\ ,
I
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP A/RODIR05-91 /156
March 1991
Gfi/
fE'72 -1"64l/07
oEPA
Superfund
Record of Decision:
Main Street Well Field, IN
.,\, ,
,u.'~. Enviro~menta' ProtectiQO 'A9~ncy
RegiO~ iii Hazardovs Waste " '
Technical Information Center
~'l Che.stnut Street. 9th Floor"
, ' " rhil~derphia I PA 19101 '.,
'-:;'~ .
Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
EPA Report Collection Center
Information ~esource
US EPA Rsglon 3
Philadelphia, PA 19107
-------
Q
/)
REPORTDOCUMENTA~ON 11. REPORT NO. ' I ~ 3. Redplen\'a Acceulon No.
PAGE EPA/ROD/R05-91/156
,.- 'fItIe and SUbtIle 5. Report Date .
SUPERFUND RECORD OF DECISION 03/29/91
- Main Street Well Field, IN
6.
Second Remedial Action
7. Aulhor(a) 8. Perfonnlng Organlz8l1on RepL No.
.. Perfonnlng Orgalnlz8llon Name and Add..... 10. Pl'ojectITuklWoril unli No.
11. Contr8ct(C) or Gr8nt(G) No.
(C)
(G)
1~ ~ng Organization Name and Addre88 13. Type of Repone. Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 14.
15. Supplementary No,"
18. Abatract (Umlt: 200 worda)
The 48-acre Main Street Well Field (MSWF) site is in Elkhart, Elkhart County, Indiana.
The well field provides the primary water supply for the 44,000 city residents.
Adjacent to the site are several industrial properties, Excel and Durakool to the
east; Elkhart Products to the west that used TCE and other organic solvents as part of
their operations. The site is bounded by Christiana Creek to the north and the St.
Joseph River to ,the south. MSWF is located in both a wetlands and a floodplain, and
overlies a sole source aquifer. Since the early 1900s, an onsite treatment and
pumping station has been used for the purification and distribution of water to the
surrounding community. The well field contains 17 production wells, two interceptors
used as production wells, two 2-million gallon storage tanks, an air stripper
facility, and recharge ponds. Site contamination first occurred during the 1950s when
phenols from a nearby fuel tank farm, east of the well field, were detected in onsite
wells. The Gontamination was mitigated by excavating six recharge ponds and diverting
the water to those ponds from Christiana Creek. During routine sampling in 1981, EPA
identified TCE contamination in onsite wells. Sampling wells were installed on the
Excel and Durakool properties, and the results of this testing indicated these
(See Attached Page)
17. Document An8Jyala L Deacrlptora
Record of Decision - Main Street Well Field, IN
Second Remedial Action
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, xylenes), other organics (PAHs), metals (arsenic)
b. IdenIiIlenl/Open-Ended Terma
c. COSA 11 FleIcllGroup
18. Avellabl8ty Statement 1.. Security CIa.. (Thia Report) 21. No. 01 Pages
None 80
20. SecurIty CIa.. (ThIs Page) 22. Price
I Nnnp
See ANSl-Z3'.18 I 272 (4-77)
See Mllucli- on Relffl,..
(FCIITIIeI1y N115-35)
Department 01 Commerce
S0272.101
-------
EPA/ROD/R05-91/156
Main Street Well Field, IN
~econd Remedial Action
u
Abstract (Continued)
industries were the likely sources of contamination. Subsequently in 1981, the city
constructed two eastern interceptor wells, which discharged to Christiana Creek, and
removed the nearby production wells from service. As a result, TCE levels in finishing
and production wells dropped significantly. In 1984, TCE levels on the west side of
the field increased, and EPA suspected a second plume had impacted the well field. A
1985 Record of Decision (ROD) provided for construction of an air stripping facility to
treat water from the seven production wells and the two eastside interceptions.
Subsequent investigations further characterized onsite contamination and led to the
discovery of a TCE-contaminated paint layer on the soil in eastern area of the site.
This ROD addresses management of migration of the western contaminant plume, as well as
source control on the east side of the well field. A third remedial action may be
necessary if further onsite contamination is identified. The primary contaminants of
concern affecting the soil and ground water are VOCs including PCE, TCE, and xylenes;
other organics including PARs; and metals including arsenic.
The selected remedial action for this site includes treating 22,000 cubic feet of
contaminated soil by in-situ vacuum extraction; removing the soil containing the 60
cubic yards of soil containing the paint layer, followed by offsite incineration or
suitable treatment based on waste characterization and offsite disposal in accordance
with the Land Disposal Restrictions Soil and Debris Treatability Variance; constructing
new interceptor wells on the west side of the field; continued pumping and treatment of
ground water using the existing air stripping unit; ground water monitoring; and
implementing institutional controls including deed restrictions. The estimated present
worth cost for this remedial action is $3,370,000, which includes an estimated annual
M cost of $130,000 for 20 years.
PERFORMANCE STANDARDS OR GOALS: Performance standards for soil and ground water are
based on a 10-5 excess lifetime cancer risk. Chemical-specific goals for soil include
TCE 100 ug/kg. Interceptor wells will remain operational as long as plumes entering
the field have cancer risk levels greater than 10-6. Chemical-specific goals for
ground water include PCE 0.6 ug/l and TCE 1 ug/l.
-------
"
Declaration For the Record of Decision
SITE NAKE AND LOCATION
Main Street Well Field
Elkhart, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Main Street Well Field site in Elkhart, Indiana, developed in
accordance with CERCLA, as amended by SARA and, to the extent
practicable, the National Contingency Plan. This decision is
based on the administrative record for this site.
The State of Indiana concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
This operable unit is the second for this site. The first
operable unit provided an alternate water supply by selecting air
stripping as the cost effective remedy. The function of this
second operable unit is to provide remediation of soil and ground
water contamination in areas of known contamination on the East
side of the well 'field and well field restoration by intercepting
the plume from undefined sources on the West side of the well
field. A third operable unit may be required if additional
sources are identified.
The major components of the selected remedy include:
In-Situ Vacuum Extraction of VOCs in contaminated soi11
Removal of a small paint layer and off-site disposal in
accordance with the Soil and Debris Treatability Variance1
Installation of new interceptors 011 the West side of the well
field to prevent continued plume migration into the well field
and provide well field restoration1
Continued use of the existing air stripper to assure a clean
drinking water supply:
Ground water monitoring to assure adequate performance of the
air stripper and attainment of ground water standards1
Deed restrictions on East Side property with contaminated soil
until the soil and ground water cleanup standards are met.
-------
2
DECLARATION
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes'
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site. This remedy satisfies
the statutory preference for treatment as a principal element of
the remedy. . .
Because this remedy may result in hazardous substances remaining
on-site above health based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy contin es to provide adequate protection of human
Dat
-------
d
Record of Decision Summary
Main Street Well Field
Elkhart, :Indiana
:I.
SITE NAME. LOCATION AND DESCR:IPl'ION
The well field:
The Main street Well Field (MSWF) is located in the City of
Elkhart, Elkhart County, Indiana, at 942 N. Main st. It covers
approximately 48 acres. The Elkhart Water Works (EWW) maintains
three well fields currently and a fourth well field will go on-
line in 1991 to supplement the city's demand. MSWF is the
primary water supply for the city and supplies approximately 80
percent of EWW's production capacity-for a city of approximately
44,000 people. The well field currently contains 17 production
wells, two existing interceptors used as production wells, two 2-
million gallon storage tanks, an air stripping facility, six
recharge ponds and a treatment/pumping station (See figure 1).
Geology/Hydrology:
The aquifer system in northwest Elkhart County consists of coarse
sand and gravel deposits averaging 175 feet in thickness. In the
MSWF area, sand and gravel (glacial outwash) occurs to depths
ranging from 42 to 58 feet. These deposits consist of mixed
sands and sands and gravels. Regionally, below the outwash is a
gray and hard to very dense silty clay layer which separates the
unconfined aquifer from a deeper aquifer. The lower aquifer
ranges from 0 to 120 feet thick within 'the city boundaries. The
confining layer is at least 10 to 160 feet thick in the vicinity
of Miles Laboratory. The Miles investigative data, in
conjunction with data collected during all phases of the RI,
indicates that the lower aquifer interfingers with the till layer
and eventually ~inches out locally northwest of and beneath the
well field. The till is continuous throughout the study area and
the lower aquifer appears to be absent beneath the MSWF. This
till layer acts as an aquitard or confining layer in the study
area. Beneath the clay and silt till lie bedrock units of the
Coldwater and Ellsworth Shales of Mississippian age and the
Sunbury Shale of Devonian age. See figure 2.
The regional aquifer, inclusive of MSWF, is part of a designated
sole source aquifer. The direction of regional ground water flow
is generally south, toward the st. Joseph River and its
tributary, Christiana Creek. This southerly flow is more
predominant east of the well field. In the area west of the well
field, the ground water flow tends from northwest to southeast
toward the well field. The ground water flow in this area is
subject to influence by natural factors, such as Christiana Creek
and by ground water pumpage and recharge. The effect of MSWF on
ground water flow patterns is dependent upon ground water levels:
the number, location and rate of pumping of the supply wells: the
-------
2
recharge from Chris~iana Creek and o~her industrial ground water
use and recharge.
Horizontal qradien~s in the unconfined aquifer measured in ~he
direction of ground water flow, range from .003 to .020 ftjft.
These qradients do not represent natural qradients because of ~he
draw-down induced by various pumpinq wells and pumping rates.
Similarly, the pumping and recharge significantly affects the
qround water velocity. The regional velocity is approximately
102 ftjyear. However, near the well field i~ can be
siqnificantly hiqher - 470 ftjyr measured west of the well field,
and 820 ftjyr measured sou~heas~ of the well field.
The water-table confiqura~ion is dramatically influenced by
artificial recharge, draw-down from the MSWF, and draw-down from
the industrial wells in the s~udy area. The response of the
water-~able is directly related to the number of wells pumping
and ~he rates at which they are pumped. Subsequently, the qround
water flow patterns are also impacted and change on a daily, or
even an hourly basis. Therefore, ~he dynamic nature of the
unconfined aquifer and impact of the pumping-wells induces a
potential for ground water mixing and rapid fluc~uations in flow
velocities.
..
rl.
Site Historv and Enforcement Activities:
Contamination History:
The first known inciden~ of ground wa~er contamination at the
MSWF was in the mid-SO's. Ground water was contaminated with
phenols as a result of releases from a fuel tank farm east of the
well field. The contamination problem was mitigated by
excavating six recharge ponds in the well field and diverting
water to those ponds from Christiana Creek. EWW acquired the
water rights to Christiana Creek from the Indiana-Michigan state
line to MSWF.
In 1981, MSWF was sampled as part of U. S. Environmental
Protection Agency's (EPA's) National Ground water Supply Survey.
The well field was found to be contaminated with trichloroethene
(TCE) at 94 ppb, 1,2-dichloroethene (1,2-DCE) at 33 ppb, 1,1,1-
trichloroethane (TCA) at 5 ppb and l,l-dichloroethane (DCA) at 2
ppb. Observation wells were installed near and on the Exce.l and
- Durakool properties located on the East side of the well field.
The results of this sampling program indicated that both
industries were likely sources of ground water contamination
affecting the MSWF. The ci~y installed two interceptor wells in
the well field on the eastern edge of the property and took
production wells near that area out of service. The interceptor
wells were discharged to Christiana Creek under an NPDES permit.
TCE levels in the finished water supply and production wells
&
-------
N
SCALf:t::uooO
SOURCE:USGS TO~O "A~
ELKHART.IIID:
FIGURE 1
Site location
Map
-------
O'
A
.t8
TW88 TW:le
TW40
F8B2t
80'
tOO'
t80'
200'
. .
..e .
n
~
r:m
Em
Ii
lAND AND GRAVIL
IlL TY CLAY ICLA Y
IHALI
FIGURE 2
Generic-schematic Geologic Cross-section
of the Main Street Well Field Site
WELL FIELD
8-2t
ICALE
o
800
f
,
A'
DI.'
t 000 FEET
-------
I .
3
dropped significantly following installation of the interceptor-
wells. However, in 1984, TCE levels on the west side of the well
field began to increase. One well increased from 14 to 75 ppb of
TCE. EPA suspected that a separate plume had reached or been
drawn into the well field. In 1985, all 15 production wells
showed measurable TCE levels. .
First Operable Unit:
MSWF was proposed for inclusion on the National Priorities List
(NPL) in December 1982, and was placed on the NPL in September,
1983. In April 1985, .EPA began a Phased Feasibility Study (prS)
to address alternatives for an alternate water supply. In August
1985, USEPA signed a Record of Decision (ROD) recommending air
stripping. The facility is designed to obtain removal
efficiencies of 99.1 percent of TCE. Seven production wells plus
the two east side interceptors were piped to the air stripper.
The facility has a capacity of 6.45 million gallons per day. The
air stripping facility consists of three stripping units
(towers) 1 each has a diameter of 10 feet, a tower height of 30
feet and a total stack height of 55 feet. The air stripper went
on-line in September 1987.
Previous Studies:
1.
East Side
Two companies operating on the East side of the well field have
been present since the 1920s and 1930s. Over the years, both
have expanded their operations at that location and thus, their
buildings have seen several additions and changes. Excel
manufactures automobile and truck sash and window assemblies.
Durakool manufactures relay and tilt switches. Both industries
have used TCE and other chlorinated solvents for degreasing in .
their processes. In 1983, Excel and Durakool retained the same
consultant to conduct a voluntary investigation of their
properties. TCE'concentrations in soil on the Excel property
ranged from 0 to 570,000 ppb. On the Durakool property,
concentrations ranged from 0 to 5,000 ppb. In 1984, the State
and EPA determined that the investigative work done by Excel and
Durakool was not adequate to meet the requirements of an RIfFS.
Federal funds were authorized in 1984 for a federal-lead RIfFS,
beginning with a PFS. Special notice was issued after EPA
completion of the prs and signing of the ROD to Excel and
Durakool offering these companies the opportunity to implement
the air stripper remedy and complete the RI/FS. The response was
not acceptable and was therefore, rejected. EPA and the Indiana
Department of Environmental Management (IDEM) funded construction
of the air stripper and continued the RI/FS as federally funded
response activities.
-------
4
2.
West Side
Little was known about why the western production wells were
contaminated in 1984. The idea of a western plume was still
only a theory in 1984. This seemed a likely scenario given the
highly industrial nature of the area west of the well field.
However, without more specific information, there was no one to
notice or provide the opportunity to undertake the RIfFS.
Identification of sources of the West side contaminated plume is
more challenging than the East or North side of the well field
due to the diversity of industry, the higher building tenant
turn-over and the almost ubiquitous use of chlorinated solvents,
many related to metal finishing. operations. Several private
response actions have been performed on the West side, however,
and these source areas are likely contributors.
Soil sampling and removal of contaminated soil was conducted by
Miles Laboratory between 1984 and 1985 after exposing
underground degreasing tanks during demolition of old buildings
on the old Adams & Westlake property which it had purchased. ..
Miles removed over 900 yards of soil containing TCE and 1,1,1-
TCA.
TCE contamination of the ground water was discovered on another
part of the Miles Laboratory property in 1984. Investigations.
into the likely source of contamination suggested that the source
of the TCE contaminated ground water was west of Miles (at
Elkhart Products). TCE is reportedly not used by Miles at this
facility. In 1985, an additional release of 180 gallons of
methylene chloride, ethyl alcohol and acetone occurred at the
Miles facility. Contaminated soil was removed and ground water
recovered. This area is currently undergoing a RCRA Facility
Investigation (~FI).
TCE spill events occurred at the Elkhart Products Corporation
(EPC) site located west of Miles Laboratory. EPC is a
manufacturer of copper fittings and custom fabricated tubular
products. EPC investigated their own property from August 1985
through February 1986. They are currently vapor extracting
contaminated soil and treating contaminated ground water using
air stripping.. .
III.
Community ParticiDation:
EPA and IDEM have been conducting community relations activities
at the site since 1985. Fact sheets were issued periodically to
inform the community of air stripper construction and RIfFS
progress. In addition, an availability session was held to
provide the community, including the potentially responsible
parties, an opportunity to have their questions answered.
-------
5
The ~emedial Investigation Report was released to the public in
May, 1989. The Phase III Technical Memorandum and Feasibility
study was released to the public in January, 1991. These
documents were made available to the public in both the
Administrative Record maintained at the EPA Region 5 office and
at the Elkhart Public Library and at the information repository .
in the City Engineer's Office. The notice of the availability of
these two documents was published in the Elkhart Truth on January
18, 1991. A public Comment period was held from January 23, 1991
through March 22, 1991. In addition, a public meeting was held
on February 7, 1991. At this meeting, representatives from EPA
and IDEM answered questions about site risks and the remedial
alternatives under consideration. A response to the comments
received during this period is included in the Responsiveness
Summary, which is part of this Record, of Decision. This decision
document presents the selected remedial action for the MSWF site
in Elkhart, Indiana, chosen in accordance with CERCLA, as amended
by SARA, and, to the extent practicable, the National Contingency
Plan. The decision for this site is based on the Administrative
Record.
.- I'V.
Scope and Role of Operable Unit:
Main Street Well Field is a multi-source, multi-plume Superfund
site. It is more complex than most sites. As a result, EPA
organized the work into operable units (OUs). These are:
- OU One:
- OU Two:
- OU Three:
Alternate Water Supply.
East Side Source Control
Additional Source Control action (if required)
EPA has already selected a remedy for OU One (Alternate Water
Supply) as described in the previous section. The contaminated
ground water is a principal threat at this site because of the
direct ingestion. of drinking water from a municipal system and
potential unrestricted use of an aquifer that contains
contaminants above health-based levels.
The purpose of this OU response action is to prevent current or
future exposure to the contaminated soils and contaminant
migrat.ion into the ground water East of the well field, and to
prevent current and potential future contaminant migration.into
the well field from the West, thus restoring the well field to
its highest beneficial use.
Since significant uncontrolled "hot spots" have not been
identified West of the well field, it is uncertain how long the
plume will continue to exist. If additional sources are
identified in other parts (west or north) of the study area, an
additional OU may be completed in the future.
-------
6
v.
SummarY of Site Characteristics:
Soil investigations at this site were limited to suspected "hot
spot" areas. Volatile Organic Compounds (VOCs) were the
contaminants of primary concern for identification of hot spots.
However, co-disposal with other contaminants needed to be '
evaluated so that remedial action alternatives could address the
entire hot spot. Contaminants selected for investigative
purposes were selected based on suspected material disposed of.
Where knowledge of possible disposed material was too limited,
full chemical scan was conducted.
The study area, or site boundary, was defined by the ground water
capture zone of the well field and by the total area of ground
water contamination within the capture zone. These boundaries
, were measured several times over the course of the RI/FS due to
the dynamic nature (rapid and frequent changes) of the capture
zone, and because its extent defined how far west EPA's response
authorities extended under this CERCLA site. This capture zone
is shown on Figure 3. Ground water is uncontaminated upgradient
of Elkhart Products Co. on the west side and upgradient of Excel
on the east side. South of these locations ground water is
contaminated and constitutes the ground water study area. This
area is over 300 acres, approximately half of which is
industrial. In conducting this RI/FS, no attempt was made to
provide a comprehensive RI/FS on each property. Instead, areas
of known or suspected disposal were the focus of investigative
efforts. Priority was given to those areas which remained
unremediated or where remediation was completed, but residual
contamination concentrations were unknown. This approach
prioritized efforts and resources to provide the highest amount
of contaminant reduction for the effort expended.
All media were sampled, including air, soil, surface water and
ground water. Figure 4 shows the distribution of TCE in the hot
spot areas on the East Side of the well field. TCE ranged from 0
to 88,000 ppb on the Excel property and from 0 to 29,000 ppb on
the Durakool property. Although other VOCs are present, TCE is
the most wide spread and present in the highest concentrations.
