PB97-964103
EPA/541/R-97/071
November 1997
EPA Superfund
Record of Decision:
Reilly Tar & Chemical
(Indianapolis Plant), Operable Unit 5,
Indianapolis, IN
6/30/1997
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Declaration for the Record of Decision
Reilly Tar & Chemical
Operable Unit 5
Site Name and Location
Reilly Tar and Chemical
Indianapolis, Indiana
Statement of Basis and Purpose
This decision document presents the selected remedial action for operable unit 5 at the Reilly Tar
& Chemical site (the Site) in Indianapolis, Indiana. This remedial action was selected in
accordance with CERCLA, as amended by SARA, and, to the 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 actions selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
Description of the Selected Remedies
This action is the final action planned for the site. It specifically outlines an action to address
off-site groundwater contamination, which has been determined by the Remedial!.. .e^'gation to
pose unacceptable risks to human health and the environment.
The major components of the selected remedy include:
- Natural attenuation (with long-term groundwater monitoring) for off-site groundwater
contamination. This selection, when combined with the continued operation of the OU 1
Groundwater Interim Remedial Measures (GWIRM) system, will provide long term protection to
human health and the environment from exposure to groundwater contamination in the OU 5
area. The perimeter groundwater extraction system, selected as an interim remedy for OU 1, is
an integral component of the final groundwater cleanup for the site. The GWIRM system will be
in operation until the cleanup and performance standards listed in the OU 1 ROD are met at the
facility boundary.
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- Long term groundwater monitoring to supplement the existing water quality monitoring
program which is currently conducted on a quarterly basis. This monitoring will be utilized to
evaluate the performance of the selected remedy over time.
Statutory Determinations
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 is consistent with achievement of a permanent remedy. This final action fully
addresses the statutory mandate for permanence and treatment to the maximum extent
practicable. This action also satisfies the statutory preference for remedies that employ treatment
that reduces the toxicity, mobility, or volume as a principal element. Because this remedy will
result in hazardous substances remaining onsite 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 vears after commencement of the remedial action.
Date William E. Muno,Director
Superfund Division
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Decision Summary - Operable Unit 5
Reilly Tar and Chemical
Indianapolis, Indiana
Site Name, Location and Description
Reilly Tar and Chemical
Indianapolis, Indiana
The Reilly Tar and Chemical site (the Site) is located at 1500
South Tibbs Avenue in the southwest quadrant of Indianapolis.
Minnesota Street divides the 120 acre site into two parcels. The
Oak Park property, occupying approximately 40 acres, is located
north of Minnesota Street. The Maywood property occupies
approximately 80 acres, and is located south of Minnesota Street
(see Figures 1 and 2). The Oak Park property contains the
majority of Reilly Industries, Inc.'s (Reilly) operating
facilities, including above-ground storage tanks, distillation
towers, and above- and below-ground utilities. The Oak Park
property also contains one area formerly used for disposal of
hazardous wastes, the Lime Pond, a surface impoundment which
received hazardous wastes. Drums containing hazardous wastes
were also buried in the soils adjacent to the Lime Pond. The
Maywood property contains operating facilities on its northern
end. This property was formerly the site of chemical process and
wood preserving activities and currently contains four other
areas used in the past for hazardous waste disposal. These four
former hazardous waste disposal areas include the Abandcned
Railway Trench, the Former Sludge Treatment Pit, the Former
Drainage Ditch, and the South Landfill/Fire Pond. The majority
of the operating facility buildings are located north of
Minnesota Street; approximately 75% of the Oak Park property is
covered by buildings, pavement and above-ground tank farms.
Approximately 20% of the Maywood property is covered by
buildings, pavement and above-ground storage tanks. Excavation
and thermal desorption activities have occurred on portions of
the remainder of the property. Following completion of these
activities, the areas will be revegetated.
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A new building has been constructed on the northern portion cf
the Maywood property. This building houses the equipment for a
new manufacturing process to produce a raw material for use in
the chemical production activities.
The Reilly Tar site is surrounded by a mix of residential,
industrial and commercial properties. Residential neighborhoods
are located immediately adjacent to the eastern boundary (on the
east side of Tibbs Avenue) of the Oak Park property. Two
residences are also located abutting the northern property
boundary near the Lime Pond in the northwest corner of the site.
Commercial and industrial properties are located south and west
of the site.
Site History and Enforcement Activities
Industrial development of the Reilly site began in 1921 when the
Republic Creosoting Company (which later became Reilly Tar &
Chemical, which in turn became Reilly Industries, Inc.) started a
coal tar refinery and a creosote wood treatment operation on the
Maywood property. On-site wood treatment operations occurred
from 1921 until 1972. Beginning in 1941, several chemical plants
were constructed and operated on the Oak Park property.
Environmental problems at the site are related to the management
and disposal of creosoting process wastes and to wastes
associated with and substances used in the process of
manufacturing custom synthesized specialty chemicals.
The earliest recorded complaint about odors and disposal
practices at the site was in 1955, which referenced the fact that
a chemical manufactured at Reilly (alpha picoline) had been found
in nearby residential wells. In 1964, three contaminants from
Reilly were detected in off-site groundwater samples and on-site
surface water samples. In 1975, State investigations revealed
several on-site problems which were believed to have been
contributing to groundwater contamination with organic chemicals.
In 1980, an on-site soil sample collected by State pe^onnel was
found to contain various organic chemicals including toluene and
trichloroethylene. In 1987, 60,000 gallons of waste fuel,
containing primarily pyridine and pyridine derivatives, benzene,
xylene, and toluene, were accidentally spilled on the Oak Park
property. Some, but not all, of the fuel oil was recovered and
some, but not all, of the contaminated soil was excavated by
Reilly.
In 1984, Reilly Tar was listed on U.S. EPA's National Priorities
List (NPL), a roster of the nation's worst hazardous waste sites,
making it eligible for cleanup under the Superfund program.
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In 1987, the potentially responsible party (Reilly) agreed to
conduct a remedial investigation (RI) to characterize the nature
and extent of contamination at the site, and a feasibility study
(FS) to evaluate and compare remedial alternatives according to
the terms of an Administrative Order on Consent between the U.S.
EPA and Reilly Tar & Chemical.
In 1989, Reilly Tar & Chemical changed their corporate name to
Reilly Industries, Incorporated, under which they operate today.
In June, 1992, a Record of Decision was signed by the Regional
Administrator for the first operable unit at the site, calling
for a groundwater extraction/treatment/discharge system to be
installed to contain the migration of groundwater contaminated by
the site at the site boundary.
In September, 1992, Reilly agreed to incorporate RCRA corrective
action requirements into existing site studies according to the
terms of an amendment to the existing Administrative Order on
Consent between the U.S. EPA and Reilly Tar & Chemical. Operable
unit actions outlined in this Record of Decision address areas
incorporated into site studies by the 1992 Amendment to the 1987
Administrative Order on Consent.
In September, 1993, a Record of Decision was signed by the
Regional Administrator for the second operable unit at the site,
calling for the excavation and thermal desorption of soil at four
on-site source areas and the solidification of sludge and
placement of a soil cover over a fifth on-site source area.
Consent Decrees have been negotiated and entered for operable
units 1 and 2. The consent decree for operable unit 1 was
entered on August 19, 1993. The consent decree for operable unit
2 was entered on February 1, 1995.
In September, 1996, a Record of Decision was signed by the
Regional Administrator for the third and fourth operable units at
the site, calling ror the installation of a permeable cover over
the OU 3 area and soil vapor extraction and a concrete cover over
portions of the OU 4 area.
The perimeter groundwater extraction system has been in operation
since October 1994, containing contaminated groundwater at the
site boundary. The sludge accumulation at the South Landfill
portion of OU 2 has been solidified and a soil cover has been
placed over the area. The thermal desorption of the four
remaining areas addressed under OU 2 was completed in January
1997. Soils from these areas that were unable to be treated by
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thermal desorption have been stockpiled on-site and will be
disposed of at the direction of U.S. EPA in the near future.
Highlights of Community Participation
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 relations program for this site, with the assistance of
the Indiana Department of Environmental Management (IDEM). The
following public participation activities, to comply with CERCLA,
were conducted during the RI/FS.
A Community Relations Plan was developed in August 1987 to
assess the community's informational needs related to the
Reilly site and to outline community relations activities to
meet these needs. Residents and community officials were
interviewed and concerns were incorporated into this plan.
A public information repository was established at the
Indianapolis/Marion County Public Library-Central Branch.
A mailing list of interested citizens, organizations, news
media, and elected officials in local, county, State and
Federal government was developed. Fact Sheets and other
information regarding site activities were mailed periodically
to all persons or entities on this mailing list. This
mailing list was also updated from time to time as persons
approached EPA for information about the site.
A Fact Sheet was mailed to the public in August 1987, that
announced a public meeting to discuss the upcoming Remedial
Investigation and answer site related questions from the
public.
A public meeting on September 2, 1987, at the Indianapolis
City-County Building announced the initiation of the Remedial
Investigation and provided details about its conduct.
A Fact Sheet was mailed to the public in Winter 1988, that
announced the beginning of Phase 1 RI sampling and the release
of the EPA approved Phase 1 RI workplan.
- A Fact Sheet was mailed to the public in Fall 1988, that
summarized the findings of the Phase 1 investigation and
provided a preview of proposed Phase 2 sampling activities.
