United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-91 '161
June 1991
Cry I
fS 72--- crt£! /1 b
oEPA
Superfund
Record of Decision:
Enviro-Chem
(North side Sanitary Landfill)
(Amendment), IN
u . S. Environmental Protection Agency
Region tit Hazardous Waste
Technical Information Center .
841 Chestnut Street. 9th Roar
PhUadelph~a. PA 19107
Hazardoul Waste CoIJectIon ..;i
information Re$ourCe .cem.~:.lf
USEP-ARegion 3. ..
PhIIQdeIphkJ. PA 19107
EPA Report Collection
Information Resource Center
US EPA R~on 3
Philadelphia, PA .19107
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50272.101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/ROS-91/161
I ~
3. Redpient'a Acceaaion No.
4. T1t8 Md Subfte
SUPERFUND RECORD OF DECISION
Enviro-Chem (Northside Sanitary Landfill), IN
First Remedial Action (Amendment) - Final
7. AulhOl1a)
5. Report Da"
06/07/91
I.
8. Piarformlng Organization R8pt. No.
8. P8rf0rmlng OrgainlDtlon Nama and AddN88
10. Projac:tlTaalllWork Unit No.
11. Contrac1(C) or Grant(G) No.
(C)
(G)
12. Sponaortng Org8nlullon Nama Md Addr8e8
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. TYJ18 of Report . Period CoV8f8d
Agency
800/000
14.
15. Suppl8m8nl8ry No-
11. Ab8W8Ct (Unlit: 200 _nla)
The Enviro-Chem site is a former waste recovery/reclamation/brokerage facility in
Boone County, Indiana. Adjacent to the site is another Superfund site, the Northside
Sanitary Landfill (NSL) which, prior to this Record of Decision (ROD) amendment, was
to be remediated in a combined remedy for both sites. Land use in the area is
agricultural to the south and east, and residential to the north and west, with
approximately 50 residences located within one mile of the sites. Runoff from the
sites is collected in a ditch which flows offsite and eventually empties into a
reservoir that provides approximately 6 percent of the drinking water for the City of
Indianapolis. Enviro-Chem began operations in 1977 as a recovery/reclamation/
brokerage facility, accepting solvents, oils and other wastes from industrial
clients. Accumulation of contaminated stormwater onsite, poor management of the drum
inventory, and several spills led to State and EPA investigations of the site.
Between 1977 and 1981, the State permitted Enviro-Chem to dispose of part of its
waste at the adjacent NSL. In 1981, a consent decree was issued against Enviro-Chem
giving them until November 1982 to comply with environmental laws and regulations.
In May 1982, the State ordered Enviro-Chem to close and environmentally secure the
(See Attached Page)
17. Document An8Iy8I8 L DncriJ*H8
Record of Decision - Enviro-Chem (Northside
First Remedial Action (Amendment) - Final
Contaminated Medium: soil
Key Contaminants: VOCs (PCE, TCE, toluene),
Sanitary Landfill), IN
other organics (phenols)
II. 1dan1l1l8nl0pen-EndacI T-
c. COSA T1 Fl8lcl/Group
18. Avallabllty ~
18. Sacurlty a... (11118 Report)
None
20. Sacurlty a... (This Page)
!\Inn<=>
21. No. of Pagea
18
22. Price
i
(SM AHSl-m.18)
SH /MrrucIiON on~-
(4.'71
(Formany NT1~35)
Departmant of Comnwrce
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EPA/ROD/R05-91/161
Enviro-Chem (Northside Sanitary Landfill), IN
First Remedial Action (Amendment) - Final
Abstract (Continued)
site because it failed to reduce hazardous waste inventories. Subsequently, two
emergency removal actions were conducted to remove the major sources of contamination.
From 1983 to 1984, approximately 30,000 drums, 220,000 gallons of waste, and 5,650
cubic yards of soil and sludge were removed offsite and treated. In 1985, 20,000
gallons of contaminated water were removed. A 1987 ROD provided a combined remedy for
both NSL and Enviro-Chem due to their proximity and other similarities. The 1987 ROD
addressed source control through soil excavating, dewatering, and onsite disposal,
followed by capping: pumping and onsite treatment of ground water; and implementing
deed and access restrictions. However, since the signing of the ROD, EPA and the State
have been engaged in negotiating with the PRPs for each site. These negotiations have
resulted in separate, complementary remedies and individual consent decrees for each
site, and modifications to the original selected remedy. This ROD amends the 1987 ROD
and provides a comprehensive site remedy for the Enviro-Chem site addressing source
control instead of ground water remediation. The primary contaminants of concern
affecting the soil are VOCs including PCE, TCE, toluene; and other organics including
phenols.
