EPA Superfund
Record of Decision:
Continental Steel Corp.
Kokomo, IN
9/30/1998
PB98-964104
EPA 541-R98-091
November 1998
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Continental Steel Superfund Site, Kokomo, Howard County, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for management of migration, operable unit
1, and source control, operable units 2-6, at the Continental Steel Superfund Site in Kokomo, Howard
County, Indiana. The selected remedial action was chosen by the Indiana Department of Environmental
Management (IDEM) in accordance with the Indiana State Cleanup Law, Indiana Code 13-25-4 et. seq.,
the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and is consistent
with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to the extent
practicable. This decision is based upon the contents of the Administrative Record for the site.
This decision document also serves as the United States Environmental Protection Agency's (U.S. EPA)
concurrence with and adoption of the remedial action decision for the Continental Steel Superfund Site.
as approved by IDEM, and pursuant to sections 104(d) of CERCLA, SARA, and to the extent
practicable, the NCP. IDEM has provided U.S. EPA with documentation to demonstrate that the State's
selection of remedy for the site conforms with the requirements of CERCLA, the NCP to the extent
practicable, and Cooperative Agreement V005072-01-7 between U.S. EPA and IDEM.
ASSESSMENT OF THE SELECTED REMEDY
Actual or threatened releases of hazardous substances from the site, if not addressed by implementing the
response action selected in this Record of Decision (ROD), may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
There are six operable units associated with the Continental Steel Superfund Site (CSSS). The operable
units consist of the Site-Wide Groundwater (OU-1), Wastewater Lagoon Treatment Area (OU-2),
Kokomo and Wildcat creeks (OU-3), Markland Avenue Quarry (OU-4), Main Plant Property (OU-5), and
the Slag Processing Area (OU-6). Each operable unit has a selected remedy, and together, these remedies
comprise the final remedial action. The final remedial action addresses soil and groundwater
contamination detected during the remedial investigation and several emergency removal actions. The
final remedial action addresses the management of migration for groundwater and source control for
solid media with the goal of minimization of exposure threats to human health and the environment.
The remedies which comprise in the final remedial action decision are highlighted below by operable
unit.
For OU-1 (Side-Wide Groundwater), Alternative MM-5 has been selected and consists of:
» Collect Intermediate and Lower Groundwater at Martin Marietta Quarry to Contain
Contaminated Groundwater within Current Boundaries
> Dispose of Collected Groundwater Off-Site at City of Kokomo Wastewater Treatment
Plant (WWTP)
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Continental Steel Superfund Site
ROD Declaration
Page 2 of 4
•• Invoke Technical Impracticability (TI) Waiver for the Intermediate and Lower
Groundwater due to no active treatment and over 200 years to attain ARARs through
Natural Attenuation
» Collect Shallow Groundwater and Dispose Off-site at WWTP
» Monitor Groundwater until ARARs are attained.
•• Groundwater Use Restrictions
* 30-Yr. Net Present'Worth Cost: $6,386,000
For OU-2 (Lagoon Area), Alternative" SCr4L has been selected and consists of:
» Excavate Contaminated Solids and Consolidate On-Site
•• Collect and Contain Shallow Groundwater with Expanded Interception Trench System
and Dispose Off-Site at Kokomo WWTP
»• RCRA Surface Impoundment Closure
•• Deed & Groundwater Use Restrictions
•• 30-Yr. Net Present Worth Cost: $44,746,000
For OU-3 (Wildcat & Kokomo creeks), Alternative SC-4C has been selected and consists of:
» Excavate Contaminated Sediment and Consolidate in On-Site CAMU/Landfill
30-Yr. Net Present Worth Cost: $ 12,560,000
For OU-4 (Markland Avenue Quarry), Alternative SC-2.5Q has been selected and consists of:
» Excavate Contaminated Sediment from Quarry Pond
»• Backfill Quarry Pond
*• Dispose of Quarry Sediment in Lagoon Area CAMU/Landfill
» Cover Contaminated Solids with Common Soil and vegetate
> Contain & Collect Shallow Groundwater & Dispose at WWTP
»• Deed & Groundwater Use Restrictions
30-Yr. Net Present Worth Cost: $11,163,000
For OU-5 (Main Plant Property), Alternative SC-3.5M has been selected and consists of:
» Elevated VOC Solids Removal and On-Site Disposal in CAMU/Landfill
> Excavate PCB Solids along Kokomo Creek and Dispose On-Site in CAMU/Landfill
> Install Common Soil Cover and vegetate
> Collect & Contain Shallow Groundwater and Dispose Off-Site at WWTP
* Deed & Groundwater Use Restrictions
30-Yr. Net Present Worth Cost: $7,747,000
For OU-6 (Slag Processing Area), Alternative SC-3.5S has been selected and consists of:
" Regrade Slag Piles to Level Site
> Install Protective Common Soil Cover Over Contaminated Solids and vegetate
» Deed Restrictions
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Continental Steel Superfund Site
ROD Declaration
Page 3 of 4
Stabilize Creek Bank
30-Yr. Net Present Worth Cost: $2,420,000
DECLARATION STATEMENT
The selected remedies are: protective of human health and the environment; comply with Federal and
State requirements that are legally applicable or relevant and appropriate to the remedial action except
for groundwater cleanup standards for the Intermediate and Lower Aquifers, where a technical
impracticability waiver has been granted by U.S. EPA; and, are cost-effective.
This remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable for the site. Treatment of the principal threats of the site have been proven to be
impracticable, except for shallow groundwater, therefore this remedy does not satisfy the statutory
preference for treatment as a principal element of the remedy. However, despite the impracticability,
extracted contaminated groundwater, particularly those collected from the intermediate and lower
aquifers for the containment portion of the remedy, will be treated. There is also a potential for some
treatment of some of the soils and sediments, however, the overall size and volume of contaminated solid
media and the fact there are no identified on-site hot spots that represent major sources of contamination
preclude a remedy in which contaminants could be excavated and treated effectively.
Because hazardous substances will remain at the site above health-based levels, IDEM will conduct a
five-year review in accordance with Section 121 of CERCLA to assess whether any other response is
necessary and to ensure that the remedies continue to provide adequate protection of human health and
the environment.
Based upon the information described above, and in the exercise of the State's authority under an
agreement with the U.S. EPA and IDEM pursuant to Section 104(d) of CERCLA, IDEM has developed
and presents the final decision for implementation of these final remedies. IDEM also seeks approval of
the final decision of the selected remedies for the CSSS.
JoUn M. Hamilton, Commissioner DATE
Inttfana Department of Environmental Management
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Continental Steel Superfund Site
ROD Declaration
Page 4 of
Based upon the information described above, U.S. EPA concurs with the decision IDEM has made in the
exercise of the State's authority in selecting these remedies under an agreement between U.S. EPA and
IDEM pursuant to Section 104(d) of CERCLA for implementation of the remedies.
William E. Muno, Superfund Division Director
U.S. Environmental Protection Agency, Region V
DATE
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SUMMARY FOR THE RECORD OF DECISION
I. Site Name, Location, and Description
The Continental Steel Superfund Site (CSSS) is an uncontrolled hazardous waste site located in Kokomo,
Indiana. The Indiana Department of Environmental Management (IDEM) is the lead agency responsible
for conducting the Remedial Investigation and Feasibility Study (RI/FS) at the site under a cooperative
agreement with the United States Environmental Protection Agency (U.S. EPA) in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), or
commonly known as Superfund.
The Continental Steel Superfund Site (CSSS) is located on West Markland Avenue in the City of Kokomo,
Township 23 North, Range 3 East, and Township 24 North, Range 3 East, of Howard County, Indiana. •
The total site encompasses approximately 183 acres and consists of an abandoned steel manufacturing
facility (Main Plant), pickling liquor treatment lagoons (Lagoon Area), a former waste disposal area
(Markland Avenue Quarry), and a former waste disposal and slag processing area (Slag Processing Area).
The site is located in a mixed residential, commercial, and industrial area and is mainly zoned for general
use. Residential properties lie mostly to the east and southeast of the site. Mixed residential and industrial
areas lie to the north and west, and industrial properties are located to the south. The closest residents to
the plant are located within 100 feet east of the site, near the property fence line along South Leeds Street,
and south of the Main Plant across Kokomo Creek. Highland Park, a public recreation area for area
residents, lies to the south of the Main Plant just across Kokomo Creek and immediately adjacent to the
CSSS property south of Kokomo Creek.
CSSS is in the Upper Wabash River basin. Kokomo and Wildcat Creeks flow westward through the site to
the Wabash River. The confluence of Wildcat Creek and Kokomo Creeks is located southwest of the Main
Plant. Howard county is located on the Tipton Till Plain, a nearly flat glacial till plain that slopes gently to
the west at a slope of less than one percent. The till plain is underlain by ground moraine and ablation tills.
The plain is covered by surficial drift deposits from melting ice, streams, and ice-dammed lakes. Buried
deposits of sand and gravel interspersed within the till plain are thicker and more extensive than valley-
train and alluvial deposits near the ground surface. Glacial drift deposits in the vicinity of the site range in
thickness from zero feet in quarries along Wildcat Creek to more than 200 feet in buried valleys that were
eroded in the underlying bedrock. Glacial drift deposits underlying the site are generally less than 20 feet
in thickness. Paleozoic bedrock underlies the glacial drift deposits. Bedrock structure is dominated by the
Cincinnati Arch in this area of the state. The axis of the Cincinnati Arch plunges to the northwest, at a
slope of 4 to 13 feet per mile. The site is located near the axis of the Cincinnati Arch, although bedrock
units in the vicinity of the site dip slightly southwest from the axis of the arch.
II. Site History and Enforcement Activities
The Continental Steel Corporation was founded as the Kokomo Fence Machine Company in 1896. In
1899, the Kokomo Fence Machine Company was consolidated with other interests to form the Kokomo
Nail & Wire Company. In 1900, the company was reorganized under the name of the Kokomo Steel &
Wire Company. Two 75-ton open-hearth furnaces were erected in 1914, and a third open-hearth furnace
was placed in service in 1917. In 1927, the Kokomo Steel & Wire Company merged with two other steel
companies to form the Continental Steel Corporation. By 1947, the other two steel companies were
divested, and the Continental Steel Corporation manufacturing facilities were centered in Kokomo.
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In 1969, the Continental Steel Corporation was acquired by New York-based Penn-Dixie Industries, Inc.,
which officially dropped the Continental Steel name for the Kokomo facility in 1974. Penn-Dixie
Industries, Inc. filed for Chapter 11 reorganization bankruptcy in 1980, and emerged from bankruptcy in
1982 as the reorganized Continental Steel Corporation. The main offices were then moved from New
York to Kokomo. Continental Steel Corporation filed for Chapter 11 bankruptcy in 1985. The facility
closed in February 1986 when the bankruptcy filing was converted to Chapter 7 liquidation. The Main
Plant has a covenant on the deed which restricts development to industrial use only.
Throughout its history, the plant produced nails, wire, and wire fence from scrap metal. Operations
included reheating, casting, rolling, drawing, pickling, annealing, hot-dip galvanizing, tinning, and oil
tempering. The steel manufacturing operations at the plant included the use, handling, storage and
disposal of hazardous materials. This section describes these materials and the components of the CSSS
called operable units (OUs). The six OUs include (see Appendix A, Figure A):
OU1 Site-Wide Groundwater;
OU2 Lagoon Area;
OU3 Kokomo and Wildcat Creeks;
OU4 Markland Avenue Quarry;
OUS Main Plant; and
OU6 Slag Processing Area.
The first phase of the 1993 Remedial Investigation generated a significant amount of information about the
nature and extent of contamination at the site. In addition, data is available from testing conducted during
emergency response actions and other miscellaneous sources. Details of the prior studies and activities at
the site can be found in the Focused RI/FS Work Plan.
Phase II of the RI was conducted in 1995. This phase of the RI addressed the Markland Avenue Quarry,
the Main Plant, and the Slag Processing Area and generated information to address data gaps for the site-
wide groundwater, the Lagoon Area, and the Wildcat and Kokomo creeks.
During June 1996, the Indiana State Department of Health (ISDH) performed environmental radiation
surveys in the Slag Processing Area, Lagoon Area, and the former laboratory area in the Main Plant. They
concluded that there is no evidence of gross radiological contamination in the areas surveyed. However,
ISDH recommended that radiation monitoring be performed on all CSSS materials removed from the site,
prior to disposal, as a precautionary health and safety measure.
In response to an IDEM report of contaminated runoff being released from the drum storage area in the
Markland Quarry, a Removal Action was initiated on February 2,1990, by the U.S. EPA Emergency &
Enforcement Response Branch (EERB). This removal action began with the construction of a trench
within the perimeter of the fence, to prevent further runoff, and the sampling of soils around the drum
storage area. About 800 cubic yards of soil from the quarry area was eventually disposed of off-site. In
addition, about 200 drums found to contain liquid were overpacked, sampled, and disposed of off-site,
with a few hundred empty drums also being crushed and disposed.
An underwater investigation of the quarry pond also revealed the existence of about 1,150 drums and three
4,000-gallon storage tanks in the pond. EERB contracted a diving contractor for removal and disposal of
the drums and tanks found in the pond. This action began in June 1991 and was completed in August 1991.
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On March 13,1990, the EERB also conducted a site-assessment of the Continental Steel facility itself.
During this visit, and subsequent visits, approximately 700 55-gallon drums were found scattered
throughout the facility, as well as 55 tanks, ranging in size from 5,000 to 2 million gallons each, and 33
vats, all of which contain unknown materials. All unknown substances were sampled to determine their
potentially hazardous characteristics. Since that time, EERB has arranged for the disposal of about a
thousand empty, crushed drums, about 200 drums of product material, about 50 containers of lead
cadmium batteries, and about 5,000 gallons of base-neutral liquids. Even beyond this, there is reason to
believe that there is an extensive amount of plant area to be investigated.
A review was also conducted of previous reports documenting waste generation/storage at the Continental
Steel facility. These reports indicated that TCE sludge was a byproduct of cleaning nails for packaging,
and was generated at a rate of about 66 tons annually or about 4 drums per week. This waste TCE sludge
was stored on-site, and was purportedly disposed of by others on a periodic basis. It was noted that the
facility was in violation, at least once, for the improper storage of this waste, including drums not being
properly marked/labeled, improper documentation relative to drum-handling practices, and improper
training of employees. In addition, PCB electric transformers and waste were found to be stored in drums
(in 1986) in the same building used to store the TCE sludge, with one of the drums found to be leaking.
In reviewing the above information, U.S. EPA requested IDEM (since this has been designated as a State-
lead project) that the quarry area and the plant area should be included into the Continental Steel NPL site
Fund-financed RI/FS. This decision was based on several factors, including the fact that, with the
exception of a small portion of the lagoon area, all of the areas were owned by Continental Steel Corp., and
the contamination found there is a part of the same operations/facility with byproducts of the plant
manufacturing operations sent to the lagoon and quarry areas for disposal. In fact, similar materials were
found in these disposal areas, as well as the Main Plant. Specifically, PCBs and TCE were found in all
three of these areas, drums were found in both disposal areas as well as on the Main Plant facility, and slag
material was disposed of at both the lagoon and quarry area. In addition, all three areas are situated above
the same aquifer, with preliminary studies indicating that the groundwater under all three areas migrating
in the same direction and potentially commingling. All three areas would also discharge into the same
surface waters. Finally, the areas are within about half a mile of each other and, as such, essentially have
the same target population. All of this leads to the need to investigate/evaluate all of the areas to ensure
that the cleanup strategy for the site is appropriate relative to all three of the areas. In response to the
IDEM request, the U.S. EPA aggregated the Markland Quarry and the Main Plant into the Continental
Steel Superfund site in May 1990.
The Lagoon Area was proposed for inclusion on the National Priorities List (NPL) on June 24, 1988. The
site was formally placed on the NPL in March 1989. The Markland Avenue Quarry and the Main Plant
were proposed for aggregation to the site, and were added in May 1990.
The following sections summarize historical information and the Remedial Investigation/Feasibility Study
results for each operable unit.
Site-Wide Groundwater
There are three aquifers under the site. They are differentiated by their water-bearing capacity, which is
directly determined by their geologic structure or stratigraphy. They have been classified as the shallow,
intermediate, and lower aquifers or water-bearing zones. These aquifers have been further separated into
two categories: (1) those underlying source contaminant areas and (2) those NOT underlying source
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contaminant areas. Site-wide Groundwater (see Appendix A, Figure 1) includes a large area and quantity
of affected groundwater from all three water-bearing zones. Groundwater appears to have also received
contaminants from the Main Plant, the Markland Avenue Quarry, the Lagoon Area and/or other areas
related to the site, and disposal of hazardous materials. CSSS properties alone cover 183 acres.
Groundwater flow is generally to the west; however, groundwater flow within each zone may vary
according to localized and regional influences, particularly in the shallow zone. The intermediate and
lower water-bearing zones are largely influenced by preferential flow through the fractures in the limestone
bedrock underlying the site. These fractures serve as conduits through which groundwater can easily flow.
The shallow water-bearing zone is influenced mostly by the surface waters, which mostly consists of the
Wildcat and Kokomo creeks. Groundwater flow in the intermediate water-bearing zone on the eastern
two-thirds of the site is due west with a horizontal gradient of 0.01. Hydraulic influence from large
quantity, groundwater pumping operations at the Martin Marietta Quarry is first observed in the vicinity of
the Slag Processing Area where the hydraulic gradient steepens to 0.02.
Most Kokomo residents rely on public water supplies, although there are private wells in the area. The
public water supply for the City of Kokomo is provided by a private water company, Indiana-American
Water Company. Indiana-American Water Company draws its drinking water supply from a reservoir
northeast of Kokomo. The reservoir is upgradient and greater than five miles from the CSSS. There are
three non community public water supply wells in the vicinity of the CSSS. They were sampled during the
RI and the results were non detect for COPCs.
In 1984, 1985 and 1986, IDEM identified chromium, cadmium, lead and iron in the on-site groundwater.
Investigation of the Markland Avenue Quarry and the Main Plant Area confirmed contamination
attributable to Continental Steel. The Main Plant includes 74 buildings, many of which are severely
deteriorated, with floor areas ranging from 10,000 square feet to 400,000 square feet. Many buildings
have basements and pits, most of which are flooded with water due to precipitation and direct connection
with groundwater. There are also water-filled tunnels between buildings. A network of underground
sewers and utility lines are also located on-site. Due to operations at the Main Plant property, waste
materials from the main plant included spent solvents, base solutions, baghouse dust (a listed waste
containing chromium and lead), asbestos insulation materials, sludge contaminated with trichloroethene,
and PCBs from transformers. Since the facility operated as a secondary steel processor, the Main Plant
property was used to store drums of scrap steel material from many sources. Many of these drums were
transported to the property containing liquid material (solvents, degreasers, cutting oils, etc.) along with the
scrap steel. These drums were stored outside on the ground surface without covers allowing for
precipitation to displace the various liquid contents. It was also common practice to dispose of liquid
waste materials on the ground.
As part of the RI/FS, a groundwater model was developed to simulate the regional groundwater flow. It
was used to simulate and predict the interactions between groundwater and surface water, between the
three water-bearing zones, and between localized and regional influences from pumping wells (i.e.,
domestic wells, industrial wells, groundwater supply wells, the dewatering wells at the Martin Marietta
Quarry). The following conclusions were developed:
• Contaminant transport of the intermediate and lower water-bearing zones is controlled by
Martin Marietta Quarry pumping and shallow groundwater discharge to Wildcat and
Kokomo Creeks;
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• Groundwater flow pathways follow the westerly course of Wildcat and Kokomo creeks
and do not diverge significantly to the north or south; and
• Capture of contaminated groundwater by wells in a residential subdivision southwest of
the site is unlikely whether the quarry pumping is operational or discontinued.
Volatile Organic Compounds (VOCs) were the primary contaminants detected in groundwater. PAHs,
PCBs, pesticides and metals were detected, but were limited to point detections at wells and plumes were
not generally identified except for a few metals. DNAPL (Dense Non Aqueous Phased Liquid), which is
produced when various VOCs become commingled, is also present in all three water-bearing zones.
DNAPL is heavier than water and migrates downward until it comes into contact with an impermeable
geologic formation. DNAPL is difficult to extract and treat. DNAPL will breakdown naturally, however,
it generally takes much longer than its non commingled counterparts.
Contaminant plumes were delineated for the shallow (see Appendix D, Table MM-1S), intermediate (see
Appendix D, Table MM-II), and lower (see Appendix D, Table MM-1L) water-bearing zones for source
areas and site-wide groundwater. Some of the source area alternatives address shallow groundwater
contamination within a source area and will not be addressed in this section. A Technical Impracticability
(TI) waiver for the intermediate and lower water-bearing zones was requested and granted pursuant to
121(d)(4) of CERCLA from the U.S. EPA TI Waiver Committee. The TI Waiver was requested based on
groundwater fate and transportation modeling results prepared as part of and presented in the Feasibility
Study. The fate and transportation modeling determined that cleanup goals or drinking water standards
(MCLs) for these water-bearing zones would not be attained within a reasonable time frame. Groundwater
modeling results predict that with or without active remediation attempts, groundwater in the intermediate
and lower water-bearing zones will not achieve ARARs in less than 200 years. The TI Waiver was
granted.
The basic strategy for side-wide groundwater remediation includes the intermediate and lower water-
bearing zones, excluding and leaving the shallow water-bearing zone as part of the remedial strategies for
the individual operable units having source areas directly affecting them (OU-2, OU-4, and OU-5). The
basic Shallow groundwater strategy has two components: (1) eliminate contaminated groundwater
migration from source areas by establishing a collection system for containment of the plumes within their
current boundaries and (2) aggressively extract contaminated groundwater to reduce contaminant levels
and ultimately attain ARARs as rapidly as possible. Shallow groundwater extracted as part of these
source area remedial actions would be pumped to the city of Kokomo sanitary sewer system for treatment
through the city's wastewater treatment plant (WWTP). IDEM has a written agreement with the City of
Kokomo to provide these services at no cost. Groundwater modeling on the lower and intermediate water-
bearing zones was performed applying several different scenarios: (1) no active measures for treatment, (2)
active measures for treatment, and (3) aggressive measures for treatment. The outcome of the modeling
based upon the geology and the presence of DNAPL predicted a 200-year time frame for attaining ARARs.
This data was presented to the EPA TI Committee, which granted the TI Waiver for the lower and
intermediate water-bearing zones.
Lagoon Area
The Lagoon Area (see Appendix A, Figure 2) is located approximately 0.3 miles west of the Main Plant
along the south side of West Markland Avenue (see Appendix A Figure 2). The area covers approximately
56 acres and includes five polishing lagoons, two acid (hazardous waste storage) lagoons, and three
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sludge-drying beds. These lagoons were originally permitted as RCRA surface impoundments for
treatment of wastewater generated from operations at the Continental Steel Plant. This area contains
approximately 788,000 cubic yards of soil, sludge, slag, and clay. A fill area near the lagoon entrance is
contaminated with volatile organic compounds (VOCs). The fill may contain drums and slag material.
Some of the lagoons contain standing water. The area is bordered on the south and west by Wildcat
Creek, on the north by West Markland Avenue, and on the east by the City of Kokomo wastewater
treatment plant. A recreational corridor along the creek has been identified. According to flood maps, the
Lagoon Area is within a 100-year floodplain. It is assumed that the area on the flood maps will be overrun
during a 100-year event. Immediately to the west of Wildcat Creek lies the Haynes International Inc.
facility and its RCRA closed landfill.
Structures on this site include an abandoned treatment building and wastewater treatment clarifiers.
Trespassers have been known to frequent this area. There are no ecological receptors on-site and no
residential areas immediately border the lagoons. This area is primarily designated for commercial/
industrial use since it contains RCRA surface impoundments. Recreational use is limited to the creek
corridor.
While in operation, spent pickle liquor (inorganic acid used to remove impurities from metal surfaces)
generated at the Main Plant was transferred via a direct pipeline to two hazardous waste storage lagoons.
The spent pickle liquor was then pumped to a neutralization and treatment system, and neutralized pickle
liquor and sludge (generated by the treatment) were deposited in one of five polishing lagoons. The treated
liquid was then discharged to Wildcat Creek and the sludge was placed into the three drying beds.
During 1980, Continental Steel achieved interim status for the facility as a hazardous waste treatment,
storage and disposal facility under RCRA. The required RCRA groundwater monitoring of the Lagoon
Area indicated that groundwater within the limestone aquifer underlying the lagoons was contaminated
with metals and trace concentrations of organic compounds. In addition, sampling indicated that surface
water, sediment, and fish in Wildcat Creek had been impacted. During RCRA inspections, drums and
waste piles of slag were observed in the Lagoon Area.
Phase I Remedial Investigation (RI) activities included sampling of the lagoon surface water, lagoon
sludge, soils underlying and adjacent to the lagoons, waste piles, sludge within the mixing and clarifier
tanks at the treatment building, and water in the basement of the treatment building. Phase II RI activities
consisted of groundwater sampling and a soil gas survey in the entrance area to assess VOCs in the fill.
The RI results indicated that elevated levels of metals including arsenic, beryllium, cadmium, lead,
manganese, and chromium were detected in the soil and sludge. Iron was also identified in the lagoon
sludge drying beds and in the shallow water-bearing zone. Methylene chloride, polycyclic aromatic
hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs) were reported in soil and sludge from the
east central and southwest lagoon areas and in the sludge drying beds. Waste piles of slag contained
mostly metals, including elevated levels of arsenic, beryllium, and chromium. Metals including arsenic,
cadmium, copper, lead, manganese, nickel, and zinc were detected in surface water from the acid lagoons.
Silver was reported in one sample collected from the polishing lagoons. The results of the soil gas survey
at the Lagoon Area entrance indicated that there are several integrated plumes of VOCs. Both soil data
and soil gas data were evaluated and identified several areas with elevated VOC solids. The primary
VOCs identified were cis-l,2-dichloroethene, trichloroethene, and vinyl chloride.
Elevated VOC solids are defined as those solids having a total VOC concentration greater than 1 mg/kg.
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This concentration was defined as the cleanup goal for VOCs in contaminated solids because the fate and
transport analysis showed that a VOC soil concentration of 1 mg/kg in solid media will leach at drinking
water MCLs into groundwater.
The groundwater underlying the Lagoon Area (see Appendix D, Tables LA-IS, LA-II, & LA-IL) is
impacted primarily by VOCs (trichloroethene and its breakdown constituents: cis-l,2-dichloroethene and
vinyl chloride) in the entrance area and to a lesser extent by metals. Within each water-bearing zone
(shallow, intermediate, and lower), VOC concentrations are highest in the shallow water-bearing zone at
the entrance, in the intermediate water-bearing zone within the Lagoon Area, and in the lower water-
bearing zone downgradient. Total VOC concentrations appear to be decreasing in the shallow water-
bearing zone, but have remained relatively constant in the intermediate and lower water-bearing zones. In
the downgradient well nests for all three water-bearing zones, the same three primary VOCs were detected
as in the soil gas survey. The lower water-bearing zone wells at these locations are the most contaminated,
indicating that the plume is migrating vertically downward as it moves downgradient. Metals present in
the Lagoon Area groundwater include iron, manganese, nickel, chromium, and antimony. Metal
contamination is likely due to past treatment practices in the acid lagoon ponds (i.e., metals mobility
increases when exposed to significant changes in pH).
DNAPL was noted at the lagoon area entrance, likely the result of near surface releases from drums and
releases from the lagoon sediments. DNAPL movement in the Lagoon Area would be through very small
cracks and pore spaces in the lagoon sludge or slag and then downward into the highly fractured bedrock
below. These bedrock formations are more highly fractured than in other areas of the site, so DNAPL is
likely to travel more easily through the intermediate into the lower water-bearing zone. The presence of
DNAPL in shallow groundwater may affect the effectiveness of the containment, collection, and treatment
of contaminated groundwater. The estimated time frames to attain ARARs are based upon fate and
transportation groundwater modeling which requires that certain assumptions be made for the site due to
the presence and persistence of DNAPL, effectiveness of the containment, collection, and treatment
system, and the variability of the geology. The estimated time frames for groundwater cleanup will change
if the assumptions change significantly, especially if residual DNAPL persists in the groundwater
following implementation of source control activities. Due to uncertainties, the time frames estimated for
groundwater to reach ARARs may likely lengthen (up to 30 years).
The presence of tetrachloroethene in wells southwest of the Lagoon Area in the vicinity of Haynes
International and east of the Lagoon Area near the city of Kokomo wastewater treatment plant (WWTP)
indicates that a source other than the CSSS has contributed to groundwater contamination.
There are two future use scenarios considered for the Lagoon Area. One is commercial/ industrial use for
the area in general. The second is trespasser use for the creek corridor, which is the 50 foot wide bank area
along Wildcat Creek.
Closure of the RCRA permitted surface impoundments (lagoons) was included in all alternatives except
for the No Action alternative. It was assumed that the lagoon sludge could be closed in-place based on the
stabilization testing results from the treatability testing program (U.S. EPA, 1996). These results indicated
that contaminants of concern would not leach from the sludge at levels above MCLs. An issue for the
RCRA impoundments will be that this area is located within the 100-year floodplain of Wildcat Creek.
Closure of the lagoons in-place would necessitate the construction of a capping system with grading/fill to
promote runoff of surface water that would extend above existing grades and into the flood storage
volume. Compensatory storage would be required.
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Closure of the lagoons in-place would be designed to provide a structurally sound subbase upon which to
construct and operate an on-site landfill (CAMU or Corrective Action Management Unit) for disposal of
excavated materials from all CSSS source areas. The on-site landfill would be constructed in the
central/southeast portion of the Lagoon Area and would be the designated disposal location for
contaminated solids from all source areas. The central/ southeast corner was selected to isolate the landfill
from public view and for access. The CAMU would occupy approximately 40 percent of the Lagoon
Area. Figure 2 (Appendix A) shows the proposed location of the CAMU landfill in the Lagoon Area as
well as an area for compensatory storage. Most importantly, siting of the landfill at the Lagoon Area will
necessitate remedial actions first occurring at the lagoons to prepare the area for accepting other source
area contaminated materials. The CAMU concept was presented to IDEM RCRA for review and
comment. Surcharging of the lagoon area was also presented to IDEM RCRA as a recommendation from
USEPA's National Remedy Review Board. IDEM RCRA approved the use of the CAMU and expressed
reservations for surcharging.
Justification for selecting the Lagoon Area as the on-site landfill location is provided in Appendix B of the
FS. Appendix B also includes more detailed discussion of the guidelines for RCRA surface impoundment
closure, landfill construction, and landfill operation as part of a CAMU. The landfill design includes a
membrane liner and cap system (the membrane bottom liner may be waived since contaminants do not
leach above MCLs). The landfill/CAMU design would be finalized during the remedial design and would
include the membrane liner and cap system, leachate collection system, and groundwater monitoring
systems. Compensatory flood storage would be provided during on-site excavation activities. The details
of the RCRA impoundment closure, landfill construction and landfill operation as part of the CAMU will
be refined during the remedial design phase. Figure 2a shows a conceptual cross-sectional view of the
CAMU landfill overlying the consolidated lagoon sludge.
Kokomo and Wildcat Creeks
The Wildcat and Kokomo creeks extend some 20,000 feet within the CSSS (see Appendix A, Figure 3).
These creeks have been impacted by direct discharge of material, runoff from the source areas, and
upstream industrial sources. The creeks are generally 50 to 100 feet wide, with depths up to four feet.
These creeks are designated for recreational use. A recreational corridor extends along most of the banks
of the creeks. These two creeks run along the borders of the Main Plant, the Lagoon Area, and the Slag
Processing Area. The creeks have received water from the plant's wastewater recycling, treatment and
filtration system, neutralized pickle liquor from the Lagoon Area, discharge from site outfalls and storm
water runoff from the site in general.
Wildcat and Kokomo creeks are part of the Upper Wabash River basin. Wildcat Creek confluences with
the Wabash River in Lafayette, Indiana, nearly 45 miles west of Kokomo. The nearest upgradient public
drinking water well is nearly five miles from the site. The nearest downgradient public drinking water well
is nearly fifteen miles from of the site and is likely too far south to be considered in the regional
groundwater flow path. The nearest surface water extraction point for a public drinking water supply is
over eight miles up stream and greater than 40 miles down stream of the site.
Surface water and sediment sampling was performed as part of Phases I and II Remedial Investigation
(RI). The Wildcat and Kokomo creeks were subdivided into six testing sections or reaches, with surface
water and sediment samples collected from all six. Reaches 1, 2, 3, 5 and 6 correspond to Wildcat Creek
and Reach 4 corresponds to Kokomo Creek. Background samples were collected upstream within both
creeks to establish a site-specific reference-based cleanup standard by which to judge sampling results
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from within the Reaches. Shallow groundwater sampling (see Appendix D, Table C-1S) was conducted
at monitoring wells adjacent to the creeks. Groundwater results were compared to sediment and stream
water results to evaluate whether an interrelationship exists between the creeks and groundwater. The
reason is that shallow groundwater at times may flow into the creeks and at other times may be recharged
by the creeks. Groundwater is addressed more completely as part of site-wide groundwater.
The analytical results of surface water sampling indicated that elevated levels of lead were detected along
all six reaches of the creeks. Copper was detected along Reaches 1 through 5 and zinc was detected along
Reach 3. Elevated levels of mercury were detected in samples collected from Reaches 4 and 5. Elevated
cobalt concentrations were detected along Reach 6.
Groundwater sampling results showed elevated levels of VOCs, including tetrachloroethene (PCE),
trichloroethene (TCE), cis-l,2-dichloroethene, 1,1-dichloroethene, and vinyl chloride. Elevated levels of
nickel and lead were also detected in shallow groundwater adjacent to the creeks. Groundwater
contamination observed indicate sources other than the creeks (e.g., lagoons, landfills, and spills) are more
significant contributors to groundwater contamination.
The results of sediment sampling indicated that constituents were consistently detected above background
and/or benchmark criteria (criteria) in the Wildcat and Kokomo Creeks. Benchmark criteria were taken
from the Indiana Water Quality Regulations or the Federal chronic water ambient quality criteria. It was
concluded in the preliminary ecological evaluation of the Wildcat and Kokomo Creeks that no critical
terrestrial, semi-aquatic, or aquatic habitat is present within the creeks.
VOCs were detected in sediment above criteria in Reach 3. SVOCs and PAHs were detected above
criteria in Reaches 3, 4, 5 and 6. PCB Aroclor-1248, Aroclor-1254, and ArocIor-1260, were detected
above criteria in samples collected from all six reaches of the creeks. Aroclor-1016 was detected above
criteria in samples collected from Reaches 3, 4, 5 and 6. Pesticides that exceeded criteria were typically
detected in the same reaches as PCBs. Pesticides were detected above criteria in sediment. 4,4'-DDE,
aldrin, and gamma-chlordane were detected in all six Reaches at three to 10 (plus) times the criteria. 4,4'-
DDT, 4,4'-DDD, heptachlor, heptachlor epoxide, endrine aldehyde, dieldrin, gamma-BHC, alpha-
chlordane, and endosulfan II were detected in various Reaches of the streams at concentrations greater than
10 times the criteria.
Numerous metals were detected above criteria in sediment samples collected along the reaches of the
creeks sampled. Cadmium, chromium, copper, nickel, and zinc were detected in Reaches I, 3 and 4 at
concentrations greater than 10 times criteria and in Reaches 2, 5, and 6 at concentrations less than 10 times
criteria. Other metals detected up to 10 times criteria include aluminum, arsenic, barium, iron, lead,
silver, thallium, mercury, selenium, manganese, antimony, and vanadium.
Fish tissue analyses performed by the Indiana Department of Environmental Management, Water
Management, Biological Studies Section, has identified several contaminants, including PCBs, mercury,
and the pesticides, at elevated levels prompting a Level Five fish advisory for the Wildcat Creek in the
vicinity of the Continental Steel Superfund Site.
Mark/andAvenue Quarry
This 23-acre area was formerly a limestone quarry, covering nearly the entire area. The quarry was sold to
Continental Steel Corporation (CSC) in 1947. It is bordered by Harrison Street to the north, West
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Mark land Avenue to the south, Courtland Avenue to the east, and Brandon Street to the west (see
Appendix A, Figure 4). Review of historical aerial photographs (August 1938 state archive aerial photos)
show the original quarry as a large pond spanning the entire block, except for the unexcavated southwest
corner and southern border, between Courtland Street and Brandon Street. CSC subsequently backfilled
the quarry about 3/4 of the way full with waste material from the CSC operations. More than 1 .2 million
cubic yards of material from the CSC were deposited in the quarry. The quarry varied in depth from 70-90
feet and includes a pond (4 acres). Continental Steel disposed of waste materials such as drums, slag,
refractory brick, pig iron, baghouse wastes, and tanks of oil and solvents at the quarry. According to
former employees, the quarry served as a drum reclamation area where drums were dumped directly onto
the ground and disposed of in the quarry pond. Previous U.S. EPA investigations (July 1986, May 1988)
revealed approximately 400 (mostly empty) drums, an abandoned storage tank, and slag, ash and refractory
brick piles in the area. Sediment in the pond contains high concentrations of VOCs and DNAPL (Dense
Non-Aqueous Phased Liquid). These sediments are four to seven feet thick and are located below 50 feet
of water. The quarry is in a residential area, is an attractive nuisance attracting trespassers, and has no
ecological significance. The surface water exhibits a pH of up to 12. The quarry area is zoned for
residential use.
This area was also used as drum disposal/staging area, where some drummed wastes were purportedly
taken and the contents were dumped into the quarry pond. In a 1986 inspection, approximately 415 drums
were found scattered around the surface of the quarry. Samples of the contents of some of the drums
revealed elevated levels of benzene, toluene, tetrachloroethane, and benzoic acid. In addition, elevated
levels of phenol, di-n-octylphthalate, TCE, and PCB-Aroclor 1248 were found in soil samples taken from
around the drum storage area. Previously the U.S. EPA sampled the contents of the drums, surficial
sediments, and quarry pond sediments for numerous organic and inorganic contaminants.
Sampling of the quarry pond was performed in 1987, and revealed that the liquid in the pond had a pH of
approximately 1 1 .5 for the top samples, and 12.6 for the bottom samples. In addition, low concentrations
of copper, zinc, and mercury were present in some of the samples. DCE and TCE were also found to be
uniformly present in each of the samples, with higher concentrations of TCE detected in the bottom
samples. Finally, very low concentrations of other volatile and semi-volatile organics were detected in the
bottom samples, including ethylbenzene, DCA, toluene, methylene chloride, naphthalene, phenol, and
phenanthrene. Sediment sampling revealed high concentrations of TCE (>200,000
Phase 1 Remedial Investigation (RI) in the Markland Avenue Quarry included sampling of the quarry pond
water and the shallow subsurface soil/fill. Phase II sampling activities performed in the quarry included
surface soil (on-site and off-site residential) sampling (see Appendix D, Tables MAQ-3), a soil gas survey
(see Appendix D, Table MAQ-5), ground water screening (see Appendix D, Table MAQ-6), groundwater
sampling (see Appendix D, Tables MAQ-7S, MAQ-7I, & MAQ-7L), and quarry pond surface water (see
Appendix D, Table MAQ-1) and sediment sampling (see Appendix D, Table MAQ-2).
The soil gas survey detected four areas of elevated VOC solids (previously defined in OU-2) (see
Appendix A, Figure 4b). VOC contamination consisted primarily of trichloroethene (TCE) and its
degradation products. The vertical extent of the contamination could not be defined. Soil gas
measurements were limited to 20 feet in depth, and fill extends from 50 to 70 feet in depth. The area with
the highest contaminant concentration is located just north of the abandoned concrete structure in the
southwest portion of the site. This area is of concern because of the relatively high concentration of the
degradation product vinyl chloride. The other two areas and an area of lesser concentration are located
along a line from southwest to northeast that parallels an old rail line that crossed the quarry. Based on
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historical information, it is assumed that the deeper fill material is the same as the top 20 feet. Historic
disposal practices for the Continental Steel Corporation would indicate that surface drum releases and
drum burial occurred on the Quarry property and may be the sources of the elevated VOC solids identified
within in soil gas results.
Surface soils were collected from the quarry fill area (on-site) and at selected residential properties
surrounding the quarry to evaluate the potential risks associated with these soils. Elevated levels of PAHs,
PCBs, lead, arsenic, and zinc were detected in the surface soils in the quarry fill area. The PAH and PCB
contamination appear primarily in the southern half of the fill area. The lead and arsenic contamination are
widespread and the zinc contamination is sporadic. The residential soil samples downwind from the
quarry show isolated detections of contaminants. However, no metals (including lead) were detected at
levels exceeding IDEM or EPA Action Levels.
The quarry pond sediment is contaminated with VOCs, PAHs, PCBs and metals. DNAPL (mostly from
TCE) is also present within the pond sediments and is likely migrating into the less fractured bedrock
comprising the intermediate water-bearing zone. Most of the contaminants exceed sediment benchmark
screening levels as defined within the Risk Assessment (RA). The sediments are a continuing source of
contamination to surface water and to ground water. The contaminants of concern are the VOCs as they are
highly mobile and migrate easily. Trichloroethene is the most prevalent and was detected at the highest
concentrations (>200,000 /^g/l)(see Table MAQ-2, Appendix D). Most of the parameters detected in the
pond sediment exceed sediment benchmark screening levels, which are based on aquatic toxicity.
The quarry pond surface water is contaminated with VOCs, primarily, TCE. It is likely that VOC
contaminants are migrating from the adjacent fill material, DNAPL in the sediments, and groundwater.
Three metals were also detected. Pond water exhibited a pH of 11.5 near the surface to a pH of 12.7 at
depth. The high pH indicates there may be a contaminant of a very basic nature which has not yet been
, identified in the quarry fill. The high pH may affect the degradation of organic constituents in the
groundwater.
Trie primary contaminants in the groundwater are TCE, cis-l,2-dichloroethene, and vinyl chloride. They
are highest in the quarry fill area in the shallow water-bearing zone and downgradient of the quarry pond in
the intermediate water-bearing zone. The lower water-bearing zone shows the least groundwater impacts.
VOC concentrations appear to decrease in the shallow water-bearing zone and increase in the intermediate
zone at the quarry. VOCs appear to have migrated to the west side of the site in the intermediate and lower
water-bearing zones. Groundwater results indicate that degradation of components in the intermediate
zone is well progressed. This is apparent based on the presence of the TCE breakdown compounds (cis-
1,2-dichloroethene and vinyl chloride).
The DNAPL in the quarry pond may also migrate vertically and laterally in directions which do not
coincide with groundwater flow. Migration from these sediments would likely be into the intermediate
water-bearing zone based on the elevation of the quarry sediments. DNAPL may also migrate downward
entering the bedrock fractures located below the sediment and on the west and north sides of the quarry
pond. However, resuspension of the sediments by disturbing their current state of rest may mobilize
DNAPL into the shallow water-bearing zone. Additionally, DNAPL that originates within the quarry fill
likely migrates down to the lower portions of the quarry. DNAPL is likely present in fractures in the lower
water-bearing zone as well, having migrated through vertical fractures in the bedrock.
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Main Plant
The Main Plant property consisted of three tracts of land comprising approximately 100 acres. These three
areas include the Main Plant building area (94 acres)(see Appendix A, Figure 5), the equipment storage
area located at the southwest corner of Markland Avenue and Park Avenue (0.8 acres), and the former
engineering building located north of Markland Avenue between Park Avenue and Syndicate Sales (5
acres). The Superfund designated area of the Main Plant consists of 94 acres bordered by West Markland
Avenue to the north, Deffenbaugh Road and private property to the south, Leeds Street to the east and
Wildcat Creek to the west. The Main Plant contained most of the steel operations and is deed restricted by
the current no asset owner for commercial/industrial use. The Main Plant includes 127 structures,
including more than 74 abandoned buildings, many with basements, underground sewers, and utility lines.
Industrial operations affected surface soil. There is contaminated soil west of the plant along Wildcat
Creek. The plant has numerous visitors/trespassers.
Early investigations found more than 700 oil- and solvent-filled drums, 55 aboveground and underground
storage tanks, and 33 vats. The tanks and vats held mostly oil and some chlorinated solvents and acids.
Twenty-four electrical transformers, 200 capacitors, electric arc furnace dust (baghouse dust), and exposed
asbestos were found in the plant.
The Main Plant buildings themselves are being addressed under an Interim Record of Decision (IROD).
The IROD includes the decontamination and demolition of 127 structures and buildings, disposal of solid
and liquid hazardous and nonhazardous wastes, and asbestos survey and abatement. The IROD has been
approved by EPA. Contractor procurement has been completed and EPA funding granted. Therefore, it is
assumed that the buildings will be removed from the site and only foundation elements and utilities shall
remain. The south Kokomo city sewer main lines transgress through the CSSS Main Plant property under
the original Park Avenue location.
Numerous basements/pits and two CSSS Main Plant process sewer lines (not municipal owned) are
considered to be sources of VOCs, PAHs, PCBs, metals, and oils which could impact groundwater. With
the exception of VOCs, these contaminants are not mobile in the environment. Although these
basements/pits and process sewer lines could potentially impact groundwater, there is not a complete
exposure pathway for direct human contact for these sources. The RA did not consider the basements/pits
and process sewers as potential risks to human health.
Phase I RI activities included collection of samples from inside (see Appendix D, Table MP-1) and outside
the buildings. Since the remediation of the buildings is being completed as a separate action, the buildings
will not be discussed herein. Field investigations and previous work by U.S. EPA included sampling of
process sewers and soil from stained areas. Phase II RJ activities (excluding the buildings) included
surface and subsurface soil sampling (see Appendix D, Tables MP-4ss & MP-4sd), groundwater sampling
(see Appendix D, Tables MP-5S & MP-5I), process sewer sampling (see Appendix D, Table MP-3),
basement water sampling (see Appendix D, Table MP-2), soil gas sampling, adjacent residential surface .
soil sampling (see Appendix D, Table MP-6), and high volume air sampling.
Phase II results indicate that the Main Plant has likely contributed to elevated metals in the residential area
east of the Main Plant. Lead concentrations were highest along plant boundaries. This indicates the plant
could be a source for airborne contaminants. Air sampling results also indicate the plant was a source. An
Indiana State Department of Health blood lead screening program did not show an exposure. The issue of
off-site residential soil contamination is a separate action and will not be discussed further herein.
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Numerous surface spills around the site have been identified based on sample analytical results and
historical records. These surface spills have resulted in an impact to soils from VOCs, SVOCs and PAHs,
PCBs, pesticides, and metals. Most significant of the releases are those involving VOCs as evidenced by
the impact to groundwater west of Building 112 (Nail Mill). Other significant surface spills include one in
the vicinity of Kokomo Creek where VOCs, PAHs, and lead were detected above initial screening levels
and the surface spill at the southeast corner of Building 71B (Wire Galvanizing) where PCBs, pesticides,
lead, and zinc were detected above initial screening levels. The area east of Buildings 5 and 42 was
observed to have oil saturated soils along with analytical results indicating concentrations of PAHs, PCBs,
and lead above screening levels in soils.
The results of soil gas sampling in an area formerly utilized as a waste slag disposal area in the south Main
Plant area indicated that VOCs were either not detected or detected at very low levels in the soil gas.
Groundwater results indicate relatively few contaminants detected except in locations where reported spills
have occurred or stained soil is present. Therefore, groundwater impact in these areas is likely related to
operational practices and spilled chemicals, mostly VOCs. The primary contaminants in groundwater are
trichloroethene (TCE), cis-l,2-dichloroethene, and vinyl chloride. Total VOCs were highest in the
intermediate water-bearing zone near Wildcat Creek. Specifically, VOC concentrations are highest in the
known spill area on the west boundary within the shallow, intermediate and lower water-bearing zones.
These results are consistent with the reported spills of TCE in this area.
VOC concentrations appear to be decreasing in all three water-bearing zones, except at Wildcat Creek.
TCE concentrations appear to be decreasing, while cis-l,2-dichloroethene and vinyl chloride are
increasing. VOC concentrations at Wildcat Creek indicate a plume is migrating downgradient from the
Main Plant. The presence of chlorinated VOCs indicates that migration of contaminants in the shallow
water-bearing zone can occur under creek beds.
The vertical extent of groundwater contamination in the Main Plant area is not well defined. Contaminants
are likely present at higher concentrations and potentially deeper near source areas. The assumed
distribution of DNAPL includes residual DNAPL in shallow soils at spill locations and in fractures in the
shallow, intermediate and lower water-bearing zones. The DNAPL migration will not necessarily follow
groundwater flow directions but rather structural features such as the fractures in the bedrock.
Slag Processing Area
The Slag Processing Area (see Appendix A, Figure 6) contains approximately 208,000 cubic yards of slag
material, much of it in stockpiles. The current site disposition includes an open, graded (relatively flat)
area with seven piles of slag material, the largest pile having a maximum height of about 45 feet. The piles
include a total volume of about 62,000 cubic yards. Historical information indicates that the southwestern
quarter of the area was formerly a quarry (Chaffin Quarry), was approximately 30 feet deep, and is now
filled with slag. The area is located between Wildcat Creek and Markland Avenue. It is visible to the
public and is easily accessed. The Wildcat Creek bank to the west has been subjected to runoff and
erosion. The surrounding area is generally residential.
Slag, prevalent throughout various areas of the CSSS, primarily consists of calcium and iron oxides with
smaller amounts of aluminum, chromium, lead, manganese, magnesium, and zinc oxides. Slag
processing was conducted to reclaim certain metals. The slag may locally be contaminated with oil and
solvents depending on location at the CSSS.
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A partially decayed drum was discovered protruding from the side of a vertical cut in the slag. Eight
drums were observed along the creek bank and on the large slag pile. The observation of these drums
combined with the confirmation of drum disposal at other CSSS properties indicates that drum burial was a
standard practice. The drums observed in this area were in varying states of decay. The majority appeared
crushed or bent indicating these drums may have been empty or near empty at the time of disposal.
Phase II RI activities performed in the Slag Processing Area included surface soil/slag sampling (see
Appendix D, Table SP-1), a soil gas survey, and an evaluation of potential impacts to Wildcat Creek.
Based on the RA, the slag material poses a direct risk to human health or the environment due to the
presence of metals (lead and arsenic). The RI noted a potential pathway for contamination of Wildcat
Creek through uncontrolled surface water. Metals identified in the slag stockpiles and surficial solid media
during the RI are also contaminants of concern for Wildcat Creek sediment and surface water.
VOCs were not detected in soil gas or surface soil. Additionally, no SVOCs or PCBs were detected in
surface soil. These results do not indicate contamination resulting from surface spills or leaking drums
buried near the surface.
No VOCs were detected in the shallow water-bearing zone, except at the upgradient well (see Appendix D,
Table SP-2S). Several VOCs were detected in the intermediate water-bearing zone (see Appendix D,
Table SP-2I) including significant concentrations of trichloroethene, cis-l,2-dichloroethene, and vinyl
chloride. Cis-l,2-dichloroethene, l,lrdichloroethane, and acrylonitrile (150 ug/L) were detected in the
lower water-bearing zone (see Appendix D, Table SP-2L). This vertical distribution indicates impact from
VOCs likely originates from upgradient sources rather than from the Slag Processing Area. VOC
concentrations appear to be decreasing higher within the intermediate zone but may be increasing deeper
within the intermediate zone. VOC concentrations appear to be decreasing in the lower water-bearing zone
as well.
Groundwater beneath the Slag Processing Area, although identified as containing contaminants of concern
above remediation goals, will not be addressed through source control alternatives presented in this
section. Source control alternatives for the Slag Processing Area will be evaluated for solid media
contamination only. The RI and modeling concluded that groundwater contamination beneath the Slag
Processing Area and extending beyond the Slag Processing Area boundaries originates from an off-site
source. Therefore, groundwater beneath the Slag Processing Area will be addressed in the management of
migration alternatives for site-wide groundwater as presented in Operable Unit 1.
Under an industrial/commercial future use scenario, previously acquired data have not indicated the
presence of any contaminants of concern in the solid media above remediation goals. Under a residential
future use scenario, however, lead and arsenic are contaminants of both the slag piles and the surficial
solids across the majority of the Slag Processing Area. A residential scenario will be utilized for baseline
cleanup goals, since this property has adjacent residential properties. The limits of the Slag Processing
Area are shown on Figure 6 (Appendix A).
It is noted that the slag material does not leach constituents at concentrations above ARARs. Therefore,
the only health issue is direct contact exposure for metals. The ability to treat slag by incineration is of low
effectiveness. Therefore, treatment options were not considered for this site.
III. Community Relations Activities
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The public participation requirements of CERCLA Sections 113 (k)(2)(B)(i-v) and 117 of CERCLA have
been met in the remedy selection process. This decision document presents the selected remedies for the
six operable units of the Continental Steel Superfund site, chosen in accordance with CERCLA, as
amended by SARA, and to the extent practicable, the NCP. The decision for this site is based on the
Administrative Record.
In June 1990, EPA and IDEM held a Public Availability Session to introduce themselves to the Kokomo
and Howard County community, explain the ongoing Removal Action activities, and explain the listing of
the site on the NPL and the steps of the Superfund process. A fact sheet was prepared and presented to
the community.
In September 1990, IDEM released fact sheet regarding Remedial Investigations and ongoing Removal
Actions and announcing two Public Availability Sessions for November 14, 1990 to discuss and answer
questions concerning these issues.
In December 1992, EPA and IDEM held a Public Availability Session for the purpose of allowing
individuals or small groups the opportunity to ask questions and discuss the past and ongoing Removal
Action and the Remedial Investigation (RI) of the site. The meeting was announced through the local
media and the release of an information fact sheet.
In May 1993, IDEM and EPA held a Public Availability Session and released an information fact sheet to
"kick off the Remedial Investigation/Feasibility Study (RJ/FS) and update the community on site Removal
Action activities. The community was also informed of their role in the process.
In November 1995, IDEM hosted two informal Public Availability Sessions and released a fact sheet
documenting the Remedial Investigation and Removal Action status. At this time, the community was
informed of the hiring of a new contractor to complete the RJ/FS and the proposed change to a focused RI
approach. The Phase I RI data, which had been accumulated by the previous contractor, was also made
available to the community at this time.
In February 1996, IDEM held a Public Availability Session and released a fact sheet for the Interim
Remedy Proposed Plan. The Interim Remedy was for the decontamination and demolition of the buildings
and structures on the Main Plant property of the CSSS. IDEM presented the four alternatives considered
by IDEM and EPA, the recommended alternative, and received oral and written comments. The
alternatives were (1) No Action, (2) Immediate Decontamination & Demolition of the Buildings and
Structures, (3) Immediate Decontamination of the Buildings and Structures, and (4) Securing the Buildings
and Structures. Alternative 2 was the recommended alternative. Community participation and acceptance
the recommended alternative was high.
In July 1997, IDEM hosted a Public Availability Session and released a fact sheet for the Residential Lead
Soil Contamination Non Time Critical Removal Action. This Removal Action was for the removal of lead
contamination deposited in the residential neighborhood located directly east of the CSSS Main Plant
property. Soil samples collected during the RJ indicated the presence of lead contamination in this
neighborhood at potentially unacceptable levels. Additional investigations confirmed the presence of the
lead contamination. During the session, the three possible actions considered in the EE/CA (Engineering
Evaluation/Cost Analysis) and the selected action were presented to the public. The meeting was attended
by 38 individuals representing the community, including 2 from local environmental groups, 6 from the
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media, 1 local governmental official, and 1 political official. This action began in May 1997. Since
commencement, dual Public Availability Sessions to update the community and provide for informal
discussions have been held by IDEM on May 4, July 9, and August 25.
In March 1997, IDEM hosted a Public Availability Session and released a fact sheet on the final proposed
plan for the CSSS. IDEM presented the considered and recommended alternatives for each of the six
operable units and accepted written and oral comments from the community at the session. The meeting
was attended by 58 individuals representing the community, including 8 from local environmental groups,
6 from the media, 5 local governmental officials, and 6 political officials.
The IDEM CSSS project manager has attended many other local meetings. The project manager has
attended meetings held by, but not limited to, Kokomo Against Pollution (KAP), the Business-Labor
Alliance, Leadership Kokomo-Howard County Beautification Issues Group, Rotary Club, and the
Community Action Committee. Some of these meetings have been held monthly and quarterly.
IV. Scope and Role of Response Action
The purpose of this Record of Decision (ROD) is to select the final remedial action for the Continental
Steel Superfund site. This final remedy controls sources and prevents the further migration of
contaminants. The final remedy for the six operable units addresses all media and migration pathways that
are considered to present an unacceptable risk, including contaminated soils, waste piles, sediments,
sludge, and groundwater.
IDEM has determined that collection and treatment of shallow groundwater, collection and containment of
intermediate and lower groundwater, on-site disposal of elevated contaminated solids, and placement of
common soil cover over source contaminant areas is necessary at the CSSS. This decision is based upon
an analysis of the site risks as described below. The decision relies on the results of the Remedial
Investigation/Feasibility Study for the Site-Wide Groundwater, Lagoon Area, the Wildcat and Kokomo
creeks, Markland Avenue Quarry, Main Plant, and Slag Processing Area.
The elevated VOC solids and elevated PCB contaminated solids will be removed and consolidated on site
in the CAMU landfill to be constructed on the Lagoon Area. If these contaminated solids are identified as
needing treatment before placement in the CAMU, then the statutory preference for treatment as a
principal element of the remedy would be achieved. However, if the excavated solids do not need
treatment based on testing for treatability and Toxicity Characteristic Leaching Procedure (TCLP) and
because treatment of the additional threats at the site was not found to be practicable, this remedy would
not satisfy the statutory preference for treatment as a principal element of the remedy.
The purpose of the contaminated solids remedial action is to address potential continuing sources of
contamination to the groundwater and remove those solids posing the greatest threat to human health.
There is also a potential for some treatment of some of the excavated soils and sediments.
