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_ -3-
The ditch flews to the southeast into the Grand calumet River, which is 1-
1/4 mile southeast of the site. The gradient in the ditch is very low and
the surface drainage area is minimal. Run-off is low and flow in the
ditch is probably largely ground water recharge. In addition, vegetation
in the ditch slows the flow rate. These conditions suggest minimal flow
velocities and greatly reduced sediment transport.
H. Sl*It! tCS'lDKy AND EJJFORCPdfT
Waste operations, including drum storage, were initiated at Midoo II
during the summer of 1976 by the same operator as at Midco I. In January
1977, (following a major fire at Midco I) Midwest Industrial Waste
Disposal Company was incorporated ostensibly for operating the Midco II
site, and the operations at Midco I were transferred to Midco II.
Operations included temporary bulk liquid and drum storage of waste and
reclaimable materials, neutralization of acids and caustics, and on-site
disposal via dumping into on-site pits, which allowed percolation into the
ground water. One of these pits, called the filter pit, had an overflow
pipe leading into the ditch (Figure 3) .
By April 1977, approximately 12,000 to 15,000 55-gallon drums of waste
materials were stored on site. In addition, approximately 10 above and
below ground tanks were. accumulated and used to .hold wastes. The drums
were stacked three high, and along with the tanks, were badly deteriorated
and leaking. The wastes included oils, oil sludges, chlorinated
solvents, paint solvents, paint sludges, acids, and spent cyanides. Also
present were waste saturated soils caused by leaking drums and spillage,
an open dump consisting mainly of drums, tires, and various wood wastes,
and an excavated pit containing unidentified sludges.
In May 1977, the Stream Pollution Control Board charged Midco II with
iirproper storage of cyanide waste, operation of -an open dump, failure to
obtain a construction or operation permit, and an improper discharge of
solvents, paint sludges, acids, and spent cyanides.
On August 15, 1977, a fire at Midco II destroyed equipment, buildings, and
an estimated 50,000 to 60,000 drums, including drums of cyanide stored in
a building. A substantial number of drums containing chemical wastes
survived the fire, although most were in a very deteriorated condition.
This included 75-100 drums of cyanide.
On February 24, 1978, the lake County Circuit Court ordered Midwest
Solvent Disposal Company to remove and properly dispose of drums of
cyanide and other industrial wastes from Midco I and Midco II within 90
days. This order was never obeyed.
In August 1979, the U.S. EPA sampled a paint tank, eight barrels, the
drainage ditch, drainage ditch sediment, and residue along the ditch.
Based on these results, the United States filed a complaint in the Federal
District Court in Hammond, Indiana under Section 7003 of the Resource
Conservation and Recovery Act (RCRA) (Civil Action No. H-79-556) . A
Preliminary Injunction and Temporary Restraining Order was granted on
-------
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FIGURE 1-3
MIDCO II
SITE MAP
FfiOM: EPA. On-Scene Coordinator's Report. 1984
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-4-
January 31, 1980 that directed a Midoo II property owner to report on
efforts to remove surface wastes from Midoo II. On December 4, 1980, the
operators of Midwest Solvent Disposal Company were ordered to submit to
U.S. EPA, a plan for the removal of all wastes stored on Midco II, and to
design a plan to determine the nature and extent of soil and ground water
contamination.
However, these court actions were ineffective, and in February 1981, the
U.S. EPA conducted an investigation to evaluate the possible presence of
an acute hazard to human health or the environment which could be remedied
by short-term safeguards. In response to site conditions, the U.S. EPA
funded the installation of a 10-foot high fence around the site. The
fence was completed in August 1981.
The U.S. EPA funded a hydrogeologic study of the site during 1981 to 1983,
in order to identify contaminants present in the soil and ground water,
determine the ground water flow characteristics, and ascertain the extent
of contamination attributable to site operations.
On January 19, 1984, the United States filed its First Amended Complaint
for Civil Action No. H-79-556, adding claims for injunctive relief under
Section 106 of the Comprehensive Environmental Response Compensation and
Liability Act (CERdA) and for recovery of response costs incurred by the
United States under Section 107 of CERdA, and adding generator
defendants.
From February to March 1984, the U.S. EPA conducted emergency removal
activities, including the repair and extension of the site fence and the
removal of 413 drums of waste. From January - March 1985, U.S. EPA
removed the remaining drums (except for 5 drums containing PCS
contaminated soils), tanks and debris from the surface of the site.
At the end of July 1985, the U.S. EPA began emergency removal of the
sludge pit and filter bed contents (Figure 3). These materials were
highly contaminated with PCBs and cyanide. The materials were excavated
and placed in separate piles on site. The sludge pit was backfilled with
crushed stone and the filter bed was backfilled with crushed stone and
debris fron the site, such as old tires, tire rims and construction waste.
In December 1985, and January 1986, the PCB contaminated soil pile was
removed and disposed of in an off-site hazardous waste landfill, and most
of the cyanide contaminated pile was removed.
Midco II was placed on the National Priorities List (NPL) in October 1984.
The NPL is a list of abandoned or uncontrolled hazardous waste sites that
are eligible for investigation and remediation under CERCLA.
The U.S. EPA completed a Work Plan for a Remedial Investigation/
Feasibility Study (RI/FS) for this site in February 1985. The purpose of
the RI was to collect data needed to determine the full extent of hazards
remaining at the site and to evaluate alternatives for remedial actions.
The RI Workplan included geophysical, soil gas, soil, hydrogeological,
surface water, surface sediment and ground water investigations. However,
-------
-5-
the U.S. EPA discontinued its work on the RI/FS in April 1985 when a group
of defendants agreed to conduct the RI/FS in accordance with the U.S. EPA-
approved Work Plan.
An agreement was formalized on June 19, 1985, by a Partial Consent Decree
in United States of America v. Midwest Solvent Recovery, Inc. et. al.
lodged with the United States District Court for the Northern District of
Indiana. This Partial Consent Decree required reimbursement of past costs
and specified that an RI/FS be completed in accordance with the U.S. EPA's
Work Plan for the Midco II site by the Defendants. Litigation was stayed
until completion of the RI/FS.
The contractor for the defendants started work in May 1985. After review
of the first draft Remedial Investigation (RI) report, U.S. EPA required
additional sampling in February 1987. The sampling was completed and a
final RI report was approved by U.S. EPA in March 1988. The contractor
submitted the final FS report in February 1989.
III. COMMUNITY RELATIONS
A public meeting was held on July 18, 1985, to explain the proposed
Remedial Investigation/Feasibility Study. U.S. EPA updated the community
on the status of the RI/FS using fact sheets in November 1987 and December
1988.
A Proposed Plan was prepared explaining alternatives evaluated and the
basis for preference for one alternative. The Plan was mailed to over 100
persons in the community. Availability of the Plan was published in two
local newpapers. A public meeting was held on April 27, 1989 in a high
school near the site.
Verbal public comments were received at the public meeting. Written
comments were received from a resident of Gary, the City of Hammond, the
Indiana Department of Highways, and the Midco Steering Committee, which
represents potentially responsible parties at the site. A summary of the
major comments, as well as U.S. EPA's response to them, is included in the
Responsiveness Summary in the Appendix.
The U.S. EPA-selected remedial actions identified in the Record of
Decision differ from the preferred alternative described in the Proposed
Plan in the following ways:
1. As an alternative to deep well injection, the option of
reinjection of the ground water back into the Calumet aquifer
is allowed following treatment, with the condition that this
operation not cause spreading of the salt plume.
2. A Treatability Variance is approved for the solidification/
stabilization (S/S) operation from the Land Disposal Restriction
(LDR) Treatment standards. This is being approved because
existing available data do not demonstrate that S/S can attain LDR
treatment standards consistently for all soil and debris at this
-------
'•'••-•' -6-
site. The Treatability Variance allows attainment of standards
that have been demonstrated to be attainable for soil and debris.
IV. SODPE AND ROI£ OF RESPONSE ACTION
Removal of the surface wastes as well as excavation and removal of
contaminated soil and waste materials from the sludge pit and filter bed
have been completed by U.S. EPA, (except for approximately 100 cubic yards
of contaminated soil from the filter bed which will remain on-site and be
addressed during the final remedial action). This is the final remedial
action and will atfrjipagg the remaining contamination at the site including
contaminated subsurface soil and materials, contaminated ground water and
contaminated sediments in the adjacent ditch.
V. SITE CHARACrmiSTTCS
The RI showed that on-site subsurface soils are highly contaminated by a
large number of chemicals. Ground water below the site is also highly
contaminated, but the contaminated ground water does not extend very far
from the site. Some surface sediments in the ditch north of the site were
also highly contaminated. The ground water was also highly saline,
especially the lower part of the aquifer. The high salinity is theorized
to be largely due to leaching from fill on the Midco II site as well as on
adjacent properties. This filling occurred prior to the Midco operations.
Source:
On-site subsurface soils are a continuing source of contaminants to the
ground water and surface water. Fifteen test trenches were excavated
into the most contaminated portions of the site and thirty samples were
collected to characterize the extent and nature of this source. Several
individual sources of contamination appear to exist in the northeastern,
central-northeastern and southeastern portions of the site. The minimum,
maximum and mean concentrations of chemicals detected in these samples are
summarized in Table 1 in the Appendix. Elevated concentrations of the
following compounds (compared to background) were detected:
aluminum . methylene chloride
arsenic acetone
baruim 2-butanone
cadmium chloroform
chromium 1,1,1-trichloroethane
copper 1,2-dichloropropane
lead trichloroethene
nickel 1,1,2-trichloroethane
zinc benzene
1,4 dichlorophenol 4-methyl-2-pentanone
isophorone tetrachloroethene
2,4-
-------
-7-
Various polyaromatic hydrocarbons and phthalates were detected in the low
mg/kg range. PCBs were detected in several samples at levels below 50
mg/kg.
Total volatile organic compounds were as high as 0.38% by weight and
consisted predominantly of ethylbenzene, toluene and xylene. Total semi-
volatile organic compounds were as high as 402 mg/kg and consisted
predominately of polyaromatic hydrocarbons, phthalates, alkanes, and iron
tricarbonyl (n^eryl-2-pyrioUmyldmethylene) benzamine N,^. Arsenic was
as high as 1,430 mg/kg, chromium as high as 1,960 mg/kg, copper as high as
4,640 mg/kg, lead as high as 2,810 mg/kg, zinc as high as 4650 mg/kg,
cadmium as high as 11 mg/kg and nickel as high as 1430 mg/kg. The
ntrations of a number of Inorganics in the on-site soils appear to be
correlated to the concentration of aluminum, including arsenic, cadmium,
lead, barium, chromium, copper, nickel, antimony and tin.
Surface water samples were collected at five locations in the ditch during
two rounds of sampling. An additional sample was collected further
upstream on a later date. The maximum, minimum and average concentrations
are summarized in Table 1. Methylene chloride, 1,2-dichloroethane,
acetone, trans-l,2-dichlorethene and cyanide were detected during both
rounds of sampling in locations adjacent to the site. The compounds
1,1,1-trichlorethane, 4-methyl-2-pentonone, toluene, xylenes, benzidene,
n-nitrosodiphenylamine and some phthalate compounds were detected in one
of the rounds of sampling. Some metals were also detected at what appear
to be elevated concentrations.
Surface Sediments:
Surface sediment samples were collected from the ditch in five locations
during two rounds of sampling and in three additional locations during the
first round. A third round of sampling included two additional sampling
locations farther upstream. The results show a large increase in
concentration of a number of hazardous substances adjacent to and for a
short distance downstream from the site. The concentrations drop off
quickly downstream from the site. These hazardous substances include:
methylene chloride; acetone, ethylbenzene, toluene, benzene, 2-butanone,
arsenic, n-nitrosodiphenyl amine, chlordane, phthalate compounds, PCBS,
polyaromatic hydrocarbons, cyanide, chromium, and lead. The maximum,
minimum and average concentrations are summarized in Table 1. The results
for total volatile organic compounds are shown in Figure 4, and for total
semi-volatile organic compounds in Figure 5.
Ground Water:
Thirty-three monitoring wells were installed and sampled during two rounds
of sampling. Eight wells were installed and sampled in an additional
round of sampling. The maximum, minimum and average concentrations of all
the ground water samples are summarized in Table 1.
-------
- -8-
An unanticipated result was that the aquifer in the vicinity of Midco II
is highly contaminated with salt consisting primarily of potasium, sodium
and chloride. The basal part of the aquifer contains as high as 60,000
mg/1 of chloride. The extent of this contamination is indicated by the
chloride isolines for the shallow wells in Figure 6 and the deep wells in
Figure 7. The shallow wells are relatively low in salt content compared
to the deeper wells. If the source was the fill, this suggests that the
salinity of the fill is largely leached out. It is probable that bulk
chemical disposal in the filter bed also contributes to the high salinity
in ground water at the site.
Sane ground water sampling results for hazardous substances are summarized
in Figures 8, 9, and 10. Cyanide was detected in the on-site ground water
in all but three wells. The highest cyanide value (7,830 ug/1) was
detected during Phase I at £10, located adjacent to the former filter bed.
The highest cyanide concentration in off-site wells were detected at
cluster F located very close to the former filter bed (Figure 8).
VOCs were detected in all but two on-site monitoring clusters and in most
off-site wells (Figure 9). In general, deep wells had lower concentra-
tions of halogenated volatile hydrocarbons than shallower wells. Ketones
were detected in most on-site wells, as well as a number of off-site
monitoring wells. On site, the highest concentrations of toluene,
ethylbenzene, and total xylene were detected at E10, located close to the
former filter bed location, and the highest concentration of benzene on
site was detected at BIO. Off site, volatile aromatic hydrocarbons were
detected only at F10, F30, CIO, MW8, and L30. Benzene was detected at
CIO, MW8, and L30.
Figure 10 shows the total semivolatile concentrations in the ground water.
Similar to the total VOC results, the highest concentrations of total
semivolatiles were•detected at £10. PAHs were detected in shallow on-site
wells at concentrations of less than 210 ug/1. The only PAH detected in
deeper on-site wells was 2-methylnaphthalene. PAHs were also detected in
some off-site wells. The concentrations of PAHs at the off-site,
upgradient well MW8 were higher than detected in the on-site wells,
indicating an off-site source of these conpounds. Phthalates were
detected on and off site. No evidence of PCS release to the ground water
within the site boundaries was found during the RI at the analytical
detection limits used. However, PCBs detected at CIO may have been a
result of Midco II operations.
Biota:
The U.S. Fish and Wildlife Service collected samples of crayfish, snapping
turtles, small mammals and earthworms near Midco II. These samples were
analyzed for organic and inorganic hazardous substances. The results were
compared to the results in control samples. Although the U.S. Fish and
Wildlife Service has not yet issued its final report, preliminary results
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indicate that the following hazardous substances were frequently detected
at elevated concentrations relative to the control samples: 2-butanone;
benzene; toluene; ethylbenzene; aluminum; chromium; copper and lead. All
of these constituents were detected at elevated concentrations in soils,
ground water, surface waters or sediments in on-site and in directly
affected areas.
SUMMARY OF SITE RISKS
For the future development scenario including usage of the ground water,
soil ingestion, and air exposure, an estimate of the health risks is as
follows:
Lifetime Cumulative
Cumulative Chronic
Carcinogenic Non-carcinogenic
Risk* Risk Index*
Exposure to Ground Water 2.6 x 10~2 124
Exposure to soils 3.3 x 10~4 2.99
* From Table 4-21 of the Addendum to Public Comment Feasibility Study
The main compounds causing the carcinogenic risks are:
Ground water - trichloroethlene, methylene chloride, isophorone, 1,1-
dichloroethane, arsenic
Soils - PCBs, trichloroethlene, tetrachloroethene, arsenic, benzo(a)-
pyrene
The main compounds causing the chronic non-carcinogenic risks are:
Ground water - 4i-methyl-2-pentanone; methylene chloride; selenium;
arsenic; acetone; 2-butanone; and ethylbenzene.
Soils - ethylbenzene, xylenes, arsenic and tetrachloroethene.
The following hazardous substances were detected at concentrations
exceeding the Primary Drinking Water Regulation, Maximum Contaminant
Levels (MCLs) (40 CFR 141) in ground water near the site: benzene; 1,1-
dichloroethene; 1,2-dichlorpropane; ethylbenzene; 1,1,1-trichloroethane;
trichloroethene; trans-l,2-dichloroethene; toluene; vinyl chloride;
xylenes; cadmium; chromium; lead; arsenic; silver; selenium; and barium.
A cumulative subchronic hazard index for an on-site future use scenario
was calculated to be 27. This index is calculated by adding the ratios of
the estimated subchronic exposure rate (SER) to the Acceptable Subchronic
-------
_ -10-
Intake (AST) for each chemical. The subchronic hazard index exceeded
unity for toluene due to inhalation while bathing, to selenium and cyanide
due to drinking water ingest ion, and for copper due to ingestion of
drinking water, and soil ingestion. If the subchronic hazard index is
less than one or unity, no adverse health effects would be expected.
(Remedial Investigation of Midwest Solvent Disposal Company (Midco II).
March 1988. p.6-55 and Table 6-17).
The estimated lifetime, carcinogenic risks to the nearest resident is
5 x 10""6 due to play and recreational activities in the ditch resulting in
exposure to arsenic, trichloroethene, methylene chloride, isophorone, and
1,1-dichloroethane that migrated from the site. (Remedial Investigation
of Midwest Solvent Disposal Company) (Midco II). March 1988. Table 6-19).
If no action is taken to contain or recover the ground water, contaminants
will continue to migrate from the site and are predicted to affect ground
water in the area shown in Figure 11. Two water wells used for non-
drinking purposes located on the Gary Airport property are in the path of
the plume. No existing wells used for drinking purposes would be
affected. The ground water would also continue to contaminate the ditch
and cause the above-mentioned, human health risk to off-site residents as
well as environmental effects.
It has been argued that the Calumet aquifer at Midco II should be
considered a Class III aquifer because of the high salinity, and,
therefore, the aquifer should not be protected for drinking water usage.
However, because the salinity is not natural and has not affected a large
portion of the aquifer and because the ground water in at least some
portions of the aquifer is usable for drinking, U.S. EPA has determined
that the .Calumet aquifer in the vicinity of Midco II is a Class II aquifer
and should be protected for drinking water usage.
It has also been argued that there should be considered no risk due to
future drinking water usage because the high salinity would prevent its
usage. However, there is no assurance that the hazardous substances will
always migrate within the salinity plume. In fact Figures, 6 and 7 show
that the shallow portion of the aquifer below the site (where the highest
hazardous substance contaminant levels exist) has a total dissolved solids
content of much less than 10,000 mg/1, the limit used in the Underground
Injection Control Program as a cut-off point for drinking water usage. In
addition, a large portion of the salinity is due to the Midco II site and
possibly due to the Midco H operations.
Compounds detected in the drainage ditch and ponded area northeast of the
site which are above freshwater chronic water quality criteria include
cadmium, chromium, copper, iron, lead, mercury, nickel, silver, zinc,
cyanide and di-n-butylphthalate. The U.S. Fish and Wildlife Service noted
that there are no fish present in the ditch downstream from Midco II,
apparently due to contamination from Midco II and other sources. The
Service believes that biota that do live in the vicinity of Midco H have
accumulated elevated concentrations of volatile and inorganic compounds
which adversely affect fish and wildlife resources.
-------
Figure 1-33
HIOCO tl
Extent of th« PliiM if
Ground Water »«»»iH.«tior
net Provided
2000
.' -^IXfJt^
Figure 11
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-11-
Contaminant migration frum Midco II through ground water and surface water
pathways moves to Lake Michigan. Significant migratory bird and
anadromous fish resources exist in Lake Michigan, and these could be
VIH. nRSCRlPl'lON OP
A large number of alternatives were screened, using engineering judgement
for applicability, past performance and implementability to address the
contaminated subsurface soil and fill materials, the contaminated ground
water and contaminated surface sediments. Detailed evaluations were
conducted for 14 alternatives, which are combinations of the most
promising technologies. These technologies can be categorized as follows:
Containment:
. multilayered cap
. slurry wall
Ground Water Treatment:
. pumping of contaminated ground water and disposal in an
underground injection well without treatment
. pumping of contaminated ground water, treatment and then disposal
in an underground injection well
. pumping of contaminated ground water and treatment by evaporation
Source Treatment:
. soil vapor extraction
. solidification/stabilization
. in-situ vitrification
. incineration
Alternatives providing for direct treatment or removal of contaminated
soils below the water table were eliminated for a number of reasons. For
one, treatment of soils below the water table would normally require
dewatering of the aquifer below the site prior to excavation. Dewatering
would require installation of a containment barrier and disposal of a
large volume of contaminated ground water. Because of the time needed for
the injection well construction, the contaminated ground water from
dewatering would have to be disposed of commercially. The nearest
commercial deep well is in Ohio, so this disposal would be expensive and
add transportation hazards. In addition, ground water pump and treatment
alternatives may address readily leachable contaminants by gradual removal
by natural ground water flushing. Contaminants that do not leach out will
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~~ -12-
be unavailable for direct ingestion because they are below the water
table. Therefore, the source removal and treatment alternatives only
address contaminated subsurface soils and materials above the water table
and highly contaminated materials below the water table that can be
handled by localized dewatering.
The area! extent and depth of source treatment above the water table will
be determined by soil cleanup action levels (CKLe) . The extent and period
of operation of ground water treatment measures will be determined by
ground water CALs. Surface sediments will be scraped up in the area shown
in Figure 12 to a depth that will leave the remaining sediments below the
soil CALs. The CAIs are defined in Section X, and includes attainment of
MCl/s in the ground water. The expected areal extent of source and surface
sediment remediation required is shown in Figure 12. The expected aerial
extent of ground water remediation is shown in Figure 13. Applicable, or
relevant and appropriate requirements (ARARs) for the various alternatives
are summarized in Tables 6, 7. and 8 in the Appendix. The fourteen
alternatives are summarized below, including the status of compliance with
major ARARs.
1: No Action
By law, U.S. EPA is required to consider the no-action alternative. No
action would be taken to address the source, the contaminated ground water
or surface water. The source would continue to cause contamination of the
ground water and surface waters. The contaminated ground water would
continue migrating off-site and may eventually affect nineteen ground
water wells.
2? Af*"**^*8 Rt&»M legion Wth
This alternative consists of the construction of a RCRA compliant multi-
layer cap over the entire site, an area of approximately 302,000 square
feet. The cap would include a low-permeability barrier layer to prevent
vertical migration of water, a lateral drainage layer and a vegetative
cover, as shown in Figure 14. A concrete conduit would be installed in
the ditch to carry surface water past the site.
The scraped contaminated sediments (estimated to be 1,200 cubic yards) and
areas of isolated soil contamination would be excavated and transported to
an off -site landfill for disposal.
Ground water use restrictions would be placed in the area shown in Figure
11. The two wells on the Gary Airport property would be replaced by a
ction to the municipal water system.
This and all the remaining alternatives would include installation of a
six foot chain link fence with 3-strand barbed wire around the site,
installing warning signs, and imposition of deed restrictions.
Ground water and surface water migration would be monitored regularly.
-------
Figure 12
GARY
MUNICIPAL
AIRPORT
KEY:
S MONITORING WELL
-«—«•- FENCE LOCATION
P-
\\V\V\\\\\\v) 80IL T0 BE REMEDIATED
'!f!i/!////i/ SEDIMENTS TO BE REMEDIATED
100
FIGURE 4-16
MIDCO II
SOIL AND SEDIMENTS
TO BE REMEDIATED
SCALE IN FEET
Dame* & Moore
-------
CONRAIL
'Figure 13
jfMV*
i MVS
' HV8
INDUSTRIAL HIGHWAY
SOIL BORING SMtft.CS
TRCNCH SAHPtCS
SAMPLES ABOVC UATZR TABLZ
SAMPLES BELOW MATER TABLE
CART MUNICIPAL
AIRPORT
200
FIGURE 1-31
MIDCO II
GROUND HAT:- TO oe REMEDIATED
-------
Figure 14
3% MINIMUM SLOPE
:-30 MIL SYNTHETIC LINER
FIGURE 4-2
MIDCO II
ALTERNATIVE 2
RCRA MULTILAYERED CAP
Dames & Moor*
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-13-
1. Relevant and Appropriate Requirements:
This alternative would be consistent with hazardous waste landfill closure
requirements of the Resource Conservation and Recovery Act (RCRA) (40 CFR
264. Ill, 264.116, 264.117, 264.310), and ground water monitoring
requirements of RCRA (40 CFR 264.97, and 264.99) . However, it would not
be consistent with the Primary Drinking Water Regulations (40 CFR 141) or
the RCRA corrective action requirements (40 CFR 264.100) because
contamination from the site would continue to cause exceedance of the Mds
in off-site ground water. It also would not be consistent with the
Ambient Water Quality Criteria (AWQC) for protection of aquatic life
because the contaminated ground water would recharge surface waters and
cause exceedance of the AWQC.
2. Applicable Requirements:
The off-site djgpngai of contaminated sediments would have to be in
compliance with U.S. EPA's off-site policy and all applicable RCRA, and
Department of Transportation (DOT) regulations.
A clay slurry wall would be installed around the area where clean-up
action levels (CALs) are exceeded in soils above the water table and for
ground water. The wall would be keyed into the material confining layer
located 48 feet below the surface, and would be approximately 36 inches
wide and 2,900 feet long.
Because of the high salt content and other contaminants at the site, bench
scale tests would be performed in order to determine the formulation for
the slurry. Bentonite clay may be affected by the high salinity, so
attupulgite clay may be used instead.
A multi-layer cap as described in Alternative 2 would be placed over
the area inside the slurry wall. A conduit would be installed as in
Alternative 2. Contaminated sediments would be scraped and contained
within the cap and slurry wall. Areas of discontinuous soil contamination
would be excavated and contained within the cap and slurry wall. An
extraction well would be placed in the containment area to lower the
ground water inside the wall by approximately 0.5 feet to insure an inward
ground water gradient. Initially, this would require disposal of
approximately 500,000 gallons of contaminated ground water. This would
be disposed of in the nearest commercial deep well.
As with Alternative 2, the site would be fenced and posted, deed
restrictions imposed, and a monitoring program implemented.
1. Relevant and Appropriate Requirements:
This alternative would be consistent with RCRA hazardous waste landfill
closure requirements. Because the ground water outside the slurry wall
would meet the CALs, this alternative would also be consistent with RCRA
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-14-
corrective action requirements, and the Primary Drinking Water
Regulations. After containment of the Midco II source, surface water
would shortly meet the AWQC (unless other sources are present) .
2. P<=*gi
-------
Figure 15
600'
LCONRAIL
GARY \ \
MUNICIPAL \
AIRPORT
INDUSTRIAL HIGHWAY
MODEL
BOUNDARY
« INDICATES WELL LOCATION
7 AND PUMPING RATE
GALLONS PER MINUTE
Vtf_INDICATES DRAWDOWN
^^* CONTOUR IN FEET
200
400
It
SCALE IN FEET
FIGURE 4-4
MIDCO II
DRAWDOWNS (FEET) AND
PUMPING WELL LOCATIONS
Dames & Moore
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_ -15-
1. Applicable Requirements:
The deep well. injection oust be in compliance with the Land Disposal
Restriction (L£R) requirements of 40 CFR 268 and 40 CFR 148. The
following listed hazardous wastes have been disposed of on the site and
are contained in the contaminated subsurface soils, ground water and
surface sediments: F001, F002, F003, F005, F007, F008, F009.
For this reason, before the ground water can be injected without
treatment, a petition to allow land disposal of waste prohibited under
Subtitle C of 40 CFR 268, must be granted by the U.S. EPA Administrator
pursuant to 40 CFR 268.6 and 40 CFR 148 Subpart C. This petition must
demonstrate that there will be no migration of hazardous constituents from
the injection zone for as long as the wastes remain hazardous.
A cross section of the geology of this area is shown in Figure 16. The
injection zone in the Mount Simon aquifer is separated by geological
formations from drinking water aquifers. Nearby class I underground
injection wells that are presently operating, have submitted petitions
pursuant to 40 CFR 268.6. These petitions are presently under review by
U.S. EPA.
The injection well must be constructed, installed, tested, monitored and
operated, closed and abandoned in accordance with U.S. EPA requirements
and conditions pursuant to 40 CFR 144 and 146. In addition, reporting
requirements must be in accordance with 40 CFR 144 and 146. Contaminated
sediments will be scraped and disposed off-site in accordance with the
U.S. EPA off-site policy and applicable RCRA and DOT requirements.
The remedial action may also require responses to operational problems,
and implementing corrective actions pursuant to 40 CFR 146.64, 144.67,
144.12, 144.51 (d) and 144.55. This may include requirements for
construction, monitoring, reporting, well plugging and injection well
closure as necessary to prevent movement of any contaminant into an
underground source of drinking water (U.S.D.W.) (40 CFR 144.3), due to
operation of the injection well. This may also require implementation of
remedial actions to restore any U.S.D.W, that becomes contaminated as a
result of operation of the injection well, to background water quality to
the extent practical, pursuant to Section 3004(u) and 3008 (h) of the 1984
Hazardous and Solid Waste Amendments.
2. Residual Risks and Relevant and Appropriate Requirements:
Natural attenuation and flushing of the source would occur during
operation of the ground water extraction system. However, some hazardous
substance residuals would remain in the subsurface soils. The residual
risks cannot be determined at this time. Therefore, a site cover would
be placed over the contaminated soils that would be consistent with RCRA
hazardous waste landfill closure requirements (40 CFR 264.111, 264.116,
264.117, 264.310). The site would be fenced, deed restrictions imposed,
and a ground water monitoring system implemented consistent with RCRA
-------
Figure 16
Figure 7, Lake County Geology
1000-1
Elev. in feel
-1000-J
-2000.
-3000-
-4000.
Trenton & Black River Limestone*
Rock Unit
,£«>. tarsi
SlPeter Sandstone
Knox Dolomite
Galesville Sandstone)
- - — Eau Claire Formation
Mount Simon Sandstone
Precambrian Rocks
System
[-Quaternary
f- Devonian
L Silurian
uOrdovician
-------
-16-
Alternative 4C: Ground Water Punpina. Treatment and Either Deep
or Rairriecti.cn int"<"» 'the calumet Aouif ff
This alternative is the same as alternative 4A except that the
contaminated ground water would be treated to the extent necessary to meet
U.S. EPA requirements prior to the underground injection. For this
alternative, U.S. EPA approval of the underground injection well would be
required, but no petition demonstration would be needed.
Prior to the deep well injection, Land Disposal Restrictions (LDR)
treatment standards would be met. Treatment requirements for listed
wastes F001, F002, F003, and F005 (40 CFR 268), would likely require an
air stripper and a liquid-phase granular activated carbon polish system.
Treatment may also be required for cyanide, chromium, lead and nickel to
meet the proposed treatment standards for listed wastes F007, F008 and
F009 (F.R. , Vol. 54, No. 7.). The LDR Treatment standards are listed in
Tables 19 and 20 (the standards for non-wastewaters would be applicable to
contaminated ground water) .
It is anticipated that treatment units would be designed for an average
flow of 28 gpm. Air emissions from the air stripper would be controlled
most likely with a carbon canister. The degree of air emissions control
required is defined in Section X. Treatment residuals, which may include
spent carbon and metals sludge would be disposed of off-site in accordance
with U.S. EPA's Off-site Policy and applicable RCRA and DOT regulations.
As with alternative 4A, the treatment and underground injection well
system may be combined with Midco I.
Alternatively, the ground water could be treated and then reinjected into
the Calumet aquifer if rein j action is conducted in a manner that will
prevent spreading of the salt plume. At the end of the pumping, treatment
and reinjection operation, the ground water at the site must meet the
ground water CALs (Section X) . The goal of the remedial actions is to
restore the ground water quality. Normally, this would require that the
remedial action also reduce secondary (non-hazardous) contaminants such as
total dissolved solids (TDS) either to background levels or to Secondary
Maximum Contaminant Levels (40 CFR 143) . However, at Midco II, since
there are nearby contaminant sources, high levels of TDS would be left in
the ground water at the site at the completion of remedial actions.
Al^^TTiative 4Es ^yound Wat***** Pumping and
A ground water extraction system would be installed and operated in the
same manner as in alternatives 4A and 4C. However, the contaminated
ground water would be treated by evaporation, instead of by separate
treatment operations combined with deep well injection. All contaminants
would be concentrated into treatment residuals that would have to be
of off -site in accordance with U.S. EPA's off -site policy and
applicable RCRA and DOT requirements. The residuals will include blow
down and salt cake. In addition, air stripping and carbon adsorption may
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-17-
be required prior to discharge of the condensate. Air emissions will have
to be controlled to meet the criteria described in Section X.
The blow down and carbon residuals would likely be commercially
incinerated. Cyanide and metals in the ground water would likely be
concentrated in the salt cake. If this occurs, land H I «£•>-*« i of the salt
cake would likely not be allowed under the Land Disposal Restrictions
regulations without prior destruction of the cyanide and treatment of
metals (F.R., Vol. 53, No. 7). See Table 20.
The final site cover and handling of contaminated sediments would be the
same as in alternatives 4A and 4C.
The evaporation system may be combined with Midco I.
Alternative 5Ai Excavat"ion ?faove the Ground Wa+^r KIevasion and
This alternative and alternatives 5C, 5E and 5G treat the source and
surface sediments, but not the ground water.
1. Excavation and Off-Site Disposal:
As part of the Feasibility Study a risk assessment was conducted to
estimate the risks to off-site residents and airport workers during
excavation activities due to volatilization of organic compounds and
fugitive dust emissions. Using very conservative assumptions, it was
estimated that the carcinogenic risk to the nearest residents may be
5.05 x 10"8 and the risk to airport workers may be l.lxlO"6. Because
these risks are low, it is acceptable to conduct the excavation activity
without prior soil vapor extraction (SVE) as long as adequate protection
.is provided to on-site workers, emissions are monitored, measures are
taken to minimize emissions during excavation, and provisions are made to
shut down the operation in case atmospheric conditions may cause levels of
exposure exceeding the criteria defined for air emissions in Section X.
An estimated 34,600 cubic yards of contaminated soil above the water table
and 500 cubic yards of contaminated surface sediments would be excavated
and disposed of off-site. All off-site disposal would be required to
comply with U.S. EPA's off-site policy and applicable RCRA and DOT
regulations. ITRs under 40 CFR 268 may not allow this alternative because
cyanide, metals and volatile organic compounds would not be treated (see
standards for non-wastewaters in Tables 19 and 20).
2. Site Cover and Ground Water:
The site would be restored to grade with uncontaminated fill. A conduit
would be installed in the ditch along the site. Over a long period of
time, ground water may attenuate to below CALs. However, in the meantime,
the ground water at the site would be highly contaminated and would
continue to migrate off -site. It may eventually affect ground water in
the area shown in Figure 11. Ground water usage restrictions would be
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: -18-
inposed in this area, and the two wells on Gary Airport property would be
replaced by connections to the municipal water system. This action would
be consistent with RCRA ground water monitoring requirements. It would be
inconsistent with RCRA corrective action requirements and Primary Drinking
Water Standards because Md£ would be exceeded in off -site ground water.
The AWQC may be exceeded in surface waters due to off-site migration of
the ground water.
The site would be fenced, deed restrictions imposed and ground water
monitoring implemented as in Alternative 2.
5Ci Excava*"*on Above Wa^^T* T^fole. Inciryration and
Incineration:
As with Alternative 5A, measures would be taken to insure that air
emissions during excavation and handling of the subsurface material do not
exceed the criteria for air emissions defined in Section X.
Following excavation, the contaminated subsurface and sediment material
would be incinerated. RCRA regulations become applicable to the material
excavated and treated. It is anticipated that the incinerator would be a
transportable, rotary-cell type, approximately thirty-eight feet long with
a ten-foot inner diameter.
