PB94-964132
EP A/ROD/R05-94/249
September 1994
EP A Superfund
Record of Decision:
Waste Inc. Landfill Site,
Michigan City, IN,
8/18/1994
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Declaration for the Record of Decision
Waste, Inc. Landfill
site Name' Location
Waste, Inc. Landfill
Michigan City, Indiana
statement of Basis and puroose
This decision document presents the selected remedial action for
the Waste, Inc. Landfill site (the site) in Michigan City,
Indiana. This remedial action was selected in accordance with
CERCLA, as amended by SARA, and, to the extent practicable, the
National contingency Plan. The selection of this remedy is based
on the Administrative Record for the site.
The Stqte of Indiana concurs with the selected remedy.
Assessment of the site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to human health, welfare, or the environment.
Descriotion of the Selected Remedv
This action is the final action planned for the Site. It
specifically outlines an action to address on-site soil and
groundwater contamination, which have been determined by the
Remedial Investigation to pose unacceptable risks to human health
and the environment.
The major components of the selected remedy include:
- Installation of a Subtitle D Cap, meeting the requirements of
329 lAC 2-14-19(3) (b) and 329 lAC 19(3) (a)-(c).
- Leachate and shallow groundwater collection via a leachate
collection trench, installed along the southern site boundary.
- Installation and operation of groundwater extraction wells to
contain deep groundwater at the site boundary.
- Discharge of collected groundwater and leachate to the
Sanitary District of Michigan city via direct discharge.
- Collection and disposal of landfill gas.
- Rerouting or abandoning the on-site sewer line.
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- Removal of the on-site underground fuel storage tank.
- Posting of fish advisory signs along Trail Creek.
- Proper abandonment of the on-site groundwater well
Declaration
The selected remedy is protective of human health and the
environment, complies with Federal and state applicable or
relevant and appropriate requirements for this operable unit
action, is cost effective, and consistent with achieving a
permanent remedy. This final action fully addresses the
statutory mandate for permanence and treatment to the maximum
extent practicable. This action also satisfies the statutory
preference for remedies that employ treatment that reduces the
toxicity, mobility, or volume as a principal element. Because
this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted to ensure
that the remedy continues to prOVi~e a quate protection of human
health and the environment within fiv years af er commencement
of the :::?it ~Ci:/9;; ~ I. '
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Date Valdas V. Ad us
Regional Ad inistrator
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a:,; LA l,e r
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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We make Indiana a cleaner, healthier place to live
Evan Bayh
Governor
Kathy Prosser
Commissioner
100 North Senate A venue
P.O. 801[ 6015
Indianapolis. Indiana 46206-6015
Telephone 317 -232-8603
Environmental Helpline 1-800-451-6027
August 11, 1994
Mr. Valdas Adamkus
Regional Administrator
u.s. Environmental Protection
77 West Jackson Blvd.
chicago, IL 60604
Agency
Dear Mr. Adamkus:
Re:
Record of Decision
Final site Remedy
Waste, Inc. Landfill site
Michigan City, Indiana
The Indiana Department of Environmental Management has
reviewed the u.s. Environmental Protection Agency's Record of
Decision for the Waste, Inc. Landfill Superfund site. IDEM fully
concurs with the major components of the selected remedy for this
site, which includes:
Site preparation
Institutional control (fencing, deed restrictions,
groundwater monitoring)
Two separate collection extraction systems -
groundwater and leachate collection trench and
groundwater extraction wells to capture and prevent any
potential future off-site migration of contaminants
Collection trench keyed into the olive grey clay layer
Extraction wells to contain contaminated groundwater at
the site boundary
Groundwater collected to be pumped to the Michigan City
Wastewater Treatment facility. Facilities for on-site
storage of collected water to be used if effluent does
not meet the requirements of the POTW, or if
overflow/bypass situation exists at the POTW
subtitle 0 cap
Gas collection
An Equal Opportunity Employer
Printed on Recycled Paper
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Mr. Valdas Adamkus
Page 2
Information to be gathered on the storm sewer to
determine if it can be rerouted or grouted and sealed
Removal of an underground tank
Fish consumption advisory signs.
We also agree that this action attains Federal and state
requirements that are applicable, or relevant and appropriate to
this final site remedy. We will work with EPA to determine the
levels which will be achieved at the site boundary for
groundwater. Because this remedy will result in hazardous
substances remaining on the site above health-based levels, a
review will be conducted within five years after commencement of
the remedial action to ensure the remedy continues to provide
adequate protection of human health and the environment.
IDEM staff have been working closely with Region V staff in
the selection of an appropriate final remedy for the Waste Inc.,
site and are satisfied that the selected alternative adequately
addresses the risk to human health and the environment posed by
the site.
Please be assured that IDEM is committed to accomplish
cleanup of all Indiana sites on the NPL and intends to fulfill
all obligations required by law to achieve that goal.
Sincerely,
~~
Commissioner
PEC:mg
cc:
Pat Carrasquero, IDEM
Dion Novak, U.S. EPA, Region V
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Decision Summary
Waste, Inc. Landfill
Michigan City, Indiana
site Name. Location and DescriDtion
Waste, Inc. Landfill
Michigan City, Indiana
The Waste, Inc. Landfill site (The Site) is located in LaPorte
County, Indiana, at 1701 East U.S. Highway 12 in Michigan city,
Indiana. The site, which is comprised of the Waste, Inc. and
Lin-See, Ltd. properties, is situated in the northeast quadrant
of section 28, Township 38 North, Range 4 West, LaPorte County,
Indiana (See Figure 1). It is bounded by U.S. Highway 12 to the
northwest, Michiana Auto Builders and Su11air Corporation to the
north and east, Trail Creek to the east and south, and Lake
Aluminum corporation (property owned by Northern Indiana Steel
Supply Company, Inc. - NISSCO) to the west. The site consists of
approximately 32 acres, and the surface elevation ranges from
slightly above 580 feet above mean sea level (MSL) along Trail
Creek to 625 feet above MSL at the top of the landfill mound
(See Figure 2). The most prominent feature of the site is the
landfill mound, which is approximately 35 feet high and
encompasses most of the site. Other structures on the site
include: decontamination and storage shed, and a fuel pump and
associated underground storage tank. Empty steel drums are also
scattered across the site. A gravel driveway that formerly
provided access to the north-central portion of the site from
U.S. Highway 12 is currently blocked by a locked steel gate that
is approximately 8 feet in height. The gate is attached to an 8-
foot metal fence that extends across approximately 155 feet of
northwestern boundary of the Waste, Inc. property.
At the eastern end of the fence, a northwest-southeast trending
snow fence extends to an 8 foot high chain link fence that runs
along the property line between the site and the leased Lin-See,
Ltd. property to the north. Two fences are located in the
northwest portion of the site, including: (1) an 8 foot high
sheet metal fence that is approximately 100 feet long and trends
northeast-southwest, and (2) an 8 foot high chain link fence and
gate that is approximately 30 feet long and trends north-south.
A 10 foot high corrugated metal fence separates the site from the
Lake Aluminum corporation property. The entire northern border
of the Lin-See, Ltd. property is separated from the leased Lin-
See, Ltd. to the north by an 8 foot high chain link fence with a
gate. The southern and eastern boundaries of the site along
Trail Creek are not fenced, and a large opening exists in the
fencing along the northern boundary of the site. The locations
of these various fences are shown on Figure 3.
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site Historv and Enforcement Activities
The Waste, Inc. site consisted of agricultural land with some
lowlands in 1939 prior to its development as a landfill. A small
disposal mound was located in the north-central portion of the
site in 1954, and an abandoned meander appeared to contain
debris. The metal salvage and reclamation facility on the west
side of the site covered most of the wetland area prominent in
1939. A long mound that may consist of debris, fill, and scrap
metal wastes was located along the site's western perimeter. As
time passed, these mounds expanded and additional mounding
occurred in the southeast and southwest portions of the site. In
1961 and 1965, portions of the site were cleared to provide
parking areas. In 1980, a fence was constructed along the site's
northeast perimeter, and a wall was built near the northwest
corner that limited traffic access from the highway.
From 1965 to 1972, the Waste, Inc. site was operated as an
unpermitted landfill by Dis-Pos-all Services Division, a division
of NISSCO. In 1972, NISSCO sold its disposal operations to
Waste, Inc., which continued operating the landfill at the site
until August 5, 1982.
In November, 1970, Dis-Pos-All Services submitted a proposal to
the Indiana stream Pollution Control Board (Board) for the
operation of their existing landfill. Under this proposal, the
site would be limited to accepting only wood, paper and cardboard
and would use foundry sand as cover material. The Board issued a
non-objection letter to this proposal in July, 1971. However,
several subsequent inspections by the Indiana state Board of
Health determined that the site was accepting unapproved
materials for disposal and was not properly covering combustible
materials. Therefore, in a letter dated August 28, 1974, the
Board's technical secretary ordered the site closed and covered
with clay.
In May, 1975, Waste, Inc. submitted an application to the Board
for construction and operation permits. This application was
denied; however, no hearing was held on the Waste, Inc. appeal of
this denial, and the site continued to operate. In May, 1981, an
Agreed Order was executed between Waste, Inc. and the Board,
which set conditions for the continued operation of the landfill.
In August, 1982, a Consent Order was signed, effectively closing
the site except for allowing the acceptance of foundry sand for
disposal and permitting the owner/operator (Waste, Inc.) to begin
covering the site with clay. In 1983, in response to the state
of Indiana enforcement actions, a Court Order demanded proper
closure of the site.
In January, 1985, a hazard ranking system evaluation of the site
by the u.S. EPA resulted in an overall hazard ranking score of
50.63.
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A Consent Order was signed between the participating Waste, Inc.
site Respondents (i.e. PRPs) and U.s. EPA Region 5 in March,
1987. This Consent Order contained requirements for the PRPs to
perform a Remedial Investigation/Feasibility Study at the site.
Hiahliahts of communi tv Partici~ation
Public participation requirements under CERCLA Sections 113
(k) (2) (B) and 117 were satisfied during the RI/FS process. U.S.
EPA has been primarily responsible for conducting the community
relations program for this Site, with the assistance of the
Indiana Department of Environmental Management (IDEM). The
following public participation activities, to comply with CERCLA,
were conducted during the RIfFS.
A Community Relations Plan was developed in November 1987 to
assess the community's informational needs related to the
Waste, Inc. site and to outline community relations
activities to meet these needs. Residents and community
officials were interviewed and their concerns were
incorporated into this plan.
Public information repositories were established at the
Michigan City PUblic Library, the Bethany Bible Baptist
Church, and the Michigan city Branch Office of the LaPorte
County Health Department.
A mailing list of interested citizens, organizations, news
media, and elected officials in local, county, State and
Federal government was developed. Fact Sheets and other
information regarding site activities were mailed
periodically to all persons or entities on this mailing
list. This mailing list was also updated from time to time
as persons approached EPA for information about the site.
A Fact Sheet was mailed to the public
announced a public meeting to discuss
Investigation and answer site related
public.
in November 1987, that
the upcoming Remedial
questions from the
A public meeting on November 18, 1987, at the city Hall
Chambers announced the initiation of the Remedial
Investigation and provided details about its conduct.
A Fact Sheet was mailed to the public in early 1988, that
announced the results of Phase 1 sampling of Trail Creek,
which was done in accordance with the EPA approved Phase 1
RIfFS workplan. This fact sheet also announced the
availability of two technical memoranda, approved by the
EPA, that described in detail the procedures and results of
the Trail Creek samples.
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4
A Fact Sheet was mailed to the public in July 1988, that
announced a revision in the reporting of results of Phase 1
sampling of Trail Creek.
A Fact Sheet was mailed to the public in June 1989, that
announced EPA approval of the RIfFS workplan for the site
and summarized the proposed sampling activities.
An Availability Session was held on June 29, 1989, at the
Michigan city Public Library which allowed EPA to answer
questions and concerns of residents regarding the planned
RIfFS and other site related issues.
A Fact Sheet was mailed to the public in December 1989,
updating the public on the status of the RIfFS at the site
and reporting on the tasks that were completed at that time.
T~o Availability Sessions were held on February 28, 1990, at
the Michigan City Public Library, to answer questions and
concerns of residents regarding the progress of the RIfFS at
the site.
An Availability Session was held on April 19, 1990,
city Hall Council Chambers, to answer questions and
of residents regarding the progress of the RIfFS at
site.
at the
concerns
the
A Fact Sheet was mailed to the public in December 1990, that
summarized the results of Technical Memorandum #4.
An Availability Session was held on December 13, 1990, at
the Michigan. City Library to answer questions regarding
Technical Memorandum #4.
An Availability Session was held on April 1, 1992 to answer
questions regarding Technical Memorandum #5.
A Fact Sheet was mailed to the public in January 1994, that
summarized EPA's recommended remedial alternative in a
proposed plan for the site. The EPA approved Feasibility
Study was also released at that time. This fact sheet also
announced a public comment period for the proposed remedial
action and was accompanied by newspaper advertisements in
the Michigan City News Dispatch.
A public meeting was held on February 9, 1994, at the city
Hall Council Chambers to present EPA's proposed plan for the
Waste, Inc. site and to receive formal public comment.
Paid newspaper advertisements announced the RI public
meeting, the availability sessions, and the FS and proposed
plan public meetings.
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5
Periodic news releases announced results of studies at the
site.
A public comment period of thirty days was originally
planned, running from January 24, 1994, to February 22,
1994. Based on several written requests during the comment
period, the comment period was extended twice, until April
22, 1994, for a total comment period of 90 days. The
extensions were announced by in newspaper advertisements in
the Michigan City News Dispatch.
A Responsiveness Summary addressing comments and questions
received during the public comment period on the RI/FS and the
proposed plan is included with this Record of Decision as
Appendix A.
This Record of Decision presents the selected remedial action for
the Waste, Inc. site in Michigan City, Indiana, chosen in
accordance with CERCLA, as amended by SARA, and the National
Contingency Plan. The decision for this Record of Decision at
the site is based on the Administrative Record.
SCODe and Role of the Selected Remedv
As with many Superfund sites, the problems at the site are
complex. A RI/FS was p~rformed by several Potentially
Responsible Parties (PRPs) pursuant to a March 1987
Administrative Order on Consent. Activities performed under this
Order included determining the nature and extent of contamination
at the site and evaluating the feasibility of various remedial
alternatives to clean up the site.
This Record of Decision (ROD) addresses contaminated soil and
waste materials and contaminated groundwater and leachate on the
site. These areas were determined to pose risks to human health
and the environment due to dermal contact or incidental ingestion
of site surface soils, ingestion of groundwater, and ingestion of
fish from Trail Creek. Groundwater was not found to be
contaminated immediately downgradient of the site; however, the
potential exists for migration of contaminated groundwater from
the site. This is the first and only planned response action at
the site.
Site Characteristics
The RI/FS was conducted to identify the types, quantities and
locations of contaminants at the Site and to develop alternatives
that best address these contamination problems. The nature and
extent of actual or potential contamination related to the site
was determined by a series of field investigations, including:
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6
- development of detailed information regarding
historical site operations
- on-site surface soil sampling
- installation and sampling of ground water
monitoring wells, both onsite and offsite
- off-site surface-water sampling
- identification of existing ground-water
wells in the site vicinity
- installation and sampling of soil borings
- a storm water and leachate study
- a water-level monitoring program, both onsite and
offsite, including the installation of piezometers
- hydraulic conductivity testing
- preparation of a site-wide human health and
ecological risk assessment
- contaminant fate and transport modeling and
analysis
site Geology:
The Waste, Inc. site is underlain by unconsolidated sediments of
the Calumet Lacustrine Plain. These deposits consist of silty
glacial till overlain by a combination of beach and dune sands,
lacustrine silts and clays, and paludal deposits of muck and
peat. The following geologic facies were defined at the site
during RI activities: fill, foundry sand and metal debris,
foundry sand, clay cap, olive-grey sand, brown sand, olive-grey
clay, interbedded sand and clay, and clay till.
The interbedded sand and clay facies overlies the clay till
facies in all portions of the site except along the eastern
boundary. This facies is overlain by the olive-grey facies
across the southern two-thirds of the site and by the olive-grey
sand facies in the northern one-third of the site.
site Hydrogeology:
The principal sources of groundwater in the site area
unconsolidated deposits of Quaternary glacial drift.
deposits can be subdivided into four units, including
and gravel aquifers and two confining glacial tills.
site, only the two shallowest units (Units 1 & 2) are
are the
These
two sand
At the
present.
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Unit 1 consists primarily of dune sand, sandy lacustrine
material, and sandy beach and shoreline deposits. Unit 1 is an
unconfined aquifer capable of yielding more than 500 gallons per
minute where its saturated thickness is greater than 50 feet. At
the site, the top of the surficial aquifer ranges from 0 to 17
feet below the ground surface. Stratigraphic and water level
data indicate that all of the geologic facies that comprise the
surficial aquifer, with one exception, are hydraulically
interconnected, both vertically and laterally. The one exception
occurs in the southern two-thirds of the site where the olive-
grey clay facies divides the aquifer into two discrete water-
bearing units. .
Unit 2 is a calcareous silty till that acts as a basal aquiclude
for the surficial aquifer and is approximately 100 feet thick in
the vicinity of the site.
Soil Contamination:
Surface and subsurface soil sampling was conducted in all areas
of the site except the main landfill area to determine the nature
and extent of potential sources of contamination. Because of the
heterogeneous nature of the landfill contents, the nature of
contamination within the landfill was assessed by characterizing
its impacts on the surrounding soil. An initial soil screening
program was conducted to identify suspected areas of near surface
~oil contamination and to direct the analytical sampling effort
toward areas with the highest probability of being contaminated
or clean, depending on the purpose of the sample.
Soil samples collected at the site were found to be contaminated
with volatile organics up to levels of approximately 890,000
parts per billion (ppb), semi-volatile organics up to levels of
approximately 6200 ppb, polychlorinated biphenols (PCBs) up to
levels of 4400 ppb, and inorganics up to levels of 191,000 ppb.
Ground Water Contamination:
Groundwater samples collected at the site
contaminated with volatile organics up to
volatile organics up to levels of 53 ppb,
levels of 1900 ppb.
were found to be
levels of 47 ppb, semi-
and inorganics up to
Summary of Site Risks
This Record of Decision is written for a final action. The RI
report includes a risk assessment, prepared by Environ using the
Risk Assessment Guidance for Superfund and approved by EPA as a
portion of the RI report, that calculated the actual or potential
risks to human health and the environment that may result from
exposure to site contamination.
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8
The risk assessment determined that the majority of risks
associated with exposure to contamination at the site were
attributed to carcinogenic PAHs, PCBs, cadmium, arsenic and
antimony.
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.
Exoosure Assessment
The exposure assessment conducted as a part of the RI concluded
that several media are impacted by the contaminants at the site,
and that there are several potential exposure routes for
contamination. These routes of exposure were identified for both
current and future scenarios (as is commonly done in EPA risk
assessments) so that all potential pathways can be evaluated.
Due to the proximity of the site to the surrounding neighborhood,
and its size, the following potential receptors were identified
in the risk assessment, and risks were computed for their
exposure.
Under the current land-use scenario, on-site trespassers could
potentially be exposed through dermal contact or incidental
ingestion of site surface soils. Recreational adult fishermen
could potentially be exposed through ingestion of fish caught
from Trail Creek.
Under the future-use scenario, on-site residents could
potentially be exposed through ingestion of groundwater, and
dermal contact and incidental ingestion of site surface soils.
Recreational adult fishermen could potentially be exposed through
ingestion of fish caught in Trail Creek.
Toxicitv Assessment
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day) (-l)
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied {e.g. to account for the use of animal data to predict
effects on humans.
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9
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mgjkg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g.,
the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g., to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The following hazardous substances were found to be of principal
concern at the site.
Polynuclear Aromatic Hydrocarbons Animal studies indicate that
PAHs may be potentially harmful to the gastrointestinal tract,
liver and kidneys and may suppress the immune system after both
short and long term exposure. Birth defects and decreased body
weight have been reported in laboratory animals, although
reproductive toxicity associated with PAH exposure has not been
demonstrated in humans. Lung and skin cancer in humans have been
associated with chronic exposure by inhalation and dermal
contact, respectively, to mixtures of compounds including
carcinogenic PARs.
Arsenic Short term exposure to arsenic or arsenic compounds may
cause effects in the gastrointestinal tract, heart, vascular
system, blood, nervous system, eye, nose and skin. Arsenic
compounds are rep~rted to act as skin allergens in humans.
Exposure to arsenic has also been reported to cause depression of
the bone marrow and disturbances in the blood cell and tissue
forming system and has been associated with kidney and liver
disorders. Arsenic has been found to be a lung carcinogen when
inhaled and to cause skin cancer when ingested. Arsenic and its
compounds may have potential reproductive and developmental
effects in humans. Teratogenic effects have been demonstrated in
animal species exposed to arsenic via oral administration or
intraperitoneal injection. Damage to genetic material has been
reported in humans.
Polychlorinated Biphenols (PCBs) The principal toxicological
effects observed in humans exposed to PCB mixtures include
effects of the skin and the liver. Results from experimental
studies in animals indicate that PCBs may also cause effects on
the thyroid gland and immune system. Liver tumors have been
observed in animals exposed to high concentrations of PCBs.
Epidemiological studies of PCB exposed populations have not
demonstrated a causal relationship between PCB exposure and any
form of human cancer. Reproductive toxicity has been reported in
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10
animals exposed to PCBs prior to and during gestation. Adverse
developmental effects have been reported in the newborn of women
exposed during pregnancy to PCBs and other chemicals in an
occupational setting or from ingestion of contaminated fish.
Manganese Long term exposure to manganese by inhalation may
cause effects in the lungs, including pneumonia and bronchitis.
Inhalation and oral exposure to manganese for long periods of
time may result in "manganism," a potentially irreversible
disease characterized by growth retardation, nonspecific anemia,
"metal fume fever," and psychological and neurological disorders.
No reports of carcinogenic effects, reproductive and
developmental toxicity, and muta~enicity of manganese were found
in the available literature.
Chromium Direct contact with chromium compounds may be
irritating to the skin, with chromium VI being much more
corrosive than chromium III. Occupational exposure to chromium
VI has been reported to cause adverse effects in the respiratory
tract and lungs. Both chromium III and VI compounds are reported
to cause kidney toxicity in animals; however, some reports
indicate that they may also cause effects in the liver and
nervous system. Chromium compounds have been found to cause
developmental effects in hamsters and mice and testicular effects
in rabbits when administered by injection. Epidemiological
studies indicate that occupational exposure to chromium VI may
cause lung cancer. Reports of workers exposed to chromates
provide evidence of damage to genetic material.
