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PUBLIC HEALTH ASSESSMENT

REILLY TAR & CHEMICAL CORPORATION
(INDIANAPOLIS PLANT)
INDIANAPOLIS, MARION COUNTY, INDIANA


SUMMARY

The Reilly Tar & Chemical Corporation site (currently named Reilly Industries, Inc.) is in Indianapolis Indiana. The site is 120 acres in size and includes a portion of two parcels of land referred to as Oak Park and Maywood. The Oak Park parcel is next to a residential area in which a health study was conducted (Bennington & Steele 1986). Reilly Industries produces pyridine, niacinamide, vinyl pyridine, and alkyl pyridines. It also has a drum cleaning operation on site.

Currently, the site poses an indeterminate public health hazard because the data do not indicate that people are being exposed to levels of contamination that would be expected to cause adverse health effects. However, data are not available on off-site surface soils and ambient air to which people are exposed.

The site did pose a public health hazard in the past to individuals who drank contaminated groundwater from their private wells. The off-site groundwater is contaminated, but is not now used for drinking purposes. The neighborhood surrounding the site is supplied water from the municipal water system and is not exposed to the contaminated groundwater unless they use private wells for domestic purposes.

Citizens are concerned with the health risk posed by the site through drinking water and ambient air. Detailed answers to these concerns appear in the Public Health Implications section of this public health assessment.

An epidemiologic study of individuals near the site did not reveal an excess amount of medical problems or conditions different from other individuals residing in the surrounding community. The primary mechanism by which contaminants migrate off-site is groundwater (northwest to southeast).

In accordance with past Agency for Toxic Substances and Disease Registry (ATSDR) recommendations, and the Record of Decision (ROD) signed in June 1992, the Indiana State Department of Health (ISDH) recommended the following: 1) remedial actions be taken to collect off-site surface soil samples at depths of 3 inches or less; 2) remedial actions be taken to prevent any further migration of the groundwater plume from the site; 3) actions be taken to protect industrial workers from exposure to volatilized chemicals at industries which lie in the direction of the groundwater plume; 4) actions be taken to prevent the use of groundwater for drinking and other domestic purposes by neighboring residents and/or industries; 5) provide on-site workers with adequate protective equipment and training in accordance with 29 CFR 1910.120; and 6) monitor the site and its perimeter ambient air for the presence and transport of contaminants of concern.

Because some exposure may still be occurring via ambient air or surface soil and since there have been reports of transitory health effects from exposure to ammonia in the ambient air, the ATSDR Health Activities Recommendation Panel recommends consideration of personal air monitoring correlated with ambient air monitoring.

BACKGROUND

A. Site Description and History

The Reilly Tar & Chemical (Indianapolis Plant) site, currently named Reilly Industries, is at 1500 S. Tibbs, Indianapolis, Indiana. The site is 120 acres in size and includes a portion of two parcels of land referred to as Oak Park and Maywood. The site is divided between these two areas by Minnesota Street. The Oak Park parcel is next to a residential area in which a health study was conducted. This health study will be discussed later in this public health assessment. Reilly Industries currently employs about 500 people.

Approximately 50% of the Reilly Industries property is covered with buildings and chemical processing units such as tanks and stills. The site is fenced, and is accessible only to authorized personnel. The southern most end of the site contains no buildings or operating chemical processes, but was formerly the site of chemical processing and wood preserving activities. This portion of the site currently contains four waste disposal areas which have been the subject of investigation.

Reilly Industries produces pyridine, niacinamide, vinyl pyridine, and alkyl pyridines (alpha picoline, beta picoline, and gamma picoline). These chemicals are produced using feedstocks of ammonia, acetaldehyde, formaldehyde, methanol, caustic soda, and sodium.

Reilly Industries has a drum cleaning operation where drum residue travels through the sewer system to the Reilly wastewater treatment plant where it is heated and followed by discharge under permit to the city of Indianapolis at the Belmont Street domestic sewage treatment plant. Drums are cleaned at other stations prior to being transported to the drum cleaning facility. Drums that are not usable are transported off-site to a drum recycler.

Problems at the site include contamination of groundwater with benzene, pyridine, picolines, and ammonia; and migration of the contaminated water to nearby industrial supply wells. On-site soils are suspected of being contaminated with chemicals that are products and byproducts of past coal tar refining, wood preservation processes, and pyridine production.

Industrial development of the site began in 1921 when the Republic Creosoting Company started a coal tar refinery and a creosote wood treatment operation on the Maywood property. The refinery used coal tar to make a variety of products. The coal tar was refined by a process known as distillation. Products from the distillation included various grades of tars (eg., coal tar), oils (eg., creosote oil), and pitches (eg., electrode pitch). The wood preserving operations were along the railroad tracks on the Maywood property. The plants operated from 1921 to 1972.

