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Action Memorandum U.S. EPA Region 5's remedy selection for the West Side Clear Creek area located adjacent to the Winston-Thomas WastewaterTreatment Plant in Bloomington, Indiana, and to support a time critical removal action at the West Side Clear Creek area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 April 3, 1996 FROM: Dan Hopkins, Senior Remedial Project Manager TO: William E. Muno, Director Superfund Division I. Purpose This Action Memorandum identifies the response action selected by the United StatesEnvironmental Protection Agency ("U. S. EPA") for the West Side of Clear Creek ("WSCC")area to abate an imminent and substantial endangerment to human health and the environment andto support a time-critical removal action to be performed for the clean-up of soils, sediments, andother materials contaminated with polychlorinated biphenyls ("PCBs") from a portion of propertyadjacent to the Winston Thomas Wastewater Treatment Plant (hereinafter "Winston Thomas").Winston Thomas is an abandoned waste water treatment plant, owned and previously operated by the City of Bloomington, Monroe County, Indiana. II. SITE CONDITIONS AND BACKGROUND Site Description 1. Removal site evaluation The WSCC area is a parcel of property, owned by the City of Bloomington, Indiana, and consisting of approximately 4 acres of wetland soils and sediments located adjacent to the southwestern portion of Winston Thomas. Approximately one acre of the WSCC area containsPCB contaminated soil, sediment, and other materials in concentrations as high as 1400 parts permillion ("ppm"). About two thirds of the remaining acreage in the WSCC area contains PCB contaminated soil, sediment, and other materials in concentrations between 10 ppm toapproximately 100 ppm. Beginning in approximately 1958, the Westinghouse Electric Corporation ("Westinghouse") used dielectric fluids containing PCBs at its electrical equipment manufacturing facility located at 300 North Curry Pike in Bloomington, Indiana. Westinghouse released waste fluids containing PCBs into sewers that discharged at the Winston Thomas Wastewater Treatment Plant until at least the mid 1970s. Consequently, sludge, water, and waste materials associated with many of theWinston Thomas process units (e.g. sludge digester tanks, sludge drying beds, tertiary lagoon,etc.) became contaminated with PCBs. The City of Bloomington Utilities ("CBU") reported that during the 1960s and 1970s, waterysewage sludge processed at the Winston Thomas Wastewater Treatment Plant ("plant") wastransported from the plant by truck and dumped or spread in the WSCC area. Based oninterviews conducted by the CBU of two former plant employees, sludge was placed as close tothe railroad tracks as possible and was spread to within 15 to 20 feet of Clear Creek on theeastern side of the WSCC area. The CBU reported that the northern limit of sludge placementwas an intermittent stream that crosses the WSCC area. The intermittent stream runs generally west to east toward Clear Creek and is located west of the northernmost of two secondary sediment basins at Winston Thomas. Both of the former plant employees recalled that a large pile of sludge (estimated to be 25 feet in diameter and as high as 8 feet) existed on the WSCC area during about 1975. The large sludge pile is no longer visible in the WSCC area. During the summer of 1996, acting on information provided by the CBU and concerning past sewage sludge disposal practices at Winston Thomas, Westinghouse collected approximately 257samples from the WSCC area for PCB analysis. Approximately 228 of the samples were analyzed using screening field kits. Westinghouse reported PCB concentrations on a wet weight basis (using the field kits) within a range of 5.8 ppm to 117 ppm. PCB concentrations below 5.8 ppm were shown simply as less than 5.8 ppm. Similarly, PCB concentrations reported to exceed 117ppm were shown as greater than 117 ppm. Westinghouse also provided laboratory analyses for approximately 29 samples. Four of the samples from locations that were screened with the testkits and showed PCB concentrations above 117 ppm, were also analyzed using laboratory protocol. The laboratory results for the four samples, indicated by the field kits to have PCB concentrations above 117 ppm, range from 100 ppm to 1400 ppm, on a dry weight basis. The analytical results for the Westinghouse sampling are shown in Figure 2. Based upon the analytical results of sampling, approximately 10,300 cubic yards of PCB contaminated soil, sediment, and other materials exist in the WSCC area. On October 8, 1996, consultants for U. S. EPA collected two samples of stream bank soil or sediments along Clear Creek. One of the samples was collected adjacent to the WSCC area. The second sample was collected downstream of the WSCC area. A third soil sample and a duplicateof the third sample were collected in the intermittent stream bed on the northern border of theWSCC area. Samples collected from the intermittent stream bed (upstream of the WSCC area)indicated the presence of several organic pesticide compounds (beta-BHC, Dieldrin, Chlordane) and Aroclor 1242 PCB at 0.02 ppm. The sample taken adjacent to the WSCC area showed the presence of several organic pesticide-related compounds (aldrin, 000, DDT, Endrin ketone, and Chlordane) and Aroclor 1242 at approximately 0.20 ppm. The downstream sample showed the presence of eleven organic pesticide-related compounds and Aroclor 1242 at 0.40 ppm. The locations and PCB results of the three samples (and duplicate sample) collected on October 8,1996, are shown in Figure 2. 