51
EmrirennwnM Pratoclion Ag*ney Oflto of Emergency and ftanwdW RMponM EPA/ROO/ROS-««/04« S«pt*mb«r 1966 AEPA Superfund Record of Decision: Seymour Recycling, IN
EmrirennwnM PratoclionAg*ney
Oflto ofEmergency andftanwdW RMponM
EPA/ROO/ROS-««/04«S«pt*mb«r 1966
A EPA SuperfundRecord of Decision:
Seymour Recycling, IN
TECHNICAL REPORT DATAIPIttst rtld Inttrutttoni on Hit rtvtnt
1. Mf^OHTNO.
EPA/ROD/R05-86/046
ACCESSION NO
4. TITLI AND SUITITLI
SUPERFUND RECORD OF DECISION
Seymour, IN
DATE
September 30. 1986I. MM'OAMING ORGANIZATION COOi
7. AUTHOftlS) ORGANIZATION R€»ORT NO
'•A'ORMINO ORGANIZATION NAMC AND AOOAf SS 10. PROGRAM fLEMINT MO
1 1 CDNTI
12. SPONSORING AQKNCY NAMI ANO AOOAf SS
U.S. Environmental Protection Agency401 M Street, S.W.Washington, D.C. 20460
13. TYM of AIPOAT ANO MAIOOFinal ROD Report
14. SPONSORING AGENCY COOI
800/00
9. SUPPLEMENTARY NOTIS
The Seymour Recycling Corporation (SRC) site, encompassing a fourteen-acre area, isapproximately two miles southwest of Seymour, IN. Approximately one hundred homes arelocated within a one-mile radius of the site in a predominately agricultural area. Fro.-about 1970 until early 1980 SRC operated a processing center for waste chemicals. Overthe years toxic and hazardous wastes, including solvents, metal finishing wastes andother materials, accumulated on the site in 55-gallon drums, bulk tanks and othercontainers. Wastes leaked and spilled from the drums creating fire and odor problems.A Consent Decree, reached in the fall of 1982 after a May 1980 suit filed by the UnitedStates against the owners and site operators, resulted in the removal of approximatelythe upper one foot of contaminated soil from about 75 percent of the site's surface.Contaminated soil remains, however, and extends throughout the shallow and deepaquifer. The site is fenced and partially covered with a temporary soil cap. Homessurrounding the site have recently been connected to the city water distribution syst-?-due to the threat of ground water contamination. The primary contaminants of concerninclude: VOCs, organics, TCE, DCE, benzene, toluene, and heavy metals.
The selected remedial alternative for the site is the implementation of a plumestabilization system which will extract, treat, and discharge approximately 101,690,000gallons of contaminated ground water to the Seymour Wastewater Treatment Plant. Theestimated capital cost for this remedy is $300.000. O&M costs are estimated to be7(See Attached Sheet) «|Y WO«O* ANO OOCVJMCNT ANALYSIS
b.'OiNTiFiEAS/OPEN ENDED TEAMS c. COSATi Field. Group
Record of DecisionSeymour, INContaminated Media: soils, gwKey contaminants: VOCs, organics, TCE,DCE, toluene, benzene, heavy metals
•. DISTRIBUTION STATIMCNT 19 SECURITY CLASS ,riiu RtpO'U
None
P*GIS
5220. SfCUMlTY CLASS < Hill ptfti
None22
I 2220-1 (••». 4-771 •••viou* co< TION i * O*«OI«TC
EPA/ROD/R05-86/046Seymour, IN
16. ABSTRACT (continued)
either $100,000 per year or $250,000 total costs for the 2.5 year periodrequired to implement a final remedial action.
HbCOKD OK DECISIONPLUilt. STrtblLUAllUH
SJLYMOUK KbCYCLlHb COKPUKA FlUNSEYPIOUK, INDIANA
SEP 3 0 lft£
Documents Keviewed
I am baiiny my decision on the following documents describing tne effective-ness ur remedial alterndtives for the Seymour ReCyC l iny site:
0 Correspondence frun John lilass, Cri^n Hill, to Dorothy Mcblincy,beraanty and Miller, Inc., ilay b,
0 Seymour Kecyclina Corporation, Kemedial investigation, Crii II , nay 12, iy«b.
0 Preliminary Hluine btdbi Mzatiori for the Seymour Kecjdiny Corp.Site, Uera^hty and Miller, Inc., June 3, lytfb.
0 Correspondence from Neil rteldyin, U.S. tPA, to Uaviu b. Miller,anu mi l ler, inc., June 20,
Correspondence frurii Hei I Heldyin, U.S. EPA, to David li. Mil ler,and ililler, Inc., July il,
0 Correspondence from iyed Maniiiood, Cri^/M Hill, to David Favero,tPrt, July Zb, iy«b.
0 Phased Feasioility Study, broundwater contamination Uperaole Unitfor tne Seymour Kecyclin^ Corporation Site, U.S. LPA, August, iy8fa.
0 Public Comment FeasiDility Study, Seymour Kecyclinb Corporation,Seymour, Indiana, CH^M Hill, August i;y, ly8b (Attached).
0 Cmmiiunity Kelotions Responsiveness Summary, for tne Puolic CommentPeriod, Phased Feasibility Study for broundwater Contami nation,September Zb, lyuo.
0 Suiiifliary of trie Alternative tvaiuation for a Plume Stabil izationProject at the Seymour Kecycl iny Corporation Site, U.S. EPA,September, iy<*b (ntcacned).
Description of Selected Kemedy
0 Contaminated jroundwater w i l l be extracted from tne sha l lowaquifer northwest of the site.
0 The contaminated 3roundwater w i l l be treated to tne extentrequired to meet the pretreatment requirements of the Seymour
Treatment Plant.
0 I his operable unit can oe integrated as a part of the finalremedial action selected for the site.
uecldration
Consistent witn tne Comprehensive tnvi romnental Kesponse, Compensationana LidOility Act or lydu (ChKCLA) ana tne National Contingency Hlan(rtCHJ, 4u UK Hart 3UU , I nave determined thdt plume stabilization isan effective interim remedial dction to address yroundwater contaminationat tne beyuiour Kecyclin3 site. Tnis interim ranedy is consistent wi tnttie permanent reiiieoies Deiny considered for tne site and providesadequate protection or ,JUDIIC nealtn, welfare arid the environment. Thebtate of Indiana has Been consulted and agrees witn this interim remedy.I nis interim ranedy w i l l require operation and (ndintcnance (Jan'ij, wnicn isconsidered ^art of" tne approved action.
A hedsioi I i ty btudy to determine tne final raiiedy ror this site nas oeenmode a v d i l a o l e ror public coniment. Trie plume staoi lization system is acomponent of U.iJ. tHA'b recominended alternative. Additional remedialactions w i l l oe descriDed in a subsequent Kecord of decision.
l/dlUaS V.Ke^ionat Aa,ninistratorunited states tnvironmental Protection AgencyKeyion V
ACtacnments
Summary of tne Alternative tvaluation fortor a Plume btabiIization Hroject at tne
^>e./muur Kecydiny corporation bile
bite Location and Description
I'nis 14-acre site Is located rou^nly 2. miles southwest or Seymour, Indiana,near the northwest corner or Freeman Municipal Airport ana Inuustrialpark (Kiyure i). Most ot tne nearby lanu is used Tor agriculture. Tnesite is located on a nearly level plain; surrace drainage is towards tnetast Fork of tne White Kiver, which is approximately i \.li miles northwestoT the site.
