United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
E PA/ROD/R05-89/095
June 1989
$EPA
Superfund
Record of Decision
Ninth Avenue Dump, IN
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50272-101
REPORT DOCUMENTATION 1. REPORT N
IX Type ol Report & Period Covered
800/000
14.
15. Supplementary NotM
IS. Abend (Limit: 200 worte)
The Ninth Avenue Dump is a 17-acre, inactive chemical and industrial waste disposal
site in Gary, Indiana. There is industrial, commerical, and residential development in
the surrounding area. There are approximately 60 industrial and residential water
supply wells within 1 mile of the site. Interconnecting ponds and wetlands areas border
ste disposal areas into the north, west, and south. The wetlands areas to the
and to the south of the site are relatively undisturbed. Hazardous waste disposal
ocurred at the site from the early to mid-1970s, with some filling associated with
cleanup activities continuing until 1980. Industrial, construction, demolition, and
chemical wastes were accepted at the site. Specific industrial wastes which were
accepted at the site include oil, paint, solvents and sludges, resins, and flammable,
caustic, and arsenic-contaminated materials. A State inspection in 1975 revealed that
there were approximately 10,000 55-gallon drums at the site. Additionally, the State
estimated that 500,000 gallons of liquid industrial waste were dumped, and 1,000 drums
were buried onsite and in contact with ground water. As a result of 1975 state orders
and 1980 EPA orders to initiate surface cleanup, the site operator removed drums, tank
cars, and some contaminated soil from the site's surface. The first Record of Decision
(ROD), signed in September 1988, addressed remediation of an oil layer floating on the
(See Attached Sheet)
IN
17. Document Analysis a. Descriptor*
Record of Decision - Ninth Avenue Dump,
Second Remedial Action - Final
Contaminated Media: soil, sediment, fill material, gw
Key Contaminants: VOCs (benzene, TCE, toluene), other organics (PAHs and PCBs),
metals (lead)
b. Idtntiaera/Opin-EnoM Term*
;OSATJ Field/Group
j^^pUbilty SUJemera
19. Security CUM (TW« Report)
None
20. Security CUM (Thie Page)
None
21. No. of P«ge»
80
22. Price
See ANS1-Z3J.18)
SM Instruction* on Rtvtnt
(Formerly NTIS-35)
Department of Commerce
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DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT
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16. Abstract Include a brief (200 worda or leaa) factual summary of the most significant Information contained In the report If the
report contains a significant bibliography or literature survey, mention It here.
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
that Identify the ma|or concept of the research and are sufficiently specific and precise to be used aa Index entries for cataloging.
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A GPO: 1983 0 - 381-526(8393) OPTIONAL FOHM 272 BACK
(4-77)
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EPA/ROD/R05-89/095
Ninth Avenue Dump, IN
Second Remedial Action - Final
5. Abstract (continued)
ground water surface and will include construction of a slurry wall around the
contaminated portion of the site and excavation and onsite storage of contaminated soil.
This second and final remedial action addresses the remaining threats to the site which
include contaminated soil, sediment, fill material, ground water (generally onsite), and
oil collected during the first operable unit. The primary contaminants of concern
affecting the soil, sediment, fill material, and ground water are VOCs including benzene,
TCE, and toluene; other organics including PAHs and PCBs; and metals including lead.
The selected remedial action for this site includes excavating approximately 36,000 yd3
of the most severely oil-contaminated waste and fill materials from the area inside the
slurry wall, onsite thermal treatment of excavated waste, fill, and previously extracted
oil, followed by filling the excavated area with incinerator and ground water treatment
process residues, discarded drums, contaminated sediment removed from on- and offsite
ponds, and trench spoils; covering the area contained by the slurry well with a RCRA cap;
pumping and treatment of ground water inside the slurry wall with reinjection of most of
the ground water within the slurry wall to promote soil flushing; pumping and treatment
of contaminated ground water outside the slurry wall with reinjection or discharge to
surface water; dismantling, decontaminating, and removing the oil storage unit
constructed under the first operable unit; continued long-term ground water monitoring;
air monitoring during remedial activities; and implementing institutional controls to
protect the site and restrict ground water use. The estimated present worth cost for
this remedial action is $22,209,000 which includes an annual O&M cost of $489,000.
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DECLARATION FCR THE RECCED OF DECISION
Ninth Avenue Dump
Gary, Indiana
OF BASTS AND HIRPDSE
This decision document represents the selected remedial action for the Ninth
Avenue Dump site developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) , as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA) , and to the
extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) .
This decision is based on the contents of the administrative record for the
Ninth Avenue Dump site. The attached index identifies the items which
comprise the administrative record upon which the selection of the remedial
action is based.
The State of Indiana is expected to concur with the selected remedy.
EON OF
This remedial action is the second and final of two operable units for the
site. The first operable unit addressed an oil layer floating on the
groundwater through oil extraction, storage, and containment with a
soil/bentonite slurry wall. The final remedy addresses all remaining threats
at the site, including contaminated soils, fill materials, stored oil,
groundwater, surface water and sediment.
The major components of the selected remedy include:
excavation of approximately 36,000 cubic yards of oil contaminated
waste and fill down to the native sand,
thermal treatment of excavated fill and extracted oil, most likely
in a mobile on-site incinerator,
removing debris and contaminated sediments from on- and off-site
surface water bodies,
filling the excavated area with treatment process residuals, trench
spoils and pond sediments and debris,
covering the area contained by the slurry wall with a RCRA Subtitle
C cap,
extraction, treatment and reinjection of contaminated groundwater
inside the slurry wall to promote soil flushing,
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discharge of a small quantity of groundwater outside the slurry
wall to compensate for infiltration,
deed and
is restrictions to prohibit use of groundwater under
the site and protect the cap, and
* long term groundwater monitoring.
EECTARATICN
The 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 (or resource recovery)
technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining on-site
above health based levels, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
Valdas V.
Regional
Region V
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KfcXJLKU OF DECISION SO-WARY
KDfDi AVENUE DUMP
I. SITE NAME, ICCATICN AND EESCRIPTTCN
Ninth Avenue Duirp is an inactive chemical and industrial waste disposal
site located at 7537 Ninth Avenue in Gary, Indiana (see Figure 1). The
site is a seventeen acre parcel in an area of mixed industrial,
commercial, and residential use approximately 1/8 mile east of Cline
Avenue.
Immediately surrounding the site are vacant, privately owned properties.
The property to the west is a lot where hazardous wastes were allegedly
buried. This property, referred to as the Ninth and Cline site, was
scored but not placed on the National Priorities List (NFL).
Approximately 1/4 mile south of the site is an NFL site, MIDGO I, and an
Indiana Department of Highways (IDOH) maintenance facility. A remedial
Investigation/Feasibility Study (RI/FS) is ongoing at MIDCO I, and the
Record of Decision will be oonpleted during the third quarter of 1989.
The nearest residential area is approximately 1/8 mile west of the site,
on the west side of Cline Avenue. The site is approximately 1/4 mile
south of the Grand Calumet River and 1 3/4 mile north of the Little
Calumet River.
Ninth Avenue Dump is located in a low-lying area with poor drainage.
Prior to filling, the site consisted of parallel ridges separated by
wetlands areas. Currently, the site is relatively flat with small
depressions and mounds remaining from waste disposal or cleanup
activities. Interconnected ponds and wetlands areas surround waste
disposal areas in the north, west and south. The wetlands areas to the
east and south of Ninth Avenue Dump are relatively undisturbed and serve
as habitat for fish, migratory birds, and other wildlife.
Figure 2 is a map showing existing site conditions. The only structures
currently on the site are a fence surrounding the contaminated area and a
fenced decontamination area including two 5,000 gallon water storage
tanks built during the RI/FS.
U. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Hazardous waste disposal occurred at the site from the early to mid
1970s, with some filling, believed to be associated with cleanup
activities, continuing until 1980. The site operator accepted dry
industrial, construction and demolition waste such as ashes, broken
concrete, bricks, trees, wood, tires, cardboard, paper and car
batteries. The site also received liquid industrial waste including
oil, paint solvents and sludges, resins, acids and other chemical wastes
including flammable, caustic and arsenic contaminated materials. A
small-scale auto wrecking operation had reportedly been observed at the
property.
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^T-ttfeJiSU'r^c^
^^CLDi-T^!7 -.•-v.~t»fes
•-•'"•-.MUNICIPAL
AIRPORT
APPROXIMATE PROPERTY??.
X-9TH & CLINE SITErr-
~ —• ^BOUNDARY OF 9TH AVENUEf
DUMP SITE ,/:!j jj:; FTS^
\. 'ii*,» i .-> :<..'j.C-'i ;a- •.• :r_^:..^!
II I x
-HAMMONDS
INDIANA
NOTE
SITE LOCATION MAP WAS REPRODUCED
FROM THE U.S.G.S. 7.5 MINUTE QUAD.
MAP. HIGHLAND. INDIANA, 1968, PHOTO
REVISED 1980. REFER TO STANDARD
U.S.G.S. TOPOGRAPHIC MAP SYMBOLS.
— APPROXIMATE
PROPERTY BOUNDARY nOfth
1- SCALE: 1" *
OWN SJP
C12912-AS
WARZYN
SITE LOCATION MAP
REMEDIAL INVESTIGATION
9TH AVENUE OUXP SUPERFUNO SITE
PART Of NW 1/4 Of SECTION 11. T36N. WW
CITY Of CART. LAKE COUNTY. INDIANA
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In 1975, the Indiana State Board of Health (ISBH) inspected the site.
The inspection documented the existence of approximately 10,000 55-
gallon drums at the surface, many of which were empty. Evidence was
also found that liquid wastes had been dumped on-site. A State
inspector estimated that approximately 500,000 gallons of liquid
industrial waste had been dumped and 1,000 drums had been buried on-
site. Subsequent inspections revealed portions of discarded auto
batteries, drummed liquid wastes and abandoned tanker trucks.
In 1975 and 1980, the site operator, Mr. Steve Martell, was ordered by
ISBH and the United States Environmental Protection Agency (EPA),
respectively, to initiate surface cleanups. In 1983, the site was
placed on the National Priorities List and a Partial Consent Judgement
was signed between U.S. EPA and Mr. Martell. The Consent Judgement
required Mr. Martell to evaluate surface and subsurface conditions and
submit a plan for remedial action. During this period, Mr. Martell
removed drums, tank cars and some contaminated soils from the surface of
the site. In early 1985, when Mr. Martell appeared to have insufficient
funds to perform the investigations required under the Consent
Judgement, U.S. EPA took over performance of the RI/FS.
In early 1988, Mr. Martell provided information on generators at the
Ninth Avenue site. Based on this information, General Notice Letters
were sent to approximately 240 potentially responsible parties (PRPs) on
^arch 9, 1988. Special Notice Letters for performance of the remedial
design/remedial action (RD/RA) for the first operable unit were sent to
approximately 180 PPJPs on July 9, 1988. When PRPs and U.S. EPA were
unable to negotiate a settlement, EPA issued a Unilateral Administrative
Order for the RD/PA on December 7, 1988. Approximately 75 PRPs agreed to
comply with the Order on January 13, 1989.
Special Notice Letters for the final remedy RD/RA were issued on
March 17, 1989. The deadline for receipt of a "good faith offer"
from the PRPs is May 26, 1989. A "good faith offer" was not
received by that date.
HI. CCMfJNnY RELATIONS fflSICRY
Public meetings have been held on August 13, 1986, July 13, 1988 and
March 29, 1989 to riica-»»ast RI/FS activities, the remedial alternatives
considered and the remedial alternative recommended by EPA. The
proposed plan and administrative record were made available to the public
on March 20, 1989, which marked the start of a 30-day public comment
period. Public comments and responses to those comments are contained in
the Responsiveness Summary (Appendix B).
IV. SCOPE AND ROLE OF THE UESKK& ACTION
This Record of Decision (ROD) addresses the second of two operable
bunits. The first operable unit ROD, signed on September 20, 1988,
addressed remediation of an oil layer floating on the groundwater
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surface. The first ROD called for pumping and storage of the oil layer,
construction of a slurry wall around the contaminated portion of the
site, limited groundwater treatment, and groundwater monitoring.
This ROD addresses the remaining threats at the site. These include
contaminated soils, sediments, fill materials, and groundwater, as well
as the oil collected under the first operable unit.
V. SITE CHARACTERISTICS
Waste And Soils
Buried wastes at the site include foundry sand, wood, concrete, bricks,
metals, slag, non-containerized liquids and sludges, and drummed liquid
and solid material. Raspri on test pit observations, it has been
estimated that 1,000 to 2,000 drums remain buried at the site. Depth of
fill ranges from approximately 0 to 10 feet. Due to the high ground-
water table (approximately 5 feet) , buried waste is in contact with the
groundwater. Test pit observations indicate that most of the filling
occurred in the central and southern portions of the site. Filling
appears to have stopped at the ponded area in the southern portion of the
site, where partially covered waste can be observed in the ponds.
Surface and subsurface soil contamination levels are summarized in
Appendix A. Soils show contamination with a variety of ke tones,
chlorinated ethanes, benzene, ethylbenzene, toluene and xylene (EETX) ,
polynuclear aromatic hydrocarbons (PAHs) , phenols, pesticides,
polychlorinated biphenyls (PCBs) , plasticizers and dioxins/furans.
Highest concentrations of organic contaminants were generally found in
the center of the site, which coincides with the location of the waste
disposal areas. Metals did not show any clearly defined spatial
patterns. Liquids in salvaged drums from test pits were also tested and
determined to contain the same contaminants found in waste and soil
samples.
\9at~ f*r and
On- and off -site surface water bodies did not show high levels of
contamination nor high frequency of detection. However, low levels of
volatile organic compounds (VOCs) , PAHs, pesticides, and metals were
found in the surface water and sediments. Appendix A contains a summary
of surface water and sediment data.
An oil layer is floating on the groundwater surface approximately five
feet below the ground. Observed oil layer thicknesses varied from 0.25
to 3.8 feet as measured in five on-site monitoring wells. The estimated
lateral extent of the oil layer covers approximately 30 to 50 percent of
the site area and enccnpasses the central and sooth central portions of
the site (see Figure 3). The quantity of oil under the site is estimated
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- 4 -
at 250,000 to 700,000 gallons, of which 100,000 to 500,000 gallons is
estimated to be recoverable. Analysis of oil samples indicate the
presence of chlorinated, hydrocarbons, PAHs, PCBs, as well as low levels
of dioxins and furans. Concentrations of contaminants are higher than in
any other medium and the oil appears to be a major source of groundwater
contamination. Analytical results for the oil layer are summarized in
Appendix A.
The shallow aquifer under the site is part of the Calumet Aquifer, which
consists of 30 feet of coarse sand and extends from the Little Calumet
River to lake Michigan. This is underlain by a 90 - 100 foot clay
aquitard. At the site, grcundwater is typically found within five feet
of the surface. Groundwater flow velocities are very slow due to the low
hydraulic gradient in the area, ranging from 0.27 feet per day (ft/day)
at the southern portion of the site to 0.02 ft/day near Ninth Avenue.
Groundwater flow is generally to the north, with ponds at the northwest
and northeast corners acting as local grcundwater discharge areas.
Discharge to leaky sewers also influences local grcundwater flow. A
Hammond sewer line approximately 1000 feet east of the site appears to
act as a local point of grcundwater discharge. Surface water discharge
to a City of Gary sewer approximately 700 feet west of the site also
affects surface water and grcundwater flow. A July 1987 water table map
is shown in Figure 4.
The shallow water table and permeable soils makes the Calumet Aquifer
highly susceptible to contamination from the numerous industrial sources
in the area. Preliminary data collected in a survey of the area by the
United States Geological Survey (USGS) indicate that low levels of
phenols, benzene, and toluene and high total dissolved solids occur in
several areas, especially downgradient of steel or petrochemical
industries.
Groundwater under the site is contaminated with approximately 100
organic and inorganic compounds including many of the compounds found in
the oil layer (see Appendix A). Concentrations were as high as 2,300,000
ug/1 total VOCs. Because of the low gradients in the area, grcundwater
contamination has not, for the most part, migrated beyond the site
boundaries, except on the eastern side of the site. A typical
isoconcentration map of groundwater contaminants is shown in Figure 5.
Groundwater contamination on-site is complicated by a plume of high
dissolved solids at the bottom of the aquifer from an off-site source.
Chloride concentrations were as high as 16,000 mg/1 immediately
upgradient (south) of the site and decreased to approximately 100 mg/1
to the north of the site. Based on this finding, a limited off-site
grcundwater investigation was done at the IDOH facility to the south of
the site, where chloride concentrations as high as 46,000 mg/1 were
found. An isoconcentration map of chlorides at the bottom of the
aquifer is shown in Figure 6.
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FIGURE 4
Water Table Map
July 7, 1987
SCALE IN FEET
0 100 200 400
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FIGURE 6
|£ Chloride Isoconcentration Map
o Deep Mel Is
SCALE IN FEET
0 100 200 40(
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- 5 -
VI. SLM4ABY OF STIE RISKS
Although the interim remedy mandated in the first operable unit ROD has
not yet been implemented, this section will describe the risks remaining
after implementation of the interim remedy, as well as the baseline risk
assessment. A summary of the baseline risk assessment is presented in
Table 1 and a summary of the risks remaining after implementation of the
interim remedy is presented in Table 2.
of Pajg<»1 jne
The current use scenario showed carcinogenic risks as high as 1.5xlO~2
for trespassers on the site, mainly due to dermal contact with
contaminated surface soils. C3ontaminants contributing to the majority of
this risk are PCBs and PAHs. The site was fenced in 1987 to protect
nearby residents from contact with surface soils, however, several holes
have been cut in the fence and trespassing remains a persistent problem.
