United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-88/075
August 1988
SEP A
Superfund
Record of Decision:
Fort Wayne Reduction, IN
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50273-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R05-88/075
3. Recipient* s AccmsJon No.
4. Title end Subtitle
SUPERFUND RECORD OF DECISION
Wayne Reduction, IN
Remedial Action - Final
7. Authors)
5. Report Date
>rt Date
08/26/88
8. Performing Organization Rept. No.
9. Performing Organization Name and Addreta
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
19. Supplementary Note*
16. Abstract (Limit 200 word*)
The 35-acre Fort Wayne site (FW) is a former municipal landfill/waste disposal
facility located along the Maumee River just east of the city of Fort Wayne, Allen
County, Indiana. Two onsite areas are designated as wetlands. In addition,, the site
lies within a 100-year flood plain. The primary land use in the general area is light
industrial and commercial. In addition, other landfills, a wastewater treatment plant,
»d sludge drying beds are located along the Maumee River in the vicinity of the site.
o residential communities are located approximately one-half mile from the site.
Before 1967, the site was uncultivated farmland often used for the dumping of unknown
waste. The site accepted residential and industrial wastes from 1967 to 1976. Few
records were kept on the volume and composition of wastes, or on the industries that
generated the wastes. From May 1967 to August 1970, FW was issued a county permit- for
public disposal of garbage and rubbish. Wastes were incinerated and the residual ash
disposed of onsite. In 1970, FW changed its name to National Recycling Corporation
(NRC) and built a recycling plant which apparently became inactive after February 1975.
All solid waste was to be processed through the plant. It was torn down in 1985.
Inspection reports indicated that deposited refuse included: industrial and liquid
wastes, municipal wastes, garbage, paper, and wood. A 40- to 60-foot diameter pit
(See Attached Sheet)
17. Document Analysis a. Descriptor*
Record of Decision
Fort Wayne Reduction, IN
First Remedial Action - Final
Contaminated Media: gw, soil
organics (phenols, PCBs, PAHs), VOCs
. COSATI Field/Group
pailability Statement
19. Security Class (This Report)
None
2O. Security Class (This Page)
None
21. No. of Pages
130
22. Price
(SMANSI-Z39.18)
See /nstructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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^PA/R
P"
Tirst
A/ROD/R05-88/075
rt Wayne Reduction, IN
Remedial Action - Final
16. ABSTRACT (continued)
adjacent to the Maumee River contained pools of volatile liquids. Wastes were disposed
of into the pit by cutting off the drum tops and emptying the contents into the pit.
There were no records indicating exactly what was dumped into the pit. NRC operation
became part of Service Corporation America (SCA) in 1973. In 1974, SCA was denied a
municipal refuse permit due to site closure problems encountered following high water
levels. Hazard Ranking System records indicate the entire site's waste quantity was
equivalent to 2,820 fifty-gallon barrels. In 1984, Waste Management Inc. (WMI)
acquired SCA and conducted an initial site investigation. The site has been inactive
since 1976. The site consists of two characteristically different areas reflecting its
historical use: the eastern half of the site was used as the municipal/general refuse
landfill .(approximately 15 acres), and the western half of the site (approximately
5 acres) was used for disposal of industrial wastes, building debris, barrels of
unidentified wastes, and residual ash from earlier incineration operations. Presently,
soil and ground water are contaminated with 43 chemicals of concern including: metals,
organics, PCBs, PAHs, phenols, and VOCs.
The selected remedial action for the eastern portion of the site includes: deed and
access restrictions; soil capping consistent with State solid waste closure _ •
^quirements; and long-term ground water monitoring. The selected remedial action for
western portion includes: excavation, re-consolidation, and on- or offsite
fcineration of approximately measures for the portions of the site within the 100-year
floodplain; and compensation for any loss of wetlands due to remedy construction by
enhancing onsite wetlands. The estimated present worth cost for this remedial action is
$10,020,000.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Fort Wayne Reduction
Fort Wayne, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action for the
Fort Wayne Reduction site developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA) and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative record for
the Fort Wayne Reduction site. The attached index identifies the items
which comprise the administrative record upon which the selection of a
remedial action is based. I
• f
The State of Indiana, through the Department of Environmental Management,
concurs with the selected remedy.
DESCRIPTION OF THE REMEDY
This final remedy addresses the contamination present at the site by
eliminating, reducing or controlling the risks posed by the site through
treatment, and engineering and institutional controls.
The major components of the selected remedy include:
o Excavate the area defined as Area C in the western portion
of the site to remove an estimated 4,600 drums containing
liquids.
o Incinerate drum contents.
o Reconsolidate the soils and waste excavated during the drum
removal.
0 Install and maintain a groundv/ater collection system on the
western portion of the site to protect the Maumee River from
the migration of contaminated groundwater into the Maumee
river at unprotective levels.
0 Provide for the removal of contaminants from the collected
groundwater through treatment, if necessary.
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o Install and maintain a soil cover compliant with the
"hybrid" closure requirements outlined in the Record of
Decision Summary on the western portion of the site.
0 Install and maintain a soil cover compliant with Indiana
Subtitle D - solid waste landfill closure requirements over
the eastern portion of the site to prevent erosion that
could result in a direct contact threat, or washout of the
wastes into the Maumee River.
0 Monitor groundwater on the eastern portion of the site to
ensure that any contaminants present do not pose a threat to
the Maumee River in the future.
0 Install and maintain a fence around the site, except along
the river, to protect the soil covers and restrict public
access to the site.
0 Limit both present and future use of the site and limit the
installation of wells on the site, through deed
restrictions.
o Provide and maintain flood protection measures for that
portion of the site within the 100-year floodplain. ~
*•
o Compensate for any loss of wetlands due to remedy
construction by enhancing an pn-site wetland.
DECLARATION
The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant
and appropriate to the remedial action, and is cost-effective. This
remedy satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility or volume as a principal
element, and utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted no less often than
every 5 years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and the
environment.
Date ' Vildas V.
Regional Administrator
Region V
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RECORD OF DECISION SUMMARY
FORT WAYNE REDUCTION
I. SITE DESCRIPTION
The Fort Wayne Reduction site is just east of the City of Fort Wayne
in Allen County, Indiana, approximately 1.1 miles east of the U.S.
Highway 30 and the Maumee River intersection. The communities of
River Haven and Sunnymede Woods are approximately one half of a mile
east and south of the site respectively (Figure 1).
The 35-acre site is bordered by the Maumee River to the north, the
Norfolk and Western Railroad to the south, Dager Auto Parts and Martin
Landfill to the west, and Herber Drain to the east.
The primary land use in the general area of the site is light industry
and commercial. In addition, other abandoned landfills and the
wastewater treatment plant and sludge drying beds are located along
the Maumee River in the vicinity of the Fort Wayne Reduction site.
The site is within the Maumee River? valley physiographic unit. The
topography of the surrounding area is typical midwestern glaciated
terrain with only a few low, rolling hills and depressions. The site
has slopes ranging from 18 percent at the eastern edge to near level
at the middle. Vegetation on the site is mostly grass and small
brush. Some larger trees can be found along the edges of the site and
along the river bank.
Two areas on-site are designated as wetlands. One is located along
the north sloping bank in the eastern portion of the site and the
other is at the eastern site boundary. In addition, the site is
within the 100-year floodplain. The floodplain includes most of the
area along the river, the low lying area near Herber Drain, the area
along the southeast corner of the site, and the area behind the on-
site fence (Figure 2).
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
The Fort Wayne Reduction site accepted residential and industrial
wastes from 1967 to 1976. Few records were kept on the volume and
composition of wastes, or on the industries that generated the wastes.
Site inspections by the Indiana State Board of Health (ISBH) and other
agencies during the site's operating years are the primary sources of
information.
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FORT WAYNE
FORT WAYNE
14 ) MUNICIPAL
SEWAGE
FILTER BEOS
FORT WAYNE
REDUCTION
2000
1000
SCALE IN FEET
INDIANA
FORT WAYNE
I I
SOURCE: Fort^W"* EJII USCS Outdranglt map.
FIGURE
LOCATI
FT. WAYNEWDUCT ION F S
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sin IOUNOAHV
ota—_
I .--V*
O '»
UOINO
Of UI
ICAll IN fill
Af»dO«m»TI tOUNOAKIII
' of M/tin niGioxt
Approximate boundaries of the
100 year floodplain (753 ft above MSL)
FIGURE!
SITE MAP
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1. Prior to 1967
Before 1967 the site was uncultivated farmland which was often used
for dumping. There is no indication of waste types dumped.
2. 1967-1970 (The Incinerator Period)
Fort Wayne Reduction, Inc. was issued a permit for public disposal of
garbage and rubbish on May 17, 1967, by the Allen County Board of
Health. The.wastes were processed through an on-site incinerator with
the ashes disposed of on-site. The incinerator was put out of
commission in August 1970.
3. 1970-1975 (The Landfill ing Period)
In 1970, Fort Wayne Reduction, Inc. changed its name to National
Recycling Corp. (NRC). A recycling plant was built, however, no
records were kept on when operating began or ended. The plant was
apparently inactive after February 1975, and the buildings were torn
down in 1985. All solid waste was to be processed through the plant.
Later inspection reports state the refuse deposited included wood,
paper, liquids, garbage, industrial wastes, municipal wastes,
industrial liquids, and sludges (paints, varnishes, etc.).
As indicated by a 1973 aerial photograph, most of the eastern half of
the site was actively being used as a general refuse landfill.
Portions north and west of the recycling plant were utilized for
disposal of industrial wastes, building debris, and occasional barrels
of unidentified wastes.
When National Recycling Corp. began accepting liquid waste is not
clear, but photos depict a pile of barrels behind the incineration
location as early as March 1971. A 40- to 60-foot-diameter pit
containing a pod of volatile liquids adjacent to the Maumee River was
first reported in May 1972. The wastes were deposited into the pit by
cutting the drum tops off and emptying the contents into the pit.
Some drums were reported floating on the surface of the solvents in
the pit. An apparent drum burial pit was located on aerial
photographs taken in 1973.
There are no records indicating exactly what was dumped into the pit.
ISBN inspection reports classified the wastes as volatile liquids,
chemical, or hazardous or prohibited wastes. A former waste hauler
described some of the waste taken to the site as "acidic material." A
January 1975 letter from National Recycling Corporation to the ISBH
contained a chemical analysis of "a general waste which I would like
to dispose of." The waste consisted of 25 percent to 30 percent
organic resin, polyester, amide-imide nylon, etc. The remaining 70
percent was solvent consisting of cresylic acid 100 hydrocarbon
solvent, xylene, and sometimes n-methyl pyrrolidone and very small
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amounts of other contaminants. Mo indication of how or where the
wastes were eventually disposed was given.
NRC operation became a Service Corporation of America (SCA) operation
in 1973. In 1974 SCA had a permit application for disposal of
municipal refuse withheld because of problems with closing of the site
after high water was experienced in 1973.
A copper wire salvage operation was also planned during this period.
The records do not indicate whether this plan was ever carried out.
4. 1976-1981 (The Inactive Period)
During this period the site was inactive.
5. 1981-1985 (The Discovery and Listing Period)
The site was proposed for addition to the National Priorities List
(NPL) in October of 1984 and was finalized on the NPL in June of 1986.
The site was listed by U.S. EPA using the Hazard Ranking System (MRS).
MRS records state that the landfill had accepted volatile industrial
liquids, 2,4-dimethyl phenol, methylene chloride, arsenic, .and sludges
and that the entire site's waste quantity was equivalent to-2,820 50-
gallon barrels.
Also in 1984, Waste Management Inc. (WMI) acquired SCA. WMI conducted
an initial investigation of the site that year. In early 1985, WMI
completed its hydrologic assessment of the site and had a closure plan
prepared. At that time EPA and WMI entered into discussions as to the
needs and responsibilities of further investigations at the site.
6. 1986-Present (RI/FS Period)
In February of 1986, U.S. EPA released its findings on residential
well samples from the River Haven community. There was no evidence of
contamination in the samples nor was there evidence of contamination
derived from the Fort Wayne Reduction site. Subsequently, U.S. EPA
initiated the Remedial Investigation (RI) of the site to define the
nature and extent of contamination present and characterize the
potential threats to public health and/or the environment from the
site. RI field activities were performed in two phases and were
completed in May 1987. The results are described in the RI report,
dated January 7, 1988.
The Public Comment Feasibility Study (FS) was completed May 2, 1988.
The FS documents, in detail, the development and evaluation of an
array of remedial action alternatives for the Fort Wayne Reduction
site. Public comment on the FS ended June 7, 1988.
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B. Enforcement Activities
U.S. EPA has identified approximately fourteen Potentially Responsible
Parties (PRPs) for the Fort Wayne Reduction site. U.S. EPA identified
the PRPs on the basis of site records (i«e., customer listings) and
responses to information requests submitted pursuant to Section 104(e)
of CERCLA.
Four of these PRPs were identified by a general Notice Letter dated
January 6, 1988. On February 2, 1988, U.S. EPA held a meeting with
the four PRPs to discuss the RI and future enforcement activities.
The remaining ten PRPs were subsequently identified in a general
Notice Letter dated April 28, 1988.
On May 5, 1988, Special Notice Letters were sent to the fourteen PRPs
pursuant to Section 122(e) of the Superfund Amendments and Reauthori-
zation Act (SARA) of 1986. On May 24, 1988, representatives from
U.S. EPA, IDEM and IAG met with the PRPs to discuss the Feasibility
Study/Proposed Plan and enforcement activities for the site. The
deadline for receipt of a "good faith offer" to conduct the remedial
design and remedial action discussed in this Record of Decision
Summary was July 11, 1988. A "good faith offer" to conduct the
remedial design and remedial action was received from one o? the PRPs.
Therefore, the deadline for negotiations was extended to September 9,
1988.
III. COMMUNITY RELATIONS HISTORY
During the RI/FS, U.S. EPA and IDEM met several times with, and
supplied fact sheets to, the community. In addition, two information
repositories were established to provide both general and project-
specific information and reports to the community.
In accordance with CERCLA Section 117, the U.S. EPA published a
Proposed Plan for the site. This document was mede available at the
start of the public comment period. A public meeting was held on May
11, 1988 to discuss the Public Comment Feasibility Study and U.S.
EPA's Proposed Plan. Comments received at the May 11, 1988 meeting
and during the public comment period (May 4, 1988 to June 7, 1988) are
addressed in the Responsiveness Summary (Appendix A).
IV. SITE CHARACTERISTICS
Initial investigations (Phase I) of the site were designed to avoid
violation of the existing soil cover and to determine by non-
destructive methods and perimeter monitoring where source areas might
be located and if any contaminant release might be detectable.
Results of these investigations indicated the site consisted of two
characteristically different areas: the eastern half of the site
consisting of a municipal/general refuse type landfill (approximately
15 acres) and the western half of the site (approximately 5 acres)
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characterized by diverse disposal activities involving industrial
wastes as well as residual ash from earlier incinerator operations.
Due to the difference in the composition of the two areas, further
investigation (Phase II) of primarily the western portion of the site
was conducted to delineate discrete source areas. In addition,
further characterization of the site was continued through use of the
previously established monitoring network.
The nature and extent of contamination defined for each of the media
sampled during the RI is summarized in the following discussion. Any
specific characteristics associated with a medium are also summarized
in the following discussion.
A. Surficial Soils
The site can be divided into five distinctly different surficial
material classifications. (Figure 3)
1. Natural Materials. Consisting of flood plain deposits, stream
channel deposits, and generally undisturbed areas around the
perimeter of the site.
2. Municipal Landfill Cover. Consisting of imported clay, silts
and gravels averaging approximately 2 feet in thickness.
3. Mixed Loamy Soil and Rubble. Consisting of a mixture of loamy
soils with some waste and rubble averaging approximately 3 feet
in thickness.
4. Mixed Granular Soil and Rubble and Clay Fill. Consisting of
gravelly soil, rubble, and construction debris densely compacted
to an average of approximately 3 feet thick.
5. Exposed Wire Waste and Mixed Soil. Consisting of wire waste and
soil with no cover materials present.
The ranges of contaminant concentrations found within the surficial
soils is presented in Figure 4. The organic compounds were
intermittently present at the specific on-site sampling locations.
Organic contaminants were detected primarily on the western portion of
the site, reflecting the mixed and random nature of disposal within
this area. The municipal landfill cover on the eastern portion of the
site does not present a source of organic contaminants.
The inorganic compounds detected in the surficial soils were arsenic,
antimony, cadmium, copper, and lead. Cadmium is associated only with
the wire disposal area. Arsenic is most prevalent in the municipal
landfill cover material and was probably in the material applied as a
cover. Background concentrations of lead and antimony were greater
than those found on-site.
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—.1—-
IITI «OUNO«KV
LIOINO
-s' CONTOUNUNIINMirar
- * COVIH HATEHUl TKICXNIU
FIGURE 3
COVER MATERIAL COMPOSITION
AND THICKNESS '
fT.WAVNIIIIOUCTION
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MUNICIPAL LANDFILL COVER
MIXED GRANULAR
SOIL/RUSOLt/CLAV fILL
ixroiEowiRf WASTES •
MIXED SOIL
s..., .;,-^
' .-^ ' ' ' •- •• i_^i •• ^L ' ' _^^^^^*l^^^^^^^ r * ft ^^** t t\ '% fc..^^'^ *Trf. -* '
••"-• ^,^1^-^—.—^.-=snrir^'<'- V'^ •--?•>•*'•> •."-....! '
--. —NOR! OK . AMU '.VI lit nil TTdl'-l
(Ill IOUMOAHV
FIGURE 4
CONCENTRATION RANGES FOR
EACH SURFICIAL ZONE
M WAVNt MOUCTtON M
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B. Subsurface Materials
Five general subsurface areas were delineated at the site (Figure 5).
The waste types in these areas are described as follows:
1. Municipal Landfill Paper, plastic, and other household wastes
mixed with soil.
2. Former Pit Area Drums and industrial liquid wastes.
3. Incinerator Waste Cinders and charred metal pieces.
4. General Industrial Waste Paper, plastic, rubber materials,
liquid wastes and drums.
5. Exposed Wire Waste Loose, loamy soil with small pieces of wire
insulation.Crushed drums at depth.
Ranges of contaminant concentrations for each subsurface area are
included in Figure 6. Two regions of high organic contamination
occur: one centered over the former pit area and one over the central
portion of the general industrial waste region. These regions exhibit
high concentrations of volatiles, acids and base/neutral type
compounds.
C. Groundwater Hydrogeology and Quality
Three unconsolidated aquifers with intervening low permeability layers
have been delineated at the site: a deep, intermediate and upper
aquifer (Figure 7A and 78).
The dt»ep aquifer consists of coarse sand and gravel outwash and is
overlain and possibly underlain by till confining layers. Very little
horizontal groundwater flow occurs within the unit, and it is confined
with little or no hydraulic connection to the Maumee River or
overlying aquifer. Higher piezometric levels were measured in the
lower aquifer as compared to the intermediate aquifer and in the
intermediate as compared to the upper aquifer. This indicates a
strong potential for upward flow from both the lower and intermediate
aquifers to the upper aquifer.
The intermediate aquifer consists of fine to medium grained sandy
outwash and is partially confined by an overlying till unit on a major
portion of the site (from the western boundary through most of the
municipal landfill). On the far eastern portion of the site, the
intermediate aquifer has direct hydraulic connection with the upper
aquifer unit. On this eastern portion of the site, some intermediate
aquifer flow contributes to upper aquifer flow prior to discharging to
the Mc'jnee River. The general flow direction of the intermediate unit
is northeast toward the Maumee River (Figure 8).
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AMIA]
«•»•!•!*•!. liquid *MII«I »«d tf*
* * i «t vOC'l. C*M
M"d ««d f ••*•! 'H
. J •» -
• L_iiL^
7* •• - - . -££--••
ll'l . •« • ' ..-~;.T:-'-:
' V__^ --^^V^-llGix
...M
,:::- ,j -
. X
/
/
/ . ,-L •; ••
'S - •'•': •'.'"'
IUUNO
« TKT >|T LOCATIONI
1 •
till BOUNDARY
FIGURE
TEST PIT LOCATIONS
AND AREAS WITH SIMILAR
WASTE TYPES
»T MAfNI MIOUCTION *l
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AM A I
MUNICIPAL LANDFILL AHIA
mwmcip*) M«*lt wp to 2* ll.
• 4 l|, ol •
A HI A I
INCINl MATOfl NAJTtt
AM A4
QCNf HAL INOU1TMIAL WAlTIS
Com* I** (ntfwittui p*(>«, pUiilc.
if h CDAcvnirtiMW •'
VOC •. Oncm «Ad lAdiMtfM
MquMf M*ntt tliH pr
AfttAft
tMfOIID WIN! WAIT!
Loo»«. lofny H
Of «
Incinerator Co ***•>! with
High ca*C**i|r»lioni Q| VOC't. Cowied wrfl*
**•» i*l.
TV 709100-
JO? OOO • 600 000
TIN 389000-*.«J5.000 oftU*
NnniQLK AND WEST fur
v--^"- IITf BOUNDARY
tCALtlNftlT
TV- T>ulV»l«H«
TIN • Toul (IM '
No»:
m«K»
-------
INTERMEDIATE M'Umo.-i-»i
AQUIFER
•' ///','' • ' / r"*1 »l«;in 111 '
H O
r« (>i
ii
'/•'s//'//////////,
. i- y
CONNECTED
UPPER AND
INTERMEDIATE
AQUIFER
A-
SCntf NtD
VAL
y WATER LEVELS TAKEN
1/13/8)
O CHAIN SIZE ANALYSIS
690
- CROSS SECTION LOCATION •
»OT TO SCALE
Iht dioiri tnd ihlchniu ol mt lubiufUct tl'iu mdtcji»d en ih<
I tenon I (MO Mt I wtff Qocii>oni ind d«tt« mdicattd So>) l>ochl
Condi lion | gnd wr«l*r l«vf If •( o|fff loCJUO'1* nt«v d<('" ''0"t ca
660 ' *"* m
-------
760-,
750-
760
750
INTERMEDIATE
AQUIFER
CROSS SECTION LOCATION
690
LEGEND
'Ilk:
• AllHOAO • OOAO
AIIWIAI OOOim.
SILT* SANO.SAMOV st^r
>u>oo>i»» ottatir*
> IM-MIOUX* S*MO OK
'
CO«AlOAK I
MO«OC«.
" - tlACK. MAUD
WELL SCREENED
INTERVAL
BORING EXTENT
INFERRED GEOLOGIC
CONTACT
y WATER LEVELS TAKEf
1/13/87
13Q GRAIN • SIZE ANALYSl:
SAMPLE
200'
HORIZONTAL SCALE
IN FEET
The depth and thickness of the subsurface strata indicated on the
section (profile) were generalized from and interpolated between
test borings. Information on actual subsurface conditions exists
only at the specific locations and dates indicated. Soil (rock)
conditions and water levels at other locations may differ from con-
ditions occurring at the boring locations. Also, the passage of
time may result in a change in the conditions at these boring
locations.
FIGURE 7B
CROSS SECTIOM B-B'
WITH AQUIFEM
DESIGNATIONS,
FT. WAYNE REDUCTION
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. OAGEMAUTOrARTS |
SITEIOUNOAflV
EASTERN f XTINT Of MIW HOLLAND 'III
IIOINO
• MONITORING WELL INSTALLIO IV CM2M HILL 11/14/M • \lll\l AMD
OWNED IV U.S. «'*
• MONITORING WELL INSTALliO IV (COLOOV AND INVIKONMENT IN
IBS) AND OWNED IV U.S. E'A
A UONITORINO WCLl INSTALLED IV ATEC ASSOCIATES IN IMS AND
OWNED IV WASTE MANAGEMENT INC.
HIM GROUNOWATED ELEVATION
711 POTINTIOMETKIC LEVEL. MET AIOVE USL
,nt— OROUNOWATER ELEVATION, f tET AIOVE MSL
WASHED WHERE EXTnATOLATEOI
_ •- ESTIMATED DIRECTION Of GROUNDWATER MOVEMENT
NOTE: Coniouri <*•«" lr
I I
FIGURE-8
POTENTIOMETHIC SURFACE OF
THE INTERMEDIATE AQUIFER
f OflT WAYNE REOUCTION
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The upper or surficial aquifer consists of alluvial and lacustrine
deposits and is underlain by a till unit from the western boundary
through most of the municipal landfill. Groundwater flow is generally
north and northeast toward the Maumee River and Herber Drain with all
groundwater flow discharging to the Maumee River (Figure 9).
Groundwater seeps were observed during the RI along the river bank in
the western portion of the site. These seeps were exposed or covered
depending on the river stage, and are representative of the
groundwater table.
The total groundwater discharge from the site (through the upper
aquifer) to the river is estimated at 2 to 5 gallons per minute. The
horizontal hydraulic conductivity of the surficial aquifer ranges from
4.5 x 10~5 cm/sec to 6.3 x 10'3 cm/sec.
The contaminant distribution in the aquifer system at the site is
limited to the upper aquifer. Samples taken from the intermediate and
lower aquifers did not indicate the presence of contamination. Total
organic contaminant concentrations for groundwater in the surficial
aquifer and groundwater seeps are given in Figure 10. The major
constituents of the total organic contaminant concentrations are
2,4-dimethyl phenol, chlorobenzene, benzene, methylene chloride, and
xylenes. -
Samples drawn from Well CH-04S contained a product-like material.
This material was similar to that found in test pit samples from the
former pit area, directly upgradient from the well. The similarities
in composition of contaminants between the former pit area and Well
CH-04S indicate a direct release from the former pit area has
occurred.
D. Surface Water Quality
An investigation of Herber Drain was conducted to evaluate the
potential for direct surface water contamination from the site.
Sample locations were selected to provide comparative off-site
(background) samples, and as much areal coverage as practicable.
Locations were identified on visual observations and proximity to fill
areas. The marshy area in the middle of the site was also sampled as
this location would be representative of runoff from the landfill
(Figure 11).
The background sample collected in Herber Drain and the sample from
the marshy area contained insignificant amounts of organic
contaminants. Only trace amounts of volatile and acid compounds were
detected in the samples collected from Herber Drain adjacent to the
site. The inorganic analyses showed no significant increase over
background concentrations for the samples collected in Herber Drain
and the marshy area.
A discussion on Maumee River quality is presented in the section
"Summary of Site Risks".
-------
rn «i
•CMM
1fc.M
'.ic. - . OAGCfl AUTO PARTI
EASTERN EXTENT OF NEW HOLLAND TILL
SITi IOUNDARY
LEGEND
• MONITORING WELL INSTALLED (V CHIM HILL II/74/M • l/7/tl AND
OWNED IT U.S. EPA
• MONITORING WELL INSTALLED IT ECOLOOT AND ENVIRONMENT IN
IIU AND OWNED IV US. EPA
* MONITORING WELL INSTALLED IV ATEC ASSOCIATE! IN IM> AND
OWNED IT WASTE MANAGEMENT INC.
I3J04 OROUNOWATEH ELEVATION
11 POTSNTIOUETRIC LIVEL. PEET AMVI MSL
_JJ»—GROUNDWATEM ELEVATION. PEET AIOVE MSL
(DASHED WHERE EXTRAPOLATED!
ESTIMATED DIRECTION Of CROUNOWATSM MOVEMENT
NOTE: Contour* d»~" "om |>o
i«OOJ«
-------
^vjr-— - ^vSSs
^ Mw^'rtv•". .-•••:: ««.Sh3£
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•Ill IOUNOAHV
LIOINO
CROUNOWATER SEEP
AND SEDIMENT SAMPLE LOCATION
MONITORING WCLL INSTALLED SV CM2M HILL
- in in AND OWNED iv u.s. EPA
MONITORING WELL INSTALLED BY ECOLOGY
AND ENVIRONMENT IN I9U AND OWNED BY U 5 EPA
• MONITORING WELL INSTALLED IYATEC
ASSOCIATES IN 1985 AND OWNED (Y WASTE
MANAGEMENT. INC.
