EPA Superfund
Record of Decision:
Douglas Road Landfill,
Mishawaka, IN
7/13/1995
PB95-964113
EPA/ROD/R05-95/288
February 1996
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Declaration for the Record of Decision
Douglas Road Landfill
Landfill Cap Operable Unit
Douglas Road Landfill
Mishawaka, Indiana
This decision document presents the selected remedial action for
the landfill cap operable unit at the Douglas Road Landfill Site
(the Site) in Mishawaka, Indiana. This remedial action was
selected in accordance with CERCLA, as amended by SARA, and, to
the extent practicable, the National Contingency Plan. The
selection of this remedy is based on the Administrative Record
for the Site.
The State of Indiana concurs with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to human health, welfare, or the environment.
lion of the Selected
This operable unit action is the first of two planned for this
Site. It specifically outlines an action to address on-site soil
and waste material contamination, which have been determined by
the Remedial Investigation to pose unacceptable risks to human
health and the environment.
The major components of the selected remedy include:
Installation of a Composite Barrier Cap with a GCL Soil
Barrier Layer, meeting the requirements of 329 IAC 2-14-19.
Collection and disposal of landfill gas
Perimeter ditches to collect surface water drainage
Groundwater and source area monitoring to ensure that the
goals of this action are met.
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Declaration
The selected remedy is protective of human health and the
environment, complies with Federal and State applicable or,
relevant and appropriate requirements for this operable unit
action, is .cost effective, and consistent with achieving a
permanent remedy. This operable unit action utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable for this site. However, because treatment of
the principal threats of the site was not found to be
practicable, this remedy does not satisfy the statutory
preference for treatment as a principal element. Subsequent
actions at the site will address other threats posed by
conditions at this site. Because this remedy will result in
hazardous substances remaining on-site above health based levels,
a review will be conducted to ensure that the remedy continues to
provide adequate protection of human health and the environment
within five years after commencement of this remedial action.
Because this is the first of two operable unit actions at the
site, review of this site and of this remedy will be continuing
as EPA continues to develop other remedial alternatives for this .
site.
Date / Valdas V. Adamkus
>^V—Regional Administrator
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O:
00:
WMU
' RA/RF
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We make Indiana a cleaner, healthier place to live
Evan Bayh
Governor
Kathy Prosser
Commissioner
100 North Senate Avenue
P.O. Box 6015
Indianapolis, Indiana 46206-6015
Telephone 317-232-8603
Environmental Helpline 1-800-451-6027
Mr. Valdas Adankus
Regional Administrator
United States Environmental
Protection Agency
77 West Jackson Blvd
Chicago IL 60604
Dear Mr. Adamkus:
<:M •> .'J 1995
U.b. ii.'.n, n^-oiUN V
WASTE MANAGEMENT DIVISION
OFFICE OF THE DIRECTOR
Re: Record of Decision
Operable Unit Two of
Site Remedy
Douglas Road Landfill
Mishavaka, IN
The Indiana Department of Environmental Management has
reviewed the U.S. Environmental Protection Agency's Record of
Decision for the Douglas Road Landfill Superfund site. IDEM
fully concurs with the major components of the selected remedy
for Operable Unit Two of this site which include:
Placement of a composite barrier cap with a GCL soil barrier
layer. The typical cross section for this composite barrier cap
consists of (from top to bottom): a topsoil layer, a protective
soil layer, an aggregate or sand drainage layer with a minimum
permeability of 1 x lO^ cm/s, a flexible membrane liner, a GCL
soil barrier layer having a maximum permeability of 1 x 100*
cm/s, and a bedding layer. ,,
"*-'.
/
We also agree that this action attains Federal and State
requirements that are applicable, or relevant and appropriate to
this final site remedy. Because this remedy will result in
hazardous substances remaining on site above health-based levels,
a review will be conducted within five years after commencement
of the remedial action to ensure the remedy continues to provide
adequate protection of human health and the environment.
IDEM staff have been working closely with Region V staff in
the selection of an appropriate final remedy for the Douglas Road
Landfill and are satisfied that the selected alternative for
Operable Unit Two of this site adequately addresses the risks to
human health and the environment posed by the soils.
An Equal Opportunity Employer
Printed on Recycled Paper
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Record of Decision
Page 2
Please be assured that IDEM is committed to accomplish
cleanup of all Indiana sites on the NPL and intends to fulfill
all obligations required by law to achieve that goal.
Sincerely,
Kathy Grosser
Commiss ioner
cc: Susan Bremer, IDEM
Dion Novak, US EPA
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Decision Summary
Douglas Road Landfill
Mishawaka, Indiana
Douglas Road Landfill
Mishawaka, Indiana
The Douglas Road Landfill site (The Site) is located in St.
Joseph County just north of Mishawaka, Indiana. The site is
approximately 16 acres in size and is located near the northwest
corner of Douglas and Grape Roads. The Site is bounded by the
right-of-way for the Indiana State Toll Road to the north, a
shopping center and an apartment complex to the east, residential
properties and Douglas Road to. the south, and agricultural land
to the. west (See Figure 1) .
In the early 1950s, the property was excavated and gravel onsite
was used for the construction of the interstate. Uniroyal
Plastics, Inc. (Uniroyal) leased the gravel pit and used it as a
repository for plant wastes between 1954 and 1979. From 1954 to
1971, solvents, fly ash, paper, wood stock, rubber and plastic
scrap were disposed of at the landfill. Only fly ash was
disposed of from 1971 to 1979. In December 1979, the site was
closed to avoid having to comply with impending RCRA regulations
pertaining to the operation of a landfill.
According to the information provided by Uniroyal, about 302,400
gallons of RCRA hazardous waste were disposed of at the landfill.
Liquid wastes included methyl ethyl ketone, acetone,
tetrahydrofuran, toluene, hexane, and xylene. Historical aerial
photographs of the landfill indicate several pits containing
liquid that may have been used for disposal; the largest (and
longest used) was in the central area of the landfill (See Figure
1).
The landfill was nominated for inclusion on the NPL on June 10,
1986, and placed on the NPL on March 31, 1989. In September,
1989, the State of Indiana and Uniroyal signed a consent decree,
in which Uniroyal agreed to perform a RI/FS at the site. Before
completion of this work, Uniroyal filed for bankruptcy and
discontinued work at the site (November 1991).
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Following the bankruptcy, it was determined that U.S. EPA should
regain the site lead and the RI/FS was began in early 1994, using
Superfund money. These investigations were completed in the fall
of 1994.
of
Public participation requirements under CERCLA Sections 113
(k) (2) (B) (i-v) and 117 were satisfied during the RI/FS process.
U.S. EPA has been primarily responsible for conducting the
community involvement program for this Site, with the assistance
of the Indiana Department of Environmental Management (IDEM) .
The following public participation activities, to comply with
CERCLA, were conducted during the RI/FS.
A Community Involvement Plan was developed in 1994, to
assess the community's informational needs related to the
Douglas Road Landfill site and to outline community
involvement activities to meet these needs . Residents and
community officials were interviewed and their concerns were
incorporated into this plan.
A public information repository was established at the
Mishawaka-Penn Public Library.
A mailing list of interested citizens, organizations, news
media, and elected officials in local, county, State and
Federal government was developed. Fact sheets and other
information regarding site activities were mailed
periodically to all persons or entities on this mailing
list. This mailing list has been updated on a continual
basis as more individuals have become aware of the
contaminated residential well problem.
A Fact Sheet was mailed to the public in April 1994, that
announced a public meeting to discuss the upcoming Remedial
Investigation and answer site related questions from the
public.
A public meeting on April 20, 1994, at the Walt Disney
School in Mishawaka announced the beginning of the Remedial
Investigation and provided details about its conduct.
A fact sheet was mailed to the public in September 1994,
that announced an availability session on September 28,
1994, to discuss sampling results from the Remedial
Investigation .
An Availability Session was held on September 28, 1994 at
the Walt Disney School to discuss RI progress and answer
questions from the public regarding residential well
contamination discovered during the RI.
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A fact sheet was mailed to the public in March 1995 that
announced an availability session on March 8, 1995, to
discuss the solution to the residential well contamination
problem.
An Availability Session was held on March 8, 1995, at the
Walt Disney School, to discuss the solution to the
residential well contamination problem.
A fact sheet was mailed to the public in April 1995 that
summarized EPA's recommended remedial alternative for the
landfill capping phase of the cleanup in a proposed plan for
the site. The EPA approved Feasibility Study was also
released at that time. This fact sheet announced a public
comment period for the proposed remedial action and was
accompanied by newspaper advertisements in the local
newspapers.
