United Slates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R05-89/092
June 1989
Superfund
Record of Decision
MIDCO I, IN
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T DOCUMENTATION i. REPORT Na 2.
PAGE EPA/ROD/R05-8 9/092
J Subtffl*
2RFUND RECORD OF DECISION
st^Smedial Action - Final
»
ling Orgdntarton Hunt end Addieee
%
xlng Organization Maim and Adfraaa
..'Environmental Protection Agency
M Street, S.W.
.lington, D.C. 20460
X Recipients Acceewon No.
5. Report Date
06/30/89
&
a. Performing Organization Rept No.
10. Pro|ect/Taak/Work Urrt No.
11. ContracK.C)orGrant(G)Na.
(C)
(0)
13. Type of Report t Period Covered
800/000
14.
mentary Notee
:t (limit: 200 wonte)
1IDCO I site is a four-acre, abandoned industrial waste recycling, storage, and
sal facility in Gary, Indiana. The surrounding area is partially rural, including
ids. Residential neighborhoods lie.to the west, south, and east, with some
2nts living as close as 900 feet from the site. Twelve drinking water wells have
»ified within approximately one mile of the site. The Calumet Aquifer, one of
jor aquifers underlying the site and providing water to these wells, is highly
e to contamination from surface sources. Recycling, storing, and disposing of
:rial wastes began at the site sometime before June 1973. Within a three-year
i, the site owners accepted and stockpiled approximately 6,000-7,000 55-gallon
containing bulk liquid waste, and 4 bulk tanks, each 4,000-10,000 gallons. The
Lty closed in December 1976 after a fire burned approximately 14,000 drums of
ral waste. Operations resumed in October 1977 under new ownership. By February
:he new owners abandoned the facility, leaving thousands of drums and waste
:als unattended. By January 1980 an estimated 14,000 drums were still stockpiled
3. In June 1981 severe flooding caused water in the area to drain west into a
uoring city; contact with the flood water reportedly resulted in skin burns. In
i:PA initiated a surface removal action which included removing extensive surface
Attached Sheet)
•ent*n*ly«i» a Dmcriptora
ord of Decision - MIDCO I, IN
st Remedial Action - Final
caminated Media: soil, sediment, gw
Contaminants:VOCs (benzene, toluene, TCE), other organics (PCBs,
als (chromium, lead)
itjficn/OpwvEndMi T«re»
PAHs, phenols),
iroup
lil^^^Brant
19. Security Cl«»» (This Report)
None
20. Socwity CUu (This Pto«)
None
21. No. of P«g»»
181
22. Price
19.18)
SM //utructforu on «•
\Jr IIUNAL rUHM 111 (4-/ I)
(Formally NTIS-35)
Department of Commerce
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(4-77)
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EPA/ROD/R05-89/092
MIDCO I, IN
First Remedial Action - Final
Abstract (continued)
wastes', an underground tank, and the top one foot of contaminated soil. Because these
activities did not address the contaminated subsurface soil, sediment, and ground water,
EPA has initiated this first remedial action to address the above-referenced
contaminated media. The primary contaminants of concern affecting the soil, sediment,
and ground water are VOCs including benzene, toluene, and TCE; other organics including
PCBs, phenols, and PAHs; and metals including chromium and lead.
The selected remedial action for this site includes excavation and treatment of 12,400
yd of contaminated soil and subsurface materials using a combination of vapor
extraction and solidification/stabilization, followed by onsite disposal; excavation and
onsite solidification/stabilization of approximately 1,200 yd3 of contaminated sediment
in surrounding wetlands; covering the site in accordance with RCRA landfill closure
requirements; ground water pumping and deep well injection in a Class I well if EPA
grants a petition to allow land disposal of waste prohibited under RCRA; if a petition
is riot approved, ground water will be treated using air stripping and a liquid-phase
granular activated carbon polish system to meet EPA requirements (LDR treatment
standards), followed by deep well injection or reinjection into the aquifer; ground
water monitoring; and implementation of deed and access restrictions. The estimated
present worth cost for this remedial action is $13,989,000, which includes annual O&M
costs of $525,000, if ground water is treated; or $10,728,000, which includes annual O&M
costs of $188,000, if ground water is not treated.
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DECLARATION FDR THE RECORD OF DECISION
Hicks I
Gary, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Midco
1 site in Gary, Indiana, developed in accordance with CERdA, as amended
by SARA, and, to the extent practicable, the National Contingency Plan.
This decision is based on the administrative record for this site. The
attached index identifies the items which comprise the administrative
record upon which the selection of the remedial removal action is based.
The State of Indiana is expected to concur with the selected remedy.
pPfiCRIPl'lON OF THE SFTFX7HU REMEDY
This is the final remedial action for the Midco I. A surface removal
action -including removal and off-site disposal of wastes in drums and sub-
surface tanks and the top one foot of contaminated soil was completed in
The final remedial action will treat the highly contaminated
face soils and materials that remain at the site and that are
ributing to ground water and surface water contamination near the
site, and will treat the highly contaminated ground water near the site.
These actions will address the principal threats posed by the site which
include public health risks due to future development of the site, public
health risks due to off-site migration of ground water and, public risks
due to air emissions, and environmental impacts on surrounding wetlands.
The major components of the selected remedial actions include;
On-site treatment of an estimated 12,400 cubic yards of
contaminated soil and waste material by a combination of vapor
extraction and solidification/stabilization followed by on-site
deposition of the solidified material. The soil vapor extraction
system will be considered successful when volatile organic
compounds are reduced to levels that will pose no health threat
and allow solidification/stabilization to proceed successfully.
The solidification/stabilization operation will be considered
successful when it reduces the mobility of contaminants so that
leachate from the solid mass will not cause exceedance of health
based levels in the ground water.
Excavation and on-site solidification/stabilization of
approximately 1200 cubic yards of contaminated sediments in
surrounding wetlands;
Installation and operation of a ground water pumping system
to intercept contaminated ground water from the site;
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Installation and operation of a deep, class I, underground
injection well for disposal of the contaminated ground
water; or if a no-migration petition is disapproved by
U.S. EPA, installation and operation of a treatment system
for the contaminated ground water to remove hazardous
substances followed by deep well injection of the salt-
contaminated water; or installation and operation of a treatment
system for the contaminated ground water to remove hazardous
substances followed by reinj action of the salt-contaminated ground
water into the Calumet aquifer in a manner that will prevent
spreading of the salt plume;
Installation of a final site cover satisfying RCRA closure
requirements, if applicable or if considered relevant and
appropriate (the quality of cap required will also depend
on the results of tests on the solidified material) ;
- Restriction of site access and imposition of deed restrictions as
appropriate;
Related testing and long term monitoring.
The groundwater treatment and underground injection portions of the
remedial action may be combined with the remedial action for Hideo II.
In this case, the combined treatment constitutes an en-site action, for
purposes of the Off-site Policy.
DECLARATION
Die selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate to this 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 technologies to the maximum
extent practicable.
Because this remedy will result in hazardous substances remaining onsite
above health-based levels, a review will be conducted within five years
after commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
Signature of Regional
Date
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I. GARY. INDIANA
I. SITE NAME. LOCATION AND DESCRIPTION
The Midco I site occupies approximately four acres and is located at 7400
W. 15th Avenue, Gary, Indiana (Figure 1). This is in the southwest
quarter of the northwest quarter of Section II, Township 36 North, Range 9
west. This is in a light industrial area. The site is within one fourth
mile of a residential neighborhood in Hammond, Indiana, and within 3000
feet of a residential neighborhood in Gary, Indiana. There is also a
resident living about 900 feet south of the site. It is bordered by an
Indiana Department of Highways maintenance facility on the west, sand
ridges and wetlands to the north, cut and fill land on the east and a
private building on the south. (Figure 2). The Ninth Avenue Dump, an NFL
site, is located approximately 1/4 mile north of Midco I.
The site is located approximately 3.8 miles south of lake Michigan and
lies midway between the Grand Calumet River and the Little Calumet River,
both of which flow into Lake Michigan. It lies in the Calumet Lacustrine
Plain.
Topography:
The original relief of this site, as well as the surrounding area,
included alternating east-vest trending ridges and swales. Originally,
two swales crossed what is now the Midco I site. However, the topography
of the site as well as of the surrounding area has been modified by man to
a great extent and is only locally preserved. The site itself is now
level and is underlain by sandy soil. A surface removal action was
completed in 1982 to remove all wastes in drums, tanks and the top one
foot of contaminated soil. The remaining contamination of concern is in
subsurface soils and materials, and the ground water.
Ecology:
There is evidence of the original ridge and swale topography just north of
the site. Despite the industrial and commercial use of the land, much of
the area around the site contains wooded and ponded areas that provide
habitat for fish and wildlife. A relatively undisturbed wetland area
approximately 1000 feet north of the site and surrounding the Ninth
Avenue Dump Superfund site has been designated by the U.S. EPA and the
U.S. Army Corps of Engineers as unsuitable for filling because of natural
resources values. However, the more disturbed wetlands closer to Midco I
have not been so designated.
There are a number of relatively undisturbed, state-dedicated nature
preserves within three miles of the site. These areas as well as other
relatively undisturbed sites, provide habitat for a wide variety of
migratory and resident wildlife. The southern end of Lake Michigan and
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nearby habitats are a convergence area for migratory birds following the
north-south boundaries of the Lake.
Habitats near Midco I support a variety of fish and wildlife populations.
Nesting mallards were observed in wetland habitats between Midco I and
Ninth Avenue Dump. The mallard has been designated as species of Special
Bnphasis by the U.S. Fish and Wildlife Service. Other birds seen in the
area were spotted sandpipers, killdeer, goldfinches and red-winged
blackbirds. Midco I is also within the range of the Federally-designed
endangered Indiana bat.
In addition, the following State of Indiana-designated endangered species
were observed near Midco I: the American bittern; broad winged hawk,
nudpuppy and Franklin's ground squirrel. One dead grey birch was
observed, which is on the Indiana Threatened Plant list. The ponded area
400 feet north of the site contained green sunfish, black crappy,
nudminnow, carp, black bullhead, crayfish, and snapping turtle.
Ground Water:
The Midco I site is underlain by two distinct aquifer units. The sandy
surface deposits, about 30 feet in thickness, comprise a surficial
unconfined aquifer (Calumet Aquifer) with a saturated thickness of 20 to
25 feet. This aquifer has good yield potential and is very susceptible to
contamination from surface sources because of the high water table and the
very permeable sandy nature of the surface soils. A 110-foot thick
sequence of silty clay and silt loam till separates this aquifer from a
bedrock aquifer of the Silurian Age. Available specific capacity data
suggest that the top few hundred feet of this aquifer has limited yield
capacity.
Ihe direction of ground water flow in the Calumet aquifer is to the north
and northeast from the site as indicated in Figure 3. The rate of ground
water movement is only about 70 feet per year because of the very low
nydraulic gradient. An estimate of the vertical flow rate through the
clay confining layer is 2 feet per year.
According to an ongoing united States Geological Survey study, the ground
water movement in the Calumet aquifer is locally affected by ditches and
Leaky sewers. The groundwater discharge to ditches and leaky sewers often
causes a fully penetrating effect on the flow in the aquifer. A City of
3ary sewer is located 2700 feet north-northeast of the site in the down
gradient flow direction from the site (Figure 1). It is not known whether
:his sewer is leaking, but its manhole does drain the wetland east of
Jinth Avenue Dump during high water conditions.
Che predominant source of water for both potable and non-potable uses in
:he Midco I area is Lake Michigan. In spite of this, the well inventory
conducted in the Remedial Investigation identified 68 private wells
screened in the Calumet aquifer within approximately one-mile of Midco I.
[his includes 16 wells potentially in the downgradient ground water flow
iirection from the site; twelve of which are used for drinking.
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Figure 1
AIRPORT
PROPERTY??
BOUNDARY OF 9 T H_A_V EN U E^
DUMP SITE
TH & CLINE SITE
AVENUE
Gary Sewer Line • :*"***
K3ARY
MIDCO H:
kAPPROXIM"ATEl
NO ANA
LEGEND
LOCATION MAP WAS REPRODUCED _ ^^ Imm^ APPROXIMATE
THE U.S.G.S. 7.5 MINUTE QUAD. PROPERTY BOUNDARY nOfth
HIGHLAND. INDIANA, 1968, PHOTO PiriJBc 1 « PROPERTY * 5*'^
ED 1980. REFER TO STANDARD HGUHE ^ LOCATION MAP
.S. TOPOGRAPHIC MAP SYMBOLS. I LSITfc LOCATION MAP
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Figure 2
1
ISth STREET
MIDCO I
SITE
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Figure 3
AVERAGE HEAD (FT MSL)
0 100 200 N
I 1 1 A
FEET
AVERAGE GROUND
WATER CONTOUR
FEBRUARY-MAY 1986
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Surfaoe Drainage:
Surface water levels are intimately related to ground water levels in the
surficial aquifer. Surface water drains into the wetlands north and east
of the site. It was also observed that contaminated ground water from the
site seeps into the adjacent wetlands east of the site. Most of the time,
there is no discharge from these wetlands. However, during the spring
melt and periods of heavy precipitation, surface water migrates slowly
northward through wetlands into the wetlands surrounding 9th Avenue Dump.
During periods of high water levels, the wetlands surrounding 9th Avenue
Dunp drain into the sewer shown in Figure 1. This sewer leads to the Gary
Hastewater Treatment Plant.
II. Sl'lti HIS'lORY AND PJFOFfl T*iME>7r AcmVIT1 ^^
Midwest Solvent Recovery (Hideo I) began industrial waste recycling,
storage, and disposal at the site sometime prior to June 1973. The Midco
I site was used for disposal of a variety of industrial wastes including
unknown quantities of bulk liquid industrial wastes. Waste handling
methods included open storage and stockpiling of 55 gallon drums.
In November 1973, an Indiana State Board of Health (ISEH) inspector
estimated that 6000 to 7000 drums were stockpiled on the site. later,
inspections by ISEH noted even more drums on the site and drums in a
state of disrepair.
Four bulk tanks ranging from 4,000 to 10,000 gallons each were on site in
mid-1976. The leakage of drums and bulk tanks on site has been
documented. A large pit on site was used for disposal of industrial
sludges and residues.
On December 21, 1976, a fire broke out at Midco I. An estimated 14,000
drums of chemical waste burned in the fire, causing emission of toxic
fumes. Shortly after the fire, Midco operations were relocated to 5900
Industrial Highway, Gary, Indiana, operating under the name Midwest
Industrial Waste Disposal Company, Inc. (Midco II) . Active operation was
renewed at the Midco I site in October 1977 when it was taken over by
Industrial Tectonics, Inc. (Intec) .
On February 24, 1978, the Lake County Circuit Court ordered the operator
of Midwest Solvent Disposal Company to remove and properly dispofip of the
fire-damaged drums of cyanide and other industrial wastes from Midco I and
Midco H within 90 days. This order was never obeyed.
In approximately February 1979, Intec discontinued operations leaving
thousands of drums of waste chemicals unattended on the site. One
property owner bulldozed drums of waste off his property causing rupturing
of some drums.
During 1979, the ISEH, U.S. EPA and the Gary Fire Department conducted
investigation at the site. Based on the results of these efforts, the
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United States filed a complaint in the Federal District Court in Hammond,
Indiana under Section 7003 of the Resource Conservation and Recovery Act
(RCRA) (Civil Action No. H-79-556) . A Preliminary Injunction and
Temporary Restraining Order were granted on January 31, 1980, that
directed Intec to remove certain surface wastes from Midco I. By further
order of the Court on December 4, 1980, Intec was required to remove
certain surface wastes from Midco I.
On December 4, 1980, the operators of Midwest Solvent Disposal Company
were ordered to submit to U.S. EPA a plan for removal of all wastes stored
on the site not attributable to Intec, and to design a plan to determine
the nature and extent of the soil and ground water contamination.
However, these court actions were ineffective, and in late January 1980,
an estimated 14,000 drums were stockpiled up to four drums high, and
thousands of fire-damaged drums still remained on the ground. In June
1981, the EPA enclosed the site with a fence. In June 1981, severe
flooding caused water in the area to drain west into Hammond. Contact
with this flood water reportedly caused skin burns, which many believe
were due to drainage from Midco I and the Ninth Avenue Dump, located north
of Midco I.
The U.S. EPA funded a hydrcgeologic study performed from June 1981 to
September 1982 to provide a preliminary indication of contaminants present
in the soil and ground water, to determine ground water flow, and to
define the extent of contamination related to the site.
The U.S. EPA announced on January 27, 1982, the allocation of funds and a
contract award for the removal of hazardous waste from the Midco I site.
This action was conducted from February 26 to July 7, 1982. It included
removal and off -site disposal of approximately 7,000 cubic yards of
crushed drums, 84,000 gallons of solvents, 5,600 gallons of acids, 13,500
gallons of bases, 56,500 gallons of inert compounds, 940 drums of
flammable solids, 170 labpacks, and 7,200 cubic yards of contaminated
son (the top 1 foot) .
It also included placing a 6-12 inch clay soil cover over most of the
site. In addition, 840 drums of wastes were removed from the site by a
responsible party, and one surface tanker was removed by Intec. This
concluded the surface removal action but the contaminated soil and ground
water had not been
Midco I was placed on the National Priorities List (NFL) in December 1982.
The NPL is a list of abandoned or uncontrolled hazardous waste sites that
are eligible for investigation and remediation under CERCLA.
On January 19, 1984, the United States filed its First Amended Complaint
for Civil Action No. H-79-556 adding claims for injunctive relief under
Section 106 of the Comprehensive Environmental Response Compensation and
Liability Act (CERCLA) , and recovery of response costs incurred by the
United States under Section 107 of CERCLA and adding generator defendants.
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The U.S. EPA completed a Work Plan for a Remedial Investigation/
Feasibility Study (RI/FS) for this site, and initiated field work for the
RI/FS in February 1985. The purpose of the RI was to collect data needed
to determine the full extent of hazards remaining at the site and to
evaluate alternatives for remedial actions. The RI included geophysical,
soil gas, soil, hydrogeological, surface water, surface sediment and
ground water investigations. However, the U.S. EPA agreed to discontinue
its work on the RI/FS in April 1985, when a group of defendants agreed to
conduct the RI/FS in accordance with the U.S. EPA-approved Work Plan.
An agreement was formalized on June 19, 1985 by a Partial Consent Decree
in United States of America v. Midwest Solvent Recovery, Inc. et. al.
lodged with the United States District Court for the Northern District of
Indiana. This Partial Consent Decree required reimbursement of past costs
and specified that an RI/FS be completed in accordance with the U.S. EPA's
Work Plan for the Midco I site by the Defendants. Litigation was stayed
until completion of the RI/FS.
The contractor for the defendants started work in May 1985. After review
of the first draft Remedial Investigation (RI) report, U.S. EPA required
additional sampling in February 1987. This sampling was completed and a
final RI report was approved by U.S. EPA in December 1987. The contractor
submitted a final FS report in February 1989.
III. CCMMUNTTV
A public meeting was held on February 21, 1985, to explain the proposed
Remedial Investigation/Feasibility Study. U.S. EPA updated the community
on the status of the RI/FS using fact sheets in November 1987 and December
1988.
A Proposed Plan was prepared explaining alternatives evaluated and the
basis for preference for one alternative. The Plan was mailed to over
100 persons in the community. Availability of the Plan was published in
two local newspapers. A public comment period was held from April 20 to
May 19, 1989. A public meeting was held on April 27, 1989 in a high
school near the site.
Verbal public comments were received during the public meeting. Written
comments were received from one resident of Gary, from the City of
Hammond, from the Indiana Department of Environmental Management, and from
members of the Midco Steering Committee, which represents potentially
responsible parties at the site. A summary of their major comments as
well as U.S. EPA's response to them is included in the Responsiveness
Summary in the Appendix.
The U.S. EPA-selected remedial actions identified in the Record of
Decision differ from the preferred alternative described in the Proposed
Plan in the follow ways:
1. As an alternative to deep well injection, the option of
reinjection of the ground water back into the Calumet aquifer
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is allowed following treatment, with the condition that this
operation not cause spreading of the salt plume.
A Treatability Variance is approved for the solidification/
stabilization (S/S) operation from the land Disposal Restriction
(ITR) Treatment standards. This is being approved because
existing available data do not demonstrate that S/S can attain ITR
treatment standards consistently for all soil and debris at this
site. The Treatability Variance allows attainment of standards
that have been demonstrated to be attainable for soil and debris.
7. SCOPE AND ROLE OF THE pPSPnn^ ACTION
anoval of surface wastes, an underground tank and the top one-foot of
Dntaminated soil was completed by U.S. EPA in 1982. This Record of
acision is for the final remedial action and will address the remaining
ontamination at the site including contaminated subsurface soil and fill
aterials, contaminated ground water and contaminated surface sediments.
. SITE CHARACTERISTICS
ye RI showed that on-site subsurface soils are highly contaminated by a
irge number of chemicals and contain sane crushed drums and other debris.
round water below the site is also highly contaminated, but the
Dntaminated ground water does not extend very far from the site. Some
orface sediments near the site have also been contaminated. The ground
iter was also highly saline, it appears largely due to run-off from the
ijacent Indiana Department of Highways facility.
xorce:
i-site subsurface soil and debris are a continuing source of contaminants
5 the ground water and surface water. Fourteen test trenches were
ccavated into the most contaminated portions of the site and nineteen
tuples were collected to characterize the extent and nature of this .
xirce. The east-central portion of the site has the highest
Titamination. The minimum, maximum and mean concentrations of chemicals
itected in these samples are summarized in Table 1 in the Appendix.
.evated concentrations of the following chemicals were detected:
methylene chloride barium
acetone cadmium
2-butanone chromium
4-methyl-2-pentanone
toluene lead
ethylbenzene nickel
xylene zinc
phenol cyanide
bis(2-ethylhexyl) phthalate
1,1,1-trichloromethane
trichloroethene
tetrachloroethane
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benzene
chlorobenzene
iscpnorone
butyl benzyl phthalate
di-n-butyl phthalate
4
A large number of polyaronatic hydrocarbons were detected at up to a few
hundred mg/kg. PCBs were detected in one sample at 44 rag/kg. Pesticides
were detected in two saitples at below 10 mg/kg.
Total volatile organic compounds were as high as 1.1% by weight and
consisted predominantly of methylene chloride, 2-butanone, toluene,
ethylbenzene, xylene, trichloroethene, 4-methyl-2-pentanone and
chlorobenzene.
Total semi volatile organic ccrpounds were as high as 0.8% by weight and
consisted predominantly of phenol, polyaronatic hydrocarbons, phthalate
and alkanes. Cyanide was as high as 2,720 mg/kg; chromium as high as
10,200 mg/kg; and lead as high as 4,980 mg/kg,
The estimated volume of contaminated subsurface soil and debris above the
water table is 12,400 cubic yards.
ice Water:
Surface water samples were collected at eleven locations during two rounds
of sampling. The maximum, minimum and average concentrations are
summarized in Table 1. The sampling locations along with the results from
total volatile organic compounds are shown on (Figure 4). Ground water
was observed recharging the wetland east of the site at location 1. The
sample at location 1 contained a number of volatile organic compounds
which were present at high concentrations on the site.
Figure 5 shows inorganic compounds exceeding the acute water quality
criteria levels. The highest metals and cyanide concentrations were found
in the wetland east of the site, which receives run-off and ground water
recharge from the site. However, other potential sources of contamination
to this area were also detected.
Surface Sediments:
Surface sediment samples were collected in eleven locations during two
rounds of sampling. The maximum, minimum and average concentrations
ire summarized in Table 1. The sampling results indicate elevated
xmcentrations of total volatile organic compounds, total semi-volatile
organic compounds, PCBS, chlordane, cadmium, chromium, and lead in the
•ions directly north and east of the site. However, it was
that other sources of contamination were also present. Figures
7 show the distribution of total volatile organic compounds, and
3esticide/PCBS in sediment samples.
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Ground Water:
Thirty-three monitoring wells were installed and sampled during two
rounds. A limited number of wells were sanpled for cyanide and a few
other parameters during a third round. The maximum, minimum and average
itrations are summarized in Table 1.
An unanticipated result was the finding that the aquifer in the vicinity
of Midco I is highly contaminated with salt consisting primarily of sodium
and chloride. Chloride was as high as 15,000 mg/1 below the site. The
extent of this contamination is indicated by the chloride isolines for the
10-feet deep wells in Figure 8 and the 30-feet deep wells in Figure 9.
The Midco I RI results, as well as a study for the Ninth Avenue Dump RI,
indicated that a very high concentration salinity plume is migrating from
the adjacent Indiana Department of Highways (IDOH) salt storage facility.
A study of aerial photographs for the Midco I RI determined that (at least
from 1970-1975) an unprotected stock pile was present at the IDCH facility
near a swale on the northern half of what is now the Midco I site.
Presumably this stock pile was salt and the highly saline drainage from
the pile drained into the swale on Midco I contributing to a salt plume
from that facility. Drainage from Midco I and even bulk discharge of
saline waste materials into the swale during Midco I operations could also
have contributed to the salinity plume at and downgradient from Midco I.
Some of the ground water sampling results for hazardous substances are
summarized in Figures 10, 11, and 12. Hazardous substances detected at
high concentrations in on-site ground water compared to background
include: chromium; nickel; zinc; cyanide; methylene chloride; trans-1,2-
dichloroethene; chloroform; 1,1,1-trichloroethane; vinyl chloride;
chloroethane; acetone; 2-butanone; 4-methyl-2-pentone; benzene; toluene;
total xylene; phenol; benzoic acid; isophorone; trans-l,2-dichloroethene
and 1-1 dichloroethane. The total volatile organic compound (VCC) content
of the ground water samples was as high as 476,000 ug/1 (MW5), but the
VOCs decreased to less than 100 ug/1 immediately north of the site in the
10 foot deep monitoring wells.
Elevated concentrations of methylene chloride, acetone, 2-butanone,
benzoic acid, phenol, cyanide and lead were detected in off-site wells A30
and/or B30. Since there is little or no vertical gradient in the shallow-
aquifer in this area, it is believed that these hazardous substances were
carried to the bottom of the aquifer with highly saline (and dense) water.
The hazardous substances were likely from the Midco I operations.
Biota:
The U.S. Fish and Wildlife Service collected samples of fish, crayfish,
snapping turtles, small mammals and earthworms near Midco I. These
samples were analyzed for organic and inorganic hazardous substances. The
results were compared to the results in control samples. Although the
U.S. Fish and Wildlife Service has not yet issued its final report,
preliminary results indicate that the following hazardous substances were
-------
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'requently detected at elevated concentrations relative to the control
amplest
2-butanane aluminum
Toluene capper
. ethylbenzene lead
xylene silver
1th the exception of aluminum and silver/ these hazardous substances were
Iso elevated in the source, ground water or surface water and sediments
t Hideo I (compared to controls).
I. SUMMARY OF SITE RISKS
or a future development scenario including usage of the ground water,
oil ingestion and air exposure, an estimate of the health risks is as
ollows:
Lifetime
Cumulative Cumulative
Carcinogenic Non-carcinogenic
Risk* Risk Index*
to ground water 4.1 x 10~2 86
Exposure to soils 6.8 x 10""5 3.6
Exposure to future surface 2.2 x 10"6 0.0039
water
Risks from exposure to ground water and soils are from Table 4-22 of the
Addendum to Public Comment Feasibility Study, Midco I, March 7, 1989
(excluding arsenic which is at background). Risk from exposure to
surface water is from Appendix A of the Public Connent Feasibility
Study, February 10, 1985.
ye main compounds causing the carcinogenic risks are:
Ground water - methylene chloride, vinyl chloride, benzene;
Soils - PCBs, bis (2-ethylhexyl) phthalate, tetrachloroethane,
methylene chloride, dieldrin trichloroethene; and benzo(a)
pyrene;
Surface Water - vinyl chloride, and methylene chloride.
impounds causing the non-carcinogenic risks in ground water
lene chloride, 4-methyl-2-pentanone, 2-butanone, phenol,
? chromium (as Cr(Vl)), chloroform, and acetone.
•e following hazardous substances were detected at concentrations above
te Primary Drinking Water Regulation Maximum Contaminant Levels (MCLs)
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-10-
(40 CFR 41) in ground water near the site: trans-l,2-dichloroethane;
trichloroethene; 1,2-dichloroethane; benzene; toluene; ethylbenzene;
vinyl chloride; halogenated methanes; selenium; cadmium; barium; and
A cumulative subchronic hazard index for an en-site future development
scenario was calculated to be 63. This was calculated by adding the
ratios of the estimated subchronic exposure rate (SER) to the Acceptable
Subchronic Intake (ASI) for each chemical. The index exceeded unity (or
one) for all age groups for nickel, toluene and 2-butanone. if the index
is less than one, no adverse health effects would be expected. In
addition, the index exceeded unity for pica children for lead, cyanide
(assumed HCN) , and bis (2-ethylhexyl) phthalate (Remedial Investigation of
Midwest Solvent Recovery (Midco I) . December 1987. pp 6-58, 6-59 and
Table 6-20).
For the nearest off-site residents, the lifetime cumulative cancer risk
was estimated to be 5.7 x 10~5, mainly due to benzene emissions to air and
ingestion of arsenic and benzo(a)pyrene in soils north of the site.
However, the concentration of arsenic in these soils was below the average
detected in background samples (Remedial Investigation of Midwest Solvent
Recovery (Midco I) . December 1987. p-€-61 and Table 6-22) .
If no action is taken to contain or recover the ground water, contaminants
will continue to migrate from the site in the ground water. The contami-
nated ground water is predicted to affect the area shown in Figure 13, and
could affect up to 19 residential wells (some of which are used for
drinking) in the Calumet aquifer. It will also affect the surrounding
wetlands.
Alternatively, the contaminated ground water could discharge to the sewer
north-northeast of the site (if it is leaking) , flow through the City of
Gary Wastewater Treatment Plant, discharge to the Grand Calumet River and
eventually reach Lake Michigan.
It has been argued that the Calumet aquifer at Midco I should be
considered a Class HI aquifer because of the high salinity, and, there-
fore, that the aquifer should not be protected for drinking water usage.
However, because the salinity is not natural and has only affected a
limited portion of the aquifer and because the ground water in the bulk of
the aquifer is of drinking water quality and indeed is used as a drinking
water source a short distance from the site, U.S. EPA has determined that
the Calumet aquifer in the vicinity of Midco I is a Class H aquifer and
should be protected for drinking water usage.
It has also been argued that there should be considered no risk due to
future drinking water usage of the ground water because the high salinity
would prevent its usage. However, there is no assurance that the
contaminants from the site will always migrate within the salinity plume.
In fact, Figures 8 and 9 show that only a small portion of the ground
water below the site has a total dissolved solids content greater than
10,000 ng/1, which is the concentration used in the U.S. EPA Underground
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IDDCO I
TS.T OF PLUME IF
VRTER RE>CDL^T10N NOT PRTMD,
0 2000
Seal* In Ft*t
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-11-
Injaction Control Program as the cut-off point for drinking water usage.
In addition, the Hideo I operation contributed an undeterminable amount of
the ground water salinity problem at and downgradient from the site.
The following parameters exceeded the chronic and, for some, also the
acute water quality criteria for protection of aquatic life in some
surface water samples: diethylphthalate, di-n-butylphthalate, cadmium,
chromium copper, iron, lead, mercury, nickel, silver, zinc and cyanide.
The U.S. Fish and Wildlife Service believes that the biota living in the
vicinity of Hideo I accumulated elevated concentrations of volatile and
inorganic compounds, which adversely affected fish and wildlife resources.
VTII. DESCRIPTION OF ALTERNATIVES
A large number of alternatives were screened, using engineering judgement
for applicability, past performance and implementability. Detailed
evaluations were conducted for 14 alternatives, which are combinations of
the most promising technologies. These technologies can be categorized as
follows:
Containment:
. multilayered cap
. slurry wall
Ground Water Treatment:
. pumping of contaminated ground water and disposal in an
underground injection well without treatment
. pumping of contaminated ground water, treatment and then disposal
in an underground injection well
. pumping of contaminated ground water and treatment by evaporation
Source Treatauent;
. soil vapor extraction
. solidification/stabilization
. in-situ vitrification
. incineration
Alternatives providing for direct treatanent or removal of contaminated
soils below the water table were eliminated for a number of reasons. For
one, treatment of soils below the water table would normally require
dewatering of the aquifer below the site prior to excavation. Dewatering
would require installation of a containment barrier and disposal of a
large volume of contaminated ground water. Because of the time needed
for the injection well construction, the contaminated ground water for
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-12-
dewatering would have to be commercially disposed of. The nearest
commercial deep well is in Ohio, so this disposal would be expensive and
add transportation hazards. In addition, ground water pump and treatment
alternatives may address readily leachable contaminants by gradual removal
by natural ground water flushing. Contaminants that do not leach out
would normally not be available for direct ingestion because they are
below the water table. Therefore, the source removal and treatment
alternatives only address contaminated subsurface soils and materials
above the water table, and highly contaminated materials below the water
table that can be handled by localized dewataring.
The area! extent and depth of source treatment above the water table will
be determined by soil cleanup action levels (CALs). The extent and period
of operation of ground water treatment measures will be determined by
ground water CALs. Surface sediments will be scraped up in the areas
shown in Figure 14 to a depth that will leave the remaining sediments
below the soils CALs. The CALs are defined in Section X, and includes
attainment of MCLs in the ground water. The expected area! extent of
source and surface sediment remediation required is shown in Figure 14.
The expected area! extent of ground water remediation is shown in Figure
15. Applicable, or relevant and appropriate requirements (ARARs) for the
various alternatives are summarized in Tables 6, 7 and 8 in the Appendix.
The fourteen alternatives are summarized below, including the status of
compliance with major ARARs:
Alternative 1; No Action
By law, U.S. EPA is required to consider the no-action alternative. No
action would be taken to address the source, the contaminated ground water
or surface water. The source would continue to cause contamination of the
ground water and surface waters. The contaminated ground water would
continue migrating off-site and may eventually affect nineteen ground
water wells.
Alternative 2: Access ttp*^t rif^im*. with
This alternative consists of the construction of a RCRA compliant multi-
layer cap over the entire site, an area of approximately 150,000 square
feet. The cap would include a low-permeability barrier layer to prevent
vertical migration of water, a lateral drainage layer and a vegetative
cover, as shown in Figure 16.
The scraped contaminated sediments (estimated to be 1,200 cubic yards)
would be excavated and transported to an off-site landfill for disposal.
Ground water use restrictions would be placed in the area shown in Figure
13. The nineteen current users of the ground water in the Calumet aquifer
in that area (both domestic drinking and non-drinking) would be connected
to the municipal water system.
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Mgure 14
/5//> STREET
KEY:
6 MONITORING WELL
-«—«- FENCE LOCATION
SOIL TO BE REMEDIATED
te?::--...-'\ SEDIMENTS TO BE REMEDIATED
e
1=
too
too
100
SCALE IN FEET
FIGURE 4-16
MIDCO I
SOIL AND SEDIMENTS
TO BE REMEDIATED
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Ul" ST.
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Figure 16
:-30wiL SYNTHETIC LINER-H
FIGURE 4-2
MIDCO I
ALTERNATIVE 2
RCRA MULTILAYERED CAP
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N
D
I
X
Dam«« & Moor*
i
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-13-
This and all the remaining alternatives would include installation of a
six foot drain link fence with 3-strand barbed wire around the site,
installing warning signs, and imposition of deed restrictions.
Ground water and surface water migration would be monitored regularly.
1. Relevant and Appropriate Requirements:
This alternative would be consistent with hazardous waste landfill closure
requirements of the Resource Conservation and Recovery Act (RCRA) (40 CFR
264.111, 264.116, 264.117, 264.310), and ground water monitoring
requirements of RCRA (40 CFR 264.97, and 264.99). However, it would not
be consistent with the Primary Drinking Water Regulations (40 CFR 141) or
the RCRA corrective action requirements (40 CFR 264.100) because
contamination from the site would continue to cause exceedance of the
MCLs in off-site ground water. It also would not be consistent with the
Ambient Water Quality Criteria (AWQC) for protection of aquatic life,
because the contaminated ground water would recharge surface waters and
cause exceedance of the AWQC.
2. Applicable Requirements:
The off-site disposal of contaminated sediments would have to be in
compliance with U.S. EPA's off-site policy and all applicable RCRA, and
Department of Transportation (DOT) regulations.
3?
A clay slurry wall would be installed around the area where clean-up
action levels (CALs) are exceeded in soils above the water table and for
ground water. The wall would be keyed into the material confining layer
located 30 feet below the site, and would be approximately 36 inches wide
and 2,050 feet long.
Because of the high salt content and other contaminants at the site, bench
scale tests would be performed in order to determine the formulation for
the slurry. Bentonite clay may be affected by the high salinity, so
attupulgite clay may be used instead.
A multi-layer cap as described in Alternative 2 would be placed over the
area inside the slurry wall. Contaminated surface sediments would be
scraped and contained within the cap and slurry wall. An extraction well
would be placed in the containment area to lower the ground water inside
the wall by approximately 0.5 feet to insure an inward ground water
gradient. Initially, this would require disposal of approximately 21,500
gallons of contaminated ground water. This would be dispospri of in the
nearest commercial deep well.
As with Alternative 2, the site would be fenced and pnstgd, deed
restriction imposed, and a monitoring program implemented.
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-14-
1. Relevant and Appropriate Requirements:
This alternative would be consistent with RCRA hazardous waste landfill
closure requirements. Because the ground water outside the slurry wall
would meet the CALs, this alternative would be consistent with RCRA
corrective action requirements, and the Primary Drinking Water
Regulations. After containment of the Midco I source, surface water would
shortly meet the AWQC (unless other sources are present) .
2. Residual Risks:
Because no treatment is involved in this alternative, the residuals
contained within the slurry wall and cap would be the sane as presently at
the site. The risks involved in case the cap and slurry wall are damaged
or if residential development occurred on the site, would be the same as
the present site risks.
e 4A: ^"ound Wa^^T Pumping and DPT* W*»H Inflection
This and all other alternatives treating the ground water includes
installation and operation of ground water extraction wells to intercept
the contaminated ground water that exceeds the CALs. The results of a
preliminary model estimated that seven extraction wells should be
installed to recover ground water as shown in Figure 17. The total
estimated pumping rate for the seven wells is 13 gpm. The extraction
wells would be operated until ground water CALs are met in all portions of
the Calumet aquifer affected by the site. Because the contaminated ground
water would be contained, AWQC would shortly be attained in surface water,
unless prevented by other sources.
A Class I hazardous waste underground injection well would be installed.
The injection zone would be located approximately 2,250 feet below the
surface in the Mount Simon aquifer. The underground injection operation
may be combined with the Midco II remedial action if this is determined to
be cost effective. The 9th Avenue Dump remedial action may also include
utilizing the deep well from Midco for H-icpogai of saline waste water.
In these cases, the combined treatment and disposal activities will
constitute an en-site action for purposes of the off -site policy, with the
exception that the transported wastes must be manifested.
The combined treatment and disposal can be considered an on-site action
pursuant to Section 104 (d) (4) of CEBCLA because the following criteria are
net (Interim RCRA/CERCLA Guidance on Non-Contiguous Sites and On-site
Management of Waste and Treatment Residue. Porter. March 27, 1986.
OSWER Directive 9347.0-01) :
1. The sites are close . together:
2. The wastes are compatible:
3. The wastes will be managed as part of a highly reliable long-term
remedy;
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Figure 17
MODEL
BOUNDARY
••00'
« INDICATES WELL LOCATION
2 AND PUMPING RATE
GALLONS PER MINUTE
V0..INDICATES DRAWDOWN
^*** CONTOUR IN FEET
FIGURE 4-4
MIDCO I
DRAWDOWNS (FEET) AND
PUMPING WELL LOCATIONS
SCALE IN FEET
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-15-
4. The incremental short-term impacts to public health and the
environment will be minimal.
1. Applicable Requirements:
te deep veil injection must be in carpi iance with the land Disposal
jstriction (L£R) requirements of 40 CFR 268 and 40 CFR 148. The
allowing listed hazardous wastes have been disposed of on the site and
re contained in the contaminated subsurface soils, ground water and
urface sediments: F001, F002, F003, F005, P007, F008, F009.
jr this reason, before the ground water can be injected without
Teatanent, a petition to allow land rf-igp-*Mi of waste prohibited under
ibtitle C of 40 CFR 268, must be granted by the U.S. EPA Administrator
irsuant to 40 CFR 268.6 and 40 CFR 148 Subpart C. This petition must
anonstrate that there will be no migration of hazardous constituents from
ie injection zone for as long as the wastes remain hazardous.
cross section of the geology of this area is shown in Figure 18. The
rj action zone in the Mount Simon aquifer is separated by geological
>nrations from drinking water aquifers. Nearby class I underground
ijection wells that are presently operating, have submitted petitions
to 40 CFR 268.6. These petitions are presently under review by
& injection well must be constructed, installed, tested, monitored,
era ted, closed and abandoned in accordance with U.S. EPA requirements
d conditions pursuant to 40 CFR 144, and 146. In addition, reporting
quirements must be in accordance with 40 CFR 144 and 146. Contaminated
rf ace sediments will be scraped and
-------
Figure 18
gure 7, Lake County Geology
1000-1
Trenton & Black River Limestone*
St.Petef Sandstone
Knoi Dolomite
Galesville Sandstone
Eao Claire Formation
* . . r*^m* ^T ^T ^ ^~ ^9 ^ ^
Mount Simon Sandstone
Precambrian Rocks
Z=r-; .Ordovician
-4000
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-16-
be placed over the contaminated soils that would be consistent with RCRA
hazardous waste landfill closure requirements (40 CFR 264.111, 264.116,
264.117, 264.310). The site would be fenced, defri restrictions imposed,
and a ground water monitoring system implemented consistent with RCRA
This alternative could be the same as alternative 4A except that the
contaminated ground water would be treated to the extent necessary to
meet U.S. EPA requirements prior to the deep well injection. For this
alternative, U.S. EPA approval of the underground injection well would be
required, but no petition demonstration would be needed.
Prior to the deep well injection, Land Disposal Restriction (LDR)
treatment standards would be met, for listed wastes F001, F002, F003,
and F005 (40 CFR 268), this would likely require an air stripper and a
liquid-phase granular activated carbon polish system. Treatment may also
be required for cyanide, chromium, lead and nickel to meet the proposed
treatment standards for listed wastes FOOT, F008 and F009 (F.R., Vol. 54,
No. 7.) The I£R treatment standards are listed in Tables 19 and 20 (the
standards for non-waste waters would be applicable to the contaminated
water).
It is anticipated that the treatment units would be designed for an
average flow of 13 gpm. Air emissions from the air stripper would be
controlled most likely with a carbon canister. The degree of air
emissions control required is defined in Section X. Treatment residuals,
which may include spent carbon and metals sludge would be disprepri of off-
site in accordance with U.S. EPA's Off-site Policy and applicable RCRA and
DOT regulations.
As with alternative 4A, the treatment and underground injection well
system may be combined with Hideo II.