I. UNLAIELLEO • SHALLOW MONITORING WELLS
I JWIil TOTAL ORGANIC COMPOUND CONCENTRATION
IN SHALLOW GROUNOWATER MONITORING
WELLS. PHASE I/PHASE II SAMPLING. UG/L
14
© TOTAL ORGANIC COMPOUND CONCENTRATION
IN GROUNOWATEH SEEPS. IN UG/L
NS-NOT SAMPLED
ifr SUSPECTED LABORATORY CONTAMINATION
FIGURE 10
ORGANIC CONTAMINANT CONCENTRATION
IN GROUNDWATER SEEP LOCATIONS AND
SURFICIAL AQUIFER WELLS
Ft WAYNE FS
-------
tin touNOAxr
*u"r ACI WAT(R/LEACHATI
AND HOIMCNT SAUfLf LOCATION
4 LCACHATt SCEF
SURFACC WATCR RUNOFF
OIRECTION
FIGURE
DRAINAGE PLAN AND
SURFACE WATER/SEDIMENT
SAMPLING LOCATIONS
FT. WAVNf RIOUCTION
-------
E. Sediment Quality
An investigation of sediment quality near the site was included as a
part of the RI. The primary purpose of the investigation was to
collect data to allow a comparison of sediment quality adjacent to and
downstream from the site in relation to sediment quality upstream from
the site. Therefore, sediment samples were collected from zones of
apparent deposition upstream, adjacent to and downstream of the site.
Figure 12 shows the various sediment sampling locations. Maumee River
locations were 12 to 15 feet from the river bank while groundwater
seep locations were part of the river bank. Herber Drain locations
were primarily mid-channel.
The sampling results indicated the presence of contaminants in the
sediments (Tables 1, 2 and 3). The contaminants found at elevated
levels (above background) in Herber Drain are not related to the site.
The contaminants detected in Herber Drain were not detected in the
surface soils or groundwater in the eastern portion of the site, the
most probable on-site source area for Herber Drain. The contaminants
present in Herber Drain are probably due to the backwash of Maumee
River sediment during high river stages.
As previously stated, the site is located in an area of numerous point
(i.e., wastewater treatment plant) and nonpoint sources (i.e.,
abandoned landfills). These additional sources made it very difficult
to establish a clear relationship between the site and the contaminant
levels in the Maumee River sediments, especially when the contaminant
levels in the Maumee River and groundwater seep sediments adjacent to
the site were not substantially different than the contaminant levels
in the Maumee River sediments upstream from the site (Table 4).
A detailed discussion of Maumee River and groundwater seep sediments
and the issues associated with addressing contamination in the Maumee
River and groundwater seep sediments near the site was presented in
Appendix G of the FS. The specific issues discussed in Appendix G
are:
o Background conditions
o Cause and effect
o Action levels
o Benefits achieved by site remediation
Based on the information presented in Appendix G of the FS, addressing
the Maumee River and groundwater seep sediments adjacent to the site
was not established as a remedial action goal for the site.
V. SUMMARY OF SITE RISKS
A baseline risk assessment was performed for the Fort Wayne Reduction
site as part of the RI Appendix B of the RI report). The risk
assessment identified and evaluated potential human health and
-------
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f f n*YH( RlQUCTlON
-------
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2-lulinoni
Chlorolori
loluene
1,4-liiettiyt phenol
4-delhfl phenol
Ptenol
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Copper
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-------
environmental threats from the site under the no action alternative.
The no action alternative assumes that no remedial actions (including
institutional controls) will occur.
The baseline risk assessment included the following:
o Identification of potential chemicals of concern
o Toxicity Assessment
o Exposure Assessment
o Risk Characterization
A. Potential Chemicals of Concern
Ninety-one chemicals were detected in samples collected during the RI.
The distribution of the chemicals at the Fort Wayne Reduction site are
summarized by media in Table 5. It was not feasible to include all of
these chemicals in the risk assessment. Therefore, potential
chemicals of concern were selected to represent the hazards the site
may pose to human health and the environment.
Chemicals of concern were selected 'in the following manner. First,
all chemicals with critical toxicity values were selected if they were
detected in a media to which exposure could occur. Second, additional
chemicals wen; selected if they were representative of the site
(across media) or represented a significant contaminant source. Table
6 lists the forty-three chemicals selected as potential chemicals of
concern for the F.ort Wayne Reduction site.
B. Toxicity Assessment
The toxicity assessment for the Fort Wayne Reduction site summarized
the toxicolog'cal characteristics of the selected potential chemicals
of concern, the critical toxicity values (i.e., cancer potency factor
or reference dose), and the risk estimation methodology.
C. Exposure Assessment
In the exposure assessment, the potential exposure pathways by which
humans and wildlife could come into contact with contaminants from the
site were evaluated. Exposure pathways were considered for both
current and future land use conditions.
A complete exposure pathway has five elements:
o a contaminant source
o a mechanism for contaminant release
o an environmental transport medium
o an exposure point
o a route of exposure.
-------
•JO- Due -87
Table 5
CHEMICALS DETECTED. BV MEDIA
FORT WAYNE REDUCTION
Page 1 of 3
Chemical
VOLATILE ORGANIC C'OttPOUNDS
Acetone
Den i en e
2- Bu tanone
Carbon disulfide
Ch 1 orobeniene
Ch loroe thane
Ch 1 or o form
1 , 1 -Di c h 1 oroe thane
1 , 1 -Dichloroe thene
trans-1 . 2-Di ch 1 oroe thene
E t hy 1 benzene
2-Hexanone
Methylene chloride
4 -fie thy 1 -2- pen tanone
Styrene
To trac hi oroe thene
Toluene
1 , 1 , 1 -Tr ichl oroe thane
Tr ichloroethene
Vinyl chloride
Xy 1 ones
ACID EXTRACTABLES
Oenzoic acid
2, 4 -Dimethyl phenol
2 -Me thy 1 phenol
4 -Me thy 1 phenol
2-Ni trophenol
4-Ni trophenol
Pen tachlorophenal
Phenol
Onsitv Leachate
Surface Leachate Seeps
Soil Seeps Sediment
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Ana 1 yzed
Analyzed
Analyzed
Analyzed
Analyzed
Analyzed
Ana 1 yzed
Analyzed
Analysed
X
M
N
K
M
M
M N
H
M
M
H
M X
M
M
X
X M
X
M X
X
" «
X K
X M
X M
X X
Qnsite Onsite
Test Monitoring Mater Surface
Pits Wells Product 'Sediment Mater
•
M X
XX X
X
X
X X
•
M
X X
M . X
X X
X
M , X X X
X
X
X X
XX X
X X
M '' XX
XX X
K
M M M
X K X
X X
X X
M
M X
X X
-------
3O-Dec-B7
TablB 3 .
CHEMICALS DETECTED, BV MEDIA
FORT WAYNE REDUCTION
Page 2 of 3 .
Surface
Soil
Chemica I
BASE/NEUTRAL EXTRACTABLES
Polycycllc Aromatic Hydrocarbons
Ac enaphthene
AcenaphthyIene
Anthracene
Benzol a)anthracene N
Denjo(a ) pyrcne M
Benzolb)fluoranthene M
Benzolk ) fluoranthcne M
Benzolq,h,i)perylene M
Chrysene K
Dibenzola.h) anthracene
Fluoranthene M
Fluorene
Indenol1,2,3-cdIpyrene x
2-tlethy 1 naphtha lene
Naphthalene M
Phenanthrene »
Pyrene »
Phthalates
Butyl benzyl phthalate H
Qis ( 2-etliy 1 heiiy: ) phthctaie M
Di-n-butyl phthalate H
Dtethyl phthalate
Dimethyl phthalate M
Di-n-octyl phthalate H
Other Base/Neutral* . •
Benzyl alcohol
1,2-Dichlorobenzenw M
1,3-Dichlorobeniene
1,4-Dichlorobenzeno
Di benzofuran
Isophorone
n-NitrosomethyIamine
n-Nitrosodiphenylamine
1,2,4-TiJchlorobenzene
Lvachate
Seeps
Leachate
Seeps
Sediment
Test
Pits
Moni tor ing
Mel Is
Product
Qnsite
Mater
Sediment
Onsite
Sur face
Mater
M
N
M
K
M
M
M
M
H
K
K
K
K
M
K
M
I 1
-------
30-Dec-B7
Table 5
CHEMICALS DETECTED, BY MEDIA
FORT WAYNE REDUCTION
Page 3 of 3
1
Chemical
PESTICIDCS/PCBs
Al Ur in .
PCD
a 1 pha-OMC
del ta-DHC
qamma-OHC (lindane)
Heptachlor
INORGANICS
A 1 umin ium
Ant imony
Arson ic
Barium
Bery II ium •
Cadmium
Chromium
Cobal t
Copper
Cyanide
1 ron
Lead
Manganese
Mercury
Nickel
Si? lenium
Si 1 ver
Tin
Vanadium
I inc
Onsite
Surface
Soil
x
x
X
X
M
K
X
i
K
K
X
X
X
K
X
X
X
Leachate
Seeps
x
x
x
x
x
x
x
x
K
X
X
X
X
X
Leachate
Seeps
Sediment
x
K
X
X
X
x
x
x
X
K
X
X
X
Test
Pits
K
X
X
X
K
X
K
X
X
K
X
X
X
X
X
X
X
X
X
X
X
X
X
^J
Ons ite
Monitoring Mater
Wells Product Sediment
x
x
x
K
K
X
X
X
X
X
X
X
X
X
X
X
K
X
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Not
Analyzed x
Analyzed
Analyzed
Analyzed x
Analyzed
Analyzed x
Analyzed
Analyzed x
Analyzed x
Analyzed
Analyzed
Analyzed x
Analyzed x
Analyzed
Analyzed x .
Analyzed
Analyzed
Analyzed
Analyzed x
Analyzed
Ons ite
Surface
Water
M
X
K
X
X
K
K
X
K
NOTE: Calcium, magnesium, potassium, and sodium were detected In all media and are not
presented here.
-------
30-Di-c -
Table 6
POTENTIAL CHEMICALS OF CONCERN
FORT WAYNE REDUCTION
Acetone
An t i mony
Ar sen i c
Barium
Benxcne
DeryI Iium
Uis(2-ethylhei«yl>phthalate
Cadmium '
ChI orobenzene
Coloro form
Chromium
Copper •
Cyan ide
Dibutyl phthalate
1,l-Oichloroethane
1.I-Olchloroethene
2,4-DJinethyl phenol
Methyleno chloride
Ethylbeniene
Lead
Manganese
Mercury
2-Methylphenol
4-Methylphenol
4-Methyl-2-pentanone
Nickel
PAH' B
PCBs
Phenol
Si 1 ver
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
Trichloroethene
Vanadium
Vinyl chloride
Xylenes
Zinc
PAH's include benio
-------
10
Figure 13 shows each of the potential exposure pathways in relation to
the five exposure pathway elements and the potentially exposed
populations. Some of these potential exposure pathways can be
considered minor in terms of either the potential for release of
contaminants or the likelihood for exposure to occur. For example,
the potential airborne release of contaminants from the site surface
is low. The cover on the site limits release, and the mechanism for
release is limited to wind blown erosion. Consequently, exposures
associated with this pathway are minor. Similarly, the groundwater is
not considered a potential water supply source. Limited groundwater
yield excludes this aquifer's use as a water supply source on-site.
A municipal water supply is available or could be readily obtained
from the City of Fort Wayne (the City of Fort Wayne obtains their
water supply from the St. Joseph River). The individual private wells
in the area are upgradient from the site and the Maumee River is not
used as a water supply in the site's area. Therefore, groundwater
discharging to the Maumee River can not be associated with a drinking
water exposure pathway.
The major exposure pathways identified for the Fort Wayne Reduction
Site are shown in Figure 14. These exposure pathways can be divided
into two major categories:
o Exposures associated with the migration of contaminants
to the Maumee River
o Exposure associated with use of the site •
Contaminants can migrate to the Maumee River through the following
mechanisms: the leaching of contaminants from the buried wastes into
shallow groundwater and the subsequent discharge of the groundwater to
the Maumee River; surface water run off during precipitation events
can carry contaminants exposed at the site surface to the river; and
flood events may wash out contaminants from the site and carry them to
the river. A continual release of contaminants through groundwater
discharge to the river would present the most significant source of
risk.
The release of contaminants to the Maumee River can result in the
direct exposure of aquatic organism to the contaminants. The
contaminants may also partition to the sediments where benthic (bottom
dwelling) organisms and bottom feeding fish can come into contact with
the contaminants. People or wildlife who consume aquatic organism may
be exposed to the contaminants (i.e., food chain effects). Exposure
may also occur to people who come into contact with river water
through recreational activities such as swimming.
People can also be exposed to contaminants through activities that
bring them into direct contact with the contaminants on-site. These
activities include: trespassing .on the site; construction activities
undertaken as part of future site development; and exposure of future
-------
W6J«I PM\nC5-J B/JJ/07
CONTAMINANT
SOURCE
CONTAMINATED
SOILS/
EXPOSED
WASTES
BURIED
WASTE
CONTAMINANT CONTAMINANT
RELEASE TRANSPORT
Direct Contact Onsite with Soil
Receptor Activities Replace.
Release and Transport
Volatilization
Air
Wind or Mechanical
Erosion
Solubilized
Runoff in Woler
Suspended
in Water
Leaching __ Groundwater
•"
EXPOSURE
POINT
Onsite
Offsite
Onsite
Maumee*
River
Onsite
Leachate Pools
EXPOSURE
ROUTE
Ingestion
Dermal
Absorption
Ingestion
Inhalation
Inhalation
Ingestion
Bioconcentration
Ingestion
Dermal
Absorption
Inhalation
Ingestion
Dermal
Absorption
Ingestion
PRIMARY SECONDARY
EXPOSED EXPOSED
POPULATION POPULATION
Trespassers ^
Future Site Users
Terrestrial ^ People Who
Wildlife Consume Wildlife
Residents
Workers
Trespassers
Users
Aquatics People Who
Organisms Consume Fish
Swimming
Trespassers
Terrestrial Hunters
• Includes water and river sediments
Wildlife
FIGURE 13
POTENTIAL EXPOSURE PATHWAYS
-------
w6i«ai pn\ncs-j i/v«o
CONTAMINANT
SOURCE
CONTAMINATED
SOILS/
EXPOSED
WASTES
BURIED
WASTE
~
CONTAMINANT CONTAMINANT
RELEASE TRANSPORT
Direct Conloct Onsite with Soil
Receptor Activities Replace.
Releo.se ond Troosport
Solubilized
in Water
Runoff
Suspended
in Water
Leaching ^ Croundwater
PfBMARY SECONDARY
EXPOSURE EXPOSURE EXPOSED EXPOSED
POINT ROUTE POPULATION POPULATION
Ingeslion __ Trespassers
Onsite Fulure Sile Users
Ingeslion ^ Terrestrial
Wildlife
-
' Maumee* Ingeslion __ Aquatics __ People Who ^
River ' Bioconcentrotion Organisms Consume Fish
Ingestion __ Trespassers
Onsile
LeOChate Pools Inontion Torrpslrinl
Wildlife
(I
• Includes water and river sediments
FIGURE 14
POTENTIAL EXPOSURE PAT
OF GREATEST CONCERN
FORT WAYNE REDUCTION, SITE
AYS
-------
11
site occupants to contaminants left exposed from site development.
Residential or commercial use of the site is considered possible,
however, residential development is less likely given the current
commercial and industrial land usage of the surrounding property.
Once the exposure pathways are identified, the next step in the
exposure assessment is exposure estimation. An estimation of exposure
to contaminants requires two items: contaminant concentrations in the
media at the point of exposure (exposure point concentration) and an
estimate of the intake of the media (media intake rates).
Exposure point concentrations can be estimated by direct measurement
at a point of contact or by modeling contaminant release and transport
to the exposure point. The exposure assessment for the Fort Wayne
Reduction site used both of these approaches.
For exposures occurring to contaminated media on-site (i.e., surface
soils, subsurface materials and groundwater seeps and the associated
sediments), the highest contaminant concentrations detected (in the
appropriate media) were used to represent the high exposure point
concentrations. Median exposure point concentrations were estimated
wherever possible. In several instances, however, the low,frequency
of detection of a chemical did not allow estimation of a median
exposure point concentration.
A somewhat different approach was taken for exposures at the Maumee
River. First, contaminant loadings from the site were calculated from
the detected groundwater and groundwater seep contaminant concen-
trations on-site. Maumee River contaminant concentrations were then
projected from the site's contaminant loadings. This approach allowed
the relationship between groundwater discharge from the site and the
effect of that discharge on the river to be evaluated. This type of
approach is consistent with State of Indiana regulations regarding
Water Quality Standards and is typically used under the National
Pollutant Discharge Elimination System (NPDES) to establish discharge
limits. The long-term effect of a discharge on a river's water
quality is based on minimum dilution which is represented by the
lowest seven consecutive day flow occurring statistically once every
10 years (Oj-io) in a specific reach of the river. Using minimum
dilution ensures maximum protection is provided for the aquatic
community. In addition, the use of a river's 50th percentile or
median flow (Q50%) has been established for evaluating the effect of a
discharge on a river's water quality in relation to human consumption
of fish. Therefore, Maumee River contaminant concentrations near the
site were projected under the following two settings: a mixing zone
of 50% of the Q7_10 flow and a mixing zone of 25% of the 0-50% flow.
Tables 7A and 7B present the projected Maumee River contaminant
concentrations near the site due to the site's groundwater discharge.
Upstream contaminant contributions were taken into account when
assessing the risk associated with the exposure pathways.
-------
Illisf I
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I.IE-OI :.ii 01 j.9( o; LIE o; y:i-^ i.:i-04 4.U-04 I.»E 04 i.ei-os I.JE 04 ).9E-ot i.u-ot 1.51-04 J.IE-OI ;.BE-O; I.BE-OJ J.OE-OB I.U-OB ».51-04 i.:i-04
I.?! 04 :.)!'') I.IE-O? J.IE-OB I.2E-0? 2.BE-OB 2.VE-07 4.4E-08 I.9E-07 t.01-08 2.9E-08 4.5E-0? 1.51 01 J.5E 0)
4.1(05 I.if o) I.It OJ J.K "4 4.11-01 I.SE-OI I.JE-OI J.51 05 2.IE-OI 5.5E-05 I.8E-OI I.IE-O) 4.IE-0) I.OE-05 I.IE-OS 9.5E-04 2.8E-04 4.5E-0/ i.BE-OI I.4E 01
l.a ('B ME-0? I.IE-O) ).)E-08 :.IE-OB 5.11-0?
8.61 0? 2.MO)
I.M (>) l.n(-H I.OE-01 ME-OI J.4E-01 l.:t-04 4.TE-OI I.IE-OI 1.31-01 2JE-OI I.4E-03 l.BE-OI I.IE-OI I.BE-OI 7.0E-OJ I.4E-05 l,n-01 I.IE-04 I.2E-02 2.7E-OI
8.41M l.?E-»; I.IE-07 1.IE-OB i.1E-08 I.4E-OB I.4E-OJ I.JE-08 3.0E-07 I.BE-OB 7.0E-07 I.IE-OB I.1E-08 t.BE-Of I.5E-OJ ME-07
).<>( ''4 4.«E-»; B.U-07 I.9E-07 7.JE-04 J.7E-07 1.3E-07 7.4E-OB 7.IE-07 1.4E-07 I.SE-04 1.5E 07 I.IE-04 7.IE-07 3.5E-07 I.IE-OB B.4E-OB 2.0E-OB 9.3E-04 2.IE 04
-------
12
Tables 8 and 9 present the exposure point concentrations and media
intake rates used in the risk assessment respectively.
D. Risk Characterization
This portion of the risk assessment evaluated the various exposure
pathways and identified, by media, the potential risks to human health
and the environment associated with the site's contaminants.
The eastern (municipal landfill) portion of the site was determined
not to pose a risk to human health or the environment. Contaminant
levels in the surface soils of this area were below levels indicating
a direct contact threat. The site history and the site's waste
disposal practices indicate that the vast majority of waste disposed
in this portion of the site was municipal refuse, though minimal
amounts of hazardous materials may have, been disposed of within the
landfill. This information, plus the groundwater monitoring data,
indicate that no current threat to the Maumee River exists from the
groundwater discharging to the river.
Under current site conditions, direct contact by trespassers to
exposed contaminants in the surficial soils on the western portion of
the site, especially the wire disposal area, is a concern. _The
primary contaminant of concern is lead. Inadvertent ingestfon of
groundwater seeps along the banks of the river is also a concern
because of the heavy metals, phenolic compounds, and xylene present in
the seeps.
If the site is developed, exposure to the wastes currently buried in
the western portion of the site could occur. Contaminants are present
in the subsurface at concentrations associated with potential health
effects, especially near the former pit and general industrial waste
areas. Chemicals of concern include phthalates, heavy metals,
phenolic compounds, polychlorinated biphenyls (PCBs), polycyclic
aromatic hydrocarbons (PAHs), and volatile organic compounds (VOCs).
The potential for aquatic effects as a result of the contaminated
groundwater discharging to the Maumee River exists. Projected
contaminant levels in the river (after the mixing of groundwater with
river water) do not exceed the chronic State water quality standards
for the protection of aquatic organisms. The concentrations of
contaminants in the groundwater and groundwater seeps do however,
exceed acute State water quality standards for the protection of
aquatic organisms at the point of discharge into the river for several
metals, phenolic compounds, and VOCs. The release of contaminated
groundwater to the river appears to be continuous and the test pit
evaluation indicates waste materials, especially from the former pit
and general industrial waste areas, are potential source areas for
future releases.
-------
Ol-Jjn-
tan 8 •
co«ci«n«iio»s or coutmiitits usu n CSIIMII IIPOSIWC
(Oil Hill KOUCIIOI
Ixiditf, «|'l Omlll Suelici Soil, ig'l| Oolili SrdiieM. 04/14 Projtiltd li.tr Concinlrilio*,
.4/1
Htniui Hifii* ftniKi Urdu* Iliiliui Rrii<» 101 ol III ol
Com till e«ml - Obnord Obier.ed O»UMI< Obitrxl1 Ottirud Obtrrxd Floi flo»
•dloni i
Pntlionr
dufnic
liriu.
Irniriti
lutJ elMIilir Im4 on « tjii«| io»« ol 101 ol Ut 'Bf.lO' llo«
-------
I.HI 9
SUMUI or (irosuic »ssuwno« usu FOR rom MINI utuciiON
Urdu
Cdluilion of
Uicr,,,.
Soil/tro'itm!
Soil/irdnrnt
Surlier mler
(lllulticn ol
Iticrnir
Soil/trdnrnl
Surlier ulef
Su'lur >iirr
'(ipoturr
. Boule SMI i*|
•onciriniogmic (Ifrdi k| Coipifiion li Itlifinit tout
Ingrtlion Iritpilt
IngMtion Irnpiit
Ingrtlion liltpm
Ingiilion $>i»ii>t
Cicrti liltliM Cincrr liil
Ingittion Impitt
Ingitlion Irttpitt
Inqrilion Irtipiti
ln;itlion S>iiiin|
loqfklion $iiiiin|
lillf
Urdu IMiU
JO •!/ir liltliMi >0-k| 0.000000021 l/k| kolf
0,«r lilituri )0-k| 0.00001 |/k« koir
O.ir lilrliotl /0-k| 0.000000001 f/k| kod(
.!/0-k| 0.0000011) l/k| kndf
0»ir Illiliin )0-k| 0.00000012 l/k| kot 10-11
CkiUkood
70 irir ptriod «ilhi«
lililiM
On
-------
13
The projected river contaminant concentrations after mixing are lower
than levels associated with adverse health effects from swimming or
fish consumption.
Table 10 summarizes the risk characterization for the site.
VI. ALTERNATIVES DEVELOPMENT
A. Remedial Action Goals
The National Contingency Plan (NCR) (40 CFR Part 300) and CERCLA, as
amended by SARA establish the remedial action objectives for the site.
In- evaluating the findings of the RI and the Risk Assessment, the
following media on the western portion of the site were identified as
presenting either an existing or a potential future unacceptable
public health or environmental risk at the site:
o Surface soils
o Subsurface soils/wastes
o Groundwater/groundwater seeps
Therefore, the following were identified as the specific remedial
action goals for the site: "i
o Surface Soil—To provide adequate protection of public
health and the environment by limiting direct contact with,
and erosion of, on-site surface soils in the western portion
of the site.
o Subsurface soils/wastes--To provide adequate protection of
public health and the environment by limited direct contact
with, and future releases to the Maumee River from the sub-
surface soils and wastes in the western portion of the site.
o Groundwater/Groundwater Seeps—To provide adequate pro-
tection of public health and the environment by limiting
discharge of, and direct contact with, groundwater/ground-
water seeps in the western portion of the site.
o Municipal landfill—Since no unacceptable public health or
environmental risk has been associated with this area, the
remedial action goals are to ensure future migration of
groundwater will not present a threat to the river and
adequate cover is present to prevent erosion resulting in a
direct contact threat or washout of the wastes to the river.
Consistent with the remedial action goals, three operable units were
developed for the site: the soil on the western portion of the site,
the municipal landfill and groundwater.
-------
id
SUMMIT OF USX. ASSESSMENT- -FOR! WAYNE UOUCTION SITE
Exposure Pathway
Direct Contacti Ingeetlon
fxpoaure folnt
Surfact lot I onsll*
Expoaed Population
Ircspaeeere
Direct Contacti Ingcstlon
Direct Contacti Ingestlon
Burled waat* tot «ub-
aurface eoll
Crounduater icep
related ledlaient
Conttructlon worker*
FVicura alt* occupant*
. Trespassers
Direct Contacti Ingestlon
Croundvater acepa
Ircipaiiera
Croundwater Hl|rattoni
Dlichar|< to Hau»e« River
Mauswa River
Aquatic Organl***
Croundwaler Nlfrattoni
Discharge to Hausiee River
Haucec River
rtople who conauM (Iah
caught In Hauaic* River
People who ewle> In
Naiwee River
Rl»k Oiaractcrliatlon Sunoarv
Reference doae eJiceeded by hl|hcic detected
concentration of lead.
No reference dote* exceeded by Kdlan
concentration*.
Exceae llfetliw cancer rlaki 4 > 10*' to
9 « 10 bated on the highest concentretlona
of PAHa and PCI.
Exceee llfetlaw cancer rlaki 1 x 10* to
3 x 10 baaed on eiedlan concentratlone of
PAH. and ret.
Concent rat loni of the following chculcal*
exceeded their rlak-baeed target levelai
cadailuat, copper, chroalua, lead
bla (I-ethylhexyl)phthalate, ethylbeniene,
2-Mthyl phenol, nethylene chloride, PAHa,
KB, tetrachloroethene, and trlchloroethene.
Reference doiee are not exceeded by any
concentration*.
Exceae llfetlew cancer rlak: S x lo"' to
2 x 10 baaed on the htgheft detected
concentration* of PAIIa and PCI.
Exceat.llfetlM cancer rlaks
S x 10 baled on nedlan co
PAH* and PCI.
10"7 to
concentration* of
Reference do** exceeded by highest detected
concentration of cadailua, 2-Mthyl phenol,
t-ejcthyl phenol, phenol, and xylcne.
Acutt aquatic criteria exceeded by groundwater,
.Including aeept, prior to dlicharge to the
river for the following chenlcalti b*rlu»,
cadaluaj, copper, 2,4-d|oethyl phenol, ethyl-
teniene, 2-rcthyl phenol, 4-nethyl phenol,
•ethylen* chloride, toluene, and xylene.
Projected contaminant level* In Mauew* River
(baaed on ealitlng groundwater data) below
level* of^fl^rn for flahlng and awlnalng.
Coirment
Surface contamination la rotrlcted
primarily to the weitein portion of the
•It*. Lipotuce under cuirent lend use
would be restricted to trespasser* (for
example, children playing onalte). The
alte la aurrounded aialnly by coraerclal/
Industrial operations. Because of this,
It I* anticipated that the nuvber ol
potentially exposed Individuate would be
(•all and their exposure frequency low.
Thll anilytla assures that alt* develop-
ment will occur without any rcrcdlatlon.
For exposure to occur, excavation It
required. Clve current land use and
toning, conxrclal developaent Is nore
likely then residential use, at least In
the near ter*.
