&EPA

United State*
Environmental Protection
Agency

Share your opinion

EPA encourages you to comment on
the proposed plan. The Agency will
only select a final cleanup plan after
reviewing comments received during
the public comment period,1 which runs
from May 16 - July 15,2016.

There are several ways to submit
written comments:

•	Orally or in writing at the public
meeting (see below).

•	Fill out and mail the enclosed
comment sheet to Susan Pastor.

•	Send an email to Susan Pastor at
pastor.susan@epa.gov.

•	Fax your comments to Susan Pastor
at 312-385-5344.

Attend a public meeting

There will be a public meeting
Wednesday, June 8, at 6:30 p.m.:
Clarion Hotel
5820 S. Franklin St.
Michigan City

If you need special accommodations,
contact Susan Pastor by June 1.

For more information

Susan Pastor

Community Involvement Coordinator

312-353-1325

pastor.susan@epa.gov

Erik Hardin

Remedial Project Manager

312-886-2402

hardin.erik@epa.gov

Jacob Hassan

On-Scene Coordinator

312-886-6864

hassan.jacob@epa.gov

(Coal ash sampling & cleanup only)

You may call EPA's Chicago office
toll-free at 800-621-8431, ~
8:30 a.m. - 4:30 p.m. weekdays.

EPA Proposes Cleanup Plan
For Soil, Groundwater

Town of Pines Groundwater Plume Site

Town of Pines, Indiana	May 2016

U.S. Environmental Protection Agency is proposing a cleanup plan for soil and
groundwater at the Town of Pines Groundwater Plume site. Contamination is
associated with coal ash. EPA reached a legal agreement with four companies
determined to be responsible for the contamination. These companies, Northern Indiana
Public Service Co., Brown, Inc., Ddalt Corp. and Bulk Transport Corp. and their
contractors, conducted an investigation under the oversight of EPA and the Indiana
Department of Environmental Management. The cleanup plan proposed is based on the
findings of that investigation.

The recommended cleanup would involve:

•	Excavating and disposing of contaminated soil off-site.

•	Implementing deed restrictions to prohibit digging into contaminated
soil.

•	Using plants to absorb the groundwater contaminants as nutrients.

•	Monitoring groundwater.

•	Implementing deed restrictions to prohibit using or installing drinking
water wells in certain areas.

•	Discontinuing the requirement to provide bottled water service to homes
in areas not affected by groundwater contamination.

•	Requiring additional properties to be sampled at the request of property
owners and cleaned up if contamination is found to be above naturally
occurring levels.

EPA expects that most, if not all, identified properties with contamination
resulting from coal ash used as landscaping fill will be addressed by another
EPA action under a different legal agreement with NIPSCO. The company is
required to do this work separately from the cleanup plan outlined in this fact
sheet.

Background

The Pines site is about 4 miles west of Michigan City and about 1 mile south of
Lake Michigan in Porter County. EPA tested residential drinking water wells in
the town of Pines in 2002, based on high levels of the metals boron and
molybdenum found when Indiana Department of Environmental Management
sampled them. The metals are from the ash generated from burning coal to make
electricity. Fly ash, a specific type of the coal ash, was disposed of in a landfill
near Pines called Yard 520.

Continued on the next page...

1 Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERLCA) requires publication of a notice and a proposed cleanup plan. The proposed plan must also be
made available to the public for comment. This fact sheet is a summary of information contained in the
remedial investigation, feasibility stuck', and other documents in the administrative record for the Town of
Pines Groundwater Plume site. Please consult those documents for more detailed information. All
official site documents can be found at the repository at the Michigan City Public Library, 100 E. 4th St., or
online at www.epa.gov/superfund/town-pines-groundwater.


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A technician compares soil samples that show the contrast
between sand and coal ash.

The coal ash In this landfill is believed to be the primary
source of the groundwater contamination. Other areas in
the town also have these coal ash materials Fly ash was
primarily used as fill in residential yards, and another
type of ash, called bottom ash, was used as road surfaces
and sub-surfaces in the town of Pines and surrounding
areas. This is an important distinction because fly ash
generally contains higher levels of the contaminants of
concern than bottom ash. The full extent of coal ash fill
materials in and around the town of Pines is still not
known. This proposed cleanup plan includes provisions
for sampling and, if needed, cleanup of additional
properties.

