United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-87/050
September 1967
Superfund
Record of Decision:
Seymour, IN (2nd O.U.)
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TECHNICAL REPORT DATA ~
(Please read Instructions on the revtne before completing)
EPA/ROD/R05-87/050
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Seymour, IN
Second Remedial Action - Final
7. AUTHOH(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
5. REPORT DATE
September 30, 1987
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO. "
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
The Seymour Recycling Corporation (SRC) site, encompassing a fourteen-acre area, is
approximately two miles southwest of Seymour, Indiana. SRC and its corporate
predecessor, Seymour Manufacturing Company, processed, stored and incinerated chemical
wastes at the site from about 1970 to early 1980. The facility was closed when SRC
failed to comply with a 1978 agreement with the State of Indiana to cease receiving
wastes and to institute better waste management practices. In 1980, several thousand
drums were removed from the site by two potentially responsible parties (PRPs). In
1981, the U.S. EPA removed chemicals from tanks at the site and disposed of those wastes
off site. A 1982 Consent Decree with potential PRPs resulted in the removal, between
December 1982 and January 1984, of approximately 50,000 drums, 100 storage tanks and th«
first foot of contaminated soil from about 75 percent of the site's surface. A Record
of Decision, signed in September 1986, evaluated the stabilization of the ground water
plume emanating from the site and selected the implementation of a plume stabilization
system to extract, treat and discharge ground water to a waste water treatment plant.
Currently, the shallow aquifer under and just beyond the site boundaries, which serves
approximately 100 residences and businesses, is highly contaminated with more than 35
different hazardous chemicals, including 1,2-dichloroethane, benzene, vinyl chloride anc
1,1,1-trichloroethane.
(See Attached Sheet)
17.
a. DESCRIPTORS
KEY WORDS AND DOCUMENT ANALYSIS
b.lOENTIFIERS/OPEN ENDED TERMS
Record of Decision
Seymour, IN
Second Remedial Action - Final
Contaminated Media: gw, soil, sediments
Key contaminants: TCE, DCE, VOCs, benzene,
inorganics, organics
B. DISTRIBUTION STATEMENT
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None
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None
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53
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EPA/ROD/R05-87/050
Seymour, IN
Second Remedial Action - Final
16. ABSTRACT (continued)
The selected remedial action for this second operable unit includes: deed and access
restrictions and other institutional controls; implementation of a full scale soil vapor
extraction system; ground water extraction and treatment by air stripping, mixed-media
cap; and excavation of 800 cubic yards of contaminated creek sediment and consolidation
of the sediment beneath the cap. The estimated capital cost for this remedy is
$10,536,000 with present worth O&M of $7,200,000.
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MECORO OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SEYMOUR RECYCLING CORPORATION SUPERFUNI) SITE
SEYMOUR, INDIANA
Statement of Basis and Purpose
This decision document, with the attached Summary of Record of Decision
(incorporated herein as Attachment 1), represents the selected remedi al
action for this site which was developed and selected in accordance with
CERCLA, as amended by SARA, and to the extent practicable, the National
Contingency Plan.
This decision concerning the appropriate remedial alternative for
the Seynour site is based primarily on the following documents:
1. Remedial Investigation, Volumes 1 and 2, Seymour Recycling
Corporation, May 12, 1986, prepared by CH2M Hill, including the
Endangerment Assessment, which is Chapter 9 of Volume 1.
2. Public Comment Feasibility Study Report, Volumes 1 and 2,
Seymour Recycling Corporation, August 29, 1986, prepared
by CH2M Hill .
3. Community Relations Responsiveness Summary, Seymour Recycling
Corporation, September 1987, prepared by CH2M Hill.
4. The Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, 42 U.S.C. § 9601 _et s_e£., as amended
by the Super-fund Amendments and Reauthonzation Act of 1986.
5. The National Oil and Hazardous Substances Pollution Contingency
Plan, 40 C.F.R. Part 300, November 20, 1985.
6. Correspondence from Dr. C.W. Fetter, Jr., to David Favero, dated
July 2, 1987.
7. Guidance on Remedial Investigations Under CERCLA, May 1985.
8. Guidance on Feasibility Studies Under CERCLA, April 1985.
9. Conceptual Level Design and Feasibility Study fo.r In-situ Air
Stripping of Volatile Organic Contaminants from the Unsaturated
Zone at the Seymour Recycling Corporation Hazardous Uaste Site,
Seymour, Indiana, Hydro Geo Chem, April 28, 1987.
10. Draft Conceptual Plan for Groundwater Remediation in the Shallow
Aquifer at the Seymour Recycling Site, Geraghty & Miller,
April 28,.1987.
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11. Superfund Public Health Evaluation Manual , OSWER Directive
9285.4-1, October 1986.
12. Memorandum from J. Winston Porter, Assistant Administrator, OSWEr-*,
to Director, Waste Managenent Division, Region V, and others,
entitled' Interim Guidance on Superfund Selection of Remedy,
Decenber 24, 1986.
13. Memorandum from J. Winston Porter, Assistant Administrator, OSUER,
to Director, Waste Management Division, Region V, and others,
entitled Additional Interim Guidance for FY '87 Records of
Decision, July 24, 1987.
14. Memorandum from J. Winston Porter, Assistant Administrator,
to Regional Administrator, Region V and Director, Waste Management
Division Reyi-on V, and others, entitled Interim Guidance on Com-
pliance with Appl icable or Relevant and Appropriate Requirements,
July 9, 1987.
15. Memorandum from J. Winston Porter, Assistant Administrator, OSWE*
to Regional Administrators, entitled Superfund Selection of Remedy, .
August 14, 1987.
16. Correspondence from Harry John Watson III, Indiana Attorney General's
Office, to Lawrence Kyte, dated August 8, 1986.
A substantial number of additional documents, which are included in the •
adhinistrative record, have also been considered in selecting the remedial
action for this site. An index to the administrative record is incorporated
as Attachment 2 to this document.
Description of the Selected Remedial Alternative
The selected remedial alternative represents the final remedy for the Seymour
site.
The selected remedial alternative includes the following major components
which are discussed in more detail in Attachment 1:
0 Deed and access restrictions/other institutional controls to
prevent future development of the site and adjacent property
and to assure the integrity of the remedial action.
0 Implemention of a full scale soil vapor extraction system.
0 Extraction and treatment of contaminated groundwater at and
beyond the site boundaries.
0 Installation of a multi-media cap.
0 Excavation of contaminated sediment and consolidation of the
sediment beneath the cap.
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-3-
0 A regular monitoriny proyran to determine the effectiveness
of the proposed remedial action.
Declaration -.-•
Consistent with the'Comprehensive Environmental Response, Compensation
and Liability Act -of 1980 (CERCLA) , as amended by the Super-fund Amend-
ments and Reauthorization Act of 1986 (SARA), and the National Oil and
Hazardous Substances Pollution Continyency P'lan, 40 C.F.R. Part 300,
I have determined that at the Seymour Recycliny Corporation Site, the
selected remedial alternative provides adequate protection of human
health and the environment; satisfies'the preference for treatment that
reduces mobility, toxicity or volume to the maximum extent practicable;
and is cost-effective.
The State of Indiana has been involved with the development of the re-
medial investigation/feasibility study. The State has been consulted
on the selection of the remedy and is expected to concur.
The Office of Waste Programs Enforcement has concurred with the remedy
selected for this site (Attachment 3).
I have determined that the action taken is consistent with Section 121
of CERCLA, as amended by SARA, and is appropriate, balanced against the
availability of Trust Fund monies for use at other sites.
Because hazardous substances will remain on-site, the 5-year review
provision of Section 121(c) of CERCLA, as amended by SARA, will apply
to the Seymour site.
vaidas V. Adamku
Regional Adminis
rator
O
to', 119?
Date
Attachments
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ATTACHMENT 1
SUMMARY OF RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SEYMOUR RECYCLING CORPORATION
SEYMOUR, INDIANA
September 25, 1987
U.S. EPA, REGION V
CHICAGO, ILLINOIS
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Table of Contents
Sect Ion Page
Site Location and-Description 1
Site History 1
Results of the Remedial Investigation 3
Endangement Assessment ' 6
Technology Analysis Results 11
Groundwater Remediation Technologies ll
Soil Remediation Technologies 16
Remedial Alternatives Development 18
Selected Alternative 22
Compliance With Other Environmental . 28
Requirements and Cleanup Standards
Groundwater 29
Potential ARARs 29
Other Standards or Criteria 32
Determination of Cleanup Standards 32
State ARARs 37
Discharge 37
Soil 41
Air 42
Radiation • • 42
Enforcement Status 43
Community Relations 43
Future Actions and Schedule 44
ATSDR Comments 44
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List of Tables
Tables
Table 9.2
from the RI
Table 9.7
fron the RI
Table 4.4
from the FS
Table 5.14
fron the FS
OWPE Hazard Criteria for Selected
Chenicals at the SRC Site
Potential Exposure Pathways SRC Site
Summary of Groundwater Extraction
Scheme Performance and Cost Analysis
Detailed Evaluation Sunnary Matrix
Page
7
13
23-24
List of Figures
Figure
Fiyure 1.2
fron the FS
Fujure 7.21
fron the RI
Fiyure A.17
from the FS
Figure 5.4
from tne._FS
Site Location/Study Area
Volatile Organic Conpounds in the
Shallow Aquifer, June, 1985
1989 Distribution of Vinyl Chloride
Without Plune Stabilization Assuming
Lowest Reported Retardation
Sedinent Removal Areas
10
20
Appendices
Appendix 1 Projected Schedule for Future Actions
at the Seymour Recycling Superfund Site
Appendix 2 Community Relations Responsiveness Sunnary
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SUMMARY OF RECORD OF DECISION
SEYMOUR RECYCLING CORPORATION
SITE LOCATION AND DESCRIPTION
The Seymour Recycling'Corporation site is located 2.3 miles southwest
of the central busirress district of Seynour, Indiana, near the northwest
corner of Freeman Municipal Airport and Industrial Park (Figure 1.2 from
the FS). The site covers about 14 acres, approximately 1/2 mile south of
the Snyde Acres subdivision. Most of the area immediately surrounding
the site is used for agriculture. A drainage ditch extends from the north-
west corner of the site, (Northwest Creek), and drains into East-West
Creek about 10UU feet north of the site. The closest residence to the
site is Mrs. Otte's fann, just north of the creek. East-West Creek flows
into Von Fange Ditch, which runs through the Snyde Acres Subdivision.
SITE HISTORY
The Seymour Recycling Corporation (SRC) and its corporate predecessor,
Seymour Manufacturing Company, processed, stored and incinerated chemical
wastes at the site from about 1970 to early 1980. The facility was
closed when SRC failed to comply with a 1978 agreenent with the State
of Indiana to cease receiving wastes and to institute better waste manage-
ment practices. In 1980, a state court placed the site under receiver-
ship. Later that year, U.S. EPA fenced the site to restrict access and
constructed dikes to control runoff from the site. Several thousand
drums were removed from the site by two potentially responsible parties
(PRPs) in 1980. In 1981, U.S. EPA removed chemicals from tanks at the
site and disposed of those wastes at authorized disposal sites. In
1982, the U.S. Government entered into a consent decree in U.S. District
Court with sone companies believed to be PRPs. Under the agreement, the
PRPs arranged for the removal of hazardous substances on the surface of
the site.
The surface cleanup was conducted from December 1982 to January 1984 by
a hazardous waste disposal firm. The cleanup was monitored by U.S. EPA
and the State of Indiana. All wastes on the surface of the site, including
roughly 50,000 druns and 100 storage tanks, were removed and taken to author-
ized disposal sites. In addition, the top foot of contaminated soil on the
site was removed from about 75 percent of the site and also transported
to authorized disposal sites. Clean fill was brought in to replace
.the contaminated soil that was removed.
In 1982 and 1983, the U.S. Government entered into additional agreements
with other PRPs. As a result of these agreements, a fund was established
to be used for future cleanup actions. For example, money from the PRP
trust fund was used in 1985 to extend municipal water system pipelines
to the Snyde Acres area and money from the trust fund will be used to
pay for a plume stabilization project at the site.
In August 1983, U.S. EPA began the remedial investigation (RI) to deter-
mine the nature and extent of the potential long-term hazards that remain
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=s=~
East Fork
—(White River]
Snyde Acres
Subdivision
SCALE 1 ^4000
0
! MILE
1000
1000 2000 3000 ace-; sxc eooc 7000
i «.L:MCTEP
FIGURE 1.2
SITELOCATION/STUDYAREA
SEYMOUR RECYCLING CORPORATION
FEASIBILITY STUDY
EPA WA 70-5L01.0
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-3-
at and in the vicinity of the site. The RI also attempted to identify
pathways in the environment by which chemicals from the site may come into
contact with people or the environment. Part of the RI, the endanyer-
ment assessment, estimates the potential impacts of the remaining
contaminants on human health and the environment if no further clean-
up actions are taken at the site. The RI, which was completed in May
1986, serves as the primary source of data U.S. EPA used in the Feasi-
oility Study to develop alternative measures for reducing the potential
long-tern threats posed by the site.
