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 Nationa l 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. 6 2 , 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 c enter 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 consi ders 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 pr ecisely 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 ref ined 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 30.002 WOR KSHEET FOR COMPUTING HRS SITE SCORE

S S 2

1. Ground Water Migration Pathway Score (S gw ) (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 W ater to Su rface Water Migration Component NS

2c. Surface Water Migration Pathway Score (S

sw ) Enter the larger of lines 2a and 2b as the pathway score. 60.00 3600.00

3. Soil Exposure Pathway Score (S

s NS

4. Air Migration Pathway Score (S

a ) NS

5. Total of S gw 2 + S

sw 2 + S

s 2 + S

a 2 3600.00

6. HRS Site Score Divide the value on line 5 by 4 and take the square root 30.003 TABLE 4

- 1

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET Factor Categories and Factors Maximum Valu e 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. Populati on
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 Factor s 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 Qua ntity 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 Maxi mum 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 5 0 0,000,000

24. Hazardous Waste Quantity a 1 0

, 0 00

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 Score c
( lines 13 + 21 + 28, subject to a maximum of 100) 100 60 .00

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE

30. Component Score (S of ) c

, (highest score from line 29 for all watersheds evaluated, subject to a maximum of 100) 100 60 .00

a Maxi mum 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

I l linois

I

ndiana Lake Michigan Lake County, IN Site Vicinity 

# E

Grand Calumet River 

### Latitude: 41°36'50.62" N Longitude: 87°25'35.21" W

I-90 E I-9 0 W SR 912 Cline Ave Gary Ave

0 1 5 0 75 Meters

0 5 0 0 250 Feet



### Approximate Site Boundary Approximate Center of Site 

# E Figure 1-1

5Sources:

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

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



# μ

**Lake County** 

**I l**  **linois**

**I n**  **dia n**  **a Lake** 

**Michigan Lake County, IN**  **Site Vicinity** 

### ! **G r**  **a nd C**  **alumet Riv**

**er**



### Approximate Site Boundary

! 

### Probable Point of Entry (PPE) - 1989

**Wetland Classified PEMF 0**  **100**

**50 Meters** 

**0 500** 

**250 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!**E2QS2 ME2QR9** **ME2QS0 ME2QR3** **PPE - 1989 Gary Dev.** **Landfill Site Lake County, IN** **Site Vicinity**

**G r**  **a n**  **d C**  **a l**  **u m**  **e t**  **R i**  **v e**  **r 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:**5/25/2010**Sources:Non Orthophotography Data**- Unpermitted Discharge Point location obtained from the State Land Office, 1989 Digital Aerial Photography** Orthophotography**- Obtained from IndianaMap Framework Data (2005 Digital Orthophotography)** **(www.indianamap.org)**Map Projection:**UTM Zone 16 N**Map Datum:**NAD83**μ!Probable Point of Entry (PPE) - 1989Sediment Sample LocationSediment Sample Delineation

**Gran d Calu**  **met R i**  **ve r** Wetland Frontage Map, Gary Development LandfillGary, Lake County, Indiana (U.S. EPA ID: IND077005916)**0 5** **10 Meters 0** **25 50 Feet** Contaminated Area:**.0955 acres 4,159.98 square feet** **(Ref. 121, pp. 27, 28, 29; Ref. 115, p. 1)** 16 9. 92 '

185. 89' 84 . 7 0' 91 .81'Wetland Frontage169.92’ + 91.81’ + 84.70’ + 185.89’ = 532.32’8 REFERENCES

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, February 8, 2011 , 1 page.

149. IDEM E

- Mail to Mark Jaworski from Mike Hill with four attachments, August 5, 2010, 5

pages.

1 50

. 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

page s

.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 l ead, c hromium ( t otal), silver, z inc,

a cenaphthene, a nthracene, b enzo(a) a nthracene, b enzo(a) p yrene, b enzo(b) f luoranthene, b enzo(k) f luoranthene,

c hrysene, f luoranthene, f luorene, p henanthrene, and p yrene, 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

hazardou s waste for disposal (Ref. 31, p. 3; 56, p p

. 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 t o 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 w aste analysis plan on file for waste it accepted (Ref. 23, p. 6).

