| |
PROPOSED PLAN FOR THE SOURCE CONTROL
RECORD OF DECISION AMENDMENT
AT
NEAL'S LANDFILL
Jan 18, 1999
Introduction
The United States Environmental Protection Agency (U.S. EPA)
is proposing to change the remedy for the Neal's Landfill site
near Bloomington, Indiana. The proposed remedy changes the original
remedy for Neal's Landfill, as described in the Enforcement Decision
Document (EDD), dated August 3, 1984, for a group of polychlorinated
biphenyls (PCBs) contaminated sites. The original remedy called
for, among other things, excavation of PCB contaminated soils
and materials from the site (source control measures), incineration
of those soils and materials in a permitted, TSCA-approved, dedicated,
municipal solid waste-fired incinerator, and water treatment.
This document is the source control Proposed Plan for the Record
of Decision Amendment, and describes and summarizes the recommended
changes to the original remedy at Neal's Landfill, as described
in the EDD. This Proposed Plan only addresses source control
measures, and future remedial decisions will be made regarding
water treatment at Neal's Landfill and sediment removal in Conard's
Branch and Richland Creek. The U.S. EPA is required to publish
this Proposed Plan and make it available for public review and
comment by Section 117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) of 1980, as
amended by the Superfund Amendments and Reauthorization Act (SARA)
of 1986. The changes described in this Proposed Plan are subject
to public review and comment. The information repository at the
Monroe Public Library, 303 E. Kirkwood, Bloomington should be
consulted for in-depth details on the development and evaluation
of the changes being proposed.
Public input on the proposed changes and the information that
support these changes is an important contribution to the cleanup
remedy selection process. Based upon new information or public
comments, U.S. EPA may modify the recommended changes described
here, or may select another alternative presented in the Proposed
Plan. The public comment period is from December 21, 1998 to
January 20, 1999. A public meeting to discuss the proposed changes
to the remedy at Neal's Landfill is scheduled for January 13,
1998, at 7:00 P.M., in the Monroe County Public Library, 303
East Kirkwood, Bloomington, Indiana.
Site Description and History
On January 4, 1983, the United States filed a civil action
against Westinghouse Electric Corporation, now known as CBS Corporation
(CBS), pursuant to Section 7003 of the Resource Conservation
and Recovery Act (RCRA) and Sections 104, 106, and 107 of CERCLA,
alleging an imminent and substantial endangerment due to improper
disposal of PCBs at two sites in the Bloomington area. During
the fall of 1983, CBS expressed its interest in negotiating a
settlement of that suit as well as a civil action filed by the
City of Bloomington for improper PCB disposal at two of the sites
owned by the City of Bloomington. After negotiations among CBS,
U.S. EPA, the City of Bloomington, Monroe County, and the Indiana
State Board of Health, (hereinafter collectively referred to
as the "Parties") a Consent Decree was signed in 1985
and subsequently entered by the court on August 22, 1985, for
the cleanup of Neal's Landfill, Neal's Dump, Lemon Lane Landfill,
Anderson Road Landfill, Bennett's Quarry, and the Winston Thomas
Wastewater Treatment Plant. The Consent Decree called for the
construction of a permitted, TSCA-approved, dedicated, municipal
solid waste fired incinerator to be used to destroy PCBs contaminated
soils and materials excavated from the six sites.
After entry of the Consent Decree, public opposition to the incinerator
rose. Applications for the necessary permits to design and build
the incinerator were submitted by CBS in 1991. Beginning in 1991,
the Indiana State Legislature passed several laws intended to
delay and block the implementation of the incineration remedy
required in the 1985 Consent Decree. In February 1994, the parties
agreed to jointly explore, under the Operating Principals, alternatives
to the incineration remedy for the six sites required under the
Consent Decree.
In part as a result of the conclusion that the incineration remedy
would not be implemented, the parties began adopting response
actions, other than incineration, for the sites covered by the
Consent Decree. Thus, on May 27, 1997, U.S. EPA issued an action
memorandum selecting a response action for certain of the PCB
contaminated units at Winston Thomas. The alternative response
action consists of excavation of PCB contaminated soil and sludge
and disposal in an appropriate, licensed landfill, as well as
decontamination and encapsulation on-site of certain concrete
digester tank walls.
On June 3, 1997, the United States lodged with the U.S. District
Court the first amendment to the Consent Decree, memorializing
the agreement of the parties to the Consent Decree to the response
action selected in the action memorandum. On August 18, 1997,
the Court entered the first amendment, thus substituting the
response action selected in the action memorandum for certain
of the units at Winston Thomas for the incineration remedy. Further
amendments for other Consent Decree sites will be submitted to
the Court as appropriate.
On January 30, 1998, U.S. EPA issued an action memorandum for
the clean-up of the interim storage facility at Winston Thomas,
which stored PCB contaminated soil and sediment from other Bloomington,
Indiana, sites. CBS implemented the selected response action
upon approval by all of the parties, and with the knowledge of
the court, of a work plan.
On May 12, 1998, U.S. EPA issued an action memorandum for the
completion of the clean-up of Winston Thomas. The units addressed
include the abandoned lagoon, trickling filter and the tertiary
lagoon. The clean-up of the tertiary lagoon, which covers 17
acres and is filled with water, involves dredging of PCB contaminated
sludge. All material excavated from the tertiary lagoon and the
abandoned lagoon will be landfilled at a licensed off-site facility.
