United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-88/070
June 1988
&EPA
Superfund
Record of Decision
IMC Terre Haute, IN
-------
50273-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-88/070
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
IMC/Terre Haute, IN
econd Remedial Action - Final
5. Report Oete
06/22/88
Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. ContracUC) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, s.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The IMC/Terre Haute site is located in southeastern Terre Haute, Vigo County,
Indiana. The 37-acre site is bordered on the west by the Milwaukee, St. Paul, and
Pacific Railroad .and on the east by the Louisville Railroad. The site is part of a
semi-industrialized area of Terre Haute and is 1.8 miles east of the Wabash River anp 1
mile north of the Thompson ditch. A waste disposal area, encompassing approximately six
acres, is located in the northeastern portion of the plant site. From 1946 to 1954 a
hmall facility on a six-acre segment of the property manufactured, packaged, and
arehoused technical-grade benzene hexachloride (BHC-tech). This material was sold to
insecticide manufacturers as a raw material for the production of insecticides,
including lindane. The site has been owned by International Minerals and Chemical
Corporation since 1975. IMC conducted surficial and subsurficial soil sampling in 1979,
finding that contamination was within seven feet of the surface and well above the
ground water table. Seven ground water monitoring wells were installed at the site, and
samples indicated measurable BHC concentrations in two of the wells. In 1980,
approximately 28,500 yd3 of soil, rubble, piping and other debris were excavated and
placed in a secure clay-capped mound to prevent offsite migration of BHC-tech. The cap
system included a surface drainage collection system and soil gas venting. The
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
IMC/Terre Haute, IN
Second Remedial Action - Final
Contaminated Media: gw, soil
Key Contaminants: pesticides
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
P'
ivailability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
76
22. Price
(See ANSI-Z39.18)
See Instruction! on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce ,
-------
^PA/ROD/R05-88/070
MC/Terre Haute, IN
Second Remedial Action - Final
16. ABSTRACT (continued)
concentration in ground water of lindane, the gamma isomer of BHC, declined relatively
quickly after construction of the mound and has continued to decline at a slower' rate
since 1983. The soil cleanup and mound construction has proven to be effective in
containing the source of BHC-tech and in reducing ground water contamination to MCL and
MCLG concentrations. The primary contaminants of concern are lindane and total BHC.'
The selected remedial action for this site is no further action with a maintenance
program, which includes: inspection of the existing cap quarterly, and maintenance of
the vegetative cover; initiation of a ground water monitoring program (sampling of
upgradient and downgradient wells semi-annually for the next five years and then
annually until 2010); access restrications; and establishment of a contingency plan.
The estimated present worth cost for this remedial action is $159,000 for O&M of the
existing system.
-------
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE: IMC EAST PLANT
Terre Haute, IN Site (IMC)
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents describing the
analysis of cost-effectiveness of remedial alternatives for the IMC site:
1. P.E. LaMoreaux and Associates (PELA), "The Impact of Waste
Disposal Practices on the Hydrogeologic System- at IMC East Plant,
Terre Haute, Indiana". March 1980
«
2. Camp Dresser &.McKee, fnc. (COM), "Waste Disposal Alternatives for
the East Plant Site". May 1980
3. Camp Dresser & McKee, Inc. (COM),-["Plans and Specifications for
International Minerals and Chemical Corporation, Terre Haute,
Indiana". July 1980
4. Ecology and Environment Inc. (E&E), "Groundwater Contamination
Study, International Minerals & Chemical Corporation, Terre Haute,
Indiana". Field Investigations of Uncontrolled Hazardous Waste
Sites, Task Report to the Environmental Protection Agency,
- Contract No. 68-01-06056
5. P.E. LaMoreaux and Associates (PELA)., "Ground Water Monitoring
Programs for IMC East Plant Waste Proposal Mound, Terre Haute,
Indiana". June 16, 1981
6. P.E. LaMoreaux and Associates (PELA), "Monitoring Well
Installation for the IMC East Plant Waste Disposal Mound, Terre
Haute, Indiana". June 16, 1981
7. Weston-Sper, "Site Assessment for IMC, Terre Haute, Indiana".
February 1985
8. Camp Dresser & McKee, Inc. (CPM), "Draft Remedial Investigation,
IMC East Plant Site, Terre Haute, Indiana". August 1987
9. Jacobs Engineering Group Inc., "Evaluation of Remedial
Investigation Draft Report, EPA, Region V Contract No. 68-01-
7351 Work Assignment No. 491", TES IV Prepared by Metcalf & Eddy,
Inc. October 1987 *
10. Camp Dresser & McKee, Inc. (COM), Remedial Investigation, IMC Est
Plant Site, Terre Haute, Indiana. January 1988.
-------
Prior IMC Remedial Action
0 Collected onsite contaminated soils to 50 ppm BHC.
0 Disposed of soils in a capped earth mound located on a fenced site
above elevation of highest groundwater level.
0 Constructed surface water drainage away from earth mound via
french drain.
Future IMC Operation and Maintenance
0 Continue to monitor the groundwater semi-annually.
0 Maintain cap and site security.
0 Deed restrictions on the site land use.
0 Performance review every S years with U.S. EPA.
\
DECLARATIONS , .
Consistent with the Comprehensive Environmental Response Compensation, and
Liability Act of 1980 (CERCLA)J as amended by the Superfund Amendments
Reauthoriration Act of 1986 (SARA), and the National Contingency Plan (40
CFR Part 300), I. have determined that the remedy outlined above at the IMC
East Plant Site is the most cost-effective remedy and provides adequate
protection of public health, welfare, and the environment. The State of
Indiana has been consulted and agrees with the approved remedy. In
addition, the action will require operation and maintenance activities to
ensure the continued effectiveness of the remedy.
I have also determined that the action being taken is appropriate when
balanced against the availability of secure off-site disposition, is more
cost-effective than other remedial actions, and is necessary to protect
public health, welfare or the environment.
Date Regional Administra
-------
Table of Contents
1.0 Location Description
1.1 Physiography
1.1.2 Population
1.1.3 Land Use/Zoning
1.2 Plant History
1.3. Nature and Extent of Contamination
1.3.1 Fate and Transport of Site Chemicals
1.4 Hydrogeology
1.4.1 Hydraulic Conductivity
1.4.2 Soil Attenuation Capacity
1.4.3 Site Geology
1.4.4 Groundwater
l^.'B Groundwater Usage
1.4.6 Groundwater Sampling
1.4.7 Surface Water
1.5 Public Health Issues
1.5.1 Chloroform
1.5.2 BHC Tech
1.6 Enforcement
1.7 Community Relations
2.0 Alternatives Evaluation
2.2 Evaluation Criteria
2.2.1 Overall Protection of Human Health and the Environment
2.2.2 Compliance with ARARs
2.2.3 Long-Term Effectiveness and Permanence
-------
2.2.4 Reduction of Toxicity, Mobility or Volume
2.2.5 Short-Term Effectiveness
2.2.6 Implementability
2.2.7 Cost Analysis
2.2.8 Support Agency Acceptance
2.2.9 Community Acceptance
3.0 Detailed Analysis of Remedial Alternative
3.1 No action
3.1.0 Description
i
3.1.1 Overall Protection of Human Health and the Environment
3.1.2 Complinace with ARARs \
• \
3.1.3 Long-Term Effectiveness and Permanence
3.1.4 Reduction of Toxicity, Mobility or Volume
3.1.5 Short-Term Effectiveness
3.1.6 Implementability
3.1.7 Cost Analysis
3.1.8 Support Agency Acceptance
3.1.9 Community Acceptance
3.2 Off-Site Disposal
3.2.0 Description
Table 1
3.2.1 Overall Protection of Human Health and the Environment
3.2.2 Compliance with ARARs
3.2.3 Long-Term Effectiveness and Permanence
3.2.4 Reduction of Toxicity, Mobility or Volume
3.2.5 Short-Term Effectiveness
-------
3.2.6 Implementability
3.2.7 Cost Analysis
3.2.8 Support Agency Acceptance
3.2.9 Community Acceptance
3.3 Incineration
3.3.0 Description
Table 2
3.3.1 Overall Protection of Human Health and the Environment
3.3.2 Compliance with ARARs
3.3.3 Long-Term Effectiveness and Permanence
3.3.4 Reduction of Toxicity, Mobility'or Volume
I.3.5 Short-Term Effectiveness
3.3.6 Implementability
3.3.7 Cost Analysis
3.3.8 Support Agency Acceptance
3.3.9 Community Acceptance
3.4 Ons-ite Treatment (Dechlorination)
3.4.0 Description
Table3
3.4.1 Overall Protection of Human Health and the Environment
3.4.2 Compliance with ARARs
3.4.3 Long-Term Effectiveness and Permanence
3.4.4 Reduction of Toxicity, Mobility or Volume
Table 4
3.4.5 Short-Term Effectiveness
3.4.6 Implementability
i
-------
3.4.7 Cost Analysis
3.4.8 Support Agency Acceptance
3.4.9 Community Acceptance
4.0 Summary and Comparison
4.1 Maintenance
4.2 Off Site Disposal
4.3 Incineration
4.4 On Site Treatment
4.5 Selection of Recommended Program
Table 5 Summary of Alternatives
i
4.6 Discussion of Alternatives
4.7 Nine Criteria Discussion
5.0 Recommended Program
5.1 General
5.2 Monitoring Program
5.3 Contingency Plan
Table 6 -
Maintenance Cost
Table 7 - Summary of Applicable or Relevant and Appropriate
Regulations
Appendix
Figures
1 Site Area Map
2 Site Map
3 IMC East Plant Site Sampling Locations
4 Residential Well Locations Surrounding the IMC East Plant
5 Generalized Geologic Cross-Section
6 Concentration for Lindane and Total BHC at B-9A and B-10A
Monitoring Wells
\
-------
Table 8 BHC Concentration in Ground Water Samples
Table 9 Index to Administrative Record
-------
DESCRIPTION OF SELECTED REMEDY
0 Collect onsite contaminated soils to 50 ppm BHC.
0 Dispose.of soils in a capped earth mound located on a fenced site
above elevation of highest groundwater level.
0 Construct surface water drainage away from earth mound via french
drain.
0 Continue to monitor the groundwater semi-annual ly.
0 Deed restrictions on the site land use.
DECLARATIONS
Consistent with the Comprehensive Environmental Response Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments
Reauthorization Act of 1986 (SARA), and the National Contingency Plan (40.
CFR Part 300), I have determined that the remedy outlined above at the IMC
East Plant Site is the most cost-effective remedy and provides adequate
protection of public health, welfare, and the environment. The State of
Indiana has been consulted and agrees with the approved remedy. In
addition, the action will require operation and maintenance activities to
ensure the continued effectiveness of' the remedy.
I have also determined that the action being taken is appropriate when
balanced against the availability of secure off-site disposition, is more
cost-effective than other remedial actions, and is necessary to protect
public health, welfare or the environment.
Original t:;ncd l;y:
Date Regional Administrator
-------
-1-
1.0 Location Description
The IMC East Plant in southeastern Terre Haute, Indiana, is in the Wabash
Lowland physiographic province of southwestern Indiana. The plant site is
located in Vigo County, approximately 1.8 miles east of the Wabash River
and one mile north of the Thompson Ditch at latitude 39°26'N., longitude
87°23'W (see Figures 2 through 5). The plant site, which has an area of
approximately 37 acres, is bordered on the west by the Milwaukee, St. Paul,
and Pacific Railroad and on the east by the Louisville Railroad. The
disposal area encompasses approximately 6 acres in the northeastern portion
of the plant site.
1.1 Physiography
The Wabash River is the most prominent physiographic feature in the region.
The topography of the area is characterized by wide alluvial plains and
aggraded valleys that have low relief and a slightly undulating land
surface. Hills occur in areas where the more resistant bedrock has not
been eroded'. The altitude ranges from about 430 feet above msl (mean sea
level) along the Wabash River to about 520 feet on the valley floor. In
the southeastern part of the study area, there is a prominent hill with a
maximum altitude of about 580 feet above msl.
Some of the precipitation in the Terre Haute area-results in overland
runoff into the Wabash River. In the urban area much of the drainage by
the city drainage network is to the Wabash River or Thompson Ditch.
1.1.1 SITE AREA FEATURES
1.1.2 POPULATION
The East Plant Site is located in southeastern Terre Haute, approximately
1.8 miles from the Wabash River at its closest point in a semi-
industrialized area of the city. Railroad tracks are located along the
west and east boundaries of the facility. Industrial facilities in close
proximity to the property include:
0 Ulrich Chemical, 1400 Lockport Avenue;
0 Indiana Gas and Chemical, 1341 Hulman Street;
0 Farmers Bureau Co-Op, 2600 South 13th Street;
0 Modern Album, .1299 Vorhees Street;
0 C-Board Railroad, 2301 19th Street.
-------
-2-
The population of 61,125 residents In Terre Haute obtains water from a
mixture of well water and water from Wabash River. The city water system
wells are located approximately 3 miles north-northwest of the East Plant.
Two parts of groundwater from the wells are blended with one part surface
water from the Wabash River and delivered via service lines to areas as far
south as Margaret Avenue. Although city water is available, some residents
in the vicinity of the East Plant site obtain their water from private
wells. No residential property or residential wells border the East Plant
site. Figure 3 shows the location of residential wells in the area,
including approximately 30 considered downgradient of the East Plant site.
