Third Five-Year Review Report Fort Wayne Reduction Dump - for Fort Wayne, Indiana - Records Collections
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EPA Region 5 Records Ctr.
1111111111111111111111111111111111111111
334796
Third Five-Year Review Report
for
Fort Wayne Reduction Dump
Fort Wayne, Indiana
PREPARED BY:
u.s. Environmental Protection Agency
Region 5
Approved by: Date:
(This page intentionally left blank)
Fort Wayne Reduction Dump
Fort Wayne, Indiana
Third Five-Year Review Report
Table of Contents
List of Acronyms 5
Executive Summary 7
Five-Year Review Summary Form 9
I. Introduction _ 11
II. Site Chronology 12
III. Background 13
Physical Characteristics 13
Land and Resource Use 13
History of Contamination 13
Initial Response 13
Basis for Taking Action 14
IV. Remedial Actions 15
Remedy Selection 15
Remedy Implementation 17
Institutional Controls 18
System Operations/Operation and Maintenance 20
V. Progress Since the Last Five-Year Review 21
VI. Five-Year Review Process 24
Administrative Components 24
Community Notification and Involvement 24
Document and Data Review 24
Site Inspection 25
Interviews 25
VII. Technical Assessment 26
Question A: Is the remedy functioning as intended by the decision documents? 26
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action
objectives used at the time of the remedy selection still valid? 26
Question C: Has any other information come to light that could call into question
the protectiveness of the remedy? 26
Technical Assessment Summary 26
VIII. Issues 27
IX. Recommendations and Follow-Up Actions 27
X. Protectiveness Statement. 27
XI. Next Review 28
3
Tables
Table 1- Chronology of Site Events
Table 2- Institutional Controls Summary Table
Table 3- Status of Issues Identified in Previous Five-Year Review
Table 4- Issues
Table 5- Recommendations and Follow-Up Actions
Figures
Figure 1 - Site Location/Map
Appendices
A - Declaration of Environmental Restrictive Covenants
B - Public Notice
C - List of Documents Reviewed
D - Extraction Well Analytical Data Summary
E - VOCs and SVOCs Jllnalyzed
F - Graphs
G - Site Inspection Report (including photographs)
4
List of Acronyms
ARARs Applicable or Relevant and Appropriate Requirements
CD Consent Decree
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
EPA United States Environmental Protection Agency
ERC Environmental Restrictive Covenant
FS Feasibility Study
FWRD Fort Wayne Reduction Dump
GAC granular activated carbon
ICs Institutional Controls
IDEM Indiana Department of Environmental Management
mg/kg milligrams per kilogram
NCP National Contingency Plan
NPDES National Pollution Discharge Elimination System
NPL National Priorities List
O&M Operation and Maintenance
OU Operable Unit
PCBs Polychlorinated Biphenyls
PCOCs Potential Chemicals of Concern
PCOR Preliminary Close Out Report
PRP Potentially Responsible Party
RA Remedial Action
RCRA Resource Conservation and Recovery Act
RD Remedial Design
RD/RA Remedial Design/Remedial Action
RI Remedial Investigation
5
RIIFS Remedialinvesti9ation/Feasibility Study
ROD Record of Decision
SVOCs Semi-Volatile Or~lanic Compounds
~g/kg micrograms per kilogram
~g/L micrograms per liter
UUlUE unlimited use/unrestricted exposure
VOCs Volatile Organic Compounds
6
Executive Summary
The Fort Wayne Reduction Dump (FWRD) Superfund Site is located in Allen County, Indiana, just east of
Fort Wayne, Indiana. The 35-acre site is situated within the 1DO-year flood plain of the Maumee River. A
municipal water supply is available from the City of Fort Wayne, which obtains its water supply from the St.
Joseph River. The individual private wells in the area are upgradient from the Site and groundwater
discharging to the Maumee River is not considered to be a drinking water exposure pathway.
The FWRD Site was listed on the National Priorities List (NPL) in June 1986. A Remedial Investigation
(RI) was completed on January 7, 1988, and a Feasibility Study (FS) was completed on May 2, 1988. The
RI concluded that remedial response actions were warranted for site media impacted by past disposal
activities. These media included surface water, soils, and groundwater. The FS recommended a
remedial action alternative for the Site, and the United States Environmental Protection Agency (EPA)
signed the Record of Decision (ROD) on August 26, 1988.
The Remedial Design/Remedial Action (RD/RA) was performed under a 1989 Consent Decree. The RA
for the Eastern Portion of the Site consisted of installing a Subtitle 0 landfill soil cover and was completed
in October 1991. The RA for the Western Portion of the Site was performed in three phases. Phase I and
Phase" construction activities consisted of the installation of a geotextile wall, a bio-polymer collection
trench, and a vertical barrier. Phase III construction activities consisted of the excavation of drums with
appropriate disposal of drummed contents. A groundwater management system was installed to collect
and treat impacted groundwater from the collection trench and to prevent groundwater from discharging to
the Maumee River. A hybrid Resource Conservation and Recovery Act (RCRA) landfill soil cover was
installed on the Western Portion of the Site. In addition, the selected remedy required restrictions to
control future property use and prohibit the use of groundwater or the installation of wells on-site for a
water supply source. The Site achieved construction completion with the signing of the Preliminary Close
Out Report (PCOR) on September 27, 1995.
Operation and Maintenance (O&M) activities have been conducted at the Site since the completion of
construction. O&M activities include inspection of the landfill cap to check for erosion, confirming that
there is adequate vegetative growth, and verification of the integrity of the fence and the rip rap along the
Maumee River. Discharge samples have been collected and analyzed, as required by the discharge
permit, to verify that the treatment system is operating properly and that the discharge is within permit
limits. In addition, as part of long-term monitoring of the response action, semi-annual sampling and
analysis of the groundwater is performed. .
