Project Overview
General
The Bedford Casting Operations facility is located at 105 GM Drive in the City of Bedford, Shawswick Township, Lawrence County, Indiana. The Bedford facility lies on approximately 152.5 acres of land situated on either side of GM Drive and extends north along Bailey Scales Road.
The U.S. EPA ID for the facility is #IND006036099.
Plant History
The Bedford facility (Facility) was originally constructed in the early 1900s as a limestone milling operation. The U.S. Government purchased the mill in 1942, converting the plant to an aluminum aircraft engine foundry, which was operated by General Motors Corporation (GMC) to support the war. GMC purchased the property in 1946 after World War II and the Facility has continued to operate as an aluminum foundry since that time. General Motors Corporation filed for bankruptcy protection in June 2009 and sold a number of its assets on July 10, 2010 to General Motors LLC, including the Facility. General Motors LLC has renovated and expanded the facility operations significantly since the asset purchase. The Facility continues to produce a variety of automotive aluminum casting products such as transmission cases, converter housings, and cylinder heads. A complete Facility history is presented in the Current Conditions Report (CCR).
Note: Reference in this website to historical documents or to the property or work prior to July 10, 2009, refers to the work performed by General Motors Corporation which includes work on properties owned by RACER Trust, third parties and/or GM LLC.
Timeline
1923
RCRA Corrective Action
GM is currently conducting Resource Conservation and Recovery Act (RCRA) Corrective Action activities pursuant to the Administrative Order on Consent (AOC), effective August 4, 2014 between U.S. EPA and GM for the Facility.
Corrective Action is required for all facilities which applied for a permit to manage hazardous waste. In essence, Corrective Action is an evaluation to determine whether plant waste management operations have impacted the environment and, if so, the cleanup work necessary to correct this impact. Corrective Action is designed to identify and address any significant risks to human health or the environment resulting from the release of contaminants to environmental media such as soil or water.
Under the terms of the AOC, GM is taking the lead role to investigate the environmental conditions and perform any needed remediation work. The scope of investigation and any required cleanup work is reviewed and approved by U.S. EPA and is conducted according to standards that are protective of public health and the environment. IDEM is also involved with the review and comment on project scope and data evaluation.
The Resource Conservation and Recovery Act (RCRA)
is a federal law that encourages recycling and requires responsible waste management in a manner that is protective of human health and the environment.
For more information: www.epa.gov/osw
Corrective Action
is a process through which the areas of a facility that may have been affected by the management of solid or hazardous waste, or releases of hazardous constituents, are evaluated and, if necessary, remediated.
United States Environmental Protection Agency (U.S. EPA)
Region V has signed an AOC with GM for Corrective Action work at the Facility.
For more information: www.epa.gov
Indiana Department of Environmental Management (IDEM) and United States Fish and Wildlife Service (USFWS)
IDEM is co-operating with U.S. EPA and GM and providing review and comment on the Corrective Action work. In the past, the United States Fish and Wildlife Surface has provide review and input on activities conducted along the local creek systems.
For more information: www.in.gov/idem and www.fws.gov
Investigation Activities
CERCLA Creek Soil and Sediment Removal Action
Removal Actions along Bailey's Branch and Pleasant Run Creek were undertaken under an Administrative Order on Consent (AOC) with the U.S. EPA Region V under the Comprehensive, Environmental Response and Compensation, and Liability Act (CERCLA), which became effective on July 31, 2003.
The Removal Action under the CERCLA AOC, was executed to clean up PCB contaminated sediment and floodplain soil within the Pleasant Run Creek Watershed. The CERCLA AOC has been entered into voluntarily to expedite the implementation of the cleanup work. This area includes approximately 5 miles of creek from the Facility to approximately the old Murdoch railroad trestle (Figure 1). Both the creek bed and the adjacent floodplain areas were part of the Removal Action activities, starting with the upstream section and then proceeding downstream. The objectives of the CERCLA AOC were to control any potential ongoing releases to the creek, and to remove sediment and soil present at levels above the cleanup criteria. The cleanup criteria for floodplain soil was the State of Indiana residential land use default criteria of 1.8 parts per million (ppm). The cleanup criteria for sediment in the creek was 1.0 ppm.
