PB97-964109
EPA/541/R-97/100
January 1998
EPA Superfund
Record of Decision:
Marion (Bragg) Dump Site, OU 2 & 3
Marion, IN
9/30/1997
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Responsiveness Summary, Record of Decision
Marion (Bragg) Dump Site
Grant County, Indiana
Operable Units 2 and 3
I. Overview
The U.S. Environmental Protection Agency (USEPA) issued a Pro-
posed. Plan in June 1997 for Operable Units (OUs) 2 and 3 for the
Marion (Bragg) Dump site (the Site), Grant County, Indiana, a
former municipal dump. The Proposed Plan, the reports covering
the periodic monitoring that had been performed between February
1990 and September 1996, and other documents were placed in the
repository at the Marion Public Library. A notice of the avail-
ability of the documents was published in the Marion Chrpnicle-
Tribune on June 27, 1997. The public comment period lasted 60
days, including the extension granted, and ended on August 27,
1997. A public meeting was held on July 16, 1997.
OU 2 is the groundwater at the Site and OU 3 is the on-site pond;
OU 1 is the surface soils and the on-site wastes. An interim
remedy had been selected for OU 1 in a 1987 Record of Decision
(ROD). This remedy has been implemented. The major components
of this remedy are: common fill was placed on the waste disposal
area to provide for proper surface water run-off, a compacted
clay cap was installed in the waste disposal area, the cap was
covered with topsoil, and a vegetative layer was established to
minimize erosion; rip-rap was installed along part of the river
bank to the south to stabilize the bank; a perimeter fence was
installed to minimize unauthorized access to the Site; new moni-
toring wells were installed on the Site and the old ones were
abandoned; and deed restrictions were obtained in the Consent De-
cree of April 1991 that protect the constructed elements of the
remedy and prevent the future use of groundwater from the shallow
aquifer on the Site. Also, monitoring of the grtruidwater, the
on-site and the large off-site ponds, and the Mitiiissinewa River
have been carried out since the beginning of the on-site work in
order to obtain the additional data needed for the selection of a
remedy for OUs 2 vind 3.
"No action" has been selected for the remedy for OU 2 and OU 3.
USEPA has determined that no further action is necessary to en-
sure protection of human health and the environment.
Some of comments that have been received have objected to the
selection of a no action remedy for OUs 2 and 3. However, no
information has been furnished to persuade USEPA to change to
another remedy.
II. Background on Community Involvement
The remedial investigation (RI) and feasibility study (FS) re-
ports, which included a proposed plan, and a fact sheet announc-
Marioo (Brau) OUi 2 & 3 ROD. Responsivenen Summary 9/97
-------
ing USEPA's recommended alternative for OU 1 were released for
public comment in August 1987. The RI and FS reports were made
available to the public in the repository at the Marion Library.
A public comment period lasting 5 1/2 weeks was held that ended
on September 11, 1987. A public meeting was held on August 19,
1987. A Responsiveness Summary that addressed the comments re-
ceived from various potentially responsible parties (no others
commented) was included with the Record of Decision that was
issued for OU 1 on September 30, 1987.
Prior to the construction of the remedy selected for OU 1, com-
munity interest in the Site increased. While the remedy was
being constructed, several availability sessions were held in
order to keep the community informed about the work going on.
One of these was a visit to the Site during which those attending
the session were escorted along the western fence and the work
going on was described. Also, USEPA participated in two meetings
with the community that were organized by the U.S. congressman
representing the district.
When the proposed Consent Decree was lodged with the court in
1990, a 30-day comment period was provided, which was announced
in a notice in the Federal Register, during which the public was
given the opportunity to comment on the proposed settlement to
implement the remedy. This was extended an additional 30 days in
response to requests for an extension. A fact sheet was issued
iii August 1990 concerning the proposed Consent Decree. An
availability session was held on August 21, 1990, which had been
announced with a notice in the local newspaper on August 16,
1990. The comments received were responded to when the motion to
enter the Consent Decree was filed with the court.
The release of the Proposed Plan for OUs 2 and 3 and the accom-
panying opportunities for public participation are described
above. At the July 16, 1997 public meeting, representatives from
USEPA and the Indiana Department of .nvironmental Management
(IDEM) answered questions about the Site.
Ill. Summaries of Comments Received and USEPA's Responses
This section summarizes the comments received during the comment
period, both written and oral. The administrative record con-
tains a copy of the transcript of the July 16, 1997 public meet-
ing as well as all of the written comments.
1. Comment. Jeff Symmes, West Lafayette, Indiana, at the public
meeting requested an extension of the comment period for at least
an additional 30 days; originally the period was to run from June
27, 1997 through July 28, 1997. He stated that the letters (ap-
parently meaning the fact sheet that was sent to the people on
the mailing list) were, not sent out until June 30, 1997. He also
stated'that there were two boxes of documents that were not
mailed to the repository till July 1, 1997.
Marion (Bnu) OUs 2 A 3 ROD. RapoMivtneu Summary 2 9/97
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Record of Decision Declaration
Site Name and Location
Marion (Bragg) Dump Site
Grant County, Indiana
Operable Units 2 and 3
Statement of Basis and Purpose
This decision document presents the selected remedial action for
Operable Units (OUs) 2 and 3 for the Marion (Bragg) Dump site
(the Site), Grant County, Indiana, chosen in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended (CERCIA), and, to the extent practicable,
the National Contingency Plan. This decision is based on the ad-
ministrative record file for the site.
Description of the Remedy
r
"No action" has been selected for the remedy for OUs 2 and 3 for
the Marion (Bragg) Dump site, a former municipal dump. The major
components of the remedy for OU 1, which have already been imple-
mented, are: common fill was placed on the waste disposal area to
provide for proper surface water run-off, a compacted clay cap
was installed in the waste disposal area to prevent air emis-
sions, to prevent contact with the wastes, and to minimize infil-
tration of precipitation, the cap was covered with topsoil, which
included matting in areas of possible exposure to 100-year flood-
waters, and a vegetative layer was established to minimize ero-
sion; rip-rap was installed along part of the river bank to the
south to stabilize the bank in order to minimize possible expo-
sure of wastes; a perimeter fence was installed to minimize un-
authorized access to the Site; new monitoring wells were in-
stalled on the Site and the old ones were abandoned; and deed
restrictions were obtained in the Consent Decree of April 1991
that protect the constructed elements of the remedy and prevent
the future use of groundwater from the shallow aquifer on the
Site. Also, monitoring of the gioundwater, the on-site and the
large off-site ponds, and the Mississinewa River have been car-
ried out since the beginning of the on-site work in order to ob-
tain the additional data needed for the selection of a remedy for
OUs 2 and 3. A deed restriction is presently being sought under
the 1991 Consent Decree for the shallow groundwater under the
cemetery to the west of the Site to prevent the future use of
this groundwater since groundwater from the Site may flow under a
small part of this cemetery before entering the Mississinewa
River.
Under the "no action" remedy, monitoring of the groundwater, the
on-site and large off-site ponds, and the river will continue in
accordance with the requirements of the 1991 Consent Decree.
Marion (Brass) Dump. ROD Dedmuon. OUs 2 A J 9/47
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Declaration Statement
No further remedial action is necessary to ensure protection of
human health and the environment.
Because the remedies for OUs 1, 2, and 3 will result in hazardous
substances remaining on-site above health-based levels, a review
of the remediation taken is required every five years dating from
the commencement of remedial action in 1989 to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
The U.S. Environmental Protection Agency has determined that its
response at the Site is complete. Therefore, the Site now quali-
fies for inclusion on the Construction Completion List.
State Concurrence
The State of Indiana has indicated that it concurs with the se-
lected remedy and is preparing a letter of concurrence. The con-
currence is premised upon the '-expectation that the deed restric-
tion that is being sought under the 1991 Consent Decree for the
cemetery property to the west, which will prevent the use of the
groundwater in the shallow aquifer there, will be obtained. This
addresses IDEM's concern over the risk to human health and the
environment that might exist if this groundwater is available for
use.
Date William E. Mun6
Super fund Division Director
Marion (Bnsa) Dump. ROD DedMioo. OUs 2 * 3 <"V7
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Record of Decision Summary
Marion (Bragg) Dump Site
Operable Units 2 and 3
I. Site Description
The Marion (Bragg) Dump site (the Site) is located just outside
the southeastern city limits of Marion, Indiana. The dump
occupies approximately 45 acres of the 72-acre Site along the
bank of the Mississinewa River. The northern end of the Site is
within the estimated 100-year flood plain.
The Site is bordered on the north and east by the Mississinewa
River (see Figure 1). A cemetery is located along the western
border and private property lies south of the Site. A residence
and two asphalt plants, Marion Paving Company and Dobson Con-
struction Company, were located on the southwest corner of the
site during the time of the remedial investigation. During the
remedial action for'Operable "Unit (OU) 1, Marion Paving moved and
the residence was torn down. A large (15 acre) pond is in the
center of the property. This on-site pond is occasionally used
for recreational purposes, such as boating and fishing. At one
time the on-site pond received discharges associated with air
pollution control operations at the Marion Paving Company. A
large pond of similar size is located off-site, adjacent to the
southern Site boundary.
II. Site History, Enforcement Activities, and Current Status
The Site was used as a sand and gravel quarry from 1935 until
approximately 1961. During the period from 1949 through 1970,
Radio Corporation of America (RCA) leased and used portions of
the Site for industrial refuse disposal. Concurrently, during
the period from 1957 to 1975, Bragg Construction leased a sepa-
rate portion of the Site which it used for disposal of municipal
wastes. Periodic inspections by the Indiana State Board of
Health (ISBH) indicated that operations at the dump were contin-
ually conducted in an unacceptable manner. ISBH specifically
noted the disposal of hazardous or prohibited wastes including
acetone, plasticizers, lacquer thinners, and enamels. Drummed
wastes were allegedly emptied from the drums and "worked" into
the other wastes with a bulldozer. Other typical violations
included lack of daily cover, placing wastes in standing water
(pond encroachment), and burning refuse. In 1975 Bragg Construc-
tion stopped operating the landfill. The landfill was covered
with a sandy/silty material and seeded. The landfill was never
formally closed under the auspices of ISBH.
In 1975, Waste Reduction Systems, a division of Decatur Salvage,
Inc., constructed a transfer station on the premises in order to
transfer solid wastes to an approved landfill. The transfer sta-
tion was closed in 1977. In January 1980, ISBH issued a letter
Marion (Bragg) Dump. ROD Sumnary
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stating that the transfer station had been closed in an accept-
able manner.
In September 1983 the Marion (Bragg) Dump was placed on the
National Priorities List (NPL). A remedial investigation (RI)
and a feasibility study (FS) were conducted under the authoriza-
tion of the U.S. Environmental Protection Agency (USEPA), begin-
ning in 1985. The reports for both were issued in August 1987.
Following a public meeting and a public comment period on the FS
report, USEPA issued a Record of Decision (ROD) on September 30,
1987 for an interim remedial action that would address the sur-
face soils and on-site wastes (OU 1).
In August 1987, special notice letters were issued to those that
USEPA had determined were potentially responsible parties (PRPs).
USEPA began negotiations with a number of these PRPs that result-
ed in a mixed funding settlement contained in a Consent Decree.
This Consent Decree was entered in April 1991. In this settle-
ment, the Generator Defendants (six of the PRPs) were to design
and construct the remedy and conduct the investigations and moni-
toring and the City Defendant. (City of Marion, Indiana) was to
maintain the Site. A second Consent Decree was entered in March
1997 under which five PRPs agreed to pay a portion of the past
costs.
The remedial design began in March 1989. During the remedial
action (RA) that was performed primarily during 1990 and 1991,
Marion Paving Company moved off the Site, and therefore its dis-
charge to the on-site pond was eliminated; the residence located
next to Marion Paving was torn down; common fill was placed on
the waste disposal area to provide for proper surface water run-
off; a compacted clay cap was installed in the waste disposal
area to prevent air emissions, to prevent contact with the
wastes, and to minimize infiltration of precipitation; the cap
was covered with topsoil, which included matting in areas of
possible exrrsure to 100-year floodwaters, and a vegetative layer
was established to minimize erosion; rip-rap was installed along
part of the river bank to the south to stabilize the bank in
order to minimize possible exposure of wastes; a perimeter fence
was installed to minimize unauthorized access to the Site; and
new monitoring wells were installed on the Site and the old ones
were abandoned. The installation of this cover system modified
the stratigraphy at the Site that is described below.
III. Highlights of Community Participation
The RI and FS reports,, which included a proposed plan, and a fact
sheet announcing USEPA's recommended alternative for OU 1 were
released for public comment in August 1987. The RI and FS re-
ports were made available to the public in the repository at the
Marion Library. A 5 1/2 week long public comment period was held
that ended on September 11, 1987. A public meeting was held on
August 19, 1987. Only comments from potentially responsible par-
ties were received during this comment period. A Responsiveness
Marion (Bragg) Dump, ROD Summary
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Summary that addressed these comments was included with the Rec-
ord of Decision that was issued for OU 1 on September 30, 1987.
Prior to the construction of the remedy selected for OU 1, some
members.of the community became interested in the Site. While
the remedy was being constructed, several availability sessions
were held in order to keep the community informed about the work
going on. One of these was a visit to the Site during which
those attending the session were escorted along the western fence
and given a description of the work going on. Also, USEPA par-
ticipated in two meetings with the community that were arranged
by the U.S. congressman representing the district.
The Proposed Plan for OUs 2 and 3 was released to the public in
June 1997 and this, the reports covering the periodic monitoring
that had been performed between February 1990 and September 1996,
and other documents were placed in the repository at the Marion
Public Library. The notice of the availability of the documents
was published in the Marion Chronicle-Tribune on June 27, 1997.
The public comment period was initially set to run from June 27,
1997 through July 28, 1997, but it was subsequently extended to
run through August 27, 1997, as a result of a request for an ex-
tension. A public meeting was held on July 16, 1997, at which
representatives from USEPA and the Indiana Department of Environ-
mental Management (IDEM) answered questions about the Site. Re-
sponses to the comments received during the comment period are
included in the Responsiveness Summary that is a part of this
Record of Decision. This decision document presents the selected
alternative for OUs 2 and 3 for the Marion (Bragg) Dump site
chosen in accordance with the Comprehensive Environmental Re-
sponse, Compensation, and Liability Act of 1980, as amended
(CERCLA), and, to the extent practicable, the National Contin-
gency Plan. The remedy decision for the Site is based on the
administrative record.
IV. Scope and Role of These Operable Units
In the ROD issued in 1987 at the conclusion of the feasibility
study, USEPA identified three operable units: OU 1 was the sur-
face soils and the on-site wastes; OU 2 was the jroundwater; and
OU 3 was the on-site pond. An interim remedy was selected only
for OU 1 in the 1987 ROD. Selections of remedies for OU 2 and OU
3 were deferred until additional data concerning the risks asso-
ciated with the on-site pond and with the discharge of ground-
water to the Mississinewa River could be obtained. Doing this
permitted USEPA to immediately address the problems associated
with possible contact with the contamination in the surface soils
and the on-site wastes and with the continual leaching of contam-
ination from these areas into the groundwater. Also, the added
data on the groundwater, the river, and the on-site pond that was
considered to be necessary in order to properly determine what,
if anything, needed to be done regarding these issues could be
obtained.. The effects of the source control measures being im-
plemented for OU 1 would also be taken into account before reme-
Harion (Bragg) Dump. ROD Summary
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dies for OUs 2 and 3 were selected.
The remedy selected in the 1987 ROD has been implemented. In
addition to the actions described above, deed restrictions were
obtained in the Consent Decree of April 1991 that protect the
constructed elements of the remedy and prevent the future use of
groundwater from the shallow aquifer on the Site. Also, monitor-
ing of the groundwater, the on-site and the large off-site ponds,
and the Mississinewa River have been carried out since the begin-
ning of the on-site work in order to obtain additional data on
the contamination in the on-site pond and on the effects of the
discharge of the groundwater to the Mississinewa River., Monitor-
ing will continue to be done after this Record of Decision for
OUs 2 and 3 is issued. Additionally, institutional controls pre-
venting the use of the shallow groundwater under the cemetery
west of the Site are presently being sought.
V. Site Characteristics and Summary of Site Risks
The stratigraphy at the Marion (Bragg) Dump at the time of the
remedial investigation consisted of landfill wastes (0-32 feet
thick) over outwash deposits (6-64 feet thick) , a glacial till
(54 to 63 feet thick), and bedrock, the surface of which was 89
to 125 feet below ground surface. It was estimated that the dump
contains approximately 1.1 million cubic yards of waste. At
least 4 percent of this is believed to be perennially saturated
in the upper aquifer. The saturated areas are to the east, west,
and north of the pond. South of the pond, a water filled gravel
pit was allegedly filled with demolition debris..
Outwash deposits (sands and gravel) constitute the upper aquifer,
which also extends into the wastes. This unconfined water table
aquifer is 18 to 42 feet thick. The average hydraulic conductiv-
ity was estimated as 4.27 x 10T2 cm/sec. The gradient in this
aquifer is toward the Mississinewa River on both sides 6f the
river. The Mississinewa River is a hydraulic barrier, causing
the groundwater beneath the site to discharge to the rtver, with-
out allowing flow to pass beyond the river. The Mississinewa
River receives groundwater discharges from both sides of the
river and upward from the bottom.
