PB99-964104
EPA541-R99-077
1999
EPA Superfund
Record of Decision;
Jennison Wright Corporation Inc. Site
Granite City, IL
9/29/1999
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Jennison Wright Superfund Site, IL
DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Jennison Wright Superfund Site
Granite City, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action for the Jennison Wright
Superfund 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 Jennison Wright
Superfund Site.
The United States Environmental Protection Agency (USEPA), Region V supports the selected
remedy on the Jennison Wright Superfund site.
ASSESSMENT OF THE SITE
The response action selected in the Record of Decision is necessary to protect the public health or
welfare or the environment from actual or threatened releases of hazardous substances into the
environment.
DESCRIPTION OF SELECTED REMEDY
The selected remedy is comprised of treatment options in five operable units. This remedy
comprises the overall remedy for the entire site.
For site wastes consisting of the drip track residue and the oils found on-site, the
selected alternative is to remove the waste and have it disposed at a hazardous
waste facility.
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For site soils, a landfarm will he constructed in the norfheast portion of Ac site .
"nd
*>«** «tora«ivc over
it is a more proven technology.
,^^^ groundwater plumes, the preferred alternative fc
enhanced in situ biological treatment using Oxygen Release Compounds (ORC)
and au- sparging rather than natural attenuation and ex situ biological treatment
Natural attenuation is the selected alternative for the other areas of the site where
toe groundwater contamination is at a much lower level.
The buildings and other structures on the site will be razed and the asbestos-
containing materials inside will be abated.
The selected alternative for the "Miscellaneous Items" category is to remove fli-
remammg miscellaneous items (debris piles, storage tanks, abandoned steel trains
and several sumps and pits) that litter the site.
STATUTORY DRTFRMTNATinvg
It is the considered opinion of the Illinois Environmental Protection Agency (Illinois EP V in
consultation with TJSEPA Region V that the selected remedy is protective of hum£ heaJfc £d
the environment attains Federal and State requirements thrt aic^c^ «^Zm?2?
appropriate for this remedial action (or invokes an appropriate waiver), is cost-effective, and
utilizes permanent solutions and alternative treatment technologies (or resource recovery) to th-
moxunum extent practicable and satisfies the statutory preference for remedies ^employ
wm Sr^l * TS ^i?*' ^^ °r V°lume " a P^*1 dement- Bccaiiie 4 remedy
will result m hazardous substances remaining on-site above levels that will allow for unlimited
use and unrestricted exposure, a statutory review will he conducted within five years after
action to ensure ** ** remedy is- or ^ be protccti VB
William E. Muno, Director
Supcrfund Division
USEPA- Region V
Thomas V. Skinner, Director
Illinois EPA
Date
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DECISION SUMMARY
FOR
THE RECORD OF DECISION
JENNISON WRIGHT SUPERFUND SITE
SITE NAME, LOCATION, AND DESCRIPTION
The Jennison-Wright Corporation site is an abandoned railroad tie-treating facility and is comprised
of approximately 20 acres of land at 900 West 22nd Street within the corporate boundaries of Granite
City, Madison County, Illinois. The facility is situated in a mixed industrial/residential
neighborhood and is bordered by the Norfolk-Southern Railroad lines to the east and south,
residential areas to the west and property occupied by the Illinois American Water Company, a
residential area and 23rd Street to the north.
The site is being managed by the Illinois EPA as the lead agency with the USEPA serving as the
support agency. Remedial actions are being pursued using federal Superfund trust fund monies as
the primary source of funding.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Operations at the facility began prior to 1921 and continued until 1989 with three separate companies
operating at the site: Midland Creosoteing Company (prior to 1921-1940), The Jennison-Wright
Corporation (1940-1981) and 2-B-J.W., Inc (1981-1989), authorized to do business as Jennison-
Wright Corporation. Jennison-Wright Corporation filed for Chapter 11 Bankruptcy in November
1989, with an auction held in 1990 to sell the remaining equipment and materials. The site has
remained vacant since 1990 except for the occasional trespasser or scavenger and periodic visits by
Illinois EPA personnel.
The Jennison-Wright Corporation site is a triangular-shaped facility that is bisected by 22nd Street,
creating a north and south portion. The area north of 22nd Street treated wood products (railroad
ties and wood block flooring) with pentachlorophenol (PCP), creosote and zinc naphthenate.
Creosote was used for treating wood products prior to 1921 to 1989. Pentachlorophenol was used
from 1974 to 1985 and zinc naphthenate was used from 1985 to 1989.
Jennite (an asphalt sealer product composed of coal tar, pitch, clay, and water) was manufactured
in the southeastern corner of the facility. The process began in the early 1960s and continued until
the summer of 1986 when Jennison-Wright sold the Jennite process to Neyra Industries. Neyra
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Industries leased the portion of the facility used by Jennison-Wright for the sealer, and continued
manufacturing the asphalt sealer until the bankruptcy in 1989.
In the summer of 1992, the Illinois EPA used trust fund monies from the bankruptcy sale to initiate
a stabilization effort on this site to alleviate the spread of contamination. The east boundary of the
south portion of the site contains the "Jennite pit" (an on-site disposal pit where creosote wastes were
dumped) which had become semi-liquid and begun to migrate off-site.
To temporarily alleviate this problem, the overflowing material was removed and placed in three cut-
off tanks. A makeshift clay cap was constructed using materials on site to shore up the boundaries
of the Jennite pit. Approximately 175 drums of various known and unknown materials were found
on-site including 15 drums of creosote contaminated asbestos insulation. These drums were stored
on-site in an existing structure.
In November, 1994, Reidel Environmental Services was mobilized for a planned removal action.
Per the EE/CA, the completed actions are as follows:
Installation of a six-foot chain link fence around the area of stockpiled soil and drainage area
at the northeast corner of the site;
Excavation and disposal of soils around the upright storage tanks, railroad cars;
Removal of aqueous waste from the various storage vessels, treatment by oil/water
separation, and off-site disposal at a water treatment plant;
Removal and disposal of creosote waste material from the storage vessels;
Decontamination/dismantling of the storage vessels;
Characterization of the material within the drums inside the Transite building and proper
disposal;
Installation of a protective geomembrane and clay cap over the "Jennite pit".
Removal of the contaminated soil in the three cutoff tanks in the south portion of the site and
dismantling of the tanks.
Subsequent to the removal action, the site was finalized on the National Priorities List on June 16
1996.
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Illinois EPA has been responsible for conducting a community relations program for the site.
Concern about the site has remained somewhat low, with public concern over the presence of weeds
and debris on site rather than the presence of chemical contaminantsLow public concern is also due
to the site's 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 1994 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.
The community relations program at the Jennison- Wright Superfund 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 and other interested citizens about the Superfund process, project
plans, progress, and problems;
Ensuring that all local, state, and federal officials who have interest in the site are kept
informed of the project plans, progress, and problems;
Identifying additional issues, changing concerns, and misconceptions of the affected
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 an possible local employment effects of the project;
Providing timely and accurate responses to inquiries regarding the project;
Setting up the local repository and administrative record for project documents and reports;
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.
The Illinois EPA has issued four separate fact sheets to the public addressing the site regarding site
contaminants and impending removal/remedial actions. The Engineering Evaluation/Cost Analysis
(EE/CA) and Proposed Plan were released to the public in July 1999. These two documents were
made available to the public in both the administrative record and an information repository
maintained at the Granite City Public Library and at the Illinois EPA headquarters in Springfield,
Illinois. The notice of availability for these and other documents was published in the Granite City
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Press Journal on July 18, 1999. A public comment period was held from July 30, 1999 through
August 29, 1999 to encourage public participation in the remedy selection process. In addition, a
public hearing was held on August 19,1999. At this meeting, representatives from the Illinois EPA
answered questions about problems at the site and the remedial alternatives under consideration. A
response to the comments received during this comment period is included in the Responsiveness
Summary, which is part of this Record of Decision. This decision document presents the selected
remedial action for the Jennison Wright Superfund Site, in Granite City, Illinois, chosen in
accordance with CERCLA, as amended by SARA and, to the extent practicable, the National
Contingency Plan. The decision for this site is based on the administrative record.
SCOPE AND ROLE OF RESPONSE ACTION __
This ROD addresses the overall site remedy for all operable units at the Jennison Wright Superfund
Site. As with many Superfund sites, the problems at the Jennison Wright Superfund Site are
complex and interrelated. As a result, Illinois EPA has divided the work into different manageable
Operable Units (OUs). These are:
OU 1 Soils and Wastes: addresses the soils that have been contaminated by past site operations
and the wastes that those operations left in place when the site went bankrupt.
OU 2 Non-Aqueous Phase Liquids (NAPLs): addresses the presence of NAPLs, which have
been found in the northeast corner of the south section of the site. «
OU 3 Groundwater: addresses the contaminated groundwater which is located throughout the
site. The most significant areas of contamination are regions of the NE comer of the north
portion of the site (Area H), the NE corner of the south portion of the site, the Jennite Pit
area, south of the old silos, and the immediate vicinity of the former Pentachlorophenol
(PCP) treatment process building.
OU 4 Buildings: addresses the variety of different structures and their remnants which remain on-
site. There are five buildings and two silos on-site.
OU 5 Miscellaneous Items: addresses the remaining miscellaneous items that consist of two
underground storage tanks, two above ground storage tanks, an oil water separator, liquids
and sediments in an on-site basin, the collapsed pole barn, several sumps and pits, scattered
debris piles, and steel tram rails.
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SITE CHARACTERISTICS
Site Location
The Jennison-Wright Corporation site is made up of approximately 20 acres of land at 900 West
22nd Street within the corporate boundaries of Granite City, Madison County, Illinois. The facility
is bordered by the Norfolk-Southern Railroad lines to the east and south, residential areas to the west
and property occupied by the Illinois American Water Company, a residential area, and 23rd Street
to the north. The site is fenced but evidence of trespassing (i.e., trash and graffiti) has been observed
in buildings at the facility.
The site topography is relatively flat, with surface runoff toward the northeast from areas north of
22nd Street. Runoff appears to be contained at the site in areas south of 22nd Street. Bare soil areas
exist at the site, but more than half of the site is covered by buildings, grass, brush, or gravel. Five
buildings, two silos, and several concrete sumps, pits, and debris piles are present on the site. In
addition, there are two small underground storage tanks and one unlined sludge pit (Jennite Pit).
Although a number of private and/or industrial wells have been identified in the area, domestic water
for the Granite City area is obtained from the Mississippi River.
Past site practices have resulted in leakage/spillage of chemicals to surface soils, or, in the case of
the Jennite pit, direct deposition of wastes into the soil. Once released to the soil, contaminations
migrated to subsurface soils and groundwater. Contamination detected at the site includes Volatile
Organic Compounds (VOCs), Semi-Volatile Organic Compunds (SVOCs), pesticides, and
dioxins/furans. In pursuit of information regarding this contamination, Illinois EPA collected 81
gridded surface soil samples, 15 biased surface soil samples, 72 subsurface soil samples, 4 sediment
samples, and a total of 58 groundwater samples in the shallow (20 feet BGS), intermediate (45 feet
BGS), and deep (-100 feet BGS) ranges. Contamination from site operations was found in both
surface and subsurface samples with varying degrees of concentration. Contamination was also
found in the groundwater in all three depth ranges with a significant NAPL source in the northeast
corner of the south portion of the site.
Shallow groundwater flow at the site is predominantly to the south with a western component of
groundwater flow in the southern half of the site. The intermediate and deep groundwater flow show
primarily a southerly component. Hydraulic gradients at the site are small and range from 0.0023
to 0.00064 ft/ft in the shallow portion of the aquifer and range from 0.00072 and 0.00081 ft/ft.
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Site Map
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USE
In order to adequately assess the risks to human health and the environment, current and potential
future land uses need to be anticipated.
Currently, there is no on-site use of the property. The facility is situated in a mixed
industrial/residential neighborhood and is bordered by the Norfolk-Southern Railroad lines to the
east and south, residential areas to the west and property occupied by the Illinois American Water
Company, a residential area and 23rd Street to the north.
The anticipated future use of the property is assumed to be commercial/industrial. Factors
contributing to this assumption include:
Records indicating the use of the property has been commercial/industrial for many years,
Proximity of the adjacent railroad spur makes the property much more attractive to
industrial use rather than residential, and
Granite City has expressed an interest in redeveloping the site as an industrial complex
once the remedial efforts have been completed.
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It is anticipated that deed restrictions will be implemented to prohibit residential use of the site.
The site topography is such that surface water is non-existent except for the occasional ponding
of water. Groundwater, though abundant, is not considered to be practical as a drinking water
source due to the prevalence and proximity of the local municipal water supply system.
SUMMARY OF SITE RISKS
The response action selected in this Record of Decision is necessary to protect the public health
or welfare or the environment from actual or threatened releases of hazardous substances into the
environment. Some remedial action is therefore warranted.
During the EE/C A, a risk assessment was performed to estimate the health or environmental
problems that could result if the proposed actions were not conducted to clean up the site. The
analysis performed is commonly called a streamlined risk assessment or, more simply, the risk
assessment. The specific purpose of the risk assessment is to evaluate potential risks to humans
and the environment as a result of exposure to contaminants present in soil and groundwater at
the Jennison-Wright site.
Several organic compounds were identified as Contaminants of Potential Concern (COPCs) in
groundwater, but not in soil either because they were not detected in soil at the site, or because
the results of toxicity screening indicated that the chemical concentrations detected in soil would
not contribute significantly to the overall estimated risk at the site. Arsenic was retained as a
COPC in groundwater, but not in soil, based on the comparison to background levels (which
indicate that the arsenic concentrations in soil at the site are similar to background levels) and on
site historical information which does not indicate that arsenic was ever used at the site. Due to
the lack of background data for lead, and because lead levels in two of the surface soil samples
exceeded the screening level, lead was retained as a COPC in surface soil. A summary of the
chemicals selected as COPCs for soil and groundwater are presented in the table below.
CHEMICALS OF POTENTIAL CONCERN IN SOIL AND GROUNDWATER
STREAMLINED HUMAN HEALTH RISK EVALUATION
JENNISON-WRIGHT SITE
GRANITE CITY, ILLINOIS
Chemical
Acenaphthene
Arsenic
Medium
Surface
Soil
X
Subsurface
Soil
X
Groundwater
X
X
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CHEMICALS OF POTENTIAL CONCERN IN SOIL AND GROUNDWATER
STREAMLINED HUMAN HEALTH RISK EVALUATION
JENNISON-WRIGHT SITE
GRANITE CITY, ILLINOIS
Chemical
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Beryllium
Carbazole
Chloroform
Chromium
Chrysene
Di(2-ethylhexyl)phthalate
Dibenzo(a,h)anthracene
1 ,2-Dichloroethane
2,4-DimethyIphenol
Ethylbenzene
alpha-Hexachlorocyclohexane
Indeno( 1 ,2,3-cd)pyrene
Lead
Manganese
Methylene chloride
2-Methylphenol
Naphthalene
Pentachlorophenol
Phenol
2,3,7,8 TCDD Equivalents'1
Medium
Surface
Soil
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Soil
X
X
X
X
X
X
X
X
X
X
X
Groundwater
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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CHEMICALS OF POTENTIAL CONCERN IN SOIL AND GROUNDWATER
STREAMLINED HUMAN HEALTH RISK EVALUATION
JENNISON- WRIGHT SITE
GRANITE CITY, ILLINOIS
Chemical
Thallium
Toluene
Trichloroethene
Medium
Surface
Soil
Subsurface
Soil
Groundwater
X
X
X
HUMAN HEALTH RISKS
Section 1: Identification of Chemicals of Concern
The Human Health Risk Evaluation estimates what risks the site poses if no action were taken. It
provides the basis for taking action and identifies the contaminants and exposure pathways that
need to be addressed by the remedial action. This section of the ROD summarizes the results of
the Streamlined Risk Assessment for this site.
The general conclusion of the human health risk assessment conducted for the Jennison- Wright
site is that the site poses unacceptable risks to human health in both current and hypothetical
future use scenarios. Some remedial action is therefore warranted.
There are a number of major factors causing the unacceptable risks for humans including:
The presence of dioxins/dibenzofurans and carcinogenic polynuclear aromatic
hydrocarbons (PAHs) in site surface soils;
The presence of several PAHs and PCP in the groundwater at several locations
around the site; and
The presence of benzene and naphthalene in subsurface soils.
Contaminant levels in different media varied widely both between media and within the media
for a number of the COPC's. Table 3-3 from the EE/CA, as reproduced below illustrates the
exposure point concentrations of each COPC.
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Table 3-3
EXPOSURE POINT CONCENTRATIONS FOR CHEMICALS OF POTENTIAL CONCERN
JENNISON-WRIGHT SITE,
Exposure Point
Concentration Set
Surface Soil
Location
Onsitc
Soil
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Data Quality
Data analyses were performed using methods and QA/QC procedures set forth in Methods for
the Chemical Analysis of Water and Wastes (EPA 1983) and Test Methods for Evaluating Solid
Waste, Physical/Chemical Methods, SW-846, Third Edition, Update 2B (EPA 1995a). The 16
surface soil grid samples analyzed by Contract Laboratory Program (CLP) were evaluated using
methods and QA/QC procedures specified by CLP. Data validation was performed in
accordance with EPA's functional guidelines for evaluating organic and inorganic analyses. Only
data approved for use by these procedures were used in the risk assessment.
Exposure Point Calculations (EPCsl
The EPCs for surface soil were based on the lower of the 95% upper confidence limit on the
mean Upper Confidence Limit (UCL) and the maximum detected value from samples collected
for CLP analysis. For the future site worker andconstruction worker scenarios, UCLs were
calculated for the combined surface and subsurface soil data, based on the assumption that these
receptors would be exposed to a mixture of these soils as a result of site redevelopment. Upon
review of the groundwater data, four discrete areas of groundwater contamination were identified
based on the processes that occurred in certain areas of the site. Consequently, the groundwater
data was segratated based on the proximity of the wells to the four functional areas (22nd Street
Lagoon, Area H, Jennite Pit, and the PCP process area), and then each area was evaluated
separately. The lower of the UCL or the maximum detected value for each area was selected as
the EPC for the particular chemical for each area. For air pathways, airborne concentrations of
chemicals were estimated from surface and subsurface soil samples using standard mass flux
calculations. EPCs calculated for the Jennison-Wright site are shown on Table 3-3 of the
EE/CA.
Section 2: Exposure Assessment
Exposure scenarios were evaluated for a number of possible exposures and reflect the excess
lifetime cancer risk if no cleanup activities are conducted. An industrial/commercial use of the
property was assumed for purposes of projecting future risk due to the history of the site as an
industrial complex. Figure 3-1 in the EE/CA displays a flow chart of the Conceptual Site Model
used for the site and is reproduced below.
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wncncoiaax
JENNISON-WRIGHT SRE CONCEPTUAL MODEL
Seven different exposure scenarios were considered in the Conceptual Site Model. A table
representation of those scenarios and the calculated risks is presented below.
Conceptual Site Model
Scenario
Scenario 1- Current Site Visitor (soil and air exposure)
Scenario 2- Current Nearby Residents (air exposure)
Scenario 3- Future Permanent Site Worker (soil and air exposure)
Risk Level
3.7X10'4
5.9X10-5
3.8X1 0'3
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Conceptual Site Model
Scenario 4- Future Permanent Site Worker (groundwater ingestion)
Scenario 5- Future Site Construction Worker (soil and air exposure)
Scenario 6- Future Nearby Residents (chronic air exposure)
Scenario 7- Future Nearby Residents (during construction)
3.9X1 0'2
2.1X10'4
i.oxio-4
6.2X10'5
SectionS: Toxicity Assessment
The purpose of the toxicity assessment is to review toxicity and carcinogenicity data for the
COPCs, and to provide an estimate of the relationship between the extent of exposure to these
contaminants and the likelihood and/or severity of adverse effects. The toxicity assessment is
accomplished in two steps: hazard identification and dose-response assessment.
The hazard identification is a qualitative description of the potential toxic effects of the COPC.
