Third Five-Year Review Report Conrail Rail Yard …The Conrail Rail Yard Site is located adjacent to...

EPA Region 5 Records Ctr.

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329556

Five-Year Review Report Pursuant to CERCLA

Third Five-Year Review Report Conrail Rail Yard Superfund Site

City of Elkhart, Indiana

Prepared by:

U.S. Environmental Protection Agency Region 5

Chicago, Illinois

In conjunction with:

Indiana Department of Environmental Management Indianapolis, Indiana

Approved By:

R ard C. Karl, DIrector Superfund Division

[This page intentionally left blank.]

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Table of Contents

Section fage List of Acronyms 5 Executive Summary 7 Five-Year Review Summary Form 9

I. Introduction.......................................................................................... II

II. Site Cbronology 12

III. Background......... 12 Physical Characteristics......................................................................... 12 Land and Resource Use 13 History of Contamination '" .. , '" 13 Initial Response 14 Basis for Taking Action '" , 14

IV. Remedial Actions 16 Remedy Selection................................................... 16 Remedy Implementation 17 Institutional Controls ,..... 18 Operation and Maintenance (O&M)............................................................... 21 Costs and Operation....................................... 22

V. Progress Since tbe Last Five-Year Review 23

VI. Five-Year Review Process '" , 23 Administrative Components........................................................................ 23 Community Notification and Involvement 24 I)ocument Review '" '" '" 24 DataRevie\\' 24 Site Inspection....................................................................................... 24

VII. Tecbnical Assessment......................................................... 24 Question A: Is the remedy functioning as intended by the

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the

Question C: Has any other information come to light that could

decision documents?.................................................................... 24

time of the remedy still valid?......... 25

call into question the protectiveness of the remedy? 25 Technical Assessment Summary.................................................................. 25

VIII. Issues 26

IX. Recommendations and Follow-up Actions 26

X. Protectiveness Statement 27

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XI. Next Review 28

Tables Table I - Chronology of Site Events............................................................... 12 Table 2 - Summary of Institutional Controls 19 Table 3 - Approximate O&M Costs from 2004 through 2007 22 Table 4 - Approximate Costs for O&M Activities for 2008 22 Table 5 - Issues 26 Table 6 - Recommendations and Follow-Up Actions 26

Attachments A.ttachment I - Figures Attachment 2 - Public Notice about Five-Year Review Attachment 3 - Documents Reviewed

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List of Acronyms AOC

ARAR

BGS

CCI..

CD

CERCLA

CFR

COPC

COPEC

em/sec

DNAPL

GAC

GMCS

GCW

gpm

ICs

IDEM

MCL

msl

NCP

NPL

O&M

OU

PAH

PCB

Administrative Order on Consent

Applicable or Relevant and Appropriate Requirement

below ground surface

carbon tetrachloride

Consent Decree

Comprehensive Environmental Response, Compensation, and Liability Act

Code of Federal Regulations

Chern ical of potential concern

Chemical of potential ecological concern

Centimeters per second

Dense non-aqueous phase liquid

granulated activated carbon

Ground water Migration and Control System

ground water circulation well

Gallons per minute

Institutional Controls

Indiana Department of Environmental Management

Maximum Contaminant Level

Mean sea level

National Contingency Plan

National Priorities List

Operation and Maintenance

Operable Unit

Polyaromatic hydrocarbon

Polychlorinated biphenyl

5

PCP

ppb

ppm

PRP

RA

RCE

RCRA

RD

ROD

SVOC

TCE

TDS

TI

TOC

TRV

VAO

VSACE

VSEPA

VVIUE

VOC

Pentachlorophenol

parts per billion

part per mill ion

Potentially Responsible Party

Remedial Action

Restrictive Covenant and Easement

Resource Conservation and Recovery Act

Remedial Design

Record of Decision

Semi-volatile Organic Compound

Trichloroethylene

Total dissolved solids

Technical Impracticability

Total organic carbon

Toxicity Reference Values

Unilateral Administrative Order

United States Army Corps of Engineers

United States Environmental Protection Agency

Unlimited UselUnrestricted Exposure

Volatile Organic Compound

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EXECUTIVE SUMMARY

The Conrail Rail Yard Site is located adjacent to and within the southwestern city limits of Elkhart, Indiana. The Site, which includes the rail yard, the drag strip, and other areas of contamination, encompasses roughly 2500 acres. The rail yard (Rail Yard Area) is an electronically controlled hump yard which serves as a classification distribution yard for freight cars. The Osceola Dragway (the Drag Strip Area) is a commercial drag racing facility. Additionally, there are several light industrial properties located within the study area as well as several residential areas, comprised mainly of single-family homes (see Figure I). The Conrail Rail Yard Site consists oftrichloroethylene (TCE) and carbon tetrachloride (CCI4) soil contamination areas at the Conrail Rail Yard and a CCI4 soil contamination area identified at the Drag Strip Area near the Vistula Avenue residential area. Two ground water contamination areas are present. One TCE and CCI4 ground water contamination plume, the County Road I plume. emanates from the rail yard and trends northwest to the Vistula Avenue residential area. A second, TCE contaminant plume, the LaRue Street plume, emanates from the eastern portion ofthe Rail Yard Area and flows north to the La Rue Street residential area (see Figure 2).

An interim Record of Decision (ROD) for remedial action at the Site to perform initial hookups of residences and businesses to alternative water supply was signed in June 1991. The final remedy selected in the Record of Decision signed in September 1994, involved: 1) the provision of municipal water to residents in the plume areas, 2) soil vapor extraction of volatile organic compounds (VOCs)in the TCE source area, and air sparging and soil vapor extraction in the CCI4 source area, 3) monitoring, and if necessary, vapor abatement actions in building floors and basements of areas north of the rail yard, 4) ground water extraction and treatment to achieve ground water standards in the contaminant plumes, 5) ground water and air monitoring, 6) well abandonment, 7) institutional controls such as access and deed restrictions to limit the potential for human exposure to contamination and restrictions to prohibit disturbance of the remedy, and 8) additional remediation of contaminated soil source areas that may be identified during further investigation.

Based on the results of the remedial design (RD) for the Site, in September 2000, the United States Environmental Protection Agency (USEPA) signed a ROD amendment modifying the remedy due tothe technical impracticability of cleaning up the two dense non-aqueous phase liquid (DNAPL) source areas on the rail yard property. Instead, the remedy was changed to hydraulic containment of the DNAPL source areas and natural gradient flushing of the dissolved portion of that plume. No change was made to the remedy for the Drag Strip Area.

An Interim Remedial action (RA) to hook up impacted residents to municipal water was completed in June 1997. Rail Yard Area soil sampling resulted in no samples that exceeded applicable cleanup levels in the area previously found to have high contaminant concentrations so no soil remediation fin that area was required by USEPA. A pilot test for the remedy, including the installation of one ground water circulating well (GCW) in the Drag Strip Area and three ground water extraction wells and treatment plant in the Rail Yard Area was constructed in 2004 and has been operational since that time. In addition, due to the discovery ofCCG vapor intrusion into the homes of some residents of the Vistula Avenue/Drag Strip Area, these residents were provided with vapor abatement units between 2000 and 2002.

Based on an evaluation by USEPA perfonned in March 2009, the ground water remedy is not operating as intended, and some ground water contamination is escaping the intended capture system. Ground water clean up goals have not yet been met in the area of the plume where the ground water remediation system is operating. The pilot remedy is addressing ecological exposure by serving to reduct~ the mass loading of contaminants to the St. Joseph River by removing and treating contaminated ground water. The potential for human exposure is being addressed by the provision of municipal water, residential

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vapor mitigation units, and institutional controls (ICs) that limit access to the rail yard. The owner of the Rail Yard, Conrail, has recorded a notice of the groundwater contamination with the county recorder, but to date, no other deed notices or restrictions have been implemented. Therefore the remedy is protective in the short term and not protective in the long-term. Long-term protectiveness requires complete and effective capture and remediation of the ground water contamination plume and compliance with effective ICs. The USEPA will work with the PRPs to continue operation of the current ground water remedial system and improve contaminated ground water capture. Compliance with effective ICs will be ensured by implementing, maintaining, monitoring, and enforcing effective ICs as well as maintaining the site remedy components. An IC work plan, developed by the PRPs to be approved by USEPA, will include any additional work or findings and then implemented.

This is the third five-year review report for the Conrail Rail Yard Site.

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Five-Year Review Summary Form

Sill I[)I '\ 1IIIl.\ IIO\;

Site name (from WasteLAN): Conrail Rail Yard

EPA 10 (from WasteLAN): IND000715490

•

SIILSI \ll'S

NPL status: Xo Final 0 Deleted 0 Other (specify) Proposed

Remediation status (choose all that apply): 0 Under Construction Xo Operating 0 Complete

Multiple OUs?* XJ:J YES 0 NO IConstruction completion date: 7/12/2004

Has site been put into reuse? 0 YES Xo NO ,

RI \'11 \\ SI \Il S

Lead agency: Xo EPA 0 State 0 Tribe 0 Other Federal Agency

Author name: Timothv Drexler

Author title: Remedial Proiect Manaqer IAuthor affiliation: USEPA

Review period: ** 8/15/08 to 6/15/09

Date(s) of site inspection: 10103/2008

Type of review: XD Post-SARA o Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL StatefTribe-lead o Regional Discretion

Review number: o 1 (first) 0 2 (second) Xo 3 (third) o Other (specify)

Triggering action: o Actual RA Onsite Construction at au #__ DActual RA Start at OU#2-o Construction Completion Xo Previous Five-Year Review Report o Other (specify)

Triggering action date (from WasteLAN): 9/27/2004

Due date (five years after triggering action date): 9/27/2009 * ["aU" refers to operable Unit.] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN,]

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Five-Year Review Summary Form, cont'd.

