INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Mitchell E. 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 of the 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 of the contamination at LaSalle Park is historic dumping of waste 

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 of the adjacent apartment complex, which is located at the western edge of the 

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. 

Recycled Paper ® 	 An Equal Opportunity Employer Please Recycle 0 
Ms. 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 of the 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 of the 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 of the Beck's Lake Site as a SAA 

site under supervision of the U.S. EPA. I request that the U.S. EPA assign staff 

appropriate to implement the process of the 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 of the 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. EPA 
Date: 1-30-12 DELIBERATIVE AND CONFIDENTIAL 

Briefing Paper 

Indiana Department of Environmental Management 

Site Name, City and County: Beck's Lake Site, South Bend, st. Joseph County 

Issue: 

• 	 A city park and nearby residences have been impacted with elevated levels of arsenic from historic 

dumping ofindustrial waste from the 1930's to 1970's. The source ofthe contamination was a 

former dump site used by the Bendix Corporation. The Bendix Corporation deposited their waste 

material into the dump which was not far from their manufacturing facility. The dump site was 

converted into a city park with a small pond, 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 being proposed for a Superfund Alternative Site under the authority of the 

Comprehensive Environmental Response Compensation and Liability Act of 1984 (CERCLA). 

Superfund Alternative Site Approach: 

U.S. EPA has two main paths to achieve cleanup at Superfund caliber sites that require long-term 

remediation. The traditional path involves EPA listing the site on the NPL, identifying the PRPs, and 

working with them to secure the cleanup or payment for cleanup. The alternative is known as the 

Superfund Alternative Approach ("SA" or "SAA"), which is designed to parallel the NPL path with 

the exception of listing the site on the NPL. A SAA site should: 

• 	 be eligible for inclusion on the NPL (i.e., currently proposed to the NPL, or would score 

above 28.5); 

• 	 require long-term response action; and 

• 	 have financially viable and capable PRPs that the U.S. EPA Region believes are willing to 

perform the cleanup work under 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. Sampling results from the investigation indicated that residential soils near Beck's Lake 

contained elevated levels of arsenic, exceeding benchmarks for health risks. 

• 	 The responsible party is believed to be Honeywell Corporation through their acquisition ofBendix, 

and Allied Signal's former holdings. Because Honeywell appears to be a viable RP and the site is a 

Superfund caliber site, it is recommended that the Beck's Lake Site should be given a Superfund 

Alternative Approach designation unless the responsible party proves recalcitrant. 

History: The Beck's Lake Site is currently owned by the City of South Bend's Parks Department. The 

Park was acquired from the South Bend Redevelopment Commission in 1960. Historical aerial photos 

document that prior to the property's development for a park the site was used as a dump site for industrial 

material since as early as 1938. A CERCLA 1 03(c) notification prepared by the Bendix Corporation 

identified this site as a location where they disposed ofmaterials including but not limited to asbestos, 

plating wastes, solvents, paint wastes, oils and sludges, and foundry sand that contained among other 

contaminants, arsenic. Part ofthe original filled area was divided offby Falcon Street and has subsequently 
become residential property. The rest ofthe filled area is now LaSalle Park. Beck's Lake is within the 

boundaries ofLaSalle Park. 

CERCLIS actions at the site began in 1985 with a Preliminary Assessment. A Site Inspection was 

conducted there in 1989, an Expanded Site Inspection was 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 of the fmdings of a 

Brownfields Program Environmental Assessment. The findings ofthe RA revealed that arsenic levels in the 

nearby neighborhood to Beck's Lake were elevated. A second ESI conducted in 2010 identified the Beck's 

Lake site as a source for the elevated levels of arsenic. 

Community Position: The area surrounding Beck's Lake is an environmental justice area. The residents of 

the neighborhood were sensitive to the possibility that fish in Beck's Lake may not be completely safe to 

consume. This information was discussed in a public meeting at the Brownfield Environmental Assessment 

stage. Some residents also fear what is buried under a hill on the park property adjacent to Beck's Lake. The 

hill is obviously man made but 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 of Beck's 

Lake. 

I . 

Impact: Elevated levels of arsenic from the industrial dumping at Beck's Lake have adversely impacted 

adjacent residential soils. Remediation ofthe site is needed to make the residential soils near Beck's Lake 

safe for residential use. 

Next Steps: 

• The Commissioner's signature on the attached letter is required for designating the site as a SAA. 

• The U.S.EP A, Region 5, will propose to EPA headquarters to designate the site a Superfund 

Alternative Approach site. 

• U. S. EPA will negotiate with the responsible party for Bendix's former activities to address the 

contamination near Beck's Lake. The responsible party is believed to be Honeywell Corporation 

through their acquisition ofBendix, and Allied Signal's former holdings. 

IAdditional Comments: 

For More Information Contact: 

Gabriele Hauer, Section Chief 

Site Investigation Program 

233-2773