There are approximately 60 industrial and residential water supply wells
within one mile of the site. However, none of the wells currently in
use are affected by groundwater contamination at the site. The majority
of residents in this area receive City of Gary or Hammond water, which is
drawn from Lake Michigan. Thus, there is no risk due to groundwater use
under the current use scenario.
No significant risk to human health due to contact with surface water
was found in the risk assessment, however, some metals and pesticides
exceeded federal Ambient Water Quality Criteria (AW2C) , indicating
potential harm to aquatic life (see Appendix A and Figure 7) .
To determine the potential for contaminants in sediments to migrate to
surface water and affect aquatic life, an equilibrium partitioning
approach was used. This approach predicts contaminant concentrations in
interstitial waters using the sediment contaminant concentrations and
organic carbon content, and the organic carbon partition coefficient of
the contaminant which are then compared to AWQC. Based on this approach,
it appears that some sediments may affect aquatic life due to
contamination with PCBs and chlordane (see Appendix A) .
The future use scenario assumed no action would be taken to restrict
access and the site is developed for residential use. If the groundwater
under the site were used for drinking and other household uses, users
would be exposed to an extremely high carcinogenic risk (greater than 1)
and noncarcinogenic risk (hazard index as high as 3000) . PAHs, PCBs,
benzene, trichloroethylene, and lead are major contributors to this risk.
Future residents would also be exposed to a high carcinogenic risk due
to ingestion and dermal contact with surface soils (carcinogenic risk as
high as 8 x 10~2) . In addition, sediment analytical data were compared
to future use risk scenarios for surface soils, since this approach was
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Medium
TRBLE 1
SLMBRY OF BASELINE RISK ASSESSMENT
Pathway Carcinogenic Risk *
Max Mean
Ncncarcinogenic Risk *
(Chronic Hazard Index)
Max Mean
CLiKKUfT USE
Oil Phase Inhalation 5.9X1C
Soils Ingestion 8.8xlO
Soils Dermal l.SxlO
~5
"2
3.2X10"6
4.3xlO~6
7.5xlO~4
RTUJKE USE ON-sni:
(assumes residential use of site)
Oil Phase
Grcundwater
Groundwater
Grcundwater
Soils
Soils
Inhalation
Ingestion
Dermal
Inhalation
Ingestion
Dermal
5.2.10
'5
>1
2xlO
1.4xlO
8.0xlO
~2
~3
~2
FU1UHE USE OFF—til'ltl
(assumes residential use of adjacent property)
Groundwater Ingestion
2.3xlO~4
<1
<1
755
<1
<1
<1
3.2X10'5
1.6X10"1
1.6X10'1
2.1X10~4
7.2X10~5
3.9xlO~3
<1
3000
29
1.8
<1
<1
62
1
_
_
.
* Risk calculation are based on the following indicator chemicals: benzene,
toluene, trichlorethylene> cresols, PAHs, bis (2-ethylhexyl)phthalate,
heptachlor, PCBs, nickel, lead, salt.
-------
TABLE 2
SGMMARY OF RISKS REMAINING AFTER IMPLEMENTATION
OF THE INTERIM REMEDY (ASSUMING FUTORE RESUHfTIAL USE OF SITE)
Medium Carcinogenic Risk * Ncrxarcinogenic Risk
Max Mean (Hazard Index)
AREA INSIEE STJJRRY WATT.
Groundwater > 1 4.3X1CT1 < 1
Soils 4.5xlO~3 < 1
AREA OUISIEE SUJRRY WATT.
Groundwater (SE corner) > 1 < 1
Groundwater (all other areas) 4.3xlO~5 < 1
Soils Below 10"7 carcinogenic risk or
less than background
* Risk calculations are based on the following indicator chemicals:
benzene, trichlorethylene, vinyl chloride, chloro-benzene, toluene, bis(2-
ethylhexyl)phthalate, PAHs, heptachlor, PCBs, arsenic, and lead.
-------
J CHROMIUM 110
VINYL CHLORIDE 100
ft - BHC .05
HEPTACHLOH 17
ARSENIC 6.1
LEAD590
NICKEL 54
" CYANIDE 20
- BHC .04
p - BHC 13
« - BHC 14
* --BHC .07
- BHC ?0
ARSENIC 11
HEPTACHLOR .06
HEPTACHLOR
EPOXIDE .05
' NICKEL 150
-•' / .
LEGEND
CD
O
A *««
•04
m
APPROIIHA1C PROPCRir (OUMOMI
fONDS AM) SKMOINC UA1IR
UNSURFACCO ACCESS ROW)
CHAIN UNX rCKt
IUUDINGS
IRtCS OR IRUSN
SURFACE MATH AND SfOIWNI SAWIING
IOCAIIM AND MMC*
STAFF CACf IOUIION AM) MMF.R
DRAINAU ARU ULIMAIION IINE
ORAINACC ARU DISICNAIICM
NOTES
I. All CONCCNIRAIIONS AH IN u)/1.
1. ROUND I SURFACE MIC* AM) SIOINCNT SAmtS COUICHO It WMIIN
tWINdRINC INC. Al IOCAIIONS SW/SO-I IHBOUCH SW/SO-I« FROM
OCIOBCR 14 10 OCIOSIR 16. I9S6. IOCAIIONS ARC ArPROIIHAII AM)
ARC (ASIO ON SAMFUNG CRU FIIID NOUS.
1. ROUND I SURFACC WAICR SAMPIIS WtRt COLLICICO If WARMN
INCINItRINC INC. Al IOCAIIONS SW?. SM3. SW6. SW9 IHROUGH SWI1.
swis. AND sw;o imoucH s«; FROM JUKI a-io. na;. IKAIIONS
ARE APPROIIMAIC.
4. SIAFF CAGES WERE FIELD IOCAIED tl UARIfN ENGINEERING INC.
SURVEtORS ON KAI 6. I 996 ANO JUNE 29, I96/.
FIGURE 7
Surface Water Constituents
Exceeding Water Quality Standards
Round 1
SCALE IN FEET
0 100 200 400
-------
.; , SW20 , ,
! '. 00''
ui c
in tj-
i: I' O* I
SOS CM
ro
CO
:c
Q-
m
•M
o
. . v • v
••M'f ', ^ •- *
i',\
•. (
.,!' i .
r
,lf
r'
^i ."' Q>^
_.« • * . ^—' _
•r; ^=r^ifUL^i
.i^vr^ff;^,!
^^^^±i^-.JrfUj-JJ2a/Xi .. i ' AV* / ¥
••i i ..: , it .
FIGURE 8
Sediment Sampling Locations
Exceeding Background or Human Health Criteria (ug/
SCALE IN FEET
0 100 200 400
-------
- 6 -
used at the nearby Midco I site. Sediments exceed background levels or
1 x 10"6 carcinogenic risk for PAHs, PCBs and pesticides. Sampling
locations where sediments exceeded these criteria are shown in Figure 8.
Groundwater modeling conducted during the RI showed the nearest
residential users (approximately one half mile east of the site) will
not be affected by site contaminants in 70 years. However, users of the
adjacent property to the east would be exposed to carcinogenic and
noncarcinogenic risks if this property were developed for residential
use in the future. (A family lived on this property until the early
1980's) . Also, contaminants have migrated from groundwater to nearby
ponds and would continue to do so if groundwater contamination was not
Aft'***' Trnplnnt'iilgf JOO Of the
Implementation of the interim remedy will reduce risks due to inhalation
of volatiles from the oil phase floating on the groundwater by pumping
out the oil that will flow. The oil phase will be surrounded by a slurry
wall which will contain the oil and limit migration of contaminants in
the oil and groundwater.
Implementation of the interim remedy in effect divides the site risks
into three areas: 1) groundwater, oil remaining after extraction, and
soils inside the slurry wall; 2) groundwater, soils, surface water and
sediments outside the slurry wall; and 3) oil extracted and stored on-
site.
Table 2 shows the risks remaining inside the slurry wall , assuming
future residential use. Although the slurry wall will limit migration
of contaminants, carcinogenic risk due to ingestion of groundwater and
soils inside the slurry wall would remain high. Risk calculations
assumed that 45% of the oil would remain after extraction.
Risk calculations for the area outside the slurry wall show that most of
the contaminated soils will be enclosed by the slurry wall, leaving a
minimal risk in areas outside the wall (below 10~7 carcinogenic risk or
less than background) . However, contaminated surface soils within the
slurry wall area will remain exposed to trespassers after jjjplementation
of the interim remedy.
Because the primary purpose of the slurry wall is to contain the oil
phase, some contaminated groundwater will remain outside the wall.
Risks due to use of the groundwater at the southeast comer of the wall
will be nearly as high as for the water inside the slurry wall .
Carcinogenic risk is considerably lower in all other areas; the maximum
calculated risk was 4.3 x 10~5, due to low levels of benzene in the
groundwater. A summary of the risk calculation is presented in Table 2.
The interim remedy will also leave some residual risk due to on-site
storage of the extracted oil. This risk was not quantified, but would
be high only if the storage tanks leaked or spillage occurred.
-------
- 7 -
VU. CESCRIFnCN OF AUIEPNATIVES
Based en the analysis of contamination and associated risks at the Ninth
Avenue Dump site, the following response objectives were identified for
the final remedy:
* treat or dispose of oil collected and stored during imple-
mentation of the interim remedy,
reduce or eliminate direct contact with and erosion of
contaminated surface soils,
reduce or eliminate direct contact with and releases to
groundwater from contaminants in waste and subsurface soils ,
reduce or eliminate off-site migration of contaminated
groundwater and discharge of contaminants from groundwater to
surface water,
reduce or eliminate migration of contaminants from soils and
groundwater to surface water and sediments, and remove
contaminated sediments, discarded drums and other debris from
ponds.
Six alternatives were developed to address these response objectives.
Elements common to these alternatives are described below, followed by a
section describing each alternative separately.
O 11*1* • \ t*f> JV1 1
All alternatives assume implementation of the interim remedy, including
the following elements: a soil/bentonite slurry wall surrounding the oil
contaminated portion of the site (see Figure 3) , oil extraction and
storage, groundwater monitoring, and treatment and discharge of enough
groundwater to compensate for infiltration inside the wall.
All alternatives, with the exception of No Action, have the following
elements in common:
thermal destruction of the oil extracted and stored on-site
under the first operable unit, either by on- or off -site
incineration in compliance with RCRA and TSCA regulations,
dismantling, decontaminating, and removing the oil storage
tanks described in the interim remedy ROD,
removal and disposal of contaminated sediments, discarded
drums and other debris from on-site ponds, and trench spoils
from slurry wall construction by placing materials under the
-------
- 8 -
cap or soil cover. If materials are oil contaminated, they
will be disposed of by thermal destruction in compliance with
RCRA and TSCA regulations,
placing deed and access restrictions on the site to ensure
protection of the cap and soil cover and to prohibit use of
groundwater under the site,
monitoring air quality during excavation, handling, and
treatment of waste, fill or soils and groundwater treatment.
Corrective action will be implemented if air emissions exceed l
x lO"6 cumulative carcinogenic risk or a hazard index of 1 at
the site boundary.
extraction and treatment of contaminated groundwater outside
the slurry wall in areas exceeding MCLs and 10~5 cumulative
carcinogenic risk, whichever is more stringent,
continued use of the groundwater monitoring system required
under the first operable unit and upgrade of the system, if
necessary, to ensure that aquifer remediation goals are
maintained outside the slurry wall, and
continued groundwater treatment and discharge outside of the
slurry wall to the extent necessary to compensate for
infiltration. Treated water will be discharged by 1)
reinjection to the shallow aquifer outside the slurry wall, 2)
discharge to on-site surface water in accordance with NPDES
standards, or 3) discharge in a deep injection well in
accordance with EPA Underground Injection Control (UIC)
regulations.
All alternatives including direct groundwater treatment have the
following options: 1) no salt treatment, 2) treatment of all extracted
groundwater for salt, and 3) treatment for salt only to the extent
necessary to ensure that the salt migration is not exacerbated by the
remedy.
Alternative 1; No Action
Under this alternative, no action would be taken other than
implementation of the interim remedy. Recovered oil would remain stored
on-site, and although contaminant migration in groundwater would be
limited by the slurry wall, the potential for exposure to contaminated
materials on-site would remain. Risks associated with this alternative
are described in Section VT.
-------
- 9 -
Alternative 2 involves source control through containment without
treatment, except for treatment of the oil extracted under the first.
operable unit. Two options are included under this alternative: 2A
includes groundwater extraction and treatment within the slurry wall
only to the extent necessary to compensate for infiltration, while 2B
includes extraction, treatment and reinjection of groundwater within the
slurry wall. These options include the following elements, in addition
to those described previously:
Alternative 2A
Grading and capping the area within the slurry wall with a
multilayer cap in compliance with RCFA Subtitle C regulations,
and
Continued use of the groundwater extraction and treatment
system required under the first operable unit.
Alternative 2B
Extraction, treatment and reinjection of contaminated
groundwater within the slurry wall. The reinjection system
would be designed to allow treated water to flow through
contaminated soils and promote soil flushing. The goal of the
groundwater treatment system would be to reduce contaminant
levels to MCLs or 10~5 cumulative carcinogenic risk, whichever
is more stringent, but the effectiveness of the remedy would
be dependant on the ability of the flushing to remove source
contaminants. It is not certain whether 10~5 cumulative
carcinogenic risk could be achieved under this alternative.
Grading and capping the area within the slurry wall with a
multilayer cap in compliance with RCRA Subtitle C regulations.
It is estimated that the elements in Alternative 2 can be constructed in
less than 2 years, but maintenance pumping and groundwater monitoring
will continue indefinitely. The groundwater treatanent and reinjection
system under Alternative 2B would probably be in operation for more than
10 years.
Costs, as shown in Table 3, are dependant on the level of salt treatment
in groundwater. Costs were developed for remediation of groundwater
without salt treatment, and with salt treatment to 250 mg/1 chloride
(the secondary MCL).
-------
- 10 -
This alternative relies primarily on excavation and treatment of
contaminant source materials by thermal destruction. Although the
possibility of transport to an off-site incinerator has not been
excluded, on-site incineration is considered a more likely option due to
the large volume of waste and soil to be destroyed. Three volumes of
waste and soil excavation were considered, as described below and as
shown in Figure 9.
Alternative 3A: (Figure 9, Scenario A) involves removal of contaminated
waste and fill within the boundaries of the containment barrier. Waste
would be excavated until native soils are encountered. The maximum depth
of excavation is estimated at 10 feet and the volume of materials to be
excavated is estimated to be 70,000 cubic yards.
Alternative 3B: (Figure 9, Scenario B) involves removal of contaminated
waste and fill material and oil contaminated native soils within the
containment barrier. Based on test pits and boring logs, it is estimated
that native soils have been contaminated by the oil layer to an elevation
of approximately 590 feet (USGS datum). The maximum depth of excavation
is estimated to be 12 feet. The total volume of materials to be
excavated is estimated at 100,000 cubic yards.
Alternative 3C: (Figure 9, Scenario C) is a "hot spot" remediation
scenario, involving removal of only the most highly contaminated waste
and fill materials. Surface soils and oily fill materials within the
estimated extent of the oil layer would be excavated until native soils
are encountered. The maximum excavation depth is estimated at 10 feet
and the volume of fill to be excavated is estimated at 36,000 cubic
yards.
Alternative 3 includes the following elements, in addition to those
described previously:
Excavated materials would be incinerated in accordance with
RCRA and TSCA regulations. This will roost likely be done using
a mobile incinerator on-site.
Trench spoils, pond debris, and sediments showing high levels
of oil contamination would also be incinerated.
Residuals from on-site treatment processes, less contaminated
sediments, pond debris and trench spoils from slurry wall
construction would be disposed of in the excavated area.
