EPA Superfund Record of Decision: Parson's Casket Hardware Co., Belvidere, IL 9/30/1996


                                 PB96-964110
                                 EPA/ROD/R05-96/307
                                 November 1996
EPA  Superfund
       Record of Decision:
       Parson's Casket Hardware Co.,
       Belvidere, IL
        9/30/1996

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
£ REGION 5
§ ^f77 ° ^ WEST JACKSON BOULEVARD
\^'l'^p* CHICAGO, IL 60604-3590

FSEP 3 1 1996J
REPLY TO THE ATTENTION OF:

SR-6
Mary Gade, Director
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62794-9276

Re: Parson's Casket Site - Belvidere, Illinois
Concurrence on Record of Decision

Dear Ms. Gade:

The United States Environmental Protection Agency (U.S. EPA) hereby concurs with the
decision that institutional controls and deed/zoning restrictions for the shallow soils and
excavation and removal for the deep soils are necessary as identified in the enclosed Record of
Decision (ROD) completed by the Illinois Environmental Protection Agency (IEPA) for the
Parson's Casket Hardware Site. Our concurrence is in accordance with 40 CFR
§300.525(e)(2)(i) and (ii) and is based on the administrative record.

U.S. EPA understands that the soils operable unit addresses the source of the contamination and
is not the final remedy at the Site. A subsequent operable unit addressing the groundwater
contamination is expected to follow.

We look forward to our continuing involvement on the Parson's Casket Hardware Site.

Sincerely yours,
E. Muno, Director
Superfund Division

Enclosure
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)

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                    DECLARATION OF THE RECORD OF DECISION
 SITE NAME AND LOCATION

 Parson's Casket Hardware
 Belvidere, Illinois

 STATEMENT OF BASIS AND PURPOSE

 This decision document presents the selected remedial action for the Parson's Casket Hardware Site in Belvidere,
 Illinois, which was chosen in accordance with CERCLA, as amended by SARA and to the extent practicable, the
 National Oil and Hazardous Substances Pollution Contingency Plan (NCP).  This decision is based on the
 administrative record for this site. The USEPA Region V concurs with the selected remedy.

 ASSESSMENT OF THE SITE

 Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the response
 action selected in this Record of Decision (ROD), may present an imminent and substantial endangerment to public
 health, welfare, or the environment.

 DESCRIPTION OF THE REMEDY

 The remedial action addresses two (2) operable units-shallow and deep soils. Groundwater is a separate operable
 unit and is still under investigation. The groundwater operable unit will be addressed under a separate ROD. The
 shallow soil operable unit is being defined as the area from ground surface to 1 foot below land surface (BLS).
 The deep soil operable is the area greater than 1 foot BLS to groundwater (approximately 20 feet BLS). The
 shallow soil operable unit remedy selection consists of institutional controls and deed/zoning restrictions for the
 property to reduce the risks associated with exposure to contaminated materials. Restrictions would apply so that
 the property remains industrial since it was  shown that the population at greastest risk would be future adult or
 child residents.  The function of the deep soil operable unit remedy selection is to excavate and remove from the
 site a source of VOCs, SVOCs,  and metals  from an abandoned lagoon  area which was utilized to dispose
 electroplating wastes from the 1930s to 1982 and to determine the nature and extent of contamination and
 remediate dry wells presumed to be on the property. Both the lagoon and the dry wells are continuing to degrade
the local groundwater, which is utilized as  a drinking water supply for the City of Belvidere.

The major components of the selected remedy include:

 *      Installation of a security fence around the site;
 >      Deed/zoning restrictions to prohibit groundwater use, limit building construction on the site (i.e.,
       residential construction), and control waste material generated from manipulation of soils at the site (e.g.,
       footings for buildings);

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                           i n i_mw                    rnA riu,  at locodoo               r. Ui
>      Excavate and remove contaminated soils from the abandoned lagoon area and determine remedial action
       for the suspected dry wells;
»      Groundwater monitoring;

DECLARATION

The selected remedy is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost
effective.  This remedy utilizes permanent solutions  and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.

Because this remedy will result in potentially hazardous substances to remain on site above health-based
levels, a review will be conducted within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human health and the environment.
                                                                    9/Jt/tt.
Mary A. xSade, Director                                          Date
Illinois Environmental Protection Agency

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SUMMARY FOR THE RECORD OF DECISION
Site Name. Location, and Description

The Parson's Casket Hardware Site, located in Belvidere, Illinois is a National Priorities List (NPL)
site under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA),
commonly known as Superfund. The Illinois Environmental Protection Agency (IEPA), under a
Cooperative Agreement with the U.S. Environmental Protection Agency (USEPA), conducted a
Remedial Investigation/Feasibility Study (RI/FS) on this Superfund site.

The Parsons Site is located on the northwest side of Belvidere, Illinois covering about 6 acres and is
bordered by residential communities to the east and various industrial facilities to the west, north and
south. The Kishwaukee River is 1/4 mile south of the site. Two of Belvidere's eight municipal water
supply wells are located approximately 1,500 feet northwest and 1/2 mile southwest of the site,
respectively. Both wells are used on a daily basis. The municipal well located northwest of the site
has had hits of TCE, which were also found at the site, however, the levels were not above MCL's.
The United States Geological Survey (USGS) has performed some work at the site on the deep aquifer.
However, no definite conclusions were made that the contaminants were from Parson's. Most likely
the contamination is from multiple sources, including Parson's. Groundwater has extended to the
Kishwuakee River and it is believed to be discharging into the river basin.

The Parson's Casket Hardware Company manufactured decorative metal fittings for caskets at the site
from the early 1920's to 1982. Such operations require the use of hazardous chemicals, and hazardous
waste byproducts are created as a result of the manufacturing process. The Parson's Company
continued to operate in the same facility until filing for bankruptcy in August 1982. Waste generated
mainly consisted of electroplating sludge, cyanide plating solution, cyanide cleaning solutions, bronze,
nickel and brass sludges, and cleaning solvents.

A series of aerial photos taken from 1954 to 1986 at various intervals show activities that occurred at
the site and features which no longer exist. A lagoon was one of the principle waste disposal locations.
A railroad spur is visible hi a few of the aerial photos. Reportedly, liquid wastes were disposed of
along the track prior to construction of the lagoon (IEPA 1989).

The west wing of the existing facility was used for diecasting and remelting of metals. The most
commonly used metals were lead brass, diecast steel, white metal, silver, and zinc. Reportedly, the
company used low volumes of diluted cyanide solutions in the west wing operations and large quantities
of alkaline compounds and sulfur.

The east wing of the facility housed the finishing operations. Cyanide treatment and electroplating was
conducted on the first floor. Trichloroethylene (TCE) treatment and refurbishing of meals were
performed on the second floor. Reportedly, there were approximately ten dry wells used for disposal
of cyamde waste sludge on the north side of this wing. See Figure 1-2 for summary of site conditions.

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SITE HISTORY AND ENFORCEMENT ACTIVITIES
Parson's Company obtained interim status to operate a hazardous waste management facility under the
Resource Conservation and Recovery Act (RCRA) in 1980. The company notified USEPA that
hazardous waste was stored on-site in tanks and containers. The listed waste streams on the RCRA
part A application were F006 (wastewater electroplating treatment sludges for electroplating operations
and F009 (cleaning bath solutions from electroplating operations where cyanides are used).

In 1982, the Illinois Attorney General's Office (which subsequently informed IEPA) received an
anonymous tip that the Parson's Company was going to cease operations and abandon hazardous wastes
at the site. A subsequent IEPA investigation found that Parson's Company stored cyanide plating
wastes in drums, treatment tanks, underground storage tanks, and in an unlined lagoon. The lagoon
was used to contain overflows from the company's treatment system. Plating wastes include spent
strippers, electroplating sludges, degreasers, acids, heavy metals (those most commonly used were
lead, brass, diecast steel, white metal, silver, and zinc), and cyanides. During the investigation, IEPA
also observed approximately 300 metal drums outside of the treatment building. Most of the drums
were full, other were partially filled without lids, and some were empty. Some of the drums showed
signs of deterioration and leakage.

At lEPA's recommendation, Parson's began a voluntary cleanup of the site. The cleanup was started
but on August 12, 1982, Parson's Company informed IEPA that the company had declared bankruptcy
and was not able to complete the cleanup.

Legal action by the State of Illinois followed, and an agreement with Dickey-Grabler was negotiated in
1982 to secure the Parson's Site. The Parson's Company removed most of the waste from the
underground storage tanks and installed a chain link fence around the lagoon. Materials in the rusting
drums were removed and placed in new sealed drums, all drummed waste material was placed hi the
secured building, and signs were posted. In 1984, the on-site buildings were purchased by Filter
Systems, Inc. of Addison, Illinois. The company agreed to recycle and remove the drums, tanks, and
other containers stored hi the building.

In February 1986, IEPA inspected the building following the Filter Systems cleanup. Immediate
concerns were adequately dealt with since all plating solutions and wastes were safely contained.
Subsequently all remaining wastes under the RCRA Part A permit were disposed by a qualified
contractor. Currently, Deveco Corporation, a company that blends chemicals for the plating industry,
operates hi the building. Chemicals are safely stored in drums inside the building or hi above ground
tanks outside the building.

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1.0 PREVIOUS INVESTIGATIONS

As part of the August 1982 IEPA investigation, testing was conducted on the plating solutions found hi
the drums and tanks and lagoon sediments. Results showed they contained elevated concentrations of
heavy metals. Two private wells, located approximately 1/2 mile from the site were also sampled for
inorganic chemicals. No concentrations were detected above state standards.

IEPA conducted a partial cleanup of areas outside the site building from fall 1984 through spring 1985.
Waste materials including lagoon liquids and sludge were removed and treated and disposed of off-site.
A one-foot thick sludge seam was uncovered at the bottom of the lagoon. Three underground storage
tanks were removed while a fourth was left in place and filled with sand.

From 1984 through 1989, IEPA and USEPA sampled and analyzed surface soil, subsurface soil, and
groundwater samples. Soil borings were drilled and three on-site monitoring wells were installed.
Routine sampling of some wells was conducted for approximately two years from 1985 to 1987.
Surface soil samples, obtained from areas west of the lagoon to determine effects of lagoon runoff,
indicated concentrations of nickel and copper slightly above normal background levels. Groundwater
samples indicated that dissolved metals were above state standards. Also, volatile organic compounds
(VOCs) were detected in groundwater samples. Observed concentrations of these compounds were
above respective state and federal standards. Due to these results and the naming of the site to the
National Priorities List (NPL), IEPA and USEPA entered into a cooperative agreement for the Parson's
Casket site. Pursuant to this agreement, IEPA is performing an RI/FS to determine the full nature and
extent of contamination at the site.

2.0 REMEDIAL INVESTIGATION

Field investigations at the Parsons' Site involved a two-phase approach. The Phase I field program was
conducted from May to September 1989. During this phase, 23 soil borings were drilled and sampled,
13 monitoring wells were installed and two rounds of sampling were completed, a topographic map was
created and aquifer tests were performed. Phase II, 11 soil borings were drilled and sampled,
groundwater plume chasing program was conducted, 15 monitoring wells and one extraction well (a
well designed to receiver hydrocarbons floating on top of groundwater) were installed, and packer
sampling and aquifer testing was performed in the three deep bedrock boreholed by USGS. Phase II
work also included collecting of geophysical logs hi the three deep bedrock boreholes, aerial and land
survey ing to update the site map, and two rounds of sampling and analysis of all Phase I and n
monitoring wells.

2.1 SOIL SAMPLING

A soil investigation was performed to locate and determine the nature and extent of contaminants hi
surface and subsurface soils at the Parson's Site. Locations and concentrations of contaminants were
determined from samples collected from both soil borings and monitoring wells boreholes. Samples of
background soil were also collected for comparison to soil samples collected on-site. In addition, the
soil investigation yielded geologic descriptions of soils and gram-size analysis of selected soil samples.

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Phase I soil sampling locations were chosen based on information from lEPA's file containing site
inspection reports, memos, aerial photos and other site-related information, former Parson's Company
employees, and regional geologic reports. Phase II soil sampling locations were selected to provide
additional data on contaminants that may be migrating off site. Samples were analyzed for VOCs,
SVOCs, metals, and cyanide. See Figure 2-1 for the soil sampling grid and locations.

2.2 GROUNDWATER SAMPLING

Four rounds of groundwater sampling were conducted during Phases I and II of the RI. Phase I
monitoring well locations were based on review of regional geological information, site-specific
geologic information previously collected by IEPA, and the sources previously mentioned for soil
boring locations. Phase n well locations were based on the plume chasing effort and to eliminate data
gaps from the Phase I investigation. See Figure 2-2. for the groundwater monitoring well locations.

Groundwater sampling rounds 1 and 2 were conducted during Phase I, and consisted of sampling and
analysis of 13 monitoring wells. During Phase II, groundwater sampling rounds 3 and 4 consisted of
sampling and analysis of the 13 Phase I wells and the 16 newly installed Phase II wells. In addition,
three wells were sampled at the Taptite Production Facility of Camcar/Textron, Inc., a manufacturing
operation adjacent to the Parson's Company. Data collected from all rounds of sampling were intended
to determine the vertical and lateral extent of contamination. In addition, the groundwater quality
hydraulically upgradient of the site was investigated. Water levels were used to determine approximate
groundwater flow directions and velocities. Groundwater samples were analyzed for the following
parameters:

VOC (Volatile Organic Compounds)
SVOC (Semi-Volatile Organic Compounds)
Dissolved Metals, total metals (on selected samples)
Dissolved Cyanide
Anions
Cyanide amenable to chlorination
Alkalinity
Specific Conductivity, pH and temperature.

See Figures 3-1 through 3-7 for location of cross section lines referencing the geology of the site.

2.3 PLUME CHASING

During the Phase II field effort, a plume chasing investigation was performed in an attempt to map the
down-gradient lateral extent of contamination migration in the alluvial aquifer. Groundwater was
sampled at selected locations through temporary well points and analyzed for target VOCs using
quick-turnaround (48-hour) lab analysis. Analytical results were then used to place monitoring wells.
Specifically, results were used to decide whether to install a monitoring well(s) at that location or move

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 further downgradient and attempt another well point.  Wells were originally planned for areas where no
 VOCs were detected.  If VOCs of concern were detected, then a second location was to be drilled
 further downgradient.

 2.4   LIGHT NON-AQUEOUS PHASE LIQUID (LNAPL)

 During Phase II a product extraction well was installed to collect an LNAPL and groundwater directly
 below it.  Samples were collected to determine the composition of the material and test for hazardous
 compounds such as PCBs that are often present in waste oils. The LNAPL was sampled for SVOCS
 and Pesticide/PCBs and groundwater was analyzed for VOCs, SVOCs,  Pesticides/PCBs, and 2,3,7,8
 TCDD/TCDF (Dioxin).

 2.5   RESIDENTIAL WELL SAMPLING

 The purpose of the private well evaluation was to identify whether private wells were being impacted
 near the Parson's Site. Ten private  wells were samples which are approximately 0.5 mile to 1.5 miles
 from the site. Samples were collected directly from taps that were in-line with the residence well. No
 samples exceeded Class I, Illinois Groundwater Regulations. Homes adjacent to the site are serviced
 by the City of Belvidere's public water supply system.

 3.0   OTHER SITE SAMPLING AND FIELD ACTIVITIES

 During the Phase n field efforts, samples of the metallic material in the smelter building of the
 Parson's Company and of the clinker material and burned material on the surface of the site were
 collected.

 Metallic material was present inside and  outside of the old smelter room at the west corner of the
 existing building. Specifically, loose material was present on the ground and on the discharged
 equipment in the room, and  melted onto  the walls of the building. Samples were collected for analysis.

 Clinker material, the residue from coal burning, is commonly used as the foundation of railroad beds.
 This material was found throughout the Parson's Site in the  top 1 to 3 feet of soils. Also, charred
 wood chips, probably from burned railroad ties, are also present. During Phase I, polynuclear
 aromatic hydrocarbons (PAHs) and creosote products were detected in surface samples. PAHs and
 creosote were suspected to result from the clinker material and burned wood chips.  Samples were
collected and analysis conducted or SVOCs, total metals, and cyanide.

Aquifer testing of Phase I monitoring wells was conducted by USEPA.  The hydraulic conductivities of
the aquifer(s) beneath the site were determined from rising and falling head slug tests.  A rising head
test is conducted by removing a "slug" of water from a well and recording the change in water level
with time as the well recovers to the static condition. A falling head test is the opposite, i.e., a sludge
of water is added.

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Packer sampling tests were conducted by the U.S. Geological Survey in three 150-foot bedrock
boreholes and one 300-foot bedrock borehole. The purpose of the packer sampling was to determine
the vertical distributions of VOCs, and the hydraulic properties of the bedrock under the Parson's Site.

USEPA is the lead enforcement Agency conducting the Potentially Responsible Parties (PRPs) search
and any subsequent enforcement actions.

COMMUNITY RELATION ACTIVITIES

An Administrative Record (AR) is available to the public at the IDA Public Library located in
Belvidere, Illinois, as required by CERCLA Sections 113(k)(2)(B)(i-v) and 117. The IEPA produced a
Community Relations Plan (CRP) in 1988 and an addendum to the plan was developed in July 1991.
The mailing list was updated prior to the release of the Proposed Plan/Public Hearing notice. A Public
Hearing was held on August 7, 1996 at the IDA Public Library regarding the Feasibility Study (FS)
and the Proposed Plan.

SCOPE AND ROLE OF OPERABLE UNITS

1. The remedial action consists of three operable units 1) Groundwater 2) Shallow Soil and 3) Deep
Soil.

1. Groundwater Operable Unit:

The groundwater remedy selection will be concluded under a separate FS.

2. Shallow Soil Operable Unit:

For remediation purposes, this unit is being considered 1 foot or less below land surface
(BLS). This unit's remedy incorporates a "limited" no action, consisting of deed notices
and restriction of activities to manage contact with soils of concern. The risk associated
with this site allows for an industrial scenario to continue with minimal remedial activities
(e.g., removal [and disposal] of shallow soils during the deep soil remedial action).

3. Deep Soil Operable Unit:

For remediation purposes, this unit is being considered greater than 1 foot BLS to
groundwater (approximately 20 feet BLS). This unit's remedy involves excavation of only
a portion of the deep soils at the site. The excavated waste will be disposed of at an
off-site disposal unit permitted to accept the waste. The excavated area would then be
filled with clean soil. This remedy greatly reduces the toxicity, mobility and volume of
contaminants that were discovered at the site.

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SUMMARY OF SITE CHARACTERISTICS
3.0 NATURE AND EXTENT OF GROUNDWATER CONTAMINATION

VOCs have been detected in the groundwater in alluvial and fractured dolomite (bedrock) aquifers
below the Parson's Site. The main VOCs detected in the study area are tetrachloroethylene (PCE),
trichloroethylene (TCE), and 1,1,1-trichloroethane (1,1,1-TCA). Degradation products such as
1,2-dichloroethylene (1,2-DCE), 1,1-dichloroethylene (1,1-DCE), 1,1-dichloroethane (1,1-DCA), and
vinyl chloride also have been detected hi association with the parent compounds.

The pattern of VOC contamination indicates a possibility that two plumes exist within the parson's Site
Remedial Investigation study area. Two contour plots are presented in Figures 4-7 and 4-8 to show
contaminant migration patterns. PCE is only detected in the western and south to southwestern
portions of the deep alluvial aquifer, and does appear to be migrating away from the site. TCE and
1,1,1-TCA, in contrast, appear to be migrating away from the site lagoon area. Ratioing of TCE to
1,1,1-TCA concentrations show that samples with the highest ratios are directly adjacent to the lagoon
area or down-gradient. Since TCE and 1,1,1-TCA have approximately the same mobility, these results
probably indicate that TCE was predominant compound used at the Parson's Site. Vinyl chloride was
only detected hi the southern most wells of the study area, and appears to be associated with the PCE
plume.

The greatest concentration of TCE detected in the deep alluvial wells is associated with the previous
location of the lagoon. Contamination is concentrated at the former location of the lagoon and
decreases toward the southeast. However, elevated concentrations of TCE were also detected in the
south and southwest portions of the study area.

Groundwater flow hi the deep alluvial aquifer is primarily toward the southeast and is consistent with
TCE migration away from the lagoon area hi this direction. However, TCE is also present hi the south
and southwest study area deep alluvial wells, which is cross-gradient from contamination associated
with the lagoon. Two explanations may account for contamination in the south and southwest: a
separate historical source to the west or southwest, or changing groundwater flow.

PCE was only detected hi deep alluvial wells hi the south and southwestern portions of the study areas.
The PCE to TCE ratio is higher for groundwater samples hi the southwestern portion of the study area.
This area is cross gradient from the Parson's Site, and since little PCE is associated with wells on-site,
this increase hi PCE concentrations is consistent with another source (or sources) of contamination.

VOC contamination has migrated into the bedrock aquifer. However, because of the heterogeneous
flow which may develop in a fractured bedrock system interpretation of extent of contamination is
difficult. Hydrogeologic investigations by USGS of the bedrock near the site (Mills 1992a, 1992b,
1992c) indicates that contamination has migrated into the Saint Peter sandstone, an aquifer which
supplies water to municipal wells. Therefore, it is possible that this contamination may have spread
toward Municipal Wells Nos. 4 and 6.

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Anion results indicate an increase of chloride in several portions of the study area. In general, these
results appear to be associated with contaminant plumes both from the lagoon area, and in the south to
southwestern portions of the study area.

The LNAPL detected in the center of the site contains VOCs and SVOCs. Several of the VOCs are
also associated with groundwater contamination detected directly below the LNAPL and in other wells
through the study area. Although the LNAPL may be a source of contamination to the groundwater, it
is not interpreted as the primary source mainly because of the limited area of influence. Other wells
cross-gradient from the LNAPL show concentrations at the same order of magnitude as groundwater
directly below the LNAPL. SVOCs were detected in groundwater below the LNAPL, but these
compounds were not detected in any other wells, therefore, migration of these compounds is not
considered extensive.