A Public Meeting was held on April 5, 1995, at the Walt
Disney School, to present EPA's proposed plan for the
landfill capping phase and to receive formal public comment.
c
Paid newspaper advertisements announced the meetings and
availability sessions.
A Responsiveness Summary addressing comments and questions
received during the public comment period on the RI/FS and the
Proposed Plan is included with this Record of Decision as
Appendix A.
This Record of Decision presents the selected remedial action for
the Douglas Road Landfill site in Mishawaka, Indiana, chosen in
accordance with CERCLA, as amended by SARA, and the National
Contingency Plan. The decision for this Record of Decision at
the site is based on the Administrative Record.
As~ with many Superfund sites, the problems at the Douglas Road
site are complex. A RI/FS was performed including activities to
determine the nature and extent of contamination at the site and
evaluating the feasibility of various remedial alternatives to
clean up the site. The RI/FS determined that soil and waste
materials and area groundwater had become contaminated because of
past disposal activities at the site.
This Record of Decision (ROD) addresses contaminated soil and
waste materials. These areas were determined to pose risks to
human health and the environment due to dermal contact or
incidental ingestion of site surface soils.
This is the first of three planned response actions at the site.
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Subsequent actions will be taken to provide a city water
extension to residential properties affected by site
contamination, and to address remediation of groundwater
contaminated by the site. This operable unit will be designed to
be consistent with any and all potential future cleanup actions
at the site.
Site Characteristics
The RI/FS was conducted to identify the types, quantities and
locations of contaminants at the site and to develop alternatives
that best address these contamination problems. The nature and
extent of actual or potential contamination related to .the site
was determined by a series of field investigations, including:
development of detailed information regarding
historical site operations
on-site surface soil sampling
performance of a geoprobe survey to aid in the
optimal placement of groundwater monitoring wells
installation and sampling of groundwater
monitoring wells, both on-site and off-site
identification and sampling of existing ground-
water wells in the site vicinity
preparation of a site-wide human health and
ecological risk assessment
contaminant fate and transport modeling and
analysis
Site Geology;
The Douglas Road Landfill site is underlain by unconsolidated
glacial deposits ranging from 30 to 200 feet thick. The glacial
deposits consist of sand and gravel outwash, interbedded with
clayey tills formed by the Saginaw Lobe of the Wisconsinan
glacial event. In the site area, an intermediate deposit of clay
till separates the sand and gravel outwash into upper and lower
units. This clay unit has an irregularly sloping scoured
surface, dipping northwest, with a bottom elevation ranging from
600 feet msl near the Michigan state line to 675 feet msl near
Mishawaka.
A basal clay till unit is also observed throughout the area,
directly overlying the bedrock. Soils on the landfill surface
consist of a well-drained sandy loam material, intermixed with
areas of gravel, fly ash, coal and sand.
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Site
Within the St . Joseph River bz.: . the sand and gravel outwash
deposits described above form - . Joseph aquifer system.
Recharge to the aquifer is genexc. from direct precipitation
and losses from surface water bodiet. The intermediate clay till
deposit separates the aquifer system into upper and lower zones.
South Bend and Mishawaka are the primary users of groundwater in
the county, with a combined average of 34 million gallons per day
(mgd) . Private water supplies rely exclusively on the aquifer,
with an estimated use of 3.7 mgd. Other uses, such as industrial
and agricultural, total about 2 mgd.
Groundwater at the site was detected between 15 and 20 feet below
ground surface with the intermediate clay till separating the
aquifer into upper and lower zones across much of the site.
Groundwater use in the vicinity of the site is private
residential, with the exception of a nearby nursery, which uses
groundwater for irrigation.
A sampling grid consisting of 22 sampling locations was
established along the length of the landfill. Composite
surficial soil samples were sampled for semi -volatile organics
(SVOCs) , pesticides/polychlorinated biphenols (PCBs) ,
metals/cyanide, and total organic carbon (TOO . Fourteen of the
samples were also sampled for BTU, and two of the samples that
appeared to contain flyash were analyzed for dioxin. A grab
sample for volatile organics (VOCs) , tetrahydrofuran (THF) , and
hexane analyses was collected from each sample also.
In addition to the 22 grid point sampling locations, six grab
samples were collected from areas of suspected contamination
because of currently observed stressed vegetation. These samples
were analyzed for VOCs, THF, hexane, SVOCs, pesticides /PCBs,
metals /cyanide, TOC, BTU and dioxin.
Surficial soil samples collected at the site were found to be
contaminated with volatile organics up to levels of 20,000 parts
per billion (ppb) , semi-volatiles up to levels of 160,000 ppb,
PCBs up to levels of 16,000 ppb, dioxin up to levels of 1.3 ppb,
pesticides up to levels of 68 ppb, and metals up to levels of
1920 ppb.
Tn^ nation
Groundwater samples collected at the site were found to be
contaminated with volatile organics up to levels of 15,000 ppb,
semi -volatile organics up to levels of 29 ppb, and metals up to
levels of 15 ppb.
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Groundwater samples collected from residential wells were found
to be contaminated with volatile organics up to levels of 100
ppb.
This Record of Decision is written for an operable unit action to
address the contaminated soils and waste materials at the site.
The RI report contains a Risk Assessment, prepared by CH2M Hill
using the Risk Assessment Guidance for Superfund and approved by
EPA as a portion of the RI report, that calculated the actual or
potential risks to human health and the environment that may
result from exposure to site contamination. Risks associated
with exposure to contaminated groundwater will be summarized in a
subsequent ROD to address contaminated groundwater.
The risk assessment determined that the majority of risks
associated with exposure at the site were attributed to dioxin,
PCBs, PAHs and bis (2 -ethyl hexyl) phthalate.
Actual or threatened releases of hazardous substances from this
site not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare or the environment.
.Toxicit
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day) (-1)
are multiplied by the estimated intake of a potential
carcinogen, in mg/kg-day, to provide an upper bound estimate of
the excess lifetime cancer risk associated with exposure at that
intake level. The term "upper bound" reflects the conservative
estimate of the risks calculated from the CPF. Use of this
approach makes underestimation of the actual cancer risk highly
unlikely. Cancer potency factors are derived from the results of
human epidemiological studies or chronic animal bioassays to
which animal to human extrapolation and uncertainty factors have
been applied (e.g. to account for the use of animal data to
predict effects on humans) .
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans ,• including sensitive individuals.
Estimated intakes of chemicals from environmental media (e.g. the
amount of a chemical ingested from contaminated drinking water)
can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
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factors have been applied (e.g. to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential
for adverse noncarcinogenic effects to occur.
The following hazardous substances were found to be of principal
concern at the site.
Polynuclear Aromatic Hydrocarbons Animal studies indicate that
PAHs may be potentially harmful to the gastrointestinal tract,
liver and kidneys and may suppress the immune system after both
short and long term exposure. Birth defects and decreased body
weight have been reported in laboratory animals, although
reproductive toxicity associated with PAH exposure has not been
demonstrated in humans. Lung and skin cancer in humans have been
associated with chronic exposure by inhalation and dermal
contact, respectively, to mixtures of compounds including
carcinogenic PAHs.
Arsenic Short term exposures to arsenic or arsenic compounds
may cause effects in the gastrointestinal tract, heart, vascular
system, blood, nervous system, eye, nose and skin. Arsenic
compounds are reported to act as skin allergens in humans.
Exposure to arsenic has also been reported to cause depression of
the bone marrow and disturbances in the blood cell and tissue
forming system and has been associated with kidney and liver
disorders. Arsenic has been found to be a lung carcinogen when
inhaled and to cause skin cancer when ingested. Arsenic and its
compounds may have potential reproductive and developmental
effects in humans. Teratogenic effects have been demonstrated in
animal species exposed to arsenic via oral administration or
intraperitoneal injection. Damage to genetic material has been
reported in humans.
Polychlorinated Biphenols (PCBs) The principal toxicological
effects observed in humans exposed to PCS mixtures include
effects of the skin and the liver. Results from experimental
studies in animals indicate that PCBs may also cause effects on
the thyroid gland and immune system. Liver tumors have been
observed in animals exposed to high concentrations of PCBs.
Epidemiological studies of PCB exposed populations have not
demonstrated a causal relationship between PCB exposure and any
form of human cancer. Reproductive toxicity has been reported in
animals exposed to PCBs prior to and during gestation. Adverse
developmental effects have been reported in the newborn of women
exposed during pregnancy to PCBs and other chemicals in an
occupational setting or from ingestion of contaminated fish.