The threat to human health posed by the groundwater has been initially addressed through sampling of
residential drinking water wells, providing of an alternate water supply where an accedence of a drinking
water standard has been detected, and continued monitoring. The groundwater contamination will be
addressed further by this remedy by: (1) collection, treatment, containment of shallow groundwater; (2)
collection and containment of intermediate and lower groundwater, including invoking a Technical
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Impracticability Waiver; and (3) use of institutional controls, in the form of deed and groundwater use
restrictions. Despite the impracticability, extracted contaminated groundwater, particularly those collected
from the intermediate and lower aquifers for the containment portion of the remedy, will also be treated.
Because hazardous substances will remain at the site, IDEM will conduct a five-year review in accordance
with Section 121 of CERCLA to assess whether any other source control measures are necessary.
V. Summary of Site Characteristics
•
The following subsections provide a characterization of each operable unit and present a summary of and
the results of the field investigation activities for that operable unit. There are six operable units for the
CSSS, four of which are considered source areas. The four source areas include the Main Plant, Markland
Avenue Quarry, the Lagoon Area and the Slag Processing Area. The remaining two operable units are
Kokomo and Wildcat Creeks and site-wide Groundwater. (see Appendix A for Figures)
On-site work performed during the RI included sampling of soil, groundwater, sediment, and surface
water. On-site sources of contamination at the site were also characterized through the review of historical
records, well survey, and ex-employee interviews. For each of the industrial facilities, a records search was
performed to support or refute the possibility that the facility impacted environmental media in the area of
the CSSS. Regulatory records maintained by various local and state agencies were reviewed to identify
facility chemical inventories as well as minor to significant industrial spills, leaks and releases. The
following items and files were reviewed for information and historical records: .
Sanborn Maps
Historical Aerial Photographs
State Spills - IDEM
UST/LUST - IDEM
NPDES - IDEM
RCRA - IDEM
SARA Title III - IDEM
TSCA - IDEM
Indiana State Board of Health
Kokomo Fire Department
Howard County Health Department
Howard County Local Emergency Planning Committee
Indiana Department of Natural Resources - Division of Fisheries
Site Geology and Hydrogeology
CSSS is located in Howard County, in the Upper Wabash River basin. The Indiana Department of Natural
Resources (IDNR) divided the Wabash River basin into three subbasins: an upper basin, a middle basin,
and a lower basin. The Upper Wabash River basin extends in area from the northeast portion of the state,
westward along the Wabash River, to the city of Lafayette in Tippecanoe County. Kokomo and Wildcat
Creeks flow westward through the site to the Wabash River. The confluence of Wildcat Creek and
Kokomo Creeks is located southwest of the Main Plant. Wildcat Creek is the last tributary of the Wabash
River in the Upper Wabash River basin.
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Most physiographic features in the Upper Wabash River basin were formed by glaciers. Howard county is
located on the Tipton Till Plain, a nearly flat glacial till plain that covers much of central Indiana. The till
plain surface slopes gently to the west at a slope of less than one percent. Till, a mixture of unsorted and
unstratified clay, silt, sand, and gravel deposits, is the predominant deposit. According to the
"Hydrogeologic Atlas of Aquifers in Indiana" (Fenelon et al. 1994), the surface of the till plain is
undulating and poorly drained. Incised valleys along Wildcat Creek and Kokomo Creek provide the most
prominent topographic features in the vicinity of the site.
The till plain is underlain by ground moraine and ablation tills deposited during several glacial advances
during the Pleistocene Epoch (1 million to 10,000 years ago). The plain is covered by surficial drift
deposits from melting ice, streams, and ice-dammed lakes. Buried deposits of sand and gravel interspersed
within the till plain are thicker and more extensive than valley-train and alluvial deposits near the ground
surface.
Glacial drift deposits in the vicinity of the site range in thickness from zero feet in quarries along Wildcat
Creek to more than 200 feet in buried valleys that were eroded in the underlying bedrock. Glacial drift
deposits underlying the site are generally less than 20 feet in thickness.
Paleozoic bedrock underlies the glacial drift deposits. Bedrock structure is dominated by the Cincinnati
Arch in this area of the state (Figure 8, Hydrogeologic Atlas of Aquifers in Indiana, Fenelon et al. 1994).
The axis of the Cincinnati Arch plunges to the northwest, at a slope of 4 to 13 feet per mile. According to
the "Hydrogeologic Atlas of Aquifers in Indiana" (Fenelon et al. 1994), the Cincinnati Arch, during the
Paleozoic Era (225 to 570 million years ago), separated open seas to the northeast and southwest and
supported coral reef communities that are now carbonate deposits. The site is located near the axis of the
Cincinnati Arch, although bedrock units in the vicinity of the site dip slightly southwest from the axis of
the arch.
According to "Water Resources of Wildcat Creek and Deer Creek Basins, Howard and Parts of Adjacent
Counties, Indiana, 1979-82" (Smith et al. 1985), the predominant feature of the bedrock surface is a valley
system cut by streams flowing from east to west. Figure 3 in "Water Resources of Wildcat Creek and
Deer Creek Basins, Howard and Parts of Adjacent Counties, Indiana, 1979-82" (Smith et al. 1985) is
drawn at a scale of three miles per inch and appears to indicate the presence of a ancient river channel
located to the southwest of the site. The presence of an ancient river channel located southwest of the site
was also suggested during construction of the groundwater model for the site from residential well logs.
Lithologic logs for residential wells located southwest of the site indicate that the top of the bedrock is at
depths up to 140 feet, which is significantly deeper than bedrock encountered at the site during the field
investigation.
According to references (Smith et al. 1985 and Fenelon et al. 1994), groundwater flow is primarily
through semi-confined sand and gravel deposits within the glacial drift, where these deposits are present,
and through open fractures, joints, bedding planes, and solutional channels within the bedrock. Although
the principle sources of groundwater are glacial drift aquifers in the Upper Wabash River basin, these
aquifers are not present at the site. The Silurian-Devonian carbonate aquifer is the primary bedrock source
of groundwater in the site vicinity.
According to "Water Resources of Wildcat Creek and Deer Creek Basins, Howard and Parts of Adjacent
Counties, Indiana, 1979-82" (Smith et al. 1985), the USGS collected water level measurements from
approximated 150 domestic and commercial wells during 1980 and from two continuous-record
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observation wells from 1966 to 1981 during the study of the Wildcat and Deer Creek basins. According to
this study, groundwater flow within the bedrock is generally toward streams; however, reaches of Wildcat
Creek near Kokomo are affected by the diversion of surface water, large-quantity groundwater
withdrawals, treated wastewater discharges, and the regulation of reservoirs.
Stratigraphy underlying the site has been categorized into three hydrologically significant water-bearing
zones: a shallow water-bearing zone; an intermediate water-bearing zone; and a lower water-bearing zone.
The shallow water-bearing zone at the site generally includes the overburden and the highly fractured
Kokomo limestone and, to a limited extent, the upper Listen Creek limestone. The intermediate water-
bearing zone includes the less fractured lower Kokomo and the Liston Creek limestone. The lower water-
bearing zone consists of the lower 10 to 20 feet of the Liston Creek limestone and the upper 5 to 20 feet of
the Mississinewa shale.
Stratigraphy underlying the site was categorized into three hydrologically significant water-bearing zones:
a shallow water-bearing zone; an intermediate water-bearing zone; and a lower water-bearing zone. The
shallow water-bearing zone at the site generally includes the overburden and the highly fractured Kokomo
limestone and, to a limited extent, the upper Listen Creek limestone. The intermediate water-bearing zone
includes the less fractured lower Kokomo and the Liston Creek limestone. The lower water-bearing zone
consists of the lower 10 to 20 feet of the Liston Creek limestone and the upper 5 to 20 feet of the
Mississinewa shale. The Mississinewa shale underlying the site was not investigated during the field
investigation.
Groundwater flow and contaminant transport in the intermediate and lower water-bearing zones in the
vicinity of the CSSS are largely influenced by preferential flow through the fractured dolomitic limestone
bedrock underlying the site.
Based on water levels collected from monitoring wells screened within each of the three water-bearing
zones, groundwater flow is generally to the west; however, groundwater flow within each zone may vary
according to localized and regional influences. Groundwater flow in the shallow water-bearing zone
within the CSSS is locally toward the creeks. The shallow water table generally follows surface
topographic features. These generalities are true with the exception of the Lagoon Area where mounding
of the water table is present due to surface water recharge from the lagoons. This recharge results in
localized northerly flow along the north side of the Lagoon Area.
Groundwater flow in the intermediate water-bearing zone on the eastern two thirds of the site is due west.
High groundwater pumping rates at the Martin Marietta Quarry affect large areas of the intermediate and
lower water-bearing zones. Hydraulic influence from pumping at the Martin Marietta Quarry located west
of the Dixon Road Quarry is first observed in the vicinity of the Slag Processing Area. Groundwater flow
in the lower water-bearing zone appears to be to the northwest and west along the structural dip of the
bedrock.
A groundwater model was constructed to simulate the regional groundwater flow system in the vicinity of
the CSSS. The model was used to simulate interactions between groundwater and surface water and to
simulate influences from pumping wells (i.e., domestic wells, industrial wells, groundwater supply wells,
and dewatering wells at the Martin Marietta Quarry). The groundwater model was used to develop the
following conclusions:
• Contaminant transport of the intermediate and lower water-bearing zones in the vicinity of the
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CSSS is controlled by Martin Marietta Quarry pumping and shallow groundwater discharge to
surface water in the Wildcat and Kokomo Creeks;
• Groundwater flow pathways are confined to a central contaminant transport pathway following the
course of the Wildcat and Kokomo Creeks in the westerly direction. Transport pathways from site
source areas do not diverge significantly to the north or south of this main transport pathway; and
• Capture of contaminated groundwater originating on the CSSS by domestic wells in a residential
subdivision located southwest of the site is unlikely whether the quarry pumping is operational or
whether it is discontinued some time in the future.
Physiography
Topography across the site is generally level with an average ground surface elevation of 800 feet Mean
Sea Level (MSL). Along the stream valleys of Kokomo and Wildcat Creeks, surface topography slopes
gently or very steeply to an average surface water elevation of 780 feet MSL. In areas disrupted by
quarrying activities, typical topographic features are greatly modified. Slopes in the quarries range from
near vertical faces to gently sloping floors. The lowest point in the floor of the Dixon quarry is 745 feet
MSL. The floor of the Martin Marietta quarry is 680 feet MSL. The Haynes International Inc. facility's
landfill rises to an elevation of 830 feet MSL and the Slag Processing Area rises to an elevation of 840 feet
MSL.
Hydrology
The Kokomo area is drained by Wildcat and Kokomo Creeks, which are tributaries of the Wabash River.
Wildcat Creek flows through the center of the City of Kokomo in a westerly direction, winding through
and bordering three of the four properties consisting of the CSSS. The Wildcat borders the Main Plant
property to the west, the Lagoon Area to the south and west, and the Slag Processing Area to the south.
Kokomo Creek, one of three tributaries of Wildcat Creek, flows in a westerly direction along the south
side of the City and discharges to Wildcat Creek along the southwestern corner of the Main Plant (OU5).
This creek is confined by banks of 10- to 20-foot deep. The other two tributaries of Wildcat Creek are the
Kitty Run Drain, which flows northeasterly toward the southeast corner of the Dixon Road quarry and
then northerly along the quarry's eastern boundary, and Shambough Run which flows in a southerly
direction between the Slag Processing Area and the Lagoon Area. Kokomo Creek has one tributary in
the study area which discharges to an unnamed drain that flows northwesterly and discharges to Kokomo
Creek at the old Continental Steel bridge. This unnamed drain is 10 to 15 feet wide and has less than one
foot of water during base flow conditions. The Wildcat and Kokomo creeks extend some 20,000 feet
within the CSSS. These creeks have been impacted by direct discharge of material, runoff from the source
areas, and upstream industrial sources. The creeks are generally 50 to 100 feet wide, with depths up to
four feet. These creeks are designated for recreational use. A recreational corridor extends along most of
the banks of the creeks.
In the Kokomo area, the mean annual discharge of Kokomo Creek was 21.6 cubic feet per second (cfs),
and the mean annual discharge of Wildcat Creek was 230 cfs, according to the 1985 United States
Geological Survey. Under normal flow conditions, Kokomo Creek is generally 15 to 20 feet wide and
less than two feet deep, and Wildcat Creek is generally 30 to 50 feet wide and approximately 2.5 to five
feet deep. From the Phillips Street Bridge to the Markland Avenue Bridge, however, Wildcat Creek is an
average of 100 feet wide and three to four feet deep.
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The USGS evaluated the hydraulic connection between Kokomo and Wildcat Creek and the underlying
aquifer during 1981. Water levels were measured during two time periods for different sections of the
two creeks. For the time of the study, the results showed: stream gains for the stretch of Kokomo Creek
located south of the Main Plant; stream losses for the stretch of Wildcat Creek located west and north of
the Main Plant, and, depending on time, both gains and losses for Wildcat Creek downstream from the
influence of Kokomo and Wildcat Creeks. The study attributed losses from Wildcat Creek primarily to
large-scale withdrawals for dewatering of quarries and storage in reservoirs in or near Kokomo.
An initial evaluation of the creeks was conducted in May 1992 to identify areas of sediment deposition.
For this study, sediment was considered to be material that settled to the bottom of a body of water.
Principle constituents were soil particles transported by water or bedrock erosion and organic matter.
Little or no sediment was measured in the main channels of the creeks. In these areas, the stream bed
consisted of limestone bedrock. Sediment deposition appeared to be primarily along the inside bend of
stream meanders (i,e., point bars) and at locations where the stream velocity was slowed due to sudden
increase in cross-sectional area or depth.
Wastewater from Continental Steel was discharged through five outfalls, designated CS-01 through CS-
05 (ISPCB, 1985). Outfall CS-01, which has not been located, was previously the main processing
outfall before the installation of the filter plant. Upon installation of the plant, this outfall was
eliminated. Discharge at outfall CS-02 included non-contact cooling water from annealing, galvanizing,
and wire tinning; some process water from galvanizing; stormwater; and cooling tower water from the
melt shop. In 1984, a lift station was installed which pumped the wastewater from this line to the filter
plant. Outfall CS-02 then discharged to Kokomo Creek only during times when excessive quantities of
stormwater caused an overflow. Outfall CS-03 was an emergency overflow for untreated wastewater.
Outfall CS-04 discharged wastewater from the Lagoon Area. Acid-pickling wastewater was transferred
to the Lagoon Area where these wastewaters were neutralized, run through clarifiers and polishing
lagoons, and then discharged. Structure CS-05 served as both an outfall and a water intake. As an
outfall, CS-05 was the discharge point for filtered, non-contact cooling waters and process waters from
rolling, drawing, and annealing operations. As an intake, water was withdrawn daily from Wildcat
Creek.
Spill Incident Report records at IDEM indicate that 16 spills have occurred during the last 20 years
which resulted in chemical releases to either Kokomo or Wildcat Creek. The chemicals spilled were
primarily acid wastewater and oils from either Continental Steel or the Cabot Corporation.
Ecology
The U.S. Fish & Wildlife Services (USFWS) office in Bloomington, Indiana and the Indiana Department
of Natural Resources (IDNR) Division of Nature Preserves were contacted for a current listing of
occurrences of threatened or endangered species, and areas of critical or sensitive habitat in the vicinity of
the site. These trustee organizations identified the potential occurrence of both state- and federally-listed
species, as well as, areas of critical or sensitive habitat on or near the CSSS.
Due to the degraded quality and limited areal extent of potential habitats onsite, it is unlikely that
threatened or endangered species, or areas of critical or sensitive habitat occur onsite. However, data
recently obtained from the IDNR Natural Heritage Data Center indicates there is potential for occurrences
of state-endangered bobcat (Lynx rufus) and state threatened Butler's garter snake (Thamnophis butleri) in
the vicinity of the site. In addition, USFWS and IDNR identified the occurrence of federally-listed Indiana
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bat (Myotis sodalis) on Wildcat Creek outside of Howard County downstream from the site. Based on
information from IDNR, Wildcat Creek is at the center of this species summer range. Therefore, while
there is no record of Indiana bat occurring in the vicinity of the site, there is substantial evidence and
trustee support to conclude that this species may occur nearby and could potential migrate to the area under
proper conditions.
Technical Impracticability of Groundwater Restoration
Restoration of contaminated groundwater is one of the primary objectives of the Superfund program.
Groundwater contamination problems are pervasive; over 85% of Superfund National Priority List (NPL)
sites have some degree of groundwater contamination. A major purpose of the Superfund program is
protecting human health and the environment from contaminated groundwater and restoring those waters
to a quality consistent with their current, or reasonably expected future, uses.
The National Contingency Plan (NCP) provides the regulatory framework for the Superfund program. The
NCP states that EPA expects to return usable groundwater to their beneficial uses whenever practicable,
within a time frame that is reasonable given the particular circumstances of the site (NCP
§300.430(a)(l )(iii)
Generally, restoration cleanup levels in the Superfund program are established by applicable or relevant
and appropriate requirements (ARARs), such as the Federal or State drinking water standards in the case
of contaminated groundwater. Cleanup levels protective of human health and the environment are
identified and calculated by EPA where specific ARARs for a particular contaminant do not exist.
While the Superfund program has had tremendous success in reducing the immediate threats posed by
groundwater contamination, experience since the beginning of Superfund has shown that groundwater
restoration to drinking water quality (or other more stringent level) may not always be practicable or
possible to achieve. The following factors are used to determine the ability or capability (practicability) for
groundwater restoration: (1) Hydrogeologic factors, (2) Contaminant-related factors, and (3) Remediation
technology system limitations and inadequacies. Therefore, EPA must evaluate whether groundwater
restoration is possible or technically practicable. If EPA determines under Section 121(d)(4) of CERCLA
upon evaluating these factors that because of conditions at the site, certain ARARs cannot be achieved
(i.e., groundwater ARARs in the intermediate and lower aquifers), then EPA may issue a Technical
Impracticability (TI) Wavier.
The determination of the appropriateness of a TI waiver is being discussed for the intermediate and lower
water-bearing zones for site-wide groundwater at the CSSS. These groundwater zones describe the
bedrock strata which decreasingly fracture at depth. There is evidence of DNAPL in these water-bearing
zones in three source areas, the Markland Avenue Quarry, the Lagoon Area, and the Main Plant. Based on
hydrogeologic experience and fate and transport analysis, the effectiveness of DNAPL recovery in
fractured bedrock is at best on the order of 80 percent recovery of the DNAPL mass, even with an
aggressive scheme of groundwater collection. The basic issue for justification of the TI waiver is whether
it is technically practical to remediate groundwater within these zones such that groundwater ARARs can
be achieved in a reasonable time frame. The reasonable time frame to achieve ARARs has been
established by IDEM and EPA at 100 years.
By applying this information for the intermediate and lower groundwater aquifers to the above three
factors, it has been demonstrated to EPA and EPA concurs with the greater than 200 years to achieve
ARARs qualifies for use of the TI Wavier for these aquifers. The TI Wavier is also discussed in the
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Management of Migration (MM) Section, Operable Unit 1.
Nature and Extent of Contamination
Site-Wide Groundwater
Groundwater appears to have received contaminants from the Main Plant, the Markland Avenue Quarry,
the Lagoon Area and/or other areas related to the site, including disposal activities (i.e., spills) of
hazardous materials. Side-wide groundwater was investigated in two phases.
The objectives of the side-wide groundwater investigation are presented below:
Characterize groundwater flow, groundwater quality and contamination;
Delineate horizontal and vertical extent of contamination;
Document the horizontal and vertical extent of migration farther from the site;
Determine the various potential sources of contamination;
Evaluate the interrelationship among the three water-bearing zones; and
Provide information for the evaluation of appropriate remedial action alternatives
if necessary.
During Phase I the local aquifer system was separated into shallow and deep water-bearing zones. As a
result of Phase II groundwater investigations, careful examination of well logs, well construction and
associated water-level elevations and field determination while drilling, three water-bearing zones were
determined and referenced as the shallow'(760 feet MSL and up), intermediate (700 to 760 feet MSL),
and lower (660 to 700 feet MSL) water-bearing units.
Phase I groundwater investigations involved the installation of 35 monitoring wells in the shallow aquifer.
Additionally, eight Westbay MP System™ multi-level monitoring wells were installed, from which discrete
samples could be collected from all three water-bearing zones. Two rounds of groundwater sampling were
conducted the 1993 Phase I investigation. During the first round (May 1993), 69 locations were sampled
and field screened for VOCs and metals. Interpretation of these results provided an initial characterization
of shallow water-bearing zone contamination and served as the basis for further sampling. Second round
samples were collected in August 1993 at all newly installed and existing monitoring wells (96 locations).
Samples collected during the second round were submitted to the U.S. EPA Contract Laboratory Program
(CLP) for SVOC, PAH, VOC, PCB, pesticide and metal analysis. This data was used to evaluate the
horizontal extent of the groundwater contamination in the shallow water-bearing zone and to determine if
contaminants had migrated into the deeper water-bearing zones.
Phase II investigations included installation often new and four replacement monitoring wells. Water
level measurements, groundwater sample collection and aquifer parameter (hydraulic conductivity) testing
were performed at all newly installed monitoring wells. Groundwater elevations were measured at
accessible monitoring wells and samples collected from selected wells based on past results. Groundwater
results generated during the Phase II investigation are compared to Phase I results for the shallow,
intermediate and lower water-bearing zones. Groundwater samples were collected for laboratory analysis
from 13 of the newly installed wells and 52 previously installed wells. (See Appendix A, Figure Ib for
monitoring well locations)
Laeoon Area
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Remedial Investigation of the Lagoon Area was performed in two phases with the first being initiated in
1992. Samples were collected of lagoon surface water, lagoon sludge, soils underlying and adjacent to the
lagoons, waste piles, sludge within mixing and clarifier tanks at the treatment building, and water in the
basement of the treatment building. The second phase of the RI at the Lagoon Area, which was initiated in
1995, consisted of a soil gas survey in the entrance area and groundwater sampling.
The soil gas sampling and soil sampling (see Appendix A, Figure 2d) was conducted to investigate for
potential hot spots of volatile organic compound (VOC) contamination in soils and sludge at the lagoon
entrance area. Elevated concentrations of VOCs were detected in a shallow groundwater monitoring well
and soil/sludge samples during previous investigations in this area. Soil gas samples were analyzed by GC
for the following VOCs: trichloroethene, tetrachloroethene, 1,1-dichloroethene, trans- 1,2-dichloroethene,
cis-1,2-dichloroethene, 1,1,1 -trichloroethane, and vinyl chloride. 87 soil gas samples were collected in the
Lagoon Area.
Groundwater was sampled from twelve monitoring wells located upgradient, downgradient, and within the
Lagoon Area. Groundwater samples were collected from six monitoring wells screened in the shallow
water-bearing zone, four intermediate-water-bearing zone monitoring wells, and three lower water-bearing
zone monitoring wells. Groundwater samples were analyzed for VOCs, SVOCs, PAHs, PCBs, pesticides
and metals.
Kokomo and Wildcat Creeks
This section documents the Remedial Investigation of the Continental Steel Superfund Site (CSSS) and the
impacts the site has imparted on Kokomo and Wildcat creeks (OU3) in Kokomo, Indiana. Phase I of the
RI investigated the creeks including a study of creek water, creek sediment and shallow groundwater due
to their close proximity to the CSSS Main Plant, Lagoon and Slag Processing Areas. Phase of the RI
included sediments and surface water from Kokomo and Wildcat creeks and shallow groundwater from
monitoring wells adjacent to the creeks to accomplish the following: confirm previous results; further
characterize Kokomo and Wildcat Creeks surface water quality and sediment contaminant concentrations;
examine the interrelationship between shallow groundwater quality and creek sediment and surface water;
determine the potential impacts from the surrounding properties; and provide information for the
evaluation of remedial alternatives if necessary.
Surface water samples for the determination of the presence and extent of contamination within Kokomo
and Wildcat creeks surface water was performed via the collection of 27 samples during the Phase II RI.
Surface water samples were field screened for temperature, conductivity, turbidity, dissolved oxygen,
salinity, and redox potential. Additionally, surface water samples were analyzed for nitrate/nitrite as
nitrogen, ammonia, phosphorous, total dissolved solids, total suspended solids, and metals by the U.S.
EPA Central Regional Laboratory (CRL).
Sediment samples were collected after surface water sampling at each of the 27 locations (see Appendix A,
Figure 3b). Sediments were characterized to confirm existing information, delineate contaminants present,
determine the potential impacts from the contiguous properties, and design appropriate remedial actions.
Creek sediment samples were analyzed for VOCs, PAHs, PCBs, pesticides and total metals by the U.S.
EPA Contract Laboratory Program (CLP).
Groundwater was sampled from 12 shallow water-bearing zone monitoring wells located along Kokomo
and Wildcat Creeks to evaluate groundwater quality and the relationship between the shallow groundwater
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and hydraulically connected Kokomo and Wildcat creeks. Groundwater samples were analyzed by CLP
for VOCs, filtered and unfiltered metals, nitrate/nitrite as nitrogen, sulfate, chloride, mercury, alkalinity,
total phosphorous, total suspended solids, and total dissolved solids. Several samples were analyzed for
PAHs, PCBs, and pesticides.
Markland Avenue Quarry
Contaminant characterization required diverse media sampling for a wide range of contaminants to
delineate the extent, quantity, and type of contamination. Investigation objectives for Markland Avenue
Quarry were as follows:
• Pond water and sediment sampling to characterize potential groundwater
contaminant sources;
• Pond sediment sampling to identify and characterize the presence of dense non-aqueous
phase liquids (DNAPL);
• Surficial soil sampling from the backfilled area to evaluate the potential risk of wind
blown dust from this source;
• Residential soil sampling based upon quarry surficial sampling results to assist in
risk assessment;
• Geoprobe soil gas surveying to pinpoint potential contaminant "hot spots";
• Groundwater screening for confirmation at soil gas survey "hot spots"; and
• Groundwater sampling at existing and newly installed monitoring wells to
further characterize possible contaminant migration.
To characterize the contaminants in the quarry pond water, samples were collected for chemical analysis at
three depth intervals (labeled A, B and C for shallow, intermediate, and deep, respectively) within the pond
water column at three locations. Water column profile results for pH, temperature, dissolved oxygen, and
conductivity versus depth using a Grant/YSI Water Quality Monitoring System showed three distinct
stratified layers with respect to parameter changes. Samples were collected from each of the three layers
using a vertical bottle sampler and analyzed for VOCs, polynuclear aromatic hydrocarbons (PAHs),
polychlorinated biphenyls (PCBs), and metals. Confirmatory surface water samples were analyzed by the
U.S. EPA Contract Laboratory Program (CLP) for VOCs, SVOCs, PCBs, pesticides and target analyte list
(TAL) metals.
Characterization of quarry pond bottom sediments was accomplished by collecting and analyzing core
samples at nine locations. The non-cohesive nature of the sediment inhibited collection of a shallow and
deep sample and composite samples were collected instead. Quarry pond sediment composite samples
were analyzed for VOCs, PAHs, PCBs and metals. Confirmatory quarry pond sediment samples were
analyzed by the CLP laboratory for VOCs, SVOCs, PCBs, pesticides and Target Analyte List (TAL)
metals.
Markland Avenue Quarry surface soil samples were collected at 26 locations (see Appendix A, Figure 4c)
and analyzed for PAHs, PCBs and metals. Confirmatory surface soil samples were analyzed by the CLP
laboratory for SVOCs, PCBs, pesticides and TAL metals. Surface soil sampling was conducted at 10
residential locations and at two locations (RS-111, RS-112) in a proposed soccer field to determine the
presence or absence of surficial contamination resulting from wind borne transport of constituents from the
site. Sample results were used to provide input to the risk assessment. Laboratory analysis was identical to
that conducted on surface soil samples collected within Markland Avenue Quarry.
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A soil gas survey (see Appendix A, Figure 4b) was conducted to delineate the areal extent of potential
impact to the subsurface and to identify hot spots indicative of buried drums or pockets of product within
the fill. Eighty soil gas sampling locations were proposed in the Work Plan and FSP, utilizing a 100-foot
by 100-foot survey grid. A total of 77 soil gas samples were actually collected due to site conditions.
Access could not be obtained to seven of the proposed locations which were located southeast of Markland
Quarry in the Moore Drugs and Village Pantry parking lots. Eleven additional samples were collected in
areas where field gas chromatography (GC) results showed elevated concentrations of VOCs in the soil
gas. These samples were collected at 50 foot intervals centered on locations where elevated VOC
concentrations were detected to further delineate the hot spots within the Quarry. Figure 4d shows the 77
soil gas sampling locations. Soil gas sampling depths ranged from 2 to 10 feet below ground surface. Soil
gas samples were analyzed for trans- 1,2-dichloroethene, cis-l,2-dichloroethene, trichloroethene,
tetrachloroethene, vinyl chloride, 1,1,1-trichloroethane, and 1,1-dichloroethene. Groundwater sampling
was attempted at locations showing elevated soil gas contaminant concentrations. Due to the resistance of
the backfill (slag), sediment clogging the milled (slotted) rods, hole collapse and the absence of
groundwater at many of the selected locations, only 6 of the 23 geoprobe groundwater screening samples
were collected. The samples were analyzed for volatile organic compounds (VOCs) by the U.S. EPA Field
Analytical Services Program (FASP) laboratory.
One additional downgradient well, LA-101C, was installed at the western margin of the quarry to better
characterize the effects of contamination in the quarry on the local aquifer. Through comparison of
groundwater elevation and water quality results at the two existing downgradient wells (UA-06 and LA-
02) with results for new well LA-101C, the origin, extent, and presence of contamination could be more
fully evaluated. Monitoring well LA-101C was screened at the approximate depth of the quarry bottom
(78 to 88 feet in depth). Groundwater samples were collected from upgradient wells (LA-01 and UA-01)
and from UA-22 in the middle of the quarry (wells within the source area). Well locations are shown on
Figure 4e.
Main Plant
Main Plant investigations included inside and outside building inspections, confirmatory wipe sampling,
basement and sewer sampling, subsurface soil sampling, soil gas sampling, groundwater sampling,
residential surface soil sampling, and indoor air and high volume air sampling. All field activities and
sample collection were conducted according to the RI/FS Work Plan and Phase II Field Sampling Plan
(FSP).
Twenty confirmatory wipe samples of internal roofs, I-beams, floors, and walls were collected to evaluate
the effectiveness of the U.S. EPA gross decontamination of the buildings in reducing human health risks to
trespassers.
CDM collected indoor air samples with Alpha-1 personal air samplers from Buildings 112B, 11, 42 and
68. Indoor air samples were collected to assess potential inhalation impacts to workers or trespassers in the
Main Plant buildings. Additionally, high volume air samples were collected from locations in surrounding
residential neighborhoods to assess migration of fugitive dust from the Main Plant.
Basement water and sewer sediment samples were collected throughout the Main Plant area in October and
November 1995. Basement sample locations were chosen based on location (proximity to machinery and
transformers) and by visual inspection (sheen on water, evidence of submersed waste, debris, etc.).
Nineteen samples and three duplicate samples were collected during the field program and 18 samples and
the three duplicates were analyzed in the laboratory. Basement samples were analyzed by the Field
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Analytical Services Program (FASP) laboratory for volatile organic compounds (VOCs), polycyclic
aromatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs).
Six sewer sediment samples in the Main Plant were collected. The six samples and one duplicate sample
were submitted to the FASP laboratory for analysis of VOCs, PAHs, and PCBs. Metals analysis was
conducted by the Kemron laboratory. One confirmatory sample was analyzed by the CLP lab for target
organics and metals.
Using the results of the U.S. EPA surface soil study, a focused subsurface soil boring investigation was
implemented to delineate the vertical extent of impact at these stained locations (see Appendix A, Figure
5c). The boring program was designed to provide the information necessary to estimate the concentrations
and volume of contaminated soil. Thirty-three geoprobe soil borings were advanced to bedrock. Samples
were collected for VOC, SVOC, PCB, and metal analyses.
Soil gas sampling was conducted in an area formerly utilized as a waste slag disposalarea in the south
Main Plant (see Appendix A, Figure 5b). The soil gas survey was conducted to identify potential source
areas of VOC contamination in the vadose zone and VOCs in shallow groundwater. Soil gas samples were
analyzed using a portable gas chromatograph (GC) to provide real-time analysis for the following VOCs:
trichloroethene; tetrachloroethene; 1,1-dichloroethene; trans-1,2-dichloroethene; cis-l,2-dichloroethene;
1,1,1-trichloroethane; and vinyl chloride. Due to the inaccessibility of several of the proposed locations
and difficulty in penetrating the slag/fill, a total of 49 soil gas samples was collected at the Main Plant.
Groundwater was sampled from ten shallow aquifer monitoring wells located upgradient, downgradient,
and within the Main Plant area to evaluate groundwater quality and characterize possible downgradient
contaminant migration (see Appendix A, Figure Ib).
Surface soil samples were collected from the residential area located east of the Main Plant and from other
areas in the vicinity that may be receptors of airborne contaminants (see Appendix A, Figure 5d). This
work was performed to assess the risk to the surrounding residential area from windblown dust. Surface
soil samples were collected at 29 residential locations. Soil samples were collected at least 10 to 15 feet
from the residences and within the top six inches. Additional soil samples were collected from Highland
Park at the following locations: in the sandbox at the playground, from beneath the swing set, and from
exposed dirt at second base at the baseball field. Samples were analyzed for SVOCs (including PAHs),
PCBs, pesticides and metals.
Slag Processing Area
The investigation of the Slag Processing Area was conducted to characterize the possible contaminants in
the slag, to confirm or deny that drums with solvents have been buried in the backfilled area of the quarry,
to evaluate the potential impacts to Wildcat Creek and to help determine appropriate remedial action
alternatives. Field investigation objectives included performing an active soil gas survey and surficial
soil/slag sampling to characterize the areal extent of possible organic impact to subsurface media and to
identify potential contaminant hot spots that may indicate buried drums or pockets of product. Slag
Processing Area investigations included a soil gas survey, surface soil sampling, a site inspection, and
groundwater sampling.
38 soil gas sampling location were identified with 35 locations being sampled. The sampling locations
were developed utilizing a 100-foot by 100-foot survey grid. A geoprobe was utilized to perform the soil
gas survey. Optimally, the hydraulically operated soil gas probe was driven to a depth of 8 to 10 feet and a
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soil gas sample was collected from that depth. However, due to resistance encountered in the slag fill,
sampling depths ranged from 2.5 to 9.5 feet in depth.
Surficial soil/slag samples were collected for laboratory analysis to characterize potential impact to
surficial soils at the Slag Processing Area. Soil/slag samples were proposed to be collected based upon the
results of the site inspection and soil gas survey at areas suspected of having contamination representative
of the slag piles. However, ambient air field screening with a photoionization detector (PID) and soil gas
survey results showed only one detection of trichloroethene (1 mg/m3at SPSG-24). Therefore, surface
soil/slag samples were collected at that location and at randomly selected locations spanning the entire
area. A total of 10 surface soil/slag samples was collected at depths ranging from 4 to 14 inches.
Selected monitoring wells were sampled to evaluate groundwater quality within the Slag Processing Area.
Groundwater samples were collected from two monitoring wells. Samples were collected from the lower,
intermediate, and upper water-bearing zones.
Groundwater/Surface Water Contamination:
The primary contaminants detected in groundwater are VOCs. Generally, PAHs, PCBs, pesticides and
metals were limited to point detections at individual wells and site-wide plumes were not generally
identified except for a few metals. This is expected due to the relatively low mobility of the PAH and PCB
constituents and their method of introduction to the subsurface; usually disposal on the ground surface. In
1984, 1985 and 1986, IDEM identified chromium, cadmium, lead and iron in the on-site groundwater.
Site-Wide Groundwater
Potential water quality trends discussed within this section are based on the comparison of data from two
sampling events. Tetrachloroethene, trichloroethene, 1,2-dichloroethene and vinyl chloride are the primary
VOC constituents of concern identified during the remedial investigation. These compounds can be
related to each other through degradation processes.
The groundwater is impacted primarily by VOCs (trichloroethene, cis-1,2-dichloroethene and vinyl
chloride) in the Lagoon Area and to a lesser extent by metals. For the Lagoon Area proper, total VOCs
were highest at the Lagoon Area entrance in the shallow water bearing zone. This area was identified as a
hot spot during the soil gas survey. Within each water-bearing zone, VOC concentrations are highest in
the shallow water-bearing zone at the Lagoon Area entrance, in each at the intermediate water-bearing
zone wells underlying the Lagoon Area and in lower water-bearing zones at the downgradient well
locations. Total VOC concentrations appear to be decreasing significantly in the upper water-bearing
zones, but have remained about the same in the intermediate and lower water bearing zones.
Trichloroethene, cis- 1,2-dichloroethene and vinyl chloride are the primary water quality contaminants in
the shallow water-bearing zone. Cis-1,2-dichloroethene is primary water quality contaminant in the
intermediate and lower water-bearing zone, although trichloroethene and vinyl chloride are also
contaminants of concern in these zones.
VOC concentrations in both the shallow and the intermediate water-bearing zones appear to be quite stable
within the Lagoon Area boundary southwest of the lagoon ponds; however, concentrations of degradation
products appear to be increasing. This trend would indicate that groundwater contaminants are naturally
attenuating with time.
Metals present in the Lagoon Area groundwater that exceed MCLs include iron, manganese, nickel,
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chromium and antimony. Nickel was detected above MCLs at seven locations within the upper water-
bearing zone and at one location within the intermediate zone. The highest nickel concentration was 0.818
mg/L in the well located by the treatment tanks northwest of the lagoon ponds. Antimony was detected in
one sample each from the shallow water-bearing zone and from the intermediate water-bearing zone.
Chromium was detected for one sample from the shallow water-bearing zone.
The primary contaminants in the groundwater in the vicinity of Markland Avenue Quarry are
trichloroethene, cis-l,2-dichloroethene and vinyl chloride. Total VOCs for the Markland Avenue Quarry
area were highest in wells finished in the intermediate water-bearing zone downgradient from the quarry
pond. Degradation products cis-l,2-dichloroethene and vinyl chloride may be increasing within the
intermediate zone downgradient from Markland Avenue Quarry. Within each water-bearing zone, VOC
concentrations are highest in backfilled area (UA-22) in the shallow water-bearing zone; highest
downgradient of the quarry pond in the intermediate water-bearing zone and highest downgradient of the
quarry pond in the lower water-bearing zone. The lower water-bearing zone shows the lowest groundwater
impacts. No water quality trends are apparent within the lower water-bearing unit
The primary contaminants in the groundwater in the vicinity of the Main Plant are trichloroethene, cis-1,2-
dichloroethene and vinyl chloride. Total VOCs were highest in the Main Plant area in the intermediate
water bearing zone downgradient from the Main Plant, near Wildcat Creek. Based on the available
information from the Main Plant property groundwater investigations, it appears that total VOC
concentrations decreased with time in the shallow, intermediate and deep zones, however, vinyl chloride
increased in all three zones at the Main Plant. VOC concentrations are highest near the former spill area
on the west property boundary within the shallow, intermediate and lower water-bearing zones. These
results are consistent with the reported historical spill of trichloroethene in the vicinity of Building 112
(Nail Mill).
Primary contaminants in the groundwater in the vicinity of the Slag Processing Area are cis-1,2-
dichloroethene, and to a lesser extent, trichloroethene, and vinyl chloride. Total VOCs were highest in the
Slag Processing Area in the intermediate water-bearing zone (984 |ig/L), although total VOC
concentrations are generally highest in the upgradient well location. VOC concentrations appear to be
decreasing higher within the intermediate zone, increasing deeper within the intermediate zone and
decreasing within the lower water-bearing zone. Total VOC concentration were lowest in the shallow
water-bearing zone. (See Appendix D, Tables MM-IS, MM-II, & MM-1L for ranges of contaminants
discovered during RI).
Lagoon Area
The soil gas survey results indicate that several coalesced plumes of VOCs in the soil gas originate near the
lagoon entrance. Two plumes trend northwest and two plumes displaying lower concentrations are present
along the two roads to the south and east of the entrance, respectively. The primary VOCs detected in the
soil gas were cis-l,2-dichloroethene, trichloroethene and vinyl chloride. The groundwater data at the
entrance showed cis-1,2-dichloroethene (400ppb) and trichloroethene (710 ppb).
The downgradient well nest in the shallow water-bearing zone, in the intermediate water-bearing zone and
in the lower water-bearing zone showed detections of the same three primary VOCs as in the soil gas. The
proportion of trichloroethene to the two daughter products, cis-l,2-dichloroethene and vinyl chloride
decreased as expected likely due to the distance from the source and the age of the source. The lower
aquifer well is the most contaminated indicating that the plume is migrating downward as it moves
downgradient.
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The monitoring well located upgradient from the lagoon entrance also contained cis-l,2-dichloroethene,
trichloroethene and vinyl chloride in proportions similar to the soil gas results. The lower aquifer well at
this location contained low levels of the degradation products but no trichloroethene. This contamination
could be from the Main Plant or it could be indicative of another near surface source in the area.
The shallow water-bearing zone wells were sampled along the west side of the Lagoon Area. These wells
contained low levels of TCE degradation products. They are located downgradient from the drum removal
arek and it is possible that a contaminant plume has already moved through this area and the local source
has been removed. The intermediate level wells at this location show significantly higher concentrations of
degradation products, however no parent products, such as trichloroethene or tetrachloroethene were
detected. This would further support the theory that a plume has moved through and the local source is no
longer available to supply parent products to the groundwater. The lower water-bearing zone wells at this
location were clean.
Monitoring well EVV-18 along the west side of the creek was contaminated, showing almost a part per
million of total VOCs. This well may be influenced by Haynes facility rather than the Lagoon Area since
it is screened above the stream elevation, has tetrachloroethene present in the well and is upgradient in the
shallow water-bearing zone.
The data indicates that no BNAs, PCBs or pesticides were detected in groundwater samples collected.
These compounds are present in the lagoon soils and sediments; however, they do not migrate readily from
the solids into the groundwater.
There are three metals present in the Lagoon Area groundwater that exceed maximum contaminant levels
(MCLs). These metals are nickel, iron and manganese. According to the data for lagoon soils and
sediments, iron and manganese were consistently present in the soils at high levels. Nickel, while
consistently detected was not present at as high levels, however it may have been disposed in a more
soluble form. The other metal that was present consistently was lead. However, lead was not detected in
the lagoon groundwater above MCLs. (See Appendix D, Tables LA-IS, LA-II, & LA-1L for ranges of
contaminants discovered during RI).
Kokomo and Wildcat Creeks
Surface water inorganic concentrations are compared to background concentrations and surface water
benchmark values taken from Indiana Water Quality Standards (327 I.A.C 2-1-6) and U.S. EPA Ambient
Water Quality Criteria (Fresh Chronic Criteria) (U.S. EPA 1992). A detailed discussion of surface water
results in comparison to background concentrations and surface water benchmark values is found in the
ecological assessment sections of the baseline risk assessment report. Background surface water values
were collected at locations upstream from the CSSS on both Kokomo and Wildcat Creeks and from the
minor tributaries feeding each creek.
Field filtered samples are defined as dissolved concentrations and unfiltered samples are defined as total
concentrations. The following discussion examines surface water results by reach that exceed benchmark
values. (See Appendix D, Table C-1S for ranges of contaminants discovered during RI).
Re_ach 1
Seven dissolved metals and nine total metals were detected above quantitation limits in Reach 1 surface
water samples. Only copper and lead exceeded the surface water benchmark criteria.
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Reach 2
Eight dissolved metals and eight total metals were detected above quantitation limits in Reach 2 surface
water samples. Only one sample contained total copper and lead concentrations slightly above surface
water benchmark criteria.
Reach 3
Ten dissolved metals and eleven total metals were detected above quantitation limits in Reach 3 surface
water samples. Total copper was detected above surface water benchmark values for all surface water
samples collected from Reach 3 of Wildcat Creek. Lead was also detected at a concentration only slightly
above surface water benchmark criteria.
Reach 4
Five dissolved metals and ten total metals were detected above quantitation limits in Reach 4 surface water
samples. Copper, lead and mercury were detected above surface water benchmark values in Reach 4 of
Kokomo Creek.
Reach 5
Ten dissolved metals and eleven total metals were detected above quantitation limits in Reach 5 surface
water samples. All surface water samples from Reach 5 contained total copper at concentrations slightly
above surface water benchmark criteria. Lead was detected above surface water benchmark values in five
of the seven surface water samples. Mercury was detected in only one sample at a concentration in excess
of the benchmark criteria.
Reach 6
Six dissolved metals and seven total metals were detected above quantitation limits in Reach 6 surface
water samples. Only lead was detected above surface water benchmark values in one-third of the samples
collected from Reach 6 of Wildcat Creek.
Copper and lead were detected in excess of benchmark criteria in all reaches of the creeks except Reach 6
where only lead was present. Additionally, mercury was found in excess of the benchmark criteria in
Reach 4 and 5. Overall, these detected concentrations were generally at or minimally above the benchmark
criteria.
Comparison of Phase II RI with Phase I RI creek surface water sample data produced a good correlation
except for several analytes. Phase II surface water total copper results were generally higher in Reaches 2-
5 than Phase I copper results (except for Reach 1 where Phase I detected copper and Phase II had a non-
detect). Similarly, lead was detected in Phase II Reach 6 samples above the benchmark criteria but was not
detected in Phase I Reach 6 samples.
Inorganic and organic concentrations in groundwater collected from shallow water-bearing units around
Kokomo and Wildcat Creeks are compared to U.S. EPA MCLs.
Reach 1 and 2
Results show no VOC metal concentrations above the MCLs.
Reach 3
Slightly elevated levels of VOCs were detected at the southwest corner of the Lagoon Area (EW-11) and at
the southeast corner of the Haynes facility Deffenbaugh Street Operations (DSO) North landfill (EW-18 ).
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Monitoring well EW-11 contained concentrations of cis-l,2-dichloroethene (19 ug/L) and vinyl chloride
(29 ug/L) in excess of the MCLs. This well is located downgradient of the former drum disposal area and
it is possible that a contaminant plume has already moved through this area and the local source has been
removed. Since the contaminants present are degradation products and no parent products are present, the
hypothesis that a local source is no longer available to supply the parent VOCs to the groundwater is
further supported. EW-18 groundwater results show elevated levels of tetrachloroethene (350 ug/L),
trichloroethene (140 ug/L), cis-l,2-dichloroethene (380 ug/L), 1,1-dichloroethene (7 ug/L) and vinyl
chloride (110 ug/L).
Elevated concentrations of nickel were detected at 212 ug/L and 875 ug/L.
Reach 4
No VOCs or metals were detected in excess of MCLs.
Reach 5
VOCs were detected in shallow water-bearing zone monitoring wells UA-32 and UA-24 west of the CSSS
Main Plant Area in Reach 5 of Wildcat Creek. Elevated levels of trichloroethene and its degradation
products, cis-1,2-dichloroethene and vinyl chloride, were detected in UA-32 and UA-24. 1,2-
Dichloroethane was detected in UA-24 at a concentration of 2,000 ug/L. These results are consistent with
the reported historical spill of trichloroethene in the vicinity of Building 112B (nail mill) located at the
northwest margin of the Main Plant.
UA-11 contained only one metal, lead (17 ug/L), in excess of the MCLs (15 ug/L). No other metals were
detected in the groundwater samples collected from the monitoring wells located in Wildcat Creek Reach
5.
Reach 6
VOCs were detected in all three shallow water-bearing unit monitoring wells, UA-28, UA-29 and LA-03A
within this Reach of Wildcat Creek. VOCs exceeding the MCLs included tetrachloroethene and its
degradation products trichloroethene, cis-1,2-dichloroethene and vinyl chloride. Tetrachloroethene was
detected at elevated concentrations in UA-28 (600 ug/L), UA-29 (48 ug/L) and LA-03A (5 ug/L).
Trichloroethene was detected in UA-28 and UA-29 at concentrations of 370 u.g/L and 14 ug/L,
respectively. Cis-1,2-dichloroethene and vinyl chloride were detected at elevated concentrations in all
three shallow water-bearing unit monitoring wells.
Groundwater sample analysis did not include SVOCs, PCBs and pesticides. However, shallow water-
bearing zone groundwater was sampled for metals and no metals were detected above MCLs along Wildcat
Creek Reach 6.
Shallow water-bearing zone monitoring wells located in Wildcat Creek Reaches 3, 5 and 6 contained
elevated levels of VOCs due to the industrial activity and documented spills within those areas.
Groundwater contamination likely stems from known and suspected surface spills (sources) which migrate
through the sediment and into the shallow groundwater, rather than from the seasonally changing hydraulic
connection with the creeks.
Markland Avenue Quarry
Upgradient wells UA-03 and UA-27 (see Appendix A, Figure Ib) were unimpacted based on the 1993
data and were not resampled in 1995. The other two upgradient wells, UA-01 and LA-01 were also not
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impacted by contaminants from the quarry based on1993 and 1995 sets of data. There were low level
detections of pesticides in both wells that are below the groundwater screening criteria. As pesticides were
not a contaminant of concern for this area they were not resampled. Low level detections of acrylonitrile in
LA-01 in the lower aquifer were discovered. The source of this VOC is unknown.
The groundwater screening samples collected during the soil gas surveys do not provide sufficient
coverage to fully evaluate vertical extent of contamination at the source areas. Most locations where
sampling was successful were in the central, most impacted area. The groundwater analytical results at this
location indicate trichloroethene and cis-l,2-dichloroethene at a depth of 10 feet below ground surface at
concentrations up to 3,000 ug/L and 33,000 ug/L, respectively and only ppb (parts per billion) level
trichloroethene at depths of 28 and 35 feet below ground surface.
The monitoring wells located within the quarry fill and downgradient contained primarily VOCs, including
trichloroethene, cis-l,2-dichloroethene and vinyl chloride. 1993 and 1995 data are consistent, with the
prevalence of degradation products increasing in the 1995 samples. This would be expected over time as
the degradation of the contaminants progresses.
Groundwater analytical results were collected from shallow depths at sample locations GW-35, GW-52,
GW-85, GW-86, GW-87 and GW-88 (see Appendix A, Figure Ib) and indicated trichloroethene, benzene,
toluene, ethylbenzene and xylene (BTEX) at concentrations up to 3,000 ug/L (Trichloroethene)(see
Appendix D, Table MAQ-7S). The presence of the BTEX compounds within the fill indicate that light
petroleum products similar to gasoline were also disposed in-the fill area. Shallow groundwater at the
central impact area is present at a depth of approximately eight feet.
The intermediate zone (see Appendix D, Table MAQ-7I) appears to be the most contaminated as
evidenced by the data from LA-02 at 72 feet and LA-101C at 100 feet. The degradation product cis-1,2-
dichloroethene is present at a part per million with ppb levels of trichloroethene, indicating that
degradation is well progressed outside of the quarry fill area. The other downgradient well, UA-04, is
unimpacted, likely because the well is not screened in a fracture zone as indicated by a slow recharge rate.
Furthermore, UA-04 is a shallow well with a depth of only 13 feet. Most contaminants at the site are
denser than water and would be expected to be present at greater depths.
It is likely that contamination from the quarry sediment and surface water is migrating into the
groundwater and moving downward as it moves to the west with groundwater flow. Any DNAPL that
migrates out of the pond would follow preferential flow pathways such as fractures or a confining layer
and be influenced more by gravity than by flow direction. The ppm (parts per million) levels of
degradation product likely indicate an older slug of contamination moving through the intermediate aquifer
just outside the quarry boundary.
The groundwater data is in good agreement with the constituent detected in soil gas, surface water and
sediment data. Trichloroethene is the primary contaminant detected in the source areas with degradation
products becoming more prevalent with depth and distance from the source. (See Appendix D, Markland
Avenue Quarry Tables for ranges of contaminants discovered during RI).
Based on surface water stratification profiling results collected in early November 1995 it appeared the
pond was in the process of turnover. The warmest temperatures were observed at depths of 30 to 38 feet in
the middle of the water column. These temperature measurements indicate thermal mixing or turnover has
occurred. Comparison of samples SW-01B and SW-01C collected November 1, 1995 to SW-01B and
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SW-01C collected November 13, 1995 indicate a decrease in concentration at these intervals by an order of
magnitude which may be a result of mixing. Stratification of contaminants is more pronounced in the
earlier samples which also supports the observation that mixing occurs in the pond. Sample results for
SW-01A collected November 1, 1995 at a depth of one foot indicate 59 ug/L of trichloroethene at the pond
surface which confirms that volatilization may be occurring from the pond surface. The presence of
trichloroethene at the pond surface confirms that mixing or distribution of VOCs occurs in the pond and
sample concentrations confirm that contaminants are leaching from the pond sediments or adjacent fill into
the pond surface water.
The surface water samples show a distinct pattern of VOC contamination, trending from lower
concentrations to higher concentrations with depth. The primary VOC detected was trichloroethene, with
low level detections of the degradation product cis-l,2-dichloroethene. VOC contamination in the pond is
likely a result of a combination of migration of contaminated groundwater from the adjacent fill area where
trichloroethene is the primary VOC detected and dissolution from VOC contamination in the pond
sediments. The stratification of contamination is likely due to the nature of the VOCs impacting lower
depth of water from the bottom sediments. The detected VOCs have a specific gravity greater than 1 (the
specific gravity of water) which results in an accumulation of the VOCs in lowest parts in the pond. As
these compounds enter the dissolved phase, they tend to stay near the bottom unless influenced by seasonal
turnover in the pond. As the VOCs near the surface, their concentration will be decreased through
volatilization and UV (ultraviolet) oxidation from sunlight. Dissolved oxygen and conductivity
distributions indicate aerobic degradation is occurring to depths of approximately 30 feet and that aerobic
biodegradation is occurring at low rates below 30 feet. Some evidence of biodegradation was observed at
depth, but is likely being impeded by the high pH in the pond water.
The pond surface water did not contain any PAHs or PCBs and only three metals were detected but the
levels are below the benchmark screening levels for surface water. PAHs and PCBs are relatively
insoluble and are not likely to leach into the surface water. The solubility of metals is strongly dependent
on pH, redox potential, and the presence of both complexing ligands and adsorbing surfaces. The pH of
the Markland Avenue Quarry surface waters was observed to range from 11.4 to 12.6. At a pH range of
11.4 to 12.6, arsenic, barium, chromium, nickel and zinc may form either soluble metal complexes
(depending on the environment) or insoluble hydroxides, carbonates, sulfide, sulfates or arsenates.
Cadmium, copper and lead will typically form complexes with low solubilities. The presence of arsenic,
barium and zinc in the surface water may indicate that some of the soluble complexes of these metals have
been formed while lead chromium and copper are likely present in a less soluble form.
Main Plant
VOCs were detected in several samples along the west side of Building 112 and 112B (monitoring wells
LA-04, LA-05, UA-12 and UA-24)(see Appendix A, Figure Ib). These VOCs include trichloroethene and
its degradation products. 1,2-Dichloroethene was detected in LA-04A at 2,000 ug/kg. Trichloroethene
was detected in monitoring wells LA-04, UA-24 and UA-32 at elevated concentrations ( 2,000 ug/kg).
Vinyl chloride was detected from 46-71 ug/kg in samples collected from LA-04, LA-05 and UA-24.
These results are consistent with the reported historical spill of trichloroethene in the vicinity of Building
112 (nail mill) and indicate that trichloroethene has entered the bedrock and is migrating along fractures
and in groundwater. Concentrations of cis- and trans-1,2-dichloroethene, trichloroethene and vinyl
chloride are highest in the shallow water-bearing zone which is consistent with a surface spill source and
the observed results for soil boring samples in the vicinity. PCBs were detected in only one groundwater
sample (UA-21). Aroclor -1242 was detected at 4.5 ug/L, however, the CLP confirmatory sampling
identified Aroclor-1248 at a concentration of 6.4 ug/L. Dissolved metals were not detected above MCLs
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in groundwater samples collected at the Main Plant. (See Appendix D, Tables MP-5S & MP-5I for ranges
of contaminants discovered during RI).
Slag Processing Area
No VOCs were detected in the shallow water-bearing zone with the exception of cis-l,2-dichloroethene
(UA-17) at the method detection limit of 1 ug/L. Total VOCs were highest in the intermediate water-
bearing zone at 984 ug/L. The VOCs detected included significant concentrations of trichloroethene (140
ug/L), cis-l,2-dichloroethene (800 ug/L) and vinyl chloride (34 ug/L). Low concentrations of cis-1,2-
dichloroethene and 1,1-dichloroethane were detected in the lower water-bearing zone as well as
acrylonitrile at a concentration of 150 ug/L. VOC concentrations appear to be decreasing higher within the
intermediate zone and may be increasing deeper within the intermediate zone. Total VOC concentrations
were higher 67 feet deep than 52 feet deep. Total VOC concentration were lowest in the shallow water-
bearing zone. This vertical distribution of VOCs indicates impact from VOCs likely originates from
upgradient rather than from the immediate vicinity of the well at the Slag Processing Area. VOCs were not
detected above screening levels in the shallow water-bearing zone during either Phase I or II sampling
events. VOC concentrations appear to be decreasing in the lower water-bearing zone. (See Appendix D,
Tables SP-2S, Sp-2I, & SP-2L for ranges of contaminants discovered during RI).
Soil/Sediment Contamination:
Lagoon Area
Trans-1,2-dichloroethene was detected in'five soil gas samples collected in the Lagoon Area at
concentrations as high as 19 milligram per cubic meter (mg/m3). Twenty-six soil gas samples contained"
cis-1,2-dichloroethene, with the highest concentration being 540 mg/m3. Tetrachloroethene and
trichloroethene were detected in 10 and 40 of the Lagoon Area soil gas samples, respectively.
Concentrations of tetrachloroethene were as high as 14 mg/m3. Trichloroethene was detected at
concentrations of 640 mg/m3. Vinyl chloride was detected at concentrations reaching 510 mg/m3. One soil
gas sample contained 1 mg/m3 of 1,1,1 -trichloroethane. Concentrations of 1,1 -dichloroethene were
detected in four samples at concentrations reaching 10 mg/m3. No other VOCs were detected in soil gas
samples collected in the Lagoon Area. (See Appendix A, Figure 2d for soil gas sampling locations).