The health effects summaries presented in Appendix I describe the toxic effects that have been
observed in humans and/or animals following exposure to the COPCs identified at the Jennison
Wright site.
Categorization of Chemicals as Carcinogens or Noncarcinogens
For the purpose of this risk evaluation, COPCs were classified into two groups: potential
carcinogens and noncarcinogens. The risks posed by these two types of compounds are assessed
differently because noncarcinogens generally exhibit a threshold dose, below which no adverse
effects occur, while no such threshold has been proven to exist for most carcinogens.
As used here, the term "carcinogen" means any chemical for which there is sufficient evidence
that exposure may result in continuing uncontrolled cell division (cancer) in humans and/or
animals. Conversely, the term "noncarcinogen" means any chemical for which the carcinogenic
evidence is negative or insufficient. These classifications are dynamic; chemicals may be
reclassified any time additional evidence becomes available that shifts the weight-of-evidence
one way or the other.
The following tables are reproduced directly from the EE/CA Streamlined Risk Assessment and
represent the carcinogenic and non-carcinogenic risk information which is relevant to the
contaminants of concern in both soil and groundwater. Because dermal route references doses
(RfDs) and slope factors (SFs) are usually not available, oral route RfDs and SFs are commonly
used to evaluate exposures to substances by both the oral and dermal routes. In accordance with
Risk Assessment Guidelines (RAGS), when the RfD or SF is based on an administered dose, and
the gastrointestinal absorption of the COPC is significantly less than 100%, the RfD or SF is
adjusted to assess dermal risks using a gastrointestinal absorption factor (GIAF), which
represents the oral absorption efficiency of the chemical.
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Table 3-18
TOXICITY INDICES FOR CARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Cancer Exposure
Chemical Class Route
Arsenic A Inhalation
Oral
Benzene A Inhalation
Oral
Benzo[a]anthracene B2 Inhalation
Oral
Benzo[a|pyrene B2 Inhalation
Oral
Benzo[b]fluoranthene B2 Inhalation
Oral
Bcnzo[k]fluoranthene B2 Inhalation
Oral
Beryllium B2 Inhalation
Oral
Slope
Factor
(mg/kg-day)'1 Target Organ Tumor Type
I.SE+01 Lung Lung Cancer
1.5E+00 Skin Skin Cancer
2.9E-02 Blood Leukemia
2.9E-02 Blood Leukemia
3.1E-01
7.3E-01
3.1E+00 Respiratory tract
7.3E+00 Forestomach
3.1E-OI
7.3E-01
3.IE-02
7.3E-02
8.4E+00 Lung i
NA : '
. : f .14^4 '
Basis
Exposure
Basis Species Route
Human, male Inhalation,
occupational
exposure
Human, male Drinking water
Human Inhalation,
occupational
exposure
Human Inhalation,
occupational
exposure
Hamster Inhalation
CFW and SWR/J Oral, diet
Swill Mice
Human Inhalation,
occupational
exposure
Reference
Source
IRIS
IRIS
IRIS
IRIS
Other EPA
Docs.
NCEA
IRIS
IRIS
Other EPA
Docs.
NCEA
Other EPA
Docs.
NCEA
IRIS
Withdrawn
9
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Table 3-18
TOXICITY INDICES FOR CARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Cancer Exposure
Chemical Class Route
Carbazole B2 Inhalation
Oral
Chloroform B2 Inhalation
Oral
Chromium (VI) A Inhalation
Oral
Chrysene B2 Inhalation
Oral
Di(2-ethylhexyl)phthalate B2 Inhalation
Oral
Dibcnz[a,h]anthracene B2 Inhalation
Oral
Dichlorocthane, 1,2- B2 Inhalation
Oral
Slope
Factor
(mg/kg-day)-l
2.0E-02
2.0E-02
8.0E-02
6.1E-03
4.2E+01
NA
3.IE-03
7.3E-03
1.4E-02
1.4E-02
3.IE+00
7.3E+00
9.1E-02
9.1E-02
Target Organ Tumor Type
Liver Tumors
Liver Tumors
Liver Hepatocellular
carcinoma
Kidney All kidney tumors
Lung Lung cancer
-
Liver Hepatocellular
carcinoma and
adenoma
Circulatory
system
Circulatory Hemangiosarcomas
system
Basis Species
Mouse
Mouse
Mouse, B6C3F1,
female
Rat/Osbome-
Mendel, male
Human
:
Mouse/B6C3FI,
male
Rat/Osborne-
Mendel, male
Rat/Osbornc-
Mendel, male
Basis
Exposure
Route
Diet
Diet
Gavage
Drinking water
Inhalation,
occupational
exposure
Diet
_
Gavage
Gavage
Reference
Source
Oral SF
HEAST
IRIS
IRIS
IRIS
Other EPA
Docs.
NCEA
Oral SF
IRIS
Other EPA
Docs.
NCEA
IRIS
IRIS
15
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Table 3-18
TOXICITY INDICES FOR CARCINOGENIC EFFECTS OF COPCs
JENNISON- WRIGHT SITE, GRANITE CITY, ILLINOIS
Chemical
Hexachlorocyclohexane, alpha-
Indeno[l,2,3-cd]pyrene
Methylene chloride
Methylphenol, 2-
Penlachlorophenol
Slope
Cancer Exposure Factor
Class Route (mg/kg-day)'1
B2 Inhalation 6.3E+00
Oral 6.3E+00
B2 Inhalation 3.1E-01
Oral 7.3E-01
B2 Inhalation I.6E-03
Oral 7.5E-03
C Inhalation NA
Oral NA
B2 Inhalation 1.2E-OI
Target Organ Tumor Type Basis Species
Liver Hepatic nodules and Mouse/dd, male
hepatoccllular
carcinomas
Liver Hepatic nodules and Mouse/dd, male
hepatocellular
carcinomas
Liver, lung Combined adenomas Mouse/B6C3FI,
and carcinomas female
Liver Hepatocellular Mouse/B6C3FI
adenomas or (female, NTP;
carcinomas (NTP) and male, NCA)
hepatocellular cancer
and neoplastic nodules
(NCA)
Liver, Hepatocellular Mouse/B6C3FI,
cardiovascular adenoma/carcinoma, female
system pheochromocytoma/
malignant
pheochromocytoma,
hemangiosarcoma/
hemangioma
Basis
Exposure Reference
Route Source
Diet IRIS
Diet IRIS
Other EPA
Docs.
NCEA
Inhalation IRIS
Inhalation IRIS
(NTP);
drinking water
(NCA)
_ _
Diet Oral SF
16
-------
Table 3-18
TOXICITY INDICES FOR CARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Chemical
Pentachlorophenol
TCDD 2,3,7,8
Trichloroethene
Key:
HE AST
IRIS
NA
NCA
NCEA
NTP
OHEA
Other EPA Docs.
Cancer Exposure
Class Route
B2
B2
B2
Oral
Inhalation
Oral
Inhalation
Oral
Slope
Factor
(mg/kg-day)"1
I.2E-OI
1.5E+05
1.5E+05
6.0E-03
1.1E-02
Target Organ
Liver,
cardiovascular
system
Respiratory
system, liver
Respiratory
system, liver
Liver
Liver
= EPA's Health Effects Assessment Summary Tables.
= EPA's Integrated Risk Information System.
= Not available.
= National Coffee Association.
= EPA's National Center for Environmental Assessment.
= National Toxicology Program.
= EPA's Office of Health and Environmental Assessment.
= EPA criteria documents such as drinking water criteria documents, drinking v
Basis
Exposure Reference
Tumor Type Basis Species Route Source
Hepatocellular Mouse/B6C3Fl, Diet IRIS
adenoma/carcinoma, female
pheochromocytoma/
malignant
pheochromocytoma,
hemangiosarcoma/
hemangioma
Rat Diet HEAST
Rat Diet HEAST
Mouse Inhalation NCEA
Mouse Gavage NCEA
rater Health Advisory summaries, ambient water quality criteria documents, and air
SF
quality criteria documents.
Slope Factor.
17
-------
Table 3-19
TOXICITY INDICES FOR NONCARCINOGENIC EFFECTS OFCOPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Exposure
Chemical Route RID Type
Acenaphthene Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Arsenic Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Benzene Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Benzo[a]anthraccne Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Reference Conn-
Dose Uncert Mod dence Target
(rag/kg-day) Factor Factor Level Organ
6.0E-02 Liver
6.0E-01 Liver
6.0E-02 3000 1 Low Liver
6.0E-01 300 Liver
NA
NA '
3.0E-04 3 1 Medium Skin
3.0E-04 3 Skin
1.7E-03 1000
1.7E-02 100 Medium
3.0E-03
' 3.0E-03
NA
NA
NA _____
NA
18
0
Reference
Critical Effect Study Description Source Date
Hepatotoxicity Chr. Oral
RID
Hepatotoxicity Subchr.
Oral RID
Hepatotoxicity Mouse, oral subchronic IRIS 4/1/94
study
Hepatotoxicity HEAST 5/31/95
Hyperpigmentation, Human chronic oral IRIS 3/1/93
keratosis and possible exposure
vascular complications
Keratosis HEAST 5/31/95
Hematopoietic effects Mouse, subchronic NCEA
inhalation study
Hematopoietic effects Mouse, subchronic NCEA
inhalation study
NCEA
NCEA
-------
Chemical
Benzo[a]pyrcne
Benzo[a|pyrenc
Benzo[b]fluoramhene
Benzo[k]fluoranthene
Beryllium
Carba/ole
Exposure
Roule RfD Type
Inhalation Chronic
Inhalation Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Table 3-19
TOXICITY INDICES FOR NONCARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Reference Confi-
Dose Uncert Mod dence Target Reference
(mg/kg-day) Factor Factor Level Organ Critical Effect Study Description Source Date
NA _ _ _ _ _
NA - _ _ _ _
NA __ _ _ _ _
NA _ _ _
NA . _ _ _ _
NA _ _ _
NA _ _ __
NA _ _ _ _
NA _ _ _ _-_
NA _ _ _ _ _
NA _ _ _ _ _
NA ___ _ _ _
NA _ _ _ ___
NA _ _ _ _ _
2.0E-03 100 1 Low No adverse effects Rat, chronic oral IRIS 2/1/93
bioassay
2.0E-03 100 _ None observed HEAST 7/1/97
NA _ _ _ _ _
NA - _ _ _ _ _
NA _ _ _ _ _ _
NA _ _ _ _ _
19
-------
Table 3-19
TOXICITY INDICES FOR NONCARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHTSITE, GRANITE CITY, ILLINOIS
Chemical
Chloroform
Chromium(lll), soluble salts
Chromium(VI)
Chrysene
Di(2-ethylhexyl)phthalate
Exposure
Route RID Type
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Reference Confi-
Dose Uncert Mod dence
(mg/kg-day) Factor Factor Level
1.1E-02 300 Medium
I.1E-02
l.OE-02 1000 1 Medium
l.OE-02 1000
NA
NA
1.5E+00
1.5E+00 1000
2.9E-05 100 Low
2.9E-05 100 Low
3.0E-03 500 1 Low
2.0E-02 100
NA
NA
NA
NA
2.9E-03 100 ..;., Low
Target
Organ Critical Effect
Liver Necrosis
Liver Necrosis
Liver Fatty cyst formation in
liver
Liver Lesions
None observed
None observed
Respiratory Diffuse nasal symptoms
tract
No effects reported
None observed
Lung Increased lung weight.
Study Description
Rat, subchronic
inhalation study
Dog, chronic oral
bioassay
Dog oral capsule 7.5
years
Rat diet
Human occupational
study
Rat, 1 -year drinking
water study
Rat drinking water
Rat, inhalation study
Reference
Source
NCEA
Chr. Inhl
RfD
IRIS
HEAST
'
IRIS
IRIS
IRIS
IRIS
IRIS
HEAST
NCEA
Date
8/25/93
9/1/92
5/31/95
9/1/98
9/1/98
3/1/99
3/1/99
3/1/99
5/31/95
3/18/96
histological alterations
20
-------
Table 3-19
Exposure
Chemical Route RID Type
Di(2-ethylhexyl)phthalate Inhalation Subchronic
Oral Chronic
Subchronic
Dibenz[a,h]anthracene Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Dichloroethane, 1,2- Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Dimethylphenol, 2,4- Inhalation Chronic
Subchronic
TOXICITY INDICES FOR NONCARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Reference Confi-
Dose Uncert Mod dence Target
(mg/ltg-day) Factor Factor Level Organ Critical Effect
2.9E-03
2.0E-02 1000 1 Medium
2.0E-02
NA
NA
NA
NA .
2.9E-03
2.9E-03
NA
NA
2.0E-01
Lung Increased lung weight,
histological alterations
Liver Increased relative liver
weight
Liver Increased relative liver
weight
"
-
Whole body Clinical signs (lethargy,
prostration, and ataxia)
and hematologica!
changes
Nervous Effects
System
Reference
Study Description Source Date
Chr. Inhl
RfD
Guinea pig, subchronic IRIS 5/1/91
to chronic oral bioassay
Chr. Oral
RfD
Other EPA
Docs.
Chr. Inhl
RfD
Chr. Oral
RID
Subchr.
Oral RfD
Oral
Chronic 2.0E-02
3000
Low Whole body
Clinical signs (lethargy,
prostration, and ataxia)
and hematological
changes
Mouse, subchronic oral
gavage
IRIS
11/1/90
21
-------
TOXICITY INDICES
Table 3-19
FOR NONCARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHTSITE, GRANITE CITY, ILLINOIS
Chemical
Dimethylphcnol. 2,4-
-_
Ethylbcnzcne
Hexachlorocyclohexane,
alpha-
Indeno[ 1 ,2,3-cdJpyrene
Manganese (diet)
Exposure
Route RfD Type
Oral Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Inhalation Chronic
Subchronic
Reference
Dose Uncert
(mg/kg-day) Factor
2.0E-01 300
2.9E-OI 300
2.9E-OI
l.OE-OI 1000
l.OE-01
NA
NA
NA
NA
NA
NA
NA -
NA
1.4E-05 1000
1.4E-05
Confi-
Mod dence Target
Factor Level Organ
Nervous
System
1 Low Whole body
Whole body
1 Low Liver
Liver
_
1 Medium Nervous
system
Nervous
system
Critical Effect
Effects
Developmental toxicity
Developmental toxicity
Liver and kidney
toxicity
Liver and kidney
toxicity
Impairment of
neurobehavioral
function
Impairment of
neurobehavioral
function
Reference
Study Description Source Date
HEAST 3/31/93
Rat and rabbit, IRIS 3/1/91
developmental
inhalation studies
Chr. Inhl
RID
Rat, Subchronic to IRIS 6/1/91
chronic oral bioassay
Chr. Oral
RfD
'
_
Occupational exposure IRIS 12/1/93
to manganese dioxide
Chr. Inhl
RID
22 [
-------
Table 3-19
TOXICITY INDICES FOR NONCARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Chemical
Manganese (diet)
Manganese (water)
.
Methylcne chloride
Mcthylphenol, 2-
Reference
Exposure Dose Uncert
Route RfDType (mg/kg-day) Factor
Oral Chronic 1.4E-01 1
Subchronic 1.4E-01 I
Inhalation Chronic 1.4E-05 1000
Subchronic I.4E-05
Oral Chronic 4.7E-02 I
Subchronic 4.7E-02 1
Inhalation Chronic 8.6E-0! 100
Subchronic 8.6E-0!
Oral Chronic 6.0E-02 100
Subchronic 6.0E-02
Inhalation Chronic 5.0E-02
Confi-
Mod dence Target
Faetor Level Organ
1 Varied Central
nervous
system
Central
nervous
system
1 Medium Nervous
system
Nervous
system
1 Varied Central
nervous
system
Central
nervous
system
Liver
Liver
1 Medium Liver
Liver
Whole body
Critical Effect
CNS effects
CNS effects
Impairment of
neurobehavioral
function
Impairment of
neurobehavioral
function
CNS effects
CNS effects
Liver toxicity
Liver toxicity
Liver toxicity
Liver toxicity
Decreased body
weights and
neurotoxicity
Study Description
Human chronic
ingestion data
'
Occupational exposure
to manganese dioxide
_
Human chronic
ingestion data
. _
Rat, 2-year inhalation
study
Rat, 2-year drinking
water bioassay
. ,
_
Reference
Source Date
IRIS 6/I/9S
HEAST 5/31/95
IRIS 12/1/93
Chr. Inhl
RfD
IRIS 3/1/99
IRIS 3/1/99
HEAST 5/31/95
Chr. Inhl
RfD
IRIS 3/1/88
Chr. Oral
RfD
Chr. Oral
RfD
23
-------
Table 3-19
TOXICITY INDICES FOR NONCARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHTSITE, GRANITE CITY, ILLINOIS
Exposure
Chemical Route RID Type
Melhylphenol, 2- Inhalation Subchronic
Oral Chronic
Subchronic
Naphthalene Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Pentachlorophenol Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Phenol Inhalation Chronic
Subchronic
Reference
Dose Unccrt
(mg/kg-day) Factor
S.OE-Oi
5.0E-02 1000
5.0E-01 100
8.6E-04
8.6E-04
2.0E-02 1000
2.0E-02
3.0E-02
3.0E-02
3.0E-02 100
3.0E-02 100
6.0E-OI
6.0E-OI
Conn-
Mod deuce Target
Factor Level Organ
Whole body
1 Medium Whole body
Whole body
Liver,
Kidney
Fetus
1 Medium Liver,
kidney
Fetus
Whole body
Fetus
Critical Effect Study Description
_ _
Deceased body weights Rat, 90-day oral
and ncurotoxicity Subchronic
neurotoxicity study
Rat oral gavage
Rat, subchronic gavage
study
Liver and kidney
pathology
Fetotoxicity
Liver and kidney Rat, oral chronic study
pathology
Fetotoxicity
Reduced fetal body
weight in rats
Decreased weight
Reference
Source
Subchr.
OralRfD
IRIS
HEAST
Chr. Oral
RfD
Chr. Oral
RfD
IRIS
Chr. Oral
RfD
Chr. Oral
RfD
Subchr.
Oral RfD
IRIS
HEAST
Chr. Oral
RfD
Subchr.
Oral RfD
Date
9/1/90
5/31/95
3/1/99
3/1/99
2/1/93
3/31/93
Oral Chronic 6.0E-01 100 1 Low Whole body Reduced fetal body Rat, oral developmental
weight in rats study
IRIS
2/1/90
24
-------
Table 3-19
TOXICITY INDICES FOR NONCARCINOGENIC EFFECTS OF COPCs
JENNISON-WRIGHT SITE, GRANITE CITY, ILLINOIS
Exposure
Chemical Route RfDType
t
Phenol Oral Subchronic
TCDD 2,3,7,8 Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Thallium Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Toluene Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Trichloroethene Inhalation Chronic
Subchronic
Oral Chronic
Subchronic
Reference
Dose Uncert
(mg/kg-day) Factor
6.0E-01 100
NA
NA
NA
NA
NA
NA
8.0E-05 3000
8.0E-04 300
1.1E-01 300
2.9E-01
2.0E-01 1000
2.0E-01 100
6.0E-03
6.0E-03
6.0E-03
6.0E-03 -
Confi-
Mod dence Target
Factor Level Organ
Fetus
_ _ _
.
_ _ _
Low Liver
Liver
1 Medium Brain
Brain
1 Medium Liver,
kidney
Liver
,-
Critical Effect Study Description
Decreased weight
_ _
Increased levels of Rat oral subchronic
SOOT and LDH study
Increased SGOT
Neurological effects Human occupational
study
Neurological effects
Changes in liver and Rat, 3-week gavage
kidney weights study
Altered weight
Reference
Source
HEAST
IRIS
HEAST
IRIS
NCEA
IRIS
HEAST
Chr. Oral
RfD
Chr. Oral
. RfD
Other EPA
Docs.
Chr. Oral
RfD
Date
3/31/93
3/1/99
7/1/97
8/1/92
4/1/94
3/31/93
25
-------
Table 3-19 (Cont.)
Key:
CNS - Central Nervous System.
HEAST = EPA's Health Effects Assessment Summary Tables.
IRIS = EPA's Integrated Risk Information System.
