CONRAIL03

July 19, 1991

Janet R. CarIBonAssistant Regional CounselU.S. EPA, Region V230 South Dearborn StreetChicago, IL 60604

Dear Janett

Enclosed are two documents: 1) an executed accessagreement for the Phase II Work Plan and 2) comments on theWork Plan prepared by our consultants, GeoTrans, Inc. andGroundwater Technology, Inc. We request that both documentsbe made a part of the administrative record.

As the Region knows from past experience, the ElkhartYard is a busy and potentially dangerous place to work giventhe many trains which move in and out of the Yard on a dailybasis. Therefore, we request the Region and its contractorsto coordinate all activities with Tom Fendergast and/or hisdesignee. Tom can be reached at 606 Six Perm Center,Philadelphia, PA 19103, (215) 977-1688. Although I am outfor the next two weeks on vacation, please feel free to calland leave a message with my office if you have anyquestions. I will be in touch with the office on a regularbasis.

With regard to the Phase II Work Plan, we believe theWork Plan inadequately addresses the need to identify andassess the sources of contamination. Our concern goes notonly to identifying the sources of contamination but also toprovide a sufficient basis for remedy selection and theultimate protection of human health and the environment.See 55 Fed. Reg. 8700 (1990) and 40 C.F.R. $300.430(a)(1)(i)(1990). We believe the data gathered so far and to begathered inadequately defines the basis need for remedyselection, in particular, groundwater pump and treatment.In this regard, the Work Plan will not obtain data to meetthe Agency's goal to protect human health and theenvironment, maintain protection over tine and minimiseuntreated waste. See 55 Fed. Reg. 8702 (1990) and 40 C.F.R.S300.430 (d)(l)(2) (1990). Indeed, as discussed in ourcomments on the Interim Feasibility Study, the Agency may

CORPORATION SIX »ENN CFNTER PLA2A PHILADELPHIA PA 19103-2959

Page 2

not only fail to identify sources but, moreover, compromisethe protection of human health and the environment bypossibly contaminating wells presently clean by theinadequate collection of data and premature, if notunnecessary, implementation of a pump and treat remedy. Seealso 55 Fed. Reg. 8705 (1990), where each operable unit mustbe supported with sufficient site data, and 8708, settingthe purpose of the RI to adequately characterize the sitefor purposes of remedy selection.

As I say, if you have any questions, please contact me.

Sincerely,

Philip R. Boxell, Jr.Associate General Counsel

1138 Six Penn Center PlazaPhiladelphia, PA 19103-2959(215) 977-5038

PRB/td

enclosure

cci Dennis DalgaT. P. PendergastLeonard Oelman

PHASE II WORK PLAN COMMENTS

PREPARED ON BEHALF OF THECONSOLIDATED RAIL CORPORATION

BY GEOTRANS, INC. ANDGROUNDWATER TECHNOLOGY, INC.

JULY 17, 1991

1. THE PHASE II WORK FLAN DOES NOT ADEQUATELY CONSIDER

EXISTING INFORMATION REGARDING THE NATURE AND EXTENT OF

CONTAMINATION AS WELL AS THE CONTAMINATION SOURCES.

The stated purpose of the proposed Remedial

Investigation (RI) is "to determine the nature and extent of

contamination at the Conrail railyard and vicinity" (Ecology

and Environment, 1991, p. 1-1). The proposed study area of

the investigations, which encompasses approximately 2,500

acres, is "bounded on the north by the St. Joseph River, on

the west by Baugo Bay, on the south by the southern border

of the Conrail railyard, and on the east by Main Street*

(Ecology and Environment, 1991, p. 1-2). Specific

residential areas of interest within the study area include

the LaRue Street area, the County Road 1 area, the Vistula

Avenue area, and the Charles Avenue area (Ecology and

Environment, 1991, p.1-2). The proposed boundaries of the

study area and the planned investigative efforts indicate

that EPA has not adequately considered and even ignored

existing available information regarding the nature and

extent of contamination as well as contamination sources.

A. Despite several independent sources of information

which document groundwater contamination south of the

Conrail railyard, and despite information which

indicates that known plumes of contaminated groundwater

are flowing northward toward and under the Conrail

railyard, EPA has arbitrarily defined the study area to

exclude these areas of known groundwater contamination.