The ROD did not stipulate site-specific groundwater cleanup criteria to determine when the operation of
the groundwater collection and treatment system could be terminated and groundwater allowed to
discharge naturally to the Maumee River. Therefore, subsequent to the 2004 Five-Year Review Report, a
process was developed by which the Indiana Department of Environmental Management (IDEM)
developed the site-specific groundwater cleanup criteria that provide protection to the Maumee River. The
Site's comprehensive monitoring data was then reviewed against those site-specific groundwater criteria
to evaluate the effectiveness of the groundwater treatment system. Upon evaluation of the data, the
groundwater treatment system was placed on temporary standby mode to evaluate whether or not, without
further treatment, the groundwater constituent concentrations were being sustained at concentrations less
than the cleanup criteria (i.e., no rebounding), as well as to evaluate if any adverse impacts were
observed. During temporary shutdown of the groundwater system, two additional confirmatory semi
annual monitoring events have taken place to further evaluate the effects of the shutdown of the
groundwater treatment system. EPA and IDEM agreed that if these two monitoring events confirmed that
the groundwater constituents continued to meet the cleanup criteria, decommissioning of the treatment
system could be pursued.
7
Since specific groundwater cleanup criteria were not stipulated in the 1988 ROD, EPA will need to
supplement the ROD with an Age'ncy decision document that articulates what the cleanup criteria are and
the process by which they were determined,
The assessment of this five-year review for the Fort Wayne Reduction Dump Site found that the remedy is
protective of human health and the environment in the short term. Based on the Site inspection,
monitoring data and communication with O&M personnel, no inappropriate land or groundwater use was
observed. EPA is not aware of site or media uses which are inconsistent with the stated objectives of the
ICs and cleanup goals. Access is further restricted by the use of fencing. Groundwater monitoring will
continue so that EPA can be sure that the remedy remains protective of human health and the
environment. Long-term protectiveness at the Site requires continued compliance with use restrictions to
assure that the remedy continues to function as intended. To assure proper maintenance, monitoring,
and enforcement of effective ICs, long-term stewardship procedures will be reviewed and a plan
developed. This plan will include a provision for regular inspection of ICs at the Site and annual
certification to EPA that the ICs a!'e in place and effective.
8
Five-Year Review Summary Form
SITE IDENTIFICATION
Site name (from WasteLAN): Fort Wayne Reduction Dump
EPA 10 (from WasteLAN): IND980679542
NPL status: IRJ Final 0 Deleted 0 Other (specify)
Remediation status (choose all that apply): 0 Under Construction IRJ Operating 0 Complete
Multiple OUs?· 0 YES Construction completion date: September 27, 1995
IRJ NO
Has site been put into reuse? 0 YES IRJ NO
REVIEW STATUS
Lead agency: IRJ EPA 0 State o Tribe 0 Other Federal Agency
Author name: Linda A. Kern
Author title: Remedial Project Author affiliation: EPA, Region 5
Manager
Review period;·· March 27,2009 to September 2009
Date(s) of site inspection April 28, 2009
Type of review:
IRJ Post-SARA o Pre-SARA o NPL-Removal only
o Non-NPL Remedial Action Site o NPL StatefTribe-lead
o Regional Discretion)
Review number: 0 (first) 02 (second) IRJ 3 (third) 0 Other (specify)
Triggering action:
o Actual RA On-Site Construction at au #_ o Actual RA Start at OU#
o Construction Completion IRJ Previous Five-Year Review Report
o Other (specify)
Triggering action date (from WasteLAN: September 29, 2004
Due date (five years after triggering action date): September 29, 2009
• ["OU" refers to operable Unit.]
•• [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]
9
Five-Year Review Summary Form
(continued)
Issues:
1. To ensure the ICs remain effective, IC requirements need to be evaluated and
an IC Plan developed.
2. The O&M Manual l1eeds to include a provision to maintain and monitor effective
institutional controls.
Recommendations and Follow-Up Actions:
1. Complete an IC evaluation for the Site. Develop an IC Plan documenting IC
activities and planning corrective measures needed to ensure long-term
protectiveness.
2. Revise and finaliZE! the O&M Manual to include long-term stewardship for ICs.
Protectiveness Statement:
The assessment of this five-year review for the Fort Wayne Reduction Dump Site found
that the remedy is protective of human health and the environment in the short term.
Based on the Site inspection, monitoring data and communication with O&M personnel,
no inappropriate land or groundwater use was observed. EPA is not aware of site or
media uses which are inconsistent with the stated objectives of the ICs and cleanup
goals. Access is further restricted by the use of fencing. Groundwater monitoring will
continue so that EPA can be sure that the remedy remains protective of human health
and the environment. Long-term protectiveness at the Site requires continued
compliance with use restrictions to assure that the remedy continues to function as
intended. To assure proper maintenance, monitoring, and enforcement of effective ICs,
long-term stewardship procedures will be reviewed and a plan developed. This plan will
include a provision for regular inspection of ICs at the Site and annual certification to EPA
that the ICs are in place and effective.
Other Comments:
None
CERCUS Data:
Date of last Regional Review of Human Exposure Indicator: 07/15/2009
Human Exposure Survey Status: Current Human Exposure Controlled and Protective Remedy
in Place (PRIP)
Date of last Regional Review of Groundwater Migration Indicator: 07/15/2009
Groundwater Migration Survey Status: Contaminated Groundwater Migration Under Control
Ready for Reuse Determination Status: Pending
10Five Year Review Report
Fort Wayne Reduction
Fort Wayne, Indiana
I. Introduction
The purpose of the five-year review is to determine whether the remedy at a site is protective of human
health and the environment. The methods, findings, and conclusions of reviews are documented in five
year review reports. In addition, five-year review reports identify issues found during the review, if any,
and recommendations to address them.
The Agency is preparing this five-year review report pursuant to CERCLA §121 and the National
Contingency Plan (NCP). CERCLA §121 states:
"If the 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 each five years after the initiation of such remedial action to
assure that human health and the environment are being protected by the remedial action
being implemented. In addition, if upon such review it is the judgment of the President
that action is appropriate at such site in accordance with section [104J or [106J, the
President shall take or require such action. The President shall report to the Congress a
list of facilities for which such review is required, the result of all such reviews, and any
actions taken as a result of such reviews. "
The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii)
states:
"If a remedial 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 agency shall review such action no less often than every
five years after the initiation of the selected remedial action. "
The United States Environmental Protection Agency (EPA), Region 5, conducted this five-year review of
the remedy implemented at the Fort Wayne Reduction Dump (FWRD) Site in Fort Wayne, Indiana. This
review was conducted for the entire Site by the Remedial Project Manager from March 2009 through
September 2009. This report documents the results of the review.