LDH = Lactate Dehydrogenase (enzyme).
NA = Not available.
NCEA = EPA's National Center for Environmental Assessment.
OHEA = EPA's Office of Health and Environmental Assessment.
Other EPA Docs. = EPA criteria documents such as drinking water criteria documents, drinking water Health Advisory summaries, ambient water quality criteria documents, and air quality criteria documents.
RfD = Reference dose.
SCOT = Serum Glutamic-Oxaloacetic Transaminase (enzyme).
Section 4: Risk Characterization
Potential cancer risks are assessed by multiplying the estimated lifetime average daily intake (LADI) of a carcinogen by its SF. This calculated risk is
expressed as the probability of an individual developing cancer over a lifetime and is an estimated upper-bound incremental probability. Cancer risks
initially are estimated separately for exposure to each chemical for each exposure pathway and receptor category (i.e., adult or child). Separate cancer
risk estimates then are summed across chemicals, receptors, and all exposure pathways applicable to the same population to obtain the total excess
lifetime cancer risk for that population. Cancer risk estimates are provided in scientific notation; 1 x 10'6is equivalent to 1E-6, which equals
0.000001.
The potential for adverse effects resulting from exposure to a noncarcinogen is assessed by comparing the estimated chronic daily intake (GDI) or
Subchronic Daily intake (SDI) of a substance to its chronic or subchronic RfD. This comparison is made by calculating the ratio of the estimated GDI
or SDI to the corresponding RfD to yield a hazard quotient (HQ). HQs that are associated with similar critical effects (e.g., liver damage) should be
summed together to obtain a hazard index (HI) for that effect, whereas HQs for different critical effects should be kept separate. However, for
screening purposes, HQs are commonly summed across all chemicals, exposure routes, and pathways applicable to a given population to obtain an HI
for that population.
For evaluating noncarcinogenic effects, EPA defines acceptable exposure levels as those to which the human population, including sensitive
subgroups, may be exposed without adverse effects during a lifetime or part of a lifetime, incorporating an adequate margin of safety (EPA 1989).
This acceptable exposure level is approximated by an HI less than or equal to 1.0.
Non-cancer risks are usually assessed by calculating a hazard quotient, which is the ratio of the estimated exposure to the RfD as follows:
26
-------
HQ =
GDI
RfD
where:
HQ = Hazard quotient;
GDI = Chronic daily intake (exposure); and
RfD = Reference dose (acceptable daily intake).
The following table, reproduced from the EE/CA quantifies the risks for both carcinogenic and non-carcinogenic effects for the different exposure
scenarios considered.
SUMMARY OF RISK ESTIMATES
JENNISON-WRIGHT SITE
GRANITE CITY, ILLINOIS
Scenario
Receptor
Age Group
Location
P«thw«y
Total
HI
/.HI
by
Path-
way
HQ>i by Chemical
(/.of total)
Total
Cancer
Risk
%CR
by
Path-
wiy
CR> 10"6 by Chemical
(%of total)
Current Exposure Scenarios
1
2
Current Site Visitors
Cuirenl Nearby
Residents
Adolescent
Adult/Child
(Integrated)
On site
Off site
Ingeslion of Soil
Dermal Absorption from Soil
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
0024
0.082
0.021
0.0027
0.13
0.355
0.087
0.4
186
629
16.4
2.1
100.0
80.4
19.6
100.0
None
None
3.8E-04
3.9E-04
4.2E-07
8.3E-09
7.7E-04
2.6E-05
I.OE-06
2.7E-05
49.10
50.85
0.05
0.001 1
100.0
96.3
3.7
100.0
TCDD-TEQ(82%)
Benzo(a)pyrene (10%)
Benzo(a)anthracene (2%)
Dibeir/(a,h)anlhraccne (2%)
Benzo(b)fluoranthene ( 1 %) ,.
Carbazole(
-------
SUMMARY OF RISK ESTIMATES
JENNISON-WRIGHT SITE
GRANITE CITY, ILLINOIS
Scenario
Receptor
Age Group
Child
Location
OfTsilc
Pathway
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
Total
HI
1.5
0.17
1.7
% HI
by
Path-
way
90.1
9.9
100.0
HQ>I by Chemical
(%of total)
Naphthalene (90%)
Total
Cancer
Risk
23E-05
3.9E-07
2.3E-05
V.CR
by
Path-
way
98.3
1.7
100.0
CR> Id"* by Chemical
(% of total)
TCDD-TEQ(76%)
Pcntachlorophenol (6%)
Carbazole(7.5%)
Future Exposure Scenarios
3
Future Permanent
Site Worker
Adult
On site
Ingestion of Soil
Dermal Absorption from Soil
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
0.03
0.41
0.34
0.05
0.8
3.6
49.4
41.1
6.0
100.0
None
2.0E-03
8.1E-03
I.4E-05
6.0E-07
l.OE-02
19.4
80.4
O.I
0.006
100.0
TCDD-TEQ(86%)
Benzo(a)pyrcne (8%)
Benzo(a)anlhracene (2%)
Dibcnz(a,h)anthracene (1%)
Benzo(b)fluoranthene (
-------
SUMMARY OF RISK ESTIMATES
JENN1SON-WRIGHT SITE
GRANITE CITY, ILLINOIS
Scenario
Receptor
Age Croup
Location
Pathway
Total
HI
%HI
by
Path-
WAV
!IQ>1 by Chemical
(% of total)
Total
Cancer
Risk
%CR
by
Path-
CR> 10"* by Chemical
(% of total)
Future Exposure Scenarios (Conl.)
3
4
5
Future Permanent
Sue Worker (Cent.)
Future Permanent
Site Worker
Fulure Construction
Worker
Adult (Conl,)
Adult
Adult
On site (Cent.)
22nd St. Lagoon
Area H
Jennite Pit
PCP Process Area
On site
Ingeslion of Water
Ingestion of Water
Ingeslion of Water
Ingestion of Water
Ingestion of Soil
Dermal Absorption from Soil
Inhalation of Vapor from Soil
46.7
0.2
0.3
31.9
0.3
0.5
42.1
~
-
-
0.7
I.I
97.5
Benzene (46%)
Naphthalene (22%)
2,4-Dimethylphenol (16%)
4-Methylphenol (9%)
Manganese (3%)
None
None
Penlachlorophenol (90%)
Arsenic (7%)
Manganese (3%)
Naphthalene (94%)
Benzene (3%)
2.4E-03
2.0E-05
1.8E-05
3.7E-02
1.4E-04
6.2E-05
I.3E-05
~
-
-
--
65.6
28.3
6.1
Pentachlorophenol (
-------
SUMMARY OF RISK ESTIMATES
JENNISON-WRIGHT SITE
GRANITE CITY. ILLINOIS
Scenario
Receptor
Age Group
Location
Pathway
Total
HI
% HI
fay
Path-
way
HQ>1 by Chemical
(% of total)
Total
Cancer
Risk
V.CR
by
Path-
way
CR> lO'* by Chemical
(% of total)
Future Exposure Scenarios (Cent.)
5
6
7
Future Construction
Worker (Com.)
Future Nearby
Residents
Future Nearby
Residents During
Construction
Adult (Cont.)
Adult/Child
(Integral ed)
Child
Adult/Child
(Integrated)
Child
On site (Cont )
Off site
Off site
Off site
Off site
Inhalation of Fugitive Dust
Receptor/Pathway Total
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
Inhalation of Vapor from Soil
Inhalation of Fugitive Dust
Receptor/Pathway Total
0.3
43.2
0.5
0.1
0.6
1.8
O.I
1.9
44.7
0.3
45.0
114.4
0.7
115. 1
08
100.0
89.3
10.7
100.0
93.5
6.5
100.0
99.4
0.6
100.0
99.35
065
100.0
None
Naphthalene (90%)
Naphthalene (96%)
Benzene (3%)
Naphthalene (96%)
Benzene (3%)
2.6E-08
2.2E-04
2.5E-05
9.1E-07
2.6E-05
2.2E-05
3.6E-07
2.4E-05
1.4E-05
2.2E-08
1.4E-05
3.7E-05
5.6E-08
3.7E-OS
0.01
100.0
96.5
3.5
100.0
98.4
1.6
100.0
99.8
0.2
100.0
99.8
0.2
100.0
Dibenz(a,h)anlhracene ( 1 %)
Benzo(b)fluoranthene (<1%)
Benzene (
-------
Discussion of Uncertainty
The risk characterization combines and integrates the information developed in the exposure and
toxicity assessments; therefore, uncertainties associated with these assessments also affect the
degree of confidence that can be placed in the risk characterization results.
Summary of Exposure Assessment Uncertainties
Overall, the exposure estimates obtained are moderately reliable for COPCs at the Jennison-
Wright site. Several of the factors adding uncertainty to the estimates tend to result in
overestimation of exposure. These include:
The directed nature of some elements of the sampling program (i.e., dioxins/furans,
subsurface soils, and groundwater);
The use of conservatively estimated or extrapolated values for some exposure point
concentrations;
The use of the steady-state assumption for estimating soil exposure point concentrations;
and
i,
The use of conservative exposure parameter values in the exposure estimation
calculations.
One factor that could lead to under-estimation of the exposures is the use of sample quantitation
limits that could result in missing low concentrations of some contaminants that might pose
significant risks. However, only two chemicals were excluded from the Human Health Risk
Evaluation (HHRE) that meet this criterion.
Finally, one factor that could lead to over-estimation or under-estimation of exposures is the use
of the steady-state assumption for groundwater exposure concentration estimates.
The cumulative effect of all of the exposure uncertainties most likely is to overestimate the true
potential exposure of receptors at the site.
Summary of Toxicity Assessment Uncertainties
Because of the number of assumptions, data points, and calculations used to derive toxicity
indices, a degree of uncertainty is necessarily associated with the numerical toxicity values in any
risk assessment. To evaluate the meaning of any risk assessment, the uncertainties in the
assumptions made, the potential impact of quantitative changes in those assumptions on the risk
estimates, and the relevance of the findings to real-world exposures and risks must be considered.
The basic uncertainties underlying the assessment of the toxicity of a chemical include:
31
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Uncertainties arising from the design, execution, or relevance of the scientific studies that
form the basis of the assessment; and
Uncertainties involved in extrapolating from the underlying scientific studies to the exposure
situation being evaluated, including variable responses to chemical exposures within human
and animal populations, between species, and between routes of exposure.
These basic uncertainties could result in a toxicity estimate, based directly on the underlying
studies, that either under- or over-estimates the true toxicity of a chemical.
The toxicity assessment process compensates for these basic uncertainties through the use of
safety factors (uncertainty factors) and modifying factors when assessing noncarcinogens and the
use of the upper 95th percent confidence limit from the linearized multistage model for the SF
when assessing carcinogens. The use of the safety factors and the upper 95th percent confidence
limit in deriving the RfDs and SFs ensures that the toxicity values used in the risk estimation
process are unlikely to underestimate the true toxicity of a chemical.
In addition to these basic uncertainties, additional uncertainty is introduced by the route-to-route
extrapolation of toxicity values. However, this practice reduces the chance that overall risks
from site contamination will be underestimated.
Other Uncertainties
Two additional factors need to be considered when discussing uncertainties associated with the
overall risk characterization: the cumulative effect of using conservative assumptions throughout
the process; and the likelihood of the exposures postulated and estimated in the exposure
assessment actually occurring.
The cumulative effect of using conservative assumptions throughout the risk estimation process
could be to substantially overestimate the true risks. However, exposure factors used in this
assessment were based on site-specific information, whenever it was available. Consequently,
the risk estimates obtained for the Jennison-Wright site are believed to be sufficiently conserva-
tive to adequately protect human health, while generally remaining within the range of risks that
individuals in the area may actually experience.
The last uncertainty factor to consider is the likelihood of the postulated exposures actually
occurring at the Jennison-Wright site. The soil exposure pathways identified as complete under
current conditions are all plausible, and exposure is either presently occurring by these pathways
or such exposure could reasonably be expected. Although the postulated frequencies of
occurrence may overestimate average occurrence, they could reflect the actual exposures of some
individuals.
Conversion of the site to industrial or commercial use and exposure of site workers and nearby
residents to site soils by the same routes in the future is also plausible. Exposure to contaminants
32
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through the use of site groundwater as a drinking water source is considered unlikely because
there is a public water supply.
SUMMARY OF ECOLOGICAL RISK ASSESSMENT (SERE)
The SERE was prepared based on information collected by Ecology & Environment (E & E)
during the site characterization investigation from July through September 1997. Federal and
state agencies were contacted for information on sensitive habitats and protected species in the
vicinity of the site, and relevant maps were reviewed to identify nearby sensitive habitats. In
addition, information was obtained from a local Illinois Department of Natural Resources
(IDNR) representative who visited the site.
A quantitative ecological risk evaluation for the Jennison-Wright site was not performed because
the findings of the SERE indicate that the site is not likely to impact wildlife. Specifically, the
following findings were made for the Jennison-Wright SERE:
Only approximately 50% of the site is vegetated, plant species at the site are of low value to
wildlife, and there are no aquatic resources at the site. Habitat at the Jennison-Wright site is
of a very low quality to wildlife;
The site is located in an industrial and residential area. Only common wildlife accustomed to
human activity and disturbance could potentially use the site, and would likely do so only as
transient or "visiting" species;
The closest aquatic resource is an unnamed intermittent stream approximately 1 mile from
the site. This stream is likely populated by a low diversity of stress-tolerant species. Site
contaminants are not likely to impact this stream because of the distance from the site and the
absence of contaminant migration routes;
The closest ecologically sensitive areas are wetland pockets and heron rookeries located
approximately 1 mile to the north and northwest of the site. Site contaminants are not likely
to impact this resource; and
Site remediation is planned. Consequently, off-site contaminant migration (groundwater and
surface soil) will be mitigated, and the already-low potential for exposure from surface soil
will be further decreased.
Based on the above, no adverse impacts to wildlife and/or sensitive habitats in the vicinity of the
site are expected to result from contamination at the Jennison-Wright site.
The conclusions of the ecological portion of the risk assessment are:
Habitat at the Jennison-Wright site is of a very low quality to wildlife;
33
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The site is located in a mixed industrial/residential area. Only common wildlife
accustomed to human activity and disturbance are likely to use the site; and
The closest aquatic resource and ecologically sensitive areas to the Jennison-Wright site
are located approximately one mile away and are not likely to be impacted by on-site
contamination.
REMEDIAL ACTION OBJECTIVES ]
Remedial Action Objectives (RAOs) are medium-specific goals for protecting human health and
the environment. The RAOs for the Jennison-Wright site were established under the broad
guideline of being protective of human health and the environment, while remaining within
statutory limits and attaining Applicable or Relevant & Appropriate Requirements (ARARs) to
the extent practicable. The RAOs were developed to reduce the potential for exposure through
specific remedial actions (i.e., institutional controls, containment, removal, and/or treatment).
During the development of the RAOs, ARARs and contaminant concentrations are evaluated to
establish risk-based cleanup objectives (CUOs) and to determine the scope of the removal
action(s) necessary to meet the objectives. The CUOs proposed for the Jennison-Wright site are
presented shown in the table below.
CLEANUP OBJECTIVES
JENNISON WRIGHT SUPERFUND SITE
-. ; Sbiico^ ,; /-' , ' '
"^ < ' "C;»*, ?'*<$ft V' '-'<''" '"'',
. . '" " - ^%v*<~ ." ^ , " skg> . ;
3,000°
14,000b
2,000C
22,000C
32,000b
27,000'
954,000°
2,000C
ll,000b
51,000b
1
lEPATACOTierl
2,100
170,000
17,000
170,000
1,700,000
8,200,000
None
17,000
170,000
520,000
None
34
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CLEANUP OBJECTIVES
JENNISON WRIGHT SUPERFUND SITE
Oroiradwater CGPC
Arsenic
Benzene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
PCP
alpha-BHC
Manganese
Naphthalene
2,4-Dimethylphenol
2-Methylphenol
Proposed CCJO
(f«S^)
50
10
0.13
0.18
0.4
4
1.0
0.03
200
400
200
500
lEPATACOTJerl
0»g^)
50
5.0
0.13
0.18
0.17
1.5
1.0
0.03
None
25
140
350
aCUO is based on the construction worker scenario.
b CUO is based on the estimated soil saturation concentration.
c CUO is based on the permanent site worker scenario.
Note: The proposed CUOs were calculated using the results of the Streamlined Risk Evaluation
(SRE) as a basis. The proposed soil CUOs represent the 10"5 risk level for carcinogens, or a
Hazard Quotient (HQ) of 1 for noncarcinogens.
There are two exceptions for these CUOs. The Maximum Contaminant Level (MCL) for arsenic
in groundwater is given as 50//g/L and has been adopted as the cleanup level for arsenic although
the corresponding 10"6 cleanup level for arsenic is 0.2jug/L. The other exception is the cleanup
level for dioxin in soil at the site. The 10~5 risk level CUO for dioxin was calculated at 0.2yug/L.
However, based upon a review of the Agency for Toxic Substances and Disease Registry
(ATSDR) documentation, a CUO of 1/^g/kg is recommended by ATSDR for dioxin and is
therefore proposed.
For dioxin cleanup numbers, EPA's "Approach for Addressing Dioxin in Soil at CERCLA and
RCRA Sites," OSWER Directive 9200.4-26, April 13, 1998, was taken into consideration in
developing preliminary soil remediation goals for dioxin. As documented in the Administrative
Record, a preliminary remediation goal of 1 ppb technical equivalency factor (TEF) was selected
35
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for soil at the site for areas reasonably expected to be used as commercial/industrial property
(with the potential for a day-care facility to be located at the site in the future). A final soil
cleanup level of 1 ppb Technical Equivalency Factor (TEF) was selected for the site based on an
evaluation, as documented in the Record of Decision, of a range of cleanup alternatives using
EPA's nine remedy selection criteria. The final soil cleanup level of 1 ppb TEF for this area
reasonably expected to be used as commercial/industrial property (with a potential future day
care facility to be located here) is considered protective (as documented in the Administrative
Record) for human health and the environment, based on future use of the site for residential
purposes, and reflects and excess cancer risk of 2.5 X 10'4.
The proposed groundwater CUOs represent the 10"6 level for carcinogens or a hazard quotion
(HQ) of 1 for noncarcinogens, or the maximum contaminant level (MCL). The IEPA TACO
Tier 1 values are provided for comparison. TACO Tier 1 values represent the 10'6 risk level for
carcinogens, and a HQ of 1 for noncarcinogens. For soil, the more conservative (lower) of the
ingestion or inhalation values for industrial/commercial properties, construction worker scenario,
are shown. For groundwater, the TACO Tier 1 figures are equivalent to the Class 1 groundwater
standards.
Based on the identified ARARs and to be considered (TBC) requirements, and the need to reduce
the potential threat to human health and the environment, the following general RAOs were
developed for the Jennison-Wright site:
Prevent current nearby residents and potential future site workers from contacting,
ingesting, or inhaling on-site soil and waste materials containing COPCs that exceed the
calculated risk-based CUOs;
Prevent the continued release of contaminants to groundwater;
Initiate long-term groundwater restoration to MCLs;
Abate regulated asbestos containing material (RACM) present in the on-site buildings;
Remove listed hazardous waste from the site for treatment and disposal at an
appropriately licensed facility; and
To the extent practical, pump NAPLs from the subsurface in the vicinity of the 22nd
Street lagoon, and treat collected groundwater.
DESCRIPTION OF ALTERNATIVES
The alternatives analyzed for this site are presented below. Each Operable Unit (OU) is discussed
with a variable number of alternatives based upon available technology for that particular media.
These alternatives correspond with those outlined in the EE/CA.
36
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Alternative 1: "No Action" Alternative
Time to Implement: None
The Superfund program requires that the "no action" alternative be evaluated at every site to
establish a baseline for comparison. Under this alternative the Illinois EPA and USEPA would
take no further action at the site to prevent exposure to the soil and groundwater contamination.
This alternative is applicable to each of the media addressed by the EE/CA.
