and the environment from the risks associated with the surface
soils and leachate seeps. Both alternatives reduce infiltration
and therefore the leachate generated; both will prevent contaminated
surface soil from discharging to surface waters or off-site, and
both caps meet the techni ca1 specifi cat ions 'for landfill closure
requirements which may be relevant and/or appropriate. Neither
alternative. however. addresses the groundwater pathway in terms
of direct human consumption or discharge to surface waters.
Therefore. both alternatives rely on monitoring to ensure that
the levels released are not above action levels. If action
levels are exceeded. groundwater pump and treat or other active
protective actions will be required.
Alternatives 3A. 3B. 4A and 4B address capping requirements and
the groundwater pathway (with the option of pond open or backfilled).
To the maximum extent practicable. all these alternatives address
elimination of potential pathways of concern. The slurry wall
eliminates off-site migration of ground water and reduces the amount
of water requiring treatment. However. some waste must b~ left on
the outside of the slurry wall in order to support the wall. The
RCRA cap further reduces the' amount of ground 'water to be treated.
but maintenance requirements. especially repair work may be expensive.
Both the on-site and off-site groundwater treatment system are
technically feasible. The off-site treatment system would be more
reliable since the operation and maintenance is already done by the
city POTW. Further characterization may be required to determine
if the ground water pumped from the Marion/Bragg site can be accepted
at the Marion POTW.
-------
AIt8matin
1) SanitllY lIndfill ClIp
pond open
pond dosed
2) RCRA ClIp
pond open
pond closed
3A) Sanitlly ClIp 81d GnanI-
waler TreaImI!nI on-sile
pond open
pond dosed
38) SanitIlY CIP 81d
Ground-water ExtrlCtioo.
treatment at POTW
pond open
pond dosed
4A) RCRA ClIp 81d Grcud-
WIler TrutmenI on-sile
pond open
pond dosed
48) RCRA ClIp 8l1li
Grcud-WII8I ExtrlCtion.
treatnnt at POTW
pond open
pond dosed
51 No Action
5.8
13.4
10.0
19.1
10.9
18.6
10.1
18.4
15.2
24.3
15.0
24.1
Cost
lin Minions)
C.,. D&M. pw.
No
TABLE 5 - Matrix Evaluation of Alternatives
1.0
1.1
1.2
1.2
1.4
1.2
1.0
.8
1.5
1.3
1.0
.8
Cost
°Capit81 costs/Operation 8. maintenance/Present worth
Effectiveness
Pulllic Health
Protectiveness
6.8
14.5
Prevents direct conllct
threat from surface soils.
but does not eliminate
threat from glOund water or
from on-site pond IiI open).
11.2
20.3
Prevents direci contact
threat from surface so~s.
but does not eliminate
Ihreal from ground waler or
from on.site pond IiI openl.
12.4
19.8
Extraction and Ireatmenl 01
ground water would signili.
canlly reduce potential risks
11.8
19.2
Exlraclion and oil-site Ireat-
ment 01 ground water
would signilicantly reduce
pOlential risks.
16.1
25.6
Extradilll ... Ireatmen! of
ground water would signifi-
canlly reduce potenlial risks.
16.1
249
Extraclion and ofl-site Ireat-
menl 01 ground waler
would signilicantly reduce
potential IIsks.
POlenlial heallh risks asso-
cialed with conlacl with
conlaminaled soils. surlace
waler and glOund waler will
remain.
Environmenlll
Protectiveness
Would ~mit. but nol prevent
conlacl 01 ground water
with landlill conlents and
subsequenl discharge 10 lhe
Mississinewa River.
Would limit. but not prevent
conlacl 01 ground water
wilh landlill contenls and
subsequenl discharge 10 lhe
Mississinewa River.
Minimal elleels during con-
slruction.
Minimal elleels during con-
struclion.
Minimal eflects during con-
slruction.
Minimal elleels during con-
struclion.
Contaminants spread 10
Mississinewa' Rive..
Implementability .. .
Technicel
Fe.sibility
Will signilicantly reduce inlillration.
but Iong.term monitoring wiD be
required. One conslruction season
needed lor implemenlalion.
Maintenance requirements 01 lhe
tIP, especialy repair 01 the ~rme-
able membrane. are substanlial
because 01 tikely IandliU dillerencial
selliing. Wdl signilicanlly reduce
infiltration. but long-term monitoring
wiD be required. One construction
season needed lor Implementalion.
Campatabilily lesting 01 bentonite
with waste prior to construction
needed. One construction season
needed lor implementation.
Compatability tesling on bentonile
wilh waste prior 10 consluclion
needed. One construction season
needed lor impIementalion.
Maintenance requirements 01 the
cap, especialy repair 01 impermeablt
membrane, are substantial because
01 ~kely landlil dillerential selliing.
One construction season needed lor
implemenlation.
MaiIIenance recPremenls of the CIII,
especially repair 01 iT1Jerme-aI*
membrane, and subslillllial becaJse 01
likely inti. dillerenlial senli1g. Com-
patalOly testing 01 bentonite with
waste prior 10 construction needed.
One construclion season needed 'or
in1Jlementalllul.
None.
AdllliniltrlliYl
feasibility
long-term enforcement 01
site access and deed reslric-
tions uncertain.
"
If'
long-Ierm enlorcement 01
sile access and deed reslric-
tions uncertain.
NPDES permit ling may sig-
nilicantly delay the con-
strudion.
POTW acceptance 01 the
discharge must be IPproved
by Indiana Ollice 01 Water
Managemenl.
NPOES permitting may sig-
nilicantly detay construction.
POTW 8CC8PtllRC8 01 the
disch.ge must be approved
by Indiana Ollice 01 Waler
Management.
NOI Applicable
-------
- 14 -
D.
Rationale for Selection of an Interim Remedy
The ground water beneath this facility is contaminated with a low level
of various organic and inorganic constituents. Given that hazardous
wastes were mixedi or co-disposed with other trash, and that so~e volume
of this trash is perennially saturated, the contaminant levels found during
the~I are likely to continue for a long time. .
The general response objectives require that hu~an health and the
environment (in this case, surface waters) be protected from existing and
potential future contamination. In protecting human health from exposure
to ground water, two options are available; use institutional controls
to prevent exposure, or pump and treat the aquifer. For surface water
protection there are also two options available; establish as Alternate
Concentration LiMit (ACL), which essentially says that existing levels
are protective, or pu~p and treat the aquifer in order to protect the
river.
SARA specifically addresses Superfund sites which are adjacent to surface
water bodies. ~ 121 (d)(2)(B) discusses the use of water quality criteria
and releases to surface waters. In some circumstances, it is acceptable
to establish an ACL or alternate contaminant level for releases to surface
waters. There are two restrictions on use of this provision. There can
be no statistically significant increase of constituents from the ground
water in such surface water at the point of entry or any point where
there is reason to believe accumulation of constituents may occur down-
stream; and the remedial action includes enforceable measures that will
preclude human exposure to the contaminated ground water at any point
between the facility boundary and all known or projected points of entry
of such ground water into surface water.
The FS examined possible action levels based on protectiveness of the
river at the 07/10. This is a very protective approach since the 07/10
does not occur frequently. Based on this approach, the inorganics
and ammonia have the potential to impact the surface water at the low flow.
The on-site ground water levels were above levels allowed by the NPDES
model, yet these were not significant in the river samples (exce~t for two
ammonia data points).
A ground water remedy at the Marion/Bragg landfill should be carefully
considered. If ground water treatment is required to protect human health
or the environment, the resulting slurry wall and treatment scenario
would last in perpetuity. On the other hand, the sensitive water quality
criteria for inorganics, especially arsenic, and the presence of ammonia,
suggest that a potential threat to aquatic resources does exist. In
order to be conservative in selecting a ground water remedy to ensure
protectiveness, additional ground water studies are recommended. These
studies will focus on the general toxicity, if present, of this ground
water on the surface waters or to humans through fish ingestion.
-------
- 15 -
The ground water treatment alternatives 3A, 3B, 4A and 4B are being
deferred at this time. When the final ground water remedy is selected,
u. S. EPA will either select an appropriate ACL or action level and allow
ground water discharge to continue, or select a ground water treatment
alternative already investigated in the FS. This approach assumes a land
use restricti~~ is enforceable.
Enforceable institutional controls play an important role in selecting the
final ground water action and determining the fat~ of the on-site pond, which
is also a point of surface water exposure. CERCLA itself does not give'
that type of enforcement authority, yet requires enforceable land use
restrictions to prevent human exposure as an element of the ground water
option if releases continue. The State of Indiana lacks legal authority
to bar uses of property for such activities as well drilling and excavation,
that might interfere with the capping of the site. The Region will attempt
to negotiate a voluntary restrictive covenant with the property owner, and
expects that the PRPs will assist in these negotiations. The operable
unit for the on-site pond will also be deferred until the ground water
remedy is selected since the two operable units are related.
Alternatives 1 and 2, capping alternatives, remain for consideration for
this operable unit. In comparing the two capping alternatives with
respect to the evaluation criteria and the site-specific technical aspects~
alternative 1, the sanitary landfill cap, was selected. This rationale is
further documented in Section VI of this Record of Decision.
v. Recommended Alternative
u.S. EPAls recommended alternative is alternative 1. (Figure 5) The
major components of the alternative are: access restrictions, residential
well replacement, flood protection, clay-type cap, installation of ground
water monitoring wells and additional study of the surface waters. The
alternative includes regrading of the site, but defers action on the
on-site pond. The capital cost is $5.7 million, the present worth of
operation and maintenance is $1.0 million and total present worth is $6.8
million.
o
Access Restriction
The access restriction includes a fence to prevent site use.
preserves the integrity of the cap and prevents recreational
the on-site pond. Access to the site would be controlled by
completing the fencing around the site perimeter and posting
This component of the remedy will cost $54,000.
Residential Well Replacement
This
use of
signs.
o
u.s. EPA seeks to secure a voluntary deed restriction to prohibit
use of groundwater or installation of shallow wells on-site. As
a protectiveness measure and in anticipation of an enforceable
deed restriction, three existing shallow wells within the site
boundary will be replaced with deep wells. The existing wells will
be sealed. One well, however, maybe left open for monitoring
purposes. This component of the remedy will cost $8 000
. , .
____0" -------...- ._-'--~'--''''--
----_.~-- ---~--~-_.. -----.-.~-----_._---"._- ---.- .-. _.-~-_.---_.
-------
- 16 -
o
Flood Protection
o
To protect beneficial use of the floodplain, yet a1l~w construction
within the floodplain and prevent inundation of the site, flood
protectioD~wi1l be required over the clay cap. For the purposes of
cost estimation, it was anticipated that a levee would be required.
This will protect the site from a 100 year flood event. The FS
estimated that a levee would be approximately 2,800 feet long and
be constructed of compacted soil. The cost for this component of
the remedy is $385,000.
