conrail/county road 1 project remedial …the conrail/county road 1 project area is located...

CONRAIL/COUNTY ROAD 1 PROJECTREMEDIAL INVESTIGATION ANDFEASIBILITY STUDY (RI/FS)

WORK PLAN

Work Assignment (WA) 01-5L7Y

July 1989

Prepared for:

U.S. ENVIRONMENTAL PROTECTION AGENCYARCS, REGION V

CONTRACT 68-W8-0086230 SOUTH DEARBORN

CHICAGO, ILLINOIS 60604

TABLE OF CONTENTS

Section Page

1 INTRODUCTION......................................... 1-1

2 BACKGROUND........................................... 2-12.1 SITE DESCRIPTION................................ 2-12.2 SITE OPERATIONS HISTORY......................... 2-12.3 SITE SPILL HISTORY.............................. 2-32.4 PREVIOUS INVESTIGATIONS/REGULATORY RESPONSE

ACTIONS......................................... 2-72.4.1 Conrail Facility......................... 2-72.4.2 Areas North of Conrail Facility.......... 2-12

2.5 ENVIRONMENTAL SETTING........................... 2-132.5.1 Regional Geology......................... 2-132.5.2 Local Geology............................ 2-142.5.3 Groundvater Occurrence................... 2-142.5.4 Surface Vater Occurrence................. 2-232.5.5 Climate.................................. 2-23

3 INITIAL EVALUATION................................... 3-13.1 OVERVIEW OF THE STUDY AREA...................... 3-13.2 CONCEPTUAL SITE MODEL........................... 3-2

3.2.1 Suspected Source Areas and ReleaseMechanisms............................... 3-2

3.2.2 Migration Pathways and Media Affected.... 3-63.2.3 Receptors and Exposure Routes............ 3-83.2.4 Data Needs............................... 3-8

3.3 APPLICABLE OR RELEVANT AND APPROPRIATEREQUIREMENTS (ARARs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10

ii

Table of Contents (Cont.)

Section

VORK PLAN RATIONALE.................................. 4-1

4.1 OVERVIEW OF WORK PLAN RATIONALE................. 4-14.2 PHASE I RI/FS OBJECTIVES........................ 4-2

4.3 SUBSEQUENT PHASE(S) RI/FS OBJECTIVES............ 4-34.4 DATA QUALITY OBJECTIVES......................... 4-3

REMEDIAL INVESTIGATION............................... 5-1

5.1 TASK 1: PROJECT PLANNING..t ..................... 5-15.2 TASK 2: COMMUNITY RELATIONS SUPPORT............. 5-2

5.2.1 Subtask 2.1: Community Relations Plan.... 5-25.2.2 Subtask 2.2: Fact Sheets................. 5-35.2.3 Subtask 2.3: Public Comment Period

Activities............................... 5-45.2.4 Subtask 2.4: Additional Community

Relations Implementation................. 5-55.3 TASK 3: SITE INVESTIGATIONS..................... 5-6

5.3.1 Subtask 3.1: Bid Specification Activitiesand Subcontractor Procurement............ 5-8

5.3.2 Subtask 3.2: Literature Search........... 5-85.3.3 Subtask 3.3: Field Investigation......... 5-8

5.3.3.1 Mobilization/InvestigationSupport......................... 5-8

5.3.3.2 Site Surveying and Mapping...... 5-95.3.3.3 Soil Gas Survey................. 5-95.3.3.4 Subsurface Soil Sampling........ 5-115.3.3.5 Sediment Sampling............... 5-165.3.3.6 Groundvater Monitoring

and Sampling.................... 5-165.3.3.7 Aquifer Characteristic Tests.... 5-21

5.4 TASK 4: SAMPLE ANALYSIS AND DATA VALIDATION..... 5-215.5 TASK 5: DATA EVALUATION......................... 5-22

iii

Table of Contents (Cont.)

Section Page

5.6 TASK 6: RISK ASSESSMENT......................... 5-225.7 TASK 7: REMEDIAL INVESTIGATION REPORT........... 5-24

5.7.1 Subtask 7.1: Computer Modeling........... 5-245.7.2 Subtask 7.2: RI Report Preparation....... 5-255.7.3 Subtask 7.3: Treatability Study/Pilot

Testing.................................. 5-27

6 FEASIBILITY STUDY.................................... 6-16.1 TASK 8: REMEDIAL ALTERNATIVES SCREENING......... 6-1

6.1.1 Subtask 8.1: Preliminary RemedialTechnologies............................. 6-2

6.1.2 Subtask 8.2: Establishment of RemedialResponse Objectives...................... 6-2

6.1.3 Subtask 8.3: Development ofAlternatives............................. 6-2

6.1.4 Subtask 8.4: Initial Screening ofAlternatives............................. 6-5

6.1.5 Subtask 8.5: Alternative Array Document.. 6-66.1.6 Subtask 8.6: Data Requirement............ 6-7

6.2 TASK 9: REMEDIAL ALTERNATIVES EVALUATION........ 6-76.3 TASK 10: FEASIBILITY STUDY REPORT............... 6-106.4 TASK 11: POST RI/FS ACTIVITIES.................. 6-10

6.4.1 Subtask 11.1: Post RI/FS Support......... 6-106.4.2 Subtask 11.2: Project Closeout........... 6-116.4.3 Subtask 11.3: Predesign Report........... 6-11

7 TASK 12: PROJECT MANAGEMENT.......................... 7-17.1 ORGANIZATION AND APPROACH....................... 7-17.2 PROJECT SCHEDULE................................ 7-37.3 PROJECT COSTS................................... 7-5

8 REFERENCES CITED..................................... 8-1

iv

Appendix Page

A SUMMARY OF ADDITIONAL HYDROGEOLOGICAL ANDCONTAMINATION INVESTIGATIONS......................... A-1

B RESULTS OF GROUNDWATER SAMPLING CONDUCTEDBY EPA/TAT........................................... B-1

LIST OF FIGURES

Figure

2-1 Study Area Location Map.............................. 2-2

2-2 Suspected Source Areas and Proposed Soil Boringand Sediment Sampling Locations...................... 2-4

2-3 EPA/TAT Soil and Vater Sampling Locations, July 31and August 1, 1986.................................. 2-9

2-4 Bedrock Topography................................... 2-15

2-5 Thickness and Extent of the Confining Layer.......... 2-16

2-6 Thickness of the Unconfined Aquifer.................. 2-18

2-7 Thickness of the Confined Aquifer.................... 2-19

2-8 Vater Table Surface of the Unconfined Aquifer,May 1979............................................. 2-20

2-9 Potentiometric Surface of the Confined Aquifer,May 1979............................................. 2-21

vi

List of Figures, Continued

Figure Page

3-1 Conceptual Site Model for Conrail/CountyRoad 1 Project....................................... 3-3

5-1 Conrail Facility Base Map............................ 5-10

5-2 Tentative Soil Gas Survey Sampling Locations(Alternative 1)...................................... 5-12

5-3 Tentative Soil Gas Survey Sampling Locations(Alternative 2)...................................... 5-13

5-4 Proposed and Existing Monitoring Well Locations...... 5-17

7-1 Project Organization for Conrail/CountyRoad 1 Project....................................... 7-2

7-2 Conrail/County Road 1 Project Schedule............... 7-4

vii

LIST OF TABLES

Table

2-1 Summary of Analysis of EPA/TAT-Collected Soil andWater Samples, July 31 and August 1, 1986........... 2-10

2-2 Daily Pumpage/Return from Aquifer at Elkhart CountyArea................................................. 2-22

3-1 Preliminary List of "Applicable" and "Relevant andAppropriate" Requirements for Conrail/County Road 1Project.............................................. 3-13

3-2 Preliminary List of "To Be Considered" Materials forConrail/County Road 1 Project........................ 3-16

5-1 Summary of Phase 1 Field Investigation Activities.... 5-7

5-2 Proposed Subsurface Soil and Sediment SampleAnalysis Details..................................... 5-15

5-3 Proposed Groundvater Sample Analysis Details......... 5-19

5-4 B & E Inc. Capabilities for Performing ComputerModeling............................................. 5-26

6-1 Technology Types Corresponding to Selected GeneralResponse Actions..................................... 6-3

viii

1. INTRODUCTION

This Work Plan was prepared pursuant to a Work Assignment (No.5L7Y) issued by the U.S. Environmental Protection Agency (EPA) toEcology & Environment, Inc. (E & E), under the Region V ARCS contract(No. 68-V8-0086). The plan describes the scope of activities that willbe performed for the Remedial Investigation/Feasibility Study (RI/FS)for the ConraiI/County Road 1 project area, located in Elkhart, Indiana.

This Work Plan is divided into 8 sections. Section 2 of the VorkPlan provides a summary of the background information, including a sitedescription and history of previous investigations, and local andregional geology, hydrology, and climate. Section 3 presents an initialreview of migration pathways, media affected, population at risk, anddata collection needs for conducting the RI/FS. Section 4 presents thework plan rationale and RI/FS objectives for this project. Sections 5and 6 describe the 11 tasks to be performed under the RI/FS. Section 7provides a description of E & E's project management approach andschedule. Section 8 includes all references cited in the development ofthe Vork Plan.

1-1

2. BACKGROUND

2.1 SITE DESCRIPTION

The Conrail/County Road 1 project area is located approximately1 mile southwest of the city of Elkhart, Indiana. The study area forthe project encompasses roughly 2,500 acres and includes the 675-acreConrail facility (also referred to as the site or railyard), plusseveral light industrial properties located to the north and northwestof the Conrail facility (see Figure 2-1). The study area also includesresidential areas south of the St. Joseph River, within which ground-water contamination has been identified based on analytical data fromprevious sampling efforts. The residential areas, designated as theCounty Road 1 area, the LaRue Street area, and the Charles Avenue area,are located to the northeast and northwest of the Conrail facility.Contaminants detected in samples collected from private wells in theseareas include carbon tetrachloride,, trichloroethylene, and othervolatile organics.

The study area, including potentially impacted areas, is bounded onthe north by the St. Joseph River, on the west by Baugo Bay, on thesouth by the southern border of the Conrail facility and on the east byMain Street.

2.2 SITE OPERATIONS HISTORYThe railyard began operations in 1956 as part of the New York

Central Railroad, and continued operations as a subsidiary of the PennCentral Transportation Company. In April 1976, Penn Central transferred

2-1

. !•,,..-.. :,..:::::;:;•••:!- i-A;:!:^^'•- ' " -«pr—jf _F. .:,.V:. _:,;_T f ••.--—;;^i

r-_, * .^ ^ fiii* ii • ** ' ''<-"-*K^ ^^f-S «-i_J _!'£:IT icUSURy f "|"*TSr — ;"T?V.

k!S:i?±33 iHy£-TTHb-'S03-^®,:

SOURCE. Ecology tnd Envlronm.nl. Inc.. I»S». BASE MAPS: U8OS. Elkhart, IN Quidr.ngl.. 79Mlnul« S«rl*l. 1»8I. PhotortvlMd 1981. USQS. Otnola. IN Oi«dr«ngl«. 75 Mlnul*S«rl«t. 1069, PhotoravlMd 1B80.

SCALIV,

LEGEND

EPA/TAT DESIGNATED TCE/CCUCONTAMINANT PLUMES FKJUBE 2-1 8TUOY AHEA LOCATION ttff

2-2

its railroad operations to the Consolidated Rail Corporation (Conrail).In October 1978, Penn Central finalized a reorganization plan thattransferred all of its rail assets to Conrail. The Conrail facilitycurrently serves as a classification and distribution yard for freightcars and is the primary connection between the Chicago area andConrail's northeastern rail system. The railyard also operates carrepair, car cleaning, and diesel refueling facilities on-site (Jacobs1987) (see Figure 2-2 for locations of diesel shop and car shop). Aninterview conducted by IDEM personnel with a former employee fromConrail revealed that solvents were used at the car shop and diesel fuelareas for degreasing purposes.

2.3 SITE SPILL HISTORYA history of oil and chemical spills, oil runoff into streams and

rivers, and complaints from the public has been associated with theConrail Railyard. The following is a compilation of documentedincidents that have occurred at the site (Jacobs 1987):

April 19, 1962 Indiana State Pollution Control Board(ISPCB) inspection noted pollution(unspecified) of Honey Creek, andultimately the St. Joseph River,resulting from railyard surface runoff atthe site.

, October 23, 1967 Diesel oil draining fron the railyard toCravford Ditch and the St. Joseph Riverprompted several complaints from thepublic.

December 11, 1967 ISPCB inspections noted that oil from therailyard diesel repair shop, refuelingarea, car repair, and car wheel lubrica-tion area contaminated the St. JosephRiver.

2-3

SOURCE: Ecology and Environment. Inc.. 1989.

1.000SCALE: I'-1,000'

l.ooo a.000 4.000 8.000 FEET

LEOENO

• SOIL BORINQ

V SEDIMENT SAMPLE

SUSPECTED SOURCE AREA

FKJURE 2-2 SUSPECTED SOURCE AREAS AND PROPOSEDSOIL BOflINO AND SEDIMENT SAMPLINQ

LOCATIONS

1-4

January 29, 1968 Oil pollution from the railyard prompteda complaint from a private citizen.

January 30, 1968

March 19, 1968

An oil discharge to the St. Joseph Riveroriginated from the oil separation pondat the railyard.

Dumping of oil from the railyard intoCrawford Ditch and the St. Joseph Riverat night and on weekends was alleged by alocal resident.

July 21, 1976 The Elkhart County Health Department(ECHO) investigated a 10,000-gallon oilspill to the St. Joseph River, which ittraced to the railyard. The spill wascaused by a washout of the oil separationpond.

June 12, 1977 Five thousand gallons of diesel fuelspilled onto the ground at the railyardafter unknown persons allegedly tamperedwith two locomotives in the railyard.

June 22, 1977 ECHO investigators reported an oil spillon June 17, 1977, from the oil separationpond at the railyard. Heavy rains hadcaused the oil to overflow the banks ofthe pond.

December 19, 1977 The ECHO investigated a 10,000-gallonspill of 48% caustic soda solution from aleaking tank car at the railyard.

2-5

July 13, 1978 An open dump associated with burning andoil spills at the railyard were reportedby the Elkhart Fire Department.

July 28, 1978 Conditions cited on July 13, 1978, wereverified by an ECHO inspection of therailyard. The inspection alsoestablished that the facility was usingan unlicensed vaste hauler.

August 28, 1978 An ECHO investigation found that pondingof oil, coolants, etc., existed at therailyard.

February 20, 1979 Indiana State Board of Health (ISBH)personnel reported a spill of 1,100pounds of hydrochloric acid from a tankerat the railyard.

July 2, 1981 A local resident alleged that an oilspill to the St. Joseph River originatedfrom the railyard. The ECHO determinedthat the spill occurred when the vails ofthe oil separation pond at the railyardwere washed away by rains.

February 12, 1982 A 27,000-gallon spill of grain alcohol atthe railyard resulted when the coupler ofa flatbed car rode up over the coupler ofa. moving tank car, causing the tank to bepunctured.

February 1, 1983 A 7,500-gallon spill of a naphtha-petroleum-based product at the railyardwas reported by ISBH.

2-6

February 8, 1983 The derailment of a boxcar resulted inthe spill of approximately 25 gallons offuel oil additives at the railyard.

October 13, 1984 An ISBH office memorandum noted a 250-gallon spill of diesel fuel at therailyard.

February 4, 1985 A rail car filled with liquidhydrofluoric gas (under pressure)developed a leak at the railyard.

November 27, 1985 An ECHO letter noted that a spill of7,500 gallons of diesel fuel occurred atthe railyard.

January 22, 1986 A confidential source reported to ECHOthat large quantities of railroad ties,trash, and track cleaner had been buriedsince 1957 at the railyard. The sourcealso noted that drinking water had tastedbad for the past 10 years.

September 16, 1986 An anonymous caller informed the St.Joseph County Health Department (SJCHD)that Conrail or its predecessor haddegreased engines and other equipmenton-site without containing the wastes.

