United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EP A/ROD/R05-93/235
September 1993
PB94-964112
..
9
&EPA
Superfund
Record of Decision:
d
'"
Lakeland Disposal Service, IN
! .
Ru , ~, Environmental Protection Agency
...:eg!o~ /II, Hazardous Waste
lechnlcal Information Center
84:"1 Ches,tnut Street, 9th Floor
. I adel - PA
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Hazardous Waste Colfection
Information Resource Center
US EPA Region 3
Philadelphia. PA 19107
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S0272.101
REPORTDOCUMENTA~ON
PAGE
11. REPORT NO.
EPA/ROD/R05-93/235
~
3. RecIpient'. Acca8lon No.
4.
Title and Subtitle
SUPERFUND RECORD OF DECISION
Lakeland Disposal Service, IN
First Remedial Action - Final
Author(.)
5
Report Data
09/28/93
&
t>
7.
8.
Perfonnlng Organization Rept. No.
9.
Performing Organization Name and Addr1188
10 Project TaskIWork Unit No.
o
11. Contract(C) or Grant(G) No.
(C)
(G)
1~ Sponsoring Organization Name and Addl'8Ss
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period CovIl'8Cl
Agency
800/800
14.
15. Supplementary Notes
PB94-964112
1&. Abstract (Umlt: 200 words)
The 39-acre Lakeland Disposal Service is an inactive landfill located near Claypool,
Kosciusko County, Indiana. Land use in the area is predominantly agricultural, with
some residences situated to the north and west of the site. In addition, several
wetland. and woodland areas are situated adjacent to Sloan Ditch, an agricultural
drainage ditch which discharge~ to Palestine Lake, and subsequently, to the Tippecanoe
River. The residents living in the vicinity of the site use private wells to obtain
their drinking water supply. The site includes a "hot-spot" drummed waste disposal
area, a general trash area, a drying bed area, and several industrial waste areas.
Prior to 1974, the site was used for agricultural purposes. From 1974 to 1978,
Lakeland Disposal Service (LDS) accepted general refuse, including plastic, metal,
wood, leaves, paper, cardboard, and certain specific industrial wastes, including
paint sludge: sludge and filter sand containing metals: cyanide, zinc, and chrome
plating liquid; sugar contaminated with bromochloromethane: and oils and oily
wastewater. State records indicate that at least 18,000 drums of waste, 8,900 tons of
plating sludge, arid more than 2,000,000 gall.ons of plating sludge containing metals
were disposed of onsite. During site operations, the landfill .operator violated
(See Attached Page)
17. Document Analyels a. Descriptors
Record of Decision - Lakeland Disposal Service, IN
First Remedial Action - Final
Contaminated Media: debris, gw, surface water
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes),
phenols), metals (arsenic, chromium, lead),
other organics (PARs,
inorganics
b.
ldentlfiera/Opln-EndId Terms
Co
COSATI FleJdlGroup
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pa\JIa
.68
22. PrIce
(See ANSI-Z39.18)
S.lnstlUCt/ons OIl R.II",...
OPTIONAL FOAM 272 (4-77)
(Fonnerly NTJS.3S)
Department of Com-
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EPA/ROD/R05-93/235
Lakeland Disposal Service, IN
First Remedial Action - Final
Abstract (Continued)
numerous permit regulations by improperly accepting and disposing of waste in the
landfill. These violations included disposing of sludge in trenches with little or no
cover; depositing uncovered barrels of waste in water; contaminating run-off water, the
adjacent stream, and the low areas with paint sludge and refuse; dumping liquid waste into
the general refuse area; burning in the open; and not providing proper surface drainage.
In 1977, the State denied renewal of the operating permit due to failure of the landfill
to maintain a minimum of 50% acceptable inspections over the prior two-year period. After
the landfill operator appealed the decision, site operations continued until 1978.
Because the operator failed to close the site in 1978, the State initiated enforcement
actions and required two additional ground water monitoring wells to be installed with
continued monitoring. From 1978 to 1983, the State conducted several inspections onsite
that identified onsite leachate problems. In 1979, residential mobile homes were built
onsite, and, in 1982, the State conducted amethane gas survey that detected high methane
concentrations beneath one of the mobile homes. In 1981, the State required that the
landfill owner continue onsite ground water monitoring until 1984, and seal any leachate
seeps until 1983. In 1983, the County required that all residents vacate the site. This
ROD addresses a first and final remedy for the onsite ground water contamination, the
landfill waste material in the "hot-spot" area, and surface water. The primary
contaminants of concern affecting the debris, ground water, and surface water are VOCs,
including benzene, PCE, TCE, toluene, and xylenes; other organics, including PARs and
phenols; metals, including arsenic, chromium, and lead; and other inorganics.
'"
The ~elected remedial action for this site includes excavating, temporarily storing
onsite, and separating approximately 3,300 drums containing waste material from the
hot-spot area of the landfill; handling, sampling, and disposing of an estimated 1,650
intact or partially intact drums offsite; sorting approximately 500 yd3 of
non-containerized waste material and any landfill wa~te and debris encountered during
excavation of the slurry wall; disposing of RCRA hazardous waste material offsite based on
TCLP testing; reconsolidating non-hazardous waste onsite in the landfill and installing a
sanitary landfill cap with a6-inch vegetative soil cover and a 12-inch gas collection
layer, with either active or passive gas collection vents beneath the compacted layer;
installing a soil-bentonite slurry wall around the perimeter of the landfill to contain
onsite ground water in the upper aquifer; providing for a contingent remedy to store and
treat extracted ground water onsite, using filtration, and air stripping if necessary,
with onsite discharge of the treated water through Sloan Ditch; installing extraction
wells along the downgradient of the slurry ~all to maintain a water table elevation within
the slurry wall below the water. table outside the slurry wall; conducting a wetlands
assessment to determine if any significant portions of the wetlands are affected by the
installation of the cap and the slurry wall, with installation of an adjustable weir in
Sloan Ditch to maintain proper water levels in the wetlands and conducting any additional
mitigation, replacement, and/or restoration of the wetlands, if necessary; installing an
onsite ground water storage and treatment system, based on further studies; fencing the
site; monitoring ground water and surface water; and implementing institutional controls,
including deed, ground water, and land use restrictions. The estimated present worth cost
for this remedial action is $10,473,300, which includes an estimated annual O&M cost of
$174,000 for 1.5 years.
PERFORMANCE STANDARDS OR GOALS:
Debris and ground water cleanup goals are based upon RCRA, the more stringent of SDWA MCLs
or State water quality standards, and an EPA-action level for lead of 15 ug/kg or 15 ug/l.
Chemical-specific cleanup goals were not provided.
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Q
RECORD OF DECISION
SELECTED REKEDI~ ALTERNATIVE
DECLARATION
SITE KAME AND LOCATION
Lakeland Disposal Service, Inc. Landfill Site
Claypool, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the United States Envlronmental
Protection Aqency's (U.S. EPA) selected remedial action for the
Lakeland Disposal Service, Inc. Landfill Superfund Site near.
. claypool, Indiana. This decision document was developed in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA),as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and, to the extent practicable, the National Cofttinqency Plan
(NCP). This decision is based on the administrative record file'
for this site.
The State of Indiana has concurred with most components of the
selected remedy. The responsiveness summary section addresses
the concerns expressed by the State of Indiana. 0
ASSESSMENT OP THB SITB
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementinq the response action
selected in this Record of. Decision, present an imminent and
substantial endangerment of public health, welfare, or the
o environment.
DBSCRIPTIO. OP THE REMBDY
This remedy i8 intended to be the final action for the site.
This remedy addresses all contaminated media at the site.
The major components of the selected remedy include:
.
construction of an Indiana Sanitary Landfill Cap, in
. accordance with Indiana Solid Waste Management 0
Requlations contained in 329 IAC 2-14~19 and RCRA
subtitle D.cover requirements for surface containment
of the waste material;
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2
. .
Construction of a soil-bentonite slurry wall and
extraction wells for containment of the on-site
qroundwater in the upper aquifer;
.
storaqe, treatment, if "necessary, to meet National
Pollution Discharqe Elimination System (NPDES)
requirements, and discharqe of recovered qroundwater.
Removal of drummed wastes in the hot-spot area of the
landfill site, and off-site treatment and/or disposal
of the drums and non-containerized waste; .
.
.
Fencinq to prevent access~ qrou~dwater advisories, and
possible well abandonment and deed restrictions to
prevent future development from interferinq with
remedial components, as provided for by Indiana
requlations;
.
Construction of an adjustable weir in Sloan Ditch, if
necessary, to maintain proper water levels in the
adjacent wetlands;
Excavation and removal off-site of any landfill wastes
and debris encountered durinq excavation of the slurry
wall, which exhibit RCRA hazardous waste
. characteristics per Toxicity Characteristic Leachinq
Procedure (TCLP) test.
.
.
A wetlands assessment to determine the portions of the
wetlands that are affected by the installation of the
selected remedy. Based on this assessment, the.
Remedial Action will include a proqram to mitiqate,
replace and/or restore wetlands, if necessary.
STATUTORY DETERMINATIONS
The select~d remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or r~levant and appropriate to the
remedial action, and is cost effeetiva. This remedy utilizes
permanent solutions and alternative treatment technoloqies to the
maximum extent practicable. To the maximum extent practicable,
this remedy addresses the principal threats posed by the drummed
waste material in the hot-spot area of the landfill by reducinq
its toxicity, mobility, and volume, and satisfies the statutory
preference for treatment as principal element.
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3
'--
Because this remedy will result in hazardous substances remaining
on-site, a review will be conducted within five years after
commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
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LEGEND
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-------
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SCALE
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LEGEND
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Figure .2-.
ROD - Approximate Locations of Waste Disposal Areas.
Lakeland Dispo.al -Landfill
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TABLE OF CONTENTS
LAKELAND DISPOSAL SERVICE, INC. LANDFILL
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
"
o
SITE NAME, LOCATION, AND DESCRIPTION.......................... 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES...........~...........l
HIGHLIGHTS OF COMMUNITY PARTICIPATION.........................3
SCOPE OF RESPONSE ACTION.................. . . . . . . . . . . . . . . . . . . . .4
SUMMARY OF SITE CHARACTERISTICS...............................5
SUMMARY OF
SITE RISKS.. .0. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
DESCRIPTION
OF ALTERNATIVES.................................. 14
. COMPARATIVE ANALYSIS OF ALTERNATIVES: THE NINE CRITERIA......22
THE SELECTED REMEDY..............'...........'.....'............ 31
"-
STATUTORY DETERMINATIONS...................................... 33 .
DOCUMENTATION OF SIGNIFICANT CHANGES.........................40
GLOSSAR.Y. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41
RESPONSIVENESS
S~y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Following
ADMINISTRATIVE RECORD INDEX............................Following
i
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
LAKELAND DISPOSAL SERVICE, INC., LANDFILL SITE
CLAYPOOL, INDIANA
o
1.0
site Name. Location. and DescriDtion
The Lakeland Disposal Service, Inc., site (LDL) is an inactive
landfill located approximately 3-1/2 miles northwest of Claypool,
Indiana. The site is located in Section 12, Township 31, Range 5
East, Kosciusko County, Indiana, and is bounded on the west by
County Road 450 West. The site consists of approximately 39
acres (Figure 1).
A chain link fence runs along the western. property of the site.
The southern half of the landfill is surrounded by a farmer's
fence. An agricultural drainage ditch, called Sloan Ditch, runs
parallel to the eastern and northern edges of the site. Several
wetland areas exist along Sloan Ditch. Wooded areas are located
east of the landfill along Sloan Ditch and the adjacent wetlands.
Land use in Kosciusko County, and specifically for the area
surrounding the site, is predominantly agricultural. Although
the current zoning regulations are for agricult~ral purposes,
several residences are located west of the site ~long County Road
450 West. The nearest residence north of ~he site is also
located along County Road 450 West approximately 200 feet from
the site's northern boundary. All of the homes in the vicinity
of the landfill rely on their own private wells to provide
drinking water and water for general use.
Surface drainage from the site is conducted by stream or overland
flow. The primary stream in the immediate vicinity of LDL-is
Sloan Ditch, which eventually discharges to Palestine Lake,
approximately 1.6 miles northwest of the landfill. Discharge
from Palestine Lake continues via Trimble Creek which flows to
the northwest and eventually discharges to the Tippecanoe River.
~.o
site ~i.torv and Enforcement Activitie.
The LDL Site (Figure 2) is a former landfill that was operated
from June 1974 to December 1978 by Lakeland Disposal Service,
Inc. Prior to 1974, this site was used for agricultural
purposes. In January 1975, the Indiana Stream Pollution Control
Board issued a Solid Waste Management-Permit (Permit No. 43-2)
for the operation of a sanitary landfill at the site. During its
period of operation, the landfill accepted general refuse (e.g.,
plastic, -metal, wood, leaves, paper and cardboard) and certain
specific industrial wastes. According to Indiana State Board of
Health (ISBH) records, the following known industrial wastes were
disposed of at the LDL Site:
1
-------
.
Various sludges containing mainly the hydroxides of
aluminum, cadmium, chromium, copper, lead, nickel, tin,
selenium, and zinc;
.
cyanide, zinc, and chrome plating liquid;
paint sludge;
.
.
sugar contaminated with bromochloromethane;
oil and oily waste water; and
.
filter sand contaminated with hydroxides of lead,
copper, and chrome. .
According to ISBH Records and other information, at least 18,000
drums of waste materials were disposed of at the LDL Site. In
addition, approximately 8,900 tons of plating sludge and more
than 2 million gallons of plating sludge containing various
hydroxide sludges of aluminum, cadmium, chromium, copper, lead,
nickel, tin, selenium, and zinc were disposed of at the site.
.
zinc,
During the four years of the, landfill's operation, the' operator
of the landfill violated numerous permit regulations by
improperly accepting and disposing of waste mate~ial at the
landfill. These violations included disposal of sludges in
trenches with very little or no cover; hazardous wastes not
placed in trenches; barrels of waste deposited in water and not
covered; run-off water contaminated with paint sludge; sludge
running out of trenches to adjacent low areas and to the adjacent
stream; refuse dumped in water; liquid waste dumped into 'general
refuse area; unauthorized oil dumping causing pollution of the
adjacent stream; open burning on site; and poor surface drainage.