Operable Unit 1; Soils and Waste (S& Wl
The Resource Conservation and Recovery Act (RCRA) regulations make a distinction between
what is considered waste and soil. Due to treatment regulations, waste and soils must be treated
differently. However, both are listed in the same OU because of their similar nature. An
estimated 55,0000 cubic yards of contaminated soils and 300 cubic yards of waste will be
addressed.
"Waste":
Regardless of the remaining alternatives for the treatment of soils at the site, there is only one
alternative for what is classified as "waste" at the site. This waste is comprised of the remaining
oil, sludge, and drip track residues found in various containers and areas around the site. Due to
regulations dictated by RCRA, and the future anticipated use of the site, the wood-treating waste
found on the site would be removed from the site and incinerated at an approved off-site facility.
Time to Implement: 12 months
Alternative S&W 1: 24-Inch Permeable Soil Cover
Time to Implement: 12 months
To implement this alternative, all miscellaneous debris would be removed from the site. All
ground vegetation would be removed, chipped, and graded on-site. A fabric underliner would be
placed upon the graded site and act as a boundary between contaminated and clean soils. The
fabric would then be covered with 18 inches of permeable fill material and 6 inches of topsoil.
The topsoil layer would then be seeded for erosion control.
This alternative is intended to reduce the potential for direct human exposure to contaminated
soil and to minimize migration of contaminants off site through windblown dust particles or by
being tracked off site by vehicles or machinery operating on site during demolition, cleanup, and
redevelopment activities. Because an impermeable soil cover would not be infiltrated by rainfall,
the stormwater would cause ponding on the cover. Construction of effective sewers or drainage
ditches to direct stormwater to the stormwater sewer system would be difficult due to the flat
nature of the site. Therefore, a permeable cover was selected.
37
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Because contaminated soils and wastes would remain on site, this alternative would also include
institutional controls in the form of deed restrictions to limit the potential for human exposure to
contaminants. Any future redevelopment of the site (such as a brownfields strategy) would
require a reevaluation of the protectiveness of the cover, based on final site configuration and
projected use.
ARARs applicable to Alternative S&W1 include pertinent RCRA sections for the removal and
disposal of listed hazardous waste. During excavation activities associated with the listed
hazardous wastes, dust may be generated. Therefore, dust suppression (RCRA §3004[e]) also
would be considered an ARAR. Since the proposed landfill cover is going to be constructed of
permeable materials, stormwater will infiltrate through the cover, causing contaminants to
continue to leach into the ground water. Therefore, Title 35,1 AC, Part 620, entitled Groundwater
Quality, and the Safe Drinking Water Act (SDWA) can be considered to be relevant and
appropriate. While not an ARAR, TACO CUOs are to be considered for this alternative.
EPA's RCRA guidance states that though a contaminated medium may exhibit characteristics of
a hazardous waste, it is not considered a hazardous waste until it is excavated. Additionally,
TCLP analysis conducted as part of the site investigation indicates that surface soils, subsurface
soil, and sediments at the site do not exhibit characteristics of a hazardous waste. Since no listed
hazardous waste will be left on site, and no additional excavations are planned for this
alternative, RCRA closure and post-closure requirements and the Treatment Surface
Impoundment Exemption (35 IAC 728.104) do not apply.
Alternative S&W 2: Landfarming
Time to Implement: 6 years
In this alternative, soils contaminated above the CUOs would be treated in an on-site landfarm
treatment cell constructed on the northeastern portion of the site. According to BPA's
Presumptive Remedies for Soils, Sediments, and Sludges at Wood Treater Sites, landfarming is
an EPA-recommended technology for wood-treater sites (EPA 1995b). In this landfarming cell,
biodegradable contaminants are subjected simultaneously to the following processes: 1) bacterial
and chemical decomposition, 2) leaching of water-soluble components, and 3) volatization of
some components of the original waste, as well as certain decomposition products. Only soils
would be treated via this alternative. The landfarm treatment cell would consist of a compacted
clay liner, drainage system, retention pond, water treatment and discharge system, moisture and
nutrient addition equipment, and tilling equipment. Once the soil within the cell is remediated to
the CUOs, the soil would be graded to final contours across the site.
Surficial soil, subsurface soil, and non-RCRA hazardous wastes would be treated in the landfarm
cell. The results of toxicity characteristic leaching procedure (TCLP) analysis indicate that
surface and subsurface soil would not be considered RCRA characteristic hazardous waste;
therefore, RCRA Subtitle C requirements for treatment storage disposal facilities (TSDFs) and
38
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land disposal restrictions (LDRs) do not apply to the landfarm cell. Deep excavations remaining
after subsurface soil removal would be backfilled with fill material as soon as feasible to prevent
the ponding of water in the excavations, and to eliminate the potential of workers or trespassers
falling into the excavations. After excavation, the contaminated soils and wastes would be
transported to a soil stockpile area constructed adjacent to the treatment cell. Soil from the
stockpile would be placed into the cell to a uniform thickness of 1 foot. This would allow for
ease of tilling the soil to increase the oxygen content, and mixing in of nutrients. Using the
average concentrations of nitrogen and phosphorus present in site soil, it is estimated that the
treatment of 55,000 cubic yards of contaminated soil would require approximately 18,000
pounds of nitrogen as N and 3,000 pounds of phosphorus as P. Exact nutrient addition
requirements would be determined in the design phase by conducting additional bench-scale
testing.
The landfarm cell would be designed to drain water into an approximately one-million-gallon
retention pond. Water in the retention pond would be allowed to evaporate. When the water
level in the pond approached 80% of full capacity, drawdown of the pond would begin by
pumping the water through a carbon filter (as required by Granite City), followed by discharge to
the Granite City sanitary sewer system. The contractor operating the cell would be responsible
for metering the discharge.
Based on an area of 6.9 acres and a lift thickness of 1 foot, approximately 11,000 cubic yards of
soil would be treated per lift. Considering the climate in the area of the Jennison-Wright site, it
is assumed that one soil lift (11,000 cubic yards) would be processed in the treatment cell per
year. It is estimated that six years would be required to treat the entire volume of contaminated
soil.
The landfarm cost estimate assumes that one soil sample would be collected on a quarterly basis
per 1,000 cubic yards of soil within the landfarm cell, and that each sample would be analyzed
for the soil COPCs, RCRA characteristic hazardous waste parameters, and nutrient constituents.
The purpose of this sampling would be to monitor the progress of the soil treatment, to determine
when soil CUOs have been achieved, and to ensure that treated soils do not exhibit RCRA
hazardous waste characteristics. In the event that, after one year of treatment, a batch of soil
within the cell does not achieve CUOs, it would likely be left in the cell for further treatment. If,
after a period of one additional year of treatment, the batch still has not met the CUOs or exhibits
RCRA hazardous waste characteristics, the isolated soil would be shipped off site for disposal.
Air samples would be collected monthly from one upwind and two downwind monitoring points
to ensure that any air emissions from the landfarm are not impacting the surrounding
neighborhood. Also included in the cost estimate is the preparation and submittal of a yearly
report which would summarize the soil sample analytical results, discuss operational highlights
and difficulties, and update the expected time frame to complete soil treatment.
For Alternative S&W2, activities associated with the removal, dust suppression, transportation,
and disposal of listed hazardous waste would be covered by RCRA. Additionally, confirmation
sampling and analysis of the open excavation and treated landfarm soils would also be performed
39
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to ensure that characteristic hazardous waste was not placed in the landfarm cell, and to identify
whether any characteristic hazardous waste was left in place. These activities are governed by
RCRA, and the pertinent sections of RCRA that cover these activities are considered to be
ARARs for this alternative. Excess stormwater runoff, which may be discharged to the local
sanitary sewer system, would be covered by the Publicly Owned Treatment Works (POTW)
requirements as set forth by the Granite City Wastewater Department, which are considered to be
an ARAR. While TACO is not an ARAR, the CUOs are to be considered for this alternative.
As noted above, EPA's RCRA guidance states that though a contaminated medium may exhibit
characteristics of a hazardous waste, it is not considered a hazardous waste until it is excavated.
It is the intent of the removal action to reduce risk associated with contaminated site soils and to
remove known listed hazardous waste from the site, followed by disposal at an appropriately
licenced off-site facility. Additionally, TCLP analysis indicates that surface soils, subsurface
soil, and sediments at the site do not exhibit characteristics of a hazardous waste. Therefore,
RCRA closure and post-closure requirements and the Treatment Surface Impoundment
Exemption (35 I AC 728.104) do not apply. Since confirmation sampling and analysis of the
open excavation and excavated soils will be performed to ensure that hazardous waste will not be
placed in the landfarm cell, 35IAC 728.104, the Treatment Surface Impoundment Exemption,
would not be considered an ARAR. Additionally, the soil treated in the landfarm cell will be
tested prior to its removal to ensure that cleanup objectives have been meet and that the material
does not meet the RCRA definition of a characteristic hazardous waste. Therefore, statutory
requirements of 35 I AC 808 through 815, which cover solid waste disposal requirements, would
not be considered ARARs.
Alternative S&W 3: Low-Temperature Thermal Desorption
Time to Implement: 6 years
In this alternative, contaminated soil would be excavated and transported to a soil stockpile area
located south of 22nd Street, followed by desorption of contaminants from the soils in a mobile
low-temperature thermal desorption (LTTD) unit. Per EPA's Presumptive Remedies for Soils,
Sediments, and Sludges at Wood Treater Sites, LTTD is an EPA-recommended technology for
wood treater sites (EPA 1995b). This process involves heating soils containing organic
contamination in a heated chamber, thereby volatilizing the moisture and organic contaminants.
LTTD desorbs the organic compounds in the soil without reaching combustion temperature.
Inorganic compounds are not treated with this technology. As with the landfarming alternative,
the treated soil would be graded to final contours across the site.
Air permits would be required to operate the LTTD unit. With LTTD treatment, there is a
potential for some contaminants with volatilization temperatures above the LTTD operating
temperatures to remain in the soil/waste mixture. The LTTD system is designed to treat organic
contaminants with boiling points less than SOOT, and soil with less than 10% total organics and
moisture.
40
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During treatment activities, air monitoring would be conducted pursuant to OSHA and National
Emission Standard for Hazardous Air Pollutants (NESHAP) regulations to ensure that workers
and the public are not exposed to site contamination above allowable levels. Air emission
standards and potentially required air pollution control equipment could become a substantial
cost and performance factor for on-site LTTD.
Based on the soil volumes requiring treatment, and an overall average feed rate of 2 tons per
hour, it is estimated that this alternative would require approximately six years to complete.
The LTTD cost estimate assumes that confirmation samples would be collected at the rate of one
per week, for a total of 52 samples annually that would be analyzed for COPCs. In addition, air
samples would be collected monthly from one upwind and two downwind monitoring points to
determine emission concentrations from the LTTD unit operations.
ARARs for Alternative S&W3 include RCRA regulations for the removal, dust suppression,
transportation, and disposal of listed hazardous waste; and 35 I AC Subtitle B for air permitting of
the off-gas from and operation of pollution-control devices for the LTTD unit. Since
confirmation sampling of the excavation will be performed to ensure that hazardous waste will
not be treated by the LTTD process, 35 IAC 728.104, the Treatment Surface Impoundment
Exemption, would not be considered an ARAR. Additionally, the soil treated by the LTTD unit
will be tested prior to its placement back in the open excavations to ensure that cleanup
objectives have been met and that the material does not meet the RCRA definition of a
characteristic hazardous waste. Therefore, statutory requirements of 35 IAC 808 through 815,
which cover solid waste disposal requirements, would not be considered ARARs. While TACO
is not an ARAR, the CUOs are to be considered for this alternative.
Alternative S&W 4: Off-Site Disposal
Time to Implement: 1 year
In this alternative, all the contaminated soil would be excavated, loaded into trucks, and
transported to an appropriate off-site hazardous waste treatment, storage, and disposal (TSD)
facility for disposal. The excavated areas would then be backfilled with clean soil and seeded.
F-listed hazardous waste identified at the site would be transported to an offsite disposal TSD
facility for incineration and disposal. Off-site disposal of wastes would be subject to RCRA
requirements and to lEPA's off-site disposal policy. Because the contaminated soils and wastes
would be disposed offsite, there would be no post removal site control (PRSC) activities or
institutional controls associated with this alternative. It is estimated that this alternative would
take one year to complete.
ARARs for Alternative S&W4 are the same as those for Alternative S&W2 with the following
exception. The excavated soils will be classified as either a listed or characteristic hazardous
waste. Therefore, statutory requirements of 35 I AC 808 through 815, which cover solid waste
41
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disposal requirements, would be considered ARARs. Finally, TCLP results from the site
investigation indicated that surface soil, subsurface soil, and sediments are not characteristic
hazardous wastes. Based on the analytical results and the previously mentioned EPA RCRA
guidance for soils left in place, RCRA closure and post-closure requirements, and the Treatment
Surface Impoundment Exemption (35 IAC 728.104) do not apply.
Operable Unit 2: Non-Aqueous-Phase Liquids
Alternative NAPL 1: Hot Water and Steam Flushing
Time to Implement: 4 years
This technology uses hot water and steam to displace and carry NAPLs to a point where they can
be collected. In this process, injection and extraction wells are installed in an area contaminated
with NAPLs. Steam is injected below the NAPLs, and condenses, causing rising hot water to
displace the NAPLs to the extraction wells. Hot water is also added to the subsurface above the
steam to further displace the NAPLs. The collected groundwater and NAPLs are processed
through an oil/water separator with the oil being collected and the majority of the water being
reinjected. Any water that is not reinjected is treated (i.e., granular activated carbon or ex situ
biodegradation) to pretreatment standards before being discharged to the local publicly owned
treatment works.
The following assumptions were made in preparing the conceptual design:
There are no tanks or usable equipment on site;
Six injection wells and two extraction wells would be required, installed in a connected 5-
spot pattern;
Injection wells would be 6 to 8 inches in diameter, and would have three screened
intervals (i.e., shallow, intermediate, and deep). The total injection rate would be a
minimum of 90 gallons per minute (gpm);
Extraction wells would be a minimum of 10 inches in diameter and screened through the
entire contaminated interval. The total extraction rate would be 10% to 20% greater than
the injection rate (i.e., 99 to 108 gpm);
Five monitoring wells would be required for temperature and water level measurements;
and
Services needed for operating the system would include 480-volt, 3-phase electrical
42
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service, natural gas or propane for the heater, a small building or shed to house
equipment, and an office trailer.
The time required until the process has achieved a point of diminishing returns (i.e., volume
recovered compared to operating expenses) is estimated to be between three and four years.
ARARs associated with Alternative NAPL1 include SDWA; Title 35 I AC, Part 620,
Groundwater Quality; and 40 CFR Part 145 as administered by lEPA's underground injection
control (UIC) program. Additionally, the recovered NAPLs will have to be disposed of off site.
Depending upon the analytical results, the NAPLs will be classified as either a characteristic
hazardous waste or a special waste. Therefore, either RCRA disposal regulations or statutory
requirements of 35 IAC 808 through 815, which cover solid waste disposal, would be the
governing ARAR for waste disposal.
Alternative NAPL 2: Surfactant Flushing
Time to Implement: 4 years
Surfactants are chemical compounds which have the ability to make NAPLs more mobile in
water. In surfactant flushing, a surfactant is injected into the NAPLs as part of a solution. The
intent is to mobilized this NAPLs to a point where it can be more readily removed from the
groundwater. Use of this method for NAPLs treatment is considered to be an emerging
technology and not a proven "off the shelf technology. No full-scale application of surfactant
flushing for which information is readily available.
A significant level of effort is required to properly design a surfactant flood. The choice of
surfactant at one site may differ significantly from that at another site given variations in
contaminant types, geology, and groundwater flow. Typically, a number of laboratory tests need
to be carried out as part of the design effort, followed by pilot-scale testing at the site. It is not
uncommon to screen the performance of up to 100 different surfactants prior to final selection for
a site.
At present, there have been no full-scale applications of surfactant flushing for which
information is readily available. Consequently, the technology is regarded as an emerging and
not a proven or "off the shelf technology. However, the time to full-scale application of this
technology appears to be short. For this reason, surfactant flushing has been included as a
potential NAPLs removal alternative for the Jennison-Wright site.
The amount of time required to complete surfactant flushing depends on a number of factors,
including the permeability of the subsurface materials, spacing of injection and recovery points,
the number of pore volumes required, and the degree of mass removal that is required. The time
required for surfactant flushing is thought to be similar to that of Alternative NAPLs 1 (three to
four years).
43
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The ARARs for Alternative NAPLs 2 are identical to those for Alternative NAPLs 1.
Operable Unit 3: Groundwater fGW)
In addition to NAPLs removal, the following alternatives were explored to address shallow and
intermediate groundwater contamination present within the 22nd Street lagoon and PCP process
area plumes. The NAPLs removal system, in conjunction with the following groundwater
treatment alternatives, forms a long-term groundwater treatment system to address both on-site
and off-site groundwater contamination.
The concentrations of COPCs in the other areas of groundwater contamination identified at the
site are much lower than in these two plumes. Therefore, these other areas of groundwater
contamination will be allowed to naturally attenuate, as described below.
Alternative GW 1: Natural Attenuation
Time to Implement: 100 years
Natural attenuation makes use of natural biodegradation processes to reduce the concentration
and amount of pollutants at contaminated sites. Natural attenuation, also referred to as
bioattenuation or intrinsic bioremediation, is an in situ treatment method. Natural attenuation is
often used as one part of a site cleanup that also includes the control or removal of the sources of
the contamination.
The processes .that contribute to natural attenuation are typically acting at many sites, but at
varying rates and degrees of effectiveness, depending on the types of contaminants present, and
the physical, chemical, and biological characteristics of the soil and groundwater. Natural
attenuation processes may reduce contaminant mass (through destructive processes such as
biodegradation and chemical transformations); reduce contaminant concentrations (through
simple dilution or dispersion); or bind contaminants to soil particles, reducing the amount of
chemical contaminant migration (adsorption).
The effects of dilution and dispersion appear to reduce contaminant concentration but do not
destroy the contaminants. Relatively clean rainwater and snow melt from the ground surface can
seep underground to mix with and dilute contaminated groundwater. Clean groundwater from an
upgradient location flowing into contaminated areas, or the dispersion of pollutants as they
spread out away from the main path of the contamination plume, also leads to reduced
concentrations of contaminants in a given area.
In certain situations, natural attenuation is an effective, inexpensive cleanup operation and the
most appropriate way to remediate some contamination problems. Natural attenuation is
sometimes mislabeled as a "no action" approach. However, natural attenuation is really a
proactive approach that focuses on the confirmation and monitoring of natural remediation
44
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processes rather than relying totally on engineered technologies. Natural attenuation is non-
invasive, and, unlike many elaborate mechanical site cleanup techniques, while natural
attenuation is working below the ground, the land surface above ground may be used. Natural
attenuation is less costly than engineered treatment options, and requires no energy source or
special equipment. The biggest drawback of this technology is the long period of time required
achieve CUOs. Based on the high levels of contamination present in the 22nd Street lagoon and
PCP process area plumes, a time period of 50 to 100 years, at a minimum, would likely be
required to achieve CUOs.
It is likely that a lesser period of time would be required to achieve CUOs in the other areas of
on-site groundwater contamination. Appendix K (Biofeasibility Study Report) of the EE/CA
gives sufficient detail to justify the use of monitored natural attenuation for the less contaminated
portions of the aquifer. Microbial counts were taken at several locations to verify the microbes'
affinity for breaking down the contaminants of concern. It is estimated that at ten years past the
beginning of construction that this portion of the remedy will be evaluated to determine its
progress toward meeting remediation goals. Actual performance of the natural attenuation
remedy will be carefully monitored in accordance with the monitoring plan to be developed as
part of the site remedy design. If monitoring data indicate that contaminant levels do not
continue to decline as estimated, Illinois EPA and USEPA will reconsider the remedy decision.
One or more of the following observations could lead to re-consideration of the remedy, if
confirmed by four or more rounds of sampling:
Increase in levels of parent contaminants, indication that other sources may be present.