One subsurface soil sample was collected from the Lagoon Area near the entrance. Toluene was detected
in this subsurface soil sample at the concentration of 2 ug/kg. No other VOCs were detected. No BNA
(SVOC) compounds were detected. Heptachlor epoxide and 4,4'-DDT were detected at concentrations of
2.3 ug/kg and 19 ug/kg, respectively. No other pesticide compounds and no PCBs were detected.
Analysis for metals produced the following results. Aluminum, antimony and arsenic were detected at
concentrations of 6,600 mg/kg, 8.6 mg/kg and 1.5 mg/kg, respectively. Barium, beryllium and calcium
were detected at concentrations of 82.2 mg/kg, 0.65 mg/kg and 171,000 mg/kg, respectively. Chromium,
cobalt and copper were detected at concentrations of 2620 mg/kg, 14.3 mg/kg and 200 mg/kg, respectively.
Iron, lead and magnesium were detected at concentrations of 170,000 mg/kg, 2.4 mg/kg and 20,700 mg/kg,
respectively. Manganese, nickel and silver were detected at concentrations of 34,800 mg/kg, 112 mg/kg
and 61.5 mg/kg. Sodium, vanadium and zinc were detected at concentrations of 291 mg/kg, 203 mg/kg
and 268 mg/kg, respectively. No other metals were detected in the subsurface soil sample from the Lagoon
Area.
An evaluation of the data for the waste piles in the Lagoon Area indicated that four waste piles contained
at least one contaminant at elevated levels, for an estimated contaminated material volume of 149 cubic
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yards. In the lagoons, an estimated total of 641,000 cubic yards of material was determined to contain
elevated levels of contaminants. The sludge drying beds have by far the deepest contamination extending
20 feet below the surface. The acid lagoons had elevated levels of contaminants to a depth of about five
feet. The polishing lagoons had elevated levels at depth varying typically from 10 feet below surface in the
central portion to about five feet in the southern portion. Contamination throughout the lagoons includes,
VOCs, PAHs, PCBs, chromium, lead and zinc.
Kokomo and Wildcat Creeks
Kokomo and Wildcat Creeks sediment inorganic and organic concentrations are compared to background
concentrations and sediment benchmark values taken from the following sources in order of priority: U.S.
EPA SQC (U.S. EPA 1993), Persaud et al. (1993), NYSDEC (1993) and NOAA (1994). Prioritization of
this list occurred through consultation with U.S. EPA Region V. A detailed discussion of creek sediment
results in comparison to background concentrations and sediment benchmark values is found in the
ecological assessment sections of the risk assessment report.
The following sections examine the creek sediment concentration accedences of both background and
benchmark criteria. Due to the large number of creek sediment samples that exceed the background and
benchmark criteria and the importance of denoting the magnitude of each accedence, parameters, in the
following discussion, are described as slightly (0 to 3 times), moderately (3 to 10 times), and greatly (> 10
times) exceeding the background and benchmark criteria. VOCs for which no benchmark values are
available include: 2-butanone, carbon disulfide, toluene, total 1,2-dichloroethane, trichloroethane, and
vinyl chloride. A benchmark value was also not available for thallium. (See Appendix A, Figure 3b for
sediment sampling locations).
Reach 1
No VOCs exceed the sediment background or benchmark criteria for Reach 1 of Wildcat Creek.
•Fluoranthene is the only PAH that slightly exceeds the background sediment value. Aroclor 1248, 1254
and 1260 greatly exceed the background and benchmark criteria for Reach 1 of Wildcat Creek.
The following pesticides greatly exceed the background criteria: 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, aldrin,
dieldrin, endrin, endrin aldehyde, gamma-chlordane, heptachlor, and heptaclor epoxide.
4,4'-DDE, 4,4'-DDT, aldrin, gamma-chlordane, heptachlor and heptaclor epoxide greatly exceed the
benchmark criteria. 4,4,'-DDD, dieldrin and endrin aldehyde moderately exceed the benchmark criteria.
Endrin slightly exceeds benchmark criteria.
The following metals greatly exceed the background criteria: arsenic, cadmium, chromium, cobalt, copper,
iron, lead, nickel and zinc. Barium, mercury, selenium, silver and thallium moderately exceed background
criteria. Aluminum, beryllium, manganese and vanadium were slightly over the background criteria.
Aluminum, arsenic, barium, cadmium, chromium, copper, iron, lead, nickel, silver and zinc greatly exceed
the benchmark criteria. Mercury and selenium moderately exceed the benchmark criteria. Cobalt and
manganese slightly exceed the benchmark criteria.
Reach 2
No VOCs or SVOCs exceed the background and benchmark criteria for Reach 2 of Wildcat Creek.
Fluoranthene is the only PAH to slightly exceed the background value and anthracene is the only PAH to
slightly exceed the benchmark criteria. Aroclor-1248, 1254 and 1260 greatly exceed both the benchmark
criteria and the background criteria.
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The following pesticides in Reach 2 greatly exceed both the benchmark and background values:
4,4'-DDE, 4,4'-DDT and aldrin. The concentrations of endrin aldehyde and dieldrin greatly exceed
background criteria. The concentrations of gamma-chlordane and heptachlor greatly exceed benchmark
criteria. The concentration of gamma-chlordane and heptachlor epoxide moderately exceed the
background values. Endrin aldehyde is only slightly higher than the benchmark value.
The following inorganics were found above the benchmark and the background criteria: arsenic, barium,
cadmium, chromium, copper, lead, manganese, nickel and zinc. Aluminum and cadmium greatly exceed
benchmark criteria. Cadmium, chromium and lead were moderately above the background criteria.
Arsenic, barium, copper, manganese, nickel and zinc are only slightly above both background and
benchmark criteria. Cobalt, iron and vanadium are slightly above only background criteria. Benchmark
criteria are slightly exceeded by chromium, lead and silver.
Reach 3
Toluene slightly exceeds the background criteria for Reach 3. The SVOC, 4-methylphenol, is moderately
above the background and greatly above the benchmark criteria.
The following compounds moderately exceed the background limit values for Reach 3: benzo (a)
anthracene, benzo (a) pyrene, benzo (b) fluorantherie, benzo (k) fluoranthene, chrysene, fluoranthene,
phenanthrene, pyrene. Anthracene, benzo (g,h,i) perylene and indeno (l,2,3-c,d) pyrene slightly exceed
the background criteria.
Benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i) perylene, benzo (k)
fluoranthene, chrysene, dibenzo (a,h) anthracene, indeno (l,2,3-c,d) pyrene and pyrene moderately exceed
the benchmark criteria. Acenaphthene, anthracene and phenanthrene slightly exceed the benchmark
criteria.
The following PCBs greatly exceed the background criteria for Reach 3: Aroclor-1248, Aroclor-1254 and
ArocIor-1260. Aroclor-1016 moderately exceeds the background limit value. The benchmark values were
greatly exceeded by Aroclors-1016, 1248, 1254 and 1260.
The following pesticides greatly exceed the background criteria for Reach 3: 4,4'-DDE, 4,4'-DDT, aldrin,
dieldrin, gamma-chlordane and heptachlor epoxide. Alpha-chlordane, endrin, endrin aldehyde and
gamma-BHC (lindane) exceed the background criteria by a moderate amount. The benchmark limit values
were greatly exceeded by the following pesticides: 4,4'-DDE, 4,4'-DDT, aldrin, gamma chlordane and
heptachlor epoxide. Gamma-BHC (lindane) moderately exceeds the benchmark limit value. Alpha-
chlordane and dieldrin slightly exceed the benchmark criteria.
The following metals greatly exceeded the background criteria for Reach 3: cadmium, chromium, copper,
iron, lead, nickel and zinc. Cobalt, manganese, and thallium moderately exceed the background criteria.
Aluminum, arsenic, barium, beryllium, mercury, selenium and vanadium slightly exceed the background
criteria. The benchmark criteria was greatly exceeded by the following metals: aluminum, cadmium,
chromium, copper, lead, nickel and zinc. The metals that moderately exceed the benchmark criteria are as
follows: arsenic, barium, iron and silver. Manganese, mercury and selenium slightly exceed the
benchmark criteria.
Reach 4
Benchmark criteria are greatly exceeded and background criteria moderately exceeded by 2-
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methylnapthalene. Bis (2-ethylhexyl) phthalate moderately exceeds the benchmark criteria in Reach 4 of
Kokomo Creek. No other SVOCs and no VOCs exceed the background or benchmark criteria.
The following PAHs greatly exceed both sediment background and benchmark criteria for Reach 4:
acenapthene, anthracene, benzo (a) anthracene, benzo (a) pyrene, benzo (b) fluoranthene, benzo (g,h,i)
perylene, benzo (k) fluroanthene, chrysene, dibenzofuran, fluorene, indeno (1,2,3-cd) pyrene, naphthalene,
phenanthrene and pyrene. Carbazole greatly exceeds the background value but a benchmark value is not
available. Dibenzo(a,h)anthracene moderately exceeds background criteria and fluoranthene moderately
exceeds benchmark criteria.
PCBs that greatly exceed benchmark and background criteria include Aroclor-1016, Aroclor-1248,
Aroclor-1254 and Aroclor-1260.
Aldrin and gamma-BHC (lindane) greatly exceed the sediment background criteria for Reach 4. 4,4'-DDE
and alpha-chlordane moderately exceed and gamma-chlordane slightly exceeds creek sediment background
criteria. Aldrin, endosulfan II and gamma-BHC (lindane) greatly exceed the sediment benchmark criteria.
4,4'-DDE and alpha-chlordane moderately exceed and gamma-chlordane slightly exceeds creek sediment
benchmark criteria.
The following metals greatly exceed the sediment background criteria for Reach 4: cadmium, chromium,
copper and zinc. Barium, cobalt, iron, lead and nickel moderately exceed the background criteria.
Aluminum, manganese, mercury and vanadium slightly exceed the background criteria for Reach 4.
Aluminum, cadmium and copper greatly exceed the sediment benchmark criteria for Reach 4. Barium,
chromium, lead, nickel and zinc moderately exceed the sediment benchmark criteria. Iron, mercury and
manganese only slightly exceed the inorganic benchmark criteria.
Reach 5
Vinyl chloride and total 1,2-dichloroethane greatly exceed the background criteria. Carbon disulfide
slightly exceeds the background criteria. Acetone slightly exceeds the benchmark criteria. No other VOCs
exceed the background or available benchmark criteria.
4-Methylphenol greatly exceeds benchmark values. Bis (2-ethylhexyl) phthalate and 2-methylnapthalene
moderately exceed the benchmark criteria. No other SVOCs exceed the background or benchmark criteria
in Reach 5.
Pyrene was the only PAH to greatly exceed the both the background and benchmark criteria in this reach.
Phenanthrene greatly exceeds only the background criteria. Benzo (a) anthracene, benzo (b) fluoranthene,
chrysene and fluoranthene moderately exceed the background criteria. PAHs slightly exceeding
background criteria include: anthracene, benzo (a) pyrene, benzo (k) fluoranthene, carbazole and fluorene.
PAHs moderately exceeding benchmark criteria include acenapthene, anthracene, benzo (a) anthracene,
benzo (a) pyrene, benzo (b) fluoranthene, chrysene, and fluorene. Benzo (k) fluoranthene, indeno (1,2,3-
cd) pyrene, naphthalene and phenanthrene only slightly exceed the benchmark criteria.
The following PCBs greatly exceed both sediment background and benchmark criteria for Reach 5:
Aroclor-1260, Aroclor-1254, Aroclor-1248 and Aroclor-1016.
The following pesticides greatly exceed the background criteria for Reach 5: 4,4'-DDD, 4,4'-DDE, 4,4'-
DDT, aldrin, dieldrin, endosulfan II, endrin aldehyde, gamma-BHC (lindane) and gamma-chlordane. The
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following constituents greatly exceeded the benchmark criteria: 4,4'-DDE, 4,4'-DDT, aldrin, endosulfan II,
gamma-chlordane and gamma-BHC (lindane). Alpha-chlordane moderately exceeds background criteria.
Endrin aldehyde and 4,4'-DDD moderately exceed the benchmark criteria. Dieldrin and alpha-chlordane
slightly exceed the benchmark criteria.
The following metals greatly exceed the background criteria for Reach 5: antimony, cadmium, chromium,
copper, iron, lead, mercury, nickel, silver and zinc. The background criteria were moderately exceeded by
these metals: arsenic, barium, cobalt, manganese and vanadium. Aluminum and beryllium slightly exceed
the background criteria. The following metals greatly exceed the benchmark criteria for Reach 5:
aluminum, antimony, barium, cadmium, chromium, copper, lead, mercury, nickel, silver and zinc. Arsenic
and iron moderately exceed the benchmark criteria. Manganese slightly exceeds benchmark criteria for
Reach 5.
No VOCs exceed the background or benchmark sediment criteria.
Butylbenzyl phthalate moderately exceeds and bis (2-ethylhexy!) phthalate slightly exceeds the benchmark
criteria. No other SVOCs exceed the background or benchmark criteria.
Pyrene, a PAHs detected in creek sediments, greatly exceeds background criteria. Benzo (a) anthracene,
benzo (a) pyrene, benzo (b) fluroanthene, benzo (k) fluoranthene, fluoranthene, chrysene and phenanthrene
moderately exceed background criteria. Anthracene, benzo (g,h,i) perylene, and indeno (l,2,3-c,d) pyrene,
slightly exceed background criteria.
Acenapthene, benzo (b) fluoranthene, and pyrene greatly exceed creek sediment benchmark criteria.
Benzo (a) anthracene, benzo (a) pyrene, benzo (k) fluoranthene, benzo (g,h,i) perylene, indeno (1,2,3-cd)
pyrene and chrysene moderately exceed the benchmark criteria. Anthracene and fluorene slightly exceed
the benchmark criteria.
Aroclor-1016, Aroclor-1254 and Aroclor-1260 greatly exceed the PCB background criteria for creek
sediments. Aroclor-1248 moderately exceeds background criteria. All of the detected PCBs, Aroclor-
1016, Aroclor-1248, Aroclor-1254 and Aroclor-1260, greatly exceed the PCB benchmark values in at least
one sample from Reach 6.
The following pesticides, aldrin, alpha-chlordane and gamma-BHC (lindane) greatly exceed the sediment
background criteria for Reach 6 of Wildcat Creek. 4,4'-DDE and endrin aldehyde moderately exceed the
pesticide background criteria. Gamma-chlordane, endrin, endosulfan II and 4,4'-DDT only slightly exceed
the pesticide background criteria. Aldrin, alpha-chlordane, gamma-BHC (lindane) and endosulfan II
greatly exceed the sediment benchmark criteria. 4,4'-DDE only moderately exceeds the sediment
benchmark criteria and gamma chlordane and 4,4-DDT slightly exceed the criteria.
Copper, lead and cobalt moderately exceed the inorganic background criteria. Aluminum, barium,
cadmium, chromium, nickel, vanadium and zinc only slightly exceed the background criteria. Aluminum
is the only metal to greatly exceed the sediment benchmark criteria. Barium, cadmium, copper, lead and
nickel moderately exceed the benchmark criteria, while chromium and zinc only slightly exceed the
criteria.
Mark/and Avenue Quarry
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The soil gas data indicate three areas of elevated VOC contamination, consisting primarily of
trichloroethene and its degradation products, cis-l,2-dichloroethene, trans-1,2-dichloroethene and vinyl
chloride (See Figure 4b, Appendix A). The area with the highest contaminant concentration is located just
north of the abandoned concrete structure in the southwest portion of the site. This area is of particular
concern because of the relatively high concentration detected of degradation product vinyl chloride. The
other two areas and an area of lesser concentration are located along a line from southwest to northeast that
parallels the old rail line. Note that at soil gas location MQSG-35 (Figure 4b), resistance was encountered
when advancing the rod. The possibility exists that the resistance was a drum as the rod was coated with
free product when pulled from the hole.
Although the soil gas survey did not define the vertical extent of VOC contamination, it served as a
qualitative screening tool by detecting elevated VOC solids areas. These VOC contaminated areas indicate
either a source within the vadose zone (unsaturated zone) or the shallow groundwater. Vadose zone and
shallow groundwater VOC contamination in the Markland Avenue Quarry may have resulted from past
disposal activities including solvent dumping and drum disposal and burial.
The pond sediment is contaminated at ppm levels with VOCs, PAHs, PCBs and metals. Most of the
parameters detected in the sediment exceed sediment benchmark screening levels, which are based on
aquatic toxicity. Trichloroethene is the most prevalent VOC and was detected at a concentration of 40,000
Hg/L (see Appendix D, Table MAQ-2). Sediment samples were also collected for treatability studies and
indicated even higher concentrations.of TCE (210,000 ug/L). This is consistent with the surface water
and soil gas data collected in the quarry area. Visual observations by the U.S. EPA (during drum removal)
confirm that DNAPL pockets exist in the sediment and along the quarry bottom. The presence of
contaminants and the DNAPL is likely to be a direct result of past dumping of drums into the pond.
Currently, contaminants may be migrating into the pond sediments from the fill either in the dissolved
form via groundwater and subsequent sorption or as DNAPL traveling down through the fill and into the
pond.
Surface soil samples were collected within the quarry fill boundaries(see Appendix A, Figure 4c) and at
selected residences upgradient and downgradient of the quarry area to evaluate the potential risks
associated with the surficial soils. The surface soils in the quarry fill area were contaminated primarily
with PAHs, the PCB Aroclor-1248 and metals (arsenic, lead and zinc) at elevated levels. The
contaminants in the surface soils are wide spread and do not necessarily coincide with the VOC hot spots.
The PAH and PCB contamination appear primarily in the southern half of the fill area. Two of the PCB
detections are in the soil gas hot spots indicating that the disposal activities in these areas may have
included PCBs in addition to the solvents.
The lead and arsenic contamination are widespread and the zinc contamination is sporadic. The
distribution of the PAHs and metals in the surface soils is Hkely not related to drum disposal episodes but
is more likely attributable to slag and baghouse dust disposal and filling and potential deposition of
emissions from the Main Plant.
The residential soil sampling downgradient from the quarry shows only isolated detections of
contaminants. The migration pathway being evaluated using this data is the air migration pathway. The
most likely contaminants to migrate are the metals. However, only small metal concentrations were
detected. There was one detection of Aroclor-1248 and one detection of dibenzo(a,h)anthracene. Because
of the isolated nature of the detections and the industrial nature of the community in this area, it is not
possible to attribute these detections to the quarry area with any degree of certainty.
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The screening level air dispersion model predicted the off-site impacts for arsenic, barium, cadmium,
chromium and lead if they were to migrate via the air pathway. The dispersion model predicted that only
lead could exceed the Indiana air toxic's standard. However, lead was detected at only minor levels off-
site of Markland Quarry. (See Appendix D, MAQ Tables for ranges of contaminants discovered during
RI).
Main Plant
Elevated concentrations of trichloroethene were detected in subsurface soil samples SB-A1S (5,600 ug/kg)
and SB-A2D (190 ng/kg) in the vicinity of Building 112 (nail mill)(see Appendix A, Figure 5c for soil
boring sample locations). PAHs and observable hydrocarbon product were detected in several samples.
While these constituents generally do not migrate as readily as VOCs, they do migrate at lower rates and
several PAHs are significant risk drivers. Surface spills evidenced by PAHs and observable hydrocarbon
product are limited to three areas at the Main Plant. The scrap storage yard located along the east side of
Building 5 (open hearth furnaces), Building 42 (blooming mill) and Building 40 (billet mill) is the area
with the most extensive observable hydrocarbon product. Mill filings were piled in this area to allow
drainage of cutting and lubricating oils from the filings. This area indicates a confirmed release of
hydrocarbons and is considered a chronic source of hydrocarbons and PAHs. Additionally, Aroclor-1242
and Aroclor-1248 were detected in five soil borings. A release has been confirmed in the vicinity of these
borings. The second area where a confirmed release of PAHs has occurred is at the south door of Building
20 (main machine shop). It is suspected that hydrocarbons were discarded out this door. The third area
where PAHs were observed is north of Kokomo Creek at SB-F2. Elevated concentrations of PAHs (108.7
mg/kg [total]) were detected in the shallow soils as well as in the deep sample (53.2 mg/kg [total]).
PCBs were detected in two soil boring samples in addition to those indicated above. Aroclor-1248 was
detected in SB-G1S (9.9 mg/kg) and SB-H3S (30+ mg/kg). A confirmed release is indicated in the
vicinity of these borings. Pesticides were detected in seven samples. Aldrin was detected at its highest
concentration in SB-H3S (1000 ug/kg).
Lead distribution in the shallow samples is generally in seven areas around the site. The first four are in
the vicinity of each of the four borings SB-El, SB-F2, SB-F5 and SB-F8. The fifth area is in the corridor
between Building 5 to the east and Buildings 34 and 37 (vicinity of SB-B3 and SB-B4). The sixth area is
between Building 69 to the east and Building 42 to the west (vicinity of SB-C5 SB-C3, SB-C4 and SB-G3.
The seventh area with the highest concentrations is south and east of Building 71B (vicinity of SB-H3 and
SB-H4). The four deep samples do not correspond to the shallow sample locations with higher lead
concentrations with the exception of SB-F2D. The remaining locations are in the vicinity of SB-C2D, SB-
E4D and SB-F6D. With the exception of the samples collected in the vicinity of Building 71B (wire
galvanizing), the distribution of higher lead concentrations does not readily correlate to known site
operations.
Zinc was detected at elevated concentrations in four samples (SB-A1, SB-C2, SB-C4 and SB-H3).
Elevated zinc concentrations at SB-A1S and SB-H3S may be attributed to galvanizing operations
associated with processes in the adjacent buildings (Buildings 112 [nail mill] and 71B [wire galvanizing]).
TCLP analyses indicate the only metals that exceeded the TCLP criteria for metals were cadmium (SB-
B4S) and lead (SB-B4S and SB-F2S). The only VOC that exceeded TCLP criteria was 1,2-dichloroethane
(SB-B2S). (See Appendix D, MP Tables for ranges of contaminants discovered during RI).
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Slag Processing Area
VOCs were not detected in soil gas samples collected at the Slag Processing Area with the exception of
one detection of trichloroethene at the method detection limit. No VOCs were detected in surface soil
samples with the exception of methylene chloride which is a common laboratory contaminant. The
presence of methylene chloride is probably not a result of site activities. Additionally, no SVOCs or PCBs
were detected in surface soil samples analyzed. Although not conclusive, these results give no indication
of residual contamination resulting from surface spills or leaking buried drums.
VI. Summary of Site Risks
Based on data collected during the RI, human health and ecological risks associated with contaminants
detected in groundwater, soils, surface water, and sediments for the site were assessed. A baseline risk
assessment, also known as a baseline screening, was conducted to compare contamination levels at the site
with U.S. EPA standards. It considered ways in which people and wildlife could be exposed to site-related
contaminants and whether such exposure could increase the incidence of cancer and noncarcinogenic
(noncancer related) diseases above the levels that normally occur in the study area or population.
The screening assumed that people could be exposed to site-related contaminants by eating them
(ingestion), breathing them (inhalation), or absorbing them through the skin (dermal contact). The
contaminants of concern are the VOCs, semi-VOCs, metals and waste-specific compounds found in on-site
soil and groundwater.
Current land use and reasonably anticipated future use of the land at NPL sites are important
considerations in determining current risks, potential future risks, and appropriate extent of remediation.
(See "Land Use in the CERCLA Remedy Selection Process," OSWER Directive No. 9355.7-04, May 25,
1995). Land use assumptions affect the exposure pathways that are evaluated in the risk assessment (RA).
The results of the RA aid in determining the degree of remediation necessary to ensure current and long-
term protection at the site. The RA considers present use of the site to determine current risks. It may
restrict its analysis of future risks to the reasonably anticipated future land use.
The CSSS RA focused on users who would face the greatest exposure to landfill contaminants under
current and potential future land use conditions or scenarios. Recreational users and on-site residents are
the two groups most likely to be exposed. Also, on-site construction workers, child trespassers, and future
on-site workers are also considered.
The RA uses a conservative estimate when evaluating a potential risk. This provides a high level of
protection for public health and the environment. For example, some of the risk estimates assume that the
site will be developed for future residential land use and that people use or will regularly use contaminated
groundwater for drinking and bathing. Therefore, the excess lifetime cancer risk estimates should be
regarded as estimates of potential cancer risk rather than actual representations of true cancer risk.
Potential risks to public health for cancer are expressed numerically, i.e. 1x10"4 or 1x10"*. Carcinogenic
risk expressed as 1x10"" means that 1 out of 10,000 people exposed to contamination over a 70-year
lifetime could develop cancer as a result of the exposure. A carcinogenic risk of 1x10"* means that 1 out of
1,000,000 people exposed over a 70-year lifetime could potentially develop cancer as a result of exposure.
The U.S. EPA has established a carcinogenic risk range in an attempt to set standards for remediation and
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protectiveness. In general, as carcinogenic risks increase above one case in a million people exposed over
a 70-year lifetime, they become less acceptable. The carcinogenic risk to individuals generally should not
exceed one case in 10,000 exposures. Risks are estimated based on both CTE and RME. The former are
intended to represent typical exposures at the CSSS, the latter represent exposures well above the average,
but still within a possible range. The measure for noncarcinogenic risk is termed a hazard index (HI) and
is also expressed numerically. When the HI exceeds 1, there is a potential for adverse health effects.
The data from the Remedial Investigation was reviewed to identify contaminants of potential concern
(COPCs) for human health risk evaluation. COPCs were selected for each source area based on the
number of times detected, maximum concentration detected, background concentration, potential toxicity,
ARARs, and future land use possibilities for the source area. Evaluation of the COPCs also provided the
information necessary to develop remedial response objectives for the CSSS. Metals, SVOCs, VOCs,
PCBs, and PAHs are COPCs for the CSSS. More detailed descriptions are presented in the CSSS RI, FS,
and Baseline Risk Assessment (BRA) Reports.
According to the Agency for Toxic Substance and Disease Registry (ATSDR), exposure to lead can affect
almost every organ and system in the body. The most sensitive is the central nervous system, particularly
children. Lead also damages the kidneys and the immune system. The effects are the same whether
through inhalation or ingestion. Exposure to lead is much more dangerous in young and unborn children.
Harmful effects include premature birth, smaller babies, decreased or stunted mental ability, learning
difficulties/disorders, and reduced growth. In adults, lead may decrease mental reaction time, cause
weakness in joints, cause anemia, and affect memory. It can cause abortion and damage the male
reproductive system. Potential risks to public health from lead are evaluated using the IEUBK (Integrated
Environmental Uptake BioKenetic) model (U.S. EPA 1994) for children and in adults using a multi-
pathway exposure model developed by U.S.EPA (1996). Default parameters or site-specific model input
parameters may be used. U.S. EPA considered risks from exposures to lead acceptable if the probability
that children may have blood lead levels exceeding 10 ug/dL is less than 5 percent. Adult exposures to
lead are evaluated using the interim adult exposure methodology developed by U.S. EPA (1996). The
focus of this method is to estimate fetal blood lead levels based on exposure to lead in soil by female
workers of childbearing age. Ninety-fifth percentile fetal blood lead concentrations should not exceed 10
ug/dL.
Human Health Risk Assessment and COPCs:
The analytical data compiled in Phases I and II of the RI were reviewed, and contaminants of potential
concern (COPCs) were selected for human health risk evaluation. COPCs were selected for each source
area based on frequency of detection, maximum concentration detected, background concentration,
potential toxicity, ARARs, and the future use scenario of the source area. The COPCs for each source
area, media of concern, and exposure scenario are presented below along with the human health risk
assessment evaluations. A summary of the human health risk evaluations is presented in the tables in
Appendix C.
Site-wide Groundwater
COPCs were selected for site-wide groundwater based on a residential future land use scenario. COPCs
selected for groundwater in the shallow water-bearing zone include: manganese, 1,1-dichloroethene, 1,2-
dichloroethene (cis- and total), tetrachloroethene, trichlorpethene, benzene, chloroform, vinyl chloride,
Aroclor-1242, and Aroclor-1248. COPCs selected for groundwater in the intermediate water-bearing zone
include: manganese, 1,1-dichloroethene, l,2-dichloroethene(cis- and total), acrylonitrile, methylene
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chloride, tetrachloroethene, trichloroethene, and vinyl chloride. COPCs selected for groundwater in the
lower water-bearing zone include: manganese, 1,2-dichloroethene (cis- and total), acrylonitrile, methylene
chloride, tetrachloroethene, trichloroethene, and vinyl chloride.
Several onsite sources, and probably other offsite sources, contribute to groundwater contamination in the
vicinity of the four major source areas of the CSSS. As a result of these several sources, groundwater is
varyingly contaminated depending on location and depth. These variations result in a range of potential
exposures and risks determined by different well locations. To account for this variability, groundwater
exposures and risks are assessed on a geographic basis. Geographic presentation provides insight not only
into the magnitude of potential risks, but also their spatial distribution. The spatial distribution allows
evaluation of potential remedial alternatives that involve such contingencies as groundwater capture,
groundwater treatment, institutional use control, bioremediation, etc.
To develop a presentation of risks on a geographic basis, potential exposures and risks from use of
groundwater for drinking and other domestic purposes are calculated well by well. Total cancer risks and
total hazard indices are then calculated as the sum of individual cancer risks and hazard quotients from
each well. These estimates form the basis for mapping of potential groundwater-related risks for CSSS
groundwater.
Each hydrologic unit, shallow, intermediate and lower, is assessed separately to allow differentiation of
potential risks with depth. Risk scenarios are assessed based on both residential and commercial/industrial
use of groundwater. Risks are estimated based on both CTE and RME. The former is intended to
represent typical exposures at the CSSS, the latter represent exposures well above the average, but still
within a possible range.
Cancer Risk Estimates
Residential Scenario
Shallow Water-Bearing Zone
A large portion of the shallow water-bearing zone is contaminated at levels associated with risks above
the lower end of the U.S. EPA risk range (10"6). In fact, the entire area enclosed by the dashed boundary
(see Appendix A, Figure 1) can be expected to have sufficient groundwater contamination that residential
risk may equal or exceed 10'5.
Several areas beneath the site can be expected to have groundwater contamination sufficient to present a
cancer risk of greater than 10"4, the upper end of the U.S. EPA risk range. These areas include the
southern portion of the Lagoon Area, the northern edge of the Lagoon Area, the south central portion of
the Main Plant, and a wedge shaped area extending west from the Markland Avenue Quarry.
Groundwater may pose extreme risks (above 10"3) for future use of groundwater in a large area beneath
the Main Plant and extending west beneath Wildcat Creek and the city's wastewater treatment plant.
Two smaller portions of the shallow groundwater plumes also could present extreme threats; a triangular
area north of the old Fence Plant, and an area including a small part of the southwest Lagoon Area and
extending west under Wildcat Creek. In these areas, major risks are presented by potential exposure to
vinyl chloride in groundwater.
Intermediate Water-Bearing Zone
Ranges for risks associated with contaminated groundwater in the intermediate water-bearing zone are
similar to those found in the shallow water-bearing zone, but the distribution of risks is significantly
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45
different. A large section of the site, extending from the Main Plant to the west, has sufficient
contamination to imply potential risk above 10'3. Risks in this area are mainly associated with potential
exposure to vinyl chloride.
On the edges of the large highly contaminated zone exist areas associated with risks still above 10"4.
These areas include a triangular zone extending west from the Slag Processing Area, a long narrow strip
running from the Main Plant west to the southwest corner of the Lagoon Area and another strip running
from the Markland Avenue Quarry west and north passed the former Continental Steel Engineering
Building and Wildcat Creek.
Lower Water-Bearing Zone
Ranges of risks associated with contaminated groundwater in the lower water-bearing zone are again
similar to those found in the shallow zone. Extreme risks (above 10'3) are associated with an area to the
north of the Main Plant property extending across Wildcat Creek toward the wastewater treatment plant
and another area beneath the Slag Processing Area extending east beneath Wildcat Creek. Some risks
are associated with potential exposure to vinyl chloride, however, risk estimates are dominated by
exposure to aery Ion itrile. This chemical is found in significant concentrations only in the lower water-
bearing zone.
A zone extending from the northeast corner of the Lagoon Area and running mainly eastward toward the
old Fence Plant is associated with risks in excess of 10"4. A relatively small area in the northern Lagoon
Area is associated with risks in the range of 10~5 to 10"4.
Commercial/Industrial Scenario
Cancer risks for future commercial/industrial workers on and near CSSS source areas are estimated for
ingestion of contaminated groundwater. Potential cancer risks for future commercial/industrial workers
from ingestion of contaminated groundwater are much less than those estimated for future residential
groundwater users. No risks above the upper end of the U.S. EPA risk range (10"4) are estimated for
worker exposures. A large volume of groundwater in all three water-bearing zones is contaminated
beneath both source areas and nearby residential, commercial, and industrial areas at the CSSS.
Significant areas exist in individual water-bearing zones, however, where groundwater contaminant levels
are sufficiently low that little threat is expected from commercial/industrial use of groundwater. In theory,
commercial/industrial use of groundwater might be permitted within the portions of the contaminated zone,
even though residential use may be prohibited.
Noncancer Risk Estimates
Residential Scenario
Noncancer risks for the residential scenario are calculated on a well by well basis for three exposure
pathways, ingestion, dermal contact, and inhalation. Therefore, all Noncancer risk estimates presented
are the sum of His for all of these pathways.
Shallow Water-Bearing Zone
All of the shallow water-bearing zones included in this assessment are affected at levels associated with
an HI greater than the target HI of 1. Groundwater may present extreme risks for Noncancer health
effects (hazard indices greater than 10s) for future use of groundwater in a small area on the western edge
of the Lagoon Area. In this area, Noncancer risks are dominated by potential exposure to c;s-l,2-DCE.
Larger areas, where His may exceed 103, are identified over the western part of the Lagoon Area and
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extend to the Slag Processing Area, the mid to southern portion of the Lagoon Area, and most of the
Main Plant. In most areas, risks are due mainly to potential exposure to manganese in groundwater,
although PCE and TCE make significant contributions in some areas.
Hazard indices above 102 are predicted for most of the central area of the site including the wastewater
treatment plant, much of the Lagoon Area, and for the area including and surrounding the old Fence
Plant. Other areas, including parts of the Markland Avenue Quarry and the eastern Main Plant are
associated with His above 10.
Intermediate Water-Bearing Zone
Ranges for His associated with contaminated groundwater in the intermediate water-bearing zone are
similar to those found in the shallow water-bearing zone, but the distribution of risks is significantly
different. A large section of the site, extending from Markland Avenue Quarry west passed Shambaugh
Run to the Dixon Road Quarry including the old Fence Plant, the northern portion of the Main Plant, the
wastewater treatment plant, most of the Lagoon Area, and part of the Slag Processing Area, has sufficient
contamination to imply potential His in the range of 102 to 103. A small area near Shambaugh Run have
associated His in the range of 103 to 104. In general, risks are due mainly to exposure to chlorinated
solvents, cis-l,2-DCE, total DCE, TCE, and PCE, although significant exposures to manganese are
implied at some locations. An adjacent area, and areas near the Continental Steel Engineering Building
and north of the Fence Plant area have lower HI estimates, in the range of 10 to 100.
Lower Water-Bearing Zone
Ranges of risks associated with contaminated groundwater in the lower water-bearing zone are again
similar to those found in the shallow zone. His in the range of 102 to 103 are estimated in a zone
extending from the northeast part of the Main Plant west to the Slag Processing Area. South of this zone,
an area with estimated His in the range of 10 to 100 is found extending from Markland Avenue Quarry
west to the Haynes International facility. Potential exposure to solvents, especially cis- and total
1,2-DCE, and to manganese dominate risk estimates. Acrylonitrile is important in a small area sampled
in the eastern portion of the Slag Processing Area. A small area including the eastern portion of the Slag
Processing Area and some land to the north of Markland Avenue is associated with somewhat smaller
His, in the range of 1 to 10.
Commercial/Industrial Scenario
Noncancer risks for the commercial/industrial scenario are calculated on a well by well basis only for
ingestion of contaminated groundwater. Therefore, all Noncancer risk estimates presented represent
hazard indices (His) for this single pathway. Potential Noncancer risks for future residential users of
contaminated groundwater are generally below the target HI of 1 beneath sources and nearby offsite
areas at the CSSS. Highest His are predicted for the shallow water-bearing zone beneath the Lagoon
Area, parts of the Main Plant, and parts of the old Fence Plant and nearby areas. The major limitation on
use of groundwater in commercial/industrial settings appears to be potential cancer risks as discussed
above.
Potential exposures to manganese and several chlorinated solvents, especially cis- and total 1,2-DCE, are
associated with the highest His for the site in all three water-bearing zones. However, concentrations of
these COPCs are sufficiently high only in the shallow water-bearing zone to suggest exposures above the
"safe" level defined by the RfD. DCE is likely a breakdown product of PCE and TCE. Controlling any
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existing sources of these latter chemicals may be important for gradual reduction in DCE concentrations
in shallow groundwater beneath the site. Manganese in groundwater may be a more persistent, since it
cannot degrade. Dilution, adsorption or other physical/chemical processes may serve to reduce
manganese concentrations in the future, but no attempt is made here to address such issues.
Lagoon Area
COPCs selected for the Lagoon Area were based on an industrial/commercial and trespasser/recreational
future land use scenario. COPCs selected for on-site surface soil include: benzo(b) fluoranthene, benzo(a)
anthracene, benzo(a)pyrene, dibenzo(a,h)anthracene, indeno (1,2,3-cd) pyrene, manganese, Aroclor-1242,
Aroclor-1248, beryllium, and lead. COPCs selected for the lagoon sludge include: benzo(a)pyrene, lead,
manganese, and beryllium. COPCs selected for the waste piles include: manganese and lead. COPCs
selected for the lagoon clarifier tank sludge were manganese and beryllium. In addition, although soil gas
results (VOCs) were not used in the RA COPC development (i.e., there are no human health impacts),
VOCs are considered COPCs for soil at the entrance area of the Lagoon Area since they may potentially
impact groundwater at the CSSS. These COPCs include: 1,1-dichloroethene, 1,2-dichloroethene (cis and
trans), trichloroethene, vinyl chloride, tetrachloroethene, and 1,1,1-trichloroethene. COPCs selected for
shallow groundwater include 1,1-dichloroethene, 1,2-dichloroethene (total), benzene, chloroform, cis-1,2-
dichloroethene, tetrachloroethene, trichloroethene, vinyl chloride and manganese.
Two groups of receptors are evaluated for potential exposures to contaminants from the Lagoon Area,
future onsite commercial/industrial workers and current and future onsite trespassers. These receptors
are quantitatively evaluated for incidental- ingestion of soil and dermal contact with soil. Trespassers are
assumed to be children of ages 6- to 14-years. Worker exposures are quantified for adults. Both the
CTE and RME exposure point concentrations are derived from data collected across the entire
approximately 56 acre source area. Cancer and noncancer risk/hazard estimates are based on these
values.
Cancer Risk Estimates
Carcinogenic risks for the Lagoon area are summarized in Table ES-1 (Appendix C). Risk estimates for
current and future onsite trespassers and future onsite commercial/industrial workers are discussed
below.
Current and Future Onsite Trespassers
Total cancer risk estimates for incidental ingestion of soil by current and future trespassers onto the
Lagoon Area based on average exposure and RME are 8.5E-07 and 5.2E-05, respectively. Estimated
cancer risks from dermal exposure to contaminants in soil are 4.9E-07 and 1.2E-04 for average exposure
and RME, respectively. Aroclors 1242 and 1248 are the main contributors to these risks. Estimated total
cancer risks from incidental dermal contact are 1.3E-06 and 1.7E-04 based on average exposure and
RME, respectively. Average risk for the exposure pathway are at the bottom and risks based on RME
exceed U.S. EPA's acceptable (1990) risk range.
Future Onsite Commercial/Industrial Workers
Estimated cancer risks for incidental ingestion of soil by future onsite commercial/industrial workers at
the Lagoon Area based on average exposure from this pathway are 5.3E-07, and cancer risks based on
RME are 1.6E-04. Aroclor 1248 is the main contributor to carcinogenic risks for the
commercial/industrial worker scenario. Estimated cancer risks from dermal exposure to are 3.0E-07 and
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48
3.6E-05 for average exposure and RME, respectively. Aroclor 1248 is again the main contributor to
these risks. Total cancer risk estimates from incidental dermal contact are 8.4E-07 and 1.9E-04 based
on average exposure and RME, respectively. Risks based on average exposure and RME are below and
above U.S. EPA's 1990 acceptable range, respectively.
The north central part of the Lagoon Area overlies significant levels of COPCs in soil gas. If soil gas in
these areas were to migrate inside buildings, cancer risks and Noncancer health effects from inhalation of
VOCs in indoor air could be unacceptably high. For areas with high levels of soil gas, vinyl chloride, a
degradation product of PCE and TCE, is a major contributor to possible risks at the site. Construction
should not be considered in these areas because of the potential for volatile chemicals to migrate into
indoor air spaces. This applies to residential as well as commercial/industrial development.
Noncarcinogenic Hazard Estimates
Noncarcinogenic risks for the Lagoon area are summarized in Table ES-2 (Appendix C).
Noncarcinogenic health effects estimates for current and future onsite trespassers and future onsite
commercial/industrial workers at the Lagoon Area are discussed below.
Current and Future Onsite Trespassers
His for incidental ingestion of soil by current and future onsite trespassers at the Lagoon Area are 0.06
and 3.8 for average exposure and RME, respectively. Because the HQ for Aroclor 1248 exceeds unity, it
is not necessary to evaluate His based on target organs. The HI for the exposure pathway exceeds unity,
indicating potential health risks may be associated with incidental ingestion of soil by trespassers.
Estimated His from dermal exposure to contaminants in soil for current and future trespassers onto the
Lagoon Area are 0.01 and 6.1 for average exposure and RME, respectively. These risks are entirely from
exposure to Aroclors 1242 and 1248.
Total noncancer risk estimates from these pathways are 0.07 and 10 based on average exposure and
RME, respectively. The total HI based on average exposure is less than unity, however, the HI based on
RME exceeds unity, suggesting that contact with contaminated soil at the Lagoon Area may result in
adverse Noncancer health effects for current and future onsite trespassers.
Future Onsite Commercial/Indus trial Workers
His for incidental ingestion of soil by future onsite commercial/industrial workers are 0.03 and 2.9, for
average exposure and RME, respectively. The His for RME exceed unity, suggesting that there is a
potential for adverse health effects from incidental ingestion of soil by future onsite commercial/industrial
workers at the Lagoon Area. Estimated His from dermal exposure to soil for future onsite construction
workers at the Lagoon Area are 0.007 and 0.6 for average exposure and RME, respectively. Based on
these estimates, adverse Noncancer health effects from dermal contact with soil at the Lagoon Area are
considered unlikely for future onsite commercial/industrial workers.
Total Noncancer risk estimates from these pathways are 0.04 and 3.5 based on average exposure and RME,
respectively. Total HI for RME for contact with soil by future onsite commercial/industrial workers of the
Lagoon Area exceeds unity, suggesting that adverse effects from contact with soil are possible for these
workers.
Risks Associated with Exposure to Lead
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Potential exposures to lead in soil at the Lagoon Area are evaluated for current and future onsite
trespassers, and future onsite commercial/industrial workers. Trespassers are assumed to be 6- to 7-year-
old children. Lead exposure in children is evaluated using the IEUBK model (U.S. EPA 1994), and lead
exposure in adults is evaluated using a multi-pathway exposure model developed by U.S.EPA (1996).
The IEUBK model predicts that 11.3 percent of children trespassing onto Lead Exposure Area A (see
Appendix A, Figure 2c for Lead Exposure Area identification) of the Lagoon Area may have blood lead
concentrations of 10 ug/dL or greater. For children trespassing onto the rest of the exposure areas of the
Lagoon Area, 0.73, 0.19, 0.10, 0.29, and 0.49 percent may have blood lead concentrations of 10 ug/dL or
greater (see Figure 2c). U.S. EPA (1994) considers risks from exposures to lead unacceptable if the
probability that children may have blood lead levels exceeding 10 ug/dL is greater than 5 percent. IEUBK
modeling results suggest that significant risk from exposure to lead in soil is not expected for children who
may trespass onto any of the exposure areas defined for the Lagoon Area except for Area A.
Adult exposures to lead are evaluated using the interim adult exposure methodology developed by U.S.
EPA (1996). The focus of this method is to estimate fetal blood lead levels based on exposure to lead in
soil by female workers of child-bearing age. Ninety-fifth percentile fetal blood lead concentrations should
not exceed 10 ug/dL (U.S. EPA 1996).
The method predicts 95 percentile fetal blood lead levels in women of childbearing age exposed to lead in
soil of 13.73, 8.74, 5.91, 7.26, 6.15, and 8.35 ng/dL for exposure Areas A, B, C, D, and E of the Lagoon
Area and in the area to be developed into a CAMU, respectively (see Appendix A, Figure 2c). Predicted
blood lead concentrations are less than the "acceptable" fetal blood lead concentration for exposure Areas
B, C, D, E, and the CAMU, but exceed the "acceptable" concentration for Area A.
Wildcat and Kokomo Creeks
COPCs selected for sediment in the Wildcat and Kokomo Creeks include: benzo(a)anthracene, benzo(b)
fluoranthene, benzo(g,h,i)perylene, indeno(l,2,3-c,d)pyrene, benzo(a)pyrene, dibenzo(a,h)anthracene,
arsenic, beryllium, ArocIor-1016, Aroclor-1242, Aroclor-1248, Aroclor-1254, and Aroclor-1260.
Recreational visitors are evaluated for potential exposures associated with contaminants in Kokomo and
Wildcat creeks. Exposure to noncarcinogens is evaluated for young children and exposure to carcinogens
for adults. Both CTE and RME exposure point concentrations are derived from data collected in each of
six reaches of the creeks.
Cancer Risk Estimates
Carcinogenic risks for recreational visitors to Kokomo and Wildcat creeks are summarized in Table ES-1
(Appendix C). Risks are estimated based on both average exposure and RME. Risks associated with
surface water in Kokomo and Wildcat creeks are assessed on a site-wide basis. To evaluate risks from
exposure to sediment, Kokomo and Wildcat Creeks are subdivided into six.reaches, and each reach is
evaluated separately.
Surface Water Ingestion - Recreational Visitors
Recreational visitors to Kokomo and Wildcat Creeks are evaluated for potential risks from incidental
ingestion of surface water during recreational activities. Only two carcinogenic COPCs were selected for
surface water in the Creeks, TCE and arsenic. Estimated risks for TCE are 1.1E-11 for average exposures
and 2.0E-07 for RME. For arsenic, the estimated risk from average exposure is 7.6E-09 and risk from
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RME is 1.1E-07. Total cancer risks for the surface water ingestion pathway are 7.6E-09 for average
exposure and 3.1 E-07 for RME. These risk estimates are considered acceptable based on U.S. EPA's
acceptable risk range (U.S. EPA 1990).
Sediment Ingestion and Dermal Contact vith Sediment
Recreational visitors to Kokomo and Wildcat creeks are evaluated for incidental ingestion of and dermal
contact with sediment. Cancer risk estimates for these pathways are summarized by reach number in Tabl
ES-1 and described below.
Reach /
Estimated cancer risks from incidental ingestion of sediment by recreational visitors in Reach 1 are 1.8E-
06 and 1.6E-04 for average exposure and RME, respectively. Estimated cancer risks from dermal
exposure with sediment are 2.7E-06 and 8.6E-04, respectively, and total cancer risk estimates from
exposure to sediment are 4.4E-06 and l.OE-03, respectively. Aroclors 1254 and 1260 are the main
contributors to these risks. The risks are within and above U.S. EPA's acceptable range.
Reach 2
For Reach 2, estimated cancer risks from incidental ingestion of sediment by recreational visitors are 1.6E-
06 and 3.4E-05 for average exposure and RME, respectively. Estimated cancer risks from dermal
exposure with contaminants in sediment are 1.1E-06 and 1.8E-04. Total cancer risk estimates from
exposure to sediment are 2.7E-06 and 2.1E-04, respectively. The greatest contribution to these risks is
from Aroclor 1248. The risks are within and above U.S. EPA's acceptable range.
Reach 3
Estimated cancer risks from incidental ingestion of sediment by recreational visitors are 1.1E-06 and 1.4E-
05 for average exposure and RME, respectively. Estimated cancer risks from dermal exposure to sediment
are 1.2E-06 and 7.5E-05, and total cancer risk estimates from exposure to sediment are 2.3E-06 and 8.8E-
05, respectively. For Reach 3, the main contributors to the estimates risks are benzo(a)pyrene and Aroclors
1242, 1248, and 1254. Risks for Reach 3 are within U.S. EPA's (1990) acceptable range.
Reach 4
Estimated cancer risks from incidental ingestion of sediment by recreational visitors are 1.2E-06 and 1.2E-
03 for average exposure and RME, respectively. Estimated cancer risks from dermal exposure with
sediment are 3.0E-06 and 6.8E-03; total cancer risk estimates from exposure to sediment are 4.2E-06 and
8.OE-03, respectively. Aroclors 1016, 1248, and 1254 are the main contributors to these risks. Risks
based on average exposure are within U.S. EPA's (1990) acceptable range but risks based on RME exceed
it.
Reach 5
Estimated cancer risks from incidental ingestion of sediment by recreational visitors are 1.8E-06 and 1.9E-
04 for average exposure and RME, respectively. Estimated cancer risks from dermal exposure to sediment
are 1.6E-06 and 1.1E-03, total cancer risk estimates from exposure to sediment are 3.5E-06 and 1.2E-03,
respectively. For Reach 5, Aroclor 1016 and 1254 are the greatest contributors to overall risk. Risks based
on average exposure are within U.S. EPA's (1990) acceptable range, but risks based on RME exceed it.
Reach 6
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Estimated cancer risks from incidental ingestion of sediment by recreational visitors are 8.7E-07 and 7.6E-
06 for average exposure and RME, respectively. Estimated cancer risks from dermal exposure to sediment
are 1.3E-06 and 4.5E-05. Total cancer risk estimates from exposure to sediment are 2.2E-06 and 5.3E-06,
respectively. Benzo(a)pyrene and Aroclors 1016 and 1254 contribute most to these risks. Cancer risks are
within U.S. EPA's (1990) acceptable range.
Noncarcinogenic Hazard Estimates
Noncarcinogenic risks for recreational visitors to Kokomo and Wildcat creeks are summarized in Table
ES-2 (Appendix C). Noncarcinogenic health effects estimates for the recreational visitor at Kokomo and
Wildcat creeks are discussed below.
Surface Water Ingestion - Recreational Visitor
For surface water in Kokomo and Wildcat creeks, the following noncarcinogenic COPCs were selected:
TCE, arsenic, barium, manganese, nickel, and zinc. Average estimated HQs for these chemicals ranged
from 0.001 to 8.6E-06, and HQs based on RME ranged from 0.03 to 8.9E-05. Total HI estimates for the
surface water ingestion pathway are 0.002 and 0.04 for average exposure and RME, respectively. The His
are less than one, suggesting that adverse noncarcinogenic risks from exposure to surface water are not
likely.
Sediment Ingestion - Recreational Visitor
Recreational visitors to Kokomo and Wildcat creeks are evaluated for incidental ingestion of sediment.
Noncarcinogenic hazard estimates for this pathway are described below.
Reach /
HI estimates for incidental ingestion of sediment by recreational visitors to Reach 1 are 0.05 and 21 based
on average exposure and RME, respectively. His for dermal exposure with sediment are 0.009 and 12.
Total health effects estimates for exposure to sediment are 0.06 and 33, respectively. The HI based on
RME exceeds unity, suggesting that there is a potential for adverse health effects from exposure to
sediment in Reach 1.
Reach 2
HI estimates for incidental ingestion of sediment by recreational visitors to Reach 2 are 0.03 and 4.5 based
on average exposure and RME, respectively. His for dermal exposure with sediment are 0.002 and 2.3,
and total health effects estimates for exposure to sediment are 0.03 and 6.9, respectively. The HI based on
RME exceeds unity, suggesting that there is a potential for adverse health effects from exposure to
sediment in Reach 2.
Reach 3
For Reach 3, HI estimates for incidental ingestion of sediment by recreational visitors are 0.02 and 1.6
based on average exposure and RME, respectively. His for dermal exposure with sediment are 0.002 and
0.8, and total health effects estimates for exposure to sediment are 0.02 and 2.4, respectively. The HI
based on RME exceeds unity, suggesting that there is a potential for adverse health effects from exposure
to sediment in Reach 3.
Reach 4
HI estimates for incidental ingestion of sediment by recreational visitors are 0.02 and 109 based on average
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exposure and RME, respectively. His for dermal exposure with sediment are 0.004 and 64, and total
health effects estimates for exposure to sediment are 0.03 and 173, respectively. The HI based on RME
exceeds unity, suggesting that there is a potential for adverse health effects from exposure to sediment in
Reach 4.
Reach 5
HI estimates for incidental ingestion of sediment by recreational visitors are 0.03 and 15 based on average
exposure and RME, respectively. His for dermal exposure with sediment are 0.001 and 8.3, and total
health effects estimates for exposure to sediment are 0.03 and 23, respectively. The HI based on RME
exceeds unity, suggesting that there is a potential for adverse health effects from exposure to sediment in
Reach 5.
Reach 6
HI estimates for incidental ingestion of sediment by recreational visitors are 0.01 and 0.5 based on average
exposure and RME, respectively. His for dermal exposure with sediment are 0.001 and 0.2, and total
health effects estimates for exposure to sediment are 0.01 and 0.8, respectively. His for Reach 6 do not
exceed unity, indicating that Noncancer health effects from exposure to sediment are unlikely.
Risk Associated from Exposure to Lead
Recreational visitors are evaluated for potential exposures to lead in sediment in Kokomo and Wildcat
creeks. Exposure to lead is evaluated for young children who may recreate at the Creeks. 3- to 6-year-old
children are considered most likely to play with creek sediment, therefore this age group is evaluated for
potential exposures to lead. IEUBK. modeling predicts that the probability of children (exposed to lead in
sediments in Reaches 1 through 6 of the Creeks) and having blood lead levels exceeding 10 ng/dL is 0.41,
2.39, 0.55, 0.37, 2.87, and 0.73 percent for children, respectively. U.S. EPA (1994b) recommends that
young children's blood lead levels in excess of 10 ug/dL does not exceed 5 percent. Based on this
evaluation, exposure to lead in sediments at Kokomo and Wildcat creeks is not likely to result in
unacceptably high blood lead levels in children.
Mark/and-Avenue Quarry
COPCs selected for the Markland Avenue Quarry were based on a residential future land use scenario.
The only COPC selected for surface water is zinc. COPCs selected for on-site surface soil include:
benzo(a)pyrene, benzo(a)anthracene, benzo(b&k)fluoranthene, dibenzo(a,h)anthracene, indeno( 1,2,3-
cd)pyrene, Aroclor-1248, arsenic, and lead. In addition, although soil gas results (VOCs) were not used in
the RA COPC development (i.e., there are no human health impacts), VOCs are considered COPCs for the
Markland Avenue Quarry since they may potentially impact groundwater at the CSSS. These COPCs
include: 1,1-dichloroethene, 1,2-dichloroethene (cis and trans), trichloroethene, and vinyl chloride.
COPCs selected for shallow groundwater include 1,1-dichloroethene, 1,2-dichloroethene (total), benzene,
chloroform, cis-1,2-dichloroethene, tetrachloroethene, trichloroethene, vinyl chloride, and manganese.
Five different groups of receptors are evaluated for potential exposures to chemicals associated with the
Markland Avenue Quarry: current and future offsite residents, future onsite residents, current and future
onsite commercial/industrial workers, future onsite construction workers, and current and future onsite
trespassers. All receptor populations are evaluated for incidental ingestion of and dermal contact with soil.
Trespassers are also evaluated for ingestion of surface water and dermal contact with surface water in the
quarry. Residential exposures are quantified for 1- to 6-year-old children and adults, and exposures for
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trespassers are quantified for 6- to 14-year-old children. Worker exposures are quantified for adults. Both
the CTE and RME exposure point concentrations are derived from data collected across the entire
approximately 13 acre source area. Cancer and Noncancer risk/hazard estimates are based on these values.
Cancer Risk Estimates
Carcinogenic risks for current and future offsite residents, future onsite residents, current and future onsite
commercial/industrial workers, construction workers, and current and future onsite trespassers at the
Markland Avenue Quarry are summarized in Table ES-1 (Appendix C) and discussed below.
Current and Future Offsite Residents
Current and future offsite residents near the Markland Avenue Quarry (the Quarry) are evaluated for
incidental ingestion of soil and dermal contact with soil in their yards. Only two carcinogenic COPCs
were selected for offsite soil, dibenzo(a,h)anthracene and arsenic. Total carcinogenic risks from incidental
ingestion of these chemicals in soilare 6.0E-06 and 1.1E-04, for average exposure and RME, respectively.
Arsenic contributes more than 70 and 90 percent to these risks, respectively. Estimated cancer risks from
dermal exposure to COPCs in soil for offsite residents at the Quarry are 1.7E-06 and 2.2E-04 for average
exposure and RME, respectively. Dibenz(a.h) anthracene is the only carcinogenic COPC evaluated for this
pathway. Total cancer risk estimates for offsite residents near the Quarry from incidental ingestion of soil
and dermal contact with soil are 7.7E-06 and 3.3E-04 based on average exposure and RME, respectively.
Risks based on RME exceed U.S. EPA's (1990) acceptable range.
Future Onsite Residents
Estimated cancer risks for incidental ingestion of soil and dermal contact with soil by future onsite Quarry
residents are summarized in Table ES-1 in Appendix C. Future onsite residents at the Quarry are also
evaluated for potential exposures from inhalation of VOCs released from subsurface soil and buried
wastes.
Total risks for the soil ingestion pathway are 9.7E-06 and 1.6E-04 for average exposure and RME.
Arsenic contributes 86 and 70 percent to these risks, respectively. Benzo(a)pyrene, dibenzo(a,h)
anthracene, and Aroclor 1248 together contribute approximately 26 percent to risks based on RME.
