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UNITED STATES EliVIRONMENTAL PROTECTIO AGENCY REGION 5 ca 77 WEST JACKSON BOULEVARD PR01*- C ' CHICAGO, IL 60604-3590 EPA RECORDS CENTER REGION 5 494898 REPLY TO THE ATTENTION MEMORANDUM SUBJECT: ACTION MEMORANDUM - Request for Approval of an Emergency Response Action at the Ritter Avenue Mercury Spill Site, Indianapolis, Marion County, Indiana (Site ID # C59Z) FROM: Shelly Lam, On-Scene Coordinator Emergency Response Branch 1/Response Section 1 THRU: Mindy Clements, Chief Emergency Response Section 1 TO: Jason H. El-Zein, Chief Emergency Response Branch I. PURPOSE This memorandum documents the decision to conduct an emergency response action at the Ritter Avenue Mercury Spill Site (the site) in Indianapolis, Marion County, Indiana. On December 14, 2015, the On-Scene Coordinator (OSC) initiated the response using her delegation and warrant authority. On December 14 and 18, 2015, Emergency Response Branch (ERB) 1 Chief Jason El-Zein verbally authorized a total of $40,000 in funding to conduct emergency response actions. Total costs should not exceed a ceiling amount of $74,585. The response actions described herein were necessary in order to mitigate threats to public health, welfare, and the environment posed by the presence of uncontrolled hazardous substances at the site. The U.S. Environmental Protection Agency's OSC documented the presence of elemental mercury, a hazardous substance as defined by section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The emergency response actions included conducting air monitoring for mercury vapor; conducting physical removal of elemental mercury; removing structural materials that were saturated with elemental mercury; washing the affected area with a mercury treatment solution to bind and remove residual surface mercury; sealing cracks and impacted surfaces to encapsulate mercury without further damaging the building's structure; conducting heating/ventilation cycles to reduce residual mercury vapors; collecting an air sample for final clearance; consolidating and packaging all hazardous substances, pollutants and contaminants for transportation and off-site 1 Recycled/Recyclable a Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post-Consumer)

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UNITED STATES EliVIRONMENTAL PROTECTIO AGENCY REGION 5 ca

77 WEST JACKSON BOULEVARD

PR01*-C' CHICAGO, IL 60604-3590 EPA RECORDS CENTER REGION 5

494898

REPLY TO THE ATTENTION

MEMORANDUM

SUBJECT: ACTION MEMORANDUM - Request for Approval of an Emergency Response Action at the Ritter Avenue Mercury Spill Site, Indianapolis, Marion County, Indiana (Site ID # C59Z)

FROM: Shelly Lam, On-Scene Coordinator Emergency Response Branch 1/Response Section 1

THRU: Mindy Clements, Chief Emergency Response Section 1

TO: Jason H. El-Zein, Chief Emergency Response Branch

I. PURPOSE

This memorandum documents the decision to conduct an emergency response action at the Ritter Avenue Mercury Spill Site (the site) in Indianapolis, Marion County, Indiana. On December 14, 2015, the On-Scene Coordinator (OSC) initiated the response using her delegation and warrant authority. On December 14 and 18, 2015, Emergency Response Branch (ERB) 1 Chief Jason El-Zein verbally authorized a total of $40,000 in funding to conduct emergency response actions. Total costs should not exceed a ceiling amount of $74,585.

The response actions described herein were necessary in order to mitigate threats to public health, welfare, and the environment posed by the presence of uncontrolled hazardous substances at the site. The U.S. Environmental Protection Agency's OSC documented the presence of elemental mercury, a hazardous substance as defined by section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

The emergency response actions included conducting air monitoring for mercury vapor; conducting physical removal of elemental mercury; removing structural materials that were saturated with elemental mercury; washing the affected area with a mercury treatment solution to bind and remove residual surface mercury; sealing cracks and impacted surfaces to encapsulate mercury without further damaging the building's structure; conducting heating/ventilation cycles to reduce residual mercury vapors; collecting an air sample for final clearance; consolidating and packaging all hazardous substances, pollutants and contaminants for transportation and off-site

1

Recycled/Recyclable a Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post-Consumer)

disposal; and transporting and disposing off-site of hazardous substances, pollutants and contaminants.

