INAAP corrective measures study for Jenny Lind pond site 25 report Nov 2002

Description:	The final report of corrective measures study for Jenny Lind pond site 25 at Indiana Army Ammunition Plant prepared for U.S. Army Corps of Engineers in November 2002.The United States federal government began acquiring land in Charlestown, Indiana in 1940 to build a smokeless powder ordnance plant to supply the US military during World War II. Indiana Ordnance Works (IOW) Plant 1 and Hoosier Ordnance Plant (HOP) began production in 1941. In 1944, IOW Plant 2 construction began. On 30 Nov 1945 at the end of WWII, the three plants were combined and renamed Indiana Arsenal. Between 1 Nov 1961 and 1 Aug 1963, the plant was designated Indiana Ordnance Plant. After this time, it became Indiana Army Ammunition Plant (INAAP). Production of ordnance continued at the plant until 1992. After that time, the land and facilities were leased to private industry. A large portion of the land became Charlestown State Park. In October 2016, all the land and facilities were officially sold by the government. This item is part of a larger collection of items from INAAP that are kept at Charlestown Library. FINAL REPORTCORRECTIVE MEASURES STUDYFOR JENNY LIND POND – SITE 25INDIANA ARMY AMMUNITION PLANTPrepared forU.S. Army Corps of EngineersLouisville DistrictNovember 2002Prepared byURS 12120 Shamrock Plaza, Suite 300Omaha, Nebraska 68154TABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA iExecutive Summary ..........................................................................................................................ES-1Section 1 Project Background....................................................................................................... 1-11.1 Purpose and Scope of Corrective Measures Study .................................. 1-11.2 Environmental Status ............................................................................... 1-11.3 Site History .............................................................................................. 1-2Section 2 Corrective Measure Objectives..................................................................................... 2-12.1 RCRA Corrective Action Goals............................................................... 2-12.2 Development of Media Cleanup Standards ............................................. 2-12.2.1 Current and Future Land Use....................................................... 2-22.2.2 Human Health Risk-Based Cleanup Levels................................. 2-22.2.3 Ecological Risk-Based Cleanup Levels ....................................... 2-32.2.3.1 Approach....................................................................... 2-32.2.3.2 Media and Chemicals of Potential Concern.................. 2-42.2.3.3 Not-To-Exceed Media Cleanup Levels ........................ 2-42.2.3.4 Residual Ecological Exposures..................................... 2-52.2.3.5 Corrective Measure Footprint ....................................... 2-52.2.4 Proposed Media Cleanup Standards ............................................ 2-52.3 Proposed Corrective Measure Objectives................................................ 2-5Section 3 Alternative Development ............................................................................................... 3-13.1 Corrective Measure Approach ................................................................. 3-13.1.1 Range of Potential Corrective Measures...................................... 3-13.1.2 Site Characteristics that Affect Design and Construction ofa Corrective Measure ................................................................... 3-13.1.2.1 Site Environment .......................................................... 3-13.1.2.2 Protection of Endangered Species ................................ 3-23.1.2.3 Areas and Volumes of Contaminated Media................ 3-33.1.2.4 Downstream Hotspot .................................................... 3-33.1.2.5 Waste Characterization ................................................. 3-43.1.2.6 Condition of Existing Dam ........................................... 3-53.2 Identification and Screening of Potential Technologies .......................... 3-53.2.1 Initial Screening of Technologies and Process Options .............. 3-53.2.2 Final Screening of Technologies and Process Options................ 3-53.2.2.1 Screening Criteria for Process Options......................... 3-53.2.2.2 Summary of Screening Results..................................... 3-63.3 Identification of Corrective Measure Alternatives .................................. 3-73.3.1 CMA-1, No Action ...................................................................... 3-73.3.2 CMA-2, Dam Modification with Institutional Controls andMonitoring ................................................................................... 3-73.3.2.1 Description of CMA-2 .................................................. 3-73.3.2.2 Effectiveness-of CMA-2............................................... 3-93.3.2.3 Implementability-of CMA-2....................................... 3-103.3.3 CMA-3, Soil Cover and Dam Modification .............................. 3-103.3.3.1 Description of CMA-3 ................................................ 3-10TABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA ii3.3.3.2 Effectiveness-of CMA-3............................................. 3-123.3.3.3 Implementability-of CMA-3....................................... 3-133.3.4 CMA-4, Removal and Disposal................................................. 3-133.3.4.1 Description of CMA-4 ................................................ 3-133.3.4.2 Effectiveness-of CMA-4............................................. 3-143.3.4.3 Implementability-of CMA-4....................................... 3-153.3.5 CMA-5, In Situ Treatment and Dam Modification.................... 3-153.3.5.1 Description of CMA-5 ................................................ 3-153.3.5.2 Effectiveness-of CMA-5............................................. 3-173.3.5.3 Implementability-of CMA-5....................................... 3-18Section 4 Feasibility Level Cost Estimates................................................................................... 4-1Section 5 Detailed Screening of Alternatives............................................................................... 5-15.1 Detailed Screening Criteria...................................................................... 5-15.1.1 Threshold Criteria ........................................................................ 5-15.1.2 Balancing Criteria ........................................................................ 5-15.2 Detailed Screening Evaluation................................................................. 5-25.3 Comparison of Alternatives ..................................................................... 5-25.3.1 Threshold Criteria ........................................................................ 5-35.3.2 Balancing Criteria ........................................................................ 5-3Section 6 Proposed Corrective Measure Alternative................................................................... 6-16.1 Summary of Proposed Corrective Measure Alternative .......................... 6-16.2 Data Gaps and Uncertainties.................................................................... 6-2Section 7 References..................................................................................................................... 7-1TABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA iiiList of TablesTable 2-1 Summary of Chemicals of Potential Ecological ConcernTable 3-1 Comparison of Maximum Chemical Detections to TCLP Regulatory LimitsUsing “20 Times” RuleTable 3-2 Initial Screening of Remedial Technologies and Process OptionsTable 3-3 Final Screening of Remedial Technologies and Process OptionsTable 4-1 Cost Estimate Summary – CMA 2: Dam Modification with ICMTable 4-2 Cost Estimate Summary – CMA 3: Soil Cover and Dam Modificationwith ICMTable 4-3 Cost Estimate Summary – CMA 4: Removal and DisposalTable 4-4 Cost Estimate Summary – CMA 5: In Situ Treatment and Dam ModificationTable 4-5 Cost Sub-Element – Dam ModificationTable 4-6 Cost Sub-Element – MonitoringTable 4-7 Cost Sub-Element – Channel ConstructionTable 4-8 Cost Sub-Element – Vegetated Soil CoverTable 4-9 Cost Sub-Element – Access RoadTable 4-10 Cost Sub-Element – Removal and DisposalTable 4-11 Cost Sub-Element –Treatability StudyTable 4-12 Cost Sub-Element – In Situ TreatmentTable 4-13 Cost Sub-Element – Channel StabilizationTable 4-14 Cost Sub-Element – Soil Sampling to Monitor In Situ TreatmentTable 4-15 Cost Sub-Element – Hotspot RemovalTable 4-16 Comparison of Total Cost of Remedial AlternativesTable 4-17 Sensitivity Analysis SummaryTable 5-1 Evaluation of Corrective Measure AlternativesTable 5-2 Comparison of Residual Exposure Levels Before and After CorrectiveMeasure ImplementationTABLE OF CONTENTSQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA ivList of FiguresFigure 1-1 Site Location MapFigure 1-2 Site PlanFigure 2-1 Decision Diagram for Development of Corrective Measure ObjectivesFigure 2-2 Site Plan Showing Areas of Contaminated MediaFigure 3-1 Conceptual Site Plan of CMA-2 (Dam Modification with InstitutionalControls and Monitoring)Figure 3-2 Conceptual Site Plan of CMA-3 (Soil Cover and Dam Modification)Figure 3-3 Conceptual Site Plan of CMA-4 (Removal and Disposal)Figure 3-4 Conceptual Site Plan of CMA-5 (In Situ Treatment and Dam Modification)List of AttachmentsAttachment 1 INAAP Dam Rehabilitation Concept ReportList of AppendixesAppendix A Ecological Risk Characterization (Included on CD-ROM)Appendix B Ecological Risk Calculations (Included on CD-ROM)Note: Information contained in the Appendices is included in CD-ROM format. The CD-ROMmay be found at the back of this binder.EXECUTIVE SUMMARY Jenny Lind Pond CMSQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA ES-1The following Corrective Measures Study (CMS) is based on data collected during the Phase IRemedial Investigation (RI) (Woodward-Clyde, 1998) and the Phase II Resource Conservationand Recovery Act (RCRA) Facility Investigation (RFI) (URS, 2001) completed at Jenny LindPond (Site 25) at the Indiana Army Ammunition Plant (INAAP).INAAP Background. INAAP currently encompasses approximately 9,790 acres in south-centralClark County, Indiana (Figure 1-1). Its southern boundary is approximately 6 miles north ofJeffersonville, Indiana and 10 miles from the Louisville, Kentucky metropolitan area that lies tothe south across the Ohio River. INAAP was a Government-Owned, Contractor-Operated(GOCO) military industrial installation that operated from 1941 to 1998. INAAP is inactive, andthe Army intends to transfer the property to a Local Reuse Authority (LRA) for commercialdevelopment or to the State of Indiana for inclusion in the state park system.Jenny Lind Pond Background. Jenny Lind Pond, a former retention basin with a water surfacearea covering approximately 21 acres, is situated in the east-central portion of INAAP, within theJenny Lind Run, approximately 1,600 feet west of the Ohio River. The main branch of the pondoccupied approximately 8.9 acres; this measurement was previously reported as the size of theentire site in earlier reports. The retention basin was formed by the construction of an earthendam at the southeastern end of the pond with a primary spillway structure located near thesouthern end of the dam. Jenny Lind Pond was dammed in the late 1950s to hold industrialwastewater for possible treatment before discharge to the Ohio River (USATHAMA 1980). Theearthen dam failed in the spring of 1997 as a result of a 10-inch rain event and the subsequentflooding of the Ohio River. The failure occurred on the south end of the dam at the primaryspillway. The pond drained and is presently empty with small streams running through theformer basin floor.Scope of CMS. The scope of the CMS for Jenny Lind Pond includes:· Identifying remedial alternatives that are tailored to meet the corrective measureobjectives outlined in the Phase II RFI (URS, 2001) and further defined in this report· Developing remedial technologies and process options considered to be suitable for thesite and contaminant characteristics· Screening the corrective measure alternatives using the following criteria:– “Threshold criteria”: Protective of human health and the environment; attain mediacleanup standards; control source(s) of release; and comply with applicable wastemanagement standards– “Balancing criteria”: Long-term reliability and effectiveness; reduction of toxicity,mobility, or volume (TMV) of waste; short-term effectiveness; implementability; andcost· Recommending a proposed corrective measureThis CMS is “focused” in that only five or fewer corrective measure alternatives are evaluated indetail.EXECUTIVE SUMMARY Jenny Lind Pond CMSQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA ES-2Human Health and Ecological Risk Assessments. Development of media cleanup levels specificto human health risk reduction is not warranted based on the results of the human health riskassessment. Carcinogenic risks totaled less than 1x10-5 and summed hazard indices were lessthan 1.0.The development of media cleanup levels specific to ecological risk reductions included thepossibility that the floodplain within Site 25 may become covered with water and revert to apond environment. The ecological risk analysis is based on maximizing the reduction ofpotential exposure in order to protect receptors while minimizing the extent of any correctiveaction to conserve resources. The ecological risk-based cleanup levels will reduce residualchemical of potential ecological concern (COPEC) exposures to levels below a threshold ofconcern. The intent of the cleanup levels developed in this CMS is to protect populations, ratherthan an individual organism, with the notable exception of the gray bat, a listed endangeredspecies.Corrective Measure Objectives. The proposed corrective measure objectives for Site 25 arefocused on reduction of potential risk to ecological receptors. The proposed corrective measureobjectives are:· Reduce potential ecological exposures to all COPECs in the upper 2 feet of soil andsediment within the Jenny Lind Pond site. Based on conservative mathematicalmodeling, significant exposure reduction with commensurate reduction in risk potentialscan be achieved by addressing three indicator chemicals as representative of all COPECsevaluated for the sites. The indicator chemicals and their respective not-to-exceed mediacleanup levels are:– Mercury, <3 mg/kg– Total PCBs, <0.1 mg/kg– Methoxyclor, <0.1 mg/kg· Control the potential migration of all COPECs to off-site receptors that may result fromthe transport of contaminated soil and sediment.Alternatives Considered. The following five Corrective Measures Alternatives (CMAs) wereevaluated:· CMA-1: No Action· CMA-2: Dam Modification with Institutional Controls and Monitoring· CMA-3: Soil Cover and Dam Modification· CMA-4: Removal and Disposal· CMA-5: In Situ Treatment and Dam ModificationRecommended Corrective Measure Alternative. CMA-3 (Soil Cover and Dam Modification) isrecommended as the preferred alternative. The primary elements of CMA-3 include:EXECUTIVE SUMMARY Jenny Lind Pond CMSQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA ES-3· Selectively clear and regrade the site to develop contours suitable for runoff andstormwater control.