Results from inorganic chemical analysis indicate that some migration of analytes such as copper and
nickel may be occurring, but only results from wells on-site show concentrations above Illinois Class I
Groundwater Standards or Federal MCLs; therefore, migration of these analytes is localized.

Cyanide was detected in several wells on-site, primarily in the eastern portions. In general, these
concentrations are low except for samples from one well (G112S) which are near State and Federal
regulatory criteria. Analysis indicates that this cyanide is not amenable to chlorination, therefore the
possibility for cyanide migrating to groundwater is significantly reduced. Potential cyanide migration
to the east and southeast is not completely bounded by wells. Chemicals detected in the groundwater
can be found in Table 1-4.

Groundwater is being investigated under a separate operable unit and will be concluded under a future
FS. The information provided above is for comparison purposes and to provide additional information
in support of the soil operable units remedy selection.

4.0 NATURE AND EXTENT OF SOIL CONTAMINATION

The results of the shallow soil (1 foot or less BLS) analyses indicate areas of surface organic and
inorganic contamination currently exist; these appear to be due to spillage from the old railroad spur
and plating tanks, vertical tanks located north of the site, or drums which were spilled or leaking
chemicals. Chemicals detected in the soil above background levels are frequently associated with
plating solutions (heavy metals and cyanide) or are used as cleaning solvents. This surface soil
contamination by metals may pose ingestion or inhalation health threats. See Figure 1-1, Table 1-1 and
Table 1-2 for summaries of shallow and background soil results.

In general, the results from the deep-soil boring investigation indicate that small isolated areas around
the old lagoon area at greater than 1 foot to 20 feet BLS exists with low concentrations of VOC,
SVOC, and inorganic chemicals. These areas may have been missed during excavation of the lagoon,

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including a sludge seam observed during the 1984-85 removal action. These remaining chemicals, may
still be contributing to groundwater contamination. Chemicals detected in the deep soils are
summarized in Table 1-3.

The predominately carbonate facies groundwater suggests that bicarbonates and carbonates should also
be present. Under these groundwater conditions, the heavy meals copper, nickel, lead, and zinc are
most likely present as +2 species or as oxides/hydroxides.

Current groundwater conditions indicate that the metals of concern should not be very mobile in
groundwater. However, conditions during past on-site disposal activities may have been different,
allowing at least initially, for the metals to migrate. Such conditions could have been caused by
disposal of bulk quantities of acid waste, such as plating waste. The metals would have been soluble in
the acids and migrated from the site until the dilution by the groundwater and reaction with the soil was
sufficient to raise the pH to neutral conditions.

Cyanides may have been present as metallocyanides. However, they have probably dissociated to some
extent in the groundwater and migrated relatively freely, although their sporadic presence may be an
indication that biodegradation has removed much of these compounds.

The distribution of contaminants in groundwater beneath and in the vicinity of the site and nearby
residential areas indicates that conditions that allow for the mobility of these contaminants existed in the
past. Since the fluid in the lagoon was higher than the elevation of the surrounding groundwater,
contaminants in the lagoon could have migrated into the groundwater. Additionally, contaminants in
other areas of the site could also have migrated into the groundwater.

Semivolatile organic compounds (e.g., PAHs) are probably a result of railroad operations (burning or
treting of ties; disposal of "clinker" material). These compounds are not mobile, and may be
biodegradable.

5.0 CHEMICAL FATE AND TRANSPORT

Chemicals released into the environment interact with the natural surroundings. Their persistence in
the environment is affected by soil chemistry, nature of soil gas, atmospheric interactions and
groundwater chemistry. Interaction with other chemicals (both natural and anthropogenic), presence of
bacteria, and availability of gaseous radicals and acids also affects the fate of released chemicals.

Organic and inorganic contaminants that are present at the site are subject to several processes which
control their movement and fate. Adsorption is the main process which retards (relative to average
groundwater velocity) the movement of contaminants. Via adsorption, contaminants are absorbed onto
organic matter and/or clay surfaces. Adsorption of metals to clay surfaces removes them from
groundwater. Calculated retardation factors for the organic contaminants within the saturated zone
range between 1.6 and 4.0, depending upon the organic content. Average shallow groundwater
velocity is estimated to be between 0.005 to 3 ft./day thus yielding approximate organic-contaminant
groundwater-transport rates ranging from a low of .001 ft./day to a high of 1.9 ft./day in the shallow

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aquifer. Rates within the deep aquifer are of the same order of magnitude. Rates within the vadose
zone would be considerably lower due to allowed water content. Rates for vapor transport, however,
are slightly higher. Calculated vapor-phase retardation factors range between 1.6 to 1.9.

Although adsorption tends to slow the migration of contaminants, persistence of "parent" contaminants
is affected by abiotic and biotic transformations. The same general principles of sorption and
transformations are valid hi the unsaturated and saturated zones. Both are controlled by amount of
water and thus, most likely to occur at soil — and rock-water interfaces (i.e., perched zones; regions of
high clay content) and within the saturated zone. The result of transformations is the breakdown of
original parent contaminants to byproducts which may be subject to further breakdowns. The present
of 1,1-DCE, 1,1-DCA, and vinyl chloride indicates that transformations of PCE, TCE, and 1,1,1-TCA
may be occurring. See Figure 5-1.

The sorption, or precipitation, of metals is dependent on several factors which include availability of
water and pH-Eh conditions of the local environment. Eh is the oxidation reduction potential which
indicates whether groundwater is hi an oxidizing or reducing state. In the presence of alkaline soils
subject to the right conditions (e.g., pH greater than 8), certain metals will tend to precipitate. Slight
changes hi conditions, however, would result in the dissolution of any precipitated metals. Assuming a
system with a pH of 6.5 to 7.5, the observed metals can exist as several different valences depending
on the Eh value.

SUMMARY OF SITE RISKS

6.0 BASELINE RISK ASSESSMENT

Risk Assessment is an essential component of the RI/FS at Superfund hazardous waste sites. A
baseline risk assessment was conducted as part of the RI for the Parson's Site to assess site conditions
in the absence of remedial actions to, more specifically, evaluate potential risks to human health, and to
support the determination of the need for site remediation. It examined the presence and release of
chemicals from the site, the observed levels of chemical contaminants in the environment, the potential
routes of exposure to human receptors, and the likelihood of adverse health effects following contact
with contaminated environmental media. An ecological assessment was not conducted since the
Parson's Site is very small and located in the heart of an industrial section of Belvidere. In addition,
there are no known endangered species present or critical habitats within the site. In conducting this
baseline risk assessment, the USEPA guidance document (USEPA 1989) was used as a primary source
of information.

The baseline risk assessment involves performing four key steps: identification of potential chemicals
of concern; an exposure assessment; a toxicity assessment; and a risk characterization. In addition, an
Vuncertainty evaluation, a qualitative assessment of the effect of uncertainty on the risk evaluation, a
qualitative assessment of the effect of uncertainty on the risk assessment of the Parson's Site is
presented.
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Uncertainty is inherent in the selection or derivation of key input parameters and in conducting
analyses. Results of the baseline risk assessment must be viewed as estimates that span a range of
possible values that may be understood only in light of the fundamental assumptions and methods used
in the evaluation. Given that the verified toxicity measures used in baseline risk assessment are
established by USEPA, the greatest sources of uncertainty are the determination of exposure point
concentrations, the development of exposure scenarios, and the derivation of long-term intake or dose
estimates for the human receptors at greatest risk.

6.1 IDENTIFICATION OF POTENTIAL CHEMICALS OF CONCERN

Results of the analysis of soil and groundwater the Parson's Site were evaluated for use in the baseline
public health risk assessment. Chemicals hi shallow soils were identified and incorporated into the
baseline risk assessment by comparison with background shallow soils. The risk assessment
characterized the risks of the site-related soil set and background soil separately.

The leaching of contaminants from deep soils (greater than 1 foot BLS) to groundwater, another source
of potential contamination, was examined as part of the risk assessment. This is an important pathway
because it addresses the potential for deep soils contributing to groundwater contamination. An
equilibrium partioning approach was utilized to produce the maximum possible concentration of a
contaminant hi groundwater resulting from the leaching process occurring hi deep soils.

6.2 EXPOSURE ASSESSMENT

The exposure assessment is intended to estimate the type and magnitude of exposure to the chemicals of
potential concern that are present at or being released from the Parson's Site. It involves characterizing
the exposure setting and potential pathways, and provides the framework for the characterization of
potential health risks. This exposure assessment focuses on potential exposures given existing site
conditions, and does not evaluate past exposures.

Exposure pathways are defined as those specific mechanisms by which an individual or a population is
exposed to chemical contaminants present at a site or released by a site. Four elements comprise an
exposure pathway: (1) a source and mechanism for direct exposure or release of chemicals to the
environment; (2) an environmental transport medium (e.g., air, water); (3) a point or site of potential
human contact with the contaminant medium (exposure point); and (4) a human exposure route (e.g.,
ingestion, inhalation, dermal contact). Each exposure pathway, therefore, is a specific mechanism of
potential human exposure, and the total exposure of an individual or population may be a composite of
several separate exposure pathways.

A conceptual model of the Parson's Site has been developed to characterize the transport of a chemical
from the source of release to receptors at potential risk of exposure. Contaminant sources associated
with the Parson's Site are categorized as primary or secondary. Primary sources are those hazardous
wastes disposed of hi the lagoon and other localized areas where wastes were introduced onto the soil
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surface within the confines of the site, for example, locations of plating solution at above- and
below-ground tanks. Secondary sources are those hazardous constituents that are transported or
migrate to a new location. These include leachate and soil.

A number of exposure pathways were examined for children and adults in the community, on-site
workers, and construction workers. For children this includes ingestion of surface soils, inhalation of
surface soils, and dermal contact with surface soils. The same exposure pathways were considered for
adults. For on-site workers and construction workers specific exposure pathways include ingestion,
inhalation, and dermal contact with surface and shallow soils. A variety of exposure equations and
assumptions are used to derive intake estimates for these exposure pathways.

6.3 TOXICITY ASSESSMENT

The objectives of the toxicity assessment are to evaluate the inherent toxicity of the compounds under
investigation, and to identify and select toxicological measures for use in evaluating the significance of
the exposure. In the development of these toxicological measures for the Parson's Site, available
dose-response data from USEPA databases were reviewed on the adverse effects to human receptors.

6.4 RISK CHARACTERIZATION

Risk characterization is the process of integrating the results of the exposure and toxicity assessments
by comparing estimates of intake or some with appropriate toxicity measures to develop an indication
of the potential for adverse effects in exposed populations. The objective of the public health risk
characterization is to determine if exposure to chemicals present at or released from the Parson's Site
poses an unacceptable risk to human health. Risk characterization is conducted separately for
carcinogenic and noncarcinogenic effects. Risk assessment results help determine the need for site
remediation. The following is a brief synopsis of the results of the risk characterization for each of the
four human receptor categories. It addresses risk associated with exposure to mean concentrations only
(except for lead exposure in children, which addresses the reasonable maximum exposure [RME]
results). Please refer to Table 1-5 for a summary of soil risk at the Parsons Site.

Direct Contact With Shallow Soils

Current Receptor: Site Worker

The excess carcinogenic risk associated with exposure to site soil is 1 x lO"6, with ingestion of soil
containing arsenic driving the risk followed by dermal contact with benzo(a)pyrene in the soil. No
noncarcinogenic adverse health effects are expected as a result of exposure to site soils. The risk
associated with site and background soils are identical.
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Current Receptor: Adult Trespasser

The excess carcinogenic risk associated with exposure to site soil is 2 x 10'7, with ingestion of soil
containing arsenic driving the risk followed by dermal contact with benzo(a)pyrene in the soil. The
excess carcinogenic risk for background soils is in the same order of magnitude at 1 x 10"7.
Carcinogenic risk of this magnitude is considered acceptable. No carcinogenic adverse health effects
are expected as a result of exposure to site or background soils.

Future Receptor: Adult Resident

The excess carcinogenic risk associated with exposure to site soil is 3 x 10"6, with ingestion of soil
containing arsenic driving the risk followed by dermal contact with benzo(a)pyrene in the soil. This
risk is identical to that associated with background soil and may be considered moderately acceptable.
No noncarcinogenic adverse health effects are expected as a result of exposure to site or background
soils.

Future Receptor: Child Resident

Lead exposure for children was evaluated using the Integrated Exposure Uptake Biokinetic Model for
RME concentrations of lead. Results indicated no adverse health effects are anticipated from exposure
to lead at RME concentrations in site soil.

Future Receptor: Site Worker

The excess carcinogenic risk associated with exposure to site soil is 1 x 10"6, with ingestion of soil
containing arsenic driving the risk followed by dermal contact with benzo(a)pyrene hi the soil. This
risk is identical to that associated with background soil and may be considered acceptable. No
noncarcinogenic adverse health effects are expected as a result of exposure to site or background soil.

Future Receptor: Construction Worker

The excess carcinogenic risk associated with exposure to site soil is 2xlO~7, with ingestion of soil
containing arsenic driving the risk followed by dermal contact with benzo(a)pyrene hi the soil. This
risk may be considered acceptable. Exposure to background soil presents a greater, but still
acceptable, carcinogenic risk of 6xlO~7 No noncarcinogenic adverse health effects are expected as a
result of exposure to site or background soil.
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Future Receptor: Adult Trespasser

The excess carcinogenic risk associated with exposure to site soil is IxlO"7, with ingestion of soil
containing arsenic driving the risk followed by dermal contact with benzo(a)pyrene in the soil. This
risk is identical to that associated with background soil and may be considered acceptable. No
noncarcinogenic adverse health effects are expected as a result of exposure to site or background soil.

Risk Associated with Deep Soils

The greatest risk associated with the deep soil operable unit is through leaching of contaminants from
the site into the groundwater. Groundwater beneath the site has consistently shown risk above the 10"6
and hazard quotients greater than 1 for carcinongenic and noncarcinongenic risk, respectively. It
appears that the groundwater will continue to be degraded by contaminants from the former lagoon area
and potentially from the suspected dry wells. Maximum Contaminant Levels (MCLs) have also been
exceeded for VOCs in groundwater beneath the former lagoon area.

Also, the TCE parts per billion (ppb) concentrations for the deep alluvial aquifer at the site indicate an
estimate of the upper confidence level (UCL) may be calculated at 200 ppb. In a residential
groundwater ingestion scenario for the excess lifetime cancer risk (ELCR) of l.OE-04 occurs at a
calculation of 160 ppb. Therefore, at 200 ppb the higher end of the Superfund risk range of l.OE-04 to
l.OE-06 would be expected to be exceeded.

Furthermore, comparisons to the soil screening levels (SSL) guidance to deep soil data indicate SSLs
for the protection of groundwater have been exceeded for the following chemicals: TCE,
Benzo(a)anthracene, Chrysene, Methylene Chloride, N-Nitrosodiphenylamine, Pentachlorophenol,
Arsenic (borderline), Barium, Cadmium (borderline), and Nickel. The conclusions are based upon
approximations of the UCLs for these chemicals in deep soil. Therefore, the deep soil data appears to
compliment the results of the groundwater monitoring data, i.e., exceedances of SSLs generally results
in significant and unacceptable risk in groundwater.
REMEDIAL ACTION OBJECTIVES

During remedial design, preliminary remediation goals will be established to determine soil cleanup
levels to address the risks from deep soils to groundwater. These goals shall ensure that the level of
compounds in groundwater do not exceed the upper bound of USEPA's acceptable risk range or 10-4
or any Maximum Contaminant Levels (MCLs) or non-zero MCLGs.
DESCRIPTION AND EVALUATION OF ALTERNATIVES

Alternatives were developed and screened so that remedial action technologies would be consistent with
the NCP. Alternative retained include the following:
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SHALLOW SOIL ALTERNATIVE NO. 1 - "LIMITED" NO ACTION

Description of Shallow Soil Alternative No. 1

A "limited" no action alternative is proposed that includes passive measures such as fencing of the
property, and the posting of warning signs, and development of deed notices/restrictions to preclude
use of the property from certain activities. Monitoring might also be included to measure contaminant
concentrations in surface water runoff and/or dust originating from the site.

Evaluation of Shallow Soil Alternative No. 1

Overall Protection of Human Health and the Environment

The potential exposure of humans to surface soil at the Parson's Site is by the following mechanisms:

• Ingestion of surface soil

• Dermal contact with surface soil

• Inhalation of surface soil particulates.

Risk estimates vary for different scenarios of site use, but based on potential future uses by adults
and/or children for recreational play, the surface soil from the site would have an excess risk of cancer
of slightly greater than 10"6 (one hi 1,000,000). The potential risk is due primarily to ingestion of
arsenic and dermal contact with PAHs and metals.

The PAHs probably result from clinkers left from the burning of wood and coal hi the locomotives, and
the burning of wooden railroad ties. These contaminants may also have been from coal fire furnaces at
the site. The manganese concentrations are being comparable to background soils at the site and
Illinois background levels for soils.

In summary, the no action alternative for shallow soils would leave surface soil contamination hi place
that presents a potential cancer threat of slightly more than IQr6 from prolonged skin contact or
ingestion to future adult or child residents. Institutional methods (fencing, warning signs) and
deed/zoning restrictions can be effective hi preventing public access to the Parson's Site.

Compliance with ARARs

There are no numerical standard potential ARARs for specific chemicals in contaminated soils, such as
the MCLs that have been promulgated for drinking water under the Federal Safe Drinking Water Act.
Instead, when necessary, risk assessment calculations are made to estimated acceptable levels of soil
contaminated. These calculations require the estimation of exposure routes, dosages, exposed
population characteristics, and other factors for each chemical at each site. The risk assessment for the
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 shallow soils at the Parson's Site has a calculated potential excess cancer risk slightly over 10"6, for
 some potential future use scenarios.

 Reduction in Toxicity. Mobility, and Volume

 The limited no action alternative would take no action to reduce the toxicity, mobility or volume of
 substances present in the shallow soil. Natural processes such as biodegradation, however, would
 gradually reduce the concentration of organic contaminants over a long period of time. And, it is
 inevitable that some shallow soils will be removed during the remedial action for the deep soil operable
 unit, thus further reducing the shallow soils' potential to pose a risk. The use of institutional controls
 alone would not satisfy the CERCLA (121(b)) preference for treatment as a primary element of a
 remedial alternative.  However, under the current land use scenario, no action is required to reduce
 TMV based on risk calculations showing no unacceptable adverse health effects for an industrial use
 category.

 Short-Term Effectiveness

 Because the limited no action alternative would not involve a remedial construction activity, this
 screening criteria is generally not applicable. Fencing and warning signs can be partially effective in
 the short-term to prevent public exposure to on-site contaminated soil.

 Long-Term Effectiveness and Permanence

 The existing potential residual risk would be unabated should the site be open to the public where
 dermal contact and accidental ingestion could occur. However, given the low levels of chemicals and
 extremely low health risk associated with shallow soils, the limited no-action alternative would be
 effective for a future industrial use scenario. Residential use poses only a slight health risk in a future
 property use scenario and can effective be controlled with deed/zoning restrictions. Long-term
 groundwater monitoring is proposed to be completed under the deep soil operable unit.

 Implementability

 Limitations on access, such as fencing and warning signs, are readily implementable. The placement of
 deed restrictions to prevent certain types of future site use would require coordination with cognizant
 local agencies controlling property transfers and land use to ensure compliance.

Cost

Capital costs for Shallow Soil Alternative No. 1, limited no action, are estimated at $33,000 for fencing
and warning  signs. Annual operations and maintenance costs of $9,500 include monitoring, reporting,
and the 5-year public health evaluation.  No cost is estimated for institutional controls to enforce deed
restrictions.  Present worth costs are $179,000 assuming a 5 percent interest rate.
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SHALLOW SOIL ALTERNATIVE NO. 2 - EXCAVATION. OFF-SITE TRANSPORT AND
DISPOSAL

Description of Shallow Soil Alternative No. 2

The excavation and off-site disposal alternative would involve excavation of contaminated surface soil
placement of excavated soil in haul trucks, transport of soil to an off-site disposal facility, and disposal
of soil in a contained land disposal unit permitted to accept the waste. The excavation would then be
refilled with imported clean fill.

Excavation would be performed using conventional earth moving equipment, though the specific
equipment to be used would be identified during the construction stage. Soil sampling would be used
to determine the necessary depth of soil excavation or to assure the removal of soil contaminated above
selected contaminant levels. Following excavation, the shallow excavated area would be regraded as
necessary with clean fill to provide proper drainage and work area elevations, and the site would be
re vegetated.

The major types of excavation and removal for shallow soils are casting/loading excavation, and
hauling excavation. It is expected that around 5,300 cubic yards of soil would be removed from the
surface over most of the site. Sampling would be conducted to confirm that the soil being excavated is
contaminated to levels requiring remediation.

Excavation can be accomplished with a wide variety of conventional equipment. Basic types of
excavation machinery fall into the following general categories:

• Backhoes

• Cranes and attachments (draglines and clamshells)

• Dozers and loaders

• Scrapers.

Off-Site Transport

Transport from the site can be performed with trucks. A variety of haul trucks are available for
transporting excavated materials and waste drums.

The transportation of hazardous wastes is regulated by the U.S. Department of Transportation, the
USEPA, states, and, hi some instances, by local ordinances and codes. In addition, more stringent
federal regulations also govern the transportation and disposal of highly toxic and hazardous materials
such as PCBs and radioactive wastes. Applicable U.S. Department of Transportation regulations
include:
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• Department of Transportation 49 CFR, Parts 172-179

• Department of Transportation 49 CFR, Part 1387 (46 CFR 30974, 47073)

• Department of Transportation DOT-E 8876.

The USEPA regulations under RCRA (40 CFR Parts 262 and 263) adopt DOT regulations pertaining to
labeling, placarding, packaging, and spill reporting. These regulations also impose certain additional
requirements for compliance with the manifest system and record keeping.

