perfcjrmance of rimedial response200-fs1-rt-eydu public comment draft feasibility study for the...

207
PERFCJRMANCE OF RIMEDIAL RESPONSE ACnVTITES AT UNCONTROLLED HAZARDOUS WASTE SITES (REMII) PUBLIC COMMENT DRAFT FEASIBILITY STUDY FOR MARION/BRAGG LANDFILL SITE MARION, INDIANA July 1987 Prepared for: U.S. Environmental Protection Agency Emergency and Rerredial "Response Branch Region V 230 South Dearborn Street Chicago, Illinois 60604 Document No. 200-FSl-PT-EYDU W.O. No. 103-5IB9

Upload: others

Post on 07-Jul-2020

3 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

PERFCJRMANCE OF RIMEDIAL RESPONSEACnVTITES AT UNCONTROLLED HAZARDOUS

WASTE SITES (REM II)

PUBLIC COMMENTDRAFT FEASIBILITY STUDY

FOR

MARION/BRAGG LANDFILL SITEMARION, INDIANA

July 1987

Prepared for:

U.S. Environmental Protection AgencyEmergency and Rerredial "Response Branch

Region V230 South Dearborn StreetChicago, Illinois 60604

Document No. 200-FSl-PT-EYDUW.O. No. 103-5IB9

Page 2: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

PERFORMANCE OF REMEDIAL RESPONSEACTIVITIES AT UNOONTROLLED HAZARDOUS

WASTE SITES (REM II)

U.S. EPA CONTRACT NO. 68-01-6939

PUBLIC COMMENTCRAFT FEASIBILnY STUDY

FOR MARION/BRAGG LANDFILL SITEMARION, INDIANA

EPA Work Assignment No. 103-5LB9

REM n Document No. 200-FS1-RT-EYDU

Prepared By: frv>>>> . tw- Date: &n / &7M. Burton, P.E."

Site Manager

Approved By: A.^V*/&-*»~»*"^ '"*- Date:JunlYoshitani, P.E.

I Region V Manager

\

Page 3: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

CAMP DRESSER

.pton/ws. 4 manaffemanl consutams Ch.e.90,

312 786-1313

August 4, 1987

Mr. Gregg KulmaActing Remedial Project OfficerU.S. Environmental Protection Agency230 South Dearborn StreetChicago, Illinois 60604

Ms. Cindy NolanRemedial Project ManagerU.S. Environmental Protection Agency230 South Dearborn StreetChicago, Illinois 60604

Project: REM II - EPA Contract No. 68-01-6939Work Assignment No.: 103-5LB9

Document No.: 200-FS1-RT-EYDUSubject: Public Comment Draft Feasibility Study for the Marion/

Bragg Landfill Site

Dear Mr. Kulma and Ms. Nolan:

Carp Dresser & McKee Inc. is pleased to submit four copies arxi oneoriginal of the Public Comment Draft Feasibility Study for theKarion/Bragg landfill site located in Marion, Indiana.

At Ms. Nolan's request, WESTON has also sent one courtesy cop-/ cf theFS directly to her; and two courtesy copies of the FS directly to Kr.Gnosh of the Indiana Department of Environmental Management. Also, atMs. Nolan's request, WESTON has sent two copies of the FS to theMarion Library which has been designated as the RI/FS repository.

Page 4: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

CAMP DRESSER & McKEE INC.

U.S. Environmental Protection AgencyKarion/Bragg Landfill Site Feasibility StudyAugust 4, 1987Page 2

If you should have any questions, please do not hesitate to contact usdirectly or the REM II Site Manager, James M. Burton, P.E.

Very truly yours,

CAMP DRESSER & McKEE INC. Approved:

ff. 'i, P.E.

Regional ManagerrJames K. Burton, P.E.Site Manager

Attachment ~

cc: John C. Comstock, Acting Contracting Officer, U.S. EPARobert D. Quinn, Project Officer, U.S. EPAJ. Kingscott, Regional Coordinator, U.S. EPA

Page 5: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

DESIGNERS

100 CORPORATE NORTH. SUITE 101ROUTE 22 AND LAKESIDE DRIVEBANNOCKBURN ILLINOIS 60015(312)295-6020

4 August 1987

Mr. Jun Yoshitani, P.E.REM II Region V ManagerCamp Dresser & McKee Inc.200 West Adams StreetSuite 1600Chicago, Illinois 60606

Project:

Document No,Subject:

REM II - EPA Contract No. 68-01-6939Work Assignment No. 103-5LB9200-FS1-RT-EYDUPublic Comment Draft Feasibility Study forthe Marion/Bragg Landfill Site

Dear Mr. Yoshitani:

Enclosed are seven copies and one original of the PublicComment Draft Feasibility Study for the Marion/BraggLandfill site. Please sign the original sign-off page, theoriginal Regional Record of Technical Review form and allcopies. Also, ask John Schroeter to sign the originalRegional Record of Technical Review form and all copies.Then, forward four copies and one original of the FS toCindy Nolan. One copy is for your files and the remainingtwo copies are for FPC document control.

If you have any questions, do not hesitate to call.

Very truly yours,

ROY F. WESTON, INC.

JMB:amp

Enclosure

James M. Burton, P.E,Site Manager

Page 6: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

100 CORPORATE NORTH, SUITE 101ROUTE 22 AND LAKESIDE DRIVEBANNOCKBURN. ILLINOIS 60015(312)295-6020

DEi ;>MH;

4 August 1987

Ms. Cindy NolanRemedial Project ManagerU.S. Environmental Protection Agency230 South Dearborn StreetChicago, Illinois 60604

Subject:

EPA Contract No.:Work Assignment No. :Document No.:

Dear Cindy:

Public Comment Draft Feasibility Studyfor the Marion/Bragg Landfill Site68-01-6939103-5LB9200-FS1-RT-EYDU

Enclosed is one courtesy copy of the Public Comment DraftFeasibility Study for the Marion/Bragg Landfill site.Official sign-off copies will be forwarded to you by -COM.If you have any questions, please do not hesitate to call.

Very truly yours,

?.:V F. WISTON, INC.

James M. Burton, P.ESite Manager

JMB: amp

Enclosure

Page 7: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

100 CORPORATE NORTH. SLUTE 101ROUTE 22 AND LAKESIDE DRIVEBANNOCKBURN. ILLINOIS 60015(312)295-6020

4 August 1987

Mr. Swapan GhoshIndiana Department of Environmental Management5500 West Bradbury AvenueIndianapolis, Indiana 46241

Subject:

EPA Contract No. :Work Assignment No.:Document No.:

Dear Swapan:

Public Comment Draft Feasibility Studyfor the Marion/Bragg Landfill Site68-01-6939103-5LB9200-FS1-RT-EYDU

Per Cindy Nolan's instructions, I have enclosed two copiesof the Public Comment Draft Feasibility Study for theMarion/Bragg Landfill site. If you have any questions,please do not hesitate to call.

Very truly yours,

ROY F. WESTON, INC.

JKB: amp

Enclosure

Jaroes K. Burton, P.ESite Manager

Page 8: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

100 CORPORATE NORTH. SUITE 101ROUTE 22 AND LAKESIDE DRIVEBANNOCKBURN, ILLINOIS 60015

"(312)295-6020

4 August 1987

Ms. Karen BlinnMarion Public LibraryMarion, Indiana 46953

Project:

Document No.:Subject:

REM II - EPA Contract No. 68-01-6939Work Assignment No.: 103-5LB9200-RI1-RT-EYDS/200-FS1-RT-EYDUPublic Comment Draft Remedial Investigationand Feasibility Study for the Marion/BraggLandfill Site

Dear Ms. Blinn:

Enclosed are two copies each of the remedial investigationand feasibility study for the Marion/Bragg Landfill site.I've sent these to you at the direction of Ms. Cindy Nolanof the U.S. Environmental Protection Agency (312/886-0400).If you have any questions concerning making these documentsavailable to the public during the five week public commentperiod, please contact Ms. Nolan. Thank you for your timeand effort concerning this matter.

Very truly yours,

ROY F. WESTON, INC.

JMB:amp

Enclosure

James M. Burton, P.E.

Page 9: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

EXECUTIVE SUMMARY

The Marion/Bragg Landfill site is located in the City of Marion, GrantCounty, Indiana. It was determined by the U.S. EnvironmentalProtection Agency (U.S. EPA) and the Indiana Department ofEnvironmental Management (IDEM) that the site potentially containedhazardous wastes resulting from improper past disposal practices.Because of the possibility of human and environmental expos\:re topotentially contaminated surface water and surface soils, as well asthe potential for migration of the hazardous materials from the siteto surface water, the site was included by U.S. EPA on the NationalPriorities List of uncontrolled hazardous waste sites under theComprehensive Environmental Response, Compensation, and Liability Actof 1980 (CERCIA).

This Feasibility Study (FS) report is to summarize the process used todevelop recommendations for a remedial action alternative for theMarion/Bragg Landfill site. In accordance with the NCP, theappropriate extent of remedy is defined as a "cost-effective remedialalternative that effectively mitigates and minimizes threats to andprovides adequate protection of public health and welfare and theenvironment" (40 CFR 300.68[i]).

This FS is based on the information and data presented in the RemedialInvestigation report.

The methodology used in this FS report allows a step-by-stepevaluation of technologies, alternatives, and assembled alternativesby progressing through a series of screenings. Initially, generalqualitative information is used. Subsequently, more refined andquantitative information is used to eliminate from considerationinfeasible or otherwise unacceptable actions. This methodologyprovides a systematic procedure for identifying and evaluatingalternatives, specifying criteria for determining the magnitude andimportance of effects resulting from the implementation of an action,and considering measures to mitigate adverse effects.

Site Description

The Marion/Bragg Tarrif-m site is located just outside thesoutheastern city limits of Marion, Indiana. The site occupiesapproximately 72 acres along the west bank of the Mississinewa River.The northern end of the site is within the estimated 100 year floodplain.

The site is bordered on the north and east by the Mississinewa River.A cemetery is located along the western border and the Eastside Coverecreational area is located along the southern border of the site. Aprivate residence and two businesses are located on the southwestcomer of the site. The two businesses are Marion Paving Company andDobson Construction Company. A large (15 acre) pond formed from sandand gravel quarry operations is located in the center of the site.The on-site pond is occasionally used for recreational purposes suchas boating and fishing." The on-site pond receives discharges from the

ES-1

Page 10: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Marion Paving Company asphalt plant associated with gravel washingoperations. A large pond of similar size is located off site on theEastside Cove recreational area, immediately adjacent to the southernsite boundary. This large pond on the Eastside Cove recreational areais used for fishing.

Approximately 45 acres of the 72 acre site were used for landfillingof municipal and industrial wastes. The landfill area of the site isrelatively flat and extends to within 10 to 15 feet of the river alongthe river perimeter of the site. The entire site is heavily vegetatedwith knee-high brush. The northern portion of the site has anestablished growth of four to six inch diameter trees. The perimeterof the large on-site pond is surrounded by trees and vegetation.Debris left from landfilling operations is evident on the surface ofthe site. Debris is more prevalent on the southern half of the site.The debris typically consists of crushed drum carcasses, plastics,miscellaneous metal, etc. The only area that appears to have beenused for waste disposal after closing of the site is the southeastcomer of the site where foundry sands and molten glass are piled.

When the landfill ceased operations, the southern and eastern portionsof the site were covered with a six inch to two foot layer ofpermeable sandy and gravel material taken from the propertyimmediately south of the site. The northern portion of the site wascovered with existing spoil materials from the excavation of landfilltrenches.

There are two aquifers present beneath the site. The first is theupper aquifer located in the outwash sand and gravel deposit.Groundwater in this aquifer enters the site along the southernboundary, flows north and eventually discharges into the MississinewaRiver. The large on-site pond is the exposed surface of the upperaquifer water table. The Mississinewa River acts as a hydraulicbarrier that intercepts the upper aquifer groundwater and prevents itfrom flowing north of the river. Groundwater in the upper aquifer onthe north side of the Mississinewa River flows in the oppositedirection, from north to south, into the Mississinewa River. Thesecond aquifer is the lower aquifer in the limestone bedrock. The twoaquifers are separated by a 54 to 63 feet thick highly impermeableglacial till layer across the site. Both aquifers are used as watersupply sources. The City of Marion is served by a public water supplysystem which is supplied water by municipal wells. These municipalwells use the upper aquifer as their water supply source.

Public Health Evaluation

A public health evaluation was conducted to evaluate contaminants ofconcern, potential pathways of human exposure to contaminants andpublic health risks. Table 2-1 summarizes the potential exposurepathways that were investigated. Table 2-2 summarizes the results ofthe public health evaluation.

The results of the public health evaluation indicate that publichealth risks due to site contaminants are present.

ES-2

Page 11: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Public health risks exist based on the plausible maximm exposurescenario associated with direct contact with soils in the area of theleachate seep (due to arsenic) at the southern boundary of the siteand with on-site surface soils (due to PAHs) at two locations.

No risks are associated with swimming in or the consumption of fishfrom the large en-site pond. No risks are associated with theconsumption of fish from the off-site pond.

The direct consumption of groundwater from the upper aquifer at thesite presents a risk (due to arsenic) based on the average andplausible maximum use scenario.

Development and Screening of Remedial Technologies and PotentialAlternatives

Applicable general response actions and technologies addressingproblems at the Marion/Bragg landfill site were identified. Remedialtechnologies were screened according to applicability to siteconditions and the contaminants of concern at the site and the abilityof the technology to adequately protect human health and theenvironment. The technologies were assessed on the basis of technicalfeasibility, including an assessment of performance, reliability,implementability, and safety with respect to site-specific physicaland waste characteristics. Both source control and off-site(management of migration) technologies were considered.

Asseinbled alternatives were subjected to an initial screening todetermine technical feasibility. Eased on initial screening, it wasdetermined that the following options are not applicable for furtherconsideration for the Marion/Bragg Landfill site:

o Off-site disposal of landfill contents in RCRA land disposalfacility;

o Off-site incineration of landfill contents in RCRAincineration facilities;

o On-site incineration of landfill contents;

o Off-site treatment of groundwater in RCRA facilities.

It was also determined that for alternatives involving groundwatertreatment, construction of a slurry wall around the site is necessaryto minimize the amount of groundwater to be extracted for treatmenteither in on-site facilities or at the Marion POTW.

Description of Assembled Alternatives

Based on screening and detailed analysis of remedial alternatives forthe Marion/Bragg Landfill site, several assembled remedialalternatives, including the No Action alternative, were developed.

ES-3

Page 12: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

The following assembled remedial alternatives represent a range ofremediation applicable to the Marion/Bragg Landfill site.

Alternative 1

Alternative 1 includes access and deed restrictions, installation ofIndiana sanitary landfill cap, flood protection and monitoring ofon-site pond, groundwater and Mississinewa River. This alternativeincludes the following four subalternatives:

o Cap installed over the existing landfill with the on-sitepond remaining open;

o Cap installed over the existing landfill with the on-sitepond backfilled;

o Cap installed after regrading the existing landfill with theon-site pond remaining open;

o Cap installed after regrading the existing landfill with theon-site pond backfilled;

Under this alternative, future remedial actions would likely benecessary if monitoring indicates that action levels rre exceeded toprevent migration of groundwater to the Mississinewa River.

Alternative 2

This alternative contains all the components of Alternative 1 with theexception that the landfill will be provided with a multilayer (RCRA)cap. Installation of multilayer cap would conform to the RCRArequirements for hazardous landfill closure, and would alsosignificantly minimize infiltration through the cap. Under thisalternative, future remedial actions to prevent migration ofgroundwater to the Mississinewa River would likely be necessary ifmonitoring indicates that action levels are exceeded.

Alternative 3A

Alternative 3A includes access and deed restrictions, floodprotection, installation of Indiana sanitary landfill cap, slurry walland on-site treatment of extracted groundwater in an activated carbonadsorption treatment system followed by air stripping for ammoniaremoval. Alternative 3A also includes four subalternatives forinstallation of cap as indicated for Alternative 1. This alternativeprevents migration of groundwater to the Mississinewa River andextracted groundwater will be discharged to the Mississinewa Riverutilizing a NPDES permit. This alternative provides significantprotection to the environment and public health since all potentialexposure pathways are controlled.

ES-4

Page 13: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Alternative 3B

Alternative 3B contains all the features of Alternative 3A with theexception that the extracted groundwater will be discharged to theMarion POTW for treatanent.

Alternative 4A

Alternative 4A includes access and deed restrictions, floodprotection, installation of multilayer (RCRA) cap, slurry wall andon-site treatment of extracted groundwater in an activated carbonadsorption system followed by air stripping for ammonia removal.Alternative 4A also includes four subalternatives for installation ofcap as indicated for Alternative 1. This alternative preventsmigration of groundwater to the Mississinewa River and extractedgroundwater will be discharged to the,Mississinewa River utilizing aNPDES permit. This alternative provides all the protection as inAlternative 3A and will also conform to RCRA requirements for closureof hazardous landfill.

Alternative 4B

Alternative 4B contains all the features of Alternative 4A with theexception that the extracted groundwater will be discharged to theMarion FOIW for treatment.

Alternative 5

This is a No Action alternative and is required by NCP to beconsidered. It provides a baseline for comparison of otheralternatives.

Analysis of Assembled Alternatives

Each assembled alternative is evaluated using technical andenvironmental criteria and cost estimates. For the technicalanalysis, each alternative is evaluated on performance, reliability,effectiveness, and implementability. For the environmental analysis,each alternative is evaluated for compliance with federal and stateenvironmental laws and regulations, protection of human health andenvironment, and effects of institutional parameters. The detailedcost analysis for each alternative includes estimates of operation andmaintenance (O&M) costs, capital costs, replacement costs, anddevelopment of present worth. The present worth includes the initialconstruction costs and the present worth of O&M costs and replacementcosts. Since the technical approach and technologies used indevelopment and comparison of assembled alternatives involve someassumptions, the assumed technology or design features may differ fromthose found in the final design.

Information on technical evaluation and summary of detailed analysisof assembled alternatives, including cost estimates, are presented inSection 6 (Tables 6-3 and 6-12) of the FS report.

ES-5

Page 14: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

A summary of the detailed evaluation of each alternative is asfollows:

Alternative 1 - Indiana Sanitary Landfill Cap and Monitoring

Access and deed restrictions and sanitary landfill capping wouldeliminate the potential for exposure due to direct contact withcontaminated soil and leachate seeps. If the on-site pond is notbackfilled, the access restriction will reduce the potential forexposure to the on-site pond; however, the potential public healthrisk associated with the on-site pond still remains. Deedrestrictions would eliminate the potential use of groundwater from thesite and thereby eliminate the associated public health risks. Sincegroundwater is not treated, the potential for public health andenvironmental risks remain if action levels are exceeded in theon-site pond and the Mississinewa River. Short-term constructionimpact, such as noise and dust, would result from installation of acap over the landfill. These impacts would be greater if the site isregraded prior to cap installation.

Difficulties may be encountered in implementing and enforcinginstitutional and access controls. For example, the effectiveness ofdeed restrictions for long-term actions has not been established.Failure of deed restrictions could result in exposure to contaminantsat some future time.

Ihis alternative does not constitute a RCRA-type closure. Because ofthe potential for future releases, this alternative may not meet thegoals of the U.S. EPA Groundwater Protection Strategy or fulfill allof the goals of CERCIA to provide protection of the public health orthe environment.

Alternative 2 - Multilayer (RCRR.) Cap and Monitoring

Discussion presented for Alternative 1 is applicable to thisalternative. Ihis alternative constitutes a RCRA-type closure for ahazardous landfill; however, not all of the RCRA closure requirementswill be met since no treatment is provided for the groundwater. As inAlternative 1, the difficulties in implementing access and deedrestriction remain a concern. If these restrictions are noteffective, the potential for the installation of on-site wells and useof contaminated groundwater exists.

The short-term construction impacts would be greater compared toAlternative 1 because installation of the multilayer cap is moreextensive construction activity than the sanitary landfill cap.

Alternatives 3A and 3B - Indiana Sanitary Landfill Cap, Slurry Wall.Groundwater Fjxtraction and Treatment (On-Site or Marion POIVD

Alternatives 3A and 3B mitigate public health and environmentalimpacts of the Marion/Bragg landfill site. Installation of a cap overthe site is effective in preventing direct contact with contaminated

... ....... . . . Es-6 - -- - ....._

Page 15: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

soils and leachate seeps. Use of a slurry wall minimizes the releaseof contaminants from groundwater to the Mississinewa River andmitigates the groundwater exposure pathway. If the pond is notbackfilled and access restrictions are not effective, the risksassociated with the on-site pond would remain.

Short-term construction impacts, such as noise and dust, could resultfrom installation of cap, groundwater extraction wells and slurrywan.

Institutional concerns regarding permitting for groundwater dischargeto either the Mississinewa River or the Marion POIW are essentiallythe same.

This alternative does not constitute a RCRA-type closure for hazardouswaste landfill. However, the other requirements of RCRA are achieveddue to prevention of migration of groundwater to the MississinewaRiver and providing treatment of the groundwater.

Institutionally, Alternatives 3A and 3B would have the same concernsregarding implementation and effectiveness of access and deedrestrictions as discussed for Alternative 1.

Alternative 4A and 4B Multilayer (RCRA) Cap, Slurry Wall, GroundwaterExtraction and Treatment (On-5ite or Marion POIW)

Alternatives 4A and 4B differ from Alternatives 3A and 3B only withrespect to the installation of a RCRA cap instead of a sanitarylandfill cap. The discussion presented for Alternative 3A and 3Bapply to this alternative with the following exceptions:

o Short-term construction impacts would be greater becauseinstallation of the multilayer cap is more extensiveconstruction activity than the sanitary landfill cap.

o This alternative would meet all the intents of RCRA closurebecause of the use of a multilayer cap.

Alternative 5 — No Action

Existing and potential future endangerment to public health, welfare,and the environment would not be mitigated. Access to the site wouldnot be restricted and direct contact with contaminants in the soil,cm-site pond and leachate seep is possible. Contaminants have thepotential to be released from the fill into the groundwater. Apotentially complete groundwater exposure pathway will exist underthis alternative. There is a concern for potential adverse publichealth and environmental impacts if future releases of contaminantsshould occur.

Institutional impacts of No Action would primarily involvenoncompliance with appropriate environmental laws and regulations and,therefore, would not fulfill the objectives of CERdA.

Page 16: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Selection of Interim Remedy

The U.S. EPA in conjunction with the Indiana Department ofEnvironmental Management (IDEM) selected Alternative 1C as the interimremedy for the site. The interim remedy includes the followingcomponents:

o Access and deed restrictions

o Flood control measures

o Installation of Indiana Sanitary Landfill cap

o Monitoring of on-site pond, groundwater and the MississinewaRiver

Action levels will be set for on-site pond and groundwater. If theselevels are exceeded based on the monitoring program, then backfillingof the pond and/or groundwater extraction and treatment would beconsidered for implementation by the regulatory agencies.

The cost to implement this interim remedy is as follows:

capital Cost $5,79l,oooPresent Worth of Operationand Maintenance $1,081,000

Total Present Worth $6,782,000

ES-8

Page 17: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE OF CONTENTS

Executive Summary

Section

1 INTRODUCTION 1-1

1.1 Purpose 1-11.2 Site Description 1-21.3 Site History 1-61.4 Summary of Remedial Investigation 1-6

1.4.1 Site Hydrogeology 1-61.4.2 Extent of Contamination 1-10

2 PUBLIC HEALTH EVALUATION AND AN E !VIRO l E 1TAL IMPACT 2-1ASSESSMENT SUMMARY

2.1 Introduction 2-12.2 Exposure Pathways 2-12.3 Public Health Risks 2-32.4 Environmental Impact Assessment 2-5

3 IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIES 3-1

3.1 Remedial Action Goals 3-1

3.1.1 Soil and Landfill Contents 3-23.1.2 Groundwater 3-23.1.3 Leachate Seep 3-23.1.4 Surface Water (On-Site Pond) 3-2

3.2 General Remedial Response Actions 3-23.3 Preliminary Screening of Rpmedial Action

Technologies 3-43.4 Discussion of Applicable Remedial Technologies 3-4

3.4.1 Landfill 3-4

3.4.1.1 Access and Deed Restrictions 3-43..4.1.2 Landfill Containment 3-323.4.1.3 Landfill Treatment 3-343.4.1.4 Landfill Removal and Off-Site

Disposal 3-34

3.4.2 Groundwater 3-35

3.4.2.1 Access and Deed Restrictions 3-353.4.2.2 Groundwater Containment 3-353.4.2.3 Groundwater Collection 3-353.4.2.4 On-Site Groundwater Treatment 3-363.4.2.5 Off-Site Groundwater Treatment 3-38

Page 18: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE OF CONTENTS (Continued)

3.4.3 Leachate Seep 3-38

3.4.3.1 Leachate Seep Containment 3-383.4.3.2 Leachate Collection and Treatment 3-39

3.4.4 Surface Water (On-Site Pond) 3-39

3.4.4.1 Pond Containment 3-39

ASSEMBLY OF ALTERNATIVES 4-1

4.1 Introduction 4-14.2 Assembled Alternatives 4-14.3 Description of Alternatives 4-5

4.3.1 Alternative 1A 4-54.3.2 Alternative IB 4-74.3.3 Alternative 1C 4-84.3.4 Alternative 2A 4-94.3.5 Alternative 2B 4-104.3.6 Alternative 2C 4-114.3.7 Alternative 3A 4-114.3.8 Alternative 3B 4-124.3.9 Alternative 3C '4-134.3.10 Alternative 4A 4-134.3.11 Alternative 4B 4-144.3.12 Alternative 4C 4-154.3.13 Alternative 5A 4-154.3.14 Alternative 5B 4-164.3.15 Alternative 5C 4-164.3.16 Alternative 6A 4-174.3.17 Alternative 6B 4-184.3.18 Alternative 6C 4-194.3.19 Alternative 7A 4-194.3.20 Alternative 7B 4-204.3.21 Alternative 7C 4-204.3.22 Alternative 8 4-214.3.23 Alternative 9 4-214.3.24 Alternative 10 4-22

SCREENING OF ALTERNATIVES 5-1

5.1 Introduction 5-15.2 Off-Site Disposal in RCRA Land Disposal Facility 5-2

5.2.1 Adams Center Facility, Ft. Wayne, Indiana 5-35.2.2 Emelle, Alabama Facility 5-45.2.3 Wayne Disposal, Detroit, Michigan 5-45.2.4 Summary of Evaluation of Disposal in

Off-Site RCRA Landfill 5-5

Page 19: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE OF CONTENTS (Continued)

Section

5.3 Disposal of Landfill Contents in Off-SiteIncineration Facility 5-6

5.4 On-Site Incineration 5-75.5 Groundwater Extraction 5-85.6 Groundwater Treatment in Off-Site Treatment

Facility 5-95.7 Summary of Initial Screening of Alternatives 5-10

6 DETAILED ANALYSIS OF ALTERNATIVES 6-1

6.1 Introduction 6-16.2 Discussion of Technical Components of Alternatives 6-3

6.2.1 Access and Deed Restrictions 6-46.2.2 Monitoring 6-46.2.3 Flood Control Measures 6-106.2.4 Landfill Cap 6-106.2.5 Slurry Wall 6-186.2.6 Groundwater Extraction 6-196.2.7 Groundwater Treatment 6-20

6.3 Technical Evaluation of Alternatives 6-21

6.3.1 Summary of Technical Evaluation 6-22

6.4 Cost Analysis 6-29

6.4.1 General Discussion 6-296.4.2 Assumptions 6-306.4.3 Cost Sensitivity Analysis 6-43

6.5 Iristitnjtior /Environmental/Public Health Analysis 6-456.6 Institutional/Environmental/Public Health 6-53

Evaluation of Alternatives6.7 Summary of Detailed Analysis of Alternatives 6-55

7 SELECTION OF INTERIM REMEDY 7-1

7.1 Discussion of Alternatives 7-17.2 Selection of Interim Remedy 7-27.3 Cost of Interim Remedy 7-5

Appendix A Groundwater Collection

Appendix B Estimation of Flood Elevation inMississinewa River

Page 20: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

LIST OF FIGURES

1-1 Feasibility Study Process 1-31-2 Site Location 1-41-3 Site Map 1-56-1 Access Restrictions, 100 Year Flood Protection Levee 6-56-2 Indiana Sanitary landfill Cap or Multilayer (RCRA)

Cap, Monitoring 6-76-3 Indiana Sanitary landfill Cap or Multilayer (RCRA)

Cap, Slurry Wall, Groundwater Extraction andOn-Site Groundwater Treatment 6-12

6-4 Indiana Sanitary landfill Cap or Multilayer (RCRA)Cap, Slurry Wall, Groundwater Extraction andDischarge to PCTW 6-13

6-5 Final Grade for Indiana Sanitary landfill Cap orMultilayer (RCRA) Cap Installed Over ExistingFill with On-Site Pond Left Open 6-14

6-6 Final Grade for Indiana Sanitary landfill Cap orMultilayer (RCRA) Cap Installed Over ExistingFill with On-Site Pond Backfilled 6-15

6-7 Final Grade for Indiana Sanitary landfill Cap orMultilayer (RCRA) Cap Installed Over Regraded Fillwith On-Site Pond Left Open 6-16

6-8 Final Grade for Indiana landfill Cap or Multilayer(RCRA) Cap Installed Over Regraded Fill with On-SitePond Backfilled 6-17

Page 21: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

LIST OF TABLES

Table

1-1 Special Waste Materials Known to be Accepted byMarion/Bragg Landfill 1-7

1-2 Summary of Waste Boring Sampling Results 1-11

1-3 Summary of Surface Soil Sampling Results 1-13

1-4 Summary of Leachate Well Sampling Results 1-14

1-5 Summary of Groundwater Sampling Results 1-15

1-6 Summary of Water Supply Sampling Results 1-17

1-7 Summary of Leachate Seep Sampling Results 1-18

1-8 Summary of Leachate Sediment Sampling Results 1-20

1-9 Summary of River Sediment Sampling Results 1-21

1-10 Summary of Pond Water Sampling Results 1-22

1-11 Summary of Pond Sediment Sampling Results 1-24

1-12 Summary of Asphalt Plant Effluent Sampling Results 1-26

1-13 Summary of Asphalt Plant Sediment Sampling Results 1-28

2-1 Potential Pathways of Human Exposure to Contaminants 2-2Originating at the Marion/Bragg Tarrf-Fin site

2-2 Summary of Potential Health Risks Associated with 2-4Exposure to Marion/Bragg Chemicals of Concern

3-1 General Response Actions 3-3

3-2 Remedial Technologies 3-5

3-3 Site Conditions and Waste Characteristics 3-11

3-4 Screening of Available Remedial Technologies 3-12

3-5 Applicable Remedial Technologies 3-28

4-1 Summary of Assembled Alternatives for Marion/Bragglandfill Site 4-2

6-1 Alternatives for Detailed Evaluation 6-2

Page 22: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

LIST OF TABLES (Continued)

Table Page

6-2 Summary of Groundwater Sampling Results andApplicable Standards for Mississinewa River andGroundwater Discharge 6-8

6-3 Technical Evaluation of Alternatives 6-23

6-4 Cost Summary for Alternative 1 (A, B, C and D) 6-316-32

6-5 Cost Summary for Alternative 2 (A, B, C and D) 6-336-34

6-6 Cost Summary for Alternative 3A (1, 2, 3 and 4) 6-35and Alternative 3B (1, 2, 3 and 4) to

6-38

6-7 Cost Summary for Alternative 4A (1, 2, 3 and 4) 6-39and Alternative 4B (1, 2, 3 and 4) to

6-42

6-8 Cost Sensitivity Analysis of Alternatives 6-44

6-9 Federal Agency Coordination 6-48

6-10 Compliance with Applicable or Relevant and AppropriateRequirements 6-49

6-11 Federal Environmental Laws and Regulations NotApplicable or Relevant and Appropriate to Alternatives 6-52

6-12 Summary of Detailed Analysis of Alternatives 6-56

Page 23: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill siteSection: 1July 31, 1987Page 1-1 of 28

SECTION 1

INTRDEXJCTION

The Marion/Bragg Landfill site is located in the City of Marion, GrantCounty, Indiana. It was determined by the U.S. EnvironmentalProtection Agency (U.S. EPA) and the Indiana Department ofEnvironmental management (IDEM) that the site potentially containedhazardous wastes resulting from improper past disposal practices.Because of the possibility of human and environmental exposure topotentially contaminated surface water and surface soils, as well asthe potential for migration of the hazardous materials from the siteto surface water, the site was included by U.S. EPA on the NationalPriorities Lost of uncontrolled hazardous waste sites under theComprehensive Environmental Response, Compensation, and Liability Actof 1980 (CERCLA).

CERCLA, through Executive Order 12316, gives U.S. EPA the authority torespond to actual or potential release of hazardous substances thatpose an imminent and substantial threat to human health, welfare, orthe environment. Pursuant to Section 105 of CERCLA, U.S. EPA•promulgated revisions to the National Oil and Hazardous SubstancesContingency Plan (NCP) on February 18, 1986, to effectuate theresponse powers and responsibilities created by CERCLA. Subpart F ofthe NCP, Hazardous Substance Response, establishes methods andcriteria for determining the appropriate extent of response authorizedby CERCLA and outlines a procedure for determining the nature andextent of contamination at a site and the appropriate extent of remedyfor the site.

Based upon the NCP, the U.S. EPA has developed a program of emergencyresponse, remedial response, and enforcement to implement CERCLA. Aspart of this program, U.S. EPA's Hazardous Site Control Division(HSCD), through Contract No. 68-01-6939, has retained Roy F. Weston toconduct remedial planning activities (Remedial Investigations andFeasibility Studies, RI/FS). The RI/FS at the Marion/Bragg Landfillsite began on May 6, 1985 with the issuance by U.S. EPA of WorkAssignment No. 103-5LB9 to Roy F. Weston.

1.1 PURPOSE

The purpose of this Feasibility Study (FS) report is to summarize theprocess used to develop recommendations for a remedial actionalternative for the Marion/Bragg Landfill site. In accordance withthe NCP, the appropriate extent of remedy is defined as a"cost-effective remedial alternative that effectively mitigates andminimizes threats to and provides adequate protection of public healthand welfare and the environment" [40 CFR 300.68(i)].

Page 24: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 1July 31, 1987Page 1-2 of 28

This FS is based on the information and data presented in the RIreport for the Marion/Bragg Landfill site.

The methodology vised in this FS report allows a step-by-stepevaluation of technologies, alternatives, and assembled alternativesby progressing through a series of screenings (see Figure 1-1).Initially, general qualitative information is used. Subsequently,more refined and quantitative information is used to eliminate fromconsideration infeasible or otherwise unacceptable actions. Thisinethodology provides a systematic procedure for identifying andevaluating alternatives, specifying criteria for determining theiragnitude and importance of effects resulting from the implementationof an action, and considering measures to mitigate adverse effects.

1.2 SITE DESCRIPTION

The Marion/Bragg Landfill site occupies approximately 72 acres ofproperty situated on the Mississinewa River flood plain in thenorthwest quarter of Section 16 and parts of Sections 8, 9, 17;Township 24 North, Range 8 East of Grant County. The site is locatedat the southeast edge of Marian, Indiana, as indicated on the locationand site maps shown in Figures 1-2 and 1-3, respectively. A largepond is located in the middle of the site. A residence and twobusinesses are located on the southwest corner of the site. (MarionPaving Co. and Dobson Construction Company.) The Mississinewa Riverborders the landfill to the north and the east. A cemetery is locatedalong the western site boundary. A commercial recreational areacalled Eastside Cove is located along the southern boundary of thesite.

Approximately 45 of the 72 acres at the Marion/Bragg Landfill sitehave been used for landfill purposes. The landfill area boundaryapproaches the banks of the Mississinewa River to the north and east,and the large off-site pond on the Eastside Cove property to thesouth. Based on conversations with the commercial businessesrepresentatives, portions of their facilities, where gravel has beenstockpiled, are suspected to be within the landfill area boundary. Inaddition, a small part of the landfill is located west of the on-sitepond and east of the cemetery.

The Marion/Bragg Landfill stopped accepting waste in 1975. Thelandfill cover is vegetated and does not appear to have any erosionproblems. The southern area of the landfill does have a slightdrainage problem where ponded water accumulates after heavy rains.The final cover applied over the landfill is silty and very permeable.There are numerous areas where debris, including 55-gallon drumcarcasses, protrudes fron the fill. Along the eastern boundary of thelandfill there are numerous uncovered industrial wastes, such asfoundry sand, solidified paint sludges, and several 55-gallon drums.

Page 25: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

INTRDCUCnON(Section 1)

1

HJBLIC HEALTH EVALUATION ANDENVIRDNMENIAL IMPACT ASSESSMENT SUI-MARY

(Section 2)

TREMEDIAL TECHNOLOGY DEVELOPMENT

(Section 3)

o Identify Goals and ObjectivesConsistent with NCP

o Identify General ResponseActions

o Identify and ScreenApplicable RemedialTechnoloaies

ASSEMBIZ REMEDIAL ALTERNATIVES FROMAPPLICABLE TECHNOLOGIES

(Section 4)

TSCREENING OF ASSEMBLED AITERNAITVES

(Section 5)

DETAILED ANALYSIS OF ALTERNATTVES(Section 6)

RECOMMENDED ALTERNATIVE(Section 7)

Figure 1-1FEASIBILITY STUDY PROCESSMarion/Bragg Landfill Site

1-3

Page 26: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

MARION

INDIANA

L_tdL_fc

A P P R O X SCALE IN MILES

FIGURE 1-2 SITE LOCATION

1-4

Page 27: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

01

n, '•;'LI ,•

nLegend ' '

"~"~ Sile Boundary'///// Marion Paving Co.. Inc. /:|:;:;:;ii:i: Dobson Construction Co.. Inc.

Private Residence

Scale in Feet

0 250 500

o' ?-. '••- * v\• H'&y ^:

- i t . . . »

v; o\

t

FIGURE 1-3 SITE MAP - MARION/BRAGG LANDFILL

Page 28: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill.SiteSection: 1July 31, 1987Page 1-6 of 28

A leachate seep was identified on site along the south-centralboundary.

Die on-site pond is occasionally used for recreational purposes, suchas fishing and boating. There is a picnic table and a row boatlocated on the west bank of the on-site pond. At the southwesternedge of the on-site pond is a 10-inch diameter effluent pipe whichconveys discharges associated with the gravel washing operations fromthe Marion Paving Co. asphalt plant. The asphalt plant effluent flowsoverland to the east and discharges into the on-site pond.

1.3 SITE HISTORY

The Marion/Bragg site was used as a sand and gravel quarry operationfron 1935 to 1961. During the period from 1957 to 1975, theMarion/Bragg Tan f-i 11 was operated for the disposal of municipalwastes and various other wastes reportedly including hazardous wastes.Records indicate that the site may have been used for waste disposalas early as 1949 at areas leased by Radio Corporation of America(RCA). Periodic inspections by the Indiana State Board of Health(ISBH) indicated that operations at the landfill were continuallyccT>f x <3|d in an unacceptable manner. An Indiana State Board of Healthmemorandum, dated August 20, 1973, indicated that the landfill wasreceiving 1,400 55-gallon drums per month from Central Waste,Incorporated, which hauled most of the waste from General TireCompany. The drums reportedly contained acetone, plasticizers,lacquer thinners, enamels and other miscellaneous wastes. U.S. EPArecords also indicate that Radio Corporation of America (RCA) usedseveral locations on the site for the dispnaai of wastes, includingcadmium and lead sludge. According to Mr. Bragg (landfill operator),the wastes from Central Waste, Inc. were highly flammable and heoccasionally used sludges from RCA to cover and work down theflammable sludge emptied from the Central Waste, Inc. drums. In June1975, the Marion/Bragg tarrf-F-i 11 stopped accepting all waste. WasteReduction Systems, a division of Decatur Salvage, Inc., constructed atransfer station on the pr-pinjfigg in order to transfer municipal wastesto an approved landfill. The transfer station remained in operationuntil it was ultimately closed in 1977. In 1980, ISBH determined thatthe transfer station was closed in an acceptable manner.

Table 1-1 lists the known waste materials accepted at the Marion/BraggTarrif ji.i. The site was added to the U.S. EPA National Priorities Listin December 1983.

The following sections summarize the results of the RI regarding thesite hydrogeology and the extent of contamination.

1.4.1 Site Hvdroqeology

Two aquifers have been identified at the Marion/Bragg Tanrif-i 11 site.

Page 29: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

C

Feasibility StudyMarion/Bragg landfill SiteSection 1July 31, 1987Page 1-7 of 28

TABLE 1-1

WASTE MATERIALS KNOWNTO BE ACCEPTED BY MARION/BRAGG LANDFILL

Period ofOperations

Unknown. Approx.1949-1970

Approx. 1972

1973-1975

Until the fallof 1975

Approx. 1975

1985

IndustrialWastes Accepted

Industrial wastesludges

Dry sewage sludge

5-10% solids

Acetone, Plastici-zers,

Quantity

Unknown

4,400,000 Ibs

thinners,Enamels

Sludge containingcadmium and lead,Miscellaneouswastes

Unknown liquidwaste

Black solventsludgeGrayish powder

Foundry sands, Whitefiberous materials,Solidified paintsludges, Several 55-gallon drums, onecontaining a smallamount of liquid

1400 drums/monthfor 2 years

Unknown

Unknown

30 barrels

InformationSource

ISBH Records

ISBH Records

ISBH Records

USEPA and ISBHRecords

ISBH Records

ISBH Records

REM n Team SiteVisit

Page 30: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 1July 31, 1987Page 1-8 of 28

The two aquifers are separated by a confining layer. The upperaquifer includes portions of landfill waste and the outwash deposits.This aquifer extends from the water table surface to the top of theglacial till. The confining layer is a dense, : permeable glacialtill and separates the upper unconfined aquifer from the lowerconfined aquifer. This confined aquifer occurs within the limestonebedrock. Both aquifers are used as a potable water source within thevicinity of the Maricn/Bragg Landfill site.

Upper Aquifer

The upper aquifer occurs within portions of the fill material and theoutwash deposits. This unconfined water table aquifer is 18 to 42feet thick and the water table is 1 to 35 feet below ground surface.The groundwater flow in the unconfined upper aquifer is toward thenorth and discharges into the Mississinewa River. There are severalgroundwater discharge and recharge zones. The large on-site andoff-site ponds are classified as seepage ponds and thus have bothdischarge and recharge zones. The large off-site pond is locatedimmediately south of the landfill and is approximately equal in sizeto the on-site pond. Euring normal river stage, both ponds dischargegroundwater from along their southern shores and recharge thegroundwater along their wesrem, eastern, and northern shores andalong the base of the pond. There is a seasonal groundwater dividethat separates groundwater flow to the on-site pond on the west sideof the divide and to the river on the east side of the divide. Thisgroundwater divide only occurs during times when the river is at highstage or a flood period. In this situation, the groundwater levelsare temporarily raised near the river due to flow into the river banksoil from the river. This water, which is stored in the river bankduring high stages, is referred to as bank storage. As the floodstage declines, the bank storage flows out towards the river and thegroundwater divide disappears.

The Mississinewa River receives groundwater discharges year round fromboth sides of the river and upward from the bottom; thus, it isconsidered an effluent, or gaining river. This has been determined byobserving static groundwater elevations from two two-well clustermonitoring wells located along the river (FIT-3/MW-12, MW-5/MW-4).The deeper wells (MW-4, MW-12) have a consistently higher hydraulichead elevation, indicating an upward gradient. This upward gradientindicates that there is a higher hydraulic pressure at depth and as aresult, groundwater flows upward into the river where it discharges.Therefore, the groundwater does not migrate under the river, butdischarges into the river. Also, the groundwater elevation data onthe north side of the river indicates a hydraulic gradient toward theriver. Based on these findings, the Mississinewa River is considereda hydraulic barrier for contaminants which might migrate northwardtoward residential wells across the river along Monroe Pike.

Page 31: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 1July 31, 1987Page 1-9 of 28

The water table of the upper aquifer experiences a one-foot verticaldrop in elevation for every 175 feet of horizontal distance (0.006ft/ft). The average transmissivity and hydraulic conductivity of thesand and gravel aquifer is 17.96 cm /sec and 4.27 x 10 cny/sec,respectively. An average velocity of groundwater for this aquifer is2.78 ft/day. These values indicate that the upper aquifer is verypermeable and transmissive. In general, the travel time forgroundwater to migrate from one end of the site to eventuallydischarge into the Mississinewa River is approximately 2.2 years.Using this value, it is estimated that the upper aquifer beneath thesite has been purged approximately 7 times since the landfill stoppedaccepting wastes.

Portions of the fill material are below the water table. Areas ofperennial saturated fill occur at the north, east, and west portionsof the landfill. Seasonal saturation of the fill occurs at thesoutheast corner of the site. This seasonal saturation occurs duringthe spring months of the year. It has been determined thatapproximately one foot of saturation occurs during these months.

