EPA Region 5 Records Ctr.
361055
Five-Year Review Report
Third Five-Year Review Report
for
Columbus Old Municipal Landfill #1
Columbus, Bartholomew County, Indiana
May 2010
Prepared by:
United States Environmental Protection Agency
Region 5
Chicago, Illinois
Approved by:
jcLcl C \ZjL-
Richard C. Karl, Director
Superfund Division
Date:
8~/o
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Table of Contents
List of Acronyms
Executive Summary
Five-Year Review Summary Form
I. Introduction 1
II. Site Chronology 2
III. Background 2
Physical Characteristics
Land and Resource Uses
History of Contamination
Initial Responses
Basis for Taking Action
IV. Remedial Action 5
Remedy Selected
Remedy Implementation
Institutional Controls
V. Progress Since the Last Five-Year Review 9
VI. Five-Year Review Process 9
Administrative Components
Community Notification and Involvement
Document Review
Data Review
Site Inspection
VII. Technical Assessment 11
Question A. Is the remedy functioning as intended by the decision documents?
Question B. Are the exposure assumptions, toxicity data, clean-up levels, and remedial action
objectives used at the time of the remedy selections still valid?
Question C. Has any other information come to light that could call into question the
protectiveness of the remedy?
Technical Assessment Summary
VIII. Issues 11
IX. Recommendations and Follow-Up Actions 12
X. Protectiveness Statement 12
XI. Next Review 12
Figure 1. OCL Site 13
Table 1. Some Results for Monitored Parameters in Last Years of Monitoring 14
Table 2. Maximum Concentrations between December 1993 and December 1995 16
Attachment 1. Declaration of Restrictions and Covenants Upon Real Estate 17
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List of Acronyms
AOC Administrative Order on Consent
ARARs applicable or relevant and appropriate requirements
BLS below land surface
CD Consent Decree
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
EPA United States Environmental Protection Agency
FS feasibility study
FWQC federal water quality criteria
GRSC groundwater recovery system contingency
IC institutional control
IDEM Indiana Department of Environmental Management
IRA interim remedial action
LC'50 lethal concentration that kills 50% of test subjects in a given time
MCL maximum contaminant level
MDL method detection limit
MSL mean sea level
MW monitoring well
NCP National Contingency Plan
NPL National Priorities List
OCL Columbus Old City Municipal Landfill #1
PCBs polychlorinated biphenyls
PRP potentially responsible party
RA remedial action
RD remedial design
RI remedial investigation
ROD Record of Decision
SMCL secondary maximum contaminant level
SOW statement of work
SPM state project manager
SVOC semi-volatile organic compound
TOC total organic carbon
TPH total petroleum hydrocarbons
UU/ UE unlimited use or unrestricted exposure
VOC volatile organic compound
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Executive Summary
The remedy for the Columbus Old Municipal Landfill #1 (OCL) site in Columbus, Bartholomew
Count) , Indiana, included: fence installation with appropriate warning signs, landfill cover
inspection and maintenance program, groundwater recovery system contingency plan, additional
groundwater monitoring wells, groundwater monitoring program, and institutional controls
restricting the use of the land and groundwater at the site. The site achieved construction com-
pletion with the signing of the Preliminary Close Out Report on September 15, 1994. The trigger
for this review was the completion of the second five-year review report on September 23, 2005.
Based upon the November 18, 2009 site inspection conducted for this five-year review, there are
no current exposures to human health and the environment. Since groundwater monitoring
ceased in 2003 because levels of contamination had remained at or below MCLs, there was no
new data to review for this five-year review.
The selected remedy is functioning as anticipated. The remedy is protective of human health and
the environment in the short-term and will be protective in the long-term once all institutional
controls (ICs) have been implemented. Specifically, an Environmental Protection Easement and
Environmental Restrictive Covenant for the northwestern part of the landfill is necessary and
must be recorded. Long-term protectiveness will be achieved once these required ICs have been
implemented. Compliance with effective ICs will be ensured by implementing effective ICs
which must be maintained, monitored and enforced by developing long-term stewardship
procedures as well as maintaining the site remedy components. Threats at the site are being
addressed through implementation of the required ICs and continued maintenance of the site.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name (from CERCLIS): Columbus Old Municipal Landfill #1
EiPA ID (from CERCLIS): rND980607626
Region: 5
State: IN
City/County: Columbus/Bartholomew County
SITE STATUS
NPL status: x_ Final _ Deleted __ Other (specify).
Remediation status (choose all that apply): __ Under construction _x_ Operating _ Complete
Multiple OUs?* _ Yes x No
Construction completion date: 9/15/94
Has site been put into reuse? x Yes _ No
REVIEW STATUS
Lead Agency: _x_ EPA _ State _ Tribe _ Other Federal Agency.
Author name: Bernard J. Schorle
Author title: Remedial Project Manager
Author affiliation: U. S. EPA, Region 5
Review period:** 9/05 to 4/10
Date(s) of site inspection: 11/18/09
Type of review: _x_ Post-SARA
Non-NPL remedial action site
Regional discretion
Pre-SARA
NPL State/Tribe-lead
NPL-removal only
Review number: _ 1 (first) _ 2 (second) x 3 (third) _ Other (specify).
Triggering action:
_ Actual RA on-site construction at OU #.
_ Construction completion
_ Other (specify)
_ Actual RA start at OU #
x Previous five-year review report
Triggering action date (from CERCLIS): 9/23/05
Due date: 9/23/10
*--"OU" refers to operable unit
**~Review period should correspond to the actual start and end dates of the five-year review in CERCLIS
Issues:
a) not all of the use restrictions have been implemented;
b) long-term stewardship of the site must be assured through development and implementation of an IC Plan for
monitoring compliance with the ICs.
Recommendations and Follow-up Actions:
a) Implement use restrictions for Parcel 1 by having the Environmental Protection Easement and Environmental
Restrictive Covenant recorded.
b ) Put into place an IC Plan or an update of the Maintenance Plan that will provide for monitoring of the ICs.
