HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD--REVIEW COVER SHEET

Name of Site: Garden City Ground Water Plume

U.S.EPA ID No.: INN000508642

Date Prepared: May 2013

Contact Persons

Site Investigation: Richard R. Milton, Indiana Department of Environmental Management(IDEM), 

Site Investigation Program, (317) 234-6878

Mark Jaworski, Indiana Department of Environmental Management (IDEM), 

Site Investigation Program, (317) 233-2407

Documentation Record: Nuria Muniz, United States Environmental Protection Agency (U.S.EPA), 

Region V, (312) 886-4439

Richard R. Milton, Indiana Department of Environmental Management (IDEM), 

Site Investigation Program, (317) 234-6878

Mark Jaworski, Indiana Department of Environmental Management(IDEM), 

Site Investigation Program, (317) 233-2407

Pathways, Components, or Threats Not Scored

Surface Water Migration Pathway, Soil Exposure Pathway, and Air Migration Pathway

The Surface Water Migration Pathway, Soil Exposure Pathway, and Air Migration Pathway were not scored as part of 

this Hazard Ranking System (HRS) evaluation. These pathways were not included because a release to these media do

not significantly affect the overall site score and because the ground water pathway produces an overall site score above 

the minimum required for the site to qualify for inclusion on the National Priorities List (NPL). 
1 

HRS DOCUMENTATION RECORD

Name of Site: Garden City Ground Water Plume

U.S.EPA Identification No.: INN000508642

U.S.EPA Region: 5

Date Prepared: May 2013

Street Address of Site*: The intersection of Jonesville Road (State Road 11) and County Road 100 South

(aka Garden Street), Garden City. (Figure 1-2 of this HRS documentation record)

City, County/State/Zip Code: Garden City, Bartholomew County, Indiana 47201

General Location in the State: South Central Indiana (Figure 1-1 of this HRS documentation record) 

Topographic Map: Columbus, Indiana Quad (7.5’) (Ref. 3, p. 1)

Latitude: 39°11'9.87" N 

Longitude: 85°55'49.7" W

Site Reference Point: *The intersection of Jonesville Road (State Road 11) and County Road 100 South. 

(aka Garden Street), Garden City. The intersection is the approximate center of 

the highest known TCE concentrations in the ground water plume.

Congressional District: 6

* Note: The street address, coordinates, and sample locations presented in this HRS documentation record identify the 

general area the site is located. They represent one or more locations EPA considers to be part of the site based on the 

screening information EPA used to evaluate the site for NPL listing. EPA lists national priorities among the known 

“releases or threatened releases" of hazardous substances; thus, the focus is on the release, not precisely delineated 

boundaries. A site is defined as where a hazardous substance has been “deposited, stored, disposed, or placed, or has 

otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release merely represent the 

initial determination that a certain area may need to be addressed under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of 

facility boundaries at the time of scoring will be refined as more information is developed as to where the 

contamination has come to be located. 

SITE SCORING SUMMARY

Pathway Scores: 

Air Pathway Not Scored

Ground Water Pathway 100.00

Soil Exposure Pathway Not Scored

Surface Water Pathway Not Scored

HRS SITE SCORE 50.00
2 

WORKSHEET FOR COMPUTING HRS SITE SCORE

1. Ground Water Migration Pathway Score (Sgw)

S S2

(HRS Scoresheet Table 3-1, line 13) 100 10,000

2a. Surface Water Overland/Flood MigrationComponent NS 

2b. Ground Water to Surface Water MigrationComponent NS

2c. Surface Water Migration Pathway Score (Ssw) NS 

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

3. Soil Exposure Pathway Score (Ss) NS

4. Air Migration Pathway Score (Sa) NS

5. Total of Sgw2+ Ssw2 + Ss2 + Sa2 10,000

 

6. HRS Site Score

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

root

NS = Not Scored

50.00
3 

 TABLE 3-1 

GROUND WATER MIGRATION COMPONENT SCORESHEET

Factor categories and factors Maximum 

Value

Value 

Assigned

Likelihood of Release to an Aquifer: 

1. Observed Release 550 550

2. Potential to Release:

2a. Containment 10 NS

2b. Net Precipitation 10 NS

2c. Depth to Aquifer 5 NS

2d. Travel Time 35 NS

2e. Potential to Release [lines 2a(2b + 2c + 2d)] 500 NS

3. Likelihood of Release (higher of lines 1 and 2e) 550 550

Waste Characteristics:

4. Toxicity/Mobility (a) 1000

5. Hazardous Waste Quantity (a) 100

6. Waste Characteristics 100 18

Targets:

7. Nearest Well 50 50

8. Population:

8a. Level I Concentrations (b) 1395

8b. Level II Concentrations (b) 3

8c. Potential Contamination (b) NS

8d. Population (lines 8a + 8b + 8c) (b) 1398

9. Resources 5 5

10. Wellhead Protection Area 20 20

11. Targets (lines 7 + 8d + 9 + 10) (b) 1473

Ground Water Migration Score for an Aquifer: 

12. Aquifer Score [(lines 3 x 6 x 11)/82,5000]c

550 x 18 x 1473 =14,582,700 / 82,500 = 176.76 or Max. Value 100.00 100 100.00

Maximum 

Value

Value 

Assigned

Ground Water Migration Pathway Score:

13. Pathway Score (Sgw), (highest value from line 12 for all aquifers evaluated)c 100 100.00 a Maximum value applies to waste characteristics category b Maximum value not applicable c Do not round to nearest integer

NS - Not Scored
 

 

 

 

 

 

 

 

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Garden City Ground Water Plume - EPA FID INN000508642

Garden City, Bartholomew County, IN

Area Location Map 

μ 

Sources:

Non Orthophotography Data 

- Obtained from the State of Indiana

Geographical Information Office Library

Orthophotography

- Obtained from 2005 Indiana Map

Framework Data (www.indianamap.org)

Map Projection: UTM Zone 16 N

Map Datum: NAD83 

") 

Bartholomew

County 

§ ̈¦65

«£¤31

11 

«58 

«9 FG! Garden City Ground Water Plume «46 Columbus

Figure 1-1 

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: Diane Osborn, Office of Land Quality

Date: March 12, 2013 

0 10 20 40 Miles 

0 20 40 60 10 KM 

Document Sources: 

- IDEM Expanded Site Inspection Report for Garden City GW Plume, INN000508642, January, 2012 
FG!

Elliott St

Garden City Ground Water Plume

Intersection Jonesville Road (SR 11) 

and Garden St (CR 100 N)

Latitude 39o

11'9.87" N

Longitude 85o

55'49.7" W

Miller Salvage

¬«11

¬«46

Garden St

Spears St

Water St

Kenmill St

Garden Rd

South Side

William St

Haw Creek

East Fork White River

Twin

Lakes

LIRC

Garden City Ground Water Plume - EPA FID INN000508642

Garden City, Bartholomew County, IN

Expanded Area Location Map

μ

Sources:

Non Orthophotography Data

- Obtained from the State of Indiana 

 Geographical Information Office Library

Orthophotography 

- Obtained from 2005 Indiana Map 

 Framework Data (www.indianamap.org) 

Map Projection: UTM Zone 16 N 

Map Datum: NAD83

Bartholomew

 County

§ ̈¦65

¬«£¤31

11

¬«58

¬«9

¬«46 Columbus FG! Garden City Ground Water Plume

 Miller Salvage

Figure 1-2

Document Sources:

 - IDEM Expanded Site Inspection Report for Garden City GW Plume, INN000508642, January, 2012 

 - IDEM Site Reassessment Report for Miller Salvage Site, IND980607618, January, 2012 

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: Diane Osborn, Office of Land Quality

Date: March 12, 2013

0 400 800 1,200 200 Feet

0 100 200 300 400 50 Meters
FG!

!%

!%

Elliott St

Garden City Ground Water Plume

Intersection Jonesville Road (SR 11) 

and Garden St (CR 100 N)

Latitude 39o

11'9.87" N

Longitude 85o

55'49.7" W

Miller Salvage

¬«11

¬«46

Garden St

Spears St

Water St

Kenmill St

Garden Rd

South

Side

William St

Haw Creek

East Fork White River

Twin

Lakes

LIRC

Salvage Yard

East Fork - White River

Affected Private

Residences

Additional Concrete Storage

Private Residences

Mobile Home Park

Concrete Products

Manufacturing and Storage

Drive-in Restaurant

Car Lot

Columbus

Water Treatment Plant

Assorted Businesses

Columbus

Municipal Well 9

Columbus

Municipal Well 12

Garden City Ground Water Plume - EPA FID INN000508642

Garden City, Bartholomew County, IN

Area Features Map

μ

Sources:

Non Orthophotography Data

- Obtained from the State of Indiana 

 Geographical Information Office Library

- Municipal Well locations obtained from 

 IDEM OLQ Sampling Database (SampDB)

Orthophotography 

- Obtained from 2005 Indiana Map 

 Framework Data (www.indianamap.org) 

Map Projection: UTM Zone 16 N 

Map Datum: NAD83

Bartholomew

 County

§ ̈¦65

¬«£¤31

11

¬«58

¬«9

¬«46 Columbus

!% Municipal Well

FG! Garden City Ground Water Plume

 Miller Salvage

Figure 1-3

{

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: Diane Osborn, Office of Land Quality

Date: March 12, 2013

0 400 800 1,200 200 Feet

0 100 200 300 400 50 Meters

Document Sources:

 - IDEM Expanded Site Inspection Report for Garden City GW Plume, INN000508642, January, 2012 

 - IDEM Site Reassessment Report for Miller Salvage Site, IND980607618, January, 2012 
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jk!

Elliott St

Garden City Ground Water Plume

Intersection Jonesville Road (SR 11) 

and Garden St (CR 100 N)

Latitude 39o

11'9.87" N

Longitude 85o

55'49.7" W

Miller Salvage

¬«11

¬«46

Garden St

Spears St

Water St

Kenmill St

Garden Rd

William St

Haw Creek

East Fork White River

Twin

Lakes

LIRC

GW12 - E2S79

TCE = 15 ug/L

GW13 - E2S45

TCE = 15 ug/L

GW19 - E2S47

TCE = 4.2 ug/L

GW05 - E2S80

TCE = 2.2 ug/L

GW06 - E2S81

TCE = 2.2 ug/L

GW30 - E2S11

Columbus Municipal Well 12

TCE = 0.66 ug/L

GW31 - E2S51

Columbus Municipal Well 9

TCE = 0.35 ug/L (J)

GW16 - E2S4

TCE = 0.71 ug/L

GW04 - E2S82

TCE = 1.3 ug/L

GW15 - E2S48

TCE = 2.9 ug/L

GW18 - E2S49

TCE = 2.5 ug/L

Ground Water Plume Area

 3.450 acres

150,279.034 ft2

 13,961.435 m2

Flatrock River

East Fork White River

GW01 - E2SB2

Shallow Ground Water Background

Below TCE Detectable Limit (0.5 ug/L U)

GW02 - E2SB0

Shallow Ground Water Background

Below TCE Detectable Limit (0.5 ug/L U)

GW20 - E2S42

Intermediate Ground Water Background

Below TCE Detectable Limit (0.5 ug/L U)

Garden City Ground Water Plume - EPA FID INN000508642

Garden City, Bartholomew County, IN

Garden City Ground Water Plume Boundary Map

μ

Sources:

Non Orthophotography Data

- Obtained from the State of Indiana 

 Geographical Information Office Library

- Sample Locations and Analytical Results

 are obtained from IDEM OLQ Sampling

 Database (SampDB)

Orthophotography 

- Obtained from 2005 Indiana Map 

 Framework Data (www.indianamap.org) 

Map Projection: UTM Zone 16 N 

Map Datum: NAD83

Bartholomew

 County

§ ̈¦65

¬«£¤31

11

¬«58

¬«9

¬«46 Columbus

Figure 1-4

Document Sources:

 - IDEM Expanded Site Inspection Report for Garden City GW Plume, INN000508642, January, 2012 

 - IDEM Site Reassessment Report for Miller Salvage Site, IND980607618, January, 2012 

FG! Garden City Ground Water Plume

 Miller Salvage

 Digitized by connecting sample locations that

 meet observed release criteria

 Approximate Ground Water Plume Boundary

 TCE: Trichloroethylene

 ug/L: microgram/Liter

jk! Ground Water Sample Location

jk! Ground Water Background Sample Location

U: Analyzed sample result Not Detected above

 the reported sample quantitation limit 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: Diane Osborn, Office of Land Quality

Date: March 12, 2013

0 200 400 600 800 100 Feet

0 100 200 300 50 Meters
FG!