This is the third five-year review for the FWRD Site. This statutory 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.
IIII. Site Chronology
T a bl e 1 - Ch rono ogy 0 f SOt
Ie Eyen t s
Date Event
October 1984 Proposed for the National Priorities List (NPL)
February 1986 EPA released findings on groundwater quality samples from River Haven
community residential wells
June 1986 Finalized on the NPL
August 1986 Rernediallnvestigation (RI) initiated by EPA
May 1987 RI field activities completed
January 7, 1988 RI Heport completed
May 2,1988 Feasibility Study (FS) completed
June7,1988 Public comment on Proposed Plan ended
August 26, 1988 Record of Decision issued
February 22, 1989 Consent Decree for Remedial Desiqn/Remedial Action (RD/RA)
December 1989 Remedial Design submitted
September 1990 Remedial Action initiated
Fall 1990 Remedial Design of Western Portion initiated
July 1991 - October 1991 Eastern Portion cap constructed
September 1992 - Western Portion Phase I & Phase II (geotextile wall, collection trench,
December 1992 vibrated beam vertical barrier) constructed
February 1993 - August . Western Portion Phase III (drum removal) conducted
1994
July 1994 - October 1994 Western Portion cap constructed ,
I
I
November 1993 - October Western Portion groundwater treatment system constructed
1994
September 25, 1995 Pre-·final inspection performed by EPA and IDEM
September 27, 1995 Preliminary Close Out Report (PCOR) signed
July 2, 1995 First Five-Year Review completed
September 29, 2004 Second Five-Year Review completed
May 11, 2007 Formal request submitted by Waste Management to IDEM to develop site
:-:---:---=-:::-:=-=-::
i-; ~p~clflc gro undwater c1ea nup cnte ria
: March 27, 2008 IDEM transmits to EPA site-specific groundwater cleanup criteria
i June 30, 2008 Waste Management notifies EPA and IDEM that groundwater cleanup
I objectives for the Site have been attained
,
two additional semi-annual sampling events are performed
November 4, 2008 Semi-Annual Compliance Monitoring Event
February 9, 2009 • Transmittal of Operations, Maintenance, and Monitoring Manual to EPA and
IDEM
April 16, 2009 Semi-Annual Compliance Monitorinq Event
April 28, 2009 Third Five-Year Review Site Inspection Conducted
12III. Background
Physical Characteristics
The FWRD Site is located along the south bank of the Maumee River approximately 1.1 miles east of the
U.S. Highway 30 and Maumee River intersection, just east of Fort Wayne, Indiana. The 35-acre site is
situated within the 1OO-year flood plain of the river. The Site is bordered by the Maumee River to the
north, the Norfolk and Western Railroad to the south, an auto parts stockyard to the southwest, Martin
Landfill to the northwest, and Herber Drain to the east. The communities of River Haven and Sunnymede
Woods are directly east and south approximately 0.5 miles from the Site. The Site's location is shown in
Figure 1.
Land and Resource Use
Prior to 1967, the Site was uncultivated farmland that may have been used for some limited waste
disposal. The Site is believed to have started official operations in 1966 and continued to accept
residential and industrial wastes until 1974. Currently, primary land use in the area of the Site is light
industrial and commercial. An abandoned landfill and the Fort Wayne municipal wastewater treatment
plant and sludge drying beds are located along the Maumee River in the vicinity of the Site.
History of Contamination
The Site operated from 1967 to 1975 as a waste disposal facility. In 1970, Fort Wayne Reduction, Inc.
changed its name to the National Recycling Corporation and expanded the recycling plant at the Site.
Few records were kept on the volume and composition of wastes, or on the generators of the waste.
The Eastern Portion of the Site (approximately 15 acres) was actively used as an industrial and general
refuse landfill. Portions north and west of the recycling plant were utilized for disposal of industrial wastes,
building debris, and barrels of liquid and sludge wastes. Inspection reports indicate that the refuse
deposited included wood, paper, liquids, sewage, garbage, industrial wastes, municipal wastes, industrial
liquids, and sludges (paints, varnishes, etc.). The Western Portion (approximately 5 acres) was used as a
disposal area for industrial wastes, wire waste, and residual ash from the incinerator operations. A 40- to
60-foot diameter waste disposal cell containing liquids was first reported in a state inspection report from
May 1972. A drum burial cell was located on aerial photographs taken in 1973.
The Site ceased accepting wastes in 1974. From 1974 until late 1977, the Site continued to be used as
the base for a waste hauling operation and a recycling center. The recycling center shut down in late
1974, and the hauling operation later moved to a different location. After that time, the Site was inactive.
In 1984, Waste Management acquired SCA Services, Inc., which was then the owner of the Site.
In February 1986, EPA released its findings on groundwater quality samples taken from residential wells in
the River Haven Community. There was no evidence of contamination in the residential well samples.
After separate and limited field investigations by both EPA and SCA, the Site was proposed for addition to
the National Priorities List in October 1984. The Site was then formally listed on the NPL in June 1986.
Initial Response
A Remedial Investigation/Feasibility Study (RI/FS), including a baseline Risk Assessment, was initiated in
August 1986. The RI (dated January 7, 1988) concluded that remedial response actions were warranted
for site media impacted by past disposal activities. These media included surface water, soils, and
groundwater. The FS identified applicable remedial technologies and screened them based on technical,
environmental, public health, institutional criteria, and cost. The FS recommended a remedial action
alternative for the Site, and EPA signed the Record of Decision (ROD) on August 26, 1988. The ROD
defined three operable units (OUs) for the Site: OU 1, the Eastern Portion municipal landfill: OU 2, the
13Western Portion of the Site; and OU 3, groundwater. For purposes of remedial action and reporting, the
operable units were combined; therefore all tracking in EPA's WasteLAN database is reported as one
overall operable unit. For purposes of discussing the remedial actions taken at the Site, the following
discussion is organized by the ori!linally envisioned three operable units.