Protectiveness Statement(s): The selected remedy is functioning as anticipated. The remedy is protective of human
health and the environment in the short-term and will be protective in the long-term once all institutional controls
(ICs) have been implemented. Specifically, an Environmental Protection Easement and Environmental Restrictive
Covenant for the northwestern part of the landfill is necessary and must be recorded. Long-term protectiveness will
be achieved once these required ICs have been implemented. Long-term protectiveness also requires compliance
with effective ICs. Compliance with effective ICs will be ensured by implementing effective ICs which must be
maintained, monitored and enforced by developing long-term stewardship procedures as well as maintaining the site
remed} components. Threats at the site are being addressed through implementation of the required ICs and
continued maintenance of the site.
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Columbus Old Municipal Landfill #1 Superfund Site
Columbus, Bartholomew County, Indiana
Third Five-Year Review Report
I. Introduction
The purpose of the five-year review is to determine whether the remedy at a site is protective of
human health and the environment. The methods, findings, and conclusions of the review are
documented in a five-year review report. In addition, the five-year review report identifies issues
found during the review, if any, and provides recommendations to address them.
The U.S. Environmental Protection Agency (EPA) is preparing this five-year review report
pursuant to Section 121 of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), 42 U.S.C. § 9621, and the National Contingency Plan (NCP) (40 Code
of Federal Regulations (CFR) Part 300). CERCLA Section 121 states:
If the president selects a remedial action that results in any hazardous substances, pollutants, or
contaminants remaining at the site, the President shall review such remedial action no less often
than each 5 years after the initiation of such remedial action to assure that human health and the
environment are being protected by the remedial action being implemented. In addition, if upon
such review it is the judgment of the President that action is appropriate at such site in accordance
with section 104 or 106, the President shall take or require such action. The president shall report
to the Congress a list of facilities for which such review is required, the results of all such reviews,
and any actions taken as a result of such reviews.
The Agency interpreted this requirement further in the NCP; 40 CFR Section 300.430(f)(4)(ii)
states:
If a remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead
agency shall review such action no less often than every five years after the initiation of the
selected remedial action.
IDEM and EPA Region 5 have conducted this five-year review of the remedy implemented at the
Columbus Old Municipal Landfill #1 (also known as the "Old City Landfill") Superfund site
(OCL) in Columbus (Bartholomew County), Indiana. This review was conducted for the entire
site by the remedial project manager and the state project manager for the period from September
2005 through April 2010. This report documents the results of the review.
This is the third five-year review for the OCL site. The triggering action for this statutory review
is the completion of the second five year review report on September 23, 2005. The five year
review is required due to the fact that hazardous substances, pollutants, or contaminants remain
at the site above levels that allow for unlimited use or unrestricted exposure.
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II. Site Chronology
Event
Date
Landfill Operations
1938-1966
Proposed for placement on the National Priorities List (NPL)
9/18/85
Final on the NPL
6/10/86
Administrative Order on Consent for remedial investigation (Rl) and feasibility study
(FS)
9/15/87
RI and FS started
9/15/87
RI report approved
8/6/90
FS report approved
12/1/91
Proposed Plan issued
1/23/92
Public meeting held
1/30/92
Record of Decision (ROD) signed
3/31/92
Indiana Department of Environmental Management (IDEM) became lead agency
5/26/92
Consent Decree for remedial design (RD) and remedial action (RA)
entered 4/16/93
RD starts
April 1993
Restrictions placed on deed for part of the facility property (9.7 acres)
6/2/93
RA starts
10/22/93
Preliminary Close Out Report (construction completion under CERCLA)
9/15/94
Fence installation completed
5/7/99
New bridge and approach road over the landfill completed
May 1999
First five-year review report
9/22/00
Interim remedial action (IRA) report approved
4/8/02
Second five-year review report
9/23/05
Site inspection by EPA and IDEM for third five-year review
11/18/09
III. Background
Physical Characteristics
OCL is located in the City of Columbus, Indiana, at the intersection of the East Fork of the White
River and State Road 11. The portion of the site containing waste material parallels the river,
which flows southeast. The site covers approximately 19 acres. The landfill was covered with a
layer of sand, clay, and gravel after the landfill was closed. Grass provides a vegetative cover.
The cover material is generally 2 to 3 feet in thickness across the site, reaching 4 to 5 feet in
some places. The depth of the landfill material averages approximately 17 feet over the area of
the landfill. The total volume of the fill material within the landfill was estimated to be about
500,000 cubic yards. Land surface elevations range from approximately 625 feet above mean sea
level (MSL) at the top of the fill area to 600 feet above MSL at the river. The maximum depth at
which the bottom of the landfill materials were found was at elevation 602 ft. See Figure 1 for a
map showing the area of the site.
The uppermost natural deposit of unconsolidated material at the site consists of coarse sand- and
gravel-sized material. The sand and gravel deposit extends to a depth of approximately 15 feet
below the natural land surface. Underlying the sand and gravel deposit is an intermittent thin
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sandy clay and gravel zone (glacial till) approximately 2 to 3 feet thick. The thin till zone is
underlain by a very coarse sand and gravel deposit which is approximately 15 feet thick. This
sand and gravel deposit was found to be continuous across the site. At a depth of approximately
50 to 35 ft below land surface (BLS) (elevation 580-575 ft.), silts and clays containing organic
material become prominent. Lenses and thin beds of very fine to coarse grained sand containing
silt are mixed throughout this zone. Underlying the silt and clay zone is a firm deposit of silt and
clay mixed with pebbles (glacial till). This deeper till deposit lies at a depth of approximately 40
lo 45 feet BLS (elevation 570-565 ft.). Based on the soil borings completed in 1968 for the City
of Columbus, this till unit is believed to extend to the shale bedrock interface.
