United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-91/162
June 1991
Superfund
Record of Decision:
Northside Sanitary Landfill
(Enviro-Chem) (Amendment),
IN
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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R05-91/162
4. ' wd Subtitle
ERFUND RECORD OF DECISION
Northside Sanitary Landfill (Enviro-Chem) , IN
First Remedial Action (Amendment) - Final
7. Author!*)
8. Performing Organization Name and AddraM
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient1* Accession No.
S. Report Date
07/31/91
6.
8. Performing Organization RepL No.
10. Pro|ect/Tssk/Work Unit No.
11. Contnct(C) or Grant(G) No.
(C)
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EPA/ROD/R05-91/162
Northside Sanitary Landfill (Enviro-Chem), IN
F'^st Remedial Action (Amendment) - Final
Aostract (Continued)
problems, acceptance of unapproved waste, and deficiencies in its closure, post-closure
and ground water assessment plans. The State then ordered NSL to perform several
remedial measures including installing a functioning leachate collection system around
the entire perimeter of the landfill, installing a slurry wall or another measure to
prevent ground water migration, monitoring ground water, and to discontinue acceptance
of solid waste except for that amount needed to adequately contour the site. A 1987
ROD provided a combined remedy for both the NSL and Enviro-Chem sites due to their
proximity and other similarities. The 1987 ROD addressed source control capping;
pumping and onsite treatment of ground water; and implementing deed and access
restrictions. Since the signing of the ROD, EPA and the State have been engaged in
negotiations with the PRPs for each site. These negotiations have resulted in
separate, complimentary remedies and individual consent decrees for each site, and
modifications to the original selected remedy. This ROD amendment provides a
comprehensive remedy and addresses both source control and ground water remediation.
The primary contaminants of concern affecting the soil and ground water are VOCs
including benzene, PCE, TCE, and toluene; other organics including phenols; metals
including arsenic, chromium, and lead; and oils.
The amended remedial action for this site includes constructing a pipeline to pump
ground water and leachate offsite to the city sewer system at the city wastewater
treatment plant and constructing a hydraulic isolation wall system south and west of
NSL to prevent uncontaminated ground water from entering the ground water leachate
collection trench. If for any reason the city treatment plant cannot be used, this ROD
idment provides a contingency for onsite treatment of ground water followed by
c j.te discharge to surface water as specified in the 1987 ROD; treatment at another
wastewater treatment plant; or another alternative consistent with the Clean Water Act.
Other remedial actions documented in the 1987 ROD including constructing a RCRA cap and
gas venting system; collecting leachate and ground water in a trench system; monitoring
ground water, surface water, and leachate; and implementing site access restrictions
are not affected by this amendment. The estimated present worth cost for this remedial
action ranges from $25,000,000 to $30,000,000. No O&M costs were provided for this
remedial action.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water and leachate clean-up
goals are based on Federal Ambient Water Quality Criteria (WQC) and State Water Quality
Standards (WQS), and include arsenic 0.0175 ug/1 (WQS), benzene 40 ug/1 (WQS), chromium
11 ug/1 (WQS), lead 10 ug/1 (WQS), PCE 8.85 ug/1 (WQS), phenols 570 ug/1 (WQC),
TCE 80.7 ug/1 (WQS), and toluene 3,400 ug/1 (WQC).
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Declaration for the Record of Decision Amendment
Bite Name and Location
Northside Sanitary Landfill, Zionsville, Indiana
Statement of Basis and Purpose
This decision document, together with a Record of Decision dated
September 25, 1987, represents the selected remedial action for the
Northside Sanitary Landfill developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), as amended by the Superfund Amendments and
Keauthorization Act of 1986 (SARA), and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP).
This decision is based on the contents of the administrative record
for the Northside Sanitary Landfill site. The attached index
identifies the items which comprise the administrative record upon
which the decision to amend the 1987 Record of Decision, and the
selection of the modified remedial action is based.