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A Fact Sheet was mailed to the public in January 1990, that
announced the findings of the Phase 2 investigation and
provided a preview of proposed Phase 3 sampling activities.
Two availability sessions were held on September 6, 1990, at
the Stout Field School to discuss site progress and discuss
results of completed sampling activities.
A Fact Sheet was mailed to the public in August 1991, that
summarized results of the completed Remedial Investigation.
The EPA approved Remedial Investigation Report was also
released at this time.
A Fact Sheet was mailed to the public in January 1992, that
summarized EPA's recommended remedial alternative in a
proposed plan for the groundwater operable unit. The EPA
approved Focused Feasibility Study was also released at that
time. This fact sheet also announced a public comment period
for the proposed remedial action and was accompanied by paid
newspaper advertisements in the Indianapolis Star and the
Indianapolis News.
A Public Meeting was held on January 23, 1992, at the South
Wayne Junior High School to present EPA's proposed plan for
the groundwater operable unit and to receive formal public
comment.
Paid newspaper advertisements announced the RI public meeting,
the availability sessions, and the OU 1 FS and proposed plan
public meetings.
Periodic news releases announced results of studies at the
site.
A public comment period of thirty days was originally planned,
running from January 16, 1992, to February 14, 1992. Based on
a written request during the original comment period, the
comment period was extended until March 31, 1992, for a total
comment period of 76 days. The extension was announced by
letter to the requestor and in a newspaper advertisement in
the Indianapolis Star.
A Record of Decision was signed by the Regional Administrator
on June 30, 1992, for the groundwater operable unit.
Two availability sessions were held on November 19, 1992, at
the Stout Field School to discuss site progress and discuss
results of completed sampling activities, including drum
removal activities near the Lime Pond.
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A Public Meeting was held on August 4, 1993, at the Indiana
Government Center-South to present EPA's proposed plan for
the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) Areas operable unit (OU 2} and to
receive formal public comment.
A public comment period of thirty days for the CERCLA Areas
proposed plan was originally planned, running from July 22,
1993, to August 22, 1993. Based on a written request during
the original comment period, the comment period was extended
until September 7, 1993, for a total comment period of 45
days. The extension was announced by letter to the requestor
and in newspaper advertisements in the Indianapolis Star. The
comment period was further extended until September 22, 1993,
for a total comment period of 60 days. The extension was
announced by phone and confirmed by letter to the requestor
and announced to the general public by a newspaper
advertisement in the Indianapolis Star.
A Public Meeting was held on July 24, 1996, at the South
Wayne Junior High School to present EPA's proposed plan for
operable units 3 and 4 and to receive formal public comment.
Paid newspaper advertisements announced the OU 3 and 4 FS and
proposed plan public meetings.
A public comment period of thirty days for operable units 3
and 4 ran from July 15, 1996, to August 14, 1996.
A Record of Decision for Operable Units 3 and 4 was signed by
the Regional Administrator on September 29, 1996.
- A Public Meeting was held on March 26, 1997, at the Stout
Field School to present EPA's proposed plan for operable unit
5 and to receive formal public comment.
A public comment period of thirty days for operable unit 5 ran
from March 24, 1997, to April 22, 1997.
Paid newspaper advertisements announced the OU 5 FFS and
proposed plan public meetings.
This Record of Decision presents the selected remedial action for
operable unit 5 at the Reilly Tar and Chemical site in
Indianapolis, Indiana. Operable unit 5 addresses the off-site
groundwater plume and is the final remedial action at the site
addressing contaminated groundwater.
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This remedial action was chosen in accordance with CERCLA, as
amended by SARA, and the National Contingency Plan. The
decisions for this operable unit at the site is based on the
Administrative Record.
Scope and Role of the Operable Unit
As with many Superfund sites, the problems at the site are
complex. The Remedial Investigation (RI) investigated five
distinct on-site source areas and groundwater. The RI determined
that groundwater had been contaminated by the site and is
migrating away from the site at levels that were determined by
the site Risk Assessment to pose unacceptable threats to human
health.
The first operable unit action was selected by EPA to stop
further off-site migration of contaminated groundwater by
installing a groundwater extraction system/treatment system.
This action provided adequate time to study and remediate on-site
source areas as well as to prevent the further contamination of
area groundwater resources by contaminants migrating from the
Reilly site.
The second operable unit at the site addressed five distinct on-
site source areas that were contributing to contamination of both
soils and groundwater. These areas were initially investigated
in the RI. The selected remedy for this operable unit was the
excavation and thermal treatment of soils from four of these
areas and the solidification of sludge with placement of a soil
cover for the fifth area.
The third and fourth operable units at the site will address the
direct contact threats from potential exposure to contaminated
soils in the kickback area and the north process area as well as
prevention of future leaching of site contaminants to groundwater
from these areas.
This Record of Decision encompasses the fifth and final operable
unit remedial action to be taken at the site. This action is the
final remedial action to address contaminated groundwater. It
includes actions to address groundwater contaminated by the site
that has migrated to off-site areas. It also represents the
final remedial action chosen for the entire site.
This operable unit has been designed to be consistent with all
remedial actions taken at or planned for the site.
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Site Characteristics
The RI/FS was conducted to identify the types, quantities and
locations of contaminants at the site and to develop alternatives
that best address these contamination problems. Because of the
size and complexity of the site, the RI was performed in three
distinct phases. The first phase focused on sampling off-site
commercial, industrial and residential wells to determine the
presence of and extent of off-site contamination. The second
phase concentrated on sampling activities to determine the extent
of contamination onsite so that site contributions to areal
contamination could be determined. The third phase concentrated
on collecting additional onsite and off-site data to complete the
investigatory picture so that a Feasibility Study could be
started to address contamination problems. The nature and extent
of actual or potential contamination related to .the site was
determined by a series of field investigations, including:
- development of detailed information regarding
historical site operations;
- on-site geophysical surveys;
- surface soil sampling, both onsite and off-site;
- exploratory test pit excavation and sampling;
- installation and sampling of groundwater
monitoring wells, both onsite and off-site;
- surface water sampling, both onsite and off-site;
- identification and sampling of existing
groundwater wells in the site vicinity;
- installation and sampling of soil borings;
- a surface water drainage study;
- a water level monitoring program, both onsite
and off-site;
- identification of groundwater contamination
sources within a one-mile radius of the Reilly
site;
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- hydraulic conductivity testing and the performance
of a short-term continuous water level monitoring
program;
- preparation of a site-wide human health and
ecological risk assessment.
Geology/Hydrogeology:
The Reilly site lies within the White River drainage basin,
located approximately three miles to the west of the River.
Eagle Creek is an attendant tribu'tary and flows in a
southeasterly direction approximately 4000 feet to the east of
the site. Topography in the site area is relatively flat with a
gentle downward slope in an easterly direction. Other surface
water bodies in the site-area include Blue Lake (a former gravel
pit) located approximately 2000 feet northeast of the site,
several small ponds or surface water impoundments located 2000 to
4000 feet east of the site, and one surface-water impoundment
located immediately southwest of the Maywood property (see Figure
2). The westernmost extension of Blue Lake has been filled in
since 1979.
The sand and gravel deposits that underlie almost all of the
White River drainage basin form the principal aquifer in the
area. There are three industrial well fields located to the east
of the site that have a reported combined pumping rate of 10
million gallons per day, or approximately 7000 gallons per minute
(see Figure 2). In the vicinity of the site, upper and lower
zones have been identified within the sand and gravel outwash
aquifer. At some locations, especially directly underneath the
site, these zones are separated by one or more till units which,
because of their silt content/ are less permeable layers and may
impede flow vertically. The lack of a continuous fine grained
unit and similar groundwater levels in shallow and deep wells
suggest that the upper and lower zones of the outwash sand and
gravel deposits are hydraulically connected and that the till
units do not act as a barrier to contaminant flow in groundwater.
Regional hydrogeologic data indicate that groundwater in the
unconsolidated material in the area of the Reilly site flows east
towards Eagle Creek with a southerly component. Water level data
from the RI indicate that groundwater flow is generally from the
northwest to the southeast and that withdrawals from neighboring
industrial production wells significantly impact the flow of
groundwater east of the site, thus providing a barrier to further
movement to the east of groundwater impacted by the site.
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Hydraulic conductivities for wells tested during the RI range
from 10 (-2) to 10 (-3) centimeters per second. An average linear
groundwater velocity of 0.68 feet per day was calculated for the
area that is not influenced by the industrial pumping to the east
of the site. An average linear groundwater velocity of 2.0 feet
per day was calculated for the area that is influenced by the
industrial pumping.
Groundwater Contamination
Groundwater benzene concentrations in the OU 5 off-site area
range from below detection limits to 2700 ppb, with the highest
levels detected directly east of the central portion of the site.
Pyridine and pyridine derivative concentrations, which were
summarized in the RI as total pyridine derivatives, were found in
the OU 5 off-site area at levels ranging from below detection
limits to 2805 ppb, with the highest levels detected east of the
northern portion of the site. Ammonia concentrations in the
ground water in the OU 5 off-site area ranged from below
detection limits to 68 parts per million (ppm) with
concentrations greatest in the area directly east of the northern
portion of the site (See Figure 3 for a map of the benzene
contaminant plume). The maximum detected levels of contamination
in the groundwater are in excess of Federal and State MCLs, as
outlined below.