The incinerator is expected to have a capacity of approximately 17.5 tons
per hour. A secondary combustion chamber would be used to assure complete
destruction of the wastes, and a caustic scrubber would neutralize acidic
flue gases and control particulate emissions. The incinerator would have
to meet the testing and performance standards in 40 CFR 264.341, 264.351,
264.343, 264.342, 7611.70 and special State of Indiana requirements
including a test burn and extensive stack sampling.
The incineration should destroy nearly all the organic compounds and
cyanide. The inorganics (other than cyanide) would largely remain in the
ash. The remaining lifetime carcinogenic risk in the ash due to direct
soil ingestion would be approximately 2.77 x 10"4 due to arsenic.*
However, these levels of arsenic represent background concentrations.
The remaining cumulative chronic non-carcinogenic risk index due to soil
ingestion would be 2.8 due primarily to arsenic, antimony, beryllium and
chromium (VI) in the soil. The subchronic risk index would remain above
1.0 for toluene, copper, selenium and cyanide because ground water would
not be remediated. The metals in the ash may be in a form that would
leach to a significant degree. However, past leaching from the soil has
caused ground water contamination by a number of metals.
From addendum to Public Comment Draft Feasibility Study, March 7, 1989.
Table 4-21.
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— -19-
The incineration at Midcb H may be combined with the incineration at the
nearby Ninth Avenue Dump site. For purposes of KCRA and the U.S. EPA off-
site policy, the combined action would be considered one site.
The incineration process must satisfy the LCRs for non-wastewaters for
listed wastes No. F001, F002, F003, F005, FOOT, F008, F009 (see Tables 19
and 20). However, a capacity variance is in effect for waste categories
F001, F002, F003 and F005 in soil, waste and debris until November 1990.
Solidification:
In addition to the risks remaining from the ash, the concentrations of
some inorganic compounds (arsenic, chromium and lead) in the ash will be
similar to concentrations in some listed hazardous wastes for which
treatment is required prior to land disposal. This is shown in Table 9 in
the Appendix. For these reasons, solidification/stabilization (S/S) of
the ash will be required following the incineration. Following S/S, the
solidified mass must meet the LCR treatment standards (see Table 19 and
29), or meet standards for a Treatability Variance, if this is approved
pursuant to 40 CFR 268.44. In addition, if the ash is a hazardous wastes
by characteristic, D004, D005, D006, D007, D008, D009 or D010, LCRs for
these wastes may be applicable at the time of the action.
Site Cover and Ground Water:
The incinerated/solidified material would be placed on-site. The design
of the final cover would depend on the results of the leachate tests on
the ash or solidified material. If the waste is delistable, a two-foot
soil cover would be placed over the site. If not, a final cover in
compliance with applicable RGRA landfill closure requirements would be
installed.
As in Alternative 5A, ground water monitoring, usage restrictions,
municipal water connections, deed restrictions, and access restrictions
would be implemented. This alternative would be inconsistent with RCRA
stive action requirements and Primary Drinking Water Regulations.
Two methods of mixing for solidification are available. One involves
excavation, mixing above ground and replacement of the solidified material
on-site; the second involves in-situ addition of reagents and mixing.
Using either method of mixing, measures would be taken to insure that air
emissions during excavation and solidification do not exceed the criteria
for the air emissions defined in Section X.
1. Above Ground Mixing:
Subsurface materials above the ground water table and surface sediments
that exceed soil CALs would be excavated, mixed with water, binder and
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-20-
reagents in a tank and then placed back on site to cure. It is
anticipated that the contaminated materials would be fed to the mixer at a
maximum rate of 75 cubic yards per hour. large items such as stumps would
be sifted out and sandwiched inside layers of solidified material on the
site.
Once the contaminated subsurface materials and sediments are excavated and
treated, the RCRA regulations become applicable. Pursuant to 40 CFR 268,
land disposal of the treated material would not be allowed unless the LCR
treatment standards are attained (see Tables 19 and 20), or Treatability
.Variance treatment standards are attained (see Table 21) (40 CFR 268.44).
Until November 1990, there are no LCR treatment standards in effect for
waste categories F001, F002, F003 and F005 in soil, waste and debris
because of a capacity variance. The proposed LCR treatanent standard for
cyanide requires destruction of cyanide rather than reduction in mobility.
Because it may be impossible to meet the LCR treatment standards for
cyanide by S/S, and because existing available data do not demonstrate
that full scale operation of S/S can attain the LCR treatment standards
consistently for all soil and debris at this site, this alternative will
comply with the LCRs through a Treatability Variance. The required
treatment standards (based on results of Toxicity Characteristic Leaching
Procedure (TdP) Tests) are summarized in Table 21. Constituents that are
not listed in Table 21 should be reduced in mobility by 90% based on TCLP
tests.
Regulations applicable to hazardous wastes by characteristic (D003, D004,
D005, D006, D007, D008, D009, D010) may become applicable to the operation
by the time S/S is implemented. If only VGCs exceed the Land Disposal
Restriction Standards, then a soil vapor extraction operation would be
conducted to assure attainment of these standards.
2. In-situ Mixing:
As an alternative to excavation and solidification, the subsurface soil to
be remediated would be solidified in-situ. It is anticipated that the
system would utilize a crane-mounted mixing system. The mixing head would
be enclosed in a bottom-opened cylinder to allow closed system mixing of
the treatment chemicals with the soil. The bottom-opened cylinder would
be lowered onto the soil and the mixing blades would be started, moving
through the depth in an up and down motion, while chemicals are
introduced. Vapors and dust would be pulled into the vapor treatment
system, composed of a dust collection system followed by in-line activated
carbon treatment. An induced draft fan would exhaust the treated air to
the atmosphere. At the completion of a mixing, the blades would be
withdrawn and the cylinder removed. The cylinder would then be placed
adjacent to and overlapping the previous cylinder. This would be repeated
until the entire area has been treated. The surface sediments would be
scraped up and consolidated on-site for solidification.
Using in-situ mixing, the LCRs would not be applicable nor considered to
be relevant and appropriate. The S/S will be considered successful if it
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_ -21- . .
reduces the mobility of contaminants so that leachate frcm the solid mass
will not cause exceedance of the Cleanup Action Levels in the ground water
(see Section X). If leaching of VDCs nay cause exceedance of ground water
CALs, but leaching of other constituents will not cause exceedance of
ground water CALs (based on the treatability tests); then a soil vapor
extraction operation (as in Alternative 5A) will be conducted to assure
that leaching of VDCs does not cause exceedance of these CALs.
3. Residual Risks:
If the solidification/stabilization operation is successful, the exposures
due to direct soil ingestion and leaching to ground water should be nearly
eliminated.
Using solidification, the mobility of hazardous constituents would be
reduced through binding or entrapment of hazardous constituents in a solid
mass with low permeability that resists leaching. Some volatile organic
compounds will be driven off during the process, but these can be
controlled so that the effects on off-site and on-site persons would be
negligible. S/S has been selected as the best demonstrated available
technology (BOAT) or part of a BOAT for treatment of a number of RCRA
hazardous wastes for the Land Disposal Restrictions (40 CFR 268). These
include the following listed hazardous wastes: F006, K001, K015, K022,
K048, K049, K050, K051, K052, K061, K086, K087, K101. These listed
hazardous wastes contain the following hazardous constituents: cadmium,
chromium, lead, nickel, silver, arsenic, and selenium (40 CFR 268,
promulgated August 17, 1988). S/S is considered a potentially applicable
technology for treatment of hazardous wastes by characteristic numbers
D004, 1X05, 0006, 0007, 0008, and 0010, which contain arsenic, barium,
cadmium, chromium, lead, and selenium (F.R., Vol. 54, No. 7, p. 1098-
1099).
The S/S process has weaknesses. Some constituents interfere with the
bonding with waste materials. This includes high organic content (>45%
by weight), semivolatile organic compounds greater than 1.0%, cyanide
greater than 3,000 ppm, and high oil and grease (>10%). In addition,
halide may retard setting, and soluble manganese, tin, zinc, copper and
lead salts increase the leachability potential (Technology Screening Guide
for Treatment of CERCIA Soils and Sludges, EPA/540/2-88/004. Sept. 1988).
Midco II subsurface materials contain halides, and elevated zinc,
manganese, copper and lead. Hideo II differs from Midco I in that Midco
II does not contain the same high concentrations of semivolatile compounds
and cyanide.
In addition, the long term integrity of the solidified material is not
well documented because few projects have been in place for long periods
of time. This is of concern because organic constituents are usually not
considered to be treated by this process but only encapsulated. There is
very little data available on the applicability of S/S to cyanide wastes.
In one study, the mobility of arsenic was increased by orders of magnitude
by the S/S. Chromium and arsenic are difficult to solidify and may
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-22-
require specialized binders. Organic lead nay not be effectively treated
by S/S (F.R., Vol. 54, No. 7, pp. 1098, 1099).
Therefore, U.S. EPA can not be sure how successful S/S will be at
Midco II until treatability tests are completed. These tests are being
initiated. In addition, treatability tests are needed to determine the
proper formulation for the solidification reagents.
4. Final Site Cover:
If the subsurface T|tfv*'^rialg are excavated, RCRA hafrgrrfrrv? waste
regulations become applicable, and the final site cover must meet RCRA
landfill closure requirements, unless the waste is delisted pursuant to 40
CFR 260.22. However, RCRA does not presently utilize leach testing
procedures in the delisting of organic compounds. The final site cover
most also protect the solidified material from degradation due to
environmental factors such as acid rain and the freeze-thaw cycle.
If in-situ mixing is used, RCRA landfill closure requirements are not
applicable. However, these requirements may be considered relevant and
appropriate by U.S. EPA depending on the results of the treatability
study. At a minimum, the cover must protect the solidified material from
environmental degradation, minimize maintenance, promote drainage, and
minimize erosion.
5. Ground Water and Access:
Ground water usage restrictions, well connections, deed restrictions,
access restrictions and monitoring would be implemented as in alternative
5A. This alternative would be inconsistent with RCRA corrective action
requirements and Primary Drinking Water Regulations.
Alternative 5G: In-Situ. Vitrification
In this thermal treatment process, a square array of four electrodes are
inserted into the ground to the desired treatment depth of 4.5 feet. A
conductive mixture of flaked graphite and glass frit is placed among the
electrodes as a path for the current. Voltage is applied to the
electrodes to establish a current in the starter path. The resultant
power heats the starter path and surrounding soil up to 3600'F. The soil
becomes molten at temperatures between 2000* and 2500*F. As the vitrified
zone grows it incorporates non-volatile elements and destroys organic
compounds by pyrolysis. Pyrolyzed products move to the surface where they
combust. A hood over the process collects off-gases for treatment. The
hood remains over the melt until gassing stops, in approximately four
days. Thus, two hoods are required for sequential batch processing. The
vitrified mass is left in place and any subsidence is backfilled with
clean fill and seeded. In addition, contaminated sediments would be
aped and transported to the site for vitrification.
The advantages of in-situ vitrification include that excavation is not
required (except for surface sediments, which would be scraped up and
-------
-23-
consolidated on-site for vitrification), air emissions are controlled in
place, organic compounds are destroyed and inorganic compounds are
incorporated into a glassy solid matrix resistant to leaching and more
durable than granite or marble (Technology Screening Guide for Treatment
of CERCXA Soils and Sludges, EPA/540/2-88/004, Sept. 1988).
Disadvantages of in-situ vitrification include that although it has been
tested in pilot studies, it has not been demonstrated in a full scale
connercial application. In addition, the commercial availability of the
equipment is limited. The presence of ground water only five feet below
the surface severely limits the economic practicability because of the
energy expended in driving off water. The presence of buried metals and
combustible solids below the surface may also cause problems in the
operation (Technology Screening Guide for Treatment of CERCIA Soils and
Sludges, EPA/540/2-88/004, Sept. 1988).
Because the organic compounds are destroyed and inorganic compounds
incorporated into a solid mass resistant to leaching, it is expected that
the treated material will be delistable. If tests show that the residue
is delistable, only a soil cover would be placed over the site.
Ground water usage restrictions, well connections, deed restrictions,
restrictions and monitoring would be implemented as in alternative
5A. This alternative would be inconsistent with RCRA corrective action
requirements and Primary Drinking Water Regulations.
with S^i ^a"r Extraction and
This alternative combines the source treatment measures in alternative 5E
with the containment measures in alternative 3. The advantage of this
alternative over alternative 3 alone is that the risks from residual
subsurface soil contamination within the containment barrier would be
nearly eliminated. The contaminants in the ground water would remain but
they would be contained within the slurry wall .
Should the slurry wall fail, the ground water in the area shown in Figure
13 may eventually be affected. Although the contamination may eventually
attenuate, the risks from ingestion of ground water on the site itself
would remain very high for a long time.
If successful, the S/S process would nearly eliminate the remaining risks
due to the source.
Pumin and Dee w^il Inflection with
Solidification
This alternative combines the source treatment measures in alternative 5E
with the ground water treatment measures in alternative 4A.
At the conclusion of this action, the site would be close to meeting RCRA
clean closure requirements. However, long-term monitoring and maintenance
-------
_ -24-
would be required because the long-term effectiveness of S/S is not well
This alternative combines the source treatment measures in alternative 5E
with the ground water treatment measures in alternative 4C.
At the conclusion of this action, the site would be close to meeting RCRA
clean closure requirements. However, long-term monitoring would be
required because the long-term effectiveness of S/S is not well
9* Around Wa**^T FUmping and Evaporation with
This alternative combines the source treatment measures in alternative 5E
with the ground water treatment measures in alternative 4E.
At the conclusion of this action, the site would be close to meeting RCRA
clean closure requirements. However, long-term monitoring would be
required because the long-term effectiveness of S/S is not well
documented.
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting the final remedial actions for Superfund sites, U.S. EPA
considers the following nine criteria:
1. Overall Protection of Human Health and the Environment: y^j^^g*^?
whether or not a remedy provides adequate protection, and describes how
risks are eliminated, reduced or controlled through treatment, engineering
controls, or institutional controls.
2. Compliance with ARARs; addrpssps whether or not a remedy will meet
all of the applicable or relevant and appropriate (ARARs) requirements of
other environmental statutes and/or provide grounds for invoking a waiver.
3. long-term effectiveness and permanence; refers to the ability of a
remedy to maintain reliable protection of human health and the environment
over time once cleanup goals have been met.
4. Reduction of toxicitv. mobility, or volume (TMV) ; is the anticipated
performance of the treatment technologies a remedy may employ.
5. Short-term effectiveness; involves the period of time needed to
achieve protection and any adverse impacts on human health and the
environment that may be posed during the construction and implementation
period until cleanup goals are achieved.
-------
-25-
6. Implementabilitv: is the technical and administrative feasibility of
a remedy, including the availability of goods and services needed to
inplement the chosen solution.
7. Cost; includes capital and operation and maintenance costs.
8. Support Agency Acceptance: indicates whether, tv»s
-------
-26-
operation of the ground water treatment system over a long period of tine.
The site cover and access restrictions would protect against on-site
direct ingestion and direct contact risks.
At the completion of the ground water action, residual contamination will
remain under the site cover, although it will be reduced from the present
conditions. It is uncertain what residual risks will remain. It is
possible that mobile- contaminants will remain under the cover after
completion of the ground water treatment actions. If the cover is
subsequently disturbed or degraded, these residuals will again cause
ground water contamination. Even if relatively mobile components, such as
volatile organic compounds and cyanide are flushed from the soil, the
residual risks due to direct ingestion in case of future development would
be: 2.7 x 1CT4 lifetime carcinogenic risk due to arsenic, and a chronic
non-carcinogenic index of 2.8. In addition subchronic risks from copper
would likely remain. In addition, arsenic, lead and chromium are present
in some of the subsurface material at concentrations similar to those in
some listed hazard w wastes, for which treatment is required prior to
land disposal pursuant to 40 CFR 268 (see Table 9) .
For these reasons, an alternative that combines a source treatment measure
with a ground water treatment measure is needed. S/S would address all
risks due to the source if it is successful. The effectiveness of S/S at
Midco II would be evaluated by treatability tests prior to its
implementation.
Compared to S/S, incineration followed by S/S would more reliably treat
the organic compounds. However, incineration is considerably more
expensive than S/S by itself, and, if S/S is successful, incineration
would do little to further reduce risks.
Vitrification, if it worked, would more reliably address both the organic
and inorganic contaminants. It also treats both organic and inorganic
compounds in one operation, which is an advantage. However, there is a
large degree of uncertainty about whether vitrification is practical at
this site because of the high water table. In addition, it is estimated
to be considerably more expensive than S/S and, if S/S is successful,
would do little to further reduce risks.
All the ground water treatment alternatives would result in attaining
ARABS and providing long-term protection of the Calumet aquifer at the
site when combined with a source treatment alternative. They differ only
in their method of treatment and disposal of the highly saline
contaminated ground water. The treatment and deep well injection
alternative (4C) may substantially reduce TMV of contaminants in the
ground water prior to deep well injection.
Organic compounds would be removed by stripping and carbon absorption.
If residuals from this treatment are incinerated, this would provide
permanent treatment of these contaminants. If they are landfilled, the
may not be considered any more permanent than deep well injection
without treatment. If cyanide 'treatment is required, a chlorination
-------
_ -27-
process nay be used, which should permanently destroy the cyanide. Metals
nay be removed by precipitation. The metals sludge would be landfilled
but nay require solidification first. This disposal may not be considered
more permanent than deep well injection without treatment.
The evaporation alternative (4E) would reduce the volume of all
contaminants and the toxicity of contaminants in the blow down by
incineration. However, extensive treatment of the salt cake would likely
be required prior to land disposal under the RCRA Land Disposal
Restrictions. If such treatment is not required, alternative 4E would
include disposal of significant quantities of hazardous wastes in off-site
landfills.
The deep well injection without treatment alternative (4A) would not
reduce TMV of contaminants in the ground water. However, if a petition to
allow land disposal is approved by U.S. EPA, this alternative should
provide permanent human health and environmental protection since the
petition must demonstrate that there will be no migration from the
injection zone while the wastes remain hazardous. In addition,
alternative 4A is considerable less expensive than alternative 4C.
X. TOE SELEC'ltD REMEDY
U.S. EPA selects either alternative 7 or 8 for implementation at Hideo II.
These alternatives are described in Sections XIII and IX. Alternative 7
will be implemented if a petition to allow injection of waste prohibited
under 40 CFR Part 148 Subpart B is approved by U.S. EPA. In this case,
the permanence of the remedial action would be considered equivalent to
alternative 8, and alternative 7 is less expensive. If a petition is not
approved, alternative 8 will be implemented.
The selected alternative will also include site access restrictions and
imposition of deed restrictions, as appropriate. Either alternative will
include treatment of the source by S/S. This is the least expensive
alternative that will permanently reduce TMV of the source and be fully
protective of human health and the environment. However, implementation
of this source remedial action depends on the results of the treatability
tests for S/S. If the treatability tests show that S/S will not provide a
significant reduction in mobility of the hazardous substances of concern,
the ROD will be reopened and a different source control measure will be
selected. A more detailed cost breakdown for these alternatives is in
Tables 15 and 16 in the Appendix.
Clean Up Action Levels (CALs):
Soil Clean Up Action Levels:
All subsurface materials affected by the site or by Midco operations that
exceed any of the following risk based levels will be treated:
-------
-28-
Cunulatiye Lifetime Carcinogenic Risk = 1 x 10~^
Cumulative Chronic Noncarcinogenic Index = 1.0
Subchronic Risk Index = 1.0
Ground Water dean Up Action Levels:
All portions of the Calumet aquifer affected by the site or by Midco
operations that exceed any of following risk-based levels will be
recovered and treated (except as provided for in the subsequent
discussion). The ground water pumping, treatment and disposal system
shall continue to operate until the hazardous substances in all portions
of the Calumet aquifer affected by the site or by Midco operations are
reduced below each of these risk-based levels (except as provided for in
the subsequent discussion). Applying the CALs throughout the contaminated
plume is consistent with F.R., Vol. 53, No 245, p. 51426.
Cumulative Lifetime Carcinogenic Risk = 1 x 10~5
Cumulative Noncarcinogenic Index =1.0
Subchronic Risk =» 1.0
Primary MCLs (40 CFR 141)
Chronic AWQC for protection of aquatic life multiplied by a factor 3.6
Evaluation of Attainment of CALs:
The risk levels will be calculated from the soil and ground water
analytical results using the assumptions listed in Tables 2,3,4 and 5
in the Appendix (except that in place of the average site concentration,
actual measured soil and ground water concentrations in each sample
location will be used, and soil ingestion rates for chronic exposures of
0.2 gram per day for ages 1-6 and 0.1 gram per day for older age groups
will be used), the procedures in the Superfund Public Health Evaluation
Manual and U.S. EPA's most recently published carcinogenic potency factors
and reference doses.
For inorganic compounds in ground water, the analytical results from
filtered samples will be used. The analytical procedures will at least
reach the analytical detection limits listed in Tables 17 and 18 in the
Appendix. Constituents that are not detected shall not be included in
risk calculations. Constituents that are detected below background
ntrations identified in Tables 17 and 18 shall not be included in the
risk calculations.
If only one constituent is detected in ground water at a concentration
that is calculated to potentially cause a lifetime, incremental
carcinogenic risk of 1 x 10~5 or greater, and an MCL has been promulgated
for this constituent pursuant to 40 CFR 141, then the MCL will be the CAL
for that constituent. In addition, that constituent will not be used in
the cumulative risk calculation.
-------
-29-
FOR USE OF io~* RISK LEVEL:
Use of the 1 X 10~5 lifetime, cumulative carcinogenic risk level as
opposed to the 1 X 10"6 level is considered more appropriate for a soil
CAL for this site because residential development is unlikely because of
the industrial usage of the area.
Use of the 1 X 10"5 lifetime, cumulative carcinogenic risk level is
considered more appropriate for the ground water CAL as opposed to the I X
10~6 level because the Calumet aquifer is little used in the vicinity of
the Site, and because there are multiple contaminant sources that are
affecting the Calumet aquifer in the vicinity of the Site. In addition,
the 10"*6 level is generally well below the analytical detection limits for
the constituents of concern.
CRITERIA FOR CONTROL OF AIR EMISSIONS:
Each separate source of air emissions shall be controlled to prevent
exposures to the nearest resident and workers on adjacent properties fron
causing an estimated cumulative, incremental, lifetime carcinogenic risk
exceeding 1 x 10~7. Since there are multiple operations that cause air
emissions, each must be controlled to the 1 x 10~7 carcinogenic risk level
to assure that the total risk will be less than 1 x 1CT6. The following
operations will be considered separate sources:
1. Subsurface soil excavation and handling;.
2. Emissions from S/S;
3. Emissions from ground water treatment.
The risk levels will be calculated using conservative assumptions, the
procedures in the U.S. EPA Public Health Evaluation Manual and Exposure
Assessment Manual, and the most recent U.S. EPA published carcinogenic
potency factor. The emissions must also be controlled to prevent any non-
carcinogenic risk either on-site or off-site. Fugitive dust must be
controlled in compliance with State of Indiana requirements.
The selected remedial actions will be protective of human health and the
environment, will attain applicable or relevant and appropriate Federal
and State requirements and are cost effective. The remedy satisfies the
statutory preference for remedies that employ treatment that reduces
toxicity, mobility or volume as a principal element and utilizes permanent
solutions and alternative treatment technologies to the maximum extent
practicable.
The State of Indiana is expected to concur with the selected remedial
actions. Although there is some public concern about the deep well
injection operation, it is believed that the protective measures required
in U.S. EPA's Underground Injection Control Program coupled with source
(soil) treatment provide a more acceptable technology for the community
than the further degradation of the existing Calumet aquifer or the Grand
Calumet River.
-------
-30-
Because the remedy will result in hazardous substances remaining cm-site
above health-based levels, a review will be conducted within five years
after commencement of remedial actions to ensure that the remedy continues
to provide adequate protection of human health and the environment.
-------
- APPENDIX TO MIDCO II RECORD OF DECISION
Table 1: Concentrations in Various Environmental Media
Table 2: Standard Parameters Used for Dosage
Table 3: Potential Exposure Pathways for the Midco II Site
Table 4: Routes of Exposures Used in Calculation of Intakes
Table 5: Characteristics of Subchronic/Chronic Exposure
Scenarios
Table 6: Midco II location Specific Requirements
Table 7: Midco II Action Specific Requirements
Table 8: Alternative's Compliance with Applicable laws and
Regulations
Table 9: Comparison of Concentrations of Inorganics in Sub-
surface Material at Midco II with Concentrations in Listed
Hazardous Wastes
Table 10: Effectiveness Evaluation of Alternatives
Table 11: Inplementability Evaluation at Alternatives
Table 12: Detailed Analysis Summary
Table 13: Midco II Estimated Costs in Millions of Dollars .and Time
to Implement
Table 14: Midco II Table of Effectiveness and Inplementability
Table 15: Alternative 7 ... Cost Estimate
Table 16: Alternative 8 ... Cost Estimate
Table 17: Ground Water Cleanup Action Levels
Table 18: Soil Cleanup Action Levels
Table 19: land Disposal Restriction Treatment Standards for Waste
Categories F001, F002, F003, F005 (from 40 CFR 268.41)
Table 20: Proposed land Disposal Restriction Treatment Standards for
Waste Categories F007, F008, F009 (from F.R., Vol. 53, No. 7,
p. 1068)
Table 21: Alternative Treatability Variance Levels and Technologies for
Structural/Functional Groups
-------
Responsiveness Summary
A Guide to the Federal Underground Injection Control Program in Indiana
Waste Treatment Results for Inorganics
-------
Table 1
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5.40E.01
i.ooe.oi
1.10(.01
2.006.0*
5.006.02
3.ME.01
•.ME.01
1.ME.02
5.106.01
1.42E.02
»*OE.Ot
3*06.0*
1 106.03
3.50E.O4
7.306.03
1.70E.01
4.40E.O*
1.40E.04
1.42E.OI
1.1M.04
1.00E.02
1.701.01
1.70E.03
1.701.01
l.20(.09
1.10(.0t
l.ME.OI
I.ME.OI
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1.70(.0t
3 ME. 02
1.10E.02
1 056.01
4.ME.01
4 JOE. 01
MtE.Ot
SOOM
eONCEMTVUTiaNS
PHASE 1
OMOUNO WATER
(nut.)
MD 5.516.01 1.01E.OO
NO 1.7IE41 1.40(42
NO 1.146.00 1.7U41
NO 1 .40(42 2.17(43
7.20641 1.146.02 1.52E.02
NO I.12E.OO 1.00(41
NO 500642 2.17«41
NO 9 Otf *>40 '4.21C41
1.10(41 122(.01 1.17E.01
ND 2.11(41 7.41(42
7.00(41 «.*4(.02 1.1«(.01
NO 1.1M.OO 1.17(41
NO 241(49 1.12(4*
NO t.ME.Ot 1.2X41
4.MC.OO 2.12E.04 l.14(.03
NO 2.12(41 7.40(42
NO 100(42 1.25(42
t.tO(.OO 1.SH.O4 4.7OE.49
NO 7.10(42 1.7X42
ND 1.10E.O1 1.74(41
NO 1.00(42 1.04(42
NO 2.10E.OO 4.21641
ND 7.13E.OO 4.11(41
ND 4.40(41 1.11(44
ND 110(.01 lt*(.aO
ND NO MD
NO 7,10(42 1.00(41
NO 2.*0(.00 155(41
MD 2.506.01 13M.OO
MD 1.10(41 1.1X44
MD 1.10(41 7.1U42
MD 2 40(41 1 11(44
MD 1.00(41 115642
MD 1.20E49 1.42(44
MD 7.10(42 1.04(41
NO 2.40642 1.11(41
ND 110(41 1.11(42
NO 140E.OO 7.1X41
NO 4:40(49 1.11(44
NO 2.006.01 1.1M41
ND 2.4M41 l*K4t
ND 4.MC49 1.4X44
NO 1.10(41 1.11(42
NO LtOE.OI 2.52(.00
NO 110141 1.7X44
MO IJM.OI MU.09
NO 2.20(41 1.17(41
ND 2.10(41 2.17E44
ND 1.20(41 2 2*644
ND 1.10(41 1.11(44
ND 1.00(42 4.3M44
•3 PCW IKOCATCW CHEUCAL SEUC
AMD KM VALUES IN VARIOUS EMVIM
PHASE 2
OMOUMO WATER
3.00642 4.AOE41 1.42E41
ND 1.146.00 1.17(41
7.WE41 1.42(^0 3.0*641
NO 1J0642 7.I2E44
NO 2.70(42 1.07(41
•.HE-JO l.S4E^2 U1E.02
NO 1.00(42 I.MC42
NO 1.70(42 1.73(41
(.00(43 I.IK^O 4.41(41
1.70(42 3.M6.O1 2.ME.OO
1.ME43 1.14(41 1.22(42
421E^O 1.71(^2 1.1K.01
1.10(41 1^7(^1 1.07C.OO
MD 140E44 4.12E4*
MD 1.55(^0. 2.11(41
l.KE>0* 1.71(^4 4.12E.01
MD 1.30C.OO 4.ME41
NO 1.00(42 1-33(43
ft.C7C*>49 1 A4C**)*! 4 04*(*A1
NO 1.72E41 1.17E42
MD 4.10(42 1.14(42
1*0(42 7.10(41 1.74(41
MD 4.ME.40 13M41
NO NO NO
NO I.IOE^I 175(41
NO ND NO
NO 140(42 1.02(42
ND ND NO
NO 1.00(41 724(42
NO 1.10(42 171(41
ND 4.106.00 111(41
1
ND 1.14(^0 1.1U41
ND 1.10(41 4.1M42
NO 120(41 1ME44
NO 100641 4.17(43
ND 1.10(42 1.11(41
NO 1.00(41 117(42
NO 12«C.4t 1.2M.OO
NO 1.40(42 7.00(44
NO 1.406.01 t.0((41
ND 1*0(42 1.31(42
ND 100(41 101(42
NO 1.MC4I 5.ME42
MO 4.401 *>41 ft.04Cf>00
MD t.401^1 1421.00
MD 1.10(42 451(44
TON:
XUENTAI. MEDIA.
SURFACE WATER
PHASE 1
1.11E41 I.ME.OI 3.ME.OO
117(43 121(42 1.47E41
7.11(42 441E41 1.47(41
NO MD MD
MD 4.11E-03 1.0X49
171E.01 171E.02 1.ME.02
MD 117(41 I41C42
MD 1.71(42 1.2SE41
1.1*642 2.146.00 113E41
111^0 1.22E.01 1.01.01
1.ME41 1.ME42 1.12E42
3.11(^1 11*6.02 5.43E.01
1.71(41 107E.OO 1.40C41
MD 1.04E41 2.IM4*
MD 1JM.OO 1.11(41
1*2(.04 130E.01 7.MC.02
4.21(44 1. $43(42 7.17E41
7.02(41 7.10(43 7.41(43
1J4E.02 1.2M.03 *.2«E.02
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MD (.17(41 1.0M41
MD 11K-02 1.02(49
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1.17(42 2.7U.OO 1.37E41
MD 144(49 1. 10(44
MD 1.1K.O1 1.12(^0
MD MD MD
MD 2.7M42 2.MC43
MD 7.41C42 124(49
4.2M44 t.*4l.OO 2.72E.OO
MD 1.13(43 (.53(45
MD 2.0M41 4.00(42
MD 1.01(41 1.HE43
MD 2.MC43 2.0M44
MD MD MD
MD 2.ME42 1.1X49
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MD 1.11(42 74*641
MD MD MD
MD 11U.OO 421(41
MD 1.14(41 1.10(44
MD 7.02E.OO 1.41(41
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NO 1.03E42 3.S5E43
1.446^)1 114E.02 1.4JE.02
NO 2.13E42 S.I1E43
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1*4642 • 056-01 1S4E4I
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5.11 £42 S.11E42 S.HE42
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1.1«E^2 1.316^1 5.706.02
S.44E44 7.4SE41 170E41
NO NO NO
1*0(41 1.74(42 4.1SE41
1.ME42 171E41 1.556-01
1.11(42 I.ME^O 1.ME41
NO NO NO
ND 1.11(^1 1.41E.OO
NO ND ND
NO 1.47E42 121 £41
NO 2.JOE-01 1S2E42
ND. 1.5*6-90 1ME41
MD MD NO
NO 1.47C41 1.74(42
NO 1.17(41 1536-02
MD NO MO
MO 111(43 1.55E44
NO 3J1E42 151(43
NO 1.11(41 1.71E44
NO 111E41 1*06-02
ND 14IE41 1S1E44
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NO 4.11(41 4.21E44
NO ' 4116-JO 1.ME41
NO 114(42 101(41
NO 1.7«(41 125644
NO 2.03641 1ME42
NO IME^I 10IE.OO
NO NO NO
NO 1.MI«01 205E.OO
MD MD NO
MD MD NO
NO ND NO
MO NO NO
NO 1ME-03 17IE44
NO NO NO
MO 772E4S 5S2E-0*
. UNKNOWN. NO lOXClTV CONSTANTS FOHTHfi EMVIRONMENTAU MEDIA AVAIVABLE
- REFERENCE OOSE AVAICAIXC. TVIEREFOaf. CONSIOEWO M T>«( HNM. IS VALUES
-------
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7J*l-«1
MM.oe
i.oic.oa
NO
MO
t.tM«4*
•.10C-41
i.40f»oe
(.44C.04
1.44C.O*
I.12C.03
1.WC»41
1 .1*4.44
1.1*C.O*
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4.1M««e
1.47C«41
MO
4.771 «00
S.Mf«tt
1.231^4
1141.04
I.Uf^l
X.04f*41
(.OOS41
».1»f.8J
H4I-41
1.7tf«02
*.«7C«41
4.MC»oa
t*4C«41
MO
11M«40
440(^0
I.IOi.OO U7f-«1
BM2-4«*tt«vl)eM
2-Buum (UEK)
1.1-OM «•«»•!•
Trw» t .2-oWMreOTww
2,4-OUNorocMnol
U-OkfttravraMm
2.4.0«OTi|>pnml U
OaetHt
2-u.tiHnumnMm U
iMtiywm cnana*
4.tta4V4-*4nM<* U
ND
MD
4.40142
ND
MD
MO
MB
NB
MB
NB
MO
NO
MD
MD
NB
ND
ND
MD
MO
MB
MB
MB
M)
MO
NB
MB
10
M)
ND
ND
ND
NO
ND
MD
ND
ND
MD
MD
(.441.01
K71.41
4.441.41
120141
1.101.41
7.44141
120142
1.*4t«40
1.20!.04
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4401.00
4.10141
110141
1*0141
NO*
1*4141
1*01.40
11444*
120141
4.M1.40
r701.00
170142
1.441.41
1001.40
110141
104141
7.041.40
4.40141
4.02I.4t
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1.44€«41
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2.131-01
It If -01
1MI-01
*.*Tf-01
NO
4.S»f-OZ
UN4t
140444
114144
4.17141
1711.01
1.011.40
4.441-02
1.411.40
(14141
•.(7141
1.41142
1.101.00
MB
MB
MB
ND
MB
ND
140142
ND
. NB
NB
NB
7.(H««i 1.«M»«2
1.44«.4»
t.44€.41
I.7M-4I
1.44I«M
4.444.42
1.00441
110441
4.20(42
4.10142
4.411.41
1.41141
1.2*141
4.00141
17*1.00
1.10142
L*OC*00 7.MC41
7.11(41
444141
1171.01
NB
443441
1.401.00
1.401.02
MB
1401.40
(.104.01
MO
NB
MB
NB
NO
MB
ND
ND
MB
ND
ND
NB
114«.