Grading and capping the area inside the slurry wall. The cap
specifications will be dependant on the level of excavation
chosen and the nature of process residuals. Scenarios A and B
will not likely require a RCRA Subtitle C compliant cap unless
-------
•CRETE 3
SCMORY OF ESTIMATED COSTS
OF AI3IENATIVES
C&pital Cost Annual O&M Present
Net Worth
Alternative 1 $ 0 $ 0 $ 0
Alternative 2
A. Limited groundwater treatment
1. with no salt treatment $ 5,720,000 $ 95,000 $ 6,529,000
2. with salt treatment $ 5,807,000 $ 133,000 $ 6,931,000
B. With grcundwater treatment
1. with no salt treatment $ 7,441,000 $ 439,000 $11,178,000
2. with salt treatment $ 7,528,000 $1,258,000 $18,238,000
A. Excavate 70,000 cy
1. with salt treatment $28,943,000 $1,258,000 $39,653,000
2. with no salt treatment $28,856,000 $ 439,000 $32,593,000
3. with limited salt treatment $28,943,000 $ 489,000 $33,104,000
B. Excavate 100,000 cy
1. with salt treatment $38,558,000 $1,258,000 $49,268,000
2. with no salt treatment $38,471,000 $ 439,000 $42,208,000
3. with limited salt treatanent $38,558,000 $ 489,000 $42,718,000
C. Excavate 36,000 cy
1. with salt treatment $18,048,000 $1,258,000 $28,758,000
2. with no salt treatment $17,961,000 $ 439,000 $21,698,000
3. with limited salt treatment $18,048,000 $ 489,000 $22,209,000
Alternative 4
A. Excavate 70,000 cy
1. with no salt treatment $27,151,000 $ 232,000 $29,126,000
2. with limited salt treatment $27,238,000 $ 270,000 $29,537,000
3. with limited groundwater treatment $27,137,000 $ 95,000 $27,946,000
B. Excavate 100,000 cy
1. with no salt treatment $36,765,000 $ 232,000 $38,740,000
2. with limited salt treatment $36,852,000 $ 270,000 $39,151,000
3. with limited groundwater treatment $36,750,000 $ 95,000 $37,559,000
C. Excavate 36,000 cy
1. with no salt treatment $16,257,000 $ 232,000 $18,232,000
2. with limited salt treatment $16,344,000 $ 270,000 $18,643,000
3. with limited groundwater treatment $16,241,000 $ 95,000 $17,050,000
-------
TAEI£ 3 (Con't)
SOMVRX OF ESTIMATED COSTS
OF AI3HRNAHVES
1. with salt treatment
2. with no salt treatment
3. with limited salt treatment
Alternative 6
1. with no salt treatment
2. with limited salt treatment
Capital o»~>
$71,891,000
$71,804,000
$71,891,000
Annual OfiM
$1,236,000
$ 439,000
$ 489,000
Present
Net Worth
$82,644,000
$75,541,000
$76, 052 , 000
$70,099,000 $ 232,000
$70,186,000 $ 270,000
$72,024,000
$72,485,000
"Salt treatment" - cost estimates include treatment of all groundwater for
salt by reverse osmosis to 250 mg/1 chloride. .
"Limited salt treatment" - cost estimates include treatment of groundwater
to be discharged inside the slurry wall by reverse osmosis to 250 mg/1.
chloride.
nt" — cost estimates include continued use of
•'Limited groundwater trea
the groundwater treatment system required under the first operable unit POD
only.
-------
•Floating
Oil Layer
j— Hecnargey-waier A—
/ Trench / Table /
f
Existing
Grade
• —• — jr*-*r*ssr4fjr^f~ jv&*r*r~ —--•
•Slurry ^ Extent of
Wall Oil
Contamination
^
NATIVE
| SOILS
Scenario A - CROSS HATCHED AREA TO BE EXCAVATED
•Recharge/-Water
Trench / Table
e/-water y—Floating ^
I Table / Oil Layer /
Existing
Grade
Extent of
Oil
Contamination
Scenario B • CROSS HATCHED AREA TO BE EXCAVATED
r Recharge/-Water
Trench / Table
i— Floating i~
I Oil Layer /
Existing
Grade
NATIVE
SOILS
•Slurry
Wall
•Extent of
Oil
Contamination
Scenario C - CROSS HATCHED AREA TO BE EXCAVATED
5 ICXVN
A8
WABZYN
Eicavatlon Scenario Seh»m«llc«
FIGURE 9
-------
- 11 -
process residuals are determined to be RCRA hazardous. Since
Scenario C addresses only the most contaminated materials, a
RCRA Subtitle C compliant multilayer cap would be required for
this option.
• Extraction and on-site treatment of groundwater inside the
slurry wall. Treated groundwater would be reinjected to the
area inside the slurry wall to promote flushing of remaining
contaminants from soils. Some treated water would be
discharged outside the slurry wall to compensate for
infiltration, as described previously. The aquifer
remediation goal is MQ.fi or 10~5 cumulative carcinogenic risk,
whichever is more stringent.
Construction of on-site treatment facilities, excavation and incineration
of soil may take up to 5 years. Groundwater treatment will likely
continue for more than 10 years and maintenance pumping and groundwater
monitoring will continue indefinitely.
Alternative 3 costs are given in Table 3. Costs are dependant on the
level of soil excavation and the level of salt treatment.
with
itii
The waste and soil components of Alternative 4 are the same as those in
Alternative 3. This alternative includes the same three levels of soil
excavation as Alternative 3. However, in this alternative, groundwater
will be treated in-situ inside the slurry wall by bioreclamation or
chemical oxidation. A limited amount of groundwater would be extracted,
treated and discharged outside the slurry wall to compensate for
infiltration, as described previously.
Because in-situ groundwater treatment methods would not likely be as
effective for some of the contaminants at Ninth Avenue Dump, such as
vinyl chloride and heptachlor epoxide, it is estimated in the FS that
this remedy is not likely to achieve a less than 10~3 cumulative
carcinogenic risk level in groundwater.
Time for implementation of the waste and soil components of Alternative
4 are the same as those for Alternative 3. Groundwater treatment to
achieve a 10~3 carcinogenic risk level will take greater than 20 years.
Groundwater monitoring and maintenance pumping will continue
indefinitely.
Costs for Alternative 4 are presented in Table 3.
*r Extraction and
Under this alternative, contaminated waste, fill and soils would be
treated by in-situ vitrification (ISV) to a depth of approximately 12
-------
- 12 -
feet. Grcundwater would be extracted and treated by the method
presented in Alternative 3.
In the ISV process, large electrodes are placed in boreholes around the
area to be treated. A hood is placed over the area to collect off-
gasses. An electric current is applied, causing the soil to melt.
Organic contaminants and metals are thermally decomposed, volatilized,
or immobilized in the vitrified material. The final result is an
obsidian like mass.
Components of this alternative, other than those described previously
are as follows:
• treatment of all contaminated waste and native soils by in-
situ vitrification, to a depth of approximately 12 feet,
covering the vitrified area with a soil cover, and
groundwater extraction and treatment by the method described
in Alternative 3.
The source control components of this- alternative will take
approximately 5 years to complete, while groundwater treatment will
require in excess of 10 years. Groundwater monitoring will continue
indefinitely.
Costs for Alternative 5 are presented in Table 3.
6; In— situ Sr«rnoe TreatTt With In—situ
The source control components of Alternative 6 are the same as
Alternative 5, while the groundwater treatment components are the same
as those in Alternative 4. Contaminated waste, soil and debris would be
treated to a depth of approximately 12 feet by ISV, and then covered
with a soil cover. Groundwater would be treated in-situ by
bioreclamation or chemical oxidation.
The source control components will take approximately 5 years to
complete, while groundwater treatment will take in excess of 10 years to
meet a 10"3 carcinogenic risk level.
Costs for Alternative 6 are presented in Table 3 .
VUI. SUMARY OF THE COMPARATIVE ANALYSIS
The nine criteria used by EPA to evaluate remedial alternatives include:
overall protection of human health and the environment; compliance with
applicable, or relevant and appropriate, requirements (ARARs) ; long-term
effectiveness; reduction of toxicity, mobility, or volume; short-term
effectiveness; implementability; cost; state acceptance; and community
-------
'- 13 -
aooeptance. Based an evaluation of the alternatives with respect to the
nine criteria, EPA has selected Alternative 3C - "Hot Spot" remediation of
oil contaminated waste and soils, with groundwater extraction and
treatment - as the preferred alternative for the Ninth Avenue Durrp final
remedy.
Protec*"ion of i*Tmap Tfc^lth and the
Alternatives 3 and 5 achieve protection of human health and the
environment by addressing the three primary sources of risk: contaminated
soils and buried wastes, contaminated groundwater, and the oil collected in
the first phase and stored on-site. Alternative 1 provides no further
current or future protection over that provided by the interim remedy, as
described in Section VI. Alternative 2 limits exposure by capping and
institutional controls, and is protective as long as the remedy is
maintained. Alternatives 4 and 6 provide similar protection to
Alternatives 3 and 5, however, these alternatives offer slightly lower
overall protection due to the limitations of in-situ groundwater treatment
technologies.
Compliance With Applicable, or P**Tevant and AHJIUUI. 'at~i"*Tiii'tv. or
Alternatives 3 and 5 provide the best levels of reduction of toxicity,
mobility, and volume (TMV) of contaminants in oil, soils, waste and
-------
TABLE 4
Probable ARARs or TBCs
Ninth Avenue Dump
Probable ARAR (or TBC)
Purpose
RequireBcnt*
CHEHICAL-SPECIFIC ARARs
Safe Drinking Uatcr Act (SDUA)
Groundwater MCLs Protection of public drinking Miter supplies.
Maximum contaminant
level goals
Protection of public drinking water
supplies.
Resource Conservation and Recovery Act (RCRA)
40 CFR Part 264
Subpart F:
Releases froa solid
waste management units
Clean Water Act (CUA)
40 CFR Part 122,
125. National
Pollutant Discharge
Elimination System (NPOES)
Ambient Uater Quality
Criteria (AUQC)
Sets groundwater protection standards
for releases from RCRA regulated facilities.
Protection of surface water fro* discharge
of pollutants.
National criteria for protection of surface
water.
Indiana Uater Quality Standards
330 IAC 1-1-6 Uater
Quality Standards
327 IAC 2-1-6 Proposed
Uater Quality Standards
330 IAC 1-1-7 Standards
for Underground Uaters
Protection of State surface waters
Protection of State surface waters
Protection of State underground waters
Public water system supplying at least 25 individuals
Rust Meet HCLs.
Sets nonenforceable health goals for public water
supplies.
Groundwater Bust Beet RCRA HCLs at the downgradient edge
of the waste aanageaent unit. Alternate concentration
Halts (ACLs) can be set under limited circumstances.
Requires States to establish pernit programs for
discharge of pollutants to surface water.
AUQC are national guidelines intended to assist States
in setting surface water quality protection standards.
Sets descriptive water quality standards.
Proposed quantitative water qualtiy standards for
surface waters of the State.
Requires underground waters to Beet minimum water
quality conditions for potable or industrial use.
-------
TABLE 4 (p 2 of 4)
Probable ARARs or TBCs
Ninth Avenue .Dump.
Probable ARAR for JBC)
Purpose
Requirements^
LOCATION-SPECIFIC ARARs
Executive Order 119.0:
Protection of Wetlands
Fish and Wildlife
Coordination Act
Clean Uater Act (CUA)
40 CFR Part 230:
Guidelines for disposal
of dredged or fill
material
Avoid short* and long-term adverse effects
caused by Federal actions in wetland
areas.
Protection of fish and wildlife when Federal
actions result in the control or structural
modification of a natural body of water
Establishes guidelines for review of permits
for discharge of dredged or fill Material
into aquatic environments.
Agencies are required to avoid enqaging in or assisting
with new construction in a wetland area unless there is
no practicable alternative and every attempt is made to
mitigate adverse Impacts.
Federal agencies must take into consideration the effect
water related projects would have on fish and wildlife.
Coordination with USFWS is required.
Prohibits discharge of dredged or fill material where
there Is a practicable alternative and requires
minimization of impact to aquatic ecosystems.
Hay require mitigation of unavoidable filling.
ACTION-SPECIFIC ARARs
Resource Conservation Recovery Act (RCRA)
40 CFR Part 261:
Identification and
listing of hazardous
waste
40 CFR Part 262:
Standards for generators
of hazardous waste
40 CFR Part 263:
Standards for trans-
porters of hazardous
waste
40 CFR Part 264:
Standards for owners and
operators of hazardous
waste treatment, storage
and disposal facilities.
Defines wastes subject to regulation under
RCRA
Establishes standards for generators of
hazardous waste
Establishes standards for transporters of
hazardous waste.
Establishes standards for the acceptable
management of hazardous waste.
Wastes are subject to regulation under RCRA if: 1) Wastes
are ignitable, corrosive, reactive or EP toxic; 2) Wastes
are listed as hazardous; 3) Wastes as mixtures listed as
hazardous.
Requires identification of waste generation activity,
obtaining an EPA ID number, manifesting and record
keeping.
Transport of hazardous waste is subject to DOT
regulations as well as manifesting, record keeping and
discharge cleanup requirements.
-------
TABLE 4 (p 3 of 4)
Probable ARARs or TBCs
Ninth Avenue Dump
Probable ARAR (or TDC)
Purpose
Requirements
Subpart J:
Tanks
Subpart 0:
Incinerators
land Ban
40 CFR Part 268:
Land Disposal
restrictions
Establishes standards for tanks used to
treat or store hazardous waste.
Establishes standards for incineration of
haiardous waste
Identifies hazardous wastes prohibited
fron land disposal.
Toxic Substances Control Act (TSCA)
40 CFR Part 761:
PCB use prohibitions
Subpart 0:
Storage and disposal
Establishes prohibitions and requirements
for the use, disposal, storage, labeling and
recordkeeping of PCB-contaminated materials.
Establishes requirements for storage and
disposal of Materials containing Pcfls
based on concentration.
Subpart G:
PCB spill cleanup
policy
Establishes cleanup action levels for
PCB spills based on amount spilled and
location of spill.
Safe Drinking Uater Act (SUPA)
40 CFR Part 144:
Underground injection
control program
Clean Air Act (CAA)
40 CFR 50:
National ambient air
quality standards
Establishes minimum requirements for
underground injection of waste.
Sets national primary and secondary air
standards to protect public health and the
environment.
Requirements for design, operation, inspection, and
closure of tanks.
Requires destruction and removal efficiency (ORE) of
99.99% for each principal organic haiardous constituent
and 99.9999% ORE for PCBs.
Prohibits land disposal and establishes treatment
standards for haiardous waste, including solvents and
dioxins. Dioxins at extract concentrations > I ppb
•ust be treated by incineration or equivalent technology.
Time frame established for land disposal restrictions.
Storage: Provides structural requirements, SPCC plan, and
Inspection requirements for storage of items containing
50 ppm or greater PCBs.
Disposal: Liquids containing PCBs at concentrations > 500
BBi luTT be incinerated. Liquids and solids containing
PCBs at concentrations > 50 ppm must either be landfilted.
incinerated or destroyed in a high-efficiency boiler.
Provides performance requirements.
Requires cleanup of spills of materials containing greater
than 50 ppm PCBs. Specifies clean up levels based on
location of spill.
Requirements based on classification of well. Wells
injecting treated contaminated water into the aquifer
from which it was drawn are Class IV. These are
prohibited except for CERCLA or RCRA cleanups.
Construction plans of new sources of air pollutants
must be reviewed by State to determine whether best
available control technology will lie required.
-------
TAliLE 4 (p 4 of 4)
Probable ARARs or TBCs
Ninth Avenue Dump
Probable AflAR (or JBC)
Purpose
Requirements
Section 111 of CAA:
New source performance
standards
Section 112 of CAA:
National Cnissions
Standards for Hazardous
Air Pollutants
Insures new stationary sources will reduce
emissions to a minimum.
Establishes emissions standards for
hazardous air pollutants.
Occupational Safety and Health Act (OSHA)
29 CFR {910:
Regulations for workers
involved in hazardous
Materials
Ensures safety of workers at hazardous
waste operations.
Hazardous Materials Transportation Act
49 CFR 100-199:
Transportation of
Hazardous Materials
State ARARs
325 IAC 6-4:
Fugitive dust
325 IAC 8-1.1-2
325 IAC 8-1.1-6
VOC Emissions
330 IAC 5-2-2
320 IAC 4.1-54
320.IAC 4.1-53-6(a)
13436.30
HSR/jpl/OLI
[jpl-602-31k]
Ensures safe transportation of hazardous
•aterials.
Protect against fugitive dust emissions
during construction
Regulates VOC emissions.
Regulates treatment facility effluent.
Regulates incinerator operation.
Provides standards for con: truetion of
hazardous landfill cap.
Promulgates standards for classes of stationary sources
including Incinerators.
Emissions standards established by source. No standards
for incinerators.
Regulates training, protective equipment, proper
handling of waste, personnel monitoring, and emergency
procedures for hazardous waste workers.
Requirements for labelling, packaging, shipping.
manifesting, and transport of hazardous materials.
Requires every available precaution be taken during
construction to minimize fugitive dust emissions.
Requires new sources to reduce VOC emissions using
Best Available Control Technology, if emissions are
> 25 tons/year.
An NPOES permit must be obtained for discharge to a
surface water body.
Hust obtain thermal destruction efficiencies of
contaminants in excess of 99.99% for principal organic
hazardous constituents (POHC).
Final cover must be designed to provide long-term
integrity with minimal maintenance.
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- 14 -
groundwater. Alternative 1 provides no reduction in TMV. Alternative 2
would reduce TMV for the oil, but provides only a limited reduction in
mobility in other media through containment. Alternatives 4 and 6 are
similar to Alternatives 3 and 5, except that there would be less reduction
in TMV of contaminants in groundwater, since the in-situ groundwater
treatment technology would not likely be as effective as direct
treatment.
All action alternatives are more effective in reducing risks to the local
community and the environment than the No Action Alternative.
Alternatives 2 through 6 will require personal protection and other safety
measures to reduce risks to on-site workers during construction. All of
these alternatives will utilize air monitoring during excavation and
control of process emissions to ensure protection of the neighboring
community. Construction and soil treatment can be completed in
approximately 5 years or less for all alternatives. Alternative 2 can be
constructed the most quickly, in 2 years or less.