A phased feasibility study was completed in August 1986 that evaluated
the stabilization of the groundwater contamination plume emanating from
the Seymour site. A Record of Oecision'was signed on September 30, 1986
selecting the implementation of a plume stabilization project.
RESULTS OF THE REMEDIAL INVESTIGATION
GroundWater Contamination
Monitoring wells have been installed and used by various contractors to
study the yroundwater at and in the vicinity of the Seymour Recycling
site. These studies indicate the presence of two aquifers: a shallow
aquifer and a deep aquifer. The shallow aquifer, sometimes as shallow
as six to eight feet below the surface, is separated from the deep aquifer
by a silty clay aquitard that allows some water to flow from the shallow
to the deep aquifer.
Groundwater in the shallow aquifer flows to the north/northwest. During
wet periods, the high level of ground water in the shallow aquifer results
in yroundwater discharging into the East-West Creek. During drier periods
the creek dries up and groundwater flows beneath the creek bed toward
residences in the Snyde Acres subdivision. Downgradient of the East-West
Creek, a portion of the groundwater in the shallow aquifer discharges to
the Von Fange Ditch. The ditch occasionally dries up which indicates ground-
water flows beneath the ditch toward additional residences in the Snyde
Acres Subdivision.
The deep crquifer, located from about 55 to 70 feet below the land surface,
flows primarily to the south. The area immediately to the south of the site
contains no wells or streams which could provide an exposure pathway for
site chaiicals in the deep aquifer to contact hunans or wildlife. How-
ever, there are wells located at Freeman Municipal Airport to the east of
the site that currently draw from the deep aquifer.
The shallow aquifer Is highly contaminated with more than 35 different haz-
ardous organic chemicals, including 1,2-dichloroethane, benzene, vinyl
chloride and 1,1,1-trichloroethane. Most of the contaminants are directly
under or just beyond the site boundaries. As of June 1985, the major por-
tion of the contaminant plume extended 400 feet beyond the site boundary.
(Figure.7.21 fron the RI) However, studies detected lower concentra-
tions of organi.c chemicals as far as 1,100 feet downgradient of the site
boundary. The contaminants in the groundwater are moving away from the
site at different rates; some as fast as 150 feet or more per year and
others as slow as one foot or less per year.
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-
68,100/ : ; 246,000
'
\
\ '
gg ,
i
tlOIMO
• :ra -- OWOUNOSUNPACI ILIVATION
N ._ ;-•* SPOT IUJVATION
i- SINCM MAUK
- - — CONCENTRATION* IN u^l
o 100 ?ao MO
nssaasas
ICAkI IN »«T
ALL IUIVATIONS AMI IN
^IITAMVI Mf AN SIA LIVIU
FIGURE 7.21
VOLATILE ORGANIC COMPOUNDS IN SHALLOW AQUIFER
SEYMOUR RECYCLING CORPORATION
REMEDIAL INVESTIGATION EPA WA 50.5 V01.1
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Hazardous organic chenicals have been detected in the deep aquifer.
Concentrations range up to 1,344 ug/1 of total oryanic contaminants.
The rate and direction of contaminant movement in the deep aquifer is
not well documented nor understood.
Soil Contamination
Soil samples were collected during 1984 and 1985 to detennine the
extent of contamination in the soil. Three types of locations were
sampled:
1. Soil Beneath the surface from the groundwater monitoring
sites (46 samples in 37 locations);
2. Sediments in the northwest drainage ditch next to the site
and in surface soils immediately surrounding the site (133
samples'in 50 locations); and
3. Soil to a depth of six feet on the site (205 samples in 51 .
locations).
Samples from the groundwater monitoring well locations and the near
surface soils were analyzed in an on-site laboratory, with select
samples being sent to the contract laboratory program (CLP) for a
complete analysis. Analyses of the soil samples indicate that soils
at various depths within the boundaries of the site are contaminated
with hazardous organic and inorganic chemicals. More than 54 organic
chemicals were identified in the soils, .including high concentrations
of 1,1,2-trichloroethane, carbon tetrachloride, 1,1,2,2-tetrachloroethane
and trichloroethene. (RI, Vol. 1 Chap. 6) (Record * ) Inorjanic
chenicals were found in the soils in concentrations greater than back-
ground. (RI, Vol. 1, Chap. 6) (Record # )
Contamination of near surface soils and sediments outside the site boun-
daries is much more limited. Sediment samples from Northwest Creek
show the presence of low level concentrations of hazardous organic chemi-
cals. (RT, Vol. 1, Chap. 6) (Record # )
Surface Water and Wildlife Contamination
In 1983 and 1984, the U.S. Fish and Wildlife Service (FWS) captured animals
and sampled sotls and sediments in the area surrounding the Seymour Re-
"cycling Site. FWS collected additional sediment samples in 1935. Analyses
of the animal tissues and the sediment samples indicate that some contami-
nation from the site has migrated to surrounding land areas and waterways.
These studies indicate that contaminants like those at the site have reached
East-West Creek.
No surface water samples were collected during the RI. However, the presence
of contaminants in the sediment and animal tissue indicate that the surface
waters, at least on occasion, contain low levels of contamination. (RI, Vol.
1, Chapters) (Record * )
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ENDANGERMENT ASSESSMENT
The endanyerment assessment (EA) performed as part of the RI includes
both a public'health and environnental evaluation. The public health
evaluation portion of the EA was conducted in three major phases:
1) toxicoloyic.al evaluation, ?) exposure assessment and 3) risk char-
acterization. A brief discussion of each phase follows.
Toxicological Evaluation (RI, Vol 1, Chapter 9.2.1) (Record * )
Over 70 chemicals were detected at tne site. Table 9.2 from the RI pre-
sents a summary of the yeneral toxicological categories into which
selected chemicals fall. Chemicals evaluated were selected based on
their concentration, frequency of occurrence and potential toxic effects.
The toxicol'oyical properties are evaluated in quantitative terms in the
EA. Three type's of quantitative evaluations are performed: 1) compari-
son with available and appropriate standards, criteria or guidelines,
2) additive carcinogenic risk calculation and 3) comparison of estimated
potential daily intakes of contaminants to acceptable intakes; The Health-
Index. ;
Exposure Assessment (RI, Vol. 1, Chapter 9.2.2) (Record'* )
The populations identified as actually or potentially exposed to chemicals"
at or migrating from the Seymour site are:
0 approximately 100 residences and businesses using grounrtwater
from the shallow aquifer.
0 users of wells supplying the Freeman Municipal Airport and otner
users of the deep aquifer.
0 populations downwind of the site; approximately 100 residences
within a 1 nile radius.
0 people who may live on, work at or may otherwise use the site.
0 people who would consume aquatic wildlife caught fron Northwest
Creek, East-West Creek, Von Fanye Ditch, and Heddy Run.
Exposure pathways are shown in Table 9.7 f-rom the RI.
Tne routes of exposure vary depending on the migration pathway and the
human activity. The potential routes of exposure are ingest ion, inhalation
or dermal absorption.
Risk Characterization (RI, Vol. 1, Chapter 9.2.4') (Record # )
According to EPA policy, the target total individual carcinogenic risk re-
sulting from exposures at a Superfund site may range anywhere from 1 x 10~4
to 1 x 10~7. (Superfund Public Health Evaluation Manual, October 1986).
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Table 9.2
GHPE HAZARD CRITERIA FOR SELECTED CHEMICALS AT THE SRC SITE*
Reproduction/
d «
Acutt Chronic
Careinoqeneitv Tcratoqenieity Hutagenieity Toxleity Toxici*?
Barlua
Benzene
Beazo(a)pyrene . .
2-Butanone
CadBlua
Chloroform
ChroBiua
1,1-Dichloroetbane
1,2-Diebloroethane
1,4-Dioxane
Lead
Methylene chloride
Methyl phenol •
Wlckel
Phenol
1,1,2,2-Tetrachloroethane
Tetrachloroethene
1,1,1-Trlcbloroethane
1,1,2-Trlcnloroethane
Trichloroetbene
Vinyl chloride
Xylene
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
•Adopttd fro» "CfcssUcal, Physical, and Biological Properties of Compounds Present at Hazard
Haste Site* Office of Haste Prograas Enforcement, (OHPE) U.S. EPA 1985. Criteria presented
below is that of OHPE. An "X" indicates tbe chemical sects tbe criteria outlined by OHPE
for tbe particular toxic effect classification. The lack of an "X" under a classification
does not necessarily imply that tbe chemical can not nave a toxic effect.
*A compound is classified as carcinogenic if it is a kaovn or suspected buaan carcinogen,
if it has been shown to be carcinogenic at a particular site in aore than one species or
set in an anlmel bioassay, or if it has been shown to Increase tbe incidence ef site-
specific malignant tu*ors in a single species or sex, and there is a statistically signi-
ficant dose-response relationship in aore than one exposed group. (This classification
is not necessarily the seM as presented by LARC or GAG in Table 2-2).
ChesUcals are classified as teratogens and reproductive toxins if there is suggestive
evidence of an effect la huaans or if at least one study in whole animals is clearly posi-
tive. Dbs-upported in vitro evidence is considered sufficient to classify a cheaiical as a
reproductive toxidty/terstogeniclty hazard.
CA cheaiical is classified as aotagenic if it has given a positive result in at least one
of tbe aaasulisa la vivo or bacterial or sasaalian cell in vitro assays for outagenicity.
A eeapeucd will be considered to be acutely toxic if it has an oral LD,0 < 100 ag/kg, an
inhalation LCSO < 400 sg/»-», or a canal LDSQ < 400 ag/kg. 5U ~
*Che«lcals vill be considered to cause chronic toxicity if they cause serious irreversible
effects other than cancer or reproductive effects after extended exposure to oral doses
of less than 100 Be/kg/day, inhalation concentrations less than 400 ag/«J, or dermal doses
less than 100 ig/kg/day.
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Table 9.7
POTENTIAL EXPOSURE PATHMATS--SRC SITE
Release Source
Fugitive dust
Transport Medium
Air
Exposure Point
Offslte end onslte
Volatilisation
from soil
Site runoff
Soil
Soil and already
contaminated
groundwater
Air
Surface water
(transferred to
fish)
Surface water
Direct contact
Groundwater
Croundwater
Groundwater dis-
charge to surface
water
Offslte and onslte
."east-west" creek
Von Pange Ditch
Heddy Run Creek
Onslte
Onslte
Of fslte (down-
gradient)
"east-west" creek
Von range Ditch
Noddy Hun Creek
Bcposure Route
Inhalation
Ingestlon
Dust on crop Ingested
Inhalation
IngestIon of fish
Direct contact
(dermal absorption)
Daraal absorption
Ingestlon
Ingestlon
Inhalation of volatiles
Denal absorption
Ingestlon
Inhalation of volatlles
Ingest Inn of fish
Direct contact
(dermal absorption)
Direct contact/
Ingestlon
Exposure Potential
Human population downwind—If site Is
disturbed—current cap may limit releases
In the short term. !
Human or livestock consumers of crops If
site Is disturbed—current cap may limit
releases In the short ten*.
Human population downwind--no known
current releases—current cap may limit
releases In the short term—future
releases potential If- site developed.
Past releases probably stopped by berm
and surface cleanup; fish may still carry
contaminants.
Past releases probably stopped by berm
and surface cleanup.
Requires development of site—does not
currently occur.
Requires development of site and potable
water well development for exposure to
occur—exposure does not currently occur.
Requires migration offslte to well loca-
tions—exposure Is not currently known to
Dermal absorption occur.
Requires offslte migration and shallow)
aquifer discharge to east-west ditch orf
Von range Ditch. i
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-9-
(Record 4 ) The 1 x 10*6 risk level is the point of departure for risk
management"! ("FS Guidance April 1985) (Record # ).
Further guidance in regard to risk nanagenent is provided in the references
cited in the FS,-the-FS-guidance document and the Superfund Public'Health
Evaluation Manual. -
Some .of the major risks associated with the site include:
0 Offsite Migration -- The offsite migration of highly mobile organic
contaminants could result in concentrations of contaminants at the
nearest offsite receptor locations (near Mrs. Otte's well, ap-
proximately one-quarter mile northwest of the site) at concentrations
associated with a 1 x 10"5 excess lifetime cancer risk in less than
five years from 1984 (See Figure A.17 from the FS). One chemical,
1,4-dioxane, could exceed the 10-day health advisory level at the
nearest receptor in less than 5 years from 1984. Contaminants may
migrate and discharge to the Von Fange Oitch, resulting in exposures
at that location, or may also migrate below the ditch to additional
residences in the Snyde Acres Subdivision.
