g  U.S. ENVIRONMENTAL PROTECTION AGENCY
      "  OFFICE OF INSPECTOR GENERAL
                          Catalyst for Improving the Environment
Evaluation Report
       Results of Independent
       Groundwater Sampling at
       Meal's Dump Superfund Site

       Report No. 09-P-0110
       March 4, 2009

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Report Contributors:                         Carolyn Copper
                                             Patrick Milligan
                                             Martha Chang
                                             Kathryn Hess
                                             Jayne Lilienfeld-Jones
                                             Denise Rice
Abbreviations

EPA         U.S. Environmental Protection Agency
NPL         National Priorities List
OIG         Office of Inspector General
PCBs        Polychlorinated biphenyls
Site          Neal's Dump Superfund Site
Cover photo:    Grass cover over the remediated Neal's Dump Superfund Site, Spencer,
                Indiana, May 2008 (photo by EPA OIG).

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                 U.S. Environmental Protection Agency
                 Office of Inspector General

                 At   a   Glance
                                                       09-P-0110
                                                    March 4, 2009
                                                           Catalyst for Improving the Environment
Why We Did This Review

The Office of Inspector
General (OIG) is testing long-
term monitoring results at
Superfund sites the U.S.
Environmental Protection
Agency (EPA) has deleted
from the National Priorities
List(NPL).  Neal'sDump
Superfund Site, located near
Spencer, Indiana, is one of
eight sites being reviewed.

Background

Neal's Dump was
contaminated with
polychlorinated biphenyls
(PCBs) from disposal of
electrical equipment and other
PCB-contaminated materials.
EPA deleted Neal's Dump
from the NPL in 1999, which
signified clean-up goals had
been achieved.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202)566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2009/
20090304-09-P-0110.pdf
Results of Independent Groundwater Sampling
at Neal's Dump Superfund Site
 What We Found
The OIG obtained groundwater samples from two private drinking water wells on
residential properties adjacent to the Neal's Dump Superfund Site on May 28,
2008. Groundwater samples from these residential wells have been part of EPA's
long-term monitoring conducted at Neal's Dump. Our results showed that PCBs
in the two residential wells did not exceed safe levels for drinking water. These
results are consistent with EPA's monitoring results.


EPA Region 5 reviewed a draft of this report and had no comment.

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 \
                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                  WASHINGTON, D.C. 20460
                                                                           OFFICE OF
                                                                        INSPECTOR GENERAL
                                     March 4, 2009
MEMORANDUM
SUBJECT:
FROM:
TO:
Results of Independent Groundwater Sampling
at Neal's Dump Superfund Site
Report No. 09-P-0110
Wade T. Najjum  tt/':,llf / J-,^
Assistant Inspector General      -j'j
Office of Program Evaluation
Bharat Mathur
Acting Region 5 Administrator
This is our final report on the subject evaluation conducted by the Office of Inspector General
(OIG) of the U.S. Environmental Protection Agency (EPA). This report contains sampling
results from residential wells adjacent to the Neal's Dump Superfund Site.  The OIG obtained its
samples in May 2008.

The estimated cost of this report - calculated by multiplying the project's OIG staff days by the
applicable daily full cost billing rates in effect at the time, then adding in the contractor costs -
is $99,200.

Action Required

Because this report contains no recommendations, you are not required to respond to this report.
We have no objections to the further release of this report to the public. This report will be
available at http://www.epa.gov/oig.

If you or your staff have any questions, please contact Carolyn Copper, Director for Program
Evaluation, Hazardous Waste Issues, at 202-566-0829 or copper.carolyn@epa.gov: or Pat
Milligan, Project Manager, at 215-814-2326 or milligan.patrick@epa.gov.

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                                                                             09-P-0110
Purpose

The Office of Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA) is
evaluating long-term monitoring at Superfund sites deleted from the National Priorities List
(NPL). The overall objective is to evaluate whether EPA has valid and reliable data on the
conditions of these sites.  Neal's Dump Superfund Site near Spencer, Indiana, is one of eight
sites being reviewed.

Background

Neal's Dump (the Site) received residential and industrial wastes between 1967 and 1972,
including materials contaminated with polychlorinated biphenyls (PCBs). The half-acre Site is
located in Owen County, approximately 15 miles northwest of Bloomington, Indiana.  Two
residential properties are adjacent to the southern boundary of the Site.

Construction of final remedy was completed in March 1999, and included removing all
contaminated materials. EPA deleted Neal's Dump from the NPL in October 1999, which
signified clean-up goals were achieved through remedial action. Groundwater monitoring was
conducted to evaluate the effectiveness of the Site clean-up. Following the first Five-Year
Review in 2003, the four monitoring wells were  closed.  However, private residential wells
continued to be sampled up to 2008.  The 2008 Five-Year Review concluded that sampling in the
residential wells also should be eliminated. EPA concluded in the 2003 and 2008 Five-Year
Reviews that the remedy was protective of human health and the environment.

