PB96-964111
                                 EPA/ROD/R05-96/308
                                 December 1996
EPA  Superfund
       Record of Decision:
       Yeoman Creek Landfill,
       Waukegan, IL
       9/30/1996

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              DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION

Yeoman Creek Landfill
Waukegan, Illinois

STATEMENT OF BASIS AND PURPOSE

This decision document represents the selected Final Remedial
Action for the Yeoman Creek Landfill Site in Waukegan,  Illinois.
This action was chosen in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act  of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA),  and to the extent
practicable,  with the National Oil and Hazardous Substances
Contingency Plan  (NCP).  The decisions contained herein are based
on information contained in the administrative record for this
site.

The State of Illinois concurs with the selected remedy.  The
concurrence letter is attached to this Declaration.

ASSESSMENT OF THE REMEDY

Actual or threatened releases of hazardous substances from the
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

This remedy is intended to be the final action for this site.
This final action includes containment of landfilled wastes,
excavation and on-site containment of contaminated soils and
sediments,  collection and treatment  of leachate entering Yeoman
Creek,  and recovery and treatment of landfill gases.   This final
action addresses the following migration pathways from  the Site:
releases  of leachate to ground water,  surface water,  surface
sediments,  and wetlands;  and release of landfill gases  to air

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within adjacent buildings and to the ambient air.

The major components of the selected remedy include:

     construction of a new cover over the landfill to minimize
     infiltration of precipitation through the landfill,
     consisting of the following components: a 3 foot frost
     protection layer including a top vegetated layer;

     a geosynthetic drainage layer overlain by a protective
     geonet providing a hydraulic conductivity of 28 cm/sec, a
     barrier layer consisting of a 3 feet Compacted Clay Liner
    . which meets Illinois Solid Waste Landfill closure standards,
     or an equivalent primary barrier layer such as a primary
     barrier layer consisting of a 40 mil very low density
     polyethylene liner (or equivalent),  a secondary barrier
     layer consisting of a Geosynthetic Clay Liner or a Compacted
     Clay Liner which meets Illinois Solid Waste Landfill closure
     regulations,  a gas ventilation layer,  and a grading layer to
     provide a 2% slope after settlement;

     implementation of a long term monitoring system which shall
     include sampling for leachate/ground water along Yeoman
     Creek,  surface water and creek sediments,  and leachate
     sampling within the landfill.  In the event action levels are
     exceeded,  post operation of the cap, construction and
     operation of a leachate collection system will be required.
     If determined necessary,  the leachate collection system
     would be constructed along both sides of Yeoman Creek
     adjacent to the northern portion of  the landfill to prevent
     leachate and contaminated groundwater from entering or
     seeping into Yeoman Creek along the  northern portion of the
     landfill;

     construction and operation of  an active perimeter landfill
     gas' collection and treatment system;

     excavation and consolidation under the new cover of
     contaminated sediments in Yeoman Creek and possibly of
     limited wetland areas and non-wetland soils that exceed
     cleanup action levels defined  in the Record of Decision
     Summary;

     actions,  including investigations, modeling,  alternative
     evaluation,  and implementation,  necessary to comply with the

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Illinois Department of Transportation and Lake County Storm
Water Management Commission regulation of development within
floodways and flood plains, which may include: creation of
compensatory storage for lost flood plain storage; use of
artificial channels combined with detention facilities or
other technologies to maintain stream capacity without
increasing the average velocity through the Site; excavation
of landfill wastes and soils at the Site out of the floodway
and flood plain and consolidation on-site for containment
under the new Site cover; and approval of a variance or
variances -from the floodway and flood plain regulations by
the regulatory Agencies;

Actions to minimize the destruction, loss,  or degradation of
wetlands, including compensation for wetlands that will be
lost or adversely affected by the selected remedial action;

Enclosing Yeoman Creek in a corrugated steel semi-arch pipe,
as necessary for construction of the site cover;

Rerouting and sealing storm drains that go through the
Yeoman Creek and Edwards Creek portion of the landfill;

Continuation of interim measures to address landfill gas
entry into buildings near the Site until the active gas
collection system is installed and demonstrated to be
effective,  including monitoring for landfill gas entry into
certain buildings north of the Site, and operation and
maintenance of the ventilation system in a building north of
the Site;

Additional investigation to define the extent of ground
water contamination,  the extent of sediment excavation,  the
extent of contaminated soil excavation,  and baseline wetland
conditions;

Long term monitoring of ground water,  surface water,  surface
sediments,  and wetland conditions to verify the
effectiveness of the remedial action;

Imposition of deed restrictions prohibiting future usage of
the Site for purposes that are inconsistent with the
selected remedy;

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     Implementation of access restrictions, including enclosing
     the entire Site in a fence and posting warning signs.

     Long term maintenance and post closure care.

STATUTORY DETERMINATIONS

This Final Remedial Action is protective of human health and the
environment, complies with Federal and State applicable or
relevant and appropriate requirements and is cost-effective.  The
selected remedial action utilizes permanent solutions and
alternative treatment technologies to the maximum extent
practicable.  However,  due to the large volume and heterogeneous
distribution of waste at the Site, treatment as a principle
element is not considered practicable at the Site.  Thus,  this
remedy does not satisfy the statutory preference for treatment
that reduces toxicity,  mobility,  or volume as a principal
element.  However, treatment is a secondary element in that
landfill gases will be treated resulting in destruction of
hazardous substances.

A review will be conducted to ensure that the remedy continues to
provide adequate protection of human health and the environment
within five years after commencement of the remedial action.
      Date                         a^  Valdas V.  Adamkus
                                  /  Regional Administrator

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                   RECORD OF DECISION SUMMARY

          YEOMAN CREEK LANDFILL SITE,  WAUKEGAN,  ILLINOIS

I.  SITE NAME, LOCATION, AND DESCRIPTION

The Yeoman Creek Landfill (Landfill) Site  (Site) is located
between Sunset Ave./Golf Road on the north, Glen Flora Avenue on
the south, Lewis Avenue on the west, and Western Avenue on the
east, in the City of Waukegan, Illinois  (see Figure 1).  The
landfilled area covers approximately 60 acres.  The Site is
adjacent to a large wetland, and residential and commercial
developments, including single family residences, apartment
buildings, a nursing home, a doctor's office, a shopping center,
and restaurants.  Yeoman Creek flows through the Site and into
the Waukegan River 1.75 miles downstream from the Site.  The
Waukegan River flows into Lake Michigan approximately 2.25 miles
downstream from the Site.

The landfill was largely constructed within wetlands and also
within the flood plain of Yeoman Creek.   The landfill is still
partially within the floodway and flood plain of Yeoman Creek.
The landfill is fairly shallow with an estimated maximum depth, of
19 feet.  The total volume of landfilled waste has been estimated
to be over one million cubic yards.

The Site can be divided into two discontinuous portions.  The
portion north of the power lines and Greenwood Avenue  (see
Figures I and 2)  will be referred to as  the Yeoman Creek Landfill
portion of the Site,  and the portion south of the power lines and
Greenwood Avenue will be referred to as  the Edwards Field
Landfill portion of the Site.  The Yeoman Creek landfill portion
includes an estimated 49.2 acres of landfilled area,  and the
Edwards Field Landfill portion includes  an estimated 11.9 acres
of landfilled area.  These portions of the Site had the same
owner, operator,  and operational procedures,  as well as being in
close proximity to each other.

II.  SITE HISTORY AND ENFORCEMENT ACTIVITIES

The Site was operated as a municipal landfill .from 1958 through
1969.  The Edwards Field Landfill portion operated as a landfill
from 1958 through 1963, and the Yeoman Creek Landfill portion
from 1962 through 1969.  Some landfilling also occurred south of
Edwards -Field after 1962 and is considered part of the Site.

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The Illinois Environmental Protection Agency  (IEPA)  inspected
both portions of the landfill periodically during  the  1970s.
IEPA repeatedly reported violations of IEPA regulations  due  to
discharge of leachate to Yeoman Creek and inadequate cover
thickness at the Yeoman Creek Landfill portion.

As a result, IEPA eventually initiated an enforcement  action
against the City of Waukegan.  In 1981, additional cover was
placed over the Yeoman Creek Landfill portion, which generally
provided a two foot cover over the entire landfill.  According to
a draft IEPA report, this action reduced the amount of leachate
discharge.  Leachate discharges were also reported by  IEPA for
the Edwards Field portion of the Site prior to 1975.

From 1978 through 1981,  IEPA conducted a more thorough
investigation of the Yeoman Creek Landfill portion of the Site
(but not the Edwards Field portion),  including conducting
leachate,  ground water,  surface water, and stream sediment
sampling.   The result of most concern was that PCBs were detected
in the leachate,  stream sediment,  and ground water.  Later
sampling by U.S.  EPA during the 1980s confirmed the detection of
PCBs in the stream sediments, and leachate at the Yeoman Creek
Landfill portion.   Based on this information,  U.S. EPA added the
Yeoman Creek Landfill Site to the National Priorities List,  which
made the Site eligible for a federally funded investigation and
cleanup.  Later it was realized that the Edwards Field Landfill
portion should be part of the Site since it is in the vicinity of
the Yeoman Creek Landfill portion,  and had the same owner,
operator,  and operational procedures.

U.S.  EPA identified potentially responsible parties (PRPs)  for
the Site.   In December 1989,  U.S.  EPA and IEPA entered an
Administrative Order by Consent (Order)  with a number of PRPs
requiring the PRPs to conduct a Remedial Investigation/
Feasibility Study under U.S.  EPA and IEPA oversight,  and to
conduct certain interim remedial measures including implementing
erosion control measures and fencing the Site.   U.S.  EPA had the
lead in providing oversight.   The first action completed under
this order was fencing the known landfill boundaries to restrict
access, which was completed in 1990.   Erosion control actions
were also completed in 1990.

The agreement between U.S.  EPA and IEPA,  and the PRPs was amended

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in 1991 to add the Edwards Field area to the Site.  Subsequently,
use of this area for baseball playing was discontinued and  the
area was enclosed in a fence.

Sampling for the Remedial Investigation was conducted from  1991-
1993.  This included conducting soil borings to define the  extent
of the landfill,  a hydrogeological investigation, ground water
sampling, surface water sampling, sediment sampling, soil
sampling and landfill gas sampling.

In October 1992,  landfill gas sampling appeared to indicate that
landfill gases were migrating off-site and entering the basement
of an adjacent building.

During 1993 and 1994, under an amendment to the Order, PRPs
implemented interim measures to attempt to address this
situation,  including blocking gas entry through footing drains
and cracks in the floor, construction and operation of a basement
ventilation system,  and regular monitoring.

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION

A kickoff meeting for the Remedial Investigation/Feasibility
Study was held in October 1991.  News releases were provided to
the public in August 1992 and October 1992 regarding the
detection of landfill gases off-site and possibly entering an
adjacent building.   In addition,•an availability session was held
by U.S.  EPA regarding the landfill gas concerns and the general
progress of the investigation in July 1993.  In July 1994,  U.S.
EPA met with officials from the City of Waukegan,  the Waukegan
Park District,  and Waukegan School District #60,  who are
potentially responsible parties,  to listen to their concerns.

The public participation requirements of CERCLA section 113(k)(2)
(B)(i-v)  and 117  were addressed when a Proposed Plan was
published by U.S.  EPA in May 1995.   U.S.  EPA provided a public
comment period on the Proposed Plan from May 15,  1995 through
July 15,  1995,  and conducted a public meeting on the Proposed
Plan on June 1,  1995.  U.S.  EPA also met again with officials
from the City of  Waukegan,  the Waukegan Park District and
Waukegan School District #60 in August 1995.   U.S.  EPA's response
to the public comments received are summarized in the attached
Responsiveness Summary,  which is  part of this Record of Decision.

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IV.  SCOPE OF THE SELECTED REMEDY

Under the existing Order, interim measures have  already  been
taken to mitigate threats due to potential entry of  landfill
gases into an adjacent building, to restrict  access  to the  Site
by construction of a fence around the Site, and  to stabilize  the
Site by implementation of erosion control measures.   The PRPs
have also imposed deed restrictions over most of the  Site
property.

The purpose of this Record of Decision  (ROD)  is  to select the
final remedial actions for the Site.  This final remedy  is  a
source control remedy,  which contains or controls the landfill,
contaminated soils and sediments from the landfill, and  releases
of leachate and landfill gas from the landfill.  The  remedy
addresses all media and migration pathways that are considered to
present an unacceptable risk, including landfilled wastes;
contaminated soil and sediment;  and releases  to surface  water, to
ambient air,  to air within adjacent buildings, to ground water,
to surface sediments, and to wetlands.

This remedy does not include treatment that reduces toxicity,
mobility,  or volume as a principal element.  Because of  the size
of the landfill (over one million cubic yards), the costs for
excavation and treatment of the entire landfill would be
prohibitive.   In addition,  excavation and treatment of the  entire
landfill would entail significant public health and environmental
risks.   Therefore,  alternatives for excavation and treatment of
the entire landfill were not evaluated.   Available information on
the landfill  operations indicates that it would not be worthwhile
to attempt to locate concentrated areas of hazardous substance
disposal (hot spots).  Therefore,  alternatives were not  evaluated
for location and treatment or removal of hot spots in the
landfill.   In addition,  because the amount of ground water
contamination is limited,  the remedy does not includes direct
ground water treatment.