The distribution of other VOC contaminants is discussed in the
RI report. Chemicals detected in a least one soil or ground
water sample are shown on Tables 1 and 2. Significant
concentrations of VOCs were not detected in West Side soil
(generally below 50 ppb), therefore, hot spots could not be
defined. While other contaminants, such as inorganics and
Polynuclear Aromatic Hydrocarbons (PAH~) were present on the West
Side, their presence was not associated with VOCs, therefore,
this operable unit RI/FS did not evaluate the extent of such
contamination.
Figure 5 shows TCE ground water concentration contours from both
East Side and West Side plumes. The East Side plume was measured
-------
~
G)
Q)
....
.c 2680
~
1.0
o
Z
G)
u
~ 2008
~
01
...
Q
G)
u
1\1
.~ tsee
Ie
o
1.0
Do
Do
-<
450B
,~o
..
.
.
.
3609
.-e
~a: g
o .
a: \ -...
WQ. .
. . ~f.JI
. ~ ,.~taO
. >-
. a:
. !~"~r!J~
"t . ". ~ g
'" . -",,:i :5
........ " -. :-..
,
,/
3I/J90
,.,..
DO
'.
,
"-
,,/
-~:r~ ,
-- nr.. '
'., +
/'
a
~Iii
XW
ilia:
-I-
::1111
t900
.....
..... .....
CD ct
:J: ~:J: .
co", '"
o ...c ::t
...f » .... II
~ .,1.0 "
U >0
=' ......
'tJ G) '..
o IIC
C 1.0 .00
GI Po ox
'"
~ + .
P.lL8
see
CD
c ...
o ~ oJ
N . II)
CD w~x
... CD
::t ... ct CD
... ..... >
Do" 0
.. ..., 1\1 c:.a
':i u :J:.....,
t; I _"0- ,
.
cff;j
.-w
~t
,
,
\
N
~
\
,
\
I
Iii
W
~
Z
~
,.,...
I
1+
I
,
,.,.. .
~
,,'t~
~
KAIN STREET WELL FIELD
LOCAL WATER LEVEL ELEVATION CONTOURS
AUGUST 17 1990
~Oi9tance East (teet)
FIGURE 3
Capture Zone
-------
-.-.~..l
.
-~
,
"51" ~:-
.'"
.
.
.
.
.
.... .
~.
,-~ :
.. .
.
.
.
.
.
.
.
~.I :
-
-,.-
~
--
...-
--
...-
w--.....-... ---.
-~~
------
~. - . . - . . - ... ..
--... -....r". - ---"""""""'r
- - --
~-
. III.",
. ! ~'L~., II.' J "'r
.~. ~.- ~".- u,~
;$-~~"'r= I.'J~ n-c~'"
..~.::. ~14111. ~.18 .. ~r!.! 1 ~~..
L ." - . t - . . 1 ~.
, 'J'i,f
'",..
I "'r~~"
08t:~r8lO
1 Iqf'';:.-
~nJJ ~-
;~r . .I~.-
~I"" ~ t.:." :u I -d-
O t -,.tJ:' ~:.~ i, ---~--~~'-.~~.. -' -'-' -' -' -' -. -. -. -'-
., ~"'r~ -"'r--- . .- .
.A .... "-- --
"'r... ~ -- . -
'" ."'" .---
~"-- In -- ...- -
!;' :'--. -. -...",
... ~." --.- ..'S',.-
"'.. - .- <-
.., -- -
~_. --~ ...-
'Y- --
-
---
--
...---
... ........
".....
."........
1
~
II'
..
U2~.
'.
EXC£l
I.j~ ...
.. .
~-
.,
.:
OIl
~-
..
z
j
:I
IUIAlCOOl
.-:
118J~
fl
~1JiJt
..
E
--
--
.--
--------
.--
~
FIGURE 4,
TCE on Eastside
Properties
--
--
~.,._.~..
-------
.
TABLE 1 CHEMICALS DETECTED IN AT LEAST ONE SOIL SAMPI.E IN THE EAST SIDE OPERABLE
UNIT OF THE MAIN STREET WEI.L FIELD OR IN A 8ACKGROUND SAMPLE
Frequency of Detection Range of Detected Values, ms/kg
Chemical East Well Field Background East We 11 Field Background
Acenaphthene 10/166 0114 0/6 0.034-0.37
Acenaphthylene 6/166 0/14 0/6 0.052-0.19
Acetone 85/182 3115 5/10 0.003-100 0.076-0.14 0.026-0.79
Alpha-chordane 2/61 0/15 0/5 0.011-0.015
Aluminum 138/138 6/6 9/9 740-9.270 1,110-2,580 .1,260-5.720
Anthracene 28/166 0114 0/6 0.05-1.3
AnUmony 49/138 016 7/9 1.1-51.8 0.47-30
Arsenic 128/138 6/6 6/9 0.41-26.5 1.9-3.6 1.09-3.1
Barium 137/138 6/6 8/9 3-176 5.4-14.4 8.65-186
Benzene 3/182 0/15 0110 0.002-0.33
Benzo(a)anthracene 40/166 0114 1/6 0.033-3.6 0.063
Benzo(a)pyrene 31/166 0114 1/6 0.037-3.1 0.082
Benzo(b)fluoranthene 36/166 0114 1/6 0.039-2.6 0.096
Benzo(g,h,i)perylene 28/166 0128 1/6 0.049-3.4 0.076
Benzo(k)fluoranthene 29/166 0114 1/6 0.037-2.1 0.12
Benzoic acid 4/166 2/14 0/6 0.11-0.75 0.071-0.1
Beryllium 67/138 016 6/9 0.21-1.7 0.21-0.67
Beta-BHC . 6/61 0/15 2/5 0.0013-0.13 0.013-0.03
Bis(2-Ethylhexyl)phthalate 41/166 10/14 116 0.41-40 0.11-0.27 0.048
2-Butanone 4/170 0/15 0/5 0.005-0.12
Butylbenzylphthalate 3/166 0/14 0/6 0.048-0.82
Cadmium 54/138 116 3/9 0.46-6.3 1.1 0.85-4.7
Calcium 138/138 6/6 9/9 512-124,000 29,900-51,100 841-58,900
Carbon disulfide 6/182 0/15 0110 0.001-0.066
Carbon tetrachloride 3/182 0/15 0110 0.001-0.43
Chlorobenzene 2/182 0/15 0/10 0.005-0.4
Chloromethane 1/116 0/15 0/4 1.1
(methyl chloride)
Chromium 138/138 6/6 9/9 2.7-63.8 4.1-9.1 2.9-12
Chrysene 42/166 0114 1/6 0.035-4 0.1
cis-l,3-dlchloropropene 1/116 0/15 0/4 0.005
continued~ .
-------
Table 1 - continued
Frequency of Detection Range of Detected Values, mg/kg
Chemical East Well Field Background East We 11 Field Background
Cobal t 131/138 6/6 6/9 1.2-17.6 1 . 8-4 . I 2.93-6.95
Copper 137/138 6/6 9/9 2.4-230 4.4-10.2 3-40
Cyanide 8/138 0/6 0/9 0.53-310
4,4-DDT 9/61 0/15 2/5 0.00089-0.03 - 0.0021-0.008
Dl-N-butyl phthalate 56/166 10/14 0/6 0.042-0.76 0.032-0.43
Di-N-octyl phthalate 1/166 0/14 0/6 0.61
Dlbenzo(a,h)anthracene 11/166 0/14 0/6 0.043-0.53
Dibenzofuran 16/166 0/14 0/6 0.046-0.25
1,2-Dichlorobenzene 1/166 0/14 0/6 0.01
1,3-Dichlorobenzene 2/166 0/14 0/6 0.061-0.35
1,4-Dlchlorobenzene 1/103 0/14 0/3 0.096
1,l-Dichloroethane 1/182 0/15 0/10 0.002
1,2-Dichloroethene (total) 24/182 0/15 0/10 0.001-58
1,2-Dichloropropane 1/182 0/15 0/10 0.001
Dieldrin 2/61 0/15 1/5 0.003-0.004 0.0035
Dlethyl phthalate 3/166 0/14 0/6 0.05-0.61
Dimethyl phthalate 0/166 1/14 0/6 0.19
2,4-Dinitrophenol 1/166 0/14 0/6 1.7
Ethylbenzene 22/182 0/15 0/10 0.001-390
Fluoranthene 51/166 0/14 1/6 0.038-7.5 3.17
Fluorene 11/166 0/14 0/6 0.047-0.56
GalDlDa-chlordane 4/61 0/15 0/5 0.0022-0.041 -
Hexachlorobenzene 1/103 0/14 0/3 0.13
Hexachloroethane 1/166 0/14 0/6 0.099
Indeno(1 ,2,J-CD) ,pyrene 25/166 0/14 1/6 0.065-2.2 0.056
Iron 138/138 6/6 9/9 1,820-24,700 4,080-15,700 5,220-18,100
Lead 138/138 6/6 9/9 1.2-1,050 2.5-8.7 2.3-1,060
Magnesium 138/138 6/6 9/9 647-46,200 6,910-17,400 914-17,100
Manganese 138/138 6/6 9/9 43.6-986 84.4-297 88.6-1,160
Mercury 43/138 0/6 2/9 0.1-195 0.18-0.34
4-Methyl-2-pentanone 0/182 0/15 1/10 0.01
contfnued-
-------
Table 1 - continued
Frequency of Oetection Range of Detected Values, mg/kg
Chemical East Well Field Background East We 11 Field Background
Methylene chloride 74/182 7/15 6/10 0.001-0.26 0.001-0.026 0.004-0.044
(Dichloromethane)
2-Hethylnaphthalene 27/166 0/14 0/6 0.041-26
2-Hethylphenol 1/166 0/14 0/6 0.01
N-Nitrosodiphenylamine 2/ 166 0/14 0/6 0.047-0.051
Naphthalene 24/166 0/14 1/6 0.034-32 0.62
Nickel 130/138 6/6 7/9 2.5-295 4.3-9.1 5";'11. 46
PCB-1248 1/61 0/15 0/5 0.14
PCB-1260 1/61 0/15 0/5 0.23
Pentachlorophenol 2/166 0/14 0/6 0.2-0.26
Phenanthrene 58/166 0/14 1/6 0.043-7.2 0.12
Phenol 1/166 0/14 0/6 0.1
Pota8sium 135/138 6/6 7/9 104-761 126-220 99.7-433
Pyrene 52/ 166 0/14 1/6 0.033-7.5 0.17
Silver 47/138 1/6 0/9 0.67-3.7 1.1
Sodium 79/138 0/6 9/9 32.7-1,200 55-334
Styrene 2/182 0/15 0/10 0.005-0.38
1,1,2,2-Tetrachloroethaue 1/182 0/15 0/10 0.01
Tetrachloroethene 29/182 2/15 2/10 0.0003-4.6 0.001-0.002 0.005-0.02
ThaI 11um 2/138 0/6 0/9 0.22-0.23
Tin 2/71 0/6 0/6 40
Toluene 47/182 10/15 4/10 0.0008-690 0.001-0.005 0.0006-0.002
trans-I,2-Dichloroethene 0/66 0/15 2/6 0.001-0.003
l,l,I-Trichloroethane 32/ 182 2/15 2/10 0.0005-25 0.001-0.002 0.004-0.007
l,l,2-Trichloroethane 5/182- 0/15 0/10 0.0006-0.006 -
Trichloroethene 128/182 12/15 2/10 0.001-88 0.001-0.065 0.007-0.022
2,4,6-Trichlorophenol 1/166 0/14 0/6 0.01
Vanadium 137/138 6/6 8/9 2.8-33 3.9-10.4 4-22.4
Vinyl acetate 0/182 1/15 0/10 0.001
Xylene8 (total) 50/182 0/15 1/10 0.001-2,300 0.002
Zinc 138/138 6/6 9/9 6.9-785 11.5-29.2 13. 21- 1 , 160
-------
TABLE 2 CHEMICALS DETECTED IN AT LEAST ONE GROUNDWATER SAMPLE OF THE MAIN STREET WELL FIELD SIT!
Frequency or PeLecLlon Ran.e of DeLee"" Ydu... (../L)
Ch-Ied E..L wut. WdUhld 118cklround E..L w.... "e11fhld 8.ckaround
Acet.on. "2' 21/71 1130 218 0.001-0.023 0.003-0.039 0.017 0.015-0.018
Alumln\88 0/8 1/25 .. 0/' 0.5 "
AnUlIIOny 0/8 1/25 " 01. 0.045 "
Ar.enle 0/8 6125 " 01' 0.001'-0.0075 ..
B8rlum 6/8 23/25 " '" 0.025-0.111 0.0033-0.1" .. 0.056-0.059
118name "240 1112 1/30 011 0.001-0.0027 0.001-0.015 0.001'
BI.(2-ELhylh.ryl) I'hLheht.e 1/7 3/29 " 0/3 0.00' 0.006-0.11 "
BuLmane, 2- 0/20 6160 019 0/8 0.002-0.0U
lIut.ylbenaylphLh818L8 0/7 2/29 " 013 0.00'-0.007 ..
Celc h.. 1/8 25125 .. '" 0.57-'2 0.024-143 " 68. '-71.'
C8rbon DI8ulride 0/2. 2112 2/30 011 0.005-0." 0.0002-0.0008
Carbon T.t.r8chlorld8 0/2. 1112 0/30 011 0.001
Chlorobename 0/240 0111 1/30 011 0.0003
Chlorofolfl8 0/240 3112 0/30 011 0.001-0.15
.Chlor_t.hen. (HWt.hyl Chlorld8) 015 1/30 019 0/11 0.0007
Copp8r 2/8 4/25 " 2/' 0.029-0.038 0.002'-0.039 .. 0.026-0.033
Cy.nld. 0/8 3/25 '" 0/' 0.0054-0.1'3 ..
Dlchloro.t.hen., 1,1- 0/2. 29172 "30 0/11 0.001-0.0076 0.002-0.022
Dlchloroet.han., 1,2- 0/5 1/30 019 0/8 0.014
.
.. Dlchloro8t.hen.not.d), 1,2- "13 23/60 1130 0/3 0.03'-0.044 0.002-0." 0.0008-0.068
I
\ Dlchloro.t.h.n., 1,1- 0/240 13112 0/30 0/11 0.001-0.052
DI, chloroprop8ne 1,2- 0/240 3112 0/30 0/11 0.002-0.003
hon "8 2"25 " "4 0.0425-0.878 0.0091-2.24 " 1-1.41
L..cI 0/8 11125 " 01' 0.0018-0.0028 ..
H.sn.8 h.. 6/8 22125 " 4/' 20.1-23.5 0.101-32.3 " 22.1-24.8
H8nS8n... 7/8 I9IU " .,. 0.0009-0.361 0.0017-0.51 " 0.231-0.247
MeLhylen. Chlorlcl. (Dlchlor088t.h.n8) 51240 30112 2130 III 0.001-0.01 0.001-0.018 0.001 0.012
Michl 0/8 1/25 " 01' 0.022' "
Ph.nol 0/3 119 " 012 0.005 "
PoL....- "8 22/U " 31' I. 03-1. 8. 1."-'.93 " 1.2'-1.84
S.l.nl- 0/8 5125 " 01' 0.0018-0.0023 ..
Silver 1/8 2/25 " I" 0 . 0097 0.0093-0.0097 " 0.011
Sodl- 6/8 25115 .. 4/4 4.72-26.1 0.024'-751 " 6.61-11.'6
Tet.r8chloro8thane. 1,1,2,2- 0/2. 1112 0/30 0/8 0.0"
T.t.r.chloroeth.ne 1/240 19111 1/30 0/11 0.11 0.002-0.2 0.0007-0.022
Toluen. 1/24 1111 6/30 1/11 0.0015 0.00"-0.003 0.0001-0.0043 0.002
Tr8n.-I,2-Dlchloro.th.n. 1011' 22/42 9121 0/11 0.002-0.094 0.001-0.1 0.001-0.005
Trlchloro.th8ne, 1.1.1- "2' 21112 11/30 0/8 0.0016-0.0078 0 '102-0.23 0.000'-0.016
Tdchloro.t.h.n. 17/2' 40/12 19/30 0/11 O.OU-O.096 O. 01-0.57 0.0016-0.051
V8n.dl'~ 0/8 I/U " 01' . 0.104 ..
Vlny I ..rld. 2/24 10/72 3/30 0/11 0.012-0.015 0.002-0.11 0.002-0.007
Zino 3/8 U/15 .. 2/' 0.02-0.033 0.0035-0.0652 " 0.017-0.021
. - -.. . - -- -.. .. -... L" "-
-------
~ . t t; I flO'lll II IL
~
Ir ' oD[
:I
i . .
ti . SIION11)M 1 II I
5
u - -~J Q
3
J .
. ~
18 I
8 -.J
~J ~
.
cu...
If.
.
.
...
~
,
FIGURE 5
TCE Concentrations in Groundwater
".~--- .. ..-.. innn
8 CHtIStlAHA CAE£k
MEASURING POINT
. MONITORINC wm.S
. PRODUC1lOH WElLS
VALUES 1M ppb
A'tt.
-------
7
at a maximum of 300 ppb and the West Side plume was measured at a
maximum of 570 ppb. The ground water contour is somewhat.
simplistic since the plumes are commingled. The relationship of
TCE found in one well to another well is unknown. Analysis of
other ground water contaminants showed that several inorganics
were present above background, particularly on the West Side.
These inorganics were evaluated in accordance with the risk
assessment procedures.
During phase III field investigations, a small paint layer was
noted in two of three borings taken in suspected disposal areas
on the Excel property. The paint layer is not well characterized
chemically or in terms of its actual extent. This layer was
found to contain the highest level of TCE (88,000 ppb), xylene
(2,300 ppm) and lead (2,900 ppm). The layer was visually
distinct and samples taken below the layer show that the
contaminants were relatively well bound.
Air and surface water pathways were not considered significant
since no site related contamination above background was found in
monitoring data. The air pathway was modeled in the risk
assessment for those chemicals which may present a potential
future risk if airborne.
VI.
Summary of Site Risks:
A risk assessment was conducted in accordance with the ~
Assessment Guidance for Superfund (RAGS). The purpose of a risk.
assessment is to analyze the potential adverse health effects,
both current and potential future, which may be posed by
hazardous substances released from a site if no action were taken
to mitigate such releases. The risk assessment consists of
contaminant identification (data evaluation and selection of
contaminants of concern), toxicity assessment, exposure
assessment, and 'risk characterization.
Contaminant Identification:
The risk assessment screened all the detected chemicals in order
to identify the potential chemicals of concern. Screening was
based on data quality, frequency of detection, comparison to
bacKground, and toxicity in accordance with the RAGS. The
potential chemicals of concern for the East Side soil and ground
water pathways remaining after screening are shown below.
Ground water
Soil
'tetrachlorethane (C)
trichloroethene (C)
vinyl chloride (C) .
barium
cis-l,2-dichloroethene
arsenic (c)
trichloroethene (C)
Carcinogenic PARs (C)
antimony
mercury
-------
8
trans-1,2-dichloroethene
xylene
(C) indicates carcinogens or potential carcinogens, all others
are non-carcinogen~.
The risk assessment provides a characterization of the West side
plume for the purpose of identifying contaminants in addition to
VOCs that may be a concern entering the well field. A summary of
risk estimates for the West Side plume are found on page 11 of
this decision summary.
Exposure Assessment:
The exposure assessment includes reasonable maximum scenarios for
current and future use. Under the no-action alternative, the
current exposure scenario assumes the air stripper is not in
place and therefore, a worker at the East side property has
exposure to contaminated soil and drinking water from the East
Side plume untreated for 40 years. A future scenario includes'
re-zoning the East side property from industrial to residential
use. Adults and children living in the homes would be exposed to
chemicals potentially remaining in site soils, and the residents
would drink the ground water untreated by the air stripper for 30
years. The exposure pathways are summarized in the risk
assessment.