The groundwater flow direction is generally to the south-southeast. Depth to groundwater in the
OCL area is approximately 5 to 15 feet BLS. At the landfill, where the fill operations have raised
the elevation of the land surface, the depth to ground water varies from 15 to 25 feet below the
sur face of the landfill. The gravel quarry, located near the southeast corner of the OCL, and the
East Fork of the White River both function as discharge points for the ground water that passes
through the shallow aquifer beneath the site. Based on data from the RI, water table elevation
fluctuations have generally not altered the groundwater flow direction and horizontal hydraulic
gradients, except for the areas near the river and the quarry.
Approximately 33,000 people live within a 3-mile radius of the site. There are private and public
water supply wells located within 2 to 3 miles. The OCL site is located in the 100-year flood
plain of the river.
Land and Resource Uses
The site forms a low barrier between the farmlands that surround it and the East Fork of the
White River to the east. Within the property boundary was the municipal landfill, a shooting
range, and a quarry The shooting range, located on the northwest portion of the property, was
used during the 1960s. The quarry, located on the southeast portion of the property, was used
until late 1998. Adjacent to the west side of the site, the land is still being used for farming. Part
of the landfill was utilized for the construction of a new road and bridge across the East Fork of
the White River that was completed in April 1999.
History of Contamination
The City of Columbus operated OCL as a municipal landfill from 1938 until 1966. The landfill
reportedly accepted municipal and industrial wastes, including solvents, acids, bases, paints and
heavy metals. The wastes were deposited within the unlined landfill. The site was proposed for
inclusion on the National Priorities List (NPL) in September 1985, and included as final in June
1986.
Initial Response
In 1987, an Administrative Order on Consent (AOC) became effective between EPA, IDEM, and
several of the potentially responsible parties (PRPs) requiring that a remedial investigation (RI)
and a feasibility study (FS) be conducted for the site.
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The surface and subsurface on-site soil analyses indicated the presence of chloroform, methyl
ethyl ketone, acetone, and methylene chloride. All other volatile organic compounds (VOCs)
were below the method detection limits (MDLs). All semi-volatile organic compounds (SVOCs)
analyzed for were also below MDLs. Cadmium and mercury were the only inorganics detected
above background soil levels.
Groundwater samples collected from the twelve on-site monitoring wells and the background
well were analyzed for target compounds. The samples did not contain any VOCs above MDLs
that were probably not laboratory contaminants. Four SVOCs were detected above MDLs during
the two sampling rounds. In the first round of sampling, 2.4-dimethylphenol (23 jj.g/1),
naphthalene (110 jxg/1), and 2-methylnaphthalene (6.63 jj.g/1) were detected above MDLs in one
groundwater sample, but there were no SVOCs detected in the sample from this well during the
second round. Bis(2-ethylhexyl)phthalate was detected above MDLs in one sample in the second
round of groundwater sampling. Seventeen inorganics (of the twenty-three analytes on the list)
were detected in at least two groundwater samples, including cadmium and lead.
The landfill material was also sampled during the RI. VOC constituents detected in the waste
material samples included: benzene, ethylbenzene, methylene chloride, toluene, acetone, carbon
disulfide, methyl ethyl ketone, methyl isobutyl ketone, and xylene. Semi-volatile constituents
found in the landfill material included: fluoranthene (4.9 mg/kg), phenanthrene (6.7 mg/kg),
pyrene (3.6 mg/kg), naphthalene (8.2 mg/kg), and 2-methylnapthalene (2.3 mg/kg). Three of the
eight samples analyzed for SVOCs had detections above MDLs. Pesticides and polychlorinated
biphenyls (PCBs) detected included: 4,4'-DDD (estimated concentration~57 mg/kg), alpha-
chlordane (maximum concentration—93 mg/kg), and Aroclor 1254 (estimated concentration—
0.84 mg/kg). The inorganic analyses indicated the presence of cadmium (24 mg/kg), nickel (95
mg/kg), mercury (0.36 mg/kg), and lead (estimated at 21,700 mg/kg).
A number of inorganic and organic constituents were detected during the remedial investigation
in groundwater, surface water, and soils in the vicinity of the landfill. The presence of these
constituents may have been due to migration of leachate from the landfill materials. There were
no on-site exposure points to the groundwater at the site. Hypothetical future use of the
groundwater as a potable source (assuming concentrations present during the RI occur at off-site
downgradient wells) would result in exposure within acceptable health-based guidelines. Current
(at the time of the RI) and hypothetical future exposure to the surficial soils were estimated to be
within acceptable health-based guidelines. Although no residential properties were located on
the site at the time of the RI, and no homes were likely to be built on the landfill within the
reasonably foreseeable future, the hypothetical future exposure of an adult or child to surface
soils was considered and this resulted in acceptable levels of estimated risk based on
non-carcinogenic effects and potentially acceptable estimates of excess lifetime cancer risk.
The environmental risks posed by the constituents of concern were judged to be minimal. All
constituents detected in surface water were below background concentrations, federal water
quality criteria (FWQC), or laboratory-tested chronic LC50 results. Constituents found in sedi-
ments did not vary significantly from typical background levels and therefore were not con-
sidered to pose a hazard to aquatic life.
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Basis for Taking Action
Based 011 the results of the RI, EPA concluded that no further action, except for the installation of
two additional monitoring wells and periodic monitoring of groundwater, was needed at the site.
H owever, it was also concluded that some action would be needed if the road leading to a new
bridge over the river, which was contemplated to be built across the landfill, was built.
IV. Remedial Action
Remedy Selected
On March 31, 1992, EPA issued a Record of Decision (ROD) for the OCL site. The ROD stated
that the investigation of the site had shown that the landfill, in its condition at the time, was
within acceptable health-based and environmental quality-based guidelines. Since the site did
not pose an unacceptable risk, the selected remedy was " 'No Action' (modified)." This primary
remedy called for a minimum of two additional groundwater monitoring wells and groundwater
monitoring for a minimum of five more years. This is not a no action decision since it called for
an action, the installation of additional monitoring wells; however, a no action decision can
require monitoring. Even though wastes remained at the site, this primary remedy did not require
that institutional controls, in the form of restrictions on land and water use, be sought;
institutional controls cannot be required in a no action decision.
