U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Kokomo Dump - Removal Polrep

EPA Emergency Response

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
Subject: POLREP #14
Progress Report
Kokomo Dump
C564
Kokomo, IN
Latitude: 40.4770000 Longitude: -86.1650000

To:
From: Shelly Lam, On-Scene Coordinator
Date: 3/2/2015
Reporting Period: February 1-28, 2015

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: 2/24/2014    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 1963 to the 1970s.  Landfill operations included running a large tepee-style incinerator until the mid to 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 the Dixon Road Site 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, included lead, arsenic, polychlorinated biphenyls (PCB), benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene, and indeno(1,2,3-cd)pyrene. 

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 U.S. Environmental Protection Agency (EPA) On-Scene Coordinator (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.

Additional site investigation in April 2014 documented hazardous substances including  lead, arsenic, PCBs, benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene, and indeno(1,2,3-cd)pyrene; and pollutants and contaminants including benzo(a)anthracene.  Refer to PolRep #6 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
The City of Kokomo and its insurers contracted with SESCO Group (SESCO).  For actions conducted before February 2015, refer to previous PolReps.

During this reporting period, SESCO and their subcontractor, Environmental Restoration (ER), excavated 26 test pits around anomalies identified during the geophysical survey and one test trench outside of the geophysical survey area.  A map showing test pit locations can be found in the Documents section of www.epaosc.org/kokomodump. 

A list of material found in each test pit is in the table below.  Excavated materials were returned to the test pits, except for drums, one paint can, and uncontained paint excavated from the test trench.  Those materials were staged on and covered by visqueen and left on-site pending disposal.

SESCO collected 17 samples from test pits and/or material found within test pits, such as drums.  SESCO field screened samples with a photo-ionization detector (PID) and x-ray fluorescence (XRF) detector.  Samples submitted for laboratory analysis had field screening readings  with PID above 10 parts per million (ppm) and/or metal readings within +/- 10% of IDEM industrial direct contact screening levels.

In Test Pit 16, SESCO excavated along the east side of a concrete pad, where historical aerial photographs indicated a clam shell building had been located. It was discovered that the eastern wall of the pad extended to at least 12 feet below ground surface (bgs). SESCO cored through the center of the pad, which was only 7 inches thick. OSC Lam discovered a newspaper article from 1969 showing that clam shell buildings often had a sub-grade dump pit (see the Documents section of www.epaosc.org/kokomodump). As such, OSC Lam requested that SESCO submit a work plan for investigating the concrete pad, which SESCO submitted on February 23, 2015.  

Between February 10-18, 2015, the City of Kokomo transported 138.01 tons of concrete to Kokomo Gravel and 2.56 tons of clay pipe to Touby Pike Recycling Center for recycling.  On February 23-24, 2015, the City transported 659 tires to Leffler Tire Recycling. 

Excavation ID Excavation Date Excavation Contents/Observations
Test Pit 1 2/5/2015 Concrete, metal strapping, brick, clay piping
Test Pit 2 2/5/2015 Concrete, brick, metal pieces, brown soil 
Test Pit 3 2/5/2015 Concrete, brick, metal cans, metal pieces, paint can, wood, steel plates, petroleum odor
Test Pit 4 2/4/2015 Metal piping, brown/black soil, newspaper, glass jars, metal pieces, petroleum odor
Test Pit 5 2/3/2015 Asphalt shingles, concrete, metal bucket handle, wood, petroleum odor
Test Pit 6 2/3/2015 Concrete, metal strapping
Test Pit 7 2/4/2015 Brown soil, gravel, water
Test Pit 8 2/3/2015 Asphalt, asphalt shingles, metal strapping, wood debris, black soil, petroleum odor
Test Pit 9 2/3/2015 Brick, concrete, wood, brown silty soil
Test Pit 10 2/3/2015 Asphalt, bricks, metal debris, steel plates, strong solvent odor
Test Pit 11 2/3/2015 Concrete, metal piping, black soil
Test Pit 12 2/4/2015 Metal pieces, wood, drum lid, dark brown soil, 55-gallon drum at approximately 4 feet bgs
Test Pit 13 2/4/2015 Metal piping, metal pieces, bricks, glass jars, dark brown , possible incinerator waste: cinder-like material, bottles
Test Pit 14 2/4/2015 Wood, metal pieces, car seat, bricks, strong petroleum odor
Test Pit 15 2/4/2015 Metal piping, brown soil
Test Pit 16 2/3/2015 Concrete, dark brown soil, concrete foundation at depth of 12 feet bgs.
Test Pit 17 2/3/2015 Concrete pad present, excavation abandoned
Test Pit 18 2/3/2015 Concrete, metal piping, wood, reddish soil
Test Pit 19 2/3/2015 Tires, metal pieces, automotive parts, wood, brown/black soil
Test Pit 20 2/3/2015 Concrete, metal pieces, wood, dark brown soil
Test Pit 21 2/3/2015 Metal fence, bricks, plastic piping, dark brown soil
Test Pit 22 2/3/2015 Wood, concrete, tires, metal pieces, plastic pieces, dark brown soil, 55-gallon drum at approximately 3 feet bgs
Test Pit 23 2/4/2015 Tires, dark brown soil
Test Pit 24 2/4/2015 Tires, automotive parts, concrete, metal pieces, drum lid, dark brown soil, wood
Test Pit 25 2/4/2015 Brick, metal pieces, dark brown soil, possible incinerator waste: cinder-like material, bottles
Test Pit 26 2/4/2015 Clay tile drain, drum lid, dark brown soil, possible incinerator waste: cinder-like material, bottles
Test Pit 27 2/4/2015 Metal fence, metal strapping, concrete, wood, possible incinerator waste: cinder-like material, bottles
Test Trench 2/5/2015 Metal bucket lids, wood, glass bottles, brown soil, five 55-gallon drums, possible paint material