Toxicity Assessment:
The toxicity assessment weighs available evidence regarding the
potential for particular contaminants to cause adverse effects ,in
exposed individuals and provides, where possible, an estimate of
the relationship between the extent of exposure to a contaminant
and the increasea likelihood and/or severity of adverse effects,
including carcinogenic and noncarcinogenic effects.
The toxicity values used in this assessment are summarized in
Table 3. Cancer potency factors (CPFs) have been developed by
EPA's Carcinogenic Assessment Group for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of
(mg/kg-daY)-l, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects
the conservative estimate of the risks calculated from the CPF.
Use of this approach makes underestimation of the actual cancer
risk highly unlikely. Cancer potency factors are derived from
the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans.)
-------
9
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for occurrence of adverse noncarcinogenic effects.
Risk characterization:
Tables 4 and 5 summarize the risk characterization results.
Arsenic and carcinogenic PAHs were included as chemicals of
potential concern as a result of application of the simplified
screening procedures described above. However, if background
comparison and toxicity-concentration screens had been based on
average concentrations instead of maximum sample concentrations,
e- they would have been excluded as potential chemicals of concern.
They are shown to contribute a risk not greater than lxlO-5.
Since their site-relatedness was questionable, as was their
association with likely industrial processes, their presence was
thought to be within background variability. The chemicals of.
concern were reduced to VOCs only.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., lxlO-6 or lE-6). An excess lifetime cancer risk of lxlO-6
indicates that as a plausible upper bound, an individual has one
in one million cpance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under
the specific exposure conditions at the site. .
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived
the contaminant concentration in a given medium to the
contaminant's reference dose}. By add'ing the HQs for all'
contaminants within a medium or across all media to which a
population may reasonably be exposed, the Hazard Index (HI)
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
The baseline risk assessment yields the following conclusions:
from
given
can
East Side and Well Field Ground water. East Side soils
-------
TABLE 3 SUMMARy OF ORAL AND INHALATION TOXICITY VALUES FOR CHEMICALS
OF POTENTIAL CONCERN AT THE EAST SIDE(~EA
OF THE MAIN STREET WELL FIELD SITE
Oral Inhala tion
Chemical RiD RfD SF RfD RfD SF
-s- --c:- -8 -c
Antimony 4E-4 4E-4 NA(b) NA NA NA
Arsenic 1E-3 1E-3 1.8E+O NA NA 1. 5E+ 1
larium 5E-2 7E-2 . NA lE-3 lE-4 NA
Mercury 3E-4 3E-4 NA 3E-4 3E-4 NA
trans-l.2-Dichloroethene 2E-l 2E-2 NA NA NA NA
Tetrachloroethene lE-l lE-2 5.1E-2(c) NA NA 3.3E-3(c)
Trichloroethene NA NA 1. lE-2 (c) NA NA 6E-3(c)
Vinyl chloride NA NA 2.3E+O(c) NA NA 3E-l(c)
PARs (d) 4E-l 4E-l 1. 2E+1 (c) NA NA 6.1E+O(c)
Xylenes (Total) 4E+0 2E+0 NA 3£-1 3£-1 NA
(a) RfD . sub chronic reference dose; RfD . chronic reference dose; SF .
slo~e factor. Source: USEPA (1990a,E)
(b) NA . Not available because chemical is not toxic by this route or has not
been evaluated.
(c) Weight of Evidence: Cadmium, 11; Tetrachloroethene. 12; Trichloroethene,
12; Vinyl chloride, A; 1,I-DCE, C; Benzo(a)pyrene, B2.
(d) Slope factors based on benzo(a)pyrene developed in the Health Effects
Assessment for polynuclear aromatic hydrocarbons (PARs) (USEPA 1984). Use
of this value for 811 carcinogenic: PARs is likely to result in an
overestimate of risk. This value is undergoing evaluation by USEPA.
Reference doses based on napthalene. Use of this value for the
noncarcinogenic effects of PARs is "likely to result in an overestimate of
risk.
-------
- - -'-~--~~----~----- -~~-~-
tABLE 4 SUMMARY OF POTENTIAL CANCER RISKS FOR FUTtJRE ADULT RESIDEN'I'
Exposure Exposure Route- Chemical (a) Chemica1- b Rel. Chem. )
Medium Route Specific Risk Specific Risk () Contribution, X(c
Sol1 Oral 7E-6 PCE 3E-9 0.04
TCE 2E-8 0.28
Care. PABs 2E-6 28.48
Areeme 5E-6 71.19
Dermal lE-7 PCE 2E-8 16.67
TCE lE-7 83.33
Inhalation 6E-8 PCE lE-9 1.64
TCE 6E-8 98.36
Total 7E-6 PCE 2E-8 0.28
TCE 2E-7 2.77
Care. PABs 2£-6 27.70 '
Arsenic SE-6 69.25 .
Groundwater Oral 3E-4 PCE 2E-5 6.12
TCE 7E-6 2.14
VC: 3E-4 91. 74
Inhalation 5£-5 PCE lE-6 2.22
TCE 4E-6 8.89
VC 4E-5 88.89
Total 3E-4 PCE 9E-6 4.17
TCE 7£-6 3.24
. VC 2£-4 92.59
Percent
risk due to
Soil . 2.74
Percent
risk due to
Groundwater 97.26
Total 3E-4 100.00
(a) PCE . Tetrachloroethene, TCE . Trichloroethene. Carc. PABs . Total carcinogenic
polynuclear aromatic: hydrocarbons. VC . vinyl chloride
(b) These values are from Appendix Page A4-18
(c) Relative contribution to total risk from this chemical or pathway.
-------
TABLE 5 SUMMARY OF POTENTIAL CANCER RISKS FOR CURRENT WORKERS
Exposure Exposure Route- Chemical (a) Chemica1- (b) Rd. Chem. )
Medium Route Specific Risk Specific Risk Contribution. %(c
5011 Oral 3E-7 PCE 5E-11 0.02
TCE 2E-9 0.66
Care. PABs lE-7 33.11
Arsenic 2E-7 66.21
Dermal 7E-8 PeE 2E-9 2.78
TCE 7E-8 97.22
Inhalation 5E-6 PCE lE-8 0.20
TCE 5E-6 99.80
Total. Soil 5E-6 PCE 1£-8 0.19
TCE 5E-6 94.16
Care. PAHs 1£-7 1.88
Arsenic 2E-7 3.77
Groundwater Oral 1£-4 PCE 4E-6 3.77
TCE 2£-6 1.89
VC 1£-4 94.34
Sol1 4.83
Groundwater 95~17
Total 1£-4 100.00
(a) PCE . Tetrachloroethene. TCE . Trichloroethene. Care. PARs. Total carcOinogenic
polynuclear aromatic hydrocarbons. VC . vinyl chloride
(b) These values are from Appendix Page A4-11.
(c) Relative contribution to total risk from this chemical or pathway.
-------
10
Total estimated excess cancer risk for current workers is
1xlO-4 (or, 1 in 10,000). Ground water exposure accounts
for more than 99 percent of the risk. OVer 98 percent of
the risk due to ground water exposure is from contamination
by vinyl chloride and PCE.
Total estimated excess cancer risk for future residents is
3xlO-4. Ground water exposure contributes approximately 97
percent of the total risk. OVer 97 percent of the risk due
to groundwater exposure is from contamination by vinyl
chloride and PCE.
Arsenic and carcinogenic PAHs pose risk less than 1xlO-S
from ingestion of contaminated soil by hypothetical future
residents. Contamination levels of these chemicals in east
side soils appear to be similar to background and may not be
site related.
Noncarcinogenic effects in current workers or future
residents are unlikely, since no hazard indices exceeded
1.0.
West Side and Well Field Ground water
Total estimated excess cancer risk for current workers is
8xlO-4. Over 89 percent of the risk due to ground water
exposure is from contamination by arsenic, l,l-DCE and vihyl
chloride.
Total estimated excess cancer risk for future residents is
6xlO-4. Over 89 percent of the risk due to ground water
exposure is from contamination by arsenic, l,l-DCE and vinyl
chloride.
Noncarcinogenic effects in current workers for future
residents are unlikely, since no hazard exceeded 1.0.
Environmental Risks
Environmental receptors are thought to be Christiana Creek and
the St. Joseph River. The recharge ponds are not considered a
significant environmental receptor of contaminated ground water
due to the hydrologic relationship between the ponds and the
ground water in that the gradient is from the ponds to the
ground water, reversal is not likely. In addition, the ponds are
dredged every 2 years to ensure maximum infiltration rates.
Samples taken from surface water and sediment within the well
field showed no VOCs. The City discharged ground water from the
East Side interceptor wells into the creek under an NPDES permit
prior to construction of the air stripper. Currently, the ground
water is pumped from these interceptor wells directly to the air
-------
11
str~pper. The interceptor discharge to the creek was sampled
prior to construction of the air stripper and found to contain 94
ppb of TCE, 21 ppb of 1,2-DCE and 2 ppb of l,l,l-TCE. Downstream
samples were free of VOCs. As suspected, it is likely that the
contaminants discharged to the creek volatilized before moving
far downstream. One sample taken in the creek far downstream
showed TCE at 8 ppb. The source of this contamination is
uncertain.
The St. Joseph River is designated recreational use by IDEM. The
IDEM adopted water quality criteria for TCE for protection of
human ingestion of fish is 807 ppb. No criteria have been
established for protection of aquatic life. The Federal Water
Quality criteria (WQC) for protection of aquatic organisms at
chronic exposure levels for TCE is 21,900 ppb. For human
ingestion of fish at a 1 x 10-5 risk, the WQC for TCE is also
807 ppb. Ground water monitoring well data near the St. Joseph
River showed TCE at 12 ppb for the highest concentration. This
is well below state and Federal WQC. VOCs were not detected in
sediments in the st. Joseph River.
MSWF was identified as a wetland and a floodplain. PAR and
inorganic compounds were detected in creek and river sediments.
These were attributed to natural and anthropogenic sources
unrelated to the hot spots of concern in the study area. This is
more thoroughly discussed in section 5 of the RI report. It was
concluded that the potential for environmental effects is low.
VII.
Description of Alternatives:
Based on the findings of the Remedial Investigation and risk
assessment, the following Remedial Action Objectives were
developed for the MSWF site:
Continue to provide a safe source of .drinking water through
on-going use of the air stripper.
Control migration of contaminated ground water to the well
field to minimize existing ground water contamination within
the well field.
Minimize risk to human health and the environment from
direct contact with contaminated soil.
Reduce migration of soil contaminants to. the ground water in
areas of known contamination.
The feasibility study documents technology and alternative
screening steps. The alternatives evaluated in detail include:
1.
No Action
-------
TABLE 6
WASTE aUANTfTY TABLE (AREA AND VOlUME)
Meln Str..1 wen Field SII.
Elkhart, Indl.n.
Note. Alia C.q. ft.' Volume (cu. yd.., T 01.1 Flow (gpm) I Number of w.ne
I Palnl ley.r Naxt 10 Building 250 30
Pelnlley.r We.le 1 PoIenll.1 Pelnt lay.r Und.r Building. 250 30 NOT APPlICABLE
TOTAL 500 60
Thr.. Hot Spote B...d on AI 0.1. tA 15,300 IA 8,500
2A 17 ,500 2A 6,500
4A 5,800 4A 2,200
son Two POlentlel Hot Spol. B...d on Prevl- 5A 3,300 5A 1,800 NOT APPlICABLE
ous Inform.llon 6A 5,500 6A 3,000
TOTAL 47,400 22,000
AelUm. 4 of 7 Production w.ne On-line 2.820 V ProductIon
Oroundwater at Any Olven Time NOT APPlICABLE 2 Int.rceplor
I
"---.---
-------
SIMONTON STREET
SIMONTON STREET
L
EXCEL
~c........
1
EX-8.
.
0IC'12
"AN. 'elf
FIGURE 6
lOCATION OF EAST SIDE HOT SPOTS
MAIN STREET WELLFIElO
ELKHART. INDIANA
=-
AREA 4A
+[1C'21
.
~
~ ARUS 0' ucns CANCEA
~ AISK GAUTUI THAN 1& 1D-5
ARUS 0' EXCns CANCEA
. AISK QRUnA THAN "'0'6
,
LOCATION OUESTIONABLE
.EIt-1
[XCEL SOIL BOltiNG
~DK - I CUItAkOOL SOIL BORING
o 50 100
L -2
S:ALE:FEET
SCALE 15 APPROXIMATE
-------
1.2
2.
In-situ vacuum extraction of contaminants in soil (East
Side), paint layer removal, maintain current well and air
stripping system, deed restrictions, and ground water
monitoring
Low temperature thermal desorption and in-situ vacuum .
extraction of contaminants in soil (East Side), paint layer
removal, maintain current well and air stripping system,
deed restrictions, and ground water monitoring
3.
4.
In-situ vacuum extraction of contaminants in soil (East
Side), paint layer removal, new interceptor well system,
current air stripper, deed restrictions, and ground water
monitoring
Low temperature thermal desorption to remove contaminants in
soil (East Side), in-situ vacuum extraction of contaminants
(East Side), paint layer removal, new interceptor well
system, current air stripper, deed restrictions, and ground
water monitoring
...,
5.
Consistent with the Agency's intent to streamline Feasibility
Studies by recognizing obvious remedies, a containment
alternative was not evaluated as a stand alone alternative. VOCs
are readily amenable to treatment. In addition, containment for
a large volume of soil on actively used property would rely.
significantly on institutional controls over a highly vulnerable
aquifer and would not be consistent with the statutory preference
for treatment. See 42 U.S.C. Section 9621 and 40 CFR
300.430 (a) (1) .
Elements common to all alternatives:
In-situ Vacuum extraction (ISVE): Table 6 and Figure 6 show the
areas and estimated volumes of contamination. The mass of
chlorinated solvents could range from less than 200 pounds to
greater than 1,000 pounds. The hot spots shown result from
disposal and/or spillage of solvents, used primarily in
degreasing operations at Excel and Durakool. The areas of
highest contamination tend to be the surficial soils and the
water table interface where contamination may have been.
- transported farther distances by the fluctuating water table.
These estimates were based on EPA studies and previous data from
the Excel and Durakool 1983 studies. These estimates represent a
minimum volume and area of contamination. The actual extent of
contamination beneath the buildings is unknown. During the
design phase, this will need to be delineated.
ISVE is included in all alternatives, either as a stand alone
technology or as used in conjunction with Low Temperature Thermal
Desorption (LTTD). The buildings on the East Side are
constructed on 4 inch concrete slabs. Penetrating the
-------
SIMONTON STREET
£ X C EL
~IC
............,.
~ -$-EX-2
E X- 1"'- ~ I
. -$: EX-4
£X-3
~EX-:
-$:
~ ..IIi:::,. ..il:i . EX-Ie
EX-SY 'TEX-9
I -S- -$: ~ .(r.
EX-IO' EX-II ~X-~. EX-13 EX-~
I -S . ~T
EX -14";"'''--&EX'15~EX-16 EX-17 "~1"~
~EX-7
j ~".19
EX-3)- '
I .~ )C-
o
r.::
~ £X-22
~
OK- I
..
~
.
"
11
OURAKOOL
~
DK"2~
OK-~-$-
PAINT LAYER APPROXIMATELY
10 FT. WIDE BY 25 FT. LONG
OK-12
:
i
-$; ~OK-8
c~K-7
~ -(r DK-II
DK-IO
~DK-4
OK'SA #OK-5 ~DK-6
~DK-9
..
11
~
..
t
NOTE:
SEE TEXT FOR EXPLANATION
OF SOIL SAMPLING LOCATIONS
LEGEND
~EX-I EXCEL SOIL BORING
-$-DK .. I DURAKOOL SOIL BORIt>
o 50 100
. ,
SCALE:FEET
SCALE IS APPROX IMATE
FIGURE 7
Suspected Paint Layer Locations
-------
13
foundations for vapor well extraction points is technologically"
fea~ible and preferable to removing these active manufacturing
facilities for remediation of the VOCs (as may be required if
LTTD was used alone). Thus LTTD is combined with ISVE in two of
the four alternatives.
Paint layer removal: During phase III of the investigation, a
small paint residue layer containing xylenes (2,300 ppm), lead
(2,910 ppm), as well as TCE and other solvents was noted. The
paint layer (approximately 30 cubic yards) is poorly defined by
the few borings placed in the disposal area and limited chemical
analysis. However, the boring logs in combination with
information provided by a hand sketched diagram of the disposal.
area, suggests that the paint residue layer is very limited and
visually distinct. Chemical results showed that contaminants
within the layer appear to be well. bound. and not leaching
appreciably. A similar disposal area is thought to exist beneath
the building (based on an aerial photograph). The volume
estimated for disposal conservatively presumes that the disposal
area inside the building also contains paint. Therefore, the
volume estimate was doubled to 60 cubic yards. TCE is mixed with
the paint. Paint has a high organic content and low porosity,
therefore, the VOCs mixed in the paint would tend to remain bound
and would not be extracted with ISVE technology. In addition,
lead exceeds acceptable levels and is not extractable with ISVE.
Due to the very small volume of soil associated with this paint
residue, on-site treatment technologies would not be cost
effective and therefore, were not evaluated.
CUrrent well and air stripper system: This component requires
that operation of the air stripper be continued in order to meet
the need for a permanently safe drinking water supply system.
Maintaining the current system also includes monitoring to
assure adequate performance, operation and maintenance of the.
system and force mains connecting the existing production wells
to the air stripper.
Deed restrictions: Deed restrictions are included for the East
Side soil and ground water contaminated property until such time
as the cleanup standards are met and sustained for at least 5
years. The City of Elkhart has been requested to prevent
residential exposure to the plume on the West Side through
whatever means available.
Alternative 1:
No Action
The no action alternative involves no ground water interception
or treatment. Therefore, the existing air stripper would be
abandoned and there would be no pumping of ground water for the
purposes of contaminant interception. The no action alternative
will result in risk associated with the ground water and soil
identified on the East Side. The risk associated with the no
-------
I .
14
action alternative would remain at 1xlO-4 for the current worker
and 3/10-4 for the potential future resident on the East Side and
at 8xlO-4 (current worker) and 6xlO-4 (potential future resident)
on the West Side. Thus, without any cleanup, the potential
lifetime excess cancer risk will exceed the acceptable risk range
of 10-4 to 10-6.
The total present net worth of alternative 1 is presumed to be
nothing. .
Alternative 2: Yn-situ Vacuum Extraction. Paint Layer Removal.
Current Well System. CUrrent Air StriDper. Deed Restrictions- and
Ground water Monitorin9
Alternative 2 incorporates the use of in-situ vacuum extraction
(ISVE) to remediate the volatile organic contaminants documented
in the hot spots of soil contamination on the East side.
Extraction and treatment of the contaminated ground water is
accomplished by maintaining the existing interceptor system and
air stripper treatment facility. .
Maintaining the operation of the existing interceptor wells and
air stripper provides control of the ground water contaminant
plume into the well field from the East side but does not provide
control of contaminated ground water from the West Side.
ISVE is a process to remove or recover VOCs in vadose-zone
(unsaturated) soil. A subsurface gradient is created and
vaporized volatile contaminants migrate through the air spaces
between soil particles toward extraction points where they are
recovered. If emissions control is needed, the removed VOCs are
processed through a liquid-vapor separator and then treated by an
activated carbon bed, catalytic converter, afterburner.
Implementation o~ ISVE would include installing at least 50
extraction wells to the water table, installing blowers, piping
and a temporary support building- The duration of the treatment
required to attain the soil cleanup standard is estimated as 12
months.
Deed restrictions are used to prevent use of ground water on the
East Side until such time as the soil 'and ground water standards
are met.
