INDIANA HARBOR AND CANAL MAINTENANCEDREDGING AND DISPOSAL ACTIVITIES – DESIGNDOCUMENTATION REPORT

HTRW EVALUATION

APPENDIX I

U.S. Army Corps of Engineers, Chicago DistrictHydraulics and Environmental Engineering Branch

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The U.S. Army Corps of Engineers (USACE) issued a two-volume ComprehensiveManagement Plan (CMP) in January 1999 for the Indiana Harbor and Canal project. Volume2 (dated September 1998) contained an hazardous, toxic, and radioactive waste (HTRW)evaluation. The U.S. Environmental Protection Agency (Dave Petrovsky), Indiana Departmentof Environmental Management (Steve West) and East Chicago Waterway Management District(Adriane Esparza) were contacted in June, 1999, to determine if any changes had occurred ornew regulatory issues been identified at the ECI site since the CMP. No changes or new issueswere identified.

The HTRW evaluation, which was Appendix R in the CMP, is included in this appendix of theDesign Documentation Report in its entirety. Since the CMP was issued, several places in theappendix need to be updated:

1) The Indiana Department of Environmental Management instead of the U.S. EnvironmentalProtection Agency (as stated on page I-2) has primary Corrective Action authority under theResource Conservation and Recovery Act.

2) At the time the appendix was written, two contractors were to perform future siteinvestigations and make the results available to USACE. On pages I-3 and I-11, it was statedthat Geraghty & Miller (G&M) and ERM, respectively, were to conduct site investigations asconsultants to the Atlantic Richfield Company. Geraghty & Miller’s report consisted of anevaluation of the hydraulic interaction of the Canal and shallow groundwater. Because thereport did not include any soil or groundwater analytical results, it has not been included in theHTRW appendix. Pertinent site investigation data from the ERM investigation was summarizedand is included as Attachment I-1 to the appendix. A reference was also made in the appendixto a report written by Ecology & Environment, Inc. This 1991 report preceded the siteinvestigations done by G&M and ERM and did not have new information on the site. Theinformation in the above reports do not impact the conclusions of the HTRW evaluation.

3) In 1995, USACE collected groundwater samples from eight monitoring wells located in the4 corners and center of the site. The purpose of the sampling event was to analyze thegroundwater for the parameters that have pre-treatment requirements for the East ChicagoDistrict’s (ECSD) Wastewater Treatment plant. The samples were analyzed for volatiles usingmethod 8260; semi-volatiles using SW-846 method 8270; PCBs using SW-846 method 8080;various metals and other parameters. The metals analyzed were cadmium, chromium, copper,lead, nickel, silver, thallium, and zinc using SW-846 method 6010 and mercury using SW-846method 7470. The other parameters analyzed were: ammonia-nitrogen (EPA method 350.1);cyanide (EPA method 335.3); fluoride (EPA method 340.2); phosphorus (EPAmethod 365.2); oil and grease (EPA method 413.1); phenolics (EPA method 420.2); chlorides(EPA method 325.3); sulfate (EPA method 375.4); alkalinity (EPA method 310.1); suspendedsolids (EPA method 160.2), and dissolved solids (EPA method 160.1). At that time thehydrocarbon thickness was 3 feet in the center of the site, decreasing to less than a foot by the

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canal. The other five wells measured had no hydrocarbon layer. Prior to this time, the highestmeasurement of the hydrocarbon thickness on the site was 7.8 feet. The analytical results werecompared to ECSD’s pretreatment limits as shown in Attachment I-2. The concentrations ofthe samples were below the pretreatment discharge limitations for all parameters except two. The sample from MW-5 exceeded the benzene limitation and the sample from MW-1exceeded the oil & grease limitation. No volatile or semi-volatile chorinated compounds orPCBs were detected. None of this data impacts the conclusions of the HTRW evaluation.