2. Physical location The West Side Clear Creek area is a parcel of property, owned by the City of Bloomington,Indiana, and consisting of approximately 4 acres of wetland soils and sediments located adjacent to the southwestern portion of Winston Thomas. The WSCC area is situated north of Gordon Pike, immediately west of Clear Creek along the eastern boundary, and east of an abandoned CSX railroad track. A site map identifying the location of the WSCC area is shown in Figure 1. 3. Site characteristics The surface of the WSCC area is uneven and slopes generally in a northwest to southeast direction toward Clear Creek. Approximately one acre of the WSCC area contains PCB concentrations in excess of 100 ppm at or near the surface. PCB contaminated soil or sediment material in concentrations exceeding 100 ppm PCB exists within 50 feet of Clear Creek. TheWSCC area is a heavily vegetated, apparently depositional area, Iying within the 100 year floodplain of Clear Creek. Almost all of the WSCC area also lies inside the 10 year floodplain ofClear Creek. During February 1997, CBU representatives described the WSCC area as "underwater" and too marshy to fence. The western portion of the WSCC area, which includes the most highly contaminated acre of property, contains blackberry brambles and is crisscrossed with paths indicating that people or animals use or walk through the area. The WSCC area is unfenced. There are no physical barriers, but for Clear Creek to the east, that discourage trespassers from entering the area. The area is readily accessible from the abandoned railroad track which lies immediately west of the area. The site poses a threat to trespassers who may become exposed to high concentrations ofsurface level PCBs. Two residential developments are situated within 1000 feet of the WSCC area. The South Crestmobile home community is located as close as approximately 700 feet south of the WSCC area.Approximately 165 mobile homes are situated in the South Crest community. School age childrenwere seen departing a school bus at the South Crest community during a site visit conducted onOctober 15, 1996. Approximately thirty five homes are situated as close as 200 feet to the westof the WSCC area near South Rogers Street along Hayes Drive and West Rebecca Street. A parcel of property, approximately 3.5 acres in size, owned by the City of Bloomington, lies immediately north of the South Crest mobile home community across Gordon Pike. The 3.5 acre parcel is unfenced, grassy, and generally level, making it an attractive play area for neighboringschool-aged children. The northwestern boundary of the 3.5 acre parcel is separated from the WSCC area only by Clear Creek. The removal actions proposed in this Action Memorandum constitute the first removal at the WSCC area. 4. Release or threatened release into the environment of a hazardous substance, or pollutant or contaminant PCBs are hazardous substances as defined by section 101 (14) of CERCLA and are regulated pursuant to Part 761 of the Toxic Substances Control Act. PCBs were released at the WSCC area during the 1960s and 1970s when operators at the Winston Thomas Wastewater Treatment Plant dumped wet sewage sludge material there. As a result of the sludge dumping activities, approximately 10,300 cubic yards of PCB contaminated soil, sediment, and other materials exist in the WSCC area. This 10,300 cubic yard estimate is based upon sampling results obtained by Westinghouse and reported to U. S. EPA in September1996, through a report prepared by the Company's contractor. The WSCC area is uncontrolledand access to it is unrestricted. The PCB contamination in the WSCC area poses a threat topeople trespassing into the area who may come into direct contact with the high concentrations ofsurface level PCBs in soil and sediment. Wildlife living in the WSCC area are at risk of ingestingPCBs. Upper trophic level animals consuming contaminated prey from the WSCC area are also at risk of ingestion of PCBs through the food chain. Figure 2 of this Action Memorandum shows sample locations (represented as dots) and analytical results within the WSCC area. The analytical results are generally shown in six inch increments,with the surface level PCB concentration (in ppm) indicated as the first of several results shown in a column adjacent to the sample location. Most of the analytical results are screening level results and are shown as less than or greater than a threshold PCB concentration that is specific to the screening level test (immunoassay test) used. PCB concentrations shown in parentheses indicate laboratory analytical values. PCB concentrations shown as discrete values (and not within parentheses) indicate values within the range of the screening level test method. Confirmatory laboratory analyses, for a limited number of samples with screening level results indicated as greater than 1 17 ppm, demonstrate that concentrations of PCB exist in the WSCC area at much higher levels (as high as 1400 ppm) than indicated by the upper bound value (117 ppm) of the screening level test. The WSCC area lies within the 100 year floodplain of Clear Creek. In addition, most of the WSCC area lies within the 10 year floodplain of Clear Creek. 