The amended remedial action for this site includes treating contaminated soil onsite
using soil vapor extraction with a granulated activated carbon system to control the
extracted vapor, if necessary: and implementing a contingent remedy for a subsurface
ground water collection and treatment system, based on monitoring results, if clean-up
objectives are not reached in 5 years. Other remedial actions documented in the 1991
ROD amendment include capping the site, implementing site access restrictions, and
monitoring of the subsurface and surface water are not affected by this amendment. The
estimated present worth for this remedial action ranges between $5,000,000 and
$9,000,000. No O&M costs were provided for this remedial action.
PERFORMANCE STANDARDS OR GOALS: 50il clean-up goals are based on ingestion of
subsurface water at the site boundary, and are calculated from the Acceptable
Subsurface Water Concentrations assuming a dilution of leachate to subsurface water of
1:196, and using established partition coefficients. Chemical-specific soil clean-up
goals include phenol 9,800 ug/kg, TCE 240 ug/kg, PCE 130 ug/kg, toluene 238,000 ug/kg,
and total xylenes 195,000 ug/kg.
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Declaration for the Record of Decision Amendment
'Site Name and Location
Environmental Conservation and Chemical Corporation,
Indiana
Zionsville,
statement of Ba.i. and puroo.e
This decision document, toqether with a Record of Decision dated
September 25, 1987, represents the selected remedial action for the
Environmental Conservation and Chemical Corporation site developed
in accordance ~ith the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and to
the extent practicable, the National Oil and Hazardous Substances
Pollution continqency Plan (NCP).
This decision is based on the contents of ~he administrative record
for the Environmental Conservation and Chemical Corporation site.
The attached index identifies the items which comprise the
administrative record upon which the decision to amend the 1987
Record of Decision, and the selection of the modified remedial
. action is based.
The State of Indiana concurs in the remedy selected by u.S. EPA for
the Environmental Conservation and Chemical Corporation site.
Descriotion of the Remedv
The primary reason for amendinq the 1987 Record of Decision is to
reflect the decision to implement separate, complementary remedies
for the Environmental Conservation and Chemical Corporation and
Northside Sanitary Landfill sites, instead of the one combined
remedy selected in the 1987 Record of Decision, and secondarily, to
modify the selected remedy.
For the Environmental Conservation and Chemical Corporation site,
the major components of the remedial action, as modified, include:
Soil vapor extraction, concentration and destruction
RCRA Subtitle Ccap
Access restrictions
Subsurface and surface water monitorinq
Contingent. subsurface water collection and treatment
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2
DeelaratioD
The selected reme~y, as modified herein, is protective of human
health and the environment, attains Federal and State requirements
that are applicable or relevant and appropriate to this remeaial
action, ana is cost-effective.
This remedy satisfies the statutory preference for remedies that
employ treatment that reduce toxicity, mobility or volume as a
principal element and 'ltilize permanent solutions and alternative
treatment technoloqies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaininq
on-site, pursuant to Section 121(c) of CERCLA, a review will be
conducted at the site within five years after commencement of the
remedial action and at least every five years thereafter to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
t
~~ 1 ~ ,Iqq/.
Date
Valdas V. Ada
Reqional Admi
Reqion V
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Record of Decision Amendment
Environmental Conservation and Chemical COrDoration
z.
LOCATION AND DESCRIPTION
The Environmental Conservation and Chemical Corporation (also
referred to as Enviro-Chem, or ECC) and the Northside Sanitary
Landfill (NSL) facilities are both on the Superfund National
Priorities List, and are located adjacent to each other. On
September 25, 1987, a Record of Decision (ROD) was signed which
selected a combined remedy for the two sites. Since the time the
original ROD was signed, u. S. EPA and the State of Indiana have
engaged in negotiations with Potentially Responsible Parties (PRPS)
for each site. These negotiations have resulted in separate
remedies for each site, individual Consent Decrees for each site,
this amendment to the 1987 ROD, and an amendment to the 1987 ROD
relating to the NSL site. The purpose of this ROD Amendment is to
describe the changes from the remedy selected in the 1987 ROD, as
they pertain to ECC.
The Enviro-Chem site is located in a rural area of Boone County,
about five miles north of Zionsville and ten miles northwest of
Indianapolis. Farmland borders the southern edge of the site and
borders the eastern edge of NSL. Residential properties are
located to the north and west, within one-half mile of the
facility. A small residential community, Northfield, is located
north of the site on U. S. 421. Approximately fifty residences are
located within one mile of the site.
