EPA/ROD/R05-95/290
1995
EPA Superfund
Record of Decision:
CARTER LEE LUMBER CO.
EPA ID: IND016395899
OU01
INDIANAPOLIS, IN
09/29/1995
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ROD ID # EPA/ROD/R05-95/290 Site: Carter Lee Lumber Company
Location: Indianapolis, IN Operating Unit: 01
Media: soil, groundwater
Keys: soil, groundwater, no action, background contaminants, fencing, wood
preserving
Contaminant: heptachlor, arochlor 1254, alpha BHC, 4,4-DDT
EPA Region: 05 ROD Date: 09/29/95 EPA ID: IND016395899
Estimated Costs: O&M Costs:
Abstract:
Please note that the text in this document summarizes the Record of Decision for the purposes of
facilitating searching and retrieving key text on the ROD. It is not the officially approved
abstract drafted by the EPA Regional offices. Once EPA Headquarters receives the official
abstract, this text will be replaced.
The Carter Lee Lumber Company Site is located west of downtown Indianapolis. The site is seven
miles upgradient of one of the groundwater pumps used to supplement the publicly owned drinking
water supply for the City of Indianapolis. It is located in a commercial and industrial center
primarily composed of heavy industry with the exception of some scattered areas of older
single-family residential dwellings. The site is currently used for storage for a commercial
lumber yard and is fenced with restricted access. The Carter Lee Lumber (CLL)Company has been
at its present location for over 120 years. The site occupies a four-acre parcel in the
southeast corner of the CLL property. This parcel was acquired by CLL in 1979 for expansion of
lumber storage capabilities.
Lumber and associated materials are stored in three sheds on the site. The site is paved with
asphalt except for the southeast corner, which is covered with about six inches of compacted
gravel and soil. The site is relatively flat. It is bordered on the east and south by Conrail
railroad tracks, on the west by Reichwein Avenue and the north by CLL property. The bordering
tracks are elevated as much as six to eight feet above the site. The southeast corner of
the property is the lowest elevation point on the site.
From 1960-1973, the site was owned by Penn Central Corporation. During this time period, the
property was leased to several commercial waste hauling companies that used the site for
industrial waste product disposal. The site was leased first for the disposal of calcium
ferrosulfate. There is no evidence that this material is hazardous. It was then leased to a
series of partnerships mainly for industrial waste disposal. From court records regarding these
partnerships, the nature of the business was to purchase lime slurry, a waste product, and to
sell it to other companies. Neutralized metal plating sludge and neutralized calcium
ferrosulfate were reportedly sprayed on the site from 1971-1972. No other information regarding
the contaminants disposed of at the site is available.
There are unsubstantiated allegations of tank car dumping and disposal of oily filter cakes from
Conrail Lines associated with this site. In addition, from 1940-1985, CLL operated a small
quantity, batch-load wood preserving operation immediately off site, north of the northeast
corner of the site. This operation reportedly used consumer grade pentachlorophenol. This
information about possible contamination was used to plan the site investigation.
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CLL purchased the site in 1979. While the property was being developed for lumber storage, red
soil was discovered. When the red soil interfered with proper soil compaction, it was moved.
The red soil was stored near a trench area dug to hold construction debris. Asphalt was laid on
portions of the site and the storage yard was fenced as part of this work. The red soil was
later spread over an area in the southeast corner of the site and covered with six inches of
clean soil and six inches of compacted gravel, where it is currently located.
The site was investigated by EPA's Ecology and Environment Field Investigation Team (FIT) in
1985 because a Carter Lee Lumber Company employee reported small animals with sores and patchy
fur. Company employees complained of skin lesions and weight loss as well. Neither reports
were confirmed by local health officials.
FIT collected samples of the red soil. When tested, these samples contained heavy metals and
semi-volatile organic compounds (SVOCs). Based on the FIT investigation, the site was scored
for NPL listing due to the potential for groundwater contamination and a concern for potential
dermal contact.
During the remedial investigation (RI) of the site, sampling and analysis of groundwater and
subsurface and surface soil occurred which allows a determination of site conditions to be made.
Based on the evaluation of site conditions, EPA determined that there is no threat to human
health and the environment through exposure by ingestion or direct contact with the pesticides/
herbicides and PCBs found in the soils and groundwater on and near the site at concentrations
above background. Background contamination was not evaluated as part of this study, however the
presence of background contaminants was the basis for eliminating some on site contaminants from
further consideration.
Remedy:
The risk assessment conducted at the site determined that the site contaminants do not pose a
significant risk to those who may come in contact with them. Given these determinations, the no
action alternative is selected because it has been demonstrated that the contamination found
could not be attributed solely to CLL and the level of contamination attributable to the site
results in negligible risk.
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Text:
Declaration For the Record of Decision
SITE NAME AND LOCATION
Carter Lee Lumber Company
Indianapolis, Indiana
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Carter Lee Lumber Company site in Marion County, Indiana
which was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and is consistent with the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP) to the extent practicable. This decision is based upon the
contents of the Administrative Record for the site.
DESCRIPTION OF THE SELECTED REMEDY
U. S. Environmental Protection Agency (EPA) has selected "No
Action" for the site remedy.
DECLARATION STATEMENT
EPA has determined that site related contaminants pose no current
or potential threat to human health or the environment.
Accordingly, no further remedial action will be undertaken at
this site. The site now gualifies for inclusion on the
Construction Completion List.
The State of Indiana has indicated a willingness to concur with
this decision. A written confirmation is expected shortly and
will be added to the administrative record upon receipt.