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TABLE OF CONTENTS

Section Page

1. AUTHORITY I-1

2. APPROACH I-1

3. PROJECT DESCRIPTION I-1

4. SITE VISIT I-6

5. DATABASE INFORMATION I-6 5.1 Aerial Photographs and Maps I-11

6. SITE CHARACTERIZATION DATA I-11

7. PHONE COORDINATION I-12

8. HTRW ENVIRONMENTAL ISSUES I-12

9. CONCLUSIONS I-13

LIST OF TABLES

No. Subject Page

I-1 FINDS Database Retrieval I-7

I-2 Ground Water Elevations and Product Thickness I-14

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I-3 Hydrocarbon API and Specific Gravities I-17 I-4 Summary of Hydrocarbon Characteristics I-19

LIST OF FIGURES

I-1 Location of Sampling Points and Product Thickness I-21

LIST OF ATTACHMENTS

ATTACHMENT I-1 – Data from previous site investigation

ATTACHMENT I-2 - Results From 1995 Groundwater Sampling Event

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1. AUTHORITY

The Water Resources Policies and Authorities ER 1165-2-132, Hazardous, Toxic and Radioactive Waste (HTRW)Guidance for Civil Works projects, requires that a siteinvestigation be conducted as early as possible toidentify and evaluate potential HTRW problems. Thisreport documents the work performed during preparation ofthe Environmental Impact Statement for the constructionof a Confined Disposal Facility (CDF) to be used fordredge material from Indiana Harbor and Indiana HarborCanal, Indiana.

2. APPROACH

The purpose of this investigation was to evaluate theextent of HTRW at the ECI site in East Chicago, Indianaand to determine what impacts known HTRW materials willhave on construction and operation of a CDF at that site. This assessment relied primarily on coordination withthe U.S. Environmental Protection Agency (USEPA), theIndiana Department of Environmental Management (IDEM),the City of East Chicago and site characterization dataobtained by Geraghty & Miller, Inc., a consultant forARCO, Inc. Additional information was obtained from theUSEPA Facilities Index System Database (FINDS).

3. PROJECT DESCRIPTION

The ECI site had been owned and operated for 60 years bySinclair Oil Company, Inc. Sinclair sold the site in1968, prior to enactment of the Resource Conservation andRecovery Act (RCRA), to Atlantic Richfield Company(ARCO). ARCO operated the site for 8 years and sold thesite in 1976 to Energy Cooperative, Inc. (ECI). ECInotified the USEPA, Region V on July 1, 1980 of hazardouswaste activity on the site. ECI submitted a Part Aapplication on November 13, 1980 as required by RCRA andacquired RCRA interim status. The Part A applicationindicated that slop oil emulsion solids from petroleumrefining (listed hazardous waste K049) and separatorsludge (listed hazardous waste K051) were being stored intanks and incinerated at the facility. ECI filed forChapter 11 bankruptcy in 1981. In 1984, U.S. BankruptcyCourt, Northern District of Illinois, Eastern Division,ordered the facility to be closed in an environmentallysound manner.

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ECI's contractor razed all above ground structures andidentified hazardous wastes for removal. Identifiedhazardous wastes included 600 cubic yards of APIseparator sludge (K051) located in an API separator, twotanks containing a total of 2,558 barrels of APIseparator sludge, two tanks totaling 61 barrels of slopoil emulsion solid (K049), six drums of tetraethyl leadwaste, and 7,000 barrels of waste gasoline. In additionto the tanks, storage containers and the incinerator,there were several pits, sumps and spill areas. Pumpswere removed from lead pump pits and then the pits werefilled. There was no testing of residuals that remainedin the pits. Subsequently, the site was graded fordrainage and covered with top soil.

Despite these activities, the hazardous waste units werenever closed in accordance with the requirements of RCRA(40 CFR Part 265, Subpart G). RCRA requires closure whena hazardous waste treatment, storage or disposal unitceases operation. Under RCRA closure the site can eitherbe clean closed, meaning contamination is not present oris removed, or closed in place, meaning contaminants arecontained in place and monitored. It is anticipated thatclean closure would not be feasible for the ECI site.

