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 #7
Progress Report
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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7/31/2014
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Reporting Period:
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July 1 - 31, 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 tepee-style 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.
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.
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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 contracted with SESCO Group (SESCO). SESCO accomplished the following between July 1-31, 2014:
- Submitted a work plan for sampling surface waste piles. The work plan has been posted to the Documents section of www.epaosc.org/kokomodump; and
- Submitted a revised schedule on July 15, 2014.
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. Refer to the Issues section (2.2.2) regarding waste disposal.
| 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 |
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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 |
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Work Plan Approval |
NA |
NA |
2/24/2014 |
| 16c |
Field Investigation |
4/21/2014 |
2/24/2014 |
4/21/2014 |
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Site boundary survey |
3/17/2014 |
3/7/2014 |
3/7/2014 |
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Phase I environmental site assessment |
3/3/2014 |
2/3/2014 |
5/28/2014 |
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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 |
6/13/2014 |
3/31/2014 |
6/10/2014 |
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Waste Pile Work Plan |
7/7/2014 |
7/7/2014 |
7/7/2014 |
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Waste Pile Sampling |
9/11/2014 |
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Waste Pile Analytical Results |
10/27/2014 |
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| 16f |
Surface and subsurface soil sampling |
4/21/2014 |
4/14/2014 |
4/21/2014 |
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Laboratory Results |
5/12/2014 |
NA |
6/27/2014 |
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Test pit excavations |
2/23/2015 |
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Removal |
TBD |
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| 22 |
Final Report, 60 days after removal is complete |
3/23/2015 |
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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
Surface waste pile sampling is scheduled to begin on September 9, 2014.
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
SESCO did not obtain EPA's certification that the disposal facility was operating in compliance with the Off-Site Rule. The receiving facility, CGS Services, is not an acceptable facility under the Off-Site Rule.
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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
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
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3. Participating Entities
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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.
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4. Personnel On Site
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No personnel were on-site during the reporting period for time-critical removal activities.
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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 |
| 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 |
| TBD |
To Be Determined |
| 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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