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1. ATSDR > Public Health Assessments & Consultations

PUBLIC HEALTH ASSESSMENT

Bloomington PCB Sites
Bloomington, Monroe County, Indiana
and
Spencer, Owen County, Indiana

NEAL'S DUMP (Owen County)

BACKGROUND

A. Site Description and History

Neal's Dump is in Owen County, Indiana (see Figure 1). The actual old fill area is relatively small in comparison with the other Consent Decree sites, being approximately 1/2 acre in area and 20 feet deep. The site served as a dumping ground by Westinghouse for capacitors, contaminated rags, and sawdust from 1966 to 1971. A preliminary health assessment was performed on this site by the ISDH in September of 1991. (IDEM. General Overview of Consent Decree Sites. July 1992.)

Interim Removal and Remedial Measures

In December 1983, Westinghouse removed surface capacitors and installed a clay cap and security fence as part of the Preliminary Remedial Action Settlement for Neal's Dump. During the preliminary remediation of the sites, in order to facilitate the fencing of the site, areas with stands of trees were included. Open areas where significant contamination existed were covered with a clay cap. The cap was subsequently seeded. Currently the site is covered with grass. Maintenance of the interim measures already in place, including surface drainage control and monitoring, are required of Westinghouse until removal and incineration.

At Neal's Dump, Westinghouse will excavate all solid waste plus an additional 2-foot buffer zone, which according to the Consent Decree will be incinerated.

Current Status

As of July 1992 there was no change in status.

B. Site Visit

On January 28, 1993, Ms. Dollis Wright and Mr. Garry Mills of the ISDH, and staff from IDEM and Westinghouse visited the Consent Decree sites. Observances made during the site visit to the Neal's Dump site are listed below.

1. Access to the site is restricted by a locked 6-foot chain-link fence, and warning signs are posted.

2. The site has a clay cap with vegetation. There are also areas within the boundaries of the site, adjacent to the cap, where trees are growing. An erosion control fence is also in place around the site.

3. The site has an accumulation of refuse (old appliances) throughout, probably from past illegal dumping. We were informed that this dumping occurred after the interim remedial measures were completed, but before the 6-foot chain-link fence was in place.

4. Five to six residences are located at the site boundary.

5. There is no gas venting on-site.

6. On-site monitoring wells were observed.

C. Demographics, Land Use, Natural Resource Use, and Environmental Setting

Demographics

Spencer, Indiana is approximately 4 miles north of the site with a population of 2,609. Private residences are within 1,000 feet of the site with the nearest residence being directly adjacent to the site. An estimated population of 954 is within a 3-mile radius of the site, and approximately 65 individuals reside within a ¼-mile radius of the site. The population in the site area is predominantly white.

Groundwater flow in the upper sandy silt unit is interpreted to be toward the northwest. Regional flow in the deeper sand aquifer is believed to be toward the west, and the White River is interpreted to be the discharge boundary for this unit.

Land Use

Neal's Dump is in a rural location. The primary land use in the area of the site is agricultural, although the site is located in a small residential area, which was built after the dump was closed. The nearest commercial/industrial area is more than 1 mile away, and the nearest recreational area is more than 2 miles from the site. The area around the site supports raccoons, opossum, white-tailed deer, squirrels, woodchucks, and rabbits.

Natural Resource Use

About 1,000 people within 3 miles of the site use well water. No municipal water source is available. There are 49 wells within 1 mile of the site. When the site was ranked in 1984, the closest residential well to the site was 750 feet. Currently, the closest private well is within 50 feet of the site.

Surface water runoff from the site and surrounding area flows in intermittent streams toward the west/northwest and drains into the floodplain prior to reaching the White River less than ¼ mile west of the site.

Environmental Setting

Neal's Dump is located on the top of a hill which slopes west toward the floodplain of the White River. Intermittent drainage ways are north and south of the site and flow west-southwest toward the White River.

There are three aquifers beneath the site. A shallow unconfined aquifer exists in the uppermost sandy silt unit at 12 to 15 feet below the soil surface. This aquifer flows from the site by the northern drainage ditch toward the northwest. The middle aquifer is located in the deeper sand unit at 37 to 45 feet below the soil surface. The deep aquifer is found in the last sand layer. The groundwater flow in the deepest aquifer is west toward the White River.

ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

A. On-site Contamination

Ambient Air

Between June and July 1983, EPA conducted a pre-cleanup on-site air monitoring study for PCBs at Neal's Dump (see Figure 15). Airborne PCB measurements were collected at two hot spot locations (A & B) where leaking capacitors were evident.

Battery operated, personal pump systems were used to sample during 8-hour, low-volume daytime periods at a fixed height (2cm and 180cm above ground level) above the hot spots and upwind locations. High-volume systems were employed to sample for 24-hour periods at the upwind and downwind locations.

The 8-hour low-volume period sample locations (A and B) detected a PCB concentration range of 1 to 61 µg/m³. The 24-hour high-volume samples detected a PCB concentration of 23-61 µg/m³.

In July 1984, EPA conducted an on-site post-cleanup air monitoring study for PCBs at the site. Airborne PCB measurements were collected at location A.

An 8-hour low-volume daytime and a 24-hour high-volume sampling period were conducted at location A. The 8-hour period detected a PCB concentration of 1 µg/m³. The 24-hour period detected a PCB concentration of 3 µg/m³. (EPA. Draft Final Report on Ambient Monitoring for PCB Near Three Landfills in Bloomington, Indiana Area. June 1983.)

Surface/Subsurface Soil

In June 1976 one on-site soil sample was collected by the ISDH near an exposed capacitor on the Neal's Dump site, and was analyzed for PCBs (see Table 22). The soil depth was not given; therefore, the sample is considered to be from surface soil. PCBs were detected at 12,500 ppm.

In November 1980, the EPA collected soil samples at Neal's Dump for total PCBs (see Table 22). Sampling was conducted around exposed capacitors, some of which had obvious PCB stained soils on the ground. Subsurface soil depths ranged from surface to in excess of 8 feet; or, intervals of 5 feet. Concentrations detected ranged from 8,000 ppm to 88,000 ppm (Westinghouse Electric Corporation, Pennsylvania. Bloomington Sites Soils Information. June 1986.; Westinghouse Electric Corporation, Pennsylvania. Surface Water and Ground-Water Analytical Information, Bloomington Sites, 1976-1983. October 1986.)