In addition, as the ECI facility was still seeking ahazardous waste permit after November 8, 1984, thefacility is also subject to RCRA corrective action (RCRASections 3004 (u) and (v), and 3008 (h)). RCRAcorrective action requires remediation as necessary toprotect human health and the environment from allreleases of hazardous waste and hazardous constituentsfrom solid waste management units at the facility. TheRCRA closure and corrective action requirementsassociated with the portions of the site affected by theCDF proposal have been integrated into the CDF design.

The U.S. EPA and the Indiana Department of EnvironmentalManagement (IDEM) share the responsibility foradministration and implementation of the RCRA programwithin the State of Indiana. Both IDEM and U.S. EPAagree that the RCRA closure and corrective action issuesassociated with the ECI site will need to be addressed. As noted above, IDEM and U.S. EPA have determined thatthe closure of the hazardous waste units previouslyhoused at the facility and corrective action for thefacility portions which would underlie the CDF can beincorporated into the CDF design. The remaining

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corrective action requirements for the non-CDF facilityparcels at the ECI site would be addressed in the future. Proposals for the closure of RCRA hazardous waste unitsin the State of Indiana must be approved by IDEM. Theimplementation of corrective action in the State ofIndiana is currently the responsibility of the U.S. EPA.

In 1989 the City of East Chicago foreclosed on the ECIsite as payment for back taxes, unaware of the site'sRCRA status. Since the City of East Chicago became theowner of the site without having approved correctiveaction and closure plans in place, the City of EastChicago assumed the RCRA liability and is currently theresponsible party. A Phase III SubsurfaceCharacterization performed by ERM, Inc. confirmed theUSEPA's speculation that debris and underground storagetanks and pipelines had been left in place. The USEPAanticipates that the contaminants on site will consistmostly of crude oil and refined crude oil due mostly tospillage.

In July 1990, the U.S. Coast Guard reported observationof free product flowing from seeps on the ECI site intothe Lake George Branch of the Indiana Harbor Canal. Inorder to contain the flow, the City of East Chicagoinstalled 4 recovery wells in December of 1992. Thewells were placed adjacent to an existing sheet pile walllocated parallel to the Lake George Branch of the IndianaHarbor Canal, from Indianapolis Boulevard to the railroadat the western edge of parcel IIA. An inspection of thesheet pile wall indicated that there may be a break nearthe center of the wall. The recovery wells were placedat each end of the sheetpile wall, and near the suspectedbreak. Analysis of the recovery water from the wells hasidentified product from wells placed at the two ends ofthe sheetpile wall but not from those placed near themiddle.

Twice during the 1980's the USEPA, investigated the ECIsite and tabulated a score for the site under theComprehensive Environmental Response Compensation andLiability Act (CERCLA). On both occasions the score wasnot high enough to place the site on the NationalPriorities List or the State Superfund List, but sincescores were tabulated, the site appears on the CERCLISDatabase.

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ARCO's consultant, Geraghty & Miller, Inc. has conducteda site investigation and in addition to geological data,has collected information on the occurrence and thicknessof free phase hydrocarbons at the ECI site. Geraghty &Miller also intends to collect geochemical andgeotechnical data from the ECI site, which will be madeavailable to the Corps of Engineers upon receipt.

As noted above, various elements required to completeRCRA closure/corrective actions for the underlyingportions of the CDF at the ECI facility have beenincorporated into the CDF design and would becomeintegral to the CDF. These include: (1) a slurry wallaround the perimeter of ECI Parcels I, IIA and IIBextending from the ground surface down about 33 feet tothe stiff clay underlying the site; (2) a clay cap onParcel I, tied into the slurry wall; (3) a groundwatergradient control system on Parcels I, IIA, and IIB; and(4) installation of an on-site facility for pre-treatmentof groundwater collected from Parcels I, IIA, and IIB, ifneeded. In contrast to Parcel I which would be cappedduring the initial phase of CDF construction, finalclosure of the CDF, would also fulfill the cappingrequirements for the RCRA corrective action of ParcelsIIA and IIB.

