INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT We ProtectHoosiers and OurEnvironment. MitchellE. Daniels,!r. 100 North Senate Avenue Governor Indianapolis, Indiana 46204 (317) 232-8603 Thomas W Easterly Toll Free (800) 451-6027 Commissioner www.idem.IN.gov
February 1, 2012 Ms. Susan Hedman Regional Administrator U.S. EPA, Region V, R-19J 77 West Jackson Boulevard Chicago, Illinois 60604-3507 Dear Ms. Hedman: Re: Beck's Lake Site South Bend, St. Joseph County, Indiana

- Designation as a Superfund Alternative

Approach The Indiana Department of Environmental Management (IDEM) is providing this letter to convey its support to the United States Environmental Protection Agency (U.S. EPA) regarding the designation ofthe Beck's Lake Site located in South Bend, St. Joseph County, Indiana, as a Superfund Altemative Approach (SAA). The Beck's Lake Site, U.S. EPA 

### 10# IND980904379, is bordered on three sides by residential housing and on one side by a wooded area. The site includes a city park (LaSalle Park) and an adjacent apartment complex. The source ofthe contamination at LaSalle Park is historic dumping ofwaste material that took place there from the 1930's through the 1970's. The Beck's Lake area was once filled with waste material from a nearby manufacturer of automotive parts. The waste material was contaminated with high levels of arsenic and lead. As a result, there appears to be ongoing potential exposure of residents including but not limited to residents ofthe adjacent apartment complex, which is located at the western edge ofthe fill area that is contaminated with levels of arsenic considered unsafe for residential settings. The neighborhood around the site has readily apparent environmental justice implications. Historically, the community near Beck's Lake (LaSalle Park) has been vocal about their concerns for environmental conditions surrounding this site. The threshold eligibility criteria for using the Superfund Alternative Approach are: 1) Site contaminants are significant enough that the site would be eligible for listing on the National Priorities List of Hazardous Waste Sites (NPL) because the site would have a Hazard Ranking Score (HRS) 

### <: 28.5. 2) The site requires a long term response action.

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### 0Ms. Susan Hedman Regional Administrator Page 2

3) There is a willing and capable potentially responsible party (PRP) to perform the investigation or cleanup. A SAA approach would allow for proper and timely investigation of the nature and extent ofthe contamination and enable the responsible party or parties to determine cleanup alternatives for the impacted area that adequately protect the health of affected individuals while preserving federal funds. A SAA designation appears to be the most viable alternative for addressing the existing environmental problems surrounding the Beck's Lake Site. If in the future, the U.S. EPA determines that the responsible party or parties are not willing or capable of performing the investigation ofthe Beck's Lake Site, IDEM would support the decision to include the Beck's Lake Site on the NPL. As the Commissioner of IDEM, I am authorized by Indiana Governor Mitchell E. Daniels to act in these matters on his behalf. I have considered my staff's recommendations and I fully support the designation ofthe Beck's Lake Site as a SAA site under supervision ofthe U.S. EPA. I request that the U.S. EPA assign staff appropriate to implement the process ofthe SAA. To expedite the process and reduce administrative expense, IDEM will share available site information with U.S. EPA. If you require any additional information or have any additional questions please don't hesitate to contact Gabriele Hauer, Chief ofthe Site Investigation Section at (317) 233-2773. Sincerely,

Thomas W. Easterly Commissioner

cc: Denise Boone, U.S. EPA Nuria Muniz, U.S. EPA Colleen Moynihan, U.S. EPA Mary Fulghum, U.S. EPADate: 1-30-12 DELIBERATIVE AND CONFIDENTIAL Briefing Paper Indiana Department ofEnvironmentalManagement

Site Name, City and County: Beck's Lake Site, South Bend, st. Joseph County
Issue: • A citypark and nearbyresidences have been impacted with elevated levels ofarsenic from historic dumping ofindustrial waste from the 1930'sto 1970's. The source ofthe contamination was a former dumpsiteused bythe Bendix Corporation. The Bendix Corporation deposited theirwaste material into the dump which was not far from their manufacturing facility. The dumpsite was convertedinto a citypark with a smallpond, now known as LaSalle Park. Beck's Lake is part of LaSalle Park.