The average private well depth is 65 ft.
1.1.3 Land Use/Zoning
The East Plant site is located in a Heavy Industrial (M2) zoning classi-
fication according to local zoning ordinance authorities. A portion of the
IMC property, outside (and upgradient) of the original disposal areas, is
used as an employee picnic area.
1.2 Plant History
Land parcels making up the so-called East Plant property (36.8 acres) were
purchased by Commercial Solvent Corporation (CSC) in 1946 from three
individuals, from the CE&I R/R, and from the Wabash & Erie Canal Co. Prior
use of this property was for agricultural activities.
In 1946, a small facility was constructed on a six-acre segment of this
property for manufacturing, packaging, and warehousing of technical-grade
benzene hexachloride (BHC-tech.). This material was sold to insecticide
manufacturers as a raw material for the production of an insecticide for
control of the cotton boll weevil. Production of BHC-tech. at this
facility ceased in 1954. Process equipment and buildings were partially
dismantled and demolished - only the warehouse, the process control
building, and some storage tankage remained.
In 1966, the BHC-tech. warehouse was.converted into an animal housing
facility in which evaluation of the effectiveness of animal growth
promotants was conducted. This testing was conducted on a small numbers of
swine, cattle, and sheep.
CSC was purchased by International Minerals & Chemical Corporation in mid-
1975.
-------
-3-
1.3 NATURE AND EXTENT OF CONTAMINATION
BHC-tech. is a mixture of several isomers, primarily alpha, beta, gamma,
and delta. The gamma isomer of BHC, was the once widely used pesticide
"lindane".
Only BHC-tech. was produced at this site, it was not purified to produce
lindane. BHC-tech. produced at this site was sold to others as a raw
material for insecticide production.
In mid-1979 soil samples, surficial and subsurficial» were taken by IMC and
P.E. LaMoreaux and Associates. Results of the sampling program showed that
over 90 percent of the contamination was within seven feet of the surface
and well above the groundwater table. The shallow depth of contaminant
penetration, 25 years after plant operation were discontinued, illustrates
the low mobility of BHC-tech. Seven monitoring wells were installed at the
site. Groundwater samples indicated the presence of measurable BHC
concentrations in two of the seven wells.
In 1980, Camp Dresser & McKee, Inc. environmental engineers, advised on
methods for preventing off-site migration of BHC-tech. Approximately
18,500 yards of soil, rubble, piping and other debris were excavated and
placed in a secure clay-capped mound. Soil samples were collected and
analyzed to control the removal of soils in the site, containing in excess
of 50 parts per million of BHC. The residual concentration of BHC
remaining in the on-site soil is substantially less than 50 ppm. The clay
mound was designed in accordance with guidelines for closure of hazardous
waste landfills as published by U.S. EPA (43 FR 59011, December 18, 1978).
The mound cap consists of a minimum of 6 inches of clay covered by 12
inches of common, fill and 6 inches of loam.
The cap system included a surface drainage collection system and soil gas
venting. The cap is currently in sound condition and supports a thick,
green vegetative growth of crown vetch. Monitoring wells upstream and
downstream of the mound have been monitored quarterly since 1981 and
results sent to the Indiana State Board of Health.
In 1984, chloroform was found in one* well (7 ppb) at the East Plant Site by
Weston-Spur, the EPA Technical Assistance Team (TAT) contractor.
Chloroform was not used in any IMC East Plant process or operations. The
chloroform was found in well B-5 which is upgradient of the capped mound
and close to the eastern boundary of the IMC facility. TAT concluded that
the chloroform was likely emanating from an offrsite source east of the
facility.
TAT's Site Assessment, completed in 1985, concluded that the waste mound
"is not presently adversely impacting the groundwater in the surrounding
area". This conclusion was based on sampling and analysis work for both
chloroform and lindane. The analytical work performed by Weston-Sper
showed no presence of lindane in any of the samples.
-------
-4-
1.3.1 Fate and Transport of Site Chemicals
BHC
Research has suggested that photolysis of BHC In the environment will not .
be an important process due to the low light adsorption coefficients above
290 nm. Despite the limited light adsorption, several papers have reported
lindane (gamma-BHC) as well as alpha, beta, and delta photolysis. The data
is suspect and the reported photolysis is likely due to processes such as
photoreaction caused by impurities in the BHC used.
Oxidation of BHC isomers in the environment is not a significant process.
Actual attempts to oxidize in aquatic systems using ozone (lindane in
hexane or water-acetone solvent), chlorine, potassium permanganate, and
potassium persulfate have not been successful.
Limited data on the hydrolysis rates for the isomers of BHC indicate that
this process is not significant in the environment. BHC (all isomers) is
believed to have a hydrolysis half life of more than two years (Callhan et
al, 1979).
The research data available on volatization of BHC and lindane (gamma
isomer) have indicated that the volatization of lindane from solution is
slow and therefore not an important transfer process.
In subsurface soil environments, the adsorption of lindane is critical and
ultimately affects the movement, uptake, and microbial and chemical
decomposition. Lindane adsorption is proportional to the organic content
of the.soil, and to a lesser extent, the mineral fraction (cation exchange
capacity and surface area). It has been reported that an increase in soil
moisture content may decrease adsorption, but it may enhance bioactivity.
Freundlich adsorption isotherms and organic carbon normalized adsorption
constants for lindane can be found in the literature for a number of soil
types. Information on the adsorption of BHC indicate that subsequent
deposition and transformation in anaerobic environments may be the most
important fate for BHC.
Information available on the bioaccumulation of the four isomers indicates
that they are not extensively bioaccumulated in organisms. Concentration
factors vary from about 10 to 500 depending on the isomer and organism.
One study concluded that the beta isomer showed the greatest tendency to
accumulate. Isomerization to the beta form was suggested as a possible
explanation.
Very little information is available on biotransformation processes of alpha,
beta, or delta BHC. However, it has been suggested that all three of these
isomers are potential biotransformation products of lindane. Interconversion
of BHC isomers in aquatic environments can complicate fate and transport
conclusions for individual isomers. Numerous research projects have
-------
-5-
iden.tified microorganisms capable of transforming lindane. Transformation
products for a variety of microorganisms include: pentachlorocylclohexane,
tetrad orocyclohexane, chlorinated phenols, chlorinated benzenes, and benzene.
It is generally accepted that microbial dechlorination and degradation of
lindane is more favorable under anaerobic conditions.
1.4 Hydrogeology
1.4.1. Hydraulic Conductivity
A series of rising and falling head tests were conducted on the borehole to
obtain information on aquifer permeability. This information supplemented
existing information developedtby PELA in their extensive site hydrogeologic
investigation performed ;in 1980. The aquifer is known to be highly permeable.
1.4.2 Soil Attenuation Capacity
A determination of the local soil attenuation capacity for lindane was carried
out by measuring the organic carbon content of undisturbed native soils of the
type that are contained in the clay mound. Determination of the organic
carbon content allowed calculation of the soil sorption constant. A
retardation factor was then calculated. This factor is a relative measure of
the velocity of a contaminant relative to the mean velocity of the
groundwater.
The Retardation Factor, R, is a function of the sorption constant, soil bulk
density and effective porosity:
R = 1 + Pb (1-ne) x K
ne
Specific values for parameters applied to the IMC site are as follows:
Pb = Soil bulk dry density =1.90 Kg/1
(Value for sand and silt obtained from "An Introduction to
Geotechnical Engineering, Holtz & Kovacs, Prentice-Hall, 1981)
ne = Effective porosity (unitless) = 0.32
(Value for sand and silt obtained from "Groundwater & Wells",
Driscoll, F.G., 2nd Edition, Johrvson Division, 1986)
K = Sorption Constant (I/Kg) = 9.5 to 15
-------
-6-
On the basis of these parameters, the Retardation Factor, R, varies from 39 to
62.
The Retardation Factor, R, is defined as the mean velocity of water through
soil divided by the apparent mean velocity of the solute (Lindane) through the
soil. A value of R approaching 1 would indicate a "no soil" condition, or
little retardation. The retardation factors calculated for the IMC site,
indicate substantial attenuation of any Lindane which might be dissolved by
percolating rainwater.
1.4.3 Site Geology
The IMC East Plant is underlain^ by approximately 85 feet of glacial outwash
overlying bedrock. This outwash is covered in some areas by up to seven feet
of black silty clay. Bedrock beneath the outwash is gray shale with coal
seams of Pennsylvanian Age that slopes northward approximately 17 feet per
mile.
The upper 15 to 25 feet of outwash consists of brown fine- to coarse-grained
sand containing some boulders. The.lower part consists of gray fine- to
coarse-grained sand and gravel which increases in size downward to boulders.
1.4.4 Ground Water
Ground water occurs in the area in the consolidated bedrock and in the over-
lying unconsolidated deposits. These unconsolidated deposits are,the
principal source of ground water in the area.
The sand and gravel outwash deposits of the Wabash River valley constitute the
thickest and most extensive aquifer of the area. Ground water in these
deposits occurs under artesian and water table conditions. Artesian
conditions occur in areas where the glacial outwash is overlain by glacial
till, whereas water table conditions occur in the study area. The saturated
thickness of the water table aquifer ranges from 50 feet near the edge of the
river valley to more than 100 feet near the river. In the study area, the
saturated thickness of the aquifer is about 60 feet.
The regional ground water movement is west toward the Wabash River. However,
changes in the general direction of groundwater movement can occur locally by
groundwater withdrawals, topography, and the configuration of the bedrock
surface. At the plant site the.groundwater movement is to the north-
northwest.
Water-well drillers in the area have reported yields as high as 2,700 gpm
(gallons per minute) from wells in the unconsolidated deposits. The average
I
t
-------
-7-
yield per well based on a study conducted by the U.S. Geological Survey in
1973 is approximately 660 gpm.
1.4.5 Groundwater Usage
Until the 1960's, the source of raw water for the Terre Haute municipal supply
was the Wabash River. Withdrawal was subsequently undertaken to allow
blending. Blending continues today on a year-round basis and consists of
about 2/3 groundwater blended with about 1/3 surface, water. A near-term goal
of the local utility is to attain a 50-50 blend.
The municipal water utility, which provides water throughout the city, has
five supply wells immediately Adjacent to the Wabash River upstream (north) of
downstream Terre Haute. Report's prepared in 1979 for the water utility by a
consulting groundwater hydrology firm (Keck .Consulting Services, East Lansing,
MI) state that these wells, which are about 130 feet deep, are hydraulically
connected to the Wabash River. The reports conclude that groundwater
available to these wells is replenished almost solely by infiltration from the
Wabash River and that well production is controlled almost exclusively by
river stage levels.
1.4.6 Groundwater Sampling
Groundwater at six on-site and six off-site locations was sampled and analyzed
for the four isomers of BHC and chloroform. The on-site wells included three
upgradient (B-l, B-2 and B-5) and three downgradient (B-9, B-10 and B-ll) of
the mound. The off-site wells included 2 residential wells downgradient of
the (on Stewart Avenue and on llth Street) and four wells located on the
Ulrich Chemical Company property (Monitoring Wells MW-1, MW-3, Mw-7 and MW-9).
The locations of all of these monitoring points are shown on Figure 4. Data
and results are presented in the Appendix.
1.4.7 Surface Water •
In the immediate area of the plant site, a drainage divide extends northeast
from the southwestern part of the property. Precipitation that falls on the
southeastern half of the plant site drains southward into Thompson Ditch.
Surface water in a small part of the northeastern side of the plant site
drains toward a topographic low to the northeast. A cinder dike around the
-------
-8-
disposal area on the northwestern part of the site once served to impound the
surface drainage in the area, resulting in downward percolation of surface
water into the glacial outwash aquifer. This dike was excavated and placed
into the disposalmound along with the contaminated soil associated with the
impoundment. Natural drainage outside of the mound now flows toward the
northwest. Runoff from the disposal mound is collected in a concrete
intercepting ditch surrounding the mound. It is then channeled to a gravel
percolation pit located directly south of the mound.
1.5 PUBLIC HEALTH ISSUES
An obvious potential health concern associated with the IMC East Plant site is
the water quality of the Wabash River Valley aquifer. Contamination of the
aquifer could impact residences.,using the aquifer as a water supply.
Quarterly onsite groundwater monitoring wells analyses for a period of six
years has shown that only two wells contain measurable concentrations of BHC.
These wells are located immediately downstream of the capped mound and contain
BHC isomers at or below maximum concentration level goal (MCLG). The only
reported occurrence of BHC in offsite groundwater samples is that of the delta
isomer found in the Ulrich Chemical wells number 7 and 9 during the RI field
work. The data for this one occurrence are highly suspect. No BHC has ever
been found in residential wells.
The IMC East Plant site is not endangering public health in the general area.
1.5.1 Chloroform
As documented, there is no history of chloroform use on the IMC site.
