United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EP A/RODIR05-91/159
June 1991
(or { l
~!S <1 ~- '10,1-//0 q
oEPA
Superfund
Record of Decision:
Conrail Railyard Elkhart, IN
Qj . S. Environmental Protectioo Agency
~~ij(Jn m Hazardous. Waste
1r~hnie~1 in1ormation Center
S4 1 Ches~m.lt Street. 9th Floor
Phiiadaiphia. PA 19101
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia. PA 19107
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REPORT DOCUMENTATION 11. REPORT NO. I 2. 3. RecIpient'. Acce88lon No.
PAGE EPA/ROD/R05-91/159
TItle and SubtItle 5. Report Date
SUPERFUND RECORD OF DECISION 06/28/91
.
Conrail Railyard Elkhart, IN
6.
First Remedial Action
7. Aulhor(.) 8. PItrfonnlng Organization Rept. No.
8. P8rf0nnlng Org8lnlzatlon ...... and AddI888 10. ProjectlTuklWork Unit No.
11. Contr8ct(C) or Gr8nt(G) No.
(C)
(G)
12. ~ng Organization ...... 8Rd Addre88 13. Type of Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/000
washington, D.C. 20460 14.
15. SUppl8ment8ry No-
.
18. Ab8tr.ct (Umlt: 200 _rd.)
The 2,500-acre Conrail Railyard Elkhart site is composed of a 675-acre railroad
facility and adjacent areas of contamination to the northeast and northwest in Elkhart
County, Indiana. Major surface water bodies in the vicinity are the St. Joseph River,
located 1 mile north of the site, and the Baugo Bay located to the west of the site,
which have adjacent wetlands and floodplain areas. From 1956 to the present, the site
has been used as a classification and distribution point for rail freight cars. Car
repair, engine cleaning, and diesel refueling activities were conducted onsite.
Reported onsite spills and releases of oil, diesel fuel, hydrochloric acid, caustic
soda, and various petroleum-related substances from 1976 to 1986 have occurred on site.
EPA investigations during the mid-1980s detected elevated levels of TCE in ground water
downgradient from the railyard, and in the subsurface soil at various points onsite.
After initially providing bottled water, in-house carbon filters were provided to 76
residences. This Record of Decision (ROD) provides for the containment of the
contaminated ground water plume, as an interim action, and provides for a safe and
permanent drinking water supply. A subsequent ROD will address contaminated soil and
(See Attached Page)
17. Docun8nt An8Iy8Ia L OHcrIpIora
Record of 'Decision - Conrail Railyard Elkhart, IN
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (carbon tetrachloride, TCE)
b. IdIntlfler8lOpen-EndIcI TIII'III8
c. COSA 11 FIeIdIGrcql
18. Av8l11bi1ty St8t8ment 18. Secl.8'ity CI... (Thl. Report) 21. No. of P.ge.
None 70
20. Secl.8'ity CI... (Thi. Page) 22. Price
I !\Tnn",
Inatrucliona on lIlIfInN
~
50272-101
(See ANSl-Z38.18)
See
R
(FormIIIty NTlS-35)
Department of Commerce
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EPA/ROD/R05-91/159
Conrail Railyard Elkhart, IN
~irst Remedial Action
Abstract (Continued)
ground water, and set final ground water remediation levels. The primary contaminants
of concern affecting the ground water are VOCs including TCE and carbon tetrachloride.
The selected remedial action for this site includes pumping and treatment of ground.
water using pre filtration and air stripping, and discharging the treated water onsite
to the St. Joseph River; treating air emissions, if needed, using carbon adsorption with
offsite regeneration and disposal of the spent carbon; conducting treatability studies
to determine treatment system design parameters; providing an alternate water supply by
extending the municipal distribution system to 505 residences/businesses; monitoring
ground water; and implementing institutional controls, including ground water use
restrictions, and site access restrictions such as fencing. The estimated present worth
cost for this remedial action is $3,969,300, which includes an annual O&M cost of
$125,000 for 20 years.
PERFORMANCE STANDARDS OR GOALS: Final soil and ground water performance standards will
be addressed during remediation of OU2.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
conrail Rai1yard
Elkhart County, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected interim remedial
action for the Conrail Rai1yard site in Elkhart County, Indiana.
This action was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, with the National Oil and Hazardous Substances
contingency Plan (NCP). The decisions contained herein are based
on 'information contained in the administrative record for this
site.
The State of Indiana concurs on the selected remedy.
ASSESSMENT OF THE REMEDY
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substa~tia1 endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
This groundwater interim action operable unit is the first of two
operable units planned for this site. This operable unit
addresses the elimination or reduction of public exposure to
groundwater contamination associated with the site.
Specifically, this interim remedial action involves the provision
of a safe, permanent drinking water supply to residents who are
potentially at risk, and taking actions to restrict migration of
the contamination in the aquifer. The second operable unit will
set remediation levels for contaminated site soils, and
contaminated groundwater at the site, as well as accompanying air
and water monitoring, so as to properly monitor
remediation/recovery efforts. This first operable unit works
toward the goal of achieving a permanent remedy at the site.
The major components of the selected remedy include:
- Installation of four extraction wells located in positions
to adequately contain the migration of contaminants in the
groundwater;
- Treatment of groundwaters collected such that the resultant
discharge will meet National pollutant Discharge Elimination
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System (NPDES) limitations as imposed by the program
administered by the State of Indiana;
- Installation of about 67,000 feet of distribution line, of
various sizes, for the distribution of City of Elkhart water
to approximately 505 residences/businesses who are
potentially at risk from exposure to the contaminated
groundwater; .
- Groundwater monitoring to ensure the effectiveness of the
remedial action; and
-' Fencing of property where the groundwater extraction
facilities are installed, as well as advisories and possible
well abandonment for residences and businesses in the area
of groundwater contamination.
STATUTORY DETERMINATIONS
This interim action is protective of human health and the
envi~onment, complies with Federal and State applicable or
relevant and appropriate requirements for this limited-scope
action, and is cost-effective. Although this interim action is
not intended to fully address the statutory mandate for
permanence antl treatment to the maximum extent practicable, this
interim action utiYizes treatment and thus is in furtherance of
that statutory mandate. Because this action does not constitute
the final action for the Conrail Railyard site, the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principle element, although
partially addressed in this remedy, will be addressed by the
final response action. Subsequent actions are planned to address
fully the threats posed by the conditions at this site.
Because this remedy will result in hazardous substances remaining
on site above health-based levels, a review will be conducted to
ensure that the remedy continues to provide. adequate protection
of human health and the environment within five years after
commencement of the remedial action. Because this is an interim
action ROD, review of thi's site 'will be continuing as EPA
continues to ~eloP final remedial alt~;ra;ives for t e site.
~J.?e,if -Iff/. Ifdlu f
I
Date '
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RECORD OF DECISION SUMMARY
CONRAIL
I.
SITE NAME, LOCATION, AND DESCRIPTION
The Conrail Railyard site is located adjacent to and within the
southwestern city limits of Elkhart, Indiana. The site includes
the 675 acre railyard facility which is approximately bounded to
the north by US33 (Franklin street), on the east by state Route
19, to the south by Mishawauka Road, and to the west by state
Route 219 (see Figure 1), and certain areas of contamination that
extend in two directions, northeast and northwest from the
Conrail railyard. The Elkhart railyard is an electronically
controlled hump yard which serves as a classification
distribution yard for freight cars. It contains 72
classification tracks where cars are separated and switched to a
specific track corresponding to a particular destination. The
yard processes approximately 74 trains per day via 15 receiving
and 14 departure tracks. Car repair, engine cleaning, and diesel
refueling facilities are also located at the yard.
The study area, which includes the railyard, encompasses roughly
2,500 acres, with the topography generally being flat. The study
area is bounded on the north by the st. Joseph River, on the west
by Baugo Bay, on the east by Oakland Avenue, and on the south by
the southern border of the Conrail railyard. There are several
light industrial properties located within the study area to the
north and northwest of the railyard, as well as the numerous
light industries surrounding the study area to the east and
south. within the above referenced study area, there are also
several residential areas, comprised mainly of single-family
homes. Approximately 3,500 people live within this study area,
within about a mile and a half of the site. Of this total, about
3,000 of the people use private residential wells .for their water
supply, and another 300 get their water supply from a private I
utility, whose well is also located in the study area. The
closest downgradient residences to the site are those located
directly across US33, just to the north of the railyard (one or
two hundred feet away).
I
In the study area, four episodes of glaciation have left deposits
of stratified and unstratified drift, ranging in thickness from
150 to 250 feet, over the bedrock. The surficial geology is
characterized by a valley-train outwash deposit consisting
primarily of unstratified sand, and sand and gravel. In some
parts of the study area, these deposits are interbedded with one
or more layers of silt or clay. Although a layer (or layers) of
clay seems to exist over a large portion of the study area, the
clay layer(s) does not appear to be continuous. Where it exists,
investigations found the depth of this layer(s) to vary from 3 to
36 feet below the ground surface, with its thickness ranging from
1 foot to 85 feet. In other areas,' no clay layer was found. The
glacial deposits are underlain by the Coldwater shale of
Mississippian age and the Ellsworth shale of Devonian and
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Mississippian age. Both units contain occasional lenses of
dolomite or limestone.
Groundwater in the area is generally found at a depth of
approximately 5 to 15 feet below ground surface. Groundwater
flow direction in the study area is toward the north/northwest,
in the direction of the st. Joseph River and Baugo Bay.
Groundwater flow data indicate that the st. Joseph River is
hydraulically connected to the outwash aquifer in the study area
and is a discharge zone for this aquifer. The aquifer is part of
the st. Joseph Aquifer System and Tributary Valleys, a federally
designated Sole Source Aquifer.
The major surface water bodies in the vicinity of the study area
are the St. Joseph River and Baugo Bay. The st. Joseph River'
flows westward and is located a little over a mile north of the
Conrail site. Baugo Bay flows north into the st. Joseph River,
and is located immediately to the west of the study area.
Crawford ditch originates at the site, and flows intermittently
to the st. Joseph River. Floodplains and wetland areas exist
along both the st. Joseph River and Baugo Bay.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
site History
The railyard began operations in 1956 as part of the New York
Central Railroad, and continued operations as a subsidiary of the
Penn Central Transportation Company until 1976. From 1961 to
1968, numerous citizen complaints regarding oil discharge~ from
the railyard to the st. Joseph River were filed with state and
local authorities.
In 1976, operations at the railyard were transferred to the
Consolirtated Rail Corporation (Conrail). From 1976 to 1986,
spills and releases of oil, diesel fuel, hydrochloric acid,
caustic soda, and various petroleum-related subs~ances occurred
there. Reports also indicate that a track-cleaning substance
(the chemical composition of which is unknown) and engine
degreasers were used and disposed of at the railyard.
Initial Investiqations and Removal Actions
In June 1986, a resident on County Road 1, just to the north of
US33, reported to U.s. EPA that his residential well contained
elevated levels of volatile organic compounds. On July 2, 1986,
U.S. EPA/Technical Assistance Team (TAT) collected and analyzed a
water sample from this residential well. Sample analysis
indicated the presence of trichloroethylene (TCE) at 800 parts
per billion (ppb) and carbon tetrachloride (CC14) at 485 ppb.
Based on this finding, EPA/TAT initiated a groundwater sampling
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program in the County Road 1 and LaRue street areas, located to
the northwest and northeast of the railyard, respectively. .
Samples were also taken at residences in the Vistula Avenue area,
to the northwest of the County Road 1 area. Groundwater sampling
began on July 17, 1986. A total of 88 residential wells were
sampled by EPA/TAT. Concurrently, 11 additional residential
wells were sampled by individual well owners. TCE, CC14, and
other volatile organic compounds were detected in many
groundwater samples. TCE concentrations as high as 4,870 ppb and
CC14 concentrations as high as 6,680 ppb were detected. A total
of 63 groundwater samples showed detectable levels of TCE, CCL4,
or both. The total of this sampling effort relates to the areas
of contamination designated on Figure 2.
Bottled water was provided to residents whose wells were affected
by the contamination. A portion of the residents in the LaRue
Street area were later connected to a watermain extension from
the City of Elkhart. Many of the residences, however, had carbon
filter units installed to ensure a safe drinking water supply.
Two types of activated carbon filter units were installed in
residences: point-of-use units and whole-house units. In all,
20 point-of-use and 56 whole-house units were installed.
Although homeowners are ultimately responsible for the operation
and maintenance of these units, the Indiana Department of
Environmental Management (IDEM) is currently assisting in their
operation and maintenance.
EPA/TAT also conducted an inspection of the Conrail site in July
and August 1986. Seven water/liquid samples and 21 soil samples
were collected at the Conrail site on July 31 and August 1, 1986.
The results of the analyses revealed TCE concentrations as high
as 5,850 ppb and CC~ concentrations as high as 117 ppb in soil
samples. Based on these results, the downgradient location of I
TCE- and CC14-contaminated private wells from the railyard, and
the history of poor waste handling practices at the railyard, the
Conrail site was placed on a roster of sites proposed for
inclusiqn on the National Priorities List (NPL) in June 1988.
The site went final on the NPL in August 1990.
Remedial Investigation/Feasibility study (RIfFS)
On June 27, 1988, U.S. EPA sent a special notice letter to
conrail offering them the opportunity to undertake the RI/FS for
the site, including investigations of the groundwater
contamination emanating from the site. Although Conrail did
express a willingness to undertake a portion of the RI/FS, u.S.
EPA determined that Conrail had not presented a "good faith"
offer to conduct the entire RIfFS at the Conrail site.
Therefore, on September 30, 1988, U.S. EPA entered into a
contract to have the RI/FS conducted. The workplan for the RIfFS
was approved in July 1989, and actual investigations for the
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Conrail site began shortly thereafter.
The first phase of the remedial investigation eRI) was
essentially completed in January 1990, and was detailed in the
April 1990 Preliminary Evaluation Report. During the RI, various
investigations were undertaken, including a soil gas survey, the
collection of soil samples from 29 soil boring locations, for
chemical/physical tests, the collection of sediment samples from
5 locations, the installation of 36 monitoring wells, and
subsequent sampling of groundwater from these wells. In addition
to the above activities, tests were performed at the monitoring
wells to aid in determining groundwater flow conditions. The
results of these investigations are discussed below.