Elliott St

Various Non-Hazardous

Waste Producing Businesses

(e.g., Restaurant, Plant Nursery, 

Trucking Warehouse, Car Lot, etc.) {

Garden City Ground Water Plume

Intersection Jonesville Road (SR 11) 

and Garden St (CR 100 N)

Latitude 39o

11'9.87" N

Longitude 85o

55'49.7" W

Miller Salvage 

CERCLIS ID

IND980607618

¬«11

¬«46

Garden St

Spears St

Water St

Kenmill St

Garden Rd

South

Side

William St

Haw Creek

East Fork White River

Twin

Lakes

LIRC

Miller Salvage

(Burn Pit Area)

Additional Devening

Block Property

Joe Boaz 

Site Number 2

CERCLIS ID

IND981094121

Devening Block Company

Kiel Bros. Site

CERCLIS ID

IND985046903

Columbus Old Municipal

Landfill 1

CERCLIS ID

IND980607626

Garden City Ground Water Plume - EPA FID INN000508642

Garden City, Bartholomew County, IN

Potential Sources Map

μ

Sources:

Non Orthophotography Data

- Obtained from the State of Indiana 

 Geographical Information Office Library

Orthophotography 

- Obtained from 2005 Indiana Map 

 Framework Data (www.indianamap.org) 

Map Projection: UTM Zone 16 N 

Map Datum: NAD83

Bartholomew

 County

§ ̈¦65

¬«£¤31

11

¬«58

¬«9

¬«46 Columbus FG! Garden City Ground Water Plume

 Miller Salvage

Figure 1-5

Document Sources:

 - IDEM Expanded Site Inspection Report for Garden City GW Plume, INN000508642, January, 2012 - US EPA Record of Decision for Columbus Old Municipal Landfill 1, IND980607626, March, 1992

 - IDEM Site Reassessment Report for Miller Salvage Site, IND980607618, January, 2012 - IDEM Preliminary Assessment for Joe Boaz, September, 1985

 - IDEM Preliminary Assessment for Kiel Bros. Oil Co., September, 1992 

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: Diane Osborn, Office of Land Quality

Date: March 12, 2013

0 400 800 1,200 200 Feet

0 100 200 300 400 50 Meters
FG!

!%

!%

Elliott St

Lincoln St

!%

Garden City Ground Water Plume

Intersection Jonesville Road (SR 11) 

and Garden St (CR 100 N)

Latitude 39o

11'9.87" N

Longitude 85o

55'49.7" W

Miller Salvage

Columbus

Municipal Well 9

Columbus

Municipal Well 12

§ ̈¦65

¬«46

¬«11

BELLSVILLE RD

CARR HILL RD

SPEAR ST

W 230 S SOUTH SIDE

S 130 W

S 150 W

S 225 W

S Beatty Ln

5th St

4th St

W Carr Hill Rd

Blessing Rd

Indiana Ave

Franklin St

1st St

Jones St

Hege Ave

Water St

McKinley Ave

Chestnut St

California St

S Mutz Dr

S Beatty St

B

Stadler Dr

rex Park

Sycamore St

Wandering Way

Lafayette Ave

W 200 S

Garden St

Dawson St

Pearl St

Kenmill St

Oak St

Huffman Dr

Reo St

Brown St

Kyte St

Jefferson St

Cross Creek Dr

Georgia Ave

Appleblossom Ln

Volmer St

County Road 150 W

William St

Haw Creek Blvd

Opossum Creek

Haw Creek

Denios Creek

Flatrock River

East Fork White River

Driftwood River

Twin

Lakes

LIRC

Unknown RR

Unknown RR

Columbus

Water Treatment Plant

Garden City Ground Water Plume - EPA FID INN000508642

Garden City, Bartholomew County, IN

Columbus Southern Wellhead Protection Area (WHPA) Map

μ

Sources:

Non Orthophotography Data

- Obtained from the State of Indiana 

 Geographical Information Office Library

- Municipal Well locations obtained from 

 IDEM OLQ Sampling Database (SampDB)

Orthophotography 

- Obtained from 2005 Indiana Map 

 Framework Data (www.indianamap.org) 

Map Projection: UTM Zone 16 N 

Map Datum: NAD83

Bartholomew

 County

§ ̈¦65

¬«£¤31

11

¬«58

¬«9

¬«46 Columbus

Figure 1-6

Columbus Municipal Utility

 WHPA - 1 Year Travel Time

 WHPA - 5 Year Travel Time

!% Municipal Well

!% Water Treatment Plant

FG! Garden City Ground Water Plume

 Miller Salvage

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: Diane Osborn, Office of Land Quality

Date: March 12, 2013

0 500 1,000 2,000 3,000 Feet

0 200 400 600 800 1,000 100 Meters

Document Sources:

 - IDEM Expanded Site Inspection Report for Garden City GW Plume, INN000508642, January, 2012 - City of Columbus, Wellhead Protection Program, Pollution Source Inventory, Contingency Plan, 

 - IDEM Site Reassessment Report for Miller Salvage Site, IND980607618, January, 2012 Management Plan, December 2000, revised October 2009
10 

REFERENCES

 Reference

Number Description of the Reference

1. U.S. Environmental Protection Agency (U.S. EPA), Hazard Ranking System, 55 FR 

51532, December 19, 1990. 138 pages. An electronic copy of the HRS is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRSRule. 

2. U.S. EPA, Superfund Chemical Data Matrix (SCDM), March 2012. 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. Excerpt, 10 pages. 

3. U.S. Geological Survey, Columbus, Indiana 7.5 Minute Topographic Quadrangle 

Map. 1962 (Photorevised 1988). Indiana Department of Natural Resources, 

Unconsolidated Aquifer Systems of Bartholomew County, Indiana. December 2004. 

2 pages. 

4. CH2M Hill, Ecology & Environment, Inc., Miller Salvage Site Inspection Report, 

November 4, 1985, 110 pages. VFC Document Number 49929900. This reference, 

and the following VFC numbered references, can be accessed electronically at the 

Indiana Department of Environmental Management (IDEM), Virtual File Cabinet 

(VFC), http://108.59.49.89/Pages/Public/Search.aspx. 

5. Indiana Department of Environmental Management (IDEM), 

Kiel Bros. Oil Company Preliminary Assessment, September 25, 1992. 

 220 pages. VFC Document Number 47626014. 

6. IDEM, Garden City Ground Water Plume Preliminary Assessment/Site Investigation 

Report, September 30, 2005. 336 pages. VFC Document Number 47774955. 

7. IDEM, Garden City Ground Water Plume Expanded Site Inspection Report, January 

2012. 197 pages. VFC Document Number 65846805. 

8. IDEM, Miller Salvage Site Reassessment Report, January 2012. 155 pages. 

VFC Document Number 66336419. 

9. IDEM, Office of Solid and Hazardous Waste, Emergency Response Branch, Initial 

Incident Report Log, March 3, 1990. 2 pages. VFC Document Number 47751318. 

10. Cummins Engine Company, Notification of Hazardous Waste Site, July 31, 1981. 

Ecology & Environment, Inc. Telephone Log, Re: Cummins Engine Co. September 

29, 1987. Indiana State Board of Health, Field Inspection Notes from 8/14/1984 site 

visit. 6 pages. VFC Document Number 49982580. 
11 

11. IDEM, Drinking Water Branch Website

https://myweb.in.gov/IDEM/DWW/index.jsp. Garden City MHP Water System 

Number IN5203005, 2 pages. 

12. Columbus City Utilities, Columbus, Indiana. Water Quality Report 2012, 4 pages. 

13. United States Census Bureau, Bartholomew County, Indiana Quick Facts. Last 

Revised Aug. 16, 2012. Accessed Sept. 11, 2012. 2 pages.

 http://quickfacts.census.gov/qfd/states/18/18005.html. 

14. John Thompson, Columbus City Utilities, electronic mail to Richard Milton, IDEM, 

December 1, 2011. Subject: Columbus Utilities information. 1 page.

15. IDEM, Office Memorandum from Sarah Finley-Johanson, Geological Services, to 

Rick Milton, Site Investigation Section. Subject: Geologic Assessment, Garden City 

Ground Water Contamination. February 18, 2013. 4 pages. VFC Document Number 

66055968. 

16. Hoosier Environmental Services, Inc. Hydrogeological Assessment Draft Report and 

Proposed Work Plan, March 8, 1991. 66 pages. VFC Document Number 25207825. 

17. Reference Number Reserved. 

18. IDEM, Office of Emergency Response, handwritten notes with various dates. 

Indiana Department of Natural Resources, Water Well Records, Bartholomew 

County. 38 pages. VFC Document Number 47751730. 

19. IDEM, correspondence to Kiel Bros. Oil Company, March 7, 1990. 2 pages.

20. IDEM, Mark Jaworski, electronic mail to Richard Milton, August 14, 2012. Subject: 

Number of employees and well depth at Musillami’s Drive-In. 1 page.

21. Reference Number Reserved. 

22. IDEM, Margie Delashmit, Office Memorandum to Karla McDonald, LUST Section, 

July 2 and 26, 1991. Subject: Receipt of data package and preliminary results of 

ground water samples. 5 pages. VFC Document Number 47750998. 

23. ATEC Environmental Consultants, Monitoring Well Installation Report, Kiel 

Brothers Oil Company. July 24, 1991. 22 pages. VFC Document Number 47751888. 

24. IDEM, Internal Office Memoranda, July 3 and 11, 1991. Subject: TCE and benzene 

in Garden City domestic wells; site referral. 2 pages. VFC Document Number 

66025926.
12 

25. U.S. EPA website, Superfund Site Information, Bartholomew County, Indiana. 

16 pages. http://www.epa.gov/superfund/sites/cursites/. Accessed October 15, 2012. 

26. Reference Number Reserved.

27. ICAIR Life Systems, Potentially Responsible Party Search for Miller Salvage, 

September 1988. 24 pages. VFC Document Number 49982591. 

28. IDEM, Billy E. Giles, Geologist, Office Memorandum to Harry E. Atkinson, Chief, 

State Cleanup Program. Subject: Miller Salvage, November 18, 2002. 2 pages. 

 VFC Document Number 4762388. 

29. IDEM, Harry E. Atkinson, Chief, State Cleanup Program, correspondence to T.M. 

Solso, President, Cummins, Inc. October 25, 2004. 4 pages. VFC Document Number 

49951060. 

30. Cummins, Inc. correspondence to Liberty Mutual Insurance, with attachments. 

December 16, 2004. 10 pages. VFC Document Number 49958280. 

31. Reference Number Reserved.

32. EMS Heritage Laboratories, Inc., Certificates of Analysis, August 30, 1991. 84 pages. 

VFC Document Number 47751074. 

33. IDEM, Internal Correspondence, Review of Laboratory Results, Samples Collected 

August 1 and 2, 1991. September 23, 1991. 28 pages. VFC Document Number 

47751003. 

34. Lowe Gray Steele & Hoffman, Attorneys at Law, correspondence to Karla McDonald, 

IDEM, November 18, 1991. Subject: Kiel Bros. meeting. Pages 1 and 2. Virtual File

contains 20 pages of multiple documents. VFC Document Number 23601475. 