V.  SUMMARY OF SITE CHARACTERISTICS

Based on information available to U.S. EPA,  it appears that
wastes  deposited at the Site were predominantly typical,
putrescible municipal solid wastes,  but  wastes from industrial
and commercial facilities in the area were also disposed of at

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the Site.  Information available to U.S. EPA  indicates  that
wastes from industrial and commercial sources  included  waste  oil
that was likely contaminated with high concentrations of
polychlorinated biphenyls  (PCBs), spent  solvent, paint  wastes,
resin wastes, foundry sand, waste inks,  uncured  rubber, and auto
and truck repair wastes.1  U.S.  EPA has no firm evidence that
hazardous wastes as defined by RCRA were disposed  of at the Site.
Samples of the landfilled wastes were not collected, but leachate
concentrations were well below the regulatory  levels for
hazardous substances by characteristic under RCRA.  Evidence  from
depositions of persons using and operating the landfill, indicate
that hazardous or drummed wastes were not segregated on the Site,
but were deposited and compacted along with other  wastes that
were being buried at the time of disposal.

The soil borings were conducted along the perimeter of  the
landfill to determine the areal extent of the  landfilling.  This
investigation indicated that the landfilled area extends north of
the expected property boundaries along the north boundary of the
Yeoman Creek Landfill portion,  and south of the expected property
boundary of the Edwards Field Landfill portion (see Figure 2).

Borings were conducted to investigate the existing site cover
characteristics.   The existing cover is very flat over  almost all
of the Site.   The cover is from 2-4 feet thick, and generally
consists of low plasticity clays.  Samples of- the cap produced
laboratory hydraulic conductivity values of from 1.7 X  10~5 to
6'. 3 X 10"9 cm/sec, although the site cover also had desiccation
cracks.

The hydro-geological and ground water investigation included 32
borings and monitoring wells into the outwash, and two borings
and monitoring wells into bedrock.   The results indicate that the
geology is complex and locally variable  (see Figure 3 for a cross
section).   The shallow upper outwash unit is discontinuous at the
Site and may be only locally interconnected to the shallow ground
     1   There  is  firm  evidence  that  waste  oil  likely containing
high concentrations of PCBs was disposed of at the Yeoman Creek
Landfill portion of the Site,  but firm evidence for disposal of
waste oil likely containing PCBs is not available for the Edwards
Field portion of the Site.

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water unit at the Site, which the Remedial Investigation
consultant designated as the fluviolacustrine unit.  A  lower
outwash unit is continuous within the study area.  The  bedrock
units are isolated from the shallower flow systems by more  than
30 feet of till.  The shallow outwash, fluviolacustrine sands and
lower outwash meet the requirements for Class I aquifers pursuant
to 35 IAC 620.

The hydrogeological investigation showed that the landfill  is
connected to permeable portions of the shallow ground water, that
shallow permeable formations are connected to the deeper outwash
aquifer at the Site, and that most of the landfill leachate
either seeps into lower outwash aquifer or into Yeoman  Creek.
The shallow aquifer is discontinuous at the Site; so there may be
little communication between the shallow aquifer and the
contaminated shallow ground water at the Site.  The flow
direction in the shallow and deep outwash is primarily  to the
east toward Lake Michigan.  A horizontal flow direction in the
fluviolocustrine sands could not be determined.   The distribution
of chloride concentrations at the Site appears to confirm that
the Site is impacting the fluviolacustrine sands and the deep
outwash aquifer.

It is estimated that 88 percent of the Yeoman Creek Landfill and
69 percent of the Edwards Field Landfill is presently under the
water table.   Capping the Site may reduce the percentage of waste
below the water table to 37 percent at the Yeoman Creek Landfill
and 46 percent of the Edwards Field Landfill.

Ground water is not used in the vicinity of the  Site,  and a City
of Waukegan ordinance requires use of the municipal system for
residential water within the City.   The ground water is used for
residential purposes in Beach Park approximately two miles from
the Site.   Based on available information,  it does not appear
that ground water from the Site has the potential to affect these
residential wells.

According to Colder Associates,  Yeoman Creek is  a gaining stream
along the Yeoman Creek Landfill portion,  but appears to be a
losing stream south of the Yeoman Creek Landfill portion (see p.
48 of the Remedial  Investigation Report,  Yeoman  Creek/Edwards
Field landfills.   Waukegan.  Illinois.  February 1995 by Colder
Associates).   Landfilled wastes are present within a few feet of

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 Yeoman Creek along the Yeoman Creek Landfill portion, including
 within approximately 10 feet of Yeoman Creek along an estimated
 600 feet of the total of 3200 feet of the Yeoman Creek Landfill
 portion bordering Yeoman Creek.  At the Edwards Field portion,
 there is at least a 30 foot buffer between the landfilled wastes
 and Yeoman Creek.

 PCBs were detected in wetland soils,  stream sediments, stream
 water,  and leachate,  but were not detected in the ground water.
 The highest concentration of PCBs detected in surface soils
 outside the fenced area was 2 mg/kg,  the highest concentration in
 stream sediments was 82 mg/kg,  and PCBs were only detected in one
 surface water sample at a concentration of 0.5 ug/1.   The PCB
 concentrations in stream sediments were highest adjacent to the
 Yeoman Creek Landfill portion,  and dropped off to non-detect
 concentrations past the Edwards Field Landfill portion (see
 Figure 4).   PCBs were detected in all three of the leachate seep
 samples at the Yeoman Creek Landfill  portion with a maximum
 concentration of 71 ug/1.   PCBs were  detected in all  four leach-
 ate seep soil samples at the Yeoman Creek Landfill portion at a
 maximum concentration of 90 mg/kg.   PCBs were detected in all
 four leachate well samples at the Yeoman Creek Landfill portion
 at  a maximum concentration of 190 ug/1.   However,  no  PCBs were
 detected in the four leachate seep soil samples collected at the
 Edwards Field Landfill portion (no liquid seep samples 'could be
 collected at the Edwards Field Landfill portion) ..  PCBs were only
 detected in one out of the three leachate well samples collected
 in  the  Edwards Field Landfill portion at a concentration of only
 0.5 ug/1.   In addition,  no PCBs were  detected in the  wetland soil
.samples south of the  Edwards Field Landfill portion.

 Other contaminants and characteristics of concern and their
 maximum detected levels include:

      In landfill gas:

           explosivity (100% LEL);
           benzene (1.2 mg/m3) ;
           trichloroethylene (0.087  mg/m3);
           tetrachloroethylene (0.051  mg/m3);
           vinyl chloride (not detected in landfill gas but
                detected in.gas  entering an adjacent building at
                52 ppbv).

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In ground water;

     arsenic  (284 ug/1);
     beryllium  (3.8 ug/1);
     lead (103 ug/1);
     manganese  (2860 ug/1);
     vinyl chloride (3 ug/1);
     benzene  (20 ug/1);
     pentachlorophenol  (2 ug/1);
     bis(2-ethylhexyl)phthalate  (10 ug/1).

In surface water:

     acetone  (19,000 ug/1);
     cyanide  (20.7 ug/1).

In wetland soils located east of Yeoman Creek  and  south  of
the Yeoman Creek Landfill portion:

     benzo(a)pyrene (0.82 mg/kg);
     lead (209 mg/kg);
     zinc (307 mg/kg);
     polyaromatic hydrocarbons  (PAHs)  (4.9 mg/kg).

In wetland soils, south of the Edwards  Field portion:

     benzo(a)pyrene (8.2 mg/kg);
     lead (1100 mg/kg);
     zinc (874 mg/kg);
     PAHs (88 mg/kg).

In Yeoman Creek sediments:

     benzo(a)pyrene (1.6 mg/kg);
     lead (257 mg/kg);
     zinc (1770 mg/kg);
     PAHs (24 mg/kg);

In leachate  seeps in Yeoman Creek Landfill portion:

     acetone (11 ug/1);
     cyanide (234 ug/1);
     lead (135 ug/1);

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     zinc  (351 ug/1).

In seep soils in  the Yeoman  Creek  Landfill portion:

     acetone  (0.1 mg/kg);
     cyanide  (1.3 mg/kg);
     lead  (127 mg/kg);
     zinc  (176 mg/kg);
     PAHs  (72 mg/kg).

In seep soils in  the Edwards Field Landfill portion:

     acetone  (not detected);
     cyanide  (not detected);
     benzo(a)pyrene  (1.8 mg/kg);
     lead  (427 mg/kg);
     zinc .(451 mg/kg) ;
     PAHs  (42 mg/kg).

In leachate wells in the Yeoman Creek  Landfill  portion:

     arsenic  (27.6 ug/1);
     beryllium (1.6 ug/1);
     lead  (953 ug/1);
     manganese (1120 ug/1);
     benzene  (21 ug/1);
     bis(2-ethylhexyl)phthalate (67 ug/1);
     acetone  (320 ug/1);
     zinc  (1460 ug/1).

Leachate wells in the Edwards Field Landfill portion:

     arsenic  (9.6 ug/1);
   •  lead  (132 ug/1);
     manganese (327 ug/1);
     trichloroethylene  (3 ug/1);
     tetrachloroethylene (3 ug/1);
     1,2-dichloroethylene  (3 ug/1);
     1,2-dichloroethane  (3 ug/1);
     benzene  (21 ug/1);
     bis(2-ethylhexyl)phthalate (22 ug/1);
     acetone  (34 ug/1);
     zinc  (466 ug/1).

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VI.  SUMMARY OF SITE RISKS

A.  ESTIMATED HUMAN HEALTH AND ECOLOGICAL RISKS  IF  CURRENT  SITE
CONDITIONS CONTINUE IN THE FUTURE:

At this time the ground water in  the vicinity of  the  Site is
unused, and it appears that it is unlikely  to be  developed  in  the
future since a City of Waukegan ordinance requires  use  of
municipal water for residential purposes.

The municipal water supply is from Lake Michigan.   There are
residential ground water users approximately two-miles
downgradient from the Site in Beach Park, although  it is unclear
whether ground water from the Site can affect these wells.
The Site is fenced, and deed restrictions have been placed  over
most of the Site.

The deed restrictions placed reportedly permanently prohibit
future development.  As a result, risks to  human  health if
current Site conditions continue  in the future are  limited.

For adjacent residents the incremental lifetime cancer  risk  (ICR)
was estimated to be 3.1 X 10~6 using average exposure  assumptions
(average),  and 2.5 X 10~5  using reasonable  maximum  exposure
assumptions (RME).   A large portion of this risk  is due to
potential for landfill gas migration into adjacent  buildings.
Presently,  this risk is being addressed by  monitoring in adjacent
buildings north of the Yeoman Creek portion of the  Site, and
operation of a ventilation system in one building.  The remainder
of the estimated risk is primarily due to potential for direct
contact with PCBs  and benzo(a)pyrene in surface soils,  and
surface water in the vicinity of the Site.

The risks to ecologic receptors was evaluated using potential
effects or. nesting red-winged black birds,  and to mink.  The risk
to ecological receptors if current conditions continue  in the
future appears, to  be substantial.  The evaluation indicated that
risks due to potential contact with soil and sediments  associated
with the site that are contaminated with PCBs,  lead, polyaromatic
hydrocarbons,  lead,  and zinc,  and surface water contaminated with
cyanide ar.d acetone may have a detrimental  impact on some
ecological  receptors.

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B.  'ESTIMATED RISKS IF GROUND WATER  IS DEVELOPED  FOR  RESIDENTIAL
PURPOSES IN THE FUTURE:

As stated previously the ground water in the vicinity of  the  Site
is currently unused.  However, if the ground water  in the
vicinity of the Site is developed in the future,  the  human  health
risks would be unacceptable.  Existing information  indicates  that
the shallow ground water is unlikely to be useable  for
residential purposes,- but that the deeper outwash aquifer most
likely could be developed for usage by a limited  number of
residences.  The distribution of chloride concentrations  appears
to indicate that the landfill has impacted both the shallow and
deep outwash formations.  Hazardous substances of concern
detected in ground water near the Site include arsenic,
beryllium,  manganese,  lead, benzene, bis(2-ethylhexyl)phthalate,
pentachlorophenol,  and vinyl chloride.  For lifetime  residential
usage of the shallow aquifer ground water,  the ICR  is  estimated
to be 8.7 X 10"5 and non-carcinogenic hazard index (HI) 6.3
(average),  and 4.6 X ICT4 and 16  (RME) .

For lifetime residential usage of the deeper aquifer,  the ICR is
estimated to be 5.1 X ICr5 and the HI 2.0 (average), and ICR 2.9
X ID'4 and HI 5.2 (RME).  In addition, lead exceeded the Illinois
Ground Water Quality Standards (IGWQS)  in some aquifer samples.
It should be noted that no PCBs were detected in ground water.

The extent to which these estimated risks,  in the case of future
residential ground water usage is attributable to the Site  can
not be fully defined using the available data.

Although it is possible that arsenic, beryllium,  and pentachloro-
phenol are being released from the Site,  these constituents do
not appear to have been detected at significant concentrations in
leachate samples.   Arsenic was not detected above the IGWQS,
either in leachate or aquifer samples,  and may be associated with
background and solids  in the aquifer.  Beryllium was detected in
leachate samples,  but  only slightly above detection limits,  and
was only detected above the Maximum Contaminant Level  (40 CFR
141)  in one of the 72  (1/72)  site-related aquifer samples.  Some
data indicates that at least some of the arsenic and beryllium
are associated with solids in the aquifer.   The range of arsenic
concentrations near .the Site is also similar to the range in
ground water samples collected from the Lake County region.

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Pentachlorophenol was detected at a very low concentration in
only one leachate sample, and was detected in 2/72 site-related
ground water samples at concentrations below the Contract
Required Quantification Levels  (CRQLs) above the IGWQS.

