Final Report

Completion of the Remedial Action for the Neal s Dumpsite
Spencer, Owen County, Indiana.
March 17, 1999

Geophysical Survey for Buried Materials
Map

1.0 INTRODUCTION

This document constitutes the final report for the Completion of the Remedial Action for the Neal s Dumpsite in Spencer, Owen County, Indiana. Figure I illustrates the location of this site in Owen County. The work described in this report was performed from August through November 1998.

This report includes a descriptive narrative of work performed, along with associated figures, tables. and photographs. Additional records associated with this project, including air monitoring results. weekly progress reports, laboratory certificates of analysis chain-of-custody documents, etc.. are available for review and future reference at CBS Corporation in Pittsburgh, Pennsylvania.

2.0 SITE BACKGROUND

2.1 GENERAL

Neal's Dump was operated between 1967 and 1972 as a disposal site for household and industrial waste materials. From 1968 to 1972. waste materials from the former Westinghouse plant were disposed of at Neal s Dump by contract waste haulers. The waste materials included whole capacitors (some drained and some undrained). capacitor parts. filter aids, and sawdust. During this time period. an estimated 10.000 capacitors were sent out of the Westinghouse plant for disposal. The waste pile at the Neal's Dump site was estimated to comprise approximately 75 percent capacitor-related waste and 25 percent residential waste.

On August 18, 1983, a Stipulation and Order'' was issued for the site by the U.S. EnvironmentalProtection Agency (USEPA). Pursuant to this order. pre-interim measures were initiated at the site.including the installation of an 8-ft-high security fence, removal of 114 visible capacitors, installation of a soil cap, and installation of erosion controls. These pre-interim measures were completed in December 1983.

Neal's Dump was listed on the National Priorities List (NPL) in October 1984 as part of the 244-siteProposed Update # 2 On August 27. 1985. CBS (formerly Westinghouse Electric Corporation) entered into an agreement (Consent Decree) with the USEPA, State of Indiana Department of Environmental Management (IDEM). City of Bloomington. and Monroe County to achieve certain cleanup criteria for this and other sites.

2.2 SITE DESCRIPTION

Neal's Dump is located in southeast Owen County. approximately 4.2 miles southwest of Spencer.Indiana. and approximately 15 miles northwest of Bloomington, Indiana. Figure 1 shows the general location of the site. The dump site is located near the crest of a hill, which slopes generally to the west toward the flood plain of the West Fork of the White River Basin.

Residential property is located adjacent to the dump and includes three single-family homes. The nearest residence is located approximately 50 ft southwest of the perimeter. The half-acre site is secured at the perimeter by an 8-ft-high chain-link fence with barbed wire around the top. Along the perimeter are some large trees, particularly at the north end of the site. Figure 2 shows the general features of the site.

2.3 PREVIOUS SITE INVESTIGATIONS

Beginning in 1976. a series of site-related investigations were conducted to characterize the Neal'sDump disposal area. These investigations entailed sampling and analysis of various environmental media including leachate, groundwater, soil, and sediment.

On January 21 and 22, 1976. the USEPA and the Indiana State Board of Health (ISBH) collected leachate and soil samples to characterize the site conditions at Neal's Dump. On June 8, 1976, the ISBH collected soil samples near an exposed capacitor. One soil sample was found to contain polychlorinatedbiphenyls (PCBs) at a concentration of 12,500 ppm. The USEPA collected soil samples around other exposed capacitors on November 4. 1980, and found PCB concentrations as high as 88 ppm.

Groundwater investigations were first initiated in October 1981 by the USEPA with the sampling of a residential well near the site. This sample, taken from the Leslie Barritt residence well, was non-detect for PCB compounds. From September 1982 through May 1983, Ecology and Environment. Inc..conducted several sampling events for the USEPA at the site as part of the Field Investigation Team (FIT) project. In addition to the samples collected by the USEPA, O'Brien & Gere Engineers. under direction from CBS. initiated a groundwater sampling and analysis program at the site in August 1982. During this investigation, a sample collected from a shallow. downgradient monitoring well (MOO-I S) exhibited a PCB concentration of 31 ug/L. Another sample collected in April 1983 from MW-5S showed a concentration of 73 ug/L.