35. IDEM, Office Memorandum, Subject: Kiel Brothers Oil Company. December 18, 

1991. 2 pages. VFC Document Number 47751321. 

36. IDEM, Office Memorandum, Subject: Summary of July 13 meeting on Garden City, 

Indiana. July 23, 1992. 1 page. VFC Document Number 47751335. 

37. Haitjema, H.M. and J. Wittman, Well Head Protection of the Southern Well Fields 

near Columbus, Indiana, May 21, 1992. 81 pages. VFC Document Number 

49930209. 

38. Reference Number Reserved.
13 

39. IDEM, Office Memoranda with attachments. Subject: Garden City Ground Water 

Plume. 1991, 1992. 5 pages. VFC Document Number 47751336. 

40. IDEM, Mikhail Stonik, Stephen Sommer, Chemistry Section, Office Memoranda with 

attachments to Karla McDonald, LUST Section. Subject: Receipt of data package 

and preliminary results; Sampling near Kiel Brothers. 1992, 1993. 11 pages. VFC 

Document Number 47751031. 

41. IDEM, Office Memorandum with attached analytical results. September 15, 1992. 

23 pages. VFC Document Number 58320746. 

 

42. Indiana Department of Natural Resources (IDNR), October 8, 1992. Memorandum 

with attachment. Subject: Sensitive Species, etc. 4 pages. 

IDEM Office Memorandum. February 16, 1994. Subject: Additional Sampling in 

Garden City, Indiana. 2 pages. Virtual File contains 2 documents. VFC Document 

Number 47751323. 

 43. IDEM, Michael H. Habeck, Chemistry Section, Office Memorandum with attached 

laboratory results to Pat Colcord, Immediate Removals Section. Subject: Review of 

Laboratory Results for Garden City, September 23, 1994. 258 pages. VFC Document 

Number 43941758. 

44. Reference Number Reserved.

45. IDEM, field sheets and preliminary summary results from December 1997 sampling 

event. 67 pages. Field sheets from 1991 sampling event. 34 pages. Field sheets and 

associated forms from 1998 sampling event. 11 pages. VFC Document Number 

47750880. 

46. Federal Emergency Management Agency (FEMA), Flood Insurance Rate Map 

(FIRM), City of Columbus, Indiana, Bartholomew County. Panel 20 of 30, 

 Community Panel Number 180007 0020 D, Revised February 19, 1997. 4 pages. 

47. IDEM, Kiel Bothers Site Inspection Work Plan with attachments. January 10, 2002. 

35 pages. IDEM, Sampling Field Sheets. January 29, 2002. 14 pages. VFC 

Document Number 47625918. 

48. Reference Number Reserved.

49. Reference Number Reserved.

50. IDEM, Drinking Water Branch website, Record of Violations, Garden City MHP 

Water System Number IN5203005, 1 page.

https://myweb.in.gov/IDEM/DWW/JSP/Violations.jsp?tinwsys_is_number=407822&t

inwsys_st_code=IN. 

 
14 

51. IDEM, Office Memorandum with attachments, April 5, 2002. Analytical results for 

Kiel Bros. sampling events. 685 pages. VFC Document Number 47626367. 

52. IDEM, Troy L. South, Chemistry Section, Office Memorandum to Andrea Robertson, 

State Cleanup Section, August 19, 2002. Subject: Analytical results for Kiel Bros. 

sampling event, June 12 and 13, 2002. 20 pages. VFC Document Number 58342134. 

53. IDEM, Office Memorandum, August 19, 2002. Analytical results for Kiel Bros. 

sampling event, June 13, 2002. 7 pages. VFC Document Number 58342450. 

54. IDEM, Memorandum of Decision, Kiel Bros. Oil Company, September 12, 2002. 

 3 pages. VFC Document Number 47751355. 

55. Reference Number Reserved. 

56. IDEM, Garden City Ground Water Plume samples, Mobile Laboratory analysis. 

 November 2002. 37 pages. IDNR Well Records. 30 pages. Laboratory Analytical 

Results Sept., Oct., Nov. 2003. 79 pages. VFC Document Number 47734370. 

57. IDEM, Garden City Ground Water Plume samples. November 2002. 55 pages. 

 VFC Document Number 47627449. 

58. IDEM, Jason Murdoch, Chemistry Section, Office Memorandum to Andrea Robertson, 

State Cleanup, September 29, 2003. Analytical results for Garden City sampling 

event, July 30, 2003. 3 pages. VFC Document Number 47625686. 

 

59. IDEM, Office Memorandum, January 9, 2004. Analytical results for Garden City 

sampling event, October 30, 2003. 3 pages. VFC Document Number 47624988. 

60. Haley & Aldrich, Inc. prepared for IDEM, Miller Salvage Remedial Investigation 

Report – Draft, on behalf of Cummins, Inc. October 3, 2006. 370 pages. VFC 

Document Number 49929729. 

61. IDEM, No Further Action Letter for Miller Salvage to Cummins, Inc. August 5, 2010. 

 3 pages. VFC Document Number 57462457. 

62. U.S.EPA CLP Organics Chain of Custody Record, ALS Laboratory Group, 

Case #41645. 6 pages. 

63. Reference Number Reserved.

 

64. U.S. EPA Superfund Information Systems website, Record of Decision System

(RODS), Columbus Old Municipal Landfill #1. 2 pages. 

http://cfpub.epa.gov/superrods/index.cfm?fuseaction=data.rodinfo&id=0501673&mRo

d=05016731992ROD194. Accessed September 11, 2012. 
15 

65. IDEM, Columbus Area Preliminary Assessments, including Preliminary Assessment 

of the Joe Boaz Site #2, with attachments. August and September 1985. 35 pages. 

VFC Document Number 47609872. 

66. Indiana Department of Natural Resources (IDNR), Garden City area well logs

 assembled from IDNR Website, 12 pages. 

http://dnrmaps.dnr.in.gov/apps/dnrwaterwells_enh/. Accessed August 14, 2012. 

67. Reference Number Reserved.

68. U.S. EPA, Level 3 Data Validation, Garden City Sample Delivery Group (SDG) 

Number E2S19, Case Number 41645. 130 pages.

69. Reference Number Reserved.

70. U.S. EPA, Level 3 Data Validation, Garden City Sample Delivery Group (SDG) 

Number E2S11, Case Number 41645. 95 pages.

71. IDEM, Drinking Water Branch website. Water System Details, Musillami’s Drive-In. 

 2 pages. Accessed September 11, 2012. 

https://myweb.in.gov/IDEM/DWW/JSP/WaterSystemDetail.jsp?tinwsys_is_number=3

90639&tinwsys_st_code=IN&wsnumber=IN2030830. 

72. Reference Number Reserved.

73. Reference Number Reserved. 

74. IDEM, Site Investigation Program, Quality Assurance Project Plan. April 30, 2008. 

84 pages. 

 

75. U.S. EPA Drinking Water Contaminants Website. List of Contaminants and their 

Maximum Contaminant Levels (MCLs), EPA 816-F-09-0004, May 2009. 6 pages. 

Accessed September 11, 2012. 

http://water.epa.gov/drink/contaminants/index.cfm#List. 

76. U. S. EPA, David Wilson, Geologist, Office Memorandum with attachments. Subject: 

Information for the Final Draft HRS DOCUMENTATION Record for the Garden City 

Ground Water Contamination Plume, February 4, 2013. 11 pages. 

77. IDEM, Sample Field Sheets, Garden City Ground Water Plume, August 9, 2011. 

 37 pages. 

78. IDEM, Sample Field Sheets, Miller Salvage, August 9 and 10, 2011. 22 pages. 
16 

79. City of Columbus Wellhead Protection Program, Pollution Source Inventory 

Contingency Plan Management Plan, December 2000, Revised October 2009. 359 

pages.

80. Haley & Aldrich, Inc. prepared for Cummins, Inc. Subject: Quarterly Groundwater 

Sampling Report – Miller Salvage, July 2009. 56 pages. 

 VFC Document Number 50161258. 

81. Haley & Aldrich, Inc. prepared for Cummins, Inc., Subject: Quarterly Groundwater 

 Sampling Report – Miller Salvage, November 2009. 248 pages. 

 VFC Document Number 52380758, Sampling analysis tables are unreadable. 

82. Haley & Aldrich, Inc. prepared for Cummins, Inc. Subject: Quarterly Groundwater 

Sampling Report – Miller Salvage, February 2010. 270 pages. VFC Document Number 

54134305, Sampling analysis tables are unreadable. 

83. Haley & Aldrich, Inc. prepared for Cummins, Inc. Subject: Quarterly Groundwater 

Sampling Report – Miller Salvage, April 2010. 23 pages. VFC Document Number 

54844525. 

84. EPA Superfund Record of Decision, Subject: Columbus Old Municipal Landfill #1, 

 March 31, 1992. 15 pages. 

85. Clark, G. Douglas, 1980; The Indiana Water Resource; Availability, Uses, and Needs, 

Indiana Department of Natural Resources. Excerpt, 28 pages. VFC Document Number 

49982368 

86. Ecology and Environment, Inc. Expanded Listing Site Inspection/Groundwater Pathway 

Assessment, Miller Salvage, Columbus, Indiana. October 31, 1991. 179 pages. 

VFC Document Number 49929130 

87. Haitjema, H.M., Vic Kelson, and Jack Whitman, 1996 (updated 2009); Capture Zone 

Delineation for the Municipal Wellfields Columbus, Indiana. 360 pages. VFC 

Document Number 53060348. 

88. Indiana Department of Natural Resources (IDNR) Well Records #216176, 216211, 

216201, 370712, 370713, 370714, 370715, 370716, 370717, 308833, 364296, 317191. 

https://secure.in.gov/apps/dnr/dowos/Waterwell.aspx 

89. Klaer, F.H., G.E. Davis, and T.M. Kingsbury, 1951; Ground-Water Resources of the 

Columbus Area, Bartholomew County, Indiana, U.S Geological Survey. 41 pages.

90. Sieco, Inc. December 1997, Cross Section D-D’; Columbus Utilities Well Head 

Protection. 1 page. VFC Document Number 53063602. 
17 

91. Strand Associates, Inc. 2009, Columbus IN Wellhead Protection Program Wellhead 

Delineation; Fairgrounds/Marr-Glick/South Wellfield. 1 page. VFC Document 

Number 53062144 

92. USDA, 2002; Soil Survey of Bartholomew County, Indiana. 754 pages. 

http://soildatamart.nrcs.usda.gov/Manuscripts/IN005/0/Bartholomew_IN.pdf

93. Watkins, F.A., and J.E. Heisel, 1970: Electrical-Analog-Model Study of Water 

Resources of the Columbus Area, Bartholomew County, Indiana; U.S. Geological 

Survey Water-Supply Paper 1981. Excerpt, 26 pages. VFC Document Number 

49982554 

94. Reference Number Reserved.

95. Gray, Henry, Jane Forsyth, Allan Schneider, and Ansel Gooding, 1972; Regional 

Geologic Map No. 7, Cincinnati Quadrangle, Indiana and Ohio, Showing Bedrock and 

Unconsolidated Deposits, Indiana Geological Survey. 1 page.

96. Planert, Michael, May 1976, Digital -Model Analysis To Predict Water Levels In A 

Well Field Near Columbus, Indiana. USGS Water-Resources Investigations 76-63. 

21 Pages.

97. USGS, 2010, Columbus Quadrangle, 7.5 minute topographic map of Columbus IN. 

 1 page. http://store.usgs.gov

98. Schneider, Allan, Indiana Geological Survey. 1966; Physiography. Reprinted from 

Natural Features of Indiana, The Indiana Sesquicentennial Volume. 18 pages. 