The soil gas survey was conducted primarily in the suspected
contaminant source areas within the Conrail railyard, although a
limited number of tests were conducted in the
residential/industrial area north of the Conrail railyard. This
survey was used to preliminarily identify the presence of
contaminants in the soil, and as a screening tool to direct
future sampling efforts. All samples were analyzed for only TCE
and CCl4. The results indicated that TCE contamination exists in
the subsurface soil in the area noted as the East Leaking Tank
Car Parking Area of the Conrail Yard, to the west of Oakland
Avenue. The soil gas survey did not indicate the existence of
TCE or CCl4 contamination at any of the other suspected source
locations. The survey, however, did indicate CC14 contamination
near the Elkhart Office Machine building on Route 33, and at a
single location along Tower Road.
Soil samples were collected from borings near the suspected
source areas within the Conrail railyard, and from areas
upgradient from the Conrail railyard. Analysis of soil samples
from these borings confirmed the TCE contamination noted during
the soil gas study in the East Leaking Tank Car Parking Area,
with concentrations of 36 to 180 ppb found. Through this limited
sampling, no TCE or CC14 contamination was detected in any of the
other suspected source areas within the Conrail railyard and the
area sampled downgradient of the Conrail railyard.
The results of the groundwater sampling performed under this
phase of the RI field investigations confirmed the TCE and CCl4
contamination plumes previously identified by EPA, and provided a
preliminary indication of the vertical extent of the plume. TCE
in the shallow wells within the County Road 1 area was found in
concentrations as high as 96 ppb, while concentrations in the
deep wells went as high as at least 2,300 ppb. No TCE was found
in the shallow monitoring wells in the Vistula Ave. area, and
only 1 ppb was found in one of the deep monitoring wells. Of the
shallow and deep wells located around the LaRue Street area, TCE
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was found in only one shallow well at a concentration of 6 ppb.
TCE was also found in two shallow wells constructed near the car
shop (in the Conrail Yard) at concentrations of 2 and 6.7 ppb.
with the exception of a concentration of 7 ppb of TCE found in
one shallow well just upgradient of the Conrail Yard, no other
concentrations of TCE were detected in any of the other
upgradient wells. .
In terms of the groundwater sampling, CC14 in the shallow wells
within the County Road 1 area was found in concentrations as high
as 150 ppb, and as high as 150 ppb in the deep wells. CC14 was
found in the shallow wells of the Vistula Avenue area in
concentrations as high as 340 ppb, and in the deep wells in
concentrations as high as 160 ppb. No CC14 was found in either
the shallow or deep monitoring wells constructed in the La Rue
Street area. CC14 was found in two shallow monitoring wells
installed near the Car Shop and to the east of the Car Shop (on
the Conrail Yard), at concentrations of 230 and 34 ppb,
respectively. No CC14 was found in any of the monitoring wells
installed upgradient of the Conrail Yard. .
other Investigations
In addition to the above investigations performed by u.S. EPA,
Groundwater Technologies, Inc. (GTI), acting as a private
consultant for Conrail, also performed various soil and
groundwater investigations within the Conrail Railyard. These
investigations included drilling a total of 24 soil borings, with
two samples generally taken from each boring (one just below the
ground surface and one at the water table). The investigations
also included the installation of a total of 10 monitoring wells,
to a depth of 20 feet.
The GTI'soil sampling results revealed the presence of TCE at
concentrations of 2,900 and 7,500 ppb in the two samples taken
from a boring in the southwestern corner of Conrail's main'
classification yard. In addition, a concentration of 510 ppb of
CC14 was found in the "water table" soil sample taken from a
boring about 400 feet to the east of the above sample (in the
south central portion of the main classification yard).
The GTI groundwater sampling results revealed concentrations of
15 and 32 ppb of TCE in two of the monitoring wells, one on the
north end of the site near Crawford Ditch, and one just to the
northwest of the Car shop. CC14 was also found at a
concentration of 82 ppb in a monitoring well located to the
northwest of the Car Shop.
III.
HIGHLIGHTS OF COMMUNITY INVOLVEMENT
u.S. EPA and IDEM have been interacting to varying extents with
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the community, in terms of the Conrail site, since contamination
was first found in residential wells in 1986. Informal
interactions with the community took place during the Removal
action, through the sampling' of wells and the provision of
bottled water, carbon filters, watermain connections, etc. In
addition, IDEM has been in contact with residents since that time
as a part of its periodic sampling of residential wells, and
maintenance of the carbon filter systems.
With respect to the remedial activities, community relations
activities began in late 1988, with the development of the
Community Relations Plan. In accordance with that plan, various
meetings have been held, and facts sheets have been issued. An
RIjFS kickoff meeting, held in July 1989, was attended by about
150 people. Availability sessions held in the afternoon and
evening of June 26, 1990, to discuss the results of the first
phase of investigations, were also widely attended. Four fact
sheets have been issued since July 1989.
Community interest is further evidenced by the creation of a
local community interest group, which has been extensively'
involved in the subject project, in part, through verbal and
written communications with both u.s. EPA and IDEM. Media
coverage has also been fairly extensive throughout the life of
the project, including coverage by local newspapers and
television stations.
The Proposed Plan for this interim action was released to the
public on April 19, 1991, outlining remedial alternatives, and
informing residents that the FS and ~ll other documents
comprising the Administrative Record for the site, were available
at the public information repository at the Elkhart Public
Library. The Administrative Record index is included as Appendix
A. A public comment period was held from April 19, 1991, to June
18, 1991, and a public meeting was held on May 1, 1991, to
discuss the proposed remedial action with the residents. The
public meeting was attended by about 150 people, with numerous
questions asked, and seven oral comments received. These
comments, as well as written comments received, and U.S. EPA's
response to the comments are included as Appendix B, the
Responsiveness Summary.
IV.
SqOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
The scope of this interim remedial action is to provide a clean
water supply to residences affected by risks in and around the
site, including the County Road 1, LaRue Street, Vistula Avenue,
and Charles Avenue areas (see Figure 3). In add~tion, this
interim remedial action is also being undertaken to control
groundwater contamination and expansion of the groundwater plume.
Investigations have not provided sufficient information to allow
the initiation of the complete remedial action at this point in
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time. Additional investigations will be conducted: 1) to
identify the source areas within the Conrail railyard, as well as
any other source(s) off-site of the Conrail railyard, which are
contributing to the TCE/CC14 contamination plumes; 2) to further
determine the vertical extent of the areas of contamination, both
within and off the Conrail railyard, including each of the
previously designated residential areas (i.e., County Road 1,
LaRue Street, Vistula Avenue, and Charles Avenue); and 3) to
further define the link between the County Road 1 contamination
area, and the contamination found in the Vistula Avenue and
Charles Avenue areas. Once U.S. EPA completes this
investigation, u.s. EPA will arrive at a final decision as to the
ultimate remediation of the groundwater, including the
anticipated remediation timeframe for the groundwater.
Information has pointed to the need for an interim remedial
action to provide a clean water supply to residences affected by
potential risks in and around the site, and to control the
migration of groundwater contamination in the study area.
Specifically, there is a need to institute an interim remedial
action that will eliminate or reduce the health risk posed to
humans by exposure to contaminated groundwater. This need is
based on contaminant levels present in the potable'water supply
for some of the residences, and the potential for other
residences in the area to be impacted by the contaminated
groundwater, due to movement of the contaminated groundwater.
The interim action is necessary or appropriate to prevent further
gr,oundwater degradation and to reduce threats to human health and
the environment. The interim action will be monitored and
maintained to ensure its effectiveness until the final remedy is
implemented.
The interim action is consistent with the final remedy. Even if
aquifer'cleanup actions can be initiated within a few years, it
will ta]~e several years to ensure that risks associated with
exposure to the groundwater will be eliminated. Therefore,
addressing exposure to the groundwater at this time, through the
provision of a potable water supply, is a necessary and natural
part of the overall remedy. This interim action will not
exacerbate the site problem.
v.
SUMMARY OF SITE CHARACTERISTICS
site Geology and Hydroqeology
As previously noted, four episodes of glaciation have left
deposits of stratified and unstratified drift, ranging in
thickness from 150 to 250 feet, over the bedrock. The surficial
geology is characterized by a valley-train outwash deposit
consisting primarily of unstratified sand, and sand and gravel.
In some parts of the study area, these deposits are interbedded
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with one or more layers of silt or clay. The glacial deposits
are underlain by the Coldwater shale of Mississippian age and the
Ellsworth shale of Devonian and Mississippian age. Both units
contain occasional lenses of dolomite or limestone.
.
The first phase of investigations und~r the RI/FS focused on the
upper 80 feet of the aquifer, to a large extent due to the
perception that a silt and clay layer existed throughout a
majority of the study area. Based on information from USGS, it
was presumed that this layer was from 16 to 20 feet thick, and
was at approximately 40 to 60 feet below grade in the study area.
Rather than a continuous layer, the results of the first phase of
investigations have found that the clay appears to be present in
a series of clay lenses, varying in size, depth, thickness, and
latBral extent. The lenses are absent in some areas (see Figure
4). Where present, they were found to occur at depths ranging
from .3 feet, to as deep as 36 feet. The thickness of the lenses
were found to vary from 1 foot to as much as 85 feet.
Groundwater in the area is generally found at a depth of
approximately 5 to 15 feet below ground surface. Groundwater
flow direction in the study area (in both the shallow and deep
wells) was found to be generally toward the north, in the
direction of the st. Joseph River. In the western portion of the
study area, the groundwater flow direction has been found to tend
toward the northwest, while in the eastern portion of the study
area, it appears to flow somewhat to the northeast (see Figures 5
and 6). Groundwater flow data indicate that the st. Joseph River
is hydraulically connected to the outwash aquifer in the study
area and is a discharge zone for this aquifer. The aquifer is
part of the st. Joseph Aquifer System and Tributary Valleys, a
federally designated Sole Source Aquifer.
A horizontal groundwater gradient of approximately 0.0017 ft/ft
was calculated for both the shallow and deep zones studied during
the first phase of investigations. For calculating horizontal
groundwater velocities, permeability values calculated from slug
test results conducted during the first phase of investigations
were utilized. Based on these calculations, a horizontal
velocity of 32 feet/year was calculated. Because of the
variability in calculated permeability values using different
methods of testing, the horizontal groundwater velocity was also
calculated using USGS-published data obtained from pump tests in
the Elkhart area. with this data, USGS upper range, USGS lower
range, and a logarithmic average of USGS upper and lower limits,
resulted in calculated velocities of 900 feet/year, 72 feet/year,
and 252 feet/year, respectively.
Vertical hydraulic gradients were calculated for all of the
nested monitoring wells. (Five of the nested wells were
installed in locations where one or more clay layer(s) were
encountered in the borings.) The data indicate that there is a
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I 0
9
downward flow component in areas distant from the st. Joseph
River, 'and an upward flow component in areas near the River.
Comparison of the horizontal and vertical hydraulic gradients in
the area where no clay was encountered (assuming equal horizontal
and vertical permeabilities) indicates that the resultant flow
direction is predominantly downward in this area.
Mature and Extent of contamination
The scope of the RI at the Conrail site included studies for all
media that may be contaminated, including soils in and around the
Conrail railyard, sediments in Crawford ditch and other areas of
standing water, and groundwater on and around the site. Resu+ts
of investigations performed to date have shown that groundwater
on and around the site has been contaminated with volatile
organic compounds (VOCs). In the residential areas, the
principal VOCs have been found to be TCE and CC14, both of which
have a Maximum contaminant Level (MCL) of 5 ppb.
No concentrated continuing source area(s) has been found to date,
although soil contamination has been found on the Conrail
railyard. Potential source(s) of contamination do exist on the
railyard, however, including facilities where engine and railcar
maintenance take place. Another potential source relates to a
purported tank car spill of CC14 which took place about twenty
years ago, in the area of Track 69 in the southern end of the
main classification yard of the Conrail railyard. Several light
industries around the Conrail railyard could also prove to be
potential contributing sources of the groundwater contamination.
Investigations undertaken at the four residential areas, where
contamination of the groundwater is of concern, are discussed
below:
County Road 1: In residential well 'sampling undertaken between
1986 and 1989, MCLs were exceeded for TCE in 28 o~ the 58 wells
sampled, and for CCL4 in 27 of the 58 wells sampled.
Concentrations, for TCE, found through the residential well
sampling, ranged from 0.1 ppb to 7,350 ppb. For CC14,
concentrations found through the residential well sampling ranged
from 1 ppb to 27,500 ppb. During the first phase of the RI, four
monitoring wells (two shallow and two deep) were installed in
this area and sampled. Results of sampling at these monitoring
wells revealed that the MCL for TCE was exceeded for all four
wells, with the highest level found being at least 2,500 ppb.
The MCL for CC14 was exceeded in samples taken from three of the
four monitoring wells, with the highest concentration found to be
150 ppb. This area is immediately downgradient of the Conrail
Railyard.
Vistula Avenue:
In residential well sampling undertaken between
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10
1986 and 1989, MCLs were exceeded for TCE in 16 of the 25 wells
sampled, and for CCl4 in 17 of the 25 wells sampled.
Concentrations for TCE found through the residential well
sampling, ranged from 1 ppb to 377 ppb. For CCl4, concentrations
found through the residential well sampling ranged from 2 ppb to
630 ppb. During the first phase of the RI, five monitoring wells
(three shallow and two deep) were installed in the general area,
and the groundwater was sampled. Results of sampling at,these
wells indicated the presence of TCE in only one well, at a level
below the MCL. CCl4 was found in three of the monitoring wells,
with the MCL being exceeded in two of those wells, and the
highest concentration found to be 340 ppb. The similarity of
contaminants of concern, and the groundwater flows (as is shown
on Figures 5 and 6), indicates an apparent relationship between
these two contamination areas.
LaRue street: In residential well sampling undertaken between
1986 and 1989, MCLs were exceeded for TCE in 10 of the 35 wells
sampled, and for CCl4 in 3 of the 35 wells sampled.