Issues:

The following issues have been identified at the Conrail Site during this Five Year Review: • There is incomplete capture by the extraction well system of the DNAPL plume in the Rail

Yard Area. • There is incomplete capture by the pilot GCW of the ground water plume in the Drag Strip

Area. • The source areas in the Drag Strip Area are not characterized completely. • ICs are not fully implemented. ICs must be implemented, monitored, maintained, and

enforced.

Recommendations and Follow-up Actions:

• Modification of the extraction system at the Rail Yard Area is needed to achieve complete capture of the DNAPL plume.

• Modification/expansion of the pilot GCW treatment system at the Drag Strip Area is needed to capture significant quantities of site contaminants. Performance metrics must be established.

• Additional soil investigation is needed in the Drag Strip Area to completely delineate source areas.

• The draft IC Workplan must be revised by the PRPs and an IC Plan must be generated to: 1) document IC activities conducted by the PRPs, 2) plan for necessary corrective measures, 3) map contaminated areas with the type of IC needed for each area, and 4) add necessary activities to ensure implementation and long-term stewardship of ICs by the PRPs.

Protectiveness Statement(s):

The Conrail remedial action is protective in the short term and not protective in the long term. Although the ground water remedy is not operating as intended, and ground water contamination is escaping the intended capture system, the remedy, as it is being implemented to-date, is addressing ecological exposure by serving to reduce the mass loading of contaminants to the St. Joseph River by removing and treating contaminated ground water. The potential for human exposure is being addressed by the provision of municipal water to residents, the installation of vapor mitigation units, and vapor monitoring in residents adjacent to impacted areas. Because short term human health and ecological exposures are being controlled, the remedy is protective in the short term.

Additionally, all required institutional controls have not yet been implemented. Compliance with effective ICs will be ensured by implementing, maintaining, monitoring, and enforcing effective ICs, as well as maintaining the site remedy components. Long-term protectiveness requires complete and effective capture and remediation of the ground water contamination plume and compliance with effective ICs.

Date of last Regional review of Human Exposure Indicator (from WasteLAN): 4/07/2009 Human Exposure Survey Status (from WasteLAN): Current Human Exposures Controlled Date of last Regional review of Ground water Migration Indicator (from WasteLAN): 4/07/2009 Ground water Migration Survey Status (from WasteLAN): Not Under Control Ready for Reuse Determination Status (from WasteLAN): No

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CONRAIL RAIL YARD SUPERFUND SITE ELKHART COUNTY, INDIANA FIVE-YEAR REVIEW REPORT

I. INTRODUCTION

Authority and Purpose The purpose of a five-year review is to determ ine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in fiveyear review reports. In addition, five-year review reports identitY issues found during the review, if any, and identitY recommendations to address those issues.

The United States Environmental Protection Agency (USEPA) is preparing this five-year review report pursuant to CERCLA § 121 and the National Contingency Plan (NCP). CERCLA §121 states:

[ijithe President selects a remedial action that results in any hazardous substances. pollutants. or contaminants remaining at the site. the President shall review such remedial action no less often than eachfive years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition. ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [lO-IJ or [l06J. the President shall take or require such action. The President shall report to the Congress a list offacilitiesfor which such review is required. the results ofall such reviews. and any actions taken as a result ofsuch reviews.

USEPA interpreted this requirement further in the NCP. 40 CFR §300.430(t)(4)(ii) states:

filfremedial action is selected that results in hazardous substances. pollutants. or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure. the lead agenc.v shall revie»' such action no less often than every five J'ears after the initiation ofthe selected remedial action.

USEPA, Region 5, conducted the five-year review of the remedy being implemented at the Conrail Rail Yard Superfund Site (the Site) in the City of Elkhart, Elkhart County, Indiana. This review was primarily conducted by Tim Drexler, USEPA Region 5 Remedial Project Manager (RPM), Kevin Adler, and Kevin Herron, Indiana Department of Environmental Management (IDEM), for the period from October 2008 through June 2009. This report documents the results of the review. The final report will be placed in the USEPA site files and at the local repositories for the Conrail Rail Yard Site at the Elkhart Public Library Reference Desk, 300 S. Second Street, Elkhart, Indiana. This is the third five-year review for the Conrail Rail Yard Site.

The triggering action for this statutory review is the completion of the second five-year review on September 27, 2004. This five-year review is required due to the fact that hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure.

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II. CHRONOLOGY

T hi a e 1.Chrono o~ 0 fS'Ife Events

EVENT DATE

Rail Yard operations begin 1956

USEPA documents trichloroethylene (TCE) and carbon tetrachloride (CCI4) in residential wells

downgradient of Conrail facility

June 1986

Conrail Rail Yard Site added to National Priorities List (NPL)

August 30, 1990

Interim Record of Decision (ROD) issued including: alternate water supply to 400 residents, ground

water extraction/treatment, and monitoring.

June 28, 1991

Remedial Investigations Complete April 1994

ROD issued including: alternate water supply to 1,125 additional residents, additional source investigation, soil remediation, ground water

extraction/treatment, and monitoring

Septem ber 9, 1994

USEPA issues Unilateral Administrative Order to Potentially Responsible Parties (PRPs) for portion of

remedial action

May 15, 1995

Consent Decree between USEPA and PRPs signed for remedial action

November 10, 1997

First Five Year Review Septem ber 23, 1999

USEPA issues ROD Amendment based on Technical Impracticability (TI) waiver request from PRPs

September 27,2000

PRP RA complete June 28, 2004

Preliminary Close-Out Report July 12,2004

Second Five Year Review September 27,2004

Deletion from the National Priorities List Estimated date: 2031

III. BACKGROUND

Physical Characteristics Conrail Rail Yard is located adjacent to and within the southwestern city limits of Elkhart, Indiana (see Figure I). The Site includes the rail yard, a 675 acre facility bounded to the north by US33 (Franklin Street), on the east by State Route 19, to the south by Mishawaka Road, and to the west by State Route 219. The total Site includes certain areas of contamination that extend in two directions, northeast and

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northwest, from the Conrail Rail Yard and encompasses roughly 2500 acres that are generally topographically flat (see Figure I).

The rail yard is an electronically controlled hump yard which serves as a classification distribution yard for freight cars. Rail car repair, engine cleaning, and diesel refueling facilities are also locakd at the yard. The rail yard began operations in 1956 as part of the New York Central Railroad, and continued operations as a subsidiary of the Penn Central Transportation Company until 1976. From 1976 to 1999, Conrail operated the rail yard. In 1999, Norfolk Southern Corporation took over operation of the rail yard.

The major surface water bodies in the vicinity of the Site are the S1. Joseph River and Baugo Bay. The S1. Joseph River flows westward and is located a little over a mile north of the Conrail Site. Baugo Bay flows north into the 51. Joseph River and is located immediately west of the area. Crawford Ditch originates at the Site and flows intermittently to the St. Joseph River. Floodplain and wetland areas exist along both the S1. Joseph River and Baugo Bay.

The Site consists primarily of unstratified sand and gravel outwash deposits with discrete silt and clay lenses or masses to an approximate depth of 150 feet below ground surface (bgs). The bedrock consists of dense, essentially horizontal, Mississippian and Devonian age shales. The depth to the water table varies from 3 to 20 feet bgs. The vertical hydraulic gradient shows a generally downward gradient with ground water recharge in the Rail Yard and ground water discharge to the St. Joseph River.

Land and Resource Use

There are several light industrial properties located within the area to the north and northwest of the Rail Yard as well as numerous light industries to the south and east. Within the area there are also several residential areas, comprised mainly of single-family homes. Approximately 3,500 people live within about I 1/2 miles of the Site.

Future land use for the Conrail Rail Yard Site and surrounding areas are anticipated to be similar to current land use.

History of Contamination

The Rail Yard facility began operations in 1956. From 1961 to 1968 there were numerous citizen complaints filed with state and local authorities regarding oil discharges from the Rail Yard to the S1. Joseph River. Based on interviews with ex-employees of the Rail Yard and other sources, between 1966 and 1969, a tank car containing CCI~ collided with another car during humping operations at the Rail Yard causing the release of approximately 16,000 gallons of CCI4•

In 1976, operations at the Rail Yard were transferred to the Consolidated Rail Corporation (Conrail). From 1976 to the present, spills and releases of oil, diesel fuel, hydrochloric acid, caustic soda, and various petroleum-related substances have occurred there. Reports also indicate that a track-deaning substance and engine degreasers were used and disposed of at the Rail Yard.

