PB99-964103
EPA541-R99-076
1999
EPA Superfund
Record of Decision:
Ilada Energy Company Site
East Cape Girardeau, IL
9/27/1999
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Ilada Energy Company Site, IL
DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Ilada Energy Company site
East Cape Girardeau, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action for the Ilada Energy Company
site developed in accordance with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative record for the Ilada Energy
Company site.
The United States Environmental Protection Agency (USEPA), RegionV supports the selected
remedy on the Ilada Energy Superfund site. USEPA and Illinois EPA have determined that their
response at this site is complete. Therefore, the site now qualifies for inclusion on the
Construction Completion List.
DESCRIPTION OF SELECTED REMEDY
No further remedial action is necessary at the Ilada Energy Company site. The earlier removal
action has mitigated the environmental risks to a degree that the conditions at the site pose no
unacceptable risk of exposure to contaminants of concern.
DECLARATION STATEMENT .
It has been determined that no further remedial action is necessary for the purpose of mitigating
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Protection Agency (Illinois EPA) in consultation with USEPA Region V that the selected remedy
is protective of human health and the environment, attains Federal and State requirements that
are applicable or relevant and appropriate for this remedial action (or invokes an appropriate
waiver), and is cost-effective.
Because this remedy requires the maintenance of institutional controls to prevent unacceptable
exposures from hazardous substances over a long period of time, a review will be conducted by
Illinois EPA, in consultation with USEPA, within five years after signature of this Record of
Decision to ensure that the remedy continues to provide adequate protection of human health
and the environment.
The institutional controls that have been instituted consist of the following:
Prohibiting the installation of groundwater wells for the purpose of producing potable
water, and;
• Prohibiting the use, improvement or maintenance of any type of residential purpose;
. Muno, Director
Superfund Divisio^jr
EPA - Region V
/Date
Thomas V. Skinner, Director
Illinois EPA
Date
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SITE NAME. LOCATION. AND DESCRIPTION
The Ilada Energy Company site (the "site") encompasses approximately 17 acres in southern
Illinois, south of the town of East Cape Girardeau in the northwest quadrant of Section 32,
Township 14 South, Range 3 West. The surrounding area is utilized primarily for agricultural
purposes. Farmland borders the site to the northeast, but the remainder is owned by the US
Forest Service and used for silvaculture. The area is relatively flat with a ground surface
elevation of approximately 330 feet above mean sea level. The site is located within the 100-
year floodplain of the Mississippi River on the "dry" side of the 20-foot high flood control levee
which is located immediately to the south of the site. A 200-foot wide slough was formed along
the south toe of the levee as a result of borrowing material for its construction. This area is
swampy during the wet season (approximately Fall through Spring) supporting riparian
vegetation consisting of cattails and other aquatic plants. The quarter-mile wide strip between
the river and the slough comprises wooded areas, dense brush and ground vegetation, and
patches of overgrown, idle cropland.
The main site is surrounded by a locked chain-link fence to restrict access. Prior to the removal
action, there were seven structures and twenty-two bulk oil tanks and numerous underground
pipelines. All were removed from the site along with the tank contents and the grossly
contaminated soil on site. The site is overgrown yearly with native grasses and weeds.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The site originally consisted of a tank farm built for the U. S. Department of War (DOW) in
1942. The location was selected to take advantage of access provided by the Mississippi River.
The facility was operated by Allied Oil Terminal Company as a bulk fuel oil storage/transfer
terminal until the early or mid-1950's. Transfer piping ran across the levee towards the river.
After Allied Terminal ceased using the facility in the mid-1950's, the site sat idle until purchased
by the Kara Oil Company in 1979. In 1982, it was assigned to Larry Wilson of the Ilada Energy
Company (Ilada).
From 1981 to 1983, Ilada operated the tank farm as a waste oil reclamation facility. Additional
tanks and structures were added to the facility in that time period.
Several inspections of the facility were conducted by the Illinois EPA and the USEPA in 1982
and 1983. These inspections revealed that Ilada was improperly storing, handling, mixing, and
disposing waste oils contaminated with PCBs. Ilada and the USEPA entered into a consent
decree and order on January 18, 1983 to correct these deficiencies. Among other action, the
order required the removal "forthwith and without delay" of PCB-contaminated materials in
accordance with TSCA. It also required Ilada to close all activities relating to the receipt,
transportation, storage, handling, use and disposal of PCBs, chemicals, and other wastes. Later
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in 1983, the boiler was removed by Ilada as well as some pumps and related equipment from the
pump house, and office and laboratory equipment were removed from the Office Building. In
1986, the Illinois EPA installed six groundwater monitoring wells on the site. The site was
subsequently proposed for inclusion on the National Priorities List (NPL) pursuant to Section
105 of CERCLA on June 24, 1988. The listing of the site on the NPL was finalized on October
4, 1989. Site visits in 1989 indicated spillage and leakage of oils on the ground near several
tanks and tank valves.
In 1989, after Ilada had make no effort to remove PCB materials from the site, a unilateral .
Administrative Order was issued pursuant to Section 106 of CERCLA. As a result of the Section
106 Order, four of the companies included as PRPs formed the. Ilada Energy Company - East
Cape Girardeau Group. These companies included Shell Oil Company, Metal Container
Corporation, Granite City Steel Division of National Steel, and Emerson Electric Company. The
group was then ordered to initiate a Remedial Investigation (RI) to determine the source, nature
and extent of the contamination at the site following the removal action.
The final RI was finalized and approved by Illinois EPA in April of 1999. The human health
Baseline Risk Assessment (HHRA) and Ecological Risk Assessment (ERA) were finalized and
approved by Illinois EPA in July of 1999.
COMMUNITY RELATIONS
The Illinois EPA has been responsible for conducting a community relations program for the site.