DATE Valdas V. Adamkus
Regional Administrator
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EPA Superfund
Record of Decision
Carter Lee Lumber Company Site
Indianapolis, IN
September 1995
RECORD OF DECISION
CARTER LEE LUMBER COMPANY SITE
TABLE OF CONTENTS
TEXT
I. Site Description 01
II. Site History and Enforcement Activities 01
III. Highlights of Community Participation 02
IV. Scope and Role of Operable Units 03
V. Site Characteristics 03
VI. Summary of Site Risks 06
VII. Explanation of Significant Changes 08
TABLES
Table 1: Summary of Organics in Soils 09
Table 2 : Summary of Inorganics in Soils 10
Table 3: Summary of Results of Groundwater Sampling 11
Table 4 : Contaminants of Concern 12
Table 5 : Summary of Risk Calculations in Soils 13
Table 6: Summary of Risk Calculations in Groundwater 13
FIGURES
Figure 1: Carter Lee Lumber Company Site Location Map 14
Figure 2 : Site Map with Sampling Locations 15
Figure 3 : Site Geology 16
Appendix A. Responsiveness Summary
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Appendix B. Administrative Index
DECISION SUMMARY
I. Site Description
The Carter Lee Lumber Company Superfund Site (Site) is located west of downtown
Indianapolis at 1621 West Washington Street. Eagle Creek is approximately one mile southwest and
the White River is about nine-tenths mile east of the Site. The Site is located 7 miles
upgradient of one of the groundwater pumps used to supplement the publicly owned drinking water
supply for the City of Indianapolis. It is located in a commercial and industrial center
primarily composed of heavy industry with the exception of some scattered areas of older
single-family residential dwellings. The Site is currently used for storage for a commercial
lumber yard and is, therefore, fenced and access is restricted. The Carter Lee Lumber (CLL)
Company has been at its present location for over 120 years. The Site occupies a four acre
trapezoid in the southeast corner of the CLL property. This parcel was acguired by CLL in 1979
for expansion of lumber storage capabilities. See Figure 1 for the Site location.
Lumber and associated materials are stored in three sheds on the Site. The Site is
paved with asphalt except for the southeast corner, which is covered with about six inches of
compacted gravel and soil. The Site is relatively flat. It is bordered on the east and south
by Conrail railroad tracks, on the west by Reichwein Avenue and the north by CLL property. The
bordering tracks are elevated as much as 6 to 8 feet above the Site. The southeast corner of
the property is the lowest elevation point on the Site.
Over 36,000 people live within two-miles of CLL. The closest residence is across
Reichwein Avenue. Demographics from the 1990 census data show that thirty-two percent of the
residents within a two mile radius of the Site are non-white while twenty-two percent of the
residents of Marion County identified themselves as non-white. In addition, the average
household within a two mile radius of the Site has income thirty-three percent lower than the
average household income in Marion County.
II. Site History and Enforcement Activities
Prior to 1979, the Site was owned by Penn Central Corporation and, in the period from
1960-1973, it was leased to several commercial waste hauling companies that used the Site for
industrial waste product disposal. The Site was leased first for the disposal of calcium
ferrosulfate containing about 30% solid. There is no evidence that this material was hazardous.
It was then leased to a series of partnerships mainly for industrial waste disposal. From court
records regarding these partnerships, the nature of the business was to purchase lime slurry, a
waste product from Union Carbide Corporation, Linde Division, and to sell it to Ford Motor
Company, in Indianapolis, Delco Electronics in Kokomo and Jones Laughlin Steel. Neutralized
metal plating sludge and neutralized calcium ferrosulfate were reportedly sprayed on the Site
from 1971-1972. No other information regarding the contaminants disposed of at the Site is
available.
There are unsubstantiated allegations of tank car dumping and disposal of oily filter
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cakes from Conrail Lines. In addition, from 1940-1985, CLL operated a small quantity,
batch-load wood preserving operation immediately off-site, north of the northeast corner of the
Site. This operation reportedly used consumer-grade pentachlorophenol. This information about
possible contamination was used to plan the Site investigation.
CLL purchased the Site in 1979. While the property was being developed for lumber
storage, red soil was discovered. When the red soil interfered with proper soil compaction, it
was moved. The red soil was stored near a trench area dug to hold construction debris. Figure 2
is a map of the Site that shows the areas identified. Asphalt was laid on portions of the Site
and the storage yard was fenced as part of this work. The red soil was later spread over an
area of about 220 by 250 feet in the southeast corner of the Site and covered with six inches
clean soil and six inches of compacted gravel, where it is currently located.
The Site was investigated by the EPA' s Ecology and Environment Field Investigation
Team (FIT) in 1985 because a Carter Lee Lumber Company (Company) employee reported spotting
small animals with sores and patchy fur. Company employees complained of skin lesions and
weight loss too. Neither reports were confirmed by local health officials. FIT collected
samples of the red soil which, when tested, contained heavy metals and Semi-Volatile Organic
Compounds (SVOCs). Based on the FIT investigation, the Site was scored for NPL listing due to
the potential for groundwater contamination and a concern for potential dermal contact should
the soils be disturbed.
Research to identify parties responsible for conditions at the Site was completed in
June 1988. Potentially responsible owners, operators and generators were identified. Based on
information gathered during this search and responses from information requests, special notice
letters were sent out during January 1992. In accordance with U.S. EPA policy, an attempt was
made to negotiate a Potentially Responsible Party (PRP) - lead response action. When the PRPs
failed to respond with a timely proposal to perform the work, a fund-lead remedial investigation
was initiated in 1992.
III. Highlights of Community Participation
EPA hosted a "kick off" public meeting on September 3, 1992 at the Presbyterian Church
located across the street from the Site. The purpose of the meeting was to inform the local
residents of the Superfund process and the work to be conducted under the Remedial Investigation
(RI). Thirty-nine people attended the meeting. Two RI update newsletters were issued to
individuals on the Site specific mailing list in June 1993 and July 1995.