The companies provided municipal water to more than 250
homes and business in and near the town of Pines. About 50
more homes received bottled water pending the results of the
investigation.

Proposed cleanup alternatives

Soil Cleanup Alternatives
Soil Alternative 1 - No Action

Under the no-action alternative, EPA would take no further
actions to clean up the contamination. The no-action
alternative is used as a baseline for comparison to the other
cleanup alternatives.

Estimated cost: $0

Soil Alternative 2 - Land-Use Controls

This alternative includes putting deed restrictions on
properties to prohibit digging or other soil disturbances
where coal ash contaminants are above EPA's cleanup
goals. This alternative would not be appropriate for
private properties where the contamination exceeds
cleanup goals in soil close to the surface (except under
specific conditions that do not allow for direct-contact,
such as under pavement).

Estimated cost: $13,000 per property

Soil Alternative 3 - Excavation and Off-Site Disposal

This alternative includes
excavation and off-site disposal
of coal ash-contaminated soil
found above EPA's cleanup
goals. Excavated soil would be replaced with clean soil
and graded to match the surrounding area. If the soil
contamination above the cleanup goals is deeper than the
depth EPA requires, the soil cover would help
technicians visually identify where to limit digging.

Deed restrictions would also then be put in place to
prohibit digging into the deeper contaminated soil to
eliminate any potential exposure. This option proposes
to continue the soil sampling and cleanup described on
Page 7.

Estimated cost: S5.6-S11.9 million

Groundwater Cleanup Alternatives
GW Alternative 1 - No Action

Under the no-action alternative, EPA would take no further
actions to clean up the contamination. The no-action
alternative is used as a baseline for comparison to the other
cleanup alternatives.

Estimated cost: $0

GW Alternative 2 - Land Use Controls

This alternative involves implementing deed restrictions
east and north of Yard 520 to prohibit the use or
installation of private drinking water wells on specific
properties or within a designated groundwater
management area. Groundwater is currently not used as
a source of drinking water in these areas, but these
restrictions could prevent future use of the groundwater
in this area.

Estimated cost: $900,000

GW Alternative 3 - Long-Term Monitoring

This alternative includes the deed restrictions described
in Groundwater Alternative 2, but adds long-term
groundwater monitoring that would help to evaluate how
protective previous cleanup actions continue to be over
time.

Estimated cost: $2.5 million

EPA's recommended
alternative

2


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GW Alternative 4 - Phytoremediation

This alternative includes the deed restrictions and long-
term monitoring described in
Groundwater Alternatives 2
and 3, but adds

EPA 'v recommended
alternative

phytoremediation. Phytoremediation is a technology that
uses specific plants to remove the contaminants through
natural processes. Plants that are efficient in absorbing
boron, such as poplar trees, would be used. Plants or
leaves would be recovered and disposed of to maintain
""normal" levels of naturally occurring metals. Long-term
monitoring would also be done to evaluate the
effectiveness of the cleanup and continue to monitor site
conditions.

Estimated Cost: S3.7 million

GW Alternative 5 - Barrier Wall

This alternative includes the deed restrictions and long-
term monitoring described in Groundwater Alternatives
2 and 3. It also includes installing an underground
barrier wall along the east side of the North Area of Yard
520. The new barrier wall would be connected with the
existing barrier wall in the South Area of Yard 520 to
prevent groundwater flow. The wall would be placed
deep into the clay to control potential flow of water
under the wall. Groundwater in the walled area would be
collected and treated. The treated water would then be
discharged to groundwater or the surface/wetland under
the appropriate permits. Long-term groundwater
monitoring would also be done to evaluate the
effectiveness of the cleanup and continue to monitor site
conditions.

Estimated Cost: $14.7 million

What is phytoremediation?

Phytoremediation is a commonly used
cleanup option for Superfund sites with
contamination at relatively low
concentrations. It involves the cultivation of
specialized plants or trees that absorb specific
contaminations from the soil through their
roots or foliage. This reduces the levels of
contaminants in the soil. All or part of a plant
is harvested and disposed of to prevent
contamination from being released back into
the environment.

EPA has used phytoremediation at several of
its Superfund sites including Chanute Air
Force Base, Illinois; Sangamo Electric
Dump/Crab Orchard National Wildlife
Refuge, Illinois and Aberdeen Pesticide
Dumps, North Carolina.