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Initial Response

In June 1986, a resident on County Road I,just north ofUS33, reported to USEPA that his residential well contained elevated levels of volatile organic compounds. A USEPA sample of that well revealed TCE at 800 parts per billion (ppb) and CCI4 at 485 ppb. USEPA conducted additional residential ground water sampling of the area in July 1986. The sampling program included the County Road and LaRue Street areas, located to the northwest and northeast of the Rail Yard respectively. Samples were also taken at residences in the Yistula Avenue area, northwest of the County Road 1 area (Figure 2). Out of the 88 residential wells sampled, USEPA discovered 63 ground water samples with detectable levels of TCE. CCI4, or both. TCE concentrations were as high as 4,870 ppb and CCI4 concentrations were as high as 6,680 ppb. The USEPA maximum contaminant level (MCL) for TCE and CCI4 in drinking water is 5 ppb.

Bottled water was provided to residents whose wells were affected by Conrail Site-related contamination. A portion of the residents in the LaRue Street area were later connected to a water-main extension from the City of Elkhart. Many of the residences, however, had carbon filtration units installed to ensure a safe drinking water supply until municipal water was provided. IDEM also periodically sampled residential wells in the area to monitor the migration of site-related contaminants.

USEPA sampling of the rail yard was conducted in July and August 1986. The results of analyses revealed soil concentrations ofTCE as high as 5,850 ppb and soil concentrations ofCCI4 as high as 117 ppb. On August 30, 1990, the Site was placed on the USEPA National Priorities List.

USEPA conducted a Remedial Investigation/Feasibility Study, followed by an Interim Record of Decision (ROD) in June 1991. A final ROD for the Site was issued by USEPA on September 9,1994 which included: I) institutional actions, which included ground water and air monitoring, restrictive covenants. access restrictions, and deed restrictions, 2) extension of municipal water supply to affected residents based on ground water monitoring, 3) source investigation and soil remediation of contamination source areas using in situ treatment technologies, 4) treatment of ground water contamination by extraction, treatment, and discharge, 5) soil vapor extraction of volatile organic compounds (YOCs) in the TCE source areas and air sparging and soil vapor extraction in the CCI4

contaminant plumes. and 6) air monitoring in basements and buildings and, based on those r~:sults, vapor abatement.

Basis for Taking Action

Based on the results of the RL a baseline risk assessment was performed to evaluate the risks posed to human health and the environment by Site contamination following USEPA and State of Indiana guidance. The risk assessment determined that Site contamination does not pose significant ,~cological

risk. but does pose significant human health risks. The risk assessment identified and focused on the following source areas:

• Ground water and subsurface soil beneath the Rail Yard. • Ground water in the County Road I plume area, extending north and west from the central

portion of the Rail Yard, affecting County Road I, Charles Avenue, and Yistula Strel~t residential areas.

• Ground water in the LaRue Street plume area, extending north from the eastern portion of the Rail Yard. affecting the LaRue Street residential area.

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From these source areas, the risk assessment identified the following exposure pathways that appear to have the greatest potential to produce adverse human health effects: direct contact with contaminated soil or ground water (dermal contact or accidental ingestion) and inhalation of contaminants volatilized from the soil or ground water. This risk assessment quantitatively evaluated two groups of receptors. adult workers and visitors exposed to existing Site conditions and local residents in potentially affected areas. The risks to Site workers and visitors consist of inhaling contaminants volatilized from ground water and subsurface soils, and possible direct contact during any excavation activity in contaminated areas.

The risks to the residents in the areas ofthe County Road I plume and LaRue Street plume were from ingestion, dermal exposure, and vapor inhalation of ground water used for domestic purposes, and inhalation of compounds volatilized from the ground water and infiltrating basements or other enclosed areas. It was assumed that there will be no change in the use ofthe Site in the foreseeable future, and no new residences constructed any closer to the Site than already exist.

The risk assessment identified the following volatile organic compounds (VOCs) as contaminants of potential concern:

Acetone TCE 2-butanone toluene CCl.t vinyl chloride chloroform xylenes ch loromethane 1, I, I-trichloroethane I.I-dichloroethane 1,1,2-trichloroethane 1.I-dichloroethene Tetrach loroethene 1,2-dichloroethene Methyl isobutyl ketone Ethylbenzene Methylene chloride

Of these contaminants of potential concern, it was determined that CCI4, chloroform, I, I-dichloroethene, 1.2-dichloroethene, TCE, and vinyl chloride contribute significantly to human health risks. Both categories of human health risks, carcinogenic and non-carcinogenic, were evaluated.

According to the risk assessment, contaminants in three areas of the Site posed carcinogenic risks that exceeded the 1 x 10-6 level established by USEPA as a point of departure for determining protective cleanup levels. These areas were the Rail Yard Area, the County Road 1 plume area, and the LaRue Street plume area.

Ecological impacts from Site-related contaminants were also evaluated. The objective oftht: ecological assessment was to screen the surface waters and sediments of nearby aquatic and wetland habitats for Site-related contaminants to estimate the potential risk that those contaminants pose to the natural environment. Results of the environmental assessment indicate that few organic compounds were detected above detection limits in St. Joseph River. Baugo Bay, or nearby ponds. Some singular detections of Site-related chemicals were found, but there is no suggestion of pervasive sediment contamination that would likely contribute a significant risk to aquatic life.

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IV. REMEDIAL ACTIONS

Remedy Selection

Based on the findings discussed above, the following primary remedial action objectives were developed for the Interim Remedial Action at the Conrail Site:

• Providing a safe pennanent drinking water supply to residents who are potentially at risk; and

• Preventing exposure to the contaminated groundwater.

The secondary objectives for implementing the Interim Remedial Action for the Conrail Site include:

• Minimizing further expansion of contamination in the aquifer and further migration of the contaminants to surface water (i.e., St. Joseph River and Baugo Bay); and

• Reducing contaminant concentrations in the ground water within the study area.

The Interim Remedial Action selected for the Site in a June 28, 1991 ROD included connecting 505 residents to the municipal water supply and extraction and treatment of the County Road 1 contaminant plume and deed restrictions to restrict the future use of the Rail Yard and a restrictive covenant to prohibit disturbance of components of the remedy.

The following remedial action objectives were developed for the Final Remedial Action:

• Minimizing the potential for human exposure to contaminants by eliminating significant exposure routes and/or reducing contaminant concentrations

• Minimizing further degradation of the ground water beneath the Conrail facility • Minimizing further degradation of the ground water downgradient from the Conrail

facility (outside of the rail yard property boundaries), and • Restoring the ground water to its original use as a drinking water source

The Final Remedial Action, described in the September 9, 1994 ROD, included: 1) connections to the municipal water supply for an additional approximately 650 residents, 2) extraction, treatment. and discharge of contaminated ground water focusing on "hot spots", 3) investigation, and if necessary, remediation of solvent vapors in residences resulting from Site contamination, 4) air sparging of the deeper DNAPL contamination areas of the rail yard,S) excavation of contaminated soils from a small area on the rail yard, and 6) institutional controls including deed restrictions and access restrictions to limit the potential for human exposure to contamination and restrictions to prohibit disturbance of the remedy.

The objective of the subsequent ROD Amendment was to waive the remedial action objt~ctives

within an area of the Conrail Rail Yard and, instead, require hydraulic containment for these source areas. A September 27,2000 ROD Amendment replaced the extraction/treatment and air sparging remedy with: I) a hydraulic containment system for the DNAPL source areas 0111 the rail yard, 2) natural gradient flushing of the dissolved portions of the contaminant plumes, and 3) active remediation of the CCI~ ground water contamination in the Vistula/Drag Strip plume area, with extraction and treatment retained as a contingency remedy.

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A pre-design study completed by the PRPs on June 19,2002 identified the presence of two source areas ofCCI4 at the Drag Strip Area. Based on that discovery, on November 25,2003. USEPA approved a work plan from the PRPs for the installation of a ground water circulation well (GCW) as a pilot to test its efficacy at capturing a substantial quantity ofcontaminant mass. Data from the completed pilot test program would be used to design a full-scale remedy and to identify performance metrics for its operation.

A Final Design Report from the PRPs was accepted by USEPA on July 14,2003, that outlined the installation of extraction wells at the rail yard in phases. The first phase was the construction of a treatment plant and the installation of three extraction wells. After an operation and monitoring period, used to assess system capture performance, the scope of the second phase of extraction well installation was to be defined. Up to two additional extraction wells wen~ outlined in the report, as needed to achieve performance goals of the system.

Remed)' Implementation

An interim ROD for remedial action at the Site to perform initial hookups of residences and businesses to alternative water supply was signed in June 1991. Subsequently, USEPA issued a Unilateral Administrative Order (UAO) to Conrail and Penn Central, the potentially responsible parties (PRPs) on July 7, 1992, to perform that work. Approximately 450 residences were hooked up to the Elkhart municipal water supply between August 1994 and February 1996. Residential wells were abandoned at all residences that received a hookup. A ROD for the final remedial action was signed by USEPA on September 9, 1994. On May 15, 1995, USEPA issued a second UAO to the PRPs to hook up the remainder ofthe homes and businesses in the impacted area to municipal water. By June 16, 1997 an additional 675 residences were then connected to municipal water and their wells abandoned. A quarterly ground water monitoring program was also established.