In addition to treatment of the TCE contaminated soils, the paint
layer will be removed, sampled for the target compound list and
disposed of off-site in accordance with RCRA. Additional
characterization of the paint layer will be required in the
design phase in order to determine the primary functional groups
of concern. Based on that information, an off-site treatment
technology will be selected. Cost estimates are based on thermal
destruction (incineration).
-------
15
The present net worth of alternative 2 is estimated at $3.8
Mil~ion.
Alternative 3: Low Temperature Thermal Desorption. :In-si~ Vacuum
:~r~~:;~nDe:~i~:s~r~i~~o:~~.G~~~n;a~:~lM~~~i~;in~ ent Air
Alternative 3 addresses the 80i1 contamination in the East Side
hot spots by means of removal, to the extent practicable,
followed by thermal treatment of the soils with an on-site low
temperature thermal desorption (LTTD) treatment system.
Recognizing that excavation of large quantities of soil next to
and/or beneath the buildings may not be desired or necessary,
ISVE is proposed to remove the remaining VOC contamination in
these areas.
Two different LTTD systems are currently in operation. One is
directly fired, forcing heated air counter-current to the flow of
soils and the other system is indirectly fired using an oxygen.
free atmosphere. Both systems use rotary drums and hea~ transfer
to desorb and remove volatile and semi-volatile organic
compounds. The organic compounds are removed by condensation,
through carbon absorption, or through combustion and the . .
airstream is then discharged through a stack. Process residuals
include processed waste, condensed organic compounds, an aqueous
offstream, ash from the afterburner, spent carbon and air
emissions (which may require controls, as discussed in the
compliance with ARARs section).
Excavated soil would be placed on trucks, hauled to the on-site
LTTD laydown area (0.25 miles away), preprocessed to remove any
large boulders, then fed into the LTT~ unit. The treated soils
would be stockpiled and eventually replaced in the original
excavation. Treatment of the estimated 14,600 cubic yards would
take approximately 60 to 90 days after the system is set up. The
ISVE portion of the remedy would require at least 17 extraction
wells and the du~ation would still be expected to extend over 12
months.
The total present net worth of alternative 3 is estimated at $8.5
million.
Alternative 4: In-situ Vacuum Extraction. Paint Laver Removal.
New InterceDtor Well System and CUrrent Air StriDDer. Deed.
,Restrictions. and " Ground water Monitoring
Alternative 4 incorporates a new interceptor well system on the
West side of the well field. All other components of the remedy
are the same as described in alternative 2.
Construction of the" additional interceptor wells on the West side
will contain, or block, the plume and prevent contamination from
-------
16
entering the well field.
Construction of the new interceptor wells on the West side is
anticipated to decrease the average daily quantity of ground
water requiring treatment from 4.1 million gallons per day (MGD)
to 1.3 - 2.5 MGD, depending on well field demand. Greater well
field demand would require greater pumping of the interceptor
wells as well. Construction of the new interceptor wells will
also necessitate the construction of approximately 3,000 linear
feet of 10-inch diameter ductile force main from the West side
interceptor wells to the air stripper building.
Initially, the existing East side interceptors, production wells
and new West Side interceptors will be routed through the air
stripper. When the production wells decrease concentrations,
.only the East and West interceptors will be routed to the air
stripper. This is expected to take less than 5 years. As the
East side ground water cleanup standards are achieved, only the
West side interceptors will be routed to the air stripper.
The air stripper was designed for an influent concentration of
310 ppb at 6.5 MGD. At this rate, emissions did not exceed 1xlO-
6 risk levels, nor did it exceed any State or Federal standard.
The air stripper, treating water from the East and West
interceptor wells, will emit approximately 2.02 pounds/day (737
pounds/year) of VOCs. The concentration in the influent will
increase from the 15 to 20 ppb currently measured to
approximately 200 ppb. The concentration will increase because
the new western interceptors will be located in the most
concentrated portion of the plume and because the existing
production wells currently routed to the air stripper will no
longer need to be routed to the air stripper. The combined air
emissions from both the air stripper and the ISVE are expected to
be less than the state regulated permit amount of 25 tons
VOCs/year (326 lAC 8-1-6), the State Implementation Plan (SIP)
regulated standards of 3 pounds/hour or 15 pounds/day.
Therefore, emissions controls will not likely be needed.
During the design phase, estimates for air emission mass and rate
will be refined and reevaluated. The estimate for new
interceptor capacity will be refined and if an increased flow is
required in order to achieve complete interception, the air.
emissions rates will be reevaluated to ensure that ARARs and
protective levels are not exceeded. And if necessary, the air
stripper facility would be modified to accommodate projected flow
changes. Similarly, if soil concentrations or volume change
significantly, air emissions controls will also be evaluated for
the ISVE system.
The total present net worth of alternative 4 is estimated at $3.4
million.
-------
17
Alternative 5: Low TemDerature Thermal Deso~tion. In-Situ
:;~::.E~~~~~o~irP:~~iD~~~rc::~o;:~tr~~~i~~;~r~~~tg~o~~lwater
lIoni torina . .
Alternative 5 combines the West Side qround water interception
system described in Alternative 4 with the LTTD contaminated
soils remediation approach identified in Alternative 3.
The total present net worth of alternative 5 is $8.1 million.
nIl.
Comparison of Alternatives:
Table 7 summarizes the alternatives relative to the 9 criteria.
. Threshold Criteria:
OVerall Protection of Human Health and the Environment:
Alternative 1, no action, does not satisfy the requirement for
overall protection of human health and the environment because
the risks posed by contaminated soils and qround water would
remain. Alternatives 2, 3, 4 and 5 are all protective since they
each include treatment of contaminated soil and qround water.
Alternatives 2 and 3 are protective in that the VOC contamination
is intercepted by the production wells and treated by the air
stripper. However, the concentrations are more dilute and the
well field itself is not restored. Alternatives 4 and 5 are
considered more protective due to the plume containment outside
of the well field. The net result is that the well field is
restored within a relatively short timeframe (a few years or
less).
Compliance with ARARs:
Section 121(d) of SARA requires that remedial act-ions meet
legally applicable or relevant and appropriate requirements
(ARARs) of other environmental laws. These laws may include: the
Resource Conservation and Recovery Act (RCRA), the Clean Water
Act (CWA), the Clean Air Act (CAA), the Safe Drinking Water Act
(SDWA), and any state law which has more stringent requirements
than the corresponding Federal law. "Legally applicable" .
requirements are those cleanup standards, standards of control,
and other substantive environmental protection requirements,
criteria or limitations promulgated under Federal or State law
that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstances at
a CERCLA site. "Relevant and appropriate" requirements are those
requirements that, while not legally applicable to the remedial
action, address problems or situations sUfficiently similar to
those encountered at the site that their use is well suited to
the remedial action.
-------
18
Non~promulgated advisories or guidance documents issued by
federal or state governments do not have the status of ARARs;
however, where no applicable or relevant and appropriate
requirements exist, or for some reason may not be sufficiently
protective, non-promulgated advisories or guidance documents may
be considered in determining the necessary level of cleanup for
the protection of human health and the environment.
Table 9 provides a summary of ARARs and other pertinent
regulations for the alternatives. . Below, however, is a
discussion of the significant ARARs for the respective
alternatives. .
RCRA is a significant ARAR for this operable unit. Chlorinated
solvents were disposed of at the site prior to 1980, but the TCE
and other solvents came from degreasing operations (RCRA listed
processes). Therefore, RCRA is applicable to the treatment,
storage and/or disposal of these wastes in this remedial action.
In addition, any solid waste derived from the treatment, storage
or disposal of a listed RCRA hazardous waste is itself a listed
hazardous waste. Therefore, both prior and subsequent to ..
treatment, the soils are considered RCRA listed hazardous wastes.
The soil and ground water are also RCRA listed wastes under the
"contained-in" rule. Under this rule, any mixture of a non-
hazardous material with a RCRA listed hazardous waste must be
managed as a hazardous waste as long as the material "contains"
hazardous waste. .
laws and
The paint layer will be removed and disposed of off-site. This
layer consists of soil contaminated with RCRA listed hazardous
waste and, therefore, RCRA Land Disposal Restrictions (LDRs)
apply to its disposal. Because the LDR treatment standards are
based on the treatment of industrial process wastes that are
physically and chemically less complex than process wastes mixed
with soil, until , treatment standards for soil and debris are
promulgated, there is a presumption that a treatability variance
pursuant to 40 CFR 268.44 will be used to comply with the LDRs.
(See Superfund LDR Guidance #6A, OSWER Directive #9347.3-06FS,
September 1990).
The guidance demonstrates that, based on their physical and
chemical properties, RCRA hazardous constituents have been
divided into twelve "structural functional groups", as provided
in Table 8. Each constituent in a group is treated in relation.
to a threshold concentration (TC) (column 3 of Table 8). If the
constituent concentration is below the TC, then the waste is
treated to a level within a specific concentration range (column
2 of Table 8). If the constituent concentration exceeds the TC,
then the waste is treated to a level specified in terms of
percent reduction (column 4 of Table 8).
-------
TABLE 7 . Page 1 of 3
COMPARATIVE EVALUATION OF FINAL ALTERNATIVES
M.ln Street wen Field Site
Elkhart, indiana
Criteria Altemat"'e 1 Altematlve 2 Altematlve 3 Altamatlve .. AIIam8l1ve 5
OVERAllPROTE~NESS
Human Health Protection
Contact Soil No reduction In rI.k. 10~rI.k r. Oreater than 10" achieved. " Oreater th.n 10" achieved. " Ore..er than to" rille echleved, O,.8I.r than 10" rille achieved,
main.. needed. needed. , needed. " needed.
Oroundwater Inge.llon No reduction In rI.k. 1~rlele r. Oreater than 10" rI.k or bener Orealer than 10" rI.1e or bailer O,..t., than 10" rid aohfeved. O,.ater than 10" rI.. achieved.
main.. echleVed. echleved.
averall Protection No protection. Protect"'e beeaUie o' Ire.t, Protective beeawe of treat. MOIl protective bee8UM of Moat protective beeaUN of
ment o' 1011 hot .pot. .nd Ire", ment of 1011 hot.pot. and tre... tre.tmant of 8011 hot .pote and treatment of .011 hoI.pota and
ment of groundw.ter. ment of groundwaler. proce.. control for containing proce.. control for containing
mlgr.llon of contaminated mlgr.lIon of c:ont8mlnated
groundwater. Groundwater.
COMPlIANCE WITH ARAR9
Chemlcal-Speclflc ARAAt Doee not maet ARAR8. Mee18 ARAAt. Meat. ARAAt. Meetl ARARt. Maete ARARa.
locatlon-Speclflo ARAAt Not appflcable. Mee.. ARARa. Meet. ARAAt. Mee18 ARAAt. Maete ARAAt.
Actlon-Speclflo ARAR. Doe. not maet AMR.. Meet. ARARa. Meet. ARAAt. Meet. ARAR.. Meetl ARAAt.
SHORT TERM EFFECTIVENESS
Community Protection SoIl and groundwater path- Potentla'thre.t. Include VOC Higher potenll.1 for expo8ure Minimal .dv..e Imp8Ol8 duro Same a. Altematlve 3.
waye provfde 'Unacceptable relea.e. removal of paint layer. and community due to airborne Ing .hort term .Inee only con-
rlek.. . dltchart. during 1011 hot .pot .tructlon aCllvltle. are removal
excevet n end preproce..lng of paint leyer end conetruc:tlon
hendllng acllvltle.. 0' n- extraction well. and .
'orcemaln. Potential threa" In-
clude VOC rele..e. removal of
pelnt leyer and conatructlon of
n- extr8cllon well..
WOrke; Protection Not appllcabf.. limited expo.ur. potential due Oreate.t~tentl.1 'or expo.ure Sam. .. Altematlve 2. Same a. Altamatlve 3.
to VOC releese during ISVE due to V volatilization duro
construction Ing excavetlon and treatment of
soil,.
TIme Until RAOI are Analned Not applicable. Two month. for paint leyer r. Same a. Altamatlve 2. How- Two month, for paint ~ar No Same a. Altematlve 4. How.
medl.tlon; ISVE remedl.tlon 12 ever, maJor~ of 1011 ramedl. mediation; .011 ramedla Ion 12 ever, maJ::J; of .011 ramedl.
months; groundweter treatment tlon eccomp i.hed within 6 month.; groundwater treatmenl lion accomp I,hed within 6
'or:!: 40 yea,.. months. 'or :t: 40 yean. month..
-------
TABLE: 7 Page 2 of 3
COMPARATIVE EVALUATION OF FINAL ALTERNATIVES
Main SIreel Wen Field Site
Elkhart, indiana '
CrRerta Allemetlve t Allemetlve 2 Alternallve 3 Allernatlve .. Allematlve 5
lONG-TERM EFFECTIVENESS
AND PERFORMANCE
Magnitude or Rnldual Flak EJd8tIng ria, Nmalne. Anemetlve"ea" IOU hot .poII Altamatlve .,....I0Il hot .pote Same .. Alternative 2. Same .. Altamatlve 3.
vlalSVE. Clean-up level. of 10 vial TTD and ISVE. Clean-up
uglkg In .011 for COC ahould level. of detection Imltl are
be e"alnable. profected by L TTD for COCo
Adequacy and RenabOn, of Con- NoIeppRoable. Souroe control of 1011 hot .pot. Same .. Altematlve 2. Source oonIroI of 1011 hot IpotI Same.. Altamatlve 4.
trola 18 approprlale for provldlnv. In conluncllon with new ground-
80ma control; however, ax 8" wat" ntllfOapior 'Y.etem pr~
Ing groundwater Interceplor vld.. beet proca88 control of
and production wen. do nol op- groundwater plume mane~
I'mlle groundwaler plume men- menlln addRlon, great"
agement blllty In operating air .trlpper
unit proce...
RedUGtlon or Toxicity,
Mobility, and Volume
Tr~nt Proc... Uaed None. Groundwater axtractlon by ex. Groundwal" e..ractlon by ex. Oroundwater extraction by new Groundwater extraction by new
1811ng Interceptor and produc. Isling Interceptor and produo- Interceptor well network and Interceptor well network and
lion well. and trealment by elr lion wen. and Irealmen! by air Ireatment by modified air ~ treatment by modified atr etrIp.
81rlpper. Pelnt le~er excavated, alrlpper. Palntl~er e.clVated, per. Paint layer exclIY8ted, per. Paint layer e.cevated,
. transported off.. e and Inclner- Iransported off.e e and Inclner- "aneported off.elte and Inolner- traMported off..ne and inciner-
ated. Soli hot r" to be eled. Soli hot '~I' e.llled and ated. SolI ~.. to be aled. Soli hot 'rrt. excavated
treeted by ISV . treeled ~ lTT on-.lte. SoUa treated by and treated ~ TTD OfHlte.
not readl exoavated to be Sol.. not re ~08Vated to
trealed by ISVE. be "eated by .
Amount Deatroyed Of Treated None. 60 01.' of paint layer dtetroyed Same.. AIIematlve 2, e.cm New Interceptor :r,:"" .. angt. Same.. Alternative ", eKCIJ:
by 0 -I"e Incineration. Soli hot eoll hol.pol. treated vlel D neered for provld ng control of eoll hot .poIIlreated vi. L D.
.pol. Irealed via ISVE ex- end ISVE for under bulldlngl. groundweler plume. Reduced
I,ecled from 1011. length of R..lduale requiring dle,.alln- .011 hol .p0t8 tr..Ied via ISVE.
groundweler tr..lment la ~ 40 clude conden"Ie and ner Comblnallon of loll eource con-
yee,. due 10 .ource conlrol of cake from LTTD. Irol end efficient extraction 'Y.
soli hot .pot.. lem deerea... groundwater
Ireatment period to 40 yaa,. at
1.28 MOD.
Reduction of Toxicity, Mobility, or None. ISVE reduce. volume of con- L TTD reduce. volume of con- Same .. Altematlva 2. Same .. Alternative 4, excepl
Volume lamlnenl.to ~OUndweler. Tox- lamlnanl810 t:undweler. Tox- L TTD r"ldua". eon YOfume,
Iclty reduced air .trlpper Iclty reduced elr .trlpper and mobility of contamlnent..
procell. proc....
-------
TABLE 7 Pege 3 of 3
COMPARATIVE EVALUATION OF FINAL ALTERNATIVES
Main Slr881 Well Field SII.
Elkhart, Indl.na ,
Crllerla AIIernatlve I Alternative 2 Altematlv. 3 Allem8llve .. Alternative 5
T~pe and auantllv 01 Re8lduall None. Soli re.,duII.. lTTD generat.. oondenlate ftI. Same - AhrnatIve 2. Same II Alternative 3.
A er Treatment ter cake and oarbon, which r.
quire. eII'poIal 0110111
r..'duall.
SlaMory Pre'erence for Tre8fm8nl Doee not ""afy. Setl.nel groundwater and I0Il Same - Alternative 2. Same - AIternaUv8 2. Same II Altem8l1ve 3.
. hot.pot ellmentl 'or providing
Irealment A prtnclpel element
10 addre.. the prlnclpa' threetl
at lhe Ille.
IMPlEMENTABllnY .
Ability 10 Con8truct and Operate. Not appRcabl.. Com!:,","" oIallematlve SlIe conatralnta and permfttlng Same - Allem8IIve 2. In 8dcfI. Same .. Allem8l1ve 3. In add!-
8hou d be reldlly Implement- IIIu.. mey hIVe problem. and tlo", new Interceptor :tatem lion, new Interceptor :tttem
able. lor delay.. and modlfloetlont to ItrlP. and modIfIc8flon. to a ttrtp.
per .houtd be II.,. to Imp... per lhould be ea.,. to Impl.
ment ment.
E..e of &pan,'on Not appRcable. Same 88 Altematlve 2, In addl- Not readily adactlble. Same II Alternatlv.2. Sam. II Allematlve 3.
lion ISVE can be moved, ell. Remoblllzatlon . alltreme~
panded. remobilized al compllcaled and not pracl cal.
nece..~ Only IImllatlon to
ISVE 18 Ilea" chemical prop-
ert'.. 0 COCo
Ability to Monllor Effective"", Not appDca&I.. Verlfloatlon of tn..llu proc...e. Soli monitoring and groundw.. Same II Alternative 2. Same a. Alternative 3.
I. more dlfflcuh. ler monhorlng are eal'ly accom-
plilhed.
Ability to Obtain Approvale and Not appDcable. AIr dlscherge '"ue. .pecIDc to Same a. Alternative 2, In add!- Same II Alternative 2. Same II Allematlve 3.
Coordinate with Other Agencl.. e'nt layer ellclVetlon need to lion, win require coordlnallon
addre88ed. with local government 10 en-
lure acceptability o. l TTD.
AvaDabRIIy of Equipment and Not appRcabl.. Service. and equIpment avan. Service. and equipment ava'l- Same II AII.mallve 2. Same II Alternallve 3.
T echnologlel eble. ISVE will requIre coordlna. able. l TTD wlR require coordl.
lion wllh vendors. nallon with vendors.
~
Capllal Coat None. $t ,210,000 $5.890,000 $1,470,000 16.160.000
O&M Colt Not appllc8bl.. $170,000 $170.000 $130.000 $t3O,000
Present Worth COIl. Not appIlC8bl.. 13.820,000 $8.500.000 $3,370,000 $8.050.000
. .