The off-site disposal facility is a landfill which meets RCRA standards. The RCRA requirements under
40 CFR Part 264 and all associated guidance and regulations are concerned with the proper location,
design, construction operation, and maintenance of hazardous waste management facilities. Due to the
land ban requirements, it may not be possible to directly landfill the excavated soils. The following
values are the guidelines above which stabilization would be required:
Chemical Level Method*

Cadmium 0.19ppm TCLP
Chromium 0.86 ppm TCLP
Lead 0.37 ppm TCLP
Nickel 5.0 ppm TCLP
Silver 0.3 ppm TCLP
Total Cyanide 590 ppm TCA
Amenable Cyanide 30 ppm TCA
* TCLP = Toxicity Characteristic Leaching Procedure
TCA = Total Constituent Analysis

Since no TCLP analysis was done on the Parson's Site soils, it is uncertain whether the shallow soils
would require stabilization prior to disposal. Stabilization treatment can be conducted at many RCRA-
approved landfills. However, it is believed that stabilization will not be required for shallow soils.

In addition to the metals content of the shallow soils listed above, PAHs and other organics may
determine whether or not the shallow soils can be landfilled directly without treatment. For example, if
certain organic constituents exceed the land disposal limits, bioremediation or incineration have to be
considered prior to landfilling. The following values indicate that the existing PAH values will
probably not trigger the land ban restrictions.

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Limit beyond which
Maximum Level direct landfilling may
Chemical Encountered (nob) not be possible (nob) Waste Code*
Benzo(a)anthracene
Chrysene
Diethylphthalate
Benzo(a)pyrene
2,250
2,500
380
1,900
3,400
3,400
28,000
3,400
U018
U050
U088
U022
*- Denotes concentrations for land disposal restriction, not waste designation for contaminants found at
the site.

Evaluation of Shallow Alternative No. 2

Overall Protection of Human Health and the Environment

The excavation and off-site disposal alternative would be protective of human health and the
environment at the site. Contaminated soil would be removed from the site preventing further potential
for surface water runoff contamination, direct soil contact, and groundwater percolation. Overall
protectiveness would be dependent on the integrity of the receiving landfill and soil treatment, if any,
performed at the receiving facility. If no treatment is employed, the toxicity and volume of the
contaminated soils would not be reduced. Treatment by stabilization would increase volume and
decrease mobility, but would not affect toxicity. The greatest risk during implementation would be
from the transport of a large volume of soil to the landfill. Spills or transport accidents could threaten
public health and the environment along the transportation route.

Compliance with ARARs

The excavation and off-site disposal alternative could be designed, implemented, and completed to
address all ARARs regarding excavation and transport of hazardous waste. The only significant ARAR
issue associated with the alternative relates to RCRA land disposal stipulations for several compounds.
Shallow soils may be classified as F006 waste, as defined in the Federal Register of August 17, 1988,
40 CFR Part 264 through 268. These wastes require stabilization prior to landfilling. TCLP tests are
needed to determine if stabilization of the contaminated soil is required prior to disposal.

Reduction in Toxicity. Mobility, and Volume

The off-site land disposal alternative without treatment offers no overall reduction in toxicity and
volume. Mobility of the shallow soil contaminants removed from the Parson's Site would obviously be
reduced.
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Short-Term Effectiveness

Potential concerns with excavation, removal, and off-site disposal are associated with worker safety,
short-term impacts, and institutional aspects. Where hazardous chemicals are present, excavation can
pose a substantial risk to worker safety. Short-term impacts such as VOCs and fugitive dust emission
and contaminated run-off may also be a concern. Preventive measures can be designed and constructed
to minimize potential effects to human health and the environment during excavation and transport.
Personal protective equipment would be used to protect workers during the action. Dust control
measures would be employed to prevent fugitive emissions from affecting the surrounding population
and environment. Surface water runoff control measures would be used to prevent contaminant
release. Decontamination procedures would be employed to prevent spread of contamination beyond
site boundaries.

Excavations and other construction activity performed on the site as part of future remedial actions
should be done with an approved health and safety plan in effect. The plan should provide for
necessary personnel protective equipment to protect workers. In addition, the plan should provide for
air monitoring at the site boundaries to ensure that off-site emissions are not potentially harmful to the
public.

It is estimated that this alternative could be accomplished in a 3 to 4 month time frame. If
accomplished in a phased manner to accommodate operations at the facility, the implementation period
may be longer.

Long-Term Effectiveness and Permanence

Factors considered under long-term protectiveness include magnitude of residual risk, long-term
reliability, potential of future public exposure to residual concentrations and potential need for
replacement of the remedy.

Magnitude of Residual Risk. The off-site disposal alternative would offer significant long-term
effectiveness through the removal of shallow soils potentially impacting surface water and creating a
direct contact risk at the site. Removal would eliminate long-term impacts from contaminated shallow
soils at the site.

Long-Term Reliability. Because wastes would be removed from the site, overall long-term
effectiveness would be dependent on the long-term integrity of the landfill receiving the waste.

Potential of Future Exposure to Residual Concentrations. If all the RCRA requirements are
implemented, disposal of the contaminated soil at a Class I landfill is expected to be effective long-
term. Since only the top foot of soil is removed, restrictions would apply to future excavation of soils.
For example, if soils are removed for a footing of a building, the workers must be properly protected
and the soil disposed as a hazardous waste if tests so indicate.
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Implementability

At this time there are no difficulties identified in obtaining permits or approvals related to
implementation of this alternative. The off-site facility destination would have to conduct screening
tests to determine if the soils can be accepted at these facilities.

The equipment necessary to implement this alternative is readily available. Standard construction
equipment could be used for excavation activities. The excavated areas would have to be refilled with
clean fill which is readily available from nearby locations. For work on-site, health and safety (OSHA-
certified) trained personnel must be used.

Cost

The estimated capital and present worth cost for excavation of shallow soils and disposal in an off-site
disposal facility without treatment is $1,802,000. O&M costs are $9,500. Present worth costs are
1,948,000, assuming a 5 percent interest rate and 30-year life.

If stabilization treatment of the soil is required prior to disposal, the estimated capital and present worth
cost increases to $2,696,000 based on an added cost of $135 per cubic yard for chemical stabilization
charged at the disposal site. The soil expands when removed from the ground approximately 25
percent, so 6,625 cu. yds. of soil are estimated for stabilization.

SHALLOW SOIL ALTERNATIVE NO. 3 - EXCAVATION. ON-SITE FIXATION AND DISPOSAL
INTO AN ON-SITE CORRECTIVE ACTION MANAGEMENT UNIT fCAMLH

Description of Shallow Soil Alternative No. 3

The major shallow soil contamination is estimated as the upper one foot of the identified contaminated
soils located in an area of approximately 144,000 square feet covering most of the site. The estimated
volume of shallow soil in these areas is approximately 5,300 cubic yards. When excavated, this soil
would expand to approximately 6,625 cubic yards. The shallow soils contain volatile and semivolatile
organic compounds, inorganic compounds and cyanide. The excavation, on-site fixation (stabilization)
and on-site disposal alternative consists of excavating contaminated surface soils at the site, stabilizing
the soils on-site and disposing of the stabilized material in an approved corrective action management
unit (CAMU) constructed on-site. Excavation of the soils would use conventional equipment and be
similar to excavation for purposes of off-site disposal.

The equipment used for soil stabilization is similar to that used for cement mixing and handling. It
includes a feed system, mixing vessels, and curing area. Numerous firms offer on-site chemical
stabilization services and provide expertise in selecting critical parameters, including selection of

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stabilizing agents and other additives, the waste-to-additive ratio, mixing, and curing conditions. The
stabilized soil would be placed directly into an on-site corrective action management unit (CAMU).

The CAMU could be designed to meet the standard of RCRA 40 CFR, Part 264. The CAMU design
used for cost estimating purposes consists of the following layers, from the bottom to the top:

• A graded native soil foundation

• 2-foot layer of clay, or low permeable admixtures

• 60 mil HDPE liner

• Geotextile separation layer

• 2-foot native soil protective layer

• 15-foot (average) layer of soils of concern placed in a cell

• 12-inch sand layer over treated soil

• 60 mil HDPE liner

• 12-inch sand layer above membrane

• Geotextile separation layer

• 18-inch fill layer using native soil

• 6-inch seeded top soil layer.

Other designs might be acceptable and can be considered during design phases if this alternative is
selected. The above cell cross-section is a typical design. The required cell area would be
approximately 1A acre, including a perimeter road and drainage swales.

The chemical stabilization would be done on-site adjacent to the location selected for the CAMU.
Bench-scale tests on representative soil samples would be necessary to determine the best type and
quality of additives to achieve good chemical stabilization of the soil. The TCLP test would be
conducted on the stabilized samples to assess the reduction hi teachability of the contaminants in the
soil. Bench-scale tests have not been done, so the quality and kind of additives listed in the cost
estimate have no basis, except that portland cement (or fly ash) at 0.3 Ib/lb of soil and sodium silicate
at 0.15 Ib/lb of soil have provided a well-stabilized soil mixture elsewhere.
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The temporary on-site solidification facility and labor to operate it is usually provided by remediation
contractors who specialize in chemical stabilization. Mobile units are brought to the site to handle,
meter, and mix the stabilization additives, water, and the soil being treated.

The temporary processing plant, storage area and work space is estimated to require about l/2 acre, in
addition to the area required for the CAMU. Preparation for the temporary solidification facility would
include clearing a flat site, constructing several concrete pads, constructing an access road suitable for
heavy trucks, and providing water, electricity, and sanitation facilities. In addition, the CAMU would
have to be constructed to be ready to accept the stabilized soil mixture.

Long-term monitoring would be required. These monitoring activities would have to meet the
substantive RCRA requirements for closure under 40 CFR Part 264 - Subpart G.

The shallow surface soil that is removed would be replaced by clean fill soil from off-site.

Evaluation of Shallow Soil Alternative No. 3

Overall Protection of Human Health and the Environment

Shallow Soil Alternative No. 3 would protect human health and the environment
through containment of the soils of concern hi a RCRA design cell (CAMU). The cell would be
designed to protect human health and the environment by preventing direct contact with materials,
preventing surface water runoff, and reducing surface water percolation to a negligible quantity. The
fact that the soils would be chemically stabilized makes the alternative more protective than if the soils
were not stabilized prior to placement into the CAMU. The contaminants of concern would be hi a
stabilized matrix within the CAMU, as well as being protected by the bottom and top liners.

Long-term maintenance of the cell and monitoring would be necessary for the alternative to remain
protective. Since chemicals of concern are left on-site, a review every 5 years is necessary, and will
help to ensure that the public is protected.

Compliance with ARARs

Soil which contains constituents of listed wastes should be treated to protective levels, but contaminated
soil disposed on-site in a CAMU is not subject to either LDR treatment standards or RCRA design
requirements for a final cover. It is anticipated that the TCLP tests on the stabilized soil material will
meet federal and state requirements. However, until treatability tests are conducted, stabilization is not
a certainty. Considering the relatively low health risk of the stabilized soil contained in an CAMU, it
may be considered that the soils are treated to protective levels.

Reduction in Toxicity. Mobility, and Volume

The on-site land disposal alternative offers no reduction hi toxicity or volume. Mobility of the
compounds of concern would be significantly reduced through the placement of the materials into a

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controlled CAMU. Chemical stabilization reduces mobility further because contaminants are trapped in
a solid matrix before placement into the CAMU. The CAMU would be designed to reduce the
mobility to near zero with its double liner. Mobility reduction would be dependent on the long-term
integrity of the CAMU.

Short-Term Protectiveness

Excavation, stabilization and redisposal into the on-site cell could be designed and constructed to
minimize potential effects to human health and the environment. Personal protective equipment would
be used to protect workers during the implementation of the alternative. Furthermore, access would be
restricted to areas where soil is being excavated and handled. Decontamination procedures would be
employed to prevent spread of contamination by equipment, e.g., by dirt on tires.

Potential health risks to the community during implementation can be mitigated with proper design and
implementation of actions. The public would experience some additional truck traffic, heavy
equipment noise, and dust. Implementing dust control measures, utilizing truck decontamination
procedures and scheduling construction activities properly should minimize construction disturbances.
It is anticipated that inhalation of soil particles and vapors will not be a significant problem.

Public health risks caused by accidental or catastrophic events occurring during construction and
operation of this alternative are primarily related to accidental releases of untreated soil. Since all the
work would take place on the Parson's Site, the primary methods of significant release would be
through washing away of stored soil during a severe rainstorm.

Significant adverse health effects for site workers and area residents during construction are not
expected. Proper use of personal protective equipment for site workers, as defined hi a health and
safety plan developed for work performance, will provide sufficient protection.

Construction of the CAMU and facilities required to accommodate the portable soil chemical
stabilization process equipment (e.g., concrete pads, utilities) should require about 9 months including
planning, design, construction bidding, permits, etc. Construction of the CAMU is estimated to
require 2 months. Excavation, chemical stabilization of the soil, and placement into the CAMU should
proceed rapidly and is estimated at 3 months duration. The total estimated time of construction for this
alternative is 14 months.

Operational and maintenance for the CAMU would be required well into the future, but for present
worth costing purposes an O&M period of 30 years is used based on general practice at other sites. Of
course, O&M costs would continue beyond 30 years, but the present worth of money spent in the
distant future is relatively small.
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Long-Term Protectiveness

The health risk from the stored materials would be minor after placement into the CAMU. Required
monitoring would ensure that the health risk would be minimal. Construction of the cap and surface
water control channels should virtually eliminate residual risk of surface water contamination. A
properly located and graded site with properly designed flood control channels should be safe from
erosion associated with any storm event.

Assessing long-term reliability to provide continued protection basically involves studying the potential
for failure of the technical components of this alternative and the degree of risk a failure poses. All of
the technical components are reliable, proven technologies.

Long-term reliability is highly dependent on the continued adequate inspection, monitoring and
maintenance of the CAMU. It is essential that the present and future ownership of the property be
legally required to prevent unrestricted access to and disruption of the CAMU by uncontrolled
activities.

Human exposure to residuals could occur primarily because the stored contaminated soils on-site reach
human receptors via an exposure pathway. Potential exposure pathways applicable to the site assume
failure of the containment provided by the CAMU. It is difficult to envision a sudden significant
failure in the CAMU. Failure in CAMUs occur gradually and are the direct result of inadequate
inspection, monitoring and prompt repair of the deficiencies identified. As long as proper O&M and
institutional controls are maintained, this alternative appears to pose little risk of future public exposure
to residual chemicals of concern.

The integrity of the CAMU is largely dependent upon the integrity of the cover constructed over the
stored soil.

Implementability

All of the technologies included in this shallow soil alternative are standard and accepted technologies.
Adequate space exists to construct the CAMU and perform the chemical stabilization. Electric power
and other utilities are available. No unusual difficulty with construction or operation is expected.

At this time there appears to be no reason why the proposed technologies in this alternative could not
meet the anticipated performance criteria. As discussed earlier, reliability is tied closely to assured
adequate operation and maintenance, which is a prerequisite to performance.
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None of the components of this alternative should involve unusual delays in scheduling or deliveries.

This shallow soil alternative does not preclude additional future remedial action, if necessary. Potential
future remedial actions that might be deemed necessary include replacement of significant components
of the CAMU. This can be readily done. Removal of the stabilized soil from the CAMU and
redisposal of the soil off-site at an approved facility would be expensive but could be done. The clay,
sand, and other materials brought in to construct the CAMU would also have to be removed.

Monitoring the effectiveness of the CAMU can be done by means of monitoring fluids entering the
space between the bottom double liner, and sampling of monitoring wells near the CAMU, as required
by regulations governing CAMUs.

The equipment necessary to implement this alternative is readily available. This includes standard
construction equipment and general contracting personnel to construct the CAMU. For work on-site,
health and safety trained personnel must be used. At least 4 firms are available that provide portable
equipment and trained labor to chemically stabilize soil. At least 4 firms are available that manufacture
and provide trained labor to install liners for the bottom and top of CAMUs.
Cost

The estimated capital cost for Shallow Soil Alternative No. 3 is $1,979,000, and the estimated annual
operation and maintenance cost is $54,000. Present worth cost is $2,809,000, assuming a 5 percent
interest rate and 30-year project life.

SHALLOW SOIL ALTERNATIVE NO. 4 - CLAY AND CONCRETE COVERS

Description of Shallow Soil Alternative No. 4

The final shallow soil alternative is covering the top foot of contaminated soil with clay or concrete
covers. Covering of the shallow soil at the Parson's Site would cover approximately 110,000 sq. ft. on
the entire west side of the building and 40,000 sq. ft. on the entire east side of the building, a total of
150,000 sq. ft. It is assumed that the entire area would be covered because it would be impractical to
construct a patch work of "band-aid" like small covers. For estimating purposes, it is assumed that the
110,000 sq. ft. of cover on the west side of the building would be constructed of one foot of clay, since
there is no vehicular traffic in this area. However, it is assumed that the 40,000 sq. ft. of cover on the
east side of the building would be 6 inches of concrete over one foot of gravel hi order to accommodate
truck and auto traffic occurring there. Beneath the covers existing soils would be graded to provide
proper slopes and compacted as a foundation for placement of the covers.
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 Evaluation of Shallow Soil Alternative No. 4

 Overall Protection of Human Health and the Environment

 Shallow Soil Alternative No. 4 would protect human health and the environment through containment
 of the soils under a cover. The cover would protect human health and the environment by preventing
 direct contact with soils of concern, preventing contamination of surface water runoff, and preventing
 airborne transport of soil particles. Surface water percolation through soils would also be reduced, but
 this is not a primary function since the PAH contaminants of concern have not migrated  with
 percolating water. Since chemicals of concern are left on-site, the mandatory review every 5 years is
 necessary and will help to ensure that the public is protected.

 Compliance with ARARs

 There are no applicable  standard chemical ARARs for soils left in place.  Chemical limits are based on
 a risk analysis.  There are no action-specific ARARs specifically covering the design of a cover over
 lightly contaminated soil left in place. The proposed covers partially satisfy the intent of regulatory
 designs for caps, though they deviate in design specifics from typical RCRA caps intended for landfills.
 RCRA design requirements for a final cover are not ARARs for contaminated soil that remains in
 place.

 Reduction of Toxicity. Mobility, and Volume

 Contaminated surface soils would remain in place.  However, covers would greatly reduce the mobility
 of the contaminants by largely eliminating the pathways of surface water runoff, airborne dust particles,
 and direct contact. Toxicity and volume would not be reduced.

 Short-Term Protectiveness

 Planning design, permits, and construction bidding would require approximately 6 months.
 Preparation of the subgrade followed  by construction of the respective clay and concrete  covers would
 require approximately 3  months. The total estimated time of construction is 11 months.

 Minimal maintenance for the covers would be required far into the future, but for present worth costing
purposes, an O&M period of 30 years is used based on general  practice at other sites.

Long-Term Protectiveness

Factors considered under long-term protectiveness include magnitude of residual risk, long-term
reliability, potential of future public exposure to residual concentrations, and potential need for
replacement of the remedy.

As long as the covers are intact, the health risk from the remaining contaminated shallow soil beneath
the  covers would be minimal.

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Construction of the covers and surface water control channels should virtually eliminate residual risk of
direct contact, airborne particulates and surface water contamination from the Parson's Site.

The covers proposed are not primarily intended to reduce infiltration of groundwater since the PAH
contaminants of concern do not appear to be leaching. Therefore, the IEPA does not intend to repair
minor cracks in the cover. Only areas where significant portions of the cover are ineffective will be
repaired.

The use of covers should minimize restrictions on future industrial use of the property. It will be
necessary to have deed restrictions on future excavation handling and disposal of contaminated soil
located below the covers. For example, excavations for building footings or to install pipelines will
have to be done with appropriate worker personnel protection and proper handling and disposal of
contaminated soil.

All of the technical components proposed are reliable, proven technologies. This alternative does not
include any experimental or innovative alternative technologies. The concrete cover would have mesh
reinforcing and would have excellent resistance to cracking under all but severe earthquakes, and could
be readily repaired if damage did take place.
Covers generally require periodic repairs. A common practice is to assume that the cover is essentially
replaced every 20 to 30 years, and estimated annual O&M costs include a cost for a fraction of cover
replacement, e.g., 1/30 of the cover cost.

Implementability

All of the technologies included are standard and accepted.

At this time there appears to be no reason why properly designed covers could not meet anticipated
performance criteria. Adequate maintenance is a prerequisite to performance.

None of the components of this alternative should involve unusual delays in scheduling or deliveries.

Remedial actions that simply puncture the cover, such as extraction well construction, pose no
difficulty. Obviously, excavation of large areas of soil would disrupt the covers.

Monitoring the effectiveness of the covers can be done by periodic visual inspection and sampling of
monitoring wells beneath the covers.

There are no technical reasons that would preclude maintenance activities.

At this time there are no difficulties identified hi obtaining permits/approvals related to implementation
of this alternative for shallow soil.
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Once constructed, there are no anticipated residuals that would require disposal.

The equipment necessary to implement this alternative is readily available. This includes standard
construction equipment and general contracting personnel. For work on-site, health and safety trained
personnel must be used.

Cost

The estimated capital cost for Shallow Soil Alternative No. 4 is $1,147,000, and the estimated annual
operation and maintenance cost is $52,000. Present worth cost is $1,946,000, assuming a 5 percent
interest rate and 30-year project life.

DEEP SOIL ALTERNATIVE NO.l- NO ACTION

Description of Deep Soil Alternative No. 1

The no action alternative literally would involve no action to remediate deep soil contamination at the
Parson's Site. The cost would be zero.

A "limited" no action alternative can also be proposed that includes passive measures such as
groundwater monitoring, the posting of warning signs and deed restrictions to prevent use of the
property for certain kinds of activities. This alternative was covered under the limited no action
alternative for shallow soils previously.

Monitoring would be conducted to determine if the VOCs left in the deep soils continue to be a source
for groundwater contamination. Cost estimates assume quarterly sampling of 10 wells. In addition to
monitoring, the IEPA may also require annual reports and USEPA would require a public health
evaluation every 5 years.