Alternatively, the ground water could be treated and then reinjected into
the Calumet aquifer if reinjection is conducted in a manner that will
prevent spreading of the salt plume. At the end of the pumping, treatment
and reinjection operation, the ground water at the site must meet the
ground water CALs (Section X). The goal of remedial actions is to restore
the ground water quality. Normally, this would require that the remedial
action also reduce secondary (non-hazardous) contaminants such as total
dissolved solids (TDS) either to background levels or to Secondary Maximum
Contaminant Levels (40 CFR 143). However, at Midco I, since there are
adjacent contaminant sources, high levels of TDS would be left in the
ground water at the site at completion of the remedial action.
s fou Wa >'*'*^lng and
A ground water extraction system would be installed and operated in the
same manner as in alternatives 4A and 4C. However, the contaminated
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-17-
ground voter would be treated by evaporation, instead of by separate
treatment operations combined with depp well injection. All contaminants
would be concentrated into treatment residuals that would have to be
dispnspd of off-site in accordance with U.S. EPA's off-site policy and
applicable RCRA and DOT requirements. The residuals will include blow
down and salt cake. In addition, air stripping and carbon adsorption may
be required prior to discharge of the condensate. Air emissions will have
to be controlled to meet the criteria described in Section X.
The blow down and carbon residuals would likely be incinerated
commercially. Cyanide, and metals in the ground water would likely be
concentrated in the salt cake. If this occurs, land disposal of the salt
cake would likely not be allowed under the land Disposal Restrictions
regulations without prior destruction of the cyanide and treatment of
metals (F.R., Vol. 53, No. 7). See Table 20.
The final site cover and handling of contaminated sediments would be the
same as in alternatives 4A and 4C.
The evaporation system may be combined with Midco II.
5As Soil Vapor Extract"' on. Excava'*"'fir> ^fr^ve •H*** <^ypund
and
This alternative and alternatives 5C, 5E and 5G treat the source and
surface sediments but not the ground water.
Soil Vapor Extraction (SVE) :
A soil vapor extraction (SVE) operation would be conducted to treat the
volatile organic compounds in the subsurface soil. This would reduce the
hazards due to air emissions during excavation and handling of the soils,
as well as risks due to leaching into ground water, direct contact and
direct ingestion. The required area! extent of treatment and degree of
treatment is defined in Section X. Emissions from the SVE would be
controlled to the degree defined in Section X.
1. Excavation and Off-Site Disposal:
Following this operation contaminated subsurface materials and surface
sediments would be excavated and disposed of off -site. All off -site
t including treatment residuals from the SVE, would be required to
comply with U.S. EPA's off-site policy and applicable RCRA and DOT
regulations. It appears likely that LCR under 40 CFR 268 would disallow
this alternative because cyanide, cadmium, chromium, lead, nickel and
silver in F007, POOS and F009 wastes would not be treated. The Land
Disposal Restrictions for F007, F008 and F009 wastes are scheduled to
fryrfl** effective in June 1989. SVE also may not provide adequate
treatment to meet the Land Disposal Restrictions for F001, F002, F003 and
F005. These treatment requirements are listed- in Tables 19 and 20 (the
standards for non-waste waters would be applicable to the contaminated
soils).
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-18-
2. Site Cover and Ground Water:
The site would be restored to grade with uncontaminated fill. Over a long
period of tine, ground water may attenuate to below CALs. However, in the
meantime, the ground water at the site would be highly contaminated and
would continue to migrate off -site. It may eventually affect ground water
in the area shown in Figure 13. Ground water usage restrictions would be
imposed in this area, and nineteen giuui'd water users (including
residential drinking water wells) would be connected to the municipal
water system. This action would be consistent with RCRA ground water
monitoring requirements. It would be inconsistent with RCRA corrective
action requirements and Primary Drinking Water Standards because MCLs
would be exceeded in off-site ground water. The AWQC may be exceeded in
surface waters due to off-site migration of the ground water.
The site would be fenced, deed restrictions imposed and ground water
monitoring implemented as in Alternative 2.
5C: SotT V^PT Extraction. Excavation Above
and A^h Solidification
1. SVE and Air Emissions:
Measures would be taken to ensure that air emissions during excavation and
handling of the subsurface material do not exceed the criteria for air
emissions defined in Section X. This may require that excavation and
handling be conducted during times when weather conditions would minimize
the volatile organic emissions, and that special procedures be followed
during excavation. Alternatively, a SVE operation may be conducted as
described for alternative 5A prior to excavation.
If SVE removes the volatile organic compounds, the risks from direct soil
ingestion, in case the site is developed, would be reduced as follows:
Before After
Lifetime Carcinogenic* 6.8 x 10"5 6.0 x lO"5
Chronic Non-carcinogenic Index* 3.6 3.4
» From Addendum to Public Comment Draft Feasibility Study, March 7, 1989.
Table 4-22.
(he subchronic hazard index would be reduced for toluene and 2-butanone
ait would remain above unity for lead, nickel, cyanide, and bis(2-
Jthylhexyl) phthalate (from. Remedial Investigation of Midwest Solvent
tecovery (Midco I), nprenfr^r 1987. pp 6-58, 6-59 and Table 6-20). The
risks due to air emissions would be nearly eliminated. In addition, the
xjtency of the source for continuing ground water contamination would be
.•educed substantially, but not eliminated.
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-19-
2. Incineration:
Following the soil vapor control and excavation operations, the
contaminated subsurface soils and surface sediment material would be
incinerated. RCRA regulations become applicable to the material
excavated and treated. It is anticipated that the incinerator would
be a transportable, rotary-cell type, approximately thirty-eight feet
long with a ten-foot inner diameter.
The incinerator is expected to have a capacity of approximately 17.5 tons
per hour. A secondary combustion chamber would be used to assure complete
destruction of the wastes, and a caustic sen inner would neutralize acidic
flue gases and control particulate emissions. The incinerator would have
to meet the testing and performance standards in 40 CFR 264.341, 264.351,
264.343, 264.342, 7611.70 and special State of Indiana requirements
including a test burn and extensive stack sampling.
The incineration should destroy nearly all the organic compounds and
cyanide. The metals would largely remain in the ash. The remaining
lifetime carcinogenic risk in the ash due to direct soil ingestion would
be approximately 2.65 x 10"5 due to arsenic.* However, these arsenic
represent levels of background concentrations. The remaining cumulative
chronic non-carcinogenic risk due to soil ingestion would be less than 1.0
that chromium is in the trivalent form, but would be greater than
\0 if chromium is in the hexavalent form.* The subchronic risk index
Ld remain above one for lead and nickel. The metals may or may not be
in a form that would leach to a significant degree.
The incineration at Hideo I may be combined with the incineration at the
nearby Ninth Avenue Dump site. For purposes of RCKA and the U.S. EPA off-
site policy, the combined action would be considered one site.
The incineration process must satisfy the LCRs for non-uaste waters for
listed wastes No. F001, F002, F003, F005, F007, F008, F009 (see Tables 19
and 20). However, a capacity variance is in effect for soil, waste and
debris until November 1990 for waste categories F001, F002, F003 and F005.
Solidification:
Following incineration, the concentrations of some inorganic compounds in
the ash will be similar to concentrations in some listed hazardous wastes
for which treatment is required prior to land disposal. This is shown in
Table 9 in the Appendix. Therefore, solidification/stabilization (S/S) of
the ash will be required following the incineration, unless TCLP tests
show that hazardous constituents in leachate from the unsolidified ash are
at concentrations less than the LCF treatment standards required under the
40 CFR 268 for F007, F008 and F009 (see Table 10). Following
solidification/stabilization, the solidified mass must meet the LCR
atment requirements for F001, F002, P003, F005, F007, POOS and F009, or
_ meet standards for a Treatability Variance if this is approved
'pursuant to 40 CFR 268.44.
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-20-
In addition, if the ash is a hazardous waste by characteristic, D004,
0005, 0006, 0007, 0008, D009 and 0010, land disrrtsal restrictions for
these wastes may be applicable at the time of the action.
Site Cover and Ground Water:
•Die incinerated/solidified material would be placed on-site. The design
of the final cover would depend on the results of the leachate tests on
the ash or solidified material. If the waste is delistable, a two-foot
soil cover would be placed over the site. If not, a final cover in
compliance with applicable RO3A landfill closure requirements would be
installed. It is anticipated that if S/S is not required, the final
cover will provide adequate protection against the direct contact risk.
As in Alternative 5A, ground water monitoring, usage restrictions and
municipal water connections would be implemented. This alternative would
be inconsistent with RCRA corrective action requirements and Primary
Drinking Water Regulations.
Al*"g'rnaf"ive 5E: vaprrr* Extraction and Solidification
Two methods of mixing for solidification are available. One involves
excavation, mixing above ground and replacement of the solidified material
on-site; the second involves in-situ addition of reagents and mixing.
1. Above Ground Mixing:
If above ground mixing is used, then a soil vapor extraction operation as
described for alternative 5A must be completed prior to excavation.
Following the soil vapor extraction, the residual risks may be as
for Alternative 5C.
Following this operation, subsurface materials above the ground water
table and surface sediments that exceed soil CALs would be excavated,
mivpri with water, binder and reagents in a tank and then placed back on
site to cure. It is anticipated that the contaminated materials would be
fed to the mixer at a maximum rate of 75 cubic yards per hour. Large
items such as stumps would be sifted out and sandwiched inside layers of
solidified material on the site.
Once the contaminated subsurface materials and sediments are excavated and
treated, the RCRA regulations become applicable. Pursuant to 40 CFR 268,
land disposal of the solidified material would not be allowed unless the
LDR treatment standards are attained (see Tables 19 and 20), or
Treatability Variance Treatment standards are attained (See Table 21) (40
CFR 268.44). Until November 1990, there are no LDR treatment standards in
effect for waste categories F001, F002, F003 and F005 in soil, waste and
debris because of a capacity variance.
The proposed LDR treatment standards for cyanide require destruction of
cyanide rather than reduction in mobility. Because it may be impossible
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-21-
to meet the I£R treatment standard for cyanide by S/S, and because
existing available data do not demonstrate that full-scale operation of
S/S can attain the I£R treatment standards consistently for all soil and
debris at this site, this alternative will comply with the ITRs through a
Treatability Variance. The required treatment standards (based on results
of Toxicity Characteristic Leaching Procedure (TdP) tests) are
summarized in Table 21. Constituents that are not listed in Table 21
should be reduced in mobility by 90% based on TCLP tests.
Land Disposal Restrictions applicable to hazardous wastes by
characteristic (DOO3, D004, D005, D006, D007, D008, D009, D010) may also
become applicable to the operation by the tine S/S is implemented.
2. In-situ Mixing:
As an alternative to excavation and solidification, the subsurface soil
would be solidified in-situ. It is anticipated that the system would
utilize a crane-mounted mixing system. The mixing head would be enclosed
in a bottom-opened cylinder to allow closed system mixing of the
treatment chemicals with the soil. The bottom-opened cylinder would be
lowered onto the soil and the mixing blades would be started, moving
through the depth in an up and down motion, while chemicals are
introduced. Vapors and dust would be pulled into the vapor treatment
system, composed of a dust collection system followed by in-line activated
carbon treatment. An induced drari fan would exhaust the treated air to
the atmosphere. At the completion of a mixing, the blades would be
withdrawn and the cylinder removed. The cylinder would then be placed
adjacent to and overlapping the previous cylinder. This would be repeated
until the entire area has been treated.
The surface sediments would be scraped up and consolidated on-site for
solidification.
Prior to in-situ solidification, a soil vapor extraction operation may
have to be conducted to reduce volatile organic compounds enough so that
emissions during mixing and curing (after the vapor treatment system is
removed) meet the criteria for air emissions and so that leachate from the
solidified mass will not cause exceedance of the ground water CALs for
volatile organic compounds (Section X).
Using in-situ mixing, the ITRs would not be applicable nor considered to
be relevant and appropriate. The S/S will be considered successful if it
reduces the mobility of contaminants so that leachate from the solid mass
will not cause exceedance of Cleanup Action Levels in the ground water
(see Section X).
3. pggiAvQ Risks:
If the vapor extraction/solidification operation is successful, the
exposures due to air emissions, direct soil ingestion and leaching to
ground water should be nearly eliminated.
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-22-
The SVE, by itself, should remove and treat most of the volatile organic
compounds. The residual risks following SVE are described for alternative
5C. Using solidification, the mobility of hazardous constituents would be
reduced through binding or entrapment of hazardous constituents in a solid
mass with low permeability that resists leaching. S/S has been selected
as the best demonstrated available technology (BDAT) or part of a BOAT for
treatjnent of a number of RCRA hazardous wastes for the Land Disposal
Restrictions (40 CFR 268}. These include the following listed hazardous
wastes: P006, K001, KD15, K022, K048, K049, K050, K051, KD52, KQ61, K086,
K087, K101. These listed hazardous wastes contain the following hazardous
constituents; cadmium, chromium, lead, nickel, silver, arsenic, and
selenium (40 CFR 268, promulgated August 17, 1988). S/S is considered a
potentially applicable technology for treatment of hazardous wastes by
characteristic numbers D004, D005, D006, D007, D008, and D010, which
contain arsenic, barium, cadmium, chromium, lead, and selenium (F.R.,
Vol. 54, No. 7, p. 1098-1099).
The S/S process has weaknesses. Some constituents interfere with the
bonding with waste materials. This includes high organic content (>45%
by weight), semivolatile organic compounds greater than 1.0%, cyanide
greater than 3,000 ppm, and high oil and grease ( >10%). SVE should
reduce those volatile and semi-volatile organic compounds. In addition,
halide may retard setting, and soluble manganese, tin, zinc, copper and
lead salts increase the leachability potential (Technology Screening Guide
for Treatment of CERCIA Soils and Sludges, EPA/540/2-88/004. Sept. 1988).
Midco I subsurface materials contain halide; elevated zinc, manganese,
copper and lead; semivolatile compounds up to 0.8%, and cyanide up to 2720
ppm.
In addition, the long term integrity of the solidified material is not
well documented because few projects have been in place for long periods
of time. This is of concern because organic constituents are usually not
considered to be treated by this process but only encapsulated. There is
very little data available on the applicability of S/S to cyanide wastes.
In one study, the mobility of arsenic was increased by orders of
magnitude by the S/S. Chromium and arsenic are difficult to solidify and
may require specialized binders. Organic lead may not be effectively
treated by S/S (F.R., Vol. 54, No. 7, pp. 1098, 1099).
Therefore, U.S. EPA cannot be sure how successful S/S will be at Midco I
until treatability tests are completed. These tests are being initiated.
In addition, treatability tests are needed to determine the proper
formulation for the solidification reagents.
4. Final Site Cover:
If the subsurface materials are excavated, RCRA hazardous waste
regulations become applicable, and the final site cover must meet RCRA
landfill closure requirements, unless the waste is delisted pursuant to 40
CFR 260.22. However, RCRA does not presently utilize leach tests in
delisting procedures for organic compounds. The final site cover must
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— ~23~
protect the solidified material from degradation due to environmental
such as acid rain and the freeze-thaw cycle.
If in-situ nixing is used, PCKA landfill closure requirements are not
applicable. However, these requirements may be considered relevant and
appropriate by U.S. EPA depending on the results of the treatability
study. At a m-in-inim, the cover must protect the solidified ina-twiai from
environmental degradation, minimize maintenance, promote drainage, and
minimize erosion*
5. Ground Water and Access:
• •
Ground water usage restrictions, well connections, deed restrictions,
access restrictions and monitoring would be implemented as in alternative
5A. This alternative would be inconsistent with RCRA corrective action
requirements and Primary Drinking Water Regulations.
Alternative 5G; In-Situ Vitrification
In this thermal treatment process, a square array of four electrodes are
inserted into the ground to the desired treatment depth of 4.5 feet. A
conductive mixture of flaked graphite and glass frit is placed among the
electrodes as a path for the current. Voltage is applied to the
electrodes to establish a current in the starter path. The resultant
heats the starter path and surrounding soil up to 3600'F. The soil
molten at temperatures between 2000* and 2500*F. As the vitrified
grows it incorporates non-volatile elements and destroys organic
compounds by pyrolysis. Pyrolyzed products move to the surface where they
combust. A hood over the process collects off-gases for treatment. The
hood remains over the melt until gassing stops, in approximately four
days. Thus, two hoods are required for sequential batch processing. The
vitrified mass is left in place and any subsidence in backfilled with
clean fill and seeded. In addition, contaminated sediments would be
scraped and transported to the site for vitrification.
The advantages of in-situ vitrification include that excavation isn't
required (except for surface sediments, which would be scraped up and
consolidated on site for vitrification), air- emissions are controlled in
place, organic compounds are destroyed and inorganic compounds are
incorporated into a glassy solid matrix resistant to leaching and more
durable than granite or marble (Technology Screening Guide for Treatment
of CERCLA Soils and Sludges, EPA/540/2-88/004, Sept. 1988).
Disadvantages of in-situ vitrification include that, although it has been
tested in pilot studies, it has not been demonstrated in a full scale
commercial application. In addition, the commercial availability of the
equipment is limited. The presence of ground water only five feet below
the surface severely limits the economic practicability because of the
energy expended in driving off water. The presence of buried metals and
c^bustible solids below the surface may also cause problems in the
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-24-
qperation (Technology Screening Guide for Treatment of CERCXA Soils and
Sludges, EPA/540/2-88/004, Sept. 1988).
Because the organic ccnpounds are destroyed and inorganic compounds
incorporated into a solid mass resistant to leaching, it is expected that
the treated material will be delistable. If tests show that the residue
is delistable, only a soil cover would be placed over the site.
Ground water usage restrictions, well connections, deed restrictions,
as restrictions and monitoring would be implemented as in alternative
5A. This alternative would be inconsistent with RCRA corrective action
requirements and Primary Drinking Water Regulations.
e g; ppnt'-a rum-ait with Soil V^PT Ext-rafrfcTm and Solidifica't"i«""i
This alternative combines the source treatment measures in alternative 5E
with the containment measures in alternative 3. The advantage of this
alternative over alternative 3 alone is that the risks from residual
subsurface soil contamination within the containment barrier would be
nearly eliminated. The contaminants in the ground water would remain but
they would be contained within the slurry wall.
Should the slurry wall fail, the ground water in the area shown in Figure
13 may eventually be affected. Although the contamination may eventually
attenuate, the risks from ingestion of ground water on the site itself
would remain very high for a long time.
The soil vapor extraction operation would remove the primary source of
ground water contamination although the remaining semi-volatile compounds
and metals could be a continuing source of ground water contamination.
Assuming that the soil vapor extraction removes all volatile organic
compounds, the risks from direct soil ingestion in case the site is
developed would be reduced as follows:
Before After
Lifetime carcinogenic* 6.8 x 10"5 6.0 x 10~5
Chronic Non-carcinogenic Index* 3.6 3.4
* From Addendum to Public Comment Draft Feasibility Study, March 7, 1989,
Table 4-22.
The subchronic hazard index would be reduced for toluene and 2-butanone
but would remain above unity for lead, nickel, cyanide, and bis (2-
ethylhexyl) phthalate (From Remedial Investigation of Midwest Solvent
Recovery (Hideo I) December 1987. pp 6-58, 6-59, Table 6-20).
Risks from air emissions from the source, in case the cap is disturbed,
would be eliminated.
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-25-
If successful, the S/S process would nearly eliminate the remaining risks
due to the source.
e *j» fSmpupc^ jfa^^T* F*3HT>ing arH D^p W^ll Inn^c^'Jcn with
and
This alternative combines the source treatment measures in alternative 5E
with the ground water treatment measures in alternative 4A.
At the conclusion of this action, the site would be close to meeting RCRA
clean closure requirements. However, long-term monitoring and maintenance
would be required because the long-term effectiveness of S/S is not well
documented.
8? ftminrj vfat'iay aing. T^reat'''*ant and Dee WE»IT
with Soil ^arr>tr Extraction and
This alternative combines the source treatment measures in alternative 5£
with the ground water treatment measures in alternative 4C.
At the conclusion of this action, the site would be close to meeting RCRA
clean closure requirements. However, long-term monitoring would be
required because the long term effectiveness of S/S is not well
documented.
9; (Srrtmri wat^T Fm^uxF and Evaporat":'i on with Soil
Extraction and Solidification
This alternative combines the source treatment measures in alternative 5E
with the ground water treatment measures in alternative 4E.
At the conclusion of this action, the site would be close to meeting PCRA
clean closure requirements. However, long-tern monitoring would be
required because the long-term effectiveness of S/S is not well
DC. SUMMARY OF THE CTWARATTVE ANALYSIS OF
In selecting the final remedial actions for Superfund sites, U.S. EPA
considers the following nine criteria:
1. Overall Rrefcection of Human Health and the Environment; addresses
whether or not a remedy provides adequate protection, and describes how
risks are eliminated, reduced or controlled through treatment, engineering
itrols, or institutional controls.
2. Compliance with ARARsr addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate (ARARs) requirements of
other environmental statutes and/or provide grounds for invoking a waiver.
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~~ -26-
3. I/TO—t^TTn effectivei>agg and permanence; refers to the ability of a
remedy to maintain reliable protection of human health and the environment
over tine once cleanup goals have been met.
4. Reduction of toxicity. mobility, or volume (TMV1; is the anticipated
performance of the treatment technologies a remedy may employ.
5. Short-term effectiveness; involves the period of time needed to
achieve protection from 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. Post: 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 state agency (the Indiana Department of
Environmental Management) concurs, opposes, or has no comment on the
preferred alternative.
9. Community Acceptance; will be assessed from the public comments
received.
These nine criteria incorporate factors required to be addressed in the
remedy selection process in SARA Section 121.
A comparison of the fourteen alternatives using the nine criteria is
included in Tables 10, 11 and 12. A comparison of costs among the
fourteen alternatives is in Table 13. Table 14 compares some major
factors considered in the effectiveness evaluation among the fourteen
alternatives. These Tables are included in the Appendix.
The no-action alternative (1) is unacceptable because ARARs for
groundwater and surface waters would be exceeded and human health and
environmental risks from continued air emissions and groundwater migration
will be unacceptable.
Alternatives that address only the source (alternatives 2, 5A, 5C, and 5G)
are unacceptable because although groundwater and surface water
contamination may eventually attenuate, this will take many years
(estimate 60-117 years). In the meantime, ARARs for the groundwater and
surface water would be exceeded, the groundwater plume would eventually
affect a large area, and biota may be adversely affected by groundwater
recharge to surface waters and air emissions. In addition, protection
from future groundwater usage, would require usage restrictions in a
fairly large area. This would be difficult to implement.
The containment alternatives 3 and 6 would provide protection to human
health and the environment for as long as the site cap and slurry wall
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-27-
are maintained. However, the high salt and organic concentrations may
affect the permeability of the slurry wall, resulting in the need to
replace it in the long term. If future development occurs or the cap or
slurry wall are damaged, the resulting health risks may be similar to no
action for alternative 3, and to alternatives addressing only the source
for alternative 6. Costs for remedying such a failure would be similar to
but higher than the original installation. In that case, the total cost
for a containment alternative would be similar to the cost for remedial
actions that treat both the source and the ground water.
Alternatives that include only treatment of the ground water (4A, 4C, 4E)
would attain a considerable degree of permanent protection. Contaminants
presently in the ground water and contaminants that are flushed into the
ground water would be reduced in toxicity, mobility, and volume (TMV) by
operation of the ground water treatment system over a long period of time.
The site cover and access restrictions would protect against on-site
direct ingestion and direct contact risks.
At the completion of the ground water action, residual contamination will
remain under the site cover, although it will be reduced from the present
conditions. It is uncertain what residual risks will remain. It is
possible that mobile contaminants will remain under the cover after
completion of the ground water treatment actions. If the cover is
subsequently disturbed or degraded, these residuals will again cause
ground water contamination. Even if relatively mobile components,
such as volatile organic compounds, phenol and cyanide are flushed from
the soil, the residual risks due to direct ingestion in case of future
development would be: 6.0 x 10~5 lifetime carcinogenic risk, with a
chronic non-carcinogenic index - 1.1 if chromium is trivalent, and 3.1
if chromium is hexavalent. Subchronic risks from lead, nickel, and bis
(2-ethylhexyl) phathate would likely remain. In addition, lead and
chromium are present in some of the subsurface material at concentrations
similar to those in some listed hazardous wastes, for which treatment is
required prior to land disposal pursuant to 40 CFR 268 (see Table 9) .
For these reasons, an alternative that combines a source treatment measure
with a ground water treatment measure is needed. Of the source treatment
measures, soil vapor extraction (SVE) by itself would reduce a large
portion of the risks from future releases to ground water, air emissions,
and reduce the direct ingestion risk to a significant degree. This is
explained in the discussion for alternative 6. However, following SVE,
residual risks will remain, and lead and chromium will be present in some
subsurface materials at concentrations similar to those in some listed
hazardous wastes, for which treatment is required prior to land
pursuant to 40 CFR 268 (see Table 9) . SVE combined with S/S would address
all risks due to the source if they are successful. The effectiveness of
S/S at Midco I would be evaluated by treatability tests prior to its
implementation .
Compared to SVE and S/S, incineration would more reliably and permanently
treat the organic compounds, it also may make subsequent solidification
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-28-
easier. However, incineraticn is considerably more expensive than SVE and
S/S, and, if S/S is successful, incineration would do little to further
reduce risks.
Vitrification, if it worked, would more reliably address both the organic
and inorganic contaminants. It also treats both organic and inorganic
compounds in one operation, which is an advantage. However, there is a
large degree of uncertainty about whether vitrification is practical at
this site because of the high water table. In addition, it is estimated
to be considerably more expensive than SVE combined with S/S and, if S/S
is successful, would do little to further reduce risks.
All the ground water treatment alternatives would result in attaining
ARARs and providing long-term protection of the Calumet aquifer at the
site when combined with a source treatment alternative. They differ only
in their method of treatment and disposal of the highly saline
contaminated ground water. The treatment and deep well injection or
reinjection into the Calumet aquifer alternative (4C) may substantially
reduce TMV of contaminants in the ground water prior to deep well
injection.
Organic compounds would be removed by stripping and carbon absorption.
If residuals from this treatment are incinerated, this would provide
permanent treatment of these contaminants. If they are landfilled, the
disposal may not be considered any more permanent than deep well injection
without treatment. If cyanide treatment is required, a chlorination
process may be used, which should permanently destroy the cyanide. Metals
may be removed by precipitation. The metals sludge would be landfilled
but may require solidification first. This disposal may not be considered
more permanent than deep well injection without treatjnent.
Reinjection into the Calumet aquifer would be acceptable to U.S. EPA if it
meets CALs and is conducted in a manner that will not spread the salt
plume. However, deep well injection is preferable because it would remove
the salt contamination from a.usable aquifer.
The evaporation alternative (4E) would reduce the volume of all
contaminants and the toxicity of contaminants in the blow down by
incineration. However, extensive treatment of the salt cake would
likely be required prior to land disposal under the RCRA Land Disposal
Restrictions. If such treatment is not required, alternative 4E would
include di^pr*^] of significant quantities of hazardous wastes in off-
site landfills.
The deep well injection without treatment alternative (4A) would not
reduce TMV of contaminants in the ground water. However, if a petition to
allow land disposal, is approved by U.S. EPA, this alternative should
provide permanent human health and environmental protection since the
petition must demonstrate that there will be no migration from the
injection zone while the wastes remain hazardous. In addition,
alternative 4A is considerably less expensive than alternative 4C.
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-29-
THE .V«KI F!L?|'K1) REMEDY
^3£S^^£'£SS^—i^—A£J££m^SjS^i£SSS^^m
U.S. EPA selects either alternative 7 or 8 for implementation at Midco I.
These alternatives are described in Sections XIII and IX. Alternative 7
will be implemented if a petition to allow injection of waste prohibited
under 40 CFR Part 148 Subpart B is approved by U.S. EPA. In this case,
the permanence of the remedial action would be considered equivalent to
alternative 8, and alternative 7 is less expensive. If a petition is not
approved, alternative 8 must be implemented. Alternative 8 may include
deep well injection of the salt contaminated ground water or reinjection
of the ground water into the Calumet aquifer.
The selected alternative win also include site access restrictions and
deed restrictions, as appropriate. Either alternative will include
treatment of the source by a combination of SVE and S/S. This is the
least expensive alternative that will permanently reduce TMV of the
source, and be fully protective of human health and the environment.
However, implementation of this source remedial action depends on the
results of the treatability tests for S/S. If the treatability tests show
that S/S will not provide a significant reduction in mobility of the
hazardous substances of concern, the ROD will be reopened and a different
source control measure will be selected. A more rtofra-iiori cost breakdown
for these alternatives is in Tables 15 and 16 in the Appendix.
Clean Up Action Levels (CALs):
Soil Clean Up Action Levels:
All subsurface materials affected by the site or by Midco operations that
exceed any of the following risk-based levels will be treated:
Cumulative Lifetime Carcinogenic Risk = 1 x 10""6
Cumulative Chronic Nbncarcinogenic Index =1.0
Subchronic Risk Index = 1.0
In addition, contaminated surface sediments within the area shown in
Figure 14 that exceed the above levels will be excavated and treated.
Ground Water Clean Up Action Levels:
All portions of the Calumet aquifer affected by the site or by Midco
operations that exceed any of following risk-based levels will be
recovered and treated (except as provided for in the subsequent
discussion). The ground water pumping, treatment and disposal system
shall continue to operate until the hazardous substances in all portions
of the Calumet aquifer affected by the site or by Midco operations are
reduced below each of these risk-based levels (except as provided for in
the subsequent discussion). Applying the CALs throughout the contaminated
plume is consistent with F.R., Vol. 53, No 245, p. 51426.
-------
-30-
Cumulative Lifetime Carcinogenic Risk = 1 x 10~5
Cunulative Ncncarcincgenic Index =1.0
Subchronic Risk * 1.0
Primary MCLs (40 CFR 141)
Chronic AWQC for protection of aquatic life multiplied by a factor of
3.9 (to account for dilution)
Evaluation of Attainment of CALs:
The risk levels will be calculated from the soil and ground water
analytical, results using the assumptions listed in Tables 2,3,4 and 5 in
the Appendix (except that in place of the average site concentration,
actual measured soil and ground water concentrations in each sample
location will be used, and soil ingestion rates for chronic exposures of
0.2 gram per day for ages 1-6 and 0.1 gram per day for older age groups
will be used), the procedures in the Superfund Public Health Evaluation
Manual and U.S. EPA's most recently published carcinogenic potency factors
and reference doses.
For inorganic compounds in ground water, the analytical results from
filtered samples will be used. The analytical procedures will at least
reach the analytical detection limits listed in Tables 17 and 18 in the
Appendix. Constituents that are not detected shall not be included in
risk calculations. Constituents that are detected below background
concentrations identified in Tables 17 and 18 shall not be included in the
risk calculations.
If only one constituent is detected in ground water at a concentration
that is calculated to potentially cause a lifetime, incremental
carcinogenic risk of 1 x 10~5 or greater, and an MCL has been promulgated
for this constituent pursuant to 40 CFR 141, then the MCL will be the CAL
for that constituent. In addition, that constituent will not be used in
the cumulative risk calculation.
JUSTIFICATION FOR USE OF 10~5 RISK LEVEL:
Use of the 1 X 10"5 lifetime, cumulative carcinogenic risk level is
mended for the ground water CAL as opposed to the 1 X 10"^ level
because there are multiple contaminant sources that are affecting the
Calumet aquifer in the vicinity of the Site. In addition, the lO"6 level
is generally well below the analytical detection limits for the
constituents of concern.
CRITERIA FOR CONTROL OF AIR EMISSIONS;
Each separate source of air emissions shall be controlled to prevent
exposures to the nearest resident and workers on adjacent properties from
causing an estimated cumulative, incremental, lifetime carcinogenic risk
exceeding 1 x 10"7. Since there are multiple operations that cause air
emissions, each must be controlled to the 1 x 10~7 carcinogenic risk level
-------
-31-
to assure that the total risk will be less than 1 x 10"6. The following
operations will be considered separate sources:
1. Subsurface soil excavation and handling;
2. Emission from SVE;
3. Emissions from S/S;
4. Emissions from ground water treatment.
The risk levels will be calculated using conservative assumptions, the
procedures in the U.S. EPA Public Health Evaluation Manual and Exposure
Assessment Manual, and the most recent U.S. EPA published carcinogenic
potency factor. The emissions must also be controlled to prevent any non-
carcinogenic risk either on-site or off-site. Fugitive dust must be
controlled in compliance with State of Indiana requirements.
CRITERIA FOR DISCONTINUATION OF SOIL VAPOR EXTRACTION SYSTEM:
The soil vapor extraction system shall be operated until the following
criteria is met:
1. Until the solidification operation will meet the criteria for air
emission defined above;
2. If soils are excavated and solidified, until applicable treatment
standards for VOCs in 40 CFR 268 will be met following
solidification;
3. If soils are solidified in-situ; until ground water CALs will not
be exceeded due to leaching of VOC's from the solidified mass.
The selected remedial actions will be protective of human health and the
environment, will attain applicable or relevant and appropriate Federal
and State requirements and are cost effective. The 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 technologies to the maximum extent
practicable.
The State of Indiana is expected to concur with the selected remedial
actions. Although there is some public concern about the deep well
injection operation, it is believed that the protective measures required
in U.S. EPA's Underground Injection Control Program coupled with source
(soil) treatment provide a more acceptable technology for the community
than the further degradation of the existing Calumet aquifer or the Grand
Calumet River.
Because the remedy will result in hazardous substances remaining oil bite
above health-based levels, a review will be conducted within five years
after commencement of remedial actions to ensure that the remedy continues
to provide adequate protection of human health and the environment.
-------
AmzOlIX TO MIDCO I MkXJLM) GF DBdSICN
Table 1: Concentrations in Various Environmental Media
Table 2: Standard Parameters Used for Dosage
Table 3: Potential Exposure Pathways for the Hideo I Site
Table 4: Routes of Exposures Used in Calculation of Intakes
Table 5: Characteristics of Subchronic/Chronic Exposure
Scenarios
Table 6: Midoo I Location Specific Requirements
Table 7: Hideo I Action Specific Requirements
Table 8: Alternative's Compliance with Applicable Laws and
Regulations
Table 9: Comparison of Concentrations of Inorganics in Sub-
surface Material at Midco I with Concentrations in Listvri
Hazardous Wastes
Table 10: Effectiveness Evaluation of Alternatives
Table 11: Implementability Evaluation of Alternatives
Table 12: Detailed Analysis Summary
Table 13: Hideo I Estimated Costs in Millions of Dollars and Time
to Implement
Table 14: Midco I Table of Effectiveness and Implementability
Table 15: Alternative 7 ... Cost Estimate
Table 16: Alternative 8 ... Cost Estimate
Table 17: Ground Water Cleanup Action Levels
Table 18: Soil Cleanup Action Levels
Table 19: Land Disposal Restriction Treatment Standards for Waste
Categories F001, F002, F003, F005 (from 40 CFR 268.41)
Table 20: Proposed Land Disposal Restriction Treatment Standards for
Waste Categories F007, F008, P009 (from F.R., Vol. 53, No.
7, p. 1068)
Table 21: Alternative Treatability Variance Levels and Technologies
for Structual/Functional Groups
-------
Responsiveness Summary
A Guide to the Underground Injection Control Program in Indiana
Waste Treatment Results for Inorganics
-------
Table 1
MAA*iC«»Tt MOSOi
>ON MO«ATO») c*CMCAL KUCTOi DATl rftfUV
TA
i m(4) ND 1JO(41 444(44
HO 41*C4I 441(41 ND 100(41 14K-09 ND 1.00(09 18(41
•3(41 I.nC4* 473(43 144(41 1MC44 2«*(41 L20C41 17U41 141(41 11U41
ND *.WC42 442(41
MD 141(40 1*7(41
MD 140(41 2*2(42 MD 1JM41 144(49 MD 440(41 t total
.00(4* 111(4* 470(41 MD . 440(41 1 tli 01 k.OH-09 t10C-01 1.l7t41 ItOt-Ol *JO(41 i IX O
I MD > 00(41
MD 400(41 140144
1*9(40 142(41 ND t«B(40 ttM-01
1JO(.09 IM(43 ND 11X42 »«(.»
100(01 (J4(41 NO 2c^04«Vi*n» NO *.20C:i l*7f-C2 ND «00(41
1.}3x>W~7»~ NO lOOiCI 3*1(41 NO 2.13(42
1.1-0»KV*>»W>» NO 100(01 3*)(4) NO 4»(43
Trto-iJ-AOMmoww NO *(C(.00 2*0(41 MO 77K.OO 34X-01
14OM»«^>vm NO 4*C(U 141(44 NO 1*9(41 141(04
1MC-01 *.n(41 NO 1Jfl(41 11X41
ND 100(44 ItXOB
149(40 147(41 ND 14O44* 1*4(41
XMC49 1.11444
•41(42 NO 140C4*
MO UW42 1J*(41
MD
100(44 MD UM41 1.11(4* ND 110(49 1«7C44 MD 140(41 10O(-04
740V02 1*4(41
lJOC4a 100(44 MD 4«C41 14*1-04
4.11(41 ND 17M41
1.70C41 141(43
140C41
1.1.1-TW*I*M MD 7*0(40 1.1X41 NO *>XC4« t*4(41
Ti*lmmimm MD *,1X 01 4.00(42 MD 1*9(41 14X49
«m«M*M4 HO 1*0(40 12X41 MD 14X40 1771-02
X*lM MD 1.10(41 (41(41 ND T.MC40 L2X41
2OH TVH (NVMONkCXTAI. l*tS1* AVIflACU
. «C/(MNU OOK AVM^aU.TtCltf/OIV. C9iSiOf.M(a M TK( riNAi,« VAI.UC
-------
HIM v vrt. mace i
a » (.M IMC.OI t*tl-tt uTi-oj *o»«.u
1401.0* tcrf.41 MD IMX^O *00t41
* 40(^1 i*a^» ••cxsdOkMO
•4£«tOLf<3
o
LM3
MO itatoi
HO
UOC-oi
ISM a» MD
7«H4i 147VM
IMC .01
NO
MD
•««4»
UU41
SXCM
IMC 01
ie«t-ei
1MC-0>
HO
*MI4> IMf-OI
T.«7f<«» JJBCJO
10C4* M3
MO TMC-Ol
M9 tMC-flf
MD ».OOC-01
lTtf-4*
T.«tf4a
4JU-09 MD
aoot-ot T7ot-a
n U
MD
M3
*">«( • IJB^^X* U
vacal U
U
&»• ati mxo
MD lOOt 01 14««
MD IMt-Ot » 0*1 33
IJOt«l tOOC U
44-.OOO
iuc.o>
MO
MO
MD
MD
MD
MD
I.MC-OI *.oo€^»
MD
MD
NO
MD
> 001.00 S.MC41
MH.OJ TJIt<«1
IMC ^
IJM
1.11141
ttitrft
UOC*01 t»n-M UOC-OS
1«OJ-0»
1MC4I
< toe 01 reto
I.Kf<«' H4J.OO
1*01-0
».10t-01 r
7 10C «
MD 1.00I4J 1 0O4-S2
COK-O*
MD uocn int-ci
MD tttC 01 1J4I4J
MO I.IOt^l »«OI-01
MD ••et-oa i.oM-04
•*»i»* tr
1.1.VTH
MD TMC-ea
MD 140»-0»
»4«« to
1J71-OJ MD
Tjet-o) tttt-oa
tK£<0> TUt-0*
MD 4JM49
10M4B
MD
M>
MD 440(41
MD uet-a
Ml i.Mt-a
1.1M4>
IJOt-01
UBC44 LMC-04
t*J(4)
1JM4J 1.1«0*
i^s-oi IJM-OI
» V7*«41
14U.09
1J«4>
1MC-0
t1«J4»
MD
NO IMC-*I
1.7M4S
TMC49 UK 04
i-Wt-OJ 1JOt41
MO i*0(32 J»4i40irfO 4.11(41
MD 4JOC-OZ LM(41
MD UCt-01 1 *Ot-OJ
MBC.OO 10C41
UM^I 1.r*(^4
X10J41 tOM-M
tjet-u *X4«
MOt-03 4.W4-04
MD IJDt^l 707141
MD 1.10(49 1.71(4*
MS 1JOC-03 7.«(4*
M3
ND
4JN4* 4J7t41
1JM41 *
Crfl OH41
.•MM MD
4.MC4I I
tt«ii»^»CIU
••THW MCUIVUNO MMQ( s COM us IOL . MOT coNiowfi rxvrmui
U . UNOMXN MQ lOWCTPr CONSTMTrt f QM TWt iNVVIONtiCMTM. Mt»* AV4IUBU
•SW49
-------
1
MTS
14U41 144(44 *41(41 117(4} 141(44 1.1M44 *4}i41 111(44 11*4.4)
1.70(4* 1*4(41 144(4* MB 14X42 140(40
1M(41 IMC 41 1M(41 IMC 4* 14M41 144(41 MD 4.MC41 1.M(41
•MC41 IMC 42 1MC41 I.70C41 «41(41 1*1(41 HD 14X41 1.11(49
M9 130(4* ItXOI 13X41 740(41 14X4* HD 240(40 HOC 01
HOC41 1.14(40 1.40(4* IM(4* IOC4* MD 140(41 24X40
424(44 144(44 114(41 7.11(44 114(44 I*M4* 14X44 141(43
•40(4* 1MC41 1*9(41 130(41 111(41 HX4* 13X40 142(44 IMC42
MB UOC40 13X40 44X40 2MC41 112C41 MD IMC41 1.*n40
IBM41 1.1*141 111(41 1.70(41 •42(41 243(41 •40(41 1*1(44 247(41
131(4) 14X44 (.10(44 11*144 444(44 1*1(44 142(4* •0*144 174(44
140(41 142(41 134(41 IMC41 114(42 243(41 141(40 4MC41 413(41
1.1*C4} 111(44 749(41 1.11(41 1*1(44 444(41 134(41 7.7X4! 2*1(41
43U41 1.77(41 1*7(41 7*0(41 1.71(4) 143(43 1.1N41 117(42 14X41
MB IMC 4* 114(41 HD *M(41 10X41
74X40 10SC43 13U43 140(41 444(41 140(42 ND 44X41 4*4(41
1*1(41 2*3(41 1*2(43 17X42 1*1(41 144(44 240(42 140(43 134(41
MB 144(4* 17X41
MB IMC4* 70X41 MD (4X4* 741(41
134(42 IMC41 110(4* 7.7X41 IMC44 14U41 14X41 14X44 2OH41
MD 14X41 174(40
14X4* 14X41 1.11(41 MD 13X41 IMC40
0*9(40 IMC41 10X41 13X41 (4X41 IMC41 MD 410(41 23X41
1.1X41 4BM41 140(41 13X41 011(41 17X42 1.1O(40 7MC41 1.*1(41
MD 140(41 1*7(42 MD 1*0(41 2MC42 ND 14X41 441(40
ND 44X41 17X41 MB 44X41 t*4C42
MB 1*0*41 (41(41 ND 1.70(41 14X40 MB 4*X41 4.7U41
ND 1.1X4* 11X41 MD 4.10(01 1.11(41 MO 110(42 1.11(41
MB 43X41 1*2(44 MD 14X41 74X41
NB I.MC4* 14X41 ND 140(4* 112(41 MB (4X41 104(41
MB 14X40 4 lit .01 MB 1*0(.00 10X41 MB IM(41 IX'.OC
MB 14X4* HX-01 HO 1M(40 7*4(41 1C •49(41 HIS-3'
MD 730(41 111(-01 MB «OX-91 204(41 MB 1.0K41 171(40
MD 2*3(41 1*4(02 ND 120(41 20X40 MB 4*0% 40 122(40
MB 14X40 147(40 MB 4.4X41 11X40 MS 1.1X41 203(>C7
MB 4*0(41 172(41
MB 440(47 130(41
MB 1*9(41 ilK4> MB 1MC40 1*9(41 MO 1*X40 10X01
N3 • •X-OJ 1*1 (-04
MB 10X40 412(41 MB 140(40 7 Ut-01 MO «4X41 103(41
MB 14X40 141(41 NO 74X40 *.7U41 MO 14X40 4*1(-01
0>)4»»»4»»» U NB 13X41 1.1X02 MO tlX-01 t.*1(42 MB 140(44 111(01
raailMnn U MB 13X41 17X43 MB 13X-01 • 141(42 MO UK41 2MC40
1>a«M4JM4«ll«« MB 140(41 14X-C3
1.1-O«WV4*W<. MD 14X41 137(49 HD 4.7X42 1.1X43
13 3«y*»»4»>4f» MO 1M(41 14X-04
1.1-3«MV»4*«~> MD 1.4X-02 137(41
Tf«Xfr134Kn»4>*Mi» ND 1.1X41 1*X43 MB 14X40 1M£01
tAOMMrVMI
tA^nwtlfiftut* U MB I.M(41 14X-03
MB 44X4* iru-oi
MB HX41 20X42
44X41 4.0X4* 117(41 MD 14X40 1.1X41 MO 1.0X42 14X41
NO 11X41 24X02 . MB 14X41 1.7X42 MB 14X41 101(40
MB 11X41 737(43 ND 44X-01 1.79(41 ND 14X41 1.11(40
MB 1.70(41 14X41 MD (40(40 144(41 NB 41X41 1.10(40
NB 13X40 134C41 MD 44X41 1.4X41 MO 1.4X42 17X41
IMC 41 III(.01
14X41 44X41
17X43 1.1X41 10X03 MD 1*X-01 1.MC41
MB 44X41 VIX41 MD 44X41 147(41
•HM U MB 14X41 147(41 MD 14X41 14X41
MB 13X40 1.7X41 MD 144(41 1.77(40
MB 11X41 141(02
MB 11X40 14X41 MD 44X41 1.71(41
MD 2JCC40 1*7(41
MB 11X40 43X41 MD 14X44 14X41
1.4X41
14X41 1.4X41
U0(41 1JK42
44X41 *MC02 MD 14X4* 14X41
4.1X41 17X41 MD 4.10(4* 444(41
1.7X43 14X41 MD 14X41 141(41
MO 17X41 .13X41
17X41 14X41 MD 14X4* 14X41
44X41 13X40
10X41 434(40
1MC41 13X41
1.0X41 4*1(42
1.1X41 144(41
14X41 14X41
14X41 44X41
41X41 •71(42
13X41 1.7X41
14X41
14X41 714(42
73X41 1M(40
13X42 701(41
13X40 lOOt-aj
43X42 21X41
73X41 117(49
(J7X41 13X42
•4X42 4.7X-S1
•3X41 11X42
14X42 1O(41
(3X4* 11X-01
4,1X41 UX-92
MD 13X40 1.1X-01 MO 1*4(41 1.nt4*
MOO.OKI24* ND «4X41 142(43
4vr-OOT
w. .