The release of hazardous substance s 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 ha bitats known to be used by numerous State endangered species (Ref. 121 pp. 97 through 111, 119 through 152)

, specifically the

m arsh w ren ( C istothorus palustris ) (Ref

. 121, pp. 98, 151, 160, 161, 164, 165, 179)

. The surface water pathway is the primary pat hway 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; 2 0, 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 perm it 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 tha t 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 fishe ry 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 pestic ides) 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 pa thway 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 so uth 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 the16 same wetland mentioned above (Ref. 11, pp. 8, 9). The operator did not have permission to pe rform 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 wh ere 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 bo undary ( 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 unacce ptable 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,

p p. 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 main tained, a potential exists for the landfill to leak hazardous substances into the adjacent wetlands located at the southeast corner of the landfill (Ref s

. 71, pp. 5, 6; 78, pp. 3, 4, 5, 6, 7, 8; 92, p. 7; 109, p. 2; 117, p p . 2 , 3 ; 141, p. 1 ). A potential e xists for ground water contamination from the landfill (Ref. 51, p. 1).

The primary hazardous substance s 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 contamin ation of

environment al 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; 14 8 ). The GDL can be found on the U.S.G.S. Highland, Ind. Quadrangle Topographic Map an d i n 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 5 00 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 Lake s National Program Office (Ref. 124, pp. 1 through 13).

The facility is bou nded 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 compri sed of three (3) parcels (Ref. 45, p. 6; 113, p p . 1, 2, 3, 4, 5 ; 118, p. 1 ; 1 49 , p. 1

- 5 )

.

Facility History

In early 1973, the operator of the landfill began to explore developing a sanitary landfill in a mined

out, 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 preparator y 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 (Re f. 15, p. 1, 2 ; 16, p. 1; 87, p. 3). The landfill began accepting solid waste for disposal in September, 1974 (Ref. 2 2 , 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 discharge d 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 indicate d that significant amounts of heavy metals a nd 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)

.

I nspections conducted by the Indiana State Board of Health fo und that areas around the working area did not have adequate cover and that fly ash was being used as cover (Ref. 68, p p. 2, 13, 85, 90, 93; 105, p. 1).

Other inspections conducted by the Indiana State Board of Health noted that leachate and contaminated w ater 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 show ed 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, p p. 2, 3; 39, p p. 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 f acility (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, t he operator was notified to submit paperwork to operate a hazardous waste facility and
submit proof of f inancial assurance (Ref s . 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 s tatus 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 198 9 (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 F ederal L and Disposal R estrictions (Ref. 23, pp. 2 throu gh 7 )

. On January, 30, 1995, other violations were noted ( Ref. 110. p. 2)

. An i nspection conducted by U. S. EPA in 1996

also revealed that landfill material had been pushed into the wooded wetland area adjacent to the G rand 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,

p p .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

monitorin g 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, p p. 3; 89, p. 1 ). Due to a lack of monies to adequately address closure and post

- closure acti vities at the facility

, i n 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 GD L on January 8, 2002 (Ref

. 47, p p . 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 )

. G round water and wetland sediment samples were co llected (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

f ormer Gary Development Landfill ( Ref.121, p. 23 ) . Once again, e levated 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 wetlan d 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 per mitted solid waste landfill (Ref. 56, p p

. 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 c ompounds (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 G rand Calumet River fro m 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 di scharge from the landfill operation contaminating the adjacent wetland (Ref . 1 17, p p . 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, p p. 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, p p. 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 notice d 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 (Ref s . 71, p p . 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 5 00 feet w est 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 ; 10 9, 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 landfi ll into the adjacent wetland located at the southeast corner of the property (Ref s

. 71, pp. 5, 6; 92, p. 7 ; 141, p. 1 ; 1 17, p p

. 2, 3 ) . An inspection also noted water was seeping into a hole along the south side of the property (Ref. 68, p p

. 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 pe rmeable soils of the landfill.

Inspections conducted by the Indiana State Board of Health staff while the landfill was act ive, 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, l ead) (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 s uspended solids of the ash) from the landfill . The landfill cap is not complete or maintained (71, p. 5

, 6 ; 1 17 , p p

. 2, 3 ). This fly ash material was not an approved as an engineered cover and no regular maintenance was ever performed ( Ref. 1 17 . p. 3 ).

Th ere 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 h ighly permeable sand with some gravel, the landfill is subject to leaking directly into the adjacent wetland area ( 92, p. 7; 1 41, p. 1 )

. No samples were collected to substantiate this premise because of the possibility of encountering methane gas pockets f rom 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 a djacent

wetland (Ref. 117

, p p. 1, 2 ). Leachate waters were routinely discharged into the adjacent wetlands via a buried pipe (Ref. Ref. 68, p. 102; 1 17 , p. 1 ).