Evaluation of Deep Soil Alternative No. 1

The following information compares the limited no action alternative with the criteria that aid in
evaluating the alternatives under the NCP.

Overall Protection of Human Health and the Environment

The limited no action alternative would do nothing physically over time to protect human health and the
environment. Release of VOCs from deep soils to the groundwater would continue unabated. The
estimated risk from groundwater ingestion exposure resulting from deep soil leaching is currently
estimated as 4 x 10~5 for maximum values. Since the hazard quotient is also greater than 1 (i.e., 5.3), a
significant risk to groundwater would be left at the site.
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Compliance with ARARs

There are no numerical standards for potential ARARs for specific chemicals in contaminated soils,
such as the MCLs that have been promulgated for drinking water under the Federal Safe Drinking
Water Act. Instead, when necessary, risk assessment calculations can be made to estimate acceptable
levels of soil contamination. The risk-based numbers are estimated based on partitioning assumptions
in the RI Report and the exposure routes of the contaminated groundwater.

Reduction in Toxicity. Mobility, and Volume

The limited no action alternative would not reduce toxicity, mobility, or volume of contaminated deep
soils and chemicals. Natural hydrolysis, aerobic and anaerobic biodegradation, and sorption, however,
would gradually reduce VOC concentrations in the soil over a long period of time. However, natural
attenuation would not sufficiently reduce VOCs to acceptable levels or adequately protect groundwater
from further degradation.

Short-Term Effectiveness

Because the limited no action alternative would not involve a remedial activity, this screening criterion
is not applicable.

Long-Term Effectiveness and Permanence

The limited no action alternative would not effectively provide long-term human health and the
environmental protection. Releases of chemicals of concern from the deep soil source would continue
and the existing residual risk to human health, safety, public welfare, and to the environment would
continue.

Implementability

A long-term groundwater monitoring program is readily implementable and was included in the cost
analyses for all deep soil operable unit alternatives. Long-term groundwater monitoring will
incorporate the requirements of both operable units.

Cost

The annual O&M for a long-term groundwater monitoring program is being proposed for the deep soil
operable unit (and will include the needs of the shallow soil operable unit). O&M costs are estimated at
$29,000. The capital cost is considered zero. The present worth is $446,000, assuming a 5 percent
interest rate and 30 year period.
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DEEP SOIL ALTERNATIVE NO. 2 - EXCAVATION. OFF-SITE TRANSPORT AND
DISPOSAL/TREATMENT

Description of Deep Soil Alternative No. 2:

The excavation and off-site disposal alternative would involve excavation of contaminated deep soil
from the west part of the old lagoon, placement of excavated soil in haul trucks, transport of soil to an
off-site disposal facility, and disposal of soil in a contained land disposal unit permitted to accept the
waste. The excavation would then be refilled with imported clean fill, as previously discussed. If
implemented, this alternative would require excavation of an estimated 5,000 cu yds. of soil, measured
in-situ. If excavated, the soil could expand to approximately 25 percent to 6,250 cu yds.

The second area of concern is northeast of the building. Following completion of the remedial
investigation in 1993, the agencies conducted additional field testing in an attempt to located former dry
wells reported to have been located northeast of the building. Only one well was found, however
additional wells are suspected to exist and additional sampling will need to be conducted to determine
the exact number and location during the remedial design phase. For the purposes of remediation, it is
estimated that the additional deep soil area of concern northeast of the building has an area of 3,500 sq.
ft. And an average depth of 4 ft. resulting in an in-situ volume of approximately 520 cu yds. An
expansion of 25 percent after excavation will result hi an above-ground volume of 650 cu yds.

The two areas of concern described above are shown hi Figure 1-1 and would total an estimated 5,500
cu yds. of soil in-situ and 6,900 cu yds. of expanded soil after excavation, given the assumptions made.

Excavation of Soil

Excavation can be performed using conventional earthmoving equipment. Backhoes and loaders are
good candidates for excavation of soil down to 20 feet. For example, to excavate the area, a 2 yd3 hoe
size may be used. These hoes have a maximum depth of excavation of 30 feet. Assuming a bucket
capacity of 2 yd3, a cycle time of 3 minutes an average bucket factor of 0.66, 22 cu yd of soil can be
excavated every working hour. This would amount to approximately 176 cu yd of excavation a day.
The total deep soil excavation would require approximately 6 weeks of excavation time. Taking soil
sampling and hazardous waste work into consideration, it would take probably 3 months for the
excavation.

Off-Site Transport

Transport from the site can be performed with haul trucks. A variety of haul trucks are available for
transporting excavated materials and waste drums. Haulers are large, rubber-tired vehicles available as
single-trailer, 2-or 3- axle vehicles, and as double-trailer, multiple-axle haulers. Then: rated haul
capacities range from 1 to 100 tons, and they are available as bottom-dump, rear-dump, and side-dump
vehicles. For costing purposes, a truck of 20 tons was assumed. Soil can be loaded onto haulers using
backhoes, draglines, shovels, or loaders.
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The transportation of hazardous wastes is regulated by the U.S. Department of Transportation, the
USEPA, states, and, in some instances, by local ordinances and codes. In addition, more stringent
federal regulations also govern the transportation and disposal of highly toxic and hazardous materials
such as PCBs and radioactive wastes. Applicable U.S. Department of Transportation regulations
include:

Department of Transportation 49 CFR, Part 172-179
Department of Transportation 49 CFR, Part 1387 (46 CFR 30974, 47073)
Department of Transportation DOT-E 8876.

In general, haul trucks for off-site transport of hazardous wastes must be DOT approved and must
display the proper DOT placard. Contaminated soils can be hauled in box trailers, and drums can be
hauled in box trailers or flat bed trucks. The trucks should be lined with plastic and/or absorbent
materials. Before a vehicle is allowed to leave the site, it should be rinsed or scrubbed to remove
exterior contaminants. Both bulk liquid containers and box trailers should be checked for proper
placarding, cleanliness, tractor-to-trailer hitch, and excess waste levels. Box trailers should be checked
to ensure correct liner installation, secured cover tarpaulin, and locked lift gate.

Off-Site Treatment and Disposal

The off-site disposal facility (landfill) will meet RCRA standards. The RCRA requirements under 40
CFR Part 264 and all associated guidance and regulations are concerned with the proper location,
design, construction, operation, and maintenance of hazardous waste management facilities. These
requirements preclude landfilling in areas of seismic instability, in a 100-year flood-plain, and where
the integrity of the liner system would be adversely affected. Due to land ban requirements, however,
it may not be possible to directly landfill the excavated soils. TCLP tests for inorganics will be
conducted on the deep soils to determine if stabilization is needed prior to disposal. In addition to the
inorganic concentrations, the presence of organics in deep soils may require pretreatment. Some
creosote compound maximum values may trigger a requirement for incineration as the best available
treatment (BAT). A representative deep soil sample hi the lagoon area will be taken to make a final
assessment. The VOC concentrations (first 4 chemicals in the table below) are not a problem in terms
of landfilling, as shown below.
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Maximum Limit beyond which
concentration land filling may not
Chemical level (ppb) be possible Cppb) Waste Code*
1,2-Dichloroethylene 4
1,1,1 -Tr ichloroethane 6
Trichloroethylene
Toluene
Naphthalene
Pentachlorophenol
Phenanthrene
120
2
2,500
4,200
2,850
30,000
6,000
6,000
10,000
5,600
7,400
5,600
U079
U226
U228
U051 (Creosote)
U051 (Creosote)
U051 (Creosote)
U051 (Creosote)
*- Denotes concentrations for land disposal restriction, not waste designation for contaminants found at
the site.

Evaluation of Deep Soil Alternative No. 2

Overall Protection of Human Health and the Environment

The excavation and off-site disposal alternative would be protective of human health and the
environment at the site. Contaminated soil would be removed from the site preventing further potential
for groundwater percolation. Overall protectiveness would be dependent on the integrity of the
receiving landfill and soil treatment, if any, performed at the receiving facility. If no treatment is
employed, toxicity and volume of soils would not be reduced. Treatment by stabilization would
increase volume and decrease mobility, but would not affect toxicity. Mobility at the site would be
eliminated, but long-term mobility reduction would be dependent on the treatment of the soil and the
integrity of the receiving landfill.

Compliance with ARARs

The excavation and off-site disposal alternative could be designed, implemented, and completed to
address all ARARs regarding excavation and transport of hazardous waste. The only significant ARAR
issue associated with the alternative relates to RCRA land disposal stipulations for several compounds.
Deep soils may be classified as F006 or F009 waste, which requires stabilization prior to landfilling.
TCLP tests will be taken to determine if stabilization is required prior to disposal. Concentrations do
not suggest landfilling will be a problem; however, LDRs may be exceeded during remediation since
concentrations are not known for all material proposed to be excavated.

For contaminated soil which is excavated for disposal off-site, a treatability variance for soil and debris
according to Superfund LDR guide 6A could be appropriate in lieu of the treatment standards in 40
CFR Part 268 Subpart D. After treatment, if the soil still contains the constituents of listed waste, it
may be disposed of off-site only hi a Subtitle C landfill. If the contaminants hi the soil have been
treated to below health-based levels, then the soil no longer "contains" the listed waste and need not be
placed in a RCRA landfill.

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Reduction in Toxicity. Mobility, and Volume

The off-site land disposal alternative without treatment offers no reduction in toxicity and volume.
Mobility of the shallow soil contaminants removed from the Parson's Site would obviously be
significantly reduced. Mobility reduction at the receiving facility would be dependent on treatment and
the long-term stability of the facility. If stabilization is used prior to disposal, this would increase the
volume and decrease the mobility.

Short-Term Effectiveness

Potential concerns with excavation, removal, and off-site disposal are associated with worker safety,
short-term impacts, and institutional aspects. Where hazardous chemicals are present, excavation can
pose a substantial risk to worker safety. Short-term impacts such as VOCs and fugitive dust emission
and contaminated run off may also be a concern. Preventive measures can be designed and constructed
to minimize potential effects to human health and the environment during excavation and transport.
Personal protective equipment would be used to protect workers during the action. Dust control
measures would be employed to prevent fugitive emissions from affecting the surrounding population
and environment. Surface water runoff control measures would be used to prevent contaminant
release. Decontamination procedures would be employed to prevent spread of contamination beyond
site boundaries. However, as shown hi the table below, there is minimal risk due to expose from the
shallow soils at the site.

The estimated mean and maximum excess cancer risk due to inhalation for the type of receptors above
are shown hi the table below:

Excess Cancer Risk Associated with Inhalation of
Surface Soils from the Parson's Site

Excess Cancer Risk Associated with Exposure to:
Type of Receptor Mean Soil Concentrations Maximum Soil Concentrations

Adult Residents 1 x lO"6 5 x lO"6
Children 1 x lO"6 2 x 10"6
On-Site Adult Workers 3 x ID"6 1 x 10'5
Construction Workers 6 x 10'7 2 x
The hazard index, which estimates noncarcinogenic effects, is well below one for all types of receptors.
The risk assessment clearly indicates that inhalation of soil is not an important pathway for the .soil
contaminants present under the exposure assumptions made hi the risk analysis for remedial activities.
Therefore, during remediation, deep soils will be the only major driving factor hi development of
health and safety procedures for construction activities.
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Excavations and other construction activity performed on the site as part of future remedial actions will
be done with an approved health and safety plan in effect. The plan should provide for necessary
personnel protection equipment to protect workers. In addition, the plan should provide for air
monitoring at the site to ensure that off-site emissions are not potentially harmful to the public.

Long-Term Effectiveness and Permanence

The off-site disposal alternative would offer significant long-term effectiveness through the removal of
deep soils potentially impacting surface water and creating a direct contact risk at the site. Removal
would eliminate long-term impacts from contaminated soils at the site.

Because wastes would be removed from the site, overall long-term effectiveness would be dependent on
the long-term integrity of the landfill receiving the waste. The alternative would be "permanent" for
the site, but not necessarily permanent for the waste.

If all the RCRA requirements are implemented, disposal of the contaminated soil at a Class I landfill is
expected to be effective long-term.

Implementability

The off-site disposal alternative is easily implementable. No unusual difficulty with excavation,
transport, and disposal is expected. A potential implementability issue is related to the capacity of
off-site facilities to accept soil from the Parson's Site. Before accepting a waste, waste management
facilities will run a series of tests including TCLP to determine if there would be a problem with land
ban requirements.

There are no difficulties identified hi obtaining permits or approvals related to implementation of this
alternative. The off-site facility destination would have to conduct screening tests to determine if the
soils can be accepted at their facility.

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Cost

The estimated capital and present worth cost for excavation of deep soils and disposal in an off-site
disposal facility with treatment is $3,255,000. O&M costs are $29,000 annually for monitoring
groundwater and reporting. Present worth cost is 3,701,000. Cost also includes relocation of City
water main.

DEEP SOIL ALTERNATIVE NO. 3 - SOIL VAPOR EXTRACTION TO REMOVE VOCS

Description of Deep Soil Alternative No. 3:

This alternative involves the installation of a soil vapor extraction system in the 6,625 sq. ft. area on
the west part of the old lagoon, to extract residual VOCs from deep soils.

The conceptual soil vapor extraction system consists of wells placed in the ground above the water
table which force air to flow through pore spaces of unsaturated contaminated soil. The moving air
collects volatile organic vapors. The physical principle underlying the process is the volatility of the
compound of interest. Compounds which are volatile preferentially partition in a soil/water/air system
into the air phase; they will diffuse into the air phase in an attempt to reach an equilibrium. The air
can then be removed and the volatile compounds are collected for disposal. However, based on
technical information, SVE is rarely successful by itself and requires some enhancement to free
contaminants to a vapor phase form for recovery (i.e., in combination with air sparging).

The underground component consists of wells inserted into the contaminated area that extract soil gases
and vapors by employing a blower. Some installations have used additional air injection wells
connected to positive pressure pumps to augment the subsurface air flow. Simple open wells with no
positive pressure are also used. The aboveground support equipment includes a blower, a condenser,
and some technique to manage the extracted gases. Techniques for dealing with the extracted gases
include thermal destruction, activated carbon adsorption, and atmospheric release. Atmospheric release
would not be acceptable because of the proximity of residences to the site. The most common
treatment method is an activated carbon adsorption system.

The components of a vacuum extraction system are relatively simple. The production wells are
installed to the lowest depth of the contaminated vadose zone (20 feet below the ground level), but
above the groundwater table. The wells are slotted in the interval between the water table and the top
of the contaminated soil. The upper portion of the well is sealed. The top of the well is connected to a
blower that draws air up the pipe and forces it through a condenser (to remove water vapor from the
gas stream). The condenser tank holds the condensate and any associated contaminants during an
interim period before disposal. The condensate can be transported off-site for disposal, or treated
on-site using the groundwater pump and treat system, if one is constructed. The VOCs in the gas
stream are adsorbed on the surface of activated carbon.

Vent holes may be sunk to provide increase air flow through the lower levels of the soil, and
monitoring wells may be installed to determine vacuum levels and/or vapor concentrations as a function

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of distance or time. It is also common to cover the ground around the surface of the contamination
zone with plastic to and operated to meet potential action-specific ARARs that include air toxicity
guidelines, hazardous waste treatment guidelines, and treatment of residuals guidelines.

Two wells 40 feet apart with a design flow of 20 cu ft/min each are assumed at this site. The two soil
gas extraction wells would be installed approximately 40 to 60 feet apart at an average depth of 18 feet.
Well material is assumed to be a 3-inch PVC piping that is slotted throughout the bottom 13 feet with a
spacing of 0.06 inches. The two wells would be connected via surface manifold pipes to a single
blower. A vacuum is provided by either a displacement blower or a centrifugal blower. For this type
of soil, a vacuum of 4 inches Hg is recommended at a total design flow of 40 cu ft/min.

Soil vapor extraction of the deep soil will not be subject to RCRA ARARs, but any treatment residue,
such as spent activated carbon, which is generated in capturing the volatiles must be disposed of as a
hazardous waste. Alternatively, spent carbon may be regenerated only in a unit which is in compliance
with RCRA regulations for miscellaneous units, 40 CFR Part 264 Subpart X.

Short-Term Protectiveness

Potential health risks to the community during implementation can be mitigated with proper design and
implementation of actions. The system would be fenced off during implementation, limiting site
access. Precautionary measures may include continuous monitoring of GAC breakthrough, properly
locating and monitoring pipelines that carry condensate, installing instrumentation and warning devices
that alert operations, and establishing an emergency response plan for the handling of hazardous
materials from accidental release.

Long-Term Protectiveness

The VOCs in the deep soil at the Parson's Site are considered a source of VOC contaminant migration
to groundwater. Based on experience at other sites, the soil VOC concentration may be reduced from
70 to 90 percent by soil vapor extraction. The remaining residual VOCs in the deep soil will be a less
significant source of VOCs for future groundwater contamination.

Soil gas extraction will have no effect upon existing groundwater contaminant concentrations. The
removal of VOCs from the deep soil source at the Parson's Site should shorten the time required to
cleanup groundwater, but there is no way to predict by how long. As previously noted, there appears
to be potential source or multiple source groundwater contamination in areas downgradient from the
Parson's Site. The area-wide groundwater problem must be remediated to significantly reduce the
magnitude of residual risk.
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Long-Term Reliability. Soil gas extraction is a short-term action. All of these technical components
are reliable, proven technologies.

Potential of Figure Exposure to Residual Concentrations. The deep soil contamination by definition is
not readily accessible to the public and the potential for future direct exposure to residual
concentrations is minimal. The principal pathway for human exposure is through leaching of the
contaminants from the deep soil into the groundwater and subsequent use of the groundwater for
domestic purposes. This remedial alternative significantly may reduce future risk specifically from the
contaminants at the Parson's Site.

There is the potential for release of contaminants through construction on the property. Deed
restrictions would be necessary to minimize this danger.

Potential air impacts from the site primarily would be from untreated soil gas emissions. The air
emissions (VOCs) would be treated with activated carbon beds. An on-line VOC monitor can be
provided on the carbon bed discharge to provide alarm and shutdown, if a VOC breakthrough occurs.

Future construction involving deep excavation could, of course, expose workers to deep soil
contamination for short periods of time and, in addition, potentially move contaminated soils to the
surface where they could be accessible for long-term human exposure. Deed restrictions would be
necessary on the Parson's property to require that proper precautions are taken during future
construction involving excavation.

Reduction of Toxicity. Mobility, and Volume

The soil gas extraction and treatment concentrates the VOC in the soil gas onto the adsorptive carbon,
thereby reducing volume. Obviously, mobility is also greatly reduced. The toxicity is reduced to the
extent that the condensate is treated and/or the carbon is thermally regenerated. Overall, this
alternative offers reduction in toxicity, mobility and volume of VOCs, however an estimated 10-30% of
the VOCs could potentially remain as a source for further groundwater contamination. Obviously, soil
vapor extraction will not affect metals and non-volatile organics. Groundwater in the vicinity of the
deep soil contamination that is affected by metals and other less mobile contaminants can be extracted
with a well.

Implementability

The system could be readily implementable to remediate deep soils at the Parson's Site. Adequate
space exists to construct the off-gas treatment system and to install all the required piping. Electric
power and other utilities are also available. No unusual difficulty with construction is expected.
However, operations would be impeded by adverse local geological conditions (e.g., clay lenses), soil
moisture content, the Non-Aqueous Phase Liquid (NAPL) located near the lagoon, the sludge seam
located within the lagoon, potential affects from the dry wells, and the presence of the unknown PCE
source(s). SVE was determined to be an unacceptable alternative because it cannot be implemented
38

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with a high degree of certainty for success removal of VOCs or with adequate assurances that the
system could perform over a reasonable period of time based on the factors stated above.

Pretreatment tests are required to establish the final design criteria. Typically, one new extraction well
is drilled, or an existing well is used, that is connected to the vacuum side of a blower. Additional
small diameter monitoring wells are drilled at set distances (e.g., 15 feet and 45 feet) away from the
extraction wells. The monitoring wells measure the radius of influence of the vacuum created and
provide an estimate of future full-scale remediation well spacing. Sampling of vapor emissions from
the well provide an estimate of the rate of VOC removal and what emission controls would be
effective.

Typically it is found that the amount of VOCs removed is initially large but declines fairly rapidly.

Cost

The estimated capital and control cost for Alternative 3 is $706,000, including two years' operation.
Annual O&M costs are estimated at $29,000 and would include long-term groundwater monitoring and
reporting. Present worth costs are $1,152,000.

SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The National Contingency Plan requires evaluation of alternatives based on nine criteria by which
technical, economic, and practical factors associated with each remedial alternative must be judged.
The nine criteria are categorized into three groups: threshold criteria, primary balancing criteria, and
modifying criteria. The nine evaluation criteria are summarized below.

Threshold Criteria must be satisfied in order for an alternative to be eligible for selection. The two
threshold criteria are:

1) Overall Protection of Human Health and the Environment addresses whether a
remedy 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, or institutional controls.

2) Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) addresses whether a remedy will meet all of the ARARs of other Federal
and State environmental laws and/or justifies a waiver.

Primary Balancing Criteria are used to weigh major tradeoffs amongst alternatives. These criteria are:

3) Reduction of Toxicity, Mobility, or Volume through Treatment is the anticipated
performance of the treatment technologies a remedy may employ.

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4) Short-term Effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be posed
during the construction and implementation period until cleanup goals are achieved.

5) Long-term Effectiveness and Permanence refer to expected residual risk and the
ability to a remedy to maintain reliable protection of human health and the
environment over time, after cleanup goals have been met.

6) Implementability is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a particular
option.

7) Cost includes estimated capital and O&M costs, also expressed as net present worth costs.

Modifying Criteria are usually taken into account after public comment is received on the Feasibility
Study report and the Proposed Plan. These criteria are:

8) State/Support Agency Acceptance reflects aspects of the preferred alternative and other
alternatives that the support agency favors or objects to, and any specific comments regarding
State ARARs or the proposed use of waivers.

9) Community Acceptance summarizes the public's general response to the alternatives described in
the Proposed Plan and in the Feasibility Study report based on public comments received.