At the north and east portions of the site, the fill is saturatedyear-round, but does experience some seasonal fluctuations. It hasbeen determined that 2 to 4.4 feet of fluctuation occurs at the northand east portions of the landfill, respectively. This fluctuation insaturation can be attributed to bank storage when the river is at highstage. At the western part of the site, approximately seven feet ofthe fill material are saturated year-round. This area is not affectedby bank storage to the sam degree as other parts of the landfill and,as a result, the depth of saturated fill does not fluctuate much. Ithas been estimated that approximately 4% of the total fill volume(40000 cy) is within the upper aquifer.

Confining Layer

The glacial till or confining layer is 30 to 64 feet thick and ischaracteristically very stiff and hard and has low permeabilities.This confining layer can be classified as an aquitard because it stillpossesses the ability to transmit water but at a .very slow rate. Inthis case, because of the greater hydraulic head experienced in thelimestone aquifer, the groundwater flow would be upward, toward thesand and gravel aquifer. The hydraulic conductivities of the glacialtill ranged from 1.01 x 10~ cm/sec to 2.88 x 10~ cm/sec. Theestimated velocity of water migrating through the glacial tillconfining layer is 1.15 x 10~ ft/day. From this value, it can beestimated that it would take 1,433 years for water to migrate upthrough the confining layer.

Lower Aquifer

The lower aquifer occurs within the limestone bedrock. The water islocated within the secondary pores of limestone because it is

Page 32: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 1July 31, 1987Page 1-10 of 28

moderately fractured. The potentiometric surface is approximately 15feet higher than the water table surface. Therefore, the limestoneaquifer has a greater hydraulic head. This situation creates avertical gradient upward toward the glacial till.

1.4.2 Extent of Contamination

A detailed discussion of the RI sampling program and the analyticalresults are presented in Sections 3 and 4 of the remedialinvestigation report.

Data collected during the RI indicate contamination of various mediaat the Marion/Bragg Landfill site. The following sections summarizethe results of RI sampling efforts.

Waste Borings

Waste borings were drilled through the landfill area to determine thetype and concentration of contaminants in the fill and in the naturalsoil beneath the fill. One waste boring was drilled through the areasuspected of being used for disposal of acetone, plasticizers, lacquerthinners, enamels and other miscellaneous wastes brought to the siteby Central Waste, Inc. This area is believed to generally occupy thesouth-central and southeast portions of the site. One boring wasdrilled through one of the areas reported to have been used fordisposal of RCA wastes. One boring was drilled through the northernend of the site for which no historical data was available.

Contaminants found in the waste boring samples are shown in Table 1-2.Waste boring samples from all three boring locations indicated thepresence of volatile and semi-volatile organic compounds atconcentrations above background levels. The concentrations ofcadmium, lead and zinc were highest at waste borings drilled throughthe area reported to have been used by RCA as disposal for cadmium andlead sludges. In all cases, the concentration of organics andinorganics in the natural soil beneath the fill were significantlyless than the concentrations found in the fill. It can be concludedthat organic and inorganic contaminants are present in the fill atconcentrations above background levels.

On-5ite Surface Soil

Surface soil samples were collected to determine if and to what extenthazards exist due to contaminants in the on-site surface soil.Investigation of on-site surface soil contamination involved thecollection of six composite samples of the top six inches of soil fromrepresentative locations across the site. Surface soil sampling

Page 33: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Table 1-2Summary of Waste Soring Sampling Results

Marion/Bragg Landfill RI/FS

INVESTIGATIVE SAMPLES(a) BACKGROUND SAMPLES(b)

CONSTITUENTS

VOLATILES, (ug/kg)

1,1-Dichloroethene1,1,1 • TrichloroethaneAcetoneBenzeneCarbon DisulfideEthylbenzene

ylene ChlorideSfyreneTetrachloroetheneTolueneTotal XylenesTrans-1 ,2-dichloroethaneTrichloroetl eneVinyl Chloride

NO. OF POSITIVEDETECTIONS/NO. OF VALIDOBSERVATIONS(c)

1/114/116/115/111/115/1110/111/113/115/113/114/119/113/11

RANGE OFDETECTION

1553 •5

1318

3654010582

12• 46824

- 115

- 340- 24017

- 91- 27- 100- 4745• 414- 341

NO. OF POSITIVEDETECTIONS/NO. OF VALIDOBSERVATIONS(C)

0/70/74/70/70/70/72/70/70/70/70/70/70/70/7

TYPICAL CONC.RANGE OFDETECTION

NDND

1 1 - 8 5NDNDND

7.5 • 9.5NDNDNDNDNDNDND

IN U.S. SOILSCEPA.1983)

NoneNoneNoneNoneNoneNoneNoneNoneNoneNoneNoneNoneNoneNone

EstablishedEstablishedEstablishedEstablishedEstablishedEstablishedEstabl ishedEstablishedEstablishedEstablishedEstablishedEstablishedEstablishedEstabl ished

EXCEEDSTYPICAL CCN:.IN U.S. SOILS

NANANANANA

NANANANANANANANANA

H-VOLATILES, (ug/kg)

bis(2-ethylhexyl)phthalate 11/11 537 - 9,040,000 1/7Di-n-butylphthalate 1/11 18S.OOO 1/7Di-n-octylphthalate 1/11 450,000 0/7

970 None Established NA447 None Established NAND None Established NA

PESTICIDES, (ug/kg)

rdane 3/4 300 - 640 0/7 None Established NA

INORGANICS,Cmg/kg)

AntimonyBariumCadmiumChromiumCopperLeadMercurySodiumTinZinc

3/1111/119/1111/1111/1111/118/1111/1110/1111/11

2810 -4.36.3136.9.1014101132

• 46402

- 403- 25

- 5850• 5870- .35- 3060• 73- 2910

0/77/71/77/77/77/70/76/73/77/7

11

711

5.5

6801929

ND•3••-

ND---

85

174218

19602287

2100.01122

0.01None

210

- 10• 3000• 0.7

- 1000- 100- 200• 0.3

Established• 200- 300

YNYNYYNNAN

r

a) Waste Boring Samples • W601, WB02, and WB03b) Background Samples • SS05, SS06, SS09, SS10, SB01, SB02, and SB03c) Number of samples in which chemical was detected over total number of samples analyzed.

• Not DetectedNM - Not Applicable

1-11

Page 34: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 1July 31, 1987Page 1-12 of 28

results are presented in Table 1-3. The surface soil was found to beessentially free of volatile organic compounds.

Semi-volatile organic compounds (polycyclic aromatic hydrocarbons,PAHs) were found at two locations at significant concentrations abovebackground concentration. One location (SS07) is on the fill area,the second location (SS04) is on site but is off the fill area. Thesource of PAHs found at location SS07 is unknown. Possible source ofPAHs found at location SS04 is runoff from a "cold mix" asphalt roadpatch storage pile located on the Marion Paving area. The presence ofsemi-volatile organic compounds does not appear to be widespread.

One pesticide compound (4,4'-DOT) was found at one of the six £~3nplelocations. The presence of pesticides does not appear to bewidespread.

Three inorganics (cadmium, lead, mercury) were found in the on-sitesurface soil at concentrations above background levels. Of thesethree inorganics, only cadmium exceeded typical concentrations in U.S.soils.

Groundwater

Groundwater was investigated by sampling 4 off-site backgroundmonitoring wells, 13 on-site monitoring wells, 2 on-site leachatewells, and 18 off-site water supply wells.

Leachate wells were installed where waste boring samples werecollected. The results of leachate well sampling are shown in Table1-4. Fewer volatile organic compounds were found in leachate wellsamples than in waste boring samples; however, those that were foundin leachate well samples were also found in waste boring samples.Minimal semi-volatile organic compounds were found. No pesti-cides/PCSs were found in leachate well samples. A large number ofinorganics were found in leachate well samples at concentrations abovebackground levels.

The results of groundwater samples are shown in Table 1-5. Thegroundwater in the upper aquifer contains organic and inorganiccontaminants at concentrations above background levels; however, thenumber and concentrations of contaminants are relatively low. Ninevolatile and four semi-volatile organic compounds were found atconcentrations above background levels. The volatile organiccompounds had detection frequencies ranging from 1 to 9 samples out of21 samples and had concentrations ranging from 0.26 to 20 ug/1. Thesemi-volatile organic compounds had detection frequencies ranging from1 to 9 samples out of 21 samples and had concentrations ranging from 9to 1000 ug/1. Pesticide and PCBs were not found in groundwater

Page 35: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Table 1-3Summary of Surface Soil Sampling Results

Marion/Brags Landfill RI/FS

INVESTIGATIVE SAMPLES(a) BACKGROUND SAMPLES(b)

DETECTIONS/ DETECTIONS/NC. OF VALID RANGE OF NO. OF VALID RANGE OF

CONSTITUENTS OBSERVAT 10NSCC > DETECTION OBSERVATIONS(c) DETECTION

VCLATILES, (ug/kg)

2-Butanone2-HexanoneToluene

SEHI-VOLATILES, (ug/kg)

:hraceneBenzo( a) AnthraceneBenzo(a)PyreneBenzo(b) Fluor ant neneBenzo(g,h, i )PeryleneBenzo(k)FluorantneneBis(2-ethylhexyl)pnthai.-!;eChryseneD ibenzoC a, h) Anthracene

n-butylphthatater luorantheneFluoreneIdeno(1 ,2,3-cd)PyrenePhenanthrenePyrene

PESTICIDES, (ug/kg)

*,4'-DDT

INORGAN!CS,(mg/kg)

CadmiumLeadMercury

1/61/61/6

1/62/62/62/62/62/64/62/61/62/62/61/62/62/62/6

1/6

5/66/62/6

10167

9803300 - 7600WOO • 72006900 - 11,0003200 • 38006900 - 11,000810 • 11,000,0003900 • 5200

HOO430 - 33003700 - 12,000

4303100 - 55002300 - 46005800 • 11,000

76

2 - 1315 - 68.1 - .14

0/40/40/4

0/40/40/40/40/40/40/40/40/40/40/40/40/40/40/4

0/4

0/44/40/4

NDNONO

NDNDNDNDNDNDNDNDNDNDNDNDNDNDND

ND

ND8.6 - 18

ND

TYPICAL CONC. EXCEEDSIN U.S. SOILS TYPICAL COkJC.(EPA,1983) IN U.S. SOILS

None EstablishedNone EstablishedNone Established

None Establ ishedNone Establ ishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone EstablishedNone Established

None Established

0 • 0.72 • 200

0.01 - 0.3

NANANA

NANANANANANANANANANANANANANANA

NA

YNN

a) Soil Samples • SS01, SS02, SS03, SS04, SS07, and SS08b) Background Soil Samples • SS05, SS06, SS09, and SS10c) Number of samples in which chemical was detected over total number of samples analyzed.ND • Not DetectedNA • Not Applicable

1-13

Page 36: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Tibia It•ry of Leachata W«H Supl ing deiultl

Harlon/lraoo; landllll HI/IS

INVEIIIQAIIVE MHTllSd) DACKGIOUND SAHPlESCb) ITAWMDS AKO CdlTEdlA1

t

111

! CONST i IDE NII

VOLAIIltS.tug/l)

Acetone

•enlenof thylbentem

ItrreneToluene

flnyt chloride

totel lylene*

Iran* 1,2-Dlchloroethene

,KKIVOlAlllf«,(Uf/l)(...................I Methrlnecrithalena

•.lt(2-ettiylheiyl)l>Mhalatelapnthalene

INOIGANICS.(ue/l)I................Alu»lnuaAnt loonyArlenlc

lirlualerylllue

Ceofelua

CelcluaCtironliM (h)

CobaltCopperCyenldeIf nn

leadAnonefllua

Hanganefte

Mercury(ticket•oteSfllM

todlwtll.frIln«»TMdluiline

NO. Of •OSIIIVfDEIKIIOHS/

NO. Of VALIDOHEHVAIIONS(e)

I/)J/lJ/l1/11/J1/J1/J1/1

1/J1/11/J

J/J2/11/1I/IJ/lJ/JJ/JJ/JJ/JJ/JI/IV53/1J/JJ/JJ/JJ/JJ/JJ/J1/J2/JJ/JJ/l

NO. OF KKIIIVfDETECTION!/

IANCC OF NO. OF VALID

DETECTION OHtlVATIONKc)

no1? • 4211 tr

2SUO11

71 • 2(011

111000

1J

80800-17(500

K - 419S - 55*

1300 21851.8 • 1<195 - 590

5 J2000 2885000

510 69670 • JJ7

1775 «7JO11

215000 90HJOO

2300 • (63517700 10320000

<260 • 150001.1 • 1.«

4J5 • 177035600 -80000

««000-««T500

7.t92 • 105

182 - 6582870 - VJ<5

0/71/70/70/70/70/70/70/7

0/6

2/»0/4

0/60/60/64/41/40/44/43/60/60/40/60/6

0/66/65/60/62/66/64/40/60/40/46/4

tAfE DmmciNG guild ACT CLEAN UATO ACT

PDOIECTION Of MfUII HI Aim MOICCTION Of FMSNUATEII EICEEOt STANDARD*.......................... AOUATIC life AND OIIIEIIA

INCESIINC INGESTING .......................... ................. ,

IANGE OF PHOTOSED PIOPOSIO UAItl AND OHGANI9K NUHM FHSNUATEI 'DITECTION NCl HCl NCLB NCLG ORGANISMS ONLT ACUTE CNOORIC MALTN MUAIIC LIFt

NO

I • • 5 .0 0 • • 0.44 ( f ) tO ( t ) 5100 (1 ) - • 11NO •• -• - 680 UOO (4) J280 (d) 12,000 (() N N

NO

NO •• •• •• 2000 14,300 (d) 1 24,000 (d) 17,500 (t) N 1

NO •- 1.0 0 -• 2.0 (t) 525 (t) •• •• 1 •• 'NO •• •- 440 •• •- •• •• N -- im .. .. .. n •• •• •• -- N -• , '

)V

1NO

1 5 • 3 3 0 • • - - • • • • 15,000 ( d ) 15,000 ( d ) 11,100 ( f ) J . O ( f ) N T 'NO . . . . . . . . . . . . 2MO (f) 420 (») •• N

{

NO j

NO ,

NO

36 1110.4NO

51100 • 1140004.5 • 6.1

NO

NONO

ND

NO ,

21400 • 36700

20 415NO

10 202250 52800

11100 27400

NONO

ND

14 • 97

• ) U.ch.t. Well Smplii - LU02 and IUOJb) Itcleround (aoplti • GU08, CUO9, GUI6. and GU17c) Nurfxr o( taapUa In uhlch cht»lc«l nai ditKlcd over lh< total nurtxr o( (a*pl«l analylad.d) For Toxlc l ty Protvctlon

• ) lor lot 6 Carclnojcnlclty froKctlonf) lou»t deported lo«lc ConcentrationNO • Not Detected

Page 37: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

INVfSIICAIIVE

lob.. 15 ( ^ t••try of Groundutttr Stapling Deiultt <

Ntrlon/lrioa llndflll «l / fS 1

SAMPlESd) (ACINOUNO SAHPUI(b) tlANOAIOS ANO CII1EIIIA

Mf[ DIIINKINC UAIE* ACT CLEAN IMIEI ACt i'

CONSUfUCNTt

ffl AOUIrEl

lATUES.dlt/l)

1-Olchlorotihtntmene(orobemonthylberaentyrenttrochtorotthenttnt- 1.2-Dlchlorotthtntichlorotthtntlentt(Iottl)J1IVOIAIIIES,(U|/I>

4-Olchlorobcnitntanlolc Acidl-(2-tthylheirl)f*ithtlttt•n-lutylcfithtlttt

IO*GANIC$,(U|/I)

ttnlctrlutfryll lutKtalueonodtfnotlutmotnettIvtr»1l.f.Ine1

NO. or posmvfDEIECIIONS/NO. or VAIIOONStlVAIIONS(C)

1/219/214/214/211/211/214/215/213/21

1/211/219/211/21

10/2121/211/211/21

12/211/21

21/212/211/21

21/21

1/21

NO. or POSITIVEOETECIIONV

IANGC Or NO. Of VAIIOOflECIION OtSEIVAtlONSU)

.92 0/71.5 • 12 1/74 • 16 0/71 . 5 - 9 0/7

1.1 0/7.78 0/7

.26 • 20 0/70.9 • 7.1 0/72.1 -7.1 0/7

14 0/6950 1/6

9 • 1000 0/699 0/6

11 • 78 0/619 • 1640 6/6

6 1/65 0/6

232 • 10700 0/66 0/6

26800 ••3000 6/6424 • 441 5/6

9.2 0/691M-753000 6/6

118 6/6

««NCf orOEIEC1ION

NO5

NONONONONO

NO

NO

NO5

NONO

•D

16 • 111.4NONONO

21400 - 3670020 - 415

NO

11100 • 27(00

16 • 97

PHOIECtlON W MJUN NEAUN

IKCfJIINC IHCT.1T INC

PROPOSED PIOPOSED UAIEI ANO ORGANISMS

NCl NCl KCIO MCIC ORGANISMS ONIT

5 0 -• .66 (t) 40 (t)60 488 (d) 15.050 (d)

e«0 1400 (d) 3280 (d)

0 .8 78m

• • 5 0 - • 2 . 7 ( t ) 8 1 ( t )440

75 75 •• 400 (d) 2600 (d)

15,000 <d> 50,000 <d)34,000 (d) 154,000 (d)

50 •• •• 50 .0022 (t) .0175 (t)1000 •• •• 1500

.0037 (t> .0641 (t)10 •• •• 5 10 (d)

50 •• •• 20 50 (d)

50 •• •• •• 50 <d>

not 1C? ION or mtmutttAOUA1IC Ufl

ACU1E CNMMIC

5300 (f)19.500 (t>32,000 <|>

5280 (•) 840 (t)135.000 (|>45.000 (|)

1120 <f> 763 (f)

11,100 (f) 3 (f)940 (f)

160 (t) 190 (1)

130 (f) 5.3 It)17.1 (f.h) 1.2 (f.h)

429 (f.h) 16.8 (f.h)

38.2 (f.h) .12 (f)

947 (f.h) 47 (f.h)

E Id EDS STAMMWt 'ANO OIIEKIA [

................. jf

HUMAN rtCMMIMNEAUN AOUAIIC lift *

^

..

T N

N N

N N .

T N j'

N Nr « iN

i

N N ':

iN rN N '.

PV

T NT

T 1II T

N I

N T 'I

N r

t) CrouidMttr ••*>!•• • •UD2.CWO].CV04.CU05,CU06.CU07,CW10,CUt1,CUI2,CUI3,CWl4, ond CU15b) Ixkoro^d So^>ltl • MM, CU09, CV16. tnd CUI7c> Nuditr of IMC4M In Uilch chtalctl wtt dtttcttd ovtr tht tottl nuifctr of itoplet tntlyttd.d) for loilclty Protectiont) ror 10E-6 Ctrclnoftnlclty Protectionf) EPA AM)lent Utter Outllty Crlttrltf> lOMtt leporttd Io>lc Conctntrttlonh) Vtlutt ihoxn trt btted on on ivtrott froundmter hirdnett of 368 "0/1 tl CtCOI.NO - Not DetectedNOTE: fleiultl fro* unflltered ltei>ltt trt not Included In thll toblt.

•: i

Page 38: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 1July 31, 1987Page 1-16 of 28

samples. Eleven inorganics were found at concentrations abovebackground levels. The inorganics had detection frequencies rangingfrrm 1 to 21 sanples cut of 21 samples. Inorganics of potentialconcern include arsenic, barium, beryllium, cadmium and zinc.

Contaminants were not found in the groundwater from the lower aquifer.This is ffae to the thick, impermeable glacial till layer thatseparates the upper and lower aquifer and due to the upward gradientof the lower aquifer.

Water supply wells were sampled to determine whether or not sitecontaminants have impacted the off-site water supply wells. Five Cityof Marion municipal wells, two industrial wells, three commercialwells from small businesses and eight residential wells were sampled.The results of water supply well sampling are shown in Table 1-6.Organic compounds were not found in any water supply sample. Fifteeninorganics were found in water supply samples and had detectionfrequencies ranging from 1 to 19 samples out of 19 samples. Of these15 inorganics, 4 have established Safe Drinking Water Standards (SDWA)(arsenic, barium, chromium, copper). All four of these inorganicswere less than their respective SEWA standard. Sodium exceeded theAmerican Heart Association criteria in several wells.

Surface Water and Sediment

Surface water and sediment samples were collected to determine whetheror not the landfill has had any detectable impact on surface water andassociated sediment. Surface water and sediment were investigated bycollecting samples from an on-site leachate seep, the MississinewaRiver, the large on-site pond, the large off-site pond and three smalloff-site ponds (background samples).

Leachate Seep

A low volume (less than 1 gpm) leachate seep was observed on the siteduring the remedial investigation. The leachate from the seep flowsto the south and a path of stained soil is visible leading towards thesouthern boundary of the site. It appears that the leachate seepsbacks into the soil as it flows south. A potential receptor is thelarge off-site pond immediately adjacent to the southern boundary ofthe site.

The results of leachate seep sampling are shown in Table 1-7. Twovolatile organic compounds were found at concentrations abovebackground levels. The volatile organic compounds had detectionfrequencies ranging from 1 to 2 samples out of 2 samples, and hadcxancentrations ranging from 74 to 160 ug/1. Semi-volatile, pesticideor PCS compounds were not found in leachate seep samples. Twelve

Page 39: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

, > le 16Sunury of *-.iT Simply Swpllng Result*

H«rlon/lr.g» Ltndflll II/FS

INVESTIGATIVE SAMPLESU) IACKGROUNO SAMPLES S«fE DRINK IMO WATER ACT

NO. OF POSITIVEDETECTIONS/

J NO. OF VALIDCONST llUf NTS OISERVATIONS(b)..... ...f........ .............................

INORGANICS, (ug/l)........ ........

Anentci.rlu.ClIclUM

2/1919/1919/19

Chromlus 1/19Cob.lt | 1/19CopperIronLlthltM

8/1917/1918/19

Mignetluii 19/19««nj«r>«s» 18/19Molybdenui 5/19Nickel 2/19Pouttluii 1/19SodluiZinc

I 19/1911/19

RANGE OFDE1ECIION

2.2 • S.417 • 416

57400- 13500037.29.9ft

4.25 • 17.820! • 303010.2 - 33.929430-429007.35 • 25911.1 • 83.722.6 • 146

36907500-4370046.7 - 1250

NO. OF POSITIVEDETECTIONS/NO. OF VALIDOfSERVAIIOHS(b)

NANAHANANANANANANANANAHANANAHA

LIFETIME AMERICANRANGE OF PROPOSED PROPOSED HEALTH HEART EXCEEDS STANDARDSDETECTION MCI MCI MCLO MCtO SMCl ADVISORIES ASSOC. AND CRITERIA

NA SO -• •• 50 •• -• •• NHA 1000 -• -• ' 1500 •• -- •• NHA

NA 50 •• •- 120 •- -• •- NMANA •• -- •• 1300 1000 •- -• NNA •• •• •• •• 300 -- •• TNAHARA

NANA •• •- •• •• -• 150 -- NKA

NA •• -- •• •• •• •• 20000 THA •• -- •• •• 5000 -- •• N

• ) Water Supply Saiple* - WS01, WS02, VS03, USM. US05. WS06, WS07, US08,I WS09, UttO. USH, WS12, US13. WS14. WS1S, WS65, WS66, WS67, md WS68

b) NLKtwr of iwf>l<t In Mhlch chculcil MM d*ttc(cd over Iht totit nurtxr of iwplciNA - Not Appllc»blt

Page 40: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Ih-1oo

Table 1-7Summary of Leachate Seep Sampling Results

Harfon/Bragg Landfill Rl/FS

INVESTIGATIVE SANPLES(a) BACKGROUND SAMPLES(b)

CONSTITUENTS

VOLATILES.(ug/l)

1,1,1-TrlchloroethaneAcetone

lNORGANICS,(ug/l)

AluminumBariumCadmiumCopperIronLeadMagnesiumManganeseNickelPotassiumSodiumZinc

NO. OF POSITIVE NO. OF POSITIVEDETECTIONS/ DETECTIONS/NO. OF VALID RANGE OF NO. OF VALID RANGE OFOBSERVATIONS(c) DETECTION OBSERVATIONS(c) DETECTION

1/21/2

2/22/22/22/22/22/22/22/21/22/22/22/2

74160

1720 - 4065634 - 9899 - 21

164 - 32759000-12070053 - 6486400-110500564 - 723

4133100-47450114000-212000785 - 997

0/70/7

0/66/60/60/60/60/66/65/62/66/66/66/6

NDNO

NO36 - 111

NDNDNOND

21400 - 3670020 • 41510 - 20

2250 • 5280011100 - 27400

16 • 97

t ,ttf

a) Water Satnples • LC01b) Background Sanples - GU08, GU09, GU16, and GU17c) Nuriber of samples In which chemical was detected over the total number of samples analyzed.ND - Not Detected

Page 41: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 1July 31, 1987Page 1-19 of 28

inorganics were found at concentrations above background levels.

Leachate Sediment

A soil sample in the leachate seep runoff path was collected to assessresidual soil contamination. The results of leachate sedimentsampling are shown in Table 1-8. The number and concentration oforganic contaminants was relatively low. Two volatile organiccompounds (12-18 ug/kg), one semi-volatile organic conpound (1050ug/kg) and one pesticide (dieldrin) (94 ug/kg) were found. Eleveninorganics were found at concentrations above background levels. Ofthese 11 inorganics, 5 exceed typical concentrations in U.S. soil(antimony, cadmium, copper, selenium, zinc).

River Water

Ten samples from five locations along the perimeter of the landfillwere collected to determine whether or not the landfill had anydetectable impact on the Mississinewa River. Organic and inorganiccontaminants were not found in any river water samples. Low levels ofcontamination present in groundwater from the upper aquifer and largedilution provided to the groundwater discharge by the river was mostlikely the reason for not detecting any contamination in the river.It has been estimate that contaminants in groundwater from the upperaquifer that enter the river would not exceed SDWA or dean Water Act(CWA) criteria in the river, based on an average recorded river flowof 627 cfs and an estimated groundwater discharge rate of 0.35 cfs.

River Sediment

The river sediments were sampled at the same locations as the riverwater sampling. The results are presented in Table 1-9. Organiccontaminants concentrations above background levels were not found inany river sediment samples. Two inorganics (silver, beryllium) werefound at concentrations above background levels. The inorganicconcentrations did not exceed typical concentrations found in U.S.soil.

On-Site Pond Water

Pond water samples were collected to characterize pond water qualitywith the ultimate goal being to evaluate whether or not hazards existdue to contaminants present in the pond water. The results of on-sitepond water samples are presented in Table 1-10.

One volatile organic compound was found at a relatively lowconcentration (chloroform 13 ug/1) in one out of seven pond watersamples. Seventeen inorganics were found above background

irations»

Page 42: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Table 1-8Summary of Leachate Sediment Sampling Results

Marlon/Bragg Landfill Rl/FS

INVESTIGATIVE SAHPLES(a) BACKGROUND SAMPLES(b)

IN>O

NO. OF POSITIVE NO. OF POSITIVEDETECTIONS/ DETECTIONS/ TYPICAL CONC. EXCEEDSNO. OF VALID RANGE OF NO. OF VALID RANGE OF IN U.S. SOILS TYPICAL CONC.

CONSTITUENTS OBSERVATIONS(c) DETECTION OBSERVATIONS(c) DETECTION (EPA.1983) IN U.S. SOILS

VOLATILES, (ug/kg)

2-Butanone 1/1 IB 0/4 ND None Established NATotal Xylenes 1/1 12 0/4 ND None Established NA

SEMI-VOLATILE*, (ug/kg)

bls(2-ethylhexyl)phthalate 1/1 1050 0/4 ND None Established NA

PESTICIDES, (ug/kg)

Dleldrln 1/1 94 0/4 ND None Established NA

INORGANICS (dig/kg)

AntimonyArsenicBariumCadmiumCopperIronLeadNickelSeleniumTinZinc

1/11/11/11/11/11/11/11/11/11/11/1

183569824390

121,000134453.430

1750

0/4 ND 2 - 1 0 Y3/4 7.5 - 12 1 - 5 0 N4/4 32 - B5 100 - 3000 N0/4 ND 0.01 - 0.7 Y4/4 1 5 - 4 2 2 - 100 Y4/4 9920 - 21,500 None Established NA4/4 8.6 - 18 2 - 200 N4/4 1 1 - 4 6 5 • 500 N0/4 ND 0.1 • 2.0 Y4/4 1 9 - 2 2 2 • 200 N4/4 57 - 87 10 - 300 Y

a) Sediment Sample • LS01b) Background Soil Samples - SS05, SS06, SS09, and SS10c) Number of samples in which chemical was detected over total number of samples analyzed.ND • Not DetectedNA - Not Applicable

Page 43: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Table 1-9Summary of River Sediment Sampling Results

Harion/Bragg Landfill RI/FS

INVESTIGATIVE SAMPLES(a) BACKGROUND SAHPLES(b)

CONSTITUENTS

INORGANICS, (mg/kg)

BerylliumSilver

NO. OF POSITIVEDETECTIONS/NO. OF VALIDOBSERVATIONS(c)

1/«1/4

NO. OF POSITIVEDETECTIONS/

RANGE OF NO. OF VALID RANGE OFDETECTION OBSERVATIONS(c) DETECTION

.5 0/3 ND1.7 0/3 ND

TYPICAL CONC.IN U.S. SOILS(EPA.19S3)

0.1 • 400.01 - 5

EXCEEDSTYPICAL CONC.IN U.S. SOILS

NN

a) Sediment samples • RS01, RS02, RS04, and RS05b) Background Sediment Samples • RS03, RS06, and RS07c) Number of samples In which chemical was detected over total number of samples analyzed.NO • Hot DetectedNA • Not Applicable

Page 44: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Table 1-10, of Pond Wtter Stapling ResultsMarlon/lragg landfill HI/IS

mvflllGAtlVf SAHPUS(a) lACtGIIOUNO IAM>lCS{b) S1AKXKOI AM) atllCfllA

•o. or POSITIVEDETECTIONS/

; M>. Or VALIDI CONSTITUENTS OIS(RVAIIOIIS(c)

no. or positiveDCICCTIORS/

RANGC or m. or VALID RANGE orDETECTION atSEIVATIONS(c) DE1ECMO*

SAfE ORINKINC WAIER ACI

PROIECIION or

IDGCSIINOPROPOSED PROPOSED WATER AM)

MCI HCl HCIC NCIC ORGANISMS

ClEA* WATER ACf

MMM RCAim

IHGdlllQ

ORCASIISHS

ONLY

pROUcnn orAOUATIC

ACUTE

fRESMAIEtlift

CRRORIC

tXCEEDS S1A«OA«OSAM) OIIIERIA

MWW rMSMMIER•EAL1R AOUA1IC llfE

.i

1.

*

ON SIX POM)

VOlAmES.(Uf/l)

Chtorofortl 0/J 100 28900(f) 12(0 (f)

' SENIVOlAIIlES.<Uf/l>II ....................blt(2-ttfiylht»yl)ptithalatt 1/7

l»0«CANICJ,(ug/l)

AlifalruaAnt leionyArstnlcItrlua

CadaluaChroatlua (h)

CobaltCopper

IronI tad

flangancttNickel

PotassiuaSilverSodlua

vanadlualine

IARGE Off Sllf

ima.GAIIICS,<ui/l)

Ctiroolua <h)Nercury I/*

2 40.9

0/3

1/71/71/76/71/72/71/71/72/71/71/75/77/71/77/71/71/7

176056118

137 • 118019

4.3 • 282»204

3160 106000

1881940

6.2 - 719740 • 11200

211*500 47900

49777

3/10/10/3

1/10/10/10/10/10/32/33/30/33/30/31/10/13/3

0/30/3

15000(d) SOOOO(d) 11100(f> 3(1)

1M-188M>m

46 • 65

M)M)

293 4812 4

21 47M)

2145 • 3490Ml

10600 • 19800M)

3 . 3 - 1 8

30.0100010.030

50

30.0

50.015005.0120

146(d).0022(e)

100(d)50 (d)

43,000(d).0175(e)

9000(1) 1600(f)I60(f) 190(f)

14.4(f.l) 2.8J(f.l)16/4489(1,1) 11/538 (f.l)

1100

30(d>

13.4 (d)

50(d)

100 (d)

53 ( f . l ) 12 ( f . l )

4063(f.l) 158(f,l>

MOO (f) 212 ( f . l )

807(f.l) 0.12(g)

<112(f.l) »7 ( f )

502.0

50 (d)S 0 2.4

(f.l)0.012 (f)

a), On lilt Uatfr t ap.pl tt • PU01.PV28. and PV29j o f f Sltt w.l.r iMpUt • PW02 Mid PW3I

b) Itcktromi Ja«*>lti • PV01. PUD*, and PVMO Rurfxr of tablet In uhlch chmlctl MI detected ovtr tht toll) nurfxr of tenpltl analyzed.d) for ta«lc l ty Protectlcn• ) for 101 e Carclnogtnlclly Protectionf) IP* Aafcltnl U»t«r duality Criteria• > lowest Reported Tonic Concentration

h) frtsh Water Aquatic lift Criteria Show art for Cr6/CrS. Cr3 criteria U baled on an average on-llte and off ill* pond nater harontif of 320 and 207 «g/l as C«C01, rnp»ctlvtly.I) Valuta ahoun art bated on an averaga on-altt and off altr pond Kater hardnttt of 3?0 and 2QT *g/l at CACO], respectively.NO • Not Detected

Page 45: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

--.•».-.*.».-Feasibility StudyMarion/Bragg Landfill SiteSection: 1July 31, 1987Page 1-23 of 28

Off-Site Pond Water

The results of of f-site pond water samples are presented in Table1-10. Organic contaminants were not found in the off-site pond abovebackground levels. One inorganic (chromium) was found at aconcentration above background levels in 1 out of 4 pond watersanples.

On-Site Pond Sediment

The results of on-site pond sediment sampling are shown in Table 1-11.One volatile organic compound was found at a concentration abovebackground levels and had a detection frequency of 2 out of 4 samplesand a concentration range of 6 to 40 ug/kg. One semi-volatile organiccompound was found at a concentration above background levels and hada detection frequency of 2 out of 4 samples and a concentration rangeof 480 to 930 ug/kg. Fourteen inorganics were detected atconcentrations above background levels. Of these fourteen inorganics,only (cadmium) exceeded the typical concentration found in U.S. soil.

Off-Site Pond Sediment

The results of off-site pond sediment sampling are shown in Table1-11. One volatile organic compound was found and had a detectionfrequency of 2 out of 3 samples and a concentration range of 11 to 245ug/kg. Three semi-volatile organic compounds were found and had adetection frequency of 1 out of 3 samples and a concentration range of786 to 1918 ug/kg. Fourteen inorganics were detected atconcentrations above background levels; however, none of theseexceeded the typical concentrations found in U.S. soil.

Asphalt Plant Effluent

Effluent from the Marion Paving Company asphalt plant is discharged tothe on-site pond via surface drainage ditch. This effluent wassampled to determine whether or not contaminants found in the on-sitepond could logically be attributed to this effluent discharge. Theresults of asphalt effluent collected from the discharge pipe areshown in Table 1-12. Only one volatile compound was detected at alevel of 15 ug/1. Three semi-volatile compounds were detected atconcentration levels of 16 to 118 ug/1. Eighteen (18) inorganics weredetected above background levels.

Asphalt Plant

Effluent fron the Marian Paving Company flows to the on-site pond anddeposits its sediment load in a low area forming a delta as the water

Page 46: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Suimary of Pond Sediment Sampling Result*Marion/Bragg Landfill RI/FS

INVESTIGATIVE SAMPLES(a) BACKGROUND SAMPLES(b)

NO. OF POSITIVEDETECTIONS/NO. OF VALID

CONSTITUENTS OBSERVATIONS(c)

NO. OF POSITIVEDETECTIONS/

RANGE OF NO. OF VALID RANGE OFDETECTION OBSERVATIONS(c) DETECTION

TYPICAL CONC.IN U.S. SOILS(EPA.1983)

EXCEEDSTYPICAL CONC.IN U.S. SOILS

ON-SITE

VOLATILES. (ug/kg)

Methylene Chloride

SEMI-VOLATILES, (ug/kg)

bis(2-ethylhexyl)phthalate

INORGANICS,(mg/kg)

AluminumArsenicBariumCadmiumChromiumhopperIronLeadMagnesiumManganeseMercuryNickelVanadiumZinc

2/4

2/4

40

480 - 930

1/3

0/3 NO

None Established

None Established

NA

NA

1/42/41/42/41/42/41/41/41/41/41/43/41/42/4

74107.6-14

1393.3 - 4.1

1119 - 60295006134200599.28

18 - 3728

49 - 280

3/31/33/30/33/33/33/33/33/33/30/33/33/33/3

1570-31806

8.5 • 19NO

5.2 - 116.25 - 125210-105005.1 - 1117500-24600119 - 414

NO4 - 114.7 - 1320.5-33

None Established1 - 50

100 - 30000.01 • 0.71 • 10002 - 100

None Established2 • 200

None Established20 - 30000.01 - 0.35 - 50020 - 50010 - 300

NANNYNNNANNANNNNN

1-24

Page 47: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Table 1-11{cont.)Summary of Pond Sediment Sampling Results

Marion/Bragg Landfill Rl/FS

INVESTIGATIVE SAMPLES(a) BACKGROUND SAMPLES(b)

NO. OF POSITIVE NO. OF POSITIVEDETECTIONS/ DETECTIONS/ TYPICAL CONC. EXCEEDSNO. OF VALID RANGE OF NO. OF VALID RANGE OF IN U.S. SOILS TYPICAL CONC.

CONSTITUENTS OBSERVATIONS(c) DETECTION OBSERVATlONS(c) DETECTION (EPA.1983) IN U.S. SOILS

OFF-SITE

VOLATILE*, (ug/kg)

Hethylene Chloride 2/3 11 - 245 1/3 7 None Established NA

SEMI-VOLATILES, (ug/kg)

.-nzoic Acid 1/3 1918 0/3 ND None Established NAbis(2-ethylhexyl)phthalate 1/3 881 0/3 ND None Established NADi-n-butylphthalate 1/3 786 0/3 ND None Established NA

INORGANICS.CmgAg)

AluminumBariunBerylliumCalciumCopperIronLeadMagnesiumManganeseMercury"ickeldiun

VanadiumZinc

1/3 6480 3/3 1570-3180 None Established NA1/3 102 3/3 8.5 - 19 100 • 3000 N1/3 1.5 0/3 ND 0.1-40 N2/3 138000-163000 3/3 72600-97900 None Established NA2/3 31 - 56 3/3 6.25 - 12 2-100 N1/3 32200 3/3 5210-10500 None Established NA1/3 37 3/3 5.1 -11 2-200 N3/3 31100-39100 3/3 17500-24600 None Established NA1/3 1200 3/3 119 - 414 20 - 3000 N1/3 .13 0/3 NO 0.01 - 0.3 N1/3 42 3/3 4 - 1 1 5 • 500 N1/3 4350 2/3 1600 - 1640 None Established NA1/3 28 3/3 4.7 - 13 20 - 500 N1/3 158 3/3 20.5-33 10 • 300 N

a) On-Site Pond Sediment Samples • PS01, PS04, and PS05Off-Site Pond Sediment Samples • PS02 and PS06

b) Background Sediment Samples - PS03, PS07, and PS08c) Number of samples in which chemical was detected over total nonber of samples analyzed.ND • Not DetectedNA - Not Applicable

1-25

Page 48: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TableSumwry of A>phalt Plant Effluent Sampling Resulti

Harlon/Hragg landfill R l / f S

INVESTIGATIVE SANPLES(a) IACKGROUM SAMPLES(b) STANDARDS AND CRITERIA

jj1

1i CONSIITUCNIt

VOLATILE!. (ug/l)

2-lutanone

SENIVOlAIILES,(ug/l).....j. .............

4 Meldylphenol•eruyl AlcoholPhenol

1INORGANICS, (ug/l)

1AliolruaArseniclarluNleryllluaCelcltaaChronluiKh)Cob.ltCopper,CyanideIron jlead >MagneaiuaManganeseNickel,PotassiumSodluaVarudlulZlrvr i

NO. OF POSITIVE

DETECTIONS/

NO. OF VALIDWSERVAIIONS(C)

1/2

1/21/21/2

2/21/22/Z1/22/22/22/22/22/22/22/22/22/22/22/22/22/22/2

NO. OF POSITIVEDETECTIONS/

IANCE OF NO. OF VALID

DETECTION OISERVAIIONS(c)

15

1610118

61285-166000152

547 • 10956.75

1940000-4921000160 - 26799 - 181265 • 481

26 • 44197700 1270010 • 2151022500- 10280007789 - 12200121 • 44629500-7480048300-6985022T • 593733 1295

0/7

0/6

0/60/6

0/60/66/61/66/61/60/60/60/60/40/66/65/62/66/66/60/66/6

SAFE DRINKING WATER ACT CLEAN WATER ACT ,

PROTECTION OF HUMAN HEALTH PROTECTION OF FRESHWATER EXCEEDS STANDARD!.......................... AQUATIC LIFE AND CRITERIA

RANGE OF PROPOSED PROPOSED WATER AW ORGANISMS HUMAN FRESHWATER

DETECTION HCL HCL HCLG MCLG ORGANISMS ONLY ACUTE CHRONIC HE Alt N AOUAIIC LIFE

NO .. .. .. .. .. .. .. .. .. .. {

«'

)

„ .. -- .. .. -- -. .. -- .. - ;! ;NO -- -- -- .. -- -- .. -- .- .- ;.

NO •• •• -- -- 3500 (d) 769000 (d) •• •• i •• j;

1i

NO .. .- -- .. -- .. .. .. .. . .

NO 50 •• -- 50 .0022 (e) .0175 (e) 360 (f) 190 (f) T N i16 • 111 1000 •• •- 1500 -• -• -- -• T •• i

.4 •• -- •- •• .0037 (e) .0641 (e) 130 (g) 5.1 (g) T t '51100 • 114000 -• - • - • • • - - • - • • - - - • • - j

4.5 - 6.1 50 •• -- 120 50 (d) -• 16/20440(f . 1) 11/2448(f.l) T T/N jNO .. .. .. .. .. .. .. .. .. .. I

NO •• •- •• 1300 -- •• J04 (f.l) 157 (f.l) N T •'

NO •• -- -• •• 200 (d) •• 22 (f) 5.2 (f) N t !DO .. .. .. .. .. .. .. .. .. .. J

NO 50 •• -• 20 50 (d) -• 1761 (f.l) 146 (f,l) T T '21400 • 36700 •- -• •• -- •• -- -• -- -• •- . ' |

20 • 41510 • 20 •• •- •• •• 13.4 (d) 100 (d) 1100 (f) 946 (f. l) t N .'

2Z50 • 52800 - • - • - - - - - • - • - - - - - - - -11100 - 27400 • • • - • • - • • • - - • • • - - - - •

NO • • • - • • • • - • • • • - - '

1 6 - 9 7 - • 19?8 (f . l ) 47 <f) T

a) Efflurnt Iwpl. - AfOI

b) larkground Sanplo • CW08, GW09, GV16, and GW17c) Nurf>*r of tanpltt In which chcolcal Mat detected over the tota l timber of (anplei analyied.d) For To«lcl ly Protectione) For Carcinogenic Ity Protectionf) EPA Acblent Water Ouallty Criteriaf) Loweit Reported Toxic Concentrationh) Freihu.ter Aquatic life Criteria ahovn are for Cr6/Crl. Crl cr i ter ia la baied on an atphalt plant effluent hardnes* of 2043 nj/l ai CaCOl.I) Valuei ihoun are baled on an alphalt plant effluent hardhett of 2041 ng/l a< CaC03.NO - Not DetectedData ahoun above U for unflltered aaa^ilei.

Page 49: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility studyKarion/Bragg landfill SiteSection: 1July 31, 1987Page 1-27 of 28

enters the pond. The results of asphalt plant sediment sampling areshown in Table 1-13. Only one volatile organic compound was detectedat a concentration level of 23 ug/kg above background level. Nosemi-volatile and pesticide/PCB compounds were detected in thesediment sample. Nine inorganics were detected above backgroundlevels.

AirTwo potential mechanisms exist for transport into air — volatiliza-tion from exposed waste, soils and water, and resuspension of wasteand contaminated soils through wind erosion or mechanical disturbance.In the past, during the active life of the landfill, it is likely thatboth of these mechanisms were important since many volatile chemicalswere disposed of at the landfill (based on current sampling data) andon-site vehicular traffic and landfilling activities would havecreated significant quantities of dust. Currently, however,landfilling activities have ceased, surface soils show very littleorganic contamination, and a large portion of the site is vegetated.All these conditions would significantly reduce the potential forcontaminants to migrate into the air. Except in one instance, organicvapor monitoring conducted during the PI did not detect concentrationshigher than background. During monitoring well installation at onelocation, the OVA detected concentrations of organic vapors in excessof background. In conjunction with the HNu, these vapors wereidentified as methane, a nontoxic gas under ambient conditionsgenerated in municipal landfills and in wetland areas by decayingorganic matter. Therefore, the air migration pathway is notconsidered to be significant.