2.4 PREVIOUS INVESTIGATIONS/REGULATORY RESPONSE ACTIONS

2.4.1 Conrail FacilityIn June 1986, a resident in the County Road 1 area reported

elevated levels of volatile organic compounds in his residential veil toEPA. On July 2, 1986, EPA Technical Assistance Team (EPA/TAT) collectedand analyzed a water sample from this residential well. Sample analysisindicated the presence of trichloroethylene (TCE) at 800 parts per

2-7

billion (ppb) and carbon tetrachloride (CCl ) at 485 ppb. Based on thisfinding, the EPA/TAT initiated a groundvater sampling program in theCounty Road 1 and LaRue Street areas, located to the northwest and northof the Conrail facility, respectively. Groundvater sampling began onJuly 17, 1986. A total of 88 residential wells were sampled by EPA/TAT.Concurrently, an additional 11 residential veils were sampled by indi-vidual well owners. These sampling results are presented in Appendix B,TablesB-1 and B-2. Sampling locations are presented in Appendix B,Figures B-l and B-2. TCE, CCl,, and other volatile organic compoundswere detected in many groundwater samples. TCE concentrations as highas 4,870 ppb and CCl^ concentrations as high as 6,860 ppb were detectedin this round of sampling. A total of 63 groundvater samples shoveddetectable levels of TCE or CC1,. Thirty-two groundwater samples hadlevels of compounds above the 10-day health advisories for either TCE orCCl^ (128 ppb for TCE and 12 ppb for CC14) (Roy F. Weston 1986b).

Bottled water was provided to residents whose veils vere affected.Additionally, tvo types of activated carbon filter unit vere installedin residences: point-of-use units and whole-house units. A total of20 point-of-use and 56 whole-house units vere installed (Roy F. Veston1986b). The IDEM is currently responsible for operation and maintenanceof these units.

EPA/TAT conducted a site assessment of the Conrail facility in Julyand August 1986. A total of 7 water/liquid samples and 21 soil samplesvere collected at the Conrail facility on July 31 and August 1, 1986.Five soil samples vere analyzed for total organic compounds, and theremaining samples vere analyzed for CC1,, chloroform (CHC1~), dichloro-ethylene (DCE) and TCE. The sampling locations are presented in Figure2-3; sampling depths and analytical results are presented in Table 2-1.Results of the analysis revealed TCE concentrations as high as 5,850ppb, and CC1, concentrations as high as 117 ppb in soil samples (Roy F.Weston 1986a).

EPA Environmental Response Team (ERT) conducted a soil gas surveybetveen September 2 and September 4, 1986. The soil gas survey vasconducted along the northern perimeter of the Conrail facility in theLaRue Street and County Road 1 areas. No conclusive data vere obtainedfrom the survey (Roy F. Weston 1986c).

2-8

to

S-63

CONRAIL

SOURCE: Ecology and Environment. Inc. 1989. ; Based on U.S. EPA/TAT Data. 1986.SCALE: V-1.000'

0 _______1.000 2.000 3.000 4.000 5.000 FEET

FIGURE 2-3 EPA/TAT SOIL AND WATER SAMPLING LOCATIONS. JULY 31 AND AUGUST 1. 1986

Table 2-1

SUMMARY Or ANALYSIS OF EPA/TAT-COLLECTED SOIL ANDWATER/LIQUID SAMPLES FROM THE CONRAIL FACILITY,

JULY 31 AND AUGUST 1, 1986

saapieDesignation

S61362S63364365S66S67

S68S69370371S72S73374S75

S76S77

S7S

S79SSO381382S83S84S8SS86S87S88

SaapleType

Water (east culvert)Water (pond)Sedisient (shore line)Liquid (tank)WaterWater (pu»p house)Liquid (old separatortank)

SoilSoilSoilSoilSoilWater ( in hole)SoilSoil

SoilSoil

Soil

SoilSoilSoilSoilSoilSoilSoilSoilSoilSoil

SacpleDepth(inches)

1224400-3

16-18

1236

66

6

2210366201812162024

vocDetected

NDNDIfDND

NOND

PCS

NDNDNDNDNDNDNDCC1,TCA

ND

TCETCA

TCADCECC1,

DCEND

NDNDNDNDNDNDND

ND

Concentration(ppb)

54,100*

70505

5,850380

3,360186117

120

ND • not detected.• This datua was reviewed by the laboratory and was invalidated.

Source: Ecology and Environment, Inc. 1989; based on data fro* Roy F. Weston 1986.

2-10

The Conrail facility was scored 42.24 using the Hazard RankingSystem (HRS) model and became a candidate for the National PrioritiesList (NPL). Based on the HRS score of 42.24, the Conrail facility vaslisted on the NPL, Proposed Update 7 Sites (by Group), in June 1988(Federal Register June 24, 1988). The Conrail facility became aproposed NPL site under federal and state responses.

EPA issued a work assignment to Jacobs Engineering Group, Inc., toperform a Potentially Responsible Party (PRP) search for the Conrailfacility. The purpose of this investigation vas to establish a historyof site ownership, operations, and disposal practices; identify PRPs,including previous and current ovners and operators of the site, andthose parties who were either generators of hazardous wastes ortransported wastes to the site; and verify current addresses of thePRPs.

The results of this search were presented in a three-volume report.Major findings and conclusions of this search as presented in thisreport (Jacobs Engineering Group, Inc. 1987) include documentation of:

o An extensive history of oil separation pond discharges andtank car spills.

o Past use of three waste stabilization ponds for carclean-out operations and the existence of an on-site dump.

o Railyard areas designated for parking tank cars leakinghazardous naterials. t

As a result of the investigations described above, EPA sent aspecial notice letter to Conrail dated June 27, 1988, which Conrailreceived July 1, 1988. This special notice letter offered a 60-daymoratorium period, beginning July 1, 1988, for Conrail to negotiate withEPA in "good faith" to undertake the the Remedial Investigation andFeasibility Study (RI/FS) at the Conrail facility. The 60-daymoratorium period expired on August 30, 1988, and EPA determined thatConrail had not presented a "good faith" offer to conduct the RI/FS atthe Conrail facility.

2-11

Conrail retained Groundvater Technology, Inc. (GTI), of Indiana-polis, Indiana, to evaluate the Conrail HRS rating (42.24) as scored byEPA. GTI challenged assumptions used by EPA to obtain the HRS score of42.24, and in a report dated August 1988, proposed a score of 7.07.Apparently because of the GTI challenge to the rating, Conrail declinedthe opportunity to conduct the RI/FS at the Conrail facility. EPAissued a work assignment to E & E under the EPA Region V AlternativeRemedial Contracting Strategy (ARCS) contract to conduct the RI/FS atthis site.

2.4.2 Areas North of Conrail FacilityThe Martin Drum site is a 14-acre property located immediately

north of U.S. 33, approximately 1.6 miles vest of State Road 19 (seeFigure 2-1). On September 19, 1985, the ECHO discovered drums at thesite while investigating open burning. After frequent contacts by theEPA On-Site Coordinator (OSC), the property owner, Mr. C. P. Martin,agreed to have the contents of the drums analyzed and disposed ofproperly (Roy F. Weston 1986c).

EIS Environmental Engineers, Inc., was retained by Mr. C. P. Martinto conduct soil and drum sampling at this site. A total of 8 soilsamples from depths of between 2 and 4 feet below grade were collectedand analyzed for volatile organic compounds. TCE was detected in 3samples, with concentrations ranging from 20 to 39 ppb. Other volatileorganic compounds, such as tetrachloroethylene (100 ppb in 1 sample),toluene (21 to 1,100 ppb in 3 samples), ethylbenzene (1,000 ppb in 1sample), and xylene (24 to 10,000 ppb in 3 samples), were detected. Iniaddition, drum contents were tested for EPA hazardous waste characteris-tics (EP toxicity for metals, ignitability, and corrosivity). None ofthe drum samples exhibited the characteristics of corrosivity. Some ofthe drum samples exhibited characteristics of EP toxicity and ignita-bility (EIS Environmental Engineers, Inc. 1986).

Twenty-eight drums containing waste paint were removed from theMartin Drum site on May 22, 1987. The drum contents were disposed of inthe Chem Fuel program, and were incinerated by Environmental WasteResources at Coal City, Illinois (McCaslin & McCaslin 1988).

2-12

Peerless-Midwest, Inc., studied the water quality and hydrology inthe vicinity of Charles Avenue, located about half a mile east of BaugoBay, and approximately 1 mile northwest of the west edge of the Conrailfacility (see Figure 2-1). As part of this study, six monitoring wellswere installed; these monitoring wells and one existing residential wellwere utilized in the study. The subsurface drilling logs and supportinggamma ray log indicated the presence of a clay layer that was 31 feet atits thickest point and thinned to less than 1 foot. The clay layer wasentirely absent in one well. Groundwater samples from the shallow wells(< 30 feet deep) were clean, but samples from the deep monitoring wells(> 110 feet deep) were all contaminated with VOCs. VOCs detected indeep wells were TCE at a maximum concentration of 2,495 ppb, and CC1, ata maximum concentration of 388 ppb (Peerless-Midwest, Inc. no date).

2.5 ENVIRONMENTAL SETTING

2.5.1 Regional GeologyIndiana has been extensively glaciated, with almost 90X of the land

surface covered by glacial material. The northern two-thirds of thestate was affected by the last major episode of glaciation, theVisconsinan. Glacial lobes entered the state from two directions, northout of the Lake Michigan basin and northeast out of the Lake Erie andSaginaw Bay basin. Six or seven till sheets from at least four majorglacial episodes cover northern and northeastern Indiana. Some of thesheets may be missing in parts of northern Indiana due to glacialerosion of the sheets formed earlier. These till sheets rest sharply oneach other, and are usually separated by sand and gravel outwashdeposits (USGS 1981).

The principal bedrock formations in Indiana are associated with thePennsylvanian, Mississippian, Devonian, and Silurian periods. Thesesedimentary rock formations are composed of sandstones, siltstones,shales, limestones, and dolomites. These formations represent a seriesof inland seas that occupied Indiana and the surrounding states duringthe Paleozoic Era. Outcrops of these formations exist where the glacialmaterial overburden does not exist. The bedrock in the northern part ofthe state dips to the northeast into a structural depression called theMichigan Basin (USGS 1981).

2-13

2.5.2 Local GeologyIn the study area, four episodes of glaciation have left deposits

of stratified and unstratified drift, ranging in thickness from 150 to250 feet, over the bedrock. The surficial geology is characterized by avalley-train outvash deposit bounded by till plains to the north, south,and southwest of the study area. The drift aquifer consists of mediumto coarse sand, silty sand, and gravel (USGS 1981).

Surficial soils at the Conrail facility area have been disturbedand no series is recognizable. Sixty-five percent of the surfacematerial in the Conrail facility area is composed of ballast andconcrete (Jacobs 1987). Ballast and concrete generally have high voidratios and are highly permeable.

A 16- to 20-foot thick silt and clay layer exists in some parts ofthe study area. The surface of this layer is approximately 40 to 60feet below grade in the study area (USGS 1981).

The glacial deposits are underlain by the Coldwater shale ofHississippian age and the Ellsworth shale of Devonian and Mississippianage. The Coldwater shale is a greenish-grey shale with alternating bedsof red shale. The Ellsworth shale is a greenish-grey shale withalternating beds of black shale. Both units contain occasional lensesof dolomite or limestone (USGS 1981).

The bedrock surface under the study area slopes to the east towardthe axis of a northeast-southwest trending pre-glacial valley locatedunder the eastern edge of the area. The general trend of the dip in theregion is to the northeast. The bedrock relief in the area is approxi-mately 150 feet, but the valley bottom is 450 feet below grade. Figure2-4 shows the bedrock topography (USGS 1981).

2.5.3 Groundwater OccurrenceThe Elkhart area is underlain by an areally extensive thick outwash

deposit composed of sand and gravel. These deposits generally havemedium to high permeability and very low moisture capacity. The 16- to20-foot silt and clay confining layer is present below most of the studyarea. Vhere present, this silt and clay layer divides the aquifer intoshallow (unconfined) and deep (confined) aquifers. Figure 2-5 presentsthe silt and clay confining layer thickness. Shallow (unconfined) and

2-14

SOURCE: USQS Water Resources Investigation. Hydrologic and Chemical Evaluation of the GroundwaterResources of Northwest Elkhart County, IN, 1981.

SCALE1

CONTOUR INTERVAL 50 FEET, DATUM: MSL

5 MILES

FIGURE 2-4 BEDROCK TOPOGRAPHY

2-15

••..••.CONFINING LAYER v.--^

$£a::-;;

.. AREACONFINING LAYER

SOURCE: USGS Water Resources lnv«stlgation, Hydrologic and Chemical Evaluation of the GroundwaterResources of Northwest Elkhart County. IN, 1981.

SCALE 5 MILES

ISOPACH INTERVAL 20 FEET

FIGURE 2-5 THICKNESS & EXTENT OF THE CONFINING LAYER

2-16

deep (confined) aquifer thicknesses are shown in Figure 2-6 and Figure2-7, respectively. This confining bed is not present on the eastern andwestern edges of the study area; therefore, in these areas a singleunconfined aquifer exists. Bedrock aquifers are not considered animportant source of water in this area due to their depth, low-yieldingcharacter, and the general occurrence of productive aquifers within theglacial material (USGS 1981).

Groundwater elevations in the study area in both confined andunconfined aquifers ranged between 720 and 735 feet mean sea level (MSL)in May 1979 (see Figures 2-8 and 2-9). These elevations correspond towater depths of approximately 5 and 15 feet below ground surface.Groundwater flow direction in both aquifers was toward the north/northwest in the direction of the St. Joseph River and Baugo Bay.Groundwater flow direction in areas north of the St. Joseph River wasalso toward the river. Horizontal groundwater gradient in the uncon-fined aquifer ranged from 0.003 to 0.006 ft/ft. Horizontal groundwatergradient in the confined aquifer ranged from 0.003 to 0.009 ft/ft. Thevertical groundwater gradient is difficult to estimate from figures dueto contour intervals used. However, vertical water level differences oftwo feet in areas away from the St. Joseph River and five feet in areasnear the St. Joseph River were measured, indicating an upward gradientnear the river (USGS 1981).

Groundwater flow data indicate that the St. Joseph River ishydraulically connected to the outwash aquifer in the study area and isa discharge zone for this aquifer. Groundwater pumpage is anotherdischarge source for this aquifer. The locations from which majorgroundwater users pumped are shown in Figure 2-1. The 1974 to 1978average daily pumpage from, and return to, the designated aquifer aregiven in Table 2-2. Precipitation is the only source of recharge tothis aquifer. For the period 19A1 to 1970, the average monthly rainfallranged from 1.69 inches in February to 3.91 inches in July (U.S.Department of Commerce 1968).

Permeability (lateral) of the aquifer is estimated to be 80feet/day for sand and 400 feet/day for sand and gravel material.Transmissivities of the unconfined and confined aquifers were estimatedby summing the products of the saturated thickness of each lithologic

2-17

SOURCE: USQ8 Water Resources Investigation, Hydrologic and Chemical Evaluation of the QroundwaterResources of Northwest Elkhart County, IN. 1981.

SCALE1 5 MILES


FIGURE 2-6 THICKNESS OF THE UNCONFINED AQUIFER

2-18

SOURCE: USQS Water Resources Investigation, Hydrologic and Chemical Evaluation of the QroundwaterResource* of Northwest Elkhart County, IN, 1981.

SCALEO ^ ^ J _ _ _ _ _ 2 ^ 3 _ _ _ _ _ * ^ 5 MILES


FIGURE 2-7 THICKNESS OF THE CONFINED AQUIFER

2-19

SOURCE: USQS Water Resources Investigation, Hydrologic and Chemical Evaluation of the GroundwaterResources of Northwest Elkhart County, IN, 1981.