The ROD also included a contingent remedy, referred to as Alternative 2A, if the planned road
leading to the new bridge were built over the landfill. Although studies suggested that
construction of the roadway should not pose any unacceptable risks, it was not possible to fully
predict future site conditions with the roadway in place, so this contingent remedy was identified.
There w as a concern that more leachate could be generated due to compression of soils and
waste material from the added weight that would result from the presence of the road; this could
potentially further contaminate the groundwater. The contingent remedy was implemented
because the road and bridge project was built. This contingent remedy included fence
installation with warning signs, landfill cover inspection and maintenance, development of a
contingent groundwater recovery system implementation plan, additional groundwater
monitoring wells, a groundwater monitoring program, and deed restrictions on land and water
use at the site. IDEM concurred on the selected remedy. IDEM and three of the PRPs, including
the City of Columbus, signed a Consent Decree (CD), which was entered in April 1993, to
implement the remedy. The CD required land- and groundwater-use restrictions at the site by
recording declarations of restrictions and covenants upon real estate. The ROD also said that
EPA w ould request the local municipality to enact a zoning ordinance to forbid use of the site
and restrict drilling of groundwater wells. However, this additional layer of control through the
use of a zoning ordinance was not pursued because the City of Columbus and the other site
owners agreed to restrict use of the site and prohibit installation of groundwater wells at the site
by recording restrictions to their real estate.
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Remedy Implementation
Two additional monitoring wells (MW-24 and MW-25) were installed in November 1993 down-
gradient of the site.
Attachment I of the CD Scope of Work (SOW) identified groundwater sampling analytes for the
monitoring program, which included iron, manganese, lead, arsenic, total petroleum hydro-
carbons (TPH), and total organic carbon (TOC). Groundwater monitoring and inspection of the
site was initiated in December 1993 and continued on a bi-monthly basis until six months after
bridge construction was completed, through October 1999. For the monitoring program, thirteen
wells were sampled. Criteria for implementation of the groundwater recovery system
contingency (GRSC) plan were designated in the CD. GRSC implementation would be
necessary if the groundwater from an individual well exceeded a maximum contaminant level
(MCL) for a target compound in two confirmatory samples. It was never necessary to implement
the GRSC plan since the concentrations of the target compounds have been below the MCLs.
There were some detections of iron and manganese that exceeded the secondary maximum
contaminant levels (SMCLs). Esthetics such as taste and odor are addressed by SMCLs (these
are not associated with any health risks). Based on the review of the analytical results in 1999,
the monitoring and site inspection schedule was changed to semi-annually, and this continued
until April 2003.
A "Declaration of Restrictions and Covenants Upon Real Estate" was signed by the land owners,
two individuals and a trust, on June 2, 1993. This restricted groundwater and land use for part of
the site, consisting of approximately 9.7 acres. This Declaration covers only the landfill area
southeast of the new roadway. This was recorded with the county on June 7, 1993. No recorded
restrictions for the remaining area of the site, which is owned by the City of Columbus, have
been established.
The site achieved construction completion with the signing of the Preliminary Close Out Report
on September 15, 1994.
Bridge and roadway construction began in April 1998. The final design for the bridge called for
the western abutment of the bridge to be located at the northwest portion of the landfill. A
portion of the landfill was excavated while IDEM staff were at the site. As a health and safety
precautionary measure, the bridge contractor monitored the ambient air during the soil
excavation. The excavated soil was temporarily staged at the site and was covered and tested.
Based on the soil analytical data, the excavated soil was suitable as fill material for the approach
road that was built across the landfill.
Fence installation was completed in May 1999, prior to opening the road and bridge to the
public. Instead of the six-foot fence called for in the SOW of the CD, the four-foot fence
requested by the city, with the approval of IDEM, was installed.
An interim remedial action (IRA) report was completed in March 2002. The PRP Group has
submitted a final remedial action report. Before this can be accepted, the remaining restrictive
covenant for the city-owned parcels of the site needs to be implemented. Additional follow-up
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actions to be implemented at the site include remedial work completion by the PRP Group and
certification by IDEM staff. Maintenance and monitoring of the site will continue, as needed,
and will consist of activities specified in the CD. Since waste remains on the site, five year
reviews will continue to be required.
Institutional Controls
Institutional controls (ICs) are required to ensure the protectiveness of the remedy. ICs are
non-engineered instruments, such as administrative and/or legal controls, that help minimize the
potential for exposure to contamination and that protect the integrity of the remedy. Compliance
with ICs is required to assure long-term protectiveness for any areas which do not allow for
unlimited use or unrestricted exposure (UU/UE).
The approximately 19 acre site is comprised of two parcels. The northwestern parcel of
approxi mately 9.5 acres is owned by the Board of Public Works and Safety for the City of
Columbus (Parcel 1). The southeastern parcel contains approximately 9.7 acres and is jointly
owned by private individuals and trusts (Parcel 2). The site is within the flood plain of the East
Fork of the White River and is fenced as part of the remedy.
The specific areas which do not allow for UU/UE are summarized in the following table.
Institutional Controls Summary Ta
)le
Media, Engineered Controls, and
Areas That Do Not Support
UU/UE Based on Current
Conditions
IC Objective
Title of Institutional Control
Instrument Implemented
Constructed landfill cover and
surface area of property southeast
of the new roadway (approx. 9.7
acres)
No interference of any sort with
construction, operation,
maintenance, monitoring, and
efficacy of all components and
structures and improvements
resulting from or relating to the
remedial actions implemented. No
agricultural, recreational,
residential, commercial, or
industrial use of the property
including, but not limited to, any
excavation, grading or other
activity involving movement of
soils at the site, and any
construction or placement of any
residences, buildings, or structures
other than for the purpose of
implementing, monitoring, and
maintaining the response action
required.
