PB95-964118 EPA/ROD/R05-95/293 March 1996 EPA Superfund Record of Decision: Southside Sanitary Landfill, Indianapolis, IN 9/28/1995 ------- DECLARATION FOR THE STATE RECORD OF DECISION SITE NAME AND LOCATION Southside Sanitary Landfill Indianapolis, Indiana STATEMENT OF BASIS AND PURPOSE This decision document presents the selected remedial action for the Southside Sanitary Landfill (SSL) site, in Indianapolis, Indiana, developed in accordance with CERCLA, as amended by SARA, 42 USC 9601 et.seq. and, to the extent practicable the National Contingency Plan 40 CFR 300. This decision is based on the administrative record for this site developed by Indiana Department of Environmental Management. The US EPA concurs with the selected remedial action. DESCRIPTION OF THE REMEDY The results of the Remedial Investigation showed the previous remedial measures were adequate to protect human health and the environment and no unacceptable risk remains at the site. Therefore, the selected remedy for this site is a no further action. The operators of SSL have undertaken specific remedial measures in an attempt to decrease any threat of release of contaminants from the site. The measure included installation of a hydraulic cut-off barrier and leachate collection system. These actions were undertaken to comply with the requirements of an Agreed Order (AO) signed between the State and Southside Sanitary Landfill, Inc., under Cause No. N-243, approved on November 25, 1986. The AO provided for^onstruction and installation of a hydraulic cut-off barrier and leachate collection system. Additionally the AO prequired the following: a performance monitoring system, cover and grading requirements, operating procedures, closing and post-closing procedures and requirements and the establishment of both closure and post-closure funds. This site is currently regulated under a State issued Southside Sanitary Landfill Permit No. OPP 49-1. An evaluation of permit requirements indicated that the SSL is in compliance with the ground water requirements of 329IAC 2- 16 and the site is subjected to regular inspections and monitoring schedules for a minimum period of 30 years after the closure of the landfill. Due to effective implementation of remedial measures, as described above in compliance with the AO requirements, IDEM has determined that no further action is necessary at the site under Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) requirements. ------- Record of Decision Page 2 of 19 Southside Sanitary Landfill DECLARATION The Remedial Investigation results and risk assessment evaluation established that chemical contamination discovered at the site, with current remedial measures in place, does not pose unacceptable risk to the environment and human health. However, as the waste is in place and contained, IDEM recommends a 5-year review of site status which includes physical inspection of the site and a review of monitoring data. The current operating permit would serve as an effective monitoring tool to mitigate any unforeseen actions at the site. Based on the RI analytical data available at this time, IDEM believes that the existing remedial measures provide the best protection of human health and environment, achieve compliance with Applicable, Relevant and Appropriate Regulations (ARARs), eliminate long term risks, reduce toxicity and mobility. Therefore, no further action under CERCLA is appropriate at this site. COMMISSIONER " DATE Indiana Department of Environmental Management ------- Record of Decision Page 3 of 19 Southside Sanitary Landfill RECORD OF DECISION SUMMARY SOUTHSIDE SANITARY LANDFILL INDIANAPOLIS, INDIANA A. SITE NAME, LOCATION AND DESCRIPTION Southside Sanitary Landfill (SSL), an active sanitary landfill, occupies 312 acres in Decatur Township, Marion County (Figure 1). The landfill is located on the west bank of the White River, where it joins with Eagle Creek, one-half mile south of intersection of Kentucky Avenue and Warman Road. The site location is approximately 4.5 miles southwest of downtown Indianapolis. The boundaries of the site include Eagle Creek and White River to the east and south of the landfill and to the west are portions of the Martin Marietta limestone mine and Strakis Lake. B. SITE HISTORY Landfill operations at this site began in 1971. The initial operation was based on a cut and fill procedure. A trench, approximately 100 feet wide and 8 feet deep, was excavated, filled with solid waste, and then covered. After trenching was found to expose sand and/or gravel pockets, a compacted soil liner was placed under the fill. In 1981, operations switched to the area method of filling which consists of dumping, spreading, and covering. Most of the waste disposed of at the landfill is believed to be typical municipal solid waste. However, waste from industry and agriculture was also disposed of at Southside Landfill over the years. Groundwater monitoring for contamination at the landfill began in 1973 when the United States Geological Survey installed 24 wells around the portion of the landfill permitted to accept wastes. The wells were part of a study to determine the nature and extent of groundwater contamination in the vicinity of landfills in Marion County. In 1981, as part of a national survey of industrial waste disposal practices prior to implementation of the Resource Conservation and Recovery Act (RCRA), four firms listed Southside Sanitary Landfill as a disposal site for their wastes. Small quantities of hazardous wastes were possibly sent to the landfill. This notification was sufficient to initiate evaluation of Southside Landfill for inclusion on the National Priorities List (NPL). In 1984, U.S. EPA contractors conducted a site inspection at the facility to acquire the data needed for Hazard Ranking System scoring. On-site wells sampled indicated the ------- ^//-r^ :4&i$/ SCALE: 1 INCH 2000 FEET TOPOGRAPHY TAKEN FROM -. 1980 MAYWOOD. INDIANA U.S.G.S. QUADRANGLES IND FIGURE « SITE LOCATION Marion County, Indiana ------- Record of Decision Page 4 of 13 Southside Sanitary Landfill presence of heavy metals in the ground water at the facility. The site was scored and nominated for the NPL in 1986, and finalized on the NPL in March 1989. In 1985, the Southside Sanitary Landfill operator signed an Agreed Order with the Indiana State Board of Health to correct drainage problems identified on the landfill surface. In 1986, the landfill operators signed an Agreed Order with IDEM to construct a barrier (known as slurry wall) below the grade and a leachate collection system to prevent potentially contaminated ground water from leaving the landfill and entering local groundwater supplies. The Agreed Order, which also permitted vertical expansion of the facility, currently serves as the operating permit for Southside Sanitary Landfill. C. COMMUNITY PARTICIPATION Section 117 (a) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA), requires that notice be published and a brief analysis of the Proposed Plan for site remediation be made available to the public. The Proposed Plan also outlines the public's role in helping IDEM as the lead Agency, and U.S. EPA as the support Agency, made a final choice on the preferred alternative. The Role of Community The first public meeting was conducted at the beginning of the RI process in September 1992, at the Indiana Government Center South, in Indianapolis. IDEM developed an Administrative Record and placed at the site information Repository of public view. The final public meeting was conducted in June 1995, after the RI completion and development of a Proposed Plan for Remedial Action at the site. Before the public meeting, IDEM prepared Fact Sheets describing site activtiites and mailed to the local residents, officials and media for information. The IDEM believed that the preferred method of cleanup at this site should meet the local community needs, in addition to being an effective solution to the existing problems. Therefore, IDEM as the lead Agency in consultation with U.S. EPA set a public comment period from June 19, to July 19, 1995, to encourage public participation in the remedy selection process. This comment period included a public meeting where U.S. EPA and IDEM discussed the RI report findings, the Proposed Plan, answered any questions and received formal comments. Comments were solicited on the Proposed Plan and the RI report. The RI report and numerous other documents regarding the site are available at the Information Repository. The repository is located at Indianapolis Public Library, 40 East ------- Record of Decision Page 5 of 19 Southside—Sanitary Landfill St. Clair Street, Indianapolis, IN 46204. These documents comprise the administrative record for the site. The proposed plan is the preliminary choice to remediate the contamination problems at the site. IDEM made the final selection only after consideration of all written and oral comments received on the remedial action described in the Proposed Plan. The IDEM encouraged the public to review and comment on both the RI report and the proposed plan. Comments received during the public comment period were responded to in the Responsiveness Summary Section of the Record of Decision (ROD). This decision document presents the selected remedial action for the SSL site in Indianapolis chosen in accordance with CERCLA, as amended by SARA, and to the extent practicable, the National Contingency Plan. D. SCOPE AND ROLE OF RESPONSE ACTIONS AT THE SITE