Semi-annual groundwater monitoring of eight selected wells was conducted from May 1987 to May1991 in accordance with the Neal's Dump Onsite Groundwater Monitoring Plan dated May 1986. Four monitoring wells (IS, 2S. SS' 6B) monitored the surficial sand and silt layer. Four monitoring wells ( I D,2D. 4D, 5D) monitored the sand/silt layer immediately below the till layer. The results of that monitoring showed PCBs present immediately downgradient of the site in the surficial unit and a minor detection of PCBs in well 5D in the second sand silt layer. In May 1991. PCBs were detected in all four wells in the second sand/silt layer. at which time monthly monitoring was initiatedand continued until November 1991. Subsequently, wells 3D. B 1. and B2 were added to the monitoring network, and semi-annual sampling was resumed. Semi-annual monitoring continued until May 1998. Results showed the continued presence of PCBs immediately downgradient of the site in the surficial unit (wells I S and 5S) and sporadic low-level detections in the second sand/silt layer (D-series wells).

In addition to the previously described sampling activities, non-invasive geophysical studies were performed to estimate the area and extent of buried metallic objects. Ecology and Environment, Inc..under direction from the USEPA, conducted the first geophysical survey at the site in June 1982 using a magnetometer to determine the probable location(s) of buried capacitors at the site. The same firm conducted an expanded magnetometer survey in August 1982 to provide a more complete picture ofpossible burial locations. Under direction from CBS, O'Brien & Gere conducted an independentmagnetometer survey at the site in December 1982. By combining these surveys, an electromagnetic anomaly area was identified and roughly delineated in the Consent Decree documents (Exhibit 8. Metes and Bounds of the Site). This electromagnetic anomaly area was identified as the probable limit of the buried material at the site. Based on the geophysical studies, a surface area of about one-half acre was identified to contain various sorts of buried metal debris. Approximately 14,000 cu yd of waste was calculated to be buried at s Dump based on these data and the testimony of the contract waste haulers.

2.4 SITE GEOLOGY

The site geology consists of five units representing Pleistocene to Recent age alluvial, lacustrine, and glacial deposition overlaying Mississippian limestone bedrock. The uppermost unconsolidated unit is described as a heterosgenous mixture varying in total thickness from I 1 to 31.5 ft. A silty clay till unit,which is approximately 17 to 25 ft thick, underlies the uppermost unit. This till unit serves as an aquitard (aleaky confining bed) to the sand unit beneath it. This sand unit is described as a fine to coarse sand a gravelly sand, or a silty sand depending on the location in which it is encountered. Beneath the sand is a 0 to 5-ft-thick silt layer. A clay unit, which is possibly lacustrine in origin, underlies the silt layer and ranges in thickness from 2 to 21 ft.Limestone bedrock lies below the clay unit.

Groundwater occurs in three hydrostratigraphic units beneath the site. A localized, unconfined, perched condition exists in the uppermost sandy silt unit 12 to 15 ft below grade, and a confined system exists in the deeper sand unit 37 to 45 ft below grade. These two systems are separated by low-permeability tillmaterial. A third, separate hydrostratigraphic unit was found in a sand layer encountered immediately above the limestone bedrock west of the site. The residential wells nearest the site are developed in the underlying bedrock. Residential wells between the site and the White River are developed in the river alluvium.

The Eads and White residential wells obtain their groundwater from the limestone bedrock that is 100 ft or more below the site. A layer of lacustrine clay and upward gradients in the limestone bedrock isolate this aquifer from the site. Both residential wells were sampled semi-annually from July 1991 to May1998. No PCBs were detected in either well at a detection limit of 0.1 ppb. In the sample from the White well taken on June 12, 1996, Heritage lab reported a 0.1 1 ppb detection, which was later determined tobe a quality assurance/quality control lab error. Two subsequent samples of the White well were taken pursuant to Consent Decree requirements on July 2 and July 19, 1996. Both samples were non-detectfor PCBs with a 0.1 ppb detection limit.

Groundwater flow in the upper sandy silt unit is interpreted to be toward the northwest to the northern unnamed drainage area. This flow direction mimics the local surface topography. Regional flow in the deeper sand aquifer is believed to be toward the west to the White River, which is interpreted to be the discharge boundary for this unit. The limestone beneath the site is geologically isolated by the confining lacustrine clay layer and hydraulically isolated by the upward gradients as indicated on the reported driller's log water levels.