Summary of Site Risks
This Record of Decision is written for an operable unit action to
address the off-site contaminated groundwater plume. The RI
report includes a risk assessment, prepared by Reilly using the
Risk Assessment Guidance for Superfund and approved by EPA as a
portion of the RI report, that calculated the actual or potential
risks to human health and the environment that may result from
exposure to site contamination.
Because this action is the final action for groundwater < J
incorporates all previous remedial actions into its execution,
only risks calculated for exposure to groundwater will be
presented. Risks associated with exposure to onsite soil
contamination were summarized in the RODs for OU 2, 3, and 4.
Groundwater use in the area is currently restricted by the Marion
County Health Department (MCHD). As outlined below, the MCHD
restricts groundwater use in the area through an ordinance that
prohibits the installation of groundwater wells in the area
affected by the ordinance and requires that all well users
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properly abandon their groundwater wells in accordance with State
of Indiana well abandonment regulations.
The risk assessment determined that three chemicals in the
groundwater are of primary concern: benzene, pyridine and
pyridine derivatives, and ammonia (See Table 1). Other chemicals
that were detected in the groundwater are also of concern but
were not found at the same frequency or amounts as these listed
here. Concentrations of these chemicals in the groundwater have
resulted in the calculation of unacceptable risks to human health
and the environment posed by exposure.
Exposure Assessment
The exposure assessment conducted as a part of the RI concluded
that several media are impacted by site contaminants, and that
there are several potential exposure routes for contamination.
These routes of exposure were identified for both current and
future scenarios (as is commonly done in EPA risk assessments) so
that all potential pathways can be evaluated. The baseline risk
assessment computed risks from exposure to these contaminants
using the upper 95% confidence intervals of the arithmetic mean
of the Phase II and III sampling data concentrations of the above
contaminants. The use of the confidence intervals is suggested
in the Risk Assessment Guidance for Superfund and represents a'
conservative step towards assessing risks associated with
potential exposures. In some cases where sample results vary
widely or sample size is small, these confidence intervals may
exceed maximum detected concentrations.
Due to the proximity of the site to the surrounding neighborhood
and major streets, and its size, the following potential
receptors were identified in the risk assessment, and risks were
computed for their exposure.
Under the future-use scenario, off-site residents could
potentially be exposed through ingestion and dermal contact with
groundwater (if residents used wells for water supply for
drinking and other household uses). Future off-site industrial
workers could be at risk through inhalation of volatilized
contaminants from the groundwater (industrial water usage).
Toxicity Assessment
Benzene is classified as a known human carcinogen (Class A) and
has been associated with hematologic effects on humans as well as
anemia (decreased red blood cells), leukopenia (decreased white
blood cells) , and thrombocytopenia (decreased platelets) .
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Chronic exposure has been shown to cause pancytopenia (decrease
in all circulating cells) and aplastic anemia (failure to
manufacture blood cells) . Exposure by inhalation has been shown
to cause leukemia. Benzene has been shown to be a growth
inhibitor in utero; however, it has not been shown to be
teratogenic (causing birth defects). Animal studies have shown
preliminary evidence of carcinogenicity; a link to leukemia via
inhalation has also been suggested. Benzene has been shown to be
nonmutagenic (not causing mutations); benzene oxide, the presumed
initial metabolite of benzene, is mutagenic (causing mutations).
Limited data exists on the oral absorption of pyridine; data on
the pulmonary and dermal absorption of the chemical was not
located. Available evidence indicates that pyridine is well
absorbed rapidly from the GI tract and is not expected to
accumulate in the body. Available information from animal
testing does not suggest that lethality is a human health concern
for exposure to pyridine by inhalation or ingestion. The major
human health concern is for liver damage, based on recent studies
with laboratory rats. Other human health concerns include the
potential for neurologic effects and kidney effects. Pyridine
has been administered to mice and rats in order to evaluate the
potential carcinogenicity of pyridine. The studies have
concluded that pyridine did not produce increases in the
incidence of tumors with respect to controls. EPA has decided
that increased liver weight in female rats is the most sensitive
toxic endpoint.
Ammonia has been shown to cause deleterious effects in acute
exposures. Irritation of the eyes, nose, throat and chest are
associated with exposure to ammonia. Ingestion can cause
gastritis and corrosive esophagitis. Exposure to high
concentrations of ammonia gas can cause pulmonary edema or death.
Ammonia has also been shown to cause negative effects to the
respiratory tract, labored breathing, eye irritation,
inflammatory lung changes, and death to many animal species.
Both the Integrated Risk Information System (IRIS-1989) and the
Health Effects Assessment Summary Table (HEAST-1990) were used as
sources for this contaminant toxicity data.
Risk Assessment
The carcinogenic risks associated with exposure to benzene by
groundwater ingestion were computed for several potential
exposure scenarios (See Table 1). These include off-site
resident (5.5 x 10(-4)), off-site industrial worker (current
risk, 1.06 x 10(-6) for a quiescent scenario and 1.64 x 10(-5)
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for an aerated scenario (mixing of the water with associated
volatilization of the benzene into the breathing space)), off-
site industrial worker (future risk, using the upper 95%
confidence interval for the groundwater plume, 6.83 x 10 (-4) for
a quiescent scenario and 7.35 x 10(-4) for an aerated scenario).
The non-carcinogenic risks associated with exposure to pyridine,
pyridine derivatives, and ammonia by ingestion of groundwater,
were computed for the same exposure scenarios as were used for
the carcinogenic risks. Generally, total Hazard Indices (HI) are
used to calculate non-carcinogenic risks and must be below a
value of 1.0; otherwise CERCLA requires remedial action. Hazard
Indices exceeded the 1.0 trigger for scenarios such as the off-
site resident (HI=247), and off-site industrial worker (HI=277)
(See Table 1).
During the RI, it was determined that there was no significant
risk to the environment from site contamination. The absence of
a suitable habitat for wildlife and the absence of any
significant onsite surface water accumulations provided the
justification for this conclusion. By implementation of the
remedy in this ROD, impacts to the environment will also be
minimized or eliminated.
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, and the environment.
Description of Alternatives
The FFS identified four alternatives that could be used to
address threats and/or potential threats to human health and the
environment posed by the site. The alternatives evaluated are
presented below.
Under each of the alternatives, the existing perimeter
groundwater extraction system is assumed to be operating,
containing groundwater at the facility boundary. Also, each of
the alternatives contains a long-term groundwater quality
monitoring program to assess the effectiveness of each
alternative at cleaning up groundwater contamination in the OU 5
area.
The National Contingency Plan (NCP) requires that a no-action
alternative be discussed as a basis for comparison with other
-cleanup alternatives. As defined in the NCP, a no-action
alternative involving no action with no associated cost has been
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evaluated in the FFS for the site, which is slightly different
from the proposed Alternative 1, Natural Attenuation. Because
the primary cleanup component of the no action alternative is
natural attenuation, or the natural breakdown of contaminants in
the groundwater, Alternative 1 from the FFS is more accurately
characterized as natural attenuation for the purposes of this
Record of Decision.
The FFS also evaluated another alternative, Alternative 5 -
Provide Alternative Water Supply for Off-Site Users of
Groundwater. The FFS describes an aquifer ban imposed by the
Marion County Health Department (MCHD) in 1984. This aquifer ban
ordered private well water users to connect to city water and to
properly abandon and seal their private well. A survey was
conducted at that time to characterize resident's concerns
regarding industry in the area, in particular, Reilly Tar &
Chemical. This survey was updated in 1996 to provide information
regarding the effectiveness of the aquifer ban and to identify
any current users of the aquifer who would be affected by
groundwater contamination in the OU 5 area.
The results of this recent survey indicate that the aquifer ban
imposed by the MCHD is effective in preventing exposure to
groundwater contamination and contains provisions to allow the
MCHD to effectively prevent future exposure to contaminated
groundwater in the OU 5 area through implementation of the
aquifer ban. Therefore, Alternative 5 was not evaluated in the
FFS report as a potential remedial option.
Alternative 1: Natural Attenuateon(with long-term groundwater
monitoring)
This alternative involves natural attenuation and degradation of
the groundwater contamination to reduce contaminant
concentrations to acceptable levels. This alternative was
evaluated with two scenarios - one with current pumping rates for
the OU 1 groundwater extraction system and the off-site
industrial pumping wells, and one without off-site industrial
pumping. In the FFS, this alternative was called No Action.
Because the primary cleanup component of Alternative 1 is natural
attenuation, or the natural breakdown of contaminants in the
groundwater, it is more accurately characterized as natural
attenuation for the purposes of this Record of Decision.
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Estimated Capital Cost: $0
Estimated Annual Operation
and Maintenance Cost (15 years): $50,000
Estimated Timeframe to Implement: Immediate
Estimated Time to Achieve
Cleanup Levels: 1.5 to 16 years
(dependent on contaminant)
Alternative 2; Additional Extraction Wells Between OU 1 Wells
and Off-Site Industrial Production Wells
This alternative involves installing two additional extraction
wells at locations to the east/southeast of the Reilly property
where the off-site groundwater would take the longest time to
reach cleanup standards. The purpose of these additional wells
would be to decrease the time for the contaminants to be removed
from the aquifer and capture contaminants that would otherwise
enter off-site production wells.
