United States Office of
Environmental Protection Emergency and
Agency Remedial Response
Superfund
Record of Decision
EPA/ROD/R05-92/197
June 1992
Reilly Tar & Chemical
(Indianapolis Plant), IN
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supplemental material is, however, contained in the administrative record
for this site.
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50272.'01
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R05-92/197
I ~
3. Recipient. AcceMion No.
4. TII8 and 8ub1ItIe
SUPERFUND RECORD OF DECISION
Reilly Tar & Chemical (Indianapolis
First Remedial Action - Interim
7. Aulhor(..)
5. Report D.te
06/30/92
Plant), IN
6.
8. Perfonning Org.nlDltion ReP'- No.
8. PItrfonnlng Org.lnlDltlon Name and Add....
10. Projec1lT.8klWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponaorlng Org.nlutlon Name and AddrH8
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report & Period Cover8d
800/000
14.
15. SuppietnenWy No..
PB93-964115
18. Abatr.c. (Umlt: 200 word.)
The 120-acre Reilly Tar & Chemical (Indianapolis Plant) site is a former coal tar
refinery and creosote wood treatment plant located in Indianapolis, Indiana. The site
is divided into the 40-acre Oak Park property and the aD-acre Maywood property. The
Oak Park property contains the majority of the operating facilities, including
above-ground storage tanks, distillation towers, and above-ground and underground
utilities. The Maywood property contains operating facilities on its northern end.
This property was formerly the site of chemical process and wood preserving activities
and currently contains four waste disposal areas. The area surrounding the site is
mixed residential, industrial, and commercial. The site lies within the White River
drainage basin. From 1921 until 1972, coal tar refinery and creosote wood treatment
plants operated on site. Beginning in 1941, several chemical plants were constructed
and operated on the Oak Park property. Environmental problems at the site were found
to be related to the improper use and disposal of creosoting process wastes and
substances used in manufacturing chemicals. In 1955, alpha picoline, a chemical
manufactured onsite, was identified in nearby residential wells, and in 1964, three
contaminants from the site were detected in offsite ground water samples and onsite
(See Attached Page)
17. Docum8nt Analyal. L DncrIptors
Record of Decision - Reilly Tar & Chemical (Indianpolis Plant), IN
First Remedial Action - Interim
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics
metals (arsenic, chromium, lead), other inorganics (ammonia)
b. Identlfl8r8l0pen-Ended Tarma
(PAHs) ,
c. COSA 11 FIeIdIGroup
18. Avlli'.blMty Stlltelnent
18. Security Clio'" (Thl. Report)
None
:!G. Security Cia... (1hI. Page)
Nnn'"
21. No. 01 Pall"
78
L
See ANSl-Z38.18
n PrIce
S-I,../rucl/OM on ReWI'8tl
72 (4-77)
(Formerly N11S-35)
Department 01 Commarce
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EPA/ROD/R05-92/197
Reilly Tar & Chemical (Indianapolis Plant), IN
First Remedial Action - Interim
Abstract (Continued)
surface water samples. In 1975, state investigations identified several onsite problems
believed to be contributing to ground water contamination with organic chemicals. In
1980, state investigations revealed various organic chemicals in soil and subsequently in
1987, 60,000 gallons of waste fuel were accidentally spilled on the Oak Park property.
The spilled fuel oil was recovered, and some of the contaminated soil was excavated.
This ROD provides an interim remedy for OU1 and addresses offsite migration of
contaminated ground water. Several additional operable units are planned to address
contamination of onsite source and onsite and offsite ground water impacted by the site.
The primary contaminants of concern affecting the ground water are VOCs, including
benzene, toluene, and xylenes; other organics, including PAHs; metals, including arsenic,
chromium, and lead; and other inorganics, including ammonia.
The selected remedial action for this site includes two alternatives for the treatment of
ground water: a final selection of options and specific design parameters will be
deter~mined during the remedial design. The first alternative includes extraction of
ground water down-gradient of the site and biological treatment, followed by filtration
and activated carbon adsorption; and discharge of 0.5 mgd to POTW with the remainder
reinjected to the aquifer. The second option includes a combination of ground water
extraction from up-gradient wells treated with precipitation/clarification, followed by
activclted carbon and reinjection to the aquifer; and ground water to the aquifer. The
seconcl option includes a combination of ground water extraction from up-gradient wells
treated with precipitation/clarification, followed by activated carbon and reinjection to
the aquifer; and ground water extraction from interior of the site treated with
precipitation/clarification, followed by air stripping and discharge to the POTW.
Monitoring ground water and implementing engineering controls will be conducted.
Treatability tests are planned to determine the optimum design and operating
requirements. The estimated present worth cost for this remedial action is $15,000,000,
which includes an annual O&M cost of $1,000,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Interim ground water clean-up levels are based on the
more stringent of a 10-6 cumulative lifetime cancer risk, or MCLs for carcinogens; and
MCLGs, MCLs, or a HI of 1 for noncarcinogens. Chemical-specific ground water goals
include benzene 5 ug/l (MCL), toluene 1,000 ug/l (MCL), xylenes 10,000 ug/l (MCL),
pyridine and pyridine derivatives 35 ug/l (HI), arsenic 50 ug/l (MCL), chromium (MCL),
lead 5 ug/l (MCL), and ammonia 30 ug/l (MCL). Treated ground water discharged to the
POTW must meet separate clean-up criteria under CWA.
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Declaration for the Record of Decision
Reilly Tar and Chemical
Groundwater operable unit
site Name and Location
Reilly Tar and Chemical
Indianapolis, Indiana
statement of Basis and PUrDose
This decision document presents the selected remedial action for
~he ground water operable unit atothe Reilly Tar and Chemical site
(the Site) in Indianapolis, Indiana. This remedial action was
selected in accordance with CERCLA, as amended by SARA, and, to the
extent practicable, the National contingency Plan. The selection
of this remedy is based on the Administrative Record for the Site.
The State of Indiana concurs with the selected remedy.-
0.
Assessment of the site
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to human health, welfare, or the environment. .
Description of the Selected Remedv
This operable unit action is the first of s6Veral planned for the
site. It.specifically outlines an interim action to control the
off-site migration of contaminated ground water, which has been
determined by the Remedial Investigation to pose unacceptable risks
to off-site receptors..
The major components ofottte selected remedy include:
Ground-water extraction, treatment and discharge:
Treatment of ground water to achieve the cleanup standards.
listed in the ROD using one or more of the following
processes: biological treatment, filtration through granular
a~tivated carbon, filtration via precipitation/clarification,
and/or air stripping. The actual optimum treatment train will
be determined during remedial design.
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.2
Discharge of a portion of the treated ground water to the
Publicly Owned Treatment Works (POTW).
Recharge of a portion of the treated ground water to the
aquifer after treatment to achieve cleanup standards.
Ground-water monitoring to ensure that the containment goals of
this action are met and that this action prevents the off-site
migration of contaminated ground water. .
Declaration
~I
The selected remedy is protective of human health and the
environment, complies with Federal and state applicable or relevant
and appropriate requirements for this operable unit action, is cost
effective, and consistent with aChieving a permanent remedy.
Although this interim action is not intended to fully address the
statutory mandate for permanence and treatment to the maximum
extent practicable, this interim4ction utilizes treatment and thus
is in furtherance of that statutory mandate. Because this action
does not constitute the final remedy for the site, the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element, although
partially addressed by this action, will be addressed by the final
response action. Subsequent actions are planned to address fully
the threats posed by conditions at this site. Because tbis remedy
will result in hazardous substances remaining on-site above health-
based levels, a review will be conducted to ensure that the remedy
continues to provide adequate protection of human health and the
environment within five years after commencement of the remedial
action.. Because this is an interim action Record of Decision,
review of this site and of this remedy will be continuing as EPA
continues to develop final remedial alternatives for the site.
~ . ..
£2aci/ II. tttPaE
~aldas v. Adamkus
& neqional Administrator
~l3o It},
Date . I
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u : wnu-. ~ ' '- 1I.J\. t;7 \"jI..
CC : BECK D ~ ().IV -
RA RF..
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We make Indiana a cleaner, healthier place to live
Evan Bayh
Governor
Kathy Prosser
Commissioner R E eEl V E D
105 Sout.h Meridian Street
P.O. Box 6015
Indianapolis, Indiana 46206-6015
Telephone 317 -232-8603
Environmental Helpline 1-800-451-6027
JUN 2 6 1992
June 25, 1992
U. S. EPA REGION 5
Mr. Valdas .Adam1CaaF REGICNAL AC:.HN1SiAA1.fJ!!
Regional Administrator
U.S. Environmental Protection Agency
77 West Jackson Blvd.
Chicago, Illinois 60604
Dear Mr. Adamkus:
$IJ'@
Vu It!
1s:ra O~ ~ ~ c9 IP
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Mr. Valdas Adamkus
Page Two
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IDEM staff have been working closely with Region V staff in
the selection of an appropriate inter~ operable unit for the
Reilly Tar and Chemical site and are satisfied that the selected
alternative adequately addresses the ~ediate threat of off-site
migration of contaminated ground water.
Please be assured that IDEM is committed to accomplish
cleanup of all Indiana sites on the NPL and intends to fulfill
all obligations required by law to achieve that goal.
Sincerely,
~~
Kathy Prosser
Commissioner
CCI
Krista Eskilson, IDEM
Dion Novak, U.S. EPA, Region V
:J.
.'
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Decision Summary - Ground Water Operable unit
Reilly Tar and Chemical
Indianapolis, Indiana
site Name. Location and Descri~tion
Reilly Tar and Chemical
Indianapolis, Indiana
:J
The Reilly Tar and Chemical site (the Site) is located at 1500
South, Tibbs Avenue in the southwest quadrant of Indianapolis.
-Minnesota Street divides the 120 acre. site into two parcels. The
Oak Park property, occupying approximately 40 acres, the major
operating facility for Reilly Tar, is located north of Minnesota
Street. The Haywood property occupies approximately 80 acres, and
is located south of Minnesota street (see Figures 1 and 2). The
Oak Park property contains the majority of Reilly's operating
facilities, including above-ground storage tanks, distillation
towers, and above- and below-ground utili t-4es. The Haywood
property contains operating facilities' on its northern end. This
property was formerly the site of chemical .process and wood
preserving activities and currently contains four waste disposal
areas. The majority of the operating facility buildings are
located north of. Minnesota Street: approximately 75% of the Oak
Park property is covered by buildings, pavement and above-ground
tank farms. Approximately 20% of the Haywood property ~s covered
by buildings, pavement and above-ground storage tanks. The
remainder is primarily unpaved and vegetated.
The Reilly Tar site is surrounded by a mix of residential,
industrial and commercial properties. Residential neighborhoods
are located immediately adjacent to the eastern b~undary (on the.
east side of Tibbs Avenue) of the Oak Park property. Two
residences are also located abutting the northern property boundary
near the Lime Pond in the northwest corner of the site. Commercial
and industrial uses are located south and west of the site.
.
site Historv and En~orcement Activities
Industrial development of the Reilly site began in 1921 when the
Republic Creosoting Company (which later became Reilly Tar &
Chemical, which in turn .beeame Reilly Industries, Inc.) started a
coal tar refinery~ and a creosote wood treatment operation on the
Maywood property. On-site plants operated from 1921 until 1972.
Beginning in 1941, several chemical plants were constructed and
operated on the Oak Park property. Environmental problems at the
site are related to the use and disposal. of creosoting process
wastes and substances used in manufacturing chemicals. .
The earliest recorded complaint about odors and disposal practices
at the site was in 1955, which referenced the fact that a chemical
manufactured at Reilly (alpha picoline) had been found in nearby
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2
~I
. residential wells. . In 1964, three contaminants from Reilly were
detected in off-site ground-water samples and on-site surface-water
samples. In 1975, state investigations revealed several on-site
problems-which were believed to have ~een contributing to ground-
water contamination with organic chemicals. In 1980, an on-site
soil sample collected by state personnel was found to contain
various organic chemicals including toluene and trichloroethylene.
In 1987, 60,000 gallons of waste fuel, containing primarily
pyridine and pyridine derivatives, benzene, xylene, and toluene,
was accidentally spilled on the Oak Park property. Some, but not
all, of the fuel oil was recovered and some of the contaminated
soil was excavated by Reilly.
In 1984, Reilly Tar was listed on u.S. EPA's National Priorities
.List (NPL) , a roster of the nation's worst hazardous waste sites,
making it eligible for cleanup under the Superfund program. In
1987, the potentially responsibie party (Reilly) agreed to conduct.
a remedial investigation (RI) to characterize the nature and extent
of contamination at the site, and a feasibility study (FS) to
evaluate and compare remedial alternatives according to the terms
of an Administrative Order on Consent between the u.s. EPA and
Reilly Tar & Chemical.
.
In 1989, Reilly Tar & Chemical changed their corporate name to
Reilly Industries, Incorporated, under which they operate today.
..-
Hiahliahts of Communi tv ParticiDation
PUblic participation requirements under CERCLA sections 113
(k)(2) (B) and 117 were satisfied during the RIfFS process. u.S.
EPA has been primarily responsible for conducting the community
relations program for this Site, with the assistance of the Indiana
Department of Environmental Management (IDEM). The following
public participation activities, to comply-with CERCLA, were
conducted during the RIfFS.
A Community Relations Plan was developed in August 1987 to
assess the community's informational needs related to the Reilly
site and to outline community relations activities to meet these
needs. Residents and community officials were interviewed and
their concerns were incorporated into this plan.
. . ..
A public information repository was established at the
Indianapolis Public Library
A mailing list of interested citizens, organizations, news
media, and elected officials in local, county, State and Federal
government was developed. Fact Sheets and other information
regarding site activities were mailed periodically to all
persons or entities on this mailing list. This mailing list
was also updated from time to time as persons approached EPA for
information about the site.
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3
A Fact Sheet was mailed to the
announced a public meeting to
Investigation and answer site
publ..i-c. '
public in August 1987, that
discuss the upcoming Remedial
related questions from the
- A public meeting on September 2, 1987, at the Indianapolis City-
County Building announced the initiation of the Remedial
Investigation and provided details about its conduct.
- -A F4ct Sheet was mailed to the public in Winter 1988, that
announced the beginning of Phase 1 RI sampling and the release
of the EPA approved Phase 1 RI workplan.
A Fact Sheet was' mailed to the public in Fall 1988, that
summarized the findings of the Phase 1 investigation and
provided a preview of proposed Phase 2 sampling activities.
',I
A Fact Sheet was mailed to the public in January 1990, that
announced the findings of the Phase 2 invest4gation and provided
a preview of proposed Phase 3 sampling activities.
- Two availability' sessions were held on september 6, 1990, at the
stout Field School to discuss site progress and discuss results
of completed sampling activities.
A Fact Sheet was' mailed to the public in August 1991~. that
summarized results of the completed Remedial Investigation. The
EPA approved Remedial Investigation Report was also released at
this time. '
A Fact Sheet was mailed to the public in Januarr, 1992, that
summarized EPA's recommended remedial alternati~e in a
proposed plan ,for the ground-water operable unit. The EPA
approved Focused Feasibility Study was also released at that
time. This fact sheet also announced a public comment period
for the proposed. remedial action and waa:~ccompanied by paid
newspaper advertisemepts in the Indianapolis:Star and the
Indianapolis News. - -
A Public Meetinq was held on January 23, 1992, at the South
Wayne J~ior High School to present EPA's proposed plan for the
ground-water operable .unit and to receive formal public' comment.
..:..
Paid newspaper advertisements announced the RI.public meeting,
the availability sessions, and the 'FS and proposed plan public
meetings.
Periodic news releases announced results of studies at the
site.
A public comment period 'of thirty days was originally planned,
'running from January 16, 1992, to February 14, 1992. Based on
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4
a written request during the original comment period, the
comment period was extended until March 31, 1992, for a total
comment period of 76 days. The extension was announced by
letter-to the requestor and in a newspaper advertisement in the
Indianapolis star.
-
A Responsiveness Summary addressing comments and questions received
during the public comment period on the RI/FS and the proposed plan
is included with this Record of Decision as Appendix A.