Dioxin Toxic effects include liver damage, thymic atrophy,
gastric hemorrhage, testicular degeneration, weight loss,
pericardial edema, and kidney and hematological effects. Humans
exposed to dioxin by industrial accidents reported nausea,
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8
vomiting, headaches, fatigue, muscular aches and joint pains,
peripheral neuropathy, loss of libido, and irritation of eyes,
respiratory tract and skin.
Bis (2-ethyl hexyl) phthalate Chronic exposure at relatively
high concentrations have retarded growth and resulted in
increased liver and kidney weight in experimental animals. Some
evidence exists in animals of teratogenic and ferotoxic effects.
Reproductive effects, decreased fertility and testicular damage
have been noted in rodents. Phthalates are poorly absorbed
through the skin and are rapidly metabolized.
Risk Assessment
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1 x 10(-6) or 1E-6). An excess lifetime cancer risk of 1
x 10 (-6) indicates that, as a plausible upper bound, an
individual has a one in one million chance of developing cancer
as a result of site related exposure to a carcinogen over a 70
year lifetime under the specific exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
Carcinogenic risks described in the risk assessment for exposure
to contaminated surface soil at the site were computed for
several potential exposure scenarios, including residential
child, residential adult, teenage trespasser, and occupational
adult exposures. The combined pathways carcinogenic risk for
surface soil exposure at the site exceeds 1 x 10 (-6) for all
receptor groups, ranging from 2.4 x 10(-4) for adults engaged in
occupational activities to 2 x 10(-6) for a teenage trespasser.
The principal carcinogenic risk contributors are dioxin, PCBs,
PAHs, and bis (2-ethyl hexyl) phthalate (See Table 1).
The non-carcinogenic risks associated with future exposure to
contaminated surface soil at the site were computed for the same
exposure scenarios as were used for the carcinogenic risks.
Generally, total Hazard Indices (HI) are used to calculate non
carcinogenic risks and must be below a value of 1.0; otherwise
U.S. EPA policy requires remedial action. The assessment of
future non-carcinogenic risks shows a combined ingestion, dermal,
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Douglas Road (Unlroyal) Landfill
Mlshawaka, Indiana
Table 1
Summary of Rl«k«
Surface Soil
dedia
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Land Use
Current
(No Land Use)
Residential
Residential
Occupational
Receptor
Trespassing
Teenager
Child
Adult
Adult
Exposure Route
Ingestion & Inhalation
Dermal
TOTAL
Ingestion & Inhalation
Dermal
TOTAL
Ingestion & Inhalation
Dermal
TOTAL
Ingestion & Inhalation
Dermal
TOTAL
Cancer Risk
1E-06
1E46
2E-06
3E-04
1E-04
5E-04
2E-04
3EJM
5E-04
5E-05
2EJJ4
2E-04
Hazard Index
0.05
QJB
0.09
21.1
5,9
27.1
2.3
2,8
5.1
0.8
2,Q
2.8
Ma|or Chemical Contributors to Risk
Carcinogenic Risk
Dioxin
Polychlorinated blphenyls
Arsenic
Benzo[a]pyrene
Beryllium
Diben(a,h)anthracene
Bis(2-elhylhexyl)phlhalate
Benzo(b|fluoranthene
Benzo[a]anthracene
NQDCCJICJnQgfiOlSLRIjli
Dioxin
Chromium
Antimony
Arsenic .
Bis(2-ethylhexyl)phthalate
Nickel
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and inhalation hazard index ranging from 0.009 for a teenage
trespasser to 27.08 for adults in a residential setting (See
Table 1).
An ecological risk assessment determined whether the contaminants
present at the site and evaluated potential threats to ecological
receptors in the absence of any remedial actions.
The results of this assessment, as summarized in the risk
assessment portion of the RI, determined that due to exposure to
site contaminants, ecological damage from surface soil
contamination is likely in the absence of any remedial actions.
Description of Alternatives
A Focused Feasibility Study (FFS) was completed for this site
using the presumptive remedy guidance, which calls for the
analysis of a very limited number of cleanup options for the site
remediation. During the FFS, a list of alternatives was
developed that could be used to address the threats and/or
potential threats identified for the soil at the site. The list
of alternatives was screened based on criteria for effectiveness
(i.e. protection of human health and the environment,
reliability), implementability (i.e. technical feasibility,
compliance with applicable Federal and State regulations) and
relative costs (i.e.- capital, operation and maintenance) .
Following this initial screening, the list of alternatives was
evaluated and only alternatives that met the nine criteria,
listed below in the comparative analysis section, were submitted
for detailed analysis. The Hydrologic Evaluation of Landfill
Performance (HELP) model was used to evaluate the performance of
each capping alternative for inhibiting infiltration of
rainwater, which assisted with the comparison of each alternative
to the no action alternative.
Alternative 1 No Action
Under this alternative, no remediation would occur and the site
would remain in its present condition. This alternative will not
reduce any potential public health or environmental risks
currently associated with the site. This alternative will
include access and deed restrictions limiting the future use of
groundwater and surface water at the site and limiting future
site development. The inclusion of the no action alternative is
required by law to give U.S. EPA a basis for comparison.
Present Worth Cost: $200,000
Time to Implement: 2-4 weeks
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10
Alternative 2; Soil Cap
This alternative consists of placement of a soil cap, which will
be constructed to prevent direct contact with landfill contents,
to prevent volatilization and fugitive dust emissions from
surficial soil contamination, to control surface water runoff and
erosion, and to reduce infiltration into the landfill thereby
reducing potential releases into the groundwater. The typical
cross section for the soil cap consists of: (from top to bottom)
topsoil and locally available soil. In addition to the soil cap,
access restrictions will be implemented to restrict site use and
access. These restrictions will include deed restrictions to
control site development and groundwater use and fencing to
inhibit unauthorized access to the landfill property.
Present Worth Cost: $2,400,000
Time to Implement: 2 months
Alternative 3At Single Barrier Cap with Compacted Clav Soil
Barrier
This alternative consists of placement of a single barrier cap
with a compacted clay soil barrier. The typical cross section
for a single barrier cap consists of (from top to bottom) : a
topsoil layer, a protective soil layer, an aggregate or sand
drainage layer with a minimum permeability of 1 x 10 (-2) cm/s, a
compacted clay soil barrier layer with a maximum permeability of
1 x 10 (-7) cm/s, and a bedding layer. In addition to the cap,
access restrictions will be implemented to restrict site use and
access. These restrictions will include deed restrictions to
control site development and groundwater use and fencing to
inhibit unauthorized access to the landfill property.
Present Worth Cost: $5,400,000
Time to Implement: 4 months
Alternative 3B Single Barrier Cap with GCL Barrier
Th~is alternative consists of placement of a single barrier cap
with a Geosynthetic Clay Liner (GCL) barrier. The typical cross
section for a single barrier cap consists of (from top to
bottom) : a topsoil layer, a protective soil layer, an aggregate
or sand drainage layer with a minimum permeability of 1 x 10 (-2)
cm/s, a GCL barrier layer with a maximum permeability of 1 x 10 (-
8) cm/s, and a bedding layer. In addition to the cap, access
restrictions will be implemented to restrict site use and access.
These restrictions will include deed restrictions to control site
development and groundwater use and fencing to inhibit
unauthorized access to the landfill property.
Present Worth Cost: $4,500,000
Time to Implement: 3 months
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11
Alternative 4A
Soil Barrier Layer
Barrier Cap wj
This alternative consists of placement of a composite barrier cap
with a compacted clay soil barrier. The typical cross section
for a composite barrier cap consists of (from top to bottom): a
topsoil layer, a protective soil layer, ah aggregate or sand
drainage layer with a minimum permeability of 1 x 10 (-2) cm/s, a
flexible membrane liner, a compacted clay soil barrier layer with
a maximum permeability of 1 x 10 (-7) cm/s, and a bedding layer.
In addition to the cap, access restrictions will be implemented
to restrict site use and access. These restrictions will include
deed restrictions to control site development and groundwater use
and fencing to inhibit unauthorized access to the landfill
property.