Ttie city uT beymour has a population of approximately is.JUU. About luuhomes are located within a one-mile radius of tne site. Most of tnesenoiues are in tne bnyde Acres subdivision to the north of tne site. Thesenoi.ies used private w e l l s until most uT them were recently connected to tnecity water distribution system because of trie threat of contamination Tromthe site.
bite history
hruni aoout iy7u until early lyau Seymour Kecyclin^ Corporation (SKC)operated a processing center tor waste chemicals at the site. Jver tneyears toxic and hazarauus wastes, including solvents, metal finishingwastes and utner materials, accumulated on the site in bb-yallon drums,bulk tanks and other containers. Ciiese wastes leaked and spilled fromtneir containers ttius creating Tire and odor problems, un May y, lyduthe United btatos Tiled suit aaainst tne owners and operators of tne site.In tne fall of lydi! the United btates and certain companies wno allegedlysent waste tu tne site reached a settlement agreement, under tne termsof a Consent Decree tne settling defendants removed accumulated wastesarid approximately tne upper one foot OT contaminated soil from aoout 7biof the site's surface between I9tt<i and Iyti4. Contaminated soil remains,however, and extenus throughout the shallow aquifer and into tne deepaquifer. Tne site is fenced and for the most part covered with a temporarysoil cover. Several abandoned buildings also remain on site.
tnforcement status
There is an existing case beTore the united States District Court, SouthernDistrict of Indiana. The United States has claims pendins ayainst over budefendants. Anotner approximately 4b parties have ueen added by certaindeTendants as third party defendants.
A case management oraer in effect c a l l s for a negotiation period that beginswhen the final feasibility study is made available, September 1, ly<}6 anaw i l l run until about December ly, iybb. If an ayreeinent cannot be reached,
case is scheduled to ao to trial.
-2-
/—L±:V. Jr^v'^rOr: T.L/ Tiy. . - . -^V^. 1 -F •>=^.-«" "
STUDYAREA i*r\, +*•—••^^ ^ M
SCALE 124000o
SEYMOUR RECYCLING CORPORATIONREMEDIAL INVESTIGATION EPA WA 50.5 V01 1
Currently <»n order is beiny negotiated between tne unltea States and tne defendants to implement the plu.ne stabilization system recoiimiended in this aocuiiient.Trie oruer, wnen finalized, w i l l oe submitted to Jud3e W i l l i a m E. Steckler tor
it an oruer cannot be agreed upon, there are tnree possible alternatives tnat.could develop. Kirst, tHA coula proceed with the impleiiientdtiun of the plumestdbi I ization project usiny Superfund monies. Second, t^A cc'-id unilaterallyapproach the court to request that court neld settlement monies be used toimplement cue plume stdDi Mzation project. Lost, dnd most probable, becauseof the s^eeo with which the./ can take action, the defendants would petitiontne court to request that tne court settlement funds be used to implementtne project.
fne defendants' consultant was involved with the conceptual Jeve lopinent of thisoperable unit and prepared the detailed work plan for its implementation.
Current Site itutus
A Kfc.iiedidl investigation was canpleteu on Nay 12, lydb. A Feasibility5tud> wdb completed on Auyust 2y, lyab. Tne Kemeoial investigation notestridt tne jTedtest soil contdiinndtion witri heavy metdl and or^amcs occursin tne upper six feet. Ihe investigation also found a plume of contaminated^roundwater in the Shallow aquifer. Contaminants include vinyl cnloride,ciiiorinated ethanes and etnenes, cresols, benzene, chloroform, toluene, phenolana acetone, liroundwater in tne shallow aquifer is flowina toward tne nortn-nortnwest at a rate of approximately IbU feet per year. Contaminants aremoving at various rates through the shallow aquifer; souie at rates Drearer thantrie flow, ana others much slower than tne flow rate. Tne closest residentialw e l l which is now used for watering cattle belonas to Mrs. Utte and is aooutUUu feet northwest of the site.
other receivers of contaminated ^roundwater could be East-West Creek ana VonFanye Uitcn, both tributaries to the East Fork of the dhite Kiver. In thisscenario tne general H"0'̂ as well as biota in the creek and the ditcn drainayearea coulo be exposed to contaminated Around/surface water.
Contaminants in the shallow aquifer are present in concentrations wnicnhazardous to public health and the environment. Table y.ls of the Kemeoialtne Kenedial Investigation shows tne risks onsite while Table y.ly exdiiiines off-site risks. These tables are included tor your reference. Potential healtheffects from inyestiny the contaminated yroundwater include cancer (benzene anaand vinyl chloride are Known carcinoyens), liver damage and kidney damage.
Determination of Alternatives for Evaluation in tne Phased Feasibility Study
1. brounuwater Extraction
TUU ».Uupcrmt own* itsci OWLUM ncm ODOMMM
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Jnly d limited number or alternatives were evaluated in tne Phased Feasi-oility btudy IPKi). l"ne decision to evaluate an unusually Minitea numberwas baseu on tne Public Comment uraft Feasibility Study (FS) wnich wasavdilaole at tne time of the preparation of the PFb. Tne FS contains tnedetailed discussion ot the technoloyy screeniny tor inetnods to collect andtreat aroundwater. Trie technologies remaining after tne initial screeninawere extraction, containment and migration control.
Extraction wells proved to be the only practical alternative Tor witndrawinyarounawdter. Subsurface drains were eliminated because they would not a l l o wtor t l e x i u i l i t y in purupiny rates which would be neeued as the concentrationana configuration of the plume chanyes. Other factors, although not mentionedin tne Kb, are the depth (approximately JU teet) ana the length (approximately7uU teet perpendicular to yroundwater flow) the drain would have to be tocapture the plume. Tne costs and installation problems associated with such adrain add to its unpracticality. Extraction would hydraulically control yround-water tlow and remove contaminants; wnicn are tne ODjectives of aquifer cleanup.
Containment is a viable alternative. Specific methods of containment are amulti-layer cap and tiie use ot yradient control throuyh extraction w e l l s witnor without slurry walls.
Cdppin3 is effective in reduciny infiltration into and throuyh tne contaminatedsoil out does notniny to stop the downaradient spread ot contaminants alreadyin tne yroundwater. According to tne Fb, if infiltration in the yroundwateris stopped immediately, it would s t i l l take over 1UU years to naturally reacnd concentration ot lu~b increase cancer risk level.
Gradient control usiny extraction wells and a slurry wall was evaluated in theKb tor the area immediately surrounding the site. A slurry wall is not practicalat tne edye ot tne flume because of the I a rye land area tnat would need to besurrounded or lona distance tnat would have to be cut-off. In order to make theslurry w a l l an effective barrier, extraction well(s) would be neeaed to controltne watar level (i.e. the yradient) inside or behind the slurry wall. Pumpinyrates tor yradient control are less than tor extraction oecause the objectivesis to control the yrounuwater flow and not cleanup the aquifer. An extractionw e l l can by itself control tne migration of the plume so a slurry w a l l wouldadd unnecessary cost to a system with plunie stabilization as its objective.
AS a result of the evaluation in the Fb, a detailed evaluation of five yround-water collection schemes usiny the technoloyies tnat passed tne in i t i a l screeningwas pertonnea. The five schemes are: (i) extraction wells only, (2) extractionwells preceded by an interim plume stabilization well, (3) extraction wells inconciliation with an injection well, (4) extraction wells comoined with partialcontainment in a slurry w a l l around tne site, and (;>) a well to l i m i t plumemiyration.
Tne plume stabilization System whicn is the subject -of this document, is identi-fied and evaluated in tne HFb and is specifically evaluated in one potential
scneme in tne Fi>. In addition, as is stated in tne Fi>, if tne plumestabilization w e l l is installed in ly«/, it could replace tne down^raaientoTT-site w e l l included in all tne scneiiies (excludin-j scheme 2 wnicn includestne plume staoilization well).
"A numerical broundwater cuntannnant transport mooel was used to simulate tneeffect ot various yroundwater extraction schemes, it snould Be noted thatbecause or tne inherent problems ot precisely modeling tne natural environ-ment, assumptions must De made. In addition, tne mathematical equations usedare limited in various ways so additional error is introduced into tne results.Also, in this case there was not a loriy enough period of 3rounawater monitorinaresults a v a i l a o l e to Historically matcn tne ooserved contaminant distrioutiunpattern with modeliny results (this is referred to as calibration).