The nine criteria are compared to each alternative in Tables 1,2, and 3. The major conclusions of the
comparisons are as follows:

SHALLOW SOIL ALTERNATIVES

Overall Protection: because the current and future health risk for shallow soil is so low as to be
acceptable under USEPA and IEPA criteria for the projected site use scenario, the limited no action
alternative offers adequate protection to human health and the environment. The other alternatives
could provide additional protection through excavating or covering contaminated soil. The additional
protection afforded by Alternatives 2,3, and 4 is estimated to be negligible and appears not justifiable.
In contrast, Alternatives 2, 3, and 4, in the short term, may provide a less protective option than
Alternative 1 because they involve months of on-site construction activity and heavy traffic into and out
of the site.

Compliance with ARARs: all alternatives can be implemented to be equally in compliance with
ARARs.

Reduction in TMV (toxicity. mobility, volume'): Alternative No. 2 will reduce toxicity, mobility, and
volume. Alternative No. 4 will only reduce mobility. Toxicity and volume would not be reduced.
Alternative No. 3 would reduce mobility, however toxicity would remain the same and volume would

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 increase.  Alternative No. 1 would not reduce toxicity, mobility, or volume.  Although Alternative 1
 does not provide a reduction in TMV, the advantage of a reduction of TMV in the shallow soil afforded
 by Alternatives 2, 3, and 4 may be considered negligible,  given that the soil presents a low acceptable
 risk.

 Short-term Protectiveness:  Alternatives Nos. 2, 3 and 4 can all be implemented to mitigate potential
 public health risks.  All work at the site would be conducted hi accordance with an approved work
 plan.   Short-term protectiveness is not applicable to Alternative No. 1.

 Long-term Protectiveness:  Alternative No. 2 would provide the most long-term protection since the
 majority of the contaminants would be removed.  The dermal contact risk also would be reduced to
 acceptable levels since a clay or concrete  cover would be provided. Alternative Nos. 3 and 4 would
 basically provide the same protection as long as long-term operation, maintenance and repairs are
 ensured.  The Limited No Action Alternative No. 1 would provide long-term protection if deed and
 zoning restrictions are enforced.  Institutional controls  and deed/zoning restrictions would provide
 adequate long-term protection under the current proposed land use scenario.

 Implementability:  Alternative Nos. 1,2,  and 4 can all be  implemented without  any problems.
 Alternative No. 3 cannot be implemeted within a reasonable degree of certainty  that contaminants
 would be  reduced to acceptable levels. The technology, material, and labor are all available.

 Cost:   Alternative No. 1 is the least costly followed by Alternative No. 4, Alternative No. 3 and
 Alternative No 2. Please refer to Table 2 for detailed capital cost, operation and maintenance, and
 present worth.

 Support Agency Acceptance:  USEPA Region V, the designated support agency for this site,  concurs
 with the Illinois Environmental Protection Agency's recommendation of Alternative No.  1 as the
 preferred  remedy.

 Community Acceptance:  The public has been given the opportunity to review and comment on the
 Remedial  Investigation report, the Feasibility Study report, and the Proposed Plan for this site.  Both a
 public comment period and a formal public hearing were held.  The community  expressed interest  hi
 the proposed remedy at the public hearing with verbal questions and comments.  Please refer to the
 responsiveness summary for details.

                                 DEEP SOIL ALTERNATIVES
Overall Protection:  Alternative No. 2 would provide the maximum protection since contaminants
would be removed from the site.  Alternative No. 3 would reduce the concentration of contaminants in
the deep soil; however, VOCs would only partially be removed and residual VOCs as well as metals,
cyanides and nonvolatile chemicals would remain.  Also, the effectiveness of Alternative 3 would be
significantly reduced based on impediments hi the local geology (e.g., clay lens), soil moisture content,
the NAPL, the sludge seam, potentially from the dry wells, and the presence of the unknown PCE

                                              41

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source(s). Alternative 1 offers the least protection as the potential for migration of VOCs to
groundwater is mitigated only by naturally occurring degradative processes such as biodegradation and
hydrolysis.

Compliance with ARARs: Alternative No. 2 would meet all compliance ARARs. However, soils
would require additional testing before the final disposal option can be fully determined. If
contaminant levels exceed those allowed under the Land Disposal Regulation, the best available
technology for reducing contaminant levels may be required. Alternative No. 3 would reduce VOC
contamination hi the deep soils, however, soil cleanup objectives may not be reached. Alternative No.
1 would not achieve cleanup levels.

Reduction in TMV (toxicity. mobility, volume): Alternative No. 2 would reduce toxicity, mobility,
and volume by removal of the source of contamination. Alternative No. 3 would also reduce the TMV
of the source; however, unacceptable levels of residual contamination could potentially remain.
Alternative No. 1 would not provide any reduction of TMV.

Short-term Protectiveness: Alternative Nos. 2 and 3 do pose a potential risk; however, these risks may
be mitigated with proper design and implementation of the alternative. Alternative No. 1 is not
applicable.

Long-term Protectiveness: Alternative No. 2 provides the best long term protection since the excavated
soil will be placed and managed under a permitted waste disposal facility. Alternative No. 3 would not
provide limited long-term protection against future migration of VOCs, SVOCs and metals into the
groundwater. The No Action Alternative No. 1 would not provide long-term protection.

Implementability: Alternative No. 1 would be the easiest remedy to implement since a monitoring
program is proposed under this alternative. Alternative No. 2 can be easily implemented since waste
disposal facilities are available. Alternative No. 3 cannot be readily implemented successfully.

Cost: Alternative No. 1 is the least expensive alternative, followed by Alternative No. 3 and finally
Alternative No. 2. Please refer to Table 3 for detailed cost estimates.

Support Agency Acceptance: USEPA Region V, the designated support agency for this site, concurs
with the Illinois Environmental Protection Agency's recommendation of Alternative No. 2 as the
selected remedy for the deep soil operable unit.

Community Acceptance: This criteria is the same as the shallow soil alternative criteria.
42

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THE SELECTED REMEDY

Based on consideration of the requirements of CERCLA, the detailed analysis of the alternatives, and
public comments, both IEPA and USEPA Region V have determined that Shallow Soil Alternative No.
1 and Deep Soil Alternative No. 2 are the best remedies for the soil operable units at the Parson's
Casket Hardware Site.

Shallow Soil Alternative No. 1 consists of institutional controls and deed/zoning restrictions.
This remedy includes physical access restriction via upgrade of the existing fence and/or installation of
additional fencing, such as a six-foot high cyclone fence with barbed wire at the top, around the entire
site. The fence will be posted with numerous visual warning signs at appropriate intervals and at other
obvious access areas such as the three entrance gates to inform the public of potential site hazards.

The site's real estate deed will also be amended and local zoning ordinances will be imposed to
maintain the site for industrial use. Prohibition of on-site groundwater use will be restricted.
Construction on-site will include restrictions that require any excavated soils be properly disposed of in
the accordance with the current state and federal regulations.

Deep Soil Alternative No. 2 consists of excavation and disposal of an isolated area of the remaining old
lagoon and dry wells. These areas were not visible during the original remediation conducted by
lEPA's immediate removal action. This deep soil contamination was discovered during the Remedial
Investigation (RI) at the site. The soil will be excavated and disposed of at a land disposal facility
permitted to accept the waste. It is expected that the remediation of the deep soil will affect the
integrity of a watermain that is located at the site. Therefore, the line will be rerouted around the
Parson's Casket Hardware Site. The proposed route is acceptable with the City of Belvidere.

The selected final remedies for this site are the same preferred alternatives presented in the Proposed
Plan that were recently presented to the public. Details of the components of the remedy may be
altered as a result of the remedial design, construction, long-term remedial action phases, and any
modifications.

Statutory Determinations

The selected remedy must satisfy the requirements of Section 121 of CERCLA to protect human health
and the environment; comply with ARARs; be cost effective; utilize permanent solutions and alternate
treatment technologies to the maximum extent practicable; and satisfy the preference for treatment as a
principle element of the remedy.

Protection of Human Health and the Environment

Implementation of the selected remedies will eliminate, reduce, and control potential risk to human
health from exposure to contaminated groundwater and soils through institutional controls and
treatment technologies. The remedy will reduce risk to within the acceptable range of 1 x 10-4 to 1 x
10-6 excess cancer risk and the hazard indices for noncarcinogens will be less than one. The selected

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remedy will also provide environmental protection from potential risks posed by contaminants
discharging to groundwater, soils, and the ambient air.

No unacceptable short-term risk or cross-media impacts will be caused by implementation of the
selected remedy.

Compliance with ARARs

With respect to any hazardous substances, pollutants, or contaminants that will remain on site, Section
121(2)(A) of CERCLA requires the USEPA to select a remedial action which complies with legally
applicable or relevant and appropriate standards, requirements, criteria or limitations (ARARs). The
selected remedy will comply with Federal ARARs or State ARARs where State ARARs are more
stringent, as determined by USEPA. No ARAR waivers will be invoked. The remedy will be
implemented in compliance with applicable provisions of CERCLA and the NCP.

Only the substantive requirements of ARARs apply to on-site activities. Federal program requirements
which are implemented under a delegated State program are ARARs only to the extent they include
requirements not incorporated into State regulations; the State regulations are the primary ARARs.

Chemical-Specific ARARs: Chemical-specific ARARs regulate the release to the environment of
specific substances having certain chemical characteristics. Chemical-specific ARARs typically define
the extent of cleanup at a site.

• Safe Drinking Water Act (SDWA) National Primary Drinking Water Standards (40 CFR 141),
MCLs are applicable; proposed MCLs are to be considered.

• Safe Drinking Water Act (SDWA) National Primary Drinking Water Standards (40 CFR 143) non-
zero MCLGs and non-zero proposed MCLGs are applicable or relevant and appropriate.

• Federal Water Pollution Control Act (also known as the Clean Water Act~CWA) (40 CFR 122,
125, 129, 131), ambient water quality criteria and NPDES program in water runoff, and
groundwater; delegated NPDES program in Illinois is implemented at 35 Illinois Administrative
Code 302, 304, and 309.

• Identification and Listing of Hazardous Waste (40 CFR Part 261.4), waste must be characterized by
TCLP testing during remedial design/remedial action to determine regulatory classification. This
requirement is applicable if the waste is determined to be characteristically hazardous. This
requirement would be relevant and appropriate if the waste are similar to listed or characteristically
hazardous waste.

• Releases from Solid Waste Management Units (40 CFR Part 264 Subpart F), This requirement is
applicable to releases of contaminants. Concentrations are identical to MCLs.
44

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• Illinois Groundwater Quality Standards (35 Illinois Administrative Code- IAC 620.410) are
applicable for groundwater standards.

Location-Specific ARARs: Location-specific ARARs are those requirements that relate to the
geographic location of site.

• None identified.

Action-Specific ARARs: Action-specific ARARs are requirements that define acceptable treatment and
disposal procedures for hazardous substances.

• National Primary and Secondary Ambient Air Quality (40 CFR Part 50), This requirement is
applicable for alternatives emitting regulated pollutants.

• Resource Conservation and Recovery Act (RCRA) (40 CFR 261) is applicable for definition and
identification of hazardous wastes; delegated program hi Illinois is implemented at 35 Illinois
Administrative Code 721.

• Resource Conservation and Recovery Act (RCRA) (40 CFR 262) is applicable for generators of
hazardous wastes if materials are disposed off site. This requirement is relevant and appropriate
for waste not characterized as hazardous, because, at a minimum, the waste is being considered a
special waste. The delegated program hi Illinois is implemented at 35 Illinois Administrative Code
722.

• Resource Conservation and Recovery Act (RCRA) (40 CFR 264 Subpart B) is applicable for
general facility standards; delegated program hi Illinois is implemented at 35 Illinois Administrative
Code 724 Subpart B.

• Resource Conservation and Recovery Act (RCRA) (40 CFR 264 Subpart D) is applicable for
contingency planning; delegated program hi Illinois is implemented at 35 Illinois Administrative
Code 724 Subpart B.

• Resource Conservation and Recovery Act (RCRA) (40 CFR 264 Subpart F), is applicable for
groundwater monitoring; delegated program hi Illinois is implemented at Illinois Administrative
Code 724 Subpart F.

• Resource Conservation and Recovery Act (RCRA) (40 CFR 264 Subpart G), This requirement is
applicable. This requirement is also relevant and appropriate since contaminants will be left in
place; delegated program hi Illinois is implemented at 35 Illinois Administrative Code 724 and 725.
35 Illinois Administrative Code 811 and 807 are relevant and appropriate for closure and post-
closure requirements, because, at a mhumum, the waste is being considered a special waste.
45

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 •   Resource Conservation and Recovery Act (RCRA) (40 CFR 264 Subpart I), This requirement
    would be applicable is the waste is determined to be characteristically hazardous.  The requirement
    is also relevant and appropriate because waste will be considered, at a minimum, a special waste.

 •   Resource Conservation and Recovery Act (RCRA) (40 CFR 264 Subpart K), this requirement is
    relevant and appropriate because the alternative involves the removal of a former lagoon
    impoundment; delegated program  in Illinois is implemented at 35 Illinois Administrative Code 728.

 •   Resource Conservation and Recovery Act (RCRA) (40 CFR Part 268), This requirement is
    applicable for land disposal restrictions relative to disposal of waste from the site.

 •   Illinois Groundwater Quality Standards (35 Illinois Administrative Cod 620 Subpart E) are
    applicable for groundwater monitoring.

 •   Illinois Solid Waste and Special Waste Handling Regulations (35 Illinois Administrative Code 808
    and 35 Illinois Administrative Code 809) are applicable for off site special waste hauling.

 •   Illinois Water Well Construction Code (77 Illinois Administrative Code 920) is applicable for the
    construction and abandonment of  monitoring wells.

 To Be Considered  (TBCs) are included in the discussion of ARARs: however, TBCs are not ARARs,
 but they may be used to design a remedy or set cleanup levels in no ARARs address the site, or
 existing ARARs do not ensure protectiveness. TBCs may include advisories and guidance.

 Cost Effectiveness

 Cost effectiveness is determined by evaluating the overall effectiveness proportionate to costs, such that
 the selected remedy represents a reasonable value for the money to be spent. The estimated net present
 worth value of the  selected remedy for the shallow soil Alternative #1 is the 10 times  less expensive
 than the next highest Alternative.  Alternative #2 for the deep soils is the most expensive alternative,
 yet the selected remedy will be the alternative most effective in the long term due to a significant
 reduction in the mobility, toxicity, and volume of on-site contamination. Alternative #2 provides  a
 high degree of certainty that hazards posed by contamination at the site will eliminate or reduced to
 within acceptable levels. Therefore, it was determined that the additional costs were acceptable.

 Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery
 Technologies to the Maximum Extent Practicable

The selected remedies meet the statutory requirement to utilize permanent solutions and treatment
technologies to the maximum extent practicable in a cost-effective manner. Of those alternatives that
are protective of human health and the environment and comply with ARARs, IEPA and USEPA have
determined that the selected remedies provide the best balance of tradeoffs hi terms of long-term
                                              46

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effectiveness and permanence; reduction in toxicity, mobility, or volume achieved through excavation
and removal; short term effectiveness; implemetability; and cost while considering the statutory
preference for treatment

Preference for Treatment as a Principal Element

The risk associated with the shallow soil operable unit did not warrant treatment is taken for property
which has been, and will be, utilized hi an industrial setting.

The selected remedy for the deep soil operable unit addresses a principal threat posed by the site
through excavation and removal to reduce contaminant levels to within an acceptable range. All
treatment technologies were evaluated and ultimately repudiated based on site specific conditions,
which were unsuitable for any of the technologies to be utilized at the site. Therefore, it was
determined by the Illinois EPA and USEPA that excavation and removal was the best technology too
adequately remediate the site for protection of human health and the environment.

Documentation of Significant Changes

The Proposed Plan for the Parson's Casket Hardware Superfund site was issued for public comment on
July 17, 1996.  The Proposed Plan identified Alternative #1 and Alternative #2 as the preferred
alternative for the shallow soil and deep soil operable units, respectively. The public comment period
ended August 15, 1996.

The Agency reviewed all public questions and comments presented at the August 7, 1996 public
hearing and all written comments received during the public comment period (see Responsiveness
Summary).  Illinois EPA and USEPA determined that no significant changes to the remedies selected,
as identified hi the Proposed Plan, are necessary.
                                              47

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Chemical Specific Federal and State ARARs
 Standard,
 Requirement Criteria,
 or Limitation
 Citation
 Description
Applicable/
Relevant and
Appropriate*
Comments
 Identification and
 Listing of Hazardous
 Waste
 40 CFR Part 261.4
 Releases from Solid
 Waste Management
 Units
 Safe Drinking Water
 Act
 40 CFR Part 264
 Subpart F
 40 U.S.C. 300
National Primary
Drinking Water
Standards
Clean Water Act
Groundwater Quality
40C.F.R. Part 141
40 C.F.R. 122, 125,
129,131
Title 35, Env. Prot.
Act, Subtitle F, Public
Water Supplies IAC
620.105-620.615
 Defines those solid waastes which   Yes/Yes
 are subject to regulation as
 hazardous wastes.
 Establishes mazimum              Yes
 contaminant concentrations that
 can be released from hazardous
 waste units in Part 264, Subpart F.
 Maximum Contaminant Levels      Yes
 (MCLs) and non-zero Maximum
 Contaminant Level Goals
 (MCLGs) - Enforceable standards
 establishing maximum
 permissible levels of
 contaminants in drinking water
 from a public water system
Establishes health-based standards   Yes
for public water systems
(maximum contaminant levels)
Provides federal, state and local     Yes
discharge for the control of
discharges of pollutants to
navigable waters

Part 620 describes various aspects   Yes
of ground water quality, including
method of classification of
groundwater, nondegradation
provisions and various procedures
and protocols for the management
and protectionof groundwaters.
Groundwater qualtity standards
are defined.
                 If wastes are listed or
                 characterisitc wastes, then SWDA
                 requirements are applicable. If
                 wastes are similar to listed or
                 characterisic wastes, the SWDA
                 requirements would be relevant
                 and appropriate.

                 The maximum contaminant
                 concentrations that can be
                 released are identical to the
                 MCLs.
                 Pertains to drinking water
                 standards
                 Federally enforceable drinking
                 water standards
                 Applicable to the waters of
                 Illinois
                 Groundwater Quality
                                                                49

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Action-Specific Federal ARARs
the following discussion applies only to on-site activities
  Standard,
  Requirement Criteria,
  or Limitation
 Citation
 Description
 Applicable/
 Relevant and
 Appropriate*
 Comments
 Releases from Solid
 Waste Management
 Units
 40 CFR Part 264,
 Subpart F
                                   Yes/Yes
 Closure and Post-
 Closure
 Subpart G
 Use and Management    Subpart I
 of Containers
                                  Yes/Yes
                                                         Yes/Yes
 Surface
 Impoundments

 Land Disposal
 Subpart K
40 CFR Part 268
Establishes a timetable for
restriction of land disposal of
wastes and other hazardous
materials.
No/Yes


Yes
Motional Primary and
Secondary Ambient
Air Quality
40 CFR Part 50
Establishes National Ambient Air    Yes
Quality Standars (NAAQS) for
ambient air to protect public
health and welfare.
 Applicable if hazardous waste
 remains on-site. This Subpart
 establishes standards for
 groundwater monitoring and
 procedures for corrective action if
 releases do occur.  If waste is
 completely treated or removed,
 regulations are relevant and
 appropriate only because on-site
 releases are not anticipated.

 Establishes requirements for site
 closures (if closure is in question)
 including placement and
 maintenance  of a cap.

 Applicable if the alternative
 involves storage of hazardous
 materials in containers.  Is still
 relevant and appropriate because
 the waste will be considered, at a
 minimum,  a special waste.

 Alternative involves the removal
 of a former surface impoundment

 Applicable if an alternative
 involves off-site or on-site
 disposal of contaminated soils.
 However, for on-site disposal
 actions, based upon the criteria set
 forth in the Federal Register dated
 February 16,  1993, a Correction
 Action Management Unit may be
 designated by USEPA, which
 could utilize somewhat less
 restrictive requirements than the
 land disposal  regulations and the
minimum technology
requirements.

Primary standards applicable for
any alternative emitting regulated
polluntants.
                                                                 50

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Action-Specific Federal and State ARARs
the following discussion applies only to on-site activities
Standard,
Requirement Criteria,
or Limitation
Citation
Description
Applicable/
Relevant and
Appropriate'
Comments
Standards Applicable 40 CFR 262
to Generators of
Hazardous Waste

Standards for Owners 40 CFR 264
and Operators of
Hazardous Waste
Treatment, Storage,
and Disposal
Facilities
Hazardous Waste
Management
Title 35 Env. Prot.
Act Subtitle G: Waste
Disposal
35IAC724.101-.451,
Establishes standards for
generators of hazardous waste in
general.

Establishes minimum national
standards which define the
acceptable management of
hazardous waste for owners and
operators of facilities which treat,
store, or dispose of hazardous
waste.

Mgt. of hazardous waste in
relation to RCRA. State of
Illinois rules generally parallel
Fed. EPA rules.
Yes
Yes/Yes
No/Yes
Generator
Requirements

Landfill Closure and
Post-Closure
Requirements
35 IAC 722
Title 35 Env. Prot.
Act, Subpart G
35 IAC 724.211.219
Requirements for generators of
hazardous waste
Closure and Post-Closure
Requirements for Landfills
Treatment of Waste in 35 IAC 724, Subpart J Specifies requirements for
Tanks treatment of waste in tanks.
Placement of Waste in 35 IAC 724, Subpart
Piles L
Specifies requirements for
management of waste piles
Yes
No/Yes
Yes
Yes/Yes
Special Waste
riauling
.and Disposal
Restrictions
Title 35 Env. Prot.
Act Subtitle G. Waste
Disposal 35 IAC
809.101-.802

35 IAC 728
Applies to all hauling of special
wastes - (also review IDOT
requirements).

Specifies which wastes may not
be disposed of on land.
Yes
Yes
These regulation are all applicable
once a medium is identified as
"hazardous".