Declaration of Restrictions and
Covenants Upon Real Estate,
recorded in Bartholomew County
on June 7, 199.3.
Groundwater for area of property
southeast of the new roadway.
Prohibit use of groundwater.
Same as above.
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Media, Engineered Controls, and
Areas That Do Not Support
UU/UE Based on Current
Conditions
IC Objective
Title of Institutional Control
Instrument Implemented
Constructed landfill cover and
surface area of property under the
new roadway and northwest of it
(approx. 9.5 acres).
No interference of any sort with
construction, operation,
maintenance, monitoring, and
efficacy of all components and
structures and improvements
resulting from or relating to the
remedial actions implemented. No
agricultural recreational,
residential, commercial, or
industrial use of the property
including, but not limited to, any
excavation, grading or other
activity involving movement of
soils at the site, and any
construction or placement of any
residences, buildings, or structures
other than the purpose of
implementing, monitoring, and
maintaining the response action
required.
Restrictive Covenant and Easement
planned.
Groundwater for area of property Prohibit use of groundwater,
under the new roadway and
northwest of it.
Restrictive Covenant and Easement
planned.
As noted in the above summary table, there is a Declaration of Restrictions and Covenants Upon
Real Estate for the southeastern part of the landfill property (Parcel 2) that was recorded in
Bartholomew County on June 7, 1993 (Attachment 1). The restrictions included in this
document are summarized in the table. No ICs currently exist for the northwestern part of the
landfill property.
Since the prior five-year review, the following IC activities have occurred: an IC evaluation by
the PRPs, including having a surveyor create a map of the landfill boundaries; a title search; and
a title commitment. The IC evaluation confirmed that the Declaration of Restrictions and
Covenants for the southeastern part of the site has been recorded and appears in the title records
for the site. Parcel 1, the northwestern part of the landfill, including the road right-of-way, is
now the property of the City of Columbus. The IC evaluation confirmed that the city has not
recorded a restrictive covenant for its portion of the site. EPA and IDEM are working with the
city to obtain an Environmental Protection Easement and Environmental Restrictive Covenant
that will provide restrictions similar to those that are on Parcel 2.
Current Compliance
As stated, the ICs have been implemented for Parcel 2 (the southeastern part of the site) but not
for the northwestern part of the site. The ICs for Parcel 1 are under development. Based on the
inspection, EPA is not aware of any uses of the site, including groundwater uses, which are
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inconsistent with the objectives of the institutional controls. Site access restrictions, as well as
groundwater restrictions, appear to be functioning as intended other than occasional trespassing
and unauthorized dumping of such things as furniture and tires.
Long-Term Stewardship Plan
Since compliance with the ICs is necessary to assure the protectiveness of the remedy, long term
stewardship is required as a part of an IC Plan. Long term stewardship involves assuring
effective procedures are in place to properly maintain and monitor the site. The IC Plan should
address the options to ensure long-term stewardship, which for this site will likely be either a
long -term stewardship plan or a modification of the landfill maintenance plan.
V. Progress Since the Last Five-Year Review
This is the third five year review for the site. The previous five-year review determined that the
remedy was protective in the short term and the only issue that arose from the review was the
need to implement some ICs.
Since the last review, the PRP Group has been maintaining the site in accordance with the CD
and SOW. The PRP Group has also conducted the following IC activities, which are discussed
above: produced a new map which shows the landfill boundaries and obtained a title search and a
title commitment. Additional IC work remains.
During June 2008 there was significant flooding along the East Fork of the White River and the
site w as flooded. The PRP Group conducted an inspection of the site subsequent to the flooding
and found no damage to the integrity of the cap.
VI. Five-Year Review Process
Administrative Components
EPA's RPM has been working with IDEM's Project Manager on a continuing basis over the past
five years. The ROD, the remedial investigation report, the feasibility study report, the Consent
Decree, the previous five-year review reports, and the RPM's site documentation completed as
part of regular interaction with IDEM has been utilized for completion of this review.
Community Notification and Involvement
EPA placed an advertisement in The Republic (Columbus, IN) on March 27, 2010, announcing
that a five-year review was to take place. This ad stated that the review was an opportunity for
members of the public to tell EPA about site conditions and any concerns that they have.
One comment was received as a result of the advertisement. The writer stated that she thought
that using the Superfund site for the new bridge into Columbus was a wonderful idea. She also
said that she is not aware of any problems or issues with the site and that it has become one of the
most photographed spots in the city because of the striking bridge design. She also mentioned
OCL Site-Five-Year Review Report
-9-
May 2010
-------
that it was a long and difficult process to receive approval for the current use.
A notice will be sent out informing the public of the completion of the review and the availability
of the report once the report is signed.
Document Review
For the review, the ROD, the remedial investigation report, the feasibility study report, the
Consent Decree, the previous five-year review reports, and the remedial project manager's notes
have been consulted.
Data Review
The specific objective of the groundwater monitoring for the site was to determine whether or not
groundwater contamination was increasing significantly due to the placement of the road across
the site. This was accomplished by monitoring the concentrations of some target metals, total
organic carbon (TOC), and total petroleum hydrocarbons (TPH). Groundwater samples were
collected from thirteen monitoring wells and analyzed for TOC, TPH and four target metals. A
review of the analytical data through April 2003 indicated that TOC and TPH and target metal
concentrations in the individual monitoring wells were generally below historic or background
values over the last five years. However, there were exceedences of secondary maximum con-
taminant levels (SMCLs) for manganese and iron in some wells. SMCLs are not related to health
risks but are related to the esthetics of the water such as odor and taste. The concentrations
observed for manganese and iron do not pose any risk to human health.