Information repositories for the Site have been established at Hawthorn Community
Center, 2440 West Ohio Street, Indianapolis IN and the offices of the Indiana Department of
Environmental Management, 100 N. Senate Avenue, N1255, Indianapolis, IN. The Administrative
Record for the Site has been made available to the public at the EPA Docket Room in Region V and
at the Hawthorn Community Center. The RI was released to the public in May 1995. The proposed
plan was mailed July 28, 1995. A public meeting to discuss the remedial investigation and the
proposed plan was held on August 10, 1995. Advertisements were placed in the Indiana
Star/News and the West-Side Enterprise to announce the public meetings and comment period. Ten
people attended the proposed plan meeting. The public comment period for the proposed plan
extended from August 1, 1995 through August 30, 1995. The public generally supports the remedy
selected. The responsiveness summary is contained in Appendix B.
The public participation requirements of CERCLA Sections 113(k)(2)(i-v) and 117 of
CERCLA have been met in the remedy selection process. This decision document presents the
selected remedial action for the Carter Lee Lumber Company Superfund Site, chosen in accordance
with CERCLA, as amended by SARA and, to the extent practicable, the National Contingency Plan
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(NCP). The decision for this Site is based on the administrative record.
IV. Scope and Role of Operable Units
EPA has determined that no further action is required at this Site. The hazardous
substances remaining at the Site will allow unlimited Site use and unrestricted exposure to Site
soils and groundwater since exposure presents no significant incremental risk. In accordance
with Agency policy, a five-year review will not be necessary to assure human health and the
environment are protected.
V. Site Characteristics
During the RI, sampling and analysis of groundwater and subsurface and surface soil
occurred which allows a determination of Site conditions to be made. The investigation took
place in two phases beginning in November 1992 and ending about one year later in September
1993.
During Phase I in November 1992, all surface and subsurface on-site soil samples were
collected, five monitoring wells were installed and sampled and 15 of the 17 off-site soil
samples were collected.
Phase II, which occurred in June, August and September of 1993, consisted of two
rounds of groundwater samples, three rounds of water level measurements and the collection of
two additional off-site soil samples. A groundwater user survey was implemented during this
time period as well. An ecological investigation of the Site was also conducted as part of
Phase II.
Using the EPA risk assessment guidance and procedures, many contaminants found at the
Site, including SVOCs, Volatile Organic Compounds (VOCs), metals and cyanide were eliminated
from further consideration primarily because on-site concentrations did not differ significantly
from off-site concentrations in the background.
The ecological investigation consisted of review of current literature to determine
whether the area contained protected plants or animals or whether sensitive habitats existed in
the area. A Site visit also took place.
Based on the evaluation of Site conditions, EPA determined that there is no threat to
human health and the environment through exposure by ingestion or direct contact with the
pesticides/herbicides and PCBs found in the soils and groundwater on and near the Sites at
concentrations above background. Background contamination was not evaluated as part of this
study, although, the presence of background contaminants was the basis for eliminating some
on-site contaminants from further consideration. The following is a summary of the findings.
1. Physiography
The Site is located within the commercial and industrial center of the City of
Indianapolis, in central Marion County. The area is relatively flat and ranges in topographic
relief from about 745 feet above mean sea level measured 2.75 miles west of the Site to about
690 feet. The Site is paved with asphalt except for the southeast corner, which is covered with
compacted gravel. Drainage swales, formed by railroad track berms 6 to 8 feet high, run parallel
to the eastern and southern boundaries and collect surface run-off from the Site. The southeast
corner is the lowest elevation point, 691 feet above mean sea level, on the Site.
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2. Geology
An extensive sand and gravel outwash deposit exists under the Site. The outwash is
composed of coarse-grained material deposited by glacial meltwater streams during the
Wisconsinan glaciation. Discontinuous silt and clay deposits are numerous. The outwash extends
along the White River, Eagle Creek and Fall Creek and it is about 6.5 miles wide from east to
west. At the outer edges of the outwash, the deposits integrate with deposits of till. Sand
and gravel deposits are discontinuous in the till plain. The thickness of the unconsolidated
deposits in Marion County ranges from less than 15 feet to more than 300 feet. Within the
vicinity of the Site, the bedrock beneath the outwash deposits consists of Silurian and Devonian
age limestones and dolomites. Depth to bedrock is about 120 feet. West of the Site,
Mississippian age shale separates the outwash deposits from the limestones and dolomites. The
bedrock surface slopes gently to the west.
The Site is characterized by a series of fill layers starting at about 12 inches below
the ground surface This fill material varies across the Site but generally consists of sandy
gravel and clayey silty sand with miscellaneous debris including bricks, concrete and wood.
Some areas of the Site are filled with black dense sand similar to a foundry sand mixed with
what appeared to be fly ash. Figure 3 shows the typical Site geology.
3. Hydrology
There are two groundwater systems beneath the Site. The outwash deposits along the
White River comprise the upper, unconfined aquifer. The thickness of the aguifer ranges from 30
to more than 80 feet. The limestone and dolomite formations comprise the uppermost bedrock
aguifer. The average horizontal hydraulic conductivity is about 300 feet/day for the outwash
aguifer and about 10 feet/day for the bedrock aguifer. The hydraulic conductivity in the
bedrock aguifer can be considerably greater in areas where solution channeling has occurred.
Wells in the outwash aguifer have produced as much as 3,000 gallons per minute (gpm).
Bedrock wells may yield 75 to 250 gpm. The bedrock is most productive in the upper 100 feet
where it was once exposed to weathering elements and where the greatest amount of solution
development has occurred.
At the Site unconfined, shallow water table was encountered at about 15 to 20 feet
below ground surface. Typically, groundwater flows toward the southeast. Through the well
users survey, a cone of depression was identified southeast of the Site. Most of the wells
within 1 mile of the Site are used exclusively for manufacturing processes.
Marion County depends on surface water for 92% of its drinking water supply, the
remainder comes from groundwater. The use of groundwater to supplement drinking water is
expected to increase to about 19% by the year 2000. The closet drinking water well is seven
miles south of the Site and has shown no significant levels of site related contaminants.