99. IDEM, February 13, 2013, Garden City Ground Water Plume Boundary Measurement 

 Calculations. 1 page. 

100. IDEM, February 13, 2013, Geographical Information Office (GIO) Spatial Database 

Engine (SDE). 1 page. 

101. National Flood Insurance Program, Preliminary Flood Insurance Rate Map, 

Bartholomew County, Indiana. Map Number 18005C0141E. 1 page. 
18 

GARDEN CITY GROUND WATER PLUME

SITE SUMMARY

The Garden City Ground Water Plume is located under the unincorporated town of Garden City, 

Bartholomew County, Indiana. The town is approximately one mile south of the city of Columbus, 

Bartholomew County, Indiana. The center of the town, and the highest concentrations of 

trichloroethylene (TCE), are located at the intersection of 900 Jonesville Road (aka State Road 11) and 

County Road 100 South (aka Garden Street). The town is composed of approximately 50 individual 

residences and the Garden City Mobile Home Park (Garden City MHP) containing 47 mobile homes. 

There are also several businesses along Jonesville Road. All the homes and businesses in Garden City 

are served by individual private ground water wells (Ref. 7, p. 9; Ref. 15, p. 5). The Garden City MHP 

has its own well and water delivery system (Ref. 11, p. 1, 2). 

 

TCE has been detected in ground water from multiple commercial and residential private wells (Ref. 7, 

p. 17, pp. 29~32). The Garden City MHP well has had intermittent TCE contamination, exceeding the 

U.S. Environmental Protection Agency (U.S. EPA) Drinking Water Maximum Contaminant Level 

(MCL) of 5 micrograms per liter (ug/l) (Ref. 75, pp. 1, 4), since 1997 (Ref. 50, p. 1). Sampling has also 

confirmed the presence of TCE, exceeding the MCL, at several private residential wells near the 

Garden City intersection (Ref. 7, pp. 15, 29~32; Section 3.1.1, Contaminated Ground Water Sample 

Table A and Figure 1-4 of this HRS documentation record). 

The plume was depicted laterally by ground water sample locations with detections of TCE 

contamination above the Cancer Risk Screening Concentration (CRSC) benchmark or exceeding nondetect background concentrations (Section 3.1.1, Contaminated Ground Water Samples, Tables A, B, C 

of this HRS documentation record). The depicted plume exists from approximately 300’ north to 

1,000’ south of the Garden City intersection, covering an estimated 3.45 acres, and is the only area 

utilized for HRS scoring purposes (Fig. 1-4 of this HRS documentation record) (Ref. 99, p. 1) (Ref. 

100, p. 1). 

The Columbus Marr-Glick Well Field is approximately 1⁄2 mile south/southeast of the Garden City 

center (Ref. 12, p. 2; Figure 1-4 of this HRS documentation record). One of the municipal wells had 

TCE concentrations which exceeded the non-detect background and the sampling methodology 

Contract Required Quantitation Limits (CRQL) detection limit of 0.5 ug/l utilized in the Garden City

Expanded Site Inspection (ESI). Municipal well detections were below the MCL (Ref. 7, p. 17, pp. 

30~32). The affected Columbus municipal wells are not within the laterally depicted plume on Figure 

1-4 of this HRS documentation record and are not included for HRS scoring purposes. 

The entire plume, as identified to date, is within the southern Wellhead Protection Area (WHPA) for the 

city of Columbus (Ref. 79, pp. 7, 8; Ref. 91, p. 1) (Fig. 1-6 of this HRS documentation record). The 

municipal wells closest to Garden City were sampled during the ESI. Columbus operates 15 ground 

water wells in this WHPA. This well field, and another well field north of Columbus, serve an estimated 

population of 45,000 (Ref. 14, p. 1). 
19 

Garden City overlies unconsolidated deposits consisting of recent alluvial silts and sands overlying, in 

part, extensive sand and gravel outwash deposits of the Quaternary-age Atherton Formation (Ref. 95, p. 

1). In the area of interest, the sand and gravel deposits are approximately 70-100 feet thick (Ref. 88, 

p.1; Ref. 96, p. 8). All Garden City residential and commercial wells, plus the Columbus municipal 

wells, draw drinking water from this aquifer. The area is subject to flooding from the adjacent East 

Fork of the White River (Ref. 5, p. 5; Ref. 46, pp. 1~4; Ref. 101, p. 1). See Figure 1-1 of this HRS 

documentation record for a state location map, and Figures 1-2 through 1-6 for additional related

information. All figures in this HRS documentation record were compiled utilizing the Indiana 

Geographical Information Office (GIO) Spatial Database Engine (Ref. 100, p. 1). 

GROUND WATER PLUME HISTORY

In May 1989, The Indiana Department of Environmental Management (IDEM) received a report of 

petroleum odors in drinking water at a residence located in Garden City (Ref. 16, pp. 4-5). IDEM’s 

Office of Emergency Response (OER) began sampling homes and businesses in Garden City. Results 

from these samples showed contamination of ground water with petroleum products and volatile 

organic compounds including benzene, toluene, and TCE (Ref. 18, pp. 29~38). The ground water well 

at the Kiel Bros. gasoline station (850 Jonesville Road) had the highest concentrations of identified 

VOCs (Ref. 16, p. 5). The station was undergoing an underground storage tank upgrade at the time of 

the initial complaint (Ref. 18, p. 30) (Fig. 1-5 of this HRS documentation record). 

 

Several contaminants were detected, with TCE and benzene exceeding drinking water MCLs at several 

sample locations. The highest concentrations of TCE were found in the Kiel Bros. drinking water well. 

TCE was also found in wells up-gradient of ground water flow from the Kiel Bros. location (Ref. 18, 

pp. 1-3, 29~38). 

 

IDEM’s Underground Storage Tank Section (UST) staff issued a notification on March 7, 1990, to the 

potentially responsible party (Kiel Bros.) that a site investigation be conducted at their facility (Ref. 19, 

pp. 1, 2).

On March 30, 1990, an Initial Incident Report was submitted to IDEM’s Emergency Response Branch 

confirming that a release of a petroleum product had occurred (Ref. 9, p. 1). Kiel began its 

investigation and installed three monitoring wells on the property. On June 18, 1991, IDEM installed 

and sampled four additional monitoring wells on adjacent properties (Ref. 22, pp. 1~5; Ref. 23, pp. 

1~22). The investigation revealed no evidence that Kiel or any of the previous operators used or stored 

TCE on-site. Piezometric contour maps, generated during monitoring, indicated ground water flow to 

the south/southeast (Ref. 5, pp. 56, 149; Ref. 23, p. 9; Ref. 37, pp. 22~28; Ref. 60, p. 52).

On July 11, 1991, IDEM’s Leaking Underground Storage Tank Section (LUST) referred the TCE 

ground water contamination to the IDEM Site Investigation Section stating that the contamination was 

unrelated to any Kiel Bros. underground storage tank and therefore LUST could not investigate further 

(Ref. 24, pp. 1-2). The Kiel Bros. site was entered into CERCLIS for the continued investigation into 

the TCE contamination and given a Discovery Date of May 20, 1991 (Ref. 25, p. 14).

TCE disposal in the vicinity of Garden City was previously known. On July 7, 1981, Cummins Engine 

Company (Cummins) of Columbus, IN, notified U.S. EPA of its past disposal activities at the Miller
20 

Salvage and Crating scrap yard (Miller Salvage), located approximately 1⁄2 mile southeast of the Garden 

City intersection. Cummins reported that it had disposed of an estimated 3.5 million gallons of waste 

containing 1,1,1-trichloroethane and TCE at Miller Salvage. This had occurred over approximately 17 

years, ending in 1969 (Ref. 10, pp. 1~6). A Preliminary Assessment of Miller was completed in April 

1983 and a Site Inspection completed in November, 1985 (Ref. 4, p. 2; Ref. 25, p. 6). After an 

investigation into Potentially Responsible Parties, Cummins took responsibility for the contamination at 

Miller and conducted a separate remedial investigation under IDEM State Cleanup Section oversight 

(Ref. 27, pp. 1~24; Ref. 29, pp. 1~4; Ref. 30, pp. 1~10; Ref. 80, p. 9; Ref. 81, p. 9; Ref. 82, p. 9; Ref. 83, 

p. 9). 

On August 1 and 2, 1991, IDEM Site Investigations Section conducted a Preliminary Assessment on 

Kiel Bros. with ground water sampling (Ref. 5, pp. 11~32). Sampling was conducted on private 

drinking water wells along with one Columbus municipal well (Ref. 5, pp. 16~37). VOCs were detected 

in eight ground water samples with two of the eight exceeding MCLs for TCE (Ref. 5, pp. 14, 15) (Ref.

32, pp. 22~36, 41~44, 53~56, 63~64; Ref. 33, pp.1, 5). The samples exceeding MCLs were taken at 

Kiel Bros. and the adjacent drive-in restaurant (Ref. 5, pp. 20~21, Ref. 32, pp. 41~44). No 

contamination was detected in the municipal well (Ref. 5, pp. 5~6, 29; Ref. 32, pp. 59~61).

In November 1991, the LUST program agreed that TCE contamination in ground water on the Kiel 

Bros. property was from an off-site source. Kiel Bros. would continue to treat its site as a normal 

petroleum release situation and would not be responsible for the TCE remediation (Ref. 34, pp. 1, 2; 

Ref. 35, pp. 1, 2; Ref. 36, p. 1).

The city of Columbus began to increase its drinking water production from ground water south of 

Garden City with the additional new well field (Marr-Glick). Production was to be increased from 6.9 

MGD in 1992 to an anticipated 13.0 MGD upon completion of the well field in 2002 (Ref. 37, pp. 

29~34, 37). IDEM was concerned about the effect the additional drawdown from these wells would 

have on the TCE plume (Ref. 39, pp. 1~3). IDEM conducted further sampling on June 30, 1992 (Ref. 

40, pp. 1~11; Ref. 41, pp. 1~3). 

In the spring of 1994, heavy rains and flooding may have been responsible for increased contamination 

in the residential wells being monitored by IDEM. It was decided to enlarge the sampling area to 

determine if contamination had spread to previously unaffected residences and businesses (Ref. 42, pp. 

5, 6). The IDEM Site Investigation Section conducted additional sampling in June 1994. No TCE 

concentrations were detected (Ref. 43, pp. 1~3). 

The Site Investigation Section completed the Kiel Bros. Preliminary Assessment on August 27, 1996 

(Ref. 25, p. 14).

Further sampling was conducted on December 23, 1997 (Ref. 45, pp. 1~20). Three residences had TCE 

contamination in their wells (Ref. 45, pp. 2, 13~15, 24, 33~35). 

IDEM conducted further ground water sampling in January 2002 (Ref. 6, p. 17; Ref. 47, pp. 2, 30~43). 

Ground water wells were sampled for VOCs. TCE exceeding its MCL was found in 2 residential wells 

and one commercial well (Ref. 6, pp. 17, 26, 180, 186, 198; Ref. 51, pp. 1~3). 
21 

IDEM returned for additional sampling in April and June 2002. Ground water and soil samples were 

collected. TCE was detected several ground water samples but exceeded MCLs in only the mobile 

home park well. TCE was not detected in any soil samples (Ref. 51, pp. 4~8, 22, 23; Ref. 52, pp. 1~20; 

Ref. 53, pp. 1~7). 

IDEM recommended that the Kiel Bros. site be given a priority of No Further Remedial Action Planned 

(NFRAP) in the site assessment process, indicating that it was not the source of TCE in local ground 

water (Ref. 6, p. 12; Ref. 25, p. 13; Ref. 54). On September 24, 2002, the Reassessment of the Kiel 

Bros. petroleum products cleanup was completed by U.S. EPA and the site was archived in CERCLIS 

(Ref. 25, p. 14). 