The on-site and the large off-site ponds are hydraulically con-
nected to the groundwater. The presence of the on-site and the
large off-site ponds creates a hydraulic anomaly in that water
flows from this off-site pond, through the aquifer, and into the
on-site pond from the south. The on-site pond discharges radi-
ally from its west, north and east sides, with the water then
entering the Mississinewa River.
The outwash deposits are underlain by a very low permeability
glacial till. This till is approximately 54 to 63 feet thick.
The hydraulic conductivity ranges from 1.0 x 10"7 cm/sec to 2.88
x 10"ff cm/'sec. This till layer is considered a confining unit.
Marion (Bragg) Dump. ROD Summary 4 ' 1/97
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The glacial till layer is underlain by. limestone bedrock. The
thickness of this layer is uncertain, but it was first encoun-
tered at 88 feet below ground surface. This bedrock layer
constitutes a second aquifer. This confined aquifer provides an
upward vertical water gradient through the glacial till.
During the remedial investigation, the groundwater was investi-
gated by sampling 4 off-site background monitoring wells, three
of which were on the opposite side of the river and one of which
was upgradient of the Site, 13-on-site monitoring wells, 2 on-
site monitoring wells designated as leachate wells (which actual-
ly functioned as groundwater wells inside the waste boundaries),
and 13 off-site water supply wells. Several of the on-site moni-
toring wells, although near the waste boundaries, were actually
installed through wastes. The groundwater in the upper aquifer
at the Site was found to contain organic and inorganic contami-
nants at concentrations above background levels; however, the
number and concentrations of contaminants were relatively low.
The organics that were found most frequently were benzene, tri-
chloroethene, and bis(2-ethylhexyl)phthalate. Most of the heavy
metals were detected only once in the groundwater at the Site;
these detections were generally below the maximum contaminant
levels (MCLs), which are presented here as points of reference,
where available, but above the fresh water aquatic life criteria.
Arsenic was an exception. Its concentrations were above the MCL
in a few samples, and it was detected frequently at lower concen-
trations.
In the public health evaluation done for the RI, in the scenario
used that considered the groundwater in the shallow aquifer at
the Site as a possible drinking water source (the Site being used
as a recreational area), the maximum estimated excess lifetime
cancer risk exceeded 10"4 due to arsenic. (The USEPA has estab-
lished the carcinogenic risk range of 10~4 to 10"s as the accept-
able level for exposures to potentially carcinogenic substances.)
Without arsenic, the maximum risk was estimated to be less than
10"6. The hazard index for noncarcinogenic effects was less than
one, the point at which there may be a level of concern for po-
tential noncarcinogenic health effects. Other parameters for the
groundwater that were at levels that might be of some concern
were chemical oxygen demand (COD) and ammonia concentrations;
there are no drinking water standards for these parameters.
Also during the RI, the on-site and large off-site ponds and the
river were sampled. (Background samples were also obtained from
three small off-site ponds on the property south of the land-
fill.) The only sample from the on-site and large off-site ponds
that exceeded water quality criteria was one that represented a
leachate seep that discharged directly into the on-site pond.
With the installation of the landfill cap, this leachate seep was
eliminated.
For the scenarios evaluated concerning use of the two large
ponds, the carcinogenic risks were not above the 10"6 point of
Marion (Bragg) Dump. ROD nummary
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departure and the hazard indexes were less than one.
Pond sediments contained several inorganic constituents, phthal-
ates, and low levels of polycyclic aromatic hydrocarbons (PAHs).
As discussed in the ROD for OU 1, comparison of the sediment re-
sults to a database for inorganics from the Great Lakes Harbor
sediments resulted in only the sediment location at the leachate
seep being a location of concern. (This database provides rel-
ative concentration ranges for comparing non-polluted, moderately
polluted, and heavily polluted sediments.)
The river did not generally shpw signs of being impacted by the
substances on the target compound list (TCL) and target analyte
list (TAL), the lists of substances usually analyzed for at
Superfund sites, during the time of the remedial investigation.
Other water quality indicators were also analyzed for. The COD
did not vary significantly between upstream, near-site, and down-
stream points. Ammonia was detected above water quality criteria
in two samples, but both were taken in areas where the river flow
at the time may have been impeded.
No human health risk was estimated for contact with the water in
the' Mississinewa River during the RI since only one sample with a
slightly elevated (compared to background) sodium concentration
was obtained. However, consideration of the amount of dilution
that the river water provided for the groundwater discharge to
the river indicated that under a low-flow situation there was a
potential risk to the river due to arsenic and ammonia. Because
of this, USEPA decided that more data was needed before making a
recommendation for the ponds and the groundwater.
As stated above, several of the groundwater monitoring wells on
the Site that had been used during the RI had been installed
through wastes. To eliminate the possibility of the groundwater
being contaminated by the wastes in the immediate vicinity of the
wells, the on-site and "leachate" monitoring wells were abandoned
during the remedial action and new downgradient ones were in-
stalled along the edges of the wastes by the river; two new back-
ground monitoring wells (wells MB-9 and MB-10) were also in-
stalled. The locations of these wells are shown on Figure 1.
One of the wells (MB-8) was installed through wastes since the
edge of the wastes was very close to the river bank at this loca-
tion, but special efforts were taken to minimize any effects from
the wastes around the well. All the wells were installed in the
upper aquifer, with some being installed at the water table (the
shallow wells) and the others being installed near the bottom of
this upper aquifer (the deep wells) ; at these wells the aquifer
was in the neighborhood of 10 to 25 feet thick. Because of the
limitations on the locations that could be used for the back-
ground monitoring wells at the Site, one (well MB-9) was in-
stalled very close to the wastes. Both of these wells were in-
stalled at the water table.
Beginning in February 1990, samples of groundwater, river (and
Marion (Bragg) Dun?. ROD Sumnary 6 »/?7
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creek) water, and pond water have been collected and analyzed
semiannually for the TCL volatile organic compounds (VOCs) and
semivolatile organic compounds (SVOC) and TAL substances and in-
dicator parameters suggested by the state's landfill regulations.
In the quarters following the semiannual sampling, samples of the
groundwater have been obtained and analyzed for the indicator pa-
rameters (total suspended solids (TSS), COD, ammonia, and chlo-
ride) . Reports have been submitted to the USEPA and IDEM .with
the results of these samplings. Selected results for a few pa-
rameters are presented in Table 1 for river and creek and pond
samples and in Table 2 for groundwater samples for the semiannual
sampling events through September 1996. One point to note about
the sampling results is that for a specific location in the
groundwater or the ponds, there are generally some fluctuations
in the concentrations with time; in thn case of the river and
creek, the concentrations sometimes change significantly all
along the river from one sampling event to the next because of
outside (upstream) influences. The data for the downgradient
groundwater wells and the on-site pond, which do show concentra-
tions for many substances that are greater than the background
concentrations, indicate generally a decrease in these concentra-
tio.ns with time.
In the groundwater samples taken from the new wells, volatile
organic compounds (VOCs) are found in wells MB-1 and MB-2, the
wells along the western boundary toward the north. Vinyl chlo-
ride, trichloroethene, total 1,2-dichloroethene, and benzene con-
sistently have been detected in these wells. Arsenic concentra-
tions have also been found at levels substantially above back-
ground in wells MB-2, MB-6, MB-7, and MB-8 and at lower levels in
other wells. Well MB-6 has had the highest levels of arsenic,
which have decreased since 1990. COD and sodium levels also
appear to have decreased in almost all of the downgradient wells
since 1990. The ammonia levels appear to have decreased or re-
mained essentially unchanged in the downgradient wells since
1990.
In the two ponds that are being monitored, ammonia, arsenic, and
VOCs have generally not been detected. Chloride and sodium con-
centrations in the on-site pond are generally higher than those
in the off-site pond; both have generally been decreasing in the
on-site pond. The sodium concentrations have been below the DWEL
guidance level of 20,000 ng/I in the last four sampling events
(DWEL is the drinking water equivalent level and is a lifetime
exposure concentration that is considered protective of adverse,
non-cancer health effects assuming all of the exposure to a con-
taminant is from a drinking water source). The chloride concen-
trations have always been about an order of magnitude below the
secondary maximum contaminant level (SMCL) of 250 mg/1 (SMCL are
unenforceable federal guidelines regarding taste, odor, color,
and certain other non-aesthetic effects of drinking water).
In the sampling of the Mississinewa River and Lugar Creek, VOCs
have not been detected and there have been only occasional de-
Marion (Bragg) Dump. ROD Summary 7 9/97
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tects of bis(2-ethylhexyl)phthalate, which may be a laboratory
contaminant, at low concentrations. (The creek has been sampled
so that if there are any unusual sampling results in the river,
it can be determined if they might have been caused by something
coming from the creek, which enters the river opposite the Site
and downstream of the upstream monitoring point; the creek sam-
ples also provide background information.) Arsenic has not been
detected in the river during the last four sampling events at de-
tection levels as low as 2.3 M9/1- Ammonia generally has been a
non-detect in the river; during the last four sampling events
there was only one ammonia detection in the river. Except in the
August 1990 sampling, there do not appear to be any trends with
position in the COD concentrations in the river. Generally there
do not appear to be any trends with position in the chloride and
sodium concentrations in the river either, but there are a couple
of instances when there have been indications of increases as one
goes downstream; since usually there is no trend with position in
these concentrations, it cannot be concluded that the sodium and
chloride in the groundwater were the causes of the increases. As
indicated above, nothing can be said about trends with time in
the river because of upstream influences.
During the August 1990 sampling event, sediment samples were
taken from the river and creek at the same locations that were
used for water samples. No VOCs were reported for the sediment
samples. Thirteen TCL semivolatile organic compounds were de-
tected in the 6 sediment samples, all at concentrations below the
contract required quantitation limit levels that a laboratory
must be able to routinely and reliably detect and quantitate;
some of the detections were in samples from the two background
locations. The detection frequencies ranged from 1 out of 6 to 4
out of 6. Bis(2-ethylhexyl)phthalate and di-n-butylphthalate
were the most frequently detected SVOCs. A number of PAHs were
detected in the sediment samples. The sample from location SW-3
contained the widest variety and highest concentrations of TCL
SVOCs, a number of them being PAHs. However, PAHs weretnot iden-
tified in any of the groundwater, river water, or pond water
samples during that sampling event or any other sampling event
through February 1992, except for one detection in a background
groundwater well. A number of TAL metals were detected in the
sediment samples as one would expect (many metals are naturally
occurring). The arsenic, beryllium, cobalt, lead, and zinc
concentrations were all estimated values below the contract re-
quired detection limits. (These are J-qualified concentrations,
which means that there is some uncertainty in the reported con-
centrations, but hot in the identity of the chemical, usually
because the concentrations are below the what the laboratory is
required to detect or quantitate. The J qualifier is the most
commonly encountered data qualifier in Superfund data packages,
except, possibly, for the U qualifier. The U qualifier means the
material was analyzed for but was not detected at the associated
numerical value). Cyanide was not detected in any samples. The
river sediment TAL metals concentrations appeared to be similar
in samples collected from upstream, nearsite, and downstream
Marion (Bragg) Dump. ROD Summary 8 ' i/»7
-------
sampling locations.
In October 1989 the Central Regional Laboratory of USEPA Region 5
conducted an instream biological assessment of the water quality
in the Mississinewa River near the Site. USEPA's Standard Oper-
ating Procedures for conducting rapid assessments of. fish using
the ecoregion approach were used to evaluate the biotic integrity
of the fish community based on Karr's index of biotic integrity.
The study was conducted during normal flow conditions. Three
stations were located in the river, one upstream, one opposite
the Site, and one downstream, and two stations were located in
Lugar Creek. Because of the poor biotic integrity of the river,
the reference station was selected from a composite of "least
impacted" stations of similar sized rivers from the Eastern Corn
Belt Plain ecoregion. The Index of Biotic Integrity (IBI) was
used to compare the different locations. For tne river loca-
tions, the upstream and downstream stations had IBI ratings of
"poor" and the nearsite station was rated "fair". In the report
for the study, it was stated that no significant environmental
impact was attributable to the Site.
f
In the 1987 ROD for OU 1, additional studies were indicated that
consisted of fish bioassay work for the river, the on-site pond,
and the large off-site pond and general toxicity studies for the
river. The purpose of these studies was to fully evaluate the
possible effects of the site groundwater on these surface waters
and the aquatic environment in these waters after the implementa-
tion of the OU 1 remedy. When the Consent Decree for implement-
ing the remedial action for OU 1 and the remedial action plan
(RAP) attached to it were developed, it was agreed that the ad-
ditional studies would be implemented in a phased approach so
that the more complex fish bioassay and toxicity studies would be
conducted only if the water quality and sediment samplings de-
tected levels of bioaccumulative contaminants associated with the
site groundwater that were exceeding water quality standards in
the r?"er and the on-site pond. The RAP includes decision trees
that were created to trigger the performance of the additional
studies when certain requirements were met. As discussed in this
ROD, evaluations of the results of the samplings and analyses of
river water, river sediments, groundwater, and water from the two
large ponds have not demonstrated significant impacts on the
surface waters. As a result, there has not been a need for the
additional studies. Given the trends in the monitoring data
collected since the OU 1 remedy was implemented, USEPA no longer
believes that these studies are or will be necessary. USEPA does
not expect that such studies would result in new information
relevant to the impacts of any releases from the Site.
As mentioned earlier, the Consent Decree that was negotiated for
conducting the remedial design, remedial action, and operation
and maintenance for OU 1 contained a deed restriction that in-
cludes prohibiting the installation of shallow drinking water
wells on the Site. This is in the form of a covenant running
with the land that is to be binding upon all persons who acquire
Marion (Bragg} Dump, ROD Summary 9 9/97
-------
any interest in the Site, and it was signed by the owners of the
Site. The covenant and the restrictions under it were granted
for the benefit of and shall be enforceable by the Marion-Bragg
Generator Group, the group of defendants who performed the remed-
ial action and remedial design and are performing the continuing
Site sampling. The strip of land between the waste boundary and
the river is part of this property and therefore drinking water
wells are now prohibited there. This strip of land is narrow; in
the southeast corner of the Site it consists only of the fairly
steep river bank. Much of this strip of land lies within the
100-year floodplain. This strip of land is in a remote location
with limited accessibility and would only be useful to someone
making use of the rest of the Site. However there are restric-
tions on the use of the rest of the Site included in the covenant
running with the land that bar any use of the land that may
threaten the effectiveness, protectiveness, or integrity of the
work that was performed during the remedial action. It is for
these reasons that USEPA has determined that that limited portion
of the shallow aquifer lying under the strip of land between the
waste boundary and the river is not a future source of drinking
water and consequently drinking water standards, are not relevant
and appropriate requirements for the Site. It must also be
remembered that even though these site conditions preclude the
use of the groundwater here, institutional controls have been
'implemented which prevent groundwater from this aquifer under
both the waste management area and this narrow strip of land from
being used. The only risk estimated during the RI that exceeded
the USEPA acceptable risk range was that for the use of the
groundwater as a possible drinking water source in a recreational
use scenario. With the institutional controls that have been
established, this is no longer a realistic scenario.
Also, an institutional control is presently being sought for the
shallow groundwater under the cemetery to the west of the Site to
prevent the'future use of this groundwater. Some of the ground-
water from the Site may flow under the northern part of this cem-
etery property before it enters the river, and this prohibition
of the use of the groundwater there will further ensure the pro-
tection of human health.
In summary, the monitoring that has been performed since 1990 has
not demonstrated any impacts on the water quality of the Missis -
sinewa River. The two substances of primary concern in the
groundwater that might adversely affect the river are arsenic and
ammonia. Dissolved arsenic has not been detected in the river
samples. The MCL and the acute and chronic aquatic criteria for
arsenic are all significantly above the detection limit for ar-
senic. Ammonia has been detected very infrequently at low con-
centrations, but these detections are not necessarily attributa-
ble to the groundwater from the Site since there are some sources
of ammonia that are due to natural causes. The one detection of
ammonia in the river during the last four sampling events did
result in a slight exceedance of the chronic aquatic criteria but
the acute aquatic criteria was not exceeded.
Marion (Bragg) Dump. ROD Summary
-------
Similarly, the monitoring has not demonstrated any problems with
the water in the on-site pond. Arsenic, ammonia, and VOCs have
generally not been detected, and the concentrations of sodium and
chloride, which are indicators of contamination, have generally
been decreasing. The reports on the water quality conditions for
the last four semiannual samplings have not shown applicable
water quality criteria being exceeded in this pond.