Page 50: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Table 1-13Summary of Asphalt Plant Sediment Sampling Results

Harlon/Bragg Landfill RI/FS

INVESTIGATIVE SAHPLES(a) BACKGROUND SAMPLES(b)

IroOO

NO. OF POSITIVE NO. OF POSITIVE

CONSTITUENTS

VOLATILES, (ug/kg)

Methylene Chloride •

INORGANICS, (mg/kg)

A 1 in inureCalciumCopperNfckelPotassiumSodiumTinVanadiumZinc

DETECTIONS/NO. OF VALIDOBSERVATIONS(C)

1/1

1/11/11/1V11/11/11/11/11/1

RANGE OFDETECTION

23

*9«1720002320

17652905282060

DETECTIONS/ TYPICAL CONC.. EXCEEDSNO. OF VALID RANGE OF IN U.S. SOILS TYPICAL CONC.OBSERVATlONS(c) DETECTION (ERA, 1983) IN U.S. SOILS

1/3

3/33/33/33/32/32/31/33/33/3

7 None Established

1570 - 3180 71,00072600-97900 None Established6.3 - 12 2 - 1004 - 1 1 5-500561 • 698 None Established1600 - 16AO None Established

10 2 - 200A. 7 - 13 20 - 50021 -33 10 • 300

NA

NNANNNANANNN

a) Sediment Samples - AS01b) Background Samples - PS03, PS07, and PS08c) Number of samples in which chemical was detected over total number of samples analyzed.NA - Not Applicable

Page 51: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 2July 31, 1987Page 2-1 of 6

SECTICN 2

PUBLIC HEALTH EVALUATION ANDAN ENVIRONMENTAL IMPACT ASSESSMENT SUMMARY

2.1 INTRODUCnCN

As part of the remedial investigation of the Marion/Bragg Landfillsite, a Public Health Evaluation (PHE) and an environmental impactassessment were performed. The public health evaluation performed forthe Marion/Bragg landfill site is a baseline assessment that addressespotential hazards to human health posed by the site in the absence ofremedial actions. Based on an evaluation of the sampling results forvarious environmental media and a knowledge of the site history andcurrent use, chemicals of potential concern were identified for thesite. The results of the PHE were presented in Section 5 of theremedial investigation report. The results of these analyses aresummarized in this section.

2.2 EXPOSURE PATHWAYS

Exposure pathways of contaminants at the Marion/Bragg landfill siteare presented in Table 2-1. Exposure media include on-sitegroundwater, surface water and sediment including on-site and off-sitepond, leachate seep, and on-site surface soil.

Under current use conditions at the site and neighboring areas, theprincipal exposure pathways through which humans might potentially beexposed to site contaminants are:

o Direct contact with contaminated soil and leachateseep/sediment by trespassers on the site;

o Direct contact with contaminated surface water by olderchildren who may swim in the on-site pond; and,

o Consumption of fish caught from the on-site pond andoff-site pond.

The above-mentioned potential exposure pathways would also apply inthe future. In addition, it is hypothesized that in the future,groundwater from the upper aquifer may possibly be ingested on aperiodic basis by people using the site for a weekend home or campsite.

Exposure scenarios for each of these potential current and futureexposure pathways were developed and concentrations of chemicals to

Page 52: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 2-1P O T E N T I A L P A T H W A Y S O F H U M A N E X P O S U R E T O C O N T A M I N A N T S

OK I 0 I NAT I NO AT THE MA f t I O N / 1 R A G O L A N D F I L L S I T i

E x p o e u r e M e d l u NP o t e n t i a l R o u t e t o f

E x p o i u r e P o t e n t i a l Receptors P a t h w a y Complete?

Ground w a t e r

K)iK)

I n g e t t l o n , i n h a l a t i o nof v o l a t iI••,d e r m a I a b s o r p t I on

Uaera of water fromm u n i c i p a l , i n d u s t r i a l ,c o m m e r c i a l , and r e s i -dent I a I w e l l s

Current use: No. W e l l s arenot h y d r e u I i c a I Iy connectedto s i t e ground water or areoutside the zone of i n f l u e n c eof the groundwater that flowsthrough the s i t e .

F u t u r e use: Yes. If a w e l l

Is I n s t a l l e d at the s i t e Int h e s u r f l c i a l a q u i f e r .

Surface w e t e r / s e d I « e n t D e r m a l a b s o r p t i o n .i n c i d e n t a l i n g e s t l o n

i f c p l l ( o n - s f t e )

I n g e s t l o n of f i s h

D a r n e l a b s o r p t i o n ,I n c i d e n t a l I n g e s t f o n

L o c a l p o p u l a t i o n ,u s i n g o n - a n d o f f - s i t eponds and H i s s l s s i n e w aR i ver

Local p o p u l a t i on,u s i n g s u r f a c e w a t e rf o r f i s h i n g

L o c a l p o p u l a t i o n

Yes. The on and o f f - s i t eponds a n d M i s s i s s i n e w a R i v e rare used for r e c r e a t i o n a lpurposes; c o n t a m i n a t i o n c a nr e a c h t h e s e s u r f a c e w a t e rb odies.

Yes, t h e M i s s i s s i n e w a R i v e ra n d o n - a n d o f f - s i t e pondsa r e used f o r f i s h i n g .

Yes, access to the s i t e isavallable.

Page 53: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 2July 31, 1987Page 2-3 of 6

which these populations might potentially be exposed were determined.These pathway-specific exposure point concentrations were thenassessed with respect to human health risks.

2.3 PUBUC HEATra RISKS

Table 2-2 summarizes the risks determined in the Public HealthEvaluation.

In the direct contact with contaminated soil exposure pathway,exposure was evaluated for the leachate seep area soils and for thegeneral surface soils of the site. For exposure to the leachate seeparea soils, potential risks (hazard indices greater than one, excesscancer risk (upperbound) greater than 10~ ) greater than the targetrisk levels were not indicated under the conditions and assumptions ofthe average exposure scenario. Assuming the conditions of theplausible maximum exposure scenarios, arsenic could pose a potentialexcess cancer risk (upperbound) greater than 10~ .

The general surface soils of the site do not appear to posesignificantly elevated risks greater than the target risk levels underthe conditions and assumptions of the average exposure scenario; underhypothesized exposure conditions of the plausible maximum scenario,the carcinogenic PAHs could Egse a potential excess cancer risk(upperbound) greater than 10 .

The two potential pathways of exposure considered for the on-site pondwere swimming and fishing. Only fishing was considered for theoff -site pond, since it is typically not used for swimming. Exposureto surface water via swimming posed risks significantly less than thetarget risk levels based on on-site pond water data.

Ingestion of fish from the on-site and off -site ponds did not poseelevated risks under the conditions and assumptions of the average orplausible maximum exposure scenario based on on-site and off-site pondwater data.

Periodic consumption of groundwater from the upper aquifer wasevaluated under a p"***ntiiql future use scenario. For this exposure,arsenic posed an excess cancer risk (upperbound) greater than 10~under the conditions of both the average and plausible maxim miexposure scenarios.

It should be noted that these estimates of risks are not precise andthe assumptions that have been made were conservative, i.e. , tendingto overestimation. One example of this is that the current

Ttrations of contaminants in environmental media at the site havebeen aggmpp^ to remain constant over the assumed exposure periods.

Page 54: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLZ 2-2Of POTENTIAL PISR5 ASSOCBOTD WITH

EXPOSURE TO MARICN/HRAQG CHEMICALS OF CCNCERN(a)

Lifetime Excess"Cancer Risk(Upperbound)

Hazard Index forNcncarcinogenic

Effects

Pathway/ChemicalFrequency ofDetection Average Maximum Average Maximum

Direct Contact with SoilsLeachate Seep Area

Arsenic I/ITotal —

Surface Soils

PAHs (Carcinogenic) 13/42Total —

*2-34X10 J

N2_32x10

**-2

NQ6x10 J'

4x10"4x10

2xlO~!J2x10

8x10 !8x10

5xlo~f5x10"

Swimming in On-site Pond

Total

Consumption of Fish fromOn-Site Pond

Total

Consumption of Fishfrom Off-Site Pond

Total

Constp^ption of Gromdwaterfrcm Ctoper Aquifer

ArsenicTotal

6.4X10~3 2.3xlO~3 NQ 3x10 -8

3.7xlO~2 2.2X10'1 NQ 2.10~7

7X10

7/195x10 3x10

NQ

7xlO~!7X10"6

NQ

5x305x10

-4

^Ine individual chemicals of concern piv>sA_at3d in this table oro t^ose tiiatfli^ypose a potential risk; they are defined as ch»n»ioals exhibitingeffects for which the hazard indtax of ^vrposure is gre;a:-.er th-Ji c.-jar or Uchesaicals exhibiting carcinogenic effects for Which the v^xsrbound risk

. exposure j^ gr-cater than 10 .

.'tone of the individual carcinogenic PAHs wore detected more frequently than2/6 vonitoring sanples.

I-JQ = Vot

2-4

Page 55: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 2JUly 31, 1987Page 2-5 of 6

While this may be reasonably appropriate for the more persistentinorganic compounds, certain organic compounds are likely tovolatilize or they might migrate through the soil envirorment to thegroundwater or may be biotransformed. Since the site is not a staticenvironment, these changes are likely to occur at least to Boreextent. In addition, a relatively high degree of uncertainty isintroduced into the assessment of risks due to ingestion of fish fromthe ponds due to the necessity of modeling the uptake of contaminantsinto fish. Actual measurements of contaminant concentrations inedible tissue of fish, if possible, would clearly reduce thisuncertainty.

Another area of considerable uncertainty concerns toxicity values.Ihe risks calculated for potential carcinogens in this assessment are95% upper confidence limit estimates. Accordingly, the actual risksare not likely to exceed those calculated but may be substantiallylower. For noncarcinogens, the critical toxicity values incorporatesafety factors that provide a margin of safety against adverse healtheffects and are therefore conservative. For some elements that may beessential nutrients, the relationship between levels in the diet andhealth and disease is still unclear. Arsenic is an example of such anelement.

Another site-related uncertainty concerns the use of chemicalsdetected only once out of several samples when modeling the exposureconcentrations and the associated risks. These one-time-detectedchemicals were included as a measure of conservatism and may not berepresentative of actual site conditions.

2.4 ENVIRONMENTAL IMPACT ASSESSMENT

The Marion/Bragg Landfill is heavily vegetated with knee-high brushand grass over the entire site. Abundant tree growth is found aroundthe perimeter of the on-site pond and on the fill area north of thecm-site pond. Stressed vegetation was not observed during theremedial investigation. Since the site has been closed for 15 yearsand no impact on vegetation is apparent, it is unlikely that futureimpacts will occur.

During the remedial investigation, numerous people were on site duringthe dawn to dusk time period. During the daylight hours, minimalwildlife was noted by site investigation personnel. Babbits and fieldmice were occasionally observed. On a few occasions, domestic dogs,were observed. One fill area surface soil location (SS07) has a 10cancer risk for humans due to PAHs based on direct contact with thesoil. It is conceivable that direct contact with surface soil from

Page 56: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Tandfill SiteSection: 2

, July 31, 1987v - - ' Page 2-6 of 6

this location could also pose a risk to wildlife and pets. This isspeculative and definitive information regarding the possible effectsof PAHs on wildlife and pets is not available.

Groundwater in the upper aquifer flows through the site and eventuallydischarges to the Mississinewa River. The groundwater containsrelatively low concentrations of contaminants. Due to the relativelylow groundwater contaminant concentrations and the high dilution rateafforded by the river, there appears to be no current adverseenviranmental impacts on the flora and fauna associated with theriver. Paver water quality is within the allowable freshwater aquaticlife ambient water quality criteria.

The potential for future adverse environmental impacts in the rivercannot be dig*--* ***- However, due to the length of tinv» that haspassed since the landfill stopped accepting waste (15 years) and thecurrent relatively low level of contaminants found in the groundwater,the potential for future impacts is less than would be expected from amore heavily contaminated site. In addition to potential futureadverse enviranmental impacts in the river due to an increase in theconcentration of hazardous compounds in the groundwater, the potentialexists for impacts on the river due to ammonia (NH_) and chemical

/ oxygen demand (COD) generated in the landfill.

Ammonia and ODD discharged to the river via groundwater couldpotentially exert an oxygen demand on the river that could adverselyaffect freshwater aquatic life. In addition, ammonia concentration inthe river due to groundwater discharge from the site could exceedacute and chronic freshwater aquatic criteria if ammonia production inthe landfill increases over existing levels.

The on-site pond contains a variety of fish and is used by Canadageese and other wildlife as a food and water source. Ambient waterquality in the on-site pond is currently within the allowable ambientfreshwater aquatic life ambient water quality criteria, and there areno apparent adverse environmental impacts to flora and faunaassociated with the pond.

As dJOTww* concerning the Mississinewa River, the potential forfuture adverse environmental impacts on the on-site pond cannot bejg/-?vTri«ad- Potential adverse environmental impacts on the on-sitepond would be from an increase in the concentration of hazardouscompounds in the groundwater and leachate over current levels.Potential future adverse environmental impacts may also be associatedwith the asphalt plant effluent due to the COD and inorganics in theeffluent if contaminant concentration in the effluent increase overcurrent levels.

Page 57: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 3July 31, 1987Page 3-1 of 39

SECTION 3

IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIES

In this section site problems are identified in terms of contaminatedmedia. Remedial action goals are established to address these siteproblems. General remedial response actions are identified to meet orexceed the remedial action goals. Within the general remedial re-sponse actions are specific remedial action technologies. Beforealternatives can be developed, remedial action technologies must besubjected to a preliminary screening based on specific site criteriato determine their applicability. The specific methodology includesidentifying:

o Remedial action goals based on contaminated media

o General response actions that meet the remedial action goals

o Possible remedial action technologies for each generalremedial response action, followed by screening to eliminateinapplicable technologies

3.1 REMEDIAL ACTION GOALS

The NCP states, "The appropriate extent of remedy shall be determinedby the lead agency's selection of a cost-effective remedial alterna-tive that effectively mitigates and minimizes threats to and providesadequate protection of public health and welfare and the environment"(40 CFR 300.68(i)). This is the general goal of all CERCXA feasi-bility studies. The risks that were identified at the site in thepublic health risk assessment (summarized in Section 2) establish thebasis for identifying site-specific goals for remedial measures. Thepublic health risk assessment identified either existing or potentialfuture unacceptable public health or environmental risks in thefollowing media:

o Soil/landfill contentso Groundwatero Leachate Seepso Surface water (On-Site Pond)

The following are specific remedial action goals for the contaminatedmedia listed above that reflect the general goal of the NCP. Thesegoals identify the exposure routes of concern and the specific areasof existing or potential hazards.

Page 58: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 3July 31, 1987Page 3-2 of 39

3.1.1 Soil and Landfill Contents

Ihe remedial action goal for soil and landfill contents is the ade-quate protection of the environment and public health from d*>rmai_absorption, and incidental ingestion of potentially hazardoussubstances due to unlimited access to the site by the local populationand by the users of the Eastside Cove recreational area.

3.1.2 Groundwater

The remedial action goal for groundwater is the adequate protection ofpublic health from inhalation of volatiles, dermal absorption, oringestion of potentially hazardous substances in the groundwaterextracted from the upper aquifer beneath the site. The groundwaterpassing through the landfill site discharges to the Mississinewa Riverwhich borders the site. The discharge of groundwater had nodetectable impact. The potential for future impact must be addressed.

3.1.3 Lsachate Seeps

The remedial action goal for the leachate seeps is the adequateprotection of environment and protection of public health from dermalabsorption or incidental ingestion of existing hazardous contaminantspresent in the leachate seeps.

3.1.4 Surface Water (On-Site Pond)

No current public health risks are associated with the on-site pond;however, the potential for future risks exists. Therefore, theremedial action goal for surface water is the adequate protection ofenvironment and public health from dermal absorption or incidentalingestion of water and consumption of fish from the pond frompotential future contaminants that may be detected in the on-site pond.

3.2 GENERAL REMEDIAL RESPONSE ACTIONS

General response actions are broad classes of responses intended tomeet the remedial action goals for the Marion/Bragg site. Severalgeneral response actions have been identified for each of thefollowing contaminated media: soil/landfill contents, groundwater,leachate seeps and surface water (on-site pond). Although generalresponse actions are separated to atVhrpfvS specific remedial actiongoals, a majority of these general response actions will work inconjunction with other general response actions to meet all of theremedial action goals. The general response actions identified foreach contaminated media with corresponding remedial action category ispresented in Table 3-1.

Page 59: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarioiVBragg Landfill SiteSection: 3July 31, 1987Page 3-3 of 39

TABLE 3-1

GENERAL RESPONSE ACTIONS

ContaminatedMedia

Soil/LandfillContents

Groundwater

Leachate Seep

Surface Water(Qn-sitePond)

General Response:ion

No ActionAccess Restrictions/MonitoringContainmentTreatmentIn-situ TreatmentRemoval Disposal

No ActionAccess Restrictions/MonitoringContainmentCollectionTreatmentIn-situ TreatmentDisposalAlternative Water Supply

No ActionContainmentCollectionTreatment tIn-situ TreatmentDisposal

No ActionAccess Restrictions/MonitoringContainmentTreatment

Page 60: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill siteSection: 3July 31, 1987Page 3-4 of 39

Within each general response action, available remedial action tech-nologies are presented in Table 3-2. For instance, capping andvertical barriers are two remedial action technologies for thecontainment general response action. In addition there may be severalcapping options such as clay, synthetic membrane liner, etc.

The remedial technologies that were determined to be applicable weresubjected to a preliminary screening. The screening criteria utilizedto evaluate the applicability of remedial technologies at theMarion/Bragg landfill site include:

o Site conditions and waste characteristicso Technology developmento Demonstrated performanceo Difficulty in implementation

Site conditions and waste characteristics that affect the choice ofremedial technologies are presented in Table 3-3.

The purpose of screening is to produce a condensed list of applicableremedial action technologies that may be suitable for source andmigration control of the contaminated media at the Marion/BraggLandfill site.

The results of screening of remedial action technologies are presentedin Table 3-4. Technologies that are considered applicable are given a"yes" rating under the column "Applicability. " Technologies that arescreened out (having a "no" rating) will not be carried forward forfurther analysis. A listing of Applicable Rampdial Technologies ispresented in Table 3-5. Technologies deemed applicable are discussedbelow under each general response action for each contaminated media.

3.4 DISCUSSION OF APPLICABLE REytE'pT&T. TECHNOLOGTE5

Applicable remedial technologies for each contaminated environmentalmedia are listed in Table 3-5. These technologies are consideredapplicable based on screening of technologies as presented in Table3-4. The following is a brief discussion of the technologiesconsidered for each environmental media.

3.4.1 Landfill

3.4.1.1 Access and Deed Restrictions

The purpose of access restriction is to prevent exposure of receptorsto contaminants by limiting receptor access to the landfill contents.The site is presently not fenced and therefore access to the site is

Page 61: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

•w >-* r»o €.f

'X at: r.j c_jra .o o rtj

en :> cj5 <t>

c± - *• iJci <.j cu»j o • - • •

iCO

Page 62: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

t1.1

t i ci u«i«- :r» f-f-10r-* i— ---> O>n rjc- ti.o -»t

m r»- i-f tU() t— • »- • lU dJ• — i j o r T- ro* - r» n o • o

(MUi n

u»r» i

rir •cj

Page 63: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

OJI i

1*1"I-f 1

1r.i

n mM :-t>l> • *: > i

Page 64: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

toI

oo

- •1 ri

•— •

n* fi i : pi ex. iJ- «•-» ri

CV. ID •---H

^ C"^J --< «_•in O' 'i itiiu -i i|i «rar*- ti- PJ -ib O »"t pjlU ra D CJ.

m . - « - ! •

Page 65: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

tn t:t «z»

»- i.*> ex. o- o »•• • no I— «iu rt«

•ri —

i"'- im

Page 66: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

I 1

tr* IL ;•*

il\l(V

Cl C3 (T-

C|J -- t»J ttt

Im

Page 67: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 3JUly 31, 1987Page 3-11 of 39

TABLE 3-3

SITE CONDITIONS AND WASTE CHARACTERISTICS

Site Conditions

1) 72 acres (large size)

2) Relief - 790-825 ft MSL (surface of landfill)

3) 15 acre on-site pond with an average depth of 10 feet

4) Leachate seeps - One lechate seep flows into the on-site pondand a second leachate seep discharges from the landfill andflows toward the property south of the site.

5) Volume of fill estimated at 1.1 million cubic yards

6) Highly permeable fill cover

7) Depth to confining layer averages 35 feet

8) Exposed fill in some areas

9) Mississinewa River bordering the site

10) Unlimited access

11) Groundwater discharges to Mississinewa River

12) Northern half of site is in flood plain

1) Unknown quantity of hazardous substances

2) Fill materials are mixed with scrap metal, plastic, wood, etc.

3) Sludge Ttn'wd with waste

4) Low to moderate level of organics present in fill material

5) Depth to water table of 1 to 35 feet below ground surface

6) Low level of organics and inorganics present in groundwater

Page 68: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 3-*SCREENINS OF AVAILABLE REMEDIAL TECKNGL33IES

ENVIRC5&EN7AL 2E1EI1AL•EDIft ACTION

IrCNSt AVAILABLE REMEDIAL AF'LICaElLI'Y CMNESTS

So A c t i o n Sens

'"U'TTL'TEL-WI* i wrf i j

Access res t r ic t ion/ Deed Res t r ic t ionslorr.torir-g

Site Fencing

Revscetat ion

soil Cavar

ri -nT . Uw

Yes

Yes

Monitoring Surface Rw-GH Yes

Surface Controls:

Grading Yes

Yss

Yes

Yes

Capping:Synthe t ic (festrane L iner Nc

The National Contingency Plan retires the NcAction alternative to be carried throuci to data:ledanalysis of alternatives.

Nculd be effective in preys-tin; er^osu'a to landfillcontacts ty placing rsst'ictior.s on the use of theproperty.

tlou'.d be effective in preventing exposure to landfillmaterials by restricting access to the site.

Effective in sen:taring contisinatior, levels reich>rc,the flississir.etia Siver. Used in conjunction *ith deedrestrictions ir.d/or site fencing.

Effective. Required to reshape surface contours tosanage surface water and prevent erosion.

Effective. Required to stabilize surface soils froserosion.

Effective. Required for establishing vegetative coverand to ciniiize surface infiltration.

Effective. Required to p-ctect the sita fro« the100 year flood.

Not considered practical as a sole lir.ar. Must beused in conjunction with ether lir.ers as Kith a•ultiaedia cap discussed belon.

Clav

Asphalt

f!ult iaedii

Yes Has proven d u r a b i l i t y , lott aainter.ance, andself-sealing capabil i t ies.

Ho Susceptible to neither nig and phctodegradat icn .

Yes Has been proven ef fec t ive in e i n i a i z i n i i n f i l t r a t i iand leachats ganerat ioa. I fa i t i i le layers increasesecur i ty of cap.

3-12

Page 69: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

U>I

c-j i—CJ » Ul3 g i:lm -o r—

o

F 40

fu

o-MJ

"

iO

Ul

r»n-*»

*-.«n

rp

rur»-

-, r

ul

IO

KB

r*1

~r

ro

-4»r>

x

ri-ru

•-»-r*-

ID

T•013

CJ-4-.

O

IO

*vUJ

1...Illr f-

ru

p

fi

oIO

r*7.

tXc:n>

o

--.^_rp

fc».

••<U

O"a*

ro

Ul

rom

CJri

».-*ru

-« ^>

D -CJ

ro ••••r> -^*•*• rpo3 -*•>

ro-O

n)rJr*-

y»r»

tn

c>ro

-iru

1 1

-1-1O

o

•-«r*-ro

n

VI

tu"<

raLX

-K

Ct

r*-O

VIroo>»•-'

ro

n

CX HI

-4» -I*

ri ric: nr»- rf

r*- r*-0 CJ

° "*-• ftk

O ft*

ro A*

,-. ru

O

rioer

ex.

^,rorx

rO

a

rariroCX

CJ

(MCl-

1-1IP

Ulnj

l-lID

Ul

CXc

id

Uli-t-**-

t-t-CJ

r-

CX

„^

c:^^.

rt-O

K

crrua*

0ro

exnO

ric:

-^c"

0:1u

ex.41f<-ro

LIX

CJc:0:1ir

U"fO

0-

rir »L:rx

crro

inrot X

. i-o

m

o

•on>

Ul

0

-f*

••*»10!-»-

CJ*f-t-

n)

<**r i

*UrtCJ7)

a*—rIP

CJX

nonmCJ"

rt-

a*

CJ:LJ

ro

exroTl

~*"

Ul

r*OciUl

ex

ro

-eia*ri••• •1"!

rir:ru

O

;r

Ulrorlroo-*.

-o a.r> -*Cn roTO riUl i*-Ul

*-. ^Ul 111

'1 UlO roM 0'ft* »--C) ••-~J .~J

-> rac:

o • —r-*- r «-

i rori mro •

(tj ro*•— rr.

r 4*--< ro?-* |£X «T-

iiiUl

•ort-

rj-

ro

o

iOIO

IU1

rr-IW

Ult «-

It)111MlIO

Jt

ri

c:

r >-ru

-ir IriroUl

«...

hitlO11

r*r>CJ-1~r1riro

rsex

P>fU

wU>

1 1-inu>«otw

jrt

roin

-n

rO1 4ro

1rV

M

tnUlrin>VJ

t?*to

o

>Dr*iO

1

rw1C

•oI/IUlroul

JtU"¥"••

ri•rcrrf

ro

ftCJ)

rjcMl

CO

:•« mi»i -an

mncrn

**" coco mr—tn 1,4... !

Ml

Page 70: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TAELE 3-«Or AVAILABLE REMEDIAL 'ECHML39IE3

ESVIRGMENTfiL REMEDIAL RESPONSE AVAILABLE REMEDIALKEDIA ACTION TECHHDLDSY

aPF-LIC'SI'-ITY CuflfOTS

SOIL/LANDFILLCONTESTS

Treataar.t

I n j e c t i o n G r o u t i n g

Solvsrt E x t r a c t i o n

No I n t e g r i t y of barrier is quest ionable andins ta l l a t ion couij prove d i f f icu l t due ta high»iter t i b i a . Presence of io« peraeab i l i tyc o n T i r ; ^ ? l a y e r at the sits l i a i t s the nsad forhcn:tntal carr iers .

No Nc*. con;:der»c aopi icsb la because the pnys ica l na ture ofthe l a n d f i l l saterials Mould pose h a n d l i n g problets.la.-or ascava t ion and large co«ao3tino area requi red .

.';: Has net bcEr, dsio'stratsc on a larc? scale a p p l i c a tL> level of contiai iants present at the sits do not—'^ir 'ast cons ids ra t io f i cf this technology.

No Elect ive con tac t w i t h xasta »ater:als would bed i f f i c u l t to obtain.

nerat ion

Thernl Baser-action:«et Sir Oxidation

Rctarv Kiin

No

No

Yes

N:

Ko

Not oppi:cabi? tc the aixsri waste prssant at the site.a?ts 31..SS*i ocy 2^ -.idzsr uous.sc .i

Lisited to liquid wastes and si-ad^ss.

Ash by-product would contain heavy letals andinorganics. Landfill saterials would posa si:ereduction problass. Transportable units are available.VGluaa o-1 fill present at the sita will require a5igr.i-';cant nusbar of years for thenal destruction.

Not applicible to sixad wastes. Landfill satarialsxouid pose si:e reduction prob'.eas.

Not applicable to tixed wastes. Lar.dfill taterialswojld :ose size reduction proc!e»s. Poor sixing ofxastes say inhibit complete coibustion.

Is effective treatsent for organic coapouiids but notapplicable to heavy aetals and inorganic caspour.ds.Landfill tatariiis would ?asa si:e reduction probiets.

3-14

Page 71: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 3-4SCREEN INS OF AVAILABLE SEKSIflL TECHX2L36IE

Euv:R"«".E!ITftL r.Er-E:!^ RESPONSE AVAILABLE F*tD!A ACTION "CKNOLOSY

EG ILi1 TrgitsantLnND"LLCSKTENT3

Jloltan Salt Reactcr No Still in crelimarv stscas ::satsrials would pose sire reaua deionstra'.ed tachnslosy.

* ' a y 2 =

•:t:on :r:t;:?as. Sat

riissa Arc No Not proper, or, lir;s ica'.s s:cli:i

In Situ Trsataent SicroDiai De^'adation Di-f-icult to ti» nut'ir-ts ard sicrobsa in-sit1:. Set aprsver, technology -for variety c* ccr.taair.ar.'.sfound at the sits.

Cheiical Dstoxirication No Not p'oven in-situ. Produ;'. rssair.i i-, j'OLnflnatsr.Very difficult to ear. i '.or s.sing cf 'eactaats andoverall sf-fsctivsress.

Soil fteraticn Contact x i th site waste «iuld be d i r - f i c d t ts c b t a i nSU8 .0 u9pwn 0* 1 1" ** \ '. ; C OH „ 8" fc S 8 *C£92 I "C *.« T99t

in sose locations.

Vitrification No Not considered practical due to sits assta voluss.

uas ^esn dssoMStriir^. .0 .9 S'TrC.ivs or«iy ^o a c?Ct.riof 15 feet. Has net bssr. iescnstrited in laresscale application.

Si:k.arvestir.g

Sot £T-sc» iv3 for crccr .LC cospcunuS. -".t-icuit ^o apo.yto tisad wastes, iiast; a-tsr f isat isn still reauiras•furts&r dispcssl. U-t-issIicibls -fcr laRaf i ' l .

Set considers;! as a sracti:al t raatsant 3'sia to the laraevcluse o-f wastes and ths larce site arsi.

Air/Oxygen Injection No NO*. COn 31 w8f?d I'a & p

voluae s-f aastas ire tfta ia-cs si:? a'=i.

3-15

Page 72: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

T.S

COri— t

ill

t'l

encr»..jCT5

inCU —.

-(- CZ-*-• O

n i<il u n,:i ci • --«in «n «H~

i~ cr(J en

•—• cu a*

cu m ttZ.\, m u-*-» ne

01 '0 1C*^ »•• curd l^rt *u -,** uk, n»O rt CU

*-*- Ul

ni '-•... - -• cu-» M- jz

.i: 's "i=J\3 O

CU -r-« C~

01 **t- '-*o a* ni

x: --t na ^-»

ni - . -« -*jj»- li O ClH- in *r .*-j

I CO

in eni c.i-»- a;

Page 73: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 3-4SKEENIN8 Or AVAILABLE FlEKEDIAL TECHNOLOGIES

ENVIRONMENTAL RESEIiSAl RESPONSE AVAILABLE REC.EDiAL«E2IA ACTION TECHNOLOGY

ArrLICASILITY COGENT;

EROUNDKfiTEF. No Act::n Scne

Access Restriction/ Deed Restricticns

Site Fencing

•Srcunc'Kiter Hcnitcrirg

ves

re?

Yes

Capping 'Isolates qrourdwaterfrci infiltration throughlandfill':

Svr.thstic desirine Liner No

Ciav

Asphalt

Multimedia

Csr.crets

Yes

No

Yes

No

Chesical Sealant/Stabiliier Ho

The National Ccc.tLnceacy Plan recLires the NoAction alternative to be carried through to detailedanalysis o^ alternatives.

Would be effective in preventing installation of watersupply nel:s within the site by placing restrictionson t?e use o* the property.

Xcjld be an elective «eins c< preventing tampering withon-site grcundnater sonitoring wells.

•Ves ••Effective if. ?cr:tcring ccntasinition levels.

Not considered practical as a sole liner. Must beused in conjunction with other liners as with alultitedia cap discussed below.

Has proven durability, low lainter.ance, andseH-sealinc. capabilities.

Susceptible to weathering and photodegradation.photcdegradation.

Has been proven effective in liniiizing infiltrationand leachate generation. Hultipla layers iiprovesecurity of.cap.

Susceptible to frse:e-thaw stresses which ultimatelyaffect its sealing qualities. Free:e-thaw processis coeaon in north-central Indiana.

Susceptible to free:e-thaw stresses ahich ulti*ately.affect its sealing qualities. F'ee:e-thaw processis ccucn IP. north-central Indiana.

3-17

Page 74: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TfiBLE 3-<SCREEVINS OF AWtLABLc REHEDIOL 7ECHNOLC5IES

EMdL "E"t!;:AL RESPONSE AWIMLE REMEDIAL CCNHENTS

Vertical Barriers:Eltrrv M

Vibrating Bea»

Srsut ~ u r t a : n

Sheet Hetai Pi Una

H o r i z o n t a l Ba r r i e r s :Slack Dispiaceaent

Injection s rou t in j

5 r=iient Controls:Barr ie r iiells

Yes

So

No

Nc

Is :3rs:d9r?d practical because a confininglayer :s present at a depth of 30-40 feet•n:c*i could be used to tey the slurry «all into.Prevents jrounc»at9'' aigration into the lard-iiL.

Difricuit to ijintain beaa aiignier.t andcontinuity O'f adjacent segaents duringinstallatic".

Difficult to fora a reliable cootinous barrier anddifficult to sonitjr integrity of installed aarrier. "

Intericcks aay be difficult to ?eai, leai.aoe sat occur.Requiras frequent iairitenanca tc ensure corrosionprctection.

integrity of barrier is difficult to ven-y andinstallation could prove difficult due to highwater tabls. Lo* peraeability confining layeris present at the site wiucii acts as abarrier fcr vertical titjration of contaainjnts.

Integrity of barrier is difficult to verity andinstallation could prcve difficult due to high»ater table. Lc« perseability confining layeris present li the site which acts as a

fo^ -verticil-aigraticr of contatinants.

No D i f f i c u l t t o s i g n i f i c a n t l y lower q r o u n d n a t e r t a t i e dueto the Rississir.ew Rive'' located adjacent to the sits.

3-18

Page 75: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

'ArLE 3-*CrEESiNS GF AVAILABLE REMEDIAL TECHS3L3SIES

EnVIRGMENTAL REMEDIAL RE:r":iK2IA ACTICN

APPLICABILITY CGIUENTE

6RCUNDWTER Collection

Treatment

Extraction Hells

French Dnins

Biological Treatment:Activated Sludge

Tricuir-s Filter

Rotating 5iolc:ica;Csr.tacio-

A^ratad Lascans

Physical/Cheaical Treatsent

Yes Considered practical due to presence of 'jccer aquiferand peroeable soils.

No Construction say be difficult due to depthreouired to interceot trie f i l l ind trie upcar aquifer.

No Not considered feasible due to relatively lowconcentrations of arganics which would ispactoperation of biological systes.

No Not considered feasible due to relatively lowloncar.tratiar.s of orgar.ics which nodi iapactcps'ation of biological syste«,

No Not considered feasible due to relatively lowconcentrations of organic: which would i::actoperation a- biological systsa.

So Sot considered feasible due to relatively lowconcentrations of orgar.ics which would iapactoperation of biological systes.

Sot applicable since grour.dwtar slraady ".as aneutral pH.

Not known to fca.effective on sised cor,tj5i"=r,ts ingroundwater.

Osidation/Rsductior, So Sot applicable for low levels of organcontasinants found in grcandwatar.

3-19

Page 76: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Myo

rnirj~ocu*r.*,r>IT1

.fl^ijrn

0r>rn

•o

Ul 10 inr~in c^j

IDft-AftUUl

rorp

•Prt*

ip

ri;>cx

*• r.Cl

TOIO

rp

Ulru

ft*t j.

O

'fu

1 1

^-.

.-*-

0)

Ul

ni

":ui<v

IVCMrt-wror-f

IW

Ul

cxro

s.n>

IS

r)~

rionMl

•P

IUCX

.--.rii.rruLI.e:ru

f*-O

IVul

L>±1M'•— •

XillIK

-I"

rirlIUinUl

ra

tp

illIS

f,*CJ

r-f-O

n

ronrp

OJ*

-rtri

•Ll

Cl

CJ

u

ill

X

initf

-io1-cxtv»

*

l%:.-;•

cxtTl

I-- "1=1 OO t:~i ^ill LJ,

=; ?;ri mV1 I"1

t_iCJ

Ul

::*Cl

roc)rp

O"3I

Cl

«-*-

«'MU

.•£.

*'*•

iO

ID0

t-rO1 .

i_l

O

»-*

Cl

a*

mUl

-iminIU

-n B*-t r.)o exft

^ oo -1

$• ?m riar ?•rn-i-.i-.

»arir*

rt-i

ro*oft*

o

SCl

'->Oc:CX.X

r**roP

oro

Cl

ip

ro

~lO

JTrp0-1

ULl

.•C.tl

ro

IP

<'IP-»,

O

k*'

IU

IP

Cl

u••--

in

ro

rta

Ul Cl r«-

ui ru a>

ru P<-», oro --

cnIPro

>\j -c-T ui -.» C) rw r r-

o.I/I

O

23CJ*. O

XJ i*JIV OL»

tu nri uiro*t- ri

ci.r*-1 uiIP Cl

*P »P

ro iu U' -*-« • i » ' IP

• - CJ 10 ft*

O l_l CX

ui rp MJo •- cx

(M UlI *•10 orx -**x oui *n«**• IPro riin n"T ri*v ciB> -jUl II*

Page 77: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 3-4< 5-SEEOS Gr AVAILABLE SERIAL TECHVCLjSIES

^ E H E D ^ L RE;ruN5£ • A V f i - L f t B L E R E M E D I A L A«LIMEIL!TY CCMEN'EH C T ! J N TECHSGLCSYTre»t?.er.t Break po in t f ie Requi res ccasler. cparit:" an: no-l id r a o u i r e

w.tloririikicn dec- i ;o r inavicn .0 rescvs r ? s i ^ u a ^ 2;-c?Sa chorine.

Spray Eviporaticr, No Set cpps:ders!i i p p l i c i b - s dua to regioni! weathertrends because treatsent -"ails under adverseweather ccr.ditior,;. R e l a j s e j v s i a t i i e or;anics i-toths at*03?hs ra.

!r s i t u Treataent f l i c rabs i l Oeoradaticn »io C i - f t i c u l t to cix autner.ts and t icrcbes i n - s i t u . Sat aproven technology -for v a r i e t y of c j r t a s inan t sfourd A\. .he sitCi ^ecuires . r^a^sci .!^/ StUSy.u i r f i c a l t t o sa i r . t a in c o R c i t i c r i S fo r e '^sc t iv?s i c r s b i a l setacciis;..

Liaestone Treat tent 8?

A c t i v a t e d Car icn red

No E f f e c t i v e or.iy for a c i d i c cor .s t i tuents and r.otaopl icabie fo r o r g a n i c co*pouads. E j r f a c e o i r .d inq ,a k c g i n g , ar.d c h a n n e h n q l i a i t ef-'e:tiveness.

So Set su i t ab l e far s i red was t s charac tar i : t ics . Not prove"ir.-situ. "ha-ne i inq ar.c p l ' j c g i r o say occur , C a r b c nbed lust be rescved to srever.t f u t u r e releaseof adscroed oroan ics .

Disposal

Cheaicai Treitsent

Deep Hell Injection No

Not proven in-sita. Product -esains in grounCnatar.Very difficult to aor.itor aixing of reactants andoverall effectiveness.

Loxer lisestone aquifer :s used ss a possible »ater.scurce. .Difficult,.to cbtair, .-.ecessary osrsitswje bO envircTiaen*al cor.cer".

3ff -Si te :P u b l i c l y OwnedTreitaent Xorrs

f>CRfi Fac i l i ty

A l t e r n a t i v e Hater Bottled HaterS u p p l y

Tie Is To Bur.icipa:Nater Systs*

Yes Eft'ective, peraanent trsatasrt is provided, ftjirovaifros FuTK required prior to d:scf-.arce.

Yes Effective, peraaner.t trsatssnt is providsd.

No hot applicable because residential neiis are notcontaninated and are -ot a; risk.

Ho Host residential areas around site 3'? -ressr.t'.y tiedto the aunicipai niter s^polv svstas. :.esidert:ai areanet served by su-icioal aater systss ire usondien: orou; of the :one of irifluerce :• !;rovr,d»ater.

3-21

Page 78: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TfiBLE 3-4•GREENING 2F A'.'AILASIE SERIAL TECHNOL2SIES

REC.E3IAL SE-P3SSE AVAi-AELE FE*ED!AlACTICN TECHNOLC3Y

rnmicureMW< J l lw l* I W

LEACr'flTE No Act ic r ,

Containeen:

Scr.s

:iav

Kultioeiia

Ve; The HatiMil Cor,tin;en:y Flan requires the NsAction iiterr.ative t: be carried thresh ts detailaiinalysis d alternatives.

V«s His prove- durability, Ion saiatsnar.ee, and seH-sea!:«5 capabilities. Car. sair.tain the laichate tsrer.ain within the Sar.d-ill.

Yss Has beer proven elective. Rjltiple layers increasesec-j*ity of cap. Can laintain the leachate to rjiain

Treataeat

Estracticn «all

French DrainPialigicii Treattsnt:

Activated Eludes

Trickling 'iltsr

Rotating Biological.Contactor

Aerated Lagoons

Yes Effective, proven aethod cf collecting leachate.

Yes Effective, proven ssthod of collecting Isachsta.

No Not considered feasible due to relatively ssallvoluae of ieach.ate and low concentrations of organicswhich would ispact the operation cf the biologicalsystea.

No Net considered feasible due to relatively saallvcluee of leachate and law concentrations of organicswhich would iapact the operation of the biologicalsystec.

No Not considered feasible due to relatively ssall.voluae.of.leachate and low .concentrations of organicswhich would iapact the operation of the biolo;ic=lsystet.

Ho Net considered feasible due to relatively ssal!vcluse of leachate and low concentrations cf organicsnhich would iapact the operation cf the biologicalsvstee.

3-22

Page 79: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 3-4E^EEWB OF AVAILABLE SEHEDIftL TtCHNC-LSSIEa

ENVIRONMENTAL 3EKE2IHL REEP3NSE AVAILftELE nESEDIAL ArPLiCAKLrV < CIWENTSXEDIA ACTION TECHNCLG3V

LEACKATE Treatsent ?hv;:caL/Chsai:i! Trsitzer.t:EEE? Dechlorinaticr. No tei Vrcwn to bs ettectiva on «is8d eontiai«ints prsser.t

in the leachats.

Dsidation/Seducticn So Not applicable »or low lavels or organic contaeir.arts.

Solvent Extraction Ho Cotitac: »ith sits *aste ncuid be difricuit to obtiir,(soil KasSir.g; due to depth ot land-fill ccrterts exceeding 25 feet

in soae locations, ccivsrt cculd becoie a ccntaair.ant.

Coaqulatisn/Seciaentation toyfce Er'tectiv? in rsseval 3t suspended ar,d colloidal inorqanics•arc "sstal'pracipitatss resulting frca cheaicai treatof laachats. Lots levels OT aetals present aay lisit-—'applicability.

Filtration Yes Elective -for the resoval z* suspended sclids.

Carbon Adsorp'.icr, Yes Reaoves a variety or organics and so*e inorganics.Proven, elective, ar-d ps'sinent treataent.

Activated Aluaina No Sot an applicable treataent technology for organiccc-ispounds. Proven affective -for resoving arsenic in labBenerates concentrated waste requiring furtherdisposal.

Reverse Gsncsis So Sot applicable fcr aiaed organic wastes, outrasoves aetals effectively. Concentrated brinesrequire further disposal.

Liquid/Liquid Extraction No Not proven on aixed waste. Requires processdeveiopsent prior to iioleser.Ution.

3-23

Page 80: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 3-4SCREESINS 0' AVAILABLE REMEDIAL TECKSCIGSIES

FEEPGNEE ;*AiLfi3LE REMEDIALTECKNCLS6Y

APPLICABILITY C01SEHTS

LEACKATE In Si tu Treatment Sic'cbial Deoradation Kc

Cheiical ?e:oxificat::n Nc

Difficult to aix nut'ients ird sicrofces in-situ. Not aprovsR tschnolojy Jcr variety o; c:r,taairintsour.i! at the sits. Difficult ts sii-tain corditicr.sfor effective aicroSial do

Not proves n-sita. r'-oriuct reaains in srcand. VarydifficLl: to asnitor ii»ing of reattants and overalleffectiveness.

F.eeoval/Dispcsai

Lisestcns Treatas-t-Bed

Activated CarbonBed

Cn-Ssts:Deep Well Injection

Off-Site:Publicly OunedTreataer.t tlorks

RCRA Facilitv

No Effective only for acidic constituents ar.d rotapplicable-for arjanic-cospour.ds. Efface biniinqpluggi-g and chanreling lisits sffectivenass.

Kc Net suitabla for lined waste characteristics. Netproven in-situ. Carbon bed aust be reaoved toprevent future release of absc-bed organcs.

No Leschite rectires treataent prior to injectioninto layer liaestone aquifer nhich i- used is a ttatersource. Feraittir.g ar,d approval-is questionablebecause of enrircnsental concern,

Yes Effective, peraar.ent trsataert.

Yes Effective, peraanent treatssr.t.

3-24

Page 81: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

-n £

y ;I

u>iro

-1,1s.