Groundwater elevations in Marion County range from about 830 feet in the northwestern
portion of the county to less than 680 feet near the White River in the central portion of the
county. Regional groundwater flow in the western half of Marion County is to the east-southeast
toward Eagle Creek and the White River. In eastern Marion County, groundwater flow is to the
west-southwest toward Fall Creek and the White River.
4. Contamination
a. Soils
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SVOCs and heavy metals were detected in on-site soil at depths ranging from 4 to 8
feet below the ground surface. Several pesticides were also detected in on-site soil. The
findings were similar to those resulting from FIT sampling in 1985. The concentration of SVOCs
and metals in on-site soils were within the ranges previously found by the FIT and the
distribution of SVOCs on-site was consistent with the presence of red soil and with the black
cinder fill material. Table 1 and 2 identify organic and inorganic substances found in the
soils on and off Site.
b. Groundwat e r
Sampling of the groundwater identified low concentrations of some SVOCs including
phenol, phenanthrene, di-n-butylphthalate, pyrene, and bis(2-ethyl-hexyl)phthalate. These were
found sporadically in groundwater samples. Low concentrations of arsenic and cyanide were
detected in several Site ground-water monitoring wells during one sampling event. Beryllium was
detected at low concentrations during two sampling events. Table 3 presents the organic and
inorganic substances found in the groundwater.
5. Ecological
The investigation determined that the area south of the Site by virtue of plant
community composition and evidence of hydrology typical of wetlands, appeared to consist of
palustrine emergent or scrub/shrub communities. Through research and observations during the
Site visit, it was determined that this area is not a sensitive or high-value ecological
habitat. Wildlife and plant communities are limited because of the urban nature of the area.
During the Site visit, gross evidence of adverse impacts on the plant and animal communities
from the Site were not apparent.
VI. Summary of Site Risks
Given that most of the contaminated soil on-site is either covered by asphalt or six
inches of compacted gravel and soil, no workers or nearby residents are currently exposed to
site related contaminants through either inhalation or dust emissions.
Occupational and residential land use scenarios were used in the risk analysis. Both
showed negligible risk for exposure.
Volatilization of some contaminants to the air can pose an unacceptable risk if
present at the soil surface. Because contaminants on-site are covered as described above,
volatilization is not considered a likely transport mechanism at this Site. The risk analysis
identified negligible risk for exposure to site contaminants.
The analytical results for SVOCs and metals for on-site and off-site samples were
evaluated using a statistical comparative analysis. Table 1 and 2 show the outcome of this
comparison. It was verified statistically, that there is no significant difference between the
SVOCs and the heavy metal concentrations found in on-site soils compared with those found in
off-site soils. The Site is located in an area with many industries which may have contributed
to the metals and Polynuclear Aromatic Hydrocarbons (PAHs) found. These facts lead to the
conclusion that the source of PAHs and metals contamination cannot be traced solely to the Site.
Based on these considerations, PAHs and metals were not considered a Site related contaminant.
The berms on the east and southern boundary are an effective barrier to overland flow
of contaminants into surface water via site run off. No evidence could be found to indicate
that surface water has been impacted by site contaminants. For these reasons, the risk for the
surface water pathway was determined to be negligible.
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During the analysis, infiltration of rainwater to groundwater was considered as a
potential transport mechanism that could leach contaminants from deeper soils into the
groundwater. The RI identified Site characteristics that make leaching unlikely. The soils are
covered with six inches compacted gravel and six inches clean soil, which decreases, somewhat,
the amount of rain through infiltration. The soils underlying contaminants consist of clayey
sands. Since contaminants tend to sorb more tightly to clay, contaminants are less likely to be
released. In addition, a fate and transport analysis of the effects of the PAHs, arsenic and
beryllium determined that groundwater does not appear to be threatened by Site contaminants.
Based on these findings, it was determined that this pathway did not present an unacceptable
risk.
The contaminants of concern evaluated guantitatively for the Site include heptachlor
and arochlor-1254 in on-site soils and alpha BHC and 4,4'-DDT in groundwater. Table 4
identifies concentration ranges and freguency of detection along with other pertinent
information.
The risk assessment determined that the Site contaminants do not pose a significant
risk to those who may come in contact with them. Tables 5 and 6 show the estimated cumulative
excess cancer risk and the hazard index for non-carcinogenic contaminants. The risk to a
hypothetical future worker exposed to on-site soil and groundwater was calculated. As can be
seen from Tables 5 and 6, the calculated numbers are well below EPA's acceptable risk range. A
reasonable future land use anticipates the land will continue to be used as commercial/
industrial property. Notwithstanding this assumption, the same calculation is performed for the
hypothetical on-site resident too. As can be seen, the estimate of cumulative excess cancer
risk for the hypothetical resident is at the low end of EPA's acceptable risk range for exposure
to soils. For groundwater, the number calculated is below the lower end of EPA's acceptable
risk range.
Given the above determinations, the no action alternative is selected because it has
been demonstrated that the contamination found could not be attributed solely to CLL and the
level of contamination attributable to the Site results in negligible risk.
VII. Explanation of Significant Changes
The public comment period resulted in no significant changes to the Agency's proposal
for site remediation.
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Table 1
Analytical Summary for Organic Compounds Detected in Soil
Carter-Lee Lumber Company site
Median Value
Detected
Maximum Value
Detected
Contaminant
of Concern?
Compound
Volatiles(• g/kg)
Toluene
10.