VI. Description of the "No Action" Alternative
The "no action" alternative is the selected alternative for the
Site for OU 2 and OU 3. The groundwater at the Site poses no
current or future risk to human health or the environment be-
cause: 1) contaminant levels have been low over most of the plume
and are generally decreasing; 2) site-related contaminants have
not materially affected the concentrations in the adjacent Mis-
sissinewa River; 3) applicable water quality criteria have not
been reported as having been exceeded within the past two years
in the on-site pond or the large off-site pond; 4) there are no
current users of the groundwater at the Site or in the northeast
corner of the cemetery to the west; and, 5) future use of the
groundwater at the Site is precluded by the conditions at the
Site and by existing institutional controls, and future use of
groundwater in the northeast corner of the cemetery to the west
is unlikely because of its location, and an institutional control
is being sought for the prevention of the use of this ground-
water. Since the future use of the land is as a landfill, there
is no reason to assume that future wells may be drilled into the
landfill to furnish a potable water supply, and there are insti-
tutional controls in place to maintain this restriction. Even if
an action were selected to restore the groundwater for use as a
potable water supply, the National Contingency Plan states that
the cleanup levels established to do this would only have to be
attained beyond the edge of the waste management area, not be-
neath the landfill wastes.
In this selected alternative, no additional remedies will be
carried out at the Site. This ROD is intended.as the final ROD
for the Site. The remedial work performed for OU 1 must be main-
tained under the requirements of the 1991 Consent Decree, which
will provide some assurances that the dump will not likely impose
an effect on the surface waters; no impact has been seen so far.
Monitoring of the groundwater, river water, and the on-site pond
will continue for an indefinite period in accordance with the re-
quirements contained in the 1991 Consent Decree, which are based
upon the 1987 ROD. The monitoring will be extensive enough and
will continue long enough to ensure that contamination from the
wastes does not become a detriment to the river or the on-site
pond.
Marion (Bragg) Dump. ROD Summary 11
-------
Table 1. Selected Results, River (and Creek) and Ponds
A. Result* for February 1990
Substance
M/l except as noted
Benzene
1.2-dichloroethene (total)
trichloroethene
vinyl chloride
bis(2-ethylhexyl )phthalate
•rtenic (dis.)
aeriua (dis.)
iron (dis.)
Mngenese (dis.)
sodius (dis.)
•amis-nitrogen. a0/l
COD, eo/l
chloride, sig/l
River (SW-5 is Upstreee)) end
SU-1
10U
3.9U
52.2J
10.8J
23.9
10600
1.0L
SOL
27
91-2
10U
3.0U
67.6J
20.14
31.0
10400
1.0L
SOL
27
SU-3
10U
3.0U
S7.9J
'•P
16.14
12400
1.0L
SOL
28
SU-4
10U
3.0U
S9.6J
4.0U
21.2
13900
1.0L
SOL
29
Creek
-------
Table 1 (cont.). Selected Results, River (and Creek) and Ponds
D. Results for August 1991
Substance
M/l except as noted
benzene
1,2-dichloroethene (total)
triehloroethene
vinyl chloride
»is(2-ethylhexyl )phthalste
arsenic (dis.)
barius (dis.)
iron (dis.)
Mnganese (dis.)
sodiua (dis.)
aBBBnia-nitrogen, ao/l
ceo, MO/I
chloride, asj/l
River (91-5 is Upstream) and Creek (SW-6)
SU-1
10U
S.OU
91 -6J
39.6J
7.3J
4S700
0.2
73
SO
SU-2
10U
S.OU
89.4J
20.8J
5.4J
42100
0.1
76
SO
SU-3
10U
S.OU
90.6J
12.SJ
9.6J
46600
0.085
82
SO
SU-4
2J
S.OUJ
as.oj
27. 1J
3.9J
42500
0.17
84
55
SU-S
18UI
S.OU
93. 7 J
110
14.4J
41700
0.18
91
60
SU-6
2J
S.OUJ
71. 1J
10. OU
32.0
24800
0.14
46
45
On-site Pond
PW-1
10U
22J
S.OU
108J
10. OU
1.0U
31300
0.5L
40
25
PU-2
9J
10U
S.OUJ
211
14.6J
249
30300
0.5L
29
30
Off -site Pond
PU-3
10U
10U
S.OU
B1.4J
1430
753
11300
O.SL
20U
15
PU-4
10U
10U
S.OU
40. 4J
20.8J
1.3J
10800
O.SL
20U
5
E. Results for February (SU) end June (PU) 1992
Substance
•a/ 1 except es noted
benzene
1,2-dichloroethene (total)
trichloroethene
vinyl chloride
bis(2-ethylhexyl )phthelete
arsenic (dis.)
bariua (dis.)
iron (dis.)
aanganese (dis.)
sodiua (dis.)
anaonia-nitrogen, «g/l
COO. no/I
chloride, ng/l
River (SU-5 is Upstressi) and Creek (SU-6)
SU-1
10U
3.0U
70.4J
23.8J
22.3
24300
O.SL
20U
40
SU-2
10U
S.OU
67.9J
20. U
20.7
20300
O.SL
120
40
SU-3
•.
17U
S.OU
71 .SJ
25.7J
22.2
23200
O.SL
22
42
SU-4
10U
S.OU
70.5J
201. J
21.4
22200
0-.5L
20U
40
SU-5
10U
S.OU
69.3J
19.0U
21.4
21500
O.SL
77
SO
SU-6
10U
S.OU
55.7J
23 .8J
89.4
23100
O.SL
20U
SU
On-site Pond
PU-t
10U
10U
10U
10U
S2J
S.OU
150
21. OU
2.0UJ
26200
0.5
20U
21
PU-2
10U
19
U
10U
10U
S.OU
17M
21 .OU
82.3R
26000R
0.5U
20U
21
Off -site Pond
PU-3
10U
10U
10U
10U
10U
S.6J
21.2
21 .OU
2.0U
10100
O.SU
20U
13
PU-4
10U
10U
10U
10U
14U
S.OU
20.8
21. OU
2.0U
9950
O.SU
20U
12
F. Results for
1992
Substance
«g/l except as noted
benzene
1.2-dichloroethene (total)
trichloroethene
vinyl chloride
bis(2-ethylhexyl)phthalate
arsenic (dis.)
bariun (dis.)
iron (dis.)
Manganese (dis.)
sodiua (dis.)
annonia-nitrogen. mg/l
COD. ng/l
chloride, ng/l
River (SU-5 is Unstress)) end Creek (SU-6)
SU-1
10U
10U
10U
10U
10U
4.0U
54.4
46.0U
8.9
9270J
O.SU
20
19
SU-2
10U
10U
10U
10U
10U
4.0U
76.4J
56.8J
6.7
9460J
O.SU
20
19
SU-3
10U
10U
10U
10U
10U
4.0U
66.3J
46.8J
6.8
9440J
O.SU
20
19
SU-4
10U
10U
10U
10U
10U
4.0U
76.8J
76.8J
7.0
9440J
O.SU
20
19
SU-5
10U
10U
10U
10U
10U
4.0U
75. 2 J
76.8J
7.7
9610J
O.SU
20U
19
SU-6
10U
10U
10U
10U
10U
4.0U
50.8
46.0U
23.7
11800J
O.SU
23
21
On-site Pond
PU-1
10U
10U
10U
10U
10U
4.0U
38.9
46.0U
2.9J
10700
O.SU
30
9.4
PU-2
10U
10U
10U
10U
52U
4.0U
37.5
46.0U
43.5
10800
O.SU
27
9.9
Off -site Pond
PU-3
10U
10U
10U
10U
100
4.0UJ
53.9
46.0U
2.6J
10300
O.SU
21
12
PU-*
in
10U
10U
10U
10U
4.0U
53.8
46.0U
2.3J
10400
O.SU
20U
13
-------
Table 1 (cont.). Selected Results, River (and Creek) and Ponds
G. Results for March 1995
Substance
M/l except as noted
benzene
1.2-dichloroethene (totel)
triehloroetfaane
vinyl chloride
iis(2-ethylhexyl)phthalate
arsenic (dis.)
aariua (dis.)
iron (dis.)
•anganese (dis.)
sodiua (dis.)
•Mania-nitrogen, ao/l
COO. eg/ I
chloride, eg/l
River (SU-S is Upstri
SU-1
10U
1QU
10U
10U
10U
3.0U
47.4
135
14.7
9970
O.SU
28
21
SU-2
10U
10U
10U
10U
10U
3.0U
75.1
157
14.6
9850
0.5U
40
21
SU-3
10U
10U
10U
10U
10U
5. OU
60.4
1ST
13.3*
9570
0.5U
28
21
tea) and
SU-4
10U
10U
10U
1011
10U
3.0U
75.4
66.4
11.0
9430
0.5U
22
21
Creek (SU-6)
SU-S
10U
10U
too
10U
10U
3.0U
95.0
78.5
11.4
9260
0.5U
40
24
SU-6
10U
10U
10U
10U
10U
3.0U
59.2
163
6.6
7210
0.5U
52
14
On-site Pond
PU-1
10U
1J
10U
10U
10U
5.0U
124
30.2
5.5
16000
0.5U
16
14
PW-2
10U
u
10U
10U
10U
3.0U
125
36.2
11.7
15900
0.5U
22
13
Off-site Pond
PU-3
10U
10U
IOU
10U
10U
3.0U
43.9
18.1J
1.0U
8400
NA
HA
NA
PU-4
10U
10U
10U
10U
10U
5.0U
47.7
24.2J
1.1J
8980
HA
HA
HA
H. Results for
1993
Substance
M/l except as noted
benzene
1,2-dichloroethene (total)
trichloroethene
vinyl chloride
bis(2-othylhexyl)phthalate
arsenic (die.)
barius (dis.)
iron (dis.)
smaanese (dis.)
sodiue (dis.)
anaonia-nitrogen. ao/l
COD. ng/l
chloride, ao/l
River (SU-5 is Upetrt
SU-1
10U
IOU
10U
10U
10U
5.2U
83.5
64.9
27900
O.SU
20UJ
38
SU-2
10U
10U
10U
10U
10U
5.2U
83.4
10.7U
28500
O.SU
28J
59
SU-3
1011
iou
10U
IOU
IOU
5.2U
82.8
25.9
27700
O.SU
22J
38
«) and Creek (SU-6)
SU-4
IOU
IOU
IOU
IOU
IOU
5.2U
81.9
19.5J
27300
O.SU
20UJ
38
SU-5
10U
IOU
IOU
IOU
10U
5.2U
81.2
10.70
26500
O.SU
16J
38
SU-6
10U
IOU
IOU
IOU
IOU
5.2U
57.3
19.4J
39.6
19500J
O.SU
31J
52
On-site Pond
PU-1
10U
10U
10U
IOU
IOU
5.2U
113
38.9
2.1J
20000
O.SU
40J
17
PW-2
10U
IOU
IOU
IOU
IOU
5.2U
116
38.9
1.6J
20700
O.SU
22J
17
Off-site Pond
_PU-3
IOU
10U
IOU
IOU
IOU
5.2U
46.4
10.7U
1.4U
9560
O.SU
20UJ
12
PU-4
IOU
IOU
IOU
IOU
IOU
S.2U
46.3
26.0
1.4U
9280
O.SU
20U
12
I. Results for March 1994
Substance
M/l except as noted
benzene
1.2-dichloroethene (total)
trichloroethene
vinyl chloride
bi s(2-ethylhexyl )phthalate
arsenic (dis.)
bariua (dis.)
iron (dis.)
manganese (dis.)
sodiua (dis.)
anaonia-nitrooen. no/I
COO. mg/l
chloride, ng/l
River (SU-5 is Ups and Creek (SU-6)
SU-1
IOU
IOU
IOU
IOU
IOU
3.4U
57.0
30.4
27.9
15100
O.SU
20U
52
SU-2
IOU
IOU
IOU
10U
2J
3.4U
55.2
26.8
27.9
14500
O.SU
20U
31
SU-3
^J***
1fc
IOU
IOU
IOU
3.4U
5S.3
26.6
25.8
15000
O.SU
20U
32
SU-4
IOU
IOU
10U
IOU
IOU
3.4U
S5.8
14.6J
26.7J
15000
O.SU
20U
51
SU-S
IOU
IOU
IOU
IOU
5J
5.4U
52.6
15. SJ
25.8
15000
O.SU
20U
31
SU-6
IOU
10U
IOU
10U
IOU
3.4U
57.6
19.2J
47.9
29100J
O.SU
20U
57
On-site Pond
PU-1
IOU
2J
IOU
IOU
10U
3.4U
146
16.9J
7.9J
19500
O.SU
20U
17
PU-2
IOU
2J
10U
10U
IOU
5.4U
145
19.9J
17.1
18900
O.SU
20U
IS
Off-site Pond
PU-3
10U
IOU
IOU
IOU
IOU
5.4U
47.0
12. 1U
6.7U
8750
O.SU
20U
2.0U
PU-4
IOU
10U
IOU
IOU
10U
5.4U
47.0
1Z.1U
15. OU
8700
O.SU
200
10
-------
Table 1 (cont.). Selected Results, River (and Creek) and Ponds
J. Results for September 1994
Substance
M/l except as noted
xnztttc
1,2-dichloroethene (total)
trichloroethane
vinyl chloride
>i s(2-ethylhexyl )phthalate
arsenic (dis.)
aariua (dis.)
iron (dis.)
Manganese (dis.)
sodiua (dis.)
aeBonia-nitrogen, ea/l
ODD. -o/t
chloride, a«/l
River (SW-S is Upstreasi) and Creek (SU-6)
SU-1
10U
10U
10U
10U
10U
10.0U
95.4
4.8UJ
11.04
36300J
O.SU
39J
51
91-2
10U
10U
10U
10U
10U
10.0U
92.2
4.8UJ
13.6J
36000
o.su
22J
52
SU-3
10U
10U
1QU
10U
10U
10.QU
90.2
48UJ
f.8J
36300
O.SU
110U
S3
SU-4
10U
10U
10U
10U
10U
10. OU
89.7
4. BUI
6.6J
36100J
O.SU
100U
52
SU-5
10U
10U
10U
10U
10U
3.5J
89.0
4.8UJ
5.4J
35000J
O.SU
100U
35
SU-6
10U
10U
10U
10U
10U
10.0U
68.6
4.8UJ
28.9J
22700
O.SU
100U
SO
On-site Pond
py-1
10U
10U
10U
10U
10U
3.4U
146
16.9J
7.9J
19300
O.SU
100U
20
PU-2
10U
U
10U
10U
10U
2.3J
128
4.8UJ
1.2J
21700
O.SU
100U
19
Off -site Pond
PW-3
10U
1QU
10U
10U
10U
10.0U
47.4
4.8UJ
0.1U
10600
O.SU
100U
13
PU-4
10U
10U
10U
10U
10U
2.8J
47.8
4.8UJ
0.1U
10800
O.SU
100U
12
K. Results for Kerch 1995
Substance
M/l except as noted
benzene
1,2-dichloroethene (total)
trichtoroethene
vinyl chloride
bis(2-ethylhexyl)phthalate
arsenic (dis.)
bariua (dis.)
iron (dis.)
aMnganese (dis.)
•odiua (dis.)
aanonia-nitrogen. wg/l
COO, og/1
chloride, mg/l
River (SU-5 is Upetreaa) and Creek (SU-6)
SW-1
10U
10U
10U
10U
10U
3.SU
72.2
27.2U
11.4
21100
O.SU
20U
42
SU-2
10U
10U
10U
10U
10U
3.5U
72.6
27.2U
11.4
21100
O.SU
20U
41
SU-3
tQU
10U
10U
10U
10U
3.SU
72.5
10.3U
7.6
32500
O.SU
20U
40
SU-4
10U
10U
10U
10U
10U
3.6U
75.4
27.2U
11.2
20700
O.SU
ft
40
SU-S
10U
10U
10U
10U
10U
3.5U
73.4
27.2U
11.2
20500
O.SU
20U
39
SU-6
10U
10U
10U
10U
10U
3.5U
72.4
27.2U
12.7
20600
O.SU
20U
39
On-site Pond
PU-1
10U
10U
10U
10U
10U
3.5U
147
27.2U
1.0
19100
O.SU
20U
18
PU-2
10U
1J
10U
10U
10U
3.SU
ISO
27.2U
2.9
19100
O.SU
20U
16
Off-site Pond
PUr3
10U
10U
10U
10U
6J
3.5U
34.8
27.2U
0.4U
9940
O.SU
20U
11
PU-4
10U
10U
10U
10U
10U
3.50
34.4
27.2U
0.4U
9870
O.SU
20U
9.9
L. Results for Sept
1995
Substance
•9/1 except es noted
benzene
1.2-dichloroethene (totel)
trichloroetnene
vinyl chloride
bi s(2-ethylhexyl )phthalate
arsenic (dis.)
beriuH (dis.)
iron (dis.)
sodiun (dis.)
amonia-nitrogen, ao/l
COO. mg/l
chloride. «g/l
River (SU-5 is Upstream) and Creek (SU-6)
SW-1
10U
10U
10U
10U
10U
2.7U
93.0
9.7U
22.6
38600J
O.SU
2S
60
SU-2
10U
10U
10U
10U
U
2.70
80.4
9.70
12.5
34500
2.0
21
60
SU-3
10U
10U
10U
10U
10U
2.7U
75.1
10.3U
7.6
32500
O.SU
17
57
SU-4
10U
10U
10U
10U
10U
2.70
83.2
9.70
7.5
33900
R
29
55
SU-5
10U
100
10U
10U
4J
2.7U
75.7
9.7U
7.9
30900
O.SU
21
53
SU-6
10U
10U
10U
10U
U
2.70
69.0
9.70
19.4
21200
O.SU
19
34
On-site Pond
PU-1
10U
10U
10U
10U
10U
2.7U
114
9.7U
0.2U
18600
O.SU
27
19
PU-2
10U
10U
10U
10U
10U
2.70
109
9.70
0.78U
18400
O.SU
27
19
Off -site Pond
PU-3
10U
10U
10U
10U
2J
3 .90
50.9
34.70
0.2U
10800
O.SU
15
14
PU-4
10U
10U
10U
10U
10U
3.9J
50.9
46.SU
0.48U
11000
O.SU
22
14
-------
Table 1 (cont.). Selected Results, River (and Creek) and Ponds
M. Results for torch 1996
Substance
M/l except es noted
xnxone
1.2-dichloroethene (total)
trichloroothene
vinyl chloride
bis(2-ethylhexyl )phthalate
arsenic (die.)
beriiai (die.)
iron -(die.)
aanoanese (die.)
eodlue (die.)