Present Worth Cost:
Time to Implement:
Alternative 4B
Layer
$5,800,000
5 months
Composite Barrier Cap with a GCL Soil Barrier
This alternative consists of placement of a composite barrier cap
with a GCL soil barrier layer. The typical cross section for a
composite barrier cap consists of (from top to bottom) : a topsoil
layer, a protective soil layer, an aggregate or sand drainage
layer with a minimum permeability of 1 x 10 (-2) cm/s, a flexible
membrane liner, a GCL soil barrier layer with a maximum
permeability of 1 x 10(-8) cm/s, and a bedding layer. In
addition to the cap, access restrictions will be implemented to
restrict site use and access. These restrictions will include
deed restrictions to control site development and groundwater use
and fencing to inhibit unauthorized access to the landfill
property.
Present Worth Cost:
Time to Implement:
$4,700,000
4 months
The nine criteria used by U.S. EPA to evaluate remedial
alternatives, as set forth in the NCP, 40 CFR Part 300.430,
include: overall protection of human health and the environment;
compliance with applicable or relevant and appropriate
requirements (ARARs) ; long-term effectiveness; reduction of
toxicity, mobility, or volume; short-term effectiveness;
implementability; cost; state acceptance; and community
acceptance.
THRESHOLD CRITERIA
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12
Protect
Addresses whether a remedy provides adequate protection of human
health and the environment and describes how risks posed through
each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional
controls.
Alternative 1 would not protect hunr.n health and the environment
because it does not reduce risks associated with exposure to
contaminated media at the site. There; 7re, since it has been
determined that Alternative 1 would not be protective of human
health and the environment or meet ARARs, it will no longer be
considered in the nine criteria evaluation.
Alternatives 2, 3A, 3B, 4A, and 4B would reduce the threats to
human health and the environment by placement of a cover material
over the contaminated landfill materials.
However, Alternatives 3A, .3B, 4A, and 4B offer greater protection
than Alternative 2 because of greater protection against
potential future groundwater migration through reduction in
rainwater infiltration. Alternatives 3B and 4B offer greater
protection than Alternatives 3A and 4A due to the increased
protectiveness of the cover materials resulting in lower levels
of infiltration, which increases long term effectiveness.
Alternative 2, due to lower levels of long term effectiveness and
increased short term infiltration rates is not as effective as
the other alternatives.
Alternatives 3A, 3B, 4A, and 4B are functionally equivalent with
respect to this threshold criterion, however, Alternatives 3B and
4B are slightly more effective due to increased protectiveness of
the cover materials which translates into slightly higher levels
of long term effectiveness and permanence.
COMPLIANCE WITH ARARs
Addresses whether a remedy will meet all of the ARARs of other
Federal and State environmental laws and/or justifies a waiver of
those laws.
All of the alternatives are capable of meeting their respective
ARARs. ARARs for the landfill closure include landfill closure
cover requirements and air emissions requirements. Alternative 2
includes the installation of a. vegetated soil cap and does not meet
the Subtitle D capping ARAR, nor can a waiver of these requirements
be justified. Alternatives 3A, 3B, 4A, and 4B meet or exceed the
minimum RCRA Subtitle D and State performance standards (See Table
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Table A-l
DHL Site Landfill Operable Unit
Federal and State ARARs
(Page I of 2)
Remedial Activity and
Applicable Alternatives
Federal ARAR
State ARAR
Comment
Waste classification for
landfill contents (all
alternatives)
40 CFR, Part 261: Identification
and Listing of Hazardous Waste,
Subparts A (General), B (Criteria),
C (Characteristics), and Appendices.
329 I AC Article 3.1,
Rules 1, 4-6.
Establishes (hut RCRA hazardous
wastes were disposed in landfill,
and soils mixed with waste are
hazardous.
Hazardous Waste landfill
Closure and Post-Closure
Care (all alternatives)
40 CFR Part 264, Subpart N
(264.310 Closure and Post-Closure
Care, and 264.301 Design and
Operating Requirements and 264.117
Post-Closure Use).
329 I AC Article 3.1,
Rule 9
Performance standards lor new
RCRA landfills require covers dial
minimize infiltration and has a
permeability no greater than
I x 10 7 cm/s. Post-closure use of
properly restricted as necessary to
prevent damage to cover.
Solid Waste Landfill
Closure and Post-Closure
Care (all alternatives)
40 CFR Part 258.60
329 IAC Article
2-14-19
Federal performance standards for
new landfills require 18 inches of
1 x 105 cm/s or less layer, with
6 inches of topsoil. Stale
regulations specify 2 feet of
compacted clay with 6 inches of
topsoil. May be deemed relevant
and appropriate.
Stormwater Control
Requirements
(Alternatives 2-4)
327 IAC Article 15,
Rule 5: Storm Water
Run off Associated
with Construction
Applicable.
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Table A-l
Site Landfill Operable Unit
Federal and State ARARs
(Page 2 of 2)
Remedial Activity and
Applicable Alternatives
Federal ARAR
State ARAR
Comment
Point Source Discharge
Requirements for
Containment
(Alternatives 2-4)
327 IAC Article 15,
Rule 6: Stormwaicr
Discharge Associated
with Industrial Activity
May he relevant and appropriate.
Air Emissions Requirements
(Alternatives 2-4)
40 CFR 50.6, Paniculate Emission
Standards
326 IAC: Air
Pollution Control
Hoard Regulations
Article 6-4, 65,
Fugitive Dust
Emissions
Applicable to emissions of "clean"
dust. Fugitive dust emissions may
not ex;-.. d 67 percent of upwind
coiurciii.iiiions, or 50 /ig/m' above
bad ('round, or he visible at the
property line. Health based dust
emission control levels may he
lower, and are considered THCs.
MKLIOOISSA3 WPS
ft
\
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13
2).
BALANCING CRITERIA
Long Term Effectiveness
Addresses any expected residual risk and the ability of a remedy to
maintain reliable protection of human health and the environment
over time, once cleanup standards have been met.
All of the alternatives involve leaving wastes in place and the
long term effectiveness and permanence is entirely dependent on the
durability and maintenance of the covers and caps and the ability
to limit infiltration of rainwater.
Alternatives 2, 3A, 3B, 4A, and 4B provide both access restrictions
and containment technologies, including caps and surface controls.
The capping systems incorporated by Alternatives 2, 3A, 3B, 4A and
4B provide similar levels of protection from direct contact with
the landfill contents.
Alternatives 2, 3A, 3B, 4A, and 4B will prevent direct contact with
the landfill contents, will control surface water runoff and
erosion, and will prevent volatilization and fugitive dust
emissions from surficial soil contamination.
Alternative 2 will prevent contact with the landfill contents but
will not limit the infiltration of rainwater. Alternatives 3A, 3B,
4A, and 4B will prevent contact with the landfill contents and will
also limit the infiltration of rainwater to prevent contamination
of groundwater from the landfill contents. This limitation on
infiltration will decrease the transport of contaminants to the
groundwater, which will assist in long term groundwater remediation
by limiting the amount of contaminants migrating into the
groundwater.
Alternatives 3A, 3B, 4A, and 4B are functionally equivalent with
respect to this balancing criterion and are superior to Alternative
2" because of long term reliability and reduction of rainwater
infiltration. However, Alternatives 4B provides higher levels of
infiltration protection than Alternatives 3A, 3B, and 4A, resulting
in greater long-term effectiveness and permanence.
Addresses the anticipated performance of the treatment technologies
a remedy may employ.
All of the alternatives will reduce the mobility of groundwater
contamination at the site by reducing the amount of rainwater that
can infiltrate into the landfill and leach contaminants from the
landfill contents. None of the alternatives provides reduction of
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14
toxicity, mobility or volume through treatment, though Alternatives
4A and 4B do the most to reduce mobility and volume by containment
and reductions in the amount of rainwater that can infiltrate into
the landfill contents.
Alternative.4B provides the greatest reduction in infiltration and
therefore, provides the best reduction of TMV, slightly higher than
for Alternatives 3A, 3B and 4A. Therefore, although it has been
determined that Alternatives 2, 3A, 3B and 4A are functionally
equivalent with respect to this balancing criterion. Alternative 4B
shows a slightly higher level of effectiveness.
Short Term Effectiveness
Addresses the period of time needed to achieve protection and any
negative effects on human health and the environment that may be
posed during the construction and implementation period, until
cleanup standards are achieved.
All of the alternatives include fencing to restrict site access to
effectively prevent or reduce risks to potential trespassers.
Alternatives 2, 3A, 3B, 4A, and 4B result in higher short term
exposures over no action as a result of workers being involved in
grading and other capping activities at the site. Alternative 2
could be completed in approximately 1-2 months. Alternative 3A
could be completed in approximately 4 months, Alternative 3B could
be completed in approximately 3 months, Alternative 4A could be
completed in approximately 5 months, and Alternative 4B could be
completed in approximately 4 months.