Tmpl«=mentabil ity
Alternatives 2, 3 and 4 utilize conventional technologies and readily
^available materials and services. Alternatives 5 and 6 use a process
'which is not as conventional (in-situ vitrification) but its use at the
site appears technically feasible.
Post
Costs are detailed in Table 3. Although Alternatives 5 and 6 are similar
in protection and effectiveness to Alternatives 3 and 4, Alternatives 5 and
6 are considerably more expensive. In Alternatives 3 and 4, the level of
soil excavation is proportional to the cost. Alternative 3C, which calls
for excavation only of oil contaminated fill and debris, is considered by
EPA to be the most cost-effective alternative because it is the least
costly alternative that effectively mitigates threats to and provides
adequate protection of public health, welfare and the environment.
State
The Indiana Department of Environmental Management (IDEM) has been
involved throughout the RI/FS and is expected to concur with Alternative
3C as the selected remedy.
Community involvement at the site has been moderate, however, several
community leaders have expressed opposition in public meetings and public
comments to on-site incineration due to concern about air emissions. A
'complete list of public cements and responses to those comments are
provided in Appendix B.
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- 15 -
EC. DooMEwranai OF SIGNIFICANT CHANGES
During negotiations for performance of the final remedy, FRPs proposed the
use of low temperature thermal stripping rather than incineration to treat
excavated fill materials. This process heats waste to a lower temperature
than incineration, typically 500 - 800* F, and volatilizes organic
contaminants. The contaminants contained in the off-gasses are condensed
and can be sent to an off -site incinerator for treatment. This process
could be used for some of the fill to be treated, but some materials such
as wood, drums and the tracted oil would still have to be incinerated.
In order to accommodate this request, the treatment process specified for
the selected remedy has been changed to "thermal treatment", rather than
"incineration". low temperature thermal stripping may be pilot tested
during the design phase, but will be allowed only if: 1) it proves to be
more cost-effective than incineration; 2) a mobile unit or sufficient off-
site capacity is available; 3) emissions meet the standards specified in
Section X; and 4) residuals contain less than 2 mg/Xg PCBs (the TSCA
requirement to show a technology will provide equivalent PCS destruction to
incineration) and residuals pass RCPA Toxic Characteristic Leach Procedure
(TCLP) extract requirements.
This change has also been made in order to accommodate concerns expressed
by the local community about emissions from an on-site incinerator.
Although EPA does not believe that emissions from an on-site incinerator
will create a public health risk, the Agency is willing to pilot test a
technology that might be more acceptable to residents by eliminating the
need for on-site incineration, or by reducing the amount of material to be
incinerated on-site.
X. SELECTED REMEDY
As discussed in the previous section, EPA has selected Alternative 3C -
"Hot spot" remediation of oil contaminated waste and fill materials, with
groundwater extraction and treatment - as the most appropriate final remedy
for the Ninth Avenue Dump site. This alternative was selected because it
is the most cost-effective remedy providing for protection of human health
and the environment and long term effectiveness. The components of the
selected remedy are described below, and a schematic diagram is shown in
Figure 10.
. soils. and
Oil contaminated waste and fill materials will be excavated from the area
inside the slurry wall, down to but not including the native sand. The
intent of the excavation is not to clean the area to health based levels,
but rather to remove the most highly contaminated fill materials and
enhance and ensure the long term effectiveness of the containment and
groundwater treatment components of the remedy. The extent of excavation
-------
EXISTING
OROUNDWAtER '',
RECHARGE TRENCH
LOCMION
OCCONtAMIHATION
/.• f
//
GROMHOWATER/OIL /
RECdVERY WELL /.'
CONTAINM^ IT
BARRCR LC C
^PROPOSED
CTION W
GROUNQWATER
,TR
''SYSTEM ,
FIGURE 10
Selected Remed
tilJlINC CROUmwXTIII/OU RtCOVtRT Mil
PTOPOStO GROUNDUAlt* DISCHAKC PIPIK
CROUNDWAIt* CONmANU IIC«M» firlNG
Oil AMD GROIINtnMltR CONVCTMKt
PIRIOMHD GROUHDWKK* DISIKIBUTION PIPING
kp cmmicnoM Btiui(N r,ow«ov/»i[«
•i AND rrornRAirn nnipioniiw PIPIW.
0 100 200
'CALE IN FEET ™
-------
TABLE 5
TARGET CLEANUP LEVELS PCR INDICATCR GCtfEAMINANrS
IN GHOCNDWATER
Chemical Risk based^1) MCL MCLG PQL/2)
heptachlor 0.022 - - 0.05
PAH 0.005 - - 10(3)
bis(2-ethy!hexyl)Fhthalate 85 10
benzene .07 5 02
trichloroethylene 3.5 5 0 1
vinyl chloride 0.021 2 0 2
lead 110 50 20 10
toluene 7,550 - 2,000<4) 2
(1) Based on 1 x 10""5 cumulative carcinogenic risk, or hazard index of 1.
(2) Source: 52 FR 2597. Practical quantitation limits for standard
analytical methods.
(3) For benzo(a)pyrene.
(4) Proposed MCLG.
-------
- 16 -
will be based en factors other than health based cleanup levels, as
explained below. "
The limits of excavation will be established by the historical horizontal
and vertical extent of the oil layer and depth to native soils as
determined by soil borings and/or test excavations in the design phase, and
by observations during the remedial action. An objective method for
distinguishing "oil "contaminated" from "non-oil contaminated" materials
will be proposed by the remedial design consulting firm and evaluated by
EPA.
The slurry wall (currently in the design phase) will be placed a
sufficient distance from the anticipated excavation area to ensure that
excavation of fill will not damage the integrity of the slurry wall.
Excavated waste and fill, oil extracted under the first operable unit, and
pond sediments and trench spoils showing high levels of contamination will
be treated through thermal treatment, most likely through on-site
incineration with a mobile incinerator meeting TSCA and RCRA requirements.
Although off -site incineration has not been precluded, it is anticipated
that on-site incineration will be less costly than transporting materials
off -site for incineration. In addition, another thermal treatment process
may be pilot tested, as described in Section IX.
be determined in design for the first operable unit that it is more
cost-effective to transport oil off -site for incineration than to build and
maintain a TSCA compliant oil storage facility on-site. In this case, only
waste and fill would be treated on-site.
Incineration and groundwater treatment process residuals will be
landfilled in the excavated area, along with relatively uncontaminated
trench spoils from slurry wall construction, pond sediments and debris
from ponds. The excavated area will be filled to grade with clean fill
and the entire area encompassed by the slurry wall will be covered with a
multilayer cap meeting RCRA Subtitle C requirements. The cap will be
installed prior to full scale implementation of the groundwater extraction
and treatment portion of the remedy to reduce the volume of water to be
treated.
It is anticipated that thermal treatment will take approximately five
years to complete.
Giuui iJwater :
Groundwater within the slurry wall will be extracted, treated and
reinjected inside the containment area to flush remaining water soluble
contaminants from soils. Bench scale testing to determine the feasibility
of various treatment processes is currently underway. Some processes under
»ideration for groundwater treatment include chemical coagulation/
iipitation, air stripping, activated sludge with optional powdered
Ivated carbon addition, granular activated carbon, strong acid/strong
-------
- 17 -
base ion exchange, and membrane separation.
The target cleanup levels (TCLs) for groundwater are: MCLs or 1 x 10~5
cumulative carcinogenic risk, whichever is more stringent, for
carcinogens, and MCLs, MCLGs, or a hazard index of 1, whichever is more
stringent, for noncarcinogens. If only one constituent is detected in
groundwater at a 1 x 10~5 (or greater) carcinogenic risk level, the MCL for
that contaminant may be used rather than the risk-based TCL. Example
target cleanup levels (TCLs), MCLs, and detection limits for indicator
contaminants are given in Table 5, however, TCLs should be recalculated in
the RD/RA phase to reflect the contaminants least amenable to treatment,
new health effects information, and the best analytical detection limits at
that time.
The point of compliance will be monitoring wells at the downgradient
(outside) edge of the slurry wall and RCRA cap. TCLs will also be used as
the treatment goal for groundwater to be reinjected inside the slurry wall,
to ensure TCLs will be met at the point of compliance even in the event of
a complete slurry wall failure. Since the point of reinjection will be
approximately 20 to 30 feet from the point of compliance, there will be
little to no natural attenuation between these two points if the slurry
wall fails.
Because the great majority of the total dissolved solids (TDS) at the site
is from an upgradient source, no treatment level will be set for salt
cleanup inside the slurry wall or at the point of compliance. The intent
of this remedy is not to clean up salt, but rather to ensure that the
groundwater treatment remedy does not make the situation worse by
spreading the salt plume.
The TCLs described above also apply to groundwater outside the slurry
wall, with the following exceptions: some monitoring wells along Ninth
Avenue and the Cline Avenue frontage road (X52, X48, X49, X50, X51, see
Figure 4) are excluded because they showed low levels of organic
contamination which do not appear to be attributable to the site. There
have been numerous reports by the public and observations by site workers
of trash dumping and discharge of liquid waste in the ditches along these
roads and of waste rf|«y*«*T on the adjacent Ninth and Cline site. The
types of contaminants found in these wells are somewhat different than
those on-site and groundwater flow patterns indicate that site contaminants
are unlikely to have migrated to these areas, especially to X52 and X50/51.
Thus, EPA does not believe it would be appropriate to consider these wells
in defining the extent of site related groundwater contamination.
An attempt will be made in design to site the slurry wall such that
groundwater outside the wall meets TCLs, with the exceptions described
above. If this is not possible, a limited amount of groundwater will be
extracted and treated outside the slurry wall to meet these standards.
A small amount of treated groundwater will be discharged outside the
slurry wall to compensate for infiltration. The cleanup level will be
determined by the discharge option:
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- 18 -
1) Treatment to Ids and reinjection to the shallow aquifer outside
the slurry wall. Salt would be treated only to the extent
necessary to ensure that the existing salt plume is not made
worse by groundwater remediation.
2) Discharge to on-site surface water in accordance with NPDES
standards.
3) Discharge in a deep injection well in accordance with UIC
regulations. The required level of treatment would be
determined by the UIC program.
The aquifer remediation goal of 1 x 10""5 cumulative carcinogenic risk
contradicts and supercedes the 1 x 10"6 cumulative carcinogenic risk level
set by the first operable unit ROD. The 10""5 risk level is considered more
appropriate for this site because of the multiple sources of contamination
in the Calumet Aquifer and because institutional controls will prohibit use
of groundwater under the site. Also use of a 10"6 risk level will result
in cleanup levels for individual contaminants far below analytical
detection limits (see Table 5) .
It is estimated that the pump and treat system will be in operation for 10
to 15 years to meet the target cleanup levels.
Surface water will not be treated directly, but eliminating migration of
contaminants from source areas through treatment and containment will
result in a reduction of contaminant concentrations over time. Sediments
exceeding target cleanup levels will be dredged and added to the fill
materials under the RCBA cap, unless oil concentrations are high enough to
warrant incineration. As described for fill materials, an objective method
for determining "oil contamination" will be developed during the design
phase. Based on a comparison of sediment analytical data to human health
criteria and background soil samples, the best indicator of sediment
contamination appears to be PAHs. Further sediment sampling will be done
in the area of SD2, SD11, SD13, and SD19 (see Figure 8 - other areas
exceeding criteria will be covered by the RCRA cap) . Sediments will be
excavated if total PAHs exceed 2400 ug/kg (95% upper confidence level for
PAHs in soil background samples) . Discarded drums and other debris will be
removed from on-site ponds and used as fill under the cap.
Other
Other components of the selected remedy include:
Dismantling, decontaminating and removing from the site the oil
storage facility constructed under the first operable unit.
Instituting deed and access restrictions to protect the RCRA cap
-------
. - 19 -
and prohibit use of the groundwater under the site.
Continued groundwater monitoring using the monitoring system
designed under the first operable unit, and upgrade of the
system if necessary.
* Air monitoring during excavation, handling, and treatment of
waste and fill materials and groundwater treatment and corrective
action if emissions exceed 1 x 10""6 cumulative carcinogenic risk
or a hazard index of 1 at the site boundary.
Continued maintenance of the fence around the site and the use
of other security measures to protect en-site structures from
vandalism.
long term operation and maintenance will include operation and maintenance
of the groundwater pump and treat system for an estimated 10 to 15 years,
continued site security measures, and long term groundwater monitoring.
The cost of the selected remedy is listed below:
Capital Cost: $18,048,000
Annual Operation and Maintenance: $ 489,000
Total Present Net Worth: $22,209,000
I i
E. STATUTORY LKHMUNATIOB
EPA and IDEM believe the selected remedy satisfies the statutory
requirements specified in Section 121 of SARA to protect human health and
the environment; attain ARARs; utilize permanent solutions and alternate
treatment technologies to the maximum extent practicable.
of F*i"g*Ti Haaith and the
The selected remedy provides protection of human health and the
environment through a combination of treatment and containment. Risks due
to exposure to contaminated soils will be reduced through: 1) excavation
and thermal treatment of the most highly contaminated fill materials, 2)
soil flushing to reduce the remaining contamination, and 3) containment
with a soil/bentonite slurry wall and RCRA cap. Risks from exposure to
groundwater will be reduced through the pump and treat system and deed
restrictions prohibiting use of groundwater on-site. Risks from the oil
stored on-site under the first operable unit will be eliminated through
incineration of the oil and decontamination and removal of the on-site oil
storage facility.
Short term impacts to off -site residents during construction are expected
to be minimal. Air monitoring will be used during all phases of
don where emissions might occur, especially during excavation of
ited soils, and corrective actions will be taken if air emissions
health-based levels. Although some impact to wetlands areas is
-------
- 20 -
expected during construction of the first operable unit, final remedy
construction should not result in further impact to wetlands.
This action meets Federal and more stringent State ARARs. ARARs and TBCs
considered for all alternatives are listed on Table 4, and ARARs specific
to the selected remedy are described in Table 6.
Qpgfr- Ff -f errt- i
Alternative 3C was selected because it is the most cost-effective
alternative providing for protection of human health and the environment
and long term effectiveness. Alternative 2 provides a less expensive
containment alternative which is protective in the short term but relies on
a slurry wall which would require maintenance and possibly replacement in
the future to ensure its effectiveness. Several more expensive
alternatives were considered, from removal of all contaminated fill
materials at $33 million to in-situ vitrification with full salt treatment
of groundwater at $83 million. Since the selected remedy addresses the
most highly contaminated portion of the site, the higher cost remedies
provide only a small incremental increase in effectiveness .
izat"» on of Permappnt Solutions and Al*'*ymat"we
the yfav"itT»im Extent
The selected alternative provides the best balance of protectiveness,
permanence, and cost, along with the other evaluation criteria used for
remedy selection. It will be more effective in the long term than the
containment alternative, as described in the previous section. Since the
oil layer contains higher concentrations of contaminants than any other
medium, removal of oil contaminated fill materials should eliminate the
largest source of contamination at the site. Native soils were not
included because contaminants can be more easily flushed from sand than
from the heterogeneous fill materials.
All alternatives evaluated in the FS, except for No Action, provide
essentially equal short term protectiveness through containment or
treatment. Alternative 3C was chosen because it provides a level of
treatment sufficient to reduce the threat of migration of contaminants to
groundwater, even if the containment portion of the remedy eventually
fails.
Prefeitame for Treat""**"* a« a Princ^r*^
The selected remedy utilizes treatment to address the principal threats at
the site through incineration of highly contaminated oil and oily fill
materials and flushing to reduce concentrations of water soluble
contaminants in the areas not addressed by incineration.
-------
•DUBLE 6
ARAKS (AND TSC CRITfcSUA) FCR THE
Regulation
Safe Drinking Water Act (SDWA)
40 CFR Part 264, Subpart F
40 CFR Part 122, 125
Clean Water Act (CWA)
330 IAC 1-1-6, 1-1-7, 2-1-6
Discussion
Specific ARARs
MCXs set under the SDWA are relevant and
appropriate. MCL£s are "to be
considered" (TBC). MCL, MCXGs or target
cleanup levels, whichever is more
stringent, will be met for non-
carcincgens. For carcinogens, MCLs or
target clean up levels, whichever is
more stringent, will be met.
RCRA grcundwater protection and
monitoring standards are relevant and
appropriate.
NPDES standards will be relevant and
appropriate if treated groundwater is
discharged to en-site surface water
bodies.
AWQC set under the CWA are relevant and
appropriate for surface water bodies.
AWQC will be met through source control,
rather than active restoration.
Promilgated Indiana water quality
standards are relevant and appropriate.
Indiana proposed water quality standards
are TBC.
location Specific ARARs
Executive Order 11990,
Fish and Wildlife Coordination
Act, CWA Section 404
Requirements for protection of
wetlands are relevant and appropriate.
Precautions will be taken to minimize
impacts to wetlands during remedial
action.
Action Specific ARARs
4.0 CFR Part 264, Subpart J
RCRA storage tank closure require-
ments will be relevant and appropriate
for removal of oil storage tanks.
40 CFR Part 264, Subpart N
RCRA landfill closure requirements
-------
TABIZ 6 (con't)
40 era Part 264, Subpart O
40 CFR Part 268
40 CFR Part 761, Subpart D
40 CFR Part 761, Subpart G
40 CFR Part 144
29 CFR 1910
325 IAC 6-4
330 IAC 5-2-2
320 IAC 4.1-54
320 IAC 4.1-53 6(2)
will be relevant and appropriate for
the multilayer cap.