130
No
Semi-volatiles(• g/kg)
Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Flourene
Phenanthrene
Anthracene
Carbazole
Di-n-butylphthalate
Flouranthene
Pyrene
Benzo[a]anthracene
Chrysene
bis(2-Ethylhexyl)phthalate
Di-n-octylphthalate
Benzo[b]flouranthene
Benzo[k]flouranthene
Benzo[a]pyrene
Indeno[1,2,3-cd]pyrene
Dibenz[a,h]anthracene
Benzo[g,h,i]perylene
Pesticides/PCBs(• g/kg)
Heptachlor(a)
Heptachlor epoxide
4,4'-DDE(a)
Endrin
Endosulfan II
4,4'-ODD
Endosulfan sulfate(a)
4,4'-DDT
Methoxychlor
Endrin ketone
alpha-Chlordane
gamma-Chlordane
Aroclor-1254(a)
214
182
128
166
140
143
672
270
157
115
875
1022
575
631
247
188
848
454
549
327
259
388
1.14
1.19
2.22
3.09
2.38
1.98
2.20
4.71
10.76
2.41
1.57
1.51
20.48
2200
1400
1800
1800
1200
610
6500
1200
580
1800
8400
15000
5300
6400
3600
3600
12000
5700
7800
3600
3600
6200
4.2
5.6
46
15
21
4.6
28
140
46
33
24
25
35
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
Yes
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Table 2
Analytical Summary for Inorganic Compounds Detected in Soil
Carter-Lee Lumber Company Site
Metals(mg/kg)
Median
Detected
Value
Maximum
Detected
Value
Contaminant of
Concern?
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
4821
5.9
11.3
43.4
0.6
0.7
80737
20.5
5.9
22.4
16458
42.8
17953
468
0.1
20.7
634
0.4
0.8
104.8
0.2
15.3
76.4
0.5
14900
10.0
197.0
328.0
151.0
1.3
198000
439.0
15.3
114.0
161000
376.0
59000
1280
0.5
173.0
1250
3.5
2.4
332.0
0.5
88.6
564.0
2.1
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
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C omp ound C LMWO1
CLW05 Water
Volatiles(• g/L)
Chloroform
Semivolatiles(• g/L)
Phenol
Naphthalene
Diethlphthalate
Phenanthrene
Di-a-butylphthaiate
Flouranthene
Pyrene
bis(2-Ethylhexyl)phthalate
Pesticides/PCBs(• g/L)
alpha-BHC
delta-BHC
gamma-BHC(Lindane)
Heptachlor
Aldrin
Dieldrin
Endrin
Endosulfan sulfate
4,4'-DDT
Inorganics(• g/L)
Aluminium
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Table 3
Analytical Summary Groundwater
Carter-Lee Lumber Company Site
Drinking
CLMW02 CLMW03 CLMW04
(UPGRADIENT) (UPGRADIENT) (downgradient) (downgradient) (downgradient)
< 10
< 10
< 10
< 10
MCL
100
< 10
< 10
< 10
< 10
< 10
< 10
< 10
< 10
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.1
< 0.1
32.3
< 1
.138
1.0
< 1.7
131000
< 3
< 3.8
3
< 10
< 10
< 10
1
< 10
< 10
0.6
< 0.05
< 0.05
0.01
< 0.05
< 0.05
< 0.05
< 0.05
< 0.1
0.012
< 23.5
1.6
70.3
<.81
< 1.7
117000
< 3
< 3.8
< 10
< 10
< 10
0.8
0.8
< 2
0.8
1
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
0.22
0.22
26.5
1.3
67.0
1.1
< 1.7
194000
< 3
< 3.8
< 10
< 10
< 10
< 10
< 10
< 10
< 10
< 10
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.1
< 0.1
< 24
1.1
49.8
< 1
< 1.7
179000
< 3
< 3.8
< 10
< 10
< 10
< 10
< 10
< 10
< 10
< 10
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.05
< 0.1
< 0.1
< 23.5
1.5
68.5
2.3
4.0
197000
< 3
< 3.8
NA
NA
NA
NA
NA
NA
NA
6
NA
NA
0.2
0.4
NA
NA
2
NA
50-200*
50
2000
4
5
NA
100
NA
NA
-------
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Thallium
Vanadium
Zinc
Cyanide
Treatment Parameters(mg/L)
Alkalinity
Total Organic Carbon
Chemical Oxygen Demand
Chloride
Hardness, as CaC03
Total Dissolved Solids
Total Suspended Solids
5.2
127.0
5.5
34400
46.7
<.l
11.9
4160
1.4
54000
<.7
< 3
11.8
2.0
399
5.54
12.7
70.9
651
686
2410
< 3.6
51.7
2.3
32400
7.8
<.l
11.4
4680
6.1
37200
1.4
< 3
7.0
5.4
295
5.65
49.2
55.1
532
586
2240
< 4
10.6
1.9
39900
224
<.l
8.9
4070
1.3
46100
1.0
< 3
4.6
2.0
442
15.1
144
71.8
827
830
3810
< 3.6
23.5
3.0
45000
11.6
<.l
< 5
4490
9.2
53200
<.7
< 3
6.5
3.9
406
9.4
93.7
72.3
569
710
3210
6.3
112.0
2.2
33100
90.6
<.l
11.4
3940
5.0
40400
< 0.7
4.8
14.3
4.0
372
7.24
98.4
61.9
592
664
5510
1300
300*
15
NA
50*
2
100
NA
50
NA
2
NA
5000*
200
NA
NA
NA
NA
NA
NA
NA
-------
Chemical
Parameter
Table 4
Chemicals of Potential Concern
Carter-Lee Lumber Company Site
Total Positive
Positive Total Detection Positive
Detections Analyses Frequency Detections
Range of
SOIL (ug/kg)
Heptachlor
Arochlor
GROUNDWATER (ug/1)
alpha BHC
4,4-DDT
27
27
17
17
15%
11%
12%
12%
1.9 -
32 -
0.001 -
0.004 -
4.2
35
0.003
0.012
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Table 5
Summary of Risk Calculations
Carter-Lee Lumber Company Site
SOIL
EXCESS LIFETIME NON-CARCINOGENIC
CANCER RISK HAZARD QUOTIENT
Ingestion of Soil Dermal Ingestion of Soil Dermal
LANDUSE/RECEPTOR and Inhalation of Absorption of Cumulative and Inhalation of Absorption
Cumulative
Particulate Contaminants Cancer Risk Particulate
Contaminants Cancer Risk
Future Residential Child 2E - 07 8E - 07 IE - 06 4E - 05 5E - 05 9E - 05
Future Occupational
Adult 3E - 08 2E - 07 2E - 07 IE - 06 2E - 05 2E - 05
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Table 6
Summary of Risk Calculation
Carter-Lee Lumber Company Site
GROUNDWATER
EXCESS LIFETIME
CANCER RISK
LANDUSE/RECEPTOR
Absorption of Cumulative
Groundwater
Contaminants Hazard Index
Ingestion of
Contaminants Cancer Risk
Dermal
Absorption of Cumulative Ingestion of
NON-CARCINOGENIC
HAZARD QUOTIENT
Dermal
Future Residential Child
3E -07
5E - 11
3E - 07
Groundwater
7E - 04
6E - 07
7E - 04
Future Occupational
Adult
![]()
![]()
![]()
8E -
3E - 11
8E -
2E - 04
4E - 07
2E - 04
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RESPONSIVENESS SUMMARY
CARTER LEE LUMBER COMPANY
INDIANAPOLIS, INDIANAPOLIS
PURPOSE
This responsiveness summary has been prepared to meet the requirements of Section
113(k) (2) (b) and 117 (b) of the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), which requires the United States Environment Protection Aqency (U.S. EPA) to respond to
each of the siqnificant comments, criticisms, and new data submitted in written or oral
presentations, on a proposed plan for remedial action. The responsiveness summary provides a
summary of citizens's comments and concerns identified and received durinq the public comment
period, and U.S. EPA's responses to those comments and concerns. All comments received by U.S.