1. 141.41
I.MC.42
MOf-01
4.*01.41
4.441.41
«JOf.41
1UI.41
I.Uf^l
4.711-41
4411.04
1.1*1.41
t.44C«44
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l.MC*4l
1101.01
1701.09
1»0€.4J I.IM>42
t.«U»«
1201.00
1*41.02
MD
MO
MD
MD
MO
MD
ND
MO
1.441.41
MO
MD
NO
MD
MO
MO
MD
MD
MO
MD
NO
MD
MO
MO
MO
2.116*04
1.20S.01
S.ME.O2
l.Mf.40
I.44C»41
».77€.04
7.*1C»41
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1.916.02
1.401.01
1701.01
(.441.04
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1.101.01
1.101.01
1.101.41
4*01.02
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4.441.44
1 401.01
(.441.01
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4*01.41
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7041.01
(.141.41
«(41.41
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4.I1E»44
1211.01
1.0*1.01
7.131.01
4.0OE.OO
14*1.01
1.3*1.04
17*1-41
4*41.00
1791.04
17(1.00
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1(11.01
(.25C.40
1.«7t.«
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1.0(1.42
2.2SE.04
4141.00
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1 0*1.00
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1.M4.01
1111.41
2.141.01
1 101.01 1*11.02
120(41 4.17142
4.44141 1.17(41
120141 114142
4.40141 110441
1.04C-01
t.44f-41
1.411-41
I.Wf-OI
NB
NB
tMf.04
«.Mf.41
1.MI.40
t.OOf^l
MD
MO
1 *41.41
(.241.41
I.7SC.44
2.201.41
144C-42 I.44C-43
1.21 E.44
MB
MD
NB
^g
(.701.01
MB
MB
1401.00
2.07E.01
2.MI.OO
1.441.41
4.001.41
NB
MB
2.141.42
ND
1.141.04
1.(01.02
ND
MB
1.401.40
NO
MB
MD
ND
MB
MB
ND
ND
MD
MD
NB
MB
ND
ND
to
NO
ND
MB
MB
NB
MB
ND
ND
ND
NB
NB
ND
ND
MB
MB
NB
NB
ND
MD
ND
M3
NB
NB
NB
NB
ND
MD
ND
NB
ND
ND
ND
ND
NB
NB
ND
MD
ND
ND
ND
»«O-imre»rml»n.n4ff» u
ln(2-«Mn»«V)»*w
»X2-cn«Maprapy
-------
1. COMTMUCD
ANALYST Id
Qg
ONOUNO WATCH
IjMkM
4.X-OOC
L70C-02
l.MC-41
L*ie-a>
t.tec.01
IO
IO
4.HCWM
i •
«.4oe-ej
4.*ec-«a
7.7M-01
to uoe-at
tToe-ai
1J3C-01
LMC.OO
7001^1
4.UI.O4
t.tse^i
inc-ai
1JM<«
. 7.MC-O1
1.70f«O1
w
w
1JOC-09
r.toc-ca
1JOC-01
Ml-MMMI**
IO
«.tac-a
IO
I.10C-M
loac-a
ux-oi
1.7M-M
i.rw-ei
LZ2C-01
IO
IO
IO
(.401^0
i.oec«ca
to
IO
M)
to
IO
2.1ff*04
i.nc«oa
t.4OC«O4 1 .Ue.04
i.ioc«oe «joe-oi
1*0(^0
«.*oe-ot
i.nc-ei
i.«oc-oi
HOe-01 2.MC-OI
aoot^o
4JOC-01
t.ao«-ai
Z.MC-O2
looe-oi
to OOPC^B o.ooc»oo
4.IOC41
HO t.Tot-ca t.«ac-oa
to a.eec-ei
tat-ea x«oc-oi 2.4K-01
U • UMIMOWN. NO TQXCirr CO««1£
IT . HCn««MC( OOM MMUW.C. TI«MVOMf. OOMSMMCO W TMC TWM. • VMUO
-------
Table 2
TABLE 6-1
Standard Parameters Used for Calculation of Dosage and Intake
Parameter
Physical Characteristics
Average Body Weight
Average Surface Area
Activity Characteristics
Amount of Water Ingested Daily
Amount of Air Breathed Daily
Amount of Foh Consumed Daily
Sol Ingested (Pica) Daily
Frequency of Water Use tor Swimming
Duration of Exposure While Swimming
Percentage of Surface Area Immersed
While Bathing
Length of Exposure While Bathing
Length of Additional Exposure After Bathing
Amount of Air Breathed Whie Bathing
Volume of ShowerstaU
Volume of Balhroom
Volume of Water Used While Showering
Material Characteristics
Oust Adherence
Transfer Ratio of Contaminant From Water
to Air
Mass Flux Rata (water-based)
Adult
70 kg (1.2)
18150 cm2(1)
2Eters(1)
1
20m3(1)
6-58(1)
7days*r{1)
2.6hrs/day(1)
0.8(4)
20min(5)
10min(5)
.S5m3(1).(5)
3m3(5)
10 m3 (5)
200 iters<5)
0.51 mg/cm3 (6)
1/10000 (4)
0.2-0.5 mg/cm2/hr(1)
Child age 6- 12
29 kg (3)
10470 cm2 (3)
1 liter (2)
11m3(1)
7days/yr(l)
2.6 hra/day (1)
0.8(4)
20mh(S)
10 mm (5)
.60m3(1).(5)
3m3(5)
10 m3 (5)
200ilers(5)
Child age 2-«
16 kg (3)
6980 cm2(3)
1 Bter (2)
6m3(1)
1.0 fld)
0.8 (4)
20min(S)
10 min (5)
.49m3(1).(5)
3m3(S)
10 m3 (5)
200 liters(S)
(1) U.S. EPA. 1986a
(2) U.S. EPA. October 1986
(3) U.S. EPA. 1985d
(4) U.S. EPA. 19846
(S) Symms. 1986
(6) Lepow. 1974
-------
QJ
-------
Table 6-5. (Cc cd)
MIDCO II
Exposure Pathway Analysis
Nearest Residence Scenario
Ground Water
Soils
(Sediment!)
Surface Water
PATHWAY
Waste Reaction
Contaminated fill/soil
Contaminated surface
water
Movement through
aquifer - use through
residential and
industrial wells
Contaminated fill/soil
ground water
discharge to Grand
Calumet River
ground water
discharge to Lake
Michigan
Ground water discharge
to drainage ditch
EXPOSURE
MECHANISM
Volatilization
Volatilization
Adsorption to dusti
Volatilization
Drinking water
Bathing
Hand-washing
Industrial/Household
Use
Adsorption to dusts
Casual contact
Volatilization/aerosols
Recreation/Fishing
Casual contact
Volatilization
TYPE OF EXPOSURE
Dermal Contact
Inhalation
Inhalation
Dermal Contact
Inhalation
Inhalation
Ingestion
Dormal contact
Inhalation
Dermal contact
Inhalation
Inhalation
Dermal contact
Inhalation
Ingestion
Dermal contact
Inhalation
Ingeslion
Dermal contact
Inhalation
Bioaccumulation
Dermal contact
Ingestion
Inhalation
Bioaccumulation
SELECTED FOR ANALYSIS
No - not likely, site covered with fill
with partial vegetation
Yes - probably low exposure levels
No - not likely, site covered with fill
with partial vegetation
Yes
No -drinking water well removed
from contamination
No - well removed from contamination
No - well removed from contamination
No
No
No
No
Yes - contact probably minimal, dilution
Yes
No - not used for drinking water
Yes - contact probably minimal, dilution
Yes
No * currently under investigation
by U.S. Fish and Wildlife
Yos
No - not used for drinking water
Yes
No - currently under investigation
by US Fish and WiWIilo
-------
Table 4
Table 6-8
Midco II
Routes of Exposure Used in Calculation of Intakes
Exposed Routes of Exposure
Exposure Scenario Population Dermal Ingestion Inhalation
On-site Scenario Child 2-6 Play in Soil Drinking Water Household Air
Bathing PICA Bathing
Child 6-12 Play in Soil Drinking Water Household Air
Play in Surface Water Bathing
Bathing
Adult Recreation in Surface Drinking Water Household Air
Water Bathing
Bathing
Nearest Residence Child 2-6 Household Air
Child 6-12 Play in Surface Water Household Air
Adult Recreation in Surface Household Air
Water
-------
in
Table 6-9
MIDCO II
Characteristics of Subchronic/Chronic Exposure Scenario*
Route ol Exposure Media
Dermal Soil
Activity
Play
Population
Child age 26
Child age 6-12
Subchrontc Exposure
Characteristics
Three exposure events (hands
only) at average concentration
or one event at highest cone.,
whichever Is greatest
Chronic Exposure
Characteristics
One exposure event (hands only)
per day, 150 days per year, at
average concentration
Surface Water Recreation Child age 6-12 Three hours ol exposure (20%
Adult ol body) at average concentration
or one hour at highest concentration,
whichever Is greatest
Ground Water Showering/ Child age 2-6 One hour ol exposure (80% ol body)
Bathing Child age 6-12 at average concnetratlon or 20 min.
Adult at highest concentration, whichever
Is greatest
One hour ol exposure (20% ol
body), 150 days per year, at
average concentration
20 minutes ol exposure (80% ol
body) at average concentration 365
days/year
Ingettton Soil Pica Child age 2-6 5 gram per day at average
concentration or 1 grams at
highest concentration, whichever is
greatest
Ground Water Drinking Child age 2-6 3 liters at average concentration or
Water Child age 6-12 1 liter at highest concentration
whichever Is greatest
Adult 6 liters at average concentration or
2 liters at highest concentration,
whichever Is greatest
1 gram per day, 150 days per
year, at average concentration
1 liter per day, 365 days per year,
at average concentration
2 liters per day. 365 days per year.
at average concentration
-------
Table 6 - 9 (continued)
MIDCO II
Characteristics of Subchronlc/Chronlc Exposure Scenarios (Continued)
Route ol Exposure
Media
Activity
Population
Subchronlc Exposure
Characteristics
Chronic Exposure
Characteristics
Inhalation Combined Soil/ Home Child age 2-6 24 hours of exposure 160 m on-site
Surface Water Child ege 6-12 and 1609 m oil-site from source at
Emission average predicted emission rate or
18 hr at highest predicted emission
rate, whichever Is greatest
Adult 24 hours of exposure 160 m on-site
and 1609 m oil-site from source at
average predicted emission rate or
16 hr at highest predicted emission
rate, whichever Is greatest
Ground Water Showering/ Child age 2-6 One hour of exposure at average
Bathing Child age 6-12 concentration or 20 minutes at
Adult highest concentration, whichever
Is greatest
18 hours of exposure, 365 days
per year, .160 m from source on-slte
and 1609 m from source off-site at
average predicted emission rate
16 hours of exposure. 365 days
per year, 160 m from source on-slte
and 1609 m from source oil-site at
average predicted emission rate
20 minutes of exposure, 365 days
per year at average concentration
Home Child age 2-6 24 hours of exposure at 0.0001 x
Child age 6-12 the average ground water cone.
or 16 hours at 0.0001 x the
highest concentration, whichever is
greatest
Adult 24 hours of exposure at 0.0001 x
the average ground water cone.
or 16 hours at 0.0001 x the
highest concentration, whichever Is
greatest
16 hours of exposure. 365 days
per year, at 0.0001 x the average
ground water concentration
16 hours of exposure, 365 days
per year, at 0.0001 x the average
ground water concentration
-------
TABU 1.14
NIOCO II
iocATiQM.s»cciric REOUIRE>CNTS
Table 6
LOCATION
gOUlBOCNT WO CITATION
APPLICABILITY
Within 100 year floodplain
*Ithin floodplain
Within wit doate formation,
underground «ne, or cave
Within area «nere action may
c*u*e irreoeribl* h*r*. lot*.
or destruction of significant
artifact*
Hiitorie project owned or
controlled By federal agency
Critical nabitat uoon nhicn
endangered ipeciea or
threatened specie* depend*
•etland
wetland
wildernee* area
wildlife refuge
Area sffecting stree* or river
within art* effecting
national -ild, >cmic. or
recreational rivtr
Within coaatal ton*
Ocean* or »aten of tnt
United Statea
within 200 feet of fault
di(placed in Halocene tiaw
TSD facility must be designed, conatructed, operated,
and Mintained to avoid vaahout
(40 CTR 264.18(b»
Action in floodplain to avoid adverae effecta, ainiaue
potential hara, reatore and preaerve natural and beneficial
value*
(Ciecutiv* Order 11988, Protection of flooaolain*,
(40 etlanda
(C>ecuti»e Order 11940, Protection of Vetlanda,
40 CTR 6, Appendix A)
Action to prohibit diaeharge of dredged or fill aatenal
into >etland "itnout perait
(Clean (Tatar Act Section 404; 40 CTR Parta 230, 231)
federally-»ned area deaignated aa oildameaa area «u»t be
adainiatered in tucn Banner a* >ill leave it uniapaired
M 'ildemeta and to preserve ita oilderneaa character
(•llderneaa Act (16 U.S.C. 1131 at aea.); 50 CTR 35.1 ,t aeq.)
Only action allotted under the proviaiona of 16 U.S.C. Section
668 tfd(c) eay be widertaken in areaa that are part of the
National "ildlife Refuge Svatm
(U.S.C. 668dd et «eq.; 50 CTR Part 27)
Action during diversion, channeling or other activity that
•edifies a atrea* or river and affects fisn or vildlife
(fish and "ildlift Coordination Act (16 U.S.C. 661 et. sea.,
40 CTR 6.M2J)
Avoid taking or assisting in action that oill nave direct
edvera* effects of scenic river
(Scenic Rivers Act (16 U.S.C. 1271 et seq. Seetin 7 (a));
40 CTR 4.302 (e))
Conduct activitiea affecting the coaatal nne in mnner
consistent -ith approved State •anage'ent program*
(Coaatal Zone Management Act (16 U.S.C. Section 1451 et seq.))
Action to dispose of dredge and fill aattrial i* prohibited
•ithout a pemt
(Clean Water Act Section 404 CTR 12) Suepart M; Marine
Protection Resource* and Sanctuary Act Section 103)
New treatawnt, storage or disposal of haardoua oaate
pronibited
(40 CTR 26*.18(a))
Migratory bird flight pattern Migratory Bird Treaty Act
Area affecting lakes and
itraao*
Habitat for «arm« iwuala
Lake in Indian*
•itnin fleodpliin m Indiana
Indiana nabitat upon >hich
nonganc or endangered
specie* depend
Anadrooou* fish Conservation Act
Marine MaMal Protection Act
lake Preaervation Act
(13-2-11.11
flood Control Act
(13-2-22J
Nongane and endangered Species Act
(14-2-8)
within Ineiana nature preserve Nature Preserves Act
(14-k-5)
Not applicable
Not applicable
Not applicable
applicable
Not applicable
applicable
Applicable to •etlmoa on or
near site
Applicable to netlands on or
near sice
Not spplicable
Not applicable
Applicable to »trrr» or river
on or neer site effected by
remediation activitiea
Not applicable
Not applicable
Applicable to sire** or rivrr
on or nesr site •feciea or
reaediation activities
Not applicable
Applicable to area affected e<
by reoediation activities
Applicable to lake or streaa on
or near atte affected by
remediation activities
Not applicable
Not applicable
Not apolicable
'•o: applicable
'•ot aoplicable
-------
Table 7
TABLE 1-15
MIDCO II
ACTION-SPECIFIC REQUIREMENTS
Page 1 of 9
Action
Requirement and Citation
Air Stripping
Capping
Consolidation
Proposed standards for control of emissions of volatile
organics.
Placement of cap over waste requires a cover
designed and constructed to:
o Provide long-term minimization of migration of
liquids through the capped area;
o Function with minimum maintenance;
o Promote drainage and minimize erosion or abrasion
of thp cover;
o Accomodate settling and subsidence so that the
cover's integrity is maintained; and
o Have a permeability less than or equal to the
permeability of any bottom liner system or natural
subsoils present.
Eliminate free liquids by removal or solidification.
Restrict use of property as necessary to prevent
damage to cover.
Prevent run-on and run-off from damaging cover.
Stabilization of remaining waste to support cover.
[40 CFR 264]
Placement on or in land outside unit boundaries or
area of contamination will trigger land disposal
requirements and restrictions.
,[40 CFR 268 (Subpart D)]
-------
TABLE i-15 (continued)
Page 2 of 9
Action
Requirement and Citation
Direct Discharge
of Treatment
System Effluent
Use of best available technology (BAT)
economically achievable is required to control
toxic and nonconventional pollutants. Use of best
conventional pollutant control technology (BCT) is
required to control conventional pollutants.
Technology-based limitations may be determined on a
case-by-case basis.
(HO CFR 122.44(a)]
Applicable federally approved state water quality
standards must be complied with. These standards
may be in addition to or more stringent than other
federal standards under the CWA.
[40 C.FR 122.44 and state regulations approved under
40 CFR 131]
Applicable federal water quality criteria for the
protection of aquatic life must be complied with
when environmental factors are being considered.
[50 FR 30784]
The discharge must conform to applicable water
quality requirements when the discharge affects a
state other than the certifying state.
[40 CFR 122.44(d)]
The discharge must be consistent with the
requirements of a Water Quality Management Plan
approved by EPA.
[40 CFR 122.44(d)]
Discharge limitations must be established for all toxic
pollutants that are or may be discharged at levels
greater than that which can be achieved by
technology-based standards.
[40 CFR I22.44(e)]
Develop and implement a BMP program and
incorporate in the NPDES permit to prevent the
release of toxic constituents to surface waters.
[40 CFR 125.100]
-------
TABLE 1-15 (continued)
: Page 3 of 9
Action Requirement and Citation '
The BMP program must:
o Establish specific procedures for the control of
toxic and hazardous pollutant spills;
o Include a prediction of direction, rate of flow,
and total quantity of toxic pollutants where
experience indicates a reasonable potential for
equipment failure; and
o Assure proper management of solid and hazardous
waste in accordance with regulations promulgated
under RCRA.
[40 CFR 125.104]
Discharge must be monitored to assure compliance.
[40'CFR 122.44(0]
Approved test methods for waste constituents to be
monitored must be followed. Detailed requirements
for analytical procedures and quality controls are
provided.
Sample preservation procedures, container materials,
and maximum allowable holding times are prescribed.
[40 CFR 136.1-136.4]
Permit application information must be submitted
including a description of activities, listing of
environmental permits, etc.
[40 CFR 122.21]
Monitor and report results as required by permit.
[40 CFR 122.44(0]
Comply with additional permit conditions.
[40 CFR 122.41(0]
-------
TABLE 1-15 (continued)
Page 4 of 9
Action
Requirement and Citation
Discharge to POTW
Discharge of Dredge and
Fill Material to
Navigable Waters
Pollutants that pass through the POTW without
treatment, interfere with POTW operation, or
contaminate POTW sludge are prohibited.
Specific prohibitions preclude
pollutants to POTWs that:
the discharge of
o Create a fire or explosion hazard in the POTW;
o Are corrosive (pH <5.0);
o Obstruct flow resulting in interference;
o Are discharged at a flow rate and/or
concentration that will result in interference;
o Increase the temperature of wastewater entering
the treatment that would result in interference
but in no case raise the POTW influent
temperature above 104°F;
Discharge must comply with local POTW pretreatment
program; and
[tO CFR 403.5 and local POTW regulations]
RCRA permit-by-rule requirements must be complied
with for discharges of RCRA hazardous wastes to
POTWs by rail, truck, or dedicated pipe.
[frO CFR 264.71 and 264.72]
The four conditions that must be satisfied before
dredge and fill is an allowable alternative are:
o There must be no practicable alternative;
o Discharge of dredged or fill material must not
cause a violation of state water quality standards,
violate any applicable toxic effluent standards,
jeopardize an endangered species, or injure a
marine sanctuary;
-------
TABLE 1-15 (continued)
Page 5 of 9
Action
Requirement and Citation
Excavation
Ground Water Diversion
Incineration (On-Site)
o No discharge shall be permitted that will cause or
contribute to significant degradation of the water;
o Appropriate steps to minimize adverse effects
must be taken; and
o Determine long- and short-term effects on
physical, chemical, and biological components of
the aquatic ecosystem.
[40 CFR 230.10 and 33 CFR 320-330]
Movement of excavated materials containing RCRA
hazardous wastes to new location and placement in or
on land will trigger land disposal restrictions.
Excavation of RCRA hazardous waste for construction
of slurry wall may trigger cleanup or land disposal
restrictions.
Analyze the RCRA hazardous waste feed
[40 CFR 264.341]
Dispose of all hazardous waste and residues including
ash, scrubber water, and scrubber sludge.
[40 CFR 264.351]
Performance standards for incinerators:
o Achieve a destruction and removal efficiency of
99.99 percent for each principal organic hazardous
constituent in the waste feed; and
[40 CFR 264.343]
o Reduce hydrogen chloride emissions to 1.8 kg/hr
or 1 percent of the HCL in the stack gases
before entering any pollution control devices.
[40 CFR 264.342]
-------
TABLE 1-15 (continued)
Page 6 of 9
Action
Requirement and Citation
Land Treatment
Monitoring of various parameters during operations of
the incinerator is required. These parameters
include:
o Combustion temperature;
o Waste feed rate;
o An indicator of combustion gas velocity; and
o Carbon monoxide.
Special performance standard for incineration of
PCBs. .
[40 CFR. 7611.70]
Special requirements for incineration by Indiana
Department of Environmental Management, including a
trial burn and extensive sampling.
Ensure that hazardous constituents are degraded,
transformed, or immobilized within the treatment
zone.
[40 CFR 264.271]
Maximum depth of treatment zone must be no more
than 30 feet from the initial soil surface, and more
than 3 feet above the seasonal high water table.
[40 CFR 264.271]
Demonstrate that hazardous constituents for each
waste can be completely degraded, transformed, or
immobilized in the treatment zone.
[40 CFR 264.271]
Minimize run-off of hazardous constituents.
[40 CFR 264.273]
Maintain run-on and run-off controls and management
system.
[40 CFR 264.273]
Unsaturated zone monitoring.
[40 CFR 264.281]
Special requirements for ignitable or reactive waste.
[40 CFR 264.282]
-------
TABLE 1-15 (continued)
Page 7 of 9
Action
Requirement and Citation
Slurry Wall
Treatment
Underground Injection
of Wastes and Treated
Ground Water
Special requirements for incompatible wastes.
[40 CFR 264.282]
Special requirements for F020, F021, F022, F023,
F026, and F027 wastes.
CFR 264.283]
Excavation of RCRA hazardous waste for construction
of slurry wall may trigger cleanup or land disposal
restrictions.
[40 CFR 268]
Proposed standards for miscellaneous units require
new units to satisfy environmental performance
standards by protection of ground water, surface
watef, and air quality, and by limiting surface and
subsurface migration.
Treatment of wastes subject to ban on land disposal
must attain levels achievable by best demonstrated
available treatment technologies (BOAT) for each
hazardous constituent in each listed waste.
[40 CFR 268.10-13]
BOAT standards for spent solvent wastes are based
on one of four technologies. Any technology may be
used; however, if it will achieve the concentration
levels specified.
[RCRA Sections 3004(d)(e).(e)(3)
42 U.S.C. 6924(d)(3).(e)(3)]
UIC program prohibits:
[40 CFR 144.12]
o Injection activities that allow movement of
contaminants into underground sources of drinking
water and results in violations of MCLs or
adversely affects health; and
o Construction of new Class IV wells, and operation
and maintenance of existing wells.
[40 CFR 144.13]
-------
TABLE 1-15 (continued)
Page 8 of 9
Action _ . _ _ Requirement and Citation _ __
Wells used to inject contaminated ground water that
has been treated and is being reinjected into the
same formation from which it was drawn are not
prohibited if activity is part of CERCLA action.
[40 CFR
All hazardous waste injection wells must comply with
the RCRA requirements.
[40 CFR 144.16]
Owners and operators must:
[40 CFR 144.26-27]
o Submit inventory information to the director of
the state U1C program;
o Report non-compliance orally within 24 hours; and
o Prepare, maintain and comply with plugging and
abandonment plan.
Monitor Class I wells by:
o Frequent analysis of injection fluid;
o Continuous monitoring of injection pressure;
o flow rate and volume; and
o Installation and monitoring of ground water
monitoring wells.
Applicants for Class I permits must:
[40 CFR 144.55]
o Identify all injection wells within the area of
review; and
o Take action as necessary to ensure that such
wells are properly sealed, completed, or abandoned
to prevent contamination of USDW.
-------
_ TABLE 1-15 (continued)
Page 9 of 9
Action _ Requirement and Citation _
Criteria for determining whether an aquifer may be
determined to be an exempted aquifer include current
and future use, yield, and water quality
characteristics.
CFR
Case and cement all Class I wells to prevent
movement of fluids into USDW, taking into
consideration well depth, injection pressure, hole size,
composition of injected waste and other factors.
Conduct appropriate logs and other tests during
construction and a descriptive report prepared and
submitted to the UIC Program Director.
Injection pressure may not exceed a maximum level
designed to ensure that injection does not initiate
new fractures or propagate existing ones and cause
the movement of fluids into a USDW.
[40 CFR 146.13]
Continuous monitoring of injection pressure, flow
rate, and volume, and annual pressure, if required.
Demonstration of mechanical integrity is required
every 5 years.
Ground water monitoring may also be required.
-------
00
OJ
A >C H 5G 4
Resource Conaervation and
Recovery (RCRA) - Subtitle C
tO OH HI Slenderd for
Gmeretor*
*0 CTR 264-26* Standarda for
o»oers end operalort of
haiurdoui waste treatment,
storage a»d disposal
facilities.
Alternative oil! involve treatment/
diapoaal of hatardoun waste.
RCRA generator regutat lone apply.
Alternative will require use of e
RCRA-permitted facility in compliance
with current RCRA regulations.
X I
I I
001 Haiardous- Material*
transport Rules (»9 OR
Silichopler C) and RCRA -
Subtitle C Stondard* for
Iransiiortere Ml aR 161
Clean Water Act (C»A)
40 CTR Part* 121, 175
end Subpstl N National
Pollutant Discharge
elimination System
(NPUCS)
»o CTR «o) crriuF..t
Guidelines and Standards
Pretrsetnenl Standard*
feOrtal Water Qmlitv
(PA Crounl N.iter Protection
Strategy
tional Safety e
llnllh Act (II'.IIA)
Part 1910 «r,IM Stwidard*)
lo«lij **«l| Imwever, POI
level* are not el concentration*
triggering diepoeel requirement*.
Alternative will re«|>ure inlrrottvrrtMt-tilnl
review of project il project will i«ie
federal fund*.
Alternative will not reault in compliance
with *tmnd*rd*
Alternative will not reault in
compliance with criteria.
I I
XXXI
I X II
X 1
I X
X X
XX X X
X X XI
-------
lAIHC »-18
AJ.TT. RNAiiviS' ccMFViAMct HUH Ami emu IAKS AJO HCU.AIICNS
te« or Regulation
Cleen Air Act (CM)
Implementation
Comment
of thle ellemetlve may
1 7 1 »A 4D *C
X I
Alt<
4C
X
»rnel ive
5A
1
JC
X
5C
X
5C
X
6
X
7
X
8
X
9
X
reeult in the cannon of pollutente
into the elr though bcloo regulatory
liaite. A Peroit ehould not be requited,
bo I neceseery technicel requirements
will be vet.
On-eite eicevation My result in the
ahort-tero eateeion of parliculetee.
On-lit* pereonnel "ill be •dequttely
protected. Ifforle to •ttlgete releeee
olll be «»de.
Sere Drinking N*ter Act, Uxler-
ground Injection Control (UlC)
rrogrm Criteria end Stenderd*
(40 OH Pert 14«)
Underground Injection Hell Ptoit
Nerine Protection, Research end
Sonctueries Act («0 (TR Pert
ZZO-II9) Oceen Owping
Rtquire*rnte
Roilioactive Meste Rule — High
lo» level
National Regieter of Hiatoric
Pieces
Wild end Scenic Rivere Act
(40 OH Pert «.WZ)
endangered Speciee Act
Protection of threatened or
tndengerrd Specie! end (heir
Habitate (SO CM Pert 407)
Fiah end Wildlife Act
Coneervatlon of Wildlife
Reeourcel
Coestel /one Hanageaent Act
(I) CTR 920-926)
Uuforai Relocation Aaaiatance
end Real Propertgr Acquisition
Policiee Act of 19» (40 (TR «)
Ciecutive Ordere for flood Plain
(IOII90B)
(•rcutive nrdere for Metlande
(till 1990)
National (nvironaental Policy
Ac! (NCPA)
Arcl*iti:ul(H|ici*l H*M| Mintoric
Prruervation Act of 1974
Implementation of the elternattvee does
not include the dumping of any 'aterlala
In the ocean or incmeretion at eee.
dialing racorde indicate that the eite
doee not contein high- or loo-level
radioactive neete.
lapleaentetion of the •Iternatlvee Mill
not effect eilee on the regieler.
Rivere on the national inventory xlll not
be effected by elternativea.
l*pleo>entetlon of the elternetivee oill
not effect threatened or endangered
epeciea end their habitat.
l*plea>entetlon of the elternetlvee fill
not affect areae of uaportent "lldlife
reaourcee.
lapleaentatlon of the elternetlvee oil!
not effect • coastal »ne.
lapleaantation of the elternetlvee should
not require relocetion of residences or
businesses or acquiaition of property.
(•pleajentellon of thie elternatlva "111
not occur in • flood plain.
lapleewntetlon of Ihie elternetlve >ay
effect • oetlend.
CERCIA ectione ere defied fro* NtPA
requireoente.
Alternativee ohiiuld not affect llnraa
reaoutcee.
X XX
X X
X X
X X
-------
AtrtwAtivcs'
unit «.ia
wmi APPIICABIC tons HO HCUAIICHS
IB* or flrgulation
SUH
Comment
«
*
I*?
*rn""
*rn""jc
"X—IE—X—X
Hjnanrment Program - Indiana
environmental H;monement Board
Article * ()20-lAT-»)
Rules I, }, «. «»!•
Generation Idenlificel ion
Standard* for Generators
Rule ) Slendnrd* Applicable
Rule 6 Stnrulard!! Applicable
In Owirri unit fl|nrralora of
Ma/artloui Voile '»cililn»
Ihile 7 riutiiirr/l'iiTilcloiiiirn
Rule 8-9 Iliurdous »••!•
fKllily Construction «nd
Operiting Permit
lndi«n« Will* lre*t>rnt
'Kilitie* RequUtiofl -
title ))0 - Article ).l
f«cilit)> Construction
Article ) Industriel W«itt-
iicter Pretreit'ent «nd NFOCS
Proqre** - Rulee 1-10
Rulee II-IJ Pretre«t«ent
Stindirdi
Inditne Wtter Omlity Standard*
Str Pollution Control Board
J)0 |<«C article I-I, Section C
Miter Quality Standard
Indiana Air Pollution Control
«.nc»v.
Zoning
Ihia elternative "ill involve off-'ite
diipoaal of htrerdoua «a*le *nd
generator reguletiona apply.
Implementation of thia allrrnitive
mcludei the off-tile traneport of
haiardoue awteriale. Ina trenaport of
tneae •ateriala will be in romplitmca
vith tneaa ruin, including u» of
properly conatructed and mrkeil
traneport vehiclee, uae of liccoueJ
tranaporttra, and me of ha»rdoua
•mate Banifeiita.
Ihia altertiative will be ci*»wintr«it with
current etate regulaliona alllauqli t»
periit vill be required.
Irtle alternative will require the me of
• etate-peraitted facility in co^>liance
•ilh current atata regulation*.
thte alternative vill require
conatruction of • neat* treatment
facility and Kill be conaietent with the
technical requirement of Article )•!•
Impleeientation of alternative will not
result in an on-*lt« point source
diechsrge. An NPOCS peralt will not be
required.
Not applicable. Implementation of
alternative* will not result in discharge
of • waste stream to e publicly-o»ned
treatment work* (PON).
Implementation of altcrnativee will
not result in noncompllance with Indians
Water Quality Standarda.
Alternatives will be consistent with
the technical requirement of current
Indian* regulation.
Alternative* ny require no toning
chsnge •
I 1
1 I
-------
TABLE 9
COMPARISON OF CONCENTRATIONS OF INORGANICS IN SUBSURFACE MATERIAL
AT NIDCO I WITH CONCENTRATIONS IN LISTED HAZARDOUS WASTES (FROM BOAT
BACKGROUND DOCUMENTS FDR THE FIRST THIRD HASTES UNDER LAND BAN)
CONSTITUENT CONCENTRATIONS (mg/kg)
Source Arsenic Chrcnriun Lead Cadniun
K101 590-1950
K102 3060-8320
K061 1730
K046
K048 O.W-3435
K049 28.9-1400
K050 11-1600
K051 0.1-6790
K052
Midco II ND-1430 ND-1960
On-Site Soils
20300
967
0.05-1250
21.95-3900
11-5800
2^5-2810
/
44
0.25-2480
ND-26
-------
o
(V
rrj
HMH ii ii
CffCCMYtNtSS CVAI.IMMON or
pRnircilvtNiss ir mn«N HAL in AND
Minn i IIIIH
rimircMvrNrss iir IIIMAN II.AUII AND tNvinnmcNf
iIMP. HIM
icniriinN nr innici'r. miniiIT. OR VH.IK
Don not rritiir* polrnlinl pirfilir licnllli ri'ik
nn'iiiclnlrd with cnnlnminnlril mil In ll c«i:imili-i|
nnj e«poied or grnmd wnter if inqriitM. Wnnld
nol comply with chrmicsl noil Incot in"-'-prcif ir
requirement ft •» well mi criteria, advinorie* ntirt
quIdance.
hirnllh rink ewiatn fnr mqrst ion or dermal
tittiiiirpl inn til i-trnvnlirtl finiln MIM| IJIIM»K| wtiter
contaminants imd fnr dermal •ttflorptioo of Hiirfnce
outer. Incrrnnrd llfctme cincpr risk to future
no-«itr rriiilnils (l.< • in'') IB un*cr«pt»l>le.
future opnnurc to rcsidiul contanlnwit* csnnot b
prevented.
loucltr, Hnhlllty. or volme of cnntoninwitn in
nniI O>H| iiromid enter era rat per«nnffill)r or
«iijnificant||p reduced.
f«l>(lnq rink* rauld be reiliiced for on-oitr nnl I
•nd qrouid oiler indention nnd tler*»l *h*nrpt ion.
thi* require* aucce*sful eiiforceiirnt of deed
restrictions «nd ••intencnce of the site, fmcinq,
•nd erosion protection. Potent!•! for
'conlMinsted ground ixter deqrcdstion Mould he
• lessened by inhibiting, curfnce "olslute
infiMrnt inn (snd thin, cnntnrt "llh polrnlinl
Rinks In Ihr worker* and thr cnmmmily during
remedial action rnn he adnpntely controlled liy
restrict mq accrsn In nili* to aiillmri/rd pernnnnrl
only, and conduct n»q Mctum with iNlrtpvitc Itrallli
precaut tona.
rin*l protection fro* eipnsiirt lo on-mle
contcomitian is •chieved upon ctMplelion of
construction, •ppro>iB*t»ly I ireir cfter
mi tut ion of construction.
c»p
Clecnup cction level* (CAt«) for mil end ground
•iiler "ill not be «wt »i sail reo*in« ulthout
treitiient «nd ground outer th«t h«» aigrited off
• lie will not be treated. Continued potential for
ground viler rVqrxMIon eilsts due to Icteril
qrnind ciler •iqrotion. Surfcce wster
cnritMinont* my be worsened by rontlnusl
dinrhnrqe nf rnnlminsteil qrtiund water. Deed
restrict loftn nnd site •nintennnce ure provided.