•Mania-nitrogen. eg/I
COD. no/I
chloride, ao/l
River (SU-S ie UpetreeB) end Creek (SU-6)
SU-1
10U
10U
10U
10U
1J
3.0UJ
42.6
11. 4U
6.1
8760J
0.1U
10U
28.0
SU-2
10U
10U
10U
10U
10UJ
3.0UJ
41.5
10.9U
6.1
8710J
0.1U
17.4
28.2
SU-3
1QU
10U
10U
10U
10UJ
3.0UJ
44.7
10.9H
6.4r
9180J
o.tu
12.7
28.2
SU-4
10U
10U
10U
10U
10UJ
3.0UJ
44.4
10.9U
7.8
93001
0.1U
26.8
28.1
SU-5
10U
10U
10U
10U
10UJ
3.0UJ
40.7
10.9U
5.8
8350J
0.1U
26.8
27.9
SU-6
10U
10U
10U
10U
1J
3.0UJ
45.3
10.9U
53.4
18500J
0.1U
10U
46.0
On-eite Pond
PU-1
10U
10U
10U
10U
10UJ
3.0UJ
152J
10.9U
0.67
17500J
0.19
18.2J
20.2
PU-2
10U
10U
10U
10U
10U
3.0UJ
158J
10.9U
2.3
18100J
0.22
20.6J
20.2
Off-site Pond
PW-3
10U
10U
10U
10U
10U
3.0UJ
42.7J
10.9U
0.23J
11400J
0.1U
10U
14.7
PU-4
10U
10U
10U
10U
10U
3.0UJ
42.2
10.9U
0.2U
11400
0.1U
21.8U
14.5
N. Result* for September 1996
Substance
M/l exceat as noted
benzene
1.2-dichloroethene (totel)
trichleroethene
vinyl chloride
bisX2-etnylhexyl)phthalate
arsenic (die.)
beriut: (die.)
iron (die.)
•enganese (die.)
sodiuB (die.)
anBonia-nitrogen. MB/I
COD. ng/l
chloride, ee/l
River (SU-5 ie UpstreM) and Creek (SU-6)
SU-1
10U
10U
10U
10U
10U
2.3U
62.7
25.5U
13.3
27900J
0.1U
14.7J
49.4
SU-2
10U
10U
10U
10U
10U
2.3U
67.5
25.5U
9.6
30600J
0.1U
16.6J
45.6
SU-3
191
10U
10U
10U
10U
2.3U
50.9
25.5U
9.1
23300J
0.1U
11. 9J
39.0
SU-4
10U
10U
10U
10U
10U
2.3U
53.0
25.5U
9.2
24900J
0.1U
10UJ
42.9
SU-S
10U
10U
10U
10U
10U
2.3U
55.4
25.5U
8.6
22900J
0.1U
14.4J
32.0
SU-6
10U
10U
10U
10U
10U
2.3U
52.8
2S.SU
27.7
18100J
0.1U
14. 4 J
32.0
On-eite Pond
PU-1
10U
10U
10U
10U
10U
2.3U
149
R
11. U
18700J
0.1U
19.2J
22.6
PU-2
10U
10U
10U
10U
10U
2.3U
148
25.SU
9.9U
18800J
0.1U
22.3J
21.1
Off-site Pond
PU-3
10U
10U
10U
10U
10U
2.3U
41.8
25 .50
8.4
12500J
0.1U
12. 8J
15.1
PU-4
10U
10U
10U
10U
10U
2.3U
40.6
2S.SU
3.9U
12400J
0.1U
13.5J
19.1
gut nee not de-
tected. The sample quant i tat ion or detection If Bit MS not specified in the report.
Qualifiers: u •earn the arterial was analyzed for but was not detected above the level of the associ-
ated value, which is either th» staple quant it at ion Unit or the saaple detection liaiit; L Mane the aateri-
al was analyzed for but MS not detected above the* associated value, which is the saaple detection limit; R
Mans the data is unusable (the analyte My or My not be presr-t) due to serious deficiencies; J means the
associated value is an estimated quantity; N indicates the pres.i,ce of the analyte that has been "tentative-
ly identified".
"dis." wans the dissolved portion; the sample MS field filtered.
-------
Table 2. Selected Results for Groundwater Monitoring Wells
A. Results for February 1990
Substance
benzene
1,2-dichloroethene (total)
trichloroethane
vinyl chloride
bi«(2-ethylhexyl)phthalate
arsenic (dis.)
bariua (dis.)
iron (dis.)
nanganese (dis.)
sodiua (dis.)
oMjaonia-nitrogen. «g/l
COO, a«/l
chloride. ag/l
SU
140
18
22
10U
11.3
193J
2990
671
23400
1.01
56
25
2J
5
50
12
10U
51.7
825
9070
1190
43600
16.0
170
40
Doungrai
SU
5U
SU
10U
3J
24.7
595
4589
324
46200
7.1
230
30
iient Gn
SU
SU
SU
1QU
10U
B.3J
359
1840
330
40800
1.01
160
30
oundMate
SU
SU
SU
10U
2J
3.0U
212
13.4J
313
41600
3.1
140
30
r Wells
1J
SU
SU
10U
2J
435
539
13100
433
118000
S-.6
250
67
SU
SU
SU
10U
2J
3.9J
461
274
264
148000
20.0
160
70
SU
SU
SU
10U
8J
114
155J
4280
163
134000
9.8
320
36
Backg
SU
SU
SU
10U
10U
3.0U
44.3J
80 .6J
305
10500
1.0L
300
15
round
SU
2J
SU
10U
2J
3.0U
101J
26.7J
13. 7J
16300
1.0L
SOL
40
B. Results for August 1990
Substance
H/l except as noted
benzene
1,2-dichloroethene (total)
trichloroethona
vinyl chloride
bis(2-ethylhexyl)phthalate
arsenic (dis.)
barius (dis.)
iron (dis.)
Manganese (dis.)
sodiu* (dts.)
annonia-nitrogen. «g/l
COD. ng/l
chloride. «g/l
NB-1
SU
57
73
44 .
64
12.2U
177J
2700
683
17700
O.SL
SOL
24
MB-2
5
21
SU
47
3J
71.0
876
15400
157
34500
12.0
60
31
Dotngrai
NB-3
91
SU
SU
10U
10U
15.9J
817
9180J
165
33400
8.5
120
34
Iient Or
N8-4
SU
SU
SU
10U
10U
18.9J
596
4280J
161
33600
2.0
54
35
ounduate
NB-S
SU
SU
SU
10U
10U
2.1J
439
14.5J
505
32500
2.5
60
31
r Wells
2J
U
SU
10U
3J
420
444
13100
98.0
76700
11.0
200
49
SU
SU
SU
10U
15
79.6
698
8270
142
100000
170
56
SU
SU
SU
10U
7J
127
284
5320
69.5
200000
200
57
Backg
SU
SU
SU
10U
10U
4.4UJ
6B.7J
389
783
10800
120
15
round
5U
5U
SU
10U
10U
2.0U
96.5J
22.8J
6.6J
11400
SOL
22
C. Results for February 1991
Substance
n/l except as noted
benzene
1,2-dichloroethene (total)
t rich lor oethene
vinyl chloride
bi s( 2-ethylhexyl )phthalate
arsenic (dis..)
barium (dis.)
iron (dis.)
sodiua (dis.)
annonia-nitrogen, «g/l
COD, rag/ I
chloride, ng/l
Doongradient Grounduater Uells
MB-1
SU
28J
79
10U
10U
27.0J
136J
2030
566
9230
O.SL
22
18
MB-2
2J
su
SU
IS
10U
26. OJ
862
11800
290
27100
10.0
64
22
NB-3
SU
SU
SU
10U
10U
29. 1J
1060
10400
295
45400
8.1
58
33
NB-4
SU
SU
SU
10U
10U
24.3J
693
5250
195
41500
2.2
23
35
NB-5
SU
SU
SU
10U
10U
7.9J
246
20. OU
258
22800
3.1
56
19
NB-6
1J
SU
SU
10U
10U
232J
332
11100
85.1
52900
9.9
41
55
NB-7
SU
SU
SU
10U
10U
12.5J
741
13300
320
128000
9.9
100
71
NB-8
SU
SU
SU
10U
10U
1B2J
402
7120
88.9
543000
7.3
260
360
Background
NB-9
SU
SU
SU
10U
10U
6.0J
74.4J
1520
833
10400
O.SL
38
17
MB- 10
SU
SU
SU
10U
10U
3.0UJ
98. 2 J
37.0J
1.7J
13000
O.SL
20U
18
-------
Table 2 (cont.)
Selected Results for Groundwater Monitoring Wells
0. Result* for August 1991
Substance
M/l except as noted
bemem
1,2-dichlorosthene (total)
trichloroathana
vinyl chloride
bis(2-ethylhexyl)phthalate
arsenic (dis.)
aarium (dis.)
iron (dis.)
ttlmm \
••nBflrmv lQi**J
sodiuB (dis.)
aBBonia-nltrogtn. aa/l
COO. a«/l
chloride, *g/l
Downgradient Cr
M-1
10L
21
72
10U
10U
13. OJ
179J
2640
778
17400
0.7
20U
35
NB-2
6J
SJ
10L
12J
10U
70.4J
702
15200
129
35200
14.0
58
25
NB-3
10L
10L
10L
10U
10U
30.7
682
9440
140
33300
7.5
40
' 25
NB-4
101
10L
10L
10U
10U
32.4
530
4100
164
33300
2.2
20U
20
ounduater Wells
NB-S
10L
10L
10L
10U
10U
5.0U
283
10. OU
537
30500
O.SL
130
15
M-6
10L
10L
10L
10U
18
226
214
8800
89.9
38300
5.9
46
30
•-7
10L
10L
10L
10U
10U
99.6
601
10100
69.3
77400
6.6
55
70
NB-8
10L
10L
101
10J
10U
251
232
3020
36.6
271000
14.0
160
70
Background
N8-9
10L
10L
10L
10U
10U
7.8J
40.7J
10. OU
1.2J
12700
O.SL
40
10
Hi- 10
10L
10L
10L
10U
10U
5.0UJ
88.9J
10. OU
1.0U
15500
O.SL
20U
10
E. Results for February 1992
Substance
Kg/ I except as noted
benzene
1,2-dichloroethow (total)
trichloroathana
vinyl chloride
a
-------
Table 2 (cent.)
Selected Results for Groundwater Monitoring Wells
G. Results for March 1993
Substance
benzene
1.2-dichloroethene (total)
trichloroethene
vinyl chloride
ais(2-ethylhexyl)phthalate
arsenic (die.)
bariua (dis.)
iron (dis.)
•anganese (dis.)
sodiua (dis.)
•eaonia-nitrooen. «g/l
COD. eg/I
chloride, eg/ 1
ttat*1
tou
52
76
1J
10U
10.0
159
2160
706
13900
0.5U
20U
17
10U
6J
10U
IS
15U
91.2
642
21900
288
Z3100
10.0
39
16
DoMngrai
10U
10U
10U
10U
10U
30.4
620
8500
20rf
i*4tiP^
5.2
45
18
Item Gn
10U
10U
10U
10U
10U
17.2
446
3250
160
25100
0.8J
22J
17
otnduate
10U
10U
10U
10U
10U
3.0U
256
187
482
20400
0.5U
20U
14
r Wells
10U
10U
10U
10U
10U
249
341
16600
92.4
3^000
1.4
34
22
10U
10U
10U
10U
10U
32.1
498U
4830
198
84800
5.6_
40
63
10U
10U
10U
10U
10U
138
195
3970
42.4
138000
6.9
120
26
Bsckg
10U
10U
10U
10U
10U
6.3
60.7
2050
637
9140
0.5U
28
11
round
10U
I 10U
10U
10U
10U
3.0UJ
76.1
13. OU
1.0U
18600
0.5U
20U
13
H. Results for Sept
1993
Substance
M/l except as noted
Mnzene
1,Z-dichloroethene (total)
trichloroethene
vinyl chloride
bi s(2-ethylhexyl )phthalate
arsenic (dis.)
bariuB (dis.)
iron (dis.)
•anganese (dis.)
sodiua (dis.)
MHonia-mtrogen. *g/l
COD. na/l
chloride. 0g/l
NB-1
10U
30
76
20
10U
16.1
165
2040
717
17600
0.5U
20UJ
16
M-2
SJ
5J
10U
IS
10V
51.6
577
18200
239
21200
8.7
22J
17
OoMnarai
M-3
Km
10U
10U
10U
14U
34.0
669
11000
160
20800
6.0
28J
16
Kent Gn
M-4
10U
10U
10U
10U
16UJ
23.S
461
3850
188
20100
2
20UJ
17
oundMate
M»S
10U
10U
10U
10U
38U
5.2U
253
889
687
19900
20UJ
37
T wells
m-6
10U
10U
10U
10U
10U
184
260
14400
83.1
27100
284
20
NB-7
10U
10U
10U
10U
10U
124
598
10800
53.4
69500
28J
34
M-8
1QU
10U
10U
10U
22U
143
248
5660
69.6
156000
90J
40
Backg
NB-9
10U
10U
10U
10U
22U
12.5J
67.8
1570
728
10200
0.5U
20UJ
11U
round
MB- 10
10U
10U
10U
10U
10U
5.2U
79.6
25.9
1.4U
20000
0.5U
20UJ
16
I. Results for March 1994
Substance
H/l except as noted
benzene
1.2-dichloroethene (total)
trichloroethene
vinyl chloride
bis(2-ethylheK\/l)phthalate
arsenic (dis.)
barium (dis.)
iron (dis.)
•anganese (dis.)
sodiun (dis.)
araonia-nitrogen, ng/l
COO, mg/l
chloride, mg/l
OoMngradient Grounduater Walls
NB-1
10U
39
74
10U
10U
11.4
154
1970
706
16000
0.5U
20U
20
M-2
2J
3J
10U
7J
10U
84.2
572
24200
320
20000
8.8
33
17
NB-3
10U
10U
10U
10U
10U
32.9
669
10900
164
22600
4.8
38
20
M-4
10U
10U
10U
10U
10U
21.0
490
3950
188
22000
1.5U
30
18
NB-5
10U
10U
10U
10U
10U
4.0J
264
527
424
19500
0.5U
25
13
HB-6
10U
10U
2J
10U
10U
205
332
17900
90.4
34200
3.8
37
25
NB-7
10U
10U
10U
10U
10U
90.3
576
9860
57.9
64000
8.8
29U
25
M-8
10U
1J
10U
10U
10U
144
205
5790
65.8
103000
4.3
69
26
Background
NB-9
10U
10U
10U
10U
10U
6.9
58.5
2050
610
9360
O.SU
20U
12
Mi- 10
10U
10U
10U
10U
10U
3.7J
79.0
12.5
6.7U
18200
O.SU
20U
16
-------
Table 2 (cont.)
