HRS DOCUMENTATION RECORD--REVIEW COVER SHEET

Name of Site: Gary Development Landfill

Contact Persons

Site Investigation: Mark Jaworski, Indiana Department of Environmental Management (IDEM), Site

Investigation, (317) 233-2407

Documentation Record: Pat Hamblin, United States Environmental Protection Agency (EPA), Region V, 

(312) 886-6312

Mark Jaworski, IDEM, Site Investigation, (317) 233-2407

Pathways, Components, or Threats Not Scored

The ground water migration pathway, the soil exposure pathway, the air pathway, and the drinking water 

threat and human food chain threat of the surface water pathway were not scored as part of this Hazard Ranking 

System (HRS) evaluation. These pathways/components were not included because a release to these media does not 

significantly affect the overall site score and because the environmental threat component of the surface water 

migration pathway produces an overall site score above the minimum required for the site to qualify for inclusion on 

the National Priorities List (NPL). 
1

HRS DOCUMENTATION RECORD

Name of Site: Gary Development Landfill

EPA Identification No.: IND077005916

EPA Region: 5

Date Prepared: March 2011

Street Address of Site: 479 N. Cline Avenue* (Refs. 62, p. 004; 148)

County/State/Zip Code: Lake County, Indiana, 46406

General Location in the State: Northwestern Indiana (Ref. 3)

Topographic Map: Highland, Indiana Quad (7.5’) (Ref. 3)

Latitude: 41° 36’ 50.62”N

Longitude: 87° 25’ 35.21”W

Site Reference Point: Approximate center of the source area

Congressional District: 01

* Note: The street address, coordinates, and contaminant locations presented in this HRS documentation 

record identify the general area the site is located. They represent one or more locations EPA considers to 

be part of the site based on the screening information EPA used to evaluate the site for NPL listing. EPA 

lists national priorities among the known "releases or threatened releases" of hazardous substances; thus, 

the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous 

substance has been "deposited, stored, placed, or otherwise come to be located." Generally, HRS scoring 

and the subsequent listing of a release merely represent the initial determination that a certain area may 

need to be addressed under the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at the 

time of scoring will be refined as more information is developed as to where the contamination has come to 

be located. 

SITE SCORING SUMMARY

Pathway Scores:

Air Pathway NS

Ground Water Pathway NS

Soil Exposure Pathway NS

Surface Water Pathway 60.00

HRS SITE SCORE 30.00
2

WORKSHEET FOR COMPUTING HRS SITE SCORE

S S2

1. Ground Water Migration Pathway Score (Sgw)

 (from Table 3-1, line 13) NS

2a. Surface Water Overland/Flood Migration Component

 (from Table 4-1, line 30)

60.00 3600.00

2b. Ground Water to Surface Water Migration Component NS

2c. Surface Water Migration Pathway Score (Ssw)

 Enter the larger of lines 2a and 2b as the pathway score.

60.00 3600.00

3. Soil Exposure Pathway Score (Ss NS

4. Air Migration Pathway Score (Sa) NS

5. Total of Sgw2 + Ssw2 + Ss

2 + Sa2

3600.00

6. HRS Site Score

Divide the value on line 5 by 4 and take the square root

30.00
3

TABLE 4-1

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categories and Factors Maximum Value Value Assigned

DRINKING WATER THREAT

Likelihood of Release

1. Observed Release 550 550

2. Potential to Release by Overland Flow

2a. Containment 10

2b. Runoff 25

2c. Distance to Surface Water 25

2d. Potential to Release by Overland Flow

 (lines 2a x (2b + 2c)) 500

3. Potential to Release by Flood

3a. Containment (Flood) 10

3b. Flood Frequency 50

3c. Potential to Release by Flood

 (lines 3a x 3b) 500

4. Potential to Release

 (lines 2d + 3c, subject to a maximum of 500) 500

5. Likelihood of Release 

(higher of lines 1 and 4) 550 550

Waste Characteristics

6. Toxicity/Persistence a NS

7. Hazardous Waste Quantity a NS

8. Waste Characteristics 100 NS

Targets

9. Nearest Intake 50 NS

10. Population

10a. Level I Concentrations b NS

10b. Level II Concentrations b NS

10c. Potential Contamination b NS

10d. Population 

(lines 10a + 10b + 10c) b NS

11. Resources 5 NS

12. Targets (lines 9 + 10d + 11) b NS

Factor Categories and Factors Maximum Value

DRINKING WATER THREAT (Concluded)

Drinking Water Threat Score

13. Drinking Water Threat Score

((lines 5 x 8 x 12)/82,500, subject to a maximum of 100) 100 NS

a Maximum value applies to waste characteristics category.

b Maximum value not applicable. c Do not round to nearest integer.
4

HUMAN FOOD CHAIN THREAT

Likelihood of Release

14. Likelihood of Release

(same value as line 5) 550 NS

Waste Characteristics

15. Toxicity/Persistence/Bioaccumulation a NS

16. Hazardous Waste Quantity a NS

17. Waste Characteristics 1,000 NS

Targets

18. Food Chain Individual 50 NS

19. Population

 19a. Level I Concentrations b NS

19b. Level II Concentrations b NS

19c. Potential Human Food Chain Contamination b NS

19d. Population 

(lines 19a + 19b + 19c) b NS

20. Targets (lines 18 + 19d) b NS

Human Food Chain Threat Score

21. Human Food Chain Threat Score

((lines 14 x 17 x 20)/82,500, subject to a maximum of 

100) 

100 NS

Factor Categories and Factors Maximum Value Value Assigned

ENVIRONMENTAL THREAT

Likelihood of Release

22. Likelihood of Release

(same value as line 5) 550 550

Waste Characteristics

23. Ecosystem Toxicity/Persistence/

Bioaccumulation a 500,000,000

24. Hazardous Waste Quantity a 10,000

25. Waste Characteristics 1,000 1,000

Targets

26. Sensitive Environments

26a. Level I Concentrations b 0

26b. Level II Concentrations b 100

26c. Potential Contamination b 0

26d. Sensitive Environments 

(lines 26a + 26b + 26c) b

27. Targets (value from 26d) b 100

Environmental Threat Score

28. Environmental Threat Score

((lines 22 x 25 x 27)/82,500, subject to a maximum of 60) 60 60.00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE FOR A WATERSHED

29. Watershed Scorec

(lines 13 + 21 + 28, 

subject to a maximum of 100)

100 60.00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE

30. Component Score (Sof)

c

, 

 (highest score from line 29 for all watersheds evaluated, 

subject to a maximum of 100)

100 60.00

a Maximum value applies to waste characteristics category. b Maximum value not applicable.

c Do not round to nearest integer.
This map is intended to serve as an aid in

graphic representation only. This information

is not warranted for accuracy or other purposes.

Mapped By:Mike Hill, Office of Land Quality

Date:2/18/2009

Sources:

Non Orthophotography Data

- Obtained from the State of Indiana Geographic

Information Office Library

- Approximate Site Boundary based on Lake County

parcels.

Parcel ID: 45-03-35-301-003.000-004 15.777 acres

Parcel ID: 45-03-35-326-001.000-004 5.9 acres

Parcel ID: 45-03-35-326-002.000-004 40 acres

(Ref. 149, pp. 1-5)

Orthophotography - Obtained from IndianaMap Framework Data

(www.indianamap.org)

Map Projection: UTM Zone 16 N Map Datum: NAD83

Site Location Map, Gary Development Landfill

Gary, Lake County, Indiana (U.S. EPA ID: IND077005916)

μ Lake

County

Illinois

Indiana

Lake

Michigan

Site Vicinity Lake County, IN

E

Grand Calumet River

Latitude: 41°36'50.62" N

Longitude: 87°25'35.21" W

I-90 E

SR 912

I-90 W

Cline Ave

Gary Ave

0 1 75 50 Meters

0 5 250 00 Feet

Approximate Site Boundary

Approximate Center of Site E

Figure 1-1

5
Sources:

Non Orthophotography Data

- Obtained from the State of Indiana Geographic

Information Office Library

(Ref. 115, pp. 1,2 - PPE; Ref. 131 p. 1 - PEMF Wetland;

Ref. 153 p. 1)

Orthophotography - Obtained from IndianaMap Framework Data

(www.indianamap.org)

Map Projection: UTM Zone 16 N Map Datum: NAD83

Current Site Features (2005), Gary Development Landfill

Gary, Lake County, Indiana (U.S. EPA ID: IND077005916)

μ Lake

County

Illinois

Indiana

Lake

Michigan

Site Vicinity Lake County, IN

!

Grand Calumet River

Approximate Site Boundary

! Probable Point of Entry (PPE) - 1989

Wetland Classified PEMF

0 50 100 Meters

0 250 500 Feet

Former Plant Buildings

Methane Vent

Area

PPE

PEMF Wetland Area

North Retention Pond

Haul Road

This map is intended to serve as an aid in

graphic representation only. This information

is not warranted for accuracy or other purposes.

Mapped By:Mike Hill, Office of Land Quality

Date:8/9/2010

I-90 W

Figure 1-2 6
!

E2QS2

ME2QR3

PPE - 1989

This map is intended to serve as an aid in graphic representation only. This information is not warranted for accuracy or other purposes.Mapped By:Mike Hill, Office of Land QualityDate:5/25/2010

Sources:Non Orthophotography Data

- Unpermitted Discharge Point location obtained fromthe State Land Office, 1989 Digital Aerial PhotographyOrthophotography - Obtained from IndianaMap Framework Data

(2005 Digital Orthophotography)(www.indianamap.org)

Map Projection: UTM Zone 16 N Map Datum: NAD83

! Probable Point of Entry (PPE) - 1989

Sediment Sample LocationSediment Sample Delineation

Grand Calumet River

Wetland Frontage Map, Gary Development Landfill

Gary, Lake County, Indiana (U.S. EPA ID: IND077005916)

0 5 10 Meters0 25 50 Feet

Contaminated Area:.0955 acres4,159.98 square feet(Ref. 121, pp. 27, 28, 29; Ref. 115, p. 1)

169.92'

185.89'

84.70'

91.81'

Wetland Frontage

169.92’ + 91.81’ + 84.70’ + 185.89’ = 532.32’

Figure 1-3 7
8

REFERENCES

Reference

Number Description of the Reference

1. EPA, Hazard Ranking System, Final Rule, 55 FR 51532, December 14, 1990. 

http://www.epa.gov/superfund/sites/npl/hrsres/index.htm. 138 pages.

2. EPA, Superfund Chemical Data Matrix (SCDM), January 28, 2004. 414 pages. A complete 

copy of SCDM is available at http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm 

3. U. S. G. S, Highland, Indiana Quadrangle Topographic Map, 1998. 1 page.

4. Reference Reserved

5. Reference Reserved

6. Indiana State Archives, 6440 E. 30th St., Indianapolis, Indiana 46219, Aerial Photo Lake 

County, Aerial Photo # 03-04, Spring 1986. 1 page.

7. Indiana Department of Environmental Management, E-mail correspondence, Marty Maupin, 

2-15-10. 1 page.

8. Indiana State Archives, 6440 E. 30th St., Indianapolis, Indiana 46219, Aerial Photo Lake

County, Aerial Photo # 89-45-3, 5-11-89. 1 page.

9. Reference Reserved

10. Indiana Geological Survey (IGS) - Indiana Historical Aerial Photo Index (IHAPI), Aerial 

Photo Lake County, 1973. 1 page.

11. Matt Klein, Indiana Department of Environmental Management, letter to Mike Mikulka 

enclosing pictures of a November 19, 1996 site visit, U.S. EPA, 1-27-97. 15 pages.

12. State of Indiana, Indiana Department of Environmental Management, Water Pollution

Control Board, Emergency Order of the Commissioner, Cause No. B-1357, 10-18-90. 

3 pages.

13. State of Indiana, Indiana Department of Environmental Management, Water Pollution 

Control Board, Final Order of the Water Pollution Control Board, Cause No. 90-W-J-428, 3-

23-1994. 14 pages.

14. EPA, Aerial Photographic Analysis of Gary Development Landfill, Gary, Indiana, 

TS-AMD-85606-8, September 1985. 13 pages.

15. State of Indiana, Settlement Agreement and Recommended Agreed Order, Cause No. N-53, 

2-28-83. 10 pages.

16. State of Indiana, Gary Development Company, Inc. vs. Indiana Environmental Management 

Board, Cause No. N-146, 4-1-85. 11 pages.

17. Reference Reserved

18. LTV Steel Company, Certification and Attestation of Copies of Official Records, Carl 

Broman, 11-20-87. 2 pages. 

19. Gary Development Co. Inc., Certification of Releases from Solid Waste Management Units, 

Lawrence Hagen, 3-5-86. 2 pages. 
9

20. State of Indiana, State Board of Health, Office Memorandum of observations, Richard T. 

Jones, 2-6-86. 2 pages.

21. EPA, Jonathan Cooper, Hydrologist, IL/IN RCRA unit, response to letters of request, 12-

18-86. 2 pages. 

22. IDEM, Office of Enforcement, Matthew T. Klein, A compilation of events that occurred at 

the Gary Development Site from January 1970 through May 19, 1995. 101 pages.

23. PRC Environmental Management, Inc., Compliance Evaluation Inspection, 4-27-92. 

64 pages. 

24. EPA, Ron Kovach, 12-11-90 Boat Tour, 12-24-90. 8 pages.

25. Reference Reserved

26. Indiana State Board of Health, RCRA Facility Review for Solid Waste Management Units, 

Gary Mills, 1-15-86. 8 pages.

27. EPA, cover letter from Ecology and Environment, Inc. Potential Hazardous Waste Site 

Inspection Report and PA, (EPA Form 2017-13), Paul Hess, 1-6-84. 21 pages. 

28. Bose McKinney & Evans, Correspondence and Civil Penalty Check for $86,000, 8-13-97. 

5 pages. 

29. Bose McKinney & Evans, Correspondence, Trust Agreement, and copy of $20,000 check, 

8-28-97. 41 pages. 

30. EPA, Preliminary Review Report, RCRA Facility Assessment, Cindy Deal, 4-20-87. 

24 pages. 