RCRA incineration requirements will be
relevant and appropriate for on-site
incineration.
RCRA land disposal restrictions (1£R)
may be relevant and appropriate
requirements for ash disposal if
material to be landfilled on-site is
RCRA characteristic due to EP Toxicity.
TSCA incineration requirements will be
relevant and appropriate for
incineration of PCS contaminated oil
and waste.
TSCA PCB spill cleanup policy is a TBC.
Requirements to clean spills of greater
than 50 ppm PCBs may not be met in all
areas. Instead, protection from PCB
contaminated materials will be provided
through a combination of treatment and
containment.
Underground Injection Control (UIC)
requirements are relevant and
appropriate for shallow or deep well
injection of groundwater.
OSHA safety standards are. applicable to
workers on-site.
Indiana fugitive dust emissions
standards are relevant and appropriate.
Indiana surface water discharge
requirements are relevant and
appropriate if treated groundwater is
discharged to surface water.
Indiana requirements for incinerator
operation are relevant and appropriate.
Indiana cap requirements for hazardous
waste landfills are relevant and
appropriate for the multilayer cap.
-------
T.T57T OF APPENDICES
APPENDIX A: Analytical Data for Waste, Soils, Oil, Groundwater,
Surface Water, and Sediments
APPENDIX B: Responsiveness Summary
APPENDIX C: Administrative Record Index
-------
APPENDIX A
ANALYTICAL DftTA
Table 1-1: Surface
Table 1-2: Subsurface
Table 1-3: Groundwater, surface water,
Table 1-4: Oil
-------
TABLE 1-1 '
SURFACE SOILS ANALYTICAL RESULTS
NINTH AVENUE DUMP
GARY, INDIANA
COMPOUND
VOLATIIES
Chloromethane
Bromomethane
Vinyl Chloride
Cnloroethane
Methylene Chloride
Acetone
Carbon Oisulfide
.1,1-Dichloroethene
1,1-Oichloroethane
trans- 1.2-Dichloroethene
Chloroform
1,2-Oichloroethane
2-Butanone
1, 1, 1-Trichloroethane
Carbon Tetrachloride
Vinyl Acetate
Bromod i ch 1 oromethahe
1,2-Oichloropropane
trans-1.3-0ich)ropropene
Trichloroethene
D i bromoch 1 oromethane
1. 1,2-Trichloroethane
Benzene
cis-1, 3-Dichloropropene
2-Chloroethyl vinyl ether
Bromoform
4-Methy 1 -2-pentanone
2-Hexanone
Tetrachloroethene .
1,1,2. 2-Tetrachloroethane
Toluene
Chlorobenzene
Ethyl benzene
Stvrene
Total Xyienes
SEMI-VOLATILES
Phenol
bis(2-Chloroethyl) ether
2-Chlorophenol
1 , 3-Oichlorobenzene
1,4-Oi Chlorobenzene
Benzyl Alcohol
1,2-Di Chlorobenzene
2 -Methyl phenol
bis(2-Ch1oroisopropy1) ether
4-Methy 1 phenol
N-Nitroso-di-n-propylamine
Hexachloroethane
Nitrobenzene
Isophorone
2-Nitrophenol
2, 4-0 i methyl phenol
Benzoic Acid
bis(2-Chloroethoxy)nethane
2 , 4-Oichlorophenol
1, 2, 4-Tri Chlorobenzene
Naphthalene
4-Chloroaniline
Hexachlorobutadiene
4-Chloro-3-
-------
TASLE 1-1 (cont.)
SURFACE SOILS ANALYTICAL RESULTS
NINTH AVENUE DUMP
GARY, INDIANA
COMPOUND
2-Nitroaniline
Oimethylphthalate
Acenaphthylene
3-Nitroaniline
Acenaphthene
2,4-Oinitrophenol
4-Nitrophenol
Oibenzofuran
2 , 4-Oini trotoluene
2,6-Dinitrotoluene
Diethylphthalate
4-Chlorophenyl phenvl ether
Flourene
4-Nitroaniline
4,6-Oinitro-2-niethylphenol
N-Nitrosodipheny lamine
4-Bromophenyl phenyl ether
Hexachlorobenzene
Pentachlorophenol
Phenanthrene
Anthracene
di-n-Butylphthalate
Flouranthene
Pyrene
Butylbenzylphthalate
3,3-Dichlorooenzidine
Benzo(a)anthracene
bis(2-Ethylhexyl)phthalate
Chrysene
di-n-Octvlphthalate
Benzo(b)f luoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
Dibenz (a, h) anthracene
Benzo(g.h, i)perylene
PESTICIDES/PCS' S
alpha-BHC
beta-BHC
delta-BHC
gamma- BHC (LINDANE)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4-OOE
Endrin
Endosulfan II
4,4-000
Endosulfan sulfate
4,4-OOT
Methoxychlor
Endrin ketone
Chlordane
Toxaphene
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
CAS
REG. NO.
88-74-4
131-11-3
208-96-8
99-09-2
83-32-9
51-28-5
100-02-7
132-64-9
121-14-2
606-20-2
84-66-2
7005-72-3
86-73-7
100-01-6
534-52-1
86-30-6
101-55-3
118-74-1
87-86-5
85-01-8
120-12-7
84-74-2
206-44-0
129-00-0
85-68-7
91-94-1
56-55-3
117-81-7
218-01-9
117-84-0
205-99-2
207-08-9
50-32-8
193-39-5
53-70-3
191-24-2
319-84-6
319-85-7
319-86-8
58-89-9
76-44-8
309-00-2
1024-57-3
959-98-8
60-57-1
72-55-9
72-20-8
33213-65-9
72-54-8
1031-07-8
50-29-3
72-43-5
53494-70-5
5103-71-9
8001-35-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
min
ug/kg
ND
NO
89
ND
360
10,000
ND
130
NO
ND
180
NO
130
NO
NO
ND
NO
NO
3,700
79
75
69
82
51
NO
NO
40
310
65
300
290
66
170
150
, 290
170
63
80
NO
NO
NO
NO
ND
NO
NO
3,600
320
57
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
16,000
430
570
NO
RANGE
max
ug/kg
ND
NO
9,600
NO
1,900
10,000
NO
2.200
NO
ND
1,900
ND
50,000
NO
NO
NO
NO
NO
3.700
50,000
25.000
26.000
32.000
28.000
ND
NO
12.000
350.000
13,000
22,000
7,300
7,600
7,900
6.100
1,300
5.700
130
510
NO
NO
NO
ND
NO
NO
ND
3,600
320
57
NO
NO
NO
NO
ND
NO
NO
ND
ND
ND
16.000
1,700
570
NO
GEOM.
cmpd
detected
ug/kg
• . ..
364
....
720
10,000
500
....
58
l"l71
....
• ....
....
3.700
2.249
1,328
668
1,695
1.597
....
1.442
6.642
1,598
1.599
1.944
1.148
1,812
1,122
606
1.594
84.6
158
----
....
....
....
....
3,600
320
57
....
....
....
....
....
....
....
....
....
16,000
1.031
570
MEAN
site
wide
ua/ka
....
' •
8.3
4.0
1.6
5.1
....
1.9
20
....
....
1.4
197
21
61
354
229
....
99
41
156
4.7
80
86
114
28
7.6
10
2.0
3.8
....
.._.
....
....
....
1.5
1.4
1.2
....
....
....
....
....
....
....
....
....
.... -
1.7
3.0
1.4
-------
TABLE 1-! (cont.)
SURFACE SOILS ANALYTICAL RE5ULrS
NINTH AVENUE DUMP
GARY, INDIANA
COMPOUND
INORGANICS
. Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Tin
Vanadium
Zinc
Cyanide
CAS
REG. NO.
min
ua/ka
111
9.8
9.6
42
0.5
2.9
2.407
21
2.97
12
131
1.2
579
117
0.2
17.9
129
1.1
3.3
165
NO
21
8.4
23.7
1.3
RANGE
max
ug/kg
75,900
267
37
1,570
6.2
32
169,000
157
32
2,050
116.000
1,380
46,900
4,840
1.6
282
3,620
1.1
3.3
2.190
NO
137
111
1.100
7
GEOM.
cmpd
detected
ug/kg
12,113
51
•18
177
2.8
8.5
13,139
44
9.1
209
8,642
134
6,282
537
0.63
68
216
1.1
3.3 -
592
44
27
258
3.0
MEAN
site
wide
uo/ka .
12,113
1.5
' 3.4
135
1.7
5.4
13,139
4.9
6.4
119
2,066
10
3,964
385
0.15
54
93
1.0
1.1
302
6.0
19
253
0.22
NO • Not Detected
Note: Surface soil analytical results include data from soil boring samples obtained from a depth of 1 ft.
13436.30
MSR/dlk/TDH/GEA
[skfa-400-63]
-------
TABLE 1-2
SUBSURFACE SOILS ANALYTICAL RESULTS
NINTH AVENUE DUMP
GARY, INDIANA
COMPOUND
VOLATILES
Chlbromethane
Bromomethane
Vinyl Chloride
Cnloroethane
Methylene Chloride
Acetone
Carbon Disulfide
1, 1-Oichloroethene
1, 1-Oichloroethane
trans -1,2-Dichloroethene
Chloroform
1,2-Oichloroethane
2-Butanone
1,1. 1-Trichloroethane
Carbon Tetrachloride
Vinyl Acetate
Bromodichloromethane
1 , 2-Oichloropropane
trans -1,3-Dichlropropene
Trichloroethene
Dibromochloromethane
1 , 1 ,2-Trichloroethane
Benzene
cis-l,3-0ichloropropene
2-Chloroethyl vinyl ether
Bromoform
4-Methyl-2-pentanone
2-Hexanone
Tetrachloroethene
1, 1,2,2-Tetrachloroethane
Toluene
Chlorobenzene
Ethyl benzene
Stvrene
Total Xylenes
SEM1-VOLATILES
Phenol
bis(2-Chloroethyl) ether
2-Chlorophenol
1,3-Oichlorobenzene
1.4-Oichlorobenzene
Benzyl Alcohol
1,2-Oichlorobenzene
2-Methyl phenol
bis(2-Chloroisopropyl) ether
4-Methyl phenol
N-Nitroso-di-n-propylamine
Hexachloroe thane
Nitrobenzene
Isophorone
2-Hitrophenol
2,4-Dimethylphenol
Benzoic Acid
bis(2-Ch1oroethoxy)methane
2.4-Dichlorophenol
1. 2. 4-Tri Chlorobenzene
Naphthalene
4-Chloroaniline
Hexach lorobutad i ene
4-Chloro-3-methyl phenol
2-Methyl naphthalene
Hexachlorocyclopentadiene
2,4, 6-Trichlbropnenol
2 , 4 , 5-Trichlorophenol
2-Chloronaphthalene
CAS
REG. NO.
74-87-3
74-33-9
75-01-4
75-00-3
75-09-2
67-64-1
75-15-0
75-35-4
75-35-3
156-60-5
107-06-2
78-93-3
71-55-6
56-23-5
108-.05-4
75-27-4
78-87-5
10061-02-6
79-01-6
124-48-1
79-00-5
71-43-2
10061-01-5
110-75-8
75-25-2
108-10-1
591-78-6
127-18-4
79-34-5
108-38-3
108-90-7
100-41-4
100-42-5
133-02-7
108-95-2
111-44-4
95-57-8
541-73-1
16-46-7
100-51-6
95-50-1
95-48-7
39638-32-9
106-44-5
621-64-7
67-72-1
98-95-3
78-59-1
88-75-5
105-67-9
65-85-0
111-91-1
120-83-2
120-82-1
91-20-3
106-47-8
87-68-3
59-50-7
91-57-6
77-47-4
88-06-2
95-95-4
91-58-7
min
ug/kg
NO
NO
NO
NO
8
32
3
NO
ND
69,000
7
ND
17,000
63.000
ND
. NO
ND
ND
ND
970
ND
NO
19
ND
NO
ND
41,000
9,700
1,500
ND
2
3,600
33
18,000
99
26,000
NO
NO
NO
NO
ND
NO
NO
NO
NO
ND
NO
ND
NO
NO
NO
NO
NO
NO
6,200
38
NO
ND
NO
450
NO
NO
NO
NO
RANGE
max
ug/kg
ND
ND
NO
NO
200,000
120,000
3
NO
NO
69.000
9
ND
450,000
89,000
NO
ND
NO
ND
NO
69.000
NO
NO
25,000
NO
NO
ND
41.000
9.700
250.000
NO
5,300,000
3.600
2.700,000
2.600,000
7,100,000
26,000
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
ND
NO
6.200
160,000
NO
NO
ND
630,000
ND
NO
ND
ND
GEOM.
cmpd
detected
ug/kg
....
....
....
._•..
1,659 .
1,497
3
....
....
69,000
8.0
....
87,464
74.880
....
....
....
....
— . •
15. .895
.....
....
3.068
....
....
....
41,000
9,700
....
....
30, .629
3.600
112.296
160,896
504,024
26.000
....
•_...
....
....
....
....
.....
....
.....
....
....
....
....
....
....
6,200
22,941
....
...•
42,562
....
....
MEAN
site
wide
ug/kg
. . ...
....
.....
....
59
13
1-1
....
1.7
1.4
....
3.1
3.1
....
....
....
....
....
4.3
....
....
7.4
....
....
....
1.7
1.6
....
824
1.5
3,430
6.0
5,088
1.7
....
....
....
.... •
....
. .. • •
....
....
....
....
....
....
....
....
....
•
1.5
1.128
....
....
»..
2,963
....
. . '..-. •
....
-------
TABLE 1-2 (cont.)
SUBSURFACE SOILS ANALYTICAL RESULTS
NINTH AVENUE DUMP
GARY, INDIANA
COMPOUND
2-Nitroaniline
Dimethylphthalate
Acenaphthylene
3 -Nitro aniline
Acenaphthene
2,4-Dinitrophenol
4-Nitrophenol
Oibenzofuran
2,4-Oinitrotoluene
2,6-Dinitrotoluene
Diethylphthalate
4-Chlorophenyl phenvlether
Fiourene
4-Nitroaniline
4, 6-Dinitro-2-methyl phenol
N-Nitrosodiphenylamine
4-Bromophenyl phenyl ether
Hexachlorobenzene
Pentachlorophenol
Phenanthrene
Anthracene
di-n-Butylphthalate
Flouranthene
Pyrene
Butyl benzyl phthalate
3,3-Oichlorobenzidine
Benzo (a) anthracene
bis(2-Ethylhexyl)phthalate
Chrysene
di-n-Octylphthalate
Benzo(b)f luoranthene
Benzo ( k ) f 1 uoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
Di benz fa , h) anthracene
Benzo (g.h.i)pery lene
PESTICIDES/PCB'S
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC (LINDANE)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Oieldrin
4,4-ODE
Endrin
Endosulfan II
4,4-000
Endosulfan sulfate
4.4-ODT
Methoxychlor
Endrin ketone
Chlordane
Toxaphene
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
CAS
REG. NO.
88-74-4
131-11-3
208-96-8
99-09-2
83-32-9
51-28-5
100-02-7
132-64-9
121-14-2
606-20-2
84-66-2
7005-72-3
86-73-7
100-01-6
534-52-1
86-30-6
101-55-3
118-74-1
87-86-5
85-01-8
120-12-7
84-74-2
206-44-0
129-00-0
85-68-7
91-94-1
56-55-3
117-81-7
218-01-9
117-84-0
205-99-2
207-08-9
50-32-8
193-39-5
53-70-3
191-24-2
319-84-6
319-85-7
319-86-8
58-89-9
76-44-8
309-00-2
1024-57-3
959-98-8
60-57-1
72-55-9
72-20-8
33213-65-9
72-54-8
1031-07-8
50-29-3
72-43-5
53494-70-5
5103-71-9
8001-35-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
win
ug/kg
ND
NO
3,200
NO
170
NO
NO
6.400
NO
NO
3,800
NO
280
NO
NO
NO
ND
NO
NO
130
140
2.700
270
220
4.400
NO
180
300
260
2,600
190
190
160
150
46,000
170
NO
NO
NO
NO
ND
NO
NO
NO
ND
NO
NO
NO
NO
NO
ND
NO
ND
NO
ND
ND
ND
ND
200
24,000
190,000
NO
RANGE
max
ug/kg
NO
ND
10.000
ND
100.000
NO
NO
78,000
NO
NO
3,800
ND
150.000
ND
ND
ND
ND
NO
NO
690,000
81,000
130,000
248,000
140,000
110,000
NO
38,000
1,500.000
63,000
110,000
46.000
46,000
46,000
46,000
46.000
46,000
NO
NO
ND
NO
NO
ND
NO
NO
ND
ND
NO
NO
NO
ND
ND
ND
ND
ND
ND
NO
NO
NO
200
24,000
190,000
ND
GEOM.
cmpd
detected
ug/kg
.. . .
....
5,657
....
5,766
....
....
15,675
....
....
3,800
....
9,296
....
....
....
....
....
....
17,253
5,534
14,369
13,460
9,864
28,132
4,632
25,984
3,890
23,707
5,378
4,178
3,099
2,103
46,000
1,616
» • ».
...
...
...
--.
...
...
...
...
.-..
• — ..
....
....
....
....
....
....
• ....
....
'. — . .
..•.
....