Cadmium Short term oral or inhalation exposures to high levels
of cadmium compounds may produce gastrointestinal, central
nervous system, lung, liver, kidney, and immune system effects.
Longer term exposure to lower cadmium levels results in effects
similar to those observed following acute exposures. In
addition, effects of the bones and the blood and blood forming
system have been reported in humans, while nervous system and
heart effects have been observed in animals orally exposed to
cadmium for long periods of time. There is limited evidence that
cadmium causes reproductive toxicity in male workers. Cadmium
has been found to be a reproductive and developmental toxicant
and a teratogen in several animal species exposed by various
routes of administration. Lung cancer has been associated with
inhalation of cadmium in cadmium exposed workers. There is
insufficient evidence that cadmium is a prostrate carcinogen in
humans; however, testicular tumors have been found in animals.
Results of lab assays for mutagenic potential indicate a
potential for cadmium to cause genetic damage.
Benzene is classified as a known human carcinogen (Class
has been associated with hematologic effects on humans as
anemia (decreased red blood cells), leukopenia (decreased
blood cells), and thrombocytopenia (decreased platelets).
A) and
well as
white
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11
Chronic exposure has been shown to cause pancytopenia (decrease
in all circulating cells) and aplastic anemia (failure to
manufacture blood cells). Exposure by inhalation has been shown
to cause leukemia. Benzene has been shown to be a growth
inhibitor in utero; however, it has not been shown to be
teratogenic (causing birth defects). Animal studies have shown
preliminary evidence .of carcinogenicity; a link to leukemia via
inhalation has also been suggested. Benzene has been shown to be
nonmutagenic (not causing mutations); benzene oxide, the presumed
initial metabolite of benzene, is mutagenic (causing mutations).
Mercury Symptoms associated with ingestion of ionizable salts
include effects in the esophageal and gastrointestinal tracts,
kidneys, and liver. Elemental mercury orally administered in
experimental animals has produced few effects other than
diarrhea. In contrast, short term inhalation of mercury vapors
may effect the lungs and the central nervous system. Chronic
exposure to mercury vapor affects primarily the central nervous
system and the kidneys. Inorganic mercury is not known to be a
human carcinogen. There is no conclusive evidence that inorganic
mercury causes reproductive or developmental toxicity.
Antimony Short term exposure to antimony or inorganic compounds
of antimony may produce eye and skin irritation, vomiting, heart
problems, and lung damage. Exposure to inorganic antimony
compounds has also been reported to cause effects of the
intestinal tract such as abdominal pain, diarrhea, and stomach
ulcers in workers. Effects in the liver and kidneys and a
decrease in red blood cells have been reported in animals. There
is no conclusive evidence linking antimony exposure to human
cancer; however, lung tumors have been reported in animals
exposed by inhalation to inorganic compounds of antimony.
Antimony may have potential reproductive and developmental
effects in humans.
Risk Assessment
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1 x 10(-6) of 1E-6). An excess lifetime cancer risk of 1
x 10(-6) indicates that, as a plausible upper bound, an
individual has a one in one million chance of developing cancer
as a result of site-related exposure to a carcinogen over a 70-
year lifetime under the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which
from
a given
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Lifetime Cancer Risks Associated with Current Potential
Exposures at and near the Waste. Inc. Site
Estimated Lifetime Cancer
Risk to an Individual
from a Reasonable
Maximum Exposure
Current Use
Exposure Scenario
Trespasser
(Sum of intakes by
a 6- to 14-year oid
child and a 15- to
36-year old adult)
Recreational Swimmer in
Trail Creek
(Sum of intakes by
a 6- to 14-year old
child and a 15- to
36-year old adult)
Recreational
Fisherman, Adult
Note:
Exposure Medium
and Route
Leachate Seeps
Dermal contact
Incidental ingestion
Subtotal
Surface Soil
Dennal contaCt
Incidental ingestion
Subtotal
Grand Total (Trespasser)
Surface Water
Dermal contact
Incidental ingestion
Subtotal
Fish
Ingestion
2 X 10-7
4 x 10-&
2 x 10-7
2 x lO-s
3 x 10.0
:: x 10-5
2 x 10-5
6 X 10-3
1 X 10-7
2 X 10-7
5x 1~
Cancer risks are not summed across all scenarios. because the scenarios are assumed to
principally involve different populations. Such a sum would be practically
indistinguishable from the risk due to fish ingestion. however.
-------
Lifetime Cancer Risks Associated with Hypothetical Future
Exposures at and Near the Waste. Inc. Site
Estimated Lifetime Cancer
IUsk to an Individual
from a Reasonable
Maximum Exposure
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Future use
Exposure Scenario
On-site Resident
(Sum of intakes by
a 1 to 6-year old
child and a 7 to
30-year old adult)
Recreational Swimmer in
Trail Creek
(Sum of intakes by
a 1 to 6-year old
child and a 7 (0
3O-year old adult)
Recreational
Fisherman. Adult
Notes:
whip 2
Exposure Medium
and Route
Leachate Seeps
Dermal contact
Incidental ingestion
Subtotal
Surface Soil
Dennal contact
Incidentai ingestion
Subtotal
Ground Water
Ingestion'"
Grand Total (Resident)
Surface Water
Dermal contaCt
Incidental ingestion
Subtotal
2 x 10~
4 X 10-7
2 x IO~
2 x 1
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~oncancer Risks Associated with Hypothetical Future
Exposures at and Near the Waste. Inc. Site
Estimated Noncancer H32aI'd
Index from a Reasonable
Maximum Exposure
Future Use Exposure Medium 6- to 14-year 15- to 36-year I
Exposure Scenario and Route old Child old Adult
Resident Leachate Seeps
Dermal contact 0.09 0.07
Incidental ingestion 0.006 0.001
Subtotal 0.09 0.07
Surface Soil
, Dermal contact 0.8 0.4
Incidental ingestion 1 2.7 0.3
Subtotal 3.5 0.7
Ground Water
Ingestion ND1II 12
Grand Total (Resident) ND 13
Recreational Swimmer Surface Water
in Trail Creek Dermal contact 0.0015 0.0003
Incidental ingestion 0.0008 0.0001
Subtotal 0.0023 0.0004
Recreational Fisherman Fish
Ingestion NDIII 6.6
Notes:
The risk index values are not summed across all exposure scenarios. because different
populations are assumed to be involved.
ND = Not determined.
* The risks due to ground water and fish ingestion are based upon intakes by adults
only, consistent with supplemental EPA guidance (USEPA 1991e), because their
exposures should be comparable to or greater than those to children.
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Noncancer Risks Associated with Current Potential
Exposures at and Near the Waste. Inc. Site
Current Use
Exposure Scenario
Trespasser
Recreational Swimmer
in Trail Creek
Recreational Fisherman
Notes:
Estimated N oncancer Hazard
Index from a Reasonable
Maximum Exposure
Exposure Medium 6- to 14-year 15- to 36-year
and Route old Child old Adult
-
Leachate Seeps
Dermal contact 0.009 0.005
Incidental ingestion 0.0004 0.0002
Subtotal 0.009 0.005
Surface Soil
Dermal contact 0.08 0.06
Incidental ingestion 0.04 0.02
Subtotal 0.1 0.08
Grand Total 0.1 0.09
Surface Water
Dermal contact 0.0015 0.0003
Incidental ingestion 0.0008 0.0001
Subtotal 0.(m3 0.0004
Fish
Ingestion NDIII 6.6
The risk index values are not summed across all exposure scenarios. because different
populations are assumed to be involved. Such a sum would be practically
indistinguishable from the HI-value for fish ingestion. however.
ND
=
Not determined.
* The risks due to fish ingestion are based upon intakes by adults only, consistent with
supplemental EPA guidance (USEPA 1991e), because the exposures to adults are
expected to be comparable to or greater than those to children.
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12
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
carcinogenic risks described in the risk assessment for exposure
to contaminated soil. at the site were computed for several
potential exposure scenarios. These include on-site trespasser
(current risk - 2 x 10(-5) (See Table 1» and on-site resident
(future risk - 3 x 10(-4) (See Table 2)). The chemical classes
causing the majority of the estimated cancer risks were
carcinogenic PARs, PCBs and arsenic.
The non-carcinogenic risks associated with exposure to
contaminated soil at the site were computed for the same exposure
scenarios as were used for the carcinogenic risks. Generally,
total Hazard Indices (HI) are used to calculate non carcinogenic
risks and must be below a value of 1.0; otherwise u.S. EPA policy
requires remedial action. Hazard Indices exceeded the 1.0
trigger for the on-site resident (future non-carcinogenic risk -
HI = 3.5 for 6 to 14 year old child (See Table 3». The chemical
classes causing the majority of the estimated non-cancer risks
were PCBs, antimony, arsenic and cadmium.
The carcinogenic risks described in the risk assessment for
ingestion of contaminated groundwater were computed for several
potential exposure scenarios. These include on-site resident
(future risk - 7 x 10(-4) (See Table 2). The chemical class
causing the majority of the estimated cancer risks were
carcinogenic PARs.
The non-carcinogenic risks associated with ingestion of
contaminated groundwater at the site were computed for the same
exposure scenarios as were used for the carcinogenic risks.
Hazard Indices exceeded the 1.0 trigger for the on-site resident
(future non-carcinogenic risks - HI = 12 for a 15 to 36 year old
adult (See Table 3». The chemical class causing the majority of
the estimated non-cancer risks was antimony.
The carcinogenic risks described in the risk assessment for
ingestion of fish caught from Trail Creek were computed for
several potential exposure scenarios. These calculations did not
include results from actual fish samples from Trail Creek. In
such instances, it is common to estimate the potential
concentrations of the chemicals of concern in the fish using an
equilibrium model, the details of which are contained in the
site-wide risk assessment. These include recreational fisherman
(current and future risk - 5 x 10(-4) (See Tables 1 & 2».
The non-carcinogenic risks described in the risk assessment for
ingestion of fish caught from Trail Creek were computed for
several potential exposure scenarios. These include recreational
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13
fisherman (current and future non-carcinogenic risks - HI = 6.6
for 15 to 36 year old adult (See Tables 3 & 4».
DescriDtion of Alternatives
During the Feasibility Study (FS), a list of alternatives was
developed that could .be used to address the threats and/or
potential threats identified for the soil, surface water,
sediment, and groundwater at the site. The list of alternatives
was screened based on criteria for effectiveness (i.e. protection
of human health and the environment, reliability), .
implementability (i.e. technical feasibility, compliance with
applicable Federal and State regulations), and relative costs
(i.e. capital, operation and maintenance) .
Following this initial screening, the list of alternatives was
evaluated and only alternatives that met the nine criteria,
listed below in the comparative analysis section, were submitted
for detailed analysis.
Alternative 1:
No Action
Under this alternative, no remediation would occur and the site
would remain in its present condition. All contamination would
remain in the ground water, with continued off-site movement at
unacceptable levels. Although this alternative does not address
the ground-water contamination problem, its inclusion in the
detailed alternatives analysis is required by CERCLA as a
baseline for comparison to the other alternatives developed.
Present Worth Cost:
Time to Implement:
$ 0
none
Alternative 2:
Veaetated Soil CaD
This alternative consists of site preparation, institutional
controls, groundwater monitoring, groundwater and leachate
collection/treatment/disposal, surface water
diversion/collection, and the placement of a vegetated soil cover
consisting of the placement of 6 inches of topsoil covered by a
vegetative layer, such as grass.
Present Worth Cost:
Time to Implement:
$ 9,700,000
6 months
Alternative 3: subtitle D CaD
This alternative consists of site preparation, institutional
controls, groundwater monitoring, groundwater and leachate
cOllection/treatment/disposal, surface water
diversion/collection, and the placement of a Subtitle D cap
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14
consisting of 2 to 4 feet of compacted clay and 12 inches of
topsoil. The layer thicknesses proposed for the alternative will
meet the technical requirements for capping solid waste landfills
contained in 329 IAC 2-14-19(3) (b).
Present Worth Cost:
Time to Implement:
$ 15,700,000
9 months
Alternative 4A:
Shallow Slurry Wall and Veaetated Soil Ca~
This alternative consists of site preparation, institutional
controls, groundwater monitoring, groundwater and leachate
collection/treatment/disposal, surface water
diversion/collection, placement of a vegetated soil cover
consisting of the placement of 6 inches of topsoil covered by a
vegetative layer, such as grass, and the installation of a
shallow slurry wall (approximately 15-25 feet deep) from the end
of the collection trench at the northeastern corner of the site
to other end of the collection trench at the southwestern corner
of the site, keyed into the olive-grey clay facies located
beneath a majority of the site.
Present Worth Cost:
Time to Implement:
$ 11,100,000
9 months
Alternative 4B:
Dee~ Slurry Wall and Veaetated Soil Ca~
This alternative consists of site preparation, institutional
controls, groundwater monitoring, groundwater and leachate
cOllection/treatment/disposal, surface water
diversion/collection, placement of a vegetated soil cover
consisting of the placement of 6 inches of topsoil covered by a
vegetative layer, such as grass, and the installation of a deep
slurry wall (approximately 40-50 feet deep) from the end of the
collection trench at the northeastern corner of the site to other
end of the collection trench at the southwestern corner of the
site, keyed into the clay till beneath the site.
Present Worth Cost:
Time to Implement:
$ 11,900,000
9 months
Alternative SA:
Shallow Slurry Wall and Subtitle D Ca~
This alternative consists of site preparation, institutional
controls, groundwater monitoring, groundwater and leachate
collection/treatment/disposal, surface water
diversion/collection, placement of a subtitle D cap consisting of
2 to 4 feet of compacted clay and 12 inches of topsoil. The
layer thicknesses proposed for the Subtitle D cap meet the
requirements of 329 IAC 2-14-19(3) (b). The installation of a
slurry wall encircling the site is also included in this
alternative.
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15
Present Worth Cost:
Time to Implement:
$ 17,100,000
12 months
Alternative SB:
Dee~ Slurry Wall and Subtitle D Ca~
This alternative consists of site preparation, institutional
controls, groundwater monitoring, groundwater and leachate
cOllection/treatment/disposal, surface water
diversion/collection, placement of a Subtitle D cap consisting of
2 to 4 feet of compacted clay and 12 inches of topsoil. The
layer thicknesses proposed for the Subtitle D cap meet the
requirements of 329 lAC 2-14-19(3) (b). The installation of a
deep slurry wall, connected to the clay till layer underlying the
site, encircling the site is also included in this alternative.
Present Worth Cost:
Time to Implement:
$ 17,900,000
12 months
Summary of the Com~arative Analysis of Alternatives
The nine criteria used by U.S. EPA to evaluate remedial
alternatives, as set forth in the NCP, 40 CFR Part 300.430,
include: overall protection of human health and the environment;
compliance with applicable or relevant and appropriate
requirements (ARARs); long-term effectiveness; reduction of
toxicity, mobility, or volume; short-term effectiveness;
implementabilitYi cost; state acceptance; and community
acceptance.
THRESHOLD CRITERIA
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 throuqh
each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional
controls.
Alternative 1 would not protect human health and the environment
because it does not reduce risks associated with.exposure to
contaminated media at the site. Therefore, since it has been
determined that Alternative 1 would not be protective of human
health and the environment or meet ARARs, it will no longer be
considered in the nine criteria evaluation.
Alternatives 2, 3, 4A, 4B, 5A, and 5B would reduce the threats to
human health and the environment by placement of a cover material
over the contaminated materials.
However, Alternatives 3, 4A, 4B, 5A, and 5B offer greater
protection than Alternative 2 because of greater protection
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16
against potential future groundwater migration. Alternatives 3,
SA and 5B offer greater protection than Alternatives 2, 4A and 4B
due to reduced infiltration rates which increases long term
effectiveness. Alternative 2 does not provide protection of
human health and the environment against potential groundwater
contamination. Alternatives 3, SA, and 5B are slightly better
than Alternatives 4A .and 4B due to the increased protectiveness
of the cover materials resulting in lower levels of infiltration.
Alternative 2, due to lower levels of long term effectiveness and
increased short term infiltration rates is not as effective as
the other alternatives. Alternatives 3, 4A, 4B, SA, and 5B are
functionally equivalent with respect to this threshold criterion,
however, Alternatives 3, SA and 5B are slightly more effective
due to increased protectiveness of the cover materials which
translates into slightly higher levels of long term effectiveness
and permanence.
The groundwater modeling performed during the FS indicated that
due to the fact that a portion of the underlying aquifer is
unconfined, the reduction of mounding of the groundwater would be
more effective than installation of a slurry wall at containing
the off-site movement of groundwater. Groundwater mounding
occurs as a result of increased permeability of landfill
materials and causes the groundwater to collect under the
landfill. The water table directly under the landfill is higher
than it is in areas surrounding the landfill, thus distorting the
regional groundwater flow. The aforementioned reduction in
groundwater mounding would allow groundwater affected by landfill
contents to respond to regional constraints and flow toward Trail
Creek, where it would be collected in the collection trench,
instead of collecting directly under the landfill. Therefore,
Alternative 3 is slightly more effective than Alternatives SA and
5B due to more effective groundwater flow management, which
provides for the most groundwater capture of the alternatives
screened and the greatest collection to recharge ratio.
COMPLIANCE WITH ARARs
Addresses whether a remedy will meet all of the ARARs of other
Federal and state environmental laws and/or justifies a waiver of
those laws.
All of the alternatives are capable of meeting their respective
ARARs. Alternatives 2, 4A and 4B include the installation of a
vegetated soil cap and do not meet the Subtitle D capping ARAR, nor
can a waiver of these requirements be justified. ARARs for
Alternatives 3, SA and 5B can be more easily met because a waiver
from State landfill closure requirements is not a requirement due
to the expectation that they will meet Federal and State landfill
closure requirements.
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17
ARARs for the alternatives include groundwater and surface water
protection standards, floodplain protection standards and POTW
discharge standards. Al ternati ves 3, SA and SB will meet or exceed
the action and chemical specific ARARs. Because Al ternati ves 2, 3,
4A, 4B, SA and SB include the construction of a cap that may
impinge on a portion of the floodplain or a wetland, these
alternatives may require a waiver for some of the location specific
ARARs listed under 40 CFR 6 Appendix A and 40 CFR 230 and 231.
Alternatives 2, 4A and 4B will not meet the action specific ARARs
for landfill caps and may require a waiver. Table 6 of this ROD
contains a complete list of potential ARARs for all of the
alternatives.
Therefore, it has been determined that Alternatives 3, SA and SB
are functionally equivalent with respect to this threshold criteria
and are superior to Alternatives 2, 4A and 4B, because the latter
alternatives do not fully meet all of the ARARs relative to
landfill cap placement.
BALANCING CRITERIA
Lona Term Effectiveness
Addresses any expected residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment
over time, once cleanup standards have been met.
All of the alternatives involve leaving wastes in place and the
long term effectiveness and permanence is entirely dependent on the
durability and maintenance of the covers and caps and the ability
to direct groundwater to the subsurface drainage trench.
Alternatives 3, SA and SB offer the greatest long term
effectiveness and permanence, due to their ability to more
effectively control infiltration and groundwater migration. Long
term reliability of the slurry wall components could be impacted by
periodic flooding of Trail Creek, with the effectiveness of the
wall potentially detrimentally impacted.
The FS contained groundwater modeling that demonstrated that
Alternatives 3 and SA would result in the lowest residual
groundwater risk. Alternative 3's reliability for preventing off-
site migration of contaminated groundwater is slightly higher than
for Alternative SA and Alternative SB. Also, with the additional
requirement that on-site groundwater be fully contained with this
action as is stated in the Documentation of Significant Changes
section of this ROD, Alternative 3's long term reliability will be
further enhanced.
Therefore, it has been determined that Alternatives 3, SA and SB
are functionally equivalent with respect to' this balancing
criterion and are superior to Alternatives 2, 4A and 4B because of
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18
long term reliability and reduction of infiltration and leachate
generation.
Reduction of Toxicitv. Mobilitv or Volume (TMV) throuqh Treatment
Addresses the anticipated performance of the treatment technologies
a remedy may employ. .
All of the alternatives will reduce the mobility of groundwater
contamination at the site by causing changes in the direction of
flow of leachate and groundwater towards the collection trench
where contaminants would be collected for treatment. The
collection of groundwater and leachate at the site will reduce the
volume of contaminated groundwater under the site. The removal of
the collected groundwater and leachate will significantly reduce
the toxicity of contaminated groundwater and leachate at the site
and, when combined with landfill cap materials, will reduce
contaminant mobility. None of the alternatives provides reduction
of toxicity, mobility or volume through treatment, though
Alternatives 3 and SA do the most to reduce mobility and volume by
containment and removal of contaminated groundwater and leachate.
Al ternati ve 3 collects the highest percentage of recharge and
therefore, provides the best reduction of TMV, slightly higher than
for Alternatives SA and 5B. Therefore, although it has been
determined that Alternatives 2, 3, 4A , 4B, SA and SB are
functionally equivalent with respect to this balancing criterion,
Alternative 3 shows a slightly higher level of effectiveness.
Short Term Effectiveness
Addresses the period of time needed to achieve protection and any
negative effects on human health and the environment that may be
posed during the construction and implementation period, until
cleanup standards are achieved.
All of the alternatives include fencing to restrict site access to
effectively prevent or reduce risks to potential trespassers.
Alternatives 2 and 3 result in higher short term exposures over no
action as a result of workers being involved in grading and other
capping activities at the site. Alternative 2 could be completed
in approximately 6 months and Alternative 3 could be completed in
approximately 9 months.
Alternatives 4A, 4B, SA and SB would result in significant
increases in risks in the short term, primarily associated with the
construction of the slurry wall component, when compared to
Alternatives 2 and 3. Short term risks associated with the slurry
wall construction include increased air emissions from excavation
activities that will disturb foundry sand and some metal debris and
management and disposal of excavated soils (depending on the
hazardous nature of the soils). Other short term impacts from the
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19
construction of these alternatives include site grading and capping
activities and their potential to disturb surface soils and
subsurface wastes. Potential impacts on the surrounding area could
be minimized through the application of vapor suppressing foam and
other similar means, such as dust suppressants. The slurry wall
alternatives could be constructed in 9-12 months.