»T . MOMlNCt DOK 4VMXLL1MCMFOMC, CO"«OU«D •• t»< >*uv. IS VALUC5
-------
\ \
TABLE 6-1
Standard Parameters Used lor Calculation of Do tag* and Intake
Table 2
1 J
• 4
Parameter
yalcal Characteristics
Average Body Weight
Avenge Surface Area
.tlvlty Charaeterlatlce
Amount of Waav IngetMd OeJiy
Amount ol Air Brealhed Oafly
Amount ol Fob Comumed Daily
Soi Ingested (Pica) Defly
Freo>wncy ol Waaw Use tor Sttrimming
Ouatton of Exposure Whea Swimming
Peroenage of Surface Area Immersed
WMeBaffvng
Length of Exposure WMe Bating
jngtfi of AdduJonal Eiposura After Batting
Amount of Air Breamed Whie Bathing
Volume of Shower stall
Volume of Battreom
Volume of Water Used While Showering
alette! Chereeterlellea
Oust Adherence
Tamler Rate of Contaminant From Water
8JA»
Mass Fkn Ra* (wacr-based)
Adult
70fcg(1.2)
1l1SOem2(1)
2ben(l)
20m3(1)
6.5 g(1)
7deys>yr(1)
2.6hnVdey(1)
O.B(4)
20mr(5)
10min(S)
55m3(1X(5)
3m3{5)
10m3(5)
200tars) U.S. EPA. October 1986
)) U.S. EPA. 1965d
I)US EPA. 1964b
>) Symms. 1966
>) Lepow. 1974
-------
ro
0*
Traniperl Media
Source
Table 6-$
•Potential Eipoiuie Pathwaya lor the Mldco I Site
Releeaa MechenUm E»po>me Polni Eipoiure Route
Selected lor Ar>«lvtlt
Air
Ground waitr
On-«Me oontamlnaled VolallUiallon On tie or oil Me InhalMlon
Ml (*U ground »Mer)
Oil Uie conlamlnaled Volaillliallon Nearest residence Inhatallon
MiHvta ground waler)
Contaminated eurlace Volaillliallon Nearest residence Inhalation
•MM
CortemtoMed groundwMar VoUimiailon during Residential wel Inhalation
household use
CottamtoMed groundwMer Votatllit atlon
ahowartngA>Mhlng
*l InhMMkxi
Conumlnatad aol Fugitive dud 6«e boundary InhalMlon
CoouminM«d Ml
Run-oil
Ingeitlon
Dermal
Inhalation
Grand Calumet R. Ingesllon
Contamnalad ground Surface water take Michigan
•Mar or aurlaca water rechaige or discharge)
Irom lha Grand
CatumetR.
Dermal
Btoaccumulalbn
Ingesllon
Dermal
Yaa
Yot
Yaa
Yea
Yaa
No • Me capped or
Y«
Yaa
Covered above (Mr madia)
No - not a d/Hung water
tourca
Yea
No • currantly under
bnresllgailon by U.S. Foil
and Wildbto
No • dilution capacity high
No • dauilon capadiy high
No • currently undar
Investigation by U4. Fifth
andWUdaia
Soil
•MM
•oils
Contaminaiad surlaca
aotla
Episodic ovufkind
Ncarosl dl site
resldenca
Dermal
BioacoimuUiion
Dermal
On-aHa or oil-Ma Derniol
Ingasllon
Yea
No • currently undar
Investigation by U.S. Fish
•ndWddkto
No-tie tapped
Yaa
Yaa
-------
— Table 6-8
Hideo X
Routes of Exposure Used In Calculation of Intakes
Routes of Exposure
re Scenario/ Exposed
• d Population Subpopulation Dermal tngestion
Table 4
Inhalation
On-»ita
Child 6-12
Child 2-6
Play in soil
Play in surface water
Bathing
Play in soil
Bathing
Drinking water
Drinking water
Pica
Household air
Bathing
Household air
Bathing
•s: Residence
Adult
Child 6-12
Reaeation in surface
water
Bathing
Play in soil
Play in surface water
Drinking Water
Household air
Bathing
Household air
Child 2-6
Play in soil
Pica
Household air
Adult
Recreation in surface
water
Household air
-------
in
tt)
Table 6-9
Mldco 1
Characteristics ol Subchronlc/Chronlc Exposure Scenarios
Route ol Exposure Media
Dermal
Soil
Acllvlly
Play
Population
Child ago 6-12
Child age 2-6
Surface Water Recreation Child age 6-12
(Wetlands area Adult
only)
Groundwater Showering/ Child age 6-12
Bathing Child age 2-6
Adult
Ingesllon
Soil
Pica
Child age 2-6
Groundwater Drinking Child age 6-12
water Child age 2-6
Adult
Subchronlc Exposure
Scenario Characteristics
Three exposure events (hands
only with Incidental Ingestion ol
.1 g) at average concentration
or one event at highest cone.,
whichever Is greatest
Three hours ol exposure (20% ol
body) at average concentration
or one hour at highest concentration,
whichever Is greatest**
One hour ol exposure (80% ol body)
at average concentration or 20 mln
at highest concentration, whichever
Is greatest
5 grams per day at average
concentration or 2.5 grams at
highest concentration, whichever
Is greatest
3 liters at average concentration or
1 liter at highest concentration,
whichever Is greatest
6 liters at average concentration or
2 liters at highest concentration.
whichever is greatest
Chronic Exposure
Scenario Characteristics
One exposure event (hands only
with Incidental Ingestion ol .1 g)
per day, 150 days per year.
ai average concentration
One hour ol exposure (20% ol
body). 150 days per year, at
average concentration
20 minutes ol exposure (80% ol
body) at average concentration
365 days/year
2.5 grams per day. 150 days per
year, at average concentration
1 liter per day. 365 days per
year, at average concentration
2 liters per day. 365 days per
year, at average concentration
-------
Table 6-9 (con!)
MIOco 1
Characteristics ol Subchronlc/Chronlc Exposure Scenarios
Inhalation
Combined SoiV
Surface Water
Emission
Home
Child age 6-12
Child age 2-6
Home
Adull
Groundwater Showering/
Bathing
Home
Child age 6-12
Child age 26
Adult
Child age 6-12
Child age 2-6
Adull
24 hours ol exposure 300 motors
(root source ai average predicted
emission rale or 22 hours al
highest predicted emission rate.
whichever Is greatest
24 hours ol exposure 300 meters
from source at average predicted
emission rate or 16 hours at
highest predicted emissldn rale,
whichever Is greatest
One hour ol exposure
at average concentration or 20 mln
at highest concentration, whichever
Is greatest
18 hours ol exposure al .0001 x
the average groundwater cone.
or 22 hours al .0001 x the highest
concentration, whichever Is the
greatest
24 hours ol exposure at .0001 x
the average groundwater cone.
or 16 hours at .0001 x the highest
concentration, whichever Is the
greatest
18 hours ol exposure, 365 days
per year, 300 meters Irom source
al average predicted emission rale
16 hours ol exposure. 365 days
per year, 300 meters Irom source
at average predicted •mission rat*
20 minutes ol exposure. 365 days
per year at average concentration
16 hours ol exposure, 365 days
per year, al .0001 x the average
groundwater concentration
16 hours ol exposure. 365 days
per year, at .0001 x the average
groundwater concentration
-------
Table 6
t*mr. ».i4
HIDCO 1
l*>
•itnjn 100 retr floodolom
•ithin floodololn
Mil do*t forvotion,
•ndtrgrownd MX*, or eov*
•itni* or>* «»i»rt octio» M«
e»>»t irrtptrtoit nor«, let*.
•r dtitruction o' oignifictnt
*rt*r*ctt
Mictortc oro<«t o»nr« or
Critir§: noDUt*. upon »Men
ixes^jtrtc io»nr« or
tnrtc.nte iptcir* Otamat
•ttl.-e
• ildtmtt* trt*
rtfugt
Art* tffetting ttrto* or ri»er
•itnjn trtt effecting
notio"*! «ild. tctnic. or
recreation*: riotr
•itnm eoottol •«•
Occam or vatoro of the
unittd SUtct
200 f**t e' fault
tn
HO Ucilitr BUBI k* «*«i9»*4. eonctrycttd. *o«r*tte.
•«« Minumce to •«•!« vvi
(«o cr« 2M.ii;»;:
•Ctlon in flMdelcl" to Mole M.tri* tff*et(, •>"!•! n
hcra, rtttert md pr«««r*« iwturiJ end
(ti»rwtl»t Order lltli.
(•0 a* 4. *op«nd» *))
. ICM h«f*rdou« «olo«»c»l md «i*iorie»l
u.s.c. tect>»« u»t M eri nn *»
Action to ort»tr»» Ktotorlc »roo»rtm; tlomung o' oetio"
U •inioin n«r» to Mo-.ionol xiotorte londaort*
(iiottanol Mtttortr >rt«»r»«:i8" *ct Stttlon 10* (U U.S.C.
•70 at MQ.I M 0**/ort «S)
*etlo" to con**r»t »«d»«g«rt< oooeito or txrvitontti oo«clt*.
including eenoui:*t>o« >ltA in* 0«eort>*^t »t Inttrier
(tno»-gtr»3 Sew: if • *et a' 1»'3 (It U.S.C. 4)); tt ooa.i
JO Of* '«rt IOC. XI CTi Port 402)
to alnioin tlo dootruction, loot, or doqridotion
of •otlotdt
(Ci»cuii»« Ordir H**3, Protection of •otlona*.
40 CT* t. *Mondti A)
Actlo* to prohibit ditc^irgt of drodgvd or fill aottriol
into votlone viftout etrvit
(Cl»o' if.tr Act S«cUo>- 40); 40 CTI Hrto 2)0. 231)
f*dtrti:*-a«i«c *rtt ett-.ff.te 01 •ildomttt orto cuot bt
oo«ini*ttrte in twen nonnt; to •»!! Ittvi it uniBooirtd
oo vtldcmtot ond to ertotr«t Ito vildtrntot e»*rt:ttr
(•ildtrnno Act (1« U.S.C. HJi ot *oa.)i X) CfR )».! tt ooa.)
Or>l» telio" ollo>«« undtr txt 0rovttieno of U U.S.C. Stctio"
tU dd(e) M? Bt an«trt*«t" in ortto thot ort port of tnt
(U.S.C. Mlae tt MO.; X) OK »ort XT)
Action during tfi««r«lon, cnon»tlino, or ottwr tcti.ity that
•odifito i ttrtt* or n«or *id of'tct* fit^ or "Udlvf*
(f>**> tnd •ildlift Caardintuon Act [It U.S.C. Ml tt. oog. .
AO V* o.X2]>
Avoid taking or muting in oetion tftot >ill hoot dirtct
•dvorM tfftet* of oconic ri»«r
(Seonie *i«tro Act (U U.S.C. 1271 tt *•«. Soetln 7 (o))i
AO Cm o.»2 (•))
Conduct octlvititt offtctlng tho cootttl »x>t in Mnntr
eo««ittr*t >ttn teoro«te Sutt •ontatvtnt progrv*
(Ctwotoi tent Nontgomnt Act (U U.S.C. Section UJ1 ot Mg. ))
Action to dttgmt of tfrtdgt tnd fill Mtoriol i* proMbitod
ntKaut t por*il
(Cloon >*ttr Act Stctio* AO* Cm 123 Subotrl M; Mtrint
Pretoction Rtvourctt ond Sonctuory Act S*«tion 10))
NOB trootswnt. otorogt or ditooool of h«»rdouo nott
proMBitm
(AO cm 2*A
•Ugrttory bird fligM potttrn Nlgrttarr iird Trtotr Act
Am tffoctlng lokt* ond
otrt***
Ndbitot for M
lokt in Indtono
••It
Nulnt
roaou* fitn Conotrvotion Act
1 Prottctien Act
•itnin floodplain in Indion*
loko *r**tr«ttion Act
(1J-I-U.J)
flood Control Act
(1J-Z-22
Nonooot tnd tndo-gered Specitt Act
•itnm Indian* noturt pr*oer«e Nature *reaer«tt Act
Indit^t xobittt uoon «n
neng»-» o; tndongcrtd
optcit*
•tt avolicobli
OMlictblt
••)•. opolietolt
Not opplictblt
"«•- opplicttit
is*, toolictslt
Ao-iie*£lt to ••'.:••'t of sr
nttr «l'.t
Agclietilt to >ttl<*:i or or
ntir lit*
NO: ooeltcieic
NO*, opplicclt
Aoplicobl* te »trtr» o; n»«r
or or notr titr »"t::»c B>
tcti»i'.iit
Not oopliciblc
Not oeoJictiir
Apelicoblr te ttrtt- cr fj»«r
on or n»t
n«tdittion
Not opplictelr
Apolicoblt to trn »"t::*t b<
<- t:ti»titi
Apolieabl* to !•«» or ttrtt* on
or noor tit* t'ltf.t' BT
reaediation tc'.Ki'.itt
Not applicoBlr
Nit applictblr
Not t»olic*bl»
Not OPOllClSlt
»ai opvlictblt
-------
TABLE J-15
MIDCO I
ACTION-SPECIFIC REQUIREMENTS
Page 1 of 9
Table 7
Action
Requirement and Citation
.- Stripping
pping
)nsolidation
Proposed standards for control of emissions of volatile
organics.
Placement of cap over waste requires a cover
designed and constructed to:
o Provide long-term minimization of migration of
liquids through the capped area;
o Function with minimum maintenance;
o Promote drainage and minimize erosion or abrasion
• of the cover;
o Accomodate settling and subsidence so that the
cover's integrity is maintained; and
o Have a permeability less than or equal to the
permeability of any bottom liner system or natural
subsoils present.
Eliminate free liquids by removal or solidification.
Restrict use of property as necessary to prevent
damage to cover.
Prevent run-on and run-off from damaging cover.
Stabilization of remaining waste to support cover.
[*0 CFR 264]
Placement on or in land outside unit boundaries or
area of contamination will trigger land disposal
requirements and restrictions.
[40 CFR 26S (Subpart D)]
-------
TABLE 1-15 (continued)
Page 2 of 9
Action
Requirement and Citation
Direct Discharge
of Treatment
System Effluent
Use of best available technology (BAT)
economically achievable is required to control
toxic and nonconventional pollutants. Use of best
conventional pollutant control technology (BCT) is
required to control conventional pollutants.
Technology-based limitations may be determined on a
case-by-case basis.
CFR 122.44(a)]
Applicable federally approved state water quality
standards must be complied with. These standards
may be in addition to or more stringent than other
federal standards under the CWA.
[40 CFR 122.44 and state regulations approved under
40 CFR 131]
Applicable federal water quality criteria for the
protection of aquatic life must be complied with
when environmental factors are being considered.
[50 FR 307S4]
The discharge must conform to applicable water
quality requirements when the discharge affects a
state other than the certifying state.
[40 CFR 122.44(d)]
The discharge must be consistent with the
requirements of a Water Quality Management Plan
approved by EPA.
[40 CFR 122.44(d)]
Discharge limitations must be established for all toxic
pollutants that are or may be discharged at levels
greater than that which can be achieved by
technology-based standards.
[40 CFR 122.44(e)]
Develop and implement a BMP program and
incorporate in the NPDES permit to prevent the
release of toxic constituents to surface waters.
[40 CFR 125.100]
-------
TABLE 1-15 (continued)
Page 3 of 9
Action _ Requirement and Citation _
The BMP program must:
o Establish specific procedures for the control of
toxic and hazardous pollutant spills;
o Include a prediction of direction, rate of flow,
and total quantity of toxic pollutants where
experience indicates a reasonable potential for
equipment failure; and
o Assure proper management of solid and hazardous
waste in accordance with regulations promulgated
under RCRA.
[40 CFR
Discharge must be monitored to assure compliance.
CFR 122.440)]
Approved test methods for waste constituents to be
monitored must be followed. Detailed requirements
for analytical procedures and quality controls are
provided.
Sample preservation procedures, container materials,
and maximum allowable holding times are prescribed.
[40 CFR 136.1-136.4]
Permit application information must be submitted
including a description of activities, listing of
environmental permits, etc.
[40 CFR 122.21]
Monitor and report results as required by permit.
[40 CFR 122.44(0]
Comply with additional permit conditions.
[40 CFR 122.41(i)]
-------
TABLE 1-15 (continued)
Page ^ of 9
Action
Requirement and Citation
Discharge to POTW
Discharge of Dredge and
Fill Material to
Navigable Waters
Pollutants that pass through the POTW without
treatment, interfere with POTW operation, or
contaminate POTW sludge are prohibited.
Specific prohibitions preclude the discharge of
pollutants to POTWs that:
o Create a fire or explosion hazard in the POTW;
o Are corrosive (pH <5.0);
o Obstruct flow resulting in interference;
o Are discharged at a flow rate and/or
concentration that will result in interference;
o Increase the temperature of wastewater entering
the treatment that would result in interference
but in no case raise the POTW influent
temperature above 104°F;
Discharge must comply with local POTW pretreatment
program; and
Uo CFR 403.3 and local POTW regulations]
RCRA permit-by-rule requirements must be complied
with for discharges of RCRA hazardous wastes to
POTWs by rail, truck, or dedicated pipe.
[00 CFR 264.71 and 264.72]
The four conditions that must be satisfied before
dredge and fill is an allowable alternative are:
o There must be no practicable alternative;
o Discharge of dredged or fill material must not
cause a violation of state water quality standards,
violate any applicable toxic effluent standards,
jeopardize an endangered species, or injure a
marine sanctuary;
-------
TABLE 1-15 (continued)
Page 3 of 9
Action
Requirement and Citation
Excavation
Ground Water Diversion
Incineration (On-Site)
o No discharge shall be permitted that will cause or
contribute to significant degradation of the water;
o Appropriate steps to minimize adverse effects
must be taken; and
o Determine long- and short-term effects on
physical, chemical, and biological components of
the aquatic ecosystem.
[40 CFR 230.10 and 33 CFR 320-330]
Movement of excavated materials containing RCRA
hazardous wastes to new location and placement in or
on land will trigger land disposal restrictions.
Excavation of RCRA hazardous waste for construction
of slurry wall may trigger cleanup or land disposal
restrictions.
Analyze the RCRA hazardous waste feed
[40 CFR 264.341]
Dispose of all hazardous waste and residues including
ash, scrubber water, and scrubber sludge.
[40 CFR 264.351]
Performance standards for incinerators:
o Achieve a destruction and removal efficiency of
99.99 percent for each principal organic hazardous
constituent in the waste feed; and
[40 CFR 264.343]
o Reduce 'hydrogen chloride emissions to 1.8 kg/hr
or 1 percent of the HCL in the stack gases
before entering any pollution control devices.
[40 CFR 264.342]
-------
TABLE 1-15 (continued)
Page 6 of 9
Action
Requirement and Citation
Land Treatment
Monitoring of various parameters during operations of
the incinerator is required. These parameters
include:
o Combustion temperature;
o Waste feed rate;
o An indicator of combustion gas velocity; and
o Carbon monoxide.
Special performance standard for incineration of
PCBs.
[00 CFR 7611.70]
Special requirements for incineration by Indiana
Department of Environmental Management, including a
trial burn and extensive sampling.
Ensure that hazardous constituents are degraded,
transformed, or immobilized within the treatment
zone.
[00 CFR 260.271]
Maximum depth of treatment zone must be no more
than 50 feet from the initial soil surface, and more
than 3 feet above the seasonal high water table.
[00 CFR 260.271]
Demonstrate that hazardous constituents for each
waste can be completely degraded, transformed, or
immobilized in the treatment zone.
[00 CFR 260.271]
Minimize run-off of hazardous constituents.
[00 CFR 260.273]
Maintain run-on and run-off controls and management
system.
[00 CFR 260.273]
Unsaturated zone monitoring.
[00 CFR 260.281]
Special requirements for ignitable or reactive waste.
[00 CFR 260.282]
-------
TABLE J-13 (continued)
Page 7 of 9
Action
Requirement and Citation
Slurry Wall
Treatment
Underground Injection
of Wastes and Treated
Ground Water
Special requirements for incompatible wastes.
[40 CFR 264.282]
Special requirements for
F026, and F027 wastes.
[40 CFR 264.283]
F020, F021, F022, FG23,
Excavation of RCRA hazardous waste for construction
of slurry wall may trigger cleanup or land disposal
restrictions.
[40 CFR 268]
Proposed standards for miscellaneous units require
new units to satisfy environmental performance
standards by protection of ground water, surface
water, and air quality, and by limiting surface and
subsurface migration.
Treatment of wastes subject to ban on land disposal
must attain levels achievable by best demonstrated
available treatment technologies (BOAT) for each
hazardous constituent in each listed waste.
[40 CFR 268.JO-13]
BOAT standards for spent solvent wastes are based
on one of four technologies. Any technology may be
used; however, if it will achieve the concentration
levels specified.
[RCRA Sections 3004(d)(e).(e)(3)
42 U.S.C. 6924(d)(3).(e)(3)]
U1C program prohibits:
[40 CFR J44.12]
o Injection activities that allow movement of
contaminants into underground sources of drinking
water and results in violations of MCLs or
adversely affects health; and
o Construction of new Class IV wells, and operation
and maintenance of existing wells.
[40 CFR J44.13]
-------
TABLE 1-15 (continued)
Page 8 of 9
Action _ Requirement and Citation _ __
WeJls used to inject contaminated ground water that
has been treated and is being rein jec ted into the
same formation from which it was drawn are not
prohibited if activity is part of CERCLA action.
[00 CFR
All hazardous waste injection wells must comply with
the RCRA requirements.
[00 CFR 100.16]
Owners and operators must:
[00 CFR 100.26-27]
o Submit inventory information to the director of
the state UIC program;
o Report non-compliance orally within 20 hours; and
o Prepare, maintain and comply with plugging and
abandonment plan.
Monitor Class I wells by:
o Frequent analysis of injection fluid;
o Continuous monitoring of injection pressure;
o flow rate and volume; and
o Installation and monitoring of ground water
monitoring wells.
Applicants for Class I permits must:
[00 CFR 100.55]
o Identify all injection wells within the area of
review; and
o Take action as necessary to ensure that such
wells are properly sealed, completed, or abandoned
to prevent contamination of U5DW.
-------
TABLE 1-15 (continued)
Page 9 of 9
Action _ Requirement and Citation __ '
Criteria for determining whether an aquifer may be
determined to be an exempted aquifer include current
and future use, yield, and water quality
characteristics.
CFR
Case and cement all Class I wells to prevent
movement of fluids into USDW, taking into
consideration well depth, injection pressure, hole size,
composition of injected waste and other factors.
Conduct appropriate logs and other tests during
construction and a descriptive report prepared and
submitted to the UIC Program Director.
Injection pressure may not exceed a maximum level
designed to ensure that injection does not initiate
new fractures or propagate existing ones and cause
the movement of fluids into a USDW.
[00 CFR 106.13]
Continuous monitoring of injection pressure, flow
rate, and volume, and annual pressure, if required.
Demonstration of mechanical integrity is required
every 5 years.
Ground water monitoring may also be required.
-------
CO
Ol
«t. it MA i IK s*
*-ia
mm APH.IC/M.C i/»s AM> ICCU.AIICNS
ts" Of Hl'«|ll I .it IIHI
HI* BM.
NeMurct Conservation and
Reco»err ("CNA) - Suhlitl* C
•0 CM It! Mondtrd for
Oiirrclor*
*0 Ctd I«4-Z»i Stondsrd* for
owier* *nd operator* of
h*r*(dbus ••ale trtstoent,
•torsu* md disposal
fSCllltlfS.
Allernsliv* Kill involve treatment/
diapoasl of heferdou!! vvsle.
(CH» ornrr«lor itqulolion* *pply*
!•• "ill require use of
ICRA-perailted facility in roi—
•ith current KM rrguUtton*
Allrrncti»* mil rrquir* use of o
RCRA-pttBiltcd ftcilily in ro«pll«nc*
X 31 3! 31 3E
Alternative
i i
is—m—IE—31—~n
III
I I I I I I
Ml Haiirdou* N*|rri«U
Irwiipart Mule* («» OH
SitictwpUr C) **t RCM -
SuhliiU C Slmdard* for
lrwii|«>rUr« *n a* HI
Clevi MB|tr Act (C»»)
40 or* f«rl» 127,
md Su>p»rl N
follutont DiKhorq
Cliiinttion S>«|«*
(NWCS)
M cm
Cuidclinct md St»od«td»
Slcndcrdt
r*Jnir«l Mclrt
CM Ground Wiltr Prolrclion
llnillh *cl Or.ll*)
r>rl IV10 (IMM Sl
III! II- *M*VI|I V(H I'll llMlll
Act ini(tr*lion prelrralocnl in Indian*
•ef*r to oection on dot* rrqulotiono.
I I
loeo ••jr not result in raplionc*
•ilh fvOC in *urfoco **t*r.
this *lt*m*ti«* «i|| not ott*in
ffA'o around »*t*r protection slrsleqr
for oquifer.
l«ple«enl*t ion of tins •Iternelive "ill
require "or* an the site, forkim)
rondilinna •unt Msura wfttr and health
of varkcra.
flll-tl>nl»BIM*lrJ •nl«ri>l| Ifmmr, rtlt
levela or* not *t ooicrnlrvl HVK
} dionossl requirnwl«rae
Alternative mil nut mult in
coaplionc* "ilh criteri*.
III
III
-------
nr Hr-nulnl ion
Clran Air Art (CM)
Safe Drinking M«|er Act. Uvler-
oround Injection Control (UIC)
froqr**: triteri* end Stenderdi
(*0 OR Perl Ut)
Uklerqround Injection Well Perait
Marine Protection, Research end
Sanctuenes *cl (W OR Pert
. I20-II9) Oct«n OimpirK)
Requirement!
Rixlioictite *»te Rule -- High
lot level
National Register of Historic
Piece*
Mild end Scenic Riven Act
(W OR Pert «.»]>
Irklnnqered Specie* Act
Protection of threatened or
endangered Specie* end Iheir
Habile! a (JO OR Pert tOI)
fish end Hildlif* Act
Coniervttion of Mildlif*
Reiource*
Coastal lone Nanaqea«nt Act
(I) CTR 920-«2i>
Unfoiaj Relocation Assiitenc*
end Real Proper!) Ac<|ui*ition
Policiet Act of I*?* (to OR «)
(•eculive Order* for flood Plain
(1011988)
(•fi:uti%e llr«lera for Wetland*
(IIIIIV9U)
Nutional In»iroiiavnlal Policy
Atl (MPA)
AHTHMAII
•cnt
Implementation of this ellernallve may
result in the emieaion of pollutant*
into the tir though bcloo regulatory
limit*. * Permit ahuuld not be required,
but neceaeary technical requirement*
• I 11 be met.
On-*ite e«c*vation may result in the
a)iort-t*rm cmiaslon of participate*.
On-*lie personnel Mill be atlequtitcly
ptotected. Cfforte to •itio.ile relto*
•ill be Mde.
Al i l»m:«il wterial*
in the ocean or incineration at sea.
dialing records indicate that the aile
doe* not contain high- or loa-lev*!
radio*cti>* ••*!•.
lepleoentction of the alternative* "ill
not effect site* on the register.
River* on the national inventory "ill not
be affected by alternativea.
Implementation of the alternat ivea "ill
not affect threatened or
•pectea *nd their habitat.
Implementation of the alternative* "ill
not affect area* of important mldlife
resource*.
Implementation of the alternatives "ill
not affect • coaatal /one.
laplemsntation of the *llernative9 ohould
not require relocation of reaidencea or
bu*ine*ae* or acquisition of property.
Implementation of this alternative "ill
not occur in • flood plein.
Implementation of thia alternative may
affect • "elland.
(IRIXA actions are exempted from ntPA
requirement a.
Allrrnul I vert ulmuld itut ufltrcl ll**'ne
reaource*.
t-IH ,
MIIH AfniCAUt IA»S AM> ICCU.AIICNS
AHernalive
tfl tC tt >A >C X
I I I I I 1
III
>C 4 I
III
Kill
I I 1 I I
III
I I
I I
-------
Ulll «-IS
ctmiAMii MIIH Ant iCAitt JAMS AM>
sun
Altrrnat ive
»A
«C
>C
iC
-i.J-JL.JL
Prui|r«M - Indiana
I nvironevnlal H;«i»|Ment lluard
Article « (WO-IAC-*)
Rules I. >, *. Masle
Cenerul ion Identification
Standards (ot Generators,
Rult
«pplic»bl*
Mule 6 Oluo.ljf.la
la llMiirrs I*M| I^M
Maotc l
nl
Hiilr
Rule 8-9 Hajirduui W**le
f«cilil| Construction and
Op*l»tt«g P«l«it
Indian* Matte Irral'cot
facilitita Rnjulation -
lillt )JO - Article ).l
facility Construction
Articlt i Industrial
•altr rrttrcalient and NIKS
Proqraaa - Rules I - 10
Rules II-It Pretreatwnt
Standards
Indiana Hater Quality Standards
fitrea* Pollution Control Board
910 (*C Aiticls 1-1. Stclton 4
Malar Quality Standard
Indiana Air Pollution Control
'.HCAl
/oning
Ihia alternative will involve ull-aite
diapoaal of haiefdous na*le and
9tner«tor requlatiuna apply.
••pleamtation of Ihia •llernalive
inclulca the o'f-»ite tranaport of
nanruou* "atenala. Ins tranaport of
Ihrie aaleriala mil be in ciHplixnca
• ilh ttjeae rulea, includim| use uf
properly cona true led and Mttril
Iraiiainrt vrhiclas. uae of lirmiinl
Iranauurlers, and ma of hazardous
•nala awiiifeala.
Ihia allerii«tive Mill b« cutiuiHtml with
current elate regulation* alllei*|li in
perait Mill be required.
Ihia alternative Hill require Ine ua* of
• etata-peraitled facility in coaplianc*
•ilh current stats regulations.
Ihia alternative Kill require
construction of • Basts treetevnl
facility *»d mil be conaistenl "ilh the
technical requirement of Article I.I.
laple*enletion of alternative "ill not
reautt in an on-aita point source
diacharqa. An NPOCS parait Bill not be
required.
Not applicable. l*ule>entation of
alternatives mil not result in discharge
of a »astc strea* to a putalicly-oxned
Irealaent .orha (POIM).
laplrventallon of alternatives "ill
not result in noncoopliance v>ilh Indiana
Matar Quality Stamlarda.
Alternatives "ill be consistent "ith
the technical requirement of current
Indiana regulation.
Allernitives *ay require no
diaiige.
I I
I I
I I
I I
-------
TABLE 9
COMPARISON OF CONCENTRATIONS OF INORGANICS IN SUBSURFACE MATERIAL
AT MIDCO I WITH CONCENTRATIONS IN LISTED HAZARDOUS HASTE (FROM
BOAT BACKGROUND DOCUMENTS FOR TIE FIRST THIRD HASTES UNDER LAND BAN)
CONSTITUENT CONCENTRATIONS (mg/kg)
Source
K101
K102
K061
KM6
K048
K049
K050
K051
KQ52
Arsenic
590-1950
3060-8320
Qiraniin
Lead
Cadnitn
1730
O.M-3435
28.9-1400
11-1600
0.1-6790
20300
967
0.05-1250
V
21.95-3900
0.25-2480
11-5800
44
I
ite Soils
ND-49
2.2-1021
2.8-4900
M)-12
-------
UIM «.]
IIIICIIMNTSS cyyuMirn or X.IKHAIIVTS
03
PMIPllCHVINIS', Of IIIHAN If M III AMI INVIRIWUNI
MIHMI HIM
PRUirCIIVTMSS If IIIHAN If M III MO (NVIRIMCNI
KINK UKM
HoucunN (i IUIICIIT. mauiir. OH VOXIM
Alternative
Uoes >«l reduce potent ml pulilic health rink
associated with contaminated toll* if eicevJled
•nil exposed or qround water if muesleil. Mould
nnl ro*|>ly with chemical and Inrellon-^irrific
ref|uirrmente •• veil a* criteria, ailvisuriee and
guidance.
f'isilic health riefc euete for inqestton or dermal
absorption of e>cavater>it of derd
reitrictiona and •aintenance of the xile, fencinq.
and rroaion protection, 'otential for con-
!•• mated qround water drqrailatlon Miild be
leaaenrd by inhibitinq aurlare aaialure infiltra-
tion (and thua, contact Kith potential
contaBinanta).
Risk* to the >orkera and the cnMunity durinq
medial action can be adrqmtvly rontrollrd hy
rettrtctinq accef* to aite to authorned pertonnel
only, and condiictinq action «ith adeiruatv health
a»d aafaty precautiona.
final protection fro" exposure to on-site
contanination la achieved icnm ctiapletiott of cap
construction, approxBately I year after
initiation of conitiuction.
Cleanup action le*ela (CM.a) for aoil and qround
•eter fill not be Ml a* aoil reaain* vithout
trrataent and qround vatar that haa •iqrated off
aila "ill not be treated. Continued potential for
qround vater oVqtedit ion eiiete due to lateral
qround xater •iqration. Surface water
contaninanta a«y be worsened by continual
discharqe of contaminated qround water. Deed
restrictions and aite •aintenanc* or* provided.
Need for replacement will be baaed on cite
maintenance over time. Performance of properly
installed multi-layered cap la generally good for
first n yeara of aervice. Integrity of synthetic
liner after Ihia time becomes uncertain and should
be investigated regularly. Punctures of the liner
by deep rooted plants and burrowing anIBS Is will
affect the performance of the cap. If remedial
mrlion fella, risk is similar to no-action
alternative, the coat for remedying failure would
be aimilar to the coat of original Installation if
it ta detected before more qround water moves off
site and if the area needmq repair could be
located. If not, coal lo remedy Kill involve, a*
a minimum, • qround water option to remove the
escaping contaminanla. Contamination may move
vertically through to the neit aquifer. Ihia
•(pilfer ha* very little yield, and I* not used for
drinking water purpose*, (tailoring of the
confining layer mhould detect movement. * ground
water e«tract ion system could be employed if
warranted by emmpltng. Coata would b* eiwilar to
ground water opt lone, without ground water uae
restrictions, the- remaining risk st.tne tit* after
remediation completion is 4.1 > 10"*. Vitti
enforcement of qround water use restrictions, all
risks would be reduced below acceptable levels.
Reduces mobility of eontaminanta in Mil but doea
not oiqnificanlly or permanently reduce toncity
or volume or reduce the mobility of conlamjnanta
that oro already in the ground mater.
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•AIM »-i
MIDI II I
mmivtmss i»«i.wiinM ir
rm>IICIIVTM_V;
IH HAN II »l III AMI INVIMINHNI
•JIIIHI II MM
rmiu cilvtmss nr in MAN ir«ilii «M> INVINIMVNI
um; HIM
<* tunciHr.
. on VQ.IK
Alternative )
Safety concrrn during installation rel«l«d to
e>revitton •rtivitiee. Hisk« la »orker* «nd
co»unity durinq rraedul Mrlioii, csn br
s>irn,imlely controlled br re»lricl-i«i| ocrr'is la
tl*c nil* In siitttur l rrJ (irriimHiel titly, H*M|
conducting act inn with Mir quite lirslth and tulrlf
precautions. Protection aipim*! principle three!
cen be achieved upon completion of construct ion,
•pproiiMtely I to 1 yeer*.
I'leanup action level* (CAl«> for Mil *nd ground
•liter vi 11 not be e*t beccme no Irectswnt I*
provided for either, tliainntr* direct canted
exposure to contNainant*. CntiliMinnt Inn any «n¥r
•••rlirtllr In nr«l vqulfrr. Ihis a<|iil'rr hni ittf
little yield, end •» not used for drinkimi ••ter
put pot el. Mgnitorinq of the twifminq ltrer
slxiuld delect •ovtvent. A ground miter eitre-ction
Spain could be explored if "trrtnled by teapling.
tost* oould be ti«iltr to ground ••ter option*.
Iwig-terB occe** lettriction muld prevent future
e'poture to re*idu*l*. In contMin*t*d
«fi«iron*mtv effect i vene** over long-tera depend*
on type of contt»in*nl* tnd concentr*tloni. High
••It t»d orqtnic concentr«tion* My effect
nrr«r*bilttjr of «*ll, resulting in need to rrplece
•rtlea in long tera. If f>iled, rick* *r* ti'iltr
In no-Klion. I he colt for reoedying fcllurt
•ould be ti«ll»r to, but higher rn*n, th* cott of
origin*! in*t*||*tion if it I* detected before
•ore ground wtler •ove* off cite tnd if the *re«
needing rrptir could be looted. If not, cott to
revrdy vill involve, •• • •iniaut, • ground t*«ter
mitiun to reaov* the e*c*ping conltaintntl. After
rrvediction it completed. *ll ri«k* *r* reduced
belo" *ccept*tal* level*.
reduce* aoblllty of cont**in*nt« in
•oil end ground »tter, but doe* not reduce
toncity or voluw.
Alternative »*
Alirrn*live «B
Protection •ill be (thieved hy inteireption of
ground vcter, capping, deed reitrirlion, tnd *ile
••intenence. Hr-edltl tction •rtivilin B*y not
roiMence for I to 2 yeir*, •* • Petition
Oraonttrction for deep veil «mt br ipprovrd by
CPA. Construction of revedi*! »ciiu" thould l»ke
I ye»r«. »it*» to oorfcer* Mid co«>i>iity during
re*edi«l Klion c*n be (deqiMtely controlled by
restricting accet* to «ite to wilhorired pei*onnel
only *nd conducting *ctlon Milh *dei|u*t* hetllh
•nd **fety precaution*.
Cleanup eel Ion level* (C*lt) for Mil fill not be
•el •• 0011 re*oln* >itHout tre*t*ent. the ground
••ler Ihtl h» •igtatrd off »ile mil be revived
irfier* CAl* *re e«ceed«t tnd ground rater CAl* on
•it* would be Bet. A c«p tod erctti restriction
• ill prevent Mil mgestion end der*«l •bsorption.
Piilentiel for foilur* of technical co«ponent* i*
•••ll, but vill require routine evintensnc* end
replacement. If fetlrd, risks *l lite *r* si'ilsr
to m-*ction. If contwtimnt* leave deep equifer,
cost to reaedy •ill be "toy ti*e* the cost of
origins) re*edie.tion due to otrsl depth end
difficulty of •onltoring. After reaedistion I*
cu^ileted, if deed restriction end site
•sintenence tre performed, ell r»ks *r* reduced
belo« scceplsbls Isvels.
Significsntly snd pervcnently reduce* aoblllty of
contwtinmt* in the soil but do«s not reduce
toiicity or voluie of so"* cont*»ln«nls in Mil.
Signific*nt|y end pcr«*nently reduce* soblllty *f
cont*ain*nt* in ground Better but dos* not reduce
toncity or voluM.
Protection Bill be schievr*! by intercrption of
ground >ster, cspping, derd restriction, tnd site
••Intenmce. Mrvcdisl ertion nrti«itiet •«» not
roMmce for tt lectt I >e«r. »^ *|ipro>*l for Ih
option Mint he i4>t*lnrent. the ground
•nlrr Ihst hs* •igreted off site Mill be removed
•riVre CAI.S *re eiceeiled snd ground ••ler C*X« on
• lie "tm Id lie Bel. A csr> «"d •« «os reetrictiim
• ill prrvrnl not I inil* of reordy vlll rnruire
routine oprrvl ion, •ointennnce end replsce*ent.
II feil!i, risk* tt site ere siailsr to no-oction.
If conlMiinvit* Irsve deep squifer, cost.to reaedy
•ill br asny I!•*• Hie cnsl of origins!
rmrdislion ihie to greet depth *nd difficulty of
•Hiilnring. After re»rdi*tion is coxpleted, if
«h*rd restriction* und *ite ••mtenence ere
performed, all risks ere retiuced belw •ccrpt«ble
Irvel*.
Significcntly snd perasnenlly reduce* eobilily «f
contceiinsnl* in the Mil but doe* not reduc*
toncity or volume of eo*e conleaincnts in soil.