On November 10, 1997, USEPA entered into a Consent Decree (CD) for Remedial Design/Remedial Action (RD/RA) encompassing the remainder of the work to be performed under the final ROD. That work included: I) further sampling of a small area of the Rail Yard to identify and, if needed, remediate soil contaminant hotspots, 2) investigate DNAPL source areas at the Rail Yard and Drag Strip Areas. 3) sample and, if necessary, clean up VOC vapors in residential basements, and 4) perform an ecological study of the St. Joseph River to determine if contaminants were adversely impacting aquatic life. Also in 1997, Conrail recorded a notice of contamination for the approximately 544 acres of the Site that it owned.

The Rail Yard soil sampling indicated that there were no samples that exceeded applicable ckanup levels in the area previously found to have a high concentration of TCE. Therefore, USEPA determined that no additional soil cleanup was warranted. The investigation ofthe Rail Yard Area also confirmed previous conclusions that two CCI4 DNAPL ground water plume areas exist.

Investigations ofthe Drag Strip Area indicated that a source of CCI4 contamination exists in the southwest portion of the Drag Strip property. Vapor sampling in basements near the Drag Strip Area resulted in the identification of CCI4 vapor intrusion in nine residences at levels that exceeded the Sitespecific health-based concentration. Soil gas depressurization units were then installed in these nine homes between 2000 and 2002.

Several )ears of benthic macroinvertebrate study data regarding the potential ecological risks from solvents entering the S1. Joseph River via Site ground water contaminant plumes indicate that Site contaminants do not pose any measurable ecological risks.

u.s. Environmental Protection Agency 17

On February 3, 2000, the PRPs submitted a Petition for a Technical Impracticability (TI) Waiver and Request for Remedy Reconsideration requesting USEPA to amend the 1994 ROD to change the ground water remedy. The PRPs stated that it was not technically feasible to clean up the two DNAPL plumes in the Rail Yard property within a reasonable timeframe. Instead, the PRPs petitioned that the source areas at the Rail Yard be hydraulically contained and that the dissolved portion of the plume be cleaned lip through natural gradient flushing. The PRP investigation of ground water contamination in the Drag Strip Area, however, identified another source of CCI4 ground water contamination that would likely extend the time needed for remedial action levels to be achieved by natural gradient flushing. The TI Waiver concluded that the Drag Strip source area would need to be remediated. USEPA granted the TI Waiver via the execution of a ROD Amendment on September 27, 2000, and, as required by the CD, the PRPs were required to address the CCI4 contamination at the Vistula/Drag Strip Area.

Subsequently, a ground water containment system was designed for the Rail Yard consisting of five ground water extraction wells and a ground water treatment plant. Three extraction wells and the ground water treatment plant have been installed. As a part of the rail yard system plan, after an operation and monitoring period, the need for the two additional extraction wells was to be evaluated. The Rail Yard remedy, as outlined in a "Final Design Report" dated July 14,2003, has been in operation since June 2004.

A pilot GCW system was designed for the Drag Strip Area and installed to remediate the CCI4 plume. After a period of operation, based on system performance, the installation of a second GWC system would be optional. The pilot Drag Strip remedy, as outlined in a "Drag Strip GCW Pilot", dated November 25,2003, has been in operation since October 2004.

Monitoring Wells and Residential Wells

Periodic sampling of residential wells and the installation of a system of monitoring wells, to determine the effectiveness of the source containment and natural gradient flushing, were identified as components of the remedy in the ROD Amendment.

Performance Measurements for Remedy

The goal of the remedy for the Rail Yard Area, as identified in the 2000 ROD Amendment, is the operation of the ground water treatment system until the contaminant plumes achieve MCLs for the Site contaminants of concern. The performance measurement for the Rail Yard Area, as identified in a July 14, 2003 Final Design Report, is a weight-of-evidence analysis of: 1) potentiometric surface maps, 2) a comparison of concentration trends in upgradient and downgradient wells, and 3) ground water modeling. Trends were to be analyzed annually for the first three years, and then every five years afterward.

Performance measurements for the Drag Strip Area have not yet been developed. According to the November 25,2003 work plan for the pilot GCW system, performance measures for the Drag Strip Area are to be developed when the full-scale remedy is implemented. Now that the pilot period is complete, the perfornlance measures will be developed.

Institutional Controls

Institutional controls (ICs) are required to ensure the protectiveness of the remedy. ICs are nonengineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is

U.S. Environmental Protection Agency 18

required to assure long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UUfUE).

In order to limit the potential for human exposure to contaminated media, the 1994 ROD identified ICs to be implemented at the Site. These ICs included access and deed restrictions to limit the potential for human exposure to contamination and restrictions to prohibit disturbance of the remedy. Institutional controls at the Conrail Rail Yard Site are summarized below:

Table 2 Summary of Institutional Controls Media, Engineered

Controls, and Areas that do not Support UU/UE Based

on Current Conditions

IC Objective and

Restrictions

Title of IC Instrument Implemented (or Planned)

Required as part of the remedy?

Prohibit

Ground water plume underlying entire Site approximately 2500 acres includes Rail Yard Area and Drag Strip Area

exposure to groundwater contam ination; limit future use of contaminated

City ordinance (planned) Yes or

equivalent IC

groundwater.

Remedy components on Rail Yard Area and Drag Strip Area

Prohibit disturbance of remedy; limit access, future use of contaminated I areas and limit II

exposure !

Soil contamination on Rail Limit access Yard Area and exposure

Environmental Restrictive Covenant or similar effective proprietary control (planned)

Pursuant to 1997 Consent Decree, PRPs filed a Notice of

Restrictive Covenants. An Environmental Restrictive

Yes or equivalent IC

Yes or equivalent IC

i Covenant or similar effective proprietary control (planned). I

Environmental Restrictive Soil contamination on Drag Limit access

I Yes or

covenant or similar effectiveStrip Area and exposure equivalent IC

proprietary control (planned)

Groundwater contamination on Rail Yard Area

1-

Groundwater contamination on Drag Strip Area

December 10, 1997 Deed Notice Limit access of groundwater contamination and prohibit on Rail Yard Record; Yes or use and limit Environmental Restrictive equivalent IC exposure covenant or similar effective

---::-~~----+-----""p-r=_oLpr_,i,_et-a~ry'--c-on-t_:_ro-1_('-Lp_la-,n_n,_e--'-dL)--IL--------11 Limit access Environmental Restrictive and prohibit covenant or similar effective Yes or use and limit I proprietary or governmental equivalent IC

: exposure I control (planned)


* Maps which depict the areas of the Site which do not allow for UUIUE will be developed as part of the IC plan and IC implementation.

Status of ICs and Follow-up Actions Required

InitiallC evaluation activities have detennined that required ICs have not been fully implemented at the Site. Pursuant to the 1997 Consent Decree, the PRPs filed a Notice of Restrictive Covenants for the Rail Yard Area only.

In a letter dated April 22,2008, USEPA requested that the PRPs develop a work plan to address the required ICs at the Site as discussed in the Consent Decree, the 1994 ROD, and the 2000 ROD Amendment and to amend the O&M Plan to monitor the ICs and ensure that they remain in place. The areas specifically addressed included the Conrail Rail Yard, the Osceola Drag Strip property, and the neighborhood northwest of the Rail Yard in Elkhart and St. Joseph Counties. USEPA requested: I) a restrictive covenant and easement (RCE) for the Rail Yard Area to prohibit interference with the ground \\'ater containment equipment and prohibit ground water usage, 2) an RCE for the Drag Strip Area to prohibit interference with the ground water recirculation wells and to prohibit the use of ground \\'ater and disturbance of the soil, and 3) establishment of an ordinance in Elkhart and St. Joseph Counties to prohibit the use of ground water and the installation of ground water wells within boundaries highlighted in a map attachment to the letter.

On June 6, 2008, at the request ofthe USEPA, the PRPs submitted a draft Institutional Control Work Plan that included the commitment to record an RCE to prohibit interference with ground water containment equipment and to prohibit the use of ground water. The PRPs stated that a Restrictive Covenant was transmitted to the owner of the Osceola Drag Strip property on many occasions and todate, the owner has declined to sign the Restrictive Covenant. The Drag Strip owner does, however, continue to provide access to the property for the purpose of operation and maintenance of th{: ground water circulation well and well testing. The PRPs further state that they will continue to pursue recording a Restrictive Covenant on the Drag Strip property, to the extent practicable, proposing to collect e\ idence of title and ownership of the Drag Strip property as well as a list of current lil~ns and encumbrances and copies of subrogation agreements for any encumbrances. With regard to establishing ordinances to prohibit use of ground water and the installation of ground water wells for residences in St. Joseph and Elkhart Counties, the PRPs proposed to prepare a functional description of the area where ground water use should be restricted. As part of the draft IC Work Plan, the PRPs should work with the County to ensure that effective ordinances are enacted.

Also, in the draft IC Work Plan submitted to USEPA, the PRPs have proposed instituting an IC monitoring plan by modifying the Operations and Maintenance (O&M) Plan. The draft IC Work Plan proposes to amend the O&M Plan to include the following: I) an annual review of any changt:s in ownership of the Rail Yard and Drag Strip Areas, 2) an annual evaluation of the progress of recording the Rail Yard RCE and Drag Strip restrictive covenant, 3) an evaluation of the progress toward establishing ground water use ordinances in Elkhart and St. Joseph Counties, and 4) annual notification to USEPA in a letter report and certification that ICs are in place and remain effective. This is discussed further under Long-Tenn Stewardship.