The State of Indiana concurs in the remedy selected by U.S. EPA for
the Northside Sanitary Landfill site.
Description of the Remedy
The primary reason for amending the 1987 Record of Decision is to
reflect the decision to implement separate, complementary remedies
for the Environmental Conservation and Chemical Corporation and
Northside Sanitary Landfill sites, instead of the one combined
remedy selected in the 1987 Record of Decision, and secondarily, to
modify the selected remedy.
For the Northside Sanitary Landfill site, the major components of
the remedial action as modified, include:
- Access restrictions
- RCRA Subtitle C cap and gas venting system
- Hydraulic isolation wall south and west of NSL and north
of Finley Creek
- Leachate collection trench north, northwest and east of NSL
- Combined ground-water and leachate collection trench south
and southwest of NSL
- Pipeline to the Indianapolis Department of Public Works
sewer system, and treatment of the ground-water and leachate
at the Indianapolis publicly-owned treatment works (POTW) or
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elsewhere in the event that the POTW is unavailable
- Ground-water, surface-water, and leachate monitoring
program.
Declaration
The selected remedy, as modified herein, is protective of human
health and the environment, attains Federal and State requirements
that are applicable or relevant and appropriate to this remedial
action, and is cost-effective.
This remedy satisfies the statutory preference for remedies that
employ treatment, that reduce toxicity, mobility or volume as a
principal element, and utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining
on-site, pursuant to Section 121(c) of CERCLA, a review will be
conducted at the site within five years after commencement of the
remedial action and at least every five years thereafter to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
Date ^ \
_ s/V. Adamkus
Regio^nal Administrator
Region V
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Record of Decision Amendment
Northside Sanitary Landfill
I. LOCATION AND DESCRIPTION
The Northside Sanitary Landfill (NSL) and the Environmental
Conservation and Chemical Corporation (also referred to as Enviro-
Chem, or ECC) facilities are both on the Superfund National
Priorities List, and are located adjacent to each other. On
September 25, 1987, a Record of Decision (ROD) was signed which
selected a combined remedy for the two sites. Since the time the
original ROD was signed, U. S. EPA and the State of Indiana have
engaged in negotiations with Potentially Responsible Parties (PRPs)
for each site. These negotiations have resulted in separate
remedies for each site, individual Consent Decrees for each site,
and this amendment to the 1987 ROD. The purpose of this ROD
Amendment is to describe the changes from the remedy selected in
the 1987 ROD, as they pertain to NSL.
The NSL site is located in a rural area of Boone County, about five
miles north of Zionsville and ten miles northwest of Indianapolis.
Farmland borders the southern and eastern edge of NSL. Residential
properties are located to the north and west, within one-half mile
of the facility. A small residential community, Northfield, is
located north of the site on U. S. 421. Approximately fifty
residences are located within one mile of the site.
An unnamed ditch runs north to south between the NSL and ECC sites,
along the western edge of NSL, and joins Finley Creek at the
southwestern corner of the NSL landfill. Finley Creek runs along
the eastern and southern edges of the NSL site and flows into Eagle
Creek about one-half mile downstream from the sites. Eagle Creek
flows south from its confluence with Finley Creek for ten miles
before it empties into Eagle Creek Reservoir. The reservoir
supplies approximately six percent of the drinking water for the
City of Indianapolis.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The 1987 ROD sets forth a summary of the history of NSL, through
the time of its issuance. Since the ROD was issued, the following
activities of pertinence have occurred.
1. NSL took an appeal to the February 1987 administrative order
issued by the Solid Waste Management Board (SWMB). Though the
State trial court affirmed the administrative order, its effect
has been stayed pending NSL's further appeal to the Indiana State
Appellate Court. As a result, NSL has continued to receive waste
and to operate as a solid waste landfill. Consequently, the
contours and dimensions of the landfill are now different from
those which existed at the time the 1987 ROD was issued.