Access to *oat of the seep areas are
llilted to tltie* when the river itage I*
low. Exposure under current lend use
would be restricted to trespaatert (for
exaaiole, children playing along the river
bank). The alte I* aurrounded mainly by
ccmnerclel/lnduitrlal operatlona. Because
of this, It I* anticipated that the nuabcr
of potentially exposed Individuals would
be snail and their exposure frequency low.
If character of the releases change, then
exposure levela could also change.
Access to most of the seep areas are
Halted to tines when the river stage I*
low. Exposure under current land use
would nost likely occur to children play-
Ing along the river bank who siay attempt
to drink the teepa aiaterlal. However,
taste and odor of seeps would licit the
palatlblllty of the seeps. The site I*
surrounded eulnly by commercial/Industrial
operatlona. Because of this, It I*
anticipated that the number ol potentially
exposed Individual* would be snail and
their exposure frequency low. If character
of the releases change, then exposure
level* could also change.
No lapacta projected for the river after
• ailxliig tone. While concentration*
exceed acute criteria prior to discharge,
dilution will occur upon discharge.
Contanlnanl levela at release »jy have
localised aquatic Inpactt. Potential
exltti for futurt release* to river fro*
burled waste*. If character of the
releases change, then exposure level*
could alao change.
Aaseitment doe* not address acdlxent
l»pacia.
Potential exist* for future releases lo
river iro« burled waatea. If character
ol the release* change, then exposure
level* could alto change.
CTT7H7/7"
-------
14
B. Technology Screening
Appropriate remedial technologies and process options were screened in
the FS. The goal of the screening was to simplify the selection of
technologies and process options assembled into alternatives without
limiting flexibility during remedial design. The screening criteria
included: effectiveness; implementability; and relative capital and
operation and maintenance costs. During the screening process,
primary focus was on the effectiveness and implementability of the
remedial technologies and process options, with less focus on the
relative capital and operation and maintenance costs.
C. Alternative Development
Using the established remedial action goals, those remedial
technologies and process options remaining from the screening process
were assembled, into remedial alternatives. In general, a range of
remedial alternatives were developed. This range included to the
extent feasible:
o A no action alternative
o A containment alternative involving little or no treatment
of contaminants
o Treatment alternatives ranging from one that eliminates the
need for long-term management, to one that significantly and
permanently reduces the toxicity, mobility or volume of
contaminants.
Based on this general array, remedial alternatives for the Fort Wayne
Reduction site were assembled to progress from addressing groundwater
contamination alone to more complex combinations addressing surface
and subsurface soils in addition to groundwater contamination.
VII. SITE SPECIFIC REQUIREMENTS
An explanation of a few site specific requirements is needed initially
to provide a more complete understanding of site conditions and/or
simplify the alternative descriptions. A detailed description of the
following site specific requirements will be provided prior to
presenting the alternative descriptions:
o Flood protection and wetlands
o Access restrictions
o Determination of risk-based areas for excavation
-------
15
A. Flood Protection and Wetlands
As indicated previously, a portion of the site lies within the 100-
year floodplain and two wetlands are located adjacent to the municipal
landfill. Therefore, providing adequate flood protection and pro-
tecting wetlands is an essential component of the remedial activities
at the site.
The remedial alternatives for the site need to address proper flood-
plain management and the protection of wetlands. The following
guidelines were considered in developing the remedial alternatives:
o Work in the flood plain should not obstruct or adversely
affect the efficiency of the floodway.
o Scheduled work in the floodplain should be planned for
times when flooding is least expected.
o Work in and adverse impacts to the wetlands should be
avoided where possible.
1. Flood Protection
The primary objective of flood protection at the site is
protecting the landfill embankment from river scour during flood
events. Several measures were considered for minimizing flood
damage. These measures were:
o Construction of an earth berm to prevent flood waters from
inundating areas where waste is buried.
o Placement of rip-rap from the river channel to the 100-year
flood level.
Both these measures were rejected because they would either cause
severe encroachment on the floodway or destroy approximately 1-acre of
wetlands.
The proposed flood protection measure is to grade the existing site
embankment to a maximum one vertical to three horizontal slope,
establish vegetation, and install erosion mats from the top of the
embankment to beyond the toe. Construction would be followed by
biannual inspections and periodic maintenance to ensure the integrity
of the embankment. The recommended method of flood protection has
been discussed with the Indiana Department of Natural Resources (IDNR)
and the Army Corps of Engineers (ACOE). Both of these agencies have a
major interest in flood control on the Maumee River and design
criteria for construction in the 100-year floodplain.
-------
16
The proposed flood protection measure is implementable at the site.
Minimal alteration of the floodway near the site, with no alteration
of the ordinary floodway, will occur.
A secondary objective of flood protection at the site is preventing
short-term effects such as: the release of contaminants to the Maumee
River and a decrease in the progress of work during the construction
phase. The site is not impacted by the river for flows at or below
the ordinary high river elevation. The flat shelf of land north of
the site embankment is subject to flooding, especially during the
months from November through June. Therefore, construction activities
in this low-lying area will be scheduled around these flood-prone
months.
2. Protection of Wetlands
Protection of the wetlands abutting the embankment of the
municipal landfill will be accomplished by preventing runoff and
sediment from entering these areas by using erosion control
techniques during construction. Such techniques may include
temporary drainage ditches, check dams, and plastic covers over
exposed cuts. The wetlands will not be used for staging of
equipment or materials.
Some destruction of the wetlands between the river and the
municipal landfill may occur. If construction at the site causes
a loss of wetlands, the loss will be mitigated by placing a weir
along Herber Drain subsequently increasing the area of the on-
site wetlands directly east of the municipal landfill.
B. Access Restrictions
Each remedial alternative for the site includes access restrictions:
a site fence, warning signs, and deed restrictions on land usage.
A 6-foot high fence would be installed on or near the property lines
to keep intruders off the site and protect the integrity of the cap or
cover. The fence is not installed along the river due to maintenance
problems associated with flood damage. Warning signs are however
placed along the toe of the site embankment near the river to alert
potential intruders to stay off the site.
Deed restrictions would be implemented to control future property use
and prohibit the use of groundwater or the installation of wells on-
site for a water supply source.
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17
Determination of Risk-Based Areas for Excavation
Two of the technologies assembled into alternatives were excavation
and incineration. Prior to evaluating or developing an alternative
containing either of these technologies, it was necessary to determine
which areas of the site required excavation. These areas were
determined based on the hazards identified in the risk assessment.
The risk assessment identified two major exposure concerns:
o Environmental concerns: releases of contaminants to the
Maumee River, primarily through groundwater.
o Human health concerns: direct contact with waste and
contaminated soil as a result of future development at
the site.
The excavation areas were determined by first considering the separate
exposure concerns (i.e., environmental release vs. human contact) at
the site. These are those areas associated with:
o The release to the groundwater.
i-
o The protection of public health.
o The buried drums.
Each of these areas is delineated separately on Figure 15.
The areas associated with the release to the groundwater were
identified by reviewing the test pit data for potential source areas.
Special consideration was given to the location of contaminants
already detected in groundwater and those contaminants that are mobile
in, a groundwater system.
The areas associated with the protection of human health were
identified by considering two future potential development scenarios:
residential development and commercial/light industrial development.
A summary of the target levels used to identify the areas posing a
risk for both the residential and commercial exposure scenarios is
given in Table 11.
Areas associated with the buried drums were identified by reviewing
the magnetometer survey data, the test pit information and historical
aerial photographs.
With the areas associated with the separate exposure concerns defined,
the maximum area requiring excavation could be determined. The maximum
area requiring excavation was determined by overlaying the areas
associated with the separate exposure concerns. In addition, the
maximum area requiring excavation was further subdivided. This
subdivision was accomplished by "ranking" the risk associated with
-------
VOO'I U.OOO 255.000 mg/li,
fh.nolle. J30 JB.OOO mj/k.
V. „:_-.— }
\ . .—»» i i
;_.-xr -Q f h 6
UOINO
FOIINTIA4. SOUHCC Of CONIAMINANI
RIIIASC TOCHOUNOnAICH
___ AnEASNHCRCCONCENflATlONS
/-" ^' IKCCCOHCSlOINIIAl USE
" TARGET CONCCNIRATION}
....... t ARIAS WHf RE CONCENTRATIONS
.' • OCEEO COMMERCIAL USC
..... TAHCEI CONCENTRATIONS
>->;X REGION WHiRi DRUMS ARE SUSPECTED TO BURICO
• TEST FIT LOCATIONS
NOTE: Cont*nifiliomp«ffi«nit(lltOitl«ni lha
f ing* ol Mltctld Ch4mn«. Hyltn* »
FIGURE 15
POTENTIAL SOURCE OF
CHEMICALS RELEASING
TO GROUNOWATER
f T. WAVNI REDUCTION H
-------
Table 11
SOIL TARGET CONCENTRATIONS
BASED ON SOIL INGESTION
Chemical
Acetone
Aldrin*
Antimony
Barium
Benzene*
Beryllium
Bis(2-ethylhexyl)phthalate*
2-Butanone
Cadmium
Chlorobenzene
Chloroform*
Chromium III
Chromium VI
Copper
Dibutyl phthalate
1,1-Dichlorothane
1,1-Dichloroethene*
2,4-Dichlorophenol
Diethyl phthalate
Ethylbenzene
Isophorone
Lead
Lindane*
Methylene chloride*
Methyl phenol
4-Methyl-2-Pentanone
Nickel
PAHs**
PCBs
Pentachlorophenol
Phenol
Stryene
Tetrachloroethene *
Toluene
1,1,1-Trichloroethane
Trichloroethene*
Xylene
Vinyl chloride*
Zinc
Residential
Target
mg/kga
15,000
0.041
60
7,500
13
750
1,000
7,500
44
4,000
8.6
150,000
750
5,600
15,000
18,000
1.2
450
2,000,000
15,000
22,000
210
0.526
93
7,500
7,500
3,000
5
10
4,500
6,000
30,000
140
45,000
14,000
64
1,500
0.3
32,000
Commercial
Target
mg/kg
70,000
0.807
280
35,000
260
3,500
20,000
35,000
200
19,000
170
700,000
3,500
26,000
70,000
84,000
. 23
2,100
91,000,000
70,000
100,000
980
10
1,800
35,000
35,000
14,000
5
10
21,000
28,000
140,000
7,000
210,000
63,000
1,200
7,000
60
150,000
Note: Target concentrations based on the following:
Noncarcinogenic effects derived from RfD values
* Carcinogenic risk at the 10-6 level derived from cancer
potency factors
** Based on background PAH levels
***Based on EPA PEC spill cleanup guidelines
Residential setting assumes exposure through soil ingestion
at 0.1 gram/day, 365 days per year, and 70 years of
.exposure.
CcnLT.ercial setting assures exrcsure thrcuch soil ir.cesticr.
c /~av , ^ --..r-r '- - -" --o-V
-------
18
various areas within the maximum area requiring excavation: Area A,
Area B and Area C. Area A is the center of the former pit area and
represents that area posing the most significant risk at the site.
Area B includes Area A as well as the center of the general industrial
waste area and the area impacted by the former pit area. Area C
includes Area A and Area B and represents the maximum area requiring
excavation. Area A, Area B and Are'a C are shown in Figure 16.
VIII. DESCRIPTION OF ALTERNATIVES
A description of the alternatives developed in the FS is presented
below.
A. Municipal Landfill
Total Present Worth: $2,320,000
Construction Cost: $1,179,000
Present Worth O&M Cost: $1,141,000
Historical information and the results of the RI indicate the eastern
portion of the site was used as a municipal/general refusejtype
landfill. The endangerment assessment did not indicate the
contaminants present in this portion of the site pose a threat through
direct contact with surface soils or migration of groundwater to the
river. Ensuring proper maintenance of this portion of the site will
require some limited action. Long-term groundwater monitoring and a
Subtitle D - solid waste landfill closure*appears to be the
appropriate extent of action needed at this time to ensure:
o future migration of groundwater to the river will not
pose a threat to the river, and
o adequate cover is present to prevent surface erosion and
subsequent direct contact with or wash-off of the wastes
into the river.
The components of this alternative include access restrictions, a soil
cover, a long-term groundwater monitoring program and the installation
of new groundwater monitoring wells around the perimeter of the
landfill. The location of the major components are shown in Figure
17.
The municipal landfill closure action described abova would be
performed in conjunction with the other remedial responses described
in Alternatives 2, 3, 4 and 5. The cost of the municipal landfill
closure is reflected in the total present worth cost estimates listed
for Alternatives 2, 3, 4 and 5.
-------
N
o 100
KAUINfEEI
LIOENO
AB£A 8
ARIA C INCLUDES AIL
AREAS SHOWN
FIGURE
RISK BASED AHEAS
OF EXCAVATION
FT. WAVMI REDUCTION M
-------
Ill""
till 10UNOARV
IIQINQ
IXTENT 0' COVf RIO REGION
MUNICIPAL LANDFILL
EXTENT OF COVERED REGION
WESTERN fOHTION OF THE SITE
fCALllNfKT
„ APPROXIMATE LOCATION FOR
FROrOSED DOWN GRADIENT MONITORING
WELLS FOR SURFICIAL AQUIFER
A APPROXIMATE LOCATION FOR
PROPOSED DOWN GRADIENT INTERMEOIATI
AND SURFICIAL AQUIFER MONITORING
WELL NEST
• EXISTING MONITORING WELL
FIGURE 17
SITE CLOSURE
ft. WAYNf REDUCTION FS
-------
19
B. Alternative 1 - No Action
Total Present Worth: $ 0
Time to Implement: 0 months
The NCR requires that the "no action" alternative be considered at
every site. Under this alternative, no further action would be taken
at the site. All wastes, routes of off-site contaminant migration
(i.e., groundwater), and human and environmental exposure pathways
would remain unchanged. This alternative would not reduce the threats
to human health and/or the environment identified at the site.
C. Alternative 2 - Groundwater Collection and Treatment
Total Present Worth:
Construction Cost:
Present Worth 0AM Cost:
Municipal Landfill Closure:
Time to Implement:
$ 4,940,000
$ 1,471,000
$ 1,149,000
$ 2,320,000
14 - 16 months
Alternative 2 includes the following components:
o Access Restrictions r
o Groundwater Collection System - The groundwater collection system
consists of a collection trench placed hydraulically downgradient
of the wastes in the western portion of the site and a vertical
barrier placed between the collection trench and the river.
Groundwater is intercepted by the trench and subsequently
treated. Additional monitoring wells would be installed to
monitor the effectiveness of the system.
o Groundwater Treatment - Groundwater treatment can be accomplished
by using either an on-site treatment plant or the Publically
Owned Treatment Works (POTW). An on-site groundwater treatment
plant would utilize a granular activated carbon adsorption
technology for the removal of the contaminants. The treated
water is monitored to assure compliance with discharge limits
and subsequently released to the Maumee River. Two options are
available if discharge to the POTW is permitted. The collected
groundwater can be discharged directly to the main sewer line
adjacent to the site or it can be collected on-site in a holding
tank, loaded into a truck and transported to the POTW facility
for discharge. Either POTW option requires compliance with the
established pretreatment requirements.
-------
20
o Soil Cover - To reduce exposure to surface and subsurface
contaminants, a soil cover would be installed at the completion
of the remedial activity. Installation of a soil cover involves
clearing and grubbing vegetation from the surface, regrading the
surface and placing and compacting a 2 foot layer of locally
available soil. The surface is regraded only to the extent that
the waste mass is undisturbed. The top 6 inches of cover is
topsoil capable of supporting grass vegetation. Final contours
are designed to promote surface drainage.
o Municipal Landfill Closure
Figure 18 shows the location of the major components in this
alternative.
Construction of the collection trench and vertical barrier should
occur between July and October to reduce the threat caused by flooding
events. Approximately, 0.3 acre of wetlands will be destroyed by this
alternative.
D. Alternative 3 - Containment
Total Present Worth: $ 5,260,000
Construction Cost: $ 1,883,000
Present Worth O&M Cost: $ 1,057,000
Municipal Landfill Closure: $ 2,320,000 •
Time to Implement: 16 - 18 months
Alternative 3 includes the following components:
o Access Restrictions
o Groundwater Collection System - This containment alternative
builds on Alternative 2 - Groundwater Collection and Treatment
by minimizing the inflow of groundwater to the area of buried
waste. This is accomplished by installing a vertical barrier
around the entire area of buried waste in the western portion
of the site. The groundwater collection trench would be in-
stalled inside the northern boundary of the barrier.
Installation of the collection trench inside the barrier will
maintain any groundwater flow through the barrier in an inward
direction.
o Groundwater Treatment - Same as described in Alternative 2.
o Soil Cover - Same as described in Alternative 2.
o Municipal Landfill Closure
Figure 19 shows the location of the major components in this
alternative.
-------
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LIOINO
• IKISTINOMONIIOBINO WtllJ
X AtPflOXIUMt LOCATION fOfl fROPOSEO
MONITORING WELLS FOR SURFICIAL
AQUIFER
A AFPRO>IMATi LOCATION FOR FROPOSEO
INTERMEDIATE AND SUHFICIAL AQUIFER
MONITORING WELL NEST
VERTICAL BARRIER
COLLECTION TRENCH WITH DIRECTION
OF MOVEMENT OF COLLECTED WATER
PIPELINE FROM COLLECT ION TRENCH
TO TREATMENT PLANT
FIGURE 18
GROUNDWATER COLLECTION
ALTERNATIVE
FT WAYNE FS
-------
HtVll»
"-M/M
IITI lOUNOARV
COLLECTION TRENCH WITH DIRECTION
OF MOVEMENT OF COLLECTED WATER
PIPELINE FROM COLLECTION TRENCH
TO TREATMENT PLANT
APPROKIMATE LOCATION FOR PROPOSED
MONITORING WELLS FOR SURFICIAL
AQUIFER
APPROXIMATE LOCATION FOR PHOPOSCD
INTERMEDIATE AND SURFICIAL AQUIFER
MONITORING WELL NEST
EXISTING MONITORING WELL
I'
FIGURE 19
CONTAINMENT ALTERNATIVE
Ft V.AONI Ft
-------
21
Construction of the collection trench and the northern portion of the
vertical barrier should occur between July and October to reduce the
threat caused by flooding events. Approximately, 0.1 acre of wetlands
will be destroyed by this alternative.
E. Alternative 4 - Soil Excavation for Drum Removal
4A
Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Municipal Landfill Closure:
Time to Implement:
$ 5,490,000
$ 2,027,000
$ 1,143,000
$ 2,320,000
18 - 20 months
4B Total Present Worth: $ 8,030,000
Construction Cost: $ 4,568,000
Present Worth O&M Cost: $ 1,142,000
Municipal Landfill Closure: $ 2,320,000
Time to Implement: 26 - 28 months
4C Total Present Worth: $ 10,020,000 -
Construction Cost: $ 6,558,000
Present Worth O&M Cost: $ 1,142,000
Municipal Landfill Closure: $ 2,320,000
Time to Implement: 28 - 30 months
Alternative 4 includes the following components:
o Access Restrictions
o Groundwater Collection System - Same as described in
Alternative 2.
o Groundwater Treatment - Same as described in Alternative 2.
o Excavation to Remove Buried Drums - Excavation is performed using
conventional equipment. Wastes and soil are removed until a drum
is unearthed, the drum is removed, overpacked and moved to a
storage area. The drums would remain on-site until they can be
incinerated. Any transportation and/or storage of drums would
be in compliance with Department of Transportation (DOT) and
Resource Conservation and Recovery Act (RCRA) regulations.
This alternative has three options for excavation and drum
removal that correspond to the three previously described risked-
based areas of excavation: Area A, Area B and Area C. The
estimated number of drums excavated in each option is listed
below:
-------
o Alternative 4A
o Alternative 4B
o Alternative 4C
22
600 drums
2,500 drums
4,600 drums
The unearthed soil and waste is reconsolidated on-site in the
excavated areas.
o Soil Cover - Same as described in Alternative 2.
o Municipal Landfill Closure
Figure 20 shows the location of the major components in this
alternative.
Most of the areas for drum excavation are above the 10-year flood
elevation and are not frequently subjected to flood waters. It is
conservatively assumed however, that drum excavation might be limited
3 months out of a year. As in the other alternatives, construction of
the collection trench and the vertical barrier should occur between
July and October. Approximately, 0.3 acre of wetlands will be
destroyed by this alternative.
F. Alternative 5 - Contaminated Soil and Drum
Removal/On-site Incineration
5A Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Municipal Landfill Closure:
Time to Implement:
5B Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Municipal Landfill Closure:
Time to Implement:
5C Total Present Worth:
Construction Cost:
Present Worth O&M Cost:
Municipal Landfill Closure:
Time to Implement:
$ 13,320,000
$ 9,951,000
$ 1,049,000
$ 2,320,000
22 - 28 months
$3 6,120,000
$ 32,729,000
$
$
1,
2,
071,000
320,000
42 - 48 months
$ 47,750,000
$ 44,401,000
$ 1,029,000
$ 2,320,000
54 - 60 months
Alternative 5 includes the following components:
o Access Restrictions
o Groundwater Collection System - Same as described in
Alternative 2.
o Groundwater Treatment - Same as described in Alternative 2.
-------
...u
sT-^cM, r^-- T>^^
.' -x ( ' ™^-- .
sSSi-K3 I:
X »ffHO»IMAU LOCATION FOR fHO^OSIO
MONITO1INC WELLS f OH IURFICIAL
AOUIFCfl
A AfrHOniMAH LOCATION fan nofOiio
INTCRMEOIATtANOSUKFICIAL AQUIFER
UONItORINO WELL NEST
VERTICAL IARRIER
COLLECTION TRENCH WITH DIRECTION
OF MOVEMENT OF COLLECTED WATER
'IFELINE FROM CO I LtOV ION TRENCH
TO TREATMENT PLANT
POTENTIAL REMOVAL AREAS:
AREA A
AREA!
AREAC
till tOUNOAHr
FIGURE 20
EXCAVATION OF SOIL FOR
DRUM REMOVAL AND
OFFSITE INCINERATION
ALTERNATIVE
FT. WA1TNI FS
-------
23
o Excavation of Soil and Drums for On-site Incineration - A mobile
incinerator would be transported and erected on the existing
foundation pad at the south end of the site. A storage building
is constructed nearby on the north end of the pad. Contaminated
soil, waste and buried drums is excavated and hauled to the
storage area. The storage area would have a leachate collection
system for any free water draining from the soils. In addition
the storage area would be completely covered to keep the soils
dry for incineration.
Drums would be staged in a separate secure area. The liquids in
the drums would be emptied to a holding tank. The empty drums
would be decontaminated and crushed.
The wastes, soils and drum liquids staged during the excavation
would be incinerated in the on-site incinerator. There are three
options for soil excavation and drum removal which correspond to
the three areas defined under Alternative 4. The estimated
volumes of wastes/soils for excavation and incineration are:
o Alternative 5A - 4,400 yd3 to incinerate
6,100 yd3 to excavate
o Alternative 5B - 30,000 yd3 to incinerate -
37,000 yd3 to excavate
o Alternative 5C - 43,000 yd3 to incinerate
57,000 yd3 to excavate
The estimated number of drums removed in each area would be the
same as those presented in Alternative 4.
The incinerator ash and the crushed empty drums would be returned
to the excavation area for disposal. The ash and crushed drums
would be placed above the expected high water table level.
o Multi-layer Cap - A multi-layer cap would be installed over the
area where incinerator ash and crushed drums are returned as
backfill. The multi-layer cap should be composed of three
distinctive layers:
o Topsoil and fill layer
o Drainage layer
o Barrier layer
More specif ical'iy a soil-clay cap consisting of a clay barrier
covered by a sand drainage layer and a fill and topsoil layer
would be used for this alternative.
o Municipal Landfill Closure
Figure 21 shows the location of the major components in this
alternative.
-------
. .
NUIIIIH.I: ,-.r
-------
24
As in Alternative 4, the areas for excavation are not frequently
subjected to flood waters. Construction of the collection trench and
the vertical barrier should occur between July and October.
Approximately, 0.3 acre of wetlands will be destroyed by this
alternative.
G. Summary of Alternatives
A summary of the major components for each of the five alternatives is
presented in Table 12.
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Each of the alternatives was evaluated using a number of evaluation
factors. The regulatory basis for these factors comes from the NCR
and Section 121 of SARA. Section 121(b)(l) states that, "Remedial
actions in which treatment which permanently and significantly reduces
the volume, toxicity or mobility of the hazardous substances,
pollutants, and contaminants as a principal element, are to be
preferred over remedial actions not involving such treatment. The
off-site transport and disposal of hazardous substances or_
contaminated materials without such, treatment should be the least
favored alternative remedial action where practicable treatment
technologies are available."
Section 121 of SARA also requires that the selected remedy be
protective of human health and the environment, cost-effective, and
use permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
Based on the statutory language and current U.S. EPA guidance, the
nine criteria used to evaluate the remedial alternatives listed above
were:
1. Overall Protection of Human Health and the Environment addresses
whether or not the remedy provides adequate protection and
describes how risks are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not the remedy will
meet all of the applicable or relevant and appropriate require-
ments of other environmental statutes and/or provide grounds
for invoking a waiver.
3. Long-term effectiveness and permanence refers to the ability of
a remedy to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
4. Reduction of toxicity, mobility, or volume is the anticipated
performance of the treatment technologies a remedy may. employ.
-------
Table 12
SUMMARY OF ALTERNATIVES
Alternative 1—No Action
Alternative 2—Groundwater Collection and Treatment
o Fence site
o Access restrictions
o Slurry wall and collection trench (downgradient of wastes)
6 Treatment plant
o Soil cover
o Municipal landfill closure
Alternative 3—Containment
o Fence site
o Access restrictions
o Slurry wall and collection trench (encircling wastes)
o Treatment plant
o Soil Cover
o Municipal landfill closure
Alternative 4—Excavate Soil/Drum Removal
o Fence site
o Access restrictions
o Alternative 2
o Excavate soil area for option 4A, 4B, or 4C
o Remove drums and incinerate offsite
o Reconsolidate soil onsite
o Soil Cover
o Municipal landfill closure
Alternative 5—-Incineration
o ' Fence site
o Access restriction
"o Alternative 2 (except soil cover)
o Excavate soil and drums base on areas for option
5A, SB, 5C
o Incinerate soil and drums
o Deposit ash onsite
o Multilayer cap over the entire area for option SB
and 5C; cap only on former pit area for option 5A;
soil cover for the remainder of the western por-
tion of the site
o Municipal landfill closure '
-------
25
5. Short-term effectiveness involves the period of time needed to
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
6. Implementability is the technical and administrative feasibility
of a remedy, including the availability of goods and services
needed to implement the chosen solution.
7. Cost includes capital and operation and maintenance costs.
8. Support Agency Acceptance indicates whether, based on its review
of the RI/FS and Proposed Plan, the support agency (IDEM)
concurs, opposes, or has no comment on the preferred alternative.
9. Community Acceptance indicates the public support of a given
remedy. This criteria is discussed in the Responsiveness
Summary. .
A matrix which summarizes the comparative analysis of alternatives on
a criteria by criteria basis is presented in Figure 22.
The following discussion expounds on the information provided in
Figure 22.
A. Overall Protection of Human Health and the Environment
All of the alternatives, with the exception of the no action
alternative, would provide adequate protection of human health and the
environment by eliminating, reducing, or controlling risk from the
site through treatment, engineering controls or institutional
controls. As the no action alternative does not satisfy the remedial
action goal to provide adequate protection of human health and the
environment, it is not eligible for selection.
Alternatives 2 and 3 accomplish overall protection of human health and
the environment through engineering and institutional controls. The
primary controls included in Alternative 2 are a groundwater
collection system and deed restrictions. Alternative 3 includes the
same controls as Alternative 2 in addition to a containment of the
wastes (i.e., a slurry wall encircling the waste area). Both of these
alternatives would use treatment to manage the collected groundwater.
