U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Kokomo Dump - Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region V
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Subject:
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POLREP #3
Progress PolRep
Kokomo Dump
C564
Kokomo, IN
Latitude: 40.4770000 Longitude: -86.1650000
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To:
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From:
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Shelly Lam, On-Scene Coordinator
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Date:
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2/28/2014
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Reporting Period:
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February 24-27, 2014
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1. Introduction
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1.1 Background
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Site Number: |
C564 |
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Contract Number: |
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D.O. Number: |
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Action Memo Date: |
8/13/2012 |
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Response Authority: |
CERCLA |
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Response Type: |
PRP Oversight |
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Response Lead: |
PRP |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
2/24/2014 |
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Start Date: |
8/5/2013 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
INN000510728 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
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FPN#: |
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Reimbursable Account #: |
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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 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.
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2. Current Activities
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2.1 Operations Section
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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 have contracted with SESCO Group (SESCO). SESCO and its subcontractor, Environmental Restoration LLC (ER), mobilized to the site on February 24, 2014. During the reporting period, SESCO and ER accomplished the following:
- Established work zones;
- Began brush clearing for geophysical survey and soil sampling;
- Overpacked surface drums;
- Collected three soil samples beneath removed drums; and
- Conducted perimeter air monitoring for particulates.
SESCO and ER demobilized from the site on February 27, 2014 but will return in March for additional time-critical removal actions .
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 |
| Drums |
Solid |
5 |
Pending |
Not applicable (NA) |
Staged on site pending disposal |
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Below is a schedule of milestones per the ASAOC.
| Order # |
Milestone |
Date Due |
Date Started |
Date Done |
| 89 |
Effective Date |
8/5/2013 |
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 |
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Work Plan Approval |
NA |
NA |
2/24/2014 |
| 16c |
Field Investigation |
4/21/2014 |
2/24/2014 |
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Site boundary survey |
3/17/2014 |
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Phase I environmental site assessment |
3/3/2014 |
2/3/2014 |
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Brush clearance |
3/3/2014 |
2/24/2014 |
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Utility clearance |
4/10/2014 |
2/18/2014 |
2/18/2014 |
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Surface drum removal |
2/26/2014 |
2/24/2014 |
2/26/2014 |
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Geophysical survey |
TBD |
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| 16f |
Surface and subsurface soil sampling |
4/21/2014 |
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Test pit excavations |
TBD |
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Removal |
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| 22 |
Final Report, 60 days after removal is complete |
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2.2 Planning Section
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2.2.1 Anticipated Activities
The following sections discuss planned response activities and next steps.
2.2.1.1 Planned Response Activities
Planned removal actions include the following:
- Conducting a site boundary survey;
- Providing a Phase I environmental site assessment report;
- Completing brush clearance;
- Conducting utility clearance;
- Performing a geophysical survey;
- Sampling surface and subsurface soil; and
- Excavating test pits.
2.2.1.2 Next Steps
The areas to be removed will be determined by the surface and subsurface soil analytical results and the geophysical survey.
2.2.2 Issues
There is significantly more yard waste (trees, grass, brush, etc.) covering the site than anticipated. The geophysical survey cannot be completed until the majority of yard waste has been removed from the site. The City of Kokomo is contracting with GreenCycle to remove the yard waste that has a beneficial reuse. The remaining yard waste may need to be disposed at a landfill.
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2.3 Logistics Section
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NA
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
Site personnel met daily for health and safety briefings. Personnel are working under an approved HASP. ER had a Site Health and Safety Officer on-site full-time with responsibility for implementing the HASP. Additionally, EPA's OSC has overall responsibility for health and safety.
2.5.2 Liaison Officer
NA
2.5.3 Information Officer
NA
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3. Participating Entities
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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.
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4. Personnel On Site
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| EPA |
1 |
| START |
1 |
| SESCO |
2 |
| ER |
4 |
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5. Definition of Terms
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| 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 |
| ER |
Environmental Restoration LLC |
| HASP |
Health and Safety Plan |
| IDEM |
Indiana Department of Environmental Management |
| NA |
Not Applicable |
| OSC |
On-Scene Coordinator |
| PCB |
Polychlorinated Biphenyls |
| PolRep |
Pollution Report |
| QAPP |
Quality Assurance Project Plan |
| PRP |
Potentially Responsible Party |
| SESCO |
SESCO Group |
| START |
Superfund Technical Assessment and Response Team |
| USC |
U.S. Code |
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6. Additional sources of information
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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.
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7. Situational Reference Materials
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NA
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