By selecting the southern boundary of the Conrail

railyard as the southern boundary of the study area, EPA has

ignored existing information that there is extensive

groundwater and soil contaminated with volatile organic

compounds (VOCs) south and upgradient of the Conrail

railyard. South of the Conrail railyard, EPA has seriously

designated ten CERCLIS sites where solvents and other

contaminants have been detected in soil and groundwater.

These sites are:

1. Gemeinhardt - 57882 S.R. 19 S

2. Champion Travel Trailers - 2103 W. Mishawauka Rd.

3. Rosen Property - County Road 20

4. Amoco Service Station - S.R. 19 and County Road 20

5. Bock Industries - 57540 S.R. 19 S

6. Bock Industries - 1901 W. Hively Avenue

7. Ned Bard & Son - 57755 Holiday Place

8. Century Chemical Products - 28790 County Road 20

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9. Superior Oil Co. - 57317 Nagy Drive

Solvents & Chemical Division

10. Walerko Tool & Engineering - 1935 W. Lusher Avenue

These sites and the groundwater quality data collected

by EPA and its contractors demonstrate that groundwater

contamination upgradient of the Conrail railyard exists from

an area east of State Road 19 to the Patriot Homes and to

the airport facilities which Are located south of the

central portion of the Conrail railyard. For example, an

investigation of the Gemeinhardt site area (ENSR, 1988)

identified a 4,000-foot long plume of contaminated

groundwater which extended toward the Conrail railyard and

the LaRue Street area. The ENSR report further indicated

that the residential neighborhood north of the Conrail yard

may be affected by this contaminant plume. The Gemeinhardt

area investigation suggested that the VOC plume resulted

from several different contamination sources in the vicinity

of the Gemeinhardt property. The likely location of these

sources was indicated in the ENSR report.

Monitoring well HW13S, which is located upgradient of

the west central portion of the Conrail facility, has

indicated groundwater contaminated with trichloroethylene

(TCE) (Ecology and Environmental, 1990). The source of the

contamination reported for that well is not known, but must

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be located south and upgradient of the Conrail facility.

The nature and extent of the contamination which affects

well MW13S cannot be determined if the study area does not

extend south and upgradient of the Conrail property to

include monitoring well HW13S and areas upgradient.

B. The Phase II Work Plan ignores existing information

which indicates that there are" several likely

contaminant sources within the proposed boundaries of

the study area.

The Phase II Work Plan refers to the County Road 1

plume as if it is most likely derived from a single source

which it states is most probably the Conrail railyard

(Ecology and Environment, 1991, p. 2-6). Groundwater

quality data from the County Road 1 area and Vistula Avenue

area, however, show that there are multiple contamination

sources rather than a single source. The reported

groundwater quality data also indicate that the northerly

portion of the County Road 1 area is characterized by TCE

contamination with a TCE hot-spot located south of the

intersection between Blane Avenue and County Road 1 (Ecology

and Environment, 1990, Figure 2-5). The southerly portion

of the County Road 1 area is characterized by carbon

tetrachloride (CC14) contamination with a CC1. hot-spot

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located in the vicinity of Elkhart Office Machines (Ecology

and Environment, 1990, Figure 2-6).

Previous soil gas surveys conducted by EPA indicated

high concentrations of CC1. in soil vapor samples on the

Elkhart Office Machine property and at a location along

Tower road. High soil vapor sample concentrations are

commonly indicative of a nearby source of contamination.

The Phase I RI soil gas survey results were reportedly used

to "verify the existence of potential source areas and to

assist in the location of soil borings where source areas

appear to be located" (Ecology and Environment, 1991, p.

2-3). EPA ignored the high soil gas results on the Elkhart

Office Machine property and along Tower Road during the

Phase I investigation and continues to ignore them in the

preparation and implementation of the Phase II Work Plan.

In addition to ignoring the water quality data which

indicate multiple sources of groundwater contamination for

the County Road 1 area, EPA has not considered the two

CERCLIS sites which are located between the Conrail rallyard

and the County Road 1 area. Both the Robert Martin Drum

site and the former ASA Fiberglass site are located between

the Conrail property and the contamination found in County

Road 1. Previous investigations of the Robert Martin Drum

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site have identified on-site TCE soil contamination (EIS

Environmental Engineers, Inc., 1986).

