United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-93/237
September 1993
PB94-964109
SEPA Superfund
Record of Decision;
Reilly Tar & Chemical
(Indianapolis Plant), IN
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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R05-93/237
2.
3. Reclplenra Accesalon No.
4.
TItle and Subtitle
SUPERFUND RECORD OF DECISION
Reilly Tar & Chemical (Indianapolis
Second Remedial Action
Author(s)
5.
Report 0818
09/30/93
Plant), IN
6.
7.
8.
Performing Organization Rept No.
9.
Performing Organization Name and Add....
10 Project TukIWork Unit No.
\/
11. Contract(C) or Grant(G) No.
(C)
tG)
12. Sponsoring Organization Nam.and Add-
U. s. Environrnenta.l Protection
401 M Street, S.W.
Washington, D.C. 20460
13, Type of Raport & Period Coyered
Agency
800/800
14,
15. Supplementary Notes
PB94-964109
16. Abetract (Umlt: 200 wordl)
The 120-acre Reilly Tar & Chemical (Indianapolis Plant) site is a former coal tar
refinery and creosote wood treatment plant located in Indianapolis, Indiana. Land use
in the area is mix,ed. residential, industrial, and commercial, and residences are
located immediately adjacent to the eastern boundary of the site. The site is divided
into the 40-acre Oak .Park property, which contains the majority of the operating
facilities, including above-ground storage tanks, distillation towers, and above-ground
and underground utilities; and the 80-acre Maywood property, which contains operating
facilities on its northern end. This site formerly was used for chemical. processing
and wood preserving activities and currently contains five former waste disposal areas.
From 1921 to 1972, coal tar refinery and creosote wood treatment plants operated'
onsite. Beginning in 1941, several chemical plants were constructed and operated on
the Oak Park property. 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 surface water samples. .In
1975, State investigations identified several onsite problems believed to be
contributing to ground water contamination with organic chemicals, and further
investigations, conducted in 1980, revealed various organic chemicals in soil. In
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Reilly Tar & Chemical (Indianapolis Plant), IN
Second Remedial l~ction
Contaminated Media: soil, sludge
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics (PARs)
b.
Identifiers/Open-Ended "errns
c.
COSATI FlalcUGroup
18. Availability Statament
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
100
22. Price
(See ANSI.Z39.18)
s.. Instructions on Revf1rS8
OPTIONAl FORM 272 (4-77)
(Formarty NTIS-35)
Department of Commerce
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EPA/ROD/R05-93/237
Reilly Tar & Chemical (Indianapolis Plant), IN
Second Remedial Action
Abstract (Continued)
1987, an accidental spill of 60,000 gallons of waste fuel Occurred at the Oak Park
property.. Some of the spilled fuel oil was recovered, and some of the contaminated soil
was excavated. Investigations have identified five former waste disposal areas: the Lime
Pond area, which received chemical process waste from 1953 until 1965; the Abandoned
Railway Trench, which was filled in the 1960s with drums of coal tar enamel and foundry
sand; the Former Sludge Treatment Pit, where wastewater sludge from the coal tar refinery
and synthetic chemicals operations was dried from the 1950s until 1979; the Former
Drainage Ditch, through which wastewater and stormwater were conveyed from the site to a
sewer system; and the South Landfill and Fire Pond, where construction debris and various
solid and semi-solid wastes, from the coal tar and the synthetic chemicals operations,
were deposited. Site contamination was found to be related to the improper use and
disposal of creosoting process wastes and ,substances used in manufacturing chemicals. In
1990, a RCRA facility investigation resulted in an interim measure to minimize risks to
wildlife, by regrading and covering the eastern portion of the south landfill and placing
plastic netting over the fire pond, which was completed in 1992. Also, in 1992, 149 drums
were removed during field activities at the Lime Pond area, and an interim ROD was signed
that addressed containment and treatment of contaminated ground water, as OU1. This ROD
addresses the contaminated soil and sludge in the five disposal areas, as OU2. Future
RODs are planned to address ground water and final source remediation at the site. The
primary contaminants of concern affecting the soil and sludge are VOCs, including benzene,
TCE, toluene, and xylenes; and other organics, including PAHs.
\~
The selected remedial action for this site includes performing bench scale and pilot scale
studies to define operational parameters and to assure the feasibility of cleanup goals;
excavating contaminated soil from the Lime Pond Drum Removal Area, the Abandoned Railway
Trench, the Former Drainage Ditch, and the Former Sludge Treatment Pit; treating the
excavated soil onsite using low temperature thermal desorption, followed by carbon
adsorption of the treatment residuals; sending condensate offsite for incineration and
disposal; returning the treated soil to the excavation areas and placing a six inch soil
cover over them; treating sludge from the Fire Pond at the South Landfill using onsite .
in-situ sOlidification, with carbon adsorption of any air emissions; performing a TCLP on
the treated sludge to determine if it is characteristically hazardous; placing a
mUlti-layer cap over the Fire Pond, if the solidified sludge is found to be hazardous;
placing a soil cover over the Fire Pond and the remaining portions of the South Landfill;
monitoring ground water and source areas; and implementing institutional controls,
including deed restrictions and site access restrictions. The estimated present worth
cost for this remedial action is $6,000,000, which includes an unspecified O&M cost for 30
~au. .
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific surface and subsurface soil and sludge excavation and cleanup goals
not provided; however, risk-based target levels will ensure that the soil that is
excavated, treated, and disposed of onsite, and that in-situ solidified sludge will
demonstrate an incremental cancer risk below 10-6.
were
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Declaration for the Record of Decision
Reilly Tar & Chemical
CERCLA Areas operable Unit
"
site Name' Location
Reilly Tar & Chemical
Indianapolis, Indiana
statement of Basis and PUrDose
This decision document presents the selected remedial action for
the CERClA Areas operable unit at the Reilly Tar & Chemical site
(the Site) in Indianapolis, Indiana. This remedial action was
selected in accordance with CERCLA, as amended by SARA, and, to
the exteI1lt practicable, the National Contingency Plan. The
selectioI11 of this remedy is based on the Administrative Record
for the Site.
The StatE! of Indiana concurs with the selected remedy.
Assessmer~t 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
endangennent to human health, welfare, or the environment.
Descri'Ot:loD of the selected Remedv
This opeJC'able unit action is the second of four planned for the
Site. I~~ specifically outlines an action to address five on-site
sources IJf soil and groundwater contamination, which have been
determim~d by' the Remedial Investigation to pose unacceptable
risks to human health and the environment.
The major components of the selected remedy include:
Excavation of soils at four of the CERCLA Areas, the Lime pond
Drum Removal Area, the Former Drainage Ditch, the Former
Abandoned Railway Trench, and the Former Sludge Treatment pit
with treatment of the soils to achieve the cleanup standards
listed in the ROD by low temperature thermal desorption.
Treated soils will be replaced into the unit from where they
were excavated and covered with six inches of soil and
veget,ated. '
Ul tirnate disposal of the condensate generated as a result of
the t;hermal desorption process by off-site incineration.
Treat~ent of sludge in the Fire Pond (a portion of the fifth
CERCIA Area, the South Landfill) by in-situ solidifi~ation to
meet the performance standards listed in the ROD. Following
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solidification,
characteristic,
the Fire Pond.
characteristic,
Pond.
if the
then a
If the
then a
solidified sludge is RCRA
multi-layer cover will be placed over
solidified sludge is no longer RCRA
soil cover will be placed over the Fire
Placement of a soil cover over the remaining portions of the
South Landfill.
Groundwater and source area monitoring. to ensure that the
goals of this action are met.
Declaration
The selected remedy is protective of human health and the
environment, complies with Federal and State applicable or
relevant and appropriate requirements for this operable unit
action, is cost effective, and consistent with aChieving a
permanent remedy. This operable unit action fully addresses the
statutory mandate for permanence and treatment to the maximum
extent practicable. This action also satisfies the statutory
preference for remedies that employ treatment that reduces the
toxicity, mobility, or volume as a principal element. Subsequent
actions at the site to address other threats posed by conditions
at this site. Because this remedy will result in hazardous
substances remaining on-site above health-based levels, a review
will be conducted to ensure that the remedy continues to provide
adequate protection of human health and the environment within
five years after commencement of the remedial action. Because
this is the second of four operable unit actions at the site,
review of this site and of this remedy will be continuing as EPA
continues to develop other remedial alternatives for this site.
J erit7 ~J l?f5.
Da te U '
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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We m.ake Indiana a cleaner. healthier place to live
\,
Kathy Prosser
Cummmsioner
105 SuuLh MerlduUI SLreeL
P.O. Hux tiOl5
Indianllpoli!;.lndilU\1I 46206.6015
Telephone 317 .232.g603
t:nvironmenL8lltelpline I.HOO.45 1-6027
Evan Hayh
I;uvernur
September 30, 1993
Mr. Valdas Adamkus
Regional Administrator
U.S. Environmental Protection Agency
77 West Jadcson Blvd.
Chicago, 11. 60604
Dear Mr. Adamkus:
Re:
Record of Decision
CERCLA Areas Operable Unit
Reilly Tar and Chemical Superfund Site
. Indianapolis, Indiana
The Indiana Department of Environmental Management (IDEM) has reviewed the U.S.
Environmelrltal Protection Agency's Record of Decision (ROD) for the Reilly Tar and Chemical
Site. The IDEM is in full concurrence with the major components of the selected second
operable unit remedy for this site, which include by media:
. Soils:
Treatment by Low Temperature Thermal Desorption for those hot spot
soils identified in the Lime Pond, the Abandoned Railway Trench, the
Former Sludge Treatment Pit, and the Former Drainage Ditch. The
treated soils will be replaced in the areas from where they were excavated,
in accordance with the Corrective Action Management Unit regulations,
and covered with six inches of soil and seeded. Treatment residuals will
be treated offsite. A soil cover will be placed on the South Landftll area.
. Slud2es:~
The sludge materials found in the South LandftlVFire Pond will be treated
by In-Situ Solidification and covered. After treatment the solidified mass
will be tested to determine if it is RCRA characteristic. If so, the cover
material will be a multi-layer cover; if it is not RCRA characteristic, a
soil cover will be placed.
. Ground'~
It was determined that the design of the first operable unit remedy will
encompass some extraction in the areas of the site identified to be
An Equal OpporwniLy 1!:mployer
P_"".,I ..... U.".",.I", P"PV#~
-------
Mr. Adamkus
Page Two
contributing to groundwater contamination: Lime Pond drum removal
area, the Former Sludge Treatment Pit, and the Abandoned Railway
Trench. Therefore, additional source controls are not necessary at this
time for groundwater. .
We also agree that this action attains Federal and State requirements that are applicable,
or relevant and appropriate to this second operable unit remedy. Because this action does not
constitute the final remedy for the site, the statutory mandate for permanence and treatment to
the maximum extent practicable will only be met paniaily by the treatment of "hot spots"
identified in the Record of Decision. However, future operable units will fully address the
threats posed by conditions at this site.
IDEM staff have been working closely with Region V staff in the selection of an
appropriate second operable unit for the Reilly Tar and Chemical site and are satisfied that the
selected alternative adequately addresses the immediate threats posed by the soil and sludge hot
spots in the five CERCLA areas.
. 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
/fJJ;~
Kathy Prosser
Commissioner
KP:kd
cc: Krista Duncan, IDEM
Dion Novak, U.S. EPA, Region V
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Decision summary - CERCLA Areas operable unit
Reilly Tar and Chemical
Indianapolis, Indiana
" .
site Name. Location and Descri~tion
Reilly Tar and Chemical
Indianapolis, Indiana
The Reilly Tar and Chemical site (the Site) is located at 1500
South Tibtls 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, is located
north of ~[innesota Street. The Maywood property occupies
approximately 80 acres, and is located south of Minnesota Street
(see Figures 1 and 2). The Oak Park property contains the
majority (If Reilly's operating facilities, including above-ground
storage tcLnks, distillation towers, and above- and below-ground
utilities. The Oak Park property also contains one area formerly
used for disposal of hazardous wastes, the Lime Pond, a surface
impoundment which received hazardous wastes. Drums containing
hazardous wastes were also buried in the soils adjacent to the
Lime Pond.. The Maywood property contains operating facilities on
its northE~rn end. This property was formerly the site of
chemical process and wood preserving activities and currently
contains four other areas used in the past for hazardous waste
disposal. These four former hazardous waste disposal areas
include the Abandoned Railway Trench, the Former Sludge Treatment
Pit, the ]~ormer Drainage Ditch, and the South Landfill/Fire Pond.
The majority of the operating facility buildings are located
north of J1innesota Street: appr~ximately 75% of the Oak Park
property is covered by buildings, pavement and above-ground tank
farms. Approximately 20% of the Maywood property is 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 residentiai,
industrial and commercial properties. Residential neighborhoods
are locat,ed immediately adjacent to the,eastern boundary (on the
east side of Tibbs Avenue) of the Oak Park property. Two
residences are also located abutting the northern property
boundary near the Lim~ pond in the northwest corner of the site.
Commercial and industrial properties are located south and west
of the site. .
site Historv and Enforcement Activities
Industrial development of the Reilly site began in 1921 when the
Republic Creosoting Company (which later became Reilly Tar &
Chemical, which in turn became Reilly Industries, Inc.) started a
coal tar refinery and a creosote wood treatment operation on the
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-------
. .
Maywood p]~operty. On-site wood treatment operations occurred
from 1921 until 1972. Beginning in 1941, several chemical plants
were cons1:ructed and operated on the Oak Park property.
Environmental problems at the site are related to the management
and disposal of creosoting process wastes and to wastes
associated with and substances used in the process of
manufactu:ring custom synthesized specialty 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 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 been
contributing to ground- water contamination with organic
chemica~s. 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, but not all, 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 responsible 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 E:valuate and compare remedial alternatives according to
the terms: of an Administrative Order on Consent between the U. S.
EPA and Eeilly Tar & Chemical.
In 1989, Reilly Tar & Chemical changed their corporate name to
Reilly Industries, Incorporated, under which they operate today.
In June, 1992, a Record of Decision was signed by the Regional
Administrator for the first operable unit at the site, calling
for a grc)undwater extraction/treatment/discharge system to be
installed to contain the migration of groundwater contaminated by
the site at the site boundary.
In SepteI~ber, 1992, Reilly agreed to incorporate RCRA corrective
action rE!quirements into existing site studies according to the
terms of an amendment to the existing Administrative order on
Consent hetween the U.S. EPA and Reilly Tar & Chemical.
Hiahliah1:s of Communi tv particiDation
Public participation requirements under CERCLA Sections 113
(k) (2) (B) and 117 were satisfied during the RI/FS process. U.s.
EPA has been primarily responsible for conducting the community
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3
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 RI/FS.
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
Federcll government was developed. Fact Sheets and other
infonlation 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
approclched EPA for information about the site.
A Fact Sheet was mailed to the public
announced a public meeting to discuss
Investigation and answer site related
public::.
in August 1987, that
the upcoming Remedial
questions from the
A public meeting on September 2, 1987, at the Indianapolis
city-County Building announced the initiation of the Remedial
Inves1~igation and provided details about its conduct.
A Fac"t Sheet was mailed to the public in winter 1988, that
announced the beginning of Phase 1 RI sampling and the release
of thle EPA approved Phase 1 RI workplan.
A Fac.t 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.
.
A Fact Sheet was mailed to the public in January 1990, that
announced the findings of the Phase 2 investigation 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 Fac:t Sheet was mailed to the public in August 1991, that
summa.rized results of the completed Remedial Investigation.
The E:PA approved Remedial Investigation Report was also
relea.sed at this time.
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4
A Fact Sheet was mailed to the public in January 1992, that
summarized EPA's recommended remedial alternative 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 was accompanied by paid
newspaper advertisements in the Indianapolis Star and the
Indianapolis News.
-- A Public Meeting was held on January 23, 1992, at the South
Wayne Junior 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
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 Record of Decision was signed by the Regional Administrator
on June 30, 1992, for the groundwater operable unit.
Two availability sessions were held on November 19,
the Stout Field School to discuss site progress and
results of completed sampling activities, including
removal activities near the Lime Pond.
1992, at
discuss
drum
Paid newspaper advertisements announced the availability
sessions, and the FS and proposed plan pUblic meetings.
A Public Meeting was held on August 4, 1993, at the Indiana
Government Center-South to present EPA's proposed plan for
the Comprehensive Environmental Response, compensation and
Liability Act (CERCLA) Areas operable unit and to receive
formal public comment.
A public comment period of thirty days for the CERCLA Areas
proposed plan was originally planned, running from July 22,
1993, to August 22, 1993. Based on a written request during
the original comment period, the comment period was extended
until September 7, 1993, for a total comment period of 45
days. The extension was announced by letter to the requestor
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. ..-
5
and in newspaper advertisements in the Indianapolis star. The
comment period was further extended until September 22, 1993,
for a total comment period of 60 days. The extension was
announced by phone and confirmed by letter to the requestor
and announced to the general public by a newspa~er
advert.isement in the Indianapolis Star.
A Responsiiveness summary addressing comments and questions
received during the public comment period on the RI/FS and the
pr:oposed plan is included with this Record of Decision as
Appendix A. .
This Recc)rd of Decision presents the selected remedial action for
the CERCIA Areas operable unit at the Reilly Tar and Chemical
site in Indianapolis, Indiana. The term, "CERCLA Areas" in this
context refers to five of the areas at the Reilly site where
hazardous waste disposal took place on a regular basis in the
past. These five areas, identified as the Lime Pond Area, the
Former Drainage Ditch, the Former Sludge Treatment Pit, the
Abandoned Railway Trench, and the South Landfill/Fire Pond, have
all been investigated by the RI/FS process. This remedial action
was chos.~n in accordance 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.
scope anlii Role of the Operable unit
As with :many Superfund sites, the problems at the site are
complex. The Remedial Investigation (RI) 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 strong correlation between these five distinct source areas
and ground water contamination. The first 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 prevent the further
contamination of area ground-water res9urces by contaminants
migrating from the Reilly site.