Hydraulic Cut-off Barrier (Slurry Wain As part of an Agreed Order with IDEM dated November 25, 1986, the Southside Sanitary Landfill agreed to install a hydraulic cut-off barrier (Slurry Wall) and a leachate control system in order to isolate groundwater beneath the landfill from surrounding groundwater. The hydraulic cut-off barrier was completed on September 29, 1988, and surrounds the fill for a total length of 17,000 linear feet approximately. The average depth of cut-off is 91 feet and ranges between 43 and 105 feet. The purpose of the cut-off wall is to provide essentially an impermeable barrier to groundwater movement between the inside and outside of the wall, while an interior leachate control drain collects leachate from any rainfall percolation. The groundwater levels inside the wall are maintained at a minimum of six inches below groundwater levels outside the wall, so that there is always an inward hydraulic gradient to insure that leakage through or beneath the wall is always into the landfill. Thus, there is two fold protection of surrounding groundwater: an effective impermeable cut-off wall and maintenance of an inward hydraulic gradient to insure that no inside groundwater escapes the landfill. Effect of Hydraulic Cut-Off Barrier on Groundwater As part of the cut-off barrier design, an interior lateral drain maintains groundwater levels inside the wall lower than groundwater levels outside, thus constantly maintaining and ------- Record of Decision Page 6 of 19 Southside-Sanitary Landfill inward hydraulic potential. Since April 1989, groundwater levels inside the wall have averaged approximately 9 feet lower than levels outside the wall in both shallow and deep aquifers. The effect of the perimeter cut-off wall on outside groundwater flow east of the landfill is to remove the pathway of groundwater movement from Eagle Creek and White River westward under the landfill. Groundwater originating from Eagle Creek and White River now either flows due westward along the northern boundary of the landfill or southward along a narrow strip of aquifer between the cut-off barrier and the streams. Similarly, groundwater flow in the deep aquifer which, prior to the slurry wall moved from northeast to southwest and south through the landfill are shunted off more southward. Along the western side of the landfill, flow between the upper aquifer beneath the landfill and Strakis Lake is no longer occurring. Based on groundwater levels from wells outside the wall on the west side, groundwater in the shallow aquifer is converging toward the area near the northeast portion of Strakis Lake from the south and north. This is similar to the pattern seen in groundwater levels prior to construction of the slurry wall with the exception that there is no longer flow from the east. The flow from the upper aquifer is likely draining downward to the deep aquifer where the till is absent and also where there is a consistent downward hydraulic potential. In the deep aquifer, groundwater appears to be consistently moving southward parallel to the cut-off wall boundary. In summary, the cut-off barrier practically isolates the aquifer beneath the landfill from the outside groundwater regime and forces outside groundwater movement to skirt its boundaries. Thus, contaminated groundwater is prevented from leaving the site and potential threat to the surrounding media has been eliminated. E. SUMMARY OF THE SITE CHARACTERISTICS Geology The Southside Sanitary Landfill is situated at the confluence of White River and Eagle Creek and lies within the center of the outwash deposit. The Phase I investigation has revealed that the glacial till has been found to be a substantial deposit throughout the site. Beneath the landfill waste is a thin silty clay layer that is either a natural deposit or a compacted liner constructed from locally excavated surficial soils. The next layer down is the sand and gravel of the shallow aquifer. This layer is 5 to 37 feet thick. Beneath the shallow aquifer is a dense glacial till, the thickness ranging from 4 to 6 feet. Beneath the till is a thicker sand and gravel layer that forms the deeper aquifer beneath this site. This unit thickness ranges from 10 to 40 feet. Underlying this sand and gravel is the Black ------- Record of Decision Page 7 of 19 Southsicte Sanitary Landfill New Albany shale as bedrock. Hydrogeology and Hydrology The site is situated in an outwash valley aquifer. The outwash aquifer is divided into two distinct hydrogeologic units, the shallow upper and a deep lower aquifer, separated by a glacial till that has an average permeability of 2X10'7 cm/sec. The general ground water flow direction in the upper and lower aquifer is from east to west during most of the year. The investigation revealed that the ground water levels in the upper outwash valley aquifer are impacted by industry existing in the vicinity of site, such as GM Allison and American Aggregate, and other surface water bodies like Eagle Creek, White River and numerous surrounding ponds and lakes created by sand and gravel quarry operations. Groundwater and surface water users to the southeast of the site have less of an effect on groundwater flow directions on-site, because White River serves as a major divide. Tn addition, the bedrock high in the southeast portion of the landfill has the effect of inhibiting hydraulic communication in the lower aquifer between the southeast and northwest areas of the site. There are existing high capacity wells that extend into the lower aquifer and draw groundwater from both the upper and lower aquifers. There is an IPL check dam existing southeast of the site constructed across White River. This dam caused a buildup of head in White River to levels higher than adjacent aquifer heads. There is considerable flow of surface water from the major surface water bodies Eagle Creek and White River into the upper aquifer. Flow from these streams has occurred throughout the landfill's history based on the fact that IPL check dam has been existing at this location and has been a significant contributing factor for over 40 years. Groundwater was also entering the northwest portion of the site from north and northeast. The groundwater flow velocities beneath the site range between 7 to 29 feet per day. A portion of water entering the upper aquifer from streams re-entered White River down stream of the IPL dam. Some entered other existing water bodies such as South Pond and Strakis Lake. Groundwater: Ground water in the upper and lower aquifers has generally flowed east to west for most of the operational life of the landfill. Eagle Creek and White River above the (IPL) check dam are upgradient of the site. The major receptor locations for groundwater flowing beneath the landfill prior to the construction of the hydraulic cut off barrier (slurry wall) included surface water bodies like South Pond, Strakis Lake, and White River (below ------- Table 1 Contaminants Detected in Grouncivater Samples Southside Landfill Site, Indianapolis, IN Contaminants VOCs Chloroform Benzene Toluene Acetone Methylene chloride 2-butanone SVOCs Bis (2-ethyl-hexyl) Phthalate Inoraanics Aluminum Arsenic Ant imony Ammonia Barium Beryllium Cadimum Calcium Chromium Chloride Copper Iron Lead Magnesium Maganese Mercury Nickel Potassium Selenium Silver Sodium Thallium Vanadium Zinc Cyanide Maximum Concentration Levels (mg/1) 0.028 BJ 0.002 J 0.001 J 0.013 0.001 0.010 U 0.039 J 0.269 0.004 J 0.035 U 0.110 J 0.149 B 0.001 U 0.003 U 68.80 0.007 B 100.0 0.236 B 1.680 B 0.005 23.70 0.113 ND 0.015 6.070 U 0.002 0.007 B 45.80 0.002 0.003 U 0.090 U 0.010 U Allowable MCLs (mg/1) 0.005 1.000 0.005 0.006 0.050 0.006 2.000 0.004 0.005 0.100 0.005 0.002 0.050 0.050 0.002 0.200 All concentration in milligrams per liter. U * the compound was not detected a'! "V^aYuV^fess than the Contract Required detection limit but; greater-than ^ detection limit. when used as subqualifer. it means the valu^ is qualifed due to contamination problems. ------- Record of Decision Page 8 of 19 Southside~Sanitary Landfill IPL's check dam). The ground water analysis generally showed no discernible contaminant plume or pattern of contamination that can be attributed directly to the landfill. The compounds detected were at low levels below Maximum Contaminant Level (MCL), and occurred primarily in upgradient river side wells. For on-site wells there was very little difference in overall ground water quality between upgradient and downgradient wells leading to the conclusion that the ground water contamination is intact and contained within the site. The ground water sampling conducted at this site can be divided into two major categories for the purpose of ground water quality analyses: 1. The routine parameter analysis conducted from 1973-1984. The analyses included only a few inorganic and organic parameters: and 2. The routine parameters, expanded by the State agency monitoring programs to include additional inorganic and organic parameters. These monitoring programs (with expanded parameters) served as an independent check on the landfill's quarterly ground water data. The State agencies (IDOH and IDEM) conducted sampling in 1984, 1985, 1989 and 1993 with expanded parameter analyses. The metals results from all wells (1984) were below MCLs. Only the iron and manganese exceeded secondary MCLs in both upgradient and downgradient wells. In 1985 sampling chromium exceeded MCLs. Silver concentrations exceeding MCL levels were detected