Sanitary Landfill Cover (clay cap)
This cap includes two feet of clayey soil (10-6 cm/sec.
permeability minimum) and six inches of topsoil.
Contaminated leachate seeps and sediments would be removed and/or
covered under the clay cap in the course of regrading the surface.
Waste, which is currently uncovered or protruding from the surface,
would also be covered in the course of regrading. A minimum working
face will be maintained during surface regrading in order to minimize,
the potential airborne release of contaminants. All work will be
performed in a "good housekeepi ng" manner. Any d rums or other
hazardous wastes, if present, would be removed, analyzed and disposed
according to RCRA requirements. If regrading fails to eliminate
the seeps, then seep collection would be required. Disposal of
seep leachate would be based upon its chemical characteristics.
Eight additional monitoring wells are recommended. These would be
placed as close to the landfill edge as possible. These wells would
best represent ground water quality as it enters the surface water.
The cap will be covered with six inches of topsoil and seeded to
control erosion and promote evapotranspiration. This component
of the remedy, including grading and site construction, will cost
approximately $3,075,000.
o
Monitori n9
Contaminant migration would be assessed through a regular
groundwater and surface water monitoring program.
Priority pollutant analysis will be conducted on a semi-
annual basis. Parameters at various locations requiring
confirmation will be resampled on the alternate quarter.
Selected indicator parameters will be included in the
analyses every quarter. It is estimated that 10 groundwater
wells, 3 on-site pond locations and 5 river locations will
be included in the quarterly analyses. The existing leachate
wells and the off-site pond will also be sampled occasionally.
Should the ground water results remain relatively consistent
over time, monitoring may not need to be as extensive.
-------
- 17 -
o Deter~ine the effectiveness of the clay cap
The key element of this interim remedy is to determine its
effectiveness before implementing other remedial actions.
The monitoring data gathered before and after installation
of the clay cap will be evaluated to determine the effectiveness
~t this interim remedy. Design and construction of the cap
may require 1 1/2 to 2 years. It will take approximately 2.2
years for the aquifer beneath the site to move from the south
through the north to the Mississinewa River. Groundwater.
samples taken during and after that period should demonstrate
the effectiveness of reduced infiltration on leachate
generation and subsequent groundwater contamination.
o Additional Studies
The additional studies will include fish bioassay work for the
on-site and off-site ponds and the river. Indicator parameters
will be selected from the volatiles, PAHs and inorganic
constituents. In addition, general toxicity tests will be
performed on the river to determine if ammonia or other
constituents in the ground water cause a toxic effect on
the aquatic environment. These general tests may be
modeled after the toxicity tests that NPDES dischargers
are subject to, or employ other approaches as may deemed
appropriate by U.S. EPA.
VI. Statutory Determinations
SARA 9121 requires that the comparison of alternatives take into
account the following factors:
(1)
(2)
(3 )
(4 )
(5)
(6)
(7)
long-term uncertainties of land disposal;
the goals and objectives of the Solid Waste Disposal Act
(RCRA) ;
the persistence, toxicity, mobility and propensity to bio-
accumulate hazardous substances;
short- and long-term potential for adverse human health
effect s;
long-term maintenance costs;
the potential for future remedial action costs if the
chosen remedy were to fail; and
the potential threat to human health and the environment
associated with excavation, transportation, redisposal, or
containment.
SARA further requires that the selected remedy be protective of
human health and the environment, attain applicable or relevant and
appropriate standards, use treatment technologies to the maximum
extent practicable, and be cost-effective.
The Feasibility Study considered all these factors during screening
of alternatives and recommendation of a final remedy. Appendix 3
contains the applicable or relevant and appropriate requirements for
this site. .
- - _.-~--- --..- -' - . - ..--- --- --- -.------ --- . ---.- - ---- - ._.-.---.- .-- .
-------
- 18 -
This section describes how the selected remedy will cOMply with the
statutory requirements in SARA ~121. generally referred to as the
cleanup standards.
A.
Consiste~c~ With Other Laws (Compliance with ARARs)
SARA requires that remedial actions meet legally applicable or
relevant and appropriate requirements of other environmental laws.
These laws may include: the Toxic Substances Control Act. the Safe
Drinking Water Act. the Clean Air Act. the Clean Water Act. the
Solid Waste Disposal Act (RCRA). and any state law which has
stricter requirements than the corresponding federal law.
A "legally applicable" requirement is one which would legally apply
to the response action if that action were not taken pursuant to
~104 or ~106 of CERCLA. A "relevant and appropriate" requirement
is one that. while not "applicable" is designed to apply to problems
sufficiently similar that their application is appropriate.
The following is a description of environmental laws which are legally.
applicable or relevant and appropriate to different components of
the remedy. and an explanation of how this remedial action meets
those requirements.
1.
Landfill Closure Requirements
Neither the sanitary landfill requirements of Subtitle D or the
RCRA Subtitle C requirements are directly applicable. This
landfill accepted some hazardous waste before the passage and
effective date of RCRA. but was not a hazardous waste landfill.
Therefore. the jurisdictional prerequistes are not met for
either subtitle. Both subtitles were designed to apply to
landfills. The Marion/Bragg landfill is a sufficiently
similar circumstance such that both laws are considered relevant.
The site was viewed in terms of the component parts for the total
site remedy. or operable units. Each component was tompared
to the requirements of both Subtitle C and Subtitle D which
were sufficiently similar. This interim remedy. and the
final remedy. will comply with the requirements which are
detenmined to be the most appropriate. For example. the
flood protection requirement complies with RCRA. CWA (and
other State of Indiana requirements which are not specifically
stated in the Subtitle D regulation). and the cap complies
with sanitary landfill requirements. The future ground water
remedy must also consider the appropriateness of RCRA corrective
actions, ground water protection requirements or other standards.
2. Soil/Capping Requirements
Alternatives 1 and 2 address capping requirements for the
Marion/Bragg landfill. Alternative 1 complies with the State
of Indiana Sanitary Landfill capping requirements. Alternative
2 complies with the RCRA capping requirements. Both caps are
protective and meet respective statutory requirements.
: ,:~;-::.;~:t..~.' ~~~ ~~ '~,., :;..::'::" . :;,~ ~',".~:';-:~"" ".' -:-..-~ '.' :::,:-: :.4 .~:: :.-~~ .~.~- :,' "4';"'. ~;'-': ,~,,:.,~' ~~~..;:.... .::;'~':~ '..~' :.; ¥:....~.: .' ,:to ~~.;'. ::: ~ -. =,~.~.. ~.'" ,~~. ~::,: .=~.:-.r';..:? '.-,;.-~ ~~ ",'. ~~\ ,..' -" .
..-.\.. ~.......-.. .
. ~ :... ... ~. .... \ ~-'.. . '.
~...: ., ~.. ":'" -. "
-------
- 19 -
The State of Indiana has jurisdiction for Subtitle D. sanitary
landfill operation and closure laws. This is covered by the
Solid Waste Management Board Regulation Title 329 lAC. This
regulation is currently under revision. This' regulation applies
to.those facilities which operated in accordance with the
stated requirements and did not accept hazardous waste. The
existing regulation is more general than the proposed regulation.
and relies on guidancp. and final appro~al of the permit
writer. The proposed regulation codifies previous requirements.
The existing and the proposed standards are technically
equivalent. The FS incorporated the greater level of technical
detail offered by the proposed standard. Not unlike the general
RCRA cap requirements. this cap seeks to minimize infiltration
by specifying clay type. and promote drainage by specifying
sloping and topsoil requirements. This also accommodates
subsidence and minimizes maintenance.
RCRA Subtitle C requirements for caps as proposed in alternative
2 can also be considered. The RCRA regulation is applicable to
those facilities which operated after promulgation of the
regulation in 1980 and/or were granted interim status to operate
in the manner provided by the regulation. This regulation'
requires that the cap minimize liquid migration, minimize
maintenance, promote drainage. accommodate subsidence and be
.less permeable than the bottom liner. Since waste from regrading
will be consolidated on-site. RCRA Land Ban Requirements will
not be triggered.
Distinguishing which regulation is most applicable. when both
are relevant, requires a review of site-specific technical
considerations. The Marion/Bragg Landfill has a portion of
the waste saturated within the upper aquifer. This water table
aquifer will fluctuate up and down within the waste as dictated
by seasonal hydrologic conditions. This fluctuation was noted
in the RI. Although it is clear that reducing infiltration will
reduce leachate generation, the low concentration of ground
water contamination may be more influenced by sea~onal fluctuations
in the water table/waste saturation interface. Therefore,
the zero infiltration provided by the RCRA cap will not
likely result in a commensurate reduction in existing ground
water concentrations. In addition, the nature of the codisposal
operations at the landfill, the very permeable nature of the
existing cap material and the fact that leaching has been occurring
for a very long time now, suggests to U. S. EPA that the
existing levels of ground water contamination are not likely
to significantly increase. Therefore, between the two caps, the
Subtitle 0 sanitary landfill capping requirements were
considered to be the most appropriate.
3.
Floodplain and Wetlands Protection
The State of Indiana regulation I.C. 13-2-22, Indiana Flood
Control Act, regulates construction in a floodplain. The
U.S. EPA also has a floodplains and wetlands policy which
-------
- 20 -
serves similar objectives, as does RCRA 40 CFR 270.14(b)(11)(iv).
Any construction which occurs in a floodplain must minimize
the loss of floodplain and provide floodproofing for anything
which must be constructed in that area. Appendix 4 shows the
flood~Jain area and levee which must be constructed around
the la';,dfill. The flood control levee will border the west,
north and one half of the eastern side of the landfill. This
is a perfonmance based goal. The FS evaluated a levee as the
best means of complying with requirements. Other technical means
of achieving the requirements may be available. The actual
design is subject to appoval from the U. S. Army Corps of
Engineers, U. S. Fish and, Wildlife Service, Indiana Department
of Natural Resources, in addition to U. S. EPA and IDEM.
B.
Use of Permanent Solutions, Alternative Treatment and/or Resource
Recovery Technologies (Reduction of Toxicity, Mobility or Volume)
Permanent solutions provided by treatment technologies were
considered for this landfill, but were screened out before detailed
analysis due to technical and cost considerations. This is detailed
in the FS.
Incineration of the entire landfill was considered. On-site
incineration was considered, even though it would require a waiver
from existing State of Indiana regulations. These regulations
prohibit the use of mobile or temporary incineration facilities
within the state. On-site incineration would require at least 25
years, require waste pretreatment and is not very amenable to the
high level of inorganics present in the landfill. The cost would
be approximately $404 million.
Existing RCRA permited off-site incineration facilities were
considered. Waste restrictions and/or pretreatment requirements
were a significant limitation. In addition, existing capacity
at these facilities limits their ability to dispose of the
1.1 million cubic yards of waste present at Marion/Bragg.