-------
Structural
functional
Groups
,:':':::9.:~,~;~~:R,~:::::;i!:::::;:';::;h:::
Halogenated
Non-Polar
AromItics
DiaxIn8
PCBs
HeItIicId8s
HaIog8n8I8d
Phenols '
HaJogel'lli8d '
AIipha1Ics
~
Nit! at8d
Aromatics
Heterocyclics
Pclynuc:lear
Aromatics
Other Polar
Organics
i a/so '""Y ~ Imd ""M1I ",4luaring ""lUll willa ,.,/iuM1y IDw Wv.u Df tHJIII1Iia IM1 ~ ~~11 -d Wour All immDbi/iz,arion
procus,
.. Orh.u II'MO/O~S nvry ~ UStd if lrttJUJbibly ftU~S or otAe, i.1IformMioft indictlUs tJwu IAIy CAlI tlc#&i.rw tAr Aursuuy concrnt'tJt;on or
~"e1lJ-"dJJc1J/)" 'lUIft,
0.5 - 10 100
0.00001 - O.DS 0.5
0.1 - 10 100
0.002 - 0.02 ,02
0.5 - 40 400
0.5-2 40
0.5 - 20 200
2.5 - 10 10,000
0.5 - 20 200
" .0.5 - 20 "'.":-":. 400
0.5 - 10 ,100
::'!;::':':'?!:icia;.::,:::::'!j::!j::;:::'H':;"i';!:j::';iiaSf';\i:i:";i:,,':.,,.:::::;:,
0,1 - 0.2 2
0.30 - 1 10
0.1 - 40 400
0.5 - 6 120
0.5 - 1 20
0.005 0,05
0.2 - 20 200
02 - 2 40
0.1 - 3 300
0.0002 - 0.008 0.08
-------
19
Sampling of the paint layer indicated the presence of TCE, xylene
and-lead. The sampling data, however, was limited and additional
characterization of the paint layer will be required in the
design phase in order to determine the presence of additional
functional groups. It is expected that, at a minimum,
halogenated aliphatics (e.g., TCE), halogenated non-polar
aromatics (e.g., xylene) and lead will be amongst the functional
groups used to determine treatment standards and technologies. .
Using the limited data available from sampling of the paint
layer, the treatability variance would be applied as follows:
Constituent Concentration
~
Treatment Level...
TCE
xylene
88 ppm
2,300 ppm
40 ppm
100 ppm
95-99.9' red.
90-99.9' red.
(lead was not measured by TCLP, so it is not used in this
- example.)
The paint layer will be removed, sampled for the full target
compound list and, based upon the results of that sampling, it
will be taken to a facility capable of the treatment
technologies and treatment standards identified in Table 8 for
disposal. Should the constituent concentrations be measured at
less than the concentration range provided in column 2 of Table 8
prior to any treatment, no treatment will be necessary prior to
disposal in a RCRA Subtitle C facility.
The Agency intends to grant a treatability variance for the paint
layer under 40 CFR 268.44 to comply with RCRA LDRs unless public
comment following release of this ROD overcomes the presumption
that a treatability variance is appropriate for this waste.
Since paint layer removal is required for alternatives 2 through
4, the above analysis applies to all alternatives except no
action. .
With the use of LTTD, the excavation and movement of these soils
from their current location for treatment and
rep1acement/redisposal at the same location will trigger the
applicability of RCRA LDRs. The treated soils will still be RCRA
listed wastes because any solid waste derived from the treatment,
- storage or disposal of the RCRA listed waste is a RCRA listed
waste. LTTD treatment of the soils, however, would meet the LDR
treatment standards for TCE under 40 CFR Part 268, Subpart D and,
therefore, could be disposed of at the location from which they
were removed.
The Hazardous and Sold Waste Amendments of 1984 (HSWA)
established minimum technology requirements for disposal of RCRA
hazardous wastes into new land disposal units. These technology
-------
I .
20
requirements would not be triggered upon redisposal/replacement
of the LTTD-treated soils because no "new" unit would be created.
RCRA closure requirements at 40 cn Part 264, however, would be
triggered by the replacement of the soils into the pre-existing
unit. Implementability of RCRA closure would be very difficult.
due to the large volume of soil and restricted space at the site.
The Agency would consider de-listing the waste.
This LTTD ARAR analysis applies to alternatives 3 and 5.
. ,
RCRA LDR treatment standards do not apply to soil treated in-
situ. RCRA LDRs will not be triggered by alternatives 2 and 4.
RCRA regulates air emissions from process vents at 40 cn 264
Subpart AA. These regulations are neither applicable nor
relevant and appropriate because CERCLA waste management
activities are considered, as a group, to be fundamentally
different than those RCRA regulated hazardous waste treatment,
storage or disposal facilities for which the Subpart AA
regulations are applicable. See 55 Fed. Reg. 25458, 25459 (June
21, 1990)..
Both the ISVE system and the air stripper produce emissions
subject to regulation under the Clean Air Act (CAA). Under the
CAA, EPA has promulqated National Ambient Air Quality standards
(NAAQS), National Emission Standards for Hazardous Air Pollutapts
(NESHAPS) and New Source Performance Standards (NSPS).
NAAQS have been promulgated pursuant to section 109 of the CAA
for particulate matter and ozone from "major" sources. States
translate these ambient standards into source-specific emission
limitations in which upon US EPA approval become incorporated
into federally enforceable state Implementation Plans (SIPs).
Under the Indiana SIP any new source with a potential of
emitting 25 tons' of VOCs per year must be used in conjunction
with the best available control device to reduce 'emissions.
Neither ISVE nor the air stripper constitute a "major source"
under the CAA. Under the Indiana's SIP (APC-19, February 16,
1982) and under the current Indiana air pollution regulation 326
IAC-2-1-1(b) (2) (D), registration is required for sources of VOC
air emissions which have the potential for emitting 3
pounds/hour, 15 pounds/day, or 25 tons per year. Such
registration requirements may result in the use of emissions
controls on sources which exceed these limits. It is anticipated
that implementation of any treatment alternative would fall below
these emission standards. However, such estimates will be
verified in the design phase and controls will be used if
required.
Pollutants for which no NAAQS exist, but that cause or contribute
to air pollution that may result in serious illness have been
identified by EPA under the CAA Subsection 112 and are called
-------
21
NESHAPS. The only pollutant at this site for which a NESHAPS
exists is vinyl chloride. See 40 CFR Part 61, Subpart F. The
emission standard for vinyl chloride plants is 10 ppm. While
this standard is not applicable because none of the treatment
technologies meets the definition of a vinyl chloride plant, it
is relevant and appropriate. All treatment alternatives will
satisfy this requirement, particularly since the amount of vinyl
chloride at the site is very low.
The NSPS are technology-based standards which are neither
applicable nor appropriate to the pollutants and chemicals at
this site.
Alternatives 4 and 5 require construction of a water main across
Christiana creek. Therefore, these alternatives must assure no
loss of floodplain or wetland area in accordance with Executive
Orders 11988 and 11990.
The SDWA requires the establishment of standards to protect human
health from contaminants in drinking water. Maximum Contaminant
Levels CHCLs) for specific contaminants have been promulgated ..
under SDWA. Additionally, SDWA maximum contaminant level goals
(HCLGs), which are non-enforceable health-based goals, have been
set at levels at which no known or anticipated adverse effects on
the health of persons is likely to occur. The NCP requires that
non-zero MCLGs shall be attained by remedial actions for water
that are current or potential sources of drinking water, where.
MCLGs are relevant and appropriate. See 40 CFR
300.430(e)(2)(i) (B). More stringent standards than MCLs may be .
appropriate for ground water used as drinking water when multiple
contaminants and/or multiple exposure pathways may not be
protective of human health and the environment. Ground water
cleanup standards for this site have been set lower than the MCLs
in order to achieve a residual risk level of 1xlO-S across all
media. See the detailed description of the selected remedy for
explanation of the ground water standards.
Balancing Criteria:
Short-term Effectiveness:
This evaluation criterion addresses the effects of the
alternatives on human health and the environment during
construction and implementation. All of the alternatives, with
the exception of no action, involve excavation and off-site
treatment/disposal of the paint layer waste, as well as treatment
of contaminated ground water in the existing air stripper.
Alternatives 3 and 5 would have significantly greater short-term
impacts than alternatives 2 and 4, such as excavation related
dust, handling of contaminated soils and disruption of existing
businesses. In addition, excavation of soil near the buildings
would require bracing and building support. Therefore,
-------
I .
22
.
alternatives 2 and 4 would have less short term adverse impacts.
Long-term Effectiveness and Permanence:
The evaluation of alternatives under this criterion address the
risk remaining at the MSWF site at the conclusion of remedial
actions. The no-action alternative provides no long-term
effectiveness and would result in continuation of the elevated
10-4 risk levels that currently exist. The two treatment
technologies considered in alternatives 2 through 5, ISVE and
LTTD, are radically different in their approach, but are capable
of achieving the same cleanup standards.
In evaluating the time required until remedial action objectives
are met, consideration should be given to the time necessary to
remediate individual elements of the alternatives as well as the
entire site. For the MSWF site, it is impossible to
quantitatively project the precise duration of the pump and treat
element of the various alternatives due to the complex
interdependence between the soils and ground water. However,
qualitatively several conclusions pertaining to duration of
e. ground water cleanup can be drawn. First, the no action
alternative would result in the indefinite, and perhaps
. perpetual, contamination of the MSWF aquifer. Alternatives 2 and
3 will result in cleanup of the East side aquifer portion in
approximately 5 to 10 years, but the well field will remain
contaminated. Should contaminants other than VOCs become a
future problem, there would be no containment before affecting
the well field, at which point the cost of treating a more
dilute, higher volume problem would be expensive. Alternatives 4
and 5 provide for plume containment before reaching the well
field, thus allowing well field restoration within a few years.
Reduction of Toxicity, Mobility and Volume:
This evaluation criterion addresses the statutory preference for
selecting remedial actions that employ treatment technologies
that permanently reduce toxicity, mobility or volume of the
untreated waste. The no-action alternative provides no reduction
of contaminant toxicity, mobility or volume. Alternatives 2
through 5 require removal of the paint layer. Compliance with
the soil and debris variance will dictate the type of RCRA'
facility which will be acceptable for treatment and/or disposal.
Both ISVE and LTTD will reduce the VOCs contamination in the
soil, thereby permanently reducing the toxicity and volume in the
soil. ISVE would be capable of treating the VOCs to the cleanup
standards in-situ with an efficiency of approximately 99.4
percent. It is estimated that up to 1,000 pounds of VOCs may be
extracted from the soil. The LTTD removal would achieve
approximately a 99.99 percent reduction in VOCs of the treated
soil. In combination with ground water treatment, the treatment
-------
23
efficiency of either technology will achieve the VOC standards
set by this ROD.
Ground water treatment can address contaminant mObility. The
well field is not a perfect hydraulic containment system in that.
contaminated ground water does escape the capture zone and flow
south beyond the well field. Alternatives 4 and 5 which include
West side interceptors, would not only prevent contaminant
migration into the well field, but beyond that toward the St.
Joseph River as well. Alternatives 1, 2 and 3 would allow the
contaminant migration to continue to the well field and beyond to
the river.
Implementability:
This criterion addresses the technical and administrative
feasibility of implementing an alternative, and the availability
of various services and materials required for its
implementation. The technologies considered, which include LTTD
and ISVE, are available from commercial vendors. However, site
limitations including confined working areas in close proximity
to residential areas at the treatment site and general disruption
make implementation of LTTD far more difficult than the ISVE soil
treatment alternative. LTTD once mobilized, must be used to the
fullest extent at that time since remobi1ization is costly and
not as flexible. ISVE is more flexible in that it can be readily
expanded and can be adapted to other areas if necessary.
The air stripper is already on-line and performing as designed.
The additional interceptor wells on the West side are readily
imp1ementable.
Cost:
Alternatives are evaluated for cost in terms of capital costs,
operation and maintenance cost (O&M), and present worth cost.
The present worth analysis is used to evaluate expenditures that
occur over different time periods by discounting all future costs
to a common base year. For cost purposes of this project, 40
years has been assumed. This is slightly over the standard 30
year projection because pumping of the interceptors on the.West
side and treatment via the air stripper would be required until
the sources are identified and controlled or until they diminish
through natural processes - an undefined time frame. As the well
field and East side aquifer area is restored, flow to the air
stripper will be reduced and operation and maintenance (O&M)
costs will be reduced. The costs assumptions for West side
interceptors remains the same fo~ both alternatives 4 and 5.
Cost estimates for the paint layer removal assume off-site
incineration. This is a relatively high cost per soil volume
alternative relative to the ISVE cost per soil volume. Cost
-------
24
assumptions for this element of the remedy are the
alternatives. Due to the uncertainty in extent of
beneath the buildings, the feasibility study costs
considered lower bound estimates.
same for all
contamination
are
Alternatives which include LTTD (3 and 5) are more costly than
those which rely on ISVE exclusively (2 and 4). Of the
alternatives which include West Side interceptors (4 and 5),
alternative 4 is less costly. Capital, operation and maintenance
and present worth costs are summarized at the bottom of table 7.
Modifying Criteria:
. state Acceptance:
IDEM has been involved throughout this RI/FS and supports the
selected remedy.
Community Acceptance:
Community acceptance of the selected remedy is discussed in the
responsiveness summary attached.
IX.
The Selected Remedy
The selected remedy will reduce the threat from contaminants at
the site such that the total excess cumulative carcinogenic risk
from exposure to all media do not exceed lxlO-S.
Based on the RI/FS, and using the comparative analysis of
alternatives described above, USEPA has selected alternative
the most appropriate remedial action at the MSWF site. IDEM
concurred with selection of alternative 4. A flow chart and
conceptual site diagram are shown in Figures 8 and 9
respectively. .
4 as
has
Components:
Implement ISVE for the treatment of VOCs in the contaminated
soils in the East side hot spots.
Excavate and treat and/or dispose of the contaminated soils
associated with the identified paint layer source area(s) at
an off-site facility in compliance with State and Federal
regulations.
Construct new interceptor wells (1-3 and 1-4) to the west of
the well field to contain the plume, construct a new force
main to connect the new interceptors to the air stripper,
maintain the air stripper and its ancillary support system
and monitor.
-------
"'IGURE 8
COMPONENTS OF ALTERNATIVE"
Main Slmt Well Field Site
Elkhort, Indlona
eontlmlnlled Soli Areal
IA, 2A, 4A, 5A, 61\ In-Sha Vlpor I!rtndlon Off .Glses
(0.97 Acres)
OrJlnlc Contlmlftlnl.: . Rlsb In Acuptlble RInge .
. TCE: ND - 29,000 ppb
Elthlu.1 GI.
L. Risks in AcceptAble Rance '" Lone Term O&:M
ConIJlmlniled Groundwllef Inlm:eptor Wells Trealed Emuenllo City 01 . Oroundwlter Monllorlne
- Air SI ripper Elkhart Polable Waler $1,470,000 C8p1181
(1.28 MGD) II, 12, 13, 14 -
Syslem $130,000 OItM
Organic Chemicals: Ambienl Air J- $3,370,000 Presenl Worth
. PCE: 13 ugn
. Tee: 189 u&/1
. I,I-DCE: I hili , Residua" Rlsb:
. Vinyl Chloride: < 1 0111 . Currenl Scenario IIItT'
. FUlun: Scenario 4110.1
,
Palnl L8)'a' Etavallon - Traftlporlliion OR.Slle Indnerallon
(60 CY)
Organic Chemical.:
. Xylene: 340-2400 ppm
. TeE: ND - 88 ppm
. Acelone: 100 ppm
. $19.5,000 CapillI
lime Unlil Cleanup Goal Met
Paint L8yer. 2 Months
I SVE .12 Months
GroundwRler. 20 Yan
.
-------
"
I "
. i / I - -. "
f.#JY I J " '. - -
:;,. I ,- -'... ". 0: to
'."" .T. -- -._--
! /' I ", ......d ~ ;; 1:"" II08N .
~:- -_J i ~(/ / ,<- ' ", II :;! BlOWERS A~:~~l rEo.. ----:-'
-', / ; "'" ' -" '---., -j IPIoIENT I
~~/ ; ./ .:~,~:. . . . . . . - . . I f---..t'~>. I "!:- --..~'. .D~- J I
~/" l l "> '-, .. ".. . '--.! l 6 - 0.____..- -. .- I
.~ ' II ' ,'.. . ;.." , - n, ..,-- ~. : . _..
./ ' ",A' II '.-, -., .. "" ' ' ~
! /.:" r (' (; -:;:"J:R'N. EX~t.tNG ...- ,. I: XCEl {ow." . I l~ I
(' { PPER. ~t"T£ . J I- I 0
, ....., \. ' ( ". "II - I . , ~ I ~ II.
, !. '\ '. '\.::1.,,.:C. >\...- "\. .ATEII AllEA '. ' AU CA rc.' ~ :~ 11:E :
\ \: ",,' - --- '. \... r=-''''tO!<.io£ ' ' REIIO .- i ' ~.:s.
\\ ~ I '..' \,,J T~, REA A L:~~~ - : ~
.. \\ _._~ ~41r ,I!TOR ~, ':-;! <:. .:.. r . - ~. -;:
~~~--.. ':\ t~ )' '--;/-'7 1/"" ' ,,/~t;JJi. .-£'.::Ql
"" ' ,(--'~"J<'" -,., " ,- . - ~
. \ .Jr" ""'-,.. l )(~?/~~' . ..>,,::- ,_...~<-;..> ,'-~~' .--
.::,:;;;,:.:... ..~ .._~ ", ,.: / -- .G:, A.." :-- :::>'jf ',' :~<1t (
, ' - " -- =-,-=-c,c. ::::'. / - ' ,- 1 ,I""~'
..0 \ \3000 !:frUIN.EX' T" " ,..;. ", " " ".-
.,T_,_---'::"" ~ <<:-.... ""- - -' ..__..----- EXlSTlNGI AlA STAIPPE] I ---'-1
- .~----"l I~'=:>'\\~>Z~'! 4+., Ii--'- ----==~-:1 f' =:. ,.I : .~~ ~.F~~!ri J L '. J I
~.. I \\ '-<-.;:""::'" -Ii-' ~~~ J -.,., '-------, ,~=:~=,".J..._-' 0-
I ., -- ,,"::... -, '(. VlV\ I _u_-.--.
,: ..'" ' ' .. - -
1/1' .'\ ["" " or. ,01' I
- -- -----1 L- . . " '. G I ~~'!i I ~... .
~_._- -.--.--.--:.\, "'- L c.1 ~
-;:. " --- ---.--'- ._-~ --- J:..: ~
~ I -\"'\\li -~-----:;~ /-=.: - ---..!. ~~l.tJ u ..t
::; , ,,&{1f<),P '\ Y'" --..- ,,-,,-_._'-~-'
-'\f'W!-",\.V ' \ ,'---" .-
----.,.------- \ \
. _'0\ .,---
...-...." .
FIGURE 9
Alternative 4
Site Layout
-------
2S
r
- -
Place deed restrictions on the installation and use of
potable water supply wells on the East Side properties until
50il and ground water goals are met and sustained.
Implement a ground water monitoring program to demonstrate
compliance with the cleanup standards.
Rationale:
All alternatives, except no-action, are protective and comply
with ARARs. Therefore, alternatives 2 through S pass the
threshold criteria. Of the alternatives involving treatment, the
ISVE alternatives 2 and 4, are less costly than 3 and S for the
same level of performance as measured by their ability to achieve
the cleanup standards. ISVE requires less disruption to
businesses and community for implementation and is more flexible
in that it can be readily expanded on-site. Given that, there is
no inherent advantage in use of the LTTD technology at this site.
Alternatives 2 and 4 differ in their inclusion of West Side
interceptors. Under alternative 2, contaminated ground water
continues to be drawn into the well field. Although several
production wells are routed to the air stripper, the influent
concentration to the air stripper is low. For the same, if not
lower operating cost, a lower influent flow with a higher
contaminant concentration could be achieved while at the same
time preventing continued contamination of the well field. Since
hot spot areas of contamination on the West Side have not been
identified, it is unknown how long this contamination will
continue. In addition, the location of the well field in an
industrial area makes it vulnerable to future contamination with
very little response time should other contamination problems
develop. Thus, West Side interception wells provide greater long
term protection. The MSWF study area constitutes a class 2A,
current use aquifer. Plume interception is consistent with the
Agency's intent .to restore aquifers to their highest beneficial
use in a reasonable timeframe. For these reasons, alternative 4
is selected as the most protective and cost-effective remedy.