1SCALE

2_____3

CONTOUR INTERVAL 5 FEET, DATUM MSL

5 MILES

FIGURE 2-8 WATER TABLE SURFACE OF THE UNCONFINED AQUIFER, MAY 1979

2-20

SOURCE: USQS Water Resources Investigation, Hydrologic and Chemical Evaluation of the QroundwaterResources of Northwest Elkhart County, IN, 1981.

SCALE

O^^J Zmm^^ 4 5 MILES

CONTOUR INTERVAL 5 FEET, DATUM: MSL

FIGURE 2-9 POTENTIOMETRIC SURFACE OF THE CONFINED AQUIFER, MAY 1979

2-21

TABLE 2-2

Daily Pumpage/Return from Aquifer at Elkhart County Area^ '

Pumping Center

City of Elkhart (3)

N. Main St. well fieldBower St. well fieldSouth well field

Major Industry

Average daily

1974-1978

Unconf inedAquifer

5.7500

0.63

pumpage Average daily return(2)

ConfinedAquifer

00.691.15

3.16

1974-1978(2)

Unconf inedAquifer

000

1.64

Source: USGS 1981.(1) Table is based on an old source; current pumpage may be different.(2)" Million gallons.(3) For well field locations refer to Figure 2-1.

2-22

unit (sand or sand and gravel) and the hydraulic conductivity of eachunit. Transmissivities calculated for the unconfined aquifer in theElkhart County area range between 4,000 ft2/day and 175,000 ft /day.Transmissivities calculated for the confined aquifer range betveen 5,000? 2ft /day and 85,000 ft /day. Permeability (lateral) of the silt and clay

confining layer is estimated to be approximately 0.1 ft/day. Verticalpermeabilities for the sand and the sand and gravel material forming theaquifer are estimated to be 8 ft/day and 40 ft/day, respectively.Vertical permeabilities for the silt and clay confining layer and forthe riverbed are estimated to be 0.007 ft/day and 0.67 ft/day,respectively (USGS 1981).

2.5.4 Surface Water OccurrenceThe major surface water bodies in the vicinity of the study area

are the St. Joseph River and Baugo Bay. The St. Joseph River flowswestward and is located approximately 1 mile north of the Conrailfacility. Baugo Bay flows north into the St. Joseph River and islocated approximately 1/2 mile west of the site.

The approximate surface elevation at the site is 745 feet HSL andthe estimated average surface elevation of St. Joseph River and BaugoBay at their nearest points to the site is 718 feet HSL. Naturalsurface drainage of the area would be to the northwest, but because ofurbanization, the actual pattern is undeterminable.

Crawford Ditch originates at the site and flows intermittently tothe St. Joseph River. Three elongated ponds also are present along thesouthern periphery of the site.

2.5.5 CliaateBlUiart County has a temperate, humid, continental climate that is

essentially uniform over the entire county. The mean annual precipita-tion is approximately 34 inches, and the monthly mean temperature isabout 49° F. Elkhart County has four well-defined seasons. Late springand early summer are often characterized by the greatest amount ofprecipitation. In April and May, there is an average of 8 days havingat least 0.10 inch of rain. In June and July, there is an average of 7days having at least 0.10 inch of rain. Thunderstorms are the primary

2-23

source of summer rainfall. July is the warmest month of the year, andtemperatures of 90°F or higher are recorded on an average of 8 days ayear. Relative humidity, on an average summer day, varies from 403! inthe afternoon to 90Z or higher just before dawn. Fall is usually markedby moderate temperatures, the least amount of rainfall, and sunshinethat averages about 70% of the maximum possible. In vinter, there is anaverage of 7 days with temperatures below 08F. January is usually thecoldest month. Snowfall occurs as early as October and as late as Hay.The largest amount of snowfall is in February, and the average yearlysnowfall is 25.9 inches. The soil is typically frozen for 3 to 4 monthsduring the winter (United States Department of Agriculture SoilConservation Service 1974).

2-24

3. INITIAL EVALUATION

3.1 OVERVIEW OF THE STUDY AREAA proposed National Priorities List (NPL) site, the Conrail

facility is suspected of being responsible for groundvater contaminationin dovngradient areas to the north and northwest of the site. The IDEHhas documented several reports of chemical spills and discharges at theConrail facility. A soil sampling investigation conducted by EPA/TATdetected volatile organic contamination including CC1, at a maximumconcentration of 117 ppb, TCE at a maximum concentration of 5,850 ppb,TCA at a maximum concentration of 3,360 ppb, and DCE at a maximumconcentration of 186 ppb (Roy F. Veston 1986a).

The proximal boundary of the County Road 1 contamination area issituated adjacent to the vestern end of the Conrail facility. Analysisof groundvater samples from residential veils in this area and fromfarther northvest near the St. Joseph River, conducted by EPA/TAT, IDEM,and some residents, has indicated contamination with CCl, at a maximumconcentration of 6,860 ppb, and TCE at a maximum concentration of 4,870ppb (Roy F. Veston 1986b).

The LaRue Street contamination area runs northeast from a locationadjacent to the northern perimeter of the Conrail facility. Groundvatersampling conducted by EPA/TAT has indicated contamination vith TCE at amaximum concentration of 300 ppb, and CCl^ at a maximum concentration of150 ppb (Roy F. Veston 1986b).

The Charles Avenue contamination area is situated immediately eastof Baugo Bay, approximately one mile northvest of the Conrail facility.Analysis of groundvater samples from monitoring veils and residential

3-1

veils in this area has indicated TCE contamination at a maximum concen-tration of 2,495 ppb, and has also identified other volatile organiccompounds in the deep (confined) zone. No groundvater contamination hasbeen detected in the shallow (unconfined) zone in this area (Peerless-Midwest no date).

3.2 CONCEPTUAL SITE MODEL

A conceptual site model for the Conrail/County Road 1 study areahas been developed based on an analysis of existing data obtained fromthe EPA and IDEM. Information collected during E & E site visits wasalso used in developing the conceptual site model. The suspectedsources, potential release mechanisms, migration pathways, mediaaffected, and the receptors for the study area were preliminarilyidentified in preparing this model. Figure 3-1 illustrates theconceptual site model. This model was used to help: 1) evaluatepossible public exposures and potential health risks, both on and offthe site, and 2) determine data needs for scoping the RI/FS activities.As will be further described in Section 4, the RI/FS for the Conrail/County Road 1 project will be conducted using a phased approach. At theend of each RI/FS phase, data gaps will be identified and the scope ofwork for subsequent phase(s) will be determined. The components of theconceptual site model are presented in the following sections.

3.2.1 Suspected Source Areas and Release MechanismsThe first and second components of the conceptual site model are

the contamination sources and release mechanisms.Suspected contamination source areas within the Conrail facility

are shown in Figure 2-2 and listed in Figure 3-1. These areas wereoutlined in a previous investigation report (Jacobs Engineering Group,Inc. 1987) and include the following:

o A surface/subsurface disposal area located in the northeastquarter of the site. The nature of the disposal practicesin this disposal area is unknown. One report indicatesthat large quantities of railroad ties, trash, and trackcleaner (chemical unknown) have been buried in these areas

3-2

PRIMARY SOURCE RELEASE MECHANISM SECONDARY SOURCE RELEASE MECHANISM MIGRATION PATHWAY MEDIA AFFECTED RECEPTORS AND EXPOSURE ROUTESHUMAN BIOTA

AREA WTE TERRE8- AOUATCRESDENT VISITOR TRIAL

SOURCE: Ecology and Environment. Inc 1969

* To be studied In Phase I InvestigationCD Suspected sources in Corirall facility! I: Other possible sources outside ol the

Conrail facility suspected ol contributingto the groundwater contamination plume

| A«AR

1 SURFACE WATER(StJoM|*rt,BaugoB>r)

.n.1 **

1 *| OROUNDWATER

-»>

s

\\

MQESTION

MHALATO)

CONTACTNOESTCN

CONTACTNQESTION

DERMAL

NOESTCN

MHAIATDN

DERMALCONTACT

A

0

A

•

•

A

A

A

A

A

A

A

A

A

A

0

0

• High probabllHy0 Medium probabilityA Low probability

FIGURE 3-1 CONCEPTUAL MODEL FOR CONRAIL /COUNTY ROAD 1 PROJECT

3-3

since 1957. Infiltration/percolation would be the releasemechanism for contaminants in this suspected source area.

o The diesel shop situated off the facility's north accessroad, near the northeastern boundary of the site. An ISPCBinspection noted that oil spills or leaks from the dieselshop area caused contamination in the St. Joseph River.Additionally, an anonymous caller informed the St. JosephCounty Health Department (SJCHD) that Conrail or itspredecessor had degreased engines in this area withoutcontaining the wastes. Leaks and spills would be theprimary release mechanism, and infiltration/percolation,storm water runoff, and volatile emission would be thesecondary release mechanisms for contaminants in thissuspected source area.

o Three areas located on the western, southwestern, andeastern portions of the site designated for parking leakingtank cars. It is not known whether a containment orcollection system was available in these areas to recoverthe leakage. Infiltration/percolation, storm water runoff,and volatile emission would be the release mechanisms forcontaminants in this suspected source area.

o Three waste stabilization ponds, also referred to as borrowpits, located south of facility's the south access road.No information is available concerning the type of wastestabilized in these ponds. In the latest site visitconducted by B & E, EPA, and IDEH personnel on March 27 and28, 1989, attempts were made to locate and observe the con-dition of the ponds. The easternmost of the three pondswas located, but it was observed to be dry. The western-most pond was located; it contained water, but the waterappeared to be clear. The third pond was not located.Infiltration/percolation, storm water runoff and volatile

3-4

emission would be the release mechanisms for contaminantsin this suspected source area.

o A primary oil separator and an equalization tank that wereinstalled west of the diesel shop in 1970. The conditionof the primary oil separator and equalization tanks isunknown. Leakage and spills would be possible primaryrelease mechanisms for contaminants in this suspectedsource area. Infiltration/percolation, storm water runoff,and volatile emission would be possible secondary releasemechanisms for contaminants in this suspected source area.

o A secondary oil separator, oil separation pond, undergroundtank, and Crawford Ditch. Both the oil separator and theunderground tank were operating between 1967 and 1984.There have been numerous reports of oil spills from the oilseparation pond. In addition, the condition of thesecondary oil separator and the underground tank isunknown. Leakage and spills would be possible primaryrelease mechanisms for contaminants in this suspectedsource area. Infiltration/percolation, storm water runoff,and volatile emission would be possible secondary releasemechanisms for contaminants in this suspected source area.

o A car shop located on the western part of the site. Thenature of the operation in this car shop area is not known.However, it is possible that solvents were used fordegreasing in this area. Leakage and spills would be theprimary release mechanism, and infiltration/percolation,storm water runoff, and volatile emission would be thesecondary release mechanism for contaminants in thissuspected source area.

In addition to the suspected source areas identified within theConrail facility, other potential sources outside the facility may have

3-5

been and/or may be contributing to the groundvater contamination in thestudy area. These sources include:

o The Martin Drum site, located immediately north of theConrail facility (downgradient of the Conrail facility).Drum removal was undertaken at the Martin Drum site (seeSection 2.4). The exact nature of operations at the MartinDrum site is not known. Leakage and spills would bepossible primary release mechanisms for contaminants inthis area. Infiltration/percolation, storm water runoff,and volatile emission would be possible secondary releasemechanisms for contaminants in this suspected source area.

o Other light industries located immediately north of theConrail facility (downgradient of the Conrail facility).The nature of operational and waste disposal activities atthese industries is not well known. Leakage and spillswould be possible primary release mechanisms for contami-nants in this area. Infiltration/percolation, storm waterrunoff, and volatile emission would be possible secondaryrelease mechanisms for contaminants in this suspectedsource area.

o Other industries located south of the Conrail facility(upgradient of the Conrail facility). The nature ofoperational and vaste disposal activities at theseindustries is not known. Therefore, at this time,speculation on the possible release mechanisms is notpossible.

Although volatile emission and storm water runoff are among thepossible release mechanisms in the study area, infiltration/percolationassociated with groundwater contamination is the major release mechanismfor contaminants in the study area. This subject will be furtherdiscussed in Section 3.2.2.

3-6

3.2.2 Migration Pathways and Media AffectedThe third component of the conceptual site model concerns the

migration pathways. This component is the link between the sources andthe fourth component of the conceptual site model, the media affected(see Figure 3-1).

Migration pathways in the study area include groundwater in theshallow aquifer, groundwater in the deep aquifer, wind, and surfacewater. The media affected include groundwater, subsurface soil, air,and surface water (St. Joseph River and Baugo Bay).

Surface water in the Crawford Ditch and in the waste stabilizationponds will be investigated in the RI/FS by sediment sampling/analysis ateach location. The surface water in the St. Joseph River and Baugo Baywill not be investigated during the initial phase of the RI/FS. How-ever, the surface water in the St. Joseph River and Baugo Bay will beinvestigated in the subsequent phase(s) RI/FS. Similarly, the airmedium will not be investigated in the initial phase of the RI/FS.However, this medium will be investigated in the subsequent phase(s)RI/FS to ensure compliance with ARARs.

The subsurface soil medium in the study area may be contaminateddue to direct contact with the sources and the soil-groundwater sorptioncharacteristic. Other than soil sampling and associated chemicalanalysis to identify source areas, and to establish subsurface soilbackground data, the subsurface soil medium will not be investigateddirectly by means of soil sampling. However, this medium will beinvestigated indirectly through groundwater investigation in the studyarea.

Groundwater in the shallow aquifer is the migration pathway forcontaminants emanating from the possible sources within the Conrailfacility and from other possible contributing sources outside thefacility in the study area. Groundwater in the deep aquifer is themigration pathway for contaminants emanating from possible sourcessituated on the eastern portion of the Conrail facility. In the easternportion of the Conrail facility, the silt and clay confining layer doesnot exist (see Figure 2-3); as a result, the contaminants in the shallowzone have an unobstructed path to migrate to the deep zone. Groundwaterin the deep aquifer is also the migration pathway for other sources

3-7

upgradient of the Conrail facility, if these sources exist, thatpossibly are contributing to the groundwater contamination in the studyarea.

Groundvater contamination is the focus of the initial phase of theRI/FS. Groundwater is the sole source of water for many residents inthe study area. Available data indicate that groundwater in the studyarea is contaminated with TCE and CC1, at levels above the 10-day HealthAdvisory Level.

3.2.3 Receptors and Exposure RoutesThe fifth component of the conceptual site model is the receptors

and exposure routes for the various contaminated media. This componentidentifies public exposures and potential health risks which may beattributable to the release of contaminants from the suspected sourceareas via the release mechanisms and pathways presented in theconceptual site model.

Figure 3-1 presents the initial evaluation of receptors andexposure routes. Ingestion and dermal contact are the high probabilityexposure routes for the area residents.

3.2.4 Data NeedsA subsurface soil sampling/chemical analysis program needs to be

conducted to identify and quantify the possible contamination sourceareas within the Conrail facility and, if needed, outside the Conrailfacility. Because of the large areal extent of the suspected sources, ascreening technique needs to be utilized to identify hot spots. Forthis investigation, the screening technique will be a soil gas survey; tobe conducted in all of the suspected source areas within the Conrailfacility, if possible. In addition, the Martin Drum site and the lightindustrial areas north of the Conrail facility will be screened usingthe soil gas survey to determine whether these areas are contributing tothe contamination in the study area. Soil sampling will be performed inthe suspected source areas within the Conrail facility and at the MartinDrum site at locations determined based on the results of the soil gassurvey.

3-8

No contamination source south (upgradient) of the Conrail facilityhas been identified. Therefore, no soil sampling for source identifica-tion will be conducted south of the Conrail facility during the initialphase of the RI/FS. However, the existence of upgradient source(s) willbe evaluated by installing shallow and deep monitoring wells immediatelysouth of the Conrail facility.