0 Use of Shallow Groundwater Onsite -- Potable use of the shallow
groundwater in a residential, commercial, or recreational setting
could result in adverse health effects. The contaminant concentra-
tions onsite exceed current and proposed drinking water standards,
criteria, and guidelines. The major chemicals of concern are the
volatile organic compounds (VOCs). Exposure to VOCs could result in
carcinogenic health effects. For example, in a residential setting,
estimates of daily contaminant intake exceed acceptable levels, and
estimates of excess lifetime cancer risk range from 1 x 10"1
to 2 x lO'l. This risk is based on maximum reported concentrations
of all known potential carcinogenic VOCs.
0 Exposure to Onsite Soils from Site Use-- Site development could result
in exposure to contaminants in the soil. Ingest ion of soil could
result in adverse health effects as measured by estimates of excess
lifetime cancer risk (ranging from 3 x 10"3 to 1 x 10-6, depending on
the site use) and comparison of estimated daily contaminant intake
to acceptable intake (acceptable intakes for children could be exceeded).
The major chemicals of concern in the soil are VOCs.
" Environmental Concerns— Prior to the surface cleanup, releases of
contaminants from the site resulted in fish kills. Sampling by
the U.S. Fish and Wildlife Service in 1983 and 1984 detected con-
taminants in aquatic and terrestrial organisms. Environmental
exposures are currently possible. Terrestrial organisms could come
onto the site and be exposed to contaminants in the soil. Re-
leases of contaminants to the "East-West" creek are occurring, and
-------
/ von Fangci Oitcti
Freeman
Municipal
Airport
SHALLOW AQUIFER
1000
FIGURE A.17
1989 DISTRIBUTION OF VINYL CHLORIDE WITHOUT PLUME
JTABIUZATIONASSJUMJN^OWESTREPORTE^
SEYMOUR RECYCLING CORPORATION
FEASIBILITY STUDY
EPA WA70-5L01.0
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-11-
continued migration of contaminants (without remedial action) will
eventually result in their release to the Von Fange Ditcn. This
could expose aquatic organisms to contaminants fron the site.
.TECHNOLOGY ANALYSIS SUMMARY
The remedial action objectives established for the Seymour Site are
discussed in the FS, Vol. 1, Chapter 2. (Record * )
A large array of technologies were identified and initially screened
for their ability to meet these objectives. Generally these technologies
addressed the two environmental nedia contaminated at the site:
soil and groundwater.
Groundwater Remediation Technologies
A. Shal low Aquifer
Technologies passing through the initial technology screening in the
FS were combined into schemes to address the groundwater contamina-
tion at and beyond the site boundary. These technologies include
extraction and injection wells, and slurry walls. Components for
extracting groundwater, and then treating and discharging contami-
nated groundwater as recommended in the FS, are part of the overall
groundwater remedial action.
1. Groundwater Extraction Schemes (FS, Vol. 1, Chapter 4.1) (Record
* )
There were three basic schemes that met the response objectives
and were evaluated in the FS. These schemes should be reviewed as
approaches to groundwater extraction based on the currently avail-
able information. They do not establish exact location, number
and pumping rates of a final extraction scheme.
The schemes are:
1. extraction wells only,
2. extraction wells in combination with an injection well(s),
and
• 3. extraction wells in combination with partial containment
in a slurry wall around the site.
The approach in scheme 1 is to extract groundwater at the down-
gradient site boundary and at the downgradient extent of the
off-site contaminant plume.
Scheme 2 takes the approach of placing extraction wells on site,
clustered around the most highly contaminated area of the plume.
These wells would maximize inward radial flow from off-site; i.e.
the wells would draw groundwater from all directions toward the
site. An injection well would be necessary to eliminate an area
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-12-
of low hydraulic gradient created by competition among the extrac-
tion wells. A downgradient migration control well is also required
in this scheme.
The approach of Scheme 3 is to use a slurry wall to contain contami-
nants within the site boundaries but restore the aquifer outside the
boundaries to the cleanup levels. A slurry wall would be installed
down to the confining layer around the site to prevent continued
off-site migration of contaminants. An extraction well would be
necessary within the slurry wall in order to maintain the interior
water table at an elevation below that of the exterior water table.
Extraction wells would be necessary near the corners of the site to
remove the contaminant plume outside of the slurry wall. A down-
gradient migration control well is also required in this scheme.
A plume stabilization project is currently in progress. Schemes 1
through 3 were evaluated with a downgradient migration control extrac-
tion well. The purpose of this well is similar to that of the plume
stabilization well: to prevent further downgradient migration of
the contaminant plume. The assumption used in evaluating the schemes
in the FS was that the downgradient migration control well would not
be installed until 1989. One option was evaluated which assumed the
plume stabilization well was to be installed in the Spring of 1987.
The results indicate the plume stabliz.ation well would decrease the
time of aquifer restoration by 1 to 3 years. (RI, Vol. 2, Appendix A)
(Record # ) This same impact can reasonably be assumed to also
occur with the other pumping schemes. Also, if the plume stabilization
well is substituted for the downgradient extraction well it would not
be necessary to install the downyradient migration control well as
far downyradient. (FS, Vol. 1, Chapter 4.1)
Computer modeling was used to compare the different schemes. The flow
component of the model was calibrated with historical data; however,
the contaminant transport model was not calibrated. Calibration of
the contaminant transport model was not possible because there is
not an adequate history of contaminant concentration levels in the
groundwater. Verification of the models was not possible because data
was not available with which the modeling predictions could be compared.
Because of lack of calibration and verification, the model results
should only be used and considered accurate far relative comparisons
between schemes. In addition, in order to provide a basis for compar-
ison, all schemes were assumed to begin extraction in Fall 1989. Results
should not be taken as absolute values.
Indicator compounds were selected on which to base the computer
modeling. The selection criteria included concentration, contaminant
mobility, toxicity and treatability. (FS, Vol. 2, Appendices A and 8)
(Record # ) The most mobile compounds determined the area that an
extraction scheme would need to contain and the less mobile compounds
determined the time period a scheme must operate. Tetrachloroethene
was selected as the indicator compound on which to base performance
comparisons. Table 4.4 from the FS provides a summary of the ground-
water extraction scheme performance and cost analysis.
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-13-
Tafole 4.4
SUMMARY OF GROUNOWATER EXTRACTION SCHEME PERFORMANCE AND COST ANALYSIS
Aquifer Restoration Time (Yrs)
To Reach Cancer Risk Of:**
Extraction Scheme
1. Extraction
Wells Unly
2. Extraction-
Injection
Soil
Option Assumed
Source El iminated
No Action
Source El iminated
No Action
1 x 10-4
11-17
50-80
9-15
50-30
1 x ID'5
19-29
>ioo
16-26
>100
1 x 10-6
25-39
>100
21-33
>100
Cost'
51,417,000
SI,643,000
3. Extraction-
Containment
N/A
14-22
20-30
27-41
S3,0$5,000
* Total Present Worth Cost Over 30 years. Costs are for extraction only and do
not include treatment costs.
** Tetrocnloroethene used as indicator compound to determine pumping times. All
pumping was assumed to start in Fall 1989.
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-11-
2. Groundwater Treatment and Discharge
The following discharge alternatives for treated groundwater from the
site were considered in tne FS: 1) direct discharge to the Northwest
Creek, 2) aquifer reinjection, and 3) discharge to the Seymour Publicly
Owned Treatment Works (POTW).
The POTW provides an added level of protection to the environment be-
cause of the additional treatment of the treated groundwater prior to
its discharge to the East Fork of the White River. Discharge to the
Seymour POTW was carried forward in the FS for detailed evaluation of
ranedial alternatives..
Discharge criteria for the Northwest Creek are not known because they
have not been identified by the Indiana Department of Environmental Manage-
ment (IDEM) which is responsible for implementing the National Pollution
Discharge Elimination System (NPDES). The criteria are expected to be
more stringent than discharge criteria to the POTW. State Water Quality
Standards adopted pursuant to 40 CFR Part 131 would be applicable to
this discharge. Treatment costs would increase as the discharge criteria
become more stringent. The creek receiving treated groundwater discharged
from the site flows through the influence of the proposed extraction scheme ;
and would provide recharge to the shallow aquifer. This recharge could in- - :
crease the volume of contaminated water that must be extracted and treated. '
Further, the creek flows through a residential area where, if the on-site
treatment system were to fail, a threat to human health could result. There-
fore this discharge alternative was not carried forward for further evaluation.
Treatment with reinjection was not carried forward because the aquifer
could not accept the anticipated flow in any of the proposed extraction
schemes. Therefore, an off site discharge would also be required using
reinjection. Operational problems such as clogging of the well screen,
plugging of the formation or possibly having to excavate part of the multi-
media cap for maintenance of the injection well are expected with rein-
jection. Those problems could reduce the effectiveness of any extraction
scheme. To be compatible with the cleanup levels for the groundwater,
reinjected water has to be at least as clean as the ultimate groundwater
cleanup levels. This could cause increased treatment cost relative to
discharge to the POTW.
Tne treatment process developed for the extracted groundwater to be dis-
charged to the POTW was designed to be able to achieve pretreatment standards
tnat were preliminarily identified by the City of Seymour .and the IDEM. The
City of Seymour, under an authorized pretreatment program pursuant to 40 CFR
4U3.5, has the authority to establish pretreatment regulations and criteria.
The City consults with IDEM when implementing the pretreatment program.
These preliminary pretreatment standards are subject to revision. The treat-
ment process would most likely remain the same under the other two discharge
alternatives. Refinements would be likely, however, due to more stringent
discharge criteria.
The treatment process consists of an air stripper followed by mixed media
filtration, followed by carbon adsorption.
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-15-
The purpose of the air stripper is to remove strippable organic com-
pounds which are present in the groundwater in high concentrations.
Vapor phase carbon treatment may be needed and is included in the
cost analysis in this document. Air emission levels must be monitored
and a determination of the public health risk associated with the
emissions made. Evaluation of estimated emission levels indicates a
maximum of a 3.6 x 1U~° excess cancer risk level at 167 meters
from the site. This risk level means there could be 3.6 additional
cases of cancer in a population of l.OUU.UUO if that population was
located 167 meters from the site for a 7U year period. This risk
was based on the summation of 9 individual risks. (See memorandum
from Steven Rothblatt to Richard Bartelt, September 18, 1986) (Record
# ). Based on actual population in the Seymour area, the
estimated emission levels would result in 2.7 x 10"^ (.0027) additional
cases of cancer within a 50 km radius of the site in a 70 year period.
This risk is considered acceptable at this time for initiation of the
plume stabilization project without vapor phase carbon treatment
because: 1) the risk is within EPA's acceptable range of excess car-
cinogenic risk, 2) the plume stabilization project is not expected
'to pump the flow volume used in the risk assessment, 3) the quality
of the water being extracted by the plume stabilization well is expected
to contain lower concentrations of carcinogenic compounds than was used
in the risk assessment, 4) the short period of operation prior to
implementation of the final extraction and treatment system, and 5)
no exposure to humans because of institutional controls. Therefore,
the plume stabilization project will be initiated but actual monitoring
results from the plume stabilization project treatability studies
should be evaluated when these results become available. Any combined
cancer risk greater than 1 x 10" caused'by air emissions must result
in treatment of the emissions. (See Memorandum from Steven Rothblatt to
Richard Bartelt, September 18, 1986) (Record # )
The mixed media filter will remove suspended solids and precipitates
that form from oxidation of iron from the groundwater in the air
stripper.
The carbon adsorbers are necessary to remove less volatile organic
compounds. The low discharge criteria for phenol makes carbon
adsorption a required part of the treatment system.
Estimated present worth for a 150 gpm treatment system is $6,115,QUO.
The treatment process may be altered when discharge criteria are estab-
lished pursuant to the authorization procedure to discharge to the POTW.
B. Deep Aquifer
Contamination in the deep aquifer has only consistently been detected
in monitoring well 222. The contamination levels detected within the
site boundary are above the cleanup standards, but contamination
above cleanup standards has not been detected at or beyond the site
boundary. Therefore, remedial technologies specifically in relation
to the deep aquifer were not evaluated in the FS. Required actions
are described in the section discussing the selected alternative.
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-16-
Soil Remediation Technologies
The soil renediation technologies passing initial screening in the FS
include:
1. capping,
2. soil removal/on site disposal,
3. soil removal/off site disposal ,
4. onsite incineration,
5. in-situ soil washing, and
6. in-situ vapor extraction.
These technologies were evaluated separately from the groundwater
technologies, but there is an important linkage between the time
of restoring the shallow aquifer and the soil contamination. The
soil serves as the source of contamination to the shallow aquifer
which in turn is:the source of contamination to the deep aquifer.
The source of contamination to the shallow aquifer must be eliminated
to allow the shallow aquifer to be restored and to prevent additional
contamination of the deep aquifer.
1. Capping
Based upon the initial screening of technologies, the capping option
merited further evaluation as a remedial action or a component of a
more comprehensive remedial action. The preliminary design of the
cap used in cost analysis had a 3% slope, and successive layers of a
two foot vegetative cover, a geotextile layer, a synthetic drainage
layer, an 80 mil synthetic liner, and 2 feet of compacted clay. (See
FS, Vol. 1, Chapter 4.3.1) (Record # ) The design is consistent
with RCRA closure requirements set forth at 40 CFR Part 264, Subpart
G. The cap is estimated to take 2 construction seasons to install.
Estimated present worth is $5,794,000.