Chloroform is known to be ubiquitous in the environment and is often found in
treated drinking water supplies as a result of chlorination of naturally
occurring organic materials in the water. The body of data accumulated 'on
this site, including the 1984' TAT investigation and the most recent sampling
done as part of the RI, show chloroform being detected up and downgradient of
the site and disposal mound. Chloroform concentrations on site fall far below
the Safe Drinking Water Act Maximum Contaminant Level (MCL) of 100 ppb. As
stated in the Work Plan, EPA considers the MCLs to be only relevant/applicable
ambient standard for groundwater contamination.
The highest concentrations detected in the last sampling round (except for
matrix spikes which represent laboratory induced contamination for quality
control purposes) are 1.9 ppb in tank truck water (field blank for
groundwater) and 1.6 ppb in baked quartz sand (field blank for soil).
Chloroform was detected at 0.3 and 0.4 ppb in the two samples taken at well B-
10A immediately downgradient of the mound. Chloroform was also detected at
-------
-9-
3.3 ppb at Monitoring Well #3 on the 111 rich Chemical property and at 10.9 and
9.9 ppb in groundwater at the Stewart Avenue and llth Street residences,
respectively.
In summary:
0 Chloroform concentrations in groundwater in the entire region
as detected in the sampling programs associated with this
project fall well below the MCL concentration of 100 ppb.
0 Chloroform, which has generally not been detected in samples
taken directly under the IMC site, is at least one order of
magnitude lower in concentration than chloroform detected
downgradient of the site.
0 There is clearly no cause-and-effect relationship between the
negligible chloroform found onsite .and the low concentrations
detected offsite. Isolated instances of offsite residential
well chloroform contamination cannot be attributed to the site.
For these reasons, the presence of chloroform should not be an issue for
further study in regard to this site.
1.5.2 BHC-tech
The occurrence of Benzene Hexachloride-tech. (BHC-tech.) and its production
and disposal history on the IMC site are well documented. The issues to be
addressed in .this program are the effectiveness of the site closure at
preventing the further migration of BHC, the impacts of the BHC remaining in
the groundwater and the investigation into the cost/benefit properties of
other remedial actions.
The data pertaining to BHC analyses conducted during the RI and the results of
IMC's contihuing quarterly monitoring program are appended for reference.
Of the four isomers of BHC, only the*"Gamma" isomer, also known as lindane, is
a priority pollutant. It is also the only isomer for which an MCL has been
established. The MCL for lindane in drinking water is 4 ppb. A MCLG of 0.2
ppb has been proposed by EPA for lindane.
Lindane was detected in the groundwater onsite during the RI program only at
B-9A and B-10A at concentrations of 0.029 ppb and 0.043 to 0.05 ppb
respectively. Both of these locations are immediately downgradient of the
disposal mound and both show contamination levels lower than the MCL and MCLG
as confirmed by the body of data accumulated during the quarterly monitoring
program. The data also show that these low levels of lindane are declining
and are now well below the MCLG of 0.2 ppb. Figure 1 shows plots of lindane
concentrations in B-9A and B-10A groundwater with respect to time.
-------
-10-
All other groundwater sampling locations, on and offsite, showed no detectable
lindane.
Lindane was detected (0.051 ppb) in soil at the SB-1 boring at the groundwater
Interface and was detected (0.029 ppb) in the 1 foot deep soil sample taken at
the picnic area. Both of these values are well below the 50 ppm target
cleanup values established and implemented in 1980.
As stated in the Work Plan, EPA considers the MCLs to be the relevant/
applicable ambient standard for groundwater contamination at this site.
The conclusion that can be drawn is that the currently implemented RCRA
closure is effective at controlling lindane in the groundwater to below
current MCL and the more stringent proposed MCLG levels.
t
1.6 Enforcement
On May 6, 1986, the U.S EPA Regional Administrator for Region V signed a
CERCLA 106 Administrative Consent Order (Order) with IMC that stipulates the
undertaking of a remedial investigation (RI) and feasibility study (FS) by
IMC. As part of the RI, the Order requires that an endangerment assessment
be completed by IMC to determine the actual or potential harm presented by the
site to public health, welfare or the environment.
The stated objectives of the Order were: (1) to determine fully the nature
and extent of the threat, if any, to the public health or welfare or the
environment caused by the release or threatened release, if any, of hazardous
substances into the environment from the East Plant; and (2) to evaluate
alternatives, .if any, for the appropriate extent of remedial action to prevent
or mitigate the migration or the release or threatened release of hazardous
substances from the site which includes evaluation of past remediation at the
site and to evaluate the need for and appropriate extent of additional
remedial action, if any.
1.7 Community Relations
The signed Order for undertaking the RI/FS went out for public comment in
September 1986. Minimum comments were received on the Order during the thirty
day comment period, and the Order became effective thereafter.
The IMC site has generated little public interest or media attention since
being identified as a potential Superfund site.
-------
-11-
The draft Feasibility Study (FS) went out for a thirty day public comment
period beginning March 1988.. An opportunity for a public meeting was provided
on April 7, 1988, for interested parties. Following the completion of the
comment period on April 29, 1988, comments were summarized and included in the
Administrative Record. A Responsiveness Summary is attached hereto.
2.0 Alternatives Evaluation
The FS for the IMC site developed and evaluated an array of remedial
alternatives. A series of screening criteria were employed to narrow the
field of possible alternatives. The resulting final array of alternatives was
analyzed in detail to select remedies that attain an acceptable level of
effectiveness and implementabiljty, and were cost effective.
2.1 ALTERNATIVE REMEDIAL ACTION TECHNOLOGIES EVALUATION •
The following remedial technologies are recommended for consideration in this
Feasibility Study:
No Action
Incineration
Off-Site Disposal
Chemical Treatment
Biological Treatment
Briefly, the remedial technologies can be described as follows:
No Action (Monitoring and Maintenance of.Existing System)
The no action maintenance alternative includes periodic monitoring of
groundwater, fence maintenance, and long term maintenance of the cover system.
All materials, including the soil di-sposed in the clay-capped mound, would be
left in place.
Incineration
This technology involves the high temperature destruction of contaminants
present on-site. Materials may be burned in either a permanent or temporary
(mobile) on-site or off-site incinerator.
-------
-12-
Off-Slte Disposal
Land disposal of contaminated materials involves the movement of these
materials from their original locations to a secure landfill. The material
disposed of may be the original materials present on the site, or may be the
remnant product of a treatment process. Hazardous materials must be disposed
of in a RCRA (Resource Conservation and Recovery Act) approved landfill.
Chemical Treatment
Dechlorination of several technical grade insecticides at laboratory scale has
been reported by several researchers. One process takes place in. an alcohol
medium by the catalytic action pf nickel boride in an excess of sodium
borohydride. The laboratory studies were done on insecticides dissolved in
acetone and suspended in water. Extraction of pesticides from soil and
treatment of the extract by this process has not been reported. Scaling Up
this to the degree necessary to handle the materials on site has also not been
done.
Because the technology has not been proved at laboratory or commercial scale,
this particular process will not be further considered as a viable
technological alternative for this site. A different dechlorination process,
using Alkaline Polyethylene Glycol (APEG) process is more promising from
laboratory and field scale perspective and is further evaluated as remedial
alternative at this site.
Biotreatment
Biological treatment as applied to this site would involve the use of native
microbes, selectively adapted bacteria, or genetically altered anaerobic
microorganisms to degrade, in situ, the contaminants present on-site.
Conflicting opinions in the literature concerning the effectiveness of
biodegradation in lindane treatment, the potential for the development of more
mobile toxic halogenated organics and byproducts, the requirement for long-
term pilot studies and the need for a water phase in the mound all cast doubt
that the pursuit of this alternative would result in a workable.solution.
Accordingly, biotreatment will not be further evaluated as a remedial
alternative at IMC.
-------
-13-
2.2 EVALUATION CRITERIA
The evaluation of remedial alternatives will be performed using the following
considerations:
1. Overall Protection of Human Health and the Environment
2. Compliance with ARARs
a. applicable or relevant and appropriate requirements (MCL in
groundwater)
b. ability of alternative to attain or exceed standards, or reduce
likelihood of present or future threats from the hazardous
substances
3. Long-Term Effectiveness and Permanence
4. Reduction of Toxicity, Mobility or Volume
5. Short-Term Effectiveness
6. Implementability
7. Cost Evaluation
a. capital, costs
b. operational and maintenance costs
c. present worth analysis
8. Support Agency Acceptance
9. Community Acceptance of RI/FS and Proposed Plan
Each of these criteria is more fully described in the following subsections.
-------
-14-
2.2.1 Overall Protection of Human Health and the Environment
This criterion considers the effectiveness of the alternative in meeting the
site remedial objectives based on potential human health and the environment,
2.2.2 Compliance with ARARs
This criterion addresses regulatory constraints associated with the remedial
alternatives. The degree to which site remediation alternatives comply with
applicable or relevant and appropriate regulatory requirements is considered.
This includes, for example, CERCLA, RCRA, the Clean Water Act, and the Clean
Air Act.
2.2.3 Long-Term Effectiveness and Permanence
(a) This criterion includes the effectiveness and useful life of remedial
alternatives. The remedial alternative is evaluated in terms of its
ability to perform as desired. The applicability of the alternative to
site conditions is evaluated as it relates to its technical performance.
Useful life considers the service life of the alternative until
replacement is required.
(b) This criterion includes operation and maintenance requirements and
previously demonstrated reliability of the alternative. Past documented
performance of the technology for similar site conditions is considered.
The technical and operational complexities of the alternative are
considered as related to functional reliability.
2.2.4 Reduction of Toxicity. Mobility or Volume
Beneficial and adverse impacts to the environment are .considered for each
remedial alternative. This evaluation considers both short-term (i.e.,
construction related) impacts and long-term impacts.
The environmental impact evaluation addresses the following specific .issues
for each alternative:
1. Potential release of contaminants to the air and groundwater
during construction.
2. Elimination of contaminant migration and elimination of future
potential impacts.
-------
-15-
These potential impacts and other applicable impacts, along with mitigation
measures, are addressed for each alternative.
2.2.5 Short-Term Effectiveness
This criterion addresses the safety of workers and nearby neighborhoods or
other potential receptors during construction of the remedial alternatives.
Air quality impacts due to emissions during site remediation are considered
relative to workers and area residents. Direct contact exposure to workers is
also considered. • ' . •
2.2.6 Implementability
i
This criterion considers the constructability of a remedial alternative based
on site-specific constraints such as depth to bedrock, site access, existing
land use, waste characteristics, and water table elevations. Construction
problems that may ultimately impact site remediation objectives are
identified. The time to construct/implement the remedial alternative is also
estimated. The time required from start up of the remedial alternative until
desired remedial response objectives are achieved is considered..
2.2.7 Cost Evaluation
The cost analysis has been conducted in the following steps:
1. Estimation of capital and annual operation and maintenance
costs;
2,. Present worth calculations to allow comparison of alterna-
tives; and
3. Sensitivity analysis of major cost items to determine poten-
tial impacts on overall costs and alternative comparison.
All cost estimates include a 30 percent engineering and contingency factor.
Present worth calculations for future annual costs are based on a 10 percent
discount rate. Future costs would be incurred primarily in the operation and
maintenance of the on-site disposal mound, and in groundwater monitoring over
a 30-year period following completion of on-site remedial construction.
-------
-16-
2.2.8 Support Agency Acceptance
IDEM has commented on the preferred alternatives based upon its review of the
RI/FS and proposed plan.
2.2.9 Community Acceptance
Public comments based upon the RI/FS and proposed plan have been received and
assessed.
-------
-17-
3.0 DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
3.1 NO ACTION (MONITORING AND MAINTENANCE OF EXISTING SYSTEM)
3.1.0 Description
The work associated with the no action alternative includes fence maintenance,
long term maintenance of ground-cover and fencing, and continuation of the
groundwater monitoring program. These actions will provide continued
protection for the public in the vicinity of the IMC site.
In. 1980, after completion of the soil sampling plan, 28,500 cubic yards of
contaminated materials were excavated, mounded and secured by a 6-inch-clay"
cap at the site. Excavation was carried out in all areas until soil samples
contained less than 50 ppm BHC. The areas from which contaminated soil was
taken were then graded, seeded and fertilized. The clay covered mound was
covered with one foot of common fill and six inches of seeded loam. The vege-
tative cover is now fully established. The mound was encircled with a
concrete drainage ditch which diverts direct runoff away from the edge of the
mound toward a gravel-infiltration area to the south.
After completion of the mound, a periodic groundwater monitoring program was
instituted. Figure 5 is a plot of total BHC-tech and lindane concentrations
versus time at wells B-9A and B-10A, both located immediately downgradient of
the mound. As the plots indicate, concentration of lindane in the groundwater
declined relatively quickly after construction of the mound and has continued
to decline, at a slower rate, since early 1983. Other isomers of BHC show
similar behavior. Concentration of Tindane in the groundwater remains well
below the MCL concentration of 4 ppb and is also below the MCLG concentration
of 0.2 ppb.
The soil cleanup and mound construction, has been effective in containing the
source of BHC-tech. and in reducing groundwater contamination to well below
MCL and MCLG concentration.
The disposal mound is surrounded by a security fence. The fencing should be
checked semi-annually for the 30-year life of the remediation activity by IMC
and maintained as necessary.