On April 4, 1977, the Indiana Stream Pollution Control Board
denied renewal of the operating permit due to failure ~f the
landfill to maintain'a minimum of 50 percent acceptable
inspections over the prior two year period. The operator of the
landfill appealed the denial and negotiated an Agreed Order
allowing the landfill to operate until May 1, 1978. After the
landfill tailed to close on May 1, 1978, the State initiated
enforcement actions. A second Agreed Order was negotiated and
the landfill was closed in December 1978. The State required two
additional qround-water monitoring wells to be installed at this
time with monitoring to continue until 1983. During the period
from 1978 to 1983, the State made several inspections and noted a
number of leachate problems. at the inactive site. The state
negotiated an amended Agreed Order in August 1981. The Order
provided that the prior landfill owner was to continue
groundwater monitoring at the site until September 1984, and seal
any leachate seeps until September 1983.
2
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In January 1979, residential mobile homes were placed on the
landfill facility. The State then notified the County Area
Planning Commission that this was not a suitable use for the
former landfill site. In November 1982, the State conducted a
methane gas survey at the closed landfill site and detected high
methane concentrations beneath one of the mobile homes. The
State filed an injunction with Kosciusko County requesting
residents to ~ove from the landfill property. In March 1983, the
Kosciusko County Board of Zoning Appeals ordered residents to
move from the landfill site. No one currently resides on the
landfill property.
The site was proposed for inclusion on the National Priorities
List (NPL) in June 1988. U.S. EPA placed the site on the NPL on
March 31, 1989, 54 Fed.Reg. 13302.
3.0
Biahliahts of Community ParticiDation
compliance with the public participation requirements of Section
113(k) (2) (i-v) of CERCLA/SARA, has been achieved for the LDL Site
by the following activit~es:
.
U.s. Environmental Protection Agency (U.s. EPA) issued
a press release announcing a public "aemedial
Investigation/Feasibility study (RI/FS") kick-off"
meeting to inform the community as to u.s. EPA's plans;
.
u.s. EPA held a public "RI/FS kick-off" meeting in
March 1990, announcing the initiation of the RI/FS;
u.S. EPA developed and distributed a fact sheet in
conjunction with the March meeting;
.
.
u.S. EPA established s~te information repositories at
the Claypool Post Office, Claypool, Indiana, and at the
Kosciusko County Health Department, in Warsaw, Indiana,
to provide public access to site-related documents;
U.S. EPA conducted public availability sessions in
April 1991, to discuss the results of the Phase I
Remedial Investigation (RI) field activities; a fact
sheet also was developed and distributed to the
community relations mailing list;
.
.
U.S. EPA conducted a public meeting in May 1992, to
discuss the results of the RI of the LDL Site; the
Agency. also developed a fact sheet and distributed it
through the community relations mailing list;
.U.S. EPA has compiled an Administrative Record, which
includes the RI, .Baseline Risk Assessment, Feasibility
.
3
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4.0
Study (FS), and other documents. The record is located
at the site information repositories;
.
u.s. EPA placed ~ formal advertisement in the Warsaw
Times-Union, a local newspaper of general circulation,
on June 21, 1993, announcing the commencement of the
public comment period, the availability of the Proposed
Plan, and the time and place of the July 15, 1993,
public meeting;
.
U.s. EPA released the Proposed Plan for remedial action
for public comment and placed the Plan into the
Administrative Record on June 21, 1993;
.
u.s. EPA provided a 30-day public
ended on July 30, 1993; copies of
were distributed to the community
list; . .
comment period, which
the Proposed Plan
relations mailing
.
u.s. tPA held a public meeting on July 15, 1993, at the
Claypool Lions Club at which u.s. EPA and the Indiana
Department of Environment Management (IDEM) presented
the Proposed Plan to the community and received verbal
comments. u.s. EPA made a transcript,of the public
meeting, which was made available to the public and
placed in the Administrative Record and site
repositories;
U.s. EPA has received oral and written comments on the
Proposed Plan. significant comments have been
addressed in the attached Responsiveness Summary.
SCOD. of R.SDODS. Ac~ioD
.
The principal threats identified at the site are considered to. be
groundwater contamination and landfill waste material in the hot-
spot area (see Figure 2) of the landfill. To mitigate the threat
to human health and the environment, the selected remedy provides
for the reduction of toxicity, mobility, and volume of
contaminants through the removal of drummed. waste in the hot-spot
area. The remedy requires an investigation of the hot-spot area
to more precisely define its geographical extent prior to the
removal of any drums. The contaminated material remaining in the
landfill will be addressed as a continuing source of groundwater
contamination. The remedy also includes a wetland assessment to
determine if any significant portions of the wetlands are
affected by the installation of the cap and the slurry wall.
Based on such an assessment, a program to mitigate, replace
and/or restore wetlands will be implemented if necessary.
For the purposes of source control, the selected remedy includes
the construction of an Indiana sanitary Landfill Cap for surface
4
-------
c
.containment of waste material; construction of a slurry wall and
extraction wells for containment of the on-site groundwater in
the upper aquifer; and provision for storage, treatment and
discharge of recovered groundwater. A soil-bentonite slurry wall
will be constructed around the perimeter of the landfill to form
a subsurface barrier to contain groundwater and waste under and
within the landfill. The slurry wall shall be properly keyed
into the confining layer below and the surface cap above the
landfill.
The remedy includes contingency measures to address changed
conditions or unanticipated problems. Examples of such
contingency measures include the construction of an adjustable
weir in Sloan Ditch to maintain proper water levels in the
adjacent wetlands; provisions for any additional treatment
equipment should it be required in the future to meet NPDES
permits; 'and, if necessary, investigations to determine the
presence of any underground drainage tile system across the
landfill. Additionally, if any drummed wastes or any non-drummed
wastes eXhibiting RCRA hazardous waste characteristics are
, encountered during any excavation for implementation of the
remedy, then such waste material would be disposed of off-site
with the targeted drum removal activities. '
,
In addition, the selected remedy includes institutional controls
such as fencing to prevent access to the site, possible deed
restrictions to limit future land and groundwater use, and a
comprehensive long-term monitoring plan to ensure effectiveness
of the remedy.
5.0
SummarY of site Characteristics
A RIfFS at the site was conducted to determine the nature and
extent of contamination, define pathways of contaminant
migration, define physical features that could affect the
migration, containment, or remediation of the hazardous
substances, and to gather information necessary to prepare a
Baseline Risk Assessment (RA) and a FS for the site. The goals
of the FS are to develop and evaluate remedial alternatives to
address the problems at the site. RI field activitie~ included
soil, sediment, surface water, groundwater, and waste material
sampling. The discussion below summarizes the results of the RI
activities. .
5~1
Geoloav
The near surface geology underlying the LDL Site can be
subdivided into two'unconsolidated units. In the vicinity of
Sloan Ditch, a brown silty sand loam with discontinuous lenses of
silty and fine to coarse sand with occasional 9ra~el occu~s ~o a
depth of approximately 15 below land surface. Th1S depos1t 1S
associated with the wetland that occupies the valley crossed by
5
-------
Sloan Ditch. Upland of the valley, a second near surface unit
consists of silt and clay loam with some sand and gravel. It
extends 5 to 25 feet below the land surface. This unit appears
to have originated as a coarse till. The alluvial deposits and
upland coarse till constitute the shallow geologic system and,
together, are equivalent to the shallow unit (unconsolidated
upper aquifer).
Underlying the shallow units, is an unstratified mixture of gray
inorganic silt, clay and sand with pebbles and occasional
discontinuous lenses of silt and fine to coarse silty sand with
variable amounts of gravel. This glacial till unit is continuous
across the Site. The top of the continuous till unit is found at
depths of 4 to 30 feet below land surface, and is the predominant
unit to a depth of at least 100 feet below land surface(t~e
maximum depth of drilling activities during the remedial
investigation). .
5.2
Hvdroaeo10av and Hvdro10av
Groundwater occurrence at the site is divided into two distinct
hydrogeologic units: the shallow upper aquifer and the lower
gravel aquifer. The lower aquifer is separated from the upper
aquifer by a till unit which acts as an aquitard. The lower
gravel aquifer is considered confined based on.the artesian
conditions. found in some of the nearby regional wells. The till
unit and the bedrock zone act as the upper and lower confining
units to. this aquifer.
The groundwater flow direction. at the landfill site is generally
toward the east to northeast with an average estimated horizontal
hydraulic gradient of 0.036 ft/ft in the shallow upper aquifer.
Within the regional discharge area, the hydraulic gradients are
generally upward toward the wetlands,. lakes and streams. The
vertical gradients calculated from well nest data indicate that
downward.gradients exist in the upland portion of the site and
that upward gradients exist within the low-lying Sloan Ditch
discharge a~ea. Owing to the low hydraulic conductivity of the
till aquitard, it is assumed that the rate of upward discharge is
relatively low.
5.3
80il Contamination
50il samples were collected at various locations on the LDL Site.
Volatile organic compounds (VOCs), semi-volatile organic
compounds (5emi-VOCs), and inorganic analytes were detected above
background concentrations in the surface and subsurface soils. A
list of these contaminants and their maximum concentrations are'
shown on Table 1.
6
-------
Groundwater Contamination
5.4
The shallow groundwater zone beneath and downgradient from the
landfill has been impacted by waste disposal practices from the
landfill. VOCs, Semi-VOCs, inorganic analytes and general water
quality parameters were detected above background concentrations
in the shallow groundwater. A list of these contaminants and
their maximum concentrations in groundwater samples are presented
in Table 2. In the downgradient groundwater samples,
concentrations of vinyl chloride, trichloroethene,
1,2-dichloroethene, antimony, and lead exceed their established
primary drinking water standards known as Maximum Contaminant
Levels (MCLs) or action levels. Methylene Chloride was detected
in the RI Phase I groundwater sample in one of the monitoring
wells at a concentration of 60 parts per billion (ppb). .nd it
exceeded its MCL of 5 ppb. Concentration of cadmium in one of
the downgradient groundwater samples was equal to the MCL of 5
ppb. Several inorganic analytes such as aluminum, iron,
manganese, and chlorides exceeded the established secondary
drinking water standards. These contaminants were detected in
some of the downgradient shallow monitoring and/or piezometer
wells installed at depths ranging from 15 to 40 feet below land
surface. No PCBs or pesticides were detected in any of the
monitoring wells on site. ,
No contaminants were detected above established primary drinking
water standards in monitoring wells installed in the lower
aquifer. within the LDL Site. Several inorganic analytes such as
aluminum, iron and manganese, however, exceeded the established
secondary drinking water standards. .
The results of the drinking water samples obtained from the
nearby residences did not indicate the presence of any of tne
contaminants above the established primary drinking water
standards. Iron and manganese concentrations, however, exceeded
the established secondary drinking water standards. A list of
these contaminants and their maximum concentrations are presented
in Table 3.
5.5
Landfill Waste Contamination
The results of test pit samples at the Site indicate the presence
of several VOCs, Semi-VOcs, and inorganic analytes. No PCBs or
pesticides were detected in any of the Site waste samples. A
list of these contaminants and their maximum concentrations are
presented in Table 4. The results of drummed waste sample
analysis in the hot-spot area indicated high concentrations of
ethylbenzene (20,000 mqlkq), methylene chloride (10,000 mg/kq),
toluene (55,000 mg/kg), 1,1,1-trichloroethane (65,000 mg/kg),
trichl~roethene (6,000 mg/kg), and xylene (74,000 mg/kg-).
7
-------
..
Page 2 of 2
Table 1
Contaminants detected in Soil Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminants
Surficial Soil
Maximum
Concentrations
(mg/kg)
Subsurface Soil
Maximum
Concentrations
(mg/kg)
Cobalt
Copper
Cyanide
Iron.
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver.
Thallium
Vanadium
Zinc
6.8.
750.0
11.0
27,000.0
. 100.0
220,000.0
1,100.0
0.32
500.0
3,100.0
5.0
0.44
11.0
57.0
"
33,000.0
26.0
35,000..0
1,400.0
0.17
300.0
3,200.0
7.5
0.13
0.75
72.0
1,400.0
66.0
1,400.0
-------
Paqe 1 of 2
Table ..l
Con~aminants det~cted in Soil Samples.
Lakeland Dlsposal Landflll Site, Claypool, Indiana
Contaminants
Surficial Soil
Maximum
Concentrations
(mqjkq)
Subsurface Soil
MaximuJD
Concentrations
(mqjkg)
~
Acetone
Benzene
2-Butanone
Carbon disulfide
Chloroform
l,l-Dichloroethane
1,2-Dichloroethene (total)
Ethylbenzene
Methylene chloride
Tetrachloroethene
Tetrahydroturan
Toluene
l,l,l-Trichloroethane
Trichloroethene
Xylene (total)
Semi-VOCs'
Benzo(b)tluoranthene
Benzo(a)pyrene '
Bi8(2-ethylhexyl) phthalate
Butylbenzylphthalate
. 3,3-Dichlorobenzidine
Di-n-butylphthalate
Di-n-octylphthalate
Fluoranth.n.
Inorcranic8
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
0.009 0.048
0.001 0.002'
0.031 ' 0,.013
0.001
0.009 0.007
'0.19
0.001 1.2
0.001
0.031 " 0.064
0.003 0.007
0.052
0.009 0.004
0.084
0.036 0~10
0.006 0.006
0.057
1.3
0.32
0.8
0.9
0.67
0.049
0.086
3.4
1.2
1.8
3.0
25,000.0
1.2
20.0
300.0
1.6
98.0
100,000.0
. 690.0
28,000.0
2.3
20.0
290.0
1.9
1.2
110,000.0
36.0
-------
Page 1 of 2
Table 2
Contaminants detected in Ground Water Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminants
, Maximum concentration
(mg/ 1 )
~
Acetone
Benzene
2-Butonone
Carbon disulfide
Chlorobenzene
Chloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene (total)
Ethylbenzene
Methylene Chloride
4-Methyl-2-pentanone
Tetrahydroturan
Toluene
Trichloroethene
Vinyl acetate
vinyl ,ch~oride
0.011
0.003
0.140
0.005
0.004
0.120
0.058
0.001
0.190 .