Concern about the site has remained low, due to its remote location and the fact that on-site
groundwater contamination has shown no apparent affect on nearby residential and agricultural
wells. Some of the local residents were aware of the environmental problems associated with the
site prior to the removal action, but awareness of the potential environmental and public health
threats posed by the site is primarily due to regulatory activities and investigations carried out by
the Illinois EPA and USEPA.
The community relations program at the Ilada Energy site was designed to allow the nearby
communities to learn about and participate in the Superfund remedial process, without disrupting
the communities' confidence that the site posed no new or immediate hazards. The community
relations plan focused on:
• informing nearby residents, operators of farms and commercial properties, and other
interested citizens about the Superfund process, project plans, progress, and problems;
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• ensuring that all local, state, and federal officials who have interest in the site are kept
informed of the project plans, progress, and problems;
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• identifying additional issues, changing concerns, and misconceptions of the affected ^^
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community;
• providing accurate and timely information to the news media;
• preventing the development of unrealistic expectations, especially regarding the timing of
actions at the site and possible local employment effects of the project;
• providing timely and accurate responses to inquires regarding the project;
• setting up the local repository for project documents and reports. A separate repository
was established and maintained to hold the administrative record for this site;
• noticing the nearby residents and potentially affected persons of the proposed plan along
with a minimum thirty-day comment period; and
• conducting a public hearing in accordance with section 117(a)(2) of CERCLA.
SCOPE AND ROLE OF RESPONSE ACTION
The proposed response action is No Further Action. The site-wide removal action already
conducted is the final action for this site.
SUMMARY OF SITE CHARACTERISTICS
The Remedial Investigation identified and defined the extent of the site impact following the
removal action from previous activities associated with site operations. The information
generated supported the risk assessment conducted to evaluate the current or potential human
health or environmental hazards associated with the site. The following approach was used:
1. Determine the hydrogeologic characteristics of the unconsolidated units beneath the site
to evaluate this as a potential migration pathway and the hydrologic and geotechnical
parameters that may affect potential groundwater remediation technologies;
2. Determine the nature and extent of any impacted soil remaining at the site following the
removal action;
3. Evaluate the nature and extent of any impact in the groundwater;
4. Evaluate the potential for off-site migration of constituents in sediments or surface waters
during site flooding events;
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5. Compile existing information on plant and animal species in the general vicinity of the
site;
6. Prepare a risk assessment to evaluate and quantify the risk to health and the environment
of any residual constituents remaining after the completion of the removal action;
7. Perform a topographical survey, locate sampling points, maintain a record of the locations
of important features, and prepare base maps for site figures;
8. Survey the number of residents and domestic drinking water wells within two miles of
the site; and
9. Assess the nature and amount of the source of the constituents via records search, tank
and pipeline sampling, and interviews with former employees of the Ilada Energy
Company.
General Conclusions from the Remedial Investigation
All structures used by Ilada Energy, including foundations, tanks, aboveground and buried
pipelines (including those south of the levee), debris, and grossly impacted soils were removed as
part of the removal action. The only remnants of the tank farm are the repaired seven-foot high
perimeter fence, roads, subdued remnants of the six berms around the tank areas, and the former
site production water well. Nearly all of the brush and trees were removed during the removal
action. Weeds and brush have reestablished a vegetative cover since completion of site
activities.
With the exception of a localized pool of subsurface aviation gasoline, no continuing source of
constituents associated with site operations remains on the site. The lateral extent of this pool
has been fully delineated and is confined to an area of about 50 by 75 feet. This pool was
observed in one monitoring well, D12. Subsurface investigation in the area of D12 revealed that
the pool is discontinuous and is not present as a contiguous pool of mobile liquid floating on the
groundwater. All other materials and potential sources, including grossly impacted surficial
soils, were removed during the removal action.
The RI report yielded information regarding the nature and extent of the contamination
remaining at the site including the following:
• The site surface and subsurface soils contain generally low levels of Volatile Organic'
Compounds (VOC's) and Semi-Volatile Organic Compounds (SVOC'S);
• A localized subsurface pocket of Light Non-Aqueous Phase Liquid (LNAPL) composed
of aviation gasoline remains from the site's original use as a fuel storage depot
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approximately 40 years ago. The lateral extent of this pocket measures approximately 50
by 75 feet, and it is entirely contained on the site; and
The adjacent properties to the south, east, west, and north are unavailable for future
development because they were acquired in 1997 as part of a federal flood control
program.
SUMMARY OF SITE RISKS
The removal action conducted between 1989 and 1991 substantially mitigated the health and
environmental threats posed by this site. This action resulted in the removal from the site of all
tanks and their contents, piping, structures, and grossly contaminated soils. A total of 442,162
gallons of oil and sludge were sent offsite to be burned as waste fuel in cement kilns; 142,700
gallons of PCB contaminated oil and sludge were incinerated at a permitted off-site facility;
865,700 gallons of contaminated water were treated and discharged to the river after testing
showed that it met Clean Water Act standards; 1055 cubic yards of soil and miscellaneous debris
were disposed offsite as special waste; 637 cubic yards were disposed offsite as demolition
debris; fifty cubic yards of PCB-contaminated soil were landfilled at a permitted offsite facility;
and 1264 tons of steel were recycled. All wastes were removed from the site and treated or
disposed elsewhere.
Human Health Risks
In conducting this assessment, the focus was on the health effects that could result from direct
exposure to the contaminants as a result of the soil coming into contact with the skin, from
accidental direct ingestion of the soil, or from inhalation of contaminants.
While redevelopment of the site is severely limited by both physical conditions (i.e., frequent
flooding) and institutional controls (i.e., state regulations or local ordinances and Declaration of
Covenants regarding groundwater usage), an exposure scenario was needed to gauge the risk
from the site. The analysis was conducted based upon a commercial/industrial scenario. Under
this scenario, commercial/ industrial workers, construction workers, and trespassers could
contact environmental media.