Alternatives 4(A, B and C) and 5 (A, B and C) accomplish overall
protection of human health and the environment through the treatment
of wastes in addition to engineering and institutional controls. Both
these alternatives include the engineering and institutional controls
of Alternative 2. Alternative 4 however, includes incinerating
excavated drums containing liquid waste. The amount of drums
-------
EVALUATION
CRITERIA AND
ANALYSIS
FACTORS
5HORTTERM
EFFECTIVENESS
P»OtK1n/n
Tim* Until:
Remedial Action*
Commence
Design Complete
Protection Aga«rm
Principal Threat*
lEnd ol Conxhudton)
Completion at
Re'ned-si Actons From
Sun o* Design
LONG-TERM
EFFECTIVENESS
Magnitude of
Aeme>nmg Rnk
Long Term Controls
ALTERNATIVE
NO ACTION
No action leKan
Mo id ton UUn
PnncipaJ threat Injm contaminated ground-
»ii«r releasing k) ch» Maume* Ri»er and
direct conuct threat «>u present.
No action laVan
Source of rtsti
• Presence of buried drums and westa
• Contaminated greundweler and ground-
weier seeps megniiude of risk •» defined
In the ntfc tisetftmera
NO long lerni control*
ALTERNATIVE 2
GROUNOWATER COLLECTION
AND TREATMENT
Community
* fent« t«W
• Oecontemineiiofl of vehicle* leaving lh«
•it*
• Use of dun and voieule organic eup-
ptenanta
* Heenrt and safety l^ed
• AU monitoring and Ufa ol protects* gt ai
» Ufa ol sele* trench tnsunaiion technology
• Ufa of lampiing plan
tn»«t>nmenl
• Runoff cor*«4 while trenching and instat-
ing tiurry "*»
ActMlles aner ROD H signed
• pre-detign investigation 4 months
• Oevgn MM2 months
• NPDES permit 49 month!
ma <00 y«ar flood plain
U-H moniha,
Ala* compiftion of th« •lurry w«|
lion ira«Kh »fwch laka 2 monihi protaci«n
again*! comaminini m«*ta to tba Uaumaa
Rlwr t acruavvd InsutUtton of tha tori oow.
•cnlvwt pfOtaction igtmH tha *f»d toll
contact ifwtti. Val um« lor both ihmtu <•
Remedial adlon to complcli whtn lh* «o4
covar i* appnad. 14- 10 moniht. but ground-
w«lir collection and trtalmvni wil ga into Ina
Sourca ol n«k
• Pt«a«nca of burlad dnjmi and wa«a
• CoUacuon ol conii
and hanoung of ipart carbon
Uagmtuda ot d»k dvpandam upon:
• Reliability of aiwrry "•" »° maintain a low
permtatHfity
• pBiiabihryot collection tranchucontlrtua
Coflacting groundwalar
• Entorctmvni of via nmnciioni
• m»iuUonaJcontroliofdaadrt«ncbon«nd
• Operation and maintenance ol ground-
water collection eystem
• Oroundwaiaf monitoring
• Maintenance of aod covar
ALTERNATIVE 3
CONTAINMENT
Inciudaa componenta of Alternate* 2
Acimiia* afiar ROO U aignad
Sam* at Aiiernahw 2
Slurry well and collection irancn would be)
installed Rot; (hen (he remainder of ina
containment w«n Construction of alurry w«l
and trencA Uhe 2-3 montha.
Pnjiect«on egainn grouncfwiter Inreai la 2
rnomnt aa m Anem*iiv» 2: pnxectian agamU
dttect koll contact \»ke> a momht itiow»ng
kx compietkxi of the comaMmenl waJ and
aoil covec.
Remedial action la complete when the con-
tainment wad U innaMed av*d tha aoil cove*
appJied.lOiQ monthi Co"eclton of weief
wtU go Into tha lulura .nd«finJlafy
Sourca of risk IB siimlw K> AJtarnaUy* 2 M
cept the westa n contained and groundwaler
dtvanad ao (ha wiuma of treated wale* la
raduced and l*a movamant ol contanwunu
In the aod reduced.
Same u AQamaiivt 2
ALTERNATIVE 4
SOIL EXCAVATION FOR
OHUM REMOVAL
• Include* components ol Altemetive 2
> Follow DOT end RCRA legulaiiona on
Iraniporting hautrdous compounds
> RCRA approved containment area tor
drums storage
> S'la safety and aampUng plan tor drum
lasting end hendUng
ActMtiee after ROD U signed aeme ae Aner-
neltve 2. COiiecllon trench and treatment
plan) are runctional pno* to eicevmtion tor
dnjm removal fhis Uhai t*-t6 month! petom
U14 montha
Protection again*! gnHindwaier lhn>et Is 2
months aa In Aiiematrv* 2. Protection against
the dree* aod contact, 4A la B months. *B
U months, 4C 10 months until eicavaiion Is
complete and ihe cover installed. Thie fame
Inciudaa the fthjrn/ watl Indexation.
Remedial action it complete when the d"um»
k'a removed and Ihe soil cove* applied.
4A. tfr?0 months; 48. 2fl ?8 months: *C.
26-30 months G'Oundm«ter co'laction end
ttaatmant wiH go uuo (ha tututeiy
Source ol risk
• ReconsoMlaied coniammnied wasia fa-
mem* buried drum* remain in option 4A
and 48
Uagmtuda of nsk depends on:
• The percent drum removal 4A • I5H. 40
• SSH. 4C - 100H ol asnmaied drums
• Peribrmence of gtoundwater coOection and
end treatment system.
iame a* Alter native 2.
ALTERNATIVE S
INCINERATION
> Include* components of Alternative 2
< Alt •mts»ca«etion and
Incmai al«rt begin Inc^ietedon will require, a
test bum •H^ch could i«su« tn delays d »m.v
non eianda/da era not met.
u » momha
Proteciion egatnei gnxindweier threat is 2
months u in Aiiemeirv* 2. Protection agamsi
direct MM) contact. &A a months, 58 28
months. SC 40 months until incme(kl*on Is
complete and cap Installed. This lime in-
cludes (he slurry weM IntnaRelion.
Remedial action is complete whan ihe mem-
aiator is removed from site and the cap
apphad. SA. 22 ?f months; IE *2*t months,
5C, 54 60 months The gtouodwaiff collec-
tion and tr. some a»n. 58 removes had ihe
drums end aoM but hat more eih buried.
5C leaves ash as residua bw>ed on aite
• Performance of me ground**!** coUeciion
and treeimant system.
Same as Alternative 2 e*cept the length of
time on deed restriction may change tor SC,
and a muiu layer cap ta present where asn
ia buried.
MUNICIPAL
LANDFILL
• fence sue
• Dun control
• Surface run o» corltol
After ROD is B>gn*d d*»-gn «.
-------
EVALUATION
CRITERIA AND
ANALYSIS
FACTORS
ALTERNATIVE 1
NO ACTION
ALTERNATIVE 2
GROUNOWATER COLLECTION
AND TRCATEMENT
ALTERNATIVE 3
CONTAINMENT
ALTERNATIVE 4
SOIL EXCAVATION FOR
DRUM REMOVAL
ALTERNATIVE $
INCINERATION
MUNICIPAL
LANDFILL
REDUCTION OF
TOXICITY MOBILITY
AND VOLUME
Tteaim«nt Ptocets and
No ti
Amount of Haiardout Malerul
Tieitod «nd n*ndu*l
from Tie*trnar«
None
P*tfuciion of Tonciry
Mobility and Volume
It Ti«»tm«nl
Rev«r*ibte?
IMPLEMENTABtLITY
Technical Feasibility
No reduction of toattfty. mobility antf w*ume
Doee no* apply
Qranular actuated ct'bon to beat contamt-
neied ground weier. no special requirements.
doet not addiau ir«e p>inc 24 million gaiiont • year groundwetef
' S600 1)1 year ctr&on regenerated
> &x«emlrwnu r*rnc**d 400 pounds a year
ealriient to If* Mm* ••
»< native 2.
• 04 minion gallant • year groundweier
• 3100 bt. r*v carbon regenerated
• Coniaminanu removed 70 pound! • yea*
Them to no reduction of tvldiy. motMUy o»
volume in In* to* conttmlnsnu c«h*r tt)M
lh«l wtid occum ov«r tim« (hrougn ln« Ruth-
Ing «nton o> th« o/Qundwvtar mowig Duough
Iht Mtui*i«d n>n«.
Citon •bMrpiton. ytt C*rbon r«gtn*n>
iton. na
tani »rt timp>* to construct. Impitmtnt
ConsiructMt In unknown w«i« mtttrial
Intf could raquift nymoval prior » miking
tht *•• or l«y>ng (hft lr*nch.
• Ntw trfnch itcnnology Mnough touibl*
U d.rticun 10 pttdlct Khtduiing or long
to long Itrm »lurry w«H p«r1cxmtnct it not
kno«n but lo dM« otnf IntUMtlWni h«v«
Aknough lha *««• to eontainad lhar* (• inl*
reduction of to>ic«v. mobiilry or volume of
tna tou«t« conurmnaru % a tAghtry gmaier
deor*a than Aitemaih* 2. some r«ductK>n I*
achif^d by the codaoxyi of the tmU woium*
of water mhiiraitont into lha contained area.
Catbon absorption. ya» Cartxxi r»gener»-
tlon. na
Technical h»«wf>Wy mdudtt Anamal>v« 2 plus
txctvaiion trwougti buried «*•«• »tnstaJI lh«
tluiry watt hat the unknown tactot of how
much additional word tkrw down i* involved
in toning utrough (he watte to bmld lha w*u.
Future remedial actiont could ba Alternative
4or&
Includai AHam«ii«« 2 lre«tm«nl
OMslie Incinerition of drumt addiattai
pan: of the direct contact thieat with buried
»««e, amited ofttite IncmeraikM capaaty
* 25 miHion g*Uont groundwaier a yeai
* Contaminants removed *00 poundt a year
* &500 Ibt year carbon r*gtn»rwton
• Drummed Nqmd tncme«alion
4A 30000 gallon*
48 125000 gillona
4C 230XWO gaitona
Drum r«movW provide* tome reduction In ihe
to««ify and votuma of conummtttd waste
The remaining contaminanti In lha tori we
din mobile,
Incmeratton. no. Carbon abtorption. y«t
lechnical Utntwliry include! Alternative 2
• Eicavanon it ample and itrargmfonwird
tecrmokigy but tne Oaiay* come Inxn work-
ing in dttfa'eni laved of protection and
toning through the burned d/uma and
dtbnt
• Orum» may have 10 be stockpiled until
InctnefAiion capacity become available
« Future remedial aciiont depend on which
option la selected AAernaiive S can be
done ai a uter date.
> Construction in th« 100 year flood plain
•nd In th« wtiiandt can ciust tcntdul*
dtlty* and nM)uir« •dminlstrtfivv conuoli.
> Schtduta da'ayi can coma tiom working
In diftaram l*v«i> of pmtaann.
• Futura fomadial action could ba tha rt-
fnadxl aaKXit propos«d tn Alia/
4orl
• inctudat AJt*rnative 2 troatinunt
• kKuteratton of to*l and drums
• PrecipttatAnoftcrubDef water end aludge
tfiipotaf.
• Addnstet DrktclpeJ Ihreatt. r» dirflcuH K>
Imptemeni and has many apeciaf techncai
consideraiwnt tuch aa bmiiad operating
data, eqmpmtitf avaitab'My, leiidual ash
and tiuge r«quue speciaJ handling.
• Otoundwattr now M. a C 25 million gai-
tona year
• Carbon reg«n«rationSA » 1140 Iba year.
48, C • 4tO »t year
• Conummcrtt removed M • 60 t>t a year.
SB. C is nvgbgtble
• Soil IraaiKl: SA. 4.400 Cy; SB. 31000 Cy
5C 45.000 CY
• Otummed bqu«dt ume •• Allarnalrve 4
• Aah remnning:
SA - IJTXDCy
50 • 26000 cy
6C - 37JBOOCV
Pi* rvdudion m conummaMd ewl and dnim-
med Kq-jid mesa, volume and toacity it
traded agamst tne addilwnai man of ash
depot'twi on tae that can potentially ba tot-
tC and hat tmiied moOilify Of inorganic
compoundt
IncmeraiKkn na Precipaation. yea.
Technical (eaubtMy includea Alternative 2. 4
• Scheduling excavation and incineration
»ie Importtr* cmtrta
• Etftvaungntfieaaturaiedioneiadifncuil
• Incmeraiion of contaminated soil ts proven
technology but there d tut fcnwed tnlorma-
boo and da-a available to datign. operate
and tchedite the procesa Can be a high
risk a aa tactora are not considered.
• II SA is selected, then future remedial ac-
uont may mvotve SB and SC
No ireaimoni
None
Soil cover and monnonn^ ^r •«• vi '
to implement and mamta
-------
EVALUATION
CRITERIA AND
ANALYSIS
FACTORS
IMPLEMENTABILITY
Availability of Service*
end Material!
Administrative
reauD'lity
OVERALL PROTECTION
OF HUMAN HEALTH AND
THE ENVIRONMENT
Compliant With ARAH'e
Reduction ol Culling
and Future Hisk
Ovcnfl PrtM*CtiCMt
COST SUMMARY
T6i». Capital Co*
Qp*tat»on (Wid M«tnt«nanc«
Toui PrMvm woth it SH
Total RfmtxMl Action W.lft
LanaMI Clasu't
ALTERNATIVE 1
NO ACTION
Oo*» noi apply
Th» Ml* r»m«lna •! th» MIT* lUlut
No
No fvductlon ol ni*. Kriur« nil. *>l« H dnjtnt
rupture Of " mjentlaj^f COrXAmtf^aled O/OUT1O*
water reechea Ifto e»ieling walla.
No pmectloi provided.
Oooa nol apply
ALTERNATIVE 2
CROUNOWATER COLLECTION
AND TREATMENT
• W meleiiela are evatfebte
• SNirrv •>•• end bench COntraCIOr* Ire
•peciebied end may («qulr» tddllkMUl
lltODillUllan !""•
• Skid mounM O«C iwvll -id«l» fv«,ltW«.
wnOOf *iB r«g«nitil« Ui« CftftraA •• p»H
of lh« comnd.
CoonJ'iuton MK Mho igwiciM l> nqdnd
tor Irittt •'•••:
NPOES diKlitrgt (mill ttquliMl
COE »p^»< ol Rod) pnoling tiW
Puarriitl «*nanos mil>gtilon
D««d fvttrlclloni
S«t cloiun
ft*
Rlik (rani Una nitut of nMtmlnMKl
QrOunftthnrt^^f to 1f^ Mauntcv Rnf^f find olfiicl
tlunlBI contact of ground»»l»r and tuflac*
•M iut>wrt>M K»> KNOW] rmun a kMl ol Xlon K nqumd w In Alan»>
Ov.1
Via
Inckjdaa all Itia componanfa of AJtarnaUv* 2
vohima of conumtnaiad groundwalaf to b«
coOaclad and Iraalad.
F.^iwtiwx ui nutfi«n ntaiiM ajH) in* anyiAW
man! subtlanllal bul • ntquraa •ntorcamanl
of Ida ak\iiMTlunt tMtUClKHl M tOfl vQtufnit
of contaminated wane but depouta a In-
ctnarclor ath on tite which pr*ianl* • potea-
Hal rlih of elevaied Inorganic concentration
Inmenxl
Protection of human hearth and the environ-
ment subnantial but II require* entorcarnent
of the ilia contrail.
9A 1.910.000
SB 12.730.000
SC 44.400.000
5A 1.050000
ja t.030.000
SC I.OM.OOO
JA 11.000000
38 33 «00 000
SC 4S.410.000
9A 11.120.000
98 M. 120 000
SC 47.750000
MUNICIPAL
LANDFILL
Afl aenricel and mitanali a'e avtilaoie
Coordmalion tor landdil clofui*
Vat
Ho immediate risk pietmil al m t l-i
100 year flood plain.
Protection from waihoutol Ina MnT'ill lum i
flooding achieved.
1,120000
1.140000
2.320 000
1.330 CCO
22,
FIGURE <-<-IPACE 3 OF 11
COMPARISON OF AITERNA ||VC
H MATNI RlOUCtlONH
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26
excavated and liquids incinerated is dependent on the risk-based area
(A, B or C) selected. Alternative 5 includes incinerating the
excavated drums containing liquid wastes and soils/wastes. The amount
of drums excavated and liquids and soils/wastes incinerated is also
dependent on the risk-based area (A, B or C) selected.
B. Compliance with ARARs
All of the alternatives, except for the no action alternative, would
meet all applicable or relevant and appropriate requirements of
Federal and State environmental laws. Table 13 indicates the
applicable or relevant and appropriate requirements for each of these
alternatives.
C. Long-term Effectiveness and Permanence
Alternatives 2 and 3 employ solely containment type technologies and
all the buried drums and wastes would remain in place undisturbed.
Alternative 4C would remove 4,600 buried drums containing liquids
which serve as the primary source of contaminant releases to
subsurface soils and groundwater. Alternative 4A and 48 would remove
600. and 2,500 drums respectively. -The number of drums removed in
Alternative 4C represents 100% of the drums anticipated to be present.
Alternatives 4A and 48 would remove 13% and 54% of the total number of
drums anticipated to be present, respectively. In all of these
alternatives, the contaminated subsurface- soils and wastes would be
reconsolidated on-site and the liquid drum contents incinerated.
Alternative 5A would treat a relatively small volume of contaminated
soil, approximately 4,400 yd3, and 600 drums. This represents 13% of
the total number of drums anticipated to be present and 10% of the
contaminated subsurface soils and wastes above target level
concentrations. Alternatives 5B and 5C would increase: the volume of
contaminated soil that is treated to approximately 31,000 yd3 and
45,000 yd3 respectively and the number of drums excavated to 2,500 and
4,600 respectively. Alternative 5B treats 69% of the contaminated
soils/wastes above target levels and 54% of the total number of drums
anticipated to be present. In all of these alternatives the
soils/wastes and liquid drum contents are incinerated and the residual
ash disposed on-site.
All the alternatives (2, 3, 4 and 5) require long-term maintenance be
performed at the site. The long-term risks associated with exposure
to, and migration of, the remaining wastes will be reduced by ensuring
the following long-term activities are performed:
-------
Table 13 (Page 1 of 4)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
Law, Regulation, Policy,
and Standard
Alternative
Aoolicaclon
234
RESOURCE CONSERVATION AND RECOVERY ACT CRCRA
40 CTR 261:
Deflnltion and identification
Definition and identification of
waste material as hazardous
40 CTR 262:
Standards for generators of
hazardous waste
40 CTR 263:
Standards for transport of
hazardous waste
40 CTR 264:
Standards for treatment of
hazardous waste
•
40 CTR 264:
Standards for disposal of
hazardous warte
40 CTR 268:
Land disposal restriction
Generator requirements include
identification of waste generation
activity, obtaining EPA ID number,
record keeping, and use of uniform
national manifest
The transport of hazardous waste
is subject to requirements includ-
ing DOT regulations, manifesting,
record keeping, and discharge
cleanup «•
Incineration requirements
Closure requirements (western
portion of the sice):
- Hybrid closure (under CERCLA)
• Landfill closure without minimum
technology requirements
Excavated waste disposed onsite.
may be subject to land disposal
restrictions if placement occurs.
X X X
40 CTR 257:
Standards for disposal
of solid waste
Closure1 requirements (eastern
portion of the site)
XXX
40 CTR 264, Subpart I
Containers
CLEAN WATER ACT (CVA)
Storage requirements for
containers
40 CTR 122, 125:
National Pollutant Discharge
Elimination Systeas (NPDES)
Discharges of extracted/treated
groundvater will be subject to
substantive requirements of the
NPDES process if discharged to the
Kausee River. NPDES is adainis-
tered by the state
XXX
-------
Table 13 (Page 2 of 4)
Law, Regulation, Policy,
and Standard
40 CFR 403:
Effluent Guidelines and
Standards: Pretreatment
Standards
40 CFR 230:
Dredge and Fill Requirements
Ambient Water Quality
Criteria
CM Section 109 and
40 CFR 50: National Ambient
Air Quality Standards
Alternative
Application
Discharges of extracted/treated
groundwater will be subject to
pretreatme&t requirements if
discharged to the POTW
Actions in a wetland or floodplain
AWQC may be used for discharge
requirements where there are no
state water quality standards
Preconstruction review of
incineration
NAAQS for PH10 applied to fugitive
dust
23 45
X X X X
X X
X X
X- X
Occupational Safety and Health Act
29 CFR 1910:
General standards for work
protection
29 CFR 1910:
Regulations for workers
involved in hazardous waste
operations
Worker safety for construction and
operation of rsmedial action
Worker safety ::or construction and
operation of remedial action
Hazardous Materials Transportation Act
49 CFR 100 through 199:
Transportation of hazardous
material
The transport of hazardous waste
is subject to DOT requirements
IfrrERCOVER.VXE.VTAI. REVIEW OF FEDERAL PROGRAMS
EXECUTIVE ORDER 12372
X X X X
X X XX
40 CFR 29
State and local coordination and
review of proposed EPA assisted
projects
X X X X
-------
Table 13 (Page 3 of 4)
Law, Regulacibn, Policy,
and Standard
Fish and Wildlife Coordination
Act
Alternative
Endanuered Species Act
Section 7(c)
Application
Protection of fish and wildlife
when federal actions result in
the control or modification of a
natural stream or body of water
Consultation with the fish and
wildlife service if action may
impact endangered species or
critical habitat
Executive Orders for Flood Plains (EO 11988)
40 CTR Part 6, Subpart A
Executive Orders for Wetlands
(EO 11990)
Protection of flp.od plains
affected by remedial action
Protection of wetlands affected
by remedial action
234
XXX
X X X X
X X X X
X X X X
INDIANA REQUIREMENTS
Indiana Hazardous Waste Management
Article 4 (320-IAC-4):
- Waste generation identi-
fication, standards for
generators
- Standards applicable to
owners and operators of
hazardous waste facilities
• Closure/post-closure
Solid Waste Managecenc
Peraits 330 IAC' 5
Standards for incineration
Closure of the western portion
of the site:
- Bybred closure (under CERCLA)
- Landfill closure
Closure of eastern portion of
the site
Indiana Waste Treateent Facilities Reeulation .
Article 3.1 (330-IAC)
Facility Construction
Construction of onsite treat-
ment plant
X X
X X
X X
X
X
X X
X X
-------
Table 13 (Page 4 of 4)
Law, Regulation, Policy,
and Standard Application
Indiana Waste Treatment Facilities Regulation
Article 3.1 (330-IAC)
Facility Construction
Construction of onsite treat-
ment plant
Alternative
X
Indiana Water Pollution Control Board
Article 5 Industrial Pre-
treatment and NPDES Programs:
- Rules 1 through 10 NPDES
Permit
- Rules 11 through 15 Pre-
treatment Standards
Indiana Water Quality Standards
330 LAC 1-1 Current Standards
327 IAC 2-1 Proposed Standards
Discharges of extracted/treated
groundwater will be subject to
substantive requireaents of the
NPDES process if discharged to the
Maunee River. NPDES is adminis-
tered by the state
Discharges of extracted/treated
groundvater will be subject to
pretreatment requireaents if dis-
charged to the POIW
Can be used to set discharge goals
Can be used to set discharge goals
X X X X
X X X X
CLX757/36
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27
o Implementation of institutional controls (i.e., deed
restrictions and access restrictions),
o Operation and maintenance of the groundwater collection
system,
o Maintenance of the soil cover/cap.
o Groundwater monitoring.
D. Reduction of Toxicity, Mobility or Volume
Alternatives 2 and 3 would provide a reduction in groundwater
contaminants J>y 400 IDS per year and 70 IDS per year respectively, but
not in the toxicity, mobility or volume of the soil and drum
contaminants.
Alternative 4C will provide a reduction in the volume and toxicity of
the wastes at the site, with 400 IDS of contaminants removed from
groundwater a year and 230,000 gallons of drum liquids incinerated.
Alternatives 4A and 4B will also reduce the volume and toxi.city of the
wastes at the sit-e with 400 IDS of contaminants removed fttim
groundwater a .year and 30.0DO gallons and .125,000 gallons,
respectively, of drum liquids incinerated. All of these alternatives
provide for the reconsolidation of excavated soils/wastes on-site. .
The contaminants remaining in the soils/wastes will still be mobile.
Alternatives 5A, "5B and 5C provide in varying degrees a reduction in
the contaminated soils/wastes and drummed liquids at the site.
Alternative 5A would incinerate 4,400 yd3 of soils/wastes and 30,000
gallons of drummed liquid waste. Alternative SB would incinerate
31,000yd3 of soils/wastes and 125,000 gallons of drummed liquid
wastes. Alternative 5C would incinerate 45,000 yd3 of soils/wastes
and 230,000 gallons of drminted liquid waste. All of these
alternatives provide for the disposal of the residual ash on-site.
The reduction achieved in the contaminated soils/wastes and drummed
liquid mass, volume and toxicity is traded against the additional mass
of the potentially toxic, but less mobile, residual ash disposed on-
site. -Alternatives 5A, 5B and 5C will have 3,700 yd3, 26,000 yd3 and
37,800 yd3 of residual ash remaining after incineration, respectively.
Therefore, incineration of the soils/wastes is only providing a 10% to
16% reduction in the volume of contaminated soils/wastes.
£. Short-terra Effectiveness
All of the alternatives (2, 3, 4, and 5) will present a short-term
threat to workers, the community and the environment during ^the
construction phase of the remedial action. The implementation of
various protective measures (i.e., dust suppressants, air monitoring,
runoff control, etc.) during the- construction phase will minimize
these threats. Alternatives 4 and 5 would require a larger number of
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28-
Alternative 4 involves the excavation of soils/wastes while
Alternative 5 involves an excavation of soils/wastes as well as an
on-site incinerator.
Alternatives 2, 3 and 4A will take relatively the same amount of time
to implement (14 to 20 months). Alternatives 48, 4C and 5A will take
a little longer (26 to 30 months). "Alternatives 5B and 5C will
however involve a significantly longer time frame to implement than
any of the other alternatives (42 to 60 months).
Each alternative will achieve protection against the principal threat
of groundwater contamination. Alternatives 4 (A, B & C) and 5 (A, B &
C) in addition to achieving protection against the principal threat
will in varying degrees minimize the major sources (drums containing
liquids and contaminated soils/wastes) contributing to the principal
threat.
F. Imp! ementabl11 ty
All of the alternatives (2, 3, 4 and 5) are technically feasible.
Some consideration should be given however, to the following items in
each alternative:
f
o Alternative 2
Soil cover and groundwater treatment system are simple
to construct, implement and maintain.
New trench technology although feasible is difficult
to predict scheduling or long-term performance.
Long-term slurry wall performance is not known but to
date other installations have performed well.
Construction in the 100 year floodplain and in the
wetlands can cause schedule delays and require
administrative controls.
Schedule delays can come from working in different
levels of protection.
o Alternative 3
Includes the items listed for Alternative 2.
Excavation through buried waste to install the
slurry wall has the unknown factor of how much
additional work slow down is involved in sorting
through the waste to build the wall.
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29
o Alternative 4 (A, B and C)
Includes the items listed for Alternative 2.
Excavation is a simple and straightforward technology.
Delays may be encountered from working in different
levels of protection and having to sort through the
buried drums and debris.
Drums may have to be stockpiled until incineration
capacity becomes available.
o Alternative 5 (A, B and C)
Includes the items listed for Alternatives 2 and 4.
Scheduling excavation and incineration are important
criteria.
- . Excavating in the saturated zone is difficult.
Incineration of contaminated soil is a proven
technology but there is still limited information
and data available to design, operate and schedule
the process. Can be a high risk if all factors are
not considered.
In addition, each of the alternatives has the following administrative
difficulties:
o Obtaining NPDES permit limits
o Obtaining various approvals for the flood protection
strategy
o Obtaining deed restrictions
6. Cost
For each alternative, the total remedial costs (capital plus operation
and maintenance) including the municipal landfill closure in present
net worth are:
o Alternative 1 $ 0
o Alternative 2 $ 4,940,000
o Alternative 3 $ 5,260,000
o Alternative 4A $ 5,490,000
4B $ 8,030,000
4C $ 10,020,000
o Alternative 5A $ 13,320,000
58 $ 36,120,000
5C $ 47,750,000
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30
For all of the alternatives, the municipal landfill closure cost
(capital and operation and maintenance) is $ 2,320,000 of the total
remedial costs. In addition, the operation and maintenance costs for
all the alternatives are comparable ($ 1,029,000 to $ 1,149,000 of the
total remedial costs). Therefore, the primary difference between the
alternatives is the capital costs associated with each alternative.
