PB97-964105
EPA/541/R-97/078
January 1998
EPA Superfund
Record of Decision:
Tippecanoe Sanitary Landfill, Inc.
Lafayette, IN
9/30/1997
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Declaration for the Record of Decision
Site Name and Location
Tippecanoe Sanitary Landfill, Inc. Site
Tippecanoe County, Indiana
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Tippecanoe Sanitary Landfill, Inc. Site in Tippecanoe County,
Indiana, which was chosen in accordance with the Comprehensive En-
vironmental Response, Compensation, and Liability Act of 1980, as
amended (CERCLA), and, to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based on the administrative record file for this
site .
Assessment of the Site
Actual or threatened releases.of hazardous substances from this
site, if not addressed by implementing, the response action se-
lected in this Record of Decision (ROD), may present an imminent
and substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
This remedy addresses all of the conditions prompting remedial
response actions that have been identified at the Site. It ad-
dresses the wastes that are contained at this former municipal
landfill through a barrier cover and leachate and gas collection.
It provides contingent groundwater remediation; this remediation
will be implemented if the source control measures being taken
along with natural attenuation do not appear to be controlling
the groundwater contamination within the stated time frames or if
future downgradient water supplies are threatened.
The major components of the selected remedy include:
- a sanitary landfill cover for the waste disposal area;
- a fence that surrounds, at a minimum, the waste disposal area
and the barrier cover;
- leachate extraction and treatment, either by transfer to the
local publicly owned treatment works (POTW) for treatment
(if the POTW can accept the leachate) or on-site treatment
and discharge to Wildcat Creek or the Wabash River, with
this discharge meeting National Pollutant Discharge Elimina-
tion System (NPDES) permit requirements and with proper dis-
posal of the treatment residues;
- gas extraction system;
- a contingent groundwater remediation component that will be
implemented if either source control and natural attenuation
are determined to not be reducing the downgradient ground-
Tippecanoe SL Site, Declaration for ihe ROD
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water contamination to acceptable levels within the speci-
fied time frame or if human health is being threatened by
water being extracted from downgradient water supply wells;
- on-site groundwater treatment, if groundwater remediation is
implemented, to produce an effluent meeting the NPDES permit
requirements that will be discharged to surface water with
the treatment residues being properly disposed of off-site;
- deed restrictions, including provisions for the protection of
the remedial actions taken and the prohibition of wells on
the Site to be used for a water supply; and
- site monitoring and maintenance of all remedial action com-
ponents .
Statutory Determinations
The selected remedy is protective of human health and the en-
vironment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. The remedy utilizes permanent
solutions and alternative treatment or resource recovery tech-
nologies, to the maximum extent practicable, for this Site. The
large size of the landfill and the apparent lack of on-site hot
spots representing major sources of contamination renders treat-
ment of the waste disposal area impracticable and non-cost effec-
tive. Thus the statutory preference for a remedy requiring per-
manent treatment as a principal element cannot be followed. A
principal threat, which the U.S. Environmental Protection Agency
(USEPA) would expect to treat, has not been indicated. Instead,
as provided for at 40 CFR 300.430(a) (1) (iii) (B) , USEPA expects to
use engineering controls, such as containment, for source control
at a municipal landfill because the wastes pose a relatively low-
level, long-term threat and because permanent treatment of the
entire landfill is impracticable. The selected response action
is consistent with the USEPA'S' guidance for remedial response
actions at municipal landfills, as described in "Presumptive
Remedy for CERCLA Municipal Landfill Sites", OSWER Directive No.
9355.0-49FS.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
every five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
State Concurrence
The State of Indiana has stated that it concurs in the selected
remedy.
Date
Will
Superfund Division Director
Tippecanoe SL Site, Declaration for the ROD
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Record of Decision Summary
Tippecanoe Sanitary Landfill, Inc. Site
I. Site Description
The Tippecanoe Sanitary Landfill, Inc. (TSL) site (Site) is lo-
cated at 2801 North Ninth Street Road, just outside Lafayette,
Indiana. The approximately 79-acre site lies within the common
floodplain of the Wabash River, which lies some distance north
and west of the landfill, and Wildcat Creek, which flows toward
the north approximately 600 feet northeast of the landfill. Fig-
ure 1 shows the Site and some of the adjacent property.
Except for the valley wall along the western boundary of the land-
fill, the ground surface beneath the landfill was formerly rela-
tively flat farmland. The original ground surface was approxi-
mately at elevation 524 feet (North American Vertical Datum
(NAVD) of 1927) and rose to an approximate elevation of 550 feet
(NAVD) along the valley wall. The Site is bordered by railroad
tracks to the west, with Nort-h Ninth Street Road further west and
some residences and businesses on the west side of this road,
several residences to the north and northwest, farmland to the
north and northeast and east, a wooded area to the east and south-
east, and a borrow area to the south where quarrying operations
are on-going. A private residence lies on the northwest corner
of the property used for the landfill, but the area near this
residence was not to be used for waste disposal operations. The
buildings used in the landfill operation in the latter years of
its operation lie on part of the waste disposal area.
II. Site History and Enforcement Activities
In 1971, Tippecanoe County, Indiana, Purdue University, the City
of West Lafayette, Indiana, and the City of Lafayette, Indiana
decided that there should be one landfill in the county that
local residents, commercial entities, and industry could use for
the disposal of non-hazardous wastes. As a result, the first
three parties moved ahead to establish such a landfill; the City
of Lafayette, Indiana, joined them later. TSL was privately
formed to operate a landfill and reached an agreement with the
Tippecanoe County Board of Commissioners in June 1971 for the
operation of a landfill. TSL first leased the property at the
Site for the landfill in June 1971; about 10 acres in the north-
west corner, which were not clearly defined, were excluded from
the lease. An operating permit was issued on April 12, 1971 and
landfilling operations began in June 1971. Gerald Schlossberg
purchased TSL in about 1975, and on February 17, 1976 the State
Board of Health issued another operating permit for the landfill.
The municipal landfill was operated at the Site until it was
closed in October 1989 pursuant to a Consent Decree from an In-
diana state court. During the years that the landfill was oper-
ated, there were several periods when the landfill did not have
ROD Summary, Tippecanoe Sanitary Landfill Site
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an operating permit from the state. During these periods, the
landfill generally continued to operate while the landfill
operator appealed the state's permit decisions in Indiana state
courts. Some of the claims against the landfill operator were
that there was only sporadic daily cover, unsatisfactory daily
cover, possible acceptance of hazardous waste, poor geologic con-
ditions, and failures to operate in accordance with the require-
ments of the permit.
Primarily, the wastes disposed of at the Site were the solid
wastes generated by local residents, businesses, and industries.
An industrial sludge went to the Site for a number of years in
the 1970s, and this practice was discontinued when a sludge sam-
ple was found to contain elevated levels of polychlorinated bi-
phenyls (PCBs). During the last year or more of operation, some
out-of-state wastes were disposed of at the Site. The landfill
closed before the anticipated final elevations were reached. An
acceptable final cover was never installed over all of the land-
fill after the landfill stopped accepting wastes.
On March 8, 1990, the U.S. Environmental Protection Agency
(USEPA), the Indiana Department of Environmental Management
(IDEM), and ten of the parties who had been named potentially
responsible parties (PRPs) for the Site agreed to an Adminis-
trative Order on Consent that requires these PRPs to conduct a
remedial investigation (RI) and feasibility study (FS) for the
Site. More parties were named PRPs in 1992, and nine additional
PRPs joined the original group. The Site was finalized on the
National Priorities List (NPL) on August 30, 1990.
III. Highlights of Community Participation
The Proposed Plan and the documents designated as being the
remedial investigation report and the feasibility report were
released to the public in July 1997. These documents were made
available to the public in both the administrative record and an
information repository maintained at the Tippecanoe County Public
Library, Lafayette, Indiana; a copy of the administrative record
is also maintained in the Records Center in the offices of Region
5 in Chicago. The notice of availability of these documents was
published in the Lafayette-West Lafayette Journal and Courier on
July 24, 1997. A public comment period was held from July 28,
1997 through August 28, 1997. A public meeting was held on Au-
gust 6, 1997. At this meeting, representatives from USEPA and
IDEM answered questions about the Site's conditions and the re-
medial alternatives under consideration. A response to the com-
ments received during the comment period is included in the Re-
sponsive Summary, which is a part of this Record of Decision.
This decision document presents the selected remedial action for
the Tippecanoe Sanitary Landfill, Inc. site in Tippecanoe County,
Indiana, chosen in accordance with the Comprehensive Environment-
al Response, Compensation, and Liability Act of 1980, as amended
(CERCLA), and, to the extent practicable, the National Contingen-
ROD Summary, Tippecanoe Sanitary Landfill Site
-------
cy Plan (NCP). The decision for the Site is based on the admin-
istrative record.
IV. Scope of the Response Action
The selected remedial action presented in this decision document
for this landfill will address all the releases and threatened
releases of hazardous substances that have been ascertained so
far for the site and which warrant remedial response action. The
landfill wastes are considered low level threat wastes, that is
wastes that generally can be reliably contained and that would
present only a low risk in the event of releases or continued
releases.
V. Site Characteristics
A presumptive remedy approach has been taken for the remedial in-
vestigation and feasibility study for this Site, using the Super-
fund program's past experience to streamline the site investiga-
tion and reduce the technology evaluation phase (Presumptive
Remedy for CERCLA Municipal Landfill Sites, USEPA, Directive No.
9355.0-49FS, September 1993). Presumptive remedies are preferred
technologies for common categories of sites, based on historical
patterns of remedy selection and USEPA's evaluation of perform-
ance data on technology implementation. Using the presumptive
remedy approach does not mean that the remedy has been selected.
It is still necessary to obtain some basic data about the site,
propose a remedy (or propose no action) for public comment, con-
sider any comments received, and issue a Record of Decision (ROD)
stating what has been decided concerning remediation. The com-
ponents of the source containment presumptive remedy for munici-
pal landfill sites are: landfill cap; source area groundwater
control to contain the plume; leachate collection and treatment;
landfill gas collection and treatment; and/or institutional con-
trols to supplement engineering controls.
If the presumed remedy (containment), or parts of it, will not be
implemented at this Site, further investigations may be required,
as discussed in more detail below. The media sampled were: sedi-
ments in ditches and surface soils around the landfill, but not
generally on the waste disposal area; groundwater; surface water;
leachate;.and landfill gas. See Figure 2 for the locations of
the groundwater and leachate wells. Groundwater wells were
screened at three different elevations: A wells were at the water
table; B wells were at the approximate elevation of the top of
the middle confining layer; and C wells were at the approximate
elevation of the high-capacity pumps at the factory southwest of
the Site and some of the nearby residential wells.
The waste disposal area at the site covers approximately 59
acres. The estimated volume of material (wastes and soil) in the
waste disposal area, assuming that the bottom of the wastes is
approximately at the elevation of the surrounding farmland, is
ROD Summary, Tippecanoe Sanitary Landfill Site
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3.4 million cubic yards.
Surficial alluvium deposits existed in the area of the landfill
before landfill operations began that, if still present under the
wastes, would resist the movement of leachate from the wastes to
the upper aquifer. The water table at the Site is sometimes less
than 5 feet below the estimated bottom of the landfill. There
are two sand-and-gravel aquifers under at least part of the land-
fill, separated by a till layer that restricts possible ground-
water flow between the two aquifers. This till layer may disap-
pear, however, toward the west, resulting in one aquifer. Gener-
ally, the groundwater flow in the area of the landfill in the
upper aquifer is towards the west, with some radial flow in the
western part of the landfill. In the lower aquifer, the flow is
toward the southwest where there are some high-capacity extrac-
tion pumps. In the western part of the Site and further west,
the vertical flow direction is downwards.
Landfill gas has been escaping from the waste area through the
surrounding soils and moving toward some of the nearby resi-
dences. This could result in- safety and health problems. Meth-
ane monitoring alarms have been installed in two nearby homes and
an office and are currently being monitored quarterly by IDEM.
As discussed in the report for the remedial investigation, the
leachate from the TSL site sampled from the wells in late 1992
and early 1993 was generally similar in content to the leachate
from municipal landfills that had been summarized in an USEPA
report. In January 1993, the leachate level was 12 to 23 feet
above the base of the landfill. These levels indicate that there
is some resistance to the flow of leachate into the groundwacer
below. However, there have been some reports that at least some
of the surficial alluvium deposits were removed prior to the
placement of wastes. It is also possible that some surficial
alluvium deposits might have been removed by an abandoned meander
bend of Wildcat Creek that has been reported to have existed in
the area. Any removal, whether partial or total, of the surfici-
al alluvium deposits, without replacement by a material with a
similar resistance to water flow, would lead to the possibility
of easier movement of leachate into the groundwater
Chloride, sodium, and specific conductivity results for the three
rounds of groundwater sampling in 1992 (a preliminary round of
four wells and Rounds 1 and 2 that included all of the ground-
water wells except one (MW-15A) with an abnormal water level)
clearly demonstrated that the groundwaters at wells MW-14A, MW-
10A, MW-11B, and MW-16A in the northwest corner, at well MW-20B
toward the southwest, and at wells MW-4AR and MW-21B, all in the
upper aquifer, and at well MW-21C in the lower aquifer had been
contaminated (at some wells there was an order of magnitude in-
crease in the chloride concentrations over the background value).
The groundwaters at some other wells (for example, wells MW-3AR
and MW-17A) had also been contaminated.
ROD Summary, Tippecanoe Sanitary Landfill Site
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There were also other contaminants found in the downgradient
groundwaters, including many inorganics in the field-filtered
samples (designated as being dissolved concentrations), especial-
ly arsenic and manganese, whose concentrations were significantly
above the background levels, and organic tentatively identified
compounds (TICs). There were only a few detections of target
compound list (TCL) volatile organic compounds (VOCs) and semi-
volatile organic compounds (SVOCs) in the groundwater. However,
the numbers of SVOC TICs in a few downgradient wells reached 20
(the maximum number the laboratory had to report), and the esti-
mated concentrations of a few of the substances exceeded 1000
Hg/1, based on unvalidated data. In the four northwest corner
wells, one groundwater sample had 8 SVOC TICs but the rest had 13
to 20 SVOC TICs, with the average number of SVOC TICs being about
15 per well.
No VOC TICs were reported in the wells in the lower aquifer (the
C wells). But there were 6 and 9 detects of SVOC TICs reported
in well MW-19C, which was considered an upgradient well, and in
the four downgradient wells the SVOC TICs reported ranged from 7
to 20, averaging nearly 15 pe-r well sample.
No PCBs were found in the groundwater of either aquifer and no
pesticides were detected in the lower aquifer groundwater.
Arsenic concentrations exceeded the maximum contaminant level
(MCL) of 50 fig/1 during the preliminary round of sampling in
a northwest corner well (MW-14A). Arsenic was detected in about
a third of the downgradient samples overall. Antimony concentra-
tions exceeded the MCL of 6 fJ.g/1 during Round 2 in groundwater at
two wells and during the preliminary round in the duplicate sam-
ple from one well, despite the fact that the detection limits
(about 53 /ig/1 in the preliminary sampling round and around 17
fig/1 in the other two rounds) were significantly above the MCL.
Secondary maximum contaminant levels (SMCLs)2' for aluminum,
iron, manganese, and total dissolved solids (TDS) were exceeded
in one or more wells in one or more rounds of sampling; in some
cases, an exceedance was found in a background well. Some de-
tects of manganese and iron in downgradient wells were at con-
centrations that were more than ten times the 95% upper confi-
1. The MCL is the maximum permissible level of a contaminant
in water which is delivered to any user of a public water system.
MCLs are established on the basis of unfiltered samples.
2. SMCLs are unenforceable federal guidelines regarding taste,
odor, color, and certain other non-aesthetic effects of drinking
water. They are discussed here partly to provide a fuller depic-
tion of the effect of the landfill on the groundwater. However,
329 IAC 10 for solid waste land disposal facilities in Indiana
does establish SMCLs as one component of the groundwater protec-
tion standards.
ROD Summary, Tippecanoe Sanitary Landfill Site
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dence lirr.it background concentrations.
Ten polycyclic aromatic hydrocarbons (PAHs) were detected at low
concentrations (1 to 4 fig/1) in the groundwater in one deep well
(MW-3C) in the southeast corner during Round 1 sampling, but not
during Round 2; the MCL for benzo(a)pyrene (the only one of the
ten PAHs with an established MCL) was exceeded. There was one
detect of 4,6-dinitro-2-methylphenol (DNOC) in one deep well
during one sampling round. In well MW-21C, background values
were exceeded for one or more sampling rounds for calcium, mag-
nesium, manganese, sodium, alkalinity, chloride, and total dis-
solved solids (TDS).
