U.S. ENVIRONMENTAL PROTECTION AGENCY POLLUTION/SITUATION REPORT Kokomo Dump - Removal Polrep UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region V
Subject:	POLREP #2 Progress PolRep Kokomo Dump C564 Kokomo, IN Latitude: 40.4770000 Longitude: -86.1650000
To:
From:	Shelly Lam, On-Scene Coordinator
Date:	11/26/2013
Reporting Period:	September 1 - October 31, 2013
1. Introduction   1.1 Background     Site Number: C564    Contract Number:   D.O. Number:      Action Memo Date: 8/13/2012 Response Authority: CERCLA    Response Type: PRP Oversight Response Lead: PRP    Incident Category: Removal Action NPL Status: Non NPL    Operable Unit: Mobilization Date:      Start Date: 8/5/2013 Demob Date:      Completion Date:   CERCLIS ID: INN000510728    RCRIS ID: ERNS No.:    State Notification: FPN#:    Reimbursable Account #: 1.1.1 Incident Category Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) incident category:  Waste Management - co-disposal landfill (municipal and industrial) 1.1.2 Site Description The Kokomo Dump Site is 4.54 acres in size, and contains one small building.  The City of Kokomo owns the property, which is currently operated by Howard County as a yard waste recycling center.    The City operated a municipal landfill at the site from approximately 1963 to the 1970s.  Landfill operations included running a large incinerator until the late 1960s. 1.1.2.1 Location The Kokomo Dump Site is located at 1130 S. Dixon Road in Kokomo, Howard County, Indiana, 46901.  The geographical coordinates for the site are latitude 40.477° north and longitude 86.165° west.  The area around the site is mixed use, including residential, commercial, and industrial properties.  The site is bounded by a metal recycling facility to the north; a railroad and Haynes International to the east; residential properties to the south; and Dixon Road to the west.  Wildcat Creek is approximately 500 feet from the northern  boundary of the site.  1.1.2.2 Description of Threat The Site Assessment documented hazardous substances in surface soil/waste piles, subsurface soil, and leaking from drums into a small creek, which drains into Wildcat Creek.  Hazardous substances, as defined by Section 101(14) of CERCLA, include lead, arsenic, and polychlorinated biphenyls (PCB).  The facility is currently operated as a yard waste recycling center, and is open to the public.  Additionally, the facility is not fenced completely along the southern, western, and northern property boundaries, potentially allowing access to trespassers.  The Environmental Protection Agency's (EPA) On-Scene Coordinator (OSC) observed that one of the drums was close to a child’s swing set on a neighboring residential property. Release mechanisms from these sources include fugitive dust generation from soil or waste to air; contaminated surface soil or waste runoff and overland flow to surface water, in particular Wildcat Creek; leaching of surface and buried waste to groundwater and deeper soils; and tracking of contaminated surface soil or waste.  Possible exposure routes for hazardous substances include dermal contact with contaminated soil or waste; inhalation or accidental ingestion of fugitive dust; and direct contact with potentially-impacted surface water or sediment in the on-site creek or Wildcat Creek.  Potential human receptors include current and future site workers, site visitors, trespassers at the site, recreational users of Wildcat Creek, and nearby residents.  1.1.3 Preliminary Removal The OSC and the Superfund Technical Assessment and Response Team (START) contractor conducted a Site Assessment on August 19, 2011.  Site Assessment activities included drum, surface and subsurface soil sampling. EPA documented high levels of lead, arsenic, and PCBs.  Refer to Pollution Report (PolRep) #1 for additional information. 