Short term impacts from the construction of these alternatives
include site grading and capping activities and their potential to
disturb surface soils and subsurface wastes. All of the capping
alternatives will be required to follow the same safety precautions
to protect the construction workers, the community, and the
environment from the short-term impacts resulting from the remedial
actions. Basic safety precautions will include site workers
wearing personal protective equipment, decontaminating equipment
before leaving the site, implementing dust control measures such as
frequent watering of construction areas and roads, monitoring
ambient air around the perimeter of the landfill for migration of
airborne contaminants from the site, enforcing safe speed limits on
the construction site, maintaining noise control devices on
construction equipment, and providing facilities for construction
workers to eat and clean up to minimize ingestion and inhalation of
contaminants.
Alternatives 3B and 4B are more effective in the short term due to
the lack of a locally available clay source for the capping
requirements of Alternatives 3A and 4A. Also, the installation of
the capping requirements of Alternatives 3A and 4'A are more weather
dependent for successful completion than those for Alternatives 3B
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15
and 4B. This becomes more important because the timeframe for
installation of the cap necessitates construction in times when
weather may hinder performance.
Therefore, it has been determined that Alternatives 3B and 4B are
functionally equivalent and superior to Alternatives 2, 3A, and 4A,
primarily because of the lack of a locally available clay source
and the greater tolerance to adverse weather conditions.
Tmpl or^of! {-«>•>< 1 1 tr
Addresses the technical and administrative feasibility of a remedy,
including the availability of materials and services needed for a
particular option to be put in place.
The implementability of the alternatives is based on availability
of materials to construct the caps and the ease in obtaining
administrative permits to perform the work. Implementing
Alternatives 2, 3A, 3B, 4A, and 4B entails managing construction
activities, locating and ordering materials for construction, and
obtaining permits related to the remedial action.
Materials for Alternatives 2, 3B, and 4B are readily available
while the clay layer component of Alternatives 3A and 4A lacks a
locally available source.
Weather related concerns also impact implementability of the
alternatives . Alternatives 3A and 4A depend on the placement of a
compacted clay layer, which cannot be constructed in inclement
weather. Alternatives 3B and 4B cover construction is not as
weather dependent as the other alternatives as the placement of the
membrane and geosynthetic layer can be accomplished under adverse
weather conditions.
Therefore, Alternatives 3B and 4B have been determined to be
functionally equivalent with respect to this balancing criterion,
and are superior to Alternatives 2, 3A and 4A.
Cost
Included are capital costs, annual operation and maintenance costs
(assuming a 3 0 year time period) , and net present value of capital
and operation and maintenance costs. The selected remedy must be
cost effective.
The FS presented net present worth cost estimates for each of the
seven alternatives brought forward for detailed analysis. These
estimates were derived from literature, vendor quotations, actual
costs from similar projects, and standard cost information sources.
Cost estimates are provided primarily for the purpose of conducting
a comparative assessment between remedial options, in order to
assess the economic feasibility of the different alternatives.
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• e.
Table 5-2
Cost Estimate Summary
Alternative
1
2
3A
3B
4A
(w/60-mil HDPE)
4A
(w/30-mil PVC)
4B
(w/60-mil HDPE)
4B
(w/30-mil PVC
Capital Cost
$180.000
$2,000,000
$5.000.000
$4,100.000
$5,800.000
$5,500,000
$4,600,000
$4,300,000
Operations
Cost
$20.000
$400,000
$400.000
$400,000
$400,000
$400,000
$400,00
$400,00
Total Present
Worth
$200,000
$2,400,000
$5,400,000
$4,500,000
$6,100,000
$5,800,000
$5,000,00
$4,700,000
MKE10015842.WP5
5-12
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16
Where limited or insufficient information was available regarding
site -specific hydrogeologic characteristics or contaminant specific
treatability efficiencies, assumptions were made based on
literature and professional judgement where necessary to develop
costs associated with different processes. The cost estimates
provided in the FS are expected to provide an accuracy of +50/-30
percent (See Table 3) .
Therefore, based on an analysis of the costs associated with all of
the alternatives analyzed in the FS, Alternative 2 is the least
expensive of all of the alternatives and Alternatives 4A and 4B are
the most expensive.
MODIFYING CRITERIA
Addresses whether or not the State agency agrees to or objects to
any of the remedial alternatives, and considers State ARARs.
The Indiana Department of Environmental Management (IDEM) has been
intimately involved with the Site throughout the RI/FS, has
attended all technical progress meetings, has been provided
opportunity to comment on technical decisions, and concurs with the
selection of Alternative 4B as the selected remedy for the Site.
ty
Addresses the public' s general response to the remedial
alternatives and proposed plan.
Throughout the RI/FS at the Site, community involvement has
increased significantly over time. U.S. EPA has been accessible
and responsive to community concerns throughout the study. This
has been accomplished by a community relations program consisting
of periodic fact sheets highlighting site progress and availability
sessions with the community to communicate site information and to
answer questions regarding site progress.
At the public meeting, the majority of those in attendance, as well
as the majority of those who submitted written comments regarding
the proposed plan, were in favor of Alternative 4B as the most
appropriate choice for this action. Specific comments on the
proposed cleanup plan are addressed in Appendix A, the
Responsiveness Summary.
In summation, Alternative 1 is unacceptable for protection of human
health and the environment.* Alternatives 3B and 5B fully satisfy
the nine evaluation criteria with the exception of reduction of
toxicity, mobility and volume through treatment. However, these
two alternatives would provide reduction in the toxicity of
contaminants through groundwater treatment and reduction in the
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17
mobility of contaminants through capping. Alternatives 2, 3A and
4A are not as effective in the long term at reducing the mobility
of contaminants through capping.
Alternatives 3B and 4B are more effective in the short term than
Alternatives 3A and 4A due to the lack of locally available clay
deposits to use in the construction of the cap and the time and
effort necessary to place and compact these materials during cap
installation. Alternatives 3B and 4B are easier to implement than
Alternatives 3A and 4A because of the more readily available 6CL
liner materials compared with the lack of locally available clay.
Alternative 4B provides greater long term protection of landfill
contents from precipitation infiltration than Alternative 3B, which
will benefit long term remediation of contaminated groundwater
coming from the site, which will help to ultimately reduce the
risks posed by the landfill contents.
Therefore, the best balance among the seven alternatives, while
providing for protection of human health and the environment and
long term effectiveness and permanence, is Alternative 4B,
Composite Barrier Cap with a GCL Soil Barrier Layer.
Selected Remedy
U.S. EPA has selected Alternau. ~ 4B - Composite Barrier Cap with
a GCL Soil Barrier Layer, as the appropriate soil cleanup remedy
for the Douglas Road site. This alternative was selected because
it is the most appropriate alternative for this operable unit
action and is compatible with the final remedial alternative
selected for groundwater remediation, because of the reduction in
rainwater infiltration provided by the selected response action.
The objective of this operable unit action is to remediate on-site
source areas that are contributing to contamination of both soils
and groundwater. The FFS contains a description of this
alternative. The components of this alternative include site
preparation, institutional controls, groundwater monitoring, and
placement of cap materials.
Site preparation will consist of clearing and grubbing activities,
with the trees and shrubs shredded and placed evenly over the site
prior to placement of the gas collection layer.
Access restrictions will be .nplemented to control site use and
access. Access restrictions for this alternative include deed
restrictions, which will be sought to limit the use of the site for
construction or other site development, and will prohibit the use
of groundwater beneath the site for any purpose, and fencing to
inhibit unauthorized access to the landfill property, and to
protect the remedy components. Warning signs stating the hazards
within the landfill area will also be placed along the property
boundary as necessary.
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z
Geomembrane
Barrier
Geoeynthebc
Ow Liner
(GCL)
BsddvtQi
• w w w w Layer
\\NXXX\\ . . .. . . \" x \" \ N~ \~ \" \
• s * s xxx * s s f * * s *m£tm* ' ' ' '
ALTERNATIVE 4B:
COMPOSITE BARRIER CAP
(WITH GEOCOMPOSITE CLAY UNER GCU
FIGURE 2 (Sheet 2 of 2)
TYPICAL MULTILAYER LANDFILL
CAP SECTIONS
DOUGLAS ROAD LANDFILL FS REPORT
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18
The typical cross section for the composite barrier cap consists of
(from top to bottom) : a topsoil layer, a protective soil layer, an
aggregate or sand drainage layer with a minimum permeability of 1
x 10 (-2) cm/8, a flexible membrane liner (20 mil minimum) , a GCL
soil barrier layer with a maximum permeability of 1 x 10 (-8) cm/s,
and a gas collection layer. The cap will be graded at 3 percent
(minimum) slopes in the direction of flow to promote surface
drainage from the site and the cap will be revegetated to control
erosion. Perimeter ditches will be used to collect and store
surface drainings (See Figure 2) .