· Install a liner and erosion protection along the drainage channel through the basin, nearits current alignment.· Modify the existing dam to stabilize the dam breach.· Construct a 2-foot-thick vegetated soil cover over the areas with contaminated soils andsediments.· Complete a Removal Action, as necessary, to address the hotspot downstream of the dam.· Restrict land use on the site, complete a baseline site inventory, and annually monitor thesite.CMA-3 has an estimated present worth cost of about $5.3 million. CMA-3 was selected for thefollowing reasons:· It is protective of human health and the environment (including ecological receptors)· It is equally or more cost-effective than other alternatives that would provide a similardegree of protection· It uses proven and reliable technology that is easily and readily implementable.CMA-3 will require that the Army retain long-term liability for management of contaminatedmedia left in place, including site inspection, maintenance, and repair. CMA-4 would eliminatethe need for long term management, but at a higher cost estimated to be over $30 million.SECTIONONE BackgroundQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 1-1This report is the focused Corrective Measures Study (CMS) for Jenny Lind Pond (Site 25)located at the Indiana Army Ammunition Plant (INAAP).1.1 PURPOSE AND SCOPE OF CORRECTIVE MEASURES STUDYA Phase I Remedial Investigation (RI) (Woodward-Clyde, 1998) and a Phase II ResourceConservation and Recovery Act (RCRA) Facility Investigation (RFI) (URS, 2001) have beencompleted to characterize the physical and chemical conditions at Jenny Lind Pond. In addition,an Incident Report for the Jenny Lind Pond Dam Failure (ICI Americas, Inc., 1997) wascompleted after the dam failed; the results of this investigation was included in the Phase II RFIreport. The purpose of this focused CMS is to identify and evaluate potential remedialalternatives for Jenny Lind Pond.INAAP has an Installation Action Plan (IAP) that addresses all Environmental RestorationProgram (ERP) sites at the facility. The IAP includes a brief description of a preliminary siteremedy, an estimated cost to complete, and a schedule for completion. Updates to the IAP arecompleted annually.This CMS is based on data collected during the Phase I RI and Phase II RFI at Jenny Lind Pond.The scope of the CMS includes:· Identifying remedial alternatives that are tailored to meet the corrective measureobjectives outlined in the Phase II RFI (URS, 2001) and further defined in this report· Developing remedial technologies and process options considered to be suitable for thesite and contaminant characteristics· Screening the corrective measure alternatives using the following criteria:– “Threshold criteria”: Protective of human health and the environment; attain mediacleanup standards; control source(s) of release; and comply with applicable wastemanagement standards– “Balancing criteria”: Long-term reliability and effectiveness; reduction of toxicity,mobility, or volume (TMV) of waste; short-term effectiveness; implementability; andcost· Recommending a proposed corrective measureThis CMS is “focused” in that only five or fewer corrective measure alternatives are evaluated indetail.1.2 ENVIRONMENTAL STATUSEnvironmental investigations and remediation at INAAP are being completed under the DoD’sDefense Environmental Restoration Program (DERP). The legal foundation for the DERP is theComprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)and the Superfund Amendments and Reauthorization Act of 1986 (SARA). Specifically,SECTIONONE BackgroundQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 1-2CERCLA Section 120 applies to Federal Facilities, and SARA Section 211 establishes theDERP. The objectives of DERP are to identify and investigate sites with past hazardous wastedisposal or releases and to address them.INAAP formerly had a RCRA permit for open burning of obsolete or spent explosives, and willbe receiving a RCRA post-closure care permit for long-term monitoring of a landfill.Consequently, the Indiana Department of Environmental Management (IDEM) is the leadagency providing oversight for all corrective measure activities at INAAP in accordance with theRCRA corrective action program. IDEM has developed the Risk Integrated System of Closure(RISC) Technical Resource Guidance Document (February 15, 2001) to serve as a flexibleframework for closure of sites under the RCRA corrective action program. The RISC guidance,RCRA corrective action program, and CERCLA remedial program are generally consistent witheach other and should result in similar environmental solutions.1.3 SITE HISTORYINAAP currently encompasses approximately 9,790 acres in south-central Clark County, Indiana(Figure 1-1). Its southern boundary is approximately 6 miles north of Jeffersonville, Indiana and10 miles from the Louisville, Kentucky metropolitan area that lies to the south across the OhioRiver. INAAP was a Government-Owned, Contractor-Operated (GOCO) military industrialinstallation that operated from 1941 to 1998. INAAP is inactive, and the Army intends totransfer the property to a Local Reuse Authority (LRA) for commercial development or to theState of Indiana for inclusion in the state park system.Jenny Lind Pond, a former retention basin with a water surface area covering approximately21 acres, is situated in the east-central portion of INAAP, within the Jenny Lind Run,approximately 1,600 feet west of the Ohio River. The main branch of the pond occupiedapproximately 8.9 acres; this measurement was previously reported as the size of the entire sitein earlier reports. The retention basin was formed by the construction of an earthen dam at thesoutheastern end of the pond with a primary spillway structure located near the southern end ofthe dam. Jenny Lind Pond was dammed in the late 1950s to hold industrial wastewater forpossible treatment before discharge to the Ohio River (USATHAMA 1980). The earthen damfailed in the spring of 1997 as a result of a 10-inch rain event and the subsequent flooding of theOhio River. The failure occurred on the south end of the dam at the primary spillway. The ponddrained and is presently empty with small streams running through the former basin floor.The Jenny Lind Pond site includes the following:· The former retention basin· The earthen dam· The downstream drainage leading to the Ohio RiverThe total site area, shown on Figure 1-2, covers approximately 26 acres.A detailed site history and discussion of previous site investigations is presented in the Phase IIRFI report (URS, 2001).SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 2-1It has already been determined that Jenny Lind Pond does not pose imminent threats to humanhealth and the environment. Therefore, interim action to stabilize the site is not necessary orappropriate. Using highly conservative assumptions, the following two preliminary correctivemeasure objectives were identified during the Phase II RFI to address environmentalcontamination at the sites:· Exposures to chemicals of concern along several ecological pathways exceed establishedbenchmarks. The primary pathways include exposures to chemicals of concern insediment. An objective of the corrective measure should be to reduce potentialecological exposures to acceptable levels through removal, stabilization, treatment,and/or capping.· Carcinogenic and non-carcinogenic risks to humans meet IDEM and EPA acceptablelevels. Carcinogenic risks totaled less than 1x10-5 and summed hazard indices were lessthan 1.0. Based on this, the CMS does not need to address human health exposures atthis site.· Potential corrective measure alternatives at Jenny Lind Pond should be evaluated inconjunction with the other sites along the Jenny Lind Run drainage basin.These preliminary corrective measure objectives are further delineated in this section to developproposed final corrective measure objectives for Jenny Lind Pond.2.1 RCRA CORRECTIVE ACTION GOALSFinal remedies implemented under RCRA are expected to achieve the following “thresholdcriteria”:· Protect human health and the environment· Attain media cleanup standards as appropriate for the current and reasonably anticipatedfuture land uses· Address the source(s) of releases to reduce or eliminate, to the extent practicable, furtherreleases of hazardous constituents that may pose a significant threat to human health orthe environment· Comply with applicable standards for waste management during the corrective measureThe EPA has developed these “threshold criteria” as an initial screening tool for potentialremedies. Remedies that meet the “threshold criteria” are further screened using “balancingcriteria” to identify a final remedy that provides an appropriate combination of attributes.2.2 DEVELOPMENT OF MEDIA CLEANUP STANDARDSOf the four “threshold criteria” listed above, attainment of media cleanup standards requires thedevelopment of standards that are site-specific and media-specific. The term media cleanupstandards typically refers to broad cleanup objectives and often includes:SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 2-2· Media cleanup levels: Media-specific concentrations of hazardous constituentsdeveloped using available regulatory risk-based standards (e.g., maximum contaminantlevels or state standards for drinking water) or site-specific risk assessments.· Point(s) of compliance: Location(s) at which the media cleanup levels are achieved.· Compliance time frame: Time period and schedule according to which the correctivemeasure will be implemented.Site-specific human health and ecological risk assessments have been completed for Jenny LindPond. These risk assessments considered all chemicals of potential concern detected inenvironmental media during the Phase I RI and Phase II RFI. The results of the risk assessmentsare further developed to identify appropriate media cleanup standards based on current andfuture land use, media and chemicals of concern, and potential exposure pathways.2.2.1 Current and Future Land UseJenny Lind Pond is a drainage feature within the valley of the Jenny Lind Run. Jenny Lind Pondwas built in the late 1950s to retain industrial wastewater before discharge to the Ohio River.The watershed of Jenny Lind Pond includes all or part of 32 sites that were addressed in thePhase I RI (W-C 1996), and the pond has received P&E Area (Site 63) effluent. After the end ofproduction at the plant in the early 1970s, Jenny Lind Pond was renovated and restocked withfish in 1981. In the spring of 1997, the dam was breached by a catastrophic failure resultingfrom heavy precipitation runoff and subsequent flooding. The pond drained and today is emptywith small streams running through it. Based on this, current land use at Jenny Lind Pond ischaracterized as “not used”. For the purposes of developing cleanup goals, it is acknowledgedthat the area now drained may become flooded in the future.Institutional controls have already been implemented at Jenny Lind Pond in the form of statelegislation that restricts the future land use to agricultural, commercial, industrial, or state park.Reasonable future land use is therefore restricted; the site is expected to remain as a drainagefeature and will not be used as building sites for residential or commercial/industrial purposes. Aconservative future land use scenario for evaluation of human health risks includes transfer of theproperty to the Indiana Department of Natural Resources (DNR) for inclusion in the state parksystem.The Jenny Lind Run drainage basin supports a threatened and endangered species, the gray bat,and ecological concerns for the gray bat are expected to have an impact on the media cleanupstandards for Jenny Lind Pond. Consultation with the U.S. Fish and Wildlife Service (USFWS)is therefore required under Section 7 of the Endangered Species Act for any corrective measurethat will impact the gray bat or its habitat.2.2.2 Human Health Risk-Based Cleanup LevelsDevelopment of media cleanup levels specific to human health risk reduction is not warrantedbased on the results of the human health risk assessment. Carcinogenic risks totaled less than1x10-5 and summed hazard indices were less than 1.0. Refer to Section 7, Human Health RiskSECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 2-3Evaluation, of Jenny Lind Pond Phase II RFI report for additional information regarding the riskto human health.2.2.3 Ecological Risk-Based Cleanup LevelsMedia cleanup levels specific to ecological risk reductions are presented in the followingsubsections. The media cleanup levels reflect conservative estimates using available site-specificdata, particularly regarding the occurrence, density, and behavior of potential receptors. Becausethese data are somewhat limited, intentionally conservative assumptions have been applied.These assumptions include the possibility that the floodplain within Site 25 may become coveredwith water and revert to a pond environment. The ecological risk analysis is based onmaximizing the reduction of potential exposure in order to protect receptors while minimizingthe extent of any corrective action to conserve resources. The ecological risk-based cleanuplevels developed below will reduce residual COPEC exposures to levels below a threshold ofconcern.2.2.3.1 ApproachThe former Jenny Lind Pond, the Process Waste Settling Basin (Site 6), and a section of the P&EFlume (Site 54) located within the Jenny Lind Run have been combined into a single “exposureunit”. The sites were combined due to the proximity and shared border of these sites and to thepresence of nearly identical ecological habitat features. The ecological receptors selected duringthe baseline ecological risk assessments, which included species representative of both riparian,floodplain forest, and pond habitats, are believed to be functional here. The intent of the cleanuplevels developed in this CMS is to protect populations, rather than an individual organism, withthe notable exception of the gray bat, a listed endangered species.The ecological risk-based media cleanup standards were established following the iterativemethod described by Schulz and Griffin (2001), as well as guidance from Bower et al. (1996)and the National Academy of Sciences (1997, 1999). Two levels are developed within thisprocess, a mean residual exposure concentration and a “not to exceed concentration” (Schultzand Griffin 2001). This approach applies the same methods used in the risk assessments whileiteratively censoring, with background or detection limit replacements, sample locations withinthe exposure unit until the residual exposure level meets an exposure known or believed toassure that no ecological harm would occur. The highest residual chemical concentration is thenthe “not to exceed concentration” and the mean residual exposure concentration is used toestimate residual ecological risk. A flowchart depicting the process is presented as Figure 2-1.This process also results in the establishment of the remedial “footprint” within the exposureunit.Ecological risk-based concentrations are based on published laboratory or field studies to assurethat no undue ecological harm would occur due to the presence of chemical stressors