This action represents the second operable unit at the site. The
purpose of this operable unit is to remediate the five distinct
on-site source areas 'that are contributing to contamination of
both soi.ls and groundwater. These areas were initially
investigiated in the RI. Additional on-site investigations
conducte~d in late 1992 pursuant to the terms of the amended
administ:rative order on consent further investigated the nature
and extent of contamination associated with the five on-site
source cLreas and determined that three of them, the Lime Pond
drum relnoval area, the Abandoned Railway Trench and the Former
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6
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Sludge Pit, were contributing to groundwater contamination
problems at the site.
This operable unit action is the second of several operable unit
remedial actions to be taken at the Site. Subsequent actions
will be taken to remediate other on-site source areas and
potentially through cleanup of off-site ground-water resources
already impacted by the site, so that the,source(s) of ground-
water contamination can be eliminated or contained. The Remedial
Investigation identified an area on the Oak Park property that
appears to be the principal source of ground-water contamination,
primarily because the highest levels of contamination were found
there. Additional characterization work for this area is being
performed under a separate enforceable document to define the
nature and extent of contamination there. This operable unit
will be designed to be consistent with any and all potential
future cleanup actions at the site.
site Characteristics
The RI/FS was conducted to identify the types, quantities and
locations of contaminants 'at the site and to develop alternatives
that best address these contamination problems. 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 sampling activities to determine the extent
of contamination on-site 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
- on-site geophysical surveys
- surface soil sampling, both onsite and offsite
- exploratory test-pit excavation and sampling
- 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
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7
-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
Geol.ogy/Jlydrogeology:
The Reilly site lies within the White River drainage basin,
located approximately three miles to the east. Eagle Creek is an
attendan1: tributary and flows in a southeasterly direction
approximiitely 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
approximi:itely 2000 feet northeast of the site, several small
ponds or surface-water impoundments located 2000 to 4000 feet
east of 'the site, and one surf~ce-water impoundment located
immediat,ely southwest of the Maywood property (see Figure 2).
The westlernmost extension of Blue Lake has been filled in since
1979.
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 combi~ed 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 iden~ified 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 grained
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 del not act as a barrier to contaminant flow in ground
water.
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8
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 withdrawals from neighbcring
industrial production wells significantly impact the flow of
ground water east of the site. Hydraulic conductivities for
wells tested during the RI range from 10(~2) to 10(-3)
centimeters per second. An average linear ground-water velocity
of- 0.68 feet per day was ~alculated 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 industrial
pumping.
i'
SOIL CONTAMINATION
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 Maywood property, the Former Sludge
Treatment Pit on the northern portion of the Maywood property,
the Drainage Ditch on the southern portion of the Maywood
property and the South Landfill 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.
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 to
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.
Buried drums were discovered during the RI soil borings at the
Lime Pond. These drums were encountered at locations to the east
and southeast of the lime pond during soil boring activities. A
magnetometry survey was immediately conducted which highlighted
several areas to the north and east of the lime pond where buried
metallic debris such as drums may be located. A drum removal
plan was prepared and its requirements were incorporated into the
amended administrative order on consent signed in September,
1992. This plan called for the investigation of the areas
identified by the magnetometer survey and if drums were
unearthed, they were to be removed. A total of 149 drums were
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removed during field activities in November 1992. The area from
where the drums were excavated is referred to as the Lime Pond
Drum Removal area and is one of the areas addressed by this ROD.
Borings in the Lime Pond generally encountered lime sludge from
the pond !;urface to a depth of four to seven feet. The Lime Pond
contains em 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 contains less than one part per
million ti:)tal organics.
The soils to the north and east of the Lime Pond, in the Drum
Removal Area, were found to be contaminated with volatile
organics up to levels of approximately 5,522,000 parts per
billion (ppb) and semi-volatile organics up to levels of
approximately 9,870,000 ppb.
The Abandoned Railway Trench was used as an unloading and loading
area for incoming rail shipments. The railroad tracks were
depressed below ground level to facilitate 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 WclS approximately five feet deep by fifteen feet wide by
580 feet long based on Phase II investigations.
Test pit!:; completed 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 tes1: pit location and fill material consisting of black,
brown or gray sand and gravel, foundry sand, coal cinders, coal
tar wastlas, wood debris and drums was found beneath. Soil
contaminant concentrations in the trench sampling for volatile
organics ranged to 656,000 ppb and for semi-volatile organics
ranged to 126,020,000 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, lQcated 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.
soil cOI1.taminant concentrations in the sludge pit sampling for
volatile: organics ranged to 202,900 ppb and for semi-volatiles
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10
ranged to 53,710,000 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 ~eposited in this area.
Coal refinery wastes deposited in the area included off-
specification pitches, c~eosoted 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 112 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-water 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 197,300 ppb and
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.
A RCRA facility investigation in 1990 identified potential
releases of hazardous constituents from surface water drainage
from the South Landfill. An inspection by the Department of Fish
and Wildlife on January 31, 1992 identified the fire pond sludges
as imminently hazardous to wildlife. As a result, EPA directed
Reilly to perform an interim measure at the South Landfill to
minimize these risks until a final remedial action could be
implemented. This interim measure consisted of regrading and
covering the eastern portion of the landfill with six inche~ of
clean soil, placement of plastic netting over the fire pond to
prevent waterfowl from landing in this area, and construction of
drainage controls to prevent runoff from this area from leaving
the site. These activities were completed in April 1992.
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11
Prior to 1970, waste water and storm water were conveyed from the
API separ~ltor by the Former Drainaqe Dit.ch into the Raymond
street stclrm sewer, which then discharged directly to Eagle
Creek. This water consisted of water separated from the raw tar,
water deccmted from the tar storage tanks, water separated from
the oil-water, "wet-dry" in the refinery, blowdown water from the
boiler opE!rations, aqueous sodium sulfate from the extraction of
tar acids and tar bases from the light and middle oils, and storm
water entE!ring the system due to natural drainage. Historically,
the length of the ditch was 1220 feet, the width was between 15
and 50 fe«at, and the depth was approximately 8 feet.
Soil contaminant concentrations in the Former Drainage Ditch
sampling :for volatile organics range to 199,930 ppb and for semi-
volatiles range to 117,120,000 ppb.
HOT SPOT DELINEATION
Further evaluation of the RI data by u.s. EPA determined that the
soil contamination was present in discrete locations within the
CERCLA Areas. These hot spots, if addressed, would significantly
reduce the contaminant concentrations at the site as well as
significantly reduce the risks posed by contributions to soil and
groundwater contamination from these areas., All of the CERCLA
Areas were reevaluated by U.S. EPA to develop hot spot volumes
for treatment alternatives for soil cleanup: this reevaluation
process yielded revised volumes for three of the areas, the Lime
Pond Drum, Removal Area, the Abandoned Railway Trench, and the
Former Drainage Ditch, that were significantly lower than those
presented in the Feasibility Study/Corrective Measures Study
(FS/CMS), that represent the majority of the contamination
associate:d with the CERCLA Area'.
The revis;ed volumes represent the most heavily contaminated soils
in the unit rather than all the soil in the unit regardless of
how contslminated it might be as was the case with the volumes
presented in the FS/CMS. CERCLA Areas were evaluated by
examinin9 the results of the soil/sludge testing and the Toxicity
Characteristic Leachate Procedure (TCLP) testing. The samples
collected during the Remedial Investigation/RCRA Facility
Investigcltion (RI/RFI) activities were evaluated to determine if
the contaminant conc~ntration for pyridines or carcinogenic PAHs
exceeded the risk-based target cleanup levels (RBTCLs) presented
in the FB, and if the'TCLP results exceeded discharge criteria'
(Maximum Contaminant Levels (MCLs) for drinking water for
benzene, pyridine and carcinogenic polynuclear aromatic
hydrocarJ,ons ( CPAHs) ) .
The ViSUiil characteristics of the samples were compared and areas
that apptaared to contain the majority of contamination were
identifi4ad for removal and treatment. The volume of 50il to be
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12
removed was calculated and an estimate of the mass of
contaminants to be treated was made. An estimate of the mass of
contaminants to remain was also made for the volume to remain
untreated. By comparing the two, the percentage of the total
contaminant mass to be treated was estimated. The following
summarizes this process for the three CERCLA Areas.
Abandoned Railway Trench: According to the FS/CMS, the railway
trench is approximately 640 feet long by 17 feet wide. The
railway trench is bordered by a wooden retaining wall on the
north and on the east and by a concrete building foundation on
the south. The FS/CMS extended the width of soil requiring
remediation beyond the limits of the trench 5 feet to the east
and to the west to include additional impacted soils. The depth
requiring remediation was estimated to be 20 feet for the
northern 490 feet (representing the depth to groundwater) and 4
feet for the remainder of the railway trench (representing the
depth to just below the railbed). The volume of material
requiring treatment was estimated in the FS/CMS to be 10,320
cubic yards.
The gross contamination is present in the original width of the
railway trench (17 feet) to a depth of approximately 5 feet (to
the bottom of the railbed). The gross contamination appears to
end within test pit J-05 where the description of the soil above
the railbed changes from dark brown-grey sand and clay to brown
sand and gravel, trace cobbles, medium coarse sand. No samples
were taken south of this transition point. The length of gross
contamination considered in the revised volumes was 512 feet
(compared to 640 feet estimated in the FS/CMS), because the
contamination was not as laterally extensive to the south as
originally estimated, using the criteria for identification of
hot spots, as outlined below.
The results of the evaluation showed that a reduction in the
amount of soil to be treated could be made, while keeping a high
percentage of reduction in the amount of contamination removed.
The FS/CMS identified 10,320 cubic yards of soil to be treated.
The EPA evaluation determined an 82% reduction in that amount
could be made to 1850 cubic yards to be treated. The percentage
removal of contaminants found in the revised soil amount is as
follows: 100% of the detected benzene: 99.9% of the detected
pyridines: and 73.9% of the detected cPAHs.
The volume of soil to be treated encompasses 12 of the 15 samples
where concentrations exceeded the industrial RBTCL (presented in
the FS/CMS) and all four of the samples where the TCLP data
showed exceedances of discharge criteria. This volume does not
include soils outside of the wooden retaining wall, because they
are part of the kickback area which is to be addressed in future
actions, as is stated in the FS/CMS.
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13
Former Druinage Ditch: The Former Drainage Ditch contains two
apparently separate areas of contamination - a layer of
cinders/tar/oily gravel that varies from about 1 to 1.5 feet
thick, and an oily material that occurs within the original
drainage ditches. The FS/CMS did not include remediation of the
cinder/ta:r/oily gravel layer in the volume calculations. This
layer is attributed to the kickback area in the FS/CMS. The
volume es'~imated in the FS/CMS that requires remediation in.cludes
an area 35 foot wide by 4 feet thick along 660 feet of the west
d:r:ainage .:hannel and 50 feet along the east drainage channel.
(3700 cubic yards). The total volume of contamination in the
area of Ule drainage ditch, as presented in the FS/CMS, is
approximately 5800 cubic yards.
The gross contamination (besides the cinders/tar/oily gravel
layer) does appear to be centered on the west drainage channel.
The width of the contaminated soil (visually identified as black
clayey silt, black silty clay, black silt (oily), and black tar)
varies from 5 to 12 feet wide according to the test pits. The
revised volume of soil to be excavated and treated includes the
material centered on the west drainage channel and the
cinders/tar/oily gravel layer that covers the area.
The results of the evaluation showed that a reduction in the
amount of soil to be treated could be made, while keeping a high
percentage of reduction in the amount of contamination removed.
The FS/CMS identified 5800 cubic yards of soil to be treated.
The EPA E:valuation determined an 66% reduction in that amount
could be made to 1950 cubic yards to be treated. The percentage
removal clf contaminants found in the revised soil amount is as
follows: 96.5% of the detected benzene: 99.6% of the detected
pyridines:: and 94.7 % of the detected cPAHs.
The volUlue of soil to be treated encompasses 7 of the 8 samples
where concentrations exceeded the industrial RBTCL and both
samples ~,here the TCLP data showed exceedances of discharge
criteria.
Lime Pond Drum Removal Area: Waste materials were deposited
north and east of the Lime Pond in what is referred to in the
FS/CMS af. the drum removal area. The wastes were originally
assumed t:o have been deposited in trenches-two running north-
south east of the lime pond and one running east-west north of
the lime pond. The volume of waste associated with these
trenches was estimated based on the results of a geophysical
investigation.
The drum!; were located and removed. as part of the Lime pond drum
removal project. samples of the waste material around the drums
were collected during the drum removal. The FS/CMS estimated the
volume o:f waste material based on an "L" shaped area to the north
and east of the lime pond. The depth of contaminated material
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14
was estimated to be 15 feet. Based on these assumptions, the
volume of material requiring remediation was estimated in the
FS/CMS to be 29,000 cubic yards.
<'
In the revised volume calculations, it was assumed that the gross
contamination is limited to the trenches. Analytical data is
unavailable in the areas outside the drum removal excavation
areas. While it is possible that gross contamination may exist
outside of the trench areas, the volume of gross contamination is
not anticipated to be significant. This assumption is based on
the RI geophysical evaluation. The depth of gross contamination
was estimated to be 10 feet. The test pits excavated during the
Lime Pond drum removal project extended to depths from 4 to 12
feet below ground surface. Drums were encountered as deep as 6
feet below ground surface.
The revised volume of gross contamination is about 5400 cubic
yards, about 19% of the volume calculated in the FS/CMS. No
samples were collected and tested outside of the excavation
areas, therefore no comparison of mass contamination to remain
versus mass contamination to be treated can be performed. Some
contamination may remain through the leaching of the waste
material.
Former Sludge Treatment Pit: The Former Sludge Treatment Pit was
reevaluated using the criteria mentioned above for determination
of hot spot volumes. The volume presented in the FS/CMS (800
cubic yards) was found to be accurate for hot spot delineation at
this area.
South Landfill/Fire Pond: The South Landfill/Fire Pond was
reevaluated using the criteria mentioned above for determination
of hot spot volumes. Due to the widespread contamination at this
area, the absence of any discernable hot spot area, and the
prohibitive volume of contaminated soils at this area, it was
determined that the South Landfill/Fire Pond would not be
included in the hot spot delineation. One area that was
identified as a hot spot was the Fire Pond, which is the subject
of remediation as a portion of this ROD.
The cost and volume estimates presented in the FS for the
alternatives analysis are for hot spot soils in the source areas
that will address the most contaminated portions of these areas.
The term "hot spot soils" is defined as including, but not
limited to, those soils which exhibit visible evidence of
contamination, or which fail the Toxicity Characteristics
Leaching Procedure (TCLP) test.
The FS estimated volumes of contaminated soil for each of the
source areas. Further evaluation of the RI data showed that the
soil contamination was concentrated in discrete locations within
the source areas. These hot spots were found to be the greatest
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15
contributors to groundwater contamination. Over 90% of the soil
contamina'tion is present in these hot spot areas which comprise
approximately 20% of the total volume presented in the FS. As a
result, treating the hot spot soils, which constitute a small
portion of the source areas, was also considered by EPA.
Treatment alternatives presented in this ROD represent cleanup of
those hot spot areas.
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 summarized in the 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 sCluth-central portion of the Oak Park property. Ammonia
concentra,tions in the ground water ranged from o. 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 for benzene, pyridine and
pyridine derivatives, and ammonia, respectively).
Additional groundwater samples collected as a part of the AAOC
sampling activities showed that groundwater quality was
significclntly impacted downgradient of three of the CERCLA Areas:
the Lime Pond Drum Removal Area, the Former Drainage Ditch, and
the FormE~r Sludge Treatment Pit. At these locations, benzene
concentrations ranged from 1 ppb to 810 ppb, pyridine
concentrcltions ranged from 41 ppb to 94,950 ppb, ammonia
concentrcltions ranged to 64 ppm and PAH concentrations ranged
from belc>w detection limits to.11,760 ppb. These concentrations
are grea1:er than the cleanup levels selected for groundwater in
the ROD for the first operable unit and demonstrate that these
areas arE~ adversely impacting groundwater quality.
SUMMARY OF SITE RISKS
This Rec()rd of Decision is written for an operable unit action to
address 1:he five CERCLA areas within the site boundaries. The RI
report includes a risk assessment, prepared by Reilly using the
Risk Assf:!ssment Guidance for superfund and approved by EPA as a
portion c)f the RI report, that calculated the actual or potential
risks to human health and the environment that may result from
exposure to site contamination. Risks from exposure to
contamin.ated groundwater were summarized in the ROD for the
groundwa'ter operable unit. Risks associated with exposure to
contamin,ated soils and sludges are presented below.
The risk assessment determined that the majority of risks
associat'ed with exposure to soil contamination at the site were
attributed to carcinogenic PAHs, pyridine and pyridine
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i: .
H
o
.
~ .we ..............-- ... .....-
I
''''~
.......
...... I
,
- ",,"'11
- ......,... 0.- J ,
-------.-
_I --.......,.......
................... ............
.............-.... ...............
.-.......- -............
...... .........
.... ..-....-............,....
.........., .......... ".-.-........
.............................--
............... ................
...--...............~......
. ...............,......- ....,-
....-....... .........
.......
.....~........
.....,.........
III ..........
- . -............ .....
I
n;;r-1 ,..................- I
~ .....-.....-- I
I~.. .1 ~--_.1811'!
I 1=-. .108-----."'"
I~. .I~----."":
} . - .. I
- - .
.....- - - ---
4.
,\p (l\-)l"~" .