An unnamed ditch runs north to south between the ECC and NSL sites,
along the western edge of NSL, and. joins Finley Creek at the
southwestern corner of the NSL landfill. Finley Creek runs along
the eastern and southern edges of the NSL site and flows into Eagle
Creek about one-half mile downstream from the sites. Eagle Creek
flows south from its confluence with Finley Creek for ten miles
before it empties into Eagle Creek Reservoir. The reservoir
supplies approximately six percent of the drinking water for the
City of Indianapolis.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The 1987 ROD set forth the history of the ECC site through the date
of its issuance. Subsequent to the issuance of the 1987 ROD, the
following activities of pertinence have occurred:
1. Both before and after the 1987 ROD was issued, a group of
defendants, who in 1983 had entered into a partial settlement of a
pending court action, proposed to clean up the Enviro-Chem site
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2
utilizing a soil vapor extraction system. In a letter dated
February 1988, U" S. EPA rej ected this proposal because, among
other deficiencies, the proposal failed to consider the cost of
pilot testing or of a granular activated carbon system to treat the
extracted vapor.
2. Subsequently, this group of defendants undertook a pilot soil
vapor extraction study at Enviro-Chem. The results of the study,
which was performed in June 1988, indicate that a vapor extraction
system, with certain enhancements, may significantly reduce the
levels of volatile organics and phenols in the soils.
3. These same parties then offered to perform a remedy at the
Enviro-Chem site utilizing a closed soil vapor extraction system,
with a granulated activated carbon system to treat the extracted
vapor. In response, U.S. EPA and the State of Indiana entered into
negotiations with these parties concerning the terms under which
they might assume responsibility for remediating the site. The
proposed Consent Decree and Exhibit A embody those negotiated terms
and provide the details of the remedy as it will be performed
pursuant to the ROD as amended, herein.
./
III.
COMMUNITY RELATIONS
..-
._-
This ROD amendment, as proposed, was available for public comment
for a thirty day period, pursuant to Section 117 of SARA. An
Administrative Record containing the documents considered or relied
upon in reaching the decision in this Amendment has been available
at the Zionsville Town Hall and at the offices of Region V, u.S.
EPA. in Chicago.
IV.
DOCUMENTATION OF SIGNIFICANT CHANGES FROM 1987 ROD
This ROD Amendment addresses those elements of the remedy which
have changed from the 1987 ROD and the requirements and preferences
under SARA. Many elements of the original 1987 ROD do not change.
Therefore, the findings made in the 1987 ROD remain the same except
for the changes described in this ROD Amendment.
The major differences between the remedy selected for ECC in the
1987 ROD and the remedy selected in this amendment are as follows:
The use of soil vapor extraction technology is selected
in this Amendment, instead of the ground water
collection and onsite treatment selected in the 1987 ROD.
The ground water collection and treatment selected in
the 1987 ROD would have resulted in cleanup of the site
after a long period of system operation, whereas the soi1
vapor extraction selected in this Amendment will result
in cleanup of the site in a significantly shorter period
of time.
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3
There were no on-site cleanup criteria specified in the
1987 ROD: this Amendment specifies Acceptable Soil
concentrat~ons, which are based on ingestion of
subsurface water at the site boundary and Acceptable
Subsurface Water concentrations based on 1x10-6 risk, on
Maximum Contaminant Levels, on Maximum Contaminant Level
Proposed Goals, or on Lifetime Drinking Water Health
Advisories.
If the soil vapor extraction does not reduce the
specified onsite contaminants to their cleanup standards
within 5 years, a subsurface water collection system may
be installed, the collected water treated in accordance
with Clean Water Act and CERCLA requirements, and
disposed of. This contingent activity is similar to
a major component of the 1987 ROD remedy, which required
collection and onsite treatment of ground water. However,
under this ROD Amendme~t, the interception of the ground
water will occur at a point nearer the ECC contamination.
Key portions of the remedy which remain the same from 1987 are
summarized here:
,
/
Access restrictions will be implemented to control use
of the site.
A RCRA subtitle C cap will be installed to prevent
contact with contaminated soils, and to reduce
infiltration. The cap will also enhance the vapor
recovery component of the amended remedy.
The off-site cleanup levels (Acceptable stream
Concentrations) remain the same as in the 1987 ROD,
except that a cleanup criterion for PCBs has been added,
which represents a 1x10-6 risk level.
direct
Monitoring of the subsurface water and surface water will
be implemented to ensure that no contamination exceeds
surface water standards (see Attachment 1).
This ROD Amendment selects separate and distinct remedies for ECC
and NSL, which do not encompass the additional area of
contamination south of ECC that was discussed in the 1987 ROD.
