REMEDIATION SYSTEM EVALUATION
REILLY TAR & CHEMICAL CORP. (INDIANAPOLIS PLANT) SITE
A.K.A. "REILLY INDUSTRIES" SITE
INDIANAPOLIS, INDIANA
Report of the Remediation System Evaluation,
Site Visit Conducted at the "Reilly Industries" Superfund Site
October 28, 2003
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Office of Solid Waste EPA 542-R-04-035
and Emergency Response February 2004
(5102G) www.epa.gov/tio
clu-in.org/optimization
Remediation System Evaluation
Reilly Tar & Chemical Corp. (Indianapolis Plant) Site
A.K.A. "Reilly Industries" Site
Indianapolis, Indiana
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NOTICE
Work described herein was performed by GeoTrans, Inc. (GeoTrans) for the U.S. Environmental
Protection Agency (U.S. EPA). Work conducted by GeoTrans, including preparation of this report, was
performed under Dynamac Corporation Prime Contract No. 68-C-02-092, Work Service Request No. ST-
1-15. Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
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EXECUTIVE SUMMARY
A Remediation System Evaluation (RSE) involves a team of expert hydrogeologists and engineers,
independent of the site, conducting a third-party evaluation of site operations. It is a broad evaluation
that considers the goals of the remedy, site conceptual model, above-ground and subsurface performance,
and site exit strategy. The evaluation includes reviewing site documents, visiting the site for up to 1.5
days, and compiling a report that includes recommendations to improve the system. Recommendations
with cost and cost savings estimates are provided in the following four categories:
• improvements in remedy effectiveness
reductions in operation and maintenance costs
• technical improvements
gaining site closeout
The recommendations are intended to help the site team identify opportunities for improvements. In
many cases, further analysis of a recommendation, beyond that provided in this report, may be needed
prior to implementation of the recommendation. The recommendations are based on an independent
evaluation by the RSE team, and represent the opinions of the RSE team. The RSE described herein was
performed at the "Reilly Industries site" in Indianapolis, Indiana. This is a "Responsible-Party (RP)" site
and not a "Fund-lead" site. This site was selected as a test case to help determine if the RSE process
might provide benefits if applied at RP sites.
The Reilly Industries site is an active chemical manufacturing facility surrounded by a mix of residential,
industrial and commercial properties. All residences in the area of contaminated ground water have been
connected to the municipal water supply. This RSE report is focused on the operating pump-and-
discharge (P&D) system, and the related monitored natural attenuation (MNA) of off-site ground water.
A two-well perimeter ground water extraction system began operation in October 1994. Extraction wells
have been added/replaced in several increments since that time. The current P&D system contains five
extraction wells, operating at a combined rate of approximately 220 gpm. There is also an SVE system
located near one of the source areas that consists of 10 wells that are rotated (5 passive and 5 active at any
point in time).
Three chemicals in the ground water are of primary concern: benzene, pyridine/pyridine derivatives, and
ammonia. Concentrations have decreased substantially at many wells since the P&D remedy was first
implemented in 1994, but there are wells located on-site and off-site where concentrations remain
elevated at concentrations more than 100 times the cleanup levels. High concentrations are generally
found in shallow wells on-site, but higher concentrations are found off-site to the east at the intermediate
or deep wells (such as at RI-19D) . This may be the result of natural downward hydraulic gradients, or
may be the result of downward hydraulic gradients caused by off-site industrial pumping.
There is no treatment plant at the site, so this RSE does not pertain to optimization of on-site treatment
processes. Rather, this RSE focuses on hydrogeologic issues, such as the effectiveness of ground water
capture, the progress of MNA, etc. and cost-effective approaches to evaluate and/or enhance the
performance of the remedy. The RSE team noted a good working relationship between the responsible
party and the EPA RPM. The observations provided in this report are not intended to imply a deficiency
in the work of the system designers, system operators, or site managers but are offered as constructive
suggestions in the best interest of the EPA and the public. These observations obviously have the benefit
of being formulated based upon operational data unavailable to the original designers. Furthermore, it is
likely that site conditions and general knowledge of ground water remediation have changed over time.
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Recommendations to improve effectiveness in protecting human health and the environment include
adding a cluster of piezometers and a cluster of monitoring wells, and performing a detailed capture zone
evaluation (including the construction/update and calibration of a three-dimensional numerical flow
model to then be used in conjunction with particle tracking) that will indicate if modifications to the
extraction system are appropriate. The one recommendation to reduce cost is to potentially use the
extracted water for process or cooling water. The RSE team acknowledges that Reilly has previously
considered and rejected that idea, but a future increase in the discharge costs may make it appropriate to
reconsider this option. Minor additions to routine O&M reports are suggested for technical improvement.
For site closeout, the RSE team recommends that an alternate approach that includes discontinuing the
P&D system be considered. The RSE team is not recommending this alternative approach per se, but is
recommending that it be considered by the site team and the regulators. There is a potential to decrease
remedy costs dramatically if all parties (including the regulators) agree that protectiveness is not
negatively impacted by such an approach.
A table summarizing the recommendations, including estimated costs and/or savings associated with
those recommendations, is presented in Section 7.0 of this report.
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PREFACE
This report was prepared as part of a project conducted by the United States Environmental Protection
Agency (USEPA) Office of Superfund Remediation and Technology Innovation (OSRTI). The objective
of this project is to conduct Remediation System Evaluations (RSEs) at selected pump and treat (P&T)
systems that are jointly funded by EPA and the associated State agency. The project contacts are as
follows:
Organization
Key Contact
Contact Information
USEPA Office of Superfund
Remediation and Technology
Innovation
(OSRTI)
Jennifer Griesert
1235 Jefferson Davis Hwy, 12th floor
Arlington, VA 22202
Mail Code 5201G
phone: 703-603-8888
griesertjennifer@epa.gov
GeoTrans, Inc.
(Contractor to USEPA)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
dsutton@geotransinc.com
The RSE described herein was performed at the Reilly Industries site. This is a "Responsible-Party (RP)"
site and not a "Fund-lead" site. This site was selected as a test case to help determine if the RSE process
might provide benefits if applied at RP sites.
in
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
PREFACE iii
TABLE OF CONTENTS iv
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 2
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 3
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 3
1.5.1 LOCATION AND HISTORY 3
1.5.2 POTENTIAL SOURCES 4
1.5.3 HYDROGEOLOGIC SETTING 6
1.5.4 RECEPTORS 6
1.5.5 DESCRIPTION OF GROUND WATERPLUME 7
2.0 SYSTEM DESCRIPTION 8
2.1 SYSTEM OVERVIEW 8
2.2 EXTRACTION SYSTEM 8
2.3 TREATMENT SYSTEM 9
2.4 MONITORING PROGRAM 9
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 11
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 11
3.2 TREATMENT PLANT OPERATION STANDARDS 12
4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT 13
4.1 FINDINGS 13
4.2 SUBSURFACE PERFORMANCE AND RESPONSE 13
4.2.1 WATER LEVELS 13
4.2.2 CAPTURE ZONES 13
4.2.3 CONTAMINANT LEVELS 15
4.3 COMPONENT PERFORMANCE 17
4.3.1 EXTRACTION SYSTEM WELLS, PUMPS, AND HEADER 17
4.3.2 SYSTEM CONTROLS 17
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF O&M COSTS 17
4.4.1 UTILITIES 18
4.4.2 NON-UTILITY CONSUMABLES 18
4.4.3 LABOR 18
4.4.4 CHEMICAL ANALYSIS 18
4.4.5 OVERSIGHT COSTS 18
4.5 RECURRING PROBLEMS OR ISSUES 18
4.6 REGULATORY COMPLIANCE 19
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT RELEASES
19
4.8 SAFETY RECORD 19
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT . 20
5.1 GROUND WATER 20
iv
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5.2 SURFACE WATER 20
5.3 AIR 20
5.4 SOILS 20
5.5 WETLANDS AND SEDIMENTS 20
6.0 RECOMMENDATIONS 21
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS 21
6.1.1 INSTALL PIEZOMETERS AND MONITORING WELLS To ALLOW FOR IMPROVED EVALUATION
OF PLUME CAPTURE 21
6.1.2 PERFORM IMPROVED PLUME CAPTURE EVALUATION (INCLUDING USE OF A NUMERICAL
MODEL) 22
6.1.3 CONSIDER THE NEED FOR A MODIFIED EXTRACTION 22
6.2 RECOMMENDATIONS TO REDUCE COSTS 23
6.2.1 CONSIDER USING EXTRACTED WATER FOR PROCESS AND COOLING WATER 23
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 23
6.3.1 MINOR SUGGESTION FOR IMPROVED O&M REPORTING 23
6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT 24
6.5 SUGGESTED APPROACH TO IMPLEMENTATION 25
7.0 SUMMARY 26
List of Tables
Table 7-1. Cost summary table
List of Figures
Figure 1. Sources of Contamination.
Figure 2. Shallow Water Levels, 3rd Quarter FY03.
Figure 3. Deep Water Levels, 3rd Quarter FY03.
Figure 4. Wells Where Last Sample in 2002 Had More than 500 ug/1 Benzene and/or Total Pyridines.
