The City requested assistance from EPA after discovering coal ash & cinders, foundry sands, drums and other potential for hazardous substances at the Site.  EPA performed a Site Assessment and documented levels of lead as high as 9,400 parts per million (ppm) (total lead) and 110 milligrams/Liter (mg/L) TCLP in unconfined waste piles and surface soils at the Site.  Lead is designated as a hazardous substance under Section 102 of CERCLA and TCLP results were above hazardous waste regulatory levels for toxicity characteristic.  Numerous drums, an above ground storage tank (AST), and other containers are also abandoned at the Site.  Many containers are old, deteriorated and empty.  At least one deteriorated drum was a lined acid drum. 

Future site workers, including sewer construction workers and city sanitation workers, as well as future public park users could be exposed to hazardous substances or pollutants or contaminants presently at the Site.  Contaminants may also migrate offsite by storm water runoff, flooding and erosion by the Wabash River, leaching to groundwater, wind action, or by foot or vehicle traffic. 

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

EPA performed a removal site evaluation of the Site.  The OSC and Superfund Technical Assessment and Response Team (START) contractors performed a site assessment including a site reconnaissance and a field sampling event on February 25th, 2013. EPA observed and documented the presence of approximately 150 55-gallon drums; numerous slag, foundry sand, ash and debris piles; and tires, heavy equipment, vehicles, and vehicle parts throughout the Site. Many of the drums and containers were deteriorated and empty. A large AST estimated at 10,000 gallons was located in the northeast corner of the retention pond and approximately 10 to 15 ft into the water. EPA collected one sediment sample, one surface water sample, and ten surface soil or waste pile samples. Analytical results documented lead in soil/waste pile samples exceeding: IDEM’s direct contact standards for industrial soil and excavation; EPA’s industrial removal management level (RML) for lead; and hazardous waste criteria for toxicity characteristic leaching procedure (TCLP) Lead. (Site Assessment Report, Weston, 2013)

EPA and START performed additional screening and sampling for metals May 9 through 13, 2014 to determine scope and extent of contamination in surface soil.  A grid system was used to track data, the system will direct where removal work is to be performed.  EPA also collected additional sediment samples in the surface impoundment and wetlands at the Site.  Results will be distributed to the City and IDEM Site Investigations.

The response actions described below will be implemented to directly address actual or potential releases of hazardous substances or pollutants or contaminants at the site which may pose an imminent and substantial endangerment to public health, or welfare, or the environment. Activities on-site will include:

-Screening additional areas for lead in waste piles and surface soils.

-Performing test trenching and screening for lead within the area where the City will be excavating a construction trench;

-Excavating surface soils and waste piles contaminated with lead greater than 800 ppm;

-Evaluation of drums, AST and other containers for hazardous substances or pollutants or contaminants;

-Staging, monitoring and sampling of containers as necessary for waste characterization and disposal options;

-Implementing post excavation soil sampling/monitoring to determine if elevated sub-surface contamination will remain on site, and delineating remaining subsurface contamination detected before backfilling;

-Determine options for treatment, backfilling and covering of, or off-site disposal of, lead contaminated soils;

-Coordinating backfilling and restoring the excavated and disturbed areas with the City; and

-Transportation and off-site disposal of wastes at an approved facility.