Selected Results for Groundwater Monitoring Wells
J. Results for September 1994
Substance
M/l except as noted
aenzane
1,2-dichloroethene (total)
trichloroethene
vinyl ehlorid*
»is(2-ethvlhexyl >uhthalate
arsenic (dis.)
aariua (dis.)
iron (dis.)
ssngenese (dis.)
sodtuB (dis.)
aasnnia-nitrogen. aa/l
COO, sg/l
chloride, ag/l
Dotawadient Gn
M-1
10U
SI
61
3J
10U
10.9
155
1670
704
16600
0.5U
100U
20
M-2
3J
12
10U
24
10U
99.4
403
13300
114
21800
5.0
20J
17
M-3
10U
10U
10U
10U
10U
36.7J
581
9310
142J
20800
4.1
38J
17
M-4
10U
10U
10U
10U
10U
22.7
490
4000
190
21300
0.7_
110
25
nundiiater Wells
M-5
10U
10J
10U
10U
10U
11.2
353
2550
443J
19600
1.3
100U
17
••6
10U
10U
10U
10U
10U
R
R
14400
78.9J
26600J
2.8
27J
20
M-7
10U
10U
10U
10U
10U
100
562
9410
51. OJ
50400
7.6
29J
20J
M-8
10U
10U
10U
10U
10U
143J
170
5070
R
1
0.5U
230
20
Background
m-9
10U
10U
10U
10U
10U
10.8
72.7
1980
R
10000
0.5U
624
6
"•-10
10U
10U
10U
10U
10U
1.9U
200U
4.8UJ
1.5J
R
0.5U
100U
20
K. Results for March 1995
Substance
M/l except as noted
benzene
1.2-didtloroetheno (total)
triehleroathene
vinyl chloride
Bis(2-ethylhexyl)phthalate
srsenic (dis.)
baritai (dis.)
iron (dis.)
sMiganese (dis.)
sodiiai (dis.)
mania-nitrogen, eo/l
COO. so/I
chloride. so/I
Oownoradient Grounduoter Wells
M-1
101)
95
38
10U
10U
10.4J
153
1730
679
17700J
0.5U
20U
22
m-2
2J
1NJ
10U
10U
10J
133
579
22000
304
25400J
6.9
20U
20
M-3
1QU
10U
10U
10U
10U
36.6
724
13100
190
21400J
3.4
20U
18
MB-4
10U
10U
10U
10U
10U
21.64
452J
3610
189
20200J
1.4
20U
20
M-S-
10U
10U
10U
10U
10U
12.8J
385
2450
471
22200J
o.su
20U
19
W-6
10U
10U
10U
101)
10U
214
352
16800
73.6
29500J
3.9
33
21
m-7
10U
10U
10U
MU
10U
91.2
542
7550
60.4
44800J
5.2
20U
21
M-8
10U
10U
10U
10U
10U
124
148
4490
59.0
61100J
O.SU
95
39
Backg
m-9
10U
10U
10U
10U
10U
8.9
70.8
1730
602
9560J
0.51)
41
3
round
M-10
10U
10U
10U
10U
10U
3.SU
99.6
27.2U
0.4U
20500J
O.SU
20U
31
L. Results for
1995
Substance
M/l except as noted
benzene
1.2-dichloroethene (total)
trichloroethene
vinyl chloride
bis(2-ethylhexyl>ohthalate
arsenic (dis.)
bariua (dis.)
iron (dis.)
aanganese (dis.)
sodius (dis.)
a*B0nia-nitrogen, eg/I
COD, «g/l
chloride, ng/l
Oowngradient GroundMeter Wells
M-1
10U
110
36
5J
10U
7.7
139
1710
648
16000J
O.SU
9.7
22
NB-2
10U
10U
10U
10U
10U
91.9
517
14000
12S
221 OOJ
8.4
53
23
M-3
10U
10U
10U
10U
10U
27.7
571
9400
147
19500
5.3
21
18
NI-4
10U
10U
10U
10U
R
16.5
439
3760
189
19200
2.0U
9.7
18
M-5
10U
10U
10U
10U
3J
173
313
63.4
R
R
3.2
17
17
M-6
10U
10U
10U
10U
10U
16.9
R
4170
R
18400
3.9
29
21
M-7
10U
101)
10U
10U
4J
120
SSI
9520
41.6
38400
6.4
23
22
M-8
10U
10U
10U
10U
3J
120
157
4880
5S.2
62500
1.4U
84
17
Background
M-9
10U
10U
10U
10U
1J
5.6
73.5
1570
540
8710
0.7U
36
13
M-10
10U
10U
10U
10U
*J
2.7U
136
9.7U
0.2U
17700
O.SU
9
29
-------
Table 2 (cont.). Selected Results for Groundwater Monitoring Wells
N. Results for March 1996
Substance
benzene
1.2-dichloroethene (total)
trichloroethane
vinyl chloride
bis(2-ethylhexyl )phthalato
arsenic (dis.)
barius (dis.)
iron (dis.)
•enganese (dis.)
sodiui (dis.)
aamonia-nitrogen. so/ 1
COO. MB/l
chloride, mg/l
10U
170J
27J
20J
10U
6.4J
171J
2020
771J
19500J
0.1U
10U
30.1
M_J
1J
2J
10U
10U
10U
51.2
426
7560
255
24400
7.6
40.6
22.8
DOMngrai
«.v
10U
10U
10U
10U
3J
25.1
R
UOfU
t
21100
4.6
10U
21.6
iient Or
Mȣ
10U
10U
10U
10U
14
15.5
470J
3490
191
20100
2.0
12U
21.9
nundMste
10U
10U
10U
10U
1J
3.0U
291J
199
443
22000
1.0
10U
20.7
r Well a
10U
10U
10U
10U
10U
185
376J
15800
69.1
32500J
4.6
30.0
24.6
10U
10U
10U
10U
2J
34.4
520J
3510
38.4
35400
3.9
16.2
20.9
10U
10U
10U
10U
2J
121
200J
6600
75.1
73400J
3.1
50.0
25.1
Backg
10U
10U
10U
10U
1J
5.2J
70.9
2100
542
10300
0.41
10U
14.0
round
10U
10U
10U
10U
0.7J
3.0U
99. U
10.9U
0.2U
18300
2.0
10U
22.0
H. Results for
1996
Substance
M/l except as noted
benzene
1,2-dichloroethsm (total)
trichtoroathene
vinyl chloride
bis(2-ethylhexyl)phthalate
arsenic (dis.)
bariua (dis.)
iron (dis.)
ssnganese (dis.)
sodiua (dis.)
aMBonta-nitrogen. BQ/I
COO, Mg/l
chloride, Mg/l
DoMngradlent Groundwater Uella
li-1
10U
84
38
10U
10U
9.1J
139J
1890J
418J
16000J
0.1U
10UJ
23.6
Motes: Qualifiers: U Means the Mater
m-2
2J
10U
10U
U
10U
8.4
135
1890
R
15800
11.0
28.3J
26.3
NB-3
W
10U
10U
10U
10UJ
29.3
583
10500
188
21000
5.5
12.8J
22.3
M-4
10U
10U
10U
10U
10U
16.3
479
3550
217
20300
1.8
10.9J
22.6
NB-5
10U
10U
10U
10U
10U
10.3
479
3130
444
20400
3.0
10.3J
21.1
Ni-6
10U
10U
10U
10U
10J
162
330
13300
60.5
30000
4.9
12.2J
22.4
m-7
10U
10U
10U
10U
10U
110
617
12600
61.7
40900
5.0
21. U
29.5
N8-8
10U
10U
10U
10U
10U
99.2
263
6590
95.0
94400
3.3
62.2J
24.8
Backg
NB-9
10U
10U
10U
10U
2J
7.9
69.0
2350
575
10700
0.45
10UJ
14.4
round
NB-10
10U
10U
10U
10U
10U
2.3U
97.0
25.SU
1.3U
15700
0.1U
10UJ
28.8
al was analyzed for but was not detected above the level of the asso-
ciated value, which is either the saaple quant i tat ion Halt or the saqple detection liait; L wans the
•aterial Mas analyzed for but Mas not detected above the associated value, which is the Maple detection
liMit; R acans the data is unusable (the analyte May or May not be present) due to serious deficiencies; J
•earn the associated value ia an estimated quantity; M indicates the presence of the analyte that has been
•tentatively identified"; • indicates that the QA/OC ta Mere Missing for these IO> sasples.
"dis." means the dissolved portion; the savple .as field filtered.
Samples for wells M8-5 and NB-6 nay have been switched in September 1995.
-------
Flgur,/
Samplng location*
Marian
-------
Attachments
Responsiveness Summary
Attachment A: Responsiveness Summary on the Proposed Consent
Decree
Administrative Record Index--Original
Administrative Record Index--Update #1
Administrative Record Index--Update #2
Administrative Record Index--Update #3
-------
USEPA Response. Black & Veatch Special Projects Corp., USEPA's
contractor, mailed the fact sheets to the parties on the mailing
list for the Site on June 27, 1997. Black & Veatch sent a copy
of the fact sheet overnight to the Marion Public Library on June
26, 1997. The documents that were added to the Administrative
Record for the Site were mailed to the Marion Public Library with
a transmittal letter dated June 26, 1997. The advertisement
announcing the public comment period appeared in the Marion
Chronic1e-Tribune on June 27, 1997.
An extension of the public comment period, for an additional 30
days through August 27, 1997, was granted. This was announced in
an advertisement that was in the Marion Chronicle-Tribune on July
28, 1997.
2. Comment. Dorothy Alabach, Valparaiso, Indiana, mentioned an
"office memorandum* (apparently a reference to a letter or memo-
randum mentioned earlier in the meeting with comments concerning
a meeting with USEPA that was sent from one person at IDEM to
another person there; a copy was not furnished at the meeting)
and said that she thought that* both agencies had dropped the ball
protecting the public. She said that there was criticism con-
cerning getting documents to the State and that there was a lack
of cooperation (apparently between the two agencies) . She
claimed that there were late changes made to the final forms of
the Consent Decree and the 1987 ROD for OU 1 by the USEPA or the
Settling Defendants that compromised the integrity of the clean-
up. She also requested that a copy of the transcript of the
meeting be mailed to her.
USEPA Response. USEPA does not believe that USEPA and IDEM have
failed to protect the public while implementing the remedy for OU
1 and obtaining the information needed in order to propose reme-
dies for.OUs 2 and 3.
Under the terms of the Consent Decree, USEPA, in consultation
with the State, generally has the primary responsibility when
dealing with the Settling Defendants. During the negotiations
for the Consent Decree and during the implementation of the work
for OU l, USEPA worked closely with the State. USEPA carefully
reviewed comments from the State and considered them. USEPA did
not embrace all of the State's comments. In many of the in-
stances where USEPA did not agree with the State, USEPA provided
the State with written responses to the State's comments.
•
There were no significant changes made to the remedy contained in
the draft ROD for OU 1 with which the State concurred. The Set-
tling Defendants had no more input to that ROD than any other
citizen had the opportunity for; all had the opportunity to com-
ment on the Proposed Plan. The ROD for OU 1 did indicate that
USEPA intended to undertake additional studies of the potential
impacts.of Site contaminants on the river and ponds. Subsequent-
ly, during negotiations of the Consent Decree, a phased approach
to such studies was agreed to by the parties. USEPA believes the
Marion (Bragg) OU» 2 i 3 ROD. topomiveucu Summary 3 9/97
-------
phased study is appropriate and that results of sampling sedi-
ments and groundwater and surface water show that fish analyses
are not necessary. There were no changes made in the Consent De-
cree after the document had been agreed upon and went out for the
signatures of all the parties except for one small change that
was made in Paragraph XIX, which is clearly marked and initialed.
Those attending the public meeting were told that they could re-
quest that a copy of the transcript be mailed to them*. Ms.
Alabach was sent such a copy.
3. Comment. At the public meeting, Marijean Stephenson, Marion,
Indiana, also requested a copy of the transcript and requested
that she be notified by mail of any extension of the comment
period. She was surprised to see that the PRPs are doing the
water testing and that the samples are sent to a lab determined
by the PRPs. She questioned the amount of USEPA's oversight and
assurances of independent validation of the data.
She also asked if test results were being averaged, and where in
the law does it state that you can do that. She wanted to know
what concentration was needed to require further action. What
happens if the remedy selected fails to contain the waste on site
or if the integrity of the cap is damaged. Why have there not
been regular informational meetings or at least why has the pub-
lic not been kept informed? She thought that nothing had been
added to the files in the repository for about five years. Does
one have to have a TAG to know what is going on?
USEPA Response. When an agreement has been reached with a group
of potentially responsible parties (PRPs) to carry out required
remedial work at a Superfund site, it is generally agreed that
the group will do all of the required work. This is done under
the supervision-and oversight of the lead agency. How much over-
sight is exercised depends upon the situation. At this Site, as
the work has gone on, the amount of oversight has been decreasing
as the PRP group (those PRPs that settled with the agencies in
the 1991 Consent Decree) has continued to demonstrate its ability
to do the work in a professional manner.
The PRP group does indeed have a contractor take the samples.
This contractor is required to use procedures that have been
approved by USEPA. The PRP group has selected the laboratory
that analyzes the samples; this selection was approved by USEPA.
The laboratory uses procedures that have been approved by USEPA.
The PRP group has a contractor that validates the data. This
contractor is required to use the USEPA validation procedures.
When the data is submitted to USEPA and IDEM it is reviewed. So
far, USEPA has had no basis to question the data submitted by the
PRP group.
The results for each sample are reported; sample results reported
to the agencies have not been averaged, as can be seen from the
reports in the repositories. Data can be averaged for the pur-
Marion (Bragg) OUi 2 A 3 ROD. Responivcnen Summary 4 0/97
-------
pose of making decisions, dependent on the context in which the
information is used. There is no law that specifically addresses
the use of sample result averages for response action decisions.
The primary purpose of the sampling is to determine what is hap-
pening with time to the groundwater and the on-site pond regard-
ing the quality of the water and to determine if there are any
impacts on the Mississinewa River in the neighborhood of the
Site. No specific concentrations have been set to trigger some
remedial action. Impacts on the river and concentrations in the
on-site pond above acceptable levels would require consideration
of possible action. In the on-site pond, acceptable levels are
primarily the various surface water criteria. Additional ground-
water analyses may be required under certain conditions.
If the remedy fails to contain the wastes, then the Site will
have to be reevaluated. But it is necessary to remember that
containing the wastes and containing contaminated groundwater are
two different things. There is contamination in the groundwater
and this groundwater is discharging to the river. However, there
has been no measurable effectfon the river, that is, the river
water monitoring has not been showing increases in concentrations
in the river with position. If the cap is damaged, the PRP group
will have to repair it.
There have been no informational meetings for the public or fact
sheets issued since the construction for OU 1 was finished since
there did not appear to be any new information to provide the
public. USEPA does admit that there were delays in finalizing
data which led to delays in placing sample results in the
repository, but there had been no inquiries from the local public
about the Site for a considerable period of time.
One does not have to have a Technical Assistance Grant (TAG) to
know what is happening at a site.
4. Comment. Dorothy Alabach also commented on splitting sam-
ples. She stated that citizens have the right to have laboratory
representation, not just the PRPs.
USEPA Response. Split samples are one of the tools available to
the agencies when overseeing remedial work, that is, the PRPs'
sampling contractor takes a sample and the agency takes a part of
it. The samples are separately analyzed by different laborator-
ies. The agency does not generally split all samples, only some
of them.
The agencies are representing the people when working with a
group of PRPs at a site, and if sample splitting is determined to
be necessary, the agencies will be the ones doing this.
5. Comment. Jeff Symtnes made a comment about the Superfund
program. He believes that the government agencies are controlled
by the polluters. He said that legislation is being prepared to
Marion (Bragg) OUt 2 & I ROD. RapOMtvencu Summary D 9,97
-------
place the liability on the citizens and there are no public hear-
ings to let citizens participate in the preparation of the legis-
lation. He said that the politicians are going to do away with
over 10,000 sites in the country and that Indiana has delisted
1350 sites and have maybe 100 sites they might even look at. He
mentioned the Fivecoate Landfill (Howard County Landfill), where
he claimed radioactive materials and toxic chemicals have been
dumped; he claimed that this site is not being looked at. He
attacked the politicians in Washington. He said that the staff
at the agencies have too many sites assigned to them to do an
adequate job, and that the managers of the agencies are
controlling and manipulating the country, poisoning the world.
USEPA Response. USEPA acknowledges this comment but has no re-
sponse to present here since the comment does not pertain to the
proposed action at the Marion (Bragg) Dump site.
6. Comment. Marijean Stephenson commented further. She ques-
tioned the appropriateness of a site's project manager saying
that a site is not that bad. She is a nurse and would not say to
a patient that he/she wasn't really that sick.
USEPA Response. There is a claim, reportedly in the 1989 IDEM
memorandum mentioned above, that the remedial project manager for
USEPA had said that this Site is not that bad. Whether or not it
was said is not known. However, USEPA is mandated to address all
Superfund sites with the same diligence, and any such comment has
no impact on the level of cleanup required for a site.
Sites are scored under the Hazard Ranking System. The score that
is obtained reflects the information known at the time of the
scoring. The score provides a measure of relative rather than
absolute risk for the site. In a National Priorities List (NPL)
from 1989, this Site was ranked 567 out of 848 sites. This Site
was scored at 35.25. A score of 28.5 was needed for a site to be
I aced on the NPL. The maximum score on that list was 75.6.
Characterizing the relative risk of a site is similar to listing
the condition of a patient as being critical, serious, stable,
etc.
7. Comment. Richard Atcheson of Marion, in a message dated July
17, 1997, commented that he supports the no-action proposal. He
said that massive expenditures on low level threats are not in
the best interests of the public. He also mentioned that there
is a severe problem locally with illegal dumping and he felt that
the trash dumping along River Road is a greater threat to the
Mississinewa River than is this Site. He further stated that no
one he talks with seems worried about the Site and he thinks that
the general public is satisfied with the containment. The
general public ends up paying for all the clean-ups and USEPA
only hears from a vocal minority.
USEPA Response. USEPA acknowledges Mr. Atcheson's comments in
support of the selected response.