If arsenic, beryllium, and pentachlorophenol are not considered,
the ICR for the shallow ground water is reduced to 1.3 X 10"5
(average)  and 7.0 X 10;5  (RME).  These estimated risks  are
apparently due to releases of benzene, bis(2-ethylhexyl)phthalate
and vinyl chloride  (or vinyl chloride precursors)  from the Site,
which has resulted in sporadic detection of these compounds in
the aquifer.  Benzene was detected in leachate, and in 8 samples
from three shallow monitoring wells along the perimeter of the
landfill,  and exceeded the IGWQS in three samples from one of the
monitoring wells.  Bis(2-ethylhexyl)phthalate was detected in
leachate,  and in 5/72 site-related aquifer samples at concentra-
Otions below the CRQL.  Vinyl Chloride was not detected in the
leachate although trichloroethylene and tetrachloroethylene,
which can degrade to vinyl chloride,  were detected in leachate.
Vinyl chloride was detected in two shallow ground water samples
from the perimeter of the Site at concentrations below the CRQL
but at or above the IGWQS.

Lead was present in elevated concentrations in leachate samples
and exceeded the IGWQS of 7.5 ug/1 in 16/37 shallow ground water
samples, and in 4/27 deep outwash samples.   The highest
concentration was 124 ug/1.   However,  lead also exceeded the
IGWQS in 1/6 background ground water samples (25 ug/1)  and
appears to be strongly associated with solids in the aquifer.
Some of the lead detected may be from the Site,  but may be
difficult to mobilize for residential exposures due to lead's
affinity for solids.

The estimated non-carcinogenic risk is predominantly due to
manganese.   The manganese was as high as 1120 ug/1 in leachate.

The IGWQS of 150 ug/1 was exceeded in 35/42 shallow ground water
samples with a maximum concentration of 2600 ug/1,  and in 12/30
lower outwash samples with a maximum concentration of 2900 ug/1.
However, manganese was also  exceeded the IGWQS in 5/6 background
ground water samples with a  .maximum of 830  ug/1.   In addition,
data appears to indicate that much of the manganese is associated
with solids in the aquifer,  and that the range of  manganese

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                                13

detected at the Site is similar to the range of ground water
concentrations detected in Lake County, if the samples with the
highest total suspended solids .are excluded.

C. ESTIMATED RISKS IN CASE OF DEVELOPMENT OF THE PERIMETER OF THE
SITE IN THE FUTURE:

If the perimeter of the Site is developed in the future  for
residential purposes and ground water is not used, the estimated
ICR is estimated to be 3 .2 X 1CT6  (average) and 7.4 X  ICr5 (RME) .
These risks are primarily due to potential exposure to PCBs in
soil.  Some of the estimated risk is also due to benzo(a)pyrene
and benzo(b)flouranthene in soil,  PCBs in surface water, and
benzene and vinyl chloride in landfill gas.  If residential
ground water usage is also assumed, these risks should be added
to the ground water risks.

D.  RISKS IN CASE SITE IS DEVELOPED IN THE FUTURE:

At this time it appears very unlikely that the Site will be
developed in the future.  However, for a number of reasons it is
very likely that,  absent the waste disposal on the Site, the Site
would have been developed for residential, recreational,
commercial,  and/or governmental purposes  (or in the case of
Edwards Fields Landfill use as a baseball field would have
continued).   These reasons include:

     the Site is flat and surrounded by residential and'
     commercial development,  including other properties that
     filled in low areas to allow such, construction;

     the City transferred the property to the School Board
     because of plans to build a school on the Site;

     until recently the Edwards Field Landfill and surrounding
     area was a little league ball park;

     until recently portions of the landfill adjacent to the
     School  Board property were being advertised for sale;

     a portion of the landfill is  presently being used as a
     parking lot,-

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                                14

 .  -  property transfers have occurred without  knowledge of  the
     presence of landfilled waste on the property.

There are a number of reasons why normal residential,  commercial
or governmental development on the Site would  result  in an
unacceptable risk.  One concern is that landfill gas  entry  would
cause an explosion risk.  In addition, landfill gas entry into a
building could result in an unacceptable risk  from long term
exposure via inhalation.  For example, use of  the equation  for
exposure to soil gas using a distance of one foot from the  source
would result in an estimated ICR of 2.6 X 10~4  (average) and 7.8
X  10~4  (RME).  Data on actual concentrations of contaminants in
the landfill are unavailable.  However, it is.certainly expected
that contaminant concentrations would be many  times higher  in
some locations in the landfill than the concentrations detected
in the leachate or leachate seep samples.  This would  result in a
very high risk due to potential dermal and ingestion exposures to
these contaminants in case the Site was developed.  The potential
risks from future ground water usage at the Site has already been
discussed.

Based on the results of the risk assessment, the objectives of
the remedial actions include addressing the following  risks:

     human health risks in case of future development  of the
     Site;

     human health risks due to off-site landfill gas migration;

     human health and ecological risks due to  the continuing
     releases of hazardous substances to wetlands, Yeoman Creek,
     and the ground water (this includes meeting drinking water
     standards in the aquifers at the Site);

     human health risks from.off-site soil contamination;

     ecological risks due to contamination of  sediments and
     limited wetland areas.
VII.  DESCRIPTION OF ALTERNATIVES:

A. OVERVIEW:

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                                15

Because of the size of the landfill  (over one million cubic
yards), the costs for excavation and treatment of the entire
landfill would be prohibitive. In addition, excavation and
treatment of the entire landfill would entail significant public
health and environmental risks.  Therefore, alternatives for
excavation and treatment of the entire landfill were not
evaluated.

In addition, available information on the landfill operations
indicates that industrial wastes were disposed of along with the
residential and commercial wastes.  Because of this and the
difficulty in locating hot spots within a landfill, alternatives
were not evaluated for location and treatment of hot spots in the
landfill.

As a result, the Feasibility Study concentrated on alternatives
for containment of the landfill -- that is measures to prevent or
minimize migration of contaminants from the landfill to the
ground water,  wetlands,  surface water,  and air.   Containment
technologies evaluated in detail for the Yeoman Creek Landfill
Site include use of the following technologies:

     site covers having single barrier clay and membrane liners,
     and having composite clay and membrane liners to minimize
     formation of leachate generated by infiltration of
     precipitation through the landfill;

•  -  leachate collection systems to intercept,  remove and treat
     any leachate before entering Yeoman Creek whether the
     leachate is formed by precipitation,  ground water movement,
     or changes in stream water level elevations;

     artificial channels to provide a barrier to entry of
     landfill leachate into Yeoman Creek;

     slurry walls to prevent off-site migration of contaminated
     ground water;  and

     passive and active landfill gas ventilation systems to
     prevent off-site migration of landfill gas  in the
     subsurface.

The alternatives evaluated in detail,  except for the no-action

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                                16

 alternative,  include  combinations  of  the. above listed
 technologies.

 B. ACTIONS  COMMON  TO  ALL  CAPPING ALTERNATIVES:

 All  of  the  alternatives,  including the  no-action alternative,
 include imposition of deed  restrictions and access  restrictions
 over all  of the  Site  property  and  enclosing the site  with a
 fence.   In  addition,  all  of the capping alternatives  include
 additional  investigation, long term monitoring,  remediation of
 contaminated  sediments in Yeoman Creek  and limited  wetland areas,
 compliance  with  floodway/floodplain regulations,  remediation  of
 contaminated  surface  soils  outside of the new cover area,
 compensation  for loss or  damage to wetlands,  rerouting  and
 sealing of  existing storm drains that go through the  landfill,
 and .continuation of interim actions to  control and  monitor
 landfill  gases until  the  final remedial action is implemented and
 demonstrated  to  be effective.

 While source  control  (i.e.  the landfill cover)  will provide a
 mechanism for preventing  future ground  water  contamination,
 natural attenuation will  address existing ground water
 contamination.

 1. Additional Investigation:

.Additional  ground  water investigation shall be conducted,  as
 necessary to determine the  extent  of ground water contamination.
 If necessary, sampling of Yeoman Creek  sediments, limited  wetland
 soils,  and'  soils that will  be  outside of  the  site cover that  may
 be contaminated  by leachate  seeps,  will  be  conducted  to determine
 the  extent  of contamination  exceeding the  cleanup action  level.
 In addition, verification sampling will  be  conducted, as
 necessary,  to test  whether  cleanup action  levels  are  attained
 following the remedial action.  The baseline  quality  of the
 wetlands  south and east of  the Site will  be assessed  to enable
 evaluation  of the  long term  impacts of  the  landfill.

 2.  Long  Term Monitoring:

 Long term monitoring  of the  ground water, Yeoman  Creek, landfill
 gas emissions, 'and wetlands  will be conducted.

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                                17

3.  Remediation of contaminated sediments  in Yeoman  Creek  and
limited wetland areas, and of surface soils outside  of  the
wetland and site cover area:

U.S. EPA and IEPA have determined that major disturbance of  the
large area of wetlands located south and east of  the Site  to
remove contaminants is not warranted to address the
concentrations of hazardous substances detected in the  wetlands
due to the potential adverse impact on the wetlands.2

For the sediments in Yeoman Creek and the  limited wetland  areas
shown in Figure 5, and for surface soils outside  of  the wetland
areas and the site cover area, U.S. EPA has established cleanup
action levels (CALs)  to address contamination that is
significantly adding to risks to ecological receptors.  An
explanation of these CALs is included in Attachment  1.  Landfill
cover Alternatives #2-#5, include excavation of sediments  that
exceed these CALs, consolidation and temporary containment of the
excavated sediments on the Site,  and final containment under the
final site cover.

By this Record of Decision, the Regional Administrator has waived
the TSCA disposal requirements of 40 CFR 761.75(b)(1),(2),(3) and
(7) .

It is anticipated that for temporary containment  of  excavated
sediments,  a berm will be constructed around designated areas on
the Site.   The excavated sediments will be placed within these
bermed areas to a depth not to exceed 1 foot.  After the
excavated sediments have dewatered to a consistency  that can
support low ground pressure earthwork equipment,   the sediments
will be covered with at least 6 inches of clean soil.

Additional sampling will be conducted of the Yeoman  Creek
sediments and in limited wetland areas,  and surface  soils that
     2   Maximum concentration of  various  hazardous  substances
detected in wetland soils were: PCBs = 2 mg/kg in surface soil,
and 5.5 mg/kg at 6-12 inches below the surface; benzo(a)pyrene =
0.82 mg/kg; benzo(b/k)flouranthene = 1.9 mg/kg; cumulative
polyaromatic hydrocarbons = 8.9 mg/kg; lead = 209 mg/kg;  mercury
= 0.31 mg/kg; and zinc = 307 mg/kg.

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                                18

may have been affected by leachate seeps and are  located outside
wetland areas and the site cover  area to determine  the extent of
excavation.  Based on sampling data available,  it appears that
between 900 and 3000 feet of stream sediments will  have to be
excavated and 40,000 square feet  of sediments south of Edwards
Field Landfill.  Assuming that contaminated sediments are
excavated to a 12 inch depth and  1200 feet of stream sediments 10
feet wide are excavated, approximately 2000 cubic yards of
sediments would be excavated at an estimated cost of
approximately $ 200,000.  This cost will be partially offset by a
reduction in the quantity of soil needed to bring the landfill
cover to an acceptable grade.

As an Alternative to the limited  excavation described above,
excavation and on-site consolidation and containment of all
sediments and the limited wetland areas shown in Figure 5 may be
conducted if necessary to comply with floodplain/floodway
regulations as described in the following section.  In this case
sampling to determine the extent of excavation will not be
required.

An evaluation of the effects of the excavation on the wetland
hydrology will have to be conducted.   No adverse effects on the
wetland hydrology will be allowed.

4.  Compliance with floodplain/floodway regulations:

Work shall be conducted to comply with the Illinois Department of
Transportation (IDOT)  regulations (92 IAC 708)  and Lake County
Storm Water Management Commission (SMC)  Watershed Development
Ordinance.  The remedial design phase shall include the
additional investigation,  modeling,  alternative evaluation,  and
work with the regulatory Agencies to  select procedures for
compliance with the floodway/floodplain regulations.  The
required additional investigation, modeling and alternative
evaluation shall be determined by U.S.  EPA,  largely based on
input from IDOT and the SMC.

Compliance with the requirements of  the SMC will entail remapping
the floodplain because the current FEMA floodplain map is out of
date (it does not include the filling that took place during
oneration  of the landfill).

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                                19

Following completion of the additional evaluation and work with
IDOT and SMC, U.S. EPA will select the actions to be implemented
for compliance with the floodplain/floodway regulations.  The
selected actions will largely be  based on input from IDOT and the
SMC.

All of the site cover alternatives  (#2-#5) have the potential to
include filling within the regulated floodway/floodplain in order
to construct the site cover.  Alternatives #3, 3A-3D, 4, 4A, and
4B have the potential for more floodway/floodplain filling than
Alternative #2 because additional filling would be conducted to
provide a 2% slope after settling and a 3 foot instead of a two
foot cover would be added over the grading layer.  Alternative #5
has the potential. for even more floodway/flood plain filling
since this Alternative includes additional filling to provide a 3
% slope after settlement and a 5  foot cover over the grading
layer.  New construction within a floodway and floodplain is
regulated by IDOT and the SMC.  The SMC regulations are more
stringent than the IDOT regulations, and among other provisions
require the following:

     providing compensatory storage for all lost floodplain
     storage at a 1.2 to 1 replacement ratio;

     prohibiting increase in flood height or velocity;

     maintenance of the flood carrying capacity (conveyance)  of
     the floodway.

The IDOT regulations are similar but require compensatory storage
for only lost floodway storage at a 1 to 1 replacement  ratio.

Compliance with the IDOT and SMC floodway/floodplain regulations
may be achieved for Alternatives #2 -  #5 by one or by a
combination of the following:

 a.   Creation of compensatory storage  for lost floodplain
     storage;

 b.   Use of artificial channels combined with detention
     facilities to maintain capacity without increasing the
     average velocity through the Site;

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                                20

 c.  Limited excavation of soil and/or landfill wastes out of the
     floodway/floodplain, consolidation on-site, and containment
     under the new site cover;

 d.  Approval of a variance by the regulatory Agencies.