One area of potential public concern is a small (50 feet by 75 feet area) area where aviation fuel
contamination dating from the mid-1950s is still present. The presence of this area of
contamination is not considered to be a threat. Analysis of groundwater flow and the nature of
the area of contamination has shown that this contamination has little or no chance to migrate
offsite. Restrictions agreed to by the responsible parties requires special safety plans before any
construction or excavation is conducted in that or any area of the site. In addition, institutional
controls are in place to restrict the use of groundwater at the site.
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The RI sampling was performed after the removal action, and the determination of risks at the
site was made reflecting conditions present after the removal. The corresponding Human Health
Risk Assessment was performed using the RI as a source of data. The Human Health Risk
Assessment concludes that the excess lifetime cancer risk at the site is 2.2 X 10'6. This means
that if no further action is taken at the site, a person working on the site would increase his or her
chances of contracting cancer by approximately one chance in 450,000 as a result of exposure to
remaining low levels of contaminants at the site. This number falls well within the range of 10-4
to 10'6 excess cancer risk that is normally considered acceptable under Illinois programs and
U.S. EPA guidance. Based upon evaluation of these findings, the site no longer poses an
unacceptable risk.
During the RI, an analysis was conducted to estimate the health and environmental problems that
could result from the residual soil and groundwater constituents at the Ilada Energy site after the
completion of the removal action at the site. This analysis is commonly known as the Human
Health Risk Assessment and Ecological Risk Assessment. The HHRA was completed based on
a standard commercial/industrial land use scenario. Under this land use, commercial/industrial
workers, construction workers, and trespassers could contact environmental media. The
approach for evaluating this potential contact is consistent with the Illinois EPA's Tiered
Approach to Corrective Action Objectives (TACO) and USEPA requirements under CERCLA.
Selection of Contaminants of Potential Concern (COPCs)
COPC's in both soil and groundwater were selected based on comparison with local background
levels (inorganic constituents only), and detection frequency, prior to comparison to screening
levels. Specific information can be located in the HHRA.
Comparison of Local Background
Local background levels as determined by site specific sampling and as provided by Illinois EPA
were used to identify constituents that could be eliminated as COPCs because their
concentrations are indistinguishable from natural background.
Soils: The comparisons and supporting analysis supports the conclusion that arsenic, aluminum,
barium, beryllium, cadmium, chromium, cobalt, cyanide, iron, manganese, nickel, and vanadium
are present in soil at levels that are consistent with local background. Therefore, these elements
were eliminated from further analysis in the risk assessment. Lead was eliminated only from the
subsurface data set based on this comparison.
Groundwater: Background groundwater quality was also evaluated for both inorganic and
organic COPCs . Using regional background concentrations for inorganic chemicals, the
evaluations showed that aluminum, arsenic, iron, lead, manganese, mercury and thallium were
detected in the shallow monitoring wells, at levels that exceeded background levels as reported
by the United States Geological Survey (USGS). Inorganic concentrations decreased with depth
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and levels similar to those of background were found in the intermediate and deep wells. None
of the organic COPCs were eliminated from groundwater consideration based on local
background levels.
Frequency of Detection
Dose is dependent, in part, on frequency of contact. USEPA provides that, under appropriate
conditions, chemicals detected in less than 5% of the samples may be eliminated from the data
set used in the risk assessment. At this site, several constituents detected in a low percentage, of
samples were eliminated from the data set.
Exposure Assessment
An exposure pathway defines a probable path by which a receptor may come in contact with an
affected media (i.e., soil, groundwater). There must be a source, a transport mechanism, a point
of contact, and a route of exposure (i.e., inhalation, ingestion, dermal contact.) to constitute a
complete exposure pathway. Each of these four necessary items were evaluated. Groundwater
use and residential construction have been precluded by a Declaration of Covenant which has
been attached to the property deed.
Receptor dose is estimated once potentially complete exposure pathways are identified and
representative COPC concentrations are established. The Reasonable Maximum Exposure
(RME) scenario for each calculation reflects both the 90th and 95th percentile of the possible
exposure. The intent of the RME scenario is to focus the assessment on conservative exposure
assumptions that remain reasonable.
• Sources: After the Removal Action, only residual constituents remain in the soil and
groundwater of the site. These residual constituents were evaluated as potential source
areas. In addition, the small area of residual LNAPL was evaluated.
• Transport Mechanism: Potential migration pathways for soil and ground water were
migration of constituents from soil to groundwater, migration of constituents through
groundwater, and migration of constituents from soil to ambient air.
• Point of Contact: Two exposure classifications were used for purposes of determining
risk: On-site and Off-site exposure classifications. Potential exposure pathways were
based upon the hypothetical commercial/industrial use of the property.
• Route of Exposure: On-Site: Groundwater use as a drinking water source is precluded
by a declaration of covenant on the property and was not evaluated as a complete
exposure pathway. However, both direct contact with soil (incidental ingestion,
inhalation of dust) and inhalation of vapor from both surface and subsurface soil was
evaluated. The two scenarios evaluated are for the on-site scenario for the
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commercial/industrial worker and the construction worker.
Off-Site: The only two pathways evaluated as potentially complete for off-site receptors
was ingestion of potable groundwater and inhalation of impacted fugitive dust. Property
immediately surrounding the site is not available for residential or commercial
development due to restrictions placed upon the property by the US Forest Service. In
addition, all adjacent property is unsuitable for residential development due to frequent
flooding. The closest drinking water wells are located approximately one quarter mile
north of the site and is anomalous in that the property is a residence situated on a very
limited hill which limits influence from seasonal flooding. Nevertheless, the potential for
off-site groundwater to be impacted was evaluated further.
Toxicity Assessment
Medium and chemical-specific criteria were developed for the COPCs whose maximum
concentrations exceeded TACO screening levels. These criteria are developed using toxicity
values that integrate toxicity and dose (or contact medium concentration).