Assuming this was not a limitation, it would still take 100 years
to accomplish the objective, at a cost of approximately $3,439
million. (Costs were based on the use of SCA Incinerator.)
Given the numerous technical limitations, incineration as a means
of penmanently reducing toxicity and mobility was eliminated.
Significant volume reduction would not occur with incineration because
the resultant ash volume would be great. Capping in place does
provide some reduction in contaminant mobility, but not toxicity or
volume.
c.
Short-Term Effectiveness
Short-term effectiveness considers such things as risks posed to
the community during remedial action implementation, time required
to complete remedial action and the subsequent reduction in existing
risks. It is anticipated that remedial actions will require one
construction season to complete. During that time some wastes
----.---.--''',- ~._w._,.~..-.- "..,..-...-.. ~ ."
". .-, . '. '.-." -'.,' -. ,"0.,_" ,-. .
...-:-~.-.:n:-.- . .::'"".-:--:-~'---'-"---..~:;','-"-- --'-7:-':'--"':":--;:::-_"7""~.':'. .: '-."'."=,~- ... ~,----,~"-:,~,,,_...
- ...., 'w - . ...- -.' - .~. .
..., ~ - ~ .. ".
-------
- 21 -
will be exposed due to regrading of the surface. U. S. EPA proposes
to use "good housekeeping" procedures to minimize the airborne release
of contaminants and minimize the working face of the regrading operations.
The workers on-site will also have appropriate personal protection.
Once remedial action is complete, the remedial action goals stated
in section IV of this Record of Decision will be met.
,
,D.
Long-term Effectiveness and Permanence
It is clear from the screening of technologies in the FS, that this
landfill will need to be contained in place. The contents will
remain in-tact and therefore will require long term operation and
maintenance and periodic review of the effectiveness. SARA ~121(c)
requires that EPA review remedial actions where any hazardous
substances, pollutants, or contaminants remain at the site, no
less often than every five years after initiating the remedial
action. This review should assess whether the remedial action is
truly protective of human health and the environment and determine
whether any further action is necessary.
Since this is an interim remedy, the long-term effectiveness and
permanence ;s best evaluated when the ground water component is
resolved. However, one of the goals of this interim remedy is to
determine its effectiveness in reducing leachate generation. The
extensive monitoring data which will be provided over the next few
years will aid in the evaluation of the effectiveness and permanence
provided by any subsequently selected ground water action.
E.
Implementability
Capping a landfill with clay is a very conventional technology,
considered reliable in the long term and it does not require specialized
expertise. Design approvals will be required from several Federal and
State offices in order to ensure that technical requirements are met.
Once design is complete, construction is expected to take only one
construction season.
F.
Cost and Cost-effectiveness
The capital, operation and maintenance and total present worth costs
for alternatives 1 and 2 were considered. Should the ground water
require treatment, the reduction in infiltration provided by the
RCRA cap reduces the amount of ground water to be treated and
correspondingly reduces the O&M costs. However, this savings is
off-set by the possible higher costs involved in RCRA cap maintenance.
Therefore, there are no long-term savings provided by the RCRA cap
over the sanitary landfill cap. In fact, the total present worth
costs of 0 & M are slightly less for the clay cap than for the RCRA
cap.
_'+_4__---_--~'- -_.. --' ..--- _h-.._- _-0
-------
VII.
- 22 -
G.
Community Acceptance
This sit~ has not seen a significant amount of community involvement.
This is 'likely because few people are directly affected by the landfill.
Comments on the FS provided by the Potentially Responsible Parties.
(PRPs) suggest that the actions proposed by the Agency in this Record
of Dec i si on are reasonable, hut expensi ve. Instead of cappi ng unde.r
Subtitle D requirements, they suggest maintenance of the existing
cap material. In addition, they suggest that flood protection
can be provided more cheaply and as effectively by means other.
than a levee. This Record of Decision specifies a performance
based response to the flood protection goal. The PRPs can offer
alternative means of achieving the goal in the design phase.
The municipal officials are concerned about the possible cost of the
remedy and their potential liability. They do not feel the tax
payers would be amenable to paying for the remedy. These comments
are addressed in the responsiveness summary.
H.
State Acceptance
The Indiana Department of Environmental Management has been a party
to the RI/FS through their technical input, and concurs on the selected
interim remedy. IDEM also recognizes their cost share and 0 & M
responsibilities.
1.
Overall Protection of Human Health and the Environment
This remedy has been evaluated according to the criteria listed in
SARA ~121. This remedial action will eliminate a direct contact threat
associated with existing surface soils, leachate seeps and exposed
debris. It will also prevent the off-site migration of contaminated
surface soils to surface waters. Fencing the site to restrict
access will prevent use of the on-site pond on an interim basis.
Replacing the three existing shallow residential drinking water
wells will provide long-term protection against the potential
for any future contamination. Futhermore, this remedy will be
consistent with any final ground water actions.
Consistency with National Contingency Plan
The National Contingency Plan, 40 CFR Part 300.68(i)(1), states that the
appropriate extent of remedy shall be a cost-effective remedial alternative
that effectively mitigates and minimizes threats to and provides adequate
protection of public health and the environment. The selected remedy will
attain relevant and appropriate Federal and State public health and
environmental requirements that have been identified for the Marion/Bragg
site. Based upon the analysis of the options, State and Federal environmental
requirements, and comments received from the public and the State, the
recommended option has been determined to be consistent with Section 300.68.
: ,.--;~;~..,--~;.~". ':~'.~~":..::..-'':~:.;.:--:.-:;_4_.'''.- ~..""; .--.-" .-'-:-
.'~' .
... '- - ---. -
"".- :", ':'; -,:':::::i':'~-:~:---'~';-::--..-~-.:.~_:-;-~~, ~'.::-::-:, _4.::-:..., 4. .~' ...' "",.,,
. ~. .. .. . . '. ..'
-------
- 23 -
VIII.
Future Schedul e
'.
Good Faith proposal by PRPs to undertake
Remedial Action
October, 1987 .
Conclude all negotiations
December, 1987
Complete Remedial Design
Fall, 1987/Spring, 1988
Fall, 1988
Begin Remedial Design
Complete Remedial Action
Sum~er/Fall, 1989
Determine effectiveness
of interim remedy and select
final ground water remedy
Fall,19.91
It is possible that a final ground water remedial action can be selected
as soon as Spring, 1989. If the additional studies demonstrate that the
existing ground water does not adversely impact the surface waters, action
levels can be established which are protective of human health and the
environment.
-------
List of Appendicies
Appendix 1 --
Ap'pend ix 2 --
Appendix 3 --
Appendi x 4 --
Appendix 5 --
Appendix 6 --
Appendix 7 --
. ,
Enforcement Summary
(CONF WENT! AL)
Cost Summary for all alternatives
Applicable or Relevant and Appropriate Requirements for
the Marion/Bra9g Landfill
Floodplain and levee control area
Community Relations History and Responsiveness Summary
Administrative Record Index
State of Indiana Concurrence
-------
Appendix 1
-- Enforcement SUMmary
The Marion/Bragg Landfill site was proposed on the NPL on December 30,
1982. In March 1985 the REM II contractor was tasked to draft a work
plan for a Remedial Investigation/Feasibility Study. The draft work
plan was used as a basis for negotiating voluntary actions with an
identified g"rOup of potentially responsible parties. Notice letters
.were issued and a meeting was held on November 7, 1985 at the Region
~ office in order to provide them an opportunity to work cohesively
and respond to the Agency's offer. "
On Decembe~ 9, 1985 Enforcement and Regional Counsel determined that the
RI/FS should proceed as a program lead. Little or no interaction has
occurred with the PRPs since.
Special notice letters were issued at the completion of the RI/FS on
August 7, 1987. The negotiation moratorium commenced on August 12
and will be completed by October 11th, at which time the program will
proceed with RD if a good faith offer is not received.
-------
Appendix 2 -- Cost Summary for all alternatives
. ~
- ,
-------
..... .,..,. ""'1. _--".,
_IGl18b8 ,"flU 'III
._,... I ._"" . __"" .. __"" . ."-'1" .. ...-U... .. .""'"' .
,..- ....... ,...", - ..- 1M"'" ,...." ... _n.un' IMPI - _1I'~'" 18(1&1 -
__---IUW .fI.,." .-M' W aU8' .t. - ..,.11 ...., _t .. ...- . .-. ." ... ...... .... _t - ..~....
---- __'8'. - _I"'. "",-'1 .n...... "",,"1 10 -,..... _"I .eu...., _tli .. "\8'1'" ....
.................................... ................................... ................,.................. ........,........... ............... ... .... ............ ..................., .............,. ...................................
--- ... II. MI" ..... -.., ...,. .....
................
1.'_-"---
"""._--
-- .. f.-.- .. 11."'.- .... 1'.111.- .., "."'.. ..., II."'.. "., ".....
.,._- II 1..'.- .. I.'''.. II.' '.61... .., '."".. ..., '."'.- "., '..'.-
,.... ...-..... II I.".. .. ........ II.' "."'.- .., 11.IU.- ..., -.11'.- II' If.'It.-
I.' - -...- ......
'In ... ""'1I8dI"''''.
"""& . ..".- .. "."'.- ... D..'.- ... D.".- ..., "..'.- II" "."..
.....-"" . 1.-.- .. '."'.. II.' '.81.- .. .r.- ..., -.1&,.- II' .,.-
..... ............ . ...m.. .. It.....- .... 8.'61.- ... "."'.- .... .."".- II' ..0'.-
I.' - -.. of. --
_'II'" '"' ... ......
---
..". .. '."'.- .. ..11'.- .... -."1.- ... ..".- .... It.",.- II' "."'.-
.,._- .. 1..,.- .. '.'..- .... 1..".- .. -."".- .... 1.'''.- II' 1..',-
.-.. ........ .. 1.111.- .. U.'".- II' 11."',- ..J 11.111,- II" ".N.- ".J M.II'.-
; 1.'_-"---
t .11"" '"' ... ... .....U..
18". . 11."'.- .. lI.ql.- ..-, -.tI-.- .-, "."'.. 11-' -.AI.- .'.. ".'M.-
.,._- . 1._.- . -."'.- II.' -.MI.'" .., "'.- II.' -..'.- II.' .'.-
..... ......... . 11."'.- . ..W.- ..., "..'.- .. ...Nt.- II.' 11."".- ..., "."'..
-------
Appendix 3 -- Applicable or Relevant and Appropriate Requirements for
the Marion/Bragg Landfill
. -
-------
.
.
.
IEGULATlOt', fIOLIC'f OR LAW
..............................
FEDEIlAL
I..aurce CCN8N8tian end
lecovery (RCIA) a.tItlUe C
40 CFR 264."6
'0 CFR 2610."