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

Source Samples:

No source samples we re 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, hazard ous 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. 221 Fluore ne, 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 U nknown 79, p. 15

K087 (Decanter Tank Tar Sludge) Benzene, Methyl Ethyl Ketone, Toluene, Xylenes, Acenaphthylene, Anthracene, Benzo(a)A nthracene, 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 ga llons 80, pp. 75 through 356 ; 128, p. 2; 127, p. 8

Lead W aste/ Battery

Cases Lead 60 cubic yard s 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. 522 2.2.3 HAZARDOUS SUBSTANCES AVAILAB LE 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 hazardo us 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, p p. 1, 2 , 3 ; 132, p. 1

, 141, p.1

Notes: NS = Not Sc ored

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

Su fficient 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

T he hazardous substances associated with e ach 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 s hows 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 W aste # of S hipments # of G allons of E ach Total Gallons/ Reference

(Hazardous W aste C ode ) Shipme nt Cubic Yards

F005 3 6 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 Sep arator

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) = 4 11

, 000 gallons.

Then the 4 11

, 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 2,0 55 tons. 2, 055 X 2, 000 = 4, 110

, 0 00 pounds (F005 and K087)

95,000 cubic yards (Fly Ash) + 200 cubic yards (API Separator Bottoms) times 2,000 = 190, 4 0 0 ,000 pounds

190, 40 0 ,000 pounds + 4, 110

, 0 00 pounds = 194, 5 1 0 ,000 pounds

194, 5 1 0

, 000 divided by 5,000 = 38, 9 02 (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

A rea Assigned Value: ( NS ) (Ref. 1, Table 2

- 5, p. 51591)

2.4.2.1.5 Source Hazardous Waste Quantity Value

Ref. 1, p. 51591: 38,90225 4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

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

occurred into the Grand Calumet River where a n 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, p p. 2, 3; 39, p p . 9, 10; 71, p p. 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 ins pectors, an d 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, p p. 2, 3; 39, p p. 9, 10; 71, p p. 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 flow ed into the Grand Calumet River, then enter ed in the Indiana Harbor Canal, and finally emptie d into Lake Michigan ( Ref. 3; 100 ; 101, pp. 1, 2). There are sensitive environments such as wetlands and habitats for endanger ed species in the area

. ( Ref. 121, pp. 95 through 112, 119 through 152, 155, 156, 160 through 163, 166 through 169 ). The environment al 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 flow s 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 nort heast 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, whi ch 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, p p. 2, 3; 39, p p. 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

op erator installed the discharge pipe on th e 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 L andfill (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, chr omium, 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, 2 287, 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 throug h 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 (Ref s

. 71, pp. 5, 6; 117, p p . 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 Wildli fe 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

gen eral, 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 sedimen ts 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 th e 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 wet land 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 o nly 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. I nspection reports and statem ents reveal that leachate from the hazardous waste deposition areas of the landfill, had come in contact with ponded waters of the pit. T he operator pumped these discharging waters which had come in contact with contaminants (i

. e. via leachate from the lan dfill) 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, p p. 2, 3, 8, 14, 15; 39, p p. 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 (R efer 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 discha rge 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, p p. 8, 14, 15; 78 pp. 5, 6, 7, 8, 9, 10 ; 117, p. 1).

As discussed in the Site Summary of th is HRS Documentation Record, there is one probable point of entry (PPE). The PPE is considered the discharge point as discussed above. Overland flow (surface water27 drainage) came in to contact with the waste material that was deposited in the landfill. Lea chate 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 disc harge 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, p p. 2, 3, 8, 14, 1 5; 39, p p. 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 , an d 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

- 493 8, 4974, 4983, 5015 ).

N on

- 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, p p. 2, 3, 8, 14, 15; 39, p p. 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) in to 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 photog raphs 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, t o 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 (R efs. 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 notic e 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 Riv er. Inspection reports during this time period (1985 to 1989) indicate that leachate was occurring and ponding on the property (Ref. 68, p p . 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).