EPA conducted these response actions in accordance with Section 104(a)(1) of CERCLA, 42 U.S. Code (U.S.C.) § 9604(a)(1), and 40 Code of Federal Regulations (C.F.R.) § 300.415 of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to abate or eliminate the immediate threats posed to public health and/or the environment.

The uncontrolled conditions of the hazardous substances at the site required that this action be classified an emergency response. The project required approximately eight working days to complete, including the time for transportation and disposal.

There are no nationally significant or precedent setting issues associated with the site.

II. SITE CONDITIONS AND BACKGROUND

CERCLIS ID: INN000506110 RCRA ID: INP000000778 Category: Emergency Response Action

A. Site Description

1. Removal Site Evaluation

On November 22, 2015, the homeowner was working in his garage workshop when he broke a bottle of mercury (Photo 1). He notified the Marion County Public Health Department (MCPHD) and the Indiana Department of Environmental Management (IDEM). The IDEM State On-Scene Coordinator (SOSC) reported the spill to the National Response Center (NRC) (Incident #1134042) on November 22, 2015 (Administrative Record [AR] #2). The homeowner indicated that he was unable to hire a cleanup contractor and his homeowner's insurance refused to pay for cleanup. On December 14, 2015, MCPHD requested assistance from the EPA because the homeowner was planning to clean up the mercury spill himself.

OSC Shelly Lam mobilized to the site on December 14, 2015 with the Superfund Technical Assessment and Response Team (START) contractor. EPA and START conducted air monitoring with a Jerome J505 mercury vapor analyzer in the garage and residence. Initial readings in the garage exceeded 9,800 nanograms per cubic meter (ng/m3). EPA observed elemental mercury in the garage (Photo 2). Mercury vapors were not detected inside the residence. EPA and the Agency for Toxic Substances and Disease Registry (ATSDR) established a mercury vapor concentration of less than 1,000 ng/m3 as the acceptable level for normal occupancy in residential buildings.

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2. Physical location

The Ritter Avenue Mercury Site is located on North Ritter Avenue in Indianapolis, Marion County, Indiana, 46219 (see Figures 1 and 2). It is in the Irvington area, which is an historic district approximately five miles east of downtown Indianapolis. The geographical coordinates are 39.7716380 degrees north latitude and 86.0739560 degrees west longitude.

An Environmental Justice (EJ) analysis for the site is contained in Attachment 1. Screening of the surrounding area used Region 5's EJ Screen Tool. Region 5 has reviewed environmental and demographic data for the area surrounding the site at North Ritter Avenue, and determined there is a low potential for EJ concerns at this location.

Site characteristics

The site is a residential lot containing a house and two-story garage (Photo 3). The emergency response action was the first EPA removal action there.

3. Release or threatened release into the environment of a hazardous substance, or pollutant, or contaminant

A release or threat of release of hazardous substances, pollutants, or contaminants was present at the site. EPA documented the presence of hazardous substances as defined by section 101(14) of CERCLA, specifically elemental mercury. The Pollution Reports documenting these findings are part of the Administrative Record (AR #3-8).

According to EPA's draft National Mercury Response Guidebook (2015), adverse human health effects can result from acute or chronic exposure to mercury. Mercury can enter the body through three pathways: ingestion, dermal absorption, and inhalation. However, the most likely exposure route for mercury is inhalation of vapors as elemental mercury evaporates. Mercury is absorbed more rapidly through the lungs than through the digestive tract or skin. Inhaled mercury enters the bloodstream, where it can accumulate and stay in the kidney and brain for weeks or months. Potential human receptors at this site consisted of the property residents, including the homeowner's grandchildren.

4. National Priority List (NPL) status

This site is not on the National Priority List (NPL).

5. Maps, pictures and other graphic representations

The following maps and pictures are attached to this memorandum.

Figure 1 Site Location Map Figure 2 Site Features Map Photographs of the Site

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B. Other Actions to Date

1. Previous actions

Previous actions consisted of EPA's emergency response actions from December 14 —22, 2015.