Basis for Taking Action
The groundwater beneath the Site was delineated into three unconsolidated aquifers (deep, intermediate,
and upper) with intervening low permeability layers. The groundwater at the Site is not considered a
potential water supply source. Limited groundwater yield excludes this aquifer's use as a water supply
source on-site. A municipal water supply is available from the City of Fort Wayne which obtains its water
supply from the St. Joseph River. The individual private wells in the area are upgradient from the Site. In
addition, the Maumee River is not used as a drinking water supply in the Site's area. Therefore,
groundwater discharging to the Maumee River is not considered to be a drinking water exposure pathway.
Eastern Portion
The soils in the Eastern Portion of the Site contained municipal wastes buried up to 25 feet deep. Wastes
were covered with a mixture of clay, silts, and gravels averaging approximately 2 feet in thickness. The
soils on this portion of the Site were not a source of hazardous organic contaminants. Some inorganic
compounds, specifically arsenic, antimony, copper, and lead, were detected in the surface soils at levels
up to 195 milligrams per kilogram (mg/kg).
Under the far Eastern Portion of the Site, the intermediate aquifer has direct hydraulic connection with the
upper aqUifer unit. The general flow direction of groundwater under the Eastern Portion of the Site is
northeast toward the Maumee River.
Western Portion
Soils in the Western Portion of the Site were found to be contaminated with volatile organic compounds
(VOCs), semi-volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), and inorganics.
Sample results for total VOCs were as high as 15,566,000 microgram per kilogram (lJg/kg) on this portion
of the Site. Two areas of buried drums, referred to as Area A and Area B, were discovered on the
Western Portion of the Site.
The upper aquifer under the Western Portion of the Site consists of alluvial and lacustrine deposits and is
underlain by a till unit. The general flow direction of groundwater under this portion of the Site is north and
northeast towards the Maumee River. The RI showed that groundwater contamination under the Western
Portion of the Site was limited to the upper aquifer. Total organic contaminant concentrations in the
groundwater beneath this portion of the Site were as high as 1,700 micrograms per liter (lJg/L).
Contaminants of Concern
A Baseline Risk Assessment was completed for the Site in coordination with the RI. Based on the
summary provided in Appendix B of the RI. the risk assessment included identification of potential
chemicals of concern (PCOCs), a toxicity assessment, an exposure assessment, and a risk
characterization. During the RI, 9'1 chemicals were detected in samples collected from various media
across the Site. Of these 91 chemicals, 80 were detected in samples collected from test pits,
groundwater, leachate seeps, and product on the Western Portion of the Site. As stated in the ROD, the
list of detected chemicals was refined to a list of 43 PCOCs for the entire Site, including VOCs,
polyaromatic hydrocarbons. metals, PCBs, and phenols. These 43 compounds were selected using two
guidelines. First, all chemicals representing a potential hazard to human health and the environment
(having "critical toxicity values") were selected if they were detected in a media to which exposure could
occur. Second, additional chemicals were selected if they were representative of site-wide conditions or
14represented a significant contaminant source. All except two of the 43 PCOCs (chloroform and PCBs)
were detected in either the test pits, leachate seeps, product, or in groundwater samples from Site
monitoring wells associated with the Western Portion of the Site.
The RI exposure assessment considered the potential exposure pathways by which human and wildlife
could come into contact with the PCOCs under current and future land use scenarios. The assessment
considered exposure to contaminated soils/exposed wastes through such means as direct contact (which
could include ingestion and dermal absorption) with soils on Site, inhalation of volatilized constituents in
the air on- and off-site, inhalation of particles liberated to the air by wind or mechanical erosion on- and
off-site, and ingestion and dermal absorption of solubilized/suspended contaminants in runoff discharged
to the Maumee River. The assessment also considered exposure to buried wastes through ingestion,
dermal absorption, and inhalation of contaminants that leached to groundwater that either discharged to
the Maumee River or collected in on-site leachate pools. Exposure populations included on-site
trespassers and future Site users, on-site terrestrial wildlife, off-site residents/workers, river organisms,
swimmers, people who consume fish, and hunters. The drinking water exposure pathway was not
considered a potential exposure pathway because the Site groundwater and Maumee River are not used
as drinking water supply sources.
Based on the potential exposure pathways identified, a risk characterization was completed Two
groundwater exposure pathways of concern were identified. The first of these pathways was associated
with the risk due to trespasser's inadvertent ingestion of groundwater, from groundwater seeps along the
river bank, containing five specific chemical parameters (cadmium, 2-methylphenol, 4-methylphenol,
phenol, and xylenes) at concentrations greater than their respective reference doses identified in the
baseline risk assessment. Although this potential exposure pathway was identified as a concern, the risk
associated with this pathway was considered to be minimal based on the low potential for actual exposure
and the expected low frequency of exposure.
The second of these pathways was associated with groundwater and groundwater seeps containing 11
chemical parameters (barium, cadmium, copper, 2,4-dimethylphenol, ethylbenzene, 2-methylphenol, 4
methylphenol, methlyene chloride, phenol, toluene, and xylenes) at concentrations exceeding acute water
quality criteria, which were either identified or derived based on EPA and U.S. Department of Interior
reference documents for the protection of aquatic organisms at the point of discharge to the river.
However, the concentrations of these chemicals were determined not to exceed the chronic water quality
criteria after mixing with the river water. Likewise, risks associated with swimming in the river or
consumption of fish were found not to be a concern.
IV. Remedial Actions
Remedy Selection
In evaluating the findings of the RI and the Risk Assessment, the following media on the Western Portion
of the Site were identified as presenting either an existing or a potential future unacceptable public health
or environmental risk at the Site:
• Surface soils
• Subsurface soils/wastes
• Groundwater/groundwater seeps
Therefore, the following were identified as the specific remedial action goals for the Site:
• Surface Soil - To provide adequate protection of public health and the
environment by limiting direct contact with, and erosion of, on-site surface soils in
the Western Portion of the Site.
15• Subsurface soilsiwastes - To provide adequate protection of public health and the
environment by limiting direct contact with and future releases to the Maumee
River from the subsurface soils and wastes in the Western Portion of the Site.