withinapplicable media (i.e., soil, sediment, water, or biological tissues). These ecological risk-basedconcentrations are presented in Appendix A for all ecological receptors. The iterative censoringprocess employed the hazard quotient (HQ) as a metric of exposure and risk potential.SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 2-4In any CMS, uncertainty is relevant. Although uncertainty was unavoidable during thedevelopment of ecological corrective action objectives, most of the uncertainty is associated withthe degree to which exposures have been overestimated. A more detailed discussion of theapproach, assumptions, corrective measure scenarios evaluated, and residual risk analysis ispresented in Appendix A.2.2.3.2 Media and Chemicals of Potential ConcernThe applicable media evaluated at the sites include soil, sediment, surface water, and biologicaltissues used as food. The practical extent of “bioavailability” and biological activity is typicallylimited to the upper 2 feet of near surface soils and sediments. In fact, the most importantbiomass is found in the top 5 to 10 centimeters, the area where the vast majority of soilinvertebrates live (Bookhout, 1996). Subsurface soils (soils deeper than 2 feet bgs) are notbelieved to constitute a complete exposure pathway for ecological receptors, except in thelimited case of deep-rooted plants.A total of 71 chemicals were identified as chemicals of potential ecological concern (COPECs)during the ecological risk assessments for the three sites that compose the exposure unit. Two ofthe COPECs (fluoranthene and methoxychlor) identified in the surface water of Site 54, the P&EFlume, were only detected in the section of the flume outside the Jenny Lind Run. Additionally,dinitrotoluene and silver were identified as COPECs for indirect exposures, via the food web, atSite 54 but were not detected within the Jenny Lind Run. Therefore the true number of COPECswithin the Jenny Lind Run is 68.Not all of these COPECs were found to pose a potential risk based on the results of the sites’individual risk assessments. However, the exposure assumptions have been modified and theexposures have been reevaluated because the sites have been combined into a single exposureunit. Additionally, new data were obtained as part of the Ecological Risk Assessmentinvestigation of the Jenny Lind Run, which specifically addressed the site-specific“bioavailability” of COPECs in a revised exposure analysis (see Appendix A). This reevaluationidentified 18 chemicals (after combining certain pesticides, PCBs, and PAHs into singlechemical groups) that, based on the revised exposure estimates, are considered candidates forcorrective action, however, not all pose a similar risk for potential ecological harm. These18 COPECs are listed in Table 2-1.2.2.3.3 Not-To-Exceed Media Cleanup LevelsBased on further analysis of the 23 COPECs that may have significant exposure potentials (Table2-1) and the distribution of these COPECs within the sites, a set of not-to-exceed cleanup levelsfor soil and sediment were found to be effective at reducing estimated exposure potentials in theupper 2 feet. The not-to-exceed media cleanup levels for the Jenny Lind Run are:· 3 mg/kg mercury· 0.1 mg/kg total polychlorinated biphenyls (PCBs)· 0.1 mg/kg methoxychlorSECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 2-5Addressing soil/sediment with contaminant concentrations more stringent than the not-to-exceedcleanup levels would only minimally reduce additional exposure potentials.2.2.3.4 Residual Ecological ExposuresThe use of not-to-exceed cleanup levels would be effective in reducing the residual exposuresassociated with all COPECs to levels considered acceptable in water, sediment, soil and biota.However, these residual exposures assume that within the areas targeted for remediation, theselected alternative will be effective for all COPECs.2.2.3.5 Corrective Measure FootprintThe area within Jenny Lind Pond where surface soil and sediment samples were found to containchemical concentrations at or above the not-to exceed cleanup levels is shown on Figure 2-2. Atotal of 105 soil and sediment samples were collected at Jenny Lind Pond; of these 68 werecollected near the surface (within the top 2 feet). This area is based on the interpretation ofchemical data along with consideration of the site topography (narrow valley) and depositionalenvironment (settling and sedimentation). This area represents the remediation footprint thatwould need to be addressed to achieve the residual ecological exposure levels determined above.2.2.4 Proposed Media Cleanup StandardsThe following media cleanup standards are proposed:· Media of concern: Soil and sediment within 2 feet of the ground surface· Not-to-exceed media cleanup levels: 3 mg/kg mercury, 0.1 mg/kg total PCBs, and 0.1mg/kg methoxychlor (achieving the not-to-exceed media cleanup levels results inacceptable mean residual exposure concentrations for all COPECs)· Points of compliance: The area of the Jenny Lind Pond site including the downstreamdrainage from the former pond to the discharge point into the Ohio River (i.e., a locationnear the bridge downstream from the site).· Compliance time frame: Since no immediate threat has been identified, any time withinthe next 2 to 5 years should be protective.2.3 PROPOSED CORRECTIVE MEASURE OBJECTIVESThe proposed corrective measure objectives for Site 25 are focused on reduction of potential riskto ecological receptors. The proposed corrective measure objectives are:· Reduce potential ecological exposures to all COPECs in the upper 2 feet of soil andsediment within the Jenny Lind Pond site. Based on conservative mathematicalmodeling, significant exposure reduction with commensurate reduction in risk potentialscan be achieved by addressing three indicator chemicals as representative of all COPECsevaluated for the sites. The indicator chemicals and their respective not-to-exceed mediacleanup levels are:SECTIONTWO Corrective Measure ObjectivesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 2-6– Mercury, <3 mg/kg– Total PCBs, <0.1 mg/kg– Methoxyclor, <0.1 mg/kg· Control the potential migration of all COPECs to off-site receptors that may result fromthe transport of contaminated soil and sediment.TABLE 2-1SUMMARY OF CHEMICALS OF POTENTIAL ECOLOGICAL CONCERNSITE 25 - JENNY LIND POND(Organics are in ppb,Inorganics are in ppm)Water Sediment Soil Food Web Lowest RBC ReceptorOrganic COPEC2,4-Dinitrotoluene X X 5.73E+02 BenthosBenzo(a)anthracene X XBenzo(a)pyrene X XBenzo(b)fluoranthene X XBenzo(g,h,i)perylene X XBenzo(k)fluoranthene X XCarbon disulfide X 1.51E+00 BenthosChrysene X XDibenz(a,h)anthracene X XFluoranthene X XIndeno(1,2,3-c,d)pyrene X XMethoxychlor X 1.86E+01 BenthosPCB 1254 X XPCB 1260 X XPyrene X XTotal HMWPAHs X X 2.30E+03 BenthosTotal PCBs X X 1.79E+01 Gray BatInorganic COPECAluminum X X X 1.46E+04 BackgroundAntimony X X 3.00E+00 BenthosArsenic X X X 1.34E+01 BackgroundBarium X X X 5.00E+02 PlantsCadmium X X 9.26E-01 Gray BatChromium X X X X 6.16E+01 WoodcockCobalt X X X 1.93E+01 BackgroundCopper X X X X 7.16E+01 Gray BatCyanide X X 1.80E+00 PlantsIron X X X 2.50E+05 BenthosLead X X X 1.28E+02 BenthosManganese X X X 1.51E+03 BackgroundMercury X X X X 1.06E+00 BenthosNickel X X X X 1.08E+02 Gray BatSelenium X X X 3.54E+00 BackgroundThallium X X X 3.54E+00 BackgroundVanadium X 1.27E+02 PlantsZinc X X X 1.49E+02 Gray BatNotes:COPEC = chemical of potential ecological concernX = was revealed to pose a potential risk under baseline conditions within the Jenny Lind RunLowest RBC = lowest risk-based concentration among the potentially exposed ecological receptorsHMWPAHs = high molecular weight polycyclic aromatic hydrocarbonsPCBs = polychlorinated biphenylsUTFE = used the total concentration for the chemical class for the evaluation of risk (i.e ., Total HMWPAHs and Total PCBs)Receptor = the potentially exposed ecological receptor or receptor group with the lowest RBCBackground = The lowest RBC is below INAAP background levels therefore the background becomes the corrective measure objectiveUTFEUTFEUTFEUTFEUTFEUTFEUTFEUTFEUTFEUTFEUTFEUTFEQ:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 1 of 1 11/6/02Q:\4599\fl010g00\inaap_cms_site 25 final\Decision Diagram11x17.docCompare datasets and develop correctivemeasure objectives that will be protective ofboth human health and ecological receptorsEvaluate Corrective Measure Alternatives usingthese corrective measure objectivesYes YesDRN BY:JLVPROJ #45FL99010G.00DATE:06/21/01REVISION:DECISION DIAGRAM FORDEVELOPMENT OF CORRECTIVEMEASURE OBJECTIVESSITE 25 - JENNY LIND PONDINDIANA ARMY AMMUNITION PLANTFIG. NO:Select indicator chemical(s) for scenario analysis:Selected chemical(s) should:1. Be widespread within the area being evaluated2. Pose a significant risk potential to multiple ecological receptors3. Be collocated with other COPECsDoes the site pose a riskto ecological receptors?YesEvaluate indicator dataset:1. Locate a logical breakpoint in the ordered results for the indicator chemical (e.g., one subset has all 100mg/kg values and a second subset has 10 mg/kg values with few if any values [sample/locations] in-between)2. Censor all samples above the identified breakpoint in the ordered indicator chemical dataset3. Replace all inorganic data in censored samples with background concentrations for each COPEC4. Replace all organic data in censored samples with one-half reporting limit values for each COPEC1. Recalculate environmental exposure concentrations for all COPEC using censored datasets2. Recalculate all hazard quotients for all COPECs and relevant ecological receptorsEvaluate exposure (risk)reductions:Are all COPEC exposure potentialsreduced?NoSelect alternate oradditional indicatorchemical(s) forscenario analysisYesEvaluate significance ofresidual risks of all COPECs:Are all risks reduced to anacceptable level?NoSelect lower breakpointin indicator chemicaldatasetDoes the site pose arisk to human health?YesSelect chemicals of concernthat contribute to exceedanceof non-carcinogenic HI > 1.0and/or carcinogenic risk> 1x10-5Calculate a cleanup levelbased on a target HI = 1.0 for non-carcinogensand/or a target risk of 1x10-5for carcinogens using appropriate scenariosand receptorsCalculate residual riskwith cleanup levelincorporatedWill all risks bereduced to acceptablelevels?No Re-evaluate chemicalsof concernNoNo Further Actionrequired for humanhealth receptorsNoNo Further Actionrequired forecologicalreceptors2-1SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-1This section presents the development of remedial technologies and assembles technologies intocorrective measure alternatives.3.1 CORRECTIVE MEASURE APPROACH3.1.1 Range of Potential Corrective MeasuresThe proposed corrective measure objective developed in the previous section is aimed atprotection of ecological receptors, with concurrent protection of human health consistent withreasonable future land use (i.e., inclusion in the state park system). In order to achieve theproposed corrective measure objective, this CMS will consider the following range of potentialcorrective measures:· Institutional Controls: Restrict public access to the site through land use restrictions.· Engineering Controls: Implement physical controls (e.g., protective covers or removal) tolimit potential exposure to contaminated media and/or migration of contaminated media.· Treatment: Use in situ and/or ex situ treatment technologies to reduce the toxicity,mobility, and/or volume (TMV) of contaminants.· Monitoring: Monitor the site to ensure that the health and/or environmental protectionachieved by the corrective action is maintained.3.1.2 Site Characteristics that Affect Design and Construction of a Corrective MeasureThe corrective measures listed above may be implemented alone or in combination. Based onthe corrective measure objectives and information obtained during the Phase I RI and Phase IIRFI, the following site-specific characteristics are considered to be relevant to the design andconstruction of a corrective measure at Jenny Lind Pond.3.1.2.1 Site EnvironmentAs discussed within the ecological risk assessments for the sites associated with the Jenny LindRun (Sites 6, 25, and the relevant portion of 54), the resident ecological communities (aquaticand terrestrial) are not overly significant in the context of the landscape ecology of the INAAPgrounds. However, the habitat within the Jenny Lind Run is home to the endangered gray bat(Myotis grisescens) whose presence within the run has been confirmed by USFWS. Thisrequires the CMS to address the management objectives, conservation goals, and prescriptionsfor the Jenny Lind Run drainage basin within the context of ecological protection andconservation.Within Jenny Lind Pond there are several palustrine and riverine wetland areas that are listed onthe USFWS National Wetlands Inventory map. Based on this, activities occurring at wetlandsunder the jurisdiction of USACE are regulated by Section 404 of the Clean Water Act.Corrective measures work at the site would likely fall under the provisions of Nationwide Permit38, Cleanup of Hazardous and Toxic Waste, which requires notification of the USACE DistrictSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-2Engineer. Depending on whether the selected alternative involves any dredging or filling of thewetland, some form of mitigation may also be required.Consideration of impacts to cultural resources is mandated under Section 106 of the NationalHistoric Preservation Act (NHPA) as implemented by 36 CFR Part 800. Requirements includethe need to identify significant historic properties that may be impacted by the proposed action oralternatives. Historic properties are defined as archaeological sites, standing structures, or otherhistoric resources listed in or determined eligible for listing in the National Register of HistoricPlaces (NRHP) (36 CFR 60.4). The Jenny Lind Pond site is highly disturbed and is not likely tocontain historic artifacts or cultural resources. Prior to commencing the construction of theselected corrective measure, the State Historic Preservation Officer (SHPO) will be consulted byINAAP to verify that the proposed project area contains no recorded historic properties.3.1.2.2 Protection of Endangered SpeciesThe ecosystem along the Jenny Lind Run supports the gray bat, a Federally-listed endangeredspecies. The gray bat uses caves in the Jenny Lind Run. An Endangered Species ManagementPlan and Environmental Assessment (ESMP/EA) for the gray bat, Myotis grisescens, has beencompleted (Tetra Tech, draft final, December 1999). The ESMP/EA developed managementobjectives, conservation goals, and prescriptions for the Jenny Lind Run drainage basin. Themanagement prescriptions relevant to this project include:· Incorporating gray bat habitat conservation guidelines into existing INAAP activities thatmight impact the gray bat, including environmental remediation· Protecting bat habitat through implementation of the following management prescriptionswhenever the gray bat may be present at INAAP (i.e., March 15 through October 31):– Prohibiting earth-moving activities and disturbance to natural vegetation within100 feet of a karst feature– Using appropriate erosion control measures to prevent debris from entering the karstfeature when earth-moving activities are done more than 100 feet from a