0.002
0.060
0.013
0.110
0.008
14.000
0.018
0.003
.,
Semi-VOCs
Bis (2-ethylhexyl) phthalate
Diethylphthalate
Di-h-butylphthalate
Phenol .
0.011
0.006
0.006
0.340
. Inoraanics
Aluminum
Antimony
Arsenic
Barium
Cadmium
Calcium
Chloride
Copper
Cyanide
Iron
Lead
2.210
0.020
0.015
1. 230
0.005
413.000
547.000
0.045
0.011
25.900
0.027
-------
.
Page 2 of 2
Table 2
Contaminants detected in Ground Water Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminants
Maximum concentration
(mg/l )
Magnesium
Manqanese
Mercury
Potassium
Selenium
Sodium
Sulfide
Vanadium
Zinc
158.000
1.180
0.0004
92.600
0.0075
204.000
23.800
0.050
0.046
.,
-------
Table 3
contaminants detected in Residential Well Samples
Lakeland Disposal Landfill Site
Contaminants
Maximum Concentrations
(mq/l)
~
Carbon disulfide
0.0005
Inoraanics
Arsenic.
Barium
Calcium
Chloride
Iron
Lead
Maqnesium
Manqanese
Mercury
Zinc
0.014
0.362
94.500
14 . 600
2.350
0.0084
30.900
0.086
0.0003
0.094
"
,
-------
Faqe 1 ot 2
Table 4
contaminants detected in Was~e Characterization Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminan~s
Maximum
Concentrations
(excludinq
hot-spot area)
(mq/kq)
Maximum
Concentrations
(hot-spot area)
(mq/Jcq)
~
Acetone
Benzene
2-&utanone
Chlorobenzene
Chloroethane
Chloroform
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloroethene (total)
1,1-Dichloroethene
Ethylbenzene
Methylene chloride
4-Methyl-2-pentanone
Tetrachloroethene
Toluene
1, 1, 1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Vinyl chloride
Xylene (total)
Semi-VOCs
Bis-(2-ethylhexyl) phthalate
Butylbenzylphthalate
Di-n-butylpbthalat.
2-Methylnapbthalen.
Naphthal.n.
Inoraanic8
Aluminum
Antimony
Arsenic
. Barium.
Beryllium
26.0 66.0
0.42 .5.8
250.0 770.0
5.7.
0.45
0.32
20.0 1,100.0
11.0
18.0 ... 86.0
180.0
48.0 20,000.0
5.1 10,000.0
20.0 20.0
270.0 9.7
360.0 55,000.0
21.0 65,000.0
84.0
190.0 6,000.0
2.8
200.0 74,000.0
27.0
0.25.
1.4
0.97
33.0
130.0
400.0
450.0
7,940.0
1.2
12.1
1,470.0
1.1
110,000.0
18.8
4.5
15.0
-------
Page 2 of 2
Table 4
contaminants detected in Waste Characterization Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminants
Maximum
Concentrations
(excludinq
hot-spot area)
(mq/kq)
Maximum
Concentrations
(hot-spot area)
(mq/kq)
Cadmium
calcium
Chromium
Cobalt
Copper
Cyanide
Iron
Lead
Maqnesium
Manqanese
Mercury
Nickel
Potassium
Silver
Sodium
vanadium
Zinc
40.7
216.,000.0
13,100.0
13.7
17,400.0
122.0
125,000.0
142.0
15,300.0
732.0
0.08
2,670.0
6.35
0.52
1,030.0
23.8
22,800.0
27.6
3,110.0
4.8
130.0
22.5
0.29
4,050.0
5.6
772.0
67.2
.,
9.6
10.4
40.9
-------
5.6
Leachate contaminants
The surface leachate seeps which discharge to Sloan Ditch
contained high concentrations of several VOCs such as acetone, 2-
butanone, ethylbenzene, 4-methyl-2-pentanone, tetrahydrofuran,
toluene, vinyl chloride, and xylene. Significant among the semi-
VOCs were benzoic acid, diethylphthalate, 4-methylphenol, and
phenol. Also, several inorganic analytes such as aluminum
. '
chrom~um, copper, and lead were detected in the leachate samples
which eventually discharge to Sloan Ditch. A list of these
contaminants and their maximum concentrations are presented in
Table 5.
5.7
Surface Water and Sediments in Sloan Ditch
Acetone and Di-n-butylphthalate were detected at relatively low
concentrations in the surface water samples downgradient of the
site. Acetone, however, was also detected in one of the
upgradient surface water samples. Several inorganic analytes
were detected in the surface water samples. Inorganic
. contaminants, including copper, lead, and mercury, were detected
in the surface water samples. Concentrations of mercury in
surface waters adjacent to the landfill exceeded the IDEM Chronic
Aquatic Criteria (CAC). Iron exceeded the established u.S. EPA
(1986) water quality criteria of 1000 ~g/l. These contaminants.
were also detected in the background surface water samples.
Several inorganic constituents detected in the surface water
samples, including cadmium, copper, and lead, were also detected
in the surface leachate seeps which eventually discharge to Sloan
Ditch. A list of these contaminants and their maximum
concentrations are presented in Table 6.
Several VOCs, Semi-VOCs, and inorganic analytes were detected
above background concentrations in the sediments of Sloan Ditch.
Several of these constituents were also detected in the surface
leachate seeps that eventually discharge to Sloan Ditch.
Elevated levels. of some of the inorganic contaminants detected
adjacent to the landfill indicate that contaminants may have
migrated from the landfill. A list of these contaminants and
their maximum concentrations are presented in Table 6.
5.8
Wetland Sediment SamDles
Several VOCs, Semi-VOCs and inorganic analytes were detected in
the wetland sediment samples above background concentrations. A
list of these contaminants and their maximum concentrations are.
presented in ~able 5.
5.9
Air Contamination
The ISBH, during a site inspection in November 1982, conducted a
methane gas survey at. the closed landfill site and detected high
8
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Page 1 of 2
Table 5
Contaminants detected in Leachate and Wetland Sediment Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminants
Leachate
Maximum
Concentrations
(mg/ 1 )
Wetland Sediments
Maximum
Concentrations
(mg/kg)
~
Acetone
Benzene
2-Butanone
Carbon disulfide
Chlorobenzene
Chloroethane
l,l-Dichloroethane
1,2~Dichloroethene (total)
Ethylbenzene
2-Hexanone
Methylene chloride
4-Methyl-2-pentanone
Styrene
Tetrachloroethene
Tetrahydrofuran
Toluene
Trichloroethene
Vinyl chloride
Xylene (total)
Semi-VOCs
Benzoic acid
Bi8 (2-ethylhexyl) phthalate
Butylbenzylphthalate
Di-n-butylphthalate
Diethylphtbalate
Dimethylpb~alate
4-Methylph8nol
Phenol
Inoraanics
Aluminum.
Antimony
Arsenic
Barium
14.0
0.011
28.0
0.004
0.001
0.019
0.069
0.021
0.078
0.13 .
0.002
46.0
0.19
0.003
0.044
0.004
0.076
0.005
.,
0.16
--
0.003
0.009
0.021
0.026
0~010
0.16
0..44
0.13
0.26
4.8
3.9
0.002
1.4
0.048
0.09
0.74
0.51
56.4
o . 0.28
1.68
24,500.0
34.1
12.8
180.0
-------
Page 2 of 2
Table 5
Contaminants detected in Leachate and Wetland Sediment Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminants
Leachate
Maximum
Concentrations
(mg/l)
Wetland Sediments
Maximum
Concentrations
(mg/kg)
Cadmium
Calcium
Chloride
Chromium
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
0.007
507.0
370.0
0.111
78.6
76,500.0
0.071
.39,700.0
20.2.
10,600.0
. 0.17
39,500.0
495.0
18,400.0
.,1,180.0
. . 0.14
130.0
2,340.0
8.6
6.9
410.0
0.051
143.0
3.02
0.1
91.8
0.0012
213.0
0.0066
0.115
1.03
51.9
27,300.0
-------
Table 6
contaminants detected in Surface Water and Sediment Samples
Lakeland Disposal Landfill Site, Claypool, Indiana
Contaminants -
Surface Water
Maximum
Concentrations
(mg/l )
Sediments in Sloan Ditch
Maximum
Concentrations
(mg/kq)
~
Acetone
2-Butanone
Chloromethane
Ethylbenzene
Toluene
Xylene (total)
0.009
0.29
0.053
0.005
0.002
0.008
0.008
Semi-VOCs
Bis (2-ethylhexyl) phthalate
'Butyl benzyl phthalate
Di-n-butylphthalate
"
0.029
0.53
6.4
0.004
Inoraanics
Aluminum 31.0 20,600.0
Arsenic 0.011 22.6
Barium 0.437 246.0
Cadmium 1.3
Calcium 159.-0 45,300.0
Chloride 2.96
ChromiWD 0.033 . 25.9
Copper 0.036 31.8
cyanide 0.92
Iron 40.3 30,600.0
Lead 0.022 35.1
MagnesiUII 34.9 9,100.0
Manqane.. 12.2 2,730.0
Mercury 0.0003 0.1
Nickel 30.6
potassiWD 14.8 2,640.0
Selenium 4.7
Sodium 17.4
Sulfide -- 28.3 --
Silver 0.33
Vanadium. 0.065 50.3
Zinc 0.174 145.0
-------
methane concentrations beneath one of the mobile homes. Methane
is a common gas generated by most landfills. During the RIfield
activities, no specific effort was made to monitor methane gas at
the site.
6.0
Summary of site Risks
The Baseline Risk Assessment in the RI Report (Chapter 5),
followed the guidance provided in u.s. EPA's Risk Assessment
Guidance for Superfund (RAGs): Volume I. Human Health Evaluation
Manual. Risk assessment guidelines developed by the State of
Indiana were also applied.
6.1
contaminants of Concern
Chemicals considered in the Baseline Risk Assessment are those
which are present as a result of chemical releases which have
occurred at the Site and are termed "chemicals of potential
concern." To identify these, chemicals present in soil and
groundwater samples are distinguished from those which may
naturally be present (Site background) and those which can be
unintentionally introduced into samples through sample collection
or laboratory analysis. Further, consideration is given to the
frequency 'of occurrence of the chemical at the Site. Those
infrequently identified may not be significant in view of overall
Site contamination. Chemicals considered to be of potential
concern are evaluated further in the risk assessment.
For the LDL Site risk assessment, 68 contaminants representing
inorganic, volatile, and semi-volatile organic compounds were
evaluated. Of these, 51 contaminants were used in assessing site
risks. The contaminants of concern include monocyclic aromatic
hydrocarbons, chlorinated aliphatic hydrocarbons, ketones, ,
tetrahydrofuran, carbon disulfide, benzoic acid, phthalate
esthers, naphthalene, phenols, and inorganic compounds. A list
of these contaminants of concern is found at Table 46 of the RI
Report.
6.2
Exoosure Assessment
An exposure assessment is performed to identify actual and
potential pathways by which human exposure to contaminated Site
media may occur. The assessment considers factors such as the
physical location of contaminated areas~ the type of
contamination and the population which may come into contact with
these areas. Exposure pathways are identified for two Site land
use scenarios: pathways based on land use practices as they
currently exist, and potential pathways based on land use changes
which may occur in the future and result in additional types of
exposure. Both current and future pathways which represent
possible exposures are then quantified to estimate the magnitude
of daily contaminant exposure a population may incur. To
9
-------
accomplish this, assumptions, pertaining to the exposed population
are made, such as the nature of the individuals (~, child vs.
adult), the rate of contact with the contaminated medium (~,
adult consumes 2 liters of water daily) and the length of time
the exposure is likely to occur (~, years vs. lifetime).
These population variables are then combined with chemical
concentration data to calculate a' level of exposure.
Both municipal and industrial wastes were accepted at the LDL
site from 1974 to 1978. Contaminants from the landfill have been
identified in the groundwater within the shallow upper aquifer,
surficial soil, subsurface soil, surface water, leachate, wastes,
and sediments from Sloan Ditch and adjacent wetlands. The most
highly contaminated media included a hot-spot area containing
drummed wastes in the northern portion of the landfill and the
groundwater in the shall~w upper aquifer. Lower levels of
contamination were found in other media such as surface water and
sediments. Current well records indicate that residential and
municipal wells within a 3-mile radius of the site likely obtain
their water supplies from a gravel aquifer beneath the glacial
, till deposit. Analytical results from samples collected from
nearby residential wells indicate that these wells have not been
affected by the site contaminants. .
,
Pathways considered to be most significant at the Site include
exposure through groundwater use and direct contact with soils,
summarized as follows:
Current Land Use Conditions:
1)
, Exposure of local residents to constituents in
surficial soils and wetlands sediments by ingestion,
dermal contact, and inhalation;
2)
Exposure of local residents to constituents in
groundwater by ingestion, dermal contact, and
inhalation of volatile contaminants released into
indoor air through household use;
Dermal contact with surface water and sediments of
Sloan Ditch;
3)
4)
Ingestion of turkey meat from turkeys exposed to
landfill soils and grasses;
5)
Exposure to landfill wastes.
Potential Future Land Use Conditions:
1)
Exposure of future residents to contaminated
groundwater resulting from either installation of a
well within' the contaminant plume or by migration of
10
-------
groundwater contaminants to existing wells. Exposure
may occur through drinking and dermal absorption.
contaminant concentrations are assumed to exist in the
future as under current conditions.
2)
Exposure of individuals to contaminated soils at a
future residence developed at the source areas.
Exposures may occur through incidental ingestion of
soil and dermal absorption. It is assumed contaminants
in either surface or subsurface soils at current
concentrations are made available for exposure as a
result of Site development.
Using such scenarios, risk numbers are calculated for each
contaminant. These calculations factor in the amount of, exposure
assumed, the dose of the chemical received (based on the
, concentrations found during the RIl, and a toxicity estimator for
, each individual chemical which quantifies the toxicity of that
chemical. Different constants and equations are used based on '
whether or not the chemical is carcinogenic. The constant for a
carcinogenic chemical is called a slope factor, and the constant
for a noncarcinogen is called a reference dose.