2610. , '7(b)
4D CFR 264.31D(b)(5)
40 eFI 264.90 JDD8(h)
SQ04(u)
CCMPlIANCE WITH APPLICABLE OR RELEvANT AND APPROPRIATE IEQUIREMENTS
MAlION/IRAGG lANDFIll SITE
-
APPL 1 CAlI L I TY
............................
elO8Ure of llUardaul Waste
Fecitltl..
Deed I..triction
Acc..s Restriction
Monitoring Surface
Run.Off (Final Cover)
Cont_irwtlon Levels,
~Itorlng, Treatment
RESPONSE
....... .... ...................
This alternative ...ts RCIA
C81'Ping r~ir_ts.
This alternative ...ts ICIA
closure requirements.
State of Indiana
has jurisdiction.
Meets RCIIA requirements
if i~l.."ttd.
Surface ~ter'8In8Veaent
ayst- IIIOUld cGllPly Mitt! ICIA
r~ir_tl.
Action levets in on..fte pond,
.r~ter and Mississinewa
river Mill be let by U.S. EPA.
f
.
AL TERMATIVES
2
38
4A
4B 5
3A
. . . . . . . . . . . . . . . ,- . . . . . . . . . . . . . . .
x X X
X X
X X X X X X
X X X X X X
X X X X X X
X
X
-------
CCMPLIAMCE WITH APPLICABLE 01 RELEVANT AND APPROPRIATE IEQUIREMENTS
MARIOM/8RAGG LAMDFILL SITE
f
I
~ ~TERNATIVES
. . ~
IEGULATI&.. 'OLI CY OR LAW APPLIWILITY IE SPOIl SE 2 3A 38 4A 48 5
.............................. ............................ ..............~............... ................................
40 CFR Z6'.,10 ICIA Lendffll Cowr Syst- fhil Ilternati~ ...ts leRA X X X
C8;1Pin; ~ir..,ta.
filii Il tem8ti~)lleu KIA X X
Closure requirl8lftts.
I.D CFR 270.14 Slurry wall Slurry wall wi II be located X X X x
betlind thl flood control lev".
1.0 CF' 264.340(c) Treetment/lncinerat;on lone of the Ilternatives Involve
treatment or incineretion of
landfill contents.
40 cn 262' 263 Groundwater Storl;e None of the Iltem8tl~s involv.
the stor.;e end surface trans-
portltion of cont_inetld
~ter.
1.0 cn 26' .4('1)(2) Groundwlter Dflchlrge Dflchlrp of grcua.tlr to x x
.flliss;newe Ifver wauld
comply with CWA, Section '02.
40 CFR 264."4 Decont88inetfon of E~;pnlltlt EquilZll"t decont..ination x x X X Ie X
proc..,r" wi II be followed
uin; conetruction.
Clean Air Act (CAA) Incinerltion/Trelt8lnt lone of the Ilternatives involve
fncinerltlon or tr88t81'1t of
hUI"" 101 l.
Cl.an Wlter Act (CWA) Regullt.. DiSchlrge of Stlte of Indiana his jurisdic: X X
Wlter Into Ifvers tion over 'lluanc:e of lPOES
. peraitl (See Itlte AIAIS).
-------
CQMPLIAMCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
MARION/8RAGG LANDFILL SITE. f
,
,
.
,
At. TERUTI VES
IEGULATlcil, ~LICY CIIt LAW
APPLICABILITY
USPdMSE
2
3A
3B
loA
48 5
..--..........................
............................
..............................
.. .... ....... .... .......... ....
STATE OF INDIANA
................
Irdi81'18 Dept. of Envi rCll"G8fttal
M8n89.-ent (IDEM)
..
.
..............................
i
Irdi8"a Hazardous Wa.te
Man898II8"t Program (1"",,"P) -
320 lAC-4
Regulate. Closure of £Ai.tint Thi, alternative I, in compli-
Hazardoul Wa.te Facilities enee with IHWKP.
x .
x
x
Irdiane Wa.te Treatment Facll.
ities Regulation (IWTFR)
330 IAC-3.'
Authorize. and Regulet.. Wlate Thl. alter"lntlve provides for
Traatment Facllltle. an on.site treatment facility
and c~lI.. with IlnFR.
x
x
Industrial Waste Water l.;ullt.. Disdlarv" to State Thl. Ilternative will r~ire X X
Pretreatment ard "PeES Program W8ters IIPOES an IIPOES perlli t.
33D IAC.50- 1D)
Pretreat8lftt Standard. Regulat.. Di.dlarge to POTW TIIII II t......tl". includes X X
330 IAC-S",-,S) dfadllrge of ""t.lnated
Ir~ter to Marion POTW.
Irdiena Water Quellty Stardarda Establish.. Water Quality Thl. alternative la I\bject to X X X X
Str.. Pollution Control Board Standards for the State c~l!ance with Irdlana Water
330 lAC '&2(b) . QUllity Standardl.
Title 329 (P,.~ed)
Solid Waite Mana;8D8nt
329 lAC 2.8.(4,7)
2.9.(2,3)
loa,.d
Regulltes Solid Walta Landfill TIll. Ilternati". will ~ly
Closu,.. triCh pI.* _lid 188te
,...,.lltiona.
X
X
x
Dept. of .atur81 I..ou,.e..
Diyi.ion of Wlter
...........................
Inc"-
Fload Control Act
I.C.13.2.22
18I\Illt.. eonatNCtlon In I
fload pilin
'nil. Ilt81"N1tlve i. subject to
CQ8Pllance with DNI Dlvi,lon
of W8ter ,.~!r.-ntl.
x
x
x
X
X
x
LOCAL
City of M8rlon ""'Ielpel Code
Drd. 8.1981
legul8tes dlsdl8,.;e to
IUIlelpel ....,. ..,.t8.
Thl' l&t8rnetlve I. IUbject to
the r~!r~tI of the Ma,.ion '
....r use code.
x
x
-------
Appendix 4 -- Floodplain and Levee Control Area
-
-------
Legend
~)
:::-7.-:::.=~ --:.: . :. . .;
/~'~~~.~' =':''''::, C,I
-- '\.........., . .:.... I,
. - - -- -.. ----- ,.:;
::::::::::::~'~'''~'''' . \ ~ ~::~ ~ 0
.:::.::,.:.:::'..:.;.:.:<:::::::., ". , -........ ~~
[[i@M;!i~\i(Mi.f::..'.':..'i'L.':.~ ~ '~~~,/;~,'t
. ..."""..., ".'" ~ \ .)
~:o.~~-.~ l~ ~~ . . JI (}." ~ . ", "..'. ' '...' '''.'.' "..J ..
. t J, '. .,. "'1':1 . ,. "\ :l:;/:::.:-:":'~'::':';;'.':'::'::::;':"::::::::::::;,:: ,:.::.
\, *\"~""~\'~'1/' ", ~ (~l 'Jr' ' " >{f{}\}\}(\X!.~):!f};(kMiW
" . "':' \. \ ,}"~' ~-, '; I, ':',~.t.'"::::~:,..:.:\;~:.{>:..::.;,(.:::t,:})~~~..:,, '"
',l'- \; i I ~ ,-'\'.tn?'1"':::':
:'" ...:"...,--t. '1- "~ II "'.:'::::,:'
'. '. . J
. " " I
',.
.
:,\
. II
(\: ,',' r
I .
"
,\~----. ".
, '......
~.-.
.
,4' "
II
&J'. ,
l\~
,
~
,
"
"."
-::::..:...-=--
Site Boundary
Inc.
-
WM
Harton Paving Co..
Inc.
~~:~:~:~:~:;
Dobson Construction Co..
-
Private Residence
I'
..)(-- Site Fence
..... Flood Protection Levee
::::-:::
100 Year
,\ f ',,- ,-, ,.,
v,:., ~--- ''i;'-'
;", '.. . . :!I. \.
.. ~ . , .\ ,~,
, . J:--.. ~,,(' ..
. ~ .
6 r\. '\,.
=:~~(t:,
~Q~ " J.J '
~o .,
b
~.=:,; \ n
.0 ~" ,"'
.""
,,'
-
'~
.~
"
I,
;': I
\,~
,I
;1
q
"
a..... ."
(
'I
..,
Access Restrictions. 100 Yeer Flood Plain. Flo~~ Protection Levp.e
All Alternatives Except No Action
,
o
.
~
'I
\,
\\
"
"
"
"
\'
\'
''.
"
. I
.. .
.
MH'
Sc8Ie In Feet
250
.
500
"(f.
8.
'f> r [~f1 L\ '
. ""f -.....
"
..
"
(7;:.:
. ,~
o ~'..
-<-"\
,/ -....-
-------
Appendix -- 5 Community Relations History and Responsiveness Summary
. ~
- ,
-------
Section
Section
Section
Section
f
I.
I I .
II I.
Marion/Bragg Landfill
Responsiveness Summary
I.
Overview
II.
II I.
Background on Community Involvement and Concerns
Sum~ary of Major Comments Received during the Public
CQrnffient Period and EPA Responses to the Comments
IV.
Remaining Concerns
Overview
The United States Environmental Protection Agency (U.S. EPA) presented a
preferred alternative in the feasibility study. This was available
at the beginning of the five and one half week public comment period.
Only the Potentially Responsible Parties submitted comments. Judging
from the comments received, the PRPs support the remedial action
goals, but suggest that the risks posed by the site do not warrent
the cost of response presented in the FS. These comments are addressed
in Section III.
Background on Community Involvement and Concerns
Very little interaction has occured with the community of Marion.
Most of the people who attended the RI/FS kick-off meeting were those
homeowners living adjacent to the existing landfill. These people wanted
U. S. EPA to close this facility. They were also concerned about
acceptable levels of arsenic (detected in their wells). The citizens
were advised of the MCL and advised to submit any analytical data to
the State. They were also advised that the State has authority for
sanitary landfills. not U. S. EPA. This landfill is now closed and this
group of citizens did not attend the FS pUblic meeting.
The municipal officials are concerned about the possible cost of the
remedy and their potential liability. They don't feel the taxpayers
would be amenable to paying for the remedy. These comments are
addressed in the responsiveness summary.
Summary of Major Comments Received during the Public Comment Period
. Comments were received from the following parties:
1)
Mr. J.B. Smith of Beckman. Kelly and Smith on behalf of Mr. Delmar
Bragg;
2)
Mr. Spitzer of Browne, Spiter, Herriman, Browne. Stephenson & Holderead
on behalf of General Plastics Corporation;
3)
Mr. Browne of Browne, Spiter. Herriman, Browne, Stephenson & Holderead
on behalf.of the City of Marion and the Marion Utility Services Board;
Mr. Cromer of Mishkin, Cromer, Eaglesfield & Maher P.A. on behalf
of RCA Corporation; and.