Carcinogenic Effects: Carcinogens are agents that may induce cancer. Both known and probable
carcinogens were evaluated for purposes of this analysis. Numerical estimates of cancer potency
known as slope factors (SF) define the cancer risk due to constant lifetime exposure to a set unit
of a carcinogen.
Non-Carcinogenic Effects: Reference doses (RfDs) and airborne reference concentrations (RfCs)
are toxicity values for non-carcinogenic effects. These values are developed based on the
assumption that thresholds exist for non-carcinogenic effects. Generally, RfDs and RfCs are
estimates of a daily exposure to the human population that is likely to be without an appreciable
risk of negative effects during a lifetime of exposure.
Risk Characterization
Excess lifetime cancer risks are determined by multiplying the intake level with the cancer
potency factors These risks are probabilities that are generally expressed in scientific notations
(e.g., 1 X 10'6). An excess lifetime cancer risk of 1 X 106 indicates that, as a plausible upper
bound, and individual has a one in one million chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions at
a site.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's reference dose). By adding
the HQs for all contaminants within a medium or across all media to which a given population
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may reasonably be exposed, the Hazard Index (HI) can be generated. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposures within a
single medium or across media.
Soils:
Potential risks associated with the site were evaluated by comparing the cleanup objectives with
representative concentrations of COPCs in these media to calculate hazard quotients for non-
carcinogenic effects and cancer risks for carcinogenic effects. Risks and hazards associated with
a commercial or industrial use of the site were first evaluated based on a comparison to chemical-
specific and media-specific criteria. The results for each were then summed up to provide a
better understanding of the site as a whole. Representative constituent concentrations in surface
and subsurface soil and groundwater do not exceed risk-based screening criteria for potentially
completed pathways on-site.
Potential cancer risks were estimated for each pathway by summing the ratio of the
representative concentration in soil with the criteria developed based on an excess lifetime cancer
risk of 1.0 X 10'6. The total risk for the site is 2.2 X 10 "6. The cumulative risk level is within the
target range of 1 X 1 Cr4 and 1 X 10'6 established by CERCLA.
The risk of non-cancer effects occurring was estimated by calculation of an HQ for each COPC.
Risks were estimated by summing the HQs to provide a hazard index associated with the
commercial/industrial use of the site. Chemical specific HQs based on this worker scenario are
given in the HHRA. The cumulative HI for the site is 3.6 X 10'2. Because this value does not
exceed the target HI of 1, the risk of non-cancer effect occurring at the site falls within an
acceptable range under CERCLA.
Groundwater:
Groundwater impacted by the site is not considered to be a potentially complete pathway for the
following reasons:
• Use of on-site groundwater is precluded by a declaration of covenant;
• The nearest drinking water well is north of the site at a distance of approximately 1/4 of
one mile north of the site;
• The only property available for development is northeast of the site;
• Vector analysis shows that the resultant groundwater flow direction is toward the
Mississippi River and away from potable water supplies; and
• For screening purposes, the maximum concentrations of site COPCs detected on-site
were compared to drinking water criteria to address the potential of off-site groundwater
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to be adversely impacted. For those chemicals detected above this criteria, calculations
indicate that groundwater flowing off-site would diminish to below the screening level
within 850 feet of the well where the maximum concentrations were detected. The
detected metals concentrations were orders of magnitude lower in shallow wells OD-1
and OD-2 located approximately 250 feet downgradient of the wells where the maximum
concentrations on site were detected indicating that shallow groundwater is not highly
mobile.
LNAPL Area:
The HHRA draws the conclusion that the LNAPL area does not present an unacceptable risk for
a commercial/industrial scenario provided the appropriate administrative controls are instituted at
the site:
• Groundwater ingestion is precluded at the site and exposure to groundwater impacted by
the LNAPL will not occur. Vector analysis of groundwater flow indicate that the
constituents will not impact off-site sources; and
• Site data will be provided to support the development of the appropriate health and safety
plan prior to any presumed excavation activities.
Short-Term Exposure to Subsurface Constituents:
Construction workers were included in the analysis, and levels detected on-site did not exceed
the applicable media-specific subchronic and chronic criteria. Acute and short term health
concerns are to be addressed via a health and safety plan based upon data collected in the RI and
prepared under the Occupational Safety and Health Act (OSHA).
ECOLOGICAL ASSESSMENT
An Ecological Risk Assessment (ERA) was conducted at the Ilada Energy Company Site to
evaluate the potential threats to ecological receptors associated with COPCs at the site. The
areas evaluated were both north and south of the flood control levee, assuming no further
reaction beyond the removal action already conducted. The assessment of potential risk to area
biota is conducted in a different manner than that of the HHRA. The HHRA addresses
individuals while the general intent of the ERA is to protect populations. An exception to this
rule is applied when addressing any threatened or endangered species as defined under the
Endangered Species Act.
South of the Levee:
The area south of the levee studied the narrow strip of the property south of the flood control
levee which was the corridor for the buried pipeline that was removed in 1990. Because part of
the corridor south of the levee is designated as a wetland, it was evaluated as a potentially viable
aquatic or riparian habitat for key species of wildlife.
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Data evaluation/collection efforts identified the following potential constituents of concern in
subsurface soil, including:
• Toluene and tetrachloroethene;
• Low and high molecular weight polynuclear aromatic hydrocarbons;
• Bis-2-ethylhexylphthatlate; and
• Tetrachlorodibenzofuran and octachlorodibenzo-p-dioxin.
The potential exposure pathways are based on the following soil and water borne exposures:
• Pathway 1—Ingestion of temporary surface water;
« Pathway 2—Ingestion of contaminated soil/sediment;
• Pathway 3~Dermal contact with contaminated soil/sediment;
• Pathway 4~Ingestion of contaminated prey; and
• Pathway 5—Ingestion of contaminated vegetation.