karst featurebut within the drainage area of the karst feature– Prohibiting disturbance of the forest cover· If deviations from the management prescriptions are necessary, ESA Section 7consultation with USFWS Region 3 Bloomington Field Office is necessary to avoid orminimize impacts on the gray batEarthwork activities associated with corrective action, such as clearing and grubbing, placing fill,or excavating and stockpiling materials, would be considered a possible disturbance of the graybat habitat. It is likely that the gray bat forages within Jenny Lind Pond, so disturbance of forestcover may be an issue.Jenny Lind Pond is located in a karst feature. Therefore, all earthwork activities will requirespecial erosion control measures to minimize any disruption to karst features that are likelyconnected to downgradient drainage including the Ohio River. Based on the managementSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-3prescriptions and location of contaminated media within the drainage channel, ESA Section 7consultation is required for any corrective action at Jenny Lind Pond involving containment,removal, or treatment.3.1.2.3 Areas and Volumes of Contaminated MediaSediment has settled behind the former location of Jenny Lind Pond Dam. The drainage channelmeanders through the basin and has formed several backwater areas. The sediment is saturatedand unstable, and in its current state is not capable of supporting construction vehicles or workersin many areas throughout the basin. The estimated depths of process waste sediment range from4 feet near the dam to 8 feet near the center of the site along the drainage channel. The processwaste sediment sits atop approximately 50 to 60 feet of Ohio River alluvium. The total area ofthe basin is an estimated 26 acres, and the total volume of process sediment at the site is anestimated 300,000 cubic yards.Contaminated media at Jenny Lind Pond include surface soil and sediment containingmethoxychlor, PCBs, and mercury above the not-to-exceed media cleanup levels. The area ofcontaminated media is shown on Figure 2-2. The contaminated media are located in threeseparate areas within the limits of Jenny Lind Pond. The approximate areas for the footprints ofcontamination are listed below:· Western-most area - 77,000 square feet (8,600 square yards)· Central area - 450,000 square feet (50,000 square yards)· Northern-most area - 13,000 square feet (1,400 square yards)The combined area of these three footprints covers approximately 540,000 square feet or 60,000square yards.The depth of contaminated sediment averages about 4 feet below the western footprint, andabout 8 feet below the central footprint. Since no subsurface soil borings were completed withinthe northern footprint, the average depth of contaminated sediment within the central footprint,8 feet, was also used as the average depth for this footprint, since it is located near and upstreamfrom the central footprint. Based on this, the following approximate volumes were calculated:· 11,000 cubic yards of contaminated sediment below the western footprint· 130,000 cubic yards of contaminated sediment below the central footprint· 3,700 cubic yards of contaminated sediment below the northern footprintBased on this, the combined volume of contaminated sediment below the three footprints atJenny Lind Pond totals 140,000 cubic yards.3.1.2.4 Downstream HotspotIn addition to the three footprints discussed above, a fourth relatively small area ofcontamination (i.e., a hotspot) estimated to be 1,200 cubic yards of soil occupying approximatelySECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-40.6 acres, was found along the top of the bank of Jenny Lind Run downstream of the dam. Thisarea of contamination was identified based on four surface soil samples collected in 1995 atlocations southeast of the Jenny Lind Pond Dam, directly downstream from the dam’s principalspillway discharge. However, these surface soil samples were collected prior to the dam failurein 1997. Therefore, it is possible that the flooding of the Ohio River, which caused the dam tofail, may have moved the contaminated surface soils or may have even washed some or all ofthese soils completely off site.A surface soil sample (25SS05, collected in December 1995) and a collocated sediment/surfacewater sample (25SW/SD01, collected in February 1996) were located upstream of the hotspot,and a sediment sample (25SD26 – ICI, collected in May 1997, after the dam failed) was locateddownstream. None of these samples contained any unacceptable concentrations of COPECs.Based on the uncertainty associated with the current existence and location of the hotspot, andgiven the dam’s breached condition, any potential hotspot removal should be completed onlyafter the following have been addressed:· The dam breach has been stabilized.· The contaminated soils and sediments across the rest of the site have been effectivelyaddressed by a corrective measure that prevents downstream migration.· Additional site characterization (e.g., sampling and analysis) has been completed todefine the location and extent of contamination. Any additional sampling and analysisshould only be completed when funding is available for the removal. This would avoidproblems associated with flooding and possible erosion/migration, which could invalidatethe planned removal locations.A hotspot removal, if necessary, could be accomplished through a Removal Action.Presently (Spring 2002), this portion of the site is flooded. This is due to both a high water levelin the Ohio River and the presence of several beaver dams that have been constructed in the area.Therefore, it is likely that the site will require dewatering prior to any additional sampling orremoval activities.3.1.2.5 Waste CharacterizationNo samples of contaminated media have been collected and tested using the toxicitycharacteristic leaching procedure (TCLP) to evaluate whether it is characteristically hazardous.However, the “20 Times” rule for analyzing the toxic characteristic of a chemical concentrationstates that if the results of a “total” chemical analysis is 20 times greater than the TCLPregulatory limit, the waste should be considered hazardous until further testing has beencompleted. As shown in Table 3-1, approximately 26% of detected lead concentrations are morethan 20 times the regulatory limit and approximately 13% of detected mercury concentrations aremore than 20 times the regulatory limit. Since the samples were not collected in a uniform gridpattern and many of the concentrations that exceed the “20 Times” rule were detected near thesurface it is assumed, consistent with the other CMSs already completed for INAAP, that 80% ofthe contaminated media is nonhazardous and that 20% is hazardous.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-53.1.2.6 Condition of Existing DamJenny Lind Pond Dam is located about 1,500 feet upstream from the Ohio River and is foundedon river sediment on the order of 50 feet in thickness. Jenny Lind Pond Dam is an earth damwith a design crest at Elevation 442.5 feet. A record drawing of the dam (dated August 12,1955) indicates a maximum height of about 22 feet. The spillway/outlet works for the damformerly consisted of twin metal riser pipes at the upstream toe, connected to twin barrel pipesdischarging through the dam. The crest of the risers is shown as Elevation 440.2. Plans showthe barrel to have two cut-offs to limit seepage along the pipe. The dam originally contained awooden framework around the riser pipes and a wood deck leading from the dam crest to the topof the riser.The spillway/outlet structure failed during a major flood of the Ohio River valley in 1995, and ithas not been repaired since that time. The failure has left a breach through the dam where theJenny Lind Run channel flows from the site to the Ohio River. The dam was visually examinedon March 28, 2002 by URS. A report on these findings, along with options to repair the dambreach, is presented in Attachment 1.3.2 IDENTIFICATION AND SCREENING OF POTENTIAL TECHNOLOGIES3.2.1 Initial Screening of Technologies and Process OptionsCandidate remedial technologies and process options (which include the various methods ofimplementing a remedial technology) have been reviewed for applicability at Jenny Lind Pond.Technologies and process options that are not technically feasible or do not apply to the siteconditions and contaminants of concern have been screened out.The evaluation of applicability takes the practical nature of implementation into consideration,given the physical site conditions (e.g., location configuration and topography) and the wastecharacteristics (e.g., chemical types and extent). Remedial technologies and process optionsconsidered to be potentially applicable, based on the initial screening, are listed in Table 3-2.3.2.2 Final Screening of Technologies and Process OptionsThe potentially applicable process options were further evaluated and screened to narrow thefield of potential options to a single (to the extent possible) representative technology or processoption for each general corrective measure category.3.2.2.1 Screening Criteria for Process OptionsThe criteria for screening process options included effectiveness, implementability, and cost, asdescribed below.EffectivenessThe evaluation of a technology’s effectiveness focuses on three primary considerations:SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-6· Ability to address the estimated areas of volumes of contaminated media and to meetcorrective measure objective· Potential effects on human health and the environment during implementation· Reliability and proven performance with respect to site conditions and chemicals ofpotential concernImplementabilityThe evaluation of implementability considers the technical and administrative feasibility of aprocess option. Implementability may be characterized as readily implemented, moderatelydifficult, or difficult to implement relative to other process options under consideration, based onexperience and engineering judgment. The following factors were considered as part of theimplementability evaluation:· Availability and capacity of treatment, storage, and disposal facilities· Availability of equipment and trained workers needed to implement the technologyCostThe cost evaluation was limited to a qualitative cost comparison that considers the capital andoperation, maintenance, and monitoring (OM&M) costs of a particular process option. Costswere characterized on a relative basis as low, moderate, or high, based on experience andengineering judgment.3.2.2.2 Summary of Screening ResultsThe evaluation and screening process is presented in Table 3-3. Comments regardingeffectiveness, implementability, and relative cost are also provided in the table. Technologiesare identified as retained or not retained and screening comments are provided to justify theexclusion of process options. Some of the process options may not be effective as stand-alonetechnologies, but have been retained for use in combination with another technology. Thefollowing technologies were retained for assembly into corrective measure alternatives:General Corrective Measure Representative TechnologiesInstitutional Controls Deed RestrictionsEngineering Controls through SurfaceEnhancementGrading and Revegetation, Armoring, Drainage ChannelImprovements, Soil CoverEngineering Controls through Containment Dam Modification, Vegetated Soil CoverEngineering Controls through Removal andDisposalMechanical Excavation and Disposal at RCRA Subtitle Dor C LandfillTreatment In-Situ Phytoremediation and BioremediationMonitoring and Inspection Periodic Soil, Sediment and Surface Water Sampling andSite InspectionsSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-73.3 IDENTIFICATION OF CORRECTIVE MEASURE ALTERNATIVESCorrective measure alternatives (CMAs) were developed based on the technologies and processoptions that passed the above screening process. The general corrective measures and theirrespective representative technologies were assembled into five CMAs as developed below.3.3.1 CMA-1, No ActionThis alternative assumes that no further corrective action would be implemented at Jenny LindPond. Human health and ecological risks would be those identified in the respective baselinerisk assessments presented in the Phase II RFI report (URS, 2001). This alternative serves as abaseline to which other alternatives will be compared.3.3.2 CMA-2, Dam Modification with Institutional Controls and Monitoring3.3.2.1 Description of CMA-2CMA-2 involves modifying the dam’s present state to contain contaminated soils and sedimentsbehind the dam, while using institutional controls to restrict land use at the site and monitoring totrack potential changes in the location or level of contaminants to help make future riskmanagement decisions. The proposed institutional controls and monitoring include:· Stabilize the breach and complete modifications to the dam to contain contaminatedsediments within the Jenny Lind Pond basin.· Restrict land use on the site.· Complete a Removal Action, as necessary, to address the hotspot downstream of the dam.· Complete a baseline site inventory and annual site monitoring.A conceptual site plan illustrating the principle elements of the CMA-2 is shown on Figure 3-1.The breach in the dam and the channel flowing through this breach require appropriatestabilization in order to control erosion and downstream sediment transport. Access to JennyLind Pond dam is limited, and mobilization of construction equipment would be via the existingroad. The area northwest of the dam would need to be cleared and leveled to form a constructionstaging area.The design concept for the dam modification is discussed in Attachment 1. Stabilizing thebreach in the dam could be completed most economically through a combination of grading thebreach slopes and installing a concrete weir. The dam repairs would generally be completed asfollows:· Install temporary sediment and erosion controls. Lower the stream water level, either bydiversion or pumping in order to prevent water from flowing over the spillway. Waterpumped from the site during dewatering activities will likely contain high levels of totalsuspended solids and will potentially contain some contaminants at levels of concern.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-8Prior to its discharge this water will require testing and possibly treatment (e.g.,filtration).· Install temporary diversion of the stream.· Grade the breach slopes to a 2:1 slope.· Demolish the riser pipe and timber framework.· Construct the concrete weir, assuming a height above stream bottom of 1 foot and lengthof 45 feet, to maintain water levels at or near the top of the channel embankment.· Place riprap in the channel the full length of the breach (upstream toe to downstream toe)and up to 10 feet (measured along the slope) up the slope.· Hydro-seed the affected areas.