In the Feasibility Study dated December 1994, Colder Associates
estimated that compliance with the IDOT regulations will require
creation of 6,880 cubic yards of compensatory floodway storage.
Colder proposes that a reasonable way to comply with this
requirement would be creation of compensatory floodway storage by
excavation of sediments in Yeoman Creek and the limited wetland
areas defined in the previous section.  Colder estimates that
excavation of these areas to a 2.5 foot dept would create 7,220
cubic yards of compensatory storage at an estimated cost of
$374,883 for excavation,  consolidation and temporary containment
on-site.  This is $170,000 more than the estimated cost for
excavation,  consolidation and temporary storage solely for
compliance with the sediment cleanup action levels.

To comply with the SMC regulations by creation of compensatory
storage, it is estimated that 30,000  cubic yards of compensatory
storage will have to be created.   Colder has estimated that this
volume of compensatory storage could be created in the golf
course north of the Site at an estimated cost of $652,200.

The sediment and limited wetland excavation as described for
compliance with the IDOT regulations could also be used toward
compliance with the SMC regulations.

Another action that could be used towards compliance with both
the IDOT and SMC regulations,  is  limited excavation of wastes at
the limits of Yeoman Creek,  or at the fringes of landfilled
wastes.   These wastes would be consolidated and temporarily
contained on-site until the new site cover is installed over the
wastes.

The excavation of wastes  may cause short term odors in the
vicinity of  the Site,  and create  some potential for releases to
the surface  water.   These problems should be controllable if the
extent of waste excavation is limited.   The costs for sediment
and waste excavation and  containment  on-site would be partially
offset by a  reduction in  the quantity of soil needed to provide

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                                21

an adequate grade for the new site cover.

Article V of the SWC Watershed Development Ordinance provides
criteria for obtaining a variance from the SMC requirements.
However, no waivers or variances are available for the  IDOT
regulations.

5.  Compensation For Loss or Damage To Wetlands:

The landfill cover alternatives  (#2-#5),  include filling  an
estimated relatively small area of on-site wetlands.  This impact
on existing wetlands will require compensation or replacement or
some other compensatory action pursuant to Section 404  of the
Clean Water Act.

Any other detrimental impact on wetlands from the remedial
actions, such as the soil excavation in the limited wetland
areas, that can not be mitigated, will also require compensation.

The run-off from the site cover will be adjusted to prevent
degradation to and,  if possible, enhance ecological conditions in
the large wetlands south and east of the Site.  It is anticipated
that the cost of this portion of the remedy will be minor.

6.  Rerouting and Sealing Of Storm Drains That Go Through the
Landfill:

Storm drains  that go through the Landfill shall be rerouted
around that landfill and sealed.  It is expected that two
existing storm drains that go through the "Yeoman Creek Landfill
portion will  have to be rerouted and sealed (see Figure 6).   It
is estimated  that this will cost $85,000  for Alternative 2,
$110,000 for  Alternatives 3,  3A, 3B,  3C,  4,  4A,  and 4B,  and
$165,000 for  Alternative 5.   Drains that  originate on-site will
be covered by the new site cover, and so  will not need to be
rerouted or sealed.

7.  Continuation of  Interim Actions to Address Landfill Gas
Migration:

Periodic monitoring  of a number of buildings north of the Site
for landfill  gas  entry,  and construction  and operation of
ventilation systems  in buildings north of the Site,  where

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                                22

potential landfill gas entry is detected, have been implemented
during completion of the Remedial Investigation/Feasibility
Study.  Implementation of these measures will continue until the
active landfill gas system is constructed and demonstrated to be
effective in eliminating off-site landfill gas migration.

C.  Alternative Evaluation

1.  ALTERNATIVE 1, -ACCESS RESTRICTIONS AND INSTITUTIONAL
CONTROLS:

 a.  DESCRIPTION:  Under this alternative,  deed restrictions
     would be imposed to prohibit use of, access to, and future
     development of the Site property, and the Site would be
     fenced.  This alternative would not involve any filling of
     wetlands nor filling within the floodplain.  Human health
     risks would be reduced by limiting access to the Site.
     However, risks to ecological receptors would not be
     addressed; leachate seepage into the ground water, Yeoman
     Creek and the wetland would continue unabated; landfill gas
     migration into the basement of an adjacent building would
     continue; and the landfill may be subject to erosion damage
     in the future.

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS       :  $    46,000
          ANNUAL O&M COSTS         :  $     5,600
          PRESENT WORTH            :  $  '120,000
          IMPLEMENTATION           :  a few months

2.  ALTERNATIVE 2, SITE COVER INCLUDING A BARRIER LAYER OF TWO
FEET OF LOW PERMEABILITY SOIL,  and PASSIVE GAS VENTILATION
SYSTEM:

 a.  DESCRIPTION:  The objective of any Site cover is to reduce
     generation of contaminated leachate that may migrate to
     ground water or the surface water,  by reducing infiltration
     through the cover,  and to eliminate the risks of direct
     contact with the  wastes.   The barrier layer to infiltration
     of precipitation  for Alternative 2  would consist of two feet
     of lew permeability soil (see Option 1 in Figure 7).
     Alternative 2 will have a minimum slope to promote run-off

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                                23

     of precipitation.

     Pipe vents would be installed into the landfill to provide a
     direct route of release for landfill gases, which would
     reduce the likelihood of off-site migration of landfill
     gases.

     The soil cover would reduce infiltration, and would at least
     temporarily eliminate direct contact with leachate seepage
     and soils near existing seeps.  However, the reduction in
     infiltration would be modest even under ideal conditions,
     and this type of cap is susceptible to cracking due to
     desiccation,  freezing and other causes.  It is possible that
     leachate seeps would eventually reemerge through the sides
     of the landfill.  The passive vents may not completely
     eliminate off-site migration of landfill gases.  In
     addition, some .of the landfill gases would be emitted near
     commercial and residential developments.  This may cause an
     odor concern, and a hazard to off-site residents.

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS       :  $ 6,700,000
          ANNUAL O&M COSTS         :  $   240,000
          PRESENT WORTH            :  $ 9,900,000
          IMPLEMENTATION           :  3-years

3.   ALTERNATIVE 3, SITE COVER INCLUDING A BARRIER LAYER
CONSISTING OF A FLEXIBLE MEMBRANE LINER,  AND PASSIVE PERIMETER
GAS VENTILATION SYSTEM:

 a.  DESCRIPTION:   The site cover's barrier layer would consist
     of a flexible membrane liner (FML)  placed over a permeable
     gas ventilation layer.   It is  anticipated that a 40 mil very
     low density polyethylene (VLDPE)  FML would be used for the
     barrier layer.   The barrier layer will underlie a
     geosynthetic  drainage layer having a hydraulic conductivity
     of 28 cm/sec.  In addition,  a  grading layer would  be added
     to provide the cover with a 2% slope after settlement,  and a
     three foot frost protection layer would be placed  over the
     FML (see option 4 Figure 7).   A passive perimeter  trench
     system  would  be used to control  off-site migration of
     landfill gases.

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                           24

Modeling indicates that this cover  could be very effective
in reducing infiltration through the'landfill due  to
precipitation as long as the FML overall quality is good.
For example, if the leakage  fraction  is Id'5,  the HELP
modeling included in the Feasibility  Study predicts a 99.4%
reduction in infiltration compared  to current conditions.

This corresponds to a reduction in  total infiltration from
1,800,000 cubic feet to 11,500 cubic  feet per year over the
portion of the landfill east of Yeoman Creek.  Some factors
argue for assuming a low leakage fraction, such as the
shallow depth of the landfill and the age of the landfill,
which will probably limit the amount  of settlement due to
further decomposition of the wastes.  In addition,  strict
quality control measures can be required during installation
of the FML to reduce the occurrence of leaks, and which
should result in construction of a  good quality FML cap.

However, leaks through FML liners always occur,  and the
results of this can result in substantial leakage through
the FML, if the FML is underlain by a permeable layer, as is
proposed for this site cover alternative.   This is
demonstrated in Figure 2-4 of Design and Construction of
RCRA/CERCLA Final Covers.  U.S.  EPA,  May 1991. As can be seen
the flow rate through holes in FMLs can increase from 330
gal/acre/day for excellent FMLs to  10,00'0  gal/acre/day for
poor quality FMLs.   This is also demonstrated using site
specific HELP model assumptions in Table 1,  which predicts
that infiltration would increase from 12,000 cubic feet for
a good/excellent quality FML to 276,000 cubic feet for a
poor quality FML.

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                                25
                             TABLE  1
                COMPARISON OF  INFILTRATION  RATES
          FOR FML AND COMPOSITE FML/CLAY  BARRIER  LAYERS
     FOR GOOD AND POOR QUALITY FMLS USING HELP  MODEL3
TYPE OF
BARRIER
FML
FML/GCL
FML/2-feet
compacted clay
@ HC=l(r7cm/sec
INFILTRATION ASSUMING
10-5 LEAKAGE FRACTION4
% REDUCTION5 CUBIC FT
99.4% 12,000
100.0% 0
100.0% 2
INFILTRATION ASSUMING
10-3 LEAKAGE FRACTION6
% REDUCTION CUBIC FT
84.9% 276,000
100.0% 15
100.0% 141
     3   Help Model Assumptions are shown in Appendix B, of the
December 1994 Feasibility Study for the 10~5  leakage  fraction
runs.  The 10"3 leakage  fraction used  the  same  assumptions  as the
corresponding run in Appendix B, except for  changing the leakage
fraction.

     4   According to Table 2-4 of  Design and Construction of
RCRA/CERCLA Final Covers. U.S. EPA, May 1991,  good to  excellent
quality FML  (or geomembranes) can be characterized by  having one
1 cm2 to 0.1 cm2 hole per  acre.  According to Figure  9-8 of the
same reference,  this corresponds to a leakage  fraction in  the
vicinity of 10~5.

     5   Cubic feet of infiltration using new cap divided by the
cubic feet of infiltration under existing conditions times  100.
Cubic feet of infiltration was estimated using the HELP model

     6   According to Table 2-4 of  Design and Construction of
RCRA/CERCLA Final Covers. U.S. EPA, May 1991, poor quality  FMLs
(or geomembranes) can be characterized by having 30 0.1 cm2 holes
per acre.  According to Figure 9-8 of the same reference,  this
corresponds to a leakage fraction in the vicinity of 10~3,
assuming a 0.33  foot head.

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FML/2-feet
compacted clay
@ HC = 10";cm/sec
                              26
100.0%            14
99.9%        1,374
    Since 30-40%  of  the landfill wastes will remain below the
    water table even after the leachate mound in the landfill
    dissipates, some leachate will be generated from movement of
    ground water  through the wastes.   In the Feasibility Study,
    Colder Associates,  Inc.  estimated that the maximum ground
    water flow through the east side  of the landfill would be 5
    gpm,  which corresponds to approximately 350,000 cubic feet
    per year and  .16% of the  estimated flow through the landfill
    due co infiltration of precipitation under existing
    conditions.   Leachate generated by ground water flow would
    continue to recharge the ground water and possibly Yeoman
    Creek.   However,  Colder  believes  that "potential for ground
    water flow through the waste would be minimal" (see p.  38 of
    the Feasibility  Study Report,  Yeoman Creek/Edwards Field
    Landfills,  Waukegan.  Illinois), December 1994 by Colder
    Associates (Colder).   Colder believes that the eastern
    portion of the Landfill  is largely isolated from the shallow
    ground water  flow system,  and the flow through the western
    portion of the landfill  may be much less than 5 gpm.

    The substantial  reduction in infiltration using a cap with
    an  FML barrier layer would reduce impacts on the ground
    water.   However,  some ground water impact will continue as a
    result of  the apparently limited  ground water flow through
    the landfill  and the amount of infiltration that gets
    through leaks in the FML.   The aquifers near the Site would
    likely meet the  ground water remediation goals over time
    (except for parameters that naturally exceed the goals)  as a
    result of  reduction of the source,  natural biodegradation,
    and other  natural  attenuation mechanisms.

    Surficial  leachate  seeps would be eliminated as a result of
    the reduction in leachate generation and placement of
    additional cover materials over the top,  and would be
    unlikely to emerge  because of  the substantial reduction in
    leachate formation.   However,  leachate would continue to
    recharge Yeoman  Creek through subsurface routes during  the

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                                27

     period of time when the leachate mound is dissipating.  Some
     leachate would also be generated from the ground water
     movement through the landfill, infiltration through the site
     cover, and variations in the water level in Yeoman Creek.
     Some of this leachate may seep into Yeoman Creek especially
     along the Yeoman Creek Landfill portion, where Yeoman Creek
     is a gaining stream.

     The passive landfill gas ventilation system would provide
     confidence that landfill gas would not migrate off-site.
     However,  the landfill gas vents would be located along the
     perimeter of the Site near residential and commercial
     developments.   This may cause an odor concern, and a hazard
     to off-site residents.

     It is possible that some of the soils excavated for the
     landfill gas ventilation system would contain PCBs at
     concentrations equal to or exceeding 50 ppm.   However, by
     this Record of Decision,  the Regional Administrator has
     waived the requirements of 761.75(b)(1), (2),  (3)  and (7).
     Therefore,  contaminated soils generated from this excavation
     can be consolidated on-site.

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS       : $ 16,500,000
          ANNUAL O&M COSTS         : $    230,000
          PRESENT WORTH            : $ 19,600,000
          IMPLEMENTATION           : 3-years

3A.  Alternative 3A,  SITE COVER INCLUDING A BARRIER LAYER
CONSISTING OF A COMPOSITE FLEXIBLE MEMBRANE LINER  OVER A
GEOSYNTHETIC CLAY LINER,  AND PASSIVE PERIMETER GAS VENTILATION
SYSTEM:

  a.  DESCRIPTION:   This alternative is identical to Alternative 3
     except that the barrier layer of the soil would consist  of a
     composite FML over a geosynthetic clay liner  (GCL),  instead
     of  being directly over the gas ventilation layer (see option
     4A Figure 7).   The GCL consists of a thin layer of natural
     bentonite clay incorporated into a geosynthetic mesh,  which
     serves to keep the bentonite in place so that a continuous
     low permeability bentonite layer is created below the FML.