Concentrations for TCE found through the residential well
sampling, ranged from 0.1 ppb to 300 ppb. For CCl4,
concentrations found through the residential well sampling ranged
from 0.4 ppb to 150 ppb. During the first phase of the RI, four.
monitoring wells (two shallow and two deep) were installed in the
general area, and the groundwater was sampled. Results of
sampling at these wells indicated the presence of TCE in only one
of the wells, at a concentration of 6 ppb, which is above the
MCL. No CCl4 was found in sampling at any of these four
monitoring wells. This area is immediately downgradient of the
Conrail railyard. .
Charles Avenue: In residential well sampling undertaken in 19vO,
no TCE or CCl4 was detected in any of the samples taken. In
addition, no monitoring wells were installed in. this general area
as a part of the first phase of the .RI. However, as can be seen
from the groundwater flow patterns (see Figures 5 and 6), this
area is'downgradient from the area of contamination found in the
County Road 1 area. This area was studied, however, by Peerless-
Midwest, Inc., which installed six monitoring wells, both shallow
(i.e., less than 30 feet) and deep (i.e., greater than 110 feet).
Groundwater samples taken from the shallow wells were clean, but
TCE and CCl4 were found in the deep wells at maximum
concentrations of 2,495 ppb and 388 ppb, respectively.
Results from the residential well sampling, and the sampling from
the first phase of the RI, are presented in total in Figures 7
and 8, with these figures representing TCE and CCl4 results,
respectively. Also presented in these figures are the estimated
boundaries of the County Road 1 and Vistula Avenue TCE and CCl4
contamination areas. Within the defined areas of TCE and CCl4
contamination, areas have also been delineated where
-------
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DETECTED LEVELS OF TRICHLOROE'THENE
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JETECTED LEVELS OF CARBON TETRACHLORIDE
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I 0
11
contamination levels above 1,000 ppb have been identified. On
Figures 7 and 8, these areas of higher contamination have been
designated as the "hot" contamination zone.
VI.
.
SUMMARY OF SITE RISKS
As a part of the feasibility study for this interim action, a
preliminary risk assessment was prepared to evaluate the need for
implementation of an interim remedial measure designed to
immediately reduce or eliminate public exposure to contaminated
groundwater. This risk assessment, as is indicated by its title,
is preliminary in nature, with more specific findings of the
baseline risk assessment to be included in the subsequent final
action Record of Decision (ROD), and the ultimate cleanup
objectives for the groundwater remediation, and for the site.
,
Relative to this interim remedial action, many residences in the
area rely on this groundwater as their domestic water supply
source. Residents using the groundwater can be exposed to the
contaminants it contains. The most significant exposures
generally result from direct consumption of the water itself and
beverages made with the water, and through dermal contact with
the water and inhalation of vapors from the water while b~thing.
U.S. EPA calculated an unacceptable public health risk for
exposure to the contaminants of concern (i.e., TCE and CCI4)
based on the exposure required for one additional person in a
miLlion to contract cancer if exposed to TCE or CCl4 over a
lifetime. (Note: These risks are in addition to normal risk of
cancer posed in everyday life.) For a one in a million lifetime
health risk, u.s. EPA determined that if an individual is exposed
to greater than 1.23 ppb of TCE or 0.152ppb of CC14, then that
person would be at risk of contacting cancer.
Also, another standard developed by U.S. EPA's Office of Drinkirlg
Water was utilized, specifically the National Primary Drinking
Water Standards MCLs for certain substances in drinking water.
These standards are set at levels as close to the level at which
no known or anticipated adverse health effects would occur,
allowing an adequate margin of safety, as can be feasibly
achieved using best available technology. For both TCE and CCI4,
the MCL is 5 ppb.
As can be seen from the above figures and the figures provided in
the previous section (regarding contamination levels found in the
groundwater), if residents with point of entry filters were to
drink untreated water or if they used untreated water for regular
household purposes such as showering, they could be exposed to
contaminant levels much higher than the estimated baseline risk
levels and the MCLs. In addition, the residents within the
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o
12
impacted area who are using private well supplies not equipped
with filter systems as their sole source of potable water are
potentially at risk. The basis for this determination is that:
1) stage fluctuations in the st. Joseph River make the
groundwater flow regimes susceptible to changes, which may result
in the mixing of groundwater' and further expansion of th~
currently identified boundaries of contamination; 2) the
current in-house filter program is restricted in terms of who is
eligible for obtaining such filters, and is open-ended in terms
of the longevity of IDEM's current monitoring program; and 3)
IDEM's monitoring program indicates that groundwater
contamination levels are increasing in some of the residential
wells in the County Road 1 and Vistula Avenue areas. Therefore,
there are four general areas which are considered to be
po~entially at risk based on the above scenario: the County Road
1, Vistula Ave., Charles Ave., and LaRue st. areas. There are a
total of approximately 505 residences/businesses which would be .
affected in these areas.
Releases of hazardous substances from the site, through exposure
to the groundwater, if not addressed by the preferred alternative
or one of the other measures discussed in this plan, may present
an imminent and substantial endangerment to public health,
welfare, and the environment.
VII.
DESCRIPTION OF ALTERNATIVES
Based on the findings discussed above, the following primary
remedial action objectives were developed for this interim
remedial action at the Conrail site:
- Providing a safe, permanent drinking water supply to
residents who are potentially at risk; and.
- Preventing exposure to the contaminated groundwater.
The secondary objectives for implementing an interim remedial
action for the Conrail site include:
- Minimizing further expansion of contamination in the aquifer
and further migration of the contaminants to surface water
(i.e., st. Joseph River and Baugo Bay); and
- R~jucing contaminant concentrations in the groundwater
within the study area.
A feasibility study was conducted to develop and evaluate
remedial alternatives for this interim remedial action at the
Conrail site which, at a minimum, satisfy the primary objectives
specified above. Remedial alternatives were assembled from
applicable remedial technology process options and were initially
evaluated for effectiveness, implementability, and cost. The
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13
alternatives meeting these criteria were then evaluated and
compared to nine criteria required by the National contingency
Plan (NCP). In addition to the remedial alternatives, the NCP
requires that a no-action alternative be considered at every
site. 'The no-action alternative serves primarily as a point of
comparison for other alternatives.
Except for the no-action alternative, which includes groundwater
monitoring only, each alternative includes the following common
elements:
Grou~dwater Monitoring. A groundwater monitoring program shall
be designed to detect changes/increases in the chemical
concentration of the groundwaters at and adjacent to the site,
and to evaluate the effectiveness of the Remedial Action.
Groundwater monitoring shall include collection and laboratory
analysis of samples from monitoring wells installed under the
first phase of investigations, as well as those planned for
installation during the second phase of investigations.
Monitoring wells to be sampled will be determined during the
Remedial Design, with the basis of selection being to ensure
adequate monitoring of the horizontal and vertical migration of
the groundwater contamination. Based on the extent of the
contamination" the location of the monitoring wells, and the
depth to which they are screened, it is assumed that
approximately 25 monitoring wells will need to be included for
sampling in this monitoring effort. Each monitoring well shall
be sampled semiannually. Laboratory analysis to be performed
sh3ll include at a minimum the volatile organic compounds (VOCs)
listed in Table 1.
Table 1
sampling Parameters
Trichloroethylene
Carbon Tetrachloride
1,1,1 -Trichloroethane
Benzene
Chloroform
l,l-Dichloroethene
Dibromochloromethane
Chloromethane
1,2-Dichloroethene
Vinyl Chloride
If additional information indicates that the groundwater
monitoring program is inadequate, the location/number of
groundwater monitoring wells, and/or type/number of laboratory
analysis, will be evaluated and adjusted as necessary.
Institutional Controls. Warning signs and fencing will be
utilized to limit exposure to the contaminated groundwater within
the area where the groundwater extraction and treatment system is
housed. Restrictive covenants may be implemented on the Railyard
and the property where the groundwater extraction facilities and
monitoring wells are installed, pursuant to Indiana Code (IC) 13-
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I
14
7-8.7-12. In addition, advisories will be issued to users and
owners of water wells within the area of contamination. It is
expected that water wells within the area of contamination will
be abandoned pursuant to IC 13-7-26-7.
Alternative 1 - No Action with Groundwater Monitoring
The "no action" alternative is included to establish a baseline
for comparison. Under a no-action alternative, actions taken to
reduce the potential for exposure should not be included as a
component of the alternative. As such, this alternative would
evaluate the situation at the site with none of the residences
having individual carbon filter units.
Taking no action at the site would result in leaving contaminated
groundwater in the aquifer, and would increase exposure to the
contaminated groundwater, since operation and maintenance of the
existing filter systems could not be guaranteed.
The no-action alternative would, however, include the monitoring
of the groundwater as discussed above.
The present worth cost for Alternative 1 would be $147,300.
Since the groundwater monitoring will be done without the
installation of any new monitoring wells, no capital costs will
be incurred. However, operation and maintenance (O&M) costs are
e~timated to be $15,000jyear for the groundwater monitoring.
Alternative 2 - Distribution of Water to be Supplied from a New
Central Well; Groundwater Extraction Sy~tem; and Groundwater
Monitor~ng.
This alternative includes the installation of a groundwater
extraction, collection, treatment, and discharge system
("groundwater extraction system") which captures and removes
contaminated groundwater from within the area of groundwater
contamination which extends through the County Road 1 area, to
the northwest (or the western contamination area shown on Figure
2). The extraction system would consist of a network of
approximately four wells designed to prevent the further
migration of contaminants, by capturing and removing contaminated
groundwater downgradient of the source area, through the
withdrawal of approximately 500 gallons per minute (GPM) of
groundwater. Intercepted groundwater would then be pumped to the
groundwater treatment system for treatment.
Testing would need to be performed prior to the design of the
groundwater extraction system network to assist in the
determination of the optimum pumping rate to contain the plume.
The groundwater extraction system would be designed to ensure
that extraction well placement will be sufficient to
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I 0.
15
hydraulically contain the contaminant plume (preliminarily
identified on Figure 2), and extract contaminated groundwater for
treatment. A collection and piping system would be used to
transport extracted groundwater to the treatment system for
chemical removal. The groundwater extraction system would be
designed to operate year-around.
In addition to controlling the movement of the plume, this system
would also serve as the potable water supply source for the
affected residences. As such, the extracted groundwater would be
treated to levels necessary to allow it to be used as the source
of drinking water for the residences. After collection in an
influent storage tank, the groundwater would be treated to
decrease concentrations of VOCs. Such treatment processes would
include the following: (1) a pretreatment system for filtering
out suspended solids, (2) an air stripping system for the removal
of VOCs,.and (3) treatment of air emissions from the air
stripper, as necessary, to meet the standards as stated within
section 326 of the Indiana Administrative Code (IAC).
Treatability testing would need to be performed to determine the
design parameters of the treatment system in order to meet Safe
Drinking Water Act (SDWA) requirements.
Treatment process residuals would be handled in accordance with
all applicable or relevant and appropriate requirements
pertaining to the site. Spent carbon from air treatment systems
would need to be handled as a RCRA waste and either disposed of
in a RCRA-compliant facility in accordance with Land Disposal
Restrictions or regenerated off-site.
The extraction system would be operated indefinitely, since it
would serve as the water supply source for the residents in the
area. The system's performance would be monitored on a regular
basis, with adjustments to the system made, as necessary, based
on the performance data collected during operation. Examples of
adjustments which could be required are additional groundwater
extraction wells, increased pumping rates, and/or changes in
treatment (e.g., due to changes in contaminant concentrations).
This alternative would also include a water distribution system
which would be sized to convey both the fire flow demand and the
peak bourly potable demand. The system would be designed to
serve approximately 505 units, within the four areas, and would
include the installation of about 67,000 feet of distribution
line.
Treated water in excess of domestic requirements would be
discharged to the st. Joseph River. This alternative would also
include groundwater monitoring, as discussed above.
Present worth costs for Alternative 2 would be approximately
$5,123,600. Of this amount, the capital costs would be
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"
16
$2,998,000, with annual O&M costs of $216,500.
Alternative 3 - Individual Point-of-Entry Treatment Units;
Groundwater Extraction System; and Groundwater Monitoring.
'This alternative would include the groundwater extraction and
treatment system detailed in Alternative 2. However, under this
alternative, all of the groundwater that is extracted and treated
would be discharged to the st. Joseph River. Therefore, under
this alternative, the amount of treatment that is needed, would
be dependent upon what is necessary to satisfy National Pollutant
Discharge Elimination System (NPDES) discharge criteria prior to
discharge to the River. The discharge criteria would be
determined by the u.s. EPA, in consultation with the IDEM. Such
discharge criteria would need to satisfy best available
technology requirements and any more stringent limits necessary
to satisfy water-quality based standards. If treatment was
deemed necessary to decrease concentrations of VOCs, such
treatment processes would be essentially the same as those
described under Alternative 2. The extraction system would be
operated until it is determined what final groundwater
remediation measures would be necessary, and such measures were
initiated. The system's performance would be monitored as is
discussed under Alternative 2, with adjustments made as
necessary.
A permanent, safe drinking water supply would be provided through
the installation of point-of-entry (POE) carbon filter units in
homes and businesses in the affected or potentially affected
area. For this alternative, about 450 homes or businesses not
currently using POE systems, including those currently having
point-of-use systems would be provided with POE systems.
Periodic sampling, as well as filter, prefilter, and flow meter
replacement, ,would also be necessary under this alternative.
This alternative would also include the groundwater monitoring
discussed above. The institutional controls discussed above,
would be slightly different for ~lternative 3, since the
residences would continue to use their own wells for their
drinking water supply. Specifically, the drinking water wells
would not be abandoned pursuant to IC 13-7-26-7.
Present worth costs for Alternative 3 would be approximately
$4,450,900. This figure includes capital costs of $937,000, and
annual O&M costs of $357,900.
Alternative 4 - provision
Charles Ave./vistula Ave.