Because of tne Hualirications that must be applied in this case to tne resultso* yrounawater modeliny. The results should be used only as a basis of relativecomparison.
In order to Keep tne computer runs to a manageable number, indicator compoundswere selected from the contaminants detected in the ^rounawater at and near thebeyniour site. Tne indicator compound analyses was performed takin^ into con-sideration the mobility, concentration, toxicity and treatability of thecontamiiioiits identified in the yrounuwater. Based upon trie analysis, tnefollowing compounds were used in the droundwater wodeliny:
0 1,2 dicnloroetnane
0 tetrachloroethene0 vinyl chloride
Fetracnioretnene is used as tne indicator of ultimate yroundwater restorationbecause uf its relatively I ow-inooi I i ty. Tne mobihtj of vinyl chloride is notwell understood and tne literature contains partition coefficients tnat cuuldmake vinyl cnloride eitner one of the most mobile compounds or one of tne leastmooile compounds. Because of this uncertainty, vinyl chloride was not consideredin tne Fb wneri evaluating extraction scheme*.
Tne followiny b figures (Figures 4.2, 4.3, 4.3, 4.t>, A.17 anti A.ib) depict therelative distribution in lytfy of tnree contaminants of different mobility withand without tne plume stabilization well. As can be seen on trie figures, triearea of tne vinyl cniuride plume is siymricantly reduced out does s t i l l reachthe nearest receptor well; the 1,2 dichloroetnane plume is noticeably reduced;and tne tetracnloroetnene plume is virtually unaltered in confijuration. Tnedifference in projected plurne size and configuration are clue lar^el> to mobil-ity differences of the contaminants. The plume staoilization w e l l is effective,altnou^n nut totally so, in preventing oownyraaient migration of contaminantspast trie w e l l . Tetrachloroetnene, the Key compound in terms of yroundwatersnould not miarate past tne plume stabilization well.
Also usiny tne yrounciwater modeling, tne peak concentrations vinyl chloride,1,2 dicnloroetnane and tetraciiloroethene were predicted over time. M'buresA.1.J, A.14 and A.iy yrapnically represent tne yreater eTfectiveness of yround-water extraction scheme t, wnich includes the plume stabilization well.
-8-
Ditch
Crane Cemetary
Downgradient
0.50
Conctntrattons in 119/1
Cancer Risk Level1 x 10'6
Cancer Risk Levelx 10'5
Cancer Risk Level1 x 10'4
FreemanMunicipalAirport
SHALLOW AQUIFER
1000
FIGURE 4.2
PREDICTED DISTRIBUTION OF 1,2DICHLOROETHANE IN FALL 1989(ASSUMING UNALTERED NATURALGROUND WATER FLOW).
SEYMOUR RECYCLING CORPORATIONFEASIBILITY STUDYEPA WA 70-5L01.0
-9-
Von Fange Ditch
Crane Cemetary
Down Gradient
Cancer Risk Leveli x icr6
Cancer Risk Level1 x 10'5
Cancer Risk Level1 x 1(T4
FreemanMunicipalAirport
Conctntrationi in ug/l
1000
SHALLOW AQUIFER
FIGURE 4.3PREDICTED DISTRIBUTION OF TETRACHLOROETHENEIN FALL OF 1989 (ASSUMING UNALTERED NATURALGROUNDWATER FLOW).
SEYMOUR RECYCLING CORPORATIONFEASIBILITY STUDYEPA WA 70-5L01 0
-10-
Von Fange Ditch
Crane Cemetery
Concentrations in ug/l
SHALLOW AQUIFER
1000
FreemanMunicipalAirport
FIGURE 4.5
PLUME STABILIZATION WELL AND RESULTING PLUME OF1,2 DICHLOROETHANE PREDICTED FOR THE FALL OF 1989.
SEYMOUR RECYCLING CORPORATIONFEASIBILITY STUDYEPA WA 70-5L01.0
Si- Von Fan*
> «
Crane Cemetery
0.68BOGPM
FreemanMunicipalAirport
Conctntratiom in ug/l
SHALLOW AQUIFER1000
FIGURE 4.6PLUME STABILIZATION WELL AND RESULTINGPLUME OF TETRACHLOROETHENE PREDICTEDFOR THE FALL OF 1989.
SEYMOUR RECYCLING CORPORATIONFEASIBILITY STUDYEPAWA 70-5L01 0
-12-
SHALLOW AQUIFER
FreemanMunicipalAirport
FIGURE A.171989 DISTRIBUTION OF VINYL CHLORIDE WITHOUT PLUMESTABILIZATION ASSUMING LOWEST REPORTED RETARDATION
SEYMOUR RECYCLING CORPORATIONFEASIBILITY STUDYEPA WA 70-5LOT .0
-13-
Nurtst Rtctptor Well
Crane Cemetary
Concentrations in ug/1
Plum* Stabilization Well
FreemanMunicipalAirport
SHALLOW AQUIFER1000
FIGURE A.181989 DISTRIBUTION OF VINYL CHLORIDE WITH PLUMESTABILIZATION ASSUMING LOWEST REPQRT1D_RETA_RDAT[ON
SEYMOUR RECYCLING CORPORATIONFEASIBILITY STUDYEPA WA 70-5LOVO
CONCENTRATION IN PPB
CANCER RISK LEVEL*•
ui
CONCENTRATION IN PPB
CANCER RISK LEVEL
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Hie peaK concentration ot 1,2 dicnloroetnane unoer scheme 2 is consistentlybelow the peak concentrations predicted to occur unaer scheme 1. For 1,2Jicnloroetnane, tne time retired to restore the aquifer to a lirb cancer
'risk level is approximately 11 years snorter under scneme 2 than scneme 1.
For tetrachl oroetnene, tne peak concentration is also always less underscneme 2 than under scneme 1. Fne effectiveness of scneme 3 is even sreaterthan scheiiie 2 in reducina peak concentration over time of tetracn I oroetnene.&j comoinihy scheme J with a plume staoi I i zation w e l l , its effectivenessin reducing peak concentration over time woulu increase, scueme 3 wi tn aplume staoi I ization well is a part of the reconnnended alternative. Tniscombination, however, was nut modeled due to limitations in tne model and anattempt to keep trie numoer of simulation runs at a reasonable number.
Tne time to achieve a lu~° cancer risK level for tetracn I oroetnene is onlysilently reduced ( approximate ly 2 years) under scheme 2 in comparison tuscneme i. however, scheme J reduces tne a^ifer restoration time over scheme1 by approximately 7 years. Aaain, installing a plume stabilization well shouldincrease the effectiveness or scneme J. The mayhitude of tnat increase is notKnown precisely out reasonably ma.y be assumed to be tne incremental increasein effectiveness the plume stabilization w e l l had on scheme i. Kefer to theslope or the lines in nyure A. 14.
Vinyl chloride is discussed nere, However the information on vinyl chlorideshould ue viewed with considerable caution. For vinyl chloride, the effective-ness of scnene 2 iri reaucina peak concentration is suostantial, approximatelyan order of ma3nitude difference. However, tne difference is ^reatest arouna b-luyears arter pumpina starts. An important factor Figure A.iy illustrated is tnereduction of the peak concentration of vinyl chloride at tne nearest receptorwe l l that is ooserved under scheme 2 versus scheme 1. Tne nearest receptor wellis used for waterin^ cattle. Under scheme 2 the peak concentration of vinylChloride is approximately .* .̂arts per b i l l i o n (ypb) under scneme 2 and lu ppbunder scneme 1. fnis is a significant reduction because tne Safe UrinkirijAct proposed trtaxinium contaminant level (i»iCL) for vinyl chloride is 1
Because of the effectiveness of the plume stabilization system in miniinizinydownyradient contaminant migration, it is recommended in tne Fi in combinationwith the extraction/injection scheme as the ^roundwater extraction componentof the recommended alternative.