-This Record of Decision presents the selected remedial action for
the ground-water operable un~ at the Reilly Tar and Chemical site
in Indianapolis, Indiana, chosen in accoJ::dance with CERCLA, as
amended by SARA, and the National Contingency Plan. The decision
for this operable unit at the site is based on the Administrative
Record. - .
BeODe and Role of the ODerable Unit
-
As with many Superfund sites, the problems at the Site are complex.
The Rem~dial Inves~igation eRI) investigated five distinct on-site
source areas and ground water. The RI determined that ground water
had been contaminated by the site and is migrating away from the
site at levels that were determined by the site Risk Assessment to
pose unacceptable threats to human health. The RI also determined
that there was not a good correlation between these fiv~,distinct
soarce areas and ground water contamination. As a result, this
operable unit action was_selected by EPA to stop further off-site
migration of contaminated ground water, thus giving adequate time
to study and remediate on-site source areas as well as .to preven~
the further contribution of site related contamination to are=-
ground-water resources.
This operable unit action is the first of several operable uni~
remedial actions to be taken at the Site. Subsequent actions will
be taken to remediate on-site source areaSy primarily cleanup of
source area soils, and potentially off-site ground-water resources
already impacted by the site, so that the source(s) of ground-water
contamination can be eliminated or contained. Additionally, the
Remedial Investigation identified an area on the Oak Park property
that appears to be a source of ground-water contamination,
primarily because the highest levels of contamination were found
there . Additional characterization work for this area will be
performed under a separate enforceable document to define the
nature and extent of contami~ation.there. This operable unit will
allow time for this work to be performed while ensuring that any
contamination associated with this area will remain onsite, thus
reducing the risks posed to off:-site receptors. This operable unit
will_also be designed to be consistent with any future cleanup
actions at the site.
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5
site Characteristics
The RI/FS was conducted to identify the types, quanti ties and
locations of contaminants at the site and to develop alternatives
that best address these contamination problems. Because of the
size and complexity of the Site, the RI was performed in three
distinct phases. The first phase focused on sampling off site
commercial, industrial and residential wells to determine the
presence of and extent of off site contamination. The second phase
concentrated on on site sampling activities to determine the extent
of contamination onsite so that site contributions to areal
contamination could be determined. The third phase concentrated on
collecting additional on site and off site data to complete the
investigatory picture so that a Feasibility study could be started
to address contamination problems. The nature and extent of actual
or potential contamination related to the site was determined by a
series of field investigations, including:
- development of detailed information regarding
historical site operations
:J
on site geophysical surveys
- surface soil sampling, both onsite and offsite
- exploratory test-pit excavation and samp~~ng
- installation and sampling of ground water monitoring
wells, both onsite and offsite
- surface-water sampling, both onsite and offsite
- identification and sampling of existing ground-water
wells in the site vicinity
- installation and sampling of soil borings
- a surface-water drainage study
- a water-level monitoring program, both onsite and
offsite
- identification of ground-water contamination sources.
within a one-mile radius of the Reilly site
.;..
- hydraulic conductivity testing and the performance
of a short-term continuous water level monitoring
program
- preparation of a site-wide human health and
ecological risk assessment
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6
Geology/Hydrogeology: The Reilly site lies within the White River
drainage basin, located approximately three miles to the east.
Eagle Creek is an attendant tributary and flows in a southeasterly
directieR approximately 4000 feet to the east of the site.
Topography in the site area is relatively flat with a gentle
,downward slope in an easterly direction. other surface-water
bodies in the site area include Blue Lake (a former gravel pit)
located approximately 2000 feet northeast of the site, several
small ponds or surface-water impoundments located 2000 to 4000 feet
east of the site, and one surface-water impoundment located,
immediately southwest of the Haywood property (see Figure 2). The
westernmost extension of Blue Lake has been filled in since 1979.
~I
The sand and gravel deposits that underlie almost all of the White
River drainage basin form the principal aquifer in the area. There
are three industrial well fields located to the east of the site
that have a reported cOmbined-pumping rate of 10 million gallons
per day, or approximately 7000 gallons per minute (see Figure 2).
In the vicinity of the site, upper and lower zones have been
identified within the sand and gravel outwash aquifer. At some
locations, especially directly underneath the site, these zones are
separated by one or more till units which, because of their silt
content, are less permeable layers and may impede flow vertically.
The lack of a continuous fine unit and similar ground-water levels
in shallow and deep wells suggest that the upper and lower zones of
the outwash sand and gravel deposits are hydraulicallY"connected
and that the till units do not act as a barrier to contaminant flow
in ground water.
Regional hydrogeologic data indicate that ground water in the
unconsolidated material in the area of the Reilly site flows east
towards Eagle Creek with a southerly component~ Water level data
from the RI indicate that ground-water flow is generally from the
northwest to the southeast and that withdrawais from neighboring
industrial production wells significantly impact the flow of ground
water' east of the site~ Hydraulic conductivities for wells tested
during the RI range fr~m 10(-2) to 10(-3) centimeters per second.
An average linear ground-water velocity of 0.68 feet per day was
calculated for the area that is not influenced by the industrial
pumping to the east of the site. An average linear ground-water
velocity of 2.0 feet per day was calculated for the area that is
influenced by the industrral pumping.
~
-:..
A detailed analysis of past operations during Task 2 of the
Remedial Investigation demonstrated that there are at least five
former waste-disposal areas onsite. These five former waste-
disposal areas were identified as potential source areas for both
on-site and off-site contamination. These include the Lime Pond on
the Oak Park property, the Abandoned Railway Trench on the northern
portion of the Haywood property, the Former Sludge Treatment Pit on
the northern portion of the Haywood property, the, Drainage Ditch on
the southern portion of the Haywood property and the South Landfill
-------
7
on the southern portion of the Maywood property (See Figure 3).
This task also identified ground water as a primary area of
investigation for the RI.
soil con~amina~ion: The Lime pond was a lagoon constructed in 1953
to receive waste discharges from the first synthetic pyridine base
processing unit constructed on the Oak Park property. Dimensions
of the Lime Pond are approximately 350 feet by 350 feet. until
1965, discharges from process areas on the Oak Park property went
ta- the-Lime pond, which included solid material and sludge that had
settled out of the waste water discharged there. since 1965, when
-a connection to the city sewer was made, the Lime pond has received
only water from boiler blowdown from the boiler operations on the
Oak Park property. At some time in the past, drums containing
unidentified liquids and solids were buried in trenches east (and
possibly north) of the Lime Pond.
:J
Borings in the Lime Pond area generally encountered lime sludge
from the pond surface to a depth" of four to seven feet.. The Lime
Pond contains on the order of 15,000 cubic yards of lime sludge
generated from boiler blowdown (water used for cooling of. boilers
that does not come into contact with production of. chemicals).
This lime sludge generally contained less than 1 part per million
total organics. The soils to the east of the Lime Pond were found
to be contaminated with volatile organics up to levels of
approximately 24,000 parts per billion (ppb) and se~-vo1atile
organics up to levels of approximately 360.,000 ppb. These areas to
the east of the Lime Pond and potentially to the north of the pond
(if confirmed during subsequent investigations) total between 400
and 1700 cubic yards of potentially contaminated material.
The Abandoned Railway Trench was used as an unloaaing and loading
area for incoming rail shipments. The railroad tracks were
depressed below ground level to facilitat~ these operations.
During the 1960s, the use of the railway trench for loading and
unloading purposes decreased and it was gradually filled in with
drums of off-specification coal tar enamel. Foundry sand obtained
from a variety of local industry was also used to complete the
filling of the trench. -It is estimated that the trench was
approximately five feet deep by fifteen feet wide by 580 feet long
based on Phase II investigations.
. . ..
..:..
Test pits co~l~ted in the railway trench area revealed a sloping
rail bed at a depth of approximately three feet at the south end of
the trench and at a depth of approximately four' feet at the north
end. A surface layer of crushed stone was encountered at each test
pit location and fill material consisting of black, brown or gray
sand and gravel, foundry sand, coal cinders, coal tar wastes, wood
debris and drums was found beneath. The estimated volume of fill
materials in the trench was calculated to be in the range of 700 to
4100 cubic yards, the exact amount being 'dependent on the trench
dimensions. soil contaminant concentrations in the trench sampling
-------
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-------
8
for volatile organics ranged to 656,000 ppb and for semi-volatile
organics ranged to 22,160,000 ppb.
From the-early 1950s until 1979, waste water sludge from the coal
tar refinery and synthetic chemicals operations was dried by
placing it in the Former Sludge Treatment pit, located in the
center of the Maywood property. The sludge pit was used for
thickening sludge by evaporation prior to off-site disposal to
landfills. The current RCRA-permitted sludge treatment area is
located directly above the northern portion of this historical
area. The dimensions of the original sludge pit, as reported in
the RI, are 110 feet long by 20 feet wide by 4 feet deep. The
estimated. volume of waste material in this sludge pit is
approximately 800 cubic yards: however, the volume may be greater
since test pit samples indicate that contamination may be as deep
as 10 feet in some places. .
:J
soil contaminant concentrations in the sludge pit sampling for
volatile organics ranged to 13,030 ppb and for semi-volatiles'
ranged to 6,118,000 ppb.
From the beginning of site operations in 1921 until the mid 1970s,
the southern portion of the Maywood property was used as a
landfill, the South Landfill, for construction debris and soil. In
addition, various solid and semi-solid wastes (tars, sludges, still
bottoms, tank cleanings) from the coal tar and the synthetic
,chemicals operations were also deposited in this arei. Coal
refinery wastes deposited in the area included off-specification
pitches, creosoted timbers, coal, and tank car sludges and waste
water sludge from the Maywood American Petroleum Institute (API)
separator. Wastes from the synthetic chemical operations were also
deposited in the south landfill beginning in the 1960s. These
wastes included waste water sludge from the API' separator and
distillation residues from various unit processes including
vinylpyridine residue and 3-pyridine carbonitrile residue.
Dimensions of the south landfill are approximately 1000 feet by 200
feet. .
..:..
A dug well, or fire pond, was situated at the extreme southeast
corner of the south landfill. This pond was reportedly dug by
facility personnel for the purpose of providing a water supply for
fire suppression. The'. dimensions of the fire pond were
approximately 110 feet in diameter and 23 feet in depth. The fire
pond dried up after a period of time, probably due to the increased
industrial ground-wate~ usage in the site vicinity. Limited data
regarding the materials used to fill the dry dug well (reported to
be tars, sludges, various chemical production residues, and foundry
sand) were derived during the RI.
The estimated volume of fill material in the South Landfill is
34,000 cubic yards. soil contaminant concentrations in the South
Landfill sampling for volatile organics range to 110,000 ppb and
-------
9
for semi-volatiles range to 35,280,000 ppb. Field investigations
in this area also identified both NAPLs (non-aqueous phase liquids)
and DNAPLs (dense non-aqueous phase liquids) as present in the
ground water in the form of oily sheen and distinct oil phases in
ground-water samples.
'.'
Prior to 1970, waste water and storm water were conveyed from the
API separator by the Former Drainage Ditch into the Raymond Street
storm sewer, which then discharged directly to Eagle Creek. This
water consisted of water separated from the raw tar, water decanted
from the tar storage tanks, water separated from the oil-water,
"wet-dry" in the refinery, blowdown water from the boiler
operations, aqueous sodium sulfate from the extraction of tar acids
and tar bases from the light and middle oils, and storm water
entering the system due to natural drainage. Historically, the
length of the ditch was 1220 feet, the width was between 15 and 50
feet, and the depth was approximately 8 feet. The estimated volume
of fill material ranges from 5600 to 15,800 cubic feet. Soil
contaminant concentrations in the Former Drainage Ditch sampling
for volatile organics range to 171,000 ppb and for semi-volatiles
range to 117,120,000 ppb. .
Ground Water contamination: Benzene concentrations in the ground
water range from below detection limits to 38,000 ppb, with the
highest levels detected on the Oak Park property. Pyridine and
pyridine derivative concentrations, which were summari~ed in the
remedial investigation (RI) as total pyridine derivatives, were
found in the ground water ranging from below detection limits to
305,405 ppb, with the highest levels detected on the south-central
portion of the Oak Park property. Ammonia concentrations in the
ground water ranged from 0.1 parts per million (ppm) to 53.3 ppm
with concentrations greatest in the northwest portion of the Oak
Park property (see Figures 4, 5, and 6 for maps of contaminant
plumes) .
.:-
Other contaminants present in the ground water include polynuclear
aromatic hydrocarbons (PAHs) and chlorinated ethanes and ethenes.
Concentrations of ~AHs.ranqe from below detection limits to 85
parts per trillion (ppt) with concentrations greatest in the
southeast corner of the Reilly property, in close. proximity to the
area known as the South Landfill. Concentrations of chlorinated
ethanes and ethenes, with~richloroethene (TCE) being the primary
component, range~from below detection limits to 110 ppb: the TCE
was detected just south of the southern boundary of the Reilly s:i,te
(see Table 1 for ground-water-contaminant profiles)
These contaminant profiles were developed. for use in the
preliminary modeling of the extraction and treatment network
necessary for site containment. Three profiles were developed ~f
groundwater conditions: upgradient, downgradient, and intern:.ll
gradient. Monitoring wells used for the upgradient average
included RI-1 and RI-16. Monitoring wells used for tne
-------
,ABLe:
.-- ---.
-
Groundwater Characteristics
Reilly SIte, Indianapolis, IN
Volatile Orgamc Compounds
methytene chloride - 75 BJ <2.5 <588
acetOne 304 BJ 1~ 2.423 J
chloroform 14 6 41
:J. 1.2~lchloroethane 14J <2.5 <588
2-butanone 26BJ <5 5J
bromodichlorcmethane 3J 2 - 2J
benzene 3,934 <2.5 25,380
.toluene 258J <2.5 2,368
ethylbenzene 252J <2.S 2,088
totat xytene 551 J <2.5 5.005
PyrIdine Dert.attves
pyridine 3,eoa <5.13 2U503
.. ... . -
2-ptcoUne 27,eoa . <5.13 164,400
3 & 4-picollne 2,813 <5.13 15.893
. .
2,6-Iutidine 208 <5.13 778
2-ethytpyridlne 303 <5.13 1,388
2.4 & 2.5-Iutidine 248 <5.13 278
~ 2,3-Iutidlne 214 <5.13 494
3-ethytpyridlne 128 <5.13 411
-------
1""AaL-=t (C.C.N"
Groundwater Characteristics
Reilly Site, In~I~'1~p'~lIs, IN
4-ethytpyridine 6 - <5.13 <6e9
3,5-Iutidine 713 <5.13 988
3,4-4utidine 52 <5.13 <659
2-methyt-5-ethytpyridine 171 <5.13 291
. .
2-methyt-3-ethytpyridine 208 <5.13 327
:J 3-ethyt-4-methytpyridlne 42 <5.13 14 .
Polynuciur Aromatic HydrocartJona
naphthalene 488J <& NIA
1-methytnaphthalene 11 J <5 <6e9
SemivolatUee
bIs-2(ethythexyt) phthalate 48. 10 NA
2,~imethytphenot 48 <5 NA
Met88s..
aluminum 14,26S -755 21.70rfA
arsenic ... .-. .- 18(12) 12 448.
barium' 52e(375) 760 417"
berytllum 1 5 18 "
chrOmium 2S 128 4()8
ccbaIt 18 118 ~
ccpper 77(4) 434 1~
..:..
lead.. 24(0.6) 118 4:Z- .-
--. _...
-------
TA~l.,," I (CONT)
Groundwater Characteristics
Reilly Site, Indianapolis, IN
.. - -
mercury 0.20 0.4 <0.1.
nickel 41 (8.6) 210 70-
silver 11 5 <2
vanadium 41 224 7e-
zinc 138(9) 809 1aga
Genera. W8t8r Quatity (mgll) (mgll) (mgll)
~ Information"
ca1cium 119(112) 979. 102(94)
Iron 37(1.5) 193 d t)28
magnesium 48(46) 332 30(29)
manganese 1.2(0.22) 7.3 2.4.
potassium 6.0(0.52) 9.0 5.