Estimated cancer risks from dermal exposure to contaminants in soil are 4.9E-06 and 2.9E-04 for average
exposure and RME, respectively. Benzo(a)pyrene and dibenz(a,h)anthracene are the main contributors to
these risks.
Total cancer risk estimates from exposure to soil are also summarized in Table ES-1 (Appendix C).
Estimated total cancer risks are 1.5E-05 and 4.5E-04 based on average exposure and RME, respectively.
Total average carcinogenic risks for this scenario are within and risks associated with RME exceed U.S.
EPA's (1990) acceptable risk range.
High concentrations of COPCs have been detected in soil gas in several areas of the Quarry and apparently
stem from buried wastes and drums. Contaminants in soil gas could theoretically migrate into any
buildings constructed in the future at the Quarry. The evaluation of potential risks for future onsite
residents shows significant risk may result from inhalation of such contaminants in indoor air.
Current and Future Onsite Commercial/Industrial Workers
Current and future commercial/industrial workers at the Quarry are evaluated for incidental ingestion of
soil, dermal contact with soil, and inhalation of VOCs released from buried wastes and drums into indoor
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air. Potential exposure pathways are thought to be incomplete for current commercial/industrial workers at
the Quarry, risk estimates therefore only apply to future onsite commercial/ industrial workers.
Estimated cancer risks from incidental ingestion of soil are 7.0E-06 and 6.8E-05 for average exposure and
RME, respectively. Arsenic is the main contributor to these risks. Estimated cancer risks from dermal
exposure are 8.2E-07 and 8.0E-06 for average exposure and RME, respectively. Benzo(a)pyrene,
dibenz(a,h)anthracene and Aroclor 1248 are the main contributors to these risks.
Total cancer risk estimates from incidental ingestion of soil and dermal contact with soil are presented in
Table ES-1 (Appendix C). Estimated total cancer risks from these pathways are 7.9E-06 and 7.6E-05
based on average exposure and RME, respectively. These risks are within U.S. EPA's (1990) acceptable
range.
As mentioned above, high concentrations of COPCs have been detected in soil gas due to buried wastes
and drums. Contaminants in soil gas could theoretically migrate into any buildings constructed in the
future and be inhaled by people living or working in the buildings. Inhalation of indoor air is evaluated on
a sitewide basis for residents. The evaluation shows that exposure to contaminants in indoor air may be
associated with significant risk for future onsite residents at the quarry. These results can also be applied
to the commercial/industrial worker scenario. Even though it would be assumed there would be reduced
exposure frequency and duration for commercial/ industrial workers versus residents, risk estimates may
still be unacceptably high.
Future Onsite Construction Workers
Future onsite construction workers at the Quarry are evaluated for incidental ingestion of soil and dermal
contact with soil. Cancer risk estimates for this scenario are summarized in Table ES-1 in Appendix C.
Estimated cancer risks from incidental ingestion of soil by future onsite construction workers are 5.5E-08
and 1.4E-06 for average exposure and RME, respectively. Arsenic is the main contributor to these risks.
Estimated cancer risks for future onsite construction workers from dermal exposure to contaminants in soil
are 6.1E-09 and 6.4E-08 for average exposure and RME, respectively.
Total cancer risk estimates for construction workers at the Quarry from incidental ingestion of soil and
dermal contact with soil are summarized in Table ES-1. Estimated total cancer risks from these pathways
are 6.1E-08 and 1.4E-06 based on average exposure and RME, respectively. Risk estimates for
construction workers at the Markland Avenue Quarry are below and at the bottom of U.S. EPA's (1990)
acceptable range.
Current and Future Onsite Trespassers
Incremental cancer risk estimates for people who may trespass onto the Quarry currently or in the future
are shown in Table ES-1. Trespassers are evaluated for incidental ingestion of soil, dermal contact with
soil, incidental ingestion of surface water, and dermal exposure to contaminants in surface water.
Total estimated cancer risks for incidental soil ingestion by trespassers based on average exposure and
RME are 5.6E-06 and 2.3E-05, respectively. Arsenic contributes 87 and 68 percent to these risks,
respectively. Potential risks for trespassers from incidental ingestion of soil are in the middle of the range
that is generally considered acceptable by U.S. EPA. Estimated cancer risks from dermal exposure are
1.3E-06 and 2.8E-05 for average exposure and RME, respectively. Benzo(a)pyrene and
dibenz(a,h)anthracene are the main contributors to these risks.
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Estimated total cancer risks from exposure to soil for trespassers are 6.9E-06 and 5.1E-05 for average and
RME, respectively. These risks are within U.S. EPA's (1990) acceptable risk range.
Since little guidance or site-specific information is available for evaluating potential exposures for
trespassers, only RME is evaluated for contact with sediment and surface water. For incidental ingestion
of surface water by current and future onsite trespassers, incremental cancer risk based on RME is 2.2E-06.
This risk is at the bottom of the acceptable risk range. For dermal contact with surface water at the
Markland Avenue Quarry by current and future onsite trespassers, estimated risk based on RME is 3.7E-06
(Table 6-4) indicating that significant risk from this exposure pathway is not expected. Exposure to
surface water is not expected given the poor water quality (pH of 12 or greater) and such exposures are
only evaluated to provide an indication of the degree of site-related exposure in this medium. Estimated
risks from exposure to surface water are therefore not added to other risk estimates in the calculation of
total cancer risk for trespassers.
Noncancer Risk Estimates
Noncarcinogenic health effect estimates from exposure to contaminants at the Quarry are estimated for
current and future offsite residents, future onsite residents, future onsite commercial/ industrial workers,
construction workers, and current and future onsite trespassers. Noncarcinogenic risks at the Markland
Avenue Quarry are summarized in Table ES-2 (Appendix C) and discussed below.
Current and Future Offsite Residents
Current and future offsite residents near the Quarry are evaluated for incidental ingestion of soil and
dermal contact with soil when working and playing in their yards. Total His for'soil ingestion by current
and future offsite residents near the Quarry are 0.9 and 2.8 for CTE and RME, respectively. The total HI
based on RME is greater than 1, suggesting a potential for adverse health effects for this exposure scenario.
Since the RME HQ for arsenic (2.7) also exceeds unity, it is not necessary to separately evaluate potential
noncancer health effects for different target organs.
Dibenz(a,h)anthracene is the only non-metal COPC selected for offsite residential soil. Noncarcinogenic
toxicity criteria are not available for this chemical. Health effects from dermal contact with soil by future
offsite residents near the Quarry were therefore not estimated.
Since noncarcinogenic health effects were not evaluated for the dermal exposure pathway these total His
are identical to those from incidental ingestion of soil. The HI from RME (2.8) exceeds unity, indicating a
potential for adverse noncancer health effects from exposure to soil by current and future offsite residents
near the Quarry.
Future Onsite Residents
Noncarcinogenic health effects estimates for ingestion of soil by future onsite residents on the Quarry
based on CTE and RME are 1.5 and 6.4, respectively. The total HI based on RME exceeds unity,
suggesting a potential for adverse health effects from ingestion of soil for future onsite residents. Since the
HI for the soil ingestion pathway is greater than one, further evaluation of effects on different target organs
is necessary. The RME HQ for arsenic (3.6) exceeds one, which indicates that there is a potential for
adverse Noncancer health effects.
Estimated His for dermal contact with soil by future onsite residents at the Quarry are 0.03 and 0.8 for
average exposure and RME, respectively. Since the His are less than unity, adverse health effects from
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dermal contact with soil is therefore not likely for future onsite residents.
Estimated total His from these pathways are 1.5 and 7.1 based on average exposure and RME,
respectively. The His exceed unity, indicating that there is a potential for adverse Noncancer health effects
for future onsite residents who may contact soil at the Quarry.
Soil gas data for the Markland Avenue Quarry indicate that there are significant releases of VOCs in some
areas of the Quarry. The evaluation suggests that inhalation of VOCs released to indoor air could result in
adverse Noncancer health effects, if development was to occur at the Quarry.
Current and Future Onsite Commercial/Indus trial Workers
Current and future commercial/industrial workers at the Quarry are evaluated for incidental ingestion of
soil, dermal contact with soil, and inhalation of VOCs released from buried wastes and drums into indoor
air. Potential exposure pathways are thought to be incomplete for current commercial/industrial workers at
the Markland Avenue Quarry, risk estimates are, however, developed for future workers at the Quarry.
Estimated His for incidental ingestion of soil by future onsite commercial/industrial workers at the Quarry
are 0.1 and 0.5 for average exposure and RME, respectively. Arsenic is the main contributor to these His.
Estimated Noncancer health effects for future onsite commercial/industrial workers at the Quarry from
dermal exposure to contaminants in soil are 0.006 and 0.02 for average exposure and RME, respectively.
The His are less than unity, suggesting that adverse health effects from dermal contact with soil are not
expected for future onsite commercial/industrial workers. Total Noncancer health effects estimates for
commercial industrial workers at the Quarry from incidental ingestion of soil and dermal contact with soil
are 0.15 and 0.5, based on average exposure and RME, respectively. The His are less than unity,
suggesting that adverse Noncancer health effects from exposure to soil are not likely for future onsite
commercial/industrial workers at the Markland Avenue Quarry.
Releases of vapors from buried wastes and drums into indoor air is a potentially complete exposure
pathway for future onsite commercial/industrial workers. This pathway is evaluated on a sitewide basis.
This pathway may result in adverse health effects for commercial/industrial workers, if development took
place in areas of the quarry where releases are occurring.
Future Onsite Construction Workers
Future onsite construction workers at the Quarry are evaluated for incidental ingestion of soil and dermal
contact with soil. Estimated His for incidental ingestion of soil by future onsite construction workers at the
Quarry are 0.05 and 0.8 for average exposure and RME, respectively. Arsenic is the main contributor to
these estimates. Estimated His for future onsite construction workers at the Quarry from dermal exposure
to contaminants in soil are 0.002 and 0.01 for average exposure and RME, respectively. Total HI estimates
for future onsite construction workers at the Markland Avenue Quarry are 0.05 and 0.8 for average
exposure and RME. These estimates are almost entirely from the soil ingestion pathway. Dermal exposure
contributes little to overall Noncancer health effects. The His are less than unity, suggesting that adverse
health effects from contact with soil are unlikely for future onsite construction workers at the Markland
Avenue Quarry.
Current and Future Onsite Trespassers
Current and future trespassers at the Markland Avenue Quarry are evaluated for incidental ingestion of soil
and surface water, and dermal contact with soil and surface water.
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Noncancer health effects estimates for incidental ingestion of soil by current and future onsite trespassers
are 0.1 and 0.5 based on average exposure and RME, respectively. Estimated His for dermal contact with
soil by trespassers onto the Quarry are 0.009 and 0.3 for average exposure and RME, respectively. For
trespassers at the Quarry, total estimated His for exposure to contaminants in soil are 0.1 and 0.8 for
average exposure and RME, respectively. The His are less than unity suggesting that adverse health
effects from ingestion of soil and dermal contact with soil are not likely to occur for the current and future
trespasser.
Exposure to surface water is not likely given the very poor water quality (pH of 12 or greater). However,
risks from exposure to quarry water are presented to provide an indication of the degree of site-related
contamination in this medium. Estimated His from exposure to surface water are therefore not added to
other Noncancer health effects estimates for trespassers. Only RME is evaluated for exposure to surface
water at the Quarry. The calculated HI for RME for ingestion of quarry water is 0.1. The total HI for
RME for dermal contact with quarry water is approximately 0.5. This suggests no significant risk for
ingestion or dermal contact of surface water while swimming in the Quarry.
Risks Associated with Exposure to Lead
Potential exposures to lead in soil at the Markland Avenue Quarry are evaluated for current and future
onsite trespassers, future onsite residents, and future onsrte commercial/industrial workers. Potential
exposures to lead by current offsite residents are not evaluated since lead is not considered a COPC for
offsite residential soils. Future onsite residential exposures are quantified for infants to 6-year-old
children, and worker exposures are quantified for adults. Since the IEUBK model evaluates potential
exposures to lead for young children, trespassers are assumed to be 6 to 7 years old.
The IEUBK model results predict that 2.39, 0.77, 0.31, and 0.49 percent of children trespassing onto lead
exposure areas A, B, C, and D (see Appendix A, Figure 4a) of the Markland Avenue Quarry may have
blood lead concentrations of 10 ug/dL or greater. According to U.S. EPA (1994a) guidelines from
exposures to lead, IEUBK results suggest that significant risk from exposure to lead in soil is not expected
for children who may trespass onto the Markland Avenue Quarry.
Fetal blood lead levels were 7.88, 6.85, 6.21, and 6.5 ug/dL for pregnant women who may become
exposed to lead in soil in the lead exposure areas. Predicted ninety-fifth percentile blood lead
concentrations for all exposure areas at the Quarry are less than the "acceptable" fetal blood lead
concentration for all exposure areas evaluated.
For the future onsite resident at the Quarry, the IEUBK model was run in the batch mode per U.S. EPA
request. This approach uses each lead data point from this source area. The cumulative results of the
batch mode run demonstrates that there is a 0.21 percent probability that the blood lead concentrations for
children residing at the Quarry may be 10 ug/dL or greater. The cumulative batch mode IEUBK modeling
results suggest-that significant risk from exposure to lead in soil is not expected for children who may
reside at the Markland Avenue Quarry.
Main Plant
COPCs selected for the Main Plaint were based on an industrial/commercial future land use scenario.
COPCs selected for on-site surface and subsurface soil include: benzo(a)anthracene, benzo(a)pryene,
benzo(b&k)fluoranthene, dibenzo(a,h)anthracene, indeno(l,2,3-cd)pryene, Aroclor-1242, Aroclor-1248,
Aroclor-1254, Aroclor-1260, and lead. In addition, although soil gas results (VOCs) were not used in the
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RA COPC development (i.e., there are no human health impacts), VOCs are considered COPCs for the
Main Plaint since they may potentially impact groundwater at the CSSS. These COPCs include: 1,2-
dichloroethene and trichloroethene. COPCs selected for shallow groundwater include 1,1-dichloroethene,
1,2-dichloroethene (total), benzene, chloroform, cis-l,2-dichloroethene, tetrachloroethene, trichloroethene,
vinyl chloride, Aroclor-1242, Aroclor-1248, and manganese.
Four different receptor groups are evaluated for the Main Plant area, current offsite residents, future onsite
commercial/industrial workers, future onsite construction workers, and current and future onsite
trespassers. Residential exposures are quantified for 1- to 6-year-old children and adults, and exposures
for trespassers are quantified for 6- to 14-year-old children. Worker exposures are quantified for adults.
Both the CTE and RME exposure point concentrations are derived from data collected across the entire
approximately 183 acre source area. Cancer and noncancer risk/hazard estimates are based on these
values.
Cancer Risk Estimates
Carcinogenic risks for the Main Plant are summarized in Table ES-1 (Appendix C). Risks are estimated
based on both CTE and RME. The former are intended to represent typical exposures at the CSSS, the
latter represent exposures well above the average, but still within a possible range.
Current Offsite Residents
Current offsite residents near the Main Plant are evaluated for incidental ingestion of soil and dermal
contact with soil when working or playing in their yards. Cancer risk estimates for these pathways are
summarized in Table ES-1 (Appendix C) and are discussed below. It should be noted that the data for
offsite residential areas are only considered screening level. The purpose of the risk assessment is to
identify chemicals that may drive potential risks in offsite areas and to determine whether additional
characterization of offsite soils may be warranted. The analysis presented is meant to provide a general
indication of potential risks that may be associated with contamination in offsite soils.
Arsenic and benzo(b,k)fluoranthene are the only carcinogenic COPCs selected for residential soil near the
Main Plant. Estimated risks for these chemicals from incidental ingestion of soil are 5.5E-08 for
benzo(b,k)fluoranthene and 5.6E-06 for arsenic for average exposures and risks for RME are 8.4E-07 for
benzo(b,k)fluoranthene and 7.5E-05 for arsenic. Total cancer risks for incidental ingestion of soil are
5.7E-06 for average exposure and 7.6E-05 for RME. Average risk for the exposure pathway are below the
risk range and risks based on RME are near the top of U.S. EPA's acceptable (1990) risk range.
Dermal exposure to metals in soil is not considered significant and is not evaluated.
Benzo(b&k)fluoranthene is the only organic chemical selected as COPC for residential soil. Estimated
cancer risk from dermal exposure to this chemical in soil is 2.1E-07 for average exposure and 5.7E-06 for
RME.
Total cancer risks from incidental ingestion of soil and dermal contact with soil are 5.9E-06 and 8.2E-05
based on average exposure and RME, respectively. Approximately 96 percent of the risk from RME and
93 percent of the risk from average exposure are from incidental ingestion of soil. Estimated cancer risks
for current and future offsite residents near the Main Plant are in the middle and at the top of U.S. EPA's
acceptable range.
Future Onsite Commercial/Industrial Workers
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Future commercial/industrial workers at the Main Plant are evaluated for incidental ingestion of soil,
dermal contact with soil, and inhalation of volatile organics released to indoor air. Carcinogenic risks for
these exposure pathways are summarized in Table ES-1 and are discussed below.
Cancer risks from incidental ingestion of soil range from 2.8E-08 for indeno(l,2,3-cd)pyrene to 2.9E-07
for benzo(a)pyrene and dibenz(a,h)anthracene for average exposure. Cancer risks based on RME range
from 7.3E-07 for indeno(l,2,3-cd)pyrene to 2.5E-05 for Aroclor 1248. Total carcinogenic risks for
incidental soil ingestion are 1.1E-06 and 7.4E-05 for average exposure and RME, respectively. Aroclor
1248 and Aroclor 1254 are the main contributors to carcinogenic risks for this exposure pathway.
Estimated cancer risks from dermal exposure to COPCs in soil are 8.5E-07 and 2.0E-05 for average
exposure and RME, respectively. Benzo(a)pyrene, dibenz(a,h)anthracene and the PCBs contribute
approximately equally to these risks. Estimated total cancer risks from incidental ingestion of and dermal
contact with soil are 2.0E-06 and 9.4E-05 based on average exposure and RME, respectively. Total risks
for commercial/ industrial workers from exposure to contaminated soil are at the bottom and at the top of
U.S. EPA's acceptable range.
Based on soil gas sampling, the Main Plant does not appear to overlie significant levels of COPCs in soil
gas, therefore, significant release of VOCs into indoor air at the Main Plant is not expected. Risks from
inhalation of indoor air should be negligible for commercial/industrial workers at the Main Plant.
Future Onsite Construction Workers
Cancer risk estimates for incidental soil ingestion and dermal contact with soil by future onsite
construction workers are summarized in Table ES-1.
Carcinogenic risks for average and RME estimates for soil ingestion range from 2.IE-10 for indeno( 1,2,3-
cd)pyrene to 2.2E-09 for dibenz(a)anthracene and benzo(a)pyrene and from 1.5E-08 for indeno(l,2,3-
cd)pyrene to 5.2E-07 for Aroclor 1248. Total carcinogenic risk estimates for average exposure and RME
are 8.6E-09 and 1.5E-06, respectively. These risks are less than and at the bottom of U.S. EPA's
acceptable range. Estimated cancer risks from dermal exposure to soil are 6.2E-09 and 1.6E-07 for
average exposure and RME, respectively. Risks from dermal contact with soil are below U.S. EPA's
(1990) acceptable risk range. Estimated total cancer risks (see Table ES-1) are 1.5E-08 and 1.7E-06 based
on average exposure and RME, respectively. Total risks associated with exposure to soil are below and at
the bottom of U.S. EPA's (1990) acceptable range.
Current and Future Onsite Trespassers
Current and future onsite trespassers at the Main Plant are evaluated for potential exposures from
incidental ingestion of soil and dermal contact with soil. Carcinogenic risks for future onsite trespassers
are summarized in Table ES-1 and are discussed below.
Average cancer risk estimates for incidental ingestion of soil are highest for dibenz(a,h)anthracene and
benzo(a)pyrene at 4.5E-07 in both cases and cancer risks based on RME are highest for Aroclor 1248 at
8.4E-06. Total carcinogenic risks from soil ingestion are 1.8E-06 and 2.5E-05 for average and RME
estimates, respectively. Aroclor 1242 and 1254 are the main contributors to risks from RME. Estimated
cancer risks for trespassers from dermal exposure to soil at the Main Plant are 1.4E-06 and 6.9E-05 for
average exposure and RME, respectively. Total cancer risk estimates for trespassers at the Main Plant
from incidental ingestion of soil and dermal contact with soil (see Table ES-1) are 3.2E-06 and 9.4E-05
based on average exposure and RME, respectively. Total average and RME carcinogenic risks for the
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trespasser scenario are within the 10"6 to 10~" range considered acceptable by the U.S. EPA (1990).
Noncarcinogenic Hazard Estimates
Noncarcinogenic risks at the Main Plant are summarized in Table ES-2 (Appendix C). Noncarcinogenic
health effects estimates for current offsite residents, future onsite commercial/ industrial workers, future
onsite construction workers, and current and future onsite trespassers scenarios are discussed below.
Current Offsite Residents •
Noncancer health-effects estimates for incidental ingestion of soil by offsite residents range from 5.6E-03
for zinc to 8.5E-01 for arsenic for average exposure and from 9.5E-02 to 2.40 for the same chemicals for
RME. Total His for average and RME estimates for the soil ingestion pathway are 0.9 and 2.7,
respectively. Since almost all of these risks are from exposure to arsenic, potential health risks from this
pathway can therefore be evaluated without subtracting effects from chemicals that affect different target
organs than arsenic. The HI based on RME exceeds unity for incidental soil ingestion greater than one;
potential health risks may therefore be associated with this exposure scenario. No organic noncarcinogenic
COPCs were selected for offsite residential soil near the Main Plant. Dermal exposure to soil is therefore
not evaluated for current and future offsite residents near the Main Plant.
Total His for offsite residents near the Main Plant from incidental ingestion of soil and dermal contact with
soil are 0.9 and 2.7 based on average exposure and RME, respectively. Since dermal exposures are not
evaluated, these estimates are identical to those from ingestion of soil. Since His based on RME exceed
unity, there is a potential for adverse health effects associated with exposure to soil by current offsite '
residents.
Future Onsite Commercial/'Industrial Workers
Noncarcinogenic hazard estimates for incidental ingestion of soil by future onsite commercial/ industrial
workers are 0.03 and 1.1 for average exposure and RME, respectively. Estimated His for dermal contact
with soil are 1.1E-02 and 2.3E-01 for average exposure and RME, respectively. These estimates are
entirely due to exposure to PCBs. Estimated total His from these pathways are 0.04 and 1.3 based on
average exposure and RME, respectively. The HI based on RME exceeds unity, suggesting that there is a
potential for adverse health effects from exposure to soil by commercial/industrial workers at the Main
Plant.
Future Onsite Construction Workers
Estimates of total noncarcinogenic health effects for the future onsite construction workers scenario are
0.009 and 1.6 for average exposure and RME, respectively. Aroclor 1242, 1248, 1254, and 1260
contribute almost entirely to these His, separate evaluation of chemicals based on their target organs is,
therefore, not necessary. Estimated His for dermal contact with soil are 0.004 and 0.1 for average
exposure and RME, respectively. Total His for future onsite construction workers at the Main Plant from
incidental ingestion of soil and dermal contact with soil are 0.01 and 1.7 based on average exposure and
RME, respectively. The HI based on RME exceeds unity for this exposure scenario, suggesting that some
measure to protect construction workers who may intensively contact soil at the Main Plant may be
justified.
Current and Future Onsite Trespassers
Estimates of Noncancer health effects from incidental ingestion of soil by current and future trespassers
onto the Main Plant are 0.04 and 1.1 for average exposure and RME, respectively. More than 99 percent
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of these HI estimates are from the polychlorinated biphenyls (Aroclor 1242, 1248, 1254, and 1260).
Estimated His for dermal contact with soil are 0.02 and 2.4 for average exposure and RME, respectively.
Most of the HI estimate is due to Aroclors 1242 and 1248. Estimated total His from these pathways are
0.06 and 3.5 based on average exposure and RME, respectively. Since the HI for RME exceeds unity, the
potential exists that exposure to soil by trespassers may result in adverse health effects.
Risks Associated with Exposures to Lead
Potential exposures to lead in soil at the Main Plant are evaluated for onsite trespassers and
commercial/industrial workers. Since the IEUBK model was developed to evaluate exposures to lead in
young children, trespassers are assumed to be 6 to 7 years old. Offsite residential lead in soil is a potential
concern based on sampling results; however, the sampling approach used was not intended to serve as the
basis of a numerical risk assessment for the offsite area. U.S. EPA is currently performing an EE/CA for
remediation of lead in residential soil near the Main Plant. Lead in offsite residential soil near the Main
Plant is therefore not further addressed in this Record of Decision.
Potential exposure to lead in children is evaluated using the IEUBK model (Version 99d). The IEUBK
model predicts that 0.77 percent of children trespassing onto Lead Exposure Area A of the Main Plant may
have blood lead concentrations of 10 ug/dL or greater (see Figure 5a). 13.64, 1.16, 0.35, 98.67, 7.75, and
0.04 percent of children trespassing onto exposure Areas B, C, D, E, F, and G (see Appendix A, Figure 5a)
may have blood lead concentrations of 10 ug/dL or greater. U.S. EPA (1994) considers risks from
exposures to lead unacceptable if the probability that children may have blood lead levels exceeding
10 ug/dL is greater than 5 percent. IEUBK modeling results suggest that significant risk from exposure to
lead in soil is not expected for children who may trespass onto areas A, C, D, F, and G of the Main Plant.
However, trespassing onto Areas B and E may be associated with significant health risk from exposure to
lead.
Adult exposures to lead are evaluated using the interim adult exposure methodology developed by U.S.
EPA (1996). The focus of this method is to estimate fetal blood lead levels based on exposure to lead in
soil by adult workers of child-bearing age. The method predicts 95th percentile fetal blood lead levels of
7.55, 13.07, 8.0, 6.87, 98.07, 11.31 and 5.58 ng/dL for female workers of childbearing age exposed to lead
in soil in exposure Areas A, B, C, D, E, F, and G, respectively (see Figure 5a). Ninety-fifth percentile fetal
blood lead concentrations should not exceed 10 ug/dL (U.S. EPA 1996). Predicted blood lead
concentrations for all exposure areas at the Main Plant are less than the "acceptable" fetal blood lead
concentration, except for exposure Areas B, E, and F. In Area E, fetal blood lead levels could theoretically
be as high as 98 ug/dL if female workers of childbearing age are exposed to lead in soil.
Slag Processing A rea
COPCs were selected for the Slag Processing Area based on a residential future land use scenario. COPCs
selected for on-site surface soil in the Slag Processing Area include lead and arsenic.
Potential exposures to contaminants associated with the Slag Processing Area are evaluated for the
following receptor groups: future onsite residents, future onsite commercial/industrial workers, future
onsite construction workers, and current and future onsite trespassers. All of these receptors are
quantitatively evaluated for incidental ingestion of soil. Residential exposures are quantified for 1- to 6-
year-old children and adults; trespassers are assumed to be 6- to 14-year-old children. Worker exposures
are quantified for adults. Both the CTE and RME exposure point concentrations are derived from data
collected across the entire approximately 9 acre source area. Cancer and Noncancer risk/hazard estimates
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are based on these values.
Cancer Risk Estimates
Carcinogenic risks for the Slag Processing Area are summarized in Table ES-1 (Appendix C).
Carcinogenic risks for the Slag Processing Area are discussed below.
Future Onsite Residents
Future onsite residents at the Slag Processing Area are evaluated for incidental ingestion of soil and dermal
contact with soil when working or playing in their yards. Cancer risk estimates for this pathway are
summarized in Table ES-1 (Appendix C).
Carcinogenic COPCs selected for residential soil at the Slag Processing Area are methylene chloride and
arsenic. For average exposures the estimated risks for these chemicals are 1 .OE-09 for methylene chloride
and 1.3E-05 for arsenic. Risks for RME are 2.7E-07 and 1.7E-04 for methylene chloride and arsenic,
respectively. Total cancer risks for incidental ingestion of soil are 1.3E-05 and 1.7E-04 for average
exposure and RME, respectively. Risks for this pathway are in the middle of U.S. EPA's (1990)
acceptable range. Estimated cancer risks from dermal exposure to soil are 1.6E-10 and 7.4E-07 for
average exposure and RME, respectively. Risks for this pathway are less than U.S. EPA's (1990)
acceptable range. Total cancer risk estimates for future onsite residents at the Slag Processing Area are
1.3E-05 and 1.7E-04 based on average exposure and RME, respectively. These risks are almost entirely
from incidental ingestion of soil. Total estimated cancer risks for average exposure and RME are in the
middle of and above U.S. EPA's (1990) acceptable range.
Future Onsite Commercial/Industrial Workers
Carcinogenic risks from ingestion of soil near the Slag Processing Area by future onsite
commercial/industrial workers are 9.5E-06 for average exposures and 7.2E-05 for RME. Estimated cancer
risks from dermal exposure to soil are 2.7E-10 and 2.0E-08 for average exposure and RME, respectively.
Total cancer risk estimates for future onsite commercial/industrial workers at the Slag Processing Area are
9.5E-06 and 7.2E-05 based on average exposure and RME, respectively. Carcinogenic risks for the future
onsite commercial/industrial worker scenario are within U.S. EPA's (1990) acceptable risk range.
Future Onsite Construction Workers
Cancer risk estimates for incidental ingestion of soil and dermal contact with soil by future onsite
construction workers are presented in Table ES-1. Estimated cancer risks for incidental ingestion of soil
by construction workers are 7.2E-08 for average exposure and 1.5E-06 for RME. Arsenic is the main
contributor to these risks. Estimated cancer risks from dermal exposure to soil are 2.0E-12 and 1.6E-10 for
average exposure and RME, respectively.
Total cancer risk estimates for future onsite construction workers at the Slag Processing Area from
incidental ingestion of soil and dermal contact with soil are 7.2E-08 and 1.5E-06 based on average
exposure and RME, respectively. These risks are below and at the bottom of U.S. EPA's (1990) acceptable
range.
Current and Future Onsite Trespassers
Carcinogenic risks for current and future onsite trespassers from incidental ingestion of soil at the Slag
Processing Area are 1.5E-05 for average exposure and 2.4E-05 for RME. Arsenic is the main contributor
to these risks. Estimated cancer risks from dermal exposure to soil are 4.3E-11 and 7.0E-08 for average
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63
exposure and RME, respectively. Total cancer risk estimates for trespassers onto the Slag Processing Area
are 1.5E-05 and 2.4E-05 based on average exposure and RME, respectively. Total cancer risk estimates
are within U.S. EPA's (1990) acceptable range.
Noncarcinogenic Hazard Estimates
Noncarcinogenic risks for the Slag Processing Area are summarized in Table ES-2 (Appendix C).
Noncarcinogenic health effects estimates at the Slag Processing Area are presented for future onsite
residents, future onsite commercial/industrial workers, future onsite construction workers, and current and
future onsite trespassers. Noncancer health effects for these scenarios are discussed below.
Future Onsite Residents
For future onsite residents at the Slag Processing Area estimated His for incidental ingestion of soil are 2.3
for average exposure and 8.9 for RME. Most of these risks are due to arsenic. Since the HQ for arsenic
and the HI for the RME are greater than 1, potential health risks may be associated with this exposure
pathway. Estimated His for dermal exposure to contaminants in soil are 2.8E-06 and 0.004 for average
exposure and RME, respectively.
Total His for future onsite residents at the Slag Processing Area from incidental ingestion of soil and
dermal contact with soil are 2.3 and 8.9 based on average exposure and RME, respectively. These risks
are almost entirely from incidental ingestion of soil. Risks from dermal contact with soil are negligible.
His for exposure to soil exceed unity, indicating that there may be a potential for adverse Noncancer
effects from exposure to soil for future onsite residents at the Slag Processing Area.
Future Onsite Commercial/Industrial Workers
HI estimates for incidental ingestion of soil by future onsite commercial/industrial workers are 0.2 and 0.7
for average exposure and RME, respectively. Estimated His for dermal exposure to contaminants in soil
are 1.1 E-06 and 1.3E-04 for average exposure and RME, respectively. The His for both pathways are less
than unity, suggesting that adverse Noncancer health effects from exposure to soil are not likely.
Total His for future onsite commercial/industrial workers at the Slag Processing Area from incidental
ingestion of soil and dermal contact with soil are 0.2 and 0.7 based on average exposure and RME,
respectively. These risks are almost entirely from incidental ingestion of soil. Risks from dermal contact
with soil are negligible. The His are less than unity, suggesting that adverse Noncancer health effects from
exposure to soil are not likely for future onsite commercial/industrial workers at the Slag Processing Area.
Future Onsite Construction Workers
Total noncarcinogenic His for incidental ingestion of soil by future onsite construction workers are 0.08
for average exposure and 1.1 for RME. Since the HI based on RME exceeds unity, adverse
noncarcinogenic health effects may therefore be associated with this pathway. Estimated His for dermal
exposure to contaminants in soil are 1.9E-07 and 7.6E-05 for average exposure and RME, respectively.
The His for dermal exposure are less than unity, suggesting that adverse Noncancer health effects from
exposure to soil are not likely for future onsite construction workers at the Slag Processing Area.
Total His from incidental ingestion of soil and dermal contact with soil for future onsite construction
workers at the Slag Processing Area are 0.08 and 1.1 based on average exposure and RME, respectively.
The HI for the RME for the combined pathways exceeds unity, suggesting a potential for adverse health
effects.
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Current and Future Onsite Trespassers
HI estimates for incidental ingestion of soil by onsite trespassers are 0.3 and 0.8 for average exposure and
RME. Almost all of these health effects are from exposure to arsenic. Estimated His for dermal exposure
to contaminants in soil are 8.4E-07 and 0.001 for average exposure and RME, respectively. Since His for
these pathways are less than unity, adverse Noncancer health effects are not expected for trespassers onto
the Slag Processing Area.
Total His from incidental ingestion of soil and dermal contact with soil for trespassers onto the Slag
Processing Area are 0.3 and 0.8 based on average exposure and RME, respectively. Since His for this
pathway are less than unity, adverse Noncancer health effects are not expected for trespassers onto the Slag
Processing Area.
Risks Associated with Exposure to Lead
The Slag Processing Area has mixed land use and is designated for residential and commercial/ industrial
exposures. Receptors evaluated for potential exposure to lead in this source area are child residents, child
trespassers, and adult workers.
The IEUBK model predicts that the risk of trespassers onto the Slag Processing Area having a blood lead
level in excess of 10 ug/dL is 2.11 percent. This suggest that risks from exposure to lead at the Slag
Processing Area are not likely for trespassers.
Adult exposure methodology predicts a 95 percentile fetal blood lead level of 7.74 ug/dL in women of
childbearing age exposed to lead in soil at the Slag Processing Area. Predicted fetal blood lead
concentrations in female workers of childbearing age exposed to lead at the Slag Processing Area are less
than the acceptable blood lead concentration. Excess risk for female workers at the Slag Processing Area
is therefore not expected.
For future onsite residents at the Slag Processing Area, the IEUBK model was run in the batch mode. This
approach uses each lead data point from this source area. The cumulative results of the batch mode run
demonstrates that there is a 38.16 percent probability that the blood lead concentrations for children
residing at the Slag Processing Area may be 10 ug/dL or greater. The cumulative batch mode IEUBK
modeling results suggest that significant risk from exposure to lead in soil is expected for children who
may reside at the Slag Processing Area.
Ecological Assessment:
Lagoon Area
Risks to ecological receptors in the Lagoon Area are principally from chemical stressors; however, the
ecology in this source area also shows signs of physical stress from the presence of slag materials in soil
and sediment. Significant impacts from this physical stressor occur at the community-level among
vegetation and the quality of potential terrestrial, semiaquatic and aquatic habitat in this source area is
diminished as a result. The major contributors of risk from chemical stressors for sediment and sludge are
acenaphthene, ethylbenzene, manganese, copper, lead, mercury, nickel and barium. Chromium and copper
are major contributors of risk in surface soil in the Lagoon Area waste piles. Lead and zinc are major
contributors of risk in surface water. Copper, lead, and mercury in sediment (sludge) are major
contributors of risk to aquatic receptors and great blue heron.
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65
Kokomo & Wildcat creeks
PCBs in creek sediment are the major contributors of risk to aquatic receptors, mink, and Indiana bat. Zinc
and cadmium also pose significant risk to aquatic receptors exposed to sediment; however PCB
contamination of creek sediment causes the greatest risk to these receptors and Indiana bat, which is an
endangered species. Lead and zinc in stream water in the Creeks are contributors of risk to aquatic
receptors, mink, and Indiana bat.
MarklandAvenue Quarry
Risks to ecological receptors in Markland Avenue Quarry are principally from chemical stressors.
However, the aquatic ecology of sediment and surface water is expected to be impacted by the high
alkalinity (pH 12) of the waterbody. The major contributors of risk for surface soil in Markland Avenue
Quarry are copper, chromium, and zinc. These COPCs in surface soil have low contributions from
background and represent HIGH risk to American robin with HQs of 33,523 (copper), 12,906 (chromium),
and 9,449 (zinc). Risks to robin were HIGH to MODERATE for lead (HQ=827) and nickel (HQ=502),
while the background contribution to COPC risk was 2, 14, 86, 43, and 49% (respectively) for these
COPCs. Cadmium, barium, and arsenic also shows significant risk to robin, but background contributions
are 86, 43, and 49% to these risks. Semi-quantitative risk estimates to generic wildlife receptors using
surface soil to benchmark comparisons showed MODERATE risks from zinc, PAHs, copper and
chromium; however, only copper and chromium (HQ=11) had low contributions from background.
Main Plant
Ecological risks in the Main Plant source area are due to chemical stressors identified in surface soil, but
slag materials in soil also produce significant physical stress on the vegetation. Major contributors of risk
for surface soil in the Main Plant are copper and PCBs (mostly Aroclor 1242). Other contributors include
zinc, lead, PAHs, cadmium, copper, and chromium
Slag Processing Area
Ecological risks in the Slag Processing Area source area are due to chemical stressors identified in surface
soil, however, slag materials in soil are also a significant physical stressor on vegetation. Nine
contaminants of potential concern (COPCs) were identified in surface soil from the Slag Processing Area
including 1 volatile and 8 inorganics (metals). Major contributors of risk for surface soil in the Slag
Processing Area are chromium, zinc, and copper. These COPCs have relatively low background
contributions, and represent HIGH risks to American Robin with Hazard Quotients (HQ) of 21,664 (for
chromium), 15,441 (zinc), and 12,800 (copper). Risks to robin were also HIGH for lead (HQ = 2,343),
however, it is not a major contributor to risk. With the exception of zinc which has 16 percent background
contributions to COPC risk, risks from the COPCs are principally site-related. The estimated risk to the
robin from cadmium is also significant, but contributions from background are 42 percent.
VII. Description of Alternatives
Remedial Response Objectives
The remedial response objectives for each source area at the CSSS are based on exposure levels and
associated risks posed by contamination within a source area and by contamination that may migrate from
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66
the source areas via site-wide groundwater. The results of the final RA identified the potential
contaminants of concern and the affected media for each source area which pose unacceptable risk to
human health and the environment. The remedial response objectives for the CSSS site are as follows by
media:
Groundwater:
Prevent the public from ingestion of shallow groundwater containing contamination in excess of
federal and state drinking water standards or criteria, or which poses a threat to human health.
Prevent the migration of contaminants from the source areas that would result in continued
degradation of site-wide groundwater, to the extent practicable.
Prevent the public from dermal contact with groundwater containing contamination in excess of
federal and state standards or criteria, or which poses a threat to human health.
Surface Water:
Prevent the migration of contaminants from the source areas that would result in continued
degradation of site-wide surface water, to the extent practicable.
Prevent the public from incidental ingestion and direct contact with surface water containing
contamination in excess of federal and state standards or criteria, or which pose a threat to human
health.
Prevent surface water impacts to the ecological environment.
Sojls. Sludges. & Waste Piles:
Prevent the public from incidental ingestion and direct contact with sludge, soil, and waste piles
containing contamination in excess of federal and state soil standards or criteria, or which pose a
threat to human health.
Prevent the public from inhalation of airborne contaminants (from disturbed soil) in excess of federal
and state air standards or criteria, or which pose a threat to human health.
Sediments:
Prevent the public from direct contact with contaminated sediments in excess of federal and state
standards or criteria, or which pose a threat to human health.
Prevent the public from incidental ingestion of sediment containing contamination in excess of federal
and state standards or criteria, or which pose a threat to human health.
Prevent creek sediment impacts to ecological environment.
Restore creek sediments to levels which are protective of human health and the environment, to the
extent practicable, while minimizing adverse impact to the wetlands and minimizing the potential for
sediment to become suspended in the surface water column.
Other:
Prevent the public from ingestion of potentially contaminated fish from the creeks which may present
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a health risk; a fish advisory has already been posted.
The BRA performed for the CSSS addresses potential human health risks posed by the site in the absence
of cleanup actions. The areas evaluated for human health risks include the four source areas (Main Plant,
Markland Avenue Quarry, Lagoon Area, and Slag Processing Area) and the two non-source exposure areas
(site-wide groundwater and Kokomo and Wildcat Creeks). The exposure hazards or human health risks
for each area are summarized in the Considered & Selected Alternatives Sections presented below. More
detailed descriptions of the risks are presented in the CSSS RI, FS, and BRA Reports available at the
Kokomo/Howard County Public Library (the Library) in the information repository and Administrative
Record.
Remedial Measures
A description of the retained remedial measures are listed below.
• Institutional Controls - deed restrictions, groundwater use restrictions, fencing, and monitoring to
limit future site usage to activities following the future use scenario and/or the site restrictions and
lessen the chance for exposure of local populations to site contaminants.
• Surface Controls - slope stabilization, erosion control, enhancement of existing vegetation.
• Containment - involves isolating areas of contaminated media through physical or hydraulic controls.
Containment technology types include capping, horizontal barriers, and vertical barriers.
• Vegetated Soil Cover - replace existing poorly vegetated as well as other vegetated areas with a new
soil layer and vegetation.
• Common Soil Cover (horizontal barrier) - replace or cover the existing surface with a common soil
layer and vegetation.
• Vertical Barriers (recovery wells or interception trenches) - control of horizontal migration of
contamination. Vertical barriers can be physical (e.g., slurry walls or HDPE-lined trenches) or
hydraulic (e.g., interception trenches or line of collection wells). Vertical barriers are constructed to
contain and prevent the migration of contaminated groundwater or leachate originating from
contaminated solids.
• Excavation - removal of contaminated soils within a specified area.
• Stabilization - the conversion of a solid material to a more chemically stable and less leachable form
by mixing them with a stabilizing agent; improves the strength and handling characteristics of soil,
wastes, sediments and sludges. Solidification/stabilization can be implemented either in situ or
aboveground.
• Biological treatment - processes that use contaminant-utilizing microbes to destroy organic hazardous
constituents and form less toxic products.
• Aerobic Ex-Situ Biodegradation - This technology utilizes excavation and on-site treatment or
excavation and bioreactor treatment where the bacteria and nutrients are introduced into the waste
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68
material after excavation. In each of these cases, biodegradation may be enhanced by optimizing
environmental conditions (soil moisture content, temperature, oxidation-reduction potential, pH and
salinity) for contaminant degrading microorganisms. Ambient environmental conditions are more
easily maintained in a bioreactor unit than in situ. Aerobic degradation occurs with an absence or
minimal amount of air.
• Immobilization - processes implemented to inhibit migration of contaminants from contaminated
' solids through fixation.
• Vacuum Extraction Ex-Situ - aboveground treatment technique in which the soil gas within the
unsaturated zone is pumped out of the pore spaces via an applied vacuum
• Thermal - Technologies that involve driving organics out of solid material through heating.
• Thermal Desorption - a solids drying process whereby heat is applied to contaminated solids at
temperatures in the range of 300 to 1,000°F to drive off water and organic contaminants, resulting in a
clean dry solid matrix.
• Consolidation - minimize waste distribution by relocating wastes or excavated soils within a limited
area designed to contain the waste.
• Off-site Disposal - transfer waste or excavated soils to an approved off-site landfill.
• On-site Disposal - transfer waste or excavated soils to an approved on-site landfill.
• Groundwater Decontamination - use of extraction wells to contain and remove mass contaminants
from groundwater flow. Determining when to shut the extraction well system down will require an
evaluation of the contamination remaining in groundwater to determine if there are accedences of
federal and state standards and/or deviations from the acceptable cumulative Hazard Index.
The retained remedial measures are then combined to form site-wide remedial alternatives. The
alternatives evaluated are listed below.
Summaries of Remedial Alternatives Considered
ForOUl:
Common Actions to the OU1 Alternatives, except No Action
* Groundwater Use Restrictions
• Collect Shallow Groundwater and Dispose Off-site at Kokomo Wastewater Treatment Plant
Alternative MM-1:
• No Action
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69
Time to Complete Construction:
Monitoring Requirements (only):
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
0 months
200+ yrs. monitoring
$0
$0
$0
Alternative MM-2:
.Natural Attenuation of Intermediate and Lower Groundwater
Time to Complete Construction:
Groundwater Monitoring &
Collection Requirements:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
12 to 18 months
200+ yrs.
$3,873,000
$223,000
$5,532,000
Alternative MM-3:
Collect Intermediate and Lower Groundwater and Dispose Off-Site at WWTP
Time to Complete Construction:
Groundwater Monitoring &
Collection Requirements:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
18 to 24 months
200+ yrs.
$1,431,000
$244000
$13,204,000
Alternative MM-4:
• Collect Intermediate and Lower Groundwater and Dispose Off-Site at Wildcat Creek
Time to Complete Construction:
Groundwater Monitoring &
Collection Requirements:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
18 to 24 months
200+ yrs.
$10,611,000
$244,000
$13384,000
Alternative MM-5:
Collect Intermediate and Lower Groundwater at Martin Marietta Quarry to Contain
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Contaminant within Current Boundaries
Dispose of Collected Groundwater Off-Site at WWTP
Natural Attenuation
Technical Impracticability (TI) Waiver Invoked
Time to Complete Construction:
Groundwater Monitoring &
Collection Requirements:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
18 to 24 months
200+ yrs.
$,013,000
$244000
$6,386,000
For OU2;
Common Actions to the OU2 Alternatives, except No Action
• Deed & Groundwater Use Restrictions
• RCRA Surface Impoundment Closure
Alternative SC-1L:
No Action
Time to Complete Construction:
Groundwater Requirements:
for Monitoring
for Collection/Treatment
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
0 months
0 years
0 years
$0
$0
$0
Alternative SC-2L:
Cap Elevated VOC Solids Areas
Time to Complete Construction:
Groundwater Requirements:
for Monitoring
for Collection
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
2 to 3 years
30 years
0 years
$29,039,000
$61,600
$29,967,000
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Alternative SC-3L:
Cap Contaminated Solids
Elevated VOC Solids Removal
Collect and Contain Shallow Groundwater with Interception Trench System and Dispose
Off-Site at WWTP
Time to Complete Construction:
Groundwater Requirements:
for Monitoring
for Collection
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
2 to 3 years
30 years
30 years
$35,787,000
$96,000
$36,812,000
Alternative SC-4L:
Excavate Contaminated Solids and Consolidate On-Site
Collect and Contain Shallow Groundwater with Expanded Interception Trench System
and Dispose Off-Site at WWTP
Time to Complete Construction:
Groundwater Requirements:
for Monitoring
for Collection
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
2 to 3 years
30 years
30 years
$43,919,000
$146,600
$44,746,000
For OU3;
There are NO Common Actions to the OU3 Alternatives.
Alternative SC-1C:
No Action
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
0 months
$0
$0
$0
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72
Alternative SC-2C:
Restricted Access by fencing and sign postage
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
12 months
$460,000
$96,000
$1,147,000
Alternative SC-3C:
Contain Contaminated Sediment In-Place
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
18 months
$7,062,000
$103,000
$7,890,000
Alternative SC-4C:
Excavate Contaminated Sediment and Consolidate On-Site
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
18 months
$12,312,000
$20,000
$12,560,000
For OU4:
Common Actions to the OU4 Alternatives, except No Action
• Groundwater Use Restrictions
• Excavate Contaminated Sediment from Quarry Pond
• Backfill Quarry Pond
Alternative SC-1Q:
• No Action
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Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
0 years
SO
$0
$0
Alternative SC-2Q:
Cap Contaminated Solids/Dispose of Quarry Sediment at Off-Site Landfill
Deed Restrictions
Time to Complete Construction:
Time to Attain MCLs:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
12 to 18 months
30 years
$16,519,000
$130,000
$17,281,000
Alternative SC-2.SQ:
Cover Contaminated Solids with Common Soil
Dispose of Quarry Sediment in Lagoon Area CAMU
Contain & Collect Shallow Groundwater & Dispose at WWTP
Deed Restrictions
Time to Complete Construction:
Time to Attain MCLs:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
24 to 36 months
10 to 15 years
$10,234,000
$168,000
$11,163,000
Alternative SC-3Q:
Cap Contaminated Solids/Removal of Elevated VOC Solids
Dispose of Contaminated Sediment at Off-Site Landfill
Contain and Collect Shallow Groundwater and Dispose Off-Site at WWTP
Deed Restrictions
Time to Complete Construction:
Time to Attain MCLs:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
24 to 36 months
10 to 15 years
$30,679,000
$168,000
$31,608,000
Alternative SC-4Q:
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Excavate Contaminated Solids and Dispose Off-Site
Collect and Contain Shallow Groundwater and Dispose Off-Site at WWTP
Time to Complete Construction:
Time to Attain MCLs:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
3 to 4 years
10 to 15 years
$350,528,000
$162,000
$351,272,000
For OU5:
Common Actions to the OU5 Alternatives, except No Action
* Groundwater Use Restrictions
• Elevated VOC Solids Removal and On-Site Disposal
Alternative SC-1M:
No Action
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
Alternative SC-2M:
Deed Restrictions
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
Alternative SC-3M:
0 years
$0
$0
$0
15 years
$1,460,000
$108,000
$2,145,000
Cap Contaminated Solids
Collect & Contain Shallow Groundwater and Dispose Off-Site at WWTP
Deed Restrictions
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Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
15 years
$4,312,000
$108,000
$4,818,000
Alternative SC-3.5M:
Excavate PCB Solids along Kokomo Creek and Dispose On-Site
Install Common Soil Cover
Collect & Contain Shallow Groundwater and Dispose Off-Site at WWTP
Deed Restrictions
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
15 years
$7,000,000
$36,000
$7,747,000
Alternative SC-4M:
Excavate Contaminated Solids and Consolidate On-Site
Collect & Contain Shallow Groundwater and Dispose Off-Site at WWTP
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
15 years
$19,606,000
$151,000
$20334,000
For OU6;
There are NO Common Actions to the OU6 Alternatives.
Alternative SC-1S:
No Action
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
0 months
$0
$0
$0
Alternative SC-2S:
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76
Regrade Piles
Stabilize Creek Bank
Deed Restrictions
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
Alternative SC-3S:
12 to 18 months
$ 2,622,000
$0
$ 2,622,000
Cap Contaminated Solids
Deed Restrictions
Stabilize Creek Bank
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
12 to 18 months
$ 3,045,000
SO
$ 3,045,000
Alternative SC-3.5S:
Regrade Slag Pile to Level Site
Install Protective Common Soil Cover Over Contaminated Solids
Deed Restrictions
Stabilize Creek Bank
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
12 to 18 months
$2,420,000
SO
$2,420,000
Alternative SC-4S:
Excavate Contaminated Solids and Consolidate On-Site
Time to Complete:
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
12 to 18 months
$ 25,622,000
$ 20,000
$ 25,622,000
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VIII. Summary of the Comparative Analysis of Alternatives
The National Contingency Plan (NCP), Section 300.430 (f)(I), requires that the alternatives considered for
the final remedy be evaluated on the basis of the nine evaluation criteria.
In order to minimize the potential or prevent the exposure to hazardous materials, IDEM and EPA is
proposing the cleanup of the source areas associated with the CSSS. In addition, the groundwater
underlying the CSSS has been identified as a threat to human health. The considered cleanup alternatives
for each source area and the side-wide groundwater have been summarized above. The Feasibility Study
(FS) Report (available in the Administrative Record of the information repository) contains a more
complete and detailed description and evaluation of the cleanup alternatives considered. The purpose of
the detailed evaluation of alternatives is to provide enough relevant information of each alternative so that
each may be evaluated against the nine criteria specified by the NCP. The alternatives are then compared
against each other to identify the advantages and disadvantages and identify a preferred cleanup alternative
for the source areas and site-wide groundwater. The detailed analysis of the alternatives includes the
following steps:
• Further define each alternative with respect to the volumes or areas of contaminated media to be
addressed, the technologies to be used, site specific application of the technologies, and any
performance requirements associated with those technologies; and
• Create a summary profile of each alternative, and assess the alternative against the evaluation
criteria specified in the NCP.
The evaluation criteria for this analysis include (1) Overall protection of human health and the
environment; (2) Compliance with Applicable or Relevant and Appropriate Requirements; (3) Long-term
effectiveness and permanence; (4) Reduction of contaminant toxicity, mobility, or volume through
treatment; (5) Short-term effectiveness; (6) Implementability; (7) Costs; (8) Support Agency Acceptance;
and (9) Community Acceptance. Two of the nine criteria - support agency acceptance and community
acceptance - are modifying criteria. The remaining seven criteria are divided into two groups - the
threshold criteria and the balancing criteria. The nine criteria are described below. A comparison of the
alternatives with regard to the nine criteria follows their description. The tables in Appendix B also
present the analysis and comparison of the alternatives for the six operable units.
Threshold Criteria
The threshold criteria relate to statutory requirements that each alternative must satisfy in order to be
eligible for selection. These criteria are as follows:
1. Overall Protection of Human Health and the Environment addresses whether a remedy provides
adequate protection and describes how risks posed through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether a remedy will meet all of the applicable or relevant and
appropriate requirements of Federal and State environmental statutes and/or provides grounds for
invoking a waiver.
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Balancing Criteria
The balancing criteria are the technical criteria that are considered during the analysis. These criteria are
described as follows:
3. Long-Term Effectiveness and Permanence refer to the amount of risk remaining at a site and the
ability of a new remedy to maintain reliable protection of human health and the environment, over
time, once cleanup goals have been met. Factors that will be considered, as appropriate, include the
following:
• Magnitude of residual risk from untreated waste or treatment residuals remaining at the completion
of the remedial activities. The characteristics of the residuals should be considered to the degree
that they remain hazardous, taking into account their volume, toxicity, mobility, and propensity to
bioaccumulate.
• Adequacy and reliability of controls, such as containment systems and institutional controls, that
are necessary to manage treatment residuals and untreated waste. This factor addresses, in
particular, the uncertainties associated with land disposal, with respect to providing long-term
protection from residuals; the assessment of the potential needs to replace technical components of
the alternative, such as a cap, extraction wells, or treatment system; and the potential exposure
pathways and risks posed should the remedial action need replacement.
4. Reduction of Toxicity. Mobility, or Volume through Treatment is the degree to which alternatives
employ recycling or treatment to reduce the toxicity, mobility, or volume of contamination, including
how treatment is used to address the principal threats posed by the site. Factors that will be
considered, as appropriate, include the following:
• The treatment or recycling processes the'alternatives employ and the materials they will treat;
• The amount of hazardous substances, pollutants, or contaminants that will be destroyed, treated, or
recycled;
• The degree of expected reduction in toxicity, mobility, or volume of the waste due to treatment or
recycling, and the specification of which reduction(s) are occurring;
• The degree to which the treatment is irreversible;
• The type and quantity of residuals that will remain following treatment, considering the
persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous substances and
their constituents; and
• The degree to which treatment reduces the inherent hazards posed by principal threats at the site.
5. Short-Term Effectiveness refers to the speed with which the remedy achieves protection, as well as
the remedy's potential to create adverse impacts on human health and the environment that may result
during the construction and implementation period.
6. Implementability is the technical and administrative ease or difficulty of implementing the cleanup
alternatives. The following types of factors are analyzed:
• Technical feasibility, which includes technical difficulties and unknowns associated with the
construction and operation of the technology; the reliability of the technology; the ease with which
additional remedial actions may be undertaken; and the degree to which the effectiveness of the
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remedy can be monitored;
• Administrative feasibility, including activities needed to coordinate with other offices and
agencies; and the ability and time required to obtain any necessary approvals and permits from
other agencies (for off-site actions and wetland impacts); and
• Availability of services and materials, including the availability of adequate off-site treatment,
storage capacity, and disposal capacity and services; the availability of necessary equipment and
specialists, and provisions to ensure any necessary additional resources; the availability of services
and materials; and the availability of prospective technologies.
7. Cost addresses the following:
• Capital costs, including both direct and indirect costs;
• Annual operation and maintenance costs (O&M);
• Cost of periodic replacement of system components; and
• Net present value of capital and O&M costs based on the estimated time for the remedial action to
achieve cleanup goals.
Capital costs consist of direct (construction) and indirect (nonconstruction and overhead) costs. Direct
costs include expenditures for the equipment, labor, and materials necessary to install remedial actions.
Indirect costs include expenditures for engineering, financial, and other services that are not part of actual
installation activities, but are required to complete the installation of remedial alternatives.
Annual O&M costs are post-construction costs necessary to ensure the continued, effectiveness of a
remedial action. Periodic replacement costs are necessary when the anticipated duration of the remediation
exceeds the design life of the system component or components (i.e., groundwater extraction pumps).
A present worth analysis is used to evaluate expenditures that occur over different time periods, by
discounting all future costs to a common base year, usually the current year. Though the U.S. EPA FS
guidance (U.S. EPA, 1988) suggests a maximum time frame of 30 years, IDEM has requested that these
costs reflect the predicted duration of the remedial alternative, which may exceed 30 years in some cases.
EPA has agreed with this approach. A discount rate of 7 percent was used for the present worth analysis.