USEPA will ensure that the PRPs implement an RCE for the Rail Yard Area and that they pursue an RCE for the Drag Strip Area. USEPA will help facilitate the development of city or county ordinances


to prevent ground water well drilling in the plume areas. An IC work plan was submitted by the PRPs to address the additional IC activities including evaluation of effectiveness of existing ICs, exploring whether additionallCs are needed and planning for long-term stewardship. This plan is under review by USEPA with input from IDEM. USEPA, in consultation with the state, will require revisions to the IC Work Plan if additionallC corrective measures and additionallC activities are necessary to ensure that effective ICs are implemented. monita-ed, maintained and enforced. Also as a part of the IC Plan and IC implementation, maps will be generated which depict the current conditions of the Site and areas which do not allow for Uu/UE.

Current Compliance

Even though the ICs have not been fully implemented, there are currently no known uses of the Site which would be considered inconsistent with the goals to be achieved by the ICs. Based on inspections and interviews with the various Site owners and PRPs, USEPA is not aware of uses of the Site or media uses which are inconsistent with the stated objectives which will be required in ICs.

Long-Term Stewardsh ip

Long-tenn protectiveness requires compliance with effective ICs. Compliance with effective ICs will be ensured by implementing, maintaining, monitoring and enforcing effective ICs as well as maintaining the site remedy components. Long-term stewardship procedures will be developed to ensure that the remedy continues to function as intended with regard to ICs. In the draft IC Workplan. the PRPs have proposed to amend the O&M Plan. The plan should include regular inspection of ICs at the site and annual certification to USEPA that ICs are in-place and effective. Additionally, use of a communications plan and use of a one-call system should be explored for long-term stewardship.

Operation and Maintenance (O&M) Ground water monitoring well system A ground water monitoring well program composed of40 wells, sampled quarterly, is in place as a part of Site O&M. The ground water monitoring program wells monitor grOlmd water capture at the Rail Yard extraction wells in addition to monitoring the downgradient plume concentration. Wells are also in place to monitor operation of the ground water circulation well in the Drag Strip Area. Wells are sampled quarterly for Site COCs.

Residential Well Monitoring One residential property in the plume area has declined to accept municipal water. In accordance with the 1997 Consent Decree between USEPA and the PRP, this residential well is periodically tested for Site COCs. The results of that testing have indicated Site-related contamination at levels greater than MCLs.

Routine Vapor Monitoring Vapor monitoring is conducted by the PRP, on both an annual and a semi-annual basis, in homes adjacent to the Drag Strip Area. Fifteen homes are sampled annually for vapor intrusion. In addition, six of these residential properties are sampled sem iannually.

Monitoring Ground Water Potentiometric Levels Monitoring ground water potentiometric levels is also a part of Site O&M. Potentiometric monitoring consists of quarterly water level measurements from the sampled wells and an annual comprehensive water level measurement event. Annual comprehensive events are staggered at IS-month inte'rvals to account for seasonal variations. As a part of the Rail Yard ground water treatment plant 0&1\1. a subset of monitoring wells at the Rail Yard and Drag Strip is measured monthly.


Monthly Progress Reports and Annual Performance Evaluation Monthly Progress Reports are delivered to USEPA from the PRPs reporting influent and effluent vapor and water sampling from the Rail Yard Treatment system. In addition, the removal efficiency of the Rail Yard and Drag Strip Granulated Activated Carbon (GAC) units is reported. As a part of O&M, USEPA requires GAC replacement when the removal rate drops to 90%. To date, four annual RD/RA Groundwater Performance Evaluation Reports have been presented to USEPA from the PRPs, evaluating the system capture performance for the Rail Yard Area and the Drag Strip Area.

Current Compliance During Site inspection and interviews with the implementing PRP, no problems were noted.

Long-Term Stewardship As previously stated, the current O&M Plan includes quarterly monitoring well sampling, residential well monitoring, ground water treatment GAC unit efficiency monitoring, residential vapor intrusion monitoring, and water level monitoring. Once the final ground water treatment system is in place with appropriate monitoring points, the O&M Plan is subject to change to reflect the new systems. USEPA will ensure that appropriate treatment and monitoring measures are incorporated into the final O&M plan.

Costs and Operation Approximate annual costs ofO&M for the Conrail Rail Yard Site from 2004 through 2007 are shown in Table 5 below.

0Table 3 A,pprOXlmate O&MCosts f rom 2004 throo!!1hDecember 2007

Time Period

2004

2005

2006

2007

TOTAL

Onsite 0& M Costs

$154,800

356,900

361 JOO

326,000

1,199.000

Management Costs

Total Costs

$116,800 $271,600

181,300 538..200

140,900 502 ..200

156,800 482 .. 800

595,800 1,794,800

Table 6 provides a breakdown of estimated costs for 2008. The total costs in the table are approximate only and do not correspond to the exact costs. They are presented here, however, to provide a general indication of what the relative expenses are for several different categories of O&M activities.

T bl e 4 A.pproxlmate Cos s t Iior O&M A f Of Iior 20080a c IVI les

CostActivity

Rail Yard O&M $122.700

GCWO&M $47,100


Activity Cost

Carbon $16,000

Other Materials and Expenses $133,600

Management $163,400

TOTAL $482,800

V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW

The September 27,2004 Five Year Review listed the placement and implementation of institutional controls as its issue and recommendation.

At the time of the last Five-Year Review, the pilot extraction system at the Drag Strip Area and the first phase of the ground water containment system were recently completed. Since lhat time, the Drag Strip Area pilot GCW Treatment System and the first phase of the Rail Yard Area ground water treatment system have been operating continuously. In addition, the Site ground water monitoring systems for the Rail Yard Area and the Drag Strip Area have been gathering the information needed to evaluate the effectiveness of the remedy. Pursuant to the 1994 ROD and 2000 ROD Amendment, residential drinking water well sampling, residential and business indoor air/vapor monitoring, Rail Yard Treatment Plant water and vapor influent and effluent sampling, and Drag Strip Area GCW influent and effluent water and vapor sampling have been performed on a monthly or quarterly basis. Annual RD/RA Performance Evaluation Reports have been generated. Annual and semi-annual vapor monitoring of residences has continued and one property on a private well continues to be sampled annually. The potentially responsible parties also continue to monitor the vapor extraction systems installed in some of the residences and to sample for potential vapor in nearby residences. Finally, USEPA performed an independent evaluation of the capture performance for the Rail Yard Area and the Drag Strip Area ground water treatment systems.

VI. FIVE-YEAR REVIEW PROCESS

Administrative Components IDEM and the implementing PRPs were notified of the initiation of the five-year review on August 15,2008. USEPA was the lead-Agency for the review.

The components of the five-year review schedule include:

• Community Notification and Involvement • Document Review • Data Review • Site Inspections • Report Development and Review


Community Notification and Involvement A public notice was published on October 7, 2008, in the South Bend Tribune announcing a fiveyear review of Conrail.

Document Review This five-year review included a review of relevant documents including the RODs, ROD Amendment, Consent Decree, investigatory reports and studies, previous 5-Year Review, correspondence, memoranda, work plans, construction specifications, remedial action final design reports, and Preliminary Close-Out Report.

Data Review-Remedy Performance Evaluation This five-year review also included the generation of an April 2009 Remedy Perfonnance Evaluation by S.S. Papadopulos & Associates, under the oversight and direction of USEPA. The evaluation included statistical and spatial mapping analyses to evaluate contamination concentration trends and physical extents at the Site. The likely extent of hydraulic capture developed by the Rail Yard ground water extraction system was evaluated using a mapping technique that included kriging with a trend to account for the effect of pumping on the shape of the ground water surface. An analytical element model was also developed to help evaluate the likely extent of capture generated by the Drag Strip ground water circulation well.

The principal conclusions and recommendations reached in the report are that: 1) it appears necessary to increase extraction, and/or supplement the existing ground water extraction system at the Rail Yard to meet the objectives of hydraulic containment of DNAPL source areas, 2) it appears that there is a need to provide additional treatment of the Drag Strip sources, as r<~quired

by the ROD, including further investigation of source area hot spots and additional extraction points in the ground water plume, and 3) additional monitoring is required to confidently evaluate the performance of the Drag Strip ground water remedy.

Site Inspection The five-year review Site inspection was conducted on October 3, 2008, by Tim Drexler and Janet Pope with USEPA and Kevin Herron with IDEM. Robert Wallace, representing the PRPs, and Anthony Limke, a consultant for the implementing PRP, were also present. The purpose of the inspection was to assess the progress of remedy implementation, ensure records and Site documents were available and up-to-date, inspect the extraction system to verify it was operational and did not appear to have significant problems or flaws, and view general Site conditions. The intent was to collect infonnation to be able to better assess the protectiveness of the remedy and try to foresee any future remedy implementation problems and needs.

Observations during the Site inspection indicated that the Site is well-maintained, roads are in good condition, and the extraction and monitoring wells are properly secured. No evidence of vandalism or trespassing was noted.

VII. TECHNICAL ASSESSMENT

Question A: Is the remedy functioning as intended by the decision documents?