2. Current actions

No actions are currently being conducted at the site.

C. State and Local Authorities' Roles

IDEM reported the mercury spill to the NRC (Incident #1134042) on November 22, 2015. Additionally, MCPHD verbally requested assistance from EPA cleaning up the site because the homeowner was making plans to clean up the mercury spill himself. State and local agencies did not have resources to immediately mitigate the threat of release.

III. THREATS TO PUBLIC HEALTH, WELFARE, OR THE ENVIRONMENT, AND STATUTORY AND REGULATORY AUTHORITIES

The conditions present at the Ritter Avenue Mercury Site presented an imminent and substantial threat to public health, welfare, and the environment based upon the factors set forth in NCP § 300.415(b)(2). These factors included, but were not limited to, the following:

Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants;

EPA observed elemental mercury and documented high concentrations of mercury vapors in the garage workshop. As such, there was actual or potential exposure to nearby human populations. Mercury is a characteristically hazardous waste (D009) according to the criteria for toxicity established in 40 C.F.R. § 261.24. Mercury is a hazardous substance as defined by section 101(14) of CERCLA.

According to EPA's draft National Mercury Response Guidebook (2015), adverse human health effects can result from acute or chronic exposure to mercury. Mercury can enter the body through three pathways: ingestion, dermal absorption, and inhalation. However, the most likely exposure route for mercury is inhalation of vapors as elemental mercury evaporates. Mercury is absorbed more rapidly through the lungs than through the digestive tract or skin. Inhaled mercury enters the bloodstream, where it can accumulate and stay in the kidney and brain for weeks or months. Potential human receptors at this site consisted of the property residents, including the homeowner's grandchildren.

ATSDR has determined that the nervous system is sensitive to metallic mercury. Exposure to very high levels of metallic mercury vapor can cause brain, kidney, and lung damage and may

4

seriously harm a developing fetus. Exposure to mercury vapor concentrations high enough to produce such serious effects might also cause coughing, chest pains, nausea, vomiting, diarrhea, increases in blood pressure or heart rate, skin rashes, and eye irritation. Exposure to lower levels of airborne mercury for prolonged periods of time would produce more subtle effects, such as irritability, sleep disturbances, excessive shyness, tremors, coordination problems, changes in vision or hearing, and memory problems. Very young children are more sensitive than adults to the effects of mercury. Children five years of age and younger are considered to be particularly sensitive to the effects of mercury on the nervous system, since their central nervous system is still developing (AR #1).

The availability of other appropriate federal or State response mechanisms to respond to the release;

MCPHD verbally requested assistance from EPA to address the potential threats posed by elemental mercury at the site. State and local agencies did not have resources to immediately mitigate the threat of release.

IV. ENDANGERMENT DETERMINATION

Given the site conditions, the nature of the known and suspected hazardous substances on site, the potential exposure pathways described in Sections II and III, and actual or threatened releases of hazardous substances from this site, it was necessary to immediately implement the response actions selected in this Action Memorandum. The hazardous substances presented an imminent and substantial endangerment to public health, welfare, or the environment.

V. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Emergency response action description

The OSC conducted the following response actions to mitigate threats posed by the presence of hazardous substances at the Ritter Avenue Mercury Site. The response actions described in this memorandum directly addressed actual or potential releases of hazardous substances on site, which posed an imminent and substantial endangeiment to public health, welfare, or the environment.

a. Established a site health and safety plan.

b. Conducted air monitoring for mercury vapor during response activities (Photo 4).

c. Conducted physical removal of approximately 10 pounds of elemental mercury using a mercury-specific vacuum (Photos 5 and 6).