Based on the available background data, E & E believes that, at thepresent time, secondary sources (contaminated soil [see Figure 3-1] inthe vadose zone) constitute the contamination sources at the Conrailfacility. Therefore, soil samples for chemical analysis will becollected from unsaturated soil. Infiltration/percolation is theprimary release mechanism and causes the contaminants sorped to the soilparticles in the unsaturated zone to desorp and enter the groundwater inthe shallow aquifer. The contaminants then migrate off-site via ground-water toward the St. Joseph River or Baugo Bay.

The initial evaluation of the groundwater contaminant migrationpathway in the study area is based on the hydrogeological data presentedin the 1981 USGS hydrologic evaluation covering the study area (seeSection 2.5.2). Based on this data, two distinct aquifers (shallow anddeep) exist in most part of the study area. The shallow aquifer extendsto approximately 40 to 60 feet below grade, and is separated from thedeep aquifer by a 16 to 20-foot thick silty clay aquitard. The deepaquifer extends to bedrock, which is 200 to 250 feet below the surfaceat the study area. The silty clay aquitard does not exist beneath theeasternmost quarter of the Conrail facility; at this location, oneaquifer exists, which extends from the groundwater table to the bedrock.

The hydrogeology presented above may be a simplistic representationof the hydrogeology of the study area. Both shallow and deep aquifersmay be interbedded with discontinuous low-permeability layers of siltand clay, and the aquitard may be interbedded with discontinuous layersof high-permeability sand and gravel. Under these conditions, deter-mination of the groundwater contaminant migration pathway would be verycomplex. A more accurate knowledge of the subsurface stratigraphy isrequired to make a realistic determination of the groundwater contami-nant migration pathway, and to evaluate hydraulic interconnectivity

3-9

between the shallow and deep aquifers. Deep soil borings need to beperformed to determine subsurface stratigraphy in the study area.

The contamination plumes defined by EPA/TAT are based on analysisof groundwater samples collected from residential wells in the studyarea. The construction details of these residential veils (e.g., screenintervals) are not known; therefore, the vertical zone of the ground-water contamination is not known. Shallow monitoring wells need to beinstalled to monitor the groundwater hydrology and determine contamina-tion conditions in the shallow aquifer. The screen intervals should beselected based on the subsurface stratigraphy; it nay be necessary tomonitor more than one zone in the shallow aquifer. Deep monitoringwells need to be installed to monitor the groundwater hydrology anddetermine contamination conditions in the deep aquifer. Depending onthe subsurface stratigraphy, it may be necessary to monitor more thanone zone in the deep aquifer. A sufficient number of monitoring wellsneed to be installed; groundwater samples from these wells need to beanalyzed to define the contamination plume associated with each contami-nation source.

After the extent and characteristics of the contamination plumes inthe study area are determined, the population affected and nature ofimpact need to be identified to conduct a risk assessment.

3.3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

For each hazardous waste site governed by the ComprehensiveEmergency Response, Compensation, and Liability Act (CERCLA) and theSuperfund Amendments and Reauthorization Act (SARA), Congress has

; directed U.S. EPA to consider the degree of public health or environ-mental protection afforded by each remedial alternative considered.

Section 121(d) of SARA requires that remedial actions meet legallyapplicable or relevant and appropriate requirements (ARARs) of otherenvironmental laws. These laws may include: the Resource Conservationand Recovery Act (RCRA), the Clean Water Act (CVA), the Clean Air Act(CAA), the Toxic Substances Control Act (TSCA), the Safe Drinking WaterAct (SDUA), among other laws, and any state law which has stricterrequirements than the corresponding federal law.

3-10

ARARs may be classified into the following requirement categories:

o Ambient or chemical-specific requirements are usuallyhealth- or risk-based numerical values or methodologieswhich, when applied to site-specific conditions, result inthe establishment of numerical values. These valuesestablish the acceptable amount or concentration of achemical that may be found in, or discharged to, theambient environment.

o Performance, design, or other action-specific requirementsare usually technology- or activity-based requirements orlimitations on actions taken with respect to hazardouswastes.

o Location-specific requirements are restrictions placed onthe concentration of hazardous substances or the conduct ofactivities solely because they occur in special locations.

ARARs preliminarily identified for the Conrail/County Road 1project have been characterized as "applicable" or "relevant andappropriate." Additionally, certain material is classified as "To BeConsidered."

Applicable requirements are those cleanup standards and other sub-stantive environmental protection requirements promulgated under federalor state lav that specifically address a hazardous substance, remedialaction, or other circumstance at the study area and all of the condi-tions of the standard or requirement have been met by the conditions atthe study area.

Relevant and appropriate requirements are those cleanup standardsand other substantive environmental protection requirements promulgatedunder federal or state law that, while not "legally applicable" to ahazardous substance, remedial action, or other circumstance at the studyarea, address problems or situations sufficiently similar to those

3-11

encountered at the study area that their use is veil suited to theparticular site.

To-Be-Considered Material (TBCs) are non-promulgated advisories orguidance issued by federal or state government that are not legallybinding and do not have the status of potential ARARs. However, in manycircumstances TBCs will be considered along with ARARs as part of thesite risk assessment and may be used in determining the necessary levelof cleanup for protection of health or the environment.

Based upon the current understanding of the study area conditionsand potential remedial action alternatives, a preliminary list of ARARsand TBCs for the Conrail/County Road 1 project has been identified andis presented in Tables 3-1 and 3-2, respectively. In conjunction withthe federal ARARs and TBCs listed in Tables 3-1 and 3-2, contact wasinitiated with IDEM and the Indiana Department of Natural Resources(IDNR) to identify state and local ARARs and TBCs. Because the RI, FS,and ARARs are interactive processes, during the Phase 1 and subsequentphase(s) of the RI/FS, identification of project-specific federal andstate ARARs and TBCs will continue as a better understanding of thestudy area contamination conditions and potential remedial alternativesis gained.

3-12

TABLE 3-1

PRELIMINARY LIST OF "APPLICABLE" AND "RELEVANT AND APPROPRIATE"REQUIREMENTS FOR CONRAIL/COUNTY ROAD 1 PROJECT »/

1. Office of Solid Wasteo Resource Conservation and Recovery Act of 1976 (42 U.S.C. 6901) b/

a. 40 CPR Pert 264, applicable for permitted facilities c/, and 40 CFR Part 265, for interim status facilities.

- Ground-water Protection (40 CFR 264.90-264.101)- Ground-water Monitoring, Subpart F (40 CFR 264.98-264.100) d/- Closure and Post-€losure (40 CFR 264.110-264.120, 265.110-265.120)- Containers (40 CFR 264.170-264.178, 265.190-265.177)- Tanks (40 CFR 264.190-264.200, 265.190-265.199)- Surface Impoundments (40 CFR 264.220-264.249, 265.220-265.230)- Waste Piles (40 CFR 264.250-264.269, 265.250-265.258)- Land Treatment (40 CFR 264.270-264.299, 265.270-265.282)- Incinerators (40 CFR 264.340-264.999, 265.340-265.369)- Land Disposal Restrictions (40 CFR 268.1-268.50)

U>t_> b. Statutory requirements, including:OJ

- Liquids in Landfills (RCRA $3004(c))- Minimum Technology Requirements (RCRA $3004(o), 30051]))- Dust Suppression (RCRA $3004(e))- Hazardous Haste Used as Fuel (RCRA $3004(q))

c. Open Dump Criteria - pursuant to RCRA Subtitle D: criteria for classification of solid waste disposal facilities(40 CFR Part 257). Mote: For nonhacardous wastes.

2. Office of Watero The Safe Drinking Water Act (42 U.S.C. 300(f))

a. Maximum Contaminant Levels (chemicals, turbidity, and microbiological contamination) (for drinking water or humanconsumption) (40 CFR 141.11-141.16).

b. Maximum Contaminant Level Goals (40 CFR 141.50-141.51, 50 FR 46936).

c. Underground Injection Control Regulations (40 CFR Parts 144, 145, 146, 147).

Table 3-1 (Continued)

o Clean Water Act (33 U.S.C. 1251)

Requirements established pursuant to sections 301 (effluent limitations), 302 (effluent limitations), 303 (water qualitystandards, including State water quality standards), 304 (Federal water quality criteria), 306 (national performancestandards), 307 (toxic and pretreataent standards, including Federal pretreataent standards for discharge into publicly ownedtreataent works, and nuaeric standards for toxics), 402 (national pollutant discharge eliaination systea), 403 (oceandischarge criteria), and 404 (dredged or fill aaterial) of the Clean Water Act (33 CFR Parts 320-330, 40 CFR Parts 122, 123,125, 131, 230, 231, 233, 400-469). Available aabient Water Quality Criteria Docuaents are listed at 45 FR 79318,Hoveaber 28, 19SO; 49 FR SS31, February 15, 1984; SO FR 30784, July 29, 1985; 51 FR 22978, June 28. 1986; 51 FR 43665,Deceaber 3, 1986; 51 FR 8012, March 7, 1986; 52 FR 6213, March 2, 1987.

o Section 10 of the. Rivers and Harbors Act prohibits unauthorised obstruction or alteration of navigable waters(33 CFR Parts 320-329, 40 CPR Parts 122, 123, 125, 131, 230, 231, 233, 400-469).

3. Office of Air and Radiationo Clean Air Act (42 U.S.C. 7401)

a. National Aabient Air Quality Standards (40 CFR Part 50)

b. National Eaissions Standards for Haiardous Air Pollutants for Asbestos and Wet Dust particulates (40 CFR 61.140-61.156),for Berylliua (40 CPR 61.30-61.34), for Vinyl Chloride (40 CFR 61.60-61.71), for Bensene (40 CFR 61.110-61.112), and forother hazardous substances (40 CFR Part 61 generally). See also effluent liaitations and pretreataent standards for WetDust Collection (40 CFR 427.110-427.116) and 40 CFR Part 763.

c. State iapleaentation plans for national priaary and secondary aabient air quality control standards (42 U.S.C. 7410)

4. Other Federal Requireaentso OSHA requireaents for workers engaged in response or other hazardous waste operations (29 CFR 1910.120).o occupational Safety and Health Act of 1970 (29 U.S.C. 651).

a. Occupational Safety and Health Standards (General Industry Standards) (29 CFR Part 1910).b. The Safety and Health Standards for Federal Service Contracts (29 CFR Part 1926).c. The Health and Safety Standards for Eaployees engaged in Hazardous Waste Operations (SO FR 45654).

o Federal Land Policy and Management Act, 13 U.S.C. 1700 (establishes requireaents concerning utilization of public lands,particularly rights of way regulation (13 U.S.C. 1761), land use planning and land acquisition and disposition (13 U.S.C.1711), and appropriation of waters on public lands).

o Department of Transportation Rules for the Transportation of Hazardous Materials, 49 CFR Parts 107, 171.1-172.558.o Fish and Wildlife Conservation Act of 1980, 16 U.S.C. 2901. (Generally, 50 CFR Part 83.) •/o Farmland Protection Policy Act, 7 U.S.C. 4201. (Generally, 7 CFR Part 658.) •/o Rivers and Harbors Act (33 U.S.C. 403).


*/ This is the list of potentially applicable oc relevant and appropriate requirements found in the October 2, 1985, CompliancePolicy with additions. As additional requirements are promulgated, they must also considered potentially applicable orrelevant and appropriate and added to this list.

b/ In authorised States, Federal regulations promulgated under RCRA are not applicable as a State requirement until the Stateadopts those regulations through its own legislative process, but probably would be relevant and appropriate as a federalrequirement. Federal regulations promulgated pursuant to the Hacardous and Solid Waste Amendments of 1914, however, areeffective immediately in all 50 states, and are potentially applicable as Federal requirements.

c/ 40 CFR Part 264 regulations apply to permitted facilities and may be relevant and appropriate to other facilities.

d/ Only the Subpart F ground-water monitoring requirements under 40 CFR264 are ARAR. The Subpart F ground-water monitoringrequirements under 40 CFR 265 are not ARAR.

e/ Hay not be applicable or relevant for many sites.

Mote: This list was compiled from a Draft CEBCLA Compliance with Other Laws Manual, Hay 6, 19»B, which is subjectto change or withdrawal.

2326:7

U»I

TABLE 3-2

PRELIMINARY LIST OF "TO BE CONSIDERED* MATERIALSFOR CONRAI L/COUNTY ROAD 1 PROJECT •/

1. Federal Criteria, Advisories, and Procedureso Health Effect! Assessments (HEAs) and Proposed HEAs ("Health Effects Assessment for (Specific Chemicals), "ECAO,

USEPA, 1985).

o Reference* Doses (RFDs) ("Verified Reference Doses of USEPA,* ECAO-CIH 475, January 1986). See also Drinking WaterEquivalent Levels (OWELs), a set of medium-specific drinking water levels derived from RFDs. (See USEPA Health Advisories,Office of Drinking Water, March 31, 1987).

o Carcinogen Potency Factors (CPFs) (e.g., Ql Stars, Carcinogen Assessment Group ICAO) Values), (Table 11, "Health AssessmentDocument for Tetrachloroethylene (Perchloroethylene),• USCPA, OHEA/6008 82/005F, July 198S).

o Federal Sole Source Aquifer requirements (See 52 FR 6673, March 5, 1987).

o Public health criteria on which the decision to list pollutants as hasardous under Section 112 of the Clean Air Act wasbased.

o Guidelines for Ground-Water Classification under the EPA Ground-Water Protection Strategy,o OSHA health and safety standards that may be used to protect public health (non-workplace),o Health Advisories, EPA Office of Water.o EPA Water Quality Advisories, EPA Office of Water, Criteria and Standards Division.

2. USEPA RCRA Guidance Documentso Interim Final Alternate Concentration Limit Guidance Part 1: ACL Policy and Information Requirements (July 1987)

a. EPA's RCRA Design Guidelinesb. Permitting Guidance Manualsc. Technical Resource Documents (TRDs)

(1) Evaluating Cover Systems for Solid and Hasardous Waste. (September 1982) EPA OSW-00-00-B67(2) Hydrologic Simulation of Solid Waste Disposal Sites. (November 1982) EPA OSW-00-00-868(3) Landfill and Surface Impoundment Performance Evaluation. (April 1983) EPA OSW-00-00-869(4) Management of Hasardous Waste Leachate. (September 1982) OSW-00-00-871(5) Guide to the Disposal of Chemically Stabilised and Solidified Waste. (1982) EPA/530-SW-872(6) Closure of Hasardous Waste Surface Impoundments. (September 1982) OSW-00-00-873(7) Hazardous Waste Land Treatment. (April 1983) OSW-00-00-874(8) Soil Properties, Classification, and Hydraulic Conductivity Testing. (March 1984) OSW-00-00-925, OSWER directive

9480.00-7D


d. Test Methods for Evaluating Solid Waste

(1) Solid Waste Leaching Procedure Manual. (1984) OSW-00-00-924(2) Methods for the Prediction of Leachate Plume Migration and Mixing

(3) Hydrologic Evaluation of Landfill Performance (HELP) Mode, Volumes I and II (1984), EPA/S30 SW-84-0094 EPA/S30-SW-84-010

(4) Hydrologic Simulation on Solid Waste Disposal Sites. (November 1982) EPA OSW-00-00-868(5) Test Methods for Evaluating Solid Wastes, third edition. (November 1986) SW-846

3. USEPA Office of Water Guidance Documentsa. Pcetceatment Guidance Documents

(1) 304(g) Guidance Document Revised Pretreatment Guidelines (3 Volumes)(2) Guidance for POTW Pretreatment Program Manual (October 1983)(3) Developing Requirement* for Direct and Indirect Discharges of CERCLA Wastewater, Draft. (1987)(4) Domestic Sewage Exemption Study(5) Guidance for Implementing RCRA Permit by Rule Requirements at POTWs(6) Application of Correction Action Requirements at Publicly Owned Treatment Works(7) Draft Guidance Manual on the Development and Implementation of Local Discharge Limitations under the Pretreatment

Program (1987)

b. Water Quality Guidance Documents

(1) Water-Related Environmental rate of 129 Priority Pollutants (1979)(2) Water Quality Standards Handbook (December 1983)(3) Technical Support Document for Water Quality-Based Toxics Control (1983)

c. NPDES Guidance Documents

(1) NPDES Best Management Practices Guidances Manual (June 1981)(2) Case studies on toxicity reduction evaluation (May 1983)

d. Ground-Water/UIC Guidance Documents

(1) Designation of a USOW (Ho. 7.1, October 1979)(2) Elements of aquifer identification (Ho. 7.2, October 1979)(3) Interim Guidance Concerning Corrective Action for Primary and Continuous Release of Class I and IV

Hazardous Waste wells (Ho. 45, April 1986) requirements


(4) Requirements applicable to wells injected into, through, or above an aquifer that has been exemptedpursuant to Section 146.104(b)(4). (No. 27, July 1981)

(5) Guidance for UIC implementation on Indian lands. (No. 33, October 19S3)

». Ground-Hater Protection Strategy (August 1984).(. Clean Hater Act Guidance Documents (see Exhibit 3-1).