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                                28

     The GCL is forgiving under load and is self healing.

     The FML by itself is very effective in minimizing
     infiltration through the landfill as long as the FML  is of
     good quality.  However, leaks in the FML always occur and
     can substantially increase the quantity of infiltration as
     discussed in Section C.3.  The GCL complements the FML's
     capability by essentially plugging leaks in. the FML with a
     thin,  but low permeability la'yer of clay.  The potential
     effectiveness of the composite FML/GCL is demonstrated in
     Figure 2-4 from Design and Construction of RCRA/CERCLA Final
     Covers. U.S.  EPA, May 1991.  For site specific application,
     it is also demonstrated using the HELP model in Table I.

     The composite FML/GCL barrier provides significantly more
     insurance that the site cover will be very effective,
     compared to the FML barrier.

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS       :  $ 18,900,000
          ANNUAL O&M COSTS         :  $    230,000
          PRESENT WORTH            :  $ 22,000,000
          IMPLEMENTATION           :  3-years

3B.  Alternative 3B,  SITE COVER INCLUDING A BARRIER LAYER
CONSISTING OF A COMPOSITE FLEXIBLE MEMBRANE LINER OVER 2-FEET OF
COMPACTED CLAY,  AND PASSIVE PERIMETER GAS VENTILATION SYSTEM:

 a.  DESCRIPTION:   This alternative is identical to Alternative 3
     except that the barrier layer of the soil would consist of a
     composite FML over 2-feet of  compacted clay,  instead of
     being directly over the gas ventilation layer.   The
     ventilation layer would be below the compacted clay (see
     option 4B Figure 7).   In order to reduce the quantity of
     soil that would have to be imported onto the Site,  the two
     foot clay layer would replace some of the grading soil.
     Along the edges where grading soil would not be required,
     the existing cover may be usable as part of the 2-foot
     compacted clay layer.  The compacted clay would have a
     maximum hydraulic conductivity of Id'6 cm/sec.

     Like the GCL,  a 2-foot compacted clay layer complements the

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                                29

     FML by providing a low hydraulic conductivity barrier
     wherever leaks develop in the FML.  The clay layer would
     also be self healing to some degree.  The FML would protect
     the clay layer from desiccation cracking.  The potential
     effectiveness of the composite FML/compacted clay barrier
     layer is demonstrated in Figure 2-4 from Design and
     Construction of RCRA/CERCLA Final Covers. U.S. EPA, May
     1991,  which is attached.  For site specific application, it
     is also demonstrated using the HELP model in Table 1.  The
     composite FML/compacted clay barrier provides significantly
     more insurance that the site cover will be very effective,
     compared to the FML barrier.

     Figure 2-3 from  Design and Construction of RCRA/CERCLA
     Final Covers.  U.S. EPA,  May 1991,  which is attached,  shows
     that the effect of reducing the hydraulic conductivity
     requirement for the compacted clay from 10~7 to 10-6 cm/sec
     does not result in a significant increase in infiltration.

     This is also confirmed for site specific application in
     Table 1.  For this reason,  and because there may be a cost
     savings, the hydraulic conductivity criteria for the
     compacted clay is set at 10~6 cm/sec.

  b. ESTIMATED COSTS:

          CONSTRUCTION COSTS        :  $  18,100,000
          ANNUAL O&M COSTS         :  $     230,000
          PRESENT WORTH            :  $  21,200,000.
          IMPLEMENTATION           :  3-years

3C.  ALTERNATIVE 3C:'  SITE COVER INCLUDING A BARRIER LAYER
CONSISTING OF A FLEXIBLE MEMBRANE LINER,  AND AN ACTIVE PERIMETER
GAS CONTROL SYSTEM:

 a.  DESCRIPTION:   This Alternative is  identical to Alternative 3
     .except that an active perimeter gas  control system will be
     used instead of a passive gas control system.   The active
     gas control system will  utilize a  blower to remove gases
     from the perimeter gas collection  trench.   It is anticipated
     that one fan/blower will be located  on the northern portion
     of the landfill and one  in the southern portion.   The gases
     collected will be directed to the  center of both on-site

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                                30

     landfills for treatment by flaring or some other method  (see
     attached Figure 8).

     The active perimeter trench control system is the most
     reliable system available for preventing off-site migration
     of landfill gases in the subsurface.  It is considerably
     more reliable than the passive perimeter trench system and,
     therefore, should eliminate concerns about entry of landfill
     gases into adjacent buildings.  An additional benefit of the
     active system is that the active withdrawal of landfill
     gases has more potential to reduce ground water
     contamination by volatile organic compounds such as benzene
     and vinyl chloride by actively withdrawing them in the vapor
     phase, and thus preventing them from recondensing at the
     perimeter of the landfill and contaminating ground water.
     Another advantage of the active system is that VOCs will be
     permanently treated prior to release to the ambient air.
     The combination of directing the landfill gases to the
     centers of the landfill and treating the gases prior to
     release,  should eliminate the concern regarding the odor and
     health risks to off-site residents from the release of
     landfill gases.

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS       :  $ 17,300,000
          ANNUAL O&M COSTS         :  $    340,000
          PRESENT WORTH            :  $ 22,000,000
          IMPLEMENTATION            :  3-years

4.    ALTERNATIVE 4,  SITE  COVER INCLUDING A BARRIER LAYER
     CONSISTING OF A FLEXIBLE MEMBRANE LINER,  AN ACTIVE PERIMETER
     GAS CONTROL SYSTEM,  A LEACHATE COLLECTION SYSTEM ALONG THE
     YEOMAN CREEK LANDFILL PORTION OF THE SITE,  AND REROUTING
     .YEOMAN CREEK ALONG EDWARDS FIELD PORTION OF THE SITE:

  a.  DESCRIPTION:   This Alternative includes the site cover and
     active perimeter gas control system described for
     Alternative 3C,  plus measures  to insure isolation of Yeoman
     Creek from the landfill leachate.   The isolation measures
     along the Yeoman Creek Landfill  portion of  the Site would be
     a leachate collection system.   The leachate collection
     system would be  installed along  both sides  of Yeoman Creek

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                           31

where the landfill is present.  It is anticipated that the
leachate collection trench would extend to. 12 to 18  inches
below the level of Yeoman Creek.  Wastes observed to be
between the leachate collection system and Yeoman Creek
would be excavated and consolidated on-site.  Leachate would
drain to a sump, from which  it would be pumped to a
treatment and/or storage system.  The leachate would either
be treated and discharged to the North Shore Sanitary
District treatment system, or be transported off-site for
treatment.

The leachate collection trenches would provide an effective
barrier to prevent leachate  from seeping into Yeoman Creek
during dissipation of the leachate mounds in the landfill,
and would prevent leachate generated from' ground water
movement from seeping into Yeoman Creek.  Since 30-40% of
the landfill wastes will remain below the water table even
after the leachate mound in  the landfill dissipates, it is
possible that some leachate will be generated from movement
of ground water through the wastes.   This leachate could
continue to recharge Yeoman  Creek especially along the
Yeoman Creek Landfill portion where Yeoman Creek is a
gaining stream.

Along the Edwards Field portion of the Site,  the stream
would be relocated through the middle of the wetlands and
away from the landfill.   According to aerial photograph
interpretation, this was the route of Yeoman Creek before
the stream bed was relocated during operation of the
landfill.   If properly implemented;  this relocation may
enhance the quality of the wetlands east of the Edwards
Field area.   This action would move Yeoman Creek to 150 feet
or more from the Edwards Field portion of the landfill (see
attached Figure 9).

Although this option would not necessarily prevent leachate
from eventually reaching Yeoman Creek,  any leachate
generated from dissipation of the leachate mound,
infiltration through the site cover,  and ground water flow
through the lower portion of the landfill,  would be buffered
by a longer ground water flow route and the wetlands before
reaching Yeoman Creek.   There is presently a 30 foot buffer
between the landfilled waste and the Creek,  and the Creek

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                                32

     appears to be a losing stream in that area.

     It is possible that some of the soils excavated for the
     landfill gas control system and leachate collection system
     would contain PCBs at concentrations equal to or exceeding
     50 ppm.  However,  by this Record of Decision, the Regional
     Administrator has waived the requirements of 761.75(b)(1),
     (2),  (3) and (7)  (see Section IX.A).  Therefore,
     contaminated soils generated from this excavation can be
     consolidated on-site.

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS       :  $  18,000,000
          ANNUAL O&M COSTS         :  $     450,000
          PRESENT WORTH            :  $  24,200,000
          IMPLEMENTATION           :  3-years

4A.  ALTERNATIVE 4A,  SITE COVER INCLUDING A BARRIER LAYER
     CONSISTING OF A FLEXIBLE MEMBRANE  LINER,  AN ACTIVE PERIMETER
     GAS CONTROL SYSTEM,  A CLOSED CULVERT IN YEOMAN CREEK ALONG
     THE YEOMAN CREEK LANDFILL PORTION  OF THE SITE,  AND REROUTING
     YEOMAN CREEK ALONG THE EDWARDS FIELD PORTION OF THE SITE:

 a.  DESCRIPTION:   This Alternative is  identical to Alternative 4
     except that Yeoman Creek would be  isolated from the Yeoman
     Creek Landfill  portion of the Site by construction of a
     closed culvert  in the creek along  the landfill instead of
     construction of a leachate collection system.  The culvert
     would be designed to provide a physical barrier to the
     landfill leachate.

     An underdrain system would be incorporated into the bottom
     of the culvert  to drain fluid into sumps.   The fluid would
     be pumped to a  treatment/storage facility,  and,  if
     necessary,  either treated and discharged to the Northshore
     Sanitary District  treatment system,  or transported off-site
     for treatment.   This system would  be equally effective as
     the leachate collection system in  preventing leachate from
     the Yeoman Creek  Landfill portion  from entering Yeoman Creek
     due to dissipation of the leachate mound,  infiltration
     through rhe site  cover,  or movement of ground water through
     the landfill.

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                                33

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS        : $ 19,800,000
          ANNUAL O&M COSTS       '   : $    440,000
          PRESENT WORTH             : $ 25,900,000
          IMPLEMENTATION            : 3-years

4B.  ALTERNATIVE 4B, SITE COVER  INCLUDING A BARRIER LAYER
     CONSISTING OF A FLEXIBLE MEMBRANE LINER OVER EITHER A GCL OR
     A 2-FOOT COMPACTED CLAY LINER, AN ACTIVE PERIMETER GAS
     CONTROL SYSTEM, AND A LEACHATE COLLECTION SYSTEM ALONG THE
     YEOMAN CREEK 'LANDFILL PORTION OF SITE

 a.  DESCRIPTION:  Alternative 4B is the same as Alternative 4,
     except for use of one of the composite clay/FML liner
     systems as described for Alternatives 3A or 3B instead of
     use of the FML liner by itself for the barrier layer.  In
     addition,  rerouting of Yeoman Creek away from the Edwards
     Field portion of the Site is not included.

  b. COSTS

          CONSTRUCTION COSTS       : $ 20,100,0007
          ANNUAL O&M COSTS         : $    450,000
          PRESENT WORTH            : $ 26,300,000
          IMPLEMENTATION           : 3-years

4C.  ALTERNATIVE 4C, SITE COVER INCLUDING A BARRIER LAYER
     CONSISTING OF A FLEXIBLE MEMBRANE LINER,  AN ACTIVE PERIMETER
     GAS CONTROL SYSTEM,  A LEACHATE COLLECTION SYSTEM ALONG THE
     YEOMAN CREEK LANDFILL PORTION OF THE SITE:

 a.  DESCRIPTION: Alternative 4C is the same as Alternative 4,
     except that rerouting of Yeoman Creek away from the Edwards
     Field portion of the Site is not included.

 b.  COSTS
     7   This  cost  is  based  on  the  cost  of  the  FML/compacted clay
barrier in Alternative 3B,  since this is estimated to be the
cheaper of the two alternatives.

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                                34

          CONSTRUCTION COSTS       :  $ 17,700,000
          ANNUAL O&M COSTS         :  $    450,000
          PRESENT WORTH            :  $ 23,800,000

5.    ALTERNATIVE 5,  SITE COVER FULLY MEETING RCRA SUBTITLE C
     TECHNICAL GUIDANCE, AN ACTIVE PERIMETER GAS CONTROL SYSTEM,
     DEEP SLURRY WALLS AROUND THE ENTIRE LANDFILL,  AND GROUND
     WATER/LEACHATE PUMPING TO PREVENT OFF-SITE MIGRATION:

 a.   DESCRIPTION:  This Alternative includes a site cover fully
     consistent with RCRA Subtitle C technical guidance.  It
     includes a 3% slope after settlement,  a gas ventilation
     layer,  a composite barrier layer consisting of an FML and a
     2 foot  compacted clay layer with 10~7 hydraulic conductivity
     above the grading layer (not incorporated into the grading
     layer as in Alternative 3B),  and a three foot  frost
     protection layer.  This cover would require importing
     considerably more soil to provide the  3% slope and the full
     2 foot  compacted clay layer above the  grading  layer,  which
     would result in a 5 foot thick site cover above the grading
     layer rather than a three foot thick cover above the grading
     layer as Alternatives 3,  3A,  3B,  and 3C,  4,  and 4A.  This
     site cover would be very effective in  preventing
     infiltration through the cover with a  high level of
     reliability.