The high soil gas concentration data, which has been

documented on the Elkhart Office Machine property, and soil

contamination data, documented on the Robert Martin Drum

site, are verification of localized contamination sources.

When soil gas or soil quality data, as have been documented

on the Elkhart Office Machine and Robert Martin Drum

properties exist documenting that they are sources of

contamination, they must be used to plan more detailed

investigations to evaluate these existing contaminant

sources. The Phase II RI must include more detailed

investigations in these areas.

The Phase II Work Flan states that the Phase I Remedial

Investigation results suggest that the County Road 1

contamination, the Vistula Avenue contamination, and the

Charles Avenue contamination are connected. The inferred

connection is based, in part, on a reported similarity in

contaminants found in each of the three areas investigated

(Ecology and Environment, 1991, p. 2-6). In a subsequent

section of the Phase II Work Plan, however, a distinct

difference among contaminants found in the three areas is

noted. The Work Plan notes that 1, 1 1 trichloroethane

(TCA) has been detected in the Vistula Avenue area (Ecology

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and Environment, 1991, p. 3-3). TCA has not been reported

for the County Road 1 area. At a minimum, the presence of

TCA in the Vistula Avenue area again suggests another

separate contaminant source which contributes to the Vistula

Avenue contamination but not the County Road 1

contamination.

The issue of whether groundwater contamination reported

for the County Road 1 area, and other areas where

contamination exists, is derived from one source or from

several sources is important for EFA to evaluate prior to

starting the Phase II field investigation. The initial

working hypothesis regarding contaminant sources will affect

the level of intensity of investigation and thoroughness of

evaluation. It is unlikely that other contamination sources

will be identified if the underlying assumption of the

investigation is that there is only one contaminant source.

The existing data verifies that there is more than on

contaminant source north of the Conrail railyard.

The ability to identify these contaminant sources is

dependent upon the level of effort and thoroughness of the

Phase II investigation. It is important for EPA to use the

existing information regarding the nature and extent of

contamination to guide the Phase II investigation. The

erroneous assumption that only the Conrail railyard and the

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Robert Martin Drum site are potential sources of

contamination (Ecology and Environment, 1990, p. 2-10),

which were made during the Phase I investigation scoping

process, are inconsistent with existing site data and would

result in an inadequate and incomplete site investigation.

Even though the Martin Drum site was identified as a

potential source of contamination during the Phase I scoping

process, there was an extremely limited investigation of

that site during the Phase I RI. The Phase II RI must be

more thorough in its Investigation of potential sources.

C. EPA misrepresents data regarding the Charles Avenue

Area.

The Phase II Work Plan is inconsistent with respect to

contamination in the Charles Avenue area. There are

repeated references to Charles Avenue contamination (Ecology

and Environment, 1991, pp* 2-6, 2-8, 3-1) and the Phase II

Work Plan states that existing data are not sufficient to

delineate the TCE and CC1- contamination in the Charles

Avenue area. These statements are misleading and

inconsistent with available information regarding

contamination in the Charles Avenue area. Groundwater

sampling has not been conducted in the Charles Avenue > area

(Ecology and Environment, 1991, p. 2-6). Consequently, it

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is not known whether there is any TCE or CC1. contamination

in the Charles Avenue area.

Water quality data from EPA monitoring wells MW-4S and

MW-4D, which are the closest monitoring wells upgradient of

the Charles Avenue area and were installed by EPA to

specifically address potential sources of contamination to

the Charles Avenue area (Ecology and Environment, 1990,

p.2-19). The water sample analyses from these wells

document the absence of contamination. Thus, it is

inappropriate to refer contamination in the Charles Avenue

area when there is no reported groundwater quality data for

that area and the closest upgradient monitoring wells are

not contaminated.

2. THE PROPOSED PHASE II LEVEL OF EFFORT AND PROJECT

SCHEDULING ARE NOT ADEQUATE TO PROVIDE A REASONABLE

BASIS TO MEET THE STATED PURPOSE OF THE INVESTIGATION

AND SOME OF THE PROPOSED TASKS ARE INCONSISTENT WITH

KNOWN SITE CONDITIONS.