Pre-design investigations indicated that this is a discrete
contaminated area, and the cleanup of it will be pursued in another
manner.
During the design phases for both the ECC and the NSL remedies,
efforts will be made to ensure that the two remedies will be
compatible with each other.
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StTHKARY
ENVIRONMENTAL CONSERVATION AND CHEMICAL CORPORATION
DIFFERENCES BETWEEN 1'87 REMEDY AND REMEDY. AS MODIPIED
1'87 REMEDY
Combined remedy for ECC and NSL
MODIPIED REMEDY
Separate, compatible
remedies for ECC and
NSL
Ground water collection and
treatment
Soil vapor extraction'
Long-term treatment of ground
water
Removal of source of
contamination by
reducing concentra-
tions of organic chem-
icals to cleanup
levels within 5
years
./
--
No on-site cleanup criteria
Acceptable Soil Con-
centrations and Ac-
ceptable Subsurface
Water Concentrations
established
No additional remedial
requirements if cleanup
standards not achieved
Subsurface water col-
lection and treatment
instituted if soil
vapor extraction does
not achieve cleanup
levels in 5 years
Figure 1 shows some components of the remedial action selected in
this ROD Amendment.
V.
DESCRIPTION OP MODIPIED REMEDY
The technical attachment to the Consent Decree (Exhibit A) provides
details regarding the remedial action selected in this ROD
Amendment. The remedial action consists of the following general
components:
Soil vapor extraction, concentration and destruction
RCRA Subtitle C cap
Access restrictions
Subsurface and Surface Water Monitoring
Contingent subsurface water collection and treatment
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5
80i1 Va~or Extraction. concentration and Destruction
The objective of the soil vapor extraction activity is to remove
and destroy volatile organic compounds and selected base
neutral/acid organics from the soils through a series of injection
and extraction trenches. Operation of the soil vapor extraction
system will be terminated when the Acceptable Soil Concentrations,
as shown in Attachment 1, and discussed below, are achieved and
verified as specified below.
The 1987 ROD selected Acceptable Stream Concentrations as ARARs for
off-site subsurface water and for surface water. In addition, a
cleanup level for PCBs has been added, which represents a 1xlO-6
risk level. Achievement of the Acceptable Stream Concentrations
for off-site subsurface water and surface water are also required
in this ROD Amendment.
Because this ROD Amendment adds a source removal component,
additional standards and regulations are applicable or relevant and
appropriate. To confirm that the required level of cleanup of on-
site soils has occurred, this ROD Amendment establishes Acceptable
Subsurface Water Concentrations which must be met in on-site till
wells, and Acceptable Stream Concentrations which must be met in
off-site subsurface water and surface water.
Those Acceptable Subsurface Water Concentrations specified herein
are either risk-based standards, Maximum Contaminant Levels,
Maximum contaminant Level Proposed Goals or Lifetime drinking water
health advisories. The Acceptable Subsurface Water Concentrations
specified in Attachment 1 will have to be met in on-site till wells
as part of the post soil cleanup verification required to shut off
the soil vapor extraction system. In addition, these cleanup
levels form the basis for the Acceptable Soil Concentrations.
The Acceptable Soil Concentrations will have to be met in on-site
soil samples as part of the post soil cleanup verification required
to shut off the soil vapor extraction system. They are based on
ingestion of subsurface water at the site boundary, and are
calculated from the Acceptable Subsurface Water Concentrations,
assuming a dilution of leachate to subsurface water of 1:196, and
using established partition coefficients. The ratio of leachate to
subsurface water is based on Appendix C of the ECC Remedial
Investigation report.
Acceptable Soil Concentrations based on ingestion of soil were
considered, but were eliminated. For each parameter showing an
Acceptable Soil Concentration in Attachment 1, the standards based
on subsurface water ingestion are significantly lower than the
standards based on soil ingestion. Because the site will be
covered with a Subtitle C cap and direct contact with the soil will
be prevented, the pathway of most concern is through the subsurface
water.
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6
Achievement of the Acceptable Soil Concentrations shown in
Attachment 1 will be verified when each of the following is met:
(1) soil vapor collected from restarts of the system show
calculated soil vapor concentrations in equilibrium with the
Acceptable Soil Concentrations: (2) on-site till wells show
compliance with the Acceptable Subsurface Water concentrations,
also shown in Attachment 1: and (3) soil samples collected onsite
show compliance with the Acceptable Soil Concentrations.