in river side wells. All of the detections being on the river side, it was concluded that the source of silver and chromium contamination was from further east to northeast off-site. In 1985, the ISBH conducted the first on-site sampling which included the priority pollutant compounds for analytical purposes. Six (6) Volatile Organic Compounds (VOCs) were detected at levels ranging from 3 to 15 ug/1 (parts per billion) in a downgradient deep well (MW22). In 1989, following completion of the hydraulic cut-off barrier, IDEM conducted another sampling event. The analyses showed an increase in sulphate and chloride concentrations compared to 1985, while most metallic compounds were lower. The previously detected (1985) silver and chromium were not detected in the 1989 sampling event. Five (5) VOCs were detected including the most prominent compound tetrachlorethene (TCE). Two detections were in upgradient river side wells and three were in wells which are considered downgradient of the landfill prior to the construction of the hydraulic cut off barrier. Tetrahydrofuran (THF) was detected in one downgradient well (MW-27) which was determined to be an isolated detection possibly due to well construction. Based on the analyses of priority pollutants sampling, no direct impact from the landfill is evident. The elevated levels of metals and organic compounds were detected in ------- Record of Decision Page 9 of 19 Southside Sanitary Landfill upgradient wells for which the source of contamination is not the landfill. A list of contaminants present in groundwater with maximum concentration are presented in Table 1 of this document. Surface Water The surface water samples were collected from major water bodies in the vicinity of the site. They included Eagle Creek, White River, Strakis Lake and South Pond. The sample analyses included priority pollutants, inorganic and organic parameters. The results from Eagle Creek samples indicated a general decrease in concentrations with time for most parameters with the exception of chlorides. Chlorides showed significant increase in trenches ranging between 40 to 140 milligrams per liter (parts per million). The priority pollutant analysis indicated tetrachlorethane concentration at 36 to 38 ug/l (parts per billion). * The historic sampling from White River and Eagle Creek indicated that there is no impact from the landfill. None of the metals tested for were detected at levels which exceeded MCLs. The water quality in Strakis Lake and South Pond was also similar to White River quality except that total dissolved solids for the ponds were slightly higher than that of White River. Also, dissolved iron in South Pond was lower than Strakis Lake and White River by a one-forth to one-tenth. Following the completion of the cut-orTbarrier (slurry wall), infiltration from Eagle Creek is divided between a westerly flow north of the landfill and a southerly flow along with White River infiltration along the narrow strip of aquifer east of the landfill. Also, as a result of the cut-off barrier, Strakis Lake no longer flows into, nor receives water from beneath the landfill. South Pond is also currently cut-off from the landfill and receives input from Strakis Lake. A list of contaminants with maximum concentrations present in surface water are presented in Table 2 of this document. Landfill Waste The wastes accepted at Southside Sanitary Landfill have been general municipal and solid waste. There is no evidence of any hazardous waste. The historic information revealed that a large amount of special wastes consist of industrial sludge and wastes from manufacturing operations, the most common of which is metal grinding. Overall, the inorganic waste streams appear to have been more prevalent than organic waste with the exception of mycelia waste. There is no evidence in support of PCBs or dioxin contaminated waste. Leaehate ------- Table 2 Contaminants Detected in Surface Water Samples Southside Landfill Site, Indianaoolis, IN Contaminant VOCs Acetone Toluene SVOCs Bis (2 -ethyl hexyl) phthalate Inoraanics Aluminum Arsenic Ant imony Barium Beryllium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Maganese Potassium Selenium Silver Sodium Thallium Vanadium Zinc Cyanide Maximum Concentration mg/1 0.014 J 0.004 J 0.001 J 0.486 B 0.003 B 0.046 U 0.092 B 0.001 0.003 U 539.0 0.003 U 0.007 J 0.009 0.779 0.005 26.10 0.059 7.290 0.002 0.003 54.10 0.002 U 0.014 B 0.022 J 0.010 U Allowable MCLs 0.006 0.050 0.006 2.000 0.004 0.004 0.100 0.005 0.050 0.050 0.002 0.200 All concencration in milligrams per liter. U = che compound was noc detected J = estimated value B = The value is less than the Contract Required detection limit but greater than the instrument detection limit, when used as subqualifer. it means the value is qualifed due to blank contamination problems. ------- Record of Decision Page 10 of 13 SouthsideT Sanitary Landfill Four (4) Volatile Organic Compounds (VOC) were detected in a full strength leachate sample collected from inside of the slurry wall. The leachate collection system monitored since the construction of the hydraulic cut-off barrier (slurry wall) indicated one detection of benzene. No acid extractable compounds were detected, but two base/neutral extractable compounds - naphthalene and bis(2-ethylhexyl) phthalate were detected in leachate samples. The leachate sampling indicated presence of three pesticide compounds - heptachlor, the beta and delta isomers of benzene and hexachloride which are attributable to background soils in the area. A comparison of the results for leachate samples with the data published by the U.S. EPA for municipal landfill leachates indicated that the Southside Sanitary Landfill leachate is a relatively weak-strength leachate. The relative weakness of the Southside Sanitary Landfill leachate sample is further highlighted by a comparison with the Maximum Contaminant Levels (MCL) established by the U.S. EPA for drinking water. The concentrations of nearly all of the parameters in the leachate sample for which MCLs have been set are close to or lower than those MCLs. A list of contaminants found in leachate samples are found in Table 3 of this proposed plan. Sediment Compounds detected in the sediment samples included metals, polynuclear aromatic and pesticides. The metal concentrations found in general showed Jow values with the exception of antimony and cadmium. Neither of these compounds were detected in the landfill so their presence in the neighboring environment is concluded to be unrelated to the landfill. The polynuclear aromatic (PNA) compounds detected included two naphthalene and 2-methylnapthalene from upstream locations of White River and Eagle Creek. The presence of naphthalene and 2-methylnapthalene in the upstream white River and Eagle Creek samples is concluded to be not site related. The concentration of total PNA detected range from zero to 6.76 parts per million. The last category of compounds detected in sediments are two kinds of pesticide compounds, heptachlor and delta benzene hexachloride. The concentrations indicated similar to background concentration surrounding the landfill. A list of contaminants with maximum concentrations found in sediments are presented hi Table 4 of this proposed plan. VI. SUMMARY OF STTE RISKS: As Southside Sanitary Landfill site has a long history of accepting a variety of wastes, an analysis was conducted to estimate potential health and environmental problems that could result if appropriate remedial action is not taken. This analysis is referred to as a ------- TABLE 3 SOUTH SIDE LANDFILL LANDFILL LEACEATE COMPOUNDS DETECTED GROUNDWATER SURFACE WATER COMPOUND ARSENIC ARSENIC CHROMIUM CHROMIUM COPPER COPPER IRON IRON LEAD LEAD NICKEL NICKEL SILVER SILVER ZINC ZINC BENZENE TETRACHLOROETHYLENE NAPHTHALENE 2 -METHYLNAPHTHALENE BIS-2 -ETHYLYHEXYL PHTHALATE DELTA- BHC HEPTACHLOR CONCENTRA TION RANGE ug/1 <3-4.2 <3-3.4 <4-12.3 <3-7.3 <4-23.6 <4-5.6 282-3640 <25-2290 <2-5.3 <2-11.4 <30 <15 <4 <3-7.l <14. 2-127 <6.8-58.2 2 <10 <10 <10 <10 <0.055 <0.055 ALLOWABLE MCL 50 100 1300' 3001 15l 100 100' 5000' 5 5 NS NS 6 0.2 0.4 ._ _ CONCENTRATION RANG^B ug/1 ^^ <2-3.6 <2.0 <4.0 <4.0 <9.2 <4.6 <87. 0-779 44.7-47.4 <2.-5.4 <2.0 <6-9.2 <15.0 <3.0 ^P <4.0 <4.8-21.2 <5.0-6.2 <10 <10 <10 <10 1 <0.054 <0.054 Notes: NS = No standard available 1 = These are action levels for drinking water supplies and are acceptable if more than 10% of water supply samples during a monitoring period exceed these values. 