LI mri. •<

n>

W

O

LIriSi rx

x

U

ID-ir*-

OriCl

r*-rptr

ri

Ul

ru

ririri

rt-•1O*

O

Ul

O-*-.

n

riUl

xrrn

acc>*.-*CX

turi!-*•

O

ri

3CX

-ilUCX

ID

U>cr

exn>rrCl

fO

(Ur*"

IU

X

0

ro-iPJ

Cl

0

rwcr

0

O

n

Ul

Ul#-»•n>

ric>rino

Oi

ClnUl

0

II

or*

ri

ri

Xot:

U-

Tlruor»-

O

Cl

inCXm

CX

roft*Ul

trroCXc:ror-*-C1

roO->

ru

X

0

10-1•-«-Cl110

•_rni

»-*.r>

ri

Ul

uimEl

riCl

rir»-iu>r*-

C>ri

o'»-.o

ZJ

ri

X

IT'

XCl

CX

-rirwr*r*-

c>rt-

O

inrX

IDCX

•-*•.idD'ini rHi

CX

mrt-O

-1ru

rf

ni

uX.

ru co?i (U

111 TT-

„,. ..

|M t.j.

LX rr-*-.... -rj

••-• m»-- -iirk m

CX » —ro m

Ml

CX

CX

tii-i

m—

1 11

.-»-

ro

kfe0U

r 1ri

Ll

CW

o

*on)

'

riCl

ri

K

oCX

X

r*-m

cr

ro

—in

o*rn

Ul

ar:o

iD

US

ro

n>1 1

B*ro

Ul

-o

iD

r*-

rJ0.1

ro-ci

Ift*

-I

ri

nriUl

i;ii)Hi

CJ

fO

Tl

o

tlr-

IU

-t.

i V

ID

rut-t-

ukn>

Cl

c:

rlo

«u X>r» nOf f-»-

--* oUl 31

«n *"o •-*•-M 10

«•*" 1 *•ro •"•

=1 ID

»-'• rj

fO CJ-ui "t>

riIw

roEX

rrO

utx

rbitfM

»•'•

CJ

Cl

Ipo

•*

roi-

n>vi

•r

Cl

Page 82: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

,'l'lr

'i

J'

J1

i4

' ' ' ' t

• .i1 f•ir

('i.1

V

iftr• i

.'i

t

_..

'»'1*J',•

•'•I' '^!$

1 1 '

•!{II, fllK't

<r*i

en1*1CMC 1

C)ur.3t(.»litt—

..J•t:caUJM;UJ

•*• ocro L.J_ iuj m— J <r

**" 5<c

fecuK»- «ariiiUJ

( jOl

,

CJJI--;/:UJ»_wrC-lI,)

»—^, 1*•-*

«*•CI

_lr*ft<c

. j<i:»— <(TlUJm;UJlfr >-UJ Cfl

S ri

1> Ul*.T: ».-

UJUJ

CJ

foUJff._ J<c— • zr.U C3L»l •— «K; »—Ul CJur <gr

_j«jct —>•.Uljr.iirUJc*-: «Tt*- ' *-•*I> C «;*•: ujIjl K

m•»•*c~•nC-:

«•n>

C-

5^LJ

'sL!'a

c>inaicu

Xo. — 1

k.0

»—

+-*u'«i-CJ

(J"or.

oj=

r:C3

•F-l

-»J

*0•o•»*JS

k-

-1ai:K

t-OJfi

-*-*rt»OJk..

I-- •

r»i{•-'UJCJ«Jt.ll.t*:^iCil

in

01

SIin

*•nmX

cu-*-'

k ..* jr:cu1 1C-ni.*k,-o

ticu

:"-

k'0ni .ci.

«jiSo.UJ»...en:

CJ

s« »«u rC3 4-1J C131 ck. •o *L; «,* ci

r«ta _

f> ci « ._

CJ <tj .(

I-r»is J

V•*J »ai-a tii .;rj- .Ml -:.tin

M-O

11 -*.

0 -»f •o<I.. •fc_(.1

*l •OJ r~

-** C1 J fni

»*- *t»*- <t*l "

CU^^/•

M'.'

UO

.4.JMl

£«•

TC.leu<n

o.i j<•:Sr»*»uo

C.J

Tcz

J •-.*

u ^->fl cr• IU

D ini a*i

-» •»-•1 O>

LJ «•

J **-O

B

C-- 0

- M»* k_

-4-Jc:a*t,.*<•:c-jt.i

i XCJ- «

k ._cu"

0 -i.'j niu *a

-11j tr; o» n

,.*->

.^t-*;

0.

*«•» 'fl

••nraa*r»»cr*iiit~tt

r"1

k.0*rx.• n

-*-"L.«4O.

*0

lA

CU>«J

»13

•*-O

AiuC:OlUlOik.CA.

OJ^=-*-J

OA J

OJ-J

•«J-<acuk.

15< 1-OJ

iir

cu-M.rtf

M.:

ezO-*j*<k.

U.

in•n

Ul

•ocu1.T

CU11.id:.iin

ui-^

^q

CJin

"(3

'O

U

nli.CJ

o

.§-•

k-'m

**

CJ*3°!(»:"

i»iOJ

c;o-*jra-k_t»i«-o*xcro

_t Jk.f*

C.J

-* *

c:cuCi

.*-"•

OJe~

at

cr

^

>-*-*

tu

trOJ

nCt~

i»crof\~o

CJ

t"nlLI!'C3

«ircuc

•4..1mtu

-*-*cu

u. — iCi-

rri'

»J

t II^

• at;•bra

-•aT3aifU

^jLJ

-X

IM-*-*mOJ

r0, — t

oSin"t"

Of

oM-

j^

LJOJ

a*cr

O

Ck-

*4inoCJ.Ul

13kcu

^_

^f

k.

cVcu

inOl

tiX

cu-*-'11i .r:t.jcrutn4J

^.-'• tfk_atCLfU

CiJ

in

feTTUl

•r-4M

-<;

*aim

o

cu

'0

"_ICT.U.rfl

Mt

C*3^

CUOnc::•n*=.uK

IU

c:o

UlOl

"«»

cro*CO

KcrCf«k.a«=

CJoUl

0

k.o

Ol

L ICU

cuTJcrtt

m

•ntJ

Oi

i»«-

cr

3C-Tcui-l"at

w

Dl

rd

•*•-'ii*-•oL J

11^J

incu

•*-*Ul

*

'0

n

OJ

^_CJ

cu_omu

'o-CJL

o

CJye.

Ul

inouin

CJ

OJinUCU>Oi

ty.

0*

"VIk.^•*crcuLJ

OuinCU

^_

"*•»-*

itCu

•-i

LO

H -•OJ41

mat

riti_

Br*-<

inoa.

11k.cu

•f

e*»c:

:Ja<

in01

Ul

»

inCJ

•*•* crt.: *nat c/iUl k-r» cin. aiUl "

! j "ont >

--» ic'J <r> ci

e:fi 0-

in O

"cu cuOJ

"^ 0x c:O

r- I UlCUk- p• n

OJ \~ »> a- —-,-, -4-J C4

CJ » T01

»»-. c: er-OJ O ••••<

ci c crsr: -. *u

o

tJ*i=CA.IT,

W-*JCO

<c

inCJ

.*•» crOl IT*VI l ,OJ (j

n. ojui rOJ -*-•

•4* 'tl^ >

O CZ^ O

o euUl O

*(|i Ol

01

ic crciOJ

k. O

OJ l ..:<• CU

^J nlU JTai•i- '*:•*•-• c:oi n

C C

O cJJC .^4

c^3=

tr>crcuu-k-

OJ

•1tlMl

CJ)

inl-l

rdW

ac:

c.rrt

-4-*r:cuwti.oOJ•tott»o

OJ

ntX

•CJ

oen-en

ai

*•*-oaiKiar:oenaiO

CO.

+•*sr

oar

crC.1.ft

•*•*um»™.*jM

UJ

^O

tlcrH"it^'=JtJ*..J

B

0*k_

crOl1 •

Ul• ••*

cn

J^eucurj-u

0

o

Ll

vOegI

Page 83: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 3-4SCREENS OF AVAILABLE REMEDIAL TECHNOLOGIES

EHViRCS^ENTAL RE*E"<IAL REiFONsE AVAILABLE SEflESIALSEJIfl ACilCN TE'KNCLOSY

APPLICABILITY

SuSFftCE HATE» Traattenti^-sITE PONC;

::ar tvaaoraticn

Spray Evaporation

Reacval/Disposal On-Site:Deep Hail Inject::

Off-Si ts :P u b l i c l y 0»r9dTrsateer.t *;rks

RCHA F a c i l i t y

So Nst considered applicable due to regional weathertrends. Fai ls under adverss xeather c:nditicr.s. nsleasesvolat i le organics in to atssspfcera.

No Not considered a p p l i c a b l e due to r eg iona l weat^srtrends. Fai ls u'.der adverse mea t ie r cond i t ions . Releasesvola t i le crganics ir.to ateosphere.

No Lsxer lisestor.e a^ui-e*' is used a:- a pcss ible wate r

scurca. D i f f i c u l t t: cbtair. necessary persitsdue t: envira- jenta i csncjrn.

No E f f e c t i v e , persansr.t t res taer t is p r o v i d e d , hanever ,l a rge vsluee :f stater present :n pond stay lis:t the useof ?OT« for treatsant.

No E f f e c t i v e , parsar.ent trsataent is o r o v i d e d . However,large vol-se of water p'esent :r. por.d say restrictthe use of RCP.A f a c i l i t y for treatseflt.

3-27

Page 84: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TASLi 3-5

?FSL'CABLE FEHEOIftL TECKNOLOSIE3

ENVIPCSHESTflL HECIA REMEDIAL RE5?OSSE flCTIBN AFFLICASLE REflEI-IAL TECKNOL06Y

SCIL/Lfl«F!LLCONTENTS

No Action

flccess Restriciicns/Isnitoring

Contiincent

irsatssnt

al/Disposal

More

Deed RestrictionsSite FencingHanitcring Surface Run-Oft

Surface Control =:endingRevesetat ionSoil CoverFlood Control

Capping:Clay

Vertical Barrier:Slurry Hall

Theraal Destruction:Rotary Kiin

Gffsite:RCRA LandfillRCRA Incineration Facility

3-28

Page 85: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

tJWISSMENTAL HEB!A

TfiELE 3-5

AFFLICA9LE REMEDIAL TECHNQLD6IES

REMEDIAL RESPONSE ACTION APPLICR3LE REMEDIAL TECHNOLQSY

SSQ'JNDMTERSo Action

Access Restrictions/Monitoring

Contiinaent

Collection

Treatier.t

Disqosii

None

Deed RestrictionsSits FencingSrourdwter Monitoring

Capping:CliyHultiaedia

Verticil Sarrier:Slurry Kill

Er.trjction Hells

Fhysic»l/C!ietical Treataent:Coiqu! at: on/Bed nent at ionFiltrationCarbon AbsorptionAir stripping laieonia reaovil)

Publicly 0»ne!! Treiteent WorksRCRA Facility

3-29

Page 86: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

EKV'RGHKENTftL 1EDIA

TABLE 3-5

AFPLICflBLE REMEDIAL TECHNOLOGIES

REMEDIAL RESPONSE ftCTIOS flcPLICABLE REMEDIAL TECHNOL06Y

LEACKA7E SEES No Action

Containment

Collection

Trsataer.t

Reacvai/Dispcsal

None

Capping:Cl»y

Extracts en MeiiFrench Drain

Physical /Chssical Treatesr.t:CsagalatioR/SedJaer.tatisnFil tuitionCarbsn flbscrption

CH-Site:BPCA r«- i T : »./i\u<vH ^ dwi A i ^yPublic Consd Treitseat Facility

3-30

Page 87: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TfiBlE 3-5

APrL!:«LE RENEWAL TECHNOLQSiES

ENVIRGM-NTAL HEDIA SERIAL RESPONSE ACTI2N APPLICABLE REflESIAL TECKN3LOBY

SWFACE HATER(CN-slTE FCNO!

No Acticn

Acc355 Rsstr

Cofit»ir.«nt

Treat ient

None

D*9d RestrictionsSite FencingFend Miter Sonitorinq

Backfill

rhysicil/Cheaica! TreitientiCoacalition/SeditentitianFiltrationCarbon Adsorption

.( '

3-31

Page 88: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

CFeasibility StudyMarion/Bragg landfill SiteSection: 3July 31, 1987Page 3-32 of 39

unrestricted. Fencing of the entire landfill site would lijnit publicaccess to the site. Deed restrictions would be used to prevent futureconstruction, well drilling, etc., activities on site. Access anddeed restriction options are considered viable and could be used inconjunction with other remedial technologies as part of aconprehensive remedial action at the site.

3.4.1.2 Landfill Containment

Applicable technologies for containment of landfill contents includeuse of surface water controls, capping and installation of a verticalbarrier.

Surface Controls

Several surface control options could be used together to containlandfill contents. Surface grading, addition of soil cover andrevegetation would limit migration of contaminated surface soil offsite, would limit migration of contaminated surface water, and preventdirect contact with contamination associated with the landfill.Overall, these actions would reduce the hazards resulting from thelandfill. Migration of contaminants in the upper aquifer wouldcontinue to occur. Ihe significance of this action is not consideredgreat since groundwater flows through the contaminated landfill. • Thereliability of this action is high if proper construction andlong-term maintenance of the cover is utilized to prevent erosion ofthe cover.

Capping

Two types of capping could be utilized - single layer cap andmultimedia cap. Capping would greatly reduce surface infiltrationwith a resulting reduction of contaminants leaching into thegroundwater.

Single layer Cap

A single layer cap, consisting of compacted soil or compacted clayeysoil can be used to provide an impermeable layer over the existinglandfill. The State of Indiana's current requirements for closure oflandfill requires the use of two feet of compacted soil with 50% finesoverlain by six inches of top soil and a vegetative cover. Two feetof compacted clayey soil, instead of two feet of compacted soil, hasbeen proposed for landfill closure by the State of Indiana. Standardconstruction practices of six inch layers compacted to 95 percentdensity can result in permeabilities of 10 cm/sec or less. Thebenefits of a single layer cap include reduction of infiltration ofwater and stabilization of the contaminated surface soils. The

Page 89: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 3July 31, 1987Page 3-33 of 39

technology is effective and has good longevity and durability assumingproper design, installation and maintenance. Long-terra maintenance ofthe cap would be required.

A TnultimBrtla cap involves the closure of the landfill utilizing a RCRA"model" cap. The "model" cap consists of the following: a beddinglayer installed on top of the solid waste, an impervious layer of clay(2 feet), a second bedding layer and a second impervious layer (20 milsynthetic liner), a drainage layer (1 foot) and a vegetative cover.Because of multiple layers of impervious material (clay and syntheticliner), the amount of infiltration into the landfill will be lesscompared to the single layer cap. The benefits of a multimedia capincludes significant reduction of infiltration of water into the fill,a reduction in leachate generation and subsequent off site migrationof leachate from seeps. This technology is effective and has goodlongevity and durability assuming proper design, installation, andmaintenance. Long-term maintenance of the cover would be requiredthroughout the life of the cap.

Slurry Wall

This technology is used to prevent or minimize lateral groundwaterflow into and out of the landfill. The presence of a low permeabilityclay confining layer at reasonable depths at the site provides animpermeable confining layer to key the slurry wall into. Because aslurry wall provides an iapermeable barrier, contact of groundwaterwith the landfill is significantly minimized. This technology iseffective and requires little or no maintenance if proper constructionmethods are used to effectively key the slurry wall into the confininglayer.

A portion of the landfill is within 10 to 15 feet from the edge of theriver on the eastern side of the site. In these areas, it will benecessary to construct the slurry wall approximately 70 to 95 feetfrom the edge of the river. This results in a small percentage of theoverall landfill waste volume to remain outside of the slurry wall.The river bank is heavily vegetated with trees and undergrowth,resulting in proven bank stability over the previous years. In orderto cap the gmaii percentage of wastes that will remain outside theslurry wall, it will be necessary in some areas to remove the treesand undergrowth to install the cap. The benefits gained by cappingthe waste outside the slurry wall in those areas may not outweigh theexisting benefit of a stable river bank, especially since the landfillis so close to the river. In addition, a cap installed outside theslurry wall at prr*8 locations would also be outside the site floodprotection levees and would be subject to significant erosion and

Page 90: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 3July 31, 1987Page 3-34 of 39

scour during flood events, resulting in eventual erosion of the cap.Therefore, for the purposes of alternative evaluation, the wasteoutside the slurry wall and flood protection levee will not be capped.

3.4.1.3 Landfill Treatment

On-site incineration of landfill contents a utilizing rotary Jciln is aviable technology for providing permanent treatment of organics. Amobile (transportable) unit could be used to incinerate the materialson-site. Incineration is a reliable and effective means of destroyingorganic contamination; however, inorganic contaminants would remainand became more concentrated in the ash. Non-combustibles and ash(potentially as much as 85% of the original volume) could be disposedof on-site provided they are non-hazardous based on EP toxicitycriteria. Excavation and physical reduction of landfill contents touniform size (-1" diameter) would be required prior to incineration.Significant time would be required to completely incinerate the entirelandfill contents. Based on the capacity of a single transportableunit (100 cu. yds/day) and the estimated fill volume of 1.1 millioncubic yards, it would take approximately 30 years to incinerate thelandfill contents. Time required for incineration can be reduced byutilizing multiple transportable units.

3.4.1.4 Landfill Removal and Off Site Disposal

The technologies considered applicable for the l»rrif ji i are disposalin an off site RCRA landfill and treatment in an off site RCRAincineration facility.

Off Site RCRA Landfill Disposal

Excavated landfill mritftrlal would be transported to and disposed at anexisting off site RCRA permitted land -Fin, off site disposal at aRCRA landfill is considered effective and reliable since contaminantsare removed from the site. However, the contaminants are notdestroyed when placed in an off -site

Since wastes have been disposed throughout the Iwflflll, it would benecessary to excavate the entire contents of the landfill. Since sucha large volume of material (estimated at 1.1 million cubic yards) isinvolved, locating a single landfill to accept this large volume maypose significant difficulty or wastes may have to be disposed inseveral available facilities. Significant time for excavation andtransportation would be required.

Off Site RCRA Incineration Facility

Excavated landfill mai-o-HaTg could be transported to and treated at

Page 91: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 3

( July 31, 1987^ Page 3-35 of 39

one of several RCRA licensed incineration facilities. The feasibilityof this option is limited by several factors. Although off siteincinerators are available most facilities are currently backloggedwith orders and a waiting period would be unavoidable.

It would take approximately 100 years to incinerate the entirelandfill contents at a typical capacity of 30 tons/day in off-siteincineration facility. The volume of ash, if determined to behazardous because of metal content, may require further disposal ashazardous waste. In accepting wastes for incineration, the off-sitefacility also is responsible for proper disposal of the resulting ash.This technology conpletely destroys the organic contaminants of theland fill and provides for permanent treatment. This technology iseffective and proven.

3.4.2 Groundwater

3.4.2.1 Access and Deed Restrictions

As with the landfill, the purpose of access restriction is to preventexposure of receptors to contaminants. Deed restrictions could beused to prevent future use of contaminated groundwater. Site fencing

( could be used to restrict access to the site and prevent use ofon-site groundwater. All of the options are considered technicallyviable and could be used in conjunction with other remedialtechnologies as part of a comprehensive remedial action at the site.

3.4.2.2 Groundwater Containment

Groundwater containment technologies include capping and a verticalbarrier utilizing slurry wall. Capping and slurry wall technologieswere discussed in Section 3.4.1.2.

3.4.2.3 Groundwater Collection

Groundwater collection would include placement of an appropriatenumber of pheripheral extraction wells around the i arrffi 11 toprevent contaminated water from the upper aquifer migrating to theMississinewa River. In order to prevent migration of groundwater tothe river, the groundwater gradient must be reversed, which inducesriver water to flow to the site. This results in a large volume ofwater to be extracted for treatment. To minimize the amount ofgroundwater extracted for treatment, use of a slurry wall is adesirable option that must be considered. Pumping would be requiredfor an indefinite period of time since the quantity andcharacteristics of contaminants in the landfill are unknown. Thedesign of the system depends on the aquifer characteristics (hydraulicgradient and transmissivity). Extraction wells are considered

Page 92: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 3July 31, 1987Page 3-36 of 39

effective for groundwatar collection. Although reliability is good,regular maintenance and pump replacement would be required throughoutthe collection period. This action would be implemented as part ofother activities such as treatment and disposal.

3.4.2.4 Qn-Site Groundwater Treatment

The applicable technologies for treatment of groundwater are:chemical coagulation/sedimentation, filtration and activated carbonadsorption.

Chemical coagulation is a physical/chemical technology that can bevised to remove metals from groundwater. Frequently, the pH of thegroundwater is adjusted to optimize precipitation of metals, followedby polymer addition. Following chemical coagulation, the treatedgroundwater will be flocculated and settled to remove solids resultingfrom chemical coagulation. Collected sludge will require dewateringand disposal in an off site sanitary landfill. Based on the metalscontent in the groundwater, it can be reasonably assumed thatdewatered sludge will be non-hazardous.

Lime and sulf ide can be used as the chemicals for metalsprecipitation. Limp precipitation is accomplished by adding lime tothe collected groundwater. Heavy metal hydroxides are precipitatedcut of solution. Other inorganic and organic contaminants can beabsorbed on to the metal hydroxide precipitate and removed, althoughsignificant organic removed is not expected.

Sulf ide precipitation can remove heavy metals to much lowerconcentrations compared to lime precipitation because of lowsolubilities of heavy metal sulf ides. However, excess sulf ideaddition could cause odor problems. A sulf ide treatment systemrequires careful pH control and an H.S monitoring and alarm system forworker protection to avoid occupational exposure. Because sulf ideprecipitation requires more operational control and monitoring, limeprecipitation is preferable for heavy metals removal.

This technology is very effective and has been used extensively fortreatment of wastewater for heavy metals removal at concentrations inparts per million levels. Concentrations of metals of concern(arsenic, beryllium, cadmium and silver) are in the very low parts perbillion range and are beyond the treatment capability of chemicalcoagulation and sedimentation. For these reasons, chemicalcoagulation and sedimentation has very limited potential for treatmentof groundwater present within the upper aquifer at the Marion/Braggsite.

Page 93: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility studyMarion/Bragg Landfill SiteSection: 3July 31, 1987Page 3-37 of 39

Filtration

Filtration will be used primarily to remove any residual suspendedsolids remaining in the grcundwater following chemicalcoagulation/sedimentation. Since coagulation and sedimentation hasbeen determined to be ineffective for treatment of grcundwater,filtration is not necessary.

Carbon Adsorption

In carbon adsorption, chemical contaminants are removed from water byphysical and chemical adsorption of organics onto the surface ofcarbon particles. Granular activated carbon (GAC) is the most commonform used in wastewater treatment. For GAC treatment, grcundwater ispumped through a bed of GAC where close contact with carbon particlespromotes adsorption of contaminants. Carbon adsorption can remove abroad range of organic contaminants and a select number of inorganiccontaminants. Adsorption is reversible, so the exhausted carbon mustbe removed for regeneration. Carbon can be regenerated either in anon-site facility or off site at carbon manufacturer's facilities. Offsite regeneration is more applicable because carbon exhaustion ratewill be small based on the low levels of contaminants present in thegroundwater.

The technology is very effective. Carbon adsorption achieves a highlevel of contaminant removal and is capable of producing water that isof drinking water quality. Operation requires skilled and trainedoperators. Operation also requires frequent monitoring to trackcontaminant breakthrough. Operation and maintenance costs may be highdue to carbon replacement and regeneration.

Air

Air stripping will be used to remove ammonia from carbon columneffluent. Prior to air stripping, caustic will be added to the carboncolumn effluent to raise the pH for effective stripping of ammonia.Air stripping is a well-demonstrated technology for ammonia removal.In air stripping, the effluent is pumped to top of the tower, and airis pumped at the bottom of the tower. Sufficient air/water ratio mustbe maintained to transfer ammonia from water to air phase. Iheammonia removal efficiency required for groundwater is approximately70% based on a maximum influent concentration of 24 mg/1 and therequired effluent concentration of 8.1 mg/1 in summer months. Iheefficiency required to be achieved is well within the typical rangefor air stripping of ammonia.

Page 94: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 3

(• , July 31, 1987Page 3-38 of 39

3.4.2.5 Off-site Groundwater Treatment

The extracted groundwater can be treated at an existing off site RCRApermitted facility or at an off site publicly owned treatment works.

Treatment at RCRA Facility

The main components of treatment at a RCRA facility are cm-sitefacilities for storage of groundwater and tanker truck loadingand transport of contaminated groundwater to the off site treatmentfacility.

The performance of off site treatment is assumed to be effective sinceit would be regularly monitored as a RCRA facility. The applicabilityof this option is related to the quantity of groundwater requiringtreatment and the availability of a RCRA facility close to theMarion/Bragg site. large volumes of groundwater requiring treatmentmay significantly inpact the operation cost since RCRA facilitynormally charges a fee on a per gallon basis.

Publicly Owned Treatanent Works (POIW)

Extracted groundwater would be pumped to a nearby sanitary sewer andwould be treated at the Marian POTW. This option is feasible if thequantity of groundwater requiring treatment is only on the order of200 - 250 gpm based on discussion with the Marian POTW personnel. Atthis rate, it would not hydraulically impact the operation of theMarion POIW facilities. Obtaining necessary state and local permitsmay delay implementation. Monitoring and reporting of the groundwaterdischarged to the Marion sewer would be required to comply with thesewer ordinances.

Discharge to POTW has been demonstrated to be an effective treatmentfor water contaminated with a variety of organic and inorganics. Thisoption transfers the bulk of the treatment operation off site.

3.4.3 leachate Seep

3.4.3.1 Leachate Seep Containment

Applicable technologies for containment of leachate seeps includecapping with single layer or multimedia capping. Capping wouldessentially contain the leachate seeps within the landfill andprevent migration of contaminants to off-site locations. Capping isdiscussed in Section 3.4.1.2.

Page 95: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 3July 31, 1987Page 3-39 of 39

3.4.3.2 Leachate Collection and Treatment

The leachate seep observed in the south-central portions of the siteis intermittent and is due to the infiltration of rainwater throughthe existing permeable cap over the landfill. Since only one surfacedischarge seep was found during the remedial investigation, a leachatecollection and treatment system does not appear to be warranted. Thisseep can be controlled when the landfill is graded and provided with asuitable surface cap. When the site is provided with a surface cap,the leachate would become part of the groundwater.

3.4.4 Surface Water ron-Site Pondl

The remedial response actions that were determined to be applicable tothe on-site pond are access restrictions, containment, and treatment.Because pond water and groundwater are essentially the same, theaccess restrictions and treatment as discussed in Sections 3.4.2.1,3.4.2.4 and 3.4.2.5 would also apply.

3.4.4.1 Pond Containment

The technology for containing the pond is to backfill the entire 15acres which would require approximately 680,000 cu. yds. of fillmaterial to fill the pond to existing grade. The fill material mustcrme from off-site borrow sources. This option would place a heavydemand for construction equipment if the pond were to be backfilled inany reasonable length of time. It is estimated that it will require 9to 12 months to complete the backfilling of the pond.

Page 96: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-1 of 22

SECITCN 4

ASSEMBLY OF ALTERNATIVES

In this section, applicable remedial technologies identified inSection 3 are assembled into alternatives that address the overallcontamination at the Marion/Bragg landfill site.

4.1

The Superfund Amendments and Reauthorization Act of 1986 (SARA)requires alternatives to be developed which meet specificrequirements. These requirements include;

o The development of treatment alternatives for source controlthat would eliminate the need for long-term management(including monitoring) .

o The development of alternatives involving treatment as aprincipal element to reduce the toxicity, mobility, orvolume of site waste.

o The development of an alternative that involves containmentof waste with little or no treatment, but providesprotection of human health and the environment primarily bypreventing potential exposure or reducing the mobility ofthe waste.

o The development of a no-action alternative.

The remedial action alternatives developed for the Marion/Bragglandfill site were assembled considering these requirements.

4.2

The alternatives developed for the Marion/Bragg Landfill site arepresented in Table 4-1. Alternatives 1A through 3C are considered tomeet the first two objectives of the SARA requirements. Alternativesthat involve containment of waste with little or no treatment arerepresented by alternatives 4A through 9. Alternative 10 representsthe No Action alternative.

It should be noted that since portions of the site are located with inthe 100 year flood plain, all alternatives other than the No Actionalternative must include flood control measures at appropriatelocations along the river perimeter.

Page 97: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 4-1SUMMARY OF ASSEMBLED ALTERNATIVES FOR MARION/BRAGG LANDFILL SITE (1)

•uI

K>

AlternativeNumber Landfill

Technology For:

Onsite Pond

1A Offsite RCRAIncineration Facility

IB Offsite RCRAIncineration Facility

1C Offsite RCRAIncineration Facility

2A Onsite Incineration

2B Onsite Incineration

2C Onsite Incineration

Backfill (2)

Backfill (2)

Backfill (2)

Backfill (2)

Backfill (2)

Backfill (2)

3A Offsite RCRA Landfill Backfill (2)

3B Offsite RCRA Landfill Backfill (2)

3C Offsite RCRA Landfill Backfill (2)

Groundwater

Extraction and treatmentat offsite RCRA facility

Extraction anddischarge to POTW

Extraction and onsitetreatment (3)

Extraction and treatmentat offsite RCRA facility

Extraction anddischarge to POTW

Extraction and onsitetreatment (3)

Extraction and treatmentat offsite RCRA facility

Extraction anddischarge to POTW

Extraction and onsitetreatment (3)

Page 98: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 4-1 (Continued)SUMMARY OF ASSEMBLED ALTERNATIVES FOR MARION/BRAGG LANDFILL SITE (1)

AlternativeNumber Landfill

Technology For:

Onsite Pond Groundwater

4A Indiana SanitaryLandfill Cap

4B Indiana SanitaryLandfill Cap

4C Indiana SanitaryLandfill Cap

Backfill (2)

Backfill (2)

Backfill (2)

Extraction and treatmentat offsite RCRA facility

Extraction anddischarge to POTW

Extraction and onsitetreatment (3)

IUl

5A

5B

5C

6A

6B

6C

Multilayer (RCRA) CAP Backfill (2)

Multilayer (RCRA) CAP Backfill (2)

Multilayer (RCRA) CAP Backfill (2)

Slurry Wall andmultilayer cap (RCRA)

Slurry Wall andmultilayer cap (RCRA)

Slurry Wall andmultilayer cap (RCRA)

Backfill (2)

Backfill (2)

Backfill (2)

Extraction and treatmentat offsite RCRA facility

Extraction anddischarge to POTW

Extraction and onsitetreatment (3)

Extraction and treatmentat offsite RCRA facility

Extraction anddischarge to POTW

Extraction and onsitetreatment (3)

Page 99: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 4-1 (Continued)SUMMARY OF ASSEMBLED ALTERNATIVES FOR MARION/BRAGG LANDFILL SITE (1)

AlternativeNumber Landfill

Technology For:

Onsite Pond Groundwater

7A

7B

7C

8

9

10

NOTES

Slurry Wall andIndiana SanitaryLandfill Cap

Slurry Wall andIndiana SanitaryLandfill Cap

Slurry Wall andIndiana SanitaryLandfill Cap

Indiana SanitaryLandfill Cap

Multilayer Cap (RCRA)

No Action

Backfill (2)

Backfill (2)

Backfill (2)

None

None

No Action

Extraction and treatmentat offsite RCRA facility

Extraction anddischarge to POTW

Extraction and on-sitetreatment

Monitor (4)

Monitor (4)

No Action

(1) Access and deed restrictions will be used for all alternativesexcept Alternative 10.

(2) Leaving the on-site pond in present condition wil also beconsidered during detailed evaluation to provide cost differencebetween leaving the pond open and backfilling.

(3) On site treatment consists of activated carbon adsorption.(4) Mississinewa River water and sediments would also be monitored.

Page 100: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 4July 31, 1987Page: 4-5 of 22

The public health evaluation indicates that there are no hazardsassociated with the on site pond. However, backfilling of pond hasbeen included for remediation of this potential contaminant pathwayexcept for alternatives 8 through 10 in order to address the potentialfor future risk if they arise due to future contamination of theon-site pond..

A description of each alternative is provided in the followingsubsections.

4.3 DESCRIPTION OF ALTERNATIVES

4.3.1 Alternative 1A - Excavation and off-site incineration oflandfill contents; oroundwater extractionand treatment at an off-site RCRA treatmentfacility

The major components of Alternative 1A are:

o Access and deed restrictions;o Excavation of landfill contents and transportation to an

off-site RCRA incineration facility;o Extraction of groundwater for treatment at an off-site RCRA

treatment facility;o Backfilling of the on-site pond.

Access and Deed Restrictions

The site is presently not fenced and, therefore, access to the site isunrestricted. Fencing of the entire landfill site would limit publicaccess to the site and would prevent exposure to contaminants presentin the landfill. Extraction of groundwater for treatment in anoff-site facility would be required. Since excavation of landfillcontents for off site incineration would require a significant numberof years to complete, groundwater treatment during the period ofdisposal of landfill contents in off site incineration facilities willbe required to prevent contaminant migration to the MississinewaRiver. Deed restrictions would be placed for the entire site and wouldbe in effect until all the contaminated material from the landfill hasbeen excavated and transported to an off-site incineration facilityand the groundwater contamination reaches background levels.

Excavation of landfill Contents for Off-Site Incineration

Wastes are known to have been disposed throughout the landfill and,therefore, it would be necessary to excavate the entire contents ofthe landfill for off-site incineration. The estimated volume ofmaterial to be excavated is 1.1 million cubic yards. An iirportantconsideration in the evaluation of any off-site incineration facilityis the need for compliance with EPA's off-site law (Section 121 of

Page 101: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-6 of 22

SARA). This law prohibits the use of a RCRA facility for off-sitemanagement of Superfund hazardous wastes if it has existing RCRAviolations. Additionally, the policy requires that transportation ofall hazardous wastes be properly manifested as required by RCRA. Theprincipal constraints of this alternative are the availability of anoff-site RCRA-approved incineration facility that can handle the largevolume of contaminated material present at the site and the length oftime required for incineration. It would take approximately 100 yearsto incinerate the entire landfill contents at a typical RCRAincineration facility with a capacity of 30 tons/day.

Following excavation and transportation of landfill contents to anoff-site facility for incineration, the excavated area will bebackfilled with clean fill and graded. A significant volume ofbackfill, equivalent to the volume of contaminated material excavated,would be required. Sufficient vegetative cover to stabilize thesurface of the site and to prevent erosion would be required.

Groundwater Extraction and Treatment at an Off-Site RCRA TreatmentFacility

The groundwater at the site is contaminated and will continue to becontaminated until all contaminated landfill material has beenexcavated. Therefore, extraction of groundwater and treatment at anoff-site RCRA treatment facility would be required. Due to theproximity of the Mississinewa River to the site, large volumes ofgroundwater must be extracted. Off site treatment capacity foranticipated large volumes may not be available.

A sufficient number of extraction wells will be placed to permitextraction of groundwater. The number of extraction wells to beinstalled at the site would be based on the aquifer characteristics(transmissivity of the aquifer, hydraulic gradient, etc.).Groundwater removed from the extraction wells will be stored in tankson site. Tank trucks would transport the contaminated groundwater toa RCRA treatment facility. It is assumed that RCRA treatmentfacilities are available within a reasonable distance from the site.The groundwater extraction and treatment at an off-site treatmentfacility would continue until all the contaminated material from thelandfill has been excavated and transported to an off-siteincineration facility.

Backfilling of Pond

Backfilling of the on-site pond will be accomplished utilizingoff-site borrow materials to fill the pond to existing grade. Duringbackfilling of the pond, the water level in the pond may rise to alevel that will overflow the existing pond banks. To prevent thisfrom occurring, it may be necessary to incorporate measures for proper

Page 102: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-7 of 22

handling of on-site pond overflows. This can be accomplished bytemporarily discharging the pond water to either the MississinewaRiver or to the Marion FOIW. Discharge to the river or to the MarionPOIW would require obtaining necessary approval or permit. If pondwater cannot be discharged to the river without on-site treatment,then discharge to the Marion POIW would be the desirable option.Based on the volume of water present in the pond and the duration ofbackfilling operation (9-12 months), a maximum discharge rate of 120gpm would result, assuming the entire content of the pond wouldoverflow. The Marian POIW has adequate hydraulic capacity availablein the treatment facility to handle the estimated maximum dischargerate. The levels of contaminants present in the pond water can beaccommodated without impacting the operation of the Marion POTW.Discharge to the Marion FOIW would require installation of a sewerline from the site to Marian sanitary sewer system.

4.3.2 Alternative IB - Excavation and off-site incineration oflandfill contents; qroundwater extractionand treatment at Publicly-Owned TreatmentWorks (POIW)

The major components of Alternative IB are:

o Access and deed restrictions;o Excavation of landfill and transportation to off-site RCRA

incineration facility;o Extraction of groundwater and treatment at POIW;o Backfilling of on-site pond.

The components of this alternative are the same as Alternative 1A withthe exception that extracted groundwater would be discharged to theMarion POIW for treatment. Discussions presented for Alternative 1Afor access and deed restrictions, excavation of landfill contents fortransportation to off-site RCRA incineration facility extraction ofgroundwater and backfilling of the pond would also apply to thisalternative.

Groundwater Extraction and Treatment at POIW

The extracted groundwater would be pumped to a nearby sanitary sewerfor treatment at the Marion POIW. On-site facilities would consist ofa discharge pipe cormecting the groundwater collection system with thesanitary sewer. Permission must be obtained from the Marion POIW fordischarge of extracted groundwater to the sanitary sewer. The MarionPOIW may not be able to treat the anticipated large volume ofextracted groundwater. In addition, sampling and analysis ofgroundwater would be required at a frequency to be established byMarion sewer authority. Groundwater extraction and discharge to thesanitary sewer will continue until all the wastes are excavated andtransported to an off-site incineration facility.

Page 103: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 4July 31, 1987Page: 4-8 of 22

4.3.3 Alternative 1C - Excavation and off-site incineration oflandfill contents; qroundwater extraction andon-site treatment

The major components of Alternative 1C are:

o Access and deed restrictions;o Excavation of landfill contents and transportation to an

off-site RCPA incineration facility;o Extraction of groundwater and on-site treatment;o Backfilling of on-site pond.

The components of this alternative are the same as Alternative 1A withthe exception that extracted groundwater would be treated in on-sitefacilities. Discussions presented for Alternative 1A for access anddeed restrictions, excavation of landfill contents for transportationto an off-site RCRA incineration facility, extraction of groundwaterand backfilling of the pond would also apply to this alternative.

Groundwater Extraction and On-Site Treatment

The extracted groundwater would be treated in on-site facilities andthe treated effluent would be discharged to the Mississinewa Riverunder a NPDE3 permit. A NPDES permit must be obtained from the Staterf Indiana prior to initiating on-site treatment. The NPDES permitwould establish effluent limits for discharge of treated effluent tothe Kississinewa River.

The on-site treatment facilities would consist of activated carbonadsorption for removal of trace levels of metals and organiccontaminants and COD present in the groundwater. The activated carboncan remove trace levels of arsenic, cadmium and silver present in thegroundwater. However, removal of beryllium by activated carbon is notdocumented. This would require a limited treatability study todetermine whether trace level of beryllium present in groundwater canbe removed by activated carbon. Exhausted carbon must be removed andregenerated to maintain treatment efficiency. The exhausted carboncan best be regenerated in the carbon manufacturer's facility due toinfrequent regeneration that may be required based on the level oforganic contamination present in groundwater. Following activatedcarbon treatment, the effluent will be air stripped for ammoniaremoval after pH adjustment.

After construction of on-site treatment facilities is completed, aprivate contractor would be retained and would be responsible forcontinuous operation and maintenance of the treatment facility. Thetreatment facility would require an operator 24 hours/day andadditional personnel for periodic maintenance of electrical andmechanical equipment. In addition to the contractor's personnel,regulatory agencies would oversee the treatment plant operation.

Page 104: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StuJyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-9 of 22

Regular sampling of the influant and effluent would be required tocomply with the requirements of the NPDES permit. Analysis ofinfluent water would be used to determine the duration of thetreatment. Groundwater extraction and treatuvent would be continueuntil all the contaminated material from the landfill has beenexcavated and transported to an off-site incineration facility.

4.3.4 Alternative 2A - On-site incineration of landfill contents;groundvater extraction and treatjaent atan off-site RCRA treatment facility

The major components of Alternative 2A are:

o Access and deed restrictions;o Excavation and on-site incineration of landfill contents;o Extraction of groundwater for treatment at an off-site RCRA

treatment facility;o Backfilling of the on-site pond.

Access and Deed Restrictions

The purpose of access and deed restrictions are the same as discussedfor Alternative 1A. The deed restriction would be in effect until allthe contaminated material from the landfill has been excavated andincinerated in an on-site incineration facility.

Excavation and On-5ite Incineration of Landfill Contents

As discussed under Alternative 1A, it would be necessary to excavatethe entire landfill contents for on-site incineration. Prior toincineration, the excavated material would be reduced to 1 inch sizeby physical shredding or other means. Oversized material that couldnot be shredded would be decontaminated and disposed of in an off-sitesanitary landfill. Incineration would be accomplished using a mobile(transportable) rotary kiln incinerator. The mobile system consistsof prefabricated and self-contained modules which could be transportedand assembled at the site. Transportable rotary kiln incinerators arecommercially available and have been used for hazardous wasteincineration. Subcontractor services will be utilized to operate andmaintain the equipment during the incineration operation. Thecapacity of a single transportable unit is 100 cubic yards/day and itwould require approximately 30 years to incinerate an estimated fillvolume of 1.1 million cubic yards, if only one incinerator is used.Time required for incineration can be reduced by utilizing multipletransportable units.

Significant quantities of ash (potentially as much as 85% of theoriginal volume) would result. The ash will be analyzed for EPtoxicity metals to determine whether the residual ash is hazardous andnonhazardous. Based on the metals content present in the waste, it

Page 105: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-10 of 22

can be reasonably expected that the incineration ash would benonhazardous. The residual ash will be placed in the excavation andcovered with clean fill and compacted. The compacted layer will beprovided with a cap similar to that employed in a typical sanitarylandfill. Sufficient vegetative cover will be established tostabilize the surface of the site and to prevent erosion.

In the unlikely event that the incineration ash is determined to behazardous, full compliance with PCRA regulations for hazardous wasteslandfilling will be required. Because of the volume of ash, in-placeclosure would be preferable to hauling ash for disposal in an off-siteRCRA landfill.

Incineration would also generate liquid wastes from stack gascleaning, such as scrubbers. These liquid wastes will be transportedfor disposal in off-site RCRA facility.

Groundwater Extraction and Treatment at an Off-Site RCRA TreatmentFacility

The approach for groundwater extraction would be the same as discussedfor Alternative 1A. The extracted groundwater would be transported toan off-site RCRA treatment facility, as discussed for Alternative 1A.

Backfilling of On-Site Pond

Discussion presented for Alternative 1A for backfilling of pond wouldalso apply.

4.3.5 Alternative 2B - On-site incineration of landfill contents;groundwater extraction and treatment atPublicly-Owned Treatment Works (POTW)

The major components of Alternative 2B are:

o Access and deed restrictions;o Excavation and on-site incineration of landfill contents;o Extraction of groundwater and treatment at POIW;o Backfilling of on-site pond.

The components of this alternative are the same as Alternative 2A withthe exception that extracted groundwater would be discharged to MarionPOTW for treatment. Discussions presented for Alternative 2A foraccess and deed restrictions, excavation and on-site incineration oflandfill contents and backfilling of on-site pond would also apply tothis alternative. The treatment of extracted groundwater as discussedfor Alternative IB would also be applicable for this alternative.

Page 106: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility Study, Marion/Bragg Landfill Site

Section: 4July 31, 1987Page: 4-11 of 22

4.3.6 Alternative 2C - On-site incineration of landfill contents;groundwater extraction and on-site treatment

The major components of Alternative 2C are:

o Access and deed restrictions;o Excavation and on-site incineration of landfill contents;o Extraction of groundwater and on-site treatment;o Backfilling of on-site pond.

The conponents of this alternative are the same as Alternative 2A withthe exception that extracted groundwater would be treated in on-sitefacilities. Discussions presented for Alternative 2A for access anddeed restrictions, excavation and on-site incineration of landfillcontents and backfilling of on-site pond would also apply to thisalternative. The treattrvsnt of extracted groundwater in on-sitefacilities is the same as discussed for Alternative 1C.

4.3.7 Alternative 3A - Excavation and off-site RCRA landfill disposalof landfill contents; groundwater extractionand treatment at an off-site RCRA facility

The major conponents of Alternative 3A are:

o Access and deed restrictions;o Excavation of landfill contents and transportation to

off-site RCRA landfill;o Extraction of groundwater for treatment at off-site RCRA

treatment facility;o Backfilling of on-site pond.

Access and Deed Restrictions

Access and deed restrictions discussed for Alternative 1A would alsoapply to this alternative.