Groundwater Monitoring
Groundwater has been tested on a quarterly basis for BHC. Background water
quality is assessed by monitoring upgradient wells PW-1 (production well), B-
1, and B-2. Downgradient wells that have been used to monitor the groundwater
quality are observation wells B-9, B-10, B-ll. This monitoring program will
-------
-18-
be continued for the 30-year monitoring period which began with closure in
August 1980. The program will include semi-annual monitoring for the next 5
years and annual.monitoring thereafter.
Should downgradient monitoring show increasing contamination additional
groundwater samples will be taken to determine if the data are valid (e.g.,
consistent increase over more than two monitoring periods when compared to
general trends defined by previous sampling or presence of contamination above
MCL level with no increase in concentrations upgradient). If these
confirmatory samples indicate an upward trend in downgradient contamination,
remedial action may be necessary. Because of the variability inherent in
sampling and in laboratory techniques, it is not possible to propose objective
criteria for initiating cap repairing; data must be-evaluated in the context
of previous data and judgement must be applied prior to initiating action.
The contingency plan under these circumstances will be to repair damaged
portions of the cap. If no damage is apparent, then the cap will be replaced
aby stripping the loam and vegetative cover, installing a high density
polyethylene membrane over the entire mound, and reestablishing vegetative
cover by placing one foot of common fill and six inches of reseeded loam over
the membrane. In view of low solubility of BHC-tech in water (less than 15
ppm), and its relative immobility (as demonstrated by high soil attenuation
properties calculated), the contingency plan will keep groundwater
contamination below MCLGs, protecting human health and environment.
3.1.1 Public Health and Environmental Impacts
The no action alternative will protect the public from direct contact with
contaminated materials and reduce the migration of contaminants offsite
through rainwater percolation and groundwater recharge. Concentrations of
lindane currently are below MCL and MCLG standards in groundwater and,
therefore, site remediation objectives have been attained.
3.1.2 Compliance with ARARs
The no action alternative entails maintaining the fence surrounding the
disposal mound to prevent damage to the capping system, and direct contact
with the disposal materials, and monitoring. The institutional requirements
of greatest concern are RCRA 40 CFR Part 264, Subpart G (Closure and Post-
Closure). The site closure was conducted in accordance with RCRA regulations
proposed at the time. Up- and down-gradient monitoring and maintenance of
site security are in accordance with these regulations.
The no action/monitoring alternative is equivalent to maintaining the natural
attenuation process which relies on the groundwater's natural ability to lower
contaminant concentration through physical, chemical and biological processes
until cleanup levels are met. As the body of data shows, groundwater cleanup
-------
-19-
has occurred to MCL and MCLG levels and contaminant concentrations continue to
decline.
This alternative has a high institutional ranking.
3.1.3 Long-Term Effectiveness and Permanence
The intended function of the fence and cap system is to protect human health
by preventing direct contact of humans with the contaminated, on-site soils
and reduce particulates and surface runoff from migrating off-site. In
addition, the installed clay cap is effective in preventing rainfall from
percolating through the contaminated soils, thereby protecting the groundwater
from new contamination. Additional safety is derived from the low solubility
and low mobility of BHC-tech. These systems are expected to accomplish these
safety objectives over the 30-y.ear life of remediation. In addition, the
monitoring program consisting of up- and downgradient groundwater sampling
will give early warning of cap failure. High levels of performance are
assigned to this alternative because of ease in maintenance and performance to
date.
It is entirely feasible to ensure the integrity of the cap, fencing and ground
cover over its 30-year life. Operation and maintenance activities will entail
fence repair and replacement as necessary. The monitoring program, with
upgradient and downgradient groundwater sampling points, forms a reliable
means of data gathering for additional protection. This alternative is given
a high reliability ranking. The capping system, fence, ground cover and
monitoring program should be reliable systems for prevention of direct
contaminant contact, for prevention of contaminant migration, and for early
warning should some failure of the capping system occur.
3.1.4 Reduction of Toxicity, Mobility or Volume
Beneficial environmental impacts associated with the no action alternative are
derived from the fact that contaminant transport and the potential for direct
contact with contaminated materials have been minimized. This is true both in
the short- and long-term future. Faithful monitoring and maintenance of the
capping system will also prevent future impacts on the groundwater beneath the
site. Sufficient warning will be given by the monitoring program to allow
timely implementation of further remedial action in the unlikely event that
they become necessary. The unlikely catastrophic failure of a substantial
portion of the cap over a considerable time period has the possibility of
allowing sufficient transport of BHC to affect the groundwater. Because the
monitoring points are close to the mound and because current groundwater
contaminant levels are well below drinking water standards early detection is
possible and no impact on downgradient groundwater users is anticipated.
-------
-20-
The Public Health is further protected by the 5-year review of the selected
remedy required by Sec. 121(b)(2)(c) of SARA. Under the no action scenerio,
contaminants would remain on-site, requiring review of the remedy at least
every 5 years to assure protection of human health and the environment. If
action under Sec. 104 or 106 is appropriate such action will be taken at that
time.
The rating of this alternative from a public health standpoint is high.
3.1.5 Short-Term Effectiveness
This alternative receives a high ranking because personnel will not be
required to directly handle hazardous materials.
i
3.1.6 Implementability
The implementability of this alternative receives a high ranking due to the
fact that the capping system, fencing and ground cover are already in place
and have proven effective over seven years of record. The monitoring program
has been implemented and coordinated with laboratory service and sampling
crews. Deed restrictions will state that no private use of this site will be
permitted for the 30 year period.
3.1.7 Cost Analysis
Capital Cost
There are no initial capital costs for the no action alternative. All
necessary capital improvements were completed in 1980.
Operation and Maintenance
Operation and maintenance (O&M) costs for the no action alternative include
sampling and analytical costs and costs for the maintenance of the fence and
ground cover. These costs are summarized in Table 1.
-------
-21-
3.1.8 Support Agency Acceptance
IDEM approved the orginal cap installation in 1980 and as both MCLs and MCLGs
are for lindane being met by the current remedy they continue to support this
remedy.
3.1.9 Community Acceptance
Monitoring provides early warning in event of cap failure. As there is no
need to re-open site, a contingency plan is available and future reviews are
planned the community supports this alternative.
-------
TABLE 1
NO ACTION ALTERNATIVE
(MONITORING AND MAINTENANCE OF EXISTING SYSTEM)
CAPITAL COST
NO INITIAL CAPITAL COSTS ASSOCIATED
WITH THIS ALTERNATIVE
OPERATION AND MAINTENANCE COST
Cap Inspection, Mowing, Repairs $10,000
Sampling & Analysis SEE BELOW
Record Keeping and Review 5,000
SUBTOTAL ANNUAL O&M ' ' $15,000
Allowance for Replacement of Felice in 15 Years .. $20,000
Sampling and Analysis (Semi-annual for first 5
years, annual thereafter through year 2010)
Present worth (10%) = ($2000 x 3.791) + (($1000
x 8.20)71.610)= $13,000
30-Year Present Worth (10%):
TOTAL O&M COST ($15,000 x 9.427) + ($20,000 x 0.2394)
$141,000 + $5,000 + $13,000 = $159,000
TOTAL NO ACTION PROGRAM COST: $159,000
-------
-22-
3.2 OFF-SITE DISPOSAL
3.2.0 Description
The off-site disposal alternative entails the excavation of contaminated soil
and subsequent hauling and disposal at a RCRA approved off-site landfill. The
procedures necessary to implement this alternative include excavation,
transportation, disposal, and site restoration. Soil would be excavated from
the mound as needed to fill the transport vehicles.
Before the soil can be transported for disposal at a landfill, it must pass
the paint filter test, discussed in RCRA 40 CFR Section 264.314: It is •
expected that soil moisture will be low enough to allow it to pass this test
without moisture adjustment. Saturated soils will need the paint filter test.
t
Soil characteristics must be determined to ensure that appropriate methods of
handling, transportation, and disposal are employed. All methods utilized
must be in full compliance with local, state, and federal requirements (40 CFR
262 and 263). Approximately 31,000 cubic yards of contaminated soil are to be
hauled offsite under this alternative. This includes 18,500 cubic yards of
soil in the.mound plus all soil to a depth of 7 feet (maximum BHC penetration
defined in soil sampling program) under the mound. Excavated soils will be
transported by 20 cubic yard truck loads.
As per 40 CFR 264.13(2)(4), landfill requirements entail taking samples from
selected truckloads before disposal. Samples are analyzed to ascertain their
chemical and physical composition. This includes specific gravity, moisture
content, pH, hydrocarbon composition, and PCB content. Testing for priority
pollutants is conducted based upon each receiving facility's waste analysis
plan.
Potential commercial landfill facilities .considered are as follows:
0 Chemical Waste Management (Model City, New York; Fort Wayne,,
Indiana; Emelle, Alabama)
0 Cecos (Williamsburg, Ohio)» or
0 GSX (Pinewood, South Carolina).
Landfill selection would be based on available capacity at the time of
disposal and the landfill's, or state government's, policies regarding maximum
disposal volumes acceptable for any one site. As landfill capacity becomes
more limited in the future, restrictions and allocation of remaining capacity
can be expected.
-------
-23-
3.2.1 Public Health and Environmental Impacts
The excavation and off-site disposal of the contaminated soils eliminates the
potential exposure to local and distant populations from this media.
Furthermore, the downward migration of contaminants and surface water
contamination will also be mitigated.
3.2.2 Compliance with ARARs
.This source control remedial alternative was evaluated for compliance with
federal, state, and local regulations.
This, alternative is in compliance with RCRA Subparts G (closure and post-
closure) and N (landfills). The transport of contaminated soils to an off-
site landfill" facility compl ies" with RCRA Parts 261, 263, 265 and DOT
regulations 49 CFR Parts 171-179 and 387.
Secure landfill capacities are becoming an issue in New York State and are
expected to result in disposal restrictions there and elsewhere in the future.
This fact, coupled with the pending landfill ban defined by 40 CFR Part 268,
encourage the implementation of on-site solutions to contamination where
possible. .
This alternative is given a low rating for institutional issues.
3.'2.3 Long-Term Effectiveness and Permanence
The performance of this alternative is dependent upon weather conditions. To
achieve the best 'results, this alternative should not be implemented during
the spring when regional rainfall is at its maximum. Excavation will remove
all contaminated soil from the site..
However, disposal to an off-site landfill will not alleviate the overall
problem of contamination. Once the contaminated soils are placed in the off-
site landfill, performance will be equivalent to the no action alternative.
During excavation, the opportunity for releases to the groundwater during
rainfall will occur. For these reasons, performance is rated at a medium
level.
-------
-24-
Excavatlon of contaminated soils requires little or no operation and
maintenance. This operation requires an 8-hour shift for 5 days a week for
the duration of the cleanup. All of the necessary equipment is standard
excavation equipment.
Once the contaminated materials are finally disposed of, the potential for on
and off-site release is low. Reliability is therefore rated high for this
alternative.
3.2.4 Reduction of Toxicity, Mobility or Volume
The adverse effects occurring from the excavation of the soils can be
controlled through engineering and personal protective equipment. The primary
adverse effects that could potentially occur are as. follows:
1. .Potential release and worker exposure during excavation.
2. Potential exposure to all populations from accidental spills or
wind carried releases during off-site transport to the landfill.
3. The potential failure of the off-site RCRA landfill, causing
contamination of surface water and groundwater.
This alternative is given a medium ranking regarding public health protection.
3.2.5 Short-Term Effectiveness
The IMC. site is fenced. Access to the work area must be restricted to
operation personnel only. Excavated soils that are to be hauled off site will
be stored in a way that prohibits further contamination. This includes covers
consisting of polyethylene sheets to reduce fugitive emissions and rainfall
percolation. The working face of the mound must also be protected with this
sheeting when work is not in progress or when it is raining. On-site safety
issues include truck traffic, accidents, and fugitive emissions in the working
area. Trucks transporting excavated materials off-site must be carefully
loaded, secured, and decontaminated to ensure that residual contamination is
not transferred from the site to public area.
From a safety perspective, this alternative is given a medium rating.
3.2.6 Implementability
Excavation needs to be implemented during a dry period to minimize transport
of exposed contaminants to the groundwater. This may not be possible due to
-------
-25-
unpredictable weather and operational or permitting problems associated with
an off-site disposal facility. Implementation is uncomplicated in all other
respects and is therefore rated medium for this alternative.
3.2.7 Cost Analysis
Capital Cost
Initial capital costs for the off-site alternative involve costs for the
following: ' .
1. Excavation and handling of. the contaminated soils at the site with
transport to a RCRA landfill. The handling and transportation costs are
based on unit costs provided by waste management companies. The unit
costs vary widely depending on the landfilling method and the. location of
the disposal site. A conservative cost estimate was adopted for this
analysis.
2. Backfill and regrade the site after excavation, including loam and seed.
3. Sample and analysis. The work includes both regular analysis for the
landfill and additional tests for the EPA priority pollutants.
Operation and Maintenance
Operation and maintenance costs for the off-site landfill alternative
represent the costs for annual post closure monitori'ng (2 rounds per year for
the first 5 years, 1 round per year for the remaining 25 years.)
All estimated costs for 'this alternative are presented in Table 2;
3.2.8 Support Agency Acceptance
As land restrictions have made off-site removal permits more difficult the
state has only limited support for this alternative.