This allows the cost of remedial action alternatives to be compared on the basis of a single figure
representing the amount of money, if invested in the first year and disbursed as needed, would be sufficient
to cover all costs associated with the remedial action over its planned lifetime.
Modifying Criteria
The following are used to assess support agency and community acceptance to the alternatives.
8. Support Agency Acceptance is the criterion used to consider whether the support agency agrees with
the lead agency's analyses and recommendations of the RI/FS and the Proposed Plan.
9. Community Acceptance is the criterion used to evaluate the public comments and will be addressed
in the Record of Decision (ROD). The ROD will include a responsiveness summary that presents
public comments and the lead agency's responses to those comments. Acceptance of the
recommended alternative(s) will be evaluated after the public comment period.
Comparison of the alternatives with regard to the nine criteria
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Site-Wide Groundwater (Operable Unit 1)
The relative performance of each of the management of migration remedial alternatives for site-wide
groundwater is summarized in Table la in Appendix C. Each of these alternatives is discussed in greater
detail in the following subsections:
Alternative MM-1:
This alternative would not be protective of human health or the environment. Contaminated groundwater
would be allowed to continue uncontrolled migration away from the CSSS. This alternative would not
attain ARARs for groundwater contaminants in any of the three water-bearing zones (shallow,
intermediate, or lower) except via natural attenuation. Because there are no containment, collection, or
treatment operations as part of Alternative MM-1, this alternative would not provide long-term
effectiveness or permanence. No reductions in toxicity, mobility, or volume would result through
implementation. No short-term risks exist. Since no remedial actions would take place, this alternative
would be easily implemented. The total costs would be zero for this site-wide groundwater management of
migration alternative.
Alternative MM-2:
Alternative MM-2 would afford an appropriate level of protection to human health and the environment.
Reductions in exposure potential to site-wide groundwater contaminants and the extent of shallow
groundwater plumes above MCLs would be reduced through groundwater extraction and institutional
controls for groundwater use. Shallow groundwater for VOCs is fully addressed by the source area capture
zones and groundwater use restrictions that rely on natural attenuation for a period of up to 40 years. The
intermediate and lower water-bearing zone would be allowed to naturally attenuate over a period of 200
years and be collected by the Martin Marietta Quarry while it is in operation. It would operate probably for
another 30 to 50 years. The extent of groundwater above ARARs is predicted to extend to the west of the
quarry once operations cease. ARARs would eventually be attained for the shallow water-bearing zone,
and a TI waiver would be applied to the intermediate and lower zones for the DNAPL where it is not
practical to recover from fractured bedrock. Long-term effectiveness would be afforded for the shallow
water-bearing zone only, assuming that source controls would be employed at the identified CSSS
groundwater source areas. Through implementation of the shallow water-bearing zone extraction system,
volume, mobility, and toxicity of shallow groundwater contaminants would be significantly reduced.
Short-term risks to workers would result during groundwater extraction system installation and monitoring.
This alternative would be moderately easy to implement, and the associated total cost would be low to
moderate relative to the remaining site-wide groundwater remedial alternatives. This alternative attempts
to reduce the extent of groundwater above MCLs until ARARs are achieved by natural attenuation, which
would not occur for at least 200 years. It also builds upon the fate and transport results that impacts to site-
wide groundwater from the source areas are not significant relative to groundwater discharge
concentrations to surface water.
Alternative MM-3:
Alternative MM-3 would afford an appropriate level of protection to human health and the environment
similarly to Alternative MM-2. Through extraction and off-site disposal of groundwater from all three
water-bearing zones, the potential exposure pathways would be affected though with marginal
effectiveness in the fractured bedrock. This alternative would provide a long-term solution to site-wide
groundwater contamination in conjunction with use restrictions until ARARs are achieved. Volume,
mobility, and toxicity would be eventually reduced through the extraction and off-site disposal processes.
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groundwater contamination in conjunction with use restrictions until ARARs are achieved. Volume,
mobility, and toxicity would be eventually reduced through the extraction and off-site disposal processes.
However, the time to achieve cleanup would not be significantly shorter than other alternatives. For this
alternative, the time to achieve ARARs would again exceed 200 years. Short-term risks to workers would
result during groundwater extraction system installation and monitoring. This alternative would be
technically easy to implement though logistics of pipelines could be cumbersome, and the associated total
cost would be moderate to high relative to the remaining site-wide groundwater remedial alternatives. This
alternative attempts to collect contaminated groundwater/DNAPL from the less fractured bedrock with
marginal effectiveness and no real improvement to site-wide groundwater quality or attainment of ARARs.
Alternative MM-4:
Similarly to Alternative MM-3, Alternative MM-4 would afford an appropriate level of protection to
human health and the environment. The main difference is that extracted groundwater from the
intermediate and lower water-bearing zones would be discharged directly to the creeks under an NPDES
permit. Provided that permitted discharge levels of contaminants are not exceeded with pretreatment if
needed, the environmental threat would be minimal.. Through extraction and off-site disposal/direct
discharge of groundwater from all three water-bearing zones, the potential exposure pathways would be
effectively eliminated. This alternative would provide a long-term solution to site-wide groundwater
contamination in conjunction with use restrictions until ARARs are achieved. Volume, mobility, and
toxicity would be reduced through the extraction and off-site disposal processes. However, the time to
achieve cleanup would not be significantly shorter than other alternatives. For this alternative, ARARs
would not be achieved for at least 200 years. Short-term risks to workers would result during groundwater
extraction system installation and monitoring. This alternative would be technically easy to implement,
and the associated total cost would be moderate to high relative to the remaining site-wide groundwater
remedial alternative, although the difference in cost is negligible as compared to the companion remedy,
Alternative MM-3. This alternative attempts to collect contaminated groundwater/DNAPL from the less
fractured bedrock with marginal effectiveness and no real improvement to site-wide groundwater quality or
attainment of ARARs. This alternative may be logistically easier to implement than Alternative MM-3, but
would include meeting substantive requirements of a surface water discharge permit.
Alternative MM-5:
IDEM selects this alternative because it provides the best balance of the nine criteria. This alternative
received complete and total community acceptance from the public comment period of the Proposed Plan.
EPA has also given approval of this alternative. Alternative MM-5 would afford an appropriate level of
protection to human health and the environment, similar to the other considered alternatives except
alternative MM-1, which would provide no protective measures. Potential exposure pathways in all three
water-bearing zones would be minimized through extraction and off-site disposal (shallow zone) and
collection at the Martin Marietta Quarry (containment and institutional controls for the intermediate and
lower zones). This alternative would be very similar from an effectiveness and residual risk standpoint as
Alternative MM-4, in that intermediate and lower groundwater would be directly discharged to the creeks
under an NPDES permit. This alternative would provide for containment of contaminated
groundwater/DNAPL within its current boundaries, minimizing or eliminating migration to additional
receptors. Coupled with the groundwater use restrictions within these boundaries, protection of human
health in the short and long-term is greatly improved and relatively certain and controllable. Volume,
mobility, and toxicity would be reduced (significantly in the shallow zone) through the extraction and
disposal processes. The time to achieve cleanup for the lower and intermediate zones would not be
significantly shorter than the other alternatives. Short-term risks to workers would result during
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groundwater extraction system installation and monitoring. However, these risks can be minimized
through implementation of proper health and safety protocols. This alternative could provide a logistical
challenge for implementation due to assuming operation of the quarry beyond its operational life (likely in
excess of 200 years) and the need for a permitted discharge of up to 3,200 gpm, yet it is still readily
implementable. The associated total cost would be cost effective, relative to the remaining site-wide
groundwater remedial alternatives. ARARs would not be achieved for at least 200 years. The result being
a Technical Impracticability Waiver being granted and invoked for the intermediate and lower water-
bearing zones. This alternative relies on the Martin Marietta Quarry to collect deeper groundwater without
the use of intermediate extraction wells. Since the predicted operational life of the Martin Marietta Quarry
is 50 years, IDEM would then assume operation and maintenance of the pumping station until ARARs are
achieved.
Lagoon Area (Operable Unit 2)
The relative performance of each of the source control remedial alternatives for the Lagoon Area is
summarized in Table 2a in Appendix B. Each of these alternatives is discussed in greater detail in the
following subsections. Within the total cost for alternatives SC-2L to SC-4L is the base cost for the RCRA
impoundment closure at approximately $27.6 million. Therefore, the large range of cost difference
between the No Action and the other alternatives is due largely to the RCRA impoundment closure. Each
of these alternatives is discussed in greater detail in the following subsections:
Alternative SC-1L:
No action would be taken at the site for this alternative. This'alternative would provide no additional
protection to human health or the environment for solid media and groundwater contaminants in the
Lagoon Area. Contaminated groundwater within the shallow water-bearing zone would continue to
migrate away from the source area with contaminant concentrations reduced to acceptable levels only
through natural attenuation and dispersion mechanisms. The fill area near the entrance could continue to
leach VOCs to groundwater, the DNAPL would not be addressed, and potentially buried drums if not
already leaking to groundwater would eventually.
Solid media contamination would not be addressed, and the potential exposure pathways with
unacceptable risks would remain until contaminant concentrations are reduced through natural attenuation
mechanisms. This pertains to all solid media in the Lagoon Area and creek corridor, including solid
materials within the impoundments, as well as contaminated soils and waste piles outside the
impoundments.
It is expected that the groundwater and solid media contamination would persist under this alternative and
ARARs would not be met for a significant period of time. Because there are no treatment options involved
with this alternative, there would be no reductions in toxicity, mobility, or volume of contaminants, except
through dispersion and natural attenuation mechanisms for groundwater. This alternative would be easily
implemented, with no associated costs to implement.
Alternative SC-2L:
This alternative would provide an appropriate level of protection to human health and the environment for
solid media and groundwater contaminants in the Lagoon Area. Contaminated groundwater within the
shallow water-bearing zone would continue to migrate away from the area until contaminant
concentrations are reduced to acceptable levels through natural attenuation and dispersion mechanisms.
However, groundwater use restrictions would prevent the likelihood of ingestion of contaminated
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groundwater in the Lagoon Area vicinity and the area where MCLs are exceeded. Capping of the elevated
VOC solids areas will reduce the impact of VOCs to groundwater through a reduction of infiltration and
natural soil washing. Most Lagoon Area and all the creek corridor solid media contamination would not be
addressed, and the potential exposure pathways would remain until contaminant concentrations are
reduced through natural attenuation mechanisms. Site restrictions would need to be implemented and
maintained in the long-term to be effective. Solid media within the surface impoundments, however,
would be addressed through the RCRA surface impoundment closure and solidification of sludge, thereby
eliminating the potential for direct contact with these materials as well as addressing mobility through in-
place closure. It is expected that shallow groundwater and a large portion of solid media contamination
would persist under implementation of this alternative and ARARs would not be met for approximately 10
years, primarily due to DNAPL and VOCs within the fill at the lagoon entrance. This time would increase
if buried drums were present and leaked in the future. Source control would be addressed through capping
of the elevated VOC solids areas. This would further reduce migration of VOCs via stormwater
infiltration and natural soil washing through the contaminated soils and into groundwater. Costs for this
alternative would be significantly higher than those associated with Alternative SC-1L, chiefly due to the
RCRA impoundment closure.
Alternative SC-3L:
This alternative would provide a high degree of protection to human health and the environment for solid
media and groundwater contaminants in the Lagoon Area. Containment and collection of shallow
groundwater via interception trenches would reduce the likelihood of shallow water-bearing zone
contaminant migration away from the site. Lagoon Area contaminated solid media would be addressed
through a combination of solidification and capping (RCRA impoundment closure), through removal and
on-site landfill disposal (elevated VOC solids areas), and through capping (PAH, PCB and metal
contaminated areas outside of the lagoons), thereby more permanently eliminating direct contact potential
routes of exposure and mobility. Access restrictions would no longer be needed for long-term
effectiveness, though groundwater use restrictions and deed restrictions would still be required. Overall,
this alternative would be moderately difficult to implement. Costs would be higher than those associated
with Alternative SC-2L. However, these additional costs provide more permanent effectiveness for solid
media, and the collection of shallow groundwater to reduce the extent of plume above VOC MCLs in this
area. Compliance with ARARs would be attained in approximately 6 years.
Alternative SC-4L:
IDEM selects this alternative because it provides the best balance of the nine criteria. This alternative
received acceptance from the public and approval by EPA. This alternative provides a high degree of
protection to human health and the environment for solid media and groundwater contaminants.
Containment and collection by use of the interception trenches would rapidly reduce shallow groundwater
contaminant concentrations and minimize the potential for contaminant migration. Lagoon Area
contaminated solid media would be addressed through a combination of solidification and capping (RCRA
impoundment closure) procedures with excavation and on-site landfill disposal (elevated VOC solids and
other contaminated areas outside of the lagoons), thereby permanently eliminating potential routes of direct
contact and the potential for migration. This alternative would also avoid potential transportation risks that
are associated with off-site disposal. This alternative would require design approval from the IDEM
RCRA program for the on-site landfill under the CAMU process. IDEM RCRA has granted approval for
the use the CAMU concept over the use of surcharging. The location of the landfill/CAMU would be
designed to maximize construction of compensatory floodplain storage and the reuse potential of the
property. The site use restrictions would still be required, but would be less extensive to allow for some
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excavation activities in those areas bordering West Markland Avenue. Source control options associated
with RCRA impoundment closure and solid media excavation/disposal would be implemented. Overall,
this alternative would be moderately difficult to implement since the use of the CAMU landfill will
necessitate remedial actions first occurring at the lagoons to prepare the area for accepting other source
area contaminated materials. Through proper Remedial Design, planning, and scheduling, implementation
difficulties can be minimized. Costs would be highest for the source control alternatives for the Lagoon
Area. The incremental costs associated with these actions would permanently isolate solid media.
Compliance with cleanup goals or drinking water standards (ARARs) may be attained in approximately 3
to 5 years, assuming that source areas and DNAPL are no longer present in the shallow water-bearing
zone. Also, groundwater collection costs were calculated for 30 years for planning and cost-estimation
purposes. This is also consistent with RCRA post-closure groundwater monitoring requirements and
compensates for the potential existence of unknown contaminant source areas and undiscovered pockets of
DNAPL.
Wildcat and Kokomo Creeks (Operable Unit 3)
The relative performance of each source control remedial alternative for Wildcat and Kokomo Creeks is
summarized in Table 3a in Appendix B. Each of these alternatives is discussed in greater detail in the
following subsections.
Alternative SC-1C:
This alternative would provide no additional protection to the environment for sediment contaminants in
Wildcat and Kokomo Creeks for the two miles of reach affected directly by CSSS operations and runoff.
In general, there is not a health issue for humans for sediment unless recreational use or trespassing would
occur. This alternative would not afford any protection to the environment in terms of aquatic species over
this portion of the creeks. This would have a local effect on the individual species as compared to the
general population in the creeks. Alternative SC-1C would not comply with the ARARs for contaminated
sediments, and may result in temporary noncompliance with surface water criteria if sediment becomes
suspended in the water column. Since there is no containment, removal, or treatment of sediment, the
long-term effectiveness of this alternative is low. In addition, the sediment may be transported downstream
via hydraulic transport during storm events. Continued contamination from upstream reaches would also
be an issue. There would be no reduction in toxicity, mobility, or volume of sediment contaminants
because there would be no treatment actions in this alternative. Since no remedial actions would be taken,
there would be no short-term risks to the community or the environment. Alternative SC-1C would have
no actions to implement, and the total cost would be zero.
Alternative SC-2C:
This alternative would provide limited additional protection to humans relative to sediment contaminants
in Wildcat and Kokomo Creeks for these two miles of creeks. Fence installation and sign posting may
deter trespassing and use of the creeks for recreational purposes. However, since the security fence around
the Main Plant property has proven only marginally affective as a deterrent to trespassers, it would be
reasonable to believe that a security fence encompassing a normally recreational area would be less
affective. Long-term effectiveness of fencing would also be marginal considering this is a floodway where
floods would likely destroy the fencing and create a hardship for maintenance and repair. This alternative
would not afford any additional protection to the environment in terms of aquatic species over this portion
of the creeks. This would have a local effect on the individual species as compared to the general
population in the creeks. Alternative SC-2C would not comply with the ARARs for contaminated
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sediments, and may result in temporary noncompliance with surface water criteria. Since there is no
containment, removal, or treatment of sediment, the long-term effectiveness of this alternative is low. In
addition, the sediment may be carried downstream via hydraulic transport during storm events. There
would be no reduction in toxicity, mobility, or volume of sediment contaminants because there would be
no treatment actions in this alternative. Since no remedial actions would be taken, there would be no
short-term risks to the community or the environment, but only to workers during environmental
monitoring procedures and fence installation.
Alternative SC-3C:
This alternative would provide an appropriate degree of protection to humans and the environment from
contaminated sediment in Wildcat and Kokomo Creeks. Installation of an articulated concrete matting
cover would prevent direct contact with contaminated sediment and prevent potential future transport. The
results of treatability testing of the creek sediment indicate that if left in-place, leaching of contaminants to
groundwater should not pose a problem. Alternative SC-3C would comply with ARARs for contaminated
sediments, although the contaminated media would remain in-place over the long-term, with only the
exposure pathways eliminated. The long-term effectiveness of this alternative is medium to high since
recontamination from existing upgradient sediment transport over the matting is an issue. Installation of a
matting would reduce the mobility of sediment-bound contaminants, and the likelihood of downstream
migration via hydraulic transport would be significantly reduced. Short-term risks to workers would be
present during cap and fence installation, as well as during monitoring events and the aquatic habitat
would be greatly disturbed. Alternative SC-3C would be implementable, but Army Corps permits would
be needed for the floodway, to fill creeks, and for impacts to aquatic habitat.
Alternative SC-4C:
IDEM selects this alternative because it provides the best balance of the nine criteria. This alternative
received complete acceptance from the public, including the local environmental group provided they
were given the opportunity to supply input on the design and implementation. EPA also approved of this
alternative. This alternative would provide the highest protection to humans and the environment from
sediment contaminants in Wildcat and Kokomo creeks. Removal of contaminated sediment and disposal
in an on-site landfill would eliminate existing exposure pathways. This alternative would comply with
ARARs for contaminated sediments. The long-term effectiveness of this alternative is high. Removing the
sediment would eliminate any possibility of downstream migration of sediment contaminants through
hydraulic transport. Significant aquatic habitat disruption would occur during implementation.
Alternative SC-4C would be technically more difficult to implement due to special design considerations
for removal, but meeting the substantive requirements of the necessary permits would be less cumbersome.
This alternative also requires that the Lagoon Area CAMU /landfill be completed to the point for
acceptance of sediments before this alternative can be implemented. Through appropriate design
development, design implementation, and timely funding, the landfill would be prepared to accept the
sediments without difficulty. The total cost for this alternative would be the highest (>$4.5M) of the four
alternatives, however, the level of protection to human health and the environment is much greater and
more permanent than the other alternatives.
Markland Avenue Quarry (Operable Unit 4)
The relative performance of each of the source control remedial alternatives for the Markland Avenue
Quarry is summarized in Table 4a in Appendix B. Each of these alternatives is discussed in greater detail
in the following subsections:
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Alternative SC-1Q:
This alternative would provide no additional protection to human health or the environment for sediment
media at the Markland Avenue Quarry. Alternative SC-1Q would not comply with the ARARs for
contaminated solids, groundwater, or surface water. Since there is no containment, removal, or treatment
of contaminated media, the long-term effectiveness of this alternative is low. There would be no reduction
in toxicity, mobility, or volume of contaminants because there would be no treatment actions in this
alternative. Since no remedial actions would be taken, there would be no short-term risks to the
community or the environment. Alternative SC- 1Q would be technically easy to implement, and no cost
would be associated with this remedial alternative for the Markland Avenue Quarry.
Alternative SC-2Q:
This alternative would provide an appropriate level of protection to human health and the environment.
Alternative SC-2Q would comply with the ARARs for some contaminated solids and surface water only
through some capping, sediment removal, and access restrictions that require long-term enforcement and
maintenance. ARARs for shallow groundwater would be achieved in approximately 30 years by natural
attenuation mechanisms. The long-term effectiveness of this alternative is low to moderate, based on the
premise that the surface water and contaminated solids exposure pathways are either eliminated or reduced,
but the surface soil capping is not permanent nor complete. The quarry pond would be filled in. Likewise,
VOC capping and pond sediment removal would limit or eliminate the mobility of solid media
contaminants. Short-term risks to workers and the environment would be present during capping and
filling of the quarry pond. Alternative SC-2Q would be technically easy to implement, although the total
cost would be higher than Alternative SC-1Q. A key benefit is utilizing the city of Kokomo WWTP with
no cost for disposal of collected groundwater.
Alternative SC-2.5Q:
IDEM selects this alternative because it provides the best balance of the nine criteria. This alternative was
widely accepted by the public and gained approval from EPA. This alternative would provide a high level
of protection in the short and long-term due to heavily contaminated sediment removal and
collection/containment of shallow groundwater. In addition to attaining ARARs for surface water and
solid media, ARARs would eventually be attained for the shallow water-bearing zone in approximately 15
to 20 years. The long-term effectiveness of this alternative is high. Surface water would be eliminated as
an exposure pathway. The volume, mobility and toxicity of shallow water-bearing zone groundwater
would be reduced. The volume, mobility and toxicity of the Quarry pond sediments through the removal,
dewatering, stabilization and placement in the on-site CAMU would also be reduced. Exposure to
contaminated solids, particularly the elevated VOC solids, would be eliminated through the cover system
and the deed restrictions on the property. Alternative SC-2.5Q would be similar to the implementability of
Alternative SC-2Q particularly with collected shallow groundwater being pumped directly to the city
sanitary sewer lines for treatment with sanitary wastes at the Kokomo WWTP. A big bonus would be the
total cost being significantly lower than Alternative SC-2Q, 3Q and 4Q. A key benefit is utilizing the City
of Kokomo WWTP at no cost for the disposal of collected groundwater.
Alternative SC-3Q:
This alternative would provide a level of protection similar to that afforded by Alternative SC-2Q, with
additional protection from groundwater contaminants through elevated VOC solids removal and collection
of shallow groundwater. Groundwater would be collected from the shallow water-bearing zone through
installation of a series of extraction wells, then disposed off-site. In addition to attaining ARARs for
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surface water and solid media, ARARs would eventually be attained for the shallow water-bearing zone in
approximately 20 years. The long-term effectiveness of this alternative is medium to high given the
capping, though the integrity of the cap must be retained through site restrictions and institutional controls.
In addition to eliminating surface water and reducing the mobility of solid media contaminants, volume,
mobility and toxicity of shallow water-bearing zone groundwater would be reduced. Short-term risks to
workers would be present during sediment removal, filling of the quarry pond, capping, elevated VOC
solids removal, installation of a groundwater containment system, as well as during monitoring events.
Alternative SC-3Q would be more difficult to implement from a technical standpoint. A key benefit is
utilizing the city of Kokomo WWTP with no cost for disposal of collected groundwater.
Alternative SC-4Q:
This alternative would provide the highest protection to human health and the environment from
contaminants at the Markland Avenue Quarry, but at the highest cost. The issue is what additional degree
of protection does this cost provide. The fate and transport analysis indicated that site-wide groundwater
discharge concentrations or time to achieve ARARs would not be significantly improved even with all
these additional actions. Therefore, though time to attain ARARs may decrease to 10 to 15 years for the
shallow groundwater, the added degree of protection may not be required based on calculated risk.
Both surface water and contaminated solid media would be eliminated from the site. As with Alternative
SC-4Q, groundwater within the shallow water-bearing zone would be collected and disposed off-site. In
addition to attaining ARARs for surface water and solid media, ARARs would be attained for the shallow
water-bearing zone in approximately 10 years. The long-term effectiveness of this alternative is high. -In
addition to eliminating surface water, the mobility of solid media contaminants would be eliminated by
placement in a landfill, and the volume, toxicity, and mobility of shallow water-bearing zone groundwater
would be reduced. Short-term risks to workers would be present during filling of the quarry pond,
excavation and disposal of contaminated solids, installation of a groundwater collection system, as well as
during monitoring events. Alternative SC-4Q would be difficult to implement from a technical standpoint.
Although the level of protection afforded by this alternative would be the highest of the Markland Avenue
Quarry alternatives, the total cost would also be the highest, primarily as a result of off-site disposal costs
for contaminated solids.
Main Plant (Operable Unit 5)
The relative performance of each of the source control remedial alternatives for the Main Plant is
summarized in Table 5a in Appendix B. Each of these alternatives is discussed in greater detail in the
following subsections:
Alternative SC-1M:
This alternative would provide no additional protection to human health or the environment for solid media
or groundwater at the Main Plant. Alternative SC-1M would not comply with ARARs for contaminated
solids or groundwater. Since there is no containment, removal, or treatment of contaminated media, the
long-term effectiveness of this alternative is low. There would be no reduction in toxicity, mobility, or
volume of contaminants because there would be no treatment actions in this alternative. Since no remedial
actions would be taken, there would be no short-term risks to the community or the environment.
Alternative SC-1M would have nothing to implement, and therefore, the total cost would be zero for this
remedial alternative for the Main Plant.
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Alternative SC-2M:
This alternative would provide an appropriate level of protection to human health and the environment.
Alternative SC-2M would comply with ARARs for contaminated solids through elimination of exposure
pathways via access restrictions. These require long-term enforcement and management. Groundwater at
the Main Plant would not attain ARARs, but the source of VOC contaminants in shallow groundwater
would be removed. Attainment of ARARs would be shallow water-bearing zone would be achieved in
approximately 40 years through natural attenuation. The long-term effectiveness of this alternative is low,
based on the premise that the groundwater and contaminated solids exposure pathways are neither
eliminated or reduced (with the exception of the VOC hot spot areas). Toxicity, mobility, and volume
would be largely unaffected under this alternative, with the exception of the VOC hot spots. Direct
exposure to VOC contaminated solids would be significantly reduced. Short-term risks to workers and the
environment would be present during VOC hot spot removal, fence installation, and environmental
monitoring procedures. Alternative SC-2M would be technically easy to implement, and the total cost
would be higher than Alternative SC-1M.
Alternative SC-3M:
This alternative would provide additional protection to human health and the environment from
contaminants at the Main Plant. Capping the contaminated solids would eliminate the route of direct
exposure though the long-term integrity must be protected. In addition, removal of VOC hot spots would
reduce the impact of source material from affecting groundwater quality in the vicinity of the Main Plant.
Also, collection of groundwater from the shallow water-bearing zone would reduce potential migration of
groundwater contaminants away from the Main Plant area. ARARs would be attained for contaminated
solids and eventually for the shallow water-bearing zone groundwater in approximately 15 years.
Although capping the contaminated solids would eliminate routes of human exposure, the contaminants
would remain in-place, and the potential for leaching would persist though at levels below MCLs. The
mobility of contaminated solids would be reduced through capping and removal, although the toxicity and
volume would be essentially unaffected. Volume, mobility, and toxicity of shallow water-bearing zone
groundwater would be reduced through collection and off-site disposal. Short-term risks to workers would
be associated with VOC hot spot removal, cap placement, groundwater collection trench installation, and
monitoring. Alternative SC-3M would be technically effective and moderate difficult to implement.
Although the level of protection would be high under this alternative, the corresponding total
implementation costs would also be higher than the previous alternatives. This alternative builds on the
fate and transport conclusion that the VOC contaminated groundwater in the shallow water-bearing zone
(fractured bedrock and overburden soil) can be addressed via collection.
Alternative SC-3.5M:
IDEM selects this alternative because it provides the best balance of the nine criteria. This alternative
received great acceptance from the public along approval from EPA. This alternative would provide a
high level of protection to human health and the environment from contaminants at the Main Plant.
Covering the contaminated solids would eliminate the route of direct exposure though the long-term
integrity must be protected, which would be achieved through the placing of use restrictions on the Main
Plant property. The removal of elevated VOC solids would reduce the volume of contaminants present
and the impact of source material from affecting groundwater quality in the vicinity of the Main Plant.
Also, collection of groundwater from the shallow water-bearing zone would reduce potential migration
of groundwater contaminants away from the Main Plant area. ARARs would be attained for
contaminated solids and eventually for the shallow water-bearing zone groundwater in approximately 15
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years. Volume, mobility, and toxicity of shallow groundwater would be reduced through collection and
off-site disposal. Short-term risks to workers would be associated with VOC and PCB solids removal,
cover system installation, groundwater collection trench installation, and monitoring. These risks would
be minimized by implementing proper health and safety protocols. Alternative SC-3.5M would be
technically effective and moderately difficult to implement, yet achievable.
Alternative SC-4M:
This alternative would provide a high level of protection to human health and the environment from
contaminants at the Main Plant. Under Alternative SC-4M, human exposure pathways to contaminated
solids would be eliminated though excavation and on-site landfill disposal. In addition, shallow water-
bearing zone groundwater would be remediated in the same fashion as for Alternative SC-3M and SC-
3.5M. ARARs would be attained for contaminated solids and eventually for shallow water-bearing zone
groundwater in approximately 10 years. In addition to attaining ARARs for solid media contamination,
this alternative would result in removal of the solid media contaminants from the site, further lessening the
potential for leaching of those contaminants into groundwater. Long-term effectiveness and permanence of
this alternative for solids would be high. Mobility of solid media contaminants would be reduced through
excavation and on-site disposal. In addition, volume, mobility, and toxicity of shallow water-bearing
contaminants would be reduced with limited effectiveness due to fractured bedrock. Short-term risks to
workers and the community may be realized during solids removal, trench installation, and monitoring
procedures. Alternative SC-4M would be moderately difficult to implement from a technical standpoint.
The associated implementation costs would also be the highest. The fate and transport analysis concluded
that the additional cost may not provide a significant or warranted reduction to site-wide groundwater risk.
Slag Processing Area (Operable Unit 6)
The relative performance of each of the source control remedial alternatives for the Slag Processing Area is
summarized in Table 6a in Appendix B. Each of these alternatives is discussed in greater detail in the
following subsections:
Alternative SC-1S:
This alternative would not be protective of human health or the environment. Under a residential future
use scenario, all potential exposure pathways would remain, including erosion to creeks. Alternative
SC-1S would not comply with the ARARs for contaminated solids. Since there is no containment,
removal, or treatment of contaminated media, the long-term effectiveness of this alternative is low. There
would be no reduction in toxicity, mobility, or volume of contaminants because there would be no
treatment actions in this alternative. Since no remedial actions would be taken, there would be no
short-term risks to the community, on-site workers, or the environment. Being a no action alternative,
Alternative SC-1S would be technically easy to implement and there would be no cost associated with its
implementation.
Alternative SC-2S:
This scenario for the Slag Processing Area would include regrading of the slag piles for use as fill in other
industrial/commercial areas on the site to eliminate a potential pathway of concern, and the placement of
riprap along the creek bank to prevent further erosion of slag material to the creek. Deed restrictions
would be necessary to minimize potential exposure to the remaining slag material. This alternative would
have a high degree of long-term effectiveness provided access restrictions controlled site access and slag
remained on-site. Rip-rap would prevent erosion of slag to the creeks. There would be some reduction in
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mobility of Slag Processing Area solid media contaminants. There would be some short-term risks
associated with pile regrading. Alternative SC-2S would also be technically easy to implement, but at a
somewhat higher total cost than Alternative SC-1S. This action is protective of groundwater since slag
does not leach.
Alternative SC-3S:
Under this alternative, pathways for human exposure would be significantly reduced. ARARs would be
attained through covering of the contaminated solids. The cap would afford long-term protection from
exposure to solid media contaminants provided it is maintained. An issue will be how to integrate the
construction of homes and excavating potential slag material without recontaminating the surface soil.
This may prove difficult, and a property use restriction may be warranted. Mobility of solid media
contaminants would also be reduced though the capping process and rip rap protection, although toxicity
and volume would be essentially unaffected. Short-term risks to the community and on-site workers would
be present due to the potential for dust emissions and direct contact during cap installation. This
alternative would also be technically easy to implement, and the costs would be somewhat higher than
Alternatives SC-1S and SC-2S.
Alternative SC-3.5S:
IDEM selects this alternative because it provides the best balance of the nine criteria. This alternative
received complete public acceptance, from the public and gained approval from EPA. Under this
alternative, pathways for human exposure would be significantly reduced. ARARs would be attained
through covering of the contaminated solids. The cover system would afford long-term protection from
exposure to solid media contaminants provided it is maintained. An issue will be how to integrate the
construction of homes and excavating potential slag material without recontaminating the surface soil..
This may prove difficult, and a property use restriction is anticipated. .Mobility of solid media
contaminants would also be reduced with the covering system and rip rap protection along the creek.
This alternative would be technically easy to implement, and the costs would be somewhat lower than
Alternatives SC-2S and SC-3S.
Alternative SC-4S:
This alternative would provide the highest level of protection to human health and the environment from
contaminants at the Slag Processing Area. Under Alternative SC-4S, human exposure pathways to
contaminated solids would be eliminated though excavation and on-site landfill disposal. ARARs would
be attained for contaminated solids. In addition to attaining ARARs for solid media contamination, this
alternative would result in removal of the solid media contaminants from the site, further lessening the
potential for leaching of those contaminants into groundwater and essentially eliminating the possibility of
future direct human contact. Long-term effectiveness and permanence of this alternative would be high.
Mobility of solid media contaminants would be reduced through excavation and on-site disposal.
Short-term risks to workers and the community may be realized during solids removal and disposal
procedures. Although Alternative SC-4S would provide the highest level of protection and remain easy to
implement from a technical standpoint provided the CAMU approach is approved by U.S. EPA. The
associated implementation costs are the highest by two orders of magnitude. Consideration must weigh the
cost of remediation with the need to develop the property. Since slag does not leach, Alternative SC-2S
satisfies ARARs. Capping allows site development but may prove difficult to maintain if construction
occurs. This alternative allows construction but provides no significant degree of added protection to the
environment or human health as compared to either Alternatives SC-2S or SC-3S.
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IX. The Selected Remedies
Site-Wide Groundwater (Operable Unit 1)
Remedial Alternative MM-5 is selected and consists of the following:
• Collect Intermediate and Lower Groundwater at Martin Marietta Quarry to Contain Contaminant
within Current Boundaries
• Dispose of Collected Martin Marietta Quarry Groundwater Off-Site
• Collect Shallow Groundwater and Dispose Off-site at Kokomo Wastewater Treatment Plant
• Natural Attenuation
• Technical Impracticability (TI) Waiver Invoked
• Groundwater Use Restrictions
Time to Complete Construction: 18 to 24 months
Groundwater Monitoring &
Collection Requirements: 200+ yrs.
Capital Cost: $,013,000
First Year O&M: $244000
30-Yr. Net Present Worth Cost: $6,386,000
Alternative MM-5 consists of the collection of the shallow groundwater by extraction wells installed along
the creeks or within the groundwater contamination plumes. Extracted shallow groundwater would be
discharged via underground piping directly to the city sanitary sewer system for off-site treatment and
disposal at the Kokomo Wastewater Treatment Plant (WWTP). Shallow groundwater is covered in more
detail within each of the source control operable units. The intermediate and lower water-bearing zones
would be addressed through continued operation of the Martin Marietta Quarry, instead of installing
separate extraction wells (up to 300 wells) to address the deeper portions of the plumes. Alternative MM-5
is shown on Figure 1 in Appendix A.
The TI waiver would be invoked as part of Alternative MM-5, since active remediation would not be a part
of this alternative. Based on modeling predictions, it would be no more effective to aggressively collect
and treat (as presented in Alternative MM-4) the intermediate and lower water-bearing zone groundwater
than to allow nature to take its course. Therefore, the intermediate and lower groundwater would be
allowed to naturally attenuate or breakdown. Collection of the intermediate and lower groundwater by the
Martin Marietta Quarry pump station would continue in order to maintain the contaminants within their
current boundaries (containment only). The predicted operational life of the Martin Marietta Quarry is 50
years. Beyond its operational life, IDEM would assume operation of the pumping station until ARARs are
achieved. In order to provide for a more complete and protective alternative, natural attenuation must be in
combination with groundwater use restrictions. Groundwater use restrictions would include the placement
of an Environmental Notice to the deeds for those properties within the current boundary of the
contamination. It should be noted that these properties are not utilizing groundwater at this time and the
entire area where the use restriction would be placed has public drinking water available. The key would
be to maintain the plume within its current boundary, since downgradient public drinking water supply is
not available at this time. On-site source control would be addressed through remedial actions at each of
the CSSS source areas. This would be performed to reduce or eliminate potential future migration of
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shallow, on-site contaminants into site-wide groundwater. The complete justification for the TI Waiver is
provided in Section 6.5 of the Feasibility Study report.
Both shallow and intermediate/lower water-bearing zone remedies would continue until contamination is
below acceptable levels. The groundwater model predicts that the area of groundwater above drinking
water standards will stay within existing boundaries, thus controlling and containing contaminant
migration. As part of addressing the shallow zone, groundwater use restrictions will be required for the
source areas and for off-site areas where existing groundwater contamination extends downgradient of
treatment/containment system capture zones that would be established by the source control groundwater
alternatives. Based on modeling results, the groundwater use restrictions for the downgradient
contaminated groundwater areas would be required for a period of approximately 40 years, until the off-
site and downgradient groundwater was allowed to naturally attenuate. It is important to note that the time
for the intermediate and lower groundwater to achieve ARARs is predicted to be over 200 years whether
the groundwater is allowed to naturally attenuate, migrate to the quarry for collection, or whether active
collection is proposed. DNAPL recovery from porous, fractured bedrock historically has a poor success '
rate (National Research Council, 1994).
The quarry extraction flow rate is currently about 3,200 gpm. Hydraulic flow limitations to the WWTP
most likely would require the construction and operation of an on-site treatment system at the quarry to
allow discharge to Wildcat Creek. However, groundwater modeling results suggest that discharge
concentrations may be below drinking water standards, surface water quality standards, and background
quality, so no treatment would be needed for the extracted and discharged water. Several factors in
determining the lack of necessity for treatment of the collected intermediate and lower groundwater are: (1)
distance contaminated groundwater must travel from source and plume areas, (2) radius of influence
Martin-Marietta Quarry collection well (extraction of large amount of clean groundwater resulting in
dilution), (3) the location of the Martin Marietta Quarry collection well at the leading edge of the
contaminant plume, and (4) dispersion tendencies of contaminants from source and plume areas, which
involves the gradual migration of contaminants downgradient at less than plume or source area
concentrations. The intermediate and lower groundwater would be discharged directly to Wildcat Creek
under a regulated discharge permit. The main purpose of the collection of the intermediate and lower
groundwater is to prevent its migration outside its current boundaries.
Groundwater use restrictions would be necessary for the period of time required for operation of the two
systems. Groundwater would be monitored quarterly for two years, semi-annually for the following two
years, and annually thereafter for an indefinite period or until compliance with ARARs is attained. A total
of 30 new wells would be installed to compliment the existing site-wide groundwater wells. Additional
domestic drinking water well sampling may be performed during Remedial Design to evaluate continued
monitoring during the Remedial Action
Lagoon Area (Operable Unit 2)
Remedial Alternative SC-4L is selected and consists of the following:
• RCRA Surface Impoundment Closure
• Excavate Contaminated Solids and Consolidate On-Site
• Collect and Contain Shallow Groundwater with Expanded Interception Trench System and Dispose
Off-Site
• Deed & Groundwater Use Restrictions
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Time to Complete Construction:
Groundwater Requirements:
for Monitoring
for Collection
Capital Cost:
First Year O&M:
30-Yr. Net Present Worth Cost:
2 to 3 years
30 years
30 years
$43,919,000
$146,600
$44,746,000
Alternative SC-4L consists of RCRA impoundment closure and construction of a groundwater interceptor
trench. It provides for more protective contaminated solids excavation with disposal in the on-site landfill.
It also provides aggressive shallow groundwater collection to shorten the time for shallow groundwater to
reach cleanup goals or drinking water standards. The schematic layouts for Alternative SC-4L are shown
on Figure 2a and 2b of Appendix A, respectively.
AH of the contaminated solids outside the lagoon impoundments would be excavated and disposed in an
on-site landfill or CAMU (Corrective Action Management Unit), which is a RCRA Hazardous Waste
disposal unit. This includes the excavation, to depths of four to 10 feet across the site, of approximately
93,000 cubic yards of material. This material includes waste piles, elevated VOC solids, and contaminated
solids outside the RCRA surface impoundment closure footprint. The majority of the PAH, PCB, and
metals-contaminated solids fall within the RCRA impoundment confines and would be addressed through
the RCRA closure and solidification. Excavated areas would be backfilled to existing grades, except were
floodway compensatory storage depressions are constructed, with clean soil.
The lagoons were operated under an interim RCRA permit which established guidelines for final closure of
the surface impoundments. RCRA guidelines for lagoon closure require an impermeable cap, post-closure
monitoring of potential leachate and groundwater quality, and post-closure care of the facility. Waivers
from some of these closure elements are anticipated given this material would be solidified to increase its
compressive strength and does not leach at levels above MCLs based upon treatability testing results from
the EPA START laboratory. The consolidation of sludge and soil from the various lagoons into one larger
lagoon would reduce costs by decreasing the total surface area requiring an impermeable cap, the extent of
leachate controls, and the extent of post closure monitoring requirements.
Once it was determined that in-place closure was appropriate, consideration was given to combining the
RCRA surface impoundment closure with construction of the on-site landfill under the CAMU process.
Since closure of a surface impoundment requires many of the same long-term monitoring components as a
landfill and the impoundment closure precludes further site development, the ability to situate waste
containment from the other CSSS source areas on top of the impoundment closure would provide cost
savings to the remedial process by eliminating duplicative areas for waste containment, liner costs, and
monitoring costs.
Construction of a landfill and establishment of a CAMU would lower the remedial costs associated with
the overall site cleanup since proposed remedial activities could be performed in a more efficient manner.
The solidification of waste, which decreases the permeability of the material, could serve as the bottom for
the CAMU landfill or a separate RCRA cap may be required based upon testing results. The RCRA cap, if
required, could serve as the bottom liner since it could be placed beneath the CAMU material. It is
assumed that the lagoon waste will be consolidated within the proposed footprint of the CAMU to
maximize benefits. Since, the lagoons will have monitoring wells; the lagoon sludge does not leach
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constituents at levels of concern according to the treatability study; and the material managed under the
CAMU will be capped, placed above the water table, and will likely not leach at levels above groundwater
standards; a bottom liner to the CAMU landfill may not be necessary.
The general concept of the combined CAMU and RCRA closure would first consolidate the lagoon sludge
within the CAMU footprint. This results in 5 to 10 feet of solidified sludge being placed as the base layer
within the CAMU. Part of the sludge removal would result in the penetration of the Wildcat Creek
floodplain by approximately four feet. The floodway would not be directly penetrated. The areas where
sludge would be excavated from the floodway to the southwest would be utilized to construct
compensatory storage depressions, which would greatly minimize the impact of a 100-year flood event on
the CAMU/landfill. Damage control measures would also be incorporated in the CAMU design to
minimize impacts of a 100-year flood event. The final location of the CAMU/landfill on the Lagoon Area
will be determined by the remedial design for this operable unit based upon final quantities of
contaminated material needing on-site disposal with the intent of maximizing compensatory floodway
storage and reuse options for the property and minimizing the impacts of a 100-year flood event on the
CAMU/landfill.
The landfill would be designed consistent with RCRA guidance; however, waivers could be sought for
certain RCRA guidelines (e.g., located outside of floodplain, bottom liner if groundwater controls
implemented or solidified sludge shown to have adequate permeability) since this is a CERCLA site. The
design of the landfill would be based on characterization of the waste materials for conformance with
RCRA and/or TSCA requirements and guidelines. RCRA guidelines suggest the use of the following
components: double liner base, a low permeability cap, a leachate detection, collection and treatment
system, and a groundwater monitoring system. During the remedial design, 40 CFR 264.18(b) and 40
CFR 270.14(b)(l l)(iv) on the construction of a CAMU in a 100-year floodplain will be reviewed and
observed. It would be necessary to meet TSCA requirements for PCBs above 50 ppm.
The corridor adjacent to Wildcat Creek has elevated contaminant concentrations. Drums, debris arid fill
material were noted in this area. These areas would be excavated to depths of two to four feet and
disposed in the CAMU.
VOC-contaminated shallow groundwater within the Lagoon Area would be collected via a trench
collection system. The trench system would be installed to a depth of about 45 feet (the bottom of the
shallow water-bearing zone) in a "U"-shape around the down gradient boundary of the VOC groundwater
plume. The interceptor trench for the Lagoon Area would be about 3,000 linear feet in length, with a total
of six collection locations. An interior bisecting trench installed in an east-west direction would provide
for more aggressive groundwater collection. A total flow rate of about 35 to 40 gpm would be expected.
The modeling results for the more aggressive collection system of this alternative show that cleanup goals
or MCLs for shallow groundwater may be reached in 3 to 6 years. Shallow groundwater outside the
source areas may reach desired cleanup levels in the time frame predicted by the modeling, however, due
to the presence of residual DNAPL and other VOC contaminant sources and groundwater collection
system limitations to extract downgradient contaminated shallow groundwater, source area shallow
groundwater collection systems may need to continue operating, up to 30 years, to contain and treat these
remaining source materials in the shallow aquifer.
Collected shallow groundwater would be pumped via a buried pipeline directly to the city sanitary sewer
system. At this point, the collected and discharged contaminated shallow groundwater would be mixed
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with untreated domestic sewage, which would result in an exemption from hazardous waste disposal
requirements (40 CFR 261.4(a)(l)(ii)). The mixed waste stream would be treated and disposed at the
WWTP per a written agreement provided by the City of Kokomo. Sewer system capacity limitations
during storm events may necessitate periodic short-term pump station shutdown. The effects of these
shutdowns on the trench system performance are expected to be minimal. Costs were based on
groundwater collection for 30 years in order to be consistent with RCRA post-closure groundwater
monitoring requirements and compensate for the potential existence of unknown source areas and
continued presence of pockets of DNAPL.
Groundwater use restrictions would be required both on-site and off-site until cleanup goals or MCLs are
reached. Groundwater would be monitored consistent with RCRA post closure groundwater monitoring
requirements. Installation of additional monitoring wells would also be a part of this alternative.
Wildcat and Kokomo Creeks (Operable Unit 3)
Remedial Alternative SC-4C is selected and consists of the following:
• Excavate Contaminated Creek Sediment and Consolidate in On-Site CAMU Landfill
Time to Complete: 18 months
Capital Cost: • $12312,000
First Year O&M: $20,000
30-Yr. Net Present Worth Cost: $12,560,000
Alternative SC-4C would involve the removal of the contaminated sediment from two miles of the
creeks. The removed material would be dewatered of liquids per RCRA requirements and placed within
the on-site landfill/CAMU at the Lagoon Area (see Figure 2a/b in Appendix A). This alternative more
easily complies with floodway ARARs than the other alternatives. The construction activities for this
alternative will be performed consistent with ARARs for wetlands.
During removal of the sediment, care would have to be taken to control the resuspension of sediment
within the water column. Turbidity control barrier's would need to be incorporated into the sediment
removal process as appropriate. Excavation could either occur through dredging methods, if the creek is
to remain flowing, or the creek flow could be bypassed or diverted and excavation can proceed in the dry
with conventional earth moving equipment. An allowance of cost has been included for these activities.
Dredging methods would include mechanical methods (i.e., clamshell bucket, draglines) or hydraulic
methods (i.e., suction dredge, auger dredge). Mechanical methods would disturb the sediment more
than hydraulic methods. Hydraulic methods would remove large quantities of water along with the
sediment and would require settling basins to allow the sediment to settle out. The water may require
treatment prior to discharge into the creeks or to an off-site treatment facility or WWTP. Conventional
earth moving equipment for excavation in the dry is the preferred method. Conventional wide tracked
earth moving equipment should be able to excavate the sediment quite readily from the creeks according
to probe testing in the sediments. Some of the sediment to be removed is sandy and gravelly and is
adequate to support equipment wheel loads. In areas where the sediment is soft, the underlying materials
are more competent and no severe impact to equipment operation is anticipated.
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After the sediment is excavated from the creeks, the fine-grained sediment and organics will likely be
saturated and soft. The more coarse grained material can be gravity dewatered. It may be necessary to
dewater the fine-grained sediment and/or improve the compressive strength of the sediment through
solidification. Once the material characteristics are suitable for landfilling based on RCRA liquid
restriction requirements and compressive strength testing, it would be placed within the on-site cells at
the lagoon/CAMU. Up to 51,000 cubic yards of material would require permanent landfilling (based on
dewatering of 61,000 cu. yds. of the in-place sediment). The material would then be capped to prevent
future exposure to the environment. The landfill would include operational controls for leachate
collection, groundwater monitoring, and cap maintenance.
Since alternative SC-4C would remove the contaminated sediment from the creeks, no future sampling
of surface water or sediment would be required in the creeks. No restrictions would be required for the
creeks and there would be no future impacts to the aquatic habitat.
Markland Avenue Quarry (Operable Unit 4)
Remedial Alternative SC-2.5O is selected and consists of the following:
• Cover Contaminated Solids with Common Soil
• Dispose of Quarry Sediment in Lagoon Area CAMU
Contain & Collect Shallow Groundwater & Dispose at WWTP
• Excavate Contaminated Sediment from Quarry Pond
• Backfill Quarry Pond with alternative fill material
• Deed and Groundwater Use Restrictions
Time to Complete Construction:
Time to Attain MCLs:
Capital Cost:
First Year O&M:
30- Yr. Net Present Worth Cost:
24 to 36 months
10 to 15 years
$10,234,000
$168,000
$11,163,000
This modified alternative is presented due to significant differences from the other alternatives presented
in the approved FS Report. These differences were brought about by additional intra-agency evaluations
prior to presentation to the NRRB and due to recommendations from the NRRB. This modified
alternative will include deed and groundwater use restrictions to restrict site access and the use of
contaminated groundwater. Shallow groundwater would be collected along the west and north boundaries
of the site and pumped directly via a buried pipeline to the city sanitary sewer system. It would also
include installation of a common soil cover to eliminate potential exposure to and direct contact with
contaminated solids. Removing contaminated sediment from and backfilling of the quarry pond is also
part of this alternative. A diagram of Modified Alternative SC-2.5Q is shown on Figure 4.
The 1.28 million cubic yards of solid (fill) material within the quarry would remain in-place with a cover
consisting of a warning barrier and two feet of permeable common soil. This cover system provides a
warning mechanism in the event of future excavation and eliminates direct contact to the contaminated
media. The protective cover would be graded and grassed to facilitate drainage, minimize erosion, and
provide for recreational use.
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The sediment in the pond would be excavated and dewatered; solidified as necessary; treated off-site if
necessary for VOCs, SVOCs, metals and PCBs; and disposed in the Lagoon Area (OU-2) landfill/
CAMU. The pond would be backfilled with appropriate material through creative management
practices. Use restrictions would be implemented to protect the cover and prevent the use of
groundwater.
This alternative would also include shallow groundwater collection and containment in the immediate
vicinity of the Quarry. The RI data indicate that shallow groundwater contamination is in the process of
biodegradation and downward migration. The time to attain cleanup goals through natural attenuation is
estimated at 30 years.
Through active collection, groundwater modeling predicts that cleanup goals or MCLs for shallow
groundwater may be reached in 15 to 20 years. Shallow groundwater outside the source areas may reach
desired cleanup levels in the time frame predicted by the modeling, however, due to the presence of
residual DNAPL and other VOC contaminant sources and groundwater collection system limitations to
extract downgradient contaminated shallow groundwater, source area shallow groundwater collection
systems may need to continue operating, up to 30 years, to contain and treat these remaining source
materials in the shallow aquifer.
Collected shallow groundwater would be pumped via a buried pipeline directly to the city sanitary sewer
system. At this point, the collected and discharged contaminated shallow groundwater would be mixed
with untreated domestic sewage, which would result in an exemption from hazardous waste disposal
requirements (40 CFR 261.4(a)(l)(ii)). The mixed waste stream would be treated and disposed at the-
WWTP per a written agreement provided by the City of Kokomo provided contaminant levels are within
pretreatment requirements. Sewer system capacity limitations during storm events may necessitate
periodic short-term shut down of the extraction pumps. Short-term shut downs would have no
significant effect on the trench system performance. Costs were based on groundwater collection for 30
years in order to remain consistent with RCRA post-closure groundwater monitoring requirements and
compensate for the potential existence of unknown contaminant source areas and continued presence of
DNAPL.
Groundwater would be monitored quarterly for two years, semiannually for the following two years, and
annually thereafter until compliance with cleanup goals or drinking water standards is attained.
Groundwater monitoring wells would be installed in and around the Markland Avenue Quarry. Five
clusters of three wells each would be installed with screened intervals across each water-bearing zone
(shallow, intermediate, and lower). An additional sample of effluent from the groundwater collection
system would be obtained for each sampling round.
Main Plant (Operable Unit 5)
Remedial Alternative SC-3.5M is selected and consists of the following:
• Excavate PCB Solids along Kokomo Creek and Dispose On-Site
• Install Common Soil Cover
• Collect & Contain Shallow Groundwater and Dispose Off-Site
Elevated VOC Solids Removal and On-Site Disposal
• Deed and Groundwater Use Restrictions
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Time to Complete: 15 years
Capital Cost: $7,000,000
First Year O&M: $36,000
30-Yr. Net Present Worth Cost: $7,747,000
Alternative SC-3M has been modified and is presented as Alternative SC-3.5M. The modified
alternative would focus on the elimination of direct contact risk, reduced stormwater infiltration, limited
soil removal, and control of shallow groundwater to achieve cleanup goals. It includes the installation of
a common soil cover over the contaminated solids (incorporated NRRB recommended modification),
collection of contaminated groundwater for treatment and disposal at the city of Kokomo WWTP, and
the removal of VOC and PCB contaminated soil in two locations along the creeks. Other measures
would include groundwater monitoring and deed restrictions. Alternative SC-3.5M is shown on Figure 5
in Appendix A.
The cover would be constructed of common soils. A two-foot soil cover would prevent direct contact
and would be graded and seeded to promote runoff and reduce erosion and infiltration. Prior to
placement of the soil cover, the Main Plant property would be graded with a warning barrier (i.e., orange
snow fencing) to be installed. This provides a warning mechanism in the event of future excavation
signifying the contact with contaminated materials.
VOC and PCB contaminated soil removal would be performed. VOC contaminated solids along Wildcat
Creek would be excavated from shallow (zero to four feet below grade) and deep (four to 12 feet below
grade) soil intervals and transportation to the on-site landfill (CAMU) for disposal. PCB contaminated
soils along Kokomo Creek would be excavated vertically and horizontally until cleanup goals are
reached and transported to the on-site landfill. Excavated areas would be backfilled with clean soil.
Contaminated shallow groundwater would be collected via a trench collection system installed along the
Main Plant western boundary adjacent to Park Avenue and Wildcat Creek. The trench system would be
installed to a depth of about 30 feet and remove groundwater at a rate of 10-15 gallons per minute.
Collected shallow groundwater would be pumped via a buried pipeline directly to the city sanitary sewer
system. At this point, the collected and discharged contaminated shallow groundwater would be mixed
with untreated domestic sewage, which would result in an exemption from hazardous waste disposal
requirements (40 CFR 261.4(a)(l)(ii)). The mixed waste stream would be treated and disposed at the
WWTP per a written agreement provided by the City of Kokomo provided contaminant levels are within
pretreatment requirements. The groundwater model predicts cleanup goals would be achieved in shallow
groundwater in 15 years. Shallow groundwater outside the source areas may reach desired cleanup
levels in the time frame predicted by the modeling, however, due to the presence of residual DNAPL and
other VOC contaminant sources and groundwater collection system limitations to extract downgradient
contaminated shallow groundwater, source area shallow groundwater collection systems may need to
continue operating, up to 30 years, to contain and treat these remaining source materials in the shallow
aquifer.
Soil excavated for site grading could be used as fill if there was no leaching potential or, if necessary,
transported to the Lagoon Area for on-site disposal.
Groundwater would be monitored until compliance with ARARs is attained. Eighteen additional
-------
99
monitoring wells would be installed in and around the main plant area. Two would be screened within
the shallow water-bearing zone, eight screened within the intermediate water-bearing zone, and eight
screened within the lower water-bearing zone. In addition, samples would be collected from the
interceptor trench effluent.
Slag Processing Area (Operable Unit 6)
Remedial Alternative SC-3.5S is selected and consists of the following:
Regrade Slag Pile to Level Site
• Install Protective Common Soil Cover Over Contaminated Solids
• Deed Restrictions
• Stabilize Creek Bank
Time to Complete: 12 to 18 months
Capital Cost: $2,420,000
First Year O&M: $0
30-Yr. Net Present Worth Cost: $2,420,000
Alternative SC-3S has been modified and is presented as Alternative SC-3.5S. This alternative is based
on the assumption that the future use of the property will be residential, due to its location and the
absence of property use restrictions.
The primary remedial action component would be a cover across the entire Slag Processing Area. The
limits of the Slag Processing Area are shown on Figure 6 in Appendix A. The cover would simply be
two-feet of common fill and topsoil. The surface of the cover would be seeded to minimize erosion.
Prior to placement of the soil cover, a warning barrier (i.e., orange snow fencing) would be installed.
This provides a warning mechanism in the event of future excavation. Supplementary erosion control
(rip-rap and filter fabric) would be installed along Wildcat Creek to minimize the potential for slag
entering the creek.
Prior to cap placement, the slag piles could be spread evenly across the rest of the relatively flat surface
area of the site. Due to the large volume contained in these stockpiles, estimates predict that regrading
would raise the surface elevation over the entire nine acres by more than six feet on average including
the cap. This difference might hamper future development of the property. The slag materials may be
used as backfill material in other areas of the CSSS according to regulatory guidelines.
Deed restrictions would be necessary to minimize potential exposure to the remaining slag material
under the cover. These restrictions would call for special procedures during future residential
construction.
X. Statutory Determination
The selected remedies must satisfy the requirements of Section 121 of CERCLA by protecting human
health and the environment and complying with ARARs. CERCLA Section 121 also requires that the
selected remedial action be cost effective; utilize permanent solutions and alternative treatment
-------
100
technologies to the extent practicable; and satisfy the preference for treatment as a principal element of the
remedy, or provide an explanation as to why the preference is not satisfied. The following is a brief
description of how the selected remedies meet the statutory requirements of Section 121 of CERCLA.