Concentration levels of parent contaminants and/or daughter products differ significantly
from modeling predictions
PRSC activities include the collection of groundwater samples on a quarterly or semiannual basis
(semiannual sampling was assumed for cost estimating purposes) to monitor the progress of the
natural attenuation.
ARARs associated with Alternative GW1 include SDWA and Title 35 IAC, Part 620,
Groundwater Quality.
Alternative GW 2: Enhanced In Situ Bioremediation
Time to Implement: 20 years
Enhanced in situ bioremediation is a process that attempts to accelerate the natural
biodegradation process by providing oxygen and nutrients to degrading microorganisms that may
otherwise be limited in their ability to biodegrade contaminants.
45
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The addition of oxygen can be achieved by either sparging air below the water table or
circulating hydrogen peroxide throughout the contaminated groundwater zone. Additionally,
solid-phase peroxide products (e.g., oxygen-releasing compound [ORC]) can also be used for
oxygen enhancement and to increase the rate of biodegradation.
Oxygen Enhancement with Air Sparging. In this technique, air is injected under pressure
below the water table to increase groundwater oxygen concentrations. A typical air sparing
system has one or more subsurface points through which air is injected into the saturated zone.
The air travels up through the saturated zone either in the form of air bubbles or as continuous air
channels.
The three main contaminant-removal mechanisms that occur during the operation of air sparging
systems include in situ stripping of dissolved organic contaminants, aerobic biodegradation of
both dissolved and sorbed-phase contaminants resulting from the delivery of oxygen, and direct
volatization of NAPLs. Implementation of air sparging is greatly influenced by the ability to
achieve significant air distribution within the target zone. The presence of lower permeability
layers will impede the vertical passage of injected air. Homogeneous geologic conditions, such
as present at the Jennison-Wright site (with the exception of silts in certain areas of the shallow
groundwater zone), are essential for the success of air sparging.
Oxygen Enhancement with Hydrogen Peroxide. During hydrogen peroxide enhancement, a
dilute solution of hydrogen peroxide is circulated through the contaminated groundwater zone by
pumping the solution into designated injection wells to increase the oxygen content of
groundwater and enhance the rate of aerobic biodegradation of organic contaminants by naturally
occurring microbes. However, because hydrogen peroxide is a strong oxidizer and can be
dangerous if handled improperly, it is the least preferred method of oxygen enhancement.
Oxygen Enhancement with ORC. There are several methods for the introduction of ORC into
the subsurface. In the most common method, ORC is placed into "socks," which are linked and
lowered into a well. The ORC slowly releases oxygen to the groundwater flowing through the
well. Another approach is to inject ORC directly into the aquifer by grouting techniques.
For the Jennison-Wright site, it appears that both air sparging and ORC could be used effectively
for oxygen enhancement. For the groundwater contamination plume in the PCP process area,
which extends vertically only to the intermediate depth of the aquifer (i.e., 50 to 60 feet BGS),
ORC socks would be the preferred method of oxygen enhancement. Existing monitoring wells
MW8S and MW8M would be used for sock placement. Also, eight to 12 additional monitoring
wells (both shallow and intermediate) would be required in the PCP process area for sock
placement. Exact well placements would be determined in the removal action design phase.
Deep groundwater exceedances of CUOs were detected in one groundwater monitoring well
(MW5D) located in the 22nd Street lagoon area. Since there is the potential for the selected
NAPLs removal alternative for this area to increase deep groundwater contamination, it was
necessary to develop a groundwater alternative; air sparging would be the preferred technique.
46
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This is especially true because the injection and extraction wells installed during the NAPLs
removal phase could be converted to air sparging wells at the completion of removal. Additional
smaller - diameter sparging points may also be required. Again, the determination of the exact
number of air sparging points would be determined in the design phase.
Two nutrients required by microorganisms are nitrogen and phosphorus. The most common
sources of nitrogen and phosphorus are ammonia and nitrate, and phosphates, respectively.
These nutrients are typically introduced into the subsurface by pumping liquid forms into
monitoring, injection, and/or extraction wells.
ARARs associated with Alternative GW2 include SDWA and Title 35 IAC, Part 620,
Groundwater Quality. Since nutrients will be added to groundwater, 40 CFR Part 145, as
administered by lEPA's UIC program, also is considered to be relevant and appropriate.
Alternative GW 3: Ex Situ Biological Treatment
Time to Implement: 10 years
Ex situ biological treatment uses bioreactors to degrade contaminants in water with
microorganisms through suspended or attached biological systems, which are installed in an
aboveground treatment building. In such a system, contaminated groundwater is removed from
the subsurface by a series of extraction wells and pumped into the treatment building. There, the
groundwater is treated, and discharged to the sanitary sewer or reinjected into the subsurface
downgradient of the site's groundwater contaminant plumes.
ARARs associated with Alternative GW3 include SDWA and Title 35 IAC, Part 620,
Groundwater Quality, and the POTW requirements as set forth by the Granite City Wastewater
Department.
Operable Unit 4: Buildings (B)
Alternative B 1: Building and Foundation Removal
Time to Implement: 1 year
In order to obtain comprehensive- soil removal alternative at the Jennison-Wright site, soils
beneath the existing foundations of site structures will have to be addressed. Based on data
obtained during the site investigation, it is likely that contaminants below these foundations
exceed the established CUOs. Therefore, building demolition and removal of the concrete
foundations must be performed in order to address the sub-floor soil contamination as part of any
soil removal/treatment alternative. An estimated 1800 cubic yards of concrete foundations and
slab materials would need to be addressed. The concrete floor slabs of the buildings and silos
47
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would be decontaminated, crushed, and shipped offsite for disposal.
There are five buildings and two silos on site. The buildings are referred to as the office
building, the white building, the green building, the boiler building, and the Transite building.
The only known hazardous material associated with the buildings is RACM. To facilitate the
implementation of the soil removal action at the site, RACM in the on-site buildings will be
abated prior to demolition of the buildings and silos. For cost estimating purposes, it has been
assumed that the concrete floor slabs of the buildings and silos would be decontaminated using
high-pressure water washing, then crushed, and shipped offsite for disposal. Any floor drains
encountered during the demolition would be emptied, decontaminated, and shipped off site for
disposal. The total estimated amount of concrete foundation or slab material on site is 1,801
cubic yards. Decontamination wash water used for concrete and drains would be treated by the
proposed groundwater treatment system or containerized and shipped offsite for disposal.
The total estimated amount of RACM on site is 181 linear feet on pipes, and 7,085 square feet on
other structural components.
Because the total square footage on other structural components exceeds the exemption area of
160 square feet, the abatement and notification requirements of 40 CFR Part 61.145 paragraphs
(b) and (c) would be applicable to the demolition of the Jennison-Wright structures.
RACM abatement is achieved through the appropriate selection of one or more of the following
five accepted techniques: removal, encapsulation, encasement, enclosure, and repair. Because
the on-site buildings would be demolished following the RACM abatement, removal of RACM
is the abatement technique that should be used at the Jennison-Wright site. Of all the available
abatement techniques, removal offers the most satisfactory long-term solution.
Before RACM abatement would begin, the work areas where RACM is present would be
prepared in a manner that would protect human health and the environment. Since the
disturbance of RACM during removal generates airborne asbestos fibers that may remain
suspended in the air for a long time, work areas must be prepared to contain fibers during the
entire removal process. A common method of containment is to install polyethylene sheeting on
walls, the floor, and the ceiling. Construction of temporary walls using pine studs and
polyethylene sheeting would likely be required.
Removed RACM (with the exception of the transite panels) would be placed into specially made
disposal bags and transported to an off-site landfill for disposal. The transite panels, after being
carefully removed from the walls of the Transite building to prevent the release of asbestos
fibers, could be loaded directly into dump trucks for transport to the landfill.
The abatement of RACM at the Jennison-Wright site would be performed by a contractor trained
and certified to perform this work, and under the supervision of IEPA and Granite City officials.
48
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As stated in Section 4.2.1, the applicable ARAR for demolition of buildings with asbestos-
containing material is 40 CFR Part 61.145.
Operable Unit 5: Miscellaneous Items (MD
Alternative MI 1: Miscellaneous Items
Time to Implement: 1 year
The miscellaneous items OU is similar to the Buildings OU in that there are only two
alternatives: removal and no action. Because the items listed in this category are structures and
no treatment technologies are needed, only one alternative for managing these items is presented.
This group consists of the following items present on the site:
Two empty underground storage tanks (USTs);
Two above storage tanks (ASTs) that contain oil;
An oil/water separator that contains rainwater;
Rainwater and sediments present in the concrete basin;
Several sumps and pits that contain oily waste;
The collapsed pole bam;
Scattered debris piles consisting of varying amounts of concrete, scrap metal, wood, and
trash; and
Steel tram rail.
As an integral part of the soil alternative, the ASTs, oil/water separator, and concrete basin
should be incorporated into the site-wide removal action. These structures contain waste
materials that could potentially be released, thereby contaminating remediated or clean soils.
Additionally, soils beneath these structures have contaminant levels above the established CUOs.
If the structures are left in place, contaminated soils still will remain on site at the completion of
the soil removal alternative. The following removal methods are proposed for these structures.
The oil present in the two ASTs should be removed, containerized, and disposed of or recycled
off site. The ASTs should then be cleaned and scrapped.
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The rainwater present in the oil/water separator should be removed, passed through carbon, and
discharged to the sanitary sewer system. Permission from the Granite City wastewater
department would be required for this discharge, and a fee would be assessed. The oil/water
separator should then be cleaned and scrapped.
Rainwater present in the concrete basin should be removed, passed through carbon, and
discharged to the sanitary sewer. Sediments present in the concrete basin should be removed and
handled in the same manner as the site's soils and wastes. For example, if the soils and wastes
are to be treated in a landfarm, the concrete basin waste should be treated in the landfarm as well.
Once emptied, the basin should be demolished and removed from the site.
Solid and sludge waste present in the sumps and pits should be removed and handled in the same
manner as the site soils and wastes. The sumps and pits would then be demolished and removed
from the site.
In order to gain access to surface and subsurface soils that contain contaminants above the CUOs,
the debris piles, steel tram rails, and USTs should be removed. The removal method is as
follows:
The debris piles should be segregated into waste streams (i.e., steel, wood, concrete, and
trash), with each waste stream being disposed of or recycled as appropriate;
Steel tram rail should be excavated, cleaned to the extent feasible on an on-site
decontamination pad, and either scrapped or disposed of off site; and
The two empty USTs should be excavated, removed, cleaned, and scrapped. No residual
fuel sludge appears to be present in the USTs.
COMPARATIVE EVALUATION OF ALTERNATIVES
Based upon the alternative evaluations conducted in the EE/CA, a site-wide remedial action
alternative is proposed as the remedy for the site contamination. The selected alternative for
remediating the Jennison-Wright site is an array of individual alternatives for each of the five
operable units. Based upon analysis, this array of alternatives presents the best balance of trade-
offs among the alternatives with respect to nine criteria that Illinois EPA and USEPA use to
evaluate alternatives. This section profiles the performance of the selected alternative against the
nine criteria, noting how it compares to the other options under consideration. Evaluation
Tables at the end of the Analysis Portion display a comparison of the alternatives for each
operable unit.
50
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ANALYSIS
Overall Protection:
Overall protection of human health and the environment addresses whether each alternative
provides adequate protection of human health and the environment and describes how risks
posed through each exposure pathway are eliminated, reduced, or controlled, through treatment,
engineering controls, and/or institutional controls.
Because the "no-action" alternative is not protective of human health and the environment, it is
not considered further in this analysis as an option for this site.
All of the alternatives (with the exception of the "no-action" alternative and the natural
attenuation ground water alternative) provide varying degrees of protection of human health and
the environment by eliminating, reducing, or controlling risk through treatment, engineering
controls, or institutional controls.
For the "Soils and Waste" operable unit, the 24-inch permeable cover (Alternative S&W 1)
alternative would provide adequate protection; however, it would merely cover the waste and
contaminated soils on-site and would allow migration of the contaminants into the groundwater.
Off-site disposal of the contaminated soils and wastes (Alternative S&W 4) would be protective
of the residents, but would simply relocate the waste rather than reducing the toxicity of the
contaminants. The landfarming alternative (Alternative S&W 2) and the Low Temperature
Thermal Desorption (Alternative S&W 3) provide the highest degree of protectiveness because
they address the toxicity of the material.
For the "NAPLs" operable unit, the hot water and steam flushing alternative (Alternative NAPL
1) and the surfactant flushing alternative (Alternative NAPL 2) differ primarily in the fluid used
to displace the NAPLs. The use of surfactants is still an emerging technology and would require
extensive bench and pilot scale testing to determine its effectiveness at this site. Alternative
NAPL 1 has been used successfully at other wood-treating sites and has been determined to have
a good probability of success at removing contamination at this site.
All three of the "Groundwater" alternatives are considered protective. Natural attenuation would
likely occur at an unacceptably slow rate for the highly contaminated plumes. Both in situ and ex
situ bioremediation would reduce the contaminant levels in the groundwater at a substantially
higher rate than natural attenuation but ex situ remediation is the most aggressive of the three.
There are only two alternatives considered for each of the "Buildings" and "Miscellaneous
Items" operable units. In order for any of the soil remedial objectives to be implemented, the
buildings, foundations, and miscellaneous items must be removed. Therefore, no further analysis
of the alternatives "B 1" and "MI 1" will be necessary.
Compliance with ARARs:
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Section 121(d) of CERCLA and NCP Section 300.430(f)(l)(ii)(B) require that remedial actions
at CERCLA sites at least attain legally applicable or relevant and appropriate Federal and State
requirements, standards, criteria, and limitations which are collectively referred to as "ARARs,"
unless such ARARs are waived under CERCLA section 121(d)(4).
In the "Soils and Waste" operable unit, only the 24-inch cover alternative (Alternative S&W 1)
does not meet ARARs, as waste would be left in place above cleanup objectives. Because it does
not meet ARARs, it will be excluded from further consideration as an alternative. The
Landfarming, LTTD, and the Off-Site Disposal alternatives would all meet ARARs.
Both alternatives for the "NAPLs" operable unit have the potential to achieve ARARs.
The "Groundwater" operable unit has three possible alternatives. Only the natural attenuation
alternative would likely fail to meet ARARs as a potential remedy for the entire groundwater
operable unit. For the least contaminated plumes, the monitored natural attenuation alternative
will likely meet ARARs. Both the in situ and ex situ alternatives are expected to meet ARARs
and thus will be carried forward in consideration.
The "Buildings" and "Miscellaneous Items" would consist of simple removal of primarily
construction debris and would meet ARARs. The asbestos abatement portion of the removal in
the Buildings alternative would need to meet the requirements of 35 Illinois Administrative Code
Part 228.
Long-Term Effectiveness and Permanence:
Long-term effectiveness and permanence refers to expected residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment over time, once
clean-up levels have been met. This criterion includes the consideration of residual risk that will
remain onsite following remediation and the adequacy and reliablility of controls.
All three of the remaining "Soil and Waste" alternatives will provide both long-term
effectiveness and permanence. In the case of the off-site disposal alternative, the local residents
will be effectively protected as the contaminated soil would no longer be present on-site;
however, the soil would be removed to another location and not actually treated to reduce
contamination levels. Both the landfarming alternative and the LTTD alternative have a longer
implementation period, but all three will be permanent solutions at the local level.
Both "NAPLs" alternatives have a high degree of both long term effectiveness because the actual
contamination is being removed. Therefore, the level of permanence is also high as the
contaminants would be physically removed from the site.
Both of the remaining "Groundwater" alternatives involve biological treatment. While ex situ
biological treatment is more aggressive and would achieve cleanup objectives in the least amount
of time, both will be effective and permanent in the long term. Both alternatives will degrade the
contaminants to a level that will meet cleanup objectives.
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Reduction of Toxicity, Mobility, or Volume Through Treatment:
Reduction of toxicity, mobility, or volume through treatment refers to the anticipated
performance of the treatment technologies that may be included as part of a remedy.
Of the three remaining "Soil and Waste" alternatives, only the Off-Site Disposal alternative does
not reduce the toxicity and volume of the contaminants through treatment. Disposal would
reduce the mobility as the material would be removed from the site to a disposal facility where it
would remain in a more controlled environment. Both the Landfarming and LTTD treatment
alternatives achieve the three criteria above as they would permanently destroy most of the
contaminants in the soils. Both of these alternatives would require that the treated soils would
remain on-site.
Both "NAPLs" alternatives would also reduce the level of toxicity, mobility and volume of the
contaminants because the NAPLs would be physically separated from the groundwater and soils.
The NAPLs would then be removed to a separate facility where it would be disposed of properly.
The "Groundwater" alternatives are similar in their treatment of the water, but different in how
the treatment takes place. As both alternatives utilize biological treatment as a method to
permanently transform the contaminants, the toxicity is most certainly reduced. Neither mobility
nor volume are affected as the groundwater will not be removed from the site or redirected.
Short-Term Effectiveness:
Short-term effectiveness addresses the period of time needed to implement the remedy and any
adverse impacts that may be posed to workers, the community and the environment during
construction and operation of the remedy until cleanup levels are achieved.
Of the "Soil and Waste" alternatives, the off-site removal alternative has the shortest period of
exposure for both the workers and the surrounding community due to its relatively short
implementation period (less than one year) for the entire removal to take place. Both the LTTD
and landfarming alternatives take considerably longer to implement but the excavations made
will be on an intermittent basis. All the soil and waste alternatives will have a slightly elevated
risk of inhalation exposure during the excavation performed.
Among the remaining "NAPLs" alternatives, both alternatives offer the same possibility for
effectiveness in the short term. The surfactant flushing alternative would take longer to
implement, however as extensive bench and pilot scale studies would need to be performed. In
addition, both alternatives provide the same low potential for adverse human health and
environmental impacts as the actions occur largely underground.
Ex situ biological treatment is the most aggressive of the two remaining groundwater cleanup
alternatives. If implemented, this alternative would achieve groundwater CUOs in the shortest
period of time. However, this alternative has a larger above ground component (the above
ground treatment building) and would take longer to implement because of the extent of the
bench and pilot-scale testing required. The in situ treatment alternative could be implemented in
53
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a shorter amount of time but would take longer to achieve the final cleanup objectives. There
would be a minimal above ground component.
The "Buildings" and "Miscellaneous Items" alternatives would require demolition and would
likely cause minor local disruption due to the operation of demolition equipment. Each of these
would slightly increase the risk of inhalation of contaminated dust during the demolition.
Implementability:
Implementablility addresses the technical and administrative feasibility of a remedy from design
through construction and operation. Factors such as availability of services and materials,
administrative feasibility, and coordination with other governmental entities are also considered.
In the "Soils and Waste" operable unit, there are few physical and administrative difficulties that
would delay implementation of the landfarm, LTTD, or off-site removal alternatives. Both the
landfarm and LTTD alternatives have longer planning and construction elements associated with
them while the off-site removal can be implemented in fairly short order.
Among the NAPL alternatives, the hot water and steam flushing alternative is most easily
implemented as it is a proven technology having been used successfully at other wood-treater
sites. The surfactant flushing alternative is more problematic with extensive bench and pilot
scale studies being necessary to properly develop the treatment system.
The enhanced in situ biological treatment alternative is easier to implement than the ex situ
biological treatment. With the ex situ treatment, there is a need for extensive bench and pilot
scale testing before treatment could be done. In addition, it is more demanding from an
equipment standpoint than in situ treatment. Treated water would also need to be addressed in an
ex situ treatment process. The buildings and miscellaneous items demolition could be easily
carried out with equipment readily available.
Cost:
The costs for the various alternatives are given along with the descriptions of each individual
alternative. There are considerable differences in the prices for the alternatives within each
operable unit. Note that some of the alternatives may have a relatively large capital (initial) cost
but a small yearly operating cost; or an alternative may have a small capital cost but a relatively
large operating cost. The most effective way of evaluating these costs is to use the alternatives'
"present worth."
State Acceptance:
The State of Illinois Environmental Protection Agency and the United States Environmental
Protection Agency concur with the selected remedy.
Community Acceptance:
The surrounding community accepts the remedy selected. The reaction to the remedy is further
described in the Responsiveness Summary at the end of this Record of Decision.