3.2.9 Community Acceptance
Alternative involves re-exposing contaminated materials and dust generation
from truck traffic. While community would prefer to have material removed.it
resists any unneeded exposure to BHC.
-------
-26-
3.3 INCINERATION
3.3.0 Description
At the IMC site it is estimated that approximately 31,000 cubic yards of
contaminated soil would require detoxification in an on-site incineration
system. Of this quantity, 18,500 cubic yards is material which was placed in
the disposal mound. The remainder is material existing to a depth of 7 feet
below the mound representing an estimate of soil contaminated to at least 50
ppm based on analyses conducted prior to and during "mound construction.
We have investigated the economies of off-site versus on-site incineration.
Because cost strongly favors on-site incineration, it is the only option
investigated under this alternative. -
For detoxification of these contaminated soils, the applicable thermal .
treatment technology commonly available as a mobile system for on-site
hazardous waste treatment is rotary kiln incineration. Although the rotary
kiln incineration process has been evaluated for this comparison, there are
other possible means of incineration such as fluidized bed incinerators and
infrared processing systems that may, after a trial burn and/or indepth
studies, be viewed as acceptable methods of incineration. The rotary kiln
incineration system handles the broadest range of organic compounds and
materials.
Rotary Kiln Incinerators
The most versatile thermal treatment system is the rotary kiln incinerator.
Pumpable and atomizable liquid wastes can be injected through conventional
burners into the kiln, sludges and viscous liquids can be pumped through open
pipes into the rotary chamber, and soils and other solid materials as well as
suitably-sized containers can be fed through entrance "chutes. Kiln rotation
continuously exposes fresh surfaces to oxidation and provides constant removal
of the treated soil and ash at the discharge end. A secondary combustion
chamber (afterburner) is provided for the further destruction of unburned
gaseous and suspended particulate organics. This combustion system provides
turbulent mixing of the waste gases with excess oxygen at high temperatures.
If properly designed, the combination of adequate volume, turbulence and
temperature will normally provide sufficient residence times to destroy the
organics within the allowable limits. If necessary, the off-gases may be
quenched and scrubbed of acids and particulates before discharge to the
environment.
-------
TABLE 2
OFF-SITE DISPOSAL ALTERNATIVE
CAPITAL COST
Excavation $ 220,000
Backfill 125,000
Sampling and Analysis 594,000
Transport, Processing and Disposal 12,400,000
SUBTOTAL $13,339,000
i
Engineering (15%) 2,001,000
Contingency (15%) 2.001,000
$17,341,000
OPERATION AND MAINTENANCE COST
Post-Closure Monitoring (5 years semi-annual,
25 years annual) 30-Year Present Worth (10%)
($2,000 x 3.791) + (($1,000 x 9.077)71.610) = $13,000
TOTAL OFF-SITE DISPOSAL PROGRAM COST
$17,341,000 + $13,000 = $17,354,000
-------
-27-
Rotary kiln incinerators have been used extensively at fixed facilities for
treatment of both hazardous and non-hazardous waste materials. The majority
of installations are used for in-plant industrial waste destruction. Rotary
kilns have also been developed as mobile or transportable systems, due to
their ability to effectively destroy diversified waste feeds. This allows for
waste treatment onsite, thereby eliminating the need to transport waste
offsite. Once remediation is complete, the system can be moved to another
site.
The system consists of six basic process modules:
0 Rotary kiln or primary combustion chamber,
0 Secondary combustion qhamber,
0 Heat recovery boiler, " .
0 Air pollution control train,
0 Control room and laboratory, and
0 Effluent neutralization and concentration equipment.
The rotary kiln or primary combustion chamber operates within a temperature
range of 1,200°F-1,800°F. Auxiliary fossil fuel or waste liquids are used in
the primary chamber to maintain temperatures. Residence times in the rotary
kiln range from seconds for gases to 30 to 40 minutes for solids. The
secondary combustion chamber operates at a temperature between 1,400°F-
2,400°F. Gas residence times range from 1.7-2.2 seconds at 2,200°F.
•
Process operation of rotary kiln systems begins with solid waste material
being fed into the feed chute of the unit. Once discharged into the feed
chute, the feed is introduced into the upper end of the kiln by various
methods including hydraulic rams, screw augers and inclined chutes. As waste
material is discharged to the kiln, it is exposed to high temperature gases
that flow either concurrent or countercurrent to the waste movement. Waste
movement through the kiln is promoted by the rotation and inclination of the
cylindrical kiln.
As wastes pass through the kiln, they are first dried and then the organic
content of the waste is substantially oxidized to gases and ash. Ash and
non-combustible detoxified solids, such as soils, are removed at the lower end
to the kiln and discharged into a residue receiving container. Meanwhile,
exhaust gases from the kiln enter a secondary combustion chamber or
afterburner to complete oxidation of the combustible waste. Liquid
combustible wastes can be burned in the secondary combustor as well as the
primary chamber. As the exhaust gases exit the secondary chamber, they are
directed through a pollution control train which may consist of a water
quench, a packed tower scrubber or an ejector scrubber system. The water
-------
-28-
quench section provides for gas washing and additional cooling. Acid gas
removal in excess of 99 percent is attained with the packed tower while
additional participate removal is provided by the high-energy ejector scrubber
system. Wastewater blowdown for the scrubbing system is analyzed, neutralized
and concentrated prior to disposal.
While rotary kilns offer an effective means of thermal treatment for the type
of wastes found at many CERCLA sites, the equipment tends to be relatively
large in size for a given throughout due to the high percentage of excess air
normally required for this system. The required high air volume is reflected
in the size, and therefore the cost, of the combustion chambers and the air
pollution control equipment. There is also a potential for increased
maintenance of the kiln's refractory-lining due to abrasive conditions
resulting from the motion of the soil and solids in the rotating chamber.
These considerations suggest thgt'the application of mobile rotary kiln
incinerators are cost effective only on relatively large sites with waste
quantities of 5,000 cubic yards or more and those requiring treatment of a
variety of contaminated materials (soils, liquids and sludges). Though
costly, investigation indicates that on-site incineration is less expensive
than hauling contaminated materials to a properly licensed off-site
incinerator for processing and disposal.
3.3.1 Public Health and Environmental Impacts
Operation of the incinerator will generate some unavoidable environmental
impacts, which can be mitigated or controlled to minimize impact. Public
health impacts should be minimal, as considerable effort will be expanded to
control emissions during the cleanup.
The construction and operation of the incinerator will generate some noise and
traffic impacts for local residents. Truck traffic to and from the site will
increase, but the increase is not anticipated to be unreasonable.
Noise levels from fabrication and operation of the incinerator may be high.
Overall, there will be moderate impact on the environment due to the stack or
fugitive emissions from the incinerator and from the noise and traffic
generated by the construction and operation of the unit. The ranking for
public health and the environment is medium.
3.3.2 Compliance with ARARs
An on-site program of incineration may be regulated by several different
guidelines, depending on: (1) the type and degree of contamination,
(2) whether it is a Superfund site or private cleanup site and (3) whether the
management of the cleanup is an EPA-lead or PRP-lead.
-------
-29-
At the IMC site, BHC would be the only contaminant of concern. It is possible
that, due to relatively low concentrations, the regulatory process would be
simplified. If it is ruled that RCRA requirements must be applied, then the
regulatory issues will become more complex. RCRA includes detailed
requirements for trial burn plans, which often require considerable time and
high level of effort. Additional requirements include: (1) emergency
contingency plan, (2) QA/QC, (3) site health and safety, and (4) site security
and site restoration.
Other possible permit requirements that may apply to this site are the Clean
Air Act (CAA), National Environmental Policy Act (NEPA), National Pollutant
Discharge Elimination System (NPDES) for discharge of scrubber wastes, and the
Noise Control Act. Also, typical state requirements are Air Pollution
Control, State Pollutant Discharge Elimination System, Hazardous Waste
Facility Registration Requirement, and Solids Waste Management Requirements.
Along with these permits, possible municipal requirements are discharge
permits and building permits.
The regulatory approach used at each site is highly dependent on the type of
wastes on site and the status of the site. Regulatory compliance is expected
to be streamlined in the future as more sites use incineration for cleanup
programs.
The issue of ash residue is currently handled on a site-by-site basis. The
ash from hazardous waste incinerators is considered hazardous unless it can be
proven non-hazardous using the Toxic Characteristic Leach Procedure (TCLP)
test. The levels of heavy metals in the soil are key factors, since these
contaminants are unlikely to be affected by thermal treatment. If leaching
tests on ash residue reveal that heavy metal levels are too high for
deli sting, stabilization/fixation may be used to reduce the mobility of the
metals, allowing the deli sting of the treated soil. The soil may be replaced
on-site or transported off-site for disposal.
At the IMC site metals are expected to occur at natural soil background
concentrations. It is not anticipated that there will be problems with
delisting of the treated soil.
There appear to be no institutional obstacles to permitting an incineration
facility at the site. The institutional ranking for this alternative is
medium.
3.3.3 Long-Term Effectiveness and Permanence
High temperature incineration is a proven technology which, when operated in
accordance with parameters established during pilot trial burns, is effective
at destroying organic contamination.
-------
-30-
/
The major performance risk associated with on-site incineration is that alt'
the contaminated soil and waste material must be effectively excavated and I
Incinerated and that the incinerator must be properly operated to ensure {
destruction of the contaminants with minimum acceptable air emissions.
Performance for this alternative is rated high.
The reliability of this alternative is high based on the data obtained from
both full-scale and pilot work done at other sites.
3.3.4 Reduction of Toxicity. Mobility or Volume
(1) Incinerator stack emissions - Closely regulated for emissions
of particulate, HS1 and organic contaminants. The stack
emissions quality must' comply with RCRA and TSCA standards.
Impact of stack emissions is likely to be small and of
limited duration (1-2 years).
(2) Fugitive dust and emissions - Fugitive emissions may be
generated during the excavation and handling of soils.
•This may result in undesirable odors and/or unacceptably high
levels of airborne organics on-site or on neighboring properties.
These emissions can be controlled by a number of methods,
including enclosing of the work area, or water spray methods
for dust control. Impact of fugitive emissions should be
small to moderate.
(3) Generation of scrubber effluent - The treatment of stack gases
will generate an aqueous stream which can be used for ash
quenching. This waste stream must be treated prior to
disposal. The scrubber effluent will either be treated to
water quality standards and discharged, or shipped off-site
for disposal at a treatment facility. Environmental impact
from generation.of scrubber water is likely to be small.
(4) Bottom ash and detoxified soil - This material is not anticipated
to pose any environmental risks following treatment. Heavy metal
levels in the soil can be delisted and replaced in the original
excavation area. If it cannot be delisted, it may have to be
further treated. Dust suppression measures will be used to
control fugitive dust emissions. Environmental impact from the
treated soil will be small.
(5) Captured flash or particulate - This material may contain
unacceptable levels of organic contaminants or heavy metals.
This material may be disposed of in a RCRA facility. The
environmental and public health impact from this material will
not be significant.
-------
-31-
3.3.5 Short-Term Effectiveness
Safety to workers Is a primary concern during the operation of high
temperature incineration systems. Leakage of hot gases from kiln seals could
be dangerous to operators. Residue is typically discharged hot, approximately
500°F, from these systems and must be handled carefully or given ample time to
cool.
Thus, these systems can expose operators to some risk if they are not well
informed about the operation of the technology. Therefore, it is imperative
that only well trained and knowledgeable personnel operate these systems.
There is a small potential that occasional improper operation of the system
could result in unacceptable emission effecting offsite workers and residents.
The safety ranking for this alternative is medium.
3.3.6 Implementability
Mobile incineration systems are commercially marketed. There are no
anticipated difficulties in obtaining the appropriate process equipment.
Companies that offer this service report a 4-week mobilization period.
Local building codes, electrical and water supply hookups and air emissions
requirements are to be considered. Obtaining an operating permit for the
incineration system may lengthen the time for erection and startup.
The time periods for key activities are estimated as follows:
Test Burn and Predesign Studies 6 months
Preliminary Design 2 months
Final Design/Permits 6 months
Bid/Award, etc. • 2 months
Site Mobilization 4 months
Demobilization
4 months
The length of operation periods are dependent on the cleanup criteria which,
in turn, decides the volume of the contaminated soil to be processed. If all
of the 31,000 cubic yards of soil must be treated, incineration could be
accomplished in about a year using two mobile on-site incinerators, each with
a 5 ton/hour capacity. A total program time of at least 3 years can therefore
be expected.
-------
-32-
The overall ranking for implementability of this alternative is medium.
3.3.7 Cost Analysis
The cost analysis is based on a rough cost estimate solicited from ENSCO
Environmental Services of Little Rock, Arkansas and on general cost data
accumulated for similar sites.
This company has prepared cost estimates based on brief site description
provided to them. The estimate made was for incineration services only.
The cost for excavation, materials handling and site restoration are estimated
separately. Recent quotes by ENSCO and companies with rotary kiln incinerator
technology have been averaged to approximate the cost for incineration of
31,000 cubic yards of contaminated soil as shown in Table 3.
Operating costs reported in Table 3 represent post-closure monitoring costs.