Street area; Groundwater
Monitoring.
of Separate Water Supplies for the
area, and the county Road l/LaRue
Extraction System; and Groundwater
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I
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17
Under this alternative, the source of the potable water supply
for the affected residents would be dependent upon the County ~n .
which the area is located. In the County Road 1 and LaRue street
areas (which are both located in Elkhart County), the
installation of a water distribution system would extend from the
existing City of Elkhart water supply system. Such a
distribution system would service about 304 units, and would
entail the installation of approximately 43,000 feet of
distribution line.
For the vistula Ave. and Charles Ave. areas (which are both
located in st. Joseph County), this alternative would include two
options. The first option, is to connect the approximately 201
residences in these areas to a municipal water supply being
planned for the Town of Osceola. There are uncertainties
involved, however, both in terms of whether such a system will
actually be developed, and the timing involved in the development
of such a system. Therefore, another option for servicing this
area involves the use of treated groundwater from the groundwater
extraction system. Under both of these options, around 20,000
feet of distribution lines will need to be installed.
The groundwater extraction and treatment system described under
Alternative 2 would be a part of this alternative. Treatment of
the groundwater would depend upon whether any part of the
groundwater is to be used as a drinking water supply source. If
the areas in st. Joseph County were to use the extracted
groundwater as their source of drinking water, treatment of the
groundwater would be as described under Alternative 2. If,
however, the areas in st. Joseph County were to obtain drinking
water from the Town of Osceola, treatment of the groundwater
would follow the scenario set up under Alternative 3, with
treatment dictated by NPDES discharge limitations. . As mentione~
previously, any treated groundwater in excess of domestic
requirements would be discharged to the st. Joseph River. This
alternative is similar to the previous alternatives, in that it
would include the groundwater monitoring.
,
Present worth costs for AlterIlative 4 would be approximately
$4,613,600. Included in this total are $2,488,000 in capital
costs, and annual O&M costs of $216,500.
Alternative 5 - Extension of the City of Elkhart's Municipal
Waterworks to Serve all Four Affected Areas; Groundwater
Extraction System; and Groundwater Monitoring.
This alternative is similar to Alternatives 2, 3 and 4, in that
it includes groundwater monitoring to help ensure that this
alternative is effectively meeting the remedial action goals.
addition, this alternative would also include the groundwater
extraction system detailed in Alternative 2. Under this
In
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is
alternative, all of the groundwater that is extracted, would be
treated, as under Alternative 3, to meet requirements for
discharge to the St. Joseph River.
The potable water supply under this alternative would serve all
four of the affected areas, through the installation of a water
distribution system extending from the existing City of Elkhart
water supply system. Such a distribution system would service
all 505 of the estimated units in the affected areas, and would
entail the installation of approximately 67,000 feet of
distribution line.
Present worth costs for Alternative 5 would be approximately
$3,969,300. This total reflects annual O&M costs of $125,000,
and capital costs of $2,736,000.
VIII.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP requires that the alternatives be evaluated on the basis
of the following nine evaluation criteria: (1) Overall
protection of human health and the environment; (2) Compliance
with applicable or relevant and appropriate requirements (ARARs);
(3) Long-term effectiveness and permanence; (4) Reduction of
toxicity, mobility, or volume through treatment; (5) Short-term
effectiveness; (6) Implementability; (7) Cost; (S) State
acceptance; and (9) community acceptance. This section compares
to the alternatives with regard to these nine evaluation
criteria.
Threshold Criteria
1. Overall Protection of Human Health and the Environment
With the exception of the no-action alternative, all of the
alternatives provide good protection of human health and the
environment with respect to exposure to contaminated groundwater.
The no-action alternative provides no such protection.
Alternatives 5 provides a somewhat higher degree of protection
than Alternatives 2 and 3, since Alternative 5 eliminates the
exposure to the affected residences, through connection to a
different water supply source. Alternatives 2 and 3 do provide
good protection, however, since the extracted groundwater will be
treated to at least MCLs. The level of protection provided by
Alternative 4 will depend upon the option selected for providing
potable water to the affected areas of st. Joseph County. If a
tie-in to the Town of Osceola is possible, the level of
prctection will be comparable to Alternative 5. If, however, the
extracted, treated groundwater is to be used as the water supply
for the affected areas of st. Joseph County, the level of
protection afforded by Alternative 4 will be comparable to that
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I .
19
provided under Alternatives 2 and 3.
2. Compliance with ARARs
All of ' the Alternatives should meet the identified ARARs.
The alternate water supply will meet MCLs set under the SDWA (40
CFR Parts 141 and 143). The groundwater extraction system
portion of Alternatives 2, 3, 4, and 5, will meet NPDES
permitting/discharge requirements (40 CFR Parts 122, 125, 131,
and 136; and lAC 327), and will utilize the best available
demonstrated control technology for treatment and discharge of
the groundwater to surface water. For air stripping facilities,
lAC 326 establishes permitting requirements for emissions of
VOCs, requiring Best Available Control Technology (BACT) for new
sources with potential emissions exceeding a specified threshold
value. U.S.EPA's OSWER Directive 9355.0-28, relating to the
control of air emissions at Superfund groundwater sites will also
. be considered to the extent that it is suitable to VOC air
emissions for the groundwater treatment process. In addition, if
off-site landfilling of residuals is considered, all Federal (40
CFR Part 268) and State (329 lAC) requirements for landfilling
hazardous wastes must be met. For off-site disposal of spent
carbon to an approved regeneration facility, the manifest
requirements under the Resource Conservation and Recovery Act (40
CFR Part 262) and the Indiana Administrative Code (Section 329)
are applicable.
MCLs and MCL Goals (MCLGs) will not be ARARs for groundwater in
the aquifer.because they are beyond the purpose and scope of this
interim action. Aquifer cleanup ARARs will be determined and
addressed by a later measure when a final decision is made on
cleanup of the groundwater.
Primary Balancinq criteria
3. Long-Term Effectiveness and Permanence
with respect to the long-term effectiveness and permanence of the
water supply, Alternative 5 will provide the highest degree of
long-term effectiveness and permanence since it involves the
provision of a water supply from a source other than the
contaminated groundwater at the site. This degree may not be
much higher, however, since groundwater from the City of
Elkhart's Main Street Well Field (which would probably be the
source of water for this area) is also contaminated with TCE,
although it is treated through the use of air strippers.
Nevertheless, the Main Street Well Field system is an established
system, with better O&M capabilities.
The long-term effectiveness and permanence of Alternative 4, with
respect to the water supply will depend upon the option chosen
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20
for servicing of the st. Joseph County area. If this. area ties
in to the Town of Osceola, then the degree of permanence for
Alternative 4 will be the same as that for Alternative 5, or
possib~y higher, assuming the water supply source is cleaner, and
treatment is equally as effective. If, however, treated
groundwater is utilized as the source of the drinking water for
the St. Joseph County areas, the long-term effectiveness and
permanence will be somewhat less since potential changes in
contaminant concentrations could effect the effectiveness of the
treatment system, and thereby potentially effect the permanence
of Alternative 4.
As with Alternative 4, since Alternative 2 involves the provision
of treated groundwater to affected residences, long-term
effectiveness and permanence of the water supply, although still
being adequate, is not as good as Alternatives 4 and 5.
Alternative 3 provides a below average degree of long-term
effectiveness and permanence, partly because of the potential for
changes in the contaminant concentrations to impact the
effectiveness of the filters, and because these changes could
impact each of the 505 filters differently. Finally, the no-
action alternative has no long-term effectiveness, since it will
not reliably protect human health and the environment.
In terms of the overall long-term effectiveness and permanence of
the various alternatives, with respect to protection of human
health and the environment from the groundwater contamination at
the site, such long-term effectiveness and permanence may not be
achieved. The groundwater extraction system, which is a part of
Alternatives 2, 3, 4, and 5, will, however, be effective in the
short term in preventing further degradation of the groundwater.
4. Reduction of Toxicity, MObility, or Volume Through Treatment
Since Alternatives 2, 3, 4, and 5 all include groundwater
extraction, treatment, and disposal, they all provide for at
least an adequate reduction of toxicity, mobility, and/or volume
of the groundwater contamination. Specifically, all of the
alternatives result in the reduction of toxicity in the extracted
groundwater, through treatment for VOCs using air stripping.
Mobility of the groundwater contamination will be reduced through
control of the gro~ndwater extraction (e.g., the rate of
extraction, the location of the extraction wells, etc.). Volume
will also be reduced through the extraction process.
Alternatives 2 and 4 may provide a slightly higher degree of
reduction, since the extracted groundwater will be used as the
water supply and will hence need to be treated to a potentially
higher level.
s.
Short-Term Effectiveness
-------
! .
21
Alternative 3 provides the highest degree of short-term
effectiveness, since the home carbon units are readily available,
and can be installed more quickly than a waterworks system. In
additiqn, there will be little or no adverse effects to human
health and the environment during the implementation period for
Alternative 3. The short-tenTI effectiveness for Alternatives 2,
4, and 5 will also be good, but will be lower than that for
Alternative 3, since the time period for implementation of these
alternatives will be longer, and will result in some disruption
during the period of construction. Alternative 5 will provide a
somewhat higher degree of short-term effectiveness (over
Alternatives 2 and 4), if connection to the City of Elkhart's
system can be agreed to quickly.
6. Lmplementability
Alternative 3 will be the easiest to implement, since the filters,
are easily available, can be easily and quickly installed, and
will simply require agreement by the individual homeowners to
begin implementation. The implementability of Alternative 5 is
good in terms of technical feasibility, since it involves
materials and services which are readily available. The
administrative feasibility of Alternative 5, however, will be
dependent upon being able to expeditiously work out an agreement
for long-term operation and maintenance of the water distribution
system with the city of. Elkhart and other parties. As with
Alternative 5, the implementability of Alternative 4 is also good
in terms of technical feasibility, since it involves materials
and services which are readily available. The administrative
feasibility of Alternative 4 depends upon the availability of
connecting to the proposed Town of Osceola water system.
Alternative 2 is adequate in terms of implementability, being
technically feasible in terms of materials and services being
readily available. Coordination among the affected governmental
bodies will be essential for most of these alternatives. In
addition, all of the above alternatives will include some
permitting requirements which may affect the administrative
feasibility of the alternatives, such as the discharge of treated
groundwater and the use of air strippers.
7. Cost
The costs of the various alternatives are presented above.
Alternat~ves 3, 4, and 5 all cost about the same. Alternative 2
is slightly more expensive.
Modifvinq criteria
8. state Acceptance
IDEM has been involved throughout the investigation of the
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22
Conrail site and supports the selected remedy.
9. Community Acceptance
community acceptance of the selected remedy is discussed in the
Responsiveness Summary, which is attached as Appendix B.
IX.
THE SELECTED REMEDY
Based on the information collected and developed in the Phase I
RI/FS, and using the comparative analysis of alternatives
described above, U.S. EPA and IDEM have selected Alternative 5 as
the most appropriate interim action for addressing exposure to
contaminated groundwater at the Conrail site. This remedy is
made up of the following components: '
Institutional Controls - This alternative may include restrictive
covenants pursuant to IC 13-7-8.7-12, for the Railyard and
property where the groundwater extraction facilities and
monitoring wells are located. In addition, advisories will be
issued to users and owners of water wells within the area of
contamination. It is also expected that water wells within the
area of contamination will be abandoned pursuant to IC 13-7-26-7.
In addition, warning signs and fencing will be utilized to limit
exposure to the contaminated groundwater within the area where
the groundwater extraction and treatment system is housed.
Groundwater Monitorinq - A groundwater monitoring program,
designed to detect changes/increases in the chemical
concentration of the groundwaters at and adjacent to the site,
and to evaluate the effectiveness of the Remedial Action is
included in the selected remedy. Groundwater monitoring shall
include semiannual sampling at approximately 25 monitoring wells
selected on the basis of ensuring adequate monitoring of the
horizontal and vertical migration of the groundwater
contamination. Laboratory analysis to be performed shall
include, at a minimum, the volatile organic compo~nds (VOCs)
listed in Table 1. If information ever indicates that the
groundwater monitoring program is inadequate, the location/number
of groundwater/monitoring wells, and/or type/number of laboratory
analysis, will be evaluated and adjusted as necessary.
Groundwater Extraction System - This alternative includes the
installation of a groundwater extraction, collection, treatment,
and discharge system ("groundwater extraction system") which will
capture and remove contaminated groundwater from within the area
of groundwater contamination which extends through the County
Road 1 area, to the northwest (or the western contamination area
shown on Figure 2). The extraction system will consist of a
network of approximately four wells designed to prevent the
further migration of contaminants, by capturing and removing
contaminated groundwater downgradient of the source area. Three
-------
23
of the wells would be located along the centerline of the
contamination area within the County Road 1 area (see Figure 9),
and would be designed to pump initially at approximately 100 GPM.
The fourth well, with the capacity to pump initially at 200 GPM,
would be located along the approximate centerline of the
contamination in the vistula Ave. area where it crosses County
Road 219. Intercepted groundwater shall then be pumped to the
groundwater treatment system for treatment, prior to discharge to
the st. Joseph River.
Testing shall be performed prior to the design of the groundwater
extraction system network to assist in the determination of the
optimum pumping rate to contain the plume. The groundwater
extraction system shall be designed to ensure that extraction
well placement will be sufficient to hydraulically contain the
contaminant plume, and extract contaminated groundwater for
treatment. A collection and piping system shall be used to
transport extracted groundwater to the treatment system for
chemical removal. The groundwater extraction system shall be
designed to operate year-around.
The degree of treatment that is needed will be dependent upon
what is necessary to satisfy NPDES discharge criteria prior to
discharge to the River. The discharge criteria shall be
determined by the U.S. EPA, in consultation with the IDEM. Such
discharge criteria shall satisfy best available technology
requirements and any more stringent limits necessary to satisfy
water-quality based standards. After collection in an influent
storage tank, the groundwater shall be treated, if needed, to
decrease concentrations of VOCs. Such treatment processes shall
include the following: (1) a pretreatment system for filtering
out suspended solids, (2) an air stripping system for the removal
of VOCs, and (3) treatment of air emissions from the air
stripper, as necessary, to meet the standards as stated within
Section 326 of the lAC. Treatability testing shall be performed
to determine the design parameters of the treatment system in
order to meet discharge requirements.