Estimated Capital Cost: $1,490,000
Estimated Annual Operation
and Maintenance Cost (15 years): $331,000
Estimated Timeframe to Implement: 2 to 3 years
(including remedial design)
Estimated Time to Achieve
Cleanup Levels: 1.5 to 15 years
(dependent on contaminant)
Alternative 3; Increase Pumping Rates for the OU 1 Extraction
Wells
This alternative involves two additional extraction wells along
the eastern property boundary to supplement the existing
groundwater extraction system. The goal of the additional
extraction wells would be to increase the rate of capture of
contaminants and to attempt to recover contaminants that have
already migrated off-site.
Estimated Capital Cost: $855,000
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Estimated Annual Operation
and Maintenance Cost (15 years): $331,000
Estimated Timeframe to Implement: 2 to 3 years
(including remedial design)
Estimated Time to Achieve
Cleanup Levels: 1.25 to 15.25 years
(dependent on contaminant)
Alternative 4: Well Head Treatment at Off-Site Industrial
Production Wells
This alternative would include well head treatment for benzene at
an off-site industrial extraction well. The treatment would
consist of air stripping to remove contaminants with activated
carbon treatment for the treatment residuals. This alternative
would only address benzene at the well head and would not have
any impact on contaminants currently present throughout the OU 5
area.
Estimated Capital Cost: $243,500
Estimated Annual Operation
and Maintenance Cost (15 years): $100,000
Estimated Timeframe to Implement: 2 to 3 years
(including remedial design)
Estimated Time to Achieve
Cleanup Levels: Immediate (at well head only)
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES FOR OPERABLE
UNIT 5
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. Based on evaluation of the alternatives with respect
to these nine criteria, U.S. EPA has selected Alternative 1 -
Natural Attenuation (with Long-Term Groundwater Monitoring) as
the alternative for the cleanup for Operable Unit 5 at this Site.
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THRESHOLD CRITERIA
Protection of Human Health and the Environment
Addresses whether a remedy provides adequate protection of human
health and the environment and describes how risks posed through
each exposure pathway are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional
controls.
All of the alternatives are protective of human health and the
environment. All of the alternatives involve natural breakdown
of contaminants through time. Alternative 1 provides protection
from exposure to groundwater contamination primarily because
water users are prohibited from using the groundwater by order of
the MCHD which is considered an institutional control over the
groundwater that is in place at present and in the future.
Alternatives 2 and 3 utilize groundwater pumping to reduce the
volume of contaminants; however, according to results of
groundwater modeling, this does not accelerate the cleanup
timeframes. However, they would provide an additional off-site
control over easterly migration of contaminated groundwater from
the site. Several off-site industrial wells provide off-site
control at present. In addition, groundwater modeling was
performed for two scenarios, one with current off-site pumping
levels and.one without. Cleanup timeframes of the aquifer were
the same for both scenarios. Alternative 4 provides immediate
protection at the industrial wellhead from any of the risks
identified in this ROD for the off-site industrial worker,
however, it does not address contamination in the groundwater
plume throughout the OU 5 area.
Therefore, because all four alternatives provide protection from
exposure to contaminated groundwater, Alternatives 1, 2, and 3
are considered functionally equivalent with respect to this
threshold criterion and are superior to Alternative 4 because
they address the entire off-site groundwater plume.
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 ARARs. ARARs are
currently being met (regardless of the remedial alternative) for
benzene, total pyridines, and ammonia at the off-site industrial
production wells. Implementation of any of the four alternatives
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will provide for compliance with all water quality and industrial
discharge requirements. However, Alternatives 1, 2, and 3 are
superior to Alternative 4 because Alternative 4 only provides for
treatment at the wellhead for benzene, and does not achieve MCLs
for benzene or any of the other contaminants in the off-site
groundwater plume.
Therefore, it has been determined that Alternatives 1, 2, and 3 are
functionally equivalent with respect to this threshold criterion
and are superior to Alternative 4, because of their individual
ability to meet the ARARs appropriate to each alternative.
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.
Aquifer cleanup times are not sensitive to off-site industrial
pumping and contaminants are predicted to never reach Eagle Creek.
Alternatives 2, 3, and 4 will require additional equipment
maintenance than Alternative 1. Alternative 4 is not entirely
effective in the long term because it only addresses contamination
at the industrial wellhead and not throughout the off-site
contaminant plume.
Therefore, it has been determined that Alternatives 1, 2 and 3 are
functionally equivalent with respect to this balancing criterion
and are superior to Alternative 4.
Reduction of Toxicity, Mobility or Volume
Addresses the anticipated performance of the treatment technologies
a remedy may employ.
Natural attenuation and degradation is the principal treatment
process for the OU 5 area for all of the alternatives. This
process is irreversible, satisfies the statutory preference for
treatment and is predicted to completely destroy the contamination
throughout the entire OU 5 area. All of the alternatives have the
same benefit from the control on contaminant mobility provided by
the off-site industrial production wells as well as the elimination
of the source of the contamination to the OU 5 area by the OU 1
Groundwater Interim Remedial Measure (GWIRM) system. Alternative
4 differs from the others only at the off-site industrial wellhead
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where benzene is transferred from the groundwater to the air and,
if necessary, may be removed from the air stream using activated
carbon. Also, Alternative 4 does not address this criterion for
the entire groundwater plume, it only addresses the contamination
at the well head.
Therefore, it has been determined that Alternatives 1, 2, and 3 are
functionally equivalent with respect to this balancing criterion
and superior to Alternative 4 because of the contaminant reduction
capabilities throughout the off-site groundwater plume.
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.
There would be no additional risks posed to the community, remedial
workers, or the environment as a result of implementing any of the
alternatives. The time predicted to complete the remedial action
throughout the OU 5 area is the same for all of the alternatives
and is approximately 9-16 years. Alternative 1 can be implemented
immediately. Alternatives 2, 3, and 4 will require 2-3 years to
obtain an approved remedial design and complete the system
installation.
Therefore, it has been determined that Alternatives 1, 2, 3, and 4
are functionally equivalent with respect to this balancing
criterion.
Impl emen tabi 1 i ty
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.
Alternative 1 would pose no implementation problems as construction
is not required and the groundwater monitoring program, engineering
controls provided by the OU 1 GWIRM system, and the institutional
controls provided by the Marion County Health Department (MCHD) are
all currently in place. Additionally, the effectiveness of the
MCHD aquifer ban has been verified with a new neighborhood well
survey as previously reported. Alternative 4 will require
coordination with off-site industries, however, conventional
equipment and services are readily available. Alternative 2 would
be the most logistically difficult to implement and would involve-
pilot testing, permitting with the City of Indianapolis POTW, and
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purchasing or obtaining access to off-site property. Alternative
3 would pose the same implementability issues as Alternative 2
except off-site access will not be required.
Therefore, it has been determined that although Alternatives 1 and
3 are functionally equivalent with respect to this balancing
criterion and are superior to Alternatives 2 and 4 due to potential
difficulties with pilot testing, permitting for discharge of
extracted water, and access.
Cost
Included are capital costs, annual operation and maintenance costs
(assuming a 30 year time period) , and net present value of capital
and operation and maintenance costs.
The capital costs of Alternatives 1, 2, 3, and 4 are: $0 for
Alternative 1, $1,490,000 for Alternative 2, $855,000 for
Alternative 3, and $243,500 for Alternative 4. Operation and
maintenance costs for Alternative 1 total $750,000 for 15 years,
$1,500,000 for Alternative 2 for 15 years, $5,190,000 for
Alternative 3 for 15 years, and $5,190,000 for Alternative 4 for 15
years.
Therefore, based on analysis of the costs associated with all of
the alternatives analyzed in the FFS, it appears that Alternative
1 has the lowest capital cost and the lowest operation and
maintenance costs of the four alternatives.
MODIFYING CRITERIA
State Acceptance
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 the
opportunity to comment on technical decisions, and concurs with the
selection of Alternative 1 as the selected remedy for this operable
unit groundwater cleanup at the site.
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Community Acceptance
Addresses the public's general response to the remedial
alternatives and proposed plan.
Throughout the RI/FS at the site, community involvement has been
moderate. U.S. EPA has been accessible and responsive to community
concerns throughout the study. At the public meeting for the
proposed plan/ the majority, were in favor of Alternative 1 as the
most appropriate choice for the OU 5 cleanup. There were a
significant number of public comments received during the public
comment period, however, the overwhelming majority were also in
support of Alternative 1.
EPA has responded to substantive comments in a responsiveness
summary, which is attached to this ROD as Appendix A. •
In summation, Alternatives 1 and 3 fully satisfy the nine
evaluation criteria for the OU 5 area. The estimated time to
achieve cleanup levels under Alternative 1 is not significantly
different from the time it would take to achieve cleanup levels
under the other alternatives. Alternative 2 would be more
difficult to implement than Alternatives 1 and 3, given the need to
obtain access to off-site properties to install the necessary
components of the remedy and the difficulties of installing an
extraction system in a heavily industrialized area, while not
providing better long term performance. Alternative 4 would not be
effective in the long term because it only addresses contamination
at the industrial wellhead and does not address the off-site
groundwater contaminant plume. Alternative 4 would also be
difficult to implement due to the need to negotiate access
agreements with the off-site industries operating the off-site
industrial production wells.
Alternative 1 is more cost effective than Alternative 3, while
providing similar levels of protection to human health and the
environment. This alternative will meet the appropriate cleanup
standards in a timeframe that is similar to Alternative 3, while
providing no short term risks associated with remedy construction.