• The Beck's Lake site qualifies to be included on the National Priorities List (NPL) ofHazardous Waste Sites and is beingproposed for a Superfund Alternative Site under the authority ofthe Comprehensive Environmental Response Compensation and LiabilityAct of 1984 (CERCLA). Superfund Alternative Site Approach: U.S. EPAhas two main paths to achieve cleanup at Superfund caliber sites thatrequire long-term remediation. The traditional pathinvolves EPA listing the site onthe NPL, identifying the PRPs, and working with them to secure the cleanup or payment for cleanup. The alternative is known as the SuperfundAlternative Approach ("SA" or "SAA"), which is designed to parallel the NPL pathwith the exception oflisting the site onthe NPL. A SAA site should: • be eligible for inclusion onthe NPL (i.e., currentlyproposedto the NPL, orwould score above 28.5); • require long-term response action; and • have financially viable and capable PRPs that the U.S. EPA Regionbelieves are willing to performthe cleanup workunder an appropriate settlement agreement.
IDEM's Position/Action: • IDEM, under a Cooperative Agreement with the U.S. EPA, Region V, conducted an Expanded Site Inspection at the site in an attempt to determine the source ofthe arsenic contamination in residential yards. Samplingresults from the investigationindicated that residential soils nearBeck's Lake contained elevated levels ofarsenic, exceedingbenchmarks for healthrisks. • The responsible partyis believedto be Honeywell Corporation through their acquisition ofBendix, and Allied Signal's former holdings. BecauseHoneywell appears to be a viable RP and the site is a Superfund caliber site, it is recommended that the Beck's Lake Site shouldbe given a Superfund Alternative Approach designation unless the responsible partyproves recalcitrant.
History: The Beck's Lake Site is currently ownedbythe City ofSouthBend'sParks Department. The Parkwas acquired from the SouthBendRedevelopment Commissionin 1960. Historical aerial photos document that priorto the property's development for aparkthe site was used as a dumpsite for industrial material since as early as 1938. A CERCLA 1 03(c) notificationpreparedbythe Bendix Corporation identifiedthis site as a location where they disposed ofmaterials includingbutnot limited to asbestos, plating wastes, solvents, paint wastes, oils and sludges, and foundry sand that contained among other contaminants, arsenic. Part ofthe original filled areawas divided offbyFalcon Street and has subsequentlybecome residential property. The rest ofthe filled area is now LaSalle Park. Beck'sLake is within the boundaries ofLaSalle Park. CERCLIS actions at the sitebegan in 1985 with a PreliminaryAssessment. A Site Inspection was conductedthere in 1989, anExpanded Site Inspectionwas conducted in 1996, and the site was archived in the same year. In 2003, the site was reopened with a Reassessment (RA) as a result ofthe fmdings ofa Brownfields Program Environmental Assessment. The findings ofthe RArevealed that arsenic levels inthe nearby neighborhood to Beck's Lake were elevated. A second ESI conductedin 2010 identified the Beck's Lake site as a source for the elevated levels ofarsenic.

Community Position: The area surrounding Beck'sLake is an environmentaljustice area. The residents of the neighborhood were sensitive to the possibility that fish in Beck's Lake may notbe completely safe to consume. This informationwas discussed in apublic meeting at the Brownfield Environmental Assessment stage. Some residents also fear what is buriedunder a hill onthepark property adjacent to Beck's Lake. The hill is obviouslymanmadebut it is unclear whether the hill consists ofbuilding debris from the demolition ofpublic housing that once sat on the site or whether it is overburden from the actual construction ofBeck's Lake.

I . Impact: Elevated levels ofarsenic from the industrial dumping at Beck'sLake have adversely impacted adjacent residential soils. Remediation ofthe site is needed to make theresidential soils near Beck's Lake safe for residential use. Next Steps: • The Commissioner's signature onthe attached letter is required for designating the site as a SAA. • The U.S.EPA, Region 5, will propose to EPA headquarters to designate the site a Superfund Alternative Approach site. • U. S. EPAwillnegotiate withtheresponsible partyfor Bendix's former activities to address the contaminationnear Beck's Lake. The responsible partyisbelievedto be Honeywell Corporation through their acquisition ofBendix, and Allied Signal's former holdings. 

# I Additional Comments:

ForMore Information Contact: Gabriele Hauer, Section Chief Site Investigation Program 233-2773