The results of these calculations are estimates, of cancer risk
for carcinogenic risks and estimates of Hazard 'Indices for
noncarcinogenic risks. The cancer risk number is expressed in
scientific notation and represents an estimate of an individual's
increased risk of getting cancer over a lifetime. The
carcinogenic risk estimate is generally a conservative estimate,
i.e., the risk may be less than predicted. For example, 1.0 x
10-6 represents an increase in an individual's risk of cancer by
1 chance in a million, under the exposure conditions assumed.
U.S. EPA considers this 1.0 x 10-6 number as a point of departure
when determining risk at a site. Risks calculated to be less
than this value are considered protective of human health and the
environment, while risks between 1.0 x 10-4 and 1.0 x 10-6 are
withih a 'range acceptable to U.S. EPA but may not be considered
protective due to site-specific conditions. Risks greater than
1.0 x 10-4 ~re generally unacceptable.
The Hazard Index (HI) represents the risk of adverse non-cancer
effects occurring due to exposure to the site. The HI number,
generated is interpreted differently from the cancer risk number.
To evaluate risk at a site due to noncarcinogenic contaminants,
U.S. EPA has determined that an HI less than or equal to 1
estimates that no adverse effects are likely to occur due to the
hypothetical exposure, while a Hazard Index greater than 1
estimates that,adverse effects due to site exposure may occur and
signals that potential risks to human health must be carefully'
evaluated. '
:11
-------
The Baseline Risk Assessment and the Hazard Index showed that the
site poses unacceptable risks to the public health. The excess
lifetime cancer risk (ELCR) and HI for current eXDosure to the
contaminated media from the LDL site are estimated to be:
Receptor
Exposure Point
Adult
child
ELCR
HI
ELCR HI
3 x 10'6 0.40
9 X 10'8 0.03
4x 10.7 1.00
6 X 10'4 20.00
6 X 10.4 21. 43
Soils
Wadinq .
Wetland sediment
Turkey Meat
Drummed waste
2 X 10'6
0.07
2 X 10-6
4 X 10.7
5 X 10.4
0.80
0.01
4.00
Total Current Risks
5 X 10~4
4.88
The total ELCR and HI for future eXDosure to the contaminated
media from the LDL site are estimated to be:
Receptor
Exposure Point. Resident Worker
ELCR HI. ELCR HI
Soil 4 x 10.5 1.00 7 X 10'8 0.40
Groundwater 3 x 10.4 . 5.00
Leachate :3 x 10" 0.20
Landfill Waste 2 x 10.2 200.00 4 X 10.5 60.00
Total Future Risks 2 X. 10'2 206.20 4 x 10'5 60.40
Thus, the potential risks at the site exceed the acceptable risk.
ranqe of 1 x 10.4 to 1 X 10'6, and thus present unacceptable
current and potential future risks to human health.
Additionally, in many cases of exposure, it is likely a person
12
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would be exposed to the site contamination through more than one
exposure route. In these cases, the risk levels of the exposure
routes would be added together resulting in higher risks due to
exposure to site contaminants.
As with the carcinogenic risks, two or more routes of exposure
may be complete for a person exposed to the site contamination.
In these cases, the hazard index for each case would be added
together resulting in a combined hazard index greater than 1.0.
The total hazard index for the site is estimated to be 21.43
currently, and 206.2 for potential future use.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Based on the lead biokinetics model conducted as part of the RI,
children between the ages of 0 to 6, exposed to groundwater and
soils at the LDL Site are not expected. to have blood levels that
exceed the permissive li~it of 10 ug/dl for lead.
6.3
Ecoloaica1 Assessment
. .,
Ecological impacts from site-related contamination were also
evaluated. These findinqs established a limited impact to the
local wetlands. Based on a study of wetland sediment samples,
landfill waste materials were detected 1.5 to 2 feet below
wetland surface areas. Although these materials potentially
could migrate from the deeper sediments to the upper sediments,
the 0 to O.S-foot wetland sediments currently did not contain
levels of contaminants that could adversely affect wetland
organisms. Elevated levels of zinc detected in wetland
sediments, however, may adversely affect aquatic organisms.
Surface leachate seeps also contained elevated levels of organic
contaminants and may adversely affect immediately adjacent flora
and fauna.
'.4
Uncertainties
The Risk ABsessment could not qUantify risks from those
contaminants without known slope factors or reference factors.
For a more detailed discussion of such contaminants at the LDL
site, see the RI report (RI report, p. 208-09). Methods to
quantify risks and possible synergistic effects due to exposure
to mixtures of multiple contaminants or multiple pathways are
very limited. The use of risk additivity helps prevent the
underestimation of oancer risks or potential noncancer health
effects.
13
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7.0
Descriotion of Alternatives
Based on the results of the RI, a FS was conducted to identify
and evaluate remedial alternatives that would minimize or
eliminate the health risks caused by site-related contaminants.
The qoals for remedy selection at the LDL Site include:
.
Prevent or reduce the release of contaminants
landfill into the various environmental media
air, qroundwater, surface water and sediments
Ditch, and the adjacentwetlandsi
ensure that chemical-specific applicable or relevant
and appropriate requirements (ARARs) are not exceeded
outside the boundaries of the landfill;
from the
includinq
of Sloan
.
.
prevent or reduce off-site miqration of contaminated
qroundwateri .
prevent or reduce the potential risk to human health
associated with exposure to contaminated qroundwater
and/or landfill waste at the Site; and
.
.
minimize all future adverse affects tQ the adjacent
wetlands.
The followinq ten remedial alternatives were developed for the
site, and are briefly described below. For more detailed
information, see the FS Report. The major ARARs which were
identified for these alternatives will be discussed in Section
8(2), Comparative Analysis of Alternatives, under ComDliance with
ARARs.
Alternative 1: NO ACTION
As required by the National Continqency Plan (NCP), the No Action
Alternative is evaluated, and serves as a basis .aqainst which all
other alternatives can be compared. Under this remedial
alternative., no active remedial action or institutional action
would be taken.
Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Present Worth:
Estimated Time to Implement
Alternative 2: INSTITUTIONaL CONTROLS
$
$
$
o
o
o
none
Alternative 2, which is also incorporated in Alternatives J, JA,
4, 4A,. 5, SA, 6, and 6A, includes access and deed restrictions,
landfill maintenance, and qround-water monitorinq. Access
14
-------
restriction would be achieved by installing a fence around the
entire landfill site.
Institutional controls to restrict access, use, and development
of the site also would be included in each of the alternatives.
A fence would control access to the site and protect the cap
(proposed under other alternatives) from unauthorized access.
Restrictive covenants may be implemented on the property pursuant
to Indiana Code (IC) 13-7-8.7-12 to prevent future development
from interfering with remedial components. 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.. Installation of new wells on the Site is
expected to be prohibited by IC 13-7-26-7. A maintenance program
would be implemented in order to maintain the existing landfill
cover or .a new cap. This program would include maintaining a
full, competent vegetative layer and semi-annual inspection of
the cover to ensure excessive erosion of leachate seep formation
are not occurring. Any such erosion or leachate seeps would be
. repaired by the placement of compacted clay and top soil over the
damaged area. .
A ground-water monitoring program would be implemented to ensure
that off-site releases of contaminants are not occurring. This.
program would follow the state of Indiana's sanitary landfill
post-closure ground-water monitoring requirements identified
under 329 IAC 3-45. The results of the monitoring data would be
periodically assessed to determine whether additional remedial
actions are warranted. Periodic surface water monitoring would
also be conducted. In addition, periodic sediment monitoring
would be conducted, if elevated levels of contamination are
detected in either the groundwater or surface water samples.
This Alternative is an integral part of the Alternatives 3, 3A,
4, 4A, 5, 5A, 6 and 6A.
Estimated
Estimated
Estimated
Estimated
Capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$ 79,000
$ 56,000
$940,000
3 to 6 months
Alternative 3: SANITARY LANDFILL CAP/PERIMETER CUT-OFF WALL
Alternative.3 consists of a sanitary landfill cap for surface
containment of the waste material and a soil-bentonite slurry
wall for containment of the on-site groundwater in the upper
aquifer. The landfill cap would consist of a compacted layer
under a 6 inch layer of vegetated topsoil. The compacted layer
would be 2 feet thick for slopes of less than 15 " 3 feet thick
for slopes of between 15. and 25 ',and 4 feet thick for Slopes of
greater than 25 , to' conform with the substantive provisions of
Indiana Solid Waste Management Regulations contained in 329 IAC
15
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2-14-19 and RCRA Subtitle D. Provisions would be made to install
a 12 inch gas collection layer with either active or passive gas
collection vents beneath the compacted layer.
A soil boring program would be conducted along the perimeter of
slurry wall to establish the depth to the inferred aquitard (low
permeability confining layer) beneath the site. To ensure
adequate groundwater containment, the bottom of the soil-
bentonite slurry wall would be at least 20 feet below the
existing land surface and would be keyed into a low permeability
confining layer. It is expected that the depth of the slurry
wall varies from 20 feet to approximately 45 feet below the land
surface over the length of the perimeter slurry wall, and that
the slurry wall would have an effective permeability of 10.7
em/sec. Section 6.2.3.1 of the FS Repor~ contains a detailed
description of this alternative. .
.. To maintain a water table elevation within the slurry wall below
the water table elevation outside the slurry wall, at least 16
extraction wells recovering 0.5 to 2.0 gallons per minute each
would be installed along the inside face of the eastern leg of
the slurry wall. These wells would have to be periodically
operated to maintain inward gradients along the entire eastern
side of the slurry wall. It is expected that e„cessive drawdown
would not occur in the adjacent wetlands. If, .however,
unacceptable drawdowns were to occur in the wetlands area,
provisions would be made to install an adjustable weir within
Sloan Ditch as a means of maintaining proper water levels in the
wetlands~ In addition, institutional controls would be
implemented as described in Al~ernative 2.
It is unknown at this time whether the recovered groundwater
would require treatment prior to discharge. To account for any
treatment that may be required for the recovered groundwater from
the extraction wells, an on-site gro~ndwater storage and.
treatment system would be installed. The groundwater in the
storage tank would be processed, either continuously or on a
batch mode basis, through a filtration step followed by an air
stripper, if necessary. The treatment equipment would be housed
in a pre-enqineered metal building that would be sized to
facilitate .additional treatment equipment should they be required
some time in the future. Following on-site treatment as
necessary, the recovered groundwater would be discharged off-site
through Sloan Ditch under a National Pollution Discharge
Elimination System (NPDES) permit. .
Estimated capital Cost:
. Estimated-Annual O&M Cost:
Estimated Present Worth:
Estimated Time to Implement:
$
$
$
4,924,600
174,000
7,599,300
18 months
16
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Alternative 3A: RCRA SUBTITLE C CAP/PERIMETER CUT-OFF WALL
Alternative 3A consists of a RCRA Subtitle C Cap for surface
containment of the waste material and a soil-bentonite slurry
wall for containment of the on-site groundwater in the upper. .
aquifer. The description of this alternative is identical to
that of Alternative 3 except that the surface cap would be a RCRA
Subtitle'C Cap instead of a Indiana Sanitary Landfill Cap.
RCRA Subtitle C Cap incorporates a 2-ft minimum upper vegetated
layer, a minimum l2-inch drainage layer, and a low permeability
layer of compacted clay (2-ft minimum) in combination with a
synthetic membrane layer. The technical requirements for the
RCRA Subtitle C Cap are contained in Title 40 of the Code of
Federal'Requlations, Part 264 (40 CFR 264). Provisions would be
made to install a 12 inch gas collection layer with either an
active or passive gas collection vents beneath the low
permeability barrier layer;
As stated earlier, the descriptions for the construction of the
slurry wall, extraction wells, treatment systems are identical to
those of Alternative 3. The institutional controls described in
Alternative 2 would also be incorporated as part of this
alternative. Section 6.2.4.1 of the FS Report~ontains a
detailed description of Alternative 3A. . .
Estimated
Estimated
Estimated
Estimated
Capital Cost:
Annual O&M Cost:
Present Worth: '
Time to Implement:
$
S
$
6,845,800
174,000
9,520,500
21 months
Alternative 4:
SANITARY LANDFILL CAP/PERIMETER CUT-OFF WALL
WITH TARGETED DRUM RBMOVAL
Alternative 4 consists of a sanitary landfill cap for surface
containment of 'the waste material and a soil-bentonite. slurry
wall for containment 'of the on-site groundwater in the upper
aquifer. In addition, this alternative would also include the
removal and disposal off-site of drummed andnoncontainerized
waste material which exhibits RCRA hazardous waste
characteristics per TCLP test. The drums and the waste materials
to pe removed are located in the hot-spot area in the northern
portion of the landfill. Figure 2 of the ROD identifies this
hot-spot area.
The descriptions for the construction of the landfill cap, slurry
wall, extraction wells; 'and.the treatment systems are identical
to those of Alternative 3, and thus will not be repeated here.
Under this Alternative, the entire volume of buried waste
material in the hot-spot area of the landfill would be excavated.
Following site-specific'health and safety procedures, waste
, materials in the hot-spot area would be excavated by the use of a
17
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backhoe and placed in temporary storage area with appropriate
containment features. Any intact or partially intact drums
containing appreciable amounts of waste material, would be
handled, sampled, and disposed off-site. Any waste material not
contained in drums would be sampled to determine if it exhibits
RCRA hazardous waste characteristics per TCLP test results. All
waste materials exhibiting RCRA hazardous waste characteristics
would be dispo~ed off-site in compliance with Land Disposal
Restrictions. All non-containerized waste material determined
not to exhibit RCRA hazardous waste characteristics would be
reconsolidated into the landfill prior to placement of the
landfill cap. In addition, all of the institutional controls
described in Alternative 2 would be incorporated as part of this
alternative. Section 6.2.5.1 of the FS Report contains a
detailed description of Alternative 4.
For the purposes of cost estimating, the FS Report assumes that
there are approximately 3,300 drums containing waste materials
and 500 cubic yards of non-containerized waste material .
exhibiting RCRA hazardous waste characteristics. Out of these
3,300 drums, approximately 1650 drums are assumed to be intact or
partially intact and the materials in these drums require off-
site treatment and disposal. Based on Indiana State Records and
.other information, at least 18,000 drums of waste were disposed
of in the landfill. Although waste materials were disposed of
throughout the landfill, drum disposal was predominant in the
hot-spot area. This area was referred in the State records as a
drummed waste area. U.S. EPA believes that there may be a
significantly greater number of drums than the estimated 3,300
drums in this hot-spot area. The cost estimate provided below is
based on the removal, off-site treatment and/or disposal of 1,650
intact or partially intact drums and may vary depending on the
type of waste and the number of drums encountered at the site.