When verification has been demonstrated, operation of the soil
vapor extraction system will be terminated. If the Acceptable Soil
Concentrations are not met within five years, u.s. EPA may require
implementation of the leachate/subsurface water collection and
treatment system.
RCRA subtitle C CaD
The cap placed on the site will have multiple layers and will
comply with the requirements of Subtitle C of the Resource
Conservation and Recovery Act. The cap will prevent direct contact
with contaminated soils, reduce infiltration, and enhance the soil
vapor extraction system. .-
."
.---'
Access Restrictions
Access restrictions will consist of those specified in the 1987
ROD.
Subsurface and Surface Water Monitorina
The purpose. of the subsurface and surface water monitoring is to
detect the presence of the volatile organic compounds, base
neutral/acid organics, PCBs, and heavy metals specified in
Attachment 1 in the subsurface and surface water during and after
soil vapor extraction, and to provide information to determine the
effectiveness of the soil vapor extraction program.
Once the Acceptable Soil Concentrations have been verified, and the
soil vapo~ extraction system has been shut off, sampling of off-
site till wells, on-site till wells, off-site sand and gravel
wells, and surface water will be conducted for seven years on a
semi-annual basis.
If, during the seven years of monitoring, cleanup levels are
exceeded, construction of a ground water collection trench and the
treatment of the collected ground water will occur. This action is
sUbstantively identical to the component of the 1987 remedy
requiring construction of a french drain, onsite treatment of the
collected ground water, and discharge pursuant to an National
Pollutant Discharge Elimination System permit to Finley Creek.
This amended remedy contemplates a more flexible approach to this
activity, however, in that the trench may be located in closer
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7
proximity to the contaminated area, and the collected ground water
may be sent to a publicly owned treatment works, consistent with
applicable law and" regulations.
Table 1 is a summary comparison of the 1987 ROD and the 1989 ROD
Amendment relative to the Agency's nine evaluation criteria.
VI.
STATUTORY DETERMINATIONS
U.S~ EPA has determined, and the Indiana Department of
Environmental Management concurs, that the remedy selected in this
ROD Amendment satisfies the statutory requirements specified in
Section 121 of SARA to protect human health and the environment:
attain ARARs: utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable, and to provide for
a cost-effective, response.
Protection of Human Health an4 the Environment
The remedy selected in this ROD Amendment will eliminate the
migration of contaminants in the subsurface water and will prevent
their discharge into the Unnamed Ditch and ~i-IHey Creek. This will
be accomplished by removing organic chemicals from the soil through
soil vapor extraction.
Some short term air and water releases may occur during the
construction of the soil vapor extraction system. Engineering
controls will be employed to minimize the releases, in accordance
with any applicable laws and regulations.
Attainment of Aoolica~le. or Relevant an4 Aoorooriate Reauirements
Section 121(d) of SARA requires that remedial actions meet legally
applicable or relevant and appropriate requirements (ARARs) of
other environmental laws. These laws may include: the Resource
Conservation and Recovery Act (RCRA), the Clean Water Act (CWA),
the Clean Air Act (CAA), the Toxic Substances Control Act (TSCA),
the Safe Drinking Water Act (SDWA), and certain State laws which
have stricter requirements than the corresponding Federal law. A
"legally applicable" requirement is one which would legally apply
to the response action if that action were not taken pursuant to
Section 104 or Section 106 of CERCIA. A "relevant and appropriate
requirement" is one that, while not legally applicable to the
remedial action, addresses problems or situations sUfficiently
similar to those encountered at the site that their use is well
suited to the remedial action.
The discussion contained in the 1987 ROD pertaining to ARARs
continues to be pertinent to the amended remedy. The method for
achieving compliance with those ARARs, though, has been modified.
The following is a description of the ARARs for the, amended
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8
components ot the remedy and an explanation of how this amended
remedial action meets those requirements:
1. RCRA Closure/Post Closure Requirements.
The amended remedy will satisty closure and post-closure
requirements of RCRA and the analogous state of Indiana
requirements applicable to hazardous waste landfills.
The 1987 remedy specified a RCRA Subtitle C cap, a french drain,
ground water collection and treatment, and 30 years of ground water
monitoring. The amended remedy herein provides for the utilization
of enhanced soil vapor extraction technology to substantially
reduce the levels of contaminants remaining onsite, construction of
the Subtitle C cap, and 7 years of surface and subsurtace water
monitoring once soil cleanup criteria have been verified. It also
provides tor construction of a subsurface water collection trench
if the monitoring indicates contaminants are present above cleanup
levels. This is, in essence, the "corrective action" which would
be required if compliance monitoring disclosed the need for same
under RCRA.