2 = Secondary standards based primarily on aesthetics; not enforceable under federal statutes. < = Means this compound may be present but it is below detectior level. ------- Record of Decision Page 11 of 19 Southside~Sanitary Landfill Baseline Risk Assessment (RA). The RA has mainly focused on human health and the environment. The contaminant database used for risk assessment analysis consists of groundwater, surface water, soil, surface drainage sediment near the landfill. The RA study included identification of exposure pathways and migration of contaminants from the site. Exposure pathways are assumed to be complete if there is a mechanism by which humans may come into contact with site-related media. All of the media at the Southside Sanitary Landfill (except leachate) may potentially be contacted by humans. The following pathways are found to be theoretically complete: Residential groundwater use pathways: ingestion, dermal contact and inhalation of volatile organic compounds (VOCs) in indoor air (the nearest residential well is approximately 1/2 mile from the site). t Surface water use pathways (primarily Strakis Lake and South Pond, but possibly also the White River): dermal contact, incidental ingestion and ingestion offish which have bioaccumulated contaminants from water. Surface soil/sediment pathways: dermal contact and incidental ingestion on-site drainage ditches. Air pathways: inhalation of VOCs or dust particles in areas downwind of the landfill. There is, in general, no basis for assuming that on-site areas may become residential or publicly accessible in the future as long as the site is regulated under a State issued permit and through the post-closure period (at least 30 years after the closure of the site). However, when leachate from the landfill is pumped directly to the City of Indianapolis sewer system the sewer maintenance crew might come in contact with leachate. In order to assess the groundwater pathway, analytical data from potential receptor well locations was used. Monitoring wells MW-1B, R-l and WP-19 are lower aquifer downgradient wells which are identified as potential receptors for any contamination release from the landfill. The constituents identified in these wells are mostly laboratory contaminants. There was only one exceedence of MCLs reported for Bis-(2-ethylhexyl) phthalate at concentrations 360 ug/1 from Monitoring Well-1 (MW-1). But the duplicate sample from the same well had no detection of Bis (2-ethylhexyl) phthalate. The analytical data suggested that the compound was introduced either during sampling event or during ethylhexyl) phthalate is a known lab artifact. The concentrations of the ------- Table 4 Concaminancs Detected in Sedimencs Samples Southside Landfill Site, Indianapolis, IN Contaminants VOCs Acetone 2-Butone Methylene Chloride Toluene SVOCs Anthracene Acenaphthylene Acephthene Benzo (b) Fluoranthene Benzo (k) Fluoranthene Benzo (a) Pyrene Benzo (g,h, i) Perylene Butyl benzyl phthalate Bis (2-ethyl-Hexyl) Phthalate Chrysene 4 Chloro-Aniline Carbozole Dibenz ( a, h) Anthracene Dibenzo furan Di-n-octyl Phthalate Fluor Anthrene Indeno (l,2,3-(d) Pyrene Naphthalene Pyrene Inoraanics Aluminum Ant imony Arsenic Barium Beryllium Cadmium Calcium Chromium Cobalt Copper Iron Lead Magnesium Manganese Mercury Nickel Pot'asium Selenium Silver Sodium Thallium Vanadium Zinc Cyanide Maximum 0.016 0.013 0.012 0.013 0.470 0.250 0.140 1.500 0.900 1.500 0.800 0.069 1.100 1.800 0.100 0.320 0.310 0.071 0.053 2.700 0.910 0.055 2.500 5680 9.10 5.400 39.30 0.290 0.780 110,000 10.10 4.00 11.90 11,700 13.50 33,900 313.0 0.140 6.500 870.0 0.520 1.000 189.0 0.052 11.800 28.00 0.570 Concentration mg/k^| ^1 U U U J J J U J J J J J J • J J J J J UJ J UJ U U J J J J J J U B B U UJ UJ U B UJ U • mmm* not d>t*ctM. v«iu» (noun i« mm d«c*ct liatt. NO » NMIW CM Mt*ri*i vu •ntlyiM tor. Due v*» net o*t*ct«d. J • M*n* «n ••tiB4tM ««IIM B . ••«•« el<» Mlu* i« !••• th«B ck» concr*et **quind detection lisit but gr>at*r th«n th« »"»•«—--- - „„,_.-...... . «r than th. trutnMt d.t«ction liait. *»• uMrt u •uMMtiUr. th» ««!IM i« qu*iif*d du« to t>l«n« cont«.»o*t»on pnel«M. o)*t*ecion limit ictBbl buc ------- Record of Decision Page 12 of 19 Southside Sanitary Landfill compounds present did not exceed the Maximum Contaminant Levels (MCLs) which are promulgated based on protection of human health. For Inorganics, the only contraventions noted are for manganese and iron. A relative comparison of analytical data was performed using sampling results prior to cut-off wall construction and following the completion of cut-off wall construction. The purpose of this study was to analyze the chemical pattern of compounds. The patterns of concentrations in the sampling events do not show significant differences between upgradient wells along Eagle Creek and downgradient wells on the west side of the landfill. From the analysis no impact from the landfill was discernable. No plume or pattern of contamination was evident. In addition, the elevated levels for metals and organic compounds were detected in upgradient wells only. This led to the conclusion that the source of contamination identified is either from the river or industries lying to the north or east of the site. The detailed analysis of the pattern of these compounds did not indicate the site as a source. Manganese showed highest concentration in upgradient well (MW-2). Antimony was identified in several groundwater samples from the Phase II investigation. For confirmation of results, the groundwater and surface water locations were resampled for antimony in the Supplemental Investigations. No antimony was detected in this second sampling. This contaminant has therefore, been confirmed to be absent down to the instrument detection levels used in this investigation (35-40 ug/1). Despite its common presence as a laboratory contaminant, the possibility existed that bis(2-ethylhexyl) phthalate is a site-related constituent. It was not found in any of the associated blanks, nor in upgradient wells but has been reported in landfill leachate. However, the concentrations are extremely low. It was not detected above the method quantitation limits, with the maximum reported value being an estimated 9 ug/1 (parts per billion). These results indicate the absence of groundwater contamination that would present a risk to human health at the site, and no impact on human health through the use of groundwater is anticipated. Surface water locations which potentially receive drainage from the site are, Strakis Lake (samples SW13, SW14 and SW16), South Pond (samples SW10 through SW12) and the White River downstream of the check dam (sample SW6). No site-related contamination was observed in the downstream surface water locations. Traces of organic constituents are typical laboratory contaminants, with the possible exception of toluene. Toluene, however, has not been found in landfill leachate and demonstrated no concentration gradient relative to the site. Furthermore, detected concentrations are below Indiana Surface Water Quality Standards. The only inorganics found in surface water that have also been detected in leachate were lead and zinc. These metals were also found in the upstream White River sample (SW13) at similar concentrations. In general, contamination of surface water with landfill derived constituents was not found. ------- Record of_Decision Page 13 of 19 Southside Sanitary Landfill Sediments in surface water locations which potentially receive run-off from the site are Strakis Lake (samples SD13, SDH and SD16), South Pond (samples SD10 through SD12) and the White River downstream of the check dam (samples SD5 and SD7). A variety of pesticides were found at estimated concentrations in these locations. However, when compared with upstream locations in the White River and Eagle Creek (SD1 through SD4), no pattern of pesticide loading emerges. PCBs were almost entirely confined to these upstream locations. VOCs in downstream locations were limited to laboratory contaminants and are, therefore, considered to be artifacts. Inorganics concentrations were consistent with normal ranges and did not show elevations in downstream locations when compared with upstream. In fact, the maximum concentrations of several metals, including iron, manganese, lead and zinc, were found only in upstream samples. A variety of polynuclear aromatic hydrocarbons (PNAs) were detected in surface sediments in the study area. PNAs bind to organic carbon in sediments, and are therefore, frequently normalized for organic carbon and expressed as ug PNAs/gOC (or parts per million). The data analyzed confirmed that PNA results for sediment sample SD6 (180 ug/gOC) were within the range of results for other downstream samples (which ranged from 107 to 320 ug/gOC). The results also confirm that the high concentrations of PNAs (880 to 1100 ug/gOC) are found at the location most upstream of the site. The other PNA locations SD2 and SD3 (at concentrations 330 and 700 ug/gOC) reported are also upstream of the site. In addition, the PNA concentrations are within the range of both typical urban and local sediment PNA background concentrations. These findings indicate that the site is not contributing to PNA loading to downstream sediments. As PNAs were found on-site in the two surface drainage ditches, a theoretically complete exposure pathway exists for on-site workers through dermal contact. The location with maximum PNAs (6.7 ppm in SD9) was used as the most conservative value for risk assessment purposes. Since the area in which the on-site surface sediment samples were collected is not part of the active landfilling operations, worker exposure is limited to frequency and type of activities performed in this area. The major activity involves mowing vegetation. Worker exposure was therefore assumed to occur on average of twice a month for 25 years. Half daily incidental ingestion was assumed to occur in this area. Dermal contact was assumed to occur with upper extremities. Inhalation of VOCs was identified as a potentially complete exposure pathway. However, there is no conclusive data to confirm the presence of this pathway. Landfill gas sampling was conducted to evaluate the potential for landfill gas utilization. A variety of halogenated hydrocarbons typically associated with landfill gas were identified, ------- Record of_ Decision Page 14 of 19 Southside Sanitary Landfill at below 10 parts per million. Because of low