Five terrestrial species (three birds and two mammals) present in the pipeline corridor area were
selected as receptors of concern based on criteria which ensure that no other species are likely to
be more exposed to site-related potential COPCs. Calculated values of the HQ for both the avian
and mammalian indicator species lie below the 1.0 benchmark. This result indicates that chronic
toxicity from the pipeline corridor COPCs found in the soils is not expected.
There is no permanent body of surface water between the flood control levee and the Mississippi
River. Temporary pools of surface water in this area were considered to be the most likely
exposure pathway, and were evaluated as such. The HQ for each aquatic species was below 1.0.
North of the Levee:
The portion of the site north of the levee differs from the area south of the levee in that it is
fenced and on the "dry" side of the levee. Also in contrast to the south side, this area is fenced.
The following compounds were identified as COPCs:
• Metals—copper and zinc;
• Volatile organic compounds—chloroform, methylene chloride, toluene, and
tetrachloroethene;
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• Low and high molecular weight polynuclear aromatic hydrocarbons;
• Three phthalates;
• Hepta- and octachlorinated dioxin/furan congeners;
PCBs; and
• Endodulfan sulfate and DDT
COPCs were not found in the surface water samples. In addition, there are no permanent
population of aquatic receptors north of the flood control levee.
Two representative terrestrial species were selected for the area north of the levee: the
earthworm and American robin. Risk analyses for both receptors were performed using
measured COPC data and identified potential pathways. All hazard quotients were below 1.0.
Description of "No Further Action" Decision
Capital Cost: SO
Annual Operating Cost: $0
(O&M) Costs: $0
Present Worth (PW) $0
Months to Implement: None
The Superfund program requires that the "No Further Action" alternative be evaluated at every
site to establish a baseline for comparison. In the case of the Ilada Energy Superfund site, the
Illinois EPA have a pre-existing agreement from the responsible parties that require the removal
of all monitoring wells and the old production well from the site along with other remaining
miscellaneous debris. No additional action would be required at the site, since the removal
action already implemented at the site would be deemed sufficient to meet all cleanup goals.
Documentation of Significant Changes:
The Proposed Plan for the Ilada Energy Superfund site was released for public comment in July
1999. The Proposed Plan identified the "No Further Action" alternative as the preferred and only
alternative for the site. Illinois EPA reviewed all written and verbal comments submitted during
the public comment period. None were received. It was determined that no significant changes
to the remedy, as originally identified in the Proposed Plan, were necessary or appropriate.
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RESPONSIVENESS SUMMARY
Ilada Energy Company Superfund Site
East Cape Girardeau, Illinois
Responsiveness Summary Overview
In accordance with CERCLA Section 117,42 U.S.C. Section 9617, the Illinois Environmental
Protection Agency (Illinois EPA) held a public comment period from August 9, 1999 through
September 7, 1999, to allow interested parties to comment on the Proposed Plan/Fact Sheet, July
1999, for this site. The Proposed Plan provides for no further remediation beyond that
accomplished already during the Removal Action carried out between 1989 and 1991.
The purpose of this Responsiveness Summary is to document the Illinois EPA's efforts to
1) inform the public of the pending decision on this Proposed Plan, to
2) provide the public with a summary of the technical details of the past Removal Action
and the current environmental conditions at the site, to
3) inform the public of the ready availability, much more detailed information about the
site, in the form of locally available Site Information Repositories and an
Administrative Record for the site, to
4) inform the public of the opportunity for interested-parties to comment on the Proposed
Plan either in person at a locally held Public Hearing or by mail during the public
comment period, and to
5) provide the opportunity to comment by holding both the Public Hearing and the 30-
day comment period.
Had there been any public comments or questions, this document would provide the Illinois
EPA's detailed responses to all questions, concerns, and comments raised during the comment
period or the Public Hearing. However, no comments were received regarding the Proposed
Plan, and only two people attended the Public Hearing, with both serving only as observers for
official bodies or interested parties, and neither offering formal comments.
Site History
The Ilada Energy Company Site is a 16.743 acre abandoned tank farm which formerly had
twelve million gallons of tank storage capacity. The facility is located southeast of East Cape
Girardeau in a rural setting next to the Mississippi River levee. In the 1980's the site was found
to contain oil, sludge, and contaminated water, some of which contained a variety of hazardous
and toxic substances including toxic heavy metals, industrial solvents, and PCBs
(Polychlorinated Biphenyls).
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The site came under Illinois EPA scrutiny in 1982 when an inspection report showed that the
Ilada Energy Company was improperly storing, handling, mixing, and disposing of waste oils
contaminated with PCBs. Stained soil near several of the tanks prompted several sampling
events and installation of several groundwater monitoring wells. These and subsequent sampling
events led to its addition to the National Priority List on October 4, 1989 and the subsequent
Removal Action.
The 1989 Administrative Consent Order named Emerson Electric Company of St. Louis, MO,,
Granite City Division of National Steel Corporation, Metal Container Corporation of St. Louis,
MO., and Shell Oil Company of Houston Texas as cooperating responsible parties. The consent
order binds these parties to perform a Removal Action and conduct a remedial investigation.
The Removal Action began in December of 1989 and was completed by March of 1991. Of the
original onsite structures, only the repaired fence and the water well remain.
The RI report yielded information regarding the nature and extent of the contamination
remaining at the site including the following:
• The site surface and subsurface soils contain generally low levels of Volatile Organic
Compounds (VOC's) and Semi-Volatile Organic Compounds (SVOC'S).
• A localized subsurface pocket of aviation gasoline remains from the site's original use as
a fuel storage depot approximately 40 years ago. The lateral extent of this pocket
measures approximately 50 by 75 feet, and it is entirely contained on the site.
• The adjacent properties to the south, east, west, and north are unavailable for future
development because they were acquired in 1997 as part of a federal flood control
program.