The stated purpose of the RI is "to determine the

nature and extent of contamination at the Conrail rallyard

and vicinity* Ecology and Environment, 1991, p. 1-1). The

proposed remedial investigation tasks include field

investigations to collect data regarding hydrogeologic

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conditions and groundwater quality; data validation and

evaluation; numerical model analyses to help identify

contaminant source areas, evaluate contaminant loading to

the St. Joseph River, and evaluate the effects of various

remedial alternatives on groundwater flow and chemical

transport; and an inventory of residential veils located

north of the St. Joseph River. The level of effort proposed

for these activities as well as the scheduled time for

completion are not sufficient to provide an adequate basis

for identifying contaminant sources and characterizing the

nature and extent of contamination, and the proposed well

inventory is inconsistent with previously described

hydraulic conditions.

A. The principal field activity which is intended to

provide data for determining the nature and extent of

contamination and for identifying source areas is the

lead-screen auger sampling. The lead-screen auger technique

is proposed as a field screening technique to characterize

the vertical distribution of contamination at a particular

location without installing a monitoring well. The results

from multiple lead-screening auger drilling locations would

be used to describe the distribution of contamination in

three dimensions. The spatial distribution of contamination

would be theoretically interpreted from field gas

chromatograph analysis of water samples collected during

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drilling. The lead-screen augering is intended to help

locate contaminant source areas as well as identify the

vertical and lateral extent of groundwater contamination.

Contaminant source areas would be identified on the basis of

interpreted contaminant concentration trends in the

upgradient direction from areas of known contamination. The

relationship between contamination in the County Road I,

Vistula Avenue, Charles Avenue, and LaRue Street areas would

presumably be interpreted on the basis of concentration

trends and contaminant continuity, or discontinuity, in all

directions from individual lead-screen auger drilling

locations.

If done properly and at a sufficient number of

locations, the lead-screen auger technique could be

effective for the intended purposes. There are numerous

potential sources of error, however, which could provide

misleading or incorrect information. Two of these error

sources ares

• Insufficient number of lead-screen auger drilling

locations to provide a reliable basis for

interpretation between drilling locations.

• Incorrect identification of upgradient and

downgradient directions.

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1* The planned Phase II investigation would be affected by both

of these sources of error.

1. The Phase II Work Plan provides for lead-screen

auger drilling to be done at 20 locations in the 2,500 acre

study area. The proposed drilling is planned to be done

over an area of 1,000 acres, or one drilling location for

every 50 acres. The average spacing between drilling

locations is too large to provide the level of detail

necessary to meet the project objectives. That is, it is

unlikely that the proposed number of lead-screen auger

borings will provide sufficient information regarding the

lateral and vertical distribution of contamination so that

potential contamination source areas and discontinuities

between contamination plumes can be identified. The known

spatial variability of contamination and possible source

areas requires a much closer spacing between lead-screen

auger drilling locations. Possible sources of contamination

include septic systems, dry wells, and spillage or dumping

in localized areas. These possible source areas are

generally small in areal extent and may require that the

spacing between data collection points be on the order of

tens of feet rather than acres. For example, the area of

County Road 1, which includes the previously mentioned TCB

and CC1* hot spots, such as the Robert Martin Drum site, ASA

Fiberglass, Elkhart Office Machines, Petersen Trucking and

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the northern boundary of the Conrail railyard. Is

approximately 60 acres. To evaluate known and potential

source areas and the continuity of contaminant plumes in

this area would require several lead-screen auger borings

for each source and the intervening regions.

2. The Phase II Work Plan states that successive

lead-screen auger drilling locations would proceed in

upgradient directions from areas of known contamination

(Ecology and Environment, 1991, p. 4-8). There is still

uncertainty regarding groundwater flow directions in

portions of the study area including the areas to be

investigated with the lead-screen auger sampling. The Phase

II Work Plan acknowledges this uncertainty by indicating

that it is necessary to install additional monitoring wells

to refine the understanding of the groundwater flow regime

(Ecology and Environment, 1991, p. 4-13). The monitoring

wells, which are intended to provide a better understanding

of groundwater flow conditions, would not be installed,

however, until after the lead-screen auger sampling is

completed. Consequently, the lead-screen auger drilling

program, which requires an understanding of groundwater flow

conditions, should not be undetaken before the groundwater

flow directions are determined.