· Remove temporary sediment and erosion control measures.A hydrologic/hydraulic analysis is required to adequately size and design the new weir. Thedimensions of the new weir must be adequate to manage the Design Flood, which will beselected based on hazard potential. There are currently no occupied structures downstream fromthe site. There is an existing road and a bridge that cross the Jenny Lind Run about 1,000 feetdownstream of the Jenny Lind Pond Dam, but this road is not accessible to the public nor is itfrequently traveled. In addition, the flood plain downstream of the Jenny Lind Pond Dambecomes quite broad before it empties into the Ohio River. Therefore, it is envisioned that,under current conditions, a flood through the breach in this dam would not pose a significanthazard to life or property. The primary consequences of a flood would be environmental, withsediments released downstream. For the purposes of this CMS, it is assumed that the new weirwill be classified as low hazard and that the typical Design Flood would be the 100-year stormevent. Since the hydrologic/hydraulic analysis has not yet been completed, it is also assumedthat setting the height of the weir at one foot above the stream bottom and lining the channel withriprap would be adequate to prevent migration of contaminated sediment. This will need to bechecked during the design phase.Institutional controls have already been implemented at the site in the form of state legislationthat restricts the future land use to agricultural, commercial, industrial, or state park. In addition,management prescriptions associated with the ESMP/EA restrict earthmoving operations within100 feet of a karst feature. It is assumed that these management prescriptions would preventman-caused disturbance of any contaminated media that is left in place. Formal deed restrictionsmay be needed if the current restrictions are judged to be inadequate in the prevention of such adisturbance.The proposed monitoring would include a yearlong, quarterly baseline inventory to develop adatabase for statistical analysis of current site conditions. Annual monitoring and site visitswould follow to document that site conditions remain relatively static. Monitoring wouldinclude collection and analysis of downstream sediment and surface water samples to evaluatepotential off-site contaminant migration. Additional surface water and sediment samples will becollected just upstream of Jenny Lind Pond to monitor for potential migration of contaminantsSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-9into the Jenny Lind Pond site. Subsequent surface water and sediment monitoring may providean early warning of future increased exposure potential. A five-year review of the site andcontrols would be used to assess the effectiveness of this option and to make future riskmanagement decisions.Sediment and surface water samples would be collected from permanent sediment/surface watersampling stations. Permanent sampling stations would provide the ability to collect samplesfrom the same location, with the capability of monitoring sedimentation rates andsediment/surface water quality. The proposed sample stations would be located at threelocations, two upstream and another downstream of Jenny Lind Pond. The sampling stationswould become part of a network of stations along the Jenny Lind Run used to monitor migrationof sediment/surface water throughout the watershed.After the modifications to the dam have been completed the hotspot Removal Action could beimplemented. This Removal Action, if needed, would require the following activities:· Removal of beavers and beaver dams from the area downstream of the dam· Dewatering of this area plus testing (and possible treatment) of the water removed· Installation of a crushed rock and geotextile road to access the hotspot· A field investigation that includes soil sampling, sample screening with a mercury vaporanalyzer, confirmatory laboratory analysis of samples, sample validation, and productionof a report that includes soil/sediment classification(s)· Excavation and disposal of mercury-contaminated soils/sediments to appropriate SubtitleD (and/or C) landfill(s)· Backfilling and grading the excavation3.3.2.2 Effectiveness-of CMA-2Dam modification will help to provide for long-term containment of the contaminated sedimentsthat have settled in Jenny Lind Pond. However, some upstream erosion combined with sedimenttransport over the weir is still expected to occur during periods of heavy runoff. Annualinspections and a maintenance program would be required to maintain the stabilized breach inthe dam. Restrictions on current and future land use are expected to maintain current siteconditions (i.e., not used). Land use restrictions would keep human health risks below levels ofconcern; however, they would not reduce the potential exposure of ecological receptors, whichdrive the calculated risks at Jenny Lind Pond. Monitoring is an effective risk management toolfor tracking and evaluating the effect of potential future contaminant migration.An important advantage of CMA-2 is that by restricting earthmoving activities in the basin to thearea around the dam, disturbance and migration of contaminated sediments from the basin wouldbe limited. However, the Removal Action to address the hotspot would involve significantdisturbance to the soils/sediments in the area downstream of the dam. Impact to habitat, such asremoval of trees and shrubs, would also be limited to the dam embankment, staging area, anddownstream hotspot. Although this alternative would cause the least amount of short-termSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-10disruption to the habitat, it offers little long-term exposure reduction to the contaminated mediafound at the surface of the basin upstream of the dam. The components of CMA-2 could beimplemented in conjunction with other remedial activities if a short-term disruption of habitatwithin the basin is acceptable to USFWS.3.3.2.3 Implementability-of CMA-2Dam modification, institutional controls, and monitoring are technically feasible and can bereadily implemented. The dam modification will require dewatering, earthwork, and structuralconcrete. These construction methods are proven and the equipment, labor, and materials arereadily available. Stringent erosion control and dust control measures will be required duringconstruction to minimize migration of contaminants during all earthwork activities. After thedam modification has been completed the hotspot Removal Action could be completed.The administrative feasibility may incur some difficulties. The anticipated difficulties wouldinvolve the prohibition of earthwork in a karst feature, prohibition of removal of forest cover,and limitations on construction access between March 15 and October 31. Special approval fromUSFWS would be required to implement this alternative. If approved, close coordination withthe USFWS and IDEM will be required during the planning, construction, and reporting phasesof the design and construction. Design of the dam modification will require the selection of aDesign Flood, which may require input from DNR dam safety personnel.3.3.3 CMA-3, Soil Cover and Dam Modification3.3.3.1 Description of CMA-3CMA-3 involves containing the contaminated media beneath a vegetated soil cover and a linedchannel to reduce the potential for direct exposures to ecological receptors and to controlmigration of COPECs caused by erosion and sediment transport. In addition, the institutionalcontrols, monitoring, and hotspot Removal Action described in CMA-2 are included as acomponent of CMA-3. The dam modification is also included in CMA-3, but the concrete weiras described under CMA-2 is not required because the soil cover and lined channel wouldeliminate the need to contain sediment behind a weir. Specific elements of this alternativeinclude:· Selectively clear and regrade the site to develop contours suitable for runoff andstormwater control.· Install a liner and erosion protection along the drainage channel through the basin, nearits current alignment.· Modify the existing dam to stabilize the breach.· Construct a 2-foot-thick vegetated soil cover over the areas with contaminated soils andsediments.· Complete a Removal Action, as necessary, to address the hotspot downstream of the dam.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-11· Restrict land use on the site, complete a baseline site inventory, and annually monitor thesite.A conceptual plan showing the principal elements of CMA-3 is presented on Figure 3-2. Thevegetated soil cover will be placed over an area about 540,000 square feet in size, and thedrainage channel improvements will run the full length of the basin, about 4,500 linear feet.Access to Jenny Lind Pond is limited, and mobilization of construction equipment would be viathe existing road cut along the valley embankment. The area northwest of the existing damwould need to be cleared and leveled to form a construction staging area.The dam modification would be done as described in CMA-2, except that installation of a weirwould not be required since the soil cover will prevent the migration of contaminants. Thesequencing of dam modification construction with other earthwork activities should bedetermined during design, if this alternative is selected. The dam could be modified during aninitial construction phase, and the soil cover and drainage channel improvements could beconstructed as a separate later phase (the hotspot removal could be completed at any time afterthe dam modification). The soil cover material will decrease the water storage capacity behindthe dam, which will result in increased peak flows over the spillway. As discussed above forCMA-2, a hydrologic/hydraulic analysis will be required during design. An important input tothis design is the selection of the appropriate Design Flood.Process waste sediments have been deposited at the site in layers varying from a few feet inthickness over much of the pond basin to several feet in thickness in the incised channels. Thesediments at the basin floor are often wet from storm runoff and/or the shallow groundwatertable, and surface soils along the edge of much of the basin are unstable due to steep slopes.Heavy construction equipment will not be able to traffic a large portion of the site, as it exists;therefore, the site will require dewatering and stabilization for construction. Dewatering couldbe accomplished by pumping water from a series of sumps aligned through the length of thebasin. Water pumped from the site during dewatering activities will likely contain high levels oftotal suspended solids and will potentially contain some contaminants at levels of concern. Priorto its discharge this water will require testing and possibly treatment (e.g., filtration).Unstable areas could be stabilized through the use of pozzolanic agents, geotextiles, geogrids,and/or aggregates, probably used in combination or applied separately in different areas based oncondition. An access road for use during construction and during long-term site monitoring andmaintenance is included as part of the conceptual design. The access road is assumed to run thelength of the both arms of the Jenny Lind Pond basin (see Figure 3-2), and is assumed to consistof a combination of geogrid (or geo-reinforcement) and crushed rock. A box culvert will beinstalled to allow the drainage channel to flow under the access road at the one crossing point.After site access and dewatering has been completed, the areas to be covered will be cleared ofexisting vegetation. In general, this activity will consist of hand clearing and use of smallequipment capable of tracking on soft ground. Most of the vegetation to be cleared consists ofgrasses and small shrubs that have grown up over the sediment surface. It may be advantageousto leave some of the vegetation and root mass in place to aid with stability for constructionSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-12equipment. Removal of trees that have grown up on the basin floor will be required to install thesoil cover. It may be possible to design the soil cover around some of the stands of larger treesin an effort to meet USFWS goals for protection of bat habitat. The cleared vegetation could bechipped and mulched for use on site during the establishment of the final vegetative cover.The site will be pre-graded to establish even slopes with positive drainage to the channel runningthrough the basin. The channel will be excavated to form an efficient conduit (i.e., unbraided)through the entire length of the basin. The final channel alignment will generally follow theexisting alignment but will have a uniform width and cross section capable of handling runoff forthe Design Flood. For purposes of this CMS, it is assumed that the channel will be lined with ageomembrane that is tied into the soil cover, with stability for the geomembrane provided by acombination of geogrid and compacted soil or rock. The liner would be covered with acombination of crushed rock and riprap to hold the liner in place and to protect the liner.Alternatively, a bioengineered, vegetated embankment may be designed to stabilize the channelbanks. A cross section illustrating the channel concept is shown on Figure 3-2.To establish the lined channel, excavation of an estimated 44,000 cubic yards will be required.This excavated material would be regraded on site beneath the new soil cover.The soil cover will consist of cohesive soil from an uncontaminated borrow source locatedwithin INAAP; it will be imported to the basin and placed in a single, 24-inch layer. It isassumed that the soil cover will be placed directly over the pre-graded basin floor, bound by thechannel edge and the valley wall. Overall long-term erosion protection for the soil cover andchannel will be provided by a combination of vegetation, geotextile, and rock. The final designof this alternative, if selected, should consider the many materials available to help stabilize thesite and to protect against erosion and migration of contaminated sediment.3.3.3.2 Effectiveness-of CMA-3In the long term, the soil cover, lined drainage channel, and dam will decrease potentialexposures to contaminated media and will subsequently reduce potential ecological exposurerisks. This combination will also limit the potential migration of contaminated media caused byerosion and sedimentation processes.In the short term, this alternative will require considerable disruption to the existing habitat. Thisalternative requires the use of earthmoving equipment throughout the basin. Current estimatesinclude excavation of about 44,000 cubic yards of soils and sediments along the channel andplacement of about 25,000 cubic yards of clay fill for the soil cover and channel work. Sometransport of contaminated sediments through karst features such as cracks, fissures, and sinkholesmay occur during excavation. Existing vegetation, including trees, will be removed in order toestablish the soil cover.The addition of the soil cover will restrict the flow through area within the basin, which wouldtend to concentrate floodwaters and could lead to severe erosion if not properly designed.Destabilization and erosion of the soil cover is likely to occur over time due to groundwaterseepage from the rocky embankments of the basin into or beneath the cover. Periodic siteSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-13inspections and maintenance of the vegetated cover, drainage channel, and dam will be necessaryto maintain the protectiveness of this alternative. The surface water and sediment samplingoutlined in CMA-2 will help to monitor the effectiveness of the alternative.3.3.3.3 Implementability-of CMA-3The activities proposed for CMA-3 present both technical and administrative difficulties.Technical difficulties are associated with constructibility and include site remoteness, pooraccess, and instability of sediments and soils. Aside from these constructibility issues, theconstruction activities associated with CMA-3 are not particularly challenging and the requiredequipment, manpower, and materials are locally available. Stringent erosion control and dustcontrol measures will be required during construction to minimize migration of contaminantsduring all earthwork activities.Administrative difficulties involve the prohibition of earthwork in a karst feature, the prohibitionof removal of forest cover, and the limitations on construction access between March 15 andOctober 31. Special approval from USFWS would be required to implement this alternative. Ifapproved, close coordination with the USFWS and IDEM will be required during the planning,construction, and reporting phases of this alternative. Long-term administrative oversight will berequired to maintain the land use restrictions and to oversee the monitoring and maintenance ofthe constructed improvements.3.3.4 CMA-4, Removal and Disposal3.3.4.1 Description of CMA-4CMA-4 involves removing the contaminated media and transporting it to a permitted landfill. Inaddition, the hotspot Removal Action described in CMA-2 is included as a component ofCMA-4. This alternative would eliminate exposure potentials caused by direct contact ormigration of contaminated media. The proposed removal and disposal activities include:· Remove contaminated soils and sediments where contaminant levels are above mediacleanup standards.