Selected results for the groundwater samplings of 1992 are pre-
sented in Table 1.
Surface water samples were taken from water that was present in
two ditches around the landfill and from the two ponds in the
southeast corner of the Site. Some metals were detected at ele-
vated (compared to background groundwater) levels in the two
ponds, and mercury was detected in the water from one pond and
both ditches. Dieldrin, the only pesticide detected, was found
only in the duplicate sample from one of the ponds.
In May 1997 the groundwater monitoring wells and three of the
four leachate wells were sampled to determine if there were any
significant changes in the groundwater contamination (the leach-
ate wells were sampled to get samples of both leachate and
groundwater at the same time). One of the leachate wells had
been damaged beyond repair; the results from the other three were
sufficient for „ha purposes for which the sampling was done. In
well MW-14A, dissolved arsenic was above the MCL of 50 fig/1 at
52.9 fig/1 and 52.8 fig/1 in the duplicate; the dissolved arsenic
concentration was above the MCL in the preliminary round in this
well, but it had been in the 40 to 50 fig/1 range during the sub-
sequent two rounds of samplings. In well MW-16A, the dissolved
arsenic concentration was 19.1 ^ig/1; before, the average concen-
tration was 23.7 ng/1. In well MW-3AR, the dissolved manganese
concentration was 5450 fig/1 whereas before its average was 1720
fig/1. In well MW-10A (like wells MW-14A and MW-16A, in the
northwest corner) the dissolved manganese concentrations were
1240 fig/1 and 1280 fig/1 (duplicate), and before, the average con-
centration here was 1375 fig/1. The dissolved nickel concentra-
tion in well MW-3AR, a shallow well next to the landfill, was 119
fig/1; in 1992 the average concentration here was 9.9 fig/1. The
MCL for nickel had been 100 fig/1, but this has been remanded (FR.
60. 3926 (June 29, 1995)) . Altogether there were 8 detects of
nickel in the 19 downgradient wells. In well MW-21B, the dis-
solved sodium concentration was 130,000 fig/1, whereas the average
concentration in this well in 1992 was 83,700 fig/1. The dis-
solved sodium concentration in well MW-21C has also increased (to
90,200 fig/1 from an average of 64,100 fig/1) ; the concentrations
of several other metals have also increased in this well. The
ROD Summary. Tippecanoe Sanitary Landfill Site
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average dissolved sodium concentration for the 5 background wells
is 10,800 /ig/1. In well MW-11B, two PAHs were detected in the
0.1 to 0.2 fig/1 concentration range. In the four northwest cor-
ner wells, the number of detects of SVOC TICs ranged from 4 to 24
(the latter in well MW-16A), based on unvalidated data. In well
MW-21C, there were 19 detects of SVOC TICs. The results of this
recent sampling have not indicated any significant improvement in
the quality of the groundwater. Therefore, groundwater contami-
nation continues to be a Site condition that must be considered
in the selection of remedial actions.
In the May 1997 sampling, the leachate elevations were approxi-
mately 20 to 25 feet above the water table elevation. The land-
fill continues to retain a significant amount of leachate.
VI. Summary of Site Risks
For the risk assessment and ecological evaluation, since the
presumptive remedy approach was used, scenarios involving expo-
sures to soil on the landfill and to leachate were not included;
exposures to landfill gas on the landfill and inside the nearby
residences were also not included. If for some reason the pre-
sumed remedies are not eventually a part of the final remedy that
is implemented, USEPA will review the risk assessment to make
sure that no unacceptable risks are left unaddressed by dropping
part or parts of the presumed remedy. (Exposures to nearby pos-
sibly contaminated soils were also not evaluated in the risk as-
sessment and ecological evaluation. These soils must be ad-
dressed further in the design phase when the cover is designed by
determining whether there are contaminated soils and sediments in
the adjacent areas that present a threat and, therefore, must be
excavated or covered.) The risk assessment focused on the
groundwater and the surface water exposures and the ecological
evaluation focused on the surface water exposures. The risk
assessment and the ecological evaluation are based on the 1992
sampling results.
In the baseline risk assessment, groundwater as a water supply,
with the exposure routes of ingestion, dermal contact while
showering, and inhalation of contaminants released from the
water, was evaluated; an adult was evaluated for potential car-
cinogenic effects and a child was evaluated for potential non-
carcinogenic effects. Also, a trespassing teenager was evaluated
for exposure to contaminants in the on-site ponds through inci-
dental ingestion of and dermal contact with surface water while
swimming or wading. Both the reasonable maximum exposure
(RME)3' and the central tendency case (CTC)4) were evaluated.
3. The reasonable maximum exposure is the highest exposure
that is reasonably expected to occur.
4. In the central tendency case, the exposure is not as high
as with the RME. The two differ in such things as the water
ROD Summary, Tippecanoe Sanitary Landfill Site
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At the time that the landfill was operating and for some time
thereafter, the residences to the northwest of the landfill were
using their wells for their water. Since that time, eleven resi-
dences have reportedly been provided with city water. However,
there has been no report of what has become of their wells, and
there is apparently the possibility that new wells could be in-
stalled .
Estimated incremental or excess individual lifetime cancer
risks5' as a result of exposures to potential carcinogens and
estimated hazard indexes (His). which are the sums of the hazard
quotients (HQs), and estimated HQs, which are measures of the
potential for noncarcinogenic effects6' due to exposure to con-
ingestion rate and exposure duration, for the adult or teenager,
but both use the same water concentrations for the same well
exposure situations in this study.
5. Excess lifetime cancer risks are determined by multiplying
the intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 10~4 or 1.0(10~4)). An excess lifetime cancer risk of 10"6
indicates a one in one million chance of developing cancer as a
result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at the site.
Cancer potency factors (CPFs' have been developed by USEPA
for estimating excess lifetime cancer risks associated with ex-
posure to potentially carcinogenic chemicals. The resulting ex-
cess lifetime cancer risk is an upper-bound estimate associated
with exposure at that intake level. The term "upper-bound" re-
flects the conservative estimate of the risks calculated from the
CPF. Use of this approach makes underestimation of the actual
cancer risk highly unlikely. CPFs are derived from the results
of human epidemiological studies or chronic animal bioassays to
which animal-to-human extrapolation and uncertainty factors have
been applied.
6. Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quo-
tient (HQ), the ratio of a single substance's estimated exposure
level (intake) to a reference dose for that substance. Adding
the HQs for all contaminants within a medium or across all media
to which a given population may reasonably be exposed gives the
hazard index (HI). The HI provides a useful reference point for
gauging the potential significance of multiple contaminant ex-
posures. However, the additivity of doses assumed when doing
this most properly only applies for substances that induce the
same effects by the same mechanism of action.
Reference doses (RfDs) have been developed by USEPA for in-
dicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs are esti-
mates of lifetime daily exposure levels for humans, including
sensitive individuals, that are lijcely to be without appreciable
risk of deleterious effects. The estimated intakes are compared
ROD Summary, Tippecanoe Sanitary Landfill Sice
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taminants, are presented in Table 2 for both the RME and CTC sce-
narios for using groundwater as a water supply. The results for
the northwest wells (wells MW-14A, MW-16A, MW-10A, and MW-11B)
have been determined since this area of the aquifer appears to
contain the higher concentrations of contaminants. The results
for the total aquifer are also presented for comparison purposes.
These results for the total aquifer would not ordinarily be de-
termined since it was clear that the contamination in the down-
gradient aquifer differed in the various directions; instead, the
risks in the various parts of the aquifer should have been deter-
mined as has been done here for the wells in the northwest cor-
ner. The results for the trespasser scenarios do not increase
the risks significantly.
USEPA has established the carcinogenic risk range of 10~4 to 10"6
as the acceptable level for exposures to potentially carcinogenic
substances. Remedial action for a site is generally warranted
when the baseline risk assessment indicates that a cumulative
site risk to an individual using reasonable maximum exposure as-
sumptions for either current or future land use exceeds a 10"4
lifetime excess cancer risk. • There are several instances in
Table 2 where this level has been exceeded. There may be a con-
cern about arsenic in the aquifer in the northwest corner and in
the aquifer as a whole. There may also be a concern about the
PAHs in the aquifer.
A hazard index, when additivity of doses is acceptable, or a
hazard quotient of 1.0 or more indicates that there may be a
level of concern for potential noncarcinogenic health effects.
Here, some HQs exceed unity, which indicates that there is a
level of concern about possible noncarcinogenic effects. There
may be concerns about arsenic, manganese, and iron. There may
also be concerns about antimony and DNOC.
There is some uncertainty about the numerical results in all
environmental risk assessments. Generally, conservative assump-
tions are used for the estimations so that one is reasonably con-
fident that the "true risk" will not exceed the risk estimate
obtained. However, the uses of conservative values do not neces-
sarily mean that the risks and hazards estimated are definitely
overestimates, for there are some factors that can cause an
underestimation of the risks and hazards.
The TICs were not included in the quantitative risk assessment.
Health information was reported for only one of the identified
TICs, and this one was detected at a low concentration (5 /ig/1)
to the RfDs. RfDs are derived from human epidemiological studies
or animal studies to which uncertainty factors are applied. The
uncertainty factors help ensure that a RfD will not underestimate
the potential for adverse noncarcinogenic effects to occur at the
level of the RfD.
ROD Summary, Tippecanoe Sanitary Landfill Site
9
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in only one groundwater sample. Many TICs were detected at sig-
nificant concentrations and in some wells there were a signifi-
cant number of TICs. There is a possibility that some of the
TICs could contribute significantly to the risks and hazards at
the Site, so not including them in the quantitative risk assess-
ment might mean that the risks and hazards have been under-
estimated .
Sodium and potassium were not included in the quantitative risk
assessment. The maximum downgradient concentration of sodium
(130,000 jig/1) was more than 10 times the upper 95% background
concentration and the maximum downgradient concentration of
potassium (49,500 /jlg/1) was more than 19 times the upper 95%
background concentration. The downgradient concentrations might
contribute significantly to the hazards from the Site. Reference
doses for sodium and potassium are not available. However, USEPA
has used a guidance level for sodium of 20,000 /jlg/1 for drinking
water.
There is more uncertainty associated with the carcinogenic unit
risk (from which the cancer s-lope is calculated) that is being
used for arsenic than with the unit risks and cancer slopes for
most other carcinogens. Therefore, it has been stated that car-
cinogenic risk estimates for arsenic could be modified downward
by as much as an order of magnitude when making risk management
decisions in specific situations (Memorandum to USEPA Offices
from USEPA Administrator Lee M. Thomas, June 21, 1988). Even if
the full modification could be used here, which has not been
justified, the risk for arsenic in the northwest corner wells
would still be a concern.
A preliminary ecological screening analysis was carried out that
addressed only the on-site ponds in the remedial investigation
because of the use of the presumptive remedy approach. A toxic-
ity quotient method was used for the aquatic analysis, in which
the eJtimated environmental concentration was divided by a chemi-
cal specific benchmark concentration to get the quotient; unfor-
tunately, no benchmark concentrations were obtained for some sub-
stances and these were not evaluated. No criteria were found for
evaluating the potential impacts to terrestrial receptors. For
the acute case, the toxicity quotients for three substances were
in the possible concern range. For the chronic case, the toxic-
ity quotients for four substances were in the possible concern
range, and that for mercury (10.8) was in the probable concern
range.
Based on these results, USEPA has determined that active or
threatened releases of hazardous substances from the Site, if not
addressed by an active measures, may present an imminent and sub-
stantial endangerment to public health, welfare, or the environ-
ment .
VII. Description of Alternatives
ROD Summary, Tippecanoe Sanitary Landfill Sice
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The alternatives that have been evaluated are:
Alternative 1: No Action;
Alternative 2: Deed Restrictions and Fencing; Barrier Cover;
Landfill Gas System; Groundwater Monitoring;
Alternative 3: Deed Restrictions and Fencing; Barrier Cover;
Leachate Collection; Landfill Gas System; Groundwater
Monitoring; A. Leachate Discharge to POTW; B. Leachate
Treatment and Discharge to Surface Water;
Alternative 4: Deed Restrictions and Fencing; Barrier Cover;
Leachate Collection; Landfill Gas System; Groundwater
Remediation; A. Leachate Discharge to POTW; B. Leach-
ate Treatment and Discharge to Surface Water;
Alternative 5: Deed Restrictions and Fencing; Barrier Cover;
Leachate Collection; Landfill Gas System; Partial Ref-
use Relocation; Groundwater Monitoring; A. Leachate
Discharge to POTW; -B. Leachate Treatment and Discharge
to Surface Water;
Alternative 6: Deed Restrictions and Fencing; Barrier Cover;
Leachate Collection; Landfill Gas System; Partial Ref-
use Relocation; Groundwater Remediation; A. Leachate
Discharge to POTW; B. Leachate Treatment and Discharge
to Surface Water.
A. Elements of the Alternatives
The various components of the alternatives are generally found in
more than one alternative, except for the "No Action" alterna-
tive. These components are described below, and each of the al-
ternatives consists of those components listed for it above. The
no-action alternative (Alternative 1) does not contain any of
these components. The USEPA Superfund program requires that the
no-action alternative be evaluated to establish a baseline for
comparison. Under this alternative, USEPA would take no further
action at the Site. However, if this were to be the. selected al-
ternative, because the investigation and study were done using
the presumptive remedy approach, it would be necessary to re-
evaluate the investigation and the risk assessment to determine
if there were additional significant risks at the Site that had
not been fully addressed.
1. Deed Restrictions and Fencing
Restrictions would be placed on the deed(s) for the property used
for the landfill and its associated operations (not including
property where only cover material was obtained) to limit future
site use and development and to notify any potential purchasers
of the prior use of the property. The restrictions would attempt
ROD Summary, Tippecanoe Sanitary Landfill Site ^
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to ensure the integrity of the waste containment system by great-
ly restricting future building on the waste disposal area so that
the cover would remain intact and by requiring that there be no
interference with the maintenance of the components constructed
for the remediation and with the monitoring of the Site. Other
restrictions on uses of the Site that might damage the integrity
of the cover would also be imposed. Restrictions on the instal-
lation of wells on the landfill property, other than those re-
quired for the remedial action, would be imposed and restrictions
on the use of wells on the surrounding properties where the
groundwater remains contaminated would be sought for the period
of time that the groundwater would remain contaminated at unac-
ceptable levels.
Fencing would be installed around at least the area capped to
physically limit access to the site; fencing around the entire
Site, except for the property that had not been used for waste
disposal in the northwest corner, would be preferred. Signs
would be posted at intervals on the fence and elsewhere as needed
to make clear that there may be a health threat associated with
going on the Site.
2. Barrier Cover
A barrier cover that meets the Indiana requirements for sanitary
landfills or municipal solid waste landfills would be provided.
IDEM has stated that the cover must comply with the requirements
of 329 IAC 10 (Solid Waste Land Disposal Facilities). The min-
imum cover that would be required by 329 IAC 10 would consist of
24 inches of compacted soil of the proper Unified Soil Classifi-
cation (a greater thickness may be required on slopes greater
than 15%, with no slope over 33%) (the barrier), with a slope of
at least 4%, plus 6 inches of topsoil; the compacted soil layer
must be compacted to achieve a hydraulic conductivity equal to
10"7 cm/s or less. Grain size, Atterberg limits, and hydraulic
conductivity tests as approved by the commissioner or as required
by 329 IAC 10 must be performed to confirm the quality of the
final cover. Prior to the installation of the cover, the Site
would be graded to obtain acceptable slopes. The grading of the
Site would also provide for acceptable control of runoff from the
waste disposal area and the rest of the Site. Proper management
of runoff would be provided. Acceptable vegetation would be es-
tablished on all areas where work had been done. All of this
would be constructed and tested according to all applicable con-
struction quality control and construction quality assurance re-
quirements. The constructed cover would have to be maintained so
that it would continue to provide the protection that the cover
provided when installed. Any leachate seeps that appeared on the
cover before or during the maintenance period would have to be
eliminated and the cover would have to be repaired.
Consideration must be taken of the fact that much of the waste
disposal area was originally in a floodplain. Where the barrier
ROD Summary, Tippecanoe Sanitary Landfill Site
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cover might be damaged by floodwaters, protection of the cover
must be provided. It is preferred that this protection not re-
sult in the removal of additional significant area from the
floodplain.