Significantly *nd peraenently reduce* eobility and
tuticity of cnnlaaiitant* in ground voter but dbee
nol reduce volume.
So»e contsaintnl* in ground «et»r sre Irensferred
to cerbon cvusler* >hich srs disposed of off
• lie. ODC* not significantly or perasnently
reduc* lancity or aobility of thss* residuals.
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1*111 »-z
HIIHO I
iftccnrtntss UfAtiiAiim or M. iti*«M»f s
pHQ.itciiviNf.ss or inn AN IIM.IH ANU INVIMWHTNI
f*IUBI IIW
rmmctiviNiss a i*nm IIM.IH AND
IUNC Hm
a IIHICIU. MOOUIIT. on va.ix
Altrrnitive »C
Protection mil be echleved by interception of
grotnd water* capping, deed revtriction, *nd vile
•aintenance. Ajiproval for thie option tltould not
unduly eloM Ktion do*n a* ciiuteainenle mil he
reaoved to drinking Mater quality eicepl eetinity
before injection. Construction of reoediel action
ehould take I yeer*. ftitfce. to Morker* and
cuMunity during remedial action can be adequately
controlled by restricting trees* to aite to
euthnri/ed per*on»el only and conducting action
• ith adequate health and aafety precaution*.
Cleanup action level* (CM.*) for *otl Mill not be
•et »f soil reoaina Mithout treatment, the ground
vater that naa Migrated off aite »lll be removed
where CM, a are eiceeded and ground Mater CM. a on
aite Mould be e«t. In* le»el of acetone being
injected into th* deep •«!! o*y e»ceed tha CM..
No ntX or NCVC preaently tint* for acetone. *
cap and *cce«* reel r let ion oil I prevent Mil
Migration and derawl abaoiption. Potential for
failure of technical coaponenl* I* increaaed du*
to further eo«pleiity of treatment proceaae* and
•ill require regular operation, aamtenance, end
repl*cea«nt. If faila, nek* at aila are aiailar
to no-action. If Mater leavea deep aquifer, tinea
thia i* not a drinking vater aquifer, the
increaaed aalintty should not pott • problao).
After rrvedietion it co^ileted, if deed
reatrictiona and ait* Mintenance are performed.
•II fit** are reduced beloo acceptabl* levela.
Significmtly and peraenenlly reduce* aobility of
conteamant* in I he Mil but doe* not reduce
toilclty or volu>* of *oa>* contaaiinanta in aoil.
Significantly and pvrawtantly reduce* eability and
toncity of contaaiinant* in ground n*t*r but dot*
not reduce voluM.
SOB* conta»in*n|* in ground Mater are trana'erred
to carbon c*ni*ter* and Mtala (ludga* Mtiich tr*
ditpoaad of off ait*. Ooea net *ignificantI. or
peraancntly reduce Uileity *>r Mobility *f thaae
retidualt.
Protection *g*in*t principle threat "ill be
echieved by interception of ground. MMler, capping,
deed reatriction and ail* «finte«ence. Nvroval
for the evaporator *y*le*> cnould b* recdily
obtainable •• thl* i* convent tonal technology.
Conttruction of r*a*dl*l action enould take I to I
year*. Ulafc to Marker* end coMunity during
re*edi*l action can b* adequately controlled by
restricting accef* to *it* end conducting action
Mith adequate heilth end aa'ety preciution*.
Cleanup action level* (CM.*) for *oil will not b*
•rt ** aoil re**ma MI!hoot treat>«nl. the ground
Mater that haa aiigrated off *it* Mill b* removed
Mhrre CM.* are eiceeded and ground Meter CM.a on
ait* Mould b* act. A cap and *cc*** reatriction
Mill prevent aotl Ingettion and dera«l *b*orption.
lechnical component* of action *hould not fall
Mith adequate operation and Mintenanc*. After
remediation i* coopleted, if deed r**triction* end
ait* •ainlenanca aie perforoed, all riak* are
(educed below acceptable l*v*l*.
Signific*nt|y *nd peroanently reduce* aoblllty of
contaminant* in the toil but doea not r*duc*
toncity or volua* of *OB* con«a»inanla in aoil.
Significantly and peroanently reduce* aobility,
toncity, tnd »olu*« of contMlnant* in ground
M*t*r.
Soa* ctmt*ain*nt* in ground Mater *r* tranaferred
to aalt cryalale Mtilch *r* diepoaed af *ff tit*.
Do** not *ignifleant(y or permanently r*duc*
toiicity *r eobllily •' the** r**idual*.
Alternative >*
Safety concerne during the re>«diel action are
releted to th* excavation of the avterial. Hiak
to th* Mork*r* and th* cowuntty cm be edrquately
controlled by restricting accea* to the aite end
conducting action Mith adequate health end M'ety
precautiona.
Cleanup action levela for aoila above ground M*t*r
level Mould be a«t. CM.* for will beloM ground
Meter e*y not b* *ct| nooever, riak calculationa
era baaed on ingeation of aoil, and the**
a all* but transfer* th* arable*) to th*
landfill til*. Obet not reduce voluae, eobillty
•r tancity *f conteailnanta in ground M*t*r.
-------
(AIM 0-1
MIDI (I I
CMfCMVlhtSS tV/HUAIIu* Of *,lt*H«'IVt5
pun it c 1 1 vi NT si i»
Mm* 11 « in «M>
II !«
prniticiivlNtss w WHAN if M.IH AND INVIRIKHNI
IIINI; HNM
H.IMCIIIM ir KHICII*.
on VH.IK
Allrl'ietive >C
Ssfrly toner-rue iluring II* riwrilisl art ion ere
(rlalr-l In the r>c«»sllnn nf the •nlrllnl. Mink
lo Ilir «oek»is •»•! tht ctMiftily <•» lie eilrgiMlely
controlled by rrr.lrict ing arm* to II* tile '""I
cutMlurtmg action wllh ertrqiMle health end aafely
prereulions, end providing eilrquate emssione
cu*tlrol. II vill be necessary In perfnra
treelability studies lo edeqiulely iit**rnl«/*ul»illil* (mcliilinq • trial burn)
•t ••!! •• lh« bickloq •! lOCN, rnrdiition of tht
•oil* My nnl beqm for up lo I yecrt. Coaplelton
of condruclion olould b* lr>t then I »e»r. lh>
•cluol nil r«wdi«iion irnuld b* lri» then I
»*»r.
rir«iiu|i icllon le»pl* for will* cbovr groifxl »nl«r
lorl •mild be Bel. tAl* Inr "oil* brio* qrouiid
••l«r mat not b« "^'l lound*.
future e»po*ure to renduala Mould be ainiMl. M
faila. nalia ar* aivilar to no action. I he cult
for remedying failure of aolidification tmuld b*
aiaiilar to the colt of original inatallation.
Nitlwut ground valtr uae realnction*, the
rrletion la 4.) « 10"*. With enforceawot of
ground rater uaa restriction*, oil riafca muld be
reduced belov accepteble levele.
Significant If and pe'ianrnt\i reducea toiiclty
and lability of conlMineiil* in toll, but doe*
not reduce loudly, aobilitf »f volua* of
contaBinanta in ground Hater.
Allrtnative
Safe!* concern during invlalliit ion ansocialeil with
nrevetion imd oinng o< conlaninaled a«lerial.
Kisli to voilier* and co"*ur*ity ikirtng re*rdial
action can be aJn|u*lelr controlled by restricting
accei* and conducting actions with arteqiiale health
and aa'et* preciulions. It «ill be ntcrss*ry to
orrfor* tre*tebilil> Itwlirs to adequately
deaooatrate that the aolidified aoll can cunforaj
to procedure* aiailar to delisting. Ihia aay
delay initiation of construction. Completion of
construction ahould b* I year.
Cleanup action level* for soil* above growid rater
level vuuld be met. CM.a for aoila beloo ground
rater Bay not be Belt however, risk calculation*
are based on ingest ion of soil, and these
additional solids trauld be belon the rater teble
end un*v*ilabl* for ingest Ion. Attenuation
result* in • dissipation of contaminant*, although
it will be many year* before ground rater cleanup
action levels will be attained for ill coapound*.
future eipoaure to reaiduals would be minimal. If
treatability studies *r* properly conducted, there
•SouId be • loner likelihood for needing
replacement. If faila, risks sr* siallsr to no
action, the cost for remedying failure rauld b*
aimilar to the coel of original inslsllstion.
Without ground rater u*e reetriction*, Ih*
remaining risk at the (lie aftar remediation
completion is «.> • 10"'. With enforcement of
gruuid water use restrictions, all risks would b*
reduced beloo acceptable level*.
Significantly ami peraanently reduce* aobility ef
contaaiinant* in aoll, but doe* not reduce
toncity, aobility or voluae of contaaiinanta in
ground rat*r.
-------
i i n-t
Ml III II I
IIIICHVINI'.G IVAHKIIfM B atltHV«IIVIS
milHCMvl X Si ur HUMAN it «i Mi *NO
II IM
or INHAN IIM.III mo CNVIRUNHINI
tour, ii m
mnciiOH or rominr. Hnnii.ii*. OH VOUK
allrlnallve it
Iterance no excavation of material ornir* and ill
of (he materials are Ireuteil in • hnnd, risk in
miinmiirtf *fter ce«edi*tion completion I* ».* « 10"'.
With enforcement of qrowid veler use restrictions,
•II rink* »ould be reduced beIox acceptabl*
level*.
Sinnific*ntl|r and permenently renl
•olidif ic*t ion. It Kill be ntrrn:.»rj to perform
Ireetebility slmlin to drmondrele thst the
•olidtftetl «»le con confnra to procediites sts»l*r
to NCP.A deliettnq. (hi* may ileler constructimi
initiation. Conetruction of remedial action miuld
lah* I la 1 year*. Minks to II* wirkers and the
rommieiity durinq remedial action con be adrqoatelv
controlled by restriclinq accrss to the sile lo
authorited parwmnel only and conductinq action
•ith adequate health and safely precaution*.
Combines the lonq-term effectiveness of
Allrtnativrs I and H. Cleanup action level* for
•oil *bov* ground naler mill be met. CM.* for
soil beloK qro»*tet any not be metl nonever.
riak ralculetion* are based on inqestion of soil.
a>kl thia vould be unavailable for inqeatl«n.
r,found naler cleanup act ion level* vould not be
met an *ile. Contamination may move vertically to
neit aquifer, nbnitoring of the confining layer
ahould detect movement. A ground vater *«tr*ctlon
syltem could be employed if narrented by sampllnq.
Costs vould be similar to ground »ater option*.
Ihe coat for remedying failure vould be nailer to
but higher than the cost of original installation
if it I* detected before more ground «ater move*
off sit* and if the area needing repair could b*
located. If not. Coat to remedy will involve, M
* minimum, a ground vel*r option to remove the
escaping contaminant*. After remediation i*
rnmpleted, *ll Make *r* reduced belov *ccept*bl*
level*.
Significantly and permanently reduce* mobility of
contaminant* in aoil and ground «*t*t.
-------
lAH'.l «,/
NIMU I
CIUCIIVIM'.S tVM.liMI(* ir
VNUtlttlVtNI-iS Of IDHW4 II M III *fll tNVIHirtXNl
•JNIHI II IM
or ItlMHN II will M) tNVlRINtCHI
IHNi; HtH
HnmiinN r« iniiriiir. muiim. OR VIXIM
Protect IIMI *i|.itnst principle Ilirral will tie
;icl>te»ed l*v ipownl water mterrrf»lion ai*|
"oil.Illiriilnm. Nraeriial ecliun activities lor
tjruipid wilier any not coMirnce for I lo I ye;irs as
• Trillion Oraunstrat ion fur the derp well amt be
w»|iiaved. II «i 11 be necessary la perforo
trealsbillty studies lo n>Bnn*lr*le the! I he
solidified waste can confora lo procedure* eiailar
lo He** Oeliating. this MIT delay construction
mil lit ion. tontlrurlian of trie remedial action
would take spprouaetely I years, disk* to lh«
workers end the coaaimly durinq rrvrdict »cl ion
c»n b« « rtttrictinq (cccst
lo lh« »ll» to .uthorirrd personnel only md
conductinq cclion «llh •dequcte h»»llh «nd M'*t|p
precaution*.
Tiartunr* the lonq-ler* elfttllvrotM of
Alttrmttives »» •nd M. Clewivi)i «lion lc«*lt for
sniI ibnve qroi»xl vatrr >ill be "el. CM.1 'or
•ail belox qrooxl mtrr ••» not be "»l| nonener,
risk c»lcullt lon> ere bued on inanition of »oit.
•Ml thi* vould be t«ie.>e.i Ublt far inqestion.
T.round vcler clennup oclion lr»eli "oold be Bel.
If contMinint* le«»e drep «quifer, toll lo rr*edy
mil be ••nr ti*c9 llw co»» of oriqinvl
rtoeiliotion due lo qrrel drplh md difficult? of
•onilorinq. Hfler re*edi»tion i« coapleled, til
rieJi* «r» reduced below acceptable levela.
Per».menll> nod aiunif icanl l|r reduce* lability of
conlaninwt* in Mil tnd qround Mter.
Allernalive •
Protection mil tw arnievrd by ground »ater
inlerception/tteat*ent an«t nolidtf ication.
•fiproval for tin* option should not unduly *lov
action dovn a* ronlaainanl* Mill be reaoved lo
drinking «a»tr quality eicept lalinity before
injrclton. It mil be neccaaary to pertor*.
Irealabilily atudie* to dtoonalrate that the
•olidified vaile can confor* to proredurea
lo KM*, oeliatmg. lhia B*y delay construction
initialion. Conatruclion of rowdial action Mould
take 1 year*. Riaka to the uorker* and (he
coBBunity during rr**di*l action can be adequately
controlled by rittricting accea* to th* ait* to
authorlred p«r*onn*l only and conducting action
nitti *d*qu*t* health and aafety precautiona.
Cra»binea llw Inng-lera; effecti>ene*i of
Altemative* »C v>d X. Cleanup action level* for
Mil above ground naler mil be Bet, Ma for
noil beloM ground itater Bay not be Mil however,
risk calculations are based on ingeation of Mil,
and this >ould be unavailabl* for inqestion.
i:round water cleanup action level* would be Bet.
If water leave* ileep aquifer. Since Ihie is not •
drinking water aquifer, th* incrsssed Mlinity
should not pose • proble*>. After reowdntion is
cuBpleted. all risks *r* reduced below acceptable
level*.
Significantly and perBwnently reduce* eobility of
contBBinantt in toll and th* Mobility *nd tonctty
of conlsBinente in qround watsr.
rontwwinanl* in ground water are transferred
to cstbo" counter* and th* B*t*l* (lunge* whicti
•re dicposrd of off site. Doe* not *ignitic*ntly
or perBaneiitly reduce tomcity or sobiiily *f
the** rasiduals.
Ollernative V
froleclion will be achieved by ground water
intercept lon/evaporat ion and aolidif test ion.
*Tpfo»*l fof th* *vBporator ayste* should be
readily obtainable •• Ihie I* conventional
technology. It will be necessary lo perforB
Ireatabilily studies lo newonatrete lhal the
solidified vast* can confotB lo procedures viailar
lo RCM delialing. Ihi* Bay delay const ruction
initial ion. Conalruclion of remedial action
atiould t*k* I to I years. Risk* to the worker*
end the cow»unity during rewedial action can be
adeqoitely controlled by restricting access lo the
• it* lo *ulhorited personnel only and conducting
action with adequate health and a*l*ty
precautiona.
th* long-lera effectivenet* of
Alternstive* *C *nd K. Cleanup action level* for
Mil abuvi ground water mil be Bet. CM.* for
Mil beloo ground wstsr swy not be Belt however,
riak calculation* ar« baaed on ingeation of Mil,
and thia would be unavailable for ingeetion.
Ground wultr cleanup action level* wuutd be wet.
After reBrdielion i* completed, ill risks are
reduced below accept*bl* level*.
Significantly and perBanently reduce* aobilili of
conlaamanla in Mil and aobility, toiicity *nd
volua* of contaainant* in ground water.
SOB* conlaBinenl* in ground water are transferred
lo Mil crystsls which *r* disposed of off sit*.
Doe* not significantly or perBanently reduce
toiicity or aobility of theae reaiduala.
-------
MIWII r
ihniMMiABii.iiT f.»AUM>iifn a
It KM
illNl; 1C MM
AYAUABUIIT
•JMlNISIMIIVt flOSIBHIIT
Alternative I
No remedial action it taken mlli thu
alternetivei therefore, no ron-itrurl MHI
difficulties Mill be encountered wnl no
schedules 'ill be deleted. No ectiim-
•pecific requirement* ere releted to
thie elternalive.
II is eitrrmely likely thai fulur*
ir»rthal M-tiwi Kill be required. It
sliiiuld be no Mire difficult to implement
the additional remediel ection than •!
present. Higretion or exposure pathweye
ten he reedily monitored. Since no
operation ami maintenance I* performed,
lunf|-term WN difficult let ere not
anticipated.
Ihe no-*cllon option it • reedily
available technology.
It l* eitrrmely unliktlr th*l Ihie
alternative would receive tht necenery
•pprovsle fro» eny agency or fro* the
community. location end chemicel-
epecifie requirement* would not be *»t.
Alternative I
Shurt-lerm leclmcel feeeibility of
elternetive le edequate. lechnotoqie*
can be constructed ei needed for
specific eite in e reeaoneble ti*e
period end enould perform ee eipectrd
during 11* re>*diel ection if proper
•winteoence le performed. C«p
co»itruction mill coaplir with ection-
epecific requireoente.
It te prohehle that future revpdiel
•clion >ould be required if contMinente
iw»e off eile Milh the ground mter.
liislellellon of the cep enould not pre-
clute puieible future re*edtel ectioue.
Ihe eite ten be reedily mnitored end
•emteined. Ihie eltemetive would he«e
lov iB|ilr*ent«tian, operetion end
•aintenence cusle. lonq-terei •einten-
e»ce proble*e e«» eriee fro* synthetic
liner puncture or poor o»intenence.
the ccp inetellere ehauld be reedily
eveileble. these inetellere would be)
treined in the operetion of Ihe
neceeeery equipeent ee well ee
eppropriete heellh end eefetf
preceutlonery Beeeuree.
Construction of tne cep "ust provide
lonq-tere) •inieiicetian of •iqrelion of
liquide throuoh the cep ere*. It I*
unlikely the! the co«"unity response te
this elternetive will be fevareble, ee
contseiinent* e»» continue to Itsve the
eite. wnile east locetlon-epecifie
requireesnte «ey be «et, chee>ic*l-
epecifie requireewnte will not.
fnforcseient of ground weter -use
restrictions eay be very difficult.
HHernslive I
Itlepulgit* cler rether then Wyaoinq
Clsy My be needed. It I* enticipeteil
the! en edequete supply of cle» ten be
otaleined. It i* eipectrd thet with
proper bench-seele testing end
instelletion, technology will be cepeble
of ewettng perfoiBence speciflest ions.
Action-specific requireewnte will be
•el. Iicevetion will tehe piece outside
the eree requiring soil reewdietion.
therefore, construction should not
trigger cleenup or lend diepaeel
restrictions.
future reewdiel eel ion euch ee ground
veler eitrection end Ireetewnt ewy be
required if it le determined thet the
cantseiinente ere s»*ing through the
confining layer beneeth the site, while
future reoediel ectione ere not
precluded by the current ection. the
construction of e well end cep could
effect Ihe construction of future
re*edisl ection. Monitoring of the eite
for effectiveness should be no problem.
Difficult lee with long-tere) OSH may
ariae from action of the contentment**
especially the eelt end organice, on the
well itself.
Conteinment well* ere e demons!feted
technology thet ere readily eveilabla
end es»y la construct. Mequele clef
enould be eveilsble. Ihe neceeeer*
equipment end epecisliete ehowld be
available end treined in the neceeeery
health end eefety technique*. l*ck ef
coa»erci*l deep well facilities mey
effect slternstlve. frssently deem well
fecilitiee ere ***ileble.
Acceptenc* of tni* elternetite would be
poaaibl*. • condition ef the eccemtence
would include deed end *cces*
restriction*, •• well ee cereful
monitering te en*«re the weele le not
meoinf through tm U« r«sl eo^ufer.
Alleinatlve »A
It te expected thet the biggest
difficulty with Ihe option will be in
obtaining spprovsl of the Petition
Oemonatretion. Ihi* could result in
problem* with the remediel vchedule. II
l* eipected thet ill ection-apecific
requirement* can be achieved.
that the e«t fact ion welle ere
properly pieced to influence ll>e eree,
Ihe deep well is properly constructed
end Ihe N|. Simon aquifer le en
eppropriete formation, future remediel
ection le not anticipated, fhie option
ittre imt prrclitle future r«-wwilial
action at Ihe oile. Mule mio,ratinu or
e«uo-Jure pothveye close to the surface
muy be reedily monitored, akmitortng of
the injection ax>T to determine whether
tlw material le confined, may prove
difficult, failure to detect prirfilem*
any result in cnntamination of another
e'|uifer. No difficult lei ere forenern
in long-term operet itifi enil meinte*ience.
t»traction well; deep well end cep
inetellere with releted equipment
be evailable.
ild
the need for • fellI ion Oemonetreti*n
mey dele* implementation of thl*
project. In eddition, epproval for •
permit muet be obtained. Beceuse the
reguletion* governing underground
injection welle ere In • etata ef flue,
it te impoeeibl* *t thl* lime te>
dstermin* eoency response. If an
•dequet* Petition Demonetretion cen be
prepered for U&tPA, the elternetive
should be able I* obtain spprovsl from
other egencie*. Some community response
mey be received In regerd to trestment
by injection rether then convent loneI
technique*. Due to the large number ef
am* eitee in the eree, other eitee
mny l*r«i*>f|t frnm the imnlimji iit^tion ef
Ihlm mltariMllv*.
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HUM II I
t>
HOMIl'iN. IMMIIlim
* KIM
nCIWICAl II A'.Mill I IT
HINI; HIM
Allernellve 411
It 19 eiprcteo" thel •!! locetiou and
•clion-sprcif1C requirements cm be
•rhieved, 'J«eil on psst prrforocnce,
technologies should be cepsble of
providing process efficienciee to remove
rOQI lo fttii solvents to the required
level before deep nell injection. Air
•tripping end grsnulsr sctivsled cerban
•f* mdely u»ed conventlonel
technologies thsl should encounter no
difficulties during construction.
With e.
Mditionsl restrictions on hsterdou*
OMpounds **r require oddition*!
trestocnt.
AVAHAHKIU
C*trsction veil, drrp veil, csp snd
proem unit mstsllers oith relsted
r, it <• lapossibl
•I this tlM lo d»ter«ins •asncy
responss. V»s cosaunity responss MJ
be received in rsgsrd to trsstaent bv
injection rsther then conventional
techniques. Out to the l»rye> nuabcr of
dm* sites m the *re», other cite*
••« benefit fro" the isplsewntstion of
this sltsmstivs. »ltem«tive s«|r be
•ore liksly to be •pprovsd 07 ogenciee,
sine* no Pstttisn P»suiistrstisn ie
neceeter*.
Alternative »C
II is expected thst si I locslion snd
•clion-specif1C requtreewnte csn be
schieved. Bssed on psst perforosncs,
technologies should be cspeble of
providing process efficiencies to reaove
conlooinsnle to drinking veter e>usltl|p
ocrpt salinitf. Air stripping, cye
ondstion, octele precipitstion, end
csrbon odsorption ere "idelf used
conventtonel technologies thst should
encounter little difficult* during
construction.
With cdequete operation end oslntenence,
technologies should continue lo provide
the necesasrr process efficiencies.
AssuBtng thst the eitrectlon ••lie ere
properly pieced lo influence the erts,
the drep >ell I* properly constructetf
end the HI. Swon equifer ie sn
•ppropriste for*olion, future reewdiel
set ion is not snticipeled. this option
does not preclude future ree*ediel action
et the eite. While mgrelion or
eipocurs pethveye close to the eurfece
•ey be reedily Monitored, •onitoring of
the injection tone to detemne nhether
the e«leriel is confined, "ey prove
difficult, feilure to detect probleve
•ey reeult in conte>instion of snother
•quifsr. No difficulties ere foreseen
in long-tere> aperetion snd •eintenence.
Reguletione ere in • elete of f|u».
Mditionel restrictions on hsnrdoue
compounds e»y require edditlonel
treelecnt.
direction «el I, deep *e 11,, csp end
process unit inttellers «ilh releted
equipoent ss veil ee ell process wilt*
theetielvee should be evsilsble.
Adequote cepecity in epprapriete
lendfill should be svsilsbls for Betels
sludge. Disposel/recycle facilities for
the spent cerbon ere Ilotted to four
focilitise but should not prevent
loploBontetion.
ApproveI for the deep ••!! sust be
obleined. Beceuoe the regulations
governing underground injection •all*
ere in e st»ls of Mm, ll ie lopeeeible
et this tiee to deterejine egency
response. V»e cosaunity reeponse «ey
be received in regsrd to trestsNrnt by
injection relher then conventions!
techniques, this to the lerge nuaber of
CtRClA eitee in the eree, other eitee
e«y benefit fro» the lopleventetion of
thie elterne/tive. Alternetivs BO* be
•ore likely to be approved by eqanciee,
since no fat it ion Doaanetretion ie
neceseery end the inter la being Irested
U ground ueter quellty sicept eelmity.
Alternetive U
It ie e>pected thst si I locstlon end
sction-opecific requirements csn bs
•chieved. Cveporstion/cryetellifetion
ie cepebls of providing procees
efficiencies lo reewve the liquid
portion of the eitrsct, sllouing for
disposel of the reeisining solids.
Iveporetion by iteelf **t not provide •
conuenssts thst is cleen enough for
discharge or shslloo squifer injectnm.
Oispossl of sslt cryMsIs osy be limited
by It* *^iunl of free cyenide preiml
•nd could eignif ireiilly incrrsee llv
cost of this ellernstive. fveporslinn
IS 0 "irtely used convent lonsl tschmilnqr
thst should encounter little difficulty
during construction.
With silequste aperetion snd esintenance,
evsporstion/crystelliistion ehould
provide necesssry trestocnl aver the
long tero. No difficulties ere foreseen
in lofxj-tersi operelion snd •aintensnce.
luture rrardisl set ion !• "ot
e/iticipeted. (hie nption lines not
preclwle future rr^ediil sctiofi et the
site. Honitorinn, of the site for
effectiveness should be no probte*.
direction veil, csp snd process unit
insistlere vilh reIsled equipment ee
•ell ee the eveporetion/cryelslliratien
process unite thesjselvee should be
svailsble. lendfill cspscity is
lioited, but should bs ovsllsble.
Oislences to off-silo landfill
foci lilies ere long.
(vapors!ion of directed ground neter
should result in e favorable response
froa other ageneiee.
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1*111.1 «-»
NIUCO I
cxwtrai nr t«ims
llCiMtTM ri
•JIURI II HK
u m
ADrllNISHAIlVt ICASIBHIU
• llrrn.it ive >•
Ihe difficulties related «ith excavation
concern the conlrol of Ihe nttri*!.
Adequate tiesllh and eefoty provtaioits
•uat be isiptracnled.
No likely future remedial K! ion is
anticipated: Migration or eipneure
pathways rsn be adequately Monitored.
Ho additional risk of opoaure rusts,
should tun i tor imj fell, •• oolenal hee
hern removed fro* Ihe ail*. Source
control •eeeuree hn»e demonstrated
nerfarwnre. Site apvretion end
Mintenence ire eiinml.
Ihe available harardoua raste landfill
capacity for disposal of material I*
limited. Distance* to off-site landfill
fact lit lea ere long ond transport mould
b* expensive.
*llrrn*ti»* mmi not b* *ppro«*bl* line*
grouftd mt*r conttamctton Kill not b*
r**»di*t*4. InforrMwnt of ground "»»*r
u*« restriction* ••» b« very difficult.
Ou* to tn*> prool«r»» of lr*n»porl*tion,
l**panw ••» net ft* (•*or*bl«.
• Hetnotlv. K
It it ripccted lh*t thrre "ill b* little
difficulty mth construction.
Procedure UBiltr to MCM deliitino, m*>*' "» roolioord *ff*cliiren**(
•tonlit b* Mllly *anitor*d.
H*in|ep*ct*d lh*l Ihi* •lt*rn*ti«*
••r not b* *ppro»*d br other •gmci**
•nd th* co**imit> *inc* ground •*t*r
contMin*tion vlll not b* r*»«di*t«*).
Inforcr*i*nt of ground Mt*r uo*
rtttriction* •*« b* **ry difficult.
In* con*truction of *n an-*it*
incin*r*tor h»* boon knoMt to c*u*(
public apposition. Ou* to th*
clocen*** of r**id*nc**, th*
l«plea*nt*blllt» lo unhnoxn.
If proper trrdiblllty lr»l» *rr
conducted, it i* opected th*t there
•ill b* no difficult* «lth conittuction.
*kM* present problesis »ith future
re«eili*l sclion*. Hi* continued
effectiveness of this rr*e<>> slwuld be
redly oonitored. Maintenance of oil*
is •ini«al, involving inspection,
enving, eroeion protection, and accesa
restriction.
Meqfnte Ireelvent and diapossl aervirea
should be evsilsble. Necesasry
equipment snd specishsls should bo
ovailabls, sssusing the uterisl I*
resdilv solidified and can conforoi to
procedure* sioilsr lo ICM dslistlng.
It to *>pecled thet this •Iternativ* ea*
not b* approvvd by oth*r ogencie* ond
th* ctMunity sine* ground «slsr
contoaination Bill not b* ro»edi«t*d.
enforcement of ground ooter MS*
restrictions ooy bo very difficult.
Unf*vor*bl* response «ay also relate lo
flailing us* »f th* property of farming
o ca»anted oolld.
Alltrn.tive
Difficulties during construction o*y be
encountered due to the hioh ground rater
table and type of soil. Ihia
alternative hss been de*onstrsled during
pilot testing) ho»svsr. the technology
has not been proven on • full scsle
project, therefore, the slternative
should be considered innovstivs. Ho
ocevstion of site Mleriel vauld be
necessary, thus reducing th* Barker*'
*lcd. Personnel oust be hii|lil»
Skilled, tffects on srese aurroumlinq
the "*lt are uncertain.
It la not snlictpsted thst future
reoediel action »uuld be needed. Ihio
option «ould preclude a«ie types of
revediel action oue to the creation of
the solid aonolith. Area eround the
eource ares should be eaaily end readily
•onitored snd aiaintained.
*t Ihe present lioe, the necessary
equipavnt end apecialiete to perform
larg*-ac*l* in-ailu vitrification or*
not available. Ihio **>* increaa* th*
••pleawntotion period to an unaccepteble
level.
Due to Ihe large nuvber of unknoun*
oaaoctated with this innovative
treatment, the likelihood of
unfavorable coMunity reapont* 10
increased. Alt email re a»y not b*
opprovebl* aince ground »aler
contooinstlon Mill not bo remediated,
Inforceaient of ground voter us*
rsstrictions e»y b* vary difficult.
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IAIM *-}
HI 1)1 U I
IMIMHMIAIIH.IIT (y«J.UAIIIM Of Al II WAI IMS
riAsimi.ii*
*IUHI iri#i
Alternative 4
Sa»e as Alternatives » end X. llw
difficulty o' performing two type* of
remediation on lite at onr time could
delay II* conetruction schedule.
nrimi «i ii AMIIII.II*
UMI; ii MH
AVAUAHII IIY
\.mt *n Mtrrniltvri ) KM| St.
Sam •• Alternative* ] md M.
HjMINISIFUIIVt rt«SIBKIU
'»••• •• Alternitive* J t»4 it. Althou^i
qroifid »»t»r contwiination "ill not b«
r wed I (ltd to clemup ectian level*, «ll
the riiki »e» tlisintted by protnting
contact vith conteamaled Mil end
qrotnt mt«r. Ou» to hin^i level »f
protection, renponae »ill li»elr W
favorable.
Alternative I
fiMe at Alternativei *A and X. lt«
difficullv of performing loo tvpe* of
re*edtetton on atte at one time could
dele* Ina conilruction ecnedula.
Sa>e ae Altemativea (A and it.
Sam •* Alternative* *A and JC.
aa Alternatives »A and X. Ground
••tar contaamation viill be reaedieted
to cleanup action level*. Due I* the
hir/i level of protection, reeponao
likely be favorable.
Alternative 8
Soae aa Alternative* «C and M. Irw
difficulty of performing tvo .type* of
remediation on aite at one time could
delay the conilruction achedule.
as Altemativea »C and
Sow a* Alternative* «C and X.
Sm«a aa Alternellvea AC and X. Ground
•ater contamination mil be remediated
to cleanup action level*. Due to In*
high level of protection, reepona* viill
likely be favorable.
Alternative •
Same a* Alternative* *f and X'. Ihe
difficulty of performing l«o typee of
remediation on ill* at one time could
delay the construction schedule.
Saw es Alternatives at and X.
as Alternatives AC and X.
•• Allernetlvee *t and X. Ground
voter contamination mil be remediated
to cleanup action level*. Ou* t* the
high level of protection, rxponae will
likely be favorable.
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C\J
I—t
OJ
n
MIOCO i
UIAIUO AMAU5IS SUMAITT
Allrnuitite I
Alternative I
Alternative 1
Alternative *A
Dor* not reduce potentiel public health riek a**ocietrlll not be art e«
•oil rrwine without treetment end ground rater the! h«e
• iqreted off eite "ill not be Ireeled. Continued potential
for ground rater deqredilion eiiele due to leterel ground
•eter atqretion. Surface "eter conta»inenl* My bo voraened
bf continual diecherge of eontmeineled ground rater.
Performance of properly inetellrd *ulli-leyered cep te
generellf good for firet 20 feere of eeroice. Without
ground rater u»e reetrictione, the rr*oining rieh et the
eite efter reaedietion ceoplelion rauld be 1.91 * 10*'.
With enforcement of ground rater me reetricllone, oil rieke
oould be reduced belw eccepteble le>ele. Reducet
of eonleiiinente in coll but doee not elgnificmtly or
permanently reduce to«ni«» «r nluw or reduce the
of ronteBinente thet ere elreedr In the ground rater
Sefety concern during tnetellttion reteted to e»ce*etlon
ectlvltiee. froteclion egeinet principle three! cen be
echieved upon coapletion of conetruction. eppronxltly I to
1 »eere. tleenup ectton le*ele (t««.e) for eotl end ground
rater ntll not be aet beceme no treetoent le provided for
the*, tlieunetee direct contect eipoeure to contealnente.
tontoemetion Boy eove verticelly to neit eguifer. Ihie
•guifer he* very little yleldi end le not ueed for drinking
voter purpoeee. High eelt end organic concent ret ion* *e»
effect peraeebillty of rail. *>ter reoedietion le
ctMpleted. ell rieke ere reduced belo» eccepteble lexlo.
Siqnificently reduce* •bhility of craileainimte in eoil end
ground rater, but doee not reduce loiicily or volume.
•wediel ection ectivltiee My not cw^mce for I to I
yeere, e* e Frtltion Omonitretion for ilrrp well *inl l>e
epproved by IPA. Conetruction of rr«rould b« •»».
»M*r rr««di«tion te co*plrlril; if ilenl rrgtrictton* end
eile *«inle«ence ere performed, ell rieke ete reducr ritfittMBKiiMiln in unit.
*>lt|lttl IftMll ly wwl |M-f«t*ttMtt If t«»lliifit Mjltltl* nt
No revediel ection te token mth thie elternetive. It te
eilro«ly likely thet future re*edi*l act ion will be
rei|uired. It le eitrraely unlikely thet thie *lternetive
•ould receive ttte neceeeery *pprov*l* fro* eny enency or
fro* the cnMieiity. locetion end chmcol-epecific require-
•enl* vould not be *et.
Irchnoloipei cen be constructed •• needed For epecifie eile
It i* probebl* thet future remedial eel ion Mould be required
if conteament* *o»e off eile "ilh the ground velcr. the
cap ineteller* ohould be readily aveileble. It I* unlikely
Ihet the CB«*unity reaponee I* thie elternative Mill be
fevorable( e* conla*inant* aey continue te leev* the eite.
Chile aoet locetion-epecifie requlre*ent* a*y be Ml,
cne*ic*l-epeclfic requirevent* mil not. InforceMnt of
ground rater UM reetrictione My be very difficult.
It i* e»pected tn*t vittt proper bench-ecel* teettng end
inetelletion, technology "III be cepeble of Meting
perforaonc* epeclfication*. Actlon-apecific requir**ent«
• III be Mt. Difficult lee ulth long-ter* UN **y erie* fro*
ection of the contwlnente, ecpeclelly the eelt end
orgentce, on the rail iteelf. Conteinaent ••!!• er* •
dtaonetreted technology that ere reedily evelleble end eeey
to conelruct. A condition of the acceptance •oald include
deed end occeea reetrictione, •* veil e» cereful aonitonng
to eneure the «eete le not aoving through le the neit
equifer.
It le eipected thet the blqqeet difficulty with the option
• ill be in obtaining efiprovel of the Fetition Oraonetretion.
'•ilure to dried profclrae My reeult in contavinetion of
another eqmfer. titraclion oell, deep veil end c»o
inelellere «ilh releled equipment anould be eveileble.
Heceuee the reguletione qnverning WMlerground injection
•eile ate in • elate of fl»i», it I* tapoeaible al tht* tiae
to iteleiaine eqency response. (Hi* to the lerge rtuaber of
CtntlA eitee in the eree, other eite* My benefit fro* the
of thie elternetive.
COS I
lotel Capital • 0
Annual UN • 0
Preeent North • 0
let el Cepitel e l,»7J.OnO
Annual MN e IM.OOO
Preeent vorlh e >,Me.ODO
tolel CepiUI e J.HJ.OnO
Aretuel MN e I'l.ODO
Preeant Worth e *,MI,000
lotel Cepitel m I,111.000
Annual MN i 188,OUO
Preeent Worth • >.}»,OQO
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UIM «-jo
Niiiru I
a. unto «*M,T5is su>*i»irf
irnnivt«tv>
Allefi'ltlve *ll
Nr»rdiol action octivilie* •»> ml c"""riir* for it leinl I
j»»r, •• *pprov*l (or (hi* nplinn Bunt tie ilhleiiiril.
foftalrucl ion of re«ediel wlion clioulit l»fc* ? ynfi.
Cleenun action level* (CM.') for tuiil oil) not be •»! ••
•oil rr*»in* mlhout lf*»l»r"l. Ihe ijroxxl rater Ihil ho*
•ignted off *il» mil b* removed where fit ire *«c*eded
•Ml growid miter CM.* on eile vould be •»!. *lter
rc»rdi*tion I* completed, if dm) restriction* end lit*
Mintensnc* ere performed, ill riefcs lie reduced brim
•cceplibl* level*. Significantly snd permanently reduce*
Ihe lability of eonlemnant* in the will but do** not reduce
loncity or voluw of *«•* contaminant* in Mil.
Significantly and permanently reduce* mobility tod toncity
of conlMinant* in ground viler but doe* not reduce volup*.
SOB* contaminant* in ground veter ire transferred to c*rban
c*ni*ler* vhlch are diipoied of off (it*. Doc* not
• ignif icmtly or petMnentty reduce to«lcl»» or •obllity of
the** re«idu*l*.
It !• r>pecl«d «l-il ill locllion Hid *cl ion-«peciflc
ret«ui>eae«l« cim be *chitved. Hith wlequitt op«t«tion ond
••inlmmcr, technnloqie* *noold continue to provide tn*
nece»«ty pcoceii efficiencie*. flilute to detect problevo
•iy result in conlwinition of *nolh*r K)u«fir. (ilroction
•ell, deep »ell, cop *nd procei* unit inililleri vith
re I iled equip^nl •• oell •* ill procri* unit*
•SouId b* *»*il*bl*. Dl*po**l/r*cycl* ficililie* for Ihe
op«nt c*rbon or* liaited. BecouM In* reowlil ion* gpireml
underground Injection mill* ire in • *l>t* of flu*, it I*
iopo**ibl* il Ihn tix to o*t*raino ogency re*pon**.
AllerniliTe ooy be *or* likely t* b« *pp'o>ed by *o«ncl»*.
eince no Pel It ion D*Bon*tr*llon I* n*c****ry.
COSI
loltl Copitcl • J.MJ.OW
«mu,| UN • 489,000
Pr*Mnt Dorm • T.••7.000
«C
*4ipro»il for thi* option tnould not OHliilt ilov IT I inn do»n
•• contminint* mil be removed lo drinking viler qmlity
eicepl **linity before injection. Conilruction of re*edi*l
•ction ihould tike t ye*r*. Clemup *clion level* (C«ll)
for Mil mil not be •*! •• Mil ree>nn» "llhout tre*t*enl.
Ine ground otter Ihil Nil oigr*led off ule mil be removed
•ner* CM.* ire e»ceeded end ground inter C*l* on *ite »ould
be *»t. the lev*! of *c*tone being injected into the deep
•ell mil eiceed the CM.. No MtV or HCVG presently einl*
for Keton*. After reaediilion I* completed, if deed
restriction* ond lit* ocinlenonce *r* perfqraed, (II riok*
•r* (educed beloo itttplibli level*. Stonif icently end
permanently reduce* the Aobility of conliamenl* in the
•oil but doe* not reduce toitcity or voluae of oo*e
conteainont* in Mil. Significently end perMnent|y reduce*
•ability end toticity of conteainent* in ground mter but
doe* not reduce volme. Saie conleJiinenli. in ground »ilef
•r* troneferred to Cllbon tmiilrri end Bel*!* eludge* "hich
•r* dupoird of off *ite. Awe not eigmficmlly or
pef-menllt reoHic* loncity or •obililt of theie re»idu»l».
It i* rioected thel ill loc*llon *nd oction-epeclfie
requirement* cen be achieved, mlh edequite operation end
••intenence, technologic* ohould continue to provide the
nece*s*ry procen eff iciencie*. future to detect prableM
•if remit In cantminetlon of onother *genry reopen**. Alternetive May b*
•or* likely to b* (pproved by iqcnci**, «inc* no fetition
De*«n*tr*tion I* ncce***ry end Ihe weter le being treiled to
ground miter ojuillty eicept Mlinity.
talil C*pit*l • J.W7.000
•jwuel 04H • >».am
Prewnt North • i.ttJ.OOO
Allerr.ilive «t
Approval for Ihe evnfwrelur ntnlrm ehoutil he rewlily
obtainibl* es this ll co>ivent innil technology, tout ruction
of remedisl action should like I to I yesr*. Cleanup action
level* (CM.*) for soil mil not be met is aoil remnni
mlhout treatment, fhe growfd viler Ittat hes migriletl off
site mil b* removed vhere CM.I ere e«certkptfiction veil,
rip end procen mil inilelleri vilh releted equipment o*
veil •» the evipor*tion/cry*t*lli»tion procet* unit*
should be ivillibll. lendfill cipicllv ll
but diould b* iviilible. DiMence* to off-nil
ficilitiei ere long. Oitposil of ull cr>et*l* >iy
be liBilcd hv Ihe ••ount of flee c>mi
-------
*.?n
HIUCII
cc i*iir.o
S4r*u*r
IIIICIIH*
cos i
Alternative J»
Safely cnncerne during the rrmriliel act ion ere related to
the eira«elion of the ••terinl. Cleani^i act ion Irvele lor
•oil* above grotml water level would he met. COL* far Mill*
belo* ground utter may not be "ftI however, nek
calculation* ere baaed en migration of coil, end thcae
additional col id* would be below the inter teble end
unavailable for ingeition. Attenuation reault* in •
di*aip*tion of contaminant*, although il mil be many year*
before ground ••let cleanup action level* will be *tt*invd
for ill compound*. Without ground water oee restriction*,
the remaining MI* it the tit* *fl«c rc»«di*tian conpUdon
•ould be I.BI » 10'*. Milh enforcement of qtotn) inter UM
restriction*, *ll ri*li* >ould be reduced belo* ecceptoble
level*. Neduce* volu»e of To»t*ej|hent* In eoil by rrwvinq
it fro* eite but trenefere the prohlt* to the lenttfill *ite.