~
The Indiana Department of Environmental~ Management, which is
authorized to administer RCRA, has determined, through its
Commissioner, that utilization of soil vapor extraction to
significantly reduce contamination in soil at the site warrants the
contingent elimination of the french drain and reduction of the
time period for post-closure ground water monitoring. The u.s. EPA
hereby similarly determines that this modification complies with
RCRA. The RCRA regulations applicable to closures of hazardous
waste landfills are found at 40 CFR 265.110, et seq. Section
265.117 provides that post-closure monitoring must continue for 30
years, but that,
"Any time preceding closure of a hazardous waste unit,...
the Regional Administrator may:
(i)
Shorten the post-closure care period applicable to the
hazardous waste management unit, if all disposal units
have been closed, if he finds that the reduced period is
sufficient to protect human health and the environment
(e.g., leachate or ground-water monitoring results,
characteristics of the hazardous waste, application of
advanced technology, or alternative disposal, treatment, or
reuse techniques indicate' that the hazardous waste
management unit or facility is secure);
.. . ~~.
It is the determination ot U. S. EPA and. the State ot Indiana
Department of Environmental Management. that use of soil vapor
extI'action,constructfon. of the cap, and the' tripartite
verification of soil cleanup, is sufficient to protect human-health
and the env~onment, so as to justify shortening the compliance
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9
monitorinq period to seven years from the date that soil cleanup
has been verified.. This determination is, in part, based on the
fact that those contaminants which will not be siqnificantly
reduced by use of soil vapor extraction, are relatively insoluble
and immobile, and therefore unlikely to miqrate into the subsurface
water. It is further based on the findinq that soil vapor
extraction will significantly reduce the volatile orqanic compounds
and other contaminants which do miqrate into and with qround water.
The soil vapor extraction remedy selected herein is both
"innovative" and "advanced". Its innovative aspect is a function
of the use of injection and extraction trenches, with a cap, which
produces a closed system. It is advanced in that it will utilize
granular, activated carbon to remove the contaminants from the
vapor.
Moreover, this amended remedy selects a backup component,
implementation of a subsurface water collection and treatment
procedure similar to the french drain specified in the 1987 ROD, if
sample results disclose contaminants at levels above the subsurface
and surface water cleanup levels during t~e'seven year compliance
monitorinq period. The collected su~surface water would be
discharged pursuant to an NPDES permit, as described in the 1987
ROD, sent to a publicly owned treatment works, or otherwise
disposed of, in a manner which complies with applicable or relevant
and appropriate laws and requlations, including the Clean Water
Act.
2.
On-site Soil and On-site Subsurface Water
As described above, the Acceptable Soil Concentrations are the
cleanup levels for on-site soils, and the Acceptable Subsurface
Water Concentrations are the ARARs for on-site subsurface water.
Both the Acceptable Soil Concentrations and the Acceptable
Subsurface Water Concentrations determine the level of cleanup on-
site. In order for the soil vapor extraction system to be shut
off, and additional remedial measures not be required, these
cleanup levels/ARARs will have to be met.
3.
Off-site Subsurface Water and Surface Water
The Acceptable Stream Concentrations specified in Table 1 of the
1987 ROD remain the ARARs for off-site subsurface water and surface
water. In addition, a cleanup level for PCBs has been added, which
represents a 1xlO-6 risk level. The remedy selected in this ROD
Amendment will meet or exceed these ARARs.
4.
Subsurface Water Protection
The subsurface water from underneath Enviro-Chem qenerally flows to
the southeast and discharqes into the Unnamed Ditch. The removal
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10
of organic chemicals from the soil, and the subsequent
prevention ot contaminant migration are consistent with u.s. EPA's
Ground Water Protection Strategy. In addition, the State's
drinking water and industrial water standards would not be
jeopardized thus adhering to Indiana's nondegradation policy.
5.
On-Site Construction Activities
The on-site construction activities at Enviro-Chem may create
fugitive dust. Any precautions required by state or other
applicable laws will be taken during construction to minimize
fugitive dust emissions.