The construction of Alternative 4B will meet at a minimum the
requirements of 329 IAC 2-14-19 with the need for additional cover
materials to be evaluated during the remedial design of the remedy.
Gas collection shall be provided by installing vent pipes into the
fill. The collected gas shall be disposed of by flaring or
venting. Final gas management requirements will be determined
during remedial design.
After construction, regularly scheduled maintenance of the cap will
be performed. These activities will include mowing and perimeter
ditch maintenance. Maintenance of the perimeter ditches includes
removal of silt and debris which may accumulate in the ditches and
obstruct drainage of stormwater from the site.
Interim groundwater monitoring shall be conducted until the final
groundwater remedy is selected to monitor existing conditions.
This monitoring shall consist of a combination of RI- ins tailed
monitoring wells as well as selected residential wells to maintain
the existing information regarding groundwater impacts from the
landfill. The details of this program, including frequency and
location, will be developed during remedial design.
Because hazardous substances will remain in place at the site, U.S.
EPA will review the remedial action every five years to determine
its effectiveness.
fcin ini nr| t
The Proposed Plan for this remedial action was released for public
comment on March 23, 1995. The Proposed Plan identified
Alternative 4B, Composite Barrier Cap with GCL Soil Barrier Layer,
as the preferred remedial alternative. No significant changes have
been made since the release of the Proposed Plan.
Statutory Determinations
In accordance with the statutory requirements of Section 121 of
CERCLA, as amended, remedial actions taken pursuant to Sections 104
and 106 must satisfy the following:
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19
1. Be protective of human health and the environment.
2. Comply with all ARARs established under federal and state
environmental laws (or justify a waiver) .
3. Be cost effective.
4. Utilize permanent solutions and alternative technologies
or recovery technologies to the maximum extent
practicable.
5. Satisfy the statutory preference for remedies that
utilize treatment and also significantly reduce the
toxicity, mobility and volume of the hazardous
substances, pollutants, or contaminants.
In addition, CERCLA § 121 (cj requires five year reviews to
determine if adequate protection of human health and the
environment is being maintained where remedial actions result in
hazardous substances remaining on-site above health-based levels.
The selected remedy for the Douglas Road Landfill Site achieves
these requirements as discussed in detail below.
Protection of HTT>n*in Health y^d the ^^Tiviiro™1***^
The selected remedy for the source control operable unit achieves
the requirement of being protective of human health and the
environment by containing the source contamination and isolating it
from the environment. Baseline cancer risks from the site exceed
the 10-4 to 10-6 acceptable risk range established by EPA in the
NCP. Deed restrictions will ensure that future land use of the
source area will not impose an unacceptable risk. Non-carcinogenic
risks will be reduced to levels less than the EPA standard of 1.0,
through institutional and source control measures.
The selected alternative complies with all chemical, action and
location specific applicable or relevant and appropriate
requirements (ARARs) for the Site. A detailed discussion of the
ARARs and to be considered (TBCs) is presented above and a complete
list of ARARS and TBCs is in the Focused Feasibility Study.
Chemical-Specific ARARs
Chemical-Specific ARARs do not exist for contaminated source soils
at the Site. TBCs, such as reference concentrations and potency
factors were evaluated as part of the risk analysis for the Site.
The selected alternative will meet the TBC based clean-up goals for
the source area.
Action-Specific ARARs
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20
The selected alternative complies with the several action- specific
ARARs identified for the Site. The action- specific ARARs define
acceptable treatment and disposal procedures for hazardous
substances. Because of the nature of the contamination and its
disposal before November 19, 1980, RCRA is a relevant and
appropriate requirement for the selected alternative. RCRA
Subtitle C requires new landfill caps to have a permeability less
than or equal to the bottom liner system (approximately 1x10-7
cm/s) . RCRA Subtitle D requires an 18 inch cover with permeability
of no less than 1x10-5. Indiana Administrative Code Subtitle D has
additional specific composition and slope requirements for a
landfill cap. The selected alternative meets or exceeds the
federal and state Subtitle D requirements.
Location- Specific ARARs
There are no location specific ARARs that apply to the Site for
this operable unit.
Cost Effectiveness
The selected alternative is slightly higher in cost than most of
the low permeability capping alternatives, however, the benefits of
the increased effectiveness at limiting rainwater infiltration
which will benefit the remedial action selected for the groundwater
portion of this remedy makes the selected alternative a cost
effective choice .
pti.li.za.ti.on of Pezr|t*>pent Solutions and Alternative
The isolation of the source material by a cap does not meet the
preference for permanent solutions and alternative treatments . Use
of a permanent solution, such as removal or treatment of the source
material was deemed impractical due to the volume of the
contaminated material and the high cost of treatment .
for
The selected alternative does not meet the preference for
treatment. Treatment of the waste was deemed impracticable, due to
the large volume and heterogeneous nature of the contamination.
Because of these conditions, the presumption for containment was
considered appropriate for this site and treatment was eliminated
as an option.
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APPENDIX A
Douglas Road Landfill
Michigan City, Indiana
Responsiveness Summary
I. Responsiveness Summary Overview
In accordance with CERCLA Section 117, a public comment period
was held from March 23, 1995 to April 24, 1995, to allow
interested parties to comment on the United Stated Environmental
Protection Agency's (U.S. EPA's) Focused Feasibility Study (FFS)
and Proposed Plan for the Douglas Road Landfill Superfund site
(the Site) . At a April 5, 1995 public meeting, EPA and Indiana
Department of Environmental Management (IDEM) officials presented
the Proposed Plan for remediation for the landfill capping phase
at the Site, answered questions and accepted comments from the
public. Written comments were also received through the mail.
XX. Background of Community Concern
The Douglas Road Landfill operated from 1954 to 1979 as a
repository for Uniroyal plant wastes. From 1954 to 1971,
solvents, fly ash, paper, wood stock, rubber and plastic scrap
were disposed of at the landfill. Only fly ash was disposed of
from 1971 to 1979.
The Site was nominated for inclusion on the NPL on June 10, 1986
and placed on the NPL on March 31, 1989. In September, 1989, the
State of Indiana and Uniroyal signed a consent decree in which
Uniroyal agreed to perform a RI/FS at the site. Before
completion of this work, Uniroyal filed for bankruptcy and
discontinued work at the site (November 1991) . Following the
bankruptcy, it was determined that U.S. EPA should regain the
site lead and the RI/FS was began in early 1994, using Superfund
money.
During the RI, it was discovered that residential wells in the
vicinity of Douglas Road and State Road 23 were contaminated with
vinyl chloride and trichloroethylene (TCE), contaminants that had
been identified as coming from the site. These residents
received the following temporary measures to provide protection
until a permanent remedy could be implemented for the affected
wells: for those with vinyl chloride contamination, residents
received portable air strippers and for those with TCE
contamination, residents received in-line filters.
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Community involvement has increased as the extent of the off-site
groundwater plume and the number of residential wells impacted by
site contamination has been determined. This has led to more
people becoming aware of activities at the site and attending the
informational meetings.
III. EPA's Proposed Remedy and its Relation to the Final ROD
In a Proposed Plan that was issued on March 23, 1995, U.S. EPA
(EPA) proposed Alternative 4B, Composite Barrier Cap with GCL
Soil Barrier Layer for the landfill capping phase of the cleanup.
This remedy was based on the information presented in the FFS, •
prepared by CH2M Hill, the EPA contractor, and reviewed and
approved by EPA. During the public comment period, EPA received
several comments regarding the proposal of Alternative 4B, all of
which were favorable.
EPA will respond to these public comments, demonstrating that
public concerns play a large role in Superfund remedy selection.
IV. Summary of Significant Comments Received During the Public
Comment Period and EPA Responses
The comments are organized into the following categories:
A. Summary of comments agreeing with the proposed remedy choice.
1. Comments were raised agreeing with the selection of
Alternative 4B for this phase of the cleanup.
EPA Response 1: EPA appreciates the support for the proposed
remediation approach for the landfill cap phase of this cleanup.
EPA agrees that the proposed remedy is the most appropriate long
term solution for this phase.
2. Comments were raised regarding the potential future migration
of contaminated groundwater away from this site.