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B. Prior to doing any field investigations, likely

source(s) of groundwater contamination are to be identified

on the basis of model analyses. The analyses have been

proposed to 'ensure that potential source areas are not

overlooked during the lead-screen auger investigation"

(Ecology and Environment, 1991, p. 4-16). Neither the Phase

II Work Plan nor the Phase I Work Plan provides sufficient

information regarding the proposed model analyses so they

cannot be evaluated in detail. Notwithstanding the

inability to review the proposed modeling task in detail,

two general comments can be made. These are:

1. EPA should not base the model analyses on an

arbitrary selection of data from a limited number of

monitoring wells as has been proposed (Ecology and

Environment, 1991, p. 4-16). An arbitrary selection of a

limited number of data points would bias the model results

and likely fail to identify other contamination.

2. If the model analyses are proposed to guide the

lead-screen auger drilling program, they should be completed

and the results analysed prior to implementing any field

investigation. As of May 7, 1991, approximately three weeks

before the scheduled start of the lead-screen auger

sampling, EPA was not aware of the status of the proposed

modeling effort. The model results will clearly be of no

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use to the field Investigation program if they are completed

subsequent to the lead-screen auger sampling.

C. The proposed seepage meter surveys are not likely to

provide a sufficient information base to "estimate the

direction, rate, And spatial variability of groundwater flux

between the aquifer and the St. Joseph River and Baugo Bay".

The Work Flan proposes that a total of four measurements

(two measurements in each of two separate locations) will be

sufficient to provide the necessary information for more

accurate input data or calibration data for model analyses.

Four measurements are too few to characterize the 5,000-foot

long stretch of the St. Joseph River between the Vistula

Avenue area and Baugo Bay. Notwithstanding the inadequacy

of four measurements to provide a reasonable representation

of spatial variability in groundwater flux, the Work Plan

also fails to consider the fact that groundwater flux varies

temporally. The rate and direction of groundwater flux is

dependent, in part, on the hydraulic gradient between the

aquifer and the St. Joseph River. , The hydraulic gradient

varies temporally in response to river stage changes and

aquifer groundwater elevations. The proposed Work Plan

gives no consideration to temporal variations in groundwater

flux. Consequently, the proposed seepage meter survey data

collection is of limited usefulness.

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D. The Work Plan proposes to identify the residential

wells on the north side of the St. Joseph River "that are at

the greatest risk of contamination because of their location

relative to the plume(s) and the groundwater flow

direction". This task is unnecessary and reflects a further

inadequate understanding of nydrogeologic conditions at the

site. Previous investigations of regional groundwater

conditions (Imbrigiotta and Martin, 1981) have indicated

that, north of the St. Joseph River, groundwater flow is

southerly and toward the St. Joseph River and, south of the

St. Joseph River, groundwater flow is northerly. The St.

Joseph river is a region of converging groundwater flow from

the north and south which is commonly referred to as a

groundwater discharge boundary. Consequently, there is no

reason to believe that any residential wells north of the

St. Joseph River are at risk from contamination found south

of the St. Joseph River.

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REFERENCES

Ecology and Environment, 1991. Work Plan for the Phase IIremedial investigation and phased feasibility study atthe Conrail site, Elkhart, Indiana, prepared for U.S.EPA, ARCS, Region V, Work Assignment Number 01*5677,Contract No. 68-W8-0086.

Ecology and Environment, 1990. Preliminary Evaluation ofPhase I RI results and interim remedial alternativesfor the Conrail/County Road 1 RI/FS, prepared for 0.S.EPA, ARCS, Region V, Work Assignment Number 01*5677,

,̂ Contract No. 68-W8-0086.

EIS Environmental Engineers, Inc., 1986. Soil drum samplingand analysis, Clifford P. Martin Estate, US 33 West,Elkhart, Indiana, Project Number 1291-01.

ENSR, 1988. Final Reports Hydrogeological investigation andhazard evaluation, Gemeinhardt site area, Elkhart,Indiana, prepared for Goodwin, Proctor 6 Hoar, DocumentNo. 3140-002-011.