These requirements are applicable
or relevant and appropriate
depending on the nature of the
wastes, or the type of activity
(i.e., treatment, storage, or
disposal) proposed.

May not be applicable to NPL,
CERCLA, but are relevant and
appropriate dependent upon
technology and design of RA.
The State of IL should determine
status of RCRA/CERCLA
interface during screening of
Remedial Technology.

If excavated soils are determined
to be characteristically hazardous,
then this requirement is applicable

This requirement is relevant and
appropriate.
Applicable where soils
stabilization is proposed ex-situ.

Applicable to RA where
excavated soils are determined to
be characteristically hazardous
and placed in waste piles prior to
treatment. Relevant and
appropriate because, at a
minimum, the excavated soils will
be considered a special waste.

Applicable because, at a
minimum, the excavated material
is being considered a special
waste.

Where excavated soils are
determined to be characteristically
hazardous, this requirement is
applicable.
51

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Location- Specific Federal ARARs
 Standard,
 Requirement Criteria,
 or Limitation
 Citation
 Description
Applicable/
Relevant and
Appropriate*
Comments
 National Historic
 Preservation Act
 Archeological and
 Historic Preservation
 Act
 Historic Sites,
 Buildings, and
 Antiquities Act
 Fish and Wildlife
 Coordination Act
Endangered Species
Act
 16 USC 470
 40 CFR 6.301(b)
 36 CFR Part 800
 16 USC 469
 40 CFR 6301©
 15 USC 461-467
 40 CFR 6.301 (a)
 16 USC 661-666
Clean Water Act
16 USC 1531
50 CFR Part 200
50 CFR Part 402
33 USC 1251-1376
 Requires federal agencies to take     No/No
 into account the effect of any
 federally-assisted undertaking or
 licensing on any district, site,
 building, structure, or object that
 is included in or eligible for the
 inclusion in the National Register
 of Historic Places.

 Establishes procedures to provide    No/No
 for preservation of historical and
 archaeological data which might
 be destroyed through alteration of
 terrain as a result of a federal
 construction project or a federally
 licensed activity or program.

 Requires federal agencies to         No/No
 consider the existence and
 location of landmarks on the
 National Registry of Natural
 Landmarks to avoid undesirable
 impacts on such landmarks.

 Requires consultation when          No/No
 federal department or agency
 proposes or authorizes any stream
 or other water body and  adequate
 provision for protection  offish
 and wildlife resources.

 Requires action to conserve         No/No
 endangered species within critical
 habitats upon which endangered
 species depend, includes
 consultation with Department of
 Interior

Provides federal, state and local      Yes
discharge for the control of
discharges of pollutants to
navigable waters.
                  The remedy does not affect any
                  district, site, building, structure,
                  or object listed or eligible for the
                  National Register.
                  The remedy does not affect
                  historical or archaeological data.
                 The remedy does not affect any
                 Natural Landmark.
                 It is unlikely that the alternatives
                 will involve any modifications of
                 nearby streams.
                 No endangered species were
                 found on the site.
                 Applicable to the waters of
                 Illinois.
                                                                  52

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Location-Specific Federal ARARs
 Standard,
 Requirement Criteria,
 or Limitation
 Citation
 Description
Applicable/
Relevant and
Appropriate*
                                                                           Comments
 Dredge or Fill
 Requirements
 (Section 404)
 Rivers and Harbors
 Act of 1899

 Section 10 Permit
 Executive Order on
 Protection of
 Wetlands
 Executive Order on
 Floodplain
 Management
 Wilderness Act
National Wildlife
Refuge System

Scenic River Act
Coastal Zone
Management Act
 40 CFR Parts 230,       Requires permits for discharge of   No/No
 231                    dredged or fill material into
                        navigable water.
 33 USC 403            Gives authority to states over       No/No
                       rivers and harbors

 33 CFR Parts 320-330   Requires permit fro structures or     No/No
                       work in or affecting navigable
                       waters
 Exec. Order No.
 11,990
 40 CFR 6.0302(a) and
 Appendix A
Exec. Order No.
11,988
16 USC 1131
50 CFR 35.1
16USC668
50 CFR Part 27

16 USC 1271
40 CFR 6.302(e)

16 USC 1451
Requires federal agencies to avoid   No/No
to the extent possible, the adverse
impacts associated with the
destruction or loss of wetlands
and to avoid support of new
construction in wetlands if a
practical alternative exists.

Requires federal agencies to        No/No
evaluate the potential effects of
actions they may take in a
floodplain to avoid the adverse
impacts associated with direct and
indirect development of a
floodplain.

Administer federally-owned        No/No
wilderness area to ensure it is left
unimpacted.

Restricts activities within a          No/No
National Wildlife Refuge

Prohibits adverse effects on scenic    No/No
rivers.

Conduct activities in accordance     No/No
with state-approved management
program.
                  There will be no discharge of
                  dredged or fill material into
                  navigable waters as part of the
                  remediation.

                  No rivers or harbors are potential
                  receptors.

                  The remedy does not involve
                  construction in or affecting
                  navigable waters.

                  No alternative involves any
                  modifications or loss of wetlands.
                 This site is not within a 100-year
                 floodplain.
                 There are no wilderness areas on-
                 site or adjacent to the site.
                 There are no wildlife refuges on-
                 site or adjacent to the site.

                 No scenic rivers in the area.
                 Area is not a coastal zone.
                                                                 53

-------
Location-Specific State ARARs
Standard,
Requirement Criteria,
or Limitation
Citation
Description
Applicable/
Relevant and
Appropriate*
Comments
Public Hearing
Advertisement and
Timing Requirements
Public Hearing
Requirements
Facility Siting
Information
Seismic Standards
Facility Location
Title 35, Env. Prot.
Act Subtitle A. Gen.
Prov. Part 166,
Procedures for Public
Hearings. 166.120,35
IAC Part 166.130,
166.191,35 IAC Part
725
35 IAC 168
35 IAC 168
35 IAC 166
35 IAC 166
35 IAC 166
35 IAC 703.184
35 IAC 724.118
35 IAC 811.102, .302
Notice shall be published once Yes
weekly for 3 consecutive weeks,
with the first notice given at least
45 days prior to the date of the
hearing. The hearing in the State
of II shall be presided over by the
"Hearing Officer" on State Lead
NPL Projects. A verbatim record,
transcript of the legal proceedings
will be taken. The hearing record
shall be closed 30 days after the
date of the hearing. A
responsiveness summary shall be
prepared by IEPA.

Air Permit Requirements Yes
Wastewater Permit Requirements
RCRA Permits
NPDES Permit Hearings
Sanitary Landfill and Closure
Plan Informational Hearing

Defines information required on No/No
location with respect to geology
and hydrogeology.

Specifies seismic requirements for No/Yes
construction of hazardous waste
facilities

Describes location requirements No/Yes
and restrictions for siting
hazardous waste facilities
No permits are required for on-
site activities under CERCLA.
But, requirements for public
hearings are applicable.
No permits are required for on-
site activities under CERCLA.
But requirements for public
hearings will be applicable.
This is not an ARAR as it is
entirely administrative.

This requirement is relevant and
appropriate.

This requirement is relevant and
appropriate.
* - Once the question "Is this regulation applicable?" is answered "Yes," the question "Is this regulation relevant and appropriate?" does not apply.
However, the waste at Parson's will be characterized for classification as hazardous or not hazardous during the remedial design/remedial action
(RD/RA) phase. Therefore, in some ARAR evaluations the criteria will be applicable if the waste is determined to be hazardous. If the waste is
determined not to be hazardous, the criteria would still be relevant and appropriate, thus the "Yes/Yes" designation.
54

-------
 To Be Considered (TBCs)
  Standard,
  Requirement Criteria,
  or Limitation
Citation
Description
Applicable/
Relevant and
Appropriate*
                                                                                                   Comments
  1-Day Health           USEPA Office of       Nonenforceable concentrations of   TBC
  Advisory               Drinking Water         drinking water contaminants that
                                                are not expected to cause
                                                noncarcinogenic adverse health
                                                effects over a 1-day exposure
                                                duration.

  10-Day Health          USEPA Office of       Nonenforceable concentrations of   TBC
  Advisory               Drinking Water         drinking water contaminants that
                                                are not expected to cause
                                                noncarcinogenic adverse health
                                                effects over a 10-day exposure
                                                duration.

  Long-Term Health       USEPA Office of       Nonenforceable concentrations of   TBC
  Advisory               Drinking Water         drinking water contaminants that
                                                are not expected to cause
                                                noncarcinogenic adverse health
                                                effects over a 7-year (or 10% of
                                                an individual lifetime) exposure
                                                duration.

  Lifetime Health          USEPA Office of        Nonenforceable concentrations of   TBC
  Advisory               Drinking Water         drinking water contaminants that
                                                are not expected to cause
                                                noncarcinogenic adverse health
                                                effects over a lifetime exposure.
                                                                          The advisory is protective for a
                                                                          10-kg child; therefore, also
                                                                          protective for adults.
                                                                          The advisory level is protective
                                                                          for a 10-kg child; therefore, also
                                                                          protective for adults.
                                                                          The longer term advisory level is
                                                                          for a 10-kg child. Additional
                                                                          advisory levels are available for a
                                                                          70-kg adult.
                                                                          Lifetime health advisories are not
                                                                          recommended for any of the
                                                                          chemicals classified as known or
                                                                          probable human carcinogens; and
                                                                          for certain chemicals classified as
                                                                          possible human carcinogens.
# - To Be Considered (TBCs) criteria are included, however, TBCs are not ARARs, but they may be used to design a remedy or set cleanup levels if no
  ARARs address the site, or if existing ARARs do not ensure protectiveness. TBCs may include advisories or guidance.
                                                                  57

-------

-------
    foil conluniiuliun

    lUltnl olileep
    joil contuiiiniUon

•   htvlouily ttcmictlioil


 |   I'itlCIIIUltl

 JL  Moniloiint well
Wilct lint

Silt UounJuy
                                                                                        DKMt'.SDII.
                                                                                        CONTAMINATION
                                                                                        AltlCAS
                                                                                     LOCATION OK DI'KI' SOIL AND
                                                                                     .SHALLOW .SOIL CONTAMINATION

-------

     Mux. aounary
       Of Leg orin
  Qis-Ccstinq
?.-—M-ltins Wetcis
     Operoxioris
 i
               Scale In  rest
   TOO
Source: 1EPA Files 1331
       TOO
200
                                   LEGEND

                                       Stained Surface Soil
	  jf^pproximate location
          of water main
	   Known location of
          water main
         Figure 1-2. Summary of Historical Site Conditions (1937
                        to 1984), Parson's Casket Hardware
                            Site, Belvidere,  Illinois

-------
LECEIIO
   SHE WLWUA»
   Ult« (UK
 . UXttA tUW CXJlCt LKAtlW \JtXMt
                  "
   FIGURE  2-1.  SOIL  SAMPLING  GRID AND SAMPLING
                  •   LOCATIONS
PARSONS'S  CASKET HARDWARE SITE, BELVIDERE,  ILLINOIS

-------
 LEGEIig
    ME10CIEA
 •—  rtitt

 LI—  inta L>€
-u -  urn* Lue'ttxAci LOCXIIW uwtvnt
- - SHE SOLKVAt
   urns
  ii
emu
                                                                    \
                                                                                                  /
                                          /
                                            «	l«
                                                                       \
                                                                         N
                                                                            cmo
                                                                            cn?4\
                                                                                 \
                                                                                    \
                                                                                      \
                                                                               X
1 \
Ml IUAJJMC UJUJH %
lit"
OIMS Nil
ILV_ SL_ ±_ ,
"~XJ - —
_L
rj
o
                                                                                      CI7IL
                                  Il-J
                             \,_i	
                               In
                               i
                                g;j
                                                                                        KJUlllHi,!;
                                                                                    0J
                                                                    -1GURE  2-2. MONITORING WELL  LOCATIONS
                                                            PARSON'S CASKET  HARDWARE  SITE, DELVIDERE, ILLINOIS

-------
X.
g
lil
g   § g 5 i
§  S I s 3 5
  UJ
  LU
1 ! 1
Z
b
1 1 1
en
en
en
o
**•*
CJ
, ,
5

2:
o
<
CJ
o
_l
_;
1
n

UJ
e:

o
ut


S.
1 1 1
MJ
r~[

>
	 1
1 1 1
-r^

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in

UJ
<
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a
Ci
<
UJ
\£
in
<
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in
:z.
O
01
T^'
<
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                                           r

-------
Geologic Units:
             (Unit 6) Very dark brown to black clayey silt


             (Unit 5) Yellowish brown sand and gravel (shallow unit)


             (Unit 4) Still, dense, clayey sill with inlerbedded sandy sill, sand and clay


              (Unil 3) Yellowish brown sand and gravel (deep unll)


              (Unil 2) Pinkish grey to pale brown silly sand with some gravel  (glacial till
              (Unll 1) Yellowish brown Iraclured dolomite, moderately weathered surlace
              Dolomite; Qalena-Plalteville Group
              Fill material, gravelly clay
               Fill malarial, brick and concrete mixed with sand and sill
               Fill materials, sill
Wollu:
 I
                                                                                             JT_
llenlonile Seal
        Well Screen
        Static waler level ol
        deep alluvial well:;
        on 12/03/30

        Slallc water level ol
         shallow alluvial welly
        on 12/03/90
                                                                                             Datum: Sea Level
             Figure 3- 1.   Legend tor Cross Sections A-A' - 1ML'; Parson's Casket Hardware Silo; llclvedm-, lloone Co., Illinois.

-------
                     Elevation (MSL)
c
as
CS
r.
h H - HH  "i*
                                       G123D
                                      WPT23A
                                           03
                                        Cross Section BB'
                                      GttSS
                                      G115D
                                      G175B
                                      G115BD
                                      G12QD
            mc^^m  i
                                      GT21D

-------
B South
Norlh LI'
                                                                                                                                   (705.4) (708.4

                                                                                                                                       Q
                                                                  LOOKING WEST
                                                                                                                                              loo
                                                                                                                                              .)
                                                                                                                               Pool II . !)V
                      Figure 3- 4.   GeoluKlc Cross Seclltm \\-\\'\ I'ltrsoiu Ciuktl Itnrtlware Silt; Ih'lvcdm, lloone Co., Illinois

-------
                                                           Soulh IHasl C'
     o o
                                w a
                                w w
                                *- *-
                                C3 O
                                                OT R
                                                co w

                                                5 5
•, 700-
 770-
    if
_   a
-I 7GO - -<£
  730-
                                        »i"tf
                                          •a
                                      k^Mi-
                                     >4V
                                          J^'.
                                       f."^ T i
                                                   »000
                                                 nr^.
                                                               I) ••£>••'
                                                               I' ' it
                                                                I)

                                                                •o,:,
                                                       Jd ••;/>.•• -a c
                                                       KC-..°-M^c|
                                                                ,0
                                                              •mP-
                                     I  . I
                                            J_Z1_._]	I
                              LOOKING
                                                         l:oul
             Figure 3- 5. Gcolofilc Cross Sections C-C'; I'arson's Casket llnrtlwnrc Sllc; llclvederc, tloniic Co., Illinois.

-------
  D Wosl
     North Ea:;l 0'
700-
                                                                                                      - 71)0
770-
7GO-
 7GO-

                                                                    j^^^^j^p^jV.' t^ ' ouo | O-
                                                                         iz~cziz.zizzir::i:
                                                        1~7-|     III    1~  I     I
                                                   .rrz:
 7-10
                                              LOOKING NORTH
    !H)         100
	J		_..)

 Tool 11 ^ ^V
                   Figure 3- 6.  Cicolofile Cross Sections U-U'; Pursuit's Casket llnnlware Site; lltlvedere, lloone Co., Illinois.

-------
   EWest
                                                                                                              East IE1
700-
770-
                                                                                                                      7UO
                                                 LOOKING NORTHWEST
                                                                                        0
                                                                                        l	
J50
    100
		I
              Fi|jiift 3-  1.   Ocolo|{lc Cross Sections K-K'; rsirson's Cnxkol Iliirdwni-e Kile; llelvetlti-t, lloonc Co., Illinois.

-------
     LEGEND
          S3   COHCBI1IUTIOH lug/U
              HOHItcmiC WELL
              COIITOJt Lilt
              Duhtil *hut i|i|>ioxlnult.
(  I hCWB CULtXllUtlOH
   IS EStlHUCU
   C«CCMI(U.1iai BCLOU LAD
   tGICCtlOW LIMIT
                                                                                  U   59      ,—,    V    *
                                                                                  <-.——cri	4	1/—	^<|-
                                                                             	_/\~  — '	' 	 	 ^      I V-
                                                                             ~  /^vN-T"      h-t
                                                                                                                                    •.(•.
                                                                                 FIGURE 1-7   Contour Plot  of  TCtE  ConconlrnlloM!!  In  l)oo|>
                                                                                            Ooop  Altuvlnl  Aciull'iir, IJiicunil)iir  l!J!)t).
                                                                                  Piirson's  Cuskol  l-ltirdwufb  Silo,  Oolvlduro,  llllnolii

-------

-------
                                                                                           -*;  22-7
             1,1,1,2 -TEC A
  F^NT
PCE
1,2.
   •3  -T^
                     1,1,1 -TCA
                                        :is-1,2-DCE
Trans -1,2 - DCE
5
_fc.
vc
                                             1,1-:
      CA
      Cr
      C3S-1,2-DCE
      CO2
      CT
      1,1 -DCA
      1,1-OCE
                                             KEY:
        Chioraethene
        Chloroform
        CIS - 1,2 - Dichioroethytene
        Carbon Dioxids
        Carbon Tetrachloride
        1,1 - Dichloroelhene
        1 ,1 - Dichtorocthytene
      trans -1,2 - DCE   Trans -1,2 - Dictitoroethytene
PCA
PCE
T ,1 ,1 ,2 - PCE
1,1,1-TCA
TCE
1,1,2,2-TECA
VC
Water
P«n;achtorDa:r.ane
T«trachloroa:r,ytene
1 . 1 . 1 ,2 - Ta:ra=tiioroeihyter,e
1.1.1 - Trichiorosihane
Trichloraethytena
1.1,2,2 - Tetrarhtoroethyter^
Vinyl Chioride
 REFERENCE

 (1) McCany (1935)
 (2) Vog«! & WcCarty (1987)
 (3) Kiocperetal(1985)
 (4) Parson etal (1984)
 (5) 3arrio-Lage eta! (1935)
 (6) Cooper etal (1987)
 (7) Vog«l«tal(1987)
 (3) Wood etal (1935)
                         MECHANISM

                          Biodegrariation
                        Abiotic Elimination
                          Siodegradation
                 NOTES

                 Major pathway ior i3io:ic
                 transforma:ion
                 Minor Pathway
              a  Cis 1,2-DCE generated a:
                 approximately 30 times Itva
                 concentration of trans - 1.2-DCE
                 (3) and by a factor of 25:1 (3)
   Figure 5-1. Potential Reaction Pathways for Organic Compounds in the Subsurfaces Environment

-------
SUMMARY Or CONTAMINA.NTS FOUND IN SURFACE SOILS
. - . . _v-/ .
Chemical
INORGANICS
Antimony
Arsenic
Barium
Ben-Ilium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Nickel
Selenium
Silver
Vanadium
Zinc
Cyanide
ORGAN1CS
Acetone
Acenaphihene
Acenaphthylene
Anthracene
Benzene
Benzo(A)anihracene
Benzo(b)fluoranthene
Benzo(k)fluoramhene
Benzo(g,hJ)perylene
Benzo(a)pyrene
Bis(2-ethyihexyl)phthaiais
Chloroform
Chrysene
Dibenzo(aji )anthracene
Dibenzofuian
Di-n-buryl phthaiats
Huoianthene
Huorcne
Indeno(lJZ3-cd)pyrene
Methylene Chloride
2-Methytaaphthalene
Naphthalene
Phenanthrcne
Pyrcne
Tetrachlorocihylene
Toluene
1 , 1 , 1 -Trichloroeihane
TrichJoroeihylcne
Mean Concensaiion in
Surface Soils (ing/Kg)

4.3
6.1
102
0.5
1.7
•74
6.9
1125
106
4SS
160

8.5
25
748
6.7

0.01
0.07
0.12
OJZO
0.0008
0.64
0.76
0.42
0.48
0.59
0.68
0.003
0.68
0.22
0.11
0^9
0.86
0.11
0.52
0.029
0^6
0.18
0.64
0.99


0.003
0.003
Nirdrr.irr. Cor.cer.n^or; j
m Su-2;s Soili {-g,C
-------
SUMMARY Or CONTAMINANTS IN BACKGROUND SOILS
r\ l . . -rv_ ' w ,
Chemical
INORGANICS
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobali
Copper
Lead
Manganese
Nickel
Selenium
Silver
Vanadium
Zinc
Cyanide
ORGANICS
Acetone
Acsnaphihene
AcenaphthyJene
Anthracene
Benzene
Benzo(A)anihiacene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(gjij)pcryisne
Benzo(a)pyrsne
Bis(2-ethylhexyl)phihaiate
Chloroform
Chrysene
Dioenzo(aJi)anihiaEcne
Dibenzofuran
Di-n-butyl phthalate
Fluoianihsne
Fluorene
Indeno(lJ23-cd)pyrrne
Meihylene Chloride
2-Mexhylnaphihaiene
Naphthalene
Phcnanihrene
Pyrene
Tetrachloroethylene
Toluene
1,1,1 -Trich loroethane
TrichJoroethylene
.Mean Concenrraiicn in
Surface Soils (ng,'rCi)
| Nia^rnum Ccnrenraron j
in Surface Soils (m^Xa) j
)