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2. NSL's challenge to its inclusion on the National Priorities
List was denied by the United States Supreme Court in March 1989.
3. In February 1988, U.S. EPA filed a complaint in the United
States District Court for the Southern District of Indiana which
sought to enjoin NSL from denying, restricting or impeding entry
and access to the landfill for the purposes of taking response
actions under CERCLA. Specifically, U.S. EPA moved the Court to
enjoin the defendants from further landfilling operations at the
Northside Sanitary Landfill. In April, 1988, the Court denied U.S.
EPA's motion, though the action remains pending.
4. As a result of the testing of soils from an uncontaminated area
conducted as a part of the predesign studies, U.S. EPA found that
the clay till, general fill material, and top soil from said area
would be suitable for use in the construction and maintenance of
the landfill cap.
5. In February 1988, a group of potentially responsible parties
(PRPs) who sent or transported hazardous substances to NSL offered
to perform a portion of the 1987 ROD selected remedy. After
lengthy negotiations, U.S. EPA, the State of Indiana, and this
group of PRPs have reached a tentative agreement concerning a
remedy to be implemented at NSL, as described in this Amendment,
and as more fully set forth in a Consent Decree and Statement of
Work included in the Administrative Record.
6. The PRPs propose to use the Indianapolis wastewater treatment
plant, instead of an onsite treatment plant, to treat contaminated
ground water and leachate from NSL. This amendment to the ROD
approves this alternative for the following reasons. First, a
careful analysis of Indianapolis' ordinance regulating discharges
to public sewers, and the chemical analysis of leachate samples
from NSL collected in February 1988 have revealed that pretreatment
would not be necessary. Second, the sewer connection moratorium
for the northern part of Marion County into the Belmont Wastewater
Treatment Plant was lifted in September, 1987. Third, an analysis
of Indianapolis' "Mass Flow Monitoring Study" has revealed that
surcharges and overflows will not be a problem.
III. COMMUNITY RELATIONS
This ROD Amendment, as proposed, was available for public comment
for a thirty day period, pursuant to Section 117 of CERCLA. An
Administrative Record containing documents of relevance to this
Amendment has been available at the Zionsville Town Hall and at the
offices of Region V, U.S. EPA in Chicago.
IV. DOCUMENTATION OF SIGNIFICANT CHANGES
This ROD Amendment addresses those elements of the remedy which
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have changed from the 1987 ROD and the requirements and preferences
under SARA. Many elements of the original 1987 ROD do not change.
Therefore, the findings made in the 1987 ROD remain the same except
for the changes described in this ROD Amendment.
The major differences between the remedy selected in the 1987 ROD
for NSL and the remedy selected in this Amendment are as follows:
1. This Amendment to the ROD provides for separate remedies
for NSL and ECC, instead of the combined remedy selected in
the 1987 ROD.
2. This Amendment approves construction of a pipeline to
the Indianapolis sewer system so that treatment of
contaminated ground water and leachate can be done at
the City of Indianapolis' wastewater treatment plant.
If the plant cannot be used for any reason, the ROD
Amendment retains as contingencies an on-site treatment
plant and discharge to Finley Creek pursuant to an NPDES
permit, as selected in the 1987 ROD; or use of another
available wastewater treatment plant; or some other
alternative consistent with the Clean Water Act.
3. To minimize uncontaminated ground water from entering
the collection trench, a hydraulic isolation system
will be constructed downgradient of the collection
system, as provided in this ROD Amendment. The 1987 ROD
remedy provided for the same goal to be accomplished
through different construction details of the trench
itself. This modification will be just as effective.
4. The 1987 ROD called for the rerouting of surface waters
to reduce the potential for contaminant movement to
surface water. The hydraulic isolation system selected
in this ROD Amendment makes this task unnecessary.