All of the alternatives could potentially increase risks in the
short term due to the potential disturbance of surface soils and
subsurface wastes during the installation. of the landfill cap
materials. other short term impacts include the increase in truck
traffic as landfill cap materials are brought onto the site. The
potential for this to impact the surrounding area can be minimized
by using engineering controls such as dust suppression and by
frequent monitoring so that potential impacts can be addressed
promptly and completely.
Therefore, it has been determined that Alternatives 2 and 3 are
superior to Alternatives 4A, 4B, 5A and 5B, primarily because the
construction of the slurry wall component would significantly
increase risks associated with exposure to site contaminants for
site workers and the nearby community.
ImDlementabilitv
Addresses the technical and administrative feasibility of a remedy,
includinq the availability of materials and services needed for a
particular option to be put in place.
. All of the alternatives are demonstrated technologies and will be
readily implemented at the site. Alternatives 2 and 3 are easiest
to implement technically and the slurry wall alternatives are the
most difficult due to the steep slopes on the landfill, access
problems on the western perimeter, the need for extra equipment and
specialists, and the trucking distance of the slurry materials.
Alternatives 3, 5A and 5B are potentially the easiest to implement
administratively because of the use of a compliant landfill cap,
which would preclude the necessity of obtaining waivers from the
landfill capping ARARs.
Therefore, although Alternatives 2, 3, 4A, 4B, 5A, and 5B have been
determined to be functionally equivalent with respect to this
balancing criterion, Alternative 3 is slightly easier to implement,
both technically and administratively.
Cost
Included are capital costs, annual operation and maintenance costs
(assuminq a 30 year time period), and net present value of capital
and operation and maintenance costs. The selected remedy must be
cost effective.
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20
The FS presented net present worth cost estimates for each of the
seven alternatives brought forward for detailed analysis. These
estimates were derived from literature, vendor quotations, actual
costs from similar projects, and standard cost information sources.
Cost estimates are provided primarily for the purpose of conducting
a comparative assessment between remedial options, in order to
assess the economic. feasibility of the different alternatives.
Where limited or insufficient information was available regarding
site-specific hydrogeologic characteristics or contaminant specific
treatability efficiencies, assumptions were made based on
literature and professional judgement where necessary to develop
costs associated with different processes. The cost estimates
provided in the FS are expected to provide an accuracy of +50/-30
percent (See Table 7).
Therefore, based on an analysis of the costs associated with all of
the alternatives analyzed in the FS, Alternative 2 is the least
expensive of all of the alternatives and Alternatives 5A and 5B are
the most expensive.
MODIFYING CRITERIA
state Acceotance
Addresses whether or not the state agency agrees to or objects to
any of the remedial alternatives, and considers State ARARs.
The Indiana Department of Environmental Management (IDEM) has been
intimately involved with the Site throughout the RI/FS, has
attended all technical progress meetings, has been provided
opportunity to comment on technical decisions, and concurs with the
selection of Alte~native 3as the selected remedy for the Site.
Community Accegtance
Addresses the public' s general
alternatives and proposed plan.
response
to
the
remedial
Throughout the RIfFS at the Site, community involvement has
increased from moderately to extremely interested. U.S. EPA has
been accessible and responsive to community concerns throughout the
study. This has been accomplished by a community relations program
consisting of periodic fact sheets highlighting site progress and
availability sessions with the community to communicate site
information and to answer questions regarding site progress.
At the public meeting, the majority of those in attendance, as well
as the majority of those who submitted written comments regarding
the proposed plan, were in favor of Alternative 5B as the most
appropriate choice for this action. The primary reason given for
this choice was potential future off-site migration of groundwater
contamination.
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-------
21
In summation, Alternative 1 is unacceptable for protection of human
health and the environment. Alternatives 3, 5A and 5B fully
satisfy the nine evaluation criteria with the exception of
reduction of toxicity, mobility and volume through treatment.
However, these three alternatives would provide reduction in the
toxicity of contaminants through groundwater treatment and
reduction in the mobility of contaminants through capping.
Alternatives 2, 4A and 4B are not as protective of human health and
the environment nor are they as effective in the long term at
preventing exposure to site contaminants in the soil and
groundwater and leachate.
Alternative 3 is more effective in the short term than Alternatives
5A and 5B due to the absence of the slurry wall component and its
associated implementation problems. Alternatives 5A and 5B would
significantly increase short term risks to the community due to
dust and the potentially contaminated soils removed in the slurry
trench excavation process, which could potentially impact the air
quality in the surrounding areas. Alternative 3, with the added
requirement for total groundwater containment at the site boundary,
provides for long term assurances that groundwater will not migrate
away from the site, which was the primary concern identified in
comments from the public. Finally, Alternative 3, while providing
similar levels of effectiveness, is more cost effective than
Alternatives 5A and 5B.
Therefore, the best balance among the seven alternatives, while
providing for protection of human health and the environment and
long term effectiveness and permanence, is Alternative 3, Subtitle
D Cap.
selected Remedv
u. S. EPA has selected Al ternati ve 3
appropriate cleanup remedy for the
alternative was selected because it
alternative for this final action.
- Subtitle D Cap, as the
waste, Inc . site. This
is the most appropriate
The FS contains a description of this alternative. The components
of this alternative are site preparation, institutional controls,
groundwater monitoring, . groundwater and leachate collection,
treatment and disposal, and placement of cap materials.
Site preparation will include grubbing, upgrading and installing
roadways, as needed; supplying electricity to sumps and pumping
stations; supplying natural gas if needed; and providing support
trailers and services.
Institutional controls such as fencing, deed restrictions, and
groundwater monitoring will be implemented. Deed restrictions on
both the Waste, Inc. and Lin-See, Ltd. properties will be sought
that will limit the use of the site for construction or other
-------
, ",' ..~,.... , "
I'UTENTIAI. I"EUI~ICAI. ANI) STAn~ ACTION-SI'I~C""I(: I(HJIIIHEI\II~NTS
WASTE, INC. SITE
MICIIIGAN l:ITY. INmANA
(Page 1 of 10)
un -----.
Adlon Requirement Citallon
u_- --<.
Air Stripping Design system to provide odor-free operation. CAA Seclion 1111"1
File an Air Pollution Emission Noti(c (AliEN) wilh the Stale of Indiana lu indlldc c~llIlIation 40 ('FR 52'''; 1211 11\(' 2 12
of emission rates for each pollutant expecred.
Verify Ihrough emission eSlimales allli dispersion modeliug Ihat hydrogen sulfidc clllissiuns do 4U CF/{ 61'''; .\20 lAC 1.1
not crcale an ambient concentration grcater than or equal to 0.10 ppm.
Verify Ihilt cmissions of mercury. vinyl chloride, and benzene do not excecd levels cKpccted 4n CHC hi"'; .I2h lAC 1.1
from sourccs in compliance with hazardous air pollulion regulations.
Cawing Placement of a cap over a landlill re1luires a cover designed and constructed 10: 40 CF/{ 264.3111Ia); .l2~ lAC .1-51-:1(01)
. Pmvide long-rerlll minilllilaliou of infiltration of liquids Ihrough Ihc cappclI .lIca.
. FIIII(lion with mini ilium lIIaintcnance.
. Promote drainage and minimizc crosion or abrasion of the cover.
. Accolllmodate sCllling and slIhsidcnce so thai Ihe cover's integrity is mainiaincil.
. lIavc.1 pcrmeability Icss Ihan or e
-------
Acllon
Capping (continued)
..,
. . .".
I'OTENTIAI. I'IWEItAI, AND STATE ACTION-SI'I!:t.;IIo'IC ICEQIJIREI\"'~NTS
WASTE,INC. SITE
MICHIGAN CITY, INUIANA
(Page 2 of 10)
Requirement
The maximum projected erosion rate shall be 5 tons per acre per year.
Apply and compact no less Ihan 2 feet of final cover, apply 6" of topsoil on top ollhc hnal
cover to establish vegetation.
The final cover shall have a slope 11111 less than 2% and nut greater than 33%.
Posl-closure care perfoffilance standard.
I~ecord a notal ion on the deed to Ihe facility property to notify any potential jJIIH:ha~cr Ihatlhe
land hB!! been used 8S 8 disposal facility.
posl-closure dlllics.
I(esponsihilily 10 correct nuisance.
Hilllinillion of threats to IlIIlIIan hCilhh or the cnvironment aftcr post-cloSIIIC.
Ground water monitoring devices.
firtllllld waler sampling procellures.
(irl/und watcr monitoring reljnirellleilis.
Restricl post-closure use of property as necessary to prevent damage to the cover.
Prevent run-on and run-off frolll dalllaging cover.
Prolect and lIIainlain surveyed bendllnilrks used to locate waste cells.
Disposal or decontamination of elluiplllcnt. stmctures, and soils.
Installation of final cover to provide II/ng-term minimization of infiltration.
Siabilize waSles, if necessary, hi support cover.
Posl-closure care and ground watcr IIII>IIilorin8.
Citution
-.u ---.-~:___-.l
-
329 lAC 2-14-19(.1)(AI
329 lAC 2-1.J-PJ(\)(II)
.\2'J lAC l-I.t-III( IHt"
329 lAC 2-15-1
40 CFR 251!.W (ill I);
32'J lAC 2-15-~(2)
129 tAC 2 15-7
129 lAC :1 -15 I II
.\2'1 lAC 1 1:\ II
329 lAC 2-16-1
329 lAC 2-162
40 CFt( 1511.50
40 CFR 26-t.117(~); 12') 11\('.\ .11> Kldl
40 CFn 26.I.\III(h); 12') 1'\(' I) 1 51hl
40 CH( :1C,.UIIJ(h); .12') I:\C .1-5.1 :\11.,
40 CFt( 21>-1.11.1; .111) 1"\(' 1..11>.)
40 CFR 26-1.110; 121) lAC .1-51-5
..........
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40 CFR 2b.UI0; .121) lAC ViJ-)
-------
--. -
Acllon
Clean Closure (Removal)
Direct Discharge of
Treatment System
Emuent
.-.... .
, l-J
POTENTIAl. "'EmmAI. AND STATE ACTION-SI'ECII'lt: UEQIIIHEI\U;NTS
WASTE, INC. SITE
MICHIGAN CITY, INUIANA
(Pagc ) of 10)
Requl~ment
General perfonnance standard requires minimization of need for further maintenance; control,
minimization, or elimination of post-closure escape of hazardous waste, hazarduns cOlistiluclIIs,
leachate, conlaminated runoff, ur hazllrdous waste Llecomposition products.
Disposal ur decontamination of clJllipmcnt, structures, and soils must meci bOlh Slah: illld
Fcderal requirements.
Hellioval or decontamination of all wilsle rcsidues, contaminated contaimucllt systcm
cumponents (e.g., liners, dikes), cOlltaminated subsoils, and structures and equipmcnt
contaminated wilh waste and leachate, and management of them as hazardous waslc.
Iklllllvill uf I'CII wilste IIIIISI IIIccl hCilllh based levels allli disposal ill ihXllldilllCC wllh Ihe Slate
and federal regulations.
Applicable Fedcral water quality crilcria for the protection of aquatic life must be complied
wllh when environmental factors arc beillg considered.
Applicahle Fcderally approved stale waler quality standards must be complied wilh- These
standards fIIay be In addition to or more stringent than other Federal standards under the CW A.
Thc discharge must be consislcllt wilh the requirement of a Waler QualilY MallagclllclIl plan
approved by the USEP A under Seclioll 208(b) of the CW A.
Usc of bcst available technology (BAT) economically achievable is required 10 cOlllrol loxic
aiuJ nonconventional pollutants. Use of best convendonal pollutant cORlroltcchnology (BCn is
required to control conventional polllliants. Technology-based limitations may be delermined
011 a case-by-case basis. In some cases, the pennit limit for a conventional polhllant may be
lIIorc slringent than BCT.
Discharge limilations must meel Ihc siandards set in Section 307(a) of Ihe CW A.
--
Citation
-- - .
40 CFR 264.111; 321) lAC 1-4f1- 2
40 CFR 264-114 allll 2611; J2'J lAC \;
329 lAC 3-46.-5
40 CFR 1C.-t25H;
321) lAC J-~ I-Ii; ~cc bCal'illillll III III" 1..1,1,- 1"1
addilional I\I(/\I{s.
:12') 11\1' -t 1--1(.-); .l2'J 11\1' -I); .ll'I!:\( 'I iii,
40 CFR /61.75
..--
50 FH 31J7114
.to CFR I 22-1-t all.\ Siaic Icglll.IIIIIII~ ilI'I'IIOI ,-.1
under 411 CFR 131; 317 lAC 5-2-111; 127 1.\("'
CWA Scclilill 2I11Hh); .1271,\(' 5 ~-lIhcltl,
40 CFH 121.1.1(al
327 lAC 5-5-2
40 CFR 122.4-1(1)1; CWA Scclinll .l1I1(al
----
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I'()TENTIAI. nmEItAI. AND STATE AC'rlON-SI'ECWIC IU,:tliJIREI\1ENTS
WASTE, INC. SITE
MICHIGAN CITY,INUlAN,\
(Page 4 or 10)
.- -. ----." ....-
Acllon Requlremmt Cllatlon
---- -
Direct Discharge of Efnuent must meet all State water quality standards, including narrative criteria. If a spcd fie 40 CFR 122.44hl)
Treatment Systcm pollutant causes or contributes to an cxculsion above a narrative criterion and a walel quality
.Emuent - (continned) critcrion has not previously been set, ,lit: Slate may establish effluent criteria.
Dischargc limitations must he cslahli~hell for all toxic pollutanls that are or may hc
-------
'j' ..ULl~ ~-..
rOTENTIAI. "'lmEItAI, AND STATI~ ACTION-SI"ECWIC IU~QlIllml\n:NTS
WASTE" INC. SITE
MICHIGAN CITY, INUIANA
(Pagt: 5 of 10)
u
Action Requirement Cllatlon
----
Direct I>ischarge (If Comply with additional conditions such as: 40 CFR 122.4I(i); 327 lAC 5-2-K
Treatmcnt Systcm
Emuent - (continucd) . Dilly 10 mitigate any iIIlverse dfeels of any discharge.
. Report to IDEM violalions of maximum daily discharge for certain pollillanis wilhin
24 hours.
. I'lOl'cr operation and mailllcnallee of treatment systems.
Dischar ge limitation lIIay nol he mollified to be less stringent than the gllidclilles m dfect at the 4() CFt{ 122.4-Hl)
time of mudification.
I >cvclop illlIl implcment a Uesl Milllagemcllt Praclices (UMP) program 10 prcvenl IIIe relcasc of 40 CFI( 12511111; J27 lAC 51}
10Aic conslituents 10 surface willers. I
Thc UMp program must: 4U CFt{ 125.1114
. ESlahlish specilic Ilfllcclhllcs lor the cOlllrol of loxic and hazilrt!ous polllll;1I11 spills.
. IlIcllltle a predicalionuf dirceliulI, rate of now, and total quanlily uf tU.\ie pollulanls
where experience indicau:s a reasunable potential for equipment failure.
. Assure proper manilgcmcnl of solid alld hazardous wasle in accurdam:c willi
regillations promulgatcd Ulliler RCRA.
Prescribed sample preservalioll procedllres, container materials, and maxillllllll allowahle 40CFR Ll6.I-Uo..t; .127 11\(' 5-2-1111:1
holding timcs.
-.- - .-
Discharge to purwill Polilltanis Ihat pass Ihrough the POlW withouttrealment, interfere wilh l'OlW operalion, or 40 CfR 40.1.5; 327 IA{: 5-11-1
contaminate I'OTW sludge are prohihiled.
Informal ion IllUst be available conn:ruing ililroduction of pollutants inln the I'OTW which 40 CI'I{ 122..11(1))
would be subjecr to the CW A (Sectiuns 301 or 306) If II wen: dlrecrly discharging Ihe
polJutunrs. Adequate norice will include the quality and quantity of effluent dischurged 10 the
I'OTW and any antlcipared impact 011 the quanriry or quality of crouent fO"1I the POTW.
Spccific prohibirions preclude the disdlarge of pollulanls 10 POTWs Ihat: 40 CfR 403.5;
......
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-------
Acllon
Discharge to POTWIII .
(continucd)
Oas ColieClion
"
J
I'OTKNTIAL FIWEICAI. ANI> STATK ACTION-SI'Et:II'IC ItE(JllmEl\mNTS
WASTE, INC. SITE
MICHIGAN CITY, INIJIANA
(Page 6 of 10)
Requirement
. Create a fire or explosion hazard in the POTW.
.
Arc currosive (1'11<5.11)
Ohstruct now resulting in inlcllerence.
.
.
Arc discharged at a now ratc alili/or concentration that will result in inlellcrcncc.
Increase the temperature of wastcwater entering the treatment plant that would result in
interference, or raise the POTW inOuenttemperaturl: above )(J4~F (40°C)
.
Dis.:harge IIIIISI comply wilh III.:al I'OTW prclrcalmenl program, incJlIlJiug POTW"l'c.:ifi.:
polhltants. spill prevention program requirements, and reponing and monituring rc"uiremenls.
The POTW Gill dcny or cUlulilion discharge of pollutanlS to the POTW if apl'licahlc p,c-
IIcalmenl slandards or requiremenls arc not met, or would resuh in a viulalion of Ihe POTW's
NPDES permit. TIle POTW can require compliance, conlrolthe contribntion through pennit.
order, or similar means or requirc Ihe developmenl of a compliance schedule.
RCRA permil-by-mle requiremenls lIIusl be complied with for discharges of HCI{A h;t:lafllilus
wasles to POTWs by Imck, rail, or dedicated pipe.
Meel Clean Air Acl requiremenls. and meel slate ambient air quality standards.
Dcsign sysh:1II 10 provide odor-free IIpcralion.
ESlablish procedures for review for wnslnrclion and operation of any source Ihal has Ihe
potential to emil crileria air pollutants. File an API!N with slate to include estimation of
emission rales for each pollntant expecl~d.
Verify Ihrough cmission eslimalCS illIIl ,Iispcrsion modeling Ihal hydrogen slIJlide cmissluns do
not crcale an amblenl concenlration greater than or cquaJ to 0.10 ppm.
Verify IIlat emissions of mercury. vinyl chloride, and benzene do not exceetJ levels cxpectcd
from sources in compliance with hazardous air pollulion regulallons.
Mcet established limits for VOC emissions. Dest Available Control Technology (!IACI') is
required if emissions exceed 25 tons/year.
-
Citation
321 lAC 5-12-2(b)
..0 CFR 40.1.5 alld IOLal 1'( n W rcgllialiolh
"II nit .111 IIi( I)
40 CFR 264.71; "II CHt Urt.72; .I.N lAC III.
329 lAC 3-44-.1
CAA; 326 lAC I.)
CAA ::ieclion 1111"'; .111 (H( 5.!'"
40 CFR 52'1'; .126 IA(: 2
40 CFR 61'"; J:!tJ lAC I"
40 CI'R 6111'; J26 lAC lot
326 lAC Ii-I
..
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AcUon
Operation and
Maintenance (0& 1'\'1)
Secmily
Slurry Wall
Surface Water Control
'hcalmcnt
1)(}Tt:NTIAI. ....~mmAi. ANO STAn: ACTION-SI)~C""I(: ICEQ"IREM~NTS
WASTE, INC. SITE
MICHIGAN CITY, INIJIANA
(Page 7 of 10)
Requirement
Post-closure care to ensure that site is maintained and monitored.
Develop Contingency Plan and Emcrgency Procedures to minimize potcntial halanls hom fires,
explosions or any unplanned release during closure and post-closure status.
Sites should be secured in accordance with this rule which:
I) Requires prevention of unknowing and unaulhorized elllry of I'CI ~Oll~ or
liveslock if physical contact with Ihe waste, elc. could cause injury OJ, if
disturbance of the waste, etc. would cause a violation.
The facility mllst have either: A 24 hour surveillance system ",hic'h
cOnlinuously monirors and controls entry or 8n artificial or natural barrier
which completely sunuunds the active portion and a means to conlrol entry
(i.e., a lock) at all times, through the gates or other entrances 10 Ihe at:tive
portion.
"Danger - lJnaulhlJliled Personnel Keep Our" signs arc relluire" Oil cadi
entrance and other locations sufficient 10 be seen from any apprualh, legible
from a distance of at least 2S feel.
2)
3)
Excavation of soil for construction of slurry wall may trigger cleanup or land disposal
restrictions.
Prevenr mn-on, and control and collect runoff from a 24-hour, 25-year storm duriug closure and
post-closure stalUS.
Standards for miscellaneous units (long-tcrm retrievable storage, !hennal trearmcnl orher Ihan
incineratiun, open burning, open detonation. chemical, physical. and biological treillment units
other than tanks, surface impoundments, or land treatment units) require new tlliscellanellus
units to sarisfy environmental perfonnance standards by protection of gruundwarer, smface
water, and air (Iuality, and by limiting surface and subsurface migrarion.
Requires pemlir for construction of treatmcnt facility and specifies standards for fadlily.
Trearment of wastes subject ro ban on land disposal must attain levels achievable by best
demonstrated available treatment technologies (BOAT) for each hazardous consrilllelit in each
listed waste.
Citation
40 CFR 264.118 (RC.RA Subpan (il;
329 lAC 3-46 'I
329 lAC )-1 /j
329 lAC 3-16~5
See Consolidalion, Excavarion in rhis rahk.
40 CFR 26.UIIIII),(gl.lh/;
329 lAC J-5.1-2(1),(g),(h)
----_._---~-
40 CFt{ 2M ISIIhilan X); ]29 lAC Vi.' 'I
327 lAC 3
40 CFR 268 (Subpart D)
---~_. -
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Acalon
Trealmenl - (conlinued)
Underground Injeclioll of
Wasles and Trealed
Oroundwillcr
Excavalion
."
POTENTIAL nmlmAI. AND STATE ACTION-SI'ECII'IC UE(1UIHEMENTS
WASTE, INC. SITE
MICHIGAN CITY,INIJIANt\
(Page 8 of 10)
Requirement
Prepare fughive and odor emission control plan for this Bctlon.
ESlablish procedures for review of cOllslmclion and operation of any source Ihal has Ihe
polenllal 10 emit criteria air pollutanls. ,File an APEN whh state to include estinUJlinn of
emission rates for each pollutant expectcd.