2. Soil Removal/Offsite Disposal
The soil removal option analysis was based on a cleanup level that
represents a 1 x 10"6 excess lifetime cancer risk for residential use.
This risk is within the acceptable ranye under current EPA guidance.
These levels also should provide adequate protection to the groundwater.
The volume of soil is estimated at 95,800 cubic yards or 7,900 truck-
•loads. Disposal is assumed to take place within a 250 mile radius of
the site over a period of .5 to three years.
Estimated present worth is $40,805,000.
3. Soil Removal/Onsite Disposal
Removal of soil and. disposal in an onsite RCRA compliant landfill was
evaluated, in the FS. As in the above option, 95,800 cubic yards of
soil would be ranoved. The size of the RCRA compliant landfill would
be approximately 4.5 acres in area and 40 feet high at its center.
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-17-
Replacement costs for cap components are included for cost analysis
purposes. Construction of the landfill would take at least two but
possibly three construction seasons to complete.
Estimated present worth is 59,229,000.
4. On-site Incineration
Rotary kiln was proposed in the FS as the nost effective and appropriate
incineration technology and was used for cost estimation purposes.
Six and a half years were estimated to be needed to themally treat the
estimated volume of contaminated soils a'nd other waste.
This option is considerably more complex to implement and operate than
other soil technologies. There is limited experience with the process
needed to demonstrate compliance with the. technical requirements for
onsite, temporary incinerators and making this demonstration could
take a considerable amount of time. Operation of an incinerator is also
very labor intensive and requires skilled operators. The FS assumed
it would take at least 5.5 years to complete incineration. The solid
residuals from the incineration process would need to be demonstrated
to not pose a threat to public health, welfare and the environment.
For the purposes of the FS it was assumed the solid residuals would
be hazardous and must be disposed of in an onsite RCRA compliant
landfill. -
Estimated present worth is $28,833,000.
5. In-situ Soil Washing
The FS stated that this technology is attractive because it removes the
more soluble contaminants from the soil by accelerating their leaching into
the groundwater and then collecting the contaminated groundwater. To im-
plement this technology at the Seymour site, surface soil that was placed
over the site after the 1982 surface cleanup would have to be ranoved.
The relatively lower permeability of this surface cover material would in-
hibit infiltration of water applied to the soil.
A pilot-study would possibly have to be performed on a portion of the site
to develop operational and effectiveness information. It is estimated
it will take 3-6 years to maximize the effectiveness of the soil washing
process. All contaminants would not leach fran the soil,.so some contami-
nants would remain In the soil and a cap would be needed.
Estimated present worth is $8,675,000.
6. In-s1tu Vapor Extraction
In-s1tu soil vapor extraction takes advantage of the volatile nature of
some of the contaminants to remove them from the unsaturated zone.
Vertical extraction wells were used in cost estimates. However, in areas
where the water table is high, horizontal extraction pipes may be more
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-In-
effective. (See FS, Vol. 1, page 4-97 and Hydro fieo Chen Report, April ?y,
1987) (Record # and Record # )
A cap nust be installed on-site in conjunction with any soil vapor
extraction system to prevent leachiny of contaninants to the groundwater,
to prevent direct contact with contaminated soil and to prevent run-off
of contaminated wate'r or sediment.
Estimated present worth is $9,554,000.
REMEDIAL ALTERNATIVES DEVELOPMENT
The technologies that passed through the initial screening in the FS
were then developed and evaluated, according to the criteria in the NCP,
in Chapter 4 of the FS. (Record # J The technologies were then com-
bined in the FS into a number of remedial alternatives to address all
the public health and environmental risks posed by the Seymour site.
The NCP requires that alternatives be developed and evaluated for the
following categories:
0 No action.
0 An alternative for treatment or disposal at an off-site
facility approved by U.S. EPA.
0 An alternative which does not attain applicable or relevant
public health and environmental standards but will reduce
the likelihood of present or future threat from hazardous
substances and provides significant protection to
public health, welfare and the environment.
0 An alternative which attains all applicable and relevant
federal public health and environmental requirements.
0 An alternative which exceeds applicable and relevant federal
public health and environmental requirements as currently
known.
The alternatives developed in the FS were also developed with the intent
.of meeting applicable or relevant and appropriate State requirements.
These requirements are identified in a correspondence from Harry John
Watson III, to Lawrence Kyte, August 8, 1986. (Record # )
In addition, alternatives were included in the FS that addressed the
cleanup standards required by Section 121 of SARA. The NCP required
that EPA develop these types of alternatives before the passage of
SARA, and it was EPA's policy to do so. (See 40 CFR Section 300.68)(n))
Alternatives developed included treatment alternatives that minimized the
public health and environmental risks associated with long term manage-
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-19-
nent of residuals and alternatives involving treatment as a principal
element that permanently and significantly reduces the toxicity, mobility,
or volune of hazardous substances at the site. Containment options were
also evaluated in the FS.
Common Features
All alternatives analyzed in the FS, except the no action alternative,
included a number of common features that are necessary to supplement
the major soil and groundwater components. These conmon features
are:
0 The existing onsite buildings would be demolished and disposed
of in accordance with the alternative selected. The volume
of building rubble is estimated at 2,200 cubic yards. The buildings
must be razed in order to allow for the installation of the
cap, soil removal or the implementation of vapor extraction
or soil washing.
0 Deed, and access restrictions and/or other institutional con-
trols would be placed on the SRC site property and the area
surrounding the site. Deed restrictions would prohibit
excavation of soil, building construction on site and ground
water extraction. Off site groundwater withdrawal restrictions
would be necessary to prevent any adverse impact's to the
proposed extraction well system. These would deal primarily
with prohibition of the installation of large volune wells.on
neighboring lands that could negatively impact the recovery
patterns of the extraction well systen. Use of the adjacent
land owned by the City of Seymour would have to be limited
in order to prevent a public health threat during operation of
the vapor extraction system. Access to the site would be con-
trolled by fencing, and the fence would be posted with warning
signs. The timing of the restrictions may vary depending on
the alternative and when cleanup standards are achieved. The
precise location, magnitude, and timing of the restrictions
v/ould be determined 'during the design phase of the remedial
action.
0 Contaminant migration would be assessed through a regular ground-
water and surface water monitoring program. Monitoring is
necessary to determine the effectiveness, of any remedial action.
0 One foot of sediment would be removed from the Northwest Creek
and from the ditch just north of the site as shown on Figure
5.4. The approximate volume of sediment to be renoved would
be 800 cubic yards. The sediments would be addressed with
the same technologies as the soils for the various alternatives.
The sediments pose a potential threat to aquatic life in the
ditch and creek.
-------
EAST WEST CREEK
LEGEND
K^VH Removal of 1 Foot
of Sediment
240
Scale m Feet
(1 inch touMt 240
480
FIGURE 5.4
SEDIMENT REMOVAL AREAS
SEYMOUR RECYCLING CORPORATION
FEASIBILITY STUDY
EPAWA 70-5L01.0
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0 Temporary runon and runoff controls would be constructed at the
site'as needed. These controls would prevent any off-site migration
of contaminants by surface water duriny construction activities on
the site.
EPA, in Chapter 6 of the FS, added the following feature to be included
in all remedial alternatives.
0 Residential wells in the Snyde Acres subdivision would be properly
abandoned if consent is obtained from their owners.
This feature is desirable to eliminate potential conduits for contamina-
tion to enter the shallow aquifer frcri residential wells which are no
longer being used. Under a previous response action, the residences have
been hooked up to the City of Seymour's water supply distribution system.
The Assembled Alternatives
The assenbled alternatives, except the no-action alternative, include the
common features described above and specific soil and groundwater com-
ponents.
The assembled alternatives are:
1. No action.
2. Offsite soil disposal/Groundwater extraction and treatment.
3. Onsite soil disposal/Groundwater extraction and treatment.
4. Onsite soil incineration/Groundwater extraction and treatment.
5. Multi-media cap/Groundwater extraction and treatment.
6. In-situ soil washing, multi-media cap/Groundwater extraction
and treatment.
7. Vapor extraction, multi-media cap/Groundwater extraction and
treatment.
An alternative was considered for each category required by the NCP.
(See FS, Vol. 1, Figure 5.2) (Record # ) The deteminations
in the FS as to attainment, exceedance or non-attainment of applicable
and relevant public health and environmental standards was made
prior to SARA being enacted.
The total capital cost, total operation and maintenance cost and total
•present worth are presented below for each alternative. •
Alternative Total Capital Cost Total 0AM Cost Total Present Worth*
1 0 00
2 $44,976,000 54,659,000 S49.635.000
3 12,275,900 5,235,000 17,510,000
4 28,281,000 3,700,000 36,981,000
5 9,034,000 4,929,000 13,963,000
6 11,845,000 5,614,000 17,459,000
7 10,536,000 7,200,000 17,736,000
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-22-
*Present worth is based on a 10 percent interest rate and a 30 year 0AM
period.
In accordance witn .the NCP, a detailed analysis of the assembled alter-
natives was performed. The factors evaluated were technical considera-
tions, public health,'welfare and environmental impacts, institutional
concerns and cost. •
A summary of the detailed evaluation of alternatives is presented in
Table 5.14 from the FS.
SELECTED ALTERNATIVE
The alternative recommended by EPA in the FS was a modification of number
7: Soil vapor extraction and multimedia cap/Groundwater extraction and
treatment. This.alternative, with minor modifications discussed below,
is the selected remedy for the site.
The criteria for selecting this remedy are contained in the NCP at 40 CFR
Part 30U.68(j) and Section 121 of the Superfund Amendments and Reauthori-
zation Act of 1986, Public Law 99-499, 100 Stat. 1613 (1986) or "SARA".
In addition, a December 24, 1986 memorandum titled "Interim Guidance on
Superfund Selection of Remedy" from J. Winston Porter, Assistant Admini-
strator to Regional Administrators and other regional management was
taken into consideration in selecting an alternative.
The vapor extraction system selected for implementation at the Seymour
site would ranove a substantial amount of. the estimated 200,000 pounds •
of volatile organic compounds (VOCs) that are present in the soil in high
concentrations. The VOCs are generally the most mobile and.toxic com-
pounds present at the site. The endangerment assessment identified this
group of compounds as posing the greatest threat to human health via
groundwater ingestion since the majority of these compounds are carcino-
gens and are present in high concentrations. (RI, Vol. I, Page 9-73)
(Record # ) The non-volatile organic compounds would remain in the
soil. However, these compounds are relatively immobile and may biodegrade
over time. The application of soil nutrients in order to stimulate bio-
deyradation is included in the selected alternative. This alternative
utilizes treatment technologies and reduces the mobility, toxicity and
volume of hazardous substances at the Seymour site to the maximum, extent
practicable.
A detailed pilot study was envisioned in EPA's recommended alternative
in the FS. However, based on reports submitted by the defendants in
this case (see Hydro Geo Chem Report and Geraghty and Miller Report,
both dated April 28, 1987) (Record # and # ' ), it is
reasonable to gather additional site data needed to design a soil
vapor extraction system, apply nutrients to stimulate biodegradation,
install the soil vapor extraction system, and then construct the
multi-media cap. This phasing of implementation of the system minimizes
the additional time the contaminated soils are exposed to the environment
and is therefore preferable to the pilot study proposed in the FS.
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Table 5.14
DETAILED EVALUATION SUflUDT IMTH1I
Technical
Criteria
Public Health
And teller*
Criteria
ntal
Institutional
Criteria
Alternative 1
Ho Action
Allows coatloucd release of hererdous
substances causing unacceptable public
health risk.
Public bMlth risk* Mist lor direct
contact i>lth excavated noil. Cancer
risk level ID soil ranges between
j«10-J to 6.10-5.
Public health risks also exist lor
Ingest loo MM! absorption ol ground-
•eter. Cancer risk level lo shello*
groundweter ranges between I a HP to
Is10-2.
Exposure Halted to local population.
Duration ol potential exposure Is
Indefinite: lor soils end greater than
100 years |Or shallow grouodvater.
Local vegetation and burrowing eolMis
•ay be al{acted through uptake or
direct contact Kith oastta soil, food
chain blooonceatratloB may affect
other local terrestrial or aquatic
aolMla.
Uncontrolled baiardous wait* site does
not a*«t the goals of CERCLA aod KM.
Shallow aquifer U *tolallon.of UIO~*
cancer risk level.
Alternative 2
Offslte Soil PIsposal/Uroundrater
t»tract loo aod Treatment
Reduces risk ol direct poatact vltk soil
or leaching of contaminants to grouod-
weUir. Soil excavation and transport Is
afflictive and reliable. Due to the large
volume of soil excavated completion could
take up to 2. S years. Disposal at a KIM
landfill does sot result lo coota»iaept
destruction. Performance of ultlMte
disposal at a KM landfill Is considered
reliable, shallon aquifer puaptng lls»
•111 require 40 to 60 yeers to reach lh«
1x10"* grouoditater cancer risk level.