Evaluation of alternatives

EPA is required by law to evaluate these alternatives
against nine criteria (see box below). These criteria are
used to help compare how the alternatives will meet
cleanup goals. The tables on Pages 4 and 7 compare each
alternative against the nine criteria.

Explanation of evaluation criteria

EPA compares each cleanup option or alternative
with these nine criteria established by federal law:

1.	Overall protection of human health and the
environment examines whether an option protects
living things. This standard can be met by reducing or
removing pollution or by reducing exposure to it.

2.	Compliance with applicable or relevant and
appropriate requirements, or ARARs, ensures
options comply with federal, state and local laws.

3.	Long-term effectiveness and permanence

evaluates how well an option will work over the long-
term, including how safely remaining contamination
can be managed.

4.	Reduction of toxicity, mobility or volume
through treatment determines how well the option
reduces the toxicity, movement and amount of
pollution.

5.	Short-term effectiveness compares how quickly
an option can help the situation and how much risk
exists while the option is under construction.

6.	Implementability evaluates how feasible the
option is and whether materials and services are
available in the area.

7.	Cost includes not only buildings, equipment,
materials and labor but also the cost of maintaining
the option for the life of the cleanup.

8.	State acceptance determines whether the
state environmental agency accepts an option.
EPA evaluates this criterion after receiving public
comments.

9.	Community acceptance considers the opinions
of nearby residents and other stakeholders about the
proposed cleanup plan. EPA evaluates this standard
after a public comment period.

3


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Green and Sustainable Remediation

EPA has added a secondary criteria when evaluating
the cleanup options. The Superfund Green and
Sustainable Remediation Strategy looks at how the
alternatives reduce negative environmental impacts
that may occur when cleaning up a site. These
considerations were also looked at during the analysis
of the cleanup options for this site. Factors include
five core elements: energy efficiency, air and
atmospheric emissions (including greenhouse gases),
water use, land and ecosystems effects and materials
and waste use/generation.

EPA's recommended cleanup plan for soil is Soil
Alternative 3 - Excavation and Off-Site Disposal (detailed
in the table below). The recommended cleanup protects

people and the environment by removing contaminated
dirt and putting in a soil cover to eliminate direct contact
and restrictions to prevent digging into the deeper
contaminated soil. It is also effective in the short and
long term. Implementing this option may be more
difficult because of the need to get access agreements
from property owners and the potential that digging on
some properties could be restricted because of mature
trees, septic systems, shallow utilities and other
structures. The estimated cost for this alternative is
between $5.6 and $11.9 million. The range is due to not
yet knowing the full extent of contamination or number
of properties to be cleaned up. Though this cleanup
option is not considered green and sustainable during
implementation, it is considered green and sustainable in
the long-term because no significant energy- or resource-
intensive actions will be needed after cleanup.