10 year and 100 year flood levelsf or Clear Creek, relative to the WSCC area, are shown in Figure 3. The City of Bloomington Utilities has reported that portions of the WSCC area flood and are marshy during seasonallyrainy periods. Storm water that percolates through the PCB contaminated soil in the WSCC area can dissolve and transport PCBs through subsurface soils before the water drains to Clear Creek. Floodwaters that directly contact high concentrations of PCB at the soil surface can carry dissolved PCBs to Clear Creek as the flood waters recede. In addition, faster moving flood waters can redistribute PCB contaminated soils toward Clear Creek and may cause the contaminated soils to be released into Clear Creek. Aquatic biota in Clear Creek are at risk as a result of exposure to uncontrolled releases of PCBs from the WSCC area to Clear Creek. Upper trophic ecological receptors (e.g. pisciverous wildlife and birds) are also at risk of ingestion of PCBs through thefood chain. During the month of November 1996, several species of fish and crayfish from Clear Creek were captured and analyzed for PCBs as part of an ecological sampling plan related to the Lemon LaneLandfill and Winston Thomas. PCBs were detected in crayfish and fish upstream and downstream of the WSCC area. Although the ecological risk assessment related to the sampling effort discussed above has not yet been completed, the analytical data demonstrates that fish and crayfish downstream of the WSCC area have bioaccumulated PCBs. PCBs that are released from the WSCC area could exacerbate the current level of PCB concentration in fish downstream. ThePCB concentrations found in stream bank samples collected in October 1996, indicate that PCBs from the WSCC area may have migrated to Clear Creek. However, because PCBs were also detected at similar levels in upstream sediments (as part of the November 1996 ecological sampling), the PCBs found in the stream bank of Clear Creek near the WSCC area do not conclusively demonstrate a release of PCBs from the WSCC area. The pesticide related compounds found in the stream bank of Clear Creek, as part of U. S. EPA'sOctober 8, 1996 sampling effort, exist at levels exceeding the "lowest effect level" for several of the pesticide-related compounds. The lowest effect level is that level of sediment contamination that can be tolerated by the majority of benthic organisms. The PCB sampling conducted byWestinghouse during the summer of 1996, did not include analyses for pesticide compounds. Because the existence of pesticide compounds in the WSCC area has not been determined, it is not known, whether organic pesticide compounds exist at harmful levels in the WSCC area. If it is later determined that organic pesticide compounds do exist in the WSCC area, at levels posing a threat to human health or the environment, then additional work may be necessary to abate threats posed by the pesticide compounds. 5. NPL status The WSCC area is neither listed on the National Priority List ("NPL") nor proposed for listing onthe NPL. No Hazard Ranking System rating has been performed for the WSCC area. The Agency for Toxic Substances and Disease Registry is not evaluating the WSCC area. The WSCC area has not been referred to the site assessment program. B. Other Actions to Date 1. Previous actions During a meeting in late September 1996, representatives from U.S. EPA, Westinghouse, and the CBU met to discuss the results of the Westinghouse sampling in the WSCC area and the need for a clean-up of the area. Westinghouse stated that a clean-up of the WSCC area would be addressed during the clean-up of the Winston Thomas site. Subsequently, Westinghouse and the CBU agreed to jointly undertake activities necessary to install a fence around the WSCC area inorder to restrict access. As of the date of this Action Memorandum, no fence has been installed and Westinghouse has not represented any intentions to remediate the WSCC area until 1998. During a regular meeting with Bloomington citizens on October 15, 1996, U. S. EPA presented preliminary sampling results related to the WSCC area. During the meeting, U. S. EPA discussed possible site control measures and requested information from the citizens concerning whether trespassers were seen on the WSCC area. 2. Current actions There are no current efforts being undertaken at the site. But for the actions proposed in this Action Memorandum, no further activities are expected. State and local Authorities' Roles 1. State and local actions to date Neither the State of Indiana, through the Indiana Department of Environmental Management, nor City or Monroe County Officials have requested that U. S. EPA provide assistance in responding to the PCB contamination at the WSCC area. Representatives of the Monroe County Health Department have indicated their support of U. S. EPA action to affect a clean-up of the WSCC area. The CBU sought approval from the Indiana Department of Natural Resources to constructa fence around