Verify through emission estimates am! dispersion modeling Ihal hydrogen sulfide I:llli~sillns do
nol create an ambient concentratioll grcaler than or equal to 0.10 ppm.
Verify Ihat emissions of mercury, vinyl chloride, and benzene do not exceed levels expecled
from sources in compliance wilh hazardous air pollution regulations.
OIC program prohibits:
. Injeclion aClivilies Ihal alluw lIIuvelllent of contaminanls inlo ulldergwlllul soulces of
drinking water (USDW) and resull in vlolallons 01 MCL! or adversely affeci human
health, and
. CUllslruclion of new Class IV wells, and operation and maintenance of cxi~ljllg wells.
Injection is prohibiled prior to pennil issuance.
Wells used 10 inject contaminated groundwaler that has been treated and is being reinjected into
Ihe some formation from which it was withdrawn are not prohibited if activity is pa.1 of
CEltCLA or RCRA aclions.
All hazardous wasle injeclion wclls IIIIISt also comply wilh Ihe RCRA reqllirclllenb.
If underground injection is proposed as part of a NPDES permit. additionallcnns and
cunditions will be added to the permilto protect ground waler quality.
Area from which malerials are excavaled may require cleanup to levels eSlablished by closure
relluiremellis.
Movemenl of excavaled malerials to previously uncontaminaled, on sile localiol\ and placement
11\ or on land may trigger 18nd disposal restrictions.
Citation
CAA Section 10101; 411 crR 521"
40 CFR 52111; Uti lAC 2
40 CFR 61111;.\26 lAC 1.1
4t) CFR 610'; .121> lAC 1.1
--- . ~ ~
40 CFR 144.12
40 CFR 144.1.\
40 CFR 144.11
40 CFR 144.14
40 CFR 144.16; 32~ lAC )-.1(1.1 (II)
327 lAC 5-4-2
----" h.
40 CFR 264 Disposal and Clnsure l{c1IuiICIIU:llh.
32~ lAC 3-40 Ihrough 32!J lAC )-54.9
40 CFR 268
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..OTI<.:NTIAI. ....mUCAI. ANI) STATE ACTI()N-SI.I~C""IC 1(1-:(111I1Ct:MENTS
WASTE. INC. SITE
MICHIGAN CITY.INUIANA
(Page 9 of 10)
--- .
Action Requirement Cllallon
-- n.. -- on
Excavalion - (continued) Removal of non-hazardous excavated material from a CBRCLA site may qualify the malerial as 329 lAC 2-21
special wasle and is subjeci 10 slale rcgulations for special wasle.
All lisled and characleristic hazardous wasles or soils and debris contaminaled by a I{CRA 40 CFR 26M
hazardous waste and removed from a CERCLA site may not be land disposed untillreated as
required by Land Ban. If altemative Ireatment lechnologies can achieve trealmenl ~imilar 10
thai required by Land 8811, and if Ihis achievemenl can be documented, Ihen a varialll:e may
nol be required.
Transporl and disposal of hazardous wasle excavaled from 8 CERCLA sile will rClJuire slale 329 lAC]
administrative and financial assuraru:c, and slate manifest
Develop fugilive and odor emission conlrol plan for Ihis aclion if exisling sile 1'10111 is CAA Seclion /111111; 40 CI.n 52"1
inadequOile. ,
Pailiculale emissions from earth tIIoving and material handling activities must he colUmlled, 326 lAC 6-4
such that no visible emissions cross Ihe propeny line and the Increase in upward/downward
total suspended particulate cOllcenlratioll is limiled 10 SO uglm'.
File an APEN wilh slale to include eslimalion of emission rates for each pollulal1l cKpccled. 40 eFR 521"; .t!6 lAC 2-1-2
Verify Ihrough emission eSlimales and dispersion modeling that hydrogen sulfide cmissions do 40 eFR 61'11; 326 lAC 14
nOI crcate an ambient concentralion greater than or equal 10 0.1 0 ppm.
Verify Ih:ll cmissions of mercury, villyl chloride, and benzene do nol exceed levcl~ cKpccled 411 CI'IC bl"'; .I.!h lAC I.t
from snurces in compliance wilh hnzmllous air pollution regulations.
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l'O'ft:NTIAI. I'ImEHAL ANI) STATI!: ACTION-SI'I~c.:""Ic.: ICE(lUIHEI\I~NTS
WASTE, INC. SITE
MICHIGAN CITV, INIJIANA
(Page 10 IIf 10)
... . .---- I
Action R~qulrement Clloelon
--. . - .---.
Consolidalion Area from which malerials are removed should be remediated. See Clean Closure or Capping
(:onsulidalion in sloragc piles will Irit;gcr slorage requiremenls. 40 CFH 2t>LI.I; -III CFH 268 (suhpilri 1:1
Place 1111 ur ill land oulside IIlIit hUlIIlllilry or area of conlaminalion will trigger Iillid ,lisposal ..0 CFH 285 ISuhpill1 II)
requirements and restrictions.
Develop fugilive and odor emissioll corllml plan for Ihis aClion if exisling sile 1'10111 is CAA Seclion 101'"; -to CH~ 52'"
InadequiUe.
hlc ilild APEN wilh slalc 10 illdlldc cslililillioll of emissioll rales for eilch 1'"11 III iI II 1 cxpcclcd. "II CH~ 52'1'; .12l> lAC 2.1-2
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(" AU u' 11M' (Iloln "If A_I AM AM" 111.
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10. b It:>- . 7
8
COMPARATIVE COST SUMMARY
WASTE. INC. SITE
. MICHIGAN CITY. INDIANA
Alternative I Total Capital Cost ($)(1) I Total 0 & M Cost ($)ill Total Present Worth ($)(1,1)
1 I 0 0 0
2 I 5.200.000 j 290.000 9.700.000 i
I I 11.300.000 j I
. I :::90.000 15.700.000 I
.1A I 6.500.000 i 300.000 11.100.000 I
48 7.300.000 I 300.000 11.900.000
5A 12.500.000 300.000 17.100.000
5B 13.300.000 I 300.000 17.900.000
Key:
O&.M = Operating and Ma.intfl!n~Ce.
Notes:
I) Totals are rounded to the nearest $100.000.
:) Present worth calculations assume a discount rate oi 5 percent.
8
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METALS TREATMENT SYSTEM
SIMPLIFIED PROCESS FLOW DIAGRAM
WASTE, INC. SITE
MICHIGAN CITY. INDIANA
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22
development, and will prohibit the use of groundwater beneath the
site for drinking water purposes.
Long term groundwater monitoring to insure that contaminated
groundwater has not moved off-site and well maintenance will be
required and will be further refined during remedial design. Two
separate collection/ extraction systems - a groundwater and leachate
collection trench and groundwater extraction wells - shall be
installed to capture and prevent any potential future off-site
migration of the contamination plume. Groundwater and leachate
will be collected by a trench along Trail Creek and in the area of
steep slopes along the property lines near the creek.
Drainage pumps in the trench will lead to sumps, with submersible
pumps. The trench would be keyed into the olive-grey clay along
the toe of the landfill near the 590 foot elevation contour. A
groundwater flow barrier, consisting of a high-density polyethylene
(HDPE) liner of sheet piles along the creek side of the collection
trench will be installed to prevent dehydrating the soils between
the trench and the creek, to ensure that the collected groundwater
and leachate do not migrate out of the collection trench and to
prevent flood waters from entering the collection trench. The
trench would be covered by the cap to provide further protection
from floods and surface water runoff.
Extraction wells shall be installed at the site and utilized so
that groundwater contaminated by the site is contained at the site
boundary. This requirement shall ensure that the potential for
future off-site migration of contaminated groundwater is
eliminated. Details on extraction rates and extraction well
placement shall be developed during remedial design to ensure that
this requirement is met.
The collected groundwater and leachate shall be pumped to the
Sanitary District of Michigan City Wastewater Treatment Facility
(the District) for treatment. The District is located along Trail
Creek directly across from the southwestern portion of the Waste,
Inc. property. Discharge to the POTW will require a pumping
station and necessary piping. Piping may be routed directly to the
District or to the combined sewer along u.s. Highway 12 and will
require winterization.
When the collected groundwater and leachate is discharged to the
local POTW, this effluent will have to meet the District's
discharge limits summarized in Table 5. In addition, the collected
groundwater and leachate would have to fulfill the requirements on
Table 5. If the collected groundwater and leachate does not meet
these limits for discharge, treatment using a combination of
gravity clarification, filtration, metals precipitation and
activated carbon shall be used to treat the groundwater to these
levels, so that discharge to the POTW will be allowable. A
simplified process flow diagram for the treatment system is shown
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23
in Figure 4.
provisions shall be made so that if the District cannot accept
direct discharge from the site (i.e. during rain events), then the
collected groundwater and leachate will be stored on-site until the
District can accept direct discharge.
The Subtitle D Cap shall meet the requirements of 329 lAC 2-14-
19(3) (b) and 329 lAC 19(3) (a)-(c). The need for additional cover
layers will be evaluated during RD/RA.
Capping the Waste, Inc. site is a three stage process. The heavily
vegetated and wooded areas on the Lin-See Ltd. property must be
cleared and grubbed. Then, the steep slope between the fill mound
and Trail Creek will be moderated unless a waiver of slope
requirements is granted. The slopes may require stabilization
based on the results of the slope stability investigation during
remedial design. The two options for moderating the slope are cut
and fill (i.e. regrading within the current landfill area) and the
addition of fill. Drums located at or near the toe of the landfill
would have to either be moved or covered. The cap would then be
placed over the new fill in the same manner as it would be over the
rest of the site.
Gas collection shall be provided by installing vent pipes into the
fill. The collected gas will be disposed of by flaring or venting.
Final gas management requirements will be determined during
remedial design.
As a portion of the selected remedy, information shall be gathered
on the storm sewer that runs under the western portion of the
landfill mound. This information shall assist in determining if
the sewer can be rerouted from under the landfill mound or grouted
and sealed so that the potential for leachate from the site to
migrate along this route and ultimately discharge into Trail Creek
is eliminated.
As a portion of the selected remedy, the underground tank that is
located on the northern portion of the Waste, Inc. property shall
be located and removed in accordance with the Underground storage
Tank regulations.
As a portion of the selected remedy, fish advisory signs shall be
posted along Trail Creek, informing residents of the potential
risks associated with consumption of fish that may have been
impacted by the Waste, Inc. site, as was calculated in the site-
wide risk assessment.
As a portion of the selected remedy, the on-site well (located on
the north-central portion of the site directly behind the front
gate) will be properly abandoned in accordance with the appropriate
state of Indiana well abandonment regulations.
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24
The point of compliance for this remedial action shall be the
property boundary, as is illustrated in site documents such as the
RI and the FS, and as defined on Figure 2. This action will ensure
that groundwater will not migrate past the point of compliance.
Because hazardous substances will remain in place at the site, U.S.
EPA will review the remedial action every five years to determine
its effectiveness.
Documentation of Sianificant Chanaes
At the public meeting and throughout the pUblic comment period,
si te residents and proposed plan commentors recommended that a
slurry wall component be added to the Subtitle D Cap remedial
action primarily to address the potential for on-site contaminated
groundwater to migrate away from the site. At the present time,
groundwater has not been found to be moving away from the site;
however, the potential exists for this to happen in the future.
EPA has modified the proposed remedy to address this concern in the
following manner: EPA has added a requirement that extraction
wells be installed that will ensure that site groundwater will
always be contained at the site boundary, so that the potential for
future off-site groundwater migration is eliminated. This
requirement is preferred to the installation of a slurry wall
because of the similarities in effectiveness between the two
technologies and the detrimental impacts of installing a slurry
wall, including dust and noise generation and disturbance of site
wastes, that will produce much higher risks to the community in the
short term.
Additionally, the RI did not identify any locations within a one
mile radius of the site that were using groundwater. However,
during the public comment period, 17 wells in the site vicinity
were identified by a local group of citizens. Of these 17 wells,
one was definitely located within a one mile radius of the site and
two others were slightly farther from the site. At the request of
the EPA, IDEM sampled these three wells to determine if they had
been impacted by the site, even though RI data indicates that
groundwater is not migrating away from the site. The results of
this sampling exercise will be examined, when available, and if
contamination attributable to the site is found in these wells, EPA
will take appropriate measures, consistent with its authority under
CERCLA, to remediate the problem.
EPA has also modified the proposed remedy to add requirements to
remove the underground fuel tank that is located on the northern
portion of the property. This action will remove a potential
source of contamination. EPA has modified the proposed remedy to
address the on-site storm sewer that is situated under the western
portion of the landfill mound. This sewer will either be abandoned
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25
or rerouted, depending on current usage. EPA has modified the
proposed remedy to include proper abandonment of the on-site well,
which has been the subject of concern throughout the RIfFS process.
Finally, EPA has modified the proposed remedy to include the
posting of fish advisory signs along Trail Creek, to warn anglers
of potential hazards associated with f ish consumption calculated in
the risk assessment for the Waste, Inc. site.
statutory Determinations
The selected remedy must satisfy the requirements of Section l21(a-
e) of CERCLA to:
a. Protect human health and the environment;
b. Comply with ARARs;
c. Be cost-effective;
d. utilize permanent solutions and alternate treatment
technologies to the maximum extent practicable; and,
e. Satisfy a preference for treatment as a principal element of
the remedy.
The implementation of Al ternati ve 3 at the Waste, Inc.
satisfies the requirements of CERCLA as detailed below:
site
a. Protection of Human Health and the Environment
Implementation of the selected alternative will reduce and control
potential risks to human health posed by exposure to contaminated
ground water. Institutional controls will provide short-term
effectiveness for the prevention of drinking contaminated ground
water under the site. The selected remedy also protects the
environment by eliminating the potential risks posed by site
contaminants and leachate discharging to surface water (Trail
Creek) by creating a hydraulic barrier through pumping of
groundwater.
Capping the landfill, in addition to reducing the potential future
risk posed by exposure to landfill contaminants and contaminated
soil, will reduce percolation and recharge through the cap by an
estimated 90 percent, and maintain that rate of reduction over
time. Ground-water contaminant loading will thus be reduced.
No unacceptable short-term risks will be caused by implementation
of the remedy. The community and site workers may be exposed to
noise and dust nuisances during construction of the cap. Vehicular
accident occurrences may rise due to the projected increase in
volume of truck traffic in hauling capping materials to the
landfill. Standard safety programs will manage any short-term
risks. Dust control measures and VOC-emission controls will
mitigate those risks as well.
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26
The permanent solutions to the principal threats to human health
and the environment at the site outweigh the minimal short-term
impacts of the construction of the remedial components. The risks
due to ingestion of contaminated ground water would be reduced to
acceptable levels once the principal threats have been addressed.
Once the cap is installed there would be no need to replace or
upgrade it, assuming. proper maintenance.
b. Compliance With ARARs
CERCLA requires that remedial actions meet legally applicable or
relevant and appropriate requirements of other environmental laws.
A "legally applicable" requirement is one which would legally apply
to the response action if that action were not taken pursuant to
CERCLA. A "relevant and appropriate" requirement is one that,
while not "applicable," is designed to apply to problems
sufficiently similar to those at the site that its application is
appropriate.
The selected remedy will comply with the Federal and/or State where
more stringent, applicable or relevant and appropriate requirements
(ARARs) listed below: .
1. Chemical-specific ARARs
Chemical-specific ARARs regulate the release to the environment of
specific substances having certain chemical characteristics.
Chemical-specific ARARs typically determine the extent of cleanup
at a site.
A. Soils/Sediments
No chemical-specific standards exist for soils and sediments. The
cap will prevent any further risk posed by contact with or
ingestion of contaminated soils on site.
B. Surface Water
i. Federal ARARs
Surface water quality standards for human health and aquatic life
protection were developed under the Clean Water Act (CWA) Section
304. The Federal Ambient Water Quality Criteria (AWQC) are non-
enforceable guidelines that set pollutant concentration limits to
protect surface waters that are applicable to point source
discharges, such as from industrial or municipal wastewater
streams. At a Superfund site, the Federal AWQC would not be
applicable except for pretreatment requirements for discharge of
treated water to a Publicly Operated Treatment Works (POTW).
CERCLA (Section 12l(d) (1)) requires the U.S. EPA to consider
whether AWQC would be relevant and appropriate under the
circumstances of a release or threatened release, depending on the
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27
designated or potential use of ground water or surface water, the
environmental media affected by the releases or potential releases,
and upon the latest information available. Since the aquifer may
be a potential source of drinking water, and treated water will be
discharged to the Michigan City POTW, AWQC adopted for drinking
water and AWQC for protection of freshwater aquatic organisms are
relevant and appropriate to the point source discharge of the
treated water into the POTW.
ii. State ARARs
section 303 of the CWA requires the state to promulgate state water
quality standards for surface water bodies, based on the designated
uses of the surface water bodies. CERCLA remedial actions
invol ving surface water bodies must ensure that applicable or
relevant and appropriate state water quality standards are met.
In addition, Indiana establishes an anti-degradation policy for all
waters of the state and it establishes water quality standards for
use classifications. These would be applicable to actions that
involve discharges to POTW/Trail Creek in that discharges must meet
water quality standards.
The Sanitary District of Michigan City, Indiana has sewer use
regulations as part of its NPDES permit which require pretreatment
prior to discharge to the sewer system. The remedy will provide
mechanisms for any such pretreatment needed for the extracted
groundwater which is to be disposed of in the POTW.
C. Groundwater
Because contaminated groundwater has not yet migrated away from the
site and because 'the selected remedy will permanently contain the
contaminated groundwater currently on-site, no treatment of
groundwater is contemplated by this ROD.
2. Location-specific ARARs
Location-specific ARARs are those requirements that relate to the
geographical position of a site. These include:
i. Federal ARARs
Both RCRA (40 CFR 264.18 (b) - hazardous waste storage - flood
plain) and Executive Order 11988 - Protection of Flood Plains, are
applicable to the site due to its location within the mapped 100-
year flood plain of Trail Creek. These regulations would require
that the ground-water treatment system be located above this
elevation and be protected from erosional damage. If it cannot be
so located, an ARAR waiver for technical impracticability will be
invoked.
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28
Executive Order 11990 - Protection of Wetlands is an applicable
requirement to protect against the loss or degradation of wetlands.
Ground-water modeling has shown that the estimated extraction rate
for Alternative 3 will not be expected to have an adverse effect on
the wetlands.
Executive Order 11998 - Floodplain Management - is applicable at
the site. Some construction will occur in the floodplain in order
to cap the site to protect human health. All attempts will be made
to minimize this impact, but an ARAR waiver will be invoked for
that necessary construction in the flood plain.
The Federal Endangered and Threatened Species Act protects against
the "taking" or harming of endangered or threatened wildlife
resources in the area. These would be applicable to the remedial
action, in that the poisoning of endangered or threatened species
by site contaminants could be considered a "taking." However, the
environmental evaluation conducted as a portion of the risk
assessment indicated that there were no endangered, threatened or
rare species to be found on or in areas immediately adjacent to the
site.
3. Action-specific ARARs
Action-specific ARARs are requirements that define acceptable
treatment and disposal procedures for hazardous substances.
i. Federal ARARs
Even though Waste, Inc. Landfill was closed after November 1980
RCRA requirements for landfill closure, RCRA Subtitle C, are not
applicable since the hazardous wastes of concern have not been
determined to be ei ther RCRA listed hazardous wastes or RCRA
character istic wastes. However, RCRA .Subti tIe C requirements would
be relevant at the site, because the' hazardous substances in the
landfill are sufficiently similar to listed and/or characteristic
RCRA wastes.
A Subtitle C cover is not appropriate for the site, however,
because the maximum slope allowed is five percent. A cap with a
five percent slope would extend several hundred feet over Trail
Creek and well into the floodplain. Furthermore, the hazardous
substances are present in the landfill at relatively low
concentrations and dispersed over a wide area with no hot spots,
making Subtitle C requirements inappropriate.
The RCRA Subtitle D landfill requirements are not applicable
because they became effective after the site stopped receiving
waste. Indiana landfill requirements listed at 329 lAC 2-14 are
applicable because they apply to inactive landfills, are more
stringent than federal standards, and are currently in effect.
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29
In the event that a flood event occurs, which affects direct
discharge to the District, or on-site pre-treatment is required,
RCRA storage and disposal requirements must be met.
Additional Federal action-specific ARARs are found in Table 6.
ii. state ARARs
The cap proposed for the Waste, Inc. site satisfies the
requirements of Indiana Subtitle D ( 329 lAC 2). The estimated
reduction of water infiltration with the Alternative 3 cap is 90
percent; the cap design, therefore, also satisfies most of the
requirements for subtitle C caps found at 40 CFR 264.310(a) (1).
Since the landfill waste is periodically in contact with the ground
water at the site, and, since ground water is to be extracted from
an area adjacent to the landfill and treated, the U.S. EPA has
determined that it is not technically advantageous and, therefore,
not appropriate to install a Flexible Membrane Liner (FML) at this
site.
In addition to the cap design requirements of 329 IAC 2, the state
is authorized to implement the National Pollutant Discharge
Elimination System (NPDES) program. For discharge of treated
water, the applicable or relevant and appropriate requirements are
dependent on the point of discharge. The substantive requirements
of an Indiana Pollutant Discharge Elimination System (IPDES)
permit, under lAC, would be applied to the discharge of the
collected water to the Michigan City POTW.
Additional ARARs are found in the FS.
c. Cost-effectiveness
Cost-effectiveness compares the effectiveness of an alternative in
proportion to its cost of providing its environmental benefits.
Table 7 lists the costs associated with the implementation of the
remedies.
1. Landfill Alternatives
Alternative 1 is the least expensive alternative, but it does not
provide adequate protection or effectiveness over the long-term and
it also does not meet state landfill closure requirements.
Alternatives 3 and 5 are initially more expensive than Alternatives
2 or 4, due to the cap design, but they provide better
precipitation infiltration reduction rates than Alternatives 2 and
4, and they meet current landfill closure requirements.
Alternatives 2 and 4 would provide some reduction of precipitation
infiltration over the short-term, but it would be subjected to the
same damage already experienced by the present cap and, thus,
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30
costly repairs are more likely. Additionally, Alternatives 2 and
4 do not meet current landfill closure requirements.
2. Ground-Water Alternatives
Alternative 1 is the least expensive of the ground-water remedies,
but it does not provide adequate protection of human health and the
environment. Alternative 2 provides only containment of the
landfill and contaminated soils but does not prevent potential of-
site migration of groundwater and leachate. The other alternatives
do prevent groundwater migration, with alternatives 3 and 4 being
less expensive.