Groundwater is no longer being monitored so there was no new data to review during this five-
year period. The results of the groundwater monitoring for the period following the selection of
the remedy through the last monitoring event were presented in the 2005 five-year review report.
These tables are included here. Table 1 presents the results for the analyses of the groundwater
samples for the last nine monitoring events. Table 2 shows the maximum contamination values
in the monitoring wells during the first couple of years of monitoring following the selection of
the remedy. These are the concentrations that were not to be significantly exceeded.
Site Inspection
A five-year review site inspection was conducted by the EPA and IDEM project managers and a
representative of the PRP Group on November 18, 2009. The site was in satisfactory condition.
The site has a considerable amount of vegetation on the cover, including trees. The surface
appears to be in satisfactory condition, with a small amount of wastes having been left on the
surface. The fence along the farm field to the southwest was in good condition. There is
evidence that trespassers do enter the site, at least at the southern end, not only to leave wastes
but to use the property for recreation and to get access to the river bank. The fact that people are
going onto the site does not affect protectiveness of the remedy: the cover on the site and the lack
of access to the groundwater prevents contact with contamination. There is a pipe gate at this
location, but this has not stopped unauthorized entry in this area.
OCL Site-Five-Year Review Report
-10-
May 2010
-------
VII. Technical Assessment
Question A. Is the remedy functioning as intended by the decision documents?
Yes. The remedy is functioning as intended. Construction and use of the approach road and the
bridge at the OCL site does not show any adverse impacts. When groundwater monitoring was
discontinued, those parameters with primary standards were at concentrations below these
standards. Long-term protectiveness also requires compliance with effective ICs. Not all of the
ICs have been implemented. Compliance with effective ICs will be ensured by implementing
effective ICs and maintaining, monitoring, and enforcing them by developing long-term
stewardship procedures and maintaining the site remedy components.
Question B. Are the exposure assumptions, toxicity data, clean-up levels, and remedial
action objectives used at the time of the remedy selection still valid?
Yes. There have been no major changes in the physical conditions of the site. No new exposure
assumptions are needed at this time.
The primary applicable or relevant and appropriate requirements (ARARs) that the site has to
meet fall into two categories of regulations: landfill and groundwater. No new ARARs have
been developed and therefore, no new standards need to be considered at this time.
There have been no changes in the toxicity factors for the contaminants of concern that were used
in the baseline risk assessment.
Question C. Has any other information come to light that could call into question the pro-
tectiveness of the remedy?
No. There has been no new information that would suggest that the selected remedy is not
protective.
Technical Assessment Summary
Based on the review of the site information and the site inspection and discussions with the
technical staff from IDEM and the PRPs involved at this site, it is concluded that the remedy is
functioning as intended by the ROD except that ICs are not yet fully in place.
VIII. Issues
a) not all of the use restrictions have been implemented;
b) long-term stewardship of the site must be assured through development and
implementation of an IC Plan for monitoring compliance with the ICs.
OCL Site-Five-Year Review Report
-11-
May 2010
-------
IX. Recommendations and Follow-Up Actions
• a) Implement use restrictions for Parcel 1 by having the Environmental Protection
Easement and Environmental Restrictive Covenant recorded.
• b) Put into place an IC Plan or an update of the Maintenance Plan that will provide for
monitoring of the ICs.
Issue
Recommendations/
Follow-up Actions
Party
Responsible
Oversight
Agency
Mile-stone
Date
Affects Protectiveness?
(Y/N)
Current
Future
a) implement
use restrictions
for Parcel 1
The Environmental
Protection Easement
and Environmental
Restrictive Covenant
that is under
development will be
finalized and
recorded.
PRPs with
input from
EPA and
IDEM
EPA and
IDEM
9/30/2010
N
Y
b) long-term
stewardship
Put into place an IC
Plan or an update of
the Maintenance Plan
that will provide for
overseeing and
monitoring ICs and
reporting the results.
PRPs
IDEM and
EPA
6/30/2011
N
Y
X. Protectiveness Statement
The selected remedy is functioning as anticipated. The remedy is protective of human health and
the environment in the short-term and will be protective in the long-term once all institutional
controls (ICs) have been implemented. Specifically, an Environmental Protection Easement and
Environmental Restrictive Covenant for the northwestern part of the landfill is necessary and
must be recorded. Long-term protectiveness will be achieved once these required ICs have been
implemented. Long-term protectiveness also requires compliance with effective ICs.
Compliance with effective ICs will be ensured by implementing effective ICs which must be
maintained, monitored and enforced by developing long-term stewardship procedures as well as
maintaining the site remedy components. Threats at the site are being addressed through
implementation of the required ICs and continued maintenance of the site.
XI. Next Review
The next five-year review for the OCL site is required five years from the date of this review.