Uoc* not reduce voluw, •ability or toncity of canteamenl*
in ground voter.
(he difficulties related with e«c*vation concern the control
of the matftnel. Ih* available heinromi* wa*ta landfill
capacity for dlapoaal of material la limited. Distance* to
off-aite landfill facililiea *re long and transport would be
e»pen*ive. Alternative may not b* approvable *me* off-*lt»
qrou»d water contamination will not be remediated.
enforcement of ground water ua* reatrietiona may b* very
difficult. Due ta th* problem* mf tranaportation, coamu
reapone* may not b* favarmbla.
1ot*l t*pit*l < •,79«.000
Armuol MM * IX).000
frcoont Worth • *,.«*,000
A|lrrn*liv*
S*fety concern* during tne rr»rdi*l *ctton »r* relcted to
the e>c*v*tion of tne Mitfri*!. C«len*ive requirement*
including tri*l burn plu* IDtA b*c*loitammant* in nil but doe* not reduce
loudly, mobility, or volume of contaminant* in ground
w*t*r.
It i* evprrtrd tn*t thia alternativ* may not b* approved
by oilier W|«ncle* and the coamunity *mce ground w*l*r
cen!o«>n»linn will not b* remediated, enforcement of
ground water re*trictlon* mar be very difficult, lha
Conatructlon of an on-eite Incinerator ha* been kno«i
to cauae p<*lic oppoaition. Due to the cloeenem of
residence*, th* implementabllity la unknown. Nece***ry
equipment and dlipoaal aervlce* •• well M operating
perconnel ahould b* av*ll*bl*. Procedure* *l*)ll*r to
KM deli*t ing may delay araject *ctwdul*.
lot.I Ctpttal IX).000
Pr***nt Vorth tll.Mt.OM
-------
Midi •-?!!
HI (Mil I
auiuo
HIICIIMM'.1.
cost
Allrrnelive
Safety concern during installation ansocialrit with
evcavet 100 and ajivinq of ro*itea>inalel*bilil|r studies lo e»feai«tely
draonstrat* thai the solidified waat* can confer* lo
procedure* *iajitcr lo KM deliatinq. 'hi*. »ey delay
initiation of construction. Completion of construction
should be I year. Cleanup action level* for (oil* *bov*
qround w*t*T lev*! would b« a*t. CM.* for •oil* below
qround water *wy not be awt| however, rieli calculations ere
based on ingest ion of Mil. end theee additional eolido
would be below the veter table and unavailable for
•notation. Attenuation reaulte in • dissipation of
contaainante, although it mil be aany yen* before qround
••ter cleanup action level* will be attained for *ll
compound*. Without qround w»ler use restriction*. Ih*
rraatntnq risk *t th* »«le *fl*r r>»rdi*linn cwpletton
would be I.M I Id"'. *«lh enfolceacnt of qrowwj weler use
rtitrielion*. ill rich* would be reduced below *ccepl*bl*
levtl** Sio^ific*nlli end peracnently reduce* enbilit* of
conteainent* In Mil. but doe* not reduce lo»icit>, "ooililw
or *olu>* of conlwinent* in qround inter.
ftu* type of ao.'idi f ir«l ion te con*idereH innovetiv* for
Ihu \mr.
Procrtlure* *t«il*r lo "CRA deliatmq •*• del*t project
•cheihil*. M*qu»l* lre*t«*nt end dltpoxl **r*lce* ehould
be *v>il*bl*. It I* eipected tr>*t »hl» *llefn*tiv* «iy not
be approved by other *qenrit* end the roMunitv *inc*
oCf-nl* ground weler conleam*!ion will not be re*wdi*t*d.
Cnforce«cflt of qround w*|*r u*e reetrictione •*« b* very
difficult. U>if*vor*bl* reeponM *•> *l*o relet* I*
u*e of ttw properIf by foroinq * cemented *o)id.
tot*l Cepilol • «,?«I.UIO
Annu.1 MM . IX>.OUO
Precent North < ?,i»,QOO
Mtern»t%v* Mi
Bec*u** no *«c*v*tion of •*leri*l occur* end ell of Ih*
•*teri*l* *r* treated in • hood. n*k I* •inicirrd. Co»ple-
tion of conctruction *hould be I to I ye*r*. Cleonup action
level* for aoila ebov* qround water level would be *wl.
C»* for aotla below qround weler **y not b* *)*t| however,
M**. caltulaliona are baaed on inqeallon of aoil, and Ineae
additional wolida would b* below the water labl* and un*,.
vailable for inqettion. Mtentuation raault* In a
duaipalion of conlaainanta, although It will be * anrl V.. Cleanup action
level* for aoil *bo»e qroind >ater will be awl. C*a for
•oil below qround water a«y nnt be a>et| hnwever. risk
cclculation* are based on inqeition of soil, end this would
b* un*v*il*bl* for imjeation. Crniod water cleanup action
level* would not be aiet on *itr. Olter fr«rdiatioi> is
completed. *ll risks are rrducril helow atcrfilable level*.
Significantly and permanent ly rf.lut ts •ability of
rantvaine"!* in anil a"d qronid wnler.
Save »* Allern*live* I and H. Ih* difficult* of perforating
two types of remedial ion on aite at on* liaw could delay
the construction schedule. Mthonqh qtound water ran.
laainalinn will not b* rewrdlated to cleanup action levele,
• II the rial* are eliminated by preventing contact with con-
twmaled anil ami qrouid water. Ou* to the high level of
protection, response will likely b* flvorabl*.
total Capital a i.W.OOO
Annual (UN a l»,000
Present North >IO,UI,UOO
-------
I Ml I 4-70
NIIMII |
a IAIUD »*«i.T!>is SWART
Alternative 1
IHICIIVIM V,
Rrvrdiel action activities tat i|rnund »nlrr My rait c<»»mce
for I to I yrnr* at • Petition t)cl um for the OVrp
•ell oust b* approved. II "ill be necc»»ry lo perforaj
tre*t*blllty (tulles la dr*nnstr*t* tnat the Mlldlfled
•••It c*n confer*) lo procedure* nailer lo HTM drlisting.
Ihi* «ey delay const ruction initiation. Construction of Ihe
rr»edi*l •etion oould like •ppronaalely I year*. Coabine*
Iht long-tera) effectiveness of Alternative* «» «nd U.
Clrcnup action lt»*l( for Mil cbovt qroi«xl mlcr fill b«
•ft. CM.* for Mil b«lo« grot*Mf ••let ••/ not b* »»t|
lw»»»rr, n«k cclcuUlioni »r» b«srd on iiH|cit ion of Mill
•nd lhi« •oulrt bt wicvtiUbl* for intlon. Ground »»tir
clrcnup icI ion l»rl* xiuld be act-. After remedial ion l>
ro»plttrd, ill risks *rt rrducrd belw> Mrcrplcbl* U*el«.
ferannently md •lonificmlly reduces •ability of
rontMincnt* in Mil md growid nter.
••! *llern*ti»e« 4* «nd f. Ihe difficulty of
prrforaini) loo type* of rr*edi*lion on site «l on* t i«e
could rieUy In* cmidruclian Khcdul*. Du* to Ih* hio^i
level of protection, r«*pon*c Kill likely be f**orebl*.
COS I
lol*l Cspil.l • •,011,000
fe.,u.| O.M . 118,000
Pr*Mnt north •lO.III.OOO
Alti>rn*liv* •
•ppfool for this option *hnuld not unduly slo« *ct ion
*• contwinent* Mill b* ttooinl to drinkinq nter quilily
e«cvpt velinity before injection. 'It will be necessary lo
perforv lre»t>bility ctudie* to dr«nn*tr*t* that In*
•olidified •»»!* can confor*) to procedure* aiailar lo MCM
dfliatinn. Ihi* My delay construction initiation.
Construction of remedial action uould lake I yrara.
Coabtnea Ih* lonfl-tece. *ftecti«en*** of *ltern*ti*e* *C *nd
VC. Cleanup action l***|* for Mil aho«* ground nler "ill
b* **t. CM* for Mil belo- ground «ater My not be *wt|
nooexr, n*k calculations are batrd on inqaation of soil,
•nd thi* Mould b* unavailable for inqeation. Ground «al*r
cleanup action level* «ould b* Ml. If «aler leave* deep
•quifer, since thi* i* not • drinking >aler aquifer, In*
increased aalinity snould not poa* • problem. After
rexiliatiun is completed, all risk* are reduced brio*
acceptable level*. Significantly and pero*nently reduce*
•ability of contaminant* in Mil and aublllly and toncity
of contcainont* in ground >ater. So»e contwincnl* in
groind niter *r* lr*n*ferred to carbon caniater* end *wtol*
lludge* «*>ich *r* disposed of off lit*. Doe* not
• iqnificanlly or pera*nently reduc* toiicily or •ability of
IKes* residu*!*.
•• Alternative* 4C *nd «. In* difficulty of
perforainq t«o type* of re»edi*tion on (it* *t on* lia>*
could del*y Ine construction odiedul*. Due to th* high
level of protection, reapona* Mill likely b* favorable.
lotal Capitcl > *,07»,ODO
Annu*| 01N . }}},000
rreavnt Morlh >l»,«•»,ODD
-------
Milt 4-211
more i
reuiito /*m.TSis
IflK IIV1M V.
Alternative
Approval for the evaporator «y*tr* anoulil be readily
obtainable *» Ihn i* conventional technolony. It »il| be
nrceaaery (• perfor* Ireatebilily iludiri lo dXwnslrate
that lha solidified •••!• ran confor* lo procedure* dollar
ID RCM delidinq. lhi» M|r 6tl*r contlruclion iniliclion.
Construction of re«edie.| oction ihould t«ke I to I |>e»r>.
CoBbine* th« lonq,-ter* •ffecttvenet* of *llern«ti«e« tf *nd
M. Clecnup oction level* for Mil •bo»e qround mtrr Mill
be Bet. C«i» for •oil be loo groind ••ler M|r not be owli
hooevet, tiik csltulction* *te b««ed on imjeition of •oil,
end thle vould be uni»*ll»t>le for inqeation. Ground mler
cleanup eel ion levele oould be •*!• After re*«4i*lion i>
coapleted, all rich* are reduced belo» acceptable levola.
Significantly and peraanentlir reduce* •ability of
contaainanla in aoll and •obilllr, to>icil», and volww of
contaainanla in ground rater. '"»* conta>inant* in qrmnd
•aler arc tranaferred lo (alt cryalala •hied are diaposed of
off aile. Dbet not nqnifleant ly or prraanentlf redurt
loncitr or •ability of Iheie rreidiiale.
r.».e aa Alternali.e* 4C and M. the difficulty of
perforating I no type* of remediation on aite at one liae
rould delay In* construction achedule. fAj* lo the high
level of protection, reaporm* oilI likely be favorable.
cost
total Capital • 7.*)}.0no
Annual (MM • tM,U0
freiant tforth •!!,711,000
»« t Citrr«ely poaitiv*
» • Poaitive or Moderalely poeilive
o « Very little effect or no chano« fro> e>i*ting contition
- > Negative effect of Moderate ainnificence
— t [•Irrxely neqatlva
-------
TABLE
ALTERNATIVE PRESENT
1.
2.
3.
No Action
Cap
Containment
REMEDIES THAT DIRECTLY
4A.
4C.
4E.
Deep Well
Treat and
Deep Well
Evaporation
REMEDIES THAT DIRECTLY
5A.
5C.
5E.
5G.
Landfill*
Incineration!
Solidification!
Vitrification
REMEDIES THAT DIRECTLY
6.
7.
8.
9.
Combines 5£!
with 3
Combines 5£!
with 4A
Combines 5£!
with 4C
Combines 5£!
with 4E
0
3.
4.
MIDCO I
ESTIMATED COSTS IN MILLIONS OF DOLLARS
AND TIME TO IMPLEMENT
YEARS TO
ANNUAL O&H DESIGN AND
WORTH CAPITAL COST COST CONSTRUCT
4
7
ADDRESS
5.
8.
6.
8
9
4
ADDRESS
9.
13.
7.
10.
7
6
6
5 '
ADDRESS
10
10
13
11
.0
.6
.7
.4
0
2
3
.0
.2
0
0.
0.
15
16
0
2
3
YEARS TO
COMPLETE
ACTION
0
1
2
GROUNDWATER
4
4
2
SOURCE
8
12
6
9
SOURCE
8
8
8
7
.0
.0
.1
.2
.2
.2
.1
AND GROUNDWATER
.6
.9
.9
.1
0.
0.
0.
0.
0.
0,
0.
0.
0.
0.
0.
19
53
45
15
15
15
15
16
19
53
45
4
3
3
2
4
2
3
3
4
4
4
30
30
30
2
4
2
3
3
30
30
30
Excavation for these alternatives is preceded by in-situ vapor extraction.
-------
00
Will Gontaninants Migrate
Alternative Off-site in Ground Water?
MIDGOI
TABLE OF EFFECTIVENESS AND WIDCNTABILITY
Will Action Result in
toiv-ccmpliance with State
or Federal Standards?
Will Gontaninants of
totential Health Concern
Remain In the Soil or
Ground Water?
Will a Significant
Arount of Off-site
Hazardous Waste
Disposal Occur?
Are Significant
Implementation
Rnoblens Expected?
1. to Action
2. Cap
3. Contalrtnent
REMEDIES THAT DIRECTLY
4A. Deep tell
4C. Treat and
Deep Wall
4E. Evaporation
1 REMEDIES THAT DIRECTLY
5A. Landfill*
5C. Incineration*
5E. Solidification*
5G._Vitrificat1on
Yes
Yes
fto
ADDRESS GROUNDWATER
No
No
MD
ADDRESS SOURCE
Yes
Yes
Yes
Yes
Yes
Yes
to
*
to
to
to
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
to
to
to
to*
No?
Yes3
Yes
to*
N°4
to
Yes5
Yes5 8
to6
to?
to
to
Yes8
Yes8
Yes8
Yes89
-------
REMEDIES THAT DIRECTLY ADWLSS SOUKCE AND CROUfUIATLR
6. (5E + 3)* No to Yes No* to
7. (5E f 4A)* to to to to* * to7
8. (5E + 4C)* No to to to4 2 tto
9. (5E + 4E)* to to to Yes3 4 to
*Excavation for these alternatives is preceded by in-situ vapor extraction.
^Hazardous Haste Disposal in Deep Aquifer.
anounts of precipitated metals and spent carbon nuy be landfilled.
3$a1t cake contaninated vrith metals, cyanide and sane orgonics will be landfilled.
Organic liquids will be incinerated.
^Snall anounts of liquids fron in-situ vapor extraction will be Incinerated.
^Approval under CERCLA is unlikely.
&lhe long tenn effectiveness of the slurry wall is uncertain.
7May be problans obtaining approval for deep well injection.
voter usage restrictions difficult to iinploneht.
^Procedures are not proven in a full scale project. High wuter table may
cause difficulties during contraction.
-------
Table 15
~~ TABLE 4-15
ALTERNATIVE 7
GROUND WATER PUMPING AND DEEP WELL INJECTION WITH IN-SITU VAPOR EXTRACTION
AND SOLIDIFICATION ABOVE GROUND WATER ELEVATION
COST ESTIMATE
Site/Process Preparation $ 6,970
Soil/Sediment Handling/Treatment 3,227,000
Ground Water Handling/Treatment 1,687,400
Site Restoration 101 ,250
Access Restriction 24,590
Monitoring System 149,600
CONSTRUCTION SUBTOTAL $ 5,196,810
Contingencies 2,078,72^
CONSTRUCTION TOTAL $7,275,53-
Peraitting 135,000
Services During Construction . 725,000
Delisting 150,000
Engineering 725,000
TOTAL CAPITAL COST $ 9,011,000
ANNUAL OPERATION AND MAINTENANCE $ 188,000
TOTAL PRESENT WORTH $10,728,000
(102 discount rate, 30-year life)
See Appendix D for detailed cost information
-------
Table 16
TABLE 4-16
ALTERNATIVE 8
GROUND WATER PUMPING, GROUND WATER TREATMENT TO DRINKING WATER QUALITY
EXCEPT SALINITY, AND DEEP WELL INJECTION WITH IN-SITU VAPOR EXTRACTION
AND SOLIDIFICATION ABOVE GROUND WATER ELEVATION
COST ESTIMATE
.ite/Process Preparation
Soil /Sediment Handling/Treatment
Ground Water Handling
3round Water Treatcent
Site Restoration
Access Restriction
Monitoring Syster
CONSTRUCTION SUBTOTAL
Contingencies
CONSTRUCTION TOTAL
Permitting
Services During Construction
Deli sting
'Engineering
TOTAL CAPITAL COST
OPERATION AND MAINTENANCE
TOTAL PRESENT WORTH
(102 discount rate, 30-year life)
S 6,970
3,227,000
1,157,400
47* ,0:0
101,250
24,590
149,to:
S 5,170,610
2,066,324
S 7,239,134
155,OOC
775,000
iso.oc:
775,00:
$ 9,0.94,000
5 525,000
$13,989,000
See Appendix D for detailed cost information
£V-j /a 4'* c-+f "**??"<{ t*> I-*' J/&f*>.e\-
K^-t >"' f r-t - '
f <>~^><~
-------
Table 17
TABLE 1-6 (PAGE i or 2)
MIOCO I
CROWD WATER CLEANUP ACTION LEVELS
'Compound
Arsenic
-Barium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercurv
• '
1
Seleniun
Silver
Vanadiun
Zinc
Cyanide
Vinyl chloride
Chloroethane
Methylene chloride
Acetone
Carbon disulfide
1,1-Dichloroethene
1 ,1-Oichloroethane
T rans-1 , 2-dichloroethene
Chloroform
1,2-Oichloroethane
2-Butanone
1 , 1 , 1-T richloroethane
Trichloroethene
o^^^^^^ktc
2 *^^^P^B fi O^ 0
Detection
Limit*
(uo/1)
10
200
5
10
0.2
5
10
50
20
1.8
5
5
1.3
0.7
0.5
0.3
10
1.2
2
Cleanup
Action Level
(uo/1)
6
118
0.235
8
50
3,880
13.5
1,400
0.0462
58
1.41
0.462
4.33
7.33
10.4
1.32
10
1.3
11.1
0.253
0.000165
0.00808
70
0.00275
0.00191
8.44
21.5
0.0139
0.00601
10
Basis
Ground water background concentration (95% UCL}.
Ground water background concentration (95% UCL).
Noncarcinogenic risk from the aite (all media) <1.
Ground water background concentration (95% UCL).
Chronic Water Quality Criteria for the protection o.f
freshwater life, with a dilution factor of 3.85
(from Hideo I Remedial Investigation Report),
lowest detected hardness.
Ground water background concentration (95% UCL).
Chronic Water Quality Criteria for the protection of
freshwater life, with a dilution factor of 3.85,
lowest detected hardness.
Ground water background concentration (95% UCL).
Chronic Water Quality Criteria for the protection of
freshwater life, with a dilution factor of 3.85
Ground water background concentration (95% UCL).
Noncarcinogenic risk from the site (all media) <1.
Chronic Water Quality Criteria for the protection of
freshwater life, with a dilution factor of 3.85.
Ground water background concentration (95% UCL).
Noncarcinogenic risk from the site (all media) <1.
Ground water background concentration (95% UCL).
Ground water background concentration (95% UCL).
Ground water background detection limit.
Ground water bad ground concentration (95%)UCL).
Noncarcinogenic risk from the site (all media) <1.
Noncarcinogenic risk from the site (all media) <1.
Carcinogenic risk from the site (all nedia) <1 £-06.
Carcinogenic risk from the aite (all nedia) <1 £-06.
Maximum Contaminant Level Goal (proposed).
Carcinogenic risk from the site (all media) <1 £-06.
Carcinogenic risk from the site (all nedia) <1 £-06.
Noncarcinogenic risk from the aite (all media) <1.
Noncarcinogenic risk from the aite (all media) <1.
Carcinogenic risk from the aite (all nedia) <1 £-06.
Carcinogenic risk from the aite (all nedia) <1 £-06.
Ground water background detection limit.
-------
TABLE 1-6 (PACE 2 OF 2)
Detection
Limit*
Cleanup
Action Level
Compound
Basis
4-Methyl-2-Pentanone
Tetrachloroethene
Toluene
Ethylbenzene
Xylenes
Phenol
Bis(2-cnloroethyl)ether
Benz>l alcohol
Cresol
Nitrobenzene
Isophorone
2,4-Dimethylphenoi
Benzole Acid
2,4-Oichlorophenol
Naphthalene
10
0.3
10
10
10
10
3.9
10
la'-nc 10
Pentachloropnenol 36
Bis(2-ethylhe«yl)phthalate 10
linda^e Q.Ou
Dieldrm 0.02
Endrm
6.06
2.6
0.0119
71.8
11.1
55
4.46
0.000158
10
5.57
0.0639
0.179
10
446
0.133
2.36.
0.26
2.19
1.5
0.000565
0.0300109
0.00886
Noncarcinogenic risk from the site (all media) <1.
Carcinogenic risk from the site (all media) <1 E-Ci.
Noncarcinogenic risk from the site (all medial <1.
Noncarcinogenic risk from the site .(all media! <1.
Noncarcinogenic risk from the site (all m«i;a)
-------
Table 18
TABLE 1-7 (PACE 1 Or 2)
MIOCO I
SOIL CLEANUP ACTION LEVELS
•Comoound
Detection
Limit-
s/kg)
Cleenup
Action Level
(ug/kg)
Basis
Antimony
^Arsenic
Bariur
Berylliu"
Cadruu1-
Chnmiun
Copper
Iron
Lead
Manganese
Here-jry
Nickel
Tin
Jiur
Cyanide
Methylene Chloride
Acetone .
Trans-1,2-Dichloroethene
2-Butanone
1,1,1-Trichloroethane
Trichloroethene
Benzene
2-Mexanone
4-Methyl-2-pentenone
Tetrachloroethene
Toluene
Chlorobenrne
Ethylbenrene
Styrene
Xylenea
Phenol
1,4-Dichlorobenzene
Cresol
2,960 Noncarcinogenic risk from the site (all media) <1.
16,000 Surface soil background average concentration.
233,000 Noncarcinogenic risk from the site (all media) <1.
310 Noncarcinogenic risk from the aite (all mediaN <1.
2,770 Surface soil background average concentrtatia-.
36,BOO Noncarcinogenic risk from the site (all media) <1.
48,900 Surface aoil background concentration (955 UCL).
13,700,000 Surface aoil background concentration (955 UCL).
146,000 Surface aoil background concentration (95? UCL).
133,000 Noncarcinogenic risk from the site (all media) <1.
305 Noncarcinogenic risk from the site (all media' <1.
67,000 Noncarcinogenic risk from the site (all media) <1.
6,990 Noncarcinogenic risk from the site (all media!1 <1.
22,900 Noncarcinogenic risk from the site (all media) <1.
1,010,000 Noncarcinogenic risk from the site (all media) <1.
47,000 Noncarcinogenic risk from the site (all media) <1.
2,270 Carcinogenic risk from the site (all media) <1 E-06.
47,500 Noncarcinogenic risk from the site (all media" <1.
5 Surface aoil background detection limit.
97,200 Noncarcinogenic risk from the site (all media) <1.
17,900 Noncarcinogenic risk from the site (all media) <1.
1,950 Carcinogenic risk from the site (all media) <1 E-06.
587 Carcinogenic risk from the site (all media) <1 E-06.
10 Surface aoil background detection limit.
70,300 Noncarcinogenic risk from the site (all media) <1.
334 Carcinogenic risk from the site (all media) <1 E-06.
975,000 Noncarcinogenic risk from the site (all media) <1.
32,000 Noncarcinogenic risk from the site (all media) <1.
289,000 Noncarcinogenic risk from the aite (all media) <1.
5 Surface aoil background detection limit.
714,000 Noncarcinogenic risk from the aite (all media) <1.
94,000 Noncarcinogenic risk from the site (all media) <1.
16.5 Carcinogenic risk from the aite (all media) <1 E-06.
991 Noncarcinogenic risk from the aite (all media) <1.
' 330 Surface aoil background detection limit.
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TABLE 1-7 (PAGE 2 OF 2)
Comoound
Isophorone
2,4-Dimethylphenol
Ben zoic acid
Naphthalene
4-Chloro-3-Methylphenol
Detection
Limit*
(uo/ka)
1,600
240
Cleanup
Action Level
(uo/ko)
4,150
330
1,220
44,800
4.7
Basis
Carcinogenic riak from the aite (all media) <1 E-06.
Surface aoil background detection limit.
Noncarcinogenic risk from the site (all media) <1.
Noncarcinogenic risk from the aite (all media) <1.
Noncarcinogenic risk from the aite (all media) <1.
2-Methylnaphthalene
Acenaphthene
Dibenjofuran
Oiethylphthalate 330
fluorene
Pentachlorophenol
Phenanthrene 330
Anthracene
Di-n-outylphthaJate
fluoranthene
Pyrene
Butylbenzylphthalate
Benzoia)anthracene
Bis(2-ethylhexyl)phthalate
Chrysene
Di-n-oetylphthalate 330
Ben zo (b) f 1 uoranthene
Ben zo (k) fl uor anthene
Benzo(a)pyrene
lndeno(l,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benza{g,h,i)perylene
Aldrin 2.7
Oieldrin 1.3
Endrin
Chlordane
PCBs 80
330
330
330
60
330
4,240
131
330
26,300
255
249
26,800
153
1,220
238
36.4
241
154
137
103
330
108
1.0
1.06
375
4,100
2.21
Surface soil background detection limit.
Surface soil background detection limit.
Surface soil background detection limit.
Noncarcinogenic risk from the site (all media? <1.
Surface aoil background detection limit.
Noncarcinogenic riak from the aite (all media) <1.
Surface soil background concentration (95% UCL).
Surface aoil background detection limit.
Noncarcinogenic risk from the site (all media) <1.
Surface soil background concentration (95% UCL).
Surface soil background concentration (95% UCL).
Noncarcinogenic risk from the site (all media) <1.
Surface soil background concentration (95% UCL).
Carcinogenic risk from the site (all media^ <1 E-G6.
Surface soil background concentration (95% UCL).
Surface soil background concentration (95% UCL).
Surface soil background concentration (95% UCL).
Surface soil background concentration (95% UCL).
Surface soil background concentration (95% UCL).
Surface aoil background concentration (95% UCL).
Surface soil background detection limit.
Surface aoil background concentration (95% UCL).
Carcinogenic risk from the aite (all media) <1 E-06.
Carcinogenic risk from the site (all media) <1 E-06.
Noncarcinogenic risk from the site (all media) <1.
Surface toil background concentration (95% UCL).
Carcinogenic riak from the tite (all media) <1 E-06.
•Practical quantitation limits as per USEPA "Test Methods for Evaluating Solid Waste," 3rd Edition,
SH-846, Nov. 1986. Values shown are higher than the corresponding cleanup action levels.
Therefore, the actual cleanup action level for each of these compounds is "nondetectable."
UCL: Upper confidence limit of the average concentration (from Table 13).
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TABLE 19
UNO DISPOSAL KESlHICnCN TREATMENT STANDARDS FOR WASTE
GAOXGCRIES F001, F002, FOO3, FOO5 (ERCM 40 CFR 268.41)
OONCINIKATIONS IN EXTRACT
rag/l
acetone 0.05 0.59
rHDUtyl alcohol 5.0 5.0
carbon disulfide 1.05 4.81
carton tetrachloride 0.15 0.96
chlorobenzene 0.15 0.05
cyclohexanone 0.125 0.75
1,2 dichlorobenzene 0.65 0.125
ethyl acetate 0.05 0.75
ethyl benzene 0.05 0.053
ethyl ether 0.05 0.75
isobutanol 5.0 5.0
methanol 0.25 0.75
methylene chloride 0.20 0.96
methyl ethyl ketone 0.05 0.75
2thyl isobutyl ketone 0.05 0.33
"ridine 1.12 0.33
strachloroethylene 0.079 0.05
toluene 1.12 0.33
1,1,1-trichloroethane 1.05 0.41
1 , 1 , 2-trichloro-l , 2 , 2
trifluoroethane 1.05 0.96
trichloroethylene 0.065 0.091
trlchloroflouirmethane 0.05 0.96
xylene 0.05 0.15
*A capacity variance is in effect for soil waste and debris until November
1990.
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PROPOSED LAND RESTRICTION TREATMENT STANDARDS
FOR WASTE CATEGORIES F007, F008, F009,
(FROM F.R., VOL, 53, NO. 7, P. 1068)
WASTEWATERS:
TABLE 20
OONSTTTUENT
cyanide (total)
cyanide (amenable)
chromum
lead
nickel
TOTAL OOMPOSrnON
(mg/D
12
1.3
0.32
0.04
0.44
TCLP
(ng/D
NONWASTEWATERS:
cyanides (total)
cyanides (amenable)
cadium
chromium
lead
nickel
silver
(rog/kg)
110
0.064
(ng/1)
0.066
5.2
0.51
0.32
0.072
-------
DRAFT
strucruraJ/functionaJ groups shown in column 1 of Highlight
5. After dividing the BOAT constituent.' into their
respective strucruraJ/fuhctionaJ groups, the new step u to
ipare (he concentration of each constituent with the
FrvshoJd concentration (see column 3 of Highlight 5> and
to select the appropriate concentration level or percent
reduction range. If the concentration of the restricted
constituent is less than the threshold concentration, the
waste should be treated to within the concentration range.
If the waste concentration is above the threshold, the waste
should be treated to reduce the concentration of the waste
to within the specified percent reduction range. Once the
appropriate treatment range is selected, the third step is to
identify and select a specific technology that can achieve the
necessary concentration or percent reduction. Column 5 of
Highlight 5 lists technologies that (based o= :n<:—c
performance data) can attain the alternate Ire. --..;,-'
Variance levels.
During the implementation of the selected treat-::-:
technology, periodic analysis using the appropriate :;H»-^
procedure (i.e.. total waste analysis for orgaoucs ace TCLF
for inorganics) wilJ be required to ensure That tie iltirza;;
treatment levels for the BOAT constituents recurve coo:.-:":
are being attained and thus can be land disposed" *v.i.x:
further treatment.
Because of the variable and uncertain cbaracreri5::c.<>
associated with unexcavated wastes, from *hjch oc.-
sampling data are available, treatment systsss genera.!.
Highlight 5. ALTERNATE TREATABILTTY VARIANCE LEVELS AND
TECHNOLOGIES FOR STRUCTURAL/FUNCTIONAL GROUPS
Structural
Functional
Groups
Concentration
Mange
(ppm)
H«wg«
Non-»w*r
0.5 - 10
Threanoid
Concentration
(pom)
100
Reduction
Mange
90-909
TecnnoJogies tfiat acrueved
recommended effluent
concentration guidance ••
BtaAooce) T^ei^Bnt l
Sot weenrc. Thennei
Owffunor
C"can»
0.00001 - 0 06
0.5
90-909
01 - 10
100
90-909
SoJWe*»v
0 002 - 0 02
02
90-990
• ft
0.5-40
400
90-90
wOemcio
0.5-2
98-99.9
Low Temo
SolWMnnc.
Nwaq*n4tee
i C.cics
0.5-20
200
90-900
NfQWO
»'?*n«CT
2.5 - 10.0
10.000
99-9099
SoJWMnriQ
H«wQcycuef
0.5-20
200
90-999
LOW Temp. SWpnQ. So< Wtenmg.
tow Temp STOpng. Sol
Benum
tti-«a
e00
90-flB
03-a
120
98-909
Soiw<
0.4-1
9S-99J
0008
0^-22
0.1-3
OB-90.9
0.0003 - O.OOB
009
90-90
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MTTXP I AND MIDOO U RESPONSIVENESS SLM4AKY
I. FESKKSIVENESS SUMMARY OVERVIEW
In accordance with CERCIA Section 117, a public comment period was held from
April 20, 1989 to May 19, 1989, to allow interested parties to Garment on the
United States Environmental Protection Agency's (U.S. EPA's) Feasibility
Studies (FSs) and Proposed Plans for final remedial actions at the Midco I and
Midco II hazardous waste sites. On April 27, U.S. EPA conducted a public
meeting in which the Proposed Plans were presented, questions answered and
public comments accepted.
The purpose of this responsiveness summary is to document comments received
during the public comment period, and provide U.S. EPA's responses to these
comments. All comments summarized in this document were considered in EPA's
final decision for remedial action at the Midco I and Midco II sites.
U. BACKGROUND ON OJMUNTIY INVOIA/EMENT
The Midco I site (as well as another National Priorities List site, Ninth
Avenue Dump) is located in Gary, Indiana. The nearest residential area is in
Hammond, Indiana within one-fourth mile of the site. On December 21, 1976, a
fire at Midco I destroyed thousands of drums of chemicals. Community concern
about the site intensified in 1981. In March 1981, a 14-year old Hammond boy
suffered leg burns while playing near the site; his parents attributed the
burns to chemicals. In June 1981, a heavy rainfall resulted in flooding in
Hammond and the flow of surface water from the Midco I and Ninth Avenue Dunp
areas into Hammond. Several residents complained of chemical odors in flooded
basements and chemical burns from contact with flood waters. These problems
were attributed to run-off from Midco I and Ninth Avenue Dump. In response to
this occurrence, Hammond constructed a dirt diJoe across Ninth Avenue at the
dine Avenue overpass. This dike is still in place and is a source of
controversy between Gary and Hammond public officials. The Indiana
Department of Environmental Management sent a letter stating that the dike was
still necessary to prevent contamination from the sites from entering Hammond.
Gary and Hammond public officials and nearby Hammond residents have been
actively involved in promoting remedial actions at Midco I.
The Midco U site is more isolated from residential areas. The nearest
residences are a small cluster of homes located approximately one mile
southeast of the site. In 1977, a fire occurred at the site that destroyed
thousands of drums of chemical wastes.
In 1981, U.S. EPA installed fences around Midco I and Midco II. In 1982,
U.S. EPA conducted a surface removal action at Midco I that included removal
of all containerized wastes and the top one foot of contaminated soil, and
installation of a temporary clay cover. From 1984-1989, U.S. EPA conducted a
removal action at Midco II that included the removal of all containerized
wastes, and excavation and removal of contaminated sub-surface soils in areas
where wastes had been dumped directly onto the ground. On July 8, 1982, a
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-2-
public meeting was held to discuss the Midco I removal action. Other
community relations activities were also conducted during the removal actions.
U.S. EPA held public meetings to disniss the initiation of the Remedial
Investigation/Feasibility Studies (RI/FSs) on February 21, 1985 for Midco I
and on July 18, 1985 for Midco II. Residential well sampling for the RI/FSs
identified several contaminated wells, but the contamination was not
attributable to the Midco sites. U.S. EPA provided updates to the community
on the status of the studies using fact sheets in November 1987 and December
1988.
Proposed Plans for Midco I and Midco II were combined into one fact sheet and
mailed to over 100 concerned parties. Oral comments were accepted during the
public meeting on April 27, 1989. In addition, written comments were received
during the public comment period from the City of Hammond, the Indiana
Department of Highways, a private citizen in Gary, a slurry wall contractor,
the Midco Steering Committee (which represents the potentially responsible
parties that conducted the RI/FSs) , and from Morton-Thicko!, Inc.
SUhfftRY OF SIGNIFICANT OCWENTS RECEIVED DURING THE PUBLIC COWENT
PERIOD AND U.S. EPA RESPONSES
The comments are organized into the following categories:
A. Comments received during the public meeting, and comments received in
writing from the City of Hammond, from a slurry wall contractor and from a
private citizen from Gary.
B. Comments received from the Indiana Department of Highways.
C. Comments received from the Midco Steering Committee and from Morton-
Thiokol.
A. SOMARY OF CCMiENTS RECEIVED CURING THE PUBLIC MEETING, AND CCM1ENT5
RECEIVED IN WRITING FRCM THE CHY OF HAWCND, FRCM A SII1RRY WALL GCNIBACTCR
AND FRO* A PRIVATE CITIZEN FRCM GARY
GCMMENT fl:
A number of comments were received concerning the protectiveness of deep well
injection of hazardous wastes. The specific comments included the following:
"In 13 states casings have cracked and leaked in deep well injections."
"Why is it they never address with landfills or deep well injections
earthquakes in the area and what they anticipate is going to happen to all
these nice little hazardous waste dumps we have either under the ground or
on top or wherever they're at."
"I would like to know how many deep wells there are in existence today."
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— -3-
"How long have they been in existence?"
"Have there been any problems with any of them?"
"How does the EPA prevent any problems? Are you saying that because they
stepped in there are no more problems or what?"
"Isn't it true that the steel mills stopped disposing of their own waste by
deep well injection many years ago? What are they injecting now?"
"I am requesting that ... (2) the E.P.A. report how the preferred option of
injecting hazardous wastes two thousand (2,000) feet underground will
affect my neighbors' well as my own."
"There is always the possibility that the substance injected into the deep
well will contaminate other aquifers."
"In addition, although these aquifers may not currently be used because of
their depth, or because they contain salt-water there may come a time when
out of necessity they may be needed to supply drinking water to future
generations."
"At a minimum the contamination in the ground water should be treated
prior to any deep well injections so as to mitigate any adverse
environmental effects that may occur in the future."
"The solution to environmental problems is not to place out of sight or to
dilute, but to correct."
U.S. EPA RESPCXSE TO CCMENT fl:
Congress recognized concerns regarding deep well injection of hazardous wastes
and enacted a number of statues to assure that deep well injection is only
conducted at locations and using procedures that will assure long-term
protection of human health and the environment. Deep well injection is
regulated by U.S. EPA under a number of statutes, primarily the Safe Drinking
Water Act (SDWA) (Pub. L. 93-523, as amended; 42 U.S.C. 300f et seq.), and the
Resource Conservation and Recovery Act (RCRA) (Pub. L. 94-580 as amended; 42
U.S.C., 6901 et. seq.). RCRA was modified by the Hazardous and Solid Waste
Amendments (KSWA) of 1984 to restrict land disposal and deep well injection of
hazardous wastes. Congress intended that deep well injection be allowed only
if it is protective of both current sources of drinking water, and any ground
water that could potentially serve as an underground source of drinking water
(USDW). A USDW generally includes any aquifer that contains a sufficient
quantity of ground water to supply a public water system and contains less
than 10,000 mg/1 of total dissolved solids (TDS). Recovery of drinking water
from an aquifer with a TDS greater than 10,000 mg/1 is not considered to be
technically or economically feasible. (See 40 CER 144.3).
Lations under the SDWA prohibit (with few exceptions) injection of any
waste into a USDW. Hazardous wastes can only be injected into
formations that are below the lower-most formation containing, within one-
-------
-4-
quarter mile of the veil bore, a USDW. All injection wells must be permitted
by U.S. EPA or an appropriate state agency. Regulations regarding permit
requirements have undergone extensive review and public cement. Permit
conditions prohibit any injection activity that allows the movement into a
USDW of fluid containing any contaminant, if the presence of that contaminant
nay cause a violation of any primary drinking water regulation (40 CFR 144.12)
or nay otherwise adversely affect the health of persons. Another permit
condition requires permittees to take all reasonable steps to minimize or
correct any adverse impact on the environment resulting from non-compliance
with the permit. (See 40 CFR 144.12).
Underground injection permits include strict construction, corrective action,
operation, abandonment, monitoring, reporting and financial requirements to
assure that the injection well is constructed and operated in a manner that
will meet U.S. EPA requirements and be protective of human health and the
environment.
U.S. EPA's permit review assures that hazardous waste injection wells are only
constructed in locations that are geologically suitable. This includes
consideration of the following factors:
1) the structural geology, stratigraphic geology, the hydrogeology, and
the seismicity of the region (including evaluation of the potential for
earthquakes) ;
2) an analysis of the local geology and hydrogeology of the well site;
3) a determination that the geology of the area can be confidently
described and that the limits of waste fate and transport can be
accurately predicted through the use of models.
Hazardous waste injection wells must be sited such that:
1) the injection zone has sufficient permeability, porosity, thickness
and area! extent to prevent migration of fluids into a USDW;
2) a confining zone is present above the injection zone which is
laterally continuous and free of transecting, transmissive faults or
fractures over an area sufficient to prevent the movement of fluids
into a USDW, and which contains at least one formation of sufficient
thickness and with lithologic and stress characteristics capable of
preventing vertical propagation of fracture.
In addition, U.S. EPA may require that the owner or operator of a hazardous
waste deep well demonstrate either:
1) that the confining zone is separated from the base of the lowermost
USDW by at least one sequence of permeable and less permeable strata
that will provide an added layer of protection for the USDW in the event
of fluid movement in an unlocated borehole or transmissive fault; or
-------
2) that within the area of review, the piezometric surface of the fluid
in the injection zone is less than the piezometric surface of the
lowermost USDW; or
3) that there is no USDW present.
(See 40 CFR 146.62).
Further data collection is required during construction of the deep well to
determine or verify the geology and the quality of the construction.
Measurements include resistivity, spontaneous potential, caliper, cement bond,
density, temperature, porosity, gamma ray and fracture finder logs, a pressure
test, a radioactive tracer survey, core samples, and a casing inspection
survey. The injection well must be cased and sealed to prevent any migration
of injection fluid up the borehole. A double casing is required from the
surface to below the lowermost USDW.
The owner or operator must assure that the injection pressure at the wellhead
does not exceed a maximum pressure in the injection zone during injection, and
does not initiate new fractures or propagate existing fractures in the
injection zone. The injection tubing must be surrounded by an annular space,
which is filled with fluid. The injection pressure, flow rate, and volume of
injected fluids, and the pressure on the annulus, must be continuously
monitored.
U.S. EPA uses three interrelated program requirements to assure compliance
with well operating regulations. Mechanical integrity tests measure the
operating soundness of the wells, including checking for leaks. Operator
reports include information on the waste being injected; the well pressure,
flow rate and volume; and report the degree of permittee compliance with these
permit conditions. Periodic inspections determine the accuracy of operator
self-monitoring and the adequacy of injected-vaste sampling. The attached "A
GUIDE TO THE FEDERAL UNDERGROUND INJECTION CONTROL PROGRAM IN INDIANA"
provides a general description of the permit program and how potential
pathways of contamination are controlled in the deep wells.