4)
-------
- 2 -
5)
Mr. Hanson of Beveridge & Diamond. P.C. on behalf of the Steering
Committee. This Steering Committee is comprised of the following
fi rms :
5.
6.
7.
1. ~~ana Corporation
2. General Electric Corporation
3. General Motors Corporation
4. Central Waste Systems. Waste
North America. Inc.
RCA Corporat ion
Owens-Illinois. Inc.
American National Can Company
Management Corporation of
There were three types of comments submitted; technical. legal
and party specific. Comments from parties 2. 3 and 4 listed
above incorporate by reference. comments submitted by Mr. Hanson.
These comments will be categorized by relevant topic. The comments
had to be paraphrased in order to fit them into the summary. The
reader is referred to the actual reports and comments available
at the pUblic repository (Marion Public Library).
Technical
A.
ERM. acting as technical consultant to Mr. Hanson and the Steering
Committee. submitted a report divided into 6 Sections; each
addressing a specific portion of the RIfFS. U.S. EPA will respond
by section as well.
Section 1 - Introduction
This is an executive summary of all comments contained in Sections
2 through 5.
U.S. EPA Response: These comments will be addressed by general
topic in the subsequent sections.
Section 2 - Remedial Investigation - Hydrogeology
Comment 1. The geophysical information was referenced in the RI.
but data and results are not contained within the report.
EPA Response: The EPA contractor, Roy F. Weston. through the
REM II contract, was not tasked to complete the geophysical work.
The geophysical work was completed by the Agency (in-house). The
contractor was present to aid in data interpretation and to
ensure project continuity. The geophysical data and interpretation
report was available at the public repository at the time of
public conment.
Comment 2. Minor errors were made in developing contour maps showing
the groundwater surface, particularly at MW-12 and FIT-3.
~PAM:e~~ons~: The contour lines were not in error. The head differences
1n - an FIT-3 are due to an upward vertical gradient from the
ground water discharge to the river (similarly at MW-4 and MW-5).
I "'-:--'--::,..:-:':'-:~:-;-:-:-:.-:-;:::~.~-::.. ...
-. . - --_. ----~..~ -.---..-.--"--. -'~-'.".'-' ----'0: - -_...~.
. . .. "'. . '" .-~ . "-' - ' - -. . . . '.
._--....,-..~--..._. - '., --.....-
-------
- 3 -
This is common near major rivers and supports the assessment that
the river is a hydraulic barrier. See RI p.2-27, 2nd paragraph.
Section 3 - Remedial Investigation - Quality Assurance/Quality Control
Comment-l. The organizat i on charts presented in the QAPP (pages 3-2
and 3-3) give names of individuals responsible for QA reviews, .
yet no reviews were present in the RI/FS.
EPA Response: The flow charts presented are not site-specific, but
refer to the entire National Superfund program under REM II,
beginning with the Hazardous Site Control Division in Headquarters
(Fig. 3-1 REM II Organizational Charts) to the Camp, Dresser &
McKee (CDM) Regional represent;ve of Quality Assurance (Fig. 3-2
REM QA Organization). Under the REM II contract, there are
rigorous QA requirements. The procedures and actual requirements
are documented in the contract itself and the established Standard
Operating Procedures (SOPs). The QAPP documents how this site fits
into the QA/QC responsibilities under the REM II contract.
On a site specific basis, the project tasks must include a line.
item for project QA (See the Work Plan). Each deliverable, includi~g
the QAPP has an organizational sign-off sheet which shows the
individuals who have reviewed the deliverable to ensure it meets
all requirements, thus demonstrating the QA system meets its.
intended purpose.
Comment 2. No report on the data quality was presented in the RI
report (reference to Figure 9-1 of the QAPP).
EPA Response: This figure refers to the data flow at CRL. The
REM II contractor is not responsible for analysis of samples or
data validation. Analysis is handled through the CRL and CLP
systems under a different contract, and the data review is done
by EPA. The labs are responsible for data QA in accordance with
the CLP contact, SOPs and other guidance. The QC review is done
in-house on every data package. A summary page of co~ents is
prepared by the EPA data reviewer concerning the use, and
qualifications for use, of the data. These qualifiers are present
on the data in the RI. . No data quality report is prepared or
required because it is specific to the data package itself.
These reviews are available with the raw data package. Since the
raw data is massive, it is made available by request only.
Comment 3. CRL Lab audit reports do not appear in the RI.
EPA Res~onse: They do not belong in a site-specific RI. These are
not per ormed by the contractors, but by U.S. EPA. They serve to
ensure that each lab meets the performance standards established
by U.S. EPA under the CLP system. In doing so, quality data is
ensured for each site. The QAPP describes where audit freqency,
responsibilities and SOP references are located. Audit results
of a specific lab can be made available upon request.
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- 4 -
Comment 4.
Data review procedures are not documented (QAPP Section 13).
EPA Response: Data review procedures follow specific EPA guidance.
Slte-speclflc documentation is not required. A li~t of all relevant
EPA gui~ance was provided at the repository. .
. ,
CommentS. Corrective action requirements are not documented in the
RI (QAPP Section 14). . .
f
EPA Response: Laboratories which have sample specific problems
are required to call the specified Region V EPA data reviewer.
This chemist will advise on corrective action procedures. The.
corrective action resolution is documented by the lab on the'
the individual data package.
Comment 6.
No QA/QC section is provided in the RI (QAPP Section 15).
EPA Res~onse: Subsequent to QAPP approval. it was determined
that thlS task was unnecessary for the following reasons: 1) Data
review is an Agency function; the contractor is merely the recepient
of the qualified data and has no direct review authorities; 2) To
be interpreted correctly. the data packages must be viewed individu~lly.
A summary may generalize the data and cause confusion in interpretation
or use; 3) Such a summary would be a duplication of the Agency's work.
Comment 7. Appendix A. page 2 is unacceptable
Comment 8. One half hour is insufficient data review time
Comment 9. The cyanide data presented in Appendix A may have QA/QC
problems associated with it which may invalidate the basis for
scoring the site.
EPA Response: In reviewing the QAPP from the commentor's
perspective. it is now clear why Appendix A of the QAPP would
lead to the above questions. Appendix A should have been more
clearly labeled. It is the raw data package summary for the HRS
scoring of the site. The Region V QA office always requests a
summary of existing data available at the site in order to evaluate
whether the analytical range presented in the QAPP wi~l meet the
site's Data Quality Objectives. No RI data had been gathered before
the QAPP, therefore, the site scoring data was submitted. (Site
scoring data is under the purview of a different QAPP.) With
respect to the cyanide, the holding times can be tracked if
needed. If the holding times were exceeded. the contract
requirements would have been violated and the data rejected.
The time to have submitted comments on the site scoring was in
1983 when the site was proposed for NPL listing.
Comment 10.
parameters.
The RI fails to document holding times, especially for SAS
EPA Response: This does not need to be in the RI. Holding times
for RAS are specified in the CLP contract (and the QAPP).
Holding times for SAS are specified in the SAS's attached to the
QAPP. Laboratories call the EPA for corrective action procedures
." :. .. ~ : :":-:.:~ :-,:. ~.::"\';~J'~ ".'o-. :i~: ~'.~' -'~: :;::~::".....:...-: :... ::":'~'~'. ..:~.;'; ;:i::. ::~::-;=~~0.. '~:~.~-~::..~ ":::-.~.o:~~,:~;,~" :.:~~~: ;",.'~:';~'~:~.:':.:. ~.-:::- ~~~,:, "Z":-, .,~> ~~: ~.~; ~ ~~'~"'.~':; :,::,,:. ,," ~'. '
: "';.:i._"':_'~ .:0;:' :. - :-;'~-~", '.~"'. .-"'.'- ....~.~. .. J";". ~;.~:. ~ ..;'c. ---"C. - :'., ",
-------
- 5 -
if holding times are a problem. The EPA data reviewers check
holding times when the data package is reviewed. Holding time
was exceeded for one set of pesticides samples during this RI.
EPA subsequently rejected the data. This rejected data is noted
on RI p.3-13, however, the reason for rejection was not listed.
Additional EPA Response: All the above questions concerned the site
specific impleAentation of the system established by U.S. EPA
t9 ensure defensible data. All contractor SOPs are available for
review at the Region V office. All EPA SOPs are established through
guidance from Headquarters. A list of all available program guidance
was provided for review in the project file at the Marion Public
Library. The sections of the QAPP referred to should be almost
identical between REM II projects, since the same IIsystem- is used.
In the case where a project is not conducted by REM, under the CLP
system, the burden is on the project director to explain how equivalent
QA/QC procedures will meet EPA requirements.
Comment 11. The definition and use of llnon-detects" is arbitrary and
means that every sample is considered a positive result.
EPA Response: For the purposes of this project, the selection of
IIchemi cal s of concernll and the data reduction procedures are one in
the same. The procedures are described before the data is dicussed (RI
p.3-3, 3-4) and again in the PHE (RI p.5-4). A geomentic mean
was applied to the data set. It is a particularly good method for
this site because the ground water investigation was conducted
beneath the source material and there was significant variability
in the concentrations detected. Geometric rather than arithmetic
means were used since most collections of measurements of environmental
contaminants are log-normally distributed. An arithmetic mean
is "additive", where as a geometric mean is "proportional".
One cannot calculate the 109 of zero, therefore, one half of the
CRDL was arbitrarily used. Host statistics booKs say that X + 1
is frequently used for a zero value. Since the CRDL is used as a
baseline, it is reasonable to use half of that value for zero. As noted
. above, this approach best suits this site and works to the commentor's
favor s.\nce a geometric mean is generally lower than an arithmetic mean.
To further clarify the application to the PHE, refer to ~I p. 5-4. A
mean wasn't used unless at least two samples were above the CRDL. If,
however, only one sample was detected above the CROL, it was used in the
maximum exposure scenario. Contaminants detected below the CRDL were not
used in the PHE at all. This approach is reasonable and defensible.
Comment 12. Use of Federal water Quality criteria for leachate
comparison is erroneous.
EPA Response: EPA assumes the commentor is referring to Table 3-
17 (See RI page 3-51, 3rd paragraph). The Agency agrees that
-------
- 6 -
fish don't live in leachate. The RI presents the criteria merely as
a reference. This is discussed in the RI p.3-51, middle paragraph.
Comment 13. Screening of data qualified as a "8" was not done according
to the specified rules.
. ~
EPA Response: In general, the rules were followed. Had the
commentor provided an example, EPA could provide better explanation.
The EPA project manager noted that one EPA data reviewer had
inadvertently misapplied the evaluation criteria with respect to
the 118" qualifier. The data were rechecked and corrected. It is
possible that some corrections were overlooked. This applies to
typical lab contaminants such as methylene choride and the pthalates.
In order to be cautious about the data, all QA/QC was checked for
parameters which were sensitive to the interpretation of the PHE.