L andfill 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 the se material s 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 photograp h 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 p ond. The outfall which was documented during the time when the landfill was active, is no longer present because it w as been filled in some time after 1989 (Ref. 3; 116, p p. 1, 2; Figure 1 of this Documentation Record). The current location of

th e outfall was determined by reviewing historical aerial photographs that showe d a discharge from the

landfill , from past inspection reports, and from an interview with a past state inspector

, who currently is an28 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 histori cal 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 D ocumentation 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 wetl and have been documented by chemical analysis of sediment samples collected during the 2009 E xpanded S ite I nspection (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 Sample s:

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 R iver 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). T he 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. A lthough the Grand Calumet River is

known to sometimes reve rse 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

, 93 0 feet (samples ME2QQ7 ) to as far as 8,115 feet (samples ME2QQ1 and E2QQ2/ME2QQ2) feet upstream from the PPE (Ref . 14 2 , 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 highes t 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 w ere compared to the 0

- 12 inch samples collected from the background samples, and the 12

- 24 inch samples from the adjacent wetland w ere 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 obtain ed 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 conta ined various concentrations of SVOCs and metals. The background samples depicted in the table represent th ose sam ples which had the highest concentration of analytes. The table depicts the sample ID s
, locations, and sample characteristics.29 Background Sed iment Sample L ocation and Comment Table

EPA

Number IDEM

Control Sample Location Comments Percent

Solids 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 phra gmites; 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 a irport

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 t he 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 analyze d 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 fo r 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 contamina nts 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

E2 QQ2 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 Level s

The table below provides a summary of the concentrations of hazardous substances detected in the background wetland s amples 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/Te chLaw 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) Refer ences

ME2QQ2 Chromium (Total)

Silver 472 mg/k g 2.6 (U) mg/kg Not Applicable Not Applicable 2

. 604 m g/ k g 2.604 mg/kg Ref. 121, pp.

4165

- 4173,

4202

E2QQ2 RE Acenaphthene

Anthracene Benzo(a)Anthracene Benzo(a) Pyrene Benzo (b)Fluoranthene Benzo(k)Fluoran thene Chrysene

Fluoranthene

Fluorene

Phenanthrene Pyrene 1 4 ,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) 65,52 0 ug/kg Not Applicable Not Applicable 4,7 00 ug/kg 7,1 00 ug/kg
5,7 00 9,0 00 ug/kg
15 ,000 ug/kg Not Applicable Not Applicable 130,460 ug/kg 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 17,586.207 ug/ k g 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/ k g 27.777 mg/ k g Ref. 121, pp.

4165

- 4173,

4201
ME2QQ7 Lead

Silver 362 mg/kg 5.7 (U) mg/kg Not Applicable Not Applicable 5.747 mg/ k g 5.747 mg/kg Ref. 121, pp.

4165

- 4172, 4174, 4207 ug/ k g micrograms per kilogram mg/kg milligrams per kilogram

U The analyte was analyzed for, but was not detected abov e 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 r eported 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), t he 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: black

10YR2/1*; 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 % Sou theast of first grouping of trees

east end of access road, southern most sample location, east of sample E2QR1 261.73 Color: black

10YR2/1*; slight petroleum odor, sheen on water;

inundated ; sample

obtained from 0

- 12 inches; predominant vegetation is phrag mites 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: black

10YR2/1*; petroleum odor, sheen on water; inundated; sample

obta ined 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: black

10YR2/1*; oil sheen

observed on wate r; 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 the i r respective pages. The percent s olids 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 . (Ref s . 125, p.2 ; 152 ).

* Note: 10YR2/1 is the color co de 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 Contamin ated Sediment Concentration Table
Sample ID Sample

Medium Hazardous Substance Hazardous

S ubstance

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/k g 270,000 ug/k g 600,000 ug/k g 540,000 ug/k g 700,000 ug/k g 500,000 ug/k g 630,000 ug/k g 2,000,000 ug/ k g 440,000 ug/k g 460,000 ug/k g 1,100,000 ug/ k g 115,580.21 ug/k g 115,580.21 ug/k g 115,580.21 ug/k g 115,580.21 ug/k g 115,580.21 ug/k g 115,580.21 ug/ k g 115,580.21 ug/ k g 115,580.21 ug/ k g 115,580.21 ug/ k g 115,580.21 ug/k g 115,580.21 ug/ k g Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable

No t 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/ k g (J) (1,333 mg/ k g) **∗** 2.463 m g/ k g 2.463 mg/k g 2.463 mg/kg

14.778 mg/k g 1,740 mg/ k g 11.7 mg/kg

6,340 mg/ k g Not Applicable Not Applicable Not Applicable Not Applicable Ref. 121, pp.

4165

- 4172

, 4176, 4217

ME2QS0 Sediment Chromium

Silver 2,030 mg/ k g (J) (1,574 mg/ k g) **∗** 2.288 mg/ k g 2.288 mg/kg 5.2 mg/kg Not Applicable

Not Applicable Ref. 1 2 1 , p p

. 4165

- 4172, 4176, 421 8
ME2QR3 Sediment Silver 7.2 mg/kg 2.841 mg/ k g 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 orga nic 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, Exhi bit 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 meta ls 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

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

.34 Attrib ution:

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 allow ed 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 Riv er (Ref. 12, p. 2; 27, p. 4). No NPDES permit was ever obtained.