OCL Site-Five-Year Review Report
-12-
May 2010
-------
t it. (, Slt^-Rv&Yeiir Review Report
May 2010
-------
Table 1. Some Results for Monitored Parameters in Last Years of Monitoring
Concentrations in ng/1 for metals, mg/l for TOC and TPH
Columbus Old Municipal Landfill #1, Columbus, IN
Parameter
& Date
Well
MW09
Well
MW11
Well
MW12
Well
MW13
Well
MW14
Well
MW16
Well
MW17
Well
MW19
Well
MW20
Well
MW21
Well
MW23
Well
MW24
Well
MW25
4/99
<4
<4
<4
<4
<4
<4
<4
<4
4
<4
<4
<4
5
A
6/99
<4
<4
<4
<4
<4
<4
<4
<4
5
<4
<4
<4
8
r
8/99
--
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
8
s
10/99
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<10
e
n
i
4/00
<4
<4
<4
<4
<4
<4
<4
<4
6
<4
<4
<4
<4
10/00
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
c
4/01
<5
<5
<5
5
<5
<5
<5
<5
<5
<5
<5
<5
<5
9/01
<-5
<5
15
<5
5
<5
<5
<5
6
5
6
<5
<5
4/02
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<5
4/99
<12
<12
20
<12
13
<12
<12
<12
1830
42
<12
1029
2770
I
6/99
<10
<10
17
194
48
<10
<10
34
928
90
<10
533
2470
r
8/99
<12
2567
404
<12
<12
<12
<12
288
50
<12
1616
3440
0
n
10/99
<12
<12
732
1 197
<12
<12
<12
505
455
26
<12
88
12,600
4/00
<12
<12
<12
<12
<12
<12
<12
<12
6300
<12
<12
237
2300
10/00
<10
<10
<10
40
<10
<10
20
<10
706
23
<10
969
1450
4/01
<10
<10
43
<10
<10
<10
<10
1920
4790
11
<10
967
4130
9/01
<10
<10
566
253
<10
<10
<10
61
27
20
<10
354
7160
4/02
<10
<10
<10
<10
<10
<10
<10
<10
1 160
<10
<10
<10
1730
4/99
<9
L 9
378
286
<9
<9
45
419
405
102
•9
104
336
M
6/99
<9
290
592
453
<9
12
75
509
397
352
<9
97
434
a
8/99
-
20
1167
322
389
25
92
369
397
434
<9
89
259
ii
g
10/99
<9
<9
686
308
17
<9
53
351
392
322
<9
60
248
4/00
<9
<9
<9
<9
<9
<9
58
52
422
<9
<9
307
307
n
10/00
<5
<5
<5
271
79
<5
75
251
468
9
<4
102
239
e
4/01
<5
<5
528
291
<5
<5
66
379
398
219
8
103
534
s
9/01
<5
<5
644
255
33
7
39
122
365
390
21
91
385
e
4/02
<5
<5
73
6
<5
<5
21
544
387
36
6
6
366
OCL Site—Five-Year Review Report
-14-
May 2010
-------
[ able l(con't). Some Results for Monitored Parameters in Last Years of Monitoring
Concentrations in ng/1 for metals, mg/l for TOC and TPH
Parameter
Well
Well
Well
Weil
Well
Well
Well
Well
Well
W^ll
VV til
U/~ II
V* I'll
Well
Well
& Date
MW09
MWI1
MWI 2
MWI 3
MWI4
MW16
MW17
MWI 9
MW20
MW21
MW23
MW24
MW25
4/99
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
L
6/99
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
e
8/99
--
<3
<3
<3
*0
<3
<3
<3
<3
<3
<3
<3
<3
a
10/99
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
u
4/00
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
10/00
<4
9
<4
<4
<4
6
8
4
5
<4
8
<4
14
4/01
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
9/01
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
<4
4/02
<4
<4
<4
<4
<4
<4
<4
5
<4
<4
<4
<4
5
4/99
<10
<10
<10
<10
<10
<10
<10
<10
11
<10
<10
<10
<10
T
6/99
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
O
8/99
--
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
16
c
10/99
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
4/00
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
10/00
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
4/01
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
9/01
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
4/02
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
4/99
<1.0
<1.0
1.9
1.6
<1.0
<1.0
<1.0
<1.0
4.7
<1.0
<1.0
1.6
<1.0
T
6/99
<1.0
<1.0
<1.0
2.2
<1.0
<1.0
<1.0
<1.0
0.9
<1.0
<1.0
1.8
<1.0
P
8/99
"
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
1.2
<1.0
<1.0
1.4
<1.0
H
10/99
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
4/00
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
1.2
<1.0
<1.0
<1.0
<1.0
10/00
<1.0
<1.0
1.2
<1.0
<1.0
<1.0
<1.0
<1.0
2.5
<1.0
<1.0
12.5
1.3
4/01
4.1
5.0
6.7
2.3
7.4
4.4
12.3
2.8
4.1
2.1
3.6
6.9
4.2
9/01
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
4/02
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
TOC is total organic carbon. TPH is total petroleum hydrocarbons. Comparison concentrations: maximum contaminate level (MCL) for arsenic has been 50 ng/1, changes
to 10 pg/1 on January 23, 2006; for lead, action level is 15 jj.g/1, treatment technique (primary standard); secondary maximum contaminate level is 300 p.g/1 for iron and 50
Hg/I for manganese.
OCL Site—Five-Year Review Report
-15-
May 2010
-------
Table 2. Maximum Concentrations between December 1993 and December 1995
Also Second Highest Concentrations In Some Cases
Concentrations in jag/1 for metals, mg/1 for TOC and TPH
Columbus Old Municipal Landfill #1, Columbus, IN
Well
Arsenic
Iron
Manganese
Lead
TOC
TPH
MW09
0.8
281
203
22
16
34*
<1
5.88
4
1.7
MW11
0.2
2240
333
30
18
*
00
4
7.70
6.20
2.1
MW12
0.6
0.2
390
156
536
518
51*
2
10.6
7.0
1.6
1.5
MW13
2.7
0.2
1190
786
315
296
43*
2
10.0
9.31
7.2
4.0
MW14
0.8
360
233
1270
980
35*
7
11.7
11.0
1.7
1.3
MW16
10.0
0.04
686
278
37
20
38*
9
8
4.49
3.4
1.3
MW17
0.02
138
100
62
56
36*
13
3.6
2.24
2.5
<1.0
MW19
0.8
1480
587
1220
469
20*
2
3.68
3.07
<1.0
MW20
22
12
12,300
6170
503
480
33
29*
22.9
21.3
6.2
3.5
MW21
0.10
5550
710
949
896
40*
2
7
5
2.0
1.7
MW22
0.2
497
255
1360
1140
30*
1
6.89
5.31
7.1
MW23
first sample 6/95
MW24
0.80
0.2
7860
7660
881
630
54*
10
12.3
11
5.8
2.0
MW25
27
19
12,200
10,400
771
608
29*
2
6.80
5.93
1.3
1.0
TOC is total organic carbon. TPH is total petroleum hydrocarbons. *These values for lead were obtained in the first reported sampling event in
November/December 1993; they are generally significantly higher than the next highest.