Estimated
Estimated
Estimated
Estimated
Capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$ 7,798,600
$ 174,000
$ .10,473,300
18 months
Alternative 4&: aCRA SUBTITLE C CAP/PERIMETER CUT-OPP WALL WITH
TARGBTBD DRUM REMOVAL .
Alternative 4A consists of a RCRA Subtitle C Cap for surface
containment of the waste material and a soil-bentonite slurry
wall for containment of the on-site groundwater in the upper
aquifer. In addition, this alternative would also include the
removal of waste .material contained in drums. and removal of
wastes not contained in drums but which exhibit RCRA hazardous
waste characteristics. . The description of this alternative is
'identical to that of. Alternative 4 except. that the surface cap
would be a' RCRA Subti~le C Cap instead of a'Indiana Sanitary
Landfill Cap. The description for the RCRA Subtitle C Cap is
18
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described in Alternative 3A whereas the description for the drum
removal procedure is described in Alternative 4, and thus will
not be repeated here. The descriptions for the construction of
the slurry wall, extraction wells, and the treatment systems are
identical to those of Alternative 3. In addition, the
institutional controls described in Alternative 2 would also be
incorporated as part of this alternative. Section 6.2.6.1 of the
FS Report contains a detailed description of Alternative 4A.
As stated earlier in Alternative 4, the cost estimate for
Alternative 4A is also based on the removal of 1650 intact or
partially intact drums containing waste material and 500 cubic
yards of non-containerized waste material, and may vary depending
on the type of waste and the actual number of drums encountered
during remedial action.
Estimated
Estimated
Estimated
Estimated
capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$ 9,719,700
$ 174~000
$ 12,394,400
21 months
SANITARY LANDFILL CAP/DOWNGRADIENT SUBSURFACB
DRAIN
Alternative 5 consists of an Indiana Sanitary Landfill Cap for
surface containment of the waste material and a downqradient
subsurface drain for passive recovery of the on-site groundwater
in the upper aquifer. Descriptions of the Indiana Sanitary
Landfill Cap have been previously described in Alternative 3 and
thus will not be repeated here. The downgradient subsurface"
drain would consist of a gravel-filled trench with a perforated
drain pipe positioned approximately parallel to Sloan Ditch along
the eastern edge of the site. The subsurface drain would
function similar to a line of extraction wells by creating a
continuous zone of depression in the water table along the entire
drainage trench. Its intended function would be to recover the
potentially affected on-site groundwater in the "upper aquifer
that would otherwise discharge to Sloan Ditch or the adjacent
wetlands. ~he subsurface drain would be placed down to a depth
approximately 20 to 25 feet below land surface along the proposed
alignment of the drain. A geotextile fabric would be wrapped
around the drain pipe to minimize the potential for silt
accumulation. An impervious flexible membrane liner would be
keyed into the glacial till below the drain pipe and would extend
up the downqradient wall of the drain trench to a point just
below the ground surface. The function of the impervious liner
along the downgradient face of the subsurface drain is to.
minimize any long-term dewatering that may occur in the wetlands
adjacent to the drain. The open drain pipe would be backfilled
with sand and/or gravel to provide a highly permeable drainage
envelope. The drain pipe would convey the recovered groundwater
Alternative 5:
19
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to a series of concrete collection sumps installed alonq the
aliqnment of the drain.
It is unknown at this time whether the recovered qroundwater
would require treatment prior to discharqe. To account for any
treatment that may be required, the water in the sumps would be
pumped to an on-site qroundwater storaqe and treatment system.
The qroundwater in the storaqe tank would be processed, either
continuously or on a batch mode basis, throuqh a filtration step
followed by an air stripper, if necessary. The treatment
equipment would be housed in a pre-enqineered metal buildinq that
would be sized to facilitate additional treatment equipment
should they be required some time in the future. Followinq on-
site treatment as necessary, the recovered qroundwater would be
discharqed to Sloan Ditch under an NPDES permit.
In addition, the institutional controls described in Alternative
2 would also be incorporated as part of this alternative.
Section 6.2.7.1 of the FS Report contains a detailed description
of Alternative 5.
Estimated
Estimated
Estimated
Estimated
Capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$
$
$
4,041,200
193,000
7,00~,000
18 months
Alternative SA: RCRA SUBTITLE C CAP/DOWNGRADIENT SUBSURFACE DRAIN
Alternative 5A consists of a RCRA Subtitle C Cap for surface
containment of the waste material and a downqradient subsurface
drain for passive recovery of the on-site qroundwater in the
upper aquifer. Alternative 5A is identical to Alternative 5
except that the surface cap would be a RCRA Subtitle C Cap
instead of an Indiana sanitary Landfill Cap. Descriptions of the
RCRA Subtitle C Cap has been previously described in Alternative
JA and thus will not be repeated here. Descriptions of the
subsurface drain is identical to that of Alternative 5 and thus
will not be repeated here. Institutional controls described in
'Alternative 2 would also be incorporated as part of this
alternative. Section 6.2.8.1 of the FS Report contains a
detailed description of Alternative 5A. .,'
Estimated
Estimated
Estimated
Estimated
Capital Cost:
Annual O&M Cost:
Present Worth: .
Time to Implement:
$
$
$
5,962,200
193,000
8,929,000
21 months
Alternative I:' SANITARY LANDFILL CAP/DOWNGRADIENT SUBSURFACE
, DRAIN WITH TARGETED DRUM RBKOVAL'
This alternative consists of a sanitary landfill cap for surface
containment of the waste material and a dOwnqradient subsurface
20
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drain for passive recovery of the on-site groundwater in the
upper aquifer. In addition, this alternative would also include
the removal of waste material contained in drums and removal of
wastes .not. contained in drums but which exhibit RCRA hazardous
waste characteristics. Descriptions for the sanitary Landfill
Cap, drum removal and subsurface drain have been previously
described in Alternatives 3, 4, and 5 respectively, and thus will
not be repeated here. The Institutional controls described in
Alternative 2 would also be incorporated as a part of this
alternative. section 6.2.9.1 of the FS Report contains a
detailed description of Alternative 6.
As stated earlier in Alternative 4, the cost estimate for
Alternative 6 is also based on the removal of 1650 intact or
partially intact drums containing waste material and 500 cubic
yards of non-containerized waste material, and may vary.dependin9
on the type of waste and the actual number of drums encountered
during remedial action.
Estimated
Estimated
Estimated
Estimated
capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$
$
$
6,915,000
193,000
9,881,800
18 months
Alternative 'A: RCRA SUBTITLE C CAP/DOWNGRADIE~ SUBSURFACE DRAIN
WITH TARGETED DRD REMOVAL
Alternative 6A consists of a RCRA Subtitle C cap for surface
containment of the waste material and a downgradient subsurface
drain for passive recovery of the on-site groundwater in the
upper aquifer. In addition, thls alternative would include the
removal of waste material contained in drums and the removal of
non-containerized waste material that exhibit RCRA hazardous
waste characteristics. Alternative 6A is identical to
Alternative 6 except that the surface cap would be a RCRA .
Subtitle C Cap instead of an Indiana Sanitary Landfill Cap. The
descriptions for the RcRA Subtitle C Cap, drum removal, and
subsurface drain have been previously described in Alternatives
3A, 4, and 5 respectively, and thus will not be repeated here.
The institutional controls described in Alternative 2 would also
be incorporated as part of this alternative. Section 6.2.10.1 of
the FS Report contains a detailed description of Alternative 6A.
As stated earlier in Alternative 4, the cost estimate for
Alternative 6A is also based on the removal of 1,650 intact or
partially intact drums containing waste material and 500 cubic
yards of non-containerized waste material, and may vary depending
on the type of waste and the actual number of drums encountered
during remediai action.
21
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Estimated
Estimated
Estimated
Estimated
capital Cost:
Annual O&M Cost:
Present Worth:
Time to Implement:
$ 8,836,100
$ 193,000
$ 11,802,900
21 months
The alternatives for the LDL site are summarized in the following
table.
Table 7:
REMEDIAL ALTERNATIVES
LAKELAND DISPOSAL LANDFILL SITE
CLAYPOOL, INDIANA
INDIANA RCRA
SANITARY SUB-TITLE 'c'
LANDFILL CAP LANDFILL CAP
SLURRY WALL ALTERNATIVE 3 ALTERNATIVE 3A SLURRY WALL
+ +
EXTRACTION $ 7.6 MILLION $ 9.52 MILLION EXTRACTION
WELLS . WELLS
SLURRY WALL ... SLURRY WALL
EXTRACTION ALTERNATIVE 4 ALTERNATIVE 4A EXTRACTION
WELLS WELLS
+ $ 10.47 KILLION $ 12.39 MILLION +
DRUM REMOVAL DRUM REMOVAL
SUBSURFACE ALTERNATIVE S ALTERNATIVE SA SUBSURFACE
DRAIN DRAIN
$ 7.01 MILLION $ 8.93 MILLION
SUBSURFACE ALTERNATIVE 6 ALTERNATIVE 6A SUBSURFACE
DRAIN DRAIN
+ $ 9.88 MILLION $ 11..80 MILLION +
DRUM REMOVAL DRUM REMOVAL
8.0 'co~Dara~iv. ADalvsis of Al~.rna~iv.sl
Th. Rin. cri~.ria
The NCP requires that the alternatives be evaluated against nine
evaluation criteria. . This section summarizes the relative
performance of the alternatives by highlighting the key.
differences among ~he alternatives in relation to these criteria.
The nine evaluation criteri~ are grouped into three categories
as: (1) ThresholdCri~eria; (2) Primary Balancing Criteria; and
(3) Modifying Criteria. Each of these terms is described as
follows:
22
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A.
Threshold Criteria
1) Overall Protection of Human Health and the Environment
addresses whether a remedy provides adequate protection of
human health and the environment and describes how risks
posed through each exposure pathway are eliminated, reduced
or controlled through treatment, engineering, or
institutional controls. The selected remedy must meet this
criteria. .
Alternative 1 (No Action): Based upon the detailed analysis, it
was concluded that Alternative 1 - No Action, would not satisfy
the criterion of ensuring the overall protection of human health
and the environment. The Baseline Risk Assessment has documented
unacceptable risks present at the site and Alternative 1 does not
. meet .this criterion because no remedial action would be taken to
address the present and future uses of the site and contaminant
migration from the site. .
Alternative 2 (Institutional Controls): The perimeter fence and
the deed restrictions to protect remedial components from future
on-site development, in addition to restrictions on water wells
in the area of contamination, that are proposed under this
alternative would effectively minimize the pote~tial for
accidental human exposure to buried waste mater1al and to the
contaminated on-site qroundwater in the shallow aquifer.
Fencing, however, would not prevent wildlife such as birds and
moles from inhabiting the site.
Groundwater monitoring would detect any trends in the quality of
on-site qroundwater and would be effective in establishing
whether off-site releases of contaminants, via groundwater
migration, were occurring, thus potentially contaminating off-
site wells.
Although the landfill cover maintenance program.would include
provisions for remediatinq surface leachate seeps, it would not
. be fully effective in minimizing the releases due to leachate
seeps. Future leachate seeps may cause contaminants to be
released to the air via passive volatilization and to the
adjacent wetlands and to Sloan Ditch vIa surface run-off. This
alternative would not prevent the continued leaching of
contaminants from the waste material into the groundwater.
Also, this alternative would not prevent the. release of methane
gas and associated VOCs from the landfill. Therefore,
Alternative 2 would provide a low degree of overall protection of
human health and .the environment.
Alternative 3 (8anita~ Landfill Ca~/Perimeter CUt-off Wall):
'Indiana Sanitary Landfill Cap proposed under this alternative
would be effective in ~reventing surface exposure. of the buried
waste material, dissipatinq any landfill qases that may be
23
An
-------
qenerated, and preventinq the development of leachate seeps~ The
perimeter slurry wall would function to contain the contaminated
qroundwater in the upper aquifer. Horizontal containment
provided by the slurry wall combined with the natural vertical
containment provided by the underlyinq aquitard would ensure that
off-site releases of contaminants would not occur via qround-
water miqration. The sanitary landfill cap in combination with
the slurry wall would. prevent any future adverse impacts from
occurrinq to the adjacent wetlands, and to the surface water and
sediments in Sloan Ditch. An on-site qroundwater treatment
system would be effective in achievinq the necessary contaminant
removal efficiencies required under an NPDES permit for discharqe
to Sloan Ditch. Alternative 3, in combination with the
institutional controls, would provide a hiqh deqree of overall
protection of human health and the environment. . . .
Alternative 3A CRCRA SUbtitle C caD/Perimeter cut-off .all):
Alternative 3A is identical to Alternative 3 except that the
surface cap would be a RCRA Subtitle C Cap instead of a sanitary
landfill cap. RCRA Subtitle C Cap provides siqnificantly hiqher
deqree of protection aqainst downward water infiltration than
would a sanitary landfill cap. However, neither cap option would
entirely eliminate the formation of leachate due to the fact that
a portion of the waste material may still lie below the water
table. Under the RCRA Subtitle C Cap scenario, a lesser amount
of leachinq of contaminants from the landfill to the qtoundwater
would result, than would under the sanitary landfill cap
scenario. The proposed slurry wall would contain the
contaminated qroundwater in the upper aquifer and prevent its,
miqration off-site. Therefore, Alternative 3A, in combination
with the institutional controls, would also provide a hiqh deqree
(sliqhtly better than Alternative 3) of overall protection of
human health and the environment.