4. USEPA Manuals from the Office of Research and Developmento SW 146 Methods - laboratory analytic methods (November 19»6)o Lab protocols developed pursuant to Clean Water Act Section 304(h).

5. Nonprosmlgated State Advisorieso State approval of water supply system additions or developments.o State groundwater withdrawal approvals.

•/ This list update* the list of other federal criteria, advisories, and guidance to be considered in the October 5, 1945,Compliance Policy. As additional or revised criteria, advisories, or guidance are issued, they should be added to this listand also considered.

Note: This list was compiled from a Draft CERCLA Compliance with Other Laws Manual, Hay 6, 1968, which issubject to change or withdrawal.

I•-• 2326:700

4. WORK PLAN RATIONALE

4.1 OVERVIEW OF WORK PLAN RATIONALE

This section states the rationale behind the proposed scope of workfor the Conrail/County Road 1 project. The overall rationale of theWork Plan is to collect the necessary data to conduct a risk assessmentand feasibility study.

The Work Plan employs a phased approach to the RI/FS: Phase 1 ofthe RI/FS will primarily address data needed to identify the sourceswithin the Conrail facility; explore study area hydrogeologicalconditions; delineate contamination plumes in the County Road 1, LaRueStreet, and Charles Avenue areas; evaluate whether interim remedialactions are necessary; and evaluate a range of feasible remedialalternatives. Data gaps will be identified and the scope of thesubsequent phases(s) RI/FS will be determined. The sources will beidentified through a combination of unbiased and biased soil gas surveysof the suspected areas, subsurface soil sampling, sediment sampling, andgroundvater sampling. The contamination plumes will be delineated by;installing shallow and deep boring/monitoring wells and conductinghydrogeological and groundwater contamination investigations at thestudy area. The detailed objectives of the Phase 1 RI/FS are presentedin Section 4.2.

Based on the data collected in the Phase 1 RI/FS, the scope ofadditional activities for subsequent phase(s) of the RI/FS will bedefined. These activities may include performing soil borings,installing monitoring wells, and soil and groundwater sampling.

4-1

Subsequent phase(s) of investigation will address data needed tofurther identify sources, quantify the sources, further delineate thegroundwater contamination plumes within the study area, and evaluate thepossible impact to surface water. This information will then be appliedto analyze remedial alternatives for the feasibility study and toconduct a risk assessment. The sources will be quantified throughsystematic three-dimensional soil sampling (using a grid system) of theidentified source areas. Further hydrogeological information andgroundwater quality data will be gathered by installing additionalshallow and deep borings and monitoring wells and collecting soil andgroundwater samples. The detailed objectives of the subsequent phase(s)RI/FS are presented in Section 4.3.

4.2 PHASE 1 RI/FS OBJECTIVESBased on E & E's initial evaluation (Section 3) and the technical

directions provided by EPA at RI/FS meetings, the objectives of thePhase 1 RI/FS will be to:

o Identify the contamination sources within the Conrailfacility.

o Preliminarily identify the other possible contaminationsources off-site/ downgradient of the Conrail facilitywhich contribute to the EPA/TAT-designated County Road 1and LaRue Street TCE/CC1, contamination plumes.

o Delineate the contamination plumes Vithin the County RoadI, LaRue Street, and Charles Avenue areas; and, in particu-lar, delineate the TCE/CCl, contamination plumes associatedwith the contamination sources within the Conrail facility.

o Identify the impacted areas and the population within theseareas which uses groundwater as its sole drinking watersource.

o Identify preliminary project-specific ARARs and TBCs.

4-2

o Evaluate whether interim remedial actions may be necessaryand if so, establish whether the contamination plumes orsources may best be remedied as separate operable units.If interim remedial actions become necessary, a range offeasible interim remedial alternatives will be evaluated.

o Evaluate a range of feasible remedial alternatives andidentify data needs to develop the scope of work for thesubsequent RI/FS phase(s).

A.3 SUBSEQUENT PHASE(S) RI/FS OBJECTIVESThe objectives of the subsequent phase(s) RI/FS will be to:

o Evaluate feasible remedial alternatives, and designremedial actions if interim remedial actions becomenecessary.

o Further identify and quantify the contamination sources inthe study area.

o Delineate the lateral and vertical extent of the ground-water contamination plumes within the study area.

o Assess the potential impact of the contaminants on humanhealth, evaluate the possible impacts to surface water andaquatic biota, evaluate other possible impact on the/environment, and conduct a risk assessment.

o Identify project-specific ARARs and TBCs.

o Evaluate a range of feasible remedial alternatives andidentify the preferred remedial alternative.

4.4 DATA QUALITY OBJECTIVES

Data Quality Objectives (DQOs) are based on the concept thatdifferent data uses may require different levels of data quality. Data

4-3

quality is defined as the degree of certainty of a data set with respectto precision, accuracy, reproducibility, comparability, and complete-ness. DQOs are qualitative and quantitative statements specifying thequality of data required to support RI/FS activities.

Generally, in the Conrail/County Road 1 project, data used for thepurpose of risk assessment, engineering design, and cost analyses willhave the highest level of quality. Data used for screening techniquesor used as supportive data (e.g., field gas chromatograph (GC), pH,conductivity) in defining the source areas or contamination plumes willhave a lower level of quality than the preceding data. Water tabledata, which are simple measurements, will have the lowest data quality.Further description of the DQOs is presented in Section 2.6 of theQuality Assurance Project Plan (QAPP); Table 2-1 of the QAPP presentsthe intended data usage and level of data quality for each datacategory.

4-4

5. REMEDIAL INVESTIGATION

Tasks to complete the RI portion of the project are presented inthis section. Tasks 1 and 2 involve project planning and CommunityRelations Support activities. Tasks 3 through 7 involve the implemen-tation of the field investigations, analysis of samples, validation ofdata, identification of potential environmental risks, and preparationof the RI report. The scope of work for each of these tasks isdescribed below.

5.1 TASK 1: PROJECT PLANNINGThis task includes efforts to initiate the project once the work

assignment is issued. A kickoff meeting, held on December 1, 1988, atthe Conrail facility, was attended by the EPA Regional Project Manager(RPM), an IDEM representative, and E & E staff assigned to theConrail/County Road 1 project. The meeting also provided the oppor-tunity to conduct an initial site visit and discuss the facilityoperations with the attending Conrail representative. ;

A Work Plan Memorandum was submitted on December 7, 1988, outliningthe scope of work to be conducted prior to initiation of the siteinvestigation. The information is presented again here in summary.

Tasks outlined in the Work Plan Memorandum included preparation ofall project planning documents, plus the tasks necessary to support thedevelopment of the documents. Planning documents include the Work Plan,the Sampling and Analysis Plan, and the Health and Safety Plan. TheWork Plan presents the overall scoping of the entire RI/FS. Included in

5-1

this plan is a description of RI/FS tasks, the proposed investigationplan, the project schedule, and cost estimates.

The Sampling and Analysis Plan (SAP) will contain two distinctplans: the Quality Assurance Project Plan (QAPP) and the Field SamplingPlan (FSP). The QAPP will be designed to insure that the data qualityobjectives for the project are met. Project procedures detailed in theQAPP will include sample handling and custody, instrument calibrationand analytical procedures, measurement of data quality, data reduction,and internal QC checks.

The FSP will be prepared as the Work Plan is being prepared. TheFSP will detail the methods and procedures to be utilized to investigateand sample soil gas, subsurface soil, groundwater, and sediment, and forsoil physical characteristics.

The Health and Safety Plan vill be developed concurrently with theSAP, and will contain a description of site entry and monitoring re-quirements, personnel assignments, physical and chemical risks, andpersonal protective equipment to be used.

5.2 TASK 2: COMMUNITY RELATIONS SUPPORTE & E will assist EPA in implementing the community relations

program during the RI/FS of the Conrail/County Road 1 project. Thescope of work for community relations support is broken down into thesubtasks described below. The EPA may modify this scope of work if itis later determined that additional community relations activities arerequired to meet the community's needs for information about the studyarea.

]5.2.1 Subtask 2.1; Community Relations Plan

E & E vill develop a community relations plan (CRP) prior toinitiation of RI/FS field work. The CRP will detail the communityrelations program to be implemented by EPA and will include thefollowing: background information about the study area; communityprofile and key community concerns; highlights of the communityrelations program; community relations activities; a list of contactsand interested parties; and locations of the information repositoriesand for the RI/FS kickoff public meeting.

5-2

Development of the CRP will require one E & E visit to the Elkhartarea with the EPA Community Relations Coordinator (CRC) to conductinterviews with local officials and interested parties and determinelocations for the information repositories and public meeting. A draftCRP will be submitted to EPA within three weeks of the visit to Elkhart,and a final CRP will be submitted to EPA within 30 days of receipt ofEPA comments.

5.2.2 Subtask 2.2: Fact SheetsE & E will write, design, and produce at least three fact sheets

(each approximately eight pages in length) at the following RI/FSmilestones: Phase 1 RI/FS kickoff; completion of Phase 1 RI/FS; andcompletion of the RI/FS. The first fact sheet will contain historicalinformation about the study area, general information about theSuperfund process and pathways of contamination, and a summary of thework to be performed during the RI/FS. This RI/FS kickoff fact sheetwill be produced upon approval of the draft by EPA and will bedistributed by E & E approximately three days prior to the date of theRI/FS kickoff public meeting.

The second fact sheet will contain a summary of the results of thePhase 1 RI/FS and will be distributed approximately three days prior tothe date of the public meeting. The third fact sheet will containinformation about the final results of the RI, the remedial alternativesfor the site, and EPA's preferred alternative. This final RI/FS factsheet will be produced and distributed in conjunction with the openingof the public comment period.

Key assumptions made in developing the cost estimate for thissubtask include the following:

o Three fact sheets, each eight pages in length, will bedeveloped;

o Five hundred copies of each fact sheet will be printed; and

o Approximately 250 copies of each fact sheet will be mailedby E & E to those on the study area mailing list.

5-3

5.2.3 Subtask 2.3; Public Comment Period ActivitiesE & E will assist EPA with community relations activities,

including a public hearing, conducted in conjunction with the 30-daypublic comment period at the completion of the RI/FS. Also, included inthis subtask are activities that must be conducted in relation to publicmeetings that will be held at the start-up and at completion of thePhase 1 RI/FS. E & E vill be responsible for the following activities:

o Preparing and placing a newspaper advertisement in localnewspapers at the completion of the RI/FS. The advertise-ment will describe the document(s) available for publiccomment, summarize the remedial alternatives and EPA'spreferred alternative, announce the public meeting date andlocation, state the dates of the comment period, and listthe EPA contact who will receive written comments. Inaddition to preparing the comment period announcement,E & E will prepare and place newspaper advertisements toannounce the start-up of the RI/FS and completion of thePhase 1 RI/FS. These two advertisements will also describeavailable documents and provide public meeting dates andlocations.

o Ensuring that copies of the appropriate site document(s)are placed in the information repositories prior to theopening of the comment period that follows completion ofthe RI/FS.

o Reserving public hearing and meeting locations at localfacilities and preparing any visual aids requested by EPAfor use at the hearing/meetings.

o Arranging for a court reporter/stenographer to attend thepublic hearing to provide a verbatim transcript of thehearing. E & E will also ensure that a copy of thetranscript is placed in the information repositories.

5-4

o Preparing a Responsiveness Summary after the close of thepublic comment period. The Responsiveness Summary willsummarize written and oral comments made by the publicduring the comment period and EPA's response to thecomments. E & E will provide a draft of this report to EPAand incorporate EPA comments on this draft into a finalreport. E & E will also insure that a copy of theResponsiveness Summary is placed in the informationrepositories.

In developing the cost estimate for this subtask, the followingassumptions were made:

o E & E's project manager or E & E's community relationsproject manager will attend two of the public meetings tobe held in Elkhart; and

o Newspaper advertisements will be placed in three localnewspapers.

5.2.4 Subtask 2.4; Additional Community Relations ImplementationThis subtask provides for additional community relations activities

that will be conducted in conjunction with the above-mentioned subtasks.The scope of work for this subtask may be modified by EPA if the com-munity relations program is expanded to include activities, such asavailability sessions, which are not currently anticipated by EPA. Atpresent, however, the following activities are included in this subtask:

o Updating the information repositories to insure that copiesof relevant RI/FS documents are available to the public.

o Establishing (through the initial visit to the Elkhartarea) and maintaining a mailing list to include all membersof the community who are to receive copies of fact sheetsand project update reports.

5-5

o Assisting EPA in developing and distributing evaluationsthat will assess the effectiveness of the communityrelations activities.

5.3 TASK 3: SITE INVESTIGATIONSField activities will be performed to meet the Phase 1 RI/FS

objectives as presented in Section 4.2 and the subsequent phase(s) RI/FSobjectives as presented in Section 4.3.

The field activities for the Phase 1 investigation at theConrail/County Road 1 project will include the following (see Table5-1):

o Mobilization,o Site Surveying,o Soil Gas Survey,o Subsurface Soil Sampling,o Sediment Sampling,o Groundvater Monitoring and Sampling, ando Aquifer Characteristic Tests.

The number of samples and sampling locations are presented in thissection. The sampling locations have been selected based on the dataconcerning the site hydrogeological and contamination conditionspresently available to E & E. Data from the investigation currentlybeing conducted in the Conrail facility (during the site visit on March28, 1989 attended by EPA, MDNR, and E & E personnel, were notified thatConrail is performing soil-'borings and installing monitoring veils) isnot available to E & E at this time. The sampling locations may berefined after consultation with EPA as additional data become available.The sampling locations vill be refined in order not to duplicateexisting data and to conduct an efficient sampling program. However,the number of samples vill not change and vill be as presented in thevork plan.

5-6

Table 5-1

SUMMARY OF PHASE 1 FIELD INVESTIGATION ACTIVITIES

Activity Quantity Comments

Soil Gas Survey 100-150

Headspace Method 72-144

Soil Boring 19-32

Grain Size Distribution 6

Vertical Permeability 3

TCE and CC14 Analyses

TCE and CC14 Analyses (1)

Approximate Depth of 20 feet

To be collected from aquifersand tested by drilling sub-contractor

On She1by tube samples fromsilty-clay layer to be testedby drilling subcontractor

Atterberg Limits

Subsurface Soil Sampling

Subsurface Soil Sampling

Sediment Sampling

Shallow Monitoring VeilInstallation

Deep Monitoring VeilInstallation

Groundvater Sampling

Groundvater Sampling

Slug Test

3

9

33

5

21

11

6

26

25

On samples collected forvertical permeability tests

TCL/TAL Analyses (2)

VOC Analyses (3)

TCL/TAL Analyses (2)

Approximate depth of 35 feet

Depth ranging from 80 feet to130 feet per veil

TCL/TAL Analyses <2)

VOC Analyses ' '

Rising Head

(1) Trichloroethylene and carbon tetrachloride analysis to be performedin an on-site laboratory.

(2) Target Compound List/Target Analyte List analysis to be performedat Contract Laboratory Program (CLP) laboratory. Oil and greaseanalysis on groundvater, soil, and sediment samples to be performedat E & E ASC.