If it is found to be cost-effective and feasible, the cover on
some parts of the landfill might be provided by merely repairing
and upgrading the present cover. The resultant cover would have
to meet all of the requirements established for a cover con-
structed as above; especially, the barrier layer would have to
consist of compacted soil of one of the specified classifica-
tions, the slopes would all have to meet the requirements, and
the junctures between areas having a new barrier and areas having
a repaired barrier would have to allow no more infiltration than
that for a new barrier layer. All areas with a repaired and up-
graded barrier layer as well as any areas where no repairing and
upgrading of the barrier layer had been done would have to have 6
inches of new topsoil at the top to complete the cover; thus the
entire waste disposal area would be covered by 6 inches of new
topsoil to ensure that any contaminated soil present would have
been covered. Vegetation would have to be established over all
of the waste disposal area and the cover would have to be main-
tained, as described above.
During the design phase, soils and sediments in areas outside the
waste disposal area, including the southeast corner pond area and
areas off the landfill property, uhat might have become contami-
nated through inadequate waste-handling practices, surface water
runoff, leachate flow, migration of wastes or contaminants
through the air, or other means would be further tested for soil
contamination. Any areas found to contain unacceptable contami-
nation would be addressed, most likely through excavation of the
contaminated material, placement of this material on the waste
disposal area where it would be capped, and placement of accept-
able clean replacement material in the excavated area. The water
and sediments in the ponds in the southeast corner would also be
tested during the design phase, and if unacceptable contamination
were found, the water and sediments would be addressed in a man-
ner that would be acceptable to USEPA; this might range from
complete elimination of the ponds to removal of small areas of
contaminated sediment. If any hot spots would be•discovered in
the landfill prior to the completion of the installation of the
cover or the repair and upgrading of the cover, these would be
addressed in a manner acceptable to USEPA.
3. Landfill Gas System
A gas collection and control system that would meet federal and
Indiana requirements would be provided. The components of the
system would include either an active or passive collection sys-
tem and any required control system, such as a flare or flares.
Some of the wells would be installed on the sideslopes, especial-
ly toward the northwest corner where the gas migration problem
ROD Summary, Tippecanoe Sanitary Landfill Site
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has been the most troublesome. Gas monitoring probes installed
in the ground around the entire landfill outside the waste dis-
posal area would be used to determine that the gas venting system
was meeting the requirements regarding migration of gas away from
a landfill. When drilling into the landfill, monitoring for hy-
drogen cyanide and hydrogen sulfide will be needed.
4. Groundwater Monitoring
Groundwater monitoring, and monitoring of the waters in the ponds
in the southeast corner, would be conducted to follow the changes
in water quality with time. Monitoring of background groundwater
would also be done so that any changes in the water quality of
the ponds and downgradient groundwater due to changes in the up-
gradient groundwater could be determined. The initial monitoring
system would be defined during the design phase in consultation
with the agencies. It would be used to monitor all levels of the
aquifers that might be impacted by leakage of leachate from the
landfill and would monitor the waters for the substances speci-
fied by the agencies. The sampling and analysis plan for this
monitoring would be subject to the prior approval of the agen-
cies. One purpose of the groundwater monitoring being conducted
without any groundwater remediation components having been imple-
mented would be to determine whether any remediation of the
groundwater would be required. As a minimum, the groundwater
monitoring system would have to meet the Indiana requirements for
solid waste land disposal facilities (329 IAC 10).
5. Leachate Collection and Discharge to POTW
Leachate would ue collected from vertical wells installed in the
landfill to within one or two feet of the bottom of the landfill.
These wells would be either wells installed solely for the ex-
traction of leachate or the wells installed for the landfill gas
collection system, or a combination of these. Reduction of the
leachate head in the waste disposal area to one to two feet above
the bottom of the landfill would be the objective of the leachate
extraction system. The leachate would eventually be transferred
to the sewer or to on-site storage, if such was needed or deemed
to be the preferred method of operation, for later transfer to
the sewer, with the sewer carrying the leachate to the local pub-
licly owned treatment works (POTW). Treatment of leachate from a
municipal landfill at the local POTW is not uncommon. The amount
of leachate to be treated is not great, and the rate of discharge
could be adjusted, if necessary, to fit the available capacity of
the POTW. All required testing of the leachate and any required
on-site pretreatment would be provided.
6. Leachate Collection, Treatment, and Discharge to
Surface Water
Leachate collection would be done using the vertical extraction
wells described above. Leachate would be transferred to the
ROD Summary, Tippecanoe Sanitary Landfill Site
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treatment system constructed on the Site or just off the Site, in
an appropriate place. The treatment system would consist of the
processes needed to meet the requirements of an NPDES (National
Pollutant Discharge Elimination System) permit. The actual steps
of the process would be determined during the design phase, which
might require laboratory testing. Treatment residues would be
disposed of in a manner acceptable to the agencies. The treated
water would be discharged via a pipeline to either Wildcat Creek
or the Wabash River.
7. Groundwater Remediation
Metal constituents, primarily arsenic and manganese, are the main
substances of concern in the groundwater, based on the results of
the remedial investigation. Concentrations of sodium, chloride,
barium, iron, ammonia and total dissolved solids are some other
parameters that may require attention in a water treatment sys-
tem. Sampling and analyses done during the time the landfill was
operating indicated that there were also organic contaminants of
concern in the groundwater at those times, and this will have to
be considered in the future. •
During the design phase and later, groundwater data would be ob-
tained, using a groundwater monitoring system as described in the
section on groundwater monitoring, to establish the full extent
of the groundwater plume and follow the changes expected in the
concentrations of the contaminants following the installation of
the source control measures (primarily the cover and the leachate
extraction system). If the information and data collected during
this monitoring period did not indicate that the groundwater
leaving the Site would reach acceptable levels of contamination
within 10 years after the barrier cover and leachate extraction
system had been installed, the movement of the unacceptably con-
taminated groundwater off the Site would have to be stopped. For
unacceptably contaminated groundwater found downgradient of the
Site, if information and data collected during the monitoring in-
dicated that this contamination would not be reduced to accept-
able levels within 30 years, restoration of the aquifer in these
areas would be undertaken. If the potential risks to users of
existing or new wells installed downgradient of the Site, east of
the Wabash River, were unacceptable at any time, groundwater in-
terception or remediation would have to be undertaken immediate-
ly. Unacceptable groundwater contamination would be defined by
concentrations exceeding the maximum contaminant levels (MCLs),
secondary maximum contaminant levels (SMCLs), and health-based
levels. The health-based levels would be concentrations that are
protective of public health and the environment and take into
consideration the USEPA guidelines for assessing risks. The
determination of the necessity for groundwater interception or
remediation would include consideration of the requirements of
the Indiana article for solid waste land disposal facilities (329
IAC 10). The possibility of taking advantage of natural attenua-
tion would be included in the evaluation of the need for ground-
ROD Summary, Tippecanoe Sanitary Landfill Site i
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water interception or remediation. If groundwater action was de-
termined to be needed, following the installation of the source
control measures, such action would be designed, constructed and
operated for as long as it was determined to be necessary in
order to be protective of human health and the environment.
Interception of groundwater, if needed, would be expected to con-
sist of wells in the affected area that would provide a barrier
to further movement of the contaminated groundwater through ex-
traction of the groundwater. Remediation of groundwater, if
needed, would be expected to consist of a pump-and-treat system.
The extracted groundwater in either case would be transferred by
pipeline to a treatment system installed on the Site or just off
the Site, in an appropriate place. The treatment system would
consist of the processes needed to produce a water for discharge
that would meet the requirements of an NPDES permit. The treated
groundwater would be discharged via pipeline to Wildcat Creek or
the Wabash River under an NPDES permit. The pump-and-treat sys-
tem would be operated until it would no longer be needed. All
necessary sampling would be performed. Sampling and analyses of
the groundwater (groundwater monitoring) would be done periodi-
cally to make sure that the extraction system was performing cor-
rectly and to determine whether or not it, or only parts of it,
were still needed. Sampling and analyses would also be done per-
iodically in contaminated areas downgradient that were not being
remediated to determine whether or not remediation in these areas
might be needed.
8. Partial Refuse Relocation
Relocation of the wastes that lie against the soil that underlies
the buildings (the soil on the side of the hill) in the northwest
corner might eliminate or greatly reduce the migration of land-
fill gas toward these buildings. The wastes would be removed
down to the native soil to create an area about 30 feet wide for
a distance of about 1200 feet. These wastes would be placed on
other parts of the waste disposal area where they would be prop-
erly compacted. In the areas where the wastes were removed, the
proper slopes would be provided on the surfaces of the remaining
wastes. The soil underlying the wastes that had been removed
would be sampled for contamination. If unacceptable levels of
contamination were found and it would not be possible to excavate
all of this contaminated soil, the soil would be capped. Proper
environmental controls would be used to minimize the release of
odors, landfill gas, and contaminated dust during the relocation
of the wastes. If any hazardous wastes were encountered, they
would be properly handled and disposed of.
B. Summary of the Alternatives
Alternative 1 is the no action alternative that must be consid-
ered. The other alternatives contain differing amounts of ac-
tion. Alternative 2 consists of: deed restrictions and fencing;
ROD Summary, Tippecanoe Sanitary Landfill Site
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a barrier cover; a landfill gas system; and groundwater monitor-
ing. Alternative 3 is Alternative 2 plus leachate collection.
Alternative 4 is Alternative 3 with contingent groundwater remed-
iation added and includes modified groundwater monitoring. Al-
ternative 5 is Alternative 3 with partial refuse relocation
added. Alternative 6 is Alternative 4 with partial refuse relo-
cation added.
C. Costs and Time Required for Implementation
The estimated capital costs, costs for annual operation and
maintenance (O&M), and total present net worth costs for the
alternatives are given in Table 3.
Except for the no-action alternative and those alternatives in-
cluding groundwater remediation, the periods of time required to
implement the remedies are similar. The installation of leachate
extraction wells and a leachate treatment system would not in-
crease greatly the time for the completion of the construction of
the barrier cover and the landfill gas control system. It is ex-
pected that the barrier cover- and gas and leachate systems could
be installed in one construction season; establishment of a fully
acceptable vegetation layer might take an additional year.
Leachate extraction and disposal or treatment would be operated
as long as would be required, which could be 3 0 years or longer;
the length of time and the rate of leachate extraction would de-
pend upon the quality of the barrier cover. Groundwater remedia-
tion would not be implemented until it was established that it
would be needed, but the rest of the components of these alterna-
tives would be installed as soon as possible. Once the need was
determined for groundwater remediation, it could be designed and
installed in less than a year. Operation of the groundwater ex-
traction and treatment system would be done until it was no long-
er needed, which might be 10 to 30 years, or longer.
As required by CERCLA, a review of the remedial action selected
will be conducted at least every five years after the beginning
of the remedial action since wastes are being left at the Site.
With the no-action alternative, this review would probably re-
quire some sampling and analyses of the groundwater and evalua-
tion of the condition of the Site; these costs have not been in-
cluded in the cost estimate.
VIII. Summary of Comparative Analysis of Alternatives
In this section the nine evaluation criteria that USEPA uses to
evaluate each alternative are discussed. These nine criteria
are :
1) Overall protection of human health and the environment. The
alternatives are assessed to determine whether they can ade-
quately protect human health and the environment from unac-
ceptable risks.
ROD Summary, Tippecanoe Sanitary Landfill Site
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2) Compliance with ARARs. The alternatives are assessed to de-
termine whether they attain applicable or relevant and ap-
propriate requirements (ARARs) under federal environmental
laws and state environmental or facility siting laws or pro-
vide grounds for invoking one of the waivers permitted.
3) Long-term effectiveness and permanence. The alternatives are
assessed for the long-term effectiveness and permanence they
afford, along with the degree of certainty that the alterna-
tive will prove successful.
4) Reduction of toxicity, mobility, or volume through treatment.
The degree to which alternatives employ recycling or treat-
ment that reduces toxicity, mobility, or volume is assessed,
including how treatment is used to address the principal
threats posed by the site.
5) Short-term effectiveness. The short-term impacts of alterna-
tives are assessed considering short-term risks to the com-
munity, potential impacts on site workers, potential envi-
ronmental impacts, and t-he time until protection is
achieved.
6) Implementability. The ease or difficulty of implementing the
alternative is assessed by considering technical feasibil-
ity, administrative feasibility, and availability of ser-
vices and materials.
7) Costs. Capital costs, annual operation and maintenance
costs, and net present value of capital and 0 & M costs are
assessed.
8) State acceptance. The concerns of the state are assessed.
9) Community acceptance. This assessment includes determining
vvhich components of the alternatives interested persons in
the community support, have reservations about, or oppose.
The first two criteria are the threshold criteria. Each alterna-
tive must meet these requirements, unless a specific ARAR is
waived, in order to be eligible for selection. The next five
criteria are the primary balancing criteria. The last two cri-
teria are the modifying criteria that are to be considered in
remedy selection.
A. Overall Protection of Human Health and the Environment
Alternative 1 (No Action) and Alternative 2 (Landfill Cover) do
not provide adequate protection of human health and the environ-
ment since the source of the contamination in the groundwater is
not adequately controlled. The cover will not prevent all infil-
tration, and so leachate will continually be generated and leak
out the bottom of the landfill into the groundwater.
ROD Summary, Tippecanoe Sanitary Landfill Site
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Alternative 3 (Source Control) may provide adequate protection of
human health and the environment if the groundwater contamination
does indeed decline with no more intervention than the installa-
tion of source control (landfill cover and gas and leachate re-
moval) measures.
Alternative 4 (Source Control and Groundwater Remediation) in-
cludes the possibility of additional intervention in the spread
of groundwater contamination, which would be necessary when there
is no indication of an adequate decline in the spread of the con-
tamination without any intervention. However, the decision to
actively intervene will not be made until there is an opportunity
to evaluate the capability of the source control measures to
provide protection of human health and the environment for the
groundwater. To protect human health, groundwater containing
contamination levels in excess of the maximum contaminant levels
(MCLs), proposed MCLs, and non-zero maximum contaminant level
goals (MCLGs) needs to be prevented from leaving the Site; when
necessary, a carcinogenic risk of no more than 1CT4 (possibly
something slightly higher for arsenic if a modification, as
discussed above, can be justi-fied) and a cumulative hazard index,
for those substances that induce the same effect by the same
mechanism, or a hazard quotient of one would be used for the
criteria.
Alternatives 5 (Source Control and Partial Refuse Relocation) and
6 (Source control, Groundwater Remediation, and Partial Refuse
Relocation) provide the same protections of human health and the
environment as Alternatives 3 and 4, respectively, just in a
different manncT- All of the alternatives except Alternative 1
provide adequate protection from contact with the wastes and
adequate protection from the release of landfill gas.
B. Compliance with Applicable or Relevant and Appropriate
Requirements
Only Alternatives 4 and 6 will meet the identified applicable or
relevant and appropriate requirements (ARARs). Alternatives 1,
2, 3, and 5 do not meet the ARARs because there are exceedances
of MCLs in the downgradient groundwater and there are no active
means provided to correct this. Alternatives 4 and 6 provide for
the groundwater remediation that may be required under the ap-
plicable parts of the solid waste regulations. In the case of
the other alternatives, if remediation of the groundwater were
determined to be necessary under the solid waste regulations and
there was resistance to its implementation because it was not
part of the alternative chosen, that alternative would have to be
amended to require such remediation.
All alternatives except Alternative 1 require the installation of
a barrier cover that meets the identified ARAR for the cover for
this Site, 329 IAC 10.
ROD Summary, Tippecanoe Sanitary Landfill Site
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C. Long-term Effectiveness and Permanence
The final landfill cover system included with all alternatives
except Alternative 1 provides long-term effectiveness with prope
maintenance. The cover reduces the mobility of the contaminants
by covering the wastes and reducing water infiltration. A prope
landfill cover, along with other source control measures, is the
accepted means for minimizing the release of wastes from land-
fills. The gas extraction that is a part of all alternatives ex
cept Alternative 1 reduces the mobility of landfill gas that con
tains constituents that may be harmful to human health and the
environment and may be a safety hazard. The leachate collection
system of all alternatives except Alternatives 1 and 2 completes
the source control that is necessary to properly reduce the mo-
bility of the contaminants and provides long-term effectiveness.
Groundwater remediation that is a part of Alternatives 4 and 6
provides a barrier to the further movement of unacceptably con-
taminated groundwater and increases the long-term effectiveness.