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d. Physically removed structural materials, such as fascia, baseboards, and a window, that were saturated with elemental mercury (Photo 7).

e. Washed the affected area with a mercury treatment solution to bind and remove residual surface mercury (Photo 8).

f. Sealed cracks and impacted surfaces, such as studs and the floor, to encapsulate mercury without further damaging the building's structure (Photo 9).

g. Conducted heating/ventilation cycles to reduce residual mercury vapors (Photo 10).

h. Collected an air sample for laboratory analysis by National Institute of Occupational Safety and Health (NIOSH) method 6009 for final clearance of the garage (Photo 11).

i. Consolidated and packaged all hazardous substances, pollutants and contaminants for transportation and off-site disposal (Photo 12).

j. Transported and disposed of all characterized or identified hazardous substances, pollutants, wastes, or contaminants to an approved disposal facility in accordance with EPA's Off-Site Rule (40 C.F.R. § 300.440).

The OSC conducted emergency response actions in a manner not inconsistent with the NCP. The OSC initiated planning for provision of post-removal site control consistent with the provisions of NCP § 300.415(1).

The threats posed by uncontrolled substances considered hazardous met the criteria listed in NCP § 300.415(b)(2), and the response actions described herein were consistent with any long-term remedial actions which may be required. Elimination of hazardous substances, pollutants and contaminants that posed a substantial threat of release was expected to minimize substantial requirements for post-removal site controls.

The estimated costs to complete the activities outlined above are summarized below. These activities required approximately eight on-site working days to complete.

Detailed cleanup contractor costs are presented in Attachment II.

2. Contribution to remedial performance

Future remedial actions should not be necessary based on available information.

3. Engineering Evaluation/Cost Analysis (EE/CA)

Not Applicable

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4. Applicable or relevant and appropriate requirements (ARAR)

The need to respond immediately was urgent and there was not time to identify ARARs or evaluate the extent to which ARARs could be attained. However, the OSC sent a letter on January 20, 2016, to Rex Osborn at IDEM requesting the identification of any applicable state ARARs (AR #9).

The OSC identified the following ARARs:

1. Hazardous substances, pollutants or contaminants removed off-site pursuant to this emergency response action for treatment, storage and disposal shall be treated, stored, or disposed at a facility in compliance, as determined by EPA, with the EPA Off-Site Rule, 40 C.F.R. § 300.440.

2. 49 U.S.C. § 5101 et seq. regulates the transportation of hazardous waste and hazardous substances by aircraft, railcars, vessels, and motor vehicles to or from a site.

3. The Mercury Export Ban Act of 2008 prohibits the export of metallic mercury from the United States. It requires that metallic mercury be transported to a designated storage facility.

B. Removal Project Ceiling Estimate — Extramural Costs:

Regional Removal Allowance Costs:

Total Cleanup Contractor Costs $38,339

(Includes a 20% contingency)

Other Extramural Costs Not Funded from the Regional Allowance

Total START, including multiplier costs $26,518

Subtotal, Extramural Costs $64,857

Extramural Costs Contingency $9,728

(15% of Subtotal, Extramural Costs)

TOTAL REMOVAL ACTION PROJECT CEILING $74,585

The response actions described in this memorandum directly addressed the actual or threatened release of hazardous substances, pollutants, or contaminants at the site which posed an imminent

7

and substantial endangerment to public health or welfare or to the environment. These response actions did not impose a burden on affected property disproportionate to the extent to which that property contributes to the conditions being addressed.

VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED OR NOT TAKEN

Given the site conditions, the nature of the hazardous substances documented on-site, and the potential exposure pathways to nearby populations described in Sections II and III above, actual or threatened release of hazardous substances from the site, if not addressed by implementing the emergency response actions described in this Action Memorandum, would have presented an imminent and substantial endangerment to public health, welfare, or the environment. Delayed or no action concerning the remaining hazardous substances, pollutants and contaminants at the site would have resulted in increased potential for hazardous substances to release, thereby threatening the environment and the health and welfare of nearby residents and other persons who are in proximity to the site.

VIII. OUTSTANDING POLICY ISSUES

None.

IX. ENFORCEMENT

For administrative purposes, information concerning the enforcement strategy for this site is contained in the Confidential Enforcement Addendum.

The total EPA costs of this removal action based on full-cost accounting practices that will be eligible for cost recovery are estimated to be $165,355.1

($74,585 + $18,720) + (77.22% x $93,305) = $165,355

X. RECOMMENDATION

This decision document represents the selected removal actions for the Ritter Avenue Mercury Site located in Indianapolis, Marion County, Indiana. This document has been developed in accordance with CERCLA, as amended, and is not inconsistent with the NCP. This decision is based on the Administrative Record for the Site (see Attachment III).