5. This Amendment adds ammonia and chloride, as shown
in Attachment 1, to the list of contaminants set forth
on Table 1 of the 1987 ROD. This remedy, as
amended, is intended to prevent ammonia and chloride from
being discharged into Finley Creek at levels above those set
forth.
6. This Amendment concludes that uncontaminated clay till,
general fill material, and top soil located in the
borrow area, which was investigated as a part of the
predesign studies, are suitable for use in constructing
and maintaining the landfill cap.
The second item above was evaluated in the Feasibility Study for
NSL, but was not selected in the 1987 ROD. However, due to changed
conditions at the Indianapolis wastewater treatment plant,
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specifically the condition of the receiving sewers, and the
determination by the Indianapolis Department of Public Works that
pretreatment of NSL contaminated ground water and leachate is not
needed, the pipeline alternative has become more cost-effective.
Key portions of the remedy which remain the same from the 1987 ROD
are summarized below:
- Access restrictions remain part of the remedy.
- A RCRA-performance cap and gas venting system will be
constructed over the landfill to prevent direct contact,
and to minimize infiltration.
- Contaminated leachate and ground water will be collected
in a trench system.
Ground-water, surface-water and leachate monitoring
remain part of the remedy.
This ROD Amendment selects separate and distinct remedies for NSL
and ECC. During the design phase for each remedy, however, efforts
will be made to ensure that the two remedies will be compatible
with each other.
SUMMARY
NORTHSIDE SANITARY LANDFILL
DIFFERENCES BETWEEN 1987 REMEDY AND REMEDY. AS MODIFIED
1987 REMEDY
Combined remedy for NSL
On-site treatment plant to
treat contaminated ground
water and leachate and dis-
charge to Finley Creek pur-
suant to NPDES permit
MODIFIED REMEDY
Separate, compatible
remedies for ECC
and NSL
Pipeline to convey con-
taminated ground water
and leachate to the City
of Indianapolis' sewer
system
Impermeable barrier along
the downgradient side of the
collection trench to minimize
inflow of water from the creek
27 contaminants to be mon-
itored for
Construction of hydraulic
isolation barrier in same
general location
29 contaminants to be mon-
itored for
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Table 1 is a summary comparison of the 1987 ROD remedy and the
remedy, as modified herein, relative to the Agency's nine
evaluation criteria. Figure 1 shows some components of the
remedial action selected in this ROD Amendment. The technical
attachment to the Consent Decree, called the Statement of Work,
which is in the Administrative Record, provides more details
regarding the remedial action selected in this ROD Amendment.
VI. STATUTORY DETERMINATIONS
U.S. EPA has determined, and the Indiana Department of
Environmental Management concurs, that the modified remedy selected
herein satisfies the statutory requirements specified in Section
121 of SARA: to protect human health and the environment; to
attain ARARs; and to utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Protection of Human Health and the Environment
Because the modified remedy embodies the same basic remedial
technologies that comprised the 1987 remedy - an impermeable cap
and ground water collection and treatment - the modified remedy
remains protective of human health and the environment.
Attainment of Applicable, or Relevant and Appropriate Requirements
Section 121(d) of SARA requires that remedial actions meet legally
applicable or relevant and appropriate requirements (ARARs) of
other environmental laws. These laws may include: the Resource
Conservation and Recovery Act (RCRA), the Clean Water Act (CWA),
the Safe Drinking Water Act (SDWA), the Clean Air Act (CAA), the
Toxic Substances Control Act (TSCA), and in some cases State law.
A "legally applicable" requirement is one which would legally apply
to the response action if that action were not taken pursuant to
Section 104 or Section 106 of CERCLA. A "relevant and appropriate"
requirement is one that, while not legally applicable to the
remedial action, addresses problems or situations sufficiently
similar to those encountered at the site that their use is well
suited to the remedial action.
The ARARs that were identified in the 1987 ROD remain the ARARs for
the modified remedy, with one change. That change concerns the
method for treatment of collected ground water and leachate.