~O~2 ; .J\\~i'~\.
----t;1i'"'
.
I
I I
"
-------
16
.
"
derivatives and volatile organics, such as benzene. Other
chemical~ that were detected in site soils are also of concern,
but were not found at the same frequency as these listed here.
concentrcltions of these chemicals in the groundwater have
resulted in the calculation of unacceptable risks to human health
and the E!Ovironment posed by exposure.
Exoosure Assessment
The exposure assessment conducted as a part of the RI concluded
that sevnral media are impacted by the contaminants at the site,
and that there are several potential exposure routes for
contamination. These routes of exposure were identified for both
current and future scenarios (as is commonly done in EPA risk
assessments) so that all potential pathways can be evaluated.
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
confiden<::e intervals is suggested in the Risk Assessment Guidance
for SupeJrfund and represents a conservative step towards
assessing risks associated with potential exposures. In some
cases wht:!re sample results vary widely or sample size is small,
these cOllfidence intervals may exceed maximum detected
concentrations.
Due to the proximity of the site
and major streets, and its size,
receptor::; were identified in the
computed for their exposure.
to the surrounding neighborhood
the following potential
risk assessment, and risks were
Under the current land-use scenario, on-site workers could
potentially be exposed through inqestion and dermal contact with
surface ::;oils, and inhalation of surface-soil dust. Off-si te
neighbor:tlood residents could potentially be exposed through
ingestio:11 and dermal contact with surface-soils from the Maywood
property (primarily from site trespassers), inhalation of surface
soil dus't (migration of dust from the site), inqestion 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 inqestion and dermal contact with on-site surface
water (site trespassers contacting a transient area of ponded
water). Off-site industrial workers could potentially be at risk
through exposure to volatilized contaminants (local industrial
usage of the ground water).
Under the future-use scenario, on-site workers could potentially
be exposed through iDqestion and dermal contact with surface
soils (some workers can enter the area of the Maywood property),
and inhalation of surface soil and dust (Haywood) and subsurface
soils (all areas) (workers may be exposed to on-site dust
generated during intrusive construction activities). Off-site
-------
17
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 potentially 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 cl:)uld be at risk through exposure to volatilized
contaminants from the ground water (industrial water usage).
Toxici tv :~ssessment
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 in utero: however, it has not been shown to be
teratogenic (causing birth defects). Animal studies have shown
preliminary evidence of carcinogenicity: a link to leukemia via
inhalation has also been suggested. Benzene has been shown to be
nonmutage:nic (not causing mutations): benzene oxide, the presumed
initial Irletabolite of benzene,. is mutagenic (causing mutations) .
Limited data exists on the oral absorption of pyridine: data on
the pulmc1nary and dermal absorption of' the chemical was not
located. Available evidence indicates that pyridine is well
absorbed rapidly fro~ the GI tract and is not expected to
accumulat:e in the body. . Available information from animal
testing does not suggest that lethality is a human health concern
for exposure to pyridine by inhalation or ingestion. The major
human hecllth concern is for liver damage, based on recent studies
with lab()ratory rats. Other human health concerns include the
potential for neurologic effects and kidney effects. 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
-------
18
incidence of tumors with respect to controls. EPA has decided
that increased liver weight in female rats is the most sensitive
toxic endpoint.
Ammonia 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.
Ammonia has also been shown to cause negative effects to the
respiratory tract, labored breathing, eye irritation,
inflammatory lung changes, and death to many animal species.
Trichloroethylene (TCE) is considered a probable carcinogen
(Class 82) and is associated with central nervous system and
renal system problems, liver damage, hepatic injury, and damage
to other organs. Animal studies have indicated that TCE is
fetotoxic but not teratogenic, producing primarily skeletal
ossification anomalies, decreased fetal weight, and other effects
consistent with delayed development.
Ethylbenzene 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 dizziness and unconsciousness. 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) carcinogenicity rating by u.s. EPA.
Both the Integrated Risk Information System (IRIS-1989) and the
Health Effects Assessment Summary Table (HEAST-1990) were used as
sources for this contaminant toxicity data.
Polynuclear Aromatic Hydrocarbons (PABs) are absorbed
-------
19
gastrointestinally. There is very limited information on human
toxicity for PAH. No information is available concerning the
possible teratogenicity of PAH in humans. From numerous
epidemiological studies of humans (primarily occupational
exposure), a clear association has been found between exposure to
PAH containing materials and increased cancer risk. The
following PAH have been classified as potentially carcinogenic -
Class B2: benzo (a) pyrene; benzo (a) anthracene; dibenzo (a,h)
anthracene; benzo (b) fluoranthene: benzo(k) fluoranthene;
indeno (1,2,3-cd) pyrene; chrysene.
Risk Ass;essment
carcino<;1lenic risks described in the risk assessment for exposure
to conta~inated soil at the site were computed for several
potential exposure scenarios (See Table 1). These include on-
site worker (current risk - 6.1 x 10(-5», off-site neighborhood
resident: (current risk - 1.7 x 10(-5», on-site worker (future
risk - 6.8 x 10(-5», off-site neighborhood resident (future risk
- 1.9 x 10(-5», construction worker (future risk - 6.2 x 10(-
5», on-site resident (future risk - 1.1 x 10(-3». The chemical
class causing the majority of the estimated cancer risks were
potenticllly carcinogenic PAH.
The non..carcinogenic risks associated with exposure to
contaminated soil at the site were computed for the same exposure
scenaric)s 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
scenaric)s such as the construction worker (future non-
carcinogenic risks - HI = 1.1). on-site resident (future non-
carcinogenic risks - HI = 2.0) (See Table 2). The chemical class
causing the majority of the estimated non-cancer risks were
pyridinl! and pyridine derivatives.
The carc::inogenic risks associated with exposure to benzene by
qrouDd-1water iDqestioD were computed for several potential
exposurl3 scenarios (see Table 3). These include off-site
residen't: (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 ground-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 iDqestioD of qrouDd water,
were computed for the same exposure scenarios as were used for
the carcinogenic risks. Hazard Indices exceeded the 1.0 trigger
-------
~
«t
T I\nLE 6- 31
SlIMMI\RY TABLE - ON-SITE WORKER
CURRENT SCENARIO - CARCINOGF.NIC RISK
IIUMAN HEALTII EVALUATION
RmLL Y INDUSTRIES, INDIANAPOLIS, INOIANA
,.-
"(~IP
- - -- - - -
-... -- ..".- -.. ..- w.v.-.
Oe-Sile Worker PoteDtl8l PotaItIaI
PoIa6! CareJ8oac* IU& CareI.DoamJc: IUIk
~RIIk Surf.. SolI In""" 8: Surf.. SOU Inlflldoa . T oC8I pCJtaldll
Surf.. SOIlI"w-tlo- Der88I CoaI8d 0.- Coallid Cud80pIc .....
POUND s.hen An8 Totli SoudIen An8 I So8dIent Arel 2 To Oe-Sie Worbr
At:
NIC 9.8E-10 2.01HI9 2.9E~ 3.2E-08
MIUM 1.6E-10 NA NA 1.6E-10
OMIUM VI 6.6E-10 NA NA 6.6E-IO
fl. 2.0E-10 NA NA 2.0E-10
"... - ..., -....... _.- ..---....- - .--
- ETiI Yl.IlEX YtlPIITII ALATE 1.4E..14 9.4E-13 6.5E-11 6.6E-1I
--- ..---___-..0-_--- - ----
:
-TE 1.6E-07 2JE-{)5 J.8E-{)5 6.IE-05
.._----_._----
TOTAl.: 16E~7 2.3E-05 3.8E-{)5 6.IE-05
---_..- -. .. -~.-
lid:
.Not ~iC8h~
...... ell. W_"
n 8!l1a UI L
COM
MH
ARSE
CAD
(OUR
NWK
IINA
~~~~2
PAil
I.('I!('
NA-
hie N~me: SUMCCI. WK I
05.0«:-90
-------
~
't
N
T AIILE 6- J8
SUMMARY TABLE - moF-SITE RESIDENT
(:tlRRENT SCENARIO - CARCIN<>
-------
'2. TAnU~ 6-39
o SUMMARY TABLE - ON-SITS WORKER
ro HrfURE SCENARIO - CARCINOCJENIC RISK
IIUMAN HEALTH EVALUATION
RElLI.Y INDUSTRIES. INDIANAPOLIS. INDIANA
CHEMI
MEt A
ARSE
l'ADM
C:IIR(
NICK
voc:
BENZ
STYR
IIN A:
I1I~C2-
IIEXA
r A":
R(IIJr
l.rJel1
NA.
OIt-SItc Worhr On-I"" Wor~ 08-1"" WOI~
Ott-Sile WOfler On-Site WOI~ PotmtW PotaIIW PcMIIW
Pota6I PoIaIIW Card8opIc: RIIk Can:18opk: IlI.t CareillOlalic IU8It
Can:IaopU: IUak Can:1aoaade RIll: S.r- Sol ....... A Surf.,. SolI ........ .. Sllbturf- Sol ",,,,108 A ToIIII PCJteetW
S.rf.,. SolI."""''''''' lubtarf- SoIIDW8IIoa 0.-1 CCIIIII8d 0.... Coat8ct Der..a CaIII8d Can:I8apaIo RIll:
CAL SouIhed A.- ToI8I TCJC8I Sle So8dIen A.- . Soadwa "'- 2 TotII Sle Par OIt-SIe Woda
!.S:
NIC 98E-10 3.7E-1I 2.0E-{)9 2.9E-()8 1.2E-{)9 UE-ol
IIJM 16E-10 3.1E-12 NA NA NA 1.6E-10
)MIlJM VI 6.6E-10 2.1E-1I NA NA NA 6.9E-10
EL 2.0E-10 9.2E-12 NA NA NA 2.IE-10
.--
ENE NA S.IE-IS NA NA I.3E-IO I.3E-IO
ENE NA 3.IE-14 NA NA 1.9E-{)9 1.9E-{)9
". ..- -- _._~.._-_._----_.
ETHYUIEX Yl)PIITII ALATE 1.4E-14 2.9E-13 9.4E-13 6.SE-1I 1.2E-{)9 I.3E-G9
CIILOROBENlENE NA I.3E-12 NA NA 2.0E-()8 2.0E-oI
.-.
.TE 1.6E-01 6. 4 E-{)9 2.3E-()S UE-()S 6.1E-()6 6.8E-()S
...-. -
TOT AL: 1.6E-()1 6. 4 E-{)9 2.3E-()S UE-()S 6.8E-()6 6.8F.-()S
_. .._- .---.-'---'-----
ct. .
':.'.'-"-:"1'r.1~!~~~.__. .-. ...
rile Nllme' SUMtTI.WKI
OS lJee .qO
-------
"
T AnLE 6- 42
~ SUMMARY TABLE - IIYI'OTIIETlCAI~ ON-SITE RESIDENT
~ HITURE SCENARIO - CARCINOOENIC RISK
IIUMAN IIEALTH EVALUATION
REn... Y INDUSTRIES, INOIANAI'OLlS, INDIANA
Oa-SIIa RC8Idad On-SIIa ReIIdmt Oa-SIIa RII8Idatt
Oa-SIre RceJctmt On. Site RfI8Ideat Potaldal PCItaIIW POIaIdII
PotaIIIaI PoCaIIi8I Card80pJc IU.t Can:1aopIc Rbk C8rdDopaic RiIt TcUI ,......
Carel"" RI8t CareIDoteaIc Rilt Surf- Sol ....... A Sub8urf- SolI ......... A Surf- W.. ......... A CaKI80pIe ...
S.rf- Soil IaWIIIIoa SaII..rfKe Sol ........... 0.-1 CoaI8d Dc:r..I CoaI8d Ocr'" CCI8t8d F.08-S"
OMI'OUHD Soudaen Area TcUI TcUI Sire ....... Area TcIIII TCUI Sle ...... Area .......
mTAL~:
RSENIC 1.9E-09 3OE-10 2.0E-07 1..5E-4)9 2.3E-ol 24E-07
. ADMIIIM I.3E-09 30E -II HA N~ NA UE-09
-IIROMlliM VI 53E-09 2.2E-10 NA NA NA 5.SE-09
ICKEI. 1.6E-09 1.4E-1I NA NA NA 1.1E~
---.---.
vO<::
BENZENE NA 4.IE-14 HA '.2E-10 NA '.2E-10
TYRENE NA 2.5E-13 NA 1.2E-oI I.IE~ 1.3E-oI
--..---.- ----"---"--------'
nNA'
1115(2- ETiI YLlIEX Yl)PH!" ALA 1.IE-13 2.3E-12 3.6E-10 1.4E~ NA 7.7E~
IIEXACIILOROBENZENE NA I.OE-II NA 1.2E-07 NA .I.2E-07
rAil:
R(.)P- TE 1.3E-06 5.1 E-{)I I.OE-03 4.2E-05 NA 1.IE-03
TOT AI.: 1.3E-06 S.2E-{)1 I.OE-03 4.2E-oS 2.SE-ol 1.IE-03
- -----.----..
I.t~tnd:
~~ =-~~Arr.lic.ble -
c
~
1\
(
(
N
s
lilt N"nlt: SlIMCFJWKI
O~ I)tc 90
-------
"
""
o
\()
l AIILE 6- 41
SUMMARY TABLE - CONSTRUCTION WORKER
I:UTtlRE SCENARIO - CARCINOGENIC RISK
IIUMAN IIEALTII EVALUATION
RmLL Y INDUSTRIES, INDIANAPOLIS, INDIANA
r
r....~.....1n. 1II'...1r..
COM
Mf.T
ARSE
CAD
CIIR
HICK
voc
BEN
STYR
nHA
h15(2
IIEX
rAil
h(II)P
r_.._a.- w...'-
------- .- -..- ----- -.-..-...
ConJtr8dIo8 worter c-.tnK:doa Worbr Pol.altl8l PcIfeaIW
PdeatW PotaIIIaI Can:l8oimJc RIIt C8n:1DcJaenk: IUIt
Can:1~ RIIt CardaopIc RIIt Sarf.. SoU InpllJoe a s..rr.. SoIInJellJo8 A T obi Pat81181
S8rr.. Sol 1.""- s"'lIIrr.. Sol .......... Der88I Ccxd8d 0a88I CaIII8d Care""" ... For
POUND SoudIcn Ana Teal Teal Sile ...... Ana Total TaIII Sile ~Worbr
AI.5:
HIC I.OE~ 1.IE-09 5.4E~ 6.2E~ 1.4E~
MIUM I.6E-IO I.IE-IO NA NA 2.8E-10
OMIUM VI 6.7E-10 8.4E-10 NA NA 1.5E~
EL 2.IE-10 1.8E-IO NA NA 4.9E-10
--~-
:
ZEHE NA 1.6E-13 NA 6.5E-10 6.5E-10
F.HE HA 9.6E-13 NA 9.6E-09 9.6E~
- -----------.-.
-ETHYLlIEXYL)PHTIIALATE . 1.4E-14 8.8E-12 9.8E-12 6.IE-09 6.IE-09
ACIII.OROBENZEHE HA 4.0E-11 NA 9.9E-- 9.9'-:-08
-.---. -,
:
-TE 1.6E-07 2.0E-07 2.8E-oS 3.4E-05 6.2E-05
---"
TOTAL: 1.6F.-07 2.0£-67 1.8E-oS 3.4E-65 6.2E-05
--
nd:
Noe ~.rrIlc:.Me.
I.c:~c:
NA -
nle Hllme' S\JMCf4.WKI
o~ "ee:.IIO
-------
M
<**
o
J
ft
I I AMI I r> 411
SUMMARY I ABIT Oil SFTF. *F.*IIIFNT
I I'lHIII SBI»I
UNA
pi'i.' I iinini >vt ir-miiM AII
Ml >l \> III •'•"III N/l Nl
I'AM
in* if ir
IIIIAI
1 .,..<
II A N.« An.1irftMf
1 .1. 1* M'MI 1 I U> 1
lilt Jto •(•!*•*
r MUM
<«rrt.««.J. IM
5wl«« VI MiWrifei
S>«hnii A/r, Ixd
4 OF. 0*
»4t II)
1 It «
1 IF 1"
NA
NA
««F 14
NA
» IF 0>
«4F 01
nn i-iiiiJi ii
FMMU
"nl- | «li Tlhl
K^wtlm Sri bM^b«
IrtdSIU
1 *
*ti^l^iB«*T4tfM ^^ l^rfl^ltffalV
t<«IS>»
1 It-ll
Jit II
ME II
1 IE II
HE it
4 )F 15
4 It 14
I«F II
* IE-10
• It- 10
Ml Hill
C
44€-
1
•
It
A
IA
IA
IA
10
A
A
A
If
_
. .T*"-'1^*^
'inn 1 il HI*
S^M> M hlJ>*jB •
D«^<^MHI
Nn*«i Kim
«*-<*
NA
NA
NA
NA
NA
1 IF-IO
HA
11E-W
11C-M
TtMNlMtl
^HlHfVliM
r«tOM-*k>
R ill 4
«IH»
»
Iff-Of
l««
-------
TABLE 6-41
SUMMARY TABLE - CONSTRUCTION WORKER
FUTURE SCENARIO - NONCARCINOGENIC RISK
."UMAN HEALTH EVALUATION
REILLY INDUSTRIES, INDIANAPOLIS, INDIANA
---. -- - .