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1.0 INTRODUCTION
1.1 PURPOSE
During fiscal years 2000, 2001, and 2002 Remediation System Evaluations (RSEs) were conducted at 24
Fund-lead pump and treat (P&T) sites (i.e., those sites with pump and treat systems funded and managed
by Superfund and the States). Due to the opportunities for system optimization that arose from those
RSEs, EPA OSRTI has incorporated RSEs into a larger post-construction complete strategy for Fund-lead
remedies. During fiscal year 2003, RSEs were planned at up to six Fund-lead sites in an effort to improve
or optimize the sites. Some of these (including the Reilly Industries RSE presented herein) were delayed
into fiscal year 2004. Furthermore, OSRTI decided to conduct at least one of the six RSEs at a
"Responsible Party (RP)" site rather than a Fund-lead site as a test case for applying the RSE process at
RP sites. The Reilly Industries RSE presented herein pertains to an RP site. GeoTrans, Inc., an EPA
contractor, is conducting these evaluations, and representatives from EPA OSRTI are attending the RSEs
as observers.
The Remediation System Evaluation (RSE) process was developed by the US Army Corps of Engineers
(USAGE) and is documented on the following website:
http://www.environmental.usace.armv.mil/library/guide/rsechk/rsechk.html
An RSE involves a team of expert hydrogeologists and engineers, independent of the site, conducting a
third-party evaluation of site operations. It is a broad evaluation that considers the goals of the remedy,
site conceptual model, above-ground and subsurface performance, and site exit strategy. The evaluation
includes reviewing site documents, visiting the site for 1 to 1.5 days, and compiling a report that includes
recommendations to improve the system. Recommendations with cost and cost savings estimates are
provided in the following four categories:
• improvements in remedy effectiveness
• reductions in operation and maintenance costs
• technical improvements
• gaining site closeout
The recommendations are intended to help the site team identify opportunities for improvements. In
many cases, further analysis of a recommendation, beyond that provided in this report, might be needed
prior to implementation of the recommendation. Note that the recommendations are based on an
independent evaluation by the RSE team, and represent the opinions of the RSE team.
The Reilly Tar site was selected by EPA OSRTI based on a recommendation from the associated EPA
Region. It was also selected as a test case to help determine if the RSE process might provide benefits if
applied at RP sites. This report provides a brief background on the site and current operations, a summary
of the observations made during a site visit, and recommendations for changes and additional studies.
The cost impacts of the recommendations are also discussed.
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1.2 TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:
Rob Greenwald, Hydrogeologist, GeoTrans, Inc.
Peter Rich, Civil and Environmental Engineer, GeoTrans, Inc.
Doug Sutton at GeoTrans also provided logistical support and report review. The RSE team was
accompanied by the following observer:
Jennifer Griesert from EPA OSRTI
1.3
DOCUMENTS REVIEWED
Author
US EPA
US EPA
US EPA
US EPA
US EPA
US EPA
US EPA
Reilly Industries
Env. and Geol. Consultants
Env. and Geol. Consultants
Env. and Geol. Consultants
Env. and Geol. Consultants
Varies
Reilly Industries
Env. and Geol. Consultants ??
Todd Stark
Date
6/30/92
9/30/03
9/27/96
6/30/97
10/6/97
12/16/99
4/6/00
11/18/02
4/3/03
9/17/03
9/24/03
??
Varies
10/28/03
10/03 ??
1 1/3/03
Title
Record of Decision, OU1
Record of Decision, OU2
Record of Decision, OU3, OU4
Record of Decision, OU5
BSD, OU2
Superfund Preliminary Site Closeout Report
Five Year Review Report
December 200 1 SMR Reports for ground water
wells
Annual Linear Regression Analysis
Addendum # 1 to Annual Linear Regression
Analysis
Water Table Maps (Shallow and Deep), Third
Quarter FY03
Cross Section Locations, and Cross Sections Based
on Soil Boring Logs and Gamma Logging
Well logs and/or construction information for
extraction wells
September 2003 SMR Reports for ground water
wells and for bypasses
Quarterly Report, Third Quarter 2003
Email to Tamra Kress with Oct 2003 PW flows
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1.4 PERSONS CONTACTED
The following individuals associated with the site were present for the visit:
Dion Novak, RPM, EPA Region 5
Kevin Herron, IDEM (State)
Tamra Kress, Reilly Industries
Phil Smith, CH2M Hill (consultant to USEPA)
Keith Might, Environmental and Geological Consultants (consultant to Reilly Industries)
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS
1.5.1 LOCATION AND HISTORY
The site is located at 1500 South Tibbs Avenue in the southwest quadrant of Indianapolis, Indiana. The
general site vicinity is illustrated on Figure 1. Minnesota Street divides the 120 acre site into two parcels.
The Oak Park property, which occupies approximately 40 acres, is located north of Minnesota Street. The
Maywood property, which occupies approximately 80 acres, is located south of Minnesota Street.
The facility is an active chemical manufacturing facility. The majority of the operating facility buildings
are located north of Minnesota Street, on the Oak Park property. Approximately 75% of the Oak Park
property is covered by buildings, pavement, and above-ground tank farms. Chemical manufacturing also
occurs on the northern portion of the Maywood Property.
The site is surrounded by a mix of residential, industrial, and commercial properties. Residential
neighborhoods are located immediately adjacent to the eastern boundary (on the east side of Tibbs
Avenue) of the Oak Park property. Two residences are also located abutting the northern property
boundary near the Lime Pond in the northwest corner of the site. Commercial and industrial properties are
located south and west of the site. All residences in the area of contaminated ground water have been
connected to the municipal water supply.
Industrial development of the Reilly site began in 1921 when the Republic Creosoting Company (which
later became Reilly Tar & Chemical, which in turn became Reilly Industries, Inc.) started a coal tar
refinery and a creosote wood treatment operation on the Maywood property. On-site wood treatment
operations occurred from 1921 until 1972. Beginning in 1941, several chemical plants were constructed
and operated on the Oak Park property. Environmental problems at the site are related to the management
and disposal of creosoting process wastes and to wastes associated with and substances used in the
process of manufacturing custom synthesized specialty chemicals.
In 1984, Reilly Tar was listed on U.S. EPA's National Priorities List (NPL). In 1987, the potentially
responsible party (Reilly) agreed to conduct an RI/FS. In 1989, Reilly Tar & Chemical changed their
corporate name to Reilly Industries, Incorporated, under which they operate today.
Records of Decision have been issued for five Operable Units (OUs) at the site, as follows:
OU1 ROD (June 1992) - calls for a ground water extraction/treatment/discharge system
to contain the migration of ground water contaminated by the site at the site boundary.
• OU2 ROD (September 1993) - calls for the excavation and thermal desorption of soil at
four on-site source areas and the solidification of sludge and placement of a soil cover
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over a fifth on-site source area. An Explanation of Significant Differences (BSD) was
issued in October 1997 to change from thermal desorption of some soil to off-site thermal
treatment, primarily because of the high BTU content of the soil.
• OU3 and OU4 ROD (September 1996) - calls for the installation of a permeable cover
over the OU3 "kickback" area, and also calls for soil vapor extraction and
concrete/asphalt cover over portions of the OU4 area.
• OU5 ROD (June 1997) - calls for monitored natural attenuation for the off-site portion of
contaminated ground water, and also calls for continued operation of OU1 Ground water
Interim Remedial Measures system.
This RSE report is focused on the operating pump-and-discharge (P&D) system, and the related MNA of
off-site ground water. A two-well perimeter ground water extraction system began operation in October
1994. Extraction wells have been added/replaced in several increments since that time.
1.5.2 POTENTIAL SOURCES
The RI indicated that there are at least five former waste disposal areas onsite that were potential source
areas for both on-site and off-site contamination (see Figure 1):
Lime Pond on the Oak Park property
Abandoned Railway Trench on the northern portion of the May wood property
Former Sludge Treatment Pit on the northern portion of the Maywood property
Drainage Ditch on the southern portion of the Maywood property
South Landfill on the southern portion of the Maywood property
Each is briefly discussed below. Remedial measures associated with OU2, OU3, and OU4 were
implemented in an attempt to eliminate or reduce the future impact to ground water from these sources.
In addition to the five areas listed above, 60,000 gallons of waste fuel, containing primarily pyridine and
pyridine derivatives, benzene, xylene, and toluene, were accidentally spilled on the Oak Park property in
1987. Some, but not all, of the fuel oil was recovered and some, but not all, of the contaminated soil was
excavated by Reilly.
Lime Pond
The Lime Pond was a lagoon constructed in 1953 to receive waste discharges from the first synthetic
pyridine base processing unit constructed on the Oak Park property. Dimensions of the Lime Pond were
approximately 350 feet by 350 feet. Until 1965, discharges from process areas on the Oak Park property
went to the Lime Pond, which included solid material and sludge that had settled out of the waste water
discharged to the Lime Pond area. Since 1965, when a connection to the city sewer was made, the Lime
Pond received only water from the boiler operations on the Oak Park property. Buried drums were
discovered at locations to the east and southeast of the lime pond. A total of 149 drums were removed
during field activities in November 1992. The soils to the north and east of the Lime Pond, in the Drum
Removal Area, were found to be contaminated with volatile organics up to levels of approximately
5,522,000 parts per billion (ppb) and semi-volatile organics up to levels of approximately 9,870,000 ppb.
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Abandoned Railway Trench
The Abandoned Railway Trench was used as an unloading and loading area for incoming rail shipments.