Based on the April 2009 Remedy Perfonnance Evaluation completed by USEPA for the Conrail Site. the ground water remedy is not functioning as intended by the CD, ROD, and ROD Amendment. The Rail Yard Area does not appear to be achieving complete hydraulic containment of the DNAPL plume. Identification of all hot spot areas in the Drag Strip Area does


not appear to be complete. In addition, the Drag Strip Area does not appear to be achieving significant capture of the CCI4 plume.

In accordance with the 2000 ROD Amendment, a contingency remedy must be developed to adequately contain the DNAPL sources at the Rail Yard Area. Further investigation of the Drag Strip Area hot spots is also needed. Finally, the pilot GCW treatment system will need to be expanded to a full-scale remedy, with performance metrics established, as identified in the PRP work plan approved by USEPA on November 25, 2003. Additional monitoring wells, in conjunction with these actions, will be necessary to monitor their effectiveness.

The ICs called for in the ROD and ROD Amendment are not fully implemented. Effective ICs must be implemented, monitored and maintained. To that end, an IC Plan needs to be finalized and implemented.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?

Changes in Standards and To-Be-Considered Requirements No changes in the location-specific or action-specific ARARs have been made, and no new standards or to be considered (TBC) requirements affecting the protectiveness of the remedy have been identified.

Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics A human health risk assessment and ecological risk assessment were developed as part of the remedial investigation of the Conrail Rail Yard Site. There have been no changes in exposure pathways, toxicity and other contaminant characteristics.

Question C: Has any other information come to light that could call into question the protectiveness of the remedy?

No.

Technical Assessment Summary

As stated, the USEPA Remedy Performance Evaluation identified shortcomings in the re:medy, as it is currently implemented, that will need to be addressed. Long-term protectiveness will be reevaluated after the remedy has been modified to address the issues raised.


VIII. ISSUES Table 5. Issues

Issue

Currently Affects

Protectiveness (YIN)

Affects Future Protectiveness

(YIN)

There is incomplete capture by the extraction well system of the DNAPL plume in the Rail Yard Area.

N Y

There is incomplete capture by the pilot GCW of the ground water plume in the Drag Strip Area.

N Y

The source areas in the Drag Strip Area are not characterized completely.

N Y

ICs are not fully implemented. ICs must be implemented, monitored, maintained, and enforced.

N Y

Other Issues Identified None.

IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Table 6. Recommendations and Follow-Up Actions

Affects

Issue Recommendations/ Follow-Up Actions

Party Responsible

Oversigbt Agency

Milestone Date

Protectiveness? (YIN)

Current Future

There is Modification of the Implementing USEPA December N Y incomplete extraction system at the PRP 2010 capture by the Rail Yard Area is extraction well necessary to ach ieve system of the complete capture. DNAPL plume in the Rail Yard Area.

There is Modification/expansion Implementing USEPA December N Y insuffic ient of the pilot GCW PRP 2010 capture by the Treatment System at pilot GCW of the Drag Strip Area is the ground necessary to capture water plume in significant quantities of the Drag Strip site contaminants and Area. performance metrics

must be established.

U.S Environmental Protection Agency 26

Affects

Issue Recommendationsl Follow-Up Actions

Party Responsible

Oversight Agency

Milestone Date

Protectiveness? (YIN)

Current Future

The SOurce Additional soil Implementing USEPA December N y

areas in the investigation is needed PRP 2010 Drag Strip Area in the Drag Strip Area are not to completely delineate characterized source areas. completely.

IC plan needs to be finalized. Effective ICs must be implemented, monitored, maintained, and enforced

The draft IC Workplan must be finalized by the PRPs and a final IC Plan must be generated to: I) document IC activities conducted by the PRPs, 2) plan for necessary corrective measures, 3)

PRPs USEPA and IDEM

December 2010

N y

map contaminated areas with the type of IC needed for each area, and 4) add necessary activities to ensure implementation and long-term stewardship of ICs by the PRPs.

X. PROTECTIVENESS STATEMENT

The Conrail remedial action is protective in the short term and not protective in the long term. Although the ground water remedy is not operating as intended, and ground water contamination is escaping the intended capture system, the remedy, as it is being implemented to-date, is addressing ecological exposure by serving to reduce the mass loading of contaminants to the St. Joseph River by removing and treating contaminated ground water. The potential for human exposure is being addressed by the provision of municipal water to residents, the installation of vapor mitigation units, and vapor monitoring in residents adjacent to impacted areas. Bt~cause

short term human health and ecological exposures are being controlled, the remedy is protective in the short ternl.

Additionally, all required institutional controls have not yet been implemented. Compliance with effective ICs will be ensured by implementing, maintaining, monitoring, and enforcing effective ICs, as well as maintaining the site remedy components. Long-term protectiveness requires complete and etTective capture and remediation of the ground water contamination plume and compliance with effective ICs.


XI. NEXT REVIEW

The next five-year review for Conrail Rail Yard will be completed five years from the signature date of this review.

u.s Environmental Protection Agency 28

Attachment 1 - Figures


Figure 1 Conrail Rail Yard Superfund Site Elkhart, Indiana

+ N

Legend

§ Rail Yard Area

Drag Strip

Soil Vapor Impacted

o 0.1250.25 0.5 0.75

__

Figure 2 Conrail Rail Yard Superfund Site Elkhart, Indiana

1 __-=__-=::. -======- Miles

Legend

o Extraction wells

Composite Plume

C Rail Yard Area

o GCW_Well

o Source Areas

• Monitoring V'klls

c::Jorag Strip

_ Residential Vapor Monitoring

Attachment 2 - Public Notice about 5-Year Review

Attachment 3 - Documents Reviewed


••

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As mom aud llaut<likL'd hoard~. n'gistc'rill~

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,\sk them if lIwt (',JlISCS I{otm)' Chill, not immediiJtelr 'j\·ailablc. any strife :ll lhc dinllcr Hokila eXfllalned he was The new regi.~lrnl\ts arc 1£llJll' and Joe looks for llll~ lLIJt. ill F,wl, Ihl: presi(!elll.. amoll~ mure limn mn .OO() IIOJillt words odur!;! hi~ wiflt lie Look oIT his pin alld g;we I loosit:r.~ .....ho either r~lolis· ruts hiJu off. illo Isis,<lSkitlg"lICl'who shl' u-rt'd for lhr rirsl lilll(' or

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Ruth lau!o!h. I'lopefllll)', HCpllhlir<l1l elcrti01I ol'ficer, Lea Pilcher \\·;tS olle of lhe h~al~d di~('ussions (:un whu smiled. those Ul)dalef:". Th~ South hl' put on hold now. People likC' Iht, BW;llhltts Beud r('sid('ul stood wilh

The BrcathiUs joinelJ are expected tn show up fflr about it dm;en people 011 hundrt'ds or l)t'Oplt: caslinft t::JJ'ly \'uling in high num lht: fuurth floor of lilt:: hallols 011 lilt, first day of bl'rs this Far. FtJr IIlc priM huilding ?tOlHlay l11ornillg, in-person ~bs~ntet' \'otin~, mary St:asun,In<liallOl .-;;:I\\" 3 fillill~ uut a lilll~ (<lTd. r<'ferred 10 informally :l'i ;100 flrrrmi inm'ase in ah' To gi\'C' VOIl ;'11\ idr:l of ~1,<tIly mtill~.r t-Clltcc vntiug. how long it'~ beell SillCI: she Th~ uption is ;lvailahll! to .\·lort! people art! illlere~L- ,"oleo, sh~'s bt:t'll at ht:r cur·

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"AI no poinl in my life l.:(Junll'y free:' he .~aid. "The ''I'm a It!I'l'ible per.'ion has politil,;S scenwcl. ~o im- mill1lll' \\'(' dl'('irlc nol to wlJ('u it mml~~ 10 fuJlowillg p()rt~tnt,~ Joe Breathitt chcri.~h the right, the duty, [1olitic.~:' l'itch~r s:lid. ".\nd said. "The things going on \0 se!rcl our own leader.:; i.~ then I gC'l m:ld. So it \ m.v ill my ('omnll1llity. the tl1f~ mililitc we ]Ilse this 11\\11 f:Jlllt hc("all:;e I didn't Ihil1g~ goin~ 011 illtt.'rna- country." do allylhin~ lo lry ltl lioIlW!l', t1IP\' r(,<lllv art' !"('I· CalHlidalcs from holh rhan!,!eil." evant rlOw.n m~ior lwrtlcs held rallit.'s

Election Day.

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CYAN MAGENTA BLACK EDITION 50R

http://www.SouthBendTribune.com

Documents Reviewed


IDEM, Comments on Draft Third Five-Year Review Report for Conrail Railyard Superfund Site, Elkhart County, Elkhart, Indiana. May 4,2009.

S.S. Papadopulos & Associates, Remedy Performance Evaluation, Conrail Rail Yard Superfund Site, Elkhart, Indiana. April 2009

URS, Revised Text of Workplan for Relocation and Pilot Testing ofGCW Treatment System, Osceola Drag Strip, Conrail Railyard Superfund Site, Elkhart, Indiana. No\;ember 25,2003.

URS, Benthic Invertebrate Data; First Remedial Design/Remedial Action, Conrail Railyard Superfund Site, Elkhart, Indiana. May 17, 2002.

URS, Final Design Report, Conrail Railyard Superfund Site Containment Groundwater Pumping and Treatment System, Elkhart, Indiana. July 14,2003.