COIIIItructioa Worker Coam-uctitoa Wu
~WOfku CODItnIdioa Work« PdadW PoIaIIi8I
I'ak8IW Potaltl8l II_II lolln lluard IIIde
llaani bide. Hamnlladca Surface SoillnAatioa " Sublur'- SoilinA
Surf8CO Sol 8.........,.. Subwr&co Sod ...... Ocr'" Coalad Ou'" Con
COMPOUND Soi6tra AI'8 TG181 T" Site Southern Area Tolal Total Site
METAL:
ARSENIC 2.IE-06 2.4E-06 2 2E..oJ
CADMIUM 1.2E-G5 8.2E-06 J.OE ..oj
CHROMIUM III 2.6E-01 ].]E-G1 19E-oS
CHROMIUM VI 2.]E-06 I.OE-G5 I 6E-04
LEAD 1.6E-G4 2.0E-G4 HE-02
MERCURY 1.1E-06 1.9E-G6 8.JE-04
NICKEL 6.9E-G1 8.8E-G1 2.IE-o)
VANADIUM 1.2E-GS NA 1.6E..o)
VOC:
ACETONE NA 1.6E..o8 NA
ETHYLBENZENE NA 9.6E-09 NA
STYRENE NA 2.1E..o8 NA
TOLUENE NA UE-09 NA
TOT AL XYLENES NA UE ..o1 NA
.-. --. .
8NA:
81S(2 - ETII Y LlIEX YL)PIITII ALATE ) 6E 09 2.2E-06 2SE06
DIBENZOFURAN UE -01 9.IE-06 1.8E-()ot
IIEXACIILOROBENZENE NA 2.IE-06 NA
P6NTACHLOROPHENOL S.bE-()8 J.)E-01 2. JI: .0.1
..---------. -.--.- -...-.
"0 -. ~ -- -
rkm
.
alioa.A
tad
2SE OJ
2 IE OJ
2 4E OS
20E 04
5 6E02
9SE04
2.9E.0)
NA
b bE OS
4 OE OS
liE 04
) OE OS
9 1E OS
-,.- --..--
I SE OJ
I IE 02
S IE OJ
I 4E OJ
T"" Plllcnli8I
lluardladc.For
CouIrucdoe Worhr
.. .,E II J
S IE III
4 -tE OS
) 81: 04
10E 01
I 8E 0)
S OE OJ
I bE 0)
-----_. -.- ..
b()E m
4 OE OS
I IE 04
) OE 0\
9 1£ 0\
1 ~I: II 1
I II: O!
S II: III
I 61: OJ
QJ
() ()
+. -
..t:.. 1\
"
-------
TABlI~ 6-47 (Conlinued)
SUMMARY TABLE - CONSTRUCTION WORKER
FUTURE SCENARIO - NONCARCINOGENIC RISK
IIUMAN HEALTH EVALUATION
REILLY INDUSTRIES, INDIANAPOLIS, INDIANA
-.. .--
CouIrudioD Worbl' COIIIUUdioa Worbr
CcI8IIruc:tIoa Worbr CaaIIructioa Worbr PoCaIIiaJ PGtallUI
PGtMIIaI PataIIJ8I lluarclledc. Ifaard INk.
"""'" ..... ....... .... Surr- SolI 18JC111io8 a. Subtur&co SoIIlaptioa a. Tobi P
..... Sol......,.. SuNlr&co Sol ...........,. Ocr..... Co8I8ct 0.... C~ lluant
COMPOUND ....... Ana TatII TatII Site Scdhcna Ar8 TOIaI T alai Site ~108
PAIl:
TOT AL CPAII 1.6E-05 2.5E-05 2.0E-02 1 I E-01
ACEN APIITIIENE 1.6E-07 6.7E-06 20E-o.t 8 ](; 0)
ACENAPHTHYLENE 2.4E-07 I.2E-06 29E-04 UE.OJ
ANTIfRACENE 1.9E-oI 1.3E-06 1.IE-04 16E-OJ
BENlO(OIll)PERYLENE 1.7E-06 1.1 E -06 2.IE-03 14E.OJ
FLUORANTIfENB 3.6E-06 UE-05 4.5E-01 I 8E 01
FLUORENE UE-07 1.3E-05 3.5E-04 I 6E 02
I-METHYLNAPIITHALENE 4.IE-07 3.5E-05 BE-04 4 4E 02
2-METlIYLNAPHTHALENE 2.3E-06 7.2E-05 29E -01 I 91H)l
NAPHTHALENE 1.4E-06 1.IE-04 1.7E-03 22E.01
PHEN ANT,.RENE 2.OE-06 UE-05 2.5E-03 4 7E .02
PYRENE 4.9E-06 1.4E-05 60E-03 1.7E 02
"-- -'-- ..-.. ....... .
PYRIDINES:
TOTAL PYRIDINES 2.IE-06 9.IE-05 86E-0] of IE 01
--..--. . ._-- -_..
TOTAl.: 0.00021 000074 010 099
- -- ----.----- ---- ..-- -.-- --
L.clcad:
N A -: Not Applic:eblc ----- '------.--------.-.--. ..._-. - ..
ulclllUi
lAde. For
WDfta
SOl.: 02
8 ~I: 01
1 IE 0)
11E 0)
) 51: 01
2 )1:02
I 6E 02
4 4E 01
9 2E 02
221: 01
4 91: OJ
2 )E 02
.. JI: III
II
File N.mc: SUMNCF4.WKI
. 07-D«-90
tJ '"' G
o n 0
'f) 0 -
~ ~ "
"
-------
TABLE 6-48
SUMMARY TABLE - HYPOTHETICAL ON-SITE RESIDENT
FUTURE SCENARIO - NONCARCINOGENIC RISK
IIUMAN IIEALTH EVALUATION
REILLY INDUSTRIES, INDIANAPOI..IS, INDIANA
-_.
Oa-Silc RC8kIaat Oa-Silc Raklc:al Oo-$ilc Rcaidall
0.-5118 ...... 0..-5110 RC8kIaat PotaIdaI Poteell8l PotaIUII
........ ........ Hcanlladc. 1l1lZU'll1odc. llaunt lode.
...... .... HIIUICI .... 5urf- Sod ....... A Subeu,r8CC Soil ........ A Surf8CC W,., SolI "'eal
...,.. SoD 1.""- SIIrf- 5011.""- 0.... CoaI8d Dermal CooI8d DcnoaI Coriad
COMPOUND ..... AnI TCIbI ToCII... Soutbaa Area ToCII Total SII.e SouIhu8 Area Tal"
METAL:
ARSENIC 5.6E~1 6.3E~1 2.6E~3 10E~3 6
CADMIUM :I.IE~ 2.2E~ 3.1E~3 2.6E~3
CHROMIUM III 6.9E-oI ..6E~. 2.4E~5 J.OE~5 2 1
CIIROMIUM VI 6.IE~7 2-1E~ 2.OE~ 2.6E-0I 1 2
LEAD 4.2E~5 5.3E~5 s.sE~ 6.9E~ 40
MERCURY 4.4E~1 5.IE~7 I.OE-63 1.2E-63
HICKEL 1.8E-61 2.3E-61 2.7E-63 3.7E-63 110
VANADIUM :I.IE-06 NA 2.0E-63 NA 31
YOC:
ACETONE NA 4.2E-09 NA 8.3E-65 16
ETHYLBENZENE NA 2.5E-09 NA 5.0E-65
STYRENE NA 1.IE-09 NA 1.4E-04 96
TOLUENE NA 9.2E-10 NA 1.IE-65 51
TOT AL XYLENES NA 9.IE-08 NA 12E-0I 26
._--- . .---- ... .__.._.
8NA:
81S(2 -ETII YLlIEXYL)PIITH ALATE 9_4E-10 5.8E-61 3.0E-06 181:-6]
DI8ENlOFURAN UE-oB 2.4E-06 2.3E-04 1.4E-62
IIEXACHLOROBENlENE NA 5.4E-67 NA 6.4E-63
PENTACHLoROPHENOL 1.5E-oI 8.1E-68 2.9E-04 1.1E-63
.L-----.---.------
loa.
---...... ...
T "'.. P.llc8IIW
l18Urcllodu
For o..-5/tc
Rcaldall
1£ ().I
NA
(:-06
£ 05
E 0]
NA
(:-Ot
£01
6 )I, IIJ i
6 3£ OJ I
S 1E 05 .
48E ().I
I ROIl
1 21, OJ .
12E1I11
2 41: III
- ---..--.,.
E().I
NA
E-01
E.OS
I: 01
--- -.-
---- ...
1 SIoIH
S OE 05
141: (M
8 91: fI~
121, CH
NA
NA
NA
NA
1 III: III I
141: O!
6UO'1
201: fli
uJ ~ .,
"
o 0 Q'
-tJ t ;;
---<. ,.... ..
-------
- ---- -.-...
o.-Sile ...... Oa-Silc RC81da18 O.-Sile RCIIidaII
0.-1118 ...... 00-5118 ...... PotaIIW PoteaIW PoIaIdII
,...... ....... HIIUnI .... IlIIUnI .... llaurclllllk. Toeal PWIatiaI
H"" .... HaanI Wu Surf.. SolI ....... A S..-,rf- SolI ....... A Surface WItcr Sol "Iailioa A II.,..........
III8rf8ca 1011"""- ....,.. 5011.""- 0...1 CoaI8d Dermal CoaIat Dermal Coataca Few 0.-5118
COMfOUND ....... An8 Total Total'" SoudIcr8 Area TC1181 T CJCaI Sile SouIhcn AnI Toeal ......
,All:.
TOTAL CPAII 4.2E-06 6.5E-06 2.4E-02 ).8E-02 NA II JI;
ACENAPHTHENE 4.)E-08 1.8E-06 2.5E-04 I.OE-02 NA , Iii
ACENAPHTHYLENE 6.2E-oI ).IE~ J.6E-04 I.IE-o) NA UE
ANTHRACENE 2.)E-oI 3.5E-07 1.4E-04 2.OE-o) NA 22E
BENIO(OHI)PERYLENE 4.5E-07 1.9E-07 2.1E-o) 1.1E-o) NA 441: (
FLUORANTHENB 9.5E-07 UE-06 5o6E-o) 2.)E-02 NA 291:
FLUORENE 7.4E-08 J.JE-06 4.)E-04 1.9E-02 NA 201:
HdETHYLN APHTHALENE UE-07 9.)E-06 7.4E-04 5.4E-02 NA 551:
2-METHYLNAPHTHALENE 6.2E-07 1.9E-05 ).6E-o) I.IE-ol NA 121:
NAPHTHALENE 3.6E-07 .t. 7E-05 2.IE-o) 2.8E-01 NA 281:
PHENANTHRENE 5.)E-07 9.9E-06 ).IE-o) 58E-02 NA 6 IE
PYRENE UE-06 3.6E-06 7.5E-o) 21E-02 NA 291:
u- ----_.-. "- . .---
PYRJDINES:
TOT AL PYRIDINES S.4E-07 2.6E-05 1.IE-~2 5.IE-01 651:-0' I lI-.'l
-..-----.--- ------ . -... ...
TOTAL: 0000059 0.00019 013 12 065 1
. -'_u_. .. - -- '.." ..
Lelend:
NA - Noe ApPlicable ...u --. ----........- ". on- -"""
T ADI.E 6-41 (Continued)
SUMMARY TABLE - HYPOTHETICAL ON-SITE RESIDENT
fUTURE SCENARIO - NONCARCINOGENIC RISK
IIUMAN HEALTH EVALUATION
REILLY INDUSTRIES, INDIANAPOLIS, INDIANA
File N._:'~UMNCF].WKI .
. 06-0«-90
01
01
OJ
OJ
tJ
01
02
01
0'
0'
01
01
~: I
HI
~ ~;
co\)
1) t -
~.-t ~
~ .
-------
7 A~LE 3
/ (I'; 3
Summary of 51te Risks
Groundwater
~."""..'.."'""'"'''''''
\.:\~r:: .:~:[t;:\:~~r~'~
........
. Futul'8 Offsite Resident
Orinking
ContaCt
Cum!m Offsite IndUSmat Worker
InhaiaDon
~
247 (pyridine)
0.90
5.5x10" (benzene)
7.4x10. (benzene)
-
0.13-0.29
1.64x1 O~. 1.07x1 ~
: Future orrstte InduStrial Worker
i I~on
'-
217.01 . 279.25
7.3Sx1 0-' . 6.84x1~
- -.---.
.'
. .
F'
-------
TABLE 6-34
SUMMARY TABLE - HYPOTHETICAL OFF-SITE RESIDENT
Ft1Tt1RE SCENARIO - CARCINOCiENIC RISK
HUMAN HEAL rn EV ALUA TION
REn.L Y INDUSTRIES. INDIANAPOLIS. INDIANA
I a.bte :J
(co NT. )
2 of 3
TOTAl.:
P-..& PCICaID&I
~1UIk CarciDo8C1111: IUak
0. To DriMiq Dae lit GnIuad
Oraaad 'tV... Wtt&r COIIt8cC
,
I
!
S.IE~5 1. 7E~7 I
4.9E-44 7.2E~
4.3E~7 1.4E-09
9.7E~7 4.0E-09
6.0E~ 8.8E-09
I I
I
I
1. 7E~ 2.SE-()8 I
I I
8.6E~ t.4E~8
5.5E-44 7.4E~
I
i
iCOMPOUND
MET AU:
ARSENIC
I::~
CHLOROFORM
METHYLENE CHLORIDE
TRlCHLOROETHENE
BNA: I
BISl2-ETHYLHEXYL)PHTHALA TE
PAIl:
B(a)P-TE
File N...: SUMGC1.WKI
06-Da:-90
. .
. .
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~
T ABl.E 6-368
SUMMARY TABLE - OFF-SITE: INDUSTRIAL WORKER
INHA.LA TION OF VOLA Tn.£S DURING INDUSTIUAL GROUNDWATER USE
CURRENT AND FU'T'URE SCENARIOS - CARCINOGENIC RJSK
HUMAN HEALTH EVALUATION
REILLY INDUSTRIES. INDIANAPOLIS. INDIANA
r a b Ie :;
(COI'-JT: )
30+ 3
~'. .'.
... . ".. -, '.'" ..
CURRENT SCENARIO:
r-
I Coaqx
-
I
!BENZ
InJct
I
ITOTA
I
I FUTtJ
!co~
I ~ Ul4illle Cuc.cr Ri8k
IIIDd Qlaic8l:lln& Sc.=ario I Aa8IIIS SccnanD
I
'ENE 1.00E-06 1.62E~S
ILOROETHENE \.04E~8 1.61E~7
L \.07E-06 I.64E~S
RE SCENARIO: I
u- UlIItimc c.-r IU8k
JUDd ie8aIt Scaana Aa8IIIS Sc.cII8no
QIa
BENZENE
TRJCHLOROETHENE
TOTAL
6.83E-04
9.86E~7
6.84E-04
7.34E-04
1.09E-06
7. JSE-04
File N-: SUMCiC2.WKl
R.N.: I
03-Apr-91
-------
20
for scenarios such as the off-site resident (HI=247), and off-
site industrial worker (HI=277) (see Table 4). 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.
DescriDtion of Alternatives
During the Feasibility Study (FS), Reilly identified and
evaluated a list of alternatives that could be used to address
the threats and/or potential threats identified for the soil,
sludge and 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).
The alternatives were evaluated separately for soil
contamination, for contamination associated with sludge at the
South Landfill, and for groundwater contamination associated with
each of the five source areas. Remedial alternatives were
screened for each source area based on contaminant
characteristics at that area.
As a result, some of the alternatives did not apply to all five
source areas. This is particularly evident for the containment,
or cover, alternatives, which would have to be combined in some
manner for total site cleanup. The areas for which the
alternative is applicable are listed under that particular
alternative.
Following this initial screening, the list of alternatives was
evaluated and only alternatives that met the nine criteria,
listed below in the comparative analysis section, were submitted
for detailed analysis.
SOIL CLEANUP
Seven alternatives were evaluated during the detailed analysis of
alternatives in the FS (See Table 5). These included no action:
soil cover: asphalt/concrete cover: mUlti-layer cover:
excavation/soil washing/slurry bioremediation: low temperature
thermal desorption: and incineration, as described below.
Alternative 1:
No Action
Under
would
would
fence
this alternative, no remediation would occur and the site
remain in its present condition. The contaminated soils
not be addressed. This alternative would include existing
maintenance, construction of access controls, periodic
-------
TABU: 6-35
SUMMARY TABLE - HYPOTHETICAL OFF-SITE RESIDENT
FUTtTltE SCENARIO - NONCARCINOGENIC RISK
HUMAN KEALm EVALUATION
REn.L'Y INDUSTRIES. INDIANAPOLIS. INDIANA
.>
! PCII8DII PGI8iII l
! N, ~J-': IUIk N~ IUIk j
Daa To DrtIItiq 0. ID CiI'OIIIIIIi
: COMPOUND 0IaaDd W... W.. CCIIIt8IS
; METALS: I
I
i ARSENIC 0.67 0.002
iCADMt1lJM 0.13 0.004
ICHROMIUM III 0.01 0.0002
I
I CHROMIUM VI 0.06 0.002
~ LEAD 4.27 0.02
MERCURY O. ()o$ 0.0004
I NICKEl. NA 0.03
;VANAD'IUM 0.79 0.01
-
jVOC:
CHLOROFORM 0.02 0.00005
1.2-DIC:HLOROETHENE NA O.OOO()1
ETHYLBENZENE 0.03 0.0004
METHYLENE CHLORIDE 0.01 0.00002
TOLUENE 0.01 0.0002
TOT AL XYLENES 0.003 0.0000.&
8NA:
BISC2-ETHYLHEXYL)PHTHALATE 0.01 0.0002
PAR:
TOT AI. CPAII 0.0000'1 0.0000003
NAPHTHALENE 1.74 0.03
l-MET1f1YLN APHTHALENE 0.01 0.001
PYRIDINES:
TOT AI. PYlUDINES 239 0.81
AMMONIA 0.30 0.0010
TOTAl.: 247 0.90
Lcp:
NA- Nat~.