Since wastes will remain at the Site in all alternatives, five-
year reviews of the protectiveness of the remedy will be re-
quired. In the case of Alternatives 3 and 5, where groundwater
remediation is not a part of the remedy, if it were determined
during one of these reviews that groundwater remediation were
necessary, the selected remedy could be amended and such remed-
iation could be included.
D. Reduction of Toxicity, Mobility, or Volume Through
Treatment
Alternatives 4 and 6 provide for the potential extraction and
treatment of the groundwater. This will reduce the mobility and
volume of the contaminants. Alternatives 3, 4, 5, and 6 provide
for the extraction and treatment of leachate. This will reduce
the mobility and volume of the contaminants. Alternatives 2, 3,
4, 5, and 6 provide for the extraction of landfill gas and pos-
sibly its treatment through flaring, which will decrease its
toxicity. This will reduce the mobility of this gas through the
soils toward nearby residences.
E. Short-term Effectiveness
The groundwater remediation of Alternatives 4 and 6 prevents the
further migration of contaminated groundwater and provides for
the greatest short-term effectiveness. Handling of the wastes
generated in on-site treatment of leachate (Alternatives 3B, 4B,
5B, and 6B) and groundwater (Alternatives 4 and 6) may present
some slight risks to the workers and to others when wastes from
the treatment processes are hauled off the Site for proper dis-
posal. Installation of the groundwater and leachate and gas ex-
traction wells may present some risks to the workers. Partial
refuse relocation (Alternatives 5 and 6) might present some risk
to the workers and some nearby residents through the release of
landfill gas; there also might be a unacceptable odor problem
ROD Summary, Tippecanoe Sanitary Landfill Site
20
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associated with this refuse relocation. The installation of the
cover, especially if the grading involves uncovering some of the
wastes, might present some risks to the workers and some nearby
residents. There are some possibilities of risks to residents
and workers if the pipeline and sewer carrying the leachate to
the POTW were to leak (Alternatives 3A, 4A, 5A, and 6A). The
extraction of gas and leachate from the landfill provides added
protection against the spreading of the contamination. The cover
for the wastes that is a part of all alternatives except Alterna-
tive 1 provides protection against contact with wastes and con-
taminated soils.
F. Implementability
Among the alternatives requiring active remedies, Alternative 2
would be the simplest to implement, followed by Alternatives 3
and 4. Alternatives 5 and 6 would be more complicated to imple-
ment than Alternatives 3 and 4, respectively. All of the alter-
natives should be fairly easy to implement since none contains
elements that have proved difficult or impossible to implement in
the agency's experience with similar sites. A possible exception
would be removal of arsenic from leachate or groundwater in an
on-site treatment system (full treatment or pretreatment) to meet
NPDES discharge or POTW pretreatment requirements since the re-
duction of arsenic concentrations to low levels is reportedly
difficult. Another possible exception could arise if a contami-
nant that has not been fully evaluated at this time were found to
be difficult or costly to remove in the treatment system. A pos-
sible implementation problem might arise in the alternatives in
which leachate is sent to the POTW for treatment if changes in
the content of the leachate occur or regulations regarding waste
streams being sent to POTWs change. Also, in these alternatives,
there might be an implementability problem if the POTW is too
close to its capacity under all conditions. Alternatives 3B, 4,
5B, and 6 require that an NPDES permit be obtained for discharge
cf the treated water to either Wildcat Creek of the Wabash River;
the permit should be obtainable. If landfill gas cannot be vent-
ed directly to the atmosphere, there should be no problem in de-
veloping a flare system to handle the gas.
G. Cost
The costs of the various alternatives are presented in Table 3.
Alternative 1 has essentially no costs associated with it.
Groundwater remediation, of course, adds to the costs of source
control alone, but it may be necessary for the protection of
human health and the environment.
H. State Acceptance
The Indiana Department of Environmental Management has been in-
volved throughout the remedial investigation and feasibility
study. The State has indicated that they believe that the re-
ROD Summary, Tippecanoe Sanitary Landfill Site
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quirements of Alterative 4 are necessary for this Site.
I. Community Acceptance
There was only one strong objection raised to the preferred rem-
edy that has been presented to the community in the Proposed
Plan. This was an objection raised to the possible inclusion of
partial refuse relocation in the remediation because of the ex-
pected strong odors that would accompany such work. The comments
that have been received are answered in the Responsive Summary
that is a part of this ROD.
IX. Selected Remedy
The alternative that has been selected by USEPA in consultation
with IDEM is Alternative 4A. This alternative includes: Site
access controls, including a fence around at least the waste dis-
posal area, and restrictions on site use, including prohibition
of installation of water supply wells on the Site and of site
uses that would damage the remedial actions; a barrier cover that
meets the Indiana requirements for sanitary landfills or munici-
pal solid waste landfills specified in 329 IAC 10; a leachate
collection system from vertical wells installed in the landfill
and discharge of the leachate to the local POTW following any re-
quired pretreatment; a landfill gas collection and control system
that meets federal and Indiana requirements for landfills; a
groundwater remediation program, if one would be needed because
the source control measures (cover and gas and leachate extrac-
tion) were insufficient to prevent unacceptable contamination of
the groundwater off the Site. Further details concerning each of
the components ot this selected remedy are presented above in
section VII.A.
If it were found that the local POTW would not be able to accept
the leachate, then Alternative 4B is the preferred alternative.
The only change that would result is that the leachate would be
treated on the Site and discharged to a local surface water body
under a NPDES permit.
Because of the possible release of objectional odors, partial
refuse relocation has not been included as an acceptable element
of the selected remedy.
X. Statutory Determinations
USEPA's primary responsibility at Superfund sites is to select
remedial actions that protect human health and the environment.
Section 121(d)(2) of CERCLA also requires that the selected re-
medial action for the site comply with applicable or relevant and
appropriate environmental standards under state and federal envi-
ronmental laws with respect to contaminants remaining on site at
completion of the remedy unless a waiver is granted. With re-
spect to ongoing work at the site, it is USEPA's policy to comply
ROD Summary, Tippecanoe Sanitary Landfill Site
-------
with state and federal environmental laws. The selected remedy-
must also be cost-effective and utilize treatment technologies to
the maximum extent practicable. CERCLA also establishes a pref-
erence for remedies that include treatment as a principal ele-
ment. This section discusses the extent to which the selected
remedy satisfies these statutory elements.
The Proposed Plan for the Tippecanoe Sanitary Landfill, Inc. site
was released for public comment in July 1997, and a 30-day long
public comment period was provided. The Proposed Plan identified
Alternative 4A as the preferred alternative unless the local POTW
could not accept leachate from the Site, in which case Alterna-
tive 4B would be the preferred alternative. Also, the Proposed
Plan stated that the partial refuse relocation of Alternatives 6A
or 6B could be included in the remedy if it was determined that
this was desirable. USEPA reviewed all the comments received
during the comment period. Upon review of these comments, it was
determined that Alternative 4A or 4B was the alternative of
choice. However, it was determined that the partial refuse relo-
cation should be dropped as a potential element of the remedy.
These determinations have been made upon consultation with, and
with the concurrence of, the State of Indiana.
A. Protection of Human Health and the Environment
The selected response action will be effective in containing the
source materials in the landfill that are contributing to contam-
ination at the Site.
The partial baseline risk assessment performed for the Site iden-
tified exposure scenarios that resulted in noncarcinogenic health
effects that may be of concern and cancer risks that exceed the
USEPA's suggested risk range of 10"4 to 10"6. The scenarios con-
templated the use of the contaminated groundwater downgradient of
the Site as a water supply, analyzing exposures due to 1) inges-
tion of the water, 2) dermal contact with the water, and 3) inha-
lation of vapors that might arise from the water. These risks
are addressed by the selected remedy by controlling the source of
the contamination and by the possible future implementation of
groundwater remediation. If groundwater remediation is deter-
mined to be needed after the source control measures are in-
stalled or because a downgradient water supply is found to be
threatened, the remediation measures implemented will be operated
and maintained until the groundwater no longer presents a human
health risk, that is, when the groundwater contamination would no
longer be unacceptable. Unacceptable groundwater contamination
is defined by concentrations exceeding the maximum contaminant
levels (MCLs), secondary maximum contaminant levels (SMCLs), and
health-based levels. The health-based levels would be concentra-
tions that are protective of public health and the environment
and take into consideration the USEPA's guidelines for assessing
risks.
ROD Summary, Tippecanoe Sanitary Landfill Site
--2-3-
-------
Since it was known that it was necessary to install a landfill
cover system over the wastes, no sampling of the surface soils
was done and no risk assessment for exposure to these soils was
performed. The landfill cover system and gas and leachate ex-
traction systems will provide the required protection from the
hazards due to the wastes that are being left in place.
Discharges of treated water to surface water (either Wildcat
Creek or the Wabash River), if Alternative 4B has to be used
because the local POTW cannot accept leachate from the Site, will
be regulated by the NPDES requirements, which will ensure that
the remedial action does not adversely affect the stream.
Based on the present levels of contaminants detected in the
aquatic ecosystem, ecological effects appear to be minimal.
Based on the fact that the groundwater is the main means by which
contamination is being transported (except for the leachate seeps
present on the waste disposal area now which will be eliminated
by the barrier cover), terrestrial ecosystem effects are not
expected. However, during the implementation of the remedy, the
surface ponds and the surrounding soils and sediments will be
further investigated to determine if any action regarding these
media might be required.
B. Compliance with Applicable or Relevant and Appropriate
Requirements
Alternative 4 will meet all of the identified federal and more
stringent state applicable or relevant and appropriate require-
ments (ARARs). The major ARARs that have been identified are
listed in Table 4.
C. Cost-Effectiveness
USEPA determines that Alternative 4 is cost-effective. Section
300.430(f)(1)(ii)(D) of the NCP requires USEPA to evaluate cost-
effectiveness by comparing all the alternatives that meet thres-
hold criteria (protection of human health and the environment and
compliance with ARARs) against three balancing criteria (long-
term effectiveness and permanence, reduction of toxicity, mobil-
ity, or volume through treatment, and short-term effectiveness).
Alternative 4 presents the best balance among these factors.
The lowest cost alternative involving some remedial action is Al-
ternative 2, landfill cover and gas system. However, this alter-
native does not provide a means for stopping the movement of the
contaminated groundwater from leaving the site, if such a measure
is deemed to be necessary. Nor does it provide as much source
control as is deemed to be necessary and which is reasonably pos-
sible. Since the minimum barrier cover that has been included in
the alternatives considered that require some action will not com-
pletely prevent infiltration, some leachate removal is required
to further reduce the amount of contamination reaching the
ROD Summary, Tippecanoe Sanitary Landfill Sice 24
-------
groundwater.
Alternative 3A, which does include leachate control, is the next
least costly alternative, but this again does not provide for
containment of the contaminated groundwater. Thus it does not
satisfactorily address the effectiveness criteria.
Alternative 4A does provide the possible necessary containment of
contaminated groundwater and the possible remediation of down-
gradient contaminated groundwater, if this is found to be neces-
sary. While this alternative is more costly than Alternative 3A,
it is to be noted that if no groundwater remediation is found to
be necessary after the effects of source containment and natural
attenuation have been evaluated, the costs will be approximately
those of Alternative 3A. Alternative 4A is the least costly al-
ternative that provides a possible barrier to the migration of
the contaminated groundwater, something which the remedial action
must provide. Thus this alternative is cost-effective for pro-
viding the protection that is required at the Site.
Alternative 4B would be used only if the POTW could not accept
the leachate from the Site. While more costly, these would be
unavoidable additional costs under the circumstances. Treatment
of leachate at a POTW is something that is not uncommon.
D. Utilization of Permanent Solutions and Alternative
Treatment (or Resource Recovery) Technologies to the Maximum
Extent Practicable (MEP)
USEPA believes that the alternative selected represents the
maximum extent to which permanent solutions and treatment tech-
nologies can be utilized in a cost-effective manner. The se-
lected alternative provides the best balance of long-term effec-
tiveness and permanence, reduction of toxicity, mobility, and
volume through treatment, short term effectiveness, implement-
ability, and cost, taking into account the statutory preference
for treatment as a principal element as well as state and com-
munity acceptance.
E. Preference for Treatment as a Principal Element
This site is a sanitary landfill, and it is generally recognized
that containment will be the main method of addressing the
wastes, which pose only relatively low, long-term threats to
human health and the environment.
Collection of leachate and transport to the POTW for treatment,
gas venting or extraction and possible flaring, and installation
of a barrier cover are being used to address the releases and
threatened releases at the Site. Treatment on-site is being used
to address the contaminated groundwater, which represents the
greatest identified health risk, if remediation of the ground-
water is determined to be necessary after the results of the
ROD Summary, Tippecanoe Sanitary Landfill Site
25-
-------
source control measures are evaluated and natural attenuation is
taken into account.
This remedy does not satisfy the statutory preference for treat-
ment as a principal element of the remedy. The size of the land-
fill and the fact that no on-site hot spots representing major
sources of contamination have been found preclude a remedy in
which contaminants could be excavated and treated effectively.
No principal threat to which the treatment preference could be
directed has been identified at the Site.
XI. Explanation of Change
One change regarding the remedy selected that has been made to
what was stated in the Proposed Plan has been the elimination of
the partial refuse relocation for possible inclusion in the rem-
edy. The Proposed Plan did not select the alternative (Alter-
native 6A) that included the elements of Alternative 4A along
with partial refuse relocation as the preferred alternative. It
merely stated that this partial refuse relocation could be imple-
mented as part of the remedy -if it would be found to be desir-
able. Because of a concern about the possible release of ob-
jectionable odors during such a relocation of wastes, this option
is not included with the selected remedy.
IDEM has further investigated its requirements for solid waste
landfills and has determined that the requirements of 329 IAC 10
(Solid Waste Land Disposal Facilities) apply to this Site. Pre-
viously, it had been expected that this article would apply to
most aspects of the remediation of the Site. The primary excep-
tion had been the barrier cover. Now 329 IAC 10 also applies to
the barrier cover. This may not result in much change in the
requirements for the barrier cover, if it is found that the
barrier cover to be installed will be that required by 329 IAC
10-22-7(b). However, if IDEM determines that one of the other
barrier covers included in 329 IAC 10 is required, there will be
some change in the requirements and these will result in a
geomembrane being included as part of the cover.
ROD Summary, Tippecanoe Sanitary Landfill Site
2-6
-------
Table 1. Selected Groundwater Results
Substance
MCL
SMCL
^g/i
Downgradient Wells
NW Corner Wells
Background Wells
Detect
Freq.
Range
^g/i
No.
Exceed
M or S
ucl95
M9/1
Detect
Freq.
Range
Mg/i
No.
Exceed
M or S
UCL95
Mg/i
Detect
Freq.
Range
m g/i
No.
Exceed
M or S
ucl95
Mg/i
B (A) P-TE (PAHs)
(a)
1/41
(b)
M-l
1.41
0/9
M-0
ND
0/11
M-0
ND
dieldrin
1/40
0 . 02
0 . 02
0/9
ND
0/11
MD
aldrin
2/41
0.037-
0 . 044
0 . 026
1/9
0 . 044
0 . 030
0/11
ND
DNOC
1/41
25 .
--
13 .4
0/9
ND
0/11
--
ND
carbon disulfide
1/41
4 .
4 . 0
0/9
--
MD
0/11
--
ND
aluminum
S-
50-200
1/41
575
S-l
55 . 1
0/9
S-0
ND
2/11
1130-
3780
S - 2
907
antimony
M-6
3/41
17 .6-
56 . 0
M-3(c)
9.6
1/9
41. 3
M-l
18 .2
0/11
M-0
ND
arsenic
M- 50
14/41
2.9-
71 .2
M-l
11.5
7/9
3.8-
71.2
M-l
47.2
1/11
5.2
M-0
2 . 0
barium
M-2000
39/41
30.3-
1190
M-0
461
9/9
478-
1160
M-0
937
10/11
21. 9-
292
M-0
168
iron
S-300
28/41
217-
11,400
S-25
3180
9/9
217-
11300
S-8
10,700
4/11
462-
7330
S-4
1716
manganese
S-50
37/41
4 . 1-
1830
S-34
650
9/9
110-
1390
S-9
1380
6/11
99. 9-
273
S-6
162
nickel
M-14 0
11/41
11. 2-
39.8
M-0
13 . 9
6/9
10 . 0-
39. 8
M-0
34.8
1/11
14.3
M-0
10 . 1
potassium
39/41
843-
49,500
12,700
9/9
6660-
28,700
24,300
10/11
1120-
3620
--
2592
sodium
39/41
3280-
130,000
49,700
9/9
53,600-
127,000
102,000
10/11
3610-
14,100
11,500
chloride
S-
250000
41/41
3000-
230,000
S-0
89,000
9/9
77,000-
230,000
S-0
183,000
11/11
9000-
31,000
S-0
22,800
TDS
S-
500000
41/41
280000-
5600000
S - 24
1130000
(d)
9/9
630000-
1100000
S-9
980,000
11/11
370000-
870000
S-3
672000
Notes: a) The MCL for benzo(a)pyrene is 0.2 /ig/l. b) In one well sample in one round, ten PAHs were found at concentrations ranging from 1 to
4 eg/l. c) The detection limit for antimony ranged from about 17 /ig/l (for most samples) to about 53 fi9/l< well above the MCL. d) If the results
for well MU-21C are not included, the UCLg5 is 668,000 ng/i.