Marion (Bragf) OUi 2 & 3 ROD. Roponiveno* Summary
-------
8. Comment. Emery Patterson of Marion, in a message dated July
25, 1997; listed three main concerns that he has with the Pro-
posed Plan. First, he said that it was documented that over
50,000 drums of chemical and industrial waste went into the Site,
and he wanted to know what happened to it; how much has already
leached from the Site and how much remains and what are the
health implications for people and wildlife. He believes that it
is absurd to think that this Site has not had some impact on the
environment. He states that he has never seen any documents that
would explain, for example, that certain chemicals can bio-
accumulate and cause renal failure; all he has seen are tables
with ppm measurements and sampling data. Secondly, he claims
that orange leachate persists at the edge of the water of the
Mississinewa River near the north corner of the Site. He ex-
pressed concern about this when the Site was being capped and he
said that his claim that it was leachate was dismissed. He asked
if testing had been done. He wants to know how it was determined
what this orange phenomenon is and if it will be tested. Third-
ly, how was the list of chemicals to be analyzed for for the
groundwater and pond water generated? He mentioned that cadmium
is used locally in the manufacture of picture tubes. Were the
chemicals used locally used as a basis for the testing? He men-
tioned observing waste glass from RCA along the southwest bank of
the on-site pond; The glass had had a phosphorescent slurry ap-
plied to it and he wanted to know how these chemicals have im-
pacted this pond. He believes that common sense has been lacking
in the investigation of the Site.
USEPA Response. First, 50,000 drums is higher than has usually
been attributed to the Site, which is around 30,000 drums. But
even 50,000 full 55-gallon drums would only constitute 1.2% of
the estimated volume of this dump. What has happened to the con-
tents of these drums is not fully known. Reportedly, the con-
tents of at least some of the .drums were dumped on the ground.
Some of the reported materials were fairly volatile and most of
this has probably left the Site, either through evaporation or
dissolved or emulsified in the groundwater. Some of the sub-
stances may still be attached to other materials, including
soils, in the landfill. What can be said about these materials
is that the analyses of the groundwater do not indicate that
these materials are presently leaving the Site at any great rate
with the groundwater. And, as has been stated in this ROD, USEPA
believes that no further action is needed here to ensure protec-
tion of human health and the environment. This is not saying
that this Site has never had an impact on the environment.
In the remedial investigation report, bioconcentration was ad-
dressed. . Discussions of many of the chemicals found at the Site
were also presented. Exposures to some of these chemicals may
affect the kidneys.
Years ago when there was a claim that leachate was appearing
along the river in the northwestern corner of the Site, two sam-
ples of the sediments in this area and a sample of water from
Marion (Brafg) OUi 2 & 3 ROD. RapomiveMM Suaumfy 7 4/47
-------
well MB-2 were taken. The results of the tests on these samples
and a discussion of the work that was done are in the report,
Detection of Iron Bacteria in River Sediment, Soil and Well Water
Samples, Barbara J. Butler and Colin I. Mayfield, June 18, 1991,
a copy of which is in the Administrative Record. It was
concluded, "It is quite possible that the iron staining observed
at the field site from which the samples were taken is
biologically-mediated." It also needs to be noted that similar
staining could be found along this river well upstream of the
Site (near the 38th Street bridge) at the time.
The commenter has expressed a belief that leachate has appeared
at the edge of the river. When the RI was done there were three
wells installed in the waste disposal area. The water levels
measured in two of them (the othe: was generally or always dry)
gave elevations that one would approximately expect for the water
table at those points, indicating that there was little or no
accumulation of leachate in the landfill. What leachate there
might be would be expected to primarily flow down to the ground-
water rather than take the fairly long path to the river at the
northwest corner of the Site.'1-
The substances analyzed for in the semi-annual samplings of the
various water samples since the remedial action was started for
OU 1 have been those substances usually analyzed for at Super fund
sites, the target compound list (TCL) and target analyte list
(TAL) substances, except that pesticides and polychlorinated bi-
phenyls (PCBs) were not included since they were not found during
the RI. In the quarterly monitoring between these semi-annual
events, several indicator parameters in groundwater have been
analyzed for; also, if anything from the semi-annual monitoring
needs confirmation, it would be analyzed for. Some phosphors
contain cadmium and zinc. Cadmium and zinc are two of the TAL
substances. The levels of these two substances at the Site were
hot seen as a problem.
USEPA believes that it, in consultation with IDEM, has investi-
gated the Site responsibly.
9. Comment. Glenn and Joan Baird, in a note dated July 30,
1997, said that the decision to do nothing at the Site is the
wisest and best and urged USEPA to stick to that decision.
USEPA Response. USEPA acknowledges their comment. This ROD does
select the "no action" remedy for these two operable units.
10. Comment. Mark Travers of de maximis, inc., commented on
behalf of the Marion (Bragg) Landfill Group (Group) (the Gener-
ator Defendants), in a letter dated July 31, 1997. The Group
believes the no-action remedy is appropriate because no impacts
on the river have been detected, no issues with the on-site pond
have been detected, the groundwater poses no current or future
risk to human health or the environment, and the existing moni-
toring systems will assure that the remedy continues to protect
Marion (Bragg) OUf 2 & 3 ROD. Ropomivencu Summary 8
-------
human health and the environment. The Group also believes that a
reduction in the extent of monitoring is appropriate and this is
supported by the conditions documented by the monitoring that has
been done. Contaminant levels in the groundwater have remained
low, site related constituents have not affected the river, and
water quality criteria in the on-site pond have not been exceeded
for the past two years.
USEPA Response. USEPA agrees that the no action alternative for
OUs 2 and 3 is appropriate. However, USEPA has made the deter-
mination that there is no risk to human health on the assumption
that groundwater in the upper aquifer under the northwest corner
of the cemetery to the west will not be used. To assure this,
USEPA believes that it is important that a deed restriction,
which the Group is seeking, be obtained to prevent the use of the
groundwater in the area to which contaminated groundwater from
the Site might flow.
USEPA will continue to evaluate further the results of the moni-
toring in order to determine what level of monitoring is now ap-
propriate. ,
11. Comment. IDEM commented, in a August 20, 1997 letter from
John Rose, Assistant Commissioner, Office of Environmental Re-
sponse, that IDEM does not support the "no action" proposal be-
cause there are no restrictions on groundwater usage for the
property underneath which groundwater from the Site travels prior
to its discharge into the Mississinewa River. Therefore, IDEM
feels that a risk to human health and the environment would re-
main. IDEM said that it could support the "no action" proposal
if groundwater use restrictions were in place on the property
affected by the Site.
USEPA Response. The Settling Defendants are pursuing a deed
restriction on the cemetery property to the west of the Site.
This is the only downgradient property under which groundwater
from the upper aquifer under the Site might pass before entering
the Mississinewa River, and this only happens in the northeastern
part of the property. Presently, this is a wooded area that lies
mostly, if not entirely, in the floodplain and the only access to
it is through the cemetery. USEPA expects that this deed re-
striction will be obtained.
On September 30, 1997, IDEM notified USEPA that it will provide a
letter of concurrence on the ROD on the basis that this deed re-
striction will be obtained.
12. Comment. Marijean Stephenson, in a letter dated August 26,
1997, resubmitted comments that had been submitted earlier with
regard to the Consent Decree proposed in 1990. She submitted, as
her own, the comments of: 1) David Hudak of the U.S Department of
the Interior, Fish and Wildlife Service; 2) Larry Davis, for USWA
Local #6786, HEC, PAHLS, and HEAL; and 3) James Simon of the
Natural Resources Defense Council. She said that she did not
Marion (Bna)OU>2 A3 ROD. Rop
-------
believe the comments were ever given serious consideration or
adequately addressed by USEPA, the Department of Justice, or any
other person or agency involved with decisions concerning the
future of this Site.
USEPA Response. First, it is necessary to respond to Ms. Ste-
phenson's letter. Except for the comments from the Fish and
Wildlife Service, the comments that she has submitted, as well as
others, were responded to in Exhibit A (Response to Comments) of
the Memorandum of the United States in Support of Motion to Enter
Consent Decree, 1991. It is USEPA's opinion that these comments
on that proposed Consent Decre^ were seriously considered and ad-
equately addressed at that time. The U.S. Fish and Wildlife Ser-
vice's comments that Ms. Stephenson has included with her letter
were not comments submitted by the U.S. Fish and Wildlife Service
on the proposed Consent Decree but are earlier comments of the
U.S. Fish and Wildlife Service that were an enclosure with their
comment letter on the proposed Consent Decree. None of the U.S.
Fish and Wildlife Service's comments were addressed in the 1991
Response to Comments because U.S. Fish and Wildlife withdrew its
comments from the public comment file in a February 27, 1991 let-
ter; note that these comments of U.S. Fish and Wildlife on the
proposed Consent Decree were comments on the litigation.
The specific comments are discussed briefly below.
a. Comment. U.S. Fish and Wildlife Service comments, let-
ter of August 25, 1989 from David Hudak. In comments that he
characterized as of a technical assistance nature only, Mr. Hudak
said that he believes that there is a valuable fish and wildlife
habitat in and adjacent to the Site. He summarized the selected
remedy for OU 1 and pointed out that there was to be, according
to the ROD: 1) quarterly sampling of surface waters at 3 on-site
pond locations and 5 river locations; 2) additional studies
consisting of fish bioassay work for on-site and off-site ponds
and the river,- and, 3) general toxicity tests on river ammonia
levels. He said that in a telephone conversation in 1989 he
learned that these additional studies might not be done. He did
not feel that the selected remedial actions would Le adequate to
protect the environment. He believed that bioassay work, tissue
residue levels, and ammonia toxicity modeling should be done. He
also said that he was pleased to learn that the original plan of
a levee for flood control had been revised, which will lessen the
impact on the riparian forest corridor.
USEPA Response. The OU 1 ROD requirements for determining the
effect of the landfill on the on-site pond, the river, and the
groundwater and for evaluating what protection or remediation of
the on-site pond or the river might be necessary was considered
further when the specifics for implementing the remedial action
were being determined during Consent Decree discussions. This
resulted in the decision-tree approach contained in the remedial
action plan that was included with the 1991 Consent Decree. It
is USEPA's opinion that this approach satisfies the goal of the
Marion (Bragg) OUi 2 & 3 ROD. Raponsivenas Summary 10
-------
OU 1 ROD that the aquatic environment of the river and the ponds
not be adversely affected by migration of the contaminants that
remain in place as part of the OU 1 remedy. USEPA believes that
the levels of ammonia in the river, where it has generally been
undetected, have not made it necessary to perform any toxicity
tests. And the overall level of contamination in the river and
the on-site pond have not been such that bioassay studies were
needed. See the discussion in section V of this ROD for OUs 2
and 3 about the results of the semi-annual sampling that has
taken place since February 1990. Also, the instream biological
assessment of the water quality in the river near the Site did
not show any significant environmental impact that was attribut-
able to the Site.
b. Larry Davis submitted a 18 page letter, dated October 8,
1990, with comments on the proposed Consent Decree. The response
that was attached to the "Memorandum of the United States in Sup-
port of Motion to Enter Consent Decree" filed for the proposed
Consent Decree in 1991 is attached hereto as Attachment A. The
section in this attachment dealing with .the comments of Healthy
Environment for All Life, Hooaier Environmental Council, and
PAHLS serves here as the summary of the technical points raised
in Mr. Davis's letter and USEPA'a responses to them.
c. James Simon of the Natural Resources Defense Council
submitted two letters dated October 9, 1990 furnishing comments
on the proposed Consent Decree; the second letter merely cor-
rected some errors in the first letter. The section in Attach-
ment A dealing with the Natural Resources Defense Council serves
here as the summary of the points raised in Mr. Simon's letters
and the responses to them.
13. Larry Davis, of Hebron, Indiana, submitted a 16 page letter
containing comments along with a 48 page attachment that covered
some of the history of the site that he had put together. The
attachment *-as apparently the same as the document that he had
submitted when he commented on the proposed Consent Decree in
1990 entitled "Selected Site History Document Summary". The
letter submitted here was dated September 22, 1997, but the
correct date was probably September 2, 1997. This date was al-
most a week after the comment period, which had been extended
beyond the normal 30 days to 60 days, had ended. Because the
comment letter was so late, specific responses are not provided.
USEPA has reviewed the letter for possible new information or
critical remarks not already made by other commentators that
might impact remedy selection and has concluded that there are
none. The letter will be placed in the Administrative Record,
however.
Marion (Bngf) OUs 2 & J ROD. Respooiivenen Summary 11. 9/97
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Marion (Bragg) Dump Site
Operable Units 2 and 3
Responsiveness Summary
Attachment A
COHflBMI
TABLE OF CONTENTS
I. RESPONSES TO TECHNICAL COMMENTS
A. Local Residents
B. Natural Resources Defense Council
C. Healthy Environment for All Life, Hoosier Environmental Council, and
PAHLS
The following persons or entities have submitted comments on the Decree which
relate to U.S. EPA's remedy and other technical issues:
•
- Healthy Environment for All Life, Hoosier Environmental Council, and PAHLS
• (collectively "Citizens Groups")
- Residents from the local community ("Residents")
Natural Resources Defense Council ("NRDC")
These responses will address these technical comments. The primary technical
comments are also addressed in the text of the motion to enter. Comments
which relate to a variety of legal issues are only addressed in the text of
the motion to enter.
A. Residents' Comments
Comment; The clay cap is not sufficiently protective of the
environment because it does not prevent or contain groundwater contamination.
Response; The proposed Decree, in accordance'with the ROD for
the site, implements an interim remedy at the site. Under the Decree, the
settling PRPs have agreed to construct a low permeability cap and cover over
designated areas at the site, and to perform further monitoring to determine
if the surface water and groundwater require remediation.
U.S. EPA concluded in the ROD that-installing a cap at the site will help
reduce groundwater contamination by minimizing the leaching of contaminants
into the groundwater. However, should monitoring results identify contamina-
tion which indicates that remediation of groundwater and surface water may be
required, U.S. EPA will address groundwater contamination in accordance with
the requirements of CERCLA, including all applicable public participation
provisions.
B. NRDC's Comments
1. Comment; The Natural Resources Defense Council ("NRDC") re-
quested confirmation that the actions described in the proposed Decree repre-
sent only an interim remedy for the site, and that any decision as to a final
remedy will be made pursuant to the public participation requirements of
CERCLA.
Response: The remedy selected for this site and encompassed by
the proposed Decree is an interim remedial action. As the ROD explains, this
Marion (Brajj) OUi 2 A 3. Rap. Sum. Atdi. A . Scanned. Refornaaed. 9/97
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site has three media of concern: surface soils and on-site wastes, ground-
water, and the on-site pond. The proposed Decree addresses the surface soil
contamination and on-site wastes by capping the site. The purpose of the cap
is to promote rain runoff, thereby reducing infiltration and prevent direct
contact with contaminated surface soils and surface wastes.
The determination of what remediation will be done, if any, of the groundwater
and the surface water is not covered by the proposed Decree. Rather, as di-
rected by the ROD, since the extent of groundwater and surface water contami-
nation and'the effect of the cap on that contamination could not be determined
fully without further monitoring, the proposed Decree provides for further
monitoring and studies at the site. Should monitoring of the groundwater and
surface water reveal that additional remedial work may be needed, a remedy
addressing the groundwater and/or surface water will be developed in accord-
ance with the requirements of CERCIA and the National Contingency Plan (NCP) ,
including all community relations and public participation requirements.
2. Comment; The proposed Decree does nof require compliance with
the National Pollutant Discharge Elimination System ("NPDBS") permitting re-
quirements of the Clean Hater Act, 33 O.S.C. §1311, et sea.. and a final rem-
edy must comply with NPDES requirements.
Response; First, CERCIA does not require an NPDES permit for
any migration of groundwater to the River. Under Section 121 (e) (1) of CERCIA.,
42 U.S.C. §9621(e)(l), Federal, Sta£e and local permits are not required for
remedial actions conducted entirely on-site, such as in this case.
Second, the Clean Water Act does not require an NPDBS permit for this site.
The NPDES program requires permits only for the discharge of pollutants from a
"point source", 40 C.F.R. § 122.Kb). The chronic migration of water from an
aquifer to a nearby river over a one-half mile stretch of river bank is not a
point source discharge under 40 C.F.R. S122.2.
Third, in any case, the interim remedy does not address the groundwater and
surface waters on the site. Thus, NRDC's comment is premature. Should moni-
toring reveal that remediation of these media may be required, any applicable
or relevant and appropriate requirements ("ARARs") will be identified in con-
nection with the proposal and selection of any subsequent remedy.
C. Citizens Groups' Comments
1. Comment: The Remedial Design/Remedial Action (RD/RA) Workplan,
and the documents required under the RD/RA Workplan (such as the sampling and
analysis plan and health and safety plan), are not available for public review
and comment. Thus, since the Workplan and the documents required under it
provide the details of the remedy, they cannot adequately comment on the
proposed Decree.
Response: First, notwithstanding the fact that the RD/RA Work-
plan has not been made public yet, the Citizens Groups, who prepared extensive
comments on the proposed Decree, have had access to considerable information
regarding the details of the remedy. The RI/FS Reports, the ROD, the proposed
Decree, and the Remedial Action Plan attached to the proposed Decree all pro-
vide substantial details about the site and the interim remedy for the site.
Moreover, the effectiveness and protectiveness of the interim remedy will be
determined by how well the remedy is implemented, not by the'details in the
Workplan and its associated documents.
Second, the fact that the final RD/RA Workplan is not available prior to entry
of this decree is not unusual. CERCZA and its regulations provide for public
participation before U.S. EPA issues a ROD and after a consent decree has been
lodged. In most cases, however, the RD/RA Workplan is not finalized until
after a court enters the consent decree. Typically, after a decree has been
entered, the parties performing the cleanup submit the RD/RA Workplan to U.S.