· Characterize and dispose of contaminated media in a permitted solid waste landfill(Subtitle D) or a hazardous waste landfill (Subtitle C).· Restore the site by removing the dam, regrading and revegetating the valley slopes, andstabilizing the Jenny Lind Run channel.· Complete a Removal Action, as necessary, to address the hotspot downstream of the dam.A conceptual plan showing the excavation depths and other principal elements of CMA-4 ispresented on Figure 3-3. The contaminated soils and sediments will be removed to an estimatedaverage depth of about 4 feet in the area of the western footprint and to an estimated averagedepth of about 8 feet in the area of each of the other two footprints. Removal to these depths isexpected, based on the current chemical data set, to leave a layer of soil or sediments at least24 inches thick (the practical extent of “bioavailability”) that does not contain any of theSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-14indicator chemicals at concentrations above their respective not-to-exceed media cleanup levels.It should be noted, however, that these indicator chemicals were selected by censoring surfacesoil and sediment data, so their application to subsurface soils may require some statisticalrefinement.Site access difficulties will be similar to those described for CMA-3. However, since thisalternative involves removal, unstable sediments can be excavated as construction progressesfrom one end of the basin to the other, and space for stockpiling will not be an issue. Prior toremoval, the site would first be cleared and grubbed of trees and shrubs. Cleared vegetationcould be mulched and reused during the establishment of final vegetation.The estimated volume of soils and sediments to be excavated is approximately 140,000 cubicyards with an estimated weight of about 210,000 tons. Excavation of the contaminated materialcould be completed using conventional earthmoving equipment. Special erosion controlmeasures would be implemented and maintained during construction to prevent downgradientmigration of soils and sediments. The actual volume of soil to be excavated would be based on astatistical, confirmatory sampling round completed from the walls and floor of the excavation. Ifunacceptable contaminant levels were found, additional excavation would be required andanother round of confirmatory samples would then be collected and evaluated.Material will be characterized during excavation to determine the final disposal destination.Some of the excavated material may be characteristically hazardous and will need to be handledaccordingly. The Subtitle D solid waste will be transported to the local RCRA Subtitle D landfill(e.g., Clark Floyd landfill, located in Clarksville, Indiana, about 20 miles from the site) fordisposal. The Subtitle C hazardous waste will be transported to the nearest Subtitle C landfill.At present, it is estimated that 20 percent of the excavated material will be disposed of at theSubtitle C landfill.After the removal has been completed, the remaining sediments and soils will be graded toestablish finish site grades with even slopes and positive drainage. The channel will also be re-gradedat this time. The final channel alignment will generally follow the existing alignment.The dam will be demolished and removed from the site. Vegetation in combination withgeotextiles and rock will be used to stabilize the channel and to protect against erosion.3.3.4.2 Effectiveness-of CMA-4The removal of contaminated soils and sediments will eliminate potential ecological risks andcontaminant migration. This alternative would also eliminate the need for long-termmanagement of the site. Disposal of the contaminated material in a solid or hazardous wastelandfill is expected to be a safe and effective means to permanently control the material.However, the government would retain long-term liability for the waste, which may includesome financial risk if the landfill selected for disposal were to leak and cause environmental orhuman health risks that would then require investigation and/or remediation.This alternative will considerably alter the habitat within Jenny Lind Pond. In the short-term,trees and vegetation will be completely removed over the footprint of the basin floor.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-15Considerable disruption is also expected due to the large amount of excavation and potential forsediment transport through karst features such as cracks, fissures, and sinkholes.3.3.4.3 Implementability-of CMA-4The activities proposed for CMA-4 present a few technical and several administrativedifficulties. Technical difficulties are associated with constructibility, and include siteremoteness, poor access, and instability of sediments and soils. Excavation is expected to begenerally easier than installation of a soil cover because most of the unstable materials can beremoved as equipment advances into the basin. Aside from these constructibility issues, theconstruction activities associated with CMA-4 are not particularly challenging and can beimplemented using traditional construction techniques and earthmoving equipment. Therequired equipment, manpower, and materials are locally available. Stringent erosion controland dust control measures will be required during construction to minimize migration ofcontaminants during all earthwork activities.Administrative difficulties involve the prohibition of earthwork in a karst feature, the prohibitionof removal of forest cover, and the limitations on construction access between March 15 andOctober 31. USFWS may not approve this alternative because it would significantly alter the bathabitat and it may be determined to be deterimental. If approved, close coordination with theUSFWS and IDEM will be required during the planning, construction, and reporting phases ofthis alternative. Because the contaminated media would be removed and not left on site, long-termadministrative oversight will not be required.3.3.5 CMA-5, In Situ Treatment and Dam Modification3.3.5.1 Description of CMA-5CMA-5 involves a combination of treatment and containment to address site contaminants.Contaminated media at the surface will be treated through the use of certain plants species,microorganisms, and soil nutrients. Contaminated sediment will be contained through theimproved erosion control of the selected plantings and through the dam modification describedin CMA-2. The primary elements of this alternative include:· Selectively clear and regrade the site to develop contours suitable for erosion control.· Introduce microorganisms and soil nutrients to the near-surface soil and sediment toenhance biodegradation of organic contaminants.· Introduce a variety of plant species, some that target extracting or immobilizing inorganiccontaminants and others that develop thick root mats for erosion control.· Stabilize the drainage channels using a combination of geotextiles, vegetation, and riprap.· Modify the existing dam to contain contaminated sediments that have settled in JennyLind Pond and install a new overflow structure (weir) across the dam breach to maintainwater levels at or near the top of the channel embankment.· Complete a Removal Action, as necessary, to address the hotspot downstream of the dam.SECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-16· Restrict land use at the site, complete a baseline site inventory, and monitor the siteannually.The components of CMA-5 are shown on Figure 3-4. The area that would be treated measuresan estimated 540,000 square feet, or about 12 acres. The dam modification, institutional controlsand monitoring, and hotspot Removal Action described for CMA-2 will be included as part ofthis alternative. However, additional monitoring will be necessary to record the progress of thetreatment. The sequencing of dam modification construction with the in situ treatment activitiesshould be determined during design, if this alternative is selected. The dam could be modifiedduring an initial construction phase, and the in situ treatment could be implemented as a separatelater phase (the hotspot removal could be completed at any time after the dam modification).Complete development of the treatment component of CMA-5 is difficult at this time becauseadditional data are needed to identify the appropriate plant species and microorganismsnecessary to address the COPECs. Additional information is also needed regarding soil types,properties and soil chemistry to aid in the design. At this time use of one or more of thefollowing in situ treatment options are considered feasible:· Bioremediation – the use of microorganisms including yeast, fungi, or bacteria to degradehazardous substances under aerobic or anerobic conditions· Phytostabilzation – the use of plants to immobilize contaminants in soil throughabsorption and accumulation by roots, adsorption onto roots, or precipitation within theroot zone of plants, and the use of plants to prevent contaminant migration via wind andwater erosion, leaching, and soil dispersion· Rhyzodegradation – the breakdown of contaminants to less toxic materials throughmicrobial activity enhanced by the presence of plants’ rhizospheres, or root zones· Phytovolatilization – the use of plants to extract contaminants from soil or water andrelease them to the atmosphere; in this case it would involve the use of transgenic plantsto convert toxic methylmercury and ionic mercury [Hg(II)] to greatly detoxifiedelemental mercury [Hg(0)], which would then be released to the atmosphere in very lowconcentrationsBecause of these data limitations, the alternative description in this report is somewhat generic.It should be noted that individually each of the above technologies is a proven technology thathas been used successfully to treat contaminants at sites. However, completion of a treatabilitystudy will be necessary to determine the effectiveness of one or more of the technologies underthe site conditions. It is assumed that treatability testing, which may include both bench andpilot scale studies, will be completed to aid in identification of the appropriate microorganisms,soil amendments, and plant species necessary to remediate the site.Site access and dewatering issues will be similar to those described for CMA-3, except that thesite will not need to be dewatered to the same depth because only limited excavation is plannedunder this alternative. As in CMA-3, water pumped from the site during dewatering activitieswill likely contain high levels of total suspended solids and will potentially contain someSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-17contaminants at levels of concern. Prior to its discharge this water will require testing andpossibly treatment (e.g., filtration).After site access and dewatering has been completed, the areas targeted for treatment will becleared or partially cleared of existing vegetation. In general, this activity will consist of handclearing and use of small equipment capable of tracking on soft ground. It may be advantageousto leave some of the vegetation and root mass in place for two reasons: the existing plants mayexhibit the phytoremediation characteristics desired for long-term use at the site, and the existingplant mass will help improve soil stability for construction equipment. Limited removal of treesis likely to be required throughout the bottom of the basin; however, the larger trees can be left inplace in order to meet USFWS goals for protection of bat habitat.At this time, the channel would be stabilized using a combination of geotextiles, vegetation, andriprap. Some limited excavation is anticipated to reduce the channel slopes and to help limithigh velocity flows around bends that would tend to cause bank cutting. The design willconsider appropriate surface treatments (e.g., geotextiles, vegetation, vegetated blanks and rolls,riprap, etc.) depending on estimated flow velocities at a given point.Depending on the results of the research, the biodegradation of the contaminants may occuraerobically, anaerobically, or in combination. Inoculated or indigenous cultures, along withnutrients and other soil amendments, will be introduced to the near surface soils and sediments toa depth of 12 to 24 inches. The cultures and nutrients could be applied by disking or tilling.Alternately, a shallow injection of a slurried mixture may be required in areas that are toounstable to till. Following the above site preparation, the selected plant species will beintroduced and established. Hand planting will likely be required in unstable areas. It may benecessary to eliminate some existing vegetation immediately prior to planting. This may be donethrough a controlled burn or an applied herbicide, as allowed by USFWS.For purposes of estimating O&M costs at this CMS stage, it has been assumed that sampling tomonitor the progress of the in situ treatment will be required for a period of ten years, theestimated duration of the treatment process. Since waste will be left in place beneath the treatedsurface, site visits and monitoring are assumed for the entire 30-year project life. Completion ofthe treatability study will set a more precise estimate for the treatment duration. If thetreatability study determines that in situ treatment will take significantly longer than ten years toachieve the corrective measures objectives, a replacement corrective measures alternative (i.e.,CMA-3, soil cover and dam modification) will be implemented as a contingency plan.3.3.5.2 Effectiveness-of CMA-5The dam modification and phytostabilization will limit the potential for migration ofcontaminated media caused by erosion and sedimentation processes. Treatment of contaminatedmedia through bioremediation, rhyzodegradation, and