SOdium 217 32. 81.
haraness (as Caco,) 488 - NA 378
chemicaJ oxygen demand , 187. NA 902.
taIaI organic cart:)on 83 NA 417
blclcgica! oxygen demand 114 NA 550
taIaI suspended solids. t 25 7.2 76 -
CCI1ductMty (micromhcslcm) 1387 841 1190
Total dissolved sotids (TDS) 888 400 743
~
alkalinity 560 NA 840
chlorides 187. NA 60-
:
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Groundwater Chanicteristics
Reilly SIte, IndlanapoUs, IN
sulfates 31 NA 12
ammonia - N 15 0.620 11
kjeldahl - N 23 NA SO
nitrate - N 027 NA 0.37
phosphorus 0.12 NA 0.40
:.I
pH 7-3 NA 1.4
. . ..
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10
downgradient average included RI-3, RI-4, RI-5, RI-6, RI-17 and RI-
18. The monitoring'well used for the internal gradient average was
also RI-18.
summary of site Risks
:.I
This Record of Decision is written for an operable unit action to
prevent contaminated ground water within the site boundaries. The
RI report includes a risk assessment, prepared by Reilly using the
Risk Assessment Guidance for Superfund and approved by EPA as a
portion of the RI report, that calculated the actual or potential
risks to human health and the environment that may result from
exposure to site contamination. Because this action will only
address the migration of contaminated ground water from the site,
only risks calculated for exposure to ground water will be
presented. Risks associated with exposure to contaminated soils
will be addressed through subsequent actions.
The risk assessment determined that three chemicals in the ground
water are of primary concern: benzene, pyridine and pyridine
derivatives and ammonia (see Table 1). Other chemicals that were
detected in the ground water are also of concern but were not found
at the same frequency as these listed above. Concentrations of
these chemicals in the ground water have resulted in the
calculation of unacceptable risks to human health and the
environment posed by exposure.
.
Exoosure Assessment
The exposure assessment conducted as a part of the RI concluded
that several media are impacted by the contaminants at the site,
and that there are several potential exposure routes for
contamination. These routes of exposure were identified for both
current and future scenarios (as is commoMy done in EPA risk
assessments) so that all potential. pathways can be evaluated. The
baseline risk assessment computed risks from exposure to these
contaminants using the upper 95% confidence intervals of the
arithmetic mean of the Phase II and III sampling data
concentrations of the above contaminants. The use of the
confidence intervals is suggested in the Risk Assessment Guidance
for Superfund and represents a conservative step towards assessing
risks associated with potential exposures. In some cases where
sample results ~vary widely or sample size is small, these
confidence intervals may exceed maximum detected concentrations.
-:..
-
Due to the proximity of the site to the surrounding neighborhood
and major 'streets, and its size, the following potential receptors
were identified in.the risk assessment, and risks were computed for
their exposure.
Under the current land-use scenario, on-site workers could
potentially be exposed through ingestion and dermal contact with
-------
11
io
surface soils, and inhalation of surface-soil dust. Off-site
neighborhood residents could potentially be exposed through
ingestion and dermal contact with surface-soils from the Maywood
property-~primarily from site trespassers), inhalation of surface
soil dust (migration of dust from the site), ingestion and dermal
contact with surface soil from the Oak Park property (residents
playing basketball at a court located in the northern portion of
the site), and ingestion and dermal contact with on-site surface
water (site trespassers contacting a transient area of ponded
w~r)~. Off-site industrial workers could potentially be at risk
through exposure to volatilized contaminants (local industrial
-psage of the ground water) .
~
Under the future-use scenario, on-site workers could potentially be
exposed through ingestion and dermal contact with surface soils
(some workers can enter the area of the Maywood property), and
inhalation of surface-soil and dust (Maywood) and subsurface soils
(all areas) (workers may be exposed to on-site dust generated
during intrusive construction activities). Of£-site neighborhood
residents could potentially be exposed through ingestion and dermal
contact with surface soils (site trespassers), inhalation of
surface soil dust (Maywood) and subsurface (all areas) soils (wind
blown dust from the site), and ingestion and dermal contact with
surface soils from the Oak Park property (residents playing
basketball), ingestion and. dermal contact with on-site surface
water (site trespassers). Construction workers could p~~entially
be exposed through ingestion and dermal contact with surface and
subsurface soils (industrial facility construction on the Maywood
property). Future on-site residents (assuming that the site will
be converted to this use in the future) could potentially be
exposed through ingestion and dermal contact with surface soil
(Maywood) and subsurface soil (all areas), ingestion and dermal
contact with on-site surface water, and inhalation of surface dust
(Maywood) and subsurface soil (all areas). Future off-site
residents could be exposed through ingestion and dermal contact
with ground water (if residents used wells for water supply for
drinking and other household uses). Future off-site industrial
workers could be at risk through exposure to volatilized
contaminants from the ground water (industrial water usage).
Toxicitv Assessment
.:..
Benzene is classified as a known human carcinogen (Class A) and has
been associated with hematologic effects on humans as well as
anemia (decreased red .blood cells), leukopenia (decreased white
blood cells), and thrombocytopenia (decreased platelets). Chronic
exposure has been shown to cause pancytopenia. (decrease in all
circulating cells) and aplastic anemia (failure to manufacture
blood cells). Exposure by inhalation has been shown to cause
leukemia. Benzene has been shown to be a growth inhibitor 111
utero; however, it has not been shown to be teratogenic (causing
birth defects). Animal studies have shown preliminary evidence of
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~J
...:..
12
-
carcinogenicity: a link to leukemia via inhalation has also been
suggested. Benzene 'has been shown to be nonmutagenic (not causing
mutations): benzene oxide, the presumed initial metabolite of
benzene,-~s'mutagenic (causing mutations).
Limited data exists on the oral absorption of pyridine: data on the
pulmonary and dermal absorption of the chemical was not located.
~ailable evidence indicates that pyridine is well absorbed rapidly
from the GI tract and is not expected to accumulate in the body.
Available information-from animal testing does not suggest that
-lethality is a human health concern for exposure to pyridine by
~nhalation or ingestion. The major human health concern is for
liver damage, based on recent studies with~aboratory rats. Other
human health concerns include the potential for neurologic effects
and kidney effec;:ts... Pyridine has been administered to mice and
rats in order to evaluate the potential carcinogenicity of
pyridine. The studies, have concluded that pyridine did not produce
increases in the incidence of tumors with respect to controls. EPA
has decided that increased liver weight in female rats is the most
sensitive toxic endpoint.
Ammoni'a has been shown to cause deleterious effects in acute
exposures. Irritation of the eyes, nose, throat and chest are
associated with exposure to ammonia. Ingestion can cause gastritis
and corrosive esophagitis. Exposure to high concentrations of
ammonia gas can cause pulmonary edema or death. Ammoni~ has also
been shown to cause negative effects to the respiratory tract,
labored breathing, eye i~itation, inflammatory lung changes, and
death to many animal species.
Trichloroethylene (TCE) is considered a probable carcinogen (Class
B2) and is associated with central nerv~us system and renal system
problems, liver damage, hepatic injury, and damage to other organs.
Animal studies have indicated that :CE is fetotoxic but not
ter~togenic, producing primarily skeletal ossification anomalies,
decreased fetal weight, and other effects sonsistent with delayed
development. '
Ethylbenz8n8 is readily absorbed via inhalation, ingestion, and
dermal exposure, both in humans and in animals. Ethylbenzene
adversely affects the kidneys, lungs, adipose tissue, digestive
tract, and liver. There "is little information available on the
toxicity of ethylbenzene in humans, although exposure to moderate
to high concentrations causes irritation to the eyes, nose, and
throat. Ethylbenzene, is not mutagenic and has been assigned a
Class D (not classified) carcinogenicity rating due to lack of
data. '
Toluene is primarily absorbed through the lung and gut, although it
can also be absorbed through the skin. Toluene is metabolized
extensively and is excreted in the urine as well as in expired air.
Toluene adversely affects the central nervous. system causing
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~.I
.:..
"
13
-
'dizziness and unconciousness. Toluene is not mutagenic or
teratogenic, but there is some evidence ,that it causes adverse
effects in laboratory animals.
Xylene is easily absorbed through inhalation and is transported in
the blood. Exposure to xylene can produce' effects ranging from
irritation of the eyes, nose, and throat for acute doses, to
central nervous system depression and cardiac arrest in chronic
doses. Xylene has been found to be embryotoxic and teratogenic in
laboratory animals and has been assigned a Class D (not classified)
-c~rcinogenicity rating by U.S. EPA.
Both the, Integrated Information System (IR~S-1989) and the Health
Effects Assessment summary Table (HEAST-1990) were used as ,sources
for this contaminant' toxicity data.
Risk Assessment
The carcinogenic risks associated with exposure to benzene by
ground-water ingestion were computed for several potential exposure
scenarios (see Table 2). These include off-site resident (5.5 x
10(-4», off-site industrial worker (current risk - 1.06 x 10(-6)
for a quiescent. scenario and 1.64 x 10(-5) for an aerated scenario
(mixing of the water with associated volatilization of the benzene
into the breathing space) ), off-site industrial worker (future risk
- using the upper 95 % confidence interval for the grpund-water
plume - 6.83 x 10(-4) for a quiescent scenario, and 7.35 x 10(-4)
for an aerated scenario)~ and on-site resident (6 x 10(-4».
The non-carcinogenic risks associated with exposure to pyridine,
pyridine derivatives, and ammonia by ingestion of groundwater,
were computed for the same exposure scenarios as were used for the
carcinogenic risks. Generally, total Hazard Indices (HI) are used
to calculate non carcinogenic risks and must be below a value of
1.0; otherwise CERCLA requires remedial action. Hazard Indices
exceeded the 1.0 trigger for scenarios -such as the off-site
resident (HI=247), and off-site industrial worker (HI=277) (see
Table 2).
Because this is an interim action, calculation of residual risks is
not necessary and will be addressed by the final remedy for ground
water, which will likely include source remediation. However, it
should be noted that ground water will ,be prevented from migrating
from the site as a result of this action, and ground-water
treatment will achieve ARAR~.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in tbis'ROD, may present an imminent and substantial endangerment
to human health, welfare, or the environment.
-------
TABLE 2
I .
Summary of Site Risks
Groundwater
Future Offstte Resident
Drinking 247 (pyridine) . 5.5x10" (benzene)
Contact 0.90 7.4x10~ (benzene)
Current Offstte IndustriaJ Worker
Inhalation O. t3-0.29 1.64x10" - 1.07x1 O~
~I Future Offstte Industrial Worker
- . Inhalation 277.01 - 279.25 7.35x1 0". - 6.84x1~
~,..:
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Remediation Options for Detailed Analyses
Reilly Site, Indianapolis, IN
:.a
-Altemative ,: No Action
Alternative 2: In-Situ 81oremediation Using Combination ~onlReinjection
Well Design
Alternative 3: Alternative 3A - Extracticn DowngradientITreaunemllnjectiOn
Upgradient
-
Alternative 38 - Extrapticn upgradientlTreatmentllnjection
Downgradientllntericr Gradient Ccntrct
Alternative 4: Alternative 4A - Fully Encircting Slurry WalUlntericr Gradient
ContraVTreatment -
Alternative 48 - Fully encircling Slurry WaJUlntericr Gradient
CcntrcUExtraction Upgradientl Treatment/Injection Downgradiem
.
. , ..
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14
DescriDtion of Alternatives
-
During the Focused Feasibility study (FFS), Reilly identified and
evaluat~ a list of alternatives. that could be used to address the
threats and/or potential threats identified for the ground water at
the site. Reilly screened the list of alternatives based on
criteria for effectiveness (i.e. protection of human health and the
_environment, reliability) , implementability (i. e. technical
feasibility, compliance with applicable state and Federal
regulations), and relative costs (i.e. capital, operation and
- maintenance) . . Following this initial screening, the list of
_alternatives was evaluated and only alternatives that met the nine
criteria were submitted for detailed analysis.
Four alternatiye~were evaluated during the detailed analysis of
alternatives in the FFS (See Table 3). These included no action:
in-situ bioremediation: ground-water extraction, treatment and
discharge: and a fUlly-encircling slurry wall with accompanying
-ground-water extraction, treatment and discharge, as described
below.
Alternative 1:
No Action
Under this alternative, no remediation would occur and the site
would remain in its present condition. Allcontami~ation would
.remain in the ground water, with continued off-site movement at
umtcceptable levels. This alternative would includ'e periodic
monitori~ of the ground-water quality both on and offsite.
Although this alternative does not address the ground-water
contamination problem, its inclusion. in the detailed alternatives
analysis is required by CERCLA as a baseline for comparison to the
other alternatives developed.
Expected capital Cost
Expected Annual Operation
Present Worth Cost:
Time to Implement:
and Maintenance
$ 0
$ 82,000
$127,000
none
A!.ternative 2:
In-situ Bioremed~
This technology can be implemented in a number of forms, and
involves the treatment; "destruction, and control of subsurface
pollutants with~ microbes. Usinq this alternative, oxyqen' and
certain nutrients (such as phosphate$) would be injected (through
injection wells) into ground water to accelerate the natural
breakdown of contaminants and control their movement offsite.
Ground water would be moni to red for several years to determine
whether the remedy is working effectively.
-
In-situ bioremediation could be enhanced by the use of several
technologies. These include underground barriers (such as slurry
walls) to control contaminated ground-water flow, an air-stripping
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15
system to remove contaminants from water blown through a controlled
facility, or a soil vapor extraction system which draws air through
contaminated soil to remove organic contaminants. The contaminated
a~r woulg_be treated by filters containing activated carbon.
Expected Capital Costs
Expected Annual Operation
and Maintenance (year 1-2)
(year 2-30)
Present Worth Costs
Time to Implement:
$ 8,000,000
$ 1,110,000
$ 660,000
$ 15,000,000
3 to 10 months
Alternative 3:
Ground-Water Extraction. Treatment and Discharae
~j
The FFS describes two ways this alternative could be implemented,
details of which would be determined during the design phase of the
cleanup. Ground water extraction at the property boundary will
create a hydraulic barrier that will prevent ground water movement
off-site. Ground water would first be extracted and then treated
through one or more of the following processes: biological
treatment, filtration through granular activated carbon, filtration
via precipitation/clarification, and/or air stripping. Most of the
treated water would be recharged to the aquifer (using wells
located up-gradient or down-gradient of the site). The remaining
treated water would be discharged to the Publicly Owned Treatment
Works (POTW). It was estimated in the FFS that approximately 1.7
to 2.1 million gallons of water per day would need to be pumped
from 8 to 12 extraction wells to achieve the containment objectives
of this action. These estimates would be further revised during
remedial design, using, at a minimum, a pump test of the aquifer to
further define aquifer properties. This remedial action would be
designed to isolate the site so that ground' water would be
contained onsite.
Expected capital Costs
Expected Annual Operation
Present Worth Costs:
Time to Implement
Alternative 4: Fullv-Encirclina
Extraction. Treatment and Discharae
& Maintenance
$ 5,500,000
$ 1,000,000
$15,000,000
2 to 6 months
SlurrY Wall:
Ground-water
~
'. .
The FFS describes~two ways this alternative could be implemented,
details of which would be determined during the design phase of the "
cleanup. Each proposal includes a slurry wall that encircles the
site and is connected to the shale bedrock below the site,'
approximately 60 to 100 feet in depth. This slurry wall would
create a physical barrier that will prevent the further off-site
movement of contaminated ground water and, when combined with
ground water extraction, will effectively isolate the site. Ground
water would be extracted from the west side and/or the center of
the site and treated with precipitation/clarification followed by
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16
air stripping or filtration through granular activated carbon.
Treated ground water would then be discharged to the POTW or
reinjected to the aquifer using wells located down-gradient of the
site. ~reatability studies on the soils extracted from the slurry
trench would be necessary during remedial design so that it could
.be determined whether it was acceptable to either uSe them in the
construction of the slurry wall or dispose of them offsite. It was
estimated in the FFS that approximately 0.6 to 1.7 million gallons
of water per day would need to be pumped from 4 to 8 extraction
wells to achieve the containment objectives of this action. These
estimates would be further revised during remedial design, using,
at a minimum, a pump test of the aquifer to further define aquifer
properties. This remedial action would be designed to isolate the
site so that ground water would be contained onsite.