31. IDEM, Terry F. Gray, Memorandum of Request for Information, 7-16-85. 4 pages.

32. IDEM, TSD-RCRA Inspection Report, Bob Blaesing, 2-1-95. 36 pages.

33. IDEM, Rick Roudebush, TSD-RCRA Inspection Report, 1-13-93. 31 pages. 

34. IDEM, TSD-RCRA Inspection Report, Ted Warner, 6-8-90. 4 pages. 

35. Reference Reserved

36. Reference Reserved

37. Indiana State Board of Health, Karl J. Klepitsch Jr., Certified Letter, 3-18-85. 3 pages. 

38. IDEM, Bob Blaesing, Photo Log for Gary Development Landfill, December 1991. 8 pages.

39. IDEM, Bob Blaesing, Photo documentation, September 26 1996. 6 pages. 

40. State of Indiana, Petition for Administrative Review, December 1992. 8 pages.

41. Reference Reserved

42. IDEM, Sediment Sample Location and Wetland Classified as PEMF Map, May 2010. 

1 page.

43. IDEM, Marty Maupin, resume, February 15, 2010. 1 page.
10

44. IDEM, Marty Maupin, E-Mail to Mark Jaworski, resume, February 17, 2010. 2 pages.

45. Lake County Surveyor, Indiana, Mapping Reference Department E-Brochure, February 24, 

2010. 6 pages.

46. IDEM, Sampling Field Sheets and Placards, May 2009. 81 pages.

47. U.S. EPA, Site Assessment Report for Gary Development Landfill, June 2002. 121 pages. 

48. U.S. EPA, Deferral to CERCLA, August 1997. 2 pages.

49. U.S. EPA, Potential Hazardous Waste Site, Preliminary Assessment, EPA Form 2070-12, 6-

5-81. 3 pages.

50. Reference Reserved

51. Ecology and Environment, Inc., Kerry Reyes, Memorandum, October 9, 1991. 2 pages.

52. Ecology and Environment, Inc., Paul Hess, Memorandum with Attachments, January 24, 

1984. 32 pages.

53. Indiana State Board of Health, Issuance of Amendment to Construction Plan Permit SW133, 

2-16-82. 2 pages.

54. U. S. Department of Justice, Joshua Levin, Letter and Consent Decree as attachment, 

August 6, 1997. 35 pages.

55. American Chemical Service, Inc., James Tarpo, Cover Letter and Hazardous Waste 

Manifests, July 3, 1985. 38 pages.

56. Indiana State Board of Health, Issuance of Operating Permit SW133, 2-16-82. 6 pages.

57. IDEM, David D. Lamm, EPA Referral, January 22, 1992. 9 pages.

58. U.S. EPA, Michael J. Mikulka, Correspondence with Attachments, September 2, 1997. 

37 pages.

59. Reference Reserved

60. Indiana State Board of Health, Jim King, Geologic Description and Evaluation, December 6, 

1977. 5 pages. 

61. IDEM, Ted F. Warner, Trip Report for the scheduled Inspection of April 28, 1988, June 2 

1988. 14 pages. 

62. U.S. EPA, Hazardous Waste Permit Application. 11-18-90. 6 pages.

63. Indiana State Department of Health, Generator Annual Report, Date not Reported. 1 page.

64. Indiana State Department of Health, Generator Annual Report, 6-8-86. 1 page.

65. Industrial Disposal Corporation, Waste Tracking Forms. Various dates from 5-25-82 

through 11-1-82. 8 pages.

66. J&L Steel Corporation, Hazardous Waste Manifests, 7-11-82. 2 pages.
11

67. State of Indiana, Certification and Attestation of Copies of Official Records, 6-27-91. 

2 pages.

68. Indiana State Board of Health, Gary Development Landfill Inspection Reports and Pictures, 

1985 through 1996. 131 pages.

69. Indiana State Board of Health, Oral H. Hert, Approval of Proposal for Sanitary Landfill 

Operation, 6-21-73. 2 pages.

70. IDEM, Ted Warner, Trip Report for the Scheduled Inspection, 7-10-90. 8 pages.

71. PRC, Compliance Evaluation Inspection, 4-27-92. 57 pages.

72. IDEM, Jack Brunner, Photographs of Gary Development Landfill, 2-18-92. 4 pages.

73. U.S. EPA, GPRA – “Not-Under-Control” Status, 3-1-01. 4 pages.

74. Bose, McKinney, & Evans, Execution of Trust Agreement, 8-25-97. 30 pages.

75. IDEM, Ted Warner, Scheduled Inspection, 11-17-86. 5 pages.

76. IDEM, Ted Warner, Photograph Logs, 7-9-87. 1 page. 

77. Indiana State Board of Health, Jeffrey Stevens, Proof of Financial Assurance for 

Closure/Post Closure, 3-29-85. 1 page.

78. IDEM, Ted Warner, Photo Documentation Logs, 3-7-91, 10 pages. 

79. State of Indiana, Petitioner’s First Set of Interrogatories Requests for Admissions, and 

Request of Production of Documents, 8-25-82. 21 pages.

80. J&L Steel, Hazardous Waste Manifests, 1980 through 1982. 356 pages. 

81. State of Indiana, Respondent’s Answers to Petitioner’s First Set of Interrogatories, Request 

for Admissions, and Requests for the Production of Documents, 9-27-82. 25 pages.

82. Indiana State Board of Health, Renewal of Operating Permit, 2-16-82. 3 pages.

83. Indiana State Board of Health, Issuance of Amendment to Construction Plan Permit, 

2-16-82. 2 pages.

84. IDEM, Ted Warner, Office Memorandum, 9-9-87. 2 pages.

85. IDEM, Bob Blaesing/Mike Mikulka, Photograph Logs, 9-26-96. 8 pages.

86. Barnes and Thornburg, Petitioner’s Answers to Respondents First Set of Interrogatories, 

Requests for Admissions and Requests for the Production of Documents, 12-6-82. 18 pages.

87. State of Indiana, Recommended Consent Decree, 2-16-83. 11 pages.

88. IDEM, Meeting Minutes, 3-10-00. 10 pages.

89. U.S. EPA, Mirtha Capiro, E-mail Memo, 8-27-99. 1 page.

90. Indiana State Board of Health, Office Memorandum, 11-12-76. 3 pages.

91. Ecology and Environment, Inc., Executive Summary, 10-9-91. 2 pages. 
12

92. IDEM, Bob, Martin, Hydro-Geologic Assessment, 3-23-10. 110 pages.

93. IDEM, Matt Klein, water-specific inspection report for the September 26, 1996 inspection 

of the GDC Landfill, 11-7-96. 20 pages.

94. U. S. EPA, RCRA Inspection at Gary Development Company, Inc., 10-16-96. 3 pages. 

95. U. S. Fish and Wildlife Service, An Assessment of Injury to Human Uses of Fishery 

Resources in the Grand Calumet River, Indiana Harbor Canal, the Grand Calumet River 

Lagoons, and Indiana Harbor, and the Nearshore Areas of Lake Michigan, Volume I, 

Donald D. MacDonald, et. al., February 2003. 495 pages.

96. Reference Reserved

97. Indiana State Board of Health, Guinn Doyle, Correspondence, 5-1-85. 2 pages.

98. Barnes and Thornburg, EPA Hazardous Waste Treatment Storage and Disposal General 

Questionnaire and Hazardous Waste Landfill Questionnaire, 1-24-83. 2 pages. 

99. Indiana State Archives, 6440 E. 30th St., Indianapolis, Indiana 46219, Aerial Photo Lake 

County, Aerial Photo # 45-3-81, 5-11-1975. 1 page.

100. U. S. G. S, Whiting, Indiana Quadrangle Topographic Map, 1998. 1 page.

101. IDEM, Mike Hill, Measurement method for 15-Mile Surface Water Pathway and Surface 

Water Pathway Measurement Map, 11-30-10. 2 pages.

102. U. S. Fish and Wildlife Service, An Assessment of Sediment Injury in the Grand Calumet 

River, Indiana Harbor Canal, Indiana Harbor, and the Near Shore Areas of Lake Michigan, 

Volume III, Donald D. MacDonald, et. al., October 2000. 167 pages.

103. U. S. EPA, Decision and Order, April 8, 1996. 66 pages.

104. Reference Reserved.

105. USEPA, Post Hearing Brief, Docket Number RCRA-V-W-86-45. 14 pages.

106. IDEM, Stuart Miller, Photograph logs, 9-30-96. 15 pages. 

107. Reference Reserved

108. IDEM, Survey Results, Duane Leith, 7-24-87. 1 page.

109. Indiana State Board of Health, Duane A. Leith, 2-25-86. 4 pages.

110. IDEM, Verification of Inspection, Robert Blaesing, 2-1-95. 2 pages.

111. Reference Reserved

112. IDEM, Preliminary Determination, James M. Hunt, 1-13-93. 32 pages.

113. Lake County Surveyor, E-Mail with Attachments, Gregory M. White, 9-29-09. 5 pages.

114. IDEM, Probable Point of Entry Reference Points for Gary Development Landfill Site, 

2-16-10. 3 pages.

115. IDEM, E-Mail describing the Intersection Method for PPE Location, Mike Hill, 8-3-10. 

3 pages.
13

116. Indiana Geographic Information, Inc., Lake County 2005 Map, Mike Hill, 2005. 2 pages.

117. IDEM, Affidavit of Bruce Palin, Bruce Palin, 12-14-10. 3 pages.

118. IDEM, Affidavit of Mark Jaworski,, Mark Jaworski, 4-6-10. 1 page.

119. Indiana State Board of Health, Scheduled Inspection of Gary Development Company, Inc., 

Ted Warner, 7-29-85. 4 pages.

120. Reference Reserved

121. IDEM, Expanded Site Inspection, Mark Jaworski, (Part A), 11-18-09. 196 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part B), 11-18-09. 731 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part C), 11-18-09. 532 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part D), 11-18-09. 536 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part E), 11-18-09. 464 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part F), 11-18-09. 624 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part G), 11-18-09. 589 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part H), 11-18-09. 686 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part I), 11-18-09. 862 pages.

IDEM, Expanded Site Inspection, Mark Jaworski, (Part J), 11-18-09. 1396 pages.

 

122. IDEM, Office Memorandum, Craig Pender, 11-17-2009. 9 pages.

123. IDEM, Table Summarizing Documented Hazardous Waste Received at the Gary 

Development Landfill, 8-31-10. 15 pages.

124. EPA, Great Lakes National Program Office, Web Site Pages, 2-24-09. 13 pages.

125. IDEM, Office Memorandum, Mike Hill, 7-14-10. 1 page.

126. Tennessee Department of Health, Coal Fly Ash Release Fact Sheet, 2-13-09. 4 pages.

127. NIOSH, Hazard Evaluation and Technical Assistance Report No. 94-0020, 10-25-93. 

36 pages. 

128. IDEM, Office Memorandum, Craig Pender, 8-18-10. 5 pages.

129. EPA, Regional Transmittal Form, 6-10-09. 11 pages.

130. EPA, Review of Data, 5-29-09. 61 pages.

131. IDEM, E-Mail Document, Marty Maupin, 8-31-10. 1 page.

132. Indianapolis Water Company, Affidavit of Matt Klein, 1/28/10. 1 page

133. Roy F. Weston, Remedial Planning Activities at selected Uncontrolled Disposal Sites, 

U.S. EPA contract No. 68-W8-0089, September 1995. 110 pages.

134. Ecology and Environment, Inc., Preliminary Assessment, Executive Summary, Roland 

Dump Site, U.S. EPA ID: IND980500557, September 30, 1991. 14 pages.

135. Roy F Weston, Site Implementation Plan for Site No. 95, U.S. EPA ID: IND980500151, 

August 1995. 53 pages.

136. Ecology and Environment, Inc., Preliminary Assessment, Gary Municipal Airport, EPA ID: 

IND067469437, September 30, 1991. 36 pages.
14

137. Roy F. Weston, Focused Site Screening Inspection Prioritization Report, Conservation 

Chemical Company, November 23, 1994. 117 pages.

138. U.S. EPA, Five-Year Review Report, Ninth Avenue Dump Superfund Site, June 14, 2010. 

31 pages. 

139. U.S. EPA, Fact Sheet MIDCO I, EPA ID: IND980615421, October 15, 2010. 4 pages.

140. U.S. EPA, Fact Sheet MIDCO II, EPA ID: IND980679559, October 15, 2010. 4 pages.

141. IDEM, Robert Martin, E-Mail to Mark Jaworski, December 6, 2010, 1 page.

142. IDEM, Mike Hill, Background Sediment Sample Location with Measurement to PPE, 

12/6/10, 2 pages.

143. U.S. EPA Contract Laboratory Program, National Functional Guidelines for Inorganic 

Superfund Data Review, January 2010, Excerpt, 7 pages.

144. U.S. EPA Contract Laboratory Program, Statement of Work for Organics Analysis, May 

2005, Excerpt, 34 pages.

145. EPA, Quick Reference Fact Sheet, Using Qualified Data to Document an Observed Release

and Observed Contamination, November 1996, 18 pages.

146. IDEM, Potential Sources, 10-24-10, 1page.

147. Macbeth Division of Kollmorgen Instruments Corporation, Munsell Color Chart, 1994. 

148. U.S. EPA, Search Superfund Site Information, 

http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0501517, February 8, 2011, 1 page.

149. IDEM E-Mail to Mark Jaworski from Mike Hill with four attachments, August 5, 2010, 5 

pages. 

150. IDEM, E-Mail from Bruce Palin to Mark Jaworski Regarding a Waiver to Release Ref. 22 to 

the Public, January 21, 2011, 1 page. 

 

151. Bing, AMG Resource Corp., January 24, 2011, 1 page.

152 . IDEM, E-Mail to Mark Jaworski from Mike Hill with one attachment, January 24, 2010, 2 

pages.
15

SITE SUMMARY – GARY DEVELOPMENT LANDFILL

The Gary Development Landfill (CERCLIS ID No. IND077005916) site consists of the landfill 

where hazardous substances had been deposited and a release of lead, chromium (total), silver, zinc, 

acenaphthene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, 

chrysene, fluoranthene, fluorene, phenanthrene, and pyrene, into a wetland (Ref. 121, pp., 806-807, 870, 1795-

1797, 2287, 2508, 3329, 3468, 4175-4176, 4211, 4217-4218, 4640, 4641, 4646-4647, 4653, 4655, 4658, 4895-4897, 4937-

4938, 4974, 4983, 5015).

The Gary Development Landfill, the source, was a permitted solid waste landfill that accepted 

hazardous waste for disposal (Ref. 31, p. 3; 56, pp. 1, 2, 4, 5; 53, pp. 1, 2; 52, p. 27; 82, p. 1). The landfill 

neither achieved interim status under RCRA nor obtained a RCRA permit (Reference 48, p.1).