• Groundwater/GrCiundwater Seeps - To provide adequate protection of public
health and the environment by limiting discharge of, and direct contact with,
groundwater/groundwater seeps in the Western Portion of the Site.
• Municipal landfill - Since no unacceptable public health or environmental risk was
associated with this area, the remedial action goals were to ensure future
migration of groundwater would not present a threat to the river and adequate
cover is present to prevent erosion resulting in a direct contact threat or washout
of the wastes to the river.
Consistent with the remedial action goals, three operable units were developed for the Site: OU1 - the
Eastern Portion Municipal Landfill; OU2 - Western Portion Soils; and OU3 - groundwater. The remedial
action alternatives described below were implemented for the operable units.
EASTERN PORTION MUNICIPAL LANDFILL OPERABLE UNIT (OU1)
The risk assessment for this area did not indicate that the contaminants present posed a threat by either
direct contact with the surface soils or by migration of groundwater to the Maumee River. Therefore, the
remedial action alternative designed for OU1 consisted of:
1) Soil cover designed for flood protection;
2) Installation of new groundwater monitoring wells;
3) Long-term groundwater monitoring; and
4) Access restrictions (fencing, warning signs, and deed restrictions).
Construction of the soil cover and installation of the monitoring wells were completed in 1994. The soil
cover consists of three soil layers. The lower layer is a 30-inch thick area of clay compacted to a
7
permeability of 1x1 0- cm/sec. The middle layer is a general fill soil area to provide frost protection for the
clay and to allow for grading to promote runoff of precipitation. The surface layer of topsoil promotes
growth of vegetation. Topsoil on steep slopes was covered with erosion control matting to prevent
excessive erosion prior to the vegetation taking root. Rip rap was placed from the river channel to the
1OO-year flood level.
WESTERN PORTION SOILS (O1l2) and GROUNDWATER (OU3)
Western Portion Soils (OU2) and Groundwater (OU3) were combined in the remedy description portion of
the ROD because the groundwater on the Western Portion required treatment and groundwater on the
Eastern Portion did not. The Western Portion of the Site is where industrial, wire, liquid, and incinerator
wastes were deposited. A large pit where liquid wastes were dumped was also located in this area, as
were areas of buried drums. The remedial action alternative designed for OU2 and OU3 consisted of:
1) Excavation of approximately 4,600 drums 1;
2) Incineration of drummed wastes;
3) Reconsolidation of soils/wastes on-site;
4) Soil cover;
1 This number of drums was an estimate made during the RifFS. Once excavation began, more drums
were discovered. This is discussed in the following section.
165) Groundwater collection and treatment;
6) Flood protection and wetlands protection; and
7) Access restrictions (fencing, warning signs, and deed restrictions).
Based on the ROD, the Remedial Design was prepared for construction of the remedy. A Consent
Decree (CD) was lodged on February 22, 1989, which called for implementation of the Remedial
Design/Remedial Action. The RD was completed in December 1989. Construction of the RA began in
July 1991 and was completed in October 1994.
Remedy Implementation
Eastern Portion - Landfill Cover
The Remedial Action for the Eastern Portion of the Site consisted of installing a Subtitle D landfill soil
cover. Construction of the cap was performed from July 1991 through October 1991. Approximately
h 1n
130,000 cubic yards of soil was transported to the Site and placed between July i and October 15 ,
1991. The soil cover consisted of a 30-inch thick clay cover compacted in 6-inch lifts. On top of the clay
layer, a layer of general fill approximately 18 inches thick was placed to allow for grading and provide frost
protection for the clay. Topsoil was used to cover disturbed areas and a vegetative cover was sown over
all disturbed areas to prevent erosion. Rip rap was placed along the Maumee River bank to the 100-year
flood level.
New groundwater monitoring wells were installed around the Eastern Portion and groundwater samples
were collected quarterly in 1991 and 1992 in order to establish a baseline and then semi-annually in 1993
and 1994. Based on the results of these samples, no additional groundwater sampling was deemed
necessary for the Eastern Portion of the Site.
Western Portion - Phase I and Phase /I
The Phase I and Phase II construction activities consisted of installation of a geotextile wall, a bio-polymer
collection trench. and a vibrated beam vertical barrier. These activities were performed from September
1992 through December 1992. Phase I activities included construction of diversion berms, fence
installation (on both the Eastern and Western Portions), and general Site preparation. Phase II activities
included the construction of approximately 255 linear feet of geotextile retaining wall and installation of a
1,200-feet long by 35-feet wide working platform along the south bank of the Maumee River to limit
erosion. A bio-polymer collection trench, 1,210 feet in length, was installed to collect impacted
groundwater for treatment on Site. The trench reaches down to the top of the New Holland Till, varying in
depth from 14 to 34 feet below ground surface. Three extraction wells were installed. Approximately
1,210 linear feet of vibrated beam vertical barrier was constructed between the collection trench and the
Maumee River to minimize recharge into the trench from the river. The vertical barrier is keyed at least 18
inches into the New Holland Till and is approximately 4% inches wide.
Western Portion· Phase //I Drum Removal
Phase III construction activities consisted of excavation of drums with appropriate disposal of contents.
Two areas were identified which contained drums within the Western Portion of the landfill: Area A
(located on the east side) and Area B (located on the west side).
Approximately 8,700 intact drums and approximately 1,900 drums that were not intact or empty were
excavated from Area A. Area A encompassed approximately 41,000 square feet and remedial activities
were performed from April through October 1993. Approximately 13,800 intact drums and approximately
3,800 not intact or empty drums were excavated from Area B. Area B encompassed approximately
99,500 square feet and remedial activities were performed from February through April 1993 and from
October 1993 through August 1994.
17The drums, upon excavation, were documented, sampled, and stored on-site. When sample results were
received, the drums were emptied into roll-off boxes (if solid material) or storage tanks (if liquid) on-site.
Drum contents were consolidated with similar waste from other drums. The consolidated material was
sampled for disposal criteria, manifested, and shipped to an appropriate disposal facility. After a drum
was determined to be "RCRA empty," its carcass was crushed and buried in areas that had already been
excavated free of drums. The number of drums excavated was much higher than originally estimated in
the RI/FS. It should be noted that drums were not found outside the general boundaries of Areas A and S,
described above.