Treatment process residuals shall be handled in accordance with
all applicable or relevant and appropriate requirements
pertaining to the site. Spent carbon from air treatment systems
must be handled as a RCRA waste and either disposed of in a RCRA-
compliant facility in accordance with Land Disposal Restrictions
or regenerated off-site.
The extraction system shall be operated until it is determined
what final groundwater remediation measures will be necessary,
and such m~asures are initiated. The system's performance will
be monitored on a regular basis, and adjustments to the system
may be warranted by the performance data collected during
operation. Examples of adjustments which may be necessary, are
additional groundwater extraction wells, increased pumping rates,
-------
J)
"T1
.....
I..C "'
C "
-s
It>
~ ~
!
"'(I i
v
LEGEND
... EXTIIACTION WILL
. TIIEATMENT PLANT
r:l POTENTIAllY IMPACTIO MEAS
SCALE: "81500'
2.000 3.000
o 1.000
-=-=-=---
4.000
5.000 FEET
.
-------
I .
24
and/or changes in treatment (e.g., due to changes in contaminant
concentrations).
Alternate Water Supply - The selected remedy includes the tie-in
of all' four of the affected areas to the existing City of Elkhart
municipal water supply system. The water distribution system
will include the installation of about 67,000 feet of '
, distribution line of various sizes. The system will be designed
to serve approximately 505 units, within the four areas. In
developing the alternatives, it was assumed that three people
occupy each residential unit, with an equivalent of eight people
use for each of the commercial units. Water usage was assumed to
be an average daily rate of 100 gallons per day per person. The
distribution system was sized to convey both the fire fighting
demand flow of 500 GPM for two hours from storage while providing
potable water service to all dwellings at the maximum daily
demand flow rate. Standard local distribution lines are six
inches in diameter. All lines in excess of six inches were sized
based on a computer program from the City of Elkhart waterworks.
This'alternative will reduce the risks posed by exposure to the
contaminated groundwater. Once the alternate water supply system
is installed, those residents who are at risk or potentially at
risk with respect to contact with the contaminated groundwater,
will have available, water meeting SDWA MCLs. Once the
groundwater extraction system is installed, a large portion of
the area of groundwater contamination will be contained to at
least its current position. This remedial action will be
monitored carefully to ensure that hydraulic control of the
contaminated plume is maintained. In addition, data collected
during this remedial action, relative to aquifer and contaminant
response to the subject remedial measures, will be used in
conjunction with data collected during further RIinvestigations,
to determine the ultimate level of remediation for the
groundwater contamination. A final groundwater remediation ROD,
which specifies the ultimate goal, remedy, and anticipated time-
frame, will then be prepared. The subject interim system may be
incorporated into the design of the site remedy specified in the
final action ROD.
The total present worth cost for the selected remedy is estimated
at $3,969,300. This total reflects capital costs of $2,736,000,
and present worth O&M costs of $1,233,300. These present worth
O&M costs are based on annual O&M costs of $125,000, discounted
over the 20-year duration with a 10% interest rate.
x.
STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. CERCLA also requires that the selected remedial
action for the site comply with applicable or relevant and
-------
25
appropriate environmental standards established under Federal and
state environmental laws, unless a waiver is granted. The
selected remedy must also be cost-effective and utilize permanent
treatment technologies or resource recovery technologies to the
maximum extent practicable. The statute also contains a
preference for remedies that include treatment as a principle
element. The following section discusses how the selected remedy
for interim groundwater remediation at the Conrail site meets
these statutory requirements.
Protection of Human Health and the Environment
As previously indicated, residents using the groundwater can be
exposed to the contaminants it contains. The most significant
exposures generally result from direct consumption of the water
itself and beverages made with the water, and through dermal
contact with the water and inhalation of vapors from the water
while bathing. Under Alternative 5, provision of an alternate
water supply to residents downgradient of the site, extraction
and treatment of contaminated groundwater, and imposition of
access restrictions to contaminated groundwater until aquifer
remediation is attained will address risks from groundwater.
I
Use of emissions controls, if necessary, will protect against
short term exposure to contaminants during the remedial action.
No environmental impacts due to site contamination have been
identified to date, and discharge of water to the St. Joseph
River will be regulated by NPDES to ensure that the remedial
action does not affect aquatic life.
Compliance with ARARs
The selected remedial action will meet a'll identified applicable,
or relevant and appropriate Federal and more stringent State
requirenents. ARARs for the selected remedy are listed below. .
Chemical Specific
SDWA National Primary Drinking Water Standards (40 CFR Part
141), and Indiana Drinking Water Quality Standards (327 IAC
2) - (The alternate water supply must meet these
requirements. However, MCLs/MCLGs will not be ARARs for the
groundwater because they are beyond the scope of this.
interim action.)
CAA National Emission Standards for Hazardous Air Pollutants
(NESHAPs) (40 CFR 61)
Clean Air Act (CAA) National Ambient Air Quality Standards
(NAAQS) (40 CFR Part 50)
Indiana Regulations for Establishing Emission Levels for
-------
I .
26
VOCs (326 IAC 2, and 326 IAC 8)
Action Specific
Clean Water Act (CWA) NPDES Permit Regulations (40 CFR Parts
122 and 125)
CWA State Enforcement Jurisdiction (40 CFR Part 131)
CWA Sample Preservation Procedures (40 CFR Part 136)
RCRA Definition and Identification of Hazardous Waste (40
CFR Part 261)
RCRA Standards for Generators of Hazardous Waste (40 CFR
Part 262)
RC~~ Standards for Transporters of Hazardous Waste (40 CFR
Part 263)
RCRA Land Disposal Restrictions (LDRs) (40 CFR Part 268)
Occupational Safety and Health Act (OSHA) Regulations for
Workers Involved in Hazardous Waste operations (29 CFR Part
1910)
Indiana Regulations for the Treatment and Disposal of
Hazardous Waste (329 IAC 3)
Indiana Regulations For Permitting of Air Strippers (326 IAC
2, and 326 IAC 8)
Indiana Regulations for Construction Permits for Water
Treatment Facilities (327 IAC 3)
Indiana NPDES Permit Regulations (327 IAC 5)
Indiana Regulations for the Registration of Groundwater
Extraction Wells Which Have a Combined Capability of Pumping
Greater 'Than 70 Gallons per Minute (Indiana Code 13-2-6.1)
Location Specific
Construction within 100-year Floodplain (40 CFR Part 264)
u.S. EPA's Statement of Procedures on Floodplain Management
and Wetlands Protection (40 CFR Part 6, Appendix A)
Indiana Regulations Governing Construction in a Floodway
(Indiana Code 13-2-22)
To Be Considered criteria
-------
27
U.s. EPA's OSWER Directive 9355.0-28 - Control of Air
Emissions from Superfund Air Strippers
E~khart County Groundwater Protection Ordinance
Cost Effectiveness
U.S. EPA believes that the selected remedy is cost-effective in
mitigating the risk posed by contact with contaminated
groundwater, within a reasonable period of time. Section
300.430(f) (ii) (D) of the NCP requires U.s. EPA to evaluate cost-
effectiveness by comparing all the alternatives which meet the
threshold criteria: protection of human health and the
environment; and compliance with ARARs, against three additional
balancing criteria: long-term effectiveness and permanence;
reduction of toxicity, mobility or volume through treatment; and
short-term effectiveness. The selected remedy meets these
criteria and provides for overall effectiveness in proportion to
its cost. The estimated cost for the selected remedy is
$3,969,300.
utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practiqable
U.s. EPA and IDEM believe that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the
interim action being undertaken at the Conrail site. Of those
alternatives that are protective of human health and the
environment and comply with ARARs, U.s. EPA and IDEM have
determined that the selected remedy provides the best balance of
trade-offs in terms of long-term effectiveness; reduction in
toxicity, mobility or volume achieved through treatment; short-
term effectiveness; implementability; and cost, taking into
consideration the statutory preference for treatment as a
principal element and considering state and community acceptance.
Preference for Treatment ~s a principal Element
Since the. selected remedy relates to an interim action to contain
groundwater contamination, and does not address the source or
complete removal of the contamination, it does not therefore
address the principal threat. Therefore, satisfaction of this
preference will be addressed in a subsequent ROD on the Conrail
site, when a final decision for the site is made concerning
remediation of source areas and the groundwater.
-------
I 0.
APPENDIX A
ADMINISTRATIVE RECORD INDEX
-------
~age NO.
O~/18/91
FICHE/FRAME PAGES DATE
6 90/06/00
I. 91/03/00
10, 91/01./00
65 90/01./00
62
91/02/05
1.:.
91/01,/00
170
91/01,/00
TiTlE
Progress Report,
Conrail Railyard Site
Fact Sheet on Conrail
Rail Yard Superfund Site
Proposed Plan for
Interim Remedial Action
Preliminary Evaluation
of Phase I R I Resul ts .
and Interim Remedial
Alternatives for
Conrail/County Road 1
Remedial Investigation/
Feasibility Study
~ork Plan for the
Phase II Remedial
Investigation and
Phasea Feasibility
Study
Proposea Plan
Phased Feasibility
StUdy Report
ADMINISTRATIVE RECORD INDEX
UPDATE tl1
CONRAIL RAILYARD SITE
ELKHART, INDIANA
AUTHOR
USEPA
USEPA
USEPA
Ecology & Environment,
Inc.
Ecology i'Environment,
Inc.
Dennis Dalga"USEPA
Ecology 6 Environment,
Inc.
RECIPIENT
D. Dalga, USEPA
USEPA
USEPA
~~
.
.
DOCUMENT TYPE
DOCNUMBER
Fact Sheets
Fact Sheets
2
Fact Sheets
3
Reports/Studies
/,
Reports/Studi es
5
Reports/Studies
6
Reports/Studies
7
'.
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(
Page No.
0(,/18/91
TITLE
Dischar;e of Wastewater
from CERCLA Sites into
Publicly Owned Treatment
Works (POTWs)
Superfund Risk Assessment
Information Directory
Superfund Federal-Lead
Remedial Project
Management Handbook
Data Quality Objectives
for Remedial Response
Activities: Development
Process (Volume 1)
Data Quality Objectives
for Remeoial Response
Activities: EAample
Scenario: R:/FS
Activi~ies at a Site
~ltn Contaminated
So; Ls and Grouno Water
'Volume 2)
Cata Quality Objectives
for Remeoial Response
Activities: Volumes
1 & 2
A COJl'C)eno i un of
Superfund Field
Operations
Guidance on Providing
Alternative water
Suppl i es
Superfund EAPOsure
Assessment Manual
Ccmmunlty Relations tn
Sucerfuno:
A HanocooK
':nterim Guicance)
:ERCLA CompLiance ~itn
:~ner La~s ManuaL:
GUIDANCE DOCUMENTS INDEX, UPDATE r1
CONRAIL RAILYARD SITE
Guidance Documents are available for review at
USEPA Region V-Chicago IL
AUTHOR
DATE
USEPA
86/01,/15
USEPA
86/11/0D
USEPA
86/12/00
USEPA
87/03/00
. USEPA
87/03/00
USEPA
87/03/00
USEPA
87/12/D1
USEPA
88/03/01
USEPA
88/0(,/00
USEPA
8S/()6/00
USE?A
as/C8/CO
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Page No.
01.118/91
2
TITLE
Overvie~ of Applicable
or Relevant and
Appropriate Requirements
(ARARs) . Focus on
ARAR Waivers
Field Screening Methods
Catalog
Superfund Analytical
Data Revi e~ and
Oversight
Guidance for Conducting
Remedial Investigations
and Feasibility Studies
(RI/FS) Under CERCLA
User's Guide to Contract
Laboratory .program
Guidance on Remedial
Actions for Contaminated
Ground Water at Superfuno
Sites
RisK Assessment Guioance
for Superfund, Volume 11:
Environmental Evaluat;on
Manual
A Cuide on Remed\al
ACtions for Contaminated
Grouna Water
POlicy for Superfund
Comcliance ~ith t~e
RCRA Lana OispOsal
Restr1ctions
ACOlicaole or Relevant
ana Acprocriate
Reoulrements (ARARs)
:s ,j, As
-eSuLts of FY'!!8
~e::~c CT ~~:~S1C~
GUIDANCE DOCUMENTS INDEX, UPDATE #1
CONRAIL RAILYARD SITE
Guidance Documents are available for revie~ at
USEPA Region V-Chicago IL
AUTHOR
DATE
USEPA
88/08/00
USEPA
88/08/18
USEPA
88/10/00
. ~SEPA
88/12/00
USEPA
88/12/01
USEPA
89/03/00
WSEPA
89/01./00
. USEPA
89/01./17
~SEPA
89/05/00
~SE~A
89/05/01
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I
Q.
"'"
Page No.
0'-/18/91
3
TITLE
AnaLysis
ControL of Air
Emissions from Superfund
Air Strippers at
Superfund Ground ~ater
Sites
CERCLA COmpLiance with
Other Laws ManuaL,
Part II: CLean Ai r Act
and other EnvironmentaL
Statutes and State
ReQui rements
EvaLuation of Ground
~ater Extraction
R~ies, Volume 1:
Sl.mI\Bry Report
CERCLA Compliance with
Other Laws Manual:
Guioe to Manual
Evaluation of Ground
~ater Extraction
R~ies. Volume 2:
Case Studies 1.19
(Interim Final)
CERCLA Comcliance with
Other Laws Manual:
RCRA (Resource
Conservation ana
Recovery Act) ARARs
(AppLicabLe or Relevant
and Appropriate
ReQUirements) fOc,us
on CLosure Reouirements
Getting Resay:
tl'le O1I/FS
ScoDing
A Guioe to DeveloDing
S.oerTuna proooseo Plans
A G~loe to Develc:'ng
5_~er;~na Re::rcs :~
GUIDANCE OOCUMENTS INDEX, UPDATE #1
CONRAIL RAILYARD SITE
Guidance Oocuments are availabLe for review at
USEPA Region V-Chicago IL
AUTHOR
DATE
USEPA
89/06/15
USEPA
89/08/00
USEPA
89/09/00
USEPA
89/09/00
USEPA
89/10/00
USEPA
89/10/00
USEPA
89/1 I /00
USEPA
69/1 1/00
USEFA
~9/11/00
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I
Page 110.