Beginning in 1941, several chemical plants were constructed on the Oak Park property including the Pilot Plant, Little Oxidation Plant, and the Fine Chemicals Plant. In 1980, the Specialty Chemicals Plant was constructed on the northern portion of the Maywood property. The Specialty Chemical Plant carries out batch synthesis of pyridine and pyridine derivatives. One change since 1985 is that 4-vinylpyridine is no longer manufactured on the Maywood property. The production facility has been dismantled. This product is currently being manufactured in the same production facility as 2-vinylpyridine on the Oak Park property.

Beginning in the mid 1950s, the Indiana Department of Environmental Management (IDEM) and the Indiana Stream Pollution Control Board responded to complaints concerning odors and wastewater disposal practices at the site. In 1955, 2-picoline, a chemical manufactured by Reilly Industries, was detected in nearby residential wells east of the site. In August of 1955, analysis of private residential wells along Centennial Street indicated the presence of pyridine and ammonia in the part per million (ppm) levels. Water from these wells was rendered unfit for human consumption, forcing those residents to establish water connections with the Indianapolis Water Company facilities. In May, June, and July of 1964, three contaminants, pyridine, 2-picoline, and ammonia were detected in off-site groundwater samples taken east of the site and in a few on-site surface water samples. In 1980, on-site soil samples were found to contain several organic chemicals including toluene and trichloroethylene. About 60,000 gallons of waste fuel were accidentally released on the Oak Park pond in 1987. The released fuel oil was recovered and the contaminated soil was excavated by Reilly Industries.

In 1986, the Marion County Health Department (MCHD) conducted a survey to determine the extent and type of water use from private wells in the Oak Park and Maywood neighborhoods. Of the 400 residences contacted, 21 had both city water and private wells; nine households relied entirely on groundwater supplemented with bottle water for drinking; and three commercial establishments relied on groundwater or groundwater supplemented with bottled water for drinking. The continued groundwater contamination has forced the MCHD to condemn additional residential and industrial wells located within the confines of the contaminated aquifer. Although not used for drinking water purposes, some of the private wells may still be used for watering lawns and gardens. It was reported by some residents that, in a few instances, this practice resulted in dead or distressed vegetation due to the level of contamination in the groundwater.

At the recommendation of the state, the U.S. Environmental Protection Agency (EPA) proposed the site for inclusion on the National Priorities List (NPL) in September 1983 (final date for placement on the NPL was September 1984). In March 1987, through an EPA Consent Order, Reilly Industries agreed to conduct a Remedial Investigation (RI) to characterize the nature and extent of contamination at the site, and to undertake a Focused Feasibility Study (FFS) to evaluate and recommend cleanup alternatives. That same year, the EPA conducted a survey of industrial and commercial facilities located within 1 mile of the site. The purpose of the survey was to obtain information that would allow EPA to distinguish between site-related chemicals and off-site chemicals. The survey found 10 facilities with wastes similar to the chemicals at the site.

In January 1989, the Agency for Toxic Substances and Disease Registry conducted a preliminary health assessment for the site. Based on available information, the site was considered to be of potential public health concern because of the risk to human health caused by the possibility of exposure to hazardous substances via contaminated groundwater, soil, surface water, sediment, and air. There were no data available with which to evaluate and rate pathways in terms of importance.

Recommendations made at that time included evaluating the current levels of contamination in the media noted above, identifying other pathways of concern, locating any groundwater plumes, evaluating the extent of public contact with the site, undertaking a well survey to identify all potential users of local groundwater, and re-sampling all known private wells for current contamination levels. Further environmental characterization and sampling of the site and impacted off-site areas during the RI/FFS was recommended to address the environmental and human exposure pathways discussed above.

The RI was conducted in three phases between 1988 and 1990 (EPA Remedial Investigation). Those phases consisted of (Phase I) off-site investigations, (Phase II) on-site investigations, and (Phase III) additional investigations both on-site and off-site. Work conducted during the RI included soil sampling, surface water sampling, and groundwater sampling.

The EPA directed Reilly Industries to conduct a FFS with a focus on the groundwater as an operable unit (an action taken as part of an overall site cleanup) after reviewing the risk assessment for the site (CERCLA Revised RI Report and RCRA Final Phase III Release Characterization Report). The purpose of segmenting a site cleanup into operable units is to accelerate certain portions of the cleanup to remedy a more immediate threat to human health or the environment.