Congress addressed concerns about the long term protectiveness of landf illing
or underground injection of hazardous wastes in the HSWA. This act
established land (or deep well) disposal restrictions focused on minimization
of land ^igpngai or deep well injection of hazardous wastes. These
restrictions prohibit the land disposal or deep well injection of specified
hazardous wastes beyond statutory dates established by Congress unless 1) the
wastes are treated to a level or method specified by U.S. EPA, 2) it can be
demonstrated there will be no migration of hazardous constituents from the
Hjgpncai unit for as long as the waste remains hazardous, or 3) the waste is
subject to an exemption or a variance. The no-migration demonstration
mentioned above can be approved by U.S. EPA under the condition that the
hydrogeological and geochemical conditions at the sites and the pnysiochemical
nature of the waste stream are such that reliable predictions can be made
that:
-------
1) injected fluids will not migrate within 10,000 years vertically
upward out of the injection zone, or laterally within the injection
zone to a point of discharge or interface with a USDW; or
2) before the injected fluids migrate out of the injection zone or to a
point of discharge or interface with USDW, the fluid will no longer be
hazardous. (See 40 CFR 148.20)
Such a no-migration demonstration Trust depend heavily on fluid flow modeling.
Fluid flow modeling is a well-developed and mature, science, having been used
for years in the petroleum industry as well as in recent studies for the
Department of Energy nuclear waste isolation program.
U.S. EPA believes that the no-migration petition requirements are so stringent
that if such a petition is approved for disposal of the ground water from
Hideo, deep well injection, even without treatment, will be considered to
provide permanent protection to human health and the environment. If the deep
well injection system receives approval from U.S. EPA, the injection will have
no impact on USDW, which includes any residential wells.
Presently, four steel mills in northwest Indiana are legally injecting
hazardous wastes into the Mount Simon aquifer located approximately 2200 feet
below the surface. These include U.S. Steel, Inland Steel, Bethlehem Steel
and Midwest Steel. Three of these facilities (Inland, Bethlehem and Midwest)
have submitted a no-migration demonstration to U.S. EPA for approval in order
to allow them to continue hazardous waste injection without treatment. U.S.
Steel is expected to submit a demonstration soon. The hazardous wastes being
injected are waste pickle liquor and waste ammonia liquor. U.S. EPA expects
to make a decision on the no migration demonstrations for these facilities by
March of 1990. If the no-migration demonstration is approved for these
facilities, it is likely that a similar demonstration will be approved for
Midco.
If the no-migration petition is not approved, the contaminated ground water
from the Midco sites would have to be treated prior to the deep well
injection. The required level of treatment is established nationally as the
best demonstrated available treatment method for that type of waste.
It has been estimated that as many as 500,000 injection wells are in operation
in the United States, but there are only 191 hazardous waste injection wells.
These wells are concentrated in Texas, Louisiana, Illinois, Indiana, Michigan
and Ohio. The oldest hay-aTtVmia wastes injection well dates back to 1951. Use
of haTaniniOT waste injection wells underwent a thorough review by the
Government Accounting Office in 1986. The results of their investigation are
summarized in a document named "Hazardous Waste Controls Over Injection Well
Disposal Operations", GAO/PCED-87-170, August 1987.
GftO determined that nationwide, two cases of USDW contamination have been
documented by companies operating hazardous waste injection wells. In
addition, one case of suspected contamination and eight cases of contamination
of water that was already considered unsuitable for drinking have been
documented. The USDW contamination occurred in Texas and Louisiana but was
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-7-
sive. Program controls now in place prohibit the practice that led
•jo the two cases of drinking water contamination.
."he leakage from hazardous waste injection wells into non-drinking water
iquifers occurred at eight facilities between 1975 and 1984. The causes of
:he leakage centered on casing and/or tubing corrosion or deterioration. The
lost notable of these cases occurred at a commercial facility in Ohio in 1983
/here large amounts of waste escaped into an unpermitted zone. This zone was,
lowever, separated from the bottom of the lowermost USDW by more than 1500
feet, of which 1000 feet was confining rock formations. In response, to these
md other concerns, and to the Congressional mandate for additional ground
rater monitoring requirements in the Safe Drinking Water Act Amendments of
.986, U.S. EPA is implementing stricter regulations. This includes:
- more specific well-siting requirements;
- an expanded "area of review" around injection wells for identifying
abandoned wells near the injection site, and added requirements for
corrective action to plug abandoned wells;
- additional operating procedures, such as automatic well shutoff or
alarms; new requirements for testing, monitoring, and reporting,
including a waste-analysis plan, additional mechanical integrity
tests, and more specific monitoring requirements; and
new requirements for well closure and post-closure care.
he GAD report also pointed out that the full extent to which injected
•azardous waste has contaminated underground sources of drinking water is
inknovn because of the problems in detecting contamination that may have
ccurred away from the well-bore. The documented cases of contamination have
ill occurred near the well-bore. However, regulations require that injection
ells not be located in areas where faults occur and that injection pressures
e maintained below a level that might cause fractures in the formation.
egulations also require that all man-made holes in the area penetrating the
onfining zone and entering the injection zone be located and properly
lugged. In addition, U.S. EPA is implementing requirements to monitor the
ligration of the waste movement.
he GAD report concluded that the new deep well injection requirements should
.rcvide additional safeguards to prevent the contamination of USDWs. In
ddition, well owners will be required to demonstrate no migration of
azardous waste.
(MOOT 12:
he City of Hammond comments included a statement that "Preferably the
would be to such an extent that the treated groundwater could be
into the aquifer from where it originated."
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-8-
U.S. EPA RE5PCK5E TO OCMEWT |2:
See cur response to o-anman*-- #5 below and to Cuiaiimit #5 from the Midco Steering
Ocomittee and Marton-Thiokol.
CO«EOT |3:
During the public meeting there were a number of Garments concerning whether
U.S. EPA puts too much emphasis on costs in its decisions on remedial actions,
and whether alternative innovative treatment and disposal technologies were
considered. Specific comments included the following:
"All we're talking is cost effectiveness.1*
"I don't think it's fair. I think cost should be put aside. These people
that are going around polluting should be made to pay. ... It's not costs
these chemicals that leak out <"g«nB«» canc^T and a number of other
sicknesses. . . . How do you put a price tag on one's life? Tell me.
"Those responsible for creating environmental problems must pay the
expense of correcting their mistakes."
"They're supposed to be using the best available technology not the most
cost effective."
"Stop delving into the pockets of the public."
"Why didn't they decide to use vitrification?"
"I'd like to know if any of these people knew about "The Superfund
Innovative Technology Evaluation Program Technology Profiles" or
"Assessment of International Technologies for Superfund Applications."
U.S. EPA RESPCNSE TO OCMQNT |3:
The Comprehensive Environmental Response, Compensation and Liability Act
(CERCXA) was enacted in 1980 to provide broad federal authority and resources
to respond to releases (or threatened releases) of hazardous substances. A
trust fund was ogfr^frHgtwi to pay for »>mn*i|a][ actions at ^^TVTvgd or
uncontrolled hazardous waste sites. This fund is predominantly from a tax on
petroleum prr»'^|y^!s and on certain chemicals.
Based on the principle that "the polluter should pay," CERCXA contains
authorities which allow U.S. EPA to ensure that those responsible for
hazardous waste problems pay for necessary remedial actions. CERCLA
enforcement authorities enable U.S. EPA to encourage responsible parties to
undertake remedial actions. It also enables U.S. EPA to spend trust fund
monies for remedial actions and to later recover these monies from responsible
parties.
If an acceptable agreement can be reached, U.S. EPA prefers that responsible
parties implement the remedial actions. At Midco, an agreement was reached
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with potentially responsible parties (PRPs) in June 1985, which required the
PRPs to reimburse U.S. EPA $3,100,000 for past costs incurred and to conduct a
Remedial Investigation/Feasibility Study (RI/FS) at each site in accordance
with the U.S. EPA's work plans. U.S. EPA is now negotiating with FRPs for
implementation of the remedial actions selected by U.S. EPA and for recovery
of the remaining costs incurred. Fund monies will be spent on the final
remedial actions only if an agreement is not reached with PRPs.
In CERdA (as amended by the Superfund Amendments and Reauthorization Act of
1986), Congress mandated that all final remedial actions selected by U.S. EPA
oust assure protection of human health and the environment, and must meet
applicable, and relevant and appropriate Federal and State standards,
requirements, criteria, and limitations (ARARs). This includes meeting
Federal Primary Maximum Contaminant Levels in the ground water (40 CFR 142).
Congress also mandated that U.S. EPA select remedial actions that are cost
effective, and that utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable. If a remedial action is selected that does not meet this
preference, U.S. EPA must publish an explanation as to why a remedy involving
such a remedial action was not selected.
The least costly alternative that would be protective of human health and the
environment was the containment alternative (Alternative 3), which is
estimated to cost $4.7 million at Midco I and $7.9 million at Midco II. U.S.
EPA is not selecting these alternatives because they would simply contain the
contamination, and the hazards would be similar to taking no action if the cap
or slurry wall were ever damaged in the future. Instead, U.S. EPA is
selecting remedial actions that it believes will provide permanent protection
to human health and the environment. This consists of soil vapor extraction
and solidification of contaminated soils combined with pumping and deep well
injection of contaminated ground water at Midco I, and the same actions at
Midco II except that the soil vapor extraction is not required. In addition,
treatment prior to deep well injection will be required if a no-migration
demonstration is not approved by U.S. EPA. The estimated cost of these
remedial actions at Midco I is from $10.7 to $14.0 million, and at Midco II
from $14.4 to $18.6 million (depending on the degree of treatment required
prior to deep well injection).
The persons involved in reviewing the Feasibility Studies are familiar with
"The Super fund Innovative Technology Evaluation Program; Technology Profiles."
The Superfund Innovative Technology Program includes a number of studies on
solidification, which is part of the selected remedial actions at the Midco
sites. This includes processes by Chemfix Technologies, Hazcon, International
Waste Technologies, Silicate Technology Corporation, and Soliditech. Soil
vapor extraction, which is part of the remedial action at Midco I, is also
included in this program in a process by Terra Vac. Other innovative
technologies were considered for treatment of the contaminated soils at the
Midco sites but were screened out because they were not considered applicable
to the conditions at the site. These include in-situ biodegradation, soil
flushing, and chemical treatment. In-situ vitrification and incineration
alternatives were evaluated in detail. Vitrification was not selected because
it has not been demonstrated to be implementable in a full scale remedial
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-10-
action at a har-aTt^nis waste site and because the high water table would make
implementation difficult and more expensive. The incineration alternative
does not suffer those disadvantages. However, both in-situ vitrification and
incineration would be considerably more expensive than solidification and
would not contribute significantly to the permanence of the remedial actions
if the soil vapor extraction and solidification operations are successful.
Since a surface water discharge would probably not be approved for the salt
contaminated ground water even after removal of the hazardous substances, the
alternative to deep well injection of the ground water is to concentrate the
solids in the ground water by an operation such as evaporation. Evaporation
would concentrate at least some haaanlnHfl substances into a solid that would
have to be dlspnspri of in an off-site landfill. It does not appear that
of the ha»THnia wastes in an off-site landfill is any more
protective of human health and the environment than disposal by deep well
injection, and the costs of the evaporation operation would be higher than the
deep well injection.
"I've been involved in a couple projects, not in this state, where they used
in conjunction with the slurry wall a well extraction, and then they leached
it back in like a septic field. Then it recirculates. Are these contaminants
able to be treated in that respect; and therefore, you wouldn't have deep well
disposal and you wouldn't have a lot of things that would be objectionable at
this point.1*
U.S. EPA BE5PCK5E TO GCMMEMT |4:
This method of treatment would not be adequate for the highly contaminated
soils on the site, but it would be acceptable to U.S. EPA for ground water
treatment when combined with a soil treatment measure.
Reinjection of the salt-contaminated ground water following treatment for
hazardous substances would be acceptable to U.S. EPA if the reinjection does
not cause significant spreading of the salt plume. Installation of a slurry
wall and reinjection within the slurry wall is one way of preventing such
spreading. This alternative is not preferred over deep well injection at the
Midco sites for the following reasons: U.S. ERA believes that deep well
injection can be accomplished safely and effectively; it is preferable to
remove the salt contaminated ground water from the Calumet aquifer rather than
containing it within a slurry wall; and there does not appear to be a cost
savings using the slurry wall/rein jection alternative compared to deep well
injection.
OOMEOT |5:
"As a slurry wall contractor, I would like to umiueaL on the slurry wall
pricing listed in your Fact Sheet. I have never seen prices like these, and,
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-11-
a^Ktractor, I would like to know what they were based on. Today, our
oes for Slurry Wall construction range from $3 to $5 per square foot and a
tonite cap $.50 per square foot."
. EPA RESPONSE ID OMffiMT |5:
»
price estimates were developed by Dames and Moore, a consulting firm
loyed by the Midco Steering Committee. According U.S. EPAs's contact with
s firm, the estimates were based on actual quotes from vendors. The costs
3 also reviewed by personnel from Roy F. Weston, Inc.
•
prices are probably not comparable to the quotes suggested by the
Tienter because a different type of cap and slurry wall were proposed in the
The proposed cap is not just a single-layer bentonite cap. Instead, it
a multi-layered cap consistent with the most recent guidance for RCRA
ardous waste sites. It includes a clay liner, a synthetic liner, a lateral
inage layer, and a vegetative layer. Instead of installation of the slurry
1 by the vibrating beam method, installation by a trench/slurry method was
posed. The proposed slurry wall would be approximately three feet thick
le a slurry wall installed using the vibrating beam method is only a few
les thick. Safety considerations also add to the cost of actions at a
ardous waste site.
v deep, how far down has this pollution gone in the sites?"
. EPA RESPONSE TO GCMtENT |6:
contamination appears to be confined to the Calumet aquifer, which extends
mxiroately 30 feet below the surface at Midco I and 40-50 feet below the
face at Midco II. Below the Calumet aquifer is 90-100 feet of low
usability clays and tills.
!EWT #7:
many people review the chemical data, and how do the different agencies
other parties work together?
. EPA RESPONSE TO GCMfENT |7:
chemical data was generated by a laboratory that conducted its own quality
irance/quality control (QA/QC) review of the data. The laboratory used in
; project is also audited by the U.S. EPA. The chemical data was then sent
i contractor hired by the PRPs, who conducted an independent QA/QC review
:he data. The contractor review was also audited by U.S. EPA. A QA/QC
the data was conducted by a second contractor working for the PRPs.
contractors conducted an interpretive review of the data, and
ared a report that included plotting the distribution of data on a map,
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— -12-
comparison to standards and a discussion of the data. This report was
reviewed by at least five persons at U.S. EPA, six personnel working for U.S.
EPA contractors, one person fron the U.S. Fish & Wildlife Service, and three
persons from the Indiana Department of Environmental Management.
U.S. EPA personnel reviewing the data included personnel from the air, water,
Great lakes and RCRA programs, who reviewed the report for concerns
specifically related to their programs. The U.S. Fish & wildlife Service
reviewed the report for adequacy of information on ecological effects.
Contractors working for U.S. EPA provided support to U.S. EPA with review of
costs, hydrogeology, ground water modeling, risk assessment and other areas.
A remedial project manager for the U.S. EPA provided an overall review and
compiled the review comments, from other agencies and contractors for
transmittal to the contractor conducting the RI/FS for the Hideo Steering
Committee. Communications among U.S. EPA employees, other Federal agency
employees and U.S. EPA contractors usually consist of informal discussions
that are followed up by formal memos.
The Indiana Department of Environmental Management generally prepared their
own comments in writing.
CO-WENT |8:
"How are you monitoring landfills?"
U.S. EPA RESPONSE TO CCMMENT 18:
Hazardous waste landfills are regulated by U.S. EPA under the Resource
Conservation and Recovery Act (RCRA) and by the various states under acts
similar to RCRA. Under these acts all hazardous wastes entering a landfill
must be manifested. A copy of the manifest is sent back to the ccnpany that
generated the hazardous waste and sometimes back to the state agency in order
to verify that the shipment arrived.
The acts also regulate operation and monitoring of the hazardous waste
landfills. Monitoring requirements include periodic sampling of ground water
near the landfill. Self-monitoring reports including ground water sampling
data are periodically sent from the landfill to the agency responsible for
oversight of these facilities (which can be Federal or state agencies). Each
hazardous waste landfill is also inspected periodically by a state or Federal
inspector.
Sanitary landfills are regulated primarily by the states. The IDEM inspects
sanitary landfills periodically and requires that ground water monitoring be
COMMENT *9:
One resident of Gary, Indiana expressed the following concern: "I am
concerned by the EPA studies performed on the Porter and lake County wells
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— -13-
lich ocncluded their well water was unsafe to drink. I an requesting that
(1) the EPA conduct a study to determine the quality of ray neighbors' well as
ny own...1*
U.S. EPA RE5FCN5E TO CCMfDfT |9:
The Porter County study referred to is an investigation conducted by the
Porter County Health Department of the effects of three landfills in Porter
County, Indiana on residential and monitoring wells .near the landfills. These
landfills will have no impact on well water in Gary, Indiana.
The well of concern is located near 17th and Baker Street in Gary. The
identified hazardous waste sites closest to the resident are Midco I and
Ninth Avenue Dump (which are approximately two miles away), and Lake Sandy Jo
and the Gary City Landfill (which are approximately one mile away). U.S. EPA
has conducted detailed investigations at each of these sites. The well of
concern was not included in these studies because it was considered to be
outside of the area that could be affected by the sites. The results of the
investigations confirmed that none of these sites will have any impact on the
well of concern. Furthermore, U.S. EPA will conduct remedial actions at the
Midco I, Ninth Avenue Dump, and Lake Sandy Jo sites that will eliminate
significant health risks, if any, from the sites even to the residents closest
to the sites. Ground water at the Gary Landfill is being pumped in a manner
that is preventing ground water from the site from flowing off-site.
COMEtf! |10:
"If the U.S. EPA would choose an alternative using incineration, we ask that
Ordinance 15090, passed by the Common Council of the City of Hammond, be
incorporated into the design parameters. We feel the standards incorporated
into Ordinance #5090 will protect the health and welfare of those citizens who
live adjacent to the site."
U.S.EPA RESPONSE TO CCM4ENT 110:
The alternative selected by U.S. EPA in this ROD does not include
incineration. If incineration was conducted, the U.S. EPA would not consider
the City of Hammond's incinerator regulations to be either an applicable, or
relevant and appropriate requirement since the operation would be conducted
outside the city limits of Hammond. However, U.S. EPA will likely reach
similar goals through requiring compliance with standards set by the RCRA,
TSCA and CERCLA programs. These include the following:
1) Each principal organic hazardous constituent in the waste must be reduced
to 0.01% of the original concentration before emission into the air. The
RCRA program refers to this as 99.99% destruction and removal efficiency.
Sane of the more toxic compounds, including polychlorinated biphenyls, must
be reduced to 0.0001% of the original concentration.
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_ -14-
2) Hydrochloric acid emissions, if greater than 4 pounds per hour, must be
reduced by 99%. Emissions of particulate matter may not exceed 0.08
grains per dry standard cubic foot.
B. SUMARY OF GO-WENTS FROM THE INDIANA DEPARTMENT OF HJQKAYS:
OCMKEMT fl:
The FS report fails to clearly define the contaminant transport mechanism
that has caused dissolved salt contaminants (e.g. chlorides) to migrate from
the IDOH Subdistrict site, against the prevailing ground water flow direction
and hydraulic gradient, and be deposited in the ground water underlying the
Midco I site."
U.S. EPA RESPONSE TO COMMENT fl:
The mechanism is explained on pages 1-13, 4-19, and 5-32 of the "Remedial
Investigation of Midwest Solvent Recovery, Inc. (Midco I)" dated December
1987, as follows: "Chloride values were also high (up to 7,700 mg/1) in
shallow wells (10-fcot-deep) in a band extending through the middle portion of
the site (MW7, MW6, MW5, Figure 5-25). ... This band occurs in a former
swale area that received run-off from the Indiana State Highway Department
property prior to Midco I as documented on September 1973 aerial photographs.
The evidence suggests that chloride in the shallow wells was derived from
concentrated NaCl surface run-off percolating downward to ground water in the
former swale area."
COMMENT 12:
"It is plausible that other chloride-containing wastes (e.g., pickle liquor,
waste oils containing chlorinated paraffins, etc.) were improperly managed or
dispmqpri of on the Midco I site and that IDOH is, therefore, not the sole
source of chloride contamination in the site area."
U.S. EPA RESPONSE TO COMMENT |2:~
U.S. EPA agrees that the Midco I site operations likely made a contribution to
the salt contamination in the ground water below and down gradient from the
site. U.S. EPA believes that both IDOH and the Midco I operations contributed
to this salt contamination, but the amount attributable to each source cannot
be determined.
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-15-
"Also the FS report fails to distinguish between reactive cyanides, which were
likely present on Midco I, and complexed ferrocyanide, which was used by IDOH
as an anti-caking agent in the salt. The conplexed ferrocyanide poses little
risk to human health or the environment under most conditions, while the
reactive forms are of greater environmental concern. "Additional technical
evaluation of the type, distribution, and potential impact of the cyanide
contaminants in the subsurface environment should be conducted.1*
U.S. EPA RESPCKSE TO GCM4EOT 13:
Four rounds of sampling were conducted for cyanide. The last round included
tests for cyanide amenable to chlorination as well as total cyanide. U.S. EPA
agrees that reactive forms of cyanide (some of which were likely disposed of
at Midco I) are more hazardous to human health and the environment than
conplexed ferrocyanide.
OOWENT 14:
FS Figure 1-32 showing the distribution of cyanide in the aquifer is
misleading- and improperly constructed.
U.S. EPA RESPONSE TO CCM-tENT |4:
U.S. EPA agrees that Figure 1-32 in the draft FS was misleading and improperly
constructed. This Figure was removed from the final FS report, at the request
of U.S. EPA. U.S. EPA agrees that the highest cyanide concentrations are in
the east-central portion of the Midco I site.
OOWENT 15:
"CALs (cleanup action levels) have not been established for chlorides in soil,
ground water, or surface waters at the Midco I site, an apparent indication
that no site-specific health or risk-based factors have been determined for
this parameter."
U.S. EPA RESPONSE TO GCMIEtfT 15:
The salt contamination in the ground water has been viewed as a concern
primarily because of the loss of a resource (that is, usage of the ground
water) rather than as a human health or environmental hazard. In spite of
this, there are some human health and environmental hazards from the salt
contamination. Sodium greater than 20 mg/1 in drinking water can have a
negative health effect on persons on a low sodium diet. High salt content can
also have an impact on fresh water aquatic life.
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COMMENT |6:
"An independent study commissioned by IDOH did not disclose total cyanide in
surface and subsurface soils at concentrations exceeding the soil CAL (136
ppm); the soil levels detected were typically 1 to 2 orders of magnitude below
the CAL. Only 2 of 16 ground water samples collected from monitoring wells on
the IDOH property exceeded the ground water CAL for cyanide (10.4 ppb).
U.S. EPA RESPONSE TO COMMENT |6:
U.S. EPA can respond to this comment once the referenced data has been sent to
U.S. EPA for review.
COMMENT |7:
IDOH recommended that the alternative of discharge to the City of Hammond
sewer system be reevaluated. It was argued that the discharge of salt from
the Midco I ground water, would be minor compared to the present salt load
discharged to the Hammond Waste-water Treatment Plant.
U.S. EPA RESPONSE TO COMMENT |7:
In general, discharge of highly saline wastewater to a POTW is not allowed due
to potential interference in the biological treatment processes. In addition,
the Hammond Wastewater Treatment Plant is already exceeding its discharge
limitation for chloride. The highly salt contaminated discharge from Midco I
would cause an even greater exceedance. Discharge to the Hammond Wastewater
Treatment Plant may also be restricted by the U.S. EPA off-site policy, which
requires that facilities used for disposal of wastes in the CERdA program
must be in compliance with applicable Federal and State regulations.
C. Comments from the Midco Steering Committee and from Morton Thiokol, Inc.
COMMENT fl:
U.S. EPA did not select a cost-effective remedy for soils or ground water.
U.S. EPA RESPONSE TO COMMENT fl
See U.S. EPA's response to the following comments from the Midco Steering
Conmittee and the response to Comment 13 from the public meeting, etc.
COMMENT |2:
The assumptions used in the risk assessment are unrealistic.
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— -17-
U.S. EPA FESPCKSE TO COMMENT 42:
U.S. EPA required that the risk assessment include a scenario that assumed
that each site would be developed for residential or industrial use. This is
a standard procedure for CERCLA sites. The particular assumptions used in the
risk assessment had to be consistent with standard U.S. EPA risk assessment
practices as expressed in the Superfund Public Health Evaluation Manual
(SPHEM). Parameters and assumptions that were not spelled out in the SPHEM
were selected by Environmental Resources Management Inc. with review and
concurrence by U.S. EPA.
COMMENT |2A:
Ingestion rates and dermal contact rates for the contaminated soils were
unrealistic. In addition, it is unrealistic to assume that there would be no
degradation of contaminants over time.
U.S. EPA FESPCKSE TO COMMENT 2A:
U.S. EPA's current guidance for soil ingestion rates for use in CERCLA and
RCRA risk assessments is more stringent than that used in the FSs. To promote
consistency within the Agency, U.S. EPA has recommended soil ingestion rates
for use in risk assessments in a memo from J. Winston Porter dated January 7,
1989. These rates are 0.1 grams per day for adults and 0.2 grams per day for
children ages 1-6. These rates are based on the most recent reliable data
reviewed by the Agency, and represent reasonable conservative values. The
guidance does not address children who exhibit pica behavior because the
occurrence of pica behavior and the associated rates of soil ingestion have
not been adequately defined. The FS assumed that 1 gram per day would be
ingested by children ages 2-6, 0.1 gram per day for children ages 6-12 (only
for Midco I), and no ingestion after that age.
The estimated, lifetime cancer risk is proportional to the total lifetime
exposure. Using the assumptions in the Midco Feasibility Study (FS) the total
lifetime amount of soil ingestion is between 1,715 and 2,044 grams. Using the
new recommended rates, the lifetime soil ingestion is 2,774 grams. As can be
seen, the lifetime cancer risk estimate will be higher using the new rates
than the rates used in the FS. In addition, using the assumptions in the FS,
there would be no further exposure following the age of 12, but using the new
rates there would be continued exposure.
The risks from soil ingestion in the industrial development scenario are less
than in the residential development scenario, but are still substantial.
Some types of exposure that can occur after age 12 could also occur under the
industrial development scenario. Assuming 30 years of exposure at 0.1 gram
per day equals 1,095 grams in a lifetime using the industrial development
scenario. This is approximately 60% of the lifetime ingestion used for risk
calculations in the FS, and, therefore, the same percentage of the lifetime,
carcinogenic risk.
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_ -18-
The dermal contact rates used in the FS were proposed by Environmental
Resources Management. Personnel from U.S. EPA and PRC Environmental
Management, Inc. (PRC) reviewed the proposed rates and felt that they were
reasonable conservative assumptions.
Degradatiorv'reTnoval of contaminants does occur over tine due to volatilization
and biodegradation. However, the rate of these processes is generally very
slow for some of the chemicals of most concern, including polychlorinated
biphenyls, lead, arsenic, and polyaromatic hydrocarbons.
CCttlQfr |2B:
It is unrealistic to assume that residential development could occur at these
sites. In addition, Midco II is included in the City of Gary airport's
expansion plans.
U.S. EPA KESKNSE TO GCM1EOT I2B:
U.S. EPA disagrees with this assertion. While it is not possible to know
whether residential development will occur, it appears to be quite possible
since there are already residences located in industrial areas near these
sites. This includes a residence located 500 feet south of the Midco I site
on Elaine Street. It is across the street from Calumet Waste Systems and near
General Drainage. The residents at this location utilize the Calumet aquifer
for drinking and have a garden. Another property adjacent to General Drainage
is used for gardening by a Hammond resident.
There are a number of residences at the corner of Clark Road and Industrial
Highway, which is one mile southeast of Midco II. These residences are across
the street from House's Junk Yard, and adjacent to Samocki Brothers Trucking.
Two of the residences formerly used the.Calumet aquifer for drinking, and a
number of the residences have gardens.
The Gary City Airport is one of three sites being considered for the third
regional airport for the Chicago area. If the Gary Airport site is selected,
the Midco II property may be incorporated into the airport. However, this is
still very uncertain. Even if Midco II is incorporated into the Gary City
Airport, this may not eliminate the risks from contact with the contaminated
soils or ground water if no action is taken.
COfEOT I2C:
It is unrealistic to assume this ground water may be used for drinking (at an
ingestion rate of two liters per day), and for bathing because of the salt
contamination in the aquifer and difficulty in obtaining a permit for well
installation.
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— -19-
D.S. EPA RESPONSE TO GCMfENT |2C:
The most contaminated portions of the Calumet aquifer at each site is in the
shallow portion of the aquifer. In the shallow portion, chloride was
generally in the range of 1,000 mg/1 at each site. Water is drinkable with
this concentration of chloride, although it has an undesirable taste. Two
residences near the comer of Clark Road and. Industrial Highway formerly
utilized wells that only pumped from the shallow portion of the Calumet
aquifer. This is evidenced by statements by the residents that their wells
ran dry due to pumping at Samocki Brothers.
Ground water contaminated with 1,000 mg/1 chloride is camion in sanitary
landfill plumes. If a landfill site is on the National Priorities List and
the plume contains hazardous substances above cleanup action levels,
remediation of the plume is often required by U.S. EPA under CERCLA
irrespective of the presence of the chloride plume or the fact that the
hazardous waste contributors may not have been the primary cause of the
chloride contamination. Similarly, the hazardous substances from the Midco
sites must be remediated irrespective of the presence or the source of the
chloride contamination.
Besides the three residential wells previously mentioned, sixteen residential
drinking water wells were located in the City of Gary that are potentially
down gradient from Midco I. Since the State of Indiana had no record of these
wells, it appears that none of them had a permit.
For the industrial development scenario, the risk level would be similar to
that for residential development because the primary risk is due to ground
water ingestion. In an industrial situation, actual water consumption depends
on the level of activity and the work environment. For extreme cases,
consumption of as much as 19 liters of water per day can be normal. A
standard consumption figure of 2 liters/day is reasonable for both 1) total
daily consumption by the general population and 2) working day consumption by
a mix of workers.
CCM4EOT |2D:
The risk assessment should take into account the number of persons exposed and
the risk compared to other cancer agents.
U.S. EPA RESPONSE TO GCM4EOT 2D:
The SPHEM and Agency policy for risks assessments for CERCLA sites address
both future potential risk and present risk. As a result, under CERCLA, U.S.
EPA often bases its remedial actions more on potential for usage of an aquifer
or for future development of a site than on the present population affected.
At the Midco sites, U.S. EPA is taking into account that the Calumet aquifer
is little used and has other contaminant sources by only requiring clean up to
the 10~5 lifetime carcinogenic risk level rather than the 10"6 risk level that
is normally required in Region V. In addition, the potential for development
-------
_ -20-
)f Midoo II is considered to be lower than usual; thus the 10~5 risk level is
aeing used for the soil clean up.
Jnder CERCLA and RCRA, Congress has mandated that U.S. EPA address and
remediate risks from hazardous waste management and disposal. It is U.S.
IPA's responsibility to arVlrRss and remediate these risks irrespective of
jther risks that are present in every day life.
)irect soil treatment is unnecessary, and Alternatives 7 and 8 (which include
iirect soil treatment by solidification and soil vapor extraction as well as a
final site cover and ground water pumping) , do not provide any reduction in
.institutional controls or significant additional protection compared to
dternatives 4A and 4C (which only include ground water pumping and
.installation of a final site cover) .
f.S. EPA RESPONSE TO GChMD/T 13:
he Midco Steering Committee proposes that Alternatives 4A or 4C include a
dlty clay cover so that contaminants in the soils would be slowly leached
rrto the ground water and recovered in the ground water pump and treatment
ystem.
Iternatives 4A and 4C would leave a large reservoir of untreated hazardous
ubstances in the on-site soils. At Midco I, this includes an estimated
0,000 Ibs. of volatile organic compounds, 60,000 Ibs. of copper, 30,000 Ibs.
f zinc, 20,000 Ibs. of chromium, 10,000 Ibs. of lead, 10,000 Ibs. of phenol,
0,000 Ibs. of cyanide, 7,000 Ibs. of bis(2-ethyl-hexyl)phthalate) , 5,000 Ibs.
f polyaromatic hydrocarbons, and 100 Ibs. of polyaromatic hydrocarbons. At
idco II, this includes an estimated 100,000 Ibs. of copper, 70,000 Ibs. of
inc, 30,000 Ibs. of lead, 20,000 Ibs. of volatile organic compounds, 20,000
bs. of chromium, 8,000 Ibs. of arsenic, 1,000 Ibs. of cyanide, and 400 Ibs.
f polychlorinated biphenyls. These weights are calculated by multiplying the
rench average concentrations by the estimated pounds of soils to be treated,
ssuming that one cubic yard equals one ton.
his large reservoir of hazardous substances presents a future risk due to its
otential to continue contamination of the aquifer and due to potential for
irect ingestion and direct contact hazards. It appears very unlikely that
his large reservoir of contamination will be adequately removed using only
assive uncontrolled natural leaching even for a long period of time. It is
uite possible that, if the site cap is disturbed in the future, renewed
round water contamination would be caused even after many years of ground
ater pumping and attainment of ground water cleanup action levels. Leaving
he hazardous substance reservoir without treatment, would also require that
he ground water pumping system operate for a much longer period of time.
Ithough the predominant risk is due to ground water ingestion in the future
sage scenario, the risks due to direct soil ingestion are also likely to be
nacceptable in case of future development of the site, if the contaminated
-------
soils are not treated. A number of the chemicals of most concern for the soil
ingestion hazard are relatively immobile in soils. This includes arsenic,
polyaromatic hydrocarbons, polychlorinated biphenyls, bis(2-ethyl-
hexyl)phthalate, and lead. Even if these chemicals alone remained in the
contaminated soils at or near their present concentrations, the residual risks
due to soil ingestion would be unacceptable. At Midco I, the estimated
lifetime cancer risk would be 3 X 1
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— -22-
ternative 2 in the FS, way be required. If solidification is very
factive, a less ccrplex final site cover would be acceptable.
.S. EPA has a strong preference for permanent remedial actions, and believes
lat Incineration followed by solidification is more certain to provide
armanent treatment of the contaminated soils. Incineration would reliably,
nd permanently destroy the organic contaminants and would leave a residual
sh that could be more easily solidified because the organic compounds would
e removed. On the other hand, incineration is considerably more expensive
nd solidification combined with soil vapor extraction has the potential to
>rovide the same degree of protection. Therefore, at this time, U.S. EPA
^refers to implement the solidification alternative pending the results of the
:reatability tests.
XmEWr 15:
"Solidification of the Midco II soils might interfere with and preclude the
contemplated expansion of the City of Gary Airport."
U.S. EPA RESPONSE TO COMMENT 15:
Measures will be taken to make the remedial actions at Midco II compatible
with the Gary Airport expansion if this occurs.
COMMENT |6:
The harm caused by releases of the chlorides to the ground water is divisible
from any impact from the Midco sites and costs can be apportioned for the
chloride contamination.
U.S. EPA RESPONSE TO COMMENT #6:
While U.S. EPA does not agree with this statement, it is not relevant to the
selection of a remedy, but rather to the liability ramifications. U.S. EPA
noted that the Midco operations themselves likely contributed to the chloride
contamination. Available site records indicate that 39,010 gallons ferric and
ferric chloride wastes and 60,755 gallons of liquid waste containing 5% HC1
were taken to Midco I or Midco II. Other wastes taken to the sites, whose
records do not identify the waste type, may also have contained high
chlorides. Some of these wastes were likely spilled onto the ground or
dumped into pits into the aquifer in accordance with the disposal practices
for these sites. In addition, at Midco I, the swales in the northern half
of the site were filled with unknown materials during the Midco operations.
It is possible that this fill contributed to the chloride contamination at
Midco I.
Moreover, U.S. EPA does not agree with the suggested procedure for calculation
of the incremental remedial action costs attributable to the salt
contamination. The procedure proposed by the Midco Steering Committee assumes
that all costs of the deep well injection operation should be considered
incremental costs attributable to the salt contamination. This is not
-------
-, -23-
because the costs for treatment are substantially reduced when using
deep well injection alternative compared to the treatment costs for
charge to surface waters or to ground water (even without treatment of the
.t). In fact, deep well injection without treatment could be less expensive
m treating to surface water discharge standards or to drinking water
indards (even without treatment of the salt). For example, the estimated
aremental cost for treating the ground water to drinking water standards
:her than chlorides) at Midco I is $3,938,000 (present worth of alternative
.minus 4A plus $675,000 for the petition demonstration), while the costs
tributable to the deep well injection operation in Alternative 4A is
', 137,000. Similarly, at Midco II the estimated incremental cost of
eating to drinking water standards is $4,910,000, while the cost
tributable to the deep well injection operation in Alternative 4A
; $3,491,000.
: treatment to meet Land Disposal Restrictions is required prior to the deep
ill injection, then the cost of the deep well injection system would be
•creased considerably, but the degree of treatment required would still be
2ss than that required for reinjection into the Calumet aquifer or for
ischarge to the Grand Calumet River.
he primary objective of the remedial actions at the Midco I and Midco II
ites is to address the contamination by hazardous substances and not by
. Nevertheless, chlorides that are captured by the ground water
system must be disposed of properly. This is consistent with the
ipproach that U.S. EPA takes at other sites. For example, at landfill sites,
iolorides are often mixed with the hazardous waste plume. In spite of the
fact that the primary objective of remedial actions at these sites is to
address the hazardous substances and not the chloride plume, the chlorides
that are present in any ground water pumped from the ground must be properly
disposed of by the party conducting the remedial action at landfill sites.
aMfEOT 17:
The State of Indiana should issue a variance allowing the discharge of the
treated Midco I ground water to the Calumet aquifer:
U.S. EPA RESPCKSE TO GOWH-NT |7:
The State of Indiana does not have primacy for the underground injection
control program. Therefore, any underground injection must be approved by
U.S. EPA. The reinjection well would be considered class IV unless the waste
is delisted, since the ground water contains listed hazardous wastes. This
reinjection is not prohibited if it is conducted for cleanup of a release
under CERCXA or RCRA. CERCLA will allow this reinjection if the contaminated
ground water meets the cleanup action levels and does not allow significant
spreading of the salt plume.
clarification, there appears to be three ways to reinject without
spreading the salt plume. One would be to construct a slurry wall around the
site, pump and treat the ground water within the site, and reinject the
-------
— -24-
water within the slurry wall. Another alternative would be to pump and treat
the ground water for both hazardous substances and chlorides (such as by
evaporation) and reinject the treated ground water off-site (Alternative 4E).
The third is to punp ground water, treat it and reinject it near the site in a
manner that would not spread the salt plume.
OMENT 17:
The State of Indiana should issue a National Pollutant Discharge Elimination
System permit allowing the discharge of the salty ground water to the Grand
Calumet River following treatment of hazardous substances.
U.S. EPA RESPONSE TO CCMMENT |7:
Dames and Moore, who conducted the FS for the Midoo Steering Committee,
concluded that the State of Indiana would not allow a discharge to the Grand
Calumet River without reducing chloride levels. However, in order to respond
to the comment fron the Midoo Steering Committee, U.S. EPA has contacted IDEM
and conducted some additional internal discussions. Personnel with the IDEM
water compliance section stated verbally that a preliminary review of data
from the Grand Calumet River indicated that no excess capacity exists in the
chloride allocations for the Grand Calumet River, and that preliminarily, it
did not appear that the State would allow a discharge with a chloride
concentration higher than 500 mg/1 for the Midoo sites. U.S. EPA followed up
these conversations with a letter requesting a formal determination on this
matter.
Cleanup action levels should be periodically revised.
U.S. EPA RESPONSE TO GCMMENr 18:
This is provided for in the RODs.
OM4ENT |9:
Only one deep well should be installed to serve both of the Midco sites.
U.S. EPA RESPONSE TO GCM4EMT 19:
This is allowed for in the PDDs. However, it is not clear why the Steering
Ccranittee feels the shared well should be located at Midco I, since Midco II
will have a higher flow rate and has a larger area.
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— "25~
CCMfEUT 110
"The U.S. EPA and the State should seriously consider prohibiting use of the
Qdumet aquifer as a source of drinking water due to the salinity issue."
U.S. EPA RESPCN5E TO GCMfOfT flO
The results of the Midco Remedial Investigations indicated that the salt
contamination had only affected limited portions of the Calumet aquifer.
Although the Calumet aquifer is susceptible to contamination by surface
sources, it is the intent of RCRA and CERCLA to control or remediate these
potential contaminant sources so that aquifers like the Calumet aquifer can be
safely used.
-------
A GUIDE
to the
FEDERAL
UNDERGROUND INJECTION
CONTROL PROGRAM
in
INDIANA
Prepared byt
SMC Martin Inc.
900 West Valley Forge Road
p. 0. Box 859
Valley Forge, PA 19482
Under Contract No. 68-01-6;
to the
U. S. Environmental
Protection Agency
Region V
230 S. Dearborn Street
Chicago, IL 60604
-------
About the Guide
This guide is intended to familiar-
ize the public with the regulations for
the Underground Injection Control (UIC)
Program. Technical criteria for the
program were published in the Federal
Register June 24, 1980 and codified as
part 146 of Title 40, Code of Federal
Regulations. Procedural requirements,
atate approval process, and the permit
issuing process were promulgated on
May 19, 1980 as part of the Consolidated
Permit Regulations as revisions to
40 CFR, Parts 122, 123 and 124. The
Part 122 and 123 Regulations were deconsol-
Idated as technical amendments on April 1,
1983 (48 Fed. Reg. 14145) and now appear
as Parts 144 and 145 of 40 CFR.
Subsequent to the promulgation of
these regulations, the Safe Drinking
Water Act was amended. Among other
changes, the amendments added a new
Section 1425 to the Act. Section 1425
establised an alternative method for a
atate to obtain primary enforcement
responsibility for those portions of its
UIC program related to the recovery and
production of oil and gas. The May 19,
1981 Federal Register (Vol. 46, No. 96,
p. 27333) contains Section 1425 guidelines.
Also, the Environmental Protection
Agency amended the regulations listed
above on August 27, 1981 and February 3,
1982. These amendments were promulgated
as part of a legal settlement reached
with a number of companies, trade associ-
ations, and the State of Texas.
-------
AQUAO
elsH
I. THE UIC PROGRAM IN PERSPesHVR
National Concern for Ground Hater
Congress Acts
Background of the Regulations
II. MAJOR CONCEPTS OF THE UNDERGROUND
INJECTION CONTROL PROGRAM
Potential Pathways of Contamination
1. Faulty Nell Construction
2. Nearby Wells
3. Faulty or Fractured
Confining Strata
4. Direct Injection
5. Lateral Displacement
Requirements for Injection Well Clas
Class I Class IV
Class II Class V
Class III
III. PERMITS AND RULES - TOOLS FOR RBGULATI
Who Must Obtain a Permit
Who May Be Authorised by Rule
Basic Permit Requirements
How to Obtain a Permit
IV. STATE INVOLVEMENT IN UNDERGROUND
INJECTION CONTROL
Indiana's Authority to Regulate
Injection Wells
V. EPA'S UIC PROGRAM FOR INDIANA
MATRIX OP STATE REGULATORY AUTHORITY
APPENDIX A - LIST OF CONTACTS RE-
GARDING UNDERGROUND INJECTION IN
THE STATE OF INDIANA
-------
I. THE UIC PROGRAM IN PERSPECTIVE
National Concern for Ground Water
Moat areas of the United State* a
underlain by geological formations or
strata that are capable of yielding
usable quantities of water. Such geo-
logical formations are called aquifers
People have long relied on aquife
as the source of high-quality water.