Alternatives 2, 3 and 4A have comparable capital costs ($ 1,471,000, $
1,883,000 and $ 2,027,000 respectively). The capital costs for
Alternatives 4B and 4C are slightly higher ($ 4,568,000 and $
6,558,000 respectively) than the capital costs for Alternatives 2, 3
and 4A. Alternative 5A provides a slight increase in capital costs ($
9,951,000) but Alternatives 5B and 5C provide a significant increase
in capital costs ($ 32,729,000 and $ 44,401,000, respectively) when
compared to the other alternatives.
H. State Acceptance
The State of Indiana supports Alternative 4C - Soil Excavation for
Drum Removal. The State of Indiana recognizes the 10% cost share and
operation and maintenance responsibilities associated with this
alternative, if the remedial action is a fund lead action.
I. Community Acceptance , -
Community Acceptance is assessed in the attached Responsiveness
Summary. The Responsiveness Summary provides a thorough review of the
public comments received on the RI, FS and Proposed Plan, and U.S.
EPA's responses to the comments received.
X. THE SELECTED REMEDY
The selected remedy for the Fort Wayne Reduction Site is Alternative
4C - Soil Excavation for Drum Removal. This alternative is protective
of human health and the environment, attains applicable or relevant
and appropriate requirements promulgated under Federal and State
environmental laws, and is cost-effective. Treatment which
permanently and significantly reduces the volume, toxicity, and
mobility of hazardous substances is a principal element of the remedy.
Finally, this alternative utilizes permanent solutions to the maximum
extent practicable, and represents the best balance of the factors for
selecting an appropriate remedy at the site.
A. Municipal Landfill
The primary components for the remedy on the municipal landfill are
access restrictions (fencing and deed restrictions), a soil cover
designed for flood protection and a long-term groundwater monitoring
program. A soil cover compliant with Subtitle D - solid waste
landfill closure requirements is the appropriate extent of remedy for
this portion of the site. Historical information and the results of
the RI indicate this portion of the .site was used as a
municipal/general refuse type landfill with little hazardous type
-------
31
materials being disposed. The risk assessment indicated that this
portion of the site does not currently pose a threat through direct
contact with surface soils. A part of the municipal landfill area is
however subjected to flood events. The resulting surface erosion
could expose wastes in this area creating a potential direct contact
threat or a wash-off of wastes into the Maumee River. Installing and
maintaining the soil cover will prevent surface erosion and ensure
protection of human health (of on-site trespassers) and the Maumee
River.
The risk assessment also indicated that the contaminants migrating
through groundwater to the Maumee River do not pose a threat to the
river. Ensuring future migration of groundwater does not pose a
threat to the river requires implementation of a long-term groundwater
monitoring program. The groundwater monitoring program will ensure
protection of the Maumee River through the use of alternative
concentration limits (ACLs) as a groundwater performance standard.
The criteria established in SARA Section l2l(d)(2)(B)(11) for the
application of ACLs stipulates that the following conditions be met at
the site:
o There are known and projected points of entry of
contaminated groundwater into surface water.
o There is no statistically significant increase of
hazardous constituents from ground water into surface
water at the point of entry or where there is reason to
believe downgradient accumulation may occur.
o The remedial action includes enforceable measures to
preclude human exposure between the facility boundary
and points of entry into the surface water.
All three of these conditions are met for the eastern portion of the
Fort Wayne Reduction site. Direct exposure to any contaminated water
on-site will be precluded through the use of deed restriction
prohibiting the use of groundwater on-site. The site's property
boundary is the discharge point to the Maumee River.
Conceptually, establishment of groundwater protection standards to
protect the Maumee River can be based on the following two criteria:
o No statistically significant increase in contamination
released to surface water will occur due to discharges from
groundwater at the site; and
o No statistically significant exceedance of a State of
Indiana Water Quality Standard for surface water will be
allowed as a result of the groundwater discharge.
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32
The first criterion will be applied at the Fort Wayne Reduction site.
As the site presently exists, satisfying the first criteria will more
than satisfy the second requirement. Taking this approach will
provide a high degree of protectiveness for the Maumee River.
The mechanics of the groundwater monitoring program will be
specifically addressed in the remedial design (RD) phase of the
project. However, the basic groundwork for establishing an effective
monitoring program is described in the following discussion.
Initially, baseline groundwater quality levels will be developed to
better quantify present site contamination. The frequency, timing,
and protocol will be developed in a Quality Assurance Project Plan
(QAPP) with the objective of gathering representative data of
groundwater quality and its variation over a year's period. A
statistical test which accounts for the variation of the data will be
employed to measure compliance, and should be equivalent to or the
same as the "Cochran's Approximation to the Behrens-Fisher Student's
t-test". This test will be workable only if the approved sampling
protocol and analysis are strictly adhered to.
After baseline groundwater quality js determined and its statistic is
derived, subsequent compliance monitoring can be compressed to the
baseline statistic. For the subsequent monitoring events a new
statistic should be developed and compared to the baseline statistic.
If the new statistic exceeds the baseline statistic at the 95%
confidence limit there is high probability that a statistically
significant increase of a parameter(s) has occurred.
If any exceedance occurs which is statistically significant at the 95%
confidence limit, confirmation sampling and analysis should occur. If
subsequent sampling confirms a statistically significant increase in
the concentrations of the compounds of interest, a Remedial Action
Plan (RAP) will be developed over a limited period df time. While the
RAP is being developed, monitoring at an increased 1'requency will
occur. Based on the frequency of statistically significant increase
of the concentrations of the parameters monitored in the ground water,
EPA will make a decision regarding the need to implement a remedial
action. This decision process will be delineated in the RD stage. At
no time will discharges to the Maumee River exceed the State of
Indiana acute Water Quality Standards for the protection of aquatic
life.
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33
B. Western Portion of the Site
The primary components for the remedy on the western portion of the
site are:
o Access restrictions (fencing and deed restrictions)
o Groundwater collection and treatment
o Excavation of risk-based Area C for drum removal
i
o Incineration of drummed wastes
o Reconsolidation of soils/wastes on-site
o Soil cover
o Flood protection and wetlands protection
1. Access Restrictions
As the remedy will leave materials on-site above health-based
levels, access restrictions are necessary to ensure overall
protection of human health and the environment. Installation of
a fence at the site will deter trespassers and assist in
preserving the integrity of the soil cover. Deed restrictions
will be implemented to control future development and groundwater
use at the site.
2. Groundwater Collection and Treatment
The risk assessment identified the groundwater and groundwater
seeps discharging to the Maumee River as exceeding the State of
Indiana acute water quality standards. By installing a
groundwater collection system downgradient of the wastes, this
unacceptable discharge is controlled. The performance goals of
the collection system are to: collect groundwater prior to
discharge into the Maumee River and reduce infiltration into the
collection system from river recharge.
The fate of the collected groundwater will be determined during
the RD phase of the project. Based on current information, it is
not known whether treatment of the collected groundwater will be
necessary. If the combined groundwater meets the following two
criteria, monitoring rather than treatment would be acceptable
prior to discharging it to the Maumee River:
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34
o the contaminant levels present in the combined
groundwater flow meets the NPOES permit limits
established for a discharge to the Maumee River;
and
o the contaminant levels present in the combined
groundwater flow are" at or below those levels
achieved by the Best Available Technology (BAT).
If the contaminant levels present- in the combined groundwater
flow exceed these criteria, then groundwater treatment prior to
discharging to the Maumee River would be necessary. This can be
accomplished by an on-site treatment plant. The other option
would be using the POTW. Any discharge to the POTW would have to
meet the pretreatment standards of the POTW.
The removal of drums, a primary source for groundwater
contamination, may impact the length of time groundwater
collection and monitoring or treatment is necessary. Therefore,
a review program will be established during the RD phase of the
project. The purpose of this review program is to establish set
periods in time when U.S. EPA in conjunction with IDEM will
evaluate all the data pertaining to the groundwater collection
and treatment, or groundwater collection and monitoring, program
in place. Based on the review, U.S. EPA in conjunction with IDEM
can then decide whether to continue, modify or eliminate the
program in place.
3. Excavation of Risk-based Area C for Drum Removal
This component of the remedy includes the removal .of drums. The
area to be excavated is that portion of the site defined as risk-
based Area C. A total of 4,600 intact drums is estimated to be
contained in Area C. The removal of 4,600 drums represents a
maximum reduction in drums containing liquids in the western
portion of the site.
4. Incineration of Drummed Liquids
This component requires the drummed liquid wastes be incinerated.
The FS specified incineration being implemented at an off-site
RCRA compliant incinerator. The selected remedy however is best
configured to allow for the option of incinerating the drummed
liquids on-site or off-site, depending on which option is less
costly at the time of remedy implementation. The short-term
risks to the community during on-site incineration are
manageable, and balance against the risks to the community during
the off-site transport of wastes to an off-site incinerator.
-------
35
5. Reconsolldation of Soils/Wastes On-site
This component of the remedy requires the reconsolidation of the
excavated soils/wastes on-site. Although incinerating the
soils/wastes would provide for a complete destruction of the
organic compounds, the incineration process might result in a
potentially toxic ash. This ash would be redeposited on-site and
the inorganic constituents in the ash would present a risk to the
environment. Therefore, a minimal reduction in risk is obtained
by incinerating the soils/wastes. Incinerating the soils/wastes
would however result in a significant cost increase (5 to 7 times
the capital cost of Alternative 4C). A comparison of the benefits
(risk reduction) received from incinerating the soils/wastes to
the associated cost increase makes incinerating the soils/wastes
impractical. In addition, the other components of this remedy
ensure adequate protection is provided against the soils/wastes
reconsolidated at the site.
6. Soil Cover
After considering the remedial action goals for the site, the
other components in the remedy and the technical information on
the site, it was determined that a hybrid closure under CERCLA
authority is the appropriate closure for the western portion of
the site. This hybrid closure is basically a soil cover that
meets the following requirements:
o A compacted cover that is applied, compacted and
maintained continuously over any point of the area.
o The final cover shall have a slope of not less than 2%
and not greater than 33%.
o The cover soil shall be of a Unified Soil
Classification of ML, CL, MH, CH or OH, or other
material determined to be suitable.
0 The maximum projected erosion rate shall be 5 tons per
acre per year.
In addition, a maintenance program inclusive at a minimum of the
following, will be necessary for the soil cover:
o Inspections
o Maintenance of final cover and vegetation
o Maintenance of the final contours to provide for
minimum slope and no ponding of water
o Control of vegetation
-------
36
7. Flood Protection and Wetlands
This remedy requires the implementation of flood protection
measures as part of the site is located within the 100-year
floodplain. In addition, all construction activities under this
remedy should not adversely impact the two on-site wetlands. If
an adverse impact to either wetlands is unavoidable than the loss
should be compensated through enhancement of an on-site wetlands.
XI. STATUTORY DETERMINATIONS
U.S. EPA and IDEM believe the selected remedy satisfies the statutory
requirements to : Protect human health and the environment, attain
ARARs, be cost-effective, utilize permanent solutions and alternate
treatment technologies or resource recovery technologies to the
maximum extent practicable and provide the preference for treatment as
a principal element.
A. Protection of Human Health and the Environment
The selected remedy (Alternative 4C) provides protection of human
health and the environment through a combination of treatment and
engineering and institutional controls.
1. Municipal Landfill
The risk assessment indicates this portion of the site does not
.pose a threat through direct contact with surface soils or
migration of groundwater to the Maumee River. The primary focus
for this component of the remedy is monitoring future potential
risks associated with this portion of the site by implementing a
long-term groundwater monitoring program and providing a Subtitle
D - solid waste landfill closure (soil cover with flood
protection measures). This is the appropriate extent of action
needed at this time to ensure protection of human health and the
environment.
2. Western Portion of the Site
Excavation for buried drums and incineration of the drum contents
will provide a significant reduction in the primary source of
contaminant releases to subsurface soils and groundwater. The
groundwater collection system adequately addresses the currently
unacceptable groundwater and groundwater seep discharge to the
Mautnee River. In addition, the groundwater collection system
will adequately address any future migration of contaminants into
groundwater from the contaminated soils/wastes remaining on-site.
Tha collected groundwater will be properly treated, if determined
to be necessary, and discharged. The soil cover and access
restrictions, controlling future uses of the site, eliminate any
direct contact threat due to the contaminated soils/wastes
remaining at the site. The use of flood protection measures will
-------
37
ensure the contaminated soils/wastes remaining on-site within the
floodplain are not exposed, thereby eliminating any threats
associated with exposed soils/wastes.
The short-term impact of the drum excavation and on-site
construction are manageable and can be accomplished in an
environmentally sound fashion. Likewise, the off-site transport
or on-site incineration of the estimated 4,600 drums present
manageable short-term impacts.
B. Attainment of Applicable or Relevant and Appropriate Requirements
(ARARs)
The selected remedy - Alternative 4C - will meet all ARARs of Federal,
and more stringent State environmental laws. Table 14 presents the
ARAR requirements for the selected remedy. Two types of ARARs
addressed in Table 14 warrant further explanation: closure
requirements, and contaminant concentration limits in groundwater.
The closure requirements of the Resource Conservation Recovery Act
(RCRA) are not "applicable" because the wastes at the site were
landfilled before RCRA requirements took effect, and implementation of
the selected remedy will not constitute new land disposal of the
wastes.
Under the selected alternative, waste currently present on the western
portion of the site will be excavated to allow for the removal of
drums, the soil and wastes will then be reconsolidated in the ground
within the" area of contamination. This reconsolidation of soil and
waste does not constitute disposal of the material so RCRA Subtitle C
closure requirements are not applicable, but they are relevant. After
considering RCRA Subtitle C closure in place for the western portion
of the site, it was determined that it would not be appropriate based
on the characteristics of the site (See discussion in Table 14, Action
Specific ARARs, under potential ARAR: 40 CFR 264). Under the
circumstances present, it is more appropriate to pursue a "hybrid"
closure approach, similar to the approach outlined in the proposed
RCRA regulations at 52 Federal Register 8712 (march 19, 1987). While
RCRA Subtitle C closure is thus determined not to be an ARAR for the
western portion of the site, the selected "hybrid" closure combines
certain appropriate aspects of RCRA "clean closure" with appropriate
aspects of RCRA "closure in place" and a purge and treat system for
contaminated groundwater.
The eastern portion of the site primarily contains municipal refuse.
Closure under RCRA Subtitle D, as described in Indiana requirements,
is not applicable due to the dates the landfill was operated, but it
i.s relevant and appropriate and thus determined to be the action
specific ARAR for closure of this portion of the site. (See discussion
in Table 14, Action Specific ARARs, under potential ARARs: Indiana
Requirements: Solid Waste Management Permit Regulations).
-------
38
An evaluation of closure options is further discussed in the FS (pages
4-9 to 4-11).
Maximum Contaminant Levels (MCL) and Maximum Contaminant Level Goals
(MCLG) under the Safe Drinking Water Act are similarly not ARARs for
this site. As the affected groundwater is not a drinking water source,
MCLs and MCLGs are not "applicable" standards. Further, since little
potential for future use of the affected groundwater between the
source of contamination and the known projected points of groundwater
discharge into the Maumee River adjacent to the site, MCLs and MCLGs
are not "relevant and appropriate" standards. As noted above in the
Selected Remedy Section, SARA Section 121(d)(2)(B)(ii) specifically
recognizes that circumstances such as those at this site are
appropriate for application of Alternative Concentration Limits (ACL)
as determined by a process set out in RCRA regulations at 40 CFR
264.94. While this RCRA ACL regulation is not applicable (see closure
discussion above), it is relevant and appropriate at this site. The
process of determining the ACLs will take place during the RD.
C. Cost-Effect1veness
1. Municipal Landfill
The components selected represent the most cost-effecfive means
for addressing the long-term concerns associated with this
portion of the site.
2. Western Portion of the Site
The costs associated with the following components of the
selected remedy - Alternative 4C - are necessary to protect human
health and the environment:
o Access restrictions
o Groundwater Collection System
o Groundwater treatment, if necessary
o Flood protection and wetlands protection
The additional cost associated with excavating and incinerating
the drum contents from risk-based Area C ensures the drum
contents are 'permanently treated. Incinerating the drum contents
provides for a maximun reduction in the contaminants associated
with the drum contents. Permanent treatment can not be gained for
any lesser costs and the wastes of ;nost concern, due to their
toxic and mobile nature, are treated. Although Alternatives 4A
and 4B include drum removal as a component, they do not provide
as significant a reduction in the number of drums at the site. As
the increase in capital costs from Alternative 4A to 4C is only
slight and Alternative 4C achieves the most contaminant
-------
14
Review of Contaminant Specific ARARs
• . mum.!
iiiimi MI
folenlul !««« Illutl littilfioillt l»llllkll Ipiroirllll liicmilo*
IICHI.U itliUltliKklS " '""""" '" " ""'" •"""""•""••"""•""
lu.-.iMilio* jnl li(itii| Id |ICM| . .
•t .n *,itpid I lifuidirnli lor ICII (iirl 7II| iiliklitkit riiuirtiiili lir tliMii) ll tiftiriuil ir l filiillillf Crouiliitir jnticlloi li«ili kind on
..I..i,i |iouid>ilir inlidioi lut ICII irjulilid tliidirdi It til I litil Iklt ll irilullii ulrr npoiytti Hi ti rilioM ind itpiopiiilt
••ill, U(Ulii| |iou«< .ilif idliclio* U fyklli kiiltk ir Iki iitlruitil, kiciuu idiom il (hi till HI III lU CISCU
lljiliili. Kill U itlitliU lo» Ike itltirl mUlllllll ill coadilionii l»o.« talif ol
f rMuifliMll lfpl| ll riillill icllcni. fiouKmlif !»!• lurlui uli>| no inuim
fdjiclil ll Iki tudici mlir loifl ">< 'i
Idiot ixliiii tnlordilli tuiutii >hick
pridgJf kill* lipoiyfl ll
i> nk i// Hi lihoail Mlylnl (bit uilict il Iki (HI iigulilu lb» III Slid ll liliiil kn lulkoflullii li lii • kftfS i li br
toditi. Iki finliil illiuiliiit lit iiclm ilili IIU utllM lir ificllit fi(alriiuli. .. ill.
I hi linkup ol Idilil or mlnilii
|iound li Ike Hiuiii lint.
\. ii.l lii (iilufil Guifiliftii ind (kit ml ion ulikliikil fiilriiliiol lit^kirii il fOIK lull ial civil ijilillii III - friUfiUinl irtuidiiilt lill k*i» io ki ni lor
J,: PirliulKnl SlinJi/*i tlmliililkolk |iniril »< (ili|oricil|U' ll ipitllll irikililloM ir Ililllliotl. liukir|i li fOU.
Iki loalrol ll follulifili lii(kir|it Uli
fOKi. Iki itnliil illiiniliiit lif i«(l»ilrr ^gililf tlinludt in ilplicibli lor
lOAJundioi nlk ltii)ilir fuilil) tlinjirlt iliji ilindirlt lor i om« ijrudir, liltn\
lor Iki ilrin. Ifct lid liiikii|ii to Iki likiiol lilir Ouililf iriliru CD ki uti4 lor
Kiyill linr. (ilri(li«°/lrtili4 \itiiniit\il
li| llto kt litlkir|il Io Iki rim.
.1. i.ii..iu.t tiiit Id
lii lit Ml.II • fliiiiui CoMiiiiiM Imli SDVt Ml nil inloriiikU ilmfirlt lor . Il •• Jrou«l«ilrr li not I Irinling ulir tourci nor
|uklii >ilir i|tlt». «»rl Io 4iltioi>i II iait il km Ui foliiliil lor «n «»| Io hull*
(km ilinfirlt ihoiill kl ippliil il i «.y»lilr
lluiyf (nil lir Ui ik |ioundu|ir.T
I'HHIM.iO- RJIIIUI fonliiiaiol tiiil SOUI HCl(l lilt noiirnloiliikli klillk |oili . Il ll (rou>4>ilir It not I 4ri«li"i xlir toyrii nor
• I'. lot public mIn t,ilru. Hill Io Irlriiini 4oit ll km Ur |«lrn|u| lor yti tut Io luilio1
ll llxit tlindiidi tl>oy|d ki jppllid it i
cluoyl li>il lor Hit iMllo> fioyndtilir.
-------
Table 14
Review of Contaminant Specific ARARs
fillilill MM
Illun
MM SUUi
IlllHil mi
IppllcikU Ippnprliu
Ilicuttlon
li... In 1(1
(it Sii I ion 101 ml It HI 11 Illliill
Miii.1 lif flallilf Slindirit
Sill ullonil litiial lif nir. HI ti rilitml md
ipprepriili II Iki pollulml nillii md Ui
Il(knol8)» uplotld luii»l dunup in
(•IlKirtlli tiillir li Iti oni lor .kick Ikeif
il i ISPS
Sidioa III liliinil Ciiiiloai
lor Nilirfout (ir follalllll
(tliklltliii iilttioa ilindifdi lir kiiirioui luiirltll itniirli lir ipidllc louriii il
lit niiiiont. thi niiiiil idiom iif iplllc pllliliill.
rnvll li Ike iiutiom il lollulmlt md
•Hi lo itliiliti .kelker lit KESlUFi ippli.
li
»[5li«Pt in nil iimrillt ippllcibli li fldtu
idiom IKIUII URCll tlllt do not giniiilli
loalii* oni ol Ihi tpidlic tourd uliqoriii
rilvlilid. KISHlPi it I tholi iri iinirill)
rilninl mi ippiopriili txiuii IM ilindidt •!
lo»lrol in lulintid lor Ur iprilli( l|pi ol
loiuid rifgillid. fid ol I III Slid? iif U
rilixnl mi ippiipriili il i ipnilK pollulml
lor (kilt Ihiri it i ((SNAP it pritinl I* in nr
Itiltion.
-------
Table 14
Review of Contaminant Specific ARARs
folmllll MU • ItUII
&i;u RKUIXMIIS
. Hiii Omlilt Slindiidt
'.i (il l-l-i Cwinol Sludirdt tlmiirit ill mlir (mlllf tliidirdi lor
Ilii ofolidioi ol iiriom llriio mi
dni|>ilioit. lit till iiiCBit|ti 1* Ui
(limit llmr.
1.-' i;C M-l rropoud SlMdudi Slindirdt III «llir iliii ol III till
i.i.l ri>lrnUi«l riu|int INCUS)
vl I.I i 1 1 (ilrjdld Itfllld liounl.ilK n| ||
ditiiii)id lo Idi RIUIII linr
intM (iiouiHimxis
,.-, JllM|| |||j| (tldf
ii..jM .'1 (ilrj(Ui1 IriiliJ irounfojlir *if It
MU tlilul
IlllllOt Hi
iMilnoiili IpplUilli Iporoprlili
t i
(•mil ulir (uilllr tlindirdi iro In
litcrfpllii, til lor ipicillc mi, kill
UiKi ui oulildi* iwi il «lili|.
ipicillc tilun lor tpicilic mitlillkii ui co*tUini'
Ollllldl Ikt Ollll| IIOl).
li^vlrii miirirouti mtiri U out Iki lo foliitliUi
ippllcikli oliliui ulir (uilllr loidilloit
lor illkir o foliklo or 10 lidvtliiil IODIII
liqulrn iniirirouai mliri lo out Iki lo 'to ki
ippllcikli oliliuo « proiUi Ibi o,uinlitillii
iolornliot ilCltlirf to III |°ilt lor ditckirgit
U Iki limn linr.
Ii Iki condition! il Ilii till III IM
rifuiriunlt ol ((BCll I2l|d||?|ll||ii| mil
|fOg«d»llir it i politll 0' induilriil tourer it
ritlridid k| linlid iquilir piodudinilj, Ihni
ri(uirin«tl iro filiiml kul iol ippiopiuli.
It Iki coiidltloni il Iki till III Iki
M«ui(iifoU ol (UCll III|dl|}|ll||il| ind
Ifoundiilir it i lolikli «f irduilfiJl tourci it
ritlridid ky liitlid iquilri piodudiilfiil>r>l riiuirinili oil) kin lo ki nl lor
-------
Table 14
Review of Action Specific ARARs
MM Slllut
lltuil
Ipplldtlt
ItllKWl lid.
tpproprlilt
Ilimtloi
I i.lliu 4 «ilf, biiirdoui ditigitilioi it ool
ippropriili.
• n» HI; SliaJjilt lor gtninlod ol
VCIl jpid ?>})
riini jdiliUk ol gfniuloM ol kiuroui
li. Ittl lo ictmlilf »htUtf ifneuloi
uiKimU lilrnj la ffUCl* ulioak
iJuut .nil.
itoirilor riquiniinli
ifiililiiilioa ol mtli gtninllot icIUilir.
okUiiiM (fl II luioir, ntttl kiipii|, M
«ii ol uMloro iilioiil
foltiliillf Olliilt Idiom • It rtitdiil idiom (ould
mull ii Irtilitil tttidui drritd
riquiuiinli tould bt ippliciblt.
Oillll Idiom - II miln iri Kniqtd ontili n
put ol I CflCtl idion (hill rifuiriiinli •ouU
ool M ippropriili.
HIBt fitd 7111 ttUbhthrt (
lo.tiii.j (lit juatiiiiil ul Mudlout mill.
fctid In iJiolilf •Icliix Ihrii itpl| lo
Ihi Iriiipod ol tiiirdout tiiU il lukjid
la riquirinali Indudiog 001 rigujiliant,
•iiilitlii], ricord knpli|, Md
dii*up.
II oiliriilt nli|0fiud kiliudout until
lit lilt* olltili Ikiii Inntporl «ill t«
U
il.i .'(.I: Slindni)> lor linlitnl ol
KCfll jpid 7il| (tlitliiMt
lOir/ioi I In liulitol, tlonijf, tad
di>pu><( ol kiiKdont ntli. Held lo
iilttlilf ulio llfi« oiild II
lullrtli-J 4nJ Iti-jlnl (iiiui In
JiMl lotplml it dtlliid If
(Pit Olltilt Poli(r.
lit
Ontili iacinirilioii lill ki>t lo nil Ut
(ttliinut ilindirdt litltd i* 10 tl»
?ll.HO-2il.J5l. (hi rifuirtitalt mcliidt
•itli jail|til, •onilorm|l iitptdiont, ind
lloiufi tlindirdt. In li»l*trt lo
j|kn'0.lll lor t
•in hiNrdout >itlt i«(l«trilor.
Ill
Olltili i«unirjlio» ton Id bt (ontidtrtd i
Iruliml uoJii HCP.I ml >ould ht.i lo bi
toadudtd il I lullf (CHI-pirillltJ ml (oiplunl
olltili l«ilil|.
(tit ((P.CU idiiili il Hit tilt lontlilulit
Irilliml 41 dllioid vndir tdl 4nd IMrtbi it
tukjid U iCDI rtguliliont
11(111 rtguirtinlt lor Irtilitil ipplf il Ikt
•jilt it 4 ttm >4tlt 4>d Iht 4ili>il<
luntlilulrt lirjlirnl 4t drill** b| till.
•o No »• ontilt »ilir IrtiUial mil >oy|d titl li.»
ilili«ilio» ol 4 xtlt "tin Irttlirnl unit |IO(II
710.111 4»d «oulj not bi- itquliUJ undn Hl'(i« |.|
•oil hit ynilt itfy|4lid unJn Sulmn 10? o>
IO/ ll Hit llri« V4ln III.