2. Uroundwater Uiscnarae ana Treatment
After the initial screening of technologies in the Fi, the reniaininy tecnno-loyies for discnarye of aroundwater were i.) surface discharge to a nearoy creek,2.) aquifer reinjection, and ^.) discharge to tne Seymour Wastewater TreatmentPlant (HUTrf). In all of these discharge options, treatment of the aroundwaterwould be necessary.
-Itt-
uased upon the initial screening ot yroundwater treatment tecnnoloyies, air strippin^ and carbon adsorption were retained for further evaluation. Tne FS deter-
. mined cnat oased upon trie wide variety OT or3anics present in the yroundwater,ootn tecnnoloyies would be needed to adequately treat the water. Trie or- jdnicsin tne arounawater include i,l,l trichluroetiidne, tetracnluroetnene, tricnioro-etnerie, i.ietnylene cnloride, toluene, benzene, xy lenes, phenols and acetone.iietals have not been detected in the yroundwater at signif icant concentration.
In addition to air scrippir iy and caroon adsorption, mixed-media f i l t rat ion isalso necessary Tor cost-etfect ive treatment. Tne mixed -media f i l ter w i l l removeiron ^recipiation and other suspended solids prior to the water f lowin^ ttirou^nthe caroun adsorption unit. lins f i l t rat ion w i l l prevent c luyy in j or tne carbonwiiich would 'reduce i t 's effect iveness.
Trie Hvjln nas a pretreatment program wiiicn sets standards for a l l o w a u l e oto the sewer system. The anticipated f l ow of tne pluine stabil ization w e l l , apprnrwtely ou-db ya lions per minute (yp>n) or llb,iiUU-lk:2,4UU ya lions per day, wi l l tnftpose a Hydraulic loadina problan on the POTW. The PUTk has a design capacity of4.J m i l l i on ga l lons per day (rnda) and tne current average f l o w is approximately J.Xniyd. Tne ^ O l w has a yood compliance record and is currently in compliance.because of tne H O f w ' s compliance proyrani, the pretreatment program, tne pretreat-ment of the yroundwater, and tne additional treatment at tne Horw, discnarbe totne Hofw is protective of public nealtn and the environment.
An NPOti permit would be necessary in order to discharge ^roundwater to a near-oj creek, (he discharge I imitations uf sucn a pennit, altnouan riot Knownprecisely, can be expected to be very strict because the receiving stream is anintermittent creeK. Thererore no dilution factor can be considered when settinydischarge criteria. To meet these anticipated discharge requirements a b io loy ica ltreatment process may nave to be added to the sequence identified above. Theaddition of o io loy ica l treatment would raise the cost of this option consiueraol^in relation to discharge to tne PUTw. Another factor that makes an NHuitSdiscnarye less practical for tne plume stabil ization system is tne tiifie that ittake to yet a pennit.
Keirijection of ^roundwater retires a pennit from the Indiana Jepartment oftnvironmental Manayement. As with the NPJ£i> permit discharge limitations, theinjection limitations are not precisely Known. However, tne luEM has indicatedthat tney strongly discourage reinjection, but have not commented on data sub-mitted to tnern containina expected ef f luent quality from the air stri^pind,mixed-media f i l ter, and carbon adsorption.
based upon trie cost and implauentaoi lity of trie discnarae to the HUTU afterair strippiny, mixed-media f i l tration, and carbon adsorption, this dischargeand treatment option is tne component of the recommended al ternat ive in tneFi.
-ia-
j. Alternatives in the Phased Feasibility btudy
ttased on tne cost dna tne effectiveness or tne plume stabilization well•and associated discharge and treatment processes, wnich were evaluated intne hb anJ summarized aoove, a phaseu redsioility study (HFb) was performedto evaluate wnether the plume staoilization system snould be implemented assoon as possible, wnetrier remedial action witn respect to aroundwater snoulabe delayed until tne tinai remedy is selected and implemented, or wnetner noaction in regard to jroundwater contamination is a^rupriate.
An evaluation or tnese three alternatives follows.
Alternative Evaluation
Tne alternatives under consideration in tne phased feasibility study were:i.; NO action; d.) ^au until tne rinal remedial action is selected anaimplemented; and 3.) Installation or a plume stabilization system.
Trie no action alternative is not appropriate because or tne existing threattu puoiic Health, welfare anu tne environment rroiii tne iiiyn concentrationsor contaiiiinants beneatn and miyratiny witn tne yroundwater rruw tne site.Additional potential threats to the public health, weirare and the environmentexist as contaminated 3roundwater miyrates away from the site and affects alarger area. Tne existitiy and potential public health and environmentalthreats are detailed in the Remedial Investigation Keport, Chapter a-tndanyer-ment assessment of tne NO Action Alternative, because or the rindinys ortins eiiJari.jer.nent assessment, tne draft reasioility study contemplateseither anuirer restoration or plume stabilization as a part or any rinalremedial action.
(Mere are no monetary costs associated with the implementation of tne no actionalternative.
Alternative '£, waitind until tne final remedial action is selected anu imple-mented amounts to no action in the short tenn. Uuriny tne estimated Z.s yearperioo (bprin3 lyd/ to Fall iytfa) that it may tane to select, take appropriateenrorcement action, and implement a final remedial action, a minimum of approx-imately J.U/ x lob cuoic reet (22,ybJ,6uu saiIons) aroundwater w i l l rlow beneaththe site and potentially become contaminated. The actual volume or ^roundwatertiiat w i l l become contaminated is dependent upon the mooility of different con-taminants and the actual increase in the J-dimensional extent or that ^artic-ular contaminant. The main body of the contaminant plume w i l l advance ,37t> feetduriny this <L.5-year period according to caiiputer modeiiny predictions. The edyeof tne plume as defined by the IxlU'b cancer risk level w i l l advance differentdistances ror uirrerent compounds over <i.b years. For example, the eoye or thevinyl cnloride plume could advance bUU reet; the J.,2 dichloroethane n'uiiie couldadvance 4su reet; and the tetracnloroethane plume could advance iiuu reet. Keterback to tne earlier fiyures ror graphic representation of the areal increase oftne respective contaminant plumes. Also previously discussed was tne increasederrectiveness or the various ^roundwater extraction schemes if the pluiiie staoi li-zation wel I is installed.
Monetary costs associdted with this alternative are limited to yrounawatermonitoring costs tnat would be necessary uuriny trie interim period. Howevertne installation and start-up costs or tne plume staDilization system would oeincurred auriny tne Tinal remedial action it U.S. tort's recommended alternativeis. ultimately implemented.
A reasondDle assumption is that tfie costs for installation and start-up or tneplume stabilization system, >3UU,OUU, woula oe necessary as a pilot study or aportion or trie design pnase or tne final remedial action. Tnis alternativemerely delays trie implementation or aquifer and treataDility tests which are -in-duces in tiie installation aru start Up costs or tne plume stabilization system.Thererore, tnis cost was included as a cost under this alternative. In adaition,soine arounawater iiionitonna woula oe necessary duriiiy trie intervening <i.5 yearperiod. H minimum ot one round or yroundwater sampliny and analysis every sixinontns is estimated. Tnis would result in b rounds of moniturin^ ror approximatelytwelve wells at a cost approximately SdUU per sample. This amounts to approximately
Tnis cost, in addition to tne installation and start up costs, total
Implementation or alternative J, tne plume scaoi I ization System w i l l minimize tne.nitration or contaminants down^rauient from the extraction w e l l ounriy tne ourationor tne public comment periou, tiie negotiation arid/or litiyation period witn poten-tial responsiole parties, and trie desiyn and iiiiplementation of a final reiiieay.assuming an ao Ballon per minute (ypm) puiiipin^ rate is continuously maintained rorthe d.5 year period assumed for tnis operaole unit, iUl,t>9(J,UUU gallons of con-taminated yrounuwater w i l l oe extracted, treated and discharged to tne Seymournastewater Treatment h'lant. Tnis system increases the effectiveness of any or the3roundwater extraction scnemes Dy reoucin^ tne area (and volume) of contaminated^roundwater, Dy reuuciny the peak concentration of contaminants in tne yroundwateranu by reauciiiy tne time needed to restore tne aquifer. Tne PKPs consultant,bera,nty 6 hi Her, estimates tnat installing the plume staoi 1 ization system w i l lreduce the time for aquifer cleanup by several years. Kurther, the area whereinstitutional controls may be needed is reduced. Institutional controls are acomponent of tPA's recommended alternative identified in the FS.