Today, about half of the American popu
tion uses ground water for its domesti*
needs.
In the arid areas of the countryt
aquifers are often the only source of
water available. And with Increased
usage of water by Industry, homes, and
municipalities, national reliance on
ground water is expected to increase.
Ground water is also a vital link
in the water cycle. Aquifers are re-
plenished by rainfall or other surface
water percolating through the soil. Ii
turn, ground water supplies the base
Clow of many streams and feeds lakes
through underground springs.
Recent years have seen a growing
concern for the quality of ground wate
Pollutants in surface waters or substa*
deposited on the soil (e.g., pestlcldei
and fertilizers) may be carried into
aquifers in the replenishment process.
The land disposal of wastes (e.g., intt
-------
injection wells, landfills, and surface
impoundments) can also cause contami-
nants to enter ground water.
Injection wells can be either bene-
fioial or a major problem in this regard.
It is estimated that perhaps as many as
500,000 injection wells are in operation
nationwide* '.These wells involve a broad
variety of practices from beneficial
purposes (a.g*, aquifer recharge and the
product loin 'of oil, gas and minerals), to
tha) improper disposal of toxic and
wastes.
contamination of ground water
is a matter of grave concern. Ground
'totter in usually assumed to be of high
quality .and la often used with little or
no treatment. Contamination is usually
discovered When the consumer becomes ill
and i; In many oases, the only practical
solution^ 14 to search for another source
of -fresh, water* Because of the slow
movement of ground water, it may be
decades b* even centuries before the
aquifer is once more usable. In some
cases, the contamination can never be
reversed, and the resource may be lost
forever.'. Finally, the effort to clean
up the nation's surface waters is ham-
pered if the base flow of streams is
alreadyvtdOptaminated.
Congress Acts l
•t
-'Congress recognized these potential
threats to ground water when, in the
Safe Drinking Hater Act of 1974
(P.L. 93-523), it instructed^Ke Environ-
mental Protection Agency (EPA) to estab-
lish a national program to prevent
underground injections which endanger
drinking water sources. More specific-
ally, the Safe Drinking Water Act (SDWA)
requires EPA tot
o Publish minimum national require-
ments for effective State Under-
ground Injection Control (UIC)
programs.
o List states that need DIG programs* -
o Make grants to states for developing
and implementing UIC programs.
o Review proposed state progr
approve or disapprove them.
and
o Promulgate and enforce OIC programs
in listed states if the state
chooses not to participate or does
not develop and operate an approvabl
program.
Several points are worth noting
about the statutory mandate. First, the
SDWA was Intended to head off what
Congress perceived aa an emerging problem
The committee report accompanying the
Act (H. Kept. 93-1185, p. 32) makes
clear that no burden la laid on BPA or
the state to prove actual contamination
before establishing regulations or
enforcing them. Second, UIC is clearly
to remain a state program. States are
expected to assume primary responsibility
for fashioning and operating effective
-------
programs in their states. The EPA is
required to step in only if a state
chooses not to participate in the program
or fails to administer its program
effectively. 1PA also has direct respons-
ibility on Indian lands. Third, Congress
enjoined EPA to observe three provisions
in establishing regulations. The
regulations i
• . •/••'.
; o Are not to interfere with or impede
' ioil end gas production unless
' necessary to protect underground
source* pf . drinking water .
ATS not to disrupt effective exist-
***** yrograjw unnecessarily.
W
to take local variations in
"Vt7.- ^geology, hydrology and history into
•;•.'»:;.. $ account •'.::.
-.i.'.-i t..",': .-.••r"'' '
>aqkoTQund:of the Regulations
•' • • !'• '
"';•" HFA originally proposed regulations
to implement Part C of the Safe Drinking
.Hater Act (8DMA) on August 31, 1976.
That proposal included the program
regulations and the technical criteria
•and standards for the UIC program.
(Numerous written comments Were filed and
: many parsons-commented at three public
hearings*. .
, > . After careful review of those
public comments, BPA determined that
there were many ways that the initial
proposal could be made generally more
flexible and less burdensome without
sacrificing the resulting environmental
protection to any significant degree.
Further, in the fall of 1978, the Agency
decided to consolidate the regulations
for its major permit programs.
As a consequence of these decisions*
the UIC program regulations were repro-
posed on April 20 and June 14, 1979.
After five public hearings and
review of public comments the Agency
promulgated final Consolidated Permits
Regulations on May 19, 1980 and Technical
Criteria for state QIC programs, on
June 24, 1980.
A number of trade associations,
mining companies, oil and gas producers*
iron and steel producers, and the State
of Texas petitioned for review of these
regulations. In all a list of 93 Issues
was filed by the petitioners with the
Court of Appeals for the District of
Columbia Circuit. In response to the
legal challenge, the Agency proposed
amendments to the regulations on October J
1982 and promulgated final amendments to
its Consolidated Permit Regulations and
Technical Criteria and Standards for
state UIC programs on August 27, 1981
and February 3f 1982. However, on April J
1983, the UIC regulations were deconsoli-
dated from BPA's other permitting programt
Thus, public comments, further
study, amended legislation and internal
management improvements are the principal
foundations of the UIC program.
-------
II. MAJOR CONCEPTS OP TUB UNDERGROUND
INJECTION CONTROL PROGRAM
Congress intended the UIC program
to protect not only the ground water
which already serves a source of drinking
water but also the ground water that
could potentially serve as an underground
source of drinking water (USDW). The
regulations propose* therefore, that all
aquifers or portions of aquifers currently
serving as drinking water sources be
designated for protection. Furthermore,
any other aquifer or portion of it which
is capable of yielding water containing
10,000 or fewer milligrams per liter of
total dissolved solids should also be
designated.
However, not all underground water
sources are suitable for providing
drinking water. Some aquifers are used
for producing minerals, oil and gas, or
geothermal energy. Others are so contami*
nated or located in such a manner that
recovery of water for drinking purposes
is neither economically practical nor
technologically feasible. An exempted
aquifer is an aquifer or portion which
would normally qualify as a USDW but
which for any of several specified
reasons has no actual potential for
providing drinking water and has been
affirmatively identified by EPA as an
exempted aquifer. If EPA exempts an
aquifer or portion of an aquifer, it is
not treated as a USDW subject to the
protections of these regulations.
-------
Aqutfar - Aay gaologlc formation which la capabla of
ding oaablo qaantitiaa of ground watar.
• * borad, drlllad, or drivan ahaft, or dug hola,
la groatar thaa tha largaat aurfaoo dloanaion.
.^jpfcoi^mi^ •MUo^Bi of "ttUB lnto th-
•oil
Mil.
.•MM.
*••'
Mda and dollar Mtoriala uaad In
knoUM) .Utfooa* • bond, drlllad. drlvaa or dug
» MkMtUl* Of MbatMOO* «hioh flow or mot*,
i»«i ii>ll4« iif«ii, cladf*. or »v otter ton or
Mr«l •»«nd«r4 for tn)«ctlo«
In tbo iMll'a o««i»f, tubln* or y*ok«ri and |]| 019-
ftifi«*M ••»••§•* flt Civito k«M«on tho o«t«roaot
*• Uroa af MviX » tb« •••« •• ttw «ir<*oo Mtrounding ••
- UlWtXoa woll witbU whtok all voll* that oanotrata tba
iiqoatipA wont aMt bo r«vlo»*d and. if nooaaaary. repair ad.
It M» ko dofi»«d to Mraa of a tl*ad radio* of not laaa
thaa 1/4 lUlo fcoa UM iajootton Mil. altaroati*«Iy, tha
araa of kowioJr mmy ba «OB»ato« by tha uaa of a oathawitlcal
forawla «*Uk aca4iot« tho lataral dlauutoo ovar which tho
Immojiaiil ocaaaora fanaratod by tho la]action oay oatiaa
tba upvfkH •ifratioa of flaide froa> tho injaction aona
throa^i fMltt, Uvroparly ibandooad walla, or iapropacly
OOBflOMl fH4MiPf Ml U.
, ' • .* *• ' • -
^Qtantiai Pathuay* of Contamination
- '-.'•*'
.' Tht batio oonocjpt of the proposed
DIG program ia to prevent the contamina-
tion of underground sources of drinking
water by keeping injected fluids within
the well and in the intended injection
/•one* There are five major ways in
which 'injection practices can cause
fluids to migrate into underground
drinking water sources. The following
discussion describes each pathway and
summarlxes the technical requirements
proposed in the regulations to prevent
migration through that pathway.
Leaks through the well casing or
fluid forced back up between the well's
outer casing and the well bore, as
illustrated in Figure i, may cause
contaminant migration into a U8DW.
Preventive Requirements
The regulations require adequate
casing to protect drinking water sources*
and adequate cementing to isolate the
injection xone. Mechanical integrity*
defined as the absence of significant
leaks and fluid movement in the well
bore, must be demonstrated initially and
every five years thereafter.
I. fMIUl MU. OOMnuCtlM
-------
2. Nearby Walla
Fluids from the pressurized area in
the injection tone may be forced upward
through nearby wells into underground
sources of drinking water, as illustrated
in Figure 2.
it *
' Preventive Requirements
r,.,*.. , ^-
Wells that penetrate the injection
•Oil* in the area of review must be
reviewed to assure that they are properly
^oomplatsd or plugged. Corrective action
'must be taken if they are not completed
or plugged to prevent fluid migration.
He*ly abandoned wells must be plugged to
>«onforn with BPA procedures.
I UKUJ
10
Faulty or Fractured
3.
Fluids may be forced upward out c
the pressurized area through faults ot
fractures in the confining beds* as
illustrated in Figure 3.
Preventive Requirements
Wells must generally be sited so
that they inject below a confining bet
that is free of known open faults or
fractures. Injection pressure must br
controlled so that fractures are not
enlarged in the injection sons or orer
in the confining bed.
riOUM >. fAULTV OS
11
-------
4. Piroot Injection
Wells may be designed to inject in-
to or above underground sources of drink-
luff water* as illustrated in Figure 4.
>: Freyentlre Requirement
.... '", ' i •• •*
;,'.';. Nells Injecting hazardous waste
Vmaterials br radioactive waste Into
•'Underground sources of drinking water
J are 11legal4 However, wells Injecting
t htttardoUs Wastes or radioactive wastes
'.into exempted aquifers will not be
U»fcnn«a< -Well* that Inject nonhazardoua
^material will be regulated In the future
*ba*ed on recommendation* to be formulated
,by the states. ...
4. MMCT INJECTION
12
5. Lateral Displacement
Fluid may be displaced from the
injection zone into hydraulically con-
nected underground sources of drinking
water, as illustrated In Figure 5.
Preventive Requirement
The proximity of injection wells to
underground sources of drinking water
will be considered in future siting of •
such wells. Hell operators will be
required to control injection pressure -.,
and conduct other monitoring activities
to prevent the lateral migration of
fluids Illustrated In Figure 5.
flfiUM I. lATUU,
13
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Requirements for Injection Wei 1 Classes
To Implement its proposed technolog-
ical controls, BPA categorized well
injection activities into five classes
defined in Figure 6. Each class Includes
wells with similar functions and construc-
tion and operating features so that
technical requirements can be applied
consistently to the class. A brief
summary of the general underground
injection controls proposed for each
.Glass are highlighted in Figure 7.
*H»-
£liM_t MIU «r»
fcMMfcit Md •tB
M«d to UJ«ct IntiM
•*•!•• bMMCtJl ClM 4«>(W*t
«rlaklaf
ClMi tl Mil* •*• OM« to dl*fOM of fluid* xbioh «r«
Couplet* UM MrCao* In eowMOtlo* vitii oil and «••
COdMtiMif »• Uj«ot ClaUa (or UM •nhaao^ tooovvry
•H. or «JM, •*• to «toM li««id hrdrooacbou.
• £
I MlU
•(
thoM M«d to Uj*et Iluida (or th*
Ci«M VI w»\l» M« tho«« (or which hastrtou* n*«t« or
r*dtoAoti«> «••!• »r« Uij*ot«d into or above strata
that o«ntAi« unterartmad drinking iMtar •oaro«« and
t tint I Milt «hioh ia}«ot ha«arao••
•MC«««lf
»I
Claae I
Class I wells are likely to inject
potentially dangerous fluids, and will,
therefore, have to meet strict construe-^
tlon and operating requirements.
Class I wells must Inject Into
strata that are below the deepest under-
ground source of drinking water and must
have an adequate confining layer above
the Injection rone. Ml Class I wells
must be cased and cemented to prevent
fluid migration and must Inject through
tubing with a suitable packer set Imme-
diately above the Injection tone (or an
equivalent alternative).
Mechanical integrity must be demon-
strated upon completion of the well and
every five years thereafter, and correc-
tive action must be taken on improperly
plugged or completed wells within the
area of review.
15
-------
to monitor continuously the volume of
disposal wastes, and well annular pres-
sures* Class I operators must also test
the composition of Injected fluids
periodically and provide the permitting
authority 'with quarterly operating
• report* * |;<|-\ .
'
BUtteftn Class I wells are known to
in Indiana.
'
Requirements for Class II wells
'(those injection wells associated with
rOll and gas production) have been fash-
V lotted in light of the congressional
•mandate that the OIC regulations are not
.to Interfere with or Impede oil and gas
production unless necessary to protect
underground drinking water sources.
'* • • ' f '
••"'.: These regulations attempt to balance
meaturea necessary for the protection of
the environment against burdens imposed
on the regulated community.
'- *« • ._ • . ' . .
'-•-•' Class II injection wells are to
have casing and cementing adequate to
,protect underground sources of drinking
water* All Class II wells will also
.have to demonstrate mechanical Integrity
initially and every five years thereafter,
'However, only the applicants for new
Class IX permits must review nearby
wells in the area of review and take
corrective action on those Improperly
completed or plugged wells.
16
ar«t
subject to limitations on the pressure
and rate of injection. They must also
monitor the injection pressure and
volume, and the quality of the Injection
fluids at Intervals depending on the
type of operation. Annual reports to
the permitting authority are required.
Two thousand, three hundred and
sixty Class II wells are known to exltt
in Indiana.
Class III
Construction, monitoring, and
reporting requirements for these wells
will resemble those for Class I wells.
Class III wells must be cased and ce-
mented to prevent fluid migration. All
Class III wells must comply with area of
review requirements and demonstrate
mechanical integrity. Class III wells
will have the same monitoring require-
ments as Class I wells, except that more
frequent monitoring will be required of
drinking water supply wells adjacent to
the Injection sites.
No Class III wells are known to
exist in Indiana.
Class IV
Existing Class IV wells used by
generators of hazardous waste and radio-
active waste and operators of hazardous
waste management facilities which Inject
directly into an underground source of
17
-------
arinxing water will be closed as soon as
«asible, but in no event later than six I
nth* from the effective date of the
program. No new Class IV wells which
inject directly into or above an under-
ground source of drinking water will be
.authorised or permitted. EPA considers
these Welle" to be a eignificant danger
- to underground drinking water sources.
However* Class IV wells injecting into
;>. exempted aquifers will not be banned.
BPA requirements for Class IV wells
Vv' which inject above underground sources
v;;of drinking water have not been
V established.
v- v ••-.-• • . ••
j/>•'••, Operators of Class IV wells will be
ir; required to monitor injected fluid
v' characteristics and volumes, as required
for hasardoua waste* under the Resource
Conservation And Recovery Act. Weekly
monitoring of the impact of injections
on drinking water supply wells will also
be necessary. Class IV well operators
must submit quarterly reports of operating
; results and immediate reports of changes
' in the characteristics of water supply
wells in the vicinity of Class IV wells.
;
HO Clsss IV wells are known to
exist in Indiana*
Class V
V'-rti.
At present BPA has too little
information on the extent, operation,
and Impact of Class V wells to propose a
suitable regulatory approach. The
regulations, therefore, require an
18
regulations*, therefore, require an
inventory and an assessment j^ftsuch
wells in each state. Specific regula-
tory requirements will be fashioned
after the completion of the assessments.
EPA will take immediate action on
any Class V well that poses a signifi-
cant risk to human health.
Between sixty and one hundred and
fifty Class V wells are known to exist
in Indiana.
19
-------
III. PERMITS AND RULES - TOOLS
FOR REGULATION
Under the Act, EPA has the dlscretlo
to specify whether the minimum national
requirements are to be applied through
rules or permits. A rule is a law,
ordinance or regulation that sets forth
the standards and conditions under which
an activity may be conducted. A permit
is a specific authorisation to an Individ
ual to carry on an activity under the
conditions and limitations specified in
the permit.
Each method of control is appropri-
ate in certain situations. Although the
requirements imposed are equally enforce-
able under either method, permits are
generally considered to make possible a •
greater degree of control. On the other
hand, permits need more time and resource
since they requires (1) the individual
to file an application containing inform*
tlon about his proposed activity! (2) the
effective participation of the public in
the review processi and (3) BPA personnel
to review, write and process each permit.
Who Must Obtain a Permit
Owners/operators of Class I, Class I
(except existing enhanced recovery and
existing liquid hydrocarbon storage),
and Class III wells must obtain a permit
to inject. New wells (those that begin
to inject after the effective date of a
program in a state) must be authorised
21
-------
t^^^-w t~^~^~ ^...JWW^^-W.. MMJf »^
existing wells, the permitting
lorlty (BPA) will develop a schedule
not to exceed five years, based on
appropriate priorities, for issuing or
reissuing the permits. Until the applica-
tion of the owner/operator of an existing
well has been processed, the injection
may be authorized by rule.
A permit may be sought either for
an individual well or for a group of
.wells in an area. An area permit may be
; issu.ed for a group of wells if they aret
.* » *
;''•'.' o Osed to Inject other than
, ,, ,•«•-. < hazardous waste.
.
••.O;,. Under the control of a single
-------
the life of the well. However, each
Class IX and Claaa III permit will be
reviewed at leaat once every five years.
Duration of Class IV permits have not
yet been established.
'. •* :'"••
. v '"• ''j Bach permit must be enforceable In
the jurisdiction in which it is issued.
.It must specify construction, abandonment,
operating* monitoring and reporting
requirements appropriate to the well
class* ; In addition, permits Must incor-
KfateMfcppfoprlate compliance schedules
any Corrective action Is to be taken
by the* >ell owner/operator. Finally,
permits oust authorise the right of the
permitting authority to have access to
tha well and the related records to
•••ttrsj-tfttoipUanoe with permit terms.
tQ t«in V permit
.
' V 'v Applications for new Injection
well* should be filed with EPA in time
to ftllo* for the review and issuance of
the permit prior to construction .
Applications for existing wells will be
filed according to the schedule estab-
lished in each state, but in no case
later than four years after the effective
date of the program.
010 permits for Indiana will be
issued Dy BPA Region V headguarters in
Chicago (see Appendix A). Permit applica-
tions sjust be signed by a policy level
of fleer-of the) company except in the
24
case of Class II wells where applications
may be made by individuals authorized by
their companies in writing to do so.
Applications must contain a statement
that the signing official has satisfied
himself that the information provided is
correct. •
The information that mutt be avail-
able to BPA is specified for each well
class in CPR Part 146. Generally, such
information should include the surface
and subterranean features of the Injec-
tion area, the location of underground
sources of drinking water in the vicinity
the results of tests in the proposed
injection formation, construction feature
of the well, and the nature of the
proposed injection operation* Contact
with EPA should be made early in the
project to obtain the necessary, forms *'
and information. BPA can also provide
guidance on appropriate sources of
information necessary to complete the
application.
The review of a permit application
begins with the receipt of a complete
application by BPA. The BPA considers
the application, gathers such additional
information as it needs, and prepares a
draft permit. The draft permit must be
presented for public comment for at
least 30 days with a fact sheet that
provides enough information that the
public can make informed judgments about
the proposed action. If there is suffi-
cient interest, a public hearing will be
held and announced at least 30 days in
advance.
25
-------
Public comments must be taken into
account in preparing the final permit,
and the EPA will prepare a summary of
the comment* and its responses to them.
A final permit is then prepared and
issued. Figure 8 presents a schematic
summary of the process.
First, SPA will also prepare an
administrative record that documents its
decision making for both the draft and
final permit. Second, if sufficient
,intermit is expressed, EPA may, after a
public hearing* hold a further hearing
with an opportunity for cross exaraina-
tiom Third, if sufficient new informa-
tion becomes available during the public
comment period, BPA may prepare a revised
draft permit and solicit further public
comment. A final BPA permit does not
become effective for 30 days after it is
issued. During that time, a permit may
be appealed. Appeals will be considered
in an established BPA process.
. „>:...
26
noun •
mi IK iraut MOCMS
Act lo«
M««U«il
Aatio* by i
MBit
feral*
••It Operator
to*l«* M« teal* M
•M
Of«ft
fact MM*>
MA
«lT« Vvbltc •>»!«•
of
••Of**
CaaMnt
Mrlod
o< •••rlnf*. Bel*
kr*
m
•oli €(«••-••••
tato M awMl
27
-------
IV. STATE INVOLVEMENT IN UNDERGROONC
INJECTION CONTROL
The Safe Drinking Hater Act clear1
Intends the states to have the primary
responsibility (primacy) for developing
and implementing UIC programs* In
fashioning these regulations, IPA has
attempted to encourage states to assume
primary responsibility (primacy).
Primacy states must have the autlu.
ity to regulate injection wells at
Federal facilities within the state.
injection on Indian lands, however, wll
remain a Federal responsibility if the
state does not have adequate authority.
The State of Indiana has not sub-
mitted an approvable UIC program to BW
Therefore, the Safe Drinking Hater Act
mandates EPA to establish and run a DIG
program in Indiana. The Indiana Strear
pollution Control Board, in conjunction
with the Indiana State Board of Health
and the Department of Natural Resources
through state law, conduct regulatory
programs similar to the EPA UIC prograr
The Indiana Stream Pollution Control
Board regulates all discharges to group
water (except those related to oil and
gas production) by the issuance of
construction, operation and discharge
permits. The discharge permitting
program is administered by the Indiana
State Board of Health through the divi-
sions of Water Pollution Control, Land
Pollution Control, Sanitary Engineering
29
-------
and the Public Water Supply Section.
All injection, disposal and enhanced
recovery wella associated with oil and
gas production are regulated by the
Indiana Department of Natural Resources
which requires all drillers to be licensed.
Injection well operators must currently
oonply with both state and BPA requirements
although Indiana has the option of
pursuing primacy for DIG at any time in
the future*
30
V. EPA'a UIC PROGRAM FOR INDIANA
All owners and operators in the
State of Indiana are required to comply
with the UIC regulations listed In
40 CFR Parts 124, 144 and 146 In addition
to the Part 147 regulations that pertain
to the particular combination of histori-
cal practices and geology unique to
Indiana.
Maximum injection pressure for the
State of Indiana for well* authorised by
rule is calculated by the use of a
simple formula, based on a fracture
gradient measured in psl/ft., to assure)
that operations do not initiate or
propogate fractures in the injection
zone. A fracture gradient of 0.8 pal/ft•
will be used for Indiana. Owners or
operators may apply for and receive
permission to operate at greater pressures
by applying for a permit and demonstrating
that they will not endanger a 08DM.
Due to the large number of wells
involved, the area of review for Class II
wells will be based on a fixed radius in
order to avoid considerable delay in
program implementation caused by processing
requests based on many formulae.
All Class I through Class V wells,
with the exception of Class II wells,
associated with oil and gas production,
are currently regulated by the Indiana
State Board of Health in conjunction
with the Indiana Stream Pollution Control
31
-------
Board (8PCB). Class II walls associated
with oil and gas production are regulated
by the Department of Natural Rsources.
In addition, with promulgation of the
federal progran, all injection wells
must ooftply with the Federal UIC
regulations* ,
32
MATRIX OF MCNANA STATE AGENCY AUTHORITY
flTAII
•TMM.1M
M1IMM.il
•TOMAOt
•ALTWA1W
in
FT wax*
MVMU4
•M.TWA1M
NAWMOTM WAtTI
•01HMUM.
X
X
X
X
X
N
X
N
Y
Y
Y
Y
Y
Y
Y
Y
X
X
X
X
X
x =
N =
Y =
TO I
mnari
33
-------
APPENDIX A
LIST OF CONTACTS REGARDING UNDERGROUND
INJECTION IN INDIANA BY WELL CLASS
EPA Region V
Ground Water Protection Branch (8WD-12)
230 South Dearborn
Chicago, IL 60604
Nark Vendi (312) 886-6195
Class I:
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
Class lit
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
35
-------
Class II: Associated with oil and gas
production.
Indiana Department of Natural
Resources
911 State Office Building
Indianapolis, IN 46204
Homer Brown (317) 232-4055
Class III:
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
Class IV:
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
! 1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
36
Class V:
Indiana Stream Pollution Control
Board
1330 West Michigan Street
Indianapolis, IN 46206
Virgil Bradford (317) 633-0700
Indiana State Board of Health
1330 West Michigan Street
Water Pollution Control Division
Indianapolis, IN 46206
Larry Kane (317) 633-0761
37
-------
ATTACHMENT E
Extraction Protocol
Waste Treatment Results for Inorganics
This attachment tabulates the data used to develop the conclusions in the
report for chemical extraction and soil washing and immobilization of
inorganics. The influent and effluent extraction protocol concentrations
in the wastes are reported, as well as the corresponding reductions in
mobility. The data are sorted by treatability group, technology group, ar
contami nan:. Not all treatability groups have data for all technology
groups.
-------
Trentability O
Proc**a Group:
III! I ll»lll >.«' I «•'!
• 10 MON-VOI.ATII.r MF.TALS
CHP.HICAL EXTRACTION AND SOU. HASHING
Ml It
i I.». I
link
1
2
3
4
5
t
7
•
9
10
11
12
13
14
19
14
17
1*
19
20
21
22
23
24
25
24
27
28
29
30
31
32
33
94
Nobility Influent Qul Effluent Oul Sr
Reductlon Concen. (PrtO tmt Concen (PPM) F.ff Process D».*r r Ipl Inn Cr>nt Ami HAM! NAIK* M«r1ia !•
0.9899312
0.9878474
0.9857497
0.90)44)1
0.9927757
0.9811757
0.9430597
0.9404477
0.9550500
O. 9541045
0.9442857
0.9434200
Q. 9382114
O. 9344200
0.9280000
0.9245714
O. 9208178
0.9108571
0.9059701
O. 90 14400
0 . 9000000
0.8874400
0. 887(400
0.8518500
0.9510500
O.*333000
0.1333000
O. 8333000
0.1333000
0.7777*00
0.7250OOO
0.7049200
0.7000000
0.4250000
159.90000
159.90000
•0.70000
•O. 70000
•0.7OOOO
159.90000
24.80000
24.80000
0.99000
24.00000
17.50000
0.09000
159.90000
O. 4 1000
1 7 . 50000
17.50000
90.70000
17.50000
24.00000
0.61000
0.40000
0.09000
0.09000
0.27000
0.27000
0.0(000
0.04000
0.0600O
0.0(000
0.27000
0.40000
0.41000
0.40000
0.40000
1.41000
1 .94000
1.15000
1 . 92000
1 . 9900O
3.01000
0.99000
1 .06000
0.04000
1 . 2 3000
0.94000
0.05000
. 9.00000
O. 04000
1.26000
1.32000
6. 39000
1.56000
2.52000
O.060OO
0.04000
0.10000
O.IOOOO
0.04000
O. 04000
0.01000
O. 01000
O.OIOOO
0.01000
0.06000
0. 11000
O.IROOO
0.12000
O . 1 SOOO
SOIL MASHING
SOIL MASHING
SOU. MASHING
SOU. MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOIL MASHING
SOU. MASHING
SOU. MASHING
COPPF.R
r*t\n offi
• i II 1 tMI
COPPF.W
ft ii> it c* ti
l.i n 1 r.M
t'l it* t» aTD
I HI r F.H
f "O|*PKR
u • I*M 0r •
HI* rCI.
M 1 f~H f"l
n 1 1.. 9A r< 1 *
C*(1PP0TD
' \ Iw 9 r.tf
NICKEL
NICKEL
COPPER
COPI-r.R
f •f\ft|>frn
* 1 >l V ff\ffv
NICKF.I.
NICKF.I.
COPPER
NICKF.I.
NICKF.I.
COPPER
NICKF.I.
COPPF.R
COPPF.R
NICKF.I.
NICKEL
CHROMIUM
CHROMIUM
CIIPOMIHH
CHROMIUM
NICKEL
NICKF.I.
COPPF.R
NICKEL
NICKF.I.
sou. a
sou. a
SOIL a
SOIL a
sou. a
SOIL a
SOIL a
sou. a
sou. a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
SOIL a
sou. a
sou. a
SOU. R
sou. a
sou. a
SOIL a
sou. a
SOIL a
sou. a
sou. a
sou. a
roii. R
Soil. H
* Test
Imrtimnnt Number Hum
ORD-TSI-RT-EUQM-
ORn-TSI-RT-EUQW-
OPn-TSl-RT-EUON-
OPO-TSI-RT-EUQW-
ORP-TSI-RT-EUON-
OPD-TSI-RT-EUOM-
ORO-TSI -RT-EUQM-
ORO-TSI-RT-EUQM-
ORO-TSI-RT-EIIOM-
OPO-TSI -RT-EIIQH-
ORn-TSI-RT-EUOM-
OPD-TSI-RT-EUQW-
ORO-TS1-RT-EUQM-
ORO-TSI-RT-EUOM-
OPO-TSI -RT-EUQH-
ORO-TSI-RT-EUQM-
OPD-TSI-RT-EUON-
ORO-TSI-RT-EIIGM-
ORD-TSI-RT-EUOW-
ORO-TSI-RT-EUQM-
OPD-TSI-RT-EUQN-
ORn-TSI-RT-EUQM-
ORII-TSI-RT-EUOM-
ORO-TSI-RT-EUOM-
OPO-TSI-RT-EUQH-
ORn-TSI-RT-EUQM-
ORD-TSI-RT-EUO"-
ORIl-TSl-DT-EUON-
ORU-TSI-RT-EUON-
ORO-TS1-BT-EUO"-
ORU-TSI-RT-EIIOM-
ORO-TSl-RT-EUO*-
ORD-TSI-RT-EUOW-
OHO-TSI -RT-F.HO**-
52
58
40
14
41
46
52
58
16
46
41
28
5)
4
)4
40
)5
35
53
10
22
22
2)
4
10
46
52
5)
50
II
2)
II
20
16
SOIL - 34 data point*
SI.IJDGE (s 1.1 if11 -
* point 9
-------
roi | ml i v | itnn I Ti
I nil in-ill F.xl|4'-l
. I . . ( i •• <
F.HIii'Mit
Treat ability Croup: HID
Proceaa Croup:
NON-VOLATILE HF.TAI.S
IMMOBILIZATION
Ink
1
2
3
1
1
2
3
4
1
2
3
4
5
t
7
•
9'
10
11
12
13
14
1
2
Nobility
Deduct Ion
0.4400000
0.2500000
0.2000000
O.OTOOOOO
SOIL -
0.901(400
0.05*3400
O. 8518500
0.3000000
SOIL -
0.9998850
0.9998850
O. 9998(04
0.9990909
0.99X3(3
0.99*5074
0.99102(3
O. 98955(0
0.9800000
0.9800000
O. 96(7900
0.9000000
0.9000000
0.8988700
BOIL -
0.9971421
0.9(79058
Influent Qu
Conren |r»N) In
1 . 00000
1.00000
1.00000
1 . 00000
4 data point*
O.dOOO
0.22750
0.27000
O. 05000
4 data point*
•7.0000O
87.00000
7(. 00000
22.00000
27.00000
2 (.80000
7 (.OOOOO
159.90000
3 . 50000
3.50000
0.89000
0.40000
0.40000
O. 89000
( data point a
17.50000
80.70000
erriu«nt oui
Conr««n (PPM) F.ff
Prorwsa Dnnot Ipl lr>n
•'onl
0.5600O
0.75000
0.80000
0.93000
STABILIZATION
STAR 1 I.I ZAT ION
STAIIILIZATION
STABILIZATION
CHROMIUM
CHROMIUM
f iimiMinM
< IIP'iMIIIM
sou. R
son. B
sou. B
son. B
9HO-TS
9BO-TS
9HO-TS
91(1 -TS
SLUDGE (SLUD) -
0.060OO
O.O3200
O.O4000
O.O350O
SLUDGE
0.01000 NO
0. OIOOO ND
O. OIOOO ND
0.02000
0. OIOOO
0.04000
0.15000
l.(7000
0.07000
0.07000
0.03000
0.04000
0.04000
O.O9000
SLUDGE
0.05000
2.59000
CEMENT
CEMF.NT
CEMF.NT
CEMF.NT
(SLUD) -
ri.VASH
ri.VASH
rLVASH
rLVASH
rLVASH
rLVASH
rLVASH
rLVASH
ri.VASH
rLVASH
rLVASH
rLVASH
rLVASH
ri.VASH
(SLUD) -
CARBONJ
CARIIollt
data points
SOLIDiriCATIO COPPER
SOLIDiriCATIO COPPER
SOLIDIFICATIO NICKEL
SOLIDiriCATIO CHROMIUM
0 dala point 9
SOLIDiriCATIO
SOLIDIFICATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDIFICATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
SOLIDiriCATIO
NICKEL
NICKEL
NICKEL
CHROMIUM
CHROMIUM
NICKEL
NICKEL
COPPF.R
CHROMIUM
CHROMIUM
COPPER
NICKEL
NICKEL
crop PER
8 data |>oln»»
CARBONATE IMMORII.IZA NirKEL
CARIIOIIATF. IHMOIIII.IZA CoppF.R
Taat
DncuiMint Nunbar Hum
SOIL
son.
SOIL
SOIL
SLUD
SLUD
SLUD
SLUD
SLUD
SOIL
SLUD
SOIL
SI.UD
SLUD
SO 1 1.
SOIL
SOIL
SOIL
SOIL
r.i * 1 1.
B
B
R
B
B
P
B
P
P
B
B
B
R
B
II
ORD-TSl -RT-FHMF-
9AO-TSI-RT-F.UNT-
OPD-TSl-RT-rHMF-
9flO-TSl-RT-EUXT-
980-TSI-RT-rAAP-
9HO-TSI-RT-FAAP-
9HO-TSI-RT-FAAP-
9RO-TSI-RT-FAAP-
910-TSl-RT-FAAP-
ORD-TSI-RT-FIIMF-
9HO-TSI-RT-FAAP-
ORD-TSI-RT-FHMF-
9HO-TSI-RT-FAAP-
9HO-7SI -PT-FAAP-
OPD-TSI-RT-rHMF-
OPO-TSI-RT-rHMF-
OPD-TSl-RT-rHMF-
OPD-TSl-RT-FHMF-
ORD-TSI-RT-FIIMF-I
OHO-TSI PT-FIIMf -1
1 1
1 1
1 1
1 1
1
1
2
1
1
2
2
2
2
2
5
4
5
4
)
1
SOIL - 2 data point*
SLUDGE (SLUD) -
>laI a point •
-------
r. I i i «I*MI
Tr««tablllt^lBupl Mil VOLATILE MKTAI.S
Ptoc«*» Giotlft^r CHKHICAL RXTRACTION AND SOU. NASHINC
Nobility InflUMt (Ml Effluent Otil Sf,
ftnk Reduction Cono«n (PPM) Inf Conc«n (PPH) F.I f ftnrrti* n«!«-r lp» Inn rn,,i Ami HAD I |Mm» H»-1in |«
1
2
10
11
12
13
14
15
16
11
18
19
20
21
22
23
24
25
26
21
28
29
30
91
32
33
34
35
36
37
38
39
40
41
0.9950284
0.994)182
0.992*911
0.9924451
0.9112)29
0.9618082
0.9589000
0.9541016
0.9484)01
0.9)50453
0.9348011
0.9315000
0.9315000
0.9252441
0.9211120
0.92140*0
0.9155807
0.9142800
0.91)9280
0.9014080
0.904)480
0.9041100
0.9021140
0.9018190
0.8998430
0.8981410
0.8944385
0.8924491
0.8891238
0.8111291
0.8494150
0.842039*
0.8405300
0.8524401
0.8504532
0.8430595
0.8004240
0.8002021
0.1851100
0.1851100
0.7851100
10.40000
10.40000
1O.40000
14.40000
14.40000
1 4 . 40000
0.13000
35.30000
14.40000
33.10000
10.40000
0.1)000
0.13000
358.50000
9.5800O
19.90000
35.3000O
0 . 1OOOO
.3900O
.20000
.20000
.1)000
.20000
.58000
.39000
.58000
395.90000
395.90000
33.10000
358.50000
4.39000
35 . 30000
358.50000
358.50000
33.10000
35.30000
9.58000
395.90000
0.70OOO
0.70OOO
0 . 70OOO
0
0
o
0
0
0
0
1
0
2
4
O
0
24
O
1
2
0
0
0
0
0
0
0
0
0
41
42
3
44
0
4
50
52
4
5
1
79
O
0
n
. 35000
.4000O
. 5OOOO
.11000
.42000
.47000
.03000
.62000
.75000
. 1 5000
.59000
.05000
.05000
.80000
.15000
.56000
.98000
.06000
.5500O
.85000
.88000
.O1OOO
. 9000O
.94000
.64000
.97000
.00000
.50000
.67000
.20000
.86000
.8)000
.00000
.9OOOO
.95000
.54000
.91000
. IOOOO
. ^OOO
. 1 MIOO
. i Minn
sou.
sou.
sou.
sou.
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
sou.
SOIL
SOIL
SOU.
sou.
SOIL
sou.
SOIL
SOIL
SOIL
SOU.
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOU.
SOIL
S< 1 1 1.
SOU.
SOU.
NASHINC
NASHINC
NASH IMC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASH INC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASH 1 NO
NASHINC
NASHINC
NASHINC
NASHINC
NASHINC
NASH INC
NASHINC
NASHINC
NASHINC
HA Mil •":
NAMIIIIi;
I.F.AU
I.FAH
I.F.AU
Z 1 NC
ZINC
ZINC
CAIiHIUH
CAIiHIUH
ZINC
CAIiHIUH
LF.An
CAUHIUH
CAIiHIUH
ZINC
APSF.NIC
I.F.AII
CAIiHIUH
I.F.AU
APSF.NIC
ZINC
ZINC
CAUHIUH
ZINC
ARSFNIC
ARSF.NIC
ARSF.NIC
ZINC
ZINC
CADMIUH
ZINC
ARSF.NIC
CAIiHIUH
ZINC
ZINC
CAUHIUH
1 AI'HIDM
AMSF.NIC
ZINC
I.F.AII
I.F.AU
I.F.AII
. sou.
sou.
sou.
sou.
SOIL
sou.
sou.
sou.
sou.
SOU.
SOIL
SOIL
SOIL
sou.
SOIL
SOIL
sou.
sou.
sou.
sou.
sou.
sou.
SOU.
SOIL
sou.
sou.
sou.
SOIL
SOIL
SOIL
SOIL
SOU.
SOIL
SOU.
sou.
sou.
sou.
SOU.
Si 1 1 1.
r.< 1 1 1.
Mill.
B
B
B
R
R
R
R
R
R
B
B
B
B
B
R
R
B •
B
B
B
B
B
R
R
R
R
R
B
B
B
B
R
R
R
R
R
H
R
R
n
II
» T«»t
linr-imMint Nunbnr Nun
opn-TSi-»T-EuoN- «J
OPIl-TSl -PT-EUQW-
OPO-TSl-PT-El»OW-
ORO-TSI -RT-CUQM-
OPIt-TSI-PT-EUQN-
OPD-TSlrRT-r.UON-
OPD-TSI-PT-F.UQM-
OPO-TSl-PT-EOQU-
OPO-TSI-PT-EUQH-
ORD-TSl -PT-eilQH-
OPD-TSl-RT-EUON-
ORO-TSl-PT-EUQN-
ORO-TSI-RT-eUQN-
OPn-TSl-BT-EUO*-
OPO-TSl-RT-EUQN-
OPD-TSl-RT-EUQN-
OPU-TSl-RT-EUQM-
OPU-TSl-RT-eUQN-
ORP-TS1-RT-EUQN-
OPn-TSl -PT-EUQM-
ORO-TSI-RT-KUQN-
ORO-TSI-RT-EIIQN-
OPO-TSI-RT-F.UON-
OPO-TSl-RT-EUON-
OPn-TSl-RT-EIIO*-
ORO-TSI-RT-EUO"-
ORO-TSl-RT-EUO*-
ORO-TSl-RT-EUQN-
OPD-TSI-RT-EUQN-
ORD-TSl-RT-BUON-
OPD-TSl-PT-eOQW-
OPO-TSl-RT-EUON-
OPO-TSl-RT-EUOW-
ORO-TSl-RT-EUQN-
ORO-TSI-RT-EUQN-
OPD-TSl-RT-CilON-
Opn-TSI-RT-EUQH-
OPH-TSI-RT-F.UOH-
OPII-TSI -PT-F.UOH-
OPU-TSI -PT-F.MOH-
52
58
28
22
16
28
52
23
41
5)
22
2)
41
52
41
46
16
41
10
4
14
01
44
40
58
52
58
«0
00
34
58
94
J5
)4
5)
5)
46
21
2 J
-------
Pidc«» Group:
CIIKMICAI. P.XTRArTION AND SOU. WASH INC.
Nobility Influent Qul Effluent Oul
Rnk Reduction Cona»n (PPM) Inf Concen (PPM) F.ff Prnr^ns n*!»r» ipl i»n
«'•»!»• *mi n.inl
Number Num
42
4)
44
45
4(
47
41
49
50
51
52
53
54
0.77)5100
0.7(4(525
0.7351759
0.72(1)40
0.71(9000
0. (93*000
0. (930000
0. (930000
0. (7537(9
O.(((((00
O.(54205(
0.5094300
0.4135(70
0.
33.
19.
(.
0.
0.
0.
0.
19.
O.
395.
0.
19.
5)000
10000
90000
39000
53000
49000
49000
49000
90000
1 5000
90000
53000
90000
0.12000
7.79000
5.2700O
1.75000
0.15000
0.15000
0.15000
0. 15000
(.4(000
O.O50OO
136.90OOO
0.2(000
II .(7000
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOIL
SOU.
SOIL
SOIL
sou.
MASHING
MASHING
MASHING
NASH 1 N'-.
MASHING
MASHING
MASHING
MASHING
MASHING
MASHING
MASHING
MAS HI in;
MASH 1 N<;
CADMIUM
CADMIUM
I.F.AII
AUSF.NIC
<• AI»M HIM
I.P.AII
I.F. All
I.F.AII
I.F.AI)
AHr.F.NIC
7. IN<-
CADMIUM
I.F.AII
SOIL
sou.
SOIL
SOIL
SOU.
SOU.
SOU.
SOU.
sou.
S0||,
S< 1 1 1.
SOU.
SOU.