The railroad tracks were constructed below ground level to facilitate these operations. During the 1960s,
the use of the railway trench for loading and unloading purposes decreased and it was gradually filled in
with drums of off-specification coal tar enamel. Foundry sand obtained from a variety of local industry
was also used to complete the filling of the trench. It is estimated that the trench was approximately 5 feet
deep by 15 feet wide by 580 feet long. Soil contaminant concentrations from trench sampling for volatile
organics ranged to 656,000 ppb and for semi-volatile organics 126,020,000 ppb.
Former Sludge Treatment Pit
From the early 1950s until 1979, waste water sludge from the coal tar refinery and synthetic chemicals
operations was dried by placing it in the Former Sludge Treatment Pit, located in the center of the
Maywood property. The sludge pit was used for thickening sludge by evaporation prior to off-site landfill
disposal. The current RCRA-permitted sludge treatment area is located directly above the northern
portion of this historical area. The dimensions of the original sludge pit were 110 feet long by 20 feet
wide by 4 feet deep. Soil contaminant concentrations in the sludge pit sampling for volatile organics
ranged to 202,900 ppb and for semi-volatiles 53,710,000 ppb.
Drainage Ditch
Prior to 1970, waste water and storm water were conveyed from the American Petroleum Institute (API)
separator by the Former Drainage Ditch into the Raymond Street storm sewer, which then discharged
directly to Eagle Creek. This water consisted of water separated from the raw tar, water decanted from the
tar storage tanks, water separated from the oil-water separator, "wet-dry" in the refinery, blowdown water
from the boiler operations, aqueous sodium sulfate from the extraction of tar acids and tar bases from the
light and middle oils, and storm water entering the system due to natural drainage. Historically, the length
of the ditch was 1,220 feet, the width was between 15 and 50 feet, and the depth was approximately 8
feet. Soil contaminant concentrations in the Former Drainage Ditch sampling for volatile organics ranged
to 199,930 ppb and for semi-volatiles 117,120,000 ppb.
South Landfill
From the beginning of site operations in 1921 until the mid 1970s, the southern portion of the Maywood
property was used as a landfil (the South Landfill) for construction debris and soil. In addition, various
solid and semi-solid wastes (tars, sludges, still bottoms, tank cleanings) from the coal tar and the synthetic
chemicals operations were also deposited in this area. Coal refinery wastes deposited in the area included
off-specification pitches, creosoted timbers, coal, and tank car sludges and waste water sludge from the
Maywood API separator. Wastes from the synthetic chemical operations were also deposited in the south
landfill beginning in the 1960s. These wastes included waste water sludge from the API separator and
distillation residues from various unit processes including vinylpyridine residue and 3-pyridine
carbonitrile residue. Dimensions of the south landfill were approximately 1,000 feet by 200 feet. A dug
well, or fire pond, was situated at the extreme southeast corner of the south landfill, but it dried up after a
period of time, and was reportedly filled with tars, sludges, various chemical production residues, and
foundry sand. Soil contaminant concentrations in the South Landfill sampling for volatile organics
ranged to 197,300 ppb and for semi-volatiles 35,280,000 ppb. Field investigations in this area also
identified both NAPLs (non-aqueous phase liquids) and DNAPLs (dense non-aqueous phase liquids) as
present in the ground water in the form of oily sheen and distinct oil phases in ground water samples.
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1.5.3 HYDROGEOLOGIC SETTING
The Reilly site lies within the White River drainage basin, located approximately three miles to the west
of the White River. Eagle Creek is an attendant tributary and flows in a southeasterly direction
approximately 4,000 feet to the east of the site. Topography in the site area is relatively flat with a gentle
downward slope in an easterly direction. Other surface water bodies in the site area include Blue Lake (a
former gravel pit) located approximately 2,000 feet northeast of the site, several small ponds or surface
water impoundments located 2,000 to 4,000 feet east of the site, and one surface-water impoundment
located immediately southwest of the Maywood property. The westernmost extension of Blue Lake has
been filled in since 1979.
The sand and gravel deposits that underlie almost all of the White River drainage basin form the principal
aquifer in the area. In the vicinity of the site, upper and lower zones have been identified within the sand
and gravel outwash aquifer. At some locations, especially directly underneath the site, these zones are
separated by one or more till units which, because of their silt content, are less permeable layers and may
impede flow vertically. The upper and lower zones are referred to as the "shallow aquifer" and "deep
aquifer" in site documents. Based on site cross-sections provided to the RSE team, "shallow" wells are
typically screened approximately 20-40 ft below ground surface, and "deep" wells are generally screened
in the range of 50-100 feet below ground surface. In the April 2003 "Annual Linear Regression
Analysis" report it is suggested that an "intermediate aquifer" may also be present at some locations.
The lack of a continuous fine grained unit and similar ground water levels in shallow and deep wells
suggest that the upper and lower zones of the outwash sand and gravel deposits are hydraulically
connected and that the till units do not act as a significant barrier to contaminant flow in ground water.
Bedrock underlies the sand and gravel deposits. To the east of the site, bedrock is approximately 100 feet
below ground surface. However, bedrock is much shallower in portions of the on-site area (such as near
RI-17, where bedrock is more like 50 feet below ground surface based on cross sections provided to the
RSE team). It was reported during the RSE visit that the subsurface material on-site is more like a till and
therefore less conductive compared to the off-site area to the east, and therefore less water is produced in
on-site extraction wells than can be produced off-site to the east.
There are three industrial well fields located to the east of the site that, in the 1990s, had a reported
combined pumping rate of 10 million gallons per day, or approximately 7,000 gpm. Regional
hydrogeologic data indicate that ground water in the unconsolidated material in the area of the Reilly site
flows east towards Eagle Creek with a southerly component. Water level data from the RI indicate that
ground water flow is generally from the northwest to the southeast and that withdrawals from the
neighboring industrial production wells significantly impact the flow of ground water east of the site, thus
providing a barrier to further movement of ground water impacted by the site to the east. Hydraulic
conductivities for wells tested during the RI range from 10"2 to 10"3 centimeters per second (it is not clear
from documents provided to the RSE team which wells were tested). An average linear ground water
velocity of 0.68 feet per day was calculated in the RI for the area that is not influenced by the industrial
pumping to the east of the site, and an average linear ground water velocity of 2.0 feet per day was
calculated in the RI for the area that is influenced by the industrial pumping.
1.5.4 RECEPTORS
In May 1984, the Marion County Health Department (MCHD) declared the industrial area in the vicinity
of Reilly to be a threat to the safety of ground water for use by humans for drinking and ordered all of the
private water well users identified in the area to connect to the city water main and to properly abandon
and seal their private wells. The MCHD declared that the use of well water in this area was a violation of
the Code of the Health and Hospital Corporation of Marion County, Chapter 18, Section 18-803. At the
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direction of U.S. EPA, the MCHD recanvassed the survey area in August 1996. The survey results
indicated that all properties in the survey area were connected to city water and that no existing wells
were confirmed.
Institutional controls allow Reilly to use the ground water under the site for industrial purposes
(non-contact cooling water) only after obtaining the express written approval of U.S. EPA, or any
successor federal governmental department or agency. Industrial ground water production continues at
neighboring properties east of the site. This water is only used for industrial purposes. When pumping at
rates observed in the 1990's, these off-site wells provide a hydraulic barrier to further eastern migration of
impacted ground water.
During the RI, it was determined that there was no significant risk to the environment from site
contamination, primarily due to an absence of a suitable habitat for wildlife and the absence of any
significant onsite surface water accumulations.
1.5.5 DESCRIPTION OF GROUND WATER PLUME
The risk assessment determined that three chemicals in the ground water are of primary concern: benzene,
pyridine/pyridine derivatives, and ammonia. Other chemicals that were detected in the ground water are
also of concern but were not found at the same frequency or amounts. Concentrations have decreased
substantially at many wells since the P&D remedy was first implemented in 1994, but there are wells
located on-site and off-site where concentrations remain elevated at concentrations more than 100 times
the cleanup levels (discussed in more detail in Section 4.2.3). High concentrations are generally found in
shallow wells on-site, but higher concentrations are found off-site to the east at the intermediate or deep
wells (such as at RI-19D) . This may be the result of natural downward hydraulic gradients, or may be
the result of downward hydraulic gradients caused by off-site industrial pumping.
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2.0 SYSTEM DESCRIPTION
2.1
SYSTEM OVERVIEW
A "pump-and-discharge" (P&D) system operates at the site in an attempt to contain ground water at the
site boundary. There is no ground water treatment prior to discharge to the POTW. The P&D system
originated in 1994, and has been modified several times (detailed in Section 2.2). The current P&D
system contains five extraction wells, operating at a combined rate of approximately 220 gpm. MNA is
the selected ground water remedy for the off-site ground water.
There is also an SVE system located on the Oak Park property associated with OU4, in the vicinity of
monitoring well location RI-18. The RSE did not focus on the performance or operation of the SVE
system. However, it is noted that the SVE system started operation in 1999 and consists of 10 wells that
are rotated (5 passive and 5 active at any point in time).