In general, the Removal Action along Bailey's Branch Creek and Pleasant Run Creek consisted of dividing up each of the three sections into discrete work zones whereby surface water was diverted from a work area while removal of sediment, floodplain soil and any impacted surficial bedrock was conducted in order to meet the cleanup goals. The cleanup goals for each work area were confirmed through verification testing after soil, sediment, and bedrock removal. Remediation of flood plain soil and sediment was performed by diverting water flow through large pipes or by-pass channels, followed by standard excavation techniques using excavators. Excavated areas in the floodplain and stream bank were restored with imported soil while the creek channel was restored with rock after any substantial bedrock excavations were filled with concrete. The floodplain areas were re-vegetated using native grasses, wildflowers, shrubbery and trees while habitat features such as snags, deadfalls, nesting boxes, perches, and vernal ponds were constructed to attract area wildlife.
- The Upstream Parcels RA was implemented between fall of 2003 and spring of 2007.
- The Parcel 22 RA was implemented starting in the winter of 2006 and was largely completed by the end of 2008 with
some restoration work continuing into the spring of 2010.
-The Downstream Parcels RA was implemented starting in the fall of 2004 and work was completed in 2014.
The Removal Action under CERCLA is essentially being classified as an interim measure for purposes of the RCRA Corrective Action. Since the Removal Action has been completed, GM and Region V have signed an AOC for remaining maintenance work, if needed, within the creek bed just east of the GM Facility. For more information visit the EPA website: link
Geology and Topography
The geology and topography of the land surface can help us evaluate potential movement of contaminants in surface water at, and in groundwater below, the ground surface.
Resources used to describe the geology and topography include published maps and reports as well as site-specific maps developed as part of this investigation.
Map of Indiana showing Topography of the Bedrock Surface (USGS, 1982)
3D Topography of Creek Areas
Map of Indiana showing Thickness of Unconsolidated Deposits (USGS, 1983)
3D Aerial View of Creek Areas
Bedrock Geologic Map of Indiana (USGS, 1987)
GIS - Based Electronic Data Access Tool
Conceptual Hydrogeological Site Model
Full details regarding the regional and local geology, and hydrogeology can be found in the RFI Report (GHD, March 2020). (Left) Bedrock geology map with topographic contours (after Thompson et al., 2008, with adjustments based on site specific data); (Right) generalized stratigraphic column showing unit relationships. The thickness of the Blue River and Sanders Group Formations shown are relative to the approximate average thickness of formations penetrated at the site. Unit Abbreviations explained in text. Yellow arrow denotes strike of regionally dominant joint set (Powell, 1976 [Plate 1]). Pilot trench shown in magenta.
Risk Assessment
What is Risk?
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Risk is defined as the probability that a substance or situation will produce harm under specified conditions. Risk is a combination of two factors:
1. The probability that an adverse event will occur
(such as a specific disease or type of injury); and
2. The consequence of the adverse event. -
Risk arises from exposure and hazards.
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EPA considers risk to be the chance of harmful effects to human health or to ecological systems resulting from exposure to an environmental stressor. For more information: https://www.epa.gov/risk
What is Risk Assessment and Risk Management?
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Risk assessment is the systematic, scientific characterization of potential adverse effects of human or ecological exposures to hazardous agents or activities.
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Risk management is the process of identifying, evaluating, selecting, and implementing actions to reduce risks to human health and to ecosystems. The goal of risk management is scientifically sound, cost-effective, integrated actions that reduce or prevent risks while taking into account social, cultural, ethical, political, and legal considerations.
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Risk management goals should be used to guide risk analyses.
What are Acceptable Risk Levels?
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Cumulative site cancer risk of 1 in 10,000 to an individual and noncancer hazard index less than 1, based on Reasonable Maximum Exposure under current and future land use (U.S. EPA 1991).
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Chemical-specific standards that define acceptable risk levels can be used to determine whether an exposure is associated with an unacceptable risk (U.S. EPA 1991).
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Background lifetime cancer risk in the United States is
approximately 4 in 10, or 0.4 (American Cancer Society 1999).
About PCBs
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PCBs were developed and used by many industries for their fire retardant and insulating properties. PCB hydraulic fluids were used at the Facility from 1965 to the early 1970’s as a safety measure to prevent fires. PCBs were later restricted by the federal government in 1978 through the Toxic Substances Control Act (TSCA).
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Additional information about PCBs can be found through the U.S. EPA and ATSDR webpages.