File NalDe: SUMGNC1.WKI
OS-Dec-90
. .
T~6i..t::
I D+ 2
4..
.
-------
TABLE 6- 36b
SUMMARY TABLE - OFF-SITE INDUST1UA1. WORKER
INHALATION OF VOLATILES DURING INDUSTRIAL o ROUNDW A TER USE
CURRENT AND FU'I'URE: SCENARIOS - NONCARCINOGENIC RISK
HUMAN HEALTH EV ALUA nON
REn.L Y INDUSTRIES. INDIANAPOUS. INDIANA
I ,..,." L E '-I
( CeNT.)
~ c~ Z.
CURRENT SCENARIO:
r Haard IDda
I
I
icolllflOUDd Qu'-st SI:aano ! Batda Tumcwer Sccurio
I
i \
: AMMONIA 0.09 0.20
i PYRJDINES O.CM 0.09
!TOT AL 0.13 0.29
I
i
. FUTURE SCENARIO: I
;Co~ Qu--- Scaana I Batda TIIftIDVeI' SI:aano
I AMMONIA 12.41 14.65
I 264.60
I PYRJDINES 264.60
TOTAL 277.01 219.2.5
Haud IDdea
File Namc: SUMCiC2. WK 1
R.N.: 2 .
03-Apr-91
.'
. ..
.'
-------
-,
iPt- f?> L E 5
j\L TERN A TIVES ANALYZED
FOR SOIL CLEANUP
. ..
.',-"'. .
AL T]~RNA TIVE 1: NO ACTION
ALT]ERNATIVE 2: SOIL COVER
AL TJERNA TIVE 3 : ASPHALT /
CONCRETE COVER
AL T:ERNATIVE 4: MULTI-LAYER
caVER
ALTERNATIVE S: EXCA V ATIONI
SOIL W ASHING/
SLURRY BIOREMEDIATION
AL1'ERNATIVE 6: LOW
. ,TEMPERATURE
THERMAL DESORPTION
AL1~ERNATIVE 7: INCINERATION
. .
-------
21
.
''''''''.'.
monitoring of the ground-water quality, and provide operation and
maintenance at the five areas. Although this alternative does
not address the contaminated soils, its inclusion in the detailed
alternatives analysis is required by CERCLA as a baseline for
comparison to the other alternatives developed. Costs associated
with this alternative consist of periodic sampling and analysis
of ground11later quality at the five CERCLA areas.
Future la:nd use at the Former Sludge' Pi t, the Former Drainage
Ditch, th,e Former Abandoned Railway Trench, and the South
Landfill/Fire Pond would be limited to industrial use by
institutional controls consisting of deed restrictions.
Present Worth Cost:
Time to Implement:
$910,000
none
Alternative 2:
soil Cover
A soil cover would be constructed over the soils at the Former
Drainage Ditch and the South Landfill/Fire Pond. Prior to
installation, any vegetation would be cleared, large debris at
the surface would be removed, and the remaining material would
then be compacted and graded. FOllowing this site preparation,
six inches of a gravel based material would be spread across the
graded area. . Once spread, the gravel would be covered with a six
inch layer of topsoil and seeded to minimize erosion.
Future la.nd use at the South Landfill/Fire Pond would be limited
to industrial use by institutional controls consisting of deed
restrictions.
Present worth Cost
Time to Implement:
$ 1,766,000
, 6 weeks
Alternative 3:
As~ha1t/Concrete Cover
Under this alternative, an asphalt or concrete cover would be
placed over the remediation areas at the Lime Pond, the Former
Drainage Ditch, the Sludge Treatment Pit, and the Abandoned. .,'.
Railway ~~rench. Surface debris and vegetation would be removed
and the clreas would be graded prior to covering these areas. A
thin layer of gravel would be placed over these areas prior to
the placE~ment of the .asphal t or concrete covers.
Future lcmd use at the Former Sludge Pit, the Former Drainage
Ditch, and the Former Abandoned Railway Trench would be limited
to indus1:rial use by institutional controls consisting of deed
restrictions.
. .
-0,- .
Present North Costs:
Time to Implement
$ 1,300,000
6 weeks
-------
22
Alternative 4:
MUlti-Laver Cover
Under this alternative, a mUlti-layer cover consisting of a sand
bedding layer, a high density polyethylene geomembrane, a
drainage layer, and a layer of loam would be placed over the Lime
Pond. Surface debris and vegetation would be removed and the
area graded prior to covering this area. This area would be
extended to the south and west to cover the area where lime
sludge is currently located.
,
Future land use at the South Landfill/Fire Pond would be limited
to industrial use by institutional controls consisting of deed
restrictions.
Present Worth Costs:
Time to Implement
$ 550,000
4 weeks
Alternative 5: Excavation/Soil Washina/Slurrv Bioremediation
Under this alternative, soils at the Lime Pond drum removal area,
the Abandoned Railway Trench, the Former Sludge Treatment Pit,
and the Former Drainage Ditch would be excavated and treated.
Bioremediation would be preceded by soil washing to help to
concentrate the contaminated silt and clay fractions of the
waste. Water and acclimated, cultured bacteria would then be
added to the soil mix and agitated, resulting in a soil slurry
mixture. This mixture is then pumped through a series of
biotreatment reactors where additional nutrients, bacteria, and
air are utilized to treat the contaminated slurry. Treated soil
would be replaced in the area from where it was excavated
consistent with the promulgated Corrective Action Management Unit
(CAMU) regulations regarding replacement of the treated soil.
Future land use at the Former Sludge Pit, the Former Drainage
Ditch, and the Former Abandoned Railway Trench would be limited
to industrial use by institutional controls consisting of deed
restrictions.
Present Worth Costs:
Time to Implement
$ 6,000,000
60 months
Alternative 6: Low TemDerature Thermal Desorotion
Under this alternative, soils at the Lime Pond drum removal area,
the Abandoned Railway' Trench, the Former Sludge Treatment Pit,
and the Former Drainage Ditch would be excavated and treated.
Thermal desorption units separate organic contaminants from soil
by increasing the volatilization through heating. These
treatment units typically consist of a chamber for heating the
soils, a condensate collection system, and an off-gas treatment
system. The organic contaminants are not directly destroyed but
are separated from the soil as off-gases. The organic off-gases,
-------
23
as well as water removed from the soil are captured in the
condensate treatment system. Additional treatment of the
airstrealtt by activated carbon is usually required. Treatment
residuals could be destroyed in on-site boilers for which
regulator'y approval would be required, or sent off-site for
treatment, and disposal. Treated soil would be replaced in the
area froltl where it was excavated consistent with the promulgated
Corrective Action Management unit (CAMU) regulations regarding
replacemEmt of the treated soil.
Future lclnd use at the Former Sludge Pit, the Former Drainage
Ditch, and the Former Abandoned Railway Trench would be limited
to indust:rial use by institutional controls consisting of deed
restrictions.
Present ~~orth Costs:
Time to Implement
$ 4,000,000
6-12 months
Al ternat:L ve 7:
Incineration
Under this alternative, soils at the Lime Pond drum removal area,
the Abandoned Railway Trench, the Former Sludge Treatment Pit,
and the Former Drainage Ditch would be excavated and incinerated.
The rotary kiln incinerator uses a primary combustion chamber
which ro~cates about its long axis to cause a turbulent
environmlant to treat materials. Materials to be treated are fed
into a "hot" end of the incinerator along with the primary fuel
and combl~stion air for the system. Gases produced from this
process ;are passed through the "cold" end of the incinerator and
generally into an afterburner or secondary combustion chamber.
Treated :soil residuals or bottom ashes also exit the incinerator
via the stack. Flue gases then exit the incinerator via the
stack. Treated soil would be replaced in the area from where it
was excavated consistent with the promulgated Corrective Action
Management unit (CAMU) regulations regarding replacement of the
treated soil.
Future land use at the Former Sludge Pit, the Former Drainage
Ditch, the Former Abandoned Railway Trench, and the South
Landfill/Fire Pond would be limited to, industrial use by
institutional controls consisting of deed restrictions.
Present Worth Costs:.
Time to Implement
$ 6,350,000
6-9 months
SLUDGE CLEANUP
Three alternatives were evaluated during the detailed analysis of
alternat~ives in the FS/CMS (see Table 6). These included no
action: in-situ solidification: and incineration, as described
below.
-------
{.4Ir,:,--, -
-rAP.JLE ~
j~LTERNATIVES ANALYZED
FOR SLUDGE CLEANUP
(SOUTH LANDFILL)
AIJTERNATIVE 1: NO ACTION
AIJ TERNA TIVE 2: IN-SITU
SOLIDIFICATION
AIJTERNATIVE 3: INCINERATION
. .
-------
24
Alternative 1:
No Action
Under this alternative, there would be no action taken for the
sludge contamination at .the South Landfill. This alternative
would not reduce the threats to human health and the environment
at the site. The inclusion of the no action alternative is
required by law to give u.S. EPA a basis for comparison between
remedial alternatives. Costs associated with this alternative
consist of periodic sampling and analysis of groundwater quality
at the five CERCLA areas. Future land use at the South
Landfill/Fire Pond would be limited to industrial use by
institutional controls, including deed restrictions.
Present Worth Costs:
Time to Implement
$ 290,000
Immediate
Al ternat.i ve 2:
In-situ Solidification
Under this alternative, the sludge would be solidified in order
to provide a stable foundation for a cover material and to
prevent the sludge from seeping through or around a cover.
Solidification would be accomplished through a large diameter
auger. The mixing head is enclosed in a specially designed
cylindrical hood which allows for the capture of air emissions
from thE~ mixing operation. As the augur head is advanced into
the sludge, grout is injected into the sludge and blended into a
solidified mass. Future land use at the South Landfill/Fire Pond
would bE~ limited to industrial use by institutional controls,
including deed restrictions.
Present Worth Costs:
Time to Implement
$ 800,000
1.5 months
Al terna1;i ve 3:
Incineration
Under this alternative, which is similar to Alternative 7 for
soil, sludge would be mixed with sand to facilitate excavation
and incineration. Future land use at the South Landfill/Fire
Pond would be limited to industrial use by institutional
control:;, including deed restrictions.,
Present Worth Costs:
Time to Implement
$ 8,600,000
7.25 months
summary of the com~arative Analvsis of Alternatives for Soil
Cleanu~
The nin.e criteria used by U.S. EPA to evaluate remedial
alternatives, as set forth in the NCP, 40 CFR Part 300.430,
include: overall protection of human health and the environment:
compliance with applicable or relevant and appropriate
requirements (ARARS): long-term effectiveness: reduction of
-------
25
toxicity, mobility, or volume: short-term effectiveness:
implementability; cost: state acceptance: and community
acceptancE~. Based on evaluation of the alternatives with
to these nine criteria, u.s. EPA has selected Alternative
TemperatuJ::-e Thermal Desorption as the alternative for the
cleanup under this operable unit remedy for this Site.
respect
6 - Low
soil
THRESHOLD CRITERIA
Protectio1tl of Human Health and the Environment
Addresses whether a remedy provides adequate protection of human
heal th ani:! the environment and describes how risks posed through
each expo:sure pathway are eliminated, reduced, or controlled
through t:reatment, engineering controls, or institutional
controls.
Alternative 1 would not protect human health and the environment
because it does not reduce risks associated with exposure to
contaminated soils. Alternatives 2, 3 and 4 would reduce the
threats to human health and the environment by placement of a
cover material over the contaminated areas, however, they would
not reduce the toxicity, mobility and volume of contaminants
through treatment.
pilot testing is needed before a final determination can be made
regarding Alternative 5; however, it appears that Alternative 5
is less protective than Alternatives 6 or 7 due to potential
longer treatment times which increase short term exposures.
Alternatives 6 and 7 are the most protective because they offer
the greatest reduction in toxicity and the greatest long term
effectiveness and permanence.
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 5 may be able to meet
ARARS, although further pilot testing is necessary before a final
determination can be made. Alternatives 6 and 7 are functionally
equivalent with respect to this threshqld criterion, and are
superior to Alternatives 2, 3 and 4 because of the contaminant
reduction capabilities.
comDlianc:e with ARARs
Addresses: whether a remedy will meet all of the ARARS of other
Federal a.nd State environmental laws and/or justifies a waiver of
those la1lrs.
All of the alternatives are capable of meeting ARARs. ARARs for
Alternatives 2, 3 and 4 are similar to one another and more easily
met compared to the ex-situ technologies ARARs. These ARARs relate
-------
26
to health and safety, erosion control, dust emissions, and storm
water discharge. ARARs for the ex-situ treatment alternatives 5,
6 and 7 include excavation-related requirements in addition to
those specific to the treatment technology, including ARARs
relative to the treatment, storage, transportation and disposal of
hazardous waste. ARARs for Alternatives 5, 6 and 7 also include
air emission requirements. However, pilot testing is needed to
determine if Alternative 5 actually can meet ARARs. ARARs for
Alternative 7 would be the most difficult to meet and would include
compliance with the provisions of 40 eFR 264.34 Part O.
Therefore, it has been determined that Alternative 5 needs further
testing to determine whether it can meet ARARs, while Alternatives
2, 3, 4, 6 and 7 are functionally equivalent with respect to this
threshold criterion, because of their individual ability to meet
the ARARs appropriate to each alternative.
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 5 cannot be ranked relative to the other alternatives
with respect to this criterion until further bench-scale and pilot-
scale tests are performed, due to uncertainties associated with the
distribution of oxygen and nutrients, soil heterogeneities, and
reaction kinetics. Alternative 7 offers the greatest long term
effectiveness and permanence, considering the ability of
incineration to destroy the organic contaminants. Alternative 6
provides a slightly lower level of long term effectiveness and
permanence when compared to Alternative 7. However, the condensate
generated from the desorption process would be incinerated off-
site, resulting in complete destruction of the organic contaminants
in the soil. Alternative 5 has the potential of achieving
contaminant destruction levels similar to Alternatives 6 and 7 but
pilot testing is needed before a final determination can be made
regarding this alternative.
Alternatives 2, 3 and 4 are capable of effectively controlling site
risks over the long term; however, these alternatives would leave
the contaminated soils in place without treatment. The long term
effectiveness and permanence of these alternatives is entirely
dependent on the durability and maintenance of the covers and caps.
Therefore, it has been determined that Alternatives 6 and 7 are
functionally equivalent with respect to this balancing criterion,
and are superior to Alternatives 2, 3, 4 and 5 because of the
contaminant reduction capabilities.
-------
27
Reductio!]. of Toxici tv. Mobili tv or Volume
Addresses: the anticipated performance of the treatment technologies
a remedy may employ.
Alternative 7 provides the greatest reduction in toxicity, mobi3:ity
and vol~~e. Alternative 7 provides for onsite, permanent
destructj.on of contaminants. Alternative 6 provides a high degree
of contaIII.inant removal. contaminants would be transferred from the
soils to condensers or filter media. The toxic compounds would be
recovered as toxic waste and would be disposed of offsite.
AlternatjLve 5 offers the potential for a high degree of contaminant
removal, but treated soils may contain higher levels of residual
contamination than Alternatives 6 or 7. However, pilot testing is
needed before a final determination can be made regarding this
alternative. Alternatives 2, 3 and 4 will not reduce the toxicity
or volumf~ of contaminants. Alternatives 3 and 4 may be effective
at reducing the mObility of contaminants by reducing groundwater
infiltra'~ion, although this reduction would not be achieved through
treatmen't. Alternative 2 will have less of an impact on reducing
contamimmt mobility when compared to Alternatives 3 and 4.
Therefor1e, it has been determined that Al ternati ves 6 and 7 are
functionally equivalent and are superior to Alternatives 2, 3, 4
and 5 with respect to this balancing criterion because of the
contaminant reduction capabilities.
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 dtlring the construction and implementation period, until
cleanup standards are aChieved.
Alternatives 2, 3 and 4 result in higher short term exposures over
no acticm as a result of workers being involved in grading and
other ac.tivities at the source areas. The longest time to complete
a containment alternative is six weeks.
Alternat.ives 5, 6 and 7 result in high~r short term exposures when
compared. to the containment alternatives. Excavation of
contaminated soil may release organic chemicals to the air.
Excavati.on will take .place over longer periods of time than for the
containrnent alternatives, resulting in an increased potential for
releasesi of chemicals to the air. There is also a potential for
failure of the off-gas treatment system which may increase short
term exposures to site contaminants. With proper maintenance and
monitorj.ng, the likelihood of equipment failure resulting in a
signific:ant release is low. Exposures to onsite and offsite
receptors would be minimized by air emission controls, such as use
of dust suppressants during material handling. Also, properly
designed engineering controls will significantly limit the
-------
28
potential exposure to organic chemicals to on-site workers and off-
site residents.
Pilot testing is needed to fully evaluate Alternative 5 with
respect to this criterion while Alternatives 2, 3 and 4 result in
the lowest risks in the short term. Alternatives 6 and 7, while
potentially resulting in increased short' term risk, will not
significantly increase exposure risks in the short term with
properly designed engineering and air emission controls and ongoing
monitoring and maintenance.
ImDlementabilitv
Addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed for a
particular option to be put in place. .
Alternatives 2, 3 and 4 are expected to be easy to implement. The
necessary materials, equipment and specialists for each of the
capping/cover alternatives are readily available. Alternative 6 is
also readily implemented, except that bench and pilot scale tests
are required to establish treatment parameters. Offsite disposal
of hazardous wastes will have to be arranged. The necessary
technologies, specialists and equipment are readily available.
Alternative 7 can be implemented but will likely require higher
levels of permitting and monitoring than Alternative 6.
Alternative 5 may be the most difficult alternative to implement
since the reliability of bioremediation for achieving the cleanup
goals is uncertain, due to the uncertain treatment effectiveness
and levels of contamination present at the site.
