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Drag Strip 60 Percent Design) Elkhart, Indiana 963063 Revision 3, Addendum 2 Final Design Report Conrail Railyard Superfund Site (Drag Strip 60 Percent Design) Elkhart, Indiana Submission Date: January 30, 2015 Prepared by: AECOM 525 Vine Street, Suite 1800 Cincinnati, OH 45202 On behalf of: Settling Parties: American Premier Underwriters, and Norfolk Southern Railway Company AECOM 513.651.3440 tel 525 Vine Street, Suite 1800 877.660.7727 fax Cincinnati, Ohio 45202 www.aecom.com January 30, 2015 Mr. Timothy Drexler U.S. EPA, HSRL-6J 77 West Jackson Blvd. Chicago, IL 60604-3590 Subject: Revision 3, Addendum 2 Final Design (Drag Strip 60 Percent Design), and Response to EPA Comment Letter dated November 4, 2014 Second Remedial Design / Remedial Action Conrail Railyard Superfund Site Elkhart, Indiana Dear Mr. Drexler: On behalf of the Settling Parties, Norfolk Southern Railway Company (Norfolk Southern) and American Premier Underwriters (APU)1, AECOM2 is providing the referenced submittal, referred to as the Drag Strip 60 Percent Design, to the United States Environmental Protection Agency (EPA). The Drag Strip 60 Percent Design addresses EPA comments dated July 11, 2014. The Settling Parties previously responded to the July 11, 2014 EPA comments and developed a key element of the Drag Strip design in, “Response to EPA July 11, 2014 Comments, and Technical Memorandum: Intermediate Remediation Goal (IRG) Calculation, Conrail Railyard Superfund Site, Elkhart, Indiana,” dated September 19, 2014 (IRG Tech Memo). EPA provided comments dated November 4, 2014 regarding the Settling Parties’ IRG Tech Memo submittal. On December 3, 2014, EPA, Indiana Department of Environmental Management (IDEM), S.S. Papadopulos and Associates (SSPA), the Settling Parties, and AECOM discussed the EPA November 4, 2014 comments letter and the Settling Parties’ initial responses. In addition to transmitting the Drag Strip 60 Percent Design, this letter provides the Settling Parties’ formal responses to EPA’s November 4, 2014 comments letter. To assist in your review, quotations from the EPA comments letter dated November 4, 2014 are presented in boldface italic type with the Settling Parties’ comments in plain-type text. 1. We consider that your responses, pending conclusive results obtained from the microcosm studies, are adequate and sufficient for moving forward with field- scale pilot testing, as soon as possible. Therefore: • We accept the IRG calculation methodology, however, consistent with previousEPAcomments,datafrom and and Drag Strip West Source Area monitoring wells should be excluded from the attenuation factor calculation; the IRGs calculated while excluding these data are 53.2 ug/L for CT and 14 ug/L for TCE; 1 Pursuant to the Consent Decree regarding the Conrail Rail Yard Superfund Site between the EPA, Consolidated Rail Corporation (Conrail) and American Premier Underwriters, Inc. (APU), dated November 10, 1997, the “Settling Parties” are Conrail and APU. Norfolk Southern Railway Company (Norfolk Southern) is performing certain environmental Activities at the site under the Consent Decree on behalf of Conrail. As such, for purposes of this correspondence, “Settling Parties” refers to Norfolk Southern on behalf of Conrail and APU. 2 URS Corporation (URS) has merged with AECOM, and URS is a wholly-owned subsidiary of AECOM. Mr. Timothy Drexler U.S. EPA, HSRL-6J January 30, 2015 Page 2 1. EPA’s previous comment is “General Comment 1.b” from the July 11, 2014 Letter: “The proposed VISL calculation method uses grouped groundwater and residential air COC concentrations; however, some of the wells identified to be used (MW-38S, DSMW-03, MW- 56S) are near/within the West Source Area, and may have groundwater concentrations that are higher than those that actually underlie the residences. This will produce groundwater-to- air attenuation factors that are potentially high (i.e. not conservative), and therefore less protective.” As the Settling Parties have already stated to EPA in the September 19, 2014 IRG Tech Memo, these buildings are less than 150 ft. from wells and are therefore useable as data pairs, per the approved Vapor Monitoring Plan. Also, EPA is extrapolating a lower concentration beneath the buildings without any basis and using that uncertainty as rationale for rejecting valid data pairs for these buildings. With this logic, all data pairs would need to be rejected because none of the wells are located within buildings. EPA expressed concern that the wells’ proximity to source areas made the groundwater data unrepresentative and introduced bias that is not protective of human health or the environment. The Settling Parties stated that the phenomenon being characterized is constituent concentration attenuation between shallow groundwater and