In May 1982, the EPA collected six samples at the site which were analyzed for PCBs, VOCs, and SVOCs (see Table 22). Three samples were collected from the corners of the site, while the remaining three were collected from the central exposed area of the site. (EPA. Draft Preliminary Report on Extent of Contamination at Neal's Dump. November 1982.)

Concentrations of total PCBs were detected throughout all the soil samples. Concentrations ranged from 4 to 19,000 ppm. Pyrene at a concentration of 0.3 ppm, and 2,4-dichlorophenol at 0.3 ppm were also detected. The concentration of pyrene and 2,4-dichlorophenol are below their respective comparison values. They are not considered to be contaminants of concern. All other chemicals detected were below the quantitation limit. (Westinghouse Electric Corporation, Pennsylvania. Bloomington Sites Soils Information. June 1986.; Westinghouse Electric Corporation, Pennsylvania. Surface Water and Ground-Water Analytical Information, Bloomington Sites, 1976-1983. October 1986.)

In April 1984, EPA conducted on-site post remediation soil borings at Neal's Dump for total PCBs (see Table 22). Discreet samples were taken from the following depth ranges: 0-21 feet, 0-15 feet, and 0-18 feet. All sample results showed PCBs at less than 1 ppm.

Table 22. On-Site PCB Soil Sample Results for Neal's Dump

Concentrations listed as one number indicate only a single sample at that location.

Groundwater - Monitoring Wells

Initial groundwater sampling was conducted by EPA at Neal's Dump in August 1982 (see Figure 16). Samples were analyzed for PCBs, VOCs, SVOCs, pesticides, and inorganic chemicals from the installation of seven monitoring wells (1 through 4). Wells 1 through 3 were installed in a nest of shallow and deep wells. Well 4 was installed as a deep well. Well depths ranged from in excess of 15 feet to in excess of 55 feet. All monitoring wells except 1 (shallow) are located downgradient of the site.

Sample results showed total PCBs at 31 ppb; bis(2-ethylhexyl)phthalate, at 11 ppb; endosulfan sulfate at 8 ppb; and zinc at 2,600 ppb. All were detected in well number 1 (shallow).

For verification of the August 1982 groundwater sampling of monitoring wells, samples were collected by EPA in September 1982 and analyzed for PCBs (see Figure 16). PCBs at 23 ppb were detected twice at shallow monitoring well location 1. All other monitoring well results were less than 1 ppb. (O'Brien & Gere. Report on Neal's Dump and Neal's Landfill Investigation. December 1982)

The sampling of on-site monitoring wells from May 1987 through November 1992 was performed semi-annually by Westinghouse as required by the Consent Decree to establish baseline PCB concentrations (see Figure 17). Four shallow wells (ND-1S, -2S, -5S, and -6B) and four deep wells (ND-1D, -2D, -4D, and -5D) comprise the monitoring network. As recommended in the Report of Investigations - Neal's Dump, Owen County, Indiana, April 1992, three (deep) additional monitoring well locations (EPA-B1 and -B2, ND-3D) were added to the existing well network from which samples are collected. The three additional monitoring well locations were included in the semi-annual sampling schedule. Well depths ranged from in excess of 17 feet to in excess of 55 feet. The shallow wells are screened in the upper unconfined sandy-silt aquifer zone, and the deep wells are screened in the lower confined sand aquifer zone. The groundwater flow direction in the upper unconfined sandy-silt aquifer zone is toward the west and northwest. The flow direction of groundwater in the lower confined sand aquifer zone is believed to be in this direction as well.

The environmental data for the on-site monitoring wells reflect the concentrations of PCBs detected from May 1987 through May 1993 (Table 23). All samples collected from the three additional deep monitoring wells (B1, B2, & 3D) were below the detection limit.

Table 23. On-Site Groundwater Monitoring Well PCB Sample Results for Neal's
Dump, May 1987 - May 1993

BDL = below detection limit of 0.1 ppb
ND = not detected at a level of 0.1 ppb
N/A = not applicable (well dry)
* = duplicate

Stream Sediment

In June 1976, one on-site stream sediment sample was collected by the ISDH from the bottom of a ditch leaving (north-northwest) Neal's Dump, and was analyzed for PCBs. PCBs were detected at 275 ppm. (Westinghouse Electric Corporation, Pennsylvania. Bloomington Sites Soils Information. June 1986.; Westinghouse Electric Corporation, Pennsylvania. Surface Water and Ground-Water Analytical Information, Bloomington Sites, 1976-1983. October 1986.)

B. Off-site Contamination

Ambient Air

Between June and July 1983, EPA conducted an off-site pre-cleanup air monitoring study for PCBs at the Neal's Dump site vicinity. PCB measurements were collected at two sample locations: 1) upwind near a mobile home south of the site area, and 2) downwind near a mobile home east of the of the site area. Battery operated, personal pump systems were used to sample during 8-hour low-volume daytime and 24-hour high-volume periods. The upwind, 8-hour sampling period detected a PCB concentration of less than 1 µg/m³. The upwind and downwind 24-hour sampling periods detected a PCB concentration of less than 1 µg/m³.

In July 1984, EPA conducted an off-site post-cleanup air monitoring study for PCBs at the site. PCB measurements were collected at two locations: 1) upwind near a mobile home south of the site area, and 2) downwind near a mobile home east of the site area. Sampling was conducted for 24-hour high-volume periods at both locations. The 24-hour upwind and downwind sample locations both detected a PCB concentration of less than 1 µg/m³. (EPA. Draft Final Report on Ambient Monitoring for PCB Near Three Landfills in Bloomington, Indiana Area. June 1983; EPA. Ambient Monitoring for PCB after Remedial Cleanup of Two Landfills in the Bloomington, Indiana Area. March 1986.)

Surface Soil

In January 1976, four off-site soil samples were collected by EPA at the Neal's Dump site, and were analyzed for total PCBs. All sample results were less than 0.001 ppm (Westinghouse Electric Corporation, Pennsylvania. Bloomington Sites Soils Information. June 1986.; Westinghouse Electric Corporation, Pennsylvania. Surface Water and Ground-Water Analytical Information, Bloomington Sites, 1976-1983. October 1986.).

In October 1981, EPA conducted follow-up sampling off-site to the on-site soil sampling in November 1980. No PCBs were detected. (EPA. Draft Preliminary Report on Extent of Contamination at Neal's Dump. November 1982.)