The industrial/sanitary landfill was operated from 1975 to 1989 (Ref. 22, pp. 7, 80; 32. p. 2; 132, p. 1; 

150, p. 1). The landfill accepted hazardous substances including volatile organic compounds, semi-volatile 

organic compounds, heavy metals, and pesticides (Ref. 21, pp. 1, 2; 18; 19; 23, p. 5; 27, p. 2; 33, p. 2; 30, p. 

5; 31, p. 3;; 34, pp. 2, 4; 55, pp. 1 through 38; 57, p. 3, 4; 61, pp. 3, 4, 5, 6; 63, p. 1; 64, p. 1; 65, pp. 1 through 

8; 66, p. 1; 67, pp. 1, 2; 70, pp. 3, 5, 6, 7; 79, p. 14, 15; 81, p. 17; 84, p. 1; 86, p. 13; 105, p. 5, 6). The landfill

ceased accepting waste materials in 1989. (Ref. 22, p. 80; 23, p. 15; 32, p. 2; 33, p. 2; 40, p.2; 47, p. 6; 68, pp. 

49, 119; 150, p. 1; 132, p. 1). Not all waste that was deposited into the landfill is known because the operator 

did not have a detailed waste analysis plan on file for waste it accepted (Ref. 23, p. 6). 

The release of hazardous substances occurred into a 2.83 acre wetland, which is adjacent to the 

southeastern portion of the facility property (Ref. Figure 1-2; 42). The wetland includes habitats known to be 

used by numerous State endangered species (Ref. 121 pp. 97 through 111, 119 through 152), specifically the 

marsh wren (Cistothorus palustris) (Ref. 121, pp. 98, 151, 160, 161, 164, 165, 179). The surface water 

pathway is the primary pathway of concern.

The probable point of entry (PPE) to surface water is the discharge area from an unpermitted outfall 

and from other areas at the Gary Development Landfill during its active operations (Ref. 99; 8; 12, pp. 1, 2, 3; 

13, pp. 1, 2, 3, 4, 5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 53, 61, 62, 63, 87; 23, p. 19; 30, pp. 

2, 3; 39, pp. 9, 10; 90, p. 3; 93, p. 3; 94, p. 3; 132, p. 1; 150, p. 1 Figure 1-2 of this HRS Documentation 

Record). The facility did not obtain an NPDES permit for any surface water that discharged from the landfill 

(Ref. 12, p. 2; 26, p. 2; 30, p. 2). Inspection reports completed by the Indiana Department of Environmental 

Management (IDEM) and USEPA personnel, along with historic aerial photographs reveal that the operator 

routinely discharged water, which may have come in contact with leachate and other hazardous materials, into 

the Grand Calumet River where wetlands are present adjacent to the landfill (Ref. 6; 8; 10; 11, pp. 8, 16 

through 21; 12, pp. 1, 2, 3; 13, pp. 1, 2, 3, 4, 5; 20, pp. 1, 2; 23, pp.17, 58; 24, p. 3; 27, p. 4; 30, pp. 2, 3, 8, 14, 

15; 78, pp. 5, 6, 7, 8, 9, 10; 90, p. 3; 94, p. 3; 99; 117, p. 1; 8; Figure 1-2 of this Documentation Record ).

An assessment of injury to human uses of fishery resources in the Grand Calumet River and 

surrounding areas was conducted by the U. S. Fish and Wildlife Service. The primary contaminants of concern 

addressed in this assessment include the same hazardous substances (i.e. metals, SVOCs, PCBs, and 

pesticides) as addressed in this Documentation Record (Ref. 95, pp. 29, 98, 103, 111; 102, p. 167). In general, 

the assessment indicates sediments from the Grand Calumet River and the Indiana Harbor Canal (which are 

part of the 15-mile surface water migration pathway for the Gary Development Landfill) have concentrations 

of numerous contaminants in the sediments sufficient to alter the chemical composition of fish tissues to such 

an extent that the human uses of fishery resources would be adversely affected (Ref. 95, pp. 29, 75, 126 

through 495; 102, p. 167). Biological resources such as benthic invertebrates, fish, birds, and mammals were 

also included in the study and were found to be impacted (Ref. 95, pp. 29, 75, 126 through 495; 102, p. 167). 

The landfill was not properly lined and there is no maintained engineered cover and no functioning 

and maintained run-on control system and runoff management system, enabling hazardous substances to 

migrate from the landfill into the adjacent wetland located at the south east corner of the landfill (Ref. 117, pp. 

1, 2, 3). 

While the landfill was active, IDEM inspectors noted that landfill material had been pushed into the 
16

same wetland mentioned above (Ref. 11, pp. 8, 9). The operator did not have permission to perform this action 

which may have released contaminants into the wetland. The inspectors also noticed several point source 

discharges of storm water runoff, creating rills and gullies, leaving the property’s southern boundary into the 

Grand Calumet River where the wetland is located (Ref. 11, p. 10; 14, pp. 4, 12; 23, p. 17; 24, p. 3; 38, pp. 5 

through 8; 85, pp. 1, 2, 3, 4, 5, 6; 94, p. 3). The runoff was visibly laden with sediment and caused a 

discoloration of the Grand Calumet River along the facility boundary (Ref. 38, pp. 5 through 8; 85, pp. 1, 2, 3, 

4, 5, 6; 106, pp. 1, 7, 10).

Another route of the contamination in the wetland is that the landfill could be leaking into the 

wetland via ground water. The property of the landfill is geologically unacceptable for waste disposal and is a 

hazard to ground water and surface-water resources in its vicinity (Ref. 60, p. 2). Because of the highly 

permeable nature of the Calumet aquifer surrounding the Gary Development Landfill, geologic conditions in 

the area around and beneath the landfill were not appropriate for the disposal of a hazardous waste (Ref. 92, 

pp. 5, 7, 15; 141, p. 1). Because of the fact that an engineered liner was never installed at the landfill, and the 

landfill cap is incomplete and not maintained, a potential exists for the landfill to leak hazardous substances 

into the adjacent wetlands located at the southeast corner of the landfill (Refs. 71, pp. 5, 6; 78, pp. 3, 4, 5, 6, 7, 

8; 92, p. 7; 109, p. 2; 117, pp. 2, 3; 141, p. 1). A potential exists for ground water contamination from the 

landfill (Ref. 51, p. 1).

The primary hazardous substances of concern in the source are lead, chromium, silver, zinc, and 

numerous semi-volatile organic compounds (See Section 2.2.2 of this HRS documentation record). A release 

of these contaminants to the surface water pathway has been documented during an Expanded Site Inspection 

conducted on May 5, 2009, by IDEM staff (Ref. 121, pp., 806-807, 870, 1795-1797, 2287, 2508, 3329, 3468, 4175-

4176, 4211, 4217-4218, 4640-4641, 4646-4647, 4653, 4655, 4658, 4895-4897, 4937-4938, 4974, 4983). All 

contaminants listed were found at levels three times or more above background.

The site is scored based on releases from the facility that have resulted in Level II contamination of 

environmental targets, via the surface water pathway (See Section 4.1.4.3 of this HRS documentation record). 

Facility Description

The former Gary Development Landfill (GDL) is located at 479 N. Cline Avenue, Gary, Lake 

County, Indiana (Ref. 23, p. 5; 148). The GDL can be found on the U.S.G.S. Highland, Ind. Quadrangle 

Topographic Map and in the southwest corner of section 35 in Township 37 North, Range 9 West (Ref. 3). 

The GDL lies adjacent to the Grand Calumet River about 500 feet west of the Gary Airport south of Lake 

Michigan (Ref. 47, pp. 6, 7; 76, p. 1; 3). The GDL is within the Grand Calumet River/Indiana Harbor Canal 

area of concern as outlined by EPA’s Great Lakes National Program Office (Ref. 124, pp. 1 through 13).

The facility is bounded to the north and east by E & J Railroad, to the south by the Grand Calumet 

River, and to the west by AMG (AKA Vulcan Materials). Wetland areas, which have been contaminated by 

the GDL operations, are present on the southeastern portion of the property (Figure 1-3 of this HRS 

documentation record). The Gary Development Landfill property consists of 62 total acres, of which 

approximately 55 acres were utilized for solid and hazardous waste disposal (Ref. 88, p. 3). The Gary 

Development Landfill is comprised of three (3) parcels (Ref. 45, p. 6; 113, pp. 1, 2, 3, 4, 5; 118, p. 1; 149, p. 

1-5).

Facility History

In early 1973, the operator of the landfill began to explore developing a sanitary landfill in a minedout, water-filled, sand pit (Ref. 15, p.1; 16, p. 1; 87, p. 2). On May 15, 1973, the Indiana Stream Pollution 

Control Board (SPCB) approved the operator’s proposal to dewater the sand pit (Ref. 87, p. 2). On June 19, 

1973, SPCB granted the operator’s construction permit SW133, allowing preparatory construction work for a

sanitary landfill to begin (Ref. 87, p. 2; 69, p. 1). On August 29, 1974, the State conducted its final inspection 

of the GDL, which led to SPCB’s granting final approval to the operator to commence sanitary landfill 

operation (Ref. 15, p. 1, 2; 16, p. 1; 87, p. 3). The landfill began accepting solid waste for disposal in 

September, 1974 (Ref. 22, p. 6). On February 20, 1975, SPCB sent the operator its operating permit,
17

No. 45-2 (Ref. 87, p. 3).

In April, May, and August of 1976, the operator of the landfill was found to have discharged leachate

into the Grand Calumet River without an NPDES permit (Ref 49, p. 3; 91, p. 1). Lab analysis of leachate 

samples taken on August 27, 1976 indicated that significant amounts of heavy metals and oils were being 

pumped into the Grand Calumet River (Ref. 90, p. 3; 117, p. 1, 2). In 1979 an Agreed Order was filed with the 

operator to address leachate concerns (Ref.17, pp. 1 through 4).

Inspections conducted by the Indiana State Board of Health found that areas around the working area 

did not have adequate cover and that fly ash was being used as cover (Ref. 68, pp. 2, 13, 85, 90, 93; 105, p. 1).

Other inspections conducted by the Indiana State Board of Health noted that leachate and contaminated water 

discharged into the Grand Calumet River without an NPDES permit and that fly ash was used as a cover for 

the landfill (Ref. 68, pp. 6, 8, 11, 17, 19, 22, 28, 29, 31, 34, 35, 38, 39, 40, 41, 45, 49, 50, 51, 53, 55, 56; 49, 

p. 3; 12, p. 2; 26, p. 2; 27 p. 4; 30, p. 2; 108, p. 1; 112, p. 5). As a result of the inspection findings, the operator 

was found not in compliance with its construction and operating permit (Ref. 23, p. 14). A Recommended 

Order regarding the findings was issued on February 16, 1983 (Ref. 15, p. 9). 

A review of IDEM records showed that uncontrolled and untreated drainage was allowed to 

discharge (via pumping or by run-off) directly into the Calumet River when the landfill was active 

(References 8; 10; 12, pp. 1, 2, 3; 13, pp. 1, 2, 3, 4, 5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 

53, 61, 62, 63, 87; 23, p. 19; 27, p. 4; 30, pp. 2, 3; 39, pp. 8, 9, 10; 71, pp. 4, 7; 78, pp. 5, 6, 7, 8, 9, 10; 90, p. 

3; 93, p. 3, 94, p. 3; 99; 106, pp. 1, 7, 10; 117, p. 1, 2; 132, p. 1; 150, p. 1). The operator was instructed to 

maintain a pond to control drainage (Ref. 83, p. 1-2). Inspections conducted in 1984 and 1990 revealed that 

the operator installed a culvert/drainage pipe under the access road to discharge drainage from the facility 

(Ref. 12, p. 2; 27, p. 4; 117, p. 1). No NPDES permit was obtained for the discharge (Ref. 12, p. 2; 26, p. 2; 

91, p. 1; 30, p. 2). 

In 1985, the operator was notified to submit paperwork to operate a hazardous waste facility and 

submit proof of financial assurance (Refs. 37, pp. 1; 77, p. 1). In 1986, U.S. EPA issued an administrative 

complaint and compliance order, which alleged that Gary Development Landfill accepted hazardous waste for 

disposal at their landfill which neither achieved interim status under RCRA, nor obtained a RCRA permit 

(Ref. 48, p.1; 29, p.10). Gary Development’s appeal of this order was dismissed as untimely in August 1996 

(Ref. 29, p. 11). The landfill operations ceased in 1989 (Ref. 22, p. 80; 23, p. 12; 32, p. 2; 33, p. 2; 40, p. 2; 

47, p. 6; 68, pp. 49, 119; 132, p. 1; 150, p. 1). 

An inspection of the GDL was conducted on February 18, 1992 and noted numerous violations of the 

Indiana Administrative Code (IAC) and Federal Land Disposal Restrictions (Ref. 23, pp. 2 through 7). On 

January, 30, 1995, other violations were noted (Ref. 110. p. 2). An inspection conducted by U. S. EPA in 1996 

also revealed that landfill material had been pushed into the wooded wetland area adjacent to the Grand 

Calumet River (Ref. 11, p. 7; 39, p. 2).

In August 1996, after negotiations regarding the 1986 complaint and compliance order, a consent 

decree was issued requiring Gary Development to pay $86,000 in fines and $40,000 into a trust fund (Ref. 28, 

pp.1, 2; 29, pp. 1, 5, 7, 14, 15, 28, 29, 30, 54, p. 1; 58, pp. 1, 2, 3; 74, p. 1; 103). The monies in the trust fund 

were to be used for the purpose of performing closure and post-closure care of the landfill, and conducting a 

ground water quality assessment program. In addition, the monies were to be used for remediation of 

contamination and/or the prevention of releases of hazardous substances at the facility (Ref. 29, p. 16; 74, p. 

9). Current cost estimates for assessments, cover and vegetation, erosion control measures, groundwater 

monitoring wells, gas system installation-flares, drain and fill ponds, capping, and other work exceed the 

amount in the trust fund (Ref. 48, p. 2; 78, pp. 3, 4, 5, 6; 88, pp. 3; 89, p. 1). Due to a lack of monies to 

adequately address closure and post-closure activities at the facility, in 1997, U. S. EPA deferred the facility to 

CERCLA (Ref. 48, p. 1). In 2001, the landfill was given a Not-Under-Control status (Ref. 73, p. 1). 