Protection of Human Health and the Environment.
The IDEM preferred and selected alternatives are believed to provide the best balance of trade-offs among
the proposed alternatives for each operable unit with respect to the criteria used to evaluate remedies.
Current and potential future risks to human health and the environment from contaminated groundwater
will be significantly reduced provided that the common soil covers remain intact, the groundwater
collection, containment, and treatment systems are maintained, and site access and use and deed
restrictions are strictly enforced. All the contamination sources would remain on-site, but the mobility,
toxicity, and volume would be reduced by the common soil covers, on-site disposal of the most
contaminated materials in the CAMU landfill, and active groundwater collection, containment, and
treatment systems. Implementation of the selected remedies will reduce human health risks to within the
acceptable U.S. EPA excess cancer range of 1 x 10~* to 1 x 10"6 and the hazard indices for the
noncarcinogens will be less than unity (1). Institutional control measures to restrict access to groundwater
in the impacted area and prevent excavation of common soil covers will also provide for reduced human
health exposure risk. No unacceptable short-term risks or cross-media impacts will be caused by
implementation of the selected remedies.
Compliance with ARARs.
The remedies for the CSSS are subject to Applicable or Relevant and Appropriate federal Regulations
(ARARs) and any more stringent state regulations. The determination of ARARs has been made in
accordance with 121(d)(2) of CERCLA, as amended by the Superfund Amendments Reauthorization Act
(SARA) of 1986. These ARARs are also consistent with the National Contingency Plan (NCP) 40 CFR
Part 300; Amended March 8, 1990. ARARs are federal, or more stringent state requirements, that the
remedial alternative(s) must achieve, that are legally applicable to the substance or relevant and appropriate
under the circumstances.
All on-site remedial activities would not require a permit, however, these activities would rather be
required to meet the substantive requirements that would be part of a permit. Ordinarily the boundary of
a site expands to include the areas necessary to cover the full extent that a contaminant release expands.
Offsite activities as part of the remedy would be subject to any and all applicable permitting
requirements and would require a permit.
The ARARs for the Continental Steel Superfund Site are presented in Appendix
Cost Effectiveness.
Cost effectiveness is determined by evaluating the overall effectiveness proportionate to costs, such that the
selected remedy represents a reasonable value for the money to be spent. Section 300.430(f)(ii)(D) of the
NCP requires the assessment of cost-effectiveness by evaluating all alternatives which satisfy the threshold
criteria: protection of human health and the environment and compliance with ARARs, with three
additional balancing criteria : long-term effectiveness and permanence; reduction of toxicity, mobility, and
volume achieved through treatment; and short-term effectiveness, to determine overall cost-effectiveness.
IDEM believes that the selected remedies comply with ARARs to extent practicable and are cost effective
in mitigating the risks posed by contaminated groundwater and solid media.
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101
Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable.
IDEM believes that the selected remedies represent the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost effective manner for the Continental Steel Superfund Site.
Of those alternatives that are protective of human health and the environment and comply with ARARs,
IDEM has determined that the selected remedies provide the best balance of trade-offs in terms of long-
term effectiveness and permanence; reduction of toxicity, mobility, mobility, and volume achieved through
treatment; short-term effectiveness; implementability; and cost.
Preference for Treatment as a Principal Element.
As stated previously, the elevated VOC solids and elevated PCB contaminated solids will be removed and
consolidated on site in the CAMU landfill to be constructed on the Lagoon Area. If these contaminated
solids are identified as needing treatment before placement in the CAMU, then the statutory preference for
treatment as a principal element of the remedy would be achieved. However, if the excavated solids do not
need treatment based on testing for treatability and Toxicity Characteristic Leaching Procedure (TCLP), or
treatment of the additional threats at the site was not found to be practicable, this remedy would not satisfy
the statutory preference for treatment as a principal element of the remedy.
The selected remedy for groundwater contamination includes the following: (1) collection, treatment,
containment of shallow groundwater; (2) collection and containment of intermediate and deep
groundwater, including invoking a Technical Impracticability Waiver; and (3) use of institutional controls,
in the form of deed and groundwater use restrictions. The remedy for shallow groundwater will meet the
statutory preference for treatment as a principal element. The remedy for the intermediate and lower
groundwater will not meet the statutory preference for treatment as a principal element due to the type of
contamination (DNAPL) and geology (infrequently fractured bedrock) present, thus the request and
approval pursuant to 121(d)(4) of CERCLA of the TI Waiver for these two groundwater zones. However,
despite the impracticability, extracted contaminated groundwater, particularly those collected from the
intermediate and lower aquifers for the containment portion of the remedy, will be treated.
Based on the information available at this time, IDEM believes the preferred alternatives would be
protective of human health and the environment, would comply with ARARs, would be cost-effective, and
would utilize permanent solutions and alternative treatment technologies or resource recovery technologies
to the maximum extent practicable.
Documentation of Significant Changes
IDEM determined that no significant changes to the remedy, as it was identified in the Proposed Plan, are
necessary.
Responsiveness Summary is presented in Appendix E.
-------
APPENDIX A
Figures and Drawings
-------
FIGURE A
Continental Steel Superfund Site - Location of Operable Units
' •rwi.il
-------
FIGURE 1
il —i i •••••-ii.-:F;i;'--:'-1: L!I.-E f- i- i I.'-L
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"F :•.•! ...•:.- if I >'- '<• iirri-MM i.-.rc ..:.!. ! ;.i i:
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•'• ' !l. t FFii.: -,..11 .1 ;..•.:;-.. |-i .MI,.-.
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11.'.HII.
II.'.HI ' '-
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—>
-------
Figure Ib
GROUNDWATER MONITORING
WELL LOCATIONS
• 600'
LEOENOt
DW-Z27(NL)o DOMESTIC WELLS
EW-324 EXISTNO MONITORINO WELLS
LA-070 MULTI-LEVEL MONITORNO SYSTEMS
(LOWER AQUIFER)
LA-07Q PROPOSED MONITORINO WELLS
(LOWER AQUIFER)
UA-IO+ SHALLOW MONITORINO WELLS
(UPPER AOUFERI
UA-.J4
-------
FIGURE 2a
Lagoon Area - Operable Unit 2
Site Top View
C AMU / Landfill Footprint
r-H
for compensatory floodway storage
-------
FIGURE 2b
Lagoon Area - Operable Unit 2
CAMU Cross-sectional View
h-
t.i.-
. .' I - •{. IL -• : r I -
:, i: .. .r . • ,i • • ,i :r-
-JL
T--.
-------
FIGURE 2c
Lagoon Area - Operable Unit 2
Exposure Areas
Kokomo WWTP
Haynes Internal!
LEGEND
> 10.000 mq/kq
5.000 TO 10.000 mg/kg
400 TO 5.000 mg/kg
< 400 mq/kg
NON DETECT (NO)
AREA FOR PROPOSED
CORRECTIVE ACTION \
MANAGEMENT UNIT (CAMU)
A THROUGH E EXPOSURE AREAS
WASTE PILES
-------
Figure 2d
LAGOON AREA
SOIL GAS AND SOIL BORING
SAMPLE LOCATIONS
}
N
4
r • ioo'
50 0 100
'' //' / / ,•'5 /' utf-« uic-a UU&-B utt>-axCuc
' y / / 1
/ / • / -. — • — . =~T -y ^ /- -^
/ / i . ' UJ5-K UUoii Utt-tt LMt-47 LABHJ LAB-t» UUC
•• v — ^_ >, • .n < • •; • •
MARKLAND AVENUE UK » u« r ,« n iMO n T« ,, ,«n T) inmir LH , ,
IL J
rS V»'-'f-;'i*?'Jnt*a'^' l*»-«
7 * Irs, ,' • V •
•00
£2 dta-tt LAO-U^~tMUJ4 UUC-M
•~^- — -UOO-OI UBMB Ud»-t»- t "**'' '
• SOIL GAS SAMPLE LOCATION // | U*
O SCO. BORING SAMPLE LOCATION //' >^
SAMPLES COLLECTED OCTOBER - DECEMBER 1995 // M&
, ' <:r"-^-v. ,' i n
v\ /-, / 1 1
^O*-:? '/ !:
14 UkB-B UK-M UU&-H U&>-«1 /
UUt-M L»S>-JI UUD-n ' /
• • • U
-* UUO-17 UK-It UK-n LABV-10
• • • •
?l«Hi "**
^*
-------
Figure 3b
KOKOMO 8 WILDCAT CREEK
SURFACE WATER AND SEDIMENT
SAMPLING LOCATIONS :,
^lt,o?8:: 7 'Ldsm
oui/cn-9io a • SURFACE WATER / SEDMENT
SW/5D-ZT9 M SAMPLWO LOCATION
-------
FIGURE 3
Kokomo & Wildcat Creeks - Operable Unit 3
—^.-^~ '-=!_•-" i-__.--,...•-
-------
FIGURE 4
Markland Avenue Quarry - Operable Unit 4
f': «
I'
* -•
L
j •
•v
4
./
t
I;
L_
. . .-:, :..• Tl-
• l-l.'CCi.'.'!
.i-i1,- r ••!'
iH-.-.n ;i , UK
-------
FIGURl 4a
Markland Avenue Quarry - Lead Exposure Areas
UJ ;
Hi!
POND
04SS-OII 178.)
'"
04SS-008 1481. J«l
0' - ^
ik.//'. - .;
r ;_
(MSS-013 1290.1 04SS-OOT IT
A04SS-003 M60.)
LEGEND
> 1000 mg/kg
399 - UOOO mg/kg
< 399 mg/k«
NOT DETECTED
L_ II.660.J*] DENOTES OU4UIFIED
" fl DAT4
~J A THROUGH 0 EXPOSURE AREAS
n
PREV4J.INC WM) DIRECTION
(FROM SOUTHWEST 220'-230')
N
10.. " in j
-4---I'1 3
SO 0
TOO
-------
Figure 4b
MARKLAND AVENUE QUARRY
SOIL GAS AND GROUNDWATER
SCREENING SAMPLE LOCATIONS
4L^-^ s-±j^_g. JT*_.^ «•*-^
' MU-M Am&
-------
Figure 4c
MARKLAND AVENUE QUARRY
SURFACE SOL SAMPLE
LOCATIONS
-------
FIGURE 5
Main Plant - Operable Unit 5
•.(•'•I'MI'-.vi II I- M '|ili--I-ID" :.l; .
• - -iiii i •••;. A;IFI- PF-i-lii .• ' n!
i . I''-AH- /.'-lI t- l-t-H'i • ' -ii'
•r Mi •-..[ l.'th •(•-l|.'lil .'..•!'• i- .' i •:. I ;'•• 'I
." - :'.'-^;i.ii :'•''• '.•..•.';':'- tr.^.'i-'': '::
i .. •..i.n:i-..'i 'i Lii.f : i- I '
i -i ••'II'L'f't'l' ' *
• -L , ' i •*;•[••••' i .
-------
HUURE 5a
Main Plant (OU-5) Lead Exposure Areas
400 - 1000 mg/kg
50 - 400 mg/kg
< 50 mg/kg
NOT DETECTED
'5SB-H04 [3.300.1
05HB-H03 139.000.1
-------
Figure 5b
Main Plant (South) - Operable Unit 5
Soil Gas Survey Locations
I \ \ \ I V- /
>*^ .' r\ ' J ff ft' I /
J^y// * // h
V-V/ / /fi>
;^ / sW
\ lii
\ II i V_
x^^ v
^^
-5ST?
-------
o
92
.EGEND
• SB-F2 - SOIL BORING SAMPLE LOCATION - 1995
SCALE r » 300'
150
300
•fivtronmtntot tnglnuirt. tcttnt/ftt,
p/onrwri. / management con tut ton ft
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO. INDIANA
MAIN PLANT SOIL BORING
SAMPLE LOCATIONS
Figure 5c
-------
RS-lsJi
JFOSTER ST1
RSr26 RS-25
HIGHLAND PARK
RS-I
LEGEND
• RS-1 RESDENTIAL SURFACE SOIL
SAMPLE LOCATION - 1995
200
400
tnvlronm«nto( onglnaert. iclentlstt.
olmn«r». t monogement consultant*
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO. INDIANA
RESIDENTIAL SURFACE
SOIL SAMPLE LOCATIONS
Figure 5d
-------
FIGURE 6
Slag Processing Area - Operable Unit 6
-------
APPENDIX B
Evaluation Criteria Tables
-------
Table 1
NINE CRITERIA SUMMARY COMPARISON TABLE
OU-1 (Side-Wide Groundwater)
(see table below for common actions)
EVALUATION CRITERIA
1. Overall Protection of Human
Health & Environment
2. Compliance with ARARs
3. Long-term Effectiveness and
Permanence
4. Reduction of Toxicity, Mobility or
Volume thru Treatment
5. Short Term Effectiveness
6. Implementability
7. Cost (in millions)
8. Support Agency Acceptance
9. Com m u n ity Acceptance
ALT. MM-1
No Action
Q
a
a
Q
•
N/A
$0
ALT. MM- 2
Monitored Natural
Attenuation of Intermediate
and Lower Groundwater
A
A
A
A
•
•
$5.53
ALT. MM- 3
Collect Intermediate and
Lower Groundwater and
Dispose Off-Site at
WWTP
A
A
A
•
•
A
$13.2
ALT. MM- 4
Collect Intermediate and Lower
Groundwater and Dispose Off-
Site at Wildcat Creek
A
A
•
•
•
A
$13.38
ALT. MM- 5
Collect Intermediate and Lower
Groundwater at Martin Marietta
Quarry and Dispose Off-Site
•
A
•
A
•
•
$6.39
U.S. EPA Support for Alternative MM-5 will be evaluated after the public comment period.
Community Acceptance after the Proposed Plan public comment period was very favorable.
N/A - Not Addressed • Fully meets criteria A Partially meets criteria Q Does not meet criteria
For more information, see the detailed nine criteria comparison table that follows or the Feasibility Study in the Repository at the Library.
Common Actions to the OU-1 Alternatives, except No Action
• Groundwater Use Restrictions
4 Collect Shallow Groundwater and Dispose Off-site at Kokomo Wastewater Treatment Plant
-------
TABLE la - Operable Unit 1
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
SITE-WIDE GROUNDWATER
Alternative
MM-1:
MM-2:
MM-3:
Overall Protection
or Human Health
and the
Environment
Not protective of
human health or the
environment.
Protective of human
health. Reductions in
exposure potential
through institutional
controls and extraction
of shallow
groundwater.
Protective of human
health and the
environment.
Elimination of
exposure potential
through groundwater
extraction and off-site
disposal.
Compliance with
ARARs
ARARs not attained,
except through natural
attenuation.
ARARs would
eventually be attained
for the shallow water-
bearing zone. The time
frame for achieving
ARARs for
intermediate and lower
water-bearing zones
would exceed 200
years.
ARARs would
eventually be attained
for all three water-
bearing zones though
limited effectiveness of
recovery for the
intermediate and lower
water bearing zones.
ARARs would not be
attained for the lower
zones for at least 200
years.
Long-term
Effectiveness and
Permanence
Exposure potential
would persist for
hundreds of years.
Collection effective for
the shallow water-
bearing zone only,
assuming that use
restrictions are
employed.
This alternative would
provide a long-term
solution to
contamination in all
three water-bearing
zones through collection
and natural degradation.
Reduction of Toxicity,
Mobility, or Volume
No reduction except
through natural attenuation.
Volume, mobility, and
toxicity of shallow
groundwater contaminants
would be reduced.
Treatment would be
addressed at the WWTP.
Only natural attenuation
would impact intermediate
and lower zones.
Volume, mobility, and
loxicity of groundwater
contaminants would be
reduced, but at marginal
effectiveness as compared
to natural attenuation.
Short-term
Effectiveness
Additional risks
to workers during
monitoring. Site
risks still persist.
Short-term risks
to workers during
extraction system
installation and
monitoring
activities.
Short-term risks
to workers during
extraction system
installation and
monitoring
activities.
Implementability
No remedial actions
take place under this
alternative.
Technically easy to
implement.
Some logistics issues.
Requires approval of a
TI waiver. Natural
attenuation for the
intermediate and
lower zones is easy to
implement. Use
restrictions would
need to encompass the
area of concern for an
extended duration.
Logistically possible
to implement. Use
restrictions over large
area of industrial/
commercial use may
not be an issue.
Cost
SO
$5,532,000
$13,204,000
-------
TABLE la - Operable Unit 1
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
SITE-WIDE GROUNDWATER
Alternative
MM-4:
MM-5:
Overall Protection
of Human Health
and the
Environment
Protective of human
health and the
environment.
Elimination of
exposure potential
through groundwater
extraction and off-site '
disposal/direct
discharge. Limited
potential for
environmental impacts
would remain due to
direct discharge.
Protective of human
health and the
environment.
Elimination of
exposure potential
through groundwater
extraction and off-site
disposal/direct
discharge. Limited
potential for
environmental impacts
would remain due to
direct discharge.
Compliance with
ARARs
ARARs would
eventually be attained
for all three water-
bearing zones though
limited effectiveness of
recovery for the
intermediate and lower
water bearing zones.
ARARs would not be
attained for these zones
for at least 200 years.
ARARs would
eventually be attained
for all three water-
bearing zones though
limited effectiveness of
recovery for the
intermediate and lower
water bearing zones.
ARARs would not be
attained for these zones
for at least 200 years.
Long-term
Effectiveness and
Permanence
This alternative would
provide a long-term
solution to
contamination in all
three water-bearing
zones through collection
and natural degradation.
This alternative would
provide a long-term
solution to
contamination in all
three water-bearing
zones through collection
and natural degradation.
Reduction of Toxicity,
Mobility, or Volume
Volume, mobility, and
toxicity of groundwater
contaminants would be
reduced, but at marginal
effectiveness as compared
to natural attenuation.
Volume, mobility and
toxicity of groundwater
contaminants would be
reduced, but at marginal
effectiveness as compared
to natural attenuation.
Short-term
Effectiveness
Short-term risks
to workers during
extraction system
installation and
monitoring
activities.
Short-term risks
to workers during
extraction system
installation and
monitoring
activities. Some
additional
community risk
due to off-site
collection at
Martin Marietta
Quarry.
Implementability
Logistically possible
to implement. Use
restrictions over large
area of
industrial/commercial
use may not be an
issue. Requires
permit for discharge.
Logistically possible
to implement. Use
restrictions over large
area of
industrial/commercial
use may not be an
issue. Requires
permit discharge and
potential operation of
Martin Marietta
Quarry beyond the life
of the quarry.
Cost
$13384,000
$6,386,000
-------
Table 2
NINE CRITERIA COMPARISON SUMMARY TABLE
OU-2 (Lagoon Area)
(see table below for common actions)
EVALUATION CRITERIA
1. Overall Protection of Human
Health & Environment
2. Compliance with ARARs
3. Long-term Effectiveness and
Permanence
4. Reduction of Toxicity, Mobility
or Volume thru Treatment
5. Short Term Effectiveness
6. Implementability
7. Cost (in millions)
8. Support Agency Acceptance
9. Community Acceptance
ALT. SOIL
No Action
Q
a
a
o
0
a
$0
ALT. SC- 2L
Cap Areas with Elevated
VOCs
A
A
•
A
•
•
$29.97
ALT. SC- 3L
Cap Contaminated Solids / Elevated VOC Solids
Removal / Contain & Collect Shallow
Groundwater with Interception Trench System
and Dispose Off-Site
A
•
- •
•
•
•
$36.81
ALT. SC- 4L
Excavate Contaminated Solids and
Consolidate On-Site / Collect &
Contain Shallow Groundwater with an
Expanded Interception Trench System
and Dispose Off-Site
•
•
•
•
•
•
$44.75
U.S. EPA Support for Alternative SC-4L will be evaluated after the public comment period.
Community Acceptance of the Selected Alternative after the public comment period was favorable.
N/A - Not Addressed • Fully meets criteria A Partially meets criteria Q Does not meet criteria
For more information, see the detailed nine criteria comparison table that follows or the Feasibility Study in the Repository at the Library.
Common Actions to the OU-2 Alternatives, except No Action
• Deed & Groundwater Use Restrictions
• RCRA Surface Impoundment
-------
TABLE 2b - Operable Unit 2
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
LAGOON AREA
Alternative
SC-1L:
SC-2L:
SC-3L:
Overall Protection of
Human Health and the
Environment
Not protective of human
health or the environment.
except through natural
attenuation. Surface
impoundments not
addressed.
Adequately protective of
human health and the
environment. Exposure
pathways for solids
addressed partially through
access restrictions and
RCRA impoundment
closure. VOC source to
groundwater addressed by
capping. Groundwater
would be addressed by
natural attenuation and use
restrictions.
Protective of human health
and the environment.
Exposure pathways
controlled through capping.
VOC removal, and RCRA
impoundment closure.
Shallow groundwater
source collected for
disposal at WWTP. Deed
and use restrictions address
long-term contact.
Compliance with
ARARs
ARARs not attained
for solids and
groundwater.
ARARs attained by
capping solids with
VOCs, RCRA
closure and access
restrictions.
Shallow
groundwater will
attain ARARs by
natural attenuation
in 10 years.
Need groundwater
use restrictions in
the interim.
Solids ARARs
attained via capping
or removal.
Shallow
groundwater
collection will
eventually attain
ARARs in 6 years
with use restrictions
in the in.erim.
Long-term
Effectiveness and
Permanence
Exposure potential would
persist until contaminant
concentrations are
sufficiently reduced
through natural
attenuation.
Some solid media and all
groundwater exposure
pathways permanently
eliminated. Restrictions
must be enforced/
maintained. Remaining
groundwater potential
would persist for 10 years.
Elevated VOC solids
would be removed.
Solids contaminants
would persist, but
exposure pathways
eliminated with
permanent capping.
Shallow groundwater
would be permanently
addressed via collection
and use restrictions.
Reduction of
Toxicity, Mobility,
or Volume
No reduction except
through natural
attenuation.
Mobility of some solids
contaminants reduced
via capping and RCRA
impoundment closure.
Groundwater addressed
via natural attenuation
only.
Mobility of solids
contaminants would be
reduced via capping.
VOC removal and
RCRA impoundment
closure. Shallow
groundwater
contaminant volume.
mobility, and toxicity
would be reduced via
collection and disposal
at WWTP.
Short-term
Effectiveness
No risks through
implementation.
Site risks still
persist.
This alternative will
present short-term
risks to the
community and
environment
through RCRA
impoundment
closure and
solidification.
These risks can be
managed through
the implementation
of site control
measures.
This alternative will
present short-term
risks to the
community and
environment
through RCRA
impoundment
closure and
solidification and
elevated VOC area
solids removal.
These risks can be
managed through
implementation of
site control
measures.
Implementability
No remedial actions
take place under this
alternative.
Remedial actions of
this alternative are
commonly applied,
technically proven.
and technically
simple.
Most remedial actions
of this alternative are
commonly applied,
technically proven.
protective, and
effective.
Hydrogeologic
characteristics may
hinder implementation
of shallow
groundwater actions.
Cost
SO
$29,967,000
NOTE: Includes
costs that
facilitate lower
cost for several
other OUs-
mostly by
eliminating off-
site disposal
costs.
$36,812,000
NOTE: Includes
costs that
facilitate lower
cost for several
other OUs -
mostly by
eliminating off-
site disposal
costs.
-------
TABLE 2b - Operable Unit 2
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
LAGOON AREA
Alternative
SC-4L:
Overall Protection of
Human Health and the
Environment
Protective of human health
and (he environment.
Exposure pathways
eliminated by placement
into a secure landfill.
Groundwater source
addressed by shallow
collection for disposal and
groundwater use
restrictions.
Compliance with
ARARs
Solids excavated
and placed in a
secure landfill to
attain ARARs.
Shallow
groundwater
collection will
attain ARARs in 3
years with
groundwater use
restrictions.
Long-term
Effectiveness and
Permanence
All contaminated solids
would be excavated and
placed into the secure
landfill/CAMU. Shallow
groundwaler would be
permanently addressed via
aggressive collection and
use restrictions.
Reduction of
Toxicity, Mobility,
or Volume
Mobility of solids
contaminants would be
reduced via landfilling.
VOC removal and
RCRA impoundment
closure. Shallow
groundwaier
contaminant volume.
mobility and toxicit_,
would be reduced via
collection and disposal
at WWTP.
Short-term
Effectiveness
This alternative will
present short-term
risks to the
community and
environment
through RCRA
impoundment
closure and
solidification, and
excavation of
solids. These risks
can be managed
through the
implementation of
site control
measures.
Implementability
Remedial actions of
this alternative are
technically proven,
protective, and
effective. On-site
solids disposal may be
administratively more
difficult to implement
since the Lagoon Area
must be the first area
addressed and the
CAMU must be
approved and
designed.
Hydrogeologic
characteristics may
hinder performance
and effectiveness of
shallow groundwater
actions.
Cost
$44,746,000
NOTE: Includes
costs that
facilitate lower
cost for several
other OUs -
mostly by
eliminating off-
site disposal
costs.
-------
Table 3
NINE CRITERIA COMPARISON SUMMARY TABLE
OU-3 (Kokomo & Wildcat Creeks)
(see table below for common actions)
EVALUATION CRITERIA
1. Overall Protection of Human
Health & Environment
2. Compliance with ARARs
3. Long-term Effectiveness and
Permanence
4. Reduction of Toxicity, Mobility or
Volume thru Treatment
5. Short Term Effectiveness
6. Implementability
7. Cost (in millions)
8. Support Agency Acceptance
9. Community Acceptance
ALT. SC-1
No Action
Q
0
Q
Q
Q
Q
$0
ALT. SC- 2C
Restricted Access
A
A
a
a
A
•
$1.15
ALT. SC- 3C
Contain Contaminated Sediment In-Place
•
•
A
A
A
•
$7.89
ALT. SC-4C
Excavate Contaminated Sediment and
Consolidate On-Site
•
•
•
A
A
•
$12.56
U.S. EPA Support for Alternative SC-4C will be evaluated after the public comment period.
Community Acceptance of the Selected Alternative after the Proposed Plan public comment period was favorable.
N/A- Not Addressed
I Fully meets criteria
A Partially meets criteriaQ Does not meet criteria
For more information, see the detailed nine criteria comparison table that follows or the Feasibility Study in the Repository at the Library.
There are NO Common Actions to the OU-2 Alternatives.
-------
TABLE 3a - Operable Unit 3
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
WILDCAT AND KOKOMO CREEKS
Alternative
SC-1C:
SC-2C:
SC-3C:
Overall Protection of
Human Health and
the Environment
Not protective of the
environment, except
through natural
attenuation and
dispersion. Effects
individual species as
compared to the
aquatic population in
Adequately protective
of human health
through fence and sign
placement. This would
requir- long-term
maintenance. Not
protective of the
aquatic environment
over these two miles
except through natural
Adequately protective
of human health and
the environment.
Concrete matting
would prevent
migration and
leaching of
contaminants from
sediment.
Compliance
with ARARs
ARARs not
attained for
sediment.
ARARs not
attained for
sediment.
Would comply
with ARARs
because
exposure
pathways would
be eliminated.
Sediment itself
would not be in
compliance for
extended
period. May
Long-term Effectiveness
and Permanence
No permanent solution for
contaminated sediment.
Affects local portion of
Creeks. Sediment may be
transported downstream
to other areas of the
Creeks.
No permanent solution for
contaminated sediment.
Affects local portion of
Creeks. Sediment may be
transported downstream
to other areas of the
Creeks
No treatment or removal
of contaminated sediment.
but is a long-term solution
to exposure through
installation of protective
cover. Impact of
upstream contaminated
sediment to recontaminate
area needs to be
addressed.
Reduction of Toxicity,
Mobility, or Volume
No reduction except
through natural
attenuation and
hydraulic transport.
No reduction except
through natural
attenuation and
hydraulic transport.
Mobility of sediment
contaminants reduced
through installation of
low-permeability cap.
Toxicity and volume
not addressed.
Short-term
Effectiveness
No short-term risks
to the community or
environment. Short-
term risks to
workers during
environmental
monitoring. Site
risks still persist.
Short-term risks
during fence
installation and
monitoring. Site
risks still persist.
Short-term risks
during cap
placement to
workers and
significant impact
to the aquatic
habitat. Other risks
during monitoring.
Implementability
Easy to implement from a
technical standpoint.
Easy to implement from a
technical standpoint.
Maintenance of fence is an
issue. No protection for
aquatic species.
May require floodplain
mitigation and Army Corps
permits. Impact to habitat
significant. Odor
control/fish kill possibly
required.
Cost
SO
SI, 147,000
$7,890,000
-------
TABLE 3a - Operable Unit 3
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
WILDCAT AND KOKOMO CREEKS
Alternative
SC-4C:
Overall Protection of
Human Health and
the Environment
Protective of human
health and the
environment. Removal
and on-site disposal of
sediment in a secure
landfill would
eliminate pathways of
migration and
exposure.
Compliance
with ARARs
Would comply
with ARARs
because
sediment would
be permanently
removed and
contained
within a secure
landfill.
Long-term Effectiveness
and Permanence
Removal and containment
of sediment in a secure
landfill. Permanent
solution for the
contaminated sediment.
No residual contaminated
sediment would remain.
Impact of upstream
contaminated sediment to
recontaminate area needs
to be addressed.
Reduction of Toxicity,
Mobility, or Volume
Volume and mobility
would be reduced
through sediment
removal and through
isolation in a secure
landfill.
Short-term
Effectiveness
Short-term risks
possible during
sediment removal
and monitoring.
Significant impact
to aquatic habitat
possible.
These risks are
manageable through
implementation of
adequate, proper
institutional control
measures and health
and safety
protocols.
Implementability
Special design
considerations for control of
turbidity, storage, and
dewatering/solidification
options. Odor control/fish
kill possibly required.
Dependent on on-site
landfill approval and
completion to the point of
accepting sediments from
the creeks.
These are manageable
through appropriate design
development and design
implementation.
Cost
$12,560,000
NOTE: Includes
a cost benefit via
on-site CAMU
landfill by
eliminating off-
site disposal
costs.
-------
Table 4
NINE CRITERIA COMPARISON SUMMARY TABLE
OU-4 (Markland Avenue Quarry)
(see table below for common actions)
EVALUATION CRITERIA
1. Overall Protection of Humin
Health & Environment
2. Compliance with ARARs
J. Long-term Effectiveness and
Permanence
4. Reduction of Toxicity, Mobility
or Volume thru Treatment
5. Short Term Effectiveness
6. Implementability
7. Cost (in millions)
8. Support Agency Acceptance
9. Community Acceptance
ALT. SC-1Q
No Action
a
0
a
a
•
•
$0
ALT. SC- 2Q
Cap Contaminated
Solids/Deed
Restrictions
A
A
A
A
•
A
$17.3
ALT. SC- 2.5Q
(modified)
Cap Contaminated Solids/
Collect & Contain Shallow
Groundwater and Dispose
Off-Site/Deed Restrictions
•
•
•
A
A
A
$11.2
ALT. SC- 3Q
Cap Contaminated Solids/Elevated
VOC Solids Removal/Collect &
Contain Shallow Groundwater and
Dispose Off-Site/Deed Restrictions
•
•
•
A
A
A
$31.61
ALT. SC-4Q
Excavate Contaminated Solids
and Dispose Off-Site/Collect &
Contain Shallow Groundwater
and Dispose Off-Site
•
•
•
•
A
A
$351.3
U.S. EPA Support for Alternative SC-2Q (modified) will be evaluated after the public comment period.
Community Acceptance of the Selected Alternative after the Proposed Plan public comment period was favorable.
N/A - Not Addressed
I Fully meets criteria
A Partially meets criteriaQ Does not meet criteria
For more information, see the detailed nine criteria comparison table that follows or the Feasibility Study in the Repository at the Library.
Common Actions to the OU-4 Alternatives, except No Action
• Groundwater Use Restrictions
• Excavate Contaminated Sediment from Quarry Pond
• Backfill Quarry Pond
-------
TABLE 4a - Operable Unit 4
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
MARKLAND AVENUE QUARRY
Alternative
SC-1Q:
SC-2Q:
SC-2.5Q:
(modified)
Overall Protection of
Human Health and the
Environment
Not protective of human health
or the environment, except
through natural attenuation.
Protective of both human
health and the environment.
Capping and sediment removal
would reduce solids leaching
potential. Surface water
exposure pathway eliminated.
Site access restricted. Natural
attenuation with ground water
use limitations to address
groundwater.
Protective of both human
health and the environment.
Cover system and sediment
removal would reduce solids
leaching potential. Surface
water exposure pathway
eliminated with Quarry
backfilling. Site access
restricted. Containment of
shallow water-bearing zone
immediately around Quarry.
Natural attenuation with
groundwater use limitations to
address groundwater.
Compliance
with ARARs
Would not
comply with
ARARs for
solids.
groundwater or
surface water.
Surface water
and solid media
ARARs would be
attained all or in
part. ARARs for
shallow
groundwater
would be
achieved in 30
years.
Surface water
and solid media
ARARs would be
attained all or in
part. ARARs for
shallow
groundwater
would be
achieved in 15-
20 years.
Long-term
Effectiveness and
Permanence
Exposure pathways
would remain until
contaminant
concentrations are
sufficiently reduced
through natural
attenuation.
Surface water pathways
permanently eliminated.
Capping, sediment
removal and use
restrictions would reduce
solids and groundwater
pathways. Need long-
term maintenance and
groundwater use
restrictions.
Surface water pathways
permanently eliminated.
Cover system, sediment
removal and use
restrictions would reduce
solids and groundwater
pathways. Need long-
term maintenance and
groundwater use
restrictions.
Groundwater
contamination reduced
below MCLs in shorter
timeframe. Less time for
potential exposure.
Reduction of
Toxicity, Mobility,
or Volume
No reduction except
through natural
attenuation.
Surface water
eliminated. Mobility of
solids contaminants
reduced through
capping and sediment
removal.
Surface water
eliminated. Mobility of
solids contaminants
reduced through
capping and sediment
removal. Mobility and
volume of shallow
groundwater
contamination reduced.
Short-term
Effectiveness
No additional risks*
to the community
or environment
through
implementation.
Site risks still
persist.
Short-term risks to
workers and
environment
during capping,
sediment removal
and filling in the
pond.
Short-term' risks to
workers and
environment
during cover
installation,
sediment removal
and filling in the
pond.
Implementability
No remedial actions
take place under this
alternative.
Moderately difficult to
implement from a
technical standpoint.
Sediment removal
would require less
common and
technically complex
remedial techniques.
Moderately difficult to
implement from a
technical standpoint.
Sediment removal
would require less
common and
technically complex
remedial techniques.
Cost
$0
$17,281,000
SI 1,200,000
-------
TABLE 4a - Operable Unit 4
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
MARKLAND AVENUE QUARRY
Alternative
SC-3Q:
SC-4Q:
Overall Protection of
Human Health and the
Environment
Protective of human health and
the environment. Surface
water eliminated. Solids
addressed by capping and
removal. Shallow
groundwater addressed through
collection and groundwater use
restrictions.
Protective of human health and
the environment. Surface
waler eliminated.
Contaminated solids
eliminated. Shallow
groundwater addressed through
collection and groundwater use
restrictions.
Compliance
with ARARs
Surface water
and solid media
ARARs would be
attained. Collect
shallow
groundwater.
Groundwater
ARARs achieved
in 20 years.
Surface water
and solid media
ARARs would be
attained. Collect
shallow
groundwater.
Groundwater
ARARs achieved
in 1 5 years.
Long-term
Effectiveness and
Permanence
Surface water pathway
eliminated. Capping,
sediment and elevated
VOC solids removal
would permanently
reduce leaching. Shallow
groundwater would be
permanently remediated.
Need restrictions to
protect from
groundwater use.
Surface water and
contaminated solids
pathways permanently
eliminated. Shallow
groundwater
permanently remediated.
Need groundwater use
restrictions.
Reduction of
Toxicity, Mobility,
or Volume
Surface water
eliminated. Mobility of
solids reduced through
capping, elevated VOC
solids and sediment
removal. Groundwater
contaminant volume
and mobility reduced
through collection.
Mobility of surface
water and contaminated
solids eliminated by
placement in a secure
landfill. No area to
treat on-site.
Groundwater
contaminant volume.
toxicity, and mobility
would be reduced.
Short-term
Effectiveness
Short-term risks
during capping,
sediment removal.
VOC pond filling
and groundwater
extraction system
installation.
Short-term risks
during pond
filling, solids
removal, and
groundwater
extraction system
installation.
Implementability
Moderately difficult to
implement from a
technical standpoint.
Sediment removal
would require less
common and
technically complex
remedial techniques.
Difficult to implement
from a technical and
m;i :rials handling
standpoint. Sediment
removal would require
less common and
technically complex
remedial techniques.
I.28M cubic yards of
material removed to
over 50 feet in depth
would be very
difficult.
Cost
S3 1,608,000
$351,272,000
-------
Table 5
NINE CRITERIA COMPARISON SUMMARY TABLE
OU-5 (Main Plant Property)
(see table below Tor common actions)
EVALUATION CRITERIA
1. Overall Protection of Human
Health & Environment
2. Compliance with ARARs
3. Long-term Effectiveness and
Permanence
4. Reduction of Toxicity, Mobility
or Volume thru Treatment
5. Short Term Effectiveness
6. Implementabilily
7. Cost (in millions)
8. Support Agency Acceptance
9. Community Acceptance
ALT. SC-I
No action
Q
Q
a
a
a
Q
$0
ALT. SC- 2M
Deed Restrictions
A
Q
A
O
•
A
$2.15
ALT. SC- 3M
Cap Contaminated Solids / Collect
& Contain Shallow Groundwater
and Dispose Off-Site / Deed
Restrictions
•
• '
•
A
•
•
$4.82
ALT. SC- 3.5M
(modified)
Cap Contaminated Solids / PCB
Solids Removal / Collect &
Contain Shallow Groundwater
and Dispose Off-Site / Deed
Restrictions
•
•
•
A
•
•
$7.7
ALT. SC- 4M
Excavate All Contaminated
Solids / Collect and Contain
Shallow Groundwater and
Dispose Off-Site
•
•
•
A
•
•
$20.33
U.S. EPA Support for Alternative SC-3M (modified) will be evaluated after the public comment period.
Community Acceptance of the Selected Alternative after the Proposed Plan public comment period was favorable.
N/A - Not Addressed • Fully meets criteria A Partially meets criteriaQ Does not meet criteria
For more information, see the detailed nine criteria comparison table that follows or the Feasibility Study in the Repository at the Library.
Common Actions to the OU-5 Alternatives, except No Action
Groundwater Use Restrictions
Elevated VOC Solids Removal and On-Site Disposal
-------
TABLE 5a - Operable Unit 5
MAIN PLANT
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
Alternative
SC-1M:
SC-2M:
SC-3M:
Overall Protection of
Human Health and the
Environment
Not protective of human
health or the environment.
All exposure pathways
would remain.
Solids addressed by site
restrictions that require
enforcement. VOC
leaching potential
eliminated through
removal. Natural
attenuation with
groundwater use
limitations to address
groundwater.
Human exposure pathways
to contaminated solids
eliminated. Shallow
groundwater collected for
disposal. Enforcement of
deed and groundwater use
restrictions is still required.
Compliance
with ARARs
ARARs would not
be attained for
solids or
groundwater,
except through
natural
attenuation.
ARARs not
attained for solids,
except through
natural
attenuation.
Shallow
groundwater
would attain
ARARs in
approximately 40
years.
ARARs attained
for solids and
eventually shallow
groundwater in
approximately IS
years.
Long-term Effectiveness
and Permanence
No permanent solution for
contaminated solids or
groundwater.
Long-term solution to
leaching potential.
Additional permanent risk
reduction through
institutional controls. Relies
on long-term enforcement.
Exposure pathways to
contaminated sol ids
permanently eliminated, but
long-term maintenance
required. Elevated VOC
solids removed and
remaining contaminated
solids remain in-place.
Shallow groundwater
permanently addressed
through collection.
Reduction of Toxicity,
Mobility, or Volume
No reductions, except
through natural
attenuation and
dispersion.
Little to no reduction.
except through na'i.ral
attenuation. VOC
leaching potential from
solids reduced.
Mobility reduced for
solids contaminants
through capping. Volume,
mobility, and toxicity of
shallow groundwater
reduced.
Short-term
Effectiveness
No additional risks
to the community,
workers, or the
environment. Site
risks still persist.
Limited risks to
workers during
VOC removal and
monitoring. Some
site risks still
persist.
Limited risks to
workers during
VOC hot spot
removal, cap
placement,
monitoring and
trenching.
Implementability
Easy to implement
from a technical
standpoint.
Easy to implement
from a technical
standpoint.
Moderately difficult
to implement. Relies
on Lagoon Area as
CAMU and Lagoon
Area initially
addressed.
Cost
SO
$2,145,000
$4,822,000
-------
TABLE 5a - Operable Unit 5
MAIN PLANT
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
Alternative
SC-3.5M:
SC-4M:
Overall Protection of
Human Health and the
Environment
Human exposure pathways
to contaminated solids
eliminated. Shallow
groundwater collected for
disposal. Enforcement of
deed and groundwater use
restrictions is still required.
Human exposure pathways
to contaminated solids
eliminated by placement in
a secure landfill. Shallow
groundwater collected for
disposal. Groundwater use
restrictions required.
Compliance
with ARARs
ARARs attained
for solids and
eventually shallow
groundwater in
approximately 10
years.
ARARs attained
for solids and
eventually shallow
groundwater in
approximately 10
years.
Long-term Effectiveness
and Permanence
Exposure pathways to
contaminated solids
permanently eliminated, but
long-term maintenance
required. Elevated VOC
solids and PCBs removed
and remaining contaminated
solids remain in-place.
Shallow groundwater
permanently addressed
through collection.
Exposure pathways to
contaminated .solids
eliminated by permanent
placement in a secure
landfill. Shallow
groundwater permanently
addressed.
Reduction of Toxicity,
Mobility, or Volume
Mobility and volume
reduced for solids
contaminants through
removal of source area
solids. Volume, mobility,
and toxicity of shallow
groundwater reduced.
Mobility of contaminated
solids reduced through
removal. Volume,
mobility, and toxicity of
shallow groundwater
reduced through
collection and off-site
disposal.
Short-term
Effectiveness
Limited risks to
workers during
VOC & PCB
removal, cover
installation,
monitoring and
trenching.
Increased risks to
on-site workers and
the community
during solids
removal, trenching.
and monitoring.
Implementability
Moderately difficult
to implement. Relies
on Lagoon Area as
CAMU and Lagoon
Area initially
addressed and ready
to receive solid
wastes.
Moderately difficult
to implement. Relies
on I agoon Area
approved as CAMU
and Lagoon Area
initially addressed.
Cost
$4,822,000
$20,334,000
-------
Table 6
NINE CRITERIA COMPARISON SUMMARY TABLE
OU-6 (Slag Processing Area)
(see table below for common actions)
EVALUATION CRITERIA
1. Overall Protection of Human
Health & Environment
2. Compliance with ARARs
3. Long-term Effectiveness and
Permanence
4. Reduction of Toxicity, Mobility or
Volume thru Treatment
5. Short Term Effectiveness
6. Implementability
7. Cost (in millions)
8. Support Agency Acceptance
9. Community Acceptance
ALT. SC-1S
No Action
a
a
a
a
•
•
$0
ALT. SC- 2S
Regrade Piles / Stabilize Creek
Bank / Deed Restrictions
A
•
•
•
A
•
$2.62
ALT. SC- 3S
Regrade Slag Piles / Cap
Contaminated Solids / Deed
Restrictions / Stabilize Creek
Bank
•
•
•
•
A
•
$3.05
ALT. SC- 3.5S
Regrade Slag Piles / Cover
Contaminated Solids with
Common Soil / Deed Restrictions
/ Stabilize Creek Bank
•
•
•
•
A
•
$2.42
ALT. SC-4S
Excavate Contaminated
Solids and Consolidate On-
Site
•
•
•
•
•
A
$25.87
U.S. EPA Support for Alternative SC-3S (modified) will be evaluated after the public comment period.
Community Acceptance of the Selected Alternative after the Proposed Plan public comment period was favorable.
N/A - Not Addressed • Fully meets criteria A Partially meets criteriaQ Does not meet criteria
For more information, see the detailed nine criteria comparison table that follows or the Feasibility Study in the Repository at the Library.
There are NO Common Actions to the OU-6 Alternatives.
-------
TABLE 6a - Operable Unit 6
CONTINENTAL STEEL SUPERFUND SITE
COMPARISON OF REMEDIAL ALTERNATIVES
SLAG PROCESSING AREA
Alternative
SC-IS:
SC-2S:
SC-3S.
SC-3.5S:
SC-4S:
Overall Protection of
Human Health and the
Environment
Not protective of human
health or the environment.
Exposure pathways would
remain under residential use
scenario.
Limited reduction of the
threat to human health and
the environment resulting
from metals in the slag. Slag
piles would be regraded to
eliminate a potential
pathway for contamination.
Depends on access
restrictions to control risks.
Pathways for human
exposure eliminated and
would significantly reduce
exposure potential.
Pathways for human
exposure eliminated and
would significantly reduce
exposure potential.
Pathways for human
exposure would be
eliminated.
Compliance with
ARARs
Would not comply
with ARARs.
ARARs would not
be fully attained
through removing
some of slag and
using it as fill in
other areas of the
CSSS. Subsurface
media would still
not achieve
ARARs.
ARARs would be
attained through
capping of
contaminated solids
ARARs would be
attained through
covering of
contaminated solids
ARARs would be
attained through
removal, relocation,
and on-site disposal
of contaminated
solids.
Long-term
Effectiveness and
Permanence
No long-term solution to
solid media
contamination.
Restrictions on property
use, fencing, and material
relocation would afford
long-term effectiveness as
long as enforced.
Cap would afford long-
term reductions in
exposure potential but
would need to be
maintained. Coordinate
with construction of
house foundations.
Cover system would
afford long-term
reductions in exposure
potential but would need
to be maintained.
Coordinate with
construction of house
foundations.
Removal would afford
permanent elimination of
exposure pathways.
Reduction of
Toxicity, Mobility, or
Volume
No reductions, since
there would be no
treatment options.
Some reductions in
mobility due to
removing slag piles.
Mobility of solid media
contaminants would be
reduced through
capping. Toxicity and
volume would be
unaffected.
Mobility of solid media
contaminants would be
reduced due to cover
system. Toxicity and
volume would be
unaffected.
Mobility of solid media
contaminants would be
eliminated. Volume and
toxicify would be
unaffected.
Short-term
Effectiveness
No short-term risks
to the community or
environment. Site
risks still persist.
Short-term risks to
the community or
environment only
due to regrading.
Short-term risks
would be limited to
dust emissions and
direct exposure
potential during cap
installation.
Short-term risks
would be limited to
dust emissions and
direct exposure
potential during
cover system
installation.
Short-term risks
would be limited to
dust emissions and
direct exposure
potential during
contaminated solids
removal.
Implementability
Not applicable,
because there are no
actions to implement.
Technically easy to
implement.
Technically easy to
implement.
Technically easy to
implement.
Technically easy to
implement.
Relies on approval of
CAMU and Lagoon
Area is addressed
initially.
Cost
$0
$2,622,000
$3,045,000
$2,420,000
$25,622,000
-------
APPENDIX C
Risk Assessment Cancer and Noncancer Result Tables
-------
Table ES-1
Cancer Risk Estimates
Final Baseline Risk Assessment
Continental Steel Superfund Site
Kokomo, Indiana
Exposure Pathway by
Operable Unit
Receptor
Current and Future
Offsite Residents
RUE
CTE
Future Onsite
Residents
RUE
ere
Future Onsite Commercial/
Industrial Workers
RME
CTE
Future Onsite
Construction Worker
RME
C7-E
Current and Future
Onsite Trespasser
RME
CTE
Main Plant
Soil Ingestion
Dermal Contact
Total Risk
7.6E-05
5.7E-06
8.2E-05
5.7E-06
2.1E-07
5.9E-06
NA
NA
NA
NA
NA
NA
7.4E-05
2.0E-05
9.4E-05
1.1E-06
8.5E-07
2.0E-06
1.5E-06
1.6E-07
1.7E-06
8.6E-09
6.2E-09
1.5E-08
2.5E-05
6.9E-05
9.4E-05
1.8E-06
1 .4E-06
3.2E-06
Markland Avenue Quarry
Soil Ingestion
Dermal Contact
Surface Water Ingestion
Dermal Contact with
Surface Water
Total Risk *
1.1E-04
2.2E-04
-
-
3.3E-04
6.0E-06
1.7E-06
-
-
7.7E-06
1.6E-04
2.9E-04
-
-
4.5E-04
9.7E-06
4.9E-06
-
-
1.5E-05
6.8E-05
8.0E-06
- .
-
7.6E-05
7.0E-06
8.2E-07
-
-
7.9E-06
1.4E-06
6.4E-08
-
-
1.4E-06
5.5E-08
6.1E-09
-
-
6.1E-08
2.3E-05
2.8E-05
2.2E-06
3.7E-06
5.1E-05
5.6E-06
1.3E-06
-
-
6.9E-06
Slag Processing Area
Soil Ingestion
Dermal Contact
Total Risk
NA
NA
NA
NA
NA
NA
1.7E-04
7.4E-07
1.7E-04
1 .3E-05
1.6E-10
1.3E-05
7.2E-05
2.0E-08
7.2E-05
9.5E-06
2.7E-10
9.5E-06
1.5E-06
1.6E-10
1.5E-06
7.2E-08
2.0E-12
7.2E-08
2.4E-05
7.0E-08
2.4E-05
1 .5E-05
4.3E-11
1.5E-05
Lagoon Area
Soil Ingestion
Dermal Contact
Total Risk
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.6E-04
3.6E-05
.1.9E-04
5.3E-07
3.0E-07
8.4E-07
NA
NA
NA
NA
NA
NA
5.2E-05
1.2E-04
1.7E-04
8.5E-07
4.9E-07
1.3E-06
NA Not applicable
* Total Risk does not include exposure to surface water, due to the high pH of the quarry water (pH 12 or higher) exposure is not considered likely.
-------
Table ES-1
Cancer Risk Estimates
Final Baseline Risk Assessment
Continental Steel Superfund Site
Kokomo, Indiana
Exposure Pathway
Sediment Ingestion
Dermal Contact
Ingestion of Site-wide
Surface Water
Total Risk b
Kokomo and Wildcat Creeks
Recreational Visitors
Reach 1
RUE
1.6E-04
8.6E-04
3.1E-07
1 .OE-03
CTE
1.8E-06
2.7E-06
7.6E-09
4.4E-06
Reach 2
RME
3.4E-05
1.8E-04
-
2.1E-04
CTE
1.6E-06
1.1E-06
-
2.7E-06
Reach 3
RME
1.4E-05
7.5E-05
-
8.8E-05
ere
1.1E-06
1.2E-06
-
2.3E-06
Reach 4
RME
1.2E-03
6.8E-03
-
8.0E-03
CTE
1.2E-06
3.0E-06
-
4.2E-06
Reach 5
RME
1.9E-04
1.1E-03
-
1.2E-03
CTE
1.8E-06
1.6E-06
-
3.5E-06
Reach 6
RME
7.6E-06
4.5E-05
-
5.3E-05
CfE
8.7E-07
1.3E-06
-
2.2E-06
NA Not applicable
* Total Risk does not include exposure to surface water, due to the high pH of the quarry water (pH 12 or higher) exposure is not considered likely.
b Total Risk does not include ingestion of surface water.
-------
Table ES-2
Non Cancer Risk Estimates
Final Baseline Risk Assessment
Continental Steel Superfund Site
Kokomo, Indiana
Exposure
Pathway by
Operable Unit
Receptor
Current and Future
Offsito Residents
RUE
CTE
Future Onsite
Residents
RUE
CTE
Future Onsite
Commercial/Industrial
Workers
RME
CTE
Future Onsite
Construction
Worker
RME
CTE
Current and Future
Onsite Trespasser
RME
CTE
Main Plant
Soil Ingestion
Dermal Contact
Total Risk
2.7E+00
OE+OO
2.7E+00
8.8E-01
OE+00
8.8E-01
NA
NA
NA
NA
NA
NA
1.1E+00
2.3E-01
1.3E+00
2.6E-02
1.1E-02
3.7E-02
1.6E+00
1.4E-01
1.7E+00
8.9E-03
3.7E-3
1.3E-02
1.1E+00
2.4E+00
3.5E+00
3.8E-02
1.7E-2
5.6E-02
Markland Avenue Quarry
Soil Ingestion
Dermal Contact
Surface Water
Ingestion
Dermal Contact
with Surface Water
Total Risk •
2.78E+00
NC
-
-
2.8E+00
9.08E-01
NC
-
-
9.1E-01
6.37E+00
7.70E-01
'
-
7.1E+00
1.49E+00
3.04E-02
-
-
1.5E+00
5.20E-01
2.48E-02
-
-
5.4E-01
1.48E-01
5.95E-03
-
-
1.5E-01
7.89E-
01
1.49E-
02
-
-
8.0E-01
5.15E-02
1.97E-03
-
-
5.3E-02
5.41 E-01
2.67E-01
1.05E-01
4.86E-01
5.9E-01
1.10E-01
9.13E-03
-
-
1.2E-01
Slag Processing Area
Soil Ingestion
Dermal Contact
Total Risk
NA
NA
NA
NA
NA
NA
8.9E+00
3.9E-03
8.9E+00
2.3E+00
2.8E-06
2.3E+00
7.3E-01
1.3E-04
7.3E-01
2.2E-01
1.1E-06
2.2E-01
1.1E+00
7.6E-05
1.1E+00
7.6E-02
1.9E-07
7.6E-02
7.6E-01
1.4E-03
7.6E-01
3.3E-01
8.4E-07
3.3E-01
Lagoon Area
Soil Ingestion
Dermal Contact
Total Risk
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.9E+00
5.7E-01
3.5E+00
3.0E-02
7.0E-03
3.7E-02
NA
NA
NA
NA
NA
NA
3.8E-K30
6.1E+00
1.0E+01
5.7E-02
1.1E-02
6.7E-02
NA Not applicable
* Total Risk does not include exposure to surface water, due to the high pH of the quarry water (pH 12 or higher) exposure is not considered likely.
-------
Table ES-2
Non Cancer Risk Estimates
Final Baseline Risk Assessment
Continental Steel Superfund Site
Kokomo, Indiana
Exposure Pathway
Sediment Ingestion
Dermal Contact
Total Risk b
Kokomo and Wildcat Creeks
Recreational Visitors
Reach 1
RME
2.1E+01
1.2E+01
3.3E+01
ere
4.8E-02
8.6E-03
5.7E-02
Reach 2
RME
4.5E+00
2.3E+00
6.9E+00
CTE
2.7E-02
1.8E-3
2.8E-02
Reach 3
RME
1.6E+00
8.2E-01
2.4E+00 .
CTE
2.0E-02
2.1E-03
2.2E-02
Reach 4
RME
1.1E+02
6.4E+01
1.7E+02
ere
2.3E-02
4.4E-03
2.8E42
Reach 5
.RME
1.5E+01
8.25E-t-00
2.3E+01
ere
2.8E-02
1.3E-03
3.0E-02
Reach 6
RME
5.3E-01
2.3E-01
7.6E-01
ere
1.4E-02
1.0E-03
1.0E-02
Exposure Pathway
Ingestion of Site-wide Surface Water (All Reaches)
Kokomo and Wildcat Creeks
Recreational Visitors
RME
4.1E-02
ere
1.9E-3
NA Not applicable
* Total Risk does not include exposure to surface watei. due to the high pH of the quarry water (pH 12 or higher) exposure is not considered likely.
" Total Risk does not include ingestion of surface water.