Western Portion - Soil Cover
A hybrid RCRA landfill soil cover was installed on the Western Portion of the Site. Construction of the
cover consisted of rough grading of the Site to obtain the appropriate slope. A drainage blanket was
constructed which consisted of 12 inches of crushed limestone covered on top and bottom with a
geotextile. This drainage blanket was tied in directly to the collection trench and was installed along the
river to intercept any potential seeps. The entire Western Area was then covered by a cohesive soil layer
consisting of silty clay to a depth of 30 inches on gentle slopes and 36 inches on steeper slopes. Rip rap
was then placed in ditches and along the bank of the Maumee River. Four to six inches of topsoil was
then placed over the entire Site and the area was seeded. The cover was constructed from July 1994
through October 1994.
Western Portion - Groundwater Management System
The groundwater management system was installed at the Site to collect and treat impacted groundwater
from the collection trench and to prevent groundwater from discharging to the Maumee River.
Groundwater is collected from the collection trench via the three extraction wells and is pumped to a
20,000-galion capacity holding tank located adjacent to the treatment building, located at the southwest
corner of the Site. The treated groundwater is then discharged via a sanitary sewer line to the City of Fort
Wayne Wastewater Treatment Plant for final treatment and disposition.
The original remedial design called for water to be treated via air stripping and granular activated carbon
(GAC). However, based on a review of the system's operation and monitoring data, this treatment train
was modified in 2001. It was determined that running the collected groundwater through both the air
stripper and GAC unit was no longer necessary and that treatment via GAC alone was sufficient to attain
the response action objectives. The groundwater management system has been monitored to ensure that
permit compliance is met and discharge monitoring reports are provided to EPA, the Indiana Department
of Environmental Management (IDEM) and the Fort Wayne City Utilities Water Pollution Control Plant.
Additional modifications to the groundwater management system are envisioned and this will be discussed
under the System Operation/Operation and Maintenance Section of this report.
Institutional Controls
Institutional controls (ICs) are non-engineered instruments such as administrative and legal controls.
They are designed to minimize the potential for human exposure to contamination and to protect the
integrity of the remedy. ICs are required for any areas which do not allow for unlimited use or unrestricted
exposure to humans. In order to limit the potential for human exposure to contaminated media, the 1988
ROD determined that deed restrictions would be required to control future property use and prohibit the
use of groundwater or the installation of wells on-site for a water supply source.
Status of ICs and Follow-up Actions Required
As part of this five-year review, EPA has reviewed the ICs in place at the Site. A "Declaration of
Environmental Restrictive Covenants" was recorded on May 29,2002, by SCA Services Inc., then owner
18and successor by statutory merger to National Recycling Corporation, in the Allen County Auditor's Office.
Waste Management acquired SCA Services in 1984 and is the current owner of the 35-acre Site. This
notice defines the Site property and imposes limitations on Site access and future uses of the property for
the protection of human health and the environment. The restrictions on use include the following:
• Groundwater Use: Groundwater on or under the Property shall not be used for any
purpose except as approved by governmental authority;
• Surface Water Use: Surface water on or under the Property shall not be used for any
purpose except as approved by governmental authority;
• Drinking Water Wells: No drinking water wells shall be installed or allowed to be installed
on the Property; and
• Compliance with Environmental Laws: The Property shall not be used in any way that is
inconsistent with any response actions, laws or regulations applicable to the Property from
time to time.
A copy of the Declaration of Environmental Restrictive Covenants can be found in Appendix A
The following table identifies those areas that do not support unlimited use and unrestricted exposure
(UUlUE) at the Site:
Table 2 - nstltutlonal Controls Summary Table
Media, EngiIhMrid ,: . . ". .s;. .- . -: .. ...~ ;. _. :..~'
Controls, andArNs ....
do not eupport UUIUE lCObjectives and ;?TItI8:0ffC;'~.nt
It\'IPi8meri1ed·
··.·R.qutteci.~ii'.i.
.... . '.
.'.~
Based on Current Restrictions . r
Conditions .... : . . . .
I Groundwater at the Site Prohibit use of Declaration of Yes
, (approximately 35 acres) groundwater except as Environmental Restrictive
approved by the Agencies Covenant
and prohibit drinking water (implemented)
well installation
Surface water at the Site Prohibit use of surface Declaration of Yes
(approximately 35 acres) water except as approved Environmental Restrictive
Covenant
(implemented)
Landfill area Prohibit residential Declaration of Yes
(approximately 35 acres) development; prohibit Environmental Restrictive
interference with cap or Covenant (implemented as
other response measures; to interference with
prohibit exposure response measures but
not for restrictions on
specific uses or to
generally prohibit
exposure)
Other remedy components Prohibit interferences with Declaration of Restrictive Yes
remedy component Covenant (implemented)
To ensure the ICs remain effective and properly maintained and monitored, EPA requested that Waste
Management conduct IC evaluation activities and propose a new Environmental Restrictive Covenant
(ERC). On July 24,2009, EPA requested that Waste Management carry out specific tasks and provide
EPA additional documentation to ensure that ICs at the Site will remain effective and protective in the long
term. Specifically, EPA has requested that Waste Management's IC evaluation include, among other
tasks, the following activities:
• Providing an updated Site map with GIS information which shows the parcel boundaries
19including the groundwater collection system, the soil cover, and the municipal landfill (i.e.,
the Eastern and Western delineation of the Site). The Site map should also show the
boundaries of the Property described in the Declaration of Environmental Restrictive
Covenants which was made on April 14, 2002.
• Preparing a proposed new ERC that satisfies Indiana's statutory requirements for an
ERC. The ERC should include, at a minimum, the following: a prohibition on the use of
groundwater at the Site; a prohibition on the installation of drinking water wells at the Site;
and a prohibition on using the Site inconsistent with the response actions. The proposed
ERC should specifically detail what the Site cannot be used for (i.e., residential use).
• Providing a title insurance commitment using ALTA Commitment form 1982, as
amended, by a title company demonstrating that there are no pre-existing interests in
conflict with the use restrictions. Once the new ERC is recorded, Waste Management will
need to provide an updated title insurance commitment form to demonstrate that the new
ERC is part of the title record.