2.2 EXTRACTION SYSTEM
The current extraction system includes the following wells (see Figure 1):
Extraction
Well
PW-1 (S)
PW-1 (D)
PW-2R
PW-3
PW-4
Other Name
For Well
Maywood Well (S)
Maywood Well (D)
Oak Park Well
Orchard Well
PW-4
Well
Depth (ft)
32
58.5
28.5
53
69.5
Screen
Depth (ft)
27-31
53-58
23-25
12-52
25.5-65.5
Screen
Length (ft)
4
5
2
40
40
Typical Rate
(gpm)
17*
132*
15
35
20
* Combined flow for PW-l(S) and PW-l(D) is typically reported, the separate flow estimates were provided during
the RSE site tour
The original two wells put in operation in 1994 were in the locations of PW-1 and PW-2 (see Figure 1).
PW-3 and PW-4 were added in 1997 based in part on numerical modeling that suggested those locations
for improved plume capture. PW-3 is located on the northern Oak Park property, and PW-4 is located
approximately 1,200 feet south of PW-1. PW-1 (D) replaced original well PW-1 (located a few feet from
the current well) in 2002. The original PW-1 began producing sand following a jet-washing procedure.
Well PW-2R was installed in 2002 as a replacement to original well PW-2 (located a few feet from the
current well). The original PW-2 was broken and separated at the top of the screen. PW-1 (S) was
installed in 2003 to increase overall production rate near PW-1, and induce more drawdown in the
shallow aquifer.
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Based on extraction well sampling in September 2003, benzene was <5 ug/1 at all the extraction wells
except PW-2R, where it was 231 ug/1. The total mass of benzene removed is therefore mostly from PW-
2R, and can be approximated as follows:
PW-2R (-15 gpm. -231 ug/1 benzene)
15 gal. 231 ug 3.785L 1440 min. 2.2 Ibs 0.04 Ibs
^^^^~^^^^~ Y ^^^^~^^^^~ Y ^^^^^~^^^^^~ Y ^^^^^^^^^^^^^^~ Y ^^^^~^^^^~ — ^^^^^~^^^^^~
min. L gal. day 109ug day
Other wells (-200 gpm. ~5 ug/1 benzene)
15 gal. 231 ug 3.785L 1440 min. 2.2 Ibs 0.01 Ibs
^^^^~^^^^~ Y ^^^^^^^^^^~ Y ^^^^^~^^^^^~ Y ^^^^^^^~^^^^^^^ Y ^^^^~^^^^~ zz ^^^^^~^^^^^~
min. L gal. day 109ug day
Therefore, approximately 0.05 pounds per day of benzene is currently being removed by the extraction
wells. This is extremely low. Pyridines are no longer monitored at these wells, but mass removal is
likely to be similarly low
2.3 TREATMENT SYSTEM
There is no on-site treatment system for extracted ground water, which is discharged to two POTWs
operated by the City of Indianapolis:
• Southport Wastewater Treatment Plant
Belmont Wastewater Treatment Plant
In addition to approximately 225 gpm of extracted ground water sent to these POTW's, approximately
350 gpm of plant process water is also sent to the POTWs. The northern wells (PW-2, PW-3) discharge
to the Southport plant, and the remaining wells plus the process water discharge to the Belmont plant.
2.4 MONITORING PROGRAM
For ground water monitoring some wells are monitored quarterly while others are monitored semi-
annually or annually. This schedule is detailed below:
Monitoring Frequency
Quarterly
Semi-Annual
Annual
List of Wells
RI-4S, RI-4D, RI-5S, RI-5D, RI-6S, RI-6D, RI-8S*,RI-16S*, RI-16D*, RI-17S,
RI-17D, RI-18S, RI-18D, RI-19S, RI-19D,
RI-11S, RI-11M, RI-11D, RI-15S, RI-15M, RI-15D, PW3, PW8
RI-2S, RI-9S, RI-9D, RI-23S, RI-25S, RI-28S, RI-29S, RI-30S, RI-31S, RI-
32S,RI-33S, RI-34S, RI-35S, RI-36S
*RI-8S, RI-16S, andRI-16D are listed as "annual" in site database, but sampling has historically been quarterly.
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In a meeting in June 2002, it was decided that "MNA data" would also be collected at selected wells. For
wells on the quarterly list, the following parameters are measured: DO, ORP, temperature, and
conductivity. At selected wells (RI-16S/D, RI-11M, RI-18 S/D, RI-19 S/D) additional parameters
measured are sulfate, methane, Fe+2, and Fe+3.
Water levels are measured quarterly, and potentiometric surface maps are produced quarterly. A Trend
Analysis Report is prepared annually, to evaluate concentration trends over time for benzene, total
pyridine, and ammonia. The purpose is to track effectiveness of the perimeter containment system and to
track progress of MNA in OU5 (off-site ground water). The ground water wells for which trend analysis
is conducted are grouped as follows:
Well Grouping
Background Wells (3)
On-site Wells (3)
Perimeter Wells (9)
Off-site Wells (10)
List of Wells
RI-16S, RI-16D, RI-23S
RI-2S, RI-18S, RI-18D
RI-5S, RI-5D, RI-6S, RI-6D, RI-8S, RI-9S, RI-9D,
RI-17S, RI-17D
PW3, PW8, RI-1 IS, RI-11M, RI-1 ID, RI-15S, RI-15M, RI-15D,
RI-19S, RI-19D
For ground water discharged to the POTW, some parameters (TSS, ammonia, flow) are measured
monthly, and remaining parameters are measured semi-annually.
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3.1
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The remedial objectives for the five operable units are summarized below:
• OU1 - According to the OU5 ROD, which finalized the interim action for OU1, "the first
operable unit action was selected by EPA to stop further off-site migration of
contaminated ground water by installing a ground water extraction system/treatment
system. This action provided adequate time to study and remediate on-site source areas as
well as to prevent the further contamination of area ground water resources by
contaminants migrating from the Reilly site." According to the ROD for OU5, the "the
perimeter ground water extraction system, selected as an interim remedy for OU1, is an
integral component of the final ground water cleanup for the site" and that "the GWIRM
[Ground Water Interim Remedial Measures] system will be in operation until the cleanup
and performance standards listed in Table 2 [of the OU5 ROD] are met at the facility
boundary". The ground water criteria, as confirmed by Reilly, are those listed in Table 5
of the OU1 ROD.
OU2, OU3, OU4 - The remedies selected in the RODs for OU 2, 3, and 4, were intended
to remediate sources of ground water contamination located on the Reilly site, and/or
mitigate the contributions of these areas to the ground water contamination problem.
• OU5 - the cleanup objective for the OU5 area is to restore ground water to drinking water
quality for future use and the remediation levels are MCLs. The point of compliance is
the property boundary, and ground water at the point of compliance must meet the
cleanup criteria mentioned above.
The cleanup standards for the primary contaminants of concern in ground water are summarized in the
following table.
Contaminant Exceeding Standard
Benzene
Pyridine (individual compounds)
Ammonia
Cleanup Standard
5ppb
35 ppb
30 ppm*
*errantly listed as 10ppm in the OU1 ROD text
The OU1 ROD lists cleanup standards for several other VOC and SVOC compounds, as follows:
trichloroethene - 5 ppb; ethylbenzene - 700 ppb; toluene - 1000 ppb; total xylenes - 10,000 ppb; benz(a)
anthracene - 100 parts per trillion (ppt); benzo (a) pyrene - 200 ppt; benzo (b) fluoranthene - 200 ppt;
benzo(k) fluoranthene - 200 ppt; chrysene - 200 ppt; dibenz(a,h) anthracene - 300 ppt; indeno (1,2,3 -c,d)
pyrene - 400 ppt.
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In the FFS for OU5, it was estimated that ground water in the OU5 area would achieve cleanup standards
in 1.5 to 16 years, depending on the contaminant. The OU5 ROD stated that the remedy will be monitored
on a continual basis over time to ensure that the selected remedy continues to be protective. U.S. EPA
will immediately reevalute the remedy to determine if it continues to provide the levels of protection to
human health and the environment outlined in the ROD if either of the following occurs:
• off-site industrial water users modify their extraction rates significantly or discontinue
ground water extraction at any point in the future
long term ground water monitoring shows that contaminant decay is not occurring at the
rates predicted in the ground water modeling results presented in the FFS
If it is determined by U.S. EPA that the remedy is no longer protective, then U.S. EPA will take the
appropriate steps necessary to provide protection of human health and the environment. The item
pertaining to contaminant decay is the basis for preparing an annual "Trend Analysis Report".
The site team indicated that they plan to operate the current perimeter pumping system for a long time,
but also indicated they might at some point seek to discontinue pumping before cleanup standards are met
based on risk arguments, but it is unclear what levels at the site boundary or off-site would allow the
pumping to be discontinued.
3.2 TREATMENT PLANT OPERATION STANDARDS
There is no on-site treatment, and extracted ground water is discharged directly to POTWs. The RSE
team was provided with several "Self Monitoring Reports" (SMR's) for individual extraction wells, and
they indicate the following "daily maximum levels" that are measured monthly:
• ammonia - 20 mg/1
pH -range of 5 to 12
TSS-300
According to an email from Reilly subsequent to the RSE site visit, the ground water discharge permit no
longer requires sampling for pyridine. As discussed earlier, water from some of the extraction wells is
mixed with plant effluent, and the plant effluent is sampled under a different permit (unrelated to ground
water).