1) In the MCL, SMCL column, M represents a maximum contaminant level (MCL) value, S represents a secondary maximum contaminant level (SMCL)
value. 2) In the detect freq. column, the nunber of detects is given as well as the nunber of sample results. 3) In the range colunn, the range of
concentrations for the detects is given. 4) In the No. exceed M or S colunn, the nunber of detects that exceed the MCL (M) or the SMCL (S) is given.
5) In the UCLg5 colunn, the 95X upper confidence limit value is given; if this value exceeds the maximum average value for any well, the maximum value
for the wells is listed. 6) The downgradient wells are all the wells except the five background wells and well MW-15A. 7) The background wells are
MU-9A, MU-12A, MU-13A, MW-18A, and MW-19C. 8) The northwest corner wells are wells MU-10A, MW-11B, MU-14A, and MW-16A; these wells are included in
the downgradient wells. 9) Data qualifiers have not been included in the table. 10) B(a)P-TE is the benzo(a)pyrene toxic equivalent for the
carcinogenic PAHs. 11). DNOC is 4,6-dinitro-2-methylphenol.
-------
Table 2: Selected Results--Groundwater as a Water Supply
Item
RME
CTC
Total
Aquifer
Northwest
Wells
Total
Aquifer
Northwest
Wells
Cancer Risk Estimates
Exposure of an Adult
Total risk
7.4(10"4)
9.8(10"4)
1.4(10"4)
2.1(10"4)
Risk, Arsenic
2.4 (1CT4)
9.7(10"4)
5 . 0 (10~5)
2.0(10"4)
Risk, B(A)P-TE (PAHs)
4 . 9(10"4)
NC
9 . 2(10~5)
NC
Risk, dieldrin
3 . 7(10~s)
NC
7.7(10"7)
NC
Risk, aldrin
5 . 3 (1CT6)
6 . 0(10~6)
1. 1(10~6)
1. 3 do"6)
Noncarcinogenic Hazard Estimates
Exposure of a Child (0 to 6 years old)
HI
22 .
49.
16 .
34 .
HQ, antimony
1. 5
18 .
1. 1
13 .
HQ, arsenic
2.4
10 .
1. 7
7 .1
HQ, barium
0.4
0 . 9
0 . 3
0.6
HQ, iron
0 . 7
2 . 3
0 . 5
1. 6
HQ, manganese
8 . 3
18 .
5 . 8
12 .
HQ, nickel
1
o
o
1
0 . 1
0.03
CO
o
o
HQ, carbon disulfide
0.6
NC
0 . 6
NC
HQ, DNOC
8.6
NC
6 . 0
NC
DNOC is i,6-dinitro-2-methylphenol.
* * * * *
Table 3. Costs
Alternative
Capital Costs
Annual 0 & M
Total Present
Net Worth
1-no action
$0
$0
$0
2-cover
$3,800,000
$260,000
$7,000,000
3A-cover, leachate off
$4,300,000
$520,000
$10,700,000
3B-cover, leachate on
$5,100,000
$6,000,000
$560,000
$870,000
$12,000,000
4A-cover, groundwater,
leachate off
$16,800,000
4B-cover, groundwater,
leachate on
$6,300,000
$880,000
$17,300,000
5A-cover, leachate off,
1 waste
$4,900,000
$520,000
$11,300,000
5B-cover, leachate on,
waste
; 6A-cover, groundwater,
' leachate off, waste
6B-cover, groundwater,
leachate on, waste
$5,700,000
$6,600,000
$6,900,000
$560,000
$870,000
$880,000
$12,600,000
$17,400,000
$17,900,000
These are the costs from the PRP Technical Committee's feasibility study
report submittal. Some of the descriptions of the alternatives have been
changed, most notably the change from a "repaired" cover to an installed
cover. These will change the cost estimates, but the relative costs will be
similar to the above.
-------
Table 4. Major Identified
Applicable or Relevant and Appropriate Requirements
Chemical Specific
Safe Drinking Water Act (SDWA) National Primary Drinking
Water Regulations (40 CFR 141)
Clean Air Act (CAA) National Emissions Standards for Hazard-
ous Air Pollutants (40 CFR 61)
Indiana Water Quality Standards (327 IAC 2)
Action Specific
Clean Water Act (CWA) EPA Administered Permit Programs: The
National Pollutant Discharge Elimination System (NPDES) (40
CFR 122)
CWA Criteria and Standards for the National Pollutant Dis-
charge Elimination System (40 CFR 125)
CWA General Pretreatment Regulations for Existing and New
Sources of Pollution (40 CFR 403)
CWA Section 401, Certification, Permits and Licenses
Clean Air Act (CAA) Requirements for Preparation, Adoption,
and Submittal of Implementation Plans (40 CFR 51)
CAA Approval and Promulgation of Implementation Plans (4 0
CFR 52)
CAA Standards of Performance for New Stationary Sources (40
CFR 60)
CAA Section 101, Findings and Purposes, Air Quality and
Eti.issions Limitations
Resource Conservation and Recovery Act (RCRA) Air Emission
Standards for Process Vents (Subpart AA in 40 CFR 264)
RCRA Air Emission Standards for Equipment Leaks (Subpart BB
in 40 CFR 264)
Toxic Substances Control Act (TSCA) Polychlorinated Bi-
phenyls (PCBs) Manufacturing, Processing, Distribution in
Commerce, and Use Prohibitions (40 CFR 761)
RCRA Criteria for Classification of Solid Waste Disposal
Fr.cilities and Practices (40 CFR 257)
RCRA Criteria for Municipal Solid Waste Landfills (Eff. 10-
9-93) (40 CFR 258)
RCRA Identification and Listing of Hazardous Waste (40 CFR
261)
RCRA Standards Applicable to Generators of Hazardous Waste
(40 CFR 262)
RCRA Standards Applicable to Transporters of Hazardous Waste
(40 CFR 263)
RCRA Land Disposal Restrictions (40 CFR 268)
RCRA Technical Standards and Corrective Action Requirements
for Owners and Operators of Underground Storage Tanks (UST)
(40 CFR 280)
Comprehensive Environmental Response, Compensation, and Lia-
bility Act of 1980, as Amended by the Superfund Amendments
and Reauthorization Act of 1986 (CERCLA)
CERCLA National Oil and Hazardous Substances Pollution Con-
tingency Plan (NCP) (40 CFR 300)
CERCLA Designation, Reportable Quantities, and Notification
(40 CFR 302)
-------
Table 4, cont., Major ARARs
CERCLA Worker Protection (40 CFR 311)
Occupational Safety and Health Act (OSHA) Occupational Safe-
ty and Health Standards (29 CFR 1910)
OSHA Safety and Health Regulations for Construction (29 CFR
1926)
Department of Transportation (DOT) Hazardous Materials Pro-
gram Procedures (49 CFR 107)
DOT General Information, Regulations, and Definitions (49
CFR 171)
DOT Hazardous Materials Table, Special Provisions, Hazardous
Materials Communications, Emergency Response Information,
and Training Requirements (49 CFR 172)
Indiana Solid Waste Land Disposal Facilities (329 IAC 10)
Indiana Hazardous Waste Management Permit Program and Re-
lated Hazardous Waste Management (329 IAC 3.1)
Indiana Water Well Drilling (310 IAC 16)
Indiana Wastewater Treatment Facilities; Issuance of Per-
mits; Construction and Permit Requirements (327 IAC 3)
Indiana Wastewater Treatment Facilities; Overload Condition
(3 27 IAC 4)
Indiana Industrial Wastewater Pretreatment Programs (NPDES)
(327 IAC 5)
Indiana Management of Sewage Disposal System Wastewater (327
IAC 7)
Indiana Public Water Supply (327 IAC 8)
Indiana NPDES General Permit Rule Program (327 IAC 15)
Indiana Ambient Air Quality Standards (326 IAC 1-3)
Indiana Fugitive Dust Emissions (326 IAC 6-4 and 6-5)
Indiana VOC Emissions (326 IAC 8-1-6)
Location Specific
National Environmental Policy Act (NEPA) Procedures for Im-
plementing the Requirements of the Council on Environmental
Quality on the National Environmental Policy Act (40 CFR 6)
(also consider Fish and Wildlife Coordination Act and Scenic
Rivers Act)
CWA Section 404(b)(1) Guidelines for Specification of Dis-
posal Sites for Dredged or Fill Material (40 CFR 230)
CWA Section 404 (c) Procedures (40 CFR 231)
Endangered Species Act (50 CFR 17; 50 CFR 402)
Indiana Construction in a Floodway (IC 14-28-1 and 410 IAC
6-1)
To Be Considered Criteria
CWA Maximum Contaminant Level Goals (Subpart F of 40 CFR
141)
CWA Federal Water Quality Criteria (FWQC)
CAA National Primary and Secondary Ambient Air Quality Stan-
dards (40 CFR 50)
Indiana Solid Waste Management (329 IAC 2, repealed in 1996)
Note: A particular ARAR may belong to more than one category.
-------
SCALE IN MILES
Ra«. ¦ USQS Mao. LafayatM Ea«t and Watt. IN.
Quadrartotaa 1S81. Bom Photoraviaad 1 OBB.
quadrangle location
FIGURE 1
SITE LOCATION MAP
TIPPECANOE SANITARY LANDFILL
LAFAYETTE. INDIANA
Q6V1SE0
WRftl
NUMtffr
9TJ9 003 SJS
-------
MW-1SA
MW-1BA
UW-16A
MW-1AR
MW-11B V III
scalc IN rcn
i inch » 100 rcci
UW-19C
UW-1BB
UW-19A
MW-9A
FIGURE 2
monitor weu. locations
TIPPEC/.NOE SANITARY LANDFILL
LAFAYETTE. INDIANA
BERT
W v
67J6-0U!' I
UW-UA
CONTOUR INTERVAL - 10 FIET
f/2/M
¦bfcauewfc
-------
Attachments
Responsiveness Summary
September 29, 1997 Letter of Concurrence, Indiana Department
Environmental Management
Administrative Record Index, Original
Administrative Record Index, Update #1
-------
Responsiveness Summary
Tippecanoe Sanitary Landfill, Inc. Site
Tippecanoe County, Indiana
I. Overview
The U.S. Environmental Protection Agency (USEPA) issued a Pro-
posed Plan in July 1997 for the Tippecanoe Sanitary Landfill,
Inc. site (the Site) and began a 30-day comment period that ended
on August 28, 1997. The remedial investigation (RI) and feasi-
bility study (FS) that provided the information used for deciding
on a preferred remedy had been performed by a group of some of
the potentially responsible parties (PRPs) as the result of a
settlement reached with USEPA and the Indiana Department of Envi-
ronmental Management (IDEM), which is contained in an Administra-
tive Order on Consent (AOC). This group of PRPs included the
city of Lafayette, Indiana, the city of West Lafayette, Indiana,
Tippecanoe County, Indiana, Purdue University, and several indus-
trial companies. USEPA's preferred alternative contained in the
Proposed Plan addressed all of the site conditions warranting
response action that have been identified so far for this former
sanitary landfill. This preferred alternative included: deed
restrictions and fencing; a barrier cover for the waste disposal
area; leachate collection and discharge to the local privately
owned treatment works (POTW); a landfill gas system; and contin-
gent groundwater remediation. If the leachate could not be sent
to the POTW for treatment, then the leachate would be treated on
or near the Site and the water would be discharged to Wildcat
Creek or the Wabr.sh River. Also, if those doing the remedial
work believed that it would be advantageous, the wastes near the
hillside in the northwest corner of the Site could be moved to
another portion of the waste disposal area.
Judging from the comments received, both at the August 6, 1997
public meeting and by mail, there is general agreement with the
primary components of USEPA's preferred alternative and en-
couragement that the remediation begin. There was an objection
to the proposed excavation of some of the wastes because of the
possible odor problems, and this option has been removed from the
selected remedy. A concern was raised about the discharge of the
leachate to the POTW for treatment because of possible capacity
problems and possible effects on the sludge produced, but it is
believed that those concerns can be overcome. If they cannot,
then the alternative of on-site treatment of the leachate will
have to be used. One person did question the need for leachate
extraction and contingent groundwater remediation components, and
this is addressed below.
II. Background on Community Involvement
Community interest in this landfill arose while the landfill was
operating (it closed in 1989) because of various disputes that
the operator had with the State and because of several denials of
TSL ROD. Responsiveness Summary
-------
the operating permit by the State.
Community interest has increased over the past few years largely
due to a local income tax which was initiated and is being col-
lected from the residents of Tippecanoe County to raise funds for
the remediation of the Site. Some people have objected to this
and the tax has been opposed in the courts. USEPA has taken no
position with regard to this tax. Usually in the cases of Super-
fund sites, when USEPA reaches an agreement with one or more po-
tentially responsible parties (PRPs) that have been named for the
site, it is the responsibility of these parties to determine how
the work that they have agreed to do will be financed. Community
interest has also increased due to the amount of time taken by
the PRPs to complete the RI and FS.
III. Summaries of Comments Received and USEPA's Responses
This section summarizes the comments received during the comment
period. The Administrative Record contains a complete copy of
the transcript for the public meeting as well as all written com-
ments .
1. Comment. At the public meeting, Mayor Sonya Margerum of West
Lafayette, Indiana, submitted a letter dated August 5, 1997 with
some comments on behalf of the group of PRPs that had performed
the work under the AOC (Tippecanoe Sanitary Landfill (TSL) PRP
Group (PRP Group)), and she summarized the contents for those
attending the meeting. The letter first summarizes some of the
history of the Superfund related work. It mentions that over
$2.5 million has been spent by the PRP Group. They are pleased
that the Proposed Plan has been issued. They state their view
that the conclusions drawn from the RI and FS by USEPA and IDEM
are substantially the same as the conclusions reached by this
group of PRPs, that differences of opinion with USEPA over the
course of the study were rather minor, and that on major points
the differences were more over form than substance. They state
that the June 1997 sampling shows an overall improvement in the
quality of the groundwater and expect that future monitoring will
continue to show such improvement. They believe the majority of
items in the components of the proposed remedy needing clarifica-
tion will be clarified during the remedial design phase.
USEPA Response: USEPA appreciates the overall agreement of this
group of PRPs with the conclusions of USEPA and IDEM regarding
the remediation of the Site. USEPA looks forward to cooperative
efforts that will lead to timely and effective remediation of the
Site.
USEPA notes that, at times, there were substantive differences
with the TSL PRP Group (PRP Group) during the performance of the
RI and FS.
USEPA has concluded that the May 1997 sampling results do not in-
dicate any practical improvement in the quality of the ground-
TSL ROD, Responsiveness Summary
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water downgradient of the Site. This is not surprising since
Site conditions have not changed substantially. Arsenic in one
well is above the maximum contaminant level (MCL). Sodium con-
centrations are well above acceptable limits; directly west of
the Site, the sodium levels have increased significantly. There
are still significant numbers of detects of semivolatile organic
compound (SVOC) tentatively identified compounds (TICs) in some
downgradient wells.
If there are items in the components of the remediation selected
that need clarification, these will be resolved during the nego-
tiations and before the PRPs are permitted to do any remedial
action. Any uncertainties need to be cleared up at that time so
that all components of the work to be done will be clearly de-
fined in the settlement document. Waiting until the design phase
could merely cause further delays in what should be a relatively
straightforward process.