concentrations, even if gas is released to the atmosphere, the constituents dissipate so rapidly that ambient air concentrations are not detectable. For this reason, risks associated with ambient air contamination at landfills are generally very low and are not subject to critical evaluation. At the Southside Landfill contamination is limited to the subsurface and the exposed waste is capped. This eliminates the potential for dust particles from the landfill, and makes VOC emissions very unlikely. In addition, there is a landfill gas collection system. Ambient air contamination is therefore highly improbable. Risks at Superfund sites are typically assessed hi relation to both carcinogenic and non- carcinogenic effects, taking into consideration the maximum contaminant level of chemical identified. For groundwater risk evaluation the maximum concentration level of 9 ug/1 (for Bis-2-ethyl hexyl) reported in well WP-20 was used. The carcinogenic risk was estimated at 1 X 10 •*, and the hazard quotient at 0.01. For on-site workers exposed to PNAs in surface sediments, the carcinogenic risk for incidental ingestion and dermal contact were estimated at 9 X 10 * and 8 X 10-* and hazard quotient were calculated to 2 X 10-' through each pathway. Risk assessment methodology requires that risks through pathways likely to be experienced by the same individual should be summed to produce multi pathway risk and hazard estimates. Summing the risk for the worker exposure pathways results in a total carcinogenic risk of 2X10* and a hazard index of 4 X 10-*. As the groundwater consumption scenario is based on a future theoretical residential population, it would be inappropriate to add these to the worker exposure pathways. The first scenario (worker contact with surface sediments) is theoretically complete at present, and involves a limited occupational target population. The latter scenario (consumption of site groundwater) is strictly hypothetical, as it assumes that homeowners are using on- site groundwater as a potable supply. EPA guidelines specify that risk through different pathways be added where there is a possibility that the same receptors may be exposed through multiple pathways. In this case, the pathways were not added because 1) they involve unrelated populations, and 2) one of the pathways is potentially complete at present, and the other is a future hypothetical one. Following human health risk evaluation an environmental assessment was also performed to study the impact of site contamination on the quality of environment. The environment assessment included an ecological and contaminant assessment. The Ecological Assessment, consisting of vegetation/habitat mapping and a wildlife survey, was performed to evaluate terrestrial and aquatic resources in the area. The assessment concluded that the presence of the landfill is not associated with general habitat impairment. Possible mechanisms by which wildlife could be exposed to landfill- related materials are as follows: ------- Record of Decision Page 15 of 19 Southside- Sanitary Landfill • Ingestion of small mammals • Direct contact with surface water by aquatic species • Direct contact with sediment by aquatic species • Ingestion of grit, seed or ground insects while feeding or burrowing. Since there is no mechanism by which wildlife can contact groundwater, groundwater is not a medium of concern from an environmental risk perspective. The contaminant assessment indicated that down stream water and sediment samples in surface water bodies are not associated with landfill contamination. No seeps or other surficial contamination sources were observed at the landfill. Previous investigations (during Phase I) have shown cadmium to be nondetect in landfill leachate liquid and groundwater inside the containment system. Cadmium has also found to be nondetect in the vast majority of groundwater samples taken at the site. There is a substantial historical database demonstrating that Cadmium is not a contaminant of concern at the landfill. A variety of PNAs were detected in the ditches (SD8 and SD9). No specific landfill waste sampling was done in order to avoid the inherent risks such as exposure and dermal contact involved in the process. For this reason surfacial sediment sampling was conducted in adjacent ditches near the landfill. The upstream White River and Eagle Creek PNA concentrations were generally higher, ranging up to 1100 ug/kg. The PNA concentrations are below the range of typical urban background soils. The slight elevations of inorganics and PNAs in the ditches compared to background surface sediments indicates these are unrelated to the landfill. Drainage swales tend to accumulate fine-grained material, which encourages adherence of chemicals. Overall, there is no evidence of landfill related contamination in surface materials. An evaluation of the chemical database for the Southside Sanitary Landfill site indicated that there is no detectable site-related contamination in areas which present an opportunity for human or wildlife contact. Based on this, it is concluded that there are no human health or environmental risks associated with groundwater and surface water/sediment quality at the site. The site is not releasing significant levels of contaminants to the surrounding environment. To be conservative, risks to future residential population consuming on-site groundwater containing Bis(2-ethyl hexyl) phthalate were assessed. Risks associated with direct contact with surface sediments containing PNAs were also assessed for on-site workers and ecological receptors. Overall, no unacceptable risks or hazards were identified. SUMMARY OR ALTERNATIVES Based on the results of RI only two (2) alternatives were considered to address the site remedial objectives and ensure compliance with requirements of National Contingency ------- Record of Decision Page 16 of 19 Southside Sanitary Landfill Plan (NCP). Alternative: NO ACTION Alternative 1 is the 'No Action' alternative and serves as basis against the preferred alternative for comparison purposes. Under this alternative, no remedial action or institutional controls would be taken at the site. According to the National Contingency Plan (NCP) the "No Action1 alternative must be carried through to the detailed analysis over the preferred alternative. Estimated Capitol Cost $ -0- Estimated Annual O&M Cost $ -0- Estimated Present Worth $ -0- Estimated time to implement None Alternative 2: No Further Action This alternative is considered because a specific response action has been implemented at the site under an Agreed Order signed between the State and the owners of the landfill in 1986. The Agreed Order also set up long term monitoring schedules for a minimum period of 30 years from the date of official closure of the landfill as required under State solid waste regulations. The Agreed Order also includes landfill inspection schedules and corrective action implementation in the event of exceedence of MCLs for chemicals specified under the monitoring program. Because of the implementation of the above stated response measures no further action is justified at this site. As this alternative appears to be more appropriate for the site conditions it is described in detail as the preferred remedy. Evaluation of Alternatives The NCP requires that the alternatives selected be evaluated against nine evaluation criteria. This section summarizes the relative performance of the alternatives by discussing the key differences among the alternatives in relation to these criteria. The nine evaluation criteria are grouped into three categories as: (1) Threshold Criteria; (2) Primary Balancing Criteria; and (3) Modifying Criteria. Each of these terms is described as follows: Threshold Criteria ------- Record of Decision ' Page 17 of 19 Southside" Sanitary Landfill 1) Overall Protection of Human Health and the Environment addresses whether a remedy provides adequate protection of human health and the environment and describes how risks posed through each exposure pathway are eliminated, reduced or controlled through treatment, engineering, or institutional controls. The selected remedy must meet this criteria. 2) Compliance with Applicable or Relevant and Appropriate Requirements (ARARS) addresses whether a remedy will meet applicable or revelant and appropriate federal and state environmental laws and/or justifies a waiver from such requirements. The selected remedy must meet this criteria or waiver of the AFAR must be obtained. Primary Balancing Criteria 3) Long-term Effectiveness and Permanence refers to expected residual risk and the ability of a remedy to maintain reliable protection of human health and the environment over time, once cleanup goals have been met. 4) Reduction of Toxicity, Mobility, and Volume through Treatment addresses the statutory preference for selecting remedial actions that employ treatment technologies that permanently and significantly reduce toxicity, mobility, or volume of the hazardous substances as their principal element. This preference is satisfied when treatment is used to reduce the principal threats at the site through destruction of toxic contaminants, reduction of the total mass of toxic contaminants, irreversible reduction in contaminant mobility, or reduction of total volume of contaminated media. 5) Short-term effectiveness addresses the period of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed, until remedial action goals. 