During a periodic inspection, IDEM staff identified several abandoned drums at the GDL on January 

8, 2002 (Ref. 47, pp. 6, 9). As a result, EPA conducted a Time –Critical Removal Action at the Gary 

Development Landfill. Numerous containers of various substances (oils, paint, insecticides, antifreeze, and 

electrical capacitors) were removed from the property Ref. 47, pp. 1, 9, 10, 13, 14, 15, 16, 17). 
18

On April 20, 2005, staff from IDEM’s Site Investigation Section conducted a Reassessment at the 

Gary Development Landfill (Ref. 121, p. 21). Ground water and wetland sediment samples were collected

(Ref. 121, p. 21). Elevated levels of metals, semi-volatile organic compounds, and pesticides were detected in 

the wetland samples (Ref. 121, p. 21). 

On May 5, 2009, IDEM Site Investigation Section conducted an Expanded Site Inspection at the 

former Gary Development Landfill (Ref.121, p. 23). Once again, elevated levels greater than three (3) times 

background of metals, semi-volatile organic compounds, and pesticides were detected in the adjacent wetland 

samples (Ref.121, 41, 42, 43, 44).
19

2.2 SOURCE CHARACTERIZATION

The primary source used to score the Gary Development Landfill is the landfill itself. 

Figures 1-1, 1-2, and 1-3 of this documentation record depict site location, source area locations, site features, 

the PPE, and the wetland perimeter on aerial photos of Gary Development Landfill. 

2.2.1 SOURCE IDENTIFICATION

Number of the source: 1

Name: Landfill

HRS Source Type: Landfill

Description and Location of the source:

The Gary Development Landfill, the source, was a permitted solid waste landfill (Ref. 56, pp. 1, 2, 3, 

4, 5; 53, pp. 1, 2). The landfill neither achieved interim status under RCRA nor obtained a RCRA permit 

(Reference 48, p.1). The sanitary/industrial landfill accepted materials including volatile organic compounds 

(VOCs), semi-volatile organic compounds (SVOCs), asbestos, metals, and pesticides (Ref. 21, pp.1, 2; 18; 19;

23, p. 5; 27, p. 2; 30, p.5; 31, p. 3; 33, p. 2; 34, pp. 2, 4; 55, pp. 1 through 38; 57, pp. 3, 4; 61, pp. 3, 4, 5, 6; 

63, p. 1; 64, p. 1; 65, pp. 1 through 8; 66, p. 1; 67, pp. 1, 2; 70, pp. 3, 5, 6, 7; 79, pp. 14, 15; 81, p. 17; 84, p. 1; 

86, p. 13; 105, pp. 5, 6; 112, p. 30; 119, pp. 1, 2 ).

Numerous on-property features can be observed based on an aerial photographic analysis of a 1985

photo from when the landfill was active (Ref. 14, pp. 11, 12, 13) which illustrate that drainage was observed 

flowing south into the Grand Calumet River from the active landfill area.

Runoff, pumping of leachate, ponded water, and uncontrolled drainage from the facility had come 

into contact with the contaminated waste being deposited into the landfill releasing hazardous substances into 

the adjacent wetland (Ref. 117, p.1). Leachate, was also produced from the landfill activities and was allowed 

to discharge from the landfill operation contaminating the adjacent wetland (Ref. 117, pp. 1, 2).

This drainage can be observed throughout most of the history of the landfill by reviewing historical 

aerial photographs and past inspections (Ref. 6; 8; 10; 11, pp. 8, 9; 12, pp. 1, 2; 13, pp. 1, 2, 3, 4, 5; 20, pp. 1, 

2; 22, pp. 11, 15, 16, 24, 25, 27, 61, 62, 63, 87; 24, p. 3; 30, pp. 2, 3; 39, pp. 9, 10; 72, p. 3; 78, pp. 5, 6, 7, 8, 

9, 10; 91, p. 1; 93, p. 3; 94, p. 3; 99; 106, pp.1, 7, 10; 108, p. 1; 117, pp. 1, 2; 132, p. 1).

An inspection conducted by U. S. EPA in 1996 also revealed that the operator pushed landfill 

material into the wooded wetland area adjacent to the Grand Calumet River (Ref. 11, pp. 7).

While the landfill was active, inspectors noticed that the operator had used fly ash as cover material 

(Ref. 68, pp. 6, 8, 11, 17, 19, 22, 28, 29, 31, 34, 35, 38, 39, 40, 41, 45, 49, 50, 51, 53, 55, 56; 49, p. 3; 108, p. 

1). This activity was never approved. In addition, the operator conducted fly ash fixation activities at the 

northeast corner of the GDL property (Ref. 68, pp. 6, 8, 11, 17, 19, 22, 28, 29, 31, 34, 35, 38, 39, 40, 41, 45, 

49, 50, 51, 53, 55, 56; 49, p. 3). Foundry sand was also used as cover material (Ref. 68, p. 2, 13, 85, 90, 93). 

The landfill cap is not complete or maintained (Refs. 71, pp. 5, 6; 117, pp. 2, 3).

Location of the source, with reference to map of the site: 

The former Gary Development Landfill is located at 479 N. Cline Avenue, Gary, Lake County, 

Indiana (Ref. 62, p. 004). The GDL can be found on the U.S.G.S. Highland, Ind. Quadrangle Topographic 

Map (Ref. 3). The GDL lies in the Southwest corner of Section 35 in Township 37 North, Range 9 West (Ref. 

3). The GDL lies adjacent to the Grand Calumet River about 500 feet west of the Gary Airport in an industrial 

setting south of Lake Michigan (Ref. 3; 47, pp. 6, 7).
20

Containment:

Inspection reports indicate that a liner had not been adequately placed within the landfill (Ref. 78, pp. 

3, 4, 5, 6, 7, 8; 109, p. 2; 117, p. 2). In addition, the geology of the area surrounding the landfill is comprised 

of sand, gravel, and silts (Ref. 92, p. 5). Such an aquifer provides a very permeable pathway for hazardous 

constituents to migrate (Ref. 92, p. 7). Since the landfill cap is not complete or maintained, no engineered liner 

was installed, and the geology of the surrounding area presented a permeable path for the migration of 

hazardous materials, a potential exists for hazardous materials in the subsurface to migrate from the landfill 

into the adjacent wetland located at the southeast corner of the property (Refs. 71, pp. 5, 6; 92, p. 7; 141, p. 1; 

117, pp. 2, 3). An inspection also noted water was seeping into a hole along the south side of the property 

(Ref. 68, pp. 20, 21). Seeps and areas ponded with leachate were noted in many inspection reports (Ref. 68, 

pp. 2, 10, 13, 15, 16, 17, 18, 19, 20, 22, 28, 30, 31, 32, 34, 35, 36, 37, 38, 40, 41, 50, 52, 54, 55, 56, 57, 61, 73, 

75, 77, 81, 83, 84, 85, 89, 97, 98, 105; 72, p. 3; 78, pp. 5, 6; 108, p. 1; 109, p. 2; 112, p. 5). The seeps are 

evidence that hazardous substances could have migrated off-site through the permeable soils of the landfill.

Inspections conducted by the Indiana State Board of Health staff while the landfill was active, 

revealed that fly ash was used as a cover material for portions of the landfill (Ref. 68, pp. 6, 8, 11, 17, 19, 22, 

28, 29, 31, 34, 35, 38, 39, 40, 41, 45, 49, 50, 51, 53, 55, 56; 49, p. 3; 108, p. 1). Fly ash contains heavy metals 

(i.e., chromium, lead) (Ref. 126, p. 3; 128, p.1). This fly ash was never approved by the State Board of Health 

for use as cover material. Storm water run-off could come in contact with the fly ash causing heavy metals to 

dissolve in solution and/or to be transported (via suspended solids of the ash) from the landfill. The landfill 

cap is not complete or maintained (71, p. 5, 6; 117, pp. 2, 3). This fly ash material was not an approved as an 

engineered cover and no regular maintenance was ever performed (Ref. 117. p. 3).

There is a potential for this southern perimeter to be leaking hazardous substances into the adjacent 

wetland from the Gary Development Landfill via the groundwater to surface water pathway. No liner or 

barrier was constructed in the landfill to inhibit the flow of contaminants to enter the wetland area located on 

the southern corner of the property (Ref. 117, p. 2). Since ground water flow is in a southern direction toward 

the Grand Calumet River and the area surrounding the entire landfill is composed of highly permeable sand 

with some gravel, the landfill is subject to leaking directly into the adjacent wetland area (92, p. 7; 141, p. 1). 

No samples were collected to substantiate this premise because of the possibility of encountering methane gas 

pockets from the landfill with the direct push instrument. 

The operator did not have a surface water run-on control system but had established a runoff control 

system (Ref. 68, p. 102; 117, pp. 1, 2). However the operator discharged the runoff directly into the adjacent 

wetland (Ref. 117, pp. 1, 2). Leachate waters were routinely discharged into the adjacent wetlands via a buried 

pipe (Ref. Ref. 68, p. 102; 117, p. 1).

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

Source Samples:

No source samples were obtained. The landfill is considered the source. The table below depicts the 

wastes and their associated hazardous substances that were deposited into the landfill. The hazardous waste 

types listed in the table were obtained from court documents, hazardous waste manifests that were sent to the 

State indicating the amount of waste that was shipped to the landfill, inspection reports by State Board of 

Health and by U.S. EPA, and RCRA inspection reports (Refer to the references listed for these reports).

SOURCE WASTE TABLE

Wastes Type Associated Hazardous 

Substances

Quantity References

API Separator Bottoms Acenaphthene, Anthracene, 

Benzo(a)Anthracene 

Benzene, Benzo(a)Pyrene, 

bis(2-Ethylhexyl)phthalate, 

Chrysene, Di-n-butyl 

phthalate, Ethylbenzene, 

200 cubic yards 81, p. 17; 79, p. 15; 128, 

p. 2
21

Fluorene, Naphthalene, 

Phenanthrene, Phenol, 

Pyrene, Toluene, Xylenes, 

Cyanides (Total), 

Chromium (Total), Lead, 

and Nickel

Paint Sludge (F005) Lead, Chromium, 

Cadmium, Barium, 

Toluene, Methyl Ethyl 

Ketone 

99,000 gallons 55, pp. 2 through 17, 19 

through 24, 26 through 

38; 128, p. 1

Fly Ash Mercury, Arsenic, Boron, 

Cadmium, Lead, Selenium, 

Cobalt, Aluminum, Barium, 

Molybdenum, Antimony, 

Thallium, and Chromium

95,000 cubic yards 68, pp. 6, 8, 11, 17, 19; 

81, p. 17; 79, p. 15; 49; 

30; 27, p. 21; 128, p. 1

Youngstown Oil Sludge Various SVOCs as noted for 

API separator bottoms

Unknown 79, p. 15

K087 (Decanter Tank 

Tar Sludge)

Benzene, Methyl Ethyl 

Ketone, Toluene, Xylenes, 

Acenaphthylene, 

Anthracene, 

Benzo(a)Anthracene, 

Benzenethiol, 

Benzo(b)Fluoranthene, 

Benzo(k)Fluoranthene, 

Benzo(a)Pyrene, Chrysene, 

Para-Cresol, Fluoranthene, 

Fluorene, Indeno(1,2,3-

cd)Pyrene, Naphthalene, 

Phenanthrene, Phenol, 

Pyrene, Antimony, Arsenic, 

Barium, Beryllium, 

Cadmium, Chromium, 

Copper, Lead, Mercury, 

Nickel, Selenium, Silver, 

Thallium, Vanadium, Zinc, 

Cyanide, Fluoride, Sulfide, 

Styrene, Dibenzofuran, and 

2-Methylnaphthalene

312,000 gallons 80, pp. 75 through 356; 

128, p. 2; 127, p. 8

Lead Waste/Battery 

Cases

Lead 60 cubic yards Ref. 34, p. 4; 30, p. 5; 65, 

pp. 1 through 8

Foundry Sand Arsenic, Barium, Cadmium, 

Chromium, Lead, Mercury, 

Selenium, Silver, Copper, 

Iron, Manganese, Nickel, 

Sodium, and Zinc

Unknown 68, p. 2, 13, 85, 90, 93; 

128, p. 5
22

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

Containment Description Containment 

Factor Value

Ref.

Release of hazardous substances via overland 

migration and/or flood: Elevated levels of 

metals, and SVOCs were detected in the 

wetlands located on the southeast corner of the 

landfill, an observed release of hazardous 

substances by chemical analysis.

The landfill also was not properly lined and 

there is no maintained engineered cover and no 

functioning and maintained run-on control 

system and runoff management system

enabling hazardous substances to potentially 

migrate from the landfill into the adjacent 

wetland located at the south east corner of the 

landfill. 

Note also the landfill inspectors had observed 

the operator of the landfill to illegally discharge 

water that had come in contact with hazardous 

materials from the landfill, into the adjacent 

wetland without an NPDES permit. 

10 Table 4-2, p. 51609; 8; 12, pp. 1, 2; 13, 

pp.1, 2, 3, 4, 5; 20, pp. 1, 2; 22, pp. 11, 

15, 16, 24, 25, 27, 61, 62, 63, 87; 30, 

pp. 2, 3; 39, pp. 8, 9, 10; 93, p.3, 94, p. 

3; 27, p. 2; 33, p. 2; 30, p.5; 31, p. 3; 

33, p. 2; 34, pp. 2, 4; 57, pp. 3, 4; 62, 

pp. 1, 2, 3, 4; 61, pp. 3, 4, 5, 6; 63, p. 1;

64, p. 1; 65, pp. 1 through 8; 66, p. 1; 

67, pp. 1, 2; 70, pp. 3, 5, 6, 7; 71, pp. 4, 

6, 7; 72, p. 3; 79, pp. 14, 15; 81, p. 17; 

84, p. 1; 91, p. 1; 92, p. 7; 97, pp. 1, 2;

98, pp. 1, 2; 105, p. 1; 106, pp. 1, 7, 10; 

108, p. 1; 109, p. 1; 78, pp. 3, 4, 5, 6, 7, 

8; 92, p. 7; 109, p. 2; 112, p. 5; 117, pp. 

1, 2, 3; 132, p. 1, 141, p.1

Notes: NS = Not Scored

2.4.2. HAZARDOUS WASTE QUANTITY

The hazardous substances associated with each waste type are shown in section 2.2.2 of this 

Documentation Record. The quantity of waste is shown in Section 2.4.2.1.3. 