the WSCC area, however, the CBU has not taken timely action to construct a fence. The extent of State and local government cooperation regarding the WSCC area has been in the review of analytical data and the provision of information about the WSCC area. 2. Potential for continued State/local response The City of Bloomington ("the City") is expected to participate in activities related to the WSCC area. The City can be expected to continue its participation in community relations activities. In addition, the City can be expected to analyze data and provide information concerning the site.The City may participate to a greater extent in clean-up efforts in the WSCC area, particularly if pesticide related contaminants are found to exist in the WSCC area at levels requiring additional removal action. The State of Indiana is expected to continue its participation in community relations activities and assessing risks posed by the PCB contamination at the WSCC area. The State is not expected to contribute funding for response actions. III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT AND STATUTORY AND REGULATORY AUTHORITIES A. Threats to Public Health of Welfare The existence of high levels of uncontrolled PCBs contaminating the WSCC area poses a direct contact threat to humans and wildlife. The western portion of the WSCC area, which includes the most highly contaminated acre of property, contains blackberry brambles and is crisscrossed with paths indicating that people or animals use the area. People who may use the site for such activities as berry picking or bird watching have potential exposure to surface soil PCB concentrations exceeding 1000 ppm (as high as 1400 ppm). In addition, neighborhood children from the South Crest mobile home community and residential areas along Rogers Street,immediately west of the WSCC area, who play on the site are potentially exposed to the high concentrations of PCBs in surface soils. The proximity of the WSCC area to residential areas, the adjacent City-owned parcel of grassy land (a suitable play area for children), and unrestricted access to the WSCC area, are factors that increase the potential for human exposure to high concentrations of PCBs in surface soil. By means of comparison, the PCB concentrations found in the WSCC area are at least 50 times greater that the level that U.S. EPA has determined to be protective (15 ppm) of a site maintenance worker at the Winston Thomas site. People who consume PCB contaminated fish from Clear Creek are exposed to PCBs that have been bioaccumulated from contaminated fish. Based on sampling conducted during November 1996, PCBs have bioaccumulated in crayfish and fish in Clear Creek. Releases of PCBs to ClearCreek that occur either by percolation of storm water through contaminated soil or that are released during flooding conditions increase the likelihood of PCB bioaccumulation in fish. PCB contaminated fish consumed by humans also increases the risk to humans from exposure to PCBs. Flood waters that directly contact high concentrations of PCB at the soil surface can carry dissolved PCBs or PCB laden soil and sediments to Clear Creek as the flood waters recede. In addition, faster moving flood waters can redistribute PCB contaminated soils toward Clear Creekand may cause the contaminated soils and sediments to be released into Clear Creek. Storm water that contacts PCBs in the WSCC area can carry dissolved PCBs through subsurface soils toward Clear Creek. The existence of high concentrations of surface level PCB within 50 feet of Clear Creek increases the likelihood that PCBs will be released to Clear Creek. Most of the highly contaminated portion of the WSCC area lies within the 10 year flood plain ofClear Creek. The occurrence of flooding conditions is unpredictable, however, the typical rainy periods in the Bloomington area occur during the spring and late fall seasons. By letter dated March 6, 1997, U.S. EPA Region 5 transmitted its clean-up criteria for PCBs at Winston Thomas to the parties of a 1985 Consent Decree concerning six Superfund sites in and near Bloomington, Indiana. U.S. EPA's clean-up criteria also addressed the West Side Clear Creek area and consisted of both risk based human health criteria and ecological criteria. In its March 6, 1997 letter U.S. EPA identified a fifteen (15) ppm total PCBs concentration limit for protection of human health and a one (1) ppm total PCBs concentration limit for its ecological criteria. B. Threats to the Environment Approximately one acre of the WSCC area contains PCB concentrations above 100 ppm (as high as 1400 ppm). In addition, approximately two thirds of the remaining property in the WSCC area contains PCB concentrations between approximately 10 ppm and 100 ppm, at or near the surface. In its March 6, 1997 letter, U.S. EPA determined that clean-up to one (1) ppm total PCBs in surface soils would adequately reduce risk to wildlife in the WSCC area. Clean-up to (one) 1ppm total PCBs in the WSCC area also adequately reduces risks to aquatic biota in Clear Creek,that can be affected by the release of PCBs from the WSCC area. The levels of PCBs found in the WSCC area are many times greater than the level determined by U. S. EPA to be adequate. The PCB concentrations found in the