A new CERCLIS site, Garden City Ground Water Plume (INN000508642), was originated to continue 

the investigation into the source of the TCE. This site was given a discovery date of September 10, 

2002, and a Combined Preliminary Assessment/Site Inspection (PA/SI) start date of October 22, 2002 

(Ref. 25, p. 4).

In November 2002, IDEM obtained soil borings and ground water grab samples (Ref. 6, pp. 13, 15, 16, 

18, 19). None of the ground water samples and only one of the soil samples contained a detectable 

amount of chlorinated solvents (Ref. 6, pp. 17, 20-24, 302~307, 316~321; Ref. 57). 

IDEM monitored contamination levels in ground water in 2003. TCE continued to exceed its MCL at 

the mobile home park and some nearby residences (Ref. 56, pp. 71~74, 78, 79; Ref. 58, pp. 1~3; Ref. 

59, pp. 1~4). 

Following completion of the PA/SI Report, IDEM recommended that the Garden City Ground Water 

Plume be given an “Other Cleanup Authority” (OCA) designation and be combined with the remedial 

investigation of Miller Salvage. The Miller Salvage investigation was being conducted by the 

Responsible Party (Cummins) with oversight by IDEM State Cleanup Program (Ref. 28, pp. 1~2; Ref. 

30, pp. 1~3). 

 

In October 2006, A Remedial Investigation Report for Miller Salvage was prepared by the consultant 

for Cummins based on field investigations conducted in April, May, and September of 2006 (Ref. 60, 

p. 2). State Cleanup Section staff agreed contamination was insufficient to warrant further remedial 

action. Cummins was issued a No Further Action (NFA) letter for Miller Salvage on August 5, 2010 

(Ref. 61, pp. 1~3). 

On August 9 and 10, 2011, the Site Investigation Section conducted an Expanded Site Inspection (ESI) 

of the Garden City Ground Water Plume. The results of the ESI indicated the presence of TCE above 

background in the mobile home park well (47 residences), five single family residences, and two 

commercial wells. Two of Columbus’ municipal wells had TCE detections with only one exceeding the 

Contract Required Quantitation Limits (CRQL) of 0.5 ug/l (Ref. 7, pp. 31, 32) (Fig. 1-4 of this HRS 

documentation record). The Garden City Ground Water Plume ESI was submitted to U.S. EPA and 

completed on May 1, 2012 (Ref. 25, p. 4). 
22 

At the same time as the ESI, IDEM’s Site Investigation Section conducted a Reassessment of Miller 

Salvage (Ref. 8, pp. 1, 5). Soil and ground water samples taken within the current boundaries of the 

Miller property revealed no TCE contamination (Ref. 8, pp. 10~11, 18~20, 33~38, 69~70, 75~80, 

111~118; Ref. 78, pp. 5~10). However, ground water samples taken just south of the Miller property 

line contained estimated levels of TCE contamination at 3.0 ug/l and 1.8 ug/l (Ref. 8, pp. 18~20, 39~44, 

63~68; Ref. 78, pp. 11~16). These were estimated values because the analytical methodology utilized 

in the Miller Reassessment used a CRQL of 5.0 ug/l. These locations were within 0.36 mile of the 

Columbus municipal wells which had detections of TCE contamination (Ref. 8, pp. 18-20; Ref. 78, pp. 

17~18). 

Ground water flow through Miller Salvage is generally to the east/southeast, down-gradient from 

Garden City (Ref. 80, pp. 33~35; Ref. 81, pp. 34~36; Ref. 82, pp. 37~39; Ref. 83, pp. 39~41). Ground 

water samples taken between Miller Salvage and the Garden City intersection have not shown TCE 

contamination between the Garden City Ground Water Plume and Miller Salvage (Ref. 80, pp. 9, 10, 16, 

19, 22, 25, 28, 32; Ref. 81, pp. 9, 10; Ref. 82, pp. 9, 10; Ref. 83, pp. 9, 10, 17, 20, 23, 26, 29, 32, 35, 38; 

Ref. 7, pp. 12, 21, 32, 61, 124; Ref. 8, pp. 9, 20, 26, 63, 69, 78). 

2.2 SOURCE CHARACTERIZATION

Residential and commercial drinking water wells at several commercial and industrial locations in 

Garden City have had intermittent TCE contamination since 1989 (Ref. 16, pp. 1, 4~5). 

 

Portions of the Garden City area are designated as a Special Flood Hazard Area (SFHA) subject to 

inundation by the 1% annual (100 year) chance flood (Ref. 46, pp. 1~4; Ref. 101, p. 1). Many low-lying 

areas and gravel pits have been filled, possibly with foundry sand and other industrial wastes since the 

1930’s (Ref. 6, pp. 9~14; Ref. 15, p. 1). 

 

A direct link between known areas of waste disposal or other contamination and the ground water 

contamination in the Garden City wells could not be made despite numerous investigations by private 

consultants, IDEM, and U.S. EPA (Ref. 6, pp. 11, 12; Ref. 5, pp. 7, 8). A brief summary of these 

investigations is shown below. More complete details are provided in the Site Summary section of this 

HRS documentation record. 

IDEM first responded in May 1989, to a complaint of petroleum odors in drinking water from a private 

well. IDEM proceeded to conduct sampling of numerous private wells and installed monitoring wells in 

the immediate vicinity (Ref. 16, pp. 4, 5). 

Kiel Bros. Oil Company was entered into CERCLIS on May 20, 1991, and given the identification 

number IND 985046903. A Preliminary Assessment (PA) was initiated in 1992 and completed on 

August 27, 1996, recommending further investigation. The Site Inspection (SI) was completed on 

September 24, 2002 (Ref. 25, pp. 12~14). Based on the results of the investigations at and near Kiel 

Bros., it was concluded that the Kiel Bros. facility should receive a designation of NFRAP (Ref. 25, pp. 

13-14). 
23 

A new site (Garden City Ground Water Plume, INN000508642) was listed on CERCLIS to continue the 

TCE investigation. A combined PA/SI was initiated on November 22, 2002, and completed on 

September 28, 2006 (Ref. 25, pp. 3, 4). 

IDEM’s evaluation of soil and ground water sampling data submitted by the Miller Salvage responsible 

party (Cummins, Inc.), between 2006 and 2010 resulted in a No Further Action (NFA) letter being 

issued from IDEM’s State Cleanup Section on Miller Salvage. This determination was based on

consistently low ground water concentrations of contaminants of concern and ground water flow 

direction towards the river (Ref. 61, pp. 1~3; Ref. 80, pp. 9, 33~35; Ref. 81, pp. 9, 34~36; Ref. 82, pp. 9, 

37~39; Ref. 83, pp. 9, 39~41). 

A Reassessment of Miller Salvage was conducted by IDEM’s Site Investigation Section following the 

NFA. The Reassessment was conducted in August 2011. The Reassessment did not discover a TCE 

source in the soil (Ref. 8, pp. 10, 11, 14, 18, 19, 24, 25).

At the same time as the Miller Reassessment, an ESI was conducted on the Garden City Ground Water 

Plume (Ref. 7, p. 12; Ref. 8, p. 9; Ref. 77, pp. 1~37; Ref. 78, pp. 1~22). The ESI was approved by U.S. 

EPA and completed on May 1, 2012 (Ref. 7, p. 5). 

The ESI did confirm Level I TCE contamination in pre-filtered drinking water at the Garden City 

Mobile Home Park (47 residences), 4 private residences, and 2 commercial buildings. Level II 

contamination was noted in one residence (Ref. 7, p. 29~32). 

IDEM staff utilized the U.S. EPA Superfund Information Systems databases and obtained the following 

information on listed facilities within one mile. 

KIEL BROS. OIL COMPANY, CERCLIS ID#IND985046903 (Archived) 

Action Name Lead Actual 

Completion

DISCOVERY S 05/20/1991 

PRELIMINARY ASSESSMENT S 08/27/1996 

SITE REASSESSMENT S 09/24/2002 

ARCHIVE SITE EP 09/24/2002 

(Ref. 25, p. 14) 

GARDEN CITY GROUND WATER PLUME, CERCLIS ID#INN000508642 (Active) 

Action Name Lead Actual 

Completion

DISCOVERY F 09/10/2002 

COMBINED PRELIMINARY 

ASSESSMENT/SITE INSPECTION

S 09/28/2006 

EXPANDED SITE INSPECTION S 05/01/2012 

(Ref. 25, p. 4) 
24 

MILLER SALVAGE, CERCLIS ID#IND980607618 (Active) 

Action Name Lead Actual 

Completion

DISCOVERY F 08/01/1981 

PRELIMINARY ASSESSMENT F 04/01/1983 

SITE INSPECTION

REASSESSMENT (not on the EPA website)

F 12/19/1985 

Not Final

(Ref. 25, p. 6) 

2.2.1 Source Identification

Number of Source: 1

Name and description of source: Other - Ground Water Plume with No Identified Source 

 

Based on the results of the ESI conducted on August 8, and 9, 2011, and previous investigations, the 

source of the TCE contamination in Garden City is unknown. More complete details of previous 

investigations are provided in the Site Summary section of this HRS documentation record. Previous 

investigations have determined at least one likely release of TCE to ground water (Miller Salvage) 

within 1⁄2 mile of the highest concentrations in Garden City, but, as previously discussed, this source 

cannot be definitively linked to the TCE plume affecting Garden City residential wells. As described in 

the Site Summary section and Section 2.2, a direct link between known areas of waste disposal or other 

contamination and the ground water contamination in the Garden City wells could not be made despite 

numerous investigations by private consultants, IDEM, and U.S. EPA. Therefore, the plume itself is

considered the source. The extent of this plume has not been completely delineated at this time but has 

been characterized by data from residential and commercial ground water wells (Figure 1-4 of this HRS 

documentation record). 

2.2.2 Hazardous Substance Associated with a Source

The ground water plume with no identified source, Source 1, contains measured levels of TCE, for 

which observed releases were established within the sand and gravel aquifer. TCE was detected above 

background levels in samples collected by IDEM in the ESI conducted in August 2011. 

Refer to Section 3.1.1 of this HRS documentation record for tables of ground water samples that were 

found to be contaminated. 

List of Hazardous Substances Associated with Source

The following hazardous substance is associated with the source: 

 - Trichloroethene (TCE) 

 

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

See Figure 1-4, Garden City Ground Water Plume Boundary Map, of this HRS documentation record 
25 

Source type for HRS evaluation purposes: 

Other - Ground Water Plume with No Identified Source. 

Containment

Release to Ground Water: The Containment Factor Value for the ground water migration pathway was 

evaluated for “All Sources” for evidence of hazardous substance migration from a source area (i.e., 

source area includes source and any associated containment structures). The applicable containment 

factor value was determined based on analytical evidence of a release obtained from ground water 

samples from wells during the ESI. Therefore, based on no liner and evidence of a release, a 

Containment Factor Value of 10 was assigned to Source No. 1 as specified in Table 3-2 of the HRS. 

2.2.3 Hazardous Substances Available to a Pathway

Containment Description Containment 

Factor Value

References

Gas release to air: Not Scored NA

Particulate release to air: Not Scored NA

Release to ground water: Because there is an observed release of a 

hazardous substance to ground water, a containment value of 10 has been 

assigned.

10

Ref. 1, 

Sections 2.2.2 and 3.1.1.

Table 3-2 

Release via overland migration and/or flood: Not scored NA

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity (Tier A)

The information available is not sufficient to evaluate Tier A source hazardous waste quantity. A 

sufficient number of samples were not collected that would statistically represent the range of 

contaminant concentrations throughout the source, therefore, hazardous constituent quantity is not 

scored (NS). As a result, the evaluation of hazardous waste quantity proceeds to the evaluation of Tier 

B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.1, pp. 61, 62). 

 

Hazardous Constituent Quantity Assigned Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity (Tier B)

The information available is not sufficient to evaluate Tier B source hazardous wastestream quantity. 