Cancer health risk fro* soil reduced to
years. Disposal onslte does not
result lo contaminant destruction.
Shallm aquifer pumping time vlll require 40
to 60 years to reach the 1x10*6 grounovater
cancer risk level.
Cancer health risk froe direct contact vlth
soil reduced to
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Table S. 14
(continuedI
DCTAIUD EVALUATION SUMMARY HATSII
Technical
Criteria
Public Health
•od Melrare
Criteria
ffcvlrooMBtal
Crllcrl*
Institutional
Tiller I*
Total
Present Hortb
Alternative 5
HultlMdU Cap/Grouod««ater
Entract loo end Treateeot
•educe* risk of direct contact Mltb toll or
leeching ol oaetMloauit* to groundMater.
Ooslte capping Is reliable. The cap Mill
require) regular •ela*e*aoce to assure Its
long-ten effectlvenetee. Completion of the
cap could tea* M* I* two rear*. Cawing does
not reeult It) ooMeeUMtloo destruction.
ShelloM aquifer pueplog tie* Kill require 2S
to 19 feers to reach UM In 10*' groundnater
cancer risk level.
Ceooer health rl*k frosi direct contact Mlth
eoll reduced to «UIO-* onslte. Cap "III
require long-ten ee!ote*eac* to enure It*
effecit*
Shallow equlfer coooeatretloo* should be lees
then the Is XT* cancer risk level after n to
19 fears of pueplag.
Soil exposure rlek reduced for terrestrial
anlMls.
All applicable end relevant standard* »III be
•el. CCHCLA goals Mill be e*t. Since con-
st ructlof) Kill teke piece oostte local gonlng
end building codec euet be) coeplled vltb.
Alternative 6
In-sllu Soil Hashing, Nultleedle
Cap/Groundrater Entree!Ion end
Treatment
Deduces risk of direct contact Mltb soil and
loog-tero Ieach109 of conlaelnants to ground-
Meter, lo-sltu soil Mashing Mill need to be
piloted to del era I oe Its effectiveness Mllh the
SBC site conditions. The In-sltu soil Mashing
systve Mill be operated for about.1 to 6 years.
See Alternative S for cepplog discussion.
She1low aquifer pueptng tlee Mill require 10 to
tS years to reach the 1»10~* grouodueter cancer
risk level.
Cancer health risk from direct contact Mltb
soil reduced to oll
vapor en tract loo systeei Mill be
operated for about 1 to l years.
See Alternative S for capping
discussion.
Shallow aquifer pUBpiog tlee vlll
require 28 to 42 years to reach the
1x10** groundMater cancer risk
level.
Cancer health risk froei dliecl con-
tact with soil reduced to
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The multi-media cap would provide protection from direct contact with
the remaininy contaninants and substantially reduce the threat of long-
term migration of remaining non-strippable contaninants into the en-
vironment.
The groundwater extraction component of the selected remedial action
is scheme 1. Scheme 1 includes downgradient extraction wells at the
site boundary in combination with the plume stabilization well. The
goal is to meet the cleanup levels listed in a later section of this
document and to prevent uncontaminated portions of the shallow aquifer
from being contaminated above these cleanup levels.
This scheme is nearly as effective in restoring the aquifer to cleanup
levels as scheme 2, which was recommended in the FS. According to model-
ing projections, ^scheme 2 is advantageous because it will restore the
aquifer quickly and maintain a hydraulic gradient from the deep aquifer
toward the shallow aquifer. However, scheme 2 adds an additional level of
operational and maintenance difficulty because of the injection well.
If the integrity of the cap is compromised for maintenance of the injec-
tion well included in scheme 2, additional leaching of contaminants from
the soil to the groundwater could take place. Additional leaching would
prolong groundwater quality restoration. Scheme 1 also costs less than
scheme 2. The simplicity in operation and maintenance of scheme 1 makes
it the selected groundwa.ter extraction component. (See Fetter corres-
pondence, July 2, 1987 and Geraghty & Miller Report, April 28, 1987)
(Record # and Record # )
Schane 3 costs considerably more than the other two schemes and is much
less reliable because of the difficulty of installing the slurry wall and
the potential failure of the slurry wall.
For the deep aquifer, additional evaluation, and extraction and treatment
if necessary, are required as part of the selected ranedy. The wells
should be of adequate design, number and location to allow for rapid
detection o_f contaminants migrating off-site and to enable extraction
of contaminated groundwater if necessary. Part of this evaluation
should include a time-series analysis of water quality from monitoring
well 222. This will aid in determining the consistency of the contam-
ination and possibly the extent of contamination near this monitoring
well. Extraction of contaminated groundwater for treatment and dis-
charge should occur if contaminant concentrations above the cleanup
levels are detected at or beyond the site boundary. Treatment and
discharge can be performed in the same mariner as groundwater extracted
from the shallow aquifer. The treatment system for the shallow
aquifer must be sized or provisions made for upgrading the system for
the potential flow from the deep aquifer. In addition to immediate
pumping of the deep aquifer, if concentrations exceeding the cleanup
standards are detected, a plan for further investigation or additional
remedial action must be prepared.
The groundwater treatment and discharge components of the selected remedy
are air stripping, mixed-media filtration and carbon adsorption with the
treated water being discharged to the sewer system leading to the Seymour
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PUTW. The treatment components can be modified to most efficiently meet
discharge criteria ultimately to be set by the POTW. (See discussion on
pages 37-4U) The discharge criteria will be established to prevent upset
of the POTW, pass through of contaminants to the East Fork of the White
River and interference or accumulation in the POTW's sludge.
In addition to the soil and groundwater operable units, the selected
remedy also includes the features common to all alternatives, except
no action. These features are discussed on page 19 above.
Alternative 1, no action, is not acceptable for the Seymour site because
of the existing and potential threats to human health and the environ-
ment. These risks were summarized earlier in this document.
Alternative 4, which includes incineration, has the distinct advantage
that if operated properly, it would destroy the organic hazardous sub-
stances present in the soil. For certain waste types, this technology
may be appropriate, but at the Seymour site, the volatile organics pose
the main threat to human health and the environment, and vapor extraction
is a less costly and mechanically simpler system for removing VOCs.
In addition, there are safety and environmental risks associated with
incineration technology. Other disadvantages associated with incinera-
tion are the potential lony time needed to obtain approval to operate,
the disposal of ash and the total system cost. The ash must be
handled as a hazardous waste unless it can be demonstrated it is not
a threat to human health and the environment. The cost for the
incineration alternative is more than twice the cost for the selected
vapor extraction alternative. The estimated cost of incinerating
soil has a high degree of uncertainty based on the limited amount of
experience with incineration of soils. On balance, it is EPA's
judgment that for this site, the benefits that can be realized from
the vapor extraction alternative are superior to the incineration
alternative due to the complexity of implementation, the safety and
environmental risks, and the high cost of incineration in relation to
other effective alternatives.
Alternative 6, in-situ soil washing, has many of the same advantages as
vapor extraction, such as enhancing natural processes to reduce the con-
taminant concentration, and minimizing excavation. From the human health
and environmental perspective, however, in-situ soil washing creates the
potential for relatively less mobile contaminants to be flushed into the
aquifer that, under natural conditions, would take many- years to migrate
to the groundwater or would never reach the aquifer if the site was cap-
ped. Once the contaminants reach the shallow aquifer, the groundwater
extraction system may not capture these relatively immobile compounds be-
cause of their slow migration rates; thus, the potential remains for long-
term public health and environmental risks from groundwater contamination.
This risk is unnecessary since the vapor extraction system would remove
the VOCs, which are of primary concern, by extracting them from the sur-
face and a cap would be installed to prevent additional leaching of con-
taminants to the shallow aquifer. In addition, in order for soil washing
to be implemented at the Seymour site, the upper one foot of soil would
need to be removed, or otherwise altered to increase its permeability.
This soil cover was placed on the site's surface after the surface clean-
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up was perfomed in 1983. It has a low enough permeability to linit In-
filtration into the highly contaminated soils, thereby reducing the
effectiveness of the washiny process. As proposed in the FS study, this
soil would be placed in a RCRA-type landfill in the trianyular area in
the northeast part of the site. The need for soil excavation also causes
soil washing to be less suitable and desirable for implementation at the
Seymour site compared to vapor extraction. The cost of this alternative
is comparable to that of vapor extraction.
Alternative ?., which includes offsite soil disposal at an EPA-approved
facility, is not selected for several reasons. Primarily, SARA makes
off site disposal the least preferred remedial technology. (SARA, Section
I21(b)(l)) Off site disposal may not be able to be completed prior to the
effective date of the RCRA land disposal restrictions for CERCLA wastes;
therefore treatment of the soil would be required, adding to the cost of
this alternative. (RCRA, Section 3004(d) and (e)) Excavation of the soil
would create un-control led releases of volatile oryanics into the air as
well as the potential for promoting the flushing of contaminants
into the yroundwater during rainfall. Excavation also poses a risk
to the construction workers on site by increasing the potential for
then to come in contact with the contaminants. The selected vapor
extraction alternative requires minimal disturbance of the soil
since it is an in-situ technology. Transportation of the contaminated
soil increases the risk to human health, welfare, and the environment
from accidents and spills along public roadways. In view of the
fact that landfills are subject to leakage, long-term-negative human
health and environmental impacts could occur at the facility where the
wastes are disposed of. Moreover, the present worth for this alternative
is more than three times the cost for the selected in-situ soil vapor -
extraction alternative.
Alternative 3, which includes on site landfill ing of the contaminated
soil, has many of the sane potential negative aspects as offsite land-
filling mentioned in the previous paragraph. Although the risks
associated with transportation would not apply, all the wastes would
remain onsite. The waste volume, toxicity, and mobility would be the
same. Since the wastes are not treated, they could create a long-term
problem should the onsite landfill leak. The estimated cost for
Alternative 3 is about the same as for the selected alternative, but
EPA believes it would represent greater risks to human health/welfare
and the environment and does not satisfy the statutory preference in SARA
for permanent solutions and treatment to the maximum extent practical.
(SARA, Section 121(b)(l) Therefore alternative 3 is not .cost effective;
nor does it protect public human and the environment to the same degree
as the selected alternative. As in alternative 2 above, RCRA landfill
restrictions may be in effect prior to completion of this remedial action.
Therefore, treatment such as incineration would be necessary prior to dis-
posal , increasing the cost of this alternative. This would make this
alternative equivalent to alternative 4, which has already been discussed.
Alternative 5, which includes a multi-media cap and groundwater extraction
and treatment, is not selected since EPA believes if the cap fails, there
-------
is a significant of additional leaching of contaminants into the
shallow aquifer because the soils are not treated. The statutory
preference- for treatment which permanently and significantly reduces
the volume, toxicity or mobility of hazardous substances is not
satisfied. This causes alternative 5 to be not as protective of
human health and the environment as the selected alternative. (See FS,
Vol. 1, pp.6-10 and'll) (Record # ) The selected alternative
includes installation of a multimedia cap, but only in combination
with in-situ soil vapor extraction. It is believed that the vapor
extraction component should greatly reduce the concentration of VOCs,
the most mobile and toxic chemicals at the site, in the unsaturated
soils.
The cost of the selected alternative is higher than the cost of alter-
native 5; however, EPA believes that the greater treatment and subse-
quent human health and environmental protection offered by the selected
alternative out-weighs the additional costs.
COMPLIANCE WITH OTHER ENVIRONMENTAL REQUIREMENTS AND CLEANUP STANDARDS
This section identifies the requirements of the environmental taws, regula-
tions and policies that are applicable or relevant and appropriate standards
(ARARs) for the selected alternative for the Seymour site.
Cleanup standards must insure that the remedy is protective of human health
and the environment. (See SARA Section 121(d)(l))
Applicable requirements are cleanup standards, standards of control, and
other substantive environmental protection requirements, criteria or
limitations promulgated under Federal or State law that specifically
address a hazardous substance, pollutant, contaminant, remedial action,
location or other circumstance at a site. A requirement is "applicable"
if the remedial action or circumstances at the site satisfy all of the
jurisdictional prerequisites of the requirement.
Relevant and appropriate requirements are cleanup standards, standards
of contra], and other environmental protection requirements, criteria or
limitations promulgated under Federal or State law that, while not legally
"applicable" to a hazardous substance, pollutant, contaminant, remedial
action, location or other circumstance at a site, address problans or
situations sufficiently similar to those encountered at the site that
their use 1s well suited to that site.
"A requirement that is judged to be relevant and appropriate must be
complied with to the same degree as if it were applicable. However,
there is more discretion in this determination: it is possible for only
part of a requirement to he considered relevant and appropriate, the
rest being dismissed if judged not to be relevant and appropriate in a
given case." (Interim Guidance on Compliance with Applicable or Relevant
and Appropriate Requirements, p. 3, from J. Winston Porter,
dated July 9, 1987) (Record # )
-------
While non-promulgated advisories or guidance documents issued by Federal
or State yovernments do not have the status of potential ARARs, they
nay be considered in determining the necessary level of cleanup for pro-
tection of human health and the environment. (See Interim Guidance on
Compliance with Applicable or Relevant and Appropriate Requirements, from
J. Winston Porter, dated July 9, 1987).
GROUNDWATER
Four yroups of federal standards and criteria and other health-based
levels were considered in determining the ARARs for the groundwater
cleanup standards for the remedial action at the Seymour Site.