WSCC area pose a threat to wildlife living on the property. The PCB contamination also poses a threat to upper tropic level mammals that consume small mammals residing on the property. Sampling conducted during November 1996, demonstrates that PCBs have bioaccumulated in crayfish and fish in Clear Creek. Releases of PCBs from the WSCC area during storms and flooding conditions can exacerbate the existing PCB concentrations in fish, crayfish, and other aquatic biota. Unless removal actions are implemented, bioaccumulative effects to upper trophic level ecological receptors (such as piscivorous wildlife and birds) that bioaccumulate PCBs from consumption of PCB contaminated fish and crayfish are also more likely to increase. IV. ENDANGERMENT DETERMINATION Actual or threatened releases of hazardous substances from the WSCC area, if not addressed by implementing the response action selected in this Action Memorandum, may present an imminent and substantial endangerment to public health, or welfare, or the environment. PCBs are hazardous substances as defined by Section 101 (14) of CERCLA and are regulated pursuant to Part 761 of the Toxic Substances Control Act. U.S. EPA has determined that PCBs are probable human carcinogens. Epidemiological findings involving PCB exposures in humans suggest strong correlations between PCB exposures and impaired reproductive function, neurobehavioral and developmental defects in infants and children. The studies also indicate that PCB exposures are related to various adverse effects on cardiovascular, hepatic, immune musculoskeletal systems, such as diabetes, immunological risks, and increased cancer risk. Numerous animal studies have demonstrated that PCBs are carcinogenic in laboratory animals and produce liver, lung, and thyroid tumors. Bioaccumulated PCBs, once ingested and absorbed, appear to be more toxic and persistent in the body than commercial PCB mixtures, hence presenting a greater risk. PCB congeners of higher chlorine content are concentrated through the process of bioaccumulation. Because some toxic PCB congeners are preferentially retained in the body, bioaccumulated PCBs appear to be more toxic than commercial PCB mixtures. PCBs, especially in the concentrations found in the WSCC area can produce negative effects in ecological receptors, such as; causing reproductive failure, developmental abnormalities, and adverse systemic effects. Piscivorous wildlife and birds are at risk from exposure by ingesting PCB contaminated fish taken from Clear Creek. Also, because PCBs are bioaccumulative, intermittent trespassers exposed to PCBs in the WSCC area may suffer increased body burdens ofPCBs. Bioaccumulative effects may also be seen in upper trophic level ecological receptors from ingestion of contaminated prey. Because the WSCC area is located within the floodplain of Clear Creek, it is unlikely that the property will be developed for residential or commercial use. It is likely that the WSCC area will remain a threat to wildlife and to human trespassers until the site is remediated. In addition, because the WSCC area lies within the 10 year floodplain of Clear Creek, the likelihood of flooding in the WSCC area increases the probability of releases of PCBs to Clear Creek in the short term. Flood waters may transport PCBs from the area to Clear Creek, where aquatic vertebrates (including fish) and invertebrates are already contaminated with PCBs. Because much of the WSCC area is likely to be wet during seasonally rainy periods (spring andfall months), excavation activities may be hampered unless response actions are implemented on a timely basis. In addition to unnecessarily extending the clean-up, any flooding of disturbed areas increases the likelihood of significant releases of PCBs to Clear Creek while the removal activities are underway. The optimal time frame for conducting response actions is approximately late June through September. Therefore, it is critical that the proposed actions described in this Action Memorandum are undertaken timely to ensure the completion of the response actions during the late June through September time frame. V. PROPOSED ACTIONS AND ESTIMATED COSTS The removal action proposed to mitigate threats of hazardous substances consists of delineating the extent of PCB contamination, removing the PCB contaminated soils and sediment material from the surface and subsurface of the WSCC area, properly disposing of the contaminated soil and sediment material excavated, backfilling the excavated areas with clean soil, and revegetating the area. In light of the need to conduct this removal action during the most dry period of the year, removal of the PCB contaminated soil, sediment, and other materials and off-site disposal is the only feasible solution for mitigating threats. The specific requirements for accomplishing activities and estimated costs for the proposed actions are identified below: A. Proposed Actions 1. Proposed action description 1) Delineation of PCB and pesticide related compound contamination. During the summer of 1996, Westinghouse extensively sampled the WSCC area for PCBs.The analytical results of the samples collected in the WSCC, however, cannot be used to define the lateral extent of the PCB contamination to a one (1) ppm total PCB