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4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1 FINDINGS
The RSE team observed a site where ground water concentrations have decreased substantially at many
wells, indicating the initial success of the remedies. However, elevated concentrations persist at some
wells on-site and off-site. There is no treatment plant at the site, so this RSE does not pertain to
optimization of on-site treatment processes. Rather, this RSE focuses on hydrogeologic issues, such as
the effectiveness of ground water capture, the progress of MNA, etc. and cost-effective approaches to
evaluate and/or enhance the performance of the remedy The RSE team also noted a good working
relationship between the responsible party and the EPA RPM. The observations provided below are not
intended to imply a deficiency in the work of the system designers, system operators, or site managers but
are offered as constructive suggestions in the best interest of the EPA and the public. These observations
obviously have the benefit of being formulated based upon operational data unavailable to the original
designers. Furthermore, it is likely that site conditions and general knowledge of ground water
remediation have changed overtime.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 WATER LEVELS
Water levels are measured quarterly, and potentiometric surface maps are produced quarterly. Figure 2
and Figure 3 illustrate water levels for the shallow and deep aquifers, respectively (the contours were
interpreted by Environmental and Geological Consultants, Inc.). Ground water flow in both aquifers is
generally to the east, and is influenced by on-site extraction (PW-1 to PW-4) and significant off-site
extraction to the east. Note that the contours interpreted on those figures are based on water levels
measured at the extraction wells, which are likely much lower than the surrounding aquifer material as a
result of well losses. Without piezometers located near the extraction wells, the interpretation of water
levels near the extraction wells is subject to considerable uncertainty, and extent of capture interpreted
using such water levels may overestimated.
4.2.2 CAPTURE ZONES
The chosen Alternative 3 in the OU1 ROD indicated that 8 to 12 wells pumping a total of 1,200 gpm to
1,450 gpm would be needed to meet the containment objectives. The current extraction rate is about 220
gpm. The discrepancy in the flow rates from the ROD was due to the installed wells not producing as
much water as expected, due to the relatively low conductivity of the aquifer materials on-site (relative to
more productive aquifer materials to the east). The five year review conducted by EPA in 2000
concludes that "after the addition of the two extraction wells [PW-3 and PW-4] to the system, the entire
system has been evaluated and is currently meeting the ROD performance goal of containment at the
eastern property boundary". During the RSE site visit this conclusion was said to be based on the volume
pumped and looking at contour maps. As discussed above, however, it is difficult to assess capture at the
site boundary using the contour maps because the contour maps rely on water levels measured at
operating extraction wells due to lack of piezometers near those extraction wells. Furthermore, a
significant capture zone in the shallow aquifer (where the majority of on-site contamination is observed)
is not apparent on Figure 2. The EPA RPM indicates that previous flow modeling performed in the 1997
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timeframe supports that plume capture would be achieved with the current system (that modeling resulted
in the installation of PW-3 and PW-4).
The portion of the eastern site boundary between extraction wells PW-1 and PW-4 is an area of particular
concern with respect to capture effectiveness. These extraction locations are approximately 1,200 feet
apart. Monitoring well RI-5S, located between these two extraction wells, had concentrations exceeding
500 ug/1 for both benzene and total pyrdines in the last sample of 2002, and off-site well RI-19D (located
downgradient of RI-5S) had concentrations exceeding 1,000 ug/1 for both benzene and total pyridines in
the last sample of 2002. The deep water levels at RI-4D (north of PW-1) and RI-5S (south of PW-1) are
lower than surrounding wells, and indicate some potential for successful capture in the deep aquifer.
However, the same cannot be said based on the water level map for the shallow aquifer, which is where
most of the on-site contamination is found. Also, in both the shallow and the deep aquifer, there are not
enough water level measurements immediately downgradient of the extraction wells to clearly delineate
an actual capture zone.
A significant issue at this site regarding capture is that the extraction wells produce water with relatively
low concentrations of site contaminants. As discussed in Section 2.2, PW-2 is the only extraction well
that removes ground water with detectable benzene (pyridines are no longer monitored in the extraction
wells). PW-2 is a relatively shallow well. For well clusters on-site, the contamination is generally in the
shallow wells (e.g., RI-17S, RI-4S, RI-18S, RI-5S), and for well clusters off-site, the contamination is
generally greater at depth (e.g., RI-15M and RI-15D, RI-11M, RI-19D). Although most of the on-site
contamination is in the shallow wells, most of the water pumped from the on-site extraction wells is
from the deep aquifer (e.g., approximately 60% of the extracted water is from deep well PW-1, and nearly
25% of the extracted water is from PW-3 and PW-4, which have 40-foot screens). It is possible that the
majority of water captured by the current on-site extraction system is from the deep, less contaminated
aquifer, and that shallow ground water is not effectively captured (particularly between PW-1 and PW-4)
and subsequently migrates off-site, where it is then transported downward due to the influence of the off-
site pumping wells.
Simple capture zone analyses (such as analytical calculations of capture zone width) are complicated at
this site for several reasons. First, such calculations assume uniform hydraulic conductivity, but it was
stated during the RSE site visit that hydraulic conductivity varies considerably at this site, and in
particular increases to the east. Second, such calculations assume uniform aquifer thickness, but at this
site the shallow, intermediate, and deep aquifers are hydraulically connected to a some degree, making
specification of aquifer thickness difficult. In addition, aquifer thickness appears to also vary
considerably by location. Third, the wells pump at vastly different pumping rates (ranging from less than
20 gpm to more than 100 gpm), complicating any such analysis. Finally, background conditions are
likely impacted by the significant off-site pumping to the east. Due to the heterogeneity and three-
dimensionality of the site flow conditions, a thorough capture evaluation will likely require water level
measurements at additional locations, or the use of a calibrated three-dimensional numerical ground water
flow model in conjunction with particle tracking.
The OU5 ROD defines the "compliance point" as the eastern property boundary. It states that "the
GWIRM system will be in operation until the cleanup and performance standards...are met at the facility
boundary". The OU5 ROD further states that "in determining the point of compliance for this final
action, U.S. EPA considered the following factors: there are multiple sources of contamination on the
Reilly site, and through previous actions, U.S. EPA has left waste in place..." This compliance point
appears reasonable for determining whether or not pumping should continue at the facility boundary if the
goal is to prevent water impacted above cleanup levels from migrating offsite beyond the capture zone
that is created by such pumping (i.e., in conjunction with MNA for OU5). However, the RSE team notes
that the extraction wells are located close to the eastern site boundary, and that the stagnation point (the
14
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downgradient edge of the capture zone) associated with the on-site extraction may extend several hundred
feet east of the site boundary. Thus, under current pumping conditions it should be expected that ground
water above cleanup levels will persist at some distance (perhaps several hundred feet) beyond the eastern
property boundary. This impacted ground water would be within the capture zone and therefore could
remain above cleanup levels for a longer period of time than other wells in OU5.
If capture at the site boundary is not sufficient, and continuing sources of dissolved contamination remain
on site, then MNA may not remediate the offsite portion of the plume (such as at RI-19D) within the
timeframe stated in the OU5 ROD. However, even if capture at the eastern site boundary is not sufficient,
the Allison (Rolls Royce) production wells downgradient of the site likely capture any off-site plume that
might persist in the aquifer at that distance from the site. In fact, site contaminants might not persist to a
distance as far as the Allison wells. The RSE team noted during the site visit that, as ground water flows
to the east, it is possible the ground water becomes more aerobic, which may promote natural remediation
of the contaminants east of the site. Samples from Allison Well #3 have shown no detections of Reilly
site contaminants since 1997, which may be due to natural attenuation with distance (as discussed above)
and/or due to dilution with other water pumped by the Allison wells. Allison is aware of the potential
Reilly impacts to the water quality in their wells.
All downgradient potable well use has been terminated and institutional controls are in place. The nearest
environmental receptor is Eagle Creek about 4,000 feet east of the site. It is extremely unlikely that the
site contamination could reach this creek, because the industrial pumping creates a hydraulic barrier (as
long as such pumping continues) and aquifer conditions are likely more aerobic in the downgradient
direction, which promotes natural degradation of the contaminants of concern.
4.2.3
CONTAMINANT LEVELS
Concentrations have decreased substantially at many wells since the P&D remedy was first implemented
in 1994. Some examples are provided below:
Examples of Wells With Significant Concentration Decreases Since 1994
Location
onsite, north property
(near SVE system)
onsite, north property
(eastern site boundary)
off-site:
east of north property
off-site:
east of north property
on-site, south property
(nearPW-4)
Well
RI-18S
RI-17S
RI-15D
RI-11M
RI-6S
Max Cone
1994-1995
Ben: 16,000
Pyr: 65,900
Am: 51
Ben: 7,700
Pyr: 51,720
Am: 281
Ben: 1,500
Pyr: 1,294
Am: 27
Ben: 2,200
Pyr: 882
Am: 59
Ben: 1,800
Pyr: 2,651
Am: 12
Max Cone
1999-2000
Ben: 20,000
Pyr: 196,000
Am. 13
Ben: 250
Pyr: 333
Am: 170
Ben: 260
Pyr: 327
Am: 11
Ben: 950
Pyr: 294
Am: 100
Ben: ND
Pyr: ND
Am: 7
Max Cone.