2. Mayors Sonya Margerum of West Lafayette and David Heath of
Lafayette, as Co-Chairs of the TSL PRP Group, submitted comments
on the Proposed Plan. Enclosed with the letter, dated August 22,
1997, was information concerning the additional groundwater
sampling conducted during May 1997 at the request of USEPA. This
includes a copy of the July 14, 1997 ENSR data transmittal letter
and a copy of a revised data validation report (still dated July
1997 and carrying the same document number, but containing three
revised memos in Attachment B; the report still does not contain
tables providing the validated results for tentatively identified
compounds (TICs), and these have not yet been submitted). The
following summarizes the points raised and the responses of
USEPA.
a. Comment. Regarding the May 1997 sampling event, the TSL
PRP Group believes it is unfounded to indicate, as the Proposed
Plan (page 4 of the full text) does, that the results of the May
1997 sampling have not indicated any improvement in the quality
of the groundwater; indeed, the PRP Group claims that a definite
improvement was shown. They present a table showing some compar-
isons. For example, they say that in May 1997 no volatile organ-
ic compounds (VOCs) were detected and 4 detects were found in
1992. In May 1997, six SVOCs were found and no pesticides were
found, and in 1992 thirteen SVOCs and four pesticides were found.
In May 1997 no antimony was found and in 1992 antimony was found
twice. They compare the arsenic results in well MW-14A and MW-
16A and state, "In the remaining 22 wells, arsenic was either not
detected or reported as an estimated, low value." Regarding man-
ganese, they say, 11 . . .the concentration of manganese decreased
in the other 3 wells (MW-4AR, MW-10A and MW-16A) which had showed
elevated levels of manganese during the 1992 sampling events."
They point out that USEPA had stated in the Proposed Plan that
nickel was found at 119 ppb in well MW-10A, which was incorrect;
this concentration was found in the center of the south border of
the landfill in well MW-3AR. Also, they point out that there
were a total of 9 detects of nickel in May 1997 whereas there
TSL ROD, Responsiveness Summary
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were detects in 8 wells in one sampling event and in 3 wells in
the other event in 1992. They also claim that chemicals in the
leachate samples are significantly lower, in general, in 1997
compared to the earlier samplings.
USEPA Response. As stated in item 1, USEPA adheres to its con-
clusion that the May 1997 sampling results do not indicate any
practical improvement in the quality of the groundwater down-
gradient of the Site. Actually there was one VOC detect in the
1997 sampling (toluene in well MW-17C); for the split samples
that IDEM took from 8 downgradient wells, IDEM reported detects
of a total of four VOCs in four wells. There are still signifi-
cant numbers of SVOC TICs in some downgradient wells. There were
significant numbers of pesticides detected in May 1997 blank sam-
ples, so the results for pesticides have to be used cautiously
when trying to draw conclusions. Arsenic is present in well MW-
14A above the MCL. In 1997 arsenic was detected in 6 of the 19
downgradient wells; in 1992, based on the average concentrations
calculated per well, it was found in 9 wells. Although the im-
plication is that manganese was found at elevated levels in 1992
in only 4 wells, an examination of the average concentrations of
manganese per well, based on the 1992 data, reveals that 9 of the
downgradient wells had concentrations in excess of the 1992 95%
upper confidence limit for the 5 background wells of 162 fig/1; in
1997, the manganese concentrations in 10 of the downgradient
wells exceeded 162 fig/1. The maximum nickel concentration of 119
fig/1 was indeed erroneously reported in the Proposed Plan as be-
ing found in well MW-19A instead of well MW-3A, which is near the
center of the southern border of the Site but is more properly
described as be^g near the eastern extent of the waste disposal
area along the southern boundary. However, the important aspect
of this nickel concentration is that the maximum concentration of
nickel detected in 1992 was just 39.8 fig/1. In summary, while
improvements can be cited, consideration of the overall picture
does not indicate any practical improvement in the quality of the
groundwater downgradient of the Site between 1992 and 1997.
With regard to the leachate results, there was only a 12% de-
crease in the average concentrations of sodium in the three leach-
ate wells and a 5.3% decrease in the arsenic concentrations. The
barium concentrations increased in 2 of the 3 wells and the man-
ganese concentrations increased in 1 of the 3 wells.
b. Comment. Concerning well MW-14A, which the PRP Group
points out has been discussed frequently, primarily because ar-
senic has been consistently found there at levels higher than
elsewhere, the TSL PRP Group notes that this well is on the TSL
property right at the refuse border. Because of this, they claim
that its results do not represent a true picture of the ground-
water as it could be tainted with leachate. They also say that,
because of the low concentration of arsenic in the leachate, the
arsenic in this well could be at least partially attributed to
naturally occurring arsenic in the geologic formation in that
area. They point out that the arsenic level decreases as one
TSL ROD. Responsiveness Summary
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moves away from this well. They conclude that arsenic is not a
concern in the aquifer as a whole.
USEPA Response. There are a number of other wells that are also
close to the waste boundary (MW-1AR, MW-17A, MW-3AR, and MW-4AR.
and, one could also say, MW-21A), some of which may be even clos-
er than well MW-14A. All of the contaminated wells have been
tainted with leachate, but it is believed that at the wells the
leachate has mixed with the groundwater. There is no basis to
assume that leachate is being sampled in well MW-14A. There was
no indication that well MW-14A was drilled through wastes. A
1971 aerial photograph of the Site shows that the building next
to well MW-14A existed then. Thus, there is no information to
cause USEPA to disregard the results from well MW-14A.
It is possible that the arsenic found in well MW-14A is coming
from naturally occurring arsenic in the geological formation.
However, it is present in the groundwater in this area at concen-
trations above background levels, and is probably related to the
Site .
Arsenic in the northwest corner is a concern. Concentrations
above the MCL are being found. The carcinogenic risk when using
the water as a drinking water source is well above the USEPA ac-
ceptable carcinogenic risk range for exposure to potentially car-
cinogenic substances. The carcinogenic risk for the aquifer
downgradient of the landfill as a whole also exceeds this risk
range.
c. Comment. Regarding the risk assessment, the TSL PRP
Group says that the risks resulting from the following substances
could be taken out or revised because of the May 1997 results:
antimony, carbon disulfide, 4,6-dinitro-2-methylphenol, dieldrin,
aldrin, and most polycyclic aromatic hydrocarbons (PAHs). They
commen^ on USEPA's statement that not including che TICs in the
risk assessment might mean that the risk has been underestimated
by saying that no health information is available for the TICs
(except one). They say that USEPA's comment ". . .active or
threatened releases of hazardous substances from the Site, if not
addressed by the preferred alternative or one of the other active
measures considered, may present an imminent and substantial
endangerment to public health, welfare or the environment" is
unfounded.
USEPA Response. There would be some changes in the results of
the risk assessment if the results of the May 1997 sampling were
included; however, the results of the 1992 sampling cannot be
disregarded, absent any information that they did not represent
the conditions at the Site. In any event, the USEPA acceptable
carcinogenic risk range for exposure to potentially carcinogenic
substances would still be exceeded at this Site.
The fact that no health information is available for the TICs,
except for the one, does not change the fact that it is possible
TSL ROD, Responsiveness Summary
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that the risks may have been underestimated by not including the
TICs in the risk assessment.
There are unacceptable carcinogenic and noncarcinogenic risks
present using the groundwater as a drinking water source. The
MCL for arsenic is being exceeded. Therefore the Site may pre-
sent an imminent and substantial endangerment to public health,
welfare, or the environment.
d. Comment. The TSL PRP Group says that various components
of the proposed remedial alternative will need to be clarified
during the design phase. They say that in the USEPA Section 6.1
for the feasibility study report, it is stated that the treatment
of the extracted groundwater will be accomplished through precip-
itation, flocculation, and settling for the removal of metals and
that the cost estimate presented reflects this treatment scheme.
They then claim that "it is impossible to remove the low levels
of arsenic anticipated by the U.S. EPA to be present in the ex-
tracted groundwater, by the treatment process stated by the U.S.
EPA." They say that the correct treatment scheme is discussed in
the Draft Feasibility Study Report submitted by the PRPs in June
1996, and therefore, the cost of groundwater treatment might be
significantly higher if such treatment for arsenic were found to
be necessary. They also say that requiring a useless technology
would not be consistent with the National Contingency Plan (NCP).
USEPA Response. As stated in item 1, any clarifications concern-
ing the work to be done will be determined during the negotia-
tions for implementing the remedy.
In USEPA's Section 6.1.5 of the feasibility study report, it
says, "The possibility that additional treatment might be needed
for reduction of arsenic and organics has not been included in
this cost estimate." The cost estimate that USEPA used in the
Proposed Plan is the one that the TSL PRP Group provided in their
June 1996 Draft Feasibility Study Report (PRP FS draft report),
so it includes what they thought was necessary (only a lump sum
dollar amount was provided). It is possible that the cost esti-
mate for groundwater treatment may be less reliable because of
treatment for arsenic.
It is uncertain whether this treatment would have to be done by
the process the TSL PRP Group presented in the PRP FS draft re-
port. In Manual: Ground-Water and Leachate Treatment Systems,
USEPA, January 1995 (EPA/625/R-94/005), arsenic is included in a
table of example precipitation treatment methods in the section
on chemical precipitation of metals. If groundwater remediation
becomes necessary and there was a concern about the treatment
system, treatability studies will be undertaken. If a treatment
to meet discharge requirements is not possible, it may be neces-
sary to revisit the Record of Decision and accomplish the desired
result (a groundwater downgradient of the Site that meets the
requirements of the ARARs) by some other means.
TSL ROD. Responsiveness Summary
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A useless technology would not be required, and none is presently-
being required.
e. Comment. The TSL PRP Group says that they do not object
to the inclusion of the May 31, 1996 letter from USEPA to Kera-
mida Environmental, Inc. in the documents that constitute the
single entity that is the remedial investigation report for the
Site. They do object to the statement ". . .disapproving the PRP
RI report. . appearing in the July 9, 1997 letter providing
the conditional approval for a remedial investigation report.
They state, "The inclusion of such wording in the July 9, 1997
letter is contrary to the conditional approval granted by the
letter, and contrary to the level of cooperation enjoyed between
the U.S. EPA and the PRPs. We would appreciate a statement from
U.S. EPA that such wording was neither intended to be included
nor to imply that PRP RI report is not approved with the condi-
tions incorporated."
USEPA Response. The phrase 11 disapproving the PRP RI report" was
included to summarize the subject of the May 31, 1996 letter from
USEPA. It is important to point out that documents listed in the
July 9, 1997 letter constitute the remedial investigation report
for this Site. There can never be a representation made that the
February 1996 version of the remedial investigation report sub-
mitted by the TSL Site PRP Technical Committee (Volumes I, II,
IIIA, and IIIB) (PRP RI report) has been "approved" or "accepted"
by USEPA.
f. Comment. Referring to the July 11, 1997 letter from
USEPA granting conditional approval to a group of documents,
listed there, as a single entity to constitute the feasibility
study report, the TSL PRP Group objects to a comment on page 4 of
Ecology and Environment's (E&E's) [USEPA's oversight contractor]
comments saying, "Furthermore, based on the past responsiveness
of the PRPs, significant contamination of the groundwater from
the leachate could occur in the time it would take to get the
PRPs to move on to the second step if this was not included in
the first step." The TSL PRP Group "strongly object [s] to this
editorial comment as untrue, unfounded and completely opposite to
the way the PRPs have functioned during the RI/FS process." They
mention that they have spent over $2.5 million for the RI and FS.
They state that they have met all the deadlines imposed by USEPA.
They "would appreciate a statement from the U.S. EPA saying the
U.S. EPA does not endorse the opinion expressed by E&E."
USEPA Response. The Administrative Order on Consent (AOC) which
began the RI and FS work at this site was signed on March 8,
1990. It is presently September 1997 and the work is only now
being finished. Much of the delay in getting this work finished
must be attributed to the TSL PRP Group. Approval of the Project
Plans took much longer than it should have. There were four
drafts of the RI report, and none were approvable. The AOC re-
quired that the second submittal (the revision) had to incorpo-
rate all USEPA comments and modifications; this was not done.
TSL ROD, Responsiveness Summary
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Another delay was caused by the initial refusal of the TSL PRP
Group to install leachate wells in the landfill in order to study
the leachate; this delay resulted in the leachate wells being
installed after the groundwater sampling that had been planned
for the RI had been completed. Once or twice, the TSL PRP Group
unilaterally suspended work when it objected to what the USEPA
required. Thus deadlines were missed and work was delayed.
3. Wayne Chambers, whose residence lies on the property of the
Site, in the northwest corner, submitted some comments at the
public meeting.
a. Comment. Mr. Chambers stated that it was unrealistic to
consider the possibility of digging up the wastes. He indicated
that there are 11 families in that area, and the odors from ex-
posed wastes if they are excavated would be unbearable. He rec-
ommended that, for any excavation, USEPA should require relocat-
ing the families while the work is being done.
USEPA Response. USEPA has withdrawn the option that the partial
waste relocation could be done as part of the remediation if the
parties doing the remediation work found that this would be de-
sirable. It is expected that the landfill gas system, if proper-
ly designed, should be capable of providing the necessary control
of gas migration. Monitoring of he effectiveness of the gas con-
trol system will be required to ensure the safety of the resi-
dents .
b. Comment. Mr. Chambers said that the information about
the landfill level being at the field level is incorrect. He
said that they (the operators) had dug down 50 feet and laid down
some plastic. He also mentioned, since the first waste disposal
was closest to his house and rules at the time the landfill was
started were not as strict, that this is another reason wastes
toward the northwest corner should not be dug up.
USEPA Response. Claims that there was some excavation of the
existing soil to such depths as 50 feet before wastes were placed
have been made orally before, but there has been nothing that
USEPA has seen that documents this. The water table in that area
is approximately 5 feet below the surrounding farmland. Excava-
tion to 50 feet would have resulted in ponds unless the water was
pumped from the excavations as it flowed in and discharged some-
where. Historical aerial photographs, while they do sometimes
show some small areas of liquid present at the site, do not indi-
cate any extensive excavations. The State inspection reports do
not mention any ponds present; they do mention problems with
standing water because of the flooding problems in the area.
Wastes were not allowed to be disposed of in water.
c. Comment. Mr. Chambers said that he does not believe
that the taxpayers should pay for the remediation, only the PRPs.
Others have also expressed this opinion.
TSL ROD. Responsiveness Summary
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USEPA Response. When a settlement is reached with a group of
PRPs for work in the Superfund program, USEPA does not dictate
how the group of PRPs is to obtain the funds that it will use to
pay for its share of the work. The tax that has been imposed on
the local taxpayers was something that was brought about by one
or more of the local government bodies. USEPA cannot prevent
this method of financing from being used.
d. Comment. Mr. Chambers said that the methane gas is at
60% at a point 5 feet from his house. He described the proced-
ures that he is to follow if the methane meters installed by IDEM
in his house are triggered. Because of the threat, he believes
that it is necessary to get the remediation started as soon as
possible. He said to deal with the groundwater if you must. He
also complimented IDEM on the work that they have done regarding
the methane meters.
USEPA Response. It is the intention of USEPA that the remedia-
tion work selected in this ROD be started as soon as possible.
e. Comment. Mr. Chambers said that there has been a lot of
cancer in the area. He does not know if it is related to the
landfill.
USEPA Response. USEPA has not been made aware of a belief that
there might be an incidence of elevated cancer cases in the area
in the past. This report will be brought to the attention of the
Agency for Toxic Substances and Disease Registry.
4. Tom Peyton AmTech provided a number of comments at the
public meeting and in a letter dated August 26, 1997.
a. Comment. Mr. Peyton wanted to know why the landfill was
not capped immediately. He said that an estimated 0.5 billion
gallons have leached through the landfill since it was closed.
Mr. Peyton said that there was a court order that was never ful-
filled. He said that someone should be responsible for the delay
if this results in the necessity for surface treatment of ground-
water .
USEPA Response. At the closure of the landfill there was a court
order in effect that called for the capping of the landfill.
USEPA was not a party in this court order. Some capping of the
landfill did take place as a result of this court order, but it
was not completed, apparently because sufficient funds were
unavailable.
USEPA has not assessed the quantity of leachate which may have
been generated since the landfill was closed. However if 0.5
billion gallons (0.5 x 109 gal) has passed out of the landfill,
which covers about 59 acres, since 1989 (about 8 years), this
amounts to about 39 inches per year per acre. However, the nor-
mal and median precipitation rates for West Lafayette are only
about 36 inches per year. Not all precipitation infiltrates the
TSL ROD. Responsiveness Summary
s
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earth. There is runoff, especially on significant slopes, and
evaporation through various mechanisms that account for a lot of
the moisture that falls. The volume that infiltrates depends on
the type of soil and the setting. Here, there was an attempt to
provide something that would at least approximate a cap on at
least part of the landfill. So it is doubtful that there was 0.5
billion gallons that passed through the landfill in these 8
years. It was more likely in the neighborhood of an order of
magnitude less.