Therefore, the best balance among the four alternatives is
Alternative 1, Natural Attenuation (with Long Term Groundwater
Monitoring).
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SELECTED REMEDY
As was discussed in previous sections, EPA has chosen Alternative
1 - Natural Attenuation (with Long Term Groundwater Monitoring) as
the selected remedy. The FFS contains a description of this
alternative. In addition, U.S. EPA is finalizing the interim
action decision for groundwater made in the OU 1 ROD.
At the Reilly Site, the unconfined aquifer below the site is a
Class II aquifer which has been used in the past for drinking water
by residents bordering the site, and could potentially be used as
a drinking water source. Therefore, the cleanup objective for the
OU 5 area is to restore groundwater to drinking water quality for
future use and the remediation levels, as indicated below, are
MCLs.
«
The OU 1 GWIRM system has been providing engineering controls since
October 1994 and acts to prevent the additional degradation of
groundwater in the OU 5 area by preventing the migration of on-site
(OU 1) groundwater to off-site areas. Reilly is legally obligated,
through the consent decree for OU 1, to maintaining the integrity
of the GWIRM system and will continue to maintain, monitor, and
report on the system. The GWIRM system continues to be considered
as an engineering control for the site. The GWIRM system will be in
operation until the cleanup and performance standards listed in
Table 2 are met at the facility boundary.
The selection of Alternative 1, Natural Attenuation (with Long Term
Groundwater Monitoring for the OU 5 area, when combined with the
continued operation of the OU 1 GWIRM system will provide long term
protection to human health and the environment from exposure to
groundwater contamination from the Reilly site. The perimeter
groundwater extraction system, selected as an interim remedy for OU
1, is an integral component of the final groundwater cleanup for
the site and is being finalized through this action.
Through the RI/FS and the phased cleanup, the objective of TT.S. EPA
has been to protect human health and the environment from
groundwater contamination while addressing sources of contamination
on the Reilly site. The interim action selected in the OU 1 ROD
was designed to prevent further off-site migration of groundwater
contaminated by the Reilly site while onsite sources were addressed
and remediated.
The remedies selected in the RODs for OU 2, 3, and 4, were intended
to remediate sources of groundwater contamination located on the
Reilly site. Thermal desorption of four hot spot areas and the
stabilization of sludge with placement of a soil cover over a fifth
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source area was the objective of OU 2 and will mitigate the
contributions of these areas to the groundwater contamination
problem.
Placement of a permeable cover over the OU 3 area will reduce the
amount of contaminants leaching into the groundwater and the
application of soil vapor extraction over two OU 4 areas and the
placement of a concrete cover over a third OU 4 area will again,
reduce the contributions from these areas to groundwater
contamination.
The point of compliance for this action only, will be the property
boundary, as is defined on Figure 2. Any groundwater at the point
of compliance must meet the cleanup criteria mentioned above.
In determining the point of compliance for this final action, U.S.
EPA considered the following factors: there are multiple sources of
contamination on the Reilly site and through previous actions, U.S.
EPA has left waste in place; as mentioned below, the Reilly site is
subject to institutional controls, prohibiting the use of
groundwater under the site unless approved in advance by U.S. EPA;
the site is an active operating facility, regulated by RCRA,
producing specialty chemicals.
Therefore, U.S. EPA has determined that the groundwater
contamination at the site is caused by releases from several
distinct sources that are in close geographical proximity and has
considered the technical practicability of groundwater remediation
under the site. U.S. EPA has also considered the vulnerability and
future use of the groundwater and the likelihood of exposure in
determining that the groundwater problem at the site should be
addressed as a whole, rather than source by source. This is why
the point of compliance has been established at the property
boundary, as identified above.
In May 1984, the Marion County Health Department (MCHD) declared
the industrial area in the vicinity of Reilly to be a threa_ to the
safety of groundwater for use by humans for drinking and ordered
all of the private water well users identified in the area to
connect to the city water main and to properly abandon and seal
their private wells. The MCHD declared that the use of well water
in this area was a violation of the Code of the Health and Hospital
Corporation of Marion County, Chapter 18, Section 18-803. A review
of the MCHD files uncovered documentation regarding the 1984 survey
in the OU 5 area, the identification of the well users resulting
from the survey, and written directives from the MCHD to connect to
the Indianapolis water supply system and to properly seal and
abandon private wells.
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At the direction of U.S. EPA, the MCHD recanvassed the survey area
in August 1996. The survey results indicated that all properties
in the survey area were connected to city water and that no
existing wells were confirmed. Two residences in the Oak Park
Addition identified unusual features. Both of these residences are
connected to city water. A followup investigation shall be
conducted on these two residences to confirm that these features
are not old water wells. If they are identified as water wells,
Reilly shall work with the residences to properly abandon these
wells in accordance with all applicable regulations.
Groundwater flow and contaminant transport models were used to
support the detailed analysis of Alternatives 1, 2, and 3.
Alternative 1 was simulated with two scenarios; one with current
pumping rates for the OU 1 GWIRM system and the off-site industrial
pumping wells and one without off-site industrial pumping.
Alternative 1 involves natural attenuation and degradation of the
groundwater contamination to reduce contaminant concentrations to
acceptable levels. Alternative 1 will also include a groundwater
quality monitoring program for the OU 5 area.
The groundwater quality monitoring program will supplement the
existing water quality monitoring program which is currently
conducted on a quarterly basis. This monitoring program will be
utilized to evaluate the performance of Alternative 1 over time.
In the FFS, it is estimated that groundwater in the OU 5 area will
achieve cleanup standards in 1.5 to 16 years, depending on the
contaminant. The cleanup standards to be met at the point of
compliance for this action are listed in Table 2.
The remedy will be monitored on a continual basis over time to
ensure that the selected remedy continues to be protective. If the
off-site industrial water users modify their extraction rates
significantly, or discontinue groundwater extraction at any point
in the future, then the selected remedy shall be immediately
reevaluated by U.S EPA to determine if it continues to provide the
levels of protection to human health and the environment outlined
in this ROD. If it is determined by U.S. EPA that the remedy is no
longer protective, then U.S. EPA will take the appropriate steps
necessary to provide protection of human health and the
environment.
If the long term groundwater monitoring shows that contaminant
decay is not occurring at the rates predicted in the groundwater
modeling results presented in the FFS, then the selected remedy
shall be immediately reevaluated by U.S. EPA to determine if it
continues to provide the levels of protection to human health and
the environment outlined in this ROD. If it is determined by U.S.
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EPA that the remedy is no longer protective, then U.S. EPA will
take the appropriate steps necessary to provide protection of human
health and the environment.
Institutional controls currently in place at the site include a
control that prohibits Reilly from using the groundwater underlying
the property through ingestion or dermal contact. This control
allows Reilly to use the groundwater under the site for industrial
purposes (non-contact cooling water) only after obtaining the
express written approval of U.S. EPA, or any successor federal
governmental department or agency.
These controls shall continue in full force, prohibiting use of the
groundwater underlying the site, until the Reilly site is.deleted
from the National Priorities List, all remedial action cleanup and
performance standards have been met, and until such time as the
U.S. EPA issues a determination in writing or the Court rules to
either modify or terminate the restrictions in response to a
petition from the owner(s) of the property.
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.
Documentation of Significant Changes
EPA published a proposed plan for this operable unit action on
March 24, 1997, that proposed the selection of Alternative 1 -
Natural Attenuation (with Long Term Groundwater Monitoring) as the
final remedy for OU 5.
There were a significant number of public comments received during
the public comment period, however, the overwhelming majority were
in support of Alternative 1, and the remedy recommended in the
proposed plan was not changed.
STATUTORY DETERMINATIONS
U.S. EPA's primary responsibility at Superfund sites is to
undertake remedial actions that protect human health and the
environment. Section 121 of CERCLA has established several other
statutory requirements and preferences. These include the
requirement that the selected remedy, when completed, must comply
with all applicable, relevant and appropriate requirements
("ARARs") imposed by Federal and State environmental laws, unless
the invocation of a waiver is justified. The selected remedy must
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also provide overall effectiveness appropriate to its costs, and
use permanent solutions and alternative treatment technologies, or
resource recovery technologies, to the maximum extent practicable.
Finally, the statute establishes a preference for remedies which
employ treatment that significantly reduces the toxicity, mobility,
or volume of contaminants.
The selected remedy for the operable unit addressed by this ROD
will satisfy the statutory, requirements established in Section 121
of CERCLA, as amended by SARA, to protect human health and the
environment, will comply with ARARs (or provide grounds for
invoking a waiver), will provide overall effectiveness appropriate
to its costs, and will use permanent solutions and alternative
treatment technologies to the maximum extent practicable.
1. Protection of Human Health and the Environment
Implementation of the selected remedy will protect human health and
the environment because: (1) the contamination in the aquifer
beyond the boundary of the property owned by Reilly Industries,
Inc. does not currently affect human health or sensitive
environmental receptors, (2) the perimeter pump and treat system
established by the first operable unit action taken at the site
will prevent further contamination from migrating beyond the
boundary of the property owned by Reilly Industries, Inc., and (3)
the contamination now present in the aquifer outside that property
boundary is expected to diminish to the vanishing point over the
next sixteen years through processes of attenuation occurring
naturally in the affected aquifer.