Nprd for rcplnrr«rnl will be bused on site
•ninlriinrice uvrr ti»e. Terformincr of properly
inntnlled •iilti-lniered cup !• qmrrslly qnnd for
firnt 70 ypfira nf prrvlre. Inteqrily of synthetic
linrr aftrr Ihin line brru«H>n u>icerl*in nnd ultould
be investiqnted requlsrfr. Punctures of the liner
by dcrp rooted plsnls snd burrowing •niacls wi||
•ffect the performnce of the c*p. If renedid
•ction fails, risk is stellar to no-setlo"
•Iternstive. Ihc cost for remedying fsllure would
be siailsr to the cost of origins! lostsi 1st Inn If
it is delected before "ore ground water Hove* off
site and if the area needing repair could be
located. If not, cost to reatdy will involve, sa
a •iniano, a ground water option to reoove the
escaping contaminants. Contamination nay nova
vertically through to the neit aquifer. Ihla
aquifer has very little yield, and la not uaed for
drinking water purposes. Monitoring of the
confining layer should detect Movement. A ground
water eitractlon system could be employed If
warranted by snmpling. Costa would be similar to
qrnixd waler options. Without qrnind water unr
rrnlrn lion-i, the rrmainino rink nl.tlii- Bile aflrr
remcdinlion completion is f.S > 10" . "Uh
enforrrmrnt of groivid water me restriction!!, all
risks wnuld be reduced brlow acceptable levels.
Reduce* nobility of contaminant* In Mil but does
not significantly or permanently reduce toticity
or volume or reduce the mobility of contaminants
that ara already In tha ground water.
-------
UIIU 4-Z
mnco II
effectiveness evmiMitM nr
PHI) ICC 11VI Nl SS Of IIIHAN II AUM AM) tNVlnUNMTNt
SIIIIHI II RM
rimitciivtNt'.s or IHWAN ICW.IM *ND CNVIIKWCNI
low HUM
HDUCIIOH or IOXICIIT. Honunr. OR YOUK
Alternative I
Safety concern during Instsllation related to
e>rnvatlon activities. *l««n to workers and
rnmainity during remediel sction ciin he adequately
rontrollr'l h)r restricting errenn In the.Bite lo
oiithnrired personnel only, IKK) cnndoct log nr.t ion
• ilh adequate health and safely precautions.
Protection n'|ninst principle threat can be
achieved u|>o*i completion of cnnnt rurlioti,
appro»imotely I lo I years.
Clenni^i cctinn level* (CAls) for coll snd ground
wntrr mil nnt.be met become no treatment In
provided for either. eliminates direct contict
e»|Kifliire to rnnlnmlnimts. Cnnlominnlloo any move
vert imll|p lo »e«l aquifer, this oqmfer hnn very
little yield. mod is not .used for drinking ester
piirnnwa. Hooiltirinr| of the cnnfininq layer
•hnutil detect-*nve»c
-------
MMU «-2
MI urn it
CrrCCIIVINCSS tVAlUAIION QT At It UN AM VIS
pnoitCMvTNtss or IHMAN
__ aiciRi it RH
AND
iwiirr.iivrwss nr HIHAN ICAUM AND CNVIROMINI
IONC ICHM
(coucnoN or itmciit. Hnoiinr. on VOLIIC
Altemnt i ve 4C
Protection will be achieved by interception of
ground water, capping, deed restriction, ond site
maintenance. Approval for Ihi* option nlioiild tiot
unduly alow action down as contaminants Hill bo
removed to drinking water quality e»cept salinity
before injection. Construct ton of remedial action
should lake f yeara. Risk* to worker* and
community during remedial action con tit orieqintely
controlled by restricting access to alte to
authonted peraonnel only and conducting action
with adequate health and aafety precaution*.
Cleanup action levela (CAla) For aoll Mill not he
met 9* aoll remains without treatment. Ihe ground
enter that ha* migrated off alte "ill be removed
•here CAla are exceeded and ground water CAl* on
aite would be met. the level of acetone being
Injected Into the deep Hell nay exceed the CM..
No MCI or MUG presently ewisle for acetone. A
cap and ncceaa realrictlon will prevent aoll
Ingeatlon and dermal absorption. Potential for
failure of technical componenta ta Increased due
to further compleiity of treatment processea and
will require regular operation, maintenance, and
replacement. If falls, risks at site are aiaillar
to no-action. If water leavee deep aquifer, since
Una la not a drinking water aquifer, the
Increased salinity should not pose a problem.
After reoediatlon la completed, if deed
restrictions and nite siamtensnce are perforated,
all riaka are reduced below acceptable levela.
Significantly and permanently reduces mobility of
contamlnonta in the soil but does not reduce
tomcity or volune of aosie contaminant* in soil.
Significantly and permanently reduce* mobility and
loudly of contaminant* In ground water but doea
not reduce volute.
Some contaminant* In ground water arc tranaferred
to carbon cantatera and metal* (ludge* which are
disposed of off alte. Does not significantl> or
permanently reduce tonlclty or mobility of theae
reaiduala.
Altrrnnlive »t
Protection against principle threat will be
achieved by interception of ground water, cspning,
deed restriction and aite maintenance. Approval
for the evaporator system should be readily
obtainable aa this is conventional technology.
Construction of remedial action should take I to 1
year*. Niak to worker* and community during
remedial action can be adeqmtely controlled by
restricting access to aite and conducting action
with adequate health and aafety precautions.
Cleanup action levela (CAla) for Mil will not be
met as soil remains without treatment. Ihe ground
water that haa migrated off alte will be removed
where CM.* are enceeded>«nd ground water C*l* on
site would be met. A cap and access restriction
will prevent soil Ingest Ion and dermal absorption.
technical componenta of action should not fall
with adequate operation and maintenance. After
remediation is completed, If deed restrictions and
aite maintenance are performed, all risk* sre
reduced below acceptable level*.
Significantly and permanently reduce* mobility of
contaminant* In aoll but doe* not reduce toncity
or volume of some contaminant* in will.
Significantly and permanently reduce* mobility,
tonlclty and volume of contaminant* in ground
«ater.
Some contaminant* In ground water are transferred
to *alt cryatal* which sre disposed of off site.
Does not iignlficantly or permanently reduce
toiiclty or mobility of thene residusls.
Alternative i*
Safety ccmcerna during the remedial action are
related to the eicavation of the m.ilerial. Rink
to Ihe worker* and the community cnn he adeqinlely
controlled by restricting access In llw site and
conducting action with adequate health nnd aafrty
precaution*.
Cleanit) action level* for soil* above ground water
level would be met. CAla for sol la below ground
water msy not be met I however, risk calculation*
are based on ingest ion of soil, and theae
additional sol Ida would be below the water table
and unavailable for Ingeatlon. Attenuation
results in a dissipation of contaminant*, although
It will be mnny yenra before ground water cleanup
net inn levels will be allnined for all compounds.
future opnnure tn residuala la minimi fed, became
material removed from site. Remedial alternative
trsnnfers the prnblems to the landfill. Without
ground water line restrictions, the remaining risk
at Ihe aile after remediation completion is 1.6 n
I0~*. With enforrcmrnt nf groivtd woter ine
restrirtions, all risks would be reduced below
acceptable levela.
Reduce* volume of contaminant* In soil by removing
It from aite but tranafera the problem to the
landfill alte. Ooea not reduce volimw, mobility
or toilcity of contaminanta in ground water.
-------
IAIIU /.-7
HUH ii II
tnr.ciivt.Nr.55 IVAIIJAIION or
rnnrrcllvf Nf.v; i» MIHAN IIAIUI AND fNvimnri HI
Vllllll HIM
mininivtNT',ri ir IIWAN irxim mo tuvinrwum
UINC. IC.IIM
irDIicnnn or inmcnt. Hnngiir. nn vmiti.
Altemnlive
Safely concerns during Ihf* remrdinl net ion are
related lo Ihf e»ra»*tion of the material. Wink
lo the workers nod the rommitiily rmi HP adequately
controlled by restricting srcess lo the sile,
conducting art ion .with adequate henllh nntl safely
precautions, and providing adequate emissions
control. It "ill tie neeessnry to perform
trealahility atudies to adrqunlely demunslrnte
lhal the anlidified unit run cnnform to procedures
similar to delisting. Hue to e«lensive technical
requiremente/eubmittals (including n trial hum)
aa well RH the hnrVIni) nt M» M, Irmrriinllnn of tlu-
•Oil'* may not begin fnr 1^1 lo J yenrs. Completion
of construct inn Rhniild !>* I'M Ihnn I yenr. the
•ctull noil renedlnt infi ntmulil he Irns Ihnn I
rirnnup iictinn Irvel* for nnila ibove ground water
level wnuld br met. CALs for voila helot* ground
oaler lay not be Bet; hnoever, rink calculations
Mre bnned on Ingrntinn nf anil, and thene
•ddilionnl aolida muld be belomg of contnminatrd material.
Risk to worker* and rnmmimty during rrmrdial
action can be adequately controlled liy restrictlnii
access and conducting action* with adequate healtli
and safety precaution*. It will be necessary to
perform treatablllty *tudles to adequately
demon*lr*te that the solidified waste can cnnform
to procedure* timilar to RtM delialing. this mny
delay initiation of construction, tcaipletinn of
construction atw>uld be I year.
Cleanup action levels for (oil* tbove ground water
level would be met. CM.*) for Mil* below ground
water may not be met| however, risk calculations
•re bssed on Ingest Ion of aoll, and theav
mihlltional aollHs would be below the water table
nnd unavailable for Ingest Ion. Attenuation
results in • dissipation of contaminant*, lit ho ugh
It will be many year* before ground w*ter cleanup
art Ion level* will be attained for ill compound*.
future evponurr to resldunl* wnuM be.minimal* If
trentnhility studies are properly conducted, there
mhould be • lower likelihood for needing
replacement. If falls, risk* are *|ml|ar to no
mctlon. the cost for remedying fcllure would be
nimilnr to the coat of original Installation.
Wittmut grotxd water use restrictions, the
remaining risk at the aite *fter remediation
completion I* 1.6 1 10" . With enforcement of
qround water use restrictions, ill rlak* would be
reduced below acceptable levela.
Significantly end permanently reduces mobility of
contaminants In soil, but does not reduce
to»lclty, mobility or volume of conteninanta in
ground water.
Alternative
Rec*use no.e>cavation of material occura and all
of the materials ire treated in a hnnd, risk la
minimi ted. *isk to workers and community during
remedial action can be adequately controlled by
restricting access and providing adequnte health
and safety precautions. Completion of
construction should be I to J yeara.
Cleanif> act Ion level* for aolla *bovm ground water
level would be met. CM* for eolls below ground
water may not be met| however, riak calculations
are based on Ingestlon of Mil, and these
•dditional aollds would be below the water table
•nd un*v*ilabte for•ingest Ion. Attenuation
result* In • dissipation of contaminants, although
it will be many year* before ground water cleanup
•ctlnn levels will be attained for *ll compound*.
Alternative ha* been evaluated on pilot scale.
technology ha* not been proven on full acsls
project, therefore nerd for replacement I*
unknown at thl* time, 'hi* option may preclude
some type* of future re*edl*l action due to
creation of solid monnlith. future exposure to
renitfuala would be minimal. If treatablllty
studies nre properly conducted, there should be •
ln**er likelihnnd for needing replacement. Ih*
cnst for remedying failure would be aimilsr to the
cost of origin*! inst*ll*tIon. Mithout ground
wnler use restrict inns, the remaining risk it the
site after remediation completion I* 1.6 i 10"'.
With enforcement of ground water use restrictions,
•II risks would be reduced below acceptable
level*.
Significantly *nd permanently reduce* toncity,
mobility *nd voltne of contaminant* in soil, but
doe* not reduce toilcity, mobility, or volume of
contaminant* In ground water.
-------
i/mi.l t-j
Hinrn 11
cfftctiKNtss CVM.UMKH or /•.rr.RNAiivts
nr in HAN irAim AMI
sumi HUM
nmif.ctivtNtss nr HIHAN if ALTM AND CNVIBDNICNI
iONE HIM
prDUC11ON of toKicur. Honiiitr. OR
Alternative 6
Protection achieved by cnntainmrnl and
solidification. It "ill hr nerennsry to perform
treatsbility studies to demonstrate I hut the
solidified waste rwi conform to procedures aimi|nr
to RCRA delistmg. thin may rielny construction
initiation. Construction of rrmrdisl action oould
lake I to 7 years. Risks to HIT oorkers and the
community during remedial Hrtinn run be adequately
controlled by restricting access In the nile In
authorised personnel only and conducting action
with adeqtaite health and safely precautinna.
Combines the long-term effectiveness of
Allrrnut ivrs } end }C. Clesnup set ion levels for
snil shove ground osier mil be net. CM.a for
soil below ground outer may not be «rl| however,
rink ralciilntinna nre bssed on ingenlion at •oil,
sort this ooulil be unavailable lot inqestion.
Kroind osier clesnup set ion levels would not be
net nn site. Contsninstion nsy "ove vertically to
ne«t sqiiifer. Honltorinq of the confining Ivyer
should detect Movement. A ground oster eitrsction
system could be employed If wsrrsnted by •••pling.
Cnsls ooiild be similar to ground oster options.
Ihe cost for remedying failure "oold be ainllcr to
but higher thsn the cost of origlnsl Installation
If It la detected before more ground oater saves
off site and if the area needing repair could be
located. If not, cost to remedy mil Involve, aa
a minimiK, a ground vster option ta remove the
e*cspmg contaminants. After remediation IB
completed, all risks are reduced beloo acceptable
levela.
Significantly and permanently reduces mobility of
contaminsnta In soil and ground oater.
Alternative 1
Protection »q*mst principle thrent oil! be
srhieved by ground osier interception nnd
solidification. Remedial orI ion nctivitie* for
qround oater may not rnmmrnce for I In 1 yrarn an
a Petition Oe»onslrat ion for the ilrrp orll mini hr
•pproved. It oil I be neressinry to perform
trestsbillty studies to drmnnntrate Hint the
solidified oasle can conform to procedures similar
to RCRA delisting. llus may delsy construction
initistion. ronstruction of Ihe rrmrriial action
oould take apprn»imately ? yeara. Rinka to the
oorkera and the community during remedial action
can be adequately control Ifd by restricting access
to the site to authorised personnel only and
conducting action oitfi adequate health and aafety
precautiona.
Combines the long-term effectiveness of
Alternatives 4A and 5C. Clesnup action level* for
•nil above qround osier oill tie met. CAIV for
nntl beloo qroip^d oster may not be mrlf hnoever,
riik rnlciilntinna are hssed on inqestion of anil,
nnd this onuld be unavailable for ingeatlon.
nrmiMl oster cleanup action levela oould be a>et.
If contaminants leave deep aquifer, coat to remedy
•ill be many tines the coat of original
remediation due to great depth and difficulty of
monitoring. After remediation Is completed, all
rinks are reduced heloo acceptable levela.
Permanently and aignificant|y reduces mobility of
contaminants In aoil and ground oater.
Alternative 8
Protection oil) be achieved by ground oster
interception/treatment and solidification.
Approval for this opt inn ahould not unduly aloo
action dnon ss contammanta oil I he removed to
drinking oater quality ewcept salinity before
injection. It oill be necessary to perfnrm
treatahility studies to demonstrate that the
anlldified osnte can conform to prore'furea nlmllar
to RCRA delintinq. Una mny delay construct inn
initiation. Construction of remedial action onuld
take 2 yeara. Risks to ttie onrkrrs and Ihe
cnnmitiity during remedial action can he'adequntrly
controlled by restricting ncceis In Ihe site tn
aiilhorired perannnrl only nnd cnn«lurt Inq -art inn
olth adeqmte hrntth IOH!
-------
IAI1U 4-Z
Minin it
iffTctivtNtss r.vAiiiAM(n or
rnrmcTlvturss nr MI HAN IIAIMI ANO CNVIRIINHINI
51 KIR I IIIIH
rwiiccnvf NI ss or IIIIIAN IIAIIH tun
IONC HRH
jcouciION or tfjKiciii. Hneiiiir. OR YO.IK
AltrrnntI ve 9
Protection will be achieved by ground wnter
I'll erception/eviiporat ion and nolidificat inn.
Approval for the evnnnrnlor ayAl<*« nhonld he
rpmlily obtmnnble m* Ihia is convrntionnt
technology. It "ill bt npcrsenry In prrfnra
Irrntibilily atuilica to drmonslrntr Hint the
nnlidifird noiitr c*n conform to prncrdurei
•i«ilir to ACRA drli»(lnq. this «ny deliy
construction mil ml ion. Connlruclinn of rr*c
-------
iAin.1 »-» .
Hinin n
inn.trCNiAnn.HT ty»vUAnai or AIIIBHAIIVIS
rtiiiniim
StlORI IIW
tow;
AVAII.Anil.ltT
•JHINISIRAIIVt ff.ASIBIl.HT
Allernntive I
No rrmrdisl net ion is Inkrti with this
alternative! therefore, in construction
difficult it* will be encountered md no
schedules mil be delayed. No
action-specific requirements «re related
to this alternative.
It in evtrrmrly likely Ihnl future
rewrdisl•set ion will be required* It
should l>r no more difficult to Implement
the additional remedial net ion limn at
present. Migration nr exposure pnthweye
cim hr rendily monitnred. Since no
o|ierntion and mninlettnnce Is performed,
long-term tMH difficulties ere not
enlicipsted.
(he no-action option le • readily
available technology.
It I* e»tremely unlikely that this
alternative would receive the necessary
approval* fro* my agency or from the
cum*unity, location sod
chemical-specific requirement* would not
b« net.
Alternative
Short-term technicil feasibility of
alternative n edeqonte. technologies
can be conatructed es needed for
specific cite in • reasonnble lime
prrtod and ahould perforai an eiprcted
during the remedial action if proper
maintenance la performed. Cap
cnnitruction will cosily with
actloM-speeific requirements.
It is probable that future remedial
act inn would be required if contaminants
move off site with the qround water.
Installation of the cop should not
preclude possible future remedial
•rtions. the site cm he readily
monitored and milntatned. 'his
alienist I ve would have In*
implrmrntetio"» operation nnd
••inlenance costs, tonq-ter*
•ninten-ance problems mny arise from
synthetic liner puncture or poor
maintenance.
the cap Installers should be readily
available, these Inatmlltrs would be
trained in the operation of the
necesssry equipment •• well as
appropriate health and safely
precautionary Measure*.
Construction of the csp must provide
long-term minimi rat ion of migration of
liquids through the cap area. It is
unlikely that the community response to
this alternative will be favorable, as
contaminant* may continue to leave the
site. While moat location-specific
requirement* may be met,
chemical-specific requirements will not.
Enforcement of ground water use
restriction* may be very difficult.
Alternative I
Mtapulgtte clay rather than Wyoming
clsy may be needed. It I* anticipated
that an adequate (unply of clay cim be
obtained. It I* e«pected that with
proper bench-scale testing and
installation, technology will be capable
of meeting performance specifications.
Action-specific requirement* will be
met. Cucavation will take place outside
the are* requiring soil remediation.
therefore, construction ahoiild not
trigger cleanup or land disposal
restriction*.
future remedial action such as ground
water e«lfaction and treatment may be
required If It is determined that the
contaminants are mnving through the
confining layer bmeath the aite. while
future remedial actions are not
precluded by the current action, the
construction of • wall and cap could
effect the construction of future
remedial action. Hrmltorinq of the site
fnr effectiveness should be no problem.
Difficulties with long-term MH may
arise from action of the contamlnanta,
especially the sslt and organlca, on the
wall Itaeir.
Containment walla are • demonstrated
technology that sre readily available
and easy to construct. Adequate elsy
should be available, the necesasry
equipment and apecislists ahould be
available and trained In the neceaaery
health and safely technique*, lack of
commercial deep well f*cllltlea may
affect alternative. Presently deep well
facllltlea sre available.
Acceptance of thi* alternative would be
possible. A condition of the acceptance
would include deed and access
restriction*, •• well •• csreful
monitoring, to ensure the waste Is not
moving through to the ne«t aquifer.
Alternative «A
It i* eitpected that the
difficulty with the option will be in
obtaining approval of the Petition
Demonatration. thie could result In
problems with the remedial achedule. It
la expected that all actlon-npecific
requirement* can be achieved.
Assuming thst the extraction cells are
properIgr placed to influence the area,
the deep well la properly constructed
and the Ht. Simon aquifer I* an
appropriate fnrmation, future remedial
action la not anticipsted. Ihia option
iluea not prerlvle future remedial
artinn at the aite. While migration or
exposure pathways close tn the surfsce
mny be readily monitored, monitoring of
the injection tone to determine whether
the mnlerisl Is cnnfinrd, •«• prove
difficult, fmlure tn detect problems
mny result HI contnminiit inn of another
aquifer. No difficulties sre foreseen
in loon-term operation rwirt maintenance.
direction well, deep Hell and cap
installer* with related equipment should
be available.
the need for • Petition Demonstration
may delay Implementation of thia
project, flecsuse the regulation*
governing underground injection wells
are In • aisle of flu«, It is impossible
at thle time to determine agency
response. If en adequate Petition
Demonstration can be prepnred for IMP A,
the alternative should be able to obtain
approval from other agencies. Some
community response may be received in
regard to treatment by injection rather
than conventional techniques. Due to
the large number of CT.RCXA sites in the
area, other ailea may benefit from the
implementation of thi* alternative.
-------
IXIIU «-)
HI 1)1(1 II
9IORI IIW
IUIMICAI
lour. ICRM
JOHINISIRAnvt fCASIBHIIY
Altrrnntlve mil
It t* expected that all locution and
action-specific requirements csn he
achieved. Rifled on past performance,
technolnqies should be cspable of
Providing process efficiencies to remove
001 to 100) solvents to the required
level before deep cell Injection. Air
stripping and granular activated curbon
sre videfy used conventionsl
technologies thst should encounter no
difficulties during construction.
Kith silpqtmte operation and mnintenonce,
lechnolni|ies should continue lo provide
the nerenanry process efficiencies.
Aasuilnq Ihst the extraction veils ere
properly plsced to Influence the »rei,
the deep »ell Is properly constructed
and the Ml. Simon aquifer Is sn
Appropriate formation, future remedial
sction is not anticipated, this option
does not preclinle future remedial sction
st the site. While •Iqrstlon or
e«pnaure pethvays close to the surfsce
«»y be resdily monitored, monitoring of
the Injection tone to determine "tie(her
the material is confined, »sy prove
difficult, fsilure to detect problems
**y result In confining! ion of snother
aquifer. No difficulties sre foreseen
in lonq-term operst inn imd maintennnce.
Regulations sre in • state of fluv.
Additional restrict Ions on hazardous
compounds may require additions!
trestment.
[•trsctlon veil, deep veil, csp and
process unit installers vllh relsled
equment as »ell as all process units
themselves should be avallsble.
Oispossl/recycle facilities for tits
spent carbon sre Halted to four
facilities but should not prevent
lajpleaentatlon.
Approval for the deep "ell Bust be
obtained. Because the requlstions
governing underground injection veils
sre in s state of flun, it is iBpossible
at this Mas to determine agency
response. Susie co«iunlty response «ay
be received In reasrd to trest'ent by
Injection rather than conventional
techniques. Due to the large nixber of
GtRClA site* In the sres, other sites
•ay benefit fro* the l*pleajentation of
thia alternative. Alternative a>ey be
•ore likely to be approved by sqencies,
since no Petition Deaonstretlon is
necessary.
Alternntive AC
It is enpected thst ell locetion and
•ctlon-specific requirements csn be
schieved. Based on psst performance,
technoloqiea should be cspsble of
providtnq process efficiencies to reoove
contaminants to drinking viler qiajlity
etcept aslmity. Air stripping, cysnide
ondstion, avtsls precipitation, and
cerbon adsorption are videly used
conventionel technologic* that should
encounter little difficulty during
construction.
Mith sdequnte operation and •alntensnce,
technologies should cont inue to provide
the necessary process efficiencies.
Ansmiinq thiit the extraction veils sre
properly plsced to Influence the ares,
the deep veil is properly constructed
and the Ml. Sinon aquifer Is an
appropriate formation, future remedial
action is not anticipated. Ihia option
doe* not preclude future remedial action
st the eite. While migration or
tipoaure pathwaya close to the eurfece
•sy be readily monitored, monitoring of
the Injection rone to determine vhether
the material Is confined, may prove
difficult, failure to detect problems
•sy result in contamination of another
aquifer. No difficulties sre foreseen
in tonq-term operst ion and msintenance.
Regulations are In a state of flu«.
Additional rentrietione on hernrdnua
compomvlB may require additional
treatment•
direction well, deep veil, cap end
process unit louts Hers vllh releted
equipment ea veil •• all process units
themselves should be available.
Arieqinte capacity In appropriate
landfill should be available for metals
sludge. Oispossl/recycle fecilitle* for
the spent carbon ere limited to four
facilities but should not prevent
implementation.
Approval for the deep veil must be
obtained. Because the regulstions
governing underground injection veils
sre In a elate of flui, it la impossible
at this time to determine agency
response. Some community response may
be received in regard to treatment by
injection rather than conventional
terhniquee. Due to the large number of
CCOCV.A sites in the area, other site*
may benefit fro* the implementation of
Mil* (Iternstive. Alternative may be
more likely to be approved by sqencies,
•Ince no fat It Ion Demonstration is
neceaeary end the veter is being treeted
to ground Water quality etcept salinity.
-------
IAI1U 0-)
Hinrn n
IVAIUAIIOM OT
ft A
urn
tone irnH
AYAH Aim i tr
JDMINISIRAIlYt
Allrrnnlive tf
II is e«pectrd tlnl ill loot loo end
•ction-specific requirements csn be
schieved. (vapors!inn/crystsi It fat ion
is capohle of providing process
efficiencies to remove the liquid .
portion of the eitrset, si lowing for
disposal of the retraining solids.
rvanorstion by itself may not provide •
cnndenaate tli*t is clean enough for
dischsrqe or shallow aquifer injection.
Disposal of salt crystals may be limited
by the amount of free cyanide present
snd could aiqnificsntly incresse the
cost of this slternstive. tviiporstinn
is • Midelv used conventions! technology
thst should encounter little difficulty
during construction.
Nith •drqinte nperstton snd •ninlrnsnce,
evnporntion/crystollitiit inn should
provide necenssry treatment over the
long (tr«. No difficulties sre foreseen
in lonq-lersj nperst ion snd mmtensnce.
future re*edtsl set ion is not
stiticlnoted. Ihis option does not
preclwle future remedial setion st the
site. Monitoring of the site for
effectiveness should be no prohleo.
t'lrsclion »ell, csp snd process unit
installers utth related equipment as «el
as the evsporstion/crystslliistion
process units the»>elves should be
svaiUMe. Isndfill cspsclljr is
lialted, but should be svailsble.
Distances to off-site landfill
facilities are long.
Cvaporstion of entrscted ground oater
stiould result in • favorable response
fro* other agencies.
Altrrnnlive
(he difficulties related with eicsvstion
concern the control of the •sterisl.
Adequate health snd ssfety provisions
•ust be ixplexented.
No likrly future re«edial set ion is
snticipated. Higration or e>nosure
pnthnays can be adeqimtely *onitored.
Nn sdditionsl'risk of <>posure e>lsts,
should wonitoring -fall, aa •aterial has
been removed fro* the site. Source
control neesures have demonstrated
performance. Site operation and
maintenance are minimal.
U'e available harardous waste landfill
capacity for dlaposal of material Is
limited. Olstanrea to off-site Isndfill
facilities sre. long snd transport could
be expensive.
Alternative msy not be spprovsble since
ground water contamination will not be
remedlsted. enforcement of ground wster
ixie restrictions may be very difficult.
Due to the problema of transportstion,
community response *sy not bs favorable.
Alternative SC
It is eipected that there will be little
difficulty with construction. Procedure
similsr lo DCRA delisting msy delsy
project schedule.
No likely future remedisl actions sre
anticipated, the solidified ssh msy
present problems with future remedial
actions. Ihe continued effectiveness
should be easily monitored.
Maintenance of aite la minimal,
involving inspect ion, mowing, erosion
protection, and access rent net ton.
Adequate vapor e« tract ion and
incineration equipment snd disposal
should be available. Necessary
opersting personnel should bm
available.
It la e«pected that this alternative
•ay not be approved by other agencies
and the coma unity aince ground water
contamination will not be remediated.
Enforcement of ground water use
rrilriclions may be very difficult.
Ir-e construction of an on-aite
it cinerator has been known to cause
public opposition. Due to the
closeness of residences, the
I'.ilementsbllity is unknown.
-------
i«mr ».)
H 11)111 II
InTUhtNIABIillT tvmiMION OT M.ITRNAIIYIS
SIORI itm
rtntjirAi rt
turn; UHH
IQHINlSIRAIIVt rCASinilllT
Alternat ive X
If proper treatahility testa ire
conducted, it it eipected that there
mil be no difficulty with construction.
However, this type of eolidifictlion la
considered innovative for thie Urge mi«
of orqiinic end inorganic wastes.
Procedures similar to RCRA del lit ing any
delay project echedule.
No likely future remedial actionn are
anticipated. Ihe solidified material
moy present problem* with future
remedial notions. Ihe continued
effectiveness of thia remedy Bhnuld be
easily untutored. Maintenance of Bite
la minims!, involving inspection,
•owing, erosion protection) arid accea*
restriction.
Adequate treatment end disposal services
sliould be available. Necessary
equipment snd specialist* should be
svstlsble, *ssuminq the asteri*l Is
resdily solidified und csn confer* to
procedure* similar to RCRA delleting.
It is e»pected thst this slternstive may
not be spproved by other sqencies snd
the community since ground water
contsulnstlon «ill not be revedisled.
(nrorcenent of ground vster use
restrictions niiy be very difficult.
Uhfevortble response »»y slso relste to
llsjlting use of the property by fording
• ce»ented (olid. .
Altrrnntive
Difficulties during construction my be
encountered due to the high ground wvter
tsble snd type of soil, 'his
ulternetive hss been de*onstrsted during
pilot testing) hoxever. the technology
hss not bren proven on • full scsle
project, therefore, the slternstive
should be considered Innovstive. No
eicsvstion of site •sterisl »ould be
necenasry, thus reducing the workers'
eiposure to nslerisl. Isrqe eoounts of
electricity sre reguired to operste this
type of systeo. Air pollution control*
•ust be provided to trest off-gnses.
Cquipoent *iat be custo* fubricsted snd
ssse»bled. Personnel nust be highly
sVilled. Cffecl* on sre** surrounding
the sielt sre uncertain.
It Is not snticipsted thst future
rewedisl action vould be needed, this
option Mould preclude ftooe types of
tededisl action due to the ctention of
the solid omnlith. Ares srnund the
snurce ares should he essily nnd readily
wmilored and imintainrd.
At the present tiaie, the necesssry
equipment and specialists to perfona
large-scale In-situ vttnficstIon sre
not avsilsble. (hi* «sy Incresae the
i»ple
-------
OJ
-Q
TJ
IAIM 4-Jo
HIDCO u
AM<.YSIS SWART
CfftCIIVtHCSS
IHn.r.rCNIAOU.IIT
cost
Alternal ive
Does not reduce potentiel public heslth rink associated mlh
contaminated will If e«cnvsted and eipnsed or ground water
if ingested. Increased lifetime cancer risk lo future
on-nile realdenle (1,4 « 10"') is unacceptable, loitctly,
mobility, or volume of contaminants in noil and ground viler
•re not permanently or aiqnificuntly reduced.
No remedial m-tion la taken Kith thie •Iternative. It la
e«lremely likely that future rmedial action Mill be
required. It ia eitremely unlikely that thie alternative
«nuId receive the neceesery approvals fro* any agency or
fro* the community, location and chemical-specific
requirement a would not be Bet.
total Capital = 0
Annual MM s 0
Preeent Worth s 0
Alternative 2
final protection fro* exposure lo on-aite contamination la
achieved upon completion of cap eonalruction, approximately
I year after Initiation of construction. Clranup action
levela (CAls) for aoll and ground water will not be met aa
•oil remaina without treatment and qroi»id water that haa
migrated off aita "ill not be treated, fonlinued potential
for qround water degradation eiisla due to lateral qround
water migration. Surface water contaminimtn moy be woraened
by continual diacharqe of contaminated ground water.
Performance of properly Inatalled multi-layered cap la
generally good for firat 70 yeara of aervice. Without
ground water uaa reatrictions, the remaining risk at the
aite after remediation completion wnuld be 1.6 * 10"'.
Kith enforcement of ground water use restrictions, all risks
would be reduced below acceptable levela. Reduces mobility
of contaminants in aoll but does not significantly or
permanently reduce loudly or volume or reduce the mobility
of contaminants that ere already In Ihe qround water.
technologies can be constructed aa needed for specific site.
It is probable that future remedial action would be required
if contaminants move off alte with the ground water. The
cap Installers should be readily available. U la unlikely
that the community response to thla alternative will be
favorable, ea contaminants any continue to leave the site.
While moat location-specific requirements may be met,
ctiemlcal-apeclfic requiremente will not. enforcement of
qround water use restrictions may be very difficult.
lotal Capital • 2,Ml.000
Annual MM > 2)1.000
Present North « »,781,000
Alternative )
Safety concern during Installation related to encavatlon
activities. Protection aqainal principle threat can be
achieved upon completion of construction, approximately I to
2 yeara. Cleanup action levela (CM.S) for aoll and ground
water will not be met because no treatment la provided for
them. eliminates direct contact e»posure lo conlamlnanta.
Contamination may move vertically to ne»t aquifer. Ihia
aquifer has very little yield, and ia not used for drinking
water purposes. High salt and orqnnic concent rat lone may
effect permeability of wall. After remediation la
completed, ell rlaks sre reduced below acceptable levels.
Significantly reduces mobility of contaminants In anil and
qround water, but does not reduce lo«icily or volume.
II la e«pected that with proper bench-scale testing end
installation, technology will be capable of meeting
performance specifications. Action-specific requirementa
will be met. Difficultly with long-term (MM may srlee from
action of Ihe contaminants, especially the ealt end
orqanica, on the well Itself. Containment walls sre a
demonstrated technology that sre readily available end easy
to construct. A condition of the acceptance would Include
deed and access restrictions, aa well ss csreful monitoring
to ensure Ihe wasle la nol movinq through to the neat
aquifer.
total Cspltsl a J,8)2,000
Annual UN a 212,000
Preaent Worth » 7,978.000
Alternative »A
Remedial act inn activitlea will nnl commence for I to 2
yeara, as a Petition Oemonnlralion for deep well must be
approved by tPA. Construction of remedial action should
take 2 yeare. Cleanup action levels (C*ls) for anil will
not be met ss soil remains without treatment. Ihe qround
water that haa migrated off aite will be removed where C/K.S
sre exceeded and qround water CW.S on site wnuld be met.
After remediation ia completed, if deed rent net Ions and
aite maintenance are performed, all risks are reduced below
acceptable levela. Significantly and permanently reduces
Ihe mobility of cnntammnnte in the null but oViea not reduce
tONicity or volume of anme cnnlnmimmta in aoll.
Siqnifleantly and permanently reduces mobility of
contaminants in qround water.
It is e>perlrd that the hlqqrst difficulty with Ihe option
will be in obtaining approval of the Petition Demonstration.
f si I HI'e to detect problems msy result In contamination of .
another aquifer, tulraction well, deep.well and csp
installers with related equipment should be available.
fleraine Ihe regulations govern inn underground Injection
wells are in s slate of flux, it ia impossible at thie time
to determine agency response. Due to the Urge number of
CIRCIA sites in the area, other aites may benefit from the
implementation of thia alternative.
total Capital « a,110,OKI
Annual MH * XII,000
Preaent Worth r 6,884,000
-------
Mint 4-2(1
HIDCn II
DCtAllCD ANftTSIS StftMHT
IfllCMVlNr.r.S
cost
Alternative 40
Remedial ict ion activities mny not commence for at lensl I
year, as approval for Ihis option mirit be obtained.
Construction of rirmedisl net inn fibould tske ? years.