On May 18, 1998, the United States lodged with the U.S. District
Court the stipulation changing the terms of the Consent Decree,
and memorializing the agreement of the parties to the Consent
Decree to the response action selected in the action memorandum.
The changes provide for the clean-up of the largest and most
complicated units at Winston Thomas - the abandoned lagoon and
the tertiary lagoon. On June 8, 1998, the Court entered the stipulation,
thus substituting the response action selected in the action
memorandum for certain of the units at Winston Thomas for the
incineration remedy.
Having already adopted a response action other than incineration
for Winston Thomas, and because the incinerator still has not
been constructed and is unavailable to address the PCB contaminated
soils and materials, the parties explored alternatives to incineration
for the Consent Decree sites. In addition, in November 1997,
Federal Judge Hugh Dillin issued a judicial order stating that
the six Consent Decree sites must be remediated by December 1999
and assigned Magistrate Judge Kennard Foster to oversee the progress
of the parties toward meeting the December 1999 deadline.
In short, the amendments to the remedial decisions for the Consent
Decree sites, which includes Neal's Landfill, are driven in part
by the need for an alternative to the incineration remedy and
in part by the consensus of the Parties that an alternative is
necessary. After discussions with the governmental parties and
CBS Corporation, the U.S. EPA issued a Proposed Plan addressing
two of the Consent Decree sites (Neal's Dump and Bennett's Quarry)
for public comment. The public comments were considered and were
addressed in the Responsiveness Summary. On October 16, 1998,
U.S. EPA issued a Record of Decision Amendment adopting new remedial
actions for Neal's Dump and Bennett's Quarry in which Neal's Dump
will be remediated to residential PCB cleanup standards and Bennett's
Dump will be remediated to industrial PCB cleanup standards.
This Proposed Plan for Neal's Landfill is a result of the further
discussions among the parties as an alternative to the incineration
remedy.
Neal's Landfill was operated as a sanitary landfill from 1950
to 1972. In 1966 and 1967, PCB filled capacitors and PCB contaminated
rags, sawdust and filter clay were disposed of at the landfill.
It has been estimated that between 10,000, and as many as 40,000
capacitors may have been disposed of at the site, and there was
extensive on-site salvaging of capacitors for the metal components.
The current size of the landfill is approximately 18 acres. Mr.
Ray Neal, the previous owner and operator of the landfill, hauled
PCB contaminated capacitors and materials to Neal's Landfill
under contract from CBS. Mr. Ray Neal owned the site until 1977
and from 1977 to 1980, the site was owned by Mr. Richard Neal.
The site is now owned by the Taylor Farm Limited Liability Corporation.
Since 1981, numerous field inspections and investigations have
been conducted at Neal's Landfill by both U.S. EPA and CBS. Sampling
included sediment/surface water sampling in Conard's Branch and
Richland Creek, springs located near the landfill, soils on-site,
residential wells in the vicinity of the landfill, monitoring
wells on-site and off-site, air monitoring upwind and downwind
of the landfill, and vegetation and fish sampling in Conard's
Branch and Richland Creek. The most recent sampling occurred
in March and April 1998, when 105 borings were placed within
Neal's Landfill. A total of 271 samples were analyzed for PCBs
and values ranged from non-detect to 34,796 parts per million
(ppm). Figure 1 shows the boring locations within Neal's Landfill
and Table 1 shows the locations where PCBs were greater than
500 ppm.
* See Neals Landfill Sampling. Report from Tetra Tech, dated
November 30, 1998 for complete results from the March/April 1998
sampling event.
Interim remedial measures were completed at Neal's Landfill
by CBS in 1984 based upon a Stipulation and Order of preliminary
injunction. The measures included the following:
* Removal of 122 exposed capacitors and associated contaminated
soil for off-site disposal. A total of 80 capacitors at 8 locations
were reburied at the site during the interim remedial measures.
* Upgrading the cover over the refuse area, including grading
and re-vegetating the surface of the landfill.
* Fencing the perimeter of the site.
* Performing sediment sampling, aerial photographic interpretations,
and water balance calculations.
* Placement of sediment filter fences.
* Construction of diversion ditches.
* Sampling of monitor wells, springs, seeps, and streams both
on-site and off-site. Included in the monitoring were selected
residential wells within a 5,000-foot radius of the site.
* Capture and treatment of the combined flows from South Spring,
North Spring and Southwest Seep up to 1.0 cubic feet per second
(approximately 448 gallons per minute) to an effluent standard
of 1 part per billion PCBs.
* Installation of erosion control fencing.
* Posting of warning signs about PCB contamination along Conard's
Branch and Richland Creek which are bordered by the Conard's
farm.
* Removal of sediments from Conard's Branch from Neal's Landfill
to Richland Creek and within Richland Creek from 25 feet upstream
of its confluence with Conard's Branch to a point 200 feet downstream
from the confluence.
* Sampling of sediments after remediation and establishing a
baseline for future monitoring.
* Establishment of a vegetative cover over all disturbed areas.
|
|