3.3.8 Support Agency Acceptance
IDEM will accept this alternative with the SARA exclusion from permits if
pilot plant work is done to confirm feasibility. The requirement for close
supervisory attention to the laboratory and incinerator operation is noted.
3.3.9 Community Acceptance
The community accepts this alternative but concerns about incinerator vapors,
wastes and disturbance of the soil require special effluent control.
-------
-33-
3.4 ON-SITE TREATMENT (DECHLORINATION BY APE£ PROCESS)
•/
3.4.0 Description
Alkaline Polyethylene Glycol (APEG) reagents have been used to dechlorinate
certain halogenated organic compound, i.e., PCBs, ethylene dibromide and
chlorinated dioxins. Typically, potassium hydroxide is reacted with
polyethylene glycol to form an alkoxide. The alkoxide, in the presence of
dimethylsulfoxide (DMSO), reacts with one of chlorine atoms of the organic
molecule to produce an ether and potassium chloride. The chemical reaction
may produce other byproducts which can be evaluated for toxicity by bioassay
or identified by analytical methods.
i
Process Description
In the full-scale process, contaminated soil is mixed in a process tank with a
heated alkaline reagent consisting of potassium hydroxide in a solution of
polyethylene glycol and dimethyl sulfoxide. The reagent mixture dechlorinates
the chlorinated organics to form a polyethylene glycol ether, which may
degrade further to form a totally dechlorinated species.
The soil and reagent are mixed to form a slurry, which is heated to 150°C.
Heating to 150°C significantly increases the reaction rates for dechlorination
and boils off the water and many volatile organics held within the soil. The
water vapor and volatile organics used are captured in a condenser and carbon
vapor trap. At the end of the reaction, the slurry is drained and the excess
reagent recovered for recycle. The soil is then washed several times using a
countercurrent extractor, which cycles clean waste into the secondary wash and
moves the secondary wash water into the primary wash. This conserves rinse
water and minimizes the volume of rinse water requiring additional treatment.
Residual/Effluents
The primary wash becomes contaminated with reagent and reaction byproducts
following multiple rinses of processes soil batches. The primary wash is then
mixed with recycled dewatered reagent from the dechlorination step. This
reagent is then used for further dechlorination of soils. Contaminated water
in the reagent mixture is boiled off during the soil heating phase.
The reagent usage rate is approximately 5 gallons/ton. This reagent must be
disposed of after it is exhausted. Incineration of the reagent is included in
the cost estimate ($0.50/lb for high BTU liquids). Some solid residuals may
be generated during cleanup, including some fine clays and silts removed by
-------
TABLE 3
INCINERATION
CAPITAL COST
31,000 cubic yards contaminated soil
Excavation $ 96,000
Operations Area 232,000
Treatment Process 10,311,000
Fuel and Electricity 1,380,000
Replacement of Soils 14,500
Residuals Disposal 341,000
Loam 1' t 31,000
Seed . 2,000
Monitoring 408,000
SUBTOTAL $12,946,000
Pilot (5%) 647,000
SUBTOTAL $13,593,000
Engineering (15%) 2,039,000
Contingency (15%) 2,039,000
TOTAL $17,671,000
OPERATION AND MAINTENANCE COST
Post-Closure Monitoring (5 year semi-annual and
25 years annual)
30-Year Present Worth (10%)
($2,000 x 3.791) + (($1,000 x 9.077)/1.610) $13,000
TOTAL INCINERATION PROGRAM COST
$17,671,000 + $13,000 = $17,684,000
-------
-34-
f1ltrat1ohj;during the washing process. The volume of these materials and
their disposal requirements are difficult to determine without testing. It is
estimated that the volume will be small, as the site soils are predominantly
sands.
Optimal Soil Characteristics
The process operates most efficiently when soil moisture content is below 20%,
The process will dechlorinate in soils of higher water content, but more time
and fuel are required to evaporate the additional water. If soils contain
significantly more than 20% moisture, a pre-dewatering step may be necessary.
Sandy soils are processed most effectively in the APE6 dechlorination system.
Fine particles (clays, silts) clause problems by becoming suspended in the
excess reagent removed at the end of the initial dechlorination step and in
the multiple step water rinse, where they can be difficult to remove. . .
3.4.1 Public Health and Environmental Impacts
The impacts associated with this alternative are less than that for on-site
incineration. Since it is a closed system, air emissions from the process
itself are not a problem. Fugitive dust and organic emissions from material
excavation are the primary concern for on-site workers.
Health and environmental impacts from these residuals are low. Public health
rating of this alternative is therefore high.
There may be some minor unavoidable impacts associated with implementation of
this alternative. The construction of a dechlorination system will require
preparation of a one to two acre staging and operations area adjacent to the
process area. Noise and traffic problems should be minimal during operation
of the dechlorination facility and will be of limited duration.
The overall impact of these activities on public health and the environment
will be low. Environmental impact rating of this alternative is therefore
high.
3.4.2 Compliance with ARARs
The regulatory requirements for implementation of a full-scale dechlorination
system are considerably less complex than for comparably sized incineration
systems. The dechlorination system operates as a closed system and does not
generate significant air emissions as product of the process. Some residuals
may be generated from the dechlorination process, but the quantity of these
-------
-35-
effluents is estimated to be low due to the,high degree of recycling of wash
.waters and reagent. Exhausted reagent can be shipped to an incineration
facility for disposal.
As with other soil excavation alternatives, regulatory requirements will apply
to construction of staging areas for soil excavation, dewatering,-if
necessary, and storage of soils before and after processing.
The institutional ranking for this technology is high.
3.4.3 Long-Term Effectiveness and Permanence
Bench and pilot scale testing of soils from the mound is necessary to evaluate
the process and determine its efficiency. Soil samples, before and after
treatment and condenser liquids would be analyzed for lindane and other
organic byproducts. Information from successful bench-scale testing would be
used to determine costs and time estimates for the lindane dechlorination.
Because of undefined process variables, ranking of this alternative for
performance is low.
The reliability of this technology at full-scale under IMC site.conditions
remains unproven. Data currently are only available for bench-scale tests and
limited pilot study tests. While the feasibility of the process has been
established, problems can be expected during scale-up to full-scale operation.
The reliability ranking for this alternative is low.
3.4.4 Reduction of Toxicity, Mobility or Volume
Effluents and residuals generated by the KPEG process might include spent
reagent, as well as some effluents from the soil rinsing process, (e.g.,
filtered fine particulates, some washwater residuals). These effluents can be
stored in closed containers until they can be shipped.to an off-site facility
for disposal. The ranking of this alternative is low.
3.4.5 Short-Term Effectiveness
APEG dechlorination systems are considered relatively safe. Reactions occur
within a closed system, and risks from the process itself are minimal.
-------
-36-
Polyethylene glycol (PEG) is not considered harmful, and is cleared by the FDA
for use in commercial food preparations. Residual reaction byproducts,
primary ethers, are readily biodegradable and are of low toxicity.
The safety ranking for this alternative is medium.
3.4.6 Implementability
No data exist on the potential problems associated with implementation.
Researchers estimate that full-scale systems can be built using existing heavy
industrial equipment. Reagent-soil mixing tanks for 20-ton batches of soil
can be provided by using commercial mixing tanks used in the the chemical
industry. Countercurrent extraction systems are used in a number of
industries, including metal plating and finishing. Extraction systems can be
designed and built by several firms.
Implementability ranking for this alternative is medium.
3.4.7 Cost Analysis
An accurate cost analysis for APEG treatment of lindane contaminated soils at
IMC will largely depend on the results of a pilot study. Unknown factors
include the following:
1. The formation and identity of breakdown products
2. Soil characteristics
3. Moisture content of soil
4. Dewatering, if necessary
5. Actual concentrations of lindane in mound
6. Pilot study costs
Table 4 presents capital, operation and maintenance, and total program cost
estimates for this alternative based on soil mass of 31,000 cubic yards
(18,000 cubic yards in the mound and- 13,000 cubic yards of soil, 7 foot depth,
under the mound) and a maximum soil moisture content of 20%. These costs have
not been substantiated by real experience and should be used for comparative
purposes only.
3.4.8 Support Agency Acceptance
This alternative is favored if pilot plant testing indicates that scale-up is
feasible. By-product water and fines disposal issues cause less concern than
the removal alternative.
-------
TABLE 4
CHEMICAL TREATMENT (DECHLORINATION) ALTERNATIVE
31,000 cubic yards of Soil
CAPITAL COST
Site Preparation $ 208,000
Soil Excavation and Handling 217,000
Process , 3,592,000
Soil Replacement, Loam & Seed 513,000
Waste Disposal " 374,000
Monitoring _.. 70,000
SUBTOTAL * $4,974,000
Pilot Study (5%) . . 249,000
SUBTOTAL . $5,223,000
Engineering (15%) 783,000
Contingencies (15%) 783.000
TOTAL • $6,789,000
OPERATION AND MAINTENANCE COSTS
Post-Closure Monitoring (5 years semi-annual &
25 years annual)
30 -Year Present Worth (10%)
($2.000 x 3.791) + (($1,000 x 9.077)/1.610) . $13,000
TOTAL CHEMICAL TREATMENT PROGRAM COST
$6,789,000 + $13,000 = $6,802,000
-------
-37-
i',
3.4.9 /Community Acceptance
The community would accept this alternative if assurances are available that
groundwater contamination is avoided. As lower temperatures are involved than
in the incinerator alternative this is the preferred on-site disposal method.
-------
-38-
4.0 SUMMARY AND COMPARISON OF REMEDIAL ALTERNATIVES
A brief summary of each alternative follows:
4.1 NO ACTION (MONITORING AND MAINTENANCE OF EXISTING SYSTEM)
The scope of activities associated with this alternative includes continu-
ation of the quarterly monitoring program, Immediate'repair of the site
security fence, posting of warning signs and the long-term maintenance of site
security and the vegetative cover over the mound.
Groundwater upgradient of the disposal mound now shows no detectable BHC-tech.
This indicates that the site cleanup program undertaken in 1980 was effective
in removing contaminated materials for the ground and placing them under the
on-site clay cap.
Groundwater downgradient of the mound contains BHC-tech. at low
concentrations. Concentration of the gamma isomer (lindane) is well below
established MCL and proposed MCLG levels; that is, well below present and
proposed' future drinking water standards. There are no established standards
for the other BHC isomers, however the total concentration of 'all BHC isomers
has not exceeded one quarter of the MCL for lindane. These data provide proof
that the site closure conducted in 1980 has been effective in reducing
groundwater contamination to safe levels.
Implementation of this alternative meets'site remediation objectives.
Total present worth cost of this alternative is $159,000.
4.2 OFF-SITE DISPOSAL
The scope of activities under this alternative includes excavation of all
contaminated soil disposed in the capped mound (including an estimated seven
feet of undisturbed contaminated soil under the mound) and hauling and
disposing of this material at a RCRA approved secure landfill. After the soil
is removed, the disturbed portions of the site would be graded, covered with
loam and seeded.
During excavation, measures will be taken to protect the exposed contaminated
soil from rainfall percolation. Some contaminant release to the environment
will be unavoidable. Truck and heavy equipment activity will cause noise and
traffic impacts locally.
There is some concern that limited secure landfill capacity will make this
alternative more difficult and/or expensive in the future.
-------
-39-
Th1s alternative will meet site remedial objectives.
Total present worth cost of this alternative is estimated at $17,354,000.
4.3 INCINERATION
The scope of activities under this alternative includes excavation of all
contaminated soil disposed in the capped mound (including an estimated seven
feet of undisturbed contaminated soil under the mound) and processing this
soil at one or more rotary kiln incinerators to be brought onto the site.
After the soil is treated, tested and delisted, some can be used to fill the
disturbed portions of the site; the rest can be placed elsewhere onsite. All
areas where the treated soil is%placed would be graded, covered with loam and
seeded.
During excavation, measures will be taken to protect the exposed contaminated
soil from rainfall percolation. Some contaminant release to the environment
will be unavoidable.' Site activities will cause noise and traffic impacts
locally. There may also be short term impacts on air quality.
Feasibility of the incineration process must be confirmed by a pilot program.
During operation, the incineration process must be carefully controlled and
monitored to assure maximum thermal destruction with minimum emissions.
Total present worth cost of this alternative is estimated at $17,684,000.
4.4 ON-SITE TREATMENT
The scope of activities under this alternative includes excavation of all
contaminated soil disposed in the capped mound (including an estimated seven
feet of undisturbed contaminated soil under the mound) and treating this soil
with a heated alkaline reagent consisting of potassium hydroxide in a solution
of polyethylene glycol and dimethyl sulfoxide. The end products are
dechlorinated organics which are rinsed from the soil. The relatively small
volumes of reagent and rinse waste are then disposed of at an industrial waste
treatment facility. After the soil is treated, tested and delisted, some can
be used to fill the disturbed portions of the site; the rest can be placed
elsewhere onsite. All areas where the treated soil is placed would be graded,
covered with loam and seeded.
Feasibility of this process is questionable and must be confirmed by pilot
testing.
-------
-40-
If the process is feasible, it will meet site remedial objectives.
Total present worth cost of this alternative is estimated at $6,802,000.
4.5 SELECTION OF RECOMMENDED PROGRAM
Table 5 is a comparative summary of the four remedial alternatives.