Cleanup ict ion levels (C*i) for soil oil I not be net as
noil remains without treatment, the ground Kilter that him
migrated off (lie mil be removed wlwre CAts tie eieeedrd
Hnd ground water CAta on site Mould be net- After
remediation I* completed, if deed restrictions and site
maintenance are performed, ill rinks ere reduced below
acceptable levels. Siqnlficantly and permnnenlly reduce*
the mobility of contaminate in the KOI I but does not reduce
loudly or volioe of Borne contsminnnle In Mil.
Significantly and permanent ly reduces nobility and tomcity
of cnnleminente In ground outer but doe* not reduce vnlim»e.
fiome contsminnnta in ground water are transferred to emrbon
canisters xfiich are disposed of off site, ftoes nut
significantly or permanently reduce toiicily or unbllity of
these residuals.
It is e«pected Ibnt all location and set ton-specific
requirements can be achieved. Mifh adeqmte operation and
•ointennnce, tectmologlea should continue to provide the
necessary process efficiencies, ftilure to detect problem
•sy result In contsBlnstion of another aquifer, t"tractIon
veil, deep veil, cap and process unit Installers Kith
related equipment as well as all process unit* theaselvea
should be available. Disposal/recycle facilities for the
spent carbon are Halted. Because the regulations governing
indergrotnd injection Bells are In • atata of flii'i it la
i*rmss!b.le at this li"e to deteralna agency response.
Alternntive •"» be «ore likely to be approved by agencies,
since no Pet It Ion Oestonat rat ion la necessary*
total Capital » J,8J«.000
Annual OAH » «7),000
Present North .10.IJ),000
Alternative 4C
Approval for this option should not unduly slow set ion down
ss cnntsninants "ill be removed to drinking miter quality
eveept sslinity before injection. Construction of rewedinl
set ion should take J yesrs. Cleanup action levela (CAla)
for soil will not be "el ss soil remins Mlthout trenl«ent.
the ground wster that hss aiigrated off aite will be rrnoved
where CAl* are oceeded snd ground woter CAla on site would
be >et. the level of acetone being injected into the deep
well will eiceed the Ml. No MO. or HCIC presently e>lat»
for acetone. After renrdmlion is completed, if deed
restrictions and aite •aintenence are perfor*ed, all rlaka
are reduced beliw acceptable levela. significantly and
peraanently reduces the mobility of contavmnnts in soil but
doet not reduce toiieity or voli«« of snoe cnntMinants in
nnil. Significantly and permanently reduces anhllity ami
ttivicity of conlaiiiniinta in ground wnler but dor* not
volume. Some contamiiniints in groind wilier are transferred
to carbon canisters and a*tala sludges which are disposed of
off aite. Does not aignificantly or permanently reduce
toiteity or mobility of these reaiduals.
It is e'pected thnt all location and actlon-npeclf1C '
requirements can be achieved. With adequate operstion and
maintenance, technologies should continue to provide the
necessary process efficiencies, failure to detect problems
may result In contamination of another aquifer. Cvtractlon
well, deep well, cap and process unit Installers with
related equipment as veil as all process unita themselves
should be available. Adequate capacity In appropriate
landfill should be available for metals sludge.
Disposal/recycle facilities for the spent carbon are
limited. Because the regulation* governing underground
injection wells are In a state of IIu», it la Impossible it
thia time to determine agency response. Alternative may be
more likely to be approved by agencies, alnce no Petition
Demonstration la necessary and the water I* being treated to
>|roi«wl wntrr qunlily e«cept salinity.
total Capital > 4,777,000
Annual 0>H . 7)),000
Present Worth .11,119,000
-------
Mini «.;n
Him it ii
DC UUCP AN*j.Y5IS 5UWART
iHnr.HtNiAiin.iiT
cost
Mlernnl ive
Approval for the evaporator system should lie readily
ntilamahle as thia is conventional technology. Cnnslruct Ion
of remedial action ahould tnke I lo 7 years. Clennup nrllon
levels (CAls) for "oil mil not be "rl as noil fr-nmi
• ithoul treatment. Ihe ground water that hns miqrated off
• lie 'ill he removed where CAl» lire e«ceert>d end ground
•Miter CAla on nile Mould he met. After remediation Is
completed, if deed restrictions and «ile maintenance *re
performed, all risk! ere reduced helow acceptable level*.
Siooif icant ly and permanently reduce* the mobility of
contaninante in the "oil but doe* not reduce tomcity or
volioe of me cnntiMinint* In noil. Significant ly *nd
permanently reduce* nobility und toilctty of conlamlnenle In
ground rater but doe* not reduce volume. Some contaminant*
in ground water ere transferred lo **lt crystal* which ere
difipo*e4 of off tile. Doe* not significantly or permanently
reduce toncity or nobility of these reairiuala.
It io e«prcted that ill locution imd *cl Ion-specific
requirements CHn he achieved.. With odpqi»iU operctloii *nd
•tnintennnce, evnnornt ion/cry«t*l 11 rnt ion should provide
nrcrsnnry trrsl'cnt over Ihe Inng trr». Cv«por*lion by
itnelf my not provide • conden**te that Is clem enough for
diachcrqe or shsllew tquifer Injection. C»tr*ctlon mil,
c*p and process unit Instcllers vlth related equipment.*s
•ell as the evspor*tlon/cry*t*llli*tIon process unit*
thrvselves *hould be *v*ll*ble. landfill cspiclty I*
limited, but should be *y*ll*ble. Oiatcnce* to off-ill*
lundfill facilltie* *re long. Olaponal of *alt cryctal* Mr
be limited by the mmount of free cysnide present and could
•lgnlflc*ntly Increase the cost of Ihe altemstlve.
evaporation of e»tr*cted around miter should remit In •
favorable response from other agencies.
total Capital : J,976,000.
Annual 04H = 1.044,010
Present Worth =17,800,000
Alternative
fxfety concern* during Ihe remedial action are related to
the encavatlon of the material. Cleanup action level* for
Roil* above ground rater level would he met. CM.* for soils
brio" ground rater may not be met) however, risk
calculation* arc b*sed on ingest ion of Mil, *nd these
additional mllds would he belo* Ihe rater table and
unavailable for ingeation. Attenuation result* In •
dissipstlon of contaminants, although It fill be many year*
before ground rater cleanup action levels "III be attained
for all compound*. Without ground viler use restrictions,
the remaining risk.at the (lie after remediation completion
would be 1.6 * 10*'. With enforcement of ground rater use
restriction*, all risks would be reduced below acceptable
level*. Reduce* volume of contaminants in soil by removing
it from lite but transfer* the problem |o the landfill cite.
Doe* not reduce volume, mobility or tonclty of cnnlnminanl*
in ground water.
Ihe difficulties related with e«e*vatlon concern the control
of Ihe wsterlal. Ihe available harardoua waste landfill
capacity for*ttlspo**l of material Is limited. Diatancea to
off-site landfill facilities are long •ml transport would be
expensive. Alternative My not be opprovnble since off-*ite
?round witer contomlnstion will not he remediated.
nforcement of ground water use restriction* asy be very
difficult. Due to the problem* of transportation, community
response may not be favorable.
total Capital .18,007.000
Annual 0>H . 7JJ.OOO
Present Worth =70,155,000
Alternative )C
Safety concern* during the remedial action are related to
Ihe e«c*valion of the material. Intensive requirement*
including trial burn plus IDtH backlog could delay the
the start of remediation up to 2 year*. Completion of the
conntructinn ahnuld be If so thrm I year, tnr arliml "oil
mediation should be lesa I lion I yenr. Cleadia? act inn
level* for toll" shove ground water would he met. CAls
for soil* below ground water may not be mrt) hnwever,
risk calculations are bnsed on inqpstion of anil, and these
mklit lonnl sollda would he hcln* the wntrr Inhle ond
unavailable for Inijestion. Atlenunt ion rr^iull* in •
dissipation of contaminant*, alltmiKjh II will be many year*
before ground water cleanup action levels will he all a inert
for all compounda. Without ground water use restrictions,
the remaining risk at Ihe site after remrdintinn ciimplet ion
wntild be 1.6 v 10 . With enforcement of groi'id water use
restrictions, all risks »oiilrt be reduced below acceptnbIr
level*. Significantly and permanently reiluces tnncity a>id
mnliillty of contnminimt* in tint I hill tine" not reilure
tnvicity, mobility, or voliie of contnminnnta >n grnifHl
wnter.
It i* e>pected I bat this alternative amy not be approved
by other agencies and the community since ground water
contamination will not be remediated, enforcement of
ground water restrictions may be very difficult, the
eonntruction of an nn-aite Incinrrntor hnfi been known
lo came public Ofipoaition. Due to the closeness of
residences, the implementahllity I* unknown. Necessary
equipment and dinpoaat services us well aa operating
personnel nhnuld he aval table. Procedures aimllar to
HfftA delintinq mny delay project arhedtile*
total Capital :76,480,000
Annual MM > 2)7,ODO
Present Worth :78,<77,000
-------
IAI1U. 4-711
Minni M
DCIAH.ro WAtYSIS SIHMRT
Altrr'intive V.
im.CIIVf.NrSr,
'mfi'ty concern during inalnllnl 10*1 nnnnrinlrtl with
eirnvnl inn WH| miainq of cnnlnminiil ril mnlrrml. II will he
nt-i ciitiiir y In |M*rfnfm I f ml nhi 111 y iilinlti-1, In i**li'i|tMil«.|y
iliifiiHiat rnte Iliot the nulnlilieil virile rint cnnlnrm to.
procedures similar lo RCRA drltstiiig. Hit* mny delay
initiation of construct inn. Completion nf connlruclion
should be t year. Cleanup action levels for soils above
ground vsler level vould he met. CM.* for (nil* belov
qraund viler may not be Bell bnvever, rink calculations are
limed on mention of loll, and thrne nddllinnal Rollria
•onId be belov the otter Indie imd unavailable for
innrstmn. Attenuation results in • diasipatinn of
rnntuminonto, althniH^i it will he mnny yenrn hrfnrr or**"0'!
wiilt-r clrnnii|i nrlloti Irvrln will hr ntlninr'l lor nil
r«*«IMiiinftit. Willmiil i|rnmMl MM! rr !*'»• rrtil r M-l iitniit ll»«
ri-Mnininf} rititf mi tlie vllff nftrr rr*rdliillnn oiMiplrtlon
Nonld be I.* « 10"*. "ilh enforce*rnt nf ormmd Muter use
rrnlrlet inns, til rinks mulil he rr-lnrnl hrlo" nrrrplnhlr
Irvrls. Siijnificnnll|r im-l perunriitIf reiluiren •nbilily of
rn*itiMiiniint> in solli but ilnen not reilmre tnmcityi •nhility
or vnliv^e of ctmtfiwinnntn in rfrnuiMl vnlrr.
IMIT.rH NIAnllllT
COM
llun ly|tr nf unl nlil irnl ion is nmoiili>reiJ innovbtive for
IhfH Inrrjr •!• nf nrf)nnlc IKM| Innrqmiir wnntes.
l'r«tfi*ilnrfi niwilnr In HTItA «lfl ml inr| my ilrlny prnji-rt
nrlinliile. Ailffiimile trrnt«i**it snil dl:t|tonul services ultould
he ivsilahle. It I* eipecteit thnt this •Iternstive osy not
be Approved by other Sf|encle9 snd the co*wunkty since
off-site ground voter contsolnstion vill not be re>edisted.
enforcement of ground wster use restrictions osy be very
difficult. Uifnvomble response itiiy *lso relste to Halting
u-ir nf the properly by Forcing s c>-«rnled solid.
lotsl Cnpitsl :II,7««.IINI
Anniml (MH : 1)J,O10
Prrneiit North =1 l.mi.im
Becsitse no encsvstion of •nterisl occurs snd si I of the
•nlerisls sre Irested in s hood, ri*h Is »ini»irrrt.
Conpletlon of construction ihnuld hr I to I yrnfs. Clennup
•clion levels for soils shove groind filer level "ould be
•el. CAl» for soils belov ground water **r not he »rt|
hoxever, risk cslculstions sre hsned on ingestion of soil,
snd these sdditionsl solids rauld be belov the vster tuble
•nd unsvsilible for ingestion. Attentuition results In •
dissipslion of contMinimts, slthoiigh It "ill he *sny yenrs
before ground viler clesnup net ion levels oil I be sttsiurd
for si I compounds, technology his not been proven on full
scale project. Without ground vster use restrictions, the
re*ninmg risk st the site nfter roedisllon completion Is
1.6 i 10"*. With enforcement of qrntind viler une
rc^lricl loni, nil rinks voulil he rnlncnl hrtnv ncrrplnhlf*
levels, tiiipuf icnnl ly I>N| nrrmimml |y rnhicei lo«icity,
mobility snd volume of cunlnminmitu in noil, but ilnen imt
reduce Innrity,.nobility, or volixr of conlnminmiln in
ground vster.
Itiis ilternative ho* been demonstrated during ptlot testing)
hnvever, effect* on sress surrounding the melt sre unknovn.
Ibe trrlmnlnqy hn* not been proven on s full scsle project.
At the preArnl timr, the necesssry equipment snd speclslists
to perform Isrge-scsle in-situ vitrificstIon srs not
svmlable. Due to the lirgc nu»ber of unknowns sssoclsted
• lib this Innnvstive trestment, the likelihood of
unfavorable community response is Increased. Alternstive
m.iy not be npprbvohle since off-site ground viler
contamination vlll not be remediated, enforcement of ground
voter use restrictions may be very difficult.
lots! Cspitsl =18,484,000
Annual MH * 112,000
Present North »2t),4)7,000
-------
....it 4-71)
HI III (I II
OtIAIUO ANALYSIS SIMHABT
rmciivi M.vi
Altern.-it i ve 6
It xill be necessary to perform trentnhility studies to
drmnnr.t rale that Ihe solidified woste con conform to
procedures similar to RCRA delislinn,. this uny delay
const ruct 100 initiation. Construction of rrmrdiol action
would I like I to 1 years. Combines Hie long-term
elfect iveness of Alternatives > (mil V.. Clrntini nrt ion
levela for aoil above ground outer "ill be net. CAle fur
soil brio* ground water may not be mel| however, risk
calculations ire based on Ingest ion of soil, and Ihia would
be unavailable for Ingestion. Ground woter cleanup action
level* would not be net on aite. After remediation Is
completed, all risks are reduced heIox Acceptable levela.
Significantly and permanently reduces mobility of
contaminants in soil and ground water.
IHfUHNIAimilY
Snme »i Alternat i ves J and 5C. Hie difficulty of performing
two types of remediation on site at one lime could delay the
const ruct ion schedule. AlthoiH|h ground ester contamination
will not be remedioled to clennup oction levels, all the
risks ore eliminnted by preventing contact with contaminated
anil mid qroiid wnler. Due to the high level of protection,
response will likely be favorable.
COS!
Iota) Capital .14.779,000
Annual (MM < 227,000
Present Worth =16.884,000
Alternative 7
ltrmedial action activities for groi>tl7,X)a,000
Allerniitive 8
Approval for this option should not unduly slow action rinwn
as contaminants will be remnved to drinking water quality
eirept salinity before injection. It will he necessary to
perform trealahility aludies In ilrmwi'il rnti- Ihnt tlw>
•jolidified waste can conform to procedures » nut he met; Imwevvr, ri-ik
calculations sre based on ingest ion of soil, *"d this woiiid
be unavailable for ingest ion. Ground water cleanup action
levels would be met. If water leaves deep nquifer, since
"creased salinity
nn la cnmplelcd.
Is.
ity of.
ity of
nants in groiid
water aie transferred to carbon canisters nnd metals slmlnes
which sre disposed of off site. Does nnt significantly or
permanently reduce loiicity or mobility of these residuals.
Some as Alternatives at and W. the difficulty of
performing Iwn types of remediation nn site sit one time
could delay Ihe construction schedule. Due to the high
level nf protection, renponne will likely be favorable.
lotsl Capital ila.DW.OOO
Annual (MM : 7)J,000
Present North :7I.HO.On0
tins 'is not • drinking water agiiiter, the
should not poae a problem. After remedial
all risks are reduced below arreptahle lev
Significantly and permanently reduces mohi
contaminants in soil and mobility and ton
contaminants in ground'water. Snme conlom
-------
I AH I ft- 71)
HI III I) II
nrtxnto /WH.TSIS MHMARY
Alternative 9
Approval for the evaporator syslew nhoiiM he rendily
nhtninshle OS this 19 conventional Irrtinnlnny. It'will be
necessary to perforn • trentnhilily slu effect ivenrsa of Allrrnnt ivrs at
St. CI runup cclion Irvela lor not! *hnv
be *rl. CAla for Roil below qrntmif imte
Itnwever'! risk ralrulut ions nre bnnrd nn
find Ihia Mould be ufmvailahle for inqenl
clennup action levels would he Met. Afl
completed, all nsV« nre rnlnced hrlow •
ground woter will
•ny not be «•<•! |
nnr9tlon nf noil(
on. Crowxl wnter
r rcwdlnt'inn IB
ceplnhle levels.
Slonif iccntly end permnenl ly reduces •ohllity of
co"li»»ln«nt« in soil mil Mihility, loncity, «nd volixe nf
ronl»*iniintB in groind water. Sme conlnMinnnta in qrotmrf
•otrr ere transferred to Bull crystals which lire dinposrrt of
o'f Bite.. Ones nnt 9tnnif icwil ly or pffrwnnrntty redtire
toicily or "obility of these resirtimls.
IHIIfK NIAIIIlllt
Simr •!> «llrrn;it iven 4C mrl f. the difficulty of
perfnr«tnf| Iwn types of remedial ion on Bile a,t one I line
ronlil ilelny the construction schedule. Due to the high
level of protection, response will likely be favorable.
CUM
total Capital tlJ.BOJ.nnO
Annual MM > 1,044,000
Present Worth =JJ,«07,000
= fitrr«ely pniitive
: I'nsilive ur wiileralely pnnilive
- Very little effect or nn cliin»|e fruo runtiiig rntMlilinn
± Nr>|nlive effect of «oiler»lr nignificimce
5 liln-arty nei|»tlve
-------
TABI£ 13
MHXD n
ESTIMATED COSES IN MILLIONS OF DOLLARS
AND TIME TO IMPLEMENT
ALTERNATIVE PRESENT WORTH CAPITAL ODST
1. No Action
2. Cap
0
4.8
3. Containment 7.9
REMFHTRS THAT DIRECTLY APTIRFRfi
4A. Deep Well
4C. Treat and1
Deep Well
6.9
11.1
4E. Evaporation 12.8
PT^/nryrPS TWVT DTPEfTLY ADnpFSS
5A. Landfill
5C. Incineration
5E. Solidification
5G. Vitrification
17.5
26.0
11.3
20.6
0
2.6
5.8
GROUNDWATER
4.1
4.3
3.0
SOURCE
15.4
23.9
9.1
18.5
ANNUAL O&M
COST
0
0.23
0.23
0.30
0.73
1.0
0.23
0.23
0.23
0.23
YEARS TO
«LWliT AND
CONSTRUCT
0
2
3
4
3
3
2
4
2
3
YEARS TO
COMPLETE
ACTION
0
1
2
30
30
30
2
4
2
3
REMEDIES THAT DIRECTLY ADDRESS SOURCE AND GROUNDWATER
6. Combines 5E
with 3 16.3
14.2
7. Combines 5E
with 4A 14.4 11.6
8. Combines 5E1 18.6
with 4C
11.8
9. Combines 5E
with 4E 21.0 11.2
0.23
0.30
0.73
1.04
4
4
30
30
30
-------
1. Costs based on treatment to drinking water standards prior to
deep well injection. For treatment only to Land Disposal Restriction
Treatment standards; cost estimate is $1,000,000 less.
-------
MIDCO II
1NSUE. OF EFFECTIVENESS WO DUfHENTABILITY
Mill Oontaninants Migrate
Alternative Off-site in Qnound Water?
Will Action Result in
Non-compliance with State
or Federal Standards?
Will Contaminants of
totential Health Concern
Ranain in the Soil or
Ground Water?
Will a Significant
Anount of Off-site
Hazardous Waste
Disposal Occur?
Are Significant
Implementation
FYt)blans Expected?
1. to Action
2. Cap
3. Contaimient
REMEDIES THAT DIRECTLY
4A. Deep Well
4C. Treat and
Deep Well
4E. Evaporation
REMEDIES THAT DIRECTLY
5A. Landfill
5C. Incineration
5E. Solidification
5G. Vitrification
Yes
Yes
to
ADORESS GROUNDWATER
to
to
to
ADORESS SOURCE
Yes
Yes
Yes
Yes
Yes
Yes
to
to
to
to
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
to Yes4
to Yes4
to to5
to1 to6
to2 to
Yes3 8 to
Yes Yes8
to Yes
to Yes
to Yes?
-------
REMEDIES THAT DIRECTLY ARMSS SOURCE AND CROUMMATEU
6. (5E + 3) to to Yes to to
7. (5E + 4A) to to to ft)1 No7
8. (5E + 4C) to ft) ft) ft)2 No
9. (5E + 4E) ND It) ft) Yes 3 8 ^
^Hazardous Vfeste Disposal in Deep Aquifer.
anounts of precipitated metals and spent carbon may be landfilled.
cake contaminated with metals, cyanide and sane organics will be landfilled.
Organic liquids will be incinerated.
^Approval under CERCLA is unlikely.
long term effectiveness of the slurry wall is uncertain.
be problens obtaining approval for deep well injection.
^Procedures are not proven in a full scale project. High water table may
cause difficulties during contruction.
8|_and Disposal testrictions may not allow.
I •
-------
Table 15
- TABLE 4-15
ALTERNATIVE 7
GROUND WATER PUMPING AND DEEP WELL INJECTION WITH IN-SITU VAPOR EXTRACTION
AND SOLIDIFICATION ABOVE GROUND WATER ELEVATION
COST ESTIMATE X
Site/Process Preparation
Soil/Sediment Handling/Treatment
Ground Water Handling/Treatment
Site Restoration
Access Restriction
Monitoring System
CONSTRUCTION SUBTOTAL
Contingencies
CONSTRUCTION TOTAL
Permitting
Services During Construction
Delisting
Engineering
TOTAL CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE
TOTAL PRESENT WORTH
(10% discount rate, 30-year life)
$ 17,596
e. ?n? ni"H> "~
'V ^ ^W£, ,WWW
1,730,400
199,500
33,600
252,500
E0.435.5QG <",
3.374,238 27
170. 0&6 /
4-^300.000 \T
150,000
.1.^300.000 /,
511,730,000 j ',
$ 301,000
917.504,000 ii,
ICC
See Appendix D for detailed cost information
4 Jtf *"<*<' if d ,
-------
Table 16
~~ TABLE 4-16
ALTERNATIVE 8
GROUND WATER PUMPING, GROUND WATER TREATMENT
TO DRINKING WATER QUALITY EXCEPT **
SALINITY, AND DEEP WELL INJECTION WITH IN-SITU VAPOR EXTRACTION
AND SOLIDIFICATION ABOVE GROUND WATER ELEVATION
COST ESTIMATE #
Site/Process Preparation
Soil/Sediment Handling/Treatment
Ground Water Handling
Ground Water Treatment
Site Restoration
Access Restriction ,
Monitoring System
CONSTRUCTION7 SUBTOTAL
Contingencies
CONSTRUCTION TOTAL
Permitting
Services During Construction
Delisting
Engineering
TOTAL CAPITAL COST
ANNUAL OPERATION AND MAINTENANCE
TOTAL PRESENT WORTH
(10% discount rate, 30-year life)
$ 17,596
•0.202,000 tt Y/ / -''-
1,230,400
535,000
199,500
33,600
252,500
.£0,470.596 C, 6 6 ~, *
- .
1,300,0.00 /,
15Q.OOO
4-.330.WO /,
91^.800.000 / /,
$ 733,000
02 lt 76 0,000 / I*,
See Appendix D for detailed cost information
-------
Tab!,
17
TABU 1 (PACK 1 OF 2)
KIDCO II.
GEOOHD XA7ER CLEAHOP ACTIOH LEVELS
Coipound
Detection Cleanup
Liiit * Action Level
(us/1) (uc/1)
Basis
Arsenic
Bariui
Beryllici
Cadiiui
CLroiiui
Copper
Iron
Lead
200
5
5
10
Hercury
Kickel
Selecki
Siher
Thalliui
Tacadiut
lice
Cyanide
fieri chloride
Cbloroethate
Eethylene chloride
Acetoce
1,1-Dichloroetbene
1,1-Dichloroethane
Trats-l,2-dichloroethene
2-Butanone
1,1,1-Trichloroethane
1,2-Dichlorcpropane
Trichloroethece
Benzene
4-Hethyl-2-Pentznote
Tetracbloroethene
Tolueie
Itbylbeniene
lylenes
Phenol
15.1
107
1.0
0.25
T.5
119
40
5
10
10
50
5
1.3
0.7
10
0.4
1.2
2
10
0.3
15,300
50
464
0.25
12.3
1.5
0.43
O.G349
J.49
. 1,470
15S
2.2
10
1.9
12.8
0.000208
O.OC932
70
9.57
24
0.0125
0.0174
0.04
3.C3
0.014
EO.l
12.8
B4.5
5.13
Ground vater background concentration (95! OCL).
Ground later background concentration (95! OCL).
Koncarcinogenic risk froi the site (all tedia) <
Koncarcinogenic risk froi the site (all ledia) <
Ground later background concentration (95! OCL).
1.
Chronic Hater Quality Criteria for the protection cf
freshvater life, sith a dilution factor of 3.57
(froi Hideo II Eeiedial Investigation Heport),
Iciest detected hardness.
Ground later background concentration (951 OCL).
Kaiitui Contaiinant Level.
Ground tater background concentration (95! OCL).
Ground later background concentration (Si! OCL).
Ground later background concentration (95* OCL).
Koncarcinogenic risk froi the site (all ledia) < 1.
Chronic Kater Quality Criteria for the protection of
freshtater life, ilth a dilution factor of 3.57.
Koncarcinogenic risk froi the site (all ledia] < 1.
Roncarcinogenic risk froi the site (all ledia) < 1.
Ground sater background concentration (95! DCL).
Ground vater background concentration (95! OCL).
Ground «ater background concentration (95! OCL).
Ground cater background detection liiit.
Groucd later background concentration (95! DCL).
Koncarcinogenic risk froi the site (all ledia) < 1.
Carcinogenic risk froi the site (all ledia) < 1 E-Gc.
Carcinogenic risk froi the site (all ledia) < 1 i-Oc.
Baxiiut Coctaiinant Level Goal (proposed).
Koncarcinogenic risk froi the site (all tedia) < 1.
Koncarcinogenic risk froi the site (all ledu) < 1.
Carcinogenic risk froi the site (all ledia) < 1 E-0:.
Carcinogenic risk froi the site (all ledia) < 1 E-G5.
Ground «ater background concentration (95! OCL).
Koncarcinogenic risk froi the site (all ledia) < 1.
Carcinogenic risk froi the site (all ledia) < 1 E-G6.
Koncarcinogenic rick frci the site (all icdia) < 1.
Koncarcinogenic rick frci the site (all tedia) < 1.
Koncarcinogenic rick frci the site (all i-iia) < 1.
Koncarcincgetic rick froi the site (a! .• ») < 1.
-------
TABLJ 1 (PiGS 2 OF 2)
Coipoued
Detection
liiit »
(us/1)
Cleanup
Action Level
Basis
6ic(2-chloroetbrl)ether 10
Bis(2-ehloroisopropvl)etber
Cresol 10
Isopborpoe 10
2,<-Diietb7lpbeBol
Benzole Acid
Bis(2-Chloroethoiv)iethase
2,4-Dichloropbenol 3.9
Kapbthalene
2-Hetbvlnaphthalene
Acenaphtbene
4-Kitrophenol
2,4-Dinitrotoluene 10
Dietkvlphthalate 4.9
floorene
4-)litroaniline
Pbenanthrene
Di-n-Butrlpbthalate
Bis(2-ethvlhexTl)phthalate 10
Di-n-Octjlpbtbalate
leptacblor epozide 0.05
0.000198 Carcinogenic risk froi the site (all tedia) < 1 K-06.
10 Ground »ater background detection liiit.
6.41 h'&ncarcinogenic risk froi tbe site (all icdia) < 1.
0.207 Carcinogenic risk froi the site (all ledia) < 1 1-06.
10 Ground later background detection liiit.
58.1 Koncarcinogenic risk froi tbe site (all ledia) < 1.
10 Ground later background detection liiit.
0.163 Koncarcinogenic risk froi the site (all ledia) < 1.
21 Koncarcinogenic risk froi tbe site (all ledia) < 1.
10 Ground vater background detection liiit.
( 10 Ground nater background detection liiit.
50 Ground tater background detection liiit.
0.000213 Carcinogenic risk froi tbe site (all ledia) < 1 E-OS.
1.25 Koncarcinogenic risk froi tbe site (all ledia) < 1.
10 Ground cater background detection liiit.
50 Ground vater background detection liiit.
10 Ground sattr background detection liiit.
9.U Koccarcinogenic risk froi tbe site (all ledia) < 1.
O.OEC6 Carcinogenic risk froi tbe site (all ledia) < 1 K-06.
10 Ground eater background detection liiit.
0.000326 Carcinogenic risk froi tbe site (all tedia) < 1 1-06.
* Practical quantitation liiits as per OS£PA 'Test Ketbods for Evaluating Solid Vaste,' 3rd Edition,
SH-846, HOT. 19E6. Values sbosn are higher than tbe corresponding cleanup action levels.
Therefore, the actual cleanup action level for each of these coipjunds is 'nondetectable.'
OCL: Opper confidence liiit of the average concentration (froi Hideo II Beiedial Investigation).
-------
Table 18
TiBLE 2 (PUCE 1 Of 2)
H1DCO II
SOIL CLEHKOP ICT10H LEVELS
Coipoutd
Detection Cleanup
Liiit * id ion Levels
(og/kg) (ug/kg)
Basis
intiioay
irsenic
Barici
Berylliui
Cadiici
Cbroiiui
Copper
Iron
Lead
Kacgactse
Hercury
Kickel
Seleciui
Siher
Tia
facadiui
Zinc
Cyanide
Betbylene Chloride
icetone
Carbon dieulfide S
Trans-l,2-Dicbloroethene
Cblorofon 0.5
2-Butaoone
1,1,1-Tricbloroethane
1,1,2,2-Tetracbloroetbane 0.3
1,2-Dicbloropropace
Tricblcroethene
1,1,2-Tricbloroetbane
Benzene 2
4-Hetbyl-2-pentanote
!etracbloroetbe&e
Toluene
Cblorobeczece . 2
Etbylbetzene
lylenes
Fbecol
1,4-Dicblorobenzene
1,2-Dicblorobenzene
Cresol 330
2,870
14,000
169,000
2,930
3,580
35,800
48,900
1,310,000
1(6,000
604,000
290
143,000
1,550
M
21,500
50,200
1,060,000
15,100
9.35
5,190
0.153
5
0.1E3
5,900
5E4
0.107
42.2
1.44
2.58
0.962
936
2.17
15,900
1
1,730
6,310
157
58.7
153
66.3
Koncarcinogenic risk froi tbe site (all ledia) < 1.
Surface soil background concentration (95X OCL).
Koncarcinogenic risk froi tbe site (all ledia) < 1.
Honcarcinogenic risk froi tbe site (all'iedia) < I.
Honcarcinojenic risk froi tbe site (all ledia) < 1.
Hoocarcinogenic risk froi tbe site (all ledia) < 1.
Surface soil background concentration (951 OCL).
Surface soil background concentration (95! DCL).
Surface soil background concentration (95* OCL).
Koncarcinoge&ic risk froi tbe site (all ledia) < 1
Surface soil background concentration (95X OCL).
Honcarcioogenic risk froi tbe site (all ledia) < i
Koncarcinogenic risk froi tbe site (all tedia) < 1
Surface soil bacljround concentration (SSI OCL).
Koncarcinogenic risk froi tbe site (all ledu) ( 1.
Koncarcinogenic risk froi tbe site (all tedia) < 1.
Honcarcinogenic risk froi tbe site (all ledia) < 1.
Koncarcinogenic risk froi tbe site (all ledia) < 1.
Surface soil background concentration (951 OCL).
Koncarcinogenic risk froi tbe site (all ledia) < 1.
Koncarcinogenic ritk froi tbe site .(all ledia) < 1.
Surface soil background detection liiit.
Carcinogecic risk froi tbe site (all ledia) < 1 E-CS.
Koncarcinogenic risk froi tbe site (all ledia) < 1.
KoDcarcinogenic risk froi tbe site (all ledia) < 1.
Carcinogenic risk froi tbe site (all tedia) < 1 1-06.
Carcinogenic risk froi tbe site (all ledia) < 1 E-06.
Carcinogenic risk froi tbe site (all tedia) < 1 E-06.
Carcinogenic risk froi tbe site (all tedia) < 1 E-05.
Carcinogenic risk (roi tbe site (all tedia) < 1 E-06.
Xoncarcinogenic risk froi tbe site (all tedia) < 1.
Carcinogenic rick (roi tbe site (all tedia) < 1 E-06.
Koncarcinogenic risk froi tbe site (all itdia) < 1.
Koncarcinogecic risk froi tbe site (all tedia) < 1.
Hoccarcinogenic risk froi tbe site (all ledia) < 1.
Kooctrcinogeeic risk froi the site (all ledia) < 1.
Koncarcinogenic risk froi the site (all ted!-- 1.
Carcinogenic risk (roi the site (all iedi>* I- 06.
Koncarcinogenic risk froi tbe site (all i
Koncarcinogenic risk froi tbe site Ul.
-------
TABU 2 (PAG? 2 OF 2)
Coipound
Detection Cleanup
Liiit * Action Lerels
(ag/kg) (ug/kg)
Basil
Isopborone 3,000
2,4-Diietbrlpbenol . . . 330
2,4-Dicblorophenol 900
1,2,4-Tricblorobenzene 330 36.7
Kapbtbalene 5,110
4-Chloroaniline 356
2-8etbylnaphtbalene 330
Acenapbtbrle:: 330
Acenaphtbene 330
Dibenzofuran 330
Dietbrlpbthalate 330 27.1
fluorece ( 330
K-Kitrosodipbenylaiine 330 269
Pheuatbrece 330 . 131
Aatbracece 330
Di-o-butylpktbalate 1,360
fluoracthene 255
Pyrete 248
Butilbenzjlpbtbalate 943
Benio(a) anthracene 158
Bis(2-etb7lhei7l)phthalate 955
Cbrrsene . 238
Di-D-octylpbtbalate .330 36.4
Benio(b) fluoranthene 241
Beazo(k) fluoranthene 154
Benzo(a) pyrese 137
Indeno(l,2,3-cd) pjrene 103
Dibenz(a,b)anthracene 330
Beczo((,b,i)per7leoe 108
4,4'-DDE 44.8
Chlordane 4,100
PCBs 80 1.62
Carcinogenic risk froi the site (all ledia) < 1 E-OS.
Surface soil background.detection liiit.
Koncarcioogenic risk froi the site (all ledia) < I.
Honcarcinogenic risk froi tbe site (all ledia) < 1.
Koncarcinogenic risk froi tbe site (all icdia) < 1.
Carcinogenic risk froi tbe site (all icdia) < 1 K-06.
Surface soil background detection liiit.
Surface soil background detection liiit.
Surface soil background detection liiit.
Surface soil background detection liiit.
Surface soil background concentration (5'1 OCL).
Surface soil background detection liiit.
Carcinogenic risk froi tbe site (all tediaj < 1 1-06.
Surface soil background concentration (S5* OCL).
Surface soil background detection liiit.
Koncarcinogenic risk froi the site (all ledia) < 1.
Surface soil background concentration (95* OCL).
Surface soil background concentration (951 OCL).
Koncarcinogenic risk froi tbe site (all ledia) < 1.
Surface soil background concentration (95! OCL).
Surface soil background concentration (251 OCL).