URS, Monthly and Annual Reports, Conrail Railyard Superfund Site, Elkhart, Indiana. 2004-2009.

US District Court for Northern District of Indiana South Bend Division, Consent Decree, United States of America vs. Consolidated Rail Corp. vs. Penn Central Corp. et al.. November 10, 1997.

USEPA, Unilateral Administrative Order for Remedial Design and Remedial Action. July 7,1992

USEPA, Record of Decision, Conrail Rail Yard Site, Elkhart, Indiana. September 9, 1994.

USEPA, Record of Decision Amendment to Change Groundwater Remedy, Conrail Rail Yard Superfund Site, Elkhart, Indiana. September 27,2000.

USEPA, Preliminary Close-out Report, Conrail Rail Yard, Elkhart, Indiana, July 12, 2004.

USEPA, Five- Year Review Report for Conrail Rail Yard, City of Elkhart, Indiana. September 27,2004.


u.~. Environmental Protection Agency

Institutional Controls Tracking System .~ ..~ . .. ...

IC Public Web Report Preview Available Click To View

Published by Donald Bruce on 05/01/2008 Click To View

Edit ModeI II Save ']

All Institutional Controls are implemented at this Site: 0

""._~••-~ •• JC._ • '-~"u '~ .,-,'';;'"

Name Site 10 Context CERCUS 10 Region Region Context State IC Required ]

CONRAIL RAILYARD ELKHART USEPA Site ID (12-digit) IND000715490 05 USEPA Region IN Yes

AddlEdjtlDeitte

Area 10 SubareaArea 10 Media Resource Individual Organization

Context of

(3141, RPM)

.' ,• I I ,

Name

Rail Yard

10

2801

AREA OF Ie INTEREST

SITE. ...~ 10

2081

(3241)Area Of IC (6001) (6781) (6782) (6783) (3142, Attorney) (3242)

Interest (6002) (6784) (6785) (3143, State Project Manager) (3243)

(3144, PRP Represenative)

(3141, RPM) (3144, PRP Represenative) (3241)

Area Of IC (3143, State Project Manager) (3242)2802 Drag Strip Property (6783) (6784)

Interest (3142, Attorney) (3243) (3145, Off-Site Property (3244) Owner)

MEDIA AddlEditlDtlet!

ID Name Is Media

Contaminated? Use Restriction Objective Engineering

Control

6001 Ground Water

Yes (3701) (3702) (6201) (6202)

6002 Soil Yes (3703) (6203)

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U.S. Environmental Protecbon Agency

OBJECTIVE AddlEditlDe.... .. .. -"

10 Objective Purpose Description Required from Decision

Document? Use Restriction Resources

6201 Prohibit Ingestion Exposure Limit GroundWater Use

Activities Yes (3702)

(6781) (6782) (6783)(6784) (6785)

6202 Protect Integrity of an

Engineering Control Protect on-site equipment for

groundwater containment. Yes (3701)

(6782)(6781)(6783)(6784) (6785)

6203 Eliminate All Exposure

Scenarios Restrict contaminated soil

disturbance (3703) (6783) (6784)

USE RESTRICTION

10

AckUEdiflDtle" ..... "

Restriction Type

".'Ii-

Description Resource Event

3701 Prohibit Any Activity that May Disturb the Integrity of an Engineering Control (6785) (6722) (6723) (6724)

3702 Prohibit Ingestion Exposure (6792) (6722) (6723) (6725) (6733)

3703 Prohibit Disturbance of Soil (6793) (6722) (6723) (6724) (6733)

ENGINEERING CONTROL AddlEditlDelet8 ... -. ... .. .. :.. ...._,.0;,,:' ... :"

10 Engineering Control Type Description Objective

981 Containment, (N.O.S.) Groundwater containment system (6202)

982 Ground Water Treatment System Pump and Treat for Drag Strip Property (6202)

I RES?URCE A~~~~""

10 Ie

Document Class

Document Class

Document Category

Class

Document Source

Document Life Span

Document Life Span Conditions

Document Title

Document 10

Document 10 Context Event Sensitivity

6781 Decision Record of

Decision (ROD)

Decision Federal

SDMS IDSuperfund Document Management System ID

(6721) Public

6782 Decision Record of

Decision (ROD)

Decision Federal

SDMS ID-Superfund Document Management System ID

(6722) Public

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U.S. Environmental Protecbon Agency

Document6725 Ordinance Implementation 12-30-2009

Recordation

6726 Restrictive DocumentImplementation 12-31-2009

Covenant Recordation

Five Year DocumentMonitoring6733 Review Issuance

(3141, RPM) (3142, Attorney) (3241) Restricted (3143, State Project (3242) (Confidential) Manager)

(3141, RPM) (3142, Attorney) (3145, Off-Site (3241 ) Property Owner) (3242) Restricted (3143, State Project (3243) (Confidential) Manager) (3244) (3144, PRP Represenative)

INDIVIDUAL Adf;tIEfljtlDtletl

10 First Name Last Name Middle Initial Phone Number Email Address Organization

3141 Timothy Drexler 312-353-4367 drexler. [email protected] (3241, Remedial Project Manager)

3142 Mike Berman 312-886-6837 [email protected] (3241, Associate Regional Counsel)

3143 Kevin Herron 317234-0354 [email protected] (3242)

3144 Gibson Barbee (3243)

3145 Ruth Chizum (3244)

ORGANIZATION AddlEdntDtlelt

10 Organization Formal Name Organization Type Phone Number Email Address Web Site

3241 USEPA Federal Government

3242 IDEM State Government

3243 Norfolk Southern Land Owner/PRP

3244 Osceola Drag Strip Property Owner

"., .-:-.......

Comments

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mailto:[email protected]



·Superfund Site Indicators Consistency Checklist

This Indicators Consistency Checklist serves to promote consistency among various indicators in the Superfund Remedial Program. It should be completed for all Final NPL, Deleted NPL, Proposed NPL and SAS sites. The Checklist should be completed/updated whenever there is an initial determination or update on the following: Human Exposure and/or Contaminated Groundwater Migration Environmental Indicators determinations, Institutional Controls status, Five Year Review (FYR) determinations, Site-Wide Ready for Reuse determinations, or Cross Program Revitalization Measure determinations. This Checklist and the various indicators in it should be reviewed and updated as appropriate as your site project remediation develops, including at such milestones as: Record of Decision, ROD Amendment, Explanation of Significant Differences, Remedial Design, Preliminary Construction Completion, and Final Construction Completion.

Site Name: Conrail RPM: Tim Drexler

Attorney: Michael Berman

Environmental Indicators: Determinations are Site-Wide.

Scope of Indicator: Environmental Indicator Determinations are required at Final NPL, Proposed NPL, and Superfund Alternative sites.

HUMAN EXPOSURE

If the Human Exposure determination for this site is:

_ Current Human Exposures Not Controlled

Then: The FYR protectiveness statement for at least one portion of the remedy must be remedy is not protective. The site cannot be Site-wide Ready for Anticipated Use.


Insufficient Data

Then: The FYR protectiveness statement for at least one portion of the remedy must be protectiveness cannot be determined until further information is obtained. The site cannot be Site-wide Ready for Anticipated Use.


XCurrent Human Exposures Controlled

Then: The FYR protectiveness statement for all of the site remedy operable units must be remedy is protective in the short term. The site cannot be Site-wide Ready for Anticipated Use.


1

_ Current Human Exposure Controlled and Protective Remedy in Place (Construction Complete, remedy operating as intended, ICs in place and effective)

Then: The FYR protectiveness statement for all of the site remedy operable units must be remedy is protective in the short term and is expected to be protective in the long term. ICs must be in place and effective for the entire site. The site may be Site-wide Ready for Anticipated Use.

If the Human Exposure determination for this site is _ Long-Term Human Health Protection Achieved (all human exposure-related cleanup goals met for the entire site)

Then: FYR protectiveness statement for all of the site remedy operable units must be remedy is protective (in the short term and the long term). ICs must be in place and effective for the entire site. The site may be Site-wide Ready for Anticipated Use.

CONTAMINATED GROUNDWATER MIGRATION

If the Contaminated Groundwater Migration determination for this site is:

~ Contaminated Groundwater Migration Not Under Control

Insufficient Data

_ Contaminated Groundwater Migration Under Control

The Contaminated Groundwater Migration Environmental Indicator does not have a direct bearing on the FYR protectiveness statement or the Site-Wide Ready for Anticipated Use indicator unless:

• There are current human exposures to the contaminated groundwater. Then the FYR protectiveness statement must be that the remedy is not protective in the short or long term and the Human Exposure Environmental Indicator should be Current Human Exposures Not Controlled. The site is then also not Site-Wide Ready for Anticipated Use.

• There are reasonably anticipated future human exposures to the contaminated groundwater. Then the FYR statement must be that the remedy is not protective in the long term (at least - there may be other site-specific reasons why the remedy may not be protective in the short term), unless ICs that will prevent future exposure to the contaminated groundwater are in place and effective. If there are reasonably anticipated future human exposures to contaminated groundwater and no effective ICs in place, then the Human Exposure Environmental Indicator cannot be Current Human Exposure Controlled and Protective Remedy in Place or Long-Term Human Health Protection Achieved, and the site is not Site-Wide Ready for Anticipated Use.