Minon (Bnu) OUi 243. Rap Sum. Au*. A 2 . Scanned. Reformoed. 9/47
-------
EPA for its review and approval. Thus, the public does not review the Work-
plan or any of the documents required under the Workplan (such as the sampling
and analysis plan or the health and safety plan) prior to commenting on the
Consent Decree.
In this case, Section VII(D) of the proposed Decree provides that the Workplan
will be finalized after entry of the Decree. Once the Workplan is finalized,
it will be annexed to the Decree in accordance with Section VIZ(D) (1), and
U.S. EPA will place a copy of the Workplan in the local information reposi-
tory. The public may then review the Workplan.
2. Comment; The integrity of the Facility is questionable as
additional landfill material was unearthed along the River bank, requiring
modifications to the remedial work of which the public has not yet been
informed.
•
Response: In the spring of 1990, as a result of severe weather
conditions, a few trees near the River bank.fell, unearthing landfill mater-
ial. In response, and in accordance with the ROD and Remedial Action Plan,
U.S. EPA is considering installing protection for part of the bank to minimize
the chances of landfill materials entering the river. Such minor supplemental
measures are often taken during the course of remedial action and are not sig-
nificant alterations of the interim remedy selected in the ROD.
3. Comment: The remedy., selected in the ROD fails to prevent
groundwater contamination or its migration off-site.
Response; As noted above, the proposed Decree does not address
the Contamination in the groundwater at the site, except to require ground-
water monitoring. Based on the further monitoring, U.S. BPA will determine,
if the surface water and groundwater require remediation. The capping of the
site should reduce groundwater contamination by minimizing the leaching of
•contaminants into the groundwater. However, if monitoring results indicate
that remediation of groundwater and surface water are required, U.S. EPA will
proceed, in accordance with CERCLA and the NCP, with appropriate measures at
that time.
4. Comment; The City of Marion was "coerced" into accepting the
costs of operation and maintenance of the landfill. Moreover, these costs are
potentially open ended, and information related to the city's potential lia-
bility has not been made available to the public.
Response; The CJ
-------
draft documents received from the settling PRPs. Moreover, particularly where
U.S. EPA has disagreed with the State's views, U.S. EPA has provided a written
response to the State's comments explaining any differences of position. In
addition, the State has regularly attended the meetings with the settling PRPs
regarding implementation of the remedy.
6. Comment! U.S. EPA has not issued a notice of significant
changes, although such changes have been made, such as noncompliance with
applicable or relevant and appropriate requirements (" ARARs•), including the
environmental regulations of the State of Indiana.
Response: It is difficult to address this comment because it
is not entirely clear from the comments what specific changes the commenter
alleges have been made which are allegedly "significant changes." However,
U.S. EPA has made no changes to the terms of the proposed Decree since it was
signed. Nor have "significant changes" been made to the interim remedy se-
lected in the ROD during design and implementation of the remedy.
Under Section 300.435(c) (2) of the National Contingency Plan, U.S. EPA need
only issue an explanation of significant differences where, after the adoption
of the ROD, the remedial or enforcement action taken, or the settlement or
Consent Decree entered into, differs significantly from the remedy selected in
the ROD with respect to scope, performance or cost. See 40 C.P.R. §
300.435(c) (2). Here, U.S. EPA has not altered the remedy significantly since
the issuance of the ROD (see e.g.. Response to Comment C-3, supra). and the
RAP is fully consistent with the goals and directives of the ROD (see Response
to Comment C.8, infra). Moreover, U.S. EPA has certainly complied with all
ARARS, including all State regulations, in selecting and implementing the
remedy for this site. The ARARs for this interim remedy are set forth in.the
ROD, and Section VII(C) of the Consent Decree requires the settling PRPs to
comply with all ARARs during remedial design and remedial action at the site.
7. Comment; The Remedial Action Plan ("RAP"), attached to the
Decree as Appendix B, is not consistent with the ROD and/or the Decree in the
following respects:
a. Comment; The RAP provides that monitoring will "show" the
effectiveness of the remedy, while the ROD provides that monitoring will "de-
termine" the remedy's effectiveness. Thus, the RAP is predisposed to find no
environmental or human health impacts.
Response; In this context, both words mean essentially the
same thing. Under both the ROD and the RAP, U.S. BPA's objective is tc ana-
lyze the data obtained from monitoring in order to determine whether or not
additional remedial action will be needed at the site to address the ground-
water and surface waters. By using the term "show" rather than "determine",
the RAP does not alter this objective nor does it predetermine monitoring
results.
b. Comment: The RAP does not comport with the ROD with re-
gard to the manner in which leachate seeps and uncovered hazardous materials
are addressed during the interim remedy.
Response: There is essentially no difference in the way
that the RAP and the ROD address leachate seeps and drums or other hazardous
wastes. First, both provide that contaminated leachate seeps and sediments
will be removed and/or covered by the cap. The ROD provides•that, if leachate
seeps are not eliminated, seep collection will be required. Under the RAP and
the proposed Decree, if the leachate seeps are not contained, additional work
regarding the seeps will be required under Section IX of the Decree.
Second, the ROD provides that during the course of regrading any drums or
other hazardous wastes, if present, would be removed according to RCRA, Here,
under the RAP, if drums containing liquids are found, the drums must be set
Marion (Bn|f) OUi 2*3. Hop- &><". Atch. A 4 Scanned. RefomiMied. 4/OT
-------
aside and sampled. If the liquid is hazardous, it will dealt with as hazard-
ous waste under RCRA. EPA recognizes that such liquid hazardous wastes (in
containers that may eventually leak) may pose a threat to the groundwater at
the site. If the liquid is not hazardous, it still will be taken off-site,
but as a non-hazardous waste. Any solid waste, after years of exposure near
the surface, is more than likely to be fairly insoluble in water and therefore
does not present a viable threat to the groundwater. As a result, such waste
will be covered in the course of regrading. Moreover, as outlined above, if
the groundwater contamination requires remediation, a final groundwater remedy
will be selected.
In any case, it is important to note that since the settling defendants
brought in fill and less excavation was done, during the installation of the
cap. only one drum which contained liquid waste was uncovered and
characterized. '
c. Comment; The RAP incorrectly reported that the RI and the
ROD concluded that there is no potential for contamination of upgradient
private-use wells and that the impacts of contaminants from the upper aquifer
on the River are minimal.
Response; The RAP does not state that the RI and ROD
reached this conclusion. The RAP states that there is little, if any, poten-
tial for contamination of private-use wells which are upgradient from the
groundwater and surface water at the site, and presents support for this
statement.
Second,, the RAP does not state that the ROD concludes the impacts on the River
are minimal. However, both the RI and ROD provide information that would sup-
port such a conclusion. Section 5.3.2.2 of the RI states that exposure path-
ways associated with the river are considered to be negligible, leading to the
conclusion that the effects on the river are minimal. Moreover, Section
II (D) (4) (b) of the ROD states that the RI/PS concludes there is no currently
identified risk to the River, although the potential for such risk exists.
d. Comment; New monitoring wells have been installed at the
site and the old monitoring wells have been abandoned. Therefore, it is not
possible to compare the results obtained during the RI with the results that
will be obtained in the future.
Response; Both the PS and the ROD, recommended the in-
stallation of new monitoring wells. The purpose of the monitoring wells is to
determine whether further action is requ *ed to remedy groundwater contamina-
tion at the site. To make this determination, U.S. EPA will.not compare
results from different monitoring wells over time. Rather, U.S. EPA will
analyze the results of groundwater monitoring that is done after the cap has
been installed and then determine whether further action is necessary.
e. Comment; The results of sampling performed in February of
1990 have not been made available to the public yet.
Response; U.S. EPA received these results after the close
of the public comment period. It will make them available to the public
shortly.
f. Comment; The Consent Decree calls for thirty years of
monitoring of the cap, while the RAP only calls for five years of groundwater
sampling.
Response: Paragraph VII(D)(7)(a)(ii) of the proposed De-
cree states that "[m]onitoring shall continue for a period of at least thirty
years after the construction of the cap is complete, unless it can be demon-
strated to the U.S. EPA's satisfaction that further monitoring is not neces-
sary." This monitoring, which covers sampling of groundwater and surface
Marion (Bragj) OUi 243. Rap. Sum. Alch. A 5 Seamed. Reformacd. 9/97
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waters, shall be done. The fact that Figure 4-3 of the RAP only shows sam-
pling through five years does not mean that- sampling will cease at that time.
Rather, sampling will continue .until U.S. EPA is satisfied that further
monitoring is not necessary.
g. Comment; The RAP calls for sampling of indicator parame-
ters on a semi-annual basis, while the ROD calls for the testing of indicator
parameters every quarter and the testing of priority pollutants semiannually.
Response; Figure 4-3 of the RAP shows that analyses for
indicator parameters will be done every quarter. These parameters are listed
in Table 4-1 of the RAP. The statement in the RAP (Section 4.1.5) that
mentions the evaluation of the data to get indicator parameters refers to the
addition of certain parameters to the list of indicator parameters on a semi-
annual basis. The Target Compound List, a list that U.S. EPA presently uses
at Superfund sites, is currently being used for the semi-annual testing. The
substances on the Target Compound List are not significantly different from
the substances which were analyzed for during the RI at this site.
h. Comment: The ROD does not provide for the averaging of
results from water quality analyses of monitoring wells, although the RAP does
allow such averaging.
Response; All of the results of the analyses of the moni-
toring wells will be reported, not }ust the averages. Averaging of results
from the analyses of samples from monitoring wells will be used in making de-
cisions as to what studies will be performed. The ROD does Hot prohibit the
use of averaging, which is a technically acceptable approach.
i. Comment; The RAP states only that criteria for the
evaluation of groundwater and surface water will include "appropriate
standards," while the ROD calls for compliance with all ARARa and for the
performance of appropriate bioaccumulation and general toxicity evaluations.
Response; There is nothing in the RAP which indicates
that criteria and standards will not be based on ARARS. Under Section XXIV of
the Consent Decree, all work must be consistent with the National Contingency
Plan. Therefore, properly identified ARARs must be observed. In addition,
the RAP does provide for the performance of bioaccumulation studies and other
biological studies.
j. Comment; The RAP calls for sampling to occur at an island
in the River which the Army Corps of Engineers and the Grant Bounty Commis-
sioners removed during the summer of 1990.
Response; The RAP does not provide for sampling on the
island, but downstream .>f the island. Furthermore, only proposed locations
are shown in the RAP and locations are, consequently, approximate. The sam-
pling mentioned is actually taking place opposite the north boundary of the
site near the west boundary. For clarification, the Army Corps of Engineers
did not remove the island, although they were involved in the permitting
process, and the island was removed in the winter and spring of 1990.
k. Comment;' The RAP's list of basic parameters excludes PCBs
and pesticides. The ROD does not allow for such a reduction of the testing
parameters.
Response; The ROD does not preclude the .deletion of PCBs
or pesticides from the list of parameters for groundwater and surface water
testing. During the RI neither pesticides nor PCBs were detected in the
groundwater monitoring wells on the site, the leachate wells, or the surface
water.
1. Comment: The RAP preconditions the performance of biolog-
Marion (Br«jg) OUi 2 A 3. Rap. Sum. Atdi. A 6 Scumd. Refonruncd. 9/97
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ical studies on the failure of the groundwater or surface water to meet cer-
tain standards, and limits the parameters that will be studied (Section
4.5.1) . The ROD, on the other hand, does not precondition bioassay work and
lists the classes of compounds from which parameters are to be selected, which
list includes, PCBs.
Response; Under the Decree, as more technically defined in
the RAP, biological studies will be performed if EPA determines, after ad-
ditional study of the groundwater, surface waters and the river sediment, that
these media are the same as they were at the time that the RI was done, or
worse. Given that the purpose of the additional studies in the ROD was to
provide information that can be used in deciding whether any further remedial
actions are needed at the site to address groundwater and surface water con-
tamination, this is fully consistent with the ROD.
Moreover, the only additional limitations on one type of biological study, a
bioaccumulation study, are that the substances that are being evaluated must
be present at the site and have the potential to bioaccumulate (Figure 4-5 of
the RAP) . The ROD does not prohibit such requirements. In addition, contrary
to the commenters' assertion, the ROD makes clear that parameters are to "be
selected from* volatiles, PAHs and inorganic constituents. See ROD at 17. In
the nomenclature used with the Target Compound List, PCBs do not fall within
any of these three classes of substances. Furthermore, as set forth above in
Response (k), supra. PCBs were not found in the groundwater or surface water
at the site. ,
m. Comment; The RAP allows for the dilution of contaminants
to be considered as an additional "safety factor* when determining if further
remedial action is necessary, but the ROD does not permit this.
Response; The RAP does not provide that dilution of con-
taminants will be considered in determining if further remedial action will be
necessary at the site. Decisions regarding further remedial action will be
made in' accordance with the requirements of the National Contingency Plan.
8. Comment; The Consent Decree and its attachments, in particular
the RAP, do not comply with ARARS, as required by Section 121(d)(2)(A) of
CERCLA, 42 U.S.C. §9621(d) (2) (A) .
Response; Since the Citizens Groups did not specify which
ARARs they claim the proposed Decree and its attachments failed to meet, it is
very difficult to address this comment. Under CERCLA Section 121(d)(2)(A), a
remedy must comply with all applicable or relevant nd appropriate Federal en-
vironmental regulations, as well as all State environmental regulations which
are more stringent than any Federal standard and which the State has identi-
fied to U.S. EPA in a timely manner. The interim remedy selected for this
site complies with all identified ARARS, as set forth in Section VI (A) of the
ROD. The proposed Decree does not alter the interim remedy, and thus comports
with the ARARs set forth in the ROD.
9. Comment; The proposed Decree "seeks provisions in the ROD and
Remedial Action Plan (RAP) to establish alternate concentration limits
(' ACLs' ) " for groundwater and surface water at the site under the provisions
of Section 121 (d) (2) (B) (ii) of CERCLA, 42 U.S.C. §9621 (d) (2) (B) (ii) .
Response; This comment does not identify what Section of the
proposed Decree allegedly refers or relates to ACLs. From the context of the
comment, it may be referring to paragraph VII(D)(7) (f) (i) of the proposed
Marion (Bragg) OUi 2*3. Rap. Sum. Aidi. A 7 Scanned, Refomaaed. 9/97
-------
Decree. However, this provision of the proposed Decree does not refer to, let
alone establish, ACLs.
In fact, the ROD and the proposed Decree do not refer to or discuss ACLs
because, as outlined above, this interim remedy does not address what action
may be needed for groundwater or surface waters at the site, except to the
extent that it provides for additional study of these media. U.S. EPA need
not establish ACLs for an interim remedy which only addresses the surface
soils and on-site wastes.
10. Comment: U.S. EPA has "massaged" monitoring results through
statistics and geometric means.
Response; There is absolutely no basis for the assertion that
U.S. EPA has massaged monitoring data1. U.S. EPA has not engaged in any such
activity, and has made, and will continue to make, monitoring data available
to the public in the information repository.
11. Comment; The proposed Decree fails to analyze the long-term
uncertainties and possible failures of the containment and capping aspects of
the interim remedy. Because of these unidentified uncertainties, the remedy
is not cost-effective.
Response; Contrary to the commenter's assertions, the PS
Report and ROD specifically address^the long-term effectiveness, as well as
the cost-effectiveness, of the selected remedy. In fact, She evaluation of
remedial alternatives in the PS demonstrated that more permanent alternatives
involving treatment of the soils, such as incineration, were prohibitively
expensive and impracticable when compared with the selected interim remedy.
See Section VI (B) of the ROD. It should also be noted that containment tech-
nologies, such as the cap in this case, are generally considered appropriate
for wastes, such as those here, that pose a relatively low long-term threat to
human health and the environment. See Section 300.430(a) (1) (iii) (B) of the
National Contingency Plan, 40 C.F.R. §300.430(a) (1) (iii)(B).
Further, the ROD makes clear that, because hazardous substances will remain
on-site, the interim remedy will require long-term operation and maintenance
and, under Section 121(c) of CERCLA, 42 U.S.C. §9621(c), U.S. EPA must conduct
periodic reviews of the effectiveness of the remedy. Thus, in addition to the
review of monitoring data and studies, these periodic reviews will assess
whether the interim remedial action, is protective of human health and the
environment and determine whether further action is necessary.
In addition, since this is an interim remedy, the lc_.-j-term effectiveness and
permanence of the remedy will best be evaluated when the groundwater issue is
resolved. The fact that this is an interim remedy will not create a false
sense of security or lead to land use that will complicate future cleanup, as
the commenter suggests. To the contrary, a restrictive covenant prevents use
of the site in any manner that may threaten the effectiveness, protectiveness
or integrity of the interim remedy.
12. Comment; The sampling presently called for in the ROD may be
insufficient to detect "hot spots" of contamination at the site.
Response; During the extensive remedial investigation of this
site, U.S. EPA found no physical or documentary evidence to indicate the pres-
ence of "hot spots" of contamination on the site. Moreover, it has not re-
ceived any new information since the RI to indicate that there are any such
hot spots on the site.