.Excavation of Landfill Contents for Off-Site Disposal

This alternative consists of excavating the entire landfill contentsfor disposal in off-site RCRA-approved landfill. The estimated volumeof material to be excavated is 1.1 million cubic yards. An importantconsideration in the evaluation of any off-site land disposal facilityis the need for conpliance with EPA's off-site law. This lawprohibits the use of a RCRA facility for off-site management ofSuperfund wastes if it has existing RCRA violations. Additionally,the policy requires that transportation of all hazardous wastes to beproperly manifested as required by RCRA. The principal constraint ofthis alternative is the availability of a suitable RCRA landfill thatcan handle the large volume of material present at the site. Because

Page 107: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-12 of 22

of the large volume of material, it may be desirable to use multipleoff-site RCRA landfill facilities for disposal of Marion/Bragg wastes.

The excavated area will be backfilled with clean fill and graded. Thebackfilling will be done on a continuous basis during excavation.Significant volume of backfill, equivalent to the volume of contami-nated material excavated, would be required. Since the contaminatedmaterial would be completely removed from the site, it would not benecessary to provide a site cap. However, sufficient vegetative coverto stabilize the surface of the site and prevent erosion would berequired.

Groundwater Extraction and Treatment at an Off-Site RCRA TreatmentFacilities

Groundwater extraction and treatment at off -site RCRA treatanentfacility considered for this alternative are identical to that ofAlternative 1A. Therefore, discussion presented for Alternative 1Awould also apply to this alternative.

Backfilling of On-5ite Pond

Discussions presented for Alternative 1A for backfilling of pond wouldalso apply.

4.3.8 Alternative 3B - Excavation and off-site RCRA landfill disposalof landfill contents; qroundwater extractionand treatment at Publicly-Owned TreatmentWorks

The major components of Alternative 3B are:

o Access and deed restrictions;o Excavation of landfill contents and transportation to an

off-site RCRA landfill;o Extraction of groundwater and treatment at POIW;o Backfilling of on-site pond.

The components of this alternative are the same as Alternative 3A withthe exception that extracted groundwater would be discharged to MarionPOIW. Discussions presented for Alternative 3A for access and deedrestrictions, excavation of landfill contents for transportation tooff-site RCRA landfill and backfilling of on-site pond would alsoapply to this alternative. The treatment of extracted groundwater asdiscussed for Alternative IB would also be applicable for thisalternative.

Page 108: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-13 of 22

4.3.9 Alternative 3C - Excavation and off-site RCRA landfill disposalof landfill contents and groundwaterextraction and on-site treatment

The major components of this Alternative 3C are:

o Access and deed restrictions;o Excavation of landfill contents and transportation to

off-site RCRA landfill;o Extraction of groundwater and on-site treatment;o Backfilling of pond.

The conponents of this alternative are the same as Alternative 3A withthe exception that extracted groundwater would be treated on site.Discussions presented for Alternative 3A for access and deedrestrictions, excavation of landfill contents for transportation to anoff-site RCRA landfill and backfilling of on-site pond would alsoapply to this alternative. The treatment of extracted groundwater asdiscussed for Alternative 1C would also be applicable for thisalternative.

4.3.10 Alternative 4A - Indiana Sanitary landfill cap; extractionof qroundwater and treatment at off-siteRCRA treatment facility

The major cxznponents of Alternative 4A are:

o Access and deed restrictions;o Installation of a sanitary landfill cap over the site;o Extraction of groundwater for treatment at off-site RCRA

treatment facility;o Backfilling of on-site pond.

Access and Deed Restrictions

Access and deed restrictions discussed for Alternative 1A would alsoapply to this alternative. However, the deed restrictions would bepermanent since the contaminants associated with the landfill would beleft in place.

Sanitary landfill Cap

A cap would be installed over the entire landfill site. The State ofIndiana current requirements for closure of a landfill require the useof two feet of compacted soil with 50% fines overlain by a six inchlayer of tcpsoil and a vegetative cover. Two feet of compacted clayeysoil instead of two feet of compacted soil has been proposed forlandfill closure by the State of Indiana. Since the current andproposed cap specifications are essentially equivalent, the proposed

Page 109: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-14 of 22

specification will be utilized for sanitary landfill closurealternatives.

The cap would not meet the standards required for closure of ahazardous landfill under RCRA. However, the cap would prevent directcontact threats and reduce surface infiltration with a resultingreduction of contaminants leaching into groundwater.

The cap would be inspected on a regular basis for signs of erosion andsubsidence. Maintenance of the cap would include the application offertilizer and periodic mowing to prevent intrusion of deep-rootedvegetation into the cap.

Groundwater Extraction and Treatment at an Off-Site RCRA TreatmentFacility

The approach for groundwater extraction and treatment at an off-siteRCRA treatment facility discussed for Alternative 1A would also applyto this alternative. Since the contaminants are left in place,groundwater extraction and transportation to an off-site RCRA facilitywould be required until the groundwater contamination level reachesbackground value.

Backfilling of On-Site Pond

Discussions presented for Alternative 1A for backfilling of pond wouldalso apply.

4.3.11 Alternative 4B - Indiana Sanitary landfill cap; extractionof oroundwater and treatment atPublicly-Owned Treatment Works fPCTW)

The major conponents of Alternative 4B are:

o Access and deed restrictions;o Installation of a sanitary landfill (non-RCRA) cap over the

site;o Extraction of groundwater and treatment at POTW;o Backfilling of on-site pond.

The Alternative 4B differs from Alternative 4A only with respect toextraction of groundwater for treatment at POIW. Therefore,discussion presented for access and deed restrictions, installation ofcap, groundwater extraction and backfilling of on-site pond forAlternative 4A would also apply for this alternative.

The treatment of extracted groundwater at POIW discussed forAlternative IB would also apply for this alternative with theexception that groundwater treatment will be required until thegroundwater contamination level reaches background value.

Page 110: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-15 of 22

4.3.12 Alternative 4C - Indiana Sanitary landfill cap; extractionof groundwater and on-site treatment

The major components of Alternative 4C are:

o Access and deed restrictions;o Installation of a sanitary landfill cap;o Extraction of groundwater and on-site treatment;o Backfilling of pond.

The Alternative 4C differs from Alternative 4A only with respect toon-site treatment of extracted groundwater. Therefore, discussionspresented for access and deed restrictions, installation of cap,groundwater extraction and backfilling of on-site pond for Alternative4A would also apply to this alternative.

The on-site treatment of extracted groundwater discussed forAlternative 1C would also apply for this alternative with theexception that groundwater treatment would be required until theuntreated groundwater characteristics approach the effluent limitsestablished in the NPDES limit.

4.3.13 Alternative 5A - Multilayer cap (RCRA); groundwater extractionand treatment at an off-site RCRA treatmentfacility

The major components of Alternative 5A are:

o Access and deed restrictions;o Installation of multilayer cap over the site;o Extraction of groundwater for treatment at an off-site RCRA

treatment facility;o Backfilling of on-site pond.

Access and Deed Restrictions

Access and deed restrictions discussed for Alternative 1A would alsoapply to this alternative. However, the deed restrictions would bepermanent since the contaminants associated with the landfill would beleft in place.

Multilayer Cap

The approach to installation of a cap is the same as discussed forAlternative 4A with the exception that a multilayer cap instead of asanitary landfill cap would be utilized. The multilayer cap wouldconform to the RCRA standards for closure of hazardous landfill. Theamount of infiltration into the landfill would be significantly lesscompared to the sanitary landfill cap. The major advantage of the

Page 111: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-16 of 22

miltilayer cap over the sanitary landfill cap is the increased safetyfactor due to two impervious layers. The miltilayer cap consists of abedding layer installed on top of the waste, an impervious layer ofclay (2 feet) , a second impervious layer (20 mil synthetic membrane) ,a drainage layer (1 foot) a tqpsoil layer and a vegetative cover. Theinspection and maintenance requirements for the multilayer cap wouldbe the same as discussed for the sanitary landfill cap (Alternative4A).

Groundwater Extraction and Treatment at Of f -Site RCRA TreatmentFacility

The extraction of groundwater and treatment at of f -site RCRA treatmentfacility discussed for Alternative 1A would also apply to thisalternative. Since the contaminants are left in place, groundwaterextraction and transportation to off -site RCRA treatment facilitywould be required until the groundwater contamination reachesbackground value.

Backfilling of On-Site Pond

Discussions presented for Alternative 1A for backfilling of pond wouldalso apply.

4.3.14 Alternative 5B - Multilayer cap (RCRA) ; groundwater extractionand treatment at Publicly-Owned TreatmentWorks

The major components of Alternative 5B are:

o Access and deed restrictions;o Installation of multilayer cap over the site;o Extraction of groundwater and treatment at PCTW;o Backfilling of pond.

The Alternative 5B differs from Alternative 5A only with respect totreatment of extracted groundwater at POTW. Therefore, discussionspresented for access and deed restrictions, installation of multilayercap, groundwater extraction and backfilling of on-site pond forAlternative 5A would also apply to this alternative. The treatment ofextracted groundwater at PCTW discussed for Alternative IB would alsoapply to this alternative with the exception that groundwatertreatment will be required until the untreated groundwatercharacteristics approach background values.

4.3.15 Alternative 5C - Multilayer cap fRCRA) ; groundwater extractionand on-site treatment

The major components of Alternative 5C are:

Page 112: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-17 of 22

o Access and deed restrictions;o Installation of multilayer cap over the site;o Extraction of groundwater and on-site treatment;o Backfilling of pond.

The Alternative 5C differs from Alternative 5A only with respect toon-site treatment of extracted groundwater. Therefore, discussionspresented for access and deed restrictions, installation of multilayercap, groundwater extraction and backfilling of pond for Alternative 5Awould also apply to this alternative. The treatment of extractedgroundwater in on-site facilities discussed for Alternative 1C wouldalso apply to this alternative with the exception that groundwatertreatment would be required until the untreated groundwatercharacteristics approach the effluent limits established in the NFDESpermit.

4.3.16 Alternative 6A - Multilayer cap (RCRA); slurry wall;groundwater extraction and treatment atoff-site RCRA treatment facility

The major components of Alternative 6A are:

o Access and deed restrictions;o Installation of multilayer cap over the site;o Installation of a slurry wall around site perimeter;o Extraction of groundwater for treatment at off-site RCRA

treatment facility.o Backfilling of pond.

The components for this alternative are the same as Alternative 5Awith the addition of a slurry wall around the site perimeter. Theslurry wall- would significantly minimize the groundwater flow throughthe landfill and would result in a decrease in the volume of extractedgroundwater to be treated. The slurry wall/cap system would alsoisolate the landfill from groundwater level fluctuations caused by theMississinewa River. The discussion presented for Alternative 5A foraccess and deed restrictions, installation of a multilayer cap andbackfilling of pond would also apply to this alternative.

A soil-bentonite slurry wall would be placed around the entire siteand would be keyed into the low permeability clay confining layerpresent at the site. This confining layer is present approximately30-35 feet below the surface of the landfill. The backfill materialwould consist of a mixture of excavated soil and bentonite clay.

A portion of the landfill is within 10 to 15 feet from the edge of theriver on the eastern side of the site. In these areas, it will benecessary to construct the slurry wall approximately 70 to 95 feetfrom the edge of the river. This results in a small percentage of the

Page 113: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-18 of 22

overall landfill waste volume to remain outside of the slurry wall.Any fill material excavated during slurry wall construction would bedisposed of on site and incorporated into the existing fill duringsite grading and capping.

The river bank is heavily vegetated with trees and undergrowthresulting in proven bank stability over the previous years. In orderto cap the small percentage of wastes that will remain outside theslurry wall it will be necessary in some areas to remove the trees andundergrowth to install the cap. The benefits gained by capping thewaste outside the slurry wall in those areas may not outweigh theexisting benefit of a stable river bank, especially since the landfillis so close to the river. In addition, the capped waste outside theslurry wall at some locations would also be outside the site floodprotection levees and would be subject to significant erosion andscour during flood events. Therefore for the purposes of alternativeevaluation, the waste outside the slurry wall will be capped only ifcapping does not destroy existing river bank stability and is withinthe flood protection levee.

A multilayer cap would be constructed over the area enclosed by theslurry wall. The multilayer cap would be the same as discussed forAlternative 5A. The slurry wall would require no maintenance ifproper construction methods are employed to effectively key the slurrywall into the confining layer. The maintenance requirement for themultilayer cap would be the same as Alternative 5A.

The groundwater would be extracted and transported to an off-site RCRAfacility for treatment. A drawdown of five feet would be maintainedwithin the slurry wall perimeter to ensure groundwater flow is inwardacross the slurry wall. Groundwater treatment discussed forAlternative 1A would also apply to this alternative. Groundwaterextraction and treatment at off-site RCRA facility would continueuntil the extracted groundwater characteristics reach backgroundlevel. After reaching background level, it would be necessary tocontinue the extraction of groundwater to prevent saturation of thelandfill with groundwater. The uncontaminated groundwater would beextracted and discharged to the Mississinewa River. A dischargepermit must be obtained before site groundwater is discharged to theriver.

4.3.17 Alternative 6B - Multilayer cap fRCRA); slurry wall ar.igroundwater extraction and treatment at aPublicly-Owned Treatment Works fPOIVfl

The major components of Alternative 6B are:

o Access and deed restrictions;o Installation of multilayer cap over the site;o Installation of a slurry wall around the site perimeter;o Extraction of groundwater and treatment at POTW;

. .. o Backfilling of pond. . . . . . .

Page 114: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility Study, Marion/Bragg Landfill Site

Section: 4July 31, 1987Page: 4-19 of 22

The components for this alternative are the same as Alternative 6Awith the exception of treatment of groundwater at POTW. Therefore,discussions presented for Alternative 6A for access and deedrestrictions, installation of slurry wall, multilayer cap andbackfilling of pond would also apply to this alternative. Thetreatment of extracted groundwater at POIW discussed for AlternativeIB would also apply to this alternative. The groundwater extractionand treatment would continue until the extracted groundwatercharacteristics reach background level. After reaching backgroundlevel, it would be necessary to continue extraction of groundwater toprevent saturation of the landfill with groundwater. Theuncontaminated groundwater would be extracted and discharged to theMississinewa River. A discharge permit must be obtained before sitegroundwater is discharged to the river.

4.3.18 Alternative 6C - Multilayer cap, slurry wall; and groundwaterextraction and on-site treatment

The major components of Alternative 6C are:

o Access and deed restrictions;o Installation of a multilayer cap over the site;o Installation of a slurry wall around the site perimeter;o Extraction of groundwater and on-site treatment;o Backfilling of pond.

The components for this alternative are the same as Alternative 6Awith the exception of on-site treatment of groundwater. Therefore,discussions presented for Alternative 6A for access and deedrestrictions, installation of slurry wall, multilayer cap, and pondbackfilling would also apply to this alternative. The on-sitetreatment of extracted groundwater discussed for Alternative 1C wouldalso apply to this alternative. The groundwater extraction andtreatment would continue until the groundwater characteristicsapproach the effluent limits established in the NPDES permit. Afterreaching this level, the extracted groundwater would be discharged tothe Mississinewa River without any treatment.

4.3.19 Alternative 7A - Indiana sanitary landfill cap; slurry wall;and qroundwater extraction and treatment atoff site RCRA treatment facility

The major components of Alternative 7A are:

o Access and deed restrictions;o Installation of Indiana sanitary landfill cap over the site;o Installation of a slurry wall around the site perimeter;o Extraction of groundwater for treatment at off site RCRA

treatment facilityo Backfilling of pond

Page 115: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-20 of 22

The components of this alternative are the same as Alternative 4A withthe addition of a slurry wall around the site perimeter as discussedfor Alternative 6A. Access and deed restrictions, installation of asanitary landfill cap and backfilling of the pond discussed forAlternative 4A would also apply. The approach for groundwaterextraction and treatment at an off site RCRA treatment facilitydiscussed for Alternative 6A would also apply to this alternative.

4.3.20 Alternative 7B - Indiana sanitary landfill cap; slurry wall;and qroundwater extraction and treatment atPublicly-Owned Treatment Works (POTW

Hie major components of Alternative 7B are:

o Access and deed restrictions;o Installation of Indiana sanitary landfill cap over the site;o Installation of a slurry wall around the site perimeter;o Extraction of groundwater and treatment at POIW;o Backfilling of pond.

The corponent of this alternative are the same as Alternative 7A withthe exception of treatment of groundwater at POIW. Therefore,discussions presented fcr Alternative 7A for access and deedrestrictions, installation of Indiana Sanitary Landfill cap, slurrywall and backfilling of the pond would also apply to this alternative.The approach for groundwater extraction and treatment at POIWdiscussed for Alternative 6B would also apply to this alternative.

4.3.21 Alternative 7C - Indiana sanitary landfill cap; slurry wall;groundwater extraction and on-site treatment

The major components of Alternative 7C are:

o Access and deed restrictions;o Installation of Indiana sanitary landfill cap over the site;o Installation of slurry wall around the site perimeter;o Extraction of groundwater and on-site treatment;o Backfilling of pond.

The components of this alternative are the same as Alternative 7A withthe exception of on-site treatment of groundwater. Therefore,discussions presented for Alternative 7A for access and deedrestrictions, installation of Indiana sanitary landfill cap and slurrywall and backfilling of the pond would also apply to this alternative.The approach for groundwater extraction and on-site treatmentdiscussed for alternative 6C would also apply to this alternative.

Page 116: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-21 of 22

4.3.22 Alternative 8 - Indiana sanitary landfill cap; and monitoring

The major component of Alternative 8 are:

o Access and deed restrictions;o Installation of Indiana sanitary landfill cap over the site;o Monitoring.

The components of this alternative are the sane as Alternative 4Awith the exception that groundwater would net be extracted fortreatment. Access and deed restrictions and installation of asanitary landfill cap discussed for Alternative 4A would also apply tothis alternative.

Groundwater flowing through the landfill discharges into theMississinewa River. To monitor t±a migration of contaminatedgroundwater to the river, monitoring wells will be installed to allowgroundwater sampling. Groundwater, river water and pond water will beanalyzed for parameters of concern. Monitoring wells, on-site pondwater and river water would be sampled and analyzed at a frequencydetermined by the Indiana Department of Envirci-srvental Managd-ient.

The time for groundwater to reach Mississinewa River from the upstreamside of the site is relatively short and in the order of 2.2 years.If contamination is detected -in groundwater, sufficient time will notbe available for installation of extraction wells for providingtreatment of groundwater either in PC7IW or on-site treatment facility.Based on the low level of contamination detected in groundwater, andthe fact that the upper aquifer has been porged over seven timesduring the last 15 years, the likelihood of groundwater contaminantlevel increasing over the existing quality is unlikely.

The purpose of monitoring will be to determine compliance with actionlevels established by the Indiana Department of EnvironmentalManagement. (Refer to Section 6.2.2 for discussion on monitoring.)If monitoring indicates that action levels are exceeded, correctiveaction, such as groundwater extraction and treatment, will beconsidered for implementation by regulatory agencies.

4.3.23 Alternative 9 - Multilayer cap and monitoring

The major components of Alternative 9 are:

o Access and deed restrictions;o Installation of multilayer cap (RCRA) over the site;o Groundwater monitoring

Page 117: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 4July 31, 1987Page: 4-22 of 22

The components of this alternative are the same as Alternative 5A withthe exception that groundwater would not be extracted for treatment.Access and deed restrictions and installation of the multilayer capdiscussed for Alternative 5A would also apply to this alternative.

Discussions presented for Alternative 8 regarding groundwater, riverwater and pond water monitoring would also apply to this alternative.

4.3.24 Alternative 10 - No action

Under this alternative, no further remedial actions will be taken atthe site. Monitoring of on-site pond, groundwater and MississinewaRiver will not be undertaken. Endangerment to public health, welfare,and the environment as presented in the Public Health Evaluation(Section 2) will not be mitigated.

Page 118: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 5July 31, 1987Page 5-1 of 11

SECTION 5

SCREENING OF ALTERNATIVES

5.1 INTRODUCnON

The assembled alternatives presented in Section 4 are subjected to aninitial screening to reduce the list of potential remedial actions fordetailed analysis. The purpose of initial screening is to eliminatesome of the alternatives from further consideration usingeffectiveness, implementability and cost as screening criteria. Allalternatives considered in Section 4 for the Marion/Bragg site aretechnically feasible and implementable and will be carried forward fordetailed evaluation with the exception of alternatives that areeliminated during the initial screening as discussed in this section.

Alternatives that are subjected to the initial screening include:

o Disposal of landfill contents in off-site RCRA land disposalfacility;

o Incineration of landfill contents in off-site RCRAincineration facility;

o On-site incineration of landfill contents;

o Determination of the need for a slurry wall as a verticalbarrier to minimize the amount of groundwater to beextracted for treatment;

o Feasibility of groundwater treatment in off-site, RCRAtreatment facility.

Disposal of Marion/Bragg landfill contents in off-site landfill andoff-site incineration facilities are source control alternatives thatwould eliminate the need for long-term management of the siteincluding monitoring. On-site incineration of the landfill contentsis also a source control option.

Groundwater can be treated either in on-site facilities, off-site RCRAtreatment facility or treated at the Marion Publicly Owned TreatmentWorks (POIW). The Mississinewa River flows in close proximity to thesite. In order to prevent migration of groundwater to the river, thegroundwater gradient must reversed, inducing river water to flowto the site from the river. Groundwater would then be extracted andtreated. An estimate of the volume of groundwater to be extracted fortreatment with and without slurry wall as a vertical barrier (in

Page 119: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 5July 31, 1987Page 5-2 of 11

addition to providing a surface cap of the landfill) is presented inAppendix A. This analysis indicates that the volume of groundwater tobe extracted for treatment without a slurry wall is 1,870 gal/minute.Construction of a slurry wall around the site significantly reducesthe volume of groundwater to be extracted. It is estimated thatapproximately 70 gal/minute of groundwater will be extracted fortreatment with a slurry wall in place. The relative cost ofgroundwater treatment at the Marion POTW will be used as the principalcriteria for the construction of a slurry wall at the Marion/Braggsite to minimize the volume of groundwater to be extracted fortreatment.

Groundwater treatment in off-site RCRA facility will be evaluated todetermine whether this option is technically feasible forconsideration.

5.2 OFF-SITE DISPOSAL IN RCRA LAND DISPOSAL FACILITY

Section 121 of the Superfund Amendments and Reauthorization Act of1986 (SARA) mandates cleanup standards provisions to which allSuperfund sites must comply. This section requires that off-sitefacilities accepting wastes from 'a Superfund site for disposal must bein compliance with the Solid Waste Disposal Act, Toxic SubstancesControl Act, or other applicable federal laws which govern thedisposal facilities operation. Off-site facilities which could beconsidered for disposal of Marion/Bragg landfill contents arepresented here. Cost estimates for disposal are based on thesefacilities. It should be noted that other off-site facilities may beavailable by the time the remedial action, is implemented. Costs fordisposal at these facilities are assumed to be the same as describedherein.

Off-site RCRA land disposal facilities that can be potentiallyconsidered for disposal of Marion/Bragg landfill contents are:

o Chemical Waste Management landfills located at Fort Wayne,Indiana (Adams Center facility) and Emelle, Alabama;

o Wayne Disposal, Detroit, Michigan.

The estimated quantity of landfill contents at the Marion/Bragg siterequiring off-site disposal is approximately 1.1 million cubic yardsdistributed over an area of 45 acres.

A brief discussion on the capability of these landfills to handle thewastes from the Marion/Bragg site is provided.

Page 120: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarioryBragg Landfill SiteSection: 5July 31, 1987Page 5-3 of 11

5.2.1 Adams Center Facility, Fort Wayne, Indiana

This facility is located approximately 50 miles from the Marion/Braggsite. The available capacity at this landfill is approximately500,000 cu. yds. The landfill is currently being expanded to provideadditional capacity of 500,000 cu. yds. The capacity available atthis facility will not accommodate the estimated 1.1 million cubicyards from the Marion/Bragg site. Discussions with Chemical WasteManagement personnel indicate that 150 acres of land adjoining thefacility (presently not owned by Chemical Waste Management) can beacquired and a dedicated landfill cell can be constructed to handleMarion/Bragg wastes if permission is granted by U.S. EPA. A dedicatedcell can be constructed within a year after permission is obtainedfrom U.S. EPA.

The use of the Adams Center facility is considered technicallyfeasible since a dedicated cell could be constructed to comply withthe RC3A standards for landfill. Implementation would requireobtaining approval from U.S. EPA for construction of a dedicated cell.Since the facility will be constructed to meet P.CRA standards, it isconsidered reliable.

The wastes can be excavated and transported to the landfill at amaximum rate of 100 truck loads/day (1500 cu. yds/day). At this rate,it would take 750 days (round the clock operation) to completelyexcavate and transport the material for disposal. Following removalof contaminated material, the site will be backfilled and providedwith a vegetative cover.

The following unit costs were used to estimate the total costassociated with off-site disposal:

Disposal $120/cu. yd.Transportation $3/mile (for 15 cu. yds. capacity)Excavation $12/cu. yd.Backfilling and grading $7/cu. yd.Vegetative cover $2,000/acre

The total estimated cost for off-site disposal, at the Adams Centerfacility is:

Disposal 132 million dollarsTransportation 11 million dollarsExcavation 14 million dollarsBackfilling 8 million dollarsVegetative cover 0.1 million dollarsTotal Cost 165.1 million dollars

Page 121: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 5July 31, 1987Page 5-4 of 11

5.2.2 Emelle, Alabama Facility

This facility is located approximately 650 miles from the Marion/Braggsite. The existing capacity at the landfill is one million cubicyards and a new cell with an additional capacity of one million cubicyards is being constructed. Chemical Waste Management indicated thatthey would not consider using the existing capacity for Marion/Braggwastes. Sufficient land is, however, available at this facility forconstruction of a dedicated cell to handle Marion/Bragg wastes.The previous discussion presented for technical feasibility,implementability and reliability for Mams Center facility is alsoapplicable for this facility.

The total estimated cost for off-site disposal at the Emelle, Alabamafacility using unit costs for the Adams Center facility, is asfollows:

Disposal 132 million dollarsTransportation 139 million dollarsExcavation 14 million dollarsBackfilling 8 million dollarsVegetative cover 0.1 million dollarsTotal cost 293.1 million dollars

Since the transportation cost to the Emelle facility is significantlyhigher compared to the transportation cost to the Adams Centerfacility, consideration of the Adams Center facility for disposal ofthe Marion/Bragg wastes is more appropriate.

5.2.3 Wayne Disposal, Detroit. Michigan

This facility is located approximately 200 miles from the Marion/Braggsite. This facility has recently started a new cell with a capacityof 700,000 cubic yards. Two additional new cells will be constructedas an expansion of the existing facility. The total availablecapacity at this landfill will be 2.5 million cubic yards. Discussionwith Wayne Disposal personnel indicate that this facility can accept amaximum of 1,000 cu. yds/day of Marion/Bragg waste in addition toserving the needs of existing clients. Since this is a permittedfacility, it can be considered reliable. Disposal at this facility isconsidered technically feasible and implementable because capacity isavailable. At 1,000 cu. yds/day, it would take approximately 1,100days (round the clock operation) to excavate and transport thematerial for disposal.

The cost of disposal at this facility is $125-150/cu. yd. The unitcosts for transportation, excavation, backfilling and providing avegetative cover previously presented for the Adams Center facilityare also applicable.

Page 122: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 5July 31, 1987Page 5-5 of 11

The total cost of disposal of Marion/Bragg wastes at the WayneDisposal facility is:

Disposal 137 million dollarsTransportation 44 million dollarsExcavation 14 million dollarsBackfilling 8 million dollarsVegetative cover 0.1 million dollarsTotal cost 203.1 million dollars

5.2.4 Summary of Evaluation of Disposal in Off-Site RCRA Landfill

The large volume of contaminated material present at the site posesseveral problems for off-site disposal. The capacity is not presentlyavailable at two of the facilities considered (Adams Center at FortWayne, Indiana and Emelle, Alabama). However, land can be madeavailable at both of these facilities for construction of a dedicatedlandfill cell specifically to handle Marion/Bragg wastes. Theconstruction of a dedicated cell at both of these locations requirepermits to be granted by U.S. EPA. One year would be required toconstruct the cell after permit is granted. Capacity is available atWayne Disposal facility and it is also a permitted facility.

Off-site land disposal is considered technically feasible,implementable and reliable. However, a major constraint is the needto obtain permission for the construction of a dedicated p*»ll fordisposal at both the Adams Center and Fjnelle facilities. The time toimplement off-site disposal varies from 750 to 1100 days for the roundthe clock operation and may take longer if inclement weather delaysexcavation at the site. Off-site disposal involves transportation of73,000 truck loads of contaminated material through major highways.Potential for accidents and spill of material exists duringtransportation.

The disadvantage of off-site disposal is it does not provide anytreatment and results in significant cost. SARA emphasizes treatmentfor permanent destruction where feasible. The least desirable optionis moving untreated wastes from one location to another. In addition,off-site disposal would be an order of magnitude higher than on-sitecontainment alternatives. On-site waste containment can be providedat a significantly lower cost and provide adequate protection of theenvironment and human health. For the above reasons, off-sitedisposal in a RCRA landfill facility is not considered viable from acost and technical standpoint and, therefore, this alternative will beeliminated from further consideration and will not be carried forwardfor detailed evaluation.

Page 123: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 5July 31, 1987Page 5-6 of 11

5.3 DISPOSAL OF LANDFILL CONTENTS IN OFF-SITE INCINERATION FACILITY

Potential for disposal of landfill contents from the Marion/Bragg sitein off-site, P>CRA incineration facility was evaluated. Two of thepermitted facilities incinerate only liquids and are not permitted forincineration of contaminated soils (Caldwell Systems, Lenoir, NorthCarolina and Old Over, Aquadale, North Carolina). There is anotherfacility in Kentucky (LWD, Calvert City, Kentucky) which has a rotarykiln for incineration of contaminated soil. Discussion with LWDpersonnel indicated that they do not have capacity and would notconsider incineration of an estimated 1.1 mill -ion cubic yards fron theMarion/Bragg site in their facility.

SCA Services, Chicago, can provide incineration of contaminated soil.This facility has a rotary kiln with a capacity of 32 tons/day. Allfeed materials must be containerized in 30 gallon fiber orpolyethylene drums. Exist.ing commitments limit the use of thisfacility for incineration of Marion/Bragg wastes. Even if SCA'sentire incineration capacity could be dedicated for incineration ofMarion/Bragg wastes, it would take approximately 100 years toincinerate an estimated 1.1 million cubic yards of wastes from theMarion/Bragg site.

The estimated cost of incineration at the SCA's facility is based onthe following unit costs:

Disposal $1.50/poundTransportation $3/mileExcavation $12/cu. yd.Backfill $7/cu. yd.Fiber drum $8/drum

It would require 11 million fiber drums (each drum holding 200 poundsof soil) to containerize the material prior to incineration.

The total estimated cost of off-site incineration is:

Incineration 3,295 million dollarsTransportation 33 million dollarsDrums 89 million dollarsExcavation 14 million dollarsBackfill 8 million dollarsTotal cost 3,439 million dollars

For reasons of technical infeasibility and cost, off-site incinerationis eliminated from further consideration and will not be carriedforward for detailed evaluation.

Page 124: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 5July 31, 1987Page 5-7 of 11

5.4 ON-SITE INCINERATION

On-site incineration utilizing transportable rotary kiln units wasconsidered. Ihese units can be brought to the site and assembled tooperate as a fixed unit. Transportable units can be dismantled andmoved off site at the completion of the operation. However, a RCRApermit has not been issued for transportable units. The incinerationof contaminated soil would provide only minimal volume reduction. Theash resulting from incineration (which could be 85-90% of the originalvolume) requires landfilling either on site or at an off-sitefacility. Permission must be obtained from the State of Indiana forincineration. However, the current state of Indiana law prohibits theuse of mobile incineration for wastes. Public opposition toincineration of a large quantity of material at this site is likely.

Transportable rotary kiln units are available for lease from ENSOOEnvironmental Services. They presently have three units and two moreunits will be available in September 1987. Each transportable unitcan incinerate up to 5 tons/hour. ENSCO has conducted trial burntests utilizing the transportable units and has achieved RCRA and TSCAcriteria. Permits have been applied for but have not been issued.A limited on-site trial burn may be required to determine that permitconditions established for the transportable unit can be achieved.

At an incineration capacity of 5 tons/hour, it would takeapproximately 25 years, utilizing a single transportable unit, toincinerate an estimated 1.1 million cubic yards of waste present atthe Marion/Bragg site. Use of multiple units at the site can reducethe time for incineration.

The cost of incineration utilizing ENSCO as a subcontractor isestimated at $300-500/cubic yard. This cost includesmobilization/demobilization of the unit, operating the system, supplyof fuel and disposal of wastewaters generated from incineration stackgas scrubbing. Excavation and backfilling of ash and providing a soilcover would cost $12 and $5/cubic yard, respectively.

The total estimated cost of on-site incineration is:

Incineration 384 in-ill inn dollarsExcavation 14 million dollarsBackfilling 6 million dollarsTotal cost 404 million dollars

On-site incineration is not considered technically feasible becausetransportable units have not been permitted and implementation isdifficult because of likely public opposition. Incineration is notamenable for inorganics present at the site. The time frame foron-site incineration is considerable, approximately 25 years. The

Page 125: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 5July 31, 1987Page 5-8 of 11

cost of on-site incineration is also significant. For these reasons,on-site incineration of landfill contents is eliminated from furtherconsideration and will not be carried forward for detailed evaluation.

5.5 GROUNDWATER EXTRACTION

Contaminated groundwater at the site requires extraction prior totreatment. In order to prevent migration of groundwater to theMississinewa River, an inward gradient must be maintained within thesite. This inward gradient induces river water to flow towards thesite and will be extracted as part of the groundvater. An estimate ofthe groundwater to be extracted to prevent migration to the riverindicates a rate of 1,870 gallons/minute based on informationpresented in Appendix A. When a slurry wall is provided around thesite, the amount of groundwater to be extracted for treatment isapproximately 70 gallons/minute. This includes leakage through theslurry wall (7 gal/min), infiltration through the Indiana sanitarylandfill cap (10 gal/min) and precipitation into the pond (36 gpm) andrunoff into the on-site pond from an estimated 50% of the 45 acre site(13 gal/min). Thus, it is apparent that construction of a slurry wallaround the site significantly reduces the amount of groundwater to betreated.

The extracted groundwater can be treated at the Marion POTW.Correspondence with Marion POTW personnel indicated that they canhandle up to 250 gal/min of groundwater from the Marion/Bragg sitewithout overloading their system. The Marion POTW has a designcapacity of 12 mgd. The present flow handled by the Marion POTW isapproximately 9 mgd. The cost of treatment at the Marion FOTW is$1/100 eft and a 13.6 cents/pound surcharge for COD over 400 ppm.Based on analysis of groundwater made during the remedialinvestigation, the average COD of groundwater is 500 ppm. Thus, asurcharge for COD must be paid in addition to the fee for volume ofwater discharged.

Discharge of groundwater for treatment at the Marion POTW wasevaluated to determine the relative difference in cost of groundwatertreatment with and without a slurry wall around the site. It isassumed, for comparative evaluation, that 1,870 gal/min of groundwaterextracted without a slurry wall can be discharged to the Marion POTW.Treatment in on-site facility was not considered in this evaluationbecause discharge to PCTW will cost less compared to on-sitetreatment. Using the cost obtained from Marion POTW, the annual costof treatment at the Marion POTW for flow rates of 1,870 gal/min(361,000 eft/day) and 70 gal/min (13,500 eft/day) were estimated. Theexcess COD over 400 ppm amounts to 2,250 Ibs/day for 1,870 gal/minflow and 85 Ibs/day for 70 gal/min flow. The estimated annual costsof treatment at the Marion POTW are as follows:

Page 126: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 5July 31, 1987Page 5-9 of 11

1,870 gal/min flow 70 gal/min flow(Without Slurry Wall) fWith Slurry Wall)

Cost for flow, $/day 3,610 135COD surcharge, $/day 310 12Total daily cost $3,920 $147Total annual cost $1,430,800 $53,655

The present worth cost of $l,430,800/year for 30 years at 10% interestrate is 13.5 million dollars. The slurry wall to be provided aroundthe site requires a length of 7,100 feet and will be keyed into theconfining layer which is present at the site at an average depth of 35feet. The estimated cost of constructing a slurry wall is 3 milliondollars.

It is clear from the cost analysis that constructing a slurry wallaround the site is preferable to minimize the amount of groundwater tobe extracted for treatment. The volume of groundwater extractedwithout a slurry wall is large and cannot be handled by the MarionPCTW. Therefore, providing a slurry wall in conjunction with surfacecapping will be carried forward for detailed evaluation foralternatives involving groundwater treatment.

5.6 GROUNDMATER TREATMENT IN OFF-SITE TREATMENT.FACILITY

Off-site RCRA treatment facilities were evaluated to determine thefeasibility of treatment of groundwater from the Marion/Bragg site.Three facilities were evaluated that can provide treatment forgroundwater. These facilities are: Chem-Clear, Chicago, Illinois;Envirite, Harvey, Illinois; and Cyanokem, Detroit, Michigan.

Chem-Clear treatment facility provides for neutralization, chemicalcoagulation, filtration and sludge dewatering. The treated effluentis discharged to the Metropolitan Sanitary District of Greater Chicago(MSDGC) sewer. The maximum treatment capacity at this plant is200,000 gallons/day. Discussion with Chem-Clear personnel indicatedthat this facility can handle a maxim-im of 20,000 gallons/day ofgroundwater from the Marion/Bragg site. The cost of treatment at thisfacility is 10 cents/gallon. The cost of transportation of water tothis facility is $3.20/mile for 5,000 gallon truck. This facility islocated approximately 150 miles from the Marion/Bragg site.

Envirite treatment facility provides for metals precipitation,filtration and sludge dewatering. The treated effluent is dischargedto the sewer of MSDGC. The maximum treatment capacity at this plantis 100,000 gallons/day. Discussion with Envirite personnel indicatedthat this facility can handle a maximum of 20,000 gallons/day from asingle source. The cost of treatment at this facility is 20

Page 127: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility studyMarion/Bragg landfill SiteSection: 5July 31, 1987Page 5-10 of 11

cents/gallon. The cost of transportation of water to this facility is$4/mile for 5,000 gallon truck. This facility is locatedapproximately 150 miles from the Marion/Bragg site.

Cyanokem treatment facility provides for metals precipitation,neutralization, clarification and activated carbon adsorption. Theeffluent is discharged to the City of Detroit's sewer. Maximumtreatment capacity at this plant is 200,000 gallons/day. Discussionwith Cyanokem personnel indicated that this facility can handle aflow of 27,000 to 36,000 gallons/day from the Marion/Bragg site. Thecost of treatment at this facility is 40 cents/gallon. The cost oftransportation of water to this facility is $4/mile for 5,000 gallontruck. This facility is located approximately 200 miles from theMarion/Bragg site.

An evaluation of the available RCRA facilities that can providetreatment of groundwater indicates that capacity is not available inany of the facilities for an estimated groundwater flow of 70 gal/min(with slurry wall in place) from the Marion/Bragg site. Therefore, itis determined that groundwater treatment ii. an off-site facility isnot technically feasible.

The estimated cost of treatment at these facilities, includingtransportation costs, are:

Name of Facility Cost. Cents/Gallon

Chem-Clear 20Envirite 32Cyanokem 56

For ccanparison, the cost of treatment at the Marion POIW is only 0.15cents/gallon. It is, therefore, apparent that groundwater treatmentin off-site treatment facility costs significantly more compared totreatment at the Marion POIW.

For reasons of lack of available capacity, transportation costs, andcost of treatment, off-site RCRA treatment of groundwater is notconsidered technically feasible. Therefore, groundwater treatment inoff-site facility will be eliminated from further consideration andwill not be carried forward for detailed evaluation.

5.7 SUMMARY OF INITIAL SCP' >?TMf; OF ATn'mrtATIVES

Based on detailed evaluations, as presented in this section, thefollowing alternatives were eliminated from further consideration forthe Marion/Bragg site:

Page 128: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 5July 31, 1987Page 5-11 of 11

o Off-site disposal in RCRA landfill;o Off-site disposal in RCRA incineration facility;o On-site incineration of landfill contents;o Off-site groundwater treatment in RCRA facilities.

It has been determined that providing a slurry wall around the sitewould significantly minimize the volume of groundwater to be extractedfor treatment. Therefore, for alternatives involving groundwatertreatment, construction of a slurry wall, in addition to surfacecapping, will be considered during detailed evaluation of thealternatives.

Page 129: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 6July 31, 1987Page 6-1 of 59

SECTION 6

DETAILED ANALYSIS OF ALTERNATIVES

6.1 INTRODUCnON

In this section, alternatives not eliminated during the initialscreening as presented in Section 5 are analyzed in greater detail.This analysis is performed in accordance with 40 CFR 300.68 (h). Thepurpose of the detailed analysis is to evaluate technical, publichealth and welfare, environmental and cost of alternatives developedfor the Marion/Bragg landfill site.

Based on information presented in Section 5, it has been determinedthat off-site disposal of landfill contents in RCRA landfill and RCRAincineration facilities are not feasible because of lack of availablefacilities and cost. On-site incineration of landfill contents hasalso been determined to be costly and technically not feasible. Forthese reasons, off-site disposal of landfill contents in RCRA landfilland RCRA incineration facilities; and on-site incineration have beeneliminated from further consideration and will not be included in thedetailed evaluation of the alternatives.

Discussions presented in Section 5 also concluded that construction ofa slurry wall around the site is necessary to minimize the volume ofgroundwater to be extracted for treatment either in an on-sitefacility or discharged to the Marion PCTW for treatment. It has alsobeen determined that groundwater treatment (even with a slurry wall)in an off-site RCRA facility is not feasible due to cost and lack ofcapacity.

The alternatives presented in Section 4 have been re-assembled basedon initial screening of alternatives presented in Section 5. Thealternatives considered for detailed analysis are presented in Table6-1.

All alternatives considered for remediation of the Marion/BraggLandfill site include capping. The capping components meet either theState of Indiana sanitary landfill or RCRA closure requirements. Asstated in Section 2, the results of the Public Health Evaluation (PHE)indicate that there are no current public health risks associated withthe on-site pond. However, the potential for future risk exists. Toaddress the potential remediation for future risks that may beassociated with the pond, each alternative (except No Action) includesa component cost for leaving the pond open and a cost for backfillingthe pond.

Page 130: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-2 of 59

TABLE 6-1

ALTERNATIVES FOR DETAILED EVALUATION

Alternative Number^ ' Components

1 Indiana sanitary landfill cap andmonitoring

2 Multilayer cap (RCRA) and monitoring

3A Indiana sanitary landfill cap, slurry wall,groundwater extraction and on-site treatment

3B Indiana sanitary landfill cap, slurry wall,groundwater extraction and discharge to MarionPOTW

4A Multilayer (RCRA) cap, slurry wall, groundwaterextraction and on-site treatment

4B Multilayer (RCRA) cap, slurry wall, groundwaterextraction and discharge to Marion POTW

5 No action

* 'All alternatives, except Alternative 5, have access and deedrestrictions and flood control measures.

Page 131: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-3 of 59

Landfill capping requires final grades of 4-5% to be used to minimizeinfiltration and prevent erosion of the cap surface. In order toobtain these final grades, two site grading options have beenevaluated for each capping alternative. The first grading option isto construct a cap without any disturbance to the existing landfill.This option has been included in each alternative because it would notinvolve excavation into the waste and would have less health andsafety risks during construction. However, this would involve the useof significant volumes of off-site borrow materials to construct a capto the required final grades. The second grading option is to regradethe site to a pre-cap grade approaching the required final grades.This option has been included in each alternative because it wouldsignificantly reduce the volume of off-site borrow material required.In addition for alternatives that include pond backfilling, regradingof the site would significantly reduce the volume of off-site borrowmaterial required to fill the pond. In all alternatives involvingpond backfilling, clean off-site borrow material would be required tofill the pond up to the existing pond water level because wastescannot be disposed of in standing water bodies. The regrading optionallows the use of existing landfill materials to be used to fill thepond to the final grade above the water level.

For reasons stated above, each capping alternative would have foursubalternatives carried through detailed analysis. Thesesubalternatives are:

o Cap installed over the existing fill with on-site pondremaining open;

o Cap installed over the existing fill with backfilling ofon-site pond;

o Cap installed after regrading the existing fill with on-sitepond remaining open;

o Cap installed after regrading the existing fill withbackfilling of on-site pond.

The detailed analysis presented is not intended to be all inclusiveand encompassing, but it is intended to present sufficient informationconcerning each alternative to allow for a comparative evaluation.Additional information and considerations should be addressed duringthe detailed design of the selected alternative to better define theimplementation of the alternative.

6.2 DISCUSSION OF TECHNICAL COMPONENTS OF ALTERNATIVES

Alternatives presented in Table 6-1 have the following majorcomponents:

Page 132: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-4 of 59

o Access and Deed Restrictionso Monitoringo Flood Control Measureso Cap (Indiana Sanitary Landfill or RCRA)o Slurry Wallo Groundwater Extractiono Groundwater Treatment (On-Site or at Marion POIW)

6.2.1 Access and Deed Restrictions

The site is presently not fenced and therefore, access to the site isunrestricted. Fencing of the entire landfill site would limit publicaccess to the site and would limit exposure to contaminants present inthe landfill and also limit access to the on-site pond forrecreational purposes, including boating, swimming and fishing.