6
136
0.5
0.4
13
9
33
98
12S2
24

0.5
26
156
0.6


0.058
0.03
0.16

0.28
0.53
OJ27
0.18
0.47
3.85

Oj2
0.05
0.03
031
1.12
0.05
030
0.002
• 0.18
0.21
0.67
1.08

O.OOS



5.9
1S5
O.S
0.4
15.8
12.6
37.4
104
1370
25.8

O.S
32.5
168
0.7


0.06
0.05
0.19

0.41
0.55
0.49
03
0.49
5.7

0.52
0.05
0.03
038
1.2
0.09
031
0.006
022
022
0.77
1.10

0.015


-------
SUMMARY 0? CONTAMINANTS FOUND IN DEE? 3QZ.3
AT PARSON'S CASKET HARD1?'' ARE SITE. BEL'vEDERE. ZLUN'OIS

i
Chemical
INORGANICS [mgykg]
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobaic
Copper
Iron
Lead
Magnesium
Manganese
Mercury-
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
ORGANICS [ug/kg]
Acenaphtnene
Acenaphthyiene
Anthracene
Benzo(a)amhracene
Benzo(b)flouramhcne
Benzo(k)fluoranthene
Benzo(a)pyrane
Benzo(gJu)pciyiene
Bis(2-ethylhexyl)phthalate
Carfaazole
Chrysene
Dibenzo(aJ>)amhracene
Dibenzofuran
Mean Concsnraiion Li
Deep Soils (nig/kg)

554032
6.71
4.74
59.63
0.45
2.92
52351.00
13.49
5.36
154.57
11S31.45
3723
27461.73
363J2
0.53
144.37
568.57
1.17
1526
242.11
129
1639
158.91
2136
Maxirr.im Cor.:;r.r3don !
in Deep Soils i'rr.^kg) |

15300.00
2420
2S30
190.00
1.40
S.40
157C€O.CO
139.00
11.70
2750.00
3S-400.00
425.00
99200.00
1020.00
0.70
4740.00
1520.00
4.00
155.00
1680.00
27.60
36.90
1580.00
457.00
Note units below in ug/kg
12733
116.67
315.40
62321
785.47
354.50
730.80
54038
340:55
170.40
.637.13
32125
88.83
280.00
120.00
480.00
2300.00
3100.00
1100.00
2000.00
1200.00
1700-00
340.00
2700.00
450.00
210.00
-------
D
I'l




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gggggggggggggggggg
-| O|-OOQOOpppQpOO'*OOrl
no ro in c"> >o o - in ir) o Tf rl >n CD co co o o r-" S o o r| O
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*^j • — *
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D . V-T
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' — ' a) p 1)

*wi D it i> " -Ji c 3 S

^? t"^ (Tl *-! I> • r^ 1 1> "r"1! C
11 ji — I -3 p". g g c c v j
— $M -5 -5 „ "S * 'E -1 -^ „ ' £ f,
t^ p S -c -c JJ V U P- « P- B- c ^ .c
u o "5 -8' -S' S rT 1) S c "9 6 v -S C
*;? "? "D fc" &1 "S i> rl ^ • "^ S -S -H 'r °
< •$ ~>- .p H 5 fi d. •>, -g" -8 g "6 S -5 v (7 o c
O f~^ "£ c* C O O c *5 *4^ "*"*•:/• ^ ^ ^ 5^ '"^ -
frt r'l .Ii - -L .J, "^ 3 1* 1' ^« 3' i "^ r* pi b^ "^ 'C "c
o — ipQofnfC3Sri!2./i(Ho-,(v.(ir— JHH
'
-------
                     TA3LE 1-
SUMMARY Or CONTAMINANTS FOUND IN THE GROUNDS" ATER
AT PARSON'S CASKET HARDWARE SITE. BEL'VTDERE. ILLINOIS
Chemical
ORGANICS
1 , 1-Dichloroemane
1 . 1 -Dichloroethylene
lJ2-t-DichloToethylene
1,2-Dichloroeihane
TetrachloToerhylene
1 ,1 . 1-Trichloroethane
Trichloroethylene
INORGANICS
Arsenic
Barium
Chromium
Cobalt
Copper
Lead
Manganese
Nickel
Selenium
Zinc
Mean Concentration
(ug/L)

21
10
225
2.5
39
169
254

3
73
6
A
-t
48
13
203
60
3
19
Maxim im ConcennHion
(ug/L)

SCO
64
^900
3
250
1900
1350

38
107
24
13J2
666
61
2060
736
17
152
-------
Table 1-5.   Summary of Carcinogenic niul Noncareinugenic Risks Associated willi Exposure lo Sile and llaeltground Shallow
                                  Suit Under Cui-i-cnl niul Future Land Use Scenarios.  (Page I of 'I)

                                                    Current Receptor:  Site Worker

Risks Associated with
Exposure to CTE1
Concenlnitions
Risks Associated with
Exposure to RME1
Concenlnitions
Risk Driver:
Exposure Palhway(s)
Risk Driver:
Compound(s)
Carcinogenic Risk5
Site Shallow Soil
1 x 10'
5 x 10'6
1) Ingestion
2) Dermal
1) Arsenic
1) Benzo(a)|)yrene
Dackground Shallow Soil
1 x IO'6
7 x 1U'6
I) Ingeslion
2) Dermal
1) Arsenic
1) Deii2o(n)pyiene
Noncaicinogeiiic Risk'1
1 la/ard Quotient
Sile Shallow Soil
-------
Table 1-5. Summary of Carcinogenic and Noncarcinogenie Risks Associated with Kxpusure lo Site and llaclcground Shallow
Soil Under Current and Future Land Use Scenarios. (Page 2 of 
-------
Table 1-5.  Summary of Carcinogenic and Noncarcinogenie Risks Associated with Exposure to Site and Mat-Unround Shallow
                                  Soil Under Current and Future Land Use Scenarios. (l'a|»e 3 ol' 'I)

                                                   Future  Receptor: Site Worker

Risks Associated with
Exposure lo Cl'E1
Concentrations
Risks Associated with
Exposure lo RME1
Concentrations
.
Risk Driver:
Exposure Palhway(s)
Risk Driver:
Compound(s)
Carcinogenic Risk3
Site Shallow Soil
1 x 10''
5 x 10'6
1) Ingestion
2) Dermal
1) Arsenic
1) Beiuo(a)pyrenc
Background Shallow Soil
1 x 10'6
1 x 10'6
1) Ingeslion
2) Dermal
1) Arsenic
1) Beiuo(a)pyrenc
Noncarcinogenic Risk'1
1 lav.ard Quotient
Site Shallow Soil
-------
Tiiblc 1-5. StiniitJiu-y of CnreltioycMle niul Noncnrcinotjenlc Ulslts Assoclnlcd wilh lixpostirc lu Sile mid ltitck|irouiul .Shallow
Soil Under Current niul Pulure Land Use Scennrius. (lj:i|jo '1 of 
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-96 THU 08:51
              IEPA LAND
                                    FAX NO,  2177823258
                                P. 02
                    ADMINISTRATIVE RECORD
                              FOR THE
                   PARSON'S CASKET HARDWARE SITE
 The  Comprehensive   Environmental   Response,  Compensation,   and
 Liability  Act  of  1930  (CERCLA),   as  amended  by  the  Superfund
 Amendments and  Reauthcrization Act of 1986  (SARA), requires  the
 establishment of  an  Administrative record  (AR)  upon which  the
 President shall  base the selection  of a response action {SARA;Sec.
 113(K) (l).

 The Illinois Environmental  Protection Agency  (IEPA)  in  conjunction
 with the U.S.  Environmental  Protection.  Agency has compiled  the
 following official  Administrative  Record  Index  for the  Parson's
 Casket Hardware KPL  site located in Boone County,  Illinois. This
 index with associated actual file will be updated by the  IEPA.

 Please refer  to information provided  in the enclosed IBPA fact
 sheet on who and where to direct questions concerning  this index.
1.
      Fact Sheet
                              ISSUE  PATB
                                              AUTHOR
                                                        NO.  PAGES
2.   Areal Photo Analysis

3.   HRS scoring and
     document at ion

4.   HRS scoring and
     documentation

5.   Letter/Legal

6.   Project Outline &
      Proposal Report
 10/84       M Orloff           3

 10/84       Snvir. Monitoring 31

04/11/85     T Groutage        90
             K. M. Roberson
                               08/18/85


                               12/14/87

                               02/22/89
                                             J Geiger


                                             M Gade

                                             SAIC
                              101


                                4

                              203
 7.    Work Plan Phase I
                                02/89
                                            IEPA
                              416
-------

i-96 THU 06:52
I EPA LAND
FAX NO. 2177823258
P. 03
8.
9.
10.
11.
12.
13.
14.

15.
16.
17.
18.

19.
20.
21.
22.
23.
24.
25.
26.
Letter/QAPP
Letter/Work Plan
Letter/H&SP
Letter/Technical
Plat/Parson's Casket
Tech Memo letter
Technical Memorandum
No's 1.2.3.4.5.
USE PA approval on
Work Plan
RI/FS Phase II Work Plan
RI/PS Phase II QAPP
Forms for Phase II
QAPP
SAS Revisions
I EPA Letter/QAPP
QAAP Guidance
IEPA letter containing
(USEPA Guidance)
Ecological Risk
Assessment Guidance
Project Schedule
Hydrogeologic Testing
Radar Borehole
03/02/89
03/07/89
04/04/89
08/16/89
09/25/89
03/12/90
03/90

06/18/90
08/90
08/90
11/02/90

11/21/90
05/16/91
06/21/91
07/05/91
08/23/91
09/05/91
09/06/91
10/29/91
K Yeates
K Yeates
K Miller
K Miller
R Cowles
D Van Winkle
SAIC

K. Yeates
SAIC
SAIC
K Yeatee

C Tsai
S Baer
USEPA
S Baer
S Baer
S Baer
Dr Vanderpool
Borje Niva
4
3
5
1
21
10
300

8
80
187
114

70
5
94
8
6
•11
91
10
          Test Results
  27.  USEPA Guidance
                  11/06/91
         T Hyde
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S6 THU  08:53
IEPA LAND
FAX NO, 21778232E8
P. 04
28.
29.

30.
31.
32.













33.
34.
35.
36.
37.
38.
39.
40.

41.
42.
Revised schedule 04/01/92
USEPA approval of 05/15/92
Schedule
Municipal well data 08/19/92
USGS report 12/92
Final Remedial 12/21/92
Investigation (Ri) Report
Vol. I (Chapters 1-7)
Vol. II (Appendices A, B, CJ
Vol. Ill (Appendices D,E)
Vol. IV (Appendix F)
Vol. V-A (Appendix G.I)
Vol. V-B (Appendix G.I)
Vol. VI (Appendix G.2)
Vol. VII (Appendix G.3)
Vol. VIII (Appendix G.4)
Vol. IX (Appendix G.5)
Vol. X (Appendix G.6)
Vol. XI (Appendix G.7)
Technical letter/RI 12/22/92
USEPA approval of RI 01/04/93
Revised schedule 01/25/93
USGS results 02/02/93
Memorandum/Technical 03/02/94
Memorandum/Technical 03/09/94
Letter/Technical 11/29/95
USEPA approval of 07/02/96
Proposed Plan
Proposed Plan 07/02/96
Soil Operable Unit 07/09/96
S Miller
J Oaks

S Miller
P Mills
SAIC













T Ayers
J Oaks
S Miller
P Mills
K Keller
E Runkel
D Heaton
R Karl

IEPA
SAIC
4
1

261
40


647
271
136
265
416
427
330
258
517
402
254
227
1
1
4
32







        Feasibility Study
-------
  Guidance Documents  Consulted  on  Parson's Casket Hardware Site
                         Remedy Selection

Guidance  for  Conducting  Remedial Investigations  and Feasibility
Studies 10/1/88,  Pages  (390)  OSWER #9355-3.01

RI/FS  Improvements Date:  7/23/87,  Pages  (11)  OSWER #9355  0-20

RI/FS  Improvements Follow-up, Date:  4/25/88,  Pages (16),  OSWER
#9355.3-05

Superfund Federal-lead Remedial Management Handbook,  Date:
12/1/86,  Pages  (179,  OSWER #9355.1-1

Superfund Remedial Design and Remedial Action Guidance, Date:
6/1/86, Pages  (100),  OSWER #9355.0-4a

Superfund State-lead  Remedial Project Management  Handbook,  Date:
12/1/86,  Pages  (120), OSWER #9355.2-1

RI/FS  - Daily Quality/site & Waste  Assessment

Compendium of Superfund  Field Operations Methods,  Date: 12/1/87,
Pages  (550), OSWER #9355.0-14

Data Quality Objectives  for Remedial Response Activities:,  Date:
3/1/87, Pages  (150),  OSWER #9355.0-7b

Data Quality Objectives  for Remedial Response Activities: Example
Scenario: RI/FS Activities at a Site W/contaminated Soils and
Groundwater, Date: 3/1/87, Pages (120), OSWER #9355.0-7b

Field Screening for Organic Contaminants in Samples from
Hazardous Waste Sites, Dates 4/2/86, Pages  (11)

Field Screening Methods Catalog: User's Guide, Date 9/1/88, Pages
(90),                                                         ..;;_..

Field Standard Operating Procedures Manual #6 Work Zones, Date
4/1/85, Pages  (19),  OSWER 9285.2.04

Field Standard Operating Procedures Manual #9 Site Safety Plan,
Date: 4/1/85,  Pages (26), OSWER #9285.2.05

Laboratory Data Validation Functional Guidelines for Evaluating
-------
 Inorganics Analyses, Date  7/1/88,  Pages  (20)

 Laboratory Data Validation Functional  Guidelines  for Evaluating
 Inorganics Analyses, Date  2/1/88,  Pages  (45)

 Practical Guide for Ground-water  Sampling,  Date:  9/1/85,  Pages
 (175), Epa/600/2-85/104

 Soil  Sampling Quality Assurance User's Guide,  Date:  5/1/84,  Pages
 104,  Epa 600/4-84/043

 RI/FS Land Disposal Facility Technology

 Covers for Uncontrolled Hazardous  Wastes  Sites, Dates:  9/1/85,
 Pages  (475), Epa/540/2-85/002

 Design, Construction, and  Evaluation of Clay Liners  for Waste
 Management Facilities, Date: 11/1/88,  Pages (500), Epa/530/sw-
 86/007ff

 Evaluating Cover Systems for Solid and Hazardous  Waste, 9/1/82,
 Pages  (58), OSWER #9476.00-1

 Land Disposal Restrictions, Date:  8/11/87,  Page  (23)

A Compendium of Technologies Used  in the  Treatment of Hazardous
Wastes, Date 9/1/87, Pages  (49), Epa/625/8-87/014

 Carbon Adsorption Isotherms for Toxics  Organics, Date: 4/1/80,
 Pages  (321),  Epa/6008-80-023

Handbook for Stabilization/solidification of Hazardous  Waste,
Date: 6/1/86, Pages (125),
Epa/540/2-86-001

Reviews  of In-place Treatment Tech-niques  for Contaminated
Surface Soils-vol. 1:  Tech-nical Evaluation, Date: 9/19/84, Pages
 (165), Epa/540/2-84-003a

Technology Screening Guide for Treatment of Cercla Soils and
Sludges,  Date 9/1/88,  Pages (130), Epa 540/2-88/004

RI/FS Ground-water Monitoring & Protection

Criteria for Identifying Areas of Vulnerable Hydrogeology under
-------
Rcra: Statutory  Interpretive Guidance, Date:  7/1/86,  Pages (95o),
OSWER #9472.00-2a

Final Rcra Comprehensive Ground-water Monitoring Evaluation (One)
Guidance Document, Date 12/19/86, Pages  (55),  OSWER #9950.2

Ground-water Protection Strategy, Date:  8/1/84,  Pages (65),  Epa
/440/6-84-002

Guidelines for Ground-water Classification under the  Epa Ground-
water Protection Strategy, Date: 12/1/86, Pages  (600),  Epa/440/6-
84-002

Protocol for Ground-water Evaluations, Date:  9/1/86,  Pages (200),
OSWER #9080.0-1

Cercla Compliance with Other Environmental Statutes,  Date:
10/2/85, Pages (19), OSWER #9234.0-2

Cercla Compliance with Other Laws Manual, Date:  8/8/88,  Pages
(245). OSWER #9234.1.01

Final Rcra Comprehensive Ground-water Monitoring Evaluation (One)
Guidance Document  (Secondary Reference), Date: 12/19/86,  Pages
(55), OSWER #9950.2

Rcra Ground-water Monitoring Technical Enforcement  Guidance,
Date: 9/1/86, Pages  (8), OSWER #9950.la

Rcra Ground-water Monitoring Tech-nical Enforcement Guidance
Document,,  Tech:

Atsdr Health Assessment on Npl Sites, Date: 6/16/86,  Pages  (14)

Chemical, Physical & Biological Properties of  Compounds  Present
at Hazardous Waste Sites,  Date: 9/27/85, Pages (320), OSWER
#9850.3

Guidelines for Carcinogen Risk Assessment, Date:  9/24/86,  Pages
(13),  OSWER #9285.4-02

Health Effects Assessment Document,  Vol. 28:  Acetone, Arsenic,
Asbestos, Date 9/1/84, Pages (1750), Epa/540/1-86/001-058

Integrated Risk Information System  (Iris) a Computer  Based Health
-------
Risk  Information System Available Through  E-mail  Brochure  on
Access  Is Included), Date:  -  Pages  (0)

Public  Health Risk Evaluation Database Two Diskettes  Containing
the Dbase lii, 9/16/88, Pages (0)

Superfund Exposure Assessment Manual, Date: 4/1/88, Pages  (160),
OSWER #9285.5-1

Community Relations in Superfund:   a Handbook, Date:  6/1/88,
Pages (188), OSWER #9230.0-03b

Interim Guidance on Superfund Selection of Remedy Date: 12/24/86
Pages (10)  OSWER #9850.0-19

Rcra/cercla Decisions More  on Remedy Selection, Date:  6/24/85,
Pages 93)

Thomson, K. 0. T., Chaudhary, M. A., Dovantis, K., and R.  R.
Riesing, Groundwater Remediation Using Extraction, Treatment and
Recharge System, Focus GWMR,  Winter 1989,  Pages 92-99.

Timmerman, C. L., Feasibility Testing of In-Situ  Vitrification  of
Arnold  Engineering Development Center Contaminated Soils,  Report
Prepared by Pacific Northwest Laboratory,  Richland, Washington,
ORNL/Sub/88-14384/1, March  1989..
Ultrox International, Brochure and Test Data.

US EPA, Cleaning Excavated Soil Using Extraction Agents: A State-
of-the-Art Review, Risk

Reduction Engineering Laboratory, Office of Research and
Development, Cincinnati, Ohio,
EPA/600/2-89/034, June 1989a.
US EPA, Control and Treatment Technology for the Metal Finishing
Industry,  EPA/625/8-81-007® 1981.
-------
US EPA, Draft  Interim Guidance  ofi  Estimating  Inhalation Exposure
During  Showeling.  Office of Research  and  Development,  1988a?
US EPA, Evaluation of Emerging Technologies  for the Destruction
of Hazardous Wastes,
EPA/600/2-85/069, June 1985.
US EPA, Health Effects Assessment Summary Tables  - First/Second
Quarters FY1990,
OERR9200-6-303  (90-1/2), 1990.
US EPA Meeting Hazardous Waste Requirements for Metal Finishers,
EPA/625/4-87/
September 1987.
US EPA, Remedial Action at Waste Disposal Sites, EPA/625/6-
85/006, October 1985.

US EPA, Risk Assessment Guidance for Superfund.  Volume 1: Human
Health Evaluation Manual  (Part A) .  Interim Final.  Office of
Emergency and Remedial Response, 1989.

US EPA, Risk Assessment Guidance for Superfund.  Volume 1: Human
Health Evaluation Manual  (Part B).  Interim Final.  Office of
Emergency and Remedial Response, December 1991.

US EPA, Second International Conference on new Frontiers for
Hazardous Waste Management,
EPA/600/9-87/018F, August 1987.
US EPA,_ Superfund Exposure Assessment Manual.  Office of Energy
and Remedial Response.
EPA/540/1-88/001, 1988b.
-------
US EPA, Superfund Public Health Evaluation Manual,  EPA/540/1-
86/060, Office of Emergency
and Remedial Response, 1986.
US EPA, Superfund Record of Decision, Byron  Salvage  Yard  IL,
Third Remedial Action,
EPA/ROD/R055-89/089, June 1989b.

US EPA, Superfund Innovative Technology Evaluation  (SITE)
Program, Description Pamphlet, EPA/540/8-89/002,  EPA Research
Symposium, April 10-12, 1989.

US EPA, Survey of Fugitive Dust for Coal Mines.   EPA-908/1-
78/003, 1978.

US EPA  (1990).  "Ground Penetrating Radar Survey, Dec.  12, 1989,
Parson's Casket, Belvidere, Illinois," Superfund  Technical
Support Unit, Chicago, Illinois.

Weber, W. T., and B. M. Van Vliet, Synthetic Adsorbents and
Activated Carbons for Water Treatment: Overview and  Experimental
Comparisons, AWWA Journal, Volume 73, Pages 420-425,  August 1981.

Weber, W. J., Physicochen-dcal Processes for Water Quality
Control, John Wiley & Sons, Pages 503-531® 1972.

Weber, W. F., and W. Bowman, Membranes Replacing  Other Separation
Technologies, Chemical Engineering Progress, Volume  82, No. 1 1,
Pages 23-28, 1986.

Weston, Task Order 7, Interim Tech ical Report Heavy Metal
Contaminated Soil Treatment: Conceptual Development,
February.1?87.

Weston, In-Situ Volatilization Remedial System Cost  Analysis,-
Technical Report prepared for U.S. Army Toxic and Hazardous
Materials Agency,  Maryland, August 1987.

Wilson, J. T.,  and C. H.  Ward,  Opportunities for Bioreclamation
of Aquifers Contaminated with Petroleum Hydrocarbons,
Developments in Industrial Microbiology, 1987, Supplement No. 1,
Pages 109-116.
-------
Soil Screening Guidance: User Guide,  April 1996.