2002
Ben: 60
Pyr: 166
Am: 14
Ben: 230
Pyr: 182
Am: 23
Ben: 100
Pyr: 105
Am: 16
Ben: 330
Pyr: 187
Am: 74
Ben: ND
Pyr: ND
Am: 2
15
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Location
off-site:
east of south property
Well
RI-19S
Max Cone
1994-1995
Ben: 2,200
Pyr: 841
Am: 16
Max Cone
1999-2000
Ben: 910
Pyr: 281
Am: 17
Max Cone.
2002
Ben: 30
Pyr: 96
Am: 3
Ben = Benzene (ug/1) Pyr = Total Pyridines (ug/1) Am = Ammonia (mg/1)
Despite impressive concentration reductions at these wells, concentrations remain above the cleanup
levels at some of these wells. The cleanup criteria are 5 ug/1 for benzene, 35 ug/1 for individual pyridine
compounds, and 30 mg/1 for ammonia.
There are other wells located on-site and off-site where concentrations remain elevated at significantly
higher concentrations than at the example wells listed above. Figure 4 illustrates wells where the latest
sample in 2002 had benzene greater than 500 ug/1 and/or total pyridines greater than 500 ug/1. These
wells are summarized below:
Wells Where Last Sample in 2002 had Benzene and/or Total Pyridines Exceeding 500 ug/1
Location
on-site, north property
(between PW-1 and PW-2)
on-site, south property
(upgradient of PW-4)
on-site, south property
(upgradient of PW-4)
on-site, south property
(upgradient of RI-5S)
on-site, south property
(between PW-1 and PW-4)
off-site, south property
(downgradient of RI-5S)
Well
RI-4S
RI-32S
RI-33S
RI-30S
RI-5S
RI-19D
Last Cone.
Ben: 130
Pyr: 6,978
Am: 46
Ben: 75
Pyr: 4,522
Am: 7
Ben: 530
Pyr: 3,441
Am: 75
Ben: ND
Pyr: 771
Am: 4
Ben: 810
Pyr: 646
Am: 11
Ben: 1,300
Pyr: 1,522
Am: 11
Comments
Concentrations relatively stable
since 1996
Had much lower concentrations
1996 to 1998 which then increased
to current values 1999-2002
Ben = Benzene (ug/1) Pyr = Total Pyridines (ug/1) Am = Ammonia (mg/1)
The declining concentrations at many wells suggest that the remedies to date (P&D, SVE, excavation,
etc.) have been successful at reducing continuing impacts to ground water, while the high concentrations
that persist at some wells indicate there continue to be some on-site areas where sources of ground water
contamination may remain, especially on the south property but potentially on the north property as well
(e.g., there are no ground water monitoring points immediately upgradient of PW-4S). Well RI-19D is of
particular concern because it is located off-site and has relatively high concentrations of benzene and total
pyridines that increased to current values after initially decreasing to much lower concentrations between
1996 and 1998. Well RI-19D is also located in a potential "capture zone gap" between extraction
locations PW-1 and PW-4, as discussed in Section 4.2.2.
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Also of note is that high concentrations are generally found in shallow wells on-site, but off-site to the
east (such as at RI-19D) higher concentrations are found at the intermediate or deep wells. This may be
the result of natural downward hydraulic gradients, or may be the result of downward hydraulic gradients
caused by off-site industrial pumping.
4.3
4.3.1
COMPONENT PERFORMANCE
EXTRACTION SYSTEM WELLS, PUMPS, AND HEADER
Each Reilly extraction well has a well head building containing well controls including amperage shutoff
and a flow meter, pressure indicator, check valve, throttling valve, sample port and air release valve on
the carbon steel pipe within the structure. Above ground piping outside of the structure is heat traced and
insulated. Grundfos pumps are used.
4.3.2
SYSTEM CONTROLS
System controls at the wellheads are summarized in Section 4.3.1. There are no centralized system
controls.
4.4
COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
O&M COSTS
During the RSE site visit, the annual costs for system O&M were estimated based on YTD costs
(approximately 75% of the year completed), and are summarized in the table below. Annual costs are
estimated to be approximately $392,000 per year for the P&D system and $55,000 per year for the SVE
system.
P&D SYSTEM
Item Description
Labor: Consulting and GW Sampling
Well & Pump Maintenance, Electrical Repairs
Agency Oversight
Utilities: Electricity
Disposal Fees (POTW)
Laboratory (GW Monitoring)
P&D Subtotal
Estimated Cost
$40,000 per year
$78,000 per year
$55,000 per year
$14,000 per year*
$175,000 per year
$30,000 per year
$392,000 per year
* This cost is estimated by the RSE team based on total pump horsepower, see section 4.4.1
SVE SYSTEM
Item Description
Labor: SVE
Utilities: Electricity
Agency Oversight
SVE Subtotal
Estimated Cost
$20,000 per year
$5,000 per year*
$30,000 per year
$55,000 per year
* This cost is estimated by the RSE team based on total pump horsepower, see section 4.4.1
Thus, the total for the two systems is approximately $447,000 per year.
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4.4.1 UTILITIES
Electrical costs are not tracked for the ground water remediation system versus the rest of the site
operations. However, during the RSE site visit it was estimated that ground water pumps had a total of
approximately 20 Hp and the five SVE blowers had a combined 7.5 Hp. Assuming an electricity rate of
approximately $0.08/kWh, this would translate to an annual cost of approximately $14,000 per year for
the P&D system and approximately $5,000 per year for the SVE system.
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
The pumped water is discharged to the POTW at a cost of $ 1.18 per 1,000 gallons, and total cost per year
was reported at $150,000 to $200,000 per year. This is the largest annual cost item at the site. It was
discussed during the RSE site visit that Indianapolis currently has one of the lowest POTW rates in the
country. However, this is expected to rise in the future, perhaps up to 3 times higher, due to required
system improvements.
4.4.3 LABOR AND MAINTENANCE COSTS
Labor cost is relatively low at this site, because there is no active ground water treatment system. Of the
estimated $60,000 per year, approximately $20,000 is associated with operating the SVE system, and the
reminder is primarily for ground water monitoring and reporting.
A contractor is used for well and pump maintenance, at cost of approximately $77,000 per year. This is a
significant percentage of annual O&M costs and results because multiple wells need cleaning
approximately two times per year and some wells (e.g., PW-2) as much four times per year. The site is
hoping to reduce these costs in the future with new approaches. Additional costs for electrical repairs are
estimated at $1,000 per year.
4.4.4 CHEMICAL ANALYSIS
At the RSE site visit it was estimated that annual cost for laboratory analysis was approximately $30,000
per year.
4.4.5 OVERSIGHT COSTS
At the RSE site visit, it was estimated that agency oversight costs (i.e., EPA and the State) charged to the
site are typically on the order of $85,000 per year. Of that, perhaps $30,000 per year pertains to oversight
costs for the SVE system, and the remainder is for ground water.
4.5 RECURRING PROBLEMS OR ISSUES
There have been issues regarding well fouling at the site for the extraction wells. In the Trend Analysis
Report (April 2003) it states that, at PW-2, the original well had "water cascading down the interior of the
well screen", and that was thought to increase the onset and extent of well fouling. The replacement well
at PW-2 was therefore constructed with a shorter (2 foot) screen. Similarly, the replacement well at PW-
1(D) in 2002 was constructed with a short (5 foot) well screen.
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4.6 REGULATORY COMPLIANCE
No problems were noted during the RSE site visit or document review.
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL
CONTAMINANT/REAGENT RELEASES
No reagent releases or accidents were reported to the RSE team.
4.8 SAFETY RECORD
No problems were reported to the RSE team.
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
The current system removes little mass and possibly does not meet the ROD goal of containment at the
site boundary (particularly between PW-1 and PW-4). In addition, some wells off-site (particularly RI-
19D) have high VOC concentrations (e.g., benzene and total pyridines concentration in ground water
exceeding 1,000 ug/1). However, all downgradient potable well use has been terminated and institutional
controls are in place, so that protection of human health is likely provided.
5.2 SURFACE WATER
The nearest environmental receptor is Eagle Creek about 4,000 feet east of the site. It is extremely
unlikely that the site contamination will reach this creek because the industrial pumping creates a
hydraulic barrier (as long as such pumping continues) and aquifer conditions are likely more aerobic in
the downgradient direction, which promotes natural degradation of the contaminants of concern.
5.3 AIR
No issues regarding air were identified during the RSE site visit. Off-site the highest contaminant levels
are at depth, while shallow ground water is relatively clean. As a result, volatilization will not likely
cause impacts to off-site structures. On-site there are some areas where ground water has elevated VOC
concentrations, and the RSE team is not aware if potential for impacts to indoor air quality have been
evaluated to date.
5.4 SOILS
Soils have been addressed by OU2, OU3, and OU4 and were not a focus of this RSE.
5.5 WETLANDS AND SEDIMENTS
The nearest environmental receptor is Eagle Creek about 4,000 feet east of the site. It is extremely
unlikely that the site contamination will reach this creek because the industrial pumping creates a
hydraulic barrier (as long as such pumping continues) and aquifer conditions are likely more aerobic in
the downgradient direction, which promotes natural degradation of the contaminants of concern.
20
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6.0 RECOMMENDATIONS
Cost estimates provided herein have levels of certainty comparable to those done for CERCLA Feasibility
Studies (-307+50%), and these cost estimates have been prepared in a manner consistent with EPA 540-R-
00-002, A Guide to Developing and Documenting Cost Estimates During the Feasibility Study, July 2000.