Noteworthy Achievements

EPA ensured that over 7,000 tons of PCB-contaminated material were excavated at the Site and
disposed of in a commercial landfill permitted to accept this material. The excavation was filled
with clean soil and reseeded with a grassy  cover. A deed restriction was implemented that
prohibited use of groundwater underlying the site. Post construction activities included
monitoring groundwater quality for 5 years in four monitoring and two residential wells.

Scope and  Methodology

We conducted our work from May 2008 to February 2009 in accordance with generally accepted
government auditing standards.  Those standards require that we plan and perform the evaluation
to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our evaluation objectives.  We reviewed key historic documents, including
past sampling results and decision documents such as the Record of Decision Amendment and
Five-Year Reviews. We also interviewed the remedial project managers from EPA Region 5 and
the Indiana Department of Environmental Management. We collected groundwater samples and
conducted a limited site inspection.

We believe that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our evaluation objectives.  This report only transmits the results of the

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                                                                            09-P-0110
sampling we conducted. We plan to issue a summary report that, as appropriate, will include
additional findings from all or some of the eight sites we are evaluating.

Sampling Method

We acquired a qualified environmental contractor from the list of General Services
Administration contractors to take groundwater samples and conduct a site inspection. On
May 28, 2008, our contractor collected samples from two residential wells for laboratory
analysis.  The samples were analyzed in the laboratory for seven different manufactured blends
of PCBs, also known as Aroclors. Due to the scope of the OIG evaluation, our contractor tested
only for PCBs and did not analyze for other contaminants typically monitored in drinking water.
OIG staff members were present to ensure that proper sampling and site inspection quality
assurance protocols were followed.  Historically, EPA sampled four on-site groundwater
monitoring wells, along with the residential wells.  EPA closed these monitoring wells in 2004,
and as a result, the wells were not available for us to sample.

For both sampling locations [Resident Well A (RW-A) and Resident Well B (RW-B)], the
groundwater was collected from exterior taps. See Figure 1 for well locations.
                                      f "'Closed
                                       3> Wei
 Figure 1.  Location of two residential wells (RW-A and RW-B) sampled at the
 remjediated Neal's Dump Superfund Site by the OIG on  May 28, 2008. Map from
 EPA? with labels added by the OIG.

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                                                                               09-P-0110


The tap for RW-B was located at the well head. The tap for RW-A was located about 150 feet
east of the well head. Prior to taking the samples, the wells were purged at a rate of 6 gallons per
minute for approximately 15 minutes using the submersible pumps installed in the wells. The
temperature, conductivity, pH, oxidation-reduction potential, dissolved oxygen concentration,
and turbidity were monitored to ensure that all standing water in the wells had been purged prior
to sampling. Samples were collected from each well using proper sampling and quality
assurance protocols.  Each sample was analyzed at a qualified laboratory using EPA method
8082. In addition, sets of samples were given to the contractor for the responsible party and to
EPA Region 5 for their own analyses.

We compared our results to the national primary drinking water standard for PCBs of 0.5
micrograms per liter. We also compared our results to the most recent historical data for the site,
collected in 2003, to test the reliability of the historical data.

A limited site inspection was conducted by OIG staff and the contractor.

Results

We observed that the site was generally well maintained. The grass cover appeared healthy and
no signs of erosion or settling of the soil used to fill the excavation were observed.  Our sample
results showed that PCBs in the two residential wells did not exceed safe levels for drinking
water.  The samples were not analyzed for other substances, and therefore are not an overall
assessment of the safety  of the water in these residential wells. Our results are consistent with
the results reported in Region 5's 2003 and 2008 Five-Year Reviews for the Site. Further,
Region 5 reports that no  analyses of water collected in the residential wells since 1991 have
detected PCBs above the drinking water standard.

EPA Region 5 reviewed  a draft of this report and had no comment.

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                                                                           09-P-0110
                Status of Recommendations and
                    Potential Monetary Benefits
                                                                     POTENTIAL MONETARY
                          RECOMMENDATIONS                                BENEFITS (in $OOOs)
                                                           Planned
Rec.   Page                                                  Completion     Claimed   Agreed To
No.   No.             Subject            Status1    Action Official       Date      Amount   Amount
                 No recommendations
 0 = recommendation is open with agreed-to corrective actions pending
 C = recommendation is closed with all agreed-to actions completed
 U = recommendation is undecided with resolution efforts in progress

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                                                                            09-P-0110
                                                                        Appendix A

                                 Distribution
Office of the Administrator
Acting Regional Administrator, Region 5
Acting Deputy Regional Administrator, Region 5
Director, Superfund Division, Region 5
Director, Office of Site Remediation and Innovation Technology, Office of Solid Waste
      and Emergency Response
Agency Follow-up Official (the CFO)
Agency Follow-up Coordinator
Acting General Counsel
Acting Associate Administrator for Congressional and Intergovernmental Relations
Acting Associate Administrator for Public Affairs
Chief, Construction and Post-Construction Branch, Office of Solid Waste
      and Emergency Response
Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response
Audit Follow-up Coordinator, Region 5
Deputy Inspector General

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