During the removal activity, the upper sand unit within the site disposal area was removed in some areas down to the till layer. The resulting void was backfilled with local soils of a silty/sand nature.

3.0 REMEDIATION PLANNING

3.1 WORK PLAN APPROVAL

A Work Plan, submitted to the government parties on September 15, 1998, was prepared to address removal of buried capacitors and remediation of PCB-impacted soils at Neal s Dump. This plan was developed to address the requirements of the Statement of Work (SOW) for the remedial action at Neal's Dump. The Work Plan was approved by the Consent Decree parties prior to the start of excavation activities at the site. Health and safety, air monitoring, post excavation sampling, and transportation and disposal were conducted in accordance with the approved Work Plan.

3.2 SURVEYING

During the initial site preparation activities, a 25-ft by 25-ft grid system with North and East coordinates was established across the site. This system was used as the basis for identifying pre- and post-excavation sample locations and excavation areas.

Prior to excavation. the relative elevations of the corners and center of each grid were also determined. Elevations were measured relative to monitoring well MOO-ID, located at the northwest corner of grid C3.

3.3

GEOPHYSICAL SURvEY

On August 31. 1998. PSARA Technologies and Geosphere, Inc., conducted for CBS a geophysical survey across the site to further define the limits of buried metal first identified in the 1982 survey (seeSection 2.3). The survey consisted of a combination of electromagnetic (EM) and magnetometer techniques. The EM survey was accomplished using an EM3 1 instrument by collecting readings along I 5 east-west lines across the site with 5-ft spacings between lines. Readings were taken at 2.5-ft intervals along each line. A fluxgate magnetometer was used to collect magnetic data along the same east-west gridlines. The magnetic survey focused primarilyon suspected target areas identified during the EM3 I survey. The results of this geophysical survey helped to refine the limits of buried metal beneath the site. Figure 3 shows the limits of the buried metal area based on the 1998 geophysical survey. as well as the approximate extent of surface metal observed during this survey. The geophysics report prepared by Geosphere is provided in Appendix A.

3.4 PRE-EXCAVATION DELINEATION SAMPLING

Following the geophysical survey, grid-based sampling was conducted outside the newly defined perimeter of the buried metal area to confirm the boundaries of the area to be remediated. Samples were collected at 0- to 6-in., 6- to 1 2-in.. 12- to 1 8-in and 18- to 24-in. depth intervals at four locations inthe perimeter grids by manually driving a split-spoon sampler to the desired depth. Equal portions from each of the four sample locations were composited to create a representative grid sample for each depth interval. These composite samples were then submitted to an approved laboratory and analyzed for PCBs. Table I summarizes the results of this delineation sampling. If a grid was found to containPCBs at a concentration exceeding 10 ppm, then the next grid outward from the anomaly was sampled in the manner described previously. Figure 4 shows the sample locations and PCB analytical results.Based on the results of the delineation sampling, four grids (A5, A6, B6, and D7) around the perimeter of the buried metal area were added to the remediation scope of work.

3.5 MONITORING WELL ABANDONMENT

Prior to the start of excavation activities at Neal's Dump, Bowser-Morner. Inc., was contracted by CBS to abandon existing onsite monitoring wells in the areas to be excavated and in the access areas where the wells would hinder movement or placement of equipment. Final selection of the wells to be abandoned was determined in the field in accordance with the Work Plan and SOW. The selected wells included shallow monitoring wells (MW-IS, MW-2S, MW-3S, MW-5S, and MW-6B). USEPA wells (EPA-I.EPA-2. EPA-3. EPA-4, EPA-5A, EPA-5B EPA-SC, EPA-6C, EPA-7B. and EPA-7C), and test piezometers (TP-1, TP-2, TP-3. and TP-4) that were no longer included in the monitoring plan. Well MW-5D was later added to the original list of wells to be abandoned after it was damaged during site preparation activities. On September 24, 1998, 20monitoring wells were abandoned consistent with the following approved procedure. First. the well casing was filled with a slurry of bentonite and Portland cement grout via a tremie pipe. The well casing was then cut I ft below the ground surface. Finally, the well was capped with a concrete pad reinforced with wire mesh. The concrete pad was mounded to allow for positive drainage away from the well.