There is no treatment plant at the site, so this RSE does not pertain to optimization of on-site treatment
processes. Rather, the focus of this RSE is on hydrogeologic issues and related site goals and site exit
strategy. In developing the recommendations, the RSE team considers cost-effectiveness for the life-cycle
of the remedy. The RSE team believes there are two "big-picture" approaches that could be considered at
this site:
• Approach 1: Continue Current Approach. This approach seeks to achieve plume
containment using on-site extraction, plus MNA for the area beyond the capture zone of
on-site extraction, plus capture of any potentially impacted off-site ground water by off-
site industrial wells to the east.
Approach 2: Discontinue On-Site Extraction. This approach allows impacted ground
water to migrate to the east towards the off-site industrial wells, and relies on a
combination of institutional controls, natural remediation, and capture of any potentially
impacted off-site ground water by off-site pumping wells to the east.
The recommendations provided below are based on Approach 1, since that is the basis of the current P&D
system and is consistent with the latest OU5 ROD. The advantages and disadvantages of Approach 2 are
discussed in Section 6.4.
6.1 RECOMMENDATIONS TO IMPROVE EFFECTIVENESS
6.1.1 INSTALL PIEZOMETERS AND MONITORING WELLS To ALLOW FOR IMPROVED
EVALUATION OF PLUME CAPTURE
The RSE team suggests the installation of one piezometer cluster (for measurement of water levels only)
and one monitoring well cluster (for measurement of water levels and concentrations), to improve the
evaluation of plume capture provided by on-site extraction wells. Suggested locations are as follows:
• Piezometer cluster (shallow and deep), downgradient of PW-IS/ID (on-site or
immediately adjacent to Tibbs Road), for quarterly water level measurements
Monitor well cluster (shallow and deep), north of RI-19S/19D near the intersection of
Minnesota Street and Centennial Avenue, for quarterly water levels and concentration
monitoring according to the same schedule as RI-19D.
The purpose of the piezometer cluster near PW-1S/1D is to better understand aquifer levels near the area
of greatest site pumping. This will aid in the evaluation of potentiometric surfaces for both the shallow
and deep aquifer, and will also help with calibration of a numerical flow model if one is created/updated.
The purpose of the monitoring wells north of RI-19S/19D is to have an additional off-site monitoring well
cluster (in addition to RI-19S/19D) to evaluate concentration trends over time. The RSE team notes that
21
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on-site monitoring well RI-4S has very high levels of total pyridines (nearly 7 ppm in the last sample of
2002). The suggested well cluster is located downgradient of RI-4S. If concentrations in this new well
cluster decrease to below MCLs, then this result would provide substantial evidence that capture of the
contamination near RI-4S is adequate.
Capital costs for installing these piezometers and monitoring wells might cost $40,000, including
development of a work plan, oversight by a geologist, and documentation in a short report. Collection of
water levels at additional points should not increase annual costs significantly. Additional monitoring of
concentrations might add $5,000 per year.
6.1.2 PERFORM IMPROVED PLUME CAPTURE EVALUATION (INCLUDING USE OF A
NUMERICAL MODEL)
After the monitoring points suggested in Section 6.1.1 are installed, and one round of water levels that
includes the new points is available, an attempt should be made to interpret actual capture of the existing
extraction system in three dimensions. This evaluation should include the following components:
• Draw a map that illustrates the "target capture zone" in three dimensions (i.e., for both
the shallow and deep aquifers). This target capture zone should indicate the locations
along the eastern site boundary where capture is desired (i.e., the spatial limits of target
capture to the north and to the south), and should also indicate that conceptually the
actual capture zone will extend off-site given the proximity of the extraction wells to the
eastern site boundary.
Interpret potentiometric surface maps relative to the target capture zone for both the
shallow and deep aquifers without biasing the interpretation with water levels from
operating extraction wells.
Construct/update a three-dimensional numerical flow model that accounts for large-scale
heterogeneities in hydraulic conductivity and stratigraphy, includes the off-site pumping
stresses, and reasonably simulates water levels in both the shallow and deep aquifers
under stressed (i.e., pumping) conditions associated with the extraction system.
Observed upward and downward head differences should also be predicted reasonably by
the numerical model. A short-term shutdown of the extraction system (or short-term
change in pumping rates), and associated water levels, could then be used to verify the
model predictions under a different set of conditions. Water levels at "PW" wells should
not be used for the model calibration. The model, in conjunction with particle tracking,
can then be used to evaluate capture zones of the on-site extraction wells in three
dimensions. The best approach is to release particles throughout the model domain at
several different depths (one depth at a time) and track the particles forward to determine
where they are captured.
It is expected that this entire evaluation can be performed for approximately $40,000.
6.1.3 CONSIDER THE NEED FOR A MODIFIED EXTRACTION SYSTEM
The capture zone evaluation performed in recommendation 6.1.2 will indicate if modifications to the
extraction system are appropriate. Such modifications could potentially take several forms:
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• Potentially adding one or more extraction points (likely in the shallow aquifer), perhaps
between PW-1 and PW-4
Potentially discontinuing extraction of deep pumping at PW-1D, and/or potentially
packing off the deep portions of PW-3 and PW-4, to focus on-site extraction in the
shallow aquifer
Potential consideration of shallow air sparging in place of (or in addition to) shallow
ground water extraction, to augment biodegradation of site contaminants
The numerical model constructed (or updated) as part of the recommendation in 6.1.2 can be used to
evaluate different alternatives. This evaluation task is estimated to cost approximately $10,000. Since it
is not clear what (if any) modifications to the extraction system might result from this evaluation, no cost
estimates are provided for any modifications. It is noted, however, that there could be capital costs if new
extraction wells are required, and costs of discharging water could be increased or decreased depending
on the total extraction rate of a modified system (if pumping was modified to focus only on the shallow
aquifer, total pumping rate and thus the cost of discharging the water could potentially go down
significantly).
6.2 RECOMMENDATIONS TO REDUCE COSTS
6.2.1 CONSIDER USING EXTRACTED WATER FOR PROCESS AND COOLING WATER
The site currently uses about 350 gpm of city water at an unknown cost for process and cooling uses. It is
likely that with reasonable pretreatment, pumped ground water from the extraction wells could substitute
for at least a portion of this potable water. This would save costs of purchasing and subsequently
discharging that water. Based on current extraction rates, the cost of discharging to the POTW is
approximately $150,000 to $200,000 per year, so it is likely that up to $200,000 per year could
potentially be saved if no pre-treatment is required. If pre-treatment is required, some of the annual cost
savings might be offset. During the RSE site visit, Reilly indicated this idea has been previously
considered and rejected. The RSE team suggests this idea be re-considered periodically, especially if
POTW fees increase significantly in future years.
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT
6.3.1 MINOR SUGGESTION FOR IMPROVED O&M REPORTING
The RSE team did not review any routine O&M reports that included all of the following information in
one document:
pumping rates at extraction wells
• concentrations at extraction wells
blended concentrations at points of discharge
Site information could be more easily reviewed and evaluated if such data were presented in one
document that also included historical data, as is done with monitoring well concentrations in the "Annual
Linear Regression Analysis". This recommendation should cost approximately $1,000 per year to
implement.
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6.4 CONSIDERATIONS FOR GAINING SITE CLOSE OUT
Based on the current ROD, pumping will continue at the on-site extraction wells as long as ground water
cleanup standards are exceeded at the site boundary. As mentioned in the OU5 ROD, EPA acknowledges
that there are sources of contamination that remain on-site, and therefore the potential exists for
contamination at the site boundary to be impacted above cleanup levels for decades (at significant cost to
the responsible party due to P&D system operation). In addition, it is possible that cleanup levels off-site
will not be obtained at all locations (via MNA) within the timeframe estimated in the OU5 ROD, despite
the impressive concentration reductions observed to date at some wells. As discussed in Section 6.1 of
this RSE report, additional efforts including new monitoring points and a detailed capture zone evaluation
(including ground water flow modeling) are recommended to determine if capture provided by the on-site
extraction wells is in fact adequate to help achieve those off-site cleanup levels.
An alternate approach could be considered at this site that could ultimately save the responsible party the
vast majority of future costs for operating the P&D system. The alternate approach would discontinue
on-site pumping and allow impacted ground water to migrate to the east towards the off-site industrial
wells. To maintain protection of human health and the environment, this approach would rely on a
combination of institutional controls (that prevent the use of impacted ground water), natural remediation,
and capture of any potentially impacted off-site ground water by off-site industrial wells to the east. The
off-site wells would need to continue to operate for protectiveness to be maintained, but that is already a
condition of the existing OU5 remedy. Obviously, this approach would require a ROD change.
Some arguments for such an alternate approach might include the following:
Most of the contaminant reduction to date likely resulted from on-site remedial actions
associated with OU2 to OU4 that have reduced the continuing source term, and more
mass is likely removed currently due to natural remediation than from the P&D system.
The current on-site extraction system is removing almost no contaminant mass, as
discussed in Section 2.2 of this report. As a result, discontinuing extraction at these wells
will likely not cause significant additional mass to migrate off-site than is currently
occurring. Furthermore, if calculations were to be performed comparing the contaminant
mass estimated to remain on-site to mass removed by the P&D system, it would likely be
concluded that the current P&D system will not be the cause of significant on-site
contaminant mass reduction in the future, and therefore extraction at these wells is not
critical for on-site restoration (the current extraction wells were not in fact intended for
that purpose).