     Alternative 5 would utilize deep soil-bentonite slurry-walls
     keyed into the  lower till to prevent flow from the landfills
     into Yeoman Creek,  as well as preventing migration into the
     aquifers near the Site.   Ground  water  would be pumped within
     the containment area formed by the slurry walls in order to
     minimize vertical flow between the shallow and deep aquifers
     by equalizing their potentiometric head.   The  removed
     leachate/ground water would be pumped  to a treatment/storage
     system  and either discharged to  the Northshore Sanitary
     District or transported•off-site for treatment.

     It is possible  that some of the  soils  excavated for the
     landfill gas control system and  the slurry walls would
     contain PCBs at concentrations equal to or exceeding  50 ppm.
     However,  by this Record of Decision, the Regional
     Administrator has waived the  requirements of 761.75(b)(1),
     (2),  (3)  and (7)  (see Section IX.A).   Therefore,

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                                35

     contaminated soils generated from this excavation  can  be
     consolidated on-site.

 b.  ESTIMATED COSTS:

          CONSTRUCTION COSTS        : $ 39,800,000
          ANNUAL O&M COSTS          : $    880,000
          PRESENT WORTH             : $ 51,900,000
          IMPLEMENTATION            : 3-years
IX.  SUMMARY OF COMPARATIVE EVALUATION OF ALTERNATIVES

The National Contingency Plan  (NCP) requires that the
alternatives be evaluated on the basis of the following nine
evaluation criteria:  (1) Overall protection of human health and
the environment;  (2) Compliance with applicable or relevant and
appropriate requirements (ARARs);   (3)  Long-term effectiveness and
permanence; (4) Reduction of toxicity, mobility,, or volume
through treatment;  (5) Short-term effectiveness;  (6)
Implementability; (7) Cost; (8) State acceptance; and  (9)
Community acceptance.  These criteria are summarized below.  This
section compares the alternatives with regard to these nine
evaluation criteria.

A.  Threshold Criteria

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, or
     institutional controls.  The  selected remedy must meet these
     criteria.

2.   Compliance with Applicable or Relevant and Appropriate
     Requirements (ARARs)  addresses whether a remedy will meet
     applicable or relevant and appropriate federal and state
     environmental laws and/or justifies a waiver from such
     requirements.  The selected remedy must meet this criteria
     or waiver of the ARAR must be attained.

B.  Primary Balancing Criteria

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                                36

3.   Long-Term Effectiveness and Permanence refers to expected
     residual risk and the ability of a remedy to maintain
     reliable protection of human health and the environment over
     time, once cleanup levels have been met.

4.   Reduction of Toxicity, Mobility, or Volume Through Treatment
     addresses the statutory preference for selecting remedial
     actions that employ treatment technologies that permanently
     and significantly reduce toxicity, mobility, or volume of
     the hazardous substances as their principal element.

     This preference is satisfied when treatment is used to
     reduce the principal threats at the site through destruction
     of toxic contaminants, reduction of the total mass of toxic
     contaminants, irreversible reduction in contaminant
     mobility, or reduction of total volume of contaminated
     media.

5.   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,  until cleanup
     levels are achieved.

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 operation and
     maintenance  (O&M)  costs,  also expressed as net present
     worth.

C. Modifying Criteria

8 .   State Acceptance
     Addresses whether or not the State Agency agrees with or
     objects to any of the remedial alternatives and also
considers State ARARS.

9.   Community Acceptance
     Addresses the public's general response to the remedial
     alternatives and to the Proposed Plan.   The specific
responses to public comments are addressed in the

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                                37

Responsiveness Summary section of this ROD.

A.  THRESHOLD CRITERIA: OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT AND COMPLIANCE WITH APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS  (ARARS):  .

The ARARs of most concern for this remedial action include the
following:

     surface water quality standards in 35 IAC Part 302;

     Maximum Contaminant Levels (MCLs)  .pursuant to 40 CFR 141 and
     Illinois Ground Water Quality Standards (IGWQS)  pursuant to
     35 IAC 620.410 in the aquifers below the Site;

  -  final cover system requirements of 35 IAC 811.314,  which
     requires placement of a final cover consisting of a low
     permeability layer (either 3  feet  of compacted soil with a
     permeability of 10"7 cm/sec, or an FML in combination with a
     shallower depth of compacted soil, of equal or superior
     performance)  overlain by a protective layer;

     actions to minimize the destruction,  loss,  or degradation of
     wetlands in Executive Order 11988  and 40 CFR 6,  Appendix A
     Section 6(a) (5) ;

     restrictions on construction  within floodways and flood
     plains pursuant to 92 IAC Part  708,  which generally requires
     compensation for lost floodway storage and conveyance,  and
     prohibits increases in average  channel velocity and flood
     height (U.S.  EPA has  determined that the Lake County Storm
     Water Management Commission Regulations,  which are  somewhat
     more stringent,  are not ARARs,  but will be -seriously
     considered during implementation of the remedial actions);

  -  Northshore Sanitary District  pretreatment  requirements,  and
     restrictions on discharge of  pollutants to POTWs in 40  CFR
     403.5,  35 IAC 307.1101-1103,  35 IAC 310 .201 (a) (c) ,  35 IAC
     310.202,  35 IAC 309(d)(e);

     landfill gas management and disposal requirements of 35  IAC
     811.311 and 811.312,  which requires use of an active
     perimeter gas control system  and treatment of the gas prior

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                           38

to discharge to the atmosphere.

TSCA disposal regulations at 40  C.F.R.  §  761.60  et seq..  are
applicable to PCBs in concentrations  of 50  ppm or greater
(PCBs")  when such PCBs*  are  "taken out of  service".  Under
the remedial actions being considered,  TSCA disposal
regulations could be triggered by excavation of  PCBs" which
may occur during the excavation  of sediments,  and during
excavation of soils and wastes for construction  of the
leachate collection system and the landfill gas  control
system.  The TSCA disposal regulations  may  also  be triggered
by constructing a new cover  over leachate seep soils that
contain PCBs*-   Pursuant to  40 C.F.R.  § 761. 60 (a) (4) ,  PCBs*
must be disposed of: "(i) in an  incinerator which complies
with 761.70; or (ii) in a chemical waste  landfill  which
complies with 761.75."  The  TSCA compliant  chemical waste
landfill disposal method is  generally much  less  expensive
than incineration.

The on-site consolidation and containment of  PCBs*, whether
from the sediments, seep soils,  or soils excavated for
construction,  would not meet the  following  chemical waste
landfill requirements of Section  761.75(b):

     bottom liner requirements because  the  landfill does  not
     have a bottom liner (761.75(b)(1)  and  (2));

     fifty foot distance between  bottom liner  and  historical
     high water table (761.75(b)(3);

     leachate collection requirements  (761.75(b)  (7) ) ;

Pursuant to 761..75 (c) (4), the Regional Administrator may
determine that one or more of the  requirements in  761.75(b)
is not necessary to protect  against unreasonable risk of
injury to health or the environment from the PCBs,  and may
waive such requirements.  In this  Record of Decision, the
Regional Administrator waives the  requirements in
761.75(b)(1),  (2),  (3)  and (7)  for the  following reasons:

1. the final remedial action will  provide protection to
human health and the environment  against unreasonable risks
of injury;

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                                39

     2. no significant reduction  in the long term risks would be
     gained from the off-site disposal of the small quantity of
     PCBs* in the sediments,  seep soils,  and excavated soils
     since the bulk of the PCBs* will  be  contained in place under
     the  final cover; and

     3. the costs for the analyses to detect the extent of  PCBs*
     and  for off-site disposal of the PCBs*  located is
     potentially large.

Alternative 1, the No Action Alternative, would result in
unacceptable risks under current  conditions due to the fire and
explosion threat from off-site migration of landfill gases, and
detrimental impacts on ecological receptors may be occurring
under current conditions.  Although Alternative 2 includes
sediment and limited wetland remediation, over the long term re-
emergence of leachate seeps may also cause a detrimental impact
on ecological receptors.   Alternative 1 would result in
unacceptable risks in case of future development of the Site.
Alternatives 1 and 2, would result in unacceptable risks in case
of future ground water usage, and Illinois Ground Water Quality
Standards would not be met in the aquifers near the Site.    It is
possible that this contamination would eventually affect
downgradient residential well users.

In addition,  Alternatives 1 and 2 do not  comply with State of
Illinois'  final site cover requirements in 35 IAC 811.314.
Therefore, Alternatives 1 and 2 are eliminated from further
consideration.

Alternatives 3,  3A,  and 3B include use of a passive perimeter gas
ventilation system rather than an active  perimeter gas control
system as required in 35  IAC 811.311.   In addition,  Alternatives
3,  3A,  and 3B may cause malodors beyond the property boundary in
violation of 35 IAC 811.311;  do not include treatment as required
pursuant to 35 IAC 811.312;  and may cause an off-site exposure
risk,due to the uncontrolled release of landfill gases along the
perimeter of the landfill.   Therefore,  Alternatives 3,  3A, and 3B
are eliminated from further consideration.

Of the remaining alternatives,  Alternatives 3C,  4,  4A and 4C
consider a cover consisting of only an FML liner.   An FML liner
does not meet the requirements of 35  IAC  Part 811 for a site

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                                40

 cover  of  at  least  3  feet of  compacted  soil  with  a  hydraulic
 conductivity of  10.7  cm/sec  or less,  or an alternative which has
 an equivalent or greater performance.

 This leaves  Alternatives 4B,  and  5 under  consideration,  both of
 which  include use  of an active perimeter  gas  control  system and a
 cap meeting  or exceeding the  critera of 35  IAC 811.

 Besides use  of the active perimeter gas control  system and  cap
 requirements, all  of the remaining alternatives  include  a number
 of common actions  that are necessary to address  site  risks  or to
 achieve ARARs, including the  following:

 1.  Site  access  restrictions;

 2.  Institutional  controls;

 3.  Additional investigation;

 4.  Long  term monitoring;

 5.  Remediation  of contaminated sediments in  Yeoman Creek and
    limited  wetland areas;

 6.  Compliance with floodway/floodplain regulations;

 7.  Remediation  of surface soils outside of the new cover area;

'8.  Compensation for loss or damage to wetlands;

 9.  Rerouting and sealing of storm drains that go through the
    landfill;

 10.  Continuation of interim actions.

 No alternative evaluation was conducted for these components  of
 the remedy because either the costs are small compared to the
 overall costs of the remedy, or (with one exception) there was
 only one  logical alternative to address the need.  The exception
 is compliance with the floodplain/floodway regulations, for which
 alternatives for compliance will be evaluated during the remedial
 design phase.

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                                41

Site access restrictions are necessary to protect the public from
exposure to potentially hazardous landfill gases and leachate,
and from the mechanical components of the remedial action.  In
addition, Site access restrictions are necessary to maintain the
integrity of the site cover, and other components of the remedial
action.  The estimated cost of site access restrictions  ($35,000)
are very minor compared to the total cost of the remedial action.

Institutional controls will include deed restrictions to prohibit
future development of the Site that would be incompatible with
the remedial action.

Institutional controls will also include restrictions on usage of
the contaminated ground water near the site.  The cost of
institutional controls is very minor compared to the total cost
of the remedial action.

The additional investigation includes additional ground water
investigation to define the extent of ground water contamination.
It also includes sampling to determine the required extent of
sediment and soil remediation and to verify attainment of the
cleanup action levels following remediation.  Long term
monitoring is necessary to evaluate the long term effectiveness
of the remedy,  and to detect any hazardous conditions caused by
the Site before it adversely affects public health or the
environment.  The FS estimates that the initial cost of the long
term monitoring and ground water investigation will be $420,000,
and yearly costs will be-$128,800.

Remediation of the contaminated sediments is necessary to reduce
impacts on ecological receptors from relatively high
concentrations of contaminants from the Site.   Since the bulk of
the contamination is being contained on-Site,  the only reasonable
alternative to address the contaminated sediments is to excavate,
consolidate and temporarily store the contaminated sediments on-
site until finally contained under the new Site cover.

Off-Site disposal is clearly more expensive and would provide no
significant reduction in risk.

Thus a waiver of the TSCA disposal requirements is•justified.
The estimated cost of $200,000 is small compared to the total
cost of the remedy.

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                                42

 Compliance with the floodplain/floodway regulations is required
 pursuant to 92 IAC 708 and the Lake County Watershed Development
 Ordinance.   Alternatives for compliance with these regulations
 will be evaluated during the remedial  design phase.  The actual
 costs will depend on the results  of further study to determine
 the  extent and impacts of filling in the floodplain and floodway.
 Colder estimates that a reasonable maximum cost will be $652,200,
 which is not a large amount compared to the total cost of the
 remedy.

 Remediation of surface soils that will be outside of the new Site
 cover,  is necessary to reduce human health risks from exposure to
 PCBs on the surface soil.   The cost of this action will be very
 minor.

 Compensation for loss or damage to wetlands is  required pursuant
 to Executive Order 11988 and 40 CFR 6,  Appendix A Section
 6(a)(5).   It is expected that this cost will be minor compared to
 the  total cost of the remedy.

 Rerouting and sealing of storm drains  is necessary to prevent
 leachate formation due to potentially  large volumes of storm
 water flow through the waste.   This leachate could recharge
 ground water or Yeoman Creek.  The estimated cost of $110,000 for
 Alternative 4B,  is small compared to the total  cost of the
 remedy.

 Continuation of the interim actions for monitoring buildings
 north of the Site for landfill gas entry,  and operation,
 maintenance and monitoring of the ventilation system - installed to
 mitigate the affects of landfill  gas entry,  are necessary to
 protect  public health from fire and explosion,  and toxic hazards
 from the landfill gas until the final  remedial  action is
 implemented.

.B.   PRIMARY BALANCING CRITERIA:   LONG-TERM EFFECTIVENESS AND
 PERMANENCE;  REDUCTION OF TOXICITY,  MOBILITY AND VOLUME THROUGH
 TREATMENT;  SHORT-TERM EFFECTIVENESS; IMPLEMENTABILITY;  AND COST.