R
R
R
B
B
R
R
R
R
R
R
R
R
OPD-TSI-HT-KUOM-
OPO-TSI-RT-rilOM-
OI»n-TSI -RT-EUQM-
OPO-TSI-PT-eUQN-
OPO-TSI-RT-r.UON-
ORIl-TSl-PT-RllOM-
opn-Tsi-PT-ruoN-
OPH-TSI-PT-F.HOM-
OPO-TSI-PT-F.HON-
OPH-TSI-PT-F.UOM-
OPII-TSI-PT-F.MOM-
OPO-TSI-PT-F.HUM-
OIMi-TSI-PT-EUyM-
ib
35
40
35
4
4
10
II
34
10
5)
II
)5
SOIL - 54 data point*
SI.IIPGE (SI.IIO) -
> inl
-------
rocaaa Group:
Mil
VOI.ATILE WT.TA1.S
IHMORILIZATIliN
Nobility InMnant Qul
ilk Reduction Conocn (PPM) lot
I
2
1
4
5
•6
7
•
9
10
II
12
13
14
0.9998224
0.9997742
0.9995161
0.9993869
0.9989899
0.9989099
0.9907730
0.9905690
0.9950920
0.9901040
0.9409790
0.9489790
0.7959100
0.4326530
6200
6200
6200
16
59
59
16
59
16
16
9
9
9
9
.OOOOO
.00000
.00000
. 30000
.40000
. 4000O
. 30OOO
.4000O
. 30000
. 30000
.00000
.00000
.00000
. aoooo
Effluant Qul
Conn Cnnt *min*r»t N4m» He'll*
LEAD
LEAD
I.FAD
LEAD
LEAD
LEAD
LEAD
LEAD
LEAD
LEAD
LEAD
I.F.AO
I.FAD
I.F.AD
SOIL
SOIL
son.
SOIL
SOIL
SOIL
SOIL
son.
SOIL
SOIL
son.
son.
son.
son.
S<-t
B
B
B
B
B
B
B
B
B
B
B
B
B
B
1 T««t
Document Nuntar Nun
»«»0-TSI-RT-rCAK-2
980-TSI-RT-rCAK-2
9«0-TSI-l»T-rCAK-2
9«0-TSI-RT-rCAE-
900-TSI-RT-euPV-
980-TSI-RT-EURY-
980-TSI-RT-rcAK-
980-TSI-RT-EUPY-
980-TSl-PT-rCAR-
980-TSI-PT-rCAK-
980-TSl-RT-rCAR-
"»»0-TSI-RT-rcAK-
9BO-TSl-PT-rCAH-
9HO-TSI -PT-FCAK-
SO1L - 14 data point*
SLUDGE (SI.UDI .
0 data point s
1
2
3
4
5
6 •
0.9996000
0.9987206
0.9011300
0.9765000
0.9467390
0.6930000
123. 70000
12.11500
0.5300O
0.01700
9.2OOOO
0.49000
SOIL -
6 data point*
0.03050
0.01550
0.01000
O.OOO40
0.49000
0. 15000
CEHENT
CEHENT
CEHENT
CEMENT
CEMENT
CF.MF.NT
soi.iniricATio
SOLIDIIICATIO
soi.iniricATio
SOI.IOIFICATIO
SOI.IOiriCATIO
SOI.IOIFICATIO
ZINC
LEAD
CADMIUM
CADMIUM
ZINC
LEAD
SLUDGE (SLUDI -
0 del* points
SOIL B
Son. B
son. B
SOIL B
son. B
9BO-TSI-RT-EUKT-
980-TSI-RT-EUKT-
OPO-TSl-RT-rHMF-
9BO-TSI-RT-EUMT-
OpD-TSI-RT-rHMF-
OPD-TSI -MT-rilMF-
1
2
0
0.9997147
0.9904301
0.9904774
0.9063000
O. 9063000
0.9710160
0.9445753
0.7047100
0.4960227
0.4714300
35.30000
1 4 . 60000
395.90000
0.73000
0.73000
9.58000
14.60000
0.70000
70.400OO
0.70000
0.01000
O. 02000
3.77000
0.01000
0.01000
0.27000
0.78000
O. I5OOO
21 .40000
0. If 000
ri.YASH
TI.YASH
TLYASH
rLYASH
ri.YASH
ri.YASH
ri.YASH
M.YASH
ri.YASH
ri.YASH
SOLIDirlCATIO
soLiniricATio
soLiniricATio
soLiniricATio
soLiniricATio
soLiniricATio
soi.iniricATio
SOI.IOIFICATIO
SOI.IOiriCATIO
SOLIOItK ATIO
CADMIUM
ZINC
ZINC
CADMIUM
CADMIUM
ARSENIC
ZINC-
LEAD
LEAD
LEAD
SOIL
SOIL
son.
SOIL
SOIL
son.
SOIL
SOIL
s»ii.
son.
B
B
B
B
B
H
B
R
R
R
OPO-TSI -RT-rHMF-
OPD-TSl-RT-rHMF-
ORD-TSt-RT-rHHr-
OPO-TSI-RT-FHMF-
ORO-TSI-RT-FHHr-
ORD-TSl-RT-FHMF-
ORD-TSI-PT-rilHF-
OP-O-TSI-RT-rMMF-
OpD-TSI-PT-rHMF-
«IPO-TSI -PT-FIIMF-
2
5
2
4
5
2
4
5
2
4
SOIL - 10 data point*
SLUDGE (SI.UD) -
O
.Inl H point n
-------
fe lo. 1
/It/N •__
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M'lllfl laltri tutu Bcpmieit of Jutict
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I Iidiin Depirtitat of lighvifi
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CI loited ftitti Dtpircitot of Iitenor
F Qnlity iiionoce Project M*t
Pottitiallf Itipotiiblt Pirty
for Toiic Subitioct tod Oiitue Itfinry
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PliBiiif lutirek CorporatioB
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l»ct««iu kit milifelt i«i iititi U
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-------
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•4/11/1)
(iiiiict Hciicirs i inti.
•IICO I t II Jltti, (III. Illllll.
(•itfuct licntiii tu ifiiliklt itt ittlii u
um it«ut i-aieii* u •
mil
luiftim If lute ItiUic.
IlfllllltitUl Ciiliiec Mi Itlrtit, IKIII. M CiliUrni Itit
lutti fik|tct ?• ICIl/ISIt Ui< litf«i«i ltitii:um.
liciiUtllti liurJou Inn liu ttikiii Sftttii (IkS) •
I lull Itiul.
lutliil luifi M tmtfiil ietui Cii^uct Ill/Hi
It rmlkilitr lutfiei |fi| li<«i CliClt.
Cliliiet U Ititditl IifiiUfitieii (II) lidtt CIICU
liti Qitlitf ObjtetiTii lt(fUM<*t «ii<«-'< for
Itipout letitii.
lltiril CiiJiiCf Oi Iir«t(n4 Stlictiet Ot liiedy.
11/fS Iipiimtiti.
Tk« Ifl frinr.
f.r CoriictlM II/H Mtt ClkCLl.
ItUtimkii 0( tkf ItiHvil M leiriiil rtifta IKct Ut
Itttiti Itr
II/IS Iifriftititi
Ctliuet It iMltKititlM 01 U< 'Cotiiktit To U« Kfuitit
ltn4Ul
IITMI
•SHI 1)4?. •••2
•SHI »i$.»-ll
•SHI J»5. 1-141
•SHI tHS.MSC
•sun tm.i-fi
•SHI J1S5.I-I7I
•SHI J1S5.4-H
•SHI 13SS.I-2I
•SHI DS5.1-42
•SHI )]».]••!
•sm nu.iu
•SHI
•SHI J1M.I-U
liTI
lit •( tin*'*' Itutil Iitk«til| T* IMitu IPL U4
in Jim.
Ilirrr ftiiek Ciiitrietiu f«i NtUtlM li|titi«i C;iiuli.
fir Cltutf •( lufm twl M Iru liut.
iirutl litti lulkoik.
flut luiftuit.
M'MII Sittt.
II II. I*. T, Hi S 1121
HiHial Ictiii U lutt
l
:>•*.
fttluct Neutit fit CUuif •{ Ittlict
Mill JM.I-14
•Sill DM I 12
MHI WI.I-IJ
Mill I1M.I-M
Itlllttt
-------
riff •».
J4/U/II
*
ciiiiici fcicmiTs i IIDII .
IIBCO I i II tITCi, CUT. Illim.
ttcnmi m inhibit (•>! rctiti it
•SIM lifivk l-CkK-li«.ll"
flfil UTMI
HIM tltkulM! ScitttiM M*t '••' titUMkl 0( CtlCLI JiiU
III Itiifit.
•Sin CiUillin r«r Ci«ii4iat«i CliiiHicJtioi lt«
-------
e le. 1
24/IJ
ii/riiu puts uri
TITII
ItCOlO I1DII - IFSifS
IIICO I
uii, iicim
iinoi -IICIMCIT
tOCliilf TTfl
OOCIOIEIF.
1 17/ll/li
1 IS/tl/U
3 li/13/13
2 li/14/17
i M/imi
N/ts/tf
leeord of ploat eill
to lirt lout of PIC
lariroaaeatal. lii ealr
coacera after returns
tic diti 01 tit I!M i»pl<
froi tic lortl of lideo I
li tic leieiibilitf of
tic Pil'i fioi tic iltg
iito tic MI'i it tic paod.
lovercr, Ic doei tot think
tltt tdditioi.il iiaph&f
it iccded.
lc:ouctditioi Uit oac
fl-foot loiitono) veils
be intillcd 01 the oorth
of tic lite to deteriioe
If i deep nod iqtafer
it prcieot.
irriifcieati ire bciof ndt
to lire (I firdi of elir
dclircred to tie lite fcr
pliceieat 01 top of the
tut pit location.
Coafiriitioa tlat tie
ISCFi tad tic OOJ IITC
•o oljcetioai to placiaj
a fcaec aid fate aloag
tic teit tide of lime
It. atd repiiriif tie
ttiatiif feaee 01 tic
•tier tlree aidei ef
tic ait*.
Icriicd icledilei for
dcliterahlti.
liel
Coaaialeitioi leeotd 1
lich loice-tSlPA
leobert ileo-BSlfi Corrcapoadeaee
iobert iteo-Ceeicieo:et liet leiee-ISIFA Correipoedesce
lobert iteo-Ccoicieacei liel loiec-ISlPI Corrcipoadeaee
Iobert itea • (eoioeacei liel loiee-ISIPi Cormpoadeace
Pfiie II iroaidmir aaaplei lolert itea-Ccoicieacei liel loiee-IIIPl Carrcapoadeaee
collected for letal aailraii
till Ic filtered.
letter aad ulle reflcetiaq Jaiei leith-Cciacicieei liel leice-MM VCarrupoadeice
efcuiet li tae treitaeit
tf fioudvatcr fuplei
fir null.
I K/tf/M leeotd |f a pa*>t call
I. Itca-Ceoieieaeei llelard lole«-niPI Corrcipoadeace
-------
It le. 2
:ii/riiu run im
7 li/li/lt
uiiiismrifi IICOID lion
IIOCO I
CUT, noun
iron
TITLI
•km Ctoacitacta its
ieeied Heir revest
(or i reductioa of tbc
hut II Croiadmtr
paraitttr lilt kr loiet
of tk( ISPa.
Itcaut of rapid rtcoitn
of Ue Kill dariaf sin;
ttiti, transducers nil be
tied to record rec«mr
tod i paeuaatic letbad
lied to depress tbe »ater
lereli. Us;, i detailed
aquifer tup test »ill
be perforied.
iirioi
liieartk lute.
-llCIfllir
locginr TTPJ
loberi ttea-teotciesces list loiet-9SI?& torrtipoodenn
DOCIOHEZK
I K/li/21 Lilt ootlioint tbe stilus
of tape do«os eoodu:ted
duriag rendeotial veil
naplio;.
II !4/«?/23 leriied sekedalei fer
coapletiog tort.
2 li/17/24 lotiee tbat a pup teit
•ill be perforied aid tbat
Ceoscieites loald like
to diiekirte tbe froiadvtter
to tke (ary Siaitary Diatnet
laitenter freatteat Plaat.
lobbia Lee
!eff-(e)i:ieo:es
lieb loice-ISEPA Correipoodeo:t
II
lobert. atea-CtQiciea:es lieb loiet-tSKPa Corrtipoadeoce
lobert itta-Ceoicieaces I.Lyacn-6»ry Correspoideace
SaaitarfOiit
11
12
1 K/17/28
7 17/11/11
• 17/11/13
«
«»
I? 17/11/15
Coipletioa of additioaal
31-foot test boriaf aid
•oiitoriif fell (titboQt
•tuektitat).
(meats 01 irray of
llteraatnei doeiaeati.
llTitf Of IIJCO I i II
II Itporti.
lifiit eoiiciti oi tke
lldei I i II II Itporti.
lobtrt ltta-(eoicitices lick loict-ISIfl Corrtipoadtoce
13
lick loice • KIPA
lifid loaer-MC
lor lall • IIH Corrtipoadeace
l.l.lriwa-reits ill lieb loict-ISIfi Comipoadcice
UUerutf
lick loiet . . i
14
IS
1C
13 17/ll/K loriti tad ualyiii of
loiald
lick loict-lim C»rreip«idcac(
-------
iin
17/13/li
17/13/11
17/13/13
17/14/13
87/15/14
17/15/2*
17/14/17
I7/K/1I
17/K/2!
uiiiismmi iicou IIDII • irom
IIOCO I
CUT, IIDIlli
mil
tic fint drifts of the
lidco I ltd II II leports.
Htm. -iiciwiT
Iiitk-Fmtiliibert.recb.
CM
TIM
17/11/2) Icfic* ltd trittei couesti Dmd ludik-D.S.Pept. of lick loiec-ISIPl Cirreipoideaee
•i the Inft II lepcrt
fir lideo I dtted
11/21/H.
Iiterior
tetcriiiitiot tkit idduioail iiiil Coostiattlos-ism Oliii, Clmke,
inplii). iiilfid iid Inker
inUitiei ire lectiurr
letiet of ii idduienl ttit lobert ltti-(toieitiees lieh loiet-IStfi
Ioni9 i«ir tkt pup test
tell.
Cirrtipoidtiet
Cerrtipeidtiee
Conetts OB lidco I iid
II Drift leitdul
iBTtitigitiooi Itporti.
lideo I iid lid:e II
Progrtti leport.
Itqutit for laforiitioi.
lideo I, irosid titti tad
urfiee itdiieit mpliaf
•etititits.
Baker-IOIli
lick loiet-DSIPA Correipoadetre
eomiti to tie
•ecood drift if tke
lidco I II.
liiiiry if In tit lideo I
dm till it itiliztd fir
tic pirpeiti if tic Ilik
liicmeit.
letter li tci|otic ti
letter lited (/il/17
•id pine cummin
•f 4/24/17 fro l»f 1*11
•f III Hrtl-Ceitril.
1. Jutificitlii fir
leteniiitiii if ID Icfeli
fir Metiie ud aitkrltit
cllirilc ire lit cliarlr
prcteitid.
2. fcttdilt if eipteted
Mliittili If Ul ti tic
Irtbnr Sl«iia«er-lortoo licb loiec-BSIfk Cirrcipoadeaee
Tbiotol
luil CoBstiateloi-BSlfl lould lieu-IDOi Cirreipeideaee
lebtrt IttB-Ccoseitfiecs lick loicc-ISIfk CirretpoBdcBCt
lull Coaitiittloi-BSPk l.llettkc-litcrprii Correipoidcice
e Co i
loj lilMli lortb
Ccitrtl
lick liicc-ISIfl
lick loiee-ISIPl Corrcipoideoee
lif 1*11-111
lirtbCeitral
Cirrcipoideice
IOCIOIEIS
11
i)
21
21
22
23
24
IS
2i
-------
om
uiiiismmi ncoio IIOH • mm
IIOCO I
CUT. noun
TITLI
ism.
3. CUrifieitiei of tin ii
•cut IT loctliztd
coitiitiitioa.
4. 1 uibtr of ttlli itre
•et Notified 00 tie
well liTtitorr.
S. TitTiM liti eo&ditiots
it i reiolt of put lite
iperatlou mit It ukea
lite teeooat.
1ITIOB
•IICmtlT
MCIIHT fill
IOC1HEZE
3 I7/K/2) letter ittichiof ieio
ibowia? tbit i laibtr
of irei residents in
tie icijbborlood lortb
tut of lidco I hue
wells tbit ire ised for
dmii&9 liter. I8H is
•iked to perfori i
looicto-boase CIOTISS
to loeite rtiideotiil wells.
itteriiie their depth, tod
•life.
4 17/17/li rreliiiurr review of the
tlird drift of tit lidec
I II.
2 17/17/21 Coieens owtr tit tlird
mid of iiipliig.
.3 17/17/31 Ittttr suiirizio) tod
rtipoidiif ti liuti niitd
Ii rtetit eorrtipoideice
rifiriiif tit drift II.
2 17/11/17 Inn" fir tie IMI'i
pliu fir iddreniif
••It ciitiiiutioi froi
tit Cur liMiitrict
* fieillty.
I'17/11/12 lifiot fir Iiforaitloi
u • fillM-ip ti MI
•lit i/4/17.
S 17/11/13 Itipoue ti eiuttti ••
tie lidco I U Irift
liel Icice-OSm
lor lilMlR
lortlCeatril
Corrtipoodtoee
2!
Cirolt liiif-lor f. lie! loiee-ISIPl Correspoidesee
Ititoo.Iec.
2)
liel loiet-ISI?!
toy lill-lll
lor lilMU
Corrtipoidtiee
liel lolet-ISIPl Corrtipoidtoee
31
fildis Idukii-ISPi Jolt Cirrtipoideice
Iieifcirfer-IIOI
lull Ctinutilii-UIFi Illllu Uf-
l«r ItlMII lortl
Ccitril, lie.
32
liel lilet-nm
33
14
-------
lo. S
in
Mill MCIS I1TI
1 17/MW
1 17/11/21
II 17/11/27
IS I7/M/I3
2 I7/4J/II
II I7/IJ/22
1 I7/D/2)
2 17/11/2!
1 17/11/11
j 47/12/1)
, ^
1 17/12/14
uiinsmrifi IICOID HOU • irom
II8CO I
CUT,
rim
lorioi
lo. ) ltd tkt lidco I
lidiaferaeat liiemeot.
letter itttiptiaj moUtioo lieh loice-OSIFA
if 1I/FS inoti.
Icrlii of lideo I II diti.
Icipoaie to coiieati ude
oa tbe lideo I II drifti.
Itfitt of tht fiul II.
ClirifieitioA of tkt lilted
Stite'i potitioo tbit the
dtftlopatat of tbe rtiedul
ictioa tlttraitifti it i
tteboieil tnk bated 01 in
ob)cctirt iTiliitioa of
tkoie rtiediil ictioos ire
wit eoido:ift to luiiinog
or litifitiot tbe tbreit
•f kiri to Mblie kdltb,
ttlfirt or eoiuooitot.
ftekiieil ritiet eoueats
•i tkt Itttditl Optioai
loeiieots.
Coutits ii tkt drift
prtliiiurr lilt of
rttedill ttckoolofiei
lid fllll COHtltl 01
tkf II.
It?lit if II (it lideo I
•id link in. liip.
If prof il if tkt fiul II.
Coueiti ii fill I if
ttt IS.
Circle liaot-lcf F.
leitoa. IDC.
lor ItlMlH
M.lroffo-IlBU IOT.
Cooialtiits
Joel (rois-DS DOJ
fort Stiipioa-lof F.
Ititoa
lick loict-ISIFi
1ICIMIIT
KCIIIIT TTfl
lick loiet-ISlPi Corrtipoadeaee
lall-IIR
Corrttpoide&ce
Ma latabaritr-IBOl lick loiet-ISIFi Corrtipoadeaee
lick lolct-ISm
lift loier-FIC
IOT lill-Ul
lick liiet-ISIN
Ctrmpoidtaet
Correipoideice
•itliie if IKJIi Coiiiltiifi I I.Licu-1601
frifiitd ictifititi rtfirdief
lideo I ud link tft. liip
lick loict-m?i .ttntifoidciee
IOCIOHIIK
IOT iiii-m
lieb loiet-ISIPA
lick loiet-BHPl
lick loiet-KIPl
I.Oliaa-SidleT 4
laftia
Corrtipoadteee
Corrtapoadeaee
Corrtipoadeaee
Corrtipoodeaet
Corrtipoadeeee
35
3i
37
31
3)
41
41
42
43
44
IS
14 11/11/12 Criud liter Cntribitioi to Iliit lilliio-III
lick loiee-ISlPi Cirnipoideiee
4(
-------
! 10. i
24/8J
i/mn pins tin
7 ll/M/31
2 IB/M/2S
2 ll/IS/17
J 11/17/li
22
UIIIISTIITW HCOIO IIOH • irom
IIOCO I
CUT, IIDIilA
rim
Surface liter Coaceetratioai
•t tic lidce Sites.
iaairsis of Phase I
•f Cjioide Siaplioo..
Contoti oa the FS.
Itriti of the Profreii
leport Ic. 14.
Coueats oo the FS.
llTlOfi
lof Bill - UN
Joba Iseebirger-IDOH
8icb loice-BSm
Dm Boaer-PIC
•BICIP1IBT
MCBIIIT TTPI
lies Boiee-BSIPa Cmespoadeaee
Iieh Boice-BSIPi
loy lill-IIH
Iieh loiee-BSIPA
lerie* of the FS i Dissipation Frederick Teit-lcy. f. Iieh loiee-BStPi
of (roaodmer ilteroatives. leitce. lac.
Correipoadeece
Corrcipoadeaee
Carrttpoadeaee
Correspoadeaee
BOCIOIEEE
17
4S
4!
51
43 ll/«7/n letiei of lideo I drift fS.
( 18/18/1! lotiee that a release of
aiurdoQi sohstaaces.
lollntaots aod contiain»c:s
•ar he attributed, tc the
IDOB faeilitr.
J 88/18/25 Caaaeots oa aev alteraatives
reqaested bj the BSIF1
(or the FS.
24 BI/D/1) leapease to BSlPk letter of
1/7/17 aed follotop letter of
8/18/81 allefiai possible
eoitaiiaatioa froa the
IBOI Sarr Sihdistriet faciltj.
3 BI/81/2) Priliiiaarr renew of the QAPP
for tie sdidificatioa tests.
( BB/M/31 leriet of eleaaap action
letels at lideo I.
4 U/ll/17 Icriet tf the QiPP for the
<'_ Mlidifieatioa tests.
0 ,
"•••.
'•^ SI/11/18 Ttehiieal rtrict if eleaaap
•etioa Itreli fox lideo I.
II 11/11/31 Idditiuil Iidiiu lir
follatin B«filatioai
fir laditai illl's.
Iieh !oi:e-OSm
lirr CtdcOSZFA
tor Bin • m
Joha Iiesbirfer-IBOH
Iieh loiee-BSlPa
lire loier • PIC
Iieh loiee-DSIPA
Irederiek tect-lor F.
lestoa, lae.
Icfiiald laler-Illl
lay Ball-UK Correapoodeoce
lilliai Iiy-IDOH Correipondea:e
Iieh loice-DSIPi Correspoodea:e
Taldas
tdaikos-BSIFi
Correspoadeoce
lor BalMIl
Correspoadeaee
Iieh loice-BSIP! Correspoadeaee
lor Bill-Hi
Carreipoadeoee
Iieh Bolee-Btni ^(«rr«i|oadeace
larea *r
faafka-laiesaaore
52
S3
5(
Si
S7
SI
Sf
(I
-------
ft le. 1
126119
H rim ncis uri
( 11/11/14
I 11/11/11
( 18/11/11
1 It/11/29
uuiismmi IICOID IIOH • mm
IIDCO I
CUT, HCim
Tint
ftcbaieil rttitti of wiitd
drift fS (or lideo I Sin
ud IBOI Ittttr of J/1J/I8.
Icfioioi to leitoi'i
eoueiti 01 tit FS.
lifjei of ipptadieto 1 i D
li tbt fS'i for lid:o I
i II.
Coattatiofi tbu tbt miliblt
diti eltirly ibovi tbit the
IBOI fieilitf ii the ujor
toaret of tbt my lift
ebloridt.iodioa.TDS tod
ceadBctimy plait is tbt
frotodmtr otir tht utt.
linos
frtdtrick Ttit-loy F.
lUtOB.lBC.
frtdtriek Tt»t-loj f.
Itotoo, lie.
Bind liitr-PRC
-IICIUMT
MCHIir TTFt
lieb loiet-ISIPl Corrtiioodeict
lieb loiet-ISIPi Corrtipoodtnee
lieb Iciet-BSlPl Corrtipoodtoet
Jsbn Corrtiposdtoet
Iitobarftr-IOQH
IOCIOHEK
fl
(2
C3
it
4 11/12/12
5 18/12/15
S It/11/13
S U/ll/23
2 M/I1/2S
1 n/ll/27
Itmioos tod additiocs
to tbt IS.
lieb Boi:»-DSlFA
Itipoote tod centals to ttt Iliit lillio:-IIN
f tod iBilfiis
Clirifieitloo of tbt erittria Juti
tbat till bt ntd to triluitt
tbt tfftetirtitis of ii-iitu
taper txtrietioa followtd by
ii-iiti icliditieition/
lUblllZltiOB.
Itfitt eoutiti 01 tbt
lideo I ud II fS.
lieb loiet-ISm
Itport 01 •miifbt ictlfitict frtdtriek Ttit-loj f.
tt Itdco I liriif tbt rtetit Ititoi. loe.
tt 11 Miplitf.
ItTitt if 1/13/19 IditloBi llebird loiet-ISIfl
•f lidee I ud II rtiiibilitj
by ne IB?. MI:
Frtdtrick Ttit-loy f.
Ititoi
ftebiieal rtfitf if tbt
rs.
loy CorrtipondtDct
Itll-l&i.ltioaet
Igit
lieb loiet-ISPi Corrtipoodtart
lor lall-lll
Corrtipoadtoet
larte Corrtipoadtaet
fiijba-iiatiiloort
loiet i
Cotrttpoidtaet
laitailorrt i Carrtipoadtiee
lirltioiiet
lieb loict-ODi ~ ttrrtiptadtiet
(7
il
71
71
-------
e lo.
21/IJ
ii/rim PISH iin
uiiiisfiinii IICOID lion - irom
IIDCO I
(ill, IIOUIA
rmi
IBTIOI
iicmiir
MCOUIT TYM
IOCIOIEIF
2 If/11/31 Coutoti oe tbe FS
I D/I2/1I leipooie to coooeats ea
the renihility Study.
1 11/12/13 litttr ititioi tilt it tbe
•mti ire escifited, liitd
with reajeets tod tbeo pliced
bid ofltc the lite, thea the
liDdtto re«.ul»uoos ny be
applicable.
liker-IDI* llel loice-ISm Comipoodeoee
lieb loice-BSlPA legioald Itktr-IOH Corrtipoede&ce
Jliei
Troy lill-PM Cerrtipoodeice
Bpdite
loftibtr 1)17*
2 ll/ll/ll 'lidco I i II leitdul
Iircitifitiot Ipditt
liatir M8S'
2 11/12/11 'lidee I i II Ititdul
latdtifttioa Ipdite*
3 N/II/M Hit of lite riiiti ip
to 1/1/83.
S T9/II/IT leeoaiiiiuee iiipeetiei of
lidee I I II to 1/2/71.
( ll/li/1) Otfaic fipflr CoipUiiti
lo lioioid, laliioo.
loipectieo to ioteitifite
tknc leporti.
4 D/I3/I! Iciort oa 3/1/13 lite
fiiit.
2 13/11/14 tilt of oite fiiiti
to 11/5/12.
ism
ism
Icterly laih-ism
Fiet Sheet
fact Sheet
leioraadoa
Jay CoKitela-ISPl Icooraoduo
Jerry Iclly-Icol. k Sri? leaorudai
loTlr. TIT faaderliaa-ISPi
Iiren
Joto imiutt-CI2l lill file
alii liooiao-ISlPi farea
Jkiorudu
fi-
r^ Inorutoo
72
73
74
3
2
4
3
IS/IS/H
is/ii/ie
15/44/1?
17/11/H
*lid:o I • 1 Saperfood Site'
'IP! lD»:ut:ts lid:c II
lork Plic'
*IP1 Iciooacet iqreeaeot Oo
lideo I 4 II SUM Is Jiry*
•lideo I i II leaedul
ISIPA
ISEPA
ISKPA
Kin
fact
FlCt
Pict
fact
Sheet
Sheet
Sheet
Sheet
75
7(
77
78
II
II
12
13
14
IS
3 13/11/11, Trip leport oo lite tiiit. lire looer-fIC
nic
leioriodio
K
-------
t lo.
3i/run puts im
umismmi iicoto IHII - ipom
IIDCO I
CUT, I 1C I III
TITLI
-tlCIPIIIT
MCIIIIT TTPI
pociosm
2 11/11/27
1 K/I3/2I
1 14/13/25
3 li/K/IC
5 If/K/U
2 li/D/15
•
2 17/11/11
3 17/11/21
I 17/11/21
7 17/11/2)
% '
I 17/11/11
( 17/15/15
laipectioo leport.
lidee I Croaadmer
Supliig Pbaae I -
of operatioas.
hi Incr-DSlPl
Careo leioraadua
HldfOfeMSIPi
I?
lidco I Surface liter
lad Jediuat Saaphof
Pbaie I • Suaaar;.
Trip Itpert, PIP iudit/
Traiaief-Ceoiciecct
lesaercb iisoc.-lay 13-15,
mi.
Itipooif to coiieits ndt
by J»T Tbikkir, Detoii
Itieleviki tod Pttrick
Cburrili rejirdio?
cootrict l»t:r»t;ry
lobert iteo • Ceoicieacei licb loice-ISIPI Itiortedai
letb Slayi-Ctoicieocei lieb lotce-OSIFA Kiortadoi
leiolonki 4
ciuniii-gsm
Ifioriodai
Jiaet Ieitb-C«oi:i
-------
fc Io. II
/2J/I)
:n/mn PISH nn
4 I7/IS/2I
2 12/11/27
uiiiismrm iicoto IIDII • IPOITI
IIDCO I
CUT,
nni
for lidco I ilu.
General critique of tie
Mceod draft of cbt
lidco I ladaogeraent
iiieintit.
iinoit
•iicimir
licbad Stapletoa-lor P. lieb loieclSIPi
•eiton
IOCIUIT TTPI MCIBIHI
Itioriodoi
4 I7/IS/22
( I7/K/1J
2 I7/IJ/I3
) II/M/-I1
2 M/M/M
locaimatioa of a aeetin?
to preient aad diicits
correction rented in
tb( lidco I II l(port.
leilth iiamaeot.
lidco I, interference ia
cfaaide aaalyi(f.
I(Tiei of the PS • leaedul
Iteraatiiei Screening.
lidteit legion Sariroaaental
lieb loicccBSIPl
loperwory Cheniit-lTSDI
lobert lteo-(eoi:ien:ei
Cinlei Saftia-BSIPi
ISIP&
Paol
li(f(obacb-BSIPA
Looiie
Pabiaaki'lfSOR
lop lalMIR
laail
Conitateloi-BSm
leaoraodua
leaoraodua
leaorandun
leaorandan
Ida lelene
111
111
112
113
114
'Kin Sdteti Contractor
Por lidco I laiardoai laite
Cltaaap la (ary, Indian*.'
ISIPA
21 N/ll/ll l(*ipap(r artielei.
leu Idtast
115
Ittapapd irtield IK
14 N/M/II
43 M/M/M
M M/ll/14
7S M/ll/ll
I 12/11/1)
25 IS/11/17
Liit(d latardoai laite
liaaoaal it lideo I aad
lideo II.
Izaaiaatioa of larioa D.
lobmoa.
lepoiitioa of Clarlei i.liebt Clirlei 1. Liebt
l«poaitioa of larria Bale larria (air lobiaioa
lobiaaoo.
Itpoaitioa of Iraeat Idart Iraeit Idart
trlfiaal lapi »T Idart
i libiaioa.
Iitcrrifatoriia Of fb(
Nlart i lobiaaoa
lickacl
117
HI
II)
HI
111
112
fee Mrtlee list Phadingi/lrderi in
Otler
Other
Itaer
•tier
-------
e lo. 11
21/1!
PIHS HTI
31 IS/14/12
J5 IS/l!/2f
71 ii/ii/ee
4 M.'H/II
2) ll/ll/ll
11 14/11/M
It 11/12/31
81 11/12/M
ISPi
Tim
Icftadaat tbe Pcaa
Ciatril Corp. To Tbe
laited Statti Of latriea
•loaf tit! a lefneit
For Prodaetioa.
Partial Coaaiat Decree.
Icipoaie lad Objtctioai Of
fit lined Stilt* To Tbe
laterrofitoriej Of The
Itfeadaal Peas Ceotnl
Corp. To fbe tailed
luiei Of aaerlea.
Staple Collectioa Procedure]
For Solidification
Treiubiliiy Stadf for
lideo I tod lideo II.
Bocaataittioa of the
ftoloir aad IB inesiieai
of tat poteaiial for
fioaadviter polluiioc
at lideo I i II.
itrial rkotgriphie ietlyin Of IISL - ISEFi
latardoat lint Judy Sites.
IICOID IIBH • nun
UOCO I
6111, IIOIAI1
iinot . 'IICIPIIIT
lliakibiii-lildait.lirrol
IOCBUIT TTFl
lideo Troattei, el PlcidiBfi/Orden
al.
Joel Cron,et al-B.S.DOJ See terriee lin Fleidiagi/Orderi
Dues ( Moore
S:baidt-ISIH
iitt ifieisaeat for
loaie't Jaak Tard.
leatoa-Sper TIT
Oealitf laaaraaet Project I.S.fiib i lildlife
Plaa • farf
-------
S I1TI
IT/12/11
17/12/M
11/11/13
It/11/21
ll/lt/lf
11/11/24
U/I2/1I
11/13/17
17/IS/IS
uiiiisriinri IICOID IIOH • irom
IIOCO 1
(ill, 1 ID IIH
mil
ucifiiir
lidicit SelTfit lecowy,
lie. Hideo 1) (irr,
Iidiaaa. Piblie Coueac
Irift - ipptadicti i
fbroifb F.
tticdiil lamtigitioa Of
lidvtat SelriBt lecortrr,
lie. (lidco I) Sari,
Iidiiot • fiblie Coutat
Inti.
iticdiil lafeatifjitioa Of
lidmt SoUcot IteoTery,
Inc. (lidco I) dry,
Iidiiai. Public Coiieat
Oraft-ipptBdicta (
fbroegh I.
CroBidmtr IK iBreotorr
lortbeiit Of lidco I.
(fOICitlCII IBd III
Ctoicieo:ei tad III
lobert Atea-ttoicieocei loy lill-IEl
ItKircb lortbCtatrtl
ftcbtictl leioriodui: lidco I, lobert itea-Ctoicitacti lay lill-HH
leaad 4 atljticil rtnlts.
Qulitf inoriaet Project PUe Btati i loor«
Per Selidifcatioi frmibilitf
Itidy lidco I lad lidco II.
lidco friattta
Italtb tad laftty PUa
lolidlficitioi frtatabilitr
Itidr lidco I ud lidco II.
Piblie Cmtit Puiibilitr
Itadr lldint Itlfcat
Itetrtri.Iac. lidco I
lit*, C»r, ladiui.
tddcadia fa Piblic
Coiiiat Puaibility
Itidy lidtcat Solicit
licoTtrr, lie. lidco I
lltt, fiiry,
laiei i loort
Baaei i lorrt
III
NCIUIT TTM
lideo Truatica Itporti/Staditi
lidco Trailed Icporti/Stadiei
Itporta/Staditt
Icporu/Stadiei
Icporta/Stadici
lipona/Staditi
lidco friatata laporta/Itadici
lifltt at dan ud data
fr»i liatci'a icrttalat
tftratioa urtb »f lidca I.
Cirtla laaa • IIIPl
lick laiet - Blr^
• *
MCHIElt
123
124
12S
127
121
12)
lideo Traattca Itpona/Staditi 131
131
-------
Page lo.
M/17ilM
TITLE
KID CO I
AOTHOR
DATS FiGES
Technical Review couents
OD RI Reports
Eiergeoc7 Action Plan
Oepositioa of
Dr. Eugene Meyer
Gar? Air Pollution Control
Inspection Earratire
Sutiary - Soil surface runoff
and waste tests for letals
Affidavit of B. Sloan
Affidavit of A. Baaiaon
Tentative Disposition
final Strategy Deteriination
Soil Cleanup
Reiedial Action Plan
Ueio concerning
public coiplaints
Neio oo public iceting
to discuss runoff
Heio oo
Contaiioation Study
lotice to Deflarts
of cleanup
lotice of cleanup
notice to Blooiberg
of cleanup
lotice to R.Oaison
of cleanup
Eotice to 7SE
of cleanup
Bertao 4 Licbt, Attys
RIovack - laiiood APC
Jlia - ISBH
BSloan • Gary fire Oept.
ABaoiaoo - EPA
Baniaon - EPA
Be nan • OSEPA
Ecology 4 Environient
99/99/98 12
89/98/99 62
76/43/94 7
79/96/15 21
79/99/11
79/11/97
39/93/18
88/93/25
TAT to Tanderlaan - OSEPA 81/96/11 17
GHHadaay - OSEPA 31/96/17 1
TAT to 7aaderlau - OSEPA 31/97/29 1
31/19/16 2
Steele, OSAtty to Corn, Atty 32/91/29 3
Steele, OSAtty to Kartell 82/91/29 3
Steele, OSAtty to Hattbevs, 82/91/29 3
Atty
Steele, OSAtty to Sorris, Atty 82/91/29 3
Steele, OSAtty to O'Cooner, 82/01/29 3
Atty
lotice to tbe Klisiaks
Steele, OSAtty to Oatrowski, 82/91/29 3
-------
.89
TITLE —
of tbe cleanup
Refusal to food fencing
lotiee to Intec
of cleanup
Heioi Continued
Removal Activities
fencing of Site
iir Monitoring Log Books
TiT Report of prime
tell saiples near tbe
Hideo I Site
Letter re: Interii
Health Assessment
Citizen Briefing
Documentation of
public iceting
Cleanupt final Report
legotiations with generator
Reioval of drtus and
settleient negotiations
legotiations vith
taste hauler
final Report Report
Affidavit to D.Convell
Hydrogeologic Report
Site Inspection
Heto: Possible
cyanide duiping
SID CO I
AUTHOR DATE PAGES
Atty
fRocbe - OSCG to EPA 82/93/92 1
Steele, OSAtty to Koran, Atty 82/93/92 3
Capper - OSEPA
Hadany - OSEPA to lortoo -
OSCG
OSEPA
Bofden - OSEPA
Skin • DHHS
HcCone - TAT
82/94/91 7
82/94/15 2
82/94/19 12
82/96/15 33
32/96/21 2
82/96/39 1
82/97/98 3
TAT to Bovden - OSEPA 82/97/19 3
B
-------
,./89
TITLE —
psts for metals and cyanides
Conclusions regarding
chemical exposure and
potential health effects
Summary of extent
of contamination
Preliminary Assessment
Bydrogeologic Report
Addendum
factual Information Package
Endangerment Assessment
first Amended Complaint
O.S. v. Kid?est Solvent
Recovery
Remedial iction Master
Plan (RiMP)
of citizen inquiry
final fork Plan: Rl/fS
Scheduling of public teeting
of surface related issues
Proposal for settlement of
surface related issues
Trip Report on public icetiog
. Letter to Grand - OSEPi ret
Meeting with Caloiet River
I Task force
! Conversation Record on Happing
of entire area
\
Letter to DOJ re:
C Coiplaints on final Partial
S Consent Decree
C To Sidley & iustin re:
Objections to Interrogatory
MIO CO I
iOTHOR .
Stein - DHHS
OSEPi
Ecology t Environment
Ecology 6 Environment
DATS . PASES
82/11/22 3
83/«3/«« 64
83/93/11 S
83/M/97 28
Oragna - DOJ to noticed cos. 83/99/92 16
OSEPi 83/12/22 20
MLIalker 84/91/19 35
CB2H Hill
lovack - laiiond iPC to EPi
CH28 Hill
Lake Michigan federation to
OSEPi
Sidley ( iastin to Dragna •
OOJ
Boice - OSEPi
Musgrave - OSEPi
84/11/99 192
85/91/28 2
85/92/9? 95
85/92/29 1
85/92/26 3
85/92/27 1
85/93/91 3
Geoscience issociates To EPi 85/94/25 1
Barker, tadison et al
Berian - OSEPi
85/95/97 3
85/95/16 5
-------
4
//89
TITLE — •
Ansvers by Prefinisb Metals
To Barker, Kadison et al re:
Obiectioas to Interrogatory
Ansvers by Zenith
Partial Consent Decree
»ith Exhibit B
lets Release OQ Agreeient
Fact Sheet OQ fork Plan
Final Conunity Relations Plan
Hideo Trustees Coiplainst
to OSEPA
Letter to OSEPA ret
latare of Contamination
Quality Assurance Project
Plan (QAPP)
Letter to OSEPi re:
Analysis of draft of
RI Report
Letter to Kietlicki et al re:
Proposed Second agreed Order
Modifying Partial Consent Decree
Suuary of coiients on
draft RI
Quality Assurance Project
Plan (QAPP)
RI Extension Request
To OSEPA re: RI Delay Requests
Modifications to Saipling
Coiients on Ecology section of
Second Draft of RI
Critique of Second Draft
of Eodangerient Assesstent
KID CO I
AUTHOR
DATE
PAGES
Bertan • OSEPA
Gasior - OSEPA
Gasior -OSEPA
OSEPA
Harpby - Rastoleai
Slesinger - Thiokol
Geosciences Research
Associates
DVSiith - Pratt
Gross - DOJ
OSEPA
Geosciences Research
Associates
Sidley & Austin
Morphy - Rnstoleni
OSEPA
Hudak - FSIS
85/95/16 7
35/9C/17 101
85/96/19 4
85/97/98 3
85/99/98 27
ac/u/ea 2
86/19/31 2
36/12/31 34
37/91/16 2
37/91/21 12
87/92/18 4
87/92/25 ill
37/93/94 2
87/93/95 1
87/93/96 3
87/95/11 2
Stapelton - RFVeston, lac. 87/95/29 6
-------
.7/89 ''
TITLE
KID CO I
AUTHOR
DAT! PASES
Discussion of ground irater
lodelliog with Rlleston, lac.
He10 to Eater Co. re:
Perforuace of RP's »ita
listof changes to RI
Letter to Boice - USEPi re:
Hideo I Risk issesstent
Data Base
Telephone Conrersation vita
asm re fs
Ball - KRM
Constantelos - USEPi
Ball • IRS
Ball - ERM
Telephone Coorersatiooi Hideo Boice - OSEPi
Trustees agree to eralaate
alternatives to reiedf salt plate
Effect of Risk issessieat
issaiptioa and Alternatives
Letter to USEPi re:
Hideo I RI Report
Boice - OSEPi
Ball -
87/06/94 2
87/ei/17 58
87/96/18 21
87/96/24 3
87/96/29 1
87/96/29 S
87/97/97 1
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