Copies of the driller's well abandonment logs are provided in Appendix B.

4.0 SUMMARY OF REMEDIATION ACTIVITIES

All remediation activities were performed by Heritage Environmental Services, LLC, under the direction of CBS. Project photographs showing remediation and sampling activities are presented in Appendix C.

1

4.1 SITE PREPARATION

4.1.1 General

Prior to beginning remediation activities, support facilities were arranged for the site. Support facilities included two office trailers; water, electric, and phone services; and sanitary facilities to accommodate allof the workers and site visitors. In addition, a portable truck scale was installed along the haul road located north of the buried metal area to weigh outgoing loads of material. Figure 2 shows the generallay out of the site after site preparation activities were completed.

4.1.2 Clearing and Grubbing

Clearing and grubbing activities at Neal s Dump were conducted in two phases. Initially, a localc ontractor was hired to clear the site of vegetation so that delineation sampling could be conducted. The second stage of clearing was conducted by the remediation contractor to remove any other larger treesand stumps that would hinder mobilization of the facilities and equipment. Smaller brush and debris outside of the excavation area were chipped and left on site. where as larger logs and debris were removed from the site and disposed of at a special waste landfill (Southside Landfill) in Indianapolis, Indiana.

4.1.3 Facility Access Roads

Vehicle access to the site was improved by constructing a new gravel entrance road from Old Morrow Road around the north side of the excavation area (see Figure 2). Construction of the new road was conducted with the approval of the resident adjacent to the site as well as the owner of the site. The new access road was graded and properly lined with erosion controls, including silt fences and berms. to minimize any impact on the surrounding properties. Vehicles exited the site via a pre-existing gravel driveway on the west site of the site.

4.1.4 Site Security

In 1983, an 8-ft-high chain-link security fence was installed around the perimeter of the site. As part of site preparation activities, the area contained by this fence was extended and a second gate added to allow room for temporary office trailers. In addition to the primary security provided by this structure. aguard service (Parsec Services. Inc.) was hired to monitor the premises while remedial activities were taking place. The site was locked and secured during periods of inactivity.

4.1.5 Decontamination Pad

To limit the amount of cross-contamination of soils outside the area of the excavation, a 5-ft by 12-ft decontamination pad with bermed sides was installed in grid D4. This pad served as a corridor into andout of the exclusion zone for personnel decontamination and as a staging area for sampling activities. Water that accumulated on this pad was pumped into a holding tank and treated. A sump pump was provided to transfer water that accumulated on the pad to a holding tank for treatment.

4.1.6 Water Collection and Treatment

A temporary water treatment system was set up on site to handle and treat rinse water from decontamination activities as well as storm water and perched water from excavated grids. Sump pumps were provided to transfer water to a storage vessel, which served as an equalization tank and settling basin. From this basin. water was pumped to a 22,000-gal holding tank until sufficient water wascollected for treatment. The batch treatment system consisted of a bag filter system followed by primaryand secondary carbon filtration and a temporary holding tank. Effluent from the treatment system was stored in the temporary holding tank pending sampling and analysis to ensure compliance with discharge limits.

4.2 REMOVAL ACTIVITIES

Mobilization to the site began on September 22. 1998. Actual excavation activities began onSeptember 29. 1998. following the close of the public comment period on September 23. Removal activities were completed on November 17, 1998. In accordance with the SOW, pre-certification inspections were performed separately by CBS, IDEM, and the USEPA upon completion of all removal activities.

4 2 1 Removal of Capacitors

Approximately 2430 capacitors were removed during remediation of the site. Capacitors were removedusing a track excavator fitted with a slotted bucket, which was designed to sift excess soils. The largest concentration of capacitors was found to be in grids b5 C5, B6, and C6. Grids E5 and E6 also contained a large cache of capacitors. All capacitors were loaded directly into lined and tarped DOT-approved rolloff containers. A total of 10 rolloffs containing an estimated 250,000 lb of capacitors were transported to the Chem Waste TSCA Incineration facility in Port Arthur, Texas, for destruction. Table 2 summarizes the amount of material transported offsite on a daily basis.