Alternative 4 (Sanitarv Landfill C&D/Perimeter Cut-Off .all with
Taraeted Drum Removal): Alternative 4, in addition to
incorporatinq all the remedial measures included in Alternative
3, includes tarqeted drum removal as a means of providinq
potential reduction of toxic contaminants at the site. The
removal of any intact or partially intact drums and non-
containerized waste materials exhibitinq RCRA hazardous waste
characteristics would serve to potentially reduce the mass of
toxic contaminants within the LDL Site. Based on the assumption
in the FS Report that approximately 3,300 drums would be
encountered at the hot-spot location, the expected reduction in
the total number of drums is approximately 18%. This alternative
, has an increased potential for short-term worker exposure.and
contaminant releases that may result from the excavation and
handlinq of waste materials at the.site. However, with proper
health and safety precautions, the potential for short-term
worker exposure and contaminant releases could be effectively
minimized. With the removal of drums containinq toxic waste
24
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~aterials, Alternative 4 provides a hiqher deqree of lonq-term
effectiveness and permanence than Alternatives 3 and 3A. In
combination with the sanitary landfill cap, slurry walls and
treatment system proposed in Alternative 3, and with the
incorporation of the institutional controls, Alternative 4 would
provide a hiqher deqree of overall protection of human health and
the environment than Alternatives") and )A.
Alternative 4A (RCRA Subtitle C Ceo/Perimeter cut-Off _all with
TaraeteeS Drum Removal): Alternative 4A is identical to
Alternative 4 except that the surface cap would be a RCRA
Subtitle C Cap instead of a sanitary landfill cap. RCRA Subtitle
C Cap provides siqnificantly hiqher deqree of protection aqainst
downward water infiltration than would a sanitary landfill cap.
However, neither cap option would entirely eliminate the :
formation of leachate due to the fact that a portion of" the waste
material may still lie below the water table. Under the RCRA
Subtitle C Cap scenario, a lesser amount of leachinq of
contaminants from the landfill to the qroundwater would result,
than would under the sanitary landfill cap scenario. The
. proposed slurry wall would contain the contaminated qroundwater
in the upper aquifer and prevent its miqration off-site. The
proposed drum removal would serve to provide a hiqh deqree of
lonq-term effectiveness and permanence. TherefGre, Alternative
4A, in combination with the institutional controls, would also
provide a hiqher deqree (sliqhtly.better than Alternative 4) of
overall protection of human health and the environment than
Alternatives) and 3A.
Altern.t~ve 5 (Sanitarv LaneSfill Cao/DovnaraeSient Subsurface
Drain): An Indiana Sanitary Landfill Cap proposed under this
alternative would be effective in preventinq surface exposure of
the buried waste material, dissipatinq any landfill qases that
may be qenerated, and preventing the development of leachate
seeps. The subsurface drain proposed under this alternative
would serve to recover the potentially affected on-site
qroundwater in ~he upper aquifer that would otherwise discharqe
to Sloan Ditch or the adjacent wetlands. A potential drawback to
"the subsurface drain is that temporary dewaterinqof the upper
aquifer along the aliqnment of the drain would be req~ired for
its installation. This temporary dewaterinq may create short-
term adverse impact to the adjacent wetlands. The sanitary
landfill cap in combination with the subsurface drain would
prevent any future adverse impacts from occurrinq to the adjacent
wetlands. An on-site qroundwater treatment system would be
effective in achieving the necessary contaminant removal
efficiencies required under an NPDES permit for discharqe to
Sloan Ditch. Alternative 5, in combination with the
institutional controls, would provide a high deqree of ov~rall
protection of human health and the environment.
25
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Alternative SA (RCRA Subtitle C Caa/Downaradient Subsurface
Drain): Alternative SA is identical to Alternative 5 except that
the surface cap would be a RCRA Subtitle C Cap instead of a
sanitary landfill cap. RCRA subtitle C Cap provides
significantly higher degree of protection against downward water
infiltration than would a sanitary landfill cap. However,
neither cap option would entirely eliminate the formation of
leachate due to the fact that a portion of the waste material may
still lie below the water table, Under the RCRA Subtitle C Cap
scenario, a lesser amount of leaching of contaminants from the
landfill to the groundwater would result, than would under the
sanitary landfill cap scenario. The proposed subsurface drain
would serve to recover potentially affected on-site groundwater
from otherwise discharging to Sloan Ditch and to the adjacent.
wetlands. Therefore, Alternative SA, in .combination with the
institutional controls, would also provide a high degree
(slightly better than Alternative 5) of overall protection of
. human health and the environment.
Alternative' (Sanitarv Landfill CaD/Downaradient Subsurface
Drain with Taraeted Drum Removal): Alternative 6, in addition to
incorporating all the remedial measures included in Alternative
5, includes targeted drum removal as a means of providing
potential reduction of toxic contaminants at the site. The
removal of any intact or partially intact drums and non-
containerized waste materials exhibiting RCRA hazardous waste
characteristics would serve to potentially reduce the mass of
toxic contaminants within the LDL Site. . Based on the assumption
in the FS Report that approximately 3,300 drums would be
encountered at the hot-spot location, the expected reduction in
the total number of drums is approximately 18'. Thisalternative
has an increased potential for short-term worker exposure and
contaminant releases that may result from the excavation arid
handling of waste materials at the site. However, with proper
health and safety precautions, the potential for short-term
worker exposure and contaminant releases could be effectively
minimized. With the removal of drums containing toxic waste
materials, Alternative 6 provides a high degree of long-term
effectivene~s and permanence. In combination with the sanitary
landfill cap, subsurface drain, and treatment system proposed in
Alternative 5, and with the incorporation of the institutional
controls, Alternative 6 would provide a higher degree of overall
protection of human health and the environment than Alternatives
5 and SA.
Alternative SA lRCRA Subtitle C caD/Downara4ient Subsurface Drain
with Taraeted Drum Removal): Alternative 6A is identical to
Alternative 6 except that the surface cap would be a RCRA
Subtitle C Cap instead of a sanitary landfill cap. RCRA Subtitle
C Cap provides significantly hiqher degree of protecti~n against
downward water infiltration than would a sanitary landfill cap.
However, neither cap option would entirely eliminate the
,26
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formation of leachate due to the fact, that a portion of the waste
material may still lie below the water table. Under the RCRA
Subtitle C Cap scenario, a lesser amount of leaching of
contaminants from the landfill to the groundwater would result,
than would under the sanitary landfill cap scenario. The'
proposed subsurface drain would serve to recover potentially
affected on-site groundwater from otherwise discharging to Sloan
Ditch and to the adjacent wetlands. The proposed drum removal
would serve to provide a high degree of long-term effectiveness
and permanence. Therefore, Alternative 6A, in combination with
the institutional controls, would provide a higher degree
(slightly better than Alternative 6) of overall protection of
human health and the environment than Alternatives S and SA.
2) Compliance with Applicable or Relevant and Appropriate
Requirements (ABARs) addresses whether a remedy will meet
applicable or relevant and appropriate federal and state
environmental laws and/or justifies a waiver from such
requirements. The selected remedy must meet this criteria
or waiver of the ARAR must be obtained.
Alternative 1 (No Action):
for a "No Actionll remedy.
taken at a site to address
environment.
Compliance with ARARs does not apply
ARARs only apply when actions are
risks to human healtQ or the
Since Alternative 1 does not satisfy a Threshold Criterion, no
further evaluation a9ainst the Primary Balancin9 or Modifying
criteria is needed. Alternative 1 wi,ll not be chosen for the
site.
Alternative 2 (Institutional Controls): Currently the
groundwater in the upper aquifer outside the boundaries of the
landfill is contaminated with contaminants at levels above their
respectiye MCLs. In the absence of a remedial action, ,
institutional controls such as groundwater monitoring would not
ensure that chemical-specific ARARs are not exceeded outside the
boundaries of the landfill, nor would such controls reduce off-
site migration of the contaminated groundwater. Also, this
alternative would not fully comply with all of its identified
action and location specific ARARs, such as Indiana sanitary
landfill closure requirements.
Since Alternative 2 does not satisfy a Threshold Criterion, no
further evaluation against the Primary Balancing or Modifying
criteria is needed. Alternative 2 will not be chosen for the
site.
Alternatives 3, 3A, 4, 4A, 5, SA, " and 'A: Alternatives 3, 3Ar
4, 4A, 5, 5A, 6, and 6A would comply with all of their identified
location and action-specific ARARs. If the point of compliance
is determined to be at the downgradient edge of the waste
27
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manaqement area (i.e., at the
cap, perimeter slurry wall or
alternatives 3, 3A, 4, 4A, S,
specific ARARs.
downqradient edqe of the landfill
subsurface drain), all of the
SA, 6, and 6A would meet chemical-
B.
PrimarY Balancina criteria
3) Lonq-term Effectivene.. and Permanence refers to expected
residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time, once cleanup levels have been met.
Alternative. 3, 3A, 4, 4A, 5, SA, I, and 'A: Alternatives 3, 4,
S, and 6 consist of an Indiana sanitary Landfill Cap.
Alternatives 3A, 4A, SA, and 6A consist of RCRA Subtitle C Cap.
. Both.of these caps would provide lonq-term effectiveness and
permanence in preventinq surface exposure of the buried waste
material, dissipatinq any landfill qases that may be qenerated,
and minimizinq the potential for the development of leachate
seeps. RCRA Subtitle C Cap under Alternatives 3A, 4A, SA, and 6A
would provide a siqnificantly hiqher deqree of protection aqainst
downward water infiltration than would an Indiana Sanitary
Landfill, Cap under Alternatives 3, 4, S, and 6. Under the RCRA-
.Subtitle C Cap scenario, a lesser amount of lea~hinq of
contaminants from the landfill to the qroundwate~ would result,
than would under the sanitary landfill cap scenario.
Alternatives 3, 3A, 4, and 4A utilize a perimeter slurry wall to
contain the contaminated on-site qroundwater in the upper
aquifer. Alternatives S, SA, 6, and 6A utilize subsurface drains
which serve to recover the potentially affected on-site
qroundwater in the upper aquifer that would otherWise discharqe
to Sloan Ditch or the adjacent wetlands. All of these
alternatives have provisions to recover, store and treat the
affected qroundwater as necessary to facilitate discharqe to
Sloan Ditch 'per an NPDES permit. Both the slur~y walls and the
subsurface drains, in combination with the surface caps, would
. prevent any future adverse impact to the adjacent wetlands, and
thus provide lonq-term effectiveness and permanence.
Alternatives 4, ~A, 6,'and 6A have additional provisions to
remove drums containing toxic wastes and non-containerized waste
material exhibitinq RCRA hazardous waste characteristics in the
hot-spot area of the landfill. This removal. activity would
achieve a hiqher deqree of lonq term effectiveness and permanence
than' the other alternatives.
Thus Alternatives 3A, 4A, SA, and 6A, which include RCRA Subtitle
C ~aps, are sliqhtly better than Alternatives 3, 4, S, and 6,
. which include Indiana Sanitary Landfill Caps, in aChievinq lonq-
term effectiveness and permanence. Alternatives 4, 4A, 6, and 6A
which have provisions. for removal of drums containinq toxic
28
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material would provide a hiqher deqree of lonq-term effectiveness
and permanence when compared to Alternatives J, JA, S, and SA,
which do not have any provisions for drum removal.
4) .Reduction of Toxicity, Mohility, and" Volume throuqh
Treatment addresses the statutory preference for selectinq
remedial actions that employ treatment technoloqies that
permanently and siqnificantly reduce toxicity, mobility, or
volume of the hazardous substances as their principal
element. This preference is satisfied when treatment is
used to reduce the principal threats at the site throuqh
destruction of toxic contaminants, reduction of the total
mass of toxic contaminants, irreversible reduction in
contaminant mobility, or reduction of total volume of
contaminated media. "
Alternative. 3,3A, 4, 4A, 5, 5A, I, and IAI Alternatives J, 3A,
5, and SA do not employ any remedial measures for treatment of
the buried waste material. Therefore, there would be no "
reduction in the toxicity, mobility, or volume of the principal
threats in the landfill. Alternatives 4, 4A, 6, and 6A provide
for the removal of intact or partially intact drums containinq
potentially toxic waste material, and the removal of non-
containerized waste material exhibitinq RCRA ha~ardous waste
characteristics. The toxicity, mobility, and volume of both
drummed and non-containerized waste material would be reduced
throuqh off-site treatment and/or disposal. In all of the
alternatives, by recoverinq on-site qroundwater, there may be a
reduction over time in the volume of affected on-site
qroundwater. Thus Alternatives 4, 4A, 6, and 6A, which provide
for the removal of drums, would provide a "siqnificantly hiqher
deqree of reduction of toxicity, mobility~ and volume of
potentially toxic material at the LDL Site, than would . .
Alternatives 3, 3A, 5, and SA, which do not employ any treatment.
5) Short-term effectivene.. addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed, until
cleanup levels are achieved.
Alternativ.. 3, 3A, 4, 4A, 5, 5A, I, and IAI For Alternatives 3
and 3A, there would be a sliqht potential for worker exposure and
contaminant releases durinq installation of the slurry wall and
extraction wells. For Alternatives 5 and SA, there would also be
a sliqht potential for worker exposure and contaminant releases
durinq the installation of subsurface drains. In addition,
. installation of the subsurface drains may cause short-term
adverse impacts to.the adjacent wetlands because the upper
aquifer alonq the alignment of the 'drain would have to be
temporarily dewatered to facilitate its installation. However,
it is expected that the long-term condition of the adjacent
wetlands would not be adversely affected by the subsurface drain.
29
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For Alternatives 4, 4A, 5, and SA, there would be an increased
potential for worker exposure and contamination releases
resultinq from the excavation and handlinq of waste material.
However, with proper health and safety precautions, this can be
effectively minimized. In all of the alternatives, the type of
cap employed (i.e., RCRA Subtitle C Cap vs. Indiana Sanitary
Landfill Cap) does not influence the comparative assessment of
short-term effectiveness. Therefore, Alternatives 3, 3A, 5, and
SA pose less short-term effectiveness than alternatives 4, 4A, 6,
and 6A, which include provisions for the removal of waste
material at the LDL Site. Because Alternatives 5, SA, 6, and 6A
would cause short-term adverse impacts on the adjacent wetlands
durinq implementation, Alternatives 3, 3A, 4, and 4A are better
than Alternatives 5, SA, 6, and 6A.
I) Implementa~ility is the technica~ and administrative
feasibility of a remedy, includinq the availability of
materials and services needed to implement a particular
option.
" Alternative. 3, 3A, 4, 4A, 5, 5A, I, and IA: All of the
Alternatives require strict health and safety precautions to be
taken durinq implementation to minimize the potential for worker
exposure and contaminant releases. The RCRA SUQtitle C Cap is
sliqhtly more difficult to implement than the Indiana Sanitary
Landfill Cap. The additional remedial measure of tarqeted drum
removal provided under Alternatives 4, 4A, 6, and 6A is sliqhtly
more difficult to implement than Alternatives 3, JA, 5, and SA.