Scope and Role of Removal Action
The removal action conducted between 1989 and 1991 substantially mitigated the health and
environmental threats posed by this site. This action resulted in the removal from the site of all
tanks and their contents, piping, structures, and grossly contaminated soils. A total of 442,162
gallons of oil and sludge were sent offsite to be burned as waste fuel in cement kilns; 142,700
gallons of PCB contaminated oil and sludge were incinerated at a permitted off-site facility; 865,700
gallons of contaminated water were treated and discharged to the river after testing showed that it
met Clean Water Act standards; 1055 cubic yards of soil and miscellaneous debris were disposed
offsite as special waste; 637 cubic yards were disposed offsite as demolition debris; fifty cubic yards
of PCB-contaminated soil were landfilled at a permitted offsite facility; and 1264 tons of steel were
recycled. All wastes were removed from the site and treated or disposed elsewhere.
Based upon the Risk Assessment performed, the Removal Action undertaken is the final action at
the site. The Illinois EPA has determined that no further action is warranted at the Ilada site.
-------
Summary of Site Risks
During the RI, an analysis was conducted to estimate the health and environmental problems that
could result if the soil and groundwater contamination at the Ilada Energy site was not addressed any
further. This analysis is commonly known as the Baseline Risk Assessment and Ecological Risk
Assessment.
In conducting this assessment, the focus was on the health effects that could result from direct
exposure to the contaminants as a result of the soil coming into contact with the skin, from
accidental direct ingestion of the soil, or from inhalation of contaminants.
While redevelopment of the site is severely limited by both physical conditions (i.e., frequent
flooding) and institutional controls (i.e., state regulations or local ordinances and Declaration of
Covenants regarding groundwater usage), an exposure scenario was needed to gauge the risk from
the site. The analysis was conducted based upon a commercial/industrial scenario. Under this
scenario, commercial/ industrial workers, construction workers, and trespassers could contact
environmental media.
One area of potential public concern is a small (50 feet by 75 feet area) area where aviation fuel
contamination dating from the mid-1950s is still present. The presence of this area of
contamination is not considered to be a threat. Analysis of groundwater flow and the nature of the
area of contamination has shown that this contamination has little or no chance to migrate offsite.
Restrictions agreed to by the responsible parties require special safety plans before any construction
or excavation is conducted in that or any area of the site. In addition, institutional controls are in
place to restrict the use of groundwater at the site.
The RI sampling was performed after the removal action, and the determination of risks at the site
was made reflecting conditions present after the removal. The corresponding Baseline Risk
Assessment was performed using the RI as a source of data. The Baseline Risk Assessment
concludes that the excess lifetime cancer risk at the site is 2.2 X 10'6. This means that if no further
action is taken at the site, a person working on the site would increase his or her chances of
contracting cancer by approximately one chance in 450,000 as a result of exposure to remaining low
levels of contaminants at the site. This number is much less than the 10"4 excess cancer risk that is
normally considered acceptable under Illinois programs and U.S. EPA guidance. Based upon
evaluation of these findings, the site no longer poses an unacceptable risk.
For comparison, it can be noted that the "background," or pre-existing risk shared by all Americans,
of contracting cancer in a lifetime is a probability between one in four and one in three (a 25% to
33% chance). The "excess risk" risk calculated in the Baseline Risk Assessment that would result
from exposure to current site conditions thus adds only two ten-thousandths of a percentage point
to this risk, which U.S. EPA and Illinois EPA guidance considers acceptable.
-------
Final Remedy Decision
The Superfund program requires that the "No Further Action" alternative be evaluated at every site
to establish a baseline for comparison. Under this decision, the Illinois EPA has a pre-existing A
agreement from the responsible parties that requires the removal of all monitoring wells and the old
production well from the site. No additional action would be required at the site, since the Removal
Action already implemented at the site would be deemed sufficient to meet all cleanup goals. *
The selected remedy for the Ilada Energy site is "No Further Action" because the risk level at the
site is within the limits accepted by the Illinois EPA and U.S. EPA.
Public Notification, Public Hearing, and Public Comment Period
Prior to making a decision on the final remedy for this site, the Illinois EPA was required to hold a
minimum 30-day public comment period to allow the public an opportunity to comment on the
Proposed Plan of No Further Action at this site. Illinois EPA prepared a Fact Sheet/Proposed Plan,
which included an announcement of the Public Hearing and comment period, and mailed it to all the
interested parties on its Contact List for this site. A copy of the Public Notice regarding the Public
Hearing and the public comment period was also included in each mailing. In addition to all nearby
neighbors of the site, the Contact List contains elected officials in all nearby Illinois towns, County
officials, State and Federal elected officials, five newspaper outlets serving the area, three local
television stations serving the area, and eight local radio news outlets. In addition to mailing copies
of the Fact Sheet and Public Notice to the news outlets, Illinois EPA also faxed copies to the
newsrooms, in early August, 1999, prior to the start of the comment period. 4Bb
Illinois EPA arranged for a large display advertisement, announcing the forthcoming public
comment period and Public Hearing, to be published in the Cape Girardeau Southeast Missourian
newspaper, the most widely read local daily newspaper for the site area. The ad was published on
July 26, August 2, and August 9, 1999, to comply with Illinois EPA regulations regarding public
notice for formal hearings, and to assure that interested parties would be aware of the Proposed Plan
and the opportunity for public involvement. The Site Information Repositories and Administrative
Record for the site were updated, and copies of the Fact Sheet/Proposed Plan were added to both
Repositories to make them more widely available to interested parties who might not be on the site
Contact List. The Fact Sheet also contained contact information for both the Illinois EPA's
Community Relations Coordinator and Project Manager for the site. Aside from a few contacts from
news media outlets, Illinois EPA staff had no inquiries about the comment process.
The Public Hearing was held at 7 p.m. on August 26, 1999 at the Bud Pearce Community Center in
East Cape Girardeau, Illinois. Only two persons attended the Public Hearing, one from the County
Sheriffs office and one contractor for the Responsible Parties at the site. Both attendees were
present only as observers and offered no formal comments. No comments were received by mail,
fax, or e-mail during the comment period. Illinois EPA staff draw the conclusion that the interested
public is satisfied with plans to require no further remediation at this site.