2. Current Activities   2.1 Operations Section     2.1.1 Narrative EPA executed an Administrative Settlement Agreement and Order on Consent (ASAOC) on August 5, 2013, pursuant to Sections 104, 106(a), 107 and 122 of CERCLA, as amended, 42 U.S. Code (USC) §§ 9604, 9606(a), 9607 and 9622. Work to be performed under the ASAOC includes: Developing and implementing site plans including a site-specific Health and Safety Plan (HASP), a Quality Assurance Project Plan (QAPP), a Site Emergency Contingency Plan, and a Work Plan; Establishing site security; Determining the extent of buried drums and contamination in soil; Developing and implementing a plan to control, contain, and/or remove drums and highly contaminated soil; Performing sampling and analysis to determine disposal options; Providing EPA with notice of sampling events five (5) business days in advance of the sampling so that EPA can conduct oversight and split samples; and  Consolidating and packaging hazardous substances, pollutants and contaminants for transportation and off-site disposal in accordance with the EPA Off-Site Rule, 40 Code of Federal Regulations (CFR) § 300.440. 2.1.2 Response Actions to Date On September 4, 2013, the consultant for the City of Kokomo submitted a Work Plan, HASP, and QAPP.  EPA disapproved the Work Plan, HASP, and QAPP.  There was a substantial lack of detail with regards to specific removal actions.  Additionally, the documents failed to adequately address the work to be performed outlined in Section VIII of the ASAOC.  EPA required that the City of Kokomo resubmit the documents to comply with the ASAOC and to be consistent with EPA guidance documents.  Revised documents were resubmitted on October 25, 2013. 2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs) EPA executed Docket No. V-W-13 C-018 on August 5, 2013 with the City of Kokomo as the Respondent.  2.1.4 Progress Metrics Below is a summary of waste transported off-site. Waste Stream Medium Quantity Manifest # Treatment Disposal Pending                                   Below is a schedule of milestones per the ASAOC. Order # Milestone Date Due Date Done 89 Effective Date 8/5/2013 8/5/2013 16b Establish site security     12 Contractor Notification, including Quality Management Plan 8/12/2013 8/9/2013 13 Project Coordinator Notification 8/12/2013 8/9/2013 18 HASP 9/4/2013 9/4/2013 17a Work Plan, including QAPP 9/4/2013 9/4/2013 17b Work Plan Revisions 10/27/2013 10/27/2013   Work Plan Approval     16c Field Investigation        Site boundary survey        Phase I environmental site assessment        Brush clearance        Utility clearance        Surface drum removal        Geophysical survey         16f  Surface and subsurface soil sampling      Test pit excavations     Removal     22 Final Report, 60 days after removal is complete       16e Sampling Notification to EPA, 5 days prior     21a Progress Reports, 30th of every month       2.2 Planning Section     2.2.1 Anticipated Activities The following sections discuss planned response activities and next steps. 2.2.1.1 Planned Response Activities EPA will review and provide comments on the revised Work Plan, HASP, and QAPP. 2.2.1.2 Next Steps Once EPA approves the work plan, field work will commence in accordance with the schedule outlined in the work plan. 2.2.2 Issues None   2.3 Logistics Section     Not applicable (NA)   2.4 Finance Section     No information available at this time.   2.5 Other Command Staff     2.5.1 Safety Officer Pending 2.5.2 Liaison Officer NA 2.5.3 Information Officer NA 3. Participating Entities   3.1 Unified Command NA 3.2 Cooperating Agencies EPA will coordinate activities with the Indiana Department of Environmental Management (IDEM) and the Howard County Health Department. 4. Personnel On Site   None 5. Definition of Terms   ASAOC Administrative Settlement Agreement and Order on Consent CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations EPA Environmental Protection Agency HASP Health and Safety Plan IDEM Indiana Department of Environmental Management NA Not Applicable OSC On-Scene Coordinator PCB Polychlorinated Biphenyls PolRep Pollution Report PRP Potentially Responsible Party QAPP Quality Assurance Project Plan START Superfund Technical Assessment and Response Team USC U.S. Code 6. Additional sources of information   6.1 Internet location of additional information/report Additional information is posted to www.epaosc.org/kokomodump. 6.2 Reporting Schedule PolReps will be submitted monthly. 7. Situational Reference Materials   NA