54
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Operable Unit 1; Soils and Waste (S&W)
Evaluation Criteria
Overall protection of human
health and environment
Compliance with ARAR's
Long-term effectiveness and
permanence
Reduction of toxicity,
mobility, or volume through
treatment
Short-term effectiveness
Im piemen tability
Cost (Present Worth)
State Acceptance
Community Acceptance
' ' ',»,; ; ;, .. >;*<;.
; > * ' ,'f-ya .'i^'M
.', ' ' ,,>,* '.*- **4?;
' -.' ,',,, %v Sr-Stl'.
Other:
Annual Operating Cost
Time to Implement
Alternative
S&W1
O
It
O
O
$2,060,000
*
!?*» *t!r4"jjfw r ₯&ss
t1*>r!*Nfe&£&,'i
$32,000
12 months.
Alternative
S&W 2
$3,540,000
*^"'^ -"' - *'\',\ '
W&. c'"'- "*- ^':''
$407,000
6 years
Alternative
S&W 3
$15,680,000
,/ ,' \«?°;#''>?~
-------
Operable Unit 2: Non-Aqueous-Phase Liquids (NAPL)
Evaluation Criteria
Overall protection of human
health and environment
Compliance with ARAR's
Long-term effectiveness and
permanence
Reduction of toxicity,
mobility, or volume through
treatment
Short-term effectiveness
Implementability
Cost (Present Worth)
State Acceptance
Community Acceptance
"~ ;' ^s^J^^^t^&^i
* A ^^'^ft^'^^i^i
Other:
Annual Operating Cost
Time to Implement
Alternative
NAPL1
$3,570,000
t ^t* W'T -?""*"'-,' ', 4
x:'v.-^' f"'^\ f,t" ><'«^'; '*.
$597,000
4 years
Alternative
NAPL 2
O
$3,930,000
^s ^ .. % ff f
* t-U S * * ' ff , ' '
;-;K'*;>''< ;,* *
$666,000
4 years
** Community Acceptance of the recommended alternative will be evaluated after the
public comment period.
Fully meets criteria
O Partially meets criteria
X Does not meet criteria
56
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Operable Unit 3: Groundwater (GW)
Evaluation Criteria
Overall protection of human
health and environment
Compliance with ARAR's
Long-term effectiveness and
permanence
Reduction of toxicity,
mobility, or volume through
treatment
Short-term effectiveness
Implementability
Cost (Present Worth)
State Acceptance
Community Acceptance
>* '" '' '&"' * >f. ' ff,^"f*'' **«.*'' 'i
i .- " ' * ' V~< 5'
Other:
Annual Operating Cost
Time to Implement
Alternative GW
1
X
X
X
X
X
$1,810,000
X
«
'$&&?**,%$£<$& 'j-\.
s f "*'.,. 4+ ?"''. >"}% '
J f ff f \ -.A J
$118,000
100 years
Alternative GW 2
$2,660,000
;" ,t.,,\'>* *
$150,000 (Years 1-3)
$186,000 (Years 4-20)
20 years
Alternative GW
3
$3,080,000
\x ",,;/
ft* vJ
$239,000
10 years
**
o
X
Community Acceptance of the recommended alternative will be evaluated after the
public comment period.
Fully meets criteria
Partially meets criteria
Does not meet criteria
57
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Operable Unit 4: Buildings (B)
Evaluation Criteria
Overall protection of human
health and environment
Compliance with ARAR's
Long-term effectiveness and
permanence
Reduction of toxicity,
mobility, or volume through
treatment
Short-term effectiveness
Implementability
Cost (Present Worth)
State Acceptance
Community Acceptance
< v ^£LZ'^/^n$&&$.
'L.:J ^.i £r".> ^.^m'Ml^:^.^
Other:
Annual Operating Cost
Time to Implement
Alternative B 1
$368,000
''^{gM^j ^'rx,,'"^!
s^i'LVj*^;^
N/A
1 year
o
X
Community Acceptance of the recommended alternative will be evaluated after the
public comment period.
Fully meets criteria
Partially meets criteria
Does not meet criteria.
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Operable Unit 5: Miscellaneous Items (MI)
Evaluation Criteria
Overall protection of human
health and environment
Compliance with ARAR's
Long-term effectiveness and
permanence
Reduction of toxicity,
mobility, or volume through
treatment
Short-term effectiveness
Implementability
Cost (Present Worth)
State Acceptance
Community Acceptance
£V -' >',; ,tf-' ,c ,, ' ,,>~,s s ^
! ' '- "- ' ]]"""\'"< *£&'*'>'%
Other:
Annual Operating Cost
Time to Implement
Alternative MI 1
$275,000
" fy^ ,v '"' -X,
'jvi>«4V » %
N/A
1 year
**
o
X
Community Acceptance of the recommended alternative will be evaluated after the public
comment period.
Fully meets criteria
Partially meets criteria
Does not meet criteria
PRINCIPAL THREAT WASTES
The NCP establishes an expectation that USEPA will use treatment to address the principal threats posed
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by a site wherever practicable (NCP Section 300.43 0(a)(l)(iii)(A)). Identifying principal threat wastes
combines concepts of both hazard and risk. In general, principal threat wastes are those source materials
considered to be highly toxic or highly mobile which generally cannot be contained in a reliable manner or
would present a significant risk to human health or the environment should exposure occur. Conversely,
non-principal threat wastes are those source materials that generally can be reliably contained and that
would present only a low risk in the event of exposure. The manner in which principal threats are
addressed generally will determine whether the statutory preference for treatment as a principal element is
satisfied.
Wastes that generally will be considered to constitute principal threats include, but are not limited to, the
following:
Liquid source material - waste contained in drums, lagoons or tanks, free product in the
subsurface (i.e., NAPLs) containing contaminants of concern (generally excluding groundwater).
Mobile source material - surface soil or subsurface soil containing high concentrations of
chemicals of concern that are (or potentially are) mobile due to wind entrainment, volatilization
(e.g., VOCs), surface runoff, or subsurface transport.
Highly-toxic source material - buried drummed non-liquid wastes, buried tanks containing non-
liquid wastes, or soils containing significant concentrations of highly toxic materials.
Wastes that generally will not constitute principal threats include, but are not limited to, the following:
Non-mobile contaminated source material of low to moderate toxicity - surface soil containing
chemicals of concern that generally are relatively immoblile in air or ground water (i.e., non-liquid,
low volatility, low leachability contaminants such as high molecular weight compounds) in the
specific environmental setting.
Low toxicity source material - soil and subsurface soil concentrations not greatly above reference
dose levels or that present an excess cancer risk near the acceptable risk range were exposure to
occur.
The major factors controlling the estimated risks for the Jennison-Wright site are:
The presence of dioxins/furans and carcinogenic PAHs in site soils and potential exposures to
current site visitors and future site workers;
The presence of PCP in groundwater in the PCP process area, and the presence of carcinogenic
PAHs, benzene, PCP, arsenic, 2,4-dimethylphenol, 2-methylphenol, and naphthalene in
groundwater at the 22nd Street lagoon, coupled with the possible future use of groundwater as a
drinking water source; and
The presence of benzene and naphthalene in subsurface soils and the potential future short-term
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inhalation exposures of workers and nearby residents during periods of excavation/construction on
the site.
SELECTED REMEDY
For site wastes consisting of the drip track residue and the oils found on-site, the selected
alternative is to remove the waste and have it disposed at a hazardous waste facility. An estimated
3DO cubic yards of soil will be excavated and removed from the site.
For site soils, a landfarm will be constructed in the northeast portion of the site (Alternative S&W
2). A landfarm is selected over a soil cover because it is more protective of human health and the
environment and over the other alternatives because of cost considerations. An estimated 55,000
cubic yards of soil will be treated over a five year period.
For NAPLs removal, hot water and steam flushing (Alternative NAPLs 1) is selected over
surfactant flushing because it is a more proven technology. An estimated 200,000 gallons of
NAPLs will be removed and treated.
For the more highly contaminated groundwater plumes, the selected alternative is enhanced in situ
biological treatment using ORC and air sparging (Alternative GW 2) rather than natural
attenuation and ex situ biological treatment. Natural attenuation is not considered an aggressive
enough approach and ex situ biological treatment involves a greater level of design, construction,
and annual operating cost than in situ biological treatment. Natural attenuation (Alternative GW
1) is the selected alternative for the other areas of the site where the groundwater contamination is
at a much lower level.
The buildings and other structures on the site will be razed and the asbestos-containing materials
inside will be abated. (Alternative B 1) An estimated 180 liner feet of pipe insulation and 7000
square feet of surface insulation will be abated and 1800 cubic yards of foundations will be
removed.
The selected alternative for the "Miscellaneous Items" category is to remove the remaining
miscellaneous items (debris piles, storage tanks, abandoned steel trams and several sumps and pits)
that litter the site. (Alternative MI 1)
Cost Estimate
The information in the following cost estimate summary table is based on the best available information
regarding the anticipated scope of the remedial alternative. Changes in the cost elements are likely to
occur as a result of new information and data collected during the engineering design of the remedial
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alternative. Major changes may be documented in the form of a memorandum in the Administrative
Record file, an Explanation of Significant Differences, or a ROD amendment. This is an order-of-
magnitude engineering cost estimate that is expected to be within +50 to -30 percent of the actual project
cost.
- « ; , C V * - " -" ! ^
' ' ' 5 - '"< " y V '>' "<
Alternative
Common Items
Removal and Disposal of Hazardous Wastes
Landfarm (S&W 2)
Hot Water and Steam Flushing (NAPL 1)
Enhanced In Situ Bioremediation (GW 2)
Building Abatement and Demolition
Removal of Miscellaneous Items
Total Cost
;Q$tl8tI!i&
Capital Costs
$ 577,000.00
$ 400,000.00
S 1,481,000.00
$ 1,309,000.00
$ 349,000.00
$ 219,000.00
$ 145,000.00
S 4,480,000.00
iTIF
kl-ICf
Present Worth
PRSC* Costs
N/A
N/A
$ 1,762,000.00
$ 2,117,000.00
$ 2,151,000.00
N/A
N/A
$ 6,030,000.00
i
Estimated Total
Present Worth
Cost
$ 577,000.00
$ 400,000.00
$ 3,243,000.00
$ 3,426,000.00
$ 2,500,000.00
$ 219,000.00
$ 145,000.00
S 10,510,000.00
* Post Remedial Site Control
An annual discount rate of 5% was assumed for calculating present worth cost.
EXPECTED OUTCOME FOR SELECTED REMEDY
It is expected that exposure to site contaminants will be controlled by:
Treatment on-site of contaminated soils;
Removal of RCRA listed hazardous wastes;
Debris, and miscellaneous items;
Removal and treatment of NAPLs; and
Treatment of groundwater.
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Through this approach, it is anticipated that this site will be returned to a usable state for redevelopment as
a commercial/industrial facility. The anticipated duration of each portion of the selected remedy reflects
preliminary estimates of construction time and is shown in the alternatives portion of this Record of
Decision.
STATUTORY DETERMINATIONS
Under CERCLA section 121 and the NCP, the lead agency must select remedies that are protective of
human health and the environment, attain Federal and State requirements that are applicable or relevant
and appropriate for this remedial action (or invoke an appropriate waiver), are cost-effective, and utilize
permanent solutions and alternative treatment technologies (or resource recovery) to the maximum extent
practicable. In addition, CERCLA includes a preference for remedies that employ treatment that
permanently and significantly reduces the volume, toxicity, or mobility of hazardous wastes as a principal
element and a bias against off-site disposal of untreated wastes.
Protection of Human Health and the Environment
The selected array of alternatives will protect human health and the environment through the treatment of '
on-site soils and groundwater, removal of RCRA listed hazardous wastes, debris, and miscellaneous
items, and treatment of the NAPLs on site. By treating the NAPLs and soils, sources of contamination,
this remedy will prevent the existing groundwater plumes from migrating further and return the water to
drinking water standards. Soil treatment will reduce the current cancer risks associated with the soils to
10~5 level which is within USEPA's target range of 10'" to 10"6. Groundwater will be treated to a risk level
oflO'6.
Compliance with Applicable or Relevant and Appropriate Requirements
The selected remedy of landfarming the contaminated soils, removal of RCRA listed wastes, collection
and treatment of NAPLs, air sparging and biotreatment of groundwater, and demolition and removal of
site buildings and miscellaneous items comply with all ARARs. The ARARs identified are presented
below.
Part 620Groundwater Quality. Title 35 of the Illinois Administrative Code (IAC), Part 620,
entitled Groundwater Quality, prescribes various aspects of groundwater quality in Illinois. Part
620 includes methods of classifying groundwater (Class I through Class IV), nondegradation
provisions, standards for the quality of groundwater, and procedures and protocols for the
management and protection of groundwater. A groundwater management zone (GMZ) may be
established within any class of groundwater as a three-dimensional region containing groundwater
being managed to mitigate impairment caused by the release of contaminants from a site.
Safe Drinking Water Act. The SDWA of 1974 establishes a federal program to monitor and
increase the safety of all commercially and publicly supplied drinking water supplies. Congress
amended the SDWA in 1986, mandating changes in nationwide safeguards for drinking water and
establishing new federal enforcement responsibility on the part of EPA. The 1986 amendments
required EPA to establish MCLs, Maximum Contaminant Level Goals (MCLGs), and Best
Available Technology (BAT) treatment techniques for organic, inorganic, radioactive, and
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microbial contaminants in drinking water.
Resource Conservation and Recovery Act (RCRA). RCRA was enacted in 1976 as an
amendment to the Solid Waste Disposal Act to ensure the proper management of solid wastes. The
broad goals set by RCRA are:
To protect human health and the environment from the hazards posed by waste disposal;
To conserve energy and natural resources through waste recycling and recovery-;
To reduce or eliminate the amount of waste generated, including hazardous waste, as
expeditiously as possible; and
To ensure that wastes are managed in a manner that is protective of human health and the
environment.
RCRA consists of three distinct yet interrelated programs in order to achieve these goals. RCRA
Subtitle C, the hazardous waste program, establishes a management system that regulates
hazardous waste from the time it is generated until its ultimate disposal. The system establishes
requirements for hazardous waste identification; generators; transporters; treatment, storage, and
disposal (TSD) facilities; hazardous waste recycling; land disposal restrictions; combustion;
permitting; corrective action; enforcement; and state authorization. IEPA has determined that
approximately 300 cubic yards of soil directly underneath the drip tracks contains waste materials
from the wood-treating operations at the Jennison-Wright site and will be considered an F-Iisted
hazardous waste (F032 and F034). The management of this material (removal and off-site
incineration at an appropriately permitted facility) will be conducted in accordance with RCRA
Subtitle C.
Groundwater Reinjcction. Several of the removal action alternatives include the reinjection of extracted
groundwater into the subsurface. In Illinois, EPA Region 5 classifies and regulates injection wells. EPA's
UIC branch has five classes of injection wells. An injection well that is part of a groundwater treatment
system would be a Class I injection well. EPA has delegated primary regulatory authority of the UIC
program to the State of Illinois because Illinois has demonstrated the ability to implement a UIC program
that meets the EPA requirements found in 40 CFR Part 145. If the design document prepared for the
removal action at the Jennison-Wright site includes groundwater reinjection, approval from lEPA's UIC
division would need to be obtained.
Demolition. Prior to the demolition of the on-site buildings, razing permits will need to be obtained from
the Granite City building inspector's office. One permit would be required for each of the structures to be
demolished.
Asbestos. Per 40 CFR Part 61 (the National Emission Standard for Asbestos), the owner of a structure
planned for demolition must thoroughly inspect the structure for the presence of ACM. This inspection
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was conducted by E & E as part of the EE/GA support sampling. ACM is categorized into three
categories:
Category I nonfriable
Category II nonfriable
Friable
The asbestos standard for demolition in presented in 40 CFR Part 61.145. The standard consists of:
(a) Applicability, (b) Notification requirements, and (c) Procedures for asbestos emission control. Based
upon the amount of RACM present in a demolition project, paragraph (a) differentiates between those
projects that must comply with both paragraphs (b) and (c), and those projects that need only comply with
certain notification requirements in paragraph (b).
RACM is defined as:
Friable ACM;
Category I nonfriable ACM that has become friable, or that will be or has been subjected to
sanding, grinding, cutting, or abrading; and
Category II nonfriable ACM that has a high probability of becoming or has become crumbled,
pulverized, or reduced to powder by the forces expected to act on the material in the.course of
demolition.
An owner of a demolition project must comply with both paragraphs (b) and (c) if the combined amount of
RACM is at least 260 linear feet on pipes or at least 160 square feet on other structural components. An
owner of a demolition project must comply only with certain notification requirements of paragraph (b) if
the combined amount of RACM is less than 260 linear feet on pipes and less than 160 square feet on other
structural components.
For the Jennison-Wright site, there are less than 260 linear feet of RACM on pipes, but there are more than
160 square feet of RACM on other structural components. Therefore, the demolition of the site buildings
would need to comply with both paragraphs (b) and (c).
Other Criteria, Advisories, or Guidance To Be Considered (TBCs)
In implementing the selected remedy, IEPA has considered an additional non-binding criterion that is
considered to be a TBC.
TACO. Title 35 IAC, Part 742, entitled Tiered Approach to Corrective Action Objectives ( TACO), is the
lEPA's method for developing remediation objectives (hereafter referred to as CUOs) for contaminated
soil and groundwater in Illinois. These CUOs protect human health and take into account site conditions
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and land use. CUOs generated by TACO are risk-based and site-specific (IPCB 1997). TACO is
considered a TBC requirement rather than an ARAR. According to IEPA, TACO cannot be an ARAR on
Superfund sites since it is not legally enforceable. TACO, however, can be used as a screening tool, and
Tier 1 cleanup values could be used as proposed cleanup goals for soil or water as part of a risk
assessment. There are three tiers of CUOs in TACO.
A Tier 1 evaluation compares the concentration of contaminants detected at a site to the corresponding
CUOs contained in "look-up" tables. These CUOs are based on simple, conservative models. To
complete a Tier 1 evaluation, the following must be known:
The extent and concentrations of contaminants of concern for both soil and groundwater;
The groundwater classification as defined in 35 IAC Part 620; and
The intended land use at the site (either residential or industrial/commercial).
If CUOs are based on an industrial/commercial land use, then an institutional control prohibiting the
property from residential use would be imposed by IEPA (IEPA 1997).
A Tier 2 evaluation uses risk-based equations from Soil Screening Level (SSL) and Risk-Based Corrective
Action (RBCA) approaches. In addition to the information that is required for a Tier 1 evaluation, the
following information is considered:
The physical and chemical properties of the contaminants;
Site-specific soil and groundwater parameters (e.g., soil type, soil organic carbon content, hydraulic
conductivity); and
The application of institutional controls and engineered barriers.
The additional Tier 2 information can allow far the calculation of less stringent but equivalently protective
CUOs as Tier 1.
A Tier 3 evaluation allows alternative parameters and factors, not available under a Tier 1 evaluation or a
Tier 2 evaluation, to be considered when developing CUOs. Situations that can be considered for a Tier 3
evaluation include, but are not limited to:
Modification of the input parameters used in risk assessment models not allowed under Tier 2;
Use of different risk assessment models from those used in Tier 2;
Use of additional site data to improve or confirm predictions of exposed receptors;
Analysis of site-specific risks using formal risk assessment, probabilistic data analysis, and
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sophisticated fate and transport models;
The impracticality of further remediation;
Incomplete human exposure pathway(s) not excluded under 35 IAC Part 742, Subpart C;
Use of toxicological-specific information not available from the sources listed in Tier 2; and
Land uses that are substantially different from the assumed residential or industrial/commercial
. property uses of a site.
The SRE performed for the Jennison-Wright site is the equivalent of a TACO Tier 3 evaluation.