Groundwater monitoring will be required to ensure that the expected
attenuation does, in fact, take place; and if it does not, U.S. EPA
retains authority to require additional measures to address
whatever contamination may remain, if necessary.
Institutional controls have already been imposed by the Marion
County Health Department which have already ensured *-v.at all
residents in the area are connected to an uncontaminated city water
supply and also that all wells in the affected aquifer have already
been sealed and abandoned in compliance with existing State law and
regulations. No unacceptable short term risks will be caused by
implementation of the remedy.
2 . Compliance with ARARs
The selected remedy will comply with all identified applicable or
relevant and appropriate federal requirements and with those State
or local requirements that are more stringent, unless a waiver is
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invoked pursuant to Section 121 (d) (4) (B) of CERCLA. The ARARs for
the selected remedy are listed below:
A. Federal ARAR s
Chemical-Specific Requirements
Chemical-specific ARARs regulate the release to the environment of
specific substances having certain chemical characteristics.
Chemical-specific ARARs typically determine the standard for
cleanup.
Resource Conservation and Recovery Act (RCRA)
The facility is an operating RCRA facility engaged in the
management of hazardous wastes; therefore, the RCRA statute and its
implementing regulations are applicable in some areas and relevant
in other areas for purposes of Corrective Action.
Section 3004(v) of the Solid Waste Disposal Act as amended by RCRA,
42 USC 6924(v) requires a RCRA facility like Reilly Industries,
Inc. to take corrective action beyond the facility boundary where
this is necessary to protect human health and the environment.
This requirement is applicable to this facility and will be
enforced by U.S. EPA when necessary to protect human health and the
environment.
The chemical-specific requirements of RCRA are also relevant and
appropriate. 40 CFR 141 requires that ground water used as
drinking water meet Maximum Contaminant Levels ("MCLs") for
contaminants of concern.
RCRA groundwater protection standards are codified at 264.94. That
regulation establishes the concentration levels which must be met
for contaminants of concern in site ground water.
Safe Drinking Water Act
40 CFR 141
Federal Drinking Water Standards promulgated under the Safe
Drinking Water Act ("SDWA") include both Maximum Contaminant Levels
("MCLs") and, to a certain extent, non-zero Maximum Contaminant
Level Goals ("MCLGs"), that are applicable to municipal drinking
water supplies servicing 25 or more people. At the Reilly Site,
MCLs and MCLGs are not applicable, but are relevant and
appropriate, because the unconfined aquifer below the site is a-
Class II aquifer which has been used in the past for drinking water
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by residents bordering the site, and could potentially be used as
a drinking water source.
The National Contingency Plan ("NCP") at 40 CFR 300.430
(e) (2) (I) (B) provides that MCLGs established under the Safe
Drinking Water Act that are set at levels above zero shall be
attained by remedial actions for ground waters that are current or
potential sources of drinking water. Groundwater monitoring wells
will be installed to ensure that the contribution to groundwater
contamination beyond the facility boundary has ceased. Existing
groundwater wells in the aquifer will also be monitored, and
additional wells may also be drilled and monitored, if necessary to
ensure compliance.
Location-Specific Requirements
Location-specific ARARs are those requirements that derive from the
physical nature of the site's location and features of the local
geology and hydrogeology such as wetlands and floodplains.
The physical nature of the site's location does not appear to
implicate any additional ARARs for this selected remedy beyond
those already identified above and below as specific to the
chemical composition of the hazardous substances addressed and
those specific to the action required by the selected remedy.
Action-Specific Requirements
OPERABLE UNIT 5 (OFF-SITE PLUME)
The remedy selected for OU 5 relies on processes of natural
attenuation in conjunction with actions already taken at the site
which include the installation of a perimeter pump and treat system
to isolate groundwater beneath the property owned by Reilly
Industries, Inc. from the surrounding aquifer (operable unit 1) as
well as actions to prevent the leaching of additional contaminants
to groundwater from contaminated soils on the Reilly property
(operable units 2, 3 and 4). Furthermore, the remedy selected
requires groundwater monitoring of the off-site plume to ensure
effectiveness of the selected remedy as well as continued operation
and maintenance of the pump and treat system already in place to
ensure that the corrective measure effectively isolates the
contamination in groundwater under the Reilly property from the
surrounding aquifer.
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The Federal and State ARARs for OU5 are presented below:
FEDERAL ARARs
Occupational Safety and Health Act
29 CFR 1910, 1926 and 1904
Resource Conservation and Recovery Act ("RCRA")
The Resource Conservation and Recovery Act ("RCRA") is applicable
at some areas of this site and relevant at other areas. The site
is an operating RCRA facility subject to Corrective Action and
these RCRA Corrective Action obligations have been integrated into
the ongoing Superfund investigation and remediation program for
this facility, pursuant to a Consent Order amendment signed and
issued in September of 1992. Section 3004(v) of the Solid Waste
Disposal Act as amended by RCRA, 42 USC 6924 (v) requires a RCRA
facility like Reilly Industries, Inc. to take corrective action
beyond the facility boundary where this is necessary to protect
human health and the environment. This requirement is applicable
to this facility and will be enforced by U.S. EPA when necessary to
protect human health and the environment.
The chemical-specific requirements of RCRA are also relevant and
appropriate. 40 CFR 141 requires that ground water used as
drinking water meet Maximum Contaminant Levels ("MCLs") for
contaminants of concern.
RCRA groundwater protection standards are codified at 264.94. That
regulation establishes the concentration levels which must be met
for contaminants of concern in site ground water.
Because some of the contamination present in soils on the site will
remain in place and closure of the facility, when it takes place
will not be clean closure, the facility will be subject to
requirements for closure of a landfill. The requirritients
considered both relevant and appropriate in this area include, but
are not necessarily limited to:
40 CFR 264.117-120
These regulations require 30-year post-closure care and
groundwater monitoring.
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Post-Closure Care
40 CFR 264.117(a)
The requirements for post-closure care are set forth at 40 CFR
264.117 through 40 CFR 264.120. The Regional Administrator may
revise the length of the post-closure care period pursuant to 40
CFR 264.117(a) (2) (I) if he finds that a reduced period is
sufficient to protect human health and the environment; or extend
the length of the post-closure care period pursuant to 40 CFR
264.117(a)(2)(ii) if he finds that the extended period is necessary
to protect human health and the environment.
40 CFR 264.117
The remedy selected for this site requires U.S. EPA to restrict
post-closure use of this property as necessary to prevent damage to
the cover systems.
NPDES Permit Regulations
Because the final remedy for groundwater at the site requires
continued operation of the pump and treatment system required by
operable unit 1, the ARARs listed in the ROD for that operable unit
continue to apply. Because the remedy involves discharge to an
off-site Publicly Owned Treatment Works ("POTW"), these ARARs
include the National Pollutant Discharge Elimination System
("NPDES") requirement codified at 40 CFR 122.42(b). This requires
notification to the issuing authority of a re-evaluation of POTW
pretreatment standards (n.b., if the local POTW does not have a
local limitation for a particular pollutant to be discharged from
this Superfund site/ then it must develop such a limitation to
prevent interference, pass-through, or inhibition, from occurring
as a result of the discharge).
NPDES National Pretreatment Standards, codified at 40 CFR 403.5
require that discharge to a POTW not result in interference, pass-
through of pollutants to receiving water or contamination of sewage
sludge. This requirement is also applicable to the remedial
actions selected for this site.
STATE ARARs Identified for OU5
The State of Indiana has identified the following regulations as
ARARs with which the selected remedy for OU 5 must comply:
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The Indiana Department of Environmental Management ("IDEM") has
developed water quality standards to prevent degradation of State
waters. These standards are set forth at:
IAC Article 2, Rule 1-7: Indiana Water Quality Standards
327 IAC Article 5: NPDES Permits1
327 IAC Article 8; Rules 1 and 2: Public Water Supply
The waters in the aquifer at the site and all waters discharged
therefrom in the course of remedial actions taken at the site must
comply with the State standards referenced above.
Because these actions include reinjection, State ARARs for
underground injection of pollutants apply here. The applicable
regulations are set forth at:
327 IAC 5-4-2
State ARARs for pretreatment include 327 IAC 5-11, limiting
discharges to POTWs, and 327 IAC 5-13, regarding the applicability
of the Industrial Waste Pretreatment Program.
3. Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative in
achieving environmental benefit in proportion to the cost required
to achieve that benefit. The FS discusses the costs of the
alternatives considered, and a comparison of those costs is
presented in the section of this ROD summarizing the analysis of
the relevant criterion, above.
The selected remedy for this operable unit action is cost effective
because it provides the greatest overall effectiveness
proportionate to the cost when compared to the other alteinatives
evaluated, the net present worth cost of the selected remedy is
estimated to be $750,000.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource recovery to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be used in a
See footnote 1, above.
31
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cost-effective manner at this site. Of those alternatives that are
protective of human health and the environment and that comply with
ARARs, U.S. EPA has determined that the selected remedy provides
the best balance in terms of long term effectiveness and
permanence, reduction of toxicity, mobility, or volume of
contaminants, short term effectiveness, implementability, and cost,
taking into consideration State and community acceptance.
5. Preference for Treatment as a Principal Element
The statutory preference for selection of remedial actions in which
treatment is a principal element cannot be satisfied by this
decision; however, EPA and IDEM believe that the selected remedy
will satisfy the statutory requirements specified in Section 121 of
SARA to protect human health and the environment, attain ARARs (or
provide grounds for invoking a waiver) and utilize permanent
solutions to the maximum extent practicable.