MCLG - Maximum Contaminant Level Goals established under the Safe Drink-
ing Water Act. MCLGs are nonenforceable health goals, set at levels
where no known or anticipated adverse health effects will occur in ex-
posed people, and which allow for a margin of safety.
MCL - Maximum Contaminant Levels established under the Safe Drinking
Water Act. -These are the niaxinm contaminant concentrations allowed
in regulated public water supplies. Levels are based on a chemical's
toxicity, treatability (including cost consideration), and analytical
1imits of detection.
KCRA Groundwater Protection Standards • RCRA Groundwater Protection
Standards established under 40 CFR Section 264.94 include Background
Concentrations, Maximum Concentration Limits, and Alternate Concentra-
tion Limits (ACLs). These standards are specified in permits issued
to hazardous waste managaient facilities pursuant to RCRA.
WQC - Ambient Water Quality Criteria for Hunan Health established under
the Clean Water Act. The original WQC assumed that people drank con-
taminated surface water and ate contaminated fish that lived in that
water. The Superfund program has adapted these criteria to groundwater
by calculating the corresponding contaminant concentration for
exposure to contaminated drinking water alone. (Superfund Public
Health Evaluation Manual, October 1986) (Record #_^ )
potential ARARS
A. Safe Drinking Water Act--MCLGs and MCLs apply at the tap to "public
. ' water systems,"" which are water systems havi-ng at least 15 service
connections or regularly serving at least 25 individuals. (42
U.S.C. section 300(f)(4)) A public water system has not been
contaminated by the Seymour site; therefore, SDWA standards v
are not "applicable" to the site. Whether these standards are
"relevant and appropriate" to the site is discussed below.
1. MCLGs—
Section 121(d)(2) of SARA mandates that remedial actions
require a level or standard of control that attains MCLGs
if they are relevant and appropriate under the circum-
stances at a site. As cleanup goals, MCLGs may be rele-
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vant to remedial actions at Super-fund sites where the
groundwater at the site is or nay be used for drinking
water. Although most area residences are connected to
the Seymour municipal water system, the aquifers at the
Seymour, site are used for drinking water. (See RI, Vol. 1,
pp. 9r21) (Record » . ) MCLGs may therefore be
"relevant" to the remedial action at the site; however,
they are not "appropriate." EPA's "Interim Guidance
on Compliance with Applicable or Relevant and Appropriate
Requirements" states on. page 9 that MCLs are generally
the relevant and appropriate cleanup standard for ground-
water that may be used for drinking. (Record # )
(MCLs are discussed below). Unlike MCLs, MCLGs are
based entirely on health considerations and do not take
cost or feasibility into account. As health goals,
MCLGs are set at levels where no known or anticipated
health effects may occur, including an adequate margin
of safety. MCLs are required to be set as close as
feasible to their respective MCLGs and are set at the
same levels as MCLGs for noncarcinoyens. MCLs are the
standards for public water supplies. EPA has therefore
determined that MCLs, rather that MCLGs, are relevant
and appropriate as cleanup standards for groundwater
that may be used for drinking water, such as the aquifers
at the Seymour site. (See also correspondence dated May
21, 1987 from Lee M. Thomas to the Honorable James J.
Florio) (Record # ^ )
2. MCLs - MCLs are "relevant" to the remedial action at the
Seymour site because the aquifers are or may be used for
drinking water. MCLs are "appropriate" because they set
enforceable drinking water standards for public water
supplies. (See July 9, 1987 "Interim Guidance on Compli-
ance With Applicable or Relevant and Appropriate Require-
ments" and the May 21, 1987 Lee M. Thomas letter to the
Honorable James J. Florio) (Record # and
& ) As MCLs apply to water at its point of distri-
bution ("at the tap"), these levels are appropriate for
groundwater at this site because residential wells that
would use the aquifers generally have minimal or no
treatment. Thus, these standards will have to be applied
In the groundwater itself to ensure safe levels at the
tap.
8. Resource Conservation and Recovery Act (RCRA) - The RCRA regulations
applicable to facilities treating, storing or disposing of hazardous
waste became effective November 19, 1980. (See 40 CFR sections
264.1 and 265.1). The Seymour facility ceased operating and
accepting wastes prior to that date. These regulations are
therefore not legally "applicable" to the Seymour facility for
the groundwater cleanup. Whether RCRA regulations are "relevant
and appropriate" to this site is discussed below.
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1. Listed Maximum Concentration Limits - The yroundwater pro-
tection standards at 40 CFR Section 254.94(a)(2) list
- maximum concentration limits for fourteen compounds. There
are listed levels for three contaminants of concern at the
Seymour site. The levels listed at 40 CFR 264.94(a)(2)
are 50 uy/1 for lead, 10 ug/1 for cadmium, and 1,000 .ug/1
for barium'. These levels are based on the Safe Drinking
Water Act MCL, which is set at a level protective of
human health and the environment. These levels are
therefore "relevant and appropriate" for the groundwater
cleanup at the site.
2. Alternate Concentration Limits (ACLs) - EPA may estab-
lish ACLs in lieu of background levels or listed maximum
contaminant levels if the ACL "will not pose a substan-
tial present or potential hazard to human health or the
environment as lony as the [ACL] is not exceeded." 40
CFR § 264.94(b). Section 121(d)(2)(B)(ii) of CERCLA
restricts the use of ACLS as cleanup standards for on-site
cleanups that assume a point of human exposure beyond
the facility's boundaries. The selected remedy for the
Seymour site does not assume a point of human exposure
to contaminants exceeding ACLs beyond the facility boundary:
the cleanup standards are required to be met at the boundary.
Therefore, the CERCLA Section 121(d)(2)(B)(ii) restriction
on the use of ACLs as cleanup standards does not apply
at this site. ACLs are "relevant and appropriate"
requirements for the groundwater cleanup at the Seymour
site, except for those contaminants with a maximum concentra-
tion limit listed at 40 CFR Section 264.94(a)(2) (discussed
above) that are sufficiently protective of human health
and the environment. When the overall health based cleanup
standards of 1 x 10'5 at the site boundary, 1 x 10"6 at
the nearest receptor, and the HI of 1 are met, by definition
the concentrations of the the individual contaminants in the
yroundwater will not present a threat to human health and
environment. Those residual concentrations are the ACLs.
3. Background Levels - RCRA groundwater protection regulations
require that the concentration of a hazardous constituent
must not exceed background or the listed maximum concen-
tration limit £r the ACL. Tfie listed maximum concentration
limits for barium, lead and cadmium, must be met at the
site. ACLs for other contaminants'will be based on the
remaining concentration of a particular contaminant in the
yroundwater at the time the overall level of protection
for human health and the environment is met. Background
levels are therefore not relevant and appropriate cleanup
standards for the Seymour site.
C. Water Quality Criteria (WQC) Established Under the Clean Water Act
The Clean Water Act is not legally "applicable" to the groundwater
cleanup at the site, with the exception of pretreatment requirements
(discussed below) for discharge of treated groundwater to the Seym.our
POTW. With this exception, there is no current or planned point
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source discharge.from the facility to surface waters. Section 121(d)
(?) of SARA requires remedial actions to attain WQC wnere the criteria
are "relevant and appropriate under the circumstances of the release
or threatened release." This determination is based on the designated
or potential use of the .water, the nedia affected, the purposes of the
criteria, and the latest infomation available.
The aquifers beneath the site are current and potential sources of
drinking water, and the shallow aquifer at times discharges to Northwest
Creek and the Von Fange Ditch. Therefore, WQC that have been adapted
for drinking water only (in the Superfund Public Health Evaluation
Manual, Record # ) and WQC for protection of freshwater aquatic
organisms are "relevant and appropriate" for the groundwater cleanup
for the site.
Other Standards Necessary to Protect Human Health and the Environment
In addition to these potential ARARs, the following non-promulgated
advisory standards were considered in determining groundwater cleanup
levels that are necessary for chenicals for which there are no ARARs
or where an ARAR is not sufficiently protective of human health
or the environment.
HA - Health Advisories developed under the Safe Drinking Water Act for
contaminants not having a MCL. Health Advisories nay apply to short
term exposure, long tern exposure or chronic exposure.
RfD - Verified Reference Doses developed by an intra-agency EPA work-
group. These values represent an acceptable daily intake of noncarcino-
genic chenicals (or, for a carcinogen, an acceptable daily intake of
that chemical considering its noncarcinogenic toxicity). The corres-
ponding acceptable concentration of a contaminant in drinking water
is calculated by assuming that a typical 70 kg person drinks 2 liters
of water per day.
Concentration (mg/1) = RfD(mg/kg/d)x [70 kg]/[2 1/d]
PF_ - Potency Factors developed by EPA to characterize the potency of
a given carcinogen. These factors are used to estimate the incranental
increase in cancer in a large group of people due to chronic exposure
to a carcinogen at a given concentration. The calculations assume
that a typical person weighs 70 kg and drinks 2-liters of -contaminated
water per day. Assuming a linear dose response curve (appropriate for
risk below 0.01):
Risk * PF((mg/kg/d)-l) x concentration (mg/1) x [2 1/d] / [70 kg]
Determination of Cleanup Standards
The MCLs, which are ARARs for groundwater at the Seymour site, are used
as cleanup levels where available and where they provide sufficient
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protection of hunan health and the environment, taking into account
cunulative health effects.
U.S. F.PA's policy on cleanup standards for Supert'und sites considers
an excess lifetime cancer risk of 1 x 10~4 to 1 x 10"? to be an accep-
table cleani/p level-. -(See July 9, 1987 "Interim Guidance on Compliance
with Applicable OP Relevant and Appropriate Requirements," page 9)
(Record # ) The exact excess cancer risk acceptable is based
on-site specific circumstances. The 1 x 10'*> risk level has generally
been applied at Superfund sites in the past.
A. Carcinogenic Effects
As discussed above, MCLs are ARARs for the groundwater cleanup at the
Seymour site. At the Seymour site, chloroform cleanup standards are
being compared.to the MCL for total trihalomethanes because there is
no specific standard for chloroform and it is a trihalomethane.
When determining whether MCLs and other standards are protective of
human health and the environment, the possible effects of simultaneous
exposure to many contaminants were considered. For the carcinogenic
compounds with proposed MCLs, the carcinogenic risk associated with
the proposed MCL was calculated using the potency factor. The cumula-
tive risk from exposure to these compounds is assumed to be additive,
rather than synergistic or antagonistic. (See Superfund Public Health
Evaluation Manual, October 1986) (Record #____) The additive risk.
of the six organic carcinogens at their proposed MCLs is 4 x 1U~*.
The total excess cancer risk in the groundwater at the Seymour Site
for all carcinogenic contaminants (including those with noMCLs) would
increase the 4 x 10'4 risk because any concentration of a carcinogenic
contaminant has an associated risk. This total risk is not acceptable
because it is not within EPA's acceptable risk range of 1 x !U'a to 1
x l(J-7. (See FS Guidance and Superfund Public Health Evaluation Manual)
(Record* _and # ) This cumulative risk level and a
number of other factors create a need for cleanup standards that are
more stringent than MCLs. These factors include: a large number of
contaminants (both carcinogenic and noncarcinogenic) are present in the
groundwater and there is a limited understanding of these contaminants'
cumulative effect on human health and the environment; low levels of
contaminants (below the MCLs) will continue to migrate when the extrac-
tion system is terminated; and the aquifer is a potential source of
drinking water. A cumulative excess cancer risk that is more stringent
than the MCLs 1s therefore necessary to ensure sufficient protection
of human health and the environment.
EPA has determined that a cumulative excess cancer risk of 1 x Itr5 for
groundwater cleanup at the Seymour site must he attained at and beyond
the site boundary. This risk level is within the acceptable risk
range (1 x 10'* to 1 x 10'7) and is appropriate for the circumstances
at the site. . A number of the circumstances justify this risk level.
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This is a conservative risk level that will provide protection of
human health. A more conservative risk level is not required to be
met at the site boundary because there must be provisions during the
cleanup fop institutional controls on the area of the groundwater
contamination plume; the current land use of the area is agricultural;
and the area is zoned industrial for any future development. Also,
the groundwateris currently highly contaminated which makes it more
difficult to restore the aquifer.
Consistent with the FS Guidance, a 1 x 10~6 excess cancer risk must be
maintained at the site's nearest receptor. (Record # ) (See Fig-
ure A.17 on page 9 for the location of the nearest current receptor in
the shallow aquifer) This more stringent cleanup standard is necessary
because no contamination has been detected at this receptor to date
and the well is being used for watering livestock and possibly human
consumption.