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Table 14
Review of Action Specific ARARs
UM IltUt
Polinlill MAI
limit
int
Ipplldbli Ippropdili
till union
UK nil Slindirdt Itl tolld Mill
:;.-.4! liiilililt
ICIl Submit I ipirl I»| nliblltkii . , (tairil rt^lrfilMl Iir lind dltpilil
tuidilimi lor lind diipoul lidliliit Tir liilllllllit. Spidllc till* unit
11
NliilUllr
lonhiiirdout tolld •nil. Itudiil idlwl
•if lim •itlil li pltii, (oniolldill
•Hill, ir fitpott ol Iriilml rnlduit
o*tili. lud li diltriloi ko> dituii lid
diipoul ipplf lo (kit till. Itiiuti Iki
lilt kit Uo dlilid inn, Iki
ikjiidiritliit il Ihi iriit mid li kt
loniidntd.
inn III Ihi djorilf ol nlirltl
ii ill Hililiulr li
•lilt pilttnl ||)|. Ikirt il i i
diud ion!id Ihnil i Ml Iki ,
lor lifillioi ol lonliilnitlt lo Ihi
|rounj«lir ind lutiqutollt lo Ihi rlur It
{itiinlili) lolil fiouadillir dll(hii|i Iroi
In till ll lilrntlf mil
tlM|tii«l httill iiipil iiluti, Ihi nliMil i* IM
poilio« ol (III till It fiinlilf mniiiptl
liluli. Ikiiilirt, Sublllll 0 (lotuK
ii^uiiiiult in tppropriili lor Uit portion nl
Iki till.
llCllltl ll Ikf »olu» ol Klllfdoul tubtllnift in
Iki •Illll* lorlioa ol jht tile, Sublllll 0 SoliiJ
•nil linllill llouu it iilttinl lul not
ippropriili.
•< UN II). It) tiliinil Pollulinl
n ,!...,; lluinilio. 5,il,n
Ihit inlioo ol IM CVt ri|ulilit Ihi
litiluigr ol mlir iilo turliu «ilii
lofirt. Ihi iiiiful illiroilint ti| incliidl
Ibi 4ii(kt fitdiiiir riquiiiirnlt "ill >"" lo bi
•ll, illboutk Jdiiniilrilin riquiriiinlt ll
pirill) iiill not ki ii^ninJ biciuti ttlion it
ontili.
U III ID) Illluml Cuidilimi til
I. inf.: frtliijlirnl S
Iku IK I ion itliblitbit iidruliiil
tliojultlbulk {iniiil iKd (iliforiitll lor
IM (ouliol ol polliiljnU.I'ilibiroit i>lo
ruivt. ll.i itirdul illiroilint iir I
Ihi dilllijiqr ol Irulrd or unlrnlil
n lo Ikt lolil PUIH.
lltikir|i lo Pom lull ml null flit
through, Inlnlirinii, nlolilion ll tpiill
irohiillloni, li ilollllont ol Illll
IliiUlloni or oriimncit. fOI« thonU
'illkir ki«t in lH-t(fitni prrlriiUitl
proirji or km tiilluiml •iihjiint lo
ml Ihi rrqulitimli ol Ihi
prililllnnl iio|rio
mill.
ffllllllilnl nouirKmlt >ill hitf la bi ill lor
ill br in I lloodplim md i •rlli»il.
Ikil nr intotr Sri 1101 101 irrqunr.rMi iln,,.:ii,
•• pro 11 >ill It riiuiiid. Sn lodlion tpnilii
M*lt lor »illi«dt jnd
-------
Table 14
Review of Action Specific ARARs
rolmliil AIM
limit
UU SliUt
Itliunl ml
Uppllcibli Ippnpdili
lillultio*
ii.. liiiuiij Vjlir frolidioi
n. i.i (u
101 frolic I Ion ttrilifr i| iniiil !• MI touiui il ilr
iiitiio»t ixludini i«daif«lloi ie<
iiUdlion.
rri-Coitliudlw lull*
II flltillillf furion il Ihli (i»lt« It lo oiliin tontliudion
ilfill. C(«Cl» 1)1 |i| unfit ontili
lio« obliiniiif pirilll. Homir. (hit rnie«
•oulf III (iqillllilitl lo Igllill lubtlinliir
rtquirriintt mi londiliont il Ilii
•item.
lilor lourif iirill
fSl firtll
totlllllniill till iirill
Vlllilllll
ftliillillr
Nol nlldMli' l»oul< quir If dlf.iol md
ippioinilr ll Ikr polUhnl tullrd ind Iftr
licni>olo|t iiplt|fd dunni ilrjnup lif
••Ililiinlll tiillir It id pollglinl lat I hi
louili. flif bl iilittnl md ippiopnili lor
ioiimrilioa. Mould nol bl rilnml mil
ippioprjilt In iKiiijita, bfctutf louiirli.t
iiunliool it no I liiilii. 1i| bi < lo If
lontidind lor tolillli iiittiont lro>
lillilliom billutl ll Iliilllilr ol pollulinlt
ll till ll Iktll IdugM ll bl linlrollid.
-------
Table 14
Review of Action Specific ARARs
• ••••StMIMMMMIfltMllSt •••*••••• t )•••••
H ti4 HI;
t It It Jilttt ftlllt
loi
•!
hfuti
ICII dl'l 1») MtiUltktt flttlhliMI
lOIIIItt Iki 4itl9tll «l klllllW «ltlt.
liiciliil atiott iif lu«t (iitit U iliu.
loottlUilt «itdt, oi ditfoit ol liitliiil
ritidult OOtill. tilt (0 dllirtill kOi
iloiuir i*i dittotil ippl| It Uii till.
IKIUII Ui lilt kit lit iitliil iriit,
III iblfJllt/itlitt Ol Idf Kill 11(4 I* ll
Vrilif* I'm II) Ibi •ijonti it ulirlil
il kiiiriuui: |>| Itlilitilr i<'|t toluit ll
milt piiinlilll. lUit it > ii«i»l
dull I ml tc I Iliinls Ml Iki >almlli\
lit lifitlitit (I ion(i»i«inli U Iki
io< tutti)ucntl| l« Ut ci«ir It
kill trou»4»ilir 4it(liir|i l/ai
till ImluJim iolill«lia«| It
mil.
iidt III Foilioa li*mci,
" i driliui. liililii irotion.
lid tillli ' '-
lid i
coiodid tilllini ind ulnlili iidfrid,
d (onr/cip iiriiibilllf ol litt lk» Id
luril tykiollt ir llnr. ledudit pott
cldiurt iilidniid lod ioiitorii|
M|kril ilotiilll Uatll tklt llotuil Ikt
tultctl It lo it\i\* l«4 lltkiot I ilotufi
Uil cotkliil Ikt nlnnl ««« ifpioiiitli
lodloit il Sukllllt C Cliu Clouiit n4
Lklllli C tuOIII cliimt ii iilillu U
till ipielllc ri(«lrui«lt. Ikii it
tilliliit «idir C(ICl« nlborllf rilkir
KM
IllKUt U Iki »ltlifl poilltn ol Ut \tlt
ktcmti II CaitUiM kiuidaut >itli.
il Iki I(ti4iil ullo* (« (iio>i (K
llll»lll kill ill jpprcprlili It utlirn podioo
ll Iki till biduli ol till) noluit ol hiuiJuu*
•Itll fllllitl U Iki tuluif ol di •gnuip.l
Iliilill ui lid ll iiiontlrilid nit.
foliiUilli tppllnUi U Iki .iiltr* poll ion ol Ihr tilr, il
lit lltiimlin (onliinv fitpotil.
liliiiol kul «al ioergpclili lor Iht
10' I ion ll Iki till. Sll ll>l litlaktion t«lo. on
tt,itil cliiuri.
Il rtltllillli (01 Ikt ittlii* Kilio* ot tM titt mk ol Ut
illtinititit (MUiot • tioui\<«ilti tollillifn
t|i(c>. liduciaf inlilliiliOA kill «al ikm^r (!•<
lui or coil ol triunldltr (lllidion.
lulillrilion nil) k( llutkiif, folinliillj rrduii
Iki lokilili, liiuil|, ind •aluii ol Ui
(onliiiniili U Hit toilt. Ihiu lull it
loitiiilioa >ilk Iki olMr till tonilii
londiliom nil i 'h|b/ed cloturi irleunl l tut not ipproprlili lo iitlim
ol Iki till biciuti ol mil voluM ol
•ltd in* Ink il dtionilulid tiit.
-------
Iflil)
i uuie 14
Keview or Action bpeciric AKARs
lilliul u|
lluuitloi
Ill
:l lU Itll (rod! tllnJiiJl laf •lltlf
..I..II..J
Flttlll I nil
Jmril riiilriiMli It ISM It
•oililui (in il liri
In
l|tllit It ill
.1 ilk Itll. lijiiljlitii lo» •Kllil
li..l.ej 14 tJtJlJJ.it xtll llcljllllk
i|. Kii iiuliml,
fllltll tlldlJM II IJtlll, IHMIfUl tl
»iilt|it Uilll, till itlKitllii, til
llll|lll| tltllillltt Itl HOflKt II
klll/jugl Mill
IjKlUc ii(ulriinli It ISM iifilillMi.
Til
II III •orliri ei Itl ill!
lulit| (lltliuclill III tililliu •! inedul
KlUlt.
I .1. Kilrilllt
III
li ilii mil 110 Ihuutl III Innifi'liliM
.1 l.niiJ.» iildult
Irinltlii Ui limfoit if kiuij kiOtitt In \ JriiliK lll fldjl
siili n< linl iioillmlltt ml ri>li« il
inputtJ IM JiiiiliJ iiitjiili
fM irfilililrilir II MlulnMl iiiiuillill
"Ilk illll |t4 (Mil ll/ldlll I* iifli't "•
infill, lltiull "Ilk ilkif illnlil Idiril
Illldll, Hi ffl«Ul I (tllltl ft''" '»
ilili ritlii.
In
frtfiil iMulrn lili((Qiiriiitlil ririi. tinii
»dt
inoimmuumiMnis
M.U.JO.I m,i, i,,,,.,,.i r,o,..»
1 lilt DC- 1)
i. ,... i.licJ idrnliliulmi, tllilllli Mil lltlf Ikl fllulllloit IK
...... '.'.•. iJiuliliuliim il liiiiluui mil ill
i,..i> i^flu illt to o.ain inl Slitltilt jiillcilli It tuiiri ill liiril
•
In Itliril riinlriuili iilir ICII. Ilili
Hifrii IK Ilii liiliuilillot il
riiiilillin mill 1(11. filiril ICII iri|rn
•III iiily iltci ilili riiulniiili in
Ml tutllJllllllf |(ul«lllll.
In lilirilnllii nl
Illlylilotl filirll
lifyllliltll mill ICII.
SH iiiifiiuiioi iii iiiiuiiiin ridmi
ll(ull|iltli utStl ICII.
../, j-.lllulgll
In ilturi/rotliliivn il
kiuiJkut mtli 11 out t, iKil'i'l, Illfilll
In ililict.
i. I.,.i,final ttitil
I ..i '.ill
IK Iki iltiun il i
mill iiufiMiil liijlilf. liitdiij u Illll
ill Imi mint it iliu, mulllili
•illll, tl diifotr il liillinl iitllmi
mill. Hcil It tttnuni dun (Itiufi itl
Jiifuul iffl| It Hit kill, liuuti Iki
tilt: bit Iku litlml nut, Iki
ll>ll Jlllliilllt -jl III! ll»'« »ll II II
rinl iinr il Ui liil. tlifi liii (kit Im
iiiuil ill tllktul
Vitliit inn |l| Iki iiiniU il ulirlil
it HUlJuyll |]| IrMiill) l
«iilr inrtiolilll. ll.(ii it 1 ntiul
liuil itnliil Ibiuli |l| (In
lui iifiiliot il iinliiimtlt lo
tiuuii^iln uJ tuui(uinllf It Iki il«ir II
iiltmll h| lalil ifiiuiiJ.iln 4itlllf|l Illl
Iki tilt it lillinl) mil.
litliit inn III fill iti 4oii not fiiiril i
liiril iiiuliil l«inl| |)| (biiral Illlitl It
Ur Mtcl it flalrlliill jl| lliimjlf ll
It rilitlllllr
Clllyll IMuliniilt yulrr BCII Sullilli I lit
Illlllll l> lb| Ilium llfgilliriiltl HO if il
llitiiil il tenknuleai tuli! .(vlr
ui
Illutl. Ikl llliml ,. II,,. rn|,
•oilioii >l I hi nil it iniiiil,
llnilliri. Suklilli I rlaiuii ii
lor Ikii
Iriinif il Iki uluir i/ biuffiut
IU .Ml..
rlutr.
il
-------
Table 14 .
Review of Action Specific ARARs
Pllinlul MM
..: 11 Hi III :i in 11 mi
I. .iinjnr.il Finil ligulilioit
; i;.i i • > • i Piopotid r •
Illlllt
MAI lltlut
liltmil nl
Ippllciili Ippnprlili
liinjiiloi
li|ulrniilt lor I hi iloturt il i tolld i i flu) iivir (I Ui till. Ilopi liu Uii In
•itlt iiiigtiiol licilil|. Imdiil ulioil iiriiil i*d ilUoul diprittiai.
ill ln«i (iiln li ilm, (ootolidilt
•Hilt, ir diipott ol Idllirtl diiduil
oitllt. liid to it in tint tit* (lotuft ind
ditpotil ipplf It Init tlU. IKIUII Ui
till in l>o dltliil inn, Ibt
ctificltrltlict »l Ibi tun tut I* It
inn (II Ihr ti|irll> »l illirlll
il kiurtauii III Itlilitil) \n\t voluti il
•nlr pittmlijll. Ibid 11 I lUiill
4i>iil lonlnl l»riil| M| Hi polcollil
loi ii|dlioi il (oaliiiiiilt U Ui
troun4«lf< ml iuirquiill| U Ibi rhir II
(mini I |)| lolil tnuaittlu 4ii(tl(|i Irei
ki till It iilriiilf mil.
ludi* KIII III forlioi ill hi,t lo lollo. Ihi
iiliott lit dguid Ihil it mill Iriilnil tubtUalut riquiriatMt ol Ihit rult.
plot li coatUuclid.
i IM.i Pullulion Conliol loud
i.. li i Indutlnil Prildlliral ind «PO($
. ,i ..•.'
: l.t I 10 NCOCS Piml Ihit (gli io«irt Ihi ri(ulrnialt lor III - Ihi lubllinllii rigulrinnlt ol I kPD(S pruil
ditikirgi ondir la ladimi kPO($. Itudlil ill iplliliblf lo aitchirgn.
uliont iriull it i ditikirgt ol (roundnltr
oi Idilid |iou»J>ilfi.
.. i.* Illi Pffliiilirnl SUnil»4t Ihit tillion itllblithit piilllllllnl Ilickirgi II fOIH lull lol dull >ltt III • Pdldilital rriuidtinll nil hid lo bl ill lor
tljndudt lor IM innlfol ol polluliall Ihroutk. laltrllltnci, tiolllioa ol tpltll ditlkngi lo POIM.
diiihiioit into POIVi. Hit rnidiil ifohibiliont, or «iolilioai il loul
illnailitit ai| tailudi Ihi ditihirat ol liiilllloot or IfdiaiaClt.
Idilrd 01 unldilid \ti>Mt*tltt U Iht
kill Pttl«.
. .iilikli priiiulion lo likio lit • Ceatlmilio* icliont lould ginruU dutl to (kit
during tanttiuclioa lo lioiiiit lugllinl dgnUlron >og|d ipplf
dutl loiitiui
.. '..-. l.il II I.I / VIIC KUtioat lioi tilr iilmlirt lit • ad nil lould ginruli VOC Kittioit, to Ihrtr
.. i.-'. |.
-------
Table 14
Review of Action Specific ARARs
MM SliUt
lilmal mi
Piilmliil (Ml limit . litulriiiili Ifpllukli tfpfoirlili ilxuitlon
.. i ivilliJ I'll I
i.i 1:
Kill CooiUuclioi io< lk*nJon«enl
III
IOCAI fHOUIKMIIIS
(oil
lt\tn\tiHttXil irouAdxIir «i» II
It Ikl fDH
IlKkirii It fOIK mil it! HUH i tlililloi
el iMU'lc frtkltlllMi M lUlllllui
In
Int Ilickiriii ill! ki«i It toiilr .ilk
fiilii.l.ini (i(ulineili.
-------
Review of
e 14
on Specific ARARs
Minliil ««B
.. :tii:iiliiirjllilltl«l«llltt«il«IIM
.1 I u.»llllllOH ml IllOlllf III (Kill
IlKil
U«l Slilut
lillltmt ml
IppllCltll Ipproprlili Olicimlon
id (IB Illi linlion tlmlirli lir lupin!
.1 l..i.ijj»> titln Udliou nlkin lOt-tiir
ilu.:t|,liio (10 ((I 711.111111.
1(11 {fid nil itlikliikii riivlillom
loirriai Ihr dltpotil ol Mnilotji mill.
ftmliil idiom >i| lu«i mill U ilm. ,
uniolilili iitlit, ti diipou ol Iriilimf
oniili. Dili la lilmini ko»
loiilioi ilmlirlt ipplf It Ikll till.
fiilllli nil! II l>il|nrl. fiulrudrl,
iprrilrl, l(i< DliUlnrl II Kill I oilkouU
II Ntiiliil Iki tilt It locili< ijliiiii i llootfpjm. for jnr
iot tl I no litililj .illii IM
t, Ikii iiqtiiiiiinl (ill be rtliunl.
til
•„. luo /HI
frolnliei ol tnitntttti iptiill 1*1
uiliul
fioilii* It (inull ilU flit iti
lt SKIJII II ldi«i •<[ Hlicl
tr uiliul kibllil. Il ii
laJinguri ipidn or crlllcil tibilil 111
il liMdl'i I illll|lcil liiniuollltl 11
iiiulnl It ttlniai inj fotiikli iiiicli tl
Ihr fttftm idlon. II II l«il(ilii Ihil
Ihi pfojid "ill illrd i tpidrt. (Pi nil
rifutil « iloloalcil o|lnloii|IO| i|
iiillillM I'll '"Hi (o»nlUll(« iniiti
•III rr|loiil f« tlllit.
Sill II •iltji) Iki rmgr ol fidrrillr rnjjuynjj
III md I hi iliili ul't pi>
!ridf ill hi>r lo 6r
ullilltd. liitlint »C(ll tttmirnl .1,
lullill
.1.1 vildlili (ooidimlion *d
il (lib ini .IHIIIr «hr«
illicit (Mull U I tit loalnl or
loillifilioi ol i oiUril tlrin tr lo<| il
•ilrr.
lilinlu thilkir Iki idloi illl mull U
Ihr unlril ir loJIIlcilloi tl i lod| tl
•ilif. Includiig idiom Ikil flitkiiir
iilliilinli Ulo i MI tl nilir tr it(lii>ii|
ml (ontlrudlon ol I'm, limit, lie.
Cooiullilioa »llk flik ml klllllli Sir.lu
ri
fiolidion ol nillmdi. lo iiold idnrii
illrdt, xniilir pulmllil kn», ntloii
md fiiuni niluiil ml Irniluul >iluii.
tiliont »Jf oilur in >illmdl, oril Ii
illitl ippliiibililf.
II onilli nrHindi in lotl n I rimll ol
idiom. Ui Ion luil ti oiligilil k(
mlorinoo or cnilioo il oltrr •illinlt.
lit
Illiont ml) lilt pint m < .ilN«d.
Slflll HI Oil 181 HI HI 5
. I llul (ill
Hrqulilrt m| loniliudioa mlkin Ikr
li'inmri (oiplimir nib Itr tuktlmlur
poiliom ol idii irqulllion, rontullilin
diiii*| drtifn ml i oil I fuel I on milt Idr
Irpnlirnl ol Niluril Irtnuriit il
•ilium nil Itir t\tir it i i| ipi.,1.
-------
39
reduction, it was determined that Alternative 4C provides the
best balance between benefits achieved and cost.
Alternative 5 (A, B, C) is the only alternative besides
Alternative 4 to provide treatment of the waste materials on-
site. Alternative 5 (A, B, and C) includes incineration of the
contaminated soils/wastes as well as the drum contents.
Alternative 5A does not provide as much treatment as Alternative
4C but would cost more than Alternative 4C. Alternatives 58 and
5C provide treatment to areas relatively the same size as
Alternative 4C and the incineration of both drum contents and
soils/wastes from these areas would provide a greater degree of
cleanup. Although incineration would provide a complete
reduction of organic contaminants in the soils/wastes, the
potentially toxic ash from the incineration process would be
buried on-site. By redepositing the ash on-site, the collection
of groundwater and a long-term management program would still be
required for the site. In addition the cost of Alternative 58 and
5C is 5 to 7 times the capital cost for Alternative 4C. As
Alternative 5B and 5C do not provide a proportionally greater
reduction in risk to the environment for the additional cost, the
cost-effectiveness of these alternatives is questionable.
Although Alternatives 2 and 3'are less costly than the selected
remedy, the long-term uncertainties associated with solely
containment type remedies increases the potential for future
remedial action costs. Therefore, these alternatives do not
provide the most cost-effective solution to the site problems.
D. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
1. Municipal Landfill
The risk assessment did not indicate a need to pursue any action
on this portion of the site beyond long-term management. If a
need to pursue further action arose, the more permanent
solutions, such as incineration, would be too costly. This is
primarily due to the size of the area, and technical
uncertainties caused by the heterogeneous waste type in this area
of the site.
2. Western Portion of the Site
The selected remedy - Alternative 4C - focuses on providing
permanent and significant treatment for a portion of the wastes
of concern (drummed liquids). Identification, excavation, and
treatment of these wastes is implementable. The alternatives
providing a greater degree of permanence present significant cost
and'implementability issues rendering such alternatives not
practicable.
-------
• 40
E. Preference for Treatment as a Principal Element
1. Municipal Landfill
As the only action required as determined by the risk assessment
at this time is a long-term management program, treatment as a
principal element is not warranted.
2. Western Portion of the Site
Treatment of the drummed liquid wastes to reduce the toxicity,
mobility and of the hazardous substances in this portion of the
site is permanent. Therefore, the preference for treatment as a
principal element is met by the selected remedy.
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APPENDIX A
FORT WAYNE REDUCTION
RESPONSIVENESS SUMMARY
-------
FORT WAYNE REDUCTION
FORT WAYNE, INDIANA
RESPONSIVENESS SUMMARY
I. RESPONSIVENESS SUMMARY OVERVIEW
In accordance with CERCLA Section 117, The United States Environmental
Protection Agency (EPA) and the Indiana Department of Environmental
Management (IDEM) recently held a public comment period from May 4, 1988,
to June 7, 1988. The purpose of this public comment period" was to permit
interested parties to comment on EPA's Feasibility Study ('FS) and
Proposed Plan for addressing the problems at the Fort Wayne Reduction
site. A public meeting was held May 11, 1988, to present the FS and
Proposed Plan.
The purpose of this Responsiveness'Summary is to document EPA's responses
to comments and criticisms received during the public comment period. All
of the comments summarized in this document were considered prior to EPA's
final decision.
II. BACKGROUND ON COMMUNITY INVOLVEMENT
The EPA has been responsible for conducting the community relations
program for the site. Assistance was provided by IDEM throughout the
process.
A community relations plan was submitted and approved by EPA in May, 1986.
While developing the community relations plan, residents of the Riverhaven
community expressed concern over the quality of their drinking water. The
Riverhaven community is located in close proximity to the site and their
drinking water is supplied by privately owned groundwater wells. In
response to this concern, EPA sampled a representative number of private
drinking water wells within the community. The sampling results did not
show contamination to be present.
Prior to initiating any field activities, EPA and IDEM distributed a
"kick-off" fact sheet and held a Remedial Investigation (RI) "kick-off"
meeting. The primary purpose of the fact sheet and meeting was to provide
the community with information on the Superfund program, the site's
history, and the activities planned for the RI phase of the project.
During the RI the following activities were conducted to provide community
involvement in the RI/FS process:
o Distribution of Fact Sheet No. 1 explaining the results of the
initial field investigations and the subsequent field
investigations necessary to characterize the site
o Distribution of Fact Sheet No. 2 explaining the results of the
subsequent field investigations and the FS phase of the project
o Conductance of a public availability session to answer questions
on the RI report
1
-------
o Placement of a newspaper ad announcing the availability of the
FS and Proposed Plan and the date of the public meeting
o Distribution of a Fact Sheet summarizing the FS and Proposed
Plan
o Conductance of a public meeting to present the FS and Proposed
Plan as well as receive public comment
Approximately 40 people attended the public. meeting on the FS and Proposed
Plan. Several questions were asked at the meeting and the oral response
to each of these questions is provided in the official meeting transcript.
In addition, two formal comments were received during the meeting, both
from local interest groups. Five formal written comments were received
during the public comment period: three from area residents, one from a
potentially responsible party (PRP), and one from a group of PRPs.
III. SUMMARY OF SIGNIFICANT COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
The comments received during the public meeting and public comment period
are divided into the following sections:
o Remedial Investigation
o Feasibility Study
o Preferred Alternative
o Regulatory Issues
o PRP Alternative Proposal
REMEDIAL INVESTIGATION
Comment #1:
The report, in purporting to pinpoint the site history, contaminant
sources, contaminant transport routes, exposure pathways and public health
endangerment, does not adequately investigate and report on all potential
responsible parties, including generators at the site nor does it
adequately address the historic use of the river front land upstream and
downstream of the site as a long-time widely used dumping ground.
Comment #2:
Although the report mentions contiguous properties, including Dager Auto
Parts junkyard and Martin's Landfill, no data was gathered or analyzed to
characterize the contribution of these obviously contaminated properties
to contamination at or around the site nor was there an evaluation of the
historic aeria' photographs of these historic sources of contamination.
-------
Comment #3;
Although only limited off-site sampling ( upriver and upgradient ) was
done, it is significant to note that some "background" samples for lead,
antimony, and arsenic were higher than concentrations detected on site.
This data, even though not part of a comprehensive analysis of likely
offsite sources of contamination, supports previous comments about other
likely sources of contamination. More thorough off-site and upriver,
upgradient investigation should be done to more completely define those
sources of contamination that might otherwise be attributed to the Fort
Wayne Reduction site.
EPA Response:
The response to these comments is divided into the following sections:
o Potentially Responsible Party (PRPs) —Investigation and
Identification
o Remedial Investigation (RI) Report—Area Around the Site
Potentially Responsible Party—Investigation and Identification
The primary objective of the RI was to gather and evaluate that data
necessary to:
o Define the nature and extent of site contamination sources and
the potential routes of contaminant release and migration
o Quantify the potential impact and risks to human health and the
environment from the presence of or release of contaminants from
the site
o Define remedial measures that reduce the risk or threat posed by
the presence of or release of contaminants from the site
o Support the Feasibility Study (FS)
The RI report merely summarizes the technical findings of the RI. The
investigation and identification of all PRPs is not a RI objective.
Therefore, this type of information is not required to be in the RI
report.
The investigation and identification of PRPs is, however, very important
to the enforcement activities at a site. The Agency did perform an.
investigation and identification of PRPs as a separate activity outside
the RI/FS. The investigation of PRPs was accomplished by gathering as much
information as possible on those parties linked to the site. This
information included but was not limited to: knowledge regarding use of
the site, knowledge on site operations, knowledge and documentation on the
types and chemical composition of wastes generated by a party both in the
past and the present, as well as information leading to the discovery of
additional PRPs. From the information available, EPA identified the PRPs
-------
for the site. The investigation and identification of PRPs is an ongoing
process, as new information becomes available EPA will continue to
identify PRPs for the site.
Remedial Investigation Report—Area Around the Site
As stated above, the RI had specific objectives, and the RI report merely
summarizes those findings. It was not the objective of the RI to perform
an investigation on "the historic use of river front land upstream and
downstream of the site as long-time widely used dumping ground." This type
of investigation would require development of an area-wide program.
Superfund cannot conduct "area-wide" investigations unless such area is on
the National Priorities List (NPL). For this particular area along the
Maumee River, only the Fort Wayne Reduction site is on the NPL.
Although elaborate investigations of the "area around the site" were not
included in the RI, the Agency did consider the historic use of the area
when developing the RI workplan. To ensure a proper evaluation of the RI
data and subsequent identification of risk directly associated with the
site, the collection of numerous background samples was planned and
executed during the RI.
Although the commentor makes specific reference to elevated levels_of
lead, antimony and arsenic in upriver and off-site sediment and surface
soil samples, respectively, the following Should be noted:
0 It is true that due to upstream sources, it is very
difficult to determine the site's contribution to sediment
contamination. EPA thus focused the remedial goals on
limiting the site's contribution to the river. (See Comment #9)
0 While it is true that off-site surface soil samples for
some locations show higher contaminant levels than those
on-site, the focus of the selected remedy is not on surface
soil contamination. EPA identified only a relatively small
area on-site where a direct contact with the surface soils
is a concern. This area is the wire disposal area where
no cover existed and wastes were exposed. The main concern
at the site is the grbundwater contamination and buried drums
in the western portion of the site. Based on groundwater
quality in the off-site upgradient monitoring wells as
compared to groundwater quality in the monitoring wells
directly downgradient of this waste area, groundwater
contamination is clearly due to the on-site wastes.