(3) Volatile Organic Compounds Analysis to be performed at CLPlaboratory.

5-7

5.3.1 Subtask 3.1; Bid Specification Activities and SubcontractorProcurement

Bid solicitation will be conducted during the initial activitiesperiod. Following EPA approval of the Vork Plan, a bid specificationwill be prepared for drilling of soil borings and installation/develop-ment of the monitoring wells. The bid specification along with otherpertinent documents will be sent to the interested bidders for subcon-tractor procurement. Subcontractor procurement is a program managementactivity under the ARCS contract, and is not budgeted under thisproject.

5.3.2 Subtask 3.2; Literature SearchA literature search will be conducted to collect available study

area background information. The search will focus on obtaining datathat are needed to conduct RI/FS and risk assessment activities.General and site-specific data collection may include:

o Additional data describing site and regional hydrogeology;

o Locations of existing monitoring wells and soil borings inthe study area;

o Information regarding existing residential wells within thestudy area and construction details of these wells; and

o Historical aerial photographs of the study area.

Sources of information that will be reviewed include: federal andstate geological survey reports, EPA files, and IDEM files.

5.3.3 Subtask 3.3; Field Investigation5.3.3.1 Mobilization/Investigation Support

Mobilization includes preparations for all field investigationtasks, including obtaining utility clearances, setting up field offices,preparing the field laboratory for GC analysis, maintaining field

5-8

equipment, and making arrangements for sample collection and shipment.Also included in this task are demobilization and cleanup activities.

The cost element for this task is based on the assumption thatLevel D protection will be sufficient for most field activities, andthat decontamination requirements will be minimal.

5.3.3.2 Site Surveying and MappingA base map of the study area has been prepared using a United

States Geological Survey (USGS) topographic map and plat map of thestudy area (see Figure 5-1). This base map illustrates the major sitefeatures including the diesel shop, the west tower, and the north andsouth towers. For horizontal control of data points, a base lineoriented in a northwest direction will be established throughout thestudy area and flagged every 250 feet. Transverse lines will beestablished at intervals of 500 feet, and will be flagged every 250feet. These flags will be maintained and, if necessary, replaced,throughout the investigation period. These lines will be utilized todevelop coordinate systems to determine the boring/monitoring welllocations. For horizontal control, existing permanent site features mayalso be used, and boring/monitoring well locations may be tied to thesefeatures.

For vertical control, existing USGS benchmarks will be identifiedand two additional benchmarks will be established in the study area.Using these benchmarks, boring/monitoring well elevations will besurveyed. A final base map will be prepared showing all boring/moni-toring well and sampling locations.

Cost estimates for this subtask are based on the followingassumptions:

o All activities will be conducted in Level D protection; ando A two-man crew will be employed for a total of ten days for

surveying activities.

5.3.3.3 Soil Gas SurveyA soil gas survey will be conducted in the suspected source

areas, and areas downgradient of these sources. This task will be

5-9

SOURCE: Ecology «nd Environment. Inc.. IBM

1.000SCALE: V-1,000'

8,OOP 3.000 4.000 a.OOO FEET

INDEX

1 DORMITORY2 HUMP TOWER3 RETAROER TOWER4 DIESEL SHOP5 CLEANOUT TRACK6 CAR SHOP7 B»B SHOPa WEST TOWERg NORTH TOWER

10 SOUTH TOWER

FIGURE B-1 CONRAIL FACILITY BASE MAP

3-10

performed to preliminarily identify the sources and delineate contami-nation plumes from these sources. Sampling methodologies are discussedin the QAPP and FSP. Soil gas samples will be analyzed by a field gaschroraatograph (GC) to determine the presence of CC1, and TCE. Thesurvey will be initiated by establishing a grid of sampling points,installing probes, and extracting and field analyzing gas from the soil.Samples will be collected from soil at a depth of approximately 5 feet.Figures 5-2 and 5-3 show tentative soil gas survey sampling locations.Alternative 1, Figure 5-2, was developed with the contingency that sitelogistics would preclude a survey of the suspected source areas withinthe Conrail facility. In this situation, the survey would be conductedonly in the area immediately north of the Conrail facility. InAlternative 2, Figure 5-3, the survey would be conducted both in thesuspected source areas within the Conrail facility and in areasimmediately north of the facility.

Final decisions on soil gas sample locations will be made in thefield based on the results of the soil gas analysis and afterconsultation with EPA. The survey will be concentrated in areas shownto be contaminated, based on soil gas analysis, to identify the hotspots.

Cost estimates for this task are based on the followingassumptions:

>

o All activities will be conducted in Level D protection;

o A total of 100 to 150 soil gas survey points will besampled; and ,

o Soil gas will be analyzed by a field GC laboratory.

5.3.3.4 Subsurface Soil SamplingSubsurface soil sampling will be conducted in the Phase 1 in-

vestigation to identify the source areas and subsurface stratigraphy.Preliminary results from soil gas surveys will be utilized to selectboring locations. The horizontal and vertical extent of the source

5-11

SOURCE: Ecology and Environment, Inc.. 1969.

NOTE: ALTERNATIVE 1 SAMPLING PLAN. ASSUMING THAT. DUE TOLOGISTICS AND SUBQRAOE BALLAST NO SAMPLING CAN BECONDUCTED IN THE SUSPECTED SOURCE AREAS ON THECONRAIL FACILITY.

AFTER INITIAL IDENTIFICATION OF HOT SPOTS OH PLUMES.BIASED SAMPINQ WILL BE PERFORMED.

SCALE: r-1500'2.000 3.000

LEGEND

APPROXIMATE LIMIT OF rPROPOSED SURVEY AREA

35C SPACING QUID

900 SPACING GRID

4.000 5.00O FEET

FIGURE 5-2 TENTATIVE SOIL GAS SURVEY SAMPLINGLOCATIONS (ALTERNATIVE 1)

5-12

SOURCE: Ecology «nd Environment. Inc.. 1»»».

NOTE: ALTERNATIVE 2 SAMPLING PLAN, ASSUMING SAMPLING CANBE PERFORMED IN THE SUSPECTED SOURCE AREAS ON THECONRAIL FACILITYAFTER INITIAL IDENTIFICATION OF HOT SPOTS OR PLUMES,BIASED 8AMPINQ WILL BE PERFORMED.

SCALE: r-1500'2,000 3,000 4.000 5.000 FEET

LEGEND

___ APPROXIMATE LIMIT OFPROPOSED SURVEY AREA

^ffifl 500 QUID SPACING

^^H 150 GRID SPACING

FWURE 6-S TENTATIVE SOIL OA« SURVEYLOCATIONS (ALTERNATIVE f)

5-13

areas vill be defined during soil sampling analysis in the subsequentphase(s). In all suspected source areas, one to three soil borings villbe performed. It is expected that a total of 19 to 32 soil borings villbe drilled. Figure 2-2 presents the proposed soil boring locations.Continuous soil samples vill be collected from all soil borings. Fromeach boring, composite soil samples vill be collected from S-foot depthintervals for chemical analysis. Drilling procedures and soil samplingmethods are discussed in the QAPP and FSP. All soil samples collectedvill be screened using headspace method by the field GC laboratory.Soil samples vill be submitted to a Contract Laboratory Program (CLP)laboratory for VOC or TCL/TAL analysis and to the Ecology andEnvironment, Inc. Analytical Services Center (E & E ASC) for oil andgrease analysis. From each boring, a maximum of tvo soil samples villbe selected for VOC or TCL/TAL analysis. Table 5-2 presents theproposed subsurface soil and sediment sample analysis details.Analytical methods for soil analysis using headspace and VOC and TCL/TALanalyses are discussed in the QAPP.

A geological log vill be recorded at each boring location. Theselogs vill describe color, texture, strength, thickness, moisturecontent, geological origin, pB, and soil classification. The unifiedsoil classification system vill be utilized for soil classification.

Cost estimates for this task are based on the follovingassumptions:

o All drilling and sampling activities vill be conducted inLevel D protection;

o A total of 19 to 32 soil borings vill be drilled to anapproximate depth of 20 feet vith continuous soil sampling;

o A total of 84 to 144 soil analysis using headspace methodsfor TCE and CCl vill be performed by the field GClaboratory;

o A total of 9 samples vill be submitted for TCL/TAL analysisand 28 samples for VOC analysis to a CLP laboratory;

5-14

Table 5-2

PROPOSED SUBSURFACE SOIL AND SEDIMENT SAMPLE ANALYSIS DETAILS

Sample LocationMonitoring Well/Boring Number

Head SpaceAnalysis VOCs (1)

TCL/TALand

Oil & Grease

Subsurface SoilConrail

»

Upgradient-west

Upgradient-east

Martin drum site

B-01B-02B-03B-04B-05B-06B-07B-08B-09B-10B-llB-12B-13B-14B-15B-16B-17

MV-13S

MW-17

B-18B-19

44444444444444444

4

4

44

21212122122221221

1

1

12

1

1

1

1

1

1

1

1

1

SedimentCravford Ditch

Conrail Ponds-south

SD-01SD-02

SD-03SD-04SD-05

11

111

Notes

-For boring/monitoring well locations refer to Figures 2-2 and 5-2.-Soil borings will extend at least 5 feet below water table, and forthe cost estimates are assumed to be 20 feet deep.

(1) Volatile organic compounds(2) Target Compound List/Target Analyte List

Source: Ecology and Environment, Inc. 1989.

5-15

o A total of 9 samples will be sent to E & B ASC for oil andgrease analysis;

o Drilling cuttings from soil borings will be backfilled inthe borehole; drilling liquid and all other liquid wastewill be dealt with as described in Section 5.3.4.6; and

o Actual subcontract costs will not exceed those listed inthe budget estimate; the subcontract costs listed in theestimate are based on informal inquiries to the firmslisted on the detail sheets.

5.3.3.5 Sediment SamplingSediment samples will be collected to assess the migration of

hazardous substances through the Cravford Ditch and to assesscontamination conditions in the holding ponds south of the Conrailfacility. Figure 2-2 presents the proposed locations of the sedimentsamples. If the holding ponds are dry (refer to Section 3.2.1), onehand-augered boring will be completed to a depth of 6-feet. 3 sampleswill be collected for soil analysis using headspace method. Based onheadspace analytical results, one sample per boring will be chosen forCLP analysis. Sediment sampling procedures are presented in the QAPPand FSP. Cost estimates for this task are based on collecting fivesediment samples in Level D protection.

5.3.3.6 Groundvater Monitoring and SamplingGroundvater monitoring vill be conducted to determine groundvater

flow conditions and to confirm/identify contamination plumes in thestudy area. At least one monitoring veil vill be installed dovngradientof each suspected source area. A series of monitoring veils vill beinstalled in the EPA/TAT-designated County Road 1 plume area. Monitor-ing veils vill also be installed in the contaminated areas near LaRueStreet and Charles Avenue. Figure 5-4 presents the proposed monitoringveil locations.

Monitoring veils designed to monitor the shallov groundvater zonevill be screened above the silt and clay confining layer. Three pilot

5-16

V^ SUll) /

SOURCE: Ecology and Environment, Inc., 1989

0 WOOSCALE: r-1500'2000__ SOOO 4000 JOOO FEET

LE3ENDPROPOSED MONITORING WELL LOCATION

• SHALLOW -^-DEEP

EXISTING MONITORING WELL LOCATION

O SHALLOW ^ DEEP

PROPOSED PILOT BORING LOCATION

FIGURE 8-4 PROPOSED AND EXI«TIN»MONITORING WELL LOCATION*

borings will extend to bedrock or a maximum depth of 130 feet, whicheveris reached first, for determination of the subsurface stratigraphy inthe study area. Based on the results of these borings, constructiondetails (depth and screen intervals) for deep monitoring veils vill bedecided. The procedures for drilling, soil sampling, well construction,development, and water table measurement are discussed in the QAPP andFSP.

Vater table measurements will be taken subsequent to well com-pletion and on a monthly basis thereafter. Groundwater samples will becollected from all monitoring wells for VOC and/or TCL/TAL analysis.Additional rounds of groundwater sampling from the monitoring wellsinstalled in the Phase 1 investigation may be conducted in the sub-sequent phase(s) investigation to evaluate the influence of seasonalvariation in the contaminant level. These additional rounds of samplingmay also assist in evaluating whether the source areas are continuing tocontribute to the groundwater contamination or are depleting. Pro-cedures for groundwater sampling, shipment, and chain of custody aredescribed in the QAPP and FSP. Table 5-3 presents the proposedgroundwater sample analysis details.

A geological log will be recorded for each boring location as wasdescribed in the subsurface soil sampling section. Physical testingwill be conducted on some of the soil samples by the drillingsubcontractor. Samples to be submitted for physical parameter testingwill be analyzed using headspace method in order to avoid submittingcontaminated samples to the testing laboratory.

Physical parameters to be evaluated will be grain size distributiontests, and vertical permeability and Atterberg limit tests of the siltand clay confining layer (see Table 5-1). Vertical permeability andAtterberg limit tests vill be conducted on three Shelby tube samplescollected from the upgradient monitoring wells MVlld, HV13d, and HV21d.These samples will be collected from the silty clay confining layer.Grain-size distribution tests will be conducted on soil samples fromscreen intervals at the upgradient monitoring wells MWlls, MVlld, MU13s,MU13d, MW21s, and MW21d. The procedures for physical testing aredescribed in the QAPP. Cost estimates for groundwater monitoring andsampling are based on the following assumptions:

5-18

Table 5-3

PROPOSED GROUNDWATER SAMPLE ANALYSIS DETAILS

Location

County Road 1Contamination Area

Charles AvenueContamination Area

State Road 33

Upgradient-Conrail

LaRue StreetContamination Area

Upgradient-east

Monitoring Well Number^1*

MV-01MW-02sMW-02dMW-03MV-04sMW-OAdMW-05sMW-05dMW-06MW-07MW-08sMV-08dMW-09

MV-lOsMV-lOdMV-llsMW-lld

MV-12sMW-12dMV-14MV-15MW-16MW-18

MW-13sMV-13dMW-17

MW-19sMW-19dMW-20sMV-20d

MW-21sMW-21d

VOCs(2) TCL/TAL(3)& Oil & Grease

XXX

XXXXXXXXXX

XXXX

XX

XXXX

XX

X

XXXX

XX

(1) See Figure 5-4 for monitoring well locations(2) Volatile Organic Compounds(3) Target Compound List/Target Analyte List at CLP and Oil and Grease

at E & E ASC


5-19

o All drilling and sampling activities will be conducted inLevel D protection.

o A total of 21 shallow monitoring veils (20 to 40 feet deep)and 11 deep monitoring veils (100 feet deep) vill beinstalled.

o A total of 26 groundvater samples vill be collected for VOCanalysis and 6 groundvater samples for TCL/TAL and oil andgrease analysis.

o All groundvater samples vill be analyzed in the field forpH, conductivity, and temperature.

o Three vertical permeability tests vill be performed,

o Six grain-size distribution tests vill be performed,

o Three Atterberg limit tests vill be performed.

o Drill cuttings vill be drummed and stored. The disposalcost for cuttings is not included in the project costestimate.

o Drilling liquid, veil development vater, vater purged priorto sampling, and liquid generated from decontamination areconsidered special waste and vill be treated/disposed in alandfill. This assumption has been made for cost esti-mation; however other alternatives will be evaluated andthe most feasible one may be employed if approved by theEPA RPH.

o Actual subcontract costs vill not exceed those listed inthe budget estimate. The subcontract costs listed in theestimate are based on informal inquiries to the firmslisted on the detail sheets.

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5.3.3.7 Aquifer Characteristic TestsSlug tests will be conducted on all of the proposed monitoring

wells downgradient of the site to assess the hydraulic characteristics(permeability, transmissivity, and storage coefficient) of the aquifer.This information will be utilized to evaluate the rate of contaminantmigration and to evaluate the remedial action alternatives during theFS. The methods for analysis of slug test data are discussed in theQAPP.

Cost estimates for this task are based on performing 25 slug tests,with all related field activities conducted in Level D protection.