Parcel I previously housed the RCRA hazardous waste unitsat the facility. These structures were razed along withthe rest of the above ground structures, but were neverclosed in conformance with the RCRA regulations. Due tothe apparent ubiquitous nature of the on-sitecontamination on this Parcel and in accordance with theirregulatory authorities, IDEM determined that closure in-place would be most appropriate for the area whichpreviously housed the hazardous waste units. The in-situclosure design for Parcel I would include a slurry wall,a gradient control system consisting of ground waterextraction wells which would maintain ground water flowinto this portion of the CDF and an overlying 3-footcompacted clay cap with a hydraulic conductivity of 10-7

cm/s. The compacted clay cap would be placed on theexisting surface and would overlie Parcel I. The slurrywall would extend approximately 33 feet from the groundsurface into an underlying clay till unit. U.S. EPA hasdetermined that construction of these components wouldalso address the corrective action requirements forParcel I. These RCRA closure and corrective actioncomponents have been incorporated into the proposed CDF

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design. Once constructed, Parcel I would be subject tothe RCRA post-closure care and permitting requirementsapplicable to hazardous waste units for maintenance andmonitoring. Corrective action for the non-CDF portionsof the ECI site would be addressed at that time. Thepost-closure care requirements under RCRA would beintegrated into the maintenance and monitoringrequirements for the CDF.

The CDF will also overlie facility Parcels IIA and IIB. Unlike Parcel I, these site portions never housedhazardous waste units and are not subject to the RCRAclosure requirements. However, these facility portionsare subject to the RCRA corrective action requirements,which addresses releases associated with waste handlingpractices to the environment. Given the apparentwidespread presence of contamination associated withthese facility parcels, U.S. EPA determined that anacceptable corrective action scenario for these siteportions would be similar to the proposed correctiveaction scenario outlined above for Parcel I. This wouldconsist of a perimeter slurry wall associated with ahydraulic conductivity of 10-7 cm/s tied into theunderlying clay unit, and a ground water removal systemconsisting of ground water extraction wells placed withinthe interior of the slurry wall. In contrast to theplacement of the overlying clay layer for Parcel Iproviding the final cap for this site portion, finalcapping of Parcel IIA and IIB would be done during finalclosure of the CDF. The corrective action components forParcels IIA and IIB would be incorporated into the CDFdesign and connected to the closure/corrective actioncomponents for Parcel I. The corrective actionmaintenance and monitoring requirements for thesefacility parcels would integrated into the maintenanceand monitoring requirements of the CDF.

In addition, the facility would also be subject tomaintenance and monitoring requirements under the TSCAauthorization as the CDF would house the regulated PCBsediments currently within the Project. A subcell withinthe CDF will be constructed in accordance with therequirements under TSCA for the disposal of the Projectsediments associated with PCB concentration equal to orexceeding 50 ppm. These maintenance and monitoringrequirements for this subcell under TSCA would also beintegrated into the maintenance and monitoringrequirements for the CDF.

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Final closure design of the CDF and the corrective actionunit for Parcels IIA and IIB, would entail the placementof cap. After final closure, maintenance of the CDF willinclude the removal of any volunteer vegetation whichcould impact the hydraulic conductivity of the compactedclay liner.

The U.S. Army Corps of Engineers, Chicago Districtcoordinated extensively with the USEPA, Region V and theIDEM in 1992 to develop the plan discussed above tocombine the required RCRA closure and corrective actionswith construction of a dredged material confined disposalfacility on Parcels IIA and IIB of the ECI site. Theobjective of the discussions was to develop a combinedplan that was cost-effective and environmentally sound,met regulatory requirements, and resulted in significantcost savings for Federal interests.

The USEPA and the IDEM indicated that if the proposed CDFwere to be constructed on a clean upland site as opposedto an existing contaminated site, such as the ECI site,total hydraulic separation between the CDF and the sitewould be required. Total hydraulic separation wouldinvolve construction of several very costly separationliners and monitoring layers. However, due to widespreadnature of the contamination at the ECI site, the closureand the corrective action needs for the underlyingportions of the site have been incorporated into the CDFdesign. Thus the slurry wall and gradient control systemwould be used to contain both the on-site contaminationand the contaminants associated with the Projectsediments.