Expected Capital Costs
Expected Annual Operation
Present Worth Costs:
Time to Implement
& Maintenance
$ 20,000,000
$ 500,000
$ 25,000,000
6 to 12 months
:1
Summary of the ComDarative Analvsis of Alternatives
The nine criteria used by U.S. EPA to evaluate remedial
alternatives, as set forth in the NCP, 40 CFR Part 300.430,
include: overall protection of human health and the environment:
compliance with applicable or relevant and appropriate re.quirements
(ARARs); long-term effectiveness: reduction of toxicity; mobility,
or volume: short-term effectiveness: implementability; cost: state
acceptance: and community acceptance. Based on evaluation of the
alternatives with respect to these nine criteria, U.S. EPA has
selected Alternative 3 - Ground-Water Extraction, Treatment and
Discharge - as the alternative for the interim remedy for this
Site.
THRESHOLD CR%TER%A
Protection of Human Health and the Environment
Addresses whether a remedy provides adequate protection of human
health and the environment and descrihes how risks posed throuqh
each exposure pathway are eliminated, reduced, or. controlled
throuqh treatment, enqineerinq controls, or instit;utional controls.
~
..:..
Alternative 1 would not protect human health and the environment
because it does not reduce risks associated with exposure to ground
water. pilot testing is needed before a final determination can 'be
made regarding Alternative 2: however, it appears that it can
control the off-site movement of contaminated ground water.
Because the effectiveness of the technology has not been verified, .
it is not clear whether Alternative 2 can meet necessary Federal
and State drinking-water standards or recharge/discharge limits.
However, it does not appear that the hydrogeologic environment at
-------
17
the site will allow for sufficient time for the bioremediation to
work effectively, because of ground-water velocity and the presence
of clay lenses. Alternatives 3 and 4 are the most protective,
because--they use proven technologies to control the off-site
migration of contaminated ground water. Both Alternatives 3 and 4
are capable of meeting recharge/discharge ARARs. Air emissions
controls will be provided if required for the air strippers used in
Alternatives 3 and 4. Sludge disposal from the biological system
and/or from backwash solids associated with the extraction and
treatment systems will remove the contamination from the site to a
location where exposure is minimized by engineering controls.
Therefore, since it has been determined that Alternative 1 would
not be protective of human health and. the environment or meet
ARARs, it will no longer be considered in the nine criteria
evaluation. It appears that Alternative 2 may be able to meet
ARARs, although further pilot ~esting is necessary before a final
determination can be made. Alternatives 3 and 4 are functionally
equivalent with respect to this threshold criterion.
ComD1iance with ARARs
~I
Addresses whether' a remedy will me.t all of the ARARs of other
Federal and state environmental la.s and/or justifies a waiver of
those laws. .
.~.
Alternatives 2, 3, and 4 should meet the ARARs relating to
treatment and discharge, although they will not immediately meet
Maximum contaminant Levels (MCLs) at the property boundary. Pilot
testing would be necessary to confirm this determination for
Alternative 2, In-Situ Bioremediation. All on-site activities
associated with Alternatives 2, 3 and 4 will comply with worker
heal th and safety' requirements,. air emissions standards,
discharge/recharge permit requirements, ~d waste disposal
requirements (see Table 4 for listing of ARARs).
Therefore, it has been determined that Alternative 2 needs further
testing to determine whether it can meet ARARs, while Alternatives
3 and 4 are functionally equivalent with respect to this threshold
criterion.
. . '.
BALANCING CRITERIA
Lona Term Effectiveness
.:..
Addresses any expected residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment
over time, once cleanup standards have been met. .
Alternative 2 cannot be ranked relative to the other alternatives
with respect to this criterion until further bench-scale and pilot-
-------
"
j.
.
ARARs
. I' . I .
II
NO AC'nON
400FR 141.11-.18, 141.50-.51, and 1"41.81(a)(SDWA)
aets MCLs and MOLGa 'or pubfic drinking waler systems.
A I18t of MCls Is provided in Table 3-5 under discharge
criteria 'or reinjection.
40 OFR 264.29 and 264.~, ROAA groundwater protection
itand.wa. Three types ofslllndardl may be used: (1)
chemical speclflo standards for 14 toxic compounds
(MOLs), (2) the groundwater must be cleaned to
background levela or (3) RORA Alternate OoncentraU,on
limite may be used.
S27IAO 2-1-7 Underground Water Standards. All
,roundwaters 0' the slate which are a present or
probable future &Gurce for public or industrial
waler supply ah,1I meet water quality standards.
AI groundwatert at all times shall meet the
minimum conditions 01 being free from
substances which are in amounts sufficient to
Injure, be.acutely toxic to, be chronically toxic to,
or be carclnogenio, mutagenio or teratogenic to
humans, animals, aquatic file or plants (327 lAC
2-1-7(b». In addition, If the groundwater is used
for drinking water at the point at which such
waters are withdrawn for use, then chemical
,
constituents in groundwater shall not be present
In sucIJ levels as to prevent, after conventional
treatment, meeting drinking water standards (327
lAC 2-1-7(0)). State MCLs are Included in Table
3-5
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1N-81TU BIOREMEDIATION
40 CFR 141.11-141.16, 141.50-141.51, and 141.61(a) Safe
Drinking Water Act (SDWA) sels MCls and MCLGs for
public ctinldng water systems. Although the groundwater Is
not currently. drinking water GOwca It Is potentially a
drinking water source In the future and therefore, according
to the NOP (40 CFR 3OO.430(e)(2)(8», 8houl~ be protected
to levels appropriate to qs potential use a. . drinking water
source. A tlst of M0181s provided In Table 3-5 under the
dl8charge criteria for reinJection.
40 CFR 264.29 and 264.94, RORA groundwater protection
etandard8. Three types 0' 1t8nd81d8 may be used: (1)
chemlcalspeciflo slandarda for 14 toxla compounds
(MCle), (2) the groundwater must be deaned to
background levels or (3) RCRA Alternate Concentration
.lImhl may be used.
I
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327 lAC 2-1-7 Underground Water Standards. All
groundwatera 0' the state which are a present or
probable future source for public or industrial
water supply shall meet water quality standards.
AD groundwatere at all times 6haU meet the
minimum conditions of being free from
substances which are In amounts sufficient to
inJure, be acutely toxic to, be chronically toxic to,
or be cardnogenlc, mutagenic or teratogenic to
humans, animals, aquatlo life or plants (327 lAC
2-1-7(b)). In addillon, If the groundwater Is used
for drinking water at the point at which 8uch
waters are withdrawn for use, then chemical
constituents in groundWater shall not be present
. In such levels 88 to prevent. aner conventional
treatment, meeting drinking water standards (327
lAC 2-'1-7(c». State MOL. are Inctuded In Table
3-5.
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ARARa Common to all Aftem8tlves
40 CFR 284.29 and 264.94, RCRA groundwater protection
8tandards. Three types 0' standards may be used: (1)
chemical spedtlo standards for 14 toxic compounds
(MQ.8), (2) "e grounctNater must be cleaned to
baic:kground lev. or (31 RCRA Alternate Concentration
UnIte may be used.
321 lAC 2-1 outDnes water quality 8tandai'ds
developed by IDEM to prevent degradation of
atate wat818
_.
327 lAC 2+7 Underground Water Standards. All
gRJUncMat818 0' e.e etate which are a present or
I probable future source tor public or indJstrlal
water aupply ahall meet water quatity 8tandards.
Aft groundwat818 at all times shall meet the
minimum conditions 0' being free from
substances which are In amounta sufficient to
Injure, be acutely toxic to, be chronically toxlo to,
or be carclnogenio, mutagenic or teratogenic to
humans, anlmats, aquatic Hfe or plants (327 lAC
2-1-1(b)). In addition, If the groundwater Is used
for d'lnldng water at the point at which such
water8 are withdrawn for use, then chemical
constituents In groundwater shall not be present
In 8uch levels as to prevent, after conventional'
treatment, meeting drinking water standards (327
lAC 2-1-7(c». State MCla are Included in Table
3-5.
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POOR QUAUT'f
ORIGiNAL
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(Continued)
40 CFR 141.11-141.16, 141.50-141.51, and 141.61(a) Safe
Drinking Waler Act (SDVVA) 8ets MOla Ind MCLGs lor
public ctinklng water system8. Anhough Ihe groundwater is
nol currently I drfnklng waler source It Is potentially a
drfnklng waler sourca In the luture and th.ereforei according
to the NCP (40 CFR 300.430 (e)(2)(8)), 8hould be
protected to levels appropriate to Its use as a drfnklng
wlter source. A nst of MCLa Is provided In Table 3-5
under the discharge crilerfa for reinjection.
. -.. --_u_-- ..- - .
29 CFR 1910, 1928. 1904, Occupational Health and Safety
Slanda/da to be compDed with during 8Ite remedlaUpn.
40 CFR 268, RCRA Land Disposal Requirements. The use
of lItration to remove euepended solids or metals will
produce a solid waste which must be disposed olin
accordance with RCRA requi(ements, depending upon
waste classillcation. :"\..
State Industrial Pretreatment Requirements.
Comply with 301~) CWA. Requires notification
ot discharge of toxic pollutants (as defined by
CWA) If over defined limits.
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(Continued)
40 CFR 263,49 CFR 101, 111-119 Transportation
requirements tor shipment of hazardou8 residuals;
applicability depends on w88te dasslftcation.
40 CFR 144. Underground Injection Control Program.
These regulations deftne the ..,.lrem,,- for siting,
pennltdng, and monltorln~ underground InJection wells
under SDWA and RCRA. Notably: 40 CFR 144.13(0)
allows operation of OIass IV InJection wells during CERCLA
remediation; 40 CFR 144.23 applies to dosure of a OIal8
IV wet; and 40 CFR 144.31 outlines the information.
required by EPA to consider and approve a new InJection
weI.
40 CFR 148, Underground InJection Control Program:
CrIteria and Standards. Notably, 40 CFR 148.8 dellnes.
~es to be used to calculate th8 "zone of
endangering Inftuence8, and 40 CFR 146.8 defines
standards and testing procedures for the mechanical
integrity 01 8n injection wel. Subpart E of the rule,
pertaining specifically to Class IV welts, ~81 not been
promulgated and thus Is not an A"AR.
321 lAC 5-4-2, underground Injection of
paDulants. Underground inject/on of treated
"f8ltewater 8t a facility that does not have a
NPDES-permlded dscharge does not require a
permh. Instead, ~e ltate regulates and
discharges under 321 lAC 3. .
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Biological Treabnent
Depending on the Identity of the by-products, the chemical-
epecIfic ARARs previously listed may be applicable
(SDWA, RCRA). No specifto by-products have been
identified that would trigger this requirement.
40 CFR 268, RCRA requirements may pertain to disposal
of spent activated carbon.
ActIvated Carbon
stripping
40 CFR 264.1032 Organic Air EmI88Ion Standards for
Process Vents pertains to stripping operations that 81'111 a
totel organics (TO) of 10 ppm by weIQI.d or greater. If this
rule applies, then total orgenle ernls8lons must be reduced
to below 1.4 kglhr,!!t control dev1ce8 that reduce total
organic emissions by 95,.. muat be Installed and operated.
Containment (Sluny WalJ
I.8nd DIapo8aI R88IIIctiona (40 CFR 268) may apply to
excavated soBs depending on waste dasslficatlon.
"
'.
IndianapoUa Air PoDuUon Control Board
Regulation IX-I, Permits. Sources emhting more
than 3 bJhr or 15 IbIday are required to obtain a
construction peimlt and a permit to operate.
326 lAC 8 Air Management Rule. Sources.
emitting more than 25 ton per year have to
I
demonstrate compliance with Best Available
Technology Requirements.
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Discharge to POTW
40 CFR Part 122.42(b), NPDES Penn. Regulatlons-
Requires notillcatlon oll88t.1lng au1hority of r~valuation of
POTW.prelreatment standards (It must be noted that In the
event that the POTW does not have a local Imftatlon for a
. particular pollutant found In 1he dscharge flam this
Superfund site, . must evaluate hllocallimhations, and
develop 8lIch a Imitation al necessary to protect the
POM from Interference, pasa-through, or inhibition from I
the dsctlarge.):
40 CFR Part 403.6, NPDES National Pretreatment
81andards, discharge to a P01W must not Inteftere, pass
through untreated Into the receiving waters, or contaminate
the 8ewage lludge (See note above.); and,
40 CFR Part 403.g(I), NPDES Pretreatment Program
Requlf8Ihents for PalWl. (J. O'Grady, 8-1938)
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discharges to POTW
327 lAC 6-13 ApplicablU1y of Industrial Wasle
Pretreatment Penn..
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18
scale tests are performed, due to uncertainties associated with the
distribution of oxygen and nutrients, soil heterogeneities, and
reaction kinetics. The long-term effectiveness of Alternative 4 is
dependent-on the structural integrity of the slurry wall and the
continued operation of the interior ground-water extraction system.
Following proper design, continued operation of this alternative
shall effectively control future off-site movement of contaminated
ground water.
The lang-term effectiveness of Alternative 3 depends on the
integrity of the extraction system: however, continued operation of
-Alternative 3 shall effectively control future off-site movement of
contaminants through extraction and treatment of ground water. The
use of backup systems, such as backup power generators, redundant
extraction wells, designing the extraction wells so that their
radii of influence overlap, and designing the system to accommodate
"shock" loads such as spills and accidental releases related to
remedial activities, should satisfy the concern identified in the.
proposed plan regarding extraction'system failure, thereby ensuring
that the containment provided by this remedial action will not. be
compromised. .
:.I
Therefore, it has been determined, based on additional information
provided during the public comment period, that Alternatives 3 and
4 are functionally equivalent with respect to this balancinq
criterion. /
Reduction of Toxicitv. Mobilitv or Volume
Addresses the anticipated performance of the treatment technologies
a remedy may employ.
Alternative 2, the in-situ treatment option, should reduce
contaminant levels within the aquifer (although-mobile constituents
can be transformed and degraded by aerobic microorqanisms, their
specific metabolites have not been fully characterized). Both
Alternatives 3 , 4 utilize conventional technologies that have
proven to be effective .in reducing the toxicity and volume of
contaminated ground waterr- The presence of the slurrY wall will
not, in itself, reduce the toxicity of the contaminated water, but
in conjunction with extraction and treatment, would provide
contaminant reduction similar to the non slurry-wall options.
~
Therefore, i~has been determined that Alternatives 3 and 4 are
functionally equivalent with respect to this balancing criterion.
Short Term Effectiveness
~
Addresses the period of time needed to achieve protection and any
negative effects on human health and the environment that may be
posed during the construction and implementation period, until
cleanup standards are achieved.
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:.1
-:..
19
-
. Alternative 2 cannot be ranked in terms of short-term effectiveness
until further pilot- and bench-scale tests are performed. However,
.Alternative 2 will cause minimal exposure during installation of
the wel-l. system, and control and monitoring equipment.
Approximately 3-10 months will be required to meet the containment
objectives of the operable unit.
For the Alternative 3 extraction and treatment options,
-installation of extraction and re-injection wells and the
cORstruction of a treatment plant will cause limited exposure to
- hazardous substances. Approximately 2-6 months will be required to
-meet the containment objectives of this operable unit.
The installation of a slurry wall (Alternative 4) will cause
exposure to h~ans because of increased air emissions during
. construction of the wall, and management and off-site disposal of
excavated soils (if determined to be hazardous enough to warrant.
this action). The short-term effectiveness of Alternative 4 is also
- dependent on management of the residuals associated wi th the
excavation of potentially contaminated soil during slurry wall
construction. However, potential impacts on the surrounding area
from this action will be minimized through the use of vapor-
suppressing foam 'and other similar means. This activity may also
cause disruptions to electrical ana gas utilities ana to water
mains vital to area services durinq construction activ~ties, as was
identified during the public comment period. Dis~ptions to
neighboring residents, Reilly's everyday operations, and to
Conrail's-operation OL the railroad tracks along the western
property boundary are also possible as a result of construction.
Installation of extraction and re-injection wells and the
construction of the treatment plant for this Alternative would
cause limited exposure to hazardous substances. Approximately 6-12
months would be required to meet the containment objectives of the
operable unit. .