Cost-Effectiveness
In the judgement of Illinois EPA, the selected remedy is cost-effective and represents a reasonable value
for the money to be spent. In making this determination, the following definition was used: "A remedy
shall be cost effective if its costs are proportional to its overall effectiveness."(NCP
Section3 00.43 0(f)(l)(ii)(D)). This was accomplished by evaluation the "overall effectiveness" of those
alternatives that satisfied the threshold criteria (i.e., were both protective of human health and the
environment and ARAR-compliant). Overall effectiveness was evaluated by assessing three of the five
balancing criteria in combination (long-term effectiveness and permanence; reduction in toxicity,
mobility, and volume through treatment; and short-term effectiveness). Overall effectiveness was then
compared to costs to determine cost-effectiveness. The relationship of the overall effectiveness of this
remedial alternative was determined to be proportional to its costs and hence this alternative represents a
reasonable value for the money to be spent.
The estimated present worth cost of the selected remedy is $10,510,000.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery
Technologies) to the Maximum Extent Practicable
Illinois EPA has determined that the selected remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a practicable manner at the site. Of those
alternatives that are protective of human health and the environment and comply with ARARs, Illinois
EPA has determined that the selected remedy provides the best balance of trade-offs in terms of the five
balancing criteria, while also considering the statutory preference for treatment as a principal element and
bias against off-site treatment and disposal and considering community acceptance.
The Selected Remedy treats the source materials constituting principal threats at the site, achieving
significant reductions in PNA and PCP concentrations in the soils and groundwater. The selected remedy
satisfies other criteria for long-term effectiveness by permanently destroying the PNA and PCP
contamination in the soil and groundwater. The selected remedy does not present short-term risks
different from the other treatment alternatives. There are no special implementability issues that sets the
selected remedy apart from any of the other alternatives evaluated.
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Preference for Treatment as a Principal Element
By treating the contaminated soils and groundwater using biological treatment methods, the selected
remedy addresses principal threats posed by the site through the use of treatment technologies. By
utilizing treatment as a significant portion of the remedy, the statutory preference for remedies that employ
treatment as a principal element is satisfied.
Five-Hear Review Requirements
Because this remedy will result in hazardous substances, pollutants, or contaminants remaining on-site
above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted
within five years after initiation of remedial action to ensure that the remedy is, or will be protective of
human health and the environment.
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JENNISON-WRIGHT CORPORATION SITE
GRANITE CITY, MADISON COUNTY, ILLINOIS
FINAL REMEDY
RESPONSIVENESS SUMMARY
September 1999
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Table of Contents
Page
Responsiveness Summary Overview 3
Site Location and History 3
Site Contamination 4
Summary of the Final Remedy 5
Public Hearing 6
Agency Responses to Questions 7
Comments From Public Hearing 13
For Further Information 14
Thanks to the Citizens Who Became Involved 14
Glossary 15
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RESPONSIVENESS SUMMARY
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
July 30, 1999, through August 29, 1999, to allow interested parties to comment on
the Proposed Plan (July 1999) for this site. The Proposed Plan identifies the
cleanup alternatives and preferred option for the final remedy at the
Jennison-Wright Corporation Superfund Site in Granite City, Illinois. The Proposed
Plan was issued by the Illinois Environmental Protection Agency, the lead agency
for site activities, and the United States Environmental Protection Agency (USEPA),
the support agency for this remedial action. Illinois EPA, in consultation with the
USEPA, has selected a final remedy for the site only now that the public comment
period has ended and written and oral comments have been submitted.
The purpose of this responsiveness summary is to document the Agency's
responses to questions, concerns, and comments received during the comment
period and during the public hearing. These comments and concerns were
considered prior to selection of the alternatives for the site. A complete copy of the
Proposed Plan, Administrative Record, Engineering Evaluation/Cost Analysis
(EE/CA) and other pertinent information are available at the Granite City Public
Library, 2061 Delmar Avenue, Granite City, Illinois (618/452-6238).
II Site Location and History
The Jennison-Wright Corporation site is made up of approximately 20 acres of land
at 900 West 22nd Street within the corporate boundaries of Granite City, Madison
County, Illinois. The facility is bordered by the Norfolk-Southern Railroad lines to
the east and south, residential areas to the west and property occupied by the
Illinois American Water Company, a residential area and 23rd Street to the north.
Operations at the facility began prior to 1921 and continued unti!1989 with three
separate companies operating at the site: Midland Creosoting Company (prior to
1921-1940), The Jennison-Wright Corporation (1940-1981) and 2-B-J.W., Inc
(1981 -1989), authorized to do business as Jennison-Wright Corporation. Jennison-
Wright Corporation filed for Chapter 11 Bankruptcy in November 1989, with an
auction held in 1990 to sell the remaining equipment and materials. The site has
remained vacant since 1990 except for the occasional trespasser or scavenger.
The Jennison-Wright Corporation site is a triangular-shaped facility that is bisected
3
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by 22nd Street, creating a north and south portion. The area north of 22nd Street,
treating wood products (railroad ties and wood block flooring) with
pentachlorophenol (PCP), creosote and zinc naphthenate. Creosote was used for
treating wood products prior to 1921 to 1989. Pentachlorophenol was used from
1974 to 1985 and zinc naphthenate was used from 1985 to 1989.
Jennite (an asphalt sealer product composed of coal tar, pitch, clay, and water) was
manufactured in the southeastern corner of the facility. The process began in the
early 1960s and continued until the summer of 1986 when Jennison-Wright sold the
Jennite process to Neyra Industries. Neyra Industries leased the portion of the
facility used by Jennison-Wright for the sealer, and continued manufacturing the
asphalt sealer until Jennison-Wright Corporation filed for Chapter 11 Bankruptcy
in November 1989.
Site Contamination
While in operation, creosote and pentachlorophenol were allowed to spill onto the
ground during the wood-treating process located south of 22nd Street. Soil
contamination also resulted from creosote dripping from treated ties and blocks
during transportation to wood storage areas located north of 22nd Street.
When the site was abandoned in 1989, large quantities of materials and hazardous
waste, including above-ground storage tanks and railroad tank cars, were left on
site. Years of wood-treating operations have also led to groundwater
contamination. Preliminary residential soil sampling also has shown low levels of
the same contaminants found on site.
Various stabilization efforts and removal projects have previously occurred at the
Jennison-Wright site. However additional work still must be completed to address
the remaining soil and groundwater contamination. The problems at the Jennison-
Wright site are complex. As a result, Illinois EPA has divided the work into different
manageable components called Operable Units (OUs). These are:
OU 1 Soils and Wastes: addresses the soils that have been contaminated
by past site operations and the wastes that those operations left in place
when the site went bankrupt.
OU 2 Non-Aqueous Phase Liquids (NAPLs): addresses the presence of
NAPLs, which have been found in the northeast corner of the south section
of the site.
OU 3 Groundwater: addresses the contaminated groundwater which is
located throughout the site.
OU 4 Buildings: addresses the variety of different structures and their
remnants which remain on-site. There are five buildings and two silos on-
site.
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OU S Miscellaneous Items: addresses the remaining miscellaneous items
that consist of two underground storage tanks, two above ground storage
tanks, an oil water separator, liquids and sediments in an on-site basin, the
collapsed pole barn, several sumps and pits, scattered debris piles, and
steel tram rails.
Summary of the Final Remedy
For site wastes consisting of the drip track residue and the oils found on-
site, the preferred alternative is to remove the waste and have it disposed at
a hazardous waste facility.
For site soils, a landfarm will be constructed in the northeast portion of the
site.
For NAPL removal, hot water and steam flushing will be used because it is
a proven technology.
For the more highly contaminated groundwater plumes, the preferred
alternative is enhanced in situ biological treatment using Oxygen Released
Compounds and air sparging.
The buildings and other structures on the site will be razed and the
asbestos-containing materials inside will be abated.
The preferred alternative for the "Miscellaneous Items" category is to
remove the remaining miscellaneous items (debris piles, storage tanks,
abandoned steel trams and several sumps and pits) that litter the site.
Based on information available at this time, Illinois EPA and USEPA believe that this
alternative will be protective of human health and the environment, will comply with
applicable regulations, be cost effective, and will utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. The decision to implement this final remedy was
made after written and oral comments were received during the public comment
period.
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Public Hearing
Illinois EPA solicited input from the community on the cleanup methods and
proposed final remedy. Prior to the final remedy, the Illinois EPA was required to
hold a minimum 30-day comment period to encourage public participation in the
selection process. The comment period began on July 30, 1999, and ended on
August 29,1999. During this time a public hearing was held by the Illinois EPA at
which the Remedial Investigation report and the Proposed Plan was presented,
questions were answered, and both oral and written comments were accepted.
A notice of the public hearing was published in the Granite City Journal on July 18
and 25, and August 1, 1999. Letters and a notice of the hearing were sent to
legislators, elected officials, and interested citizens on July 19, 1999. The notice
was also placed on the Illinois EPA's web site home page.
The public hearing was held at the Granite City Township Hall, 2060 Delmar
Avenue, on August 19, 1999, at 7:00 pm. Approximately 13 citizens and two local
officials attended; representatives from the Illinois EPA and Ecology & Environment,
Inc. (Illinois EPA contractors) were present. One newspaper reporter, representing
Belleville News Democrat, was also present.
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Res po rises
Questions from Jennison-Wright Public Hearing
Remediation Issues
General Questions
When will the remediation work begin?
The Illinois EPA is currently waiting for the USEPA to provide us funding for this project.
We are anticipating the money for the design portion of the final remedy by January 2000.
The remedy will be designed over the winter months. If all goes well, the USEPA wilt
provide us the $10.5 to implement the design and work should begin late Spring of 2000.
Will debris be hauled from this site to another site to be disposed of?
Liquid waste will be transported and disposed of at a hazardous waste incinerator in New
Castle, Kentucky. Scrap metals will decontaminated on-site and will taken to a smelter.
Contaminated soils will be treated, and a landfarm will be constructed on-site.
How will waste be transported off the site railway or roadway?
Waste will be hauled off-site via trucks with liners; these trucks haul 20 cubic yards in a load.
Will the remediation project include the property between the railroad tracks and the Nestle
factory?
Some. Groundwater flowing in the area of the railroad tracks and some soil in the area will
be excavated.
Will the remediation project include the residential properties located nearby, specifically
along Missouri Avenue?
It is not Illinois EPA's intention to excavate any residential soils. Past investigations
indicated that residential soils are at a low enough risk to be below a level of concern for the
residents along Missouri Avenue, the closest street to the site. This conclusion was drawn
through health risk consultations with Illinois Department of Public Health, United States
Protection Agency, and Illinois Environmental Protection Agency.
Will the processing facility in the northern part of the property be remediated as well?
Yes. Areas for soil and groundwater treatment have been already determined; this
designated area should include the portion of the site which the Agency was questioned
about.
How do you ensure your contractors do the remediation properly?
Ecology and Environment, Inc., the Illinois EPA's oversite contractor, will be there when
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contractors are performing the work.
What is involved in cleaning up this site?
For site wastes consisting of the drip track residue and the oils found on-site, the preferred
alternative is to remove the waste and have it disposed at a hazardous waste facility.
For site soils, a landfarm will be constructed in the northeast portion of the site. A landfarm
is preferred over a soil cover because it is more protective of human health and the
environment and over the other alternatives because of cost considerations.
ForNAPL removal, hot water and steam flushing is preferred over surfactant flushing because
it is a more proven technology.
For the more highly contaminated groundwater plumes, the preferred alternative is enhanced
in situ biological treatment using Oxygen Released Compounds and air sparging rather than
natural attenuation and ex situ biological treatment.
The buildings and other structures on the site will be razed and the asbestos containing
materials inside will be abated.
The preferred alternative for the "Miscellaneous Items" category is to remove the remaining
miscellaneous items (debris piles, storage tanks, abandoned steel trams and several sumps
and pits) that litter the site.
Soil Remediation Questions
What is the soil cleanup process?
Soils which are contaminated above the Cleanup Objectives (CUOs) will be treated in an on-
site landfarm treatment cell constructed on the northeastern portion of the site. Landfarming
is an USEPA-recommended technology for treating contaminated soils found a wood-treater
sites. In this landfarming cell, biodegradable contaminants are subjected simultaneously to
the following processes: 1) bacterial and chemical decomposition, 2) leaching of water-soluble
components, and 3) volatilization of some components of the original waste, as well as certain
decomposition products. Only soils would be treated via this alternative. The landfarm
treatment cell would consist of a compacted day liner, drainage system, retention pond, water
treatment and discharge system, moisture and nutrient addition equipment, and tilling
equipment. Once the soil within the cell is remediated to the CUOs, the soil would be graded
to final contours across the site.
Once you mobilize the contaminants in the soil, how can you control their migration?
"Mobilizing" contaminants in the soil is not part of the remediation. In addition, the
contaminants in the soil are not readily mobile and do not tend to migrate easily. Controls
used with the selected soil treatment which is being utilized ensures the contaminants do not
migrate into the residential areas or move off-site.
Will digging and hauling soil leave large amounts of contaminated soils exposed and able to
migrate off-site?
No. Dust suppression and runoff control measures will be maintained during all phases of the
processes at the site.
-------
What is used as the vegetative cover?
The type of vegetative cover has not yet been determined. It will be some form of hydro-
seeding that will have good erosion control properties. It will not be sod.
Are you going to remove the soil on the north side of 22nd street?
We will remove and treat soil from the north portion of the site which is north of 22nd Street.
Will excavation of soil occur outside of the fence?
Some so/7 removal will occur outside of the fence. However, sampling indicates that there
wasn't much drippage outside of the fenced area.
Is the soil contamination any farther down than 12 inches?
For the most part, contamination does not go any deeper than 12 inches. However, there
are certain areas - like the Jennite pit (waste pit) - that contamination goes deeper. The
on-site area known as the "22nd Street lagoon" will undoubtedly have contaminated soil
deeper than 12 inches. All of this soil will be removed, landfarmed and treated until the
cleanup levels are reached.
NAPL Questions
Could the hot water and steam treatment cause contaminants to move off-site to residential
yards or private wells, specifically on Missouri Avenue?
No. The purpose of this action is to prevent such an occurrence. Wells will be specifically
installed for the purpose of collecting contaminants that are mobilized during the process.
Additionally, all of this action takes place well below ground surface and a considerable
distance from Missouri Avenue. This procedure will be conducted in the northeast comer
of the southern portion of the site.
This process uses hot water and steam to displace and carry NAPLs to a point where they
can be collected. In this process, injection and extraction wells are installed in an area
contaminated with NAPLs. Steam is injected below the NAPLs and condenses, causing
rising hot water to displace the NAPLs to the extraction wells. Hot water is also added to
the subsurface above the steam to further displace the NAPLs. The collected groundwater
and NAPL are then put through an oil/water separator. The NAPL is then removed from the
site and disposed of in an off-site facility.
What is done with the site once the clean up is complete.
It will be open for purchase by a prospective buyer for a commercial/industrial use.
What is done with cleaned up dirt?
-------
Erosion control is provided, followed by a vegetative 'seeded cover of hydro-seed.
Some of the residential yards have just been remediated with new top soil and sod because of
another Superfund site in the area. Will this clean up process cause contamination from the
Jennison-Wright site to get into their yards and cause additional problems?
Wo. Erosion and dust control measures are required to prevent such an occurrence.
Risk Issues
Are there threats to children other than cancer coming from this site?
None of the chemicals found at this site are uniquely toxic to children. However, the
chemicals present can have effects other than cancer. For example, skin irritation is possible
from dermal contact with the creosote-related chemicals.
Could past windblown dust and rain erosion have posed a health risk to residents?
The contaminants found at this site have a tendency to bond tightly to the soil; therefore, they
move with the soil. Therefore, windblown dust from the site could contain these contaminants.
Does contamination from the site wash out to the alley or people's yards when it rains really
hard?
Hard rains can cause the soils to be washed across the alley way. The contaminants found
at this site have a tendency to bond tightly to the soil; therefore, soils washed across the
alleyway could contain these chemicals. However, the vegetation on the site has cut down
on the amount of washout.
Why is there no contamination on 22nd Street?
Contamination, if any was present, on this road probably has been carted away a little bit at
a time - via the heavy traffic.
Can animals that go on and off of the property carry contamination into residential yards?
The transfer of contaminated soil by animals traveling off and on the site is minimal and not
of substantive concern as a risk to residents.
Sampling issues
Could there be additional sampling conducted along the alleyway and the residential properties
immediately adjacent to the Jennison-Wright site? More assurances are needed that
contamination does not stop at fence line.
10
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As part of the remedial design, the Illinois EPA will conduct additional soil sampling to ensure
that the contamination plume is delineated and that we can be sure the contamination is not
located in the alleyway or residential yards.
Would the citizens be made aware of sampling conducted in the alleys between Illinois Avenue,
between Missouri Avenue, and the tie yard property?
Yes. Prior to sampling an event, local officials and affected homeowners would be made
aware of our intentions.
When was the last sampling in the residential areas, specifically on or near Missouri Street?
From July through September 1997, and in December 1997, surface and subsurface
sampling, sediment sampling, and a hydrogeologic investigation was conducted.
Groundwater sampling was conducted using a Geoprobe; new monitoring wells were
installed; and aquifer testing occurred.
This sampling was conducted in the locations indicated in the EE/CA which can be found in
the Information Repository, Granite City Public Library.
If the sample results tested "positive", how would the residents be informed about the results?
It is the responsibility of the Illinois EPA's remedial project manager and community relations
coordinator to keep the residents, local officials, and other community members informed of
on-going site activities, sampling events, milestones, etc. We often meet persons face-to-
face, make telephone calls, write letters, and publish fact sheets and newsletters to ensure
citizens are made aware of what is going on.
Can there be additional sampling conducted at the point where the ties crossed 22nd Street?
Wo. Any contamination which was there probably no longer exists because of being carried
away by vehicles. In addition, this area is now covered with asphalt.
General issues
What is meant by RCRA waste?
7?7e Resource Conservation and Recovery Act (RCRA) was enacted in 1976 to address the
huge volumes of municipal and industrial waste generated nationwide. After several
amendments, the Act as it stands today governs the management of solid and hazardous
waste and underground storage tanks.
RCRA waste is any waste that falls under the jurisdiction of the above-mentioned definition.
11
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Explain the groundwater flow and contamination.
The groundwater at this site basically goes from north to south. In the shallower aquifer, it
runs north to south until it gets to the south portion of the site then it takes a more westerly
flow and heads in the direct of the residential houses.
Contaminants in the groundwater include pentachlorophenol, polyaromatic hydrocarbons,
benzene, arsenic, 2,4-dimethylphenol, 2-methylphenol, and naphthalene.
12
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Comments from Jennison-Wright Public Hearing
Both aldermen (Ward 4) attending the public hearing expressed their specific desires to make sure the
site is properly cleaned, but they were also very pleased and grateful for the past and upcoming
remedial efforts. One alderman offered access to the same city roads to ensure the route the trucks
hauling the soil would take. A 84-year old resident who also worked for Jennison-Wright for 42 years
had much information regarding past history and operations at the facility. He also expressed his lack
of concern for health risks for past employees and nearby residents associated with this site,
nevertheless he felt that the site needed to be cleaned up and was glad that it would be 'done
sometime soon.
The most common concerns were about off-site contamination and exposure to residents. The
residents were concerned mainly about four subjects:
The major concern voiced was regarding possible contamination in the alleyway and
residential yards. It was believed that the contamination plume could be outside of the fence
line. '
Residents wanted to know why there was no contamination on 22nd Street because it was
known that ties drip-dried as they crossed the road;
A concern was that residents believed that they may be further being exposed to
contamination through overland flow and dust from the site. They wanted to know what Illinois
EPA was doing to reduce this exposure;
A concern was over how the Illinois EPA could control the mobilization of contaminants in the
soil using the steam technique. There was a fear that the mobilized contaminants could re-
contaminate their soils or yards now that they have been excavated and re-sodded due to a
cleanup of another nearby Superfund site.
The residents had two requests:
Additional residential and alleyway sampling to determine if there is any contamination in those
areas.
Precautions taken and oversite conducted by the Illinois EPA or their contractors when soil
excavation occurred.