Surface soil background concentration (95X OCL).
Surface soil background concentration (95X OCL).
Surface soil background concentration (95! OCL).
Surface soil background concentration (95! OCL).
Surface soil background concentration (95! OCL).
Surface soil background concentration (95! OCL).
Surface soil background detection liiit.
Surface soil background concentration (55! OCL).
Surface soil background concentration (95! OCL).
Surface soil background concentration (95! OCL).
Carcinogenic risk froi the site (all tedia) < 1 I-
06.
» Practical quattitation 1'iiits as per OSEPA 'Test Kethods for Evaluating Solid Ifaste," 3rd Edition,
SH-E46, NOT. 1986. Values shcvn are bigber than tbe corresponding cleanup action levels.
Therefore, tbe actual cleanup action letel for each of tbese coipoasds is "nordetectetle.'
OCL: Upper confidence liiit of the average concentration (Table 14).
-------
TABLE 19
IAND DISPOSAL KESEKECTICN TREATMENT STANDARDS FCR WASTE
CATEGORIES F001, F002, P003, POOS (FRCM 40 CFR 268.41)
CONSTITUENT OBJCENTRATIONS IN EXTRACT
ng/1
Wastewaters Non-wastewaters*
acetone 0.05 0.59
n-butyl alcohol 5.0 5.0
carbon disulfide 1.05 4.81
carbon tetrachloride 0.15 0.96
chlorobenzene 0.15 0.05
cyclohexanone 0.125 0.75
1,2 dichlorobenzene 0.65 0.125
ethyl acetate 0.05 0.75
ethyl benzene 0.05 0.053
ethyl ether 0.05 0.75
isobutanol 5.0 5.0
methanol 0.25 0.75
methylene chloride 0.20 0.96
methyl ethyl ketone 0.05 0.75
methyl isobutyl ketone 0.05 0.33
pyridine 1.12 0.33
tetrachloroethylene 0.079 0.05
toluene 1.12 0.33
1,1,1-trichloroethane 1.05 0.41
1,1,2-trichloro-l,2,2
trifluoroethane 1.05- 0.96
trichloroethylene 0.065 0.091
trichloroflouromethane 0.05 0.96
xylene 0.05 0.15
*A capacity variance is in effect for soil waste and debris until November
1990.
-------
TABLE 20
PROPOSED LAND RESTRICTION TREATMENT STANDARDS
FOR WASTE CATEGORIES FOOT, F008, F009,
(FROM F.R., VOL, 53, NO. 7, P. 1068)
WASTEWATERS:
CONSTITUENT TOTAL COMPOSITION TCLP
(ng/1)
cyanide (total) 12
cyanide (amenable) 1.3
chromium 0.32
lead 0.04
nickel 0.44
NCNWASTEWATERS:
(mg/kg)
cyanides (total) 110
cyanides (amenable) 0.064
cadium 0.066
chromium 5.2
lead 0.51
nickel 0.32
silver 0.072
-------
DRAFT
structural/functional groups ihown in column 1 of Highlight
5. After dividing the BOAT constituent: :nto their
respective structural/functional .groups, the nex: step is to
Compare the concentration of each constituent with the
•esbold cooctatratioo (see column 3 of Highlight Si and
^ select the appropriate concentration level or percent
reduction range. If the concentration of the restncted
constituent is less than the threshold concentration, the
waste should be treated to within the concentration range.
If the waste concentration is above the threshold, the waste
should be treated to reduce the concentration of the waste
to withia the specified percent reduction range. Once the
appropnate treatment range is selected, the third step is to
identify' aad select a specific technology that can achieve the
necessary concentration or percent reduction. Column 5 of
Highlight 5 lists technologies that (based on s-cs—;
performance data) can attain the alternative Tre~ r;l:r.
Variance levels.
During the implementation of the selected treats;:::
technology, periodic analysis using the apprcpr-.at; :;s;j-.c
procedure (i.e.. total waste analysis for oreamcs and TCLF
for inorganics) will be required to ensure that the olter-a;;
treatment levels for the BOAT constituents requiring con:.-:";
are being attained and thus can be land disposed" wits^u;
further treatment.
Because of the variable and uncertain characteristics
associated with unexcavated wastes, from which ocJ*.
sampling data are available, treatment systems generaiK
Highlight 5. ALTERNATE TREATABILTTY VARIANCE LEVELS AND
TECHNOLOGIES FOR STRUCTURAL/FUNCTIONAL GROUPS
Structural
Functional
Grouoa
Concentration
Mange
(ppm>
Threenoid
ConcemYation
(ppm)
Percent
Reduction
Rang*
Technologies tnat achieved
recommended effluent
concentration guidance ••
0.5 - 10
100
90-909
aioloayej TnMgnarn. (jy* Tamo. St^png.
Sohi W^BflaiTQ, TnaHf^mi Ow^jcoon
Cionnt
0.00001 - 0.06
0.5
90-999
Deeraonneaan. Sari W«rvng. Ttwmei PM>UL».II
PCS!
0.1 - 10
100
90-989
Bif*-me)
Th«mneiO«H
TrMffnenc Oeenonneaan. Sal We**tng.
rOCiOM
0 002 - 0.02
0.2
90-999
mejOeirucac
0.5-40
400
90-99
BUcocrt
Sort WM^
USA* Tamo.
NogtnttM
0.5-2
96-904
. Sot W
C.ciics
0.5-20
200
90-999
at-40
400
90-90
0.5-6
120
96-90.9
SoIWi
Nc«ei
0.5-1
96-99J
Sol Wearing
0.006
0.01
90-90
07-22
90-90
Cedmum
96-90.0
Sol Weaning
0.1 -3
300
90-90.0
. Sol Weaning
ry
0.0002 - 0 006
0.08
90-99
TCLP «4« mff b» tat*
-------
- MTTTT) I AND MZDOD U RESPONSIVENESS SLWARY
I. RESPCrcrVENESS SLM1ARY OVERVIEW
In accordance with CTKCLA Section 117, a public comment period was held from
April 20, 1989 to May 19, 1989, to allow interested parties to comment on the
United States Environmental Protection Agency's (U.S. EPA's) Feasibility
Studies (FSs) and Proposed Plans for final remedial actions at the Midco I and
Midco II hazardous waste sites. On April 27, U.S. EPA conducted a public
meeting in which the Proposed Plans were presented, questions answered and
public Garments accepted.
The purpose of this responsiveness summary is to document comments received
during the public comment period, and provide U.S. EPA's responses to these
comments. All comments summarized in this document were considered in EPA's
final decision for remedial action at the Midco I and Midco II sites.
n. BACKGROUND ON COMMUNITY INVOLVEMENT
The Midco I site (as well as another National Priorities List site, Ninth
Avenue Durp) is located in Gary, Indiana. The nearest residential area is in
Hammond, Indiana within one-fourth mile of the site. On December 21, 1976, a
fire at Midco I destroyed thousands of drums of chemicals. Ooranunity concern
about the site intensified in 1981. In March 1981, a 14-year old Hammond boy
suffered leg burns while playing near the site; his parents attributed the
burns to chemicals. In June 1981, a heavy rainfall resulted in flooding in
Hammond and the flow of surface water from the Midco I and Ninth Avenue Durp
areas into Hammond. Several residents complained of chemical odors in flooded
basements and chemical burns from contact with flood waters. These problems
were attributed to run-off from Midco I and Ninth Avenue Dump. In response to
this occurrence, Hammond constructed a dirt dike across Ninth Avenue at the
Cline Avenue overpass. This dike is still in place and is a source of
controversy between Gary and Hammond public officials. The Indiana
Department of Environmental Management sent a letter stating that the dike was
still necessary to prevent contamination from the sites from entering Hammond.
Gary and Hammond public officials and nearby Hammond residents have been
actively involved in promoting remedial actions at Midco I.
The Midco II site is more isolated from residential areas. The nearest
residences are a small cluster of homes located approximately one mile
southeast of the site. In 1977, a fire occurred at the site that destroyed
thousands of drums of chemical wastes.
In 1981, U.S. EPA installed fences around Midco I and Midco II. In 1982,
U.S. EPA conducted a surface removal action at Midco I that included removal
of all containerized wastes and the top one foot of contaminated soil, and
installation of a temporary clay cover. From 1984-1989, U.S. EPA conducted a
removal action at Midco II that included the removal of all containerized
wastes, and excavation and removal of contaminated sub-surface soils in areas
where wastes had been dumped directly onto the ground. On July 8, 1982, a
-------
public meeting was held to discuss the Midco I removal action. Other
oumunity relations activities were also conducted during the removal actions.
U.S. EPA held public meetings to digrams the initiation of the Remedial
Investigation/Feasibility Studies (RI/FSs) on February 21, 1985 for Midco I
and on July 18, 1985 for Midco II. Residential well sampling for the RI/FSs
identified several contaminated wells, but the contamination was not
attributable to the Midco sites. U.S. EPA provided updates to the community
on the status of the studies using fact sheets in November 1987 and December
1988.
Proposed Plans for Midco I and Midco II were combined into one fact sheet and
mailed to over 100 concerned parties. Oral comments were accepted during the
public meeting on April 27, 1989. In addition, written comments were received
during the public comment period from the City of Hammond, the Indiana
Department of Highways, a private citizen in Gary, a slurry wall contractor,
the Midco Steering Committee (which represents the potentially responsible
parties that conducted the RI/FSs), and front Morton-Thiokol, Inc.
. SUfARY OF SIGNIFICANT GGMMEttIS RECEIVED DURING THE PUBLIC CCM4ENT
PERIOD AND U.S. EPA RESPONSES
The comments are organized into the following categories:
A. Comments received during the public meeting, and comments received in
writing fron the City of Hammond, from a slurry wall contractor and frcr. a
private citizen from Gary.
B. Comments received from the Indiana Department of Highways.
C. Comments received from the Midco Steering Committee and from Morton-
Thiokol .
A. SUGARY OF OM1ENI5 RECEIVED DURING THE PUBLIC MEETING, AND CXJ«EtfTS
RECEIVED IN WRITING FflCM THE CITY OF HNfCND, FfiCH A SIURRY WALL
AND FflGK A PRIVATE CITIZEN FROM GARY
COMQfT II:
A number of comments were received concerning the protectiveness of deep well
injection of hazardous wastes. The specific comments included the following:
"In 13 states casings have cracked and leaked in deep well injections."
"Why is it they never address with landfills or deep well injections
earthquakes in the area and what they anticipate is going to happen to all
these nice little hazardous waste dumps we have either under the ground or
on top or wherever they're at."
"I would like to know how many deep wells there are in existence today."
-------
- -3-
"How long have they been in existence?"
"Have there been any problems with any of them?"
"How does the EPA prevent any problems? Are you saying that because they
stepped in there are no more problems or what?"
"Isn't it true that the steel mills stopped disposing of their own waste by
deep well injection many years ago? What are they injecting now?"
"I am requesting that ... (2) the E.P.A. report how the preferred option of
injecting hazardous wastes two thousand (2,000) feet underground will
affect my neighbors' well as my own."
"There is always the possibility that the substance injected into the deep
well will contaminate other aquifers."
"In addition, although these aquifers may not currently be used because of
their depth, or because they contain salt-water there may come a time when
out of necessity they may be needed to supply drinking water to future
generations."
"At a miniinun the contamination in the ground water should be treated
prior to any deep well injections so as to mitigate any adverse
environmental effects that may occur in the future."
"The solution to environmental problems is not to place out of sight or to
dilute, but to correct."
U.S. EPA RESPONSE TO OOMENT tl:
Congress recognized concerns regarding deep well injection of hazardous wastes
and enacted a number of statues to assure that deep well injection is only
conducted at locations and using procedures that will assure long-term
protection of human health and the environment. Deep well injection is
regulated by U.S. EPA under a number of statutes, primarily the Safe Drinking
Water Act (SDWA) (Pub. L. 93-523, as amended; 42 U.S.C. 300f et seq.), and the
Resource Conservation and Recovery Act (RCRA) (Pub. L. 94-580 as amended; 42
U.S.C., 6901 et. seq.). RCRA was modified by the Hazardous and Solid Waste
Amendments (HSWA) of 1984 to restrict land disposal and deep well injection of
hazardous wastes. Congress intended that deep well injection be allowed only
if it is protective of both current sources of drinking water, and any ground
water that could potentially serve as an underground source of drinking water
(USDW). A USDW generally includes any aquifer that contains a sufficient
quantity of ground water to supply a public water system and contains less
than 10(000 mg/1 of total dissolved solids (IDS). Recovery of drinking water
from an aquifer with a TDS greater than 10,000 mg/1 is not considered to be
technically or economically feasible. (See 40 CFR 144.3).
Regulations under the SDWA prohibit (with few exceptions) injection of any
hazardous waste into a USDW. Hazardous wastes can only be injected into
formations that are below the lower-most formation containing, within one-
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quarter mile of the well bore, a USDW. All injection wells must be permitted
by U.S. EPA or an appropriate state agency. Regulations regarding permit
requirements have undergone extensive review and public comment. Permit
conditions prohibit any injection activity that allows the movement into a
USDW of fluid containing any contaminant, if the presence of that contaminant
may cause a violation of any prijnary drinking water regulation (40 CFR 144.12)
or nay otherwise adversely affect the health of persons. Another permit
condition requires permittees to take all reasonable steps to minimize or
correct any adverse ijtpact on the environment resulting from non-compliance
with the permit. (See 40 CFR 144.12).
Underground injection permits include strict construction, corrective action,
operation, abandonment, monitoring, reporting and financial requirements to
assure that the injection well is constructed and operated in a manner that
will meet U.S. EPA requirements and be protective of human health and the
environment.
U.S. EPA's permit review assures that hazardous waste injection wells are only
constructed in locations that are geologically suitable. This includes
consideration of the following factors:
1) the structural geology, stratigraphic geology, the hydrogeology, and
the seismicity of the region (including evaluation of the potential for
earthquakes);
2) an analysis of the local geology and hydrogeology of the well site;
3) a determination that the geology of the area can be confidently
described and that the limits of waste fate and transport can be
accurately predicted through the use of models.
Hazardous waste injection wells must be sited such that:
1) the injection zone has sufficient permeability, porosity, thickness
and area! extent to prevent migration of fluids into a USDW;
2) a confining zone is present above the injection zone which is
laterally continuous and free of transecting, transmissive faults or
fractures over an area sufficient to prevent the movement of fluids
into a USDW, and which contains at least one formation of sufficient
thickness and with lithologic and stress characteristics capable of
preventing vertical propagation of fracture.
In addition, U.S. EPA may require that the owner or operator of a hazardous
waste deep well demonstrate either:
1) that the confining zone is separated from the base of the lowermost
USDW by at least one sequence of permeable and less permeable strata
that will provide an added layer of protection for the USDW in the event
of fluid movement in an unlocated borehole or transmissive fault; or
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2) that within the area of review, the piezometric surface of the fluid
in the injection zone is less than the piezometric surface of the
lowermost USDW; or
3) that there is no USDW present.
(See 40 CFR 146.62).
Further data collection is required during construction of the deep well to
determine or verify the geology and the quality of the construction.
Measurements include resistivity, spontaneous potential, caliper, cement bond,
density, temperature, porosity, gamma ray and fracture finder logs, a pressure
test, a radioactive tracer survey, core samples, and a casing inspection
survey. The injection well must be cased and sealed to prevent any migration
of injection fluid up the borehole. A double casing is required from the
surface to below the lowermost USDW.
The owner or operator must assure that the injection pressure at the wellhead
does not exceed a maximum pressure in the injection zone during injection, and
does not initiate new fractures or propagate existing fractures in the
injection zone. The injection tubing must be surrounded by an annular space,
which is filled with fluid. The injection pressure, flow rate, and volume of
Injected fluids, and the pressure on the annulus, must be continuously
monitored.
U.S. EPA uses three interrelated program requirements to assure compliance
with well operating regulations. Mechanical integrity tests measure the
operating soundness of the wells, including checking for leaks. Operator
reports include information on the waste being injected; the well pressure,
flow rate and volume; and report the degree of permittee compliance with these
permit conditions. Periodic inspections determine the accuracy of operator
self -monitoring and the adequacy of injected-vaste sampling. The attached "A
GUIDE TO THE FEDERAL UNDERGROUND INJECTION CONTROL PROGRAM IN INDIANA11
provides a general description of the permit program and how potential
pathways of contamination are controlled in the deep wells.
Congress addressed concerns about the long term protectiveness of landfilling
or underground injection of hazardous wastes in the HSWA. This act
established land (or deep well) disposal restrictions focused on minimization
of land disposal or deep well injection of hazardous wastes. These
restrictions prohibit the land disposal or deep well injection of specified
hazardous wastes beyond statutory dates established by Congress unless 1) the
wastes are treated to a level or method specified by U.S. EPA, 2) it can be
demonstrated there will be no migration of hazardous constituents from the
unit for as long as the waste remains hazardous, or 3) the waste is
subject to an exemption or a variance. The no-migration demonstration
mentioned above can be approved by U.S. EPA under the condition that the
hydrogeological and geochemical conditions at the sites and the physiochemical
nature of the waste stream are such that reliable predictions can be made
that:
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1) injected fluids will not migrate within 10,000 years vertically
upward out of the injection zone, or laterally within the injection
zone to a point of discharge or interface with a USDW; or
2) before the injected fluids migrate out of the injection zone or to a
point of discharge or interface with USDW, the fluid will no longer be
hazardous. (See 40 CFR 148.20)
Such a no-migration demonstration must depend heavily on fluid flow modeling.
Fluid flow modeling is a well-developed and mature science, having been used
for years in the petroleum industry as well as in recent studies for the
Department of Energy nuclear waste isolation program.
U.S. EPA believes that the no-migration petition requirements are so stringent
that if such a petition is approved for disposal of the ground water from
Hideo, deep well injection, even without treatment, will be considered to
provide permanent protection to human health and the environment. If the deep
well injection system receives approval from U.S. EPA, the injection will have
no impact on USDW, which includes any residential wells.
Presently, four steel mills in northwest Indiana are legally injecting
hazardous wastes into the Haunt Simon aquifer located approximately 2200 feet
below the surface. These include U.S. Steel, Inland Steel, Bethlehem Steel
and Midwest steel. Three of these facilities (Inland, Bethlehem and Midwest)
have submitted a no-migration demonstration to U.S. EPA for approval in order
to allow them to continue hazardous waste injection without treatment. U.S.
Steel is expected to submit a demonstration soon. The hazardous wastes being
injected are waste pickle liquor and waste ammonia liquor. U.S. EPA expects
to make a decision on the no migration demonstrations for these facilities by
March of 1990. If the no-migration demonstration is approved for these
facilities, it is likely that a similar demonstration will be approved for
Hideo.
If the no-migration petition is not approved, the contaminated ground water
from the Hideo sites would have to be treated prior to the deep well
injection. The required level of treatment is established nationally as the
best demonstrated available treatment method for that type of waste.
It has been estimated that as many as 500,000 injection wells are in operation
in the United States, but there are only 191 hazardous waste injection wells.
These wells are concentrated in Texas, Louisiana, Illinois, Indiana, Michigan
and Ohio. The oldest hazardous wastes injection well dates back to 1951. Use
of hazardous waste injection wells underwent a thorough review by the
Government Accounting Office in 1986. The results of their investigation are
summarized in a document named "Hazardous Waste Controls Over Injection Well
Disposal Operations1*, GAD/RCED-87-170, August 1987.
GAO determined that nationwide, two cases of USDW contamination have been
documented by companies operating hazardous waste injection wells. In
addition, one case of suspected contamination and eight cases of contaminatior
of water that was already considered unsuitable for drinking have been
documented. The USDW contamination occurred in Texas and Louisiana but was
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not extensive. Program controls now in place prohibit the practice that led
to the two rases of drinking water contamination.
The leakage from hazardous waste injection wells into non-drinking water
aquifers occurred at eight facilities between 1975 and 1984. The causes of
the leakage centered on casing and/or tubing corrosion or deterioration. The
most notable of these rasps occurred at a commercial facility in Ohio in 1983
where large amounts of waste escaped into an unpermitted zone. This zone was,
however, separated front the bottom of the lowermost USDW by more than 1500
feet, of which 1000 feet was confining rock formations. In response, to these
and other concerns, and to the Congressional mandate for additional ground
water monitoring requirements in the Safe Drinking Water Act Amendments of
1986, U.S. EPA is implementing stricter regulations. This includes:
- more specific well-siting requirements;
- an expanded "area of review" around injection wells for identifying
abandoned wells near the injection site, and added requirements for
corrective action to plug abandoned wells;
- additional operating procedures, such as automatic well shutoff or
alarms; new requirements for testing, monitoring, and reporting,
including a waste-analysis plan, additional mechanical integrity
tests, and more specific monitoring requirements; and
- new requirements for well closure and post-closure care.
The GAO report also pointed out that the full extent to which injected
hazardous waste has contaminated underground sources of drinking water is
unknown because of the problems in detecting contamination that may have
occurred away from the well-bore. The documented cases of contamination have
all occurred near the well-bore. However, regulations require that injection
wells not be located in areas where faults occur and that injection pressures
be maintained below a level that might cause fractures in the formation.
Regulations also require that all man-made holes in the area penetrating the
confining zone and entering the injection zone be located and properly
plugged. In addition, U.S. EPA is implementing requirements to monitor the
migration of the waste movement.
The GAO report concluded that the new deep well injection requirements should
provide additional safeguards to prevent the contamination of USDWs. In
addition, well owners will be required to demonstrate no migration of
hazardous waste. .
GdtfDfr 12:
The City of Hammond comments included a statement that "Preferably the
treatment would be to such an extent that the treated groundwater could be
reinjected into the aquifer from where it originated.11
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D.S. EEA RESPCN5E ID GCMMDfT |2:
See our remorse to Cement #5 below and to Comment #5 from the Midoo Steering
Committee and Morton-Thiokol.
During the public meeting there were a number of comments concerning whether
U.S. EPA puts too much emphasis on costs in its decisions on remedial actions,
and whether alternative innovative treatment and disposal technologies were
considered. Specific comments included the following:
"All we're talking is cost effectiveness."
"I don't think it's fair. I think cost should be put aside. These people
that are going around polluting should be made to pay. . . . It's not costs
because these chemicals that leak out cause cancer and a number of other
sicknesses. ... How do you put a price tag on one's life? Tell me."
"Those responsible for creating environmental problems must pay the
expense of correcting their mistakes."
"They're supposed to be using the best available technology not the most
cost effective."
"Stop delving into the pockets of the public."
"Why didn't they decide to use vitrification?"
"I'd like to know if any of these people knew about "The Superfund
Innovative Technology Evaluation Program Technology Profiles" or
"Assessment of International Technologies for Superfund Applications."
U.S. EPA RESPONSE TO OCMfEMT |3:
The Comprehensive Environmental Response, Compensation and Liability Act
(CERCXA) was enacted in 1980 to provide broad federal authority and resources
to respond to releases (or threatened releases) of hazardous substances. A
trust fund was established to pay for remedial actions at abandoned or
uncontrolled hazardous waste sites. This fund is predominantly from a tax on
petroleum prT^'iuc'*'-'8 and on certain chemicals.
on the principle that "the polluter should pay," CERdA contains
authorities which allow U.S. EPA to ensure that those responsible for
hazardous waste problems pay for necessary remedial actions. CERCIA
enforcement authorities enable U.S. EPA to encourage responsible parties to
undertake remedial actions. It also enables U.S. EPA to spend trust fund
monies for remedial actions and to later recover these monies from responsible
parties.
If an acceptable agreement can be reached, U.S. EPA prefers that responsible
parties implement the remedial actions. At Midco, an agreement was reached
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• - -9- .
*jith potentially responsible parties (PRPs) in June 1985, which required the
PRPs to reimburse U.S. EPA $3,100,000 for past costs incurred and to conduct a
Remedial Investigation/Feasibility Study (RI/FS) at each site in accordance
with the U.S. EPA's work plans. U.S. EPA is now negotiating with PRPs for
implementation of the remedial actions selected by U.S. EPA and for recovery
of the remaining costs incurred. Fund monies will be spent on the final
remedial actions only if an agreement is not reached with PRPs.
In CERGLA (as amended by the Superfund Amendments and Reauthoriration Act of
1986), Congress mandated that all final remedial actions selected by U.S. EPA
must assure protection of human health and the environment, and must meet
applicable, and relevant and appropriate Federal and State standards,
requirements, criteria, and limitations (ARARs). This includes meeting
Federal Primary Maximum Contaminant Levels in the ground water (40 CFR 142).
Congress also mandated that U.S. EPA select remedial actions that are cost
effective, and that utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable. If a remedial action is selected that does not meet this
preference, U.S. EPA must publish an explanation as to why a remedy involving
such a remedial action was not selected.
The least costly alternative that would be protective of human health and the
environment was the containment alternative (Alternative 3), which is
estimated to cost $4.7 million at Midco I and $7.9 million at Midco II. U.S.
is not selecting these alternatives because they would siirply contain the
contamination, and the hazards would be similar to taking no action if the cap
or slurry wall were ever damaged in the future. Instead, U.S. EPA is
selecting remedial actions that it believes will provide permanent protection
to human health and the environment. This consists of soil vapor extraction
and solidification of contaminated soils combined with pumping and deep well
injection of contaminated ground water at Midco I, and the same actions at
Hideo II except that the soil vapor extraction is not required. In addition,
treatment prior to deep well injection will be required if a no-migration
demonstration is not approved by U.S. EPA. The estimated cost of these
remedial actions at Midco I is from $10.7 to $14.0 million, and at Midco II
from $14.4 to $18.6 million (depending on the degree of treatment required
prior to deep well injection).
The persons involved in reviewing the Feasibility Studies are familiar with
"The Superfund Innovative Technology Evaluation Program: Technology Profiles."
The Superfund Innovative .Technology Program includes a number of studies on
solidification, which is part of the selected remedial actions at the Midco
sites. This includes processes by Chemfix Technologies, Hazcon, International
Waste Technologies, Silicate Technology Corporation, and Soliditech. Soil
vapor extraction, which is part of the remedial action at Midco I, is also
included in this program in a process by Terra Vac. Other innovative
technologies were considered for treatment of the contaminated soils at the
Midco sites but were screened out because they were not considered applicable
t vhe conditions at the site. These include in-situ bicdegradation, soil
i Jhing, and chemical treatment. In-situ vitrification and incineration
alternatives were evaluated in detail. Vitrification was not selected because
it has not been demonstrated to be implementable in a full scale remedial
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action at a hazardous waste site and because the high water table would make
implementation difficult and more expensive. The incineration alternative
does not suffer those disadvantages. However, both in-situ vitrification and
incineration would be considerably more expensive than solidification and
would not contribute significantly to the permanence of the remedial actions
if the soil vapor extraction and solidification operations are successful.
Since a surface water discharge would probably not be approved for the salt
contaminated ground water even after removal of the hazardous gnbptanpps, the
alternative to deep well injection of the ground water is to concentrate the
solids in the ground water by an operation such as evaporation. Evaporation
would concentrate at least some hazardous substances into a solid that would
have to be disposed of in an off-site landfill. It does not appear that
disposal of the hazardous wastes in an off-site landfill is any more
protective of human health and the environment than disposal by deep well
injection, and the costs of the evaporation operation would be higher than the
deep well injection.
gCMMECT 14:
"I've been involved in a couple projects, not in this state, where they used
in conjunction with the slurry wall a well extraction, and then they leached
it back in like a septic field. Then it recirculates. Are these contaminants
able to be treated in that respect; and therefore, you wouldn't have deep well
disposal and you wouldn't have a lot of things that would be objectionable at
this point."
U.S. EPA RESPONSE TO GCMfEMT #4:
This method of treatment would not be adequate for the highly contaminated
soils on the site, but it would be acceptable to U.S. EPA for ground water
treatment when combined with a soil treatment measure.
Reinjection of the salt-contaminated ground water following treatment for
hazardous substances would be acceptable to U.S. EPA if the rein j action does
not cause significant spreading of the salt plume. Installation of a slurry
wall and reinjection within the slurry wall is one way of preventing such
spreading. This alternative is not preferred over 'deep well injection at the
Midco sites for the following reasons: U.S. EPA believes that deep well
injection can be accomplished safely and effectively; it is preferable to
remove the salt contaminated ground water from the Calumet aquifer rather than
containing it within a slurry wall; and there does not appear to be a cost
savings using the slurry wall/reinjection alternative compared to deep well
injection.
"As a slurry wall contractor, I would like to conment on the slurry wall
pricing listed in your Fact Sheet. I have never seen prices like these, and,
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as a contractor, I would like to know what they were based on. Today, our
prices for Slurry Wall construction range from $3 to $5 per square foot and a
bentonite cap $.50 per square foot."
U.S. EPA RESPCKSE TO COMQfT |5:
The price estimates were developed by Dames and Moore, a consulting firm
employed by the Midco Steering Committee. According U.S. EPAs's contact with
this firm, the estimates were based on actual quotes from vendors. The costs
were also reviewed by personnel from Roy F. Weston, Inc.
The prices are probably not comparable to the quotes suggested by the
oonmenter because a different type of cap and slurry wall were proposed in the
FS. The proposed cap is not just a single-layer bentonite cap. Instead, it
is a multi-layered cap consistent with the most recent guidance for RCRA
hazardous waste sites. It includes a clay liner, a synthetic liner, a lateral
drainage layer, and a vegetative layer. Instead of installation of the slurry
wall by the vibrating beam method, installation by a trench/slurry method was
proposed. The proposed slurry wall would be approximately three feet thick
while a slurry wall installed using the vibrating beam method is only a few
inches thick. Safety considerations also add to the cost of actions at a
hazardous waste site.
OYMENT |6:
"How deep, how far down has this pollution gone in the sites?"
U.S. EPA RESPCNSE TO CQfQOT 16:
The contamination appears to be confined to the Calumet aquifer, which extends
approximately 30 feet below the surface at Midco I and 40-50 feet below the
surface at Midco II. Below the Calumet aquifer is 90-100 feet of low
permeability clays and tills.
COWEtfT 17:
How many people review the chemical data, and how do the different agencies
and other parties work together?
U.S. EPA RESPONSE TO CCWQ/T |7:
The chemical data was generated by a laboratory that conducted its own quality
assurance/quality control (QA/QC) review of the data. The laboratory used in
this project is also audited by the U.S. EPA. The chemical data was then sent
to a contractor hired by the PRPs, who conducted an independent QVQC review
of the data. The contractor review was also audited by U.S. EPA. A QA/QC
review of the data was conducted by a second contractor working for the PRPs.
The PRP contractors conducted an interpretive review of the data, and
prepared a report that included plotting the distribution of data on a map,
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comparison to standards and a discussion of the data. This report was
reviewed by at least five persons at U.S. EPA, six personnel working for U.S.
EPA contractors, one person from the U.S. Fish & Wildlife Service, and three
persons from the Indiana Deparbnent of Environmental Management.
U.S. EPA personnel reviewing the data included personnel from the air, water,
Great lakes and RCRA programs, who reviewed the report for concerns
specifically related to their programs. Ihe U.S. Fish 6 Wildlife Service
reviewed the report for adequacy of information on ecological effects;
Contractors working for U.S. EPA provided support to U.S. EPA with review of
costs, hydrogeology, ground water modeling, risk assessment and other areas.
A remedial project manager for the U.S. EPA provided an overall review and
compiled the review comments from other agencies and contractors for
transmittal to the contractor conducting the RI/FS for the Hideo Steering
Committee. Communications among U.S. EPA employees, other Federal agency
employees and U.S. EPA contractors usually consist of informal discussions
that are followed up by formal memos.
The Indiana Department of Environmental Management generally prepared their
own comments in writing.
COMMENT 18:
"How are you monitoring landfills?"
U.S. EPA RESPONSE TO COMMENT 18:
Hazardous waste landfills are regulated by U.S. EPA under the Resource
Conservation and Recovery Act (RCRA) and by the various states under acts
similar to RCRA. Under these acts all hazardous wastes entering a landfill
must be manifested. A copy of the manifest is sent back to the company that
generated the hazardous waste and sometimes back to the state agency in order
to verify that the shipment arrived.
Ihe acts also regulate operation and monitoring of the hazardous waste
landfills. Monitoring requirements include periodic sampling of ground water
near the landfill. Self-monitoring reports including ground water sampling
data are periodically sent from the landfill to the agency responsible for
oversight of these facilities (which can be Federal or state agencies). Each
hazardous waste landfill is also inspected periodically by a state or Federal
inspector.
sanitary landfills are regulated primarily by the states. The IDEM inspects
sanitary landfills periodically and requires that ground water monitoring be
conducted.
COMMENT 19:
One resident of Gary, Indiana expressed the following concern: "I am
concerned by the EPA studies performed on the Porter and Lake County wells
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which concluded their well water was unsafe to drink. I am requesting that
(1) the EPA conduct a study to determine the quality of my neighbors' well as
my own."
...
U.S. EPA KESPCXSE TO CCJWENT |9:
The Porter County study referred to is an investigation conducted by the
Porter County Health Department of the effects of three landfills in Porter
County, Indiana on residential and monitoring wells near the landfills. These
landfills will have no impact on well water in Gary, Indiana.
The well of concern is located near 17th and Baker Street in Gary. The
identified hazardous waste sites closest to the resident are Midco I and
Ninth Avenue Dump (which are approximately two miles away) , and Lake Sandy Jo
and the Gary City landfill (which are approximately one mile away) . U.S. EPA
has conducted detailed investigations at each of these sites. The well of
concern was not included in these studies because it was considered to be
outside of the area that could be affected by the sites. The results of the
investigations confirmed that none of these sites will have any impact on the
well of concern. Furthermore, U.S. EPA will conduct remedial actions at the
Midco I, Ninth Avenue Dump, and Lake Sandy Jo sites that will eliminate
significant health risks, if any, from the sites even to the residents closest
to the sites. Ground water at the Gary landfill is being pumped in a manner
that is preventing ground water from the site from flowing off -site.
CCMENT 110:
"If the U.S. EPA would choose an alternative using incineration, we ask that
Ordinance 15090, passed by the Common Council of the City of Hammond, be
incorporated into the design parameters. We feel the standards incorporated
into Ordinance 15090 will protect the health and welfare of those citizens who
live adjacent to the site."
U.S. EPA RESPONSE TO CCfMENT 110:
The alternative selected by U.S. EPA in this ROD does not include
incineration. If incineration was conducted, the U.S. EPA would not consider
the City of Hammond's incinerator regulations to be either an applicable, or
relevant and appropriate requirement since the operation would be conducted
outside the city limits of Hammond. However, U.S. EPA will likely reach
similar goals through requiring compliance with standards set by the RCRA,
TSCA and CERGLA programs. These include the following:
1) Each principal organic hazardous constituent in the waste must be reduced
to 0.01% of the original concentration before emission into the air. The
RCRA program refers to this as 99.99% destruction and removal efficiency.
Sane of the more toxic compounds, including polychlorinated biphenyls, must
be reduced to 0.0001% of the original concentration.
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;2) Hydrochloric acid emissions, if greater than 4 pounds per hour, must be
reduced by 99%. Emissions of particulate matter may not exceed 0.08
grains per dry standard cubic foot.
B. SLM^ARY OF COMMENTS FROM THE INDIANA DEPARTMENT OF HIGHWAYS:
? • • .
COMMENT II:
"The FS report fails to clearly define the contaminant transport mechanism
that has caused dissolved salt contaminants (e.g. chlorides) to migrate fror.
the IDOH Subdistrict site, against the prevailing ground water flow direction
and hydraulic gradient, and be deposited in the ground water underlying the
Midco I site."
U.S. EPA RESPONSE ID COMMENT fl:
The mechanism is explained on pages 1-13, 4-19, and 5-32 of the "Remedial
Investigation of Midwest Solvent Recovery, Inc. (Midco I)" dated December
19S7, as follows: "Chloride values were also high (up to 7,700 mg/1) in
shallow wells (10-fcot-deep) in a band extending through the middle portion of
the site (MW7, MW6, MW5, Figure 5-25). ... This band occurs in a former
swale area that received run-off from the Indiana State Highway Department
property prior to Midco I as documented on September 1973 aerial photographs.