 Alternative 4B,  is much less  costly than Alternative 5.  As stated
 before,  these  remaining alternatives include an active perimeter
 landfill  gas control system.   Alternative 4B includes  a Site
 cover using a  composite FML and clay liner as a barrier layer,  a

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                                43

leachate collection system along  Yeoman Creek  for  the Yeoman
Creek Landfill portion of the Site, but does not include
relocation of Yeoman Creek away from the Edwards Field area.
Alternative 4B is estimated to cost $25,600,000 less than
Alternative 5, which includes a site cover fully consistent with
RCRA Subtitle C technical guidance, slurry walls,  and a ground
water/leachate pumpout system.

1.  Active.landfill gas control system:

The active perimeter landfill gas control system is estimated to
cost $1,200,000 to construct and  $115,000 per year to operate and
maintain.  This is substantially  more than the $540,000 to
.construct and $13,000 per year to operate and maintain the
passive perimeter control system.   However, this additional cost
is necessary to assure protection of the public health and to
meet ARARs.

As stated previously none of the  alternatives evaluated in detail
include treatment to reduce toxicity,  mobility or volume as a
principle element.  However,the remaining Alternatives,  4B, and 5
include treatment as a secondary element through inclusion of an
active perimeter gas collection and treatment system.  The active
perimeter trench control system is the most reliable system
available for preventing off-Site migration of landfill gases in
the subsurface,  and for addressing potential risks from air
emissions of landfill gases.   An additional benefit of the active
system is that withdrawal of landfill  gases has potential to
reduce ground water contamination by volatile organic compounds
(VOCS)  such as benzene and vinyl chloride by withdrawing these
VOCs in the  vapor phase along with other landfill gases,  and thus
preventing them from recondensing at the perimeter of the
landfill and contaminating ground water.  No significant short-
term risks nor implementability problems are expected from
construction of an active perimeter gas system.

2.  Site cover alternatives:

The site cover fully consistent with RCRA Subtitle C technical
guidance,  which is included in Alternative 5 is estimated to cost
$4,400,000 more than the Alternative 4B site cover, which also
includes a composite barrier layer.   However,  Table 1 indicates
that the Alternative 4B site covers would be expected to reduce

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                                44

infiltration to negligible levels, even if leaks in the FML
occur.  Therefore, the Alternative 5 site cover is not cost
effective.  The Alternative 5 site cover also has more
implementability problems than the Alternative 4B site cover due
to more disturbance of nearby businesses and residents from
transportation of a much larger quantity of soil in order to
construct the five foot thick cap over a grading layer with a 3%
slope, and more potential to affect nearby properties and
structures due to the thicker capping requirement.  Therefore,
the site cover option in Alternative 5 is screened out.

The use of a site cover with a composite FML/clay liner barrier
layer is included in Alternative 4B,  but not in Alternatives 3C,
4, 4A, or 4C.  As . stated before, the FML by itself can be very
effective in minimizing infiltration through the landfill as long
as the FML is of good quality.  Nonetheless,  the FML by itself
does not comply with 35 IAC 811 requirements.

In addition, the composite barrier layer would provide
considerably more assurance that the site cover will remain very
effective over the long-term.   The estimated additional cost of
use of the site cover with the composite FML/clay barrier layer
compared to a site cover using only an FML as a barrier layer is
summarized below:

          ADDITIONAL CONSTRUCTION COSTS      :  $  1,900,000
          ADDITIONAL ANNUAL O&M COSTS        :  $          0

No additional short term risks are anticipated from construction
of a site cover with a composite FML/clay barrier as proposed in
Alternative 4B compared to construction of with only an FML.   In
addition,  no significant additional implementation problems are
anticipated.

There may be some concern that the Edwards Field portion of the
Site should not require as effective  a site cover as the Yeoman
Creek Landfill portion.

Although leachate seepage from only the Yeoman Creek Landfill
portion of the Site had been the primary regulatory concern
during the 1970s and early 1980s,  the detection of VOCs such as
benzene,  acetone,  trichloroethylene and tetrachloroethylene,  in
the leachate well samples at Edwards  Field along with the  similar

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                                45

operational history indicates that an effective site cover should
be placed over both the Edwards Field Landfill and the Yeoman
Creek Landfill portions of the Site.

3.  Alternatives to further isolate Yeoman Creek from the
Landfill leachate along the Yeoman Creek Landfill portion of the
Site.

A leachate collection system for the Yeoman Creek Landfill
portion of the Site was included in Alternative 4B.

At the Yeoman Creek Landfill portion of the Site,  some conditions
argue against the need for measures to further isolate Yeoman
Creek from the leachate beyond the protection provided by the new
Site cover.

The new Site cover will eliminate surficial leachate seeps; so
the only mechanism for leachate recharge of the Creek following
cover installation would be through migration through the
subsurface.  A low permeability cover will nearly eliminate
leachate generation due to precipitation,  which will result in a
gradual decrease in the leachate mound in the landfill,  and
therefore,  a gradual decrease in the driving force for leachate
recharge to the Creek.

Even after the leachate mounds are dissipated,  leachate can be
generated by movement of ground water through the portion of the
landfilled waste that will remain below the water table.  However,
shallow ground water recharge to the Creek is apparently minor
since the base flow of the Creek is zero during parts of the
year.  Water level measurements also indicate that discharge of
ground water to the Creek occurs only locally.   Furthermore,  the
ground water data indicates that there is significant natural
attenuation between the leachate and ground water,  which may also
apply to the leachate recharge of the Creek.   Consequently,  there
is a reasonable potential that implementation of the Remedy
without a leachate collection system,  along with natural
attenuation,  may expeditiously reduce leachate  to  below levels of
concern.

On the other hand,  further isolation of the Creek  using a
leachate collection system or an artificial channel along the
Yeoman Creek Landfill portion of the Site would provide

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                                46

significant additional  insurance  that  leachate would  not  have  a
continuing effect on the Creek.   The primary  concern  is that
landfilled wastes are within a  few feet of the Creek  along much
of the Yeoman Creek Landfill portion.  Some of this landfilled
waste may contain high  concentrations  of hazardous substances.

It is known that wastes likely  to contain high concentrations  of
PCBs were disposed of in the Yeoman Creek Landfill portion over
most, if not all, of its period of operation.  The attenuation
mechanisms that are protecting  the ground water may not be
effective over the few  feet between the landfilled waste  and
Yeoman Creek.  A number of the  hazardous substances detected in
the leachate at the Yeoman Creek Landfill portion of  the  Site  may
have an adverse impact on ecological receptors, including PCBs,
lead, zinc, acetone and cyanide.  Therefore,  even local recharge
of Yeoman Creek from the Yeoman Creek portion of the  Site is of
concern.  Since 30-40% of the landfill wastes will remain below
the water table even after the  leachate mound in the  landfill
dissipates, some leachate will be generated from movement of
ground water through the wastes, and some of  this could recharge
Yeoman Creek.

It is preferable to construct a leachate collection system or
artificial channel now in conjunction with construction of the
new site cover because the design can be integrated with  the Site
cover design to maximize effectiveness.  After construction of
the site cover construction of the Creek isolation measures would
likely be more expensive due to additional mobilization costs,
and the need to repair portions of the Site cover damaged during
the construction.  Furthermore,  the Remedial  Investigation (see
Section 4.2.1.2.2)  indicates that it may be difficult to detect
the impact of leachate on Yeoman Creek through the monitoring
program.  As a consequence,  concentrations of less mobile
contaminants such as PCBs could build up over time without being
detected.

The leachate collection trenches as proposed  in Alternatives 4
and 4B would provide an effective barrier to prevent leachate
from seeping into Yeoman Creek during dissipation of the leachate
mounds in the landfill,  in the event that the site cover is not
effective,  and would prevent leachate generated from ground water
movement from seeping into Yeoman Creek.

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                                47

 The  estimated  additional  costs  for  the  leachate  collection system
 including  treatment  and disposal  are  summarized  below:

   CONSTRUCTION COSTS FOR  LEACHATE COLLECTION : $   300,000
   ADDITIONAL ANNUAL  O&M COSTS                 : $    87,000
   ADDITIONAL PRESENT WORTH                    : $ 1,500,000

 The  construction  cost of  the leachate collection system for the
 Yeoman  Creek Landfill portion is  relatively  modest.   The major
 portion of  the present worth cost is  for  operation  and  mainten-
 ance.   It  is expected that  as the leachate mound dissipates that
 the  flow into  the  leachate  collection system will decrease,  and,
 as a result, operation and  maintenance  costs will also  decrease.

 There are  some addition potential short term risks  from exposure
 to leachate during construction and operation of the  leachate
 collection  system.   However, these risks  are controllable  through
 implementation of  standard  worker safety  procedures.

 Alternative 4A includes use of a  corrugated  steel arch  pipe with
 underdrains to collect leachate to isolate Yeoman Creek from the
 Yeoman  Creek Landfill portion of  the Site, instead  of a leachate
 collection  system.   Use of  corrugated steel  arch pipe is
 estimated to cost  $1,300,000 more to construct than a leachate
 collection  system  with no decrease in operation  and maintenance
 costs.  This Alternative is  not expected to be significantly more
 effective than the leachate collection  system.   Therefore,
 Alternative 4A is  screened  out.

•4.   Alternatives to  further isolate Yeoman Creek from the
 Landfill leachate  along the Edwards Field Landfill portion  of the
 Site.

 Alternative 4B includes no  further actions beyond the new  Site
 cover to control leachate from the Edwards Field Landfill portion
 of the  Site.   Alternatives  4 and  4A include  relocation  of Yeoman
 Creek away  from the  Edwards Field area  to further isolate Yeoman
 Creek from the  leachate.

 Conditions are  significantly different at the Edwards Field
 Landfill portion of  the Site.  Along the  Edwards  Field  Landfill,
 the  Creek is generally a losing stream,  which indicates  that
 recharge by the ground water is unlikely.   There  is no  definitive

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                                48

evidence that wastes containing high concentrations of PCBs were
disposed of at the Edwards Field Landfill portion.  In addition,
PCBs were detected in only one leachate well sample at a very low
concentration at the Edwards Field Landfill portion.  Cyanide was
not detected in the leachate at the Edwards Field Landfill, and
lead, zinc and acetone were detected at lower concentrations than
at the Yeoman Creek Landfill portion.

Finally, even if the leachate does recharge the Creek, there is
an approximately 30 foot buffer between the Creek and the
landfilled waste,  which would be expected to provide significant
attenuation especially for relatively insoluble contaminants such
as PCBs and lead.

Therefore, it appears that the Site remedy without further
measures to isolate the Edwards Field Landfill portion from the
Creek will be effective in protecting Yeoman Creek.  As a result,
leachate collection or relocation of Yeoman Creek away from
Edwards Field does not appear to be necessary (even though the
cost of relocating Yeoman Creek is relatively modest ($280,000)
and the short term impacts are not expected to be significant).

5.   Containment of leachate and contaminated ground water with
slurry walls with ground water extraction.

Alternative 5 would contain leachate and contaminated ground
water from both Yeoman Creek and the ambient ground water using
slurry walls and ground water extraction within the slurry wall.
Its primary advantage over Alternative 4B is that it would
prevent off-site migration of contaminated ground water.
However, this advantage would be gained at a very major increase
in costs compared to Alternative 4B ($ 16 million in additional
construction costs and $430,000 in additional annual costs).
Considering the relatively minor levels of ground water
contamination and the fact that the ground water in the vicinity
of the Site is not presently being used,  this additional  cost
does not appear to be justified.   As previously noted in  Section
II.B,  regarding the risks from ground water exposures,  the ground
water contamination is presently limited even though the  Site
does not have an effective site cover.

The substantial reduction in infiltration using an effective  site
cover would reduce impacts on the ground water,  and most  likely

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                                49

would result in the aquifers near the Site eventually meeting  the
ground water remediation goals  (except for parameters that
naturally exceed .the goals) as  a result of controlling the
source, natural biodegradation, and other attenuation mechanisms.

The results of the HELP model runs in Table 1, demonstrate that
infiltration can be nearly eliminated using the site covers  in
Alternative 4B, without construction of a site cover that fully
complies with RCRA Subtitle C technical guidance.  In addition,
the leachate collection system  along the Yeoman Creek Landfill
portion of the site along with  the site cover will effectively
isolate Yeoman Creek from the landfill without construction  of
the deep slurry walls.

Alternative 5 has implementability problems including a lack of
space along the perimeter of the landfill for construction of
slurry walls, more disturbance  of nearby businesses and residents
due to importing a much larger  quantity of soil in order to
construct the five foot thick cap over a grading layer with  a  3%
slope,  and more potential to affect nearby properties and
structures due to the thicker capping requirement.  Therefore,
Alternative 5 is screened out.

C. MODIFYING CRITERIA: STATE AGENCY ACCEPTANCE; COMMUNITY
ACCEPTANCE.

The State of Illinois concurs in the U.S.  EPA preferred
alternative.
A representative of the potentially responsible parties (PRP)
participating in preparation of the Remedial Investigation/
Feasibility Study (RI/FS)  has indicated that the group favors
Alternative 3C,  which does not include a leachate collection
system along the Yeoman Creek Landfill portion, and includes the
active landfill gas control system, and a site cover using only
an FML for the barrier layer.  Alternative 3C is estimated to
cost $22,000,000 in present worth.  U.S. EPA agrees with use of
the active gas control system, but also believes that the
additional long-term protectiveness and permanence, and reduction
in leachate generation justifies the additional $ 1.7 million
construction cost for a site cover with a composite FML/clay
barrier layer. In addition, a barrier layer consisting of only an
FML does not comply with either the capping ARAR 35 IAC 811 or

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                                50

the current capping requirements applicable under 35 IAC 807 as
proposed by PRP representatives.