-------
APPENDIX D
Phase II Remedial Investigation Sampling Result Tables
-------
Table MM-1S
SIDE- WIDE GROUNDWATER
Shallow Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L)
1,1,1 -Trichloroethane
1 , 1 ,2-Trichloroethane
1,1-Dichloroe thane
1,1-Dichloroethene
1 ,2-Dichloroethane
1,2-Dichloroethene (total)
Acetone
Benzene
Chloroform
cis- 1 ,2-Dichloroethene
m&p-Xylene
Methylene Chloride
o-Xylene
Tetrach loroethene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Group: SVOCs (ug/L)
1 ,2,4-Trimethylbenzene
1 ,3,5-Trimethylbenzene
1 ,4-Dichlorobenzene
bis(2-Ethylhexyl)phthalate
di-n-Butylphthalate
Group: PAHs (ug/L)
Naphthalene
Pyrene
Group: PCBs (ue/L)
Aroc lor- 1242
Aroclor-1248
No. of
Detects
5
1
5
11
1
3
4
4
3
19
1
3
1
9
13
17
13
1
1
1
2
1
2
1
2
2
No. of Samples
Analyzed
28
28
28
28
28
3
28
28
28
25
25
28
25
28
25
28
28
25
25
28
3
3
28
3
6
6
Range of Concentrations
Detected
1 -43
1 - 1
1 -5
1 -7
2000 - 2000
200 - 400
3-4
1 - 1
1 - 19
1-880
1 - 1
1 - 1
2-2
1 - 1900
1 -7
1 - 2000
1 - 110
9-9
4.4
2-2
2-8
2-2
1- 16
.5 -.5
1.6-4.5
5.8 - 6.4
Group: Pesticides (ug/L)
-------
Table MM-1S
SIDE-WIDE GROUNDWATER
Shallow Water-Bearing Zone Sample Results
Parameter
alpha-Chlordane
No. of
Detects
2
No. of Samples
Analyzed
3
Range of Concentrations
Detected
.081 -.09
Group: Inorganics (mg/L)
Aluminum
Aluminum, Dissolved
Antimony, Dissolved
Arsenic
Arsenic, Dissolved
3arium
Barium, Dissolved
Cadmium
Cadmium, Dissolved
Calcium
Calcium, Dissolved
Chromium, Dissolved
Cobalt, Dissolved
Copper
Copper, Dissolved
Iron
Iron, Dissolved
Lead
Lead, Dissolved
Magnesium
Magnesium, Dissolved
Manganese
Manganese, Dissolved
Mercury
Nickel, Dissolved
Potassium
Potassium, Dissolved
Sodium
Sodium, Dissolved
Vanadium
Vanadium, Dissolved
Zinc
4
7
2
3
8
4
28
3
3
. 4
29
3
3
2
16
4
21
4
1
4
28
4
29
13
7
1
17
4
29
2
6
3
4
29
29
4
29
4
29
4
29
4
29
29
29
4
29
4
29
4
29
4
29
4
29
29
29
4
29
4
29
4
29
4
.344 - .775
.082 - .923
.002 - .006
.003 -.01 3
.004 -.01 4
.099 -.169
.018 -.358
.0003 -.0031
.0004 - .0007
131-235
13-620
.01 7 -.066
.007 -.13
.015 -.016
.006 -.01 5
7.58- 12.5
.083 - 3050
.009 - .03
.12-. 12
28-49
1 1 - 236
.879- 1.77
.009-38.7
.0001 - .0003
.021 -.875
5.24 - 5.24
6-79
45- 127
19-456
.009 -.011
.008 -.01 2
.058 - .246
-------
Table MM-1S
SIDE- WIDE GROUNDWATER
Shallow Water-Bearing Zone Sample Results
Parameter
Zinc, Dissolved
No. of
Detects
7
No. of Samples
Analyzed
29
Range of Concentrations
Detected
.045 -.621
Group: Miscellaneous (mg/L)
Alkalinity
Chloride
Nitrate/Nitrite Nitrogen
Sulfate
Total Phosphorous
4
27
3
4
4
4
29
4
4
4
310-620
32 - 265
.65 - 4.89
70- 182
.07-. 53
-------
Table MM-1I
SIDE- WIDE GROUNDWATER
Intermediate Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L)
1,1,1 -Trichloroethane
1,1-Dichloroethane
IjJ-Dichloroethene
1,2-Dichloroethene (total)
Acetone
Acrylonitrile
Benzene
Carbon Disulfide
Chloromethane
cis- 1 ,2-Dichloroethene
Ethylbenzene
m&p-Xylene
vtethylene Chloride
o-Xvlene
Styrene
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Group: SVOCs (ue/U
Kexachlorobutadiene
Group: Inorganics (me/L)
Aluminum, Dissolved
Antimony, Dissolved
Arsenic, Dissolved
Barium, Dissolved
Calcium, Dissolved
Chromium, Dissolved
Cobalt, Dissolved
Conner. Dissolved
No. of
Detects
3
9
11
1
3
5
2
1
1
31
1
3
4
1
3
2
1
16
18
22
1
6
5
9
27
27
1
2
12
No. of Samples
Analyzed
33
33
33
1
29
28
33
29
29
32
33
32
33
32
29
33
33
32
33
29
28
27
27
27
27
27
27
27
27
Range of Concentrations
Detected
1 - 18
1 -55
1 -7
2000 - 2000
5- 14
19- 140
1 - 1
3-3
1 - 1
1 - 1900
1 - 1
1 -4
1 - 1
1 - 1
1 - 11
76-99
1 - 1
1 -29
1 -5100
1 - 150
1 - 1
.082 -.144
.002 - .004
.003 - .008
.012 - .278
3-427
.048 - .048
.019 -.019
.006 -.01 2
-------
Table MM-1I
SIDE-WIDE GROUNDWATER
Intermediate Water-Bearing Zone Sample Results
Parameter
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Mercury
Nickel, Dissolved
Potassium, Dissolved
Sodium, Dissolved
Vanadium, Dissolved
Zinc, Dissolved
No. of
Detects
24
26
25
1
4
18
27
2
4
No. of Samples
Analyzed
27
27
27
27
27
27
27
27
27
Range of Concentrations
Detected
.213- 13.9
3-248
.006 - 1 .04
.0006 - .0006
.032 - .272
5-53
16- 144
.016 -.016
.05 - .622
Group: Miscellaneous (mg/L)
Chloride
27
28
24-211
-------
Table MM-1L
SIDE- WIDE GROUNDWATER
Lower Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ue/L)
1,1-Dichloroethane
1 , 1 -Dichloroethene
1 ,2-Dibromoethane
Acetone
Acrylonitrile
Carbon Disulfide
Chloroform
Chloromethane
cis- 1 ,2-Dichloroethene
m&p-Xylene
vlethylene Chloride
Styrene
Tetrachloroethene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Group: PAHs (ue/L)
Naphthalene
No. of
Detects
3
4
1
1
6
2
2
1
15
1
2
2
1
6
9
8
1
No. of Samples
Analyzed
15
15
11
11
11
11
14
14
16
15
16
14
15
16
16
15
14
Range of Concentrations
Detected
1 - 1
1 -2
1 - 1
18- 18
8- 150
1 -2
1 - 1
1 - 1
1 - 4700
1 - 1
1 -4.5
1-6
130- 130
1 -4
1-160
1 -330
1 - 1
Group: Inorganics (me/L)
Aluminum, Dissolved
Antimony, Dissolved
Aluminum, Dissolved
Antimony, Dissolved
Arsenic, Dissolved
Barium, Dissolved
Cadmium, Dissolved
Calcium, Dissolved
Chromium, Dissolved
Copper, Dissolved
Iron, Dissolved
Maenesium Dissolved
4
2
4
2
2
11
3
11
1
5
9
11
1
1
1
.081 -.147
.002 - .007
.081 -.147
.002 - .007
.002 - .003
.033 -.159
.0003 - .0003
13- 167
.016 -.016
.007 -.01 4
.128- 1.09
6-62
-------
Table MM 1L
SIDE- WIDE GROUNDWATER
Lower Water-Bearing Zone Sample Results
Parameter
Manganese, Dissolved
Mercury
Potassium, Dissolved
Selenium, Dissolved
Sodium, Dissolved
Zinc, Dissolved
No. of
Detects
10
1
10
1
11
4
No. of Samples
Analyzed
1
1
1
1
1
1
Range of Concentrations
Detected
.009 -.135
.0001 - .0001
5- 19
.027 - .027
23 - 107
.048 - .062
Group: Miscellaneous (nv /L)
Chloride
11
11
22-139
-------
Table LA-IS
LAGOON AREA
Shallow Water-Bearing Zone Sample Results
Parameters
No. of
Detects
No. of Samples
Analyzed
Range of Concentrations
Detected
Group: VOCS (ug/L)
1 , 1 -Dichloroethene
Acrylonitrile
Carbon Disulfide
Chloromethane
cis- 1 ,2-Dichloroethene
Styrene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
1
1
1
1
. 3
1
1
2
3
3
3
3
3
3
3
3
3
3
2-2
8-8
1 - 1
1 - 1
4-630
1 - 1
3-3
1 - 160
1 -25
Group: Inorganics (mg/L)
Aluminum, Dissolved
Antimony, Dissolved
Barium, Dissolved
Cadmium, Dissolved
Calcium, Dissolved
Copper, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Potassium, Dissolved
Sodium, Dissolved
Zinc, Dissolved
2
I
3
1
3
2
3
3
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
.1 -.119
.002 - .002
.033 -.159
.0003 - .0003
69- 160
.007 - .007
.128- 1.09
32-51
.009 -.135
7-13
33-64
.056 - .062
Group: Miscellaneous (mg/L)
Chloride
3
3
22-112
-------
TableLA-lI
LAGOON AREA
Intermediate Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L)
1 , 1 -Dichloroethane
1,1-Dichloroethene
Acrylonitrile
Carbon Disulfide
cis- 1 ,2-Dichloroethene
Styrene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
No. of
Detects
2
4
1
1
6
1
4
3
5
No. of Samples
Analyzed
6
6
6
6
6
6
6
6
6
Range of Concentrations
Detected
1 -2
1 -4
140- 140
3-3
2 -1100
11 - 11
2-6
5- 1300
2- 110
Group: Inorganics (mg/L)
Aluminum, Dissolved
Antimony, Dissolved
Barium, Dissolved
Calcium, Dissolved
Chromium, Dissolved
Copper, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Nickel, Dissolved
Potassium, Dissolved
Sodium, Dissolved
Vanadium, Dissolved
2
3
6
6
1
4
5
6
6
1
3
6
1
6
6
6
6
6
6
6
6
6
6
6
6
6
.082 -.118
- .002 - .004
.018 -.278
53 - 427
.048 - .048
.007 -.011
.29- 13.9
18-248
.006 - .204
.272 - .272
8-47
21 -82
.016-. 016
Group: Miscellaneous (mg/L)
Chloride
6
6
24-211
-------
Table LA-1L
LAGOON AREA
Lower Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L1,
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene (total)
Acetone
Benzene
cis- 1 ,2-Dichloroethene
VIethylene Chloride
Tetrach loroethene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
No. of Detects
1
2
2
1
3
5
1
3
4
7
4
No. of Samples
Analyzed
7
7
2
7
7
5
7
7
5
7
7
Range of Concentrations
Detected
3-3
2-7
320 - 400
4-4
1 - 1
4-410
1 - 1
2-350
1 -7
1 -710
1-110
Note: Volatile organic compounds were analyzed by two different laboratories, CLP and CRL. The CLP laboratory reported total 1,2-
dichlorocthcne and CRL reported the individual isomcrs Thus, both the total (CLP) and individual isomers (CRL) were reported in this range
list.
Group: BNAs (ug/L)
1 ,4-Dichlorobenzene
Group: Inorganics (mg/L)
Aluminum
Aluminum, Dissolved
Antimony, Dissolved
Arsenic
Arsenic, Dissolved
Barium
Barium, Dissolved
Cadmium
Cadmium, Dissolved
Calcium
Calcium, Dissolved
Chromium, Dissolved
Cobalt, Dissolved
Conner. Dissolved
1
2
3
1
1
2
2
6
2
1
2
7
3
1
4
5
2
7
7
2
7
2
7
2
7
2
7
7
7
7
2-2
.344 . .484
.103 -.923
.002 - .002
.003 - .003
.007 - .009
.137-. 138
.018 -.129
.0003 - .0003
.0007 - .0007
224 - 235
13 - 620
.01 7 -.066
.13-. 13
.01 - .015
-------
Table LA-1L
LAGOON AREA
Lower Water-Bearing Zone Sample Results
Parameter
Group: Inorganics (mg/L)
Iron
Iron, Dissolved
Lead
Magnesium
Magnesium, Dissolved
Manganese
Manganese, Dissolved
Mercury
Nickel, Dissolved
Potassium
Potassium, Dissolved
Sodium
Sodium, Dissolved
Vanadium
Vanadium, Dissolved
Zinc
Zinc, Dissolved
Group: INDIC (mg/U
Alkalinity
Chloride
Nitrate/Nitrite Nitrogen
Sulfate
Total Phosphorous
No. of Detects
2
7
2
2
7 .
2
7
2
5
1
7
2
7
1
2
2
4
2
7
2
2
2
No. of Samples
Analyzed
2
7
2
2
7
2
7
7
7
2
7
2
7
2
7
2
7
2
7
2
2
2
Range of Concentrations
Detected
7.58- 12.5
.111 -3050
.009 -.011
45-49
35 - 236
1.4-1.54
.032 - 38.7
.0001 - .0001
.024 - .875
5.24.- 5.24
6-32
125- 127
95 - 456
.009 - .009
.008 - .008
.15- .246
.045 -.491
460 - 460
90- 195
4.75 - 4.89
172- 182
.08 - .08
-------
Table C-1S
KOKOMO & WILDCAT CREEKS
Shallow Water-Bearing Zone
Parameter
Group: VOCs (UE/L)
1,1,1 -Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1 ,2-Dichloroethane
Acetone
Benzene
Chloroform
cis- 1 ,2-Dichloroethene
VIethylene Chloride
Tetrachloroethene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Group: SVOCs (ug/L)
1 ,4-Dichlorobenzene
di-n-Butylphthalate
Group: PAHs (ug/L)
Naphthalene
Pyrene
No. of Detects
3
4
8
1
2
3
1
13
1
6
9
9 .
9
1
1
1
1
No. of Samples
Analyzed
14
14
14
14
14
14
14
14
14
14
14
14
14
15
1
is
i
Range of Concentrations
Detected
1 -2
1 -3
1 -7
2000 - 2000
3-4
1 - 1
1 - 1
1 -880
1- 1
4-600
1 -5
1 - 2000
17- 110
2-2
2-2
1 - 1
.5 -.5
Group: Inorganics (mg/L)
Aluminum
Aluminum, Dissolved
Arsenic
Arsenic, Dissolved
Barium
Barium, Dissolved
Cadmium
Cadmium, Dissolved
Calcium
Calcium. Dissolved
Chromium, Dissolved
1
3
1
6
1
14
1
1
1
15
3
i
15
1
15
1
15
1
15
1
15
15
.775 - .775
.101 -.923
.013 -.013
.004 - .009
.169 -.169
.025 -.181
.0031 -.0031
.0004 - .0004
131 - 131
13-548
.01 7 -.066
-------
Table C-1S
KOKOMO & WILDCAT CREEKS
Shallow Water-Bearing Zone
Parameter
Cobalt, Dissolved
Copper
Copper, Dissolved
Iron
Iron, Dissolved
Lead
Magnesium
Magnesium, Dissolved
Manganese
Manganese, Dissolved
Mercury
Nickel, Dissolved
Potassium, Dissolved
Sodium
Sodium, Dissolved
Vanadium, Dissolved
Zinc
Zinc, Dissolved
No. of Detects
3
1
7
1
14
1
1
15
1
15
6
3
8
1
15
3
1
4
No. of Samples
Analyzed
15
1
15
1
15
1
1
15
1
15
15
15
15
1
15
15
1
15
Range of Concentrations
Detected
.007 -.13
.016 -.016
.006 -.01 5
10.8- 10.8
.086 - 3050
.017 -.017
28-28
23 - 236
1.77- 1.77
.027-38.7
.0001 -.0001
.055 - .875
6-32
75- 75
34 - 456
.009 -.01 2
.058 - .058
.061 - .491
Note Several dissolved metals (calcium magnesium, manganese, sodium and zinc) are listed as having greater concentrations than the total
than the total concentration for the same metal. This discrepancy occurs because only one sample was analyzed for the total metal versus 15
samples analyzed for the dissolved metal.
Group: Miscellaneous fmg/L)
Alkalinity
Chloride
Sulfate
Total Phosphorous
1
14
1
1
1
15
1
1
310-310
48-214
94-94
.53 - .53
-------
Table MAQ-1
MARKLAND AVENUE QUARRY
Surface Water Sample Results
Parameter
Group: VOCs (ug/L)
Trichloroethene
Methylene Chloride
cis- 1 ,2-Dichloroethene
No. of Detects
13
3
3
No. of Samples
Analyzed
13
13
13
Range of Concentrations
Detected
13-3400
8.6- 19
34-41
Group: Inorganics (mg/L)
Arsenic, Total
Barium, Total
Zinc, Total
1
11
3
13
13
13
.054 - .054
.048 - .68
.02 -.12
-------
Table MAQ-2
MARKLAND AVENUE QUARRY
Pond Sediment Sample Results
Parameter
Group: VOCs (ug/kg)
1,1-DichIoroethene
1 ,2-Dichloroethane
Benzene
Chlorobenzene
Ethylbenzene
m&p-Xylene
o-Xylene
Tetrach loroethene
Toluene
Trichloroethene
Methylene Chloride
cis- 1 ,2-Dichloroethene
trans- 1 ,2-Dichloroethene
Group: PAHs (ug/kg)
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)pvrene
Benzo(a)anthracene
Benzo(b&k)fluoranthene
Benzo(g,h,i)Derylene
Fluoranthene
Fluorene
Indeno( 1 ,2,3-cd)pyrene
Chrysene
Phenanthrene
Group: PCBs (ug/kg)
Aroclor-1242
Aroclor-1248
No. of
Detects
2
1
2
1
4
3
5
3
5
9
1
5
1
2
2
2
4
6
6
2
5
2
3
3
5
3
5
No. of Samples
Analyzed
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
Range of Concentrations
Detected
26- 100
2-2
20-28
30-30
5.1 -4000
5.7-330
5.4 - 3400
5.8- 75
8 - 8600
260 - 200.000
12- 12
6.8 - 260
38-38
3100-3800
3000 - 3900
2500 - 3000
3700- 14.000
11.000-30,000
6000 - 24,000
7400 - 8200
2500 - 9900
4300 - 5400
15,000-28,000
22,000 - 28,000
2000 - 9300
900 - 3300
700-5100
-------
Table MAQ-2
MARKLAND AVENUE QUARRY
Pond Sediment Sample Results
Parameter
No. of
Detects
No. of Samples
Analyzed
Range of Concentrations
Detected
Group: Inorganics (me/kg)
Arsenic, Total
Barium, Total
Cadmium, Total
Chromium, Total
Copper, Total
Lead, Total
Nickel, Total
Zinc, Total
7
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
13-73
140-300
5- 18
33 - 190
38-310
500- 1300
11-120
160-2900
Group: Miscellaneous (%)
Percent Solids
9
9
45 - 79.8
-------
Table MAQ-3
MARKLAND AVENUE QUARRY
Surface Soil Sample Results
Parameter
Group: PAHs (u«/kg)
Acenaphthylene
Anthracene
8enzo(a)pvrene
Benzo(a)anthracene
Benzo(b&k)fluoranthene
Group: PAHs (ug/kg) (Continued
3enzo(g,h,i)perylene
Dibenzo(a,h)anthracene
Fluoranthene
lndeno( 1 ,2,3-cd)pyrene
Chrvsene
Phenanthrene
Group: PCBs (ue/kg)
Aroclor-1248
No. of
Detects
1
3
3
3
4
No. of Samples
Analyzed
29
29
29
29
29
Range of Concentrations
Detected
1600- 1600
2100-4200
4600 - 7600
11,000- 18,000
5100- 17.000
4
1
4
3
4
3
6
29
29
29
29
29
29
29
3100-7100
22,000 - 22,000
2800 - 5300
16,000-24.000
. 16,000-27,000
1 800 - 4400
670- 16,000
Group: Inorganics (mg/kg)
Arsenic, Total
Barium, Total
Cadmium, Total
Chromium, Total
Copper, Total
Lead, Total
Nickel. Total
Zinc, Total
29
29
24
29
28
28
29
29
29
29
29
29
29
29
29
29
42- 140
20 - 690
4-36
10-2800
29- 1100
77 - 2400
19-850
63-41,000
Group: Miscellaneous (%)
Percent Solids
29
29
67.1 -95.7
-------
Table MAQ-4
MARKLAND AVENUE QUARRY
Residential Surface Soil Sample Results
Parameter
Group: PAHs (ue/kg)
Benzo(R,h,i)perylene
Dibenzo(a,h)anthracene
Fluoranthene
Group: PCBs Cue/kg)
Aroclor-1248
No. of
Detects
1
1
2
2
No. of Samples
Analyzed
12
12
12
12
Range of Concentrations
Detected
3000 - 3000
15.000- 15,000
2600-3100
650 - 680
Group: Inorganics (mg/kg)
Arsenic, Total
Barium, Total
Cadmium, Total
Chromium, Total
Copper, Total
Lead, Total
Nickel, Total
Zinc, Total
13
13
3
13
11
12
13
13
13
13
13
13
13
13
13
13
43-74
46-130
4-6
16-38
20 - 57
44- 180
17-93
72 - 370
Group: Miscellaneous (%)
Percent Solids
13
13
77 - 85.9
-------
Table MAQ-5
MARKLAND AVENUE QUARRY
Soil Gas Analytical Sample Results
Parameter
No. of
Detects
No. of Samples
Analyzed
Range of Concentrations
Detected
Group: VOCs (mg/m3)
1,1-dichloroethene
Cis- 1 ,2-dichloroethene
Trans- 1 ,2-dichloroethene
Trichloroethene
Vinvl chloride
6
19
6
34
5
77
77
77
77
77
1 -32
1 - 1980
2- 17
1 - 4530
1 -290
Table MAQ-6
MARKLAND AVENUE QUARRY
Groundwater Screening Sample Results
Parameter
Group: VOCs (uR/L)
1,1,1 -Trichloroethane
1 ,2-Dichloroethane
cis- 1 ,2-Dichloroethene
Benzene
Chlorobenzene
Ethylbenzene
Methylene Chloride
Toluene
Trichloroethene
m&p-Xylene
o-Xylene
No. of
Detects
3
2
6
1
1
1
1
1
7
1
3
No. of Samples
Analyzed
8
8
8
8
8
8
8
8
8
8
8
Range of Concentrations
Detected
590- 1200
560 - 700
6.7 - 33,000
20-20
18- 18
18- 18
250 - 250
22-22
6.6 - 3000
20-20
8-55
-------
Table MAQ-7S
MARKLAND AVENUE QUARRY
Shallow Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L)
Ll-Dichloroethene
Acetone
Benzene
cis- 1 ,2-Dichloroethene
m&p-Xylene
vlethylene Chloride
o-Xylene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Group: SVOCs (ug/L)
1 ,2,4-Trimethy Ibenzene
1 ,3,5-TrimethyIbenzene
Group: PAHs (ug/L)
Naphthalene
No. of
Detects
1
1
1
1
1
1
1
1
1
1
1
1
1
No. of Samples
Analyzed
4
4
4
4
4
4
4
4
4
4
4
4
4
Range of Concentrations
Detected
1 - 1
3-3
1-1
150- 150
1 - 1
1 - 1
2-2
5-5
440 - 440
4-4
9-9
4-4
16- 16
Group: Inorganics (mg/L)
Aluminum, Dissolved
Antimony, Dissolved
Barium, Dissolved
Cadmium, Dissolved
Calcium, Dissolved
Copper, Dissolved
Iron, Dissolved
Lead, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Mercury
Nickel. Dissolved
2
1
4
1
4
2
1
1
3
4
2
1
4
4
4
4
4
4
4
4
4
4
4
4
.082 - .646
.006 - .006
.039 -.358
.0004 - .0004
87 - 205
.013 -.013
.083 - .083
.12-. 12
11-25
.01 - .07
.0002 - .0003
.021 -.021
-------
Table MAQ-7S
MARKLAND AVENUE QUARRY
Shallow Water-Bearing Zone Sample Results
Parameter
Potassium, Dissolved
Sodium, Dissolved
Zinc, Dissolved •
No. of
Detects
1
4
1
No. of Samples
Analyzed
4
4
4
Range of Concentrations
Detected
79-79
61 - 139
.621 -.621
Group: Miscellaneous (mg/L)
Chloride
3
4
51-265
-------
Table MAQ-7I
MARKLAND AVENUE QUARRY
Intermediate Water-bearing Zone Sample Reults
Parameter
Group: VOCs (ug/L)
1 , 1 -Dichloroethene
Acetone
Benzene
Chloromethane
cis-1 ,2-Dichloroethene
No. of
Detects
1
1
1
1
4
No. of Samples
Analyzed
5
4
5
4
5
Range of Concentrations
Detected
3-3
14- 14
1-1
1-1
44- 1400
Group: VOCs (ug/L) (Continued)
m&p-Xylene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
1
1
3
4
2
5
5
5
5
4
1 - I
1 - 1
12-29
1 1 - 720
3-5
Group: Inorganics (mg/L)
Aluminum, Dissolved
Antimony, Dissolved
Arsenic, Dissolved
Barium, Dissolved
Calcium, Dissolved
Copper, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Potassium, Dissolved
Sodium, Dissolved
1
1
1
4
4
2
2
3
2
2
4
4
4
4
4
4
4
4
4
4
4
4
.101 -.101
.002 - .002
.003 - .003
.012 -.106
3-102
.007 - .009
.266 - .347
3-31
.027 - .049
7-53
16-72
Group: Miscellaneous (mg/L)
Chloride
4
4
29- 107
-------
Table MAQ-7L
MARKLAND AVENUE QUARRY
Lower Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L)
Acetone
Acrylonitrile
Carbon Disulfide
cis-l,2-Dichloroethene
No. of
Detects
1
2
1
1
No. of Samples
Analyzed
2
2
2
2
Range of Concentrations
Detected
18- 18
21-85
2-2
19- 19
Group: VOCs (ug/L) (Continued)
m&p-Xylene
Styrene
trans- 1 ,2-Dichloroethene
Trichloroethene
Group: PAHs (ug/L)
Naphthalene
1
1
1
1
1
2
2
2
2
2
1 - 1
6-6
1-1
62-62
1 - 1
Group: Inorganics (mg/L)
Barium, Dissolved
Calcium, Dissolved
Chromium, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Potassium, Dissolved
Sodium, Dissolved
2
2
1
1
2
1
1
2
2
2
2
2
2
2
2
2
.038 -.114
13- 104
.016 -.016
.261 - .261
6-37
.014 -.014
11-11
23-36
Group: Miscellaneous (mg/L)
Chloride
2
2
51 -65
-------
Table MP-1
MAIN PLANT
Wipe Sample Results
Parameter
Group: SVOCs (us/ft2)
Phenol
bis(2-Ethylhexyl)phthalate
di-n-Octylphthalate
Group: PCBs fun/ft2)
Aroclor-1248
Aroclor-1260
Group: Inorganics (nR/ft2)
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
No. of
Detects
1
1
1
6
1
21
21
21
21
21
21
21
21
No. of Samples
Analyzed
21
21
21
21
21
21
21
21
21
21
21
21
21
Range of Concentrations
Detected
1500- 1500
770 - 770
710-710
1.1 - 106
1 .4 - 1 .4
16-190
6.7 - 730
1.1 -36
4.3- 1100
34 - 4600
11 - 100.000
17-530
120-24.000
-------
Table MP-2
MAIN PLANT
Basement Sample Results
Parameter
Group: VOCs (ue/L)
1,2-Dichloroethene (total)
cis- 1 ,2-Dichloroethene
Trichloroethene
No. of
Detects
1
2
2
No. of Samples
Analyzed
3
19
22
Range of Concentrations
Detected
3-3
22 - 370
28-31
Note: Volatile organic compounds were analyzed by two different laboratories, CLP and FASP. The CLP laboratory reported total 1,2-
dichloroethene and FASP reported the individual 1,2-dichlorocthene isomers Thus, both the total individual isomcrs were reported in this list
Group: PAHs (ue/L)
Acenaphthene
Acenaphthylene
Anthracene
2
4
4
24
24
24
84 - 390
34 - 5200
52 - 330
Group: PAHs (ug/L) (Continued)
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b&k)fluoranthene
Benzo(K,h,i)perylene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
[ndeno( 1 ,2,3-cd)pyrene
Naphthalene
Phenanthrene
Pyrene
Group: PCBs (u«/L)
Aroclor-1242
Group: Inorganics (mg/L)
Aluminum
Arsenic
Barium
Cadmium
3
4
5
3
2
4
4
4
2
1
4
4
1
1
2
20
1
24
24
21
24
24
24
. 24
24
24
24
24
24
23
3
23
23
23
340 - 390
80-410
300-41,000
490 - 3000
680 - 680
460 - 980
83- 1500
52 - 260
640 - 900
420 - 420
53 - 230
130-650
11 - 11
.156-. 156
.061 -.1
.0135-. 11
.02 - .02
-------
Table MP-2
MAIN PLANT
Basement Sample Results
Parameter
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Zinc
No. of
Detects
3
2
8
3
4
3
3
9
3
3
23
No. of Samples
Analyzed
3
23
23
3
23
3
3
23
3
3
23
Range of Concentrations
Detected
24.3 - 57.5
.028 - .05
.0099 - .2
1.14-2.11
.002 -.1
1.58-3.41
.201 -.215
.02 - .22
5.25 - 7.32
4.04 - 8.95
.0063- 12
-------
Table MP-3
MAIN PLANT
Sewer Sample Results
Parameter
Group: VOCs (ue/kg)
2-Butanone
Acetone
Chlorobenzene
Chloroform
cis- 1 ,2-Dichloroethene
Ethylbenzene
o-Xylene
Tetrach loroethene
Toluene
Total Xylenes
Trichloroethene
Group: SVOCs (ue/kg)
di-n-Butylphthalate
2-Methylnaphthalene
Group: PAHs (ue/kg)
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b&k)fluoranthene
Benzo(R,h,i)perylene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
lndeno( 1 23-cd)pyrene
Naphthalene
Phenanthrene
Pvrene
No. of
Detects
2
2
1
1
1
3
1
1
2
2
1
1
2
2
1
1
1
3
3
3
2
1
2
2
1
3
1
3
. No. of Samples
Analyzed
2
2
8
2
6
8
6
8
8
2
8
2
2
7
7
7
7
7
5
7
7
7
7
7
7
7
7
7
Range of Concentrations
Detected
13-43
61 - 200
280-280
6-6
230 - 230
5-410
1000- 1000
17- 17
2- 18
30 - 300
2600 - 2600
970 - 970
6500 - 6700
2400 - 2900
1000- 1000
2000 - 2000
13,000- 13,000
6000- 12,000
7300 - 62,000
5400- 16,000
21,000-29000
18,000- 18,000
2600 - 6300
640 - 4200
20,000 - 20,000
4200 - 24,000
7700 - 7700
3000- 15.000
-------
Table MP-3
MAIN PLANT
Sewer Sample Results
Parameter
Group: PCBs (ug/kg)
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
Group: Pesticides (ug/kg)
4,4'-DDE
4,4'-DDT
Aldrin
alpha-BHC
Endrin
Group: Inorganics (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
No. of
Detects
2
2
1
1
2
1
2
2
2
2
2
9
9
2
8
2
8
2
9
2
9
2
2
2
9
2
2
2
2
No. of Samples
Analyzed
7
7
7
7
2
2
2
2
2
2
2
9
9
2
9
2
9
2
9
2
9
2
2
2
9
2
2
2
2
Range of Concentrations
Detected
2100-25.000
11,000-25,000
25,000 - 25,000
25,000 - 25,000
36-53
16- 16
20-22
21-30
49-61
6660 - 7520
32.1 -33.3
7.3 - 220
53 - 800
.66 - .68
5-53.1
42,900 - 46,500
22 - 704
12.6- 14.8
55- 1330
123,000- 129,000
6.1 -8800
11.700- 12,700
4250 - 5280
.22 - .33
22 - 480
865-916
4.7 - 5.7
2.5-2.5
383-755
-------
Table MP-3
MAIN PLANT
Sewer Sample Results
Parameter
Thallium
Vanadium
Zinc
Miscellaneous (%)
Percent Solids
No. of
Detects
2
2
9
7
No. of Samples
Analyzed
2
2
9
7
Range of Concentrations
Detected
6.7-7.1
48.8 - 54
72-510,000
60-82.1
-------
Table MP-4ss
MAIN PLANT
Soil Borings (Surface) Sample Results
Parameter
Group: VOCs (ug/kg)
1,1-Dichloroethene
2-Butanone
Acetone
Carbon Disulfide
Ethyl benzene
m&p-Xylene
Methylene Chloride
Xylene
Tetrach loroethene
Toluene
Total Xylenes
Trichloroethene
Group: SVOCs (ug/kg)
bis(2-Ethylhexyl)phthalate
Butylbenzylphthalate
di-n-Butylphthalate
Diethylphthalate
2,4-Dimethylphenol
2-Methylnaphthalene
Group: PAHs (ng/kg)
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b&k)fluoranthene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Carbazole
Chrysene
No. of
Detects
1
1
8
1
2
1
18
3
5
8
1
3
3
2
4
1
1
4
3
1
7
10
12
4
9
6
6
3
12
No. of Samples
Analyzed
47
12
12
12
47
35
47
35
47
47
12
47
9
9
9
9
9
9
44
44
44
44
44
35
9
44
9
9
44
Range of Concentrations
Detected
330-330
8-8
7-76
7-7
3-8.1
16-16
1-39
18-26
4- 1600
3-76
26-26
9.6 - 5600
96- 180
20- 120
22-55
71 -71
62-62
28 - 260
28 - 260
45 - 45
88-2100
23 - 16,000
21 -8800
8800- 15,000
34- 1600
38 - 4000
24- 1100
21 - 130
27 - 30,000
-------
Table MP-4ss
MAIN PLANT
Soil Borings (Surface) Sample Results
Parameter
Dibenzo(a,h)anthracene
dibenzofuran
Fluoranthene
Fluorene
Indeno( 1 23-cd)pyrene
Naphthalene
Phenanthrene
Pyrene
Group: PCBs (ue/ke)
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
No. of
Detects
5
3
12
6
7
4
10
13
4
11
4
1
No. of Samples
Analyzed
44
9
44
44
44
44
44
44
47
47
47
47
Range of Concentrations
Detected
150-20,000
56 - 220
29 - 8000
35 - 2300
31 -21,000
21 -310
21 -4000
33-16,000
600 - 30,000
110-30,000
49 - 30,000
300 - 30,000
Group: Pesticides (us/kg)
4.4--DDD
4,4'-DDE
4,4'-DDT
Aldrin
alpha-Chlordane
beta-BHC
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin Aldehyde
Endrin Ketone
gamma-BHC (Lindane)
Heptachlor
Heptachlor
Methoxvchlor
1
4
2
2
4
2
1
1
2
1
1
1
1
3
3
1
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
9.4 - 9.4
5.5 - 280
3.8- 18
3.9- 1000
3.4-320
2.4 - 360
170- 170
2-2
7.7-8
2.7-2.7
7.5 - 7.5
15- 15
190- 190
8.8 - 280
8.8 - 280
21 -21
Group: Inorganics (mg/kg)
Aluminum
10
10
4880 - 9920
-------
Table MP-4ss
MAIN PLANT
Soil Borings (Surface) Sample Results
Parameter
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Group: Miscellaneous (%)
Percent Solids
No. of
Detects
5 .
44
46
10
40
10
46
10
46
10
44
10
10
7
46
9
9
5
9
5
10
46
36
No. of Samples
Analyzed
10
46
46
10
46
10
46
10
46
10
46
10
10
10
46
10
10
10
10
10
10
46
36
Range of Concentrations
Detected
2.6-37.1
5.4 - 89
18-580
.34- 1.8
.82 - 83
21,700- 111,000
6.3 - 2800
4.5- 12.2
15- 1300
19,700-78,800
42 - 39,000
8450 - 38,900
484-12,800
.06 -.81
14-260
191 - 1380
.53-2.7
.65 - 1 1
83.2-5710
.43 - .68
19.1 - 113
42 - 92,500
79-96
-------
Table MP-4sd
MAIN PLANT
Soil Borings (Deep) Sample Results
Parameter
Group: VOCs fue/ke)
1,1-Dichloroethene
2-Butanone
Acetone
Ethylbenzene
m&p-Xylene
Methylene Chloride
Xvlene
Tetrach loroethene
Toluene
Total Xylenes
Trich loroethene
Group: SVOCs (us/kg)
bis(2-Ethylhexyl)phthalate
di-n-Butylphthalate
Diethylphthalate
Dimethylphthalate
Group: PAHs (uR/kg)
Acenaphthene
Anthracene
Benzo(a)anthracene
BenzoCa)pyrene
Benzo(b&k)f1uoranthene
Benzo(g,h,i)perylene
Chrysene
Dibenzofuran
Fluoranthene
Fluorene
Indeno( 1 23-cd)pyrene
Phenanthrene
Pyrene
No. of
Detects
2
1
4
1
1
5
2
2
1
1
1
3
3
1
1
2
1
3
2
3
1
2
1
3
2
1
4
4
No. of Samples
Analyzed
34
4
4
34
30
34
30
34
34
4
' 34
7
7
7
7
37
37
37
37
30
37
37
7
37
37
37
37
37
Range of Concentrations
Detected
2.1 - 170
6-6
15-46
7-7
17- 17
1 - 19
26 - 230
7-25
2-2
2-2
190- 190
67-93
37-54
350-350
120- 120
88 - 2700
1500- 1500
7100- 14,000
4400 - 5800
7100- 14,000
2400 - 2400
26- 11,000
22-22
67 - 4600
38 - 2000
22,000 - 22,000
40 - 4700
72 - 6300
-------
Table MP-4sd
MAIN PLANT
Soil Borings (Deep) Sample Results
Parameter
Group: PCBs (ug/kg/
Aroclor-1248
No. of
Detects
3
No. of Samples
Analyzed
34
Range of Concentrations
Detected
2700 - 9300
Group: Pesticides (ug/kg)
beta-BHC
1
4
5.3-5.3
Group: Inorganics (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
Group: Miscellaneous (%)
Percent Solids
6
1
31
36
6
16
6
36
6
33
6
28
6
6
2
36
6
4
5
4
6
36
30
6
6
36
36
6
36
6
36
6
36
6
36
6
6
6
36
6
6
6
6
6
36
30
8690- 12,400
.93 - .93
6.2 - 65
15- 170
.51 -.82
.39 - 89
3590-11,300
6.3 - 890
7.7- 12.4
1 1 - 900
17,100-26.300
7.1 -3600
2760-4910
435- 1200
.06 - .24
13- 160
613- 1590
.23- 1.4
58.3- 127
.47- 1.6
22.1-28.1
37-4100
76-95
-------
Table MP-5S
MAIN PLANT
Shallow Water-Bearing Zone
Parameter
Group: VOCs (ug/L)
1,1,1 -Trichloroethane
1,1-Dichloroethene
1 ,2-Dichloroethane
Chloroform
cis- Ij2-Dichloroethene
trans- 1^2-Dichloroethene
Trichloroethene
Vinyl Chloride
Group: SVOCs (ug/L)
bis(2-Ethylhexyl)phthalate
di-n-Butylphthalate
Group: PAHs (ue/L)
Naphthalene
Pyrene
Group: PCBs (ug/L)
Aroclor-1242
Aroclor-1248
Group: Pesticides (ug/L)
alpha-Chlordane
Group: Inorganics (mg/L)
Aluminum
Aluminum, Dissolved
Antimony, Dissolved
Arsenic
Arsenic, Dissolved
Barium
Barium. Dissolved
Cadmium
No. of
Detects
1
3
1
1
6
3
3
3
2
1
1
1
2
2
2
1
1
1
1
4
1
10
1
No. of Samples
Analyzed
9
9
9
9
9
9
9
9
3
3
12
3
6
6
3
1
10
10
1
10
1
10
. 1
Range of Concentrations
Detected
1 - 1
3-3
2000 - 2000
19- 19
1 -790
3-5
1 - 2000
46-71
2-8
2-2
1 - 1
.5 -.5
1.6-4.5
5.8 - 6.4
.081 - .09
.775 - .775
.105 -.105
.006 - .006
.013 -.013
.004 -.01 4
.169 -.169
.025 -.133
.0031 -.0031
-------
Table MP-5S
MAIN PLANT
Shallow Water-Bearing Zone
Parameter
Cadmium, Dissolved
Calcium
Calcium, Dissolved
Copper
Copper, Dissolved
Iron
Iron, Dissolved
Lead
Magnesium
Magnesium, Dissolved
Manganese
Manganese, Dissolved
Mercury
Nickel, Dissolved
Potassium, Dissolved
Sodium
Sodium, Dissolved
Vanadium, Dissolved
Zinc
Zinc, Dissolved
No. of
Detects
1
1
10
1
3
1
8
1
1
10
1
10
5
1
4
1
10
2
1
2
No. of Samples
Analyzed
10
1
10
1
10
1
10
1
1
10
1
10
10
10
10
1
10
10
1
10
Range of Concentrations
Detected
.0004 - .0004
131 - 131
87 - 229
.016 -.016
.01 -.014
10.8- 10.8
.086-7.11
.017 -.017
28-28
18-84
1.77- 1.77
.009- 1.71
.0001 - .0002
.021 - .021
6-9
75-75
19- 105
.009 -.01 2
.058 - .058
.061 - .088
Group: Miscellaneous (mg/L)
Alkalinity
Chloride
Sulfate
Total Phosphorous
1
10
1
1
1
10
1
1
310-310
48- 131
94-94
.53 - .53
-------
Table MP-5I
MAIN PLANT
Intermediate Water-Bearing Zone
Parameter
Group: VOCs (ua/U
1,1-Dichloroethene
1,2-Dichloroethene (total)
Acetone
Acrylonitrile
cis- 1 ,2-Dichloroethene
Ethylbenzene
m&p-Xylene
Methylene Chloride
o-Xylene
Styrene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
No. of
Detects
1
1
1
2
6
1
1
3
1
2
2
4
5
No. of Samples
Analyzed
7
1
7
6
6
7
6
7
6
7
6
7
7
Range of Concentrations
Detected
7-7
2000 - 2000
7-7
19-34
1 - 1900
1 - 1
4-4
1-1
1 - 1
1-1
3- 15
13-5100
1 -82
Note: Volatile organic compounds were analyzed by two different laboratories, CLP and FASP. The CLP laboratory reported total 1,2-
dichloroethene and FASP reported the individual 1,2-dichloroethene isomers Thus, both the total individual isomcrs were reported in this list
Group: SVOCs (ug/L)
Hexachlorobutadiene
Group: Inorganics (mg/L)
Arsenic, Dissolved
Barium, Dissolved
Calcium, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Nickel, Dissolved
Potassium, Dissolved
Sodium, Dissolved
Zinc, Dissolved
1
2
6
6
6
6
6
1
3
6
3
6
6
6
6
6
6
6
6
6
6
6
1-1
.003 - .003
.034 - .087
100- 174
.387 - 2.74
3 1 - 43
.013 -.23
.032 - .032
5-14
21 -53
.05 - .622
-------
Table MP-5I
MAIN PLANT
Intermediate Water-Bearing Zone
Parameter
No. of
Detects
No. of Samples
Analyzed
Range of Concentrations
Detected
Group: Miscellaneous (mg/L)
Chloride
Group: VOCs (ug/L)
1,1-Dichloroethene
Acrylonitrile
cis- 1 ,2-DichIoroethene
Methylene Chloride
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Group: Inorganics (mg/L)
Chloride
Barium, Dissolved
Calcium, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Potassium, Dissolved
Sodium, Dissolved
6
1
2
2
1
1
1
1
2
2
2
2 •
2
2
2
2
6
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
35-184
2-2
10-11
1 -700
1 - 1
3-3
5-5
330-330
59- 139
.058 -.141
96- 167
.155 -.903
39-62
.01 4 -.025
11-16
42-47
-------
Table MP-6
MAIN PLANT
Residential Sample Results
Parameter
Group: SVOCs (ue/kn)
2-Methylnaphthalene
Group: PAHs (ug/kg)
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b&k)fluoranthene
Benzo(b)fluoranthene
Benzo(g,h, i )pery lene
Benzo(k)fluoranthene
Butylbenzylphthalate
Carbazole
Chrysene
di-n-Octylphthalate
Dibenzo(a,h)anthracene
Diethylphthalate
Fluoranthene
lndeno( 1 23-cd)pyrene
Phenanthrene
Pyrene
Group: PCBs (ue/ke)
ArocIor-1254
No. of
Detects
4
2
6
6
2
6
6
6
2
1
5
1
1
5
8
7
6
8
3
No. of Samples
Analyzed
6
36
36
36
30
6
36
6
6
6
36
6
36
6
36
36
36
36
36
Range of Concentrations
Detected
27 - 400
22-37
36- 11,000
39- 1400
4500 - 4800
61 - 200
58 - 4300
45 - 220
23-28
74 - 74
57-250
410-410
16,000- 16,000
20-32
58 - 2200
31 - 16,000
29-210
50 - 2600
120- 1100
Group: Pesticides (ujj/ke)
4,4'-DDE
4,4'-DDT
Aldrin
Endrin
Endrin Ketone
gamma-Chlordane
Heotachlor Eooxide
2
5
5
2
3
2
3
6
6
6
6
6
6
6
3.6-3.7
2.5 - 25
1.2-2.3
4-4.4
1.9-3.3
2.6-3
.94- 1.6
-------
Table MP-6
MAIN PLANT
Residential Sample Results
Parameter
No. of
Detects
No. of Samples
Analyzed
Range of Concentrations
Detected
Group: Inorganics (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
6
4
37
37
6
28
6
37
6
33
6
35
6
6
6
37
6
1
4
3
6
37
6
6
37
37
6
37
6
37
6
37
6
37
6
6
6
37
6
6
6
6
6
37
3250- 10,600
.81 -2.6
7.1 -86
10-550
.47 - .68
2-73
2220- 105.000
7-110
6.2- 13.9
20 - 2630
17.500-25.000
50- 1500
2340 - 39.200
428-1550
.14-.37
7-69
1270- 1720
1.2-1.2
.55 - 2.8
85.1 - 109
15.6-26.9
21 -6700
Group: Miscellaneous (%)
Percent Solids
31
31
68.1 -96.7
-------
Table SP-1
SLAG PROCESSING AREA
Surface Soil Sample Results
Parameter
Group: VOCs (wg/kg)
Methylene Chloride
Group: SVOCs (ue/kg)
4-Choro-3-methylphenol
1 ,2,4-Trichlorobenzene
2-Methylnaphthalene
di-n-Butylphthalate
Diethylphthalate
Group: PAHs (ue/kg)
Acenaphthene
Anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)xperylene
Benzo(k)fluoranthene
Chrysene
Fluoranthene
ldeno( 1 ,2,3-cd)pyrene
Phenanthrene
Pyrene
Group: PCBs fug/kg)
Aroclor-1242
Aroclor-1254
Group: Pesticides (tig/kg)
4,4'-DDE
Alpha-Chlordane
Heptachior Epoxide
Methoxvchlor
No. of
Detects
10
1
1
1
1
2 .
2
1
3
3
2
3
3
3
2
2
2
2
3
1
1
3
1
No. of Samples
Analyzed
>
14
3
3
3
3
3
14
14
14
3
14
3
14
14
14
14
14
14
14
3
3
3
3
Range of Concentrations
Detected
27- 100
12- 12
2-2
5-5
16- 16
4- 17
1 -7
4-4
4- 18
7-25
10- 11
2-8
8-28
11 -41
7-8
29-34
30-42
160-210
12-72
1.5- 1.5
0.76 - 0.76
0.74-5.1
2-2
-------
Table SP-1
SLAG PROCESSING AREA
Surface Soil Sample Results
Parameter
Group: Inorganics (.ng/L)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
No. of
Detects
3
3
14
14
3
14
3
14
3
14
3
14
3
3
3
14
1
2
3
3
3
14
No. of Samples
Analyzed
3
3
14
14
3
14
3
14
3
14
3
14
3
3
3
14
3
3
3
3
3
14
Range of Concentrations
Detected
16,800-20,900
8.9 - 20.4
6- 140
290 - 660
0.55 - 0.46
5.2 - 73
137,000-206,000
2770 - 4700
6.9- 17.8
86-647
176,000-338,000
160-6800
32.400-41,100
22,000 - 37,000
0.24 - 0.32
33 - 328
135- 135
0.45 - 0.73
2.2-6.6
295 - 423
179-234
473 - 67,000
Group: Miscellaneous (%)
Percent Solids
11
11
91.3-96.8
-------
Table SP-2S
SLAG PROCESSING AREA
Shallow Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L)
cis- 1 ,2-Dichloroethene
Group: Inorganics (mg/L)
Arsenic, Dissolved
Barium, Dissolved
Calcium, Dissolved
Cobalt, Dissolved
Copper, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Mercury
Sodium, Dissolved
Vanadium, Dissolved
No. of Detects
2
2
2
2
2
2
2
2
2
1
2
1
No. of Samples
Analyzed
2
2
2
2
2
2
2
2
2
2
2
2
Range of Concentrations
Detected
1 - 1
.004 - .005
.084 - .097
108-115
.007 - .007
.006 - .008
.701 - .767
30-32
.981 - 1.05
.0001 -.0001
57-61
.009 - .009
Group: Miscellaneous (mg/L)
Chloride
1
2
24-24
-------
Table SP-2I
SLAG PROCESSING AREA
Intermediate Water-Bearing Zone Sample Results
Parameter
Group: VOCs (ug/L)
1,1-Dichloroethane
1 , 1 -Dichloroethene
cis- 1 ,2-dichloroethene
m&p-Xylene
trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
No. of Detects
2
1
3
1
2
2
3
No. of Samples
Analyzed
3
3
3
3
3
3
3
Range of
Concentrations
Detected
2-4
2-2
76 -800
1 - 1
1 -3
110- 140
8-34
Group: Inorganics (mg/L)
Arsenic, Dissolved
Barium, Dissolved
Calcium, Dissolved
Cobalt, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Nickel, Dissolved
Potassium, Dissolved
Sodium, Dissolved
3
3
3
2
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
.003 - .004
.04 - .083
137- 166
.019 -.019
1.74-2.19
36-47
.139 -.38
.052 - .056
6- 14
53-83
Group: Miscellaneous (mg/L)
Chloride
3
3
110- 115
-------
Table SP-2L
SLAG PROCESSING AREA
Lower Water-Bearing Zone Sample Results
Parameter
No. of Detects
No. of Samples
Analyzed
Range of
Concentrations
Detected
Group: VOCs (ug/L)
1 , 1 -Dichloroethane
Aery Ion itrile
cis- 1 ,2-Dichloroethene
1
1
1
1
1
1
1 - 1
150- 150
2-2
Group: Inorganics (mg/L)
Barium, Dissolved
Calcium, Dissolved
Iron, Dissolved
Magnesium, Dissolved
Manganese, Dissolved
Potassium, Dissolved
Sodium, Dissolved
.062 - .062
102- 102
.525 - .525
35-35
.026 - .026
6-6
38-38
Group: Miscellaneous (%)
Chloride
1
1
59 - 59
-------
APPENDIX E
Responsiveness Summary
-------
RESPONSIVENESS SUMMARY
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY, INDIANA
PURPOSE
This responsiveness summary has been prepared to meet the requirements of Sections 13(k)(2)(B)(iv) and
117(b) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1986
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), which
requires the Indiana Department of Environmental Management (IDEM) to respond to each of the
significant comments, criticisms, and data submitted in written and oral presentations on the proposed plan
for remedial action. The responsiveness summary provides a summary of citizens' comments and concerns
identified and received durin? the public comment period, and IDEM responses to those comments and
concerns. All comments received by IDEM during the public comment period were considered in the
selection of the remedial alternatives for the six operable units of the Continental Steel Corporation
Superfund Site. The responsiveness summary serves two purposes: it summarizes community preferences
and concerns regarding the remedial alternatives, and it shows members of the community how their
comments were incorporated into the decision-making process.
This document summarizes written and oral comments received during the Proposed Plan Summary public
comment period of February 25 to March 24, 1998 and the extended public comment period of April 20 to
May 19, 1998 due to the later release of the Administrative Proposed Plan. Some of the comments have
been paraphrased to efficiently present them in this document. The Proposed Plan public meeting was
held from 7:00-9:00 p.m. on Thursday, March 5, 1998 in the Ralph W. Neal Council Chambers of the
Kokomo City Hall, Kokomo, Howard County, Indiana. A full transcript of the public meeting, as well as
all site related documents, are available at the Information Repository, located in the Reference Section at
the Kokomo/Howard County Public Library, 220 North Union Street, Kokomo, Indiana. Comments and
questions were received during the public meeting from several residents and political officials.
Additionally, comments were received through conventional and electronic mail and orally through a
special toll-free voice-mail system by IDEM.
OVERVIEW
The proposed remedial alternatives for the six operable units associated with the Continental Steel
Superfund Site were announced to the public just prior to the beginning of the public comment period.
IDEM proposed the following alternatives for OU1-OU6:
For OU-1 (Side-Wide Groundwater), Alternative MM-5was proposed and consists of:
* Collect Intermediate and Lower Groundwater at Martin Marietta Quarry to Contain
Contaminated Groundwater within Current Boundaries
»• Dispose of Collected Groundwater Off-Site
•• Invoke Technical Impracticability (TI) Waiver for the Intermediate and Lower
Groundwater due to no active treatment and over 200 years to attain ARARs through
Natural Attenuation
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Responsiveness Summary Continental Steel Superfund Site
Record Of Decision Page 2 of
> Collect Shallow Groundwater and Dispose Off-site at City Wastewater Treatment Plant
> Monitor Groundwater until ARARs are attained.
» Groundwater Use Restrictions
30-Yr. Net Present Worth Cost: $6,386,000
For OU-2 (Lagoon Area), Alternative SC-4L was proposed and consists of:
•• Excavate Contaminated Solids and Consolidate On-Site/Collect and Contain Shallow
Groundwater with Expanded Interception Trench System and Dispose Off-Site
*• RCRA Surface Impoundment
*• Deed & Groundwater Use Restrictions
30-Yr. Net Present Worth Cost: $44,746,000
For OU-3 (Wildcat & Kokomo creeks), Alternative SC-4C was proposed and consists of:
Excavate Contaminated Sediment and Consolidate On-Site
30-Yr. Net Present Worth Cost: $12,560,000
For OU-4 (Markland Avenue Quarry), Alternative SC-2.5Q was proposed and consists of:
» Excavate Contaminated Sediment from Quarry Pond
•• Backfill Quarry Pond
•• Dispose of Quarry Sediment in Lagoon Area CAMU
Cover Contaminated Solids with Common Soil and vegetate
Contain & Collect Shallow Groundwater & Dispose at WWTP
Deed & Groundwater Use Restrictions
30-Yr. Net Present Worth Cost: $11,163,000
For OU-5 (Main Plant Property), Alternative SC-3.5M was proposed and consists of:
»• Elevated VOC Solids Removal and On-Site Disposal
»• Excavate PCB Solids along Kokomo Creek and Dispose On-Site
»• Install Common Soil Cover and vegetate
*• Collect & Contain Shallow Groundwater and Dispose Off-Site
» Deed & Groundwater Use Restrictions
>• 30-Yr. Net Present Worth Cost: $7,747,000
For OU-6 (Slag Processing Area), Alternative SC-3.5S was proposed and consists of:
» Regrade Slag Piles to Level Site
> Install Protective Common Soil Cover Over Contaminated Solids and vegetate
> Deed Restrictions
* Stabilize Creek Bank
30-Yr. Net Present Worth Cost: $2,420,000
SUMMARY OF COMMENTS AND AGENCY RESPONSES
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Responsiveness Summary Continental Steel Superfund Site
Record Of Decision Page 3 of
Listed below are summaries of the public comments received from oral comments at the public meeting
and written and oral comments received during the public comment period for the Final Remedy Proposed
Plan. Six individuals provided twelve oral comments at the public meeting. A total of seventy-two (72)
written comments and one oral comment were received within the 30-day public comment period deadline.
ORAL COMMENTS RECEIVED FROM MARCH 1998 PROPOSED PLAN PUBLIC MEETING:
Comment #1:
Over the past 22 years, I've seen the Markland Avenue Quarry pond being used by water foul
increasingly over the years, from almost none to many. I don't have figures, but I know some of them
are residents and some are migratory. And if I understand the law correctly, when you drain a wetland or
fill in a wetland, you're supposed to replace it with something of equal or greater value. I disagree with
the comment that the pond has no ecological significance, because of these migratory water foul. What
will become of them? I agree that this site needs cleaned up, and it's actually worse than I realized it
was, but I wonder what will become of these birds that have been accustomed to going to this place.
Response #1:
Based upon our information from investigations of the Markland Avenue Quarry, the pond contains no
significant aquatic life. The pH of the water is at least 11.7, which alone would cause this condition to
exist. The water is also contaminated with several metals and volatile organic compounds. The water fowl
may possibly utilize the pond as a temporary resting place. However once they realize the adverse
conditions of the water they move to another local water body such as Wildcat Creek or Kokomo Creek.
According to an Indiana Department of Natural Resources - Fish & Wildlife Division Water Fowl
Biologist, due to the small size of the pond and the presence of other possible water bodies in close
proximity to the Quarry, the impact of the backfilling of the Quarry pond will result in insignificant harm
to the migratory and resident water fowl in the area. The presence of contaminants in the Quarry pond and
soil around the pond are a more significant threat to the health of the water fowl than eliminating the pond
habitat through backfilling. The presence of the pond likely serves as an attractive feature that draws water
fowl to the property and the contaminants present on the property.
You are correct in your assessment that replacement of wetlands is required in the regulations. IDEM
Superfund Section has informed the appropriate IDEM Water Division section of the selected remedial
action to backfill the quarry pond and their need to assess this action. Superfund staff is working with and
will continue to work with Water staff to investigate and determine what level of mitigation (replacement)
would be required or necessary based on regulation and the assessed conditions of the quarry pond.
Mitigation may or may not be required depending on the results of the assessment.
Comment #2:
I'm a representative of the Wildcat Guardians, a group who's worked to help clean up Wildcat Creek
throughout the watershed. I want to ask what the final construction - final reconstruction of Wildcat
Creek will be like. That's our biggest concern with this project. Going along with that, we have
concerns about the possible degradation of the scenic downstream areas of Wildcat Creek. We would
like to become involved in the planning and design aspects of the reconstruction of Wildcat Creek. We
have ideas and we'd like to have a forum to express our ideas. We want to come and offer ourselves as
advisors, and later on, as workers, if possible, to achieve a result in an area that can become a scenic
recreational area for Kokomo and Howard County.
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Responsiveness Summary Continental Steel Superfund Site
Record Of Decision Page 4 of
Response #2:
Public participation in the design of the selected remedial alternatives is encouraged. Wildcat and Kokomo
creek Remedial Design meetings will therefore be open to Wildcat Guardians. However, it may be
necessary to limit the number of individuals in attendance in order to maximize use of meeting time. It
would be helpful to identify key persons within the group to attend meetings. These key persons can be
provided the opportunity to review and comment on draft remedial design documents on the Wildcat and
Kokomo creeks.
Comment #3:
The residential yards east of the Main Plant property are being cleaned up right now. I am concerned
that dust generated from tearing down the buildings will recontaminate these residential properties.
Response #3:
Dust emission was a major concern during the design development for the Decontamination and
Demolition project. Dust control measures and several air monitoring approaches must be utilized during
demolition activities, including an independent Air Technician looking specifically for visual dust
emissions. This individual will have the authority to immediately cease all operations upon notice of
visible air emissions from the demolition activities. IDEM will also be present to oversee the
decontamination and demolition activities and will monitor for air emissions.