The evidence suggests that chloride in the shallow wells was derived from
concentrated NaCl surface run-off percolating downward to ground water in the
former swale area."
COMMENT 12:
"It is plausible that other chloride-containing wastes (e.g., pickle liquor,
waste oils containing chlorinated paraffins, etc.) were improperly managed or
disposed of on the Midco I site and that IDOH is, therefore, not the sole
source of chloride contamination in the site area."
U.S. EPA RESPONSE TO COMMENT |2:
U.S. EPA agrees that the Midco I site operations likely made a contribution to
the salt contamination in the ground water below and down gradient fron the
site. U.S. EPA believes that both IDOH and the Midco I operations contributed
to this salt contamination, but the amount attributable to each source cannot
be determined.
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"Also the FS report fails to distinguish between reactive cyanides, which were
likely present on Hideo I, and complexed fernocyanide, which was used by IDOH
as an anti-caking agent in the salt. The ccnplexed ferrocyanide ?***$ little
risk to human health or the environment under most conditions, while the
reactive forms are of greater environmental concern. "Additional technical
evaluation of the type, distribution, and potential impact of the cyanide
contaminants in the subsurface environment should be conducted. "
U.S. EPA RE5PCKSE TO OOflDir 13:
Four rounds of sampling were conducted for cyanide. The last round included
tests for cyanide amenable to chlorination as well as total cyanide. U.S. EPA
agrees that reactive forms of cyanide (some of which were likely disposed of
at Midco I) are more hazardous to human health and the environment than
oomplexed ferrocyanide.
CCMMQ/T 14:
FS Figure 1-32 showing the distribution of cyanide in the aquifer is
misleading and improperly constructed.
U.S. EPA RESPONSE TO OCWEWT #4:
U.S. EPA agrees that Figure 1-32 in the draft FS was misleading and improperly
constructed. This Figure was removed from the final FS report, at the request
of U.S. EPA. U.S. EPA agrees that the highest cyanide concentrations are in
the east-central portion of the Midco I site.
OJWENT 15:
••GALS (cleanup action levels) have not been established for chlorides in soil,
ground water, or surface waters at the Hideo I site, an apparent indication
that no site-specific health or risk-based factors have been determined for
this parameter."
U.S. EPA RESPONSE TO CCfWEWT |5:
The salt contamination in the ground water has been viewed as a concern
primarily because of the loss of a resource (that is, usage of the ground
water) rather than as a human health or environmental hazard. In spite of
this, there are some human health and environmental hazards from the salt
contamination. Sodium greater than 20 mg/1 in drinking water can have a
negative health effect on persons on a low sodium diet. High salt content can
also have an impact on fresh water aquatic life.
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CQMMENT 16:
"An independent study commissioned by IDOH did not disclose total cyanide in
surface and subsurface soils at concentrations exceeding the soil CAL (136
ppm); the soil levels detected were typically 1 to 2 orders of magnitude below
the CAL. Only 2 of 16 ground water samples collected from monitoring wells on
the IDOH property exceeded the ground water CAL for cyanide (10.4 ppb).
U.S. EPA RESPONSE TO COMMENT |6:
U.S. EPA can respond to this connent once the referenced data has been sent to
U.S. EPA for review.
COMMENT 17:
IDOH recommended that the alternative of discharge to the City of Hammond
sewer system be reevaluated. It was argued that the discharge of salt fror.
the Hideo I ground water, would be minor compared to the present salt load
discharged to the Hammond Wastewater Treatment Plant..
U.S. EPA RESPONSE TO COMMENT 17:
In general, discharge of highly saline wastewater to a POTW is not allowed due
to potential interference in the biological treatment processes. In addition,
the Hammond Wastewater Treatment Plant is already exceeding its discharge
limitation for chloride. The highly salt contaminated discharge from Hideo I
would cause an even greater exceedance. Discharge to the Hammond Wastewater
Treatment Plant may also be restricted by the U.S. EPA off-site policy, which
requires that facilities used for disposal of wastes in the CERCLA program
must be in compliance with applicable Federal and State regulations.
C. Comments from the Midco Steering Committee and from Morton Thiokol, Inc.
COMMENT |l:
U.S. EPA did not select a cost-effective remedy for soils or ground water.
U.S. EPA RESPONSE TO COMMENT II
See U.S. EPA's response to the following comments from the Midco Steering
Committee and the response to Comment 13 from the public meeting, etc.
COMMENT 12:
The assumptions used in the risk assessment are unrealistic.
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-17-
U.S. EPA RESPONSE TO OCM4ENT |2:
U.S. EPA required that the risk assessment include a scenario that assumed
that each site would be developed for residential or industrial use. This is
a standard procedure for CERCLA sites. The particular assumptions used in the
risk assessment had to be consistent with standard U.S. EPA risk assessment
practices as expressed in the Superfund Public Health Evaluation Manual
(SPHEM). Parameters and assumptions that were not spelled out in the SPHEM
were selected by Environmental Resources Management Inc. with review and
concurrence by U.S. EPA.
COMQ/r |2A:
Ingestion rates and dermal contact rates for the contaminated soils were
unrealistic. In addition, it is unrealistic to assume that there would be no
degradation of contaminants over tine.
U.S. EPA RESPONSE TO OMIDfr 2A:
U.S. EPA's current guidance for soil ingestion rates for use in CERCLA and
RC3RA risk assessments is more stringent than that used in the PSs. To proncte
consistency within the Agency, U.S. EPA has recommended soil ingestion rates
or use in risk assessments in a memo from J. Winston Porter dated January 7,
j.989. These rates are 0.1 grams per day for adults and 0.2 grains per day for
children ages 1-6. These rates are based on the most recent reliable data
reviewed by the Agency, and represent reasonable conservative values. The
guidance does not address children who. exhibit pica behavior because the
occurrence of pica behavior and the associated rates of soil ingestion have
not been adequately defined. The FS assumed that 1 gram per day would be
ingested by children ages 2-6, 0.1 gram per day for children ages 6-12 (only
for Midco I), and no ingestion after that age.
The estimated, lifetime cancer risk is proportional to the total lifetime
exposure. Using the assumptions in the Midco Feasibility Study (FS) the total
lifetime amount of soil ingestion is between 1,715 and 2,044 grains. Using the
new recommended rates, the lifetime soil ingestion is 2,774 grains. As can be
seen, the lifetime cancer risk estimate will be higher using the new rates
than the rates used in the FS. In addition, using the assumptions in the FS,
there would be no further exposure following the age of 12, but using the new
rates there would be continued exposure.
The risks from soil ingestion in the industrial development scenario are less
than in the residential development scenario, but are still substantial.
Some types of exposure that can occur after age 12 could also occur under the
industrial development scenario. Assuming 30 years of exposure at 0.1 gram
per day equals 1,095 grams in a lifetime using the industrial development
Tenario. This is approximately 60% of the lifetime ingestion used for risk
xLculations in the FS, and, therefore, the same percentage of the lifetime,
carcinogenic risk.
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-18-
The dermal contact rates used in the FS were proposed by Err/ironmental
Resources Management. Personnel from U.S. EPA and PRC Environmental
Management, Inc. (PRC) reviewed the proposed rates and felt that they were
reasonable conservative assumptions.
Degradation/removal of contaminants does occur over time due to volatilization
and biodegradation. However, the rate of these processes is generally very
slow for sane of the chemicals of most concern, including polychlorinated
biphenyls, lead, arsenic, and polyaronatic hydrocarbons.
OCfflENr |2B:
It is unrealistic to assume that residential development could occur at these
sites. In addition, Midco II is included in the City of Gary airport's
expansion plans.
U.S. EPA RESPONSE TO OCMMEOT |2B:
U.S. EPA disagrees with this assertion. While it is not possible to know
whether residential development will occur, it appears to be quite possible
since there are already residences located in industrial areas near these
sites. This includes a residence located 500 feet south of the Midco I site
on Elaine Street. It is across the street from Calumet Waste Systems and near
General Drainage. The residents at this location utilize the Calumet aquifer
for drinking and have a garden. Another property adjacent to General Drainage
is used for gardening by a Hammond resident.
There are a number of residences at the corner of Clark Road and Industrial
Highway, which is one mile southeast of Midco II. These residences are across
the street from House's Junk Yard, and adjacent to Samocki Brothers Trucking.
Two of the residences formerly used the Calumet aquifer for drinking, and a
number of the residences have gardens.
The Gary City Airport is one of three sites being considered for the third
regional airport for the Chicago area. If the Gary Airport site is selected,
the Midco II property may be incorporated into the airport. However, this is
still very uncertain. Even if Midco II is incorporated into the Gary City
Airport, this may not eliminate the risks from contact with the contaminated
soils or ground water if no action is taken.
COM}*! I2C:
It is unrealistic to assume this ground water may be used for drinking (at an
ingestion rate of two liters per day), and for bathing because of the salt
contamination in the aquifer and difficulty in obtaining a permit for well
installation.
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— -19-
U.S. EPA RESPONSE TO COWENT |2C:
The most contaminated portions of the Calumet aquifer at each site is in the
shallow portion of the aquifer. In the shallow portion, chloride was
generally in the range of 1,000 mg/1 at each site. Water is drinkable with
this concentration of chloride, although it has an undesirable taste. Two
residences near the corner of Clark Road and Industrial Highway formerly
utilized veils that only pumped from the shallow portion of the Calumet
aquifer. This is evidenced by statements by the residents that their wells
ran dry due to pumping at Samocki Brothers.
Ground water contaminated with 1,000 mg/1 chloride is common in sanitary
landfill plumes. If a landfill site is on the National Priorities List and
the plume contains hazardous substances above cleanup action levels,
remediation of the plume is often required by U.S. EPA under CERCIA
irrespective of the presence of the chloride plume or the fact that the
hazardous waste contributors may not have been the primary cause of the
chloride contamination. Similarly, the hazardous substances from the Midco
sites must be remediated irrespective of the presence or the source of the
chloride contamination.
Besides the three residential wells previously mentioned, sixteen residential
drinking water wells were located in the City of Gary that are potentially
down gradient from Midco I. Since the State of Indiana had no record of these
wells, it appears that none of then had a permit.
For the industrial development scenario, the risk level would be similar to
that for residential development because the primary risk is due to ground
water ingestion. In an industrial situation, actual water consumption depends
on the level of activity and the work environment. For extreme cases,
consumption of as much as 19 liters of water per day can be normal. A
standard consumption figure of 2 liters/day is reasonable for both 1) total
daily consumption by the general population and 2) working day consumption by
a mix of workers.
OOMDfT |2D:
The risk assessment should take into account the number of persons exposed and
the risk compared to other cancer agents.
U.S. EPA RESPONSE TO GCMJENT 2D:
The SPHJEM and Agency policy for risks assessments for CERCIA sites add
both future potential risk and present risk. As a result, under CERCIA, U.S.
EPA often bases its remedial actions more on potential for usage of an aquifer
or for future development of a site than on the present population affected.
At the Midco sites, U.S. EPA is taking into account that the Calumet aquifer
is little used and has other contaminant sources by only requiring clean up to
the 10"5 lifetime carcinogenic risk level rather than the 10""6 risk level that
is normally required in Region V. In addition, the potential for development
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- -20-
of Midoo II is considered to be lower than usual; thus the 10"5 risk level is
being used for the soil clean up.
Under CERCLA and RCRA, Congress has mandated that U.S. EPA address and
remediate risks fron hazardous waste management and disposal. It is U.S.
EPA's responsibility to address and remediate these risks irrespective of
other risks that are present in every day life.
CO-WENT 13:
Direct soil treatment is unnecessary, and Alternatives 7 and 8 (which include
direct soil treatment by solidification and soil vapor extraction as well as a
final site cover and ground water pumping), do not provide any reduction in
institutional controls or significant additional protection compared to
Alternatives 4A and 4C (which only include ground water pumping and
installation of a final site cover).
U.S. EPA RESPONSE ID GCJWEf/T 13:
The Midoo Steering Committee proposes that Alternatives 4A or 4C include a
silty clay cover so that contaminants in the soils would be slowly leached
into the ground water and recovered in the ground water pump and treatment
system.
Alternatives 4A and 4C would leave a large reservoir of untreated hazardous
substances in the on-site soils. At Midoo I, this includes an estimated
70,000 Ubs. of volatile organic compounds, 60,000 Ibs. of copper, 30,000 Ibs.
of zinc, 20,000 Ibs. of chromium, 10,000 Ibs. of lead, 10,000 Ibs. of phenol,
10,000 Ibs. of cyanide, 7,000 Ibs. of bis(2-ethyl-hexyl)phthalate), 5,000 Ibs.
of polyaromatic hydrocarbons, and 100 Ibs. of polyaromatic hydrocarbons. At
Midoo II, this includes an estimated 100,000 Ibs. of copper, 70,000 Ibs. of
zinc, 30,000 Ibs. of lead, 20,000 Ibs. of volatile organic compounds, 20,000
Ibs. of chranium, 8,000 Ibs. of arsenic, 1,000 Ibs. of cyanide, and 400 Ibs.
of polychlorinated biphenyls. These weights are calculated by multiplying the
trench average concentrations by the estimated pounds of soils to be treated,
assuming that one cubic yard equals one ton.
This large reservoir of hazardous substances presents a future risk due to its
potential to continue contamination of the aquifer and due to potential for
direct ingestion and direct contact hazards. It appears very unlikely that
this large reservoir of contamination will be adequately removed using only
passive uncontrolled natural leaching even for a long period of time. It is
quite possible that, if the site cap is disturbed in the future, renewed
ground water contamination would be caused even after many years of ground
water pumping and attainment of ground water cleanup action levels. Leaving
the hazardous substance reservoir without treatment, would also require that
the ground water pumping system operate for a much longer period of time.
Although the predominant risk is due to ground water ingestion in the future
usage scenario, the risks due to direct soil ingestion are also liXely to be
unacceptable in case of future development of the site, if the contaminated
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soils are not treated. A number of the chemicals of most concern for the soil
ingestion hazard are relatively immobile in soils. This includes arsenic,
polyaromatic hydrocarbons, polychlorinated biphenyls, bis(2-ethyl-
hexyl)phthalate, and lead. Even if these chemicals alone remained in the
contaminated soils at or near their present concentrations, the residual risks
due to soil ingestion would be unacceptable. At Midco I, the estimated
lifetime cancer risk would be 3 X 1
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-22-
Alternative 2 in the FS, may be required. If solidification is very
effective, a less complex final site cover would be acceptable.
U.S. EPA has a strong preference for permanent remedial actions, and believes
that incineration followed by solidification is more certain to provide
permanent treatment of the contaminated soils. Incineration would reliably,
and permanently destroy the organic contaminants and would leave a residual
ash that could be more easily solidified because the organic compounds would
be removed. On the other hand, incineration is considerably more expensive
and solidification combined with soil vapor extraction has the potential to
provide the same degree of protection. Therefore, at this time, U.S. EPA
prefers to implement the solidification alternative pending the results of the
treatability tests.
CCmENT 15:
"Solidification of the Hideo II soils might interfere with and preclude the
contemplated expansion of the City of Gary Airport."
U.S. EPA RESPONSE TO OCWQfT #5:
Measures will be taken to-make the remedial actions at Midco II compatible
with the Gary Airport expansion if this occurs.
CCWENT 16:
The harm caused by releases of the chlorides to the ground water is divisible
from any impact from the Midco sites and costs can be apportioned for the
chloride contamination.
U.S. EPA RESPONSE TO GOff^ENT 46:
While U.S. EPA does not agree with this statement, it is not relevant to the
selection of a remedy, but rather to the liability ramifications. U.S. EPA
noted that the Midco operations themselves likely contributed to the chloride
contamination. Available site records indicate that 39,010 gallons ferric and
ferric chloride wastes and 60,755 gallons of liquid waste containing 5% HC1
were taken to Midco I or Midco II. Other wastes taken to the sites, whose
records do not identify the waste type, may also have contained high
chlorides. Seme of these wastes were likely spilled onto the ground or
dumped into pits into the aquifer in accordance with the disposal practices
for these sites. In addition, at Midco I, the swales in the northern half
of the site were filled with unknown materials during the Midco operations.
It is possible that this fill contributed to the chloride contamination at
Midco I.
Moreover, U.S. EPA does not agree with the suggested procedure for calculation
of the incremental remedial action costs attributable to the salt
contamination. The procedure proposed by the Midco Steering Committee assumes
that all costs of the deep well injection operation should be considered
incremental costs attributable to the salt contamination. This is not
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- -23-
correct, because the costs for treatment are substantially reduced* when using
the deep well injection alternative compared to the treatrent costs for
discharge to surface waters or to ground water (even without treataient of the
salt) . In fact, deep well injection without treatirent could be less expensive
than treating to surface water discharge standards or to drinking water
standards (even without treatment of the salt) . For example, the estimated
incremental cost for treating the ground water to drinking water standards
(other than chlorides) at Hideo I is $3,938,000 (present worth of alternative
4C minus 4A plus $675,000 for the petition demonstration) , while the costs
attributable to the deep well injection operation in Alternative 4A is
$3,137,000. Similarly, at Midco II the estimated incremental cost of
treating to drinking water standards is $4,910,000, while the cost
attributable to the deep well injection operation in Alternative 4A
is $3,491,000.
If treatment to meet Land Disposal Restrict ions is required prior to the deep
well injection, then the cost of the deep well injection system would be
increased considerably, but the degree of treatment required would still be
less than that required for rein j action into the Calumet aquifer or for
discharge to the Grand Calumet River.
The primary objective of the remedial actions at the Midco I and Midco II
sites is to address the contamination by hazardous substances and not by
chlorides. Nevertheless, chlorides that are captured by the ground water
treatment system must be disposed of properly. This is consistent with the
approach that U.S. EPA takes at other sites. For example, at landfill sites,
chlorides are often mixed with the hazardous waste plume. In spite of the
fact that the primary objective of remedial actions at these sites is to
address the hazardous substances and not the chloride plume, the chlorides
that are present in any ground water pumped from the ground must be properly
disposed of by the party conducting the remedial action at landfill sites.
The State of Indiana should issue a variance allowing the discharge of the
treated Midco I ground water to the Calumet aquifer:
U.S. EPA KESKKSE TO COM-NT |7:
The State of Indiana does not have primacy for the underground injection
control program. Therefore, any underground injection roust be approved by
U.S. EPA. The reinjection well would be considered class IV unless the waste
is delisted, since the ground water contains listed hazardous wastes. This
reinjection is not prohibited if it is conducted for cleanup of a release
under CERCLA or RCRA. CEROA will allow this reinjection if the contaminated
ground water meets the cleanup action levels and does not allow significant
spreading of the salt plume.
For clarification, there appears to be three ways to reinject without
spreading the salt plume. One would be to construct a slurry wall around the
site, pump and treat the ground water within the site, and reinject the ground
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-24-
water within the slurry vail. Another alternative would be to punp and treat
the ground water for both hazardous substances and chlorides (such as by
evaporation) and reinject the treated ground water off-site (Alternative 4E).
The third is to punp ground water, treat it and reinject it near the site in a
manner that would not spread the salt plume.
CCfWEWT |7:
The State of Indiana should issue a National Pollutant Discharge Elimination
System permit allowing the discharge of the salty ground water to the Grand
Calumet River following treatment of hazardous substances.
U.S. EPA KESKK5E TO CCMMENT |7:
Dames and Moore, who conducted the FS for the Hideo Steering Committee,
concluded that the State of Indiana would not allow a discharge to the Grand
Calumet River without reducing chloride levels. However, in order to respond
to the comment from the Hideo Steering Committee, U.S. EPA has contacted IDEM
and conducted some additional internal discussions. Personnel with the IDEM
water compliance section stated verbally that a preliminary review of data
from the Grand Calumet River indicated that no excess capacity exists in the
chloride allocations for the Grand Calumet River, and that preliminarily, it
did not appear that the State would allow a discharge with a chloride
concentration higher than 500 mg/1 for the Hideo sites. U.S. EPA followed up
these conversations with a letter requesting a formal determination on this
matter.
OJMENT 18:
Cleanup action levels should be periodically revised.
U.S. EPA RESPONSE TO CCWMENT 18:
This is provided for in the RODs.
OMSCT |9:
Only one deep well should be installed to serve both of the Hideo sites.
U.S. EPA EESPCKSE TO OCWMENT |9:
This is allowed for in the RODs. However, it is not clear why the Steering
Connittee feels the shared well should be located at Hideo I, since Hideo II
will have a higher flow rate and has a larger area.
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- -25-
O>HENT f 10
"The U.S. EPA and the State should seriously consider prohibiting use of the
Calumet aquifer as a source of drinking water due to the salinity issue."
U.S. EPA KESKNSE TO QCMQNT {10
The results of the Hideo Remedial Investigations indicated that the salt
contamination had only affected limited portions of the Calumet aquifer.
Although the Calumet aquifer is susceptible to contamination by surface
sources, it is the intent of RCPA and CERCLA to control or remediate these
potential contaminant sources so that aquifers like the Calumet aquifer can be
safely used.
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A GUIDE
to the
FEDERAL
UNDERGROUND INJECTION
CONTROL PROGRAM
in
INDIANA
Prepared byj
SMC Martin Inc.
900 Heat Valley Forge Road
P. O. Box 859
Valley Forge, PA 19482
Under Contract No. 68-01-621
to the
U. S. Environmental
Protection Agency
Region V
230 S. Dearborn Street
Chicago, IL 60604
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About the Guide
This guide is intended to familiar-
ize the public with the regulations for
the Underground Injection Control (UIC)
Program. Technical criteria for the
program were published in the Federal
Register June 24, 1980 and codified aa
Part 146 of Title 40, Code of Federal
Regulations. Procedural requirements,
state approval process, and the permit
issuing process were promulgated on
May 19, 1980 as part of the Consolidated
Permit Regulations as revisions to
40 CFR, Parts 122, 123 and 124. The
Part 122 and 123 Regulations were deconaol-
idated as technical amendments on April 1,
1983 (48 Fed. Reg. 14145) and now appear
as Parts 144 and 145 of 40 CFR.
Subsequent to the promulgation of
these regulations, the Safe Drinking
Water Act was amended. Among other
changes, the amendments added a new
Section 1425 to the Act. Section 1425
establised an alternative method for a
state to obtain primary enforcement
responsibility for those portions of its
UIC program related to the recovery and
production of oil and gas. The Hay 19,
1981 Federal Register (Vol. 46, No. 96,
p. 27333) contains Section 1425 guidelines.
Also, the Environmental Protection
Agency amended the regulations listed
above on August 27, 1981 and February 3,
1982. These amendments were promulgated
as part of a legal settlement reached
with a number of companies, trade associ-
ations, and the State of Texas.
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Table of Contents
I. THE UIC PROGRAM IN PERSPECTIVE
National Concern for Ground Water
Congress Acts
Background of the Regulations
II. MAJOR CONCEPTS OP THE UNDERGROUND
INJECTION CONTROL PROGRAM
Potential Pathways of Contamination
1. Faulty Well Construction
2. Nearby Wells
3. Faulty or Fractured
Confining Strata
4. Direct Injection
5. Lateral Displacement
Requirements for Injection Well Class
Class I Class IV
Class II Class V
Class III
III. PERMITS AND RULES - TOOLS FOR REGULATIO
Who Must Obtain a Permit
Who May Be Authorized by Rule
Basic Permit Requirements
How to Obtain a Permit
IV. STATE INVOLVEMENT IN UNDERGROUND
INJECTION CONTROL
Indiana's Authority to Regulate
Injection Wells
V. EPA'S UIC PROGRAM FOR INDIANA
MATRIX OF STATE REGULATORY AUTHORITY
APPENDIX A - LIST OF CONTACTS RE-
GARDING UNDERGROUND INJECTION IN
THE STATE OF INDIANA
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I. THE UIC PROGRAM IN PERS.ACTIVE
National Concern for Ground Water
Most areas of the United States are
underlain by geological formations or
strata that -are capable of yielding
usable quantities of water. Such geo-
logical formations are called aquifers.
People have long relied on aquifers
as the source of high-quality water.
Today, about half of the American popula-
tion uses ground water for Its domestic
needs. :
In the arid areas of the country,
aquifers are often the only source of
water available. And with increased
usage of water by industry, homes, and
municipalities, national reliance on
ground water is expected to increase.
Ground water is also a vital link
in the water cycle. Aquifers are re-
plenished by rainfall or other surface
water percolating through the soil. In
turn, ground water supplies the base
flow of many streams and feeds lakes
through underground springs.
Recent years have seen a growing
concern for the quality of ground water.
Pollutants in surface waters or substances
deposited on the soil (e.g., pesticides
and fertilizers) may be carried into
aquifers in the replenishment process.
The land disposal of wastes (e.g., into
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injection wells, landfills, and surface
Impoundments) can also cause contami-
nants to enter ground water.
Injection wells can be either bene-
ficial or a major problem in this regard,
It is estimated that perhaps as many as
500,000 injection wells are in operation
nationwide. These wells involve a broad
variety of practices from beneficial
purposes (e.g., aquifer recharge and the
production of oil, gas and minerals), to
the improper disposal of toxic and
hazardous wastes.
The contamination of ground water
is • natter of grave concern. Ground
water is usually assumed to be of high
quality and is often used with little or
no treatment* Contamination is usually
discovered when the consumer becomes ill
and, in many cases, the only practical
solution is to search for another source
of fresh water. Because of the slow
movement of ground water, it may be
decades or even centuries before the
aquifer is once sore usable. In some
oases, the contamination can never be
reversed and the reeource may be lost
forever. Finally, the effort to clean
up the nation's surface waters is ham-
pered if the base flow of streams is
already contaminated.
Congress Acts
Congress recognized these potential
threats to ground water when, in the
Safe Drinking Hater Act of 1974
(P.L. 93-523), it instructed the Environ-
mental Protection Agency (EPA) to estab-
lish a national program to prevent
underground injections which endanger
drinking water sources. More specific-
ally, the Safe Drinking Water Act (8DMA)
requires EPA tot
o Publish minimum national require-
ments for effective State Under-
ground Injection Control (OIC)
programs.
o List states that need OIC programs.
o Make grants to states for developing
and implementing UIC programs.
o Review proposed state programs and
approve or disapprove them.
o Promulgate and enforce OIC programs
in listed states if the state
chooses not to participate or does
not develop and operate an approvable
program.
Several points are worth noting
about the statutory mandate. First, the
SDWA was intended to head off what
Congress perceived as an emerging problem.
the committee report accompanying the
Act (H. Rept. 93-1185, p. 32) makes
clear that no burden is laid on EPA or
the state to prove actual contamination
before establishing regulations or
enforcing them. Second, OIC is clearly
to remain a state program. States are
expected to assume primary responsibility
for fashioning and operating effective
-------
programs in their states. The EPA ia
required to step in only If a state
chooses not to participate in the program
or fails to administer its program
effectively. EPA also has direct respons-
ibility on Indian lands. Third, Congress
enjoined BPA to observe three provisions
in establishing regulations. The
regulationsi
o Are not to Interfere with or impede
oil and gas production unless
necessary to protect underground
sources of drinking water.
o Are not to disrupt effective exist- .
ing state programs unnecessarily.
O Are to take local variations in
geology, hydrology and history into
.• account.
Background of the Regulations
BPA originally proposed regulations
to Implement Part C of the Safe Drinking
Water Act (SDWA) on August 31, 1976.
That proposal included the program
regulations and the technical criteria
and standards for the UIC program.
Numerous written comments were filed and
many persons commented at three public
hearings. .
After careful review of those
public comments, BPA determined that
there were many ways that the initial
proposal could be made generally more
flexible and less burdensome without
sacrificing the resulting environmental
protection to any significant degree.
Further, in the fall of 1978, the Agency
decided to consolidate the regulations
for its major permit programs.
As a consequence of these decisions,
the UIC program regulations were repro-
posed on April 20 and June 14, 1979.
After five public hearings and
review of public comments the Agency
promulgated final Consolidated Permits
Regulations on May 19, 1980 and Technical
Criteria for state UIC programs, on
June 24, 1980.
A number of trade associations,
mining companies, oil and gas producers,
iron and steel producers, and the State
of Texas petitioned for review of these
regulations. In all a list of 93 issues
was filed by the petitioners with the
Court of Appeals for the District of
Columbia Circuit. In response to the
legal challenge, the Agency proposed
amendments to the regulations on October 1,
1982 and promulgated final amendments to
its Consolidated Permit Regulations and
Technical Criteria and Standards for
state UIC programs on August 27, 1981
and February 3, 1982. However, on April 1,
1983, the UIC regulations were deconsoli-
dated from EPA'a other permitting programs.
Thus, public comments, further
study, amended legislation and internal
management improvements are the principal
foundations of the UIC
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II. MAJOR CONCEPTS OP THE UNDERGROUND
INJECTION CONTROL PROGRAM
Congress intended the UIC program
to protect not only the ground water
which already serves a source of drinking
water but also the ground water that
could potentially serve as an underground
source of drinking water (USDW). The
regulations propose, therefore, that all
aquifers or portions of aquifers currently
serving as drinking water sources be
designated for protection. Furthermore,
any other aquifer or portion of it which
is capable of yielding water containing
10,000 or fewer milligrams per liter of
total dissolved solids should also be
designated.
However, not all underground water
sources are suitable for providing
drinking water. Some aquifers are used
for producing minerals, oil and gas, or
geothermal energy. Others are so contami-
nated or located in such a manner that
recovery of water for drinking purposes
is neither economically practical nor
technologically feasible. An exempted
aquifer is an aquifer or portion which
would normally qualify as a USDW but
which for any of several specified
reasons has no actual potential for
providing drinking water and has been
affirmatively identified by EPA as an
exempted aquifer. If EPA exempts an
aquifer or portion of an aquifer, it is
not treated as a USDW subject to the
protections of these regulations.
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•Ignlflcant Tera>* Oeed in the
0IC ttoqtmm
Mai tut - Any geologic formation which ia capable of
yielding uaable quantities of ground water.
H«|| - A bored, drilled, or driven ehaft, or dug hole,
whoa* ileptJl ia frenter then the large*t eurface dleenaion.
•ell Injection r The eapleceaent of fluid* into the
ground feioept drilling auda end elollar Mterlal* need in
veil oonatnotion) through e bored, drilled, driven or dug
veil.
fluid* - Material* or aubatancee vhlch flow or we,
whether eeaU-eolld, liqvid, aludge, or any other for* or
• tate. '
Mechanical Integrity • A general standard for injection
well* which •ignlfiea that there 1* not fl| elgnlflc*nt
leakage in the well'e oaeiag, tubing or packeri and |2| eig-
alfioant aovenaat of field* between the outaraoet caaing and
the veil bora.
miration o| f|y.id* - the anvcewnt of fluid* from the
•ell or the laJeetion cone lato wtdergroMwl aourcee of
driakla* water.
Area et Mview - The area on the eurface eur round ing an
Injeotlao veil wltSiM vhloh all well* that penetrate the
injeotioa eone au*t be reviewed and, if neceaaary, repaired.
It ejay be defined in tarae of a fiaed radlua of not le*a
thaa 1/4 a>ilo Iron the Ui)eotlon well. Alternatively, the
area off review nay be coepeted by the Mae of a antheaatlcal
forawla whiati prediota the lateral dletanoe over which the
liwreneAtal preaeera generated by the injection nay cau**
the wpward algration of fie Ida fron the injection eone
throegh faalt*. lapcoperly abandoned walla, or inproperly
ooejplatad prodeoiAg valla.
Potential Pathways of Contamination
Thfj basic concept of the proposed
DIG program la to prevent the contamina-
tion of underground sources of drinking
water by keeping injected fluids within
that well and in the intended injection
zone. There Are five major ways in
which Injection practices can cause
fluids to migrate into underground
drinking water sources. The following
discussion describes each pathway and
summarizes the technical requirements
proposed in the regulations to prevent
migration through that pathway.
1. Faulty Well Construction
Leaks through the well casing or
fluid forced back up between the well's
outer casing and the well bore, as
illustrated in Figure 1, may cause
contaminant migration into a USOtf.
Preventive Requirements
The regulations require adequate
casing to protect drinking water sources,
and adequate cementing to isolate the
injection zone. Mechanical integrity,
defined as the absence of significant
leaks and fluid movement in the well
bore, must be demonstrated Initially and
every five years thereafter.
riCUM I. PAULTT MILL
-------
2. Nearby Wei la
Fluids from the pressurized area in
the injection zone may be forced upward
through nearby wells into underground
sources of drinking water, as illustrated
In Figure 2.
Preventive Requirements
Nells that penetrate the injection
•one in the area of review must be
reviewed to assure that they are properly
completed or plugged. Corrective action
must be taken if they are not completed
or plugged to prevent fluid migration.
Newly abandoned wells must be plugged to
conform with EPA procedures.
3. Faulty or Fractured Confining Stat
Fluids may be forced upward out of
the pressurized area through faults or
fractures in the confining beds, as
illustrated in Figure 3.
Preventive Requirements
Wells must generally be sited so
that they Inject below a confining bed
that is free of known open faults or
fractures. Injection pressure must be
controlled so that fractures are not
enlarged in the injection zone or creat
in the confining bed.
>. HKAMV HCLLS
ncuu i. rnuLTv on rMcnmn ct iw>
-------
4. Direct Injection
5. Lateral Displacement
ii
Hells may be designed to inject In-
to or above underground sources of drink-
Ing water, as illustrated in Figure 4.
Preventive Requirement
Nells Injecting hazardous waste
materials or radioactive waste into
underground sources of drinking water
are illegal. However, wells injecting
hazardous wastes or radioactive wastes
into exempted aquifers will not be
banned. Nells that inject nonhazardous
material will be regulated in the future
based on recommendations to be formulated
by the states.
Fluid may be displaced from the
injection zone into hydraulically con-
nected underground sources of drinking
water, as illustrated in Figure 5.
Preventive Requirement
The proximity of injection wells to
underground sources of drinking water
will be considered in future siting of
such wells. Nell operators will be
required to control injection pressure
and conduct other monitoring activities
to prevent the lateral migration of
fluids illustrated in Figure 5.
rieuM 4. Bluer INJECTION
ncuu s. LkTuut •isruci
12
13
-------
tin W CDMtaOU
TC I*MC*IO* MIL CMM*>
Requirements for Injection Well Classes
To implement its proposed technolog-
ical controls, EPA categorized well
Injection activities into five classes
defined in Figure 6. Each class includes
wells with similar functions and construc-
tion and operating features so that
technical requirements can be applied
consistently to the class. A brief
summary of the general underground
injection controls proposed for each
class are. highlighted in Figure 7.
Ttri or
in
it
•MA Of
at*IB»
M» Mil* OBlf
wa
ONitaiCtKM
ruauu
•/a
•*«»•
ay a»i. ••
rti
it n Mil* *r* •*•« to 41**o»* *f flulA* Mblch *r*
jfhf to th* Mrfao* 1* •otuMOtlo* with oil and e*a
•rodvatloa, t* l*j*at f 1*14* for th* *nh**e*d r*oo**ry
•(.oil *c •*•« *r to *tor* 11««I4 by4roo*rbo**.
••
if I
Iraot
Itj Mil* ar* UIOM
r*l*.
*•!!• *r* tho*« for
to l*j*ot CUM* Co* th*
k*«*rdou* *••!• or
radlMOttv* «**t* *r* l*j*ot*4 l*ta or *bov* atrat*
that oontal* «**•>•rnuni tfrlaklnf v*t*r aourcaa and
UMM* well* vhleli i*)act ha*ardoM waat** or radlo-
*otl«*) ***to* l*t* *B**jpt*d aquifer*.