Role of the Baseline Risk Assessment, OSWER Directive 9355.0-30
-------
    Responsiveness Summary

           for the

Parson's Casket Hardware Site
       Public Hearing
   Illinois EPA File #248-96
      September 1996
-------
-------
             Responsiveness Summary

                       for the

          Parson's Casket Hardware Site
                   Public Hearing
             Illinois EPA File #248-96
                       INDEX
                                               Page
Title Page and Index   	      1
Agency Decision   	      2
Parson's Casket Hardware Company  	      2
Illinois EPA Public Hearing and Hearing Record  	      2
Site Map and Location  	      4
Responsiveness Summary - Index of Issues	      5
Questions and Comments	      6
Glossary and Acronyms     	     16
For Additional Information (Contacts list)   	     17
                        -1-
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                        AGENCY DECISION

On September 26, 1996, the Illinois Environmental  Protection Agency
(Illinois EPA or Agency) and the United States Environmental Protection
Agency (USEPA) decided to accept the remedial actions as outlined in the
proposed  plan for the Parson's Casket Hardware  Company Site.  The
effective date of this decision is September 30, 1996.
                Parson's Casket Hardware Company

The Parson's Casket Hardware Company manufactured and plated metal
fittings  for caskets from 1898  until it filed for  bankruptcy  in August,
1982.  From the mid-1920s until 1982, the company operated at  424
Fairview Street in Belvidere, Illinois.  Electroplating metal parts typically
produced wastes  such as heavy metal contaminated sludges, cyanide
plating and cleaning solutions, and  metal-cleaning chlorinated solvents.
The property is currently being used for similar industrial processes by a
different company but with  strict waste management practices being
utilized to prevent any contribution to the sites contamination.  The site
boundaries are shown on the site map (page 4) along with the location of
the waste lagoon where the contamination  levels are the most severe.
The current  owners and operators at the site have offices,  processes,
storage, and distribution areas all located at the  site but are not in any
way affiliated with the Parson's  Casket Hardware Company.
       ILLINOIS EPA PUBLIC HEARING AND HEARING RECORD

Upon review of the Proposed Plan, the Illinois EPA issued  a Public Notice
to announce two Public Availability Sessions on June 25, 1996 (2:30-
4:30pm and 6:30-8:30pm).  Because of the public interest, the Illinois
EPA determined  that a  public hearing  should be held.  The hearing
notification was  published  in the  Rockford Register Star and in the
Belvidere Daily Republican on the following approximate dates: July 5, 13
and 23, 1996.

                               -2-
-------
The public comment period began on July 17, 1996. The public hearing
started at 6:30 pm on Wednesday, August 7, 1996, with twenty-seven
people attending the proceedings held at the Ida Public Library (320 North
State Street,  Belvidere)  and continued until 8:00  pm.   The public
comment period and the hearing record were closed on August 15, 1996.

This responsiveness summary addresses comments received at the public
hearing and written comments received by the Agency between July 17,
1996, and  August 15,  1996.  The main issue addressed at the public
hearing  was  that  of the Proposed  Plan.   The  proposed plan is the
document that suggests a course of action that the Agencies may take to
remediate the site.  The public comment period allows the Agencies to
receive any questions or comments related to the proposed plan before a
final decision is made. The proposed plan may also undergo revisions due
to the comments that are submitted if the Agencies believe  that the
proposed plan should be changed in order to address issues raised by the
public. A responsiveness summary is prepared to address any relevant
questions or comments, whether they result in changes being made to the
proposed plan or not.

Citizens are encouraged to review the proposed plan and other documents
including fact sheets and this responsiveness summary, which are located
in the following public repository under the name "Parson's Casket":
                    Ida Public Library
                    320 North State Street
                    Belvidere, IL 61008

     Telephone:      815/544-3838
         Hours:      Monday through Friday: 9:30 am - 8 pm
                    Saturday: 9:30 am - 5 pm
                              -3-
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Map of Site:
                            -4-
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                  RESPONSIVENESS SUMMARY




                         Index of Issues






Issues Relevant to the Proposed Plan:                   Page




Section




 1   Impacts to Ground or Surface Waters      	      6




 2   Selection of the Remedial Action      	      8
                             -5-
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         Section 1:  Impacts to the Ground or Surface Water
Question 1-1:  Have the contaminants reached the Kishwaukee River?

Answer:  Yes.  The monitoring wells along the banks of the river have
shown  contaminants  that are associated with this site.   What  is not
known  yet,  and won't be known until further testing and sampling is
done, is whether the contaminated groundwater is simply flowing under
and past the river or whether it is mixing with the river. The geology of
the area  is  not  fully characterized  and  until more investigation is
accomplished, all that is known is that the contaminants have migrated
a distance at least as far away as the river in the direction of the river.
Question 1-2:   Have the contaminants impacted the water in the city
               wells?

Answer:  The City of Belvidere has detected levels of contaminants at
some of its wells during some of the regular sampling events. Although
the contaminants  are similar  to  those present  at the  Parson's site,
whether the  Parson's source  is  partly or  wholly responsible for the
contamination has not been determined. The City has addressed this by
instituting procedures that allow for the treatment of the contaminants.
The City water that is distributed to the public after treatment complies
with all the state and federal regulations necessary to assure the water is
suitable for drinking and other uses.
Question 1-3:   Has  the migration of contaminants compromised  the
               safety of the wells that supply the city of Belvidere with
               water?

Answer:   Although the City wells do show evidence of both natural and
manmade contaminants in the  raw water  supply, the  City's water
treatment processes have removed the undesirable components to below

                               -6-
-------
the Federal Drinking water standards.  This means that no water that is,
or has been, distributed by the city is unsafe for drinking or any other use.
Since some manmade contaminants may not  be associated with this site
directly, it is not clear whether this  site is the major or only source of the
contaminants but an extensive investigation that is necessary to address
that question is now underway.
                               -7-
-------
             Section 2: Selection of the Remedial Action
Question 2-1:   What is the likely time table for the removal action if the
               recommended actions are chosen?

Answer:  An exact time table  is not fully developed currently but it will
be provided through the public repository when available. The Agencies
would expect the approximate  time table to be as follows:

  9/26/96      Record of Decision signed  by Agencies
  Winter 96-97 Work plan written, submitted, reviewed, and approved
  Spring 97    Final preparation of site for removal action
  Summer 97  Removal of contaminated soil from site

Groundwater investigations  are already  underway  but due  to the
complexity of  the  groundwater issues,  both  on and off site, the
completion of such studies will take a considerable amount of time.  The
Agencies conducting the studies will endeavor to  provide the data and
conclusions as it becomes  available.
Question 2-2:   What is the justification for selecting the removal action
               that is recommended?

Answer:   All the criteria, calculations, discussion, and determination of
the selected removal actions in comparison to the other possible actions
are found in detail in the Feasibility Study with a summarized version
appearing in the proposed plan. Please refer to these documents for a full
explanation of  the  selected action.   A  given  action,  however, only
emerges  as an  Agency recommendation when it is shown that it best
meets the requirements of a satisfactory remedial action.            .
Comment 2-3:  It is premature to select a remedy with the information
               that is contained in the Soil Operating Unit FS.
                               -8-
-------
Response: The Agency does not agree.  We believe enough information
exists in  the  Operable Unit Feasibility Study  (FS)  and the Remedial
Investigation  (Rl) to  support the  remedies selected  for  this site.
Investigations  have been ongoing since 1982 and are still underway (i.e.,
groundwater investigations). The data gathered to this point is adequate
to support the recommendations found in the Proposed Plan.  While the
data that will be gathered from the ongoing investigations are critical to
answering significant groundwater issues, the Agencies feel that the
remedial actions  to  be taken now are appropriate, based on current
findings and will be beneficial toward any remedial actions selected in the
future.
Comment 2-4:   The FS is for soil only, and groundwater is being dealt
                with as a separate operable unit FS. The FS only updated
                the baseline risk assessment (BRA) for the shallow soils
                and that BRA (presented as Attachment H to the FS) is
                still in draft form.  The updated soil BRA presented in the
                FS concludes that risk for the shallow soils is the same
                as for background, and therefore "limited no action" is
               proposed.  This conclusion is understood.  The BRA for
                deep soils, however, has  not been updated since 1992,
               nor has a baseline risk assessment been completed which
                evaluates the overall risk associated with groundwater.

Response: Several factors influenced the updating of the shallow soils
operable unit baseline risk assessment (BRA).   In June of  1992, the
USEPA  revised  the  cancer slope factor (CSF) for benzo(a)pyrene.  The
CSF is critical to the quantification  of cancer risk in the BRA. The revision
for B(a)P recognized an error in USEPA's calculation of the CSF and had
the effect of reducing the estimation of risk due to contact with quantities
of B(a)P. In March 1993, USEPA released  its toxicity equivalency factors
guidance for use when evaluating  cancer risks  due  to exposures to
quantities of carcinogenic polynuclear aromatic hydrocarbons (PAHs).
This  guidance  provided a  more accurate  method to  evaluate  the
carcinogenic PAH chemicals and had the  effect of further reducing the
estimated risks  from the site.

                               -9-
-------
These two revisions were substantial in magnitude and both operated in
the same direction; toward  reducing the estimation of cancer risks for
PAHs. Because carcinogenic PAHs were the chemicals that were driving
the surface soil risks at this site, it was prudent to recalculate risks based
upon the most current evaluation methods. These factors are irrelevant
to  carcinogenic  risks  calculated for  deep soil.   B(a)P and other
carcinogenic PAHs do  not drive the risks for deep soil. The toxicity values
and  methods  for evaluating the chemicals detected in  deep  soil were
unchanged. This  would provide the  appropriate level  of protection for
human health and the environment, and therefore, no revisions were made
for the deep soil operable unit.

As for the "draft" in  the revised risk assessment for shallow soils in
Attachment H, it would not have been cost effective to revise  the entire
document based on a word change in the document. Therefore, it  was
concluded that the "draft" could remain in the title since  the revised risk
assessment was  becoming  an attachment  to  what is   now the final
Feasibility Study.
Comment 2-5:  The BRA, originally issued with the Remedial
               Investigation (Rl) in 1992, has a number of errors related
               to its calculations on the potential for deep soils to affect
               groundwater at the Site. Deep soil is being proposed for
               removal in  the FS due to the groundwater exposure
               pathway. Prior to proposing any remedy for deep soil,
               it is critical that these calculations be corrected.  No
               remedy  should be selected for  deep soils until the
               groundwater investigation has been completed and the
               risk assessment has been verified for its accuracy related
               to groundwater exposure.

Response: The  Agencies  do not agree that  there are  errors  in  the
calculations. The Rl was finalized in January 1993  with calculations that
were completed using the site specific data available at that time. The
BRA was completed utilizing  guidance issued by USEPA and reviewed to
the fullest extent possible for errors. The Agencies believe the completion

                              -10-
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was approved  with all risk calculations compliant with the  guidance
available for the project at the time. Information regarding default values
was retrieved through literature searches at the time of the  1992 BRA,
when site specific data could not fulfill definitive data requirements of the
risk guidance in calculating risk for the site.  This is commonly done for
Superfund projects and is consistent with other projects conducted by the
State of Illinois.

We  do  know  that  the deep soils  are  adversely  impacting local
groundwater. The Agencies believe that overall protectiveness of human
health  and  the environment  is  best achieved  by  utilizing  the risk
assumptions  calculated in the 1992 BRA for the deep soil operable unit.
Therefore, the Agencies agree that the risk numbers are appropriate for
the deep soils and that removal would best serve requirements under the
NCP, as well  as the local residents impacted by the site or any future use
of the property.
Comment 2-6:   The Proposed Plan does not consider the potential major
                risks presented by the implementation of the remedial
                alternative chosen which may far outweigh the, at most,
                marginal risk posed by the deep soils when errors in the
                BRA calculations are corrected.

Response: Again, the Agencies do not agree that errors were made in the
calculations,  but to address the rest of  the  comment, the Agencies
understand the risk inherent to the remedial alternative selected and will
take all precautions to ensure that releases  will  not occur and  that
workers and the  public are  adequately protected during the removal.  The
Agencies believe that the  potential risk  in the removal action does not
outweigh the calculated risk  posed by leaving deep soils in place.
Comment 2-7:  If after reevaluation of the risk assessment and inclusion
               of risk presented by the remedies it is determined that a
               remedy for deep soil other than "Limited No Action" is
               still needed, soil vapor extraction (SVE) is the most cost

                               - 11-
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                effective remedy for elimination of  the potential for
                migration of VOCs to Site groundwater from deep soils
                and will be protective because non-VOCs in deep soils
                were found  to present negligible risk of migration to
                groundwater.

Response: The risk assessment does not need to be reevaluated.  The
Agencies believe the BRA from 1992 and the revisions for shallow soils
from 1995 are accurately representative for risk at the site.

Although it is true that the Soil Vapor Extraction (SVE)  alternative is less
costly than the remedial  alternative selected for deep  soils, based on site
specific  information,  SVE will probably fail to meet  expectations for
design or operational performance.  This was concluded based on various
factors.  The range of effectiveness based on other projects is between
70-90%  efficiency for removal of VOCs.  This means that some residual
VOCs would remain at the site and SVE is not effective in remediating
semivolatiles or metals - both present at  the site.

The SVE  alternative is selected as  a remedial alternative when site specific
conditions are ideal for extraction  of VOC vapors.  Unfortunately this Site
has  less  than ideal  subsurface  geological  conditions.   The  soil is
heterogenous with various clay lenses which would adversely affect SVE
performance.  There  is  also  an  identified contaminant (called an Non
Aqueous Phase Liquid or NAPL) at the site which has not been completely
characterized for volume. A sludge seam was also discovered during the
1984-85 remediation of the old lagoon. Neither of these factors could be
calculated into the design of an SVE system, since their influences on and
by the SVE would be unpredictable.  There is also a PCE plume on the
southwest portion of the site from an unknown source area. This PCE
plume would probably adversely  influence the performance of the SVE
system since nothing is known of PCE's origin.  There are  the  further
unknown influences of  the  suspected dry wells and since  very little
information is available on these dry wells, they may also adversely affect
the performance of the  SVE system.  Soil moisture  content and vapor
retardation factors have also  been identified  as less  favorable for SVE.
Based  on these  factors  it  was  determined that  SVE could not be

                               -12-
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implemented with a high degree of certainty or success or with adequate
assurances that the system could perform over a reasonable amount of
time.

Comment 2-8:  If there is a current concern regarding the possible need
               to perform  SVE remediation  beneath the building,  it
               would be appropriate to combine this effort with the use
               of SVE in adjacent areas at the site.

Response:    Based on information contained in the FS, it  appears that
additional source areas  may  not  be  located  under existing building
structures.  However,  if additional   information   did  indicate  that
contamination  was  located under  a  structure the  use  of SVE for
remediation would be considered. This does not change the factors that
lead to SVE being dismissed for remediation of the deep soils. (Refer to
SVE effectiveness for  deep soils at this  site discussed above in the
response to comment 2-7.)
Comment 2-9:  The risks and hazards associated with the leaching of
               contaminants from deep soils to groundwater are based
               on  a  too conservative  value of foe (0.1 %).   USEPA
               Guidelines assume foe default values ranging from 0.2 to
               0.6%. Recalculation of the risks using these foe default
               values yields values with  the "acceptable" cancer risk
               range of 1.0E-06 to 1.0E-04 and hazard indices slightly
               above 1 (for foe 0.2%) and less than 1 at higher foe
               values.  The use of 0.1% foe thus overestimates the risks
               and hazards associated with the leaching of contaminants
               from deep soil to groundwater.

Response:    The value of 0.1 % for foe used in calculating the excess
carcinogenic  risks  and  hazards  associated  with  the  leaching  of
contaminants from  deep soils to  groundwater was derived from  a
literature search in  1991.   Remedial alternatives for  deep soil were
developed for the current FS  in 1995 prior to the publication of the
USEPA default foe values of 0.2%-0.6%.

                               -13-
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Using  the foe value of 0.1%, the risks  and hazards associated with
leaching of contaminants from deep soils to groundwater are in the same
order of magnitude as those calculated using the 0.2% value (i.e., 10'5)
for excess carcinogenic risk and  >1  for health  induces.  Thus, use of
0.1 % for foe is not overly conservative.

Remedial alternatives are developed where excess carcinogenic risks are
greater than 1 .OE-06 and/or health hazards (per target organ) are greater
than 1. Commonly, it is the excess carcinogenic  risk that determines the
need to remediate. Although USEPA guidance suggests a target range of
1 .OE-04 to 1 .OE-06 as moderately acceptable, risks in this range do not
de facto justify no action to be taken.  Remediation may be undertaken
when excess carcinogenic  risks are in this moderately acceptable range
according to site  specific  considerations and lead agency/community
disposition.  Moreover, although a 0.6% value of  foe yields health hazard
induces < 1, the excess carcinogenic risks, ranging from 5.OE-06 to 1.7E-
05, remain greater than the level considered as the "point of departure"
(i.e.,  1 .OE-6) in  remediating a  site.   Thus,   risk  values,  based on
calculations using any foe values ranging from  0.1% to 0.2%, would
require  the  development  of  remedial alternatives  for  deep soils  at
Parson's.  Given the similarity of risks and hazards associated with  foe at
0.1 % and 0.2% and that foe values up to 0.6% yield excess carcinogenic
risk greater than 1 .OE-6, the development of remedial  alternatives for the
deep soils remains valid and a  revision of the BRA is not required.

Regarding groundwater, the TCE parts  per billion (ppb) concentrations for
the deep alluvial aquifer at  the site indicate an estimate of UCL may be
calculated at 200 ppb. In a residential groundwater ingestion scenario the
cancer risk  (ELCR) of 1 .OE-04  occurs at a calculation of  160  ppb.
Therefore, at 200  ppb the higher end of the Superfund risk range of 1 .OE-
04  to 1 .OE-06  would  be expected to  be  exceeded.   This risk is
unacceptable. The groundwater  feasibility study does  not have  to be
completed before selecting a remedy for soils, unless there is great doubt
that the Parson's  site is the source of TCE in groundwater.  It has been
determined that the TCE in groundwater beneath the site originated from
the old  lagoon area and possibly from the suspected dry wells and is
continuing to leach into the groundwater.

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    Furthermore, even if current Soil Screening Level (SSL) guidance was
    taken into consideration, the deep soil data would indicate that SSLs for
    the protection of groundwater have been  exceeded for the following
    chemicals: TCE,  Benzo(a)anthracene, Chrysene, Methylene Chloride, N-
    Nitrosodiphenylamine, Pentachlorophenol, Arsenic (borderline), Barium,
    Cadmium  (borderline), and Nickel.  This is in reference to some organic
    and inorganic chemicals for which deep soil data was reported and  for
    which  SSLs are  available.    These  conclusions  are based  upon
    approximations of the UCLs for these chemicals in deep soil.  Therefore,
    the deep soil data appears to compliment the results of the groundwater
    monitoring data, i.e., exceedances of SSLs generally results in significant
    and  unacceptable  risk in  groundwater.  This would also support  the
    decision not  to  select SVE  based on the  fact that inorganics have
    exceeded  or  are  borderline  of  their respective SSLs and SVE is  not
    effective in remediating inorganics.
Comment 2-10: The remedial action recommended by the Agencies requires the
                costly relocation of a water main.

Response:    It is true that the water main, which bisects the property through
the former lagoon area, is proposed to be relocated to the southern portion of the
property. This decision was based on discussions with the City of Belvidere, who
wish to continue using the water main adjacent to the Parson's property in order
to supply service to the buildings at Parson's.

It is also believed that  the water main may have acted as a preferential pathway
for contaminants to travel beneath the ground surface much like a conduit.  Since
the present water main  has deteriorated to  the  point of failure  (i.e., leaking
underground)  and  the  City  feared  that  contaminants from  Parson's  may
compromise the City's drinking  water supply if a negative flow situation arose,
it was determined that the best course of action would be to relocate the main to
an acceptable location with the  installation of a new pipe to  ensure integrity.
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                         Glossary and Acronyms
Groundwater   Includes all forms of water beneath the ground's surface.

Illinois EPA     Illinois Environmental Protection Agency.

Public Hearing  Period of time before, including, and after the public
Record         hearing for the collection of written testimony and
               hearing transcript. The hearing record began April 21,
               1995, and remained open until November 10, 1995.

Responsiveness A document prepared by the Illinois EPA in response to
Summary       questions and issues raised during the public hearing
               record (this entire document).

Surface waters  Includes all forms of brooks, streams, rivers, ponds,
               drainage ditches, impoundments, or lakes of natural or
               manmade origin.

USEPA         United States Environmental Protection Agency.
                                 -16-
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                         For Additional Information
For information related to the Public Hearing Process, Hearing Record, Hearing
Exhibits, or Hearing Transcript, please contact;
     John Williams
     Illinois EPA Hearing Officer
     217/782-5544
     TDD: 217/782-9143
     Fax: 217/782-9807
Additional copies of this Responsiveness Summary

     Mark Britton
     Illinois EPA - Office of Community Relations
     217/524-7342
     Fax: 217/785-7725
Thanks to all the citizens that became involved in this process.  On behalf of
Director Mary Gade and the Agency staff, I would like to thank the large number
of citizens who took time to get involved by participating in the public hearing,
reviewing documents in the repositories, meeting with the Illinois EPA staff, and
sending in written comments for the hearing record.
                 Signed:
                         John D. Williams,
                         Agency Hearing Officer
                   Date:	               ,  1996
                                  - 17-
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                              Distribution List

Responsiveness Summary:

   Bureau of Land File
   Eric Runkel - Springfield, BOL, Project Manager
   Terry Ayers - Springfield, BOL-NPLU, Manager
   Greg Michaud - Springfield, Community Relations Unit, Manager
   Mark Britton - Springfield,  Community Relations Unit
   John Williams - Springfield, Division of Legal Counsel (2 copies)
   Jason Thorp - Rockford Regional Office, BOL-FOS
EPA8134/corres/parsons/resp_sum.004
MTB/mtb:9/96
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