I Direct Costs include direct extramural costs and direct intramural costs. Indirect costs are calculated based on an estimated indirect cost rate expressed as a percentage of site specific direct costs, consistent with the full cost accounting methodology effective October 2, 2000. These estimates do not include pre-judgement interest, do not take into account other enforcement costs, including Department of Justice costs, and may be adjusted during the course of a removal action. The estimates are for illustrative purposes only and their use is not intended to create any rights for responsible parties. Neither the lack of a total cost estimate nor deviation of actual total costs from this estimate will affect the United States right to cost recovery.

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Conditions at the Site met the NCP § 300.415(b)(2) criteria for an emergency response action. The total project ceiling, if approved, will be $74,585. Of this, as much as $48,067 comes from the Regional removal allowance. I recommend your approval of the emergency response action. You may indicate your decision by signing below.

APPROVE: 0 C DATE: -2 - 2 Chief, Emergency Response Branch

DISAPPROVE: DATE: Chief, Emergency Response Branch

Enforcement Addendum

Figures: 1 Site Location Map 2 Site Layout Map Photo Log

Attachments: I. Environmental Justice Analysis

Detailed Cleanup Contractor Cost Estimate III. Administrative Record Index IV. Independent Government Cost Estimate

cc: Brian Schlieger, U.S. EPA, 5104-A Lindy Nelson, U.S. DOI, w/o Enf. Addendum (Lindy [email protected]) Rex Osborn, IDEM w/o Enf. Addendum ([email protected])

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BCC PAGE HAS BEEN REDACTED

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

ENFORCEMENT ADDENDUM

HAS BEEN REDACTED – THREE PAGES

ENFORCEMENT CONFIDENTIAL

NOT SUBJECT TO DISCOVERY

FOIA EXEMPT

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION

L

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plant

FIGURE 1 SITE LOCATION MAP

RITTER AVENUE MERCURY SITE LNTDIANAPOLIS, MARION COUNTY, LNEILANA

1:24,000 0 1,000 2,000 insemii Feet

Source: Es6, Delorme, NAVTEG, USGS, NRCAN, MFR. FC. TornTorn

E washi Won S t

,M,1,511Ingion,

I St

ate Locafon

JSC.45', 'rdRCAN, MET: IPC, To-nToir

E English :Ave

i•-••TEI-14-Jr fA.ve

Encil0 Ave

L • Or I

FIGURE 2 SITE FEATURES MAP

RITTER AVENUE MERCURY SITE INDIANAPOLIS, MARION COUNTY INDIANA

Sources: Esr5, DeLome, NAVTEG, USGS, NRCAN, MET', iPC, TomTom

1:1,000 0 100 200

Feet

1 Broken bottle that contained mercury 12/15/2015

Number

2 Mercury beads on workshop floor

S. Lam 12/15/2015

Number Description

Description

Date

Photographer Date

PHOTO LOG

Number Description

3 Garage where mercury was spilled. Note children's toys in the fore A sund.

Date 12/15/2015

Number Description

4 OSC Lam conducting air monitoring for mercury vaior

Date 12/14/2015

Number 5 Description Removing elemental

mercury with a mercury vacuum

Date 12/15/2015

Number Description

6 Mercury pooled under window

Date 12/16/2015

Number 8 Description

Date

Spraying surfaces with H. X solution 12/18/2015

Number Description

Date

Checking skirt roof for mercury vapors. Note that window above was removed because it was saturated with merc 12/18/2015

7

Caulking cracks to encapsulate mercury 12/14/2015

Description

Date

10 Heating and venting workshop

Number Description

Loading containers for transportation and dis . osal

ATTACHMENT I

ENVIRONMENTAL JUSTICE ANALYSIS

RITTER AVENUE MERCURY SITE INDIANAPOLIS, MARION COUNTY, INDIANA

FEBRUARY 2016

-21.111•11110•511111119,06.