4. SITE VISIT

Ms. Kay Nelson, Project Manager for the East ChicagoSanitary District conducted a site visit in early June1993 to evaluate the impact of heavy rainfall on thesite. Ms. Nelson indicated that there appear to be nonew seeps on Parcels IIA and IIB (the proposed projectsite). Ms. Nelson indicated that the site has becomevery densely vegetated since the summer of 1992. Shereported seeing cottonwood trees and tall grass, makingidentification of seeps and free phase liquid difficult. Ms. Nelson suspects that the recovery wells areresponsible for preventing the development of new seepson the main parcel. Ms. Nelson visually inspected runoff

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from the site that was flowing into storm sewers alongIndianapolis Boulevard. Ms. Nelson reported that therewas no visible free phase liquid in the runoff and therewas no evidence of staining on the concrete surroundingthe sewer grates.

U.S. Army Corps of Engineers, Chicago District personnelhave not inspected the site recently. Site inspectionsby U.S. Army Corps of Engineers personnel will beincluded in future work.

5. DATABASE INFORMATION

U.S. Army Corps of Engineers personnel reviewed the USEPAFacilities Index Database System (FINDS) to identifywhich sites in the City of East Chicago have beenincluded on the USEPA's Comprehensive EnvironmentalResponse Compensation and Liability Information System(CERCLIS) and the Resource Conservation and RecoveryInformation System (RCRIS) databases. This information,shown in Table I-1, is not of particular importance inthis case, since it is already known that the proposedsite is regulated under RCRA, but the database retrievaldoes show that the area in which this site is located isheavily industrialized and contains numerous sites listedon the CERCLIS database.

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5.1 AERIAL PHOTOGRAPHS & MAPS

An examination of aerial photographs taken in 1978 showsnumerous tanks and processing structures on the ECI site. The plant was obviously in operation as shown byfunctioning stacks. Some of the tanks on the site hadopen tops and appear to have been filled or partiallyfilled with liquid. Several undated aerial photos takenafter the site was leveled indicate that all of thesurface structures have been removed. Some features suchas roads and railways are still visible. It appears thatmuch of the area has been backfilled and graded. Outlines of concrete pads that once held storage tanksare still visible, especially in the northern end of thesite. There appear to be areas of sparse vegetationperhaps indicating areas where spills had occurred orwhere there are surficial quantities of constructiondebris. There appears to be an extensive pool of freephase liquid north of the railroad track which mayconsist of water or liquid contamination or somecombination of both.

One of the important features of East Chicago revealed bythe aerial photographs is the heavy industrialization ofthe area. All the land adjacent to the Lake GeorgeBranch of the Indiana Harbor Canal and the Indiana HarborCanal is industrial, and appears to be centered aroundrefining and coal processing. There is a residentialarea northwest of the ECI site, but there is a band ofindustrial property between the ECI site and theresidences. There are no open nearby sites suitable forconstruction of an upland CDF. Open areas near the siteare either inundated with water or directly adjacent toresidential areas.

6. SITE CHARACTERIZATION DATA

Geraghty & Miller, Inc. collected data from 49 wells,borings and piezometers on the ECI site between November20, 1991 and March 20, 1992 on presence and thickness offree phase hydrocarbon product in the wells. Plate I-1shows the locations of wells, borings and piezometers andthe minimum and maximum product thickness where productwas encountered. Table I-2 shows the thickness of thefree phase product during the period from 22 to 24 March1993. It should be noted that Table I-2 includes wellsnot located in Parcels IIA and IIB and not shown inFigure I-1. Table I-3 shows the American Petroleum

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Institute (API) gravity and specific gravity for theproduct encountered. Table I-4 shows the API gravity,viscosity and PCB concentration for samples of product. Additional site characterization data was collected byERM and summarized in a report entitled Phase III:Subsurface Characterization of the ECI site. The resultsof this report have been discussed with numerous membersof the USEPA, the IDEM, the City of East Chicago andGeraghty & Miller. At the time this appendix wasprepared, however, the Phase III report was not availablefor review. In addition, some information from theEcology & Environment Scoring of the ECI site wasdiscussed, but this report was also not available forreview. These documents and all forthcomingcharacterizations will be reviewed and discussed ingreater detail in the future.