Therefore, further testing is required to
implementability of Alternative 5 and Alternatives
7 are functionally equivalent with respect to
criterion.
determine the
2, 3, 4, 6, and
this balancing
~
Included are capital costs, annual operation and maintenance costs
(assuming a 30 year time period), and Det present value of capital
and operation and maintenance costs. The selected remedy must be
cost effective.
The present worth costs of Alternatives 2, 3 and 4 are low, ranging
from $160,000 for the asphalt/concrete cover on the Former Sludge
Treatment Pit to $2,000,000 for a soil cover on the South Landfill,
including groundwater monitoring costs. However, some combination
of these containment alternatives would be necessary for total
cleanup of the five CERCLA areas under this operable unit, while
each of the treatment alternatives listed below represents total
cleanup. Present worth costs for Al ternati ve 5, 6 and 7 are higher
than those for the containment alternatives, ranging from
-------
29
$4,000,000 for Alternative 6 to $6,350,000 for Alternative 7.
Therefore, based on analysis of the costs associated with all of
the alternatives analyzed in the FS, it appears that Alternative 6
has the lowest present worth cost for the treatment alternatives,
and Alte;rnative 4 has the lowest present worth cost for the
containment alternatives. However, the containment alternatives
would have to be combined in some manner so that total site cleanup
can be achieved for all of the CERCLA areas.
MODIFYING CRITERIA
state ACC!eDtance
AddresseEI whether or not the state aqency aqrees to or oDjects to
any of t1Le remedial alternatives, and considers state ARARs.
The Indi21na Department of Environmental Management (IDEM) has been
intimately involved with the site throughout the RIfFS, has
attended all technical progress meetings, has been provided
opportun:Lty to comment on technical decisions, and concurs with the
selection of Al ternati ve 6 as the selected remedy for this operable
unit soil cleanup at the Site.
community AcceDtance
Addresselil the puDlic' s qeneral
alternatives and proposed plan.
response
to
the
remedial
Throughout the RI/FS at the Site, community involvement has been
moderate. U . S. EPA has been accessible and respons i ve to community
concerns throughout the study. At the public meeting for the
proposed plan, the majority of those in attendance, as well as the
majority of those who submitted written comments regarding the
proposed plan, were in favor of Alternative 6 as the most
appropri;ate choice for the soil cleanup. Permanent contaminant
destruction was the primary reason for'the citizen support for this
remedy. ",,'. ,', .
In summa~~ion, Al ternati ve 1 is unaccept,able for protection of human
health and the environment. Alternatives 2, 3 and 4 will provide
protection from exposure to risks associated with contact with
contaminated soils at the CERCLA areas but will not prevent their
detrimental impacts on groundwater quality and its accompanyinq
unacceptable risk. These alternatives will also not reduce the
toxicity, mobility or volume of contaminants through treatment and
will req~ire that contamination be left in place. The long term
permanence of these containment alternatives can also not be
assured so that future risks associated with exposure to
contamin,ated soil cannot be entirely prevented. Alternative 5
would require additional time for pilot studies, may not be
effective, and has a similar present worth cost to Alternatives 6
-------
30
and 7. Alternatives 6 and 7 may pose problems with short term
effectiveness due to potential emissions or dust generated from
excavation activities but these potential problems will be
minimized with properly designed engineering controls and dust
suppression technologies. Alternatives 6 and 7 permanently remove
the contaminants from the soil, thus ensuring that risks associated
with exposure to contaminated soil will be eliminated.
Alternatives 6 and 7 offer similar levels of long term
effectiveness and permanence and permanently reduce the toxicity,
mObility and volume of contaminants through treatment. Alternative
7 is less implementable than Alternative 6 and is more costly.
Therefore, the best balance among the seven alternatives is
Alternative 6, Low Temperature Thermal Desorption.
EPA also evaluated the aforementioned seven alternatives for soil
cleanup of the South Landfill. The Fire Pond cleanup is addressed
under alternatives for sludge cleanup. Alternative 2 - Soil Cover
-was selected for soil cleanup at the' remainder of the South
Landfill. As is highlighted in the discussion above regarding hot
spot delineation, due to the widespread contamination at this area,
the absence of any discernable hot spot area, and the prohibitive
volume of contaminated soils at this area, it was determined that
the South Landfill would not be included in the hot spot
delineation.
As a result, it was determined that Alternatives 2, 3 and 4 were
more effective in the short term, more easily implementable, and
more cost effective than Alternatives 5, 6 and 7. Alternative 5
would require additional time for pilot studies, may not be
effective, and has a similar present worth cost to Alternatives 6
and 7. Although Alternatives 2, 3 and 4 do not reduce the toxicity,
mobility or volume of contaminants through treatment, as would
Alternatives 6 and 7, they are more cost effective for cleanup of
the South Landfill. Finally, Alternative 2 is more easily
implemented than Alternatives 3 and 4 and has a greater
effectiveness in the long and short term than Alternatives 3 and 4.
Therefore, the best balance among the seven alternatives for South
Landfill cleanup is Alternative 2, Soil Cover.
SELECTED REMEDY FOR SOIL CLEANUP
As was discussed in the previous section, EPA has selected
Alternative 6 Low Temperature Thermal Desorption as the
appropriate soil cleanup remedy for the Reilly Tar and Chemical
site. This alternative was selected because it is the most
appropriate al ternati ve for this operable uni t action and is
compatible with the final remedial alternatives anticipated for the
Site, which will likely encompass additional source-area
remediation.
The objective of this operable unit action is to remediate on-site
source areas that are contributing to contamination of both soils
-------
31
and grounl:iwater. The areas that will be addressed by the selection
of this remedial action are the Lime Pond drum removal area, the
Abandoned Railway Trench, the Former Drainage Ditch, and the Former
Sludge T:reatment Pit. The result of this action will be a
reduction in the levels of on-site contamination and will maximize
the performance of the groundwater extraction/treatment/discharge
system tn,at was detailed in the ROD for the groundwater operable
unit at the site.
The FS cc:mtains a description of this alternative. and a typical
process flow chart for thermal desorption is outlined on Figure 7.
Thermal desorption units separate organic contaminants from soil by
increasing volatilization through heating. The units generally
consist of a chamber for heating the soils, a condensate collection
system and an off-gas treatment system. operational temperatures
and treat~ment times are tailored to the properties of the material
being tre~ated. Typically, temperatures range from 200 degrees F to
1000 degrees F and treatment times range from a few minutes to an
hour. Tbe organic contaminants are not directly destroyed but are
separated from the soil as off-gases. The organic off-gases as
well as \later removed from the soil are primarily captured in the
condensa1:e treatment system. More volatile organics are captured
in a media such as activated carbon or destroyed by incineration.
Most syst:ems also require a cyclone separator to reduce particulate
emission~;. Water, organics, and some particulates are carried away
from the heated chamber by an inert carrier gas. Particulates are
usually <=aptured in a cyclone separator or liquid scrubber. Heat
exchangeJ~s are generally used to condense the bulk of the organics.
Additional treatment of the airstream by activated carbon is
usually required. The condensed organics, contaminated carbon, and
scrubber water. would contain hazardous materials and would require
additional treatment. It is possible that the condensed organics
could be destroyed in on-site boilers. Approval of the u.S. EPA is
required for additional treatment in on-site boilers.
Several different types of thermal desorption units are in
developm'ent or are currently commercially available. A key aspect
of the d.ifferent designs is the method employed for heating the
contamin,ated soil. Heating methods include indirect or direct
fired rotary kilns, internally heated screw augurs and fluidized
media. Factors such as soil properties; level of contamination and
contaminants determine the type of unit to be used. Bench scale
and pilo't scale tests, are required during remedial design to define
operational parameters and to assure that cleanup goals can be met.
Risk Based Target Cleanup Levels (RBTCLs) are listed in Table 7.
These were presented in the FS/CMS. These RBTCLs were used in the
hot spot delineation process for determining the amount of soil to
be excavated at each of the CERCLA areas. Soils at the Abandoned
Railway Trench, the Former Sludge Treatment Pit, and the Former
Drainage Ditch will be treated to industrial cleanup standards as
are highlighted with an asterisk on Table 7. Soils at the Lime
-------
"
'4,
'=
~
~
~
EtaI
_1
8Al18IA1M1Hf
IfttIM
I
i---. --- -1
I
I
I
~ '
---- I
-------~-
---. w....
IXCAVAn
DIIOIII'1IOH
- . -..-. D*II. 0wi8rII8
c...-
18IA18 ---
FIOUftE 4.2-2
Thennal Deecllpllon PIOC8SI Row
(Soun:e. EPA T8dWca1 BulletIn. 1981)
. . Cleen on Gal
.-.. Spent
C.1bon
. .. . C~"'"
ConI8InNnI8
"'" -
--
~I
iiI
-------
TABLE 1.3-2 .
SUMMARY OF RISK.BASED TARGET CLEANUP lEVElS (RBTClsIIN MG/KG FOR B(aIP J[ IN 5011 ASSIIMING II~IIIISHUAI ICOMMIIIt.IAI :;1\ I 11:)1
AElll Y INDUSTRIES, INDIANAPOLIS SITE
r--""'-"-"---"'-l---.""''''''-''''-'''''' '1-""""''''''''B(~~'~TE'AB'TC~~f~ 'i';d~~!~~iic~i~!~~!~~:~'~!)E.;.. :,...._.:~ '.. I
~~. !~!9~! ~!!'~~..~~~:~
MEDIUM SWMU RE;CEPTUR SCENARiO ferg!! ~!SK =:~~>~ .:1 ~!2~! !!!S.~ ::. ~
Surface Soil Soulh Landfill On,Slle Worker RME aooo tWO
...------ ---- --- --- ..-.
On.Sile Worker Worsl Case 60 6
- .- . ... ... -- ..
Lime Pond On.Sile Worker RME 300 30
Railway Trench .. ---- - -----
Sludge Pit
Drainage Ditch On-Sile Worker Worst Case 60 6
.. _. ..'. ....- .... .... -
-------.-.- .
lime Pond Construction Worker RME 2000 200
Railway Trench ._-- --- - - -- _...
Sludge Pit
Drainage Ditch On-Site Neighborhood RME 2000. 2()(}
Soulh Landfill Resident (Teen)
.. .. ...... .... ..-
Subsurface Soil lime Pond On.Site Worker RME 10,000 1OUO
Railway Trench .-. .-. .. ..n
Sludge Pil
Drainage Dilch Conslruction Worker RME 2000 20n
South landlill
_h' - ----- --- ---- ...
On-Sile Nelghborhuod RME 15,OOU I ~.lll)
Resident (Teen)
Notes:. .... - h. -- .- . .-..-. __n- - ...
n(aIP; n; - Benlo(a)Pyrene TOllic Equivalenls.
liME ",Reasonable Mallimum Ellposure.
~WMU - Solid Waste Management Unit. ---- -- .. ..
all
06
3
-.----- -+0- - .
'*~*
---
20
...- ...__.._~. +.-.-
2U
~~ -.----=----.-..----...-
100
~ ~~u "-
I ~,II
SUM-'_BW01
.---- --. -- - ..
o
o
-
It
AN: 5
22'Apr-93
-
~
~
....
-------
TAmE 133
SUMMARY OF RISK.BASED TAnG!:: I CI EANUP lEVEl S (R8TCls) Fon PYIUDIN1:S IN SOli. A~;:iIlMII~I; INlJlJSIIUAt /COMMUICIAI :.111 11:;1
RElll V INDUS fRIES, INDIANAPOLIS SITE
.---- --.--. ....,-,-. '"'''''-''' .,.-.... .....--.-..-----.--_u....--..-.-. .. ....- .. ...h._._......-- ......-
PVridillu RBTCL8 'ur
'nctllstr'aI/Commercl.' 9118 Us. (ppm)
MEDIUM .. BY/MU RECEPTOR SCENARIO _._.3ra~9~t ~t :' ~)
-. .. ... -- .-...
Surface Soil SOllih landlill On.Site Worker rlMl 6G.(>OO
--".'--'-- . -_. ... -- ... ..
On-Sile Worker Worst Case !>1U
.. . --_.. -. -'-.- .. . .. -- -------.-.-
lime Pond On-Sile Worker RME 2500
Railway Trench -- ..---.. -- - -"0 .... _.
Sludge Pit
Drainage Ditch On-Sile Worker Worsl Case 510
----- - - -. -- '--'-----
lime Pond Conslructlon Worker RME -*= 510 *
Railway Trench -
-.- - ------- -.
Sludge Pil
Drainage Ditch O"-Slle Neighborhood RME 4;!OO
Soulh landfill Residenl (Teen)
- - - ... -"... .. ---------.
Subsurface Soil Lime Pond On-Sile Worker RME 2500
Railway Trench -..----_u_-.--- _.- ------. ..-------- .
Sludge Pil
Dr ainage Ditch Conslruclion Worker RME !>IO
Soulh landfill
------ - . - - ". - - - -.- "--"---" - .. .....
O".Sile Neighborhood nME 4:0'00
Resident (Teen)
. ---..-..-- ------- .-.... - . ".- - .- - u_.. ----. .. ..
NOles:
RME . Reasonable Maximum Exposure-
SWMU - Solid Wasle Management Unit --'- . -..- ....---. - -.....------
--- -- ....--
SUM_I_P WOI
fiN 6
2:! A", 9:1
;f
~
-
,.
.....
I\)
o
-b
,.....
~
..
-------
TABLE 1.3.2
SUMMARY OF RISK.BASED TARGET CLEANUP lEVELS (RBTCls) IN MG/KG FOR B(aW rE IN 5011. ASSlIMING RlSIOI:NHAI SitE. liSt
REillY INDUSTRIES,INDIANAPOLIS SITE
.-q.o; "'O'TC'DiiTT.'-'-'''-''---'-''--''''''''''''''''''-''''''..''''... ........ ....... I
o~ .6
..~.- -.- ..-. T8rg.t Risk = ,-
MEDIUM .SWMU . ReCEPTOR SCENARIO T8!ge~ ~~~k.c: 10":4 T8rget Risk = 10"'-5
--- ...---- ...~- - -....-- .- ..
Surlace Soil lime Pond Hypothetical On.Site Resident RME 40 4 114
Railway Trench
Sludge Pit --. -. .. .. ~- - . ".- --_. -
Drainage Ditch ----- .----.-
South landlill Hypothetical On-Site Resident Worst Case 20 2 X 02
-
. ~ .. --. -.- -..- .. ---- -. - -----_.. - - -. ----.-. .. ---
.
Subsurface Soli lime Pond Hypothetical On.Site Resident RME 1500 150 +- t5
Railway Trench -
Sludge Pit
Dreinage Ditch
South landli"
Notes: ... -... --. -_..- - .--. .-.--.-. ..- - -- . .
B(a)P- TE . Benzo(a)Pyrene Toxic Equivalents.
RME - Reasonable M8Jllmum Exposure.
SWMU . Solid Waste Management Unit.
---------.-----.
-. - ......- . -'_n
SUM.R_B WOI
RN:8
22.Apr.93
'U)
C)
-h
-C..
-It.
*
~
~~
o
~....
... ,
-------
TABLE I 35
SlJMMAnV Of IUSKOASU) T AI\Gl , Ct [ANUr I L VI I ~; (nOTCI s) run "YHlDIN[ S IN :,011 A:;~;IIMIN( j HI StDI N IIAI ~jlll. 11:>1
RElll V INDUS fAlES, INDIANAPOLIS SIlE
- - '--".. ...~...... '-"""'..-"".'"'''''''' .....
MEDIUM .,SWMU. RECEPTOR SCENARIO
- ""'....:=..=..&a~_.._~ "-.
Surface Soil Lime Pond Hypothetical On.Site Resident UME
Railwav Trench
Sludge Pit .- u. -. ---
Drainage Ditch
South Landfill Hypothelical On-Sile Resident Worsl Case
- . - --
Subsurface Soil Lime Pond Hypothetical On.Site Resident RME
Railway Trench
Sludge Pit
Drainage Ditch
Soulh Landfill
Notes:
RME . Reasonable Maximum Exposure.
SWMU . Solid Waste Management Unit.
---
SUM_R_P.WQ'
RN.S
22 ApI 93
- '''0.' "o_-oop'viidi'~'e"RB TCl-s"i'or'_o,,,,,,,,,,,,,,,
Resldenllat SUe Use (ppm)
- -- ..0_- 1~!iI~ t!!= !~L=-~-=-
310
--------_...
- - --
t50
. .- ...-- ------------.-- .-
~
410
*
--..-..--.- .
..--.--------------..
~
~ C-
""
o
"h "'-I
"' '""'
d
-------
32
Pond Drum Removal Area will be treated to residential cleanup
standards, as are highlighted with an asterisk on Table 7.
soil will be treated by low temperature thermal desorption to
achieve t~he cleanup standards highlighted with an asterisk in Table
7. The levels that are highlighted on Table 7 represent the lowest
values under a given set of assumptions and at a given risk level
will result in conservative remediation goals that are protective
of all of the receptors for which these levels were derived, and
all receptors assumed to have equal of lesser exposures. In this
manner, all potential exposures will be accounted for and risks
minimized for all receptors. Both industrial and residential
cleanup levels were highlighted for the following chemicals of
concern: cPAHs (using the benzo(a) pyrene toxic equivalency factor
recommended in the Risk Assessment Guidance for Superfund); and
pyridine:s. The RBTCLs derived for surface soil should be applied
to the t,op six inches of soil at the CERCLA areas. The RBTCLs
derived :Eor subsurface soil should be applied to material under the
top six inches and above the shallowest water table in each of the
CERCLA areas.
In order to ensure that applying the RBTCLs as a cleanup standard
to these soils will not pose a residual threat to groundwater when
the soils are placed back into the locations from which they were
excavated, a performance based standard shall also be applied to
the treated soils.
