IDEM 

ed Paper 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect }Joos;ers and Our Environn1ent. 

100 N. Senate Avenue • Indianapolis, IN 46204 

(800) 451-6027 • (317) 232-8603 • www.idem.lN.gov 

Michael R. Pence 

Gol'enwr 

Thomas W. Easterly 

Commissioner 

June 30, 2015 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA, Region V, R-19J 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3507 

Dear Ms. Hedman: 

Re: Proposed Inclusion of the 

West Vermont Contaminated Drinking 

Water Site, Indianapolis, Marion County, 

Indiana, on the National Priorities List of 

Hazardous Waste Sites 

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 

inclusion of the West Vermont Contaminated Drinking Water site on the National Priorities List 

(NPL) of hazardous waste sites. The West Vermont Contaminated Drinking Water site, SEMS 

ID number INN000510429, is a ground water plume that encompasses an area of 

approximately 21.5 acres. The site includes three residential wells with vinyl chloride 

contamination in Indianapolis, Marion County, Indiana. There are 20 additional residential 

homes within the area that obtain drinking water from their private wells that may be subject to 

the contamination. 

IDEM has identified two (2) sources of contamination, Genuine Parts and Michigan 

Plaza. The responsible parties are currently enrolled in IDEM's Voluntary Remediation Program 

(VRP), however, one of the parties in particular, Michigan Plaza, has been difficult to work with 

and reluctant to fully address U.S. EPA's and IDEM's environmental concerns. For instance, the 

responsible parties for Michigan Plaza injected a vegetable-oil based product, CAP 18, into the 

ground water as part of their remedy before fully investigating and delineating their source 

areas. This lack of understanding of release mechanisms, extent of contamination, and aquifer 

geochemistry likely underestimated the mass and extent of contamination, and without a 

complete understanding of source areas may have resulted in an over production of vinyl 

chloride in the ground water that has impacted the residential wells. 

VRP accepted Genuine Parts and Michigan Plaza into the program in 1999 and 2006, 

respectively. They have remained in VRP since that time and despite repeated requests by 

IDEM, still have not determined the nature and extent of contamination. In addition, VRP staff 

0 An Equal Opportunity Employer A State that � • Recycl
Ms. Susan Hedman 

Regional Administrator 

Page 2 of2 

has asked the responsible parties to investigate potential vapor intrusion into the nearby 

residential homes. This investigation has not been conducted. 

In a meeting with U.S. EPA, Region V, on April 29, 2015, the PRPs did not agree to 

conduct time-critical removal actions under an Administrative Settlement Agreement and Order 

on Consent. If the PRPs had agreed to conduct the time-critical removal actions (connecting 23 

residents to municipal water), conduct a vapor intrusion investigation/mitigation program and 

reimburse EPA the $1 million dollars they owe in past costs, EPA would have no longer 

considered this site for inclusion on the National Priorities List (NPL) as a Superfund site. 

This site qualifies for inclusion on the NPL because: 

1) The site meets the National Oil and Hazardous Substances Pollution Contingency

Plan (NCP) criteria for listing on the NPL, scoring sufficiently high pursuant to the

Hazard Ranking System (HRS).

2) The site requires a long-term response action.

An NPL listing would allow for proper and timely investigation of the nature and extent of 

the contamination of the potential sources and enable the U.S. EPA to determine clean up 

alternatives for the impacted areas, thereby protecting human health and the environment. The 

NPL listing appears to be the most viable alternative for addressing the existing environmental 

problems. 

As the Commissioner of IDEM, I am authorized by Indiana Governor Michael R. Pence 

to act in these matters on his behalf. I have considered my staff's recommendations and I fully 

support the designation of the West Vermont Drinking Water Contamination site for inclusion on 

the NPL. I request that the U.S. EPA assign a Remedial Project Manager and/or On-Scene 

Coordinator to implement the process. If you require any additional information or have any 

questions, please contact Mark Jaworski of the Site Investigation Program at 317 /233-2407 or 

via e-mail at mjaworsk@idem.in.gov. 

· Thomas W. Easterly

Commissioner

cc: Denise Boone, U.S. EPA 

Nuria Muniz, U.S. EPA 

Mark Jaworski, IDEM