There are insufficient historical and current data (manifests, PRP records, State records, permits, etc.) 

available to adequately calculate the total mass of all hazardous wastestreams and CERCLA pollutants 

and contaminants in the source. Therefore, hazardous wastestream quantity is not scored (NS). As a 

result, the evaluation of Hazardous Waste Quantity proceeds to the evaluation of Tier C, Volume (Ref. 

1, Section 2.4.2.1.2, p. 62).

Hazardous Wastestream Quantity Assigned Value: NS
26 

2.4.2.1.3 Volume (Tier C)

Horizontal and vertical extent of the plume cannot be determined based on available sampling data; a 

sufficient number of samples are not available to statistically represent the range of contaminant 

concentrations throughout the source. Therefore, the source volume is unknown, but greater than 0 

(Ref. 1, Section 2.4.2.1.3, p. 62). 

 

 Volume Value Assigned: unknown, but >0

2.4.2.1.4 Area (Tier D) 

Area (Tier D) is not evaluated for source type “Other” (Ref. 1, Section 2.4.2.1.4, p. 62). 

 

Area Assigned Value: NA

SUMMARY OF SOURCE DESCRIPTIONS

Source Hazardous Waste Quantity Source #1:

Other - Ground Water Plume with No Identified Source

Tier Measure Ground Water Migration Pathway 

Tier A, Constituent Quantity *NS

Tier B, Wastestream Quantity *NS

Tier C, Volume >0

Tier D, Area NA

*NS = Not Scored

2.4.2.1.5 Calculation of Source Hazardous Waste Quantity Value

Volume of ground water plume: >0 but unknown 

Source Hazardous Waste Quantity Value: >0 but unknown 

Description of Other Possible Sources: 

Miller Salvage, CERCLIS ID# IND980607618 

Miller Salvage (Miller) is an active auto/scrap metal salvage operation encompassing nearly 30 acres at 

5 Kenmill Road in the unincorporated community of Garden City. The business is approximately 1⁄4 

mile southeast of the Garden City intersection. The surrounding area is mostly rural with the residential 

areas of Garden City generally west of the site. Although active, the property has less than 100 cars 

with small amounts of assorted scrap metal. The property is mostly overgrown with weeds and 

shrubbery. The property soils consist of silty loams and fill (mostly foundry sand). Agricultural fields 

and woodlands surround the property on three sides. There are several residences within 1⁄4 mile from 

the property (Ref. 8, p. 6). Ground water flow through Miller is generally to the southeast through all 

levels of the aquifer (Ref. 80, p. 9; Ref. 81, p. 9; Ref. 82, p. 9; Ref. 83, p. 9). U.S. EPA was informed 

of potential contamination at Miller in August 1981, when Cummins submitted a Notification of 

Hazardous Waste Site form to U.S. EPA in compliance with Section 103(c) of CERCLA (Ref. 10, pp. 

1, 2). This notification stated that Cummins had deposited 3.5 million gallons of process waste 
27 

between 1952 and 1969 at Miller. Waste oil analysis conducted by Cummins in 1983 revealed 

contaminants such as TCA, TCE, toluene, lead, and waste acids in the waste oil (Ref. 10, pp. 4~6). 

Several large diameter irrigation and livestock wells surrounding Miller could have provided a pathway 

for ground water to migrate from Miller Salvage to Garden City. In 1988, drought conditions in 

Bartholomew County likely increased the eastward extent of the wells’ hydraulic capture zones, 

potentially drawing ground water towards Garden City (Ref. 76, pp. 1, 3, 5). Also, in 1976, the United 

States Geological Survey (USGS) conducted a digital-model analysis to predict water levels in the then 

proposed southern well field for Columbus, south of Garden City. It stated that during periods of high 

water a reversal of ground water flow from the river can occur (Ref. 96, p. 11). 

IDEM completed a Reassessment of Miller, including both soil and ground water sampling via directpush technology, in August 2011. Soil samples were taken just above the water table generally 

between 7.5’ and 17.7’ below ground surface (bgs). TCE was not found in any soil or ground water 

samples taken within the present day boundaries of Miller Salvage. Ground water samples taken 

adjacent to the southern boundary, and possibly within the former boundary of Miller Salvage, did 

reveal TCE contamination in ground water. These detections were below the Contract Required 

Quantitation Limits (CRQL) for TCE utilized for the Reassessment and are considered estimated values 

(Ref. 8, pp. 8, 26, 27).

Kiel Bros. Oil Company Gas Station, CERCLIS ID# IND985046903 

The former Kiel Bros. Gas Station was located at 850 Jonesville Road, Garden City. Kiel had purchased 

the facility in 1984 from Eddy Oil Company which also had operated a gas station at that location since 

the early 1970s. Prior to 1971, the property was owned by Bruce Motor Freight of Indiana, but it is 

believed the property was vacant at that time (Ref. 5, pp. 1~5). 

 

In May 1989, IDEM received a report of petroleum odors in drinking water at a residence located 

adjacent to the former Kiel Bros. property (Ref. 16, pp. 4, 5). IDEM’s Office of Emergency Response 

(OER) began sampling wells at homes and businesses in Garden City. Results from these samples 

showed contamination of ground water with petroleum products and volatile organic compounds 

including benzene, toluene, and TCE (Ref. 16, p. 5; Ref. 18, pp. 29~38). The ground water well at the 

Kiel Bros. gasoline station had the highest concentrations of identified VOCs (Ref. 16, p. 5). The 

station was undergoing an Underground Storage Tank (UST) upgrade at the time of the initial 

complaint (Ref. 16, p. 5) (Fig. 1-5 of this HRS documentation record). IDEM agreed that Kiel Bros. 

was not the source of the TCE in ground water. On September 24, 2002, the Reassessment of the Kiel 

Bros. petroleum products cleanup was completed by U.S. EPA and the site was archived in CERCLIS 

(Refs. 34, pp. 1, 2; 36, p. 1; Ref. 25, p. 14). 

Columbus Old Municipal Landfill, CERCLIS ID# IND980607626 

The 19-acre Columbus Old Municipal Landfill is located approximately 1 mile north of Garden City. 

The landfill, located in the 100-year floodplain of the East Fork of the White River, is bounded by 

farmland, state roads, and an inactive gravel quarry pond. From 1938 to the 1960s, the facility was 

operated as a municipal landfill accumulating an estimated 500,000 cubic yards of fill material. After 

the landfill reached a maximum of 20 feet, operations ceased and the landfill was closed by placing two 

to three feet of dredged river sediments over the entire area. Deposited materials were mainly municipal 

and household wastes, although wastes from industrial sources were reportedly disposed of at the 
28 

landfill. Limited dumping by unauthorized parties may also have occurred. No records of operations 

were kept. The waste material was dumped directly on the ground surface and was exposed to the 

elements. Open burning of waste material occurred regularly. Annual spring flooding caused the waste 

material to become submerged periodically. Eventually, the landfill began to function as a berm 

between the floodplain and the adjacent farmland. In 1981, Cummins Engine Company notified U.S. 

EPA of waste materials, including solvents, acids, lubricants, cutting fluids, and metals, that were 

generated and reportedly disposed of at the landfill. In 1990, the potentially responsible parties, under 

direct guidance of the state and U.S. EPA, conducted an investigation to assess the potential impacts of 

the waste material deposited in the landfill on soil, ground water, surface water, and river sediments in 

the vicinity of the landfill (Ref. 64, p. 1, 2; Ref. 84, p. 6). Based upon findings of the remedial 

investigation and evaluation of current risks, U.S. EPA concluded that the landfill currently poses no 

immediate or long-term risks to human health and the environment. This conclusion is based on 

current conditions of the landfill with the assumption that these conditions will not change. The EPA is 

requiring ground water monitoring and a five-year review of landfill conditions (Ref. 64, p. 2; Ref. 84, 

p. 13). 

Joe Boaz Site #2, CERCLIS ID# IND981094121 

The Joe Boaz Site #2 is 1/3 mile west of the Garden City intersection (Ref. 65, p. 4). The site was an 

approximately 2 acre low-lying area which was filled in with various waste materials by the owner. The 

depth of the fill was estimated to be less than 8 feet (Ref. 65, p. 3). No records of operation were kept. 

Cummins Engine had no records of their TCE contaminated waste going to this location (Ref. 65, pp. 1, 

8, 16). A Preliminary Assessment was conducted and the facility was recommended for no further 

action in September 1985 (Ref. 25, pp. 15, 16).

Devening Block Company Property (no CERCLIS or U.S. EPA ID#) 

Devening Block (aka Horn Precast), 895 Jonesville Road, is a manufacturer of concrete block and other 

concrete products. Devening is not a generator of hazardous waste and there is no record of TCE being 

used at the facility. The property is approximately 9 acres used for offices, parking, product 

manufacturing and storage. Prior to 1968, a large lagoon or gravel pit was present on the property. This 

pit was filled in and the Devening Block office and parking lot currently occupy much of the space (Ref. 

7, Attachment E). Two ground water well samples and several direct-push grab samples (soil, 7.5’ to 

17’ bgs, and ground water, 8’ to 17.7’ bgs) were taken on the property (Ref. 7, pp. 12, 40~49; Ref. 77, 

pp. 6, 9~19). All results were below background except one well sample taken from a spigot in the 

office building bathroom (Ref. 77, p. 9). This sample (E2S79) exceeded the MCL for TCE. This water 

is not used for drinking purposes and was not used in scoring (Ref. 7, pp. 29~32). 

3.0 GROUND WATER MIGRATION PATHWAY

3.0.1 General Considerations 

The ground water contamination plume associated with the Garden City Ground Water Plume is located 

in an area comprising a buried bedrock valley, bordered on the west by Mississippian-age Borden 

Group siltstone and shale, which forms the Knobstone Escarpment (Ref. 89, p. 4). The bedrock which 

forms the valley floor consists of relatively nonresistant black shale of the New Albany Group (Ref. 89, 

p. 4; Ref. 98, pp. 41, 45). The unconsolidated deposits within this valley consist of recent alluvial silts 

and sands overlying, in part, extensive sand and gravel outwash deposits of the Quaternary-age 
29 

Atherton Formation (Ref. 95, p. 1). In the area of interest, the sand and gravel is approximately 70-100 

feet thick (Ref. 88, p.1; Ref. 96, p.8) (Figure 1-4 of this HRS documentation record). 

The surficial soils in the area of Garden City consist of Shoals Silt Loam and Nineveh Gravelly Loam 

(Ref. 92, p. 754). The Shoals Silt Loam is a deep, well drained and somewhat poorly drained, medium 

textured and moderately fine textured, nearly level soils on bottom lands (Ref. 92, pp. 73, 74). Nineveh 

Gravelly Loam is a deep, well drained, medium textured soil found on terraces (Ref. 92, pp. 60, 61). 

Disturbed areas are located on both sides of State Road 11, north of County Road 100 South and on 

most of the Miller Salvage property (Ref. 86, pp. 12, 15; Ref. 7, pp. 195-197). 

Aerial photography of the area of interest indicates that numerous gravel pits were opened and filled 

from the 1930s until the 1960s (Ref. 7, pp. 195-197). Other low areas and lagoons/gravel pits have been 

brought to grade with assorted fill (Ref. 7, pp. 10, 195-197). 