5.4 TASK 4: SAMPLE ANALYSIS AND DATA VALIDATIONE & E will utilize the CLP and E & E ASC to analyze all samples

collected for the project. Compounds analyzed for by the CLP arevolatile organic compounds and those on the TCL and TAL. Oil and greaseanalysis will be performed by E & E ASC. The following groups ofcompounds and analytes are included on the TCL/TAL: volatile organics;semivolatile organics (base/neutral and acid extractables, pesticides,polychlorinated biphenyls (PCBs)); and inorganics consisting of 23metals and cyanide. The field GC laboratory will be utilized for soilgas analysis and the results will be utilized primarily as a screeningmeasure to identify hot spots in the suspected source areas. E & E willalso utilize the field GC laboratory to screen soil samples for CLPanalysis using headspace method. The field GC laboratory will have thecapability to analyze samples for TCE and CC1,. Table 5-1 presents asummary of the field investigation activities.

A summary of the analytical methods to be employed will be providedin the QAPP. The QAPP outlines the quality assurance (QA) program,which insures that all technical data generated are accurate, repre-sentative, and will ultimately withstand judicial scrutiny.

Prior to the submission of analytical reports to EPA Region V, alldata will be evaluated for precision, accuracy, and completeness.Specific procedures for CLP data validation are included within the CLPStatement of Work as Exhibit E, Quality Assurance/Quality ControlRequirements.

5-21

5.5 TASK 5: DATA EVALUATIONField and laboratory data will be evaluated with respect to the

project activities and will be presented in a series of exhibits. Theseexhibits are anticipated to include:

o Site cross-sections depicting stratigraphy, water table,and potentiometric surface;

o Tables presenting contaminant concentrations in variousmedia;

o Figures demonstrating groundwater flow directions; and

o Appendices that present all boring logs, monitoring wellconstruction details, and analytical results.

The data will be evaluated to determine whether the data qualityobjectives have been met, and to identify data gaps for conducting therisk assessment and FS. Based on this data evaluation, decisions willbe made to determine whether a subsequent phase(s) RI/FS is requiredand, if so, what the scope of the subsequent phase(s) would be.

5.6 TASK 6: RISK ASSESSMENT

One of the primary objectives of the RI is to identify the risks tohuman health and the environment resulting from the contaminantsources. A Risk Assessment (RA) will be conducted following thecompletion of the Phase 1 RI/FS. The purpose of the RA is to evaluatethe current and potential future threat to public health and theenvironment under no action conditions. The results of the RA will beutilized to determine whether an interim remedial action is warranted.The results of the Phase 1 RA will be refined in the subsequent phase(s)RI/FS as additional data concerning study area contamination conditionsand potential receptors become available.

5-22

The RA methodology used in the public health evaluation will beconsistent with EPA guidance documents, including:

o The Superfund Public Health Evaluation Manual (EPA 1986a);

o Guidelines for Carcinogen and Mutagenicity Risk Assessment,Guidelines for the Health Assessment of Chemical Mixturesand Development Toxicants, and Exposure Assessment (EPA1986b-f); and

o The Superfund Exposure Assessment Manual (EPA 1988).

According to the National Academy of Science (NAS 1983) and EPA,there are four RA components:

o Hazard identification;

o Dose-response evaluation;

o Exposure assessment; and

o Risk characterization.

The first two of these components, hazard identification and dose-response assessment, collectively comprise the toxicity assessmentmodule for site-related contaminants.

The third RA component, exposure assessment, encompasses evaluationof environmental transport pathways; loci of exposure of human andenvironmental receptors; and exposure routes and scenarios (conditionsof exposure) to estimate doses or intakes by the identified receptors.

The fourth RA component, risk characterization, integrates the dataand findings from the first three components to provide a comprehensivecharacterization of significant site-related human health and environ-mental risks.

5-23

5.7 TASK 7: REMEDIAL INVESTIGATION REPORT5.7.1 Subtask 7.1; Computer Modeling

The RI/FS for this project will include computer modeling of thegroundvater flow and contaminant transport in the study area. Theobjectives of the computer modeling include the following.

o Provision of an additional tool to evaluate the hydro-geology of the study area. A groundwater flow modelprovides a continuous (time-dependent) estimation of theflow parameters (velocity, gradient, etc.) in the studyarea. This makes it possible to determine any significantseasonal variation in the flow parameters, and to make arealistic evaluation of groundwater flow conditions in thestudy area.

o Assisting in evaluating the nature of the contaminantmigration (past and future) and in estimating contaminantloading to the St. Joseph River and Baugo Bay.

o Assisting in the feasibility studies at the study area.

The computer modeling program will address the following:

o A multi-aquifer system with leaky hydrodynamic dispersion;

o Contaminant transport by convection and hydrodynamicdispersion;

o Retardation coefficients;

o Aquifer recharge/discharge properties;

o Surface water/groundwater interaction;

o Aquifer heterogeneities; and

5-24

o Multiple boundary conditions.

The following steps will be taken to develop and apply a computermodel:

o Review of hydrologic and geologic data;

o Review of all contamination data;

o Development of a groundwater flow model;

o Checking/modifying the model against field data(calibration of model);

o Development of contaminant transport model;

o Estimation of contaminant loading to the river; and

o Estimation of current and future concentration levels forreceptors of concern under no action and different remedialscenarios and generation of data for a risk assessment.

Table 5-4 presents a list of groundwater flow/contaminant transportmodels available to E & E.

5.7.2 Subtask 7.2; RI Report PreparationUnder this task, one drafl and one final RI report will be

prepared. These reports will present data obtained during fieldactivities, an analysis of data, and conclusions regarding the natureand extent of contamination, and a risk assessment. Included in the RIreport will be a section describing details of the computer modelingperformed for the study area. This section will discuss the data andmethodologies used, and present the results of transport and fateanalyses. In developing the cost estimate for this subtask, it isassumed that eight copies of the draft and eight copies of the finalreport will be produced for distribution to EPA, IDEM, and E & E.

5-25

Table 5-4

LIST OF GROUNDWATER FLOW/CONTAMINANTTRANSPORT MODELS AVAILABLE TO E «. E

Model Name Description

GWSIM: FEMWATER

PLASMA: PLASMB:SUPERPLASM

FEMVASTE

GWTRANS

RANDOM WALK

DREXEL

Finite element groundvater flow

Finite difference groundvater flow

Finite element solute transport

Finite difference solute transport

Solute transport

Finite element source detection

MODFLOW

' SUTRA

AMPLUME

Finite difference groundvater flov

Finite element solute transport

Solute transport in groundvater


5-26

5.7.3 Subtask 7.3; Treatability Study/Pilot TestingTreatability studies or pilot testing may be conducted as a part of

the remedial investigation in this project. The scope of this workcannot be defined at this time. Therefore, no cost estimate for thissubtask is included in the project cost estimate. As additional databecome available subsequent to the Phase 1 investigation, the scope ofthis work will be defined and submitted along with the subsequentphase(s) investigation for approval.

5-27

6. FEASIBILITY STUDY

As described in the preceding sections, a phased RI/FS will beemployed for the Conrail/County Road 1 project. Because the RI/FS is aninteractive process, the Phase 1 FS will follow the Phase 1 RI and willinclude preliminary screening of the remedial alternatives, and identi-fication of the data needed for scoping the second phase RI. The samesequence will be followed for subsequent phase(s) of the RI/FS until thesubsequent phase(s) RI/FS objectives as presented in Section 4.3 areachieved.

Any phase of the RI/FS (e.g., Phase 1 RI/FS) may include a full-scale FS, if interim remedial action becomes necessary. Under thiscondition, the FS for interim remedial action will be conducted in thesame manner as for "final" remedial action. However, the possibility ofimplementing "final" remedial action will be considered when developingan "interim" remedial action. This adds another element to screeningand evaluating interim remedial alternatives. The following sectionspresent the steps involved in conducting an FS. -'

6.1 TASK 8: REMEDIAL ALTERNATIVE SCREENINGThis task, constitutes the first stage of the FS. The objective of

this task is to develop and evaluate remedial alternatives for addition-al screening and evaluation. The results of the Public HealthEvaluation will be considered throughout this evaluation process.

6-1

6.1.1 Subtask 8.1; Preliminary Remedial TechnologiesTable 6-1 presents a master list of remedial technologies applic-

able to soil, groundwater, surface water, and sediment contamination.Based on the study area conditions, waste characterizations, andtechnical requirements, the master list will be screened to develop thepreliminary remedial alternatives. Those technologies that may proveextremely difficult to implement, require unreasonable time periods, orrely on insufficiently developed technology will be screened out.Emerging technologies that are being evaluated through the EPA's SITEprogram will also be evaluated, if that information is available. Theresults of this task will be summarized in a technical memorandum whichwill be presented to EPA as an attachment to the concurrent monthlystatus report, which is submitted to EPA for each project under the ARCScontract.

6.1.2 Subtask 8.2; Establishment of Remedial Response ObjectivesThe remedial response objectives will be further developed in the

Phase 1 RI/FS and will be refined in the subsequent phase(s) RI/FS asadditional information about study area contamination conditions andhuman and environmental impacts becomes available. For each impactedmedium, a remedial response objective will be developed. The responseobjectives will be based on public health and environmental concerns,Section 300.68 of the National Contingency Plan (NCP), EPA's interimguidance, and the requirements of any other applicable EPA, federal, andIndiana environmental standards, guidance, and advisories as definedunder Section 121 of SARA. Preliminary cleanup objectives will bedeveloped under formayconsultation with EPA and IDEM. Development ofremedial response objectives will also include a refinement of theproject-specific ARARs and TBCs.

6.1.3 Subtask 8.3; Development of AlternativesBased on the results of the RI and consideration of preliminary

remedial technologies, a limited number of alternatives, which are basedon objectives established for the response, will be developed. To theextent that it is both feasible and appropriate, the following alter-natives will be considered.

6-2

Table 6-1

TECHNOLOGY TYPES CORRESPONDING TO SELECTED

GENERAL RESPONSE ACTIONS

Medium General Reiponie Action Technology Type

Soil Containment

Partial or co»pl«t» removal

On-lit* or off-tit* diipoial

On-ait* or off-lit* treatment

In-iitu Treatment

No action

CappingMulti-lay*r*d capiSingle-layered capi

Excavation

Omit* or offlit* landfill

Ther»al treatmentRotary kiln incinerationMultiple hearth incinerationrluidixed bed incinerationInfrared furnace incinerationMolten gait deitructionSupercritical water oxidationPyroliiing rotary kiln

Chemical treatmentChemical fixation

Phyiical treatmentSolidification/itabilisationSoil washingSupercritical extraction

Biological treatmentBioreclamation

ChemicalPrecipitationChelationPolymerizationSoil rluihingHydrolyiiiOxidationReductionNeutralizationPermeable treatment bedsChemical dechlorination

PhysicalVolatilizationVitrificationSoil venting/vacuum extraction

None

6-3

Table 6-1 (Cont.)

Medium General Response Action Technology Type

Groundwater Containment Slurry vailsDiaphragm willsGroutingSheet piling

Collection Pumping (extraction welli)Well points

Subsurface drains

In-situ treatment BioreclamationPermeable treatment bedsActivated carbon bed

On-site treatment ChemicalNeutralisationPrecipitationOxidationReduction

BiologicalActivated sludge

Off-lit* treatment of groundwater

Mo action

PhysicalActivated carbonFiltrationPlocculation/sedimentationIon exchangeReverse osmosisGravity separationAir stripping

Pretreatment/discharge to POTW

None

Sediment On-site drainagecontrol measures

Capping and gradingRevegetation

Sediment removal, treatment,and/or disposal

Mechanical renoval andonsite or offsite treatmentand/or disposal

On-site Drum Debris Removal and disposal Removal and disposal in off-sitelandfill

No action None

6-4

o Treatment alternatives for source control that eliminatethe need for long-term management (including monitoring).

o Alternatives involving treatment as a principal element toreduce the toxicity, mobility, or volume of waste.

In addition, the following two alternatives will be considered:

o An alternative that involves containment of waste withlittle or no treatment but provides protection of humanhealth and the environment primarily by preventing exposureto or reducing the mobility of the waste.

o A no action alternative.

For groundwater response actions, a limited number of remedialalternatives will be developed within a performance range that isdefined in terms of a remediation level. The targeted remediation level

4 7will be within the risk range of 10 to 10 for maximum lifetime riskand includes different rates of restoration. If feasible, one alterna-tive that would restore groundwater quality to a 10~ risk for maximumlifetime risk level within five years will be configured.

The remedial action alternatives developed for the Conrail/CountyRoad 1 study area may involve both source control and groundwaterresponse actions. In these instances, the two elements may beformulated together so that the comprehensive remedial action iseffective and the elements are complementary. However, because eachelement has different requirements, they will be detailed separately inthe development and analysis of alternatives.

6.1.4 Subtask 8.4; Initial Screening of AlternativesThe remedial alternatives identified will be screened on the basis

of effectiveness, implementability, and cost. Each of these factors isdescribed herein.

6-5

o Effectiveness. Alternatives will be evaluated to determinewhether they adequately protect human health and theenvironment and meet contaminant-specific ARARs and TBCs.For example, a thermal destruction process unable togenerate sufficient temperatures to attain TSCA-mandateddestruction removal efficiencies (DREs) for PCBs would bescreened out. Additionally, the reliability of the processwill be taken into consideration. Processes not proven tobe applicable to the specific contaminants at the site maybe discarded.

o Implementability. This factor relates to whether or not aprocess option is workable at the site. Processes not ableto meet location- and action-specific ARARs will bescreened out. Processes requiring prohibitively extensivepermitting from government agencies may also be dropped.Additionally, if sufficient treatment, storage, or disposalcapacity is not available for certain off-site options,these also may be screened out.

o Cost. Cost will not be used as a major factor in thescreening of process options. Cost will only be a factorin comparing process options that can produce similarlevels of remediation.

As a result of the screening of the identified alternatives, atleast six remedial alternatives will be selected. The alternativesselected will be in compliance with CERCLA, SARA, and otherenvironmental statutes.

6.1.5 Subtask 8.5; Alternative Array DocumentTo obtain ARARs from IDEM and EPA, a detailed description of alter-

natives (including the extent of remediation, contaminant levels to beaddressed, and method of treatment) will be prepared. This documentwill also include a brief site history and background, a site char-acterization that indicates the contaminants of concern, migration

6-6

pathways, receptors, and other pertinent site information. A copy ofthis Alternative Array Document will be submitted to EPA and IDEM, alongwith the request for a notification of the standards.

6.1.6 Subtask 8.6; Data RequirementsData requirements that are specific to the relevant and applicable

technologies will be identified. These requirements will be focused onproviding data that is needed for detailed evaluation and development ofa preferred alternative.

6.2 TASK 9: REMEDIAL ALTERNATIVES EVALUATIONAlternatives remaining after the initial screening described in the

previous step will undergo further analysis. Criteria by which thealternatives will be assessed include the following.

o Compliance with ARARs and TBCs. This criterion is used todetermine how each alternative complies with ARARs andTBCs. A preliminary list of ARARs is provided in Table 3-1and a preliminary list of TBCs is provided in Table 3-2.

o Reduction of mobility, toxicity, or volume. This criterionis used for selecting remedial alternatives that employtreatment technologies that permanently and significantlyreduce toxicity, mobility, or volume of the contaminant.The factors to be evaluated include:

- Treatment process and remedy,

- Amount of hazardous material destroyed or treated,

- Reduction in toxicity, mobility, or volume of thecontaminants,

- Irreversibility of the treatment, and

- Type and quantity of treatment residuals.