Cost-Effectiveness
The modified remedy selected in this ROD Amendment is as protective
as, and offers greater long-term effectiveness than the 1987 ROD
remedy. In the Feasibility Study completed at the time of the 1987
ROD, the cost of the combined Northside/Enviro-Chem remedy was
estimated to be $33.9 million. The modified remedy discussed in
tpis ROD Amendment for ECC alone is estimated~o cost at minimum $5
million and at most, $9 million. The total' cost of the separate
remedies for Northside and Enviro-Chem is now estimated to be
between $30 and $39 million. The modified remedy selected in this
ROD Amendment contains additional remedy components, as discussed
in Section v; the modified remedy is a cost-effective solution.
utilization of Permanent Solutions an4 Alternative Treatment
Technoloaies to the Maximum Extent Practicable. an4 Preference for
Treatment as a Princioal Element
If the soil vapor extraction program selected in this ROD Amendment
is successful, the concentrations of organic chemicals in on-site
soils and subsurface water will be permanently reduced to levels
which are below those shown in Attachment 1. If the soil vapor
extraction program is not successful within the required time frame,
subsurface water will be collected and treated, preventing the
migration of contaminants off-site.
VII.
FUTon ACTIONS
The anticipated Remedial Design and Remedial Action schedule is
attached as Figure 2.
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ENVIRONMlNT AI. CONSf.RV A TlON
AND CII[MI(AI. CORrOI/ATION
110N'iVIII.: INOUNA
SOli. UrOR H1I1anION-1IU:NCII 1'1.\:4
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TA8.£ ]-, (PI;e \ of 2)
SITE'SPECJIJC ACCEPTAILE CONCE~T.ATIONS
ENVI.OWNENTAL coNSERvaTION ANO CMENICAL COQ~ATIOW (ECC) SITE
Acceptacle
SubI~rflce Water Acceptacle Stream Aceepuet. $0 i l
Concentration (1.2) Concentration (3.') Concentration (5,6)
C~I C\JI/I) (1oIg/1) C\JI/kg)
............................ ................... ................... ...................
VOlATILE ORGANICS CVCCI):
Acetone 3.500 II '90
CM oroe.nzene 60 MCLGP 10, 100
OIlorofo,.. 100 MCL 15.7 2.300
1,1'Oichloroethane 0.31 .1 5.7
1,1'Olchloroeth8"8 7 MCL 1.85 120
Ethyl benzene 6aO NCLCiP 3,280 2~, 000
...thylene Chloride 4.7 II 15.7 20
...thyl Ethyl r.tone '70 LOWNA 7'5
...thyl II~tYI retone ',7'50 II 8,900
T.traehloroeth8"8 0.69 .. 8.85 '30
,
Tolwne 2,000 NCLCP 3.'OQ.~ 238, 000
1,1,1'Trichloroetllane 200 NCL 5,280 7,200 ~
1,1,2'Tri~loroetllane 0.6' II ".8 22 ..
T r i c/ll oroe tllene 5 "CL 80.7 2'0
Total Xylenel 440 I'CLGP 195,000
'ASE NEUTRAL/ACID ORCA~ICS:
liIC2..thylh.xyl)phthalat. 2.5 .. 50,000
Oi,",'~ty( Phthalat. 3,500 II 15',000
Ol.tllyl Phthalate 28,000 .. 52,'00
I I oph or one 8.5 II
l/.thal8"8 14,000 .1 620
'henol 1,'00 II 570 9,800
INORGAI/ICS:
Ant i lIOrIy " .1
Arlenic 50 MCL 0.0'75
lar ha ',000 MCL
leryll II.. 175 II
C8dlh. 10 MCL
OIrClii \8 VI 50 MCL 11
L.ed 50 MCL '0
ICanslanel. 7,000 .1
I/ictel 150 ~WMA '00
S il vet' 50 MCL
Tin 21,000 II
VIt\ICf hn 245 II
Zinc 7,000 .. 47
Cyanide 15' LDWIIA 5.2
PESTICIDES/PCII:
PCIs 0.001.5 .. (7) 0.00007'9 (7,8)
Attachment 1
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~
TABLE )-1 (Page 2 of 2)
SITE-SPECIFIC ACCEPTABLE CONCENTRATIONS
ENVIRO~TAL CONSERVATION AND CHEH!CAL CORPORATION (ECe SITE)
NOTES:
- Risk-based standard. U.S. EPA, Draft RCRA Facility
Investigation Guidance, 1987.
- Drinking water Maximum Contaminant Level. 40 CFR
141
MCLGP - Drinkinq water MCL goal, proposed. U. S. EPA
Superfund Public Health Evaluation Manual, update
of November 16, 1987.
LDWHA - Lifetime drinking water health advisory. U.s. EPA,
Superfund Public Health Evaluation Manual, update
of November 16, 1987.
(2) In the event that higher concentrations than those set for~h
for any parameter in this column are p~~sent in the upgradient" ."
subsurface water in the till and/or sand and gravel according t~
the procedure specified below, then those higher upgradient ~
subsurface ~ater concentrations and not the values set forth in
this table shall constitute the Acceptable Subsurface Water
concentrations within the meaning of this Exhibit A and the
Consent Decree. Those upqradient subsurface water concentrations
are referred to in this Exhibit A as "Applicable Subsurface Water
Background Concentrations." Twelve subsurface water samples will
be taken from existinq or new well locations, approved by EPA,
over at least a 12 month period in areas upgradient of the site.