Each alternative, except the No-Action alternative, includes theinstallation of 7,100 feet of an eight-foot chain-link fence with abarbed wire top around the entire site with appropriate access gatesand warning signs. The location of the perimeter fence is shown inFigure 6-1.

Deed restriction for the site would be required for an •indefiniteperiod of time since waste will remain at the site. Deed restrictionswould be incorporated in all alternatives except the No Actionalternative. The purpose of deed restrictions would be to preventfuture development of the land to protect against direct contact withcontaminants during any future site excavation. The deed restrictionwould also prohibit the use of groundwater or installation of wells onsite.

Marion Paving Company and Dobson Construction Company are located onthe southwest corner of the site, and each utilize a private wellinstalled in the upper aquifer. Due to the potential forcontamination of these wells, they will be abandoned and plugged. Inaddition, a private residence, located on site near the Marion PavingCompany, also has a private well. This well has not been used forseveral years. As a precautionary measure, this well will also beabandoned and plugged. New wells will be installed at the same threelocations; however, these new wells will be installed in the loweraquifer. The lower aquifer is separated from the upper aquifer by animpermeable layer that would prevent contamination of the loweraquifer.

6.2.2 Monitoring

Alternatives 1 and 2 include Bonitoring of the on-site pond (if leftopen), groundwater, and Mississinewa River for the purpose ofconformance to the established action levels.

Page 133: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

0

Legend

—~ Site Boundary

'////, Marion Paving Co., Inc.

+%& Dobson Construction Co., Inc.

Private Residence

Scale in Feet

0 250 500

•X— Site Fence

••• Flood Protection Levee

•':•••'.'• 100 Year Flood Plain

Figure 6-1Access Rentrlctlons, 100 Year Flood Plain, Flood Protection Levee

Ml Alternatives Except No Acti -

Page 134: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-6 of 59

The characteristics of groundwater from the site vary widely acrossthe site. The site is approximately one-half mile long along theMississinewa River. In order to determine the characteristics ofgroundwater discharges to the Kississinewa River, the site will bedivided into four zones, as shown in Figure 6-2, for the purpose ofmonitoring groundwater discharges to the Mississinewa River fromindividual zones. Two monitoring wells screened in the upper acquiferwill be installed in each zone to characterize groundwater.

The criteria for discharge of groundwater to the Mississinewa Riverhas been established by the Indiana Department of EnvironmentalManagement (IDEM), based as NPDES discharge approach. IDEM iscurrently changing their water quality standards and, therefore, bothexisting and proposed regulations are presented. The applicableconcentration limits for discharge to the Mississinewa River forcontaminants known to be present in groundwater at the Marion/Braggsite are shown in Table 6-2. The concentration limits for dischargeof groundwater to the Mississinewa River are based on the following:

ExistincT Regulation

Noncarciriogens: Concentration limits are based on the lowest valueobtained by either multiplying the chronic water quality criteria bydilution of the groundwater flow from each zone at one-half of the 7day 10 year low flow (9 cfs) in the Mississinewa River, or multiplyingthe acute water quality criteria by dilution at twice the groundwaterflow from each zone.

Carcinogens: Concentration limits are based on a site-wide basis bymultiplying the 10~ cancer risk criteria by dilution of groundwaterflow from the site (0.35 cfs) at one-fourth median flow in theMississinewa River (44.7 cfs).

Proposed Regulation

Noncarcinogen: Concentration limits are based on the most restrictivevalue obtained by either the acute water quality criteria withoutdilution, or the chronic water quality criteria multiplied by dilutionof the groundwater flow from each zone at one-half of the 7 day 10year low flow (9 cfs) in the Mississinewa River.

Carcinogens: Concentration limits are based on a site-wide basis bymultiplying the 10~ cancer risk criteria by dilution of groundwaterflow from the site (0.35 cfs) at one-fourth median flow in theMississinewa River (44.7 cfs).

Both existing and proposed regulations are based on protecting surfacewater quality. IDEM has adopted the federal water quality criteria.

Page 135: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Legend

• ' Site Boundary

'////, Marion Paving Co., Inc.

«Dobson Construction Co.,

Private Residence

Area to be Capped if the On-sitePond is not Backfilled

Q.

DOWNSTREAM SAMPLE

Additional Area to be Capped if .the On-site Pond is Backfilled

New GroundwaterMonitoring Wells

Surface Water Sample Location

Estimated Grotmdwator Flowfrom each Zone

UPSTREAM BACKGROUND SAMPLE

Figure 6-2Indiana Sanlta Landfill Cap or Multilayer (RCRA"1 Cap, Monitoring

Alternatives 1 and 2 V

Page 136: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Iibli k-tuiiiry of (raundmtir Suplin) Hisultt ind App l i cab le

EroyndKtirlimti)jtl«i liiplnlil

No. gf Poll tl viDetection!/Do. of Villd

CtMtltufltl OblK>ltllHll(tl

VDl»t RES, l.l/l 1

1,1-licKloroitkinilenientCMoroeliieniEthylbeniiniSlyriniIitrickloroitftiftitr.ni-|,2-tuhloroitkiiiiIriciloroelheneTotil Ivlentl

SCniVOUIIUS,lu)/tl

1,4-lichloroeeminilenioic Acidkli-12-itnylhnyllphthilitili-»-l«tylpMh«Uli

INO«MNlC8,lu)/ll

trunklirinlirvlllulCidiluiIronLeidfliineitulAin)initiEllvirSod imline

COUVCITIOML POUUIIIIITI.lM/ll

AieoMi «itro)in

1/219/214/214/211/211/214/213/213/21

1/211/219/211/21

10/2121/21

1/211/21

12/211/21

21/212/211/21

21/211/21

14/24

>UI)I Ol

Illicit on

0.9J1.3 - 124 - Ii1.3 - 9

3.30.71

.24 - 200.9 - 7.1J.3 - 7.3

14950

9 - 100099

11 - 7139 • 1440

41

232 • 107004

24600-13000424 - 441

9.29160-233000

III

0-24

Stindirdi for Eroutidntir Onckir)idto fluiliiinni River Id

Eiiitli)

tillyKill Ml

————————————————....

....

....

....

....

——....— -22.4....

574.2DCNC

20.4NC

227

l4.3(tuMtr>

Lon)-ttriAvenge

NC5101

19,50032,0001)1

NC1131

133,0001)145,0001)1

NE

11201)1HE

77.11)1941)1

2.2NC

1.310.3

25,700249.9

NENC

9.4DC

483

I.IUutiifl17.093liintirlB.3(«iBlir>

Propond

(lily lon)-tiriNII mi (viri)i

NC3300

19,300—— 32,0001)1

NC11,300

— - 133,0001)143,0001)1

NC

11201)1NC

— - 77.11)19401)1

22K63

7.6 3.723,700

192.1 90NC NCNC NC

7.8 3.7K ,NC

170 BO

l4.3ltuMirl g.lliullirl17. 0?5I. inter! 8.5lmntrrl

niiiiftinefti niter

Acutt AquiticCritirii

NENCNENCNC

NCNCNENC

NCNCNCNE

....

NEME

14.1-—344.7

NCNC

14.2NE

305.2

5.4U!liu»<r)5.6/4l!«inUrl

Cilltlnq

Chronic AquitlcCntir ii

NCNENCNEIENENEKENC

NCNENENE

....NENC2.8

100013.4

NCNENENE

7 / 4 . 4

O.Bie4(lul»rll .nooUinterl

XlllltllniHi RiverNiter Oulllty Stindirdtlfl

HtiunKiiltk

NE40ld)

NE3290lil

NEB.esidi

NEend)

NE

2tOOIil....

50,000lilIM,OOOI|)

0.0175NE

0. 11 /141

....

....————....

----

....

Acvtl Aqgltic[filer II

NEIENENENEHENENENC

«ENC«CNC

NC....

14.1....

3 4 4 . 7NENE

14.2NE

305.2

3.4l33lsuiierl5.eminnttrl

Propond

Chronic IquiticCritirii

NEHEHEHiNENENEHENE

NENENENE

__

NC....7.8

100013.4

NCNENENC

2 / 4 . 4

0.6l94lfuiitr)1. 13001. mlrl

KuiinHeiltk

NC

4COIE

3760111IE

88. Md)NE

9C7 ld )NE

2400(1)....

50,0'JOIel1 5 4 , 0 0 0 ( e l

0.173NC

I.I/Id)............-.-.................

....

....

il troundutir lupin - 6X02,H03,6«04,6N03,6W6,6N07,6KIO,6KI1,61112,•«!!,6114, Did EN 13II Nuibir ol iiipln ii irl>Uh cKiiicil nil ddictid over the totil nuibir ol lupincl ViUll utibliihid by ludiini Otpirtiint ol En«iroflifntil KinigtiinUIDEIIIdl For CirciiO)inicl(y Protictloi. Cilltln) itindirdt irt kind on lOE-t rut ind propoied ittndirdi iri bistd on 10E-3 nilil For Toi icl ty Predictionfl liter Ou«hty Stiidirdi ii Hiiiiiiinin Ri«ir iitibhihid by IDEM)l Viluli bind on ddtril mtir )u«lity crltirli lor protect ion ol Irtthiitir iquitlc IHilicuti or chronic!NE - Not EttibluM

Page 137: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-9 of 59

The levels shown in Table 6-2 are possible action levels to be net forgroundwater discharges to the Mississinewa River after installation ofa suitable cap over the site. The action level criteria will becompared with the groundwater characteristics from each zone fordetermining compliance with the criteria.

On-site pond should meet water quality criteria unless U.S. EPA setsan alternative concentration limit. This has not been done at thistime.

The proposed sampling locations are shown in Figure 6-2. The proposedlocations include sampling of the following media:

o Monitoring wells (2 locations/Zone) ;

o On-site pond (2 locations);

o Mississinewa River (1 background upstream location, 3 siteperimeter locations, and 1 downstream location).

Each media will be sampled on a quarterly basis. Samples collectedduring the first and third quarters will be analyzed for the completeHazardous Substances List (HSL) for organics and inorganics andammonia. The samples collected during the second and fourth quarterswould be analyzed only for those fractions that indicatedcontamination during the previous quarter sampling. The purpose ofthis sampling is for confirmation of the results of previous sampling.Ammonia will be analyzed in all quarters regardless of the previousquarter sampling results. The above sampling frequency and analyticalrequirements were utilized in estimating the monitoring costs.

Four alternatives (3A, 3B, 4A, 4B) involve groundwater extraction andtreatment (on-site and at the Marion POTW). Monitoring would berequired to assess conformance with the NPDES permit or to provideindication of the level of contaminants discharged to the Marion POTW.Alternatives (3A, 4A) utilizing on-site treatment will requiremonitoring of the treatment system influent and effluent based on theanalytical requirements to be established in the NPDES permit.Alternatives (3B, 4B) utilizing discharge to the Marion POTW, willrequire groundwater monitoring prior to discharge to the POTW. Theparameters to be analyzed for groundwater discharge would beestablished by the Marion POTW. Costs for monitoring of groundwaterdischarges (to Marion POTW or to the Mississinewa River) are based onthe following frequencies and analytical parameters:

o Marion POTW - one sample per month analyzed for allHazardous Substances List (HSL) organics and inorganics andCOD;

Page 138: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-10 of 59

o On-site treatment plant - one sample for week of thetreatment system influent and effluent. These samples willbe analyzed for COD, TOC, metals (arsenic, barium,beryllium, cadmium and silver) and ammonia. In addition,one sample per month of the effluent discharged to theMississinewa River will be analyzed for HSL organics andinorganics.

6.2.3 Flood Control Measures

The northern and eastern portion of the site lies within the 100 yearflood plain elevation of 806.5 at the northwestern corner of the siteand 808.5 at the southeastern corner of the site. All alternativesother than the No Action alternative include the construction of floodcontrol structures. The top of the levee will be at an elevation twofeet over the 100 year flood elevation. The levee will be constructedof compacted soil from off-site borrow sources and will have outsideslope of 3:1 and an inside slope of 2:1. The flood protection leveewill be constructed as close to the river as is technically feasible.Tr. approximate length of the levee is 2,800 feet. The location ofthe levee is shown in Figure 6-1.

The U.S. Army Corps of Engineers HEC-2 Water Surface Profile Model wasused to evaluate the effect of construction of flood control levees atthe Marion/Bragg site on the Mississinewa River 100 year floodelevation. The results of the evaluation indicate that there would beno significant increase in the 100 year flood elevation of theMississinewa River due to on-site levees. The evaluation is presentedin more detail in Appendix B.

6.2.4 Landfill Cap

Two types of landfill caps have been evaluated. These include anIndiana Sanitary Landfill Cap and a multilayer (RCRA) cap. The Stateof Indiana's current requirements for landfill closure requires theuse of two feet of compacted soil with 50% fines overlain by sixinches of top soil and a vegetative cover. Two feet of compactedclayey soil, instead of two feet of compacted soil, has been proposedfor landfill closure by the State of Indiana. Since the current andproposed cap specifications are essentially equivalent, the proposedspecification will be utilized for sanitary landfill closurealternatives.

A multilayer cap involves the closure of the landfill utilizing a RCRA"model" cap. The "model" cap consists of the following: a beddinglayer installed on top of the solid waste, an impervious layer of clay(2 feet), a second bedding layer and a second impervious layer (20 milsynthetic liner), a drainage layer (1 foot) and a vegetative cover.

Page 139: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6JUly 31, 1987Page 6-11 of 59

For each alternative involving capping (Alternatives 1, 2, 3A, 3B, 4A,4B), two site grading options were evaluated. All cappingalternatives require a 4-5% final grade to minimize infiltration andto prevent erosion of the cap surface. The first grading optionconsiders constructing a cap without any disturbance to the existinglandfill. However, this would involve the use of significant volumeof off-site borrow material to construct the cap to the required finalgrade. The second grading option is to regrade the site to a precapgrade approaching the final 4-5% grades. This option is includedbecause it would significantly reduce the volume of off-site borrowmaterial required.

Since the potential exists for future risks due to the on-site pond(see Section 6.1), all capping alternatives consider leaving the pondopen or backfilling the pond. If the site is not regraded,backfilling of the pond requires significant volume of materials fromoff-site borrow sources to bring the pond to the precap grade. If thesite is regraded prior to capping, sufficient fill material will beavailable to fill the pond over the existing water level in theon-site pond. However, clean fill from off-site borrow sources willbe utilized to fill the pond to the existing water level elevation.

The river bank is heavily vegetated with trees and undergrowthresulting in proven bank stability over the previous years. In orderto cap the small percentage of wastes that will remain outside theflood protection levee, it will be necessary in some areas to removethe trees and undergrowth to install the cap. The benefits gained bycapping the waste outside the flood protection levee in those areasmay not outweigh the existing benefit of a stable river bank,especially since the landfill is so close to the river. In addition,a cap installed outside the flood protection levee would be subject tosignificant erosion and scour during flood events resulting ineventual erosion of the cap. Therefore, for the purposes ofalternative evaluation, the waste outside the flood protection leveewill not be capped.

Capping alternatives that involve leaving the pond open will cover anarea of approximately 45 acres. Capping alternatives that involvepond closure will require an additional cover area of 15 acres for atotal of 60 acres. Capping areas are shown on Figures 6-2, 6-3 and6-4. The final grade of the site after installation of the cap forvarious alternatives is shown in Figures 6-5 through 6-8. Site runoffwill flow by way of drainage swales to two outlet structures to allowthe water to flow through the flood protection levee. Thesestructures will have flap gates to prevent flood water from enteringthe site through these structures.

The estimated volume of off-site fill material required and volume ofexisting landfill to be regraded are shown below.

Page 140: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

II—•NJ

Legend

ii Site Boundary

'W// Marion Paving'Co., Inc.

jiSSij Dobson Construction Co., Inc.

Private Residence

v ; Area to be Capped if the On-sitePond is not Backfilled

rag- Additional Area to be Capped^™ If the On-site Pond is Backfilled

Conceptual Location of Groundwater* Extraction Wells

— — Extraction Well Piping

•——1 Slurry Wall

D Conceptual Location of On-siteTreatment Facility

— Effluent Discharge Piping

Scat* In F««l

0 250 500

P?\v---*" \

Figure 6-3Indiana Sanitary Landfill Cap or Multilayer (RCRA) Cap; Slurry Wall;

Groundwater Extraction; On-Site Groundwater TreatmentAlternatives 3A and 4A

Page 141: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Legend

Site Boundary

Marion Paving Co., Inc.

Dobson Construction Co., Inc.

Private Residence

Area to be Capped if the On-sitePond is not Backfilled

LLLI Additional Area to be Capped1411 if the On-site Pond is Backfilled J,

\t^ Conceptual Location of GroundwaterJI~ Extraction Wells

'"• Extraction Well Piping

=» Slurry Wall

Seal* In F*«t

n 250 500

\Figure 6-4

Indiana Sanitary Landfill Cap or Multilayer (RCRA) Cap; Slurry Wall;Groundwater Extraction; Discharge to POTW

Alternatives 3B and AB

Page 142: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

f i

I I

<:>

iK-'4>

Legend

•' • Site Boundary

'////, Marion'Paving Co., Inc.

|S:j:|::: Dobson Construction Co., Inc.

IBM Private Residence

— 800—• Elevation Contours

Surface Runoff Outlet Structures

\

Scale In F«et

0 2bO 500

•v

\

Figure 6-5Final Grade for Indiana Sanitary Landfill Cap or Multilayer (RCRA) Cap

Installed Over the Existing Fill with On-Site Pond Left OpenAlternatives 1A, 2A,- 3A1 , 3B1, AA1, 4B1

Page 143: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

IH-1l/l

-." • I)n. .?.

Legend

Site Boundary

Marion Paving Co., Inc.

Dobson Construction Co., Inc.

Private Residence

— 800—Elevation Contours

—— ^ Surface Runoff Outlet Structures/1—,;•-—-

\

Figure 6-6Final Grade for I*- 'tana Sanitary Landfill Cap or Multilayer (RCRA) Cap

Installed Ov the Existing Fill with On-Site( id BackfilledAlternatives IB, 2B, 3A2, 3B2, 4A2, <(B2

Page 144: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

(TiI

v« -nn .?.

Legend

Site Boundary

Marion Paving Co., Inc.

Dobson Construction Co., Inc.

Private Residence

-—800——Elevation Contours

Surface Runoff Outlet Structures

V7 Q C - ;

Figure 6-7Final Grade for Indiana Sanitary Landfill Cap or Multilayer (RCRA) Cap

Installed Over Regraded Fill with On-Slte Pond Left OpenAlternatives 1C, 2C, 3A3, 3R3, 4A3, 4B3

r: I

Page 145: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

I I

Legend

Site Boundary

Marlon'Paving Co.. Inc.

Dobson Construction Co., Inc.

Private Residence

— '800 — Elevation Contours

— • — fc Surface Runoff Outlet Structures

. ---• \ N-; I i

.\

Figure 6-8Final Grade for Indiana Sanitary Landfill Cap or Multilayer (RCRA) Cap

Installed Over Regraded Fill with On-Site Pond BackfilledAl! latives ID, 2D, 3A4, 3BA, 4A4, ft

Page 146: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyKarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-18 of 59

Cap Installed Over Cap Installed OverExisting andf <•>,], Reqraded Landfill

Pond Open Pond Backfilled Pond Open Pond Backfilled

Volume ofOff-SiteMaterial(cy) 160,000 940,000 25,000 500,000

Volume ofExistingFill tobe Re-

(cy) Minimal Minimal 90,000 390,000

6.2.5 Slurry Wall

Alternatives 3A, 3B, 4A and 4B involve the construction of a slurrywall around the entire site perimeter. A soil-bentonite slurry wallwould be placed around the entire site and would be keyed into the lowpermeability clay confining layer present at the site. This confininglayer is present approximately 30 to 35 feet below the surface of thelandfill. "Die slurry wall will average approximately 35 feet deepwith an additional 3 to 5 feet keyed into the confining layer. Theapproximate length of the slurry wall is 7,100 feet. The majority ofthe wall must be constructed through the waste fill (5,700 feet) . Theexcavated waste fill will be disposed of on site prior to capping andwill be replaced with low plastic silt or clay from off-site barrowsources. The backfill material would consist of a mixture of soil andbentonite.

A portion of the landf in is within 10 to 15 feet from the edge of theriver on the eastern side of the site. In these areas, it will benecessary to construct the slurry wall approximately 70 to 95 feetfrom the edge of the river. This results in a small percentage of theoverall lan^-Hii waste volume to remain outside of the slurry wall(18,000 cy or 1.6%) . The slurry wall location is shown on Figures 6-3and 6-4. A portion of the slurry wall will be constructed mar theasphalt plants requiring the temporary relocation of several gravelstockpiles within the plant area. Relocation of major structures isnot anticipated.

The river bank is heavily vegetated with trees and undergrowthresulting in proven bank stability over the previous years. In orderto cap the g n percentage of wastes that will remain outside theslurry wall, it will be necessary in some areas to remove the treesand undergrowth to install the cap. The benefits gained by capping

Page 147: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill siteSection: 6July 31, 1987Page 6-19 of 59

the waste outside the slurry wall in those areas nay not outweigh theexisting benefit of a stable river bank, especially since the landfillis so close to the river. In addition, a cap installed outside theslurry "all at sane locations would also be outside the site floodprotection levees and would be subject to significant erosion andscour during flood events, resulting in eventual erosion of the cap.Therefore, for the purposes of alternative evaluation, the wasteoutside the slurry wall and flood protection levee will not be capped.

6.2.6 Groundwater Extraction

Four groundwater extraction wells would be installed in the upperaquifer at the approximate locations shown in Figures 6-3 and 6-4.The wells would be 10 inch diameter PVC casing with a 15-foot screenplaced in the upper aquifer. The design life of the groundwaterextraction system is estimated to be 15 years for the pump and 30years for the -wells and piping.

The groundwater extraction rate would vary, depending upon the type ofcap installed (Indiana Sanitary Landfill or Multilayer RCRA cap) andupon whether the on-site pond is backfilled or left open. Initially,the landfill requires dewatering to lower the groundwater level withinthe slurry wall. A five foot difference in head between the outsideand inside of the wan will be maintained. A total initialgroundwater extraction rate of 100 gpm (25 gpm/well) would be requiredto dewater the site to the required gradient in approximately 10months if the pond remains open. If the pond is backfilled, thedewatering would require 170 days. To maintain the required gradientbased on the type of cap (Indiana or RCKA) and whether the pond isleft open or is backfilled, the groundwater extraction rate afterinitial dewatering shown below would be required.

Indiana Tarri-fjn cap Miitilay**'''' fRQRA) CapPond Open Pond Backf i 1 led Pond Open Pond Backfilled

Infiltration through 7 gpm 7 gpm 7 gpm 7 gpmslurry wall

Inf iltration through 10 gpm 13 gpm 0 gpm 0 gpm

Rainfall into the pond 36 gpm — 36 gpm —

Site runoff into the 13 cnan = 13 can =pond

Total Flow 66 gpm 20 gpm 56 gpm 7 gpm

Page 148: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 6July 31, 1987Page 6-20 of 59

6.2.7 Groundwater Treatment

The extracted grcundwater would be treated either in an on-sitefacility or at the Marion POIW. The required treatment capacity rangeis 7 to 66 gpm, depending upon the type of cap used and whether or notthe pond is backfilled. The treatment capacity required duringdewatering is 100 gpm. This results in an overall treatment range of7 to 100 gpm.

On— Site

The on-site treatment facility would consist of activated carbonadsorption system consisting of two columns in series. Each column is4 feet in diameter and 11 feet in height and can treat the anticipatedflow range of 7 to 100 gpm. Each column would contain 2,000 to 3,000pounds of granular carbon. The exhausted carbon will be regeneratedin off-site vendor facilities. At the thre of exhausted carbonremoval, the carbon vessel will be filled with regenerated carbon.The carbon system would be enclosed within a heated building.

The carbon system can remove the limited number and low concentrationsof hazardous organics and ODD present in the extracted groundwater.

( Law levels of barium, beryllium, arsenic, cadmium and silver weredetected above background levels in the groundwater. The carbonsystem can remove arsenic, cadmium and silver. Information is notavailable regarding the capability of carbon to remove barium andberyllium. In order to determine the feasibility and to establishperformance levels for using an activated carbon system forgroundwater treatment, it is IH.X nuHRnried that a limited treatabilitystudy, employing accelerated column testing provided by activatedcarbon system vendor, be conducted using actual groundwater.

The effluent from the carbon system will be treated in an airstripping system for the removal of ammonia. The main component ofthe system is a countercurrent type stripping tower where the water ispumped to the top of the tower and flows to the bottom through apacking medium. Air is introduced at the bottom which moves to thetop of the tower along with ammonia being stripped from the water.For a treatment capacity to handle a maximum flow of 100 gpm, a towerof six feet ^nMrtw with a packing height of 24 feet will berequired. Since a pH of 11.5 is required for efficient stripping ofammcnia from the water, a pH adjustment unit using caustic sodasolution (NaCH) will be provided upstream of the stripping tower forproper pH adjustment. Another pH adjustment unit will be provideddownstream of the tower to adjust the pH of the effluent to 8.5 usingsulfuric acid. Since ammonia removal is dependent upon temperatureand to maintain a consistent removal during winter months, thestripping tower will be enclosed within a heated building. The

Page 149: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Tarrffjn siteSection: 6

( July 31, 1987v Page 6-21 of 59

stripping tower is designed to produce an effluent with an ammoniaconcentration of 8.5 mg/1 in winter and 8.1 mg/1 in sunnier. Theeffluent from the ammonia removal system will be discharged to theMississinewa River under a NFOES permit.

A proposed on-site treatsent facility and effluent discharge pipelocation is shown on Figure 6-3.

Discharge to Marion POTW

The extracted groundwater will be discharged to the 33-inchinterceptor located at the intersection of Home Avenue and LincolnBoulevard, based on discussions with the Utility Director of theMarian Utility Service Board. The invert elevation at this locationis 787 MSL. The 33-inch interceptor is located approximately 3,200feet from the Marion/Bragg landfill site. The groundwater will bepumped to the interceptor sewer. The Marion POTW has indicated thatthey can handle up to 250 gpm of groundwater from the site withoutimpacting their facility. The proposed discharge location from thesite to the Marion POTW is shown on Figure 6-4.

This section presents an evaluation of the technical aspects for eachalternative. The technical evaluation involves assessing the ability,and generally to what degree, each alternative satisfies a given setof technical evaluation criteria. Factors considered in the technicalevaluation of alternatives include:

o Effectiveness

Meeting remediation action goalsReliability of remedyUseful life of remedy

o Implementability

Technical feasibility including demonstratedperformance, operational complexity, operationalflexibility, reliance on monitoring results andmaintenance requirements;

Administrative feasibility including ease ofimplementation, t^me to implement and time to achieveremedial action goals;

Availability of needed equipment.

Page 150: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 6July 31, 1987Page 6-22 of 59

Safety

Risks to public health and environment in the event ofsystem failure;

Safety during construction.

The evaluation comments for each alternative are presented in Table6-3.

6.3.1 Summary of Technical Evaluation

The following discussion summarizes the more pertinent technicalaspects of the alternatives. Table 6-3 presents a detailed listing ofthe technical evaluation criteria and the associated technicalassessment for each alternative.

Effectiveness

All alternatives except the No Action alternative address the remedialaction objectives relating to contaminated on-site soil, groundwater,on-site pond, and leachate seep. Given proper implementation andoperation and maintenance, all alternatives other than the No Actionalternative would be effective in preventing risk to public health andenvironment from exposure pathways associated with these media.Alternatives 1 and 2 place a significant emphasis on monitoring ofgroundwater, cnrsite pond and Mississinewa River to meet actionlevels. Alternatives 1 and 2 would not be effective in preventingrisks to public health and environment in the future if contaminantconcentrations exceeded action levels since no treatment is providedfor these media. All remaining alternatives (Alternatives 3A through4B) would be effective in eliminating risks to the public health andthe environment since the landfill is capped and contained within aslurry wall; and groundwater is extracted and treated either in anon-site facility or at the Marion PCTW. The effectiveness is furtherincreased because the slurry wall would prevent migration ofgroundwater to the Mississinewa River.

The effectiveness of all the alternatives in preventing risk to publichealth and environment is partially dependent upon the permanentimplementation of access and deed restrictions since the waste willremain in place.

Of the two capping options, the multilayer (RCRA) cap is considered tobe more reliable than the Indiana Sanitary landfill cap due to theadditional reduction in infiltration into the landfill. Alternatives

Page 151: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

* $i \

liI1'Hi

*il««i|?5|»||j|

IS!

•T;jliI|![r!'Ill

5 Sjj 1 ji ij!.»!*iilil- l^J l - U S I I l *- •••Ri!|'~^!ir<i|HfiBn?i; iii*n ii»r!!!

iif

i^iM;- '

«; 11 ;ji=;!«fi !i i i it if l infi. p .

a'MS alMji ..2

lla!illt.h r U U i k

iniih liiiiii. ^ . b*

5?ta m

Tt*Kk.JiH!».li iijni hiHiiii<P . b*,ii{M jil^i

»'' W l'Hi|l:-h]N:lmliiJill Ifiill!

l

Page 152: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TP*JLf *-• <»w» 1 *f •)

TTOfllCrX. pJPlUntlCM V nVmmTlVfnWIQH/VBHOT LAWFUL SITf

PLTfJVMTIUC I nLIMhWTIVI J ! PLTfMITtVl M PLTHMI1IVC a* PtTffMUIVI «JINDIA* SPMITrV* LPMF1LL CPF HOIPMH VWITnWV UWFILL CPff> MUUI-tPrtt> ("OH) Cnf

IHOIfMI WWtrPJlT UMVIU CP"> HU.Tm.nVC* (KM) O» SUW WAIL PHI OM-SITt *.UB*V MM.L PM) BISDHaK OP SLUBOT UV.L P*C M-SITf. IWLUnTION OM1WHI i*« nWimiMS PMO NUrilTOVlNS CMU4MUC* TWJDUrCOT •BLMNITn TO I**) I ON POW MMCMiTC* IMIrKNT

i, •aUapJIIhy,

•pllaallltv, a* T ___ I BaW ra**rlatl«M raaM^a aa>lnt*n- B»*d r««4*-iaU«_ r««ilr* aatntarr- Ow* rwtrlvtlw rvwjulra aalnt*w aaW rwArtatlan* raajelrv aainta*- DM* rwtrlatlana raajuir* a*into>*- QM* raatrictlana raa>lra aaintwa>w* Par w indafinil* UM pariad. anca far M i rf U.I. Uw p*-i«d, anM far an Indrftnita tla» pariad. vww Par an Maflnlto UM par I ad. anca far an |t«Jaf lf>IU tlM pariarf. ana* P«r an nwJrflnit* ilaa aariarf.FataMlal *nl*t* thri iaalaaantoilan P^Untlal *.i*L. tn*t l l*MM*tl«n **Un*Ul nl.t. Uw» i l*aant*kian ••toMUl vnlvto WwA faplvwntollan P*A*M1*I «.|.l. lK*t l«p>lMM«l*tian *Maritl«l *.i»l« that iapl«M^aii«*Mill nat to aantlnuarf In futtr« .III fwH. to Mntlnu^ In fwi^-« w i l t n»t to ovHtrwrf In fwtva will —* to ««Hlnu*4 In Pwiv* will n»t to aMtlnu^ In ful -* .411 nat to •aMi'Mtf -

.rvliabl* IP aarlarfle l>«vactl««j •* r.l.*l. IP p ,.rf.. ifMa^fcian* «r r*U«*l* IP aari^ia In^Mtiani ^ r«ll«al* IP aM-larito IfM^wilvra *P r*||akl* IP aarlarii* InaaMtlMW aP r.ltakU .P aM-larti. .«^«t.——»*™» IntoarihV. *+ »'9r«; vwJ r«ne* Inlay-it* wwl Bian*; w^ P«n»* int*ar|tv «-^ al*7«l *^ f——— i«t-aj-IU( «nrf aia^at and Pwntw Intofrii^ «nd Blfna; and fanw |nt**r<L* and ala ii afrfPIIHI.-^ Mlntonm* ar* aandurt»d. memanj MintMMnc* *r* aanA*»W. nmiaar^ Min4«»mv ar« in «^»t<. natiM»irv MlntoMfva ar* aa»*»li<. nn. .-y M|nt*nanc« ara oanduci«<. naaMMry •»ir4.na»»j> •-» aar ai

• rvllMllltv •* Mnltarv Lana-tara raliakl liluafaulkl-lauar Lpna-tom reliability, af *~ti«^V >*^*?r* r>l"*llijf ** **>*^.— UnTi * ^l1*111^ ^ •uIt'-|*UOT> Lanf-tor* rallMlllta «f awlkl-laupr

•P patankl.l landfill aattlMant and patantlal landfill aakklaaanft anal *f pa4a«tl*l landfill Mttliaant and •* patantUl landfill aatkI»Mnk and pakantlal landfill aakklaaaM and pakantlal landfill Mktliiiint andkha naad Par lana-k - •aintanww*. tna mad far Ia.*-Ur* Minlananaa>. kha AMd far |a.wj karw Ml.*a.iaiwja. W*> naad Par lanfriar* a«int <anM. kha nwd far lanfrtara Minkananca. Lha naad far la -tar. Mf4a-wjn*a.»amlkarinf vawld to <-«||a»|* ta Nanitarinaj would to raliabU kaindleak* •• I ••! mil lav«lp In In* tndicata oantaninant lawlv In kha Lana-tara rallaallllv af • lurry LaiwJ"tpra rallaalllku af plurru tana kara rallabUItu af •lurrw LaM-karai rvliafcilltv af vlMrryayaunahatar. an-«lta pand and araunduator, an~plla pand and M.IIP hM not town oaadnatrakad but wall* haa nat toan aaaNnatraiad but •all. hM nat town daaanakratad but w«llc haa nak toan dManatratad butNlMlaatrwMa tiwr. If aataallanaal Hitti.a.rw* t.wr. IP a«ta*ll«npd !• tollawd ta to faad Pw khla la tollawd U to aaavJ Par thl* !• tolivwd to to gaod for thi« Ip toll«w4 to to favd far l»lpaatlan liatta «ra • ajiidid It aclian lialtp ar» pipjuaid It purpoa*. pmpan. put uu««. pur.aa..•Ill to naoawaaru ka !•»!• mt t will to naca»pary ta tapliMntadalltlanal raaa ial Mtiwna. a«itlan«l raaMicI aetian*. Call Milan af araun*—tar thraMfh OallMtlan af f-mt+mtm- thraudH wIlMtlan af araunowtar Unwah CallMttan af i

» af awkTMtlcn Mil* ia a prawn *•» •* aHtrMtlan wall* U * prawn MM af aMtractian wlla imkaofewilaau *nd U aaiMidar U toahnalaflv and !• eanal«W-*4 U fc.vhn.lagv and im cwwldwad la Laonnalafu *n4 i« cmidwatf I*hM* opad rallMpllity. UtrMkl«n haw faad rallablllkv. EMtractlan h^* a««f rvlttbility. ExkraEtlon ha«* «»d r.llMllitv. C*tr«clianwlU uu to puM>*d at MryJnf. ratoa walla •*« to puaaad at w lnf rato* •»! I. My to ^u » i* at wv^tr^ r*t«« «•!!• a^ to n fit *t var inf r«ta«ka ar«wld» riM.bllllv i» ffr*di*nt to fr«vlda PI*Nl»lllM| in v>"*^ to pr*rid» flmkllity In a/Wt»nt k« prwvld* MM.*. I it* in y^ivntcwttral. fWdltlonal valla ••» to aaniral. P«ddtklan«l **!!• pan to eankrwl. MMit.*n.l —ll« c«n to ew^-*|. Mdriiliorx«1 Mil. *«n to

IP nuMpary,. Mailv ***>d If

Carton .in ptlwn la Mil dpwan- PVWa ara wall PI i utratod and Carton ad.arpi.ar. !• Mil *aan- POtW, r, wl I d~ar. atW and•kratad and ia a rallavlv krvataajnt rallabl* far IK» rvamral af aanta- vkratad and I. • rallabla kraakaant raltaal. far kh> raaavpl af eonta-a taai. Lar^-fcar* raUakillky ainanka at avlatlna; iyax<dM«i•ay dUlnlah If ay*ta- *upk to u»- aantoalnant aanMntratlaM.•radaal and •alnt lnad lar p«at Myaara. If a fult-kiw aparatar la yrw.. If * futl-iiM .nat uaad. reliability af th» vyatoa - ' rwt "ud.rallaaillty af Uw ayataa)would to ridi.im< furthar. • Muld to riajurf fwUwjr.

Intonanp* aanltary Uaaful I If. af aunthatU oMbrana Uaaful Ufa of aunthatla n »• ••HIUi prapir aalottonanM .anikary wvful Ufa af aynUwtla aiafc ana Hlth pmpir a«lntanan»a •anliary "HW> pTMjar aalntonan** aanltary Uaaful Ufa af awnUvil. oMbrana Uaaful Ufa of aunthaUa aiafcranalandfill cap deaa nat hav« a lialk -ith •uUI-laun- cap la ntiwtvd landfill cap daaa nak haw a lialk landfill eap daa« nat haw • Halt Mlth aulkl-lauM- cap I. a*tla*l»d with aulii-layM- c<* |. a«tl*ata«an waaful Uf. *t TO ytarp, 0ralac«M*it ia an uaaful Itfa. •*» M««fwl llfp. at .X yvara. BvplMMant I* at TO yaara. BM! itm '« i*

UMfwl Ufa af a*traBtlan wall* la w*#wl Ufa mf a rMilan wlU IP Uaaful Ufa af awkrMtlon wlU la Uaa/ul Ufa af a«krMtlan wlla IP

flurry wall IP eonpidpr** ta haw Hurry **H I* aanpldprad U haw Slurry wall I. aanalaWW U haw Slurrv wall I* a«npidar«d to haw.an Indafinit* llf# If prapprlu •" indaflnlto llfp If liF. if prap»rly

.lt »!«!. eanptructa.1.

U**fwl Llfa af an- ill* kraatMM W™ i" •••"••< to to a^«*«inad w*ful I ifa af •n-atU IrMtMnt POn In aaa-aMd to to .*IM»lfacllltu !• MtiMiW «k 30 yaarp. *n*1 ""y**"* •• naaaaaary. Ca«t> facility la a.tia«kW «t M uaarp. and taifr^Jnl «• tvEvavary. CBaplacaaant rwau.rad. -^ InpludW In ww aaai. QaplabMan* rwv'r^. r. Inclwrt-d in war cart.

6-24

Page 153: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

[ii1[ =\<

111'!'!!{)«W $

j

«USI • r •• a J « * " T

»1K m- j«ilit t;f !i!lM II; i"

iH|9' REf !!H ll'l£t'l?:t i*h jjv ;l«IilrfSI ilf} ft i|W|••*-f S rlSil

:,!

1'

|l

ii• 5[ oe f

^lililii^iR;t!i O

Page 154: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

~»~f

j

: n\? Eg!

i I

I-Ni

f iii

IH i

i :* *i t ..i - i t-fiifiiii li |i]]i ~u!rSMfSJ l '11!]' I'sl'li' " j^i|. i!*|^r- l i i .^ itlJi: MV.-i.-J ii |-«|J ]k*|Cf J i~ * fit " I .— * • • — - « » I t « 4 { « * •

'l i i ~"i \*$\* iH!?!1!' i| Hjili = i » l Ii| J 1 i?|ij jl'i*] Hjiji'V -F-'l |={?rl |f]it» . . i?w: i f r?* ' ji;[5:I-t 7sj ?U"s- i il

M ! H > 0 ^ ? itt ItlMI izftI]

i! i i E M!

jr]

-tif

it

il*r

j_? i! p*l j{]$S M fc fc — i £ t l U j ? - *

— •" v * S ^ t t i ^ - * * « l

II ill! IiiilBillllffi

4 K m

r i k i l , - .J. .«!;•:i

• b

-"1

illH*Snil

Jihi

11 jS; f :

J illi:-.

IM[PIwtki l

rjiili!"Mi

t - f iij»«*!•:

*;

Page 155: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

CI \

V TIL

IPi'li s ;

1

s.

IJT «« * Ujs jHtfliilpill! I ill

s»s! A-a* \ i1';?!i! «i1!

»! !JSfilaiiii Jiffiiii![H§i«ii* 'ii«h

IfIIi!i*=

l/L•iY*ii- ?*!;*

5 i«?i

, ,S Jl Jl'iii i !

M

!Pti i i i

Ml!it

'I

ii"3!!«i

Iin|MUlJHi;8flIi!"

ililii Ml^iif Mm'if Ipfi,

i! $l[l« fehli!

iiU

111 illIi !]!.!! fll,is Hiij

"1=-1!1• C » ~ - CiS £ I IJi f i * t != ,» l1111-. . fUJIt

in

I*:?! r-ilhbin il^llihj'i »t!=,»!

'-11

»•

1 ! i WI iu!! ^

I H'fi{! -hii^-i1!fl!

iill-HitJSMi

ill!*-•* »^f t }

U fin

li,I i J]

Page 156: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

V\\lHi!mHi i

' |rLjt]f i^MJ! ?ibj1$ SI lif||j {lijjlj 111

!!s

jhili II S , ?

.Bill! s j i U:Hi f i 1

.1 ?'

! i

J i H ?i ! J5 l

*"'?•!iiiii!

H f S l j . ? | . j

i f ' i L S

•j ' l , :i , j

r?

i

i!! :!! ! H ii f - I ? M i j 'J i -^j 1 -;? si o (* t r f t ^ { ? ?1

f: ?! - c.1 '! i! f Is tlt;•i , ill! (t.;,,!-;1

. 1 t ;«* i-! " - - j - -« - * f l « f - f t - o ' ' . . , .j r ^ - 1 — r . B * ^ 1 T^ " 7 ' 1 " ™ ' " * ? ? l ' l i . f t *

t* ? I! < o y - " f — — t —

S J l - j i U « - f l % ; 1 ?

1 It!i p-=Mf;?rn

" : < = f " , -^ fi}1: .1

\iiK i q\[{

i!

s:'

I f! *

Page 157: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-29 of 59

1 and 2 place a heavy reliance on monitoring to determine if actionlevels are exceeded. If exceeded action levels are first detected inmonitoring wells or the on-site pond, there may be sufficient time toimplement additional remedial actions before action levels areexceeded in the river.

All remaining alternatives offer a high degree of reliability withregard to protection of the public health and the environment due tothe prevention of off-site migration of groundwater contaminants tothe Mississinewa River by the use of a slurry wall.

Of the groundwater treatment alternatives, discharge to Marion POIW isconsidered to be more reliable because the volume of water from thesite is relatively small compared to the design capacity of the POTWand because of the availability of trained operating personnel. Anon-site treatment facility is considered much less reliable because ofthe need for skilled operators necessary to ensure efficient operationof the treatment facility.

Alternative 1 (Indiana Cap) is the easiest to implement as it has thefewest components to construct. Alternative 2 (multilayer cap)although similar to Alternative 1, requires additional construction

and expertise to install the multilayer cap.

Alternatives involving the use of a slurry wall (Alternatives 3Athrough 4B) are slightly more difficult to implement because of theproximity of the Mississinewa River to the site.

Excavation of fill material during slurry wall construction and siteregrading prior to capping will result in health and safety issuescommon to remedial actions at any hazardous waste site. These healthand safety concerns will be taken into account during remedialconstruction. Implementability will not be affected by these issues.

Hie implementability of the groundwater treatment alternatives varysomewhat. On-site treatment requires the longest design andconstruction time while also requiring NPDES permitting. POIWtreatment does not require permitting and would be the easiest toimplement.

6.4 COST ANALYSIS

6.4.1 General Discussion

Cost estimates for the assembled alternatives were prepared from costinformation included in the 1987 Means Site Work Cost Data, estimatesfor similar projects, and estimates provided by equipment vendors.

Page 158: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-30 of 59

Capital and operation and maintenance cost estimates areorder-of-magnitude level estimates, that is, the cost estimates havean expected accuracy of +50 and -30 percent. The estimated presentworth of remedial alternatives was based on 10 percent discount rateand a 30-year alternative life.

The order—of-magnitude cost estimates presented have been preparedfrom the information available at the time of the estimate. Finalcosts of assembled alternatives will depend on actual labor andmaterial costs, actual site conditions, productivity, competitivemarket conditions, final project scope, final project schedule,continuity of personnel, engineering between the feasibility study andfinal design, and other variable factors. As a result, the finalalternative costs will vary from the estimates presented in thisreport. Most of these factors are not expected to affect the relativecost differences between alternatives. Because of these factors,funding needs must be carefully reviewed prior to making specificfinancial decisions or establishing final budgets.

Estimated capital costs, annual operation and maintenance costs, andpresent worth for each alternative, except No Action, are presented inTables 6-4 through 6-7.

6.4.2 Assumptions

Total capital costs are those expenditures required to initiate andinstall a remedial action. Both direct and indirect costs areconsidered in the development of capital costs. Direct costs includeconstruction costs or expenditures for equipment, labor, and materialsrequired to install a remedial action. Indirect costs consist ofengineering, permitting, supervising, and other services necessary tocarry out a remedial action.