EPA durinq the public comment period will be considered in the selection of the remedial
alternative for the Site. The responsiveness summary serves two purposes: It provides U.S.
EPA with information about community preferences and concerns reqardinq the remedial
alternatives, and it shows members of the community how their comments were incorporated into
the decision-makinq process.
This document summarizes written and oral comments received durinq the public comment
period of Auqust 1 to Auqust 30, 1994. The comments have been paraphrased to efficiently
summarize them in this document. The public meetinq was held at 7:00 p.m. on Auqust 10, 1995 at
the Hawthorne Community Center, Indianapolis, Indiana. Written comments were submitted durinq
the public meetinq by one resident. Five comments were mailed to U.S. EPA.
OVERVIEW
The proposed remedial action for the Carter Lee Lumber Superfund Site was announced to
the public just prior to the beqinninq of the public comment period. U.S. EPA proposed "No
Action."
Community Comments
1. Comment: The commenter states that the term "no action clean up" is a
contradiction in terms. The commenter expressed concern for qroundwater and surface water
contamination and its impact on the residents of Indianapolis and those livinq and workinq near
the Site. The commenter also expressed concern about the effects past exposure to the
contaminants in the soil has had on area workers and residents and the impact of leavinq
contaminated soils at the site as well as contaminants identified in backqround soils.
Response: The commenter's observation reqardinq "no action clean up" is probably
valid. The term, which appears in the newspaper announcement of the date for the public
meetinq, is not easily understood althouqh it is used as a measure of accomplishment by U.S.
EPA. The proposed plan fact sheet that was mailed to individuals on the mailinq list, however,
is more detailed, makes for easier readinq and explains how the U.S. EPA uses the term. It
recommends that no action be used to address the contaminants at this site.
The U.S. EPA shares the commenter's concerns reqardinq the impact this Site has on
qroundwater. Concern for qroundwater was one of the reasons the site was put on the National
Priorities List in 1989. As a result of site listinq, the investiqation at this site included
samplinq and analysis of qroundwater, a qroundwater user survey and a study of the site qeoloqy.
The soils underlyinq the site are just one factor considered in arrivinq at the remedy at the
site. The fate and transport analysis concluded that contaminants would have to be present in
the soil in much hiqher concentrations before qroundwater use would be compromised. Based on
-------
the results of that investigation, it has been concluded that the contaminants at this site do
not pose an unacceptable risk to groundwater users. We believe this concern has been addressed
thoroughly.
The commenter asserts that the west side of Indianapolis has many sites that are or
could be addressed by Superfund and that several areas have contaminants similar to those found
at the Carter Lee Lumber Company. U.S. EPA's remedial investigation confirmed that there are
nearby areas which are either currently being studied, have studies which have been completed by
various local, state and/or federal agencies or will be the subject of future studies. U.S. EPA
concluded, after collecting soil samples and analyzing the resulting data, that in some
instances, the contaminants at the site do not differ significantly from those found in the area
surrounding the site. In fact, off-site concentrations, primarily because of the industrial
nature of the area, are often higher than those detected on-site. According to the Agency for
Toxic Substances and Disease Registry (ATSDR)report, The Toxicological Profile for Polycyclic
Aromatic Hydrocarbons, the constituents of the soils in and around the Site are generally
consistent with other urban areas. Our investigation determined that these constituents did not
originate at Site. And, further, it was determined that the contaminants unigue to the site
could be dealt with in an effective and timely manner now. Our investigation concluded that
there is no significant incremental risk caused by the Site.
ATSDR, along with the Indiana Public Health Department, has been tasked with the
responsibility of evaluating health conditions. They have already solicited health concerns from
the public. The 1990 Preliminary Health Assessment outlines the efforts made at that time.
They are currently updating their evaluation based on the remedial investigation data available.
The public will be provided an opportunity to review their findings in the near future.
2. Comment: The commenter guestioned whether any of the men who worked at Carter Lee
Lumber Company complained about illnesses, the commenter guestioned whether U.S. EPA activity
would bring down residential property values and, finally, the commenter asked if anyone other
than the Carter Lee Lumber Company had been guestioned regarding the contaminants at the site.