Tne experience yained from implementation of this system "would be extremely usefuland help expedite and refine tne remedial design of a final response action.
The plume stabilization well w i l l also reduce, although slightly the verticalgradient tnat exists in the confining layer between the shallow and deepaquirers. Tnis would reduce contaminant miyration into the deep aquifer.
The plume stabilization system is consistent witn all final remedies for thesite with the exception of no action. Key pieces of information that wouldbe obtained are: aMuifer behavior under stress (pum^iny), including puwpiriy rates,and drawciown, and treataoility results that can be used to maximize efficiencyof any final extraction and treatment systau.
AS previously stated, tne no action alternative is not acceptable and thereforetne drarc hi contemplates either aquirer restoration or plume stabilization asa component of any final remedy. Any remedial alternative selected w i l l be re-rined uased upon trie inTormation ootained from implenientinj tnis Operable unit.
berav,hty & M i l l e r provided the estimate or tne instal lation and start up costs.LPM provided tne estimate or tne 'J&ii costs.
The estimated costs ot tnis alternative are $Juu,uuu for installation ana startiV ot tne plume stabilisation systeni. Operation and maintenance (U&M) coststdr tne system are estimated ac *luu,uuU per year or a total of $ifbU,UUU for tnei!.t> .year ^eriod ^rior to i n|>le.iientatiori of tne f i n a l remedial action. Tneestimated total cost tor tnis alternative is
Table i provijes a sumsiiary ot the alternative evaluation.
Alternative
Alternative J, tne ^lu;ne stabilization system, is recommended oecause it w i l lstabilize trie migration ot contaminants in the shallow aquifer tor a relativelysmall cost, ODDU.UUU - iJ48,uou = >^iii,LiJU). Hie real cost results from tneoperation ana maintenance of tne treatment system and additional monitoringassociated witn trie effluent ana tne PUTW. Inis action w i l l minimize tnearea in winch tne public could potentially oe exposea to contaminants miyratinyfrom tne site ana the area that could require institutional controls. This w i l lalso reduce peak concentrations of contaminants and may reduce tne time ana thecost ot the final remedy. In addition, tne information yained ouriny implemen-tation of this System w i l l expedite ana allow optimization of tne design ot any^rounowater alternative selected as part ot tne final remedy.
This system is an effective way of addressiny yroundwater contamination causedQJ ana miyratiriy from the SKC site.
Tne plume staDi lization system is consistent with tne National Contingency Hlan,4U ChK Part iiuu.
Tne plume stabilization system includes an extraction w e l l , an ooservation w e l lana a pretreatment syscem Krior to discnarye to tne beymour Wastewater Tredtrnentplant. Fne wells w i l l De located north of tne western portion ot tne site(Myure 2). urounawater flow in tne snailow aquifer is nortn-riortnwest from thesite.
Prior to tne installation of tne plume staoi lization and observation wells,Camples w i l l be collected from selected monitoring wells. This set of monito-ririy results w i l l provide data on current water quality in the vicinity of theplume stabilization well.
The plume stabilization w e l l w i l l oe installed by tne cable tool .iietnod to adeptn of approximately 4t> feet below the land surface (Fiyure 3). Tne well w i l lbe completed witn an b inch diameter casniy and screen. The ooservation wellw i l l oe d r i l l e d in a similar manner.
Both w e l l s w i l l be constructed witn black steel pipe; a incn diameter for tneplume stabilization well and b incn diameter for tne observation well.
Stainless steel screens iu feet in length w i l l be installed at the bottomof tne u^per aquirer. Tne slot size of tne screens w i l l be determined fromtne results ot sieve analyses ot cuttings from tne lower 10 feet ot the upperaHui ter.
fABLt 1
ALf tKNAT iV tSUMrtAKf
bVALUAlMMlKlX
fecnnicdl
ic healthanu Me I tareCriteria
Alternativeno Action
A 1 1 ows continuedmigration ornazardous suo-
unacceptaole nealtnrisk.
Huulic riealtit risnexists ror in^estiondiiu absorptionof ^roundwater.Cancer risKlevel in yroundwater
fruni lxiU° toDuration ot
potential exposureis ^reater tndn1UU years for snal low^rourtdwater.
Al ternat ive '£Wait untiI Select ionuf Kinal KA
bee Uiscussiun forAlternative 1.Kelease is forsnorter ^eriou(̂ .i years is assumed).
bee discussion forAlternative 1.duration of potentialexposure reducedwhen final remedialaction is implemented.
AlternativeMume Staoi ISystem
izat ion
Grounawaterwi I I iiiinimizetion of contaminantplii'iie past ex t rac t ionw e l l .
Limits potentialexposure tojroundwater on-siteand a short distancedown^raoient. Risklevels remain the samebecause tne sourceis s t i l l present.
tnvi ronmentdlCriteria
Contaminated arouna-water plume continuesto expand ana itiay dis*charye to surfacewater.
bee discussion forAlternative i.Duration of expansionwiII end wnen finalreiiiedial action isimplemented.
liroundwater degradationand puDlic health risicminimized down^rduientof extraction we 11.
InstitutionalCriteria
uncontrolled hazardouswaste site does notmeet criteriafor KCKA and cannotbe deleted from tne
bee discussion forAlternative 1. HCKAand CtKCLA require-ments may oe metwhen final remediationis i.npleinented.
Al I applicable reMuire-ments wiI 1 be met torextraction, treatmentand discharge.
tstimatedLOSt
^Includes costs that would not be incurred in the final remedialaction if trie plume staoi lization system was installed.
2I2A ^^ ^ —* - == *=- .2IOA.B*«226
• tlllTIN* •0«ITO«II« Wflt
: ..2I3A.B.C -f
146^145x20€A,B,C
lie . --o.i- .
LOCATION OF PLUME8TABLIZATION AND OBSERVATION
WELLS
, p - - - ''jV-7 —'V*-^-. •
•CVMORE NECYCLMO CORPORATION
•f VMOAC. MDUNA
GENERALIZED WELL CONSTRUCTION DIAGRAMFOR PROPOSED PLUME STABILIZATION WELL
SEYMOUR, INDIANA r>D £ p \
A yravel paCK w i l l be installed around tne w e l l screens to b teet above thetop OT the screen. Tne yravei w i l l be followed uy 'd. reet or fine sand and theni teet ot bentonite pellets. The sanu prevents any bentonite truii entenny thescreened zone. The bentonite prevents migration ot fluids throuyh the annularso,ace into trie screened zone. Tne re-uaiiiuer of the annular s^ace is filledwith a cement/bentonite arout.
both w e l l s w i l l be developed oy pumpin^ ana Suryiny. Development w i l l taKeapproximately two days for the plume stabiIizacion well. A yood hydraulicconnection witn the aHuirer must be established. In addition, tne pumpinyrate ot trie w ell w i l l oe detennined duriny the development period. TheObservation w e l l w i l l oe developed for a period ot approximately d hours.o>on completion ot the ^lume stabilization well and the observation w e l l , astep test and an aquiter test w i l l oe pertonneu on tne plume stabilizationw e l l . "Ihe step test w i l l oeyin with a pu,.ipina rate of 3u gallons per minuteli»K"0, '"ill increase to t>U 3pm and w i l l end at dU-«3 y^ni. tacn step w i l l berun tor at least two hours. Ine pumpiny rates and the time allotted to eacnstep may be cnanyed auriny the test based upon tne data Aenerated.
water levels duriny tne step test w i l l be measured at appropriate intervalsso vecitic capacity values tor tne stabilization w e l l can be estimated.*/ater levels w i l l be Measured in the observation well and several well clustersin trie vicinity of tne plume stabilization well.