The procedure that must be used for calculating the excess cancer risk
level is detailed in the Superfund Public Health Evaluation Manual.
(Record # )
The cleanup level for groundwater was not determined considering the
potential carcinogenic effects from ingest ion of the groundwater
in combination with the risks from inhalation of air or ingestion of
soil. Simultaneous exposure to contaminated air and groundwater is
not expected because of the prohibition on the use of groundwater
until cleanup is achieved. The air emissions from the vapor extrac-
tion system are expected to toave ceased by the time the'groundwater
is usable. If the vapor extraction system is still in operation,
the cumulative excess lifetime cancer risk from air and groundwater
at the nearest receptor must not exceed 1 x 10"6. The soil is being
capped, so any direct exposure to contaminated soil is eliminated.
In addition to meeting ttie total cumulative excess cancer risk level of
1 x 10"5 at the site boundary, the individual MCLs for the carcinogenic
compounds must also be met. The compounds to be considered in the
calculation of the cumulative excess cancer risk and their MCL are:
- benzene (MCL-5 ug/1) - methylene chloride
- chloroform (MCL-100 ug/1) - tetrachloroethene
• • 1,2 dichloroethane (MCL-5 ug/1) - 1,1,2 trichloroethane
- 1,1 dkhloroethene (MCL-7 ug/1) - trichloroethene (MCL-5 ug/1)
- 1,4 dioxane - vinyl chloride (MCL-2 ug/1)
This list includes all the carcinogens by the oral route of exposure
that have been identified in the groundwater. This list of compounds
must be revised if other compounds are identified as possible, probable
or known human carcinogens.
The cumulative risk calculation shall be performed in accordance with
the methods being employed by EPA in the Superfund Public Health
Evaluation Manual and subsequent revisions in effect at the time the
calculations are performed. The toxicity data used shall be the most
current data contained in the Superfund Public Health Evaluation Manual
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or avail able from EPA's Cancer Assessment Group.
8. Non Carcinogenic Effects
For noncarcinoyenic chemicals there is also a need to establish an
overall cleanup level'for the ground water. Again this need arises
because of the larye number of contaminants in the yroundwater. The
method recomnended to address effects of multiple noncarcinogenic
chemicals is the chronic health index (HI). The method is defined in
more detail in the Superfund Public Health Evaluation Manual (SPHEM) ,
Octooer 1986. (Hecord # )
The qualifications to the HI process identified in the Superfund Public
Health Evaluation Manual are recognized. However, the HI process is
a reasonable procedure to attenpt to take into consideration cumulative
noncarcinogenic health effects and will provide a conservative measure
of the potential threat to human health from contaminants in the ground
water. The justification for using this approach is based on the sane
site specific circumstances described in paragraph A above regarding the
1 x 19'5 excess lifetime cancer risk level.
The total HI for the following compounds shall not exceed 1.
- bariun (MCL-50 ug/1) - methylene chloride
- benzene (MCL-5 ug/1) - nickel
- copper - phenol
- 2-butanone ' - tetrachloroethene
- cadmium (MCL-10 ug/1) - toluene
- chloroform - 1,1,1 trichloroethane
- ethyl benzene - xylenes
- lead (MCL-50 ug/1) - vinyl chloride (MCL-2 ug/1)
- manganese
In addition, for those contaminants that have MCLs, the MCL nust not be
exceeded.
This list was developed from compounds identified and used in the endan-
gement assessment performed as part of the RI. The list should be
updated as additional reference doses or other information becomes avail-
able and as MCLs are established for additional compounds.
•The calculation of the HI shall be performed in accordance with the
Superfund Public Health Evaluation Manual and subsequent revisions.
Reference doses used in this calculation shall be taken from the
Superfund Public Health Evaluation Manual. (Record # )
The carcinogenic risk level is expected to be the ultimate factor for
establishing compliance with cleanup standards because of the low
concentrations associated with excess lifetime cancer risk levels.
In summary, the ARARs for groundwater cleanup standards for both the
shallow and deep aquifer are the MCLs from the Safe Drinking Water
Act,-the listed maximum concentration limits and ACLs as discussed at
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40 CFR Section 264.94, and the water quality criteria established
pursuant to the Clean Water Act.
In accordance with EPA policy (See "Interim Guidance on Compl iance. with
Applicable or Relevant and Appropriate Requirements," dated July 9, 1987)
(Record # ) the MCLs are first considered as cleanup standards
for the groundwater. However, because of cumulative health risks,
the MCLs were not sufficiently protective of human health. Therefore
health based standards of 1 x 10"^ cumulative excess lifetime cancer risk
and a chronic health index not to exceed 1, are set for the groundwater
cleanup standard at the site boundary. 'A 1 x 10"^ excess lifetime
cancer risk must be met at the nearest current receptor. In addition,
the MCLs must, at a minimum, be met for a particular compound at both
compliance points. Although specific concentration levels required
for cleanup are not established at this time, the cumulative risk
calculation and the chronic HI calculation are dependent upon the
concentrations present in the ground water. The health based standard
allows for evaluating different contaminants at different concentrations
that may be present in the groundwater at the time when the groundwater
extraction system may be terminated. Different compounds will be
removed from the groundwater preferentially. The mobility and original
concentration of a contaminant will be among the factors that determine
the time required for removal from the groundwater. Arriving at specific
concentration levels for individual contaminants based on the cumulative
health risk is consistent with the requirement for an ACL under RCRA
because they are protective of human health and the environment and
because of the Direct relationship between the health based standard
and an associated concentration level. The factors in 40 CFR Part
264.94(b) were considered when the cleanup standard was determined.
The cleanup standards are consistent with and more stringent than
the water quality criteria for protection of human health for con-
sumption of water only and for the protection of fresh water aquatic
organisms. The water quality criteria consider an excess cancer risk
of 1 x 10~5 to 1 x 10~' for individual compounds to be an acceptable risk
range. The cleanup standard requires a cumulative excess cancer risk
of 1 x 10"5 at the site boundary, so excess cancer risks for individual
compounds must necessarily be within the 1 x 10"5 to 1 x 10~? range
identified in the water quality criteria document.
C. Compliance Point
The point of conpl iance for the ARARs, the 1 x 10'5 cumulative excess
lifetime cancer risk level and the chronic HI of 1 is at and beyond
the site boundary; or from a practical standpoint, the edge of the
cap. The remedial action includes a multi-media cap over the site.
Future use of the site is not envisioned, and deed restrictions
prohibiting use of the site are a part of the remedial action.
Therefore, the aquifers do not become actual or potential sources of
drinking water until they reach the site boundary. The site boundary
is therefore an appropriate point of .compliance for groundwater
cleanup standards and is consistent with 40 CFR Section 264.95. A
second compliance point for the MCLs, the 1 x 10-6 cumulative excess
lifetime cancer risk and the chronic HI of 1 in the groundwater is the
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nearest current receptor. The compliance points apply to both the
shallow and deep aquifers.
D. Technical Impracticability
The possibility exists of not being able to technically neet the clean-
up levels. Therefore provisions for making such a claim must be care-
ful ly developed. Section 121(b)(2) of SArtA allows for a waiver. Gene-
rally the approach to a waiver of the cleanup levels based on technical
impracticability should be based on information developed during the
operation of the selected groundwater extraction and treatment system.
A monitoring program must be carefully designed to develop needed in-
formation. This information must then be evaluated from both an overall
qualitative perspective and a quantitative perspective. The qualitative
evaluation should, include, among other things, water quality at extrac-
tion and monitoring wells, possible modifications to the extraction
system that could help achieve cleanup levels, and an endangerment assess-
ment of the impact of discontinuing operation of the extraction system.
The quantitative evaluation should consider, among other things, a statis-
tical analysis of contaminant concentrations over time and the cumulative
mass of contaminants being removed by the extraction system compared to
the mass of contaminants remaining in the aquifer. The groundwater model
developed as a part of the RI must be calibrated and verified for con-
taminant mass transport to aid in predicting aquifer behavior and
determining if cleanup levels are met at the determined compliance points.
State ARARs
Based on information supplied by the State of Indiana in an August 3, 1986
letter from Harry John Watson III to Lawrence Kyte (Record # ), State
ARArtS for groundwater at the Seymour site include:
1. Narrative water quality standards and non-degradation
standards requiring waters to be free of substances which
are acutely toxic or cause serious adverse physiological
response, or are believed to be chronically toxic,
carcinogenic, mutagenic or teratogenic, and
2. Numerical drinking water standards for public water supplies.
The State of Indiana has not identified .these standards as more strin-
gent than the Federal standards previously identified. Consistent with
the State's narrative standards, the recommended cleanup levels have
accounted for chronic health threats.
Discharge
For discharge and subsequent treatment of extracted groundwater, the ARARs
are dependent on the point of discharge. The Department of Public
Works of the City of Seymour and IDEM have preliminarily identified the
pretreatment standards for the metal finishing and electro-pi at ing
industry to be appropriate for discharge to the Seymour sewer system
of treated groundwater from the Seymour site.
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These pretreatment standards are:
SUBSTANCE . MAXIMUM CONCENTRATION (mg/1)
Arsenic ' 1.0
Cadniun " 1.0
Copper 5.0
Cyanide 1.0
Lead 1.0
Mercury 0.5
Nickel ' 5.0
Total Chromium 10.0
Zinc 10.0
Phenols 0.5
Oil and Grease 100.0
Total Toxic Oryanics 2.13
Total Suspended Solids* 13.4
*Average daily discharge for four consecutive monitoring days.
A more thorough evaluation of water quality and the POTW's ability to
handle the water must be performed as a part of the plume stabilization
project and as a part of the final groundwater extraction system.
This evaluation must be consistent with 40 CFR 403.5 and local POTW
regulations. The major criteria considered in 40 CFR 403.5 are pass
through the POTW without treatment, interference with POTW operation,
and contamination of POTW sludge..
In order to discharge from a Superfund site to a POTW, certain issues
identified in an April 15, 1986 memorandum entitled "Discharge of
Wastewater from CERCLA Sites Into POTWs" from Henry L. Longest,
Director, Office of Emergency and Remedial Response, Rebecca Manner,
Director, Office of Water Enforcement and Permits, and Gene Lucero,
Director, Office of Waste Programs Enforcement, to Waste Management
Division Directors, Region I-X and Water Managanent Division Directors
Region I-X, must be evaluated.
The first Issue that must be evaluated concerns the compatibility of
the discharge with the POTW. An evaluation of the anticipated water
quality that would reach the POTW is provided in the Work.PI an for
the Plume Stabilization Project. Because of the pretreatment being
provided at the site prior to discharge, and the treatment and dilu-
tion of the discharge at the POTU, no "pass through" or interfer-
ence with the POTW's operations or accumulation in the sludge is ex-
pected. However, this will have to be verified by continued monito-
ring. No hazards are expected to employees at the POTW-because of
the pretreatment of the discharged water. The air stripper included
in the treatment scheme will greatly reduce the concentration of VOCs
which could cause a hazard to employees of the POTW.
•The quantity of water initially expected to be discharged during the
plume stabilization project is less than 150 gpn, which is approximately
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2Q% of the excess capacity of the Seymour POTW and approximately 15%
of the average daily wastewater flow. The design capacity of the
plant is 4.3 nil! ion gallons per day (ngd) and current average wastewater
flow is 3.2 myd. However, it has been noted from the Indiana Department
of Environmental Management that hydraulic overloading of the plant
occurs during and after periods of precipitation. (See correspondence
from Jacqueline W. Strecker to David Favero, dated August 22, 1986)
(Record # ) This factor must be taken into consideration when
determining the operational parameters for the extraction/treatment
system.
The second point of consideration is the POTW's ability to ensure compli-
ance with applicable pretreatment standards and requirements. The Seymour
POTW has an approved pretreatment program. Monitoring reports will be pro-
vided to the Seymour POTW. The monitoring will either be performed through
funding of the Su-perfund program, the State during the 0 & H period, or
responsible parties conducting the remedial action with EPA oversight.
Volatilization fran the wastewater is the next point to consider. As
stated above, an air stripper is a part of the selected treatment system.
If determined to be necessary, air enission control equipment will be in-
stalled on the air stripper. The potential is low for significant volati-
lization at the POTW because most VOCs will have been volatalized during
air stripping. Should the air stripper not be included in the pretreat-
nent system because it is determined not to be necessary to meet pre-
treatment requirements, this point must be reevaluated.
The potential for groundwater contamination from transport of the
treated groundwater or an impoundment at the POTW is the next concern.
The potential exists for groundwater contamination along the sewer
systen transporting the treated water. Again the pretreatment at
tne site minimizes any expected impact of leakage from the sewer
to the groundwater. The area of greatest potential impact is fron
the site to the sewer's hookup with other lines from the industrial
park. At that point mixing would further minimize any potential
impact of leakage to groundwater. A portion of the sewer line
was integrity tested during the plume stabilization project. The re-
sults are being evaluated.