Selected Variables State

Percentile

EJ Indexes

EJ Index far PM2.5

EJ Index for Ozone — EJ Index for NATA DIesel PM

EJ Index far NATA Air Toxics Cancer Risk

EJ Index for NATA Respiratory Hazard Index

EJ Index for HATA Neurological Hazard Index

EJ Index for Traffic Proximity and Volume

EJ Index for Lead Paint Indicator — EJ Index for ProximiWo NPL sites

EJ Index for Proximity to RMP sites 24

El Index for Proximity to ISDFs 36

EJ Index for Proximity to Major Direct Dischargers 73

64

53

64

65

33

6,3

^ 1

60 51 07 52

51 39

63 50

57 47

62 43

07 E4

39 22

49 38

20 13

38 20

ea 53

69

EPA Region USA

Percentile Percentile

jut

S' • 4, ^. 3, • "‘ •

-

EpA EISCREEN Report lta#

for 1 mile Ring Centered at 33.771850,-86.073836, INDIANA, EPA Region 5

Approximate Population: 15244

F1 7.1(.4-ix fr:r rarpa'rid b All 5r%•111,15.IlrrknirA:p.: in Ihr: grab; itr•cillvillA

F I:nlwra,

• Frrr-ntil* P.rcn-nrd ='.-rrr• -tar Fr: -renh

75's ,assrt 'ewer:al larroracr `2,2 .02.22 :t ".7P.VS 2 -4 Star srac 42V. Ca2S.:G.;..t15 :Stir nee CDRGVATIGi5P

32,2.15 .2' 2hG Ziff. WM Disc sr sw; 541 a: sar:ar:iie 55:1! F c ',aka reprecer:c. 2.35 secenti 5•CfiGG 201'2;31.C211. GI IDY2 2-0t G.G1GGI1 3bU psaF Cr

sOter 2,52 comprer :3 hit EGG't 225421. 5F ▪ rg'sn. Sr 1st C.1. "c us! ir a ;'‘en lccricr at:rn SS? ca-cent'a r aticrwina; tSIS pears :rataniv

parzer: c!:r a UE F02./1:tic -as rear bac, Erscc 'AUG hint,: real' !F.,1 F5105 .1415 C.211.321 hein ant'oec lams It -yrnier :he cats 2 -e aralatla.

all rhe matIcas Jsea, re-? a:rs:: Mat ihG.C22C't -213E22:hh.25:2122 5.1h LH-car:air:in aprins :Kr rc-5a-..5;-1eqa'ir•5crr eisn. ac it's-assert': ':c criarstard Sr aFsossera intararatatisrt ar S acs 'cat cm ',the! ireatv: 'tact se a EJINEE11 Ccccmantricr fsr Jisck:,s'm cf:r .c:Jes Carom. Jen

re 33r3.5.

February 02, 2016 113

lanlenCe

Fed>, lOpple

WV1111, 'Ile

Lynhu,,,

umberlond

Beech Gore Pele,

PA United States Environmental Protection Agency

EJSCREEN Report

for 1 mile Ring Centered at 39.771650,-86.073636, INDIANA, EPA Region 5

Approximate Population: 15244

February 2, 2016

Digkized Point

Buffer Area

1.144,448 1.25 or

I I I 0 1 I

0 2 • 0 km 02,x1E-111.-5.5.E.T.Iume -S. rarnaa 0et 020...11,.

Ir

.Ex.0141.003: 0..5111

February 02, 2016 2/3

United States Einitionmental Protection Agency EJSCREEN Report

for 1 mile Ring Centered at 39.771650,-86.073636, INDIANA, EPA Region 5

Approximate Population: 15244

Raw Selected Variables

Data State %ile in Avg. State

'

EPA Region

Av .