200
24.000
190,000
MEAN
Site
wide
ug/kg
- — — — —
2.4
....
76
....
....
29
.... •
....
1.5
....
240
....
....
....
....
....
• ....
3,993
48
504
300
•249
4.6
29
2,047
94 .
34
48
12
37
15
1.7
9.2
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
....
1.3
1.7
1.8
-------
TABLE 1-2 (cont.)
SUBSURFACE SOILS ANAIYTICAL RESULTS
NINTH AVENUL DUMP
GARY, INDIANA
•
COMPOUND
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
CAS
REG. NO.
min
ucj/kg
1.143
NO
1.5
11
1.0
1.1
714
2.7
6.8
2.7
2,304
3.8
251
14
0.1
4.3
230
NO
2.1
138
NO
6.0
11
0.2
RANGE .
max
uo,/kg
252.000
NO
320
3,190
10
24
76.400
2.820
32
6.530
57,200
1.660
14,080
13,441
0.6
383
2.430
NO
12
1,020
NO
306
2.630
4.2
GEOM.
cmpd
detected
ug/kg
4,341
....
9.7
123
2.6
5.8
7.736
80
15.8
82
8,149
206
2.655
256
0.22
46
559
....
4.4
455
....
33
279
0.92
MEAN
Site
wide
ug/kg
4.341
3.1
14
1.2
2.9
7,736
33
2.6
11
8,149
19
2,655
256
0.13
8.2
61
....
1.8
12
....
5.7
68
0.19
ND • Not Detected
Note' Subsurface soil analytical results include data from soil boring samples obtained from a depth greater
ft. and soil samples obtained from test pits.
13436.30
MSR/dlk/TDH/GEA
[dlk-400-23]
-------
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tyrtm
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2
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26
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41
69
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lUllt
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24 hr ICcn: 21 -q/l
24-96 hril,: 220-150 ifo/l
41 hr IC.0: 1.4 >g/L
no <(ltcl live! - 5 «g/l, 24
24 hr )!„: 2.6 ug/l
96 hr ll-: 76 uo/t
10 dl« tfi0: 0.075 Kj/l
lOdly ICjo- 0.177 >o/l
-------
TABLE 1-4
OIL LAYER ANALYTICAL DATA
Mean
1 , l-Dichloroethane 160,000 160,000
Trans-l,2-dichloroethene 940,000 64,539
2-Butanone 16,000 16,000
1,1,1-Trichloroethane 1,000,000 1,000,000
Benzene 390,000 290,560
4-Methyl-2-pentanone 540,000 87,533
Tetrachloroethene 120,000 120,000
Toluene 15,000,000 1,108,573
Ethylbenzene 8,800,000 421,908
Styrene 530,000 530,000
Total Xylenes 63,000,000 1,918,905
1,2-Dichlorobenzene 52,000 50,990
4-Methylphenol 5,700 5,700
Naphthalene 3,700,000 368,039
4-Chloroaniline 220,000 220,000
2-Methylnaphthalene 11,000,000 424,604
AcenaFhthylene 500,000 463,681
Acenaphthene 550,000 550,000
Dibenzofuran 630,000 404,722
Fluorene 1,000,000 255,300
N-nitrosodiphenylamine 35,000 15,751
Bienanthrene 3,300,000 433,930
Anthracene 1,600,000 669,328
Di-n-butylphthalate 51,000 48,952
Fluoranthene 960,000 101,186
Pyrene 500,000 75,936
Benzo (a) anthracene 240,000 132,363
Bis(2-ethylhexyl)phthalate 520,000 297,975
Chrysene 230,000 85,631
Di-n-octylphthalate 54,000 54,000
Benzo (b) nuoranthene 180,000 140,712
Benzo(a)pyrene 210,000 122,963
Indeno(l,2,3-cd)pyrene 160,000 78,994
Dibenz (a, h) anthracene 42,000 42,000
Benzo (g,h,i)perylene 170,000 72,595
ATOClor 1248 1,500,000 61,799
Aroclor 1254 79,600 21,854
Aroclor 1260 5,700 5,392
2378 TCED ND ND
Total CDD 530 142
2378 TCDF 4 4
Total CDF 27 13
Aluminum 410 410
Cadmium 17 17
Calcium 1,560 1,560
Chromium 920 156
Iron 514 350
Nickel 70 57
Silver 66 66
Zinc 543 189
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B
NINTH AVENUE DUMP
GARY, INDIANA
RESPaeiVENESS SCM4&RY
I. RESPONSIVENESS SUMMARY OVERVIEW
In accordance with CERCIA Section 117, a public comment period was held
from March 20, 1989 to April 19, 1989, to allow interested parties to
comnent on the United States Environmental Protection Agency's (EPA's)
Feasibility Study (FS) and Proposed Plan for a final remedy at the Ninth
Avenue Dump site. At a March 29, 1989 public meeting, EPA presented the
Proposed Plan for the Ninth Avenue Dump site, answered questions and
accepted cements from the public.
The purpose of this responsiveness summary is to document comments
received during the public comment period and EPA's responses to these
ccnments. All ccnments summarized in this document were considered in
EPA's final decision for remedial action at the Ninth Avenue Dump site.
II. B&OOO3ND CM OMUNTIY INVOLVEMENT
Ninth Avenue Dump (and another National Priorities List site, Midco I) is
located in Gary near its border with Hammond. A Hammond residential area
called Hessville is the closest residential area to the site,
approximately 1/8 mile west of the site. Gary and Hammond public
officials and Hessville residents have been actively involved with both
of these sites.
Community concern intensified in June 1981, when heavy rainfall resulted
in flooding from the area around Ninth Avenue Dump and Midco I to the
Hessville neighborhood. Several residents complained of chemical odors
in flooded basements and chemical burns from contact with flood waters.
EPA's Technical Assistance Team sampled flood waters a few days after the
flood and analyzed for volatile organics. None were detected.
Hessville residents constructed a dirt dike across Ninth Avenue at the
Cline Avenue overpass. The dike is located at the corporate boundary
between Gary and Hammond and obstructs traffic between the tv~
communities. The dike remains a source of controversy between Gary and
Hammond public officials and residents.
EPA has held several public meetings since the initiation of a pre-
liminary investigation by the site operator in 1983. Results of the
Remedial Investigation and the interim remedy Feasibility Study and
Proposed Plan were presented in a July 13, 1988 public meeting. The
March 29, 1989 public meeting, attended by approximately 25 residents and
public officials, focused on the results of the Feasibility Study and the
Agency's Proposed Plan for the final remedy. Residents and public
officials expressed their opposition to an on-site incinerator at the
March 29, 1989 meeting due to concerns about air emissions. Local public
officials were also concerned about the Agency's findings that the
Indiana Department of Highways (IDOH) was contributing to the
groundwater contamination problem and asked that enforcement measures be
taken to remediate this problem.
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Several oral comments were accepted at the public meeting. EPA received
three written submittals during the public comment period, one from a
local public official and two from Potentially Responsible Parties
(PRPs).
HI. SOfMARY OF SXafEFIC&NT GCM4ENTS RECEIVED CORING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
The comments are organized into the following categories:
A. Summary of comments from the local community
1. Comments on the Feasibility Study and Proposed Plan
2. Other comments
B. Summary of comments from Potentially Responsible Parties
1. Comments related to risk assessment
2. Comments on integration of the interim and final remedies
3. Comments on cost calculations
4. Other comments
The comments are paraphrased in order to effectively summarize them in
this document. The reader is referred to the public meeting transcript
and written comments available at the public repository for further
information.
A. SUMMARY OF COMMENTS FROM THE IOCAL COMMUNITY
1. COMMENTS ON THE FEASIBILITY STUDY AND PROPOSED PIAN
COMMENT:
Incineration is not a viable alternative for the cleanup of Ninth
Avenue Dump. New combinations of chlorinated compounds, including
dioxins, may be formed during the incineration process, which would
then be released through air emissions or through disposal of ash.
Heavy metals would not be treated by incineration and would remain in
the ash.
There are alternative remediation technologies currently available
which would be significantly cheaper than incineration. (The
commenter provided a copy of a paper entitled "GE's Non-Sodium Process
for Chemically Decontaminating Mineral Oil Dielectric Fluid" as an
example alternate technology.)
Dioxin concentrations measured in soil samples were extremely low
(less than one part per billion) in soil and oil samples. Dioxin
precursors, those compounds which might combine to form dioxins, were
also found at extremely low concentrations, making the likelihood of
dioxin formation during incineration extremely low. Studies have
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shown that chlorine is preferentially converted into hydrogen chloride
(HC1) gas during the incineration process. Emissions of HC1 will be
monitored to ensure EPA emissions standards (described below) are met.
The alternate technology provided by the ocmnenter is known within the
Industry as the "KPEG" process. This technology was evaluated during
the development of the Feasibility Study, and was found to be of
limited application for the following reasons: 1) the process is not
appropriate for wastes contaminated with multiple compounds, and
further treatment would be required, and 2) this process has been
applied to waste oils, but not to solids treatment.
GCtMENT:
The City of Hammond has an incinerator regulation which prohibits
burning waste which may result in generation of dioxins, furans,
chlorine, and hydrochloric acid (HC1) in incinerators within the City
of Hammond. These standards should be applied to the incinerator at
Ninth Avenue Dump. Stack tests should be done in worst case
conditions and in-stack monitoring should be done for furans,
hydrochloric acid and other toxic substances.
RESKxBE:
Since this mobile incinerator will be operating in the City of Gary,
EPA cannot consider the City of Hammond's incinerator regulation an
applicable, or relevant and appropriate requirement. However,
although EPA cannot promise no emissions of the substances listed
above, stringent standards set by the RCRA, TSCA and Superfund
programs will be enforced for incinerator emissions. These include
the following standards:
1) Each principal organic hazardous constituent in the waste must be
reduced to .01% of the original concentration before emission
into the air. The RCRA program refers to this as 99.99%
destruction and removal efficiency (ERE). Some more toxic
compounds, including PCBs, must be reduced to .0001% of the
original concentration, or 99.9999% ORE.
2) Hd 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.
3) In addition to the above regulations, a standard has been set in
this Record of Decision (ROD) to limit emissions of hazardous
substances in air resulting from all cleanup activities to less
than 1 x 10"6 (one in one million) cumulative carcinogenic risk
at the site boundary.
COfffiOT:
A public meeting should be held after the results of a stack test are
available and before the incinerator is in full scale operation to
inform the public and di*"ip« the results of the test.
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RESPONSE:
This is an excellent suggestion and EPA will make every effort to
acoannodate this request.
2. (JlHfcH OCWMEWIS
All hazardous waste sites in northwest Indiana should be addressed in
a comprehensive manner instead of a piecemeal approach. Remedial
actions should concentrate on creating usable sites when they are
completed.
KE5FCN5E:
EPA agrees that a comprehensive approach would be the best way to deal
with all of the hazardous waste sites in northwest Indiana. To that
end, EPA is recommending remedial action for the Ninth Avenue Dump
site concurrently with the nearby Midco I and Midco II Superfund
sites, to ensure that these three sites will be addressed in a
consistent manner. EPA and IDEM have initiated studies to assess
overall contamination problems in the Calumet Aquifer and the IDEM is
in the process of developing a remedial action plan for the Grand
Calumet River/Indiana Harbor Canal area. It is EPA's hope that these
regional studies can be used to ensure that all of the major
contamination problems in northwest Indiana are addressed in a
consistent manner.
In response to the second portion of the comment, EPA agrees that the
ideal approach would be to leave a completely usable site after
remedial action. Unfortunately, the large volume of contaminated
materials at this site makes the attainment of this goal extremely
difficult. EPA must take a number of considerations into account when
a final remedial action including prptectiveness, long term
effectiveness, implementability, and cost. Since EPA has determined
that it would be extremely difficult to clean up 100% of the
contaminated materials on the site, the selected approach combines
partial treatment with partial containment and deed and land use
restrictions to provide added protection to present and future area
residents.
OMfEOT:
IDEM should take action against the Indiana Department of Highways
(IDOH) regarding the release of contaminants from their Gary
Suhdistrict road maintenance facility.
IDEM has informed EPA that it is currently conducting discussions
between their office, the IDOH and the Governor's office, focusing on
the most appropriate method to remediate the salt contamination and
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establishing a funding mechanism to pay for the cleanup, in an effort
to resolve this issue as quickly as possible.
EPA should have a toll free number and should have a regional office
in northwest Indiana so that cleanups may be implemented more quickly.
RESPONSE:
EPA does have a toll free number for reporting spills or other
releases of hazardous substances under the purview of the Superfund
program. That number if 800-621-8431. The regional office in Chicago
is easily accessible to northwest Indiana.
B. StMORY OF CCM1EWIS BY POTENTIALLY RESPONSIBLE PARTIES
1. GCM1ENT5 RELAXED TO RISK ASSESSMENT
GCMfENT:
The significant public health risks associated with the current use
scenario are due to trespassing on the site. Because there is no
basis provided in the FS or the RI for the frequency of trespassing
nor the degree of contact with each contaminated media, this violates
any rational concept of risk assessment procedure, and, therefore, is
invalid. It is noteworthy that none of the risks significantly
deviate from 10~4, even with the unrealistic and speculative
assumptions embodied in the calculations.
Assumptions for trespassing rates were based on information provided
by local residents, numerous observations of trespassers during field
work at the site, and professional judgment. Given that the site
fence has been vandalized several times and there are spent shot gun
shells on-site, there is ample reason to believe that trespassing
occurs on-site.
Although the highest carcinogenic risk associated with trespassing is
7.5 x 10~4, far higher carcinogenic risks (greater than 1 for
ingestion or dermal contact with groundwater) are associated with
future use of the site if no further action is taken to mitigate
risks.
OCmENT:
The concept of residual risk is based on the assumption of unre-
stricted development of the site, which cannot be supported. This
approach results in a presumption that institutional controls have no
value or reliability. This assumption severely penalizes remedies
that mitigate risk with the reasonable use of institutional control
versus remedies that achieve arbitrary numerical risk levels in all
media without such reliance. This concept constitutes a major flaw in
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the FS and should be corrected prior to issuance of the POO.
Institutional controls are, in fact, appropriate at this site, as
recognized by EPA in its elected preferred remedy, as described in the
Fact Sheet.
RESFCKSE:
Ihe National Contingency Plan requires that Feasibility Studies
conpare remediation alternatives against a no action alternative. It
is Agency policy that risks calculated for the no action alternative
presume no institutional controls. A fence constructed by EPA in 1987
to restrict access has been frequently vandalized, indicating that
institutional controls alone would be ineffective in eliminating risks
at the site. EPA agrees that institutional controls would be an
effective component of a full site cleanup, and have included them in
every alternative except no action. However, there is no doubt that
EPA prefers remedies that permanently and significantly reduce the
volume, toxicity or mobility of hazardous substances, pollutants, and
contaminants.
GCM4ENT:
The risks associated with the future use scenario have been grossly
overstated because they assume contact with the most contaminated
media in both soil and groundwater simultaneously and assume
unrestricted residential development of the site. However, EPA has
stated that the site is not suitable for residential development.
This site is also a wetlands area, which limits access. The Clean
Water Act (Section 404) would further restrict future use
development. EPA has failed to establish a basis for assuming
unrestricted growth for purposes of its risk assessment.
RESPCrBE:
The maximum and average contaminant concentrations were used to
characterize risks. Average concentrations in each medium were used
to characterize the risk associated with each alternative.
A residential use scenario was used to estimate worst case future use
risks, because the area has been developed for residential use within
1/8 mile of the site, and a residence adjacent to the site was
inhabited until the early 1980's. Given the extremely high risks
associated with residential use, an industrial use scenario would have
also shown substantial risk due to contact with soils and groundwater.
EPA has not stated that the site is not suitable for residential
development, except in the sense that the present gross contamination
of the site precludes safe residential use. The Clean Water Act would
not restrict future use of most of the site, since it has already been
filled.
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The FS does not accurately characterize or evaluate the no action
alternative. Reference should be made to the Phase I RI/FS for a
discussion of the no action alternative. The FS fails to evaluate
"no action" in Phase II in light of work completed in Phase I (the
interim remedy). Thus, the FS fails to reflect accurately the
actions taken during the FFS Remedy nor does it reflect the long tern
institutional controls and groundwater monitoring system that are
stated to be part of the no action alternative.
The No Action alternative did not assume any institutional controls,
as the only institutional controls included in the ROD for the Fhase I
remedy were temporary security measures during the inplementation of
the interim remedy. No Action does, however, assume the facilities
identified in the ROD are in place as a baseline condition to the FS.
adapter 3 of the FS and Section IV of this ROD describe the risks
remaining after implementation of the Phase I remedy.
OCHMENT:
EPA has used different assumptions of the level of risk reduction that
is desired in comparing remedial alternatives. If other remedial
options were compared on an equivalent basis, other alternatives, such
as the no action alternative and Alternative 2, would have compared
more favorably to Alternative 3C. Accepting the fact that EPA's
remedy will involve institutional controls, the no action alternative
(including completion of Phase I work) or Alternative 2 would compare
more favorably.
EPA used risk reduction calculations to compare different excavation
scenarios on a relative basis, and to compare in-situ versus direct
groundwater treatment methods. For the most part, EPA used a
qualitative assessment of protectiveness to compare across
alternatives, since it was not possible to fully quantify the risk
reduction provided by each Alternative.