4.6 All of the alternatives are capable of meeting site remedial objectives.;,
.!_
The potential for human contact and for migration of contaminants into the '!
groundwater or to off-site locations, though low, is present if contaminated '\
materials must be exposed or handled. The maintenance alternative is the onlyi
one which does not involve reexposing and handling the contaminated soil. >
The process parameters, and therefore the feasibility, of the On-Site . i
Treatment (Dechlorination) alternative are not well defined when compared to ;•
the other ;alternatives. For this reason, the overall ranking of this 't1
alternative is the lowest of the four. • /
/
/
Incineration is reliable when properly designed and operated. The technology
is proven and is becoming readily available. A positive consideration is that
contamination would be destroyed yielding'clean soil and little ash. The
process is expensive and not without some short term environmental risk.
Off-Site Disposal carries the advantage that the contaminated materials are
removed from the site and, after the removal process, would not pose any
environmental threat to the local area. The contaminated materials would
carry a low risk of threatening the environment at the ultimate disposal site.
This option is currently very expensive and is not encouraged by EPA. As
secure landfill space becomes increasingly rare, restrictions will be placed
on this type of disposal and the cost will continue to increase. A November
1988 ban on landfilling of certain listed materials, including soil
contaminated with lindane, may eliminate this as a practical alternative.
The maintenance alternative meets site remedial objectives at the least cost
and low environmental risk. The capping system was constructed in 1980 in
accordance with regulations proposed at the time. Although the contaminated
materials remain onsite, the clay capping system prevents physical contact
with contaminants and prevents transfer of contamination to the groundwater
table. The ongoing monitoring program has proven the effectiveness of this
system and has consistently demonstrated that groundwater contamination is
well below drinking water standards. Continuation of the monitoring program
will give early indication if the capping system has failed to the extent that
the groundwater is threatened. A contingency plan to repair or replace the
cap can be enacted before off-site receptors are threatened.
-------
SUMMARY OF REMEDIAL^fTION ALTERNATIVES
COMMUNITY ACCEPTANCE
Monitoring
Maintain Existing
Closure System.
Continue
Monitoring
Off-Site Disposal Incineration
CRITERIA: Ranking
PUBLIC HEALTH/ENVIRONMENTAL
COMPLIANCE WITH ARARS
TECHNICAL FEASIBILITY
Long-Term Effectiveness
and Permanence
Reduction of Toxidty,
Mobility or Volume
Short-Term Effectiveness
Implementability
COST
IDEM ACCEPTANCE
High
High
High
High
High
High
$159,000
High.
MCL/MCLG levels
are presently
attained in
groundwater.
High.
Monitoring
provides
early warning
in event
of cap
failure.
Excavate Mound
and Contaminated
Soils Beneath.
Haul and Dispose
of these Materials
at Secure Landfill
Medium
Low
High
Medium
Medium
Med1 urn
$17,354,000
Low.
Landfill spact
becoming
restricted.
Med1 urn.
Alternative
involves
reexposing
contaminated
materials.
Incinerate Mound
and Contaminated
Soils Beneath In
On-Site Rotary
Kiln
Medium
Med1 urn
«•
High
High
Medium
Medium
!
t
$17,684,000
Medium.
Pilot work
required to
confirm
feasibility.
Close operator
attention 1s
required.
Low.
Alternative
involves
reexposing
contaminated
materials.
On-Site Treatment
Dechlorinatlon of •
Mound and Underlying
Soil Using Alkaline
Polyethylene Glycol
Process
High
High
Low
Low
Medium
Medium
$6,802,000
Medium.
Feasibility is
questionable
and must be
determined by
pilot studies.
Medium.
Alternative
involves
reexposing
contaminated
materials.
-------
-41-
As the aquifer has not been or is not being impacted by contaminated migration
the risk involved in the treatment of the BHC was not found to be as
protective of the environment as leaving the capped mound undisturbed. The
Monitoring and Maintenance alternative is selected among protective, ARAR-
attainlng cost-effective alternatives by a determination of which option best
balances the inevitable tradeoffs among the alternatives in terms of long-term
effectiveness and permanence, the reduction in toxicity, mobility or volume
afforded through treatment, short-term effectiveness, implementability, and
cost, also weighing the statutory preference for treatment as a principal
element, and considering support agency and community acceptance.
i
The maintenance alternative is the recommended program for all of these
reasons. >i
J
; I
4.7 In summary, the recommended alternative is the Monitoring and Maintenance
of the Existing System Alternative based on the following criteria:
4.7.1 - Overall Protection of Human Healthi.'and the Environment -
The maintenance alternative will proyide adequate protection of
human health and the environment due/to the low solubility and
mobility of BHC-tech. in water and soil, it does not involve
handling of the contaminated soil and avoids human exposure and
migration to off-site locations.
4.7.2 - Compliance with ARARs - the recommended alternative will meet'
all of the applicable or relevant and appropriate requirements of
other Federal and State environmental laws. The system has
demonstrated effectiveness at meeting MCLs and the proposed
MCLGs. See Table 6.
4.7.3 - Long-Term Effectiveness and Permanance - the preferred
alternative is believed to afford a permanent adequacy and
reliability. If problems arise an upgraded cap can be installed
in the future based upon information supplied by the monitoring
system. This contingency plan will provide further security if
the early warning system indicates it is required.
• 4.7.4 - Reduction of Toxicity, Mobility or Volume - the alternative
adequately prevents mobility of BHC-tech. due to the low water
infiltration through the cap, the high adsorbancy of BHC on the
organic portion of the soil and the low solubility of the
contaminant in water. No opportunity, is allowed for migration or
exposure due to movement of the soil. Slow decomposition of BHC
due to microbial activity will reduce the concentration over
time.
4.7.5 - Short-Term Effectiveness - the preferred option prevents any
adverse impacts upon the human health of the community or workers
-------
TABLE 6
SUMMARY OF APPLICABLE OR RELEVANT AND APPROPRIATE REGULATIONS
FOR REMEDIAL ACTION ALTERNATIVES -
Alternative
Monitoring A Maintenance
Off-Site Disposal
On-Slte Incineration
On-Slte Treatment
Regulations
The construction of the waste mound was voluntarily performed by IMC
prior to the RCRA effective date of October 1980. Therefore, this Is
not a Transportation, Storage or Disposal (TDS) facility by RCRA statutes
and does not require two or more liners and a leachate collection system
above and between the liners (320 IAC 4.1-53-2(1).
Groundwater Standards
Water quality standards which apply tj> the waters of Indiana appear 1n
330 IAC 1-1(2). They are narrative in nature and require Interpretation
by the Office of Water Management (OWM).
The Water Pollution Control Board has recently promulgated new water
quality standards 327 IAC 2-1(3). These standards are awaiting final
approval. In this document 327 2-1-7 applies to underground waters.
When finalized, 327 IAC 2-l-6(a) and 327 2-1-7 would be applicable.
On-S1te Construction Activities
Any on-slte construction activities which may .create a significant amount
of fugitive dust are regulated under 325 IAC 6-4-6(4). This rule
requires that every available precaution be taken during construction
to minimize fugitive dust emissions.
Indiana statutes filed in Administrative Record
-------
-42-
as further exposure is avoided. Other alternatives would require
excavation, transportion or redisposal.
4.7.6 - Implementability - the recommended remedy requires no further
immediate action to complete. Analytical sample points and
procedures are established, security systems are in place, the
performance is proven, no further permits or off-site actions are
required from other agencies.
4.7.7 ,- Cost - the capital for the preferred "no-action" alternative
^consists of a contingency fund for future repairs, monitoring and
((replacement. The present worth of a 30 year program at a 10%
^discount rate is $159,000. This is less costly than the other
;options by from $6.6 million to $17.5 million on a present worth
libasis.
4.7.8 ;i- Indiana Department of Environmental Management Acceptance -
iiafter reviewing and commenting on the RI/FS and close interaction
;ftn the RI stages IDEM concurs with the selected remedy.
4.7.9 /- Community Acceptance - Comments received during the setting of
'the RI/.FS work plan indicated local support for the proposed
remedy. No negative comments were received on this alternative.
Comments were in favor of not reexposing the local population to
the contaminated soil.
5.0 RECOMMENDED PROGRAM
5.1 GENERAL
The No Action/Maintenance, program recommended for the site involves systematic
monitoring backed up by a contingency plan of action. The program objectives
are to: •
0 Confirm that the closure system continues to.prevent transfer of
contamination to the groundwater.
0 Provide early warning should capping system failure occur.
0 Establish a contingency plan for cap repair or replacement.
5.2 MONITORING PROGRAM
The on-going quarterly monitoring should continue until December 2010 (30
years after closure was completed in 1980) and so noted in the deed for the
property.
-------
-43-
Major elements of this program include:
0 Quarterly cap inspection; maintenance of vegetative cover as
necessary.
0 Sampling of upgradient wells PW-1, B-l and B-2 with analysis
conducted for BHC isomers. (Semi-annual sampling for next 5 years,
annual thereafter until year 2010).
0 Sampling of downgradient wells B-9A, B-10A and B-11A with analysis
conducted for BHC isomers. (Semi-annual sampling for next 5 years,
annual thereafter until year 2010). j,
i!j
0 Annual reporting of monitoring results;* to the State of Indiana.
. i
0 A' review of the results of the remedial action will be conducted with
IDEM and the U.S. EPAtat the end of eae;h five period.
'. •
; I
'. I
/ i *
An estimate of the, cost of this program, expressed iniDecember 1987 dollars,
appears in Table 7. This cost estimate includes an allowance for replacement
of the fence surrounding the disposal mound halfway through the monitoring
period. '
5.3 CONTINGENCY PLAN
The monitoring program will give early warning should the clay cap over the
mound fail. Prevailing contaminant levels immediately downgradient of the
mound are well below the MCL/MCLG acceptable drinking waters levels. Should
contamination reach the MCLG level, or show a consistent, significant (order
of magnitude) rise above prevailing levels over more than two monitoring
periods, additional samples will be taken to determine if remedial action may
be necessary. Because of the variability inherent in sampling and in
laboratory analytical techniques, it is not possible to propose objective
criteria for initiating cap repair; data must be evaluated in the context of
previous data and judgement must be applied prior to initiating action.
Remedial action would definitely be necessary any time the quarterly
inspection shows slumping or erosion at any location on the cap.
If localized failure is obvious, the recommended action is to expose and
repair the clay in the area of the failure. After repairs are made, the
vegetative cover would also be restored.
If no failures are obvious and the data demonstrate that transport of the
contaminants to the groundwater is occurring, then replacement of the cap
would be necessary. The most effective means of doing this under these
circumstances is to strip the vegetative cover, leaving the common fill over
-------
TABLE 7
NO ACTION ALTERNATIVE
(MONITORING AND MAINTENANCE OF EXISTING SYSTEM)
CAPITAL COST
NO INITIAL CAPITAL COSTS ASSOCIATED
WITH THIS ALTERNATIVE
OPERATION AND MAINTENANCE COST
Cap Inspection, Mowing, Repairs $10,000
Sampling & Analysis . SEE BELOW
Record Keeping and Review 5,000
SUBTOTAL ANNUAL O&M " $15,000
Allowance for Replacement of Fence in 15 Years $20,000
Sampling and Analysis (Semi-annual for first 5
years, annual thereafter through year 2010)
Present worth (10%) = ($2000 x 3.791) + ((1000
x 8.20)71.610) =
30-Year Present Worth (10%):
TOTAL O&M COST ($15,000 x 9.427) + ($20,000 x 0.2394)
$141,000 + $5,000 + 13,000 = $159,000
TOTAL NO ACTION PROGRAM COST: $159,000
-------
-44-
the clay, to install a high density polyethylene membrane over the entire
mound, then install a new vegetative cover over the membrane.
The membrane cover system would consist of six inches of sand on the sides of
the membrane, with six inches of common fill and six inches of seeded loam
over the top layer of sand. Six inches of clay beneath the membrane is
necessary to provide an impervious bedding and to protect the membrane from
sharp stones or other potentially damaging materials in common fill. The
remaining fill and loam are necessary to sustain the vegetative cover.
A review of the results of the remedial action will be conducted with IDEM and
the U.S. E,ffA at the end of each five year period commensing with the signing
of this ROP. The need for such a review, the results of each review and any
actions required as a result-of such review will be reported to Congress as
required in the Superfund Amendments Reauthorization Act Section 121(c).
-------
APPENDIX
TERRE HAUTE - EAST PLANT BHC CONCENTRATIONS IN GROUNDWATER SAMPLES
SAMPLING - IMC/TERRE HAUTE
ANALYSIS HAZLETON LABORTORIES AMERICA, INC,
AKA HAZLETON RALTECH, INC.