4.2.2 Soil Removal

Contaminated soil was removed from each grid using a track excavator and placed in a soilstockpile/material loading area. The stockpile was located within the exclusion zone but adjacent to the haul road. The material from the stockpile was then loaded into lined transport trucks using a second track excavator stationed within the material loading area. During loading, the visqueen liners that were placed in the transport trucks were draped over the sides of the trailer. Prior to exiting the site, the filled trailers were covered with tarps, weighed decontaminated (tires and rails). and placarded. All material was removed and disposed of at the Wayne Disposal Chemical Waste Landfill in Belleville, Michigan.

A total of 17 full or partial grids were excavated within the approximate limits of the waste. Grids were initially excavated to the depth determined by the pre-excavation sampling effort or until all buried capacitors and metal debris within a grid had been removed. After each grid was excavated to the final depth confirmation sampling was performed and the relative elevation of the center of the excavated grid was determined. Figure 5 shows the relative final elevation for eachgrid. A total of 297 truck loads containing approximately 7250 tons of excavated material were transported to the landfill for disposal. Table 3 summarizes the amount of material transported offsiteon a daily basis. Figures 6. 7. and 8 show cross-sections of the excavated area.

4.3 SOIL BORING INSTALLS TION

Following the excavation of grids C5 and B5, visual evidence of residual PCB oil was observed in the verification samples from these grids. To determine whether PCB oil had migrated into perimeter grids'CBS directed the installation of 15 soil borings to determine the lateral extent of impact (see Figure 9).Continuous split-spoon samples were collected during the installation of these borings. Soil borings were installed to a depth of approximately 20 ft or until 3 ft of the lower confining unit (a gray silty clay) had been recovered in the split-spoon samples.

Initially, the samples from each boring were collected at 2-ft intervals and archived. Once groundwater was encountered in the borings, samples were collected at 1-ft intervals. These samples were submitted to the laboratory for analysis of PCBs. The initial 2-ft interval samples were sent to the laboratory only ifthe 1-ft samples contained PCB concentrations exceeding the CBS-directed cleanup criterion of 5.0ppm for soils less than 7 ft below the surface. Figure 9 shows the analytical results for each of the soilborings. Table 4 summarizes the results of the soil boring investigation for the Neal s Dump site.

One of the borings, installed in the center of grid C4, exhibited PCB concentrations to a depth of 17 ftbelow grade. This grid was ultimately excavated to a depth of 20 ft below grade based upon verification sample results. All of the other samples collected from borings installed during this effort were within the cleanup criteria established for this project.

4.4 WATER COLLECTION AND TREATMENT

A temporary water treatment system was set up on site to handle and treat rinse water from decontamination activities as well as storm water and perched water from excavated grids. The

IDEM established a discharge limit of 0., ppb PCBs for the temporary treatment system. Following receipt of the analytical results. the effluent was discharged at a controlled flow rate of <15 8pm to an unnamed tributary of the White River located northwest of the site. The discharge was controlled using aflow meter to prevent streambed erosion. Approximately 22,000 gal of wastewater was treated and discharged to the intermittent creek northwest of the site during remediation of Neal's Dump.

4.5 SITE RESTORATION/BACKFILLING

All excavation areas were backfilled with clay and topsoil and rough graded to promote positive drainage toward the intermittent creek northwest of the site. Backfill was obtained from two local properties with permission from the owners: Mrs. Mary White's front yard, and Mr. Coleman White's farm. Samples of the backfill material were collected for analysis prior to use. The analytical result sidentified no PCBs or pesticide compounds in the clay backfill or topsoil material used at the site. Disturbed areas were hydroseeded with a fast-growing native grass after topsoil placement. grading, and compaction.

Since excavation was completed in the early winter months. some of the final site restoration activities will not take place until early spring 1999. In the interim, erosion controls have been established until theseareas can be revegetated. Figure 10 presents the layout of the restored site and the final surface elevations as of December 15, 1998.

5.0 SUMMARY OF SAMPLING ACTIVITIES

All sampling activities were conducted by PSARA Technologies, Inc., in accordance with the approved Field Sampling and Analysis Plan, dated September 10, 1998.