2.4.2.1.1. Hazardous Constituent Quantity

Sufficient information is not available to document a hazardous constituent quantity (Ref. 1, Section 

2.4.2.1.1, p. 51590).

Hazardous Constituent Quantity Value (S): NS

2.4.2.1.2. Hazardous Wastestream Quantity

The hazardous substances associated with each waste type are shown in section 2.2.2 of this 

Documentation Record. The calculation of the volume of each specific waste that was obtained from 

manifests is shown below:

The table below summarizes the information found in Reference #123. This table shows the total 

number of waste shipments and the total volume by listed waste category. The individual shipments of waste 

itemized in Reference #123, were summed as shown below. 
23

 Type of Waste # of Shipments # of Gallons of Each Total Gallons/ Reference

(Hazardous Waste Code) Shipment Cubic Yards

F005 36 2,750 99,000 gallons 55, pp. 2 through 

38

K087 100 3,000 300,000 gallons 80, pp. 187-326, 

328-331, 333-

335, 337-356

K087 3 4,000 8,000 gallons 80, pp. 327, 332, 

336

Fly Ash NA NA 80,000 cubic yards 81, p. 17; 79, p. 

15; 30, p. 5; 49, 

p. 2; 27, p. 6

Fly Ash NA NA 15,000 cubic yards 81, p. 17; 79, p. 

15; 49, p. 2; 30, 

p. 5; 27, p. 6

API Separator 

Bottoms

NA NA 200 cubic yards 81, p. 17; 79, p. 

15

API Separator Bottoms = 200 cubic yards 

F005 = 99,000 gallons

K087 = 300,000 + 12,000 = 312,000 gallons

Fly Ash = 80,000 + 15,000 = 95,000 cubic yards 

99,000 gallons (F005) + 312,000 gallons (K087) = 411,000 gallons. 

Then the 411,000 gallons will be converted to pounds.

According to Table 2-5, on page 51591 of the HRS, 1 ton =2,000 pounds = 1 cubic yard = 4 drums = 200 

gallons. 

Therefore 411,000 divided by 200 equals 2,055 tons. 2,055 X 2,000 = 4,110,000 pounds (F005 and K087)

95,000 cubic yards (Fly Ash) + 200 cubic yards (API Separator Bottoms) times 2,000 = 190,400,000 pounds 

190,400,000 pounds + 4,110,000 pounds =194,510,000 pounds

194,510,000 divided by 5,000 = 38,902 (Hazardous Waste Quantity)

Refer to reference #128 for hazardous substances expected to be associated with each waste. 

The volume of waste depicted in the above table was derived from information supplied to the State 

of Indiana. The complete volume of wastes and type of wastes deposited in the landfill is not known because 

the operator did not maintain proper waste records.

Hazardous Wastestream Quantity Value (W): 38,902

2.4.2.1.3. Volume

Volume Assigned Value: >NS

(Ref. 1, Table 2-5, p. 51591)
24

2.4.2.1.4 Area

Area Assigned Value: (NS)

(Ref. 1, Table 2-5, p. 51591)

2.4.2.1.5 Source Hazardous Waste Quantity Value

Ref. 1, p. 51591: 38,902
25

4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

The surface water pathway starts at the southeast edge of the landfill property where discharges 

occurred into the Grand Calumet River where an emergent wetland is present (Ref. 99; 8;12, pp. 1, 2; 13, pp.

3; 20, pp. 1, 2; 22, pp. 11, 15, 16, 24, 25, 27, 61, 62, 63, 87; 30, pp. 2, 3; 39, pp. 9, 10; 71, pp. 4, 6, 7; 93, p.

3; 94, p. 3; 131, p. 1; 132, p. 1; 150, p. 1). The Gary Development Landfill never had an NPDES permit to 

discharge water from the GDL (Ref. 12, p. 2; 26, p. 2; 27, p. 4; 30, p. 2; 91, p. 1). Inspection reports, 

statements from past inspectors, and historical aerial photographs, show that overland flow drainage from the 

landfill activities was allowed to discharge from a point located on the southeast corner of the landfill (Ref.

99; 8; 12, pp. 1, 2; 13, p. 3; 20, pp. 1, 2; 22, pp. 11, 15, 16, 24, 25, 27, 61, 62, 63, 87; 30, pp. 2, 3; 39, pp. 9, 

10; 71, pp. 4, 6, 7; 91, p. 1; 93, p. 3; 94, p. 3; 132, p. 1; 150, p. 1). From the southeast portion of the landfill,

un-permitted discharges entered the surface water pathway through an adjacent wetland area. The drainage 

then flowed into the Grand Calumet River, then entered in the Indiana Harbor Canal, and finally emptied into 

Lake Michigan (Ref. 3; 100; 101, pp. 1, 2). There are sensitive environments such as wetlands and habitats for 

endangered species in the area. (Ref. 121, pp. 95 through 112, 119 through 152, 155, 156, 160 through 163, 

166 through 169). The environmental threat of the surface water pathway is the only threat that is being scored 

as part of this HRS Documentation Record.

4.1.1.1 Definition of Hazardous Substance Migration Pathway for Overland/Flood Component

The Gary Development Landfill property is adjacent to the east branch of the Grand Calumet River 

(GCR). The route for hazardous substances to migrate into the GCR from Gary Development Landfill would 

be via the probable point of entry (PPE) (See Figures 1-2 and 1-3 of this HRS documentation record). The 

PPE is the furthest upstream point where hazardous substances enter the surface pathway. The PPE is the 

point where un-permitted discharges from the landfill were allowed to enter the surface water pathway. From 

the PPE, the un-permitted discharge flows through .032 miles of an adjacent wetland area. From the wetland 

surface water enters the Grand Calumet River and flows 2.917 miles to the Grand Calumet River/ Indiana 

Harbor Canal (IHC) confluence. From this confluence surface water flows 4.079 miles north through the IHC 

to the Lake George Branch /IHC confluence. From this confluence surface water flows 2.099 miles northeast 

through the IHC where it enters the southwest corner of the Indiana Harbor. From this point in the Indiana 

Harbor, surface water flows 5.873 miles through the harbor and enters Lake Michigan where it completes the 

15 mile surface water pathway (Ref. 3; 100; 101, pp. 1, 2)

Possible routes for hazardous substances to migrate into the GCR from Gary Development Landfill 

would be either via the PPE, which discharges directly into the adjacent wetland, and/or via the southern 

perimeter of the facility, which borders the river, and may be leaking hazardous substances into the wetland 

from the landfill (Ref. 92, pp. 6, 7; 8; 12, pp. 1, 2, 3; 13, p. 3; 20, pp. 1, 2; 22, pp. 11, 15, 16, 24, 25, 27, 61, 

62, 63, 87; 27, p. 4; 30, pp. 2, 3; 39, pp. 9, 10; 90, p. 3; 93, p. 3; 94, p. 3; 117, p. 1, 2). 

Note: No appropriate liner was installed in the landfill to prevent the landfill from seeping (Ref. 78, 

pp. 3, 4, 5, 6, 7, 8; 109, p. 2; 117, p. 2). The furthest upstream PPE of hazardous substances is where the 

operator installed the discharge pipe on the southeastern edge of the landfill property (See Figures 1-2 to 1-3

of this HRS documentation record). The 15-mile surface water pathway was measured from the PPE of the 

Gary Development Landfill (Ref. 101, pp. 1, 2).

The hazardous wastes at Gary Development Landfill pose a significant threat to surface water in the 

area because the source is located in or near surface water (See Figures 1-2 and 1-3 of this HRS 

documentation record). Several references show that landfill material had been pushed directly into the 

wetland (Ref. 11, p. 7; 39, pp. 2). The operator did not have permission to conduct this activity. Analysis of 

samples collected within the wetland indicate the presence of heavy metals such as lead, chromium, silver, and 

zinc, numerous SVOCs such as acenaphthene, anthracene, benzo(a)anthracene, benzo(a)pyrene, 

benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene, fluoranthene, fluorene, phenanthrene, and pyrene (Ref. 

121, pp. 806-807, 870, 1795-1797, 2287, 2508, 3329, 3468, 4175-4176, 4211, 4217-4218, 4640, 4641, 4646-4647, 4653, 

4655, 4658, 4895-4897, 4937-4938, 4974, 4983; Section 2.2.1 of this HRS documentation record). 
26

Hazardous substances from the source could enter the GCR by migrating through the Gary 

Development Landfill property and entering the adjacent wetland via surface water runoff (Ref. 8; 12, pp. 1, 2; 

13, pp. 1, 2, 3, 4, 5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 53, 61, 62, 63, 87; 23, p. 19; 27, p. 

4; 30, pp. 2, 3; 39, pp. 8, 9, 10; 71, pp. 4, 6, 7; 78, pp. 5 through 10; 90, p. 3; 93, p. 3; 94, p. 3; 106, pp. 1, 7, 

10; 117, p. 1; 132, p. 1; 150, p. 1). No complete, maintained cap is present (Refs. 71, pp. 5, 6; 117, pp. 2, 3). 

Due to the sandy and highly permeable nature of the overlying material covering the hazardous waste (Ref. 

92, p. 7; 117, p. 2; 141, p. 1), drainage from the facility could have easily percolated through the overlying 

material coming into contact with the hazardous waste. Drainage/leachate and/or hazardous substances could 

be pumped/drained from the landfill into the PPE releasing hazardous substances directly into the adjacent 

wetland (Ref. 12, p. 2; 27, p. 4; 30, pp. 8, 14, 15; 78, pp. 5, 6, 7, 8, 9, 10; 117, p. 1). Run-off from the landfill 

could have entered directly into the adjacent wetland (Ref. 8;12, pp. 1, 2; 13, pp. 1, 2, 3, 4, 5; 20, pp. 1, 2; 22, 

pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 53, 61, 62, 63, 87; 23, p. 19; 27, p. 4; 30, pp. 2, 3; 39, pp. 8, 9, 10; 71, 

pp. 4, 6, 7; 78, pp. 5 through 10; 90, p. 3; 93, p. 3; 94, p. 3; 99; 106, pp. 1, 7, 10; 117, p. 1; 132, p. 1; 150, p. 

1). 

An assessment of injury to human uses of fishery resources in the Grand Calumet River and 

surrounding areas was conducted by the U. S. Fish and Wildlife Service. The primary contaminants of concern 

addressed in this assessment include the same hazardous substances (i.e. metals, SVOCs, PCBs, and 

pesticides) as addressed in this HRS Documentation Record (Ref. 95, pp. 29, 98, 103, 111; 102, p. 167). In 

general, the assessment indicates sediments from the Grand Calumet River and the Indiana Harbor Canal 

(which are part of the 15-mile surface water migration pathway for the Gary Development Landfill) have 

concentrations of numerous contaminants in the sediments sufficient to alter the chemical composition of fish 

tissues to such an extent that the human uses of fishery resources would be adversely affected (Ref. 95, pp. 29, 

75, 126 through 495; 102, p. 167). Biological resources such as benthic invertebrates, fish, birds, and 

mammals were also included in the study and were found to be impacted (Ref. 95, pp. 29, 75, 126 through 

495; 102, p. 167). 

There is a potential for the southern perimeter to be leaking hazardous substances into the adjacent 

wetland from the Gary Development Landfill via the groundwater to surface water pathway. No liner or 

barrier was constructed in the landfill to inhibit the flow of contaminants to enter the wetland area located on 

the southern corner of the property (Ref.117, pp. 1, 2). Since ground water flow is in a southern direction area 

toward the Grand Calumet River and the area surrounding the entire landfill is composed of highly permeable 

sand with some gravel, the landfill is subject to leaking directly into the adjacent wetland area (Ref. 92, p. 7; 

117, p. 2; 141, p. 1). No samples were collected to substantiate this premise because of the possibility of 

encountering methane gas pockets from the landfill with the direct push instrument. 

The surface water pathway is the only pathway evaluated for this documentation record.

Likelihood of Release

4.1.2.1.1 Observed Release

An observed release by chemical analysis, to the surface water pathway, is documented for the Gary 

Development Landfill. Inspection reports and statements reveal that leachate from the hazardous waste 

deposition areas of the landfill, had come in contact with ponded waters of the pit. The operator pumped these 

discharging waters which had come in contact with contaminants (i.e. via leachate from the landfill) into the 

Grand Calumet River (Ref. 8; 12, pp. 1, 2; 13, pp. 1-5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 

53, 61, 62, 63, 87; 23, p. 19; 30, pp. 2, 3, 8, 14, 15; 39, pp. 8, 9, 10; 71, pp. 4, 6, 7; 91, p. 1; 93, p. 3; 94, p. 3; 

132, p. 1; 150, p. 1).Chemical analysis of the wetlands, where the discharging waters flowed into, revealed an 

observed release due to the fact that elevated concentrations of hazardous substances at levels greater than 

three times background were detected (Refer to the Observed Release by Chemical Analysis of this section).

The drainage was occurring from a point located from the southeast corner of the landfill (Ref. 12, p. 2; 26, 

pp. 2; 27, p. 4; 30, p. 2). An NPDES permit was never issued for this discharge point (Ref. 91, p.1). The 

operator was known to have pumped ponded water from the landfill directly into the Grand Calumet River 

(Ref. 12, p. 2; 27, p. 4; 30, pp. 8, 14, 15; 78 pp. 5, 6, 7, 8, 9, 10; 117, p. 1). 

As discussed in the Site Summary of this HRS Documentation Record, there is one probable point of 

entry (PPE). The PPE is considered the discharge point as discussed above. Overland flow (surface water 
27

drainage) came into contact with the waste material that was deposited in the landfill. Leachate was created 

and was noted throughout inspections when the landfill was active (Ref. 68, pp. 2, 10, 11, 13, 15 through 20, 

22,, 28, 30-41, 49-57, , 61, 73, 75, 77, 81, 83-85, 89, 97, 98, 108, p. 1; 109, p. 2;). The leachate waters were 

allowed to discharge to the adjacent wetland area located along the southeast corner of the landfill from the 

PPE (Ref. 8; 12, pp. 1, 2; 13, pp. 1 through 5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 53, 61, 

62, 63, 87; 23, p. 19; 30, pp. 2, 3, 8, 14, 15; 39, pp. 8, 9, 10; 71, pp. 4, 6, 7; 93, p. 3; 94, p. 3; 99; 132, p. 1; 

150, p. 1).