Because the 1987 ROD called for an on-site treatment plant, the
discharge of treated effluent from that plant to Finley Creek would
have been regulated through the National Pollutant Discharge
Elimination System under the Clean Water Act. The modified remedy
approves use of a pipeline to carry contaminated ground water and
leachate to the City of Indianapolis' sewer system and treatment by
its wastewater treatment plant. As a consequence the national
pretreatment program under the Clean Water Act becomes an ARAR for
the discharge of NSL effluent to the City sewer system. The City's
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sewer use ordinance which sets forth an approved pretreatment
program will also apply to the NSL effluent.
Cost-Effectiveness
The modified remedy is as protective, offers greater long term
effectiveness and is more cost effective than the 1987 ROD selected
remedy. The capital outlay to construct a pipeline from the
facility to the IDPW sewer system is less than that required to
construct an onsite treatment plant. Likewise, the operation and
maintenance costs associated with the former method are less than
those required for the latter.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable, and Preference for
Treatment as a Principal Element
As discussed in the 1987 ROD, treatment of NSL refuse would be
nearly impossible because of the variety of materials, large
volume, and resulting high cost.
VI. Future Actions
The Remedial Design schedule is as follows:
Submittal of a Work Plan for Supplemental Investigations
10 weeks after work initiation;
Submittal of the Preliminary (30%) RD Report 30 weeks
after work initiation;
Submittal of the optional Intermediate (60%) RD Report 10
weeks after receiving EPA approval of the Preliminary RD
Report;
Submittal of the Prefinal (95%) RD Report 22 weeks after
receiving EPA approval of the Preliminary RD Report or 12
weeks after approval of the optional Intermediate RD
Report; and
- Submittal of the Final (100%) RD Report 6 weeks after
receiving EPA approval of the Prefinal Report.
The Remedial Action schedule will be developed and submitted for
approval as part of the RD report.
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TABLE 1
NORTHSIDE SANITARY LANDFILL
COMPARISON OF EVALUATION CRITERIA
1987 REMEDY
MODIFIED REMEDY
Protection of
human health and
the environment
Compliance with
ARARs
Long-term
Effectiveness
Reduction in
Toxicity, Mo-
bility and Volume
Short-term
Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Surface water pro-
tected by ground
water collection
Compliance with off-
site ARARs (Accep-
table Stream
Criteria)
Less certain, due to
need to operate and
maintain onsite
treatment plant for
a significant period
of time
Slow reduction in
volume of contam-
inants from ground
water collection
Little site distur-
bance; little chance
of releases during
construction
Long-term operation
and maintenance re-
quired
$30.9 million
Full acceptance
Full acceptance
Surface water pro-
tected by ground
water collection
and slurry wall
Compliance with
off-site ARARs
(Acceptable Stream
Criteria), plus
remedial standards
for ammonia and
chloride
Less maintenance
required due to
use of City waste-
water treatment
plant
Same as 1987 ROD
Same as 1987 ROD
Same as 1987 ROD
$25 to $30 Million
Full acceptance
Acceptance in-
dicated
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GERAGHTY& MILLER
ENGINEERS, INC.
TABLE 2
(Page 1 of 2)
Standards for Ground Water and Leachate
Statement of Work
NSL Remediation Committee
Zionsville. Indiana
Remedial Standard
Constituent (ug/L) Reference
1, 1, 1-Trichloroethane
1,1, 2-Trichloroethane
Chloroform
Benzene
Ethylbenzene
Methylene Chloride
1 , 1-Dichloroethene
Trichloroethene
Tetrachloroethene
Toluene
Phenol
4-Chloro-3-methyl phenol
Bis (2-ethylhexyl) phthalate
Vinyl chloride
1 , 2-Dichloroethane
Di-n-butyl phthalate
Diethyl phthalate
Dimethyl phthalate
Naphthalene
Arsenic
Chromium (VI)
5280
41.8
15.7
40
3280
15.7
5
80.7
» 8.85
3400
570
1
50,000
525
243
154,000
52,000
33,000
620
0.0175
11
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A - Selected stream criteria in Table 1 of the USEPA Record of Decision,
Environmental Conservation and Chemical Corporation and Northside
Sanitary landfill Sites, Zionsville, Indiana, September 25, 1987.