Analysis of the wetland sediment samples obtained at the sout heast 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 th is HRS documentation record).

Because of the highly permeable nature of the Calu met 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 m aintained, in addition to the direct discharge, the landfill may have leak ed hazardous substances into the adjacent wetlands

located at the southeast corner of the landfill (Ref s

. 71, pp. 5, 6; 78, pp. 3, 4, 5, 6, 7, 8 ; 92, p. 7; 117, p p . 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 (EP A ID: IND980794432): The Ninth A venue 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

r eportedly 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). Groun d 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. 1 4 ).

2) Conservation Chemical (EPA ID: IND040888992): Conserva tion 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 9 00 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). A ny 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 Landfil l35 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 Sedime n t 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 Compa ny 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 bor d er 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) Rola nd Dump (AKA Site #73)(EPA ID: IND98050057): Roland Dump is located approximately

5500 feet north

- northeast of the G ary Development Landfill (Reference 146). Roland Dump was a pit that may have been used for sand excavation at one time was filled with wate r 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

exist ed (Ref. 134, p. 2).

6) Vulcan Materials (AKA AMG) (IND005444732): Vulcan Materials is loca ted 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.

1 33, 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) propert y (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, a ny surface water runoff from this facility would be expected t o 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 8 000 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 t he 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 sedim ents 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 (IND9806795 59)

– 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 surf icial wastes, the subsurface soil and ground water were found to be highly

contaminated ( Ref. 140, p. 1)

. Cont aminants 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

ac cidental 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 facili ty'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 sho wn 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 s ubstances have been release d : 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 Rele ase 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

ec osystem 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/persisten ce/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 Fact or 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.5137 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 50,000,0 00 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 sensi tive 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 10 8

4.1.4.2.2 Hazardous Waste Quan tity

Source No. Source Type Source Hazardous Waste Quantity

1 Landfill 38,902

Sum of Values: 38,902

Hazardous Waste Quantity Factor Value: 10

, 0 00 (Ref. 1, Section 2.4.2.2, Table 2

- 6 )

4.1.4.2.3 Waste Characteristics Factor Category Value

The envir onmental 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 10 8 . Then multiply the product by the ecosystem bioaccumulation potential factor value for that hazardous substance, subject to a maximum product of 1 x 10 12 (Ref. 1, Section 4.1.4.2.3, p. 51624). The product is assigned a waste characteristic s factor category value from HRS Table 2

- 7 (Re f. 1, Section 2.4.3.1, p. 51592). The values presented below are for benz o (a)pyrene and mercury

.

Ecosystem Toxicity/Persistence Factor Value: 10,000 Hazardous Waste Quantity Factor Value: 10

, 0 00 Bioaccumulation Potential Factor Value: 50,00038 10,000 (Eco tox) X 10

, 0 00 (Hazardous Waste Quantity is 10

, 0 00 ) = 1 x 10 8 X 50,000 (Bio a ccumulation) = 5 X

10 12

Then enter 5 X 10 12 into HRS Table 2

- 7

HRS Table 2

- 7 yields a waste characteristics factor category value of 1,000

Waste Characteristics Factor Category Va lue: 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 Sensit ive 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 ( C istothorus 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 t he 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 fou nd 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 Haza rd 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, an d 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 ha s become contaminated with various concentrations of lead, chromium, zinc and

numerous SVO Cs 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. 51 624). The wetland is considered an area/habitat known to be used by the marsh wren, C istothorus 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 se diment. 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, p p. 165, 177, 179, 180).

The table below lists the sens itive environments that have been impacted and their associated sensitive

environment value s

.

Sensitive Environment Distance from PPE to

Nearest Sensitive

Environment Reference Sensitive Environment Value (Table 4

- 23)

Habitat known to be used by State de signated endangered species,

m arsh w ren ( C istothorus 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, p p. 165

, 166 , 179 25

T he PPE is in the wetland sensitive environment. There is evidence that numerous s tate 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 uncle ar 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 requiremen ts 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 distan ce 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 poi nts 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 Docum entation 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. (Ref s . 125, p. 2 ; 153 ). The assigned HRS wetland value fo r 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 + 2540 Level II Concentrations Factor Value: 100

5.0 S OIL E XPOSURE P ATHWAY

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.