Chemical analysis of wetland soils adjacent to the southeast corner of the landfill reveal that the 

wetlands have been contaminated with lead, chromium, silver, zinc, and various semi-volatile organic 

compounds at levels greater than three times background wetland samples (Ref. 121, pp. 806-807, 870, 1795-

1797, 2287, 2508, 3329, 3468, 4175-4176, 4211, 4217-4218, 4640, 4641, 4646-4647, 4653, 4655, 4658, 4895-4897, 4937-

4938, 4974, 4983, 5015).

Non-permitted uncontrolled drainage from the landfill can be observed by reviewing historical aerial 

photographs, former landfill inspection notes/reports, and past inspector statements (Ref. 8;12, pp. 1, 2, 13, pp.

1-5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 53, 61, 62, 63, 87; 23, p. 19; 30, pp. 2, 3, 8, 14, 15; 

39, pp. 8, 9, 10; 71, pp. 4, 6, 7; 91, p. 1; 93, p. 3; 94, p. 3; 99; 132, p. 1; 150, p. 1).These inspection reports and 

statements reveal that leachate from the hazardous waste deposition areas of the landfill, had come in contact 

with ponded waters of the pit (Ref. 117, p.2). The operator pumped these discharging waters, which had come 

in contact with contaminants (i.e. via leachate from the landfill) into the Grand Calumet River. A historical 

aerial photograph taken in 1965 shows an active sand mine (Ref. 9). The photograph shows that the eastern 

half of the mined-out sand pit was filled with water. No sand mine was present when observing aerial 

photographs taken in 1954 and 1958 (Ref. 4; 5).

According to IDEM records, in 1974 a letter was issued to the operator of GDL, Larry Hagen 

granting final approval to Gary Development Company, to allow landfill operations to begin. An aerial 

photograph taken 11-14-75 shows landfill activities had begun including pit dewatering. The photograph 

shows that pit dewatering occurred on the eastern half of the GDL property. Drainage in the form of a white 

narrow stream can be observed within the northern portion of the Grand Calumet River emanating from the 

southeast corner of the landfill property (Ref. 3, p. 1).

The 1975 and 1986 historical aerial photographs show that the landfill is active and that a large area 

of standing water bisects two active filling areas (Refs. 3; 6). The two aerial photographs show that drainage 

from the GDL is not adequately controlled allowing drainage into the Grand Calumet River along the 

southeast portion of the GDL property (notice small drainage rill south of the haul road/also notice small 

amount of sedimentation of the haul road is occurring into the Grand Calumet River on the southeast side of 

the GDL property (Ref. 3; 6). Historical 1975 and 1989 aerial photographs show that uncontrolled drainage 

was entering the Grand Calumet River. Inspection reports during this time period (1985 to 1989) indicate that 

leachate was occurring and ponding on the property (Ref. 68, pp. 2, 10, 11, 13, 15, 16, 17, 18, 19, 20, 22, 27, 

28, 30, 31, 32, 34, 35, 36, 37, 38, 40, 41, 50, 52, 54, 55, 56, 57, 61, 73, 75, 77, 81, 83, 84, 85, 89, 97, 98, 105; 

72, p. 3; 78, pp. 5, 6; 108, p. 1; 109, p. 2; 112, p. 5). The inspection reports also state that the operator was told 

not to allow drainage from the GDL to enter the Grand Calumet River (Ref. 68, pp. 2, 16, 22, 31, 32, 37, 38, 

64). 

Landfill materials were observed to have been pushed into the adjacent wetland (Ref. 11 pp.8, 9). 

Hazardous substances associated with the landfill material could have been deposited directly into the wetland 

when these materials were pushed into the wetland. Pictures show rills, gullies, and depositional areas in the 

wetland area. (Ref. 11, pp. 8, 9).

An aerial photograph taken on May 11, 1989 shows a point discharge from the southeast corner of 

the GDL property. The photograph shows a surface water collection pond along the southeast corner of the 

GDL property. This pond corresponds to a 2-11-85 certified engineering drawing for the landfill (Ref. 68. p. 

102). The drawing is also showing an internal drainage outfall from the pond. The outfall which was 

documented during the time when the landfill was active, is no longer present because it was been filled in 

some time after 1989 (Ref. 3; 116, pp. 1, 2; Figure 1 of this Documentation Record). The current location of 

the outfall was determined by reviewing historical aerial photographs that showed a discharge from the 

landfill, from past inspection reports, and from an interview with a past state inspector, who currently is an 
28

Assistant Commissioner of IDEM (Ref. 12, p. 2; 27, p. 4; 99). A certified engineer’s drawing confirms the 

location of the outfall (Ref. 68, p. 102). Since the exact location of the PPE is no longer present, the former 

location of the outfall was determined by triangulating the location of the PPE from historical photographs to 

present day photographs and reviewing past landfill inspector statements (Ref. 12, p. 2; 27, p. 4; 99; 114, pp. 

1, 2, 3; 115, p. 1, 2; 117, p. 1). No discharge was observed in aerial photographs after 1989 (Ref. 116, Figure 

1-1 of this Documentation Record). The photograph shows water is ponding southeast of the haul road and 

draining into the Grand Calumet River as a result of the existence of the internal outfall. 

Basis for Chemical Analysis

Observed releases to the adjacent wetland have been documented by chemical analysis of sediment 

samples collected during the 2009 Expanded Site Inspection (ESI). 

IDEM conducted an ESI on May 5, 2009 (Ref. 121, pp. 11, 14, 26, 27, 28, 29, 52 through 91; 46, pp. 

1 through 40). During the ESI, sediment samples were collected from the adjacent wetland area and from 

wetlands that were considered background, located east of the adjacent wetlands (Ref. 121, pp. 26, 27, 28, 29; 

46, 1-40). Analytical data from the 2009 ESI sampling event supports an observed release by chemical 

analysis to the adjacent wetland (Ref. 121, pp. 806-807, 870, 1795-1797, 2287, 2508, 3329, 3468, 4175-4176, 4211, 

4217-4218, 4640, 4641, 4646-4647, 4653, 4655, 4658, 4895-4897, 4937-4938, 4974, 4983, 5015).

Background Samples: 

Background wetland sediment samples were collected during the May 2009 ESI (Ref. 121, pp. 62, 

63, 64, 65; 46, pp. 1, 2, 7). The background wetland samples were collected in wetland areas located along the 

south and north sides of the Grand Calumet River just east of Gary Development Landfill (46, pp. 1, 2, 7). 

According to IDEM’s wetlands specialists, the background samples were obtained from the same type of 

wetlands as those located at the southeast corner of the Gary Development Landfill (Ref. 43, p. 1; 44, pp. 2, 

3). The Grand Calumet River predominantly flows from east to west (Ref. 92, p. 5; 95, p. 46). The background 

samples were collected on the east branch of the Grand Calumet River. Although the Grand Calumet River is 

known to sometimes reverse its flow, reversal of flow in the Grand Calumet River only occurs on the West 

Branch of the Grand Calumet River (Ref. 95, pp. 39, 46). All background samples collected were obtained 

upstream from the PPE. The background samples were collected from 1,930 feet (samples ME2QQ7) to as far 

as 8,115 feet (samples ME2QQ1 and E2QQ2/ME2QQ2) feet upstream from the PPE (Ref. 142, p. 2).

The background samples were collected from 0-12 inch and 12 to 24 inch intervals of sediment and 

were of the same general soil description as the other wetland samples (Ref. 46, pp. 1, 2, 7). Eight background 

sediment samples were obtained for the 2009 ESI. However only four samples were selected to represent

background sediment levels because they were found to contain the highest concentrations of contaminants of 

concern. These background sediment samples include ME2QQ2, E2QQ2, ME2QQ1, and ME2QQ7 (Ref. 121, 

pp. 53, 62, 63, 64, 65; 46, pp. 1, 2, 7).The background samples were obtained in the Grand Calumet River 

upstream from the Gary Development Landfill and were obtained in similar depositional areas where the 

target wetland samples were obtained. 

The 0-12 inch samples from the adjacent wetland were compared to the 0-12 inch samples collected 

from the background samples, and the 12-24 inch samples from the adjacent wetland were compared to the 

12-24 inch samples collected from the background samples.

A comparison of the background sediment samples and the adjacent wetland sediment samples reveal 

that the samples were obtained from the same type of wetland (PEMF) and show relatively comparable ranges 

of sediment properties (Ref. 131, p. 1; 46, pp. 1 through 40).

The following tables depict the wetland samples used as background wetland samples. The 

background samples contained various concentrations of SVOCs and metals. The background samples

depicted in the table represent those samples which had the highest concentration of analytes. The table 

depicts the sample IDs, locations, and sample characteristics. 
29

Background Sediment Sample Location and Comment Table

EPA

Number

IDEM

Control Sample Location Comments PercentSolids References

ME2QQ2 SDA2

60 feet west of airport 

strobe light at east end of 

runway

Color: black-10YR2/1*; 

inundated; sample obtained from 

12 -24 inches; dominant vegetation 

is phragmites;

38.4 %

Ref. 46, p. 2; 

121, pp. 62, 

63; 121, p. 

4173

E2QQ2 SDA2

60 feet west of airport 

strobe light at east end of 

runway

Color: black-10YR2/1*; 

inundated; sample obtained from 

12 -24 inches; dominant vegetation 

is phragmites;

29 %

Ref. 46, p. 2; 

121, pp. 62, 

63; 121, p. 

4634

ME2QQ1 SDA1

60 feet west of airport 

strobe light at east end of 

runway

Color: black-10YR2/1*; 

inundated; sample obtained from 0 

-12 inches; dominant vegetation is 

phragmites;

21.6 %

Ref. 46, p. 1; 

121, pp. 64, 

65; 121, p. 

4173

ME2QQ7 SDD1 Southwest corner airport 

property

Color: black-10YR2/1*; 

inundated; sample obtained from 

0-12 inches; dominant vegetation 

is phragmites

17.4 % Ref. 46, p. 7: 

121, p. 4174

* 10YR2/1 are color codes derived from the Munsell Color Chart (Ref. 147).

Note: The background samples listed are only those background samples which contain the highest 

concentrations of each contaminant used for scoring. 

All samples were collected using the same protocols and were analyzed for the same parameters. The 

samples were analyzed for metals according to CLP SOW ILM05.4 and for SVOCs, pesticides, and PCBs 

according to CLP SOW SOM01.2 (6/2007) and reviewed according to the National Functional Guidelines for 

Inorganic Data Review for SOM01.2 and the SOP for ESAT 5/TechLaw Validation of Contract Laboratory 

Program Organic Data (Version 2.3) (Ref. 121, p. 4166, 4601; 130, p. 2; 129, p. 2). The wetland samples were 

sent to EPA’s Test America and SVL Analytical laboratories for the above-mentioned analysis (Ref. 121, pp. 

199 through 5025). 

Sediment samples ME2QQ2, E2QQ2, ME2QQ1, and ME2QQ7 were obtained for the May 2009 ESI 

(Ref. 121, pp. 53, 62, 63, 64, 65; 46, pp. 1, 2, 7). These samples, which were collected upstream from the Gary 

Development Landfill, are considered reference background wetland samples. Even though these samples do 

not represent natural background due to the high lead, chromium, and SVOC levels, there is still a three fold

increase in the concentration of contaminants in the southeast adjacent wetland samples when compared to 

these samples. The samples were collected in an area east of the Gary Development Landfill property on the 

north and south side of the Grand Calumet River, east of the railroad/toll road bridge (Ref. 46, pp. 1, 2, 7).
30

Sample Location and Depth Table

Sample ID Percent Solids Sample 

Location Depth Date Reference

ME2QQ2 38.4 %

60 feet west of 

airport strobe 

light at east end 

of runway

12-24 inches 5-5-2009

Ref. 46, p. 2; 

121, pp. 62, 63; 

142

E2QQ2 29 %

60 feet west of 

airport strobe 

light at east end 

of runway

12-24 inches 5-5-2009

Ref. 46, p. 2; 

121, pp. 62, 63; 

142

ME2QQ1 21.6 %

60 feet west of 

airport strobe 

light at east end 

of runway

0-12 inches 5-5-2009

Ref. 46, p. 1; 

121, pp. 64, 65; 

142

ME2QQ7 17.4 %

Southwest 

corner Airport 

property

0-12 inches 5-5-2009 Ref. 46, p. 7; 

121, p. 53; 142

- Background Concentration Levels 

The table below provides a summary of the concentrations of hazardous substances detected in the 

background wetland samples collected from east of the adjacent wetland during the 2009 ESI. The analytical 

data package and data validation report from the sampling event are provided in Reference 121. All samples 

analyzed for metals were analyzed using the U.S. EPA Contract Laboratory Program (CLP) SOW ILM05.4 

Analysis Procedures (Ref. 121, p. 4166). All samples analyzed for semi-volatile organic compounds were 

analyzed using the CLP SOW SOM01.2 (6/2007) and reviewed according to the NFG for SOM01.2 and the 

SOP for ESAT 5/TechLaw Validation of Contract Laboratory Program Organic Data (Version 2.3)

(Ref. 121, p. 4601).
31

Background Concentration Level Table

Sample ID Hazardous Substance Sample Concentration Adjusted Sample 

Concentration

Sample Quantitation 

Limit (SQL) 

References

ME2QQ2 Chromium (Total) 

Silver

472 mg/kg

2.6 (U) mg/kg

Not Applicable

Not Applicable

2.604 mg/kg

2.604 mg/kg

Ref. 121, pp. 

4165-4173, 

4202 

E2QQ2RE Acenaphthene

Anthracene

Benzo(a)Anthracene

Benzo(a) Pyrene

Benzo (b)Fluoranthene

Benzo(k)Fluoranthene

Chrysene

Fluoranthene

Fluorene

Phenanthrene

Pyrene

14,000 ug/kg (J) 

17,000 (UJ) ug/kg

17,000 (UJ) ug/kg

4,700 (J) ug/kg 

7,100 (J) ug/kg 

5,700 ug/kg 

9,000 ug/kg (J) 

15,000 (J) ug/kg 

17,000 (UJ) ug/kg

17,000 (UJ) ug/kg

11,000 ug/kg (J) 

65,520 ug/kg

Not Applicable

Not Applicable

4,700 ug/kg

7,100 ug/kg

5,700

9,000 ug/kg

15,000 ug/kg

Not Applicable

Not Applicable

130,460 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

17,586.207 ug/kg

Ref. 121, pp. 

4601-4611, 

4634, 4635, 

4636, 4637

ME2QQ1 Chromium (Total)

Zinc

185 mg/kg

1,020 mg/kg

Not Applicable

Not Applicable

4.629 mg/kg

27.777 mg/kg

Ref. 121, pp. 