The exact procedure, location of wells, and schedule for
collecting and analyzinq the samples will be approved by EPA,
after consultation with the State, prior to its implementation.
Subsurface samples for inorqanics and PCB analysis will be
filtered. For each parameter, the analytical results from the 12
samples vill be analyzed using standard statistical procedures.
The mean and standard deviation will be calculated, and all non-
detects vill be assigned a value equal to 1/2 the EPA-approved
quantification limit. For purposes of this Document, "Applicable
Subsurface Water Background Concentrations" is defined as two (2)
standard deviations above the calculated mean of these 12
samples.
(1)
RB
M~
(3) Stream criteria, from Table 1 of the Record of Decision for
the site, September 25, 1987.
(4) In the event that higher concentrations than those set forth
for any parameter in this column are present in the upstream
surface water, then those higher upstream concentrations and not
the values set forth in this table shall constitute the
Acceptable Stream concentrations within the meaning of this
Exhibit A and the Consent Decree. Those higher upstream surface
water concentrations are referred to in this Exhibit A as
Attachment 1 (cont.)
-------
"Applicable Sur'face Water Background Concentrations." Twelve
s~rface water samples will be taken from Unnamed Ditch upstrea~
of the site over at least a 12 month period. The exact
procedure, location of samples, and schedule for collecting and
analyzinq the samples will be approved by EPA, after
consultation with the State, prior to its implementation. For
each parameter, the analytical results from the 12 samples will
be analyzed using standard statistical procedures. The mean and
standard deviation will be calculated, and all non-detects will
be assiqned a value equal to 1/2 the EPA-approved quantification
limit. For purposes of this Document, -Applicable Surface Water
Backqround Concentrations" is defined aa two (2) standard
deviations above the calculated mean of th... 12 samples.
(5) Acceptable Soil Concentration is based on inqestion of
subsurface water at the sit~ boundary, assuminq a dilution of
leachate to subsurface water of 1:196 (Appendix B).
(6) The Acceptable Soil Concentrations, within the meaninq of
this Exhibit A and the Consent Decree, will be achieved when th~
arithmetic average of the 20 soil samp~. .'results for each' :
parameter, assiqninq all non-detect results a value of one-half~
the detection limit, do not exceed the values set forth in this~
table by more than 25 percent.
. (7) So lonq as the EPA-approved quantification limit for PCBs in
water is above the acceptable subsurface water and stream
concentrations for PCBs, compliance with the Acceptable
Subsurface and Stream Concentrations for PCBs will be determined
as follows: all subsurface and surface water sample results for
PCBs must be below the EPA-approved quantification limit for
PCBs (at the time compliance is determined).
~ /
(8) Modified from Superfund Public Health Evaluation Manual,
October, 1986, EPA 4/540/1-86/060, OSWER Directive 9285.4-1.
Attachment 1 (cont.)
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G
"
TABLE 1
ENVIRO-CHEM
COMPARISON OF EVALUATION CRITERIA
Protection of
human health and
the environment
Compliance with
ARARs
Long-term
Effectiveness
Reduction in
Toxicity, Mo-
bility and .Volume
Short-term
Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
1987 REMEDY
Surface water pro-
tected by ground
water collection
Compliance with off-
site ARARs (Accep-
table Stream
criteria)
Less certain, due
to slower removal
of contaminants, .--~/
and the need for
long-term main-
tenance of the
treatment system
Slow reduction in
volume of contam-
inants from ground
water collection
Little site distur-
bance; little chance
of releases during
construction
Simple construction;
long-term operation-
and maintenance re-
quired
$3 million
Full acceptance
Full acceptance
MODIFIED REMEDY
Surface water pro-
tected by soil
vapor extraction
Compliance with
off-site ARARs,
(Acceptable Stream
Criteria), on-site
ARARs (Acceptable
Soil Concentrations
and Acceptable Sub-
surface Water
Concentrations)
Faster removal of
/ contaminants, and
less time required
for long-term
maintenance
Faster reduction in
volume of con-
taminants from soil
vapor extraction
Possibility of air
and water releases
during construc-
tion; these will be
minimized through
eniineering con-
trols
More complex con-
struction: oper-
ation and mainte-
nance time reduced
$5 to $9 Million
Full acceptance
Anticipate ac-
ceptance
-------
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