Thus, the selected remedy is the most cost-effective remedy, in
that Alternative 3 is the only cost-effective option that complies
with Federal and state landfill-closure ARARs. The slurry wall
afforded by Alternatives 4 and 5 is not needed since the pump and
treat system is just as effective in containing the groundwater.
d. utilization of Permanent Solutions and Alternative Treatment
Technoloqies or Resource Recoverv Technoloqies to the Maximum
Extent Practicable
The selected remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable ("MEP").
This finding was made after evaluation of the protective and ARAR-
compliant alternatives for the Waste, Inc. site remedial action and
comparison of the "trade-offs" (advantages vs. disadvantages) among
the remedial alternatives with respect to the five balancing
criteria (see above).
Once the threshold criteria of protection of human health and the
environment and ARARs compliance were satisfied, the key criteria
used in remedy selection for the Waste, Inc. site were long-term
effectiveness; reduction of toxicity, mobility, and volume ("TMV")
through treatment; short-term effectiveness; and cost). The
priority given to long-term effectiveness and to reduction of TMV
at the site is consistent with u.S. EPA policy established in the
NCP. This policy states that long-term effectiveness and reduction
of TMV through treatment are generally the key decision factors to
be considered at Superfund sites.
The selected remedy's long-term effectiveness and its ability to
reduce the TMV of hazardous substances were weighed against its
short-term effectiveness aspects in relation to the remaining
alternatives. In general, the selected remedy does involve a small
degree of risk to site workers and to the community in that there
would be movement and treatment of hazardous substances during
implementation in order to minimize the long-term effects those
substances would have on human health and the environment.
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31
There may be minimal risks associated with the hauling of materials
for cap construction. Any risks posed by such action will be
mitigated by attempting to secure local materials to construct the
cap and to employ standard dust control measures during
construction.
1. Landfill Alternatives
The FS report indicates that it is not practicable to utilize a
permanent treatment technology on the low-level, long-term threat
posed by the landfill contents. Although a cap is not a permanent
solution to the low-level threat, it does provide adequate
protection from exposure to the wastes. More importantly it
provides adequate protection to the ground water by using a barrier
to precipitation infiltration through the landfill, which reduces
the rate of contaminant. loading into the ground water.
The state has concurred with the selection of Alternative 3 as the
preferred containment remedy for the landfill unit.
2. Ground-Water Alternatives
Alternative 3 provides a greater degree of long-term effectiveness
and permanence than the other ground-water alternatives considered
for the site.
None of the alternatives provide reduction of TMV through
treatment. However, Alternative 3 does control groundwater
migration so no further off-site contamination of surface water or
ground water will occur.
3. Summary
The combination of engineering and institutional controls will
minimize the residual threats remaining on-site. Negative short-
term impacts during implementation of the remedy will be minimized
by health and safety measures. The state has concurred with the
selection of the preferred remedy. Communi ty acceptance is
addressed in the responsiveness summary.
e. Preference for Treatment as a Principal Element
The principal threats at the Waste, Inc. site are the on-site
ground-water contamination, due to the potential use of the
contaminated water as a drinking water source, and the contaminated
soils found on site. No alternative satisfies the statutory
preference for treatment as a principal element of the remedy
through extraction (and treatment) of the ground-water contaminant
plume to achieve Ground-Water Cleanup Standards. Since the
landfill does not appear to contain "hot spots", and the wastes are
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32
too heterogeneous for soil treatment to be fully effective,
satisfaction of the preference for treatment as a principal element
of the landfill portion of the remedy is not practical or cost
effective.
EPA and IDEM believe the selected remedy satisfies the statutory
requirements specified in Section 121 of SARA to protect human
health and the environment; will comply with ARARs (or provide
grounds for invoking a waiver); provides overall effectiveness
proportionate to its costs; and will utilize permanent solutions
and alternate treatment technologies to the maximum extent
practicable.
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APPENDIX A
Waste, Inc. Landfill
Michigan City, Indiana
Responsiveness Summary
I. Responsiveness summary overview
In accordance with CERCLA Section 117, a public comment period
was held from January 24, 1994 to April 22, 1994, to allow
interested parties to comment on the United stated Environmental
Protection Agency's (U.S. EPA's) Feasibility Study (FS) and
Proposed Plan for the Waste, Inc. Landfill Superfund site. At a
February 9, 1994, public meeting, EPA and Indiana Department of
Environmental Management (IDEM) officials presented the Proposed
Plan for remediation at the Waste, Inc. site, answered questions
and accepted comments from the public. Written comments were
also received through the mail.
II.
Background of community Concern
The Waste, Inc. Landfill operated from 1965 to 1982 as an
unpermitted landfill. In August, 1982, a consent order required
that the site be covered with foundry sand and capped with clay.
However, this order was not fully complied with. In January
1985, the site was scored for the National Priorities List (NPL).
The site was placed on the NPL in 1987.
community involvement has increased over the years as more people
became aware of activities at the site. Residents and interested
citizens have formed several environmental activist groups to
deal with the growing problem of hazardous waste in LaPorte
County. These include Save the Dunes Council, LaPorte County
Environmental Association, Canada Community Improvement Society,
People against Hazardous Waste Sites, and Mothers Opposed to
Pollution.
Trail Creek dredging activities in 1987 raised community
awareness of environmental activities at the site. Since that
point, community interest and involvement has increased.
III.
EPA's Proposed Remedy and its Relation to the Final ROD
In a Proposed Plan that was issued on January 24, 1994, U.S. EPA
(EPA) proposed Alternative 3, Subtitle D Cap, for on-site
cleanup. This remedy was based on the information presented in
the FS, prepared by the site Steering Committee and reviewed and
approved by EPA. During the public comment period, EPA received
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2
numerous comments regarding the proposal of Alternative 3, most
of which were not favorable. The majority of the comments
recommended that EPA select Alternative SB, Deep Slurry Wall and
Subtitle D Cap, for the site cleanup.
As a result of the public comments, EPA has added several
requirements to the selection of Alternative 3, Subtitle D Cap,
as the remedy for site cleanup, as is outlined in the Record of
Decision (ROD).
EPA will attempt to provide information relative to the
additional requirements that this ROD contains, demonstrating
that public concerns playa large role in Superfund remedy
selection, as well as answering the concerns that the public has
voiced regarding the other remedial components of this ROD.
IV. summary of Significant Comments Received During the Public
Comment Period and EPA Responses
The comments are organized into the following categories:
A. Summary of comments concerning the overall effectiveness of
the proposed remedy.
1. Comments were raised concerning the proposed remedy not being
able to prevent potential future off-site migration of
contaminated groundwater.
u.S. EPA response 1: U.S. EPA understands the concerns regarding
the potential for groundwater contaminated by the site to move
away from the site in the future. Superfund cleanup remedies
provide for remediation of actual and threatened releases of
contamination from Superfund sites. At the Waste, Inc. site,
there is no evidence that groundwater contamination is moving
away from the site at present, however, the potential exists for
this to occur in the future. Consequently, EPA has added a
requirement to this ROD that will use groundwater extraction
wells to assist in the collection of groundwater at the site, so
that the potential for future off-site migration of contaminated
groundwater is eliminated.
2. Comments were raised concerning the fact that groundwater
monitoring results in the RI were not indicative of future
results due to the presence of drums in the landfill.
u.S. EPA response 2: U.S. EPA agrees with this comment and with
the installation of the aforementioned extraction wells and
subsequent groundwater monitoring during the remedy
implementation, will ensure that groundwater contaminated by the
site is contained at the site boundary.
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3
3. Comments were raised about the long term effectiveness of the
proposed remedy, specifically excessive cap erosion and long term
operation and maintenance and effectiveness of the leachate
collection trench.
u.s. EPA response 3: Capping is accepted as an effective means
of cleanup at landfill sites, due to the highly variable mixture
of wastes present which precludes effective treatment of the
contents of the landfill. Proper design and implementation of a
landfill cap will ensure optimum performance. Periodic
monitoring and routine maintenance after cap placement will
identify potential operating problems early enough so that any
adverse impacts can be addressed promptly.
The commentors are correct that the leachate collection trench
will only collect leachate and groundwater from the shallow
portion of the aquifer; however, the landfill cap, as designed,
would significantly impact groundwater flow in the deeper portion
of the aquifer by reducing the influences of groundwater mounding
on local groundwater flow. This will allow the groundwater to
revert to a more natural flow path, as if the landfill was not
there. Landfills typically impact local groundwater flow
significantly because the increased infiltration of rainwater
causes the local groundwater to "mound up" or collect under the
landfill. This interrupts local flow patterns and creates a
"radial" flow pattern, or one that migrates away from the site in
all directions. The landfill cap, coupled with the requirement
that extraction wells be used to assist in total site groundwater
isolation, will eliminate the off-site migration pathway.
It is true that the leachate collection trench will require long
term maintenance to ensure optimal performance-the det~ils for
this are to be provided to the public in the operation and
maintenance plan, which will be completed during the RD/RA
process. The public will be frequently informed on site
activities during the entire RD/RA process so that any questions
or concerns can be promptly addressed.
4. Comments were raised that stated that the proposed remedy
would not sufficiently protect human health and the environment
and did not adequately meet the nine NCP criteria.
u.s. EPA response 4. U.S. EPA believes the remedy selected in
this ROD does protect human health and the environment by the
placement of a cap over the landfill contents and the collection
of contaminated groundwater and leachate. These actions will
prevent people from contacting site materials and by including
deed restrictions at the site, will ensure that this contact will
be prevented in the future. The selected remedy was evaluated
against the nine NCP criteria and was determined to be the best
alternative for site cleanup. The commentor is referred to the
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4
comparative analysis section of the ROD to see how Alternative 3
was evaluated and rated superior to the other alternatives.
5. Comments were raised regarding the applicability of RCRA
subtitle C regulations to the site cleanup and the
inapplicability of subtitle D regulations to site cleanup.
u.s. EPA response 5: RCRA subtitle C requirements are not
directly applicable because the site was never a permitted RCRA
facility; however, they are relevant. A requirement is
appropriate as well if its implementation is necessary to address
the conditions at the site. According to 40 CFR 265.310 Subpart
N, the cap requirement for closure of an interim status facility
is that it must have equal to or less permeability than the soils
at the bottom of the facility, in this case the olive gray clay
layer. This permeability standard is the relevant and
appropriate standard. The cap must be constructed in such a way
as to meet that standard. In addition, Subtitle C requirements
are not appropriate for the site because the maximum slope
allowed is five percent, which would extend the cap several
hundred feet into the Trail Creek floodplain. Finally, the
hazardous substances are present in the landfill at relatively
low concentrations and dispersed over a wide area with no hot
spots, making RCRA subtitle C requirements inappropriate.
RCRA subtitle D requirements are not directly applicable because
they became effective after the site stopped receiving waste.
Indiana landfill requirements listed at 329 lAC 2-14 are
applicable because they apply to inactive landfills, are more
stringent than federal standards, and are currently in effect.
6. A comment or questioned EPA's selection of Alternative 3 over
the slurry wall alternatives in relation to the short term
effectiveness balancing criterion.
u.s. EPA response 6: The selection of Alternative 3 over the
slurry wall alternatives because of increased short term
effectiveness was not only based on the fact that Alternative 3
would take three fewer months to implement. ,The primary reason
that it was rated superior to the slurry wall alternatives was
because of the intrusive activities of slurry wall construction
and the greatly increased short term impacts on site workers and
nearby residents. Dust generation, trucks hauling excavated
soils, the impact of slurry wall installation on under and above
ground utilities in the site vicinity and increased noise were
given far greater consideration than the implementation
timeframe. EPA has determined that the remedy selected in this
ROD will provide protection from site risks while subjecting the
community to lower short term risks during implementation than
the slurry wall alternatives.
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5
B. Summary of comments regarding off-site impacts from the
landfill contents and remediation activities.
7. Comments were raised regarding the RI findings that there
were no private wells identified within a one mile radius of the
site.
u.S. EPA response 7: The findings of the RI were that there were
no private wells identified as using area groundwater within a
one mile radius of the site. However, during the public comment
period, several local groups conducted a door to door survey of
site area residents and identified seventeen wells currently used
for drinking water purposes. EPA requested that IDEM sample
three of the wells identified by the local groups that were
located approximately 1 mile from the site. The other fourteen
wells were located approximately 2 miles from the site. The
reasoning behind this sampling activity was to determine if any
site related contamination had migrated to these locations.
These monitoring results will be available soon and will be
released to the public at that time.
This exercise is a perfect example of EPA working in conjunction
with local residents to address a potential environmental
problem. EPA appreciates the groups' efforts that resulted in
the well sampling. EPA will continue to work with local
residents so that potential concerns such as these are promptly
identified and addressed.
8. A commentor stated that potential off-site migration of
groundwater contamination has not been adequately modeled.
u.S. EPA response 8: Additional groundwater modeling will be
done during remedial design, to assist in determining optimum
performance and operating conditions for all remedy components.
9. Several commentors stated that the RI did not include an
evaluation of biological indicators of exposure on individuals
who live near the site.
u.S. EPA response 9: EPA requires a risk assessment be
performed to evaluate potential risks to human health and the
environment as a result of contamination at Superfund sites.
This assessment does not include biological markers. However,
the Agency for Toxic Substances and Disease Registry (ATSDR) can
perform these studies if the results of the Health Assessment
that ATSDR is required to perform for each Superfund site
indicate that an epidemiological or other health study is
warranted. At the Waste, Inc. site, this assessment is to be
performed by ATSDR shortly. As a result of public comment, ATSDR
also performed blood lead testing in the immediate site area that
did not indicate any problems due to lead exposure. The results
of this study will be released when they become available.
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6
10. Several commentors were concerned about adverse impacts on
nearby residents during actual site remediation.
u.S. EPA response 10: U.S. EPA shares this concern and will
ensure that frequent monitoring will prevent this occurrence. A
number of measures can be taken to prevent potential exposures.
Dust suppression, such as spraying on-site areas with water or
vapor suppressing foam, will be used to minimize dust generation.
Air monitoring for personal safety, using organic vapor detectors
will also be used, both to ensure the protection of on-site
workers, as well as to ensure the protection of nearby residents
and businesses.
c.
Summary of comments regarding the selected remedy.
11. Commentors requested that specific variances from ARARs (cap
slope angles, construction in the floodplain) be provided in the
ROD so that actual cap design could proceed more efficiently
u.S. EPA response 11: It has not been demonstrated at this time
that site specific variances are necessary. If cap design
determines the need for variances or ARARs waivers, then they
will be pursued at that time.
12. A commentor stated that the landfill did not pose any risks
and EPA should select Alternative l-No Action for site cleanup.
u.s. EPA response 12: EPA disagrees with this comment. The
risks associated with potential exposure to site materials are
unacceptable, as demonstrated in the site risk assessment. The
risks calculated demonstrate an unacceptable increased health
risk to human health and the environment due to exposure to
hazardous substances disposed of at the site, if no action is
taken to remediate the contamination problem. EPA has been
tasked with an enormous responsibility of making hazardous sites
safe so that everyday risks to people who live nearby are
decreased. This is the case at the Waste, Inc. site.
13. A commentor called the costs for the alternatives
ridiculous.
u.s. EPA response 13: The cost figures presented for the seven
alternatives were derived from literature, vendor quotations,
actual costs from similar projects, and standard cost information
sources. These cost figures are provided primarily for the
purposes of conducting a comparative assessment between remedial
alternatives, in order to assess the economic feasibility of each
alternative. What the cost figures demonstrate is that once
hazardous wastes are improperly disposed of, it costs far more to
clean them up then it does to dispose of them properly in the
first place. With all of the new environmental laws and
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7
regulations in place today, it is hoped that similar costs will
not be passed along to future generations.
14. Several commentors suggested that EPA build a safe container
from scratch and move the wastes to it.
u.S. EPA response 14: U.S. EPA disagrees with this approach
because it entails the same risks as the total excavation and
removal of the landfill approach. Plus, the building would have
to be very large and very tall and nearby residents or local
businesses may not be amenable to its presence. These types of
containers are typically used for temporary storage of hazardous
wastes, and are not typically used for permanent storage.
Compliance with the appropriate Federal and State standards for
facility construction and hazardous materials storage, future
maintenance of the building and the foundation, and provisions
for security would still be required, as is the case for all of
the alternatives considered for the site cleanup.
D. Summary of comments regarding other environmental issues
related to site cleanup.
15. Several commentors stated that the storm sewer that runs
under the western portion of the landfill should be addressed.
u.S. EPA response 15: The current and future usage of the storm
sewer is being investigated by the site steering Committee at the
direction of EPA. This includes determining whether the sewer is
vital for local drainage needs and a video survey to determine if
it is leaking, as has been alleged in the past by numerous
entities. This information will be available shortly. In any
case, if the sewer is needed for local drainage, then it will be
rerouted from under the landfill and the portion that is
currently under the landfill will be permanently sealed. If it
is determined that the sewer is not needed for local drainage,
then it will be permanently sealed. Therefore, this potential
migration pathway will be eliminated as a portion of the remedy.
EPA has requested in the past months information regarding the
community allegations regarding perforations in the sewer line
and has not received any information to date. If there is any
information that residents would like to provide EPA, please do
so as soon as possible. .
16. Several commentors have stated that the site's southern
portion is not fenced and trespassers have easy access to the
site from this direction. These commentors also stated that the
fences were not signed properly to warn people of hazards posed
by the site.
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8
u.s. EPA response 16: U.S. EPA agrees that a fence is needed
along the southern site boundary. EPA directed the site Steering
Committee to construct a fence in this area. The fence
installation is now complete and proper warning signs have been
placed on this new fence.
17. A comment or asked whether air emissions off of the Waste,
Inc. Landfill were violations that would be subject to
enforcement.
u.s. EPA response 17: Air emissions from the landfill could
theoretically violate the Clean Air Act, if releases of
sufficient quantities of specific hazardous air pollutants were
detected. Also, the failure to report releases of greater than
the "reportable quantity" of any hazardous substance or extremely
hazardous substance could violate section 103 of CERCLA.
Detection of any such violation would require monitoring
equipment which is not in place at the site~ However, even were
violations detected, such violations would be chargeable to the
owner or operator of the landfill. As discussed above, levying
fines may prove futile because Waste, Inc. is bankrupt and the
landfill has been inoperable for over a decade.
CERCLA gives u.s. EPA the authority to deal with air emissions if
they pose an imminent and substantial endangerment to human
health and the environment. The RIfFS conducted at the site has
not found air emissions themselves to be cause for concern.
Nevertheless, air releases will be monitored during construction
and any appropriate action needed will be taken. Once the
landfill is capped, any threat to human health or the environment
from air emissions at the site will be eliminated.
18. Several commentors supported total removal of landfill
materials as the appropriate remedy for the site.
u.S. EPA response 18: For a number of reasons, this is simply
not feasible. First, it is too costly - EPA has placed a letter
estimating what would be involved in total removal of the
landfill in the site repositories. Superfund requires remedies
to be cost effective. Second, it is dangerous to dig into a
landfill, because of the unknown nature of landfill contents.
Third, the volume of material to be removed is enormous and it
would be nearly impossible to find a facility to accept the
waste. Fourth, it would take an inordinate amount of time to
excavate the landfill. Fifth, during the long period of
excavation, residents would be exposed to the dust, smell, and
air emissions of disturbed garbage. Sixth, this material would
have to be trucked from the landfill, through the streets of
Michigan City, to be disposed of at an off-site location. All of
these factors make total removal a technically and
administratively infeasible choice.
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9
As is contained in the aforementioned letter, approximately
754,500 cubic yards of waste material would have to be removed.
Following excavation, the landfill area would have to be
backfilled, or filled in with clean soil. The total amount of
time estimated to perform these activities is 22 years, during
which trucks filled with Waste, Inc. waste would be travelling
through the streets of Michigan City to their ultimate
destination. The total estimated cost for all of these
activities is $241 million. The risks posed by the excavation
and removal activities are far greater than those posed presently
by the site.
~9. A comment or felt that EPA and the city of Michigan City were
trying to downplay the environmental problem.
u.s. EPA response 19: EPA cannot comment on the City's position
relative to the cleanup. EPA, however, has committed necessary
resources to expedite the site cleanup and the remedy selected in
this ROD will expedite the site cleanup. EPA has communicated
the risks posed if nothing is done at the site and has committed
large amounts of resources to see that the remedy is designed and
constructed as soon as possible. Finally, EPA has been very
supportive of community concerns and, along with the IDEM, is the
primary Agency responsible for moving the site through the
superfund process to where it is today.
E. Summary of comments regarding future citizen involvement in
the site remediation process.
20. Several commentors stated that once the ROD is signed,
citizen input will no longer be part of the remediation process
at the site.
u.s. EPA response 20: citizen input is always included as a
part of the Superfund process. This is highlighted at the Waste,
Inc. site by the frequent availability sessions and fact sheets
in the past and EPA's willingness to have residential wells
sampled at citizen request. EPA has also demonstrated a
willingness to listen by including the storm.sewer and on-site
storage tank and fencing near Trail Creek as a portion of the
selected remedy.
This will continue throughout the RD/RA process. Frequent fact
sheets and availability sessions will exPlain the design and
construction components of the selected remedy and will allow
citizens to comment on RD/RA activities. The RD/RA process
contains provisions for changes to the selected remedy, if
changes become necessary. Major changes, such as changes in
technologies or selected alternatives or the acquisition of new
data that change a fundamental understanding of the site, are
required to be resubmitted to the public for comment.
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10
EPA has demonstrated a willingness to listen and take actions,
when appropriate and within their authorities. This working
relationship will only improve with time.
F. Summary of other questions regarding the site, not related to
the proposed remedy.
Although EPA is not required to answer questions on issues
unrelated to proposed remedies, in the interests of fostering
good community relations and furthering the recent progress made
in communicating with area residents, EPA is providing answers to
these questions in this summary.
21. A commentor asked why there was no public notice for the
consent order when it was released in 1987.
u.s. EPA response 21: EPA has responded to this question several
times in the past~ For the record, EPA Region 5 policy is not to
public notice consent orders unless community interest indicates
otherwise. At the time the consent order was released, EPA was
not aware of the level of community interest at the site.