6-7

o Short-term effectiveness. This criterion addresses theeffects of the alternative during the implementation phaseuntil the remediation action is complete. The factors tobe evaluated include time necessary to implement the reme-dial action and short-term threats to the safety of nearbycommunities, workers at the site, and the environmentduring the construction period.

o Long-term effectiveness. This criterion addresses thelong-term threats to human health and the environment aftercompletion of remedial action. The primary focus of thisevaluation is to determine the extent and effectiveness ofthe controls that may be required to manage the risk posedby treatment residuals and/or untreated wastes.

o Implementability. This criterion addresses the technicaland administrative feasibility of implementing an alter-native. Considerations of technical feasibility include:

- Ability to construct the technology or technologiesinvolved,

- Performance and reliability of the technology(ies), and

- Ease of undertaking additional remedial action, ifnecessary, and operation and maintenance considerations./

Considerations of administrative feasibility include:

- Coordination with other agencies,

- Availability of treatment, storage capacity, anddisposal services, and

- Availability of necessary equipment and specialists.

6-8

o Cost. This criterion addresses the costs of remediation.Costs to be considered include the cost of implementation,operation, and maintenance of each alternative. Becauseall of the work will not be conducted at the same time, apresent-worth analysis needs to be performed.

o Community acceptance. This criterion incorporates publicconcerns into the evaluation of the remedial alternatives.

o State acceptance. This criterion evaluates the technicaland administrative issues and concerns that the state ofIndiana may have regarding each of the alternatives.

o Overall protection of human health and the environment.This criterion is utilized to evaluate whether eachalternative meets the requirement that it be protective ofhuman health and the environment. Factors to be evaluatedinclude:

- Consistency of the remedial alternative with the risk,assessment performed in Task 6,

- Compliance with ARARs and TBCs,

- Short-term and long-term effectiveness, and}

- Environmental impact.

After each alternative has been individually assessed against eachof the nine criteria, a comparative analysis will be conducted to selectthe most feasible alternative. In this analysis, the relative strengthsand weaknesses of each alternative, with respect to each criterion, willbe weighed. If innovative technologies are being considered, their

6-9

potential advantages in cost or performance and the degree of uncer-tainty in their expected performance will be evaluated and considered inthe selection of the preferred remedial alternative.

A cost evaluation will be performed for each of the selectedremedial alternatives and will include the following steps:

o Operation and maintenance, and institutional costs;o Present-worth analysis; ando Sensitivity analysis.

6.3 TASK 10: FEASIBILITY STUDY REPORTThe entire FS process will be documented in a draft FS report and,

following receipt of written comments from EPA, in a final FS report.The FS report will not be considered final until a letter of approval isissued by the RPA. The FS report will document the decision processused by the project team for the selection of the recommended alter-native. The FS report will include a description of the technologiesconsidered, the screening and evaluation process used, a summary of thedetailed technical and cost evaluations, and the comparative evaluationof remedial alternatives.

In developing the cost estimate for this task, it is assumed thateight copies of the draft and eight copies of the final report will beproduced for distribution to EPA, IDEM, and E & E.

6.4 TASK 11: POST-RI/FS ACTIVITIES

; This task is divided into three subtasks. The scope of work forthis task cannot be determined at this time. However, a preliminarycost estimate has been made for each subtask for inclusion in theproject cost estimate. These preliminary cost estimates are based on avery limited scope of work for this task. The scope of work for thistask may be modified and expanded to include E & E's extensiveinvolvement in negotiating with PRPs, the development of the Record ofDecision (ROD), a more detailed development of the conceptualremediation design, and other post-RI/FS activities.

6-10

6.4.1 Subtask 11.1 Post-RI/FS SupportE & E will provide support to EPA, when requested, for activities

that occur after the Conrail/County Road 1 project RI/FS is completed.Support will include community relations, negotiations with PRPs,assistance in preparing the ROD or Responsiveness Summary, andassistance to parties involved in the remedial design/remedial action.A 40-hour level of effort (LOE) for negotiation support is assumed inthe cost estimate for this subtask..

6.4.2 Subtask 11.2 Project CloseoutPost-RI/FS activities will also include project closeout and

transfer of project-related information to the EPA. The full scope ofthese activities has not been developed, and will be more clearlydefined as the project progresses.

6.4.3 Subtask 11.3 Predesign ReportAs a part of post-RI/FS support, EPA may request that E & E develop

a conceptual remediation design for the project. As a part of theconceptual remedial design phase, a predesign report will be prepared,which includes the following elements:

o Development of a conceptual remediation design;

o Determination of the scope of predesign studies (if needed)to identify data gaps in order to conduct a full-scaleremediation design;

o Development of criteria for selection of a contractor/consultant to prepare a full-scale remediation design;

o Development of a preliminary design specification outline;and

o Development of the conceptual design schedule and costestimate.

6-11

7. TASK 12: PROJECT MANAGEMENT

7.1 ORGANIZATION AND APPROACHThe Conrail/County Road 1 RI/FS will be accomplished using a

functional task breakdown following the standard RI/FS tasks, as coveredin E & E's Management Plan and required by EPA. The project managerwill have the primary responsibility for implementing the RI/FS.Implementation of the RI/FS will include:

o Coordinating the two primary segments of the project (RIand FS) through key task leaders;

o Insuring that the necessary resources (personnel andequipment) are available;

o Vorking with the review team leader to assure qualitydeliverablesj and

o Providing continued communication with the EPA's RPM.

Continued communication will insure that EPA receives projectinformation in a timely manner and is updated on the progress of thework and any potential problems or necessary changes in the direction ofproject methods or goals. The project organization is shown on Figure7-1.

7-1

"IH28KT

•WS3SEZTOXl tmr

tCAU

SOURCE: Ecology and Environment. Inc. 1989.

FIGURE 7-1 PROJECT ORGANIZATION FOR CONRAIL / COUNTY ROAD 1 PROJECT

7.2 PROJECT SCHEDULEFigure 7-2 provides a schedule for the completion of the Phase 1

RI/FS and the rest of RI/FS tasks outlined in this Work Plan. Theproposed schedule does not include subsequent phase(s) of the FieldInvestigation because the scope of the work cannot be determined at thistime. The scope of subsequent phase(s) of the Field Investigation willbe determined following Phase 1 Field Investigation activities andevaluation of the data collected from this phase. The followingassumptions have been made for formulation of the proposed projectschedule.

o The start date for the RI/FS will be contingent upon thenotice to proceed from EPA.

o EPA will obtain site access for field investigationactivities.

o EPA personnel will respond to draft submittals withinapproximately 5 weeks.

o Level D protection will be required for all field investi-gation activities. However, it is possible that the siteconditions could change, requiring a higher protectionlevel. Should this happen, time estimates outlined in thisplan would no longer be valid and a revised schedule may berequired.

o All the equipment for the Field Investigation will beprocured prior to the scheduled start of fieldinvestigations.

7-3

ACTIVITY / / /„> y / WEEKS

TASK1 PROJECT PLANNING (WP/SAP/H«S)TASK 2 COMMUNITY RELATIONS

Subtaik2.1 Commun«yRelaliorePI«nSubU«k22 FldShMUSuW.sk 23 PuMcCommMAdMlMSubUlk2.4 Community ReMlonl ImptormnUton

TASK 3 SITE INVESTX5ATION rphM* 1)SutalMk 3.1 BU SpMMcdton ActvMo

SoblMk 3.2 Utarakn SiaJi

3.3.1 MDUb^on tiimiB«lnn Support332 StaSunnylngindkbppkig333 SolOv Survey334 SubwrteoiSolSmpIng333 8*t*mm Simping

TASK 4 SAMPLE ANALYSIS AND DATA VALDATKXTASKS DATA EVALUATIONTASK* RISKASSESMENTTASK? Rl REPORT PREPARATION/

OROUNDWATCR MOOELNQSurjtart71 Compute MoiMng9uMw»7J RIFtoportPrapintfon

TASKS REMEDIAL ALTERNATIVES SCREENMQSuUMk6.1 Pi»lii*»»/> RemedM Ttcrnotogtoi

RHportM OlfKlWB

^ublaifc 8.4 Mill "cienJinj ot AA»mrtv*fSUHuka5 Aftvntfhw Array DocunwrtSubtMkSe DMaRequkwnM

TASK B REMEDIAL ALTERNATIVES EVALUATIONTASK 10 FEASWUTY STUDY REPORTTASK 11 POSTRIrFSACTIVrreS

SuMMktll Po« RVFS SupportSubMk11.2 Pro)MCIoMoulSublMkll.3 PredMlgn Report

TASK 12 PROJECT MANAGEMENT

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LEGEND

vvx CLP OR E4E ASC SAMPLE ANALYSIS • TASK TECHNICAL MEMORANDUM A DRAFT DELIVERABLE• • • • • EPA REVIEW O PUBLIC MEETING I FINAL DELIVERABLE

FIGURE 7-2 CONRAIL /COUNTY ROAD 1PROJECT SCHEDULE

A second Fact Sheet will be prepared and related publiccomment activities conducted at the end ol Phase 1

7.3 PROJECT COSTSDetailed project costs have been broken down by standard tasks and

are provided under separate cover. Costs for field equipment purchaseand rental are not included in the budget estimate. Miscellaneoussupplies, such as tools, film, fuel for rental vehicles and other fieldequipment, and other expendable supplies will not exceed the amountlisted in the estimate.

The project cost package includes the following information:

o Optional form 60;

o Tabulation of the estimated LOE by labor categoryapportioned by task; and

o The estimated dollar costs for the RI/FS broken down bytask as well as by labor, travel, equipment, computers,miscellaneous, and subcontractors.

7-5

8. REFERENCES

EIS Environmental Engineers, Inc., April 1986, Report on Soil DrumSampling and Analysis, Clifford P. Martin Estate, U.S. 33 Vest,Elkart, Indiana, Project number 1291-01.

Goodvin, Procter & Hoar, October 1988, Final Report HydrogeologicalInvestigation and Hazard Evaluation Gemeinhardt Site Area, Elkhart,Indiana, Boston, Massachusetts.

Jacobs Engineering Group, Inc., Environmental Systems Division,September 1987, Potentially Responsible Party Search for ConrailRail Yard, Elkhart, Indiana (confidential document).

McCaslin & McCaslin, December 9, 1988, Response to U.S. EPA request forInformation Concerning Martin Drum Site, Elkhart, Indiana.

NAS, 1983, Risk Assessment in the Federal Government: Managing theProcess, National Academy Press.

Peerless-Midvest, Inc., no date, Hydrogeologic Study Enchanted OaksEstates, Osceola, Indiana, Water Supply Contractors, Granger,Indiana.

Roy F. Weston, Inc., October 1986a, Site Assessment for ConrailFacility, Elkhart, Indiana.

8-1

Roy F. Veston, Inc., November 26, 1986b, letter to U.S. EPA,supplemental to the Site Assessment Report for Conrail Facility,Elkhart, Indiana.

Roy F. Weston, Inc., December 30, 1986c, letter to U.S. EPA concerningTAT Assessment of Martin Drum Site, Elkhart, Indiana.

U.S. Department of Agriculture Soil Conservation Service, April 1974,Soil Survey of Elkhart County, Indiana.

U.S. Department of Commerce, June 1968, Reprinted 1979, Climatic Atlasof the United States.

U.S. EPA, 1986a, Superfund Public Health Evaluation Manual, Office ofEmergency and Remedial Response, Environmental Protection Agency.

_______, 1986b, Guidelines for Carcinogen Risk Assessment, 51 FederalRegister 33992-3A005.

____, 1986c, Guidelines for Mutagenicity Risk Assessment, 51Federal Register 34006-34012.

, 1986d, Guidelines for the Health Assessment for ChemicalMixtures, 51 Federal Register 34014-34025.

____, 1986e, Guidelines for the Health Assessment for SuspectDevelopmental Toxicants, 51 Federal Register 34028-34040.

, 1986f, Guidelines for Exposure Assessment, 51 FederalRegister 34042-34054.

____, 1988, Superfund Exposure Assessment Manual, Office ofRemedial Response.

8-2

USGS, October 1981, Hydrologic and Chemical Evaluation of theGroundvater Resources of Northwest Elkhart County, IndianaGeological Survey Water Resources Investigation, 81-53.

1816:1

8-3

APPENDIX A

SUMMARY OF ADDITIONAL

HYDROGEOLOGICAL AND CONTAMINATIONINVESTIGATIONS

A-l

Hydrologic and Chemical Evaluation of the Groundvater Resources ofNorthwest Elkhart County, Indiana (USGS 1981).

This is the most extensive study of the geology and hydrology of theElkhart, Elkhart County area. This study provides the basic geologicaland hydrological framework for investigations in this area. Maps of thelocal bedrock geology, confining bed thickness and distribution,confined and unconfined aquifer thickness and distribution. Thisreport, however, deals with a different groundwater problem, but is themost useful, basic report of the area.

Final Report Hydrogeological Investigation and Hazard EvaluationGemeinhardt Site Area (Goodwin, Procter & Hoar 1988).

The objective of this investigation was to characterize the sources,extent, and potential for impact on human health of off-site groundwatercontamination to the northwest of the Gemeinhardt property in Elkhart,Indiana. Results indicated tetrachloroethane, trichloroethene, and1,1,1-trichloroethane were introduced to the groundwater on-site.Computer modeling could not demonstrate Gemeinhardt was the solegenerator of trichloroethene without incorporating additional sources inthe vicinity of the site. The extent of each contaminant's plume hasbeen identified and mapped, and plumes have not yet reached the Conrailrailyard.

A-2

APPENDIX B

RESULTS OF GROUNDWATERSAMPLING CONDUCTED BY EPA/TAT

B-l

Table B-l compiles results of water quality tests on residential andbusiness wells north of the Conrail facility and along County Road 1.All samples were taken unfiltered if a filter system was installed.Figure B-l presents the sample collection locations.

Table B-2 compiles results of water quality tests on residential wellsnorth of the Conrail facility in the LaRue Street area. Figure B-2presents sample collection locations.

B-2

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Taolt 1-1, Continued

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B-5

Table B-2

CONTAMINANTS IN THE LARUE STREET AREA(PPB)

Address

56485 Elm Ridge56550 Elm Ridge56566 Elm Ridge56580 Elm Ridge56620 Elm Ridge56678 Elm Ridge56726 Elm Ridge

56631 Upper Parkway56642 Upper Parkway56708 Upper Parkway56723 Upper Parkway56740 Upper Parkway

56745 Spring Avenue

56631 Boss Avenue

j28316 Illinois Avenue

56601 Best Avenue56675 Best Avenue

28395 LaRue Street28298 LaRue Street28276 LaRue Street28238 LaRue Street

TCE TCA CC14 DCA DCE

1.1 0.11.2 0.3

25.719.6 10.069.6NDND

0.3ND5.3ND

47.5 17.5

ND

ND

ND

0.30.2

NDNDND0.3 1.3

B-6

Table B-2, Continued

Address

28230 LaRue Street28220 LaRue Street28211 LaRue Street28196 LaRue Street28158 LaRue Street28091 LaRue StreetChurch East End, LaRue Street

28479 US 3328339 US 3328273 US 3328213 US 33

28192 County Road 1628178 County Road 16

TCE TCA CCl^ DCA DCE

78.5 5.659.7 0.41.0 0.486.5ND0.23.3 0.2

ND300 67.00.1 15096.2

0.2 0.4ND

56609 Lake Shore Avenue ND

28195 Pennsylvania 0.2

1717 Nappanee 0.61330 Nappanee -' 0.2

56349 Burr 0.4

1338 Laramie 0.1 7.61332 Laramie 0.3 45.5

1212 Uaurika 0.31430 Vaurika 0.2

B-7

Table B-2, Continued

Address

1430 Okena

1237 Water Street1401 Water Street1625 Water Street

1315 Edgewater1414 Navajo

2217 West Franklin

2022 Lusher Avenue1839 Lusher Avenue

18206 Fieldhouse28129 Fieldhouse28075 Fieldhouse2083 Fieldhouse2023 Fieldhouse1745 Fieldhouse

28165 Markle28101 Markle

TCE

0.315.0

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8.3

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0.28.30.2

0.418.9

6.8

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0.8

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1819 Markle

1807 Leininger

2421 Nappanee

1809 Hively Avenue

0.2 2.8

0.6

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2.8 15.5

0.4

B-8