Comment 14.
Typical concentrations of metals in soils are not provided.
EPA Response: Data summary tables for soils compares the
investigative sample results to both the site-specific background
valves and typical concentrations found in U.S. soils. See Table
3-1, 3-7 and 3-12.
Comment 15. Cyanide was not detected in the waste borings yet was
the basis for site scoring.
EPA Response: The comment is noted. Three borings are not
representative of the entire landfill ,contents. Other contaminants
detected bring the site clearly within the scope of SARA.
Comment 16. Data below CRDL is reported as being detected when
concentrations below CRDL can not be detected and quantified with
accuracy.
EPA Response: The data referred to in Table 5-4 is a geometric
mean. The phthalate and arsenic were in error; the values should
be 13.4 and 12.3 respectively. This changes the average risk due
arsenic from 7x10-6 to 2xlO-5. An errata sheet will be issued.
The following clarification of the definition of the CRDL is
provided. The CRDL represents a minimum detection limit that all
laboratories participating in the CLP program must meet. The
CRDL value is actually set artificially high in order to be certain
that a sufficient number of laboratories qualify for the program
to meet the program capacity needs. In reality, most labs can
achieve a more sensitive instrument detection limit. Any value
detected is a "hard" number. It is quanti fied with accuracy
because it is above the instrument's detection limit. and therefore
within the instrument's analytical range. The results would be
reproducible on any instrument which could achieve the same
detection limit. The "JU value means that the result may not be
reproducible (it may not be detected) if another lab were used.
Another lab may not have an instrument which can achieve the same
sensitivity. Defining "J" as "estimated" is a misnomer, since
the value presented is not an estimate. Technically, every data
value could have been used in the PHE. The CRDL provided a
convenient break point for selecting chemicals of concern.
. . '. .", . . . ,. ..... . . ':0. -. ".... ~ - .'~
. .- ~. . '," "'. ! .
, .', ... ~. .. .
-.. ". '. ." ." ...."": ,",
-------
- 7 -
Comment 17. There is no docu~entation in the RI to indicate whether
the inorganics were filtered or unfiltered. The application of
MCLs to unfiltered samples is not justified.
EPA Response:
theRI.
See the last footnote on Table 3-22~'page 3-56 of
. ~
Comment 18: The PAH concentrations detected on-si"te are typical of
urban soils and are attributed to sources other than the landfill.
f
EPA Response: The history of the site suggests that a lot of
burning occured on-site. Burning creates PAHs. The RI clearly
states (page 3-22) where each sample was taken. The conclusion
that EPA draws from this data is that multiple sources (i.e., the
landfill and the asphalt plants) contribute to the PAH problem.
PAHs were detected above site-specific background values.
Comment 19. The RI describes DOT and cadmium in background as
"anomalies" and therefore may not be considering alternate sources
of contamination.
EPA Response: EPA assumes the commentor is referring to page 3-
34, 5th paragraph, in which case the pesticide in question is
SHC, not DOT. The soil boring samples were used as site-specific
background values for comparison to the waste boring (Table 3-1).
Since BHC was not found in the waste boring, listing the background
soil concentration i.s .moot. The cadmium value was listed in the
tahle. Therefore, from Table 3-1, one can conclude that the
background cadmium (detected once in seven samples) is above
typical soil concentrations, but the waste boring sample for
cadmium is statistically significant above the background values.
The commentor's remark is not clear.
Section 4 - Risk Assessment
Comment 1. Unrealistic Interpretation of the Plausible Maximum Scenario
for PAH Exposure in Surface Soils. '
EPA Response: EPA interprets the commentor to suggest that subchronic
exosures should have been calculated, and that the site average
concentration should have been used in the maximum exposure case.
Both exposures scenarios are considered chronic. Exposure duration
is what determines chronic or subchronic (occuring over a period
of time). The difference in the exposure scenarios was frequency,
not duration. Subchronic values were ,not needed. It is generally
the Agency's procedure to look at the maximum value in the maximum
exposure case. This is supported in the Superfund Exposure
Assessment Manual (Aug. 17, 1984). A review of the maximum, or worst case
exposure scenario is necessary to compensate for uncertainties in
sampling and analysis, unknown health effects due to multiple contaminants
and possible exposure to sensitive subgroups within the population.
It is true that the maximum concentration for PAHs represent a specific
source. This particular area leaches radially in the direction
of the surface slope. The point at which it enters the pond
serves as a convenient access point. Teenage kids seen fishing
from the pond, have been noted at the most accessible 'points, on the
western side of the pond. This assessment doesn't even address
.. ---~....- -...., ",... -- . . ~. -
"._-.._--~--- .-_.;----_._--~
-------
- 8 -
the exposure to workers who are present in this area during the
asphalt plant's operating periods.
Comment 2. Representation of Various PAHs with limited evidence of
Carcinogenicity as Benzo (a) Pyrene.
\,
EPA Respdnse: The discussion presented on p. 5-56 and 5-59 very
clearly states that numerous assumptions are made for PAHs in the
risk assessment. Each assumption is discussed, the impacts of
that assumption 6n the risk value presented and the appropriate
EPA references which endorse the assumption are given. The nature'
of risk assessments is such that many assumptions must be made.
Use of this group of carcinogenic PAHs is suggested in the criteria
documents (attached) used to develop the SPHEM guidance. Refer to:
EPA (1984) Health Effects Assessment for Polycyclic Aromatic Hydrocarbons.
Environmental Critteria and Assessment Office. September 1984.
EPA 540/1-86-013. and,
EPA (1980) Ambient Water Quality Criteria for PAHs. Office of Water
Regulations and Standards, Criteria and Standards Division.
October 1980. EPA 440/5-80-069.
There is a discrepancy between these criteria documents and the SPHEM
with respect to the two compounds mentioned by the commentor. The
Agency will request clarification of this, but would rely on the crjteria
development documents for the time being.
3.
4.3 Inappropriate Specification of Applicable or Relevant and
Appropriate Requirements (ARARs).
EPA Response: Possible ARARs were identified throughout the
entire RI, in all discussion of data. It is important to distinguish
applicable from relevant and appropriate. A standard which is
applicable in a given situation, meets the statutory requirements
(circumstances) of the law it reflects. A relevant and appropriate
requirement is not directly applicable but the circumstances are
sufficiently similiar that its use is appropriate. For example,
MCLs are not directly applicable to the aquifer beneath the site.
However, since the aquifer is a Class II B, potential use aquifer,
MCLs may be considered relevant and appropriate.
The commentor states: IIThese ARARs are applicable at the point
of use; if concentrations of contaminants are not available at
these points, the concentrations should be predicted.1I The Agency
agrees, and did just that when predicting possible risks from
consumption of the aquifer beneath the site, if it were used.
The RI clearly states the ground water risk is based on potential
future use. In addition, in the absence of criteria, health
effects criteria such as risk reference doses or potency factors
are to be considered in risk development. Therefore, ARARs
presented in Chapter 5 are correctly used and the points of
exposure (beneath the site) correctly referenced.
. - - ~. -" "-.".-
" -.. .- -', .. - -". '''.'-'--.' ~ -.-.
'~"....:_~ ~-_L..'.. '-..".--,. '..,"',..-' "~""".." ',-,
.... ~ ~: ',-:.,0"0
"', '''',''-'' '.-~--~." ~.- ----- ,,-,---~,"'-
..'''.". ,,' ,,' ~ '.'~'-., - - ...,-.", .:.. . . ,,0 ,.', . ." . '...: - -.
.." "'." ~- -.' ~ -". . '.. . .
'.' ~'." # ":. ..... ..'" ~ -. .. '.. .';. \ . "
-------
/
/
IARC (1983) has evaluated selected PAHs based on the overall we1ght of
ev1dence of carc1nogen1cHy to humans. "These c1assHtcat10ns range from
Group 2A (SaP) and 28 mean1ng that the com~ound 1s probably carc1nogen1c tn
humans to Group 3 wh1ch 1nd1cates that there 1s only 11~1ted an1mal ev1dence
or a pauc1ty of ev1dence such that the data base 1s inadequate to assess the
h~n carc1nogen1c potenttal.
Some of these classtf1cat10ns are based on
f
routes of exposure other than oral and 1nha1at10n." As a class. PAH-conta1n-
1983).
1ng soots, tars and 0115 are most appropr1ate1y c1aS51f1ed as Group 1 (IARC,
App1y1ng the cr1ter1a proposed by the Carc1nogen Assessment Group of
-
the U.S. EPA (Federal Reg1ster, 1984) forevaluat1ng the overall we1ght of
evidence for human carc1nogen1cHy. these chemicals are most appropr1ately
c1ass1f1ed 1n Group A.
IARC has judged the fo110w1ng spec1f'c PAHs to be probably carcinogenic
in humans.
evidence.
there be1ng sufficient an1mal evidence and or l1m1ted human
would be Group 81 or 82. depending on the quality of the ev1dence.
-
The correspond1ng U.S. EPA .~~oup1ng (Federal Register, 1984)
"
1.
2.
3.
~4.
5.
6.
7.
8.
9.
10.
11.
, 2,
13.
--A 14.
benz[a]anthracene
benzo[b]f1uoranthene
benzo[j]f1uoranthene
benzo[k]f1uoranthene
benzo[a]pyrene
d1benz[a,h]acr1d1ne
d1benz[a,j]acr1d1ne
d1benz[a,h]anthracene
7H-d1benzo[c,g]carbazo1e
d1benzo[a,e]pyrene
d1benzo[a,h]pyrene
d1benzo[a.1]pyrene
d1benzo[a.1]pyrene
1ndeno[1,2,3-cd]pyrene
Reference: EPA (1984) Health Effects Assessment for Polycyclic Aromatic
Hydrocarbons. Environmental Criteria and Assessment Office. September 1984.
EPA 540/1-86-013.
-28-
.. ._~..- . - -.. - .._--_. - -.. ---..
----- '--.-"~ ~..-_._._--.,.,~ --,-~ <-.. .--. -_..~ -., -.. - -- ---"-- ----- ...-
-------
/
/ fur ther. the f 011 owl ng ,ompound 5 ha ve 1 ImHed an lma 1 ev 1 den'e for tare 1 no-
/ gen'c1ty, however, the ev1dence accord1ng to IARC 1s 1nadequate for mak1ng a
def1n1t1ve statement about the human carc1nogen1c potent1a1.
The appro-
"
pr1ate U.S. EPA class"1cat1on (Federal Reg1ster, 1984) for thesechem1cals
1s Group C-Poss1ble Human Carc1nogen.
f
-..--. - -_.~.~ -... -.. - -_..n.._.__.---,.-.-
',-" ... .. ..: ',';"'., '" - ~., '.- ..~~... -,' ,,' . '.
,
l.
2.
3.
4.
5.