32
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
REILLY TAR & CHEMICAL SITE
INDIANAPOLIS, INDIANA
UPDATE #3
OPERABLE UNIT #5
JUNE 23, 1997
NO. DATE
1 08/10/94
2 09/15/94
3 10/00/94
4 10/00/94
5 10/17/94
6 11/15/94
7 11/28/94
AUTHOR
Bratina, J.,
Reilly
Industries,
Inc.
Giordano, M.,
ENSR
Smith, P.,
CH2M Hill
Novak, D.,
U.S. EPA
Bratina, J.,
Reilly
Industries,
Inc.
RECIPIENT
Novak, D.,
U.S. EPA
Novak, D.,
U.S. EPA
ENSR Consulting U.S. EPA
& Engineering
ENSR Consulting U.S. EPA
& Engineering
Novak, D.,
U.S. EPA
Bratina, J.,
Reilly
Industries,
Inc.
Novak, D.,
U.S. EPA
TITLE/DESCRIPTION PAGES
Letter Re: Schedule 2
for Operable Unit #5
(OU#5) Feasibility
Study (FS)
Letter re: BNSR's 11
Response to U.S. EPA's
Comments on the "Human
Health Risk Assessment"
for the Reilly Tar Site
Human Health Risk 186
Assessment: Volume I
of II (Text, Tables
and Figures)
Human Health Risk 586
Assessment (Volume II
of II (Appendices)
Letter re: FS Scope of 1
Work for OU#5
Letter re: U.S. EPA's 2
Response to Reilly
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04/05/95
10 12/12/95
Indiana
Department of
Natural
Resources
Kress, T.,
Reilly
Industries,
Inc.
Public
Novak, D.,
U.S. EPA
Hater Well Drilling 18
Regulations
Letter re: Submittal of
Focused Feasibility
Study (FFS)
Reilly Tar & Chemical AR
i Update #3
NO.
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
11 01/31/96
August Mack
Environmental
Inc.
U.S. EPA
12
13
14
15
16
17
18
02/22/96 Nash, T.,
U.S. EPA/
ORC
03/05/96 Hansen, S.,
IDEM
03/18/96 Barnett, C.,
CH2M Hill
05/01/96 Novak, D.,
U.S. EPA
05/17/96 U.S. EPA
06/13/96 Kress, T.,
U.S. EPA
06/17/96 Novak, D. ,
U.S. EPA
Novak, D. ,
U.S. EPA
Novak, D.,
U.S. EPA
Novak, D. ,
U.S. EPA
Kress, T. ,
Reilly
Industries,
Inc.
File
Novak, D.,
U.S. EPA
Kress, T.,
Reilly
Industries,
Inc.
Revised FFS for OU#5: 222
Off-Site Groundwater
Contamination
Memorandum re: ORC 3
Comments on the FS
for OU#5
Letter re: IDEM's 2
Comments on the FFS
for OU#5
Letter re: CH2M's 7
Comments on the FFS
for OU#5
Letter re: U.S. BPA's 11
Comments on the FS
Report for OU#5
Memorandum re: Summary 17
of May 17, 1996 Meeting
with Marion County Health
Department
Letter re: Request for a 1
Time Extension for the
Preparation of the Revised
FS Report for OU#5
Letter Re: U.S. EPA's 1
Approval of a Time
Extension for Submission
of the Revised FS Report
for OU#5
19 06/19/96 Kress, T.,
Novak, D.,
Letter re: Reilly's
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Reilly
Industries,
Inc.
U.S. EPA
Request for a Three Week
Extension for Preperation
of the Revised PS Report
for OU#5
20
07/01/96
21
07/10/96
22
07/11/96
Weinreb, G. ,
August Mack
Environmental
Inc.
Novak, D.,
U.S. EPA
Haitjema, H.,
August Mack
Environmental
Inc.
Novak, D.,
U.S. EPA
Kress, T.,
Reilly
Industries,
Inc.
Novak, D.,
U.S. EPA
Letter re: AME's Request
for a Time Extension for
Submittal of the Revised
FFS Report for OU#5
Letter re: U.S. EPA's
Approval of an Extension
for Resubmission of
Revised FS Report
Letter re: Revised
FFS Report for OU#5
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Reilly Tar & Chemical AR
Update #3
Page 3
NO. DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
23 08/05/96 Barnett, C.. Novak, D.
CH2M Hill U.S. EPA
Letter re: CH2M's
Comments on the Revised
FFS for OU#5
24 08/13/96 Hansen, S.,
IDEM
Novak, D.
U.S. EPA
Letter re: IDEM's
Comments on the Revised
FFS for OU#5
25 08/14/96 Novak, D.,
U.S. EPA
Kress, T.,
Reilly
Industries,
Inc.
Letter re: U.S. EPA's
Comments on the Revised
FFS Report for OU#5
26
08/23/96
Kress, T.,
Reilly
Industries,
Inc.
Novak, D.,
U.S. EPA
Letter re: Reilly's
Request for Meeting with
U.S. EPA
27
09/12/96
Weinreb, G.,
August Mack
Environmental
Inc.
Novak, D.,
U.S. EPA
Letter re: Documentation
of Issues Discussed and
Agreements Reached at the
September 14, 1996 Meeting
Concerning the Revised
FFS for OU#5
28
09/13/96
Heinreb, G.,
August Mack
Environmental
Inc.
Novak, D.,
U.S. EPA
Letter re: AME's
Response to U.S. BPA's
August 14, 1996 Letter
Concerning the Revised
FFS for OU#5
19
29
10/01/96
Barnett, C.,
CH2M Hill
30 10/24/96 Hansen, S.,
IDEM
31 11/19/96
Novak, D.,
U.S. EPA
Novak, D.,
U.S. EPA
Novak, D.,
U.S. EPA
Kress, T.,
Reilly
Industries,
Inc.
Letter re: CH2M-S
Response to U.S. EPA 's
Comments on the Revised
FFS Report for OU5
Letter re: IDEM's
Comments on the Revised
FFS for OU5 w/ Attached
Letter Concerning TCLP
Analytical Methods for
Phase II
Letter re: U.S. BPA's
Comments to AME's Response
to U.S. EPA's September 13,
1996 Letter Concerning the
FS for OU#5
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32 00/00/97 U.S. EPA/ORC
File
Memorandum re: ORC
Comments on the Draft
Record of Decision for
OU#5 at the Reilly Tar
Site
( Reilly Tar & Chemical AR
Update #3
Page 4
NO. DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
33 02/06/97 Barnett, C., Novak, D.,
CH2M Hill U.S. EPA
Letter re: CH2M's
Comments on the PRP
Response to U.S. EPA's
Comments on the Revised
PFS for OU#5
34 02/07/97 Hansen, S.,
IDEM
Novak, D.,
U.S. EPA
Letter re: IDEM'a
Comments on the Ground-
Water Well Survey for the
PFS for OU#5
35 02/07/97 Hansen, S.,
IDEM
Novak, D.,
U.S. EPA
Letter re: IDEM's
Comments on the Revised
FFS for OU#5
36 03/00/97 U.S. EPA
Public
37 03/26/97 Allison Engine U.S. EPA
Company
38 03/26/97 U.S. EPA
File
Fact Sheet: Proposed
Plan for Remedial Action
(OU#5) at the Reilly Tar
Superfund Site
Public Comment (OU#5):
Allison Engine Company's
Statement in Support of
Proposed U.S. EPA and
IDEM Recommendation to
Implement Alternative 1
Transcript of Proceed-
ings re: Proposed Plan
for Remedial Action for
OU#5
43
39
04/16/97
Various
Citizens
Novak, D.,
U.S. EPA/
OPA
Public Comments re: the
Proposed Plan Received
January 12 - April 16,
1997
59
40
04/21/97
Favero, D.,
Novak, D.,
Letter re: Favero's
-------
Favero
Geosciences
U.S. EPA
Comments on the Proposed
Plan for Remedial Action
for OU#5
41 04/22/97 Kress, T.,
Reilly
Industries,
Inc.
42 04/22/97 Ellis, P.,
Allison
Engine
43
06/16/97
Might, K.,
August Mack
Environmental
Inc.
Novak, D.,
U.S. EPA/
OPA
Novak, D.,
U.S. EPA
Novak, D.,
U.S. EPA
Letter re: Reilly"s 2
Response to Allison
Engine Company's Statement
at the March 26, 1997
Public Meeting
Letter re: Allison 2
Engine's Concern About
Health Effects on Employees
from Reilly Contaminants
Letter re: Final 15
Addendum to the Revised
FFS for OU#5
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Reilly Tar & Chemical AR
Update #3
Page 5
NO. DATE
44
06/18/97
AUTHOR
Kleiman, J.
U.S. EPA/
RCRA
RECIPIENT
Novak, D..
U.S. EPA
TITLE/DESCRIPTION
Letter re: RCRA's
Review of the Draft
Record of Decision
for OtJ#5 at the Reilly
Tar and Chemical Site
PAGES
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APPENDIX A
Reilly Tar & Chemical
Indianapolis, Indiana
Responsiveness Summary
I. Responsiveness Summary Overview
In accordance with CERCLA Section 117, a public comment period was held from March 24,
1997 to April 22, 1997, to allow interested parties to comment on the United States
Environmental Protection Agency's (EPA's) Feasibility Study and Proposed Plan for the Reilly
Tar & Chemical Superfund site. At a March 26, 1997 public meeting, EPA and the Indiana
Department of Environmental Management (IDEM) officials presented the Proposed Plan for
remediation at the Reilly Tar & Chemical site, answered questions and accepted comments from
the public. Written comments were also received through the mail.