3301 KINSMAN BLVD
P.O. BOX 7545
MADISON, WISCONSIN 53707
(608) 241-4471
-------
RAILROAD
YARD
FIGURE 1
tf*m.m
"/•T
ULRICH i Jy
CHEMICAL !W
Site Area Map
IMC East Plant Site
Terre Haute, Indiana
FARM BUREAU
CO-OP
Springfield
A
GRANDVIEW
CEMETERY
A
Lexington
Disposal Area
Inactive Buildings
Fence
Monitoring Wells
LEGEND
IMC East Plant Property Boundry
-------
Hrl STATVDN
RUNOFF INTERCEPTOR
DITCH
GRAVEL PERCOLATION
PIT
• PRODUCTION. \1_r
\ - CHEMICAL '
GSAN3VEW C2MS7ESY
MAP ADAPTED FROM IMC SfTE MAP
TG OF OBSERVATION WELL LOCATIONS
i X
FIGURE 2
SITE MAP
100 0 100 200 300
APPROX. SCALE IN FT.
IMC EAST PLANT
TERRE HAUTE, IN
WELL LOCATIONS
-------
FIGURE ~ 3 IMC EAST PLANT SITE
SAMPLING LOCATIONS
*or roc c 400 too
-------
I*-1" 1
K
,t
J
-/7=^1
INDIANA CAS AND CH£MICAL*\ /
)(
i
-1
•Vn P^ * F^
i I u> I
V II fe- Ur j
\O V__^_— ^-'^j
JS. PL. rW °
LJLJLJLJ
innrin
FIGURE
RESIDENTIAL WELL LOCATIONS
SURROUNDING THE IMC EAST PLANT
TERRE HAUTE', IN
o- PRIVATE RESIDENTIAL WELLS
* WELLS'SAMPLED BY WESTON-SPER
-------
tl
V
•H
t>
m
C
C
tl
O
«J
(I
tl
c
o
V
ft
14
HAD ASH RIVER
* 550-
500 •
450
400
350
A'
THOMPSON DITCH
EAST
PLANT SITE
STRIP
MINED AREA.
X
approximate water table elevation
GLACIAL OUTHASH
PETERSBURG FORMATION
EXPLANATION
vj] gravel
1000
HORIZONTAL SCALE
•
1000 2000
3000
FIGURE 5
VERTICAL EXAGGERATION: x 20
GENERALIZED GEOLOGIC CROSS-SECTION A-A'
4000 feet
P.E. L*Mof»*u« &
Inc.
-------
&
I
O OAUUABHC
WELL B-9A
Proposed MCLG for Lindane
DATE
•*> TOTAL BHC-T«<*
WELLB-KJA
OIC *- TEWS Hum. INDIAN*,
Note: MCL for Lindane is 4 ppb
t
^/x,
\
\
'• \ Av
~* \
\
~N, .\
^1\n n B _ _ ug
B~ e u^i
\
\ r\
M / x.
/ \ / \
i/ \-/
'•i^*-8^^-— -»^\
Proposed MCLG for Lindane
Oel-U
C OMAUSHC (UNOWC)
DATE
DM 83 Jan-XT
*• TOTAi. BHC-T«c*
Figure -e.
CONCENTRATION FOR LINDANE AND
TOTAL BHC AT B-9A AND B-10A
MONITORING WELLS
-------
DATE
ANM^ED
9/21/M1
2/4/82
7/1/82
9/21/82
12/9/82
3/22/83
6/20/83
9/30/83
1/10/84
3/26/84
6/18/84
9/26/84
10/27/04
10/27/84
11/13/84
11/13/84
12/20/84
4/4/85
4/10/85
6/27/85-
10/8/85
10/8/85
1/6/86
3/21/86
6/23/86
9/11/86
WELL'
NO.
B-10A
B-10A
B-10A
B.-10A
B-10A
B-10A
B-10A
B-10A
B-10A
B-10A
B-10A
B-10A
B-10A
B-IOA(DUP)
B-10A
B-10A
B-10A
8-10A
B-10A
B-10A
B-10A
B-10A
B-10A
B-10A
R-10A
R-10A
• ALPHA
BHC
0.130
0.140
0.100
0.070
0.070
0.070
0.060
0.067
0.050
0.070
0.070
<0.010
0.070
0.070
0.080
0.070
<0.010
0.070
0.080
0.061
0.050
0.050
<0.010
<0.010
0.050
0.051
BETA
BHC
0.330
0.300
0.320
0.220
0.240
0.280
0.220
0.035
0.240
0.310
0.280
<0.010
0.310
0.150
0.350
0.290
<0.010
0.097
0.347
0.243
0.160
0.180
<0.010
<0.010
0.270
0.240
GAMMA
BHC^
0.190
0.130
1 0.100
0.060
0.060
0.060
0.050
0.058
0.050
0.060
0.050
<0.010
0.060
0.060
0.070
0.060
<0.010
0.055
0.020
0.049
0.050
0.060
<0.010
0.040
0.040
0.042
DELTA
> BHC
0.060
0.220
0.200
0.140
0.160
0.13
0.200
0.230
0.040
<0.010
<0.010
<0.010
0.190
0.180
0.170
<0.010
<0.010
0.124
0.270
0.132
0.130
0.140 .
<0.010
<0.010
0.000
0.124
TOTAL . COMMENTS
0.710
0.790
0.720
0.490
0.530
0.540
0.530
0.390
0.380
<0.450
^<0.410
<0.040
0.630
0.460 CHCL3 <1: C2H2CL4 <
0.670
0.430
<0.040 CHCL3 <10
0.355
0.710 EAEI SURVEY SPLIT
0.485
0.390
0.430 DUPLICATE SAMPLE
<0.040
<0.070
0.440
0.457
: C6H6 <2
-------
- - _ - - t
-------
DATE
/Av ZED
9/21/81
7/1/82
9/21/02
12/9/02
3/22/03
6/20/03
9/30/03
1/10/04
3/26/04
6/10/04
9/26/04
10/27/04
12/21/04
4/4/85
6/27/85
10/8/85
1/6/86
3/21/06
6/23/06
9/11/86
10/20/06
12/3/06
3/10/07
9/23/07
WELL
NO.
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
HIGH
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
PW-1
ALPHA
BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
UETA
BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
TOTAL COL I FORM FOUND IN
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
GAMMA
''''•
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
SAMPLE -
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0,01
<0.01
<0.01
<0.01.
<0.01
DELTA
BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.06*
<0.01
<0.01
<0.01
<0.01
- - HEAVY
<0.02
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
TOTAL- COMMENTS
i
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.075
<0.04
<0.04
<0.04
' <0.04
DOSE OF HIH PUT DOWN WELL
<0.05 CHCL3 113: C2H2CL4 <1: C6H6 <2
<0.04 CHCL3 <10
<0.04
<0.04
<0.04
<0.04 .
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
-------
DATE
AMALYZEO
9/21/81
2/4/82
7/1/82
9/21/M2
12/')/82
3/22/83
6/20/83
9/30/83
1/10/84
3/26/84
6/18/34
9/26/84
10/27/84
11/13/84
4/4/85
6/27/85
10/3/85
1/6/86
3/21/86
6/23/86
9/11/86
12/3/86
3/10/87
6/13/87
9/23/87
WELL
NO.
B-l
B-l
U-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
B-l
ALPHA
mic
<0.01
0.03
<0.01
. <0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
BETA
BMC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
GAMMA
mic
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
OELTA
BMC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01*
<0.01
<0.01
<0.01
<0.01
<0.02*
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01 -
TOTAL COMMENTS
<0.04
<0.06
<0.04
<0.04
<0.04
<0.04
<0.04
<0.025
<0.04
<0.04
'" <0.04
<0.04
<0.05 CHCL3 <1 : C2H2CL4 <1: C6H6 <2
<0.04
<0.04
<0.04
<0.04
<0.04 ,
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
-------
DATE
ANgkED
2/4/82
7/1/82
9/21/82
12/9/82
3/22/83
6/20/83
9/30/83
1/10/84"
3/26/84
6/18/84
9/26/84
10/27/84
11/13/84
12/20/84
4/4/85
4/10/85
6/27/85
10/8/85
1/6/86
3/21/8G
6/23/86
'9/11/86
— 12/8/86
3/10/87
6/18/87
9/23/87
WELL
NO.
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
ALPHA
BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01 .
<0.01
' <0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
BETA
BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
. <0.01
<0.01
<0.01
GAMMA
BHcf
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
DELTA
I BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
vfV f\A^f
V u » v» H~
<0.01
<0.01
<0.01 *
<0.01
<0.02*
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
' TOTAL COMMENTS
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.055
<0.04
<0.04
<0.04
^0.04
<0.05 CHCL3 <1 : C2H2CL4 <1: C6H6 <2
<0.04
<0.04 CHCL3 <10
<0.04
<0.04 EAEI SURVEY SPLIT
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
<0.04
-------
DATE
ANALYZED
2/4/82
7/1/82
9/21/82
12/9/32
3/22/83
6/20/83
9/30/83
1/10/84
3/26/84
6/18/H4
9/26/H4
10/27/84
11/13/84
12/20/84
4/4/85
6/27/85
10/8/85
1/6/86
3/21/86
6/23/86
9/11/86
12/8/86
3/10/87
6/18/87
. 9/23/87
WELL
NO
IM1A
B-11A
B-11A
B-11A
B-11A.
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
U-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
B-11A
ALPHA
BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
. <0.01
<0.0l
<0.01
<0.01
<0.01
<0.01
BETA
mic
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.012
<0.01
<0.01
<0.01
<0.01
GAMMA
BHC
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.005
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.02
<0.01
<0.01
DELTA
BHC
<0.01
<0.01
<0.01
-------
(CONCENTRATIONS IN MICROGRAMS/LITER)
WELL ALPHA BETA GAMM^ DELTA TOTAL COMMENTS
NO. BHC BHC BHC^T BHC
12/20/84 B-5 <0.01 <0.01 <0.01 <0.01 <0.04 CHCL3 <10
6/18/07 B-5 <0.01 <0.01 , <0.01 <0.01 <0.04
-------
IMC ADMINISTRATIVE RECORD
GUIDANCE DOCUMENTS - NOT COPIED
MAY BE REVIEWED AT EPA
IN CHICAGO, IL
TITLE
AUTHOR
DATE
Community Relations Activities at
Super-fund Enforcement Sites
Guidance on Remedial Investigations
and Feasibility Studies
NEIC Policy and Procedures Manaual
Remedial Action at Waste
Disposal Sites, Handbook •
\
Superfund State Lead Remedial
Project Management Handbook
Draft
Timely Initiation of Responsible
Iparty Searches, Issuance of
Notice Letters, and of
Information
85/03/22
85/05/00
85/05/00
85/06/00
86/06/00
86/10/09
IMC DOCUMENTS INCLUDED IN ADMINISTRATIVE RECORD
TITLE
AUTHOR
DATE
PAGES
Final Report; National Dioxin
Study Tier 6 Dioxin Screening
Report of the Lindane
Advisory Committee
Lindane; Monograph of an
Insecticide
Chronic Toxicity of Lindane to
Selected Aquatic Invertebrates
and Fishes
Preliminary Assessment
MMiller - Ecology & Envrnmnt 00/00/00
I
'otential Hazardous Waste Site
Site Inspection Report
U.S. EPA
70/07/02 22
72/00/00 30
76/05/00 25
Ecology & Environment Inc. 83/04/11 5
EPA 84/01/26 18
-------
TITLE
Documents regarding meetings
between U.S. EPA and IMC et al
Site Assessment for IMC
Federal Register: Lindane;
Amendment of Notice of Intent
to cancel pesticide products
containing lindane
Memo to Regional Environmental
Officer, USOI, Chicago
Re: Preliminary Natural
Resources Survey, IMC
Manual of Acute Toxicity: -.
Interpretation and Data Base for
410.Chemicals and 66 Species
of Freshwater Animals
Exhibit A Work Plan RI/FS
Administrative Order on Consent
EPA Environmental News Release
Health & Safety Plan for
IMC Est Plant Site (1st Draft)
Community Relations Responsiveness
Summary for the Public Comment
Period on the IMC Administrative
Order on Consent
QAPP (Revised)
Responsiveness Summary for the
Public Comment Period on the
IMC Administrative Order
on Consent
QAPP for IMC (2nd Revision)
Draft QAPP - Surfact Soil
Sampling and Analyses at IMC
AUTHOR
Weston Sper
Regional Director, FWS
U.S. Dept of the Interior
Camp Dresser & McKee Inc.
U.S. EPA
U.S. EPA
Camp Dresser & McKee Inc.
U.S. EPA
Camp Dresser & McKee, Inc
U.S. EPA
DATE PAGES
85/00/00 5
85/02/00 • 40
85/02/08 3
85/11/00
86/00/00
86/05/23
86/08/06
86/09/08
86/09/29
15
29
2
27
86/11/24 10
86/12/05 77
87/01/12 10
RSocki - U.S. EPA
87/03/00 78
87/04/14 8
-------
TITLE
AUTHOR
DATE
PAGES
Project Operations Plan for IMC
East; Plan Site RI/FS
Includes QAPP, Health & Safety
Plan, Site Work Plan
Final Community Relations Plan
IMC
EPA Environmental News Release
RI
FS
Indiana ARARs
Responsiveness Summary
Camp Dresser & McKee Inc.
87/05/00 120
Jacobs Engr. Group Inc.
U.S. EPA
Camp Dresser & McKee, Inc.
Camp Dresser & McKee, Inc
IDEM
U.S. EPA
87/05/08 .36
87/05/19 1
87/08/00 100
88/01/00 78
88/04/15 68
88/06/00 37
------- |