• Where not previously provided, providing documentation of governmental controls that
are currently in effect.
The IC evaluation activities are underway. Once the IC evaluation activities have been completed, EPA
will develop an IC Plan, in consultation with IDEM, to incorporate the results of the evaluation and plan
corrective measures to ensure long-term protectiveness, including, but not limited to, recording a new
ERC and updating the Operation and Maintenance (O&M) Manual to reflect IC monitoring. This will
ensure that future uses of the FWRD Site are consistent with protecting human health and the
environment.
Current Compliance: Based on the Site inspection, monitoring data, and communication with O&M
personnel, no innappropriate land or groundwater use was observed. The Declaration of Environmental
Restrictive Covenants recorded in May 2002 is currently in place and effective; EPA is not aware of site or
media uses which are inconsistent with the stated objectives of the ICs and cleanup goals. Access is
further restricted by the use of fencing. In order for the Site to be protective in the long-term, EPA will
continue to work with the PRPs to implement a new restrictive covenant to strengthen the use controls.
Long-Term Stewardship: Long-term protectiveness at the Site requires continued compliance with use
restrictions to assure that the remedy continues to function as intended. To assure proper maintenance,
monitoring, and enforcement of effective ICs, long-term stewardship procedures will be reviewed and the
O&M Manual will be revised. The manual will include a provision for regular inspection of ICs at the Site
and annual certification to EPA that the required ICs are in place and effective. Additionally, development
of a communication plan and a one-call system will be explored for long-term stewardship.
System Operations/Operation and Maintenance
On September 25, 1995, EPA and IDEM conducted the pre-final inspection at the Site. EPA determined
that the remedy was constructed according to the RD/RA specifications and signed a Preliminary Close
Out Report on September 27, 1995.
Operation and Maintenance activities have been conducted at the Site since completion of construction.
O&M activities include upkeep of the landfill cap to check for erosion, confirming that there is adequate
vegetative growth, and verification of the integrity of the fence and the rip rap along the Maumee River.
Discharge samples have been collected and analyzed, as required by the discharge permit, to verify that
the treatment system is operating properly and that the discharge is within permit limits. In addition, semi
annual groundwater monitoring is performed.
As will be discussed in greater detail in Section V of this report, the ROD did not specify site-specific
groundwater cleanup criteria to determine when the operation of the groundwater collection and treatment
system could be terminated and groundwater allowed to discharge naturally to the Maumee River. Since
20the 2004 Five-Year Review, numerous discussions have taken place concerning this matter between
representatives of EPA, IDEM, and Waste Management. A process was developed by which IDEM would
develop site-specific groundwater cleanup criteria. The monitoring data would then be reviewed to
evaluate whether the Site had achieved those criteria. Upon that determination, a temporary shutdown of
the groundwater system would occur to evaluate/confirm that the groundwater constituent concentrations
were being sustained at concentrations less than the cleanup criteria (i.e., no rebounding), as well as to
evaluate whether any adverse impacts were observed. Upon temporary shutdown of the groundwater
system, two additional confirmatory semi-annual monitoring events would take place. This confirmatory
sampling would include samples from the groundwater extraction wells (EW-1 and EW-2) and
groundwater monitoring wells (FW-1S, FW-2S, and F_21)2, located hydraulically downgradient of the slurry
wall.
The site-specific groundwater criteria were developed by IDEM, in coordination with EPA. Based on an
evaluation of the comprehensive data for the Site, IDEM's Office of Water Management Assessment
Branch calculated cleanup levels for four parameters of concern, namely, ethylbenzene, total xylenes, 4
methlyphenol, and 2,4-dimethylphenol, and transmitted those cleanup levels to Waste Management on
June 20, 2008. The site-specific criteria will be discussed in more detail in Section V, below. On June 30,
2008, Waste Management provided notification to EPA and IDEM that the results of the semi-annual
groundwater monitoring event (completed on May 13, 2008) verified that the groundwater cleanup criteria
had been attained. Based on that finding, the conditions for placing the groundwater treatment system on
shutdown, as discussed and agreed during a March 5, 2008, meeting with EPA and IDEM, were met.
Operation of the groundwater treatment system was placed on temporary shutdown on July 25, 2008, and
the system was placed in a standby mode. As agreed at the March 5, 2008, meeting, the facility would
then conduct two additional semi-annual sampling events, the first in the fall of 2008 and the second in the
spring of 2009, to confirm that the groundwater constituent concentrations are being sustained at
concentrations less than the cleanup criteria.
If these two monitoring events confirm that the groundwater constituents continue to meet the cleanup
criteria, decommissioning of the treatment system will be pursued. However, if a groundwater constituent
concentration rebounds to a concentration greater than its cleanup criteria, the treatment system would
then be reactivated and operated until the groundwater monitoring results demonstrate that the cleanup
criteria are being attained on a sustained basis.
Since specific groundwater cleanup criteria were not stipulated in the ROD, EPA will need to supplement
the ROD with an Agency decision document that articulates what the cleanup criteria are and the process
by which they were determined. A summary of the evaluation of the groundwater cleanup criteria will be
presented in the Technical Assessment Section of this report.
The process for terminating the operation of the groundwater extraction and treatment system has been
documented in an updated O&M Manual for the Site. This draft O&M Manual has been transmitted to
EPA and IDEM and is currently under review.
V. Progress Since the Last Five-Year Review
The Second Five-Year Review Report was completed for the FWRD Site on September 29,2004, and
concluded that the implemented remedy was protective of human health and the environment. The 2004
Five-Year Review concluded that:
2 Monitoring wells FW-1 S, FW-2S, and FW-21 have historically been monitored and are used to evaluate
groundwater quality at the Site. The shallow aquifer monitoring wells (FW-1S and FW-2S) are sampled to verify that
migration of constituents of concern toward the river is being prevented. The intermediate aquifer monitoring well
(FW-21) is sampled to verify that there is no downward, vertical migration of the constituents from the shallow aquifer.