The subsurface drain component of Alternatives 5, SA, 6, and 6A,
which requires temporary dewaterinq of the upper aquifer alonq
the aliqnment of the drain, is more difficult to implement than
the slurry walls and extraction wells under Alternatives J, JA,
4, and 4A. With proper health and safety precautions and/or
proper hydraulic controls, all of the alternatives can be
implemented without excessive difficulties. Alternatives J, 4,
5, and 6 could all be implemented within a time frame of 12 to 18
months, whereas Alternatives 3A,4A, 5A, and 6A would require an
implementation time frame of 15 to 21 months.
7) C08t "includes estimated capital and operation" and
maintenance (0&") costs, also expressed as net present-worth
cost.
Specific details reqardinq the costs of the remedies are
available in the FS.
Alternatives JA,4A, 5A, and 6A cost approximately $1,921,200.
more than'Alternatives 3, 4, 5, and 6, respectively. The
increase in cost is due to the hiqher cost associated with the
RCRA Subtitle C Cap vs. the Indiana Sanitary Landfill Cap.
Alternatives 4, 4A, 6, and 6A cost approximately $2,874,000 more
30
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than Alternatives 3, 3A, 5, and 5A, respectively. This increase
is due to the additional cost involved in the removal of drummed
waste and non-containerized waste material, based on an
assumption. of a total of 3,300 drums and 500 cubic yards of waste
material exhibitinq RCRA hazardous waste characteristics. This
cost for the removal of drums and non-containerized waste
material varies dependinq on the actual number of drums
encountered at the site and the amount of waste material found to
exhibit RCRA hazardous waste characteristics. Because the
subsurface drain is relatively inexpensive to install when
compared to the installation of slurry walls and extraction
wells, Alternatives 5, 5A, 6, and 6A cost less than Alternatives
3, 3A, 4, and 4A, respectively.
c.
Modifvina criteria
8) Support Aqency (IDEM) acceptance reflects aspects of the
preferred alternative and other alternatives the IDEM favor
or object to, and any specific comments reqardinq federal
and state ARARs or the proposed use of waivers.
9) community acceptance is assessed in the Responsiveness
Summary. The Responsiveness Summary provides a thorouqh
review of the public comments received on. the Proposed Plan,
and the Aqency's responses to those comments.
9.0 . The Selected Remedv
The u.S. EPA and IDEM have conducted an analysis of the potential
remedies and u.S. EPA has chosen Alternative 4 as the remedy for
the LDL Site. Alternative 4 consists of a perimeter cut-off wall
in conjunction with an Indiana sanitary Landfill Cap and tarqeted
drum removal. The institutional controls described under'
Alternative 2 would also be incorporated as part of this remedy.
Fiqures 3 and 4 of the ROD show the lateral extent and a typical
cross section of the Indiana Sanitary Landfill Cap, respectively.
The Indiana Sanitary Landfill Cap would effectively reduce
surface water infiltration, control qas emissions and prevent
direct contact with the waste materials. The soil-bentonite
slurry wall around the perimeter of the landfill would
effectively contain on-site qroundwater in the upper aquifer.
The aquitard, below elevation 979 feet, provides a natural
vertical containment of the on-site qroundwater. The extraction
wells alonq the inside face of the downqradient slurry wall would
serve to maintain an inward qradient and ensure that contaminated
on-site qroundwater would not miqrate off-site. Recovered
qroundwater would.be collected and stored.
The qroundwater Performance Standards for the LDL Site are the
Federal MCLs and the substantive provisions of Indiana.State's
Grounds Water Quality Standards, 327 lAC 2-1-7, whichever is more
31
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v Cap and .lurry wall location.
are approximate and not drawn
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./~
. Figure 3. .
ROD - tateral Extent of Surface Cap and Slurry Wall
~laad D18po8.l Landfill.
-------
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t
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VEGETA TlOH
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(A ASH TO MC3; NO. 57)
GAS CO' I -CTIOH SYSTDI UTILIZID 'MSIVa GAS VEHTI (HOT SHOWN)
. 2'. SLoPES c 1ft .
SO. SLGPIS & 1ft TO S 2ft
C'. ILOPD a 2ft
ROD -
Indiana
.'
Fiqure 4.
sanitary Landfill Cap cross-section
Lak8land D1~po.~1 Landfill
-------
stringent. Because there is no MCL for lead, the cleanup level
for this contaminant in groundwater will be the federal action
level of 15 ppb. The point of compliance for groundwater
Performance Standards for the source containment system shall be
adjacent to the perimeter of the slurry wall, as measured through
a series of u.s. EPA designated monitoring wells. The purpose of
the monitoring wells is to ensure that contaminated groundwater
below the landfill is not migrating from the upper aquifer to
either the lower aquifer or to Sloan Ditch. The selected remedy
will meet MCLs and the lead action level at the boundary of the
waste management unit and thus will comply with these standards
outside the slurry wall.
To account for any treatment that may be required for recovered
groundwater, the remedy provides for installation of an .on-site
treatment system. Following on-site treatment as necessary, the
recovered groundwater would be discharged to Sloan Ditch.
Discharged recovered groundwater will meet the substantive
requirements of an NPDES permit. Sloan ditch is located
partially on the site. If the discharge point is located on
site, the substantive requirements of an NPDES permit will be
met; if the discharge point is located off-site, then an NPDES
permit will be required.
,
Based on the groundwater model simulations, it is expected that
there would not be excessive drawdowns in the adjacent wetlands.
If, however, unacceptable drawdowns were to occur in the wetlands.
due to the slurry wall and extraction wells, the remedy includes
provisions for installation of an adjustable weir in Sloan Ditch
to maintain proper water levels in the wetlands. To minimize. or
eliminate any short-term damage to the adjacent wetlands during
installation, the remedy provides for installation of the slurry
wall as close to the edge of the landfill cap as possible.
. The remedy also includes a groundwater monitoring program and all
of the institutional controls, as described under Alternative 2,
including site fencing, groundwater advisories, .and possible deed
restrictions and well abandonment as provided for by Indiana
regulations~ A groundwater monitoring program, which includes
periodic monitoring of groundwater, surface.water and sediments,
and residential wells, if necessary, will be established to
monitor the effectiveness of the remedy and provide assurance
that contaminated groundwater from the site is not impacting the
local residents or the environment.
The Remedial Desiqn will include a wetland assessment to
determine if any significant portions of the wetlands are.
affected by the installation of the cap and the slurry wall.
Based on this assessment, the remedial action will include a
program to mitigate, replace and/or restore wetlands, if
necessary. No estimate of the costs associated with the wetlands
assessment is available at this time.
32
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The u.s. EPA has determined that the selected remedy is the best
balance of desirable characteristics among the alternatives with
respect to the nine criteria. Based on information available at
this time, the U.S.EPA believes that the selected remedy offers
the best protection of human health and the environment, complies
with ARARs, eliminates long-term risks, reduces toxicity,
mobility or volume through treatment, is easily implemented and
is cost effective. By cutting off surface leachate discharges to
the adjacent wetlands and to Sloan Ditch, the sediment and the
surface water quality will 'be improved, benefitting the local
environment. The removal, off-site treatment and/or disposal of
drummed waste materials in the hot-spot area would satisfy
statutory preference for treatment as a principal element.
At the present time, IDEM has not fully concurred with u.s. EPA's
selection of Alternative 4 as the chosen.remedy for the LDL Site.
IDEM concurs with the installation of the Indiana Sanitary
Landfill Cap, targeted drum removal, extraction wells, treatment
of the recovered groundwater, and institutional controls. . IDEM
has taken the position that the extraction wells without
containment by a slurry wall are likely to be more effective in
capturing all groundwater at the LDL Site. IDEM recommends that
the decision to install a slurry wall be contingent on the
results of monitoring groundwater downgradientfrom the
extraction wells. Specific responses to IDEM's recommendations'
are given in the following Responsiveness Summary.
10.0 Statutory Determinations
Under .its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several 'other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for this site must comply
. with applicable or relevant and appropriate environmental
. standards established under Federal and State environmental laws,
.unless a statutory waiver is justified. The selected remedy also
must be cost effective and utili~e permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for treatment as principal element
of the remedy. The following sections discuss how the selected
remedy meets these statutory requirements.
10.1 Protection of Human Health and the Environment
The selec~ed remedy protects human health and the environment.
through containment of buried waste material and extraction and
treatment of selected wastes.
33
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The Indiana sanitary Landfill Cap will prevent surface exposure
of the buried waste material, will dissipate any landfill qases
that may be qenerated, and will prevent the development of
leachate seeps. The perimeter slurry wall would function to
contain the contaminated qroundwater in the upper aquifer.
Horizontal containment provided by the slurry wall combined with
the natural vertical containment provided by the underlyinq
aquitard would ensure that off-site releases of contaminants
would not occur vi~ qroundwater miqration. The sanitary landfill
cap, in combination with the slurry wall, would prevent any
future adverse impacts to the adjacent wetlands, surface water
and sediments in Sloan Ditch, and private drinkinq water wells.
The tarqeted drum removal in the hot spot will provide a
reduction of toxic contaminants at the site. The removal of any
intact or partially intact drums and non-containerized waste
materials exhibitinq RCRA hazardous waste characteristics will
serve to potentially reduce the mass of toxic contaminants within
the site. Based on the assumption in the FS Report that
approximately 3,300 drums would be encountered at the hot-spot
location, the expected reduction in the total number of drums at
the site is approximately 18%. This percentaqe will increase
with the increase in the total number of drums encountered at the
site. Any potential for worker exposure and contaminant releases
resultinq from excavation and handlinq of waste material can be
effectively addressed with proper health and sa~ety precautions.
There are no short-term threats associated with the selected
remedy that cannot be readily controlled.
Requlations promulqated under section 404 of the Clean Water Act,
33 U.S.C. 51344, provide that discharqes of dredqed or fill
material into naviqable waters, includinq wetlands, will be
permitted only if there is no practicable alternative to the
proposed discharqe which would result in a lesser impact to. the
aquatic ecosystem. 40 CFR 5230.10(a). The sanitary landfill cap
required as part of the selected remedy may result in fillinq
two potential wetland areas on site. Additionally, the slurry
wall and extraction well components of the selected remedy have
. the potential to cause short-term injury to wetland areas
adjacent to the cap, on the western edqe of Sloan Ditch. This
injury is expected to result from potential vehicular movement
throuqh a portion of the wetlands, which is necessary for
construction of these remedial components. Only two
alternatives, Alternative 1 (no action) and Alternative 2
(institutional controls), discussed above, will not require
fillinq on-site wetlands or vehicular movement on wetlands.
outside the proposed cap. These alternative remedies are not
practicable alternatives under the criteria set out in 40 CFR
230.10 because neit~er would remediate the present flow of
contaminants from the landfill into qroundwater, surface water,
soils, and wetlands on and off the site. Thus, these two
alternatives would pose a siqnificant adverse environmental
consequence to the aquatic ecosystem, and therefore, are not
34
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viable remedies for the site. As discussed in Section 8.0 above,
the selected alternative provides the most effective protection
of human health and the environment, taking into consideration
cost, existing technology, and logistics in light of overall
project purposes, as required by 40 CFR 230.10(a) (2).
Institutional Controls such as fencing, deed restrictions will
supplement the selected remedy by preventing access to the site
and limiting the land and groundwater usage at the site. The
long-term monitoring will ensure effectiveness of the selected
remedy.
10.2 ComDliance with ARARs
The selected remedy of extraction and treatment of wastes in the
hot-spot area, together with the Indiana Sanitary Landfill Cap
and slurry wall will comply with all applicable or relevant and
appropriate chemical, action, and location specific requirements
(ARARs). The ARARs are presented below.
Action-specific ARARs
Resource Conservation and Recovery Act (RCRA): The RCRA
regulations applicable to facilities treating,.etoring or
disposing of hazardous waste became effective November 19, 1980
(See 40CFR sections 264.1 and 265.1). The LDL facility ceased
operating and accepting wastes prior to that date. These
regulations are therefore not legally "applicable" to the LDL
facility.
These regulations are relevant, but not appropriate at the LDL
site for the following reasons. Waste material at the site
currently is in contact with groundwater, and is a source of
potential contamination. Thus, choosing a hazardous waste cap
rather ~han a sanitary landfill cap will not prevent further
leaching of contaminants into the aquifer below the LD~ Site.
The slurry wall, however, in conjunction with either a hazardous
waste cap or a sanitary landfill cap, will effectively mitigate
further groundwater contamination. Because both caps would
provide equivalent remedial results at the site, when used in
conjunction with the slurry wall, the choice of the more
expensive hazardous waste cap is not appropriate at the LDL Site.
Although new design requirements under 40 CFR 258.60 for covers
on solid waste landfills are applicable only to landfills that
received municipal waste after October 9, 1991, these design
standards are relevant. and ~ppropriate at the LDL Site. 40 CFR
258.60' requires that the cover on a solid waste landfill must
have (1) an infiltration layer of 18" of clay and (2) an erosion.
layer of 6" of soil capable of sustaining native plant growth.
Additionally, 40 CFR 258.61 requires maintenance of the integrity
and effectiveness of the final cover, collection leachate, and
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. .
monitorinq of qroundwater. These requirements are also relevant
and appropriate at the LDL Site.
The Selected Alternative will comply with the substantive
requirements of the followinq ARARs:
.
329 IAC 2-14-16 throuqh 329 lAC 2-14-24, which specifies
standards for Solid Waste Land Disposal Facilities.
Contains standards for final cover, and requirement to
monitor qroundwater.
.
329 IAC 2-16, which specifies qroundwater monitoring and
corrective action for solid waste land disposal facilities.
329 IAC 2-14-20, which specifies requirements for landfill
.qas collection and extraction treatment systems. .
.
.
The substantive requirements of 326 IAC 2, which requlates
any source which has the potential to emit air pollutants.
326 IAC 1-3, 6-4, 8-1, which spec~fies requirements for air
emission monitorinq 'with respect to primary and secondary
ambient air quality standards, particulate emissions, and
volatile orqanic compound emissions.,
.