Therefore, based on the new information presented to EPA during the
public comment period, it has been determined that Alternative 3 is
superior to the other alternatives in effectiveness in the short
term.
ImDlementabilitv
. . '.
Addresses the technical and administrative feasibility ot a remedy,
inc.ludinq the-availability of materials and services needed tor a
particular option to. be pu~in place.
The equipment and materials required for the Alternative 3
extraction and treatment options are available and commonly used
for_remediation. The use of extraction wells is a proven, reliable
method for ground-water extraction. Air stripping, biological
treatment and carbon adsorption are all proven technologies.
Treatability testing of these technologies will be needed to
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~I
..:-
20
-
determine design and operating requirements for the ground water
from the site. The options which involve air stripping may need
emissions control to meet air emissions standards. The activated
carbon system would need replacement and/or regeneration of carbon
periodically. The Al ternati ve 2 in-situ treatment options involved
installation of a network of wells, using commercially available
components, but tailored to subsurface conditions. Field testing
w~uld be required to effectively develop the design.
Although slurry walls- have been used ~or remediation at other
-sites, and the technology to install deep slurry walls is
available, potential problems exist with installing a wall to
confining layer depths such as those at the -Site, and in keying the
wall into shale bedrock. Complications in the construction of the
slurry wall could- also arise from the presence of underground'
utilities.
Therefore, it has been determined that Alternative 3 is superior to
the other alternatives with respect to implementability.
Cost
Included are capital costs, annual operation and maintenance costs
Cassuminq a 30 year time period), and net present value of capital
and operation and maintenance costs. The selected remedy must ~e
cost effective.
T~e FFS presented net present worth cost estimates for each of the
four alternatives brought forward ,for detailed analysis. These
estimates were derived from literature, vendor quotations, actual
costs from similar proj ects, and standard cost information sources.
Cost estimates are provided primarily for the purpose of conducting
a comparative assessment between remedial options, in order to
assess the economic feasibility of the different alternatives.
Where limited or insufficient information was available regarding
site-specific hydrogeologic characteristics er contaminant specific
treatability efficiencies, assumptions were made based on
literature and professional judgement where ,necessary to develop
costs associated with different processes. As directed by U.S.
EPA, the FFS also presented a cost-sensitivity analysis for each of
the alternatives, outlining expected, best, and worst cases. The'
cost estimates provided" 'in the FFS are expected to provide an
accuracy of +/- ~.50 percent, except for Alternative 4 which has
undergone a slightly more detailed analysis, provided to u.s. EPA
during the public comment period.
Cost estimates for Alternative 3, Ground Water
Extraction/Treatment/Discharge, and Alternative 2, In-situ
Bior~mediation, are comparable. Expected capital costs for
Alternative 2 are higher, at $8 million. (versus $5.4 million to
$5.5 million for Alternative 3), but operation and maintenance
costs are lower for Alternative 2: $1.1 million for the first two
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21
.
years and $660,000 annually thereafter for Alternative 2, and $1
million annually fo.r Alternative 3. . The 30-year present worth
costs are $15 million, and between $13.9 million and $15 million
for Alternatives 2 and 3, respectively. Alternative 4, which
. incorporates the fUlly-encircling slurry wall, has a higher
expected capital cost (estimated to be between $19.2 million and
$22.7 million, based on information presented to EPA during the
public comment period), but a lower expected annual operation and
maintenance cost (estimated at between $470,000 and $700,000). The
expected 30-year present worth estimate for Alternative 4 is
between $23.6 million and $29.4 million.
Therefore, based on analysis of the costs associated with all of
the alternatives analyzed in the FFS, it appears that Alternative
3 has the lowest capital .cost, Alternative 4 has the lowest.
operation and maintenance costs, and Alternatives 2 and 3 have the
lowest present worth cost.
MODIFYING ~RITERIA
~I
state AcceDtance
Addresses whether or not the state aqency aqrees to or objects to
any of the remedial alternatives, and considers state ARARs.
The Indiana Department of Environmental 'Management (IDEM1~has been
intimately involved with the site throughout the RI/FS, has
attended all technical progress meetings, has been provided
opportunity to comment on technical decisions, and concurs with the
selection of Alternative 3 as the selected remedy for this interim
action at the site.
community AcceDtance
...:..
Addresses the pU))lic' s qeneral
alternatives and proposed plan.
Throughout the RI/FS at the site, community involvement has been
moderate. u.S. EPA has been accessible and responsive to community
concerns throughout the study. At the public meeting for the
proposed plan, there were many citizens who voiced opposition to
the proposed slurry wal~ alternative for many reasons. written
public comments also reflected many of the reasons. for opposition.
These included that the added benefits. of the slurry wall did not
justify the additional costs: installation of the slurry wall would
disrupt the neighborhood, area utilities and Minnesota .street:
installation of a slurry wall at the Reilly site would be difficult
to accomplish and even more difficult to monitor and repair: and
the cost differential between the slurry wall and the ground-water
extraction alternatives could be better spent by Reilly on
improvements in the company and for the workers and surrounding
neighbors. .
response
to
the
remedial
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22
At the public meeting, the majority of those in attendance, as well
as the majority of those who submitted written comments regarding
the proposed plan, were in favor of Al ternati ve 3 as the most
appropriate choice for this action. Reasons for this ranged from
cost effectiveness to short-term effectiveness to implementability.
In summation, Alternative 1 is unacceptable for protection of human
health and the environment. Alternative 2 would require additional
time for pilot studies, may not be effective, and has a similar
present.., worth cost as Alternative 3. Alternative 4 may pose
problems regarding short-term effectiveness, implementability, and
~ost effectiveness. Therefore, the best balance among the four
alternatives is Alternative 3, Ground-water Extraction, Treatment
and Discharge.
selected Remedv
:,I
As was discussed in the previous section, EPA has selecteQ
Alternative 3 - Ground-water Extraction, Treatment and Discharge as
the appropriate interim remedy for. the Reilly Tar and Chemical
site. This alternative was selected because it is the most
appropriate alternative for this interim action and is compatible
with the final remedial alternatives anticipated for the Site,
which will mainly encompass source-area remediation.
The objective of this interim action is to contain th~ site to
prevent the further off-site migration of ground water contaminated
by the site. Design of this remedy will also include adequate
documentation so that it can be demonstrated that ground water is
indeed being captured by the extraction system and not migrating
from the site.
The FFS described two different ways this alternative could be
implemented. The first was a combinati~n of ground-water
extraction down-gradient (or east) of the site and biological
treatment, followed by filtration and activated carbon adsorption
to meet the cleanup standards. After the biological treatment, 0.5
million gallons of water per day would be discharged to the
Publicly Owned Treatment' WQrks (POTW). The remainder of the water
would be reinjected to the aquifer after the activated carbon
treatment. This alternative was described as Alternative JA.
. . ..
~
Alternative 38 tconsisted of a combination of ground-water
extraction up;qradient(or west) of the site and in the interior of
the site. Ground water extracted from the up-gradient side of the
site would be treated with precipitation/clarification followed by
activated carbon to meet the cleanup standards. Ground water
extracted from the interior of the site (primarily for .gradient
control) would be treated with precipitation/clarification followed
by air stripping to meet the cleanup standards. . Following
treatment, the ground water extracted from the up-gradient wells
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.-.
I
-.------ .
GIaundiII8W
.....
.........
,.
'';
II
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'---------------------------~-----------l------- ------ I
I I I
. I
CIrMnI88tIr
=-
.-... ------.-.-- ...
Fill8I
I FUler
Calbon
Calbon
...... T'"
POrN
Sludge Disposal
..
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UJ9acienl
RaqecIIan
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-
"
C
i')
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-------
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......
~
.......
IGlnlConIIII .
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fa....
......
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SIte
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IRE
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~r II
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HaIcIng Tn
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. D.......
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All Emiliona Conlnll
(II '''''811)
--------------------------------------------------------r------1
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..... Tn
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.'.
SWge DIIpoI8I
Carbon
Carbon
I I
: .1
I I
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-----1-- J
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Downgradlenl
Rmjee*wl
,.,
-
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do
-------
-r-A Q I '.: '-
. , -- ~
DI~harge Criteria
Reilly Site, Indianapolis, IN
Volatile Organic Compounds
methylene chloride 5 19.07
acetone -I
chloroform 100. 58.SO
1 ,2~lchloroethane 5 95.36
j
2-butanone
bromodichloromethane 100
benzene 5 .. 30.20 ~
toluene 1000 14.83 ~.
ethyIbenzene 700 75.23 ~.
total xylene , 0,000
Pyridine DeltwallV88
pyridine ~ ~
2-p1collne 35*8. ~.
3 & 4-picollne ~ ".
2,6-Iutldine 35t1t .
2-ethylpyridine ~ ..
2.4 & 2,5-1utidlne 35tIt ...
2,3-1utldine ~ ...
~ 3-ethylpyridine 35tIt - ~
44hylpyridine ~ -.
"-" _.. ..
..~--_._.
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TABLE -5 ((01\,-
-..--.
--
Discharge Criteria
Reilly Site, Indianapolis, IN
3,5-1utidine 35'-t ~
3,4-Iutidine 3s<'t -t.
2-methyt-5-ethytpyridine 35tI8 ~
2-methyl-3-ethytpyridine 35toI ~
3-ethyf.4-methytpyridne ~ ~
Polynuclear Aromatic HyctrocarDons
~I naphthalene
1-methytnaphthalene
M8taI8
.'
aluminum
arsenic 50 4,000
barium 1 COOl"
beryllium 1
cadmium 10M 12QO<"
chromium ~ 24,000("
cobatt
copper 1,300 2.200'''
lead . . .. 5 4,700
mercury 1 25'
nickel 100 7,300
setenium 10M
silver 3S 4,200
- -_.. ---- '. --- . -'-.0- -.-.. ---. _.-
-------
TA1SL~ ~
\. ""..-.... . ~
.---
Discharge Criteria
Reilly Site, Indianapolis, IN
.
-
vanadium
zinc 38,000(.
Semi Volatiles
2,4-dimethytphenol
bis(2-ethythexyt) phthalate 4,200
3 & 4-dimethytphenol
:J. General Water Quality (mgn) (mgn)
ammonia. nitrogen 30
nitrate. nitrOgen 10 "*
kjeldahl . n~n
nitrite - nitrogen 1
nitrate + nitrite 10
phOSPhOrus'" 1
catdum
iron(QI 1
magnesium
manganese
potaSSium
sodium
hardness (as CaCO,>
..:.. chemical oxygen demand
total organic carbOn
---
-------
T ""-~ (. t:
":I
~ "'''f'W .
"
Discharge Criteria
Reilly Site, Indianapolis, IN
- -
total suspended solids'Q 25.30
biologicai oxygen demand'!) 25-. 30
alkalinity
pH 6.9 5 -10
specific conductiVity (micromhoslcm) 1,200
chlorides 250
~ sulfates .250
temperature
..:..
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23
'treatment, the ground water extracted from the up-gradient wells
would be reinjected 'to the aquifer and ground water extracted from
the interior wells would be discharged to the POTW.
u.s. EPA did not specifically select either of these options for
this Record of Decision. Although Alternative 3 satisfies the nine
criteria as being the most appropriate alternative for this action,
actual remedial design of this system will determine which of these
two options, and the specific design parameters for said option
(see Figure 7-treatment train for Alternative 3A and Figure 8-
treatment train for Alternative 3B), is the most appropriate for
satisfying the remedial objectives of halting' the off-site spread
of contaminants from the site and achieving the cleanup standards
listed below in the most expeditious manner.
:J
£xtracted ground water will be treated using the above methods to
meet the cleanup standards (-see Table 5-cleanup standards are
marked with asterisks). Cleanup standards are: benzene - 5 ppb:
pyridine - 35 ppb: pyridine derivatives (2-picoline, 3 & 4-
picoline, 2,6-lutidine, 2-ethylpyridine, 2,4 & 2,5-lutidine, 2,3-
lutidine, 3-ethylpyridine, 4-ethylpyridine, 3,5-lutidine, 3,4-
lutidine, 2-methyl-5-ethylpyridine, 2-methyl-3-ethylpyridine, 3-
ethyl-4-methylpyridine) - 35 ppb: ammonia (as nitrate) - 1,0 ppm:
trichloroethene - 5 ppb: ethylbenzene - 700 ppb: toluene - 1000
ppb: total xy1enes - 10,000 ppb: benz(a) anthracene - 100 parts per
trillion (ppt): benzo (a) pyrene - 200 ppt: benzo (b) flupranthene
- 200 ppt: benzo(k) fluoranthene - 200 ppt: chrysene - 200 ppt:
dibenz(a,h) anthracene - 300 ppt: indeno (1,2,3 -c,d) pyrene - 400
ppt. If at any time, any contaminants are present in the extracted
ground water other than those listed in this paragraph that exceed
a 10(-6) cumulative lifetime cancer risk, or MCLs for carcinogens,
whichever is more stringent: and MCLs, maximum contaminant level
goals (MCLGs), or a hazard index of 1. 0, whichever is more
stringent, for non carcinogens, addi~ionar- remedial work as
determined by U.S. EPA shall be performed.
'The point of compliance for these levels for this action only, will
be the site property boundary, as is illustrated in site documents
such as the RI and the FFS and is included in this ROD. While this
action will ensure that ground water will not migrate past the site
boundary, any ground water at the point of compliance must meet the
cleanup criteria mentioned'oabove.
.:..
Documentation of sianificant Chanaes
EPA published a proposed plan for this interim action on January
16, 1992, that selected Alternative 4 (slurry wall) as the
preferred remedial action. This selection was based on the
knowledge of the site and the Focused Feasibility study that was
prepared by Reilly and approved by EPA. ' In the FFS, Reilly
prepared a cost sensitivity analysis for each of the alternatives
to analyze the costs from three scenarios: an expected case, a low-
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24
;.I
cost estimate and a high cost estimate. This analysis was required
by EPA so that the' alternatives could be compared based on all
available data. In the FFS, it was assumed for the expected case
that 50%- of all excavated soils would have to be disposed of
offsite at a cost of approximately $12 million. EPA prepared a
memorandum dated February 16, 1992, which analyzed the major
component of the anticipated cost of slurry wall construction,
namely, the off-site disposal of excavated soils. The results of
this memorandum, which calculated expected contaminant
concentrations on the soils based on ground-water monitoring
results from the RI, appeared to indicate that the bulk of the
~xcavated soils would not be sufficiently contaminated to
necessitate off-site disposal, which would decrease this estimate.
The comments received during the public comment period are one
measure of the community's acceptance of U. S . EPA' s proposed
remedy. Comments received during the public comment period from
local utility companies as well as a slurry wall contractor
indicated that the costing analysis presented-in the FFS was not
entirely correct and that potential costs were dramatically greater
than initially estimated. Numerous comments from local citizens
also reflected concerns with EPA's remedy selection and voiced many
of the concerns that are outlined here. Potential disruption to
local utilities was not presented as a major problem in the initial
FFS; however~ the local gas company raised the comment that slurry
wall construction would impact their customers by removing from
service a vital transmission line that cannot be bypassed during
the winter season.
;0
Slurry wall cost estimates in the FFS did not accurately portray
the costs of rerouting electrical power lines, sewer lines, phone
lines, water mains, construction of a suitable roadbed for
emplacement over the completed trench where it crosses Minnesota
Street in two locations, operational traffic requirements imposed
by the City of Indianapolis for rerouting traffic while the slurry
wall construction proceeds across Minnesota Street, providing for
stability for the foundations of large active storage tanks along
the western boundary of the site, design of a railroad embankment
structure that could be rapidly emplaced over the slurry trench to
allow the use of active Conrail railroad tracks along the western
boundary of the site as well as lines entering the Reilly facility
used for transportation- of Reilly products, providing for vapor
suppression foam r to minimize dust and air quality impacts from
slurry wall construction, minimizinq construction impacts on the
residences located immediately adjacent to the northern boundary of
the site, work requiring Level C protective clothing (including
respiratory protection) and potential requirements of bedrock
grouting to ensure adequate connection to the shale bedrock.
Based on information received during the public comment period that
was not available to EPA at the time the proposed plan was released
for public comment as well as public sentiment towards the proposed
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.