Institutional Controls:

Scope of ICs: ICs are required as determined by site decision document(s) and current evaluation. ICs may apply site-wide or for distinct parcels of land, and are not necessarily based on operable unit. In order for ICs to be considered in place and effective the following must be met (check all that apply):

_the ICs cover all physical areas that do not support unlimited use/unrestricted exposure (UU/UE) and the ICs physical description of the non-UU/UE areas are accurate based on current conditions for the entire site (e.g., groundwater ordinance covers the entire plume area, legal description of cap in restrictive covenant has been mapped or undergone other verification);

2

,

_all needed land use restrictions/objectives are stated in and covered by the IC; _title work shows recording and that no other existing property rights will interfere with the site remedy or cause undue exposure (for restrictive covenants and other proprietary controls only), _there is current compliance with the land use restriction determined by a recent inspection; and _further compliance with the restrictions is expected because: (1) there is a legal basis for enforcing the use restriction against current and future owners; or (2) ORC and Superfund Program Branch Chiefs concur that the totality of the circumstances support the expectation of future compliance with restrictions.

IF: ICs are NOT required based on site decision document(s) and the site is cleaned up to UUlUE;

THEN: The site may be Site-Wide Ready for Anticipated Use. The site HE EI should be Long Term Human Health Protection Achieved. The site FYR protectiveness statements should be protective in the short-term and protective in the long-term.

IF: ICs are NOT required based on site decision document(s) and the site is not cleaned up to UU/UE;

THEN: The site is not Site-Wide Ready for Anticipated Use. The site Human Exposure Environmental Indicator may be Current Human Exposures Not Control/ed, Insufficient Data, Current Human Exposures Control/ed, or Current Human Exposures Control/ed/Protective Remedy in Place. The site Human Exposure Environmental Indicator may not be Long Term Human Health Protection Achieved. The site FYR protectiveness statements may be protective in the short term and must be not protective in the long term.

IF.:-ICs are required based on site decision document(s) but are NOT in place and/or effective;

THEN: The site is not Site-Wide Ready for Anticipated Use. The site Human Exposure Environmental Indicator may be CU;:;nt Human Exposures Not Controlfed, Insufficient Data, or Current Human Exposures Control/ed. The site Human Exposure Environmental Indicator may not be Current Human Exposures Control/ed/Protective Remedy in Place or Long Term Human Health Protection Achieved. The site FYR protectiveness statements may be protective in the short term and must be not protective in the long term.

IF: _ ICs are required based on site decision document(s) and are in place and effective; THEN: The site may be Site-Wide Ready for Anticipated Use. The site HE EI may be any of the five categorizations. The site FYR protectiveness statements may be protective in the short term and may be protective in the long term.

IF: _ ICs are required based on current evaluation, but are not properly documented In a decision document and not in place and effective; THEN: The site is not Site-Wide Ready for Anticipated Use. The site HE EI may be any of the five categorizations. The site FYR protectiveness statements may be protective in the short term and must not be protective in the long term. The need for ICs should be properly documented in the site record as soon as possible.

IF: ICs are required based on current evaluation, but are not properly documented in a decision document, and

are in place and effective; THEN: The site may be Site-Wide Ready for Anticipated Use. The site HE EI may be any of the five categorizations. The site FYR protectiveness statements may be protective in the short term and may be protective in the long term. The need for ICs should be properly documented in the site record as soon as possible.

_ Other, please explain _

Five Year Review Protectiveness Statements: Determinations are made for each Operable Unit Remedy.

3

Scope of FYRs: FYR are required at sites where a remedial action was selected post-SARA, and the remedi~.

action leaves hazardous substances on site above health-based limits under one or more land use scenario(s). FYRs are also conducted at sites: (1) where a remedial action was selected pre-SARA, and the remedial action leaves hazardous substances on site above health-based limits under one or more land use scenario(s) and (2) where the remedial action is anticipated to take a long time (over 20 years) to reach the cleanup goals which will then allow unlimited use and unrestricted access.

FYR protectiveness statements are specific to an operable unit remedy. If there are multiple operable unit remedies at a site, there may be different FYR protectiveness statements for each operable unit remedy. In cases where there are different protectiveness statements for different operable unit remedies at a site, the "least protective" protectiveness statement in a FYR dictates the protectiveness of the site-wide Human Exposure EI determination. Considering the "least protective" protectiveness statement in the FYR...

If the FYR protectiveness statement is:

_ Remedy is protective

Then the site is considered protective in the short term and protective in the long term. The site must be categorized as Long Term Human Health Protection Achieved. The site may be Site-Wide Ready for Anticipated Use. If ICs are needed, they are in place and effective as documented by the IC checklist beginning on page 2.


~ Remedy will be protective once the remedy is complete, and in the interim, exposure pathways that could result in unacceptable risks are being controlled ...

Then the site is considered protective in the short term and not considered protective in the long term. The site must be categorized as Current Human Exposures Controlled or Current Human Exposures Controlled-Protective Remedy in Place. 14' If"'~ ~r~ .... .~. ."""" .... ] hei€

~ J :II. A •• ' """ ,

':>' .:> "'" I"'''''~'''' "-, .... , ''''' oJ "", ..... ruur;; ,r;;Quy ' ....., -.. ", ....,'fjalefl-Idse.


_ Remedy is protective in the short-term, however, in order for the remedy to be protective in the long-term, the following actions need to be taken ...

Then the site is considered protective in the short term and is not considered protective in the long term. The site must be categorized as Current Human Exposures Controlled or Current Human Exposures ControlledProtective Remedy in Place. If ICs are needed, they may be in place and effective, as documented by the IC checklist beginning on page 2; and the site may be Site-Wide Ready for Anticipated Use.


_ Remedy is not protective, unless the following actions are taken to ensure protectiveness...

Then the site is not protective in the short term and not protective in the long term. The site must be categorized as Current Human Exposures Not Controlled. The site is not Site-Wide Ready for Anticipated Use.


_ Protectiveness (short term) cannot be determined until further information is obtained

Then the site must be categorized as Insufficient Data to Determine Human Exposure Control Status. The site is not Site-Wide Ready for Anticipated Use.

Ready for Anticipated Use: Determination is Site-Wide.

Scope of Indicator: Ready for Anticipated Use determination is made for Final and Deleted NPL sites. Sites

4

, where there is impact to groundwater only and EPA has not assessed the land surface are not eligible for SiteWide Ready for Anticipated Use. Sites that have been deferred to other programs without significant work by the EPA Superfund program are not eligible for Site-Wide Ready for Anticipated Use.

All answers below must be ·Yes" in order for the site to meet the GPRA definition of Ready for Anticipated Use.

Is the site a Final or Deleted NPL site? 'LYes _No

Is the site Construction Complete? _Yes A No

Have all cleanup goals in the site decision document(s) been achieved for media that may affect current or reasonably anticipated future land uses of the site, so that there are no unacceptable risks? _Yes ~No

Have alllCs and other controls required in the decision document(s) or by current conditions b{(n put in place and determined effective as determined by the IC checklist that begins all page 2? _Yes No

Is the Human Exposure Environmental Indicator determination either Current Human ExpoXes Controlled and Protective Remedy in Place or Long Term Human Health Protection Achieved? _Yes _ No

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Ilf cleanup goals for ecological exposures were established in the decision document(s), have they been met?

I Ves _No .)(Not Applicable

Cross Program Revitalization Measure (CPRM): Determination is made on acres of i land by operable unit or property transfer parcel.

Scope of Indicator: The CPRM is made for the following universe of sites: Proposed NPL, Final NPL, Deleted NPL, Superfund Alternative Sites, Non-Time Critical Removal Sites (NTCR), certain non-NPL federal facilities, and Formerly Used Defense Sites.

I\V-and parcel is ~ Protective for People (PFP)

Then, in that parcel of land, all identified human exposure pathways from contamination at the site are under control and all possible exposures are below health-based levels for current land and/or groundwater use conditions. This determination, for this parcel of land, is consistent with one of the three following Human Exposure Environmental Indicator determinations: Current Human Exposures Controlled, Current Human Exposures Controlled and Protective Remedy in Place, Long Term Human Health Protection Achieved. The site-wide Human Exposure Environmental Indicator does not have to meet the criteria of these three Human Exposure Environmental Indicators.

If a land parcel is _ Ready for Anticipated Use

Then, that parcel of land, • Is PFP, • Has achieved all cleanup goals for media that affect current and reasonably anticipated future land

uses such that there is no unacceptable risk, and • All les identified as part of the response action to help ensure long-term protection have been put in

place and are currently effective.

This determination, for this parcel of land, is similar to the Site-Wide Ready for Anticipated Use indicator, however, the full site does not need to meet the criteria of this indicator.

Ready for Anticipated Use Relationship to Site-Wide Ready for Anticipated Use

If ...

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,. • all of the land parcels at a site are Ready for Anticipated Use, • the Human Exposure Environmental Indicator for the site is Current Human Exposures

Controlled/Protective Remedy in Place or Long Term Human Health Protection Achieved, and • all cleanup goals for ecological exposures established in the decision document(s) have been met

Then ... the site is Site-Wide Ready for Anticipated Use.

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Third Five-Year Review Report Conrail Rail Yard …The Conrail Rail Yard Site is located adjacent to...

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