Groundwater - Residential Wells

In July 1991 (see Figure 18) and November 1992 (two wells only shown in Figure 19), Westinghouse collected water samples from 13 residential wells around Neal's Dump. A residential well sampling program was initiated because PCBs were found for the first time in seven of eight groundwater monitoring well samples obtained during the semi-annual groundwater monitoring sampling at Neal's Dump in May 1991. Additional follow-up samples confirmed the PCB contamination in the groundwater monitoring wells. (Westinghouse. Letter regarding residential well sampling. August 8, 1991.; Westinghouse. Ground Water Monitoring Report, Neal's Dump. December 1992.)

All residential well sample results, however, were below the detection limit of 0.1 ppb for PCBs.

Stream Sediment

In January 1983, EPA conducted stream sediment sampling of the north-northwest ravine stream for total PCBs. Samples were collected at 12 locations (#20-31); no PCBs were detected (Westinghouse Electric Corporation, Pennsylvania. Surface Water and Ground-Water Analytical Information, Bloomington Sites, 1976-1983. October 1986.).

C. Quality Assurance and Quality Control

The surface soil samples taken in 1982 showed inconsistent concentrations of methylene chloride and phthalates. These inconsistent concentrations were directly attributed to either field, bottle, or lab contamination; thus, those concentrations were not used.

D. Physical and Other Hazards

Per the site visit on January 28, 1993, Neal's Dump has refuse on-site which appears to be from past illegal dumping. The site does not pose a physical hazard and access is limited by the chain-link fence and a locked front gate.

PATHWAYS ANALYSES

A. Completed Exposure Pathways

On-Site Surface Soil

Before the interim remediation of Neal's Dump, soils on this site were visibly stained with PCBs. The site was accessible and active scavenging of scrap metal from PCB capacitors occurred on a regular basis. (Stehr et al. 1986) The on-site surface soil is a past completed exposure pathway for landfill workers, scavengers, and trespassers through incidental ingestion of contaminated soil, inhalation of contaminated air particles due to off-gassing of soils, and by dermal contact with PCB-contaminated soils during on-site activities.

Presently, surface soil is not a pathway for contaminants to enter the body. Much of the contaminated soil and all the capacitors have been removed. Erosion and surface soil runoff is currently controlled by a clay cap and silt curtains inside the fence line along the north, east, and west perimeters of the site. Access to the site is restricted by an 8-foot high fence with barbed wire.

Table 24. Completed Exposure Pathways for Neal's Dump

* Possibly exposed at all Consent Decree sites

B. Potential Exposure Pathways

Off-Site Groundwater

There is no municipal water supply to the area surrounding the site. All potable water is obtained from private wells. There are two aquifers below the site. Groundwater flow in the shallow aquifer is interpreted to be toward the northwest toward the northern unnamed drainage area. The deep aquifer is reported to flow toward the west and the White River. All private wells are located in the deep aquifer.

Samples from on-site monitoring wells from the deep aquifer have all had PCB levels below the EPA Public Drinking Water Standard of 0.5 ppb. Private wells have been monitored once a year from 1987 to the present. All sample results were below 0.1 ppb in May 1992.

PCBs were detected in the shallow aquifer at very high levels (240 ppb). Because of the high levels detected and the type of soils (silt and fine sand) present at the site, the presence of other organic chemicals in these soils could facilitate migration of contamination from the shallow to the deep aquifer. Off-site groundwater is a present and future potential exposure pathway for individuals using private wells for a potable water source.

Off-Site Surface Water/Sediment

Surface water drains west-southwest through a ravine and toward the White River, with some intermittent water drainage running north and south of Neal's Dump. The maximum concentration of PCBs found in samples taken from these ravines prior to any remediation was <1 ppm in the west-southwest drainage ditch and 275 ppm in the north-northwest drainage ditch.

The potential for surface water and sediment to be a pathway of exposure is decreased since the interim remediation. The implementation of erosion and surface soil controls by the placement of silt curtains inside the fence line, and a clay cap, reduces the potential for surface soil and sediment to migrate off-site. Surface water and sediment in the north-northwest and west-southwest ravines are past potential exposure pathways for hikers primarily through incidental dermal contact.

Table 25. Potential Exposure Pathways for Neal's Dump

NEAL'S LANDFILL (Monroe County)

BACKGROUND

A. Site Description and History

Neal's Landfill is in Monroe County, Indiana (see Figure 1). The site is approximately 18 acres in an area which was used as an industrial and municipal waste landfill from 1950 to 1972. The main fill area is approximately 150 by 300 yards. (IDEM. General Overview of Consent Decree Sites. July 1992.) The site was scored and included on the NPL in September 1983.

Interim Removal and Remedial Measures

In December 1983, Westinghouse removed surface capacitors and installed a clay cap, erosion control fences, a security fence, and drainage control trenches as part of the Preliminary Remedial Action Settlement for Neal's Dump and Neal's Landfill. During the preliminary remediation of the site, in order to facilitate the fencing, areas with stands of trees were included. Open areas where significant contamination existed were covered with a clay cap. The cap was subsequently seeded. Currently, the site is covered with grass. Maintenance of these measures are required of Westinghouse in addition to a sediment collection system for Conard's Branch, installation of additional erosion control fences, and posting of warning signs along Conard's Branch and Richland Creek.

Due to known VOCs existing in Neal's Landfill, IDEM conducted an area water well user survey to assure drinking water integrity. The wells involved in the survey and subsequent sampling were within a 5,000-foot radius of Neal's Landfill. The sample results showed no contamination of wells.

Westinghouse completed construction and began operation of the Neal's Landfill Spring Treatment System in February 1990. This water treatment facility was required under the terms of the Consent Decree to treat PCB-contaminated water discharging from three springs around Neal's Landfill into the Conard's Branch stream. Westinghouse was issued a National Pollutant Discharge Elimination System (NPDES) permit on July 1, 1988, by IDEM. This permit requires Westinghouse to operate a spring treatment facility, to sample the spring treatment facility influent and effluent twice a month, and to submit monitoring reports once a month.

The PCB discharge limit for this facility was set at 1 ppb pursuant to the Consent Decree. The owners of the property that the discharge stream crosses challenged this permit limit in court in May 1989 based on the current NPDES PCB discharge limit of 0.1 ppb. In April 1991, a Jackson Circuit Court judge ruled that IDEM is not bound by the PCB discharge limit set in the Consent Decree and ordered IDEM to reissue the NPDES permit following a new public hearing. Westinghouse appealed this decision in May 1991. On August 2, 1991, the Circuit Court judge ordered IDEM to reconsider the NPDES permit standards and to hold a public hearing while the Westinghouse appeal is being decided.