indoor air, which is wholly dependent on observed concentrations from valid data pairs and only indirectly related to proximity to sources. The Settling Parties stated that rejecting these data based on perceived bias mischaracterizes the phenomenon that is taking place in the Vistula neighborhood, and that they have worked diligently to describe since monitoring began in 1998. The Settling Parties informed EPA that the extensive and valuable data record from these two buildings and three monitoring wells represents a significant proportion (53 percent) of the sample data available for this analysis. Furthermore, the EPA-required use of the 95th percentile statistic is inherently a biased approach because it considers only the most conservative (upper) tail of the distribution instead of the mean, which is an acceptable method for evaluations of risk. Following the December 3, 2014 conference call and in the interest of maintaining progress with the Drag Strip remedial design, the Settling Parties agreed to remove the two buildings from the analysis and to use the revised IRGs required in EPA’s November 4, 2014 letter. The IRG Tech Memo has also been revised and is provided in the attached Drag Strip 60 Percent Design. 2. You should now submit, for EPA and IDEM approval, a Target Zone based on the 95% upper confidence limit of the mean (UCL) concentrations of CT and TCE measured in samples from shallow wells over the last 2 years (March 2012-March 2014) to serve as a basis for remedial design, using the current monitoring well network and the updated IRGs; 2. During the December 3, 2014 conference call, the Settling Parties reminded EPA that requiring Target Zone establishment before the delineation task is inconsistent with the approach proposed in Revision 2, Addendum 2 Final Design Report, dated May 16, 2014 (30 Percent Design), “Additional delineation of COCs is needed at the Drag Strip in order to refine the current treatment area footprint.” In order to accurately characterize nature and extent, the delineation task is needed. In particular, plume geometry is needed in order to focus the pilot testing on the plume core while accommodating EPA’s GCW operational requirement during pilot testing. EPA agreed that the delineation task is necessary to establish the Target Zone, and EPA understands that access to the Drag Strip property is necessary to perform the delineation task. Revision 3, Addendum 2 Final Design Report Table of Contents Table of Contents Acronyms .......................................................................................................................................................iv Executive Summary........................................................................................................................................iv 1.0 Introduction ..........................................................................................................................................1 1.1 Purpose: Revision 3 Addendum 2 to Final Design ....................................................................1 1.2 Report Organization...................................................................................................................2 2.0 Background to Drag Strip Final Remedy Selection..............................................................................3 2.1 Regulatory History.....................................................................................................................3 2.1.1 Drag Strip Pilot-Phase Remedy .................................................................................4 2.1.2 Third Five-Year Review............................................................................................5 2.1.3 Railyard Remedy Upgrade.........................................................................................6 2.1.4 Drag Strip Remedy Finalization Activities................................................................7 2.1.4.1 Drag Strip Remedial Action Objective-2011.............................................................8 2.1.4.2 Previously-Proposed Drag Strip Remedy and Performance Metrics.........................8 2.1.4.3 EPA Response to Proposed Approach.......................................................................8 2.1.4.4 Technical Rebuttals....................................................................................................9 2.1.4.5 Revised Drag Strip Contingency Remedy ...............................................................10 2.1.5 Drag Strip Access Prohibition .................................................................................11 3.0 Conceptual Site Model (CSM) ...........................................................................................................13 3.1 Environmental
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