The treated soils shall be tested by the Toxicity Characteristic
Leaching Procedure (TCLP), or a modification of this procedure if
approved by EPA, and the leachate analyzed for the Contract
Laboratory Program (CLP) Target compound List (TCL) volatiles and
semi-volatiles. The concentrations in the leachate shall not
exceed the concentrations for those parameters listed in Table 8.
The performance' of the treatment system for soils shall be
demonstrated during the remedial design of the low temperature
thermal desorption unit(s). Periodic testing during the operation
of the treatment system shall be conducted to ensure the
performance of the treatment system. The performance standards
shall bla attained for the treatment of soils to ensure that
residual leaching threats to groundwat~r from the treated soils are
eliminated.
If at an.y time, any ,contaminants are present in the treated soils
other than those above that exceed a 10(-6) cumulative lifetime
cancer risk, or MCLs 'for carcinogens, whichever is more stringent;
and MC~;, maximum contaminant level goals (MCLGs), or a hazard
index oj: 1.0, whichever is more stringent, for non carcinogens,
addi tior.tal remedial work as determined by U. S . EPA shall be
performE~d. .
Treated soils will be replaced in the areas from where they are
excavatE!d and covered with six inches of soil and seeded. The
-------
r
7&b I ~
I 0;' 3
8
DISCHARGE CRITERIA
REILLY SITE. INDlANAPOUS. INDIANA
.i
I
-!
CONTAMINENT RECHARGE
I..1MJTl.81 I
(J£g/l )
1
VolaCile O"_C Compounds
methvlene chloride S
acetone -
chloroform 100
1.:-dichJorcclhanc 5
!.bulanonc -
bromoQlchloromctnanc 100
benzene S
loluene 1000
ethvtbeD%eDc 700
10lal xylene 10.000
Pyridine Ocmatms
pyridine 3S
-------
7aJole 8
2.~ .3
CONT AMINENT RECHARGE
Lo1M",.'
V£111)
2.metbvl-+-etbvlpyridine 35\C'
Polynadar Ar'OID8UC H~rocarDons
Na.,btbalene -
. I-metbylnaDlubalene -
Metals
Aluminum -
Arsenic SO
Barium J(JOO(d)
Bervllium 1
Cadmium latd)
Chromium SO
-------
lahl~ g
3.~.f 3
CONT AMINENT RECHARGE
LIMI1'II
(}I.II1 )
Kjeldahl - mllro,en .
Nitrate. nltro,en 1
Nitra.te + nnnte 10
Phosphorus,n I 1
Calcium .
Iron'" 1
Mallnesium .
Manranese .
potassium -
sodium -
Hardness las, CaCO,) .
Chemical (»:ygen Demand .
Total Or,anlc CarbOn -
Total Suspended Solids(r) 25.30
Biological Ox.vgen Demand(r) 25.30
AIkaliniry .
pH 6.9
Specific Corllductiviry Imicromnos/cm} 1.200
Chlorides 250
Sulfates 250
TemFratur,: .
(a)
(b)
(c)
(d)
(e)
(0
(g)
Based on MCLs or otber peninant standard.
Based on Reilly's existing permit for disdWge to the Belmont P01W.
Calculated assumiDg tward index of I.
Supplied by IDEM by fax dated 916/91.
Indianapolis City Sewer Ordinance.
Qark. ViC:SSmaD and Hammer. 1977.
Supplied by EPA in teuer dated 9/16191.
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corrective Action Management Unit (CAMU) regulations allow the
replacernent of the treated soils into the units from where they
were exc:avated. The five CERCLA areas are designated in this ROD
as Corrl5!ctive Action Management units. This designation will
result i.n the treatment of contaminated soils which will result in
permanerLt reduction in the toxicity, mobility and volume of
contamination at the CERCLA areas. Absent this designation, these
areas mClY not have been treated and replaced, thus not achieving
reductic>n in the toxicity, mObility and volume of contaminants at
the si tE~.
Treatment residuals from the low temperature thermal desorption
process will be incinerated off-site, as is presented in the
FS/CMS. This will result in complete destruction of the organic
contaminants removed during the desorption process.
samples collected outside of the excavation areas at the Lime Pond
drum removal area, the Former Drainage Ditch, the Former Sludge
Treatment Pit and the Former Abandoned Railway Trench would be
tested using the already described criteria and if they fail, they
could be added to the total. However, the potential for this to
occur is low and should not significantly increase the volume
required to be excavated as a result of the hot spot delineation
cri teri,a.
The point of compliance for this action only, will be the CERCLA
Area boundaries, as is defined on Figure 3.
Future land use at the Lime Pond would be unrestricted. Because
the soils at the Lime Pond are to be treated to residential cleanup
levels, deed restrictions for this area are unnecessary.
Residential cleanup levels were selected for this portion of the
site bel=ause of the close proximity «50 feet) to residential areas
to the north of the site.
Future land use at the Former Sludge Pit, the Former Drainage
Ditch, the Former Abandoned Railway Trench, and the South
Landfill/Fire Pond would be limited to industrial use by
insti tutional controls consisting of deed restrictions. These deed
restrictions would be developed so tha~ they could not be wiped out
by rezoning efforts.
Access controls would be placed to restrict the potentially exposed
populat.ion from entering these contaminated areas and, thereby,
would prevent the associated exposures. The south Landfill is
already fenced to prevent access; however, the other CERCLA Areas
are in locations where vehicular traffic and industrial worker
eXposuI~es are not prevented. Guardrails to restrict traffic and
signs to identify potential hazards will be installed at the
Abandoned Railway Trench and the Former Drainage Ditch areas.
Fencin9 would be installed at the Former Sludge Treatment Pit.
Additicmal fencing would be installed at the Lime Pond area.
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~
Maintenance of all fences and guardrails would be required.
Summarv of the comoarative Analvsis of Alternatives for Sludae
Cleanuo
The nine cri teria used by U ..5. EPA to evaluate remedial
alternatives, as set forth in the NCP,' 40 CFR Part 300.430,
include: overall protection of human health and the environment:
compliance with applicable or relevant and appropriate requirements
(ARARs): long-term effectiveness: reduction of toxicity, mobility,
or volume: short-term effectiveness: 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 2 - In-situ Solidification as the alternative
for this operable unit remedy for this Site.
THRESHOLD CRXTERXA
Protection of Human Health and the Environment
Addresses whether a remedy provides adequate protection of human
health and the environment and describes how risks posed through
each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional controls.
Alternative 1 would not protect human health and the environment
because it does not reduce risks associated with exposure to the
contaminated sludge: however, it produces the lowest short term
risks. Alternative 3, incineration, may be the most protective
because it provides the greatest reduction in toxicity and the
greatest long term effectiveness. However, this alternative also
presents the greatest potential for short term exposures to onsite
workers and offsiteresidents. When compared to Alternative 3,
Alternative 2 provides a lower level of long term effectiveness and
will not result in a reduction in contaminant toxicity.
Alternative 2 does present significantly lower short term risks
when compared to Alternative 3. If implemented, Alternative 2
would significantly reduce site risks by preventing direct exposure
to the sludge.
Therefore, since it has been determined that Alternative 1 would
not be protective of human health and the environment, it will no
longer be considered in the nine criteria evaluation. Alternatives
2 and 3 have been determined to be functionally equivalent with
respect to this threshold criteria.
Comoliance with ARARs
Addresses whether a remedy will meet all of the ARARs of other
Federal and state environmental laws and/or justifies a waiver of
those laws.
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All of the alternatives are capable of meeting ARARs. ARARs for
Alternative 2 relate to health and safety, erosion control, and
fugitive dust emissions and are more easily met compared with
Al ternati ve 3 . ARARs for Al ternati ve 3 would be the most
restrictjlve and would include compliance with the provisions of 40
CFR Part 0, as well as other ARARs relative to the treatment,
storage, transportation and disposal of hazardous waste treatment
residuals. .
Thereforta, it has been determined that Al ternati ve 2 is
functionally equivalent to Alternative 3 with respect to this
threshold criteria, but there are cost and implementability
problems in meeting ARARs for Alternative 3.
BALANCING CRITERIA
Lona Te~n Effectiveness
Addresse:s any expected residual risk and the aDili ty of a remedy to
maintain reliaDle protection of human health and the environment
over tim,e, once cleanup standards have been met.
Alternative 3 provides the greatest long term effectiveness and
permanence, considering the ability of incineration to destroy the
organic contaminants of concern. Residual levels of organic
contaminants in sludge following incineration are expected to be
extremely low. Long term monitoring, maintenance and a five year
review (:>f the remediated site may not be necessary if this
alternative is implemented. Alternative 2 is capable of
effectively controlling site risks over the long term. However,
the in-situ solidification process would not destroy the
contaminants, they would be left in place. Long term monitoring,
maintenance and a five year review of the site would probably be
required.
Therefore, it has been determined that Alternative 3 is slightly
better t:han Alternative 2 with respect to this balancing criterion.
Reduction of Toxicitv, Mobilitv or Volume
Addresse,s the anticipated performance of the treatment technologies
a remedy may employ.
Al ternat,i ve 3 provides the greatest reduction in toxicity, mobility
and volume and would result in permanent destruction of the
contaminants. Alternative 2 will not reduce the toxicity or volume
of cont;aminants. It would also be effective at reducing the
mobility of contaminants by reducing groundwater infiltration,
erosion, and airborne dust, although these reductions would not be
achieved through treatment.
Therefore, it has been determined that Alternative 3 is superior to
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Alternative 2 with respect to this balancing criterion.
Short Term Effectiveness
Addresses the period of time needed to achieve protection and any
neqative effects on human health and the environment that may be
posed during the construction and implementation period, until
cleanup standards are achieved.
Alternative 2 results in slightly higher short term exposures over
no action as a result of workers being involved in the
solidification process and other activities at the Fire Pond.
Exposures to onsite and offsite receptors would be minimized by air
emission controls on the solidification process, such as a
cylindrical hood over the working area to capture air emissions,
and the use of dust suppressants during material handling. The
estimated time required to complete Alternative 2 is 6 weeks.
Alternative 3 results in significantly higher short term exposures
when compared to Alternative 2. Excavation of contaminated sludge
will release volatile and semi-volatile chemicals to the air.
Contaminants may also be released to the air on dust particles.
Contaminants released to the air may impact onsite workers as well
as the surrounding community. Addi tional short term exposures
after excavation may result if the off-gas treatment equipment
fails during operation. With proper maintenance and monitoring,
the likelihood of equipment failure resulting in a significant
release is low. The estimated time to complete Alternative 3 is 31
weeks.
Therefore, it has been determined that Alternative 2 is superior to
Alternative 3 with respect to this balancing criterion.
ImDlementabilitv
Addresses the technical and administrative feasibility of a remedy,
includinq the availability of materials and services needed for a
particular option to be put in place.
Alternative 2 is expected to be easy to implement. The necessary
materials, equipment, and specialists are readily available.
Debris in the Fire Pond could prevent advancement of the augurs and
increase the difficulty of completing the in-situ solidification.
Pilot tests to assure the success of Alternative 2 would be
required. Alternative 3 would be the most difficult to implement.
Bench and pilot scale tests are required to establish treatment
parameters. Permits to operate may have to be obtained. Offsite
disposal of hazardous waste residuals might have to be arranged.
A significant amount of monitoring would be required, but the
necessary technologies, specialists, and equipment are readily
available.
Therefore, it has been determined that Alternative 2 is superior to
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Alternative 3 with respect to this balancing criterion.
,
"
cost
Included are capital costs, annual operation and maintenance costs
(assuminq a 30 year time period), and net present value of capital
and oper~~tion and maintenance costs. The selected remedy must be
cost efft!ctive.
Alternative 2 has a present worth cost of $800,000 (includes
solidifit::ation and soil cover for the Fire Pond) and Alternative 3
has a prl~sent worth cost of $8,600,000.
MODIFYING CRITERIA
state Acceotance
Addresses whether or not the state agency agrees to or objects to
any of the remedial alternatives, and considers state ARARs.
The Indi.ana Department of Environmental Management (IDEM) has been
intimately involved with the site throughout the RIfFS, has
attended all technical progress meetings, has been provided
opportunity to comment on technical decisions, and concurs with the
selection of Alternative 2 as the selected remedy for this operable
unit sludge cleanup at.the Site.
community Acceotance
Addresses the public' sgeneral
alternatives and proposed plan.
response
to
the
remedial
Throughe,ut the RIfFS 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, those in
attendal'1lce, as well as those who submitted written comments
regardir.lg the proposed plan, were in favor of Alternative 2 as the
most appropriate choice for the sludge' cleanup.
In summation, Alternative 1 is unacceptable for protection of human
health and the environment. Alternative 3 is superior to
Alternat:ive 2 with respect to long term effectiveness and
permanence and reduction of toxicity, mobility and volume through
treatment. Alternative 2 is superior to Alternative 3 with respect
to shclrt term effectiveness, implementability and cost
effectiveness. Because the alternative selected for sludge cleanup
at the Fire Pond will be combined with the alternative selected for
soil clt~anup at the South Landfill - Soil Cover, the long term
effectiveness of Alternative will be increased. Therefore, the
best balance among the three alternatives is Alternative 2 - In-
Situ solidification.
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Selected Remedv for South Landfill/Fire Pond Sludae CleanuD
As was discussed in the previous section, EPA has selected
Alternative 2 - In-Situ Solidification as the appropriate sludge
cleanup remedy for the South Landfill/Fire Pond at the Reilly Tar
and Chemical site. This alternative was selected because it is the
most appropriate alternative for this operable unit action and is
compatible with the final remedial alternatives anticipated for the
Site, which will mainly encompass source-area remediation.
The FS contains a description of this alternative. The Fire Pond
sludge requires treatment to provide a stable foundation for
application of a cover, and to prevent the sludge from seeping
through or around a cover. Bench-scale treatability tests were
recently completed and indicate that the sludge can be effectiyely., ;
solidified using several different types of reagents and mixing
ratios. The treatment produces an increase of approximately 25-30%
in volume of the treated sludge, depending on the moisture and
reagent contents.
Treatment of the Fire Pond sludge in-place could be accomplished by
a method referred to as Shallow Soil Mixing (SSM). SSM can operate
over depths from 0-30 feet in contaminated' soils and sludges.
Sludge must be treated to a maximum depth of less than 30 feet in
the Fire Pond. SSM utilizes a crane-mounted drill attachment which
turns a single-shaft, large-diameter augur that consists of two or
more cutting edges and mixing blades. The single mixing augur, up
to 12 feet in diameter, is driven by a high-torque turntable. the
mixing head is enclosed in a specially designed cylindrical hood
which allows for the capture of air emissions from the mixing
operation. Air emissions would be treated by carbon adsorption to
remove organic contaminants.
As the augur head is advanced into the sludge, grout is injected
into the sludge at the pilot bit. The cutting edges and mixing
blades blend the sludge and grout in-place with a shearing action.
When the design depth is reached, the augur is raised to expose the
mixing blades at the surface and then readvanced to the bottom
depth to provide the necessary blending. As the augur blends the
reagents and sludge, it creates a cylindrical column of treated
material. Field tests would be required to verify that SSM is
effective and implementable in the viscous Fire Pond sludge.
The SSM construction method consists of creating primary
alternating columns which are allowed to set. A series of
secondary columns are then installed which overlap the primary
columns resulting in a continuous treatment of the sludge over the
entire depth.
It is unlikely that the sludge in the Fire Pond would support the
weight of the crane used for SSM. As a result, treatment of the
sludge would have to be carefully staged. Treatment would progress
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q
u
inward from the edge of the Fire pond, in a series of concentric
rings or rows. Sludge at the edges of the Fire Pond would be
treated first. After the treated mass cured and could support the
weight of a crane, the treatment unit would be moved out onto the
edge of 'the Fire Pond and the next concentric ring of sludge
treated. Treatment would progress in this fashion until the entire
Fire Pond was solidified. The presence of large debris such as
drums or :~ailroad ties may require the use of excavating equipment
to remove the obstructions.
The Fire pond sludge is a RCRA characteristic waste, characteristic
for corrosivity. Solidification shall be performed on the sludge
and shall result in a solidified mass that no longer exhibits RCRA
characteristics. The solidified mass shall be tested using the
TCLP tes1: to determine if it is still RCRA characteristic for
corrosivity. If the sludge still exhibits RCRA characteristics,
then the cover material for the Fire Pond will be Alternative 4 -
Multi Layer Cover. If the sludge no longer exhibits RCRA
characteI'istics, then Alternative 2 - Soil Cover will be used for
the cover material for the Fire Pond. Different solidification
methods shall be investigated in a treatability study and one that
results in a non-RCRA characteristic waste shall be preferred.
The poin1: of compliance for this action only, will be the South
Landfill boundary, as is defined on Figure 3.
DocumentzLtion of Sianificant Chanaes
EPA published a proposed plan for this operable unit action on July
22, 1993, that selected Alternative 3 Groundwater
Extractic)I1/Treatment/Discharge for groundwater cleanup at the
follo¥in~~~th.re~c;:'BROLA'OAreas: the Lime Pond drum removal area, the
Former Sludge Treatment Pit, and the Abandoned Railway Trench.
This selection was based on data collected during supplemental
field investigations conducted pursuant to the Amended
AdministJ:ati ve order on Consent. These investigations indicated
that these three CERCLA Areas were contributing to the groundwater
contamination problem at the site and that by addressing them, the
performance of the groundwater extraction/treatment/discharge
system sE!lected in the ROD for the first operable unit at the site
could be maximized.