327 IAC 3, substantive requirements of construction
standards for wastewater treatment facilities. There will
be construction of some on-site treatment equipment if
qroundwater requires treatment;
.
327 "IAC 15-5, substantive requirements of stormwater runoff
control provisions tor construction sites of five or more
acres. This provision may be necessary if construction
activities take place durinq any period of heavy rains.
. The Clean Water Act, 5404, 33 U.S.C. 51344, and requlations
promulqated thereunder, 40 CFR $230, requlate discharqes or "
fillinq ot naviqable waters, includinq wetlands. These
provisions are necessary to mitiqate potential injury to
wetlands. as a res~lt of im~lementinq the selecte~ remedy.
The Hazardous and Solid Waste Amendments (HSWA) to RCRA include
provisions restrictinq land disposal of RCRA hazardous wastes.
The purpose ot the HSWA is to minimize the potential of future
risk to human health and the environment by requirinq treatment
ot hazardous waste prior to land disposal. At the LDL site there
will be no land disposal on site, thus Land .Disposal Restrictions
do not apply. Containerized and non-containerized waste
exhibitinq RCRA hazardous waste characteristics per TCLP test
'will be shipped off-site for treatment and disposal in compliance
with RCRAqenerator'requirements under 40 CFR Part 262 and Land
Disposal Restrictions~
.
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o
,
Chemical-specific ARARs:
.
Pursuant to the Safe .Drinking Water Act, EPA has published
" maximum contaminant levels (MCLs) allowable in regulated
public water supplies, 40 CFR Part 141. The MCLs are
relevant and appropriate for use at the site since the lower
aquifer once was used as a drinking water source, and
remains a potential drinking water source. The selected
remedy will meet MCLs at the boundary of the waste.
management unit and thus will comply with this ARAR outside
the slurry wall;
Pursuant to the Safe Drinking Water Act, U.S. EPA has
published an action level for lead in drinking water, 40 CFR
141.2. The action level determines ~he treatment. .
requirements that a water system is required to complete for
specific contaminants. U.S. EPA has established a health-
based action level"for lead in drinking water sources at 15
ppb. This provision is relevant and appropriate for use at
the site since the lower aquifer is a potential drinking
water source, as explained above. The selected remedy will
meet the action level at the boundary of the waste
management unit and thus will comply with this ARAR outside
the slurry wall;,
.
.
The Clean Water Act requlates point source discharqe to
navigable waters. This Act is administered by the state of
Indiana under 327 lAC 5 and establishes surface water
quality standards. The state oversees point discharge
standards as promulgated by the Federal NPDES program under
this Act. The selected remedy would comply with this ARAR
by meeting the substantive requirements for an effluent
discharge permit and the terms and conditions of the
permit's effluent standards and limitations;
327 lAC 2-1, provides state minimum surface water quality
standards which apply to all waters of the state.
Location-specific ARARs:
.
.
Endangered Species Act (16 USC 1531); The Endangered
Species Act requires that actions must be performed to
conserve the endangered or threatened species located in and
around the LDL site. Activities.must not destroy or
adversely mOdify the critical habitat upon which endangered
species depend. The selected remedy will be implemented in
compliance with this regulation. Prior to conducting
remedial activities, a survey of the subject areas will be
conducted to determine whether or not endangered or
threatened species will be affected;
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.
IC 13-2-22, substantive provisions regarding construction in
floodway. The slurry wall, extraction and monitoring wells,
and water treatment discharge point may all be in the
floodway of Sloan Ditch.
-
.
Federal "To be Considered" Reauirements (TBCs)
In implementing the selected remedy, u.S. EPA and the State have
agreed to consider the following federal provisions that are
advisory, but not legally binding. .
.
Executive Order 11990 (40 C.F.R. Pt.6, App. A)i provides
that activities required in a wetland must minimize the
destruction, loss, or degradation of the wetland. In
addition, any affected wetlands may be restored, as
appropriate.
.
CERCLA Off-Site Policy, CERCLA S121(d) (3): The off-site
policy describes procedures that should be observed when a
response action under CERCLA involves off-site storage,
treatment or disposal of CERCLA waste. The purpose of the
policy is to prevent CERCLA wastes from contributing to
further environmental problems by placing them in facilities
where they will be appropriately managed. ,
10.3 Cost-Effectiveness
Cost effectiveness is determined by evaluating the following
three of five balancing criteria to determine overall
effectiveness: long-term effectiveness and permanence, reduction
of toxicity, mobility, or volume through treatment, and short-
term effectiveness. Overall effectiveness is then compared to
cost to ensure that the remedy is cost effective.
The selected remedy is cost-effective because it provides a high
degree of long-term effectiveness and permanence. Significant
. reduction in toxicity, mobility, and volume of drummed waste
material is achieved through the removal of drummed waste
material in the hot-spot area within the landfill. By adhering
to proper health and safety plans, no unacceptable short-term
risks will be caused by implementation of the remedy. Although
other alternatives provide long-term effectiveness and
permanence, only Alternatives 4, 4A, '6, and 6A provide for the
reduction ot toxicity, mobility, or volume of toxic contaminants
through treatment. Of these four remedies, alternatives 6 and 6A
were not preferred due to.the additional short-term adverse
impact these a.lternatives have on the adjacent wetlands during
the implementation of the remedy. The cost difference of .
$1,921,100 between Alternatives 4 and 4A was not proporti~nal to
the increase in the overall effectiveness achieved by Alternative
4A. Therefore, the selected remedy (Alternative 4) is cost
effective.
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o
.
10.4 utilization of Permanent Solutions and Alternative Treatment
Technoloaies (or Resource Recoverv Technoloaies) to the
Maximum Extent Practicable
The u.s. EPA has determined 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
LDL Site. Of those alternatives that are protective of human
health and the environment and that comply with ARARs, the u.S.
EPA has determined that this selected remedy provides the best
balance of tradeoffs in terms of long-term effectiveness and
permanence, reduction in toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability,
cost, and considering the statutory preference for treatment as a
principal element and considering state and community input.
The selected remedy consists of a perimeter cut-off wall in
conjunction with an Indiana Sanitary Landfill Cap, targeted drum
removal, and institutional controls. The sanitary landfill cap
would effectively reduce surface water infiltration, control gas
emissions and prevent direct contact with the waste materials.
The soil bentonite slurry wall around the perimeter of the
landfill would effectively contain on-site groundwater in the
upper aquifer. By cutting off surface leachate, discharges to the
adjacent wetlands and to Sloan Ditch, the sediment and the
surface water quality will be improved, benefitting the local
environment. The removal of any intact or partially intact drums
and non-containerized waste materials exhibiting RCRA hazardous
waste characteristics would serve to potentially reduce the mass
of toxic contaminants within the LDL site. With the removal of
drums containing toxic waste materials, the preferred remedy
provides a high degree of long-term effectiveness and permanence.
The preferred alternative is the best balance of desirable
characteristics among the alternatives with respect to the nine
balancing criteria. While all of the alternatives 3 through 6A
discussed in the Proposed Plan provide overall protection of
. human health and the environment, the preferred alternative was
selected based on the comparison of the following three items:
Drum removal vs. non-drum removal; soil bentonite slurry wall vs.
sub-surface drain; and an Indiana sanitary Landfill Cap vs. RCRA
Sub-title 'c' Cap.
The alternatives that included the reduction of toxicity,
mobility, or volume through treatment were preferred to those
that. did not provide for such reduction. Alternatives that
included the slurry walls were preferred to those that included
sUb-surface drain, due to the additional short-term risk to the
adjacent wetlands during installation of the sub-surface drain.
Alternatives that included RCRA'Sub-title 'c' Cap were not.
preferred to those that included the Indiana Sanitary Landfill
Cap due to their high cost. .
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The preferred alternative offers the best protection of human
health and the environment, complies with ARARs, eliminates long-
term risks, reduces toxicity, mobility and volume of contaminants
through treatment, is easily implemented and is cost effective.
. .
a
.
The State of Indiana is in partial concurrence with the selected
remedy. Although pUblic comments were received concerning the
selected remedy, those comments are fully addressed in the
responsiveness summary.
10.5 Preference for Treatment as a PrinciDa1 Element
The FS Report estimated approximately 3,300 drums in the hot spot
area. By removing an estimated 1,650 intact and partially intact
drums, together with an estimated 500 cubic yards non-
containerized waste materials from the hot-spot area, the Agency
expects that. the reduction in the total amount of drummed waste
at the site will be approximately 18%. The removal, off-site
treatment and/or disposal of drummed waste materials in the hot-
spot area would satisfy the statutory preference for treatment as
a principal element. Based on enforcement information, at least
18,000 drums were disposed of at the site. U.S. EPA believes
that there could be a significantly higher number of drums than
the estimated 3,300 in. the hot spot area. Thus, the removal of
drummed waste in this area could provide a higher percentage
reduction of toxicity than the present estimate.
Additionally, by recovering on-site groundwater through
extraction wells installed along the slurry wall, and, if
necessary, treating recovered water by filtration and an air
stripper, there will be a reduction over time in the volume of
contaminated on-site groundwater.
11.0 Documentation of Sianifican~ Chana..
U.S. EPA reviewed
during the public
it was determined
it was originally
necessary.
all written and verbal comments submitted .
comment period. Upon review of these comments,
that no significant changes to the remedy, as
identified in the Proposed' Plan, were
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GLOSSARY
()
.
Applica~le or Relevant and Appropriate requirements (ARARS) -
Federal, state and local environmental and public health laws
with which remedial actions must comply.
Aquifer - A body of rock that is sufficiently permeable to
conduct groundwater and to yield economically significant
quantities of water to wells and springs.
Aquitar4 - A confining bed that retards but does not prevent the
flow of water to or from an adjacent aquifer
Baseline Risk Assessment - A study conducted to determine the
associated short and long-term current and future risks posed to
public health and the environment if no remedial actions are
undertaken.
comprehensive Environmental Response, compensation, and Lia~ility
Act (CERCLA) - A Federal law passed in. 1980 and revised in 1986
.by the Superfund Amendments and Reauthorization Act. CERCLA
created a special tax that goes into a trust fund, commonly known
as "Superfund", to investigate and clean up abandoned or .
uncontrolled hazardous waste sites.,
Groundwater - The water beneath the earth's surface that flows
through soil pores and rock openings. Often utilized as a source
of drinking water.
Inorganic compounds - Chemical compounds that are composed of
mineral materials, including salts and minerals such as iron,
aluminum, mercury, and zinc.
Leachate - A liquid (usually water from rain or snow) that has
percolated through wastes and contains components of those
wastes.
MCL8 - These are Maximum contaminant Levels (see Primary Drinking
Water Standards).
Nationai Priority Li8t. (DL) - U.s. EPA's list. of top .priority
hazardous waste sites that are eligible for federal money under
Superfund.
National contingency Plan (NC') - The Federal regulation that
sets the framework for the Superfund proqram. The NCP identifies
the governmental. organizations involved in the remedial response,
outlines their roles and responsibilities, and discusses the.
interrelationships of these organizations.. In addition, the NCP
. provides quidelines.for planning and conducting response
activities.
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organic Compounds - Chemical compounds composed primarily of
carbon, including materials such as solvents, oils, and.
pesticides.
Permeability - The ease with which groundwater moves through
earth materials. Movement is controlled by the size and shape of
spaces between these materials.
~
)
Polychlorinated Biphenyls (PCBs) - A group of organic compounds
related by their basic chemical structure. They are highly
resistant to degradation, but have a tendency to be retained in
body tissue. They were widely used in electrical capacitors,
transformers, and other products in the u.s. before 1980..
Present Value Cost - An economic term used to describe. today's
cost for a Superfund cleanup and reflect the discounted value of
future costs. A present value cost estimate includes
construction and future. operation and maintenance costs. u.S.
EPA uses present value costs when calculating the cost of
alternatives for. long-term projects.
Primary Drinking Water Standards (MCLs) - Primary Drinking Water
Standards are the maximum contaminant levels (MCLs) set for
substances that can pose a threat to health wheA present in
drinking water at certain levels. Because these substances are
of concern for health (not just aesthetic) reasons, primary MCLs
are enforceable under the Safe Drinking Water Act.
Resource, Conservation and Recovery Act of 197& (RCRA) - The
federal law that establishes a.requlatory system to require the
safe and secure procedures to be used in treating and disposing
of hazardous waste.
Record of Decision (ROD) - A document signed by EPA's Regional
. Administrator, outlining the selected. remedy for a Superfund
site. The ROD includes. the Responsiveness Summary, which
addresses concerns presented to EPA during the public comment
period.
SMCLs - These are Secondary Maximum Contaminant Levels (see
Secondary Drinking Water Standards).
Secondary Drinking Water Standards (SMCLs) - These are Secondary
Maximum Contaminant Levels set under the Safe Drinking Water Act
to serve as qui de lines in setting levels based on aesthetic
considerations such as taste or odor. unlike primary MCLs,
. secondary MCLs are recommended levels only and are not federally
enforceable.
Sediment - Material that settles to the bottom of a stream,
creek, lake, or other body of water.
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"
q
surface Water - Streams, lakes, ponds,. rivers or any other body
of water above the ground.
Semi-Volatile organic Compounds (semi-Vocs)- Organic chemicals
that vaporize less readily than VOCs. These compounds include
many polynuclear aromatic hydrocarbons and pesticides.
slurry Wall - A civil engineering technique commonly used at
hazardous waste landfills to prevent movement of water soluble
and mobile contaminants by .restricting groundwater movement
around or beneath the contaminant source. The most common slurry
wall construction method is to excavate. a trench and backfill
with lqw permeability mixtures of soil or cement and bentonite
clay.
Superfund Amendments and Reauthorization.Act of 1986 (SARA) -
Amendments to the Superfund Law, CERCLA.
Volatile organic Compounds (VOCs) - organic chemicals, such as
methylene chloride and benzene, that vaporize easily. Some VOCs
found at the site include carbon tetrachloride, vinyl chloride,
benzene, and chloroform.
Wetlands - Areas that are inundated by surfaceQr groundwater
with sufficient frequency to support vegetative or aquatic life.
that depends upon saturated or seasonally saturated soil
conditions for growth and reproduction. 40 CFR Pt.6, App.A,
Section 4(j).
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