04118/91
" "
TITLE
Decision
The Feasibility Study:
Deve l O~t and
Screening of Remedial
ACtion Alternatives
Guidelines for Effective
Management of the
Contract Laboratory
Program, Part 1:
Contract Award. Part 2:
Contract Administration
The Remeaial
Investigation: Site
Characterization and
Treatibi l ity Studies
Guice tor. Conducting
Treatability StUdies
Uncer CERCLA (Interim
Final)
Risk Assessment Guidance
tor Superfund, Volume J:
Human Health Evaluation
Manual, Part A
CfRCLA Compliance with
Other Laws Hanual:
CERCLA Comcliance with
State RequIrements
CfRCLA Compliance with
Other Laws Hanual:
CfRCLA Compliance with
the Clean Water ~ct (C~A)
ana the Safe Drinking
~ater Act (SDWA)
The Feasibility StUdY:
:eta; lee Analysis Of
~eme-c;al Action
Alternatives
-eSuLts oT FY-89 Recore
:" :eclSl0n AnaLYSIs
GUIDANCE DOCUMENTS INDEX, UPDATE #1
CONRAIL RAILYARD SITE
Guidance Documents are available for review at
USEPA Region V-Chicago IL
AUTNOR
DATE
USEPA
89/1 1/00
USEPA
89/11/00
USEPA
89/1 1/00
USEPA
89/12100
USEPA
89/12100
USEPA
89/12100
USfPA
90/02100
USfPA
90/03/00
"SEPA
90/03/30
-------
'Pag~ No.
01./18/91
~
TITLE
R i sit Ass~ssment
Guidance for Superfund,
Volume I: Human Health
Evaluation Manual,
Part A
A Guide to Selecting
Super1und Remedial
Actions
CERCLA Compliance with
Other Laws Manual,
Summary of Part II: CAA,
TSCA, and Other Statutes
ARARs Qs & As:
Comcliance with the
Toxicity Characteristics
Rule: Part 1
ARARs Qs & As:
Comcliance with Federal
,
~ater Quality Criteria
Sasics of Pumc and
Treat Ground ~ater
Remeciation Technology
,
CERCLA Site Discharges
to POT~s: Guidance
Manual
Evaluation of Ground
Water Extraction
Remecies, Volume 3:
General Site Data, Data
Sase Reports (Interim
F ;nal)
GUIDANCE DOCUMENTS INDEX, UPDATE .1
CONRAIL RAILYARD SITE
Guidance Documents are available 10r review at
USEPA Region V-Chicago IL
AUTHOR
DATE
USEPA
90/OJ./00
USEPA
90/OJ./00
USEPA
90/01./00
USEPA
90/05/00
USEPA
90/06/00
USEPA
90/09/00
USEPA
90/09/00
USEPA
90/10/00
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Page No.
01./18/91
ACRONYM
ARARs
CERClA
CIJA
POTIJS
RI
RI/FS
SDIJA
USEPA
"1
ACRONYM GUIDE
Conrail
DEF I NI T ION
Applicable or Relevant
and Appropriate
Requirements
C~rehensive
Environmental Response,
C~nsation ana
liability Act of 1980
Clean IJater Act
Publ iCly Owned
Treatment IJorks
Remedial Investigation
Remedial Investigation/ .
Feasibility Study
Safe Drinking ~ater
Act
United States
Env; rorvnental
Protection Agency
for the Administrative Record
Railyard Site, Update #1
Elkhart, Indiana
-------
'0: J. (f)
: 130
ADNI'ISfRArIFI RICORD I'D II - ORIGI'AL
CO, RAIL RAILfARD SOPIRIUJD SIrl
'LIBARf, IIDIA.A
'IIRAKE PAGES DArE rIrLE AurBOR "CIPI"r DOCUKrrr rTPE DOC'UKBER
1 00100100 Lttttr (fon) Staa RttdT, '.D. - 'CBD Stt DocDlut Corrupoadtact , 1
. Rtl Pottatial
Groundrattr
CODtuiaatioa
8610~117 Lttttr D.Sttiakt - RAL, IDc. '.IJtcb CorrupoDdtDct 2
h: tbt .up.lt
of rattr taktD
bOlt OD
J~Ot 13, 1986
86107/25 £ttttr StaD Rttdy, '.D. - ICHO Local ruJdtot, CorrupoDdtoct 3
h: rtll
rattr cootalioatioo
86107/31. L!Wr D.Sttiokt . RAL, lac. C. Ivt T5 Corrt!poDd!Dct
Rt: analytical up~rt
for rater '~Iplts
colluted ~D
July 26, 1986
86107/31 LtttH D.SttiDkt - RAL, IDC. D.SpaDglt CorrupoDdtDCt 5
. Rt: analytical ltr~rt
for rattr salplts
collecttd ~D
Ju1, 30, 1986
86107/31 LtttH D.Sttiakt - RAL, ID'. 1.laDccek CorrupoodtDce 6
Rt: aDalytical rtp~rt
for tbt ,attr .alplt
colltcttd OD
July 30, 1986
2 86109130 Lttttr Valdas r. Adalkus . OSKPA J.liltr - loose of CorrupoDdtDCt
Bt: ~utSti ODS Rtp,.
CODCtrDiDg tbe
rtctDtly discovertd
groond rICtr
cODtaliDatioD problel
rtH of Elkbart,
IDdiaDa
86110101 Letttr l.rbeistD - USrPA G.GaDStr CorrupoDdeDce 8
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'5/90
ADKIIISrRArIfl RICORD IIDII - ORIGINAL
COIRAIL RAILfARD SUPIR1DlD SIrl
ILKHARr, I'DIAIA
:E/1RAKE PAGES DArE rIfLE ADrHOR RlCIPIElr DOCUK"r rrpg DOCNDKBER
Rt: USEFA
supliog
of residtot' s
IItll rattr
86 /J 0101 Lt t ttr l.rbti,tD - OSIPA J.raidtlicb CorrespODdtoct 9
It: OSlFA
supliog
of ruidtot 's
IItll rattr
86/J0/07 Letttr K.rbeiseo - OSIPA 1.lirer Corrupoodtoce 10
It: OSEFA
5upliog
of resideot '5
rell ratH
85/J0/07 Letter K.rbeiseo - OSIPA '.Beodelloo Oorrespoodtoct 11
Rt: USEFA
supliog
of resideot's
rell rattr
85110/10 . Letter K.rbeisto - OSIPA G.Kootgo.ery Correspoodeoce 12
Re: USEFA
5a1pllog
of resideot's
r,~ll raUr
86/J0/J0 Letter K.fbei'eD - USEPA J.Hopper Corre,poDdeDce 13
Re: USEFA
5a1pliog of
resideot'5
rell rattr
86/10/J0 Letttr l.rbei,eo - OSIPA L.Clnt Correspoodeoce 14
Rt: 'OSEn
Ia.pliog
of usideot',
rell rater
86/10/14 LettH K.fbeiseo .OSIPA B.Jeooiogs Corrupoodeoct 15
Re: USE FA
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~ Nit. 3 .
J6/90
ADKI*ISrRArlr. RleORD I*DII . OR1GI*AL
CO*RA1L IAILrARD SUPIRIU'D SIr,
.LIBARr, I'DIA'A
1E/IRAKE PAGES DArE r1nE AUriOR "CHInr DOCUKur rfPB DOC*UKBER
'..pliog of
ltSUeDt . 5
rell rater
2 87/02/13 Letter l.rbei.eD - USIPA I.DaDcb-St.Jo.epb CorrupoDdeDce 16
R'I iDquir, Coaot,
on po"ible ground
rater conta.inatioD
in tbe ,rea of a
propo.ed boa'iog
dtrtlopltot io
St. Josepb Couot,
-2 87/02/20 Letttr l.rbeiseo - USIPA G.Bbagavao CorrespoDdeDce 17
Re: USEn
groundrattr
cODtnioatioD
infonatioD
.1 88/06/27 Letter serring If.Gade - USIPA Con,01idate1 Rail Corre'pondeDce 18
as Sp~cial Notice Corp.
of FottDtial
Liability
. torards CODsolidattd
Rail Corporation
10 88/08/30 Letter R.luntz - r.B.A. , D. '.'ade - USBPA Corre'poDdence 19
responding to US'PA',
Special *otice of
PoteDtial Liability
" giren ander eERCLA
SectioD JZZ (e) (11
for Consolidated Rail
CorporatioD', (Conrail)
ritb eDcloStd
at tacbleo t,
88/09119 Letter acknorledging J.Con,taDtelo, - USBFA R.luntz-r.B.A.' D. Corlt.pondence ZO
tbe receipt of a
proposal dated August
30, 1988, fbicb ra5
sub.itted on bebalf
of Coosolidated Rail
Corporation (CoDrail)
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4 .
ADKIJISrRArIfl RICORD 1'011 . ORIGIJAL
COJRAIL RAILrARD SUPIR1UJD SIrl
ILIRARr, IIDIA.A
K/1RANE PAGIS DArE
fITLE
AureOR
RICH nn
DOCUHENf rUI
DOCNUKBER
9 89/12121 Letter cOllenting f.P. Penderga,t . Conrail D.Dalga. USIPA Corrupondence 21
on tbe USEPA lork
Plan tor tbe Conrail/
Country Road 1
Project (attacblent,
incl uded J
8 89/07/00 USEn USnA lact Sbeet 22
lact Sbeet
Conrail Railyard Site
Elkbart, Indiana
86/07/00 1act Sbeet IlCt Sbeet. 23
Elkbart, Indiana
County Road 1 Area
J 89/11/03 Kelo to doeulent D.Dalga . USnA B.Borenziak . I & I, Neiorandul 24
approval ot Ii nor Inc.
cbanges in tbe RI/1S
related tc field
,a.pling activities
H 89/11/16 recbnlcal Ke.o K.Gera.inegad-1 & ',Inc. D.Dalga - USnA Ke.orandu. 25
Re: Soil Gas Sa.pling
at tbe Conrail/
County Road 1 Site
If;tb atta.~bed
cover letter and
lap
5 90/01/10 Tecbnical Kelo 1I.Gera.ioegad-1 & I, Inc. D.Dalga. USIPA IInorandul 26
Rei Aquifer
Cbaracteristic
Tests at tbe
Conrail/County
ROad 1 Site
Ifitb accolpanying
letter
26 '90/04/10 Tecbnical Kelorandu. Kebdi GerliDegad-I&I,Inc. Denni, Dalga - ltnorandul 27
of Groundwater USIPA
Nonitoring and Sa.pling
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5/90 ADKIJISrRA1IVl RICORD IIDIl - ORIGIJAL
COIRAIL RAILrARD 50P'RI0lD 5111
ILIBAR1, I'DIA'A
8/IRANE PAGES DArE rIfLE AorHOR IICIPIII1 DOCOKI" ffPB DOCNOIfBlR
at tbe Conrail/County
Road 1 Site
ritb corer letter
2 00/00/00 'ater Serrice Otber 2B
Connections,
Group J2
5 00/00/00 County Road One Stan Reedy, K.D. . ICBD Otber 29
!a$ter Well Li$t
5 00/00/00 Results of OSIFA Otbtr 30
..ater ..ell
salple$ collected
by USEPA
6 87/00/00 List of Otber 31
Residences
recei ring Point
of US! liltraticn
Uni ts
BE/07m PreS! Release Stan Reedy, «.0. - ICB~ PreS! Release 32
.
Re: an additional
area of ground..ater
contalination located
in tbe nortbrestern
portion of llkbart
County
I
2 86/07/25 Press Release Stan Reedy, 1.0. - ICBD Prus Release 33
Re: tbe ruu!ts
of tbe drinking
rater analysis
perforled by USBPA .
86/08/25 Press Release Stan Reedy, 1.0. - ICBD Prus Releue 34
Re: tbe result,
of tbe inres~igatjon
into tbe contalinatlon
in llkhart County
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/90
ADNIJISrRArIVI RICORD I'Dfl - ORI6IIAL
CO'RAIL RAILrARD SUPIRTU'D SIrl
ILIBAR', IIDIAIA
ITRAKE PAGES DAfE rIfLE AUrlOR IICIPIII' DOCUI!IJ' rfFE DOC/iUKBER
86/08/28 PItU Releue Staa 'eedr, '.D. - ICBD PIt" 'eleue . 35
ReI grouadwater
coataliaatioa in
tbe Coontr Road
arta ot rUbart
County and rater
,a.pling conducted
by USEPA ia tbe
area
15 00/00/00 Tbe Coordination fCBD Report,/Stadiu 36
ot Local, State, aad
leceral Agencie,'
Respoase to Grouadwater
Conta.ination fpisodes
. ritb apptndices
86/06/22 Drinking rater S.Liggett - fLS, Inc. I.Tltcb ReportslStadiu 37 '\
Cuality Aaalysis:
litcb aew residtace
(Elkbart) rell rater
86/08/05 Drinking rater R.S.Liggett - fLS, Inc. A.Joba.oa Report,/Stodiu 38
. Cuality Aaalysis
86/08/12 Volatile Organic fIS Inriro. 'ngia., lac. B.llarrtl, Jr. Report,/StDdiu 39
Co.pound (VOC )
Analysis Report
86/08/14 Drinbag 'ater S.Liggett - 'LS, Inc. '.Jlblondr Report,/Stodiu 'O
puality Analy,is,
Jablonsky re,idence
rtll rater
J33 86/09/00 Regipnal GroDnd rater reston-Sper DSfPA Report,/Stadies .1
Inrestigatioa ot
Volatile Orgaaic
Ccata.ination in
Ilkbart, Iadiaaa
71 86110/00 Si tt AHt!Sltnt futoa-Sper USEPA Rtport,/Stadiu 42
lor
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I 0
~. 10.
.'6/1/
7 .