5.1 POST-EXCAVATION SOIL SAMPLING

Post-excavation verification sampling was performed consistent with the procedures described in the approved Field Sampling and Analysis Plan. After all of the soil had been removed to the prescribed depth, each grid was visually subdivided into four smaller 12.5-ft by 12.5-ft subgrids. A sample was collected from the 0- to 6-in. depth interval in the approximate center of each subgrid and homogenized. Equal portions from each of the four subgrid samples were composited to create a representative grid sample. These composite samples were analyzed for PCBs. If the laboratory result from a grid sample showed a PCB concentration in excess of 10 ppm. an additional 1- to 3-ft lift of soil was removed and the grid was resampled. This procedure continued until all of the delineated grids showed a PCB concentration below 10 ppm. Figure 11 presents the final post-excavation verification results for Neal'sDump. Table 5 summarizes the post-excavation soil analytical results.

The arithmetic average of all the final composite PCB results was calculated on a daily basis. The calculated average remaining PCB concentration for all grids after excavation activities were completed was 0.8 ppm, which was below the requirements of the SOW. The final PCB concentrations for each gridand the daily arithmetic average calculations are presented in Table 6.

5.2 WAS TEWATER SAMPLING

Accumulated wastewater from decontamination operations, stormwater runoff. and perched water was treated in a temporary onsite wastewater treatment system operated by Heritage. Effluent samples werecollected and analyzed in accordance with the Field Sampling and Analysis

Plan prior to discharge. Table 7 presents the effluent sample results. All samples were below the IDEM treated water discharge limit of 0.3 ppb PCBs.

5.3 GROUNDWA TER MONITORING

Prior to the beginning of remediation and every 30 days thereafter until remediation activities were completed, CBS sampled the Neal's Dump monitoring wells (MW-1D, MW-2D, MW-3D, and MW-4D) and the residential well water at two residences (Winkles and Eads) in the vicinity of the site forPCBs. Samples were collected in accordance with the Field Sampling and Analysis Plan. All purge water and decontamination fluids were containerized and transferred to the onsite wastewater treatment systemfor treatment and disposal in accordance with Section 4.4. Purging and sampling activities were recordedon a Groundwater sampling log for each well. A PCB concentration of 0.1 1 ,ug/L was detected in the sample collected from monitoring well MOO-1 D on October 23, 1998. All other Groundwater samples collected during the course of the remediation were below the detection limit of 0.10 ug/L. Table 7 summarizes the ground water analytical results.

6.0 PERIMETER AIR MONITORING

Perimeter air sampling was performed to ensure that excavation and materials handling operations did notresult in excessive airborne PCB emissions from the site. Air samples were collected using modified polyurethane foam (PUF) samplers in accordance with USEPA Method T-04 and the site-specific AirMonitoring Plan (AMP) dated September 10, 1998. Air samples were analyzed to determine the concentrations of PCBs at the boundaries of the Neal's Dump site during excavation operations. Perimeter air monitoring was conducted by PSARA.

Air monitoring stations were located at three locations along the south, southeast, and southwest perimeters of the site as described in the AMP. Sampling was conducted only on days when material handling or excavation took place. One sample representing the prevailing down-wind direction wasselected each day for analysis at an offsite laboratory. A meteorological station was installed and operated at the site in order to determine prevailing wind direction and weather information

CBS collected and analyzed a total of 50 perimeter air samples during the remediation project of 38 different days. The average concentration was 268 ng/m3. The action level for perimeter airborne PCB concentrations was 1000 ng/m3 for this site. Three of the perimeter samplers, plus one overnight sample.exceeded this action level. The highest perimeter air sample result showed PCBs at a concentration of 2200 ng/m3 on October 15, 1998. All three elevated sample results occurred at the south monitoring station. which was placed within 15 feet of the actual excavation.

CBS implemented a number of measures in response to the elevated perimeter results. These included the use of a water spray during truck loading and material handling operations and the application of tarps to cover all stockpiles and open excavations. Using the tarps, CBS was able to keep all of the excavation covered overnight and during any periods of low activity at the site.

Table 8 presents the perimeter air sample results for the Neal's Dump site.