level. Accordingly, additional sampling shall be performed to define the lateral extent of PCB contamination to a 1 ppm PCB level. A ten foot by ten foot grid shall be placed around the perimeter of the area as defined by the previous samples in the WSCC area. The grid may be limited by the following features at the WSCC area; the abandoned railroad embankment to the west, Clear Creek to the east, Gordon Pike to the south and the intermittent stream to the north. Sampling and analysis shall be conducted to demonstrate that the PCB contamination within the gridded area is below one (1) ppm PCB. Grid dimensions other than ten foot by ten foot squares may be used provided that prior approval is obtained from U.S. EPA. Regardless of the geometric shape of any alternative grid or grid system proposed the area represented by each individual grid should be no greater than 100 square feet. 2) Removal of PCB contaminated material All PCB contaminated soil and sediment within the "ridded area and above a concentration of one (1) ppm total PCBs shall be removed from the WSCC area, unless:1) the depth of excavation for any gridded area exceeds eighteen inches below the surfaceof the grid; and 2) the PCB concentration of the material remaining in the grid, as determined by post excavation sampling, is no greater than fifteen (15) parts per million. 3) Initial Grid Sampling Samples that are required for this action shall adhere to the following requirements: 1) samples must be taken from the center of the grid. Each sample must be taken from a depth of zero (0) to six (6) inches of soil or sediment material within an individual grid, 2) samples analyzed to demonstrate compliance with a one (1) ppm PCB concentration shall not be compos ted with samples from other individual grids. 4) Post Excavation sampling 1) A separate grid shall be prepared for post excavation sampling. The post excavation grid system must consist of individual grids measuring twenty feet by twenty feet over the entire area excavated. Grid dimensions other than twenty feet by twenty feet squares may be used provided that prior approval is obtained from U. S. EPA. Regardless of the geometric shape of any alternative grid or grid system proposed, the area represented by each individual grid should be no greater than 400 square feet. A grid system consisting of approximately 400 individual grids is estimated for the purposes of post-excavation sampling. 2) samples must be taken from the center of the grid. Each sample must be taken from a depth of zero (0) to six (6) inches of soil or sediment material within an individual grid, 3) samples analyzed to demonstrate compliance with a one (1) ppm concentration must not be composited with samples from other individual grids, 4) samples analyzed to demonstrate compliance with a fifteen (15) ppm concentration may be composited from as many as five individual grids. Any compositing scheme should be approved in advance by U.S. EPA prior to sampling. If compositing of such samples occurs, then a second decision criteria should be applied to ensure that the 15 ppm concentration is not exceeded for any individual grid. For example, if 5 individual grid samples are composited, then the decision criteria will be equal to 15 ppm divided by the number of individual grid samples composited (five). The decision criteria is then 3 ppm For this example, if a concentration of greater than 3 ppm is determined for the composited sample, the neither a reanalysis of each individual grid sample should be performed to determine the grid or grids containing greater than 15 ppm, or excavation of all five of the individual grids represented by the composite sample should occur. If a composite sampling is to be used, then prior to compositing the individual samples, portions of the samples from the individual grids shall be retained for subsequent analysis, pending the analytical results of the composite sample. In no case, may either the composite sample or the individual samples be held for analysis beyond the appropriate holding times for the samples. 5) samples of soil and sediment material shall be analyzed according to U. S. EPA method SW-846 Method 8081 and in accordance with the procedures and protocols previously approved as part of the U.S. EPA approved Quality Assurance/Quality Control Plan developed by Westinghouse for the sampling and analysis of Superfund Sites in Bloomington. 5) Disposal of PCB Contaminated Materials PCB Contaminated soil and sediment material excavated from the WSCC area containing concentrations greater than fifty (50) ppm PCBs must be disposed of in accordance with the requirements of Toxic Substances Control Act ("TSCA"). PCB contaminated soils and sediment material containing less than fifty (50) ppm PCBs but greater than one (1)ppm PCBs must be properly disposed in a licensed disposal facility permitted to accept the PCB contaminated materials. Compliance with all laws, regulations, and any permit requirements imposed by the State, in which the facility receiving the PCB contaminated materials, is located must be ensured. In addition, compliance with U.S. EPA's Offsite Disposal Rule at 40 CFR 300.440 should be ensured. 