6) Implementability is the technical and administrative feasibility of a remedy, including the availability of materials and services needed to implement a particular option. 7) Cost includes estimated dollar amount associated with selected remedial alternative. Modifying Criteria 8) Support Agency (USEPA) acceptance reflects aspects of the preferred alternative and other alternatives the EPA favor or object to, and any specific comments regarding federal and state ARARS or the use of waivers. ------- Record of Decision Page 18 of 19 SouthsideT Sanitary Landfill 9) Community acceptance summarizes the public's general response to the alternatives described in the proposed plan and the RI report based on public comments received. The assessment of support agency and community acceptance were completed after the public comment period was completed. The Record of Decision (ROD) documents support agency acceptance and the Responsiveness Summary attached to the ROD documents the community's reaction to the proposed remedy and the Agency's response to the community's comments. A summary of the evaluation of the preferred remedy against the applicable nine point criteria is provided below. Threshold Criteria 1) Overall Protection of Human Health and the Environment Alternative 1 (No Action^: Based upon the detailed analysis* it was concluded that Alternative 1 - No Action, would not satisfy the criterion of ensuring the overall protection of human health and the environment. The RI has documented remedial measures implemented at the site which had impact on overall protection of human health and the environment and Alternative 1 does not meet this criterion because no remedial measures would be taken to address the present and future conditions of the site and contaminant migration from the site. Further, 'No Action1 alternative does not recognize the remedial activities implemented at the site pursuant to the Agreed Order. Therefore, this alternative is not appropriate for this site. Alternative 2 (No further Action*: The hydraulic cut-ofFbarrier (slurry wall) constructed around the site and the installation of a leachate collection system at the site would effectively minimize the potential for accidental human exposure to the contaminated on-site groundwater and the leachate generated which are contained within the site boundaries. Groundwater monitoring being conducted at the site under a state issued operating permit would detect any trends in the quality of on-site groundwater and would be effective in establishing whether off-site releases of contaminants via groundwater migration, are occurring. The ground water monitoring is required to continue for 30 years after closure of the landfill. There are specific daily cover, grading and operating procedures stated in the Agreed Order. These measures prevent any direct contact with landfill waste or surficial sods, the type of landfill cover material is restricted to clay type soil specification which eliminates potential for dermal contact with landfill waste or soil. Therefore, this alternative would provide the required degree of over all protection of human health and the environment. ------- Record of Decision Page 19 of 19 Southside- Sanitary Landfill 2) Compliance with ARARS Alternative 1: No Action: Alternative 1 would not meet this criteria because it would allow contaminated groundwater on-site to remain untreated and uncontrolled. Since Alternative 1 does not satisfy a Threshold Criterion, no further evaluation against the Primary Balancing or Modifying criteria is needed. Alternative 1 will not be chosen for the site. Alternative 2: fNo further Action): The remedial measures, the hydraulic cut-off barrier wall (slurry wall) around the site and the leachate control system established isolation of groundwater beneath the site and ensured that chemical specific ARARS are not exceeded out-side the boundaries of the landfill. Further the landfill current operating permit requires the landfill compliance with the groundwater monitoring requirement under 329 IAC 2-16. The State issued permit (opp.49-1) under 1C 13-7 also requires the landfill to comply with provision of 330 IAC 4-5-13(C) and 330 IAC 4-9-5 concerning landfill closure requirements. The remedial measures ensured compliance with state ARARS, as a result no additional response or remedial measures are required at the site. The preferred remedy is protective of human health and the environment and attains the Federal and State requirements that are applicable to this site. The statutory preferences for cost effectiveness, permanent solutions and alternate treatment technologies are not applicable to a 'No Further Action' alternative. G. STATUTORY DETERMINATION Protection of Human Health and the Environment: The cut-off barrier (slurry wall) constructed around the site and the leachate collection system at the site would effectively minimize potential for human exposure to contaminated on-site ground water and the leachate generated, as both are contained within the site. The ground water monitoring being conducted at the site under a State issued operating permit would detect any trends in the ground water quality of on-site ground water and would be effective in detecting off-site migration. The current operating permit requires the operator to meet specific daily cover, grading, and operating ------- Record of Decision Souchside Sanitary Landfill procedures. These measures eliminate direct exposure or contact threat with landfill waste. These remedial measures ensures the required degree of overall protection of human health and the environment. COMPLIANCE WITH APPLICABLE, RELEVANT AND APPROPRIATE REGULATIONS (ARARS) The remedial measures, the hydraulic cut-off barrier wall (slurry wall) around the site and the leachate control system established isolation of ground water beneath the site and ensured that chemical specific ARARs are not exceeded outside the boundaries of the landfill. Further the landfill current operating permit requires the landfill compliance with the ground water monitoring requirement under 329 IAC 2-16. The State issued permit (opp. 49-1) under 1C 13-7 also requires the landfill to comply with provisions of 330 IAC 4-5-13 (C) and 330 IAC 4-9-5 concerning landfill closure requirements. The remedial measures ensured compliance with State ARARs, as a result no additional response or remedial measures are required at the site. The preferred remedy is protective of human health and the environment and attains the Federal and State requirements that are applicable to this site. The statutory preferences for cost effectiveness, permanent solutions and alternative treatment technologies are not applicable to a *No Further Action1 alternative. Cost effectiveness and utilization of permanent solution and alternative treatment technologies are not applicable to the T^o Further Action1 alternative. H. EXPLANTION OF SIGNIFICANT CHANGES The selected remedy i.e., a no further action is the same as the preferred remedy identified in the Proposed Plan that was released for public review and comment period June 19, 1995, through July 19,1995. No changes were made to the preferred remedy after the comment period, as no signifiant comments were received that required any changes to the Proposed Plan. RESPONSIVENESS SUMMARY FOR SOI JTHSTDE SANITARY LANDFILL SUPERFIJND SITE. INDIANAPOLIS. INDIANA JUNE 1995 ------- Record qj: Decision Souchside Sanitary Landfill The purpose of this response summary is to document milestone community relations activities along with citizen comments and questions and agency responses. The Indiana Department of Environmental Management has been responsible for conducting a coordinated community relations program for this site. Community relations activities have been administered throughout the remedial investigation and the presentation of selected alternatives. In accordance with CERCLA Section 117 (a) a 30-day public comment period, and a public meeting were held to acquire public comment on the proposed plan. The selected remedy of no further action was presented in the June 1995 proposed Plan and at the public meeting. There has been no negative public reaction to the selected remedy before or during the comment periods, except for one comment letter by a concerned citizen to IDEM. The IDEM reviewed the comment and determined that the comment did not warrant any specific changes to the proposed plan. The citizens letter and the agency's (IDEM) response are attached to this summary. The proceedings of the public meeting conducted on June 29, 1995, is also attached to this summary. ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 BEFORE THE STATE OF INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT SOUTHSIDE SANITARY LANDFILL SUPERFUND SITE PUBLIC MEETING ORIGINAL PROCEEDINGS in the above-captioned matter, before Moderator Susan Gross, under the applicable rules of Civil Procedure, taken before me, Llndy L. Meyer, Jr., a Notary Public in and for the State of Indiana, County of Shelby, at the Indiana Government Center South, Conference Room C, 402 West Washington Street, Indianapolis, Indiana, on Thursday, June 29, 1995 at 3:38 o'clock p.m. William F. Daniels, RPR/CP CM d/b/a ACCURATE REPORTING OF INDIANA 12922 Brighton Avenue Carmel, Indiana 46032 (317) 848-0088 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 APPEARANCES: IDEM Staff: Susan Gross, Moderator Prabhakar Kasarabada Steve Poe Bill Crawford ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 8:38 o'clock p.m. June 29, 1995 MS. GROSS: Good evening, ladies and gentlemen, and we'd like to welcome you to the Indiana Department of Environmental Management's public meeting concerning the Southside Sanitary Landfill Superfund Site. In this evening's meeting, the purpose will b-e to inform you, the area residents, about the proposed plan and invite public comments on the proposed plan for the Southside Sanitary Landfill Superfund Site. As a part of the Superfund Site and community relations aspect, we do have a court reporter here tonight at the meeting. This evening's meeting will become part of the public document and will be available for public review. The agenda for this evening's meeting -- I'm Susan Gross of IDEM, serving as the moderator — will be to have Prabhakar Kasarabada — that's Prabhakar, Kasarabada — IDEM project manager, ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 Prabhaicar will give a presentation on the s background, remedial investigations, and preferred remedial alternatives. Also assisting us tonight will be technical assistance from Steve Foe, IDEM geologist, and Bill Crawford, IDEM chemist. Bill will be available for any type of technical comments. Following this evening's presentation by Prabhakar, we will open the * program for a public comment period. As part of the Superfund Site, we invite the public to comment on the remedial work that is being undertaken, and that's also part of tonight's program as having a public record. Public input in the Superfund program is important, and documents pertaining to the Southside Sanitary Landfill Superfund Site, Including the proposed plan and fact sheets, which were mailed to area residents -- and we also have fact sheets available here this evening -- are available to you for review at the public information repository located at the Indianapolis-Marion County ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Public Library, the Telephone Room, at 40 East St. Glair Street in Indianapolis. The public comment period for the Southside Landfill Superfund Site is a 30-day period running from June 19th through July 19th, 1995. During this time, the public is invited to offer comments about the proposed plan. Following Prabhakar's presentation, we will open this meeting for » public comment. At this time, I'd like to present Mr. Kasarabada. MR. KASARABADA: Thank you, Susan. As you all know, I'm Prabhakar Kasarabada, and I'm here to present to you or explain to you the agency's recommendation for remedial action at this site. To begin with, I would like to give you some site background or history. The landfill operations began in 1971 under a state-issued permit. At that time, it was the Department of Natural Resources. And after ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 that, in about 1980, the Superfund law cane Into existence, effect. I Just wanted to explain to you how this evolved. Because of the growing concerns to the human health and the environmental risk. Congress came up with a trust fund basically created from the taxes paid by the industries, especially petroleum and the chemical industry. This money was used,to clean up the sites, wherever it is possible. In some places, wherever they were done, the cleanup actions were done through consent agreement and enforcement orders. At this site, we have an agreed order. That means we have cooperation, that the respondent parties will cooperate with us and sign an agreed order. During 1980's, Congress authorized the U.S. EPA to administer the Superfund, so the EPA was looking for sites to create a National Priorities List. In 1981, I think, as part of a national survey of industrial waste disposal practices, four industries indicated ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Landfill as their disposal site for their waste. After that, in 1986, the Indiana State Board of Health issued some notices of violation concerning grading and drainage requirements under the state-issued permit. To correct these actions, landfill operators signed an agreed order to construct a barrier wall around the site, and also installed a leachate collection system and continued ground water monitoring. Then U.S. EPA also conducted site Inspections, sampled on-site wells, and evaluated the site or scored the site, and placed it into the National Priorities List. Because the site is on the National Priorities List, we have to meet the requirements of the — of the Superfund law. To do so, IDEM and the landfill owners have signed another agreed order in February 1990 to conduct the remedial investigation. The purpose of the remedial investigation was to meet the Superfund law ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21' 22 23 requirements and also to evaluate the site determine the nature and extent of the contamination at the site. Now let me talk about briefly the remedial Investigations. The remedial investigations were conducted in two different phases. The Phase I activity was conducted within January of 1992 through November of 1994. The Phase I was focused mainly on collection and analysis of existing data, and the Phase II was focused on the nature and extent of the -- the nature and extent of possible contaminants reaching the ground water, surface water or sediments in the area. The emphasis was mostly on the ground water, because that's being used by the -- by the public as a ground water resource. This study concluded that the ground water analysis really did not show any kind of plume or pattern of contamination that can be attributed to the landfill that consisted of the landfill waste. Also, the compounds detected were at a very -- at low ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 ' 22 23 levels, and particularly they are less than the maximum contaminant levels. At this time, I would like to show you the contaminants we have found at the site. These are the chemicals we found, and I will try to refer to the maximum contaminant levels we observed during the order in the remedial investigation phase. As you can see, I have shown the last column, the allowable t MCL's, and you can see those -- when you compare these numbers with these, all of the maximum contaminant levels -- or the compounds detected are less than the MCL's. That means that the contaminants we found at the site were within the allowable MCL's. Also, the waste analysis conducted at the site showed no evidence of any hazardous waste, and the only waste that we found that was prevalent at the site was the inorganic waste, and there was really no organic waste at the site. Basing on these contamination levels, a base line risic assessment study was ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 conducted to evaluate any risk to human or the environment. The evaluation of chemical database for this site indicated that there is no detectable site-related contamination in the areas which present an opportunity for human contact. The risk calculations have been made for compounds detected in ground water, • surface water and sediments. All these risk t calculations showed that the maximum risk range is below the acceptable range, which is ten to the minus four to ten to the minus So, the RI Study showed that the barrier wall constructed is containing the contaminants within the site. I just would like to show you the wall. The dark, thick line is the barrier wall constructed around the site. I believe it's about 17,000 feet in linear length, and the depth range varies from some 43 to 105 feet, and briefly I can turn to this. Basing on the RI Study conclusions, we have selected the two ------- 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 alternatives for consideration for our recommendation for remedial action. One is that no action ought to be made. This is -- by Super fund law, we are required, we must consider this as one of the alternatives, to get a comparative study of the CERCLA alternatives. No action means this alternative was made for the scenario in which t you don't make a — conduct any actions on site, which is not the case at this site. There are some actions conducted at the site, so no action is not appropriate for this site. So, the next one we considered was no further action. We say no further action because there are some actions conducted at the site. The actions are barrier wall on the site, leachate collection system, and the ground water monitoring. And I would like to make a point at this time, because when we say no further action, the no further action is stated under the Superfund law. ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 There are some other actions going on under site under the state-issued permit. So, no further action is really in relation to the CERCLA action at this site. this doesn't -- no further action doesn't mean that we are walking away from the site. There is going to be a five-year review for the site once the final proposed plan is done. At that time, we'll review all the analytical data and t make a determination about the final shape of the site. And along with this, there a -- there is a state-issued permit, which serves as as tool to monitor the site conditions for at least 30 years after the official closure of the landfill site. So, we are pretty confident, even though we conclude this as no action, we have enough mechanism to monitor the site and take any corrective action if something down the road happens. So that's all about the site Are there any questions? (No response.) ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. KASARABADA: Then I turn it over to Susan. MS. GROSS: As I mentioned earlier, we are in the midst of the public comment period for this Superfund Site, and we have two ways that we will be taking comments from the public. The first is from the fact sheet that was either mailed to you or that's available here at the meeting. * There's a tear-out section in the fact sheet for written comments. These can be mailed to Prabhakar Kasarabada at the Indiana Department of Environmental Management. It must be postmarked by July 19th. 1995. If you need a fact sheet, they are available where you signed in this evening, and if you have not signed in at this meeting on the sign-up sheet, we please ask you to do so before you leave this meeting. The second way that IDEM will receive comments will be through oral comment' that will be taken at tonight's meeting. In order to include the oral comments in the ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 official record, we ask that you come to one of the two floor microphones, state your name address, and affiliation, if any, and then spell your first and last names. Then please state your comment slowly and clearly. I hope that you'll understand that for the benefit of the court reporter, we may ask you to repeat your comment. All comments will be considered and incorporated into the responsiveness summary of the record of decision, which is the final position of the agency regarding t cleanup action at this site. He would appreciate you limiting your comment to three minutes. audience? Are there any comments from the (No response.) MS. GROSS: If there are no comments -- this would serve as your opportunity to make oral comments here at the meeting. Since there are no comments from the audience, we ask that any further comments be ------- 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 in a written form and sent to the Indiana Department of Environmental Management. I'm going to ask Prabhakar if there's anything in addition that you would want to present at this meeting. MR. KASARABADA: No. MS. GROSS: Okay. On behalf of the Indiana Department of Environmental management, those of us involved in the t Southside Sanitary Landfill Superfund Site, we thank you for coming to the meeting, and this concludes the meeting on Thursday, June the 22nd — June the 29th, excuse me -- 1995. (Applause.) Thereupon, the proceedings of June 29 1995 were concluded at 8:56 o'clock p.m. ------- i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 CERTIFICATE I, Lindy L. Meyer, Jr., the undersigned Court Reporter and Notary Public residing in the City of Shelbyville, Shelby County, Indiana, do hereby certify that the foregoing is a true and correct transcript of the proceedings taken by me on Thursday, June 29, 1995 in this matter and transcribed by me. a Lindy LV Meyer, Jr., Notary Public in and for the State of Indiana. My Commission expires October 19, 1996. ------- June 15, 1995 Mr. Prabhakar Kasarabada Project Manager ^ "( Superfund Section £ <%, Office of Environmental Response ^ x IDEM Room N-1255 \A -0 P.O. Box 6015 ^ ^ Indianapolis, In 46206-6015 ^ ** Dear Mr. Kasarabada: I'm writing in regards to the remedial action for the Southside Sanitary Landfill under the CERCLA Act. I have followed this process for some time and have been in contact with some of your predecessors during this time period of remedial investigation. I have asked for them to look at the potential hazards to the residents of the Mars Hill Sub-Division located west of the site. The area in question is almost exclusively served by well water which I believe is pulled from the identified , aquifers associated with this Superfund Site. I understand the work that has been done at the site in regards to the slurry wall of bentonite clay to bedrock and the associated leachate collection system. The problem with this sole approach to prevent future hazards to the residents that rely on well water is that it has never been done on this scale anywhere in the world to my knowledge. I have yet to find anyone with your agency that will guarantee this will prevent future contamination of the aquifer in question. This is are sole opportunity to address future problems associated with the Southside Sanitary Landfill Superfund Site. I had asked for them to look at providing Mars Hill with municipal water to avoid any potential for trouble in the future. I believe it has been said an ounce of prevention is worth a pound of cure. It would appear that the cost for this would not be overly burdensome to an entity that serves as the sole sanitary landfill for Marion County. We rest our future health and welfare in the hands of the IDEM. Sincerely; Donald R. Coleman 3121 S. Mars Hill Street Indianapolis, In 46221 317/241-8136 ------- INDIANA DEPARTMENT OF ENVIRONMENTAL MAN AGEMI make Indiana a cleaner, healthier place to Hue Euan Bayh '00 North Senate Avenue Governor" P.O. Box 60 15 if , n Indianapolis. Indiana 46206-601.' KathyProsser Telephone 3 17-232.8603 Commissioner Environmental Helpline 1 -800-45 August 3, 1995 Mr. Donald R. Coleman 3121 S. Mars Hill Street Indianapolis, IN 46221 Dear Mr. Coleman: Re: Southside Sanitary Landfill Indianapolis, IN Thank you for your letter dated June 15, 1995 concerning Southside Sanitary Landfill site and your keen interest in • keeping track of the field activities at the site. Your letter mentioned a concern with ground water contamination from the landfill impacting your well. This shou not be a problem because: 1. The contaminant levels of the leachate and other chemicals, in relation to the site, were below the Maximum Contaminant Levels; 2. The landfill is being pumped to remove the leachate and to provide an inward flow if the slurry wall should leak; 3. The slurry wall has been tested and is providing an excellent barrier; 4. There are monitoring wells outside the landfill and slurry wall which are periodically sampled and tested. Any leaks will be detected in these wells long before the contamination could leave the site, and 5. Your subdivision is located at a considerable distance from the site, and is not in the direction of ground water flow from the site. Even if the remedial measure do not function properly, it is highly unlikely your area would be impacted; by the contamination associated with the site. An Equal Opportunity Employer Prinud on Rtcycitd Paptr ------- Mr. Donald R. Coleman Page 2 August 3, 1995 As stated in your letter, while I concede that there are no guarantees associated with any technique, I can confidently state that slurry wall techniques are proven, successful, cost effective mechanisms commonly used at landfill sites throughout the United States and the State of Indiana. Examples are the 9th Avenue Dump Superfund site, and landfills located in Gary and Liberty in White County. Several other Superfund sites have been in the process of implementing slurry wall techniques as a remedial alternative. Slurry walls have also been used for many years to repair leaky reservoirs. IDEM believes that the remedial measures at Southside Landfill are protective of human health and the environment. Alternative water supplies are provided where there is existing evidence of chemical contamination of the aquifer in use. There is no such evidence in relation to Southside Landfill. However, as there are no guarantees that your ground water will not be impacted by another source of contamination and if you are concerned with your ground water, I would suggest testing your water periodically. Additionally, I suggest you pursue the City or County administration in regards to a water line extension to your subdivision. Again, thank you for your interest in this project, and please feel free to contact me at (317) 233-6424 if you need more information regarding this site. Sincerely, J Prabhakar Kasarabada, Project Manager Superfund Section Office of Environmental Response PK:fflg ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS _ 77 WEST JACKSON BOULEVARD . CHICAGO. IL 60604-3590 '£_ CEP 2«"'995 REPLY TO THE ATTENTION OF: OCf 51995 Ms. Cathy Prosser Commissioner . , Mariarrament Indiana Department of Environmental Management 100 North Senate Avenue Indianapolis, IN 46206-6015 Dear Ms. Prosser: The united States Environmental reviewed the loliana Department of mvironmentai hS (IDEM) Record of Decision £« ch*?££hS ^ s. EPA fully concurs SirMS c^entsPof1Sthense?etted0rSe!nedy for this site. which includes: No Further Action 1986. Long term performance cover and grading, °P"a^9re!Sf re^ns . establishnent civil n uar inspections and groundwater monitoring will be performea uou Agreed Order continued operation under State issued operating permit No. OPP-49-1 We also agree that this action attains J^^optiate to retirements that are Applicable, or relevat ana P* and the continues to provide adequate protection environment. U.S. EPA has determined that ^•a complete and no further action is pessary at c Therefore, the site now qualifies for inciusio Construction Completion List. Prima on Recyetea Pic ------- IDEM staff have been working closely with Region V staff in the selection of an appropriate final remedy f°* ^J^lScwd Sanitary Landfill site and are satisfied that the selected alternative adequately addresses the risk to human health and tne environment posed by the site. Sincerely, Valdas V. Adamkus Regional Administrator ------- |