EPA response 2: EPA shares these concerns regarding potential
future impacts on area groundwater. The installation of the cap
will eliminate the possibility of rainwater soaking through the
landfill contents, which is how this site has contaminated
groundwater in the past. This, coupled with the next phase of
cleanup, which will remediate the contaminated groundwater, will
eliminate the migration of contaminated groundwater away from
this site.
3. A number of commentors expressed a desire to be hooked up to
city water as soon as possible to avoid any contact with the
contaminated groundwater.
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EPA response 3: EPA agrees with the commentors and is taking the
steps necessary to provide city water as soon as possible. Right
now, funding for the water line project is temporarily
unavailable. EPA had planned to use funding which would have
been provided from it's Headquarters office located in
Washington, D.C. to design and construct the water line
extension. This money has been frozen by EPA Headquarters in
anticipation of Congressional budget cuts. Congress is in the
process of re-examining EPA's overall budget for potential budget
cuts Agency wide. It is hoped that following this process, the
project will be funded. Once monies become available, the water
line extension will be designed and constructed in a several
months, hopefully later this year.
4. A commentor raised a number of concerns regarding the
groundwater phase and it's interrelation with the proposed
capping portion of the Site cleanup.
EPA response 4: EPA appreciates the input and suggestions for
characterizing and cleaning up area groundwater. EPA will factor
these concerns into any future plans for groundwater cleanup. As
was stated in the meeting, the proposed capping of the landfill
is closely interrelated with future cleanup plans for area
groundwater.
EPA proposed this capping alternative because it's implementation
will greatly augment future groundwater cleanup.
EPA will propose a final remedy for area groundwater cleanup this
summer, for which the commentor and the rest of the public will
have the opportunity to provide input to the EPA.
The comments are paraphrased in order to effectively summarize
them in this document. The reader is referred to the public
meeting transcript which is available in the public information
repository, which is located at the Mishawaka-Penn Public
Library. Written comments received at EPA's regional office are
on file in the Region 5 office. A copy of these written comments
has also been placed in the aforementioned repositories.
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
DOUGLAS ROAD LANDFILL SITE
MISHAWAKA, INDIANA
ORIGINAL
O6/13/95
DOCI DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
1 00/00/00 Schafer, 6., U.S.
EPA
2 10/05/79 Carpenter, R.,
Uniroyal, Inc.
3 10/24/80 Carpenter, R.,
Uniroyal, Inc.
4 00/00/85 U.S. EPA
5 06/00/87 U.S. EPA
6 08/00/89 USDHHS/USPHS/ATSDR
7 12/00/90 IDEH
8 06/00/91 Eder Associates
Consulting
Engineers, P.C.
9 07/00/91 Eder Associates
Consulting
Engineers, P.C.
10 04/15/93 U.S. EPA
11 06/11/93 Warren, H., Eder
Associates
Consulting
Engineers, P.C.
12 07/13/93 Schafer, 6., U.S.
EPA
13 07/19/93 Schafer, 6., U.S.
EPA
Plotb, D., CH2H Hill Cover Letter Poniarding Various Background
Information Documents
Trost, P., St.
Joseph County Health
Department
Trost, P., St.
Joseph County Health
Departient
File
File
Public
Public
U.S. EPA
U.S. EPA
File
Schafer, 6., U.S.
EPA
Letter re: Termination of Landfill Operations 34
N/Attaclwents Documenting Disposal Practices
Letter re: Closure of Douglas Road Landfill
x/Attachients
Uniroyal Historical 6round«ater Data 1970—
1985
Correspondence, Hater Veil Records and
Sampling Data Relating to the Harvey
Residential Hell from 1970*1987
Public Health Statement: 'Vinyl Chloride*
Fact Sheet: 'Environmental Investigation
Begins*
Progress Report 11
Progress Report 12
Statement of Work for Conducting an RI/FS
(HANDMRITTEN ANNOTATIONS)
Letter re: Eder's Response to U.S. EPA's
104(e) Information Request N/Attachments
Nathan, S., U.S.EPA Memoranda* re: RPK's Notes from the June 28,
1993 Kickoff Meeting Kith CH2H Hill
20
75
123
7
6
49
22
27
134
Addressees
Cover Memorandum Forwarding the Draft RI/FS 1
Hork Plan
-------
DOCI DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
14 07/22/93 Schafer, 6., U.S. Plotb, D., CH2N Kill Cover Letter Fornarding Three Boxes of Rail 1
EPA . Analytical Data
15 07/27/93 Helier, E., U.S. EPA Schafer, &., U.S. Heiorandui re: Ecological Revien of the Draft 2
EPA RI/FS Nork Plan
16 08/11/93 Nathan, S., U.S. EPA Sandoval, K., U.S. Hetorandui Foraarding Attached August 11, 37
EPA 1993 Statement of Nork (Revision 1)
17 08/11/93 Schafer, 6. and File Metorandu* re: Suiiary of Discussions Held at 4
Nathan, S., U.S. EPA the June 28, 1993 Kickoff Meeting vith CH2M
Hill
18 08/11/93 Borski, H., U.S. EPA Figliulo, I., U.S. Heiorandui re: Hetlands Regulatory Unit's 1
EPA Revien of the Draft RI/FS Nork Plan
19 08/18/93 Schafer, 6., U.S. Ploib, D., CH2H Hill Cover Heiorandui Foraarding Various Docuients 1
EPA re: the Quality Assurance Project Plan
20 03/19/93 Matters, E., U.S. Traub, J., U.S. EPA Heiorandui re: Hater Division's Review of. the 3
EPA RI/FS Nork Plan
21 08/23/93 Kasarabada, P., IDEH Schafer, E., U.S. Letter re: IDEH's Review Couents on the 4
EPA RI/FS Hork Plan
22 OS/24/93 Schafer, 6., U.S. Plotb, D., CH2K Hill Letter re: U.S. EPA/IDEM's Revien Couents on 5
EPA the Draft RI/FS Hork Plan
23 09/14/93 Ploib, D. and Scbafer, 6., U.S. Hetorandui re: DRL Meeting Minutes (FASP and 3
Ohland, C., CH2M EPA Beoprobe)
Hill
24 09/17/93 Schafer, 6., U.S. Addressees Hetorandui re: Suuary of Septeaber 2, 1993 4
EPA Minutes froi the FASP/6eoprobe Meeting
25 11/01/93 CH2H Hill U.S. EPA Report: Hork Plan for the RI/FS 95
26 11/05/93 Ploib, D., CH2M Hill Schafer, 6., U.S. Cover Letter Foraarding the Quality Assurance 1
EPA Project Plan, Field Sampling Plan, and Health
and Safety Plan
27 11/05/93 CH2N Hill U.S. EPA Health and Safety Plan 26
28 12/09/93 Schafer, E., U.S. Ploib, D., CH2H Kill Letter Foraarding Attached CH2H Hill's 35
EPA Cowents on the Draft Quality Assurance
Project Plan n/Attachunts
-------
DOM DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
29 01/11/94 Henne, D., U.S. 001 Novak, D., U.S. EPA Letter re: U.S. DOI's Review Contents on the 3
Draft RI Report .