Response: In response to the commenter's guestion regarding the health of Carter Lee
Lumber Company employees, a record review was implemented. According to site files, the
investigation of this site resulted from a report by a Carter Lee Lumber Company employee of
spotting small animals with sores and patchy fur and complaints by employees of skin lesions and
weight loss. These reports were investigated by the Indiana Department of Health and Human
Services and these claims could not be substantiated. The site investigation was continued,
however, to determined if soil contamination could pose a health hazard. The remedial
investigation examined the probability of health hazards resulting from site related
contaminants and concluded these contaminants do not pose an unacceptable risk.
The commenter's concerns regarding the effects that hazardous waste in the
neighborhood will have on real estate property values are understandable. In areas where
uncontrolled hazardous substances have been identified, there are instances where property
values have been lowered and it has been difficult to get home mortgages or home improvement
loans. Fortunately, that is not the case for the Carter Lee Lumber Company property we just
completed investigating. Through study, we have developed sufficient information to conclude
that this property does not pose a threat to human health and the environment. This finding
should eliminate problems that may have resulted from having a Superfund site in the area.
The last comment guestioned U.S. EPA contact with past property owners. CERCLA, the
law being implemented in the Superfund process, provides that public dollars used to investigate
and clean-up hazardous waste sites be recovered from liable parties. These generally include all
past owners, past operators and hazardous waste generators that can be connected to the site
-------
contaminants. The research to identify parties responsible for conditions at the site was
completed in June 1988. Potentially responsible owners, operators and generators were
identified. Based on this information, five (5) companies identified as potentially responsible
parties were provided notice of the U.S. EPA's intent to investigate the site by letter in
January 1992. The U.S. EPA has attempted to work with the current owner and tried not to disrupt
commercial activities during the investigation. We have also kept them informed of our actions.
We have been pleased with the cooperative working relationship that has been established with
the Carter Lee Lumber Company and believe it has obtained in beneficial results.
3. Comment: The commenter states the belief that the employees within a one-mile
radius of the Site are at risk and should have blood work to determine any and all health
problems. The commenter also asks if Carter Lee Lumber Company employees have been given blood
tests to detect carcinogens and the commenter reguest the results of such testing and finally,
the commenter ask if the arsenic, cyanide and beryllium detected in the groundwater can be found
in the blood stream of individuals in the area and if exposure would cause health problems for
individuals in the immediate area.
Response: In response to the concern regarding employees within a one-mile radius of
the Site, the remedial investigation concluded that the contaminants at the site do not pose an
acceptable risk to area workers or residents. This conclusion is based on findings determined
during the investigation which included sampling and analysis of groundwater and subsurface and
surface soil both on and off-site, a groundwater user survey and an ecological investigation.
Our investigation did not include blood tests for Carter Lee Lumber Company employees since
blood testing was not warranted. The Indiana Public Health Department looked into allegations
of weight loss and skin lesions reportedly occurring among Carter Lee Lumber employees and could
not substantiate these claims. No health problems have been reported in the area as a result of
contact with the contaminants at the site.
In response to the commenter's guestions regarding the groundwater, both cyanide and
beryllium levels can be measured in the blood. Arsenic, however, is better measured in urine
samples. The presence of these compounds in the blood or urine does not necessarily mean that
health hazards exist. It is believed by many, for instance, that trace amounts of arsenic may
be essential to good health. Our investigation revealed that no one is currently drinking water
contaminated with site related chemicals. Because the contamination found does not pose
unacceptable risks, testing individuals is not warranted. In evaluating the risk associated
with groundwater, we determined that contaminants at the site would have to be much higher
before groundwater guality is degraded and human consumption affected.
4. Comment: The commenter asks the U.S. EPA to remove the contaminated soils from the
site rather than the leave the soils as proposed. The reasons for the reguest include;
1. The remedial investigation failed to examine the impact the
site has on the health and stability of the neighborhood.
2. A community impact study should have been completed before a
plan is proposed.
3. The recommended action outlined in the proposed plan does
not prohibit contaminated soil from being disturbed by
Carter Lee Lumber.
4. Facts about the soils underlying the site were presented at
the proposed plan meeting that was not presented in the
proposed plan fact sheet.
-------
5. The U.S. EPA is not learning from past experiences. The
Avanti site clean-up did not prevent community and workers'
exposure to lead-contaminated soil. A similar problem can
be avoided if the soils are removed.
Response: The U.S. EPA shares the commenter's concern regarding the impact this site
has on the community. In accordance with our guidelines, we implemented a community relations
plan that is designed to keep the community informed of the activities at the Site and help the
U.S. EPA anticipate and respond to community concerns. Past activities included interviews with
interested people in the community, public meetings, establishing a information repository at
the community center and releasing news letters, final reports and other work products. In
addition, the Agency for Toxic Substances and Disease Registry (ATSDR), in conjunction with the
Indiana Health Department, has published a preliminary health assessment and is completing work
on a final health assessment based on the data collected during our investigation. We are not
familiar with the details of the "community impact study" that the commenter referenced, but
believe adeguate efforts have been made to promote community involvement, we have been
responsive to community needs and we have evaluated the impact the Site has had on the
community.
Our investigation concludes that no unacceptable incremental level of risk will result
from the leaving the soils at the Site. The baseline risk assessment provided an evaluation of
the potential threat to human health and the environment if no remedial action takes place.
This risk assessment was conducted consistent with U.S. EPA guidance. On the basis of these
assessments, no action was proposed.
The commenter's concern that new information was presented at the proposed plan
meeting is understandable. Be assured, however, that no new facts were introduced at the
meeting. Site geology is discussed at great length in the remedial investigation report. The
presentation at the meeting went over the content of the remedial investigation report. A copy
of the report was placed in the information repository on June 1, 1995. The proposed plan fact
sheet summarized the data collected during the investigation since it is not in the nature of a
fact sheet to include details.
The commenter's desire that we use the lessons learned is consistent with current U.S.
EPA policy. It should be noted, however, the situations at the Avanti removal site and the
Carter Lee Lumber Superfund Site are not at all similar. Because of the differences, it is not
appropriate to deal with the sites in the same manner. The facts have been assembled regarding
the Carter Lee Lumber Superfund Site in the remedial investigation and based on those facts, it
has been determined the no action alternative is protective of human health and the environment
and, therefore, has been proposed.