The IDEM conducted the NPDES public hearing in Bloomington on November 25, 1991. At the public hearing, a staff member of the U.S. Fish and Wildlife Service submitted a biological report entitled "PCBs in Richland Creek Downstream from Neal's Landfill, April 1991". This report summarizes the Service's cursory fish and sediment sampling effort in Richland Creek and Conard's Branch downstream of the Spring Treatment Plant.

The Fish and Wildlife Service report states that human health and the environment are not being adequately protected under the current NPDES permit limits and makes several recommendations for stricter NPDES permit limits. This report also recommends that IDEM implement a fish consumption study on Richland Creek downstream from Neal's Landfill.

On April 14, 1992, the Court of Appeals of Indiana denied the Westinghouse appeal of Judge Curry's decision. The IDEM must now issue a new NPDES permit that is not bound by the PCB limit set in the Consent Decree.

Westinghouse is also required to perform groundwater monitoring activities at Neal's Landfill to refine the knowledge of hydrogeologic conditions, to monitor the groundwater for PCBs, and to confirm remediation efforts. In January 1992 Westinghouse, in cooperation with all the Consent Decree parties, initiated a dye tracer study of the Karst aquifer at this site to determine groundwater flow patterns and if residential wells in the area are hydrologically connected to the site. Preliminary results indicate the largest amount of dye was recovered at North Spring and South Spring, which are part of the Neal's Landfill Spring Treatment System. Only one residential well of the approximate 39 monitored was found to have a possible hydrologic connection to the site. The EPA sampled this well for all priority pollutants including dioxins and furans. The IDEM is currently waiting for the final results of this study to be released.

The Indiana Supreme Court ruled in May 1993 that the 1 ppb PCB limit set in the Consent Decree is binding on IDEM.

Removal Measures

An estimated 320,000 cubic yards of material will be excavated for incineration by Westinghouse. Excavation at the headwaters of Conard's Branch to Richland Creek began in the summer of 1987. The Stream Bank and Stream Sediment Removal Project was completed in October 1988. Following the excavation project, sediment samples were taken above and below Conard's Branch in the Richland Creek stream bed. The analysis of these samples did not detect any PCBs.

Current Status

The IDEM staff requested the Biological Section of the Office of Water Management to review the Fish and Wildlife report and to conduct fish tissue sampling in Conard's Branch and Richland Creek downstream of Neal's Landfill to assess the possible human health risks associated with the consumption of fish from these areas.

The IDEM Superfund Section staff, in cooperation with the EPA, are evaluating the need to conduct additional sediment sampling in Conard's Branch and Richland Creek to assess whether or not these waterways have been re-contaminated by PCB-contaminated spring waters bypassing the spring treatment facility.

On October 26, 1992, the IDEM and Westinghouse collected sediment samples from Richland Creek and Conard's Branch for PCB analysis (Westinghouse. Memorandum to M. Pompelia regarding IDEM sediment sample results from Richland Creek and Conard's Branch. December 7, 1992). The IDEM samples showed PCBs ranging from below the detection limit to 12 ppm. The Westinghouse PCB analysis results ranged from below the detection limit to 21 ppm.

B. Site Visit

On January 28, 1993, Ms. Dollis Wright and Mr. Garry Mills of the ISDH, and staff from IDEM and Westinghouse visited the Consent Decree sites. Observances made during the site visit to the Neal's Landfill site are listed below.

1. Access to the site is restricted by a locked chain-link fence, and warning signs are posted.

2. The site has a clay cap with vegetation. There are also areas within the boundaries of the site, adjacent to the cap, where trees are growing. An erosion control fence is also in place around the site.

3. There was a surface water runoff collection system near the southwest surface water seep area. Per a conversation with Westinghouse staff, this system has underground pipes and a tank.

4. Several areas throughout the site had refuse on them (i.e., old appliances, tires).

5. Deteriorated and open former operations buildings had refuse inside.

6. Surface water areas at the Southwest Seep, North and South Springs, and Conard's Branch, including the spring treatment facility were seen.

7. The injection point locations for on-site dye testing were seen.

8. A white-tail deer was seen near the southwest seep area.

9. There were residences within ¼ to ½ mile of the site.

C. Demographics, Land Use, Natural Resource Use, and Environmental Setting

Demographics

Neal's Landfill is in a rural area. The population in the site area is predominantly white. Approximately 30-40 people live within a ½-mile radius of the site.

Land Use

Land use in the vicinity of the site includes 10-20 nearby residences approximately ¼ mile west and ½ mile north (hog farm) of the site. There is no apparent use of the wooded lands immediately adjacent to the site.

Natural Resource Use

There is no municipal water service to the immediate area surrounding the site; however, some residences in the vicinity of the site rely on residential groundwater well supplies. The hog farm north of the site receives water drainage (Conard's Branch) from Neal's Landfill.

Environmental Setting

Richland Creek is 1½ miles northwest of the site. The southwest seep branch and Conard's branch are two tributaries which flow from the site. Conard's Branch flows from the north and joins with the creek ¾ miles downstream. The southwest seep branch joins Richland Creek approximately 2 miles west of the landfill from the south.

The soils at Neal's Landfill consist of refuse, fill material, and silty clay ranging in depths from 0 to 31 feet. St. Genevieve Limestone formations underlie the soil. This limestone has the following features: sinkholes, swallowholes, solution cavities, caves, sinking or disappearing streams, and springs. It is composed of shale interbeds and chert beds. The bedrock at this site dips northwest which is contrary to the southwest regional trend. The water table is located at depths as low as 65 feet. The number and depths of aquifers below the site were not indicated in the data.

Groundwater recharge is through sinkholes, swallowholes, joint sets, and solution cavities that intersect the land surface in the area surrounding the site. Groundwater flow beneath the site discharges to the surface at springs located within valleys northwest and southwest of the site. The South and North Springs of Conard's Branch are resurgence points for groundwater originating at the site.

Discharges from the North and South Springs, and Southwest Seep are handled by the Westinghouse Spring Treatment facility during low-flow periods. During high-flow conditions (when combined, the total flow from the three springs exceeds 1 cubic foot per second); however, the overflow from the North and South Springs goes directly to Conard's Branch, and overflow from the Southwest Seep goes directly to the Southwest seep branch.