Based on the conclusions reached by EPA regarding the commentor's points,
it is apparent that "background" conditions were taken into consideration
prior to reaching any conclusions regarding on-site and off-site
contamination.
-------
Comment #4;
Excavation procedures used at test pit locations during the RI appear to
have caused release of contaminants to the site. Technical Memorandum 10
explains that if intact drums were punctured during excavation, released
materials were not removed. The pits were simply filled in with the
leaking drum caused by EPA's contractors and allowed to remain in the
ground.
EPA Response:
Test pit excavation ceased when a drum was encountered. The test pit was
then backfilled with the excavated soil. If test pit excavation
procedures resulted in a leak or a spill from a drum, the spill was dry-
packed with an application of absorbent material prior to backfilling the
test pit with 'soil. In addition, absorbent material was applied to any
previously leaking drum uncovered by the test pit investigation. The use
of absorbent material was recommended to EPA by Waste Management, Inc.
prior to work initiation.
Comment #5:
The RI gathered very little upgradient groundwater data. Due to the
limited number of upgradient monitoring weJls, it is not possible to
confidently assess contribution of likely upgradient contaminant sources
to groundwater contamination on site.
EPA Response;
While planning the RI, EPA utilized a contractor with years of both
practical and field experience in hydrogeological investigations. Prior to
initiating work, EPA performed a thorough review of all proposed
groundwater monitoring well locations as well as the number of groundwater
monitoring wells to be installed. In addition, a thorough review was
performed by IDEM. The Agency believes the number of upgradient
groundwater monitoring wells and the areal coverage provided by their
locations was sufficient to assess if any upgradient sources were
contributing to the groundwater contamination at the site.
The RI data also confirms EPA's conclusion that the number and location of
upgradient wells was sufficient. The RI indicates groundwater
contamination to be primarily downgradient of the former pit area. The
well located directly upgradient from the former pit area was not
contaminated. Subsequently, EPA's conclusion that groundwater
contamination is due to the site rather than an upgradient source is not
unfounded. In addition, the test pit data indicating the presence of
drummed liquid wastes and contaminated soils upgradient from the
contaminated groundwater monitoring wells, further supports EPA's
conclusion.
-------
Comment #6;
While mention is made of a planned Corp of Engineers flood control
project, no information is present on its impact on the site, nor is any
COE data reviewed. Since any dredging or alteration of the Maumee River
near the site would have potentially significant impact on the site,
information on the COE project must be considered before a Feasibility
Study Report can be made.
EPA Response;
During the Feasibility Study, the Army Corp of Engineers (COE) was
contacted regarding their future plans on the Maumee River. A copy of the
COE flood control feasibility study was obtained and reviewed. In
addition, EPA worked closely with the COE when evaluating the various
options for site remediation.
Comments #7:
No explanation is offered on the significance of laboratory analytical
results reflecting false positive results in field blanks and laboratory
blanks.
EPA Response:
Each Technical memorandum (RI Report - Vol. 2) presented a summary table
of any data obtained during a particular field investigation. The data may
have been notated with the following qualifiers:
o B indicating that the compound was present in the laboratory
method blank or in the trip field blank.
o J indicating an estimated value less than instrument detection
limit, or greater than instrument detection limit but less than
the contract required detection limit.
The use of these qualifiers indicates the significance of false positive
results (i.e. field and laboratory blank contamination) within a
particular data set.
FEASIBILITY STUDY
Comment #8;
Claims were made that sediment were untraceable because the river has been
regularly dredged, yet the river has never been dredged.
EPA Response:
The RI incorrectly stated that this reach of the Maumee River had been
dredged. The statement was based on observations made during the field
investigation. Piles of what appeared to be river dredgings were
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noticable along the bank of the river. Subsequent conversation with the
COE confirmed that the river has not been dredged.
The conclusion that sediments were untraceable because the river was
regularly dredged was not made in either the RI or the FS reports. There
is no correlation between these two points. Sediments were not traceable
to the site due to a number of factors. These were discussed in detail in
Appendix G of the FS report.
Comment #9:
It was also indicated that the topographic relief varied, implying the
river was fast and sped sediments away, yet this area of the river is
probably the most sluggish and sediments would settle rapidly. Any
contaminated sediments downstream from Fort Wayne Reduction site are
candidates for removal.
EPA Response:
The Maumee River is a shallow, flat-bottomed, meandering river, typical of
the Midwest. In general, sediment load in the river consists of two
parts: bed load and suspended load. Bed load is supported by grain to
grain contact and suspended load is supported by the column of fluid. At
low flow rates, the suspended load more readily settles to the bottom to
become part of this bed load. During stonn events, velocity increases and
sediments from the bed load are lifted and transported. Larger grained
soils may remain on the river bottom and slide over one another in the
direction of flow. Thus, sediment transport is variable.
Sediment sampling performed during the RI indicated little bed load
adjacent to the Fort Wayne Reduction site. Sediments were generally less
than 6 inches thick, and were absent in some locations (see Technical
Memorandum No. 12, RI Report). Most sediment samples collected were a
fine sand with some silt. Another sediment sampling study (Maumee River
Bed and Embayment Sampling, ATEC, January 1988) reported that river
sediments were either gravel or sand. These data suggest that bed load in
the Maumee River is mostly sand and gravel, and that net deposition of
fine-grained materials along the Fort Wayne Reduction site is not
occurring.
EPA believes sediment contamination in the Maumee River is not associated
with the Fort Wayne Reduction site alone. The data do not identify a
discernable impact directly associated with the releases from the site.
Comment ?10;
It was stated the EPA couldn't use the Army Corps of Engineers sediment
Study. Why not?
EPA Response:
The COE data were used in the FS and can be found in Appendix G. The data
were used for comparison purposes only. The differences in sampling
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methodology and analytical methods as well as the seasonal variation of
the sampling events precluded combining these data sets.
Comment ill:
Tests showed positive PCS contamination in the aforementioned area,
warranting the presently effective fish advisory extending from the Ohio
state line to Fort Wayne, Indiana. If this contamination is not coming
from the Fort Wayne Reduction site, then where is its source? And no
matter what the source, isn't the EPA responsible for pinpointing cleanup?
EPA Response:
Although PCB contamination was found to be intermittently present in the
Maumee River sediments near the Fort Wayne Reduction site, PCB
contamination was present in Maumee River sediments upstream from the site
at levels equal to or exceeding the levels near the site. This indicates
that PCB contamination in the Maumee River sediments is a result of
several different potential sources.
The Agency agrees that implementation of a comprehensive (area wide)
program to investigate contamination in the Maumee River sediments^and the
various potential sources contributing to the problem is needed. However,
an area-wide program cannot be conducted under U.S. EPA's Superfund
remedial program. The Superfund program is limited to investigating those
sites on the National"Priorities List (NPL), like the Fort Wayne Reduction
siie. For this reason, the RI had to be limited to investigating and
idontifying only those discernable impacts directly associated with the
releases from the Fort Wayne Reduction site.
Conment #12;
Two points were raised about the activities along the Maumee River and the
use of the water for drinking purposes by the surrounding comnunities.
The consumption of fish contaminated with PCBs which are known to
bioaccumulate and the inability of the normal filtration process for
drinking water to remove PCBs are leaving the communities at risk through
these identifiable pathways of exposure to the contaminants being
discharged from the Fort Wayne Reduction site.
EPA Response;
The current data indicates that the concentrations of PCBs in the river
are below drinking water criteria at this time. In addition, the risk
assessment indicates that recreational use of the river, such as swimming
ana fishing, would not pose a risk to human health. These conclusions are
however based on the estimated river concentrations (see RI Report Vol. 2
- Technical Memorandum #11) during mean and low river flow conditions.
The presence of PCBs in the sediments can serve as a contaminant source
especially to aquatic organisms. Sediments contaminated with PCBs were
present upstream as well as near the site. The PCB levels upstream from
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the site were equal to or exceeding the PCB levels near the site. This
indicates that PCB contamination in the Maumee River sediments is a result
of several different sources and not just the Fort Wayne Reduction site.
Although EPA can implement a site cleanup that prevents the Fort Wayne
Reduction site from contributing contaminants into the river at
unacceptable levels, EPA's Superfund program can not address the other
potential sources until they are included on the NPL. It should be noted
however, that even if EPA could address all of the potential sources, the
fish and other aquatic organisms can not be "remediated". Therefore, EPA
encourages people to observe any fish advisory in effect.
Comment #13: ' . .
A request was made to reevaluate the river sediments and take action to
remove the contaminated sediments from the Maumee River.
EPA Response:
An evaluation of the Maumee River sediments was presented in Appendix G of
the FS. The commentor -is referred to this appendix for detailed
information of the Agency's evaluation and conclusions. The Agency
believes the evaluation was performed properly and a reevaluation of the
Maumee River sediments is not warranted. As a result the conclusions
drawn by the Agency remain valid and Maumee River sediment removal _will
not be included as part of the remedial action. -
Comment #14:
A request was made to consider using soil from a source along the river
that is currently being excavated as a part of the Maumee River Basin
Commission activity for use in the soil cover.
EPA Response;
Grain size distribution curves for soil samples received from the Maumee
River and the north embankment were reviewed (re. Embankment Sampling,
ATEC project number 21-75039, January 1988) . Samples were taken at cross
sections corresponding to river mile (RM) 131.0, 132.0, 132.74, 133.7 and
134.95. The Fort Wayne Reduction site is on the south river bank at river
mile 132.7. All samples obtained from the river were either sand or
gravel.These materials would not be suitable for the soil cover. Three
soil samples obtained from the north river bank (at RM 132.74, 132.0, and
131.0) are classified as ML (low plasticity silt). These samples were
collected from 1 to 2 feet below ground surface, and were described in the
soil report as containing "large amounts" of organic material. Although
the ML soil is suitable for the soil cover, it should be free of organic
material. Since the samples were obtained near the ground surface, the
organic material was probably roots from surface vegetation. Deeper
samples would need to be collected and analyzed to confirm the depth of
the silt deposit and determine whether the organic material is associated
with surface vegetation. If this is the case, surface could be stripped
and the underlying soil stockpiled as a potential cover material source
for the Fort Wayne Reduction site.
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Comment #15;
Several comments were received that addressed the issue of a complete
cleanup. The concern centered around the regular flooding of the Maumee
River and spreading contaminants during a flood event.
EPA Response*:
The purpose of the Feasibility Study is to weigh and balance the reduction
of risk and the costs of the various cleanup technologies. Often a
complete cleanup requires the removal of the landfill to another location.
During the initial FS screening, it was determined that undertaking this
type of an action at the Fort Wayne Reduction site would be excessively
high in cost. There currently is a lack of capacity in RCRA landfills to
handle this volume and there is a risk associated with transporting the
contaminated soil over public roads. For these reasons, none of the
alternatives developed for the Fort Wayne Reduction site would result in
complete cleanup. The alternatives were developed to achieve a reduction
in risk. We have chosen Alternative 4C because it provides adequate
reduction in risk at an acceptable cost.
The design criteria for the soil cover will specify flood protection as a
major component. EPA believes adequate sloping and revegetation of the
landfill will protect against wash out of the contaminants during a-
flooding event and reduce the risk of contaminants spreading downstream.
PREFERRED ALTERNATIVE
Comment #16:
It is understandable that 4C would be recommended by EPA because it will
take care of the major portion of the hazardous waste. The problem with
that alternative is that not only is toxic ash from the incineration going
to be placed in the ground, but the soil which is contaminated will stay
there also. I recommend that alternative 5C be selected so that the site
will be more thoroughly cleaned up.
EPA Response:
The incineration of the drummed liquids could take place off-site. If
this were the case, the ash would not be returned to the site. The
contaminated soil would be returned to the excavation and a soil cover
installed. If incineration occurs on-site the buried ash would be covered
by a RCRA type cap providing maximum protection from infiltration and
providing for reduced mobility of th« inorganics in the ash.
In either situation, the collection trench will ensure protection of the
river should any contaminants migrate to the groundwater and move towards
the river. The soil cover or RCRA type cap will prevent any direct contact
with the contaminated soils or incinerator ash.
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Selection of alternative 5C does provide a greater degree of cleanup but
at a substantially greater cost than alternative 4C. For this additional
cost there is not a proportionally greater reduction in risk to the
environment. Although a complete reduction of the organic compounds in
the soils would be accomplished through incineration, the potentially
toxic ash would be buried on site and still require the collection of
groundwater for an undetermined length of time.
If the ash was transported off-site to a RCRA facility, the management and
potential problems associated with the ash .is merely being moved to
another location. In addition, transportation of the ash to- a RCRA
facility would make the cost of Alternative 5C even higher. As Alternative
5C provides for the incineration of drums, soil and wastes only from the
western portion of the site, all wastes in the eastern portion of the site
would remain in-place. With these wastes remaining in-place, a long-term
management program would still be necessary at the site even if the ash
was transported to an off-site RCRA facility. For these reasons, a
decision was made during the FS that Alternative 5C is best configured
with the ash remaining -on-site.
Comment
I feel alternative 5B should be considered. I also feel the estimated
total cost for alternative 58 is an inflated figure. I believe BB'should
be studied more closely and the cost estimate adjusted down to a more
realistic figure. I also believe the estimated time to complete 5B should
be revised downward.
EPA Response:
The cost estimate for figure 5B, like all the other alternatives, is an
order of magnitude estimate. This means the cost estimate can vary from
+50% to -30% in accuracy. This type of cost estimate is typical for a
Feasibility Study. It is assumed that when you refer to this estimate as
being inflated you are comparing this to a normal construction of a
collection trench and slurry wall and standard excavation practices. Some
components contributing to the higher cost estimate for Alternative SB' are
the health and safety considerations for working in contaminated soil, the
uncertainty associated with the number of buried drums and the scheduling
of excavation and incineration around flood prone months. When working in
contaminated soils, the workers must be protected. Based on the field
investigation data, we estimated that a good portion of the work will be
done under level B and C protection. The uncertainty associated with the
number of buried drums and the extent of soil contamination is a result of
estimating these quantities from the test pit data collected during the
field investigations. Therefore, a conservative estimate was made on the
number of buried drums in order to develop the cost estimate.
The length of time required to complete 58 is based on several factors.
In the design process we have allowed for adequate review time by other
government agencies, in particular the Army Corp of Engineers. Another
impact on the schedule is the timing of the excavation and the
incineration. The excavation would proceed faster than the incineration
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so several mobilizations and demobilizations would be required during the
remedial action. The schedule also accounts for the potential slow down
of work during the flood prone months.
Selection of Alternative 5B would have provided a greater degree of
cleanup but.at a substantially greater cost than Alternative 4C. For this
additional cost Alternative 5B does not provide for a proportionally
greater reduction in risk to the environment. Although a complete
reduction of the organic compounds in the soils would be accomplished
through incineration, the potentially toxic, ash would be buried on-site
and still require the collection of groundwater for an undetermined length
of time.
Potentially Responsible Party (PRP) Alternative Proposal
Comment #18:
The first pathway of exposure as indicated by the risk assessment is
direct contact from the- waste materials. Direct contact with the waste or
leachate would be limited because of the odor and bad taste of the waste
and leachate and could be prevented by a fence and soil cover.
EPA Response: -
A soil cover will prevent direct contact with the waste but will not
prevent direct contact with the "leachate". As a point of clarification
the leachate is actually groundwater discharging or seeping out at the
surface rather than landfill leachate. The taste and odor of the
groundwater seeps would not necessarily discourage a one-time exposure,
while the exposed soil in the wire disposal area would not necessarily
have a taste or odor. Fencing the site would not eliminate groundwater
seep contact unless the fence extends into the river. This is not being
considered as it is impractical.
Comment #19:
The second pathway of exposure as indicated in the risk assessment is
groundwater migration to the-river. EPA's own findings state that current
releases are "order of magnitude lower than levels required to pose a risk
to human health through incidental ingestion or ingestion of fish".
EPA Response
The quote refers to statements made on page 5-6 of the RI and B-23 of the
appendix. We were specifically addressing the potential human exposure to
contaminants in the river, from fish ingestion and swimming in these
sections of the report. We were not addressing at this point the potential
aquatic impacts from the site. The quotation is misleading when taken out
of context.
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Comment
It appears from the text of the RI/FS reports that the ground water
collection and barrier system is required because of perceived present and
future risk of increased discharge to the river from leaking drums of
liquid waste. Once the EPA decided to remove these drums from the site,
then certainly this perceived risk of additional groundwater discharge is
likewise removed; however this risk reduction does not appear to be fully
considered in the FS selection process. Removing the drums containing
liquid waste removes the risk of future increased discharge and thus
removes the primary basis upon which the Alternative 2 groundwater
collection system is based.
EPA Response:
The risk assessment indicates the existing groundwater and groundwater
seep contaminant levels in relation to their impacts on aquatic life are a
concern. The presence of the drums and contaminated soil may represent a
source of loading in the future, possibly at levels greater than currently
detected. Removing the drums containing liquid waste does not remove the
risk of an increased discharge of contaminated groundwater into the river.
The drum removal will reduce this risk but not eliminate it. A risk may
still be present from contaminated soil reconsolidated on-site after
excavating and removing the drums. These soils may leach contaminants to
the groundwater. Although the reconsolidated soils may leach contaminants
to the groundwater, the only other options for these soils is treatment or
transportation to a off-site RCRA facility. Transportation to a RCRA
facility would only transfer the problem to another location. Treatment
could be provided; however, due to the types of contaminants present ,
incineration is the most viable treatment option. Incineration of the
soils was included in Alternative 5. A discussion of why Alternative 5 was
not selected can be found in EPA's response to comments #16 and #17. As a
result, the groundwater collection system is required to prevent any
groundwater from discharging into the river.
Comment #21:
The only remaining question relates to preventing any future migration of
the site groundwater to the river. The mixing zone was expressed as an
area of concern. We agree that to calculate the size of this zone is
.impractical; however to test for it (through sampling and analysis) is
not. The EPA collected river water .samples adjacent to the river banks
which showed no contamination. Considering the minimal groundwater
discharge to the river, no significant mixing zone would be expected. It
is clear from the EPA study that current and future discharges will pose
no health or significant environmental impact to the river.
EPA Response:
It cannot be concluded that current and future discharges will pose no
health threat or significant environmental impact to the river based on
the information presented by the commentor.. The levels of contaminants in
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the groundwater and groundwater seeps suggest an adverse aquatic Impacts
exists even though the area of Impact may not be a large area.
As a point of clarification the EPA did not collect river water samples at
any time during the RI. Adverse acute impacts in the river were assessed
on the quality of groundwater and groundwater seeps at the point of
discharge into the river. Adverse chronic impacts in the river were
assessed on the estimated river concentrations outside a mixing zone
during mean and low river flow conditions. Estimated river concentrations
were calculated from the quality of groundwater and groundwater seeps
discharging into the river. The commentor can find a detailed explanation.
of the methodology used in the RI Report Vol. 2 - Technical Memorandum
#11.
Comment #22:
The contamination levels in the groundwater and any impact to the river
will be closely monitored by the post-construction monitoring program.
The completeness of all aspects of this remedial construction will be
periodically reassessed as part of the monitoring program. Thus, the
mechanism is already in place to check for and address "threats of
release". Should unacceptable discharges occur in the future, which is
very unlikely once the m-ajority of the drums are removed, then specific
groundwater collection and treatment system can be designed.
r
EPA Response:
The purpose of the groundwater collection system is to prevent the
discharge of contaminated groundwater into the Maumee .River. The
groundwater contaminant levels measured during the RI were exceeding the
acute water quality standards for the protection of aquatic organisms at
the point of discharge into the Maumee River. Removal of the drums from
the site will not change this fact. Therefore the groundwater collection
system is necessary to prevent the release of contaminants at unacceptable
levels into the river.
Comments #23:
We believe more credit should be given to the existing clay cap on the
eastern portion of the site, thus reducing the amount of additional fill
required.
EPA Response:
The soil cover as described in the FS for the eastern portion of the site
meets the State of Indiana regulations for Subtitle D closure of a solid
waste disposal site. The approach taken in the feasibility study
(i.e. 18" of soil and 6" of topsoil) was conservative for cost-estimating
purposes. After the site is regraded, two requirements need to be met:
o The cover must be 2-feet thick
o The soil must meet specified classifications
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It must be adequately demonstrated that these requirements are met after
regrading the site, or additional cover material will be required to meet
the regulations.
Comment #24;.
A total 2- to 3-foot thick top cover has been a standard top cover for
sanitary landfills in Indiana, a 2-foot thick clay cap, topped by 6-inches
of topsoil is currently required by Indiana .Solid Waste regulations. Due
to the lack of health or environmental impact from this port-ion of the
site, we see no need to depart from this standard. In Attachment B, our.
evaluation of water balance calculations contained in technical Memorandum
No. 7 shows that there is very little if any infiltration reduction to be
gained by increasing the top cover thickness. Further, the slopes are
relatively gentle and additional erosion protection will be installed
along the side slopes. Thus, the expected soil loss due to erosion is
minimal.
EPA Response:
The main reason for selecting a soil cover for the eastern portion of the
site was to prevent direct contact with and washout of the buried waste.
In addition, surface infiltration will be reduced and compliance wfth the
State Subtitle D - solid waste landfill closure requirements will be
achieved.
The erosion control plan for the site is a maximum 1 (vertical) to
3 (horizontal) slope and a polypropylene mesh stapled into the embankment
to hold soil in place until vegetation is established. At present, the
slopes adjacent to the municipal landfill are 1 (vertical) to
5 (horizontal) or less, which meets the grading requirement. The slopes
are poorly vegetated in some areas and erosion gullies were observed
during the RI. The erosion control plan will eliminate such erosion
gullies, and continued site inspection and maintenance will assure erosion
does not occur in the future.
Comment #25;
Based upon our review of the RI/FS, we did not find any other direct
calculation or specific reasoning to justify a thicker cover. We
therefore recommend that once the site is regraded that the existing
thickness of the top cover be confirmed on a grid pattern and additional
fill be added as needed to achieve a total 3-foot thickness, which is
6 inches more than required to account for thickness variations between
probe checks.
EPA Response:
During the remedial investigation field work, the cover was probed on a
grid (100 ft X 100 ft). The cover thickness ranged from 4 to 24 inches
with an average thickness of 17 inches based on 36 samples. We did not
specify that a new cover was required for the eastern portion of the site,
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but only that the final cover meet Indiana Subtitle D closure requirements
for a solid waste landfill. Therefore, EPA considers the commentor's
proposal to be a technically acceptable approach to completing the final
cover on the eastern portion of the site.
Comment #26;.
Exploring for buried drums is a very difficult process, involving
balancing the need for accurate information versus minimizing site
disruption during the exploration phase, when equipment resources are
limited. The amount of information gained at this site wiH make it
difficult to obtain an accurate construction bid to perform the drum
excavation and handling work. It will be difficult to establish a drum
handling protocol, particularly a demarcation between crushed drums which
stay in place, and intact drums, containing liquid waste, which must be
removed for off-site treatment or incineration. This additional
information is important as drum excavation and disposal represents a
large percentage of the estimated cost to complete the project.
We believe a more selective approach should be taken with a respect to
drum excavation, realizing that isolated drums will not have a significant
impact on the river water. This selective approach would concentrate on
exploring for substantial "pockets" of drummed liquid waste, and not
performing extensive excavations looking for a few isolated drums.
A physical probing program should be developed during the design phase.
Based on the site conditions it is likely this probing could extend at
least four feet into the waste materials. Excavation across the site
could proceed in four foot lifts with the probing proceeding backhoe
excavation. Once the bottom 4-foot lift was reached, further vertical
excavation would proceed only if metallic contact was made. This probing
would reduce the chance for drum rupture by the backhoe and reduce the
extent of required excavation.
EPA Response:
The areas delineated as containing drums and the estimated-ftumber of drums
present was based on the test pit data. The procedure used ta "estimate
the numbers of drums on-site involved extrapolating information from
several pits over an entire area (see Appendix B of the FS Report). It is
likely that some areas have concentrated numbers of drums (e.g. the barrel
pit area), and a probing program may be useful in identifying these areas.
However, physical probing is not a viable method for this site. This is
due to the following factors:
o The need for ve,*y close probing spacings to ensure drums
would not be missed.
o The inability of physical probing to differentiate between
concrete and dri-irs. This particular site has construction rubble
and debris scattered throughout the excavation area.
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It might be possible to use a vertical gradient magnetometer survey at
close grid spacing (i.e. 10 feet) to identify areas of buried metal.
These areas would be excavated and drums removed; metal would also be
removed. Another magnetometer survey would be conducted and areas showing
anomalies would be excavated. This iterative process would occur until it
was demonstrated that no magnetic anomalies exist within the excavation
area.
Comment #27;
The EPA's findings indicate there is not current health or environmental
harm resulting from the ground water discharge. We believe that the
threat of any such future harm will be removed when the drums are removed.
Further, the EPA has found that Area A is providing the majority of the
contaminant loading to the river, even though it is insignificant
(Technical Memo No. 11, Table 6A, and Figure 3). Therefore, it is our
opinion that drum removal, soil cover, and fencing satisfy the remediation
criteria (ARAR) and no further ground-water collection and treatment is
warranted at this time. In fact, construction of EPA's proposed
collection and barrier trenches will adversely impact the site physically
will delay construction, and will reduce future options at this site.
EPA Response:
the RI findings indicate there is a threat to the environment from
contaminated groundwater discharging into the river. Removing the drums
from the site may reduce this risk but does not eliminate the potential
risk associated with the contaminated soil replaced after excavation.
Therefore, collection of the contaminated groundwater will be necessary to
ensure protection of the river. Groundwater collection would have to
continue until it was demonstrated that a "natural" groundwater discharge
would be protective of the river.
Construction of the collection trench and barrier wall will not adversely
impact the site. As a part of the remedial action, the area will be
revegetated and the slopes stabilized for flood protection. This action,
although adding to the length of time for construction, is required to be
protective of the environment, and in no way reduces future options at the
si te. .
Comment 328:
In order to evaluate the effect of contaminant loading reductions which
would result from drum removal, a site-specific contaminant transport
model was used. Results of our modeling effort show that once contaminant
loading is reduced or eliminated, contaminant concentrations in the
aquifer will attenuate fairly quickly rather than become worse with time.
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EPA Response:
The conclusion of the commentor's contaminant transport model is that
"once contaminant loading is reduced or eliminated, contaminant
concentrations in the aquifer will attenuate fairly quickly." This
conclusion -is questionable for the following reasons:
1. Alternative (4C) does not eliminate the entire contaminant source by
drum excavation and removal. Drum excavation eliminates drum rupture
(assuming that all drums are found), reducing further soil and
groundwater contamination. Contaminated soil is stilV redeposited
on-site and will remain a potential source.
2. The use of the model is questionable due to both the lack of
explanation given for some chosen assumptions and the
inappropriateness of some assumptions used in running the model. The
specific problems and questions with the use of the model are as
follows:
o The use of a constant aquifer thickness of seven feet may not be
appropriate. The aquifer material and the saturated thickness
varies from approximately 5 feet to 10 feet on the northern
boundary of the western portion of the site (See Figure "2,
Technical Memorandum 7). Both groundwater discharge and
contaminant loading calculations presented in the remedial
investigation report (Technical Memoranda 7 and 11) allowed for
these variations by choosing individual saturated thicknesses
for each flow tube.
o The use of a 1.6 percent south to north slope chosen for both
the groundwater surface and the confining layer surface is not
explained.
o Attachment C, paragraph 2, states that chloride and TCE were
modeled "using randomly distributed concentrations of each
constituent across the site immediately following the removal of
the contaminant source." Once again, contaminated soil is not
removed under implementation of alternative 4C. The modeler
does not state the basis for assuming that the "randomly
distributed concentrations" are representative of concentrations
left in the soil after drum removal.
o Attachment C did not provide an explanation or basis for how the
following model assumptions were arrived at:
"Number of particles"
Retardation coefficient calculations are not ^included. The
organic carbon content and bulk density of the materials
from which the retardation coefficients were calculated are
not included. A Re of 2.0 for TCE is too small for the
flood plain soils of the surficial aquifer at..fort Wayne.