The purpose of the FFS (November 1991) is to develop and evaluate alternatives to prevent further off-site movement of contaminated groundwater (Focused Feasibility Study, November 1991). The EPA examined four cleanup alternatives for the groundwater operable unit at the site:

    Alternative 1:
    No action
    Alternative 2:
    In-situ (in place) bioremediation
    Alternative 3:
    Groundwater extraction, treatment, and discharge
    Alternative 4:
    Fully encircling slurry wall, groundwater extraction, treatment, and discharge

The EPA proposed groundwater cleanup alternative #4, but after the public comment period (January 16-February 1992) was extended to March 31, 1992, Alternative #3 was selected. The Record of Decision (ROD) was signed in June 1992. The EPA will prepare a proposed plan to implement the remedy. After the FFS on the groundwater operable unit is complete, a FFS for the waste disposal areas and a final remedial action for groundwater will begin.

B. Site Visit

On January 22, 1992, Dr. Greg Steele, Ms. Dollis Wright, and Mr. Garry Mills, of the Indiana State Department of Health (ISDH) conducted a site visit at Reilly Tar & Chemical (now named Reilly Industries, Inc.) Superfund site. Also present were staff members from the IDEM, Reilly Industries, and ENSR (contractor for Reilly Industries).

During the site visit, the following were observed:

  1. Access to the site was restricted by a barbed-wire fence, a wooden fence (on the Maywood property), and by security staff. Security staff were at the main entrances to the Oak Park and Maywood properties where routine security inspections are conducted (patrolling of the site).
  2. The on-site media and/or sample locations at the lime pond, abandoned railroad trench, former sludge treatment area, former drainage ditch, and the South Landfill were verified. The lime pond was snow-covered and contained calcium carbonate/calcium sulfate; the abandoned railroad trench was filled in and covered with gravel and/or crushed rock; the former sludge treatment pit is being excavated; the former drainage ditch was covered with vegetation; and the South Landfill contained mounds of fill material, and was fenced and secure.
  3. The southern section of the site had mounds of broken concrete, blacktop pavement, and other debris as a result of structures that have been razed in the past.
  4. On-site and off-site monitoring well locations were observed and the migration of groundwater contamination was discussed. We were shown the proposed location for the on-site slurry wall listed in the EPA FFS alternative.
  5. We conducted a windshield tour of nearby residences, businesses, and industries, to assess their proximity to the Reilly site.

On October 6, 1994, a windshield tour of the Reilly Tar & Chemical Corporation site was conducted by Ms. Cheryl Thomas and Ms. Dollis Wright of the ISDH. Visible sections of the fence on Tibbs Avenue and Holt Road were intact. On the fence, signs were also posted, which read "Keep Out, No Hunting, and No Trespassing".

No other pertinent information was observed during this perimeter site visit.

C. Demographics, Land Use, and Natural Resource Use

Demographics

The Reilly Industries site is in a highly industrialized area in Marion County (population 765,233). The area west and directly adjacent to the Maywood property is occupied by Olin Brass (formerly Bridgeport Brass). To the east is General Motors Allison Gas Turbine Division, Plant Numbers 5 and 8, both which are within a 1-mile radius of the site. Directly south of the Maywood property is a commercial property leased by Reilly Industries for warehousing and shipping purposes.

North and east, directly adjacent to the Oak Park property of Reilly Industries, are residential communities including the Oak Park Community, which contain approximately 200 households with about 600 residents. About 33 percent of the residents are children and elderly people; and about 30 percent are between the ages of 45 and 64. The area is predominantly a white middle class neighborhood. This neighborhood is very stable; approximately one-third of the residents have lived there for more than 20 years, and more than half have lived in this neighborhood for more than 10 years. More than 5,000 people live within a 3-mile radius of the site. Income ranges from the high low class to low middle class.

Land Use

Within the Reilly Industries site, approximately 75 percent of the land surface consists of buildings, equipment, and paved surfaces. The recreational area consists primarily of a basketball court and picnic areas. This recreational area is used by Reilly Industry employees, and the basketball court is occasionally used by the local community. Access to this area of the site is not restricted since it is not located near any of Reilly's production facilities.

The remaining 25 percent of the land surface (approximately 30 acres) is uncontrolled vegetation in the vicinity of the South Landfill (on-site media). The only wildlife reported have been occasional sightings of eastern cottontail rabbits.

Within the adjacent area are several residential areas including the communities of Oak Park and Maywood. Homes are located directly next to the site on the north side and directly across the street on the east side of the site. There are several schools in the area with the closest being approximately ½ mile to the south and west of the site. Another school is located approximately 1 mile south and west of the site. There are several churches in the area, the closest being directly across the street from the site. About 1 mile directly east of site is a park/playground area, and approximately 2,000 feet further east is a library and a community center. Approximately 1 mile due south of the site is Maywood Lake, a former gravel pit, which is used for fishing, swimming, boating, and other recreational activities.