Soil Alternatives

Evaluation Criteria

Alternative 1

Alternative 2

Alternative 3

Overall Protection of Human Health
and the Environment

~

~

¦

Compliance with ARARs

~

~

¦

Long-Term Effectiveness and
Permanence

~

~

¦

Reduction of Toxicity, Mobility, or
Volume through Treatment

~

~

~

Short-Term Effectiveness

~

~

¦

Implementability

¦

¦

¦

Cost

$0

$13,000 per property

$5.6-$ 11.9 million

State Acceptance

Will be evaluated after comment period

Community Acceptance

Will be evaluated after comment period

B - Meets criterion ~ - Does not meet criterion

EPA's recommended cleanup plan for groundwater is
Groundwater Alternative 4 - Phytoremediation (detailed
in the table on Page 7). This alternative also includes the
deed restrictions and long-term monitoring described in
Groundwater Alternatives 2 and 3 (see Page 2). Long-
term monitoring would also be done to evaluate the
protectiveness of the previous cleanup actions and the
phytoremediation system. The recommended
groundwater cleanup alternative protects people and the
environment by using deed restrictions to eliminate
direct contact with the contaminated groundwater and
using specific plants to absorb and remove the
contaminants from the water. By removing
contamination from the groundwater, this cleanup
alternative will, in time, meet all applicable laws and is

~~~ - Partially meets criterion N/A - Not applicable

effective in the short and long term. This alternative
reduces the toxicity, mobility or volume of the
contamination by using plants to remove contaminants
from the groundwater. Because this alternative requires
access to properties and passing local ordinances or deed
restriction, it may be a little more difficult to implement.
This alternative is considered green and sustainable. The
estimated cost for this option is $3.7 million.

4


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Public Comment Sheet
Use this space to write your comments

EPA is interested in your comments on the proposed cleanup plan for the Town of Pines Groundwater Plume site. You may
use the space below to write your comments and hand it in at the public meeting on June 8, 2016, or detach, fold, stamp and
mail to EPA Community Involvement Coordinator Susan Pastor. Comments must be postmarked by July 15, 2016. If you have
questions, contact Susan at 312-353-1325, or toll-free at 800-621-8431, Ext. 31325, 8:30 a.m. - 4:30 p.m., weekdays.
Comments may also be emailed to pastor.susan@epa.gov or faxed to Susan at 312-385-5344.

Name:

Affiliation:

Address:

City:
State:

Zip:


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Town of Pines Groundwater Plume site - Comment Sheet

Fold on dashed lines, seal, stamp, and mail

Name		

Address		

City

State		 Zip

Susan Pastor

Community Involvement Coordinator
U.S. EPA Region 5
Superfund Division (SI-7J)
77 W. Jackson Blvd.

Chicago, IL 60604-3590


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Groundwater Alternatives

Evaluation Criteria

Alternative
1

Alternative
2

Alternative
3

Alternative
4

Alternative
5

Overall Protection of
Human Health and the
Environment

~

~

~

¦

¦

Compliance with ARARs

~

¦

¦

¦

¦

Long-Term Effectiveness
and Permanence

~

~

~

¦

¦

Reduction of Toxicity,
Mobility, or Volume
through Treatment

~

~

~

¦

~

Short-Term Effectiveness

~

¦

¦

¦

~

Implementability

¦

¦

¦

¦

~

Cost

$0

$900,000

$2.5 million

$3.7 million

$14.7 million

State Acceptance

Will be evaluated after the comment period.

Community Acceptance

Will be evaluated after the comment period.

B - Meets criterion ~ - Does not meet criterion ~~~ - Partially meets criterion N/A - Not applicable

Next steps

Before making a final decision, EPA will review
comments received during the public comment period. If
new information is presented, EPA may modify the
proposed plan or select another option.

EPA encourages you to review and comment on the
proposed cleanup plan. More detailed information on all
of the cleanup alternatives is available in the official
documents on file at the information repository or EPA's
website listed in the box to the right.

EPA will respond to the comments in a document called
a "responsiveness summary." This will be part of
another document called the "record of decision" that
describes the final cleanup plan. EPA will announce the
selected cleanup plan in the local newspaper, place a
copy in the information repository and post it on the
Web.

Coal ash residential soil sampling, cleanup

Pines residents can still request that their properties be
sampled and analyzed for soil contamination related to
coal ash by contacting one of the EPA team members on
Page 1 of this fact sheet.

If sampling results indicate that a residential cleanup is
warranted:

•	The condition of the property will be
documented before work starts.

•	Soil would be excavated and transported for off-
site disposal.

•	A permanent barrier such as landscape fabric or
orange construction fencing would be installed,
if necessary.

•	The area would be backfilled and covered with
clean soil.

•	The property would be restored as closely as
possible to its original condition.

•	New trees, shrubs, vegetation, etc., would be
planted, if necessary.

•	Concrete or pavement would be repaired or
replaced, if necessary.

In March, EPA and NIPSCO signed a legal agreement,
called an administrative order on consent. It outlines the
cleanup that the company will be responsible for. This
cleanup, which so far affects about a dozen homes as
well as the town hall playground area, is expected to
begin this spring.

7


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For more information

Save the date

You may review the proposed plan and other

EPA is hosting a public meeting to talk about

site-related documents at:

the cleanup plans for the Pines site.

Michigan City Public Library

Wednesday, June 8, at 6:30 p.m.

100 E. 4th St."

Clarion Hotel



5820 S. Franklin St.

On the Web:

Michigan City

www.epa.gov/superfund/town-pines-
groundwater

An administrative record, which contains
detailed information that will be used in the
selection of the cleanup plan, is also located at
the Michigan City Public Library.

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