SITE ASSOCIATED SPRINGS AND SEEPS
- North and South Springs (NW)
- Southwest Seep (southern perimeter)
- Taylor and Branham Springs (SW)

ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

A. On-site Contamination

Multi-Media Contamination

In July of 1983 an evaluation of alternative remedial actions for PCB contamination at Neal's Landfill was prepared by EPA.

Before beginning the study, EPA undertook certain initial remedial measures to limit exposure or threat of exposure to public health or the environment. Remediation was initiated based on the observations listed below.

• There was an actual or direct potential contact with the PCB contaminant by the nearby population and local animal life.

• There was no effective drainage control system to prevent the runoff of PCB contaminants.

• Visible PCB-laden capacitors and capacitor paper, and PCB stained soils were present on the landfill site, at or above ground surface, which posed a serious threat to the public health and the environment.

• Conditions were such that normal rainfall events upon the landfill could cause the PCBs to migrate from the site and pose a threat to the public health and environment.

The results of the study are as follows:

• Monitoring wells adjacent to site showed PCBs at 9.8 ppb.

• Soil samples collected on-site showed PCBs at 219 ppm.

• Off-site stream sediment PCB levels in Conard's Branch and Richland Creek ranged from 0.002 to 0.07 ppm. PCB levels in water samples from Conard's Branch approached 1 ppb (excluding springs).

• Off-site samples of aquatic life from Conard's Branch and Richland Creek exhibited PCB levels as high as 1,118 ppm.

No Laboratory QA/QC data summary sheets or maps were attached to this information. (EPA. Remedial Alternative Assessment for Neal's Landfill. July 1983.)

Surface Soil

On November 3, 1980, the Environmental Emergency and Investigation Branch of EPA collected two soil samples. Samples were analyzed for PCBs.

The soil samples were taken around leaking capacitors. The depth of these samples was not reported. These samples are therefore considered surface soil samples. The PCB concentration range found in these two samples was 79,000 - 136,000 ppm. The data met all QA/QC laboratory requirements. A map was not provided with these data. (EPA. Letter From Phyllis A. Reed regarding data results for Neal's Landfill, Environmental Emergency Investigation Branch. February 24, 1981.)

On February 18, 1981, EPA conducted an inspection of Neal's Landfill. A survey of the area revealed PCB-filled capacitors, which represented an environmental threat to both surface and subsurface waters. No indication of any surface runoff was present in the area of the dump; the soil in the area consisted mainly of sand. Soil samples taken at the site showed PCB levels greater than 1,000 ppm (assumed to be surface samples as no depth was given). No laboratory data sheets or map were provided. (EPA. Memorandum to Ross Powers. February 19, 1981.)

On September 8, 1983, EPA collected six soil samples at Neal's Landfill for polychlorinated dioxin and dibenzofuran analysis (dioxins and furans). The first two soil samples were collected from the surface, and the remaining four were collected by digging a hole to a depth of approximately 8-12 inches. The last two samples were taken from areas of discolored, possibly charred, material/soil. All samples are considered to be surface soil samples as it was not possible to distinguish which samples were surface or subsurface. Congeners are chemical compounds that are closely related to one another by virtue of their chemical makeup and the effects they exert on each other as well as other chemicals. As certain chemicals share similar properties, they are assumed to produce similar health effects. A toxic equivalency factor is a number that has been assigned to a chemical that represents its relative degree of toxicity (ATSDR. Interim Procedures for Estimating Risks Associated with Exposure to Mixtures of Chlorinated Dibenzo-p-Dioxin and Dibenzofurans. 1989 Update). This number is then multiplied by the concentration of the chemical found in the media. The product is the toxic equivalency factor concentration. Concentrations for dioxins and furans are reported as toxic equivalency factor concentrations for 2,3,7,8-tetrachlorodibenzo-p-dioxin. The chemicals of concern in these soil samples are listed in Table 26. No map was provided with this information. (EPA. Transmitted information to H. Beard regarding field data, October 1984.)

Table 26. On-Site Surface Soil Sample Results for Dioxin
and Furan Congeners, Neal's Landfill, September 8, 1983

ND = non-detect
* = Toxic equivalency factor
** = Toxic equivalency factor concentration
*** = 2,3,7,8-tetrachlorodibenzo-p-dioxin

Subsurface Soil

On October 30, 1984, EPA collected an additional six soil samples at Neal's Landfill (see Figure 20) to determine dioxin and dibenzofuran contamination. Three samples were taken from the landfill (E09-E11) and a background sample (E12) was taken from a city park for baseline data comparison. Data are presented in Table 27.

In addition to the soil samples, three composite samples (E15 to E17) were collected from a borehole situated in the southeast portion of the fill area, approximately 150 feet south of the on-site road. Sample E15 comprised of soil from the upper 13 feet of the borehole, with no definite ash layers or burned material observed in any of the six split-spoon samples. Samples E16 and E17 were composites from materials collected from 13-28½ feet in nine separate split spoon samples. The boring was terminated at a depth of 28½ feet due to hitting the upper surface of the bedrock.

Three dioxin congeners were detected in these samples (Table 27): hepta, octa, and penta. Dibenzofurans were not detected in the soil boring samples. Background sample E12 did not detect any furans or dioxins. (EPA. Final report on dioxin sampling at Neal's Landfill and Lemon Lane Landfill. April 1986.)

Table 27. On-Site Soil Boring Sample Results for Dioxin, Neal's Landfill,
October 30, 1984

* = Toxic equivalency factor
** = Toxic equivalency factor concentration
*** = 2,3,7,8-tetrachlorodibenzo-p-dioxin

Ambient Air

Ambient air monitoring was performed at Neal's landfill prior to the on-site interim remediation.

PCB levels (Table 28) were measured at locations where capacitors were leaking PCB fluid onto the ground. The air levels measured on the landfill exceeded the upwind background levels indicating that PCBs were being emitted into the air. The level of PCB identified in the air generally correlated with the number of exposed leaking capacitors. The higher concentrations were measured at locations where more capacitors were visible. PCB concentrations were also observed at sampling locations downwind of the landfill.

The airborne PCB concentrations varied with height; levels at 2 cm above the ground were 40 to 100 times higher than the levels at an elevation of 180 cm.

The sampling took place during unseasonably warm, dry weather which probably maximized PCB emissions. Thus, the levels observed during this study may represent the "upper limit" of values. (EPA. Ambient monitoring for PCBs near three landfills in the Bloomington, Indiana area. June 1983.)