6) Backfilling and grading of excavated area Following the completion of excavation activities, backfill should be placed in the excavated areas in the WSCC area. The backfill soil shall be graded to a level consistent with the elevation of the property prior to excavation. Backfill must consist of clean soil containing not greater than one (1) ppm PCBs. 7) Revegetation of the WSCC After backfilling activities have been completed, the backfilled areas of the WSCC area shall be seeded with a fast growing grass such as winter wheat or rye grass in order to minimize the possibility of erosion in the excavated areas. Excavation of the PCB contaminated soil, sediment, and other materials, and disposal of the PCB contaminated materials will mitigate the public health threat posed by direct human contact. Excavation of the PCB contaminated soil, sediment, and other materials will mitigate the threat posed by direct contact to wildlife and the threats posed to aquatic biota and pisciverous wildlife posed by the release of PCBs to Clear Creek. Further sampling to determine the extent of soil contamination and to determine the existence of pesticide-related organic compounds is expected to be conducted prior to the beginning of the summer of 1997. U.S. EPA will perform confirmatory sampling of PCBs and will perform sampling for pesticide-related organic compounds. Because PCB contaminated soil, sediment, and other materials lie within the 10 year floodplain, excavation activities may be hampered by flooding conditions. No deed restrictions are anticipated to prevent future activities at the site. No post-removal controls are planned or expected. 2. Contribution to remedial performance The removal actions proposed in this Action Memorandum will mitigate the threats, posed by the site, as discussed in sections III A and III B above. If the removal actions proposed in this Action Memorandum are completed, then no further action will be required at the WSCC area. 3. Description of alternative technologies Because the removal actions described in this Action Memorandum are time-critical, land disposal was selected as the most expeditious means of disposing of the PCB contaminated soil, sediments,and other materials at the WSCC area. 4. Engineering Evaluation/Cost Analysis ("EE/CA") Because the removal actions proposed in this Action Memorandum are time-critical, an EE/CAwill not be performed. 5. Applicable or relevant and appropriate requirements ("ARARs") Federal the Toxic Substances Control Act ("TSCA") State State ARARs will be requested from the Indiana Department of EnvironmentalManagement 6. Proposed Schedule The following milestones are considered to be necessary critical path items related to the activities for the clean-up of the WSCC area. The milestones do not include every activity necessary for completing the clean-up, The following activities, if undertaken soon will allow for the completion of the WSCC area clean-up during calendar year 1997. The timeframe shown with each milestones activity represents the projected duration of each milestone. Contractor Procurement ..................30 days Work Plan Preparation .......this activity should be completed concurrently with procuring a contractor U.S. EPA Approval of Work Plan ..............10 days Mobilization for Sampling ...........................7 days Placement of Grid/Sampling .......................15 days Excavation Activities ................................2.5 months Post-Excavation Sampling.............................7 days (following the conclusion of excavation activities) Backfilling, Grading and Seeding ................14 days (following post-excavation sampling) B. Estimated Costs Estimates of the costs to complete the actions proposed in this action memorandum are provided below. 1 ) Sampling costs The costs associated with this activity include costs for the preparation and placement of a sampling grid, sampling and analysis costs to delineate the limit of PCB contamination to 1 ppm, and to perform post excavation sampling. Based on an estimate of the placement of approximately 500 grid squares, the placement of the perimeter grid system is estimated to take two individuals approximately three days to complete. The estimated cost for this effort is $2,500. The preparation of the post excavation grid is expected to take approximately four days and cost approximately $3,000. In order to collect approximately 550 samples (including QA/QC samples) for the initial perimeter delineation sampling, two teams of samplers are estimated to need approximately two weeks to collect, label, and ship samples for analysis. Based on an approximate cost of $60-$80 per sample, the analytical costs are expected to be approximately $33,000 to $44,000. The perimeter grid sampling is expected to be accomplished using two three person crews for approximately ten days of sampling effort (8 to 10 hours per day). Based on an average cost of $60 per hour per person, the manpower costs related to the perimeter sampling is estimated to be between approximately$28,800 to $36,000. Post excavation sampling can be expected to consist of more than one sample per individual grid, in order to demonstrate that the concentration of PCBs within the grid is acceptable. On the basis of two samples per grid, approximately 880 samples may be necessary. Sampling costs for post excavation sampling are estimated to be approximately $52,800 to $70,400. The cost of shipping 1,430samples is estimated to be approximately $4,000. The post excavation sampling is expected to be accomplished intermittently during the excavation activities. Based on using a three person crew for a total of ten to twelve days (ten hour days) at $60 per hour, the estimated cost of labor necessary to complete the post excavation sampling is between $18,000 to $21,600. 