-------
For Further Information
Questions about the hearing process and about access to exhibits should be directed to John
Williams, Illinois EPA Hearing officer, Division of Legal Counsel, Illinois EPA, 1021 North
Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276, or phone at
217/782-5544.
Questions about the Proposed Plan or the Removal Action should be directed to Fred Nika,
Project Manger, Bureau of land, Illinois EPA, 1021 North Grand Avenue East, P.O. Box 19276,
Springfield, Illinois 62794-9276 or phone at 217/782-3983.
Questions about the public notification process or this Responsiveness Summary should be
directed to Stan Black, Office of Community Relations, Illinois EPA, 1021 North Grand Avenue
East, P.O. Box 19276, Springfield, Illinois 62794-9276, or phone at 217/785-1427.
All documents used by Illinois EPA in formulating the Proposed plan for this site are contained
in the Administrative Record for this site, located at the Reference Section, Cape Girardeau
Public Library, 711 North Clark Street, Cape Girardeau, Missouri 63701, phone 573/334-5279.
Additional copies of this Responsiveness Summary can be obtained from Stan Black, at
217/785-1427.
Thanks to the Citizens Who Became Involved
On behalf of Director Thomas Skinner and the staff of the Illinois EPA, we would like to thank
all who have taken the time to get involved over the years regarding this site.
Signed:
Illinois EPA Hearing Officer
Signed:
Illinois EPA Project Manager
Signed:
Illinois EPA Community Relations Coordinator
Illinois Environmental Protection Agency Dated: ,1999
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
-------
-------
ADMINISTRATIVE RECORD INDEX
ILADA ENERGY SUPERFUND SITE
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
JULY 12,1999
UPDATE #1
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), requires the establishment of an Administrative Record upon which the Agency bases
its decision when selecting the alternatives for the Remedial Action process.
The Illinois Environmental Protection Agency (IEPA) has compiled the following official
Administrative Record Index for the Ilada Energy Superfund Site located in East Cape
Girardeau, Illinois. This index as well as the Administrative Record itself will be updated when
necessary by the IEPA.
Please contact Stan Black (P.O. Box 19276, 1021 North Grand Avenue, East, Springfield,
Illinois 62794-9276, 217/785-1427) for more information on who and where to direct questions
concerning this index.
Doc.
#
1
2
3
4
5
6
7
Document Title
Remedial Investigation/Feasibility Study (RI/FS)
Workplan
Corr. To D&M: RI/FS Workplan Approval
Health and Safety, Implementation Plans
Corr. to Division File-RE: Contact Rule Interp.
Health Assessment
Corr. To Babst, Calland, Clements, and Zomnir-
RE: Risk Assessment
Minutes of Phase II Scoping Meeting
Issue
Date
1-10-90
1-29-90
3-29-90
8-27-90
9-26-90
10-30-90
1-3-91
Author
Dames & Moore (D&M)
Stephen Washbum-
Illinois Environ-mental
Protection Agency
(IEPA)
D&M
Stephen Washburn-
IEPA
US Dept. Of Health and
Human Serv.
Allison Kilmer-United
States Environmental
Protection Agency
(USEPA)
D&M
#
Pages
545
3
71
1
13
6
5
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Doc.
#
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Document Title
Notice of Intent to Proceed
Corn to D& M
Corr. to IEPA-RE: RI/FS Oversight
RI/FS Workplan Addendum Phase 2
Phase 1 RI/FS Incorporation of IEPA and USEPA
Comments
Corr. to D&M-RE: Risk Assessment
Approval of RI/FS Workplan Addendum
Approval of Ph. 2 RI/FS Workplan
Corr. to USEPA-RE: Removal Action Completion
Corr. to USEPA & IEPA-RE: Additional
Monitoring Well
Corr. to USEPA & IEPA-RE: Additional
Monitoring Well
Corr. to D&M-RE: Notice to Proceed
Corr. To D&M-RE: Free Product Layer
Removal Action Summary Report
Documentation Results-Free Product Layer
Corr.-RE: Workplan Addendum #4
Workplan Addendum #4
Replacement Page for Workplan Addendum #4
Workplan Addendum #4 Approval
Replacement Page Approval
Oversight of Scope of Work (SOW)
RI/FS Workplan Addendum #6
Notice to Proceed to D&M
Issue
Date
1-11-91
1-24-91
2-1-91
3-15-91
5-3-91
5-7-91
5-9-91
5-17-91
12-30-91
2-10-92
2-19-92
3-5-92
7-2-92
7-24-92
10-15-92
2-5-93
2-5-93
2-17-93
3-1-93
3-2-93
10-15-93
12-14-93
3-15-94
Author
D&M
Allison Hiltner-USEPA
Ecology and
Environment (E&E)
D&M
D&M
Allison Hilrner-USEPA
USEPA
Stephen Washburn-
IEPA
Stephen Washbum-
IEPA
D&M
D&M
Stephen Washburn-
IEPA
USEPA
D&M
D&M
D&M
D&M
D&M
Charlene Falco-IEPA
USEPA
Charlene Falco-IEPA
D&M
Charlene Falco-IEPA
#
Pages
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7
217
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1
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Doc.
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31
32
33
34
35
36
37
38
39
40
41
42
Document Title
Project Manager Change-Corr.