phytovolatilization is expected to decreasepotential exposures to contaminated media and to subsequently reduce potential ecological andhuman health risks. Although both technologies have been demonstrated to be effective, theircombined effectiveness at Jenny Lind Pond can not be predicted based on existing data. TheSECTIONTHREE Alternative DevelopmentQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 3-18design will require treatability testing to select and develop microorganism cultures, stands ofplants, soil nutrients and admixtures, and planting schemes.Short-term impacts due to construction of this alternative would be greater than the impactsassociated with dam modification and hotspot removal (i.e., CMA-2), but would be considerablyless than those associated with either the soil cover or the removal alternatives. Impact tohabitat, such as removal of forest cover, would be limited to the dam embankment, staging area,and selected areas of the site where other types of vegetation have been judged to provide greaterbenefit due to their phytoremediation characteristics. Areas cleared of vegetation will beimmediately replanted and any impact should not last longer than a single growing season.Periodic site inspections and maintenance of the vegetation, drainage channel, and dam will benecessary to maintain the protectiveness of this alternative. In addition to the surface water andsediment sampling outlined in CMA-2, additional sampling will be needed to document theprogress of treatment. It may be necessary to modify the treatment based on analysis of thesampling results. Modifications may include further inoculations of microorganisms and/ornutrients, as well as planting of different plant species.3.3.5.3 Implementability-of CMA-5The activities proposed for CMA-5 may present some technical difficulties, including thoseassociated with site accessibility and the identification of appropriate plant species. Difficultiesmay also arise when identifying microbes and the appropriate nutrients. This alternative isinnovative in that it would combine bioremediation with phytoremediation for treatment ofseveral types of chemical wastes; however, there is no record of proven reliability at similarsites. The use of plants to stabilize sites against erosion and sediment transport (i.e.,phytostabilization) is a proven and reliable technology that will be incorporated into the finaldesign. Treatability testing, which may include both bench-scale and pilot-scale testing, shouldbe completed before full-scale implementation.The construction activities can be implemented using traditional construction equipment andlabor. The required equipment, manpower, and materials are generally available locally.Stringent erosion control and dust control measures will be required during construction tominimize migration of contaminants during all earthwork activities.Administrative difficulties are the same as those described for CMA-2, and involve theprohibition of earthwork in a karst feature, the prohibition of removal of forest cover, and thelimitations on construction access between March 15 and October 31. Special approval fromUSFWS would be required to implement this alternative. If approved, close coordination withthe USFWS and IDEM will be required during the planning, construction, and reporting phasesof this alternative. Design of the dam modification will require the selection of a Design Flood,which may require input from DNR dam safety personnel. Long-term administrative oversightwill be required to maintain the land use restrictions and to oversee the monitoring andmaintenance of the constructed improvements.TABLE 3-1COMPARISON OF MAXIMUM CHEMICAL DETECTIONS TO TCLP1REGULATORY LIMITS USING 20 TIMES RULESITE 25 - JENNY LIND PONDMaximumResult(mg/kg)Max. Dividedby 20(mg/kg)TCLPRegulatoryLimit 2(μg/L)Reg. LimitTimes 20(mg/kg)Number ofDetections > 20Times Reg.LimitVOLATILE ORGANICS1,1-Dichloroethene < 7001,2-Dichloroethane < 5002-Butanone 0.1 0.005 200000Benzene 0.036 0.0018 500Carbon Tetrachloride < 500Chlorobenzene < 100000Chloroform < 6000Tetrachloroethene < 700Trichloroethene < 500Vinyl chloride < 200SEMIVOLATILE ORGANICS1,4-Dichlorobenzene < 75002,4,5-Trichlorophenol < 4000002,4,6-Tricholorphenol < 20002,4-Dinitrotoluene < 1302-Methylphenol < 2000004-Methylphenol < 200000Hexachlorobenzene < 130Hexachlorobutadiene < 500Hexachloroethane < 3000Nitrobenzene 0.298 0.0149 2000Pentachlorophenol < 100000Pyrene 7 0.35 5000PESTICIDES/PCBEndrin 0.018 0.0009 20gamma-BHC (Lindane) 0.0049 0.000245 400gamma-Chlordane 0.0085 0.000425 30Heptachlor 0.0068 0.00034 8Heptachlor epoxide 0.0026 0.00013 8Methoxychlor 0.4 0.02 10000Toxaphene < 500HERBICIDES2,4,5-TP (Silvex) < 10002,4-D < 10000METALSArsenic 27.8 1.39 5000Barium 301 15.05 100000Cadmium 2.1 0.105 1000Chromium 64 3.2 5000Lead 2310 115.5 5000 100 27 / 105Mercury 22.4 1.12 200 4 14 / 105Selenium 3.1 0.155 1000Silver < 5000Notes:1 TCLP = Toxicity Characteristic Leaching Procedure2 TCLP Regulatory Limits published in 40 CFR Part 261 Appendix IIChemicals with maximum results that exceed the 20 Times rule appear in boldface font and are outlined by a box border.Q:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 1 of 1 11/6/02TABLE 3-2INITIAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSSITE 25 - JENNY LIND PONDGeneral CorrectiveMeasure Technology Process Option Description ApplicabilityNo Action None None Do nothing to achieve corrective action objectives. Yes, as baseline for comparison purposes.Institutional Actions Land UseRestrictionDeed Restrictions Place restrictions on property deed to control future land use. Yes.Perimeter Fence Install fencing around contaminated areas to control site access. No. Method not effective in preventing access to ecologicalGrading and receptors.RevegetationGrade soils/sediments to develop positive drainage and revegetate withnative plant species to control erosion.Yes.Armoring Install rip-rap or other engineered surface over prepared subgrade toenhance erosion control, prevent resuspension of sediments during flooding,and reduce potential ecological contact with contaminated surfacesoils/sediments.Yes.Drainage ChannelImprovementsRealign drainage channel to eliminate braiding; install a liner and erosioncontrols to prevent the migration of contaminated sediment.Yes.Dam Rehabilitation Repair existing dam to stabilize dam using compacted soil, roller compactedconcrete, rock, or cyclopean concrete. May involve re-sizing spillway,depending on the Spillway Design Flood.Yes.Vegetated SoilCoverInstall 24 inches of soil over a pre-graded surface to reduce potentialecological contact with contaminated surface soils/sediments, enhanceerosion control, and reduce potential leaching to groundwater.Yes.Geomembrane Cap Install impermeable geomembrane barrier over contaminatedsoils/sediments to reduce potential ecological contact with contaminatedsurface soils/sediments, enhance erosion control, and reduce potentialleaching to groundwater.Yes.Multi-layered Cap Install cap consisting of impermeable barrier, drainage layer, and protectivecover layer over contaminated soils/sediments to reduce potential ecologicalcontact with contaminated surface soils/sediments, enhance erosion control,and reduce potential leaching to groundwater.No. Multi-layered cap will not provide additional protection overother types of covers given site conditions.Asphalt orConcrete CapInstall asphalt or concrete over contaminated vadose zone soils to reducepotential ecological contact with contaminated surface soils/sediments,enhance erosion control, and reduce potential leaching to groundwater.No. Asphalt/concrete cap typically used only where final land use isa parking lot.MechanicalExcavationExcavate contaminated soils and sediments from source areas for treatmentor disposal.Yes.Dredging Dredge contaminated soils and sediments from source areas for treatment ordisposal.No. Area can be dewatered to eliminate the need to dredge.Off-site RCRASubtitle D LandfillDispose of contaminated soil excavated from the source area in an existingoff-site Subtitle D (solid waste) landfill.Yes.Off-site RCRASubtitle C LandfillDispose of contaminated soil excavated from the source area in an existingoff-site Subtitle C (hazardous waste) landfill.Yes.Engineered Controls SurfaceEnhancementContainmentSoil/SedimantRemovalLandfill DisposalQ:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 1 of 3 11/6/02TABLE 3-2INITIAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSSITE 25 - JENNY LIND PONDGeneral CorrectiveMeasure Technology Process Option Description ApplicabilityOn-site Landfill Dispose of contaminated soil excavated from the source area in a newlandfill constructed on site or at the existing on-site landfill.No. New landfill is not compatible with future land use alternativesand existing landfill has been closed to further disposal.NaturalAttenuationAllow naturally occurring processes (e.g. dispersion, volatilization,biodegradation, adsorption, and chemical reactions) to reduce contaminantlevels.No. Natural attenuation processes may not occur at a sufficient rateto naturally reduce concentrations contaminants to acceptable levels.Composting Ex-situ treatment. Contaminated soil is excavated and mixed with bulkingagents and organic amendments such as wood chips, hay, manure, andvegetative (e.g., potato) wastes. Proper amendment selection ensureadequate porosity and provides a balance of carbon and nitrogen to promotethermophilic, microbial activity.No. Specifically used to remediate nitrocellulose fines.Phytoremediation In-situ treatment. Develop site and use plants to remove, transfer, stabilizeand/or destroy contaminants. Contaminants may be either organic orinorganic. Typically not effective on strongly sorbed contaminants, such asPCB.Yes, but it requires testing to define plant species and may notremediate soils as deep as two feet. Typically not effective at treatingPCBs.EnhancedBioremediationIn-situ treatment. The activity of naturally occurring microbes is stimulatedthrough the addition of nutrients or other amendments to enhance in situbiological degradation of organic contaminants or immobilization ofinorganic contaminants. Typically will have to be used in conjunction withanother technology to address metals.Yes.AcidExtractionEx-situ treatment. Soil is first segregated. Then an acidic solvent isintroduced to preferentially remove the metal contaminant while leavingnon-regulated metals intact. Metal-laden solvent is then treated to recoverthe metal contaminant for recycling.No. Higher clay content may reduce extraction efficiency andrequire longer contact times.ThermalDesorptionEx-situ treatment. Wastes are heated to volatilize water and organiccontaminants. A carrier gas or vacuum system transports volatilized waterand organics to the gas treatment system.Yes.Soil Flushing In-situ treatment. Water, or water containing an additive to enhancecontaminant solubility, is applied to the soil or injected into the groundwater to raise the water table into the contaminated soil zone. Contaminantsare leached into the ground water, which is then extracted and treated.No. Low permeability or heterogeneous soils are difficult to treat.Soil Washing Ex-situ treatment. Contaminants sorbed onto fine soil particles areseparated from bulk soil in an aqueous-based system on the basis of particlesize. The wash water may be augmented with a basic leaching agent,surfactant, pH adjustment, or chelating agent to help remove organics andheavy metals.Yes.Dehalogenation Ex-situ treatment. Reagents are added to soils contaminated withhalogenated organics. The dehalogenation process is achieved by either thereplacement of the halogen molecules or the decomposition and partialvolatilization of the contaminants.Yes, but process is limited to the chlorinated compounds.Treatment BiologicalPhysical/ChemicalQ:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 2 of 3 11/6/02TABLE 3-2INITIAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSSITE 25 - JENNY LIND PONDGeneral CorrectiveMeasure Technology Process Option Description ApplicabilitySolidification/StabilizationIn-situ treatment. Contaminants are physically bound or enclosed within astabilized mass (solidification), or chemical reactions are induced betweenthe stabilizing agent and contaminants to reduce their mobility(stabilization).Yes.Oxidation/ReductionEx-situ treatment. Oxidation/Reduction chemically converts hazardouscontaminants to non-hazardous or less toxic compounds that are morestable, less mobile, and/or inert. The oxidizing agents most commonly usedare ozone, hydrogen peroxide, hypochlorites, chlorine, and chlorine dioxide.No. Less effective against nonhalogenated VOCs and SVOCs, fuelhydrocarbons, and pesticides.Solvated ElectronTechnologyProcess uses alkali or alkaline earth metals dissolved in a variety of solventsto produce a solution of free electrons and metal cations. Ideally suited fortreating mixed wastes.Yes.Monitoring Site Monitoring Sampling andInspectionPeriodically sample soil, sediment, and/or surface water to evaluatepotential contaminant migration. Inspect the site for erosion and signs ofenvironmental stress.Yes.Treatment(Continued)Physical/Chemical(Continued)Q:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 3 of 3 11/6/02TABLE 3-3FINAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSSITE 25 - JENNY LIND PONDGeneralCorrectiveMeasure TechnologyProcessOption Effectiveness Implementability Relative Cost (1) Retain?No Action None None Does not address any corrective action objective. No action required. No capital.No O&M.YesInstitutionalControlsLand UseRestrictionsDeedRestrictionsLimits potential human exposures and future activities that maycause erosion of contaminated sediment through legally restrictingfuture land use. Does not reduce exposures to ecologicalreceptors.Feasible given site use and planned future use. Surveyand legal assistance required. Periodic future reviewsrequired.Low capital.Low O&M.YesGrading andRevegetationBeneficial for erosion and runoff control, but would leavecontaminants on the surface and may require additional correctiveaction to be effective. Reduces potential ecological exposures tocave resources caused by migration of contaminated sediment.Routine earthwork constructibility is easy after accessimprovements and dewatering. Requires Section 7 ESAconsultation for approval.Low capital.Low O&M.YesArmoring Provides significant protection against erosion and transport ofcontaminated sediment. Eliminates or reduces all potentialecological sediment-exposure issues. Would also result insignificant reduction of terrestrial ecological exposure potentialsdue to deep rooted plants and direct exposures to fossorialanimals.Routine earthwork constructibility is easy after accessimprovements and dewatering. Requires Section 7 ESAconsultation for USFWS approval.Low capital.Medium O&M.YesDrainageChannelImprovementsBeneficial to control surface water flow through basin, but wouldleave most contaminated sediment in place. Reduces exposedsurface area of contaminated sediment and aquatic foodwebexposure potentials.Routine earthwork constructibility is easy after accessimprovements and dewatering. Requires Section 7 ESAconsultation for USFWS approval.High capital.Low O&M.YesDamModificationPrevents sediment migration from basin but would leavecontaminated sediment in place. Controls flow of