OCL Site-Five-Year Review Report
-16-
May 2010
-------
Attachment 1
Declaration of Restrictions and Covenants Upon Real Estate
OCL Site—Five-Year Review Report
-17-
-------
DSCIARArCOH 01? HBSmCTIOBB AND
COVBMjUTPS TJPOtt FU3AI. EBTTT^
THIS DEC LARATION OF RESTRICTIONS AND COVENANTS UPON REAL
SSTAT5 (tha "Declaration") is made this 2nd day of June ,
].9f>3 b;/ Marie Web^r and Linda O'Con^^r r. /Mhsrt Guhre Trust
("Owner"), under the following circumstances:
WITNESSETH:
(JHKP-EAS, Owner is tha title holder of certain real property in
Bartholomew County, Indiana., tha legal description at which is
iict.ichod hereto as t'xhibit (the "Real Estate") ; and
WHEREAS, on Apcrl l 16, 1993, the State of Indiana and various
parties (auch parties being referred to as "Settling Defendants")
nnt'smd into a Consent- Decree in State of Indiana v. Arvin
Tnrtujtrloa. Inc.. et al ¦ Cause No. 49D02-9303-CP-0403, in the
Harion County Superior Court, (the "Consent Decree"), a notice of
which was racotded on H-iy , 199 3, at Docu&ent Ho,
'': '' i'1 {io "RO/RA") to bo performed on property located in Bartholomew
county, Indiana, said property being defined as tha "Sita" pursuant
V o tno romsent D«creei; and
ii'HCiiEiVS, tho Constant Decree requires that Settling Defendants
ui.o their bent efforts to have placed of record certain
roi'.triut ions and covenants which will effect, and protect the RD/RA
to performed on th« Site; and
WHEREAS, tha Real Estate owned by Owner comprises a part, of
r.ho Si~e; ~>nd
NOW, THEREFORE, In consideration of ih« foregoing, owner
i.orclry laclaron and icprffaaed upon the ae^l Estate the following
rict.iona arid covenants;
1, Owner aha 11 use its beat efforts to restrict use of and
ntrcso ( t ' he Rr;a). Eatntn in such manner to insure that:
-\. Ther-a shall fca no interference of any sort, by any
person, with construction, operation, maintenance,
monitoring, and ax'ficacy of all components find structures
jn terms
oI thir. Conncnt: Decree;
-------
!
(
C. There snail be do agricultural, r:crlationai, residential, commercial* !
or industrial use of die Real Estate including, but not limited to, any j
excavation, grading air other activity involving movement ot soils at lie
Site, and any construction or placement of any residence*, buildings or i
structures -- fixtures or otherwise — other ihan the purpose of J
implementing, monitoring, and maintaining th«r response action required j
by the Cc nsent Decree; and j
D. There shall be no construe doc, installation, or use of any buildings, i
wells, pipes, 1 oad, ditches, or any ether structures ~ fixtures or j
otherwise — on the Real Estate that may affect the construction, physical |
integrity, npetii'.ion and maintenanci:, or efficacy of the Work (as that
terra is usr.d iti the Consent Decree) undertaken pursuini to the Consent
Decree including without limitation the Facility's: security fence, lsindfill
cap, groundwf.f.er monitoring syseer/is, unleas such construction,
installation of use is approved iu advance, in writing, by IDEM.
2. Owner, its successors and assigns shall faithfully observe each of the
restrictions ana covenant , stated herein.
3. The restriction!. and covenants stated herein snail ran with the Real Estate,
and the conveyance of my interest therein, and are gi:jitcd for the benefit of and
shall be enforceable by the State of Indiana, the Settling Defendants, their successors
and assigns
4. If the Owner, iw successors and assigns, at Jtny time violates, threaten.": or
attempts to violate, or £ tils: to faitlifully observe or perform each of the foregoing
restrictions and covenans upon the Real Estate, it shiill be lawful for the State of
Indiana or any and all c f tbc Settling Defendants, in addition to other remedies,
available under law or equity, to rjistitute and prosecute appropriate proceeding)),
judicial or other, at law or in equity for the wrong done, threatened or attempted.
5. Any person, corporation, partnership or oiher entity, including Owner,, who
is the tills owner of or controls the Real Estate which is subject to die. restrictions
and covenants hereof, may ask ED EM for a determination that one or more of said
restrictions and covenants is no longer required in order to prevent interference! with
construction, operation, maintenance, monitoring and efficacy of the RD/RA taken
pursuant to the Con/ient Decree, or to protect human health and the environment.
Upon such request, the State of Indiana, shall determine whether such restrictions and
covenant can be extinguished.
6. The most recent deed of record for (he Real Estate is Document
No. ^-"^/Tecorded oo Faiimiry 5, l')Q2 jn the office of the- Register of Deeds,
Bartholomew County, Indiana.
IN WITNESS WHEREOF, Owner lias executed this Declaration of Restrictions
and Covenants upon Real Estate as of day and year first written z-bave.
mmmm
-7177
m
%
-------
'Owner* ^ . /. / y V Z.
STATE OF INDIANA )
) SS:
COUTJTY OF BARTHOLOMEW
Before me, the undersigned, a Notary Public in and for said County and State,
tiiis 2nd day of Jur.e 1992 personalty appeared
ifarje frfeber Linda Q'Conr:fcr s, Albert &J:Tre^pi^nwierigeri )Jje execution of
the for agoing to be a voluntary act and deed, for the uses and purposes therem set
forth.
WITNESS my hand and notarial seal.
.i. X. v /;,**)< V t..'
Notary Public
•Xieliolle \<. Fisher
Pnnted Name
My Coimiiission Expires:
B-Il-96
'' ¦¦¦ 717 7
County of Residence:
Bartholomew
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