30 03/04/94 CH2H Hill U.S. EPA . Quality Assura.-.ce Project Plan for the fil/FS 371
31 03/22/94 Traub, J.f U.S. EPA Various Property Letters to Eleven Property Owners Requesting 44
Owners Access to Property w/Attached Blank 'Consent
to Access to Property1 For§
32 04/04/94 Novak, D., U.S. EPA Lopat, B., Jennings FAX Transaitta: re: Access to the Lake Shore 2
Realty, Inc. Estates Property w/Attached Signed 'Consent
for Access to Property* For§
33 04/25/94 Ploib, D., CH2H Hill Novak, D., U.S. EPA Letter re: Results of Beoprobe Investigation 2
and Proposed Bell Locations
34 05/04/94 Various Property U.S. EPA Ten 'Consent for Access to Property' Fom 10
Owners Signed Between (larch 24-April 5, 1994
35 05/0&/94 Peterson, S., U.S. Novak, D., U.S. EPA Heiorandui re: Results of Saaples Collected 45
. EPA April 11-18, I?94
36 08/00/94 U.S. EPA File Round 1 Chain of Custody Records and Saipling 76
Data
37 08/00/94 U.S. EPA File Round 2 Chain cf Custody Records and Saipling B7
Data
38 08/01/94 Ploib, D., CH2H Hill Novak, D., U.S. EPA Letter re: Results of Residential Hell 2
Sampling
39 08/30/94 Theisen, K., U.S. South Bend Residents Letters to Eleven Residents re: Results of 11
EPA August 25, 19?4 Residential Hell Saipling for
Vinyl Chloride
40 08/30/94 Theisen, K., U.S. South Bend Residents Letters to Five Residents re: Results of 5
EPA August 12, 1994 Saipling of Residential Hell
Hater for Vinyl Chloride
41 09/0&/94 Novak, D., U.S. EPA Hichael, E., St. FAI Transeittai Forwarding List of Addresses 4
Joseph County Health in Area of SP. 23 / Dougles Road w/Attached
Departient Haps
42 09/08/94 Novak, D., U.S. EPA Hishawaka Residents Letters to Five Residents re: Suuary of 12
Results of April 11, 1994 Residential Nell
Saipling
-------
DOM DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PASES
ssss ---- =r=== ===:=:= c=========3==r=s: sssss
43 09/09/94 Novak, 0., U.S. EPA South Bend Residents Letters to Four Residents re: Summary of 8
Results of Nay 23 and April 11, 1994
Residential Hell Saipling
44 09/16/94 Tavitas, N., ATEC Doran, H., Riedel Letter Forwarding Attached Results of the 46
Associates, Inc. Environmental Organic Analyses for Thirteen Saiples (Round
Services 3)
45 09/19/94 Krieg, 0., Ecology i Theisen, K., U.S. FAX Transmittal Forwarding Chain of Custody 22
Environment, Inc. EPA Records and Field Saiple Data Sheets for
Residential Hell Saipling w/Attachments
46 09/23/94 CH2H Hill U.S.EPA Technical Memorandum II: Suuary of Field 58
Investigation Data Collection Activities
47 10/11/94 Theisen, I., U.S. South Bend Residents Letters to Eleven Residents re: Results of 11
EPA September 13, 1994 Residential Hell Sampling
for VOCs
48 12/01/94 Novak, D., U.S. EPA Ostrodka, S., U.S. Cover Memorandum Forwarding the Risk 1
EPA Assessment
49 12/15/94 Plomb, D., CH2H Hill Novak, D., U.S. EPA Cover Letter Forwarding the Agency Review 1
Draft of the RI Report
50 01/03/95 PodoHski, A., U.S. Novak, D., U.S. EPA Memorandum re: Technical Support Section's 9
EPA Review Comments on the Baseline Risk
Assessment M/Attachments
51 01/05/95 Hicheal, E., St, Novak, D., U.S. EPA Letter re: SJCHD's Request to U.S. EPA to 17
Joseph County Health Conduct Hater Sampling to Verify the
Department Effectiveness of the Hater Filtration Devices
H/Attached Documents from the SJCHD's Douglas
Road Site File
52 01/11/95 Theisen, K., U.S.EPA South Bend Residents Letters to Eight Residents re: Results of 8
November 21, 1994 Residential Hell Sampling
for VOCs
53 01/11/95 Morrow, H., U.S. EPA Novak, D., U.S. EPA Memorandum re: Technical Support Section's 3
- Review Comments on the RI Report
54 01/11/95 Chapman, J., U.S. Novak, D., U.S. EPA Memorandum re: Technical Support Section's 2
EPA Review Comments on the Agency Review Draft RI
Report
55 01/20/95 Theisen, K., U.S. South Bend Residents Letters to Two Residents re: Results of 2
EPA November 14, 1995 Residential Hell Sampling
for VOCs
-------
DOM DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
56 01/20/95 Theisen, K., U.S. South Bend Residents Letters to TNO Residents re: Results of 2
EPA November 21, 1995 Residential Hell Saipling
for VOCs
57 01/23/95 Theisen, K., U.S. South Bend Residents Letters to Five Residents re: Results of 5
EPA Decesber 19, 1994 Residential Hell Saipling
for VOCs
58 01/24/95 Srejda, H., IDEM Novak, D., U.S. EPA Letter re: IDEH's Couents on the First Craft 4
of the RI Report
59 01/25/95 Panos, C., U.S. EPA Novak, D., U.S. EPA Heiorandui re: Air Toxics and Radiation 1
Branch's Review of the Draft FS Report
60 01/26/95 Brejda, H., IDEH Novak, D., U.S. EPA Letter re: IDEH's Review Couents on the 6
First Draft of the FFS Report
61 02/00/95 CH2H Hill U.S. EPA Public Coiient Focused Feasibility Study 150
62 02/00/95 CH2K Hill U.S. EPA • Reiedial Investigation Report: Volute 1 of 2 159
(Text)
63 02/00/95 CH2H Hill U.S. EPA Reiedial Investigation Report: Volute 2 of 2 384
(Appendices A-F)
64 02/06/95 Novak, D., U.S. EPA Ploab, D., CH2H Hill Letter re: U.S. EPA'5 Couents on tbe FFS 10
Report H/Attachients
65 02/23/95 Ploib, D., CH2H Hill Novak, D., U.S. EPA Letter re: CH2H Hill's Response to U.S. EPA 13
Couents on the Agency Review Draft of FFS
Report
66 02/27/95 Ploib, D., CH2H Hill Novak, D., U.S. EPA Letter re: CH2H Hill's Response to U.S. EPA's 13
Couents on the Agency Review Draft of the RI
Report
67 02/28/95 Environmental Health St. Joseph County Laboratory Report re: One Drinking Hater 5
Laboratories Health Departient Saiple and One Laboratory Trip Blank
68 03/00/95 U.S. EPA Public Fact Sheet: 'Proposed Plan for Reiedial 4
Action (Landfill Cap)1
69 03/01/95 Novak, D., U.S. EPA Addressees Cover Heiorandui Forwarding the Final RI 1
Report
70 03/02/95 Novak, D., U.S. EPA Addressees Cover Heiorandui Forwarding the Draft 1
Proposed Plan for Review
-------
DOM DATE AUTHOR RECIPIENT TITLE/DESCRIPTION PABES
71 03/09/95 Grejda, H., IDEM Novak, D., U.S. EPA Letter re: IDEM's Revien Cotients on the 2
Second Draft of the FFS Report
72 03/10/95 Grejda, H., IDEfl Novak, D., U.S. EPA Letter re: IDEH's Review Contents on the 3
First Draft of the Proposed Plan
73 03/10/95 Henne, D., U.S. DOI Novak, D., U.S. EPA Letter re: U.S. DOI's Review Contents on the 5
Draft Proposed Plan
74 03/13/95 Bright, D., ISDN Novak, D., U.S. EPA Meiorandui re: ISDH's Review Couents on the 1
Draft Proposed Plan
75 03/14/95 flarrero, J., U.S. Novak, D., U.S. EPA Meiorandui re: Air Toxic and Radiation 1
EPA Branch's Review Cements on the Draft
Proposed Plan
76 03/15/95 U.S. EPA Public Public Notice re: Announceient of April 5, 1
1995 Public Meeting and March 23-April 24,
1995 Public Couent Period
77 03/20/95 Novak, D., U.S. EPA Ploab, D., CH2H Hill Letter re: U.S. EPA's Review of the Revised 1
FS Report
• 78 03/21/95 Grejda, H., IDEM Novak, 0., U.S. EPA Letter re: IDEM's Review Couents on the 5
Second Draft of the RI Report
79 04/04/95 Grejda, H., IDEH Novak, D., U.S. EPA Letter re: IDEM's Review Cotients on the 2
First Draft of the Hork Plan for Reiedial
Design
80 04/07/95 Beutter, R., City of U.S. EPA/OPA Letter re: Mayor's Coiients Concerning the 2
Hishanaka Proposed Plan
81 04/24/95 Concerned Citizens U.S. EPA Five Public Coeient Sheets re: the Proposed 5
Plan
82 04/28/95 RuMel Reporting U.S. EPA Transcript: April 5, 1995 Public Hearing 53
Service
-------
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
DOUGLAS ROAD LANDFILL SITE
MISHAWAKA, INDIANA
GUIDANCE ADDENDUM
O6/13/95
ODCt DATE AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
1 05/16/89 U.S. EPA
2 09/00/93 U.S. EPA/OSHER
U.S. EPA
Index: 'Compendium of CERCLA Response
Selection Guidance Documents' (Attached)
[Guidance Documents are Incorporated by
Reference and Hay be Viewed at U.S. EPA
Region 5, 77 N. Jackson Blvd., Chicago, IL
60604-3590]
Quick Reference Fact Sheet: 'Presumptive
Remedy for CERCLA Municipal Landfill Sites'
(OSUER Directive 9355.0-49FS; EPA
540-F-93-035)
12
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