• Because the on-site extraction wells are located near the eastern site boundary, the
capture zone of those wells likely extends off-site to the east, perhaps several hundred
feet. This off-site area within the capture zone of the extraction wells may continue to be
impacted above cleanup levels for a long period of time. Therefore, some off-site impacts
are expected to persist for a long period of time under the current extraction approach,
and discontinuing the on-site extraction would only increase this "impacted off-site area"
an incremental amount (the distance between the downgradient extent of the capture zone
and the location of the Allison wells)
If pumping is discontinued and off-site concentrations do not increase from current
values, then there is no decrease in protectiveness relative to the current system (given
the institutional controls that prevent water use). Therefore, an argument could be made
to discontinue on-site pumping and to monitor off-site concentrations (including the new
well cluster recommended in Section 6.1.1) at an appropriate frequency (perhaps
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quarterly) to determine concentration trends overtime, with pre-set conditions that would
trigger pumping to resume.
Some arguments against such an alternate approach include the following:
It is not consistent with the current ROD, and a modified ROD would be required.
It potentially relies more heavily on continued off-site pumping than the current remedy.
It potentially increases the area between the site boundary and the off-site industrial wells
that may remain above ground water cleanup levels for an extended period of time.
It is beyond the scope of the RSE to recommend this alternate approach in place of the existing approach.
However, the RSE team suggests that this alternate approach be periodically considered by the site team
and the regulators at this site because there is a potential to decrease remedy costs dramatically if all
parties (including the regulators) agree that protectveness is not negatively impacted by such an
approach.
6.5 SUGGESTED APPROACH TO IMPLEMENTATION
The alternate approach suggested in Section 6.4, which includes discontinuing the P&D system, should be
considered first. As stated, RSE team is not recommending that alternate approach per se, but is
recommending the site team and regulators consider that alternative.
If the alternate approach is implemented, the additional monitoring well cluster in recommendations 6.1.1
should still be installed, but not the piezometer cluster. The other recommendations would no longer
apply.
Assuming the on-site P&D system is to continue, recommendation 6.1.1 should be implemented as soon
as feasible, followed by recommendation 6.1.2, and then 6.1.3. Recommendation 6.3.1 can be
implemented with the next routine O&M report. Recommendation 6.2.1 is not a high priority, since the
site team indicates it has previously been considered and rejected, and the RSE team simply recommends
that it be periodically reconsidered.
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7.0 SUMMARY
The RSE team observed a site where ground water concentrations have decreased substantially at many
wells, indicating the initial success of the remedies. However, elevated concentrations persist at some
wells on-site and off-site where . There is no treatment plant at the site, so this RSE does not pertain to
optimization of on-site treatment processes. Rather, this RSE focuses on hydrogeologic issues, such as
the effectiveness of ground water capture, the progress of MNA, etc. and cost-effective approaches to
evaluate and/or enhance the remedy effectiveness. The RSE team also noted a good working relationship
between the responsible party and the EPA RPM. The observations provided below are not intended to
imply a deficiency in the work of the system designers, system operators, or site managers but are offered
as constructive suggestions in the best interest of the EPA and the public. These observations obviously
have the benefit of being formulated based upon operational data unavailable to the original designers.
Furthermore, it is likely that site conditions and general knowledge of ground water remediation have
changed over time.
Recommendations to improve effectiveness in protecting human health and the environment include
adding a cluster of piezometers and a cluster of monitoring wells, and performing a detailed capture zone
evaluation (including the construction (or update) and calibration of a three-dimensional numerical flow
model to then be used in conjunction with particle tracking) that will indicate if modifications to the
extraction system are appropriate. The one recommendation to reduce cost is to potentially use the
extracted water for process or cooling water. The RSE team acknowledges that Reilly has previously
considered and rejected that idea, but a future increase in the discharge costs may make it appropriate to
reconsider this option. Minor additions to routine O&M reports are suggested for technical improvement.
For site closeout, the RSE team recommends that an alternate approach that includes discontinuing the
P&D system be considered. The RSE team is not recommending this alternate approach per se, but is
recommending that it be considered by the site team and the regulators. There is a potential to decrease
remedy costs dramatically if all parties (including the regulators) agree that protectiveness is not
negatively impacted by such an approach.
Table 7-1 summarizes the costs and cost savings associated with each recommendation in Sections 6.1
through 6.3. Both capital and annual costs are presented. Also presented is the expected change in life-
cycle costs over a 30-year period for each recommendation both with discounting (i.e., net present value)
and without it.
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Table 7-1. Cost Summary Table
Recommendation
6.1.1 Install Piezometers and
Monitoring Wells To Allow
For Improved evaluation of
Plume Capture
6. 1.2 Perform Improved
Plume Capture Evaluation
(Including Use of a Numerical
Model)
6. 1.3 Consider The Need for a
Modified Extraction System
6.2.1 Consider using
Extracted Water For Process
and Cooling Uses
6.3.1 Minor Suggestion For
Improved O&M Reporting
6.4. 1 Develop and Exit
Strategy (Consider Alternate
Approach)
Reason
Effectiveness
Effectiveness
Effectiveness
Cost
Reduction
Technical
Improvement
Site Closeout
Additional
Capital
Costs
($)
$40,000
$40,000
$10,000
$0
$0
Estimated
Change in
Annual
Costs
($/yr)
$5,000
$0
$0
($200,000)
$1,000
Estimated
Change
In Life-cycle
Costs
(S)1
$190,000
$40,000
$10,000
($6,000,000)
$30,000
Estimated
Change
In Life-cycle
Costs
($)2
$121,000
$40,000
$10,000
($3,228,000)
($16,000)
No costs estimated
Costs in parentheses imply cost reductions.
1 assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)
2 assumes 30 years of operation with a discount rate of 5% and no discounting in the first year
27
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FIGURES
-------
FIGURE 1. SITE LAYOUT AND SOURCES OF CONTAMINATION.
RI-10S/D
RI-16S/D
-N-
RI-11S/M/D
-3S/DJ
APW-3
f—ABANDONED
^RAILWAY TRENCH
(ALONG BUILDING)
RI-30S RI-5S/D
ALLISON PLANT
SLUDGE
TREATMENT
PIT
(AROUND PANS)
DRAINAGE
DITCH
SOUTH LANDF LL/
RAYMOND STREET
ALLISON PLANT #5
TW-100
LEGEND
© OFFSITE INDUSTRIAL PRODUCTION WELL
A PERIMETER EXTRACTION WELL
® Rl MONITORING WELL
® PRODUCTION WELL (PUMPING LEVEL)
(674.99)
600
=^
SCALE IN FEET
1200
(Note: Basemap from this figure produced by ECG, Inc., potential sources from figure in Five Year Review Report.)
-------
FIGURE 2. SHALLOW WATER LEVELS, 3RD QUARTER FY03.
RI-16S/D
691.22
9
FORMER
SLUDGE
TREATMENT
PIT
RI-21S/D
682.64
™MA1°©
600
SCALE IN FEET
1200
©
S
-680-
LEGEND
OFFSITE INDUSTRIAL PRODUCTION WELL
PERIMETER EXTRACTION WELL
Rl MONITORING WELL
NM NOT MEASURED
NL NOT LOCATED
NA NOT AVAILABLE
D DAMAGED WELL TOP
(Note: Based on figure produced by ECG, Inc.)
LINE OF EQUAL WATER LEVEL ELEVATION
' [ft msl (DASHED WHERE INFERRED)]
® PRODUCTION WELL (PUMPING LEVEL)
(674.99)
-------
FIGURE 3. DEEP WATER LEVELS, 3RD QUARTER FY03.
RI-16S/D
690.33
3)
-N-
FORMER
SLUDGE
TREATMENT
PIT
0 600 1200
SCALE IN FEET
(Note: Based on figure produced by ECG, Inc.)
LEGEND
OFFSITE INDUSTRIAL PRODUCTION WELL
PERIMETER EXTRACTION WELL
Rl MONITORING WELL
LINE OF EQUAL WATER LEVEL ELEVATION
0
A
«
con
[ft msl (DASHED WHERE INFERRED)]
® PRODUCTION WELL (PUMPING LEVEL)
(674.99)
NM NOT MEASURED
NL NOT LOCATED
NA NOT AVAILABLE
D DAMAGED WELL TOP
-------
FIGURE 4. WELLS WHERE LAST SAMPLE IN 2002 HAD MORE THAN 500 ug/L BENZENE AND/OR TOTAL PYRIDINES.
«
A
-N-
-ABANDONED
* RAILWAY TRENCH j
"(ALONG BUILDING) ;
RI-30S
f
RI-5S
Ben 810
Pyr=646
RI-33S
Ben=530
Pyr=3441
- FORMER
• SLUDGE
TREATMENT
PIT
(AROUND PANS)
FORMER W
DRAINAGE
DITCH
®
®
®
®
®
®
®
®
®
®
LEGEND
0 OFFSITE INDUSTRIAL PRODUCTION WELL
A PERIMETER EXTRACTION WELL
9 Rl MONITORING WELL
® PRODUCTION WELL (PUMPING LEVEL)
(674.99)
®
®
600
SCALE IN FEET
1200
(Note: Basemap from this figure produced by ECG, Inc., potential sources from figure in Five Year Review Report.)
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