However, when residents complained about the lack of opportunity
for public comment on the consent order, EPA then asked for any
comments. None were ever received. EPA is continually
reassessing their community relations efforts and results at
Superfund sites and at the beginning of remedial design, the
community relations plan will be revised to accommodate all that
has been learned about the community since 1987.
22. A commentor asked how EPA could void a state Order that
required the site owner to construct a hydraulic cut-off wall as
a component of site closure.
u.s. EPA response 22. EPA did not void the order. The state of
Indiana issued this Order to the site owner, who then declared
bankruptcy. Because it was issued by the State, they had
jurisdiction to enforce it. Because the site owner declared
bankruptcy, they could not enforce it. In 1985, Judge Kickbush
issued an order declaring the site an imminent hazard, and also
declared that the respondent did not possess the financial
wherewithal to respond, therefore, a receiver was appointed.
SUbsequently, the Indiana Attorney General stated that all legal
remedies had been exhausted and that the practical use of a
receivership was limited for remedial response. The order was
not carried out because there was no viable party to comply with
it. The site was then referred to EPA to be addressed under
c~c~.
It should be noted that EPA's remedy will remediate the Waste,
Inc. site. The RIfFS was funded by Potentially Responsible
Parties (PRPs) and EPA will pursue those companies, as well as
those others who have been notified of potential liability in the
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11
past, to fund the cleanup. The site owner/operator has also been
notified of his potential liability with regard to environmental
contamination at the site and will be pursued in the same manner.
In response to a question at the February meeting, the site is
not being cleaned up for the former owner-it is being cleaned up
to mitigate unacceptable environmental risks. Deed restrictions
will be placed on the property limiting future use of the
property as a portion of the remedy.
23. A commentor asked for a Natural Resources Damage Assessment
(NRDA) to be performed for the site, as well as wetland
mitigation for 160 acres for the 10 acres filled in by the dump.
U.S. EPA response 23: The authority for completion of NRDA's
lies with IDEM, the Indiana Department of Natural Resources, and
the U.S. Department of Fish and Wildlife. They are required by
law to perform these at Superfund sites. Details of the
assessments, such as the public comment that described an example
for another site in Maine, are left to those Agencies. If
citizens are not happy with the progress of assessment
completion, EPA urges them to contact the appropriate Agencies.
24. A commentor referenced the Technical Assistance Grant
process at the site and the fact that the guidelines kept
changing over time, making the application process more
difficult.
(TAG)
U.S. EPA response 24: The TAG process was designed to assist
communities with their understanding of the Superfund program.
The guidelines for completion of the TAG application have,
indeed, changed -over the years that TAG has been in existence.
The guidelines have been changed by our Region 5 TAG coordinator
to make the completion of the TAG application easier. EPA Region
5 records show that, in the past, a group expressed interest in
applying for a TAG grant but never completed the application.
This year, several groups expressed interest in the TAG grant at
the proposed plan meeting, but, to date, have not completed their
application, despite repeated attempts by EPA to assist in the
process.
25. A commentor stated that the adjacent site should be included
in the site cleanup because of similar characteristics.
U.S. EPA response 25: The information in EPA's possession
regarding the adjacent site, Lake Aluminum, does not indicate
that it has similar characteristics to the Waste, Inc. site.
According to written responses from the former owner, the
adjacent business used the western portion of the Waste, Inc.
property primarily for storage. However, EPA will continue to
gather information regarding this property as a part of the
remedial design activities and if additional information should
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12
indicate a link, then EPA can pursue the link at that time. EPA
continues to urge the community to indicate what information they
are referencing so that EPA can investigate the matter promptly
and efficiently.
26. A commentor stated that EPA include all information
regarding the PRP status of Waste Management, the entity that
bought the assets of Waste, Inc. in 1982.
u.s. EPA response 26: EPA has since sent a letter noticing
potential liability to Waste Management, dated February 25, 1994,
and the company will be noticed of their potential liability for
remedy implementation negotiations in the same manner as the
other PRPs.
27. A commentor stated that long term monitoring of the
downstream Confined Disposal Facility (CDF) should be included as
a portion of the selected remedy because it contains sediments
that have been impacted by site contaminants.
u.s. EPA response 27: Superfund jurisdiction does not allow for
long term monitoring of the CDF to be included as a portion of
the site remedy unless it can be conclusively proven that it
contains sediments that have been proven to be impacted by the
site. There are many point and non-point source discharges to
Trail Creek so that identifying sources of contaminants in Trail
Creek is difficult, at best. However, EPA will look into this
matter further and communicate any findings to local residents.
28. A commentor stated that the Superfund process at the Waste,
Inc. Landfill has been closed and secretive.
u.S. EPA response 28: EPA disagrees with this statement. There
have been at least six availability sessions, two public
meetings, and numerous fact sheets that have been released to the
public over the years, announcing site progress. EPA has also
sampled residential wells at citizen requests, as well as
installing fencing and signs at the site for security purposes.
EPA extended the public comment period twice, at citizen
requests, to allow for more time to prepare comments on the
proposed plan. EPA also set up an information repository at the
Bethany Bible Baptist Church at the request of local residents.
EPA will continue to keep the public informed on site progress
and solicit and answer questions throughout the RD/RA process.
This is the most important time as the site remedy will be
designed and built, so that the environmental problems posed by
the Waste, Inc. site can finally be addressed.
29. A commentor stated that the EPA was willing to allow
substandard remedy at the site, which demonstrated EPA's
insensitivity to the issue of environmental justice.
a
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13
u.s. EPA response 29: The selected remedy is the most effective
remedy for remediating the Waste, Inc. site. The remedy will
prevent direct contact with landfill contents, prevent the future
off-site migration of groundwater contaminated by the landfill,
address the on-site sewer and underground storage tank, provide
for site access restrictions and deed restrictions for future
land usage, provide for long term monitoring of the remedial
action with provisions for actions to be taken if the remedy is
not performing at maximum efficiency, and provide signs warning
residents of "potential hazards at the site as well as fish
advisory signage along Trail Creek.
EPA has selected a standard municipal landfill remedy to be
implemented at the site and is confident that the selected remedy
will control or eliminate the risks posed by the site.
The issue was also raised that because the site is located in a
poor minority community, it is not receiving equal opportunity
for community involvement. The Waste, Inc. site community is
afforded the same opportunities for public involvement as are
offered at all Superfund sites. This is required by the
Superfund law. At the Waste, Inc. site, community involvement
has actually been far greater than what is required by the
Superfund law. This is due to community interest, which EPA has
responded to over the years.
30. A comment or stated that EPA should talk to the unnamed
neighbor who lives immediately adjacent to the site as soon as
possible.
u.S. EPA response 30: Dave Novak, site community relations
coordinator and Dion Novak, site project manager, talk~d to the
neighbor, Shelley Piotrowski on March 9, 1994 and answered
questions relating to the site cleanup. She indicated at that
time that she was satisfied with EPA responses. IDEM and IDOH
have also contacted her.
31. Commentors were grateful that the site is to be finally
cleaned up and want the best solution possible.
u.s. EPA response 31: EPA appreciates the positive comments
received in writing and at the meeting that support efforts to
remediate on-site contamination which will reduce risks to
acceptable levels. EPA will continue to work with the community
so that the remediation process is as quick and easy to
understand as possible.
The comments are paraphrased in order to effectively summarize
them in this document. The reader is referred to the public
meeting transcript which is available in the public information
repositories, which are located at the Michigan City PUblic
Library, the LaPorte County Health Department, and the Bethany
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Bible Baptist Church.
regional office are on
these written comments
repositories.
14
Written comments received at EPA's
file in the Region 5 office. A copy of
has also been placed in the aforementioned
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JOCt
om
----
----
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U.S. EPA ADMINISTRATIVE RECORD
WASTE INC. SITE
MICHIGAN CITY. INDIANA
ORIGINAL
08/05/94
~!JTHOR
------
L',B. EPA
Puchalski. C.. U.S.
EPA
Nieder~an~. N.. U.S.
EPA
~dals. v.. U.S. EFA
~ovak. D.. U.S. EPA
Saker R.. I DE~
ER"-North Central.
Inc.
Novak. D.~ U.S. EPA
ER"-North Central.
!n~.
~eele~ C.~ ~ildlan.
Harrold. Allen &
Dixon
P~chalski! C.. U.S.
EPA
Baker. tI.. iDE"
;mpwn
..--------
...--------
Keele. C.. ilildlllan.
Harrold, Alien «
Di10n
~dals. J.. U.S. EFA
Niederqanq! N.. U.S.
E?A
8;11. R.. ERN-North
:entral. i~,C.
Novak. D.. U.S. EPA
U.S. ErA
Ball. R.. ERM-North
Central. Inc.
u.s. EPA
Puchalski. ~.. U.S.
EPA
Keele! C.. Wildman.
Harrold. Allen &
Dixon
Novak. D.. U.5. ErA
Lentzen. T.. Metcalf Ncvak. D.. U.S. EPA
,~ EddY. Inc.
TITLE/DESCRIPTION
-----------------
-----------------
.. State.ent of Work
Cayer Letter ForMardir.q Various 6uidance
:acuments re: the ~ork Plan (UNSISNED)
Transmittal Sheet ForMardinq Mini GAPP for
Revie~/Comgent/AoDroval
~elorandul re: Hooroval of Short For~ gAPP
'ar the Surface Water and SediBent 5amolino
."0 AnalYsis
~=tter re: U.S. EPA's ana IDE~'s Loaments Gf
t"e Surface Nater/Sediment SalDlinq of Trail
Creek (UNSIGNED]
Letter re: IDE"'s CO.lents Concerning the RI
Wark Pian
ijork Plan: Surface ~ater and Sediment
Saloling Phase
Letter re: Aooroval M/Changes of the Nort
Plan for the Surface Nater and Sedilent
Saluling Phase of the RI
~orK Plan: Surface Nater and Sedilent
Salol ino Phase
~etter re: Section XIVIA] of the
Adlinistrative Order b¥ Consent and Reouest
for a 30 Dav Extension for Subaittal of the
Draft Work Plan
Latter re: Resoonse to Juiy 9. 1987 Letter
Cuncerninq Section XIViA) of the
Adlinistrative Order by Consent and Reouest
f~r a 30 Day Extension tor the Submittal of
the Draft Work Plan
Latter re: IDEM's COllents on the Julv 20.
1987 Draft Work Plan
Latter re: Technical Evaluation of the Draft
Work Plan
~R
PAGES
-----
.,.,
....
.,
..
25
8
7
77
'1
..
.,~
; ~
.,
..
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~
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4
-------
JOCI
:",,'TC'
.1"""10..
----
----
14
09/09/87
, c
,i...,
09/10/87
-',j
~)9/21/87
~7
09127/87
'0
""
10/06/87
'0
! ,
10/16187
:0
1:/00/87
~1
11/00/87
""
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11/06/87
"~
....'
11/ 13187
24
12/04/87
"c
.....'
01/06i88
"'
.0
(11/08/88
".,
.1
01112/88
28
01/28/88
29
03/15/88
~UTHOR
------
Novak. D.. ~.S. EPA
Niederganq.
:?A
N.. U.S.
r;Qvak. D.. J.S. EFA
ER~-North Central.
In c.
Adals. J.. U.S. EPA
~ovak. D.. U.S. EPA
:J.5. EPA
Jacobs Enqineerinq
GrouD j nc.
U.S. EPA
NavaL D.. U.S. ErA
Ball~ R.~ ERH-North
Central. Inc.
Keele. C.. Wildllan.
~arrold. Allen &
Dixon
Baker. R.. IDEII
Hudak~ D.~ U.S. 001
Novak~ D.. U.S. EPA
Keele~ C.. ~ildlan.
Harrold. Allen ~
Dixon
PESIPIENi
---------
---------
Ball. R.. ERH-North
Central. Inc.
Adams. J.. U.S. ErA
3a:1. R.. ERN-North
Central. Inc.
U.S. EPA
Niedergang. N.. U.S.
EPA
Ball. R.. ERII-North
Central. Inc.
P~blic
U.S. E?A
Public
Ball. R.. ERII-North
CentraL Inc.
Novak~ D.. U.S. EPA
Puchalski. C.. U.S.
EPA
Novak. D.~ U.S. EPA
Novak. u.. U.S. EPA
Ball. R.. ERII-North
Central. Inc.
Puchalski. C.. U.S.
ErA
r;TLE!DESCRIPTION
-----------------
-----------------
Lstter re: U.S. EPA and IDEII'~ CO~lIents
C:ncernino the RIfFS Work Plan
Transmittal Sheet Forwarding the QAPP for
Re¥lewiComment'AoDravaJ
Letter re: Inclusion of Prcoerty on Eastern
8cundarv in RI'FS
Technical lIeloranaul 12: Surface ~ater and
Ssdi.ent Sallollng Phase of RI
Memorandum re: Quality Assurance Section's
Review of the Draft GAPP
Letter re: Co;ments on the Draft Technical
~emorandulII .1
Fact Sheet: Lang Ter~ Investigation Planned
rinal Community Relations Plan
News Release: Announcement of Nove.ber 18.
1987 Public "eeting
Letter re: Issues Raised at the October 2.
1987 ~eetinQ Concerning the Natural Resource
Trustee
Letter Forwarding the RIfFS Nork Plan
HfAnnotated Attachlent
Letter Confirling the Januarv 5. 1988
Teleohone Conversation re: Steerino
COI.ittee's Agreement to Exoand the Scooe of
the RIfFS
Letter re: IDEII's COllents on the Novelber 2.
1987 Work Plan wiAttachlent
Letter re: U.S. OOI's COllents Concerning the
rroDosed Work Plan
Letter re: U.S. EPA's CO.lents on the Draft
Workolan wiHandwritten Annotations
Letter re: Cancern over U.S. EPA Release of
infor.ahon
"
..
~A6ES
-----
f ,~
91
.,.
.,
..
4
26
14
"f
4
.,
..
8
,,)
-------
",--:ra
.. ..'..'If
~~;E
----
----
30
('~!l6/88
"
. .
(;4/15/88
"~
~'"
(i4/20/88
..
O~!03/88
34
05/03/88
:'5
i)5/13/88
,jO
05/16/68
"1
,~, ,
(l5m/ss
38
f;~!24/88
.39
OS/26/88
40
06/01/88
41
06/06/88
42
06/06188
43
(I.S/13/88
="i}THOP.
------
Gasior. L.. U.S. EPA
8011. R.. ERH-North
Cemtrai. I!ic.
3eaucnalllo. Joo r DEI'!
5ail. R.. ERH-North
Central. Inc.
Hudak. Coo U.S. DOl
~~:clor.e. ~.. U.S.
EPA
Baker. Po.. I DEli
Kratzllever ~ J..
~etcalf & Eddy, Inc.
Nova~. D.. U.S. EPA
'ECIPIE1H
---------
---------
~ichiaan Cit, P~blic
~ibrarY an.d Larcrte
Ca. Health Deot.
:iovak. :I.. U.S. EPA
Carrasouero. P..
IDE~
Novak. D.. U.S. EPA
Novak. D., U.S. EPA
Novak. Coo U.S. EPA
Novak. u.. U.S. EPA
NDvak~ D., U.S. EPA
Ball. R., ER~-North
Central, Inc.
~ITLE!~E5CRIPTIQN
~m:s
-----------------
-----------------
-----
Letters For~ardir.c COJies of the Surface
water and Sediaent Samollng Reoort iU~SI6NED)
Letter Forwarding CcaouChel's COllents re:
Statements ~ade in U.S. EPA Memo OT December
18. 1987 Concerning Organlc Data Re:ults
Memorandus re: the Nork PIa..
Corrected Data Package frol COlouCheD
Laboratories wiCover Letter
28
Letter re: U.S. DOl's Coslents on the March
22. 1~88 Wort Plan
Me;oranduI: Reoly to Laboratory Resoonse
Regardin9 5e SDi~e Recovery Dated Acril 5.
1988
Letter re: IDE"'s COllents or. the ~arch 22.
1988 lIork Plan
Letter re: Alternative SDil Sa;DlinQ Progral
Letter re: U.S. EPA and IDEII's COI;ents on
the RIIFS lIork Plan w/Handwritten Annotations
6asior, A.. U.S. EPA "ichi~an City Public Letters Forwardin~ Additional Cooies of the
Library and LaPorte Surface Nater and Sedilent 5alolin~ Nork Plan
Co. Health Deot. iUNSISNEDI
Keele, C.. ~ild;an.
~arrold. Allen &
Dixon
Novak. D., U,S. EPA
Churilla, P., U.S.
EPA
Novak. D.. U.S. EPA
Ball. R., ER"-North
Central. Inc.
Novak, D.. U.S. EPA
Ninnin~ha.. B.. IDEK Carrasouero, P..
IDE!!
?
.
Letter re: Notification of Receiot of U.S.
EPA COGlents on the Draft Nork Plan
Letter in Resoonse to Aoril 15. 1988 Letter
re: the Qaulity Assurance Review of the Trail
Creek Saloling Results
Meiorandul re: Or~anic Data Results
Meiorandul re: HYdrogeologic Review OT the
~arch 22. 1988 Revision of the Nor~ Plan
3
-------
~sc#
:.,: TE
::')THOf'
~E:!PIENT
~:;LE/DESCR!Pir~N
P~6ES
----
----
------
---------
...--------
-----------------
-----------------
-----
4l
';6i20i88
l:e21e~ c.. ~ildman.
~arrQld. Allen &
Di.::on
~IQ...aL D..
U,S. EFA
L:tter re: Anticiaated Areas
for the June 22. 1988 ~eetlnq
07 DisCUSS10ll
~
..
J:
.:'27/88
fRM-North CEntral.
r~"
..01",
'.'.S. EPA
T:chnical Memorandum '1: Surface Water anD
Sediment Samoling Phase ot RI
58
16
:'~"J(i/8B
U.S. ErA
Public
~act Sheet: Uadate
.
47
::;" /1)7/88
Hudak. D.. U.S. DQ!
NQvai.~ D.. U.S. EPA
Letter in Resoonse to Reouest for Bioassay
Information
.~
~8
:)'/11/88
,Jordan. S.
Carrasouero. p..
:~EI!
Letter Forwarding Attached .Re~oval and
Disoosal of Used UnderQr~und Petroleum
Storage Tanks' Reoort
q
,L'.'
49
<;~ /12/98
Novak. D.. ~.S. EPA
B311. R.. ERM-North
Letter re: Biological Studies to be PerformeD
During the R! and Screening/Soil Samolin?
Central. Inc.
s (~
-:,-!~3i88
G2sicr.
H.. 0.S. EPA
Mi:hiqan Cit, Public
Library and LaPorte
:0. Health Deot.
Letters Forwardir.g Cooies ot ie~hnical
Memorandum 11: Surface Water and Sediment
Samolinq (U~S!GNEDj
i.
"
".
08/00/88
ER~-North Central.
Inc.
U.S. EFA
Data l'Ianagellent Plan for the RI/FS. Revision I
28
~~ ;)8/(11/88 NavaL D.. "c EPA Bcll. R.. ERI'!-North Letter re: Disoosition of the Remains from
...L u,oJ.
Centra 1. Inc. the June 1986 Trail Creek SaDDling Event
~3 ')8/02/88 Sasior. A.. U.S. EPA l'IichiQan City Public Letters ForMarding CODies of Technical ~
L
Library and LaPorte Mellorandum '2: Surface Water and Sediment
Co. Health Deat. Saloling Studies ,UNSIGNED)
S4 08/22188 ~a'fka~ lol,. I ~: EPA ~dafDs. J.. U.S. EPA Translittal Sheet Forwarding the GAPP for
..:.....
Review/Comment/Aooroval
~~ (,9 (:')6/88 gdals. J.. U.S. EPA I'!ayka. T U.S. EPA r,ellorandul re: Gaulity Assurance Section's 8
.\-.J u..
RevieM of the GAPP. Revision '
.
56 .)9! 16/88 Baker, R.. IDE!! Novak. D.. U.S. EPA Letter re: IDE!I's Comments on the Draft Nark
Plan. Revision ~
~
57 (;9/22/88 Novak, D.. U.S. EPA Ball. R.. ERI'!-North Letter re: COlllents Concerning the Nork Plan
Central. Inc. for the RIfFS (UNSIGNED)
~o 1 G /25/88 Baker. R.. IDEI'! Naval:, D.. U.S. EPA Letter re: IDE"'s Comments to the August 1988 ~
..''..I
Draft Wor~. Plan
4
-------
:~:t
:I~T::
: ~;THOR
::EC rF J ENT
...---
...---
------
---------
---------
:9
U.S. EPA
Keele. C.. ~ild;an.
Harrold. Ailen &
Di~on
10.'26/88
'!,',aL D..
:0)
1').'31.'88
Canada Ccmmunity
I~prove!ent Society
E'ianey. H.. Ja;:obs
E~gineering Braue
. ....1
61
11/09/~8
'eele. C.. 4ildl!an~
Harrold. ~Ilen &
Di~on
U.S. E?A
~;cvaL D..
.."..
lU16/S8
N~Var.. D.. U.S. EPA
Keele, C.. Wirdman.
~arrold. Alien ~
Di:,:en
63
Novak, D,. U.S. EFA
Keele. C.. Wild;an.
Harreld.,Allen t
~l/28/8B
i,.~lXOr;
-~TLE!JE3CRIPr!Cfl
~A6E5
-----------------
-----------------
-----
Letter re: Ba;:korcund 53mole5. Geoloqic
~escr.oticns af Soils. ana Boring Deaths
~
..
L2tter >orw3rdlnc Inror;aticn re: Waste. rn;:.
3~oerfund Site rUNSJ6NEDI
Letter re: Steerlr:q Committee's Resoense to
Seotember 22. 1988 U.S. EFA Letter Concerning
:~e Nork Plan wiAttachment
Letter re: U.S. EPA's Comments on the Revised
~Drk Pian
,
..
Letter Forwardinq Attached IDE" "emorandul
re: Leachate 83;01ing {UNSIGNEDI
~4 12,'00/88 U.S. EPA Public Fact Sheet: Uadate 2
65 12/16/88 ER"-North Sentral. IJ.S. EPA Health and Safetv Plan fer the RI/FS, 44
inc. Revision 2
66 12/16/88 ER"-North Central~ U.S. EPA SalDling and Analvsis Plan ,for the RI/FS. 59
Inc. Part i: Field SalDlinq Plan: Reyision 2
67 12/16/88 ER"-North C2ntral~ !j.S. EPA SalDlin~ and Analysis Plan for the RI/FS~ 455
!iIC. ~art Jr: Quality Assurance Project Plan:
Revision 2
,8 12l16/88 ER"-North Central. U.S. EPA Work Plan for the RifFS. Revision 4 160
Inc.