;.I
..:..
25
integrity of the community, EPA has chosen Alternative 3, instead
of Alternative 4, as its interim remedial action for ground water
at the site. Alternative 3 consists of ground-water extraction,
treatment.. and discharge. .
statutorv Determinations
-
EPA and IDEM believe the selected remedy satisfies the statutory
requirements specified in Section 121 of SARA to protect human
health -and the envir-enment: will comply with ARARs (or provide
-grounds for invoking a waiver): provides overall effectiveness
..proportionate to its costs: _and will utilize permanent solutions
and alternate treatment technologies to the maximum extent
practicable.
Protection of HUman Health and the Environment
The selected remedy, Alternative 3, provides protection of' human
.bealth and the environment for' this ground-water operable unit
action by intercepting contaminated ground water before it reaches
potential off-site receptors. No unacceptable short-term risks
will be.posed by the implementation of the remedy.
The selection of treatment trains will be made in the design phasa
of the remedy. Any potential for cross-media impacts being caused
by treatment and discharge will be addressed in the desigp phase of
the- remedy, and will be prevented by. compliance with ARARs.
Treatment ~rains which ...f;reate a potential for such cross-media
impacts (e.g~, air-stripping) will be evaluated in the light of
such concerns and, if selected, will be required to comply with
ARARs. Discharge of treated ground water to the POTW is
contemplated, and compliance with ARARs will be required for any
such discharge.
Attainment ot Aoolicable or Relevant and ADoroDriate Reauirements
This action meets Federal and State ARARs specific to 'the
extraction and treatment. of contaminated ground water. Due to' the
limited nature of. this operable unit action, chemical-specific
ARARs for ground water and surface water will not be addressed,
except that ground water treated and discharged to the aquifer will
meet MCLs. SARA SectioR'~21(d)(4)(A) allows for selection of a
remedy not meeting ARARs when the remedial action selected is only
part of a total remedial action tha~ will ultimately meet all
ARARs. The National contingency Plan (NCP) as set forth at 40 CFR
300.430 (f) (ii) (c) (1) indicates that an alternative that does not
meet Federal or State environmental laws may be selected if the
alternative is an interim measure and will become part of a total
reme~ial action that will, when completed, attain the applicable or
relevant and appropriate requirements. ARARs specific to this
operable unit interim action remedy are listed below.
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:J
~
26
Chemical Scecitic ARARs
The remedy selected contemplates the discharge/recharge of treated
water ~ the aquifer. Therefore, compliance with ARARs for'
discharge to ground water, as summarized below, will be required.
-
-
The Safe Drinking Water Act sets Maximum Contaminant Levels and
M_aximum Contaminant Level Goals (MCLs and MCLGs) for public
drinking water systems. These are codified at 40 CFR Part 141
(Maxim~ Contaminant Levels). These are considered relevant and
-appropriate for water to be treated and discharged to the aquifer
as a result of this action. Although ground water is not currently
used as a potable water supply, it is a potentia~ future source of
potable water: therefore, the NCP (40 CFR 300.430(e) (2) (B»
indicates that it- is appropriate to treat the water to levels
consistent with future use as drinking water (i.e. to MCLs
established pursuant to the SDWA).
'The Indiana Department of Environmental Management (IDEM) has also
developed water quality standards to prevent degradation of State
waters. These standards are set forth, at 327 Indiana
Administrative Code (IAC) 2-1. Underground Water Standards are set
forth at 327 IAC 2-1-7. All ground waters of the State which are
a ,present or probable future source for public or industrial water
supply shall meet water quality standards.
The Resource Conservation and Recovery Act (RCRA) ground-water
protection~tandards are_set forth at 40 CFR 264.29 and 264.94.
These standards provide that ground water must be cleaned up to
meet 1) MCLs where such standards are available, 2) background
levels where appropriate, or 3) a RCRA Alternative Concentration
Level, which may be established for, a specific. contaminant for
which an MCL has not been established.
Action-scecific ARARs
The use of filtration to remove suspended solids or metals will
produce a solid waste which must be disposed of in accordance with
the applicable RCRA regulations. The Land Disposal requirements of
RCRA are set forth at 40 CFR Part 268.
Transportation requiremenbs for shipment of hazardous wastes are
applicable, and these regulations are set forth at 40 CFR 263, 49
CFR 107, 171-179.
The Underground Injection Control Program's requirements will be
applicable to the remedial action selected as a component. of the
action calls for the recharge to the aquifer by injection wells of
trea1;ed ground water.. The regulations set forth at 40 ~FR Part 144
are applicable. The Criteria and Standards set forth at 40 CFR
Part 146 are also applicable to this action.
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. .
27
state ARARs for underground injection of pollutants also apply
here. The. applicable regulations are set forth at 327 IAC 5-4-2.
Dependin~_on the' components selected in the design phase for
treatment of the contaminated ground water extracted from the
aquifer, the following regulations may apply:
--Chemical-specific ARARs for by-products of biological treatment
--40 CFR 268, regarding RCRA Land Disposal Restrictions,
disposal of spent activated carbon
--40 CFR 264.1032, Organic Air Emission Standards for Process Vents
pertains to air-stripping operations that emit total organics of
10ppm by we~ght or greater'
for
:J
State and local ARARs for Air Pollution also may apply (depending
on treatment components selected in design and weight of pollutants
emitted). These include:
--Indiana's Air Management Rule set forth at 326 IAC 8. Sources
emitting in excess of 25 tons a year must demonstrate compliance
with Best AvailableCon~rol Technology (BACT) requirements
The remedy selected will involve a discharge to the POTW~ state
Industrial Pretreatment Requirements require compliance with
~ 307(a) of the Clean Water Act (CWA). This requires notification
of the discharge of toxic pollutants in amounts exceeding the
limits defined by the Act and its implementing regulations.
--Indianapolis Air Pollution Control Board Permits. Sources that
emit in excess of 3 lbs per hour or 15 lbs per day are required to
obtain a construction permit and an operating permit.
Location-S08cific ARARs
The site is an operating RCRA facility. RCRA explicitly regulates
all storage, treatment or disposal of hazardous waste. Because the
site is a RCRA facility, the RCRA regulations are applicable to all
remedial actions undertaken at the site.
Because the remedy sele~ted for this interim action will involve
discharge to the l~cal POTW, which is off-site, the following ARARs
are applicable:
~
--40 CFR Part 122.42(b), NPDES Permit Regulations, requires the'
notification to the issuing authority of a re-evaluation of POTW
pretreatment standards (n.b., if the local POTW does not have a
local limitation for a particular pollutant to be discharged from
this Superfund site, then it must develop such a limitation to
prevent interference, pass-through, or inhibition, from occurring
as a result of the discharge).
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28
.--40 CFR Part 403.5, NPDES National Pretreatment Standards,
requires that discharge to a POTW not result in interference, pass-
~hrough of pollutants to receiving water or contamination of sewage
sludge. --
state ARARs for pretreatment include 327-IAC 5-11, limiting
discharges to POTW, and 327 IAC 5-13, regarding the applicability
of the Industrial Waste Pretreatment Program.
Cost-Effectiveness
The remedy selected will provide an overall effectiveness
proportionate to its cost by employing a readily available and
proven technology to contain and prevent off-site migration of
contaminants while treating the captured ground water to MCLs, or
.other levels, before recharge to the aquifer. While the operation
and maintenance costs for this remedy are higher than Alternative
4 ($1, 000,000 annually for Alternative 3 versus approximately
$500,000 annually for Alternativ& 4), the initial capital costs
expected for implementation are considerably lower (approximately
$5,000,000 for Alternative 3 versus $20,000,000 for Alternative 4).
~
utilization of Permanent Solutions and Alternative
Technoloaies to the Maximum Extent Practicable
Treatment
The intent of this operable unit is to provide effective
remediation of the potential threat posed by off-site migration of
ground water contaminated by the Site, while providing flexibility
in developing a final remedy for the Site. The remedy selected for
this interim action will contain and isolate contaminated ground
water at the Site until the source areas on-site can be thoroughly
defined, characterized and remediated. .
The threshold criteria, Protection of Human Health and the
Environment, and Compliance with ARARs, eliminated Alternative 1
from consideration. The need for pilot-scale testing and the
. uncertainties associated with the performance of Alternative 2
eliminated it from further consideration. Two of the five primary
balancing criteria, Lonq-term Effectiveness, and Reduction of
Toxicity, MObility, or Volume throuqh Treatment, indicated that
the remaining two alternatives presented in the FFS were
functionally equivalent.. . However, two of the balancing criteria,
Short-term Effec~iveness and Implementability, indicated that
Alte+native 3 was superior to Alternative 4, once the additional
information (not supplied in the FFS but presented during the
public comment period) was factored into the evaluation of
alternatives.
.:..
The. superiority of Alternative 3 over Alternative 4 when both
alternatives were measured against these two criteria was evidenced
by higher risks and greater difficulties in implementation
associated with Al ternati ve 4. The higher risks were attri~utable
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29
to the dangers of contact with contaminants encountered in
excavation of a trench for a slurry wall in an area proximate to
individual residences, while greater difficulties of implementation
were presented by the site I s location in an area where roads,
railways, and buried utilitiep made the construction of a slurry
wall a potential source of serious disruption to the community.
~
FErthermore, the considerations of state and community acceptance
also support the selection of Alternative 3, as a number of the
comments received ind~ated that the selection of Alternative 4
~ould present problems of community acceptance due to. potential
disruption of traffic and utilities in the area. The majority of
the comments received indicated a much higher level of community
acceptance for Alternative 3.
utilization of permanent solutions and alternative treatment
technologies was not considered practicable within the limited
scope of this interim action operable unit. Isolation of the site
~ill allow more flexibility for the study and design of permanent
solutions for the overall site remedy.
:.t
Preference for Treatment as a PrinciDal Element
The statutory preference for selection of remedial actions in which
treatment is a principal element is satisfied by the selection of
Alternative 3. Although this interim action is only in~ended to
contain and prevent migration of the contaminant plume~ pending
future operable unit remedial actions to address source areas on-
site, and despite the fact that this interim action will only
address chemical-specific ARARs to the extent that ground water
discharged to the aquifer will be remediated to meet MCLs, this
latter clean-up objective will be achieved by the use of treatment
trains whose specific components will be selected in the Remedial
Design phase. Because this action is an interim action that is
designed to control ground water movement, it is not designed to
treat the principal threats at the site. These will be addressed
in future source area actions.
EPA and IDEM believe the selected remedy satisfies the statutory
requirements specified in section 121 of SARA to protect human
health and the environment, attain ARARs (or provide grounds for
invoking a waiver), and utilize permanent solutions and alternate
. treatment technolQgies to the maximum extent practicable.
.:..
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APPENDIX A
Reilly Tar , Cb8Di.cal
Tn~iaft~lis, TndiAftA
~~
I. m'.SPONSIVENEss SCMM:ARY UYUWJ.&:iW
In accordarx:e with CERCIA Section 117, a public Cox '"'D.-TIt period was held fran
J~ 16, 1992 to March-31, 1992, to allow interested parties to cnI'ftrIIp11t on '
- the United States Envircnmenta1. Protection Aqercy I S (U.S. EPA' s) Focused
Feasibility Study (P'PS) an:i Prcposed Plan for an interim gramd-water l.~y
at the Reilly Tar and O1emi.cal SUperfund site. At-a January 23, 1992, public
meetin}, EPA an:i In:liana Department of Environmental, Management (IDEM)
officials presented t.be Prcposed Plan for grcurxl-water ~; ;:!tion at the
Reilly site, ~ questions and accepted c::cmment:s fran the public. '
Written OJl""-'ILs were also received thrcugh the mail.
:.I
.II. ~ OJ' CXHoIIJNI'n CX'KZRH
Reilly Industries is an ope.ratin} ~ facility located on the south side of
IndianapOlis, In:tiana: Reilly Tar & O'Il=IInical (its fODer name) was prcpcsed
for the NPL in 1983. '
'!here is a l~ history of ~nUty ~u abcut the Reilly- Tar &
CJ1emi.cal ("~ (l"ICW Reilly Industries). ~laints abcut pollug.cn fran the
site are ~~ as far back as 1955, when amoerns abcut c::ont:aminated wells
were made to the In:liana Depa;t:ment of Conservation. Indiana State Board of
Health tests-shewed c:xmt:aminai1t: iran Reilly in loc:::al c::lrinki.n:3'-water wells.
Consistent t"T'III'f'laints since then have revolved around water i~CII14;'S and air
pollution. '!he i ~CII" have received significant media attention all alc:n:J.
ID:. EPA'S ~ ~ AND I'l'S REtM':rCH 'm 'mB J'IHAL ReD
..:..
In a Prcposed Plan that wasi$.c::ned on January 16, 1992, U.S. EPA selected
Alternative 4, P\1lly Erx:ircli.n; Slurry Wall with aco .''l.anyjn;J Ground-water
Extraction, Treatment and D.iscbarqe. 'Ibis 1:ehcJJy was based on the infamation
presented in the FFS prepared by Reilly. I:m'iD;J the public o..ou.-nt period,
EPA received J'UJDIe.raJS, (). .....-at:s reg;mtin;J the selection of Alternative 4, most
of which were not favarable. 'Ibe majority of the Q .'D'_'its re0 .'D'_~ that
U.S. EPA select Alternative 3, Grcurn-water Extraction, Treatment and
Discharge. As a result of the -significant public 0......--4. received, which
included infcmlB'ticr\ that was net a~;bnle to EPA at the time the Prcposed
Plan was released, EPA has selected Alternative 3 for the Recom of Decision.
As a result of this ac:W.tianal infcmuaticn and the c::haD:Je in the selected
ra.:.ly, many of the ~ "'.'~"'fIts that were raised regarc:lin; the 1:~ selection
have, in effect, already been answered. However, EPA will att:enpt to provide
infcmnation relative to the ch.arge in i.~, c:leDa1stratin;J that public
~ playa large role in SUperfund 1:emedy selection.
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2
IV. - StJMHAmC OF SI:GNIFIONr CXHmHl'S IW.Zi.L vd) DtJRIR3 THE PCBLIC CXIo!MEN.r PERIOD
AND EPA RESPONSES
'!he I,.1Jllu.....,.Ls are organized into the following categories:
A. summary of OJlIU.R-'l.ts ~ potential di.srupt:i.on to the neigh):xJrt1cod
am local utilities, incl1.Xl.in;J safety am health c:on:::en1S
:J
1. 0 "'UI~Xlts were raised ~ di.srupt:i.on to the neigh):xJrt1cod fran
:increased truck am c:cnstruction traffic ani di.srupt:i.on to area utilities fran
the slurry wall installation activities.
U.S. EPA response 1: U.S. EPA ~ the CXJl'1CernS relatin; to the
potential di.srupt:i.on to the neighlxn:hood fran the slurry wall c:cnstruction.-
While the majority of the c:cnstruction work would occur onsite, the excavated
material wa.Ud remain onsite until final n;~ition was decinArl, ani ~~
would be taken to ensure that di.srupt:i.on would be minimal, EPA agrees that the
di.srupt:i.on to area utilities, i11cludiD;J gas am water mains that are vital to. -
area services, that would be as~iated'with slurry wall c:cnsauction is more
i:mportant than originally presented in the FFS. 'Ihe1:efore, potential 10lJ)-
tem benefits frail slurry wall c:cnstruction are outweighed by shcrt-tem
effects on the area.
;0
. 2. l"rItInIP1'1ts were raised regcmiin;J potential exposure to ccntaminated soil
that to be excavated for the slurry waJ.1 c:cnstruction.
,;,..'