4165-4173, 

4201

ME2QQ7 Lead

Silver

362 mg/kg

5.7 (U) mg/kg

Not Applicable

Not Applicable

5.747 mg/kg

5.747 mg/kg

Ref. 121, pp. 

4165-4172, 

4174, 4207 

ug/kg micrograms per kilogram

mg/kg milligrams per kilogram

U The analyte was analyzed for, but was not detected above the reported contract required detection 

limit (CRDL).

J The analyte was positively identified; the associated numerical value is an approximate 

concentration of the analyte in the sample (Ref 121, p. 4633).

UJ The analyte was not detected above the reported SQL. However, the reported quantitation limit is 

approximate and may or may not represent the action limit of quantitation necessary to accurately 

and precisely measure the analyte in the sample (Ref. 121, p. 4633).

Concentrations that are bolded are based on the adjustment factors found in the EPA fact sheet “Using 

Qualified Data to Document an Observed Release and Observed Contamination” (Ref. 145). Because no 

direction of bias was indicated for the J-qualified data (Ref. 121, pp. 4601-4611), the values were adjusted 

upward in accordance with the fact sheet.
32

- Contaminated Sediment Samples

Sediment Sample Comment and Location Table

Sample 

ID

Percent 

Solids Sample Location

Distance 

from the 

PPE, feet

Comments Depth Date References

E2QS2 42 % South of first 

grouping of trees 

past end of the 

road; north of 

E2QR1

169.92 Color: black10YR2/1*; solvent 

odor; inundated ; 

sample collected 

from 12-24 inches; 

predominant 

vegetation is 

phragmites

12-24 

inches

5-5-2009 Ref. 46, p. 

20

ME2QR9 40.6 % Southeast of first 

grouping of trees 

east end of access 

road, southern most 

sample location, 

east of sample 

E2QR1

261.73 Color: black10YR2/1*; slight 

petroleum odor, 

sheen on water; 

inundated; sample 

obtained from 0-12 

inches; predominant 

vegetation is 

phragmites

0-12 

inches

5-5-2009 Ref. 46, p. 

17

ME2QS0 43.7 % Southeast of first 

grouping of trees 

east end of access 

road, southern most 

sample location, 

east of sample 

E2QR1

261.73 Color: black10YR2/1*; petroleum 

odor, sheen on water; 

inundated; sample 

obtained from 12-24

inches; predominant 

vegetation is 

phragmites

12-24 

inches

5-5-2009 Ref. 46, p. 

18

ME2QR3 35.2 % South of first 

grouping of trees 

past end of access 

road, over half way 

to the river

185.89 Color: black10YR2/1*; oil sheen 

observed on water; 

petroleum odor; 

sample collected 

from 12-24 inches; 

predominant 

vegetation is 

phragmites

12-24

inches

5-5-2009 Ref. 46, p. 

11

The percent solids for the metals were obtained from the analytical results found on their respective pages. 

The percent solids for the organics were obtained by taking 100 minus the percent moisture found in the 

analytical results. 

Using GIS software, the distance between the PPE and each sample location was measured. (Refs. 125, p.2; 

152).

* Note: 10YR2/1 is the color code derived from the Munsell Color Chart (Ref. 147).

Contaminated Samples- All samples analyzed for metals were analyzed using the U.S. EPA Contract 

Laboratory Program (CLP) SOW ILM05.4 Analysis Procedures (Ref. 121, p. 4166). All samples 

analyzed for semi-volatile organic compounds were analyzed using the CLP SOW SOM01.2 (6/2007) and 

reviewed according to the NFG for SOM01.2 and the SOP for ESAT 5/TechLaw Validation of Contract 

Laboratory Program Organic Data (Version 2.3) (Ref. 121, p. 4601).
33

Contaminated Sediment Concentration Table

Sample ID Sample 

Medium

Hazardous Substance Hazardous

Substance

Concentration

SQL Benchmark for

SW Environmental

Ref. 2, App. BII

References

E2QS2 Sediment Acenaphthene

Anthracene

Benzo(a)Anthracene

Benzo(a)Pyrene

Benzo(b)Fluoranthene

Benzo(k)Fluoranthene

Chrysene

Fluoranthene

Fluorene

Phenanthrene

Pyrene

480,000 ug/kg

270,000 ug/kg

600,000 ug/kg

540,000 ug/kg

700,000 ug/kg

500,000 ug/kg

630,000 ug/kg

2,000,000 ug/kg

440,000 ug/kg

460,000 ug/kg

1,100,000 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

115,580.21 ug/kg

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Ref. 121, pp. 

4602, 4646, 

4647, 4655, 

4937, 4938, 

ME2QR9 Sediment Chromium

Lead

Silver

Zinc

1,720 mg/kg (J) (1,333 mg/kg)∗ 2.463 mg/kg

2.463 mg/kg

2.463 mg/kg

14.778 mg/kg

1,740 mg/kg

11.7 mg/kg

6,340 mg/kg

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Ref. 121, pp. 

4165-4172, 

4176, 4217

ME2QS0 Sediment Chromium

Silver

2,030 mg/kg (J) (1,574 mg/kg)∗ 2.288 mg/kg

5.2 mg/kg 2.288 mg/kg

Not Applicable

Not Applicable

Ref. 121, pp. 

4165-4172, 

4176, 4218

ME2QR3 Sediment Silver 7.2 mg/kg 2.841 mg/kg Not Applicable Ref. 121, pp.

4165-4172, 

4175, 4211,

Key

mg/kg milligrams per kilogram

ug/Kg micrograms per kilogram

NA Not Applicable

The SQLs for the organic analysis (Semi-Volatile Organic Compounds (SVOCs) Pesticides, and 

Polychlorinated Biphenyls (PCBs)) were calculated utilizing methods described in Exhibit C “Target 

Compound List and Contract Requirement Quantitation Limits” pages C-1, C-7 – C-11, Exhibit D “Analytical 

Method for the Analysis of Semi-Volatile Organic Compounds” page D-48/SVOA, in CLP SOW SOM01.1 

for Organic Analysis (Ref. 144) and information contained in Reference 121, pages 4634 – 4660.

The sample quantitation limits (SQLs) for metals analysis were calculated utilizing methods described on page 

30 of the USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Superfund Data 

Review (Ref. 143) and information contained in Reference 121, pages 4173 – 4176.

 

∗ ME2QR9 Chromium Result Biased High and adjusted using the procedure described in EPA 540-F-94-028, Using Qualified Data to 

Document an Observed Release and Observed Contamination, November 1996 (Ref. 145).

∗ ME2QS0 Chromium Result Biased High and adjusted using the procedure described in EPA 540-F-94-028, Using Qualified Data to 

Document an Observed Release and Observed Contamination, November 1996 (Ref. 145).
34

Attribution:

Manifests, court documents, and other cited information from IDEM files demonstrate that hazardous 

materials have been deposited into the landfill (Ref. 21, pp. 1, 2; 18; 19; 22, pp. 7, 8, 9, 10, 11, 12, 13, 22, 23, 

18, 19, 20, 21, 22, 28, 29, 30, 31, 36, 37, 43, 50, 52, 54, 59; 23, p. 5; 27, p. 2; 33, p. 2; 30, p. 5; 31, p. 3; 33, p. 

2; 34, pp. 2, 4; 55, pp. 1 through 38; 57, pp. 3, 4; 61, pp. 3, 4, 5, 6; 63, p. 1; 64, p. 1; 65, pp. 1 through 8; 66, 

p. 1; 67, pp. 1, 2; 70, pp. 3, 5, 6, 7; 75, p. 2; 84. p. 1; 79, pp. 14, 15; 81, p. 17; 86, p. 13;). Historical aerial 

photographs, inspection reports, and past inspectors statements reveal that non-permitted drainage (leachate, 

runoff that would have come in contact with waste material, etc.) was allowed to discharge from the facility 

into the adjacent wetland located at the southeast corner of the of the GDL property (Ref. 8; 12, pp. 1, 2; 13, 

pp. 1, 2, 3, 4, 5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 53, 61, 62, 63, 87; 23, p. 19; 30, pp. 2, 

3; 39, pp. 8, 9, 10; 78, pp. 5, 6; 90, p. 3; 91, p. 1; 93, p. 3; 94, p. 3; 99; 106, pp. 1, 7, 10; 132, p. 1; 150, p. 1). 

The operator also installed a culvert under the access road to discharge drainage from the landfill into the 

Grand Calumet River (Ref. 12, p. 2; 27, p. 4). No NPDES permit was ever obtained. 

Analysis of the wetland sediment samples obtained at the southeast corner of the landfill revealed 

elevated levels of the same substances that were deposited in the landfill (Ref. 121, pp. 806-807, 870, 1795-

1797, 2287, 2508, 3329, 3468, 4175-4176, 4211, 4217-4218, 4640, 4641, 4646-4647, 4653, 4655, 4658, 4895-4897, 4937-

4938, 4974, 4983,; Section 2.2.1 of this HRS documentation record).

Because of the highly permeable nature of the Calumet aquifer, geologic conditions beneath the 

landfill were not appropriate for the disposal of a hazardous waste (Ref. 92, p. 7). Because of the fact that an 

engineered liner was never installed at the landfill, and the landfill cap is incomplete and not maintained, in 

addition to the direct discharge, the landfill may have leaked hazardous substances into the adjacent wetlands 

located at the southeast corner of the landfill (Refs. 71, pp. 5, 6; 78, pp. 3, 4, 5, 6, 7, 8; 92, p. 7; 117, pp. 2, 3; 

141, p.1).

There are 8 other possible sources of hazardous substances that have been identified in the area. 

Descriptions and locations of the possible sources are as follows (Refer to Reference 146 for a location of 

each possible source): 

1) Ninth Avenue Dump (EPA ID: IND980794432): The Ninth Avenue Dump is located approximately 

6000 feet south of the Gary Development Landfill (Reference 146). Hazardous waste disposal 

occurred at this NPL site from the early to mid 1970’s (Ref. 138, p. 13). The facility operator 

reportedly accepted dry industrial wastes, construction and demolition debris, liquid industrial wastes 

(Ref. 138, p. 13). Soils were found to be contaminated with a variety of VOCs, polycyclic aromatic 

hydrocarbons (PAHs), and PCBs (Ref. 138, p. 13). Ground water was found to be contaminated but 

the contamination did not extend beyond the original operating area. Surface water was found to 

present no significant risk to human health. (Ref. 138, p. 14).

2) Conservation Chemical (EPA ID: IND040888992): Conservation Chemical is located 4000 feet north 

of the wetlands that lie adjacent to the southern perimeter of the Gary Development Landfill 

(Reference 146). The company began operations in 1967 and operated the facility as a ferric chloride 

producer (Ref. 137, p.103). In 1975, the company ceased ferric chloride production and began 

operations as a hazardous waste terminal and treatment facility for cyanide, organic solvents, plating 

wastes, and waste oils (Ref. 137, p.103). Regulations in 1980 forced the company to stop the 

transport of hazardous waste (Ref. 137, p.103). In 1983 the Gary Municipal Airport Authority 

conducted a hazardous waste assessment at the Conservation Chemical Company for possible 

acquisition of the property for airport expansion (Ref. 137, p.103). No overland flow to the nearby 

surface water was noted. Conservation Chemical has undergone remediation under an administrative 

order between the responsible parties and EPA (Ref. 137, p. 106). 

3) Gary Municipal Airport (GMA) (EPA ID: IND067469437): Gary Municipal Airport is located 

approximately 900 feet east of the Gary Development Landfill (Reference 146). According to an 

inspection by an EPA contractor on April 8, 1987, oily waste was observed in a ditch located on 

Airport property (136, p. 2). Any oily waste in the ditch would have entered into the Grand Calumet 

River at a point upstream from the Gary Development Landfill. Contaminants detected in upstream 

samples that were obtained from the Grand Calumet River during the Gary Development Landfill 
35

Expanded Site Inspection were found to be lower than three times the wetland samples, indicating 

that the GMA is not expected to be a source of the contamination in the wetlands adjacent to the 

Gary Development Landfill (Refer to the Contaminated Sediment Concentration Table found in 

Section 4.1.2.1.1). 

4) Site # 95 (AKA City Service refinery tank bottom dump) (EPA IND980500151): Site number 95 is 

located approximately 450 feet due north of the Gary Development Landfill (Reference 146). City 

Service Company allegedly used a tar pit and a caustic pit for waste disposal (Ref. 135, pp. 6, 12). 

The contents of the tar pit (oily waste and sludge from petroleum refining tank bottoms) were mixed 

with soil and either deposited in piles or land-spread over a 7 acre disposal area (Ref.135, pp. 6, 12). 

An unnamed drainage ditch was located along the western edge of the property (Ref.135, pp. 6, 12). 

This drainage ditch enters a culvert near the southern border of the property and is piped underground 

to the southwest under Cline Avenue (Ref.135, pp. 6, 12). This pipe discharged into an access 

structure located near the northwest corner of the Cline Avenue interchange (Ref.135, pp. 6, 12). 

This location is to the west of the Gary Development Landfill (Ref. 146).

5) Roland Dump (AKA Site #73)(EPA ID: IND98050057): Roland Dump is located approximately 

5500 feet north-northeast of the Gary Development Landfill (Reference 146). Roland Dump was a pit 

that may have been used for sand excavation at one time was filled with water and was being utilized 

as a dump for demolition debris, refuse, foundry sand, and hazardous waste (Ref. 134, pp. 1, 2). 

Migration of hazardous substances into the ground water was suspected because of the sand aquifer 

and the shallow ground water table (4-6 feet) (Ref. 134, pp. 1, 2). Migration of hazardous substances 

from the property to the Grand Calumet River was considered unlikely because no drainage route 

existed (Ref. 134, p. 2).

6) Vulcan Materials (AKA AMG) (IND005444732): Vulcan Materials is located west of and adjacent to 

the Gary Development Landfill and is located at 459 Cline Avenue (Reference 146). The Vulcan 

Materials Company (VMC) was a steel detinning facility (Ref. 133, pp. 9, 12). Caustic mud slurry 

that was generated from the operations was placed in an unlined storage pond for the evaporation of 

water (Ref. 133, p. 12). In December 1979, the Gary Development Landfill operator notified the 

Indiana State Board of Health of a leachate flow from the Vulcan Materials Company property (Ref. 