:9 12/19/88 Sould. 11.. U.S. EPA Adals. J.. U.S. EPA Trans.ittal Sheet FOfNarding the QAPP for
Review/Collent/ADoroval
7(1 01/03/89 COIDuChel Laborator- U.S. EPA COlouChe.'s ResDonses to Quality Assurance 3
ies Section's Callents on the GAPP
71 01/03/89 Ada.s. J.. U.S. EPA lIayh. J.. U.S. EPA Meiorandul re: Quality Assurance Section's 18
Review of the QAPP. Revision 2 w/Attachlents
72 oH/l2189 Novak. D.. U.S. EPA Ball. R.. ER"-North Letter re: U.S. EPA COllents on the Work Plan ~
"
Central. 1I1C. and QAPP (UNSIGNED)
;..' ,}1 i 18/89 9aker. ft.. IDE" Novak. D.. U.S. EPA Letter re: IDEM's COllents on the Wort Plan
;.~d QAPP
-------
::::#
~!JTHOR
,~E~IPr~~~T
~'~. t
----
---------
---------
----
------
74
01/24/89
Saker. R.. rDEr1
Novak. Dt. U.S. E?A
"5
;)2/09/8°
Sould. M.. ~.5. EPA
;dalls. J..
!1.S. EPA.
''-i
1)2/17/89
M;"y'Ka. J.. U.S. EFA
1'1"1 "'''',''
~.~. trH
~daRis. '
. .
02i23i59
Ball. R.. ERM-North
Cantral. Inc.
Novak. D.. U.S. EPA
78
')2/28/89
Beck~ J.. u.S. EPA
:harv ~ L..
EnviroMental
Strategies ~
Consul ting
'q
r,4i26!89
90uld. M.. U.S. EPA
Adams. J.. U.S. EPA
30
05/03/89
Niedergang, N.. U.S.
EPA
Jones. 'i.. U.S. EPA
81
05/08/89
8all, R.. ER"-North
Central. Inc.
Novak. D.. U.S. EPA
j!T~E!DESCR!FT!0~
-----------------
-----------------
Letter ~orMaroir.~ Attached Lea~hate and
Sediment Samoling Results
Tr;nsmlttal Sheet ForMardino the UAPP f~r
RevieM/Ccmaent/HDcroval
Memorandum re: Quality Assurance Se~tion':
CaQlents on t~e GAPP. Revision 3
Letter re: Revisions to the Ooerations Plans
and Comments on the QAPP
Letter re: Concerns of the Waste In~. Clean
Uo C~alition (UNSIGNED)
Transmittal Sheet ForMarding the GAPP for
RevieMiComr.entiAooroval
Meiorandul re: Monitoring and Quality
Assurance Branch': Conditional Aooroval of
the gAPP w/Attachlent
Letter ForMarding U.S. EPA Nelorandul
Conveving Conditional Approval of the GAPP
(uNSIGNED)
?AGES .
-----
10
: ~
"
"''1'
;'.'
82 06/00/89 U. S. EPA Public Fact Sheet: Voda te . 6
83 06/09/89 Sasior. A.. U.S. EPA Nichigan City Public Letters ForMarding Co Dies af the RI/FS 3
Library ~ et al. iUNSI6NED}
84 06i29/89 Anderson. Novak. D.. U.S. E!lA Questionnaire re: Work Plan and Partial Work 14
Plan N/Attachlents
8S 06/29/89 Chary ~ L.. U.S. EPA Questions far U.S. EPA's Public "!Joen House" 2
Environaental
Strategies &
Consul hng
26 07/05/89 ~~ovak. D.. U.S. EPA Chary. L.. Letters ReQuesting Background Inforlation -
Environ;en tal tUNS IGNED I
Strategies ~
Consultants: et al.
27 07/06/89 Naval:. D.. U.S. EPA Ball. Roo ERI!-North Letter re: StartuQ of Fieldwork (UNSIGNED)
Central. Inc.
..
-------
C',jCt
----
:i:TE
----
,,..
'.J'~
i; 7 /06/89
89
07/12/89
9'~
(;7! 14/89
91
07/17/89
~2
Oi/20/89
~~
1.J
07125JSq
94
07/31/89
9S
08/10/89
96
08/11/89
qj
08/11/89
98
08/15/89
99
08/18/89
;!JT~OR
------
~a¥a[. ~., U.S. ErA
U,an. L..
Environ;entai
Strateqies ~
Ccmsul ting
NovaK. D.. U.S. ErA
Sa 11. R., ER:H~orth
Central. In::.
Anderson. T.
8all. R.. ER"-North
Central. In:.
Beck. J.. U.S. EPA
~ECIPrENT
---------
---------
!:intzele. J.:
3aldMin. J.: and
~isellan. 'J.
~ovaK. ~.. U.S. E?~
Chan, L..
Enviror.~er.tal
Strat2qies and
Consulting
~ovak. D.. U.S. ErA
~ovaK. D.. U.S. EPA
Novak. D.. U.S. ErA
Chary~ L.. Waste
Inc. COI.unity Graue
Anzia, ".. ERft-North Novak, D.. U.S. EPA
Central. Inc.
Novak. D., U.S. EPA
NovaK. D.. U.S. EPA
Novak. D.. U.S. EPA
Beet. J., U.S. EPA
Anderson. T.
Chary. L..
Environlental
StrateQies !
Consul ting
SaIl. R.. ERft-North
CentraL in::.
Chary. L..
Envirnl!ental
strategies ~
Consul tinQ
TfTLE!DESCRIPTION
-----------------
-----------------
Letters Re~uestina 8acKaround Ir.torllatian
: :JNSI6NED)
L:!!er re: ~om;unl,v ~oncerns w/Juiv 16. 1989
Addendum Cancerning the Consent Order
Letter Reouesting COlsents re: the Consent
Order
Letter re: Schedule for Initial RI Activities
Letter P.esDondina to U.S. EPA Letter of July
5. 1989 re: the ~orK Plan
Letter re: Collection of Soil SalDles ano Use
of Steel. 55 Gallor. Drums. ~ithout Plastic
Liners w/Attachment
Conversation Record re: CO.lunitv 6rouo's
Reauest to Receive. COI.ent. and Discuss
Technical fteuoranduis M/Attached
CorresDondence
Letter re: Sail 5creeninQ Pragram
Letter re: Answers to Questions Given to the
U.S. EPA at the June 29. 1989 Availability
Session (UNSI6NEDI
Letter re: ResDonses ta Questions Provided at
the June 29. 1989 Availability Session
fUNS r SHED)
Letter re: U.S. EPA's CO.lents an Technical
~elorandul 13 rUNSI6NEDJ
Letter re: Community Relations iUNSI6NEDI
°AGES
-----
'J
-
-
..
7
4
2
-------
:~Ct
:':TE
----
----
100
1),3 i 22/ 89
'(d
- .- ~
1:8/28/89
~.i)2
.::c "07 /B9
:':3
/1108/89
,04
;"10 t.~/CO
,',;."/1.11
: '~!5
":~9 /22/89
~i)6
':'9/27/89
107
(:9/27/89
lOB
')9/29/89
109
10/04/89
110
1')/10/89
111
10/11189
112
:0/13/89
113
10/25/89
114
l1i03/S9
~:_:TYOR
.. -----
Ball. R.. ER~-North
S~ntral. Ir;c.
B:ker. Roo lDE~
?all. R.. ERM-North
Central. Inc.
9all. R.. ER~-NDrth
Central. Inc.
Boll. R.. ER~-North
Central. Inc.
?:Il. R.. ER~-North
Central. I"c.
~iEher. D.. !DE~
Edl4ards. D. ~
ER~-North Central~
Inc.
Ball. R.. ERH-North
Central, inc.
Ball. R., ER"-North
Central, Inc.
Fisher. Doo IDEM
Baker. R.. IDEII
Novak. D.. U.S. EPA
Baker. R.. IDEH
Ball. R.. ERII-North
Sentral. In:.
PEcrprE~~T
---------
---------
Ncva~. ~'..
"= C:)'
:.J.'W' ~I H
Novak. .,.
::0'"
'.,j ,WI ~,H
~iovak. ..,
~ IS. t:.rH
Novak. D.. U.S. ERA
Novak. D.. U.S. EPA
Novak. D.. v.~. EPA
Novak. D.. U.S. ERA
Novak. D.. U.S. EPA
Novak, D.. U.S. EPA
Novak. D.. U.S. EPA
Novak. D.. U.S. EPA
Novak. D.. U.S. EPA
Ball. R., ERII-North
Central. Ii1::.
Novak. D.. U.S. ERA
Novak. D.. U.S. EPA
"IiLE/DESCRIPTION
-----------------
-----------------
Memorandum re: Soil Screenin9
Letter r~: jDE~'s Comlents on Technical
i'!er,;oranduill #3
Letter Forwardino Attached Mao Shewing the
Pro Dosed Locations of Piezometers
Letter Enclosino Seil Screening Results. Soil
Screening Boring Locations. and Frooosed Soil
Salolino Locations
Disoosition of U.S. EPA CO;lents at August
15. 1989 re: Technical Memorandum .3 and
Cccies of Water Well Records MiCover Letter
Letter re: Procedures for the Drilling and
Samoling Programs
Handwritten Me;orandu. re: IDEH's Review of
Soil Screening Results wiAttachlent
Letter re: Analytical Results tor ~ichigan
City ~unicioal Water Supalv
Letter re: Proaosed Location 01 BackQround
Soil Saaole
"eiorandul re: Soil SaiD Ie LocatiDns
~andwritten lIelorandul re: IDE~'s Reviel4 of
Technical "eftorandul 13
L~tter re: iDEII's Review 01 Soil Screening
Results
Letter re: U.S. EPA's CO.lents on Technical
~e.orandu. 13 (UNSIGNED)
Letter re: IDElI's Review 01 Technical
Heiorandul 13. Revision I
Letter Forwarding Attached October 13. 19B9
Discosition on U.S. EPA Comments re:
Technical ~elorandul '3. Revision 1
8
P~5ES
-----
,
..
"
i.
"
29
11
"
i.
,
..
,
"
"
i.
-------
:'~Ct
C'4Tc
----
----
: 25
ilf03/89
:16
~1f22/B9
1 ~ .,
..J
~ 1/22/89
118
11i27J89
119
11/27/89
120
12/00/89
,."
......
12/04/89
1"'~
I...
12/11/89
123
12i21lB9
124
01/03/90
125
01/08/90
I~L
..~
02/01/90
t"7
....,
02/07fCiO
1 ~O
...\.1
02/08/90
129
02/15/90
'::!JTHOR
------
~P.~-North Central.
i!iC.
B~]l. R.. ERN-North
:entral. Ir.:.
~Jva~. D., ~.S. EDA
Schafer. G.. U.S.
EPA
Ball. R.. and
Edwards. D..
:F.~-North Central.
!~c.
U.S. EPA
Sai 1. F:.,
ERrH~orth
Central. Ino:.
Frey, R., U.S. EPA
Baker, R.. IDE"
~:ECiPI:~1T
---------
---------
:J.5. EPA
~Qvak. D.. U.S. EPA
Ball. R., ER~-NDrth
Central. inc,
File
Novak, D.. U.S. EPA
Publil:
Novak. D..
1:"0'
W.WI 1.1 H
Ball, R.. ERM-North
Central. Inc.
Frey, R.. U.S. EPA
Gasior, A., U.S. EPA Addressees
Frev,
R., U.S. EPA
Frey. R.. U.S. EPA
Ball. R., ERM-North
Central. 1m:.
Frey, R.. U.S. EPA
Ball. R. and
Ed.ards, D..
ERM-North Central.
Inc.
Ball, R.. ERM-North
Central. Iilc.
Bail. R.. ERM-Ncrth
Central. Inc.
Novak, D.. U.S. EPA
Ball. R.. ERM-North
Central. Inc.
Frev, R.. U.S. EPA
-iTLEiDESCRIPTION
-----------------
-----------------
'echnlcal Memoranaum t3. Revision -
L.tter re: Deia, 0; Submlttal tor Tecnnica!
~e'!ioranduS! 14
~:tter re: RIfFS Schedule ~nd Technical
~elorandul #2 iUNSI6NEDi
~andwritten Review Comments re: Prooosed
~cnitoring Well Locations
~.tter re: Prooosed Monitorino Well Locations
~i~ttachments (Annotated)
"act Sheet: R! Vocate
~etter re: Reouest fer Er.tension of Submittal
~~te for Technical Meioranaul i4
Letter re: U.S. EPA's Aooroval of Reauest for
Extension of Tel:hnical Memorandul .4
Letter re: IDEM's COllents on the Prooosed
~onitoring Well Locations
Letters Forwarding CDoies of Technical
~elorandul 13 (UNSIGNED)
Letter re: U.S. EPA's Caalents on Prooosea
~onitoring Well Locations Report
Letter re: Resubmittal of Technical
~e.orandul 14
Letter re: Reauest for Extension of
Submission for the Prooosed Monitoring Well
ReDort
Letter re: Aooroval of Extension for
S~bmission of the Prooosed Monitoring Well
geDort
Letter in Resoonse to U.S. EPA's Comments o~
the Prooosed ~onitoring Nell Locations Reoort
9
'"AGES
-----
62
70
~
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2
3
6
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14
-------
Don ;~T: ~UTHOP ~ECrprE~JT
---- ---- ..----- ---------
---------
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1'",....
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131 ':;2/20/90 ......... EPA Public
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03/30/90
142
04/02/90
143
04/04/90
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04/17/90
~ead, C., Save the
0~nes CQuncll
P;stor. ~.. U.S.
U,S. EPA
EPA File
~ITLE'DES:P:PT:Q~
-----------------
-----------------
Technical RevieN of Te~hnical Memorandum i4
~!FebruarY :0. 1990 Cover Letter
News Release: Hnnouncement of February 28.
1990 AvaIlability Session
Letter re: Co;;unitv Relations
Memorandul re: February 28. 1990 Availability
Session
~artin. i:.. U.S. EPA Lesser. T.. U.S. EPA Kemorandul re: February 28. 1990 Ayailability
Session Trio Reoort
Frey. R.. U.S. EPA
'fortin. ':.. U.S. EPA
Read, C.. Save the
Dunes Council
Frey. R.. U.S. EPA
Frey, R.. U.S. EPA
Bater. R.. IDEI'!
F rev ~ R I .
U.S. EPA
Baker. R.. !DEI'!
Frev. R.. U.S. EPA
:;11. R.. ERI'I-North
Central. r~c.
Ball. R.. ERM-North
Central. ].,e.
Read. C., Save the
Dunes Council
Letter re: Delay in Providinq R~view CD;I~nts
on T~chnical "e.orandu~ 14 and Locations for
the ProoDsed Monitoring Well Network
~=ttEr re: Co;;unit, Relations
~artin. r..o U.S. EPA Letter re: CODlunity Relations
Ball! R.. ER"-North
Central, Inc.
Ball, R., ERM-North
Central. Inc.
Frev. R.. U.S. EPA
Ball. R.. ER"-North
Central. Inc.
Frey! R.. U.S. EPA
Bali. R.. ERM-North
Central. lne.
Frey, R.. U.S. EFA
Letter re: U.S. EPA's CO.lents on Technical
"eiorandul .4
Cover Lett~r Forwardin~ U.S. EPA's CO.lents
re: the Data Validation Results for the Soil
Sa.olin~ Activities in Technical Meiorandul
14
Letter re: IrE"'s Review 01 Technical
Meilorandul .4
Letter re: COllents on ProDosed Monitoring
1I1!1l Locations
Letter re: IDEM's CO..l!nts 00 the ProDosed
~onitorinQ Nell Locations for Tas~ II.
Revision 1
Letter re: U.S. EPA's Additional Comments on
the Pro Dosed Geotechnical Sa.Dlin~
Letter re: Monitoring Well Installation
10
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-----
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------
Bail. R.. ERM-Nort~
[sntra!. In:.
Ball. R. ~"d
:dwards. D..
ER~-North Cer.trai,
Inc.
ER~-North Central.
Inc.
9all. R., ERI'I-North
Centrai, rnc.
Bat.er. R.. IDEI'!
CRC Environ~ental
~anaQesent. In:.
ER~-North Sentral.
Inc.
Frey. R.. U.S. EPA
Frey, R.. U.S. EFA
Ball, R.. ERI'I-Ncrth
Centra!. Ine.
ERI'I-North Central.
1n(.
Ball, R.. ER~-North
Central. Inc.
Frey, R.. U.S. EPA
Edwards, D.,
ERI'I-North Central.
Inc.
:ECIPIENT
---------
---------
~~eY. P" ~.S. EPA
-rev. R," U.S. E?A
.J ,S. EPA
Frey. R.. U.S. EPA
Frey, R.. U.S. EPA
'J,S. EPA
'~ . w. EPA
Ball. R.. ERI'I-North
Central. Inc.
Ball. R.. ERI'I-North
Central. Inc.
Frey, R.. U.S. EPA
U.S. EPA
Frey, R.. U.S. EPA
Ball. R., ERI'I-North
Central. Inc.
Frey, R., U.S. EPA
Thomas. C.. U.S. EPA Frey, R.. U.;. EPA
~rTLE/DESCRIPTrGN
-----------------
-----------------
~;tter re: Extenslcn of Subsisslon rar
Technical Memorandul 14
~:tter re: Disoosition of U.S. EPA and IDEM's
Cc;lents on rroDosed ~onltorinq ~ell
~oeations ~iADoendices
Reoort: Proposed Monitorlnq Well Locations
for Task I r
Letter wiAttached Revised RI/FS Schedule
Letter re: IDE"'s COllents on Technical
Meiorandul #4, Revision 1
Technical Review of Technical "eiorandul #4.
Ri. Phase 1. T;s~ 2 wfJulv 2i. 1990 Cover
Letter
DisDositicn of U.S. EPA COllents on Technical
Melorandum 14, Revision,
Letter re: U.S. EPA's COllents on Technical
l'Ielorandum 14. Revision 1
Letter re: Technical "eiorandul 14 and RIfFS
Schedule
Letter re: ER"-North Central's CO.lents on T-
echnical l'Ielorandul 14, Revision 1
Reoort: ProDosed Scoee of Work Private Well
,nd Round Two MonitorinQ Nell Samoling
Letter re: Deletions and Modifications to
Technical "eiorandul 14. Revision 1
Letter re: U.S. EPA's COllents on Technical
l'Ielorandul 14. Revision 2
Letter ForwardinQ Coeies of the Prooosed
SeoDe of Nark for Private Well and Round Two
"onitoring Well SasolinQ
~e.orandul re: Technical SUDport Unit's
Ccalents on the Procosed ScoDe of ~ork for
Private Nell and Round Two l'Ionitorinq Well
Sasoling
11
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-----
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12
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'::/00/91 !: ~ EPA
-~'.J --'WI
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---------
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Ball. R.. ERM-North
C2iJtral. In:.
i=re¥. F:.. U.:. EPA
Ba!i. R.. ER~-North
Central. In:.
Public
Public
1~7 02107/91 Ball. R., ERP!-North Frey, P.. ~ U.S. EPA
...1.11
Central. In~.
168 (i2i19/91 Ball. R.! ERM-North F-"," t{ I ~ U.S. EPA
. - J' ,
Central. T~-
.111...
~69 ')3/18/91 ~n:ia. M., ERI1-North F rey ~ R.. U.S. EPA
Central. In~.
1'0 .:i3/25/91 Baker. R.. IDE!'! Fiev, R.. U.S, EPA
...t'.'
1 i ~ ':'3/31/91 lIa Hers. t" U.S.
... ..
EPA
ti'" '}4/22f91 Frey II R. ~ U.S. EPA
., ..
173 ')~,iObl91 Baker. R. ~ iDEI1
174 ")6/13/91 Frey, R.. U.S. EPA
~ieder~an~~ N.. U.S.
EPA
Ball. R.. ER~-North
CentraL In'.
.rev! R.~ U.S. EPA
Payne. D.. U.S. EPA
":TLEiDESCRlPT;JN
-----------------
-----------------
"~x Transmittal FQr~arding Attached
~andNritten Draft af Seoteaber 1990 Warr. Pian
Letter re: U.S, EPA and IDEM': C:maen!s on
~.:ooseo ScoDe of Work. Rouno 2
~=tter re: Prooosed Sceee of WQr~ ror Private
~ell and Round 2 Monitoring Well Samoling
w! Attact'lilents
Letter re: U.S. EPA's RevieN and Aoproval of
TEchnical "emorandus 14. Revislon 3
Fact Sheet: Technical Memorandul 14 Update
News Release: Announcement of December 13.
1=90 Availability Session
S~idance: 'Conducting Remedial
Inve5tigationsiFeasibilitv Studies for CERCLA
~uniciDal Landfill Sites8rEPAi540/P
91/001: QS~ER Directive 9355.3-11)
Letter re: Delays ir. Completing the RIfFS
~etter re: ProQosed Schedule for COloletion
of RI/FS Activities
Letter N/Attached Prooosed l1odification to
the RI ReDort Format
Letter re: Prooosed Modification of the RI
peoort Fori1at
Meiorandul re: Water Division's Review of the
FS ReDort
~2tter re: Proposed Modification to the RI
ReDort Forllat
~etter re: IDEM's Comlents on Technical
~elorandum 85
FAX Helorandus 'Forwarding Attached July 27.
1988 "Determination of Total Organic Carbon
:n Sediment" R~Dort
12
PAGES
-----
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'J.S. EPA
'}~rsar Ii,;.
Paker ~ R.. IDEM
~.j ore: :;es
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:rey. R.. U.S. SPA
184 !jQ/09/91 :a.i 1, 0 ERH-Narth Frey. R," I' C EPA
1\1' WI'oJI
Central. !".:.
:85 091W91 F rev ~ R.. n c EPA !;ddressees
.....101.
186
09/16/91
SteeLe. 6.. Indiana
State Board o~
Health
Baker. R.. IDE!!
-:~~E'~E~C~I~T!GN
;A6E5
-----------------
-----------------
-----
_=i:ter re: 0.E.
EPA's C~~ment5 on re~hnlcai
i..