7. PHONE COORDINATION

U.S. Army Corps of Engineers personnel coordinated withMr. Dave Petrovski of the USEPA, Ms. Carla Gill of theIDEM, Ms. Kay Nelson of the City of East Chicago, and Ms.Kathy Duchac of Geraghty & Miller, Inc.

8. HTRW ENVIRONMENTAL ISSUES

The presence of HTRW at the ECI site is well known. ARCO, Inc. and the City of East Chicago have documentedthe presence of petroleum related HTRW, and will performa limited quantification of the volume and range ofwastes present. Although construction of the CDF at theECI site may introduce some added liability that wouldnot be involved in construction at a clean site, it seemslikely that this liability will be offset by significantcost savings in engineering and constructing the CDF, andcomplying with regulatory requirements.

The presence of the HTRW should not significantly impactthe design, construction, or operation of the CDF,although it is likely that workers will be required towear personal protective equipment during construction. Personal protective equipment will also be requiredduring dredging the harbor and filling the CDF andpossibly for monitoring activity, but this is a result ofthe nature of the sediment and not the location of theCDF.

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Northwest Indiana is a heavily industrialized area. Building a CDF for Indiana Harbor sediments, some ofwhich are regulated under the Toxic Substances ControlAct (TSCA) due to PCB concentrations, in a clean area isless desirable than constructing the CDF at the ECI sitefor two reasons:

a. The USEPA and the IDEM have already indicatedthat if the CDF is built at a noncontaminated or "green"site, stringent liner and collection systems will berequired at substantial additional cost. In addition,the USEPA and the IDEM have already demonstrated thatthey favor the plan to construct the CDF at the ECI site. b. Building a CDF at a clean site would placecontaminated material on one of northwest Indiana's fewremaining green areas, and based on the demographiclayout of the area, possibly bring contaminated materialcloser to a residential area. In contrast, building theCDF at the ECI site keeps the Indiana Harbor sediment inan industrial area and will not consume one of the fewremaining green sites.

The ECI site is located in a prime location forconstruction of a CDF, based on proximity to the dredginglocation and ease of transporting the dredged sediment. The liability associated with loss of TSCA contaminatedsediment during transport to the ECI site issignificantly less than the liability associated withtransporting the sediment over land to a more distantsite.

In addition, since the CDF would be constructed inconformance with RCRA closure and corrective action, itseems likely that additional analysis required for designof the CDF could be accomplished by cooperative effortswith other parties involved. Geraghty & Miller haveindicated their desire to tailor future ECI sampling andanalysis to U.S. Army Corps of Engineers requirements.

Since the ECI site will be contained using a slurry walland a maintained inward gradient, the risk of migrationof sediment related contaminants is very low.

In addition to disposal of dredged material from theFederal navigation channel, materials excavated from theInland Steel Company and LTV Steel Company berthing areasis also expected to be placed in the CDF. Dredged

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materials generated from the Inland Steel Consent Decreesediment remediation activities would be disposed of inthe CDF as well. Any potential problems that might arisecould be dealt with cost effectively, and the cost wouldbe spread out among the all the parties involved.

9. CONCLUSIONS

There is significant petroleum based HTRW contaminationat the ECI site. However, the HTRW should have nosignificant adverse impact on the design, construction oroperation of the CDF. In fact, the condition of the ECIsite will allow for construction of a CDF without costlyliner and collection systems. Cooperative effortsbetween the parties involved will allow much of thenecessary analysis to be conducted and paid for by non-Federal interests.