AD!IIISrRArIrl .,CORD I'DIZ - ORI'IIA£
eOJRAIL 'AILrARD SUPIRIU.D SIrl
ILIBA'f, I'DIA'A
:E/IRAKE PAGES DarE rIfLE AUrBOR fleIfIllf DOCUK"f rrpg DOCIUlfBIR
Coarail Rail,ard
111bart, ladiaaa
35 86/lJ /26 Sappleleat to tbe 'ntoa-Sper IJcblel StrJlba - leport./Stadin f3
Coarail Site A.ses.leat 'SIP!
Report
8 86112131 "~ter Saaple DrPC/'S leBD Report./Stadiu U
Idtatiticatioa
SbH ts
21 88/0311 0 Oa-Setae Coordiaator'. ltaattb rbei,ea - US'PA Report./Stadit. f5
Rtport CIRCLA
Illtdiate Re.oral Action
lfain Street fell lield,
last Jacksoa Arta
Ilkbart, Iadiana
9 89/03/00. Preliliauy ladiaal Statt Bt.ltb Dtpt Rtport./Stndiu H
Bealtb Assts'ltat
tor Coarail
Rail yard
23 89/05/00 COlluaity Relatioa. Plaa Icology and lariroaltat US"A . Report,/Studi(. 47
lor
'oarail/Couaty Road J
llkbart, lediaea
111 89/07/00 Coarail/ Icology lad leriroaleat IISln Report./Studiu 48
Couaty Road 1 Projtct
Rtltdial Iare,tigatioa
ADd Ita,ibility Study
(RI/ISI rork Plaa
288 89/07/00 Coorail/CouDty Road J Icology ADd larirODltDt US"A Report' /Stud J u 49
Project
Reltdial Iart.tigatJoD
Aad lta,ibility Study
(RI/151 Salpliag aa~
ADaly.i. Plaa
rork Auignltat
(IA) 01-5L71
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No.
:/90
8 .
'/FRAHE PAGES DArt
692 B911J/JO
rinE
Subsurface Iare,t1gatioa
For fbe
Coarail Elkbart Railyard
Elkbart, Iadiaaa
ADKIJISfRAfIVE'RECORD 1.DEI . ORIG11AL
COIRAIL RAILrARD SDPERIDID SIfE
ILIBARf, I'DIA'A
ADfBOR
RlCIPI"f
GroDadrater flcbaology
CODsol1datld Rail
Corp.
o
DOCDKnf frPE
DOCIDKBER
'lport,/StDdiu . 50
I
-------
Pagt '0.
'6/90
DArg
rrrLl
89/0D/00 Varioas Salpliag Data:
Cbtlical data ot
groaadrattr, surfact
rater, sabsurfact
lattrial, ,oil boriag,
aad stdiltat salplts
(32 pagts)
ADKl*IsrRAflV' "CORD SAKPL1'G/DAfA IJD'Z
Coarail R.ilT.rd Soperfaad Site
DOCUKr*rs 'OT COPl'D, KAr 81 IIVllf'D AT rBI
DS'PA "'10' r OlliCIS, CBICAGO, 1££1'015.
AUTBOR
RlClPI"T
Duhora
'SIPA
DOCDK"T npg
$lIpl1ag Data'
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Page No:
07/06/90
ACRONfK GUIDE for tbe Ad.iai'tratire Record
Coarail Railyard Superfuad Site
Ilkbart, Iadiaaa
ACRORYK
DEFINIrIOlt
CERCLA Co.prbeuive
IDriroueatal
Rupoue,
COIpeautioa,
aad Liability
Act of 1980
Coarail Coasolidated Rail
Corporatioa
DrpC/GS Dirisioa
of rater Pollutioa
Coatrol
Grouadwater Seetioa
E « E, Ecology aad Eariroa.eDt,
IDC. IDC.
ECBD Ilkbart Coucty
Bealtb Depart.eat
EIS EIS
lariro. IDviroa.ectal
EagiDeers,
IDc.
RAL, IDC. Regioaal
ADalytical
Laboratory,
IDC.
RIllS Re.edial Iare'tigatioD
ADd leasjbjjjty Study
IJSEPA UDited States
EDvirca.eDtal ProtectiOD
AgeDcy
VOC Volatile
OrgaDic
Co'pouDd
r.B.A. « rild.ao, Harrold,
D AlleD « DizOD
r.~ rork Assigo.eat
NU, IDC. rillials
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.pagt Jo.
o 07'~(/90
ACROJfN
2
ACROIYN gUIDE tor tbt Adliaistratlrt Rtcord
Coarail Railrard Suptrtuad 51tt
Iltbart, ladiaua
DllIRIrIOJ
Laboratory
Strrictl, lac.
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APPENDIX B
RESPONSIVENESS SUMMARY
CONRAIL RAILYARD SITE
ELKHART COUNTY, INDIANA
The United states Environmental Protection Agency (U.S. EPA) has
recently completed a first phase of Remedial Investigations (RI),
and prepared a Phased Feasibility Study (PFS) regarding the
Conrail Railyard site located in Elkhart County, Indiana. During
the RI and PFS, information was collected on the nature and
extent of contamination at the Conrail site, and alternatives for
addressing interim groundwater remediation were developed and
evaluated. At the conclusion of the PFS, a Proposed Plan was
finalized by U.s. EPA which identified the preferred remedial
alternative for the Conrail site. U.s. EPA held a public comment
per.iod from April 19, 1991 to June 18, 1991, for interested
parties to comment on the U.S. EPA's April 1991 Phased
Feasibility Study Report and the Proposed Plan. U.s. EPA and the
Indiana Department of Environmental Management (IDEM) presented'
the Proposed Plan to the public at a May 1, 1991, public meeting,
where questions were answered and comments accepted from the
public.
The purpose of this Responsiveness Summary is to document the
comments received during the public comment period and U.S. EPA's
responses to these ,comments. All of the comments summarized in
this document were considered in U.s. EPA's final decision for
this interim remedial'action at the Conrail Railyard site.
I.
RESPONSIVENESS SUMMARY OVERVIEW
The phased feasibility study identified and evaluated alternative
remedial actions for interim groundwater remediation at the
Conrail Railyard site. Five detailed alternatives were evaluated
based on the nine criteria analysis as described in the Summary
of the Comparative Analysis of Alternatives. Based upon this
detailed evaluation, available information, and public comments,
the U.S. EPA and IDEM have determined that the most appropriate
interim remedy for the Conrail Railyard site is Alternative 5:
Groundwater Extraction System, and a Waterline Extension from the
City of Elkhart.
The major components of the selected remedy include:
- Installation of four extraction wells located in positions
td adequately contain the migration of contaminants in the
groundwater;
1- Providing for adequate treatment of groundwaters thus
collected such that the resultant discharge ,will meet
National Pollutant Discharge Elimination System (NPDES)
limitations as imposed by the program administered by the
State of Indiana;
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I Q
2
- Installation of about 67,000 feet of distribution line, of
various sizes, for the distribution of City of Elkhart water
to approximately 505 residencesfbusinesseswho are
potentially at risk from exposure to the contaminated
groundwater;
- Conducting groundwater monitoring to ensure the
effectiveness of the remedial action; and
- Fencing the groundwater extraction facilities, as well as
advisories and well abandonment for residences and
businesses in the area of groundwater contamination.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT
u.s. EPA and IDEM have been interacting to varying extents with
the community, in terms of the Conrail Railyard site, since
contamination was first found in residential wells in 1986.
Informal interactions with the community took place during the
Removal action, through the sampling of wells and the provision
of bottled water, carbon filters, watermain connections, etc. In
addition, IDEM has been in contact with residents since that time
as a part of its periodic sampling of residential wells, and
maintenance of the carbon filter systems.
,
With respect to the. remedial activities, community relations
activities began in late 1988, with the development of the
Community Relations Plan. In accordance with that plan, various
meetings have been held, and facts sheets have been issued. An
RIfFS kickoff meeting, held in July 1989, was attended by about
150 people. Availability sessions held in the afternoon and
evening of June 26, 1990, to discuss 'the results of the first
phase of investigations were also widely attended. Four fact
sheets have been issued since July 1989.
Through these meetings, and other interactions with the public,
various concerns were voiced by residents of the area, and
others. In particular, the potential health effects from the use
of contaminated groundwat~r has been a major concern.
Specifically, questions were raised about the effects of exposure
to the cQntaminants of concern, at the levels found. In
addition, concerns were raised relative to the effectiveness of
the carbon filters, particularly the point-of-use filters, and
the lack of such filters at some residences. Residents are also
concerned about the apparent decline in property value of their
homes, as a result of the impacts from a Superfund site.
Residents have also expressed frustration at the length of time
it has taken to study the site, prior to cleanup"
Community interest is further evidenced by the creation of a
local community interest group, which has been extensively
involved in the subject project, in part, through verbal and
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3
written communications
coverage has also been
the project, including
television stations.
with both u.s. EPA and IDEM. Media
fairly extensive throughout the life of
coverage by local newspapers and
The Proposed Plan for this interim action was released to the
public on April 19, 1991, outlining remedial alternatives, and
informing residents that the PFS and all other documents
comprising the Administrative Record for the site, were available
at the public information repository at the Elkhart Public
Library. A public comment period was held from April 19, 1991,
to June 18, 1991, and a public meeting was held on May 1, 1991,
to discuss the proposed remedial action with the residents. The
public meeting was attended by about 150 people, with numerous
questions asked, and seven oral comments received.
III. SUMMARY OF SIGNIFICANT COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND U.S. EPA RESPONSES
Comments raised during the Conrail railyard comment period are
summarized below. The comments are paraphrased in order to
effectively summarize them in this document. The reader is
referred to the public meeting transcript and written comments
available at the public repository for further information.
Comment l:A number of residences commented that the residential
area which receives its drinking water through a private utility,
Suburban Utilities, should also be connected to the municipal
wa~er system. A couple of the residents said that their water
looks, smells, and/or tastes bad, adding that little, if
anything, has been done to check the quality of the water. In
addition, it was noted that this area is located within the study
area, downgradient of the Conrail Railyard, and between the LaRue
Street and County Road 1 contamination areas, with the
contamination of their groundwater essentially being inevitable.
The commentors advocated connecting 'the Suburban Utility area as
a part of this action, rather than monitoring the situation until
the contamination does reach the area. Finally, the commentors
noted that since a line from the City of Elkhart system already
runs to the Suburban Utility system, to serve as a backup, it
would be easy and inexpensive to connect the Suburban Utility
serviced area, as a part of this interim action.
Response: The Suburban utilities Well Field is located in an
area between the LaRue Street and County Road 1 areas of
contamination (as can be seen in Figure 2 of the ROD). Samples
of water drawn by the well field have been taken, and have not
been found to contain any of the contaminants of concern with
respect to this project. In addition, residences serviced by the
Suburban Utilities have been sampled, with the same results. To
the east of Suburban utilities (in the LaRue Street area), the
nearest residential wells, in which contamination has been found,
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4
are about half a mile away. To the west of Suburban utilities,
the nearest residential well found to have contaminated
groundwater, was over a mile away (in the County Road 1 area).
Finally, no contamination was found in either of the monitoring
wells located between the Suburban utility Well Field and the
Conrail Railyard (upgradient of the Well Field). In addition,
based on what we know, at this time, relative to the extent of
the groundwater contamination and the direction of groundwater
flow, th~re does not appear to be migration from the areas of
known contamination, to the Suburban utility Well Field.
Accordingly, since the contamination has not been found to
migrated to the area of the Suburban utilities Well Field,
it ~ikely to migrate to that area in the immediate future,
EPA is not taking any action to provide this area with an
alternate water supply, as a part of the interim groundwater
actions pursuant to the ROD. without this basis, there is no
need to evaluate other factors such as ease of connection.
have
nor is
u.S.
Residents who are not connected to the Elkhart water supply
system, through this action, will also be protected from
migration of the contaminants, to some extent, by the groundwater
extraction system, which will be drawing contaminated water out
of the aquifer. In addition, the selected remedy will include
monitoring of the groundwater contamination, to ascertain if the
contamination is spreading. However, if, at any time, it is
revealed that there is a threat to the public health from the use
of this well field as a result of contamination from the site,
action will be taken to supply those affected residences with an
alternate supply of potable water.
Comment 2: The State of Indiana's Office of utility Consumer
Counselor also recommended in a comment that the Suburban
utilities area be connected to the proposed water supply system.
The Office of Utility Consumer Counselor made some of the same
points as the residents, as addressed under Comment 1. In
addition, the Office of Utility Consumer Counce lor commented that
Suburban Utilities draws its water from the same aquifer that has
been determined to be contaminated, and noted that Suburban's
wells are closer to the Superfund site than at least two of the
other included areas.
Response: Although the Suburban Utility wells may be in the same
aquifer where the groundwater contamination has been found, no
contamination has specifically been found in the Suburban
utilities area, nor does it appear that the Suburban utilities
area is at risk. Although Suburban utilities may be closer to
the Conrail Railyard than the Vistula and Charles Avenue areas,
no contamination has been found in the Suburban utilities area,
whereas it has been found in both. the Vistula and Charles Avenue
areas. Also, based on what we know, at this time, relative to
the direction of groundwater flow, there does not appear to be
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I
5
migration from the areas of known contamination, to the Suburban
Utility Well Field.
Comment 3: A couple of residents had comments relative to if and
when the individual carbon units, installed during U.S. EPA's
Removal Action, would be removed.
Response: When the carbon filtration units were installed in the
residences, these units were given to the residents, with the
understanding that the system is their property and their
responsibility. Therefore, once residents are connected to the
Cit~ of Elkhart water supply system, they may do what they wish
with the units. It is expected, however, that wells will be
abandoned in the area of groundwater contamination.
Comment 4: A few residents agreed that Alternative 5, the
selected remedy, is the most logical course of action to address
the groundwater contamination problem associated with the site.
Response:
No response is necessary.
Comment S: One resident said that since information provided by
employees of Conrail has indicated that Conrail has been cleaning
engines, and ptherwise using chemicals such as TCE, controls.
should be placed on Conrail to have them cease and desist these
activities.