13. Comment; The proposed Decree does not provide specific
technical criteria for subsequent decisions, nor does it provide, assurances
that U.S. EPA will adequately oversee the settling PRPs' work at the site or
that the work will be done properly.
Marion (Brau) OUs 2 & 3. Rap. Sum. Aldi. A 8 Scanned. Refocmaied. 9/97
-------
Responae: The proposed Decree sets up the framework under
which the settling PRPs conduct, and U.S. EPA oversees, the remedial design
and action at the site. This ROD calls for monitoring of groundwater and
surface water to determine if further action is necessary. Decisions as to
whether such actions will be necessary will be made in accordance with the
National Contingency Plan.
Second, a number of provisions in the proposed Decree ensure that the work at
the site will be done properly. For example, under Section VII of the Decree,
U.S. EPA will oversee the development of work plans for the site. Further,
Section X of the Decree provides for quality assurance, which includes the
preparation of a Quality Assurance Project Plan regarding sampling and analy-
sis, in addition, Section XI of the Decree requires the settling generator
PRPs to provide to U.S. EPA and the State, on a regular basis, all sampling
results and other data, and to give U.S. EPA and the State, upon their re-
quest, split or duplicate samples of all samples which the PRPs collect at the
site. Section XII of the Decree further elaborates the settlors' reporting
obligations.
14. Comment; U.S. EPA has not taken into account in its remedy the
oil and gas wells which are purportedly still on the site and the effect these
wells may have on the possible contamination of the lower aquifers
Response; U.S. EPA was aware of the possible presence of oil
and gas wells at the site even before the RI began. However, U.S. EPA never
found any such wells at the site. As the site has been used for gravel and
then landfill operations for decades, it is not surprising that none of the
wells apparently still exist at the site. Regarding the lower'aquifer, U.S.
EPA found during the RI that the pressure in the lower aquifer was much higher
than in the upper aquifer, leading to the conclusion that there is more than
likely no direct connection between the two aquifers in the vicinity of the
site. Therefore, there is little danger of contamination of the lower aquifer
at the site.
*
15. Comment; The "land ban* requirements of the Resource Conserva-
tion and Recovery Act ("RCRA"), which restrict the disposal and placement of
contaminated materials, have not been followed at this site.
Response; As U.S. EPA made clear in the ROD, RCRA land dispos-
al requirements are not triggered by the interim remedy. This is because
under U.S. EPA's interpretation of RCRA, consolidation of waste within a unit
does not constitute "placement or disposal" under RCRA land disposal restric-
tions. Here, the interim remedy calls for consolidation ann regrading of the
material already on-site in preparation for the construction, of the cap.
16 Comment; The proposed Decree limits the ability of U.S. EPA
and the U.S. Fish and Wildlife service (FWS) to commence an action for natural
resource damages.
Response: The proposed Decree does not in any way limit the
discretion of any agency to commence a natural resource damages action. To
the contrary, the Decree does not address natural resource damages except to
expressly reserve, in Section XIX, the natural resource trustee's right to
bring a claim for such damages in the future. There is no finding in the
Decree, nor will there' be any finding during design and implementation of the
interim remedy, with respect to natural resource damages which limits the
period in which such an action may be brought.
Marion(BraU)OUs2&3. Rap. Sum. Atch. A 9 Seamed. Reformmed.
-------
Administrative Record Index — Marion/Bragg Landfill
Administrative Record for Marlon/Bragg Landfill. Grant County. ledlana
i$ of September 30. 1987. . \
*
i "'
i
File I 1. PA/SI. HRS
• Raw data for scoring package
2. Site Inventory
>s fro* observation during site visits
• file search Information obtained during RAMP period
Including: land ownership, water well records, city
township location documentation
3. RAMP (Remedial Action Master Plan)
9/9/83
4. Rl/FS initiation
• letter from IDEM requesting project initiation and making
Assurances
• RI/FS Statement of Work
5. Work Plan memorandum 6/19/8S
6. Community Relation Plan 2/10/86
•
7. Initial Site Evaluation 8/20/85
8. Groundwater Utilization Survey 7/18/85
9. Draft Geophysical Investigation . Fall '85
10. Work Plan - PRP negotiating draft 10/11/85
•
11. Final Work Plan 4/24/86
12. Final Quality Assurances Project Plan 7/10/86
13.' Final Health and Safety Plan 4/24/86
14. Phase II Sampling and Analysis Memorandum 6/2/86
-------
-2-
15. Request for applicable, relevant and appropriate requirements.for
. Remedial Alternatives 3/6/87 I
-• »
j USEPA Comments:
1 • Hater Division 4/28/87
• Air Division ^ 6/17/87
• Great Lakes National Program Office 4/27/87
• Solid Haste Branch 4/15/87
IDEM Comments: 5/4/87 and 7/27/87
*
16. Quality Assurance Project PIart - Addendum One for supplemental sampling
( May. 1987)
17. General Correspondence File - Contains various comments and
correspondence with other Agencies suoh as; ATSDR, ISBH. IDEM and
U.S. Fish and Wildlife Service.
• ISBH letter identifing water quality standards 7/3/85
• Fact sheet. Public "Kick-off meeting 1/30/86
• ISBH comments to Draft QAPP and Health and 9/25/85
Safety Plan
• ISBH comments to T~aft Work Plan 10/9/85
• ATSDR comments to Draft Work Plan and Draft 10/23/85
QAPP
• Memo from Potentially Responsible Party meeting of 11/7/85
• ATSOR memo for review of residential drinking 11/9/85
water samples '
• ISBH additional comments on Work Plan and QAPP 2/6/86
* U.S Fish and Hlldlife comments on surface water and 6/10/87
sediment data
-------
- 3 -
18. Applicable Guidance
19. Comments to Agency Proposed Plan
Uncopied references which are available at the Regional Office in
Chicago, Illinois:
1. Guidelines for the Pollution*! Classification of Great Lakes
Harbor Sediments - April. 1*77
2. Raw Data fro* all RI field investigations
The reader should note that in 1986 the Indiana State Board of Health
(ISBH) was reorganized and the Indiana Department of Environmental
Management (IDEM) was created.
-------
a.s. nn
RAL PROTBCr:
)IAL ACTIOM
ADKIMI8TRATXVI RZCORD
VOK
BTOfll/BBM7 LAWDFXLL 8ITB
ORAVT (JUWK1, IMDIAOTl
nra&n ti
JOLT 27, 1992
HO. DXTK
1 09/12/84
2 02/15/85
PAQ18
Const«nt«loa, B., K«nd*ll, 8.,
U.S. DA Indiana Stat*
Budg«t
Danialaon, T.8., Adaakua, v.,
of ttaalth
Notification of
Propoaad 8up«rfimd
Projacfe
R*qu«at for
Initiation of
RI/F8 Study
TO
mutrxvB BMCQKD
MAT 13, 1997
HO. DATK
1 09/30/87
O.8. KPA
U.S. KPA
Racord of Oaciaion 80
-------
AK
U.S.
RBMBDXAL ACTXOV
(BRA00) LANDFILL SITB
UPDATE ta
s, 1997
07/00/87
Camp Dreaaer
6 McKee Inc.
U.S. BPA
07/00/87
Camp Dreaser
& McKee Inc.
U.S. BPA
07/00/87
09/30/87
07/00/89
01/27/90
Dreaaer
ft McKee Inc.
U.S. BPA
Environmental
Reaourcea
Management
U.S. BPA/CRL
U.S. BPA
Public
Marion (Bragg)
Landfill PRP
Group/U.S. BPA
U.S. EPA
11/00/90
12/00/90
Beak
Consultants
Limited
De Maxiraia,
Inc.
Marion Bragg
Landfill Group/
U.S. BPA
Marion Bragg
Landfill Group/
U.S. BPA
Remedial Investigation 328
Report for the Marion
(Bragg) Landfill Site:
Volume 1 of 2 (Text,
Tablea and Pigurea)
[PUBLIC COMMENT DRAFT]
Remedial Inveatigation 471
Report for the Marion
(Bragg) Landfill Site:
Volume 2 of 2 (Appendices
A-K) [PUBLIC COMMENT
DRAFT]
Feasibility Study 207
Report for the Marion
(Bragg) Landfill Site
[PUBLIC COMMENT DRAFT]
Record of Decision 71
for the Marion (Bragg)
Dump Site
Quality Aaaurance 452
Project Plan (QAPP)
Monitoring and Additional
Studiea at the Marion
(Bragg) Landfill Site
Superfund Biological 24
Survey: •Inatream Fish
Hater Quality Evaluation"
for *--he Marion Bragg
Landfill Site w/Attached
February 23, 1990 CRL
Review of Region 5 Data
Sheeta
Quarterly Report 224
(February 1990) : Baaeline
Water Quality Conditions
at the Marion (Bragg)
Landfill Site
March 1989 Remedial
Design/Remedial Action
Work Plan for the Marion
(Bragg) Landfill Site
(Reviaed) w/Attached
July 24, 1992 U.S. BPA
Approval Letter
34
-------
Marion (Bragg) Aft
Update 12
Page 2
01/00/91
10
02/00/91
11 04/00/91
12
13
04/24/91
06/18/91
Beak
Consultants
Limited
Beak
Consultants
Limited
Beak
Consultants
Limited
U.S. District
Court /Northern
District of .
14 08/00/91
15
02/00/92
16 05/00/92
17
18
05/00/92
09/00/92
Butler, B. and
C. Mayfield;
University of
Waterloo
(Canada)
Beak
Consultants
Limited
Beak
Consultants
Limited
Beak
Consultants
Limited
Beak
Consultants
Limited
Beak
Consultants
Limited
Marion (Bragg)
Landfill Group/
U.S. SPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Parties to
the Consent
Decree
Beak
Consultants
Limited
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Quarterly Report (May
1990): Hater Quality
Conditions at tlw
Marion (Bragg) Landfill
Site
Quarterly Report
(November 1990) : Water
Duality Condition* at
the Marion (Bragg)
Landfill Site
Semi-Annual Report
(August 1990): Water
Quality and Sediment
Quality Conditions at
the Marion (Bragg)
Landfill Site
31
29
213
226
22
Report: "Detection of
Iron Bacteria in River
Sediment, Soil and Well
Water Samples"
Quarterly Report (May 28
1991): Water Quality
Conditions at the
Marion (Bragg) landfill
Site
Water Quality Conditions 189
for the Period February
1990 - February 1991 at
the Marion (Bragg)
Landfill Site
Semi-Annual Report 168
(August 1991): Water
Quality Conditions at
the Marion (Bragg)
Landfill Site
Quarterly Report 33
(November 1991): Water
Quality Conditions at the
Marion (Bragg) Landfill
Site
Water Quality Conditions 194
for the Period February
1990 - February 1992 at
the Marion (Bragg)
Landfill Site
-------
lea (Bragg) AR
Update §2
Pag* 3
19 12/00/92 OCM. Inc.
20 09/00/93 U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
August 1991 Operation 105
and Maintenance Plan
at the Marian (Bragg) -•
Landfill Site (Revised)
Report of the Completion 385
of Remedial Design and
Resadial Action (Final
Inspection Report) at
the Marion (Bragg)
Landfill Site
21 11/15/96 0&M. Inc.
22 11/15/96
OCM, Inc.
23 11/15/96 OtM, Inc.
24
11/15/96
OU1. Inc.
25
11/15/96
OUt, Inc.
26 11/15/96
OUt, Inc.
Marion (Bragg)
Landfill Group/
•U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Report (Second Quarter 97
1992): Mater Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised June 1992
Report)
Report (Third Quarter 401
1992): Mater Quality
Conditions at thiE
Marion (Bragg) Landfill
Site (Revised February
1993 Report)
Report (Fourth Quarter 49
1992): Mater Quality
Conditions at the
Marion (Bragg) Landfill.
Site (Revised February
1993 Report)
Report (First Quarter 353
1993): Mater Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised September
1993 Report)
Report (Second Quarter 90
1993): Mater Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised Hovember
1993 Report)
Report (Third Quarter 363
1993): Mater Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised February
1994 Report)
-------
Marion (Bragg) Aft
Update 12
Pag* 4
27 11/15/96 GUI, Inc.
28 11/15/96 OUI, Inc.
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Report (Fourth Quarter 50
1993): Water Quality
Conditions at the
Marian (Bragg) Landfill '
Site (Revised March
1994 Report)
Report (First Quarter 444
1994): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised August .
1994 Report)
29 11/15/96 O&M, Inc.
30 11/15/96 O&M, Inc.
31 11/15/96 O&M, Inc.
32 11/15/96 OfcM, Inc.
33 11/15/95 O&M, Inc.
34 11/15/96 O&M, Inc.
•Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Report (Second Quarter 47
1994): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised December
1994 Report)
Report (Third Quarter 401
1994): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised February
1995 Report)
Report (Fourth Quarter 48
1994): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised April
1995 Report)
Report (First Quarter 410
1995): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised January
1996 Report)
Report (Second Quarter 66
1995): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised January
1996 Report)
Report (Third Quarter 387
1995): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site (Revised January
1996 Report)
-------
Marion (Bragg) Aft
Update §2
Pag* 5
35 • 05/00/97 O£M, Inc.
36 05/00/97 OfiM, Inc.
37 05/00/97 OCM, Inc.
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
Report (Fourth Quarter 46
1995): Water Quality
Condition* at the
Marion (Bragg) Landfill
Site
Report (First Quarter 415
1996): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site
Report (Second Quarter 51
1996): Water Quality
Conditions at the
Marion (Bragg) Landfill
Site
38 05/00/97 OCM, Inc.
39 06/24/97 Schorle, B.,
U.S. BPA
Marion (Bragg)
Landfill Group/
U.S. BPA
File
Report (Third Quarter
1996): Water Quality
Conditions at the
Marian (Bragg) Landfill
Site
Memorandum re: Guidance
Documents
514
-------
Marion
(Bragg) AR
Update t3
Pag* 2
07/28/97 U.S. BPA
Public
10
07/31/97
11 07/31/97
Travers, M.,
Do Maxiais,
Inc.
Schorle, B.
U.S. SPA
Schorle, B.,
U.S. BPA
12 08/20/97 Rose, J.,
IOBM
13 09/04/97 Concerned
Citizen*
Pabinski, L.,
uSDUHS/ATSDR
Schorle, B.
U.S. BPA
Bmeric. N.,
U.S. BPA
Public Notice re:
Announcement of Public
Comment Period for the
Preferred Alternative
for Operable Unit* 2
and 3 at the Marion
(Bragg) Dump Site
[Chronicle-Tribune)
Letter re: Marion (Bragg)
Landfill Group'a Comments
on the Proposed Plan for
Operable Units 2 and 3
at the Marion (Bragg)
Landfill Site
Letter re» February 1995
Public Health Assessment
for the Marion (Bragg)
Dump Site w/Attachtnents
Letter re: ZOBM's
Comments on U.S. BPA's
Proposed Plan for "NO
Action* at the Marion
(Bragg) Dump Site
34
14
00/00/00
U.S-. BPA
Public
Five Public
Letters Received
Between July 17 -
September 4, 1997 re:
the Proposed Plan for
the Marion (Bragg) Dump
Site w/Attachnenta
Record of Decision for
Operable Units 2 and 3
at the Marion (Bragg)
Landfill Site (PENDING)
-------
U.S. KNVIRONKBITAL PROTECTION AGENCY
REMEDIAL XCTIOH
[XSTRATXVE RECORD
FOR
MARION (BRAOQ) LANDFILL 8ZTB
MARION, GRANT COUNTY,
UPDATE §3
30, 1997
HO. DATE
1 00/00/90
2 04/11/90
AUTHOR
U.S. District 'Respondents
Court/Northern
District of
TTTtK/DMCftlPTIOH
PACKS
3 08/15/90
U.S. District Respondents
Court/Northern
District of
Indiana
U.S. District Respondents
Court/Northern
District of
4 02/07/95
5 06/00/97
6 06/00/97
USDHHS/USPHS/ U.S. BPA
ATSDR
U.S. BPA
U.S. BPA
7 06/27/97 U.S. BPA
File
Public
Public
8 07/16/97 U.S. BPA
Public
Memorandum of the United 267
States in Support of
Motion to Enter Consent
Decree re: the Marion
(Bragg) Dump site
Motion to File Brief in 3
Accordance with Local
Rule 12 re: the Consent
Decree for the Marion
(Bragg) Dump Site
Motion for Extension 3
of Time Concerning the
Public Comment Period
for the Consent Decree
re: the Marion (Bragg)
Dump Site
Public Health Assessment 45
for the Marion (Bragg)
Dump Site
Marion Bragg Mail List 8
Proposed Plan for 14
Operable Units 2 and 3
at the Marion (Bragg)
Dump Site
Public Notice re: l
Announcement of (1)
July 16, 1997 Public
Meeting and (2) Public
Comment Period for the
Preferred Alternative
for Operable Units 2
and 3 at the Marion
(Bragg) Dump Site
[Chronicle-Tribune]
Transcript of July 16, 98
1997 U.S. EPA Public
Meeting re: the Proposed
Plan for the Marion
(Bragg) Dump Site w/
Attached Sign-In Sheet
(PORTIONS OF THE SIGN-IN
SHEET HAVE BEEN REDACTED)
------- |