133, p. 12). At the time the VMC was inspected by EPA personnel in 1980, no direct correlation 

could be made to indicate that leachate was flowing from the Vulcan materials Company storage 

pond to the west side of the Gary Development Landfill (GDL) property (Ref. 133, p. 12). Sampling 

conducted by US EPA contractor indicated that soils have been impacted significantly by SVOCs 

(Ref. 133, p. 51). However, it was concluded that the SVOCs were not a result of the detinning 

process (Ref. 133, p. 51). Currently the property is being used as metal recycling facility and the 

name of the facility is now AMG (Ref. 151). Since Vulcan Materials is located adjacent and west of 

the Gary Development Landfill, any surface water runoff from this facility would be expected to 

enter the Grand Calumet River downstream from the Gary Development Landfill (Ref. 3; 146).

7) MIDCO I (EPA ID: IND980615421) – MIDCO I is located approximately 8000 feet due south of the 

Gary Development Landfill (Reference 146). This NPL site includes a four-acre area where disposal 

occurred and an adjacent contaminated wetland area (Ref. 139, p. 1). From 1973 through 1979, this 

site was used for the storage of waste solvents and other wastes in tanks and in drums (Ref. 139, p. 

1). Following removal of the surficial wastes, the subsurface soils and groundwater were still found 

to be highly contaminated with volatile organic compounds, chromium, lead and nickel (Ref. 139, p. 

1). Nearby sediments were contaminated with similar contaminants as well as PCBs, polyaromatic 

hydrocarbons, and chlordane. Volatile organic compounds, chromium, lead, cadmium, and cyanide 

were detected in surface waters northeast of the site (Ref. 139, p. 1). Contaminants in the soil are 

leaching into the ground water (Ref. 139, p. 1). Until the site is cleaned up, risks to humans by direct 

contact or accidental ingestion of contaminated ground water, surface water, sediments, or soils is 

currently controlled by a site fence, on-site staff, and a temporary soil cover. Contaminated sediments 

are not migrating off-site (Ref. 139, p. 1). Based on the facility's location (Ref. 146), any potential 

runoff from this facility is not expected to enter the Grand Calumet River in the vicinity of the Gary 

Development Landfill.
36

8) Midco II (IND980679559) – Midco II is located approximately 4500 feet northeast of the Gary 

Development Landfill (Reference 146). This NPL site includes a 7-acre disposal area (Ref. 140, p. 1). 

This site was used for the storage of waste solvents and other wastes in tanks and drums, storage of 

reclaimable materials, neutralization of acids and caustics, and dumping of wastes (Ref. 140, p. 1). 

Following removal of surficial wastes, the subsurface soil and ground water were found to be highly 

contaminated (Ref. 140, p. 1). Contaminants affecting ground water include VOCs and some metals,

Sediments and soils are contaminated with similar substances as well as PCBs and polyaromatic 

hydrocarbons (Ref. 140, p. 1). Until the site is cleaned up, risks to humans by direct contact or 

accidental ingestion of contaminated ground water, surface water, sediments, or soils is currently 

controlled by a site fence, on-site staff, and a temporary soil cover. Contaminated sediments are not 

migrating off-site (Ref. 140, p. 1). Based on the facility's location and intervening structures (Ref. 

146), this facility is not expected to contribute runoff to the Grand Calumet River in the vicinity of 

the Gary Development Landfill. 

Based upon the information provided above and the facility locations shown on Reference 146, the 

contaminants found in the observed release to the wetlands adjacent to the Gary Development Landfill are 

not expected to have come from any of the other cited facilities.

Hazardous Substances Released:

The following hazardous substances have been released: 

Acenaphthene, Anthracene, Benzo(a)Anthracene, Benzo(a)Pyrene, Benzo(b)Fluoranthene, 

Benzo(k)Fluoranthene, Chrysene, Fluoranthene, Fluorene, Phenanthrene, Pyrene, Chromium, Lead, Silver, 

and Zinc.

Surface Water Observed Release Factor Value: 550

4.1.4 Environmental Threat

4.1.4.2 Environmental Threat Waste Characteristics

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

The ecosystem toxicity and persistence values, the environmental bioaccumulation values, and the 

ecosystem toxicity/persistence/bioaccumulation factor values for all hazardous substances associated with the 

Source that have a surface water containment value greater than zero (0) is presented in the table below. The 

combined ecosystem toxicity/persistence/bioaccumulation factor values were obtained from HRS Table 4-21 

(Ref. 1, Section 4.1.4.2.1.4, p. 51623).

Hazardous 

Substance

Source 

No.

Ecosystem 

Toxicity 

Factor 

Value

Persistence 

Factor 

Value*

Bioaccumulation 

Value**

Ecosystem 

Tox/Persistence

/Bio Factor 

Value (Table 4-

21)

References

Acenaphthene 1 10,000 .4 500 2,000,000 Ref. 1, p. 

97; 2, p. 5

Anthracene 1 10,000 .4 50,000 200,000,000 Ref. 1, p. 

97; 2, p. 27

Benzo(a)Anthracene

(Benz(a)Anthracene)

1 10,000 1 50,000 500,000,000 Ref. 1, p. 

97; 2, p. 39

Benzo(a)Pyrene 1 10,000 1 50,000 500,000,000 Ref. 1, p. 

97; 2, p. 45

Benzo(k)Fluoranthene 1 0 1 50,000 0 Ref. 1, p. 

97; 2 p.51
37

Chrysene 1 1,000 1 5,000 5,000,000 Ref. 1, p. 

97; 2, p. 93

Fluoranthene

(Benzo(j,k)fluorene

1 10,000 1 5,000 50,000,000 Ref. 1, p. 

97; 2, p. 49

Fluorene 1 1,000 1 5,000 500,000 Ref. 1, p. 

97; 2, p. 

177

Phenanthrene 1 1,000 .4 50,000 20,000,000 Ref. 1, p. 

97; 2, p. 

277

Pyrene 1 10,000 1 50,000 500,000,000 Ref. 1, p. 

97; 2, 

p.301

Chromium 1 10,000 1 500 5,000,000 Ref. 1, p. 

97; 2, p. 87

Lead 1 1,000 1 50,000 50,000,000 Ref. 1, p. 

97; 2, p. 

227

Silver 1 10,000 1 50 500,000 Ref. 1, p. 

97; 2, p. 

315

Zinc 1 10 1 50,000 500,000 Ref. 1, p. 

97; 2, p. 

409

* The river persistence value was used since the nearest sensitive environment is the southeast adjacent

wetland which is part of the Grand Calumet River.

**Bioaccumulation factor value for Freshwater

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 500,000,000 or 5 x 108

4.1.4.2.2 Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste 

Quantity

1 Landfill 38,902

Sum of Values: 38,902

Hazardous Waste Quantity Factor Value: 10,000

(Ref. 1, Section 2.4.2.2, Table 2-6)

4.1.4.2.3 Waste Characteristics Factor Category Value

The environmental waste characteristics factor value is obtained by multiplying the ecosystem toxicity/ 

persistence factor value and the hazardous waste quantity factor value for the watershed, subject to a 

maximum product of 1 x 108

. Then multiply the product by the ecosystem bioaccumulation potential factor 

value for that hazardous substance, subject to a maximum product of 1 x 1012 (Ref. 1, Section 4.1.4.2.3, p. 

51624). The product is assigned a waste characteristics factor category value from HRS Table 2-7 (Ref. 1, 

Section 2.4.3.1, p. 51592). The values presented below are for benzo(a)pyrene and mercury.

Ecosystem Toxicity/Persistence Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10,000

Bioaccumulation Potential Factor Value: 50,000
38

10,000 (Ecotox) X 10,000 (Hazardous Waste Quantity is 10,000) = 1 x 108 X 50,000 (Bioaccumulation) = 5 X 

1012

Then enter 5 X 1012 into HRS Table 2-7

HRS Table 2-7 yields a waste characteristics factor category value of 1,000

Waste Characteristics Factor Category Value: 1,000

(Ref. 1, Table 2-7, p. 51592)

4.1.4.3 Environmental Threat Targets

4.1.4.3.1.1 Level I Concentrations

There are no Level I concentrations; therefore, Level I concentrations were not evaluated as part of 

this HRS Documentation Record.

4.1.4.3.1 Sensitive Environments

There are three sensitive environments identified that have been impacted by the Gary Development 

Landfill. The three environments are as follows:

1) Habitat known to be used by State designated endangered species, Marsh Wren (Cistothorus 

palustris) (Ref. 121, pp. 98, 151, 160, 161, 164).

2) Particular areas, relatively small in size, important to maintenance of unique biotic life (Grand 

Calumet River Corridor) (Ref. 121, p. 165, 166, 179).

3) Wetland (PEMF) (Ref. 7; 43; 44; 131, p. 1)

4.1.4.3.1.2 Level II Concentrations

Actual contamination is shown in the preceding sections by establishing an observed release by 

chemical analysis to wetland sediments and sensitive environments. Contaminants that meet the criteria for 

observed releases to the surface water pathway were detected in sediment samples (Section 4.1.2.1.1 of this 

HRS Documentation Record). Therefore, Level II concentrations are assigned (Ref. 1, Sec. 2, p. 51592). 

Please refer to the Contaminated Sediment Concentration Table found in Section 4.1.2.1.1 of this HRS 

documentation record.

A 2.83+/- acre wetland, is present by the southeast corner of the landfill property (Figure 1-2 of this 

HRS documentation record). This area meets the criteria for a wetland as defined by the Hazard Ranking 

System and as defined in 40 CFR Section 230.3, and is considered eligible for HRS scoring (Ref. 1, Table 4-

24, p. 51625; 125, pp. 1, 2). This area is inundated and/or saturated by surface water at frequency and duration 

sufficient to support, and that under normal circumstances does support, a prevalence of vegetation typically 

adapted for life in saturated soil conditions. This portion of the property contains hydrophytes in both hydric 

and non-hydric soils (Ref. 131, p. 1). A reconnaissance of the wetland was conducted by IDEM’s wetland 

specialist. The wetland specialist indicated that this wetland is designated as PEMF (Ref. 131, p. 1).

This wetland has become contaminated with various concentrations of lead, chromium, zinc and 

numerous SVOCs as a result of continued discharge into the wetland from the Gary Development Landfill 

activities (Ref. 8; 12, pp. 1, 2, 13, pp. 1, 2, 3, 4, 5; 20, pp. 1, 2; 22, pp. 11, 15, 16, 22, 24, 25, 27, 39, 41, 53, 

61, 62, 63, 87; 23, p. 19; 30, pp. 2, 3; 39, pp. 8, 9, 10; 90, p. 3; 93, p. 3; 94, p. 3; 97, pp. 1, 2; 98, pp. 1, 2; 

132, p. 1; 150, p. 1).

A habitat known to be used by State designated endangered or threatened species meets the HRS 

definition of a sensitive environment (Ref. 1, Table 4-23, p. 51624). The wetland is considered an area/habitat 

known to be used by the marsh wren, Cistothorus palustris, a state designated endangered bird; it is suitable 

habitat for and is within the current range of this species (Ref. 121, pp. 117, 119, 136, 145, 151, 160, 161, 162, 
39

164). The marsh wren is a wetland species that utilizes aquatic plants for nesting and feeding habitats and 

forages on or near the marsh floor (Ref. 121, pp. 160, 161). As such, it would be expected to contact wetland 

surface water and sediment. Also, the wetland area, a particular area, relatively small in size, is important to 

the maintenance of unique biotic communities. It is part of the Grand Calumet River Corridor (Ref. 121, pp. 

165, 177, 179, 180). 

The table below lists the sensitive environments that have been impacted and their associated sensitive 

environment values.

Sensitive Environment

Distance from PPE to 

Nearest Sensitive 

Environment

Reference Sensitive Environment 

Value (Table 4-23)

Habitat known to be used 

by State designated 

endangered species, 

marsh wren (Cistothorus 

palustris)

0 ft. 121, pp. 160, 161, 164 50

Particular areas, 

relatively small in size, 

important to maintenance 

of unique biotic life 

(Grand Calumet River 

Corridor) 

0 ft. 121, pp. 165, 166, 179 25

The PPE is in the wetland sensitive environment. There is evidence that numerous state designated 

endangered or threatened species, are also in the area (Ref. 121, pp. 95 through 112, 119 through 152, 155, 

156, 160 through 163, 166 through 169). It is unclear whether these species remain in the GDL area at this 

time. 

Sum of sensitive environment values: 50 + 25 = 75

 

Sum of Level II Sensitive Environments Value: 75

Wetlands

Wetland sediment samples E2QS2, ME2QR9, ME2QS0, and ME2QR3 meet the requirements for an 

observed release (Refs. 1, Section 2.3, p. 51589; Section 4.1.2.1.1 of this HRS Documentation Record). The 

total length of wetlands perimeter that is subject to Level II concentrations of hazardous substances is 

determined by measuring the distance from the PPE to sample location points E2QS2 to sample ME2QR9 to 

sample ME2QR3 and then back to the PPE (Ref. Figure 1-3 of this HRS Documentation Record). The 

perimeter of the wetlands outlined by connecting a line to the PPE and these three sample points represents a 

quadrilateral (Ref. 153; Figure 1-3 of this HRS Documentation Record). The perimeter of the wetland 

measured by this quadrilateral that is subject to Level II concentrations is 532.32 feet or .1008 miles (Ref. 

Figure 1-3 of this HRS Documentation Record). The distance from the PPE to each of the three (3) sample 

points and back to the PPE was calculated using GIS software, and the total length of the wetland perimeter

was measured. (Refs. 125, p. 2; 153). The assigned HRS wetland value for Level II concentrations is 25 (Ref. 

1, Table 4-24, p. 51625).

Wetland Wetland Perimeter (ft) Wetland Perimeter (miles) Reference

PEMF 532.32 0.1008 Figure 1-3 of this HRS 

documentation 

record 

Notes:

Sum of Level II Wetland Perimeter: 169.92 + 91.81 + 84.70 + 195.89 = 532.32 = 0.1008 miles

Wetlands Value (Ref. 1, Table 4-24): 25

Sum of Level II Sensitive Environments Value + Wetlands Value: 75 + 25 
40

Level II Concentrations Factor Value: 100

5.0 SOIL EXPOSURE PATHWAY

The soil exposure pathway was not evaluated as part of this HRS Documentation Record.

6.0 AIR MIGRATION PATHWAY

The air migration pathway was not evaluated as part of this HRS Documentation Record.