Response: As with anyone who uses chemicals, Conrail is required
to follow specific guidelines, such as those specified in RCRA,
relative to the storage, treatment, and/or disposal of such
chemicals. Any such controls, as s~ggested above, fall under the
purview of these requirements, and are not something which needs
to be addressed as a part of the specific actions taken to be
taken under this ROD.
Comment 6: A couple of residents noted that the people who are
responsible for the contamination problem should be held
accountable, and should be forced to take care of the problem.
,
Response: U.S. EPA and IDEM intend to pursue enforcement options
against parties responsible for the contamination at the Conrail
Railyard site. The United States has already filed a civil
action against Consolidated Rail Corporation in Cause No. S90-56
in U.S. District Court of Indiana, South Bend Division for past
costs and for future costs incurred at the site by the United
States.
Comment 7: One resident was concerned that water which had
backed up in his basement, from Crawford Ditch, is contaminated.
Response: Samples taken in Crawford Ditch, as a part of the
first phase of the remedial investigations, showed no
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I ~
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6
contamination.
Comment 8: One resident expressed a preference for Alternativ.e 2.
- Groundwater Extraction System, and Distribution of the
Extracted and Treated Groundwater to Affected Residents. This
individual stated that this preference is based on his perception
that Alternative 2 offers a higher degree of protection than
Alternative 5, since the Elkhart Water System has a contaminated
well field and is currently using air strippers. In addition, he
said that Alternative 2 would assure a higher degree of reduction
of toxicity and mobility. Finally, he added that bringing in the
City of Elkhart could only bring in more problems for the
residents of the affected areas. He said that bring~ng in the
City will cause more delays. He also said that he does not want
to live in the City limits, and if connected to the City water
supply, he fears that the City will find it very tempting to
annex the area.
Response: As is discussed in the ROD, it is u.S. EPA's and
IDEM's belief that Alternative 5 provides a somewhat higher
degree of protection than Alternative 2. It is true that the
water supplied from the City of Elkhart will probably come from
the Main Street Well Field, which itself is contaminated with
TCE. However, TCE is the only contaminant of concern in the Main.
street Well Field, whereas there are two contaminants of concern
in the aquifer of the Conrail site. In addition, only a portion
of the Main street Well Field is contaminated, with this
contaminated groundwater treated with the air strippers, and then
diluted with the clean water extracted, thereby providing an even
cleaner water supply than is provided with the air strippers.
Finally the Main street Well Field is an established system, with
better demonstrated O&M capabilities than with the establishment
of a new system. All of the alternatives that include the
groundwater extraction and treatment system provide for
essentially the same degree of reduction in toxicity in the
extracted groundwater, while mobility of the groundwater
contamination will be reduced through the extraction system.
Alternat~ve 2 may provide a slightly higher degree of reduction,
since the extracted groundwater will be used as the water supply,
although treat~ent levels for discharge to the st. Joseph River
may dictate an equivalent level of treatment. Taking into
account these criteria, and all of the other criteria discussed
in the Decision Summary, u.s. EPA and IDEM believe that
Alternative 5 provides the best balance of those alternatives
which meet the threshold criteria of being protective of human
health.
Based upon dis=ussions with City of Elkhart officials, u.s. EPA
and IDEM do not believe that connection to the City of Elkhart
water supply will create more problems than the other
alternatives. The City has been quite cooperative to date in
working with us to develop the various alternatives, and has
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expressed a willingness to continue to work with u.s. EPA and
IDEM to ensure that the selected remedy is implemented. With
respect to concerns about annexation, City of Elkhart officials
have stated to us that annexation is not a necessary prerequisite
to connection to the City of Elkhart's water supply.
Comment': Another resident suggested using a combination of
Alternatives 2 and s. Specifically, the resident suggested
connecting the residents in the LaRue Street area to City of
Elkhart water, while providing all of the other affected areas to
a new water supply created from the groundwater extraction
system. The reason for suggesting the connection of the LaRue
Street residents to the City of Elkhart, was based on the ease of
th~s connection. Many of this resident's reasons for preferring
Alternative 2, for a majority of the area, were the same as those
expressed above under Comment 8. The resident also commented
that he hoped that our plan includes fire hydrants, free of
charge, with one such hydrant near the school in the area.
Response: For the reasons specified in the ROD, and reemphasized
in the response to Comment 8, U.S. EPA and IDEM believe that
connecting all affected residents to the City of Elkhart water
supply system, as is provided for under Alternative 5, provides
the best balance of those alternatives which meet the threshhold .
criteria of being protective of human health. With respect to
the fire hydrants, 'the water distribution system, as proposed,
includes such fire fighting capabilities. Although the exact
location of fire hydrants will not be determined until the
design, locating such a hydrant near the school will be kept
under consideration. Although the hydrants will be provided free
of charge, maintenance of the hydrants will be the responsibility
of those who will maintain control over them.
Comment 10: One resident expressed concern about whether the air
stripper would put the contaminants into the air for them to
breath. .
Response: Emissions controls will be used, if necessary, to
protect against exposure to contaminants during the remedial
action. .
Comment 11: A resident expressed concern over the size of the
groundwater extraction and treatment system, and whether the
system will be designed to fit in with a residential area. A
concern is that such a system, in the middle of a residential
area, might cause property values to go down.
Response: The actual design and placement of the extraction
wells and treatment system will take this concern into account
during the remedial design phase .of the project. The containment
of the groundwater contamination, however, will be the primary
consideration in locating the system.
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comment 12: A couple of residents expressed concern over the i
effect that the groundwater extraction system might have on wells
in the area. In one instance, a resident noted that he wanted to
be able to continue to use his outside well for watering.
Response: Prior to, and during, the operation of the groundwater
extraction system, various things will be done to ensure that the
impact on wells, which remain active, is minimized. During the
design, modeling of the groundwater, and field testing of the
pumping systems is planned. Once operation begins, the system
will be monitored and modified, as necessary, to minimize the
impact by the system on active wells.
It should be noted, however, that the selected remedy will,
include the capping of wells at those residences/businesses who
are connected to the water supply extension. This is a necessary
step in ensuring that individuals are not exposed to the
contaminated groundwater.
Comment 13: conrail stated that it is their belief that
providing an alternate water supply for the Charles Avenue area
is excessive, and an inappropriate interim remedial action, since
there is no factual information regarding actual or likely
threats of groundwater contamination in the Charles Avenue area.
They went on to state that this belief is based on the lack of
water. quality information for the area, and the fact that there
is no information to indicate that any of the residential wells
in the Charles Avenue area are contaminated. Conrail also added
that no contamination has been detected in the EPA installed
monitoring wells upgradient of the Charles Avenue area, ncr is
there any information that there is upgradient contamination
which would reach the Charles Avenue'area before the RI/FS and
final remedy selection can be completed.
Response: U.S. EPA and IDEM believe that the residents in the
Charles Avenue area are potentially at risk to exposure to
contaminated groundwater based upon the close proximity of
upgradient groundwater contamination to this area and the
direction and yelocity of groundwater flow. Thus, the provision
of an alternate water supply to this area is therefore justified
and necessary. Although no contamination has been found in any
of the residential wells samples to date, groundwater
contamination has been found in the Charles Avenue area in close
proximity to the Charles Avenue residences to be supplied, as is
discussed in the ROD. This contamination, which was found at
concentrations of 2,495 ppb and 388 ppb, for TCE and CCl4,
respectively, was found in wells installed by Peerless-Midwest,
Inc. in the northwest portion of the Charles Avenue area. The RI
and PFS show that the groundwater is flowing in a northwesterly
direction in the Charles Avenue area. Groundwater contamination
exists in wells that are downgradient of a majority of the
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Charles Avenue area, which itself is downgradient of the County.
Road 1 area. The groundwater flow direction, groundwater
velocity, and the similar contaminants, show that it is likely
that the groundwater in the Charles Avenue area is or may be
contaminated in the near future, and that the residents of the
area are potentially at risk with respect to exposure to the
contaminated groundwater.
Comment 14: Conrail stated that it is their belief that based
on the general lack of contamination detected in the Blaine and
Wolf Avenue areas, that a pUblic water supply is not necessary
for this portion of the County Road 1 area. They noted that
there has been only one well in this portion of the County Road 1
area which has had any reported contamination for the quarterly
sampling events which have occurred between 1986 and 1989.
Response: U.S. EPA and IDEM believe that the RI and PFS contain
sufficient information for the agencies to a make a decision that
the residences in the Blaine and Wolf Avenue areas are at risk or
potentially at risk with respect to exposure to the contaminated
groundwater, and should therefore remain a part of the County
Road 1 area to be connected to the proposed water supply system.
As you mentioned, one of the residences on Blaine Avenue was
found to have CCl4 in its well, at a level above the MCL. In
addition, these areas are in close proximity to other residences
with contamination,' which, with possible changes in groundwater
flow patterns, makes them susceptible to possible exposure to
contaminated groundwater, and therefore makes them potentially at
risk relative to exposure to contaminated groundwater.
Comment 15: Conrail stated .that the proposed extraction,
treatment, and discharge system is based on assumptions that are
inconsistent with known site conditions, is likely to have a
negative effect on identification of contaminant sources and
selection of a final remedy, and is an excessive and unnecessary
interim remedial action. Conrail further expanded upon this
comment as detailed below:
.
Comment 15a: Conrail stated that the proposed extraction
system is based on assumptions which are inconsistent with
known site conditions. Specifically, Conrail noted that the
system is based on the assumption that contaminated
groundwater in the County Road 1 area represents a single
contaminant plume, while the data indicates that the
contaminated groundwater is the result of at least two
different sources and there is more than one contaminant
plume in the area. Therefore, Conrail says that it is
impossibla to identify the center line of the plume in the
County Road 1 area, for placement of the extraction wells,
as is proposed. They further added that installation of the
proposed extraction system will cause mixing of the existing
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contamination from multiple plumes in the County Road 1
area, thereby altering both hydraulic and concentration
gradients. As a result, Conrail said that the proposed
Phase II, and subsequent investigations, which require
identification and int~rpretation of existing hydraulic and
contaminant gradients to locate contaminant source areas and
evaluate continuity between contaminant plumes, will be
ineffective and the objectives of the RIfFS will not be met.
RespoDse: The groundwater extraction system is intended to
be designed to best control the migration of the area of
contamination, and it was with this in mind that the PFS
proposed placing the extraction wells within the center of
the area of contamination. More data gathering will occur
during the Phase II investigations, and during the Remedial
Design to further assist in optimizing the design of the
proposed extraction system. The Phase II investigations
should begin and be completed prior to completion of the
design of the extraction system. Therefore, there does not
appear to be a reason for concern relative to the effect of
the operation of this extraction system on the ability to
meet the objectives of the RIfFS, including the proposed
Phase II investigations.
Comment 15b: Conrail contends that the data is incomplete
relative to tne vertical distribution of contamination, and
hydraulic characteristics of the hydrogeologic units within
which the contamination is located. They added that if the
proposed interim remedy is implemented prior to completion
of the remedial investigation studies, then .the design of
the interim remedy extraction well system will have to be
completed before the critical information necessary for
system design has been collected.
Response: U.S. EPA and IDEM believe that the RI and PFS
contain sufficient information for the agencies to make a
decision with regard to the selection of the interim
groundwater remedy for the Conrail Railyard site. The
information gathered is for this decision-making purpose and
is not necessarily sufficiently detailed enough to base the
actual design upon. U.S. EPA and IDEM agree that more data
needs to be gathered in order to fully delineate the
groundwater contamination. This data gathering is now
beginning as a part of the second phase of remedial
investigations. It is also agreed that more data needs to
be gathered to support the design of the interim groundwater
remediation. It is anticipated, however, that this data
will be gathered during the Remedial Design for the interim
groundwater remediation.
Comment 15c: Conrail stated that the proposed extraction
system will have a negative effect on identification of
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contaminant sources and thus the selection of a final
remedy. They noted that the proposed extraction system is
located in an area where the nature and extent of
contamination is not characterized, the rate of migration
has not been determined, and the sources of the
contamination have not been identified. Conrail said that
given the likelihood that the investigations necessary to
address these points could take many years, the proposed
extraction system would have an undesired effect on
completing the Phase II investigations, as well as
subsequent investigations. It was also stated that
implementation of the proposed extraction system as an
interim remedy may have a negative effect on the selection
of a final remedy. Conrail said that until the necessary
information has been collected, it cannot be known whether
an extraction system is necessary as a final remedy and, if
so, whether the proposed interim extraction system would be
consistent with the final remedy.
Response: U.S. EPA and IDEM agree that more data needs to
be gathered in order to fully delineate the groundwater
contamination, to further locate the source{s) of
contamination, and to further characterize the source{s) of
contamination. This data gathering is now beginning as a .
part of the s~cond phase of remedial investigations. U.S.
EPA and IDEM see no reason why such investigations should
not be completed prior to completion of the design of the
extraction system. with this in mind, and with the
information presented in the RI and PFS, U.S. EPA and IDEM
believe that the proposed interim action will not have a
negative effect on any final remedy, and that the proposed
interim extraction system will .be consistent with the final
remedy.
Comment 154: Conrail stated that the proposed extraction
system is an excessive and unnecessary interim remedial
action. They added that the proposed extraotion system does
not address either of the two primary objectives of the
interim remedial action. Specifically, Conrail said that if
a pUblic water supply is, in fact, provided to the necessary
affected residential areas, then the proposed extraction
system is not necessary because it neither provides a safe,
I,ermanent water supply to the affected residents, nor
prevents exposure to the contaminated groundwater.
Response: The U.S. EPA and IDEM believe that the proposed
extraction system is neither excessive or unnecessary. The
PFS states that the selected remedy for the interim remedial
action should, at a minimum, satisfy the primary objectives
mentioned by Conrail in its comment. The PFS also includes
secondary objectives for consideration, including minimizing
further expansion of contamination, and reduction of
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contaminant concentrations in the groundwater within the
study area. Although the water supply system will address
the needs of those who are currently or potentially at risk,
there is still the potential for the groundwater
contamination to migrate. The proposed groundwater
extraction system assists in preventing exposure of
additional residences, through controlling the migration of
the contamination, through the removal of contaminated
groundwater.
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