Description:
A minimum soil estimate for vapor extraction is 22,000 cubic
yards. Volume estimates will be refined in the design phase.
ISVE is easier to implement and does not trigger RCRA LDRs
because the waste is treated in-situ. The paint layer is
considered a listed waste under the RCRA derived-from rule.
Additional characterization will be required during the design
phase. With high concentration of xylene and lead, this waste
may also be RCRA characteristic. The paint layer volume is
estimated at 60 cubic yards, assuming the disposal area
identified beneath the building received the same waste streams
as the disposal area outside the building. ISVE is not a
-------
26
separation technology for mixtures and will not be able to treat
this waste stream. Leaving the paint layer waste in place
would fail to satisfy RCRA closure requirements, would not meet
the cleanup standards, nor would it provide long term protection.
Therefore, it will be removed and disposed of in accordance with.
RCRA. .
The existing air stripper does not have air emissions controls on
it. Existing air emissions do not exceed risk levels at design
concentrations and emissions rates. This remedy, including
higher influent concentration as a result of the West side
interceptors, and ISVE, is still not anticipated to exceed the
state and federal regulatory levels at which control equipment
could be required.
The remedial action objectives are translated into cleanup levels
for soil, ground water and air as follows:
Cleanup standards for the soil, ground water and air on the East
Side are selected at a 1x10-5 level based on potential future
use. The 1x10-5 level is very close to standard analytical
detection limits for ground water, therefore, its achievement can
be reliably measured. At this cleanup level, the soil
remediation is expected to achieve ground water protection in the
10-8 range as a single pathway, prevent soils from further
contributing to ground water contamination and is achievable with
the selected technology. The following table shows the range
from which the cleanup standards were selected.
Ground Water (ppb)
CUrrent Worker
10-4 10-5 10-6
Future Resident
10-4 10-5 10-6
TCE
PCE
Vinyl Chloride
10
5
4
1.0
0.5
0.4
0.1
0.05
0.04
10 .
6
3
1.0
0.6
0.3
0.1
0.06
0.03
~ (ppb)
TCE
PCE**
Vinyl Chloride***
*
800
80
*
100
10
*
**
***
TCE baseline risk not less than 10-4.
PCE baseline risk not less than 10-6.
Vinyl Chloride not detected in soil.
Soil cleanup must achieve 100 ppb (or better) of TCE.
Interceptor wells must continue to operate until the following
ground water standards are met on the East Side:
-------
27
T~
p~
Vinyl Chloride
1.0 ppb
0.6 ppb
0~3 ppb*
* The acceptable vinyl chloride standard may be modified
slightly based on best available analytical detection limits.
~e West side interceptors must continue to operate until the
plume entering the well field from the west no longer poses a
cumulative contaminant risk of greater than lx10-6. This is
consistent with the ROD for operable unit 1 and is appropriate
for the West Side given that without a known relationship between
source and ground water, contaminant-specific standards cannot be
selected.
It is expected that soil cleanup in combination with the existing
ground water treatment provided by the East Side interceptor
wells will restore the ground water to the cleanup standards.
Ground water monitoring is needed to ensure that cleanup levels
are met and maintained. Deed restrictions will ensure that
exposure does not occur until cleanup levels are reached.
Air pathways risks were calculated based on the percent of total
site risk contribution from the air stripper and ISVE under
assumed air flow rates. Air emissions from the air stripper and
the ISVE units were evaluated for potential impacts to receptors
and to identify whether vapor-phase carbon adsorption treatment
may be needed on these units to reduce risks to an acceptable
level. At assumed flow rates, emissions would be limited by the
following table. For example, both the air stripper and ISVE
would require state registration under the SIP for mass
discharges in excess of 15 lbs./day. Such registration mayor
may not require emission control measures. If controls are not
required by State regulation, emissions can continue uncontrolled
until the site risk based contaminant emission mass is exceeded.
The table below shows that TCE emission mass would need to exceed
58.06 lbs./day in order to trigger controls based on risk.
Similarly, the ISVE would require an emission mass of 31,765
lbs./day before controls would be needed based on risk.
Air Striccer
Constituent
Mass Discharge (lbs./day)
lxlO-5 risk ~ ~
TCE
PCE
1,1-DCE
Vinyl Chloride
58.06
3.89
4.17
< 0.26
137
total
VOCs
15
total
VOCs
-------
28
DB
Constituent
Mass Discharge (lbs./day)
1xlO-5 risk ~ lIE
TCE
PCE
31,765
1,177
137
total
VOCs
15
total
VOCs
MSP - Major Source/Modification Permit limit at 25 tons/year
SIP - State Implementation Plan Standard at 15 lbs/day
..
The maximum discharge from the air stripper is expected to be
less than 3 lbs./day total VOCs based on expected treatment
efficiency and treatment system flow rate. The maximum discharge
from the ISVE system is expected to be less than 2 lbs./day. In
both cases the discharges will be well below the risk level of
10-5.
Some balancing of contaminant emissions mass and rate between the
ISVE- and air stripper can occur. Therefore, projected emissions
will be reevaluated during design. Regardless of design
estimates, precise estimates for ISVE emissions cannot be made
due to the limitations inherent in accurately measuring soil
concentrations with existing sampling and analytical techniques.
Therefore, offgas from ISVE will need to be monitored initially
for comparison to acceptable levels.
Some changes may be made to the remedy as a result of the
remedial design and construction processes. Such changes, in
general, reflect modifications resulting from the availability of
more detailed information in the design phase.
Statutory Determ~nations
Protection of Human Health and the Environment:
The selected remedy provides for remediation of site-related
chemicals in soil and ground water on the East Side. Use of ISVE
allows for unrestricted access to the land after remediation and
allows for aquifer restoration. Removal of the paint layer-
. allows for unrestricted use of the property after -implementation
of the remedy and it provides long-term protection. Continued
use of the air stripper ensures a safe source of drinking water.
Installation of the West Side interceptors allows restoration of
the well field to its highest beneficial use, contains the plume
outside the well field, and protects against long term
uncertainty.
Compliance with Applicable or Relevant and Appropriate
Requirements:
-------
29
The selected remedy will meet all identified applicable, or
relevant and appropriate, Federal and more stringent state
requirements. ARARs are listed on table 9 and discussed in the
comparison of alternatives section of this ROD. No ARAR waivers
are required as discussed earlier. However, a soil and debris.
treatability variance may be used for the paint layer to satisfy
40 CFR 268.
Cost-effectiveness:
ISVE in alternative 2 and 4 is a less expensive means of"
achieving the same level of performance as LTTD in alternatives 3 -
and 5. The capital cost of ground water interception on the West
Side remains the same for all alternatives, as does removal of
the paint layer. All costs are estimated over a 40 year period.
The volume of ground water requiring treatment decreases over
time with alternatives 4 and S, although the capital expenditure
remains the same. A less expensive technology and lower
operation and maintenance costs make alternative 4 the most cost
effective remedial alternative for soil and ground water
remediation and long term protectiveness of the well field.
Use of Permanent Solutions and Alternative Treatment to the
Maximum Extent Practicable:
Alternative 4 permanently reduces soil contamination by using
ISVE. ISVE is still considered an innovative technology. Since
VOCs are highly amenable to treatment, all alternatives except no
action incorporated a treatment technology which would
permanently reduce contamination. Thus, any of the alternatives
would have met this criteria. ISVE eliminates the need for
further treatment of residuals off~site. Alternative 4 presents
the best balance of long- and short-term effectiveness,
implementability, reduction in toxicity, mobility and volume and
overall cost.
SatisfY the Preference for Treatment that Reduces Toxicity.
MObility. or Volume as a Principal element:
This selected remedy satisfies the preference for treatment that
- reduces toxicity, mobility or volume.. Both the ISVE and air
stripping systems reduce mobility and volume in soils and ground
water. However, since both technologies transfer contaminants
into the air, toxicity reduction does not occur. The selected
remedy satisfies the statutory preference for treatment as a
principal element.
-------
La..
Federa I I
SectIon 10 0' the RIver
and Herbor Act of 1899,
ee Amended
E.ecutlve Orders t1988,
Floodplain Managemant,
and 11990, ProtectIon
of Wetland.
CAA; Clean AIr Act 0'
1963. e. Amended
TA8LE
9
COMPARISON OF ARARS FOR EACH ALTERNATIVE
MaIn Street Well FIeld SIte
Elkhart, IndIana
RegulatIon
T I tI e
PermIt. for Structure. or
Work In or Affecllng
Nevluable Weters 0' the
UnIted Stetes
PermIts for DI.ch~rge of
Dredged or FIll MaterIal
Into Waters of the UnIted
States
Procedures for ImplementIng
the RequIrements of the
CouncIl of EnvIronmental
Qual Hy on NEPA
NatIonal EmIssIon Standards
'or Hazardous AIr Pollutants
ApplIes
ProvIde. procedure. for the C.O.E. 'or
revIewIng parmlts to authorIze structures
or work affectIng nevlvebl. .ater,
IncludIng ..etlend ...-.a5.
ProvIdes procedure. for the C.O.E. 'or
revIewIng permtts to authorIze the
dIscharge 0' dredged or 'III materIal
Into navIgable water (IncludIng wetlands),
ProvIdes pollcte. and procedures 'or
floodplaIn management and wetland
protection.
Requires EPA programs to determIne I'
proposed actIons wIll be In or af'ect a
floodplaIn or ..at land.
RequIres all Fedaral proJect., Ilcens..,
permIts, ptans, and 'Inanclal assIstance
actlvltle. to conform to any Stat. AIr
QualIty ImplementatIon Plan (SIP).
Identl'Ies substanc.s that have b.en
de.lgnated hazardous .Ir pollutant., and
for which a Federal Regl.tar notIce has
been publIshed. LIsted substance. Includ.
trIchloroethylene and vInyl chlorIde.
RequIre. that no Owner or operator sh.11
construct or mOdl'y any statIonary source
wIthout fIrst obtaInIng wrItten approval
'rom the Admlnlstretor.
The owner or operator shall submIt an
applIcatIon for epprova' 0' the construc-
tIon 0' any new source or modIfIcatIon
of any eRlstlng source.
SpecIfIes complIance wIth emIssIon stan-
dards. Atso. specIfIes regulatIons tor
emIssion tests and maIntenance and
monItorIng requIrements.
Oe'lnes modl'Icatlon to a statIonary
source and spec I' les t asks that must be
parfonned In the event that a lIIodlf Ica-
t Ion Is lJerformed. ~
~
.
.
.
.
RIAP
A
A
A
A
RiAP
.!
1.
It
It
It
It
II
~
It
It
II
It
It
~
~
It
)(
II
)(
)(
)(
)(
)(
)(
)(
)(
)(
II
It
It
)(
II
)(
II
)(
-------
la..
CAAI CI.an AIr Act 0'
1963, as Amended
\1-
CAA: Clean AIr Act,
TItle I Amendment. 0' 1990
CAAI CI.an AIr Act,
TItle III Amendments 0'
1990
SOWA: Sa'e DrInkIng
Water ACI
SWDA; SolId Waste Olsposal
Ac t as a,nel1dud bv RCRA
0' 1916
TABLE
9
COMPARISON OF ARARS FOR EACH ALTERNATIVE
Main Street Well Field SIte
Elkhart, Indiana
(ContInued)
Regulat Ion
Title
Natlonat EmtS.'on Standard.
'or Hezardous AIr POllutants
Federel Ozone Measures -
Control Techniques GuIde-
lInes fOr VOC Sources
Hazardous Air Pollutants-
Oe"nlttons
Natlon81 Prlmarv DrInkIng
Weter RvOulsllons
Identl'lcatlon ,,"tJ Listing
Hazsrdous Wasle
Standards Applicable to
Generators of H~zardous
Wasle
Applies
Prohtblt. conc.allng .mlsslons.
National eml.elon standard 'or vinyl
ChlorIde. Appl'.s to plents whIch Pro-
duce ethylene dIchlorIde, vInyl chlorIde,
process, and/or one Or mora pOlymers con-
taInIng any 'ractlon 0' polvmerized vInyl
chlorIde.
Specl,tes standards 'or pumps, compras-
sors, pressure reI Ie' devIces, samplIng
connectIon systems, open ended valves or .
lInes, valves, 'Ianges, and other con-
nactors, product aCcumulator ves.als,
and control devlc.s Or systems that ara
Intendad to operete In the volatile
hazardous aIr pOllutant (VHAP),
Establl.hes test methods and Procedura.,
recordkeeplng requirements, and reportIng
requirements thet an owner or operator are
sUbject to when a VHAP Is Involved.
WIthin 3 y.ar. a'ter the date 0' enactment
0' the CAA Amendments 0' 1990, the
Administrator shall "sue control tach-
nlque. guidelInes 0' statIonary .ource.
0' VOC emissIons
Congress established an.lnltlel lIst 0'
hazardous pollutants, Included In the
list are PCE, TCE, vinyl Chloride, and
-ylenes.
EstablIshes national revlsud primarV
drInkIng water regulations 0' MCLs 'or
organIc chemIcals.
Ouflnes those solId wastus which ere
SUbJecl to regulatIon as h~zardous "estes.
Halogunated solvents. to.g. TCE, are lIsted
es F002 compounds.
EstablIshes hazardous waste tfetermlnat lon,
accumulatIon tIme, and recordkeeplng and
reportIng procedur~s for h~zardous waste
generators.
ARAR .
A
RIAP
A
A
*
*
A
A
A:AP
!
Ie
~
)(
Ie
)(
)(
)(
)(
)(
)(
x
}
!
)(
~
)(
Ie
)C
)(
)C
Ie
)(
)(
)(
)(
)(
)C
)(
)(
)(
)(
Ie
)(
Ie
Ie
)(
)(
x
x
x
)(
-------
la.
SolId Waste Disposal
Act as Amended by RCAA
of 1976
CERClA; Comprehenstve
Envlronmenta' Response,
Compensation. and
liability Act
HMTA; Hazerdous Materlala
Transportation Act
TABLE 9
,
COMPARISON OF ARARS FOA EACH AlTER~TIVE
Main Street We'l Field Site
Elkhart. Indiana
(Conttnued)
Aeguletlon
Tit Ie
~tenderda Applicable to
Transporters 0' Hazardous
Waste
land Disposal Restrlctlons-
Prohibitions on land
Disposal
land ~ISposal Restrlctlons-
Treatment Standards
"atlonal Oil and Hazardous
Substances Pollution
Contingency Plan - Scope
"atlon81 Oil and Hazardous
Substances Pollution
Conttngency Plan - Worker
Ha81th 8nd Sa'ety
"atlonal Oil and Hazardous
Substences Pollution
Contingency Plan - RemedIal
Investigation/Feasibility
Study end Selection 0'
Remedy. Feasibility Study
Hazardous Materials Program
Procedures
Generel Information. Aegul.-
tlons. and Definitions
Applies
Establishes atandards 'or off-site tr8ns- .
portatlon 0' hazardous .aste I' manl'ested
under 40 CFR 262.
Lists EPA hazardous wastes that are
prohibited from land dIsposal.
Restrtcts wastes from being land disposed
above specl'led concentrations. listed
compounds Includel Acetone. <0.59 ppm;
PCE <0.05 ppm; TCE <0.091 ppm; and Xylene
<0.15 ppm.
The NCP provides 'or effIcient, coordI-
nated. and e'fectlve response to
discharges of 011 and releases of
hazardous substances, pollutants,
and contaminants.
Aesponse actIons wIll comply wIth the
provisions 'or responae action worker
sa'ety and health In 29 CFA 1910.120 8nd
the requIrements, standards, and regula-
tIons of the OccupatIonal Sa'ety and
Health Act of 1970 129 USC 651 et seqJ
10SH Act) and state laws with plans
approved under SectIon 18 0' the OSH Act,
Establishes remedial actIon
specifying contamlnents and
concern. potential ..po.ure
and remediation goals.
objectIves
medIa 0'
pathways,
Aegulates transportatIon of hazardous
materials.
Prescribes the requirements 0' the depart-
ment of transportation governing the
transportation of hazardous materials and
the manu'acturer. 'abrlcatlon, marking.
melntenance, recondItioning, repairing. or
testIng of a packaging 0' a contaIner which
represented, marked, cert If led. or sold
for use In transportlny hazarduus waste.
AAAA .
*
A
A
A
A
A
*
*
!
x
x
1
X
X
x.
x
x
x
x
x
~
)(
)(
)(
x
)(
)(
)(
Ie
!
~
Ie
X
Ie
)(
X
)(
)(
)(
)(
x
)(
)(
)(
Ie
Ie
)(
-------
law
HMTAI Hazardoua Matertata
Transportatton Act
State:
Envtronmentat Management
Act, IC 13-7 (1984 SuPP.)
ProfessIonal and
OccupatIonal Rules
Atr PollutIon Control
Board, lAC Tit Ie 326
TABLE 9
COMPARISON OF AAAAS FOA EACH AlTEANATIVE
MaIn Str.et Well FIeld S'te
Elkhert, IndIana
(ContInued)
RegulatIon
Tit Ie
Hazardous MaterIals Tables
end Hazardoue MaterIals
Communtcatlons Aegulatlons
ShtpperS--General
Requ'rements for ShIpments
and PackagIng
Carr'age by PublIc HIghway
Issuances of Certlf'cates of
Env'ronmental Compatlblttty
Weter Well Drillers
Construction and Operating
PermIt Requirements
OpacI ty LImlta't Ions
Fuglt've Dust EmissIons
ADDIles
ProvIdes tebles of hazardous mater'eta
along w'th thetr descriptIons, proper
shlpp'ng nemes, ctasses, tabela, packag'ng
and other requ'rements.
Deftnes regulated matert.t and thetr
preparatIon for transportatIon.
Prescribes generat regulatIons for the
transportatIon of hazardous mater'els by ,
publIc htghway. Also, provtdes toadtng
and unloadIng requ'rements.
DescrIbes the poltc'es and procedures to
be followed regardtng certtflcates of
envtronmental compatlblttty for facltlttes,
whIch have receIved a construct'on perm't.
SpecIfIes requIrements for water .etl
tnstallattons 'ncludlng well records, .ell
drIlling procedures, tnstallattons spec'-
ftcattons, and mInImum well constructIon
standards.
ThIs rule applIes to any currently opera-
ttng or proposed to operete Source Or
facIlIty whIch has potent tal emlss'ons of
regulated pollutants.
Regulates vIsIble emIssIons emttted by any
facIlIty or source not granted a temporary
e.emptlon.
EstablIshes thet this rule appltes to all
sources of particulate matter to the
e.tent that some portion 0' the materIal
escapes beyond the pronerty line.
AAAA .
*
*
*
AIAP
*
A
AIAP
R:AP
!
1
)C
)C
)C
x
Ie
x
x
~
~
~
)(
)C
)C
)(
)C
)C
)C
)C
)(
x
)C
x
x
x
x
x
x
x
x
)C
)C
Ie
x
-------
Law
Air Pollution Control
Board, lAC Title 326
SOlid Waste Management
Board. lAC T It Ie 329
TABLE 9
COMPARISON OF ARARS FOR EACH ALTERNATIVE
Main Street Well Field Site
Elkhart, Indiana
(Cont Inued)
Regulation
Tltla
Fugitive Oust Emissions -
Emission Llmltstlons
Fugitive Oust Emissions -
Multiple Sources of
Fugitive Oust
Fugltlva Dust Emissions -
Motor Vehicles Fugitive Dust
Sourcas
Volatile Organic Compounds
Rule. - New Facilities;
General Reduction
Requ I remen t s
Naw Source Performance
Standards
E.Isting Hazerdous Waste
Facility Standards.