water throughthe basin. Reduces potential ecological exposures to caveresources caused by migration of contaminated sediment.Construction safety and difficult access will be majordesign issues. Requires Section 7 ESA consultation forUSFWS approval.High capital.Low O&M.YesVegetatedSoilCoverEliminates or reduces exposure in upper 24 inches of land.Eliminates aquatic foodweb exposures as well as potentialecological sediment-exposures. Would also result in significantreduction of terrestrial ecological exposure potentials to due deeprooted plants and direct exposures to fossorial animals.Routine earthwork constructibility is easy after accessimprovements and dewatering. Requires Section 7 ESAconsultation for USFWS approval.Medium capital.Low O&M.YesEngineeringControlsSurfaceEnhancementContainmentQ:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 1 of 3 11/6/02TABLE 3-3FINAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSSITE 25 - JENNY LIND PONDGeneralCorrectiveMeasure TechnologyProcessOption Effectiveness Implementability Relative Cost (1) Retain?GeomembraneCapEliminates or reduces exposure in upper 24 inches of land.Eliminates aquatic foodweb exposures as well as potentialecological sediment-exposures. Would also result in significantreduction of terrestrial ecological exposure potentials to due deeprooted plants and direct exposures to fossorial animals. Does notprovide a significant degree of additional protection over a soilcover for the added cost.Routine earthwork constructibility is easy after accessimprovements and dewatering. Requires Section 7 ESAconsultation for USFWS approval.High capital.Low O&M.NoRemoval MechanicalExcavationEliminates or reduces contaminant source material. Eliminatesaquatic foodweb exposures and all potential ecological sediment-exposures,with temporary destruction of aquatic community.Would also result in significant reduction of terrestrial ecologicalexposure potentials.Routine earthwork constructibility is easy. RequiresSection 7 ESA consultation for USFWS approval.Medium capital.No O&M.YesOff-siteSubtitle DLandfillEliminates or reduces potential for future release of contaminantsinto environment through controlled containment.Requires off-site transport and consumes landfill space. Low capital.No O&M.YesOff-siteSubtitle CLandfillEliminates or reduces potential for future release of contaminantsinto environment through controlled containment.Requires off-site transport and consumes landfill space. High capital.No O&M.YesPhytoremediation Eliminates or reduces contaminant mass through processesincluding phytoextraction, phytodegradation andrhizodegradation. Eliminates or reduces contaminant migrationthrough processes including phytostabilization. Eliminates orreduces potential for future release of contaminants intoenvironment through treatment and surface stabilization.Requires research to determine which plants can be usedfor rhyzoremediation and phytostatilization. The depthof the treatment zone is determined by plants used inphytoremediation. In most cases, it is limited to shallowsoils. Treatment may be seasonal. Some concern withanimal vectors.Low capital.Medium O&M.YesEnhancedBioremediationEliminates or reduces contaminant mass through biodegradationprocesses. Eliminates or reduces potential for future release ofcontaminants into environment through treatment.Requires research to determine appropriatemicroorganisms and enhancements that can be used tooptimize remediation. The depth of the treatment zoneis typically five feet or less. Treatment activity may beseasonal.Low capital.Medium O&M.YesDisposalTreatment BiologicalQ:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 2 of 3 11/6/02TABLE 3-3FINAL SCREENING OF REMEDIAL TECHNOLOGIES AND PROCESS OPTIONSSITE 25 - JENNY LIND PONDGeneralCorrectiveMeasure TechnologyProcessOption Effectiveness Implementability Relative Cost (1) Retain?ThermalDesorptionEliminates contaminant mass. Eliminates or reduces potential forfuture release of contaminants into environment throughtreatment.Commercially available process that requires minimaltreatability testing. Particle size and materials handlingrequirements that can impact applicability or cost atcertain sites. Heavy metals may produce a treated solidresidue that requires stabilization. Clay and silty soilsand high humic content soils increase reaction time as aresult of contaminant binding.High capital.No O&M.NoSoilWashingEliminates or reduces contaminant mass. Eliminates or reducespotential for future release of contaminants into environmentthrough treatment.Commercially available process that requires minimaltreatability testing. Complex waste mixtures (e.g.,metals with organics) make formulating washing fluiddifficult. High clay content will decrease effectiveness.High capital.No O&M.NoDehalogenation Eliminates or reduces contaminant mass. Eliminates or reducespotential for future release of contaminants into environmentthrough treatment.Commercially available process that requires minimaltreatability testing. High clay and moisture content willincrease treatment costs.High capital.No O&M.NoSolidification/StabilizationEliminates or reduces migration potential by immobilizingcontaminants within soil.Commercially available process that requires minimaltreatability testing. Eliminates all potential ecologicalexposures but also renders site uninhabitable forecological receptors for a significant period of time.The solidified material may hinder future site use.Plants will not grow in solidfied mass. Certain wastesare incompatible with different processes. Treatabilitystudies are generally required. Organics are generallynot immobilized.Medium to highcapital.No O&M.NoSolvatedElectronTechnologyEliminates or reduces contaminant mass. Eliminates or reducespotential for future release of contaminants into environmentthrough treatment.Commercially available process that requires minimaltreatability testing. Produce byproduct salts that may betoxic to ecological receptors.High capital.No O&M.NoMonitoring Monitoring Sampling andInspectionUseful to document site conditions and to evaluate potentialmigration and changes in concentrations with time. Necessary tomonitor effectiveness of any constructed corrective action.Technical staff and laboratories are readily available.Required for any action that leaves contaminants inplace.Low capital.Medium O&M.Yes(1) Relative cost presents subjective costs (high, medium, low) as compared to other process options within a particular technology group.Physical/ChemicalTreatment(Continued)Physical/Chemical(Continued)Q:\4599\fl010g00\inaap_cms_site 25 final\Site 25 Tables_rev1.xls Page 3 of 3 11/6/02SECTIONFOUR Feasibility Level Cost EstimatesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 4-1Cost estimates have been prepared to compare costs among the various corrective measurealternatives and to assist in making a site-specific risk management decision. The cost estimatesinclude capital costs, annual operation and maintenance (O&M) costs, periodic costs, a one-timefuture cost, and present worth cost as defined below:· Capital costs are expenditures required to construct or install the corrective measure.Capital costs include only the expenditures that are initially incurred to implement anaction, including engineering design and construction costs. Capital costs do not includethe costs required to operate and maintain the corrective measure throughout its lifetime.· Annual O&M costs are those post-construction costs necessary to ensure or verify thecontinued effectiveness of a remedial action. They include all labor, equipment, andmaterial costs associated with activities such as monitoring, site inspections, and repairsto constructed improvements.· Periodic costs are those post-construction costs that occur periodically (but not at anannual frequency). For this CMS, periodic costs include five-year review meetings heldto evaluate the overall effectiveness of the corrective measure.· The one-time future cost is the estimated expenditure necessary to investigate andremediate the downstream hotspot area. It includes construction and engineering costs.This estimate assumes this one-time cost will occur in the third year after the initialcorrective action implementation.· The present worth cost is the amount of money needed in the base year to cover thefuture costs associated with a particular time period at a particular interest or discountrate. Computation of the present worth cost allows for comparison of future costsdiscounted to a base year. For this CMS, a discount rate of 7 percent was used. The baseyear for the estimate is 2002.Contingency costs have been added to both the capital costs and O&M costs to help reduce therisk of possible cost overruns. Contingencies are used to cover unknowns, unforeseencircumstances, or unanticipated conditions that cannot be determined from the known data. Thetwo types of contingencies added are scope contingency and bid contingency. Scopecontingencies account for changes and refinements to the scope of work that occur during finaldesign as well as changes that may occur during construction. Scope contingencies includeprovisions for the inherent uncertainties in characterizing contaminated media volumes andextent. Bid contingencies cover unknown costs associated with construction or implementingthe project scope. Bid contingencies account for such items as the economic conditions at timeof bidding, weather conditions, material supply conditions, and geotechnical unknowns.Cost estimate summaries for CMA-2 through CMA-5 are provided in Tables 4-1 through 4-4.Cost worksheets for specific sub-elements of the various alternatives are provided in Tables 4-5through 4-16. Comments and/or assumptions used to develop the costs, along with quantityestimates, are listed for each line item within the cost estimate tables. The unit prices andgeneral cost estimating data were obtained based on cost estimating references (e.g., RS Means2001), cost estimates for similar work, vendor quotes, guidance documents, and engineeringjudgment. A comparison of costs among the various alternatives is provided in Table 4-17.SECTIONFOUR Feasibility Level Cost EstimatesQ:\4599\fl010g00\inaap_cms_site 25 final\jennylindpond_cmsrev1.doc\5-Nov-02 /OMA 4-2The cost estimates presented in this CMS are intended to provide an accuracy range of –30 to+50 percent of actual cost. The actual project cost will depend on actual labor and materialcosts, productivity, competitive market conditions, actual project scope and schedule, and othervariable factors. As a result of these factors, the actual project cost is likely to vary from theestimates provided in this study. Funding needs should be carefully evaluated, taking thesefactors into consideration before budgets are established.TABLE 4-1COST ESTIMATE SUMMARYCMA 2: DAM MODIFICATION WITH ICMSITE 25 - JENNY LIND PONDSite: Jenny Lind Pond (Site 25) CMS Description:Location: Charlestown, INPhase: CMSBase Year: 2002Date:CAPITAL COSTSDESCRIPTION QTY UNIT UNIT COST TOTAL NOTES/ASSUMPTIONSConstructionBaseline SamplingQuarterly Monitoring 4 LS $11,324 $45,294 See sub-elementInstall Sampling Station 3 EA $2,500 $7,500 Fiberglass or plastic basinSubtotal $52,794Site PreparationConstruction Staging Area 1 LS $31,000 $31,000 25,000 sf area, 6 crushed rockDewatering 20 DAY $250.00 $5,0004 dia. trash pump , 300 GPM, weekly discharge tests,filtration/settling basin downstream of dam, includeslaborErosion Controls 1 MO $1,000 $1,000 Silt fencing/bales and laborSubtotal $37,000Site WorkDam Rehabilitation 1 LS $55,707 $55,707 See sub-elementSubtotal $55,707Contractor Overhead and Profit 20% $29,100Construction Subtotal $174,602Contingency 30% $52,380 20% scope + 10% bidConstruction Total $226,982EngineeringProject Management 8% $18,159 % of construction totalPre-Design Investigation 1 LS $10,000 $10,000Institutional Controls 1 LS $5,000 $5,000 Survey and legal descriptionRemedial Design 15% $34,047 % of construction totalLong-Term Monitoring Plans 1 LS $20,000 $20,000 WP, QAPP, SSHP, Dam O&MConstruction Management 10% $22,698 % of construction totalEngineering Total $109,904TOTAL CAPITAL COST $336,886ANNUAL O&M COSTSDESCRIPTION QTY UNIT UNIT COST TOTAL NOTES/ASSUMPTIONSO&M ActivityAnnual Visit and Monitoring 1 LS $11,324 $11,324 See sub-elementDam Maintenance 1 LS $2,785 $2,785 5% of rehab costO&M Activity Subtotal $14,109Contingency 30% $4,233 20% scope + 10% bidO&M Activity Total $18,342EngineeringProject Management 10% $1,834 % of O&M activity subtotalTechnical Support 20% $3,668 % of O&M activity subtotalEngineering Subtotal $5,502TOTAL ANNUAL O&M COST $23,844Modify dam to control migration, restrict future landuse, and monitor.November 6, 2002Q:\4599\fl010g00\inaap_cms_site 25 final\Site 25 CMS Cost_rev1.xls Page 1 of 2 11/6/02TABLE 4-1COST ESTIMATE SUMMARYCMA 2: DAM MODIFICATION WITH ICMSITE 25 - JENNY LIND PONDSite: Jenny Lind Pond (Site 25) CMS Description:Location: Charlestown, INPhase: CMSBase Year: 2002Date:Modify dam to control migration, restrict future landuse, and monitor.November 6, 2002PERIODIC COSTSDESCRIPTION QTY UNIT UNIT COST TOTAL NOTES/ASSUMPTIONSFive Year ReviewsSite Visit and Meeting 1 LS $5,000 $5,000 4 people, 1 dayPlan Addenda 1 LS $5,000 $5,000 WP, QAPP, HSP (as found necessary)Subtotal $10,000Contingency (% of Sum) 30% $3,000 % of periodic costsTOTAL PERIODIC COSTS $13,000ONE-TIME FUTURE COSTQTY UNIT UNIT COST TOTAL NOTES/ASSUMPTIONSHotspot Removal 1 LS $331,271 $331,271 See sub-elementContingency (% of Sum) 30% $99,381 20% scope + 10% bidSubtotal $430,652Project Management 8% $34,452 % of subtotalConstruction Management 6% $25,839 % of subtotalTOTAL ONE-TIME COST $590,325PRESENT VALUE ANALYSISTOTAL TOTAL COST DISCOUNT PRESENTCOST TYPE YEAR COST PER YEAR FACTOR (7%) VALUE NOTESCapital Cost 0 $336,886 $336,886 1.0000 $336,886Annual O&M Cost 1-30 $715,319 $23,844 12.4090 $295,880One-Time Future Cost 3 $590,325 $590,325 0.8163 $481,882Periodic Cost 5 $13,000 $13,000 0.7130 $9,269Periodic Cost 10 $13,000 $13,000 0.5083 $6,608Periodic Cost 15 $13,000 $13,000 0.3624 $4,711Periodic Cost 20 $13,000 $13,000 0.2584 $3,359Periodic Cost 25 $13,000 $13,000 0.1842 $2,395Periodic Cost 30 $13,000 $13,000 0.1314 $1,708$1,721,000 $1,142,698PRESENT VALUE TOTAL $1,143,000DESCRIPTIONQ:\4599\fl010g00\inaap_cms_site 25 final\Site 25 CMS Cost_rev1.xls Page 2 of 2 11/6/02TABLE 4-2COST ESTIMATE SUMMARYCMA 3: SOIL COVER AND DAM MODIFICATION WITH ICMSITE 25 - JENNY LIND PONDSite: Jenny Lind Pond (Site 25) CMS Description:Location: Charlestown, INPhase: CMSBase Year: 2002Date:CAPITAL COSTSDESCRIPTION QTY UNIT UNIT COST TOTAL NOTES/ASSUMPTIONSConstructionGeneral CondtionsMobilization/Demobilization 1 LS $15,000 $15,000Submittals and Plans 1
Origin:	2002-11-07
Source:	http://indianamemory.contentdm.oclc.org/cdm/ref/collection/p15078coll17/id/33750
Collection:	Clark County Collections
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Geography:	Charlestown, Clark County, Indiana 38.4357546,-85.6577676
Subjects:	Maps Indiana Ordnance Works (U.S.) Hoosier Ordnance Plant Indiana Arsenal Indiana Army Ammunition Plant Explosives Industry--Indiana Gunpowder, Smokeless Ordnance manufacture Black powder manufacture Facility One ICI Americas Inc Clark County (Ind.) Charlestown (Ind.) United States. Army Ordnance and Ordnance Stores INAAP

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