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EPA in Indiana

Cline Avenue Ditch Site

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The Site is located near the northeast corner of the intersection of Gary Avenue and Cline Avenue (Indiana Route 912) in Gary, Lake County, Indiana. The Site is bordered by a rail line and the airport property to the north and east, Gary Avenue to the south, and Cline Avenue to the west. The Site lies within the larger, heavily industrialized area to the west of the airport .

The Cline Ave Ditch (Ditch) is located along the east side of Cline Avenue and oil sheens have periodically been observed on water in the Ditch. The Ditch flows to the south and into a subterranean pipe/culvert for approximately ½ miles and discharges into the Grand Calumet River. In June 2004, EPA responded to a reported release of oil to the Grand Calumet River. Initial investigations identified the oil  as coming from a portion of the ditch along Cline Avenue. Containment and sorbent booms were placed to contain oil entering the ditch. EPA conducted response actions that included the removal of impacted material along the embankment, backfilling the embankment and installing erosion protection.

Later, January 2011, EPA responded to additional oil in the Cline Avenue Ditch, north of the intersection of Cline and Gary Avenues. EPA installed and maintained absorbent booms to capture floating product and prevent it from migrating to the Grand Calumet River. EPA also placed additional booms along the eastern embankment of the Ditch near five identified oil seeps. EPA continued to conduct boom maintenance and bird hazing operations until 2017.

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What Has Been Done to Clean Up the Site?

In March 2017, after a public comment period, EPA entered a Resource Conservation and Recovery Act (RCRA) 7003 Administrative Order on Consent (AOC) with Oxy USA, Inc. (OXY). Under the AOC,  Oxy  took over maintaining the absorbent boom materials controlling the sheen impacts in the ditch, and conducted investigations necessary to develop a feasibility study and design investigation to evaluate and develop potential final cleanup measures. The final cleanup measures identified by the feasibility study are to permanently control and mitigate the releases of oil or petroleum wastes and waste constituents. The final cleanup measures are also designed to assure that contamination does not migrate off-site via groundwater at levels that present unacceptable risks

OXY’s subsidiary, Glenn Springs Holding (GSH), conducted the feasibility study under EPA’s supervision (in consultation with the State), and has prepared a proposed cleanup plan to eliminate the release of oil into the Cline Ave Ditch. The feasibility study investigation was conducted in multiple phases in order to develop information on physical, geological, and hydrogeological conditions at the Site, including data on soil, surface water, and ground water contamination.

A conceptual site model (CSM) of the petroleum and related contamination was developed based on the nature and extent of the contaminated material identified through data from the investigation. The CSM evaluated the conditions creating potential for release of oil and petroleum wastes laterally from the sidewalls and upward from the bottom of the ditch.

OXY is now proposing to construct and implement final cleanup measures (following EPA approval after its consideration of public comments) as additional work under the AOC.

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What Is the Current Site Status?

Investigation Summary

The design investigation indicated the presence of oil across most of the site east of the ditch.  However, most of the oil is below the water table, restricting it from movement. The area along the eastern edge of the ditch where there are visual observations of oil discharging into the ditch are a result of pooled oil that lacks the resistance from saturated soils and has found a pathway to the surface.  The oil is not moving in bulk from the site, but from isolated pockets near the surface of the embankments.   Supplemental investigations also indicated that there is minimal oil on the western edge of the ditch, indicating that the source of the oil is along the eastern embankment and underneath the ditch.

Groundwater Study

Ten water-table monitoring wells were installed both on and off-site in the immediate area of the Cline Avenue ditch to determine if any contaminants have moved off-site.  Groundwater sampling indicated that petroleum-related groundwater impacts are limited to on-site monitoring wells, with no detectable volatile organic compounds (VOCs) or semivolatile organic compounds (SVOCs) in wells off-site to the west and southwest.

Feasibility Study

Using historical site data and information collected from the design investigation, as well as the groundwater monitoring study; several remedies were evaluated for their effectiveness, implementability, cost, and ability to meet the cleanup goals and protect the public.  The feasibility study identifies the proposed remedy.

Contaminant Risks

Results from the investigation show that oil is discharging from seeps along the eastern edge of the Ditch.  The proposal is designed to prevent oil from entering the ditch and prevent contaminants from moving off-site.

Cleanup Goals

The goal of the cleanup is to prevent the release of oil from the Site into the Cline Ave ditch and ultimately the Grand Calumet River. Long-term groundwater monitoring at the Site will ensure that contaminants that remain are not leaving the site and creating an unacceptable risk.

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Proposed Remedy

  • Installation of a storm sewer pipe to replace the open channel ditch
  • Removal of oil impacted material above the paver stones within the ditch and in construction areas where impacted soils are disturbed
  • Installation of low permeability collars (or engineered equivalents)
  • Sealed pipe joints
  • Installation of soil/bentonite cut off wall
  • Long-term monitoring and reporting

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Responsiveness Summar

This Responsiveness Summary provides a summary of the public comments that the United States Environmental Protection Agency (EPA) received regarding a proposed remedy for the Cline Ave Ditch Site in Gary, Indiana. This Responsiveness Summary also provides EPA’s responses to those comments, developed in consultation with the Indiana Department of Environmental Management (IDEM).