EPA response 2: ~ typical slurry wall c:cnstruction activities, exposure
to excavated soils am wind-blam dust is minimized. Vapar-sl..lWressin;J foam
am water spray are tyr; ~, 'y used for soil piles to minimize exposure to
hamful emissions. TaJ:ps ani plastic sheetin;J are also typically used to
ccver the piles to prevent exposure to the elements. F1nally,. portable-
:instnIment:s are used to mnitor the air a.ra.n:l the excavation so that the
impacts of potential emissions on the neighlxn:hood are ~;1!1; '7.ed. ~11Se the
selected l:emedy was charJ;Jed to Altemative 3, this patSi1tial exposure shculd
be greatly r~inn:lti. However, '-1i:Ures will be taken to ensure that well
drilliD;J ani devel~.t. activities do net release potential cqntaminants i.nt:o
the air. Also, the site health an:i safety plan Will ocntain previsions for
m:ni.torin; the air space around each drill site so that human health an:i the
envircrment are ~~ly prctect:ed. -
B. ~ of O.....~I.ts ca~ cost of the 1J.'.~ L=u=dy
3. 0 .....~'1ts were raised regcmiin;J the estimated cxsts for AlteJ:native 4 an:i
their relation to the estimated costs for the other three alteJ:natives,
particularly Altenative 3.
..:..
EPA response 3: EPA based its decision on the L=u&Jy ccrrt:ai.ned in the
proposed plan on the infatmation that was available in the Site FFS. However,
based on infcmaation presented durin;J the public O.,.._.tt period, it does net
~.,. that the benefits of the slurry wall justify the added cxsts.
'lberefore, EPA has selected Alternative 3, as CAItlined above.
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3
c. SUnIDary of cnmment:s c:oncemin3' the feasibility, reliability,
c::onstruct:ability, am Other en;Jineerin; c::oncems of the proposed l:~Y
4. ~ were raised regardin; problems with slurry wall installation arx:i
mnitorin; such as difficulty in installin;J arx:i keyin; into bedrock arx:i
difficulty in ~ arx:i repairin; fractures arx:i breaks.
,
~t
EPA response 4: Slurry walls are r--njrg m::n:e o",u..1T\ in ~;~t:i.rq waste
. sites. Slurry wall installation prcblems are en",ul.IIU.Y addressed durin;
~; ,,~ design so that potential problems can be avoided. Water levels, both
inside arx:i outside of the slurry wall, are typically IOOnitored c::cnt:inuaJsly so
-that containment can be prcven. Slurry wall inspections typically consist of
evaluatm; mcnitorin; infmmation arx:i perfcmuance of soil :':itL~~ tests so
that slurry wall performance can be maximized. Fractures in slurry walls are
typically repaired by injectin; grout into the prcblem area or, in m::n:e
exu=ue cases, an entire section of the slurry wall is excavated arx:i repl~.
5. Several O'''D'_,tts stated that the installation of the slurry wall would
inFe ~bl efforts near the wall, that the installation wculd cause
grcurn subsiderD!, am peDBnent1y ;nF,:a the natural grcurn-water flaN'. '!bey
also 0 .""'~I«:ed that witbcut interior p.mpin;J, risin;J grcurn water levels waUd
cause the wall the eoll "p-, installation wculd cause an :increase in
ccntami.nant nx::i)ility, arx:i the slurry wall would be susc:eptible to eart:hquakes.
EPA response 5: ~ the difference in the grcurn-water elevation onsite
ana offsite would be miniJDaJ. (1-2 feet), there wculd not be 111IJCb ~ for
grcurn subsiderD!. '!be installation of the slurry wall would net 1~
~; "1 efforts near the wall because of the effects of the interior pmpin;J
am the resultant inwam grcund-water flaN', nor wculd there be any ''bathtub
effect" hecause of the ocnst:ant pumpin;. Slurry walls are o.''IP,:'u.y designed
to. withstarxi grcund-water pressure, ttc:tUlll Y by increasin; the wall thicknesS.
Finally, ccntami.nant nx::i)ility is ttc:tUllly net increased due to the ocnst:ant
II1ixin; of soils with the slurry in the c:onstJ:ucti.on U~dl. Earthquakes are
not a prr::i11em with soil bentonite slurry walls ~1Se-they are flexible arx:i
if the wall does net cross an active fault line, are not a detriment.
6. O....-rt;Qrs raised ~ over health and safety i9-c:t- such as children
faUin; into the slurry ut::dcn, physical ncvement of the contaminated soil,
arxl the fact that clay is net ~cus. .
..:..
EPA response 6: Canstmction of a slurry wall does not include an "open"
t.rend1 such that pecple cculd fall in. T.II:a..JJeS are excavated and i~btely
filled in with a soil slurry such that these activities are aJ.Dcst
si:al1l.tanecus. Not all of the excavated soil wculd be contaminated arx:i all
excavated soils wculd be piled near the t..~m until n;~itian. Clay is not
iJlpervicus, but it is ;~nN:»ahle ezru;Jh to effectively stq) grcurxi-water .
flaN', especi" 11 Y when ccmbined with an extraction system. .
7. Several 0 .....-Ilters stated that the slurry wall c::cnst:nJcticn cculd take 2-3
Years to cx:mplete, not 6-12 Da1ths as was stated in the prcposed plan.
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:.I
~
4
'EPA response 7. EPA disagrees with this tY'InIITIP-"It in that a ex.ll.D..eJ1t received
fran an indeperx1ent consultant stated that their estimate for ccmpletion of
the slurry wall was ~tely 9 nart:hs.
D. SUImDary of 0 '''D'~ c:cncemin;J the equivalent perfcmnance of Alternative 3
-
8. Many 0 M'D'~ stated that Alternative 3 provided the same benefits as
Alternative 4 and, since it was less costly, slDlld be selected.
EPA response 8. Based on-infcmDation received du.rirg the public ex MID..o:>1tt
- period, EPA agrees that Alternative 3 provides the best balance and is the
-1IOSt a~~late .L~y for this action.
9. A 0 .1D..AYltcr' stated that Alternative 3 would JIaint:ajn the natln:al grcun:l-
water flew while Alternative 4 wa.1J.d not.
EPA response 9. EPA disagrees with this c..'I'D'~J'1t because both alternatives
wal1.d alter the natln:al groun:i-water flew across the site. By doin:j this,
-which is the goal of this action, the site is isolated -am. 8rrf Reilly-related
ccntaminant:s are prevented fran migratin:j offsite.
E. SUDmary of o....-.It c:cncemin;J the prciJlem of off-site cantamination
10. Several (~.....~1Itors stated that the presence of the slurry wall wculd
block the ability of the wells installed onsite to draw, the off~ite plume
back to the site. .-
EPA respanse-10: '!be goal of-this interim action is to isolate the site so
that no site-related cantamination can migrate offsite. Na1B of the
alternatives were designed to draw 8rrf off-site cantamination back to the
site. '!be perfm:mance goals for Alternatives 2, 3, and 4 are to pmp just
enough groun:i water. to contain the plume at the site1:lc:un:1a!:y .
11. A. ~ ~1D._.&tar stated that the off-site plume cculd migrate further with the
installation of the slurry wall.
EPA response 11: EPA disagrees with this O..a._IIt. '!be presence of the slurry
wall or the grcunr::l-water extraction system \oU1ld net cause 8rrf aa::elerated
off-site plume ucvement. By isolatin:j the Reilly site so that further
degradation to the aquifer is prevented, the off-site plume would not increase
in size and extent and ~~ waU.d decrease in the future.
12. A o.'.'-Ilter stated that the installation -of the slurry wall wculd delay
TNCrk 'on the off-site plume until ~tional public hearin:;Js we%'e held. 'Ibis
same c" ...._-,ttor considered Alternative 3 as bei1'1g able to part1ally clean up
the off-site plume. ' .
EPAresponse 12: Alternative 3 was net designed to clean up 8rrf off-site
cantamination. '!be off-site plume will be the subject of patential f'ut:LU:e
rl:lt,w:v'1i::l1 activity so that all risks posed by the Reilly site can be addressed.
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5
13. A ccmmentor stated that the neighboJ:hood should be cleaned up first ani
that EPA should reconsider their plans to help Reilly with this action.
EPA response 13: '!be off-site plume will be addressed through future actions
as stated previously. EPA is not .helpin;J Reilly with this action. EPA is
taJcin; steps to correct the contamination problem at the site that has existed
for many years. '!his is the first step towards the ultimate goal, maJd.n;J the
Site safe.
F. SUmnm:y of 0 mu._lrt:s COl'1CeI:T1in;J SUR;mt for the P1.0~ alternative
14. Several ~'1tors stated that they believed that the proposed
alternative wa1lcl provide greater protection against off-site mvement of
cont:aminants and that Alternative 4 would be preferred if EPA didn't think
Alternative 3 wculd be effective.
:J
EPA response 14: EPA expressed ccncem that if the extraction wells under
Alternative 3 failed, cont:aminants would migrate offsite. D.1rin; the public
.camnent period, EPA received infomaticin that provided assurances that this
would not haQ?en. '!his infomation, which would be incarporated into ~b'
design activities, included the installation of sister plmps, the
establishment of overlappin;J cones of influence, and the availability of
bacJoJp generators, which was not included in the FFS that EPA approved. With
this additional infomation, ani. the proper ~i"J design, EPA believes that
Altemative 3 will ac:x::cmplish the goals of this action.
15; A o....u.-.d;or stated that because Reilly ccntinues to spill contaminants,
the slurry WAll is better.
EPA response 15: Bath Altematives 3 and 4 will contain the site and c:antain
spills through the installation of the ccnt:ainment system.
G. SUmmary of (} ...u.-ttls c:ancemin;J mechanical j c:c:n~ related to Altemative 3
16. Several 0 ....._~ &tors stated that sister Punt:s cculd be :inst:al1ed to ensure
the reliability of Altemative 3.
EPA response 16: EPA did net pass-oos this infcmuation at the time of the
ciraft:in;;r of the pt~ plan. Based on the sum; ~Qion of this, ani other,
inforinatian, EPA agrees ani has. selected Alternative 3 as the remedy for this
action.
. . ..
H. SUmnm:y of <> "'.'~nt. ccncernin;J the need for cleanup at the site
17. A 0 ...u.-. Iter asked if the Site wculd ever be safe.
..:..
EPA response 17: Eventually, after all. of the scurc:es of contamination are
addressed, the Site will be safe. '!his grcun:I water interim ~~ is the
first- step tcwarc1s ac::hieviJ'q this goal.
18. Many o..u._trt;cm stated that none of the proposed alternatives would make
the grc:un:i water safe to drink.
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6
EPA reSponse 18: '!be goals of SUperfund are to discover contaminated sites,
am remedi.ate the contamination problems posed by those sites. Because the
wealth of infomation on off-site ccn:iitions was collected ciurin; t:iJDes that
Reilly contaminants were beiIx; bIb.. dtl~ into the grourxi, the risks
associated with drink:in;r the grourxi water without the presence of Reilly
contaminants is not kna.m. 'Ibis infomation would be useful to collect after
tl1e extraction system is operational am will be a part of. the ~i ::\1 design
so that the effectiveness of tl1e extraction system can be verified.
19. Several camment:ors stated that cw::~ent operations are not contrilJutin;J to
tl1e contamination problem am others asked if the p.mIpS installed by Reilly
would clean up the site. .
:J,
EPA response 19: Levels of contamination that were foum in off-site wells
are similar to levels that were present in samplin; done 10 years ago. '!be RI
identified a plume of ground water. contaminated with benzene, pyridine, am
anm:m.ia that is centered arcun:l active Reilly facilities. EPA does not krxM
of arrf pumps that have recently been :i11stalled by Reilly: if they were
designed to clean up the site, tl1e RI resw.ts would have shewn this.
20. A O...a.~ stated that, if left alane, tl1e grc:un:i water would be cleaned
up by natural biodegradation.
EPA response 20: If the source was reaxwed, this wa1ld be true, but it wa1ld
take many many years. If the source is not removed or ccntained, then this is
net true. 'Ih1s statement can be made for many sites, but EPA has been ~
with the task of e.~i tin;J cleanups so that risks posed by contamination can
be minimized or elimi1'1ated.
21. A Cu.an~"ltcr stated that Reilly is ~.e:ntly takin; measures not to
release contamination. .
EPA re;:.panse 21: EPA is not aware of these activities am, if this is true,
they will assist the eventual site cleamJp. -
I. ~ of o....-nts ccncem:iD;J the need for source ~uL..ul at the site
22. A v..anA1'ltcr stated that this ~bl action does not provide for
trea'bnent of on-site som:ces.
EPA response 22: 'lhis action does not addresS treatment of on-site saIrCeS.
Source ~lL..vl, as is a.ttliriedln the RJD, will be the subject of future
actions at the site.~
..:..
23. A <> ..a.~tttar stated that Alternative 2 is the best altemative after the
actual release is ~,
EPA response 23: Bench- am pilot-scale testin;J wa1ld be neanM before the
effectiveness of Altemative 2 cculd be accurately j~. However, it does
net ~ that with ClA.I.J::ent grc:un:i-water conditions, there is sufficient time
or diStance for bi"'-l........::..ibtion to work effectively.
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,.
7
J. Sunmmy of comments conceming other issues not related to the other
categories of cc:mnents listed here .
2.4. A ~r stated that the selection of Alternative .4 would cripple
voluntary cleanup action in the In:tianapolis area.
EPA response 2.4: EPA cannot ccmnent on this statement but SUperfurxi sites
typically require remediation of contamination problems that are very
extensive an:! costly to fix.
25. A c:Cmmentor stated that lan:ifillirg of the excavated sluny trench soils
_does not reduce the vol\mle of contaminants.
EPA response 25: EPA agrees with this ~ntor an:! with the selection of
Alternative 3, this potential problem will be avoided.
26. A ccrmnent:or stated that after grouni-water treatment, Reilly could
provide clean grc::Jl.1nj water to their neighbors.
:.1
EPA response 26: '!his possibility was not d;~lSsed durirg the FFS. It
appears unworkable. G:rcuni water will be treated to regulatory stamards an:!
discharged to the Publicly OWned Treatment Works or recharged to the aquifer.
27. A ccrmnent:or stated that the source of the contamination would be located
an:! remediated eventually so current action is unnecessary.
EPA response 27: While the source of the contamination will event:Ul!1.ly be
~iated, this action will address risks posed by grc::Jl.1nj-water contamination
that have been detemined as unacreptable by EPA stamards.
28. Several comment:ors stated that this action will do~ to address the
neighbors I conce:rns about odors am property values.
EPA response 28: '!his action is the first action to address the contamination
problem at the Reilly site. '!here will be other actions that will be taken so
that eventually, the site will no lcn;Jer pose a threat to human health or the
enviJ:01~L.=ut. Odor problems are the result of current operations am are
subject to the Clean Air Act regulations.
29. A o.JIIUI~.tor asked if the state really had a role in .L~ selection.
EPA response 29: '!he State has..been intbuately involved in all rH~1Ssians
regardirg the. Site. ~ '!hey have atten:led all negotiatirg meetin1s am have been
provided the OH;Ortunity to ~nt on all technical documents proonced by
Reilly. '!he State commented on the proposed plan an:! the ROD, am their
cancerns have been addressed. 'lh1s is evidenced by their letter of
concurrence that is attached to the ROD for this action. .
~
30. A cc:mmentor stated that the best use for the grourxl wa~ is imustrial
process water.
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:J
-:..
8
-
EPA response 30: '!be goal of ~;;..] action at the Site is to address the
grourxi-water c:cntamination problem ard through treatment, to re:fuce to
acceptable levels the risks associated with exposure. Followin; this, the use
of the ground water is net restricted as l~ as the risks are within
acceptabfe levels.
'!be O]"UI~nts are paraphrased in order to effectively summarize them in this
.iiOOlment. '!be reader is referred to the public meet:iJx} transcript which is
available in the public information repository, located at the Irdianapolis
~ic- L:i1JJ:m:y, 48 Fast St. Claim, Irdianapolis, Indiana. Written cu.u._..t;s
- received at EPA's regional office are on file in the Re;j.on 5 office. A CJ::1fJY
- of these written 0. ...u.~rrts has also been placed in the In:tianapolis Public
Libraty .
..
. . ..
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~I
..:..
JOCI
DATE
----
----
1)0/00/00
2
03113184
00100/56
4
12/0G/86
5
02/18/87
b
03/31/87
i
05;22/57
3
08/00/87
9
08/00/87
10
08/27/87
11
11/11 187
"'I
lJ.
u.s. EPA ADMINISTRATIVE RECORD INDEX
ORIGINAL
REILLY TAR & CHEMICAL CORPORATION
AUTHOR
------
McLaughlin. Ii.,
Reilly industrles
U.5. EPA
Bennington, 11.,
Marion Ctv. Health
Deparhent
ERT (noli £1/5R)
COOK, r., , DONney,
R., Process
Engineerlng 5roup
~~.