CUaa f veil* iaol*** all w*ll* *ot Incorporated In
Claa*i* 1-lT. Tyflcal *ma*pl«a of aucti well* ar*
nchar** •*!!• *ad *lr eondltlonlnf return flow walla.
Class I
Class I wells are likely to inject
potentially dangerous fluids, and will,
therefore, have to meet strict construc-
tion and operating requirements.
Class I wells must Inject into
strata that are below the deepest under-
ground source of drinking water and must
have an adequate confining layer above
the Injection zone. All Class I wells
must be cased and cemented to prevent
fluid migration and must Inject through
tubing with a suitable packer set Imme-
diately above the injection zone (or an
equivalent alternative).
Mechanical integrity must be demon-
strated upon completion of the well and
every five years thereafter, and correc-
tive action must be taken on improperly
plugged or completed wells within the
area of review.
14
15
-------
I'
Class I well operators are required
to monitor continuously the volume of
disposal wastes, and well annular pres-
sures. Class I operators must also test
ths composition of injected fluids
periodically and provide the permitting
authority with quarterly operating
reports*
Sixteen Class I wells are known to
exist In Indiana.
CU«s II
Requirements for Class II wells
.fthose Injection wells associated with
oil and gas production) have been fash-
ioned In light of the congressional
mandate that the DIG regulations are not
.to interfere with or Impede oil and gas
production unless necessary to protect
underground drinking water sources.
These regulations attempt to balance
measures necessary for the protection of
the environment against burdens Imposed
on the regulated community.
Class II injection wells are to
have casing and cementing adequate to
protect underground sources of drinking
water. All Class II wells will also
have to demonstrate mechanical integrity
initially and every five years thereafter.
However, only the applicants for new
Class II permits must review nearby
wells in the area of review and take
corrective action on those improperly
completed or plugged wells.
1
J
Operators of Class II wells are
subject to limitations on the pressure
and rate of injection. They must also
monitor the injection pressure and
volume, and the quality of the injection
fluids at intervals depending on the
type of operation. Annual reports to
the permitting authority are required.
Two thousand, three hundred and
sixty Class II wells are known to exist
in Indiana.
Class III
Construction, monitoring, and
reporting requirements for these wells
will resemble those for Class I wells.
Class III wells must be cased and ce-
mented to prevent fluid migration. All
Class III wells must comply with area of
review requirements and demonstrate
mechanical Integrity. Class III wells
will have the same monitoring require-
ments as Class I wells, except that more
frequent monitoring will be required of
drinking water supply wells adjacent to
the Injection sites.
No Claaa III wells are known to
exist in Indiana.
Class IV
Existing Class IV wells used by
generators of hazardous waste and radio-
active waste and operators of hazardous
waste management facilities which inject
directly into an underground source of
16
17
-------
drinking water will be closed as soon as
possible, but in no event later than six
months from the effective date of the
program. No new Class IV wells which
inject directly into or above an under-
ground source of drinking water will be
authorized or permitted. EPA considers
these wells to be a significant danger
to underground drinking water sources.
However, Class IV wells Injecting into
exempted aquifers will not be banned.
EPA requirements for Class IV wells
which inject above underground sources
of drinking water have not been
established.
Operators of Class IV wells will be
required to monitor Injected fluid
characteristics and volumes, as required
for hazardous waste* under the Resource
Conservation and Recovery Act. Weekly
monitoring of the Impact of injections
on drinking water supply wells will also
be necessary. Class IV well operators
must submit quarterly reports of operating
results and Immediate reports of changes
in the characteristics of water supply
walla in the vicinity of Class IV wells.
No Clasa IV walla are known to
axiat in Indiana.
Class V
At present BPA has too little
information on the extent, operation,
and impact of Clasa V wells to propose a
suitable regulatory approach. The
regulations, therefore, require an
regulations, therefore, require an
inventory and an assessment of such
wells in each state. Specific regula-
tory requirements will be fashioned
after the completion of the assessments,
EPA will take immediate action on
any Class V well that poses a signifi-
cant risk to human health.
Between sixty and one hundred and
fifty Class V wells are known to exist
in Indiana.
18
19
-------
III. PERMITS AND RULES -TOOLS
FOR REGULATION
Under the Act, EPA has the discretion
to specify whether the minimum national
requirements are to be applied through
rules or permits. A rule is a law,
ordinance or regulation that sets forth
the standards and conditions under which
an activity may be conducted. A permit
is a specific authorization to an Individ-
ual to carry on an activity under the
conditions and limitations specified in
the permit.
Each method of control is appropri-
ate in certain situations. Although the
requirements imposed are equally enforce-
able under either method, permits are
generally considered to make possible a
greater degree of control. On the other
hand, permits need more time and resources
since they requires (1) the individual
to file an application containing informa-
tion about his proposed activityy (2) the
effective participation of the public in
the review processf and (3) EPA personnel
to review, write and process each permit.
Who Must Obtain a Permit
Owners/operators of Class I, Class II
(except existing enhanced recovery and
existing liquid hydrocarbon storage),
and Class III wells must obtain a permit
to inject. New wells (those that begin
to Inject after the effective date of a
program in a state) must be authorized
21
-------
by a permit before injection may begin.
For existing wells, the permitting
authority (EPA) will develop a schedule
not to exceed five years, based on
appropriate priorities, for issuing or
reissuing the permits. Until the applica-
tion of the owner/operator of an existing
well has been processed, the injection
may be authorised by rule.
A permit may be sought either for
an individual well or for a group of
wells in an area. An area permit may be
issued for a group of wells if they are:
o Used to inject other than
hazardous waste.
o Under the control of a single
individual.
o Within a single field, project
or site within a state.
o Of the same type and construction,
o Injecting into the same aquifer
or tone.
Under an area permit, additional
wells that meet the above criteria may
be authorised administratively by the
permitting authority.
Who May Be Authorised By Rule
Class II existing enhanced recovery
and existing liquid hydrocarbon storage
wells, may be authorized by rule for the
life of the well. New Class IV wells
injecting into or above underground
sources of drinking water are banned.
Existing Class IV wells injecting into
underground sources of drinking water
may be authorized by rule until they are
closed but in no case for more than six
months after the effective date of the
program. Class V wells may be authorized
by rule until such a time as further
regulations are issued by EPA. All of
these rules must apply the requirement*
specified for the appropriate well class
in the UIC regulations.
As mentioned above, owners/operator*
of existing wells waiting to file their
applications and have them processed may
be authorized to inject by rule in the
interim. Such rules must incorporate
the appropriate monitoring, reporting
and abandonment requirements for each
well class.
Finally, in the case of imminent
and substantial hazard to human health
or the environment, or if substantial
and irretrievable losa of oil and gas
resources will occur, injection not
otherwise authorized may be desirable.
In such cases, a temporary authorization
to inject may be granted administratively,
subject to certain limitations.
Basic Permit Requirements
Class I and Class V permits may be
issued for up to ten years. CMss II
and Class III wells may be is: d for
-------
tne life of the well. However, each
Class II and Class III permit will be
reviewed at least once every five years.
Duration of Class IV permits have not
yet been established.
Bach permit must be enforceable in
the jurisdiction in which it is issued.
It Mist specify construction, abandonment,
operating, monitoring and reporting
requirements appropriate to the well
class. In addition, permits must incor-
. porate appropriate compliance schedules
if any corrective action is to be taken
by the well owner/operator. Finally,
permits must authorise the right of the
permitting authority to have access to
the well and the related records to
assure compliance with permit terms.
Bow to Obtain a Permit
Applications for new injection
wells should be filed with EPA in time
to allow for the review and issuance of
the permit prior to construction.
Applications for existing wells will be
filed according to the schedule estab-
lished in each state, but in no case
later than four years after the effective
date of the program. .
UIC permits for Indiana will be
issued by EPA Region V headquarters in
Chicago (see Appendix A). Permit applica-
tions must be signed by a policy level
officer of the company except in the
24
case of Class II wells where applications
may be made by individuals authorized by
their companies in writing to do so.
Applications must contain a statement
that the signing official has satisfied
himself that the information provided is
correct.
The information that must be avail-
able to EPA is specified for each well
class in CFR Part 146. Generally, such
information should include the surface
and subterranean features of the injec-
tion area, the location of underground
sources of drinking water in the vicinity,
the results of tests in the proposed
injection formation, construction features
of the well, and the nature of the
proposed injection operation. Contact
with EPA should be made early in the
project to obtain the necessary forms
and information. EPA can also provide
guidance on appropriate sources of
information necessary to complete the
application.
The review of a permit application
begins with the receipt of a complete
application by EPA. The EPA considers
the application, gathers such additional
information as it needs, and prepares a
draft permit. The draft permit must be
presented for public comment for at
least 30 days with a fact sheet that
provides enough information that the
public can make informed judgments about
the proposed action. If there is suffi-
cient interest, a public hearing will be
held and announced at least 30 days in
advance.
25
-------
Public comments must be taken into
account in preparing the final permit,
and the EPA will prepare a summary of
the comments and its responses to them.
A final permit is then prepared and
issued. Figure 8 presents a schematic
summary of the process.
First, EPA will also prepare an
administrative record that documents its
decision making for both the draft and
final permit. Second, if sufficient
Interest is expressed, BPA may, after a
public hearing, hold a further hearing
with an opportunity for cross examina-
tion. Third, if sufficient new informa-
tion becomes available during the public
comment period, BPA may prepare a revised
draft permit and solicit further public
comment. A final BPA permit does not
become effective for 30 days after it is
Issued. During that time, a permit may
be appealed. Appeals will be considered
in an established BPA process.
now* •
m tic r*Mt nocttt
act to*
•*4«U«
act to*
Will Operator
l*» a»i BMlVM
r»nit Application
raparo Oralt r*nit
an« r«et
•ra
Olv* rub lie •ocie*
of Draft Vcralt
•olteit
wa
or«ft.
M
Mrlod
ai«« rub lie Vatie*
•< ••arliifl*. Bol«
••acl*f*
•ra
«v Mbll« Co i«i at*.
ffraaacclytc
V
to
•ra
i
laaw* rual **nU
1
MalaUtcatlv*
•ra
1
••art»f« It
•M
•ra a«BiM
26
27
-------
IV. STATE INVOLVEMENT IN UNDERGROUND
INJECTION CONTROL
The Safe Drinking Water Act clearly
intends the states to have the primary
responsibility (primacy) for developing
< and implementing UIC programs. In
fashioning these regulations, EPA has
attempted to encourage states to assume
4 primary responsibility (primacy).
Primacy states must have the author
ity to regulate injection wells at
Federal facilities within the state*
injection on Indian lands, however, will
remain a Federal responsibility if the
state does not have adequate authority.
The State of Indiana has not sub-
mitted an approvable UIC program to EPA.
I Therefore, the Safe Drinking Water Act
mandates EPA to establish and run a UIC
i ! program in Indiana. The Indiana Stream
1 j pollution Control Board, in conjunction
. | with the Indiana State Board of Health
j and the Department of Natural Resources,
; through state law,, conduct regulatory
' programs similar to the EPA UIC program.
j The Indiana Stream Pollution Control
I Board regulates all discharges to ground
I water (except those related to oil and
| gas production) by the Issuance of
i construction, operation and discharge
permits. The discharge permitting
j program is administered by the Indiana
j State Board of Health through the divi-
I aions of Water Pollution Control, Land
! Pollution Control, Sanitary Engineering
-------
and the Public Water Supply Section.
All injection, disposal and enhanced
recovery wells associated with oil and
gas production are regulated by the
Indiana Department of Natural Resources
which requires all drillers to be licensed.
Injection well operators must currently
comply with both state and EPA requirements
although Indiana has the option of
pursuing primacy for UIC at any time in
the future.
30
V. EPA'a UIC PROGRAM FOR INDIANA
All owners and operators in the
State of Indiana are required to comply
with the UIC regulations listed In
40 CFR Parts 124, 144 and 146 In addition
to the Part 147 regulations that pertain
to the particular combination of histori-
cal practices and geology unique to
Indiana.
Maximum injection pressure for the
State of Indiana for wells authorised by
rule is calculated by the use of a
simple formula, baaed on a fracture
gradient measured in psi/ft., to assure
that operations do not Initiate or
propogate fractures in the injection
zone. A fracture gradient of 0.8 psi/ft.
will be used for Indiana. Owners or
operators may apply for and receive
permission to operate at greater pressures
by applying for a permit and demonstrating
that they will not endanger a USDH.
Due to the large number of wells
involved, the area of review for Class II
wells will be based on a 'fixed radius in
order to avoid considerable delay in
program Implementation caused by processln
requests based on many formulae.
All Class I through Class V wells,
with the exception of Class II wells,
associated with oil and gas production,
are currently regulated by the Indiana
State Board of Health in conjunction
with the Indiana Stream Pollution Control
31
-------
Board (SPCB). Class II wells associated
with oil and gam production are regulated
by the Department of Natural Rsources.
In addition, with promulgation of the
federal program, all injection wells
must comply with the Federal UIC
regulation*.
32
MATRIX OF NDIANA STATE AGENCY AUTHORITY
•TATIAOMCV
CLAMI
MMCTAL
•CUnWML
MUAMKN*
0AM •
tTOHAOiWBl
•ALTWATtNMKMAL
•MANGHDNMOWV
CLAM*
CLAM IV
CLAMV
AM CONDmONM MTUNN
(MAN NUNOn> WBL*
OMVWIU*
MCMAMK
-------
APPENDIX A
LIST OF CONTACTS REGARDING UNDERGROUND
INJECTION IN INDIANA BY HELL CLASS
EPA Region V
Ground Water Protection Branch (SWD-12)
230 South Dearborn
Chicago, IL 60604
Mark Vendl (312) 886-6195
Class It
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
Class II:
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
35
-------
Class Hi Associated with oil and gas
production.
Indiana Department of Natural
Resources
911 State Office Building
Indianapolis, IN 46204
Boner Brown (317) 232-4055
Class Hit
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
CUs* IVt
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
t Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
Class V:
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
-------
ATTACHMENT B
Extraction Protocol
Vast* Treatment Results for Inorganics
This attachment tabulates the data used to develop the conclusions in the
report for chemical extraction and soil washing and immobilization of
inorganics. The influent and effluent extraction protocol concentrations
in the wastes are reported, as well as the corresponding reductions in
mobility. The data are sorted by treatability group, technology group, and
contaminant. Not all treatability groups have data for all technology
groups.
-------
ATTAl.
At E
BOAT FOR CONTAMINATED SOIL
Ranked by Reiturt inn in Mobility
For Individual Tr«atnmnt Technologies
Influtint EM! carl - M fluent F.Ml r«.:t
Treat ability Group: H1O
Ptoceaa Group:
MOM-VOLATILE METALS
CHEMICAL EXTRACTION AMD SOIL HASHING
Paqe: |
Data: 01/08/1989
Mobility InfliMat
Ink Reduction Concen (M91)
1
2
3
4
5
f
7
•
9
10
11
12
13
14
15
14
17
19
19
20
21
22
23
24
25
24
27
29
29
30
31
32
33
34
0. 9999312
O. 9979474
0.9957497
O. 9934431
O. 9927757
0.9911757
0.9430597
0.9404477
O. 9550500
0.9541045
0.9442957
0.943920O
0.9392114
0.9344200
0.9290000
0.9245714
0.9209179
0.9109571
O.90597O1
0.9014400
O.9OOOOOO
O. 9974400
O.99744OO
0.9519500
0.9519500
0.9333000
0.9333000
0.9333000
0.9333000
0.7777900
O.72SOOOO
O.704920O
O.700000O
O. 4250000
159.9OOOO
159.90000
90.7OOOO
9O.7000O
9O.70OOO
159.900OO
24.9000O
24.90000
6.99000
24.90000
17.50000
O.9900O
159.90000
0.41OOO
17.50000
17.5000O
90.70000
17.500OO
24.90000
0.41000
O.4000O
0.9900O
0.9900O
0.27000
0.27000
O. 04000
O. 04000
O.O400O
0.0400O
O.2700O
O.4000O
O. 41000
O. 40000
O. 40000
QtU ((fluent Qul
laf Concen (PPM) Eff
41000
94000
150OO
32000
39000
01000
O.99000
1.04000
O.04000
1.23000
0.94000
O.05000
9.98000
0.04000
1.24000
1.32000
4.390OO
1.54000
2.52OOO
O.040OO
O.040OO
O.100OO
O.100OO
O.04OOO
0.040OO
0.010OO
0.01000
O.01000
0.01000
0.04000
O.I 1000
O.I8000
O.120OO
0.150OO
Process Description
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
Contaminant NAMA
COPPER
COPPER
COPPER
COPPER
COPPER
COPPER
NICKEL
NICKEL
COPPER
NICKEL
NICKEL
COPPER
COPPER
COPPER
NICKEL
NICKEL
COPPER
NICKEL
NICKEL
COPPER
NICKEL
COPPER
COPPER
NICKEL
NICKEL
CHROMIUM
CHROMIUM
CHROMIUM
CHROMIUM
NICKEL
NICKEL
COPPER
NICKEL
NICKEL
Media le
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL R
SOIL B
SOIL B
SOIL B
SOIL B
SOU. B
SOU. B
SOIL B
t
Document Number
ORD-TSIrRT-EUOH-
ORD-TSI-RT-EUQN-
ORD-TSI-RT-EUON-
ORD-TS1-RT-EUQN-
ORD-TSI-RT-EUQN-
ORD-TSI-RT-EUON-
ORD-TSI-RT-EUON-
ORD-TSI-RT-EIIOM-
ORD-TSI-RT-EUQM-
ORD-TSI -RT-EUQM-
ORD-TSI-RT-EUON-
ORO-TSI-RT-EUQH-
ORD-TSI-RT-EUOM-
ORD-TSI-RT-EUQN-
ORD-TSI-RT-EUQN-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQH-
ORO-TS1 -RT-EUQH-
ORD-TSI -RT-EUON-
ORD-TSI-RT-EUON-
ORD-TS1-RT-EUQN-
ORD-TS 1 -RT-EUQW-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQM-
ORII-TSI-RT-EUOH-
ORD-TS1-RT-EUOH-
ORD-TSI-RT-EIIQM-
ORD-TSI-RT-EIIQH-
ORD-TSI-RT-eUQN-
ORtl-TSl-RT-EUQW-
ORD-TSl-RT-EHQN-
ORD-TSI-RT-EUQH-
ORO-TSl-RT-EUQW-
ORD-TSI-RT-EUQM-
Test
Hum
52
58
40
3«
41
46
52
58
16
46
41
28
5]
4
34
40
35
35
5]
10
22
22
23
4
10
46
52
53
58
II
23
11
28
16
SOIL - 34 data point*
SLUDGE ISLUD) -
O data points
-------
ATTACHMENT E
BOAT FOR rONTAMINATF.0 SOIL
R«iik»rl l>y R«i|iirt ion in Mobility
For Individual TraalMflnt Tei:hnolfi<|iA)i
Infltinnt. Extract - Effluent. P.x»ia<:l
Treatability Group: M1O
Frocaa* Croupi
NON*VOLATILE METALS
IMMOBILIZATION
Data; 0)/08/|989
nk
1
2
3
4
1
2
a
4
1
2
10
11
12
11
14
1
2
Nobility
Radtiot ion
0.4400000
O.2SOOOOO
0.2000000
0.0700000
•OIL -
0.901 (400
0. 8599400
0.4)51*500
0.30OOOOO
SOIL -
0.999MSO
0.999MSO
0.999*4*4
0.9990909
0.99*4343
0.99*5074
0.99*0243
0.9*95540
0.990OOOO
0.99OOOOO
0.9442900
0.9000000
O.9OOOOOO
O.*9**700
8011, -
0.997142*
0.9«7905*
Influaat On
Canaan <»*•» In
1.00000
l.OOOOO
I.OOOOO
l.OOOOO
4 data point*
0.41000
0.22750
0.27000
0.0500O
4 data point*
•7.OOOOO
•7.OOOOO
74.OOOOO
22.00000
22.OOOOO
24.90000
74.OOOOO
159.9000O
3.SOOOO
3.50000
0.*90OO
O.40OOO
0.400OO
O.*90OO
< data point*
17.500OO
•O.700OO
a* • » •
Concan
0
0
0
O
0
0
O
0
0
O
O
0
0
0
O
1
O
O
0
O
O
0
O
2
•*«»?•«. Ww •
(PPM) Efr Procaaa Dearr l|>t ion
.54000
.75000
.•0000
. 93000
SLUDGC
.04000
.03200
.04000
.03500
SLUDGE
.O1OOO NO
.O1000 NO
.01000 NO
.O2000
.03000
.04000
.15000
.47000
.07000
.O7OOO
.O3000
.04000
.04000
.09000
SLUDGE
.05000
.59000
STABILIZATION
STABILIZATION
STAB II.
IZATION
STABILIZATION
(SLUO) -
CEMENT
CEMENT
CEMENT
CEMENT
(SLUD) -
FLVASH
ri.YASH
FLYASH
rLYASH
FLVASH
FLYASH
FLYASH
FLYASH
FLYASH
FLYASH
rLYASH
rLYASH
rLYASH
rLYASH
(SLUD) -
Cont aminocu««nt NiMbar Hum
980-TSI-RT-rCAK-I 1
980-TSI-RT-FCAK-l I
980-TSI-RT-FCAK-l |
980-TSl-RT-FCAK-l 1
0 data point*
SOLIOiriCATIO
SOLIDiriCATIO
SOLIDIFICATIO
SOLIDIFICATIO
COPPER
COPPER
NICKEL
CHROMIUM
SOIL
SOIL
SOIL
SOIL
B
B
B
B
ORO-TSI-RT-FHMF-1 I
980-TSI-RT-EUXT-l 1
ORD-TSI-RT-FHMF-I 1
980-TSI-RT-EUXT-l I
O data pointa
SOLIOIFICATIO
SOLIDIFICATIO
SOLIDIFICATIO
SOLIOiriCATIO
SOLIOiriCATIO
SOLIDiriCATIO
SOLIOiriCATIO
SOLIOiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIOiriCATIO
SOLIOiriCATIO
SOLIOiriCATIO
SOLIOiriCATIO
NICKEL
NICKEL
NICKEL
CHROMIUM
CHROMIUM
NICKEL
NICKEL
COPPER
CHROMIUM
CHROMIUM
COPPER
NICKEL
NICKEL
COPPER
SLUD
SMJD
SLUD
SLUO
SLUD
SOIL
SLUD
SOIL
SLUD
SLUD
SOIL
SOIL
SOIL
SOIL
P
P
P
P
P
B
P
B
P
P
B
B
B
B
980-TS1-RT-FAAP-
980-TSI-RT-FAAP-
980-TSI-RT-FAAP-
980-TSl-RT-FAAP-
980-TSI-RT-FAAP-
ORO-TSI-RT-FHMF-
980-TSl-RT-FAAP-
ORD-TSI-RT-FHMF-
980-TSI-RT-FAAP-
980yfsl-RT-FAAP-
ORD-TSI-RT-FHMF-
QRO-TSI-RT-FHMF-
ORD-TSI-RT-FHMF-
ORD-TSI-RT-FHMF-
I
1
2
I
1
2
2
2
2
2
5
4
b
*
8 data pointa
CARBONATE IMHOBILIZA
CARBONATE IMHOBILIZA
NICKEL
COPPER
SOIL
SOIL
B
B
ORO-TSI-RT-FHMF-1 3
OHD-TSI-RT-FHMF-1 1
SOIL -
2 data pointa
SLUDGE (SI.UD) -
0 data pointa
-------
ATTACHMENT E
BOAT FOR CONTAMINATED SOU.
Ranked hy Redm:t ion in MnMllty
For Individual TrAAlm^ut Tnrhnnlotj |«
Influent E>tiact - Kfflumit Eitiacl
Treatability Group: Mil
Proceaa Group:
VOLATILE METALS
CHEMICAL EXTRACTIOH AND SOIL MASHING
ft alt,-. 01/08/1989
Knk
Nobility InflttMt
ReduotIon Cono««
Qwl Effluent Oul
I«f Concen (PPM) Eff
Proceaa DaacrlptIon
Contaminant NAM
Media le
1
2
3
4
5
f
7
f
9
10
11
12
13
14
15
1C
17
18
19
20
21
22
23
24
25
2*
27
20
29
30
31
32
33
34
3*
37
30
39
40
41
0.9950204
0.9943102
0.9920977
0.9924*57
0.9712329
0.9*70002
0.9509000
0.954107*
0.940*301
0.9350453
0.9340011
0.9315000
0.9315000
O. 9252441
0.9217120
0.921*080
0.9155*07
0.9142000
0.9139200
O. 907*090
0.9043400
O.9O4110O
0.9021740
0.9010790
0.0990430
0.0907470
0.09*4305
0.092*497
0.0091230
0.0711297
0.0*54150
0.0*2039*
0.0*05300
0.0524407
0.05O4532
O.043O595
O.000C2CO
O. 0002021
0.7057100
0.7057100
0.7057100
70.400OO
70.4000O
7O.4OOOO
14.COOOO
I4.COOOO
14.COOOO
0.73000
35.30000
14.COOOO
33.10000
70.40000
O. 7 3000
0.73000
350 . 50000
9.50000
19.90000
35 . 30000
0.70000
. 39000
.20000
.20OOO
.7300O
.20000
.50000
. 39000
.50000
395.90000
395.90000
33.1OOOO
3S0.SOOOO
«. 39000
35.30000
359.50000
350.5OOOO
33.10000
35.30000
9.59000
395.90000
0 . 70000
O.7000O
0.7OOOO
0 . 3SOOO
0.40000
0 . 50000
O.I 1000
O.4200O
0.47OOO
O.O3000
1.C200O
0.7SOOO
2.15000
4.59000
O.0500O
0.0500O
26.8000O
0.75000
1.5*000
2.9900O
0.0*000
0.5500O
0.0500O
0.0000O
O.0700O
O . 9000O
0.94000
0.44000
0.9700O
41.OOOOO
42.5000O
3.C7000
4*. 20000
O.0COOO
4.0700O
50.00000
52.90000
4.95000
5.54000
1.91000
79.1OOOO
0.15000
O.I500O
O.I 5000
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL NASH INC
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
•OIL MASHING
•OIL MASHING
•OIL MASHING
•OIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
. SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
LEAD
LEAD
LEAD
ZINC
ZINC
ZINC
CADMIUM
CADMIUM
ZINC
CADMIUM
LEAD
CADMIUM
CADMIUM
ZINC '
ARSENIC
LEAD
CADMIUM
LEAD
ARSENIC
ZINC
ZINC
CADMIUM
ZINC
ARSENIC
ARSENIC
ARSENIC
ZINC
ZINC
CADMIUM
ZINC
ARSENIC
CADMIUM
ZINC
ZINC
CADMIUM
CADMIUM
ARSENIC
ZINC
LEAD
LEAD
LEAD
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOU. B
SOU. B
SOU. B
SOU. B
SOU. B
SOU. B
OBD-TSI-RT-EUQM-
ORD-TSI-RT-EUQN-
ORD-TSI-RT-EUOM-
ORD-TSI-RT-EUQN-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQN-
ORD-TSl-RT-EUOM-
ORO-TSl-RTrEUQN-
ORD-TSI-RT-EUOH-
ORD-TSl-RT-EUQN-
ORD-TSl-RT-EUON-
ORD-TSI-RT-EUQN-
ORD-TSl -RT-EUQ.M-
ORD-TSI-RT-EUQN-
ORD-TS1 -RT-EUQN-
OAD-TSI-RT-EUON-
ORD-TSI-RT-EUQM-
ORD-TS1-RT-EUO.N-
ORD-TSI-RT-EUQN-
ORD-TSl-RT-EUQM-
ORD-TSI-RT-EUQN-
ORD-TSI-RT-EUQM-
ORO-TSI-RT-EUQN-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUON-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQM-
ORD-TS1-RT-EUQN-
ORD-TS1-RT-EUQM-
ORD-TS1-RT-EOQN-
ORD-TSl-RT-EUQM-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQM-
ORD-TSI-RT-EUQN-
ORD-TS|-RT-EI»OMr
ORO-TSI-RT-EUQH-
0«n-TSl-RT-EIIOtl-
.4 ...
46
52
50
28
22
1*
20
52
23
41
53
22
23
41
52
41
46
16
41
10
4
1C
11
4*
40
58
52
58
40
40
34
58
34
35
34
51
51
46
22
23
28
-------
Tr«.t«blllty Group,
Prdc*** Groups
Mil
VOLATILE METALS
CHEMICAL EXTRACTION AND SOIL MASHING
ATTACHMENT E
BOAT FOR CONTAMINATED SO||.
Ranked by Radnor inn in Mobility
For Individual Ti~*t*niit T«rhnn|<>q|*9
Influent Evtiant - effluent Ext tact
feik
42
43
44
45
4(
47
4*
4*
SO
SI
S2
53
54
Mobility Influ««t Qul Effluent C
••duct Ion Conoen <»tM) Imt Concen (PPM) ft
0.7735*00 0.91000 0.12000
0.7(4(525 11.10000 7.79000
0.73S17S9 1*.*0000 5. 27000
0.72(1140 (.39000 1.75000
O.7KMOO 0.530OO 0.15000
o.(*3**oo 0.4*000 o.isooo
O.O3MOO 0.4*000 O.ISOOO
0.(*3MOO 0.49OOO O.ISOOO
0. (7537(9 19.90000 (.4(000
0.(((((OO O.ISOOO O. 05000
O.(54205( 395.90000 13(. 90000
O. 5094 300 O.S300O 0.2(000
O. 4135(7* 19.90000 11. (7000
SOIL - " -•-•*-
lul
Iff Proceas Deacriptinn Contaminant Name
SOIL MASHING
SOIL MASHING
SOIL HASHING
SOIL HASHING
SOIL MASHING
SOIL HASHING
SOIL HASHING
SOIL HASHING
SOIL NASH ING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
CAOHIUH
CADMIUM
LEAD
ARSENIC
CADMIUM
LEAD
LEAD
LEAD
LEAD
ARSENIC
ZINC
CADMIUM
LEAD
data point.
SLUOG. JSLUO, -
Media
SOIL B
SOIL B
SOIL B
SOIL B
SOIL
SOIL
SOIL
SOIL B
SOIL B
SOIL B
SOIL B
S0||. B
SOU. B
ORD-TSI
ORD-TSI
B
B
B
0»D-TS|
HT-EUQM-I
-»T-EUOW-|
-RT-EUQW-I
-RT-EUQM-1
ORD-TSI
ORO-TSI
ORO-TS1
ORO-TSI
-RT-eOQW-
-BT-EOQW-
-HT-EOUH-
-RT-B,|O|(.
ORO-TSI-
ORI»-TSI-
BT-EIIOM-
RT-ei,0((.
10
35
40
35
4
4
10
11
34
10
5)
11
35
-------
ATTACHMENT E
Testability Group: Mil
Proca** Croup:
VOLATILE METALS
IMMOBILISATION
FOR CONTAMINATED sou.
Ranked t>y R*dii<:( ion In Mobility
For Individual Tiaatntant Trrhno|<>.)|*9
Influent Entrant - Kffluiiit Extract
Page: 5
Data: 01/08/1989
Ink
1
2
3
4
5
•
7
(
9
10
11
12
13
14
1
2
3
4
5
• 4
1
2
3
4
5
f
7
9
1O
Mobility
ftaduction
0.999*224
0.9997742
0.9995141
0.9993*45
0.99*9*99
0.99*9*99
0.99*7730
0.99*5490
0.9950920
0.9901*40
0.94*9790
0.94*9790
0.7959100
0.4324530
SOIL -
0.9994***
0.99*7204
O.9II13OO
0.9745000
0.9447390
0.493*800
•OIL -
.9997147
.99*4301
.9904774
.9*43000
.9*43000
.971*140
0.9445753
0.7*57100
0.4940227
0.4714300
Inflwaat Qu
Concaa (MM) !•
4200.000OO
4200.00000
4200.00000
14.30000
59.40000
59.40000
14.30000
59.40000
1 4.30000
14.30000
9.COOOO
9.90000
9.*0000
9.90000
14 data point*
123.70000
12.11500
O. 5 3000
O.0170O
9.200OO
O.49OOO
« data point*
35 . 30000
14.40000
395.90000
0.73000
O. 7 3000
9.5*000
14.40000
0.7OOOO
7O. 40000
O.7OOOO
Effluent Qu
Concan (PPM) Ef
1 . 10OOO
1 . 40000
3.00000
O.OIOOO
O. 04000 NO
0.04OOO NO
O.0200O
O. 08500
O.OIOOO
O.I 4000
O.SOOOO
O. 50000
2.00000
3.40000
SLUDGE
0.03*50
O.OI55O
O.OIOOO
O. 00040
0.49000
O.I 5000
SLUDGE
0.01000
O. 02000
3.77000
O.OIOOO
O.OIOOO
0.27000
0.78000
0.15000
21.40000
0.37000
1
f Piocea* Description Contaminant Nam*
STABILISATION LEAD
STABILISATION • LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILISATION LEAD
STABILIZATION LEAD
ISLUD) - 0 data point*
•CEMENT SOLIDIFICATIO SINC
CEMENT SOLIDIFICATIO LEAD
CEMENT SOLIDIFICATIO C ADM MM
CEMENT SOLIDIFICATIO CADMIUM
CEMENT SOLIDiriCATIO SINC
CEMENT SOLIDIFICATIO LEAD
ISLUO) - O data point*
FLYASH SOLIDIFICATIO CADMIUM
FLYASH SOLIDIFICATIO SINC
FLYASH SOLIDIFICATIO SINC
FLVASH SOLIDIFICATIO CADMIUM
FLVASH SOLIDIFICATIO CADMIUM
FLYASH SOLIDIFICATIO ARSENIC
FLVASH SOLIDIFICATIO SINC
FLVASH SOLIDIFICATIO LEAD
FLVASH SOLIDIFICATIO LEAD
FLVASH SOLIDIFICATIO LEAD •
Sea
Media I*
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOU. B
SOIL B
SOIL B
SOIL B
SOU. B
SOU. B
SOIL B
SOU. B
SOIL B
SOIL B
SOU. B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOIL B
SOU. H
Document Number
9HO-TSI-RT-FCAK-2
9BO-TSI-RT-FCAK-2
980-TSi-RT-FCAK-
980-TSI-RT-FCAK-
980-TSI-RT-EURY-
980-TSI-RT-EORV-
980-TSI-RT-FCAK-
980-TSI-RT-EURV-
98O-TS1-RT-FCAK-
980-TS1-RT-FCAK-
980-TSI-RT-FCAK-
980-TSI-RT-FCAK-
980-TSI-RT-FCAK-
980-TSI-RT-FCAK-
980-TSI-RT-EUXT-
980-TSI-RT-EUXT-
ORO-TSI -RT-FHHF-
980-TSI-HT-EUXT-
ORO-TSI-RT-FHMF-
ORD-TSI-RT-FHMF-
ORD-TSI-RT-FHMF-
ORD-TSl-RT-FHMF-
ORD-TSl-RT-FHMF-
ORD-TSl-HT-FHMF-
ORD-TSI-HT-FHMF-
ORD-TSl-RT-FHMF-
ORn-TSl-RTrFIIMF-
ORD-TSl-RT-FHMF-
ORD-TSl-RT-FHMF-
OBD-TSl-RT-FHMF-
Teat
Hum
t a»a»*i
2
5
2
4
5
2
4
5
2
4
SOIL - 10 data point*
SLUDGE (SLUD) -
0 data point*
-------
£~:::;lcx?roup! "M ~"« «««
P IMMOBILIZATION
ATTACHMENT E
BOAT FOB rONTAHINATF.O SOU,
gankr.l hy ftrdm-t Inn in MoMlity
For Individual Tr««tMont Tnolm
Influent F.xt.iact - F.I fluent K
«•••: 01/08/198,
0.90092(1
0.07«3690
0.02000
3.97000
0.79000
80"--
point.
S:
3
)
3
-------