Trie aquifer test w i l l be run at a pumpiny rate of au-8b ypm for a period ofnot less than tive days, based upon the data generated duriny tnetest, trie pumpiny rate inay be increased and tne time period extended.
Junn3 tne aHuiter test, water levels w i l l be measured in the observation w e l lano several monitoririy wells at frequent, specific time intervals over theentire testind period. In the remaining monitorina wells, water levels w i l l beineasured dai ly.
quality saiiiplin^ and analyses w i l l be conducted durin3 the aquifer test.
MM water generated auriny tne step and aquifer tests w i l l pass throughpretreatr.ient system before discharainy to tne sewer system which w i l l carry tnewater to tne Seymour wastewater Treatment Plant.
Tne water withdrawn from the aquifer by tne plume stabilization well w i l l bepiped to trie pretreatinent system in the southeast portion of the trianyular area,just north of trie tenced portion of tne site.
Tne pretreatment system was developed takiny into account the Seymourwastewater Treatment Plant and tne East For* ot the White Kiver, which isthe ultimate receivina stream. Preventing a plant upset and meeting theplant's pretreatment requirements were the major concerns. The first pre-caution to prevent a plant upset is to acclimate tne plant with small volumesof contaminated water from tne site. The volume of water would be increasedover a several wee* period to build up a bacteria population that can tolerateana aearade the containi nants of concern.
-Zb-
Tne pretreatment system w i l l consist of an air stripper, d sana filter, ana acaruon dusorption unit.
*
Tne air striker w i l l be rirst in the pretreatment series. Tne air stripperw i l l remove a niyfi percentage or v o l a t i l e uryanic coi^ounds. Air is forcedupward into a packed tower counter current to tne flow or water. This countercurrent flow of air incrsases trie removal efficiency. The amount of airemissions is not expected to be larde enou^n to require emission controls.
The sand filter w i l l remove iron as it precipitates from the extracted around-water. iron precipitates out of solution wnen the extracted yroundwater isexposed to atiuospneric conditions (oxidizing conditions) in the air stripper anatrie iron oxidizes ana ^recipitates as an iron oxide. The precipitate can cloathe carbon particles in the carbon adsorption unit tnereby reducing the unit'sorganic removal efficiency, increases frequency or caroon replacenient wouldtnen oe necessary.
Trie caroon adsorption unit is the final step in tne pretreatment system. Organiccuirvounos inciuuiny soi.ie ot tne v o l a t i l e organic compounds tnat parsed tnrouantne dir striker, w i l l adsorb onto carbon ^articles as tne water flows tnrouantrie carbon bed. Preliminary plans call for a carbon unit with approximatelyi.>,uuu pounds of carbon. Caroon replacement costs are minimized 3j placing tneCdfoon un;t last in trie pretreatment system.
Vne decree and set)uencina of pretreatment may oe altered based u^on botn tneinfluent and etrluent water Duality in order to develop an understand!ny of thepretreatment system's effectiveness under varying operatiny conditions.
After pretreatment at the site, the water will be discharged to an existinymannole dt trie site from whicii tne sewer system w i l l carry tne water totne beymour wastewater Treatment Plant. The ^retreatment system describedriere w i l l allow tne discharge ^e^ui^elnents of tne Seymour Wastewater Treat-ment Plant to be met.
Compliance with other Envirunmental Laws
ine plume stabilization w i l l be operated in compliance witn all applicablelaws.
At tnis time the following environmental requirement is expected to apply.
- Pretreatment require^ients for discharge to tne ieymourwastewater Treatment Plant.
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
for the Public Comment Period
PHASED FEASIBILITY STUDY FOR GROHNOWATER CONTAMINATION
SEYMOUR RECYCLING CORPORATIONSeymour, Indiana
September 25, 1986
Seymour Recycling Corporation Responsiveness Overview
The U.S. Environmental Protection Agency (U.S. EPA) has completed
a Phased Feasibility Study (PFS) to evaluate an interim remedy for ground
water contamination at the Seymour Recycling Corporation (SRC) Superfund
site in Seymour, Indiana. The PFS was completed in August, 1985 under the
authority of the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), 42 U.S.C. 9601 et se£., and in accordance with the
National Contingency Plan (NCP), 40 C.F.R. Part 300.
EPA recommended a system be implemented to stabilize
the ground water contamination plume. The public comment period to
review the PFS was opened August 15, 1986 and closed September 8, 1986.
Notice of the Public Comment period was published in the local Seymour
newspaper (Attachment 1). Because the completion of the final Feasibility
Study was scheduled for September 1, a public meeting for the
PFS was unnecessary. Two written comments on the PFS were received during
the public comment period and the action is viewed as a positive step
toward remedying the contamination problems at the site.
The public will have an opportunity to comment on the document containing
EPA's recommended final remedial action. The final action as recommended
by EPA will incorporated the plume stabilization system.
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&ackground of the Phased Feasibility Study The remedial response activities
at the SRC site are being conducted under a case management order issued by
Judge Wm. E. Steckler of the Federal District Court, South District of Indiana.
In addition a "Stipulation and Order Regarding Meeting of Expert Consultants"
was entered into by the United States and the generator defendants in the
Spring of 1986. As a result of discussions held pursuant to the above stipulation,
the plume stabilization concept was developed. It was included and
evaluated in the final FS. In order to expediate implementation of the plume
stabilization EPA initiated the PFS to prevent the continued spread of
groundwater contamination. This system provides the following benefits:
the area of the shallow aquifer that may become contaminated is reduced,
the cost of the overall groundwater remedial action may be reduced,
the design of the final groundwater remedial action is expedited and
the effectiveness of all of the potential ground water extraction
schemes is increased.
Community Involvment and Concerns
Community interest at the Seymour Recycling Corporation site dates back to T976
when the site was reported by residents to the Indiana State Board of Health.
Community interest seems to have peaked Tri early 1980 when the state
court placed the site under receivership as a resutt of SRC failure to
abide by a 1978 agreement with the State of Indiana. Residents became
aware of the situation and were concerned with the potential danger of
soil and ground water contamination from hazardous organvc chemicals.
The site covers about 14 acres in a predominately agricultural area about
- 3 -
1/2 mile south of the Snyde Acres subdivision. The main concern continued*
to be the health hazards associated with groundwater contamination.
In the early stages of EPA's involvment the community felt it had not
received adequate information about the health hazards. The overall image of
EPA in the Community was regarded as "poor " and was generally due
to a lack of communication. The community continued to show interest
in the progress of EPA's studies.
A community relations program to address citizen's concerns is in
place. It provides for information concerning site activities to be available
to the citizens, involved agencies, elected officials and the media in a
timely manner. Information on the scope, progress and findings of the
Remedial Investigation/ Feasibility Study (RI/FS) has been released
through fact sheets reporting Superfund work and the settlement of monies.
Repositories have been established at the Seymour City Hall, the Seymour
Public Library and the Seymour Chamber of Commerce. It provides interested
parties the opportunity to review all site related documents.
The focus on the community concerns remains the possible health effects
from the contamination at the site and the need for communicating this infor-
mation to the community.
Interest and concerns of residents
Two letters were received from the public that commented on the PFS and
recommended alternative. Both letters were in favor of implementing the
plume stabilization system. Copies of the two public comment letters and
U.S. EPA's specific responses are attached (Attachment III).