Potentially Responsible Party Comments
5. Comment: The commenter clarified information in the remedial investigation report
about the small batch wood treatment unit operated by the Carter Lee Lumber Company, which,
according to the commenter, can be misinterpreted to mean that pentachlorophenol was part of the
material spread on the southern portion of the site. The commenter concludes that since
pentachlorophenol was not detected in any samples except at very low concentrations,
pentachlorophenol did not contribute to the site contamination. The commenter discussed the
contents of the trench. The proposed plan and remedial investigation states that the excavated
soil was placed in the trench. The commenter states that red soils did not go into the trench
and referenced affidavits supplied to the U.S. EPA to support that position. Finally, the
commenter informed the U.S. EPA that most of the Site will be covered in asphalt in the spring
-------
of 1996.
Response: U.S. EPA acknowledges the clarifications. There was never an intent to
imply that pentachlorophenol was spread over the site. If that can be inferred from the text,
we'd like to thank you for the opportunity to clarify. During the site investigation, the
historical use of pentachlorophenol was examined. It was determined that it was not a
contaminant of concern because it did not meet the criteria used to evaluate contamination at
Superfund sites.
Relative to the comments on the placement of the red soil, notwithstanding the
affidavits received, soil sampling during the investigation found some of the highest
concentration in soils in the trench area.
The proposed plan recommends no action at this site. And further, the hazardous
substances remaining at the Site will allow unlimited Site use and unrestricted exposure to Site
soils and groundwater. Given the conclusions drawn based on the examination of site facts,
plans for site development can proceed.
-------
DOC# DATE
1 08/13/84
2 07/23/85
3 03/06/86
4 09/06/90
5 06/00/92
6 08/04/92
7 02/03/93
8 02/07/94
9 04/13/94
10 05/00/95
11 07/13/95
AUTHOR
Dalton, M. and
Kolze, L., ISBH
U.S. EPA
CH2M-H111
RECIPIENT
U.S. EPA
File
U.S. EPA
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
CARTER-LEE LUMBER SITE
INDIANAPOLIS, INDIANA
ORIGINAL
07/26/95
TITLE/DESCRIPTION
USDHHS/USPHS/ATSDR; U.S. EPA
ISBH
CH2M-H111
U.S. EPA
CH2M-H111
Peterson, L.,
CH2M-H111
Peterson, L.,
CH2M-H111
Orr,D.,U.S. EPA
CH2M-H111
Cragan, J., CHH2M
Hill
U.S. EPA
Orr, D.,U.S. EPA
Orr, D.,U.S. EPA
Schaible, R.,IDEM,
et al
U.S. EPA
Orr,D.,U.S. EPA
Preliminary Assessment
Chain of Custody Records and Sampling Data
for Case #4730
Site Inspection Report
Preliminary Health Assessment
Quality Assurance Project Plan (Including
Field Sampling Plan and Health and Safety
Plan) w/Attached U.S. EPA Memorandums re: (1)
June 28, 1992 Approval of the QAPP and (2)
June 28, 1993 Addendum to Appendix A
Work Plan for the RI/FS
Letter Forwarding Attached Revisions to the
January 25, 1993 Technical Memorandum
Letter Forwarding Attached September 1993
Soil and Groundwater Analytical Data
Letter Transmitting September 1993 Soil and
Groundwater Analytical Data
Remedial Investigation Report (Includes Chain
of Custody Forms)
Technical Memorandum re: Fate and Transport
Analysis
45
PAGES
5
73
7
318
57
71
229
286
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DOC# DATE
1 00/00/80
2 00/00/83
3 09/24/86
4 09/24/86
5 09/24/86
6 12/00/89
7 03/00/91
8 04/00/91
GUIDANCE ADDENDUM
CARTER-LEE LUMBER SITE
DOCUMENTS MAY BE VIEWED AT
U.S. EPA REGION 5
77 W. JACKSON BLVD., CHICAGO, IL 60604-3590
07/26/95
AUTHOR
RECIPIENT
Indiana Department
of Natural Resources
Smith, B.
U.S. EPA U.S. EPA
U.S. EPA U.S. EPA
U.S. EPA U.S. EPA
U.S. EPA U.S. EPA
U S. EPA/OSWER U.S. EPA
U.S. EPA/OSWER U.S. EPA
TITLE/DESCRIPTION
Report: Geology for Environmental Planning
in Marion County, Indiana" (Geological Survey
Special Report 19)
Report: "Availability of Water From the
Outwash Aguifer, Marion County, Indiana"
(Geological Survey Water Resources
Investigation Report 83-4144)
Guidelines for Carcinogenic Risk Assessment
(Federal Register 51: 32992-34013
Guidelines for Estimating Exposure (Federal
Register 51: 34042-34045)
Guidelines for Health Risk Assessment of
Chemical Mixtures (Federal Register 51: 34014-
34041)
Risk Assessment Guidance for Superfund: Human
Health Evaluation Manual (Part A) [Interia
Final] (EPA/540/1-89/002
Standard Default Exposure Factors [Interia
Guidance] (OSWER Directive 9285.6-03)
Role of the Baseline Risk Assessment in
Superfund Remedy Selection Decisions (OSWER
Directive 9355.0-03)
PAGES
0
-------
9 12/00/91 U.S. EPA/OERR
10 12/00/91 U.S. EPA
11 00/00/92 U.S. EPA/ORD
U.S. EPA
U.S. EPA
U.S. EPA
Health Effects Summary Tables [Annual FY
1991] (OERR 9200.6-303 [90-31])
Risk Assessment Guidance for Superfund: Human
Health Evaluation Manual (Part B)[Interia
Final] (Publication 9285.7-01B)
Integrated Risk Information System:
Background Information (U.S. EPA Integrated
Risk Information System Database)
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