Natural Resource Use

A total of 5,130 individuals residing within a 3-mile radius of the site receive water from the Indianapolis Water Company municipal public water supply (EPA Hazard Ranking System). The supplied water comes predominantly from surface water reservoirs located upgradient from Reilly Industries.

Groundwater flow in the area generally flows from the northwest to the southeast toward Eagle Creek. There are several industries located near Reilly Industries that operate production water wells to augment their water needs. These industrial wells form an extensive cone of influence which has significantly affected the migration of groundwater in the area. This cone of influence has apparently prevented, for the most part, any further easterly migration of the groundwater to Eagle Creek. Data reviewed indicate, however, that the groundwater flow may enter Eagle Creek in an area east-northeast of the site where the groundwater flow is least affected by the cone of influence from the industrial wells.

The Reilly site lies within the White River Drainage Basin. Surface topography on the site and in the surrounding areas is relatively flat, sloping gently to the east. Most of the surface water flow on the site remains on-site and collects in shallow depressions in undeveloped and unpaved areas. Stormwater runoff in the chemical processing areas is collected and processed through Reilly's wastewater treatment system.

Eagle Creek, a tributary 4,000 feet east of the site bounded and channelized by flood-control levees in the vicinity of the site, comprises the river habitat. Surface water in Eagle Creek ultimately discharges into the White River approximately 6,200 feet south of the West Raymond Street bridge. The water depth varies depending on rainfall and upstream water use.

Surface water at Blue Lake (a former gravel pit) is to the east and within less than 1 mile of the site. The depth of Blue Lake is unknown, but Eagle Creek and Blue Lake contain fill material. It is unknown whether Eagle Creek or Blue Lake are used for recreational purposes; access is not restricted at Eagle Creek, but it is partially restricted at Blue Lake.

Apart from Eagle Creek and Blue Lake, open water was found at two unnamed ponds 2,000-4,000 feet east of the investigation area. A small surface drainage impoundment to the immediate northwest of the site also is present, but was not considered for evaluation in this assessment given its size and function. The western part of the southern ponds are flooded gravel pits and hold the largest areas of open water. These ponds appear to be from former gravel mining operations. The depths of the pits are below the water level for the shallow aquifer. It is not known whether the water in these ponds is contaminated however, due to the ponds being downgradient from the site. Because of the impact the industrial wells are having on the movement of the groundwater and the contaminant plume, it is unlikely that the contaminants would have been able to migrate in this direction and distance.

The third area of open water is a former Reilly drainage ditch in the southeastern corner of the investigation area. Numerous dead trees emerging from the water give the indication that this pond has recently increased in size and has flooded areas of the adjacent forest. Again, no information regarding the quality of this water is available, nor is any data available regarding the use of the pond for recreational activities.

As previously stated, groundwater contamination has been found in several private residential wells located to the east, approximately 2,000 feet from Reilly Industries. In 1986, the MCHD performed an extensive well survey of all potentially affected residential areas. Although the MCHD condemned many of the private wells and has forced all residences to establish water connections to the municipal water system, a few of these private wells may still be used for the watering of lawns, gardening, and other outdoor activities.

D. Health Outcome Data

This section identifies the relevant, available databases; their evaluation occurs in the PUBLIC HEALTH IMPLICATIONS section. Cancer may be a plausible health outcome from long-term exposure to at least one of the contaminants of concern. The ISDH maintains a statewide cancer registry; however, data regarding cancer incidence by city and county are not yet available. In addition, the ISDH maintains a mortality database by county. Mortality data on Marion County cancer deaths are available. The public health implications of these data will be evaluated in the Health Outcome Data Evaluation subsection.

COMMUNITY HEALTH CONCERNS

The following community health concerns were developed based on information from a public meeting held on January 23, 1992. This meeting was attended by staff from EPA, ISDH, and IDEM. These concerns are addressed in the Community Health Concerns Evaluation subsection and the PUBLIC HEALTH IMPLICATIONS section.

  1. Is benzene a carcinogenic chemical?
  2. Does the site present any health risks?
  3. Should there be a concern about odors in the air that come from the site?
  4. What are the acceptable levels of contaminants in the groundwater?
  5. Are families at risk from drinking the municipal water?

On August 31, 1994, ISDH staff were invited to a meeting held at Reilly Industries, Inc. to discuss methods of communicating health effects to the community surrounding the site.

Reilly Industries has established a community relations group called the Neighborhood Involvement Council (NIC). This group meets once a month. The primary health concerns that have been expressed during these meetings have been inhalation risk, and the use of water from private wells for gardening.


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