* = 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 ontothe ground. The air levels measured on the landfill exceeded the upwind background levelsindicating that PCBs were being emitted into the air. The level of PCB identified in the airgenerally correlated with the number of exposed leaking capacitors. The higher concentrationswere measured at locations where more capacitors were visible. PCB concentrations were alsoobserved at sampling locations downwind of the landfill.

The airborne PCB concentrations varied with height; levels at 2 cm above the ground were 40 to100 times higher than the levels at an elevation of 180 cm.

The sampling took place during unseasonably warm, dry weather which probably maximized PCBemissions. 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. June1983.)

The EPA performed ambient air monitoring at Neal's Landfill after the interim remediation (seeFigure 21). This monitoring program was conducted to determine PCB levels in ambient air onand in the vicinity of the site. The sampling locations and methods used were the same asemployed 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. PCBconcentrations 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 spotson the site. (EPA. Draft project summary - ambient monitoring for PCBs after remedial cleanupof two landfills in the Bloomington, Indiana area. 1985.)

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 Landfillfor PCBs and other organic chemicals.

Monitoring wells were installed by both EPA and Westinghouse for the purpose of collectinggeologic and groundwater quality data and for measuring groundwater elevations from thelimestone bedrock aquifer. The data results for both the EPA and Westinghouse wells are nottruly comparable. This could be due to slightly differing depths, the wells being sampled atdifferent times, or the samples being analyzed by different laboratories. Non-detect sample andnot sampled readings were left in the tables for completeness of information. Table 29 lists thePCB sample results and Table 30 lists the maximum concentrations of specified organicchemicals. All sample locations are shown in Figure 22. (Westinghouse. On-site GroundwaterMonitoring Plan, Neal's Landfill. August 1987.)

ND = non-detect
NS = not sampled

* No comparison value available

Surface Water

The EPA and Westinghouse have investigated surface water features on and surrounding theNeal's Landfill site, including North and South Springs (groundwater resurgence points), and theoverflow springs of South Spring and Southwest Seep. Surface water was sampled and analyzedby both Westinghouse and the EPA in 1982 and 1983 for PCBs (Table 31) and other organicchemicals. The surface water channel that flows from Southwest Seep is known as SouthwestSeep 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 feetdownstream 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 phthalatewas found at 20 ppb at the north flume. N-nitrosodi-n-propyl was found at the Southwest Seepat 120 ppb. The analytical results for n-nitrosodi-n-propyl were not reproducible. It is thereforenot considered as a chemical of concern. All other sampling locations were non-detect fororganic chemicals.

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

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 ofRichland Creek, Conard's Branch, and Southwest Seep Branch in January and June 1983. PCBswere found above 1 ppm in 86 percent of the sediment samples from Conard's Branch and in 49percent 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 inBloomington conducted a well user survey of approximately 43 residential wells within 5,000 feetof the Neal's Landfill site. Samples were collected at faucets nearest to the well head for drinkingwater and were analyzed for PCBs. Documentation for the well user survey did not include alocation map of the residences sampled. Samples had a concentration range of non-detect to 7ppt. (Indiana University. Collection and Analysis of Drinking Water Well Samples for PCBContent. November 1986.)

Surface Water

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

* No comparison value available

In July of 1982, a field investigation was conducted by the EPA for Neal's Landfill. The purposeof this investigation was to determine the extent of groundwater contamination, thehydrogeology, 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 wereanalyzed by West Coast Technical Services and California Analytical Service for organic andinorganic chemicals (Table 33). PCBs were detected ranging from 3 to 7 ppb. Trichloroethylenewas also found at concentrations ranging from 34 to 56 ppb. (EPA. Field Investigations ofUncontrolled Hazardous Waste Sites Task Report. November 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 sitefrom the stream bed of the Northwest Spring, approximately 20 feet downstream from where thespring flow originates. The sample showed PCBs at 68 ppm. This data met all QA/QCrequirements. No map was provided with this data. (Environmental Protection Agency.Memorandum from Phyllis A. Reed, Environmental Emergency Investigation Branch. February24, 1981.)

On October 26, 1992, the IDEM and Westinghouse collected sediment samples from RichlandCreek and Conard's Branch for PCB analysis (Westinghouse. Memorandum to M. Pompeliaregarding 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. TheWestinghouse PCB analysis results ranged from below the detection limit to 21 ppm. No map orQA/QC was provided with these data. Results are shown in Table 34.

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 theS.R. 43 bridge in Owen County, and also near the S.R. 54 bridge east of Bloomfield in GreenCounty. 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 inMonroe County.

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

Fish samples in Indiana are routinely sampled for at least 20 parameters, PCBs, pesticides, andmercury. All other parameters were at normal low levels and did not represent a cause forconcern at the time. (ISDH. Memorandum from C.L. Bridges to D. Lamm regarding RichlandCreek Fish Survey. January 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 organsremoved. Concentrations in sediments are reported on a dry weight basis (Table 36). All aquaticlife PCB concentrations (except for snapping turtles) are listed under fish.

Corresponding water samples were taken for each fish and sediment sample (Table 36). PCBsranged from 0.1 to 8 ppb for all water samples. Two samples were taken at the Salt Lick locationof Richland Creek. PCB concentrations ranged from 3 to 5 ppm. PCB concentrations insediment samples ranged from non-detect to 320 ppm, and fish samples had PCB concentrationsof 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.)