I.    Outcome of Review of Public Comments and State Consultation

After carefully reviewing and considering all public comments submitted during the public comment period, EPA, in consultation with IDEM, determines that the public comments do not require any changes to EPA’s evaluation and determination of the proposed remedy for the Site.  Therefore, the additional work outlined in the Focus Feasibility Study will be implemented by OXY USA, Inc. (OXY), under a workplan approved (and overseen) by EPA.   

II.    Comments and Responses

EPA received a total of ten comments during the public comment period.  Two of the comments were from interested citizens and eight were provide by members of the Citizens Advisory for the Remediation of the Environment (CARE) Committee.  The CARE Committee serves as an advisory role with IDEM on the removal of Beneficial Use Impairments that apply to the Grand Calumet River Area of Concern.  As this project impacts the Grand Calumet Area of Concern, a presentation and comments were solicited from the group during a presentation on July 23, 2020.  It should be noted that some comments discussed matters beyond the scope of this proposed remedy and EPA was not able to directly provide responses for them. EPA carefully considered each comment while developing this Responsiveness Summary.  

Comment #1:

One commenter asked that EPA “Please clean up as much of Gary as you can” including Lake Gary.

Response:  This public comment period addresses only the work to be done under a cleanup order for the Cline Ave Ditch site. As such, any comments on Lake Gary and other portions of Gary are beyond the scope of this order.   Notwithstanding, EPA will share this comment with the Indiana Department of Environmental Management to address concerns with the current state of Lake Gary.


One commenter supported the proposed remediation plan for the Cline Avenue Ditch. They went on to suggest that state and federal governments should tax generators of hazardous materials to fund a Superfund Account to clean up old industrial sites in the area where responsible parties cannot be determined.

Response:  EPA appreciates the support for the proposed cleanup plan. The further suggestions are beyond the scope of what EPA can address under the cleanup order for the Cline Ave Ditch site.

The remaining comments came from a public forum with the CARE Forum, which includes representatives of stakeholders with an interest in environmental issues connected to the Grand Calumet River Area of Concern. These comments generally sought further information and detail about the proposed cleanup plan, and did not seek or suggest any changes to the cleanup plan:     


The commenter requested that a summary PowerPoint presentation of the Cline Ave Ditch Proposed Remedy be made available and emailed to the CARE committee.  

Response: EPA provided a copy, which is posted at IDEM’s CARE website. (


The commenter asked where the surface water will go when the ditch is replaced with a buried impervious pipe.
Response: A shallow swale will be constructed next to the pipe to direct surface water into a series of catch basins. The surface water will enter the newly enclosed culvert system and flow to a collection vault and discharge into the Grand Calumet River. This design will significantly reduce the potential for storm water to absorb surface contamination currently in and around the ditch.  


The commenter asked if the new pipe would discharge into the Grand Calumet River at the same location as the current pipe.

Response: Yes, the new pipe will connect with the existing culvert that traverses alongside Cline Ave and discharges into the Grand Calumet River approximately, 2,000 feet to the south of the Site.

Comment #6

The commenter asked if there will be subsurface sampling to determine if oil is migrating along the outside edge of the pipe.

Response: Under EPA and IDEM supervision, OXY will implement an adaptive monitoring plan to detect and understand any migration of petroleum. There was a detailed pre-remedy study conducted so that differences post-remedy can be tracked.  Details of the monitoring will be provided in the comprehensive work plan that EPA will review and approve prior to implementation of the remedy.

Comment #7

The commenter asked who takes on the operations and maintenance (O&M) of the remedy.

Response: Under the cleanup order, OXY and its appointed contractor(s) will be responsible for the O&M for the project.


The commenter asked whether IDEM will continue investigating the source of the oil?

Response: DEM has been involved throughout the investigation, feasibility study, and the selection of a proposed remedy.  The source of oil around the Cline Ave Ditch has been thoroughly investigated.  

Comment #9

The commenter sought clarification on the length of the public notice and comment period.

Response: EPA established a 30-day public comment period that ended August 21.

Comment #10

The commenter asked what type of seed mix will be used.

Response: The seed mix will be accordance with the Permanent Seeding Section of Chapter 7 of the Indiana Storm Water Quality Manual and INDOT Specification Part 621.06(b). This section states that the seed mixture shall be applied at the rate of 200 lb/ac consisting of 100 lb/ac 230 of a 4-way blend of turf type Tall Fescue, 50 lb/ac Creeping Red Fescue, 45 lb/ac Perennial Ryegrass and 5 lb/ac White Dutch Clover. Fertilizer and mulching material, where specified or directed, shall be applied in accordance with 621.05.

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