The EPA performed ambient air monitoring at Neal's Landfill after the interim remediation (see Figure 21). This monitoring program was conducted to determine PCB levels in ambient air on and in the vicinity of the site. The sampling locations and methods used were the same as employed in the interim remediation of the site conducted during June and July of 1983.

Sampling data from former hot spots were considerably lower than pre-remediation levels. PCB concentrations downwind of the site were comparable to pre-remediation levels. The results (Table 28) indicate the interim remedial cleanup reduced ambient PCB levels at former hot spots on the site. (EPA. Draft project summary - ambient monitoring for PCBs after remedial cleanup of two landfills in the Bloomington, Indiana area. 1985.)

Table 28. PCB Air Monitoring Data Pre- (1983) and Post-Cleanup (1985) for Neal's Landfill

cm = centimeter
LV = low volume
HV = high volume
* No comparison value available

Groundwater

From the fall of 1982 to the summer of 1983 groundwater sampling took place at Neal's Landfill for PCBs and other organic chemicals.

Monitoring wells were installed by both EPA and Westinghouse for the purpose of collecting geologic and groundwater quality data and for measuring groundwater elevations from the limestone bedrock aquifer. The data results for both the EPA and Westinghouse wells are not truly comparable. This could be due to slightly differing depths, the wells being sampled at different times, or the samples being analyzed by different laboratories. Non-detect sample and not sampled readings were left in the tables for completeness of information. Table 29 lists the PCB sample results and Table 30 lists the maximum concentrations of specified organic chemicals. All sample locations are shown in Figure 22. (Westinghouse. On-site Groundwater Monitoring Plan, Neal's Landfill. August 1987.)

Table 29. On-Site Groundwater PCB Sample Results for Neal's Landfill, 1982-83

ND = non-detect
NS = not sampled

Table 30. On-Site Groundwater Sample Results for Neal's Landfill, 1982-1983

* No comparison value available

Surface Water

The EPA and Westinghouse have investigated surface water features on and surrounding the Neal's Landfill site, including North and South Springs (groundwater resurgence points), and the overflow springs of South Spring and Southwest Seep. Surface water was sampled and analyzed by both Westinghouse and the EPA in 1982 and 1983 for PCBs (Table 31) and other organic chemicals. The surface water channel that flows from Southwest Seep is known as Southwest Seep Branch. Both Conard's Branch and Southwest Seep Branch flow into Richland Creek. Samples were taken from all locations listed on the table including a sample taken 500 feet downstream for Conard's Branch, which was non-detect for PCBs (see Figure 23).

Other organic chemicals were detected at two surface water sample locations. Diethyl phthalate was found at 20 ppb at the north flume. N-nitrosodi-n-propyl was found at the Southwest Seep at 120 ppb. The analytical results for n-nitrosodi-n-propyl were not reproducible. It is therefore not considered as a chemical of concern. All other sampling locations were non-detect for organic chemicals.

PCBs were found in the North and South Springs in low levels ranging from 1 to 10 ppb. Water samples collected from Conard's Branch and the seep areas contain detectable levels of PCBs ranging from 0.1 to 7 ppb. (Westinghouse. On-site Groundwater Monitoring Plan, Neal's Landfill. August 1987.)

Table 31. On-Site Surface Water PCB Sample Results for Neal's Landfill, 1982-83

Concentrations listed as one number indicate only a single sample at that location.
ND = non-detect
NS = not sampled

Stream Sediment Sampling

Westinghouse performed a stream sediment sampling and analysis program for the tributaries of Richland Creek, Conard's Branch, and Southwest Seep Branch in January and June 1983. PCBs were found above 1 ppm in 86 percent of the sediment samples from Conard's Branch and in 49 percent of the sediment samples from Southwest Seep Branch.

B. Off-site Contamination

Groundwater - Residential Wells

In November 1986, the Indiana University School of Public and Environmental Affairs in Bloomington conducted a well user survey of approximately 43 residential wells within 5,000 feet of the Neal's Landfill site. Samples were collected at faucets nearest to the well head for drinking water and were analyzed for PCBs. Documentation for the well user survey did not include a location map of the residences sampled. Samples had a concentration range of non-detect to 7 ppt. (Indiana University. Collection and Analysis of Drinking Water Well Samples for PCB Content. November 1986.)

Surface Water

On November 3, 1980, a sampling inspection was conducted by the EPA Environmental Emergency and Inspection Branch. All samples were analyzed for organic and inorganic chemicals, and PCBs. Sample results were all non-detect for organic chemicals. PCBs were present in two spring samples and one leachate sample at 3, 6, and 4 ppb respectively. The inorganic chemical sample results are listed in Table 32. The data met all QA/QC laboratory requirements. A map was not provided with this information. (Environmental Protection Agency. Letter From Phyllis A. Reed regarding data results for Neal's Landfill, Environmental Emergency Investigation Branch. February 24, 1981.)

Table 32. Off-Site Stream Surface Water Inorganic Sample Results,
Neal's Landfill, November 3, 1980

* No comparison value available

In July of 1982, a field investigation was conducted by the EPA for Neal's Landfill. The purpose of this investigation was to determine the extent of groundwater contamination, the hydrogeology, and the extent of buried materials at Neal's Landfill.

On July 28-29, 1982, six spring samples were collected (see Figure 24). All samples were analyzed by West Coast Technical Services and California Analytical Service for organic and inorganic chemicals (Table 33). PCBs were detected ranging from 3 to 7 ppb. Trichloroethylene was also found at concentrations ranging from 34 to 56 ppb. (EPA. Field Investigations of Uncontrolled Hazardous Waste Sites Task Report. November 1982.)

Table 33. Off-Site Spring Surface Water Organic and Inorganic Sample Results,
Neal's Landfill, July 28 & 29, 1982

Concentrations listed as one number indicate only a single sample at that location.
* No comparison value available

Sediment

On December 11, 1980, EPA collected an additional sediment sample for PCB analysis at the site from the stream bed of the Northwest Spring, approximately 20 feet downstream from where the spring flow originates. The sample showed PCBs at 68 ppm. This data met all QA/QC requirements. No map was provided with this data. (Environmental Protection Agency. Memorandum from Phyllis A. Reed, Environmental Emergency Investigation Branch. February 24, 1981.)