U..:. tt'H
Rivers, r., Reilly"
Industries
U.S. ErA
CH2" Hi 11
U.S. ErA
:ii2" Hill
12/00/87 "Reilly Tar &
Chelllca; Cerp.
13
1975--67
14
00/00/88
U.S. EPA
INDIANAPOLIS~ INDIANA
RECIPIENT
---------
---------
Reilly Tar &
Che.lcal Corp.
U.S. ErA
Lraun.~ Jt~ Reill;
Tar & C~elical Corp.
Reilly Tar'
Che.ical Corp.
5ickels, M., IDE"
U.S. ErA
U.S. EPA
U.S. EPA
06/18/92
".
TITLE/DE5CRIPTION
-----------------
-----------------
Statelent
HR5 Scoring Package
Oak rarK Health Stud!
~IIF5 ~orK ,., an
Findings of Preli.inary Subsurtace
Investigation
Ad.inistrative Order by Consent
RevieN ot Keeting and Tour at Site
fJoOR QuALIfY
ORIGINAL
Fact Sheet: Reilly Tar & Chellcal 3egins
Re.eaial investigation & Feaslbility Study of
Superfund Site
Final CO.lunity Relations Plan
NEMS RELEASE: ErA to Brief Residents on Reily
Tar Superfund Site
Evaluation of Potentlal 8ft Site :(;~taainar.t
50urces--Finai ~eport
~~CHNICAL ~tKORANDUH: ~aste Characterization
for the Reilly Tar & Chelical Corp.
List of Docu.ents Copied tor Each ?RP
Facility--~oculents Follow List
Fact Sheet-Fall: Progress Report
?'~~~
. Hilt:!
-----
.,
..
.3i
. .
:.1
41
27
~
to
J
61
74
36
284
2
-------
\1
...:..
:J~i
.,,,,c,
----
----
, c
1...:
':1')/00/86
l~
(:2/00/88
. ~
- I
:.2/00;88
is
;2/00/88
i9
09/22/68
20
10100/88
21
WOO/88
.;...
1:/00/38
?~
..:!
01/00/89
24
03/00/89
25
03/00/89
26
03/00/89
27
11/00/89
:8
:1100/89
29
lliOO/89
30
11/16/89
31
01/00/90
32
01112/90
,::.' ':-;~
"".J IMwl";
------
.ow. crA
-~I""~
c,,~t\
::\S.iL
.-~''''''''
:.iJII
HinCheY~ n., :H2M
Hi il
ENSR
::N5R
E~5R
ENSR
ENSR
ENSR
ENSR
ENSR
::",SR
ENSR
Cruciani~ C., CH2"
Hill
U.S. EPA
3aker, R., IDE"
.-011....,,-...
"t1...r'~:J~1
---------
---------
,.....
w.;" :rH
.:.;" i:r'k
U.S. EPA
Novak, ~.~ u.~. ErA
U.S. EFA
U.S. EPA
c'.". ::rH
u.s. ErA
U.S. EFA
U.S. EFA
U.S. EFA
U.S. ErA
u.s. ::rA
U.S. EPA
Novak~ D.~ U.S. EPA
. .
Novak, D.~ U.S. ErA
~~TLEjDE~CR1FTrGN
-----------------
-----------------
'act 5le~t-~ioter: ?~ogress or ~l!F5
Health ~ Saf2ty Pian ,~. Grcunc
Ndter ~ 3urfa~e-water Sa;pjl~g lD tne Vl:l~:-
tv of Rei;;y Tar & Cn2~lcaj
Phase j EfivIronmental Sampling rlan
GAPP fer R liFS
TechnIcal Me~oranau~: Dversignt of Pnase i
Envircnaental 5aapiing Progra;: ComparIson OT
Split SaQpje Analyses
TECHNICAL HEHGRANDUH: Phase i Environaentai
Saapling Prograll
Phase Ii ~ork Pian (Final): ~j
i;:MNi~AL MEnunANDUH: ~ater Level ~cnItcring
Prograll iF ina; i
iECHNICAl MEMORANDUH: Geophysical
Explorahcl1s
Phase II Project Operations Flan for RI/FS
Fhase II Project Operations Flan for RIiFS:
Appendices H - E for gAPP ..-
Phase II uAFP
TECHNICAL HEHORANDUH: HYdrogeologic Study
(Task ~.3j
.
TECHNICAL HE~ORANDUM: ~agnetc:etrv
SurveY-LIme Feno.Area
TECHNICAL MEMORANDUM: Surface Water Drainage
Evaluation Study (Task) (Final)
Technical He.orandul: Co.parison of
Co-located Sa.pie Analyses, Phase II Rr~ Ruu-
nd I 6roundwater Sa.pling nesults
Fact Sheet: Progress Report
Phone Conversation FollDwup ne: Agreed urder
between Reilly & IDEH
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(TasK 9.1)
JNSI6NED. NON-LETTERHEAD
COlments O~ Draft Phase 11; WorKPlan: Rl
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Agreed Jrder & the Tank 66 Spill
Phase III Project Jperatiqns Plan for RIIFS
DRAFT-Monthly water Level Measurements
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during. Phase II Drilling at Lile Pond Area
Public Notice and NeNspaper Article He:
Public Meeting
Technical Melorandul: lIagnetoletry
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Investigation Progral--Task 9 (Finali
UNSI6NED~ NON-LETiEnHEAD
Transllttal of Keiorandul negarding Risk
Asesslents Pert Dried oy PR?'s
Request to be Added to Kailing List
Review COllents on Draft RI Report & RCRA
Final RFI Phase III Release Characterization
Report
COltents on the RI Report
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RCRA Final RFI Phase III Release
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U.S. EPA
U.S. EPA
Novak, D., U.S. EPA
Novak, D.. U.S. EPA
Prosser, K., IDEM
j!TLEJD~S~~!?T!DN
-----------------
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Status er ~PA Comlents on urait Hi
RisK Hssess~ent Concerns & COllents
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RFI Phase iII Reiease Characterization
TECHi-J I CriL :iEHORAHuun:
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(TaSK 1.,
Draft RI Report-Response tc Co..ents & Revis-
ions ana Request for ExtensIon
Reiteration of Issues Re: Feasibility Study
Work Plan
Modeiing Tor Bridgeport Brass Worier tXpos~~~
Response to Request for Extension
Revised CERCLA RI Report & RCRA RFI Phase III
Rel~ase Characterization Report ifor Facliity
SWHU); Vol. II: Appendices A & B
ReviseD CEF.CLA RI ReDort & RCRA RFI Phase III
Rel~ase Characterization Report (for the
Facility SWHU)j Voi. IiI: Appendices C-F
Draft RI Report-Response to COllents & Revis-
ions and Request for Extension
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aroH, K.. &
~ielens, R., ENSR
(rulnansl, II.. ,~
Clelens, R., ENSR
Prosser, K., IDE"
Novak, D., U.S. EPA
Novak, D., U.S. EPA
Novak, D., U.S. EPA
Novak, D., U.S. EPA
Novak, D., U.S. EPA
Krulhansl, R., i
Clelens. R., ENSR
Novak, u., u.S. EPA
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R. ~ ~ :iSR
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:;iLE/DE5CR~PTIDN
-----------------
-----------------
~~ViEw CJ~~ents un KEVIsea CERsLA RI Reoort ~
~CRA RFI Phase iii ~eiease Character::ation.
~Epurt :icr Facliiry S~Mw)
~~VIew LOi~entS un ~eviseo K1Ef. Mssess~ent
C~mlents to RevIseD CEhCLA RI ~eport ~ ~CRA
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;: a ci 1 i ty SWHU i
RCRA CCllents on the Alternatiye Array
Document
Scheduie for FFS
S:oDe of ~ork for Collecting Certdi~
SrounoMater Quality Data
JeSCflD!IOn of Approacn to Responses to
COllents & Clarification of Schedule for
Final RI
ARARs for Reilly Industries
JNSI5NED, NON-LETiERHEAD, uNOAiED-
Response to COllents on Need for Additional..
broundNater guali ty Data .'
UNSI5NED, NON-LETTERHEAD-
COllents on toe Contents of FFS
sOllents on the Draft AR Document
UNSI5NED, NON-LETTERHEAD-
Extension for Final RI Approved
Response to Request for Extension
Keeting Notes: Oversight rroject
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LA RI i RCRA RFI Phase III Release
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industries
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32 ,",- '...... '''''1 2.a~er. mi~ ~~ovilk, U" (.:.5. E?A ~=viejj CCllllents on iJraft FF5 for 5rour,oICater ~
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10/11/91
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-----------------
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tr,e "I"'~
f~ovak, D" J.3. ErA
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Novak, D.~ ~.S. EPA
Rivers, P., Reilly
industries
Novak, D., U.S. EPA
~ecelPt or In;crf.ation hejating to ~2QUest
for EXte~slon fJr ResuO~1ssiQn of FS
:o~.ent Response Summary of Draft F~S
Review or Alternatives uffered in FFS
Llmits for ryridines & Allonia
Review of Response to EPA Comlenes on FFS
COllents on Revised FFS
104 lei/16/91 ~ovai.:. 0., EPA Rivers, P" Reilly Preliminary Review of the Revised F~~
u.;" r:.
industries
. :" = i.G/22/91 :iovai;. U.S. EPA K1vers, ?, Rei;; y CuHents on tr!e ~,ev 1seo FFS
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industries
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106
Clelens, R., ENSR
10/22/91
107
10/28/91
Clelens, R., ENSR
Novak, D., U.S. E?A
Novak, D., U.S. EPA
108 10/30/91 Novak, D., U.S. ErA Clelens, R., ENSR
109 11/00/91 ENSR U.S. EPA
110
11/01/91
:1elens. R., ENSR
111
11/05/91
NovaK. D.. U.S. EPA
112 lli07/91 r' R., ENSR
"Jeuns,
I ~., 11/14/91 Cielens, R., ENSR
.~.J
114 11/18/91 BaKer. R., IDEM
115
l1J27/91
Novak, D.. J.S. EPA
NovaK, D., U.S. E?A
Cielens, ii., ENSR
Novak, D., U.S. E?A
Novak, D., U.S. E?A
~ovak, D., U.S. E?A
Rivers, P., Reilly
Industries
Responses to COllents on Revised FFS
Revisions to FFS
Response to COllents Regarding Major issues
to the Rev i sed FFS .'
Final FFS for the Groundwater Operable Unit
Interi. Remedial "easure
Response to Unresolved Issues Re: Revision of
FFS
CO'lents G~ 11/1/91 letter Re: Sublission of
Final FFS
Cover to FFS for the Groundwater interi.
Reledy and Response Letter
Response to Questions' Requests by EPA on
FFS
CO.lents' on the Revisions to FFS
Review of Final FFS
7
POOR QUALITY
ORIGINAL
':~GES
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01/23/92
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:ndustries
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?olaci, R,~ Reilly
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Geotechnical Group
Reilly Industries
Carrasquero. P.,
IDE/!
~ECjFIE~ii
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. . ".
;rTLEiDE5CR!Fi!~N
-----------------
-----------------
~yree~ent Wl:~ ~Ecc;~enoaci~r. DT Alternat:,e
4 and other C~~.ents
Fact Sheet: ;roQosaa ;:3~ for inter:~
?eleoiai ~cti~n
Various Cc~.enrs on rranDsea uotians Tor
Rellediation
NEWS RELEASE: ErA 5eeks COilenrs on ~uperTur.d
Site; Public Meeting 1/23/92
Notice of Public ~eeting
Statuent
iranscript: Public Heeting RegarDing j~teri;
Reudia! Achc;'!
~eQuest fer txtensico 01 rublic ~OJlent
PerioD on ProposeD Fia;'! for interia Re~eaial
Action
Construction Analysis & Cost Estilate:
Appendix 1 and Appendix 2
Forlal COllents on EPA Remedial Action
Decision
Additional Infor.ation for Groundwater
~istharge Lilit Deter.ination
;AGE5
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-------
REILLY TAR GUIDANCE DOCUMENTS
(These documents may be viewed at Region V Headquarters)
06/16/92
DDC' DATE AUTHOR Doc,.," II TITLE/DESCRIPTION PA6ES
---- ===:1 ====== - --------- ================= -----
---------
01127/86 U.S. EPA 9355.1 Drift: Federil-leid Re.edial Project "anige.- 0
ent Handbook
2 03/24/86 U.S. EPA 9260.1-9 Delegation of Re.edy Selection to Regions 7
3 11/07/86 U.S. EPA 9285.4-01 Superfund Public Health Evaluation "anuil 0
4 12/24/86 U.S. EPA 9355.0-19 Interi. Guidance on Superfund Selection of 8
Ruedy
5 02/12/87 U.S. EPA 9875.4 Interi. Guidance: Strea.lining the Settle.ent 0
Decision Process
6 04/22/87 U.S. EPA 9285.4-02 Guidlnce for Coordinating ATSDR Health 22
, Assess.ent Activities .ith the Superfund
Re.ediil Process
)J
7 07/21/87 U.S. EPA 9375.1-09 Interi. Guidince an Stite Pirticipation in 23
Pre-Re.edial and Re.edial Response
B 07/98/87 U.S. EPA 9234.0-05 Interi. Guidance on Co.pliince .ith ARARs 0
of":
9 05/16/88 U.S. EPA 9835.1A Interi. Guidance an Potentially Responsible 34
Pirty Participition in Re.edial Investigation
and Feasability Studies
10 06/00/88 U.S. EPA 9230.0-038 CO.lUnity Relations in Superfund hind book 190
11 08/00/88 U.S. EPA EPA/540/G-89-006 CERClA Co.pliince .ith Other Li.s "inuil, 246
Pirt 1 (Interi. Finil)
12 10/00/88 U.S. EPA 9355.3-01 Guidance for Conducting Re.ediil 195
Investigations' Feisability Studies Under
CERClA-lntlril Finil
.
13 10/00/88 U.S. EPA . EPA/540/6-89-004 6uidance for Conducting Reledial 195
. . .. Investigations and Feasability Studies
(RI/FS) Under CERCLA
14 12/00/88 U.S. EPA 9283.1-02 Guidance on Reledial Action for Contalinated 180
Ground_ater at Superfund Sites
..:.. 15 02107/89 U.S. EPA 9835.2A Revisions to the Interil Guidance on PRP 37
Participation in Re.edial Investigations and
Feasibility Studies
PooR QUALITY
ORIGINAL'
-------
DOC' DATE AUTHOR Doc'. # TITLE/DESCRIPTION PA6ES
===8 ==== ------ --------- ================= -----
--------
Ib Ob/OO/89 U.S. EPA 9355.3-02 6uidance on Preparing Superfund Decision 21b
Doculents: The Proposed Plan, The Record of
Decis~on, Explanation of Significant
Differences, The Record of Decision
Alaendlent
'j CERCLA COlpliance with Other Laws "anual,
17 08/00/89 U.S. EPA EPA/540/6-89-009 17b
Part 2: Clean Air Act and Other Environ.ental
Statutes and State Requirelents
18 12/27/99 U.S. EPA 9234.1-06 Applicability of Land Disposal Retrictions to~ 5
RCRA , CERCLA 6round Water Treatlent
Reinjection Superfund "anagelent Reie.
Recollendation '26.
19 06/04/90 U.S. EPA 9230.0-06 Superfund Responsiveness SUllaries 190
20 08/28/90 U.S. EPA 9835.15 Perforlance of Risk Assesslents in Reledial 4
Investigation/Feasility Studies
21 11/30/90 U.S. EPA 9230.0-20 innovative ftethods to Increase Public 5
Involvelent in Superfund COllunity Relations
22 12103/90 U.S. EPA 9833.3A-l Final Guidance on Adlinistrative Record's for 110
Selecting CERCLA Response Actions
, . '.
23 04/22/91 U.S. EPA r9355.0-30 Role of the Baseline Risi Assesslent in 10
Superfund Reledy Selection Decisions
A'
.:..
POOR QUALITY
ORIGINAL
------- |