Protectiveness is only one of several criteria EPA uses in remedy
selection. The no action alternative was rejected because it provided
no protection against exposed contaminated surface soils, among other
reasons. Alternative 2 was rejected mainly because it did not provide
adequately for long term effectiveness in prohibiting migration of
contaminated groundwater, and not because it compared unfavorably to
Alternative 3 in short term protectiveness.
COMENT:
Alternative 2 (capping, oil incineration, and institutional controls)
in addition to the Phase I remedial action, will eliminate risks to
trespassers. EPA rejected institutional controls on the premise that
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- 8
the site will be subjected to unrestricted residential development,
yet the fined remedy includes restricted use of the site, it would be
more appropriate to fence the site and restrict its use.
HESPCKSE:
EPA did not reject the use of institutional controls at the site, and
in fact these are part of the selected remedy. EPA rejected
Alternative 2, not because it did not provide protectiveness in the
short tern, but because it did not provide for adequate long term
effectiveness in controlling groundwater contamination. An
alternative solely relying on institutional controls and implemen-
tation of the Phase I remedy was not included in the final list of
alternatives because, aside from the fact that long term risks due to
contaminated groundwater would be inadequately addressed, this would
leave an unacceptable risk due to contact with contaminated surface
soils to trespassers.
OlflQIT:
Alternative 2 has been characterized in the FS as being "somewhat
more protective than Alternative 1." In fact, Alternative 2 is highly
protective of human health and the environment and effectively
mitigates all risks from the site in all media. This level of risk
reduction is not apparent in the FS because of the erroneous
assumptions used in calculating risk, such as the assumption that
contamination was evenly spread throughout the area within the slurry
wall. Thus, a determination that the slurry wall with cap, access
control, and collection of contaminated sediments and pond debris as
well as destruction of the majority of the on-site contamination (that
associated with the collected hydrocarbons) is merely somewhat more
protective than the no action remedy indicates an arbitrary bias on
the part of the EPA for a remedy that theoretically restores the site
to a condition suitable for unrestricted development.
RESPCKSE:
Protectiveness is only one of several criteria used by the Agency in
remedy selection. The primary reason Alternative 3 was selected ever
Alternative 2 was not protectiveness in the short term, but rather
because Alternative 3 provides superior long term effectiveness in
preventing migration of contaminants in groundwater.
03MEOT:
The risk reduction calculations for various levels of removal of
contaminated soils that were assessed under Alternative 3 were based
only on the removal of the contaminants and, therefore, did not
accurately quantify risk that will remain associated with contaminants
present inside or outside the slurry wall.
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KESPCN5E:
Risk reduction calculations were presented in the full-site FS for
groundwater and waste/soils inside and outside the slurry wall, and
were based on pathways of exposure to each environmental medium.
COMENT:
The FS indicates, under Alternative 3, that the calculation of
residual risk was based on an assumed percentage of contaminant
removal equated to a percentage of soil volume removed. This assumes
that the contamination is evenly spread over the entire volume of
contaminated soil found inside the slurry wall. This procedure does
not adequately address the operating history during which the wastes
were used to fill in the spaces between the natural dunes at the
site, or the "hot spots" that were identified during the RI.
Residual risks following waste and soil excavation were based on the
assumption that the excavated soils were at an average contaminant
concentration which was calculated from available analytical data.
This assumption is conservative in that the waste and soils that would
be removed under excavation Scenario C would be at a much higher
contaminant concentration due to their direct contact with the oil
layer. The actual risk reduction resulting from implementation of
Scenario C would likely be substantially higher than that presented in
the FS.
OCMMENTT:
The evaluation of the alternatives is inconsistent with the
evaluation of the selected remedy proposed by EPA. In the FS the
risk-reduction scenarios under Alternative 3 were fully developed.
All other alternatives were compared against the subalternative 3B,
which achieved the greatest level of risk reduction. This procedure
understates the effectiveness of the other Alternatives.
It was not possible to fully quantify the risk reduction provided by
each alternative. Some calculations were done to allow comparison of
the three excavation scenarios in Alternative 3, but Alternatives were
compared against each other largely on the basis of a qualitative
assessment of the relative risk reduction provided by each
alternative. In addition, Alternative 3C was selected because it
provided the best balance of all of the nine criteria considered by
EPA in remedy selection, not just on the basis of protectiveness.
OCWHEOT:
The Agency has arbitrarily chosen to burn 35,000 cubic yards of what
it believes to be the worst materials art-site, at an exorbitant cost.
The remaining material will still have a risk greater than -10"^. The
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- 10
EPA's documents point out that burning 100% of the contaminated
material would be economically impractical. Partial treatment is
being done only to satisfy the SARA preference for treatment.
RESPCNSE:
Die residual risk due to contaminated soils after implementation
of Alternative 3C was estimated in the Feasibility Study to be
5.9 x 10"4. For this reason, further protection through a RGRA cap is
included in the selected remedy. Due to limited data on distribution
of contaminants in subsurface soils, several conservative assumptions
were used in order to simplify risk calculations. The assumption made
in the FS was that contaminants are distributed evenly through
subsurface soils. In reality, the 35,000 cubic yards of highly
contaminated material would likely be at concentrations of
contaminants in excess of the assumed average concentration, making
the assumed risk reduction value a conservative estimate. The actual
residual risk after excavation and treatment of this material would
likely be substantially less than the estimated 5.9 x 10~4.
The selected alternative was not chosen solely in order to satisfy the
SARA mandate for "treatment to the maximum extent practicable", as the
commenter suggests. Rather, the selected remedy was chosen because a
combination of partial treatment and containment would, in the
Agency's judgment, attain a high level of protectiveness and long-
term effectiveness.
OOWHfT:
The proposed remedy includes flushing the site with recirculating
groundwater. However, the Feasibility Study implies that this is
senseless because the overall risk would not be reduced below the 10~3
risk level after 20 years. Containment would accomplish the same risk
reduction at 20% of the cost.
RESFCI6E:
The Agency did not independently evaluate flushing contaminated soils
with recirculating groundwater as part of the preferred remedy.
"Soil flushing", in this case, has been H-i
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- 11
replacement to ensure future protectiveness.
CO-WENT:
The FS indicates the presence of salt presents a significant risk at
the site, but does not clearly indicate that the salt is part of a
massive salt plume underlying the area and emanating from the adjacent
Indiana Department of Highways (IDCH) salt storage facility. The
document also states that the PCB risk is not believed to be
representative of the site; however, it has been included in the
calculation of risk.
KESKK5E:
It is true that the salt beneath the site is part of a large plume
that appears to emanate from the IDOH facility. PCBs were detected in
groundwater at a single off-site location, and at a concentration in
excess of the solubility limit for PCBs in water. This sample was
therefore not considered to be representative of the site, and PCBs
were not considered in the risk analysis for groundwater. However,
PCBs were detected in the oil, waste and soil on-site. Risks due to
PCB contamination in oil, waste and soil were included in the risk
analysis for the site.
2. OMfBlTS CN INTEGRATION OF THE INTERIM AND FINAL KEMkUU£>
CO-WENT:
The final remedy decision is not necessary at this time because an
operable unit remedy is currently being implemented. The final remedy
decision would benefit from information collected during implemen-
tation of the first operable unit. Further, EPA has failed to show a
need for the Phase II work.
The PRP steering committee stated in a December 27, 1988 letter in
response to the Unilateral Administrative Order for the first operable
unit that it was unreasonable to require PRPs to implement the first
operable unit when there were several unknowns relating to the final
remedy. At that fcjp*=> they requested that the implementation of the
first operable unit be delayed until the final remedy decision was
made. EPA tried to accommodate the PRPs as much as possible by moving
forward on schedule with the final remedy ROD. Now EPA is being askpri
to delay the final remedy ROD until after implementation of the
interim remedy. EPA agrees with the PRPs' initial position that
knowledge of the final remedy decision will enhance their performance
of the Phase I remedial action.
In response to the second comment, that EPA has failed to show a need
for the Phase II work, Chapter 3 of the final remedy FS describes the
substantial risks remaining after implementation of the interim
remedy. ...
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12
GCMffiMT:
The final remedy FS requires consistency with the selected Phase I
remedy as a general constraint on the development of the final site
alternatives. A major eminent of the PRPs was the selection of the
technologies for the Phase I remedy. In response to many of the major
comments, the EPA stated that a significant basis for selection of any
of the Phase I technologies was that it would be consistent with the
final site remedy. It is apparent that the EPA has been engaging in
circular reasoning, which can be used to justify any selection of
technology, and the technologies considered in the FS do not, in
fact, maintain consistency with the remedy. Several of the
alternatives (e.g., site-vide incineration) constitute a virtual
abandonment of the slurry wall that has been specified for the Phase I
remedy.
The selection of the slurry wall in the Phase I remedy was based on
several factors which considered both the Phase I remedy and the
anticipated full-site remedies. The benefits of a slurry wall in
iirplementing the Phase I remedy have been disaisspri in the June 1988
Phased Feasibility Study. Additional benefits of the slurry wall in
implementing the full-site remedy include;
The presence of the slurry wall will greatly reduce the quantity
of groundwater requiring treatment during groundwater remedi-
ation, since the flow of relatively clean groundwater into the
area of highest contamination would be restricted; and
* The slurry wall would serve to prevent migration of residual
contamination over the time in which the full-site remedy is
being implemented.
The selected remedy treats only a portion of the contaminated
soils, and leaves approximately 65,000 cubic yards of con-
taminated soils in place, mostly below the water table.
Containment reduces the possibility of migration of these
residual contaminants.
These benefits, as well as the benefits of a slurry wall to the Phase
I remedy, were considered in selecting the technology, the materials
of construction, and the placement of the barrier around the area to
be contained. An additional consideration in selecting the slurry
wall as a Phase I technology, was that it be consistent with the
technologies under consideration for the full-site remedy. The
selection of the Phase I remedy is, in fact, consistent with the
alternatives developed for the full-site remedy, none of which would
require abandonment of the slurry wall implemented as part of the
Phase I remedy.
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13
CEMENT:
The slurry wall cannot be justified as necessary to contain ground-
water, based upon the EPA's assessment of risk and grcundwater
mobility.
Containment of groundwater is not the sole justification for the
slurry wall. The primary intent of the slurry wall is to enhance the
recovery of oil during the Phase I remedy. In addition, the slurry
wall is intended to reduce the quantity of groundwater requiring
treatment during the full-site remedy, and to contain residual
contamination after implementation of the full-site remedy.
CO-WENT:
The FS fails to H-icmgg adequately the implementation problems
associated with excavation of material from within the slurry wall
that will have been constructed as part of the PFS Remedy. The
integrity of the PFS slurry wall was a major item of eminent by the
PRPs (See Reference 4) and, at that time, the EPA indicated a
recognition that slurry walls do not possess structural strength
sufficient to resist differential earth pressures. The extensive
excavation contemplated by several of the FSR alternatives may be
infeasible because of the presence of the soil-bentonite slurry wall
and could require implementation of the remedies in a different
sequence.
RESPCKSE:
A list of references was not provided with PRP cotments, however, it
is inferred from statements in the eminent letter that Reference 4 is
the Agency's September 1988 Record of Decision. As is reflected in
the responsiveness summary attached to that ROD, the integrity of the
slurry wall was, in fact, not mentioned by the PRPs as an issue during
the public comment period, nor did EPA indicate in that document a
recognition that slurry walls do not possess structural strength
sufficient to resist differential earth pressures.
The location of the slurry wall as presented in the Phase I and Phase
I FS reports, is tentative and based on available site data. As
discusspd in the Phase I remedy FS, the actual location of the slurry
wall will be based on additional subsurface data which is to be
collected during the design phase for the Phase I remedy. The final
location of the slurry wall will be selected to avoid disposal areas,
avoid filling wetlands as much as possible, and to avoid contact with
the oil layer. The wall will be located such that possible excavation
of fill material as part of the full-site remedy would not compromise
the integrity of the slurry wall.
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- 14
GCM1ENT:
The Agency has underestijnated the rate of infiltration of stormwater.
If the Agency had used an estimate of 30 inches per year for
infiltration, they would have found that combining deep well injection
of groundwater with that to be injected at the Hideo I site, would be
considerably cheaper than construction of a slurry wall.
This question pertains to the interim remedy Record of Decision signed
by the Regional Administrator in September 1988. That interim remedy
was initiated in order to respond to an immediate threat due to a
highly contaminated oil phase floating on the groundwater. At that
time no decision had been made regarding use of deep well injection at
the Hideo I site. Even if that decision had been made at that time,
it would have been inappropriate to rely on deep well injection, which
will certainly take several months to resolve permit issues, to abate
an immediate threat.
In regards to the issue of cost estimates, the June 1988 Phased
Feasibility Study assumed that, allowing some unsaturated zone
storage, an average maintenance pumping rate of approximately one
gallon per minute would be adequate to prevent overtopping of the wall
during a three year period.
If more conservative assumptions were used, and no storage of
rainwater within the slurry wall was allowed during implementation of
the interim or final remedy, an estimate of the average maintenance
pumping rate would be 6.75 gallons per minute.
An infiltration rate of 10.64 inches (30% of 35.48 inches per year,
annual normal rainfall, Gary, Indiana) over an area of 9.37 acres is
considered to be a conservative estimate of average annual conditions.
The annual volume associated with these conditions is approximately
360,000 cubic feet per year, which corresponds to an average
maintenance pumping rate of 5.1 gallons per minute. The highest
average monthly rainfall for Gary is 3.82 inches in June. This
corresponds to an infiltration volume of approximately 39,000 gallons,
assuming 30% infiltration through the sand, and an average maintenance
pumping rate of 6.75 gallons per minute.
As indicated in our response to comments for the Phase I ROD regarding
water volumes, the treatment system capacity need not be appreciably
different from that used for a 1 gallons per minute average rate, it
would simply be operated more frequently.
Assumptions regarding treatment methods and costs are the same as
those made in the PFS (Table A-l, PFS Report). The piping and
trenching costs are assumed to be the same, and the disposable carbon
units cost is increased by the ratio of 5.1:1. The difference in
capital cost for water treatment is therefore $197,400 - $38,700 =
$158,000. This would represent an increase of 11.1% relative to the
capital cost estimated for the first operable unit selected remedy,
-------
" 15
well within the +30/-50% range of accuracy for Feasibility Study cost
estimates.
3. OBMQrES ON COST KST1MAXES
OOMOT:
Incineration costs have been underestimated. On-site incineration
costs at similar sites in Illinois were $600+ per cubic yard. The
cost estimate makes no provision for solidification of the ash, which
will be required if the ash fails the EP Toxicity test or if EPA
changes the listing of incinerator ash.
Costs of on-site incineration of the excavated waste and soil are
based on quotes provided by vendors, and assume the recovered oil will
be coincinerated with the contaminated solid materials. Cost
estimates for alternatives that involve incineration presented in the
FS include mobilization, demobilization, startup, feed preparation,
extension of required utilities, and on-site disposal of residuals.
Incinerator ash will have to be treated by some means only if it is
RCRA characteristic by EP Toxicity and it exceeds standards to be set
by the Land Disposal Restrictions. Since these standards have not yet
been set, treatment was not included in cost estimate.
Since the "similar site in Illinois" was not named, it is difficult to
respond to the cost estimate given in the comment. Actual
incineration costs at the LaSalle site in Illinois have been
approximately $300 per cubic yard.
OCMffNT:
Hie alternatives considered in the FS do not adequately consider the
cost and difficulty of treating groundwater with the high concen-
trations of salt that exist because of the IDQH facility. The level
of treatment is not identified. In particular, the cost and disposal
problems are understated with respect to the disposal of the reverse
osmosis reject stream. Additionally, in the discussion and selection
of a groundwater treatment process, the effects of the salt on
treatoent process efficiency have not been addressed.
Although not specifically (tismispcl in the FS report, the effects of
the observed salt concentrations on various groundwater treatment
processes under consideration for use at the Ninth Avenue site have
been considered. These effects will also become evident in the
results of the current treatability studies being conducted by the
USAGE. Because the reverse osmosis (BO) process is being considered
as a polishing process, the reject stream should contain relatively
low concentrations of •ha*arriri*g organic compounds. The costs
associated with digpng^i of the concentrated brine reject stream were
based on experience and are considered to be somewhat conservative.
-------
16
Alternatives 2 through 6 include destruction of the on-site stored
hydrocarbons. However, the cost in Alternative 2 for hydrocarbon
destruction has not been appropriately allocated to Alternatives 3
through 6. This distorts the relative cost ocnparison of the
Alternatives.
Incineration costs for extracted oil were included in cost estimates
for all alternatives (except No Action) . It was assumed that under
the alternatives that included excavation of waste and soils, the oil
would be co-incinerated with the solid material . Therefore, the
incremental cost of incinerating the solid materials over that of
incinerating the oil only would be smaller than if the oil was
incinerated separately from the waste and soil.
The cost evaluation for all of the alternatives grossly understates
several costs. Such costs include the operating and maintenance
costs, the costs of pumping and rein j acting for the enhanced flushing
option, the cost associated with handling of residual ash and the cost
of incineration for destruction of PFS hydrocarbons.
Cost estimates for all alternatives were based on vendor quotes,
experience from similar projects, and engineering judgment. They are
within the level of accuracy the Agency typically expects from Feasi-
bility Studies, and are intended for the purpose of comparison between
alternatives. They are not intended to provide the level of accuracy
expected from a design cost estimate.