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
Non-hazardous purge water Liquid 100 gallons 70914 NA CGS Services, Morristown, Indiana
Non-hazardous soil cuttings Solid 410 gallons 70914 NA CGS Services, Morristown, Indiana
Concrete (recycled material) Solid 138.01 tons NA NA Kokomo Gravel, Kokomo, IN
Clay pipe (recycled material) Solid 2.56 tons NA NA Touby Pike Recycling Center, Kokomo, IN
Scrap tires (recycled material) Solid 659 NA NA Leffler Tire Recycling, Peru, IN

Below is a schedule of milestones per the ASAOC and/or the approved schedule.

Order # Milestone Date Due Date Started Date Done
89 Effective Date 8/5/2013 Not applicable (NA) 8/5/2013
16b Establish site security NA NA 8/5/2013
12 Contractor Notification, including Quality Management Plan 8/12/2013 NA 8/9/2013
13 Project Coordinator Notification 8/12/2013 NA 8/9/2013
18 HASP 9/4/2013 NA 9/4/2013
17a Work Plan, including QAPP 9/4/2013 NA 9/4/2013
17b Work Plan Revisions 10/27/2013 NA 10/27/2013
  Work Plan Approval NA NA 2/24/2014
16c Field Investigation 4/21/2014 2/24/2014 4/21/2014
  Site boundary survey 3/17/2014 3/7/2014 3/7/2014
  Phase I environmental site assessment 3/3/2014 2/3/2014 5/28/2014
  Brush clearance 3/3/2014 2/24/2014  
  Utility clearance 4/10/2014 2/18/2014 2/18/2014
  Surface drum removal 2/26/2014 2/24/2014 2/26/2014
  Geophysical survey 6/13/2014 3/31/2014 6/10/2014
  Geophysical survey completion 1/8/2015 12/15/2015 12/15/2014
  Waste Pile Work Plan 7/7/2014 NA 7/7/2014
  Waste Pile Work Plan Approval NA NA 7/31/2014
  Waste Pile Sampling 9/11/2014 9/9/2014 9/11/2014
  Waste Pile Analytical Results 10/17/2014 NA 10/14/2014
  Waste Pile Relocation or Disposal 12/12/2014 12/2/2014 12/8/2014
16f Surface and subsurface soil sampling 4/21/2014 4/14/2014 4/21/2014
  Laboratory Results 5/12/2014 NA 6/27/2014
  Test pit excavations 2/6/2015 2/3/2015 2/5/2015
  Removal TBD    
22 Final Report, 60 days after removal is complete TBD    


  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
In March, SESCO will conduct an investigation of the concrete pad to find out if it is a subsurface pit containing material that may be a threat to human health or the environment.  SESCO will also submit a summary report, including a work plan for time-critical removal actions.

2.2.1.2 Next Steps
The areas to be removed will be determined by the surface and subsurface soil analytical results, the geophysical survey, and test pit findings.

2.2.2 Issues
None.
  2.3 Logistics Section
    NA
  2.4 Finance Section
    No information available at this time.
  2.5 Other Command Staff
    2.5.1 Safety Officer
Personnel are working under an approved HASP.   EPA's OSC has overall responsibility for health and safety.

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 with the Indiana Department of Environmental Management (IDEM) and the Howard County Health Department.
4. Personnel On Site
  The following personnel were on-site during the reporting period for time-critical removal activities.

EPA 1
START 1
SESCO 3
ER 3


5. Definition of Terms
 
ASAOC Administrative Settlement Agreement and Order on Consent
bgs below ground surface
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
EPA Environmental Protection Agency
ER Environmental Restoration
HASP Health and Safety Plan
IDEM Indiana Department of Environmental Management
NA Not Applicable
OSC On-Scene Coordinator
PCB Polychlorinated Biphenyls
PID Photo-ionization detector
PolRep Pollution Report
ppm parts per million
PRP Potentially Responsible Party
QAPP Quality Assurance Project Plan
SESCO SESCO Group
START Superfund Technical Assessment and Response Team
TBD To Be Determined
USC U.S. Code
XRF X-ray fluorescence


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