While USEPA could have tried to get the TSL PRP Group to install
a cap or complete the cap shortly after the closure of the land-
fill, it was thought that with the cap that was there it was best
to investigate the Site prior to implementing any remediation. A
hastily implemented cap could have made the gas problem worse, so
it would have been necessary to also address the gas problem
then. USEPA expectation in 1990 was for the PRP Group to quickly
complete the remedial investigation and feasibility study for the
Site so that a final remedy could be implemented.
There are no plans to pursue any individuals that contributed to
the delay in the completion of this project as PRPs to provide
the funds for surface treatment of groundwater, if this should be
needed. Such involvement with a site does not make a party a
PRP.
b. Comment. Mr. Peyton asked why USEPA or IDEM do not re-
quire that qualified environmental professionals be hired from
within Tippecanoe County when the tax to supply the money for the
remediation is imposed on the local citizens?
USEPA Response. When USEPA reaches a settlement with a group of
PRPs, as long as the settlement does not include the federal gov-
ernment furnishing some of the funds, USEPA can not dictate who
the PRP Group employs or how they go about getting their contrac-
tors, as long as the PRP Group complies with all applicable laws.
In these settlements, however, USEPA does usually have a right to
approve or disapprove a contractor the PRPs had selected, but
USEPA could not disapprove a contractor just to force the PRPs to
select a contractor that USEPA preferred.
c. Comment. Mr. Peyton asked why USEPA or IDEM do not re-
strict the use of the funds from the tax to site cleanup and not
legal fees.
USEPA Response. As stated above, USEPA does not take a position
on the local tax that has been imposed to generate funds for the
remedial action.
d. Comment. Mr. Peyton asked why the risk for cancer from
arsenic is nearly 10"^ for the northwest corner wells when there
has been only one exceedance of the MCL of 50 fig/1?
USEPA Response. The MCL that has been set for arsenic is not
TSL ROD. Responsiveness Summary
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based strictly on the cancer slope factor that has been estab-
lished for arsenic. Arsenic is reportedly being studied further,
both with regard to the MCL and the cancer risk.
5. Comment. Bill Baitinger, West Lafayette, discussed the his-
tory of the Site at the public meeting. He said that he had read
the materials about the Site. He said that it was unfortunate
that the landfill had been located by Mr. Chambers home. He said
that we should now move forward, that there is now a reasonable
plan and he thinks that the community in general is behind it.
He does believe the Site needs remediation. He urged flexible
implementation. USEPA has chosen 4A, but he could live with 3B
[he probably meant 3A] and 4B. He said to do only what is neces-
sary. He would not recommend moving any of the wastes. The com-
munity, in his view, can always argue about who should pay. He
stated that if resources were expended trying to pursue purported
white-collar criminals (as someone else at the meeting advocat-
ed) , a lot of time and money would be spent but this would prob-
ably accomplish nothing.
USEPA Response. USEPA appreciates Mr. Baitinger's remarks.
USEPA is interested in moving forward quickly. USEPA is inter-
ested in flexible implementation of the remedy, and calling for a
contingent groundwater remediation component does provide for
flexible implementation. If groundwater remediation is not
needed then essentially Alternative 3A has become the remedy
instead of Alternative 4A.
6. Comment. Darrell Leap, a geologist, said at the public
meeting that he was glad to see things finally moving, that the
plan is a reasonable one. One concern is that the two aquifers
(the transcript does not record this word, but this is probably
what was meant) may coalesce west of the landfill. He believes
that more information is needed about the groundwater to the west
and southwest of the landfill, more monitoring wells are needed
in that area.
USEPA Response. USEPA agrees that more information will be
needed downgradient of the landfill to fully characterize the
plume and determine how it will be changing in the first few
years after the source control measures have been implemented.
This will indeed require more wells further from the landfill
than have been used so far. Although the TSL PRP Group in the
June 1996 draft feasibility study report (PRP FS draft report)
said that groundwater monitoring would be carried out using only
some of the present wells in only parts of the aquifers, USEPA
has stated that this is not acceptable. A monitoring network
acceptable to the agencies that will cover the entire plume, in-
cluding any part of the plume that has reached the deeper parts
of the aquifers, will have to be designed. What has been learned
so far has been sufficient to propose and select a method of re-
mediation .
7. Comment. Dorothy Alabach, of Valparaiso, Indiana, asked at
TSL ROD. Responsiveness Summary
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the public meeting if this was going to be a "stage show", a
cover-up. She then went on about pursuing white collar crime and
using RICO (racketeer influenced and corrupt organization) in
doing this. She criticized the State of Indiana. She said that
the general assembly has no business passing a special tax to pay
for this clean-up.
She also brought up that she had submitted a freedom of informa-
tion act (FGIA) request some time =igo that she said was not pro-
perly responded to, and she was here resubmitting it. The FOIA
request dealt with who besides Schlossberg was involved in the
decision making concerning the operation of the landfill.
USEPA Response. USEPA has followed its usual procedures in try-
ing to determine who might be liable at this Site and should be
named a PRP. So far 30 to 40 parties have been named PRPs.
Since these were named, USEPA has continued to try to obtain in-
formation on all parties that have been mentioned in regard to
the site. The information collected will be used to see if any
more should be named PRPs.
In her FOIA request of 9/12/96, Ms. Alabach asked who besides Mr.
Schlossberg was listed and identified in public records as the
operators of the Site. USEPA was only able to identify a part of
the Administrative Order on Consent (AOC) as being responsive to
Ms. Alabach's request. A copy of the AOC was sent to her. Un-
fortunately, the transmittal letter did not direct her to the
part that USEPA had identified, which was Article V of the AOC.
8. Comment. Je'Ff Symmes, West Lafayette, at the public meeting
stated that he has periodically been watching the landfill for
the last ten years. He said that the landfill was a toxic waste
dump for a number of years, till the mid 1980s. He believes that
there are millions of pounds of toxic wastes in the landfill. He
claimed that two companies that hauled wastes to the landfill
were connected with organized crime in Pennsylvania. He talked
about some other landfills. He said that out-of-state wastes
went to the Tippecanoe landfill. He asked where the money gener-
ated from taking in out-of-state wastes went. He claimed that
Mr. Schlossberg destroyed monitoring wells that were contaminated
with PCBs and noted that PCBs are not found in any samples during
the RI. Mr. Symmes also carried on a dialogue with a couple of
the USEPA representatives concerning information responses from
PRPs, enforcement investigations, enforcement procedures, and
operation of the landfill without a permit from the State that
have not been considered as comments.
Mr. Symmes also commented on the hearings that led to the closure
of the landfill, that these were held behind closed doors and
USEPA should be aware of this.
USEPA Response. USEPA has not received any documentation to show
that considerable quantities of hazardous or toxic wastes have
gone into the landfill. The results of the groundwater monitor-
TSL ROD. Responsiveness Summary
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ing do not indicate that this might be the case.
In the 1984 edition of 330 IAC 4 (Refuse Disposal Act; Solid
Waste Management Permits; Industrial Waste Hauler Permits), 330
IAC 4-5-14 states, "Under no circumstances shall hazardous wastes
be accepted at a sanitary landfill unless authorized in writing
by the Board or its designated solid waste management agent." It
also said that this was filed August 15, 1974. Thus there was an
awareness back then, at least, that hazardous wastes did not gen-
erally belong in a sanitary landfill.
USEPA is aware that some out-of-state wastes were deposited in
the landfill and has been provided with the names of some alleged
haulers of these wastes. USEPA had no control over what happened
to the money that the landfill received for taking these wastes
and has not investigated this matter.
USEPA is aware that some monitoring wells were lost when Mr.
Schlossberg was operating the landfill. This would have no con-
nection with whether or not polychlorinated biphenyls (PCBs) are
now found in the groundwater around the landfill.
USEPA appreciates the information that Mr. Symmes has provided.
9. Comment. Dan Duncan, Lafayette Waste Water Treatment Plant
[Manager, Water Pollution Control Department], commented at the
public meeting that he did not want to see the risks from the
landfill transferred to the wastewater treatment plant. He men-
tioned the possibility of additional costs for monitoring, that
they have no rate structure for that. He did say that there is
currently in their ordinance a set fee for those kind of inde-
pendent monitoring things from landfill leachate. He also said
that they recycle their biosolids [incorrectly stated as biosol-
vents in the transcript] (sewage sludge) and wanted to know what
the risks were to these.
USEPA Response. It is not unusual for leachate from a sanitary
landfill to be sent to a wastewater treatment plant. If this can
be done (the main obstacle might be the capacity of the waste-
water treatment plant, but the amount being sent there eventually
might be only on the order of 10 to 20 gallons per minute, and it
could be less), it will be necessary that the details be worked
out so that the water discharge from the plant and the biosolids
are protected and that the added costs for accepting the leachate
are fully covered by the charges imposed. If it is necessary,
the leachate will have to be pretreated for the protection of the
wastewater treatment plant, just as industrial discharges are
often treated.
10. Comment. Francis Kovach commented by letter dated July 28,
1997 that, if discoveries are made during the cleanup that would
result in the removal or treatment of extraordinary substances
such as radioactive materials or highly toxic chemicals, every
effort should be made to identify the sources of the materials
TSL ROD, Responsiveness Summary
T3
-------
and require these sources to pay for the additional costs rather
than have the tax money cover them.
USEPA Response. As has been stated previously, if a settlement
is reached whereby a group of PRPs agrees to perform the remedial
action, USEPA does not expect to direct how this group will allo-
cate among its members the respective shares of the costs.
11. Comment. Lotte Hirsch commented in a message received
August 1, 1997 that they accept the USEPA preferred alternative,
that the groundwater should be protected. Once this alternative
is implemented, it should take care of the problem.
USEPA Response. USEPA appreciates the comments.
12. Comment. David Easterwood commented in a message received
August 6, 1997 that it should not be the responsibility of the
local taxpayers to clean up the landfill. It should be the re-
sponsibility of the businesses and factories and Purdue Univer-
sity whose chemicals and contaminants have been put in there.
USEPA Response. As stated above, if an agreement is reached for
a group of PRPs to implement the remedial action, USEPA will not
specify how they pay for their share. The Superfund law requires
USEPA to identify as PRPs any parties who may have contributed
hazardous substances to the site. If anyone affected by this tax
does not believe that the tax should be used for the cleanup,
that person will have to contact those responsible for imposing
the tax or controlling the use of the funds.
13. Comment. Norbert Fisher in a message received August 26,
1997 agrees that the Site must come to some sort of proper clos-
ure. He agrees with the cover and the gas system. He disagrees
about the leachate collection system and the groundwater remedia-
tion. If there is a proper cover and surface water can no longer
seep down into the landfill, he cannot see why leachate would
continue to seep out. He does say that the groundwater must be
safe, and if it takes leachate collection and groundwater remedi-
ation to make it so, then this should be done. He said to only
do as much as is appropriate.
USEPA Response. The cover that is required for this landfill
will reduce the amount of infiltration that would take place
through wastes or some soils or some other shapes. However, it
will not completely prevent the infiltration of water. Because
of this and the necessity to remove the leachate already present
so that it will not all get into the groundwater, a leachate ex-
traction system has been selected. The groundwater remediation
will only be implemented if it is necessary because the source
controls have not been sufficient.
TSL ROD. Responsiveness Summary
-------
Indiana Department of Environmental Management
We make Indiana a cleaner, healthier place to live
Frank O'Bannon
Oovcmor
John M. Hamilton
Cnmmfjiioncr
100 North Senate Avenne
PO. Rox 6015
Indianapolis, Indiana 46206^01!
Tttivhofie 317-232-8603
Environment!! Helpline 1-0OO-451-6O27
September 29, 1997
Mr. David Ullrich, Acting Regional Administrator
U.S. Environmental Protection Agency, Region 5
77 West Jackson Boulevard
Chicago, Illinois 60604
Dear Mr. Ullrich,
RE: Record of Decison
Final Site Remedy
Tippecanoe Sanitary Landfill, Inc.
Lafayette, Indiana
The Indiana Department of Environmental Management has reviewed the U.S.
Environmental Protection Agency's Proposed Plan for the Tippecanoe Sanitary Landfill, Inc.
Superftind Site. IDEM fully concurs with the major components of the selected remedy for this
site, which include:
- Deed restrictions and fencing;
- Barrier cover;
- Landfill gas collection and control system;
- Remediation of contaminated ground water;
- Leachate collection, treatment, and discharge to a publicly owned treatment works;
We also agree that this alternative attains Federal and State requirements that are
applicable, or relevant and appropriate to this remedy. Because this remedy will result in
hazardous substances remaining on site above health-based levels, a review will be conducted
within five years after commencement of the remedial action to ensure that the remedy continues
to provide adequate treatment of contaminants as well as protection of human health and the
environment. If it is discovered that the remedy is failing in these regards, then another remedy
will need to be instituted. Please be assured that IDEM is committed to accomplishing clean up
An Ri|u«l Opportunity Employer
Primtut on KtejtUd Papa
-------
Tippecanoe Sanitary Landfill, Inc.
Letter of Concurrence
Page 2
of all Indiana sites on the NPL and intends to fulfill all obligations required by law to achieve this
goal.
Sincere!1
Assistant Commissioner
Office of Environmental Response
cc: Robert Moran, IDEM
Patricia Carrasquero, IDEM
Christopher J. Brown, IDEM
Bernard Schorle, US EPA Region V
-------
MO.
1
2
3
4
5
6
7
8
9
10
U.S. ENVIRONMENTAL PROTECTION AGENCY
ADMINISTRATIVE RECORD
FOR
TIPPECANOE SANITARY LANDFILL SITE
LAFAYETTE, INDIANA
ORIGINAL
JULY 24, 1997
DATE
03/08/90
06/14/90
04/17/91
05/00/91
AUTHOR
U.S. EPA
ENSR Consulting
and Engineering
Schorle, B. ,
U.S. EPA
U.S. EPA
RECIPIENT
Respondents
U.S. EPA
File
Publi c
TITLE/DESCRIPTION .'PAGES
Administrative Order 6 3
on Consent re: Remedial
Investigation and
Feasibility Study for
the Tippecanoe Sanitary
Landfill Site
Preliminary Site 82
Evaluation Report for
the Tippecanoe Sanitary
Landfill Site
Conversation Record re: 2
Connections to City Water
w/B. Trillingham (Lafayette
Water Works)
Superfund Fact Sheet re: 7
Tippecanoe Sanitary
Landfill Site
09/00/91
11/14/91
01/00/92
02/00/92
04/00/92
04/28/92
ENSR Consulting
and Engineering
Meschede, L.
and G. Kulma;
ENSR Consulting
and Engineering
U.S. EPA
Schorle, B.,
U.S. EPA
B. Schorle,
U.S. EPA
ENSR Consulting U.S. EPA
and Engineering
ENSR Consulting U.S. EPA
and Engineering
ENSR Consulting U.S. EPA
and Engineering
Meschede, L.,
ENSR Consulting
and Engineering
Project Plans for the 505
Remedial Investigation/
Feasibility Study at the
Tippecanoe Sanitary
Landfill Site
Letter re: Addendum to 3
the Monitor Well Instal-
lation Standard Operating
Procedures
Quality Assurance 580
Project Plan for the
Remedial Investigation/
Feasibility Study at the
Tippecanoe Sanitary
Landfill Site
Source Characterization 324
Technical Memorandum for
the Tippecanoe Sanitary
Landfill Site
Migration Pathway 36 0
Assessment for the
Tippecanoe Sanitary
Landfill Site
Letter re: U.S. EPA and 11
Ecology & Environment's
Comments on the Source
Characterization Technical
Memorandum
-------
NO
11
12
13
14
15
16
17
18
19
20
21
Tipp«cano« AR
Original
Pag* 2
DATS
05/26/92
AUTHOR
Pachowicz, T.,
Ecology and
Environment,
Inc.
RECIPIENT
Schorle, B.,
U.S. EPA
05/26/92 Schorle, B.,
U.S. EPA
Meschede, L.,
ENSR Consulting
and Engineering
05/29/92 Schorle, B.,
U.S. EPA
Meschede, L.,
ENSR Consulting
and Engineering
06/23/92 Schorle, B.,
U.S. EPA
Keramida, V.,
Ontario
Environmental,
Inc.