4. OTHER GCMffiNTS
GCMfENT:
The EPA has apparently dismissed in-situ treatment Alternatives based
upon a determination that these alternatives are not cost effective.
EPA is correct in the determination that they are not cost effective.
RESPCfCE:
EPA agrees that in-situ treatment methods are generally not effective
in treating the heterogeneous fill materials found at a dump site.
In order to properly compare alternatives, the level of risk reduction
to be achieved by bioreclamation should be compared to that achieved
by the preferred alternative (Alternative 3C) . Additional data on the
-------
- 17
treatability of the contaminants of concern should also have been
developed. It is likely that the cost of a bioremediation system
could be reduced. Additionally, there appears to have been an
inadequate and subjective assessment of the in-situ bioreclamation
characteristics or the pump-and-treat system, part of the selected
Alternative 3. This is demonstrated by the EPA's off-hand Garment
that soil flushing is part of the selected remedy, although this is
not clearly addressed in the Proposed Plan Fact Sheet nor the FS.
RE5PQGE:
In-situ bioreclamation was evaluated in the FS and was rejected
largely because in-situ treatment methods would likely be ineffective
in treating the heterogenous fill materials found at a dump site.
"Soil flushing", as part of the selected remedy, is intended to be an
additional benefit of groundwater treatment and not a stand-alone
technology application. The soil flushing would occur as a result of
groundwater extract ion/re inject ion, and the soil affected would be the
contaminated native soils beneath the fill inside the slurry wall.
The flashing is intended to be an incidental benefit of the
groundwater treatment system and not an active "percolation-type" soil
flushing system designed to affect contaminated source material left
in place.
-------
Page ."to.
Ol/22/aa
TITLE
APPENDIX C
ADMINISTRATIVE RECORD INDEX
9TH. AVENUE DUflP, INDIANA
AUTHOR DATE PAGES
Results froi VIAR analyses of
saaples.
Saaole results fro* Hideo I
Prehainary Assessment
Nintn Avenue Quip
Site Inspection Reoor:
US v. Kartell, et ai. Consent
• Judgaent
Mufilic Meeting Agenda
Recoonendation of placement of
•cm tor ing wells
An Inventory of the Sroundwater
Use in tne Vicinity of Hideo I,
Gary, IN
RI/FS Pnase I wry Plan
Final Jomunity Relations Plan
••isiic Te«t:nc of 3/13/80
iucer'una "rograa ?ac: iiee:
i.-~ •nv.rcriii'eritai News ^eisase
5'iWttrv or i/iaiytical .'"suits.
^roa .-essBaiing weils riesr
"::co i arc r.oc* Ii, 5ary, :N,
Robert finaedinger
81/03/13 20
Region V TAT to Beverly Kusn 82/06/03 17
CMueller - Ecology t Envrrart 83/02/02 5
EPA 83/08/08 14
US Gist Ct, NW Dist of inc. 83/01/29 20
USEPA Region V 84/12/12 5
JStrecker Ind St 3d. of Health 33/02/05 1
Seosciences Research Assoc. 86/04/00 3S1
Harzyn Engr. Inc.
Caiip, Dresser, i .icXee inc.
'JSEPA Region v
UScPA Region V
jSEPA 3eq-.cn *
9. 9oice4J£EPA RP-l
re grrunaxater
war:yn Engr. Inc.
CHSutfin - tW
86/04/00 203
86/07/00 26
Ss/oa/'.i i
86/08/00 •»
37/Ol.ci
;5 ?tn Avenue >iasa II •*:•:•"
r. 'iuoaieaenti'. '*jr« Pijn ano
riatec Plans.
-------
Page No. 1 — '
01/22/88
9TH. AVENUE DUPP, 1 NO I AM
GUIDANCE DOOJPCNTS - NOT COPIED
NflY BE REVIEWED AT EPA
IN CHICAGO, IL
TITLE AUTHOR • M7E
Rewdial Action At Waste Disposal
Sites Handbook (revised)
Policy On Flood Plains And Uetlands
Assesssents
Standard Operating Safety Guide
Manual
Superfund Rewdial Design And
Remedial Action Guidance
Guidance on Reaedial Investigations
Under CERCLfl
Superfund Puolic Health Evaluation
Manual
Intern Suid lines And 80/I2/23
Specifications
for Creoaring QAPPs
Coanumty .Relations In Sucerfund . ai/ 05/00
ayioancs or. .Reswoiai Investigations
ino -easiai:i:y itucies
NEIC Policy Procedures .tanual
State Sesoval Participation tn
Superf'inc
Rewdial Program
Addenda to State Participation in
tne
Suoerfuno Seaeflial Progru manual
-------
Pace NO. l
FICJs/'rSHPt WfcES DfiTE TI7L£
UPDflTE
flONINlSTRflTIVE RECORD INDEX
NINTH flVENUE' OUflP SITE
GARY, INDIANA
AUTHOR
RECIPIENT
DCOjnST TYPE
1 88/03/29 Record of pnone conv. mtn Allison
Arthur Carter of IDEil wno
added to the list of Indiana
ARARs the VCC Emissions
Regulations 1325 WC, 8-1.1-2
am 8-1.1-6 to be aoow to V
tne list provided in tne
2/26/88 letter.
CoBBunicition
Uoodrow flyers, Jr.-ISBw
2 65/03/21 Letter requesting
^classification of
tne Nintne Avenue
Duap Site.
2 87/04/30 Letter reflecting the status Gorcan Stoner-U.S.Dept. of
of Steve Kartell's performance Justice
of tne requirements of tne
Partial Consent Judgement and
(us obligations tuner the
saae.
'i. 87/09/24 Letter to resident enlosing Otis Ueicn
the results of Mil water
tests froa nis hone.
c 37/10/05 Notification tnat a prcracr
necsssarv.
Dennis
Valdas Asaaxus-iJE^ Cutresponderc*
A.Tigne-CotsiriIos4Cn3wIe Correspondence
fill i son rtiitrer-USEM CorrescoRCer^2
Janet • !«ac?-.'. i. Arm-
s 26. Oc/io State if ino:ana'3
or rteievanc and Aa:
Secuiresent3
'5 . as/Oj/O'i General Notice Letter
Infi:rsati.;n fteouest
Nanr/ •-.-..
flaioiev--n. £%3:t.ofEnvtr..lKt.
t ia/:>«/.Cb -.etter to.resicant enclosing Allison «:;:raj—j£S?>
resales'of analyses of ;o:.
3iao:s3 :a»-5n frcn .ner -/arc.
,'.ini2v
•X--.'-;0''.0 Mr.tp.n fly
Plan.
DUKO
Sastc-r J
-------
UPDATE
flD/llNlSTfifiTlVE KECOfiO IJ»CS£
NINTH fiVEN'JE DlflP SITE
. SfiRY, IN013M
FfiHH£ PflSEa DflTE' TITLE AUTHOR . RECIPIENT DOCLflENT TYPE
be
rwesignatea as a category l
site a an explanation of wny
accsptaole inpleoentaion of an
RI/F5 and remedial actions LS
very unlikely to be ootaineo
through responsible party
actions. -
1 87/08/24 Review of residential well Loise FaOinsKi-fiTSBR Allison HiltnerHJSEPA Keaorandua
samples dated 6/12767. _
7 67/03/10 ACTION !£«CRANtt!i1: fieaoval Sherry Kaaxe - !££>•« Valdas AoaaKus - USEW tesorandtu
Request for tne Ninth Avenue :
Duap Site, Gary, Inoiana.
21 88/02/07 List of individuals receiving USEPfl Other
notice/information requests.
8 flO/03/ci Ccsolaint in the case of Barsara flageHJ3£?A. et ai. Steve kartell, et ai.
United States v. Steve
Kartell, et al., tttiO-473,
U.S.O.C., No. Oist. of
Inciana-naBBcrw Oiv.
21 84/06/Os Orser for entry of Partial Juccs Jaaies T. *5ccy Pleacznas/Crcsrs
Consent Decrse oe entered
as of Qec=rjcer7, 1392 and "
tnat it se furtner that . .
cereriants !r/in Clarx,
Dona.a Clarv, Claries 0.
Clars, oernics J. Ciarx,
hosisr Clar1' and Jorotny
Clarx ae oisaissec wita
pr3;-u::c3 wirr. Partial • .
C:r:S5nt Decree attacneo
in tne case of United Scat::
v. Steve Kartell, et al.,
SH30--.73, U.i.O.C., No. .
D:s?. of
Div.
-------
UPDATE
ADMINISTRATIVE RECORD IMOEt
NINTH AVEMJh OUKP SITE
1#RY, INDIAN
AUTHOR
U.S.Arsy Corps of
Engineers-Guana
Geosciences and EM
« •
PwiiES DATE TITLE
86/03/00 .lanajesent Plan
Nintn Avenue Ouap Site.
87/12/00 Reaedial Investigation Of
Hilowest Solvent Recovery,
Inc.
(Hideo I) Gar/, Indiana:
Puolic Ccaaent Draft -
Appendices J Through P.
324 67/12/00 Renecial Investigation Of Geosciences and ERN
Hid*est Solvent Recovery, Inc.
(Hideo I) Gary, Indiana:
Puolic Cement Draft-
Appenoices 6 Througn I.
404 87/12/00 Renewal Investigation Of Gecsciences and ERM
Hidwest Solvent Recovery, Inc.
(Hideo I) Gary, Indiana:
Pualic Coasten:
Oraft-hcpenaices
A Througn F.
87/12/00
Investisation Of
s- Solvent Recovery,
Inc. (Rice? I) Sary,
Inciina - -Puoiic CoKsent Draft
6e«?sc:erces ano
RECIPIENT
USEPfl
Midco Trustees
Hideo Trustees
Midco Trustees
Hioeo Tnistees
DOtXWE,NT TYPE
Reports/Studies
Reports/Studies
Reports/Studies
Reports/Studies
Resorts/Studies.
ice, 87/lc/:& xjcues: for ^aaiicscle, or
rteisvcnt ind scsrocrtate
fieou:rs.iients. (A5.flSi.
17: 36/01/00 HOGsnaaa '*:•. 2 Quality
Plan
0. Iverscrt -
Ersineerina
ps of £.15. 3e:cr:3i2t'jSiSs
574 38/01/12 Tecr.nicai ^-norancua:
Grouw «:5r'-jse in-/en:ory
ncrTHSsit of. iicro I.
il-€.iJ! f»r:n Centra] Reccrts/Scuaiss
.20 aa.'0y:2 .wry Plsn --:r 'iicc
Trss:aOiii:y Besting
Plan.
57 SS/'i'/Oi wo-' J'.in *:r Tatsr-.sis
urjti::;:.::-. "?=t;nc
-------
No.
3/88
PA6E5 DATE TITLE
US 88/06/00 Phased Review Draft -
Phased Feasability Study
Ninth Avenue Dump
RI/FS, Gary, Indiana.
225 88/06/00 Puolic Review Draft -
Reoedial Investigation
Report Ninth Avenue
Ounp RI/FS Gary, Indiana:
VoluM 2 Taoles Ana figures.
306 88/06/00 PuDlic Review Draft -
Reoerial Investigation
Report Ninth Avenue Duap
RI/FS Gary, Indiana:
. . . Voluae I.
•••••- •" . ;.»-•»??-,.:£•. '
366 88/06/00 Public Review Draft -
Remedial Investigation Report
Ninth Avenue Duan RI/FS
Gary, Indiana: Volme 3
Appendix Part 1.
565 88/06/00 Public Review Draft -
Remedial Investigation
Reoort Ninth Avenue RI/FS
Gary, Indiana: Voluae 4
Acpenoix Par: 2.
UPDATE
flMINiSTRflTIVE RECORD INDEX
NINTH AVENUE 0(J«P SITE
GflKY, INDIANA
AUTHOR
Marryn Engineering Inc.
Marzyn Engineering, Inc.
Uarzyn Enginearing, Inc.
^n Engineering, Inc.
.Warryn Engineering, Inc.
RECIPIENT
02 for the USEPA
COE for tne USEPA
CCE for the USEPA
CQE for the USEPA
CCE for the USEPA
DOCUBENT TYPE
Reports/Studies
Reports/Studies
Reports/Studies
Reports/Studies
Reoorts/Stuoies
-------
••]0€/HW£ W6tS DATE TITLE
UPUOTE
REDJRO INDEX
NIN1H AVVW6 WJf* SITE
GAMY, INDIANA
WJ1HOH
RECIPIENT
DOCUSNT TYPE
DOCUW€NT
NUWKR
88/06/0.1 Letter stating the P«>
croup's position with
respect to any proposed
actions that the USfcPA
•ay adopt. Letter also
encloses a report orepared
Oy Enviror«ental Resources
Managenent-Morth Central,
Inc. for tne PRP's entitleo
•Analysis Of PuDlic Review
Draft ftused Feasibility
Study Hydrocartwn Layer
OperaBle Unit 7th Avemie
Uunp fll/KS Gary, Indiana*
61
68/09/lb Aaenaients to the
Meeting Transcript and
a MM frc* the Court
< Reporter regarding these
corrections.
68/06/03 Meeting to discuss PHP
concerns regarding tne
Ninth Avenue OIMO Phased
Feasibility Study and
Proposed Plan (along
Nttn attendenn list
to the Meting held on
7/c8/68).
88/07/13 Transcript for the Ninth
Avenue Dun Public
Meeting held on 7/13/88.
Arthur E. Slesinger-PRP
Group
Allison Hiltner-USEPA Ccrresponaence
Narti Shanks-Hlack I
Ve#tcn
Art
Correspondence
Allison HiltnerH&PA Rle
newrandui
10 87/10/16 On-Sctne Coordinators Letter
Report CERCLA Retcval Action
9th Avenue Duap - Gary,
Indiana.
545 88/01/00 Endangeroent Asseswent
Ninth Avenue Ouip - Gary,
Indiana. Supplement
Toiicity Profiles.
Carol Flores-Court
Reporter
verneta
Other
Reports/Studies
Uarzyn Lngineering Inc. USEPAKorps of Engineers Reports/Studies
42 68/09/3) Record of Decision
Valdas Adankus-USEFfl
Reports/Studies
-------
om
* 2 87/«8/87
2 87/12/U
4 88/18/18
3 8J/I1/1J
DFOM!
RECORD HDU
mm DOKF SITS
SARI, IIDim
TITLE
IOT10I
HCIflllT
OOCUUIT
DOC1UI1BBR
lequest that the Indiana Taldas idaskug-osm
Dept. of UohUTS (IDOB)
respond to thii letter
intoning thei that their
faeilitr li the only
probable toaree for
todiai tad chloride
continuation at the
IIOCO I and lloth ire.
Duip litei. leiponse
iboald outline the
IDOfl'i proposed plan
for reiediatia; the
alt eontaiinatioa.
John Correspondence
Isenbar^er-IDOB
Outline of the Indiana
Dept. of Ilfhtafi'
Consultant's proposed
activities regarding
IIDCO I and llnth
Irenne Ooip.
lotice that intonation
indicates that the
release of hazardous
substances, pollutants
and contaiinanti at the
UDCO I aad lloth ire.
Dnip Site can be
attributed
to the Indiana Dept. of
Ilfhtars (HOI) faeilitr.
This letter Is to notify
1001 of potential
liability
lith respect to these
sites.
letter of latent
submitted la accordance
with par.Ill of the
Unilateral Sec. IK
Order. Listed Is the
composition of the
til Coitittee.
D.I. Lncas-II Dept. of
Ilghfays
Richard 8oice-QSIFI Correspondence
lary Cade-OSm
lilllai T. Hay-IDOH Correspondence
Susaa Idiard Correspondence
rileder-lildian,!arrold,et al loialskl-SSIFi
1 8J/I2/14 additional cost
Ulison Illtner-asm
linth ifcnne Dnip Keiorandni
-------
All PAGSS Oiri
117 M/12/17
IS S8/I4/M
14 M/I8/1S
232 J?/«1/I9
2« 19/41/11
21 89/13/69
rim
ealcnlatloai
for the lioth Areaae Daip
reaiibilitr Stndr.
Adilaiitratirt Order
Partoiat
To Section Hi of CIRCLA.
Scope of fork for The
Hath Areaae Daip
Saperfoad Site Ground
liter TreiUbilitf
Stadf.
Scope of fork for The
Hath Arcane Daip
Soperfaad
Site Slarrf Treach
laterialt/
Croaodiater
Coipatlbilitr.
Poblle Rerlet Draft
foil Site teaedr
ftuibilUy Stodr
Health iiieiiaeet
Propoied flaa
Hath arcane Oaio
Car?, ladlaoa.
mm
URIIISTRATITK RSCORD I1DU
IIITH miOK OOKP SIT!
GiRT, IIOIAIA
AUTHOR
Bull CoBttaoteloi-OSIPA
O.S.Arar Corpa of laflaeeri
RKCIPIIIT
File
Reipoadeota
I.S.Arar Corpi of laflaeeri
larzya lojlaeeriaf
ATSOR
ISIPA
OSCOI i OSIPA
OSIPA
DOCDKKIT TTPI
Pleadiafa/Orderi
Reporti/Stodles
teporta/Stodiea
DOCIOSB8R
Reporti/Stodlet 3
Reporti/Stodiei II
leporta/Stadlei 11
------- |