,,,
"":!orc!idl,.HD #~
::nedule f~r Remainlng Tasks
_=:ter r~: Revision
1 ~~ Technical Memorandu~
11
:..~tter re:
=ub~ission of Draft RI qeoort
~:!orandum re: Reviseo DUE Date ~or RI Recort
~:tter re: ReQuest for E:tension far
Sub;ittal DT Draft RI Reaort
.'
U:~Qranaum iQr~ardinQ far Review thE Draft Rl
~;:ter of Tran~mittal FGrwar~inQ Attached
~eyiew of TEchnical "emorandul 15
6
LEtter re: IDEM's Review of Technical
~2lDrandul 15. Revision i
.,
..
Latter forwarding Attached Aooendices F and 6
~f the Baseline Risk Assesslent
~elDrandul Forwarding Six Pages to 02
Inserted into the Draft RI Reoort
1
~e.orandus re: ISBH's Review of the Risk
~ssesslent. Hopendices F and 6
~87 (19/17/91 Kleiman. 1 U.S. !=reY~ R. ~ U.S. EPA ~E!orandu. re: RCRA's Review of the Draft RI
\,i..
EPA ~eoort for ARARs
100 (l9/1S/91 FreY~ R.. II: EN Ball. R.. ERII-North Latter re: U.S. EPA's Co.aents on Technical 3
~'.I'..I ""'.w.
Central. Inc. !'Ie!lorandull i5. Revision 1
leq ':9/20/q 1 Maatus. II U.S.
...
EPA
:90 ;}9/23/91 Baker. R., !DE!!
Prosser~ K.. IDE!!
Frey! R.. U.S. EPA
~~tter re: Reouest for IDE"'s RevieM 01 the
;lternati,es Array Document and State ARARs
L.tter re: IDE~'s COllents u;, the RI Reocrt
ill/Attachments
1 ~
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Frey. R..
~.s. EPA
"~ey. R.. G.:. ECA
F'rE~'. R" U.S. E?A
TITLE!DESCR!P!ION
-----------------
-----------------
Memorandum re: ~ater Division's Revlew or the
0raH R!
~e~orandum re: CERCLA CoeDlia~ce Branch's
:oament: on :he Draft Ri w/Attach!oEnts
Memorandum re: iSU's C~~ments on the Risk
~==es;ment
~e~orandua re: Air Taxies and Radiation
Branch's Review of tte Rl ReDor:
~2tter Forwarding Revised Pages for Technical
Memorandum #5. Revision 1
Grimr.er. ~.. Letter re: S~ecifications for Site Perimeter
Eichhorn. Ei,hnorn ~ 'ence
~ink
'"oJ" ~,:'/(l2/91 :~~-North Cer1:r3!. " c ErA
'~..'.
I..
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199 10/08/91 Sa] 1. R.. ERr'H~orth Frey. t> U.S. EPA
H,"
Central ~ Iii C I
199 lO/1lI91 Baker. R.. IDEi'I F rey ~ R.. U.S. EPA
20() 10/21/91 "~ey, R.. ~.S. EPA Baker. F..
Wei l-IlcLain
201 10/21/91 Heller. E.~ 'I c: EPA Frey ~ R.. U.S. EPA
u.....
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10/25/91
204
10/29j91
205
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Orzehoskie. C.. U.S. Pawlowskl. U.S. EPA
EPA
Hudak! 9.. U.S. 001
Watters. E.! U;S.
EPA
Frey~ R.. U.S. EPA
Frey. R.. U.S. EPA
Niedergang. N.. U.S.
EPA
Grimmer. 1'1.. Waste
r r. c. Steering
Committee: et al.
Technicai Memorar:dul 45. Revislon "A
Letter re: Incorporation of CRL Data
Validation Ca~lents into Technical Memorandum
15. Revision 1
Letter re: IDEfl's Review of the Alternatives
Array Docu"ent
letter re: Scecifi~ations for Site Perimeter
Fence
Memorandum re: BTAG's Review of the
Ecological Assesslent
Memorandum re: ~etlands Regulatory Urit's
Co..ents on the Draft Rl
Letter re: U.S. DOl's COllents on the Rl
Reoort and the Baseline Risk Assess.ent
Memorandum re: Addendum to Water uivision's
Review of tne Draft RI
Letter re: U.S. EPA's Comments on the Draft
HI Report and ~aseline Risk Assessment
~;Attachl1ent5
14
PAGES.
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~PA
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Lin~
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FreY~ R.. U.S. EPA
Ball. R.. ER!'!-Nor:h
Central. 1nc.
Ball. R.. ER!'!-North
Central. Inc.
Addressees
Frey!' R..
~:.s. EPA
trey. R.. U.S. ErA
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PAGES
-----------------
-----------------
-----
~=tt2r rE: I~E~'s R2yie~ of the A!ter~atlves
;~~3Y Doc~~eit! ar.d Ev=iuati~n ar,d Cc~~ents ~n
~h2 ARAIIs
?
Letter re: Due Date fer the Final RI ReDOrt
cetter In ResDonse to U.S. EP~ Novesber 7.
1991 L:tter re: CC~lent5 ~n th2 Draft RI
ReDort ar,d Baseline Ris~ Ass2ssaent
Letter re: National wetl~nd I~ventQrv
cetter Forwarding Htta~hed Jc~rnal Article
re: RisK AssEss;ent
~stt=r re: Baseline Risk Asssssment
~stter Forwarding Ceeies of RI ReDort.
Revision 1
Letter re: Placement aT rence Adiacent to
Trail Creek wfAttached CcrresQondence
Letter re: Com;ents or: Alternatives Array
Document and Due Date fer Draft FS Reoor:
Letter re: U.S. EPA ADDrOysl 01 ~echnical
~emoranauB #5. ReYlsicr: lA
~ett2rs ForWaralG~ CeciEs of ~echnical
MEmorandulI i5
Letter re: IDE!'!'s Comlents on the RI Reoort.
Revision 1
Letter Forwarding an Addendum to Attachment B
o' Te~hr:ical ~emorandus i5. Reyisior. lA
~;tt2r r~: IDEM's Co:ments ~r. t~e Bas2iine
RisK HSSeSSl!ent
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Inc. Steering
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-: .:.::':::CF:~'r7 ;~:
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RecQr~ ":~
.:tter "Qr~ar~lno Cooies of the RI qeoort.
;:~vi=i~n 2
q:illedial 1",12stigation Reoort.
Re~'i51Qr: 2
:~:hnl~=l
Revil?w
.:- F~ Renc:rt : Dr3r:)
~=:tEr ~:rwardin9 Coei:5
;Jf P3~e 4-
32 of t~e RI. Reyisi~r. 2
Letter re: U.S. DOl's CClments en the uraft
~S Reoort
Me~orar.dul re: RCRA's RevieM of the vraft ,S
Reoort for ARARs
Me~orar.du; re: ADril 1. 1992 Availability
5255ion Trio Reoort
ME~orandul re: Revie" of Mar~h o. 1992 FS
ReDor!
~Etter re: IDEI1's Com;ents on the FS Reoort
~etter r:: U.S. EPA's Comeents on the Revised
Baseline Risr. Assessment
~E30randu; re: Air Tc~ic5 and Radiation
Branch's RevieM ot the FS Reoort
Technical Review of FS Reoort (Dratt) ~/CQver
Letter
~6
:'::":ES
-----
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---------
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~~='~. ~;..
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:srvic:
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II.:': I S:~erin9
:Dnitte~
-:-~E,':E5CRrpT!Q~
-----------------
-----------------
~s;eline Ri5t As;es:~ent
-::t2r F:rwardinQ CaDies of t~e Revlseo
2s;eline Ri;K Assess$ent Re~ert MfAttache:
~:s~cr.se ty U.£. EPA'; C~m..ents yt A~rll :0.
loe.,
:":1....
-::ter '2: !DE~'s Coalent; D~ the Baseiic:
Ri;k AS52ssment. Re,isian L
~:::er re: ReQuest tG ]cclude Enclaseo
Baseline Risk Assessment Comments int~ the
~d~inistrative Record
~2tter re: U.s. EPA's Coements Gn the Dratt
Puhlic Health Assessment
L::ter re: U.S. EPA's Huorcval of the RI
Pe~ort. Revision 2 and the Baseline Risk
Assess!3ent
Grimmer. M.. Letter re: U.S. EPA's Celments on the F5
Eichhern. Eichhorn & ReDOr! [UnSISNED)
Link
243 ~;lIOOin !~diana State U .5. EPA
~:!oartllent ~f Health
244 Olf04!93 :..cav R.. ::.5. EPA Addressees
, . -. .
245
In/29m
Verhagen. To. ~arleY navak. D.. U.S. EPA
CorGeratian
24,~ :)2i02/93 :': a:e. M.: 'iersar.
i;Jc.
m '')2/03/93 .,'!lor. E..
ER"-North Ceiitral~
Inc:.
248 02/08/93 Tavlor. E..
ER"-North Central.
:rH:.
249
02.112/93
~oYak. D.. l.S. EPA
3~nsen. S.: Versar.
Inc.
Novak. D. and
Tyndall. K.. U.S.
EPA
Tyndall. K.. U.S.
EPA
Public Health Assessment
Meiorandul Forwarding the Final RI ReDert and
Baseline Risk Assessment
Letter re: Reauest fer Extensien for
Submittal ef FS Reoort
~=.oranau. re: ModfloM 6reundMater Flow Hodel
Melorandum re: Additional Field Nark to
Succort the FS ReDDrt
~elorandul re: Access to Josam ProDerty
Verhagen. T.. Marley Letter re: Revised FS Schedule
Cercoraticn
17
C~5EE
-----
:')4
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74
.,
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-------
:~:t
[::'7E
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----
----
------
2~O
..;.. " ~ c :C~
'.'JaI..IJ/,".'
Wright. ~.. :DEM
---
!)3/0~;/93
Edwards. D..
ERM-North Central.
~nc.
"0"
.....:.
03/17/Q3
5ri;ler. ~.. Waste
inc. Steering
COiJi!ittee
::3
03/17 /93
Taylor. ~..
ERI'I-North Central.
Inc.
254
(i3f25J93
Nova~. D.. U.S. EPA
2:5 04/(12/93 Griller. " waste
I'.,
Inc. Steering
Coui ttee
256 04/08/93 Bunsen. S. and
Place. II.: Versar~
Inc.
257 04/16/93 Branigan. T.. U.S.
EPA
25B
04/26/93
Verha~en. T.. ~arleY
Corooration
259
05/12/93
VerhaQen. T.. ~arleY Novak. D. and
COlBoany Branigan~ T.. U.S.
EPA
260 OS/12/93 TaYlor~ c
....
ERI'I-North Central.
Inc.
~'1 (!,~i03/93 ERII-North Cen trOll.
~t~
T. -
..11'..
"L" 06/03/93 Taylor. E..
..iJ,J..
ERI'I-North Central.
Inc.
;'EIPmn
---------
---------
'Javak. D..
U.S. E,:A
'.JQvak, D..
U.S. E?4
~~QvaL D..
U.S. EPA
Novak. D.. U.S. ErA
Brilmer. ~.. Waste
Inc. Steering
:ollillittee
Novak. D.. U.S. ErA
Novak. D.~ U.S. EFA
Grilaer. II.. Waste
Jnc. Steerino
Calli ttee
Novak. D. and
Branigan. T.. U.S.
EPA
Novak. D.. U.S. EPA
!J.S. EPA
Novak~ D.. U.S. EPA
"!TLE1DESCPIOT!CN
-----------------
-----------------
L:tter re: rD~'s Resoonse to Questior.s
~aised Durir.~ the January 12. 1993 ~eeting to
Di=cuss Agency Comments
L:tter re: :u"clesental Field Work for the FS
",iAttachment:;
L:tter re: C~.cletion of FS ReDort
Letter "iAttached Outline oi Bround Water
Modelin!) Pr~ject
Letter re: Denial of Request ior E~tension
fer Submittal of the FS ReDort
~etter re: E~tenslon for Submittal of the FS
Reoort
~elorandul re: Versar's Co,aents on the
Outline of GroundNater ~odeling Project
Letter re: Disoute Reso]ution Concerning
Sublittal of the Revised FS
Letter re: Dispute Resolution Concerning the
Sublittal Df the Revised FS "/Attachment
Letter Sublitted on Behalf of the Waste Inc.
Steering COllittee re: Delay in Sublission of
the Revised FS
letter re: Delay in Subaission of FS ReDort
Feasibility Study Report. Aopendices:
Revision 1 .
Letter ForNarding the FS ReDort. Revision 1
wiAttached Table Denoting U.S. EPA's Comments
Addressed in the Red LineiStrike Out Version
18
°AGES
- ----
28
37
..
.:\
'I
..
5
10
'I
..
"
I..
535
8
-------
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----
----
_.....'
06/16/93
::4
;:!6/21/93
1,~5
06/23/93
:66
06/24/93
267
06/29/93
:68
OJ/02/93
269
07/09/93
270
07/12j93
271
07/16193
272
07/21/93
273
07/26/93
:74
08/02193
m
08/17/93
276
08/19/93
277
OS/2!/93
"UTHOR
------
7raub. J..
:J.S. EPA
5mh. iI.. :':.8. EPA
Harrity, D.. PRC
Environmental
~anaqelent. H1C.
Watters. E.. U.S.
EPA
Bandelehr. A.. U.S.
EPA
Kleiman. J.. U.S.
EPA
':n~1III
"'Ut.1I
S~ith. J.. IDE/'I
U,5. EPA
Novak! D.~ U.S. EPA
5riller. I'I'!
Eichhorn. Eichhorn &
Link
Taylor. E.~
ERft-North Central.
Inc.
Novak. D.. U.S. EPA
ERft-North Central.
Inc.
~right! L.. IDEM
::C!F!ENT
..--------
---------
Srilmer. M.. Waste
:~C. Steerino
Sault tee
~igiulo.
EPA
.i... u.:'.
"Qvak. D..
w.~. E?A
~raub. J.. U.S. EPA
lIovak. D.. U.S. EPA
~avak. D.. U.S. EFA
~o,'ak. D I.
U.s. E?A
ilriqht. L.. IDEI'!
Publh
6ri.ler! 1'1.. Waste
inc. Steerinq
COllittee
Novak. D.. U.S. EPA
Novak. D.. U.S. EPA
Tavlor. E..
ERft-North Central.
Inc.
Novak. D.. U.S. EPA
Novak! D.. U.S. EPA
!!7LE.'DE5CRIfTIGN
-----------------
-----------------
c2tter r2: uisoute Concernlno the Deadline
iQr Subais;io~ of the Revised FS Reaort
~2morandum re: Wetlands Reoulatorv U"lt s
Cumlents an the Draft FS
Te~hnical Review of the FS Reoort !Drafti
~;Cover Letter
Melorandul re: Water Division.s Review of the
Revised FS
Me~orandul re: Air T~xics and Radiation
Branch's Review of ~he Revised FS (Annotated)
~eIDrandu; re: RCRA's Review af the Draft FS
I"r ARARs
Letter re: IDEM's Cuilents an the FS Reoort.
Revision 1 (Draft)
~e;orandul re: SUDerfund Section's Review of
the FS. Revision 1 for ARARs
Letter re: Activities Uodate
Letter re: U.S. EPA's COBlents to the Revised
FS wiAttarhlents (UNSIGNED)
Letter re: Delay in l'Iaking Revisions to the
Revised FS
Letter re: ReQuest for Extension of FS
Reoort. Revision 2
Letter re: U.S. EPA's Denial of Reouest for
Extension for Sublission of the FS Reaort.
~evision 2 (UNSIGNED!
Letter re: ERl'!'s COllents on the FS. Revision
1 lIiAttachaentS
Letter re: 1DEI'I's Comaents on the Revised FS
\UNSIGNED!
19
jA6ES
-----
, "
1'-'
..
:,,;
.,
.:.
5
10
~
'J
4
21
2
2
79
-
-------
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----
----
...: ~
::':;':24/Q3
, "
'~"9 /30/93
'."
:)9/30/93
:31
~("01/93
'-.0,",
~._L
[0/20/93
..~~\
12/20/93
::4
::128/93
285
01/00/94
286
01/04/94
257
')1;' 10/94
288
')1/10/94
"00
-",
;):/09/94
290
':'2/09/94
291
'12109/94
292
02/1S/94
,,~~
,)3/01194
::JTHDR
------
iiriqht. L.. IDE/!
~R~-North Central~
~;1': .
~~~',akl GH
J.S. EPA
8u~sen. S..
Inc.
'Jersar.
HIJdaL D., U.S. DOl
Novak. D.. U.S. EPA
~211er .
r', :!-=
"". ~ ~. oJ.
U.S. EPA
-,~r'.cr:"fT
:"',_\";11 ....." I
---------
---------
~GYak. D.. U.3. ErA
"a [:0,',
'.J...'. .....,
Griemer. M.. Waste
Inc. Steering
Comillittee
NovaK. D. ~
U.S. EPA
Novak. D.. U.S. ErA
Addressees
EPA Novak.~..
J . S. EPA
Public
Ha~verlale! G., IDEM Novak. D.. U.S. EPA
Meyer, D., U.S. EPA
~atters. E., U.S.
E~A
Marilyn M. Janes ~
Associates. Ltd.
Anderson. T., Save
the Dunes Council
Various
NovaK, D.. U.S. EPA
Traub, J.. U.S. EPA
'1.5. EPA
Novak. D., U.S. EPA
IJ. S. EPA
eoklund. R.. LaPorte Novak. D.. U.S. EPA
CountY Health
Deoartlent
Novak. D.. U.S. EPA
Anderson, ,.. Save
the Dunes Council
TITLE!DE5CRIPT!ON
-----------------
-----------------
~~tter re: iDEM's Ccm;ents Gn the Auqust 19.
lq93 Revise~ '-5
;easibility Study Reccrt. Revision 3
~etter re: Acoroval wiCorrectiens 01 the
Revised FS (UNSlSNED)
Letter re: Versar's Review of COllents and
Changes to the FS
Letter re: U.S. DOl's COllents en the F5.
F~evislon ,)
Meioranduill FOf"ardinq the Draft Pro Dosed Plan
for Revie~
Memorandul re: RCRA's Review of t~e Prooosed
Plan tor ARARs
Fact Sheet: Prooosed Plan for Relediai Action
Letter re: IOE~'s Comlents on the Prooosed
Plan Fact Sheet
Melorandum re: Air Toxic and Radiation
Branch's COllents on the ProDosed Plan
r.elorandul re: Nater Division's Review of the
Draft Proposed Plan
Condensed Transcrict: U.S. EPA Public Hearing
Letter re: Comlents Concerninq the ProDosed
Alternatives w/Attachlents
Public [ollent Sheets
Letter re: LCHD's Reouest for a 30 Day
E~tension of the COllent Period for the
Prooosell Plan
Letter ir. ResoDnse to Questions Raised re:
PrODosed Remediation Plan (UNSIGNED)
20
cASES,
-----
~1"
'.',£,L
.,
~
~
S
.,
L
3
75
10
B
.,
..
-------
: '::# ..'M' t ~iJTHOR R~~iF'IENT -:.~EI~~ECR!PTI~~i =-~6ES
---- ---- ------ --------- ----------------- -----
--------- -----------------
294 ':':/')8/94 2ergerson. ~., Ci.t'f Novak. ...0 ,-,,,,," EPA ,-:::er re: ~i':higan Cit.;,~ ReQuest for a ..,
-< Michlgan City - E~tension to the P'le! ic COiilent Period
v: - ~ ~
:~.~. (:~.... :1/94 Steele. 6.. indiana Noy~k. ".. :1 c EPA '_otter re: I S~H' s Reouest for Extension of
'..11'811
':tate u'2[jartmern of :-~ P:Jblic '::~G!en t Period tor the Prooosed
Health : ::n and FS
-::'.:. ':'3/14/94 J:rdan. n.. ai,O !'~Dvakl :;.. :.JIWI ErA :..s:ter re: Reouest f:Jr Extenslon of the
;'I,J
P;ri!:h. M.. :'!i!1ori tv :'!ol ic COlIBent Period
Health Coalition
.,o~ :'3/lS/94 9:1Uund. R.. LaPorte No\'ak. D., U.S. EPA Letter re: LCHD's Reouest tor a TellDorarv
-"
County Health ;'~stoonel1en t of the COlllen t Period for the
veoartment :~oDosed Plan
298 03/23/94 Adals. J. and Novak. D.. U.S. EPA :.. :tter re: Cost Estiillate for a CaGlolete "
HaiDer. H.. Wan...n :,eloval Re:;edy
Inc.
:99 i),)/31i94 AdaGlkus. .., U.S. Liecipients ~~Iinistrative Order bv Consent 49
EPA
300 (it / 15/94 CitY ot Michigan U.S. EPA 'esolution 13688: Resolution to the Indiana 5
City :tate Deoart~ent of Health Re9ardinQ the
~!Jblic Health Assesslent for Maste Inc.
./Attachments
:01 04/15/94 City of Michigan U.S. EPA Reso iu tion 13689: Resolution to the U.S. EPA "
City R~ardinQ the Waste Inc. SUDer'fund Site
"i Attach.en t
302 04/19/94 Mothers Opoosing Novak. D., U.S. EPA C~~len ts on the Pr~posed Plan and FS II/Cover 13
Pollution Letter
,303 04121/94 Anderson, T.. Save No';ak. D.. U.S. EFA '-= tter re: CaDlents ConcerninQ Supoort of 13
the Dunes Councli ~ltErnative 5B II/Attachments
304 ')4/21/94 Sokl und, R.. LaPorte Novak. D.. U.S. EPA L.Etter re: LCHD's CPGllents on the Proposed "
County Health ;'lan
Departlent
305 04/22/94 Carrasouero, P.. Novak, D., U.S, EPA L.stter re: IOE"'s RecoI.endations tar the ROD ~
..
IDE"
306 04/22/94 Adals. J.. Wanvn NovaL n II c: EPA L.stter re: Technical COllents on the Pro:Josed S
".. \j1'~1
Inc. Plan 'for Reledlal Action
307 07/13/94 Pastor. :,... U.S. EPA Anderson. T" Waste L.stter re: Technical Assistance Grant ~
~
Inc. Cleanup
Coa Ii tion
21
-------
::Ct
_~I",
----
----
3(;8
',}7/22j94
::UTHOF
------
Carrasouera. P..
mil
~ECjPIENT
---------
---------
Novak. D.. J.S. EFA
::;LE!DE::R!~T!QN
-----------------
-----------------
Letter re: IDEM's Comments an the ROD
~.,
...
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