6.
7.
8.
9.
anthanthrene
benz[c]acr1d1ne
carbazole
chrysene
cyclopenta[c,d]pyrene
d1benz[a,c]anthracene
d1benz[a,J]anthracene
d1benzo[a,e]fluoranthene
2 and 3-methylfluoranthenes
.' .
-29-
.- :-:-._~-::- ,.':: -.- .-.-.:. "',-'.": -:',~'. ':-':-:-.'.-:~:~:~.:-::~"--~';:-'~7'":-::.~'.~~-.-.-' .- _.y. -":..:~-
-------
- 9 -
Comment 3.
The Future Use Scenario is unrealistic.
EPA Response: The commentor's opinion is noted. The Agency did
not check with the County to determine land use. However, it would
not be unreasonable to assume future land use similar to existing
land use (i.e. additional commercial facilities on the property,
perhaps~~ith a need for recirculating cooling water, as Marion
Paving has now). Since municipal water does not extend to this
area, use of the surficial aquifer is not an unreasonable assumption.
Restrictions currently do not exist. Note that the home existing
within the site boundry has a woman of child bearing age, with an '
infant (sensitive population). Many more conservative assumptions
could have been made, just based on extrapolation of existing conditions.
The recreational use projected for only a five or ten year period
(depending on matrix) presents a rock bottom set of assumptions
(which favor the commentor's view) when future conditions cannot
be known.
Comment 4.
Application of Data Reduction Procedures is Inconsistent.
The commentor felt that data reduction errors led to erroneous
identification of chemicals of concern at the site and that use
of the highest contaminant value in the maximum exposure scenario
presents a misleading interpretation of the risks present at the
site. The commentor also presents his interpretation of the
best indicator chemicals.
EPA Response: Examples of data reduction errors were not presented,
therefore, EPA has no comment on this point. Use of the highest
contaminate value and the plausible maximum exposure scenario is
conservative, but not unreasonable given it is at least based on
existing values where future values are uncertain. See response to
Comment 1, section 4. The maximum exposure scenario compensates for
many data uncertainties.
The selection of indicator chemicals is not a requirement, merely
a convenience when working with a large data base. This process
was not necessary at Marion/Bragg. The Agency doesn't need to assess
the commentor's recommended PHE procedures. The RI has already
completed this tasK in a manner which complies with the guidelines.
Section 5 - Feasibility Study
Comment 1.
Listing of Media Inconsistent
The commentor suggests that inconsistent listing of media has lead
to inconsistent response objectives, which may not correspond to
the PHE.
EPA Response: The FS correctly identifies the media in which the
PHE identified risKs, as well as the media in which the pathway
for potential future risK exists. The on-site pond and/or river
. .. -- ~ ..-. -
. . - .-~ . -. - .-._.
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- 10 -
were identified as presenting a current risk, however, they are
exposure pathways of concern. In adrlition, the FS (Chapter 7)
clearly states that (based on existing data) these .pathways are
more likely to be impacted if existing contaminant level actually
increase~over time. Since the Agency is required to select
remedial' actions which are permanent and protective, then the
potential for future risk must be addressed.
Comment 2.
Interim Remedy
The commentor presents an alternate view of the selected remedy
el ernent s.
5.3.1 Access and Deed Restrictions
The commentor concurs on the need.
EPA Response: The comment is noted. A point of clarification is
needed with respect to the deed restriction. The land owner must
provide the restriction voluntarily. The Agency does not have
the authority to impose it.
5.3.2 Flood Protection Measures
The commentor feels the levee is an expensive means of achieving
the goal and suggests other technical approaches which are felt.
to be comparable. .
EPA Response: The language in the ROD has been clarified as a
result of this comment. The goal stated is performance based.
If the PRPs can find another means of achieving it which gains
the approval of appropriate State and Federal Agencies, then
U.S. EPA may accept it as well.
Comment 3.
Indiana Sanitary Landfill Cap
The commentor feels the clay cap is an excessive means.of preventing
the direct contact threat. Further, the commentor suggests that
repair work on the existing cap is all that is necessary.
EPA Response: Section 121 of SARA specifically states that the
selected remedy will comply with the ARARs which are determined
to be appropriate. The Subtitle D requirements are the minimum
ARAR at this site. Two feet of clay would be excessive if the
direct contact threat was the only concern. Congress wanted to
ensure that selected remedies did not undermine the minimum
protectiveness requirements considered by the regulations established
under other State and Federal environmental laws. This mandate
is very clear in Section 121. The sloping and capping requirements
under Subtitle D serve to minimize future problems at any landfill.
This minimum ARAR follows common sense and good engineering
practice. This cap will be consistent with any ground water
remedy, ACL or slurry wall.
_:...,t.~~~~~7::~~..~-~;.~~~_7~~~=..~:;~-;;':-: :~.., ..~~.~;::;:::~.:~::.~;.~,~'::-" :':~r;~~ ~~~.~:~~.~.."~:~~~~~~;~.,~~..~,~:.:-..~~~.':','~~=~':;# .,~~~~~~~'~~,-~ -~~~~~":-":,~~'~'~-~:~~~,:,~~~'''_: ..:\~. "~'&,i" "'~ ~.~:.~:. ." ~-'~;. -, ~ ~ ~:.~. .#~..,. ~: :"--~.~~.~..~.: .: '". ...
-------
- 11 -
Comment 4.
Monitoring and Additional Investigations
The commentor suggests that additional study is not
monitoring. Further, a frequency for monitoring is
interpretion of the point of compliance, and action
based on table 6-2 in the FS.
needed, only
suggested,
levels selected
EPA Response: The FS clearly states that ammonia is a "potential"
problem-epage 7-4, 4th paragraph), and that additional data will
answer whether it is an actual problem. This is a conservative
and reasonable approach to make sure that the final remedy is
indeed permanent and protective.
The monitoring program suggested is not sufficient. The river
bank is one half mile long on the site border. Ground water
quality will change because waste type and characteristics
will change. In order to be protective, EPA recommended monitoring
appropriate "discharge zones" (page 6-7). The action levels
suggested in Table 6-2 are only "to-be-considered". The NPDES
approach is logical, but there are several differences in the
fundamental assumptions between an end-of-pipe discharger and a
chronic discharge occurring over a one half mile stretch. The FS
did not specify which of the "to-be-considered" values would be
applicable since the ground water remedy was not being selected
at this time. Other approaches can also be considered in the
future. Refer to the RCRA ACL Determinations guidance for examples.
Cormient 5.
Future Remedial Actions
The commentor felt that a slurry wall was not justified by the
existing risks and that the FS failed to adequately address the
technical 1imiations associated with installation of a slurry
wall through trash.
EPA Response: EPA is not recommending a slurry wall at this time.
If it were needed, the FS strongly suggests that compatibility
tests be performed first (Table 6-3). Table 6.8 shows the potential
cost consequences if the slurry wall failed. The EPA contractor
recognized the difficulties and risks associated with application
of a slurry wall in a landfill environment and made adjustments
for those concerns in the estimated capital cost. However, if
it was necessary to prevent the ground water from reaching the
river, not many technical choices are available. The FS evaluates
use of a hydraulic barrier (FS Appendix A), but still suggests
that the slurry wall presents the best cost and feasibility.
Conwnent 6.
General Comments - FS
The commentor felt that the cost documentation should have been
more detailed so that they could determine the reasonableness of
the figures.
EPA Response: This level of cost documentation is typical of FSs.
EPA has offered to make detailed cost documentation available to
the PRP steering committee.
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- 12 -
Section 6 - Conclusions
The commentor summarized all previous comments and suggests that
the proposed remedy is not responsive to the risk. .
EPA Res~Qnse: All comments have been adequately addressed. It
appears that the commentor actually concurs with EPA's response
actions, but feels that the clay cap is excessive. The comments
have not changed the Agency's view of the need for the selected
remedy. The EPA again reminds the commentor of the requirements
of SARA, particularly Section 121.
No other technical comments were submitted. The next section will summarize
legal comments. This will begin with Mr. Hanson's letter.
1.
Mr. Hanson of Beveridge & Diamond, P.C. on behalf of the Steering Committee.
Comment: Due Process Requires a Reasonable Comment Period and
Fair Agency Procedures: They Have Not Been Provided.
The PRPs are entitled to procedural due process, and are entitled
to a substantially extended public comment period to include
60 days beyond the date they receive a response to a Freedom of
Information Act request concerning the Marion/Bragg site.
EPA Response: EPA agrees that the PRPs are entitled to the benefits
of that procedural due process, which is due and appropriate
under the circumstances, regarding notice of and an opportunity
to comment on the remedy selection set forth in the Feasibility
Study (FS) released August 4, 1987. However, EPA disagrees with
the PRP position that the demanded extension of the public comment
period beyond that provided for in the enabling legislation and
the National Contingency Plan is mandated by considerations of
due proces s.
First, the public comment period began with the release, with
public notice, of the FS on August 4. Special notice letters were
sent to the PRPs on August 10, 1987, notifying them of .their
opportunity to negotiate a voluntary performance of remedial
action at the facility, and notifying them of the availability of
the FS. EPA rejects as completely ungrounded the PRP assertion
that public comment period began on August 22, 1987.
Most of the PRPs who have received special notice under Section
122(f} of SARA were previously given, in December 1985, an
opportunity to perform the RI and FS themselves. They declined
to do so. They have also been aware of the existenc~ of the
Region's ongoing RI and FS activities since that date, which are
part of a continuum from identification and listing of an NPL
site through of final remedy and removal from that list. The
PRPs have evidently chosen not to remain involved in that process
or to seek to obtain the data and other developing site information
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. .
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available from the EPA. Notice consistent with the requirements
of Section 113(k) of SARA was given, along with "special notice"
of the moratorium period under Section 122(e)(2) of SARA. The
administrative record developed to date has been available since
August 4,1987, in the locations prescribed in Sect.ion 113(k)(1)
of SARA (at the Marion public library and in Region V's offices),
and it c9Qtains the "background data and procedures" used in
developing the RI and FS. The FOIA request submitted by one of
the PRPs largely tracks and includes information already available
to the PRPs in the public record established .by the Region.
Comment: A summary of the technical comments is provided in points
II, II I, I V and V. The Agency wi 11 not repeat the res ponse to
comments which have been provided to the ERM Report in Appendix.2
to Mr. Hanson's letter.
Comment: Mr. Hanson also requests the opportunity to comment on
a draft work plan for remedial action.
EPA Response: The Agency generally does not submit a work plan
for RD/RA to public comment since it represents implementation
of a remedy already the public has already commented on. The
plan, however, will be put in the repository for review. If the
steering committee elected not to undertake RD/RA, their next
opportunity for project involvement will be at cost recovery.