3.0.1.2 Aquifer Boundaries

Aquifer Name: Unconsolidated Sand and Gravel 

The bedrock formations of the Columbus area generally yield only small quantities of water to wells 

(Ref. 89, p. 8) and are some of the poorest water-bearing formations in the state (Ref. 85, p. 11). The 

major ground water sources are confined to the sand and gravel deposits of the East Fork of the White 

River (Ref. 85, p. 11). The central part of Bartholomew County is crossed by a large gravel-filled valley 

(Ref. 89, p. 7). Extensive surficial Wisconsinan till deposits border the valley to the east and appears to 

partially underlie the outwash valley deposits (Ref. 95, p. 1; Ref. 86, p. 27). There are no aquifer 

discontinuities such as mountain ranges, oceans, or faults (Ref. 95, p. 1; Ref. 97, p. 1). The gravel-filled 

valley extends north-south through the study area and is approximately 4 miles wide at the site (Ref. 86, 

p. 31; Ref. 95, p. 1; Ref. 96, p. 8). The sand and gravel outwash deposits of the Atherton Formation 

form a large ground water reservoir which is utilized as the drinking water source for the city of 

Columbus (Ref. 86, p. 30; Ref. 95, p. 1). This is an unconfined sand and gravel aquifer (Ref. 86, pp. 

2~19). In the Garden City area, well logs indicate that the unconsolidated deposits are approximately 70 

to 90 feet thick and directly overlie the shale bedrock (Ref. 86, p. 30; Ref. 88, p. 1). The more recent 

alluvium forms an undulating surficial layer that increases in thickness to a maximum of 25 feet near the 

Miller Salvage property and the East Fork of the White River (Ref. 86, p. 30).

Ground water is under water table conditions and the streams are in hydraulic connection with the 

aquifer (Ref. 93, p. 8). The narrowing of this bedrock valley downstream from Columbus acts 

somewhat as a drain, causing an increase in ground water runoff to the stream (Ref. 93, pp. 4, 8-9). The 

depth to ground water ranges from 0 to approximately 30 feet, and varies dependent on stream proximity 

and seasonal variations (Ref. 86, p. 30). The hydraulic conductivity in the aquifer is between 200 and 

400 ft/day (Ref. 87, pp. 48, 49).

The regional ground water flow in the aquifer is predominantly to the south, and follows the East Fork 

of the White River (Ref. 86, p. 30). 
30 

Ground Water Usage 

The Garden City community is served by individual private potable wells (Ref. 7, p. 9). Most of the 

known private wells are between 40 and 60 feet deep (Ref. 7, p. 15; Ref. 16, pp. 12, 38-43, 53-55, 59-

60). The city of Columbus municipal water supply wells are located at the fairground about 700-1000 

feet southwest of the ground water plume and about 3000-6000 feet south of the ground water plume in 

the agricultural area adjacent to the river (Ref. 91, p. 1). These wells are 80-100 feet deep and typically 

screened at the base of the aquifer on top of the bedrock (Ref. 90, p. 1; Ref. 88, pp. 1-4). 

SUMMARY OF AQUIFER(S) BEING EVALUATED

Aquifer 

No. Aquifer Name

Is Aquifer 

Interconnected? 

(Y/N/NA)

Is Aquifer 

Continuous within 

4-mile TDL? (Y/N)

Is Aquifer 

Karst? (Y/N)

1 Unconsolidated Sand 

and Gravel Aquifer NA Y N 

The Unconsolidated Sand and Gravel Aquifer is the only aquifer being evaluated. 

3.1 LIKELIHOOD OF RELEASE

3.1.1 Observed Release

Aquifer Being Evaluated: Unconsolidated Sand and Gravel Aquifer 

Chemical Analysis

Establishing an observed release by chemical analysis requires analytical evidence of a hazardous 

substance in the media significantly above background level. If the background concentration is not 

detected (or is less than the detection limit), an observed release is established when the sample 

measurement equals or exceeds its own Sample Quantitation Limit (SQL) and that of the background 

sample. If the SQL cannot be established, the U.S. EPA Contract-Required Quantitation Limit (CRQL) 

is used in place of the SQL (Ref. 1, Table 2-3, p. 60). The CRQL was used in all IDEM ESI sampling. 

Samples were analyzed for the list of Trace level VOCs. The samples were analyzed according to CLP 

SOW SOM01.2 and reviewed according to the National Functional Guidelines for SOM01.2 and the 

SOP for ESAT5/TechLaw Validation of Contract Laboratory Program Organic Data (Version 2.6) 

(Ref. 7, pp. 136, 137). All samples were collected, and sample locations were recorded using the 

Global Positioning System (GPS), in accordance with the IDEM Site Investigation Quality Assurance 

Project Plan (Ref. 7, p. 11; Ref. 74, p. 1). 

Background Ground Water Samples: 

Three ground water samples, taken during the August 2011 ESI, are being utilized to illustrate the 

background contaminant levels in this HRS documentation record. Two shallow samples 

(GW01/E2SB2, GW02/E2SB0), were collected up-gradient of the ground water plume via direct-push 

technology. These samples were taken at the top of the aquifer, approximately the same depth as other 

samples taken via direct-push (Ref. 7, p. 34, 36; Ref. 77, p. 1, 3) 

The third sample (GW20/E2S42) was obtained from an unfiltered outside spigot at a residence on 

Jonesville Road (Ref. 7, p. 59; Ref. 77, p. 27). The well is expected to be screened at approximately the 

same depth as residential wells in Garden City and is used to represent background constituents for the 
31 

residential wells. A well log exists for the MHP showing a depth of 58’ deep. Well logs which are 

available in the area generally show private well depths between 40’ to 65’ deep (Ref. 16, pp. 12, 38-

43, 53-55, 59-60; Ref. 66, pp. 2~6).

All background samples were collected from the same aquifer being evaluated. The gravel-filled valley 

extends north-south through the study area and the sand and gravel deposits are vertically continuous 

(Ref. 88, pp. 1-2; Ref. 90, p. 1; Ref. 95, p. 1; Ref. 96, p. 8). 

None of the background samples exhibited any detectable concentrations of TCE.

Shallow Ground Water Background Samples 

(Obtained by direct-push technology) 

IDEM

Loc. #

U.S. EPA

CLP #

Sample

Date

Location Hazardous

Substance

Sample

Concentration

Contract

Required

Quantitation

Limit (CRQL)

Depth

(Feet)

Reference

GW01 E2SB2 8/9/11 Approx.

1mile north of 

the Garden 

City 

intersection

TCE 0.5 U ug/l 0.5 ug/l 15’ 

below 

ground 

surface 

(bgs)

Ref. 7, p. 31;

Ref. 62, p. 4; 

Ref. 70, pp.

31, 32, 58-59; 

Ref. 77, p. 1 

GW02 E2SB0 8/9/11 Approx.

1⁄4 mile north 

of the Garden 

City 

intersection

TCE 0.5 U ug/l 0.5 ug/l 11’ bgs Ref.7, p. 31;

Ref. 62, p. 4 

Ref. 68, pp.

45, 82-83; 

Ref. 77, p. 3 

U = The analyte was analyzed for, but was not detected above the reported sample quantitation limit (Ref. 7, p. 141).

Intermediate Ground Water Background Sample 

(Obtained from residential drinking water well)

IDEM

Loc. #

U.S. EPA

CLP #

Sample

Date

Location Hazardous

Substance

Sample

Concentration

Contract

Required

Quantitation

Limit (CRQL)

Depth

(Feet)

Reference

GW20 E2S42 8/9/11 300 block**

Kenmill Street

TCE 0.5 ug/l U 0.5 ug/l Estimated 

between 

40’~65’bgs

Ref. 6, pp. 38-

43, 53-55, 59-

60; 

Ref.7, p. 32;

Ref. 62, p. 1; 

Ref. 66, pp. 3, 

5; 

Ref. 68, pp. 11, 

75; Ref. 77, p.

27

**Private residence

U = The analyte was analyzed for, but was not detected above the reported sample quantitation limit (Ref. 7, p. 141)
32 

Contaminated Ground Water Samples:

Table A. Observed Release Concentrations in Ground Water Samples Table (Residential Wells)*** 

IDEM 

Loc. #

U.S. EPA

CLP #

Sample

Date

Location Hazardous 

Substance

Sample

Concentration

Contract

Required 

Quantitation 

Limit (CRQL)

Depth References

GW05 E2S80 8/9/11 Garden City 

MHP

TCE 2.2 μg/l 0.5 μg/l 58’bgs.

Intermediate

Ref.7, 31 

Ref. 62, p. 2 

Ref. 68, 

pp. 31, 81 

Ref. 77, p. 7

GW06 E2S81

*Duplicate

 of 

 E2S80

8/9/11 Garden City 

MHP

Same location as 

GW05

TCE 2.2 ug/l 0.5 μg/l 58’bgs.

Intermediate

Ref.7, p. 31

Ref. 62, p. 2 

Ref. 68, 

pp. 33, 81 

Ref. 77, p. 8

GW13 E2S45 8/9/11 900 block 

Jonesville 

Road**

TCE 15 ug/l 0.5 μg/l Unknown but 

assumed 

Intermediate

Ref.7, p. 31;

Ref. 62, p. 1 

Ref. 68, pp. 17, 77 

Ref. 77, p. 20

GW15 E2S48 8/9/11 900 block 

Jonesville 

Road**

TCE 2.9 ug/l 0.5 μg/l Unknown but 

assumed 

Intermediate

Ref. 7, p. 31

Ref. 62, p. 1 

Ref. 68, pp. 23, 

78-79 

Ref. 77, p. 22

GW18 E2S49 8/9/11 900 block 

Jonesville 

Road**

TCE 2.5 ug/l 0.5 μg/l Unknown but 

assumed 

Intermediate

 

Ref. 7, p. 32

Ref. 62, p. 1 

Ref. 68, pp. 25, 

78-79 

Ref. 77, p. 25

GW19 E2S47 8/9/11 1000 block 

Jonesville 

Road**

TCE 4.2 ug/l 0.5 μg/l Unknown but 

assumed 

Intermediate

Ref. 7, p. 32

Ref. 62, p. 1 

Ref. 68, pp. 21, 

76-77 

Ref. 77, p. 26

**Private residence

***These samples also all qualify as Level I Concentrations.

Table B. Observed Release Concentrations in Ground Water Samples Table (Commercial Wells)

IDEM 

Loc. #

U.S. EPA

CLP #

Sample

Date

Location Hazardous 

Substance

Sample

Concentration

Contract

Required 

Quantitation 

Limit (CRQL

Depth References

GW04 E2S82 8/9/11 Musillami’s 

Drive-In 

855 

Jonesville 

Road

TCE 1.3 ug/l 0.5 ug/l Reported by 

owner at 

24’bgs.

Shallow or 

Intermediate

Ref. 7, p. 31

Ref. 20, p 1 

Ref. 62, p. 2 

Ref. 68, pp. 35, 

80-81

Ref. 77, p. 6

GW12* E2S79 8/9/11 Devening 

Office Bldg. 

895 

Jonesville 

Road

TCE 15 ug/l 0.5 ug/l Unknown 

but assumed 

Intermediate

Ref. 7, p. 31

Ref. 62, p. 2 

Ref. 68, pp. 29, 

78-79 

Ref. 77, p. 19
33 

*Not used for drinking water. 

Table C. Level II* Concentrations in Ground Water Sample Table (Residential Well) 

IDEM 

Loc. #

U.S. EPA

CLP #

Sample

Date

Location Hazardous 

Substance

Sample

Concentration

Contract

Required 

Quantitation 

Limit (CRQL) 

Depth References

GW16 E2S41 8/9/11 800 block 

Jonesville 

Road**

TCE 0.71 ug/l 0.5 ug/l Unknown but 

assumed 

Intermediate

Ref. 7, p. 31

Ref. 62, p. 1 

Ref. 68, 

pp. 9, 75

Ref. 77, p. 23

* Level II concentrations are established whenever actual contamination is present, but Level I concentration requirements have not been

met. (Ref. 2, p.1) 

**Private residence

An observed release has been determined through chemical analysis pursuant to the HRS (Ref. 1, 

Section 3.1.2, p. 66).