II. Background of Community Concern
The Reilly Tar & Chemical site operated from the early 1920's to 1972 as a wood treatment
facility. From 1941 to the present, Reilly has been in operation producing specialty chemicals.
The earliest complaint about odors and disposal practices at the site was in 1955, which
referenced the fact that a chemical produced at Reilly (alpha picoline) had been found in nearby
residential wells. In 1964, three contaminants from Reilly were found in off-site groundwater
samples. In 1987, 60,000 gallons of waste fuel, containing mostly pyridine and pyridine
derivatives, benzene, xylene, and toluene, was accidentally spilled on the northern portion of the
site.
Community involvement has increased over the years as more people became aware of activities
at the site. Residents and interested citizens have formed several environmental activist groups to
deal with problems associated with the Reilly site. These include a neighborhood group that
meets quarterly with Reilly to address ongoing problems at the plant, known as the Neighborhood
Involvement Committee, or NIC.
HI. EPA's Proposed Remedy and its Relation to the Final ROD
In a Proposed Plan that was issued on March 24, 1997, EPA proposed Alternative 1 - Natural
Attenuation (with Long-Term Groundwater Monitoring). This remedy was based on the
information presented in the FS, prepared by Reilly and approved by EPA. During the public
comment period, EPA received numerous comments regarding the selection of Alternative 1,
most of which supported the proposal
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Almost all of the comments received during the public comment period were received from a
group of students at the Lawrence Central High School. EPA will attempt to address the issues
arising from these comments and demonstrate how they were factored into the final remedy
selection for OU 5 at the Reilly site.
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 general comments concerning site cleanup.
1. Comments were raised that indicated that Alternative 1 was the best remedy because it was the
cheapest.
EPA response 1: Remedial alternatives are initially screened in the Feasibility Study using three
criteria: effectiveness, implementability and cost. If an alternative fails any of these three, then it
is excluded from further consideration. Remaining alternatives then go through a detailed
screening in the Feasibility Study where their merits are compared to EPA's nine evaluation
criteria. During the comparison, alternatives are evaluated against one another and the one that
provides the best balance of the nine criteria is selected. Cost is one of the nine criteria, but not
the only one. EPA does not select an alternative simply because it is cheaper-EPA selects the
most effective alternative for site cleanup.
2. Comments were raised indicating that the nearby industry should be closed by EPA, which
would benefit the groundwater cleanup.
EPA response 2: Closing the nearby industry would not benefit the groundwater cleanup. Reilly
has contaminated the groundwater and, under this action and others, is responsible for cleanup
activities. The nearby industry is not contributing to the overall groundwater contamination
problem as identified by the remedial investigation. It is, therefore, not EPA's intent to close
down industry as a result of this remedial action.
3. Comments were raised indicating that the City of Indianapolis should pay for the g, oundwater
cleanup.
EPA response 3: As indicated above, the owner/operator is considered a potentially responsible
party under CERCLA, responsible for the contamination problem at the site and is responsible for
paying for the cleanup.
4. Comments were raised that expressed concern that the OU 1 extraction system is making the
problem worse by drawing contamination into the off-site area and that its use should be
discontinued.
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EPA response 4: The OU 1 system is designed to prevent contaminants from moving into the off-
site area. This system is not designed to cleanup the off-site area; however, because it is
removing the source of contamination to the off-site area, the OU 1 system will assist in the off-
site cleanup. Turning this system off would make the off-site situation worse and extend the time
for off-site cleanup.
5. Comments were raised stating that local industry should not use groundwater in the future and
should switch to city water.
EPA response 5: The nearby industry is aware of the groundwater contamination problem. Local
industrial groundwater use for nondrinking water purposes does not present a risk to the
community or to the industrial workers. No one is drinking the affected groundwater, which
poses the highest risk from contamination.
B. Comments in support of the selection of Alternative 1 for cleanup.
6. Comments were raised in support of the selection of Alternative 1 because it is a natural
process, works immediately, and has a low cost.
EPA response 6: EPA appreciates the support for the proposed remedy. EPA agrees that
Alternative 1 is the most appropriate remedy for this action.
7. Comments were raised in support of Alternative 1, as it would remove contaminants
immediately from the aquifer.
EPA response 7: This assumption is incorrect. None of the alternatives will remove the
contaminants from the aquifer immediately-groundwater cleanup takes time.
C. Comments raising questions regarding the long term effectiveness of Alternative 1.
8. Comments were raised asking what would happen if the groundwater cleanup did not progress
at the rate presented in the FS modeling.
EPA response 8: EPA nas written a contingency into the ROD that requires that the remedy
performance be monitored over time. If cleanup is not progressing as modeled, then the cleanup
decision will be revisited and additional actions will be taken to accelerate the cleanup. Under the
Superfund law, EPA is also required to revisit and reassess remedial actions every five years, to
assure that the selected remedial action is continuing to provide protection to human health and
the environment.
9. Comments were raised indicating that EPA is doing nothing by selecting this remedial option
and will allow the groundwater contamination to move to the Blue Lake area.
EPA response 9: Natural attenuation with monitoring is an active cleanup option. Long term
monitoring of groundwater will provide for continual updates on the progress of the cleanup. As
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was presented in the FFS, groundwater extraction would not accelerate the cleanup times for
groundwater. Therefore, because the different remedies discussed in the FFS provided the same
levels of effectiveness, EPA selected the remedy that would provide the least amount of
disruption to the surrounding area. Also, the OU 1 groundwater extraction system will be in
operation until all groundwater meets the appropriate cleanup levels. The off-site industrial
extraction wells are currently blocking the easterly movement of off-site groundwater. Modeling
results from the FS indicate similar timeframes for cleanup if these wells discontinue pumping.
10. Comments were raised stating that Alternative 1 was leaving contaminants in the
groundwater that other alternatives might address.
EPA response 10: None of the alternatives remove contaminants from the aquifer immediately.
Through continual monitoring, EPA will evaluate the performance of the selected remedy and
make appropriate adjustments over time.
11. Comments were raised stating that if you try to remediate the groundwater, you will worsen
the problem
EPA response 11: Only through active remediation can the groundwater contamination problem
be addressed and corrected. EPA has taken steps to prevent additional contamination from
entering the off-site area, and will monitor the aquifer in the off-site area while the processes of
natural attenuation clean the aquifer..
D. Comments on other alternatives in the FS or ways Alternative 1 could be augmented.
12. Comments were raised stating that EPA should add more on-site extraction wells to speed up
the cleanup.
EPA response 12: As indicated above, increasing the rate of groundwater extraction does not
decrease the cleanup time. Reilly is installing additional on-site wells under OU 1 to provide
further proof of containment at the property boundary. The purpose of OU 1 is to isolate the site
from further groundwater contamination, which will accelerate the off-site cleanup by removing
the contamination source.
13. Comments were raised stating that EPA should inject chemicals into the aquifer to accelerate
the natural contaminant breakdown.
EPA response 13: Bioremediation is a proven treatment method for groundwater cleanup,
however, in this situation it would not provide the levels of effectiveness needed to accelerate the
cleanup. Strict controls on the treatment area are needed in order to implement bioremediation.
At the Reilly site, the hydrogeologic conditions do not allow for the proper control measures to
be put into place at the treatment area in order for the injected chemicals to work. The limitations
on obtaining access and the implementability of this method preclude its use here.
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14. Comments were raised stating that Alternative 3 would accelerate the cleanup through
additional extraction.
EPA response 14: As is stated above, the groundwater modeling contained in the FFS indicated
that groundwater cleanup was not accelerated by groundwater extraction, rather, the cleanup
timeframe was similar to that of natural attenuation.
15. Comments were raised indicating support for Alternative 1 because the other alternatives
would take 2-3 years to implement, would encounter off-site access problems, and would require
excessive pump maintenance.
EPA response 15: EPA agrees with these conclusions and this information was factored into .
EPA's final cleanup decision.
16. Comments were raised indicating that Alternative 2 was inconvenient to area residents due to
access requirements for implementation.
EPA response 16: EPA agrees with these conclusions and this information was factored into
EPA's final cleanup decision.
17. Comments were raised indicating that NPDES requirements for the off-site industries did not
address Reilly contaminants.
EPA response 17: EPA contacted IDEM's Water Management Section, which is responsible for
setting industry discharge requirements. IDEM is aware of the Reilly contamination problem and
has indicated that the current requirements for industrial discharge are adequate for protection of
human health and the environment. If these standards change in the future, the discharge
requirements will be revisited.
18. Comments were raised which indicated that if Reilly contamination caused problems for the
surrounding area, that Reilly should be legally and financially responsible for correcting any
problems.
EPA response 18: Reilly is responsible under CERCLA for correcting any site related
contamination problems emanating from their facility and if any problems arise in the future, EPA
will assist in ensuring that they are addressed by Reilly correctly and promptly. EPA's role is to
ensure protection of human health and the environment.
These 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, located at the Indianapolis Public Library, 48 East St. Claire, Indianapolis, Indiana.
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 Indianapolis Public Library.
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