The community relations coordinator (Michelle Tebrugge) for the Jennison-Wright site promised to
obtain the 1989 residential sampling results for a home on Missouri Avenue. The current home owner
will be sent those results in the near future. The Illinois EPA representatives also indicated that
residents and aldermen (and other local officials) will be kept informed about on-going site activities
including when the Illinois EPA has the design and construction monies from the USEPA and when
construction begins - via a some type of written update, i.e. newsletter or press release.
For Further Information
13
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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 and the Engineering Evaluation/Cost Analysis removal actions
should be directed to Fred Nika, Project Manager, 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 Illinois EPA's enforcement activities should be directed to Kyle Davis, Assistant
Counsel, Division of Legal Counsel, Bureau of Land, Illinois EPA, 1021 North Grand Avenue East, P.O.
Box 19276. Springfield, Illinois 62794-9276, or phone at 217/782-5544.
Questions about the Responsiveness Summary should be directed to Michelle Tebrugge, Community
Relations Coordinator, Illinois EPA, 1021 Norm Grand Avenue East P.O. Box 19276, Springfield, Illinois
62794-9276. or phone at 217/524-4825.
All documents used by Illinois EPA in formulating the Proposed Plan and all of the alternatives for this
site are contained in the site Administrative Record (which also contains the EE/CA) at the Granite City
Public Library, 21st and Delmar Streets, Granite City, Illinois.
Copies of the transcript of the August 19,1999, public hearing can be purchased from Jo Elaine Foster
& Associates. 618/877-7016. Copies of this responsiveness summary will be mailed in October 1999
to those who registered at the public hearing and to anyone who requested a copy.
Additional copies of this responsiveness summary are available from Michelle Tebrugge, 217/524-
4825.
Thanks to the Citizens Who Became Involved J
On behalf of Director Thomas Skinner and the Agency staff, we would like to thank all who took the
time to get involved by participating at the public hearing, and at other community meetings, and for
their questions and comments.
Signed: Signed:
Illinois EPA Project Manager Illinois EPA Hearing Officer
Signed:_
Illinois EPA Community Relations Coordinator
Dated: , 1999
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
GLOSSARY
Specialized terms and acronyms that are used in the proposed plan, this responsiveness summary,
and elsewhere and in this proposed plan are detailed below.
14
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(/IK) - a file that is maintained, and contains all information used by the lead agency to
make its decision on the selection of a response action under CERCLA. This file is to be available for public
review and a copy established at or near the site, usually at one of the Information Repositories.
ARARs (Applkable or Relevant and Appropriate Requirements) -Applicable requirements are those cleanup
standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations
promulgated under Federal or State law that specifically address a hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstance at a CERCLA site. Relevant and Appropriate requirements are
those same listed standards that while not "applicable" at the CERCLA site, address problems or situations
sufficiently similar to those encountered at the site that their use is well suited to the particular site.
Arsenic -a naturally-occurring but poisonous metallic element extensively used in insecticides and weed killers
because of its highly toxic character; also used in the manufacture of glass and in wood preservatives (sodium
arsenate).
Asbestos - a building and insulating material widely used for years because of its strength and heat-resisting
qualities; it has been found to cause a severe lung ailment, certain types of lung cancer and other respiratory
problems.
Benzene - a clear, colorless liquid used as a component of gasoline and diesel fuel. It is also used in recent years
in the production of chemical compounds and drugs and in the rubber industry. Long-term exposure of benzene
may cause damage to the blood-forming system.
CERCLA (Comprehensive Environmental Response, Compensation and Liability Act or Super/unit) - a
Federal law passed in 1980 and modified in 1986 to create a special tax that goes into a Trust Fund, commonly
known as Superjund, to investigate and take remedial action at abandoned or uncontrolled hazardous waste sites.
Clean-Up Objectives (CUOs) - remediation objectives for contaminated soil and groundwater which protect
human health and take into account site conditions and land use. These CUOs are risk-based and site specific.
Community Relations Plan (CRP) - a plan that is prepared at the start of most Superfund response activities
to direct activities that will allow the community affected by the site to be kept informed of USEPA, Illinois EPA,
and PRP activities.
Creosote - a brown to black oily liquid obtained from coal tar and used as a wood preservative in railroad ties to
extend their useful life. Adverse effects to the skin, lungs, and nervous system may be caused by long-term
exposure of creosote.
Dibenzofurans - crystalline solid derived from coal tar sometimes used as an insecticide or industrial solvent.
Dioxins - a generic term for a group of 75 related compounds known as polychlorinated dibenzo-p-dioxins. The
most toxic compound of this group is 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD). Although scientists
disagree on the long-term health effects of exposure to dioxins, they do agree exposure can cause a persistent skin
rash called chloroacne.
Engineering Evaluation/Cost Analysis (EE/CA) - performed to evaluate removal actions in terms of their
effectiveness, implementability, and cost.
Groundwater - underground water that fills pores in soils or openings in rocks to the point of saturation.
Jennite - an asphalt sealer product composed of coal tar, pitch, clay and water.
Maximum Contaminant Level (MCL) - a concentration established by the USEPA for specific chemicals in
drinking water supplies that may cause adverse health effects; these MCLs are a set of enforceable standards for
drinking water quality.
Naphthalene - a white, crystalline powder and is produced from either coal tar or petroleum. It is a major
component in diesel fuels, fuel oil, and creosote. Naphthalene can cause irritation to the respiratory tract,
15
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gastrointestinal system, or skin.
NAPL (Non-Aqueous Phase Liquid) - this is a generic term for a usuajly petroleum based substance that is found
in contaminated groundwater. It's concentration is great enough that it cannot be completely dissolved in water
and shows up in concentrated pools at locations within the groundwater.
National Priorities List (NPL) - the United States Environmental Protection Agency's list of the most serious,
uncontrolled or abandoned hazardous waste sites identified for possible long-term remedial action.
Operable Units (OU) - an action taken as one part of an overall site cleanup.
Parts per billion (ppb) - an expression describing a small concentration, equal to an amount of one substance in
billion parts of another material; for example, one drop of alcohol in 16 gallons of water.
Pentachtorophcnol (PCP) - organic compound consisting of light tan to white, needle-like crystals, primarily used
in wood preservation and pesticide. Short-term exposure causes skin, eye, or upper respiratory tract irritation;
long-term exposure effects the major organ systems - liver, kidney, nervous, and immune. PCP is tentatively
classified as a probable human carcinogen; the classification is based on inadequate human data and sufficient
evidence of cancer in animals studies.
Polynuclear aromatic hydrocarbons (PAHs) - a group of compounds that are often by-products of combustion.
PAHs are also associated with coal tar derivatives.
Proposed Plan - a public participation requirement of CERCLA in which Illinois EPA summaries for the public
the preferred cleanup strategy, rationale for the preference, alternatives presented in the detailed analysis of their
remedial investigation. This document must actively solicit public review and comment on all alternatives under
consideration,
PRP (Potentially Responsible Party) - any individuals) or company(s) potentially responsible for, or contributing
to, the contamination problems at a hazardous waste site. PRPs can include present and former site owners and
operators, as well as anyone who generated or transported the hazardous wastes found at the site. Whenever
possible, through administrative and legal actions, Illinois EPA/USEPA requires PRPs to clean up sites they have
contaminated.
Purge water - water used to flush a well when taking test samples.
Record of Decision (ROD) - a public document that explains which cleanup alternatives will be used. The ROD
is based on information and technical analysis generated during the remedial investigation and consideration of
public comments and community concerns.
Recycle - process minimizing waste generation by recovering usable products that might be otherwise become
waste.
Remedial Investigation/Feasibility Study (RI/FS) - Investigative and analytical studies usually performed at the
same lime in an interactive, iterative process, and together referred to as the RI/FS. They are intended to: gather
the data necessary to determine the type and extent of contamination at a Superfund site; establish criteria for
cleaning up the site; identify and screen cleanup alternatives for remedial action; and analyze in detail the
technology and costs of the alternatives.
Removal action - short-term immediate actions taken to address releases of hazardous substances that require
expedited response.
Resource Conservation and Recovery Act (RCRA) - a Federal law enacted in 1976 that established a regulatory
system to track hazardous substances from their generation to disposal. The law requires safe and secure
procedures to be used in treating, transporting, storing, and disposing of hazardous substances. RCRA is designed
to prevent the creation of new, uncontrolled hazardous waste sites.
Responsiveness Summary - a summary of oral and written public comments received by Illinois EPA during the
16
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comment period on key documents and the Illinois EPA's responses" to those comments. The Responsiveness
Summary is a key part of the ROD, highlighting community concerns for decision-makers.
Sludge - a generic term that describes a solid, semi-solid, or liquid waste by-product of an industrial or recycling
process.
Solvent - a liquid substance capable of dissolving or dispersing other substance (liquids or solids).
Transite - asbestos siding used in construction of some buildings.
Volatile - readily vaporizable at relatively low temperature.
Zinc naphthanate - chemical used in wood preservation.
17
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ADMINISTRATIVE RECORD INDEX
JENNISON-WRIGHT CORPORATION SITE REMOVAL ACTION
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
JULY 1,1999
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 (EEPA) has compiled the following official Administrative
Record Index for the Jennison-Wright Corporation site located in Madison County, Illinois. This index as
well as the Administrative Record itself will be updated when necessary by the EEPA. (Definitions of
abbreviations are provided.on the last page.)
Please contact Michelle Nickey-Tebrugge (P.O. Box 19276, 1021 North Grand Avenue, East, Springfield,
Illinois 62794-9276, 217/524-4825) for more information on who and where to direct questions concerning
this index.
No.
1.
2.
3.
4.
5.
6.
7.
8,
9.
10.
11.
12.
Title
Compliance Investigation Report
Preliminary Assessment
Consent Decree
Sample Results
Alternative Approach
Dioxin/Furan Assessment
Sample Results (3 volumes)
Sample Results (Groundwater)
(2 volumes)
Corr. re: Dioxin
Site Assessment Report
Memo to Stephen Davis (IEPA)
Memo to Stephen Davis (IEPA)
Corr. to Pat Petrella
(Jennison-Wright)
Issue
Date
1/18/85
1/14/86
1/15/86
2/10/88
3/14/88
3/22/88
,3/25/88
4/15/88
8/88
9/26/88
9/26/88
1 1/03/88
Author
E&E
Kenneth L. Page (IEPA)
IAGO
ffiPA
Woodward-Clyde
ARDL
Woodward-Clyde
Woodward-Clyde
Woodward-Clyde
Tom Long (IDPH)
Tom Long (IDPH)
Thomas Crause
Number
of Pages
122
8
16
27
62
542
393
1
575
4
3
2
-------
«
]NO.
13.
14.
15.
16.
17.
18.
19.
20.
21.
) 22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
Title
Meeting Minutes
Response to IEPA Comments
Sample Results
Sample Results (Inorganic)
Memo to Div. File
Sample Results
CERCLA Screening Inspection
Report (2 Volumes)
Corr. to Stephen Davis (IEPA)
Corr. to Stephen Davis (IEPA)
Corr. to Gregory Dunn (IEPA)
Corr. to Mayor Von Dee Cruse
(Granite City)
Corr. to Aid. Dan Partney
(Granite City)
Corr. to Aid. Dan Brown
(Granite City)
Fact Sheet IEPA
News Release IEPA
Memo to LPC Div. File
Corr. to Aid. Daniel Partney
(Granite City)
Corr. to Mayor Von Dee Cruse
(Granite City)
Corr. to Aid. Dan Brown
(Granite City)
Issue
Date
11/17/88
11/18/88
11/30/88
1 1/30/88
1/20/89
1/30/89
3/17/89
6/07/89
6/23/89
6/23/89
7/20/89
7/20/89
7/20/89
8/89
8/24/89
9/89
11/09/89
1 1/09/89
1 1/09/89
Author
Stephen Davis (IEPA)
Pat P. Petrella
(Jennison- Wright)
IEPA
ffiPA
Stephen Davis (IEPA)
Triangle Labs
IEPA
Tom Long (IDPH)
Michael A. Cyphert
(Thompson, Hine, &
Flory)
Curtis Ross
(USEPA-Region V)
Virginia Wood (IEPA)
Virginia Wood (IEPA)
Virginia Wood (IEPA)
IEPA
IEPA
Virginia Wood (IEPA)
Virginia Wood (IEPA)
Virginia Wood (IEPA)
Virginia Wood (IEPA)
Number
of Pages
5
31
69
47
2
1355
518
4
2
4
2
2
2
5
2
2
2
2
2
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No.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47,
48.
Title
Con. to Stephen Davis (EPA)
Corr. to Aid. Daniel Partney
(Granite City)
Seal Order
News Release
Corr. to Beth Halpern
(Congressman Jerry Costello)
Memo to Div. File
Jennison- Wright Superfund Site
Trust Agreement
Corr. to Stephen Davis (IEPA)
Corr. to Stephen Davis (JJEPA)
Expanded Site Inspection Site
Workplan
Corr. to Honorable
Sam Vadalabene
Corr. to Mr. Dan Partney
(Aid.) (Granite City)
CERCLA Expanded Site
Inspection Report
Corr. to Resident
Sample Results
Status of Jennison- Wright
Treatment Tests
Memo to Sherry Otto (ffiPA)
Issue
Date
12/14/89
7/27/90
11/08/90
11/19/90
1991
5/24/91
6/24/91
7/07/91
7/11/91
7/18/91
7/26/91
7/26/91
7/30/91
8/14/91
8/16/91
8/28/91
10/30/91
Author
Pat Petrella
(Jennison- Wright)
Virginia Wood (IEPA)
Bernard P. Killian
(EEPA)
Virginia Wood
Stephen Davis (IEPA)
Virginia Wood (IEPA)
ffiPA
Aid. Dan Partney
Sen. Sam M.
Vadalabene
Tom Crause (ffiPA)
Stephen Davis (IEPA)
Stephen Davis (IEPA)
IEPA
Virginia Wood (IEPA)
Dan Gillespie (ARDL)
COM Federal
Programs Corporation
Paul Lee (IEPA)
Number
of Pages
1
2
5
1
1
1
7
1
1
14
1
2
216
1
139
3
13
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mr
No.
49.
50.
51.
52.
53.
54.
55.
.».
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
Title
Asbestos Removal
Above Ground Storage Tank
Cleaning
News Release
Corr. to Resident
Corr. to Stephen Davis (EPA)
4 (q) Notice
Corr. To Stephen Davis (ffiPA)
Final Report by Riedel
Professional Services
Contract/Letter of Agreement Info.
Sample Results
(2 volumes)
Contract Transmittal
Corr. To Daniel J. Wilson
(Riedel)
Corr. To Dan Sewell (E&E)
Corr. To Daniel J. Wilson (Riedel)
Corr. To Stephen Davis (IEPA)
Memo to Div. File
Corr. To Alan Altur (USEPA)
Corr. To Brad Benning (USEPA)
SACM Status Report to
Dough Ballotti (USEPA)
Corr. To Rebecca Frey (USEPA)
Confidential Investigative Report 1
Issue
Date
10/31/91
3/25/92
3/25/92
5/14/92
5/15/92
5/27/92
6/22/92
6/29/92
7/07/92
7/17/92
8/03/92
9/15/92
9/20/92
11/04/92
1 1/24/92
2/03/93
2/03/93
2/03/93
2/03/93
2/15/93
Author
Riedel
IEPA
Lesley D. Morrow
(IEPA)
Daniel J. Wilson
(Riedel)
Mary A. Gade (IEPA)
Daniel J. Wilson
(Riedel)
Daniel J. Wilson
(Riedel)
Bill Child (IEPA)
TMS Analytical
Sheila File (IEPA)
Stephen Davis (IEPA)
Stephen Davis (IEPA)
Stephen Davis (ffiPA)
Kathleen Getty (E&E)
Greg Dunn (IEPA)
Gregory Dunn (IEPA)
Gregory Dunn (IEPA)
Rebecca Frey (USEPA)
Gregory Dunn (IEPA)
Orion
Number
of Pages
218
2
2
36
57
4
124
2
1127
6
1
1
1
1
4
2
2
3
2
301
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No.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
86.
87.
88.
89.
Title
Corr. to Don Insul
(Jennison-Wright Corp.)
Confidential Investigative Report 2
Paul Seebold Interview
Confidential Investigative Report 3
Corr. To Stephen Davis
Removal Scope of Work
Proposed EE/C A Workplan
Confidential Investigative Report 4
Corr. to L.E. Spencer
(All Track Equipment)
Tar Pit Characterization
Memo Re: Tarpit Investigation
Strategy Approval
Draft Time Line
Corr. to Rebecca Frey (USEPA)
Confidential Investigative Report 5
Corr. to Stephen Davis (EBP A)
EE/CA Comments
Last Will and Testament of
Carleton G. Carver
(Jennison-Wright Corp.)
Corr. to Aid. Daniel Partney
(Granite City)
4 (q) Notice
Memo re: Disposal Options to
Clarence Smith (ffiPA)
Issue
Date
3/05/93
3/18/93
5/03/93
5/03/93
5/03/93
5/03/93
6/01/93
6/03/93
6/03/93
6/07/93
6/09/93
6/21/93
7/01/93
7/06/93
7/09/93
7/14/93
8/12/93
8/23/93
9/14/93
9/17/93
9/23/93
Author
Stephen Davis (IEPA)
Orion
Orion
Orion
Carl Shepherd (Orion)
T.E. Fitzgerald (IEPA)
E&E
Orion
Leslie Morrow (IEPA)
T.E. Fitzgerald (IEPA)
Tracey Fitzgerald
(IEPA)
Jodi Traub (USEPA)
Rebecca Frey (USEPA)
Stephen Davis (IEPA)
Orion
Carol Shepard (Orion)
Rebecca Frey (USEPA)
Orion
Michelle Tebrugge
(IEPA)
IEPA
Tracey Fitzgerald
(IEPA)
Number
of Pages
1
103
28
366
3
3
15
57
3
2
2
3
2
4
98
3
3
92
2
45
1
-------
I
INC.
90.
91.
92.
93.
94.
95.
96.
97.
Title
Sample Results to Fred Nika (IEPA)
Memo re: Waste Classification
to Tracey Fitzgerald (ffiPA)
Sample Results (Tar)
to Sue Doubet
Corr. re: 4(q)
Status to Leo Konzen (Granite City)
Memo re: Removal Options
to Dan Sewell (E&E)
Decision Summary
EE/CA Final Draft
Community Relations Plan
Issue
Bate
10/7/93
10/26/93
10/26/93
11/12/93
11/16/93
12/06/93
1/18/94
2/94
Author
Janel Woodin (ESE)
Clarence Smith (IEPA)
Janel Woodin (ESE)
Stephen Davis (IEPA)
Fred Nika (IEPA)
Jodi Traub (USEPA)
E&E
IEPA
Number
of Pages
16
2
26.
2
2
3
117
19
-------
Abbreviations
IAGO - Illinois Attorney General's Office
Orion - Orion Management International
Riedel - Riedel Environmental Services, Inc.
E & E - Ecology and Environment, Inc.
IEPA - Illinois Environmental Protection Agency
USEPA - United States Environmental Protection Agency
ESE - Environmental Science and Engineering
ARDL - Applied Research and Development Laboratory
Woodward-Clyde - Woodward-Clyde Consultants
-------
ADMINISTRATIVE RECORD INDEX
JENNISON-WRIGHT CORPORATION SITE REMOVAL ACTION
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
JULY 29, 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 Update for the Jennison-Wright Corporation site located in Madison County, Illinois. This
index as well as the Administrative Record itself will be updated when necessary by the IEPA. (Definitions of
abbreviations are provided on the last page.)
Please contact Michelle Nickey-Tebrugge (P.O. Box 19276, 1021 North Grand Avenue, East, Springfield,
Illinois 62794-9276, 217/524-4825) for more information on who and where to direct questions concerning
this index.
No.
Title
EE/CA Final
Proposed Plan Final
Fact Sheet
Public Notice of Hearing
Revised Community Relations Plan
.
Issue
Date
July, 1999
7-14-99
7-20-99
7-18-99
7-28-99
Author1
E&E
Fred Nika (IEPA)
Michelle Tebrugge
(IEPA)
Michelle Tebrugge
(IEPA)
Michelle Tebrugge
(IEPA)
Number
of Pages
'
-------
-------
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