07/17/92
07/21/92
07/31/92
11/25/92
Schorle, B.,
U.S. EPA
Symonds, S.,
ENSR Consulting
Meschede, L.,
ENSR Consulting
and Engineering
Meschede, L.,
ENSR Consulting
and Engineering
Keramida, V.,
Ontario
Environmental,
Inc.
B. Schorle,
U.S. EPA
B. Schorle,
U.S. EPA
U.S. EPA
B. Schorle,
U.S. EPA
12/04/92
Schorle, B.,
U.S. EPA
Meschede, L.,
ENSR Consulting
and Engineering
12/11/92
Schorle, B.,
U.S. EPA
Meschede, L.,
ENSR Consulting
and Engineering
12/18/92 Meschede, L., B. Schorle,
ENSR Consulting U.S. EPA
and Engineering
TITLE/DESCRIPTION PAGES
Letter re: EfcE's Comments 7
on the Migration Pathway
Assessment Technical
Memorandum
Letter re: U.S. EPA 7
Comments on the Migration
Pathway Assessment
Technical Memorandum
Letter re: Ecology and 3
Environment's Comments on
the Migration Pathway
Assessment Technical
Memorandum
Letter Forwarding 5
Attached IDEM Comments on
the Migration Pathway
Assessment Technical
Memorandum and Dates for
Events in the Remedial
Investigation
Letter re: Sampling at 3
the Tippecanoe Sanitary
Landfill Site
Letter re: Round 1 2
Sample Designation
Telephone Call Summary: 2
Chemical Characterization
Sampling Activities
Letter re: Installation 5
of Three Leachate
Monitoring Wells for the
Remedial Investigation
Letter re: Landfill 2
Cover Investigation and
Miscellaneous Remedial
Investigation
Letter re: U.S. EPA's 3
Comments on the Revised
Addendum for the Field
Sampling Concerning
Leachate Wells
Letter Forwarding 12
Attached Addenda to the
Field Sampling and Health
and Safety Plans for
Additional Investigation
-------
NO
22
23
24
25
26
27
28
29
30
31
32
Tippacano* AR
Original
Pag* 3
DATB
AUTHOR
RBCiriBHT
TITLB/DBSCRIPTION
PAGBS
02/15/93
05/14/93
ENSR Consulting
and Engineering
Meschede, L.,
ENSR Consulting
and Engineering
U.S. EPA
Schorle, B.,
U.S. EPA
Preliminary Data
Transmittal Technical
Memorandum for the
Tippecanoe Sanitary
Landfill Site
Letter Forwarding
Attached Draft Addendum
to Field Sampling Plan
for Additional Landfill
Cover Investigation
222
05/28/93
06/07/93
06/10/93
06/24/93
08/03/93
08/13/93
09/00/93
09/20/93
10/29/93
Schorle, B.,
U.S. EPA
Gorski, W.,
U.S. EPA/
Wetlands
Regulatory Unit
Meyer, D.,
U.S. EPA/Air
Toxics and
Radiation
Branch
Watters, E.,
U.S. EPA/Safe
Drinking Water
Branch
Kasarabada, P.,
IDEM
Schorle, B. ,
U.S. EPA
U.S. EPA/
OSWER
Schorle, B.
U.S. EPA
Keramida, V.,
Keramida
Environmental
Inc.
Meschede, L.,
ENSR Consulting
and Engineering
Figiulo, I.,
U.S. EPA/
Water Divsion
Schorle, B.,
U.S. EPA
Traub, J.,
U.S. EPA/WMD
Wehrman, D.,
Lafayette Bank
& Trust
Meschede, L.,
ENSR Consulting
and Engineering
U.S. EPA
Meyer, D.
U.S. EPA/
Air and
Radiation
Division
Schorle, B.
U.S. EPA
Letter re: U.S. EPA
Approval of Addendum C
to the Phase II Landfill
Cover Investigation
Memorandum re: WRU's
Comments Concerning the
Tippecanoe Sanitary
Landfill Site
Memorandum re: ATR's
Comments on the Draft RI
Report for the Tippecanoe
Sanitary Landfill Site
Memorandum re: WD's
Review of the Draft
RI Report for the
Tippecanoe Sanitary
Landfill Site
Letter re: Installation
of Methane Detectors in
Residences Near the
Tippecanoe Sanitary
Landfill Site
Letter re: Phase II
Landfill Cover
Investigation
Memorandum re:
Presumptive Remedies
Directives
Memorandum re: Request
for ARD's Comments on
on the Air Pathway
Analysis
Letter re: U.S. EPA
Comments on the Air
Pathway Analysis
72
-------
33
34
35
36
37
38
39
40
41
42
43
44
Tippacanoa AR
Original
Page 4
DATS
06/01/94
01/27/95
03/00/95
03/24/95
03/28/95
04/11/95
05/19/95
05/19/95
05/25/95
05/26/95
06/01/95
06/22/95
AUTHOR RECIPIENT
U.S. EPA/ U.S. EPA
Integrated Risk
Information
System
TITLE/DESCRIPTION PAGES
Health Risk Assessment 22
Information re: Arsenic,
Inorganic
Kasarabada, P., Schorle, B.,
IDEM U.S. EPA
Letter: IDEM's Comments 2
on the Final RI Report and
the Alternatives Array
Documents
U.S. EPA
File
Areas to be Considered
for ARARs and TBCs at the
Tippecanoe Sanitary
Landfill Site w/Attached
March 1995 Alternatives
Array Document (U.S. EPA
Version)
35
Schorle, B. Keramida, V.
U.S. EPA Keramida
Environmental
Inc.
Letter re: U.S. EPA's 64
Comments on Revision 2
(November 1994) to the
Alternatives Array
Document
Adamkus, V. , Prosser, K.,
U.S. EPA IDEM
Letter re: U.S. EPA l
Request for Indiana ARARs
for the Tippecanoe
Sanitary Landfill Site
Schorle, B. Addressees
U.S. EPA
Memorandum re: Request 194
for ARARs and TBC's for
the Tippecanoe Sanitary
Landfill Site
Schorle, B.
U.S. EPA
Keramida, V.
Keramida
Environmental,
Inc.
Letter re: Possible
ARARs for the Tippecanoe
Sanitary Landfill Site
Greensley, J. Schorle, B.
U.S. EPA U.S. EPA
Memorandum re: TSCA 2
Applicability to the
Tippecanoe Sanitary
Landfill Site
Schorle, B.
U.S. EPA
Schorle, B.
U.S. EPA
Kasarabada, P.,
IDEM
Kasarabada, P. ,
IDEM
Letter re: Possible
ARARs at the Tippecanoe
Sanitary Landfill Site
Letter re: Possible
ARARs at the Tippecanoe
Sanitary Landfill Site
U.S. EPA/ U.S. EPA
Integrated Risk
Information
System
Schorle, B. Keramida, V.
U.S. EPA Keramida
Environmental,
Inc.
Health Risk Assessment 21
Information re: Arsenic,
Inorganic
Letter re: Potential 5
Federal ARARs for the
Tippecanoe Sanitary
Landfill Site
-------
NO.
45
46
47
48
49
50
51
52
53
54
55
Tippecanoe AR
Original
Page 5
DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
U.S. EPA
Schorle, B.
U.S. EPA
Keramida, V.
Keramida
Environmental,
Inc.
File
07/01/95 U.S. EPA/
Integrated Risk
Information
System
07/12/95 Kasarabada, P
IDEM
08/02/95 Schorle, B.
U.S. EPA
09/12/95 Schorle, B.,
U.S. EPA
09/21/95 Simmons, J.,
Tippecanoe
Sanitary
Landfill PRP
Group
10/02/95 Schorle, B.,
U.S. EPA
10/20/95 Schorle, B.
U.S. EPA
10/23/95 Czajka, T.,
Tippecanoe
Sanitary
Landfill PRP
Group
02/00/96 ENSR Consulting
and Engineering/
Keramida
Environmental,
02/00/96 ENSR Consulting U.S. EPA
and Engineering/
Keramida
Environmental,
Inc.
02/00/96 ENSR Consulting U.S. EPA
and Engineering/
Keramida
Environmental,
Inc.
Schorle, B.
U.S. EPA
Keramida, V.,
Keramida
Environmental,
Inc.; et al.
Keramida, V.,
Keramida
Environmental,
Inc.; et al.
Schorle, B.
& T. Williams,
U.S. EPA
U.S. EPA
Health Risk Assessment 21
Information re: Arsenic,
Inorganic
Letter re: Hazardous and 1
Solid Waste Regulations
Letter re: Feasibility 2
Study for the Tippecanoe
Sanitary Landfill Site
Gas Emissions Estimation 11
for the Tippecanoe
Sanitary Landfill Site
w/Attached Handwritten
Notes and Calculations
Letter re: Notice of 123
Dispute and Statement
of Position w/Attached
Exhibits
Letter re: U.S. EPA's 25
Statements of Position
on the September 1995
Dispute Issues
Letter re: Various Issues 30
Concerning the RI Report
w/Attachments
Letter re: Understanding
of Agreements Reached at
the October 11, 1995
Meeting
Remedial Investigation 34 0
Report for the Tippecanoe
Sanitary Landfill Site:
Volume 1: (Text, Tables
and Figures) [FINAL]
Remedial Investigation 489
Report for the Tippecanoe
Sanitary Landfill Site:
Volume 2 (Appendices A-M)
[FINAL]
Remedial Investigation 385
Report for the Tippecanoe
Sanitary Landfill Site:
Volume 3A (Appendices N-V)
[FINAL]
-------
NO.
56
57
58
59
60
61
62
63
64
65
66
Tippecanoe AR
Original
Page 6
DATE
02/00/96
02/29/96
05/31/96
06/00/96
07/01/96
07/10/96
08/15/96
10/20/96
02/25/97
03/17/97
04/03/97
AUTHOR RECIPIENT TITLE/DESCRIPTION PAGES
ENSR Consulting U.S. EPA
and Engineering/
Keramida
Environmental,
Inc.
Keramida, V. , Schorle, B.,
Keramida U.S. EPA
Environmental
Inc.
Remedial Investigation 6 56
Report for the Tippecanoe
Sanitary Landfill Site:.
Volume 3B: (Appendices ~W-Z)
[FINAL]
Letter re: Revised 7
Table 5-1 for the Remedial
Investigation Report
Schorle, B., Keramida, V. ,
U.S. EPA Keramida
Environmental,
Inc.
Letter re: U.S. EPA's 55
Disapproval of the
February 1996 Remedial
Investigation Report for
the Tippecanoe Sanitary
Landfill Site w/Attached
U.S. EPA Comments
Keramida
Environmental,
Inc.
U.S. EPA
Feasibility Study 246
Report for the Tippecanoe
Sanitary Landfill Site
(DRAFT)
Schorle, B. ,
U.S. EPA
Kasarabada, P.,
IDEM
Letter re: U.S. EPA's
Comments on the Draft
Feasibility Study for the
Tippecanoe Sanitary
Landfill Site
18
Schorle, B., Kasarabada, P., Letter re: U.S. EPA
U.S. EPA IDEM Comments on the Revised
Draft Feasibility Study
for the Tippecanoe
Sanitary Landfill Site
Kasarabada, P., Schorle, B.,
IDEM U.S. EPA
Letter: IDEM's Comments 2
on the ARARs Section of
the Draft Feasibility
Study
U.S. EPA/ U.S. EPA
Integrated Risk
Information
System
Keramida, v., Schorle, B.,
Keramida U.S. EPA
Environmental,
Inc.
Health Risk Assessment 34
Information re: Manganese
Letter re: U.S. EPA l
Recommendation to Use
Two CLP Laboratories
for the Analyses of the
Proposed Sampling
Keramida, V. , Schorle, B.,
Keramida U.S. ~PA
Environmental,
Inc.
Letter re: ENSR's 16
Proposal for Sampling
Activities
Keramida, V., Schorle, B.
Keramida U.S. EPA
Environmental,
Inc.
Letter re: CLP Labora- 7
tories Comments on the
QAPP
-------
Tippecanoe AR
Original
Page 7
NO. DATE
AUTHOR
RECIPIENT
67 04/14/97
Keramida, V.,
Keramida
Environmental,
Inc.
Schorle, B.,
U.S. EPA
68 04/18/97
Schorle, B.
U.S. EPA
Keramida, V.,
Keramida
Environmental,
Inc.
69 05/02/97
B. Schorle,
U.S. EPA
Dale, D.,
Keramida
Environmental
Inc.
70 07/02/97
Ferguson, G. ,
ENSR Consulting
and Engineering
Keramida, V.,
Keramida
Environmental,
Inc.
71 07/09/97 Schorle, B.,
U.S. EPA
Keramida, V.,
Keramida
Environmental,
Inc.
72 07/11/97
Schorle, B.,
U.S. EPA
Keramida, V.,
Keramida
Environmental,
Inc.
73 07/14/97
Ferguson, G.,
ENSR Consulting
and Engineering
Keramida, V.,
Keramida
Environmental,
Inc.
74 07/22/97 Schorle, B., File
U.S. EPA
TITLE/DESCRIPTION PAGES
Letter re: Survey 4
Results and Revised
Schedule of Activities ..
Letter re: Additional 5
Sampling
Letter re: Additional 1
Sampling
Data Validation Report: 137
Round 3 Groundwater
Samples for the Tippe-
canoe Sanitary Landfill
Site
Letter re: U.S. EPA's 25
Conditional Approval for
the Listed Documents to
Constitute the Remedial
Investigation Report fcr
the Tippecanoe Sanitary
Landfill Site w/Attachments
Letter re: U.S. EPA's 77
Conditional Approval for
the Listed Documents to
Constitute the Feasibility
Study Report for the
Tippecanoe Sanitary
Landfill Site w/Attachments
Data Transmittal Letter 22
re: Groundwater Monitoring
Activities at the
Tippecanoe Sanitary
Landfill Site
Memorandum: Applicable 11
Guidance Documents for
the Tippecanoe Sanitary
Landfill Site
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
ADMINISTRATIVE RECORD
FOR
TIPPECANOE SANITARY LANDFILL SITE
LAFAYETTE, TIPPECANOE COUNTY, INDIANA
UPDATE #1
SEPTEMBER 30, 1997
NO. DATE
1 05/00/90
2 09/00/93
3 09/26/94
4 07/00/97
5 07/00/97
6 07/17/97
7 07/25/97
8 07/28/97
9 07/29/97
author
U.S. EPA/
OERR
U.S. EPA/
OSWER
U.S. EPA/
Hazardous Site
Control
Division
U.S. EPA
U.S. EPA
Rose, J. ,
IDEM
Brown, C.,
IDEM
U.S. EPA
Schorle, B.,
U.S. EPA
RECIPIENT
U.S. EPA
U.S. EPA
U.S. EPA
TITLE/DESCRIPTION
PASES
Public
Public
Schorle, B.,
U.S. EPA
Schorle, B.,
U.S. EPA
Public
Dale, D.,
Keramida
Environmental,
Inc.
Site Analysis for the
Tippecanoe Sanitary
Landfill Site
Memorandum re:
Presumptive Remedies
Directives
Memorandum re: Feasi-
bility Study Analysis
and Administrative
Record for Presumptive
Remedies
Proposed Plan for the
Tippecanoe Sanicary
Landfill Site
Fact Sheet: U.S. EPA
Recommends Cleanup Plan
for the Tippecanoe
Sanitary Landfill Site
Letter re: IDEM's
Comments on the Proposed
Plan for the Tippecanoe
Sanitary Landfill Site
Letter re: IDEM's
Comments on the May 1997
Split Sampling Event at
the Tippecanoe Sanitary
Landfill Site
Public Notice re:
Announcement of Public
Comment Period on the
Proposed Plan for the
Tippecanoe Sanitary
Landfill Site
Letter re: U.S. EPA's
Comments on the Data
Validation Report for
Round 3 Sampling at the
Tippecanoe Sanitary
Landfill Site
21
51
18
-------
Tippecanoe AR
Update #1
Page 2
HO*.
10
DATE
08/05/97
11
08/06/97
12 08/22/97
13 08/26/97
14
09/25/97
15
00/00/00
AUTHOR
Margerum, S.
and D. Heath;
Tippecanoe
Sanitary
Landfill PRP
Group
U.S. EPA
Margerum, S.
and D. Heath;
Tippecanoe
Sanitary
Landfill PRP
Group
Concerned
Citizens
Brown, C.,
IDEM
U.S. EPA
RECIPIENT
Kimbrough, D.,
U.S. EPA
TITLE/DESCRIPTION
PA
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