Because this feasibility study is conceptual and based on dataavailable at the time, bid and scope contingencies were estimated toaccount for unknown costs. Bid contingencies account for a variety offactors that would tend to increase costs associated with constructinga given project scope, such as economic/bidding climate, contractors'inexperience in working on hazardous waste sites, contractors1uncertainty regarding liability and insurance on hazardous wastesites, adverse weather conditions, strikes by material suppliers, andgeotechnical unknowns. Scope contingencies cover changes whichinvariably occur during final design and implementation. Scopecontingencies include provisions for items such as inherentuncertainties in defining waste volumes and regulatory or policychanges that may affect FS assumptions. Allowances for priceinflation and abnormal technical difficulties are not accounted for inthe contingencies.

Page 159: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-4(1 of 2)COST SUMMARY

ALTERNATIVE 1 (A 4 B)INDIANA SANITARY LANDFILL COVER, MONITORING

(COVER INSTALLED OVER EXISTING FILL)

COST ITEM

ON-SITE PONDREMAINING OPEN

(ALT. 1A)

ANNUAL 0 & MI REPLACEMENTCOSTS (ALT. 1A)

PRESENT ON-SITE POND ANNUAL 0 S M PRESENTWORTH BACKFILLED & REPLACEMENT WORTH

(ALT. 1A) (ALT. 1B) COSTS (ALT. IB) (ALT. 1B)

INDIANA SANITARY LANDFILL COVER (a)Vegetative CoverTop SoiIClay SoiI CoverPre-Cap F i l lSite ConstructionVegetative Maintenance (b)Site Inspection (b)

MONITORING (b)

6200041800018410001240000360000

12000WOOD1&4000

140002000

81000

700050000109000

13200019000

764000

8300055500026420007285000360000

17000111000264000

190002000

70000

1000066000156000

17900019000

660000

ACCESS RESTRICTIONSigns and Fence 54000 54000

SURFACE WATER MANAGEMENTFlood ControlSite Drainage

WELL REPLACEMENT(c)

INSTRUCTION SUBTOTALHealth I Safety (10%)ContingencyBid (15X)Cont i ngencyScope (20X)Contingency

CONSTRUCTION TOTALLegal (5X)Construction Services (2X)

35200033000

8000

4368000

437000

655000

874000

6334000317000127000

35200033000

8000

11372000

1137000

1706000

2274000

16489000824000330000

TOTAL IMPLEMENTATION COSTEngineering I Design (6X)

TOTAL CAPITAL COST

6778000407000

7185000

176430001059000

18702000

TOTAL OtM AND REPLACEMENTPRESENT WORTH 1081000 1090000

TOTAL PRESENT WORTH 8266000 19792000

(a) 0 £ M costs assumes replacing 105 of the clay soil cover, and20X of the topsoil and revegetation cost for the landfill every 10 years

(b) Present worth based on a 10X discount rate over a 30 year period.(c) Plugging existing three wells at Marion Paving Co. and Dobson Construction Co.

and installing three new wells in the lower aquifer.

6-31

Page 160: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-4(2 of 2)COST SUMMARY

ALTERNATIVE 1 (C I D)INDIANA SANITARY LANDFILL COVER, MONITORING

(CAP INSTALLED OVER REGRADED EXISTING FILL)

COST ITEM

ON-SITE POND ANNUAL 0 & M PRESENT ON-SITE POND ANNUAL 0 £ M PRESENTREMAINING OPEN I REPLACEMENT WORTH BACKFILLED & REPLACEMENT WORTH

(ALT. 1C) COSTS (ALT. 1C) (ALT. 1C) (ALT. 1D) COSTS (ALT. 1D) (ALT. 1D)

INDIANA SANITARY LANDFILL COVER (a)Vegetative CoverTop SoiIClay SoiI CoverGradingSite ConstructionVegetative Maintenance (b)Site Inspection (b)

620004180001541000394000360000

1200084000184000

140002000

700050000109000

13200019000

8300055500026420004075000360000

17000 1COOO111000 6600026iCCO 156000

190002000

1790GO19000

MONITORING (b) 81000 764000 70000 660000

tCESS RESTRICTIONSigns and Fence 54000 54000

SURFACE WATER MANAGEMENTFlood ControlSite Drainage

35200033000

35200033000

WELL REPLACEMENT(c)

CONSTRUCTION SUBTOTALHealth £ Safety (IDS)ContingencyBid (15X)ContingencyScope(20S)Contingency

8000

3522000

352000

528000

704000

8000

8162000

816000

1224000

1632000

ONSTRUCTION TOTAL-Legal (5X)Construction Services (2X)

5106000255000102000

11834000592000237000

TOTAL IMPLEMENTATION COSTEngineering £ Design (6X)

5463000328000

12663000760000

TOTAL CAPITAL COST 5791000 13423000

TOTAL CAM AND REPLACEMENTPRESENT WORTH

TOTAL PRESENT WORTH

1081000

6872000

1090000

14513000

(a) 0 t M costs assumes replacing 10X of the clay soil cover, and20% of the topsoiI and revegetation cost for the landfill every 10 years

(b) Present worth based on a 10X discount rate over a 30 year period.(c) Plugging three wells at Marion Paving Co. and Dobson Construction Co.

and installing three new wells in the lower aquifer.

6-32

Page 161: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-5(1 of 2)COST SUMMARY

ALTERNATIVE 2 (A I B)MULT I-LATER (RCRA) CAP, MONITORING(CAP INSTALLED OVER EXISTING FILL)

ON-S1TE POND ANNUAL 0 I M PRESENT ON-SITE POND ANNUAL 0 & M PRESENTREMAINING OPEN I REPLACEMENT WORTH BACKFILLED t REPLACEMENT WORTH

COST ITEM (ALT. 2A) COSTS (ALT. 2A) (ALT. 2A) (ALT. 2B) COSTS (ALT. 2B) (ALT. 2E)

MULTI -LAYER (RCRA) COVER (a)Vegetative CoverTop SoilGeo-TextileDrainage LayerSynthetic LinerClay LinerPre-Cap F i l lSite ConstructionVegetative Maintenance (b)Site Inspection (b)

MONITORING (b)

ACCESS RESTRICTIONSigns and Fence

SURFACE WATER MANAGEMENTFlood ControlSite Drainage

WELL REPLACEMENT(c)

CONSTRUCTION SUBTOTALHealth 1 Safety (10X)ContingencyBid (15X)ContingencyScope (20X)Contingency

CONSTRUCTION TOTALLegal (5X)Construction Services (2X)

TOTAL IMPLEMENTATION COSTEngineering I Design (6X)

62000E3600021500097800098000018410001240000360000

54000

352000330008000

6959000

696000

1044000

1392000

10091000505000202000

10798000648000

12000 7000 83000167000 99000 111200043000 25000 289000196000 116000 129900098000 58000 1320000

26420007285000360000

14000 1320002000 1900081000 764000

54000

352000330008000

14837000

1484000

2226000

2967000

215140001076000430000

230200001381000

17000 10000222000 13100058000 3400C260000 154000132000 78000

19000 1790002000 190CC70000 66000C

TOTAL CAPITAL COST

TOTAL O&M AND REPLACEMENTPRESENT WORTH

TOTAL PRESENT WORTH

11446000

1220000

12666000

24401000

1265000

25666000

(a) 0 £ M costs assumes replacing 10X of the synthetic liner, and 20X of thethe drainage layer, geo-textile, topsoil, and vegetative cover every 10 years.

(b) Present worth based on a 10X discount rate over a 30 year period.(c) Plugging existing three wells at Marion Paving Co. and Dobson Construction Co.

and installing three new wells in the lower aquifer.

6-33

Page 162: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-5(2 of 2)COST SUMMARY

ALTERNATIVE 2 (C I 0)MULTILAYER (RCRA) CAP, MONITORING

(CAP INSTALLED OVER REGRADED EXISITNG FILL)

COST ITEM

MULT I -LAYER (RCRA) COVER (a)Vegetative CoverTop SoilGeo- TextileDrainage LayerSynthetic LinerClay LinerGradingSite ConstructionVegetative Maintenance (b)Site Inspection (b)

ONITCRING (b)

ACCESS RESTRICTIONSigns and Fence

SURFACE WATER MANAGEMENTFlood ControlSite Drainage

WELL REPLACEMENT(c)

:ONSTRUCT10N SUBTOTALHealth t Safety (10X)ContingencyBid (15X)Cont i ngencyScope (20%)Cont i ngency

INSTRUCT I ON TOTALLegal (5X)Construction Services (2X)

TOTAL IMPLEMENTATION COSTEngineering I Design (6%)

TOTAL CAPITAL COST

TOTAL CAM AND REPLACEMENTPRESENT WORTH

TOTAL PRESENT WORTH

ON -SITE POND ANNUAL 0 & M PRESENTREMAINING OPEN & REPLACEMENT ' WORTH

(ALT. 2C) COSTS (ALT. 2C) (ALT. 2C)

62000 12000 7000836000 167000 99000215000 43000 25000978000 196000 116000980000 98000 580001841000394000360000

14000 1320002000 1900081000 764000

54000

352000330008000

6113000

611000

917000

1223000

8864000443000177000

9484000569000

10053000

1220000

11273000

ON- SITE POND ANNUAL 0 & MBACKFILLED i REPLACEMENT(ALT. 2D) COSTS (ALT. 2D)

83000 170001112000 222000289000 580001299000 2600001320000 13200026420004075000360000

19000200070000

54000

352000330008000

11627000

1163000

1744000

2325000

16859000843000337000

180390001082000

19121000

1265000

20386000

PRESENTWORTH

(ALT. 2D)

1000013100034COO15400078000

17900019000

66CCOO

(a) 0 £ M costs assumes replacing 10% of the synthetic liner, and 20X of thethe drainage layer, geo-textile, topsoil, and vegetative cover every 10 years.

(b) Present worth based on a 10X discount rate over a 30 year period.(c) Plugging existing three wells in Marion Paving Co. and Dobson Construction Co.

and installing three new wells in the lower aquifer.

6-34

Page 163: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TAILE 6-6(1 of 4)COST SUNWART

ALTERNATIVE 3A (1 » 2)INDIANA SANITART LANDFILL CAP. SLURRY UALL, ON-SITE GROUNDUATER TREATMENT

(CAP INSTALLED OVER EXISTING FILL)

COST ITEM

INDIANA SANITMT LANDFILL COVER (•)Vegetative CoverTop SoilClay Soi I CoverPre-Cap F i l lSite ConstructionVegetative Maintenance (b)Site Inspection (b)

sium UALLFeasibility TestingInstal lat ion

SROUNDUATER EXTRACTIONWell Installationyell Ponpa (c)Electrical (b)Col lection Piping

TREATMENTCarbon Treatment SystemAir Stripping SystemBuilding I Effluent PipingElectricalCarbon (b)Chemicals (b)Labor (b)Maintenance (b)Heat ant) Electrical (b)Monitoring {b)

ACCESS RESTRICTIONSigns and Fence

SURFACE UATER MANAGEMENTFlood ControlSi te Drainage

WELL REPLACEMENT (d)

CONSTRUCTION SUBTOTALNaelth t Safety (10X)Contingencylid (15X)ContingencyScope (20X)Contingency

CONSTRUCTION TOTALLegal CSX)Construction Services (21)

TOTAL IMPLEMENTATION COSTEngineering t Design (6X)

ON-SITE POND ANNUAL 0 t MREMAINING OPEN 1 REPLACEMENT(ALT. 3A-1) COSTS (ALT.3A-1)

62000 12000418000 840001841000 18X0001240000160000

140002000

910002820000

200009000 900014000 600030000

60000780002SOOO14000

16000170003000060001100030000

54000

352000330008000

7529000

753000

1129000

1506000

10917000546000218000

11681000701000

PRESENT ON-SITE PONO ANNUAL 0 t MWORTH SACKFILLED ( REPLACEMENT

(ALT. 3A-1) (ALT. 3A-2) COSTS (ALT.3A-2)

7000 83000 1700050000 555000 111000109000 2642000 264000

7285000360000

132000 1900019000 2000

910002820000

200002000 9000 900057000 14000 300C

30000

60000780002500014000

151000 7000160000 5003283000 3000057000 600010-000 7000283000 30000

54000

352000330008000

14533000

1453000

2180000

2907000

210730001054000421000

225480001153000

PRESENTWORTH

(ALT. 3A-2)

1000:660CC15600:

1790C3IvOCO

20002SCSC

66000470CO2S300C57o:c66COC2£300:

TOTAL CAPITAL COST 12382000 23901000

TOTAL OU> AND REPLACEMENTPRESENT WORTH

TOTAL PRESENT WORTH

1414000

13796000

(D 0 4 M costs assumes replacing 10X of the clay soil cover, and201 of the topsoil and revegetation coat for The landfill every 10 years

(b) Present north based on a 10X discount rate over a 30 year period.(c) OH coati (HUM replacement every IS years.(3) Plugging existing three Hells in Marion Paving Co. and Dobaon Construction Co.

and installing three new veils in the lower aquifer.

1262000

25163000

6-35

Page 164: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-6(2 of 4)COST SUMMARY

ALTERNATIVE 3A (] I 4)INDIANA SANITAIT LANDFILL CAP. SLURRY WALL, ON-S1TE GROUNDUATER TREATMENT

(CAP INSTALLED OVER REGSAOED EXISTING FILL)

COST ITEM

INDIANA SANITARY LANDFILL COVER (•)

TOD Soi ICity Sot I CoverGradingS i te Construction

Site Insoection (b>SLURRY UAL.

Feasibi I i ty TestingInstil Lat ion

CROUNDUATER EXTRACTIONWell InstallationUell Pumos (c)Eiectrical (b)Col Lection Piping

TREATMENTCarbon Treatment SystemAir Stripping SystemBuilding & Effluent PipingElectricalCjroon (b)Chemicals (b)Laoor (b)Maintenance tb)Heat and Electrical (b)Monitoring (b)

ACCESS RESTRICTIONSigns and Fence

SURFACE HATER MANAGEMENTFlood ControlSite Drainage

WELL REPLACEMENTS)

CONSTRUCTION SUBTOTALHealth ( Safety OCX)Com i ngencyBid (151)ContingencyScope (2CX)Contingency

CONSTRUCTION TOTALLegal (5X)Construction Services (2X)

TOTAL IMPLEMENTATION COSTEngineering i Design (6X>

ON-S1TE PONO ANNUAL 0 I M PRESENTREMAINING OPEN I REPLACEMENT UORTH(ALT. 3A-3) COSTS (ALT.JA-J) (ALT. 3A-3)

62000 12000 7000418000 84000 5000018*1000 184000 109000394000360000

14000 1320002000 19000

910002B20000

200009000 9000 2000UOOO 6000 5700030000

600007800025000UOOO

16000 15100017000 16000030000 2830006000 57C.-XJ11000 10400030000 283000

54000 •

352000330008000

6643000

668000

1002000

1337000

9690000485000194000

10369000622000

ON-SITE POND ANNUAL 0 t M

BACKFILLED t REPLACEMENT(ALT. 3A-4) COSTS (ALT.3A-4)

&3000 17000555000 1110002642000 2640004075000360000

190002000

910002820000

200009000 9000UOOO 300030000

60000780002500014000

rooa5000300006000700030000

54000

352000330008000

11323000

. 1132000

1698000

2265000

16418000821000328000

175670001054000

PRESENTWORTH

(ALT. 3A-4

1COC66"'S6c;

1 TOO'"I f rJL<

190:

2:02s:o

66CO4?c:253::5?::66C:253::

TOTAL CAPITAL COST 10991000 18621000

TOTAL OiN AND REPLACEMENTPRESENT UOflTH

TOTAL PRESENT WORTH

1414000

12405000

1262000

19883000

(a) 0 t M costs assumes replacing 10X of The clay soil cover, and2CX of the toc«oiI and revegetation cost for the landfill evtry 10 years

(b) Present worth basea on a 10X discount rite over a 30 year period.(c) 3tM costs asstm replacement every IS years.(d) Plugging existing wells at Marion Paving Co. and dobson Construction Co.

and installing three new wells in tht Lowtr aquifer.

6-36

Page 165: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-6(3 of 4)COST SUMMARY

ALTERNATIVE 31 (1 I 2)INDIANA SANITARY LANDFILL CAP, SLURtT WALL, DISCHARGE OF GROUMOUATER TO POTW

(CAP INSTALLED OVER EXISTING FILL)

COST ITEM

INDIANA SANITARY LANDFILL COVER (a)Vegetative CoverTop SoilClay Soil CoverPre-Cap F i l lSite Constructionvegetative Maintenance (b)Site Inspection (b>

SLURRY WALLFeasibility TestingInstallation

&ROUNDUATER EXTRACTIONWell InstallationWell Purps (c)Electrical (b)Collection Piping

TREATMENTSewer Discharge PipeSewer Connection FeeUser Fee (b)Monitoring (b)

ACCESS RESTRICTIONSigns and Fence

SURFACE WATER MANAGEMENTFlood ControlSite Drainage

UELL REPLACEMENT (d)

CONSTRUCTION SUBTOTALHealth t Safety (10X)ContingencyBid (15X)ContingencyScope (20X)Contingency

CONSTRUCTION TOTALLegal (51)Construction Services (2X)

TOTAL IMPLEMENTATION COSTEngineering i Design (6X)

ON-SITE POND ANNUAL 01* PRESENTREMAINING OPEN ( REPLACEMENT WORTH(ALT. 3B-1) COSTS (ALT. 38-1) (ALT. 3»-1>

62000 12000 7000418000 84000 500001841000 184000 1090001240000360000

14000 1320002000 19000

910002820000

200009000 9000 200014000 6000 5700030000

500002000

53000 50000018000 170000

54000

35200033000soo:

7404000

740000

1111000

1481000

10736000537000215000

11438000689000

ON-SITE POND ANNUAL 0 t MBACKFILLED t REPLACEMENT(ALT. 3t-2) COSTS (ALT. 38-2)

83000 17000555000 1110002642000 2640007265000360000

190002000

910002820000

200009000 900014000 300030000

500002000

2300318000

54000

352000330008000

14408000

1441000

2161000

2882000

208920001045000418000

223550001341000

PRESENTWORTH

(ALT. 38-2

100366C315633

17900190C

2032333

217:;170CO

TOTAL CAPITAL COST 12177000 23696000

TOTAL OCX AND REPLACEMENTPRESENT WORTH

TOTAL PRESENT WORTH

1046000

13223000

847000

24543000

(a) 0 t M costs assuMts replacing 101 of the clay toil cover, and20X of the topsoil and revegctation cost for the Landfill every 10 years

(b) Present worth besed on a 101 discount rate over a 30 year period.(c) OIM costs assuaa replacement every IS years.(d) Plugging existing three wells at Marion Paving Co. and Dobson Construction Co.

and installing three new wells in the lower aquifer.

6-37

Page 166: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TA»LE 6-6(4 of 4)

COST SUMMARYALTERNATIVE 31 <3 t 4)

INDIANA SANITMT LANDFILL CAP, SLUMY UALL, DISCHARGE OF GROUNDUATEH TO POTU

(CAP INSTALLED OVE« REG*AOED EXISTIHC FILL)

COST I TEH

IM3!ANA SANITARY LANDFILL COVER (•)Vegetative CoverTop SoilClay Soil CoverGr»d-'rvgSite ConstructionVegetative Maintenance (b)Sitt Inspect ion (b)

SLURRY UALLFeasibility TestingInstal let ion

CROUNOUATER EXTRACTIONWell InstallationWell fJHM (c)Electrical (b)Collection Piping

TREATMENTSewer Discharge PipeSewer Connection FeeU»ir Fee (b)Monitoring (b)

ACCESS RESTRICTIONSigns and Fence

SURFACE JATER MANAGEMENTFlooc! ControlSite Drsinage

WELL REPLACEMENT (d)

CONSTRUCTION SUBTOTALHealth t Safety (102)Contingencylid C15X)Cont i ngencyScope (205)Contingency

CONSTRUCTION TOTALLegal (5X)Construction Services (2%)

TOTAL IMPLEMENTATION COSTEngineering I Design (6X)

TOTAL CAPITAL COST

TOTAL OtM AND REPLACEMENTPRESENT WORTH

TOTAL PRESENT WORTH

(a) 0 t M costs assim* replacing 1M

ON-SITE POND ANNUAL DIM PRESENTREMAINING OPEN t HEPLACEMENT WORTH(ALT. 31-!} COSTS (AIT. 31-3) (ALT. 31-3)

62000 12000 7000418000 84000 50CCC1841000 184000 109000394000360000

14000 13200C2000 19000

910002820000

200009000 9000 200014000 6000 S700C30000

500002000

53000 50000C18000 170000

54000

352000330008000

6558000

656000

984000

1312000

9510000476000190000

10176000611000

10787000

1046000

11833000

of the clay soil cover, and

ON-SITE PONO ANNUAL 0 I MBACKFILLED I REPLACEMENT(ALT. 3»-4) COSTS (ALT.3B-4J

S300C 17000555000 111000264200C 2640004075000360000

19CCO2000

9100C2820000

200009000 900014000 30C330000

500002000

2300C18000

54000

352000330008000

11198000

1120000

1680000

2240000

16238000812000325000

173750001043000

18418000

847000

19265000

CBESENTUORTH

(ALT. 3B-4;

•003046:3:i5&co:

•790:315003

2C3328C30

z-7o:o173C30

20X of the toptoil and revegetation cost for the landfill every 10 years(b) Prevent worth based on a 10X discount rate ov«r a 30 war period.(c) C&M costs assune replacement every 15 years.(d) Plugging existing three wells at Marion Paving Co. and Dobson Construction Co.

and installing three wells in the lower aquifer.

6-38

Page 167: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TAKE 6-7(1 of 4)COST SUMMARY

ALTERNATIVE 4A (1 4 2)MULTI-LATE* CICtA) CAP. SLLWRT WALL, ANO ON-SITE GROUNOUATER TREATMENT

(CAP INSTALLED OVER EXISTING FILL)

COST ITEM

MULTI-LATER (RCRA) COVER (a)Vegetative Cov«rTop Sol IGeo-TexttteDrainage LayerSynthetic LinerClay LinerPre-Cap MilSite Construction

Site Inspection (b)SLURRT WALL

Feasibility TestingInstallation

GROUNDUA7ER EXTRACTIONuell InstallationUeU PUIDS (c)Electrical (b)Coitection Piping

TSEATMENTCarbon Treatment SystemAir Stripping SystemBui IdingElectricalCarbon (b)Chemicals (b)Labor (b)Maintenance (b)Heat and Electrical (b)Monitoring (b>

ACCESS RESTRICTIONSigns and fence

SURFACE UATE* MANAGEMENTFlood ControlSite Drainage

WELL REPLACEMENTS)

CONSTRUCTION SUBTOTALHealth I Safety (10X)Contingencylid C15X)ContingencyScope (20X)Contingency

CONSTRUCTION TOTALLegal <5X)Construction Services (ZX)

TOTAL IMPLEMENTATION COSTEngine*ring I Design (6X)

CM-SITE POND ANNUAL 0 I M PRESENTREMAINING OPEN ( REPLACEMENT UORTH(ALT. 4A-1) COSTS (ALT.4A-1) (ALT. 4A-1)

62000 12000 7000836000 167000 99000215000 41000 25000978000 196000 116000980000 98000 5800018410001240000160000

14000 1320002000 19000

910002820000

200009000 9000 200028000 6000 5700030000

60000780002SOOOUOOO

13000 12300014000 13200030000 2830006000 STOOD11000 10400030000 283000

54000

352000330008000

10134000

1013000

1520000

2027000

14694000735000294000

15723000943000

ON-SITE POND ANNUAL 0 I MIACTHLLED I REPLACEMENT(ALT. 4A-2) COSTS (ALT.4A-2)

83000 170001112000 222000289000 580001299000 2600001320000 13200026420007285000360000

190002000

910002820000

200009000 900014000 100030000

60000780002SOOO14000

2000200030000600C700030000

54000

352000330008000

17998000

1800000

2700000

3600000

260980001305000522000

279250001676000

PRESENTUORT-

(ALT. 4A-2

103C1310:3ic;15.:;78::

177":9c:

2::9c:

19::15::

2BJ"57"66::2S3"

TOTAL CAPITAL COST 16666000 29601000

TOTAL OUt ANO REPLACEMENTPRESENT UORTH

TOTAL PRESENT UORTH

1497000

18163000

(1) 0 I M cost! assuaes replacing 10X of the synthetic liner and 20X of thedrainage layer, geo-textile, top soil, and vegetative cover every 10 years.

(b) Present worth baaed on a 10X discount ratt over a 30 year period.(c) 0 I M costs assume replaccwnt every 15 years.(d) Plugging existing three walls at Marion Paving Co. and Dobson Construction Co.

and installing three new walls in the lower aquifer.

1343000

30944000

6-39

Page 168: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-7(2 of 4)COST SUMMARY

ALTERNATIVE 4A (3 t 4)

MULTI-LATER (RCRA) CAP, SLURRT UALL, ANO ON-SITE GROUNOWATER TREATMENT(CAP INSTALLED OVER REGRAOED EXISTING FILL)

COST ITEM

HULT] -LATER (RCRA) COVER (•>Vegetative CoverTop SoilCeo-Texti ItDrainage LayerSynthetic LinerClay LinerGradingSice ConstructionVegetative Maintenance (b)Sitt Inspection (b)

SLURRY UALLFeasibility TestingInstallation

GROUNDUATER EXTRACTIONUel I fnstal lat ionWell Punpa (c)Electrical (b)Collection Piping

TREATMENT

Carbon Treatment SystemAir Stripping SystemBuilding I Effluent PipingElectricalCarbon (b)Chemicals (b)Labor (t)Maintenance (b)Heat and Electrical (b)Monitoring (b)

ACCESS RESTRICTIONSigns and Fence

SURFACE UATER MANAGEMENTFlood ControlSite Drainage

WELL REPLACEMENT(d)

CONSTRUCTION SUBTOTALHealth 1 Safety (10X)Contingencylid (151)ContingencyScope (20*)Contingency

CONSTRUCTION TOTALLegal (5X>Construction Services (2X)

TOTAL IMPLEMENTATION COSTEngineering I Design (6X)

ON-SITE POND ANNUAL 0 t MREMAINING OPEN I REPLACEMENT(ALT. 4A-3) COSTS (AIT.4A-3)

j

62000 12000136000 167000215000 43000978000 196000780000 980001S41000394000360000

140002000

910002820000

200009000 9000UOOO 600030000

60000780002500014000

13000UOOO3000060001100030000

54000

352000330008000

9274000

927000

1391000

1855000

1344700067200026 WOO

14388000863000

PRESENT ON-SITE PONO ANNUAL 0 ( MWORTH BACKFILLED ( REPLACEMENT

(ALT. 4A-3) (ALT. 4A-4) COSTS (ALT.4A-4)

7000 UOOO 1700099000 1112000 22200025000 289000 58000116000 1299000 26000058000 1320000 132000

26420004075000360000

132000 1900019000 2000

910002B20000

200002000 9000 OCOO57000 14000 1000

30000

60000780002500014000

123000 2000132000 2000283000 3000057000 6000104000 7000283000 30000

54000

352000330008000

147B8000

1479000

2218000

2958000

214430001072000429000

229440001377000

PRESENTUORTH

(ALT. 4A-4)

10000131COC34C3C154C3:7e:oc

1790C3••9oc:

200:9oc:

19000i9oo:28300:570CD660C32630SO

TOTAL CAPITAL COST 15251000 24321000

TOTAL OtM ANO REPLACEMENTPRESENT UORTH

TOTAL PRESENT UORTH

1497000

16748000

1343000

25664000

(a) 0 t M coats asaine* replacing 10X of the synthetic liner and 201 of thedrainage layer, geo-textile, top soil, and vegetative cover every 10 years.

(b) Present worth based on a 10X discount rate over a 30 year period.(c) OtM costs assure replacement every 15 years.(d) Plugging uniting three wells at Marion Paving Co. and Dobson Construction Co.

and installing three new wells in the lower aquifer.

6-40

Page 169: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TAIIE 6-7(3 of 4)COST SUMMARY

ALTERNATIVE 41 (1 t 2)MULTI-LATER (ItClU) CAP, SLURRY UALL, DISCHARGE Of GROUNOWATER TO POTU

(CAP INSTALLED OVER EX 1ST I HO FILL)

COST ITEM

HULT1 -LATER (RCRA) COVER (a)Vegetative CoverTop SoilGeo-Texti I*Drainage LayerSynthetic LinerClay LinerPre-Cap FillSlt« ConstructionVegetative Maintenance (b)Slti Inspection (b)

SLURRY UALLFeasibility TestingInstal lat ion

GROUNDWATER EXTRACTIONWell Installationu*(l Putc* (c)Electrical (b)Colltction Piping

TREATMENTSewer Discharge Pip*Sewer Connection FeeUser Fee (b)Monitoring (b)

ACCESS RESTRICTIONSigns and Fence

SURFACE UATER MANAGEMENTFlood ControlSite Drainage

WELL REPLACEMENTS)

C3NSTRUCTION SUBTOTALHealth 1 Safety (10X)ContingencyBid (151)ContingencyScope (20VContingency

CONSTRUCT ION TOTALLegal (SX)Construction Services (2X)

TOTAL IMPLEMENTATION COSTEngineering t Design (6X)

TOTAL CAPITAL COST

TOTAL OtX AM REPLACEMENTPRESENT WORTH

TOTAL PRESENT UORTH

OX-SITE POND ANNUAL 0 t N PRESENTREMAINING OPEN 1 REPLACEMENT WORTH(ALT. 4*-1) COSTS (ALT. 41-1) (ALT. 41-1)

62000 12000 7000836000 167000 79000Z1SOOO 43000 2SOOO978000 196000 116000980000 98000 5800018410001240000360000

14000 1320002000 19000

910002820000

200009000 9000 200014000 6000 5700030000

500002000

42000 39600018000 170000

54000

352000330008000

9995000

10000CO

1499000

1999000

14493000725000290000

15508000930000

16438000

1081000

17519000

OM-SITE PONOSACKFUL ED

(ALT. 4i-2)

&300011120002890001299000132000026420007285000360000

910002820000

2000090001400030000

soooo2000

54000

352000330008000

17873000

17B7000

2681000

3575000

259160001296000518000

277300001664000

29394000

843000

30Z37000

ANNUAL 0 t N PRESENTt REPLACEMENT UORTHCOSTS (ALT.4B-2) (ALT. i3-

17000 ICC222000 131C58000 34C260000 154C132000 73C

19000 179C2000 WC

9000 2C1000 9C

6300 57;18000 17;:

(a) 0 I M coats assuaes replacing 10X of the synthetic liner and 201 of thedrainage layer, seo-textile, top soil, and vegetative cover every 10 years.

(b) Present north baaed on a 10X discount rate over a 30 year period.(c) 0*»» costs astum replacement every 15 years.(d) Plugging existing three weds at Marion Paving Co. and Dot*on Construction Co.

and installing three nex Mill in the lower aquifer.

6-41

Page 170: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TA8LI 6-7(4 of 4)COST SUMMARY

ALTERNATIVE 4B-(3 t 4)MULTI-LAY!* (ICRA) CAP. SLURRT WAIL, DISCHARGE OF GROUNDUATE* TO POTU

(CAP INSTALLED OVER RECRAOEO EXISTING Fill.)

COST ITEM

MULTI -LAYER (RCRA) COVER (a)Vegetative CoverToo Soi iGeo-TextileDrainage Laver

Synthetic LinerCtiy LinerGradingSite Conatr-uct ion

Site Inspection <b)SLURRY WALL

Feasibi L i ty TestingInstat Lation

GROUNOWATER EX TRACT I OkW«U Installationwe 1 1 Pui» ( c )Electrical (b)Col lection Piping

TREATMENT

Sewer Discharge PipeSewer Connection FeeUser Fee (b)Monitoring £b)

ACCESS RESTRICTIONSign* and Fence

SURFACE WATER MANAGEMENT

Flood ControlSite Drainage

WELL SEPLACEMEkT(d)

CONSTRUCTION SUBTOTALHealth 1 Safety (10X)Contingencyaid (15X)ContingencyScope (201)Contingency

CONSTRUCTION TOTALLegal (51)Construction Services (2*>

TOTAL IMPLEMENTATION COSTEngineering ( Design (6Z)

TOTAL CAPITAL COST

TOTAL Qt* AND REPLACEMENTPRESENT WORTH

TOTAL PRESENT WORTH

CO-SITE POND ANNUAL 0 t M PRESENTREMAINING OPEN I REPLACEMENT WORTH(ALT. 41-3) COSTS (ALT. 41-3) (ALT. 48-!)

62000 12000 7000836000 167000 99000215000 43000 2500097BOOO 196000 116000980000 98000 580001 84 1000394000360000

14000 1320002000 19000

910002820000

200009000 9000 200014000 6000 5700030000

500002000

42000 39600018000 170000

S4000

3S2000330008000

9149000

915000

1372000

1830000

13266000663000265000

14194000852000

15046000

1081000/-

16127000

CM-SITE POND ANNUAL 0 i MBACKFILLED t REPLACEMENT(ALT. 48-4) COSTS (ALT. 48-4)

83000 170001112000 222000289000 580001299000 2600001320000 13200026420004075000360000

190002000

910002820000

200009000 900014000 100030000

500002000

600018000

$4000

352000330008000

14663000

1466000

2199000

2933000

212610001063000425000

227490001365000

24114000

843000

24957000

PRESENTWORTH

(ALT. 48-4

10CO131CO3400

i 4oL

7ECC

1790:•9C3

2CO900

5703170C:

(•) 0 I H costs *»sut.« replacing 101 of the synthetic Liner end 201 of thedrainage Layer, geo-textile, top soil, and vegetative cover every 10 years,

(b) Present worth based on a 101 diicotnt rate over a 30 year period.Cc? 01* costs assume replacement every IS years.(d) Plugging existing three wells at Marion Paving Co. and Oobson Construction Co.

and installing three new wells in the lower aquifer.

6-42

Page 171: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-43 of 59

Present worth was determined over a 30-year period to allow forcomparison of costs over that period. It should be noted that costswill continue to accrue where operation and maintenance is requiredafter the 30-year period? however, the present-worth analysis does notreflect these additional costs. As per U.S. EPA guidance, no costexpenditures in the future are escalated to reflect inflation. A 10percent discount rate is applied to future values in computing presentworth.

Health and safety requirements are estimated to include Levels C and Dpersonal protective equipment. During construction, vehicledecontamination would be required for all vehicles having directcontact with contaminated soil and landfill wastes. During finaldemobilization of equipment, the vehicles and hand equipment used onsite would be steam cleaned. Workers who would be exposed to thecontaminated soil during on-site activities would receive physicalexaminations before and after all phases of activity involving directworker exposure to contaminated elements of the site. These elementsof health and safety measures are covered in a supervision/health andsafety contingency designed to include costs incurred for work onhazardous waste sites above and beyond those incurred on traditionalconstruction jobs.

6.4.3 Cost Sensitivity Analysis

Costs presented in this section represent order-of-magnitude estimatesassembled from information available at the time of the estimate. Todevelop useful cost estimates for feasibility assessment, it wasnecessary to make reasonable assumptions regarding labor and materialcosts, site conditions, etc. If actual conditions vary substantiallyfrom the estimates made, the cost of an alternative may be outside theorder-of-magnitude range presented here. Factors, such as deviationsin estimated labor and material costs, are not considered significantto the extent of altering total costs to values outside theorder-of-magnitude range. The only component that differs amongalternatives is the manner in which treatment of groundwater isprovided. The factors that may substantially influence the costestimates for groundwater treatment are:

o Future groundwater contaminant levelso Leakage through slurry wallo Leakage through the Indiana sanitary landfill or the

multilayer cap

These factors were evaluated for their influence on cost estimates ofthe alternatives (Table 6-8). Where applicable, the factor was variedover a range considered reasonable for the Marion/Bragg landfill site.The effect on alternatives was rated as to its potential for

Page 172: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-8

COST SENSITIVITIES OF ALTERNATIVES

ALTERNATIVES

FACTOR 1 2 3A 3B 4A 4B

Future Contamination LevelsIncrease by 100 times ++ ++ ++ ++ ++ ++Decrease by 10 times 0 0

Slurry Wall Hydraulic ConductivityHigher by 10 times NA NA + + + +Lower by 10 times NA NA 0 0 0 0

Leakage through Landfill CapIncrease by 2 times NA NA + + + +Decrease by 2 times NA NA

++ Significant increase in alternative costs. May affectalternative selection in using Marion POTW.

+ Moderate increase in alternative costs. Does not affectalternative selection.

0 No substantial change in alternative costs. Does not affectalternative selection.

- Moderate decrease in alternative costs. Does not affectalternative selection.

Page 173: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 6July 31, 1987Page 6-45 of 59

significantly increasing or decreasing the cost. Double pluses areused to designate a factor has the potential for significantlyinfluencing cost and should be considered when selecting analternative.

Future contaminant levels have the most significant impact onalternative selection. If contaminant levels increase by 100 tines ormore, Alternatives 1 and 2 will likely require additional remedialactions for groundwater including construction of a slurry wall andwill greatly increase the cost. Ihe probability of increasing ordecreasing contaminant levels is difficult to estimate since littleinformation is available on contaminant source characteristics and itis not practical to obtain this information on this type of site.

Increasing contaminant levels also would significantly change therelative cost differences between the groundwater treatmentalternatives. If COD levels in the effluent were to increase by 10times, the POIW treatment costs would greatly increase as a result ofincurring organic loading user charges in addition to the flow usercharge applicable to the existing waste stream. It is likely thatMarion POIW may not be able to handle the groundwater discharges atthese high ODD concentrations because of its impact on the POIWoperation.

Minor increases in slurry wall conductivity or leakage rates throughthe cap will not affect groundwater treatment options.

6.5 INST IUnC PJVENVIRONME 7a/PUBIJC HEAUH ANALYSIS

In the detailed evaluation and final selection of a remedial actionalternative, adequate protection of public health, welfare, and theenvironment is a major concern. Ine NCP requires for eachalternative:

o An assessment of the extent to which the alternative isexpected to effectively prevent, mitigate, or minimizethreats to, and provide adequate protection of, publichealth and welfare and the environment [40 CFR300.68(h)(2)(iv)].

o An analysis of any adverse environmental impacts, methodsfor mitigating these impacts, and costs of mitigation [40CFR 300.68(h)(2)(vi)].

In this section, each alternative undergoing detailed analysis isevaluated with regard to its impact on institutional, environmental,and public health concerns. This analysis evaluates short-term(construction-related) impacts, those impacts related to the operation

Page 174: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-46 of 59

of the remedial technology, and the final results of the remedialaction alternative.

EPA's informal position is that CERCIA discharge to POTWs can occuronly if it is done so in a manner that is protective of human healthand the environment, and also conplies fully with all applicable andrelevant or appropriate requirements of environmental statutes. Anecessary adjunct to this is that the POIW has a pretreatment programthat is able to prevent pass-through of the POIW or interfere withPOIW operations (including sludge disposal).

Chemicals currently detected in the Marion/Bragg Landfill groundwaterare present in low concentrations, and are amenable to removal in thePOIW and also would not interfere with the activated sludge operationat the Marion POIW. Marion POIW has a pretreatnent permit with asuitable pretreatment program established.

Current EPA policy considers residue of treatment of material fromCERCLA sites to be hazardous waste, and to be handled in accordancewith RCRA, unless proven otherwise by delisting procedures. For theon-site treatment option the only residue is spent granular activatedcarbon. Disposal of this material would be in off-site carbonmanufacturers regeneration facilities, and would have to be consistentwith EPA policy for off-site disposal.

The institutional analysis examines the ability of each alternative toattain federal, state, and local environmental and public healthstandards, regulations, guidance, advisories, and ordinances.

The public health analysis considers a broad range of public healthand welfare concerns. Criteria used in evaluating the impact onpublic health and welfare include; public health risks; odor, noise,air and water pollution impacts; impact on parks and recreation;and impact on traffic.

The environmental analysis evaluates such impacts as wildlife habitatalteration; water pollution; toxic and adverse effects on plants andwildlife; impacts on threatened and endangered species; naturalresource loss and diminution; and impacts on wetlands, prime farmland,and unique resources.

General Institutional Considerations

This institutional analysis considers general concerns andrequirements that are common to all of the alternatives.

Page 175: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-47 of 59

Coordination with Other Agencies

The authority to manage certain aspects of CERCLA responses has beendelegated to several federal agencies. Those federal agecies that mayhave responsibilities in the CERCLA response to the Marion/BraggLandfill site are shewn in Table 6-9.

CERCLA Compliance with Environmental Statutes

In determining appropriate remedial actions at CERGLA sites,consideration must be given to the requirements of other federal andstate environmental laws in addition to CERCLA.

Applicable laws and standards are those that would be specificallytriggered when the law or regulation is clearly, and indisputably thecontrolling authority for the planned action for the proposedSuperfund remedy except that the proposed action would be undertakenpursuant to CERCLA Section 104 or 106; e.g., applicable laws andstandards are those that would legally apply if the action was notbeing taken under the authority of CERCLA. Relevant and appropriatelaws or standards are those where the intent of the law or standard isto apply to circumstances sufficiently similar to those encountered atCERdA sites. The term "relevant and appropriate" means that the lawor regulation need not be truly applicable to or legally required forthe proposed action or existing circumstances, but that the intent ofthe law was to control similar situations. The applicable or relevantenvironmental and public health standards are reviewed for eachalternative and are summarized in Table 6-10.

For the alternatives developed for the Marion/Bragg T n fHi site,several federal environmental laws and regulations are not applicable.These laws and regulations, along with the reasons for theirnonapplicability, are presented in Table 6-11.

The site is not in coastal zones, critical habitats, wetlands, primeagricultural lands, federal parklands, national forests, wild andscenic rivers, or wildlife sanctuaries and refuges. The site is inthe 100 year flood plain of the Mississinewa River. Therefore, theseenvironmental standards, guidance, or advisories will not be addressedexcept for flood plains. No known threatened or endangered specieswill be affected by the implementation of alternatives.

General Public Health Concerns

The public health evaluation of the No Action alternative highlightedfour major exposure concerns. They include exposure to groundwater;on-site pond; leachate seep and sediment and on-site surface soil.Groundwater exposure routes include ingestion and dermal absorption.

Page 176: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg landfill SiteSection: 6July 31, 1987Page 6-48 of 59

TABLE 6-9

FEDERAL AGENCY COORDINATION

Federal EmergencyManaaejnent Agency(FEMA)a

Health & HumanServices (KHS)

U.S. Array Corps of

Occupational Safetyand HealthAdministration(OSHA)

Bureau of Land

Advisory Council onHistoric Preserva-tion

U.S. Fish and Wild-life Service(USFWS)

U.S. Forest Service(USFS)

Department ofHousing and UrbanDevelopment (HUD)

Department ofTransportation (DOT)

Conroents

No alternative requires relocation of a businessoperation. If relocation becomes necessaryafter selection of a remedial action, FEMA willbe notified.

All alternatives that involve action will bepreceded by a contact with HHS to request theappropriate support.

COE will be contacted when EPA hasselected a remedial action and isprepared to proceed with design andconstruction.

All alternatives that involve action may requireOSHA contact prior to action to provide inputand assistance if necessary.

No federal lands are involved in the implementa-tion of alternatives.

No landmarks, historic sites, or areas ofhistoric, scientific, or cultural interest willbe affected by the implementation of alterna-tives.

No game species or fish are expected to beaffected by any of the alternatives.

No Wild and Scenic rivers will be affected byimplementation of alternatives.

The site does lie in a flood plain.

On-site treatment alternatives require off-sitetransportation of spent granular carbon.

aCoordination with this agency is not anticipated to be needed at thissite.

Page 177: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-10 (Page 1 of 3)

COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTSMARION/BRAGG LANDFILL SITE

REGULATION, POLICY OR LAW

FEDERAL

APPLICABILITY RESPONSE

ALTERNATIVES

1 2 3A 3B 4A 48 5

Resource Conservation andRecovery (RCRA) Subtitle C

Closure of Hazardous WasteFacilities

This alternative meets RCRAcapping requirements.

This alternative meets RCRAclosure requirements.

X X

X X

40 CFR 264.116

40 CFR 264.14264.117(6)

Deed Restriction

Access Restriction

State of Indianahas jurisdiction.

Meets RCRA requirementsif implemented.

X X X X X X

X X X X X X

40 CFR 264.310(b)(5)

40 CFR 264.90 3008(h)3004(u)

Monitoring SurfaceRun-Off (Final Cover)

Contamination Levels,Monitoring, Treatment

Surface water managementsystem would comply with RCRArequirements.

Action levels in on-site pond,groundwater and Mississinewariver w i l l be set by U.S. EPA.

X X X X X X

X ' X

6-49

Page 178: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-10 (Page 2 of 3)

COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTSMARION/BRAGG LANDFILL SITE

REGULATION, POLICY OR LAW

40 CFR 264.310

APPLICABILITY RESPONSE

ALTERNATIVES

2 3A 3B 4A 4B 5

X

40 CFR 270.H

RCRA Landfill Cover Systems

Slurry Wall

This alternative meets RCRAcapping requirements.

This alternative meets RCRAClosure requirements.

Slurry wall w i l l be locatedbehind the flood control levee.