B - Constituents added by the IDEM with associated values.
Attachment 1
2-24
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^GERAGHTY & MILLER
ENGINEERS, INC.
TABLE 2
(Page 2 of 2)
for Ground Wa^T- *"d Leachate
Statement of Work
NSL Remediation Committee
Zionsville. Indiana
Constituent
standard
(U3/L)
Reference
Copper
Cyanide
Iron
Lead
Nickel
Zinc
Ammonia
Chloride
26
5.2
1000
10
100
47
1,140 (Summer)
1,640 (Winter)
* 230,000
: A
A
A
A
A
A
B
B
B
A - Selected stream criteria in Table 1 of the USEPA Record of Decision,
Environmental Conservation ; and Chemical Corporation and Northside
Sanitary Landfill Sites, Zionsville, Indiana, September 25, 1987.
B - Constituents added by the IDEM with associated values.
FL0060. GC1\TBL\NEWTBL2.2
Attachment 1 (continued)
2-25
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HYDRAULIC
ISOLATION
SYSTEM
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(LMTED ACCESS)
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(IS
REMEDIAL ACTION
PLAN
STATEMENT OF WORK
NSL REMEDIATION COMMITTEE
ZIONSVILLE, INDIANA
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NORTHSIDE SANITARY LANDFILL
SUPERFUND SITE
ZICHSVILLE, INDIANA
RESPCKBIVENESS SUMMARY
June 24, 1991
I. R£3tOMSa.vcznc2iS SUMMARY OVERVIEW
In accordance with CERCLA Section 117, a public comment period was held from
May 20, 1991 to June 18, 1991, to allow interested parties to cement on the
United States Environmental Protection Agency's (EPA's) proposed Record of
Decision (PCD) amendment for the Northside Sanitary landfill Superfund site.
At a May 30, 1991 public meeting, EPA and Indiana Department of Environmental
Management (IDEM) officials presented the ROD amendment for the Northside
site, answered questions and solicited comments from the public. One written
comment was received through the mail.
ZI. BACKCTOUND OP COMMUNITY OUNUUtN
Because of the proximity of Northside Sanitary landfill and the adjacent
Enviro-Chem site, the history of community concerns reflects both sites.
Concerns focused on air and water quality, especially as they relate to public
health, and the timeline for the closure of Northside.
A toxic oil spill in mid-1989, caused by vandals and believed to come from
tanks stored on neighboring Great Lakes Asphalt Company property, caused
intensified public concern about the effects of site-related contaminants in
the community. At the time, it was believed the spill could have some effect
on the Eagle Creek Reservoir, from which part of Indianapolis draws drinking
water. The spill was cleaned up under EPA's emergency authorities.
Ongoing concerns focus on implementation of the remedy (for instance, where
the sewer pipeline will be placed) and liability of the owners/operators.
III. SUMMARY OF SIOTEFICANT COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES
One written comment was received from a local resident; the letter is
attached. The resident expressed concern that any contaminated leachate will
not be separated and treated before being commingled with domestic effluent
when discharged to the Indianapolis wastewater treatment system. The resident
believes that Indianapolis cannot handle the type of waste it will receive
from Northside, resulting in a situation where contaminants will enter the
White River.
EPA's response: Allowing contaminated leachate and ground water from
Northside to be treated by the Indianapolis wastewater treatment system was
carefully and thoroughly examined. The Administrative Record contains a great
deal of information on this subject, some of which was prepared by EPA's
contractor, and some of which was submitted to us by the City of Indianapolis.