General Facllltv Standards -
Security
Appllas
Establl.hea the crlterta which de,tne 8
violation of thl. rule. Violation.
tnclude. causing 'ugltlve dust concan-
tratron. gre.ter than 67~ In e.ces. 0'
ambient upwind concentrattons; when fuOI-.
t Ive dust Is comprised of 50~ or more
respirable dust; when the ground level
ambient air concentration e.ceeds 50~
mglcm abova background concentrations
for 60 mlnutesl and when fugitive du.t
Is visible crossing the property line.
Requires that the totat of all particle.
leaving the boundary regardles. 0'
whether from a .Inole oparatlon or .
number 0' operation. .hal Ibe In compl t-
ance with the allowable limits of
3261AC 6-4-2.
Requires that vehicle. traveling on public
roed systems to be constructed so a. to
prevent Its contents from dripping.
sift tng, leaking. or esceplng tha vahlcle
In a manner that would craate condition.
which result In fugitive dust. Thl. rule
applies only to cargo and mud tracked by
the vehicle.
Requires new 'acilities (as of J.nuery I,
1980). which have potent lei eml..lons 0'
22.7 megagrams (25 tons) or more per year
to reduce VOC emisSions using best
available control technology (BACT).
Regulation appllas to plants that manu-
facture ethylene dichloride. vinyl
chloride. or PVC. Specified emlslllo"
standards for hazardous air pollutant.
of any stationary source. Includes
standards for vinyl chloride.
Requires the owner or operator to prevent
unknowing entry. and minimize the possi-
bility for the unauthorized entry of
persons or livestock Ol1to the acllve por-
tion of a facility.
AR~R .
RIAP
RIAP
*
A
*
RIAP
!
1.
)(
)(
x
x
x
x
~
~
!
)(
)(
)(
)(
)(
)(
)(
)(
)(
)(
)(
)(
)(
)(
)(
J(
I(
I(
-------
"'8LE 9
COMPARISON OF ARARS FOR EACH ALTERNATIVE
Main Street Well Field Site
E I khar t. I nd I ana
(ContInued)
Regulation
la. TI tIe Applies AAAA . ! l ~ ! ~
Indlane Occupation Sa'ety H.. I th and Sa'ety Standard. Adopte 'ederal OSHA Regulatlone (29 C'A * X X )( )(
and Hea I th Act, IC 223 1910), but doae not par", I t adopttng or
(1984 SuPP.) en'orclng provlelon. ",ore etrlngent than
US Oept, 0' labor Occupational Se'ety end
He.lth Act 0' 1970.
8ulldlng and Se'ety But Idlng Code. Specl,te. .e'ety etendarde and other * Ie )( )( )(
Regulation., IC 22-11 bul1dtng code..
(1982 Ed.)
Electrical Codes Specl'Ies electrical code.. * )( )( )( )(
MechanIcal Codes Spec" les ",echanlcal coda.. * )( )( X Ie
5011 and MineraI. Re'erred to a. the "land Conservation Act. A Ie )( Ie X
0' 1969, " and Includes Pollution Control I
PluggIng 0' Wells, and Pollution Control
and Wastel Test Holes. Thts act .a.
I",plemented to protect the .ater. and
lands of the etate a9aln.t pollution, and
the lOS8 and Impairment 0' .ater .ources
through .ell control.
Regulations 0' Re'erred to a. tha "Motor Carrier Act 0' * x X X X
CarrIers Generally 1935." this la. regulates route deslg-
nations. permits and certification, regls-
tratlon. contract carriers and other motor
carrIe,. actlvlttes.
A/AP/MAINSTRT/AVO
*
ThIs table may contaIn regulattons .hlc;h ,may I10t meet the technIcal definition 0' ARAlb. but are In'cluded for re'Mreltctt.
A = Applicable;.R = Relavant: AP =
uprl..te
-------
continued
Table 9
To Be Considered Criteria, Advisories or Guidance
OSWER Directive 9355.0-28 on Air Stripper
OSWER Directive 9355.4-02 on Establishing
Levels at Superfund Sites
Executive Order 11988 on Floodplains
Executive Order 11990 on Wetlands
Controls
Soil Lead Cleanup
-------
MAJ:N STREET WELL FIELD
SUPERFUND SITE
ELKHART, :IND:tAHA
/. .
RESPONSIVENESS SUMMARY
x.
RESPONS:IVE:NESS SUMMARY OVERv:rEW
In accordance with CERCLA Section 117, a public comment period
was held from January 19, 1991 to March 22, 1991, to allow
interested parties to comment on the United States Environmental
Protection Agency's (EPA's) Feasibility Study (FS) and Proposed
Plan for remedy selection at the Main Street Well field Superfund
Site. At a February 7, 1991 public meeting, EPA and Indiana
Department of Environmental Management (IDEM) officials presented
the Proposed Plan for the Main street Well Field, answered
questions and accepted comments from the public. Written
comments were also received through the mail.
II.
BACKGROUND OF COMMUNITY CONCERNS
Since the Main Street Well Field is the largest of Elkhart's well
fields, providing 80 percent of the city's potable water, the
issue of providing usable water has been an ongoing concern for
the residents since discovery of the contamination in 1981.
An interim ROD was signed in 1985, providing authorization for
construction of an air stripper. In operation since 1987, the
air stripper has worked to provide the citizens a reliable source
of clean water. Since then, the public has expressed little
concern about the quality of water from the well field.
There has been an overall acceptance of EPA's extensive work
since the air stripper was installed. Since the contamination
comes from many sources, not all of which have been identified,
the work has taken a relatively long time to get to the point of
proposing a final remedy for the site. At the public meeting
held February 7, 1991, the city expressed support for the EPA's
proposed plan. To this date, no citizens have opposed the
remedy.
III. SUMMARY OF SIGNIFICANT COMMENTS RECEIVED DUJUNG THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES
The comments are organized into the followin~ categories:
A.
B.
Summary of comments from the community
1. Mr. Gary Gilot on behalf of Elkhart City
Administration
Summary of comments from Potentially Responsible Parties
(PRPs)
1. Mr. Nicholas Valkenburg of Geraghty & Miller, Inc.,
on behalf of Excel Corp.
-------
2
2.
Ms. Jacqueline Simmons of Ice, Miller, Donadio &
Ryan, on behalf of Excel Corp.
Mr. Lennie Scott of Miles Laboratory
3.
The comments are paraphrased in order to effectively summarize
them in this document. Written comments received at EPA's
Region 5 Office are on file and available for review by
contacting the site community relations coordinator, Ms. Karen
Martin, (312) 886-6128, or (800)621-8431. The reader is referred
to the public meeting transcript which is available in the public
information repositories, located at the Elkhart Public Library,
300 S. Second St., and the Elkhart City Engineer's Office, 229 S.
Second st., Elkhart.
A.
SUMMARY OF COMMENTS FROM THE LOCAL COMMUNITY
1. Mr. Gary Gilot, City Engineer, speaking on behalf of the City
of Elkhart, stated the City's belief that the proposed plan meets
the community's needs, is an adequate remedy, and incorporates
cost-effective, proven technologies to accomplish cle~nup goals.
EPA's Response: EPA acknowledges receipt of the City of
Elkhart's comment, and thanks the City for its support.
B.
SUMMARY OF COMMENTS FROM POTENTIALLY RESPONSIBLE PARTIES
1. Mr. Nicholas Valkenburg of Geraghty' Miller, Inc. (G&M), on
behalf of Excel Corp.
a.
The MSWF capture zone is underestimated.
G&M points to capture zones shown by contour maps drawn
November/December 1989 and August 1990. They note that
field pumpage for those timeframes did not reflect high
field pumping demand, therefore, the capture zone is
underestimated. G&M feels the FEMSEEP model used. should have
been used to evaluate a range of pumping patterns, and then used
to determine the sensitivity of the capture zone to changes in
pumping. They also feel the model documentation should have
been provided. G&M criticize the FEMSEEP model calibration shown
in Appendix G. They state that the model consistently calculates
water levels that are too high compared to the field
measurements, thus underestimating the capture zone. G&M state
that a more exact method of capture zone analysis, such as
particle-tracking, should have been used because ground water
flow at the capture zone edge is difficult to determine visually
with accuracy. All of these comments reinforce the underlying
concern that more accurate capture zone analysis would have
resulted in the identification of additional PRPs.
for
well
well
EPA's Response:
-------
3
The 6.1 MGD upon which the capture zone is based was pumped
primarily from wells on the west side of the well field. A five
day pumping test was run to maximize pumping on the west side for
a sustained period of time. Unfortunately, the entire well field
could ~ot be pumped at the maximum rates because of low water
usage during the pumping test. EPA considered use of modeling to
define a "worst case" capture zone scenario. However, modeling
for this purpose would result in a significant amount of
uncertainty in the parameters, calibration would be very costly
and the results would be less defensible than actual
measurements. G&M correctly indicates that calibration of the
FEMSEEP model used was only fair. However, the capture zone was
not based on the model. The model was only used to evaluate the
adequacy of the proposed western interceptors. The model
documentation will be made available in the record and the
information repository. EPA feels the capture zone represented
in the feasibility study based on actual data collected in the
field represents the major forces of capture zone influence.
b.
West Side sources have not been identified.
G&M state that without identifying sources on the West Side of
the Well Field, EPA cannot judge the risk or the need for
remediation. Further, the scope of the RI/FS was too limited to
identify sources on the West Side and that without additional
studies, a major source or sources may be missed.
EPA's Response:
EPA's focus for source control has always been on "hot spots".
Searching for disposal areas in an industrial area which has
existed since the turn of the century and where most facilities
have used TCE or other chlorinated solvents has been a challenge.
Using a grid sys~em over each property for soil sampling would
have been expensive and, due to the high permeability of the
soils, even a tight grid may have missed disposal areas and thus,
not have resulted in identification of disposal areas. EPA used
several methods to attempt to identify spill, leak or disposal
areas. These include use of 104(e) information response, soil
gas survey, historical information where available (including the
investigative reports by Miles Laboratory and Elkhart Products)
and informants, when available. In addition, EPA's investigative
efforts have also focused on sources not yet controlled or where
residual contamination after removal actions is unknown. EPA
agrees that additional information may be needed on the West side
and we intend to pursue such information, however, the extent of
any additional field work is unknown now.
EPA does not agree that because additional unremediated sources
could not be identified that the need for remediation cannot be
determined. The need to intercept and contain the existing
ground water plume is clear based on risk. Because specific
-------
4
sources cannot be identified, the duration of the ground water
interception system cannot be predicted.
The risk assessment does not support soil remediation
and overestimates the ground water risk.
G&M states that the risk for TCE in soil are below 1 x 10-6 and
therefore do not require remediation. They further state that
since 99 percent of the risk relates to ground water which is
already being remediated that soil remediation will not reduce..
the total risk significantly enough to make implementation of
soil vapor extraction system cost effective. G&M feels that the
risk estimates were overestimated because the 95 percent upper
concentration limit was used. G&M state that the risk assessment
failed to include the drinking water ARARs, therefore, a possible
target level for cleanup was overlooked. They feel the cleanup
targets presented are so low they are not likely to be achieved.
G&M state that the practice of balancing out total site risks by
remediating media that already have an acceptable level of risk
is not a standard practice, nor is it clear why remediation of
TCE in soil is needed. G&M also note that use of a multiplier of
2.5 times the oral exposure estimate for estimating non-potable
domestic water use such as showering is not consistent with other
EPA regulatory programs and is excessively conservative.
c.
EPA's Response:
G&M makes several comments concerning the risk assessment and the
associated conclusions. In the first two comments they state
that because the soil risk from ingestion and contact were
determined to be below lx10-6, the soils need not be remediated
and that since the majority of the risk is associated with
ground water, soil remediation will not reduce total site risk
significantly. ~his is incorrect because the soils are a source
of contamination to the ground water for which the risk is
greater. The source must be controlled to minimize future
contamination of ground water. G&M suggest that modeling of the
hydraulics associated with the pumping wells would result in a
more realistic estimate of future concentrations and exposures.
EPA does not agree that modeling would provide a more accurate
. result in this complicated system. such modeling could tend to
oversimplify the dynamics of contaminant partitioning and
contaminant transport phenomena. VOC contamination in the well
field has been identified for over 10 years. It is reasonable to
expect that without remediation ground water risk would continue
for an unknown period of time.
Use of the 95 percent upper confidence level concentration limit
is standard practice as identified in the Risk Assessment for
Superfund (RAGS) quidance EPA/540/1-89/002, December 1989.
Similarly, domestic uses such as showering activities are known
to increase the exposure to chemicals. Literature values support
-------
5
a relationship between oral exposure estimates and vapor phase
inhalation for typical residential use. Using a mid-range
literature value is not unacceptable and is becoming more common
in lieu of lengthier calculations. This is not inherently more
or less conservative than other approaches.
G~ indicates that ARARs were not included in the baseline risk
assessment. ARARs are not supposed to be in the baseline risk
assessment, by definition, since the baseline risk assessment
evaluates site-specific excess cancer and non-cancer risks. The
RAGS emphasizes that preliminary remediation goals are
established in the feasibility study (FS) based on ARARs. RAGS-
does differ from the Superfund Public Health Evaluation Manual
(SPHEM) in that way. See the Alternatives Array document for
discussion of the preliminary remediation goals. Although there
are ARARs for some of the chemicals of concern at this site,
ARARs may not be sufficiently protective when there is more than
one contaminant and multiple pathways of potential exposure. The
ROD summary explains the rationale behind selection of the lXlO-S
risk range for all media at this site. At a lxlO-5 risk level,
the .soil and ground water standards are detectable and achievable
with the selected technologies. Balancing risk by remediating
more than one medium is an accepted procedure. (See SPHEM). In
considering the media options for remediation, it was obvious
that less stringent soil cleanup levels would result in
unachievable ground water standards. As the ground water
standards are presented in the feasibility study now at lxlO-S~
vinyl chloride is still below routine analytical detection
limits. In making ground water standards achievable and
measurable, the soil cleanup level had to be more stringent.
However, the lower soil cleanup level is reliably achievable with
the selected technology. In addition, as has been emphasized
previously, the soils create the ground water risk, and
therefore, it is appropriate to put the remediation emphasis on
the source.
d.
There is no evidence for a "paint layer".
G&H state that the evidence regarding the paint layer suggests a
very limited area where some residue may lie. They state that
there is no support for the contention that soil beneath the
- building is affected by either volatile organic compounds or
paint residue and no further investigation is warranted. They
point to a discrepancy in documentation concerning how deep the
paint layer may be below the surface. They indicate that even if
paint was present, the ISVE system would remove the TCE. They
suggest that it is inappropriate to develop cost estimates for
removal of something there is no data to support exists.
EPA's Response:
The presence of the paint layer is verified by paint residue
-------
6
material found in a limited number of borings as noted by G&M.
Site limitations prohibited precise definition of the areal
extent of contamination. The information supporting the actual
extent is limited (See feasibility study appendix J). If this
information is inaccurate and the amount of paint layer material.
is insignificant, the cost of removal will be low. Given the
existing information, it is most appropriate to refine these
estimates during remedial design. .
ISVE would not be able to remediate the paint layer because the .
volatiles trapped in the paint layer would not be removed from
the paint layer in a reasonable timeframe, therefore, it is not
technically practical to use ISVE for solvents trapped in paint.
Further, it is appropriate to provide conservative estimates of
the volume of soil beneath the building that could be
contaminated for cost and engineering implementability
considerations. The existing information is sufficient to
suggest that additional investigation be conducted beneath the
floor of the building. If the waste does not exist beneath the.
building, then remediation costs will be lower.
e.
Costs for the vapor extraction system are overestimated.
G&M suggest there are several cost assumptions within the FS
which unnecessarily overestimate the costs, including:
additional soil analysis when the existing data base is
sufficient, rental of air vacuum units when purchasing is
cheaper, construction of a system housing structure when other
accommodations can be made considering alternative equipment,
such as lower horsepower blowers with mufflers would reduce
costs.
EPA's Response:
EPA does not agree that the costs are over estimated. In fact,
they are considered biased low because the extent of
contamination beneath the buildings is unknown. However, a value
engineering review during design might find areas where cost
could be reduced. Such activities are encouraged.
2. Ms. Jacqueline Simmons of Ice, Miller, Donadio & Ryan (IMDR),
on behalf of Excel Corp.
IMDR reiterate G&M's technical comments. They emphasize that
there is no credible evidence to support the existence of a paint
layer, that the "confidential sources" referenced in the
feasibility study had no personal knowledge of dumping, further
that such reference to a "confidential source" is contrary to
law and that soil only poses a lxlO-6 risk, therefore, its
remediation and that of the supposed paint layer is also contrary
to law. If the paint layer were present, it does not pose a risk
beneath the building. Further, EPA's failure to identify sources
,
-------
7
on the west side and underestimate the capture zone harms the
PRPs. As a final point, IMDR state that they are willing to
implement ISVE on the Excel property.
EPA's response:
The use of "confidential sources" in the FS was not the best
choice of words. See appendix J for the information which
supports the volume estimates in the FS. The FS use of
"confidential sources" is unrelated to the witness statement
taken and corrected by Elizabeth Murphy on December 8, 1989.
However, the appendix J information is sufficient to support
investigation of the area, and if as suggested, the excavated.
area only contains water, the costs for remediation will be lower
than estimated. However, a boring placed inside the building
during previous investigative efforts by Excel showed
approximately 5 ppm of TCE. All these pieces of information
together demonstrate the need to further evaluate this area for
whatever may (or may not) be present. Cost estimates in the FS
conservatively assume the presence of the paint layer and do
include building support for removal of the paint layer if
. needed. Excel is already familiar with such techniques as they
have already been used to remove contaminated soil in conjunction
with an underground tank removal conducted at the property.
The existence of the building over contaminated soil does not
provide long term protection, it does not achieve cleanup levels
and does not constitute closure. See specific response to the.
G&M comments regarding the risk assessment and ground water
model. EPA does not agree that its proposed actions are contrary
to law. EPA appreciates Excel's willingness to implement the
ISVE without delay and hopes that it will encourage the other
PRPs to reach a full settlement without delay.
3.
Mr. Lennie Scott of Miles Laboratory
Miles cites several questionable field practices which occurred
during the sampling period of May, 1990 on the Miles property.
These practices include use of technical grade isopropyl alcohol
for use in decontamination when pesticide grade isopropyl alcohol
was required by the field sampling plan, residual isopropyl
alcohol in split soil samples indicating inadequate cleaning of
equipment, use of antifreeze in hoses and the potential
contamination of truck beds which held equipment, use of a hard
hat to deliver drilling materials and a discrepancy in sample
identification.
EPA's Response:
The can of isopropyl alcohol shown in the photograph supplied by
Miles, was brought to the site by the driller and was rejected
for use by Donohue. It was not used. Instead, Donohue
-------
8
Analytical Laboratory supplied pesticide grade methanol to be
used for decontamination. The use of pesticide grade methanol
was noted in the field sampling plan dated February 1989.
Therefore, the presence of isopropyl alcohol as a tentatively
identified compound in some soil samples is uncertain.
The Miles comment notes the placement of augers directly on the
ground, down hole equipment on the pickup truck tail gate without
plastic protection and use of a hard hat for materials handling.
EPA and its contractor, Donohue, agree that some field procedures
did not follow the field plan. However, these situations were.
called to the attention of the drilling subcontractor and were
corrected for all additional work at the site. It is always a
challenge in a field program to follow the field plan to the same
level of detail in which the plan is written, particularly in the
winter months. However, the differences are not significant
enough the affect the sampling results.
Finally, Miles notes a discrepancy between the information
supplied after the laboratory data was obtained and the issuance
of the final technical memorandum. The results shown in the
technical memorandum are correct. The information supplied to
Miles early was not final and there were in fact some
discrepancies. Miles indicates that not all samples are reported
in the technical memorandum. This is because the database in the
technical memorandum show samples only for which there were.
positively identified compounds above the detection limit.