X x

X X

X X X X

40 CFR 264.340(c) Treatment/Incineration None of the alternatives involvetreatment or incineration oflandfill contents.

40 CFR 262 & 263

40 CFR 261.4(8X2)

40 CFR 264.114

Clean Air Act (CAA)

Groundwater Storage

Groundwater Discharge

None of the alternatives involvethe storage and surface trans-portation of contaminatedgrounduater.

Discharge of groundwater toHississinewe River wouldcomply with CVA, Section 402.

Decontamination of Equipment Equipment decontaminationprocedures w i l l be followedduring construction.

Inc i nerat i on/T reatment None of the alternatives involveincineration or treatment ofhazardous soiI.

X X X X X

Clean Water Act (CWA) Regulates Discharge ofWater into Rivers

State of Indiana has jurisdic-tion over issuance of NPDESpermits (See state ARARs).

6-50

Page 179: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 6-10 (Page 3 of 3)

COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTSHARION/BRACG LANDFILL SITE

REGULATION, POLICY OR LAU

STATE OF INDIANA

APPLICABILITY RESPONSE

ALTERNATIVES

1 2 3A 38 4A 48 5

Indiana Dept. of EnvironmentalManagement (IDEM)

Indiana Hazardous UasteManagement Program (I HUMP)320 IAC-4

Regulates Closure of Existing This alternative is in compli-Hazardous Waste Facilities ance with IHWMP.

X X

Indiana Uaste Treatment Facil-ities Regulation (IWTFR)330 IAC-3.1

Authorizes and Regulates Uaste This alternantive provides forTreatment Facilities an en-site treatment facility

and complies with IUTFR.

Industrial Uaste Uater Regulates Discharges to State This alternative will requirePretreatment and NPDES Program Uaters NPDES an NPOES permit.330 IAC-5CI-10)

Pretreatment Standards330 IAC-5C11-15)

Regulates Discharge to POTU This alternative includesdischarge of contaminatedgrounduater to Marion POTU.

Indiana Uater Quality Standards Establishes Uater QualityStream Pollution Control Board Standards for the State330 IAC U2(b)

Title 329 (Proposed)Solid Uaste Management Board329 IAC 2-8-C4.7)

2-9-(2.3)

This alternative is subject tocompliance with Indiana UaterQuality Standards.

Regulates Solid Uaste Landfill This alternative will complyClosure with proposed solid waste

regulations.

X X X

X X

Dept. of Natural ResourcesDivision of Uater

IndianaFlood Control ActI.C.13-2-22

Regulates construction in aflood plain

This alternative is subject tocompliance with DNR Divisionof Uater requirements.

LOCAL

City of Marion Municipal CodeOrd. 8-1981

Regulates discharge tomunicipal sewer system.

This alternative is subject tothe requirements of the Marionsewer use code.

6-51

Page 180: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-52 of 59

TABLE 6-11

FEDERAL ENVIRONMENTAL LAWS AND REGULATIONS NOTAPPLICABLE OR RELEVANT AND APPROPRIATE TO ALTERNATIVES

Law or Regulation

Underground Injection ControlRegulations

Ocean Dumping Requirements

Disposal of certain waste materialcontaining TCDD (40 CFR Parts 260 to267, Subpart J)

Uranium Mill Tailing Rules

Radioactive Waste Rule—High and LowLevel

Asbestos Disposal Rules

National Register of Historic Places

Wild and Scenic Rivers Act

Protection of Threatened or EndangeredSpecies and Their Habitats

Conservation of Wildlife Resources

Coastal Zone Management

Relocation Assistance and PropertyAcquisition

Toxic Substance Control Act

Analysis

None of the alternatives include theunderground injection of materials.

Implementation of the alternatives doesnot include the dumping of any materialsin the ocean.

The contaminated materials to bedisposed of or treated in any alterna-tive do not contain TCDD as a con-taminant.

The site contains no uranium milltailings.

The site does not contain high- orlow-level radioactive waste.

Asbestos was not measured at the site.

Implementation of the alternativeswill not affect sites on the register.

Rivers on the national inventory willnot be affected by alternatives.

Implementation of the alternatives willnot affect threatened or endangeredspecies and their habitat.

Implementation of the alternatives willnot affect areas of important wildliferesources.

Implementation of the alternatives willnot affect a coastal zone.

Implementation of the alternativesshould not require relocation ofresidences or businesses or acquisitionof property.

Site does not contain PCBs and would nottrigger TSCA requirements-.

Page 181: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-53 of 59

On-site pond exposure routes include incidental ingestion, dermalabsorption and ingestion of fish. On-surface soil and leachateseep/sediment exposure routes include incidental ingestion and dermalabsorption. Each alternative is specifically evaluated for its impacton mitigating these potential exposures.

6.6 INb'lTIUI O IAI/ENVTRO M£ ^ AL/HJBLIC HEALTH EVALUATION OFAT rrERNATTVES

Alternative 1 - Indiana Sanitary Landfill Cap and Monitoring

Access and deed restrictions and sanitary landfill capping wouldeliminate the potential for exposure due to direct contact withcontaminated soil and leachate seeps. However, this does notconstitute a RCRA-type closure. If the on-site pond is notbackfilled, the access restriction will reduce the potential forexposure to the on-site pond; however, the potential future publichealth risk associated with the on-site pond still remains if actionlevels are exceeded. Deed restrictions would eliminate the potentialuse of groundwater from the site and thereby eliminates the associatedpublic health risks. Since groundwater is not treated, the potentialfor public health and environmental risks remain if action levels areexceeded in the on-site pond and the Mississinewa River. Short-termconstruction impact, such as noise and dust, would result frominstallation of a cap over the landfill. These impacts would begreater if the site is regraded prior to cap installation.

Difficulties may be encountered in implementing and enforcinginstitutional and access controls. For example, the effectiveness ofdeed restrictions for long-term actions has not been established.Failure of deed restrictions could result in exposure to contaminantsat some future time.

Alternative 2 - Multilayer fRCRA) Cap and Monitoring

Discussion presented for Alternative 1 is applicable to thisalternative. This alternative constitutes a RCKA-type closure for ahazardous landfill; however, not all of the RCSA closure requirementswill be met since no treatment is provided for the groundwater. As inAlternative 1, the difficulties in implementing access and deedrestriction remain a concern. If these restrictions are noteffective, the potential for the installation of on-site wells and useof contaminated groundwater exists.

The short-term construction impacts would be greater compared toAlternative 1 because installation of the multilayer cap is moreextensive construction activity than the sanitary landfill cap.

Page 182: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-54 of 59

Alternative 3A and 3B - Indiana Sanitary landfill Cap, Slurry Wall,Groundwater Extraction and Treatment fOn-Site or Marion POTW)

Alternative 3A and 3B mitigate public health and environmental impactsof the Marion/Bragg Landfill site. Installation of a cap over thesite is effective in preventing direct contact with contaminated soiland leachate seep. Use of a slurry wall precludes the release ofcontaminants from groundwater to the Mississinewa River and eliminatesthe groundwater exposure pathway. If the pond is not backfilled andaccess restrictions are not effective, the risJcs associated with theon-site pond if action levels are exceeded would retrain.

Short-term construction impacts, such as noise and dust, could resultfrom installation of cap, extraction wells and slurry wall.

Institutional concerns regarding permitting for groundwater dischargeto either the Mississinewa River or the Marion POIW are essentiallythe same.

This alternative does not constitute a RCRA-type closure for hazardouswaste landfill. However, the other requirements of RCRA are achieveddue to prevention of migration of groundwater to the MississinewaRiver and providing treatment of the groundwater.

Institutionally, Alternative 3A and 3B would have the same concernsregarding implementation and effectiveness of access and deedrestrictions as discussed for Alternative 1.

Alternative 4A and 4B Multilayer (RCRA) Cap, Slurry Wall, GroundwaterExtraction and Treatment fOn-Site or Marion POIW)

Alternative 4A and 4B differ from Alternative 3A and 3B only withrespect to the installation of a RCRA cap instead of a sanitarylandfill cap. Ihe discussion presented for Alternative 3A and 3Bapply to this alternative with the following exceptions:

o Short-term construction impacts would be greater becauseinstallation of the multilayer cap is more extensiveconstruction activity than the sanitary landfill cap.

o Ihis alternative would meet all the intents of RCRA closurebecause of the use of a multilayer cap.

Alternative 5 — No Action

Existing and potential future endangerment to public health, welfare,and the environment would not be mitigated. Access to the site wouldnot be restricted and direct contact with contaminants in the soil,

Page 183: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-55 of 59

and leachate seep is possible. Contaminants have the potential to bereleased from the fill into the groundwater. A potentially completegroundwater exposure pathway will exist under this alternative. Thereis a concern for potential adverse public health and environmentalimpacts if future releases of contaminants should occur.

Institutional impacts of No Action would primarily involvenoncompliance with appropriate environmental laws and regulations (seeTable 6-10). Not controlling contaminant movement through the aquiferwould be counter to U.S. EPA's groundwater protection strategy. Thisalternative would not minimize and mitigate the threat to publichealth, welfare, and the environment, and therefore, would not fulfillthe objectives of CERCLA.

6.7 SIM4AHY OF THE DETAILED ANALYSIS OF AITERNATTVES

A summary of the detailed analysis of alternatives is presented inTable 6-12.

All alternatives, except No Action, rely on deed restrictions toprevent future site excavation or use of on-site groundwater. Thereliability of the concept is good in the short term, but long-termreliability is unknown. Alternatives 1 and 2 rely upon monitoring todetect increases in types and concentrations of contaminants. If theaction levels are exceeded, then additional on-site remediation wouldbe required since the receptor of groundwater is the MississinewaRiver. Alternatives 1 and 2 would not meet RCRA groundwaterprotection requirements and EPA groundwater protection policy sincecontaminant migration is not eliminated. Since Alternatives 3A, 3B,4A and 4B prevent migration of groundwater to the Mississinewa Paverdue to the slurry wall and treatment of groundwater (on site or MarionPOIW), these alternatives are considered to be more reliable thanAlternatives 1 and 2.

For alternatives not involving extraction of groundwater, the IndianaSanitary Iarrifi.il cap (Alternative 1) would not meet RCRA closurestandards, but would eliminate public health risks associated withdirect contact with surface soil and landfill content. Alternative 2involves the installation of a multilayer cap that would meet RCRAcapping requirements. Since the volume of groundwater flowing throughthe upper aquifer is much higher than the amount of infiltration,reduction in the amount of infiltration provided by the more expensivemultilayer cap may not be justified.

For groundwater treatment alternatives (3A, 3B, 4A, 4B), theinstallation of a slurry wall is essential to reduce the volume ofgroundwater that must be treated. Slurry wall construction will alsoprevent migration of contaminated groundwater to the Mississinewa

Page 184: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

u

SliJiiti. ,,* sSf kI. ini^---J!-!i:fi I'ili:

f j !Si | 5 • ' - \ t -ifjf!Jh|!5?ii!i»iifssfi: k T J t i

1j P- . A if'

I St *i

s j * f ' f j . j t s k ' u — r i s i J " i'KjP'lrl-i' "iiif'ti*"j.E*:»-ir':U k»!i-iiilj »if{|«H|jiPi] }ik;j^iMt=i{kK-:i;ilijJ iis4^|f*lsijtiiijiihiiji iiis^lhal

Page 185: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Is .—.

I viiiilii.-5 iiilIs;

i-;N*f

DC

mt

ICH

i|j jf ||L >!i{| l!i ijil i!

isifjjj^jijjif<H|iJ|!^u'^|:A

MI'S

lTal

ni] jij Ifa

Ml.-u

cl io

n.

.,ld

b

a

aao

rad

od

m 'iiI •!i il!'! iN

si

E.:B: ! ' - l 5 i [ ; i|Edi;jiii;!r.jj;

I

!ii= iihijl tjii\-. {;l i '? k IIiii ilUii! niiMlmnii ifi-tf^'l

l!'liS!

sill Ji|iil Pi If-t !|{5 ! ; *{" '!r-j ;3? : » = |;! il H -:i,]= l;ii N

H!=ii

!! i

li'i!

?IU :-! i"-1 »!!!]= iij Ifil ?|ij»l * = 5 ! « ] } fiiil l1^ !l i 11k ^ - 5 J J I-}? - S i i l ! ihit* i»^ iijl 1^

= H MI Mi ii

I ' l l - l ! j J ;i im

< J j < * r ji.; hiskl'i-'SfIslH.i

Hi

t ie ? • ° I ' ^ • / - , J -

UrJiil j!i ;;»?;i^irr |r. i8Ml? 7 - - v * i « t * [ - e

ior.

ldta

cti

or.

Utiu

ld»

,v»

M

H'

*.«

*d

. n*.,

.tarx

ia-T,S . r;..

nJvatv

r p

raB

<

f>ft

t.fu

r a»

J «-»

c t'

cto

lnlv

d.

ith

H

t^l :|:iii*r ;in-.t&rjij.ij! iilfiM&iii H 1s •»nliihh! im h«i

'B *

ft-'ii

uHi

S )ii L| 1}il li

fii i1)!

!&BIWIJ ill!I iBiill

uliiibliih HIO

I!i

Daa

a not

aaat

«j

r«undM

at*r

pra

tac

tto

n a

oa

l*.

lB r«

«' =tis1«r jil»iiii, Piilli iilJi

Page 186: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

(All! * 1? (»tg* ) <

[Till Of ALt f tNUIVTI

•CM LI Itll

0*1101 CtltltU

EVAlUAtlOM

UMHATIVff 1

IW1W tAMITAAT UNQMll O* tUTI-LATf* (iC»A) CM

rVALUAMO" CUTfllA AM MOHtT01|N6 AM MNttOirM

INDIAN* SAIItAIT l*MMll ttf

IIUMT MIL AM ON-fllf

0*01*0** t (I Ttf ATNMT

AH MUM i vt MINDIANA UMIURT I»«f1ll t*fJIUtIT Mil *HD DllCIUflCf Of

ATII 1*0*1 c*>l AHO DltCNARU Of

!* TO lutioi ratw

CAPITAL0 1 M amTotil fr*i

7,in.«M1,011,000B.26A.OOQ

11,144,0001,2tt.OOO

II,644.000

JA 1

S* 1

1Z.W.OOO1,tli.OM

11,794,000

14,446,000

l,i*r,000tS.t61.000

16.4Jfl.000

1.081.000

CAPITALO K U pr««

11.702.000

1.090,000i«, m, ooo

24,401,0001,24^,000

2).6W.OOO

11 IMl)• 2

U. 49*, 0004U.OOO

24^(1,000

4A I 29,601.000(.A I t .Ul .OOO4A 2 10.9U.OOO

29.194,0004iJ,000

lo.2ir.ooo

5,791,000

1,001,0006,er2,ooo

10.mi,ooo1,220,000

11,271.000

M l11 1Si 1

10.787.0001.M6.000

M.Bll.OOO

I 1 ii.2i1.000I 1 1,4*7,000k 1 16.74S.OOQ

41 J

41 1

41 1

15,046,0001,Ml,000

16,127,000

O 1 H pr«t*nt Worth

itln« fUl tilth pond bKkflU«d

0 i H pTM«nt Worth11,421.0001.090.000

14.111,000

14.121.0001,?4V000

M, 3*4.000

J* 4U - 4

18.421.0001,242.000

i*.MI. OOO

H-4 IB. 419,000M 4 6LI,OOO

M-4 '9.261,000

24,121.0001.141.000

21.664.000

24.114,000&41.000

6-58

Page 187: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 6July 31, 1987Page 6-59 of 59

River. Alternatives that involve the use of a slurry wall andgroundwater extraction and treatment would meet CERCLA goals and U.S.EPA groundwater protection policy.

Both the on-site (carbon adsorption) and off-site (Marion POIW)groundwater treatment alternatives are technically feasible. However,the on-site groundwater treatment alternatives (3A and 4A) are lessreliable than the off-site treatment alternatives (3B and 4B) becauseof greater reliance on operation and maintenance of the on-sitetreatment facility.

Alternatives 1 and 2 provide protection of the public health and theenvironment from the risks associated with on-site soil contaminationand leachate seep migration due to the installation of a cap. Limitedprotection from risks to public health associated with the on-sitepond if action levels are exceeded are provided by access restrictionfor alternatives that do not include pond backfilling. Protectionfrom risk to public health associated with potential future use ofsite groundwater is provided by deed restriTtions. Deed restrictionsmust be enforceable for an extended period of time.

Alternatives 3A, 3B, 4A, 4B provide all of the protection associatedwith Alternatives 1 and 2 and also provide protection of the publichealth and environment from risks associated with groundwater andpotential contamination of the river due to groundwater containment,extraction and treatment.

Hie No Action alternative does not provide any protection of thepublic health and the environment from the contaminants present at thesite.

Page 188: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 7July 31, 1987Page 7-1 of 5

SECTION 7

SELECTION OF INTERIM REMEDY

Ihis section presents the rationale for the selection of an interimremedy for the Marion/Bragg Landfill site based on the detailed eval-uation of various alternatives presented in Section 6.

7.1 DISCUSSION OF ALTERNATIVES

Five alternatives including the No Action alternative were evaluated.All alternatives other than the No Action alternative include accessand deed restrictions; and flood protection measures. Access and deedrestrictions were utilized to reduce existing and potential futureuses of the site. Flood control measures were required because aportion of the site lies within the 100 year flood plain of the Mis-sissinewa River.

All alternatives other than the No Action alternative include closureof the site using either the Indiana sanitary landfill or multilayer(RCRA) cap. Capping of the site will eliminate public health risksassociated with on-site surface soils and leachate seeps. The publichealth evaluation indicated that there are no current human healthrisks associated with swimming or fishing in the on-site pond, basedon existing data, however, as long as the exposure pathway is noteliminated, the potential for risk is still present. Action levels todetermine the need for future remediation of the on-site pond will beset by U.S. EPA and Indiana Department of Environmental Management(IDEM). Monitoring of the on-site pond has been included as acomponent for Alternatives 1 and 2. In the event monitoring indicatesaction levels have been exceeded, the decision to implementbackfilling of the pond will be made by regulatory agencies at thattime. Therefore, all landfill closure alternatives include leavingthe on-site pond open or backfilling the on-site pond in order toprovide a cost comparison in the event that the future risks warrantbackfilling the pond to eliminate exposure pathways such as swimmingand fishing.

The results of the public health and environmental evaluationindicated that there are no current human health risks associated withthe groundwater discharge to the Mississinewa River. However, risksto the aquatic life will require additional investigation in order todetermine if there is an existing impact or potential for futureimpact. Action levels to determine the need for on-site groundwaterextraction and treatment will be set by U.S. EPA and IDEM at a futuredate, based on additional study and groundwater Tnonitoring.Monitoring of the on-site groundwater and Mississinewa River has beenincluded as a component of Alternatives 1 and 2. In the eventjnonitoring indicates .that.action levels are exceeded, the decisionjto""jotplement groundwater extraction and treatment will be made by .regulatory agencies at that time. Therefore, groundwater extraction

Page 189: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 7July 31, 1987Page 7-2 of 5

and treatment was included for several alternatives. To preventmigration of groundwater to the Mississineva River, an inward gradientmust be created by groundwater extraction. Due to the proximity ofthe site to the Mississinewa River, large volumes of river water willalso be extracted along with the groundwater. To minimize the amountof groundwater extracted for treatment, it was determined that aslurry wall around the perimeter of the site will be required.Therefore, a slurry wall has been included for all alternatives invol-ving groundwater extraction and treatment (Alternatives 3A, 3B, 4A,and 4B). Extracted groundwater will be treated either in on-sitefacilities (Alternatives 3A and 4A) or discharged for treatment at theMarion POIW (Alternatives 3B and 4B). On-site treatment ofgroundwater includes carbon adsorption for organics and trace levelsof metals and air stripping for ammonia removal.

The capital, operation and maintenance and total present worth costsfor all alternatives are summarized in Section 6 (Table 6-12).

7.2 SEIZCnON OF INTERIM REMEDY

Section 121 of SARA requires that all remedies for Superfund projectsbe protective of human health and the environment and comply withother state and federal laws which are deemed applicable or relevantand appropriate. Based on the evaluation of all alternatives usingthe SARA requirements and the technical, public health, environmentalimpacts and cost criteria, the U.S. EPA, in conjunction with IDEM, hasselected Alternative 1C as an interim remedy (see Section 6). Theinterim remedy consists of capping the site utilizing the Indianasanitary landfill closure requirements, monitoring the groundwater,and conducting additional study on the nature of groundwater releasesto the surface waters. This includes the on-site and off-site pondand the Mississinewa River.

This interim remedy is considered a cost-effective source controlmeasure. It complies with the State of Indiana sanitary landfillclosure requirements and is protective of human health threats whichmay be presented by direct contact with surface soils and leachateseeps. Capping is a necessary and minimum building block component ofall groundwater alternatives. Therefore, it is consistent with anygroundwater remedy which may be selected. Selection of groundwaterremedy will be deferred until additional data can be gathered on thenature of groundwater release to the on-site pond, adjacent off-sitepond and Mississinewa River.

The principal components of the selected interim remedy includes thefollowing:

o Access and deed restriction

____..__ .__.._ o _ Flood contrql_measures_ __. .... . _.._.—— —.-...._.....-._.

Page 190: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Rragg Landfill SiteSection: 7July 31, 1987Page 7-3 of 5

o Indiana sanitary landfill cap

o Monitoring and further study of the on-site pond, on-sitegroundwater and the Mississinewa River

The rationale for selection of the interim remedy for the Marion/EraggLandfill site are discussed below.

Access and Deed Restriction

The site is presently not fenced and therefore access to the site isunrestricted including the use of the on-site pond for swimming andfishing. Fencing and posting of signs would limit public access tothe site and help to prevent the use of on-site pond by the public.

The public health evaluation indicated minimal risks associated withswimming and fishing in the on-site pond. However, since the landfillwaste material will remain in place, that is, saturated within theaquifer which recharges the pond, the pathway will remain open forpossible exposure to contaminants. Access restriction will preventthis possibility.

Any private use wells within the site boundary and within the sameaquifer as the landfill have the potential to be contaminated by thelandfill. Therefore, existing shallow on-site private wells will beabandoned and plugged in order to mitigate potential exposure tolandfill contaminants which have impacted the aquifer beneath thesite. New wells will be installed in the lower uncontaminated aquiferfor on-site private wells.

A deed restriction will be placed on the property to prevent theconstruction of shallow wells for private use.

Flood Protection Measures

A portion of the site lies within the 100 year flood plain of theMississinewa River. Flooding of the site has the potential to damageon-site groundwater monitoring wells and the integrity of the cap.Therefore, a flood protection levee will be constructed to preventflooding of the site.

Indiana Sanitary Landfill Cap

After cessation of the landfilling operations at the site, a propercap was not installed over the landfill waste material. It has beendetermined that there are public health risks associated with theon-site surface soils and leachate seeps. To provide for properclosure of the site and to mitigate the existing risks, a cap will beinstalled over the landfill portion of the site. Two options forcapping the site were evaluated. ..These included the use of either the"Indiana sanitary landfill cap or the multilayer (RCRA) cap. Each of

Page 191: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 7July 31, 1987Page 7-4 of 5

these cap types would meet the objectives of proper site closure toprevent risks associated with on-site surface soil and leachate seeps.However, the Indiana sanitary landfill cap was selected over themultilayer (RCRA) cap because the multilayer cap costs approximately4.26 million dollars more than the Indiana sanitary landfill capwithout providing any substantial increased benefits. This alsocomplies with sanitary landfill closure requirements.

The on-site pond will not be backfilled at this time. Existing datadoes not suggest that there is a current risk from swimming or fishconsumption. Fish consumption assessment was based on theoreticalbioaccumulation factors. Fish samples will be collected to verify theexisting assessment. The on-site pond water will also be monitored.In the event that additional monitoring indicates an unacceptable riskto human health or the environment, the decision to implement thebackfilling option will be made by the regulatory agencies at thattime.

Monitoring and Additional Investigations

Sampling of the Mississinewa River did not indicate the presence ofcontaminants that could be attributed to the site with the exceptionof ammonia. This lack of detectable contaminants in the river may bedue to the high dilution rate afforded by the river. Therefore,action levels for on-site groundwater have been proposed based on theNPDES permit approach as presented in Section 6.2.2. As long as theon-site groundwater concentrations for parameters of concern are lessthan their corresponding action level (presented in Table 6-2), theresulting concentration in the river should remain within allowableambient water quality criteria. Of the parameters of concern pre-sented in Table 6-2, two, arsenic and ammonia, were detected at asignificant frequency (arsenic 10 out of 21 samples, ammonia 16 cut of24 samples). The concentration of these two parameters exceed theaction levels proposed by the NPDES approach. Three additionalparameters (cadmium, silver, zinc) do not exceed the action levels,based on existing Indiana regulations;, however, they do exceed theaction levels based on proposed Indiana regulations. However, each ofthese parameters was detected in only 1 out of 21 samples.

In general, the inorganic parameters have very low water qualitycriteria. Therefore, aquatic impacts may occur at very lowconcentrations. Further study on inorganic contaminants will berequired for the surface waters in order to determine if thegroundwater beneath the site has adversely impacted the aquaticenvironment or presents any human health risks from ingestion ofaquatic organisms such as fish. Similarly, the chronic release ofammonia and its potential impact to the aquatic life will requireadditional investigation.

_It has been determined that the effect of the interim remedy, .in __particular installation of the cap, on the concentrations ofparameters of concern will be evaluated through a monitoring programto establish the need for future remedial action including backfilling

Page 192: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Feasibility StudyMarion/Bragg Landfill SiteSection: 7July 31, 1987Page 7-5 of 5

of the on-site pond and groundwater extraction and treatment.Therefore, long term monitoring of the on-site groundwater and theMississinewa River will be implemented as part of this interim remedy.This includes the installation of eight groundwater monitoring wellslocated along the river perimeter of the site.

7.3 Cost of the Interim Remedy

The cost for implementing the interim remedy is as follows:

Capital Cost $5,791,000Present Worth of Operationand Maintenance $1.081,000

Total Present Worth $6,872,000

Page 193: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

APPENDIX A

GROUNDKATER COLLECTION

Page 194: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

APPENDIX A

GRQUNDWATER COLLECTION

Introduction

Estimates of the groundwater flow condition present at theMarion/Bragg Landfill site and estimates of the quantity ofgroundwater which could be collected during implementation of selectedremedial alternatives are presented in this appendix. Thesecalculations have been derived through the use of data collectedduring the remedial investigation (RI) and through use of analyticalequations, geotechnical testing, and the Hydrologic Evaluation ofLandfill Performance (HELP) (Schroeder, Morgan, Walski, Gibson, 1984).

Existing Groundwater Flow Conditions

Groundwater remediation, addressed in detailed analysis ofalternatives, requires site-specific flow condition for the unconfinedaquifer system. Estimates of the groundwater flow conditions weregenerated from data collected during the Remedial Investigation (RI)at the Marion/Bragg Landfill. Utilizing standard calculations andutilizing RI data, the following values can be estimated: averageflow rates (Qa) (entering and leaving the site), hydraulic gradient(I), and transmissivity (T).

A groundwater contour map illustrating flow directions and water tableelevations (hydraulic head) at various locations throughout the siteis presented on pages 2-22, 2-23 and 2-25of the RI report. Thesecontour maps were generated by using water level measurements from theon-site and off-site ponds, the monitoring wells, and the MississinewaRiver.

The hydraulic gradient (I) was calculated by dividing the verticaldistance between two elevations by the horizontal distance between theelevations. For the Marion/Bragg site, the hydraulic gradient wasdetermined using the water level elevations of large off-site pond(793.89) and the groundwater monitoring well FIT-3 (785.65). Thedistance between the two groundwater elevations is 1,800 ft.

I - 793.89 - 785.651800

The hydraulic gradient (I) of the Marion/Bragg Landfill site wasdetermined to be approximately 4.58 x 10 ft/ft.

The hydraulic conductivity (K) was measured at seven monitoring welllocations and an average value of 1.215 x 10~ ft/min was derived.See Appendix F of the RI report for individual hydraulicconductivities _ _ _ ____

Page 195: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

The transmissivity (T) of the aquifer is equal to the hydraulicconductivity (K) multiplied by the saturated thickness (b) of theaquifer.

T - K x b .- 1.215 x-10 ft/min x 21.5 ft= 2.62 ft/min

Based on average values of the hydraulic conductivity and the averagesaturated thickness of 21.5 ft, the transmissivity of the aquifer isapproximately 2.62 ft /min.

The average flow rate O (entering and leaving the site) is determinedby the product of the hydraulic conductivity (K), the hydraulicgradient (I) and the area (A) (saturated thickness x width of aquiferperpendicular to groundwater flow direction).

Qa = KIA

O = (1.215 x Id"1 ft/min) (4.58 x lo"3 ft/ft) (21.5 ft x 1740 ft)(7.481 gal/eft)

= 155.7 gpm

Infiltration

Infiltration rates through the landfill were generated using theHydrologic Evaluation of Landfill Performance Model (HELP) (Schroeder,Morgan, Walski, Gibson, 1984). Infiltration rates were estimated forthree different cover materials; the existing silty sand cover at theMarion/Bragg T>rrif-m, a silty clay material which could achieve a10~ cm/sec permeability, and a RCRA multilayer cover. The thicknessof the covers were 24 inches, except the RCRA cover in additionincorporates a synthetic liner. Factors also taken into account wereprecipitation, runoff, evapo-transpiratian, and lateral drainage.

Estimates of the infiltration are summarized in Table A-l.Infiltration through the existing landfill surface was estimated to beoccurring at a rate of approximately 13.0241 in/yr. This would resultin infiltration ever the 45 acre site at an average rate ofapproximately 30.28 gpm. With a silty clay cover, the estimatedinfiltration rate is 4.1372 in/yr or 9.62 gpm over the 45 acrelandfill surface. A RCRA cap with a synthetic liner would result inapproximately no infiltration.

Water Bai ance

Table A-l shows the factors taken into account to calculate the sitewater balance. As in the previous section, three different types ofcover are used. The precipitation for Indianapolis, Indiana taken forthe year 1975 was used in this evaluation. Of the five years'precipitation data. (1974..through 1978) .provided by the HELP model,1975 had the highest precipitation. Factors that have been taken into

A-2

Page 196: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE A-l

COVER INFILTRATION MEASUREMENTS

ExistingSoilCover

SoilMaterial

Effective hydraulicconductivity, inches/yr

Thickness

Precipitation,inches/yr

Runoff, inches/yr

Evapo-transpiration,inches/yr

Lateral drainage,inches/yr

Infiltration, inches/yr 13.0241

Soil Moisture ContentStart of yr., inches/yr 1.59End of yr., inches/yr 1.73

Snow WaterStart of yr., inches/yr 2.30End of yr., inches/yr 4.40

Balance .00

ProposedIndianaSanitaryLandfill

Silty clay

4.1372

19.9819.99

2.34.4

.00

Multilayer(RCRA)

Multilayer

0.0495

10"

46.72

5.315

26.143

0.0011

24"

46.72

11.328

29.138

0

24"/liner

46.72

6.207

31.904

6.655

28.2528.10

2.304.40

.00

A-3

Page 197: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

account are runoff, evapo-transpiration, lateral drainage,infiltration, moisture content, and snow water. By adding the runoff,evapo-transpiration, lateral drainage and infiltration and subtractingthe difference between moisture content and snow water at thebeginning and end of the year, a water balance of 0.00 is achieved.

Extraction Wells

Extraction wells are used to control the hydraulic gradients andgroundwater flow directions. Extraction wells are also used to removegroundwater from the inside of slurry wall in order to create aninward gradient. The water table drawdown created by the extractionwells is dependent upon the hydraulic conductivity of the aquifer,saturated thickness of the aquifer, the pumping rates of individualwells and the spacing of the wells.

In order to determine the number of extraction wells needed toeffectively contain groundwater without a slurry wall at theMarion/Bragg Landfill site, the following calculations were completed.

3 3First, three typical pumping rates of 10 ft /mm, 20 ft /min, and 40ft /min, were chosen and drawdown around a typical well pumping ateach of these rates Was calculated. For each pumping rate, thedrawdown value at the pumping wall (S.) of 5 ft, 10 ft and 20 ft,respectively, were used. The Theim equation was used to calculatedrawdown:

Sl - S2 " Q in <f2>217 T (r

where S- is the drawdown at the well, ftS_ is the drawdown at a given distance r from the well, ftQ is the pumping rate of the well, cft/mln-T is the transmissivity of the aquifer, ft /minr, is the radius of the pumping well, ft (0.5 ft)

The assumptions of the Iheim equation are that there is infiniterecharge at the radius of influence of the well, the aquifer isconfined, and the well is fully penetrating. Although the aquifer atthe site is unconfined, the error introduced at lower pumping rates isinsignificant for the purpose of calculating drawdown.

The drawdowns around a typical well pumping at the three differentrates are listed below. A transmissivity of 2.62 ft /min for theupper aquifer was used.

A-4

Page 198: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Drawdown inPumping Well,

3 S (ft)Pump Rate (ft /min) Distance, r2 (ft) ________ Drawdown. S (ft)

10 0 5 -50 2.1100 1.7150 1.4100 1.3250 l.l

20 0 10 -50 4.2100 3.4150 2.8200 2.6250 2.2

40 0 20 -50 6.3100 5.1150 4.2200 3.8250 3.3

To verify a well can perform at the above pumping rates, the followingequation was used (J. Patrick Powers, 1981).

Qw = 0.035 Iw rw K1/2

Qw is the well capacity in gallons per minute, Iw is the wettedthickness of the screened interval in feet, rw is the radius of thewell in inches, and K is the hydraulic conductivity in gallons per dayper square foot. The wetted thickness of the screened interval can becalculated by subtracting the drawdown at the well from the averagesaturated thickness of the aquifer, 21-5 ft. The average hydraulicconductivity of the site is 1.22 x 10~ feet per minute or 1,314gallons per day per squarefoot.

If Qw is less than the chosen pumping rate Qp of the well, it will notbe able to perform at that rate. For each chosen rate, thecorresponding Qw is as follows:

Qp = 10 ft /min » 74.8 gal/minQw = .035 x (21.5 ft - 5 ft) x 6 inches x (1314

= 125.6 gal/min

Qw > Qp, a rate of 10 ft /min is feasible

Qp = 20 ft /min = 149.6 gal/minQw = .035 x (21.5 ft - 10 ft) x 6 inches x (1314

= 87.5 gal/min. _ _A-5

Page 199: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

Qw < Qp, a rate of 20 ft /min is not feasible

Qp = 40 ft3/raJJi = 299.2 gal/min

Qw = .035 x (21.5 ft - 20 ft) x 6 inches x (1314 gpd/ft2)1/2

= 11.4 gal/min

Qw < Qp, a rate of 40 ft /min is not feasible

Because 10 ft /min is the only feasible pumping rate, the remainingdiscussion concerns only using a pumping rate of 10 ft /min.

Groundwater flow velocities near a pumping well vary such that thevelocities increase closer to the well. Groundwater also has anatural flew velocity. (At the Marion/Bragg facility, the naturalflew is fran the south to the Mississinewa River.) At sons distancedowngradient from a pumping well, the pull back to the well is exactlyequal to the flew away from the well due to natural flow velocity.This distance is referred to as the "stagnation point" (Keely andTsang, 1983). The distance to the stagnation point can be calculatedand once determined, the boundary within which water is drawn to thewell is also known. The boundary is referred to as the "capturezone." The calculation used to estimate the capture zone is:

r = Q/27T bOe Vnwhere r = distance to edge of capture zone

Q = pumping rate of wellb = saturated thickness of the aquiferOe = effective porosity of the aquiferVn » natural velocity of groundwater flow

The natural flew velocity can be calculated as follows:

Vh = HOe

where K = hydraulic conductivityI = hydraulic gradientOe = effective porosity of the aquifer

At the Marion-jBragg Landfill site, the average hydraulic conductivityis 1.22 x 10~ ft/min, the average hydraulic gradient is 4.58 x 10~ft/'ft, and the effective porosity of the aquifer which consists ofmedium to coarse silty, gravelly sands, is estimated to be 25 percent.

Vh - fl.22 x IP"1 ft/mirO (4.58 x 10"3 ft/ft).25

Vh - 2.23 x 10~3 ft/min

By using the purtping rate of 10 ft /min.calculated in the previewssection, the capture zone boundary can also be calculated.

A-6

Page 200: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

At a pumping rate of 10 ft /min:

r = 10 cft/min

2 (21.5 ft) (.25) (2.23 x 10~3 ft/min)

r - 133 ft

Wells pumping at a rate of 10 ft3/min need to be spaced at a distanceof two times the capture zone radius, or about 260 feet, to captureall groundwater flowing into or out of the site. The locations of thewells are included in Figure A-l. -This results in a total of 25 wellsand a total pumping rate of 250 ft /min (1870 gal/min) . The pumpingwells located along the south and west side of the site are requiredto prevent groundwater from becoming contaminated. The pumping wells,located along the river edge, are required to capture contaminatedgroundwater prior to its discharge into the river. The purpose oflocating wells along the entire periphery of the site is to preventtreatanent of groundwater for an indefinite period of time bypreventing contact with the contaminated fill material.

Leakage Through Slurry Wall

The potential leakage through a slurry wall can be calculated forvarious hydraulic head conditions. It was assumed that the slurrywall has a 3-foot thickness and is 40 feet deep and a hydraulicconductivity of 1 x 10 cm/sec. Estimates of the leakage through theslurry wall were made using a form of Darcy's Law:

Q - KiA

i is the hydraulic gradient across the wall and A is the area of thewall (wall length equals 7,100 feet and depth equals 40 feet) . If thehead inside the wall is maintained approximately five feet below theoutside hydraulic head, then the hydraulic gradient across the wallwould be approximately 1.67 ft/ ft and leakage through the wall wouldbe 7 gpm.

Extraction wells would be installed on the site in conjunction withthe soil-bentonite slurry wall. The sole purpose of extraction wellinstallations would be to control the hydraulic gradient andgroundwater flow direction within the boundary of the slurry wall.

In calculating dewatering frj™pg and number of wells needed to dewaterthe site in a specified time interval, the following factors must beknown:

o Affected area 45 acres (land) and_15 acres (pond)o Hydraulic conductivity -3.28 x 10~ ft/seco Gradient across wall 5 ft/3 fto _ 25% porosity is assumedo And a 100 gpm maximum pumping rate

A-7

Page 201: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

oo

, U,' c'I '

Legend

——— Site Boundary

'///// Marion Paving Co., Inc.

SSwi Dobson Construction Co., Inc.

Private Residence

Extraction Well

n

'L '&

Figure A-l F.xt rac t ion Well Location - No Slurry Wall

Page 202: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

The volume of water to be removed from landfill roust first becalculated. It was determined that over 45 acres of landfill, 18.3millions gallons of water would exist and the pond has a volume of 25million gallons. The time required to remove the 43.3 million gallonsof water and reach equilibrium is 300 days. If the pond is backfilledand a 25% porosity is assumed, the volume of water to be removed from60 acre area would be 24.4 million gallons and approxijnately 170 dayswould be needed to dewater the site.

To maintain a uniform drawdown across the entire site would requirethe use of multiple wells at selected locations around the site tocreate the desired drawdown of five feet and would cumulatively pump atotal of up to 100 gal/min.

Average Linear Velocity of Groundwater Movement

The average linear velocity of groundwater flow from the southern partof the site to the northern part was estimated from the groundwatercontour maps reported in the Remedial Investigation report andhydraulic properties of the aquifer. Velocities can be estimatedusing the following equation:

V = KLn

n is the porosity of the aquifer, K is the hydraulic conductivity andi is the hydraulic gradient. From the groundwater contour map, thehydraulic gradient of the site was estimated:

i = 743.89 ft - 785.65 ft = 4.58 x 10~3 ft/ft1800 ft

Thus, the average linear velocity of groundwater movement from thesouthern portion of the site toward the north can be calculated using25% porosity and a hydraulic conductivity of 1.215 x 10 ft/min:

Jl X.25

V = 1.215 x 10"1 ft/min x 4.58 x lo"3 ft/ft

2.23 x 10~3 ft/min = 1,172.1 ft/yr

A-9

Page 203: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

REFERENCES

Keely and Tsang. 1983. Velocity Plots and Capture Zones of PumpingCenters for Groundwater Investigations. Groundwater, Vol. 21,No. 6.

Powers, J. Patrick. 1981. Construction Dewatering. John Wiley &Sons, New York.

Schroeder, Morgan, Walski, Gibson. 1984. The Hydrologic Evaluationof landfill Performance (HELP) Model. U.S. EPA, Cincinnati,Ohio.

A-10

Page 204: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

APPENDIX B

ESTIMATION OF FLOOD ELEVATIONIN MISSISSINEWA RIVER

Page 205: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

PRELIMINARY HYDRAULIC MODELING ON THE EFFECTS OF A BERMTHE MARION/BRAGG LANDFILL SITE

AROUND

INTRODUCTION:

The Marion/Bragg landfill site is situated on a meander of theMississinewa River approximately 500 feet upstream of thePennsylvania Street river crossing. A large portion of the siteresides in the 100-year floodplain. In order to prevent floodingof the site during this storm event, a berm is proposed forconstruction along the perimeter of the site. This preliminarystudy was made to estimate the effect of this berm on watersurface elevation (WSE) and velocity.

METHODOLOGY:

This evaluation was performed using the Army Corps of EngineersWater Surface Profile Model HEC-2. Detail of the site was ob-tained from a one foot interval topography map of theMarion/Bragg landfill site. Estimations of the 100-year flowsand water surface elevations at the Pennsylvania Street rivercrossing and the Pennsylvania Railroad track river crossing weresupplied by the Indiana Department of Natural Resources-Divisionof Water. These estimations were 31,500 cfs @ WSE 805.5 and30,500 cfs @ 813.0, respectively.

Cross-sections started at 0.5, which corresponds to the Pennsyl-vania Street river crossing, and were plotted roughly every 500feet going upstream until cross-section 10 which is just down-stream of the mouth of Lugar Creek. Cross-section 11 correspondsto the Pennsylvania Railroad track river crossing. Because thetopo map did not contain any detail for the channel bottom, atrapezoidal channel was assumed. Flows were interpolated at eachcross-section.

Under modified conditions, a berm was added along the perimeterof the site. The top of berm elevation increased from 808.5 to810.5 going upstream. A side slope of 3:1 was assumed.

RESULTS:

Two HEC-2 runs were made, modeling present and modified condi-tions. Table 1 presents a comparison of the results at thevarious cross-sections. The modeling shows that the installationof a berm should not significantly affect water surface elevationor velocity at any cross-section. The largest change in WSE andvelocity occurs at cross-section 6. The berm actually causes a0.06 foot decrease in WSE and a 0.25 feet per second increase invelocity.

B-l

Page 206: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

TABLE 1: MISSISSINEWA RIVER - HYDRAULIC MODELING RESULTS

PRESENT CONDITIONSCross- WSE VelocitySection (feet) (ft/sec)

0.5123467891011

805.50805.57805.36805.48805.82805.75805.87806.24806.57806.38808.76

6.626.738.908.706.788.088.126.976.367.678.58

805.50805.57805.36805.44805.80805.69805.82806.24806.60806.42808.78

WITH BERM DELTA DELTAWSE Velocity WSE VEL

(feet) (ft/sec)

6.62 0 06.73 0 08.90 0 08.86 -0.04 0.166.87 -0.02 0.098.33 -0.06 0.258.36 -0.05 0.247.07 0 0.106.34 0.03 -0.027.66 0.04 -0.018.57 0.02 -0.01

DISCUSSION:

It is important to remember that the accuracy of this study waslimited by the lack of channel definition but it is appropiatefor a relative comparison.

It is interesting to note that the addition of a berm willactually cause a decrease in WSE at cross-sections 3 through 7.This may seem confusing at first glance, but it is understandablewhen viewed in light of the site topography. The downstreamcorner of the site is a low lying area which becomes floodedduring the 100-year event. This area is not an effective flowarea and a pooling effect takes place. By building a berm, flowis confined to the channel area and the subsequent increase invelocity causes a net decrease in WSE. Because the flow in theriver is subcritical there are no downstream effects of thisincrease in velocity.

There are upstream effects as can be seen from the increase inWSE at cross-sections 9, 10, and 11. The largest increase is .04feet at cross-section 10. By the time the backwater gets to thePennsylvania Railroad track crossing the profile is within .02feet of recovery.

CONCLUSIONS:

Using a one-tenth foot change in water surface elevation asrepresentative of a significant change, in can be concluded thatthis preliminary study indicates that a berm around the perimeterof the Marion/Bragg landfill site will not significantly affectwater surface elevations during a 100-year storm event.

B-2

Page 207: PERFCJRMANCE OF RIMEDIAL RESPONSE200-FS1-RT-EYDU Public Comment Draft Feasibility Study for the Marion/Bragg Landfill Site Dear Mr. Yoshitani: Enclosed are seven copies and one original

W ' )i :J

"Oti.ti -

iiOS.t! -

805. (i -

805.!) -l

i'.Ob.Ii ••

wA 1 1 1 sni'.-i . - . . • ' i i n

Mr:!:.i:.;:.iNP.v-\ i i.'i |.

1

r•>•—.

I.)TEFT I.IPSTRI:AM riv-nt.i r-rn

w/o tjuiiii isrr-iwil l i l

'!:]