On October 26, 1992, the IDEM and Westinghouse collected sediment samples from Richland Creek and Conard's Branch for PCB analysis (Westinghouse. Memorandum to M. Pompelia regarding IDEM sediment sample results from Richland Creek and Conard's Branch. December 7, 1992). The IDEM samples showed PCBs ranging from below the detection limit to 12 ppm. The Westinghouse PCB analysis results ranged from below the detection limit to 21 ppm. No map or QA/QC was provided with these data. Results are shown in Table 34.

Table 34. Off-Site Sediment Sample Results for Richland Creek and
Conard's Branch, October 26, 1992

BDL = below detection limit
Concentrations listed as one number indicate only a single sample at that location.

Fish

In 1982, samples were collected about 3 miles downstream of the site in Richland Creek at the S.R. 43 bridge in Owen County, and also near the S.R. 54 bridge east of Bloomfield in Green County. The stream in the immediate vicinity of Neal's Landfill is quite small, and with the low-flow conditions at the time of the survey, it was not possible to collect fish tissue samples in Monroe County.

The results show abnormally high PCB levels (Table 35), especially at the upper station S.R. 43 bridge. The levels encountered were often in excess of the FDA action level of 2 ppm for the edible portion of fish.

Fish samples in Indiana are routinely sampled for at least 20 parameters, PCBs, pesticides, and mercury. All other parameters were at normal low levels and did not represent a cause for concern at the time. (ISDH. Memorandum from C.L. Bridges to D. Lamm regarding Richland Creek Fish Survey. January 1982.)

Table 35. Off-Site Fish PCB Sample Results, Neal's Landfill, January 20, 1982

In February of 1983, an analysis of aquatic life found in Neal's Landfill drainage was performed. Fish samples were analyzed as whole fish or edible portions with heads, scales, and internal organs removed. Concentrations in sediments are reported on a dry weight basis (Table 36). All aquatic life PCB concentrations (except for snapping turtles) are listed under fish.

Corresponding water samples were taken for each fish and sediment sample (Table 36). PCBs ranged from 0.1 to 8 ppb for all water samples. Two samples were taken at the Salt Lick location of Richland Creek. PCB concentrations ranged from 3 to 5 ppm. PCB concentrations in sediment samples ranged from non-detect to 320 ppm, and fish samples had PCB concentrations of non-detect to 280 ppm. The PCB concentration found in snapping turtles was 3 to 17 ppm. (U.S. Fish & Wildlife. Analyses of PCBs in Neal's Landfill drainage, Richland Creek, Fish, Snapping Turtles, plants, and caged fish. 1983.)

Table 36. Off-Site Drainage PCB Analyses Results for Neal's Landfill, February 2, 1983

ND = Non-detect

A caged fish study was performed by the U.S. Fish and Wildlife agency in September of 1982 (U.S. Fish & Wildlife. Analyses of PCBs in Neal's Landfill drainage, Richland Creek, Fish, Snapping Turtles, plants, and caged fish. 1983.). The upper cage was initially stocked with 16 channel catfish, 25 longear sunfish, 11 creek chubs, and on one white sucker. The lower cage was stocked with 16 channel catfish, 25 longear sunfish, and 12 creek chubs. Only fish exposed in the cages for 28 days were analyzed for PCBs (Table 37).

Table 37. Caged Fish Stock PCB Sample Results, Neal's Landfill,
September 1982

In 1989 the fish advisory for Richland Creek was lifted. An advisory is lifted from a body of water when two data samples show that the level of contamination is below the FDA guideline. (ISDH. 1989 Indiana Fish Advisory.)

Vegetation

In February of 1982, vegetation samples were taken at Neal's Landfill. These samples were considered deer browse. All samples were analyzed for PCBs. Controls were taken from areas other than Neal's Landfill and were all non-detect (Table 38). No map was provided with this information. (U.S. Fish and Wildlife. 1983. PCBs in Neal's Landfill Plants.)

Table 38. On-Site Vegetation PCB Sample Results for Neal's Landfill,
February 1, 1982

C. Quality Assurance and Quality Control

The groundwater and surface water organic chemical results showed the presence of heptachlor, n-nitrosodi-n-propylamine, carbon tetrachloride, 1,1 dichloroethane, trichlorofluoromethane, 1,1,-dichloroethylene, benzene, toluene, chloroform, ethylbenzene, and endosulfan sulphate; however, in most cases the concentrations are less than 100 ppb, and the analytical results were not always reproducible. Methylene chloride and acetone were field and laboratory contaminants. The data on these chemicals were deemed unacceptable for use in this report.

The field blank for the Neal's Landfill sampling for dioxin and furans (October 1984) showed contamination with hepta dibenzodioxins and hepta dibenzofurans. The contamination was attributed to possible use of dirty glassware. Sampled data were considered not affected, and blank subtraction was not recommended. The samples for tetra dibenzodioxin samples should not be used as there was no corresponding spiked sample. All other samples were considered valid.

The methodology employed to measure PCB levels in the ambient air during the 1983 sampling event performed well. The QA data gathered during the study demonstrate that both the low- and high-volume methods yielded reliable, reproducible data, and that comparable results are obtained by the two methods.

D. Physical and Other Hazards

Per the site visit on January 28, 1993, this site has several open, dilapidated structures and refuse on-site. This site is not accessible without a key to the front gate. There are no physical hazards accessible to the public.

PATHWAYS ANALYSES

A. Completed Exposure Pathways

On-site/Off-site Ambient Air

Nearby residents and scavengers reported open burning of trash and PCB-contaminated materials at this site. Air sampling was not done during these burn periods at the site. Prior to the on-site interim remediation of this site, PCB levels were measured at locations where capacitors were leaking PCB fluids onto the ground. The level of PCBs identified in the air generally correlated with the number of exposed leaking capacitors. Air sampling downwind (north of fill area) of the landfill revealed PCB concentrations. Ambient air contamination by leaking capacitors and open burning is considered to be a past completed exposure pathway through the inhalation route for landfill workers, scavengers, trespassers, and nearby residents. Ambient air is a present and future completed exposure pathway for nearby residents as long as there is PCBs present in the site associated springs.

On-Site Surface Soil

Before the interim remediation began, Neal's Landfill was accessible. Scavenging and trespassing did occur at this site (Stehr et al. 1986). PCB-stained soils were removed from the site during the interim remediation. There is a past completed pathway for landfill workers, scavengers, and trespassers through incidental ingestion and dermal contact with PCB-contaminated soil particles. This pathway does not presently exist due to the 2-foot thick clay cap in the primary fill areas and the vegetation that has covered the site.