Tentatively identified compounds including isopropyl alcohol were
not reported in the technical memorandum database. They were
also not used in the risk assessment for this site.
IV.
REMAINING CONCERNS
No remaining concerns from the public comments received have been
identified.
-------
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
lOS South Meridian Street
P.o. Box 6015
Indianapolis 4Q206-6015
Telephone 317/232.8603
March 28, 1991
Xr. Valdas V. Adamkus
Regional Adminiatrator
U.S. Environmental Protection Agency
230 S. Dearborn Street
Chicllgo,"I11inois 60604
Re:
Record of Decision
Main Street Well PieldSite
Elkhart, Indiana
Dear Hr. Adamkus:
The"Indiana Department of Environmental Management (IDEM)
has 1~eviewed the U. S. Environmental Protection Agency's draft
Record of Decision. The IDEM is in full concurrence with the
selec:ted remedial alternative presented in the document for the
second operable unit for this site.
The major components of the selected remedy include.
-
In-Situ Vacuum Extraction of VOCs in contaminated soil;
Removal of a small paint. layer and off-site disposal in
accordance with the Soil and Debris Treatability
Variance;
Installation of new interceptors on the west side of
the well field to prevent continued plume migration
into the well field and provide well field restoration;
Continue use of the existing air stripper to assure a
clean dr~nking water supply; .
Ground water monitoring to assure adequate performance
of the air stripper and attainment of ground water
standards; and
Deed restrictions on property with "hot spot~ 80i1
contamination until the soil and ground water
performance standards are met.
An Equal Opportunity Employer
-------
Mr. Valdas V. Adamkus
Page-1'wo
Our staff has been working closely with Region V staff in
the Ilelection of an appropriate remedy and is satisfied that the
selec:ted alternative adequately addressee the public health,
welfilre and the environment with regard to the Main Street Well
Pield 8ite.
Please be assured
clear~p of all Indiana
intends to fulfill all
that 90a1.
that IDEM is committed to accomplishing
sites on the National Priorities List and
obliqations required by law to achieve
Sincerely,
~fl.y~M-'
Kathy Prosser
Commissioner
cc:
Cindy Nolan, u.s. EPA, Reqion V
~
-------
------------
~
.
'8tl 110. 1 1f
0lt/0ll/t1
ADMIIiISTRATlVE RECORD INDEX' UPDATE f3
MAIII STREET WEU FIELD
ELI:IWIT, I lID lAllA
ItCCIND OPERAILE UIIIT
FlCllE/FIWIE PAGES DATE TITLE AUTHOR IECIPIEIiT DOCItEIiT TYPE DOCNLJCBER
3 9t/DZ/Olt Corrected Tabl.. Mfchall L. Croa..r, C.llolen,UItPA CClRRESPONDEIiCE
2-1, 2-2 DONOHUE & ASSOCIATES,
0' feufbllfty lCUIty IIIC.
17 91/03/07 'ollow-yP fnfoMiatfon MfchMl L. Croa..r, C.llolen,USEPA CCRRESPONDEIiCE 2
to Flasfbflfty Study DONOHUE & ASSOCIATES,
IIiC.
7 91/03/18 Comment. to prlvious R.Lemie Scott, C.Nolan,USEPA CORRESPONDENCE 3
correspondence MILES INC.
8 '1/03/20 Letter Nicholas Valkenburg, ".Siarnona ,I/IID&R CORRESPONDENCE "
RI: Comments to PrOPOSed GERAGHTY & MILLER, INC.
Plan
5 91/03/21 Comment. to Propoled Jacqueline A. Simm0n8, I:.Martin,USEPA CORRESPONDENCE 5
Plen ICE MILLER DONADIO &
RYAN
50 '1/02/07 Public Meetinll M. Key Dornburg, USEPA MEETlIIG IIOTES 6.'
Transcript OLMSTED & ASSOCIATES
2 '1/01/07 Public Acceptancl CITY OF ELKHART OTHER 7
S fa t 81111nt
76 91/03129 hcord 0' Decflion Valdaa II. Adanicua, REPORTS/STUDIES 8
(ROO) USEPA
-------
o
P8'8 110.
,.
04/08/91
MAIN STREET WELL fiELD: SECOIa) DPEWLE UNIT . UPDATE 13
GUIDANCE DOCUMENTS FOI THE ADMIIiISTUTIVE RECCIIID.
DOCUMEIITS IIOT COPIED. MAT IE REVIEWED AT THE
USEPA REGION V OFFICES, CHICAGO, ILLINOIS.
T JTLI
AUrIlCll
DATE
fEMIEEP
ffnh. EI--.t
Gr0\rGw8t.r Flow
end rrenaport Model
J. Ft OV Mode I U..,..
.....1
(81 P8,n)
D.M.frf,EBASCO ENVIRONMENTAL
90/07100
-------
t p... 110.
01./08/91
ACiONYM
1'1)&1
laD
UlEPA
1
ACRONYM GUIDE FOR THE ADMINISTRATIVE RECORD
MAIN STREET WELL FIELD: SECOND ClPEWLE UNIT - UPDATE f3
ELCHAlT, INDIANA
DEFINITION .
ICE MILLER DONADIO
& RTAII
RECORD OF DECIIION
UNITED ITA TES
ENVIRONMENTAL
PROTECTION AGENCY
-------
I d-
Q
Plge 110.
O"~/91
1
*
ADKIIIISTRATIVE RECORn INDEX
MAIN STREET WELL FIELD SITE
OPERABLE UNIT G - UPDATE G
ELKHART, INDIANA
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOaJ4ENT TYPE DOCNUMBER
6 86/04/01 Durakool correspondence Strl..,-USEPA lucklen-DK Correspondence
re: construction of 8akeer-ISIH Strhllbu'USEPA
new bul idi~ 8ucklen-Durakool
10 91/01/00 Proposed Pi...
Fact ShNt
2 88/06/01 Preliminary Health
Assessment
USEPA
C.llolan-usePA
fact Sheet
2
ATSOR
USEPA
ReportS/Studies
3
631, 90/10/00 Technical Kemorandum Donohue & Associates C.Nolan-USEPA Reports/Studies I,
Phase III
163 91/01/00 PIb l I c Cc:mn.nt Donohue & Associates C.llolan-USEPA Reports/Studi es 5
Draft Feasibility
Study
1209 91/01/00 Draft Feasibility Donohue & Associates C.Nolan-USEPA Reports/Studies 6
Study Appendices
A - J
-------
r 11~t\L
'''' 10.
01/15/91
1
ADMINISTRATIVE RECORD INDEX. UPDATE .,
MAIN STREET WELL FJELD
ELKNAlT, INDIANA
IECCW OPERABLE UNIT
FICHE/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOC\JCENT TYPE
DOCIIIJCBER
10
90/12/27
Letter
Ie: 1I0IlIIII ry of
the IrCUld weter
8Cldel description
with ett.ched
tetter (Aprlt 3,
1990) .nd IIeIIIO
(Mlly 1, 1990)
Cindy .I. lolan,
USEPA
C.S.yre,Excel
Industries
CORRESPONDENCE
,
5 90/08/20 Letter Cindy .I. lIolan, L.Scott,Miles Inc. CORRESPONDENCE 2
Re: Response to comments USEPA
on "Miles propertY" loil
borinss .nd 8Onitorins
tIIll inst.ll.tion
proca..res
with cover letter
(Deceneer 27, 1990)
093 DO/DO/DO Toxicity Summeries USEPA OTHER
" 00/00/00 Various dated PHOTOGRAPHS "
Ilack-end-White
Aerlel Photogrephs
teken of the
Main.Street well Field
7 87/06/10 Aeriel W.C. Il.nton, N.Nole,USEPA PHOTOGRAPHS 5
Photogrephs Ice Mitler Donadio
with .tteched I Ryan
"ver letters
24 82/07120 Docllllentatfon Records Iteve Reuter, USEPA REPORTS/ST~IES 6
for ISBH
Hlzerd Rankins System
51 90/06125 Dtte,..inetion Robert I. Cerr USEPA REPORTS/ST~IES 7
of Soil-Water Partition Environnenul
Coefficients for Reselrch Laboretory
Mlterletl
from the Meln Street Wtll
Field
-------
-------
',g, 10.'
.I/U/I,
J
lICll/l!W 1!GlS ~!rl
fIrLI
J '9/CS/22 JCf (': tollorap o"r
tb, pboa, I' to rb.:
.it' r,. ,14r,..,'
1D tb, r,c,at "fU":
tor ilton.:iOD.
3 '2/JC/Jf J,.;oa., to Ilton.tiol
"fa,.t of JI/15/'2.
3 '2/IIIJE "';01" :0 IDtorll:ioa
J'fD,.t of ICIC2/'2.
E B2111124 P.r:i.l r,,;oa., to
ID~i'I' IDrirol.eD:.l
I.a",.eat Bo.rd JeiDe.t..
2 B2112/Cf IDfe:..:ioa :eqae.:e' by
tbe II!E cereria, tbe ule
of rcr .: Sel.er'. IliD
Strut ~llat.
3 B41C"ll !dri.o:y tbe lil,. bl'
di,eor,:,d .e.e ,oil
cODt..ia.:,d ritb rcr
lad J,J,J rricbloro,:b.a,.
28 BSICfl12 lellor-up :0 l':t,r ot
911J/8f :0 lik, ',:le;
of tb, llib.:: '.:e:
'e:i. ,ad lub"iD'Dt
.,e:iD, r,g.rdiag
cODt..iD.:ioD ,: tbe
lilu .i:e.
IC BE/Cg/25 Sattlflf~:.l Rf,po~'e to
tb, ID DDd,t,d JefDel:
for lafo:..:ioD fro.
tb, CODD.,l for Ilc,l
Corp.
2 '7/Cf/13 J"poa.e to Refa,.:
tor IDtor..:io. bl coa.fl
to: lile. L.be:.tori,.,
l1c. .
5 B7/Cf/25 J"POI.' to Reiae.: tor
U!IJISrRArIYf J1CCRt ilUI
IAI' srun fELL IIILt
ILI!Ur, iI~IU!
"CClt CPfRlJLf unr
lurlCR
IfCI'IIIf
~CCC
lUll
~CCU!Elr flPf
Cildy lol..-USIP!
fo. li.,le-IISCC, IDC.
(o..aDic.tioD ',corl
~"j' 'eb'ter-~ur.kool, J,l;b Pick.rl-IIII Corrupol6flfc,
llc.
~.L.'bit'-"c,l Corp; I.lpb 'ick,rl-IIII Co:ru;ODOtDCe
fbe Seller Co. IIIE Ce::upoao'Dc,
I.'illi.. 'eter.eD-fb,
Seller Ce.
..l;b 'ick.:d-IfIE
CO::upoDoeDc,
B:ace C.:t,:-lil,.
L.berateri"
f,:l,p-llkba:: ..te: 'o:i Co::,,;oD4eDc,
Brac, C.::,:-lil,.
Llborato:iu
la:ty Ri,cb-ISBE
Co::upoaO'Dc,
r,C.Bl'D:o~-Ice liller,e: '.rbfr. l.gel-USIP!
11.
CorrUrODQfDCf
J,.e. Scbiai-li:il.ad' Sa..a Sr,l,.-USI'!
JHi.
CorrUpODOtDC'
Jo.,pb fiDer-S.. 'iD':' Sa.,D Sr.le.-USrp!
Corrupoad'Dc,
-------
.I
""f '0.
U/JS/U
2
\)
lIcelllRW lAGI5 &Arl
f!fL'
Iltorutiol.
4 '811C117 'f'POD'f to 'f(3"t
lor Illorutioa.
7 '811C12C 'f'POD'f to 'f(3"t
tor 11!orutioD.
I '811C121 'e.poD,e to 'efDe,t
tor .otor..:ioa
8 8SIICI27 Relpoa" to leiae,t
tor Iotor..:ioa.
5 8811el28 lelpoa,e to BeiDe.: tor
Iotor.,:ioo by tbe
ccaD.fl tor frilit!
10~D.:riel, lac., p,reot
ot ',etDfl, IDe.
4 SBI121eS Re,poD.e to Reiue.t tor
Iater.,:ioo by 'ortb
A.,ric'D Pbilip. Corp.
ter tbe 5,l.tr Co.
4i,i,ioa.
22 891e4117 Re,poD.t to IfiDe.t
ter 1ofor.a:ioo by
eO~Dsel tor Iltb.rt
Pr04Dcts Corp.
4 S91CGI27 RelpoD.' to ReiDe.t
tor Iatorutioa.
U!I.I5fiAr1rl Ilcon I,tn
JAIl srun 'ILL IIILt
fLIlARr, 11&IUA
$lcelt epnULI "If
AUreOR lIeInfn ~eCD!EJr rr" ~eCD
IOU
Co.
loba 'eD~tr,bot-Io3rl '3.ID 1,.l,,-UI',! CorrupoD~fDCf
'Iterpri."
~.ri4 'orrood-AACOA 'O.ID "Il,,-UI"! eorrupoDduce
eb,rle, ',l:el-'ll:e1 'a.ID "Il,.-US'P! eOrrUpOD~fDCf
liuo Co.
fbo.,s li,tle-IIBCO, IDC. S3..D S,.le,-U51'A Cor1upOD~tDCI
'obert S3'.D Ir.ll,-05IPA CorrupoD~e~ce
Jlder-R,de1,A4di.oa i
StoU!
',rk IUrr-'01tb A.e11C'D 53..D $,.lc,-U51P!
lbilips
CO;;upoDduCf
ferrlDCt ',y-5.itb ,
Scblaeif
la"D Sr.l,,-DSI'!
CorrupoDdtDCf
LfRoy O:t-Ad,., i
futl,kt,Ltd.
SU'.D S,.le.-D51'A
Corrup0:JdeDCf
4 861C61CC SapfrtDad lro,r.. I.ct Iblft US,,!
',ia Streit "ll li114.
f ,7/C8ICC SapertDDd lro,r.. Dpd.te.
lie: Ib,,:
.IIPA
lact Ihe:
3 871C2127 "'0 coatir.ia, tbe Ibl.e II lictie lell, - eCl
lie14 .c:iri:i,..
4 CCICCICC Su..,ry li,t of .01relt
0"11.
4 8'IC513C Cbt.ic.l 'I.te,.ttrl
lateri.l. Iafeot01Y lor..
Ciad! 'Ol.D - US'P!
IU01UdDl
'SIPA
O:btr
AAeO!
Otbtr
-------
.
".,e '0.
CIIlS'"
3
IICBI/IRW PA"S tn,
fULl
4 "/CS/3C tbelic.l f.,ter.ter/
,.teri.l, IlreltOtl lOll.
3 "/CS/3C tbelicil 'I,terlt,r/
"terill, Ilreitorl lOll.
lZ 'S/Ci/ZJ 'elrl:or, fitb ICCJ or
'CCZ t04".
73 'S/C3/1S 'roul~ ..tel tOltalil.tiol
Stu~1 Prepare4 lor lile,
~abor.torie', Ilc.',
lacilitr At Ilibart,
II~i'Di.
S2 '5/ll/CC 'ori PIal 'e.or.llul lor
fbl lel,lial Ilrt,ti,.tiou:
'Iii Strtet "ll liell.
77 '6/C./ll 'roullrattr Ilrt,ti,atiol.
J5C '6/C7/J6 '010., I - 'ori 1111
ftcbuicil Sob.ittal
lail Strtlt 'tll firld
Itl,dial IDrl,tigatiol
Pbue I.
311 '6/12/22 Qualitr A"oralcr Prejrct
P1au (DAPF) Tor Pba., I
Ilil Street 'tll li,ll
Itlrli.l Iure.tigatiol.
J, '7/C2/12 AI'I~.tUt to 'ori P1.u tor
'ail Stlllt '111 liell
J3C '7/C7/C2 fraa'iittal of tb,
tolloriug att.cb,4
r,port,: 'reoldrat,r
Iare,tigatiol preparel
bl l.t./orl'l; COlclptaal
Deli,1 fOl ',.edi,tiol
01 rCI Coutl.ilate4
'rooD~'ltel br 'rooulrater
recbuelegr, Ilc.; III .
SUII,rf rtst Rtpert tor
U,;';SrRUIfI JlCOIt lltn
IAII SfREn flU 11l~t
ILlBARf, IltIUA
SlCelt OpnJJ~I "If
!UrBOR
loura 'Iter,rl".
'icbill. Illu.trll1
11111111' .
""A
0.'. ..terl.1, Co.
Ct,
'i cbul
D'Btlru-I.C.lorlal
eu
eu
Ct,
lIeIlI"f
DOCUUIr ff"
roer
'Ull
Ctbrr
Othr
Otbtr
'11" ~lbor.torl1', Ilc. Report,/Stolit,
DSIIA
Iliblrt Prolact' Cor,.
DSIll
DSIl!
DSIll
'bola, ',rcb'lt-'lib,rt Al ~Io-It'l
Prolactl
Beport,/Stodiu
Rt,ort,/Staliu
!tport,/Stali"
Btport,/Stoliu
hpcr:./Staliu
Jtpor:'/Sto~il'
-------
\J
cr
.
.,.,t 1o.
'81151"
,
U!j'jSfJArIn RlCORt IICU
1111 SfUn 'ELL IIILC
rUBUY, II&IUA
SICOI& OlfRLBL' U'If
IICBI/liW IAGIS tArI
fULl
!f1fBOR
IICIIIEIf
DCCD!EJlf r!PI
roc
JUI
rol.til, Or,'11e. 'lppli,4
6r .il" Llborltori".
fl 17/J2/J2 Sit' II,p,ctiOI R,polt
for BICkl'r, IIC.,
IUbart, ID4illl.
'Ir"r,t .,il-Icolo,,' lil,
IDriroDltDt ..
',portll/Stodiu
253 ',ICJ/CC f,cbaicil 't.orlldl.
Ib"t 1 ',.tI111
Ilrt,ti"tiol 11,ld
Actiritit, SOI.,rl lor
"il Strttt 't11 li,11
CD!
.SIPA
',ports/Stodiu
3C7 SS/C2/C1 ~ollitl A..orIICt Irej,ct C&I US'P! itport./Stodit.
11'1 I~!PF: Addtldo. lor
Iba.t II lail Strttt 'tl1
litld It.,dill Ilrt'ti"t1ol/
Ita.atilitr Study.
gg S'IC212S f'cb~jC41 !t.or,odo. C'.p &rr..t1 , !crtt, uSln itport,/Stadit.
Ib,.t II 't.tdial Ilc.
IDrtlti"tiol litld
!ctiritiu SOlllll.
zg S9/C3/21 !pptldict. to RCi! R1I Sttrtl S!itb-11rkllld' ',lttr Iralci.-US"! Rtpertl/Stodiu
'ort 1111. 1111i.
JG S9/C312B Soil 'a. Ilr"ti,atiol. &00,111 CD.bil,-fEASCO '.'bi"i-&olabat' A"oc. Rtpcrt,/Studit,
Suric"
2S8 89/CS/3C Ilttri. Et.tdill CI.p &1t..t1 , 'Crtt, USIPA Rtpcrt,/Stodit,
Ilvt,ti"tiol Erport IIC,
"iI Strttt 'tll li,14
'olOlt 3 of J .
lplrldil I tat'. fabl".
JJ2 89/C513C 1lttri. Rt.tdial Ca.; Crt"tr , 'cltt, USIPA Rtport,/Stodit,
Ilrt.ti"tiol Rtport lac.
"iI Strttt 'tll lit14
'01111t 2 ot 3 .
1.;lu4ic" A-I.
287 89/C5/3C 1lttri. It.tdi,l Ca.p Crt"tr , Icl't, US'PA hport,IStodiu
Ilrtlti,atiol Rtpcrt fer lie.
"il Strttt 'tll li,ld -
Vololt J ot 3.
------- |