2) Disposal Costs Based on the preliminary sampling results provided by Westinghouse, U. S. EPA has estimated that approximately 10,300 cubic yards of PCB contaminated soil and sediment should be excavated from the WSCC area. Estimated costs for disposal are based on land filling the contaminated materials. Approximately 3,600 cubic yards of the PCB contaminated material is expected to be disposed at a licensedTSCA landfill facility. Approximately 6,700 cubic yards could be disposed at a special waste facility in Indiana. The range of costs for disposal to a TSCA landfill is estimated to be approximately $175 to $200 per ton. Disposal costs for special wastes are estimated to cost approximately $50 per ton. Based on disposal of 3,600 cubic yards of soil (3,300 pounds per cubic yard ), disposal to a TSCA landfill is estimated to cost approximately $1,039,500 to $1,188,000. Based on disposal of 6,700 cubic yardsof soil (3,300 pounds per cubic yard), disposal to a special waste landfill is estimated to cost approximately $552,750. Total disposal costs are estimated to range from $1.59 million to $1.74 million. The excavation activities are estimated to take approximately 2.5 months. Based on the use of one backhoe (one and one-half cubic yard bucket), one D-4bulldozer, and one five cubic yard, rubber tired loader, and operators donning hazmat protective equipment, the estimated costs per month of excavation activities are approximately $150,000 per month. The total equipment and operator costs are estimated to be $375,000 for the project. 3) Cost of Backfill Material Approximately 10,300 cubic yards of backfill will be required, based on the estimates previously made for the amount of material to be excavated from the WSCC area. Cost estimates are based on $6 per cubic yard of clay and $7.50 percubic yard of topsoil (assuming six inches of backfilled topsoil across the excavated area). The cost of backfill, based on the above mentioned parameters, is estimated to be approximately $66,000. 4) Revegetation Costs Revegetation costs are estimated at approximately $4,500 per acre. Based on these cost estimates, the cost to revegetate 4 acres would be approximately $18,000. 5) Total Costs Summing the cost estimates for the items identified above yields an overall project cost estimate of between $2,193,350 to $2,381,250. VI. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN Delayed action will increase the potential contact by trespassers to high concentrations of PCBs contained in surface level soils and sediment threatening public health. Because PCBs are bioaccumulative, intermittent trespassers exposed to PCBs in the WSCC area may suffer increased body burdens of PCBs. Delayed action also increases the potential for PCB contaminated water and sediments to be released into the waters of Clear Creek,threatening the environment and exacerbating the levels of PCBs in aquatic biota (including fish) in Clear Creek. Bioaccumulative effects may also be seen in upper trophic level ecological receptors from ingestion of contaminated prey. VII. OUTSTANDING POLICY ISSUES None VIII. ENFORCEMENT The Potentially Responsible Parties ("PRPs") for this action are Westinghouse and theCity of Bloomington, Indiana. Westinghouse is known to be the generator of the PCBs. The PCBs found in the WSCC area originated from releases of PCBs at Westinghouse's electrical equipment plant in Bloomington to the Winston-Thomas Wastewater Treatment Plant. The City of Bloomington, through its Winston-Thomas employees, placed PCB containing sludges in the WSCC area during the 1960s and 1970s. In addition, the City of Bloomington is the owner of the WSCC area. Westinghouse has indicated a willingness to perform clean-up activities at the WSCC area, however, it has informed U. S. EPA that it does not intend to conduct any removal activities at the WSCC area until 1998. IX. RECOMMENDATION This decision document represents the selected removal action for the West Side Clear Creek area adjacent to the Winston Thomas Superfund Site in Bloomington Indiana. This decision document has been developed in accordance with CERCLA, as amended, and is not inconsistent with the NCP. This decision is based on the Administrative Record this site. Conditions at the site meet the NCP section 300.415(b)(2) criteria for a removal. Although no funding has been specifically budgeted for the removal actions proposed for the WSCC area, U.S. EPA intends to consider all options available to it to pursue the removal actions proposed in this Action Memorandum. Because the removal actions described must be undertaken in a timely manner to mitigate the threats posed to human health and the environment, I recommend your approval of the removal actions proposed in this Action Memorandum.

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