We examined the requirements for discharges into the City of Indianapolis
wastewater collection and treatment system. Chemical analysis of leachate
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samples from Northside collected in February 1988 indicates that all
contaminant concentrations are low enough that pretreatment prior to discharge
to public sewers is not required (see Record of Decision Amendment
Administrative Index, documents 1-4, 6, 9, 12, 13, 15, 17, 21, 22). We
believe that the Indianapolis treatment plant can effectively remove the
contaminants from Northside leachate and ground water.
A eminent was made at the meeting suggesting EPA should put the pipeline on
the west side of Highway 421.
EPA's response: The location of the pipeline has not yet been determined.
This is a design detail that will be worked out with the rest of the design at
a later date.
Two comments were made at the meeting suggesting EPA needs a method to isolate
the uncontaminated ground water from the north and east from the contaminated
leachate and ground water that will be collected and treated; an isolation
system on the north and east sides of the site was suggested.
EPA's response: EPA considered an isolation system encircling the landfill in
its Feasibility Study of 1986. However, based on our study of the regional
ground water flow in the area, we concluded this is not necessary because the
regional ground water from the north and east appear to be naturally isolated
from the contamination. We believe that the regional ground water does not
enter the site from the east. Furthermore, we believe that regional ground
water flow from the north is deep, and goes under the site. Because it is
deep, it will not become contaminated by the waste, and will not enter the
collection system. All the contamination we have seen is in the shallow
ground water; the deeper regional ground water is uncontaminated. In
addition, in the shallow aquifer, there is an upward gradient, which means
that flow is upward, so contamination cannot move downward from the shallow
glacial till aquifer into the deeper uncontaminated aquifer.
A comment was made at the meeting suggesting EPA have continuous monitoring of
the leachate system.
EPA's response: All dischargers to a municipal sewer system must perform
monitoring on the material they are providing to the sewer system. The
Northside discharge will be no different. The way monitoring will be
conducted, whether continuous or on some interval, will be determined during
the design of the project, and will depend, in part, on City of Indianapolis
requirements.
For further information, the reader is referred to the Administrative Record
and the public information repository at the Zionsville Town Hall, 110 S. 4th
St., Zionsville. (Contact: Karen Martin, (312)886-6128, or (800)621-8431 (9-
4:30 central time))
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760 Round Court
Zionsville, IN 46077-2017
Friday, May 31, 1991
Karen Martin
Community Relations Coordinator
Office of Public Affairs, 5PA-14
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois
Subject: ROD, Northside Sanitary Landfill, Zionsville, Indiana
Dear Karen:
Again, thanks for conducting last night's hearing in Zionsville.
I wish to enter the following additional comment. Though I spoke
on the subject in the form of a question in the meeting, I am entering
this comment in written form as this allows me to work carefully on
the exact wording.
Comment:
It concerns me that the proposed ROD will remove the burden of
separation and treatment of any contaminated leachate which will be
extracted from the ground. By piping this leachate to the North-
western corner of the Indianapolis wastewater treatment system, and
allowing it to commingle with the domestic effluent of hundreds of
thousands of other customers," it will be diluted far beyond the point
that it can be effectively treated. This, coupled with the fact that
neither of the Indianapolis treatment plants provide treatment
facilities for industrial chemical wastes, leads me to believe that
all we are really changing is the place at which the contaminated
leachate enters the waters of the United States, that change being
from the local aquifer to White River.
Unless it can be demonstrated that the Indianapolis treatment
plants can effectively remove the variety of contaminants expected, in
the form in which they will arrive, I believe that separation of the
contaminants from groundwater should be performed on-site, and the
burden of proper treatment and/or disposal of contaminants should be
fairly borne by the potentially responsible parties, (end of comment)
I look forward to reading the historical prospective of the
situation that will be presented by the entire series of Fact Sheets
that you offered to send. Thanks for so offering.
Sincerely,
Philip L. Brown
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