There is, of course, the moratorium period which-began with the
special notice (plus delivery time) on August 10, 1987. The
negotiations during this period, ~nd the PRP's opportunity to
submit a good faith proposal for RD/RA work consistent with this
ROD, allows the PRPs access to discussions on the work plan with
EPA.
2.
Mr. J. B. Smith of Beckman, Kelly and Smith on behalf of Mr. Delmar Bragg.
Comment: Mr. Smith refutes the Agency's record of hazardous
waste at the site and provided additional information on the
likely quantities. He also felt the risk posed by the site was
de minimus and that a clay cap over only the transfer station
area is needed to restrict percolation. He suggests th~t EPA
consider this in lieu of the FS proposed remedy.
EPA Response: The Agency appreciates the augmentation of site
history provided. A clay cap over a small portion of the landfill
achieves very little and does not comply with the law.
3.
Mr. Spitzer of Brown, Spitzer, Herriman, Browne, Stephenson and
Holderead on be half of General Plastics Corporation.
Comment: Mr. Spitzer requests that General Plastics Corporation
be removed from the list of PRPs since their waste is of an
industrial t but not hazardous nature.
EPA Response: EPA will accept information General Plastics cares
to submit on the scope of their involvement.
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-14-
4.
Mr. Browne of Browne, Spitzer, Herriman, Browne, Stephenson & Holderead
on behalf of the City of Marion and the Marion Utility Services Board.
Comment: Mr. Browne requests that the City of Marion be withdrawn
from th~~EPA list of PRPs because the City does not handle hazardous
waste (&r hazardous sludge). Mr. Browne also suggests that this
landfill does not pose a risk and the EPA remedy is inappropriate..
EPA Response: Ultimately, the court determines liability. EPA
has adequately addressed the technical concerns raised by the
steering committee and continues to assert that the recommended
remedy is the minimum necessary to protect human health and the
environment. Therefore, it is appropriate.
5.
Mr. Cromer of Mishkin, Cromer, Eaglesfield & Maher P.A. on behalf of
RCA Corporation.
Comment: The procedure followerl in identifying and selection
the Marion/Bragg remedy is inconsistent with CERCLA and SARA and
arbitrary and capricious.
This general statement and comment includes a number of sub-points.
that will be addressed individually.
Comment: The allegedly short review and comment period is being
imposed solely to mee~ internal Regional desires to conclude the
ROD by the end of EPA's fiscal year.
EPA Response: As demonstrated above, EPA does not believe the
comment period is unreasonahle short, but does not dispute that
it desires to conclude the ROD process as quickly as possible.
EPA maintains, however, that the procedures and timing followed
here are fully consistent with the law.
Comment: The PRPs are entitled to a full trial-type hearing
before a "neutral and detached decision maker," including pre-
hearing discovery, examination of witnesses and associated
procedures, before being compelled to expend large sums of money
at the facility.
EPA Response: The PRPs have not been required to expend large
sums of money to finance the remedy. The PRPs have received the
statutory notice of two opportunities to voluntarily assume the
responsibility for certain response actions: To perform the
RI/FS, and to undertake the remedy. No compulsion attaches to
EPA's offer to allow such voluntary action.
'. "..''-~. '.:~'~,,,.:::.io~Z~':":":'!' ;':':~~0.."':'~or"..;~'~:':;'-:-";''':AJ;,:. ':!::~~'~(.{:.;:::...-:;~"J:" .~::"~;.~.;;;;~i:~'. ~::.,~~:,~.;.,f""; :. ~:":~'-;:~~;.';>.;;"~>~~~.r~':~:::;~:;;;;:;~~ ~-~'::: ~~~..~'. ~'':t ':~~'.:::;. ~ ';~ ,.:';?'": -:,.:~.:~'..~~' :~. '.:.: '...; .~, I,",: "'~'...'~:- ..., ...~~:'I"~~:: .~":.: :"~.... ".. '; .:v-. :t .:,- -:...:. T-_"'.. -'
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f
Beyond that threshold point, however, it is patent that neither
CERCLA nor SARA apprehend any adjudication-type procedures before
a "neutral and detached decision maker," presumably and equivalent
of an administrative law judge or hearing officer. .Section 113
requires ~otice and opportunity to comment, which has been
provided~; Section 107 provides defenses and sets. the standards
for recovery, in a judicial adjudication that must be brought by
EPA, of costs the EPA must expend if the PRPs decline to assume
the remedial tasks. Particular notice and opportunity to comment
have been given to the PRPs and the community in the manner
provided by the site, and the PRPs have been on notice of ongoing
RIfFS process since December 1985. The data generated by EPA .
during the RIfFS process are made available routinely on request
from PRPs and the public and are included in the public record.
The final decision on a ROD is committed by delegated authority
to the Regional Administrator, who is not involved in the details
of the remedial development process. EPA believes that the
statutory process is fully protective of the PRPs' due process
rights, and the process as administered here was neither arbitrary
nor capricious given the manifold opportunities the PRPs have had
continuously available to gain information about the remedy
selection process and prepare comments for submission during the
public comment period.
Comment: EPA has disregarded a requirement of Section 122(e) of
CERCLA, as amended, by closing the public comment period during the
moratorium on response action established in Section 122(e).
EPA Response: Closure of the public comment period on the FS is
not "commencement of response action" under Section 104(a).
Rather, it is only one step in the process, already under way,
leading to actual commencement of on-site cleanup activity. The
moratorium period is clearly inteneded to halt, where environmental
and human health threats are not pressing, the actual conduct of
response actions at the facility. The moratorium period, moreover,
is an additional opportunity for the PRPs to negotiate with EPA
concerning response work to be performed, if the PRPs prbduce a
good-faith proposal after 60 days and oblige themselves by the
end of 120 days through a consent agreement to perform the remedial
work. EPA does not agree that the Section 122 moratorium requires
holding the public comment period and the administrative record
open. Indeed, this PRP comment, were it to be acceded to by EPA,
poses a conundrum: A remedy, following the PRPs' view of the
moratorium, could not be selected through a ROD and made the
subject of negotiations until the moratorium period was over, but
negotiations over the remedy cannot begin until the EPA has
established the remedy.
Comment: In a cost recovery action, the EPA will not be able to
support its recommended remedy, and the ultimate decision maker
on issues such as cost recovery will be a Federal District Court.
""--~-'- u_--",-.,,'~---~-'-'''' .~---'-~'_--_P- -, p,. -r,....~.."-"--"--"-'
. . . -
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EPA Response: EPA agrees that cost recovery actions will be
decided, if they are not settled, by a federal court. This
comment illustrates a degree of confusion between the process of
selecting a remedy through notice-and-comment procedures, and
litigation of cost recovery claims should the PRPs decline to
undertake",the remedy. In any cost recovery action, the PRP
defendants wi 11 have the opportunity to demonstrate to the court
that the remedy is inconsistent with the National Contingency
Plan and the enabling legislation, and to seek to raise challenges
to that legislation as well. The PRPs' rights to due process of
remedy selection and to negotiate their own agreement on performing
a remedy; and they have access to judicial review, in action brought
to recover EPA costs, of the EPA's remedy. -
IV.
Remaining Concerns
None identified.
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Appendix 6 -- Administrative Record Index
. ,
-.-,,,,.~__---4__.__.- 4.. -. .-. - -' -- .._--- ....--.-
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Administrative Record Index -- Marion/Bragg Landfill
Administrative Record for Marion/Bragg Landfill, Grant County, Ifdiana
as of September 30, 1987.
.
~ .
File' 1. PAISI, HRS
f
o Raw data for scoring package
2. Site Inventory
o memos from observation during site visits
o file search information obtained during RAM? period
including: land ownership, water well records, city
township location documentation
3. RAMP (Remedial Action Master Plan)
9/9/83
4. RI/FS initiation
o letter from IDEM requesting project initiation and maKing
Assurances
o RI/FS Statement of Work
5. Work Plan memorandum
6/19/85
2/10/86
6. Community Relation Plan
. 7. Initial Site Evaluation
.
8. Groundwater Utilization Survey
9. Draft Geophysical Investigation
8/20/85
7/18/85
Fall 185
10. Work Plan - PRP negotiating draft
11. Final Work Plan
10/11/85
4124/86
14. Phase 11 Sampling and Analysis Memorandum
7/10/86
4/24/86
6/2186
12. Final Quality Assurances Project Plan
13. Final Health and Safety Plan
. .
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-2-
15. Request for applicable, relevant and appropriate requirementsifor
Remedial Alternatives 3/6/87. t
.
~ USEPA COnWnents:
.
, 0 Water Division
4/28/87
0 Air Division 6/17/87
0 Great Lakes National Program Office 4/27/87
0 Solid Waste Branch 4/15/87
..
IDEM Conrnents: 5/4/87 and 7/27/87
..
16. Quality Assurance Project Plan - Addendum One for supplemental sampling
( May, 1987)
17. General Correspondence File - Contains various comments and
correspondence with other Agencies such aSj ATSDR, ISBH, IDEM and
U.S. Fish and Wildlife Service.
o ISBH letter identifing water quality standards
o Fact sheet, Public NKick-offN meeting
o IS6H comments to Draft QAPP and Health and
Safety Plan
7/3/85
1/30/86
9/25/85
o ISBH comments to Draft Work Plan
o ATSDR comments to Draft Work Plan and Draft
QAPP
10/9/85
10/23/85
o Memo from Potentially Responsible Party meeting 01 11/7/85
o ATSDR memo for review of residential drinking
water samples
11/9/85
o ISBH additional comments on Work Plan and QAPP
2/6/86
o U.S Fish and Wildlife comm~nts on surface water and 6/10/87
sedi ment data
.- .~, I,:. -~ ',,'.:: ~~...~~';:,,:;.~.:.~.:::: ~.:{..;~,.:;"':~:: ~~:~::;,:;::" '1-. ".;::;-.~.,-::-.::..-,~~.::, -:;:.;7.;':::.-, :~~:;i -.- :~ -~..--~ ~ ~\,..-:-~" ":, 'c~;:::. ':',,-:",..~:..-.- ~-:: ::~ :-:. ~ -.:'~-~~,,\'~-.,:~- :~:- k:<"~~, .;-~:-- ':"
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- 3 -
18. Applicable Guidance
19. Comm~~ts to Agency Proposed Plan
f
Uncopied references which are available at the Regional Office in
Chicago, Illinois:
1. Guidelines for the Po11utional Classification of Great Lakes
Harbor Sediments - April, 1~77
2. Raw Data from all RI field investigations
The reader should note that in 1986 the Indiana State Board of Health
(ISBH) was reorganized and the Indiana Department of Environmental
Management (IDEM) was created.
..- -.".-. ~..-... ..--..-.-... -,p._-'-- ~ .
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Q
Appendix 7 - State of Indiana Concurrence
. ~
.- ~
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INDIANA DEPARTMENT OF ErMRONMENTAL MANA
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