However, during the public comment period, it was brought to the
attention of EPA that the design of the first operable unit remedy,
which is: currently underway, would preclude the need for this
addi tion,al source control component for groundwater. It appears
that the design will encompass some extraction in areas of the site
that will maximize the performance of the system, while also
including some source control in the design. Therefore, it has
been determined by U.S. EPA that the groundwater component of the
remedies called for in the proposed plan are not necessary at this
time and that the ongoing remedial design will accomplish the
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objectives as set forth in the proposed plan.
STATUTORY DETERKINATIONS
u.s. EPA's primary responsibility at Superfund Sites is to
undertake remedial actions that protect human heal th and the
environment. Section .121 of CERCLA has established several other
statutory requirements and preferences. These include the
requirement that the selected remedy, when completed, must comply
with all applicable, relevant and appropriate requirements
("ARARs") imposed by Federal and State environmental laws, unless
the invocation of a waiver is justified. The selected remedy must
also provide overall effectiveness appropriate to its cpsts, and
use permanent solutions and alternative treatment technolagie!S, .or. .
resource recovery technologies, to the max~mum extent ~acticab~e. .
Finally, the statute establispes a pre.fer~ncefor remedies which
employ treatment that significantly reduces the toxicity, mobility
or volume af contaminants.
The selected remedy will satisfy the statutory requirements
established in Section 121 of CERCLA, as amended by SARA, to
protect human health and the environment, will comply with ARARs
(or provide grounds for invoking a waiver), will provide overall
effectiveness appropriate to its costs, and will use permanent
solutions and alternate treatment technologies to the maximum
extent practicable. The statutory preference for treatment is
satisfied by that component of the selected remedy which requires
treatment to remove hazardous substances from contaminated soils
and further requires that those substances be destroyed through
whatever method of final disposal is chosen for the treatment
residuals. Furthermore, that component of the selected remedy
which requires stabilization of the sludges will also satisfy the
statutory preference for treatment as the stabilization process is
expected to reduce the mobility of hazardous substances in the
sludges while it is also expected that the process of stabilization
may effectively render the sludges (currently characteristic wastes
under RCRA) non-hazardous because the stabilized sludges may no
longer exhibit the characteristic of corrosivity.
1.
protection of Human Health and the Environment
Implementation of the selected remedy will protect human health and
the environment by reducing the risk of direct exposure to
hazardous substances present in surface and subsurface soils and
sludges at the site: the selected remedy will further protect human
health and the environment by removing and destroying, or
immobilizing sources of hazardous substances which have been
identified as contributors to groundwater contamination at the
site.
Adequate final covers for the source areas which are the subject of
the selected remedy will reduce or eliminate any remaining risk of
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a
"
exposure to hazardous substances present in soil and sludges at the
site, and will also reduce the rate of infiltration by which
precipi tat:ion passes through any residual contamination.
Instituticmal controls will also be imposed to restrict uses of the
site to prevent exposure to any hazardous substances and
contaminants in the soil and sludges. No unacceptable short-term
risks will be caused by implementation of the remedy. Mitigative
measures 'will be taken during remedy construction activities to
minimize impacts of remedy implementation upon the surrounding
community and environment. Ambient air monitoring will be
conducted and appropriate safety measures will be taken during
remedy implementation.
2.
compliance with ARARs
The selec'ted remedy will comply with all identified applicable or
relevant and appropriate federal requirements, and with those state
requirements which are more stringent, unless a waiver is invoked
pursuant to section 121(d)(4)(B) of CERCLA. The ARARs for the
selected remedy are listed below:
A.
Federal ARARs
Chemiea1-s~ecifie Reauirements
Chemical-specific ARARs regulate the release to the environment of
specific substances having certain chemical characteristics.
chemical-'specific ARARs typically determine the standard for clean-
up at a s:ite.
Resclurce conservation and Recoverv Act (RCRA)
Although the RCRA hazardous waste in the source areas addressed by
this remE!dy was placed in those units before the effective date of
the requirements established by RCRA's implementing regulations,
the facility is an operating RCRA facility engaged in the
management of hazardous wastes: therefore, the RCRA statute and its
implemen1:ing regulations are applicable for purposes of Corrective
Action. As the soils and sludges at the source areas which are the
subject Clf the selected remedy are highlY contaminated by hazardous
substancli!s similar to RCRA hazardous substances which have been
demonstrated to be contributing sources to groundwater
contamination, the chemical-specific requirements of RCRA are also
relevant and appropriate. 40 CFR 141 requires that ground water
used as drinking water meet Maximum contaminant Levels (IIMCLs") for
contamin.:mts of concern. '
Saf,e Drinkina Water Act
40 CFR 141
Federal
Drinking
Water
standards
promulgated
under
the
Safe
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Drinking Water Act ("SDWAtt) include both Maximum Contaminant Levels
( "MCLs ") and, to a certain extent, non-zero Maximum Contaminant
Level Goals ("MCLGs"), that are applicable to municipal drinking
water supplies servicing 25 or more people. At the Reilly Site,
MCLs and MCLGs are not applicable, but are relevan~ and
appropriate, because the unconfined aquifer below the site is a
Class II aquifer which has been used in the past by residences
bordering the site, and could potentially be used in the future as
a drinking water source.
The National Contingency Plan <"NcPtt) at 40 CFR 300.430 (e) (2) (i)
(8) provides that MCLGs est~blished under the Safe Drinking Water
Act that are set at levels above zero, shall be attained by
remedial actions for ground waters that are current or potential
sources of drinking water. The point of compliance for federal
drinking water standards is at the boundary of the
solidified/stabilized waste, because this is the point where humans
could potentially be exposed to contaminated groundwater. Because
the source areas addressed by this action will have final covers,
the points of compliance for each unit addressed will be at the
boundary of the final covers. Ground water monitoring wells may be
installed at the points of compliance to ensure that the
contribution to groundwater contamination from these source areas
has ceased. Existing ground water wells in the aquifer will also
be monitored, and additional wells may be drilled and monitored, if
necessary.
Location-SDecific Reauirements
Location-specific ARARs are those requirements that derive from the
physical nature of the site's location and features of the local
geology and hydrogeology such as wetlands and floodplains.
The physical nature of the site's location does not implicate
additional Applicable or Relevant and Appropriate regulations
beyond those already identified as specific to the chemical
composition of the hazardous substances addressed and those
specific to the action required by the selected remedy.
Action~SDecific Reauirements
Resource conservation and Recoverv Act ("RCRA")
The Resource Conservation and Recovery Act (RCRA) is applicable at
this entire site because the site is an operating RCRA facility.
Contaminated soils and sludges at the source areas which will be
addressed by the selected remedy are characteristic RCRA wastes,
either because they exhibit the characteristic of corrosivity, or
because they exhibit the characteristic of toxicity when tested
using the Toxicity Characteristic Leaching Procedure (TCLP).
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For Low Temperature Thermal Desorption
c
"
The selec'ted remedy of excavation and treatment of contaminated
soils at the Lime Pond Drum Removal Area, the Abandoned Railway
Trench, the Former Sludge Treatment Pit, and the Former Drainage
Ditch will require compliance with action-specific ARARs related to
excavatio]~ as well as those specific to the treatment technology.
As the se1ected remedy requires that the treated soils be replaced
in the units after treatment which achieves Risk Based Target
Cleanup Levels (RBTCLs) (to residential levels in the case of the
soils from the Lime Pond Drum Removal Area, to industrial levels in
the case of soils from the other three source areas), the Land
Disposal Restrictions of 40 CFR Part 268 are applicable to this
specific component of the selected remedy.
However, the recently promulgated final regulation regarding the
designation of Corrective Action Management units (CAMUs) allows
the Agenc:y to designate these four source areas as CAMUs. This
designation will allow the treated soil to be replaced in these
units without violation of the Land Disposal Restrictions. u.S.
EPA find:; that this designation of these units as CAMUs will
further t,he goals of the CERCLA statute by allowing for reduction
of toxicity through treatment in a cost effective manner. Without
this designation it might not be possible to achieve this goal.
Accordin9ly, the Lime Pond Drum Removal Area, the Abandoned Railway
Trench, t:he Former Sludge Treatment Pit, and the Former Drainage
Ditch, are hereby designated as CAMUs for the purpose of receiving
those renlediation wastes which consist of soils treated to comply
with the relevant RBTCL, as specified elsewhere in the Scope of
Work whic:h accompanies this Record of Decision. Those remediation
wastes which consist of hazardous substances removed from soils
through 1~he treatment process are required to be disposed of by
thermal destruction.
As the ~~elected remedy requires that the hazardous substances
removed from soils by treatment be destroyed through incineration,
the regulatory standards applicable to the generation, storage,
transpor1: and disposal of hazardous waste are all applicable.
These inc::lude the regulations specified below:
40 CFR Pi:irt 261: Identification and Listing of Hazardous Waste:
40 CFR Part 262: Standards Applicable to Generators of Hazardous
Waste:
40
CFR
Part
263: Standards Applicable
Hazardous Waste:
to
Transporters
of
40 CFR Part 264: standards Applicable to Owners and Operators of
Hazardous Waste Treatment, storage and Disposal
Facilities.
The Low 'femperature Thermal Desorption treatment units must comply
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with the standards set forth at 40 CFR 264, Subpart X-Miscellaneous
Units.
For Stabilization of Sludaes
The regulations applicable for excavation, and for particulate
emissions resulting from such activity which have been set forth
already elsewhere in this section will also be applicable to the
stabilization component of the remedy selected for the South
Landfill.
For Final Cover Comconents
The RCRA requirements related to the installation of final covers
will be applicable for the installation of final covers for the
source areas addressed in this Record of Decision. These
requirements include, but are not necessarily limited to, the.
regulations specified below:
40 CFR 264.310
This regulation requires the installation of a final cover to
provide long-term minimization of infiltration. This regulation
also requires 30-year post-closure care and ground-water
monitoring. The Regional Administrator may revise the length of
post-closure care period pursuant to 40 CFR 264.117(a) (2) (i) if he
finds that a reduced period is sufficient to proteqt human health
and the environment; or extend the length of the post-closure care
period pursuant to 40 CFR 264.117(a) (2) (ii) if he finds that the
extended period is necessary to protect human health and the
environment.
Although the RCRA hazardous waste in this landfill was placed
before the effective date of the requirements, the facility is an
operating RCRA facility engaged in the management of hazardous
wastes and the RCRA statute and its implementing regulations are
applicable for purposes of Corrective Action. The regulation cited
above establishes standards for the final cover and requires
compliance with the regulations which govern post closure care set
forth at 40 CFR 264.117-120.
Post Closure Care
40 CFR 264.117(a) (1)
The requirements for post closure care set forth at 40 CFR 262.117
through 264.120 are appropriate at this site because of the
presence of hazardous substances similar to RCRA hazardous wastes.
This includes the requirement for maintenance and monitoring of the
waste containment systems for thirty years.
40 CFR 264.117(c)
,
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46
In addition, the potential for air emissions from the Low
Temperature Thermal Desorption treatment process will be monitored.
If any air emissions were to result from these treatment units they
may become subject to the National Emissions Standards for
Hazardous Air Pollutants.
"
v
B.
State A~s
Identification of State of Indiana ARARs for the Remedial Action
Addressina the CERCLA Source Areas at the Reillv Tar & Chemical
Sucerfund Site
The FS identified the following statutory sections and regulations
promulgated for the management of hazardous waste as ARARs for the
site and for the specific actions represented by the components of
the selected remedy.
329 IAC Article 3.1, Rules 1, 4, 6.
329 IAC Article 3.1, Rule 9.
329 IAC Article 3.1, Rule 7.
329 IAC Article 3.1, Rule 8.
Indiana Code Sections 8-2.1-18-36:
Materials.
Transportation of Hazardous
329 IAC Article 3.1, Rule 12.
325 IAC Article 8
326 IAC Article 2-1: Permit Review RUles2 (for construction and use
of LTTD treatment units)
326 IAC Article 5-1 (opacity Standards)
326 lAC: Article 6-4, 6-5 Fugitive Dust Emissions Standards.
327 IAC Article 15, RuleS: Storm Water Run-off Associated with
Construction.
327 IAC Article 15, Rule 6: stormwater Discharge Associated with
Industrial Activity
2 The CERCLA statute does not require compliance with the
procedural requirements of permit regulations, and permits need
not be obtained for actions implemented on-site; however,
compliance with the substantive requirements of such regulations
is required.
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Q
C.
To Be considered
c
(,
The propos.ed rule for National Emission Standards for Hazardous Air
Pollutant!~ for Source categories: organic Hazardous Air Pollutants
from the synthetic organic Chemical Manufacturing Industry, 53 Fed.
Reg. 11667 (February 26, 1993) is to be considered at this site in
connection with the potential for the emission of hazardous organic
air pollutants fron the Low Temperature Thermal Desorption
treatment units.
3.
Cost Effectiveness
Cost effe<::tiveness compares the effectiveness of an alternative in
proportiolr1 to its cost of providing environmental benefits. Table
9 lists the costs associated with the implementation of the
remedies.
The selected remedies for this site are cost effective because they
provide the greatest overall effectiveness proportionate to their
costs when compared to the other alternatives evaluated, the net
present wc:>rth being $6,000,000. The estimated cost of the selected
remedy is, reasonable when compared with the other al ternati ves
considered, and it assures a high degree of certainty that the
remedy will be effective in the long-term, due to the significant
reduction of the toxicity, mObility and volume of the contaminants
achieved through treatment of the source material and the
destruction of hazardous substances removed by the treatment
process.
4. utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable
The sele,cted remedy represents the maximum extent. to which
permanent solutions and treatment technologies can be used in a
cost-effective manner at this site. Of those alternatives that are
protective of human health and the environment and that comply with
ARARs, u.s. EPA has determined that the selected remedy provides
the best balance in terms of long-term effectiveness and
permanence, reduction of toxicity" mobility, or volume of
contaminants, short term effectiveness, implementability, and cost,
taking into consideration state and community acceptance.
The excavation and treatment through Low Temperature Thermal
Desorption of soils contaminated by hazardous substances with these
soils being replaced in the units following treatment to risk-based
levels: t:he stabilization of sludges at the South Landfill: the
imposition of final covers at all five CERCLA source areas
addressed by this remedy: together with restrictions to access at
all of these areas including but not limited to institutional
controls: will provide the most permanent solution practical,
proportic1nate to the cost. .
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-<:
a
TABLE 4.5-7
Comparallve Analysis - Soli and Sludge
Cosl Effecllveneaa (Eallmaled Tolal Presenl Wor1h)
Altern-live ~ --roo",,,,-,,,,--,,--,,,,,,---, .,. I
Alltmallv. to Alt8m.llv... Low.Temperllu,.
~~t AI""" a. Ae...-... ~ 1IuftI.I-rw Alhlmillve 5 TtMwmIll All
8WIIU No AooM' :.. eo- CIww Cov., SIu,,! Blorem8dlallon D"orpUon
n' ..-.-..---- ,. .....-
Ume Pond '250,000 Nol applicable. Asphall '250.000 $300.000 $ 18.000.000 ~ $10.000.000 . $1:1.000
Cone..le '260,000
--- -_. -- --. - . --- ..-
Abandoned '100.000 Nol applicable. Asphall . I 50,000 Nol applicable. 15.500.000 . 14.400.000"" S!t."OO.
Railroad Cone..le . 150,000
T..nch
- . _. ------ ----- ..
Fonne, Sludge '90,000 Nol lIppIicllble. Asphall $80,000 Nol applICable .1.000.000 .. $790,000 . 11700.
T..almenl Pit Cone.... '110,000
. - d- ----.-.-.
Fonner '1110,000 $61,000 Asphall . 1 7.0,000 Nol applicable $2,100.000 + $1.600.000 * 12.100.
O,all1898 Ditch Conc"Ie . 170.000
-------- -- -------'- .. ..".
Sou" Landlil $290.000 '1.700.000 Not applicable. Nol applICable 119.000.000 112.000.000 $15000
(ind'" Fi.. (ind'" In,."
Pond) .llIbilil.llon of
Fi.. Pond
Sludge)
..'--. .- _. - . ..
Fi.. Pond $800,000 lor Fir. Nol applicable. Nol applicable. Nol applicable. Nol apphcdblo 18.bOO.
Pond alone
.G~ 8ftOI.~.. ~ .. ,.oI1neIucW In ~~ 01 c:oYM. ~ Pl'8Ant wo'" 0011. IQ, emuaJ moniloring would be:
800II LtndiIlFn PDN $170,000
""'* DtIIInegt Did . .IIO.GOD
.. Pond . . 82ID,ooo
Ab8ndoIMcI RaiIDltd T"" . 80,000
Former 8btgt TlNInIent fill . 80,000
0"_-_--___0____-
emallv.'
1nc1n..lIon
---_.
000 ~
. -.... -
oou
...
000
-#.
000
,r
.0110
000
----..---..... .
. 5e~ Sf-c:frtn'tSOr. 1101 S,vI- D~/,"'~.h.N 4t1d. SOl I CI~dt1up
~r -fLNh,r r."'t1.nw.l11- o~ -Mol ~c cos+s c1~ -#a~y r~ II ~ -Iu
'.ho+ ~of cl,~tJ tJp
-
QI
(J
....
1\
..J
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48
'"
5.
Preference for Treatment as a principal Element
The statutory preference for selection of remedial actions in which
treatment is a principal element is satisfied by the selection of
Alternative 6 for soil cleanup and Alternative 2 for sludge
cleanup. This operable unit action will permanently reduce the
toxicity, mobility and volume of contamination at the five CERCLA
areas through treatment of the soils and solidification of the Fire
Pond sludge. These remedies, coupled with the groundwater
extraction/treatment/discharge system selected for operable unit 1,
will reduce risks at the site through treatment of principal
threats at the site. Future operable unit remedial actions will
address other principal threats at the site.
" u
EPA and IDEM believe that the selected remedies satisfy 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 to the
maximum extent practicable.
T
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