ATTACHMENT 1
PUBLIC COMMENT PERIOD NOTICE
THE UNITED STATESENVIRONMENTAL PROTECTION AfiENCY
is accepting
PURL 1C COMMENTS
on the proposed Plume Stabilization Systemfor
SEYMOUR RECYCLING CORPORATIONSuperfund Site
U.S. EPA invites public comments on the "mini Feasibility Study"prepared for the proposed Plume Stabilization System.
Copies of the Remedial Investigation and the "mini FeasibilityStudy" are available for review at the Seymour Public Library,the Seymour City Hall and the Seymour Chamber of Commerce.
Comments on the proposed Plume Stabilization System must be receivedby EPA no later than SEPTEMBER 8, 1986.
Questions about the findings of the Remedial Investigation andcomments on the "mini Feasibility Study" for the Plume StabilizationSystem may be addressed to:
ART GASIORCommunity Relations Coordinator
U.S.EPA Region V230 S. Dearborn St.,Chicago, II. 60604
(312) 886-6128TOLL FREE - 1-800-621-8431 (9:00 - 4:30 Central Time)
U.S. EPA will conduct a public meeting and another public commentperiod on the full feasibility study after the study is releasedin September, 1986.
ATTACHMENT 2
LETTER FROM THE DEPARTMENT OF JUSTICE TO THE
DEFENDANTS PROVIDING NOTICE OF THE PUBLIC COM;<€NT PERIOD
U.S. Department of Justice
DTB:EH:gak62-26S-19
. D.C. 20530
August 26. 1986
All Counsel of RecordUnited States v. Seymour Recycling Corporation, et al.
Re: Phased Feasibility Study and Opportunity to Comment
Dear Counsel:
The Environmental Protection Agency (EPA) has issued aphased Feasibility Study which proposes the installation of aplume stabilization system for contaminated ground water at theSeymour Recycling Corporation site near Seymour,- Indiana. Enclosedis a "Superfund Fact Sheet/Update" for the Seymour site forSummer 1986. The report provides an overview of the RemedialInvestigation and the proposed plume stabilization system. Thepublic, including the defendants, are invited to submit anycomments that they may have on the phased Feasibility Study orthe proposed remedial action by no later than September 8, 1986.Directions for obtaining copies of the report or submittingcomments are on the last page of the report.
Notice of this public comment period was first publishedon August 15, 1986 in the Seymour local newspaper and sent topersons on the mailing list for the public maintained by the EPARegion V Office of Public Affairs. A form for placement on themailing list is also found on the last page of the report.
A copy of the phased Feasibility Study was providedlast week to Geraghty & Miller, consultants for the generatordefendants. This study follows technical discussions betweenthose consultants and EPA consultants and program staff.
The full Feasibility Study (FS) is scheduled to beavailable by September 1, 1986. Shortly thereafter a notice ofan opportunity for public comment will be made. After the publiccomment period EPA will issue its final decision on a remedy forthe Seymour site. Copies of the FS will be available for review
- 2 -
at public repositories. In addition, copies will be sent to leadliaison counsel for the generator defendants and to their consultantsGeraghty & Miller. Copies will also be available under theFreedom of Information Act.
Thank you for your attention to this natter.
Sincerely,
Assistant Attorney GeneralLand and Natural Resources Division
Eva Heffernan/AttorneyAssistant Regional Counsel Environmental Enforcement SectionU.S. Environmental Protection
AgencyRegion V
Enclosure
cc w/enclosure:All Counsel of Record (Distribution List Attached)Honorable William E. StecklerCharles GoodloeAnna Thode, EPA HQArt Gasior, EPA Region V, Office of Public Affairs
ATTACHMENT 3
PUBLIC COMMENT LETTERS AND U.S. EPA'S RESPONSES
GREATER
SEYMOURCHAMBER of COMMERCE
Tel«:
August 26, 1986
Honorable Art GasiorCommunity RelationsU.S. EPA Region V230 S. Dearborn StrutChicago, Illinois 60604
Dear Art,
Enciy»cd is a copx of my letter to Valda* Adamkus which w i l lstrvt as our conntnts on the SRC 'Phased* Feasibility Study.
There are several other questions that have cone to my mindsince writing the letter, but I w i l l save them for the publicmeetings to be held in September concerning the RemedialInvest igation.
I have written Judge William E. Steckler to get aclarification on the 'Phased" Feasibility Study vs. the FinalFeasibility Study. I hope to hear from both Judge Steckltr and Mr.Adamkus before the public comment period is over.
/JoHn D. BottorffPresident
JDB:g1s
Enclosure
GREATER
SEYMOURCHAMBER of COMMERCE
August 10, 1986 R E C E I V E D
Honorable Valdas V. Adair.kusUni t e d States Environmental Protection Agency AU5 2 1 1386Region V2?C S. Dea-bo-n S-reet U. S. FPA REC'CN 5Chicago, I l l i n o i s 60604 OFrICi C-f fcitiiJ-"- •.;;•.;•:,;»;;;.
Dear Mr. ndamkwS,
I aff, in r e c e i p t o* a copy o-f the E.P.A.'s "PHASED" F e a s i b i l i t - - Stud* -cr
Seymojr Recycling Corporation, which your agency is allowing 21 days *or &Lb!--:comr?nt.
Let me say -first that I was shocked to reac the term "PHASED" in theheading o-f the f e a s i b i i i : - study. It was our understanding that the E.F.A. ^scmade a corfmtment to Federal Judge U i l l i a m E. Steckler that you woc'ic preset: *.:hirr, by September 1, 198d. a F e a s i b i l i t y Study to clean up the subsu-iace atS.R.C, At no time have we heard the term "PHASEO" used in con.iunc: i or- w' tL:F e a s i b i l i t y Stucy. That crirase distorts everything we have beer t'OT-sei :••• r*fE.P.H. -for the past two years and, in our v i e w , is not in keeping wit h: t'>*mandate o-f Judge S'.eckler. I plan to bring this issue to Judge Steepler sattent i on.
Let me say. secondly, that the !4-page E.P.A. "PHASED" Fes='b ' '•• 5:.-=••report must be one o-f the shortest documents in the history o-f the E.P.A. isu-agency has taken l i t e r a l l y thousands o-f pages o-f history and test r e s u l t s ar.drec-ced them to this 14-page document. For that we are thank-fu 1. e<ce:: »:•- t-e*«ct that the -final product is not what was promisTcT!
O-f the three alternatives stated in your study, the best alte<-naVve isob'.-tously number three, which calls -for plume s t a b i l i z a t i o n and w : l l assist i ••.holding down the spreading o-f the contaminated ground water.
Our questions to you are:
1. Uhy are you recommending t h i s stop gap 2 1/2 yea'' pi'-mes t a b i l i z a t i o n measure instead o-f a total subsur-facecleanup which was proni.sed''
2. What is the E.P.A. going to do over the next 2 1/2 yearsthat you have not done in the last 2 1/2 years'!"'
k3. How many more delays do you expect a-fter 2 1/2 years" C.
cc: RF4. Is there a sc e n t i - f i c method a v a i l a b l e to achieve Little
a true subsrJr-face cleanup or is the government justbuying itseH anothe- 2 1/2 year delay and hopin g *cr amethod to be developed7
Mr. Adam*usAugust I',Page 2
Mr . Adamkus, we are not tryng to be offensive or uncoocerat i ve. w* wou'djust l i k e to ha"* ycur agency t& honest w i t h us. Jus*, t e l l us the tru t h ir,s:escof ad:mg de'a- s*ter deiax w h i c h creates f r u s t r a t i o n and distrus:.
If pluir.e s t a b i l i z a t i o n is the best and only method a v a i l a b l e at tr. is tirr,e,t^er, we wll accept that, but if the technology is a v a i l a b l e for a tctai ct.her. we exoect >our agency to act responsibly or t e l l us why you canno:.