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 16channel catfish, 25 longear sunfish, 11 creek chubs, and on one white sucker. The lower cage wasstocked with 16 channel catfish, 25 longear sunfish, and 12 creek chubs. Only fish exposed in thecages for 28 days were analyzed for PCBs (Table 37).

In 1989 the fish advisory for Richland Creek was lifted. An advisory is lifted from a body ofwater 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 wereconsidered deer browse. All samples were analyzed for PCBs. Controls were taken from areasother than Neal's Landfill and were all non-detect (Table 38). No map was provided with thisinformation. (U.S. Fish and Wildlife. 1983. PCBs in Neal's Landfill Plants.)

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 alwaysreproducible. Methylene chloride and acetone were field and laboratory contaminants. The dataon 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) showedcontamination with hepta dibenzodioxins and hepta dibenzofurans. The contamination wasattributed to possible use of dirty glassware. Sampled data were considered not affected, andblank subtraction was not recommended. The samples for tetra dibenzodioxin samples should notbe 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 samplingevent performed well. The QA data gathered during the study demonstrate that both the low- andhigh-volume methods yielded reliable, reproducible data, and that comparable results are obtainedby the two methods.

D. Physical and Other Hazards

Per the site visit on January 28, 1993, this site has several open, dilapidated structures and refuseon-site. This site is not accessible without a key to the front gate. There are no physical hazardsaccessible 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 materialsat this site. Air sampling was not done during these burn periods at the site. Prior to the on-siteinterim remediation of this site, PCB levels were measured at locations where capacitors wereleaking PCB fluids onto the ground. The level of PCBs identified in the air generally correlatedwith the number of exposed leaking capacitors. Air sampling downwind (north of fill area) of thelandfill revealed PCB concentrations. Ambient air contamination by leaking capacitors and openburning is considered to be a past completed exposure pathway through the inhalation route for landfill workers, scavengers, trespassers, and nearbyresidents. Ambient air is a present and future completed exposure pathway for nearby residents aslong 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 trespassingdid occur at this site (Stehr et al. 1986). PCB-stained soils were removed from the site during theinterim remediation. There is a past completed pathway for landfill workers, scavengers, andtrespassers 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 andthe vegetation that has covered the site.

On-Site Sediment

Before the interim remediation of Neal's Landfill, PCBs were found in sediment samples atconcentrations greater than 1 ppm. Sediments are materials that settle to the bottom of, or aresuspended in, a liquid. PCBs bind tightly to soil particles, thus its concentration can accumulateover 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 areconsidered 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 thechlorination, the longer it takes to be excreted by the body. Wild game forage in the brush on thesite. Accumulation of PCBs in their systems is very likely through ingestion of PCB-contaminatedsoil or water and/or animals. A study of dogs that roamed the Consent Decree sites documentedelevated 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 ofdeer 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 completedexposure pathways.

Off-Site Surface Water/Sediment

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

Swimmers, especially young children, could swallow water containing these sediments. Fishcaught and eaten from these waters may contain contaminated sediments (see Off-site Fish inCompleted and Potential Exposure Pathways). It is important to note that these chemicals arebound 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 sedimentsamples. 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 werefound in high enough concentrations in fish to cause concern to the local and state public healthofficials. The standard consumption limitation for a level 2 fish advisory of no more than ½pound 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 ofthe fish taken from Richland Creek. There is a past completed exposure pathway for allindividuals eating fish caught in Richland Creek prior to the fish advisory, or for individuals whoignored the fish advisory.

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

* 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 theirpotable water. On-site monitoring wells showed PCB concentrations of up to 9.8 ppb during the1992 sampling event. The nearest residential well is within a ½-mile radius of the site. Thedepths 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 systemby 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/NorthSpring area. It also discharges to the southwest of the site at the Southwest Seep, and Taylor andBranham Springs. The treatment water system at the site collects and treats water from the NorthSpring, South Spring, and Southwest Seep. This system is capable of reducing or eliminating thelevels 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 greaterthan the allowable level of less than 1 ppb, since the spring water treatment system is not able tohandle 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 usersthrough ingestion, inhalation, and dermal contact. PCBs have not been detected, however, abovethe 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 havebeen found at 7.7 ppb in sediment samples taken from the overflow basin of the spring treatmentplant. Water and sediment collected in the basin are fed to the spring treatment facility. Duringheavy rainfalls, the spring water treatment system is not able to handle the amount of waterflowing from the site.

Contaminated sediments are formed when chemicals bind to soil particles. PCBs bind tightly tosoil 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 accidentalingestion 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 eatenfrom these waters may contain contaminated sediments (see Off-site Fish in Completed andPotential Exposure Pathways). It is important to note that these chemicals are bound to soilparticles reducing the amount of human skin and stomach absorption considerably. The amountof sediment ingested during swimming is expected to be minimal.

Surface water and sediment are present and future potential exposure pathways for individualsparticipating 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 chemicalsat different rates. White suckers and catfish generally contain the highest concentrations ofcontaminants. This is due to their bottom feeding, scavenging habits. Certain fish in RichlandCreek 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 andwomen not contemplating pregnancy. All other adults and children should not consume thesefish. This advisory was lifted by the ISDH in 1989 due to a decrease in PCB levels found in fishtissues. There is a future potential exposure pathway for all individuals eating fish caught inRichland Creek if the sediments were to become re-contaminated due to overburdening of thespring water treatment system.

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