21"Drums containing hazarcfous materials have been excavated and contents have been disposed
of appropriately. The groundwater collection system protects the Maumee River from the
migration of contaminated groundwater into the river at unprotective levels. Soil covers at the Site
prevent erosion that could result in a direct contact threat, or washout of the wastes into the
Maumee River."
Two issues were identified in the :2004 Five-Year Review and recommendations were made for follow-up
action. These issues, as well as follow-up actions that have been taken, are itemized in the following
table:
Table 3 - Status of Issues Identified in Previous Five-Year Review
lssuesfrOrn " ·····Recommendationsl Parf.Y Action Tak,-and< Dateo' ." .
PnMousReVieW' FoRow-up Actions Re$pe»nsible e>utc:ome '; f';··~=:.:c~"t.'
Several areas in Repair fence and well PRPs Fence was October 2004
the Site fence were casings repaired and
compromised and maintenance
well casings were performed
opened
Possible Submittal of proposal PRPs Proposal submitted June 30, 2008
termination of on- for evaluation by Waste
Site treatment of Management to
Qroundwater EPA and IDEM
As indicated above, perimeter fence repairs and other maintenance issues were addressed by Waste
Management soon after the completion of the 2004 Five-Year Review Report.
A central issue to the evaluation of the implemented remedy for the Site is the determination of when
remedial action objectives have been attained. More specifically, the issue is determining when the
operation of the Site's groundwater collection and treatment system can be terminated, thus allowing
groundwater to discharge naturally to the Maumee River.
The subject of when the operation of the groundwater collection and treatment system may be terminated
was first addressed in the Site's First Five-Year Review Report, dated July 2, 1999, which was prepared
by IDEM in coordination with EPA. In this regard, the report stated the following:
''The groundwater cleanup objectives are to provide adequate protection of human health and the
environment by limiting discharge of, and direct contact with, contaminated groundwater and
groundwater seeps. The length of operation of the collection system is related to the groundwater
cleanup objectives for the Site. In the event of future modifications to the collection system,
groundwater cleanup objectives will be developed to protect the Maumee River based on the
following criteria:
• No statistically significant increase in constituents related to groundwater discharge from
the Site will be released to surface water; and
• No statistically significant exceedance of the State of Indiana Water Quality Standard for
Surface Water resulting from groundwater discharge from the Site will be allowed."
During the 2004 Site inspection, EPA, IDEM, and Waste Management representatives discussed the need
for the development of specific groundwater cleanup criteria for the Site to assist in that determination.
Since that time, EPA, IDEM and Waste Management have participated in numerous discussions
concerning this matter.
In September 2005, IDEM requested that Waste Management submit a formal written request to modify
the groundwater collection and treatment system in operation at the Site. To begin that process, Waste
Management was instructed to include with its request a summary of at least three years of qualified
22influent and effluent data with a trend analysis. IDEM then indicated it would evaluate the request based
on the aforementioned data and would consider the following options at the Site: (1) No change to the
groundwater collection and treatment system; (2) Direct discharge of collected and treated groundwater to
the Maumee River under the guidelines of the National Pollution Discharge Elimination System (NPDES);
(3) Direct discharge of collected and untreated groundwater to the Maumee River under the guidelines of
the NPDES; and (4) Complete shut-down of the groundwater collection and treatment system allowing the
groundwater to flow naturally to the Maumee River.
IDEM then indicated it would consider the aforementioned modifications to the groundwater collection and
treatment system with the emphasis being placed on the continued protection of human health and the
environment. The criteria that were used in the evaluation are outlined in 327 lAC 2 (Indiana Water
Quality Standards). The specific provisions within the water quality standards that apply can be found in
327 lAC 2-1-6 (Minimum Surface Water Quality Standards) and 327 lAC 2-1-11 (Groundwater Quality
Standards).
Waste Management reviewed the standards identified by IDEM in its September 1, 2005, letter. Waste
Management acknowledged that the Groundwater Quality Standards appeared to be relevant to the extent
that groundwater must meet the appropriate Surface Water Quality Standards at the groundwater surface
interface. Waste Management noted that the Surface Water Quality Standards referenced by IDEM (327
lAC 2-1-6) appeared to apply to water outside the Great Lakes drainage basin, but that the Maumee River
is included in the Great Lakes drainage basin and, therefore, it would appear that the Surface Water
Quality Standards 327 lAC 2-1.5-8 would be more applicable. These standards identify methodology for
developing chemical-specific numeric criteria. However, based on Waste Management's review of the
standards and inquiry with State staff, they noted that IDEM had not yet developed such numeric criteria.
Therefore, Waste Management requested IDEM to develop the acute water quality criteria needed to
determine when the operation of the groundwater collection system at the Site could be terminated.
In May 2007, Waste Management submitted its formal written request to IDEM to develop the
groundwater cleanup criteria for the Site that would allow groundwater to discharge naturally to the
Maumee River. The request was supported by a tabulation and analysis of groundwater monitoring data
to show the extent of groundwater cleanup achieved. Waste Management included a compilation and
summary of historic information that established the basis for the requirement of a remedy to manage
groundwater on the Western Portion of the Site to mitigate potential acute toxicity risk to aquatic
organisms via the groundwater to surface water exposure pathway. Waste Management also included
groundwater monitoring data that illustrated the improvement in groundwater quality that has been
accomplished since operation of the groundwater collection and treatment system began in 1995.
As indicated in the ROD, the most significant exposure concern associated with the groundwater pathway
was the potential acute toxicity to aquatic organisms due to contaminated groundwater migrating from the
Site to the Maumee River. As a result, IDEM's Office of Water Management Assessment Branch
concluded that the follOWing cleanup levels for contaminated groundwater should be attained to provide
adequate protection of the Maumee River:
o Ethylbenzene 2000 1J9/L
o Total Xylenes 626 1J9/L (or 630 1J9/L if rounded to two significant figures)
o 4-Methylphenol 962 IJg/L (or 960 IJg/L if rounded to two significant figures)
o 2-4-Dimethylphenol 2700 1J9/L
The above groundwater cleanup criteria were transmitted to Waste Management in a June 20, 2008,
correspondence from IDEM.
A discussion of this data analysis will be presented in the Document and Data Review Section of this Five
Year Review Report.
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