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A larger retardation coefficient for TCE will cause an even
longer attenuation than 100 years.
Initial average area! concentration for chloride and TCE
dispersivity: Current modeling techniques almost
universally make transverse dispersivity 1/20 of
longitudinal dispersivity. A transverse dispersivity of
17 is too large compared to the longitudinal dispersivity
given of 37 feet. A smaller transverse dispersivity will
increase attenuation time greatly. The source or
explanation for both of these numbers is not-given.
"Uniformly random but average value" for initial vertically
mixed concentrations" for chloride and TCE.
Linear equilibrium isotherm adsorption for TCE.
Comment #29:
We recognize and appreciate the goal of achieving a "walk away"
remediation. Because of the proposed soil cover and drum removal
operation, we believe that this goal will be achieved at this site,
without the need for ground water collection and barrier system. -At
worst, should subsequent monitoring show that these ground water systems
are required, they could then be installed, resulting in a phased
approach. This phased approach of addressing ground water after
contaminant source removal has been standard operating procedure on CERCLA
sites, such as Conservation Chemical of Illinois, CAM-OR, and Seymour, to
name a few local examples.
EPA Response:
The soil cover and drum removal will not be protective of the environment
without the groundwater-collection system. If after an interim period of
collection and treatment groundwater meets discharge criteria then a
monitoring of the collected groundwater would be acceptable.
The phased approach implemented at the Seymour site resulted from a need
to perform an emergency removal action to eliminate the direct contact
threat at the site. The soil was removed over 75 percent of the site to
1 foot depth. Fifty-five thousand drums and 1,000 bulk tanks were also
removed. The extraction wells were installed to clean up and control
groundwater until further action could be taken.
Obviously, the objective of this phased approach was to address the more
serious risks posed by the site while an investigation of the long-term
risks was conducted. The RI at the Fort Wayne Reduction site identified
all of the risks associated with the site based on the information
available. The FS subsequently identified the ways in which those risks
could be addressed. The selected Alternative 4C contains only those
components necessary to comply with SARA and ensure protection of human
health and the environment. Implementing anything less than Alternative 4C
would compromise the protection Alternative 4C provides to human health
19
-------
and the environment. For these reasons, EPA believes a phased approach of
the remedy is not appropriate for this site.
Comment #30;
Although not required by the risk assessment and the ARAR's presented in
the FS report, we do believe it would be advisable during excavation and
drum removal in Area A to construct a sump(s) and pump off the more
contaminated ground water. This will significantly hasten the attenuation
process. We estimate about 50,000 gallons -can be effectively withdrawn
during the construction process. Further ground water collection is not
warranted at this time.
EPA Response:
Alternative 4C does not call for any excavation below the water table and
groundwater extraction should not be necessary. It has not been
demonstrated that a 50,000 gallon groundwater extraction well will clean
up all contaminated groundwater at the site, or how the one time
extraction of groundwater in the excavated region will clean up the future
releases by replaced contaminated soil.
Comment 131; -
In order to construct a slurry wall and interceptor trench along the
northern boundary of the site, along.the flood plain, it will be necessary
to construct a level berm, at least twenty feet wide to facilitate
construction. The slurry wall construction procedure recommended in the
FS includes bulldozer mixing of the slurry. This requires a minimum
horizontal berm width, alongside the trench, of 25 feet, and preferably
50 feet. This will require either substantial filling of the flood plain
and/or removal of the trees along the river bank. Also, this will impact
the existing wetlands as shown in Attachment D. Removal of those trees
would significantly reduce the capacity of the site to withstand flooding
and would promote erosion of the site. Note that during the 1982 flood,
almost the entire site was underwater.
The slurry trench and interceptor trenches must extend through waste. The
observed character of waste at this site can make excavation very
difficult and the.variable porosity and pore size may make it impossible
to develop the required filter cake for slurry wall construction. In
addition, constructing the slurry wall would preclude recharge from the
river. This recharge from the river has the beneficial effect of
"flushing" the soils between the trench and the river.
EPA Response:
In the feasibility study, it was assumed that a 30 foot wide, level
alignment would be necessary for slurry wall construction. Some cut and
fill construction will be needed to prepare the site, especially just
north of the former barrel pit area. However, the overlap quantities for
regrading are not estimated to be "substantial" (1100 cy estimated).
Trees will be removed and tree roots grubbed to allow the trench to be
20
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installed. Impacts to the wetlands will be minimized using erosion
controls and scheduling construction at low flood frequency time periods
(see "Flood Control and Wetlands," Chapter 4 of FS Report). Trees will be
removed only along the slurry wall path, not between the slurry wall and
the river. The remaining trees will provide erosion stability along the
river bank.- Following construction (estimated to take 2 to 4 months), the
area will be immediately revegetated and stabilized with polypropylene
matting. Construction could be staged so that all work in a given area is
completed and the area reseeded before progressive grading and trenching.
Neither the slurry trench or groundwater collection trench will be placed
through areas of waste.
The primary purpose of the slurry wall is to prevent recharge from the
river and any dilution effect river recharge may have on the collected
groundwater, as dilution is not considered an acceptable form of
treatment.
Comments #32:
The proposed interceptor trench construction procedure utilizing a
biodegradable slurry is very new technology. Insufficient data is
presented to judge its feasibility, particularly since it will extend
through waste. A significant concern is tfiat obstructions in the waste
will likely be encountered such as drum, timber, and rubble which were
prevalent in the test pit excavations. Slurry trenching procedures cannot
effectively penetrate such obstructions and typical standard open hole
excavation techniques must be utilized to remove the obstructions.
Considering an average depth of excavation of 15 to 20 feet and 1:1 side
slopes for OSHA trench safety considerations, the top width of such an
excavation would be at least 30 feet wide. Considering the steep slopes
and wooded vegetation along the trench alignments, such an excavation
would be very difficult and disruptive.
EPA Response:
Use of a biodegradable slurry trench was proposed for installing the
groundwater collection trenches because no dewatering or shoring costs are
incurred and personnel do not have to enter the trench. This method was
used successfully in California to contain a diesel fuel spill; the
collection trench was placed to a depth of 50 feet. Additional testing is
needed at this site during the Remedial Design phase to ensure
compatibility between the slurry and the waste stream. If an adequate
slurry cannot be designed, then a more conventional type of construction
(e.g. shoring or trench box) would be needed.
Comment 133:
If ground water purging were necessary we would agree that either an
interceptor trench or well points would be the design of choice. However,
either system would provide a sufficient cutoff and a barrier wall would
not be necessary. Our calculations, presented in Attachment B, indicate a
radius of influence of about 50 feet for the trench and this the amount of
21
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recharge from the river could be reduced as desired, by moving the wall
away from the river.
Considering site-specific constraints on trench construction, we believe
well points are more appropriate at this site. Such wells can be located
to pump from" specific areas and can be located far enough from the river
to reduce its recharge impact. In fact, by suitable well location,
recharge from the river may be encouraged for its beneficial "flushing"
impact.
The hydrogeologic conditions are conducive to well point construction
since the upper soils are permeable and the ground water level is less
than 25 feet deep. It is true, as the EPA states, that the amount of
water pumped will be limited by the saturated thickness of the aquifer.
However, the saturated thickness at this site is well within standard
operating well point range. Calculations presented in Attachment B
indicate an expected pumping rate of 0.008 gpm per lineal foot of pumping
which is very similar to the proposed trench. Well point construction is
far less disruptive than the proposed interceptor trench construction. It
will not require filling the flood plain, destruction of the wooded bank
and wetlands, and will allow pumping not only along the bank, but also
from suspected centers of contamination.
While we do not believe such a ground water pump and' treat program is
necessary, the trench and well point options remain viable should future
conditions warrant.
EPA Response: .
The comment states that a 50 feet radius of influence was calculated for
the collection trench and the amount of recharge from the river could be
reduced, as desired, by moving the wall away from the river and that a
barrier wall would not be necessary. Although the commentor's statement is
generally true, the statement does not take into account several site
specific conditions; such as the minimum amount of room in which to move
the trench away from the river in the vicinity north of monitoring
well CH04; or the probable existence of higher permeability "sand
stringers" next to the river'acting as preferred pathways for increased
river recharge into the trench.
Although the use of well points may be feasible (if appropriately field
demonstrated) for use at the site, the use of well points was not
considered in calculations and cost estimates in the Feasibility Study for
the groundwater collection system for the following reasons:
1. A maximum individual well point yield ranging from 0.04 to 0.34 gpm
was calcuiated assuming a saturated aquifer thickness of 10 feet,
100 percent efficiency which means a drawdown at the well of
6.7 feet, j range of hydraulic conductivity of 1 X 10 -3 to 1 X 10 -
4 cm/sec, and an effective well point radius of 0.5 feet. It was
also assumed that steady-state conditions were reached after 1 year
of pumping. The amount yielded by an individual well is very small
given the above-named assumptions. Of these assumptions, site
22
-------
specific conditions may yield an even smaller pumped volume per
minute from each individual well point:
o Saturated thickness, at the time of the investigation, varies
from about 5 to 10 feet. Seasonal variations may decrease
saturated thickness, and therefore well yield, to an even lower
value. Eventually the aquifer may "dry up" during some
seasonally low recharge periods. Operation and maintenance is
high for a system that is periodically "sucking air." As a
result increased operation and maintenance costs and performance
problems may be encountered.
o The radius of influence cannot be accurately calculated for such
a dynamic system. Because contaminant source material remains,
capture of all contaminated groundwater before it reaches the
river must be assured.
For these reasons, it was determined that a collection trench would be a
more "robust" or certain and dependable method of intercepting and
collecting all contaminated groundwater that is being generated at the
Fort Wayne site.
Comment #34: -^
A significant advantage of proceeding with initial construction, without
the ground water collection and barrier systems, is that only minimal
construction will then be required within the flood plain. This will
reduce, and possible eliminate, the very time consuming Corp of Engineer
permitting process.
The Corps of Engineers permit process will require review of final design
drawings, will likely involve their input into design modifications,
resulting in redesign. This could easily delay the project by twelve
months or more.
EPA Response;
As previously stated, the RI.findings indicate that a release of
contaminated groundwater above the ARAR (acute water quality standards for
the protection of aquatic life) is occurring. Therefore the collection of
groundwater on the western portion of the site is necessary to mitigate
the release. The optimum location for the groundwater collection system
is downgradient of the waste area and subsequently construction within the
floodplain cannot be avoided. As construction within the floodplain is
considered part of the on-site remedial action for this site,
Section 121(e)(l) of SARA would apply. This provision specifically states
that: "No Federal, State or local permit shall be required for the
portion of any removal or remedial action conducted entirely on-site,
where such remedial action is selected and carried out in compliance with
this section."
Although obtaining a permit would not be required, compliance with the
substantive portions of a "permit" is required. Therefore, consultation
23
-------
with those Federal and State agencies responsible for reviewing plans
involving construction within a floodplain is also unavoidable.
Comment »35;
It is important to note that the residual ground water migration to the
river will be naturally air stripped once it enters the river. This will
remove the volatile organics as demonstrated by the EPA river sediment
sampling which show little or no volatile contamination from past seepage.
Thus, with respect to the volatile organics, the natural flow regime
accomplishes the same purpose as the collection and treatment system.
EPA Response;
The "natural flow regime" is considered a form of dilution. Although State
water quality standards allow for use of a mixing zone when assessing
chronic impacts of a discharge, thus some dilution is considered
acceptable, they do not allow use of a mixing zone when assessing acute
impacts. Even though river quality is not projected to exceed the chronic
water quality standards outside the mixing zone, the groundwater and
groundwater seeps entering the mixing zone are exceeding the acute water
quality standards for the protection of aquatic organisms. Therefore,
groundwater collection is necessary to mitigate this problem.
REGULATORY ISSUES , -
•^^^» w
Comment #36:
I would like a copy of how much money the EPA collects from the owners of
the landfill and generators of the waste. If ths owners of the property
do not have to pay for the cleanup then they should be denied permits to
operate and expand landfills and dumps.
EPA Response:
EPA is currently negotiating with the PRPs on the costs incurred as a
result of past response activities at the site (<;.g. RI/FS) and
performance of the site cleanup. As negotiations are not finished, a copy
of how much money EPA collects from the PRPs is unavailable at this time.
When negotiations are completed, EPA will either have a settlement with
the PRPs, will issue an order compelling cleanup, or will proceed with the
cleanup using Superfund dollars. If a settlement is reached with the PRPs,
EPA and one or more of the PRPs will sign a consent decree. The consent
decree will define the terms of the settlement (e.g. How much money EPA
will collect on past costs? Will the PRPs perform and pay for the site
cleanup?). Prior to filing the consent decree in court, EPA will provide
an opportunity for public comment on the consent decree. At this time, no
information would be available on the amount of money EPA collects from
the PRPs. If EPA had to perform the site cleanup with Superfund dollars,
EPA could pursue a cost recovery action in court against the PRPs. The
outcome of the cost recovery action would determine the amount of money
EPA would collect from the PRPs.
24
-------
As pointed out above, EPA is currently negotiating with the PRPs to
perform the cl.eanup at the site. EPA may or may not reach a settlement
with the PRPs. EPA does not currently possess the legal authority to deny
any of the PRPs a permit to operate and/or expand another landfill based
on their willingness to perform the site cleanup.
Comment #37;.
Due to economics, a partial cleanup will allow the "cleanup" of additional
sites, but then the Fort Wayne Reduction site will continue to contaminate
the environment. It seems reasonable to expect that once a superfund site
is cleaned up (even if partially), it will be a long time before the EPA
will consider this site for a subsequent cleanup.
EPA Response:
Although EPA's preferred alternative will leave contaminated materials at
the site, implementation of the various components in EPA's preferred
alternative will reduce contaminant exposure to levels protective of human
health and the environment. As a result, EPA's preferred alternative
achieves the level of protection intended for a final cleanup. To ensure
EPA's preferred alternative remains protective of human health and the
environment, EPA is committed to meeting the following requirements of
SARA Section 121 (b)(2)(c):
o The Agency shall review the remedial action no less often than
each 5 years after the initiation of the remedial action to
assure that human health and the environment are being protected
by the remedial action being implemented.
o In addition if upon review, it is the judgment of the Agency
that further action is appropriate, the Agency shall take or
require such action.
Comment #38:
It is our understanding that the owners of the landfill are responsible
for the cleanup. If this is not the case please let us know. If they are
indeed responsible, we feel that no permits should be given for them to
continue operation at any site they own until this one is cleaned up
completely.
EPA Response:
As specified by Section 107 Ca) of CERCLA, not only owners but also
operators, generators and transporters can be held liable for the cleanup
costs at a site.
As stated previously, EPA is currently negotiating with the PRPs to
perform the cleanup at the site. EPA may or may not reach a settlement
with the PRPs. EPA does not currently possess the legal authority to deny
any of the PRPs a permit to operate and/or expand another landfill based
on their willingness to perform the site cleanup.
25
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INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
IW1CY A. AAALOLEY. Commissioner
103 South Meridian Street
P.O. Box 6015
Indianapolis 46206-6015
Telephone 317-232-6603
Mr. Valdaa V. Adamkus
Regional Administrator, Region V
U.S. Environmental Protection Agency
230 S. Dearborn Street
Chicago, Illinois 60604
Re: Record of Decision
Port Wayne Reduction
Fort Wayne, Indiana
Dear Mr. Adamkus:
The Indiana Department of Environmental Management (IDEM) ha&T
reviewed the U.S. Environmental Protection Agency's draft Record of
Decision. The IDEM is in full concurrence with the selected remedy
which includes:
Construction and maintenance of a fence around the site, except
along the river, to protect the soil covers and restrict access
to the site.
Limiting present and future use of the site as well as the
installation of wells on the site through deed restrictions.
Installation and maintenance of a soil cover in compliance with
Indiana Subtitle D - solid waste landfill requirements over the
eastern portion of the site to prevent erosion resulting in
direct contact with, or washout of, wastes to the Maumee River.
- Monitoring groundwater on the eastern portion of the site to
ensure migration of groundwater to the Maumee River does not
pose a threat to the river*
- Installation and maintenance of a groundwater collection system
on the western portion of the site to protect the Maumee River
from the migration of groundwater into the river at unprotective
levels.
Provisions for the removal of contaminants from the collected
groundwacer through treatment.
- Ezcavselon of the area defined as Area C in the western portion
of the sice Co remove an estimated 4,600 drums containing
liquids.
Installation of a vertical barrier to minimize Che inflow of
groundwater and migration of contaminants.
An Equal Opportunity Employer
-------
Mr. Valdas V. Adamkus
Page Two
- Incineration of liquid drum contents.
- Reconsolldatlon of the soils and waste excavated during the drum
removal.
- Installation and maintenance of a soil cover In compliance with
the "hybrid" closure requirements outlined In the Record of
Decision Summary on the western portion of the site.
- Provisions for and maintenance of•flood protection measures for
that portion of the site within the 100-year floodplaln.
Compensation for any loss of wetlands due to remedy construction
by enhancing an on-slte wetlands.
Our staff has been working closely with Region V staff In the
selection of an appropriate site remedy and Is satisfied the selected
remedy adequately addresses the protection of public health, welfare and
the environment with regard to the Fort Wayne Reduction site.
Please be assured the IDEM Is committed to accomplish cleanup of all
Indiana sites on the NPL and Intends to fulfill all obligations required
by law to achieve that goal.
Sincerely,
Nancy A. Maloley
Commissioner
-------
DATE
l:.:.iDl3iri- :n Case «f.cS6-72
Letter concerning site
Sij^ary of Ysnt Pesi^ence Well
',:**.:?.: :•:" >'r:v2te Weils
Prcii.TiM.ry assessment
Djnciusirn ?n Well Data
P.RP yosiTion -:n H«»sr Saaaies
Sucerv:sicn of SCfl Sanpiing
!f!rsr:t:cn to Ssaole ail
monitor Wei is
of Contaminant Levels
Seciwents 4 Biota of
St. rtary's, St. Joe's 4
Kauasee Sivsr
en Prea Uells and
Duzpinc rtisrory
>r/crc;eo logic fissessasnt ano
Closure Plan
•Qf'er to '.'sect! ate on
RI/FS Conssnr
Ssttleren: Negotiation Letter
Mor« .-iin f.:r Djraunity
Ccrisent Crcer
^KG
re: River Uiceninj
c: 5v BHen Co.
SCS v.Tnoaas, et al
R.waitar-itesionai Recycling
c:aH-£coi.£ Envir.
DLaws-Pollution Cr.tr i.Sysress
'.Ca?.csr:ian-ftl le>£o. S2. cr'Heaitr,
fiStJonrrScoi. 4 £nvir.
DHosxins - USE^a
J. Snooes - 5Cfl
ft.st.Jofin - tcoi.4 tnvir.
UScnubert-Irdiana '^as;e Sys.
OHudaK-U.S.Oeot.of Int.
PR? Protss: Letter res
106 Orser
JStrecxer- I.S.B.H.
fttec - 'Srilio I Weaver
C. -.owan - SCfl
C. Le*an - SCfl
J.Ma«:ncrne - CDs
T.Daggec: - U=£Pfl
CPo;t-rifiRZfl Eng. Co.
JPerns:ein - SCA
oo/co/oo
75/01/09
33/02/22
34/11/09
85/02/25
35/04/16
85/05/00
£5/07/05
85/07/19
S5/OS/CO
85/08/21
85/09/10
S5/V9/13
29
5
14
22/02/a
32/07/25
a4/Oc/!4
84/07/27
3f/03/20
7
6
i
1
«
1
13
256
2
3
19
4
-------
V.ftoaakL-s - ii=E?jj
DflTE
85/03/20
PSGES
8I/F3 ani Cozsaniiy SeUnons
?9cuesz to Conduct fi!/.=5
Seef.r,: wit.1! private citizen
Healtn fiss-ssaent
U3t:sr 10 i?95:cant3 wi:.i
prmte «ei! saspiing r=suics
ar.a
Oefe/yss Actions to -haiis; in case
CcHwants OR ?I/'F3 Worv. Plan - Phase I
'F:nsi work Plan - RI/F5
Site Safety 3'an - Seopnysical tork
CflPP
Site ;a:2tv Pian - Phase I
Sesecjvss ts c;:csnts -sra rscitutarMations
on t.ie SI/?= tei-R Plan for tfte "crt
Uayne .?sd'jc:::n Site
rficre ?ie»3. - r-scsvai of D
i»!/F5 it»;a:;ar>r of iisrx
wcr- -Isn Sevis;;n .^erusst »:.
SJ/Fs >r;i^ II
GV-? - Pnass II
'FoKcH-MC t-: Phase II .PI aork 0!
J. Bernstein - £CA
C. Lynch - I.S.B.H,
flct. Dir. , Off. ofrealtfifiss. -HMS
Q-'cian - USEPfl
Grille 4 Weaver - nTEC flrsoc.
SCfl v. Thoaias. et al,
SCfl v. Thcisas. et al.
Srigalauski to Favero-fPfl
CH2.1 Hill
TSU
CH2B Hill
CH21 Mill
Faverc to Srid3lauski-£Pfl
H. Suddy - L'S£°fl
USSPS
t-SS*
<"V-;-M u. 1 |
u* -<^i ni A »
C.6n;alau5Ki - Kas:a ffiat.
85/10/09
85/12/16 -
86/01/17
86/02/10
86/02/10
86/05/09
86/06/08
86/06/30
86/08/07
86/08/15
86/08/20
66/08/29
86/09/04
86/09/08
86/09/13
27/01/iJO
87/03/05
87/03/27
2
2
3
5
8
£6
58,
3
84
10
125
£5
4
1
14
20
,.a
2
site Safety a.'an - Phese II
CH2?! Hill
87/03/27
14
-------
~^ ,,....
"•••':'"'-•*' I>CTC
Lh' - rW.-iz
:.-.33t
«sw 4 -:«==>• - u~-->S S7/OVOO
t? rsnasnts-en Phase II Sucsy - i.!S£"ft • 87/05/05 *
3! Work Pian
*5!'K Plan SevisioR ^ecussi *2 'J?£.rA 97/07/20 I;?
-------
PoOS NO. 1
FIChE/F«i€ PftGES DflTE
TITLE
fiDMNlSTRftTIVE RECORD INDEX UPDflTE
Ft. Hayne Reduction Site
Inoiana
AUTHOR
RECIPIENT
DOCUaENT TYPE
13 64/12/11
1 87/03/27
1 87/04/14
2 87/12/31
4 86/01/06
1 88/01/15
1 86/01/15
Waste Management, Inc.
consents on HRS package
Letter requesting tne
addition of Martin's
Landfill to the Fort
Uayne Reduction RI/FS
Letter responding to
the Stumps' request
Letter requesting Indiana
State .flRfiRs
Generic PRP Notice Letter
sent to 6F Goodricft Co.,
New Haven Mire & Caole Co.,
ToWieia Corp. and Waste
flgt., Inc.
Letter transnitting 31
Report to repository
Letter transnitting SI
Report to repository
Schuoert of Waste Hgt. Inc.
Uyer, USEPfl
Correspondence
Stuiips of the haak Walton League ftdamkus, USEPfl Correspondence
Constantelos, USEPfl
fldankus, USEPfl
Bade, USEPfl "
•88/01/E2 ---- Senertc-Lstter-to PRPs-
informing tnea of date
cnange for PRP neeting
oentioned in Notice
Letter of I-6-J8
38/02/24
88/03/15
68/04/07
Letter conveying Indiana
Stiie
Letter to US Deot. of
Interior froa US£?fl
re: flauciee River Sea i cents
Letter :o USEPfl fna
L'S Dept.of Interior
re: Wauaee ftiver Sediuents
flaloley, IN Dept.of Env.Mgt.
Dikinis, USEPfl
area residents, Correspondence
Stuaps
IN Dept.of Env.Kgt. Correspondence
see title field Correspondence
Sasior, USEPfl
Sasior, USEPfl
Scnorle, USEPfl
Allen Cty. Public
Library
New Haven
Pub. Library
PRPs
Correspondence
Correspondence
Correspondence
ftdasKus, USEPfl Correspondence
Hudak,US Correspondence
Dept.Interior
Hudak, US Dept. of the Interior 6aoe, USEffl
4 fifl/04/26 Seneric vRP Notice Letter Gaoe, USEPfl
PRPs
Correspondence
Correspondence
1 88/03/00 «! rtvaihailiry Sessions Gasior, USEP'fl
Fact Sheet
-------
:>ce Ho.
)s/07/83
r!O.£/FiW3£ PAGES MTE
ADMINISTRATIVE RECORD INDEX UPDATE
Ft. Wayne Reduction Site
Inoiana
TITLE
scheduled for Ft.Hayne
Reduction site Fact Sneet
AUTHOR
RECIPIENT
DOCUMENT TYPE
4 86/03/00
2 88/02/02
£ 87/02/06
87/12/21
2 88/04/07
85/01/00
8 68/02/31
21 84/07/12
Fort Wayne Reduction
Superfund Site Fact Sheet,
Winter 88
Agenda arid sign-in
sheer for 2-2-88
PftP meeting
Action memo requesting
supplemental RI/FS funding
Action caeno requesting
suppieoental RI/FS funding
Notes for Ft. Uayne
file re: State support
of RI/FS
USEPd resoonse to H«S
comientors
Worn Plan Revision Request
No. 3 for Ft. Uayne fll/FS
Hazard Ranking System
Pacxace
6asior, USEPA '
Constantelos, USEPA
Constantelos, USEPfl
Carny, USEPA '
USEPA
CH11 Hill
Hopkins, USEPA
15 87/12/00
88/01/07
68/05/0*
11 36/05/04
Detsrainatton of ARARs
Keceoiai Investigation
Report
Feasioiity Study Report
Proposed Plan
CH2fl Hill
Chin Hill
Dill Mill
Carney, USEPfl
Fact Sheet
. Meeting Notes
AcaoKus, USEPA teaorancua
Adaakus, USEPA Hefiorandun
file
Hesorandua
Otner
Other
Reports/Studies
Reports/Studies
Reports/Studies
Reports/Studies
Reports/Studies
-------
ADMINISTRATIVE RECORD I.\DEX u-^DnTE
Ft. Wayne Rec uct i on Sits
Ft. Wayne. Indiana
PSSES DnTE TITLE AUTHOR ' RECIPIENT- DOCUMENT TYPE
5 -SS/04/££ Letter -to U.S. Mew Haven wire Carney, U. S. EPS Correspondence
EPA from PRPs and Cable Co. ,
re: Comments SCA Services of
on the RI Indiana, Tokheim
Report Corp. , Uriiroyal
Goodrich Tire Co.
3 OS/O5/04 Letter to U.S. Gade, U.S. EPA Hudak, U. S. DCI Correspondence
Dept. of
Interior from
U.S. EPfl re:
Maurnee River . . ••
Sediments
4 8S/O5/05 Special PRP Gade, U.S. EPfl PRPs Correspondence
Notice Letter
14 88/O5/24 flgenda and Meeting Notes
Sign—in sheet
for S/£4/aa
PRP meeting
11 8S/O5/11 Written state- Stump, Ft. Wayne Other
rnent given at Izaak Walton League
public meeting
£1 33/05/11 Transcript of Accurate Reporting Other
public meeting of Indiana
1 83/05/17 Public comment Baxle, resident Other
on FS and
Proposed Plan
1 aa/OS/OS Public comment Martin, resident Other
on FS and
Proposed Plan
1 88/O&/06 Public comment VanDaele, resident Other
on FS and
Proposed Plan
-------
/OS PuDiic com merit ."x=w Haven Uiir-a
on FS «nd
Proposed Plan
anC Cc.Die LJO. j
Potistch Corp.,
Rsa Magnet. Wire,
SCfl Serv i ces of
Indiana, Tokheirn
Corp. , L/niroyal
Goodrich Tire Co.
3S/OS/07 Public comment SCfl Services of
on FS and Indiana
Proposed Plan
33/06/07 Public comment Precision Litho
on FS and Don flyres Pontiac
Proposed Plan
Sa/08/OO Record of
Decision and
Responsiveness
Summary
Other
Other
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