Ground Water Observed Release Factor Value: 550 

Level I Sample Table for Residential and Commercial Wells

U.S. EPA

CLP #

Contaminant Sample

Concentration

Superfund Chemical Data 

Matrix (SCDM)

Ground Water Cancer Risk 

Screening Concentration 

March 2012

References

E2S80 Trichloroethene

(TCE)

2.2 μg/l 1.0 ug/l Ref. 2, p. 10,

Ref. 68, 

pp. 31, 81

E2S81

*Duplicate

 of E2S80

Trichloroethene

(TCE)

2.2 ug/l 1.0 ug/l Ref. 2, p. 10,

Ref. 68, 

pp. 33, 81

E2S45 Trichloroethene

(TCE)

15 ug/l 1.0 ug/l Ref. 2, p. 10,

Ref. 68, pp. 17, 77

E2S48 Trichloroethene

(TCE)

2.9 ug/l 1.0 ug/l Ref. 2, p. 10,

Ref. 68, pp 23,

78-79

E2S49 Trichloroethene

(TCE)

2.5 ug/l 1.0 ug/l Ref. 2, p.10,

Ref. 68, pp. 25,

78-79

E2S47 Trichloroethene

(TCE)

4.2 ug/l 1.0 ug/l Ref. 2, p. 10,

Ref. 68, pp. 21,

76-77

E2S82 Trichloroethene

(TCE)

1.3 ug/l 1.0 ug/l Ref. 2, p. 10, 

Ref. 20, p. 1 

Ref. 68, pp. 35, 

36, 80-81
34 

3.1.2 Potential to Release

As specified in the HRS, since an observed release was established, the potential to release was not 

scored (Ref. 1, Section 3.1.2, p. 66).

Attribution

As described in the Site Summary section and Section 2.2, a direct link between known areas of waste 

disposal or other contamination and the ground water contamination in the Garden City wells could not 

be made despite numerous investigations by private consultants, IDEM, and U.S. EPA. Therefore, the 

source is evaluated as a ground water plume with no identified source. 

3.2 WASTE CHARACTERISTICS

3.2.1 Toxicity/Mobility

The following toxicity, mobility and combined toxicity/mobility factor values have been assigned to 

those substances present in the observed release.

Hazardous

Substance

Source No. 

(and/or 

Observed 

Release)

Toxicity 

Factor Value

Mobility 

Factor 

Value*

Does Hazardous 

Substance Meet 

Observed

Release by Chemical 

Analysis? (Y/N) 

Toxicity/ 

Mobility

References

TCE Observed

Release 1,000 1 Yes 1,000 Ref. 2, p. 10

*All hazardous substances that meet the criteria for an observed release by chemical analysis to one or 

more aquifers underlying the source(s) at the site, regardless of the aquifer being evaluated, are assigned 

a mobility factor value of 1 (Ref. 1, Section 3.2.1.2, p. 72). 

Contaminant characteristic values for hazardous substances found in an observed release to the ground 

water were derived from the Superfund Chemical Data Matrix (Ref. 2, pp. 9, 10). The hazardous 

substance with the highest toxicity/mobility factor value available to the ground water migration

pathway is TCE (1,000). TCE was detected at concentrations meeting observed release criteria in the 

Garden City MHP, Musillami’s, and several residence wells.

Toxicity/Mobility Factor Value: 1,000

(Ref. 1, Section 3.2.1.3, p. 73) 

3.2.2 Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity 

1 Other Unknown, but >0
35 

The Garden City Ground Water Plume site is scored as a site consisting of a contaminated ground 

water plume with no identified source. According to Section 2.4.2.2 in the HRS, if any target for the 

migration pathway is subject to Level I (or Level II) concentrations and the hazardous constituent 

quantity is not adequately determined, assign either the value from Table 2-6 or a value of 100, 

whichever is greater, as the hazardous waste quantity factor value for that pathway. Because Level I 

concentrations were present in a drinking water well, a hazardous waste quantity factor value of 100 

is assigned for the ground water pathway. 

Hazardous Waste Quantity Factor Value: 100

(Ref. 1, Section 2.4.2.2, p. 63) 

3.2.3 Waste Characteristics Factor Category Value

As specified in the HRS (Ref. 1, Section 3.2.3, p. 73), the Hazardous Waste Quantity Factor Value of 

100 was multiplied by the highest Toxicity/Mobility Value of 1,000 resulting in a product of 100,000 

(1.0E+05). Based on this product, a Waste Characteristics Factor Category Value of 18 was assigned 

from Table 2-7 of the HRS (Ref. 1, Section 2.4.3.1, p. 63).

Utilizing TCE, as listed in Section 3.2.1 of this HRS documentation record, the Waste 

Characteristics Factor Category Value is calculated as follows: 

Toxicity/Mobility Factor Value: 1,000

Hazardous Waste Quantity Factor Value: 100

 Toxicity/Mobility Factor Value (1,000) x Hazardous Waste Quantity Factor Value (100) =

100,000 = 1 X 105 = 18 from Table 2-7. 

Waste Characteristics Factor Category Value: 18

3.3 GROUND WATER PATHWAY TARGETS

The ground water pathway targets utilize the ground water in the Unconsolidated Sand and Gravel 

Aquifer for drinking water purposes (Ref. 85, p. 11; Ref. 86, p. 30; Ref. 88, p. 1; Ref. 15, p. 2). This 

ground water has been contaminated with TCE, as shown in Section 3.1.1 of this HRS documentation 

record. The number of target wells and estimated population subject to Level I concentration of TCE is 

given in section 3.3.2.2 of this HRS documentation record. Data from the 2010 U.S. Census 

approximates an average population of 2.5 persons per household in Bartholomew County (Ref. 13, p. 

1). 

3.3.1 Nearest Well

Sample IDs: E2S80, E2S81, E2S82, E2S45, E2S48, E2S49, E2S47 

Level of Contamination: Level I

If potential contamination, distance from source in miles: Not Applicable

Ground water samples taken from potable wells surrounding the intersection of Jonesville Road and 

County Road 100 S. exhibited TCE above its CRSC benchmark. Based on the sampling results, 51 

residences have TCE contamination in their drinking water above the Cancer Risk Screening 

Concentration benchmark (1.0 ug/l) prior to treatment (Ref. 2, p. 10). Please see tables in Section 

3.1.1 of this HRS documentation record. 
36 

As specified in the HRS (Ref. 1, Section 3.2.1.3, Table 3-11, p. 74), if one or more drinking water wells

are subject to Level I concentrations, a Nearest Well Factor Value of 50 is assigned. Level I 

concentrations have been documented in drinking water at the Garden City Mobile Home Park, 

Musillami’s, and in 4 residences south of the Garden City intersection. 

Nearest Well Factor Value: 50

3.3.2 Population

3.3.2.1 Level of Contamination 

3.3.2.2 Level I Concentrations

Sampling at the Garden City Mobile Home Park revealed at least 47 residences with drinking water 

subject to Level I TCE contamination (Ref. 11, p. 2; Section 3.1.1 of this HRS documentation 

record). Additional sampling at 4 private residences recorded TCE Level I contamination. 

Musillami’s commercial well also exhibited Level I TCE Contamination. This well serves 12 

employees (Ref. 20, p. 1; Ref. 71, p. 1). One additional commercial well at Devening Block also 

exhibited Level I contamination but this well is not utilized for drinking purposes. 

As specified in the HRS (Ref. 1, Section 3.3.2.2, p. 74), the number of people served by drinking 

water from points of withdrawal subject to Level I concentrations was calculated. The total 

population counted was calculated as follows: 

Four single family dwellings plus 47 mobile homes were totaled for 51 residences. An average of 2.5 

people per residence was multiplied times 51 equaling a residential population of 127.5. One 

commercial well serving 12 people was added to the residential population equaling a total Level I 

population of 139.5. 

 4 Residential homes with private wells exceeding Level I

 47 Mobile homes serviced by the Garden City Mobile Home Park water system well 

 exceeding Level I

 51 Total residences exceeding Level I 

 51 X 2.5 residents per home = 127.5 residents

 12 employees of Mussilami’s Drive-In restaurant using water system well exceeding 

 Level I

 127.5 = Resident Population 

 12.0 = Employee Population 

 139.5 X 10 (Level I) = 1,395 (Ref. 1, Section 3.3.2.2, p. 74) 

 
37 

Level I Samples Aquifer Population References

E2S80/E2S81(GW05/06) Unconsolidated 

Sand 

and Gravel

117.5 Ref. 7, pp. 29~32, 39-40, 166~169

Ref. 11, p. 2 

E2S45 (GW13) Unconsolidated 

Sand

and Gravel

2.5 Ref. 7, pp. 29~32, 52, 152-153

Ref. 13, p. 1 

E2S48 (GW15) Unconsolidated 

Sand

and Gravel

2.5 Ref. 7, pp. 29~32, 54, 158-159

Ref. 13, p. 1

E2S49 (GW18) Unconsolidated 

Sand

and Gravel

2.5 Ref. 7, pp. 29~32, 57, 160-161

Ref. 13, p. 1 

E2S47 (GW19) Unconsolidated 

Sand

and Gravel

2.5 Ref. 7, pp. 29~32, 58, 156-157

Ref. 13, p. 1 

E2S82 (GW04) Unconsolidated 

Sand

and Gravel

12 Ref. 7, pp. 29~32, 38, 170-171

Ref. 20, p. 1 

The sum of the population was multiplied times 10 for a Level I Concentrations Factor Value of 

1,395 (Ref. 1, Section 3.3.2.2, p. 74).

Level I Concentrations Factor Value: 1,395

3.3.2.3 Level II Concentrations 

One residence exhibited TCE contamination above background concentrations indicating Level II 

contamination. 

 1 x 2.5 = 3 (Ref. 1, Section 3.3.2.3, p. 74)

Level II Concentration Factor Value: 3 

3.3.2.4 Potential Contamination 

Potential Contamination was not calculated. The Garden City Ground Water Plume has sufficient 

Level I and II targets to exceed the maximum value (100) for this pathway. 

 

3.3.3 Resources

The ground water in the Unconsolidated Sand and Gravel Aquifer is used for livestock and 

irrigation within the target distance limit. Irrigation equipment was in place and well log records 

designate some wells for livestock and irrigation. A Resource Factor value of 5 is assigned (Ref. 

1, Section 3.3.3, p. 75; Ref. 66, p. 12; Ref. 76, pp. 1~4).

Resources Factor Value: 5
38 

3.3.4 Wellhead Protection Area

The entire ground water plume lies within the southern Wellhead Protection Area of the City of 

Columbus’ well field (Fig.1-6 of this HRS documentation record). Wellhead Protection Areas are 

designated by IDEM in accordance with Section 1428 of the Safe Water Drinking Act (Ref. 79, pp. 1, 

7; Ref. 91). Therefore, the Wellhead Protection Area Factor Value of 20 is assigned (Ref. 1, Section 

3.3.4, p. 75).

Wellhead Protection Area Value: 20 

3.3.5 Calculation of Targets Factor Value 

The target factor value is calculated by determining the sum of the factor values for the nearest well 

(50), population (1,398), resources (5), and Wellhead Protection Area (20), (Ref. 1 Section 3.3.5, p. 

75).

 50.0 + 1,398 + 5.0+ 20.0 = 1,473 

3.4 GROUND WATER MIGRATION SCORE 

The Ground Water Migration Score for the Garden City Ground Water Plume is calculated by 

multiplying the factor category values for Likelihood of Release (550), Waste Characteristics (18), and 

Targets (1473), divided by 82,500. The resulting value (with a maximum value of 100) is assigned as 

the ground water migration pathway score. 

 (550 x 18 x 1,473) / 82,500 = 176.76 or a maximum value of 100.00 (Ref. 1, p. 78) 

3.5 CALCULATION OF GROUND WATER MIGRATION PATHWAY SCORE

The maximum value (100) was assigned to Ground Water Migration Pathway. 

 Ground Water Migration Pathway Score = 

100.00 (Ref. 1, p. 78)