Voile in EPA

Region •

USA %Ile in Avg. USA

Environmental Indicators

Particulate Matter (Pm 2.5 in lig/m1 12.3 11.3J95 10.8 91 9.78 95

Ozone (polo) 48.5 46.5 79 44.4 87 46.1 63

NATA Diesel PM (µg/m3)* 1 0.828 a341 94 I 0.7121 60-70th 0.824 60-70th

NATA Cancer Risk (lifetime risk per million)* 58 36 97 I 42 80-90th 1 49 70-80th __ NATA Respiratory Hazard Index* 2.1 1.1 95 1.5 70-80th 2.3 , 50-60th

NATA Neurological Hazard Index* 0.069 0.059 79 0.067 70-80th 0.0631 70-80 h

Traffic Proximity and Volume (dailytraffic count/distance to road) 4.6 24 27 69 15 110 11

Lead Paint Indicator (% Pre-1960 Housing) I 0.9 0.37 96 0.4 94 0.3 96

NPL Proximity (site count/km distance) 0.096 0.11 69 0.086 0.096

RMP Proximity (facility count/km distance) 1.1 0.35 92 0.33 • 0.31 93 __. TSDF Proximity (facility count/km distance) 0.097 0.042 90 0.051 88 0.054

Water Discharger Proximity (facility count/km distance) 0.38 0.26 81 0.23 84 0.25 84

Demographic Indicators

Demographic Index 29% 26% 69 28%1 66 35% 51

Minority Population 18% 19% 67 24% 60 36% 39

Low Income Population — 41% 34% 613 32% 69 34% 65

Linguistically Isolated Population 2% 66 2% 62 I 1% 5% 47

Population With Less Than High School Education 16% 13% 64 12% 71 14% 61

Population Under 5 years of age v 9% 7% 74 6% 78 7% 76

Population over 64 years of age 10% 13% 35 13% 35 13% 40

The Notional-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to

prioritize a ir toxics, emission sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks

over geographic areas of the country, not definitive risks to specific individuals or locations. More information on the NATA analysis can be found

at: ht-tp://www.epa .govittniatwinata mai n/index. html.

For additional information, see: www.epa.gov/environnientaljustice

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not

provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial

uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this

screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see

EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and

demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge

before taking any action to address potential El concerns.

February 02, 2016 3/3

ATTACHMENT II

DETAILED CLEANUP CONTRACTOR ESTIMATE

HAS BEEN REDACTED – ONE PAGE

ATTACHMENT III

U.S. ENVIRONMENTAL PROTECTION AGENCY REMOVAL ACTION

ADMINISTRATIVE RECORD FOR

RITTER AVENUE MERCURY SITE INDIANAPOLIS, MARION COUNTY, INDIANA

ORIGINAL FEBRUARY, 2016

Na SEMS ID DATE AUTHOR RECIPIENT PAGES TITLE/DESCRIPTION

1 922741 3/1/01 ATSDR File ToxFAQs Fact Sheet—Metallic 2 Mercury

2 922742 11/22/15 National Response File Incident Report #1134042 3 Center

3 484839 12/15/15 Lam, S., U.S. EPA Distribution List Pollution Report (POLREP) #1 — 8 Initial Report

4 484840 12/16/15 Lam, S., U.S. EPA Distribution List Pollution Report (POLREP) #2— 8 Progress Report

5 848841 12/17/15 Lam, S., U.S. EPA Distribution List Pollution Report (POLREP) #3— 8 Progress Report

6 848842 12/18/15 Lam, S., U.S. EPA Distribution List Pollution Report (POLREP) #4— 5 Progress Report

7 848843 12/19/15 Lam, S., U.S. EPA Distribution List Pollution Report (POLREP) #5 — 10 Progress Report

8 848845 1/6/16 Lam, S., U.S. EPA Distribution List Pollution Report (POLREP) #6 — 9 Progress Report

9 922743 1/20/16 Lam, S., U.S. EPA Osborn, R., IDEM Letter re: Request for Applicable or Relevant and Appropriate

2

Requirements at the Ritter Avenue Mercury Site

10 Lam, S., U.S. EPA El-Zein, J., U.S. EPA Action Memorandum re: Request for a Time-Critical Removal Action at the Ritter Avenue Mercury Site (PENDING)

ATTACHMENT IV

INDEPENDENT GOVERNMENT COST ESTIMATE

HAS BEEN REDACTED – THREE PAGES

NOT RELEVANT TO SELECTION

OF REMOVAL ACTION