The potential of groundwater contamination from an impoundment at the
POTW is diminished because of the pretreatment at the site and the
additional treatment and mix at the plant. Groundwater mo/iitoring at"
'the POTW is therefore not recommended specifically as a result of
receiving pretreated groundwater.
The next point of concern is the effect of water discharged from the
Seymour site on maintaining water quality standards in the South Fork
of the White River, the POTW's receiving stream. The results of the
evaluation contained in the Plume Stabilization Work Plan indicate
tnat there will De no detectable levels of toxics in the discharge of
the POTW. (See Plume Stabilization Work Plan) (Reco'rd # )
Further evaluation of this concern will be performed. When flow is
increased for the final remedial action, treatment must also be
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appropriate :to assure water quality standards are maintained in
the East Fork of the White River.
The next point of concern is applicability of other environmental
laws at the POTW because it has received a discharge from a Superfund
site. All water discharged to the POTW wi'll nix with domestic waste
along the transportation route to the POTW. Therefore RCRA require-
ments would not apply to the POTW. (See 40 CFR Section 261.4)
Disposal of sludye is not anticipated to be a problem but will be
evaluated more thoroughly during the process of receiving authorization
to discharge. Monitoring of the sludge'will continue after discharge
is started. No other environmental requirements have been identified
that would apply to the POTW because it is receiving wastewater
fron a Superfund site.
The last point of concern is the cost of managing water from a Super-
fund site. Increased costs will be related to monitoring requirements.
Parameters that are not currently monitored will be required. There
are potential costs associated with sludge disposal should the con-
taminants accumulate in the POTW's sludge due to improper operation
of the pretreatment system or should the current land application
sites refuse to accept the sludge.
Based on the evaluations performed on the discharge of treated ground-
water to the Seymour POTW, it was determined in tne FS that this is a
viable -leans of managing the wastewater. An authorization to discharge
must be obtained from the City of Seymour prior to any discharge to
the POTW occurring. The considerations in the policy on CERClA dis-
charges to POTWs will continue to be reevaluated as additional data
becomes available.
The public has been informed of the U.S. EPA's intention to discharge
treated groundwater from the Seymour site to the Seymour POTW. No
negative comments were received. In addition preliminary contacts
have been nade on this matter with the Director of the Seymour Sanitary
District, the City of Seymour Department of Public Works, the IDEM
Water Division and U.S. EPA's Region V Water Division to ensure that
the treated groundwater is discharged in compliance with applicable
federal, state and local laws. Additional coordination and document
submittal will occur prior to actual discharge to the POTW. A con-
sultant has been retained to represent the City of Seymour's interest
'in this matter.
If the discharge of treated groundwater were to occur to the Northwest
Creek, the NPOES regulations would apply and a NPDES permit would be
necessary.
If reinjection of treated groundwater or injection of water from another
source were to be incorporated into the remedial action, the substantive
requirements of the UIC program would apply. A permit would not be neces-
sary, however, because the. injection would be an on-site action. This
would qualify it for the permit exemption in SARA.
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SQIL
RCRA contains the ARARs for contaminated soil at the Seymour site. Closure
and post-closure requirements of RCRA are not "applicable" to the remedial
action because the facility ceased disposal of hazardous wastes prior to
November 19, 1980. (See 40 CFR 264.1) RCRA's closure and post closure re-
quirements are, however, generally "relevant and appropriate." The RCRA
closure performance standards set forth at 40 CFR Section 264.111 are
narrative and state:
The owner or operator must close the facility in a manner that:
(a) Minimizes the need for further maintenance; and
(b) Controls, minimizes or eliminates, to the extent
necessary to protect human health and the environment,
post-closure escape of hazardous waste, hazardous
constituents, leachate, contaminated run-off, or
hazardous waste decomposition products to the ground
or surface waters or to the atmosphere; and
(c) Complies with the closure requirements of this subpart
including but not limited to the requirements of
[specific closure provisions for various types of
facilities].
Closure standards for containers, tanks, surface impoundments, and
landfills are generally "relevant" and "appropriate" to the Seymour site.
The closure requirements for containers are generally relevant and
appropriate because drums of waste material generated during the RI
containing drill cuttings, groundwater and protective clothing meet
the RCRA definition of "container." (See 40 CFR Sections 264.170 and
260.10).
The closure requirements for tanks are generally relevant and appropriate
to the treatment units used to treat collected surface water runoff.
(See 40 CFR sections 264.220 and 260.10).
The surface Impoundment created to collect the surface water runoff
causes the closure and post-closure requirements for surface impound-
ments to generally be relevant and appropriate. (See 40 CFR sections
264.220 and 260.10).
Because the disposal of hazardous wastes occurred at the site, the land-
fill closure and post-closure requirements are generally relevant and
appropriate for.the Seymour site. One of the landfill closure
requirements that is specifically relevant and appropriate calls for
placing a cap on the disposal facility. (40 CFR Section 264.310 (a))
A cap is part of the selected remedial action.
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As the State is authorized to implement the RCRA program, State require-
ments are equivalent to Federal requirements. See 320 [AC 4.1-46-1
et. seq. U.S. EPA has not been notified of any more stringent or broader
in scope State requirements.
The land disposal restrictions of RCRA also apply to any off-site disposal
of hazardous waste. (RCRA § 3004(d) and (e))
Contaminated sediment will be consolidated on the existing disposal area,
which is the entire fenced area of the site. The sediments must be de-
watered, if necessary, prior to consolidation in order to comply with the
land disposal restrictions of RCRA. (See 51 Fed. Reg. 40572)
Other relevant and appropriate RCRA requirements include a notice in
the deed to the .property (40 CFR §264.119), access restrictions (40
CFR 264.14 and 264.117), inspection requirements (40 CFR §§ 264.1.5 and
264.117), and disposal or decontamination of equipment (40 CFR § 264.114).
The remedial action selected for the Seymour site meets all applicable
or relevant and appropriate RCRA requirements.
AIR
The air emission requirenents of the Indiana State Implementation Plan
(SIP) Rule 325 IAC Article 8 Section 6 apply to sources that emit greater
than 25 tons per year of volatile organic compounds (VOCs). The selected
remedy for the Seymour site is not expected to emit greater than 25 tons
per year of VOCs to the air. Therefore, these requirements are not
applicable. If emissions from the site were to exceed 25 tons per year"
of VOCs, the technical, substantive requirements of the SIP would apply.
The requirement of Rule 325, Article 2 for registration of VOC emission
sources does apply and will be met.
Although there are no applicable emission standards, an evaluation
of the air emissions must be made to determine if they pre-
sent an unacceptable threat to human health and the environment. Two
component-srof the selected remedy emit to the air: 1. the air stripper
in the yround water treatment system and 2. the vapor extraction system.
These two sources must be considered in combination and the potential
human impacts from the total air emissions from the site evaluated. As
with the uroundwater cleanup standard, air emissions must not exceed
a 1 x 10"° excess lifetime cancer risk level or a chronic health index
(HI) of 1 at the nearest receptor.
Also, consistent with the FS guidance and as explained on page 34,
the cumulative excess lifetime cancer risk from exposure to contaminated
air and yroundwater should not exceed 1 x 10~6.
RADIATION
At another Superfund Site in Region V radon was discovered accumulated
on carbon adsorbers used in treatment of groundwater. The radon was pre-
sent at levels that pose a potential threat to human health and the
environment. The radon was naturally occurring.
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Because of this finding, radon will have to be considered in implementing
the selected remedy. For example, soil gas sampling during the pre-desiyn
investigation phase must be performed and monitoring of air emissions and
carbon used in any treatment process must be performed.
Radon must be factored into the calculations to determine if the cleanup
standards for air, described above, are met.
ENFORCEMENT STATUS
Negotiations with the PRPs are on-going. As stated in the site history,
a lawsuit was filed in the Federal District Court for the Southern
District of Indiana in 1980. In 1984 a case management order was
issued that provides the framework for negotiations between the
defendants and the United States. There are approximately sixty
defendants currently named by the United States in the ongoing suit.
These defendants have in turn added approximately sixty third party
defendants. Summaries of information linking defendants to the site
and relative contribution of waste volume have been provided to the
defendants.
negotiations are expected to continue into the fall of 1987.
COMMUNITY RELATIONS
The community of Seymour lias been concerned about the Seymour Recycling
Corporation Site since 1976. Air and surface water discharges, which
people in the area felt were responsible for detrimental public
health and environmental impacts, were migrating from the site.
Evacuation of 100 homes was necessary in March, 1980 due to a chemical
reaction that released toxic fumes. As a result, U.S. EPA became in-
volved with the site.
The community was relieved when the surface cleanup began in Decenber,
1982. A concern about drinkiny contaminated groundwater still existed.
In order to alleviate this concern, money from the court-held trust
fund, established as part of a 1983 settlement between U.S. EPA and
certain potentially responsible parties, was used to extend the city's
municipal water system to the Snyde Acres subdivision.
U.S. EPA has provided regular updates to the interested parties. In
addition, important documents and information have been placed in three
repositories in Seymour.
On October 9, 1986, U.S. EPA held a public meeting in Seymour to discuss
the results of the RI and FS and to answer any questions and receive
comments from the public. The prevailing concern of the public in regard
to the remedial action seemed to be getting the action implemented as
soon as possible.
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For more information on community relations, see the Responsiveness
Summary, Appendix 2.
- - FUTURE ACTIONS AND SCHEDULE
Future actions and a prelininary schedule for their implementation are
shown in Appendix 1; The schedule will no doubt go through many modifi-
cations as negotiations progress and the project becomes more thoroughly
defined in the design and implementation.
ATSDR COMMENTS
The Ayency for Toxic Substances and Disease Registry (ATSDR) performed
a health assessment for the Seymour Recycling Corporation as required by
Section of-104(i)(6)(a) SARA. The health assessment memorandum is dated
April 2, 1987. (Record # ) The report concludes, that no
population is at present known to be exposed to hazardous substances
from the site. The primary potential risk associated with the on- and
off-site contaminants is the possibility for chronic toxicity and/or
increased risk of cancer via low-level, repeated exposure should the
no-act ion alternative be chosen. ATSDR also stated-that all the alterna-
tives considered by EPA, except no action, and EPA-'s recommended
alternative are considered adequate to protect human health based
upon the data presented.
Specific recommendations included in the memo, pending the implemen-
tation of a suitable remedial action alternative, are:
1. Periodically monitor airport well #5 and the nearest
operational downyradient water supply well for vola-
tile organic contaminants. If or when volatiles are
detected, reassess the potability of the supply and
the likelihood of endangerment to any remaining area
wells. This nay necessitate the extension of water
lines to affected or potentially affected residences/
establishments.
2. Post signs in the contaminated area of northwest creek
identified for sediment removal to restrict recreational
activities.
At such time as the suitable remedial action alternative fs implemented,
dust control should be instituted for those surface areas disturbed
by removal/construction activity to minimize the production of beryllium
contaminated airborne particulates.
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APPENDIX 1
PROJECTED SCHEDULE FOR FUTURE ACTIONS
AT THE SEYMOUR RECYCLING SUPERFUND SITE
PHASE - Plune Stabilization Project
. Activity Projected Date
Conclude Negotiations for the . November, 1986 (Actual)
plume Stabilization Project
Install Plu.ne Stabilization September, 1987 (Actual)
Well
Initiate Construction of a Fall, 1987
Temporary Groundwater Treatment
System
Complete Aquifer Tests Fall, 1987
Operate and Maintain the Plume On-going
Stabilization System
PHASE - Negotiations for.Remedial Design (RD) and Remedial Action (RA)
Activity Projected date
Receive Proposal for Site Cleanup December, 1986 (Actual)
Complete the Government's Response January, 1987 (Actual)
to the PRP Cleanup Proposal
Conclude Negotiations Fall, 1987
PHASE - Implementation of RD/RA
Activity Projected Date
Complete Design of Groundwater Winter, 1988
Cleanup Component
Implement Groundwater Cleanup Spring, 1989
Component
Complete Design for Soil Cleanup Spring, 1989
Component
Implement Soil Cleanup Component Fall, 1989
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ATTACHMENT 2
INDEX OF THE ADMINISTRATIVE RECORD
SEPTEMBER 28, 1987
U.S. EPA, REGION V
CHICAGO, ILLINOIS
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•>« t
jay
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ff WASHINGTON, O.C. 20460
SEP 28 ;:.
of
SOLID WASTE ANO IMEMOCNCV "SSPONSi
MEMORNADUM
SUBJECT! OWPE Concurrence on the Record of Decision for the Seymour
Recycling Corporation Site, Seymour, Indiana
PROM i Gene Lucero, Directo
Office of Waste Programs Enforcement
T0» Valdus V. Adamkus, Administrator
Region v
Based on the August 31 ROD briefing, and the communications
and followup analysis conducted by our staffs, I concur on the
record of decision for the Seymour Recycling Corporation site a*
stipulated in the "Twelth Remedy Delegation Report - Part Two"
(May 19, 1987).
cct J. Winston Porter
Jack McGraw
Rues Wyer
Bill Constantelos
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