Removal Action Completion Documentation
Corr. to Fred Nika-RE: Final Pollution Report and
Completion Report
Floating Product Layer Identification
Corr. to Fred Nika-RE: Floating Layer
Legal Description of Property Surrounding Site
Evaluation "of Composition of Floating Product
Layer
Floating Layer Classification
Revision #2, RI Report Volumes 1,2, and 3
Corr. to D&M-RE: Ecological Risk Assessment
and RJ comments
Final Volume 1 of RI Report
Approval of RI Report
Issue
Date
7-21-94
3-10-95
3-20-95
9-27-95
12-27-95
1-18-96
7-11-96
1-8-97
10-97
12-1-98
3-8-99
4-19-99
Author
Charlene Falco-IEPA
Fred Nika-IEPA
Kenneth Theisen-
USEPA
D&M
USEPA
John Varro- US Forest
Service
Chi Fan-USEPA
Fred Nika-IEPA
D&M
Fred Nika-IEPA
D&M
Fred Nika-IEPA
#
Pages
1
4
5
15
2
6
2
1
1562
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1
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ADMINISTRATIVE RECORD INDEX
ILADA ENERGY SUPERFUND SITE
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
AUGUST 2,1999
UPDATE #2
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), requires the establishment of an Administrative Record upon which the Agency bases
its decision when selecting the alternatives for the Remedial Action process.
The Illinois Environmental Protection Agency (IEPA) has compiled the following official
Administrative Record Index for the Ilada Energy Superfund Site located in East Cape
Girardeau, Illinois. This index as well as the Administrative Record itself will be updated when
necessary by the IEPA.
Please contact Stan Black (P.O. Box 19276,1021 North Grand Avenue, East, Springfield,
Illinois 62794-9276, 217/785-1427) for more information on who and where to direct questions
concerning this index.
Doc.
#
1
2
3
4
5
6
7
Document Title
Remedial Investigation/Feasibility Study (RI/FS)
Workplan ,
Corr. To D&M: RI/FS Workplan Approval
Health and Safety, Implementation Plans
Corr. to Division File-RE: Contact Rule Interp.
Health Assessment
Corr. To Babst, Calland, Clements, and Zomnir-
RE: Risk Assessment
Minutes of Phase II Scoping Meeting
Issue
Date
1-10-90
1-29-90
3-29-90
8-27-90
9-26-90
10-30-90
1-3-91
Author
Dames & Moore (D&M)
Stephen Washbum-
Illinois Environ-mental
Protection Agency
(IEPA)
D&M
Stephen Washburn-
IEPA
US Dept. Of Health and
Human Serv.
Allison Hiltner-United
States Environmental
Protection Agency
(USEPA)
D&M
#
Pages
545
3
71
1
13
6
5
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Doc.
#
8
9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
26
27
28
29
30
Document Title
Notice of Intent to Proceed
Corr. to D& M
Corr. to IEPA-RE: RI/FS Oversight
RI/FS Workplan Addendum Phase 2
Phase 1 RI/FS Incorporation of IEPA and USEPA
Comments
Corr. to D&M-RE: Risk Assessment
Approval of RI/FS Workplan Addendum
Approval of Ph. 2 RI/FS Workplan
Corr. to USEPA-RE: Removal Action Completion
Corr. to USEPA & IEPA-RE: Additional
Monitoring Well
Corr. to USEPA & IEPA-RE: Additional
Monitoring Well
Corr. to D&M-RE: Notice to Proceed
Corr. To D&M-RE: Free Product Layer
Removal Action Summary Report
Documentation Results-Free Product Layer
Corr.-RE: Workplan Addendum #4
Workplan Addendum #4
Replacement Page for Workplan Addendum #4
Workplan Addendum #4 Approval
Replacement Page Approval
Oversight of Scope of Work (SOW)
RI/FS Workplan Addendum #6
Notice to Proceed to D&M
Issue
Date
1-11-91
1-24-91
2-1-91
3-15-91
5-3-91
5-7-91
5-9-91
5-17-91
12-30-91
2-10-92
2-19-92
3-5-92
7-2-92
7-24-92
10-15-92
2-5-93
2-5-93
2-17-93
3-1-93
3-2-93
10-15-93
12-14-93
3-15-94
Author
D&M
Allison Hiltner-USEPA
Ecology and
Environment (E&E)
D&M
D&M
Allison Hiltner-USEPA
USEPA
Stephen Washburn-
IEPA
Stephen Washbum-
IEPA
D&M
D&M
Stephen Washburn-
IEPA
USEPA
D&M
D&M
D&M
D&M
D&M
Charlene Falco-IEPA
USEPA
Charlene Falco-IEPA
D&M
Charlene Falco-IEPA
#
Pages
11
2
7
217
19
2
3
2
1
1.
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Doc.
#
31
32
33
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35
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48
Document Title
Project Manager Change-Corr.
Removal Action Completion Documentation
Corr. to Fred Nika-RE: Final Pollution Report and
Completion Report
Floating Product Layer Identification
Corr. to Fred Nika-RE: Floating Layer
Legal Description of Property Surrounding Site
Evaluation of Composition of Floating Product
Layer
Floating Layer Classification
Revision #2, RI Report Volumes 1,2, and 3
Corr. to D&M-RE: Ecological Risk Assessment
and RI comments
Final Volume 1 of RI Report
Approval of RI Report
Ecological Risk Assessment (ERA) Final
Internal Memorandum (Re: ARARs)
Human Health Risk Assessment (HHRA) Final
Proposed Plan/Fact Sheet Final
Revised Community Relations Plan
Approval Letter for HHRA and ERA
Issue
Date
7-21-94
3-10-95
3-20-95
9-27-95
12-27-95
1-18-96
7-11-96
1-8-97
10-97
12-1-98
3-8-99
4-19-99
April,
1999
6-29-99
July, 1999
7-30-99
8-2-99
8-2-99
Author
Charlene Falco-IEPA
FredNika-IEPA
Kenneth Theisen-
USEPA
D&M
USEPA
John Varro- US Forest
Service
Chi Fan-USEPA
Fred Nika-IEPA
D&M
Fred Nika-IEPA
D&M
Fred Nika-IEPA
D&M
Rob Watson -IEPA
D&M
Fred Nika-IEPA
Stan Black-IEPA
Fred Nika-IEPA
#
Pages
1
4
5
15 .
2
6
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1
131
3
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