On-Site Sediment

Before the interim remediation of Neal's Landfill, PCBs were found in sediment samples at concentrations greater than 1 ppm. Sediments are materials that settle to the bottom of, or are suspended in, a liquid. PCBs bind tightly to soil particles, thus its concentration can accumulate over time in sediment samples.

During scavenging activities or trespassing, individuals had dermal contact with PCB-contaminated sediment (Stehr et al. 1986). Sediment in the streams found on Neal's Landfill are considered to be past completed exposure pathway through dermal contact.

On- & Off-site Wild Game

Excretion of PCBs is slow, so accumulation occurs even at low exposure levels. The higher the chlorination, the longer it takes to be excreted by the body. Wild game forage in the brush on the site. Accumulation of PCBs in their systems is very likely through ingestion of PCB-contaminated soil or water and/or animals. A study of dogs that roamed the Consent Decree sites documented elevated serum PCBs in animals having contact with these sites. (Schillig et al. 1988).

Reports were made to the Monroe County Health Department regarding the illegal poaching of deer at the site. It was alleged that these deer were subsequently sold to local restaurants. Bio-accumulation of PCBs in these animals was very likely. Consumption of game such as deer, rabbit, raccoon, and squirrel that roamed Neal's Landfill are considered to be past completed exposure pathways.

Off-Site Surface Water/Sediment

Off-site sediment is a past potential exposure pathway for individuals participating in recreational activities in Richland Creek and Conard's Branch. Sediment samples taken from these areas prior to the interim remediation showed a maximum PCB contamination of 38 ppm. The sediment route of entry to the human body would be through incidental or accidental ingestion of stream sediment laden water and/or absorption of the chemicals through the skin.

Swimmers, especially young children, could swallow water containing these sediments. Fish caught and eaten from these waters may contain contaminated sediments (see Off-site Fish in Completed and Potential Exposure Pathways). It is important to note that these chemicals are bound to soil particles reducing the amount of human skin and stomach absorption considerably. The amount of sediment ingested during swimming is expected to be minimal.

Off-site Fish

PCBs bind tightly to soil particles, thus its concentration can accumulate over time in sediment samples. Bottom feeders or scavengers such as catfish or carp, due to their rummaging behavior, bioaccumulate contaminants through sediments over time.

In 1983, a level 2 fish advisory was issued by the ISDH on all fish in Richland Creek. PCBs were found in high enough concentrations in fish to cause concern to the local and state public health officials. The standard consumption limitation for a level 2 fish advisory of no more than ½ pound of fish per week was encouraged for adult males and women not considering pregnancy; and women of child bearing age and children under the age of 18 were warned not to eat any of the fish taken from Richland Creek. There is a past completed exposure pathway for all individuals eating fish caught in Richland Creek prior to the fish advisory, or for individuals who ignored the fish advisory.

Richland Creek is no longer on the fish advisory because the fish currently do not show contamination above the FDA action level.

Table 39. Completed Exposure Pathways for Neal's Landfill

* Possibly exposed at all Consent Decree sites
^a Nearby residents only

B. Potential Exposure Pathways

Off-Site Groundwater

Many private residences within a 5,000-foot radius of the site rely on private wells for their potable water. On-site monitoring wells showed PCB concentrations of up to 9.8 ppb during the 1992 sampling event. The nearest residential well is within a ½-mile radius of the site. The depths of the residential wells near the site, and the number and depths of aquifers below the site, were not provided in the reviewed data. Continuous overburdening of the water treatment system by heavy rainfall could potentially result in contamination of private wells in the area.

Groundwater underlying the site flows to the northwest and re-surges at the South Spring/North Spring area. It also discharges to the southwest of the site at the Southwest Seep, and Taylor and Branham Springs. The treatment water system at the site collects and treats water from the North Spring, South Spring, and Southwest Seep. This system is capable of reducing or eliminating the levels of PCBs in the groundwater before the water leaves the site under base flow conditions. During heavy rainfalls, there is a potential for the amount of PCBs leaving the site to be greater than the allowable level of less than 1 ppb, since the spring water treatment system is not able to handle the amount of water flowing during these conditions. It is important to note, however, that the maximum detected amount in the effluent of the treatment plant has been 0.22 ppb (sample taken 11/21/92), and PCBs have not been detected above the drinking water standard (0.5 ppb) for any private well sampling event.

Off-site groundwater is a present and future potential exposure pathway for all private well users through ingestion, inhalation, and dermal contact. PCBs have not been detected, however, above the drinking water standard (0.5 ppb) for any sampling event.

Off-Site Surface Water/Sediment

Sediments are materials that settle to the bottom of, or are suspended in, a liquid. PCBs have been found at 7.7 ppb in sediment samples taken from the overflow basin of the spring treatment plant. Water and sediment collected in the basin are fed to the spring treatment facility. During heavy rainfalls, the spring water treatment system is not able to handle the amount of water flowing from the site.

Contaminated sediments are formed when chemicals bind to soil particles. PCBs bind tightly to soil particles, thus its concentration can accumulate over time in sediment samples.

The sediment route of entry to the human body would be through incidental or accidental ingestion of stream water and/or absorption of the chemicals through the skin. Swimmers, especially young children, could swallow water containing these sediments. Fish caught and eaten from these waters may contain contaminated sediments (see Off-site Fish in Completed and Potential Exposure Pathways). It is important to note that these chemicals are bound to soil particles reducing the amount of human skin and stomach absorption considerably. The amount of sediment ingested during swimming is expected to be minimal.

Surface water and sediment are present and future potential exposure pathways for individuals participating in recreational activities in Conard's Branch and/or Richland Creek.

Off-site Fish

Fish species differ in diet, habitat, growth rate, and physiology. They also accumulate chemicals at different rates. White suckers and catfish generally contain the highest concentrations of contaminants. This is due to their bottom feeding, scavenging habits. Certain fish in Richland Creek may be contaminated with PCBs due to the accumulation of contaminants in the sediments.

In 1983, a level 2 fish advisory was issued by the ISDH on all fish in Richland Creek. Consumption of no more than ½ pound of fish per week was encouraged for adult males and women not contemplating pregnancy. All other adults and children should not consume these fish. This advisory was lifted by the ISDH in 1989 due to a decrease in PCB levels found in fish tissues. There is a future potential exposure pathway for all individuals eating fish caught in Richland Creek if the sediments were to become re-contaminated due to overburdening of the spring water treatment system.

Table 40. Potential Exposure Pathways for Neal's Landfill

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