Si ncerely,
President
cc: .'.'dae u • H ; ar. E. Steck'erSerijtor R i c h a r d Luoari»r.at?r Dan QL,ay!eCcr,;- essman Lee Ha/nil'.onMayor Ui i 1 i air, Bi i 1 ey0- . Joe BlackBoard o- DirectorsEn ronmertal Issues ComritteeDuct E u t l e r
GREATER
August 19,
Honorable U i l l i a m E. Steckler, JudgeUnited States District Court204 U.S. Court HouseIndianapolis, Indiana 46204
Dear Judge Steckler,
Enclosed is a copy oi my letter to Yaldas Adamkus in response to receivingthe E.P.A.'s 'PHASED* Feasibility Study -for Seymour Recycling.
I believe the letter is sell explanatory, but we did want you to know o-four shock at the E.P.A.'s latest delaying tactic.
Are you as surprised as I that they termed this a "PHASED* FeasibilityStudy and not a Final Feasibility Study?
I hope my letter finds you in good health. I look forward to yourresponse.
Sioferely,
'John D. Bottorf-fPresident
JDB/cjh
5RA-1*
01 SEP 1986
Mr. John 0. BottorffPresidentGreater Seymour Chamber of Commerce224 soutn Chestnut StreetP.O. 9ox 312Seynour. Indiana 47274
Dear Hr. Bottorff:
Thank you for your Interest In tn* Seynour Recycling CorporationSuperfund site.
The chased feasibility study evaluates the Implementation of a plinestabilization system. This phased or "Mini* feasibility study shouldnot be confused with the feasibility study for the comprehensiveremedial action for the site. The plume stabilization system 1s onlyone co>vonent of the U.S. Environmental Protection Agency's (<J.S. EPA)recommended remedial action.
You are correct in your understanding that a feasibility study was rfueto Federal Judge William E. Stickler, on September 1. 1986. A finalreport was sent to him, as well as yourself, on August 29, 1W. Asyou can see from the substance of that report, all pertinent si toInformation was taken Into consideration. That report contains therecomoended final comprehensive remedial action.
U.S. EPA agrees with you that the best alternative In the phasedfeasibility study Is number three: the plume stabilization system.
Answers to your specific questions follow;
Question 1:
U.S. EPA is recommending the plume stabilization system 1n orderto prevent further downgredtent migration of contaminated ground-water from the site. U.S. EPA recommends th'ls system be installedas soon as possible to allow for adequate time to work throughthe appropriate administrative and enforcement procedures necessary
to Implement a final comprehensive renedlal action. Two and one-half years Is the period estimated that It may take to Initiatethe final remedial action.
Question 2:
Over the next ? 1/2 years, several actions must be taken. Pursuantto an existing court order, U.S. EPA must negotiate with theregaining potentially responsible parties (PRPs) to determine Ifthe PRPs are willing and capable of Implementing the selectedremedial action, if a settlement cannot be reached, litigationwill be pursued or money from the Hazardous Substance Response Fund(Superfund) may be used. In addition, a design phase which couldbe conpHeated and time-consuming must be conducted. When a multi-million-dollar project 1s being undertaken. It 1s essential for acost-effective and technically sound Implementation that thedesign phase provide precise and accurate engineering plans andspecifications.
The design pnase will Include the preparation, review and approvalof several documents, as well as additional field work. After designIs completedt a qualified contractor will be necessary to Implementthe design. Preparing bidding documents and reviewing contractorproposals take additional time, as does working out acceptablecontract language with the selected bidder. Another factor In the2 1/2-year estimate 1s the Superfund reauthorlzatlon bill that Isbeing discussed by Congress. The Impacts of a new law on responseactions at the SRC site may take time to sort out.
Question 3:
U.S. EPA does not expect additional delays after the estimated ? 1/7-year period prior to Initiation of the remedial action. Delayshave occurred In the past and may occur In the future. However, U.S.EPA will do everything In Us power to avert or minimize any delays.
Question 4:
There are technologies available to achieve cleanup of the groundwater,and there are several technologies to achieve at least a partialcleanup of the subsurface soil. U.S. EPA's recommended alternativeIncludes groundwater extraction, which will cleanup the saturated sub-surface over a long period of time. To address subsurface soil cleanup,U.S. EPA recommends vapor extraction. This technology will remove thevolatile organic compounds which art generally the most mobile andtoxic organic compounds.
-3-
U.S. EPA believes that It Is Justified, both from • scientific andenvtron-aental perspective, to take advantage of any new technologiesthat way becone available between now and the completion of the vaporextraction process (approximately 1-5 years). Therefore, prior to In-stall Ing a cap on the SRC site. U.S. EPA recommends an evaluation ofthe available technologies to determine 1f a cost-effective technologyexists to supplement or replace the cap reconnended for the site.
Again, thank you for your consents, and If you have additional questionsfee) free to contact Art Galsor, Cenwunity Relations Coordinator at (31?)836-6128, or David Favero, Remedial Project Manager, at (31?)
Sincerely yours.
/•/ originalf •
Valdas V. AdawkusRegional Administrator
bcc: Larry Kyte, 5CS-16Art Galsor. 5PA-14OR AIrene LittleCarol Kavctc (control copy)Denise Reape
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, Indiana
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1ms 1$ 1n replj to /our l«tter of Seyteaoer i, 1*<»6 to Art fiaslortr* water qualttj of ewnltorlny well no. Ul. potential effects of cattleunr,Kliia content nateu aPc^iuwater end tne plu»e *t*oUl2«t1on
Honltorln, ««ll no. 131 near tn« Se/«our $1t« MIS l«$t *««plta tn June.no vwUtDe or»«nit continents, the contMln*nts of concern In the*<ter, i»ere detected In well no. 131. At jrt̂ sent there ere m* |»l«n$ to te*ttin* net I in trw n**r future. Howtvtr, there ere pUns to test we us no*.tU* enc » In Ute fall or winter. These wells art locetea a»»pro*1*«teljr2uu f««t soutr«-sojtr»e«$t of well no. 131. These te*t results -111 ».rov1ge us•Un Inforwatlon on tn« vru+rei* of ^roundwater cont*«1n«t1on «1*rat1n, oetweentne site aftd jour well.
If tne ^lum staDl Mutton systeu that fcFA 1s recoMMitdln* Is Installed, co«-t«*1n«i1o<i fciiouiu not reach jour well. If contamination would ^osslDljr r«acnjour wel t , tn« fastest *o*1n* contealnants are ««t exacted to be tnere untHl!»di>. Tne concentrations that would be expected are a 1 K iu'° Increase lite-t1i« cancer r»s« level. Th1* mans tftat If a nuaan wt1^1nv 70 kilogramlappronlJMtel/ 1!>4 pounds) drinks Z liters (t»»pro*1«atel> 2 quarts) of contea -nated water per aa; for 70 jtar*. tnat person woulu have • 1 In a Billion woulanave a 1 In a art 1 lion yreater chance of aevelopl** cancer than a person notdrin*1nu contMlnated water. Other potential to*1c effects on bod/ organs, tneMver or klane/s for example) would not ocoir until Beater concentrations ofcontaalnants are present and consuaied over a Ion, period of t1e». inls healtnrisk for nu»ans can be used «s a royyh yu1d« for wnat effects consu«lr% contami-nated water e*j have on cattle.
Cont1nu«o *round»ater «onitortny Is necessary to werlfy our contaminantMigration predictions. If significant conta*1nant concentrationsor1yti»«t1n* fro* tne &c/«our site reacn /our well, «M can then take an
action. You snow Id not oe financially responsible for anjrresponse.
1 hope tn1» answers /our questions. Don't hesitate to contact Art t»«1soror e^self at fcPft'i toll free nu^er l-tfuo-6ll-t»4Jl.
Sincere! j,
Oavio faveroRemedial Project Manager
tnforce««nt Section, Ill/Ind unit
DCC: Art balsor,Larr/
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