Comment #4:
I really thoughtfully wish that there had been more emphasis over the past ten years of using the
knowledge of people that worked at the plant and have implicit knowledge about activities and common
practices. A few have now passed on. That was a loss, but there are still some individuals still around,
like me.
Response #4:
During the Remedial Investigation, many plant employees were interviewed by IDEM and its contractor.
The information gathered from these interviews helped to guide or expand investigation activities to
discover those areas identified as problem areas. As we move into remedial design for the selected
alternatives, any information that can be obtained from ex-employees of the Continental Steel Corporation
that will aid in development of remedial design documents will be welcomed.
Comment #5:
I have mentioned the old stockyard area before. Everybody needs to understand the extent that many
materials were brought to the plant for scrap steel from all over the Midwest. These materials were
loaded by scrap dealers, mostly to increase weight, with oils, contaminant oils, solvents, etc. from
machine shops. The scrap included cars and anything, including the kitchen sink and railroad engines.
All these materials were stored on the ground surface in this area known as the stockyard. At one point
in time, the stockyard caught fire, and men were almost killed from an almost unseen fire taking place
underground. I have reservations on whether we want to cover that stuff up or not, and then allow our
kids to walk on it or people to build on it.
Response #5:
Presently the Main Plant property is deed restricted to commercial/industrial use only. This restriction
alone does not eliminate exposure threats associated with the contamination and past conditions that
occurred in the area of the stockyard. However, the focused remedial investigation on the Main Plant
property investigated the presence of the contaminants suggested and in the area indicated by former
-------
Responsiveness Summao' Continental Steel Superfund Site
Record Of Decision Page 5 of
employees as the stockyard. The remedial investigation verified the existence of the contamination. The
selected remedial alternative deals with it by removing and disposing of the areas with the highest levels of
contamination which were identified as posing the highest risk to human health and the environment.
After removal of these areas, the entire site will be covered with 24-inches of clean common soil and
vegetated per EPA guidance to minimize or eliminate human health exposure to remaining contaminants.
Comment #6:
West of Dixon Road, I really don't understand that whole proposition over there, because before the end
of the mill, the quarry site up on Markland Avenue and the quarry site west (Dixon Road
Quarry/Landfill) — Martin Marietta -- west of Dixon Road became prime disposal areas. I noticed
recently that somebody brought in a bunch of dirt with a bulldozer and very carefully covered up that
whole thing — and probably with permit, as I'm told just a few minutes ago ~ and there was some
proposition that they were going to keep that quarry dry for 200 years. Well, let me simply say that we
won't. Why don't we just use that, then; just throw all of this debris into that quarry and keep it dry for
200 years? Because if it's already there, the unknown, when it does get wet, it will start leaching.
Response #6:
The Dixon Road Quarry/Landfill property was purchased by Mohr Construction, who entered it into the
Voluntary Remediation Program of IDEM to address the presence of contamination on the property.
IDEM provided technical support, document review and comment, and guidance on properly addressing
this contamination. A final action has been completed and approved by IDEM. Mohr Construction has
been presented with a Certificate Of Completion from IDEM Commissioner, John Hamilton, and a
Covenant Not To Sue by Governor Frank O'Bannon.
The Markland Avenue Quarry was investigated to identify the contaminants of potential concern and
develop the baseline risk assessment which analyzes the human health exposure threats posed by those
contaminants. The proposed action is to remove the most concentrated contaminants, fill the quarry pond
with acceptable materials, and place two feet of clean soil cover and vegetation over the entire area. The
final remedy for the Quarry minimizes the threats for these contaminants and treats the groundwater.
Comment #7:
Let's go to the slag. Either slag is a true bad animal, or it's not. We're spending a lot of money ~
thinking of spending a lot of money — cleaning up the area there by the underpass. What are you going
to do about the site over there where the jail's built, and thousands of other sites around, where we hauled
it, by the State Highway Department, by private citizens who today have it in their driveways around this
town? They should at least be warned to get it up and get it out of there, or that it's running by their door.
Response #7:
Based upon information from the risk assessment, cancer risks at the Slag Processing Area exceed the
U.S. EPA's acceptable risk range of lO^to 10"* (U.S. EPA 1990). That means the highest estimated risk
probability is 2 excess cancers in 10,000 people for future onsite residents. Future onsite residents
simply means that the property would not be required to have property access restrictions such as a
security fence. Cancer risk is due mainly to the presence of cadmium. Noncancer risks exceed the U.S.
EPA's acceptable hazard index (HI) for future onsite residents and construction workers. The noncancer
risks are due mainly to the presence of arsenic. These results would indicate that slag could be a material
that produces adverse health affects. The ultimate use of the slag removed from the CSSS would dictate
the potential exposure threat posed by the material. If the material were covered with asphalt, concrete,
or 24 inches of clean soil, the exposure threat would be minimal, since these are effective measures for
-------
Responsiveness Summary Continental Steel Superfund Site
Record Of Decision Page 6 of
minimizing or eliminating exposure to the material. Those materials that remain exposed for direct
contact could pose a human health threat based upon the figures from the risk assessment. CSSS has
been a well-publicized superfurid site in Kokomo, Howarc County and in the State of Indiana. The
health risks associated with the site have been identified and presented to the public in many different
ways. The public has been made aware of the potential exposure threats from the site.
Comment #8:
Let's take a look at the Markland Quarry itself, and again, I say, it was toward the end of the thing when
they were burying stuff over there. I don't know what all they put there. There are people alive who
know what they put there. Why don't you ask them?
Response #8:
Many former employees have been interviewed and many of the materials disposed from the CSSS have
been identified, including the locations where they were disposed. This information was utilized when the
remedial investigation work plans were developed. These areas were investigated during field
implementation of the remedial investigation.
Comment #9:
Part of the contamination in the stream — of course, it's dry right now, but it's still like a mountain on the
south end of the creek down there. I'm not even sure about the pond water in the lagoons that we're
spending so much on. No doubt they tested proper.
I wonder if you know how many wells there are around that site, so you can really test. And have they
been tested regularly over these past ten years, so you can see what the improvements or worsening of
that site are? And are there not other wells within that building structure (treatment buildings)? A few
wells exist that you don't know are there, which you could be utilizing today.
Response #9:
The selected remedy for the Lagoon Area would pump out the contaminated water from the lagoons
(ponds) and send them to the Kokomo wastewater treatment plant (WWTP) for treatment and disposal.
The cost of the lagoons is expensive due to the construction of a RCRA impoundment of approximately
J27.9M. There are 13 monitoring wells within the Lagoon Area property. The wells were tested several
times during the Remedial Investigation (RJ), but have not been tested since 1995. The well sampling
results from the RI showed contaminant levels above drinking water standards migrating in a westerly
direction. Surface water sampling results indicate that shallow groundwater contaminants are not being
transmitted from groundwater to surface water anywhere along the Wildcat or Kokomo creeks. Also, the
selected remedy includes a shallow groundwater extraction system to contain and treat the groundwater
under the Lagoon Area property.
Comment #10:
My concern is children entering the OU-5, or the Main Plant area. I believe there should be routine
fencing performed until the areas are considered residential.
Response #10:
The fence has been regularly inspected and repairs made as necessary. However, the fence is frequently
damaged by trespassers, both children and adults. The likely solution to trespasser problems may be the
implementation of the Interim Record of Decision for Decontamination and Demolition of the Main Plant
structures and buildings. Once this action is completed, the removal of most of the treasures, play areas,
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Responsiveness Summary Continental Steel Superfund Site
Record Of Decision Page 7 of
and profitable items should minimize trespassing. During the D&D action, continuous site security
measures should also minimize or prevent site entry by trespassers.
Comment #11:
My name is Karen Burkhardt. As a 20-year resident of Kokomo, I am now the new District 30
Representative to Indianapolis, and I am definitely in a listening and learning mode here. I thank all of
the people who have come before me and have put so much time and effort and research into bringing us
to this point, so I have much to leam, but I am conr 'itted to taking the concerns that I hear tonight to the
(IDEM) Commissioner, John Hamilton, and to Indianapolis to make a difference and make sure that this
does happen for Kokomo, and happens in a very healthy, safe manner, because in listening to all of the
contaminants and kinds of things that could possibly happen, we need to proceed cautiously, but we need
to proceed. To procrastinate any longer does not make it any easier or any better for the citizens of
Kokomo. Thank you.
Response #11:
Thank you Ms. Burkhardt for your comments indicating your support of the final remedy and your
commitment to express your support and stress timely action to the decision-makers. This Final Decision
has been proposed in order to remove the public health threat posed by the entire site. Contamination
remaining onsite after the interim action will be addressed by the final remedial action.
Comment #12:
My name is Jim Troubaugh (Mayor and resident of Kokomo): I live at 428 South Western Avenue,
which is about two blocks from Continental Steel. I am in complete agreement, and I want to go down
on record as being in complete agreement, with the remedial alternative that has been proposed here
tonight, the cleanup of Continental Steel. Thank you.
Response #12:
Thank you Mayor Troubaugh for your comments supporting the selected remedy.
WRITTEN COMMENTS RECEIVED DURING PROPOSED -PLAN PUBLIC COMMENT PERIOD:
Comment #13:
Some consideration should be given to testing the former employees for lead and other contaminants, i.e.,
asbestos, associated with the plant operations. Lead exposure appears to be of greatest concern with
the sites associated with Continental Steel. Has the Indiana Department of Health (ISDH) done lead
testing on former employees of Continental? This population is still in Kokomo and available for testing.
The lead removal for the residential areas, which is planned for the 3 to 4 months, should make sure lead
exposure is limited in the current population.
Response #13:
Lead or any other chemical exposure in the work place is typically within Occupational Safety & Health
Agency (OSHA) jurisdiction. This matter has been referred to the ISDH and the following information
obtained. Lead testing has been performed in the past by the State and local health departments. Former
employees may also request blood lead screening from their family physicians. Since the plant closed over
12 years ago, lead exposures received by former employees at that time would no longer be present in the
body at this time due to natural removal and assimilation processes in the human body. Also, positive
blood lead results at this time would be difficult to link to the plant after this length of time.
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Responsiveness Summary Continental Steel Superfund Site
Record Of Decision Page 8 of
Comment #14:
What are the components of the Operation & Maintenance (O&M) costs for the annual O&M for the
various operable units? These proposals show about $700,000 in annual O&M costs. Are there ways to
reduce these O&M costs?
Response #14:
O&M components vary depending on the remedy for the operable unit. Some standard components of
O&M are sample monitoring events (i.e., quarterly, semiannual, annual), pump and pipe replacement,
mowing, washout repairs to caps/soil covers, fence repairs, tree removals, and treatment system repairs.
The O&M costs are only estimates, yet they are based upon past experience and performance at other
superfund sites. The actual cost may be more or less. IDEM has worked hard to scrutinize and reduce the
cost of this action and will, in the future, work to minimize the O&M costs to the extent possible.
Comment #15:
Taxes will probably result in recovery of the (Main Plant) property by the local government. If so, the
likely use of the property would be as a park. I agree and hope that this will be used for this purpose.
Response #15:
The Main Plant property is currently deed restricted by the present owner as commercial/industrial use
only. All remedial alternatives, including the selected alternative, were based on this use scenario. The
Risk Assessment was also developed based on this scenario. For the property to be utilized as a park,
additional cleanup actions may have to occur in order for the deed restriction to be removed. Additional
cleanup actions would be based upon the results of a human health reassessment under a residential use
scenario.
Comment #16:
Supportive comments were received through 68 written comments from the Kokomo community. One
comment was hand written from a husband and wife stating' "We support the recommended remedial
alternatives as listed for each site location of the Continental Steel Superfund Site." The remaining 67
supportive comments were identical typed comments stating, "I support the remedial alternatives for the
Continental Steel Superfund Site as described by IDEM officials and hope that funding will be approved
by the Indiana Department of Environmental Management and United States Environmental Protection
Agency." One of these comments included a hand written comment noting their past affiliation with the
site as a former employee and having knowledge of past dumping practices for the plant.
Response #16:
Thank you for your support for funding and selection of the final remedies for the six operable units of the
Continental Steel Superfund Site.
Comment #17:
There are several beneficial uses for slag. Has there been any thought or pursuit of these uses for the slag
located on the Slag Processing Area and other parts on the site?
Response #17:
The beneficial use of all materials associated with the Continental Steel Superfund Site and cost savings
will be sought and implemented within the bounds of regulatory restrictions and requirements.
-------
APPENDIX F
Administrative Record Update Summary
-------
Continental Steel Superfund Site
Administratitive Record Index
Initial Index
April 1993
(3 pages)
-------
AUMINISTRATIVF-KECORD INDEX ^,
APKlT, 1993 CONTINENTAL STEEL SUPERFUNU SITIi -^f
KOKOMO. INDIANA ~
PC'S
21J4
DATE
1-1992
TITLE
Final Management Plan for Contin-
ental Steel Site Remedial Investi-
gation/Feasibility Study, Kokomo.IN
AUTHOR
ABB Environmental
Services, Inc.
RECIPIENT
Gabrlele Hauer,
IDEM
DOCUMENT TYPE
PLANS/STUDIES/
REPORTS
DOCUMENT NO.
1
1
-------
ADMINISTRATIVE RECORD GUIDANCE DOCUMENTS
CONTINENTAL STEEL SUPERFUND SITE
Guidance documents are available for review
at the Indiana Department of Environmental
Management's Office—Indianapolis, Indiana
TITLE
AUTHOR
DATS
Aablant Water Quality Criteria Docuaent*
later la Guidelines ard Specification! for
Preparing Quality Aaaurance project Plani
Slurry Trench Construction for Pollution
Hlgration Control
Practical Guide for Ground-Water Sampling
T«et Method* for Evaluating Solid Vaite
Pbyelcal/Chealcal Method*, Laboratory Manual,
Vol. 1A C Vol. U
Test Method* for Evaluating Solid Waite
Phyelcal/Chemlcal Method*, Field Method*, Vol.
1C
Toe RPM Prlaer, An Introductory Guide to the
Role end Reiponiibilitle* of the Superfund
Heaertial Project Manager
A CoBpeadluB of Superfund Field Operation*
Method*
Superfund Expoiure Aa*e*«awnt Manual
Coaamnlty Relation* in SuperCund, Interia
Version
CZRCLA Compliance with Other Law* Manual:
Interia Final
Guidance for Conducting Remedial
Investigation* and Feasibility Stadia* under
CERCLA (Interia Final)
Guidance on Remedial Action* for Contaminated
Ground-Water at Superfund Site*
U*er'a Guide to Contract Laboratory Prograa
US0A Contract Laboratory Program, Statement
of Work for Inorganic* Analyela
U80A contract Laboratory Program, Statement
of Work for Organic* Analysis
Riek Aaaeeement Guidance for superfnnd Volume
ZI Environmental Manual, Inter!*) Final
Interim Guidance on Administrative Record* for
Selection of CXRCLA Reaeonie Action*
Guideline* for the Prepaxatlon of Standard
Operating Procedure* (SOPS) for Field and
Laboratory Meaaureaent*
Final Standard Quality Aa*urance Project Plan
Content Docuaut
CERCXA Coapl lance with Other Lewe Manual: Part
IX. Clean Air Act and Other Envlronaantal
Statute* and State fteqnireaente
Health and Safety Audit Guideline*, SARA Title
I, Section 126
U3BVA
USBFA, gAMS-OOJ/80
UStPA, EPA/540/2-84/001
US«PA, tPA/600/2-85/104
USOA, SW-846
U3BPA, SW-046
UaZFA, EPA/5 40/C-87/OOS
OSWBt Directive 9355. 1-02
USKPA, EPA/540/P-87/001
OSVXR Directive 9355. 0-14
USXPA, EPA/540/l-aa/OOl
OSWXR Directive 9285.5-1
USKPA, EPA/340/G-86/002
OSWKR Directive 9230.0-03B
USKPA, EPA/540/C-69/006
USKPA, EPA/540/G-89/004
USXPA, EPA/540/C-8B/003
U3KEA, KPA/S40/8-89/012
USXPA, SOW Document Mo.
IUtOl.0
USOA, SOW Docrauent Mo.
outoi.o
USZPA, EPA/540/1-89/001
USXPA, OSWXR Directive
I9833.1A
U8XPA, Region V
USEPA, Contract Ho. 63-01-7331
USEPA, EPA/540/0-89/009 OSWBR
Directive 9234.1-02
USBPA, EPA/54O/C-89/010
80/
80/12/29
84/02/
85/09/
86/11
86/11
87/09/
87/12/
88/04/
88/06/
88/08/
88/10/
88/12/
88/12/
88/12/
88/12/
89/03 /
89/03/01
89/03/16
89/06/14
89/08/
89/12/
-------
ADMINISTRATIVE RECORD GUIDANCE DOCUMENTS
CONTINENTAL STEEL SUPERFUND SITE
Guidance documents are available for review
at the Indiana Department of Environmental
Management's Office—Indianapolis, Indiana
TITLE
AUTHOR
OAZB
Rlek Assessment Guidance for Supexfund VolUM
I Human Bealth Evaluation Manual (Part A),
Interim Final
National Oil and Hasardoua dubstancee
Pollution contingency Plan; rioal Rule (40 C7H
Part 300)
Guidance On Oversight of Potentially
Responsible Party Remedial Investigation* and
Feasibility studies. Final, Volume 1
Ooldaao* on Ov«riigbt of Potentially
Raeponaible Party Raaadial Inveatigationa and
P»a»lblllty Studlaa, Final, VoloM 2
Appaindleaa
knforcaoMnt Project Nanageaeat Bandbook
Conducting Reaedial Inveatlgatlon/Feaelblllty
Studies for CEXC1A Municipal Landfill Sites
Bandbook of Suggested Practices for the Design
and Installation of Ground-Water Monitoring
Wells
Bend book, Xeawdiatioa of Contaminated
Sediments
Model Quality Assurance Project Plan, Region
v, office of Superfond
Baadbook Cround-Watar, Volume II: Hethodology
USBPA, EPA/S40/1-89/002
USKPA, 7. R. /Vol. 53, Ho. 46
USOA, OSVER Directive No.
9635.1(0)
USD A, OSWBR Directive No.
9i35.1(d)
USXPA, OSWKR Directive 9837.2-
A
USIPA, EPA/540/P-91/001
US0A, EPA/600/4-89/034
USXPA, EPA/62S/6-91/026
USZPA, Region V
USXPA, EPA/625/6-90/0168
89/12/
90/01/08
91/ /
91/ /
91/01/
91/02/
91/03/
91/04/
91/OS/24
91/07/
-------
Continental Steel Superfund Site
Administratitive Record Index
UPDATE #1
November 1994
(3 pages)
-------
NOVEMBER 1994
ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
KOKOMO, HOWARD COUNTY, INDIANA
UPDATE #1
Pgs
17
3
3
12
17
13
57
DATE
1-23-94
4-14-94
8-26-94
8-15-94
10-26-93
10-26-93
May 1993 '.
TITLE
Continental Steel Site
Unilateral
Administrative Order
Amendment of the (ROD)
Dates for Continental
Steel
Letter of comments for
Site Review and Update
For Continental Steel
Site Review and Update
for Continental Steel
Proposed Bios lurry
Tests at T&E,
Continental Steel Site
Field Studies for
Biological
Characterization
Technical Memorandum
#3 RI/FS for
Continenal Steel Site
AUTHOR
US EPA
Region 5
Pat
Carrasquero
IDEM
Bernard
Schorle
USEPA
USPHS .
Edward
Opatken
USEPA
Norman
Richardson
ABB. Inc
ABB
Environmental
Services
RECIPIENT
Matthew
Gentry
Romona
Smith
USEPA
Louise
Fabinski
USPHS
Bernard
Schorle
USEPA
Subhas
Sikdar
USEPA
USEPA
IDEM
DOCUMENT TYPE
Orders
Decrees
Correspondence
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
DOC
NO
1
2
3
4
5
6
7
Page 1 of 3
-------
NOVEMBER 1994
ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
KOKOMO, HOWARD COUNTY, INDIANA
UPDATE #1
Pages
717
38
218
2
6
8
14
DATE
May 1993
May
1993
May
1993
7-12-94
10-5-93
8-26-93
4-30-93'.
TITLE
Sampling and Analysis
Plan Revision #3 for
Continental Steel
Work Plan Revision #4
for Continental Steel
RI/FS
Health and Safety Plan
for Continental Steel
Letter about the
cleanup by EPA at
Continental steel
Letter with questions
about Continental
Steel
Conference Report for
Continental Steel
Public Meeting plus
Questions/Answers for
Continental Steel
AUTHOR
ABB
Environmenta 1
Services
ABB
Environmental
Services
ABB
Environmental
Services
Clayton
Duncan Sr.
William
Muno
US EPA
ABB
Environmental
Services
IDEM
RECIPIENT.
IDEM
IDEM
IDEM
IDEM
Gayl
Catt
IDEM
General
Public
DOCUMENT
TYPE
Plans
Studies
Reports
Plans
Studies
Reports
Plans
Studies
Reports
Community
Relations
Community
Relations
Community
Relations
Community
Relations
DOC
NO
8
9
10
11
12
13
14
Page 2 of 3
-------
NOVEMBER 1994
ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
KOKOMO, HOWARD COUNTY, INDIANA
UPDATE #1
Pages
22
DATE
March
1993
TITLE
Community relations
Plan for Continental
Steel
i
AUTHOR
ABB
Environmental
Services
RECIPIENT
IDEM
DOCUMENT TYPE
Community
Relations
DOC NO
15
Page 3 of 3
-------
Continental Steel Superfund Site
Administratitive Record Index
UPDATE #2
February 1996
(4 pages - index
7 pages - sampling index
4 pages - field documentation)
-------
PAGE
ADUINISTIMWK WORD INDIA
CONTINKNTAI, STM. .SUPKKFUND SITK
M1KOUO. IIOMRI) COUNTY. INDIANA
FKHKUAKY IflflG UPDATE /2
PC'S
'&
2
1
1
'I
1
1
1
IJATK
:i 1 !)r»
r, in ro
n r, %
10-1.1-95
io ig-fl5
12 7 !)ri
12 n 95
12 20-95
TITI.K
Iniliiil Scoping Merlin" focused HI/FS
Atiirndincnl Of The HOI) Dales Kor Conlinniliil Fieri
lfrt|iirs! l-'or KA/KS llnildini; nrinolilion Cnsls
Approval Of Tcrhnirnl McmoranHtim llnrkoroimd Conlnminnle level!;
(inndilional Approval Of QAPP For Focused Kcincdial
Investigation/Feasibility Study
Approvnl Of Rile Work I'liin
Approv;il Of Forusrd RI/FS "ork Plan. Ficnrr-;. And Appendices A And fl
Approval taller for Oocumcnls For The Conliwmlal .Steel Supcrfund
Silr
MITIIOR
John .1 OCi.idy. USKPA
Pnl rnrrnsijiicro. IDKM
Arthur C Cjirrraii.'IDRH
Arthur C. Garccau. IDRU
John J OC I,K|). USFIPA
lininona |{. Sniilli. USKPA
Arthur C. Carcrnn. IDKH
Homoiio |{. Smith. USKPA
RWIPIFNT
Arlhnr C. Gnrccau.
IDKU
Romona Smith.
USEPA
Mark A. Rurgesj.
Camp. Dresser &
UcKee. Inc.
Mark A. Burgess,
Camp, Dresser &
UcKcc, Inc.
Arthur C. Garceau.
IDEM
Pat Carrasqucro.
IDEM
Mark A. flurgess.
Camp, Dresser &
McKcc. Inc.
Pal Carrosquero.
IDF.U
IJOCUMKNT TYI'K
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
DOC NO.
I
2
3
4
5
G
7
B
-------
PAGE 2
ADHIINISTRATIVK RECORD INDKX
CONTINENTAL STKKI, SIH'KRFUND SITK
KOKOIIO. HOWARD COUNTY. INDIANA
KKHHUAKY I09G ' UPDATR #2
I'C'S
1
7.
2
\
1
7
7
6
DATR
i 9 nn
I :«i fin
i no nn
i :io %
2 6 96
II 2 05
8-31-95
9-22-95
TITI.K
Approval Irllrr. Dorunirnls for The Cniilinnilal Slrrl Snprrfnrid Silc
Formal H<:t|iicsl Anil Snppnrl To Demolish Iliiililiiti;:.- Al ('iniliiiriilal Slrrl
Siiprrlund Silc
formal Request And Support To Demolish Huildinqs Al rniilinrnl.il Slrrl
Supcrliind Silc
Approval l.cllcr Of Tin* (JAI'I1 Kor The (loiiliiiciiliil Slccl Supcrfiiiid Silr
Approval Of Phasr II Qiinlily Assiiranrr Projrcl I'lnn
Continental Slccl/Supcrfund Silc Vlsil/Urrliii" (fl/l()/!),r))
Conlincnlal Sleel Redevelopment Meeting (Chicago fl/31/95)
IDEU Conlincnlal Sled Supcrfund Sile Rl/fS Hnrkground Conlaminanl
Irvcl-?
AUTHOR
Arthur C. Carrrait. IDRU
Jiiincs K. Tioli.iucli.
Mayor of Kokoino
Dave (I'riffcv, Howard
Con nly Conuiiksioncr
Komoiia l{ Smilli. HSK'I'A
Arlhiir C Cnrccnu. IDRH
llcnlhcr Johnson.
Congressman Steve
Buyer1 Office
John O'Crady. USEPA
Hark A. Duress. P.C.
RECIPIENT
llork A. nnrgess,
Camp. Dresser &
Urkrr. Inc.
Kiilhy I'rosscr.
Coiiiniissiontr
IDKU
Kalhy Prosscr.
Commissioner.
IDEU
Cat Carrasqncro.
IDRU
Mark a. Burgess.
Camp. Dresser k
McKec. Inc.
Art Carceau. IDEU
Art Carceau. IDEU
Arl Garceau, IDEU,
John O'Grady.
USEPA
DOCUMENT TYPE
Correspondence
Corrrspondonrr
Correspondence
Correspondence
Correspondence
Memoranda
Memoranda
Memoranda
DOC NO.
9
10
II
12
13
M
15
16
-------
'•AGK
ADIIINISTIMTIU: MCORUINDKX
CONTINKNTAI. STEM, SUPKRFUND SITK
KOKOUO. HOWARD COUNTY. INDIANA
FKHKIIAHY 19% UPDATE f2
I'C'S
I!
B7
II
12
2 1 0(5
II nr)
10 20 !)!)
m-20 %
10-20-95
TITI.K
Continental Sled Trcalability Studies
Remedy Selection l^:vcl Ikiich -Scnlc Hioslnrry SI inly On Coitlnniinalcd
Soil From The Continental Slccl SupcrfuncJ Silc
Conlinenlal Slcel Snprrfiind Site Trrhniral Memorandum Huildin"
Demolition Costs
Crnvilv Dcnnlrrini; Trslini; Resulls
I'hnsp II Qimlily Assurnnee Project Plan
hn-uscd ttl/FS Work I'lan
Foeused RI/FS Work Plan Figures
Focused RI/FS Work Plan Data Summary Table.'; and Preliminary
Feasibility Sludy
AUTHOR
Kdftiird R Males. USKI'A
Douplas 1. (irossc. TSAP
Coordinnlor. USKI'A
Mark A. Unless. P R..
Camp. Dresser A McKce.
Ine.
Mark A. (targets. P .11.
Camp. Dresser k McKec.
Inc.
Camp. Dresser ft Mr.Kec.
Inr
Camp. Drrssrr f. M«-Kee.
Inc.
Camp. Dresser ft lleKec.
Inr.
Camp. Dresser * Mekcc.
Ine.
RRCII'IKNT
Art Garceau. IDL'U
llernard Schorle.
USEPA
Arthur C. Garceau.
IDEM
Mr. Ed Bales.
USEPA
IDRM
IDKU
IDRU
IDEU
DOCUMENT TYPE
Memoranda
Plans/ Studies
/ Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
DOC NO.
17
IB
19
20
21
22
23
24
-------
PAGE
(ADMINISTRATIVE RECORD INDKX
CONTINENTAL STRFI. SUI'ERFUND SITK
KOKOMO. IIO&AKI) COUNTY. INDIANA
raiKlUin HIM . UPDATE |2
PC'S
W>
2M
2:1
78
2
1
1
1
IMTK
HI 20 %
Id (i %
10-95
2-96
f, M 9f>
5 17-95
f,- KI-95
fi-21-95
9-15-95
TITI.K
I'linsc II held .Sampling I'lnn
rowiswl KI/KS llciiltli And Safely I'lan
Comnuinily Illations I'lan
Interim Risk Assessment/ Feasibility Study Main Plant Buildings
Nnws Arliclr
News Release • IDKM Undertakes Invesliealion And Study At ronlincnlnl
Steel Superfund Site
News Article
Appreciation l-ellcr • Town Meeting (6/20/fl,r>)
News Release - IDEM Warns Public Not To Trespass On Continental Steel
Superfund Site In Kokomo
AI'IIIOK
(.'amp. Dresser A- Mekcc.
Ine.
(.'jimp. Dresser ft Uckcc.
Inc.
Camp. Dresser k McKce.
Inc.
Camp. Dresser k Mckee.
Ine.
ll.ff. I'cnbody. and Hoyd
Jenkins
IDEM
JcK Carroll. Kokomo
Tribune - Staff Writer
Jon R. Padfidd. Stale
Rcpresenlalivc
IDEM
RKCII'IENT
IDKM .
IDr.'M
IDRM
IDEM
Kokomo Tribune
News Media
Kokomo Tribune
Art Carceau. IDEM
News Media
DOCUMENT TYI'K
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Community
Relations
DOC NO.
25
26
27
28
29
30
31
32
33
-------
APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Off ice--Indianapolis, Indiana
PAGE 1
DATE
5-4-94
4-6-94
3-17-94
3-11-94
3-4-94
2-10-94
2-2-94
1-27-94
TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
QUALITY
ASSURANCE REPORT
PACKAGE #1581.1
QUALITY
ASSURANCE REPORT
PACKAGE #1548
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
HERITAGE
LABORATORIES
HERITAGE
LABORATORIES
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELE
HAUER
MANUELA
JOHNSON
MANUELA
JOHNSON
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE
SAMPLING
DATA
REPORT
REPORT
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
i
i
SAMPLING
DATA
-------
APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 2
DATE
1-13-94
12-27-93
12-20-93
12-13-93
12-3-93
12-9-93
12-3-93
TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
-------
APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 5
DATE
9-10-93
9-3-93
8-28-93
8-24-93
8-17-93
8-13-93
8-13-93
8-11-93
TITLE
CONTINENTAL
STEEL CORP FAS
LAB RESULTS
CONTINENTAL
STEEL CO^P
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY .
RESULTS
AUTHOR
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
-------
APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 3
DATE
11-29-93
11-15-93.
11-9-93
11-5-93
10-27-93
10-20-93
10-14-93
TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
-------
APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 4
DATE
10-12-93
10-8-93
9-29-93
9-22-93
9-15-93
9-13-93
9-10-93
TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE.
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
-------
APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Off ice--Indianapolis, Indiana
PAGE 6
DATE
8-11-93
8-10-93 .
8-6-93
8-5-93
8-4-93
7-30-93
7-28-93
TITLE
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
CONTINENTAL
STEEL CORP
LAORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
BERNARD J.
SCHORLE
BERNARD J
SCHORLE
BERNARD J
SCHORLE
RECIPIENT
GABRIELS
HAUER
GABRIZLE
HAUER
GABRIZLE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
GABRIELE
HAUER
DOC/TYPE 1
SAMPLING |
DATA |
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
SAMPLING
DATA
n
SAMPLING
DATA
I
-------
APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 7
DATE
7-27-93
TITLE
CONTINENTAL
STEEL CORP
LABORATORY
RESULTS
AUTHOR
BERNARD J
SCHORLE
RECIPIENT
GABRIELE
HAUER
DOC/TYPE
SAMPLING
RESULTS
-------
APPENDIX B-2
ADMINISTRATIVE RECORD, CONTINENTAL STEEL
FIELD DOCUMENTATIGN/DELIVERABLES
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 1
DATE
3-14-95
11-3-93
9-10-93
8-5-93
10-29-93
3-11-94
3-15-93
6-14-93
11-3-93
10-29-93
9-16-93
3-17-94
10-29-93
8-5-93
8-5-93
8-6-93
8-5-93
11-17-93
9-10-93
TITLE
OUl/TASK 3 A
OU1/TASK 3C
OU1/TASK 3C
OU1/TASK 3D
OU1/TAKS 3D
OUl/TASK 3D, 3G,
3M
OUl/TASK 3D, 3G,
3M
OUl/TASK 3F
OUl/TASK 3F
OUl/TASK 3G
OUl/TASK 3G
OUl/TASK 3H, 31.
3K
OUl/TASK 3H, 31,
3K
OUl/TASK 3H
OUl/TASK 31
OUl/TASK 3J
OU/TASK 3K
OUl/TASK 3L
OUl/TASK 3L
AUTHOR
DON WALSH
DON WALSH
DON WALSH
DON WASLK
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
DON WALSH
RECIPIENT
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
DOC/
TYPE
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
-------
APPENDIX B-2
ADMINISTRATIVE RECORD, CONTINENTAL STEEL
FIELD DOCUMENTATION/DELIVERABLES
Documents not copied, "may be reviewed at the Indiana Department
of Environmental Management's Off ice--Indianapolis, Indiana
PAGE 2
DATE
9-10-93
6-8-94
8-5-93
10-19-93
10-29-93
11-1-93
6-21-93
2-15-94
8-5-93
11-3-93
3-18-93
10-19-93
10-29-93
9-22-93
11-3-93
6-21-93
6-21-93
11-3-93
6-22-93
11-3-93
TITLE
OU1/TASK 3L
GUI/TASK 3M
OU1/TASK 3M
STEPPED DISCHRGE
TEST RESULTS
OU1/TASK 3M
OU1/TASK 14
OU1/TASK 14
OU2/TASK 3 A
OU2/TASK 3 A
OU2/TASK 3 A
OU2/TASK 33, 3F,
7B
OU2/TASK 3F
OU2/TASK 3B, 3F
OU2/TASK 3B, 3F
OU2/TASK 3C
OU2/TASK 3C
OU2/TASK 3D
002 /TASK 3D
OU2/TASK 3E
OU2/TASK 3E
AUTHOR
DON WALSH
DON WALSH
DON WALSH
K HEWITT & D
WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
RECIPIENT
G HADER
ART GARCEAU
G HAUER
B DAVIS & G
HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER & B
SCHORLE
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HADER
G HAUER
G HAUER
DOC/
TYPE
LTR
LTR
LTR
MEMO
LTR
LTR
LTR
LTR
LTR
LTR
LTR
MEMO
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
-------
APPENDIX B-2
ADMINISTRATIVE RECORD, CONTINENTAL STEEL
FIELD DOCUMENTATION/DELIVERABLES
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 3
DATE
9-28-93
3-18-94
10-29-93
8-5-93
10-29-93
6-10-94
11-1-93
8-5-93
9-28-93
11-1-93
8-6-93
8-31-93
11-1-93
11-23-93
10-18-94
9-14-94
11-22-93
6-2-94
TITLE
OU2/TASK 7B
OU3/TASK 3 A, 3B,
3C, 3D
OU3/TASK 3 A, 3C
OU3/TASK 3B, 3D
OU3/TASK 3B, 3D
OU3/TASK 3E .
OU3/TASK 3E
OU3/TASK 3E
OU3/TASK 7B
OU3/TASK 7B
OU4/TASK 3A
OU5/TASK 3C
OU5/TASK 3C
OU5/TASK 3B
ANALYTICAL
DATABASE
001, OU2, OU3
FIELD
DOCUMENTATION
OU1,2,3, TASK 3
OU1/TASK 3 A
RADIONETIVITY
VALIDATION
AUTHOR
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
D WALSH
RECIPIENT
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
A GARCEAU
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
G HAUER
A GARCEAU
A GARCEAU
G HAUER
A GARCEAU
DOC/
TYPE
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
LTR
-------
APPENDIX B-2
ADMINISTRATIVE RECORD, CONTINENTAL STEEL
FIELD DOCUMENTATION/DELIVERABLES
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
PAGE 4
DATE
2-21-94
5-20-93
TITLE
OUl/TASK 3M
AQUIFER TESTING
OU3/TASK 3 A,. 3C
INITIAL SEDIMENT
AUTHOR
K HEWITT
RECIPIENT
G HAUER
DOC/
TYPE
LTR
•
-------
Continental Steel Superfund Site
Administrative Record Index
UPDATE #3
September 1996
(9 pages - index
1 page - sampling index)
-------
PAGE I OF V
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND Silt
KOKOMO. HOWARD COl/NTY. INDIANA
SEPTEMBER 1996 UPDATE »3
PC'S
9
30
21
3
2
9
19
6
DATE
11-25-85
8-14-90
11-8-90
11-13-90
11-16-90
12-14-90
12-18-90
3-15-91
TITLE
Motion For Order To Show Cause
Order Authorizing Sate Of Real And Personal Property By Public Auction Free
And Clear Of Liens. Valid Liens To Attach To Proceeds
Second Application For Orders Confirming Auction Sales Of Real And Personal
Properly Free And Clear Of Liens, Valid Liens. If Any. To Attach To Proceeds
Order Approving Extension Of Offer For Purchase Of Real Estate (And Lease)
Notice Of Filing
Objection Of The United States On Behalf Of The Environmental Protection
Agency To Application And Second Application 1 or Orders Confirming Auction
Sales Of Real And Personal Property
Entry And Order On Application And Amended Application For Orders
Confirming Auction Sale* Of Real And Personal Property Free And Clear Of
Liens, Valid Liens. If Any. To Attach To Proceeds
Report Of Sales
AUTHOR
Henry A. Efroynison. United
States Bankruptcy Court
Richard W. VunJivicr.
United Slates Bankruptcy
Court
1 Icnry A Kfr oymson,
Attorney for N. Wayne Liter,
Trustee
Richard W. Vandivier. Judge
United Stales Bankruptcy
Court .
Dennis E. Burton, Clerk
United Slutes Bankruptcy
Court
Jeffrey L Hunter, Assistant
United Stales Attorney
Richard W. Vandivier. Judge
United Slates Bankruptcy
Court
Henry A. Efroymson, United
Slates Bankruptcy Court
RECIPIENT
Bankruptcy Trustee
Bankruptcy Trustee
Bankruptcy Trustee
Bankruptcy Trustee
Bankruptcy Trustee
Bankruptcy Trustee
Bankruptcy Trustee
Bankruptcy Trustee
DOCUMENT
TYPE
Orders/Degrees
Orders/Degrees
Orders/Degrees
Orders/Degrees
Orders/Degrees
Orders/Degrees
Orders/Degrees
Orders/Degrees
DOC NO
1
2
3
I
4
5
6
7
8
-------
PAGE 2 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SI It 1
KOKOMO. HOWARD COUNTY. INDIANA
SEPTEMBER 19% UPDATE *3
PC'S
26
4
2
7
3
12
13
DATE
1-24-91
J-2-90
5-23-90
5-20-96
6-4-96
3-14-96
9-30-88
TITLE
Second Entry And Order On Application And Amended Application For Orders
Confirming Auction Saks Of Real And Personal Property Free And Clear Of
Liens. Valid Liens. If Any, To Attach To Proceeds
Aggregation Of Quarry And Plant Areas To The Continental Steel RI/FS
Response To May 2, 1990. Letter Regarding The Aggregation Of The Quarry And
Plant
Summary Of May 10th Meeting With EPA And Associated Action Items
Response To An Inquiring Letter, Letter Of April 22. 19%
Continental Steel/Superftmd Site Kokorao. Indiana Treatability Study Program
Comparison Of Treatablllly Data With Remedial Investigation Data
In Regards To Conducting A Site Assessment
AUTHOR
Richard W. Vandivier.
Judge. United Stales
Bankruptcy Court
Reginald O Baker. IDEM
Norm Niedergang. Acting
Associate Division Director
Office Of Superfund
Camp Dresser & McKce
Inc.
Kathy Prosser.
Commissioner, IDEM
Rose Najjar. Camp Dresser
A McKee Cambridge
Roy F. Weslon. Spill
Prevention & Emergency
Response Division
RECIPIENT
Bankruptcy Trustee
Mr. Dennis Dalga.
U.S. Environmental
Protection Agency
Mr. Reginald Baker.
IDEM
Arthur C. Garceau.
IDEM
Ms. Gayl D. Can
Tom Holdsworth.
START Laboratory
Steven J. Faryan.
Deputy Project
Officer. United
States
Environmental
Protection A?£ncv
DOCUMENT
TYPE
Orders/Degrees
Correspondence
Correspondence
Correspondence
Correspondence
Memoranda
Plans/Studies/
Reports
DOC NO.
9
10
II
12
l>
14
IS
-------
PAGE 3 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEI. SUPERFUND SI 1C
KOKOMO, HOWARD COUNTY. INDIANA
SEPTEMBER 1996 OPDATE * 3
PC'S
6
10
106
17
19
4
6
DATE
3-31-89
10-13-89
11-89
3-26-90
6-90
7-19-90
9-28-90
TITLE
Continental Steels Listing In The Federal register On The National Priorities
List For Uncontrolled Hazardous Waste Sites- Final Update »5 Final Rules
In Regards To A Possible Removal Action
A Guide To Developing SupcrAmd Records Of Decision
Action Memorandum- Removal Request
Site Assessment For Continental Steel. Kokomo . Indiana
Amended Action Memorandum- Ceiling Increase Request For Removal And
Disposal
Request For A Ceiling Increase And Exemption for the $2 Million Statutory
Limit For The Continental Steel Site
AUTHOR
Federal Register . United
States Environmental
Protection Agency
Roy F. Weslon. Spill
Prevention & Emergency
Response Division
United States Environmental
Protection Agency
Rosanne M. Ellison. On-Scene
Coordinator. U. S. EPA
United Stales Environmental
Protection Agency
Rosanne M. Ellison, On-Scene
Coordinator. US. EPA
Steve Lufllg, Director
Emergency Response Division
RECIPIENT
Public
Public
Public
David A. Ullrich.
Action Associate
Division Director
Office of Superfund
Public
David A. Ullrich.
Acting Director
Waste Management
Division
Don R. Cliy.
Assistant
Administrator Office
Of Solid Waste And
Emergency
DOCUMENT
TYPE
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/ Studies/
Reports
Plans/Studies/
Reports
Plans/ Studies/
Reports
Plans/ Studies/
Reports
DOC NO
16
17
18
•
19
2°;
21
22
-------
PAGE 4 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SI 1 L > '
KOKOMO. HOWARD COUNTY. INDIANA
SEPTEMBER 1996 UPDATE #3
PC'S
3
8
8
26
2
DATE
2-6-91
11-24-92
12-11-92
6-9-93
11-23-93
TITLE
Action Memorandum • Request For A 12-Monih Exemption
Continental Steel Acid Lagoon Area Site Assessment And Sampling Results
Action Memorandum • Request For A Ceiling Increase And Approval For An
Amended Action Memorandum
In Regards To Provide Technical Support And Oversight Assistance During
Removal Action Activities
Results From The Screening Trealability Studies Conducted On Soil
AUTHOR
Rosinne M. Ellison. On-
Scene Coordinator
Emergency & Enforcement
Response liranch. U.S. EPA
Samuel F. Borries. Acting
On-Scenc Cooidinitor. U. S.
EPA
William E Muno. Acting
Director Waste Management
Division. U.S. lil'A
Karen M Spangler, Ecology
and Environmental. Inc.
Steven 1. SaffermBn.
Treatability Study
Coordinator. Regional
support Section. Technical
Support Branch. Superfund
Technology Demonstration
Division, US EPA Region V
RECIPIENT
David A. Ullrich,
Director Waslc
Management
Division
FILE
Valdas V. Adamkus,
Regional
Administrator
Ms. Pat Vogtman.
Deputy Project
Officer. Emergency
And Enforcement
Response Branch,
U.S. EPA Region V
Bernard Schorle.
Remedial Project
Manager, Region V
Wasle Management
Division
DOCUMENT
TYPE
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/ Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
DOC NO.
23
24
2)
26*
*>
27
-------
PAGE 5 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERF UNO SI 1 1:
KOKOMO. HOWARD COUNTY, INDIANA
SEPTEMBER 1996 UPDATE »3
PC'S
332
4)
II
4
83
30
DATE
3-24-94
3-24-94
12-94
2-2I-9J
7-5-96
7-17-96
TITLE
Funded Removal Letter Report
Drift On-Scene Coordinilon's Report
Soil Screening Guidance
Action Memorandum - Request For A Celling Increase And Removal Action
Results Of Ground water Trtaubillty Study
Solidiftcallon/SUbilizalion Bench-Scale Titaiibilily Studies Preformed On
Acid And Non-Acid Sludges
AUTHOR
Deb™ Pool. Region V
Technical Assistance 1 cam
Debra Poolc, Region V.
Technical Assistance Team
United States Environmental
Prolection'Agency. Office Of
Solid Waste And 1 imergency
Response
Samuel Barries. On-Scene
Coordinator. Emergency
Response Section II
Rose Najjar. Camp Dresser &
McKce, FS Manager
Science Applications
International Corporation
RECIPIENT
Sam Domes, On-
Sccne Coordinator.
ftegion V.
Emergency And
Enforcement
Response Branch
Gail Nabasny.
Deputy Project
Officer. Region V.
Emergency And
Enforcement
Response Brunch
Office Of Chemical
Safety
Vladus V. Adamkuj.
Regional
Administrator
Arthur C. Garceau,
IDEM
Tom Holds worth.
Technical Project
Monitor, U.S. El'A.
Region V and John
O'Grady. Regional
Project Manager
IIS FPA Reelnn V
DOCUMENT
TYPE
Plans/Studies/
Kcporls
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
DOC NO
28
29
30
31
32
33
-------
PAGE 6 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY. INDIANA
SEPTEMBER 1996 . UPDATE #3
PC'S
9
II
57
1
1
1
DATE
8-5-96
8-6-96
9-3-96
2-15-96
2-20-96
2-23-96
TITLE
Final Letter Report On The Potential Applicability Of Air Sparging To
Quarry Sediments
Results Of Solidification/Stabilization Trealability Study
Letter Regarding Results Of Continuing Investigation Of Possible
Radiological Hazards
Comment Period Opens On Continental Steel Site
County May Take Over Old Steel Site
Rudolph Family, Kokomo Blessed By Continental Steel
County Makes Commitment To EPA On Rusting Steel Plant
AUTHOR
Rose Najjar, Camp
Dresser & McKee
Feasibility Study Manager
Rose Najjar, Camp
Dresser A Mckee
Feasibility Study Manager
Rex J. Bowser,
Coordipator Emergency
Response/Radioactive
Materials Indoor &
Radiological Health,
Indiana State Department
Of Health
Jeff Parrott. Tribune Staff
Writer
Jeff Parroil, Tribune Staff
Writer
Mike Fletcher.
JefTParrott,
Tribune Staff Writer]
RECIPIENT
Arthur C. Garceau,
IDEM
Arthur C. Garceau,
IDEM
Arthur C. Garceau,
IDEM
Community
Community
Community
DOCUMENT
TYPE
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
Community
Relations
Community
Relations
Community
Relations
DOC NO.
34
35
36
9
37
38
39
-------
PAGE 7 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SI 1 L
KOKOMO. HOWARD COUNTY, INDIANA
SEPTEMBER 1996 UPDATE »3
PG'S
5
4
'
53
1
1
1
1
1006
DATE
2-23-96
3-12-96
3-12-96
3-14-96
3-15-96
3-25-96
3-26-96
3.21-96
3-28-96
TITLE
1986-1996 10 Yean After The Closing
Letter Regarding The Cleanup Al The Continental Steel Supcrfiind Site
Continental Questions Remain
Transcript From The Public Meeting For The Proposed Plan For Interim Cleanup
Action
Residents Support Demolishing Buildings
LETTERS To The Editor • Speak Up On Continental
LETTERS To The Editor - Get Ready For Flood Of Business
Article - Council Says Tear Down Mill
Getting Rid Of The Albatross
Public Comments Concerning The Interim Remedy Proposed Plan
AUTHOR
Tribune StafT Writers
John 1. O'Grady. Remedial
Project Manager, Superfund
Division. United Stales
Environmental Protection
Agency
William Lane. Tribune Stall
Writer
Jan Alderfer, Registered
Professional Reporter, A
Notary' Public
JeffParrotl. Tribune Stiff
Writer
Rick A. Parsons. Kokomo
Wade Kaublc. Kokomo
Steve Jackson, Tribune Staff
Writer
Arden A. Draeger,
Publisher -General Manager
John Wiles. Editor and Joe
Folllck. Opinion Editor
Public
RECIPIENT
Community
Arthur C. Garceau,
IDEM
Community
Public
Community
Community
Community
Community
Community
DOCUMF.NT
TYPE
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Community
Relations
Arthur C.
Garceau, IDEM
DOC NO
40
41
42
43
44'
45
46
47
48
-------
PAGE 8 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SI It
KOKOMO, HOWARD COUNTY. INDIANA ' '
SEPTEMBER 1996 UPDATE »3
PO'S
1
243
3
'
1
1
2
91
DATE
3-28-96
3-30-96
8-14-96
6-4-96
6-7-96
6-20-96
7-11-96
7-96
TITLE
LETTERS To Editor - IDEM Solicits Your Opinion
Public Comments Concerning The Interim Remedy Proposed Plan
NEWS RELEASE - Senators Lugar And Coils Announce EPA Funds For
Continental Steel
Continental Steel Interim Remedy Record Of Decision
Continental Steel Review
Comments On The Record Of Decision
Comments On The Record Of Decision
Interim remedy Record Of Decision And Responsiveness Summary
AUTHOR
Kalhy Prosser, Commissioner,
IDEM
Public
Valdas V. Adamkus. Regional
Administrator
Judy Kleiman,
RCRA/CERCLA Liaison
Jcancllc Murrcrn
»
Don Hcnne, Regional
Environmental Officer
Arthur C. Garceau. Project
Manager. Superftind Section,
Office Of Environmental
Response
Arthur C Garceau. Krista E.
Duncan. Partlcla E.
Camsqucro, Gregg D.
Romalne, John J. O'Grady,
Thofnjn J Krutpcf
RECIPIENT
Community '
Arthur C. Garceau
Community
John O'Grady, RPM
John O'Grady
John O'Grady,
Remedial Project
Manager. US. EPA
Region 5
Ms. Judy Kleiman.
RCKA/CI2RCLA
Liaison. U.S. EPA,
Region V
Public
DOCUMENT
TYPE
Community
Relations
Community
Relations
Community
Relations
Record Of
Decision
Record Of
Dccliion
Record Of
Decision
Record Of
Decision
Record Of
Decision
DOC NO.
49
50
51
52
53
54
p
55
56
-------
PAGE 9 OF 9
ADMINISTRATIVE RECORD INDEX
CONTINENTAL STEEL SUPERFUND SITE
KOKOMO, HOWARD COUNTY. INDIANA
SEPTEMBER 1996 UPDATE «3
PC'S
1
1
1 .
DATE
7-11-96
7-11-96
7-96
TITLE
Comments On The Record Of Decision
Comments On The Record Of Decision
Briefing Summary
AUTHOR
Arthur C. Garceau. Project
Manager, Superfund Section.
Office Of Environmental
Response
Arthur C. Garceau. Project
Manager. Superrund Section.
Office Or Environmental
Response
Arthur C. Garceau, Project
Manager. Superrund Section.
Office Of Environmental
Response
RECIPIENT
Jancttc Marrero,
Environmental
Engineer, US. EPA.
Region V
DonHenne.
j Regional
(Environmental
Officer. U.S.
'Department Of
'Interior, Office Of
Environmental
Policy And
Compliance
Public
1 '
DOCUMENT
TYPE
Record Of
Decision
Record Of
Decision
Record Of
Decision
DOC NO.
57
58
39
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APPENDIX B-2
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
Documents not copied, may be reviewed at the Indiana Department
of Environmental Management's Office--Indianapolis, Indiana
DATE
May 1,
1996
TITLE
Phase II Field
Investigation and
Sampling Program
Including :
Soil Gas
Chroma t ogr aph
002,OU4,OU5, QU6
Field Screening
OU1 , OU3 , OU4
Wipe Samples
OU5
Air Samples
OU5
Soil/Sediment
Site Backgroud
OU3 , OD4 , OD5 , OU6
Residential Areas
and Lagoon Area
Groundwater/
Surface Water
OU1,OU3,OU4,OU5
Drilling
Operation
AUTHOR
Mark A.
Burgess/ Camp
Dresser &
McKee Inc .
--
RECIPIENT
Art Garceau
r <
DOC /TYPE
Sampling
Data
.
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Continental Steel Superfund Site
Ad ministratitive Record Index
UPDATE #4
June 1997
(5 pages - index)
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ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
KOKOMO, HOWARD COUNTY, INDIANA
JUNE 1997 UPDATE #4
Pgs
1
1
4
1
2
DATE
2 14 97
2 24 97
2 26 97
3 4 97
3 21 97
TITLE
National Remedy Review
Board
Amendment Of The
Record of Decision
Dates
Remedial Investigation
Report
Aggregation Of Slag
Processing Area
Proposed Final Remedy
Selections
AUTHOR
Wendy L.
Carney, Chief
Remedial
Response
Branch #1
Pat
Carrasquero/
IDEM
Arthur C.
Garceau /
IDEM
Pat
Carrasquero/
IDEM
Carolyn S.
Kauble/ KAP
Secretary
RECIPIENT
Arthur
Garceau/
IDEM
Romona
Smith HSRL-
6J
Mark A.
Burgess,
P . E . , DEE
Bruce
Sypniewski
(HSRM-6J)
Art
Garceau/
IDEM
DOCUMENT TYPE
Correspondence
Correspondence
Correspondence
Correspondence
Correspondence
DOC
NO
1
2
3
4
5
Continental Steel Update #4: Page 1
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ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
KOKOMO, HOWARD COUNTY, INDIANA
JUNE 1997 UPDATE #4
Pgs
2
1
1
133
236
DATE
3 24 97
4 8 97
6 6 97
3 12 96
1 31 97
TITLE
Remedial Investigation
Report
Main Plant Buildings
Engineering
Evaluation/Cost
Analysis
Final Engineering
Evaluation/Cost
Assessment
Radiochemistry Lab
Worksheet
Remedial Investigation
Volume I
AUTHOR
Art Garceau/
IDEM
Arthur C.
Garceau/ IDEM
Romona R.
Smith/ USEPA
Aitnee
Vessell/
USEPA
Camp Dresser
& McKee
RECIPIENT
James E.
Trobaugh,
Mayor of
Kokomo,
Indiana
Mark A.
Burgess,
P . E . , DEE
Pat
Carrasquero
/IDEM
Arthur C.
Garceau/
IDEM
Arthur C.
Garceau/
IDEM
DOCUMENT TYPE
Correspondence
Correspondence
Correspondence
Plans/Studies/
Reports
Plans/Studies/
Reports
DOC
NO
6
7
8
9
10
Continental Steel Update 84: Page 2
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ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
KOKOMO, HOWARD COUNTY, INDIANA
JUNE 1997 UPDATE #4
Pgs
94
450
287
309
239
249
DATE
1 31 97
1 31 97
1 31 97
1 31 97
1 31 97
1 31 97
TITLE
Remedial Investigation
Volume II
Remedial Investigation
Volume III
Remedial Investigation
Volume IV
Remedial Investigation
Volume V
Remedial Investigation
Volume VI
Remedial Investigation
Volume VII
AUTHOR
Camp Dresser
& McKee
Camp Dresser
& McKee
Camp Dresser
& McKee
Camp Dresser
& McKee
Camp Dresser
& McKee
Camp Dresser
& McKee
RECIPIENT
Arthur C.
Garceau/
IDEM
Arthur C.
Garceau/
IDEM
Arthur C.
Garceau/
IDEM
Arthur C.
Garceau/
IDEM
Arthur C.
Garceau/
IDEM
Arthur C.
Garceau/
IDEM
DOCUMENT TYPE
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
Plans/Studies/
Reports
DOC
NO
11
12
13
14
15
16
Continental Steel Update #4: Page 3
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ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
. KOKOMO, HOWARD COUNTY, INDIANA
JUNE 1997 UPDATE #4
Pgs
98
10
1
2
1
DATE
4 18 97
6 5 97
9 16 96
3 19 97
4 17 97
TITLE
Main Plant Engineering
Evaluation/Cost
Analysis
Continental Steal
Health Consult
IDEM/USEPA Agree To
Conduct An Interim
Cleanup
Presentation Update
State May Seal In
Sludge At Steel Site
AUTHOR
Camp Dresser
& McKee
Dollis M.
Wright/
Indiana State
Department of
Health
Indiana
Department of
Environmental
Management
James E.
Trobaugh,
Mayor of
Kokomo
Jeff Parrott/
Tribune Staff
Writer
RECIPIENT
Arthur C.
Garceau/
IDEM
Art
Garceau/
IDEM
News
Release/
Public
Business/
Labor
Alliance
Committee
News
Article/
Public
DOCUMENT TYPE
Plans/Studies/
Reports
Plans/Studies/
Reports
Community
Relations
Community
Relations
Community
Relations
DOC
NO
17
18
19
20
21
Continental Steel Update #4: Page 4
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ADMINISTRATIVE RECORD INDEX
(CONTINENTAL STEEL) Superfund Cleanup Site
- KOKOMO, HOWARD COUNTY, INDIANA
JUNE 1997 UPDATE #4
Pgs
1
1
7
DATE
4 18 97
4 24 97
2 5 97
TITLE
National Priority List
Continental Site Has
An Owner
Applicable To Relevant
and Requirement
(ARARs)
AUTHOR
Steve Buyer /
Member of
Congress
Wade Kauble/
Kokomo
Krista
Duncan/ IDEM
RECIPIENT
National
Remedy
Review
Board
Members
News
Article/
Public
Art
Garceau/
IDEM
DOCUMENT TYPE
Community
Relations
Community
Relations
ARARS
DOC
NO
22
23
24
Continental Steel Update #4: Page 5
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