The City of Waukegan, the Waukegan Park District and Waukegan
School District #60, which are PRPs, have expressed concern
regarding their budgetary constraints, and, in particular, urged
U.S. EPA to use discretion in regarding the costs of the cap
alternatives,  the slurry wall, leachate collection,  relocation of
Yeoman Creek,  and ground water remediation.

It should be noted that U.S. EPA's preferred alternative does not
include the expensive site cover, slurry wall or ground water
control measures included in Alternative 5.  U.S. EPA's preferred
alternative also does not include a leachate collection system
along the Edward's Field Landfill nor relocation of Yeoman Creek
away from Edward's Field.

In its comments on the draft Feasibility Study,  the Lake County
Health Department supported the following components in the
selected remedy: a site cover with a composite FML/clay; a
leachate collection system along Yeoman Creek; an active gas
control system; and soil and sediment remediation.
U.S. EPA's preferred Alternative includes all of these
components.

Residents in the vicinity of the Site are expected to favor U.S.
EPA's preferred alternative since it will eliminate  the landfill
gas migration problem without causing potential  off-site risks
and odor problems.   In addition,  U.S. EPA's preferred alternative
will not entail nearly as much disruption of local  businesses as
Alternative 5  because the Site cover will not be as  thick and
because less soil would have to be imported onto the site.   In
spite of this,  U.S.  EPA's preferred alternative  will impact some
local businesses,  potentially including consolidation of wastes
from,  or construction of the site cover over business property in
locations where.landfilled wastes extend onto the properties,
including property at 1401-1451 Golf Road,  2122  Yeoman Street,
and 1615 Sunset Avenue.   The exact dimensions and location of the
cover will be  developed during the design of the U.S.  EPA's
selected remedial alternative.

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                                51

X.  THE SELECTED REMEDY

The selected remedy is Alternative 4B.  Alternative 4B, includes
the following components (these components are further expanded
including discussion of ARARs for each component):

A.  Construction of a new cover over the Landfill to minimize
infiltration precipitation through the landfill,  consisting of
the following (see options 4A and 4B Figure 7):

     a 3' foot frost protection layer including top soil and
     vegetation;

     a geosynthetic drainage layer with a hydraulic conductivity
     of at least 20 cm/sec and with a protective  geotextile
     filter fabric above the layer to prevent plugging;

     a 3 foot Compacted Clay Layer,  or a barrier  of equal or
     exceeding performance,  such as a composite  barrier layer
     consisting of a 40 mil  very low density polyethylene liner
     (or equivalent)  over either a geosynethic clay liner (GCL)
     or a 2-foot compacted clay layer;

     a gas ventilation layer with a hydraulic conductivity of at
     least 10"3 cm/sec with a protective geotextile filter fabric
     above it if the compacted clay layer option  is implemented;

     a grading layer to provide a 2% slope after  settlement;

 1.   Further Description:

     The construction quality control staff must  be certified by
     the National Institute  of Certification and  Engineering
     Technologies.

     A GCL consists of a thin layer of bentonite  clay
     inccrporated into a geosynthetic mesh.   The  GCL must be
     capable of  producing a  continuous low permeability clay
     layer below the FML.  The GCL must be able to withstand
     construction without tearing and must be self healing.

     Remedial Design concepts (i.e.  mounding cap  design;  limited
     consolidation)  to minimize the volume of grading materials

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                               52

    and the aerial extent of the landfill cover will be
    considered during the Remedial Design phase.

    The 3 foot Compacted Clay Layer must have a hydraulic
    conductivity of less than i X 10 -7 cm/sec. A composite
    barrier must have compacted clay or equivalent construction
    material must have a hydraulic conductivity less that 1 X
    10"6 cm/sec. The compacted clay layer, or equivalent
    material,  would make up some of the grading layer over the
    Site so as not to increase the quantity of imported soils
    needed.  Along the edges of the landfill where a grading
    layer would not be needed,  the compacted clay layer can be
    constructed by scarifying and compacting the existing soil
    cover to the greatest extent possible.

    The composite layer landfill cover will provide source
    control, the mechanism for preventing future ground water
    contamination.  Natural attenuation will abate existing
    ground water contamination.

2.   ARARs:

    This final cover system will meet the requirements of State
    of Illinois regulations 811.314 (which requires a barrier
    layer at least as effective as 3  feet of compacted clay with
    a hydraulic conductivity of 1CT7 cm/sec), and 811.322
    (slope,  vegetation and on-site structure requirements),  for
    new solid waste landfills.   In conjunction with other
    portions of the remedy, . it  also meets the closure
    performance standard for solid waste landfills in 35 IAC
    807.502 (minimize future maintenance and releases).   In
    addition,  Ambient Air Quality Standards 40 C.F.R.  §  50.6 and
    35 IAC 811.103 are ARARs for the  construction operation.
    Impacts on wetlands shall be subject to Executive Order
    11990, 40  CFR 6 Appendix A,  and Section 404 of the Clean
    Water Act.

   • RCRA hazardous waste landfill  site cover requirements are
    not considered ARARs because there is no documentation that
    listed RCRA hazardous wastes were disposed of at the Site,
    and because none of the leachate  samples even came close to
    meeting the definition of the  RCRA hazardous waste by
    characteristic.   However,  because of the presence of PCBs

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                                53

     and other hazardous substances at the Site, the RCRA site
     cover requirements should be considered.

     The selected site cover meets all of the criteria
     recommended in RCRA technical guidance documents for a
     hazardous landfill covers, with the following exceptions:
     use of a 2% slope instead of a 3% slope and acceptance of a
     1 X 10'5 cm/sec compacted  clay instead of 1 X 1CT7  cm/sec  in
     a composite barrier. Use of a 2% slope instead of 3% will
     reduce the quantity of soil that must be imported to the
     Site substantially,  which is a significant consideration
     both because of the costs and because the disruption that
     the construction will cause to adjacent businesses and
     residents.  Use of 1 X 1C"5 cm/sec instead of 1 X 10"7 cm/sec
     as the hydraulic conductivity requirement for the composite
     barrier compacted clay will increase the likelihood that
     local clays can be used for the construction,  and may reduce
     costs.  Neither the reduced slope requirement nor the
     reduced hydraulic conductivity requirement is expected to
     significantly increase infiltration through the landfill.

B.   Implementation of a comprehensive,  long-term monitoring
system which shall include sampling for leachate,  groundwater at
the edge of the landfill contents,  surface water and creek
sediments.   Action levels will be established in the monitoring
plan and shall include Maximum Contaminant Levels (40 CFR 141)
and 35 IAC 620.

In the event that Action Levels are exceeded for a specified
number of sampling events (to be determined and approved by U.S.
EPA after construction of the Site cap),  construction and
operation of a leachate collection system along both sides of
Yeoman Creek adjacent to the Yeoman Creek Landfill  portion of the
Site to prevent leachate and leachate contaminated ground water
from entering or seeping into Yeoman Creek will be required.

 1.  Further Description:   If determined necessary,  the leachate
     collection system is expected to consist of a  trench
     extending 12 to 18 inches below the level of Yeoman Creek.
     The trench will be lined with a membrane on the creek side
     in order to attempt to limit infiltration of creek water.

     The trench will be capped with a clay surface  seal.

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                               54

    Leachate will be collected in a 2 inch diameter pipe and
    will drain to a sump,  from which it will be pumped to a
    storage and treatment system.   It is anticipated that the
    leachate would either be treated (if necessary) and
    discharged to the North Shore Sanitary District treatment
    system, or transported off-site for disposal.

    Excavated material,  which will include landfilled wastes,
    from the leachate collection trench shall be consolidated
    and temporarily stored on-site before being contained under
    the new Site cover,  in the same manner as the contaminated
    sediments as described in Section X.D.  The construction and
    consolidation shall  be conducted in a manner that prevents
    any release of contaminants from the Site into Yeoman Creek,
    the wetlands,  or other off-site soils.
2.   ARARs:
    If the leachate is discharged to the North Shore Sanitary
    District,  the following ARARs will be applied:  40 CFR 403.5
    (pretreatment standards);  Northshore Sanitary District
    regulations;  35 IAC 307.1101-1103 (sewer discharge criteria)
    ;  35 IAC 310.201(a)  and (c)  (pretreatment standards);  35 IAC
    310.202 (pretreatment standards); and 35 IAC 309(d)  and
    309(e)  (leachate treatment and disposal).

    If the leachate is discharged to Yeoman Creek, the following
    ARARs will apply:  surface  water standards in 35 IAC Part
    302;  effluent standards 35 IAC 304.

    40 CFR 122.44 (requires permit for direct discharge),  35 IAC
    Part 302 (water quality standards),  35 IAC 811.103 (run off
    from disturbed areas),  Federal Water Pollution Control Act
    Section lll(b)(3),  40 CFR  110.6 (discharge prohibited),
    Clean Air  Act Section 101,  40 CFR 52,  40 CFR 61 shall  be
    construction  requirements.

    Although no testing of  excavated wastes and soils will be
    required,  it  is possible that some of  the waste and soils
    excavated  for the  leachate collection  system may contain
    PCBs exceeding 50  ppm.   Excavation of  these wastes and soils
    and consolidation  on-site  could be considered disposal of
    PCBs pursuant to 40 CFR 761.1(b).

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                                55

In this case, 40 CFR  761.60 (a) (4) would  require  any non-liquid
PCBs' at concentrations of  50  ppm  or  greater  in the  form of
contaminated soil, rags,  or other debris  shall be disposed  of:
(i) In an incinerator which complies with 761.70; or (ii) in a
chemical waste landfill which complies with  761.75.

The selected remedy provides  for  disposal of  the PCBs  in a
landfill that does not meet the following chemical  waste landfill
requirements of Section' 761.75(b): bottom liner  requirements
because the landfill 'does  not  have a bottom  liner  (761.75(b) (1)
or (2));leachate collection requirement  and  requirement  for a
fifty foot distance between bottom liner  and  historical  high
water table (761.75 (b) (3)  and  (b) (7)), and landfill  operation
requirement (761. 75(b) (8) .  However, pursuant to 761. 75 (c) (4) ,
the Regional Administrator has determined that for  this  Site the
requirements in 761.75(b)(1),  (2),  (3),(7), and  (8)  are  not
necessary to protect human health and the environment.   For this
Site,  the low permeability site cover, leachate  collection
system,  if indicated, long term monitoring, access  restrictions,
and institutional controls included  in the selected  remedy
provide protection to the public  health and the  environment.
Since the remedy provides  for  containment  of  the bulk  of the PCB
contamination,  which will not  be  moved,  below the new  site
cover,  no additional protection to the public health or  the
environment would be added by  off-site transport and disposal of
the leachate collection material  in  an incinerator complying with
761.70  or in a chemical waste  landfill complying with  761.75(b).
The written statement of this  finding and waiver by the  Regional
Administrator,  as required in  761.75(c) (4), is provided  by
signing this Record of Decision.

The material excavated for the leachate collection system will be
consolidated and temporarily stored  above the 100 year flood
elevation.   The remedy will comply with 40 CFR 761.75(b) (4)  (ii),
which requires diversion of surface  water run-off from a 24-hour,
25-year storm.

The remedy will also comply with  761.75(b)(5), which requires a
site  to have a moderate relief, 761.75(b)(6), which requires
surface water and ground water monitoring, and 761.75(b)(9),
which includes requirements for support facilities.

Regulations relevant  to active landfilling operations  such  as

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                                56

the waste handling requirements of 811.105, 106, and 107, are not
ARARs but should be considered.  These regulations should not be
ARARs because the operations and conditions for this remedial
action are very different from the operations and conditions - at
operating landfills.

The Yeoman Creek Landfill along with adjacent and downstream
contaminated sediments within Yeoman Creek, and contaminated
soils adjacent to the Landfill, constitute a single area of
contamination.  Therefore, excavation of contaminated sediments
in Yeoman Creek and excavation of soils and landfilled wastes
away from Yeoman Creek and consolidation on-site for final
containment under the Site cover along with the rest of the
landfilled wastes,  does not constitute placement or disposal and,
therefore, will not trigger the storage,  handling or disposal
requirements of RCRA,  TSCA,  or the State of Illinois Waste
Disposal Regulations (the treatment and air emission requirements
relevant to hazardous waste in 40 CFR 260-268 and 35 IAC 724 are
not anticipated to be ARARs since no listed hazardous wastes are
known to have been disposed of in the Landfill and the leachate
samples collected were not even close to the criteria for a
hazardous waste by characteristic.)   The leachate collection
system requirements in 35 IAC 307, 308 and 309 [except for 309(d)
and 309(e)]  shall not be ARARs since these requirements relate to
construction of new landfills having a bottom liner and drainage
system.

Regulations relative to stabilization of hazardous wastes such as
40 CFR 264.228(a)(2),  which requires elimination of free liquids
by removal- or solidification,  and stabilization of remaining
wastes and waste residues to support a cover are not ARARs
because the consolidation operation on the existing Site cover is
much different than the type of operation in a surface
impoundment.   In addition, there is no documentation identifying
that listed hazardous wastes were disposed of on the Site,  and
leachate samples from the Site have not even come close to
meeting the criteria for a RCRA hazardous waste.

Construction and operation of an active perimeter landfill gas
collection and treatment system.

 1.   Further Description:  A landfill gas collection trench will
     be constructed along the perimeter of the Landfill except

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                                57

     along the sides that are adjacent to Yeoman Creek or the
     wetlands  (see Figure 8).  A blower or fan will be used to
     remove the gases from the perimeter trench system.  One
     trench system and blower will be located on the northern
     portion of the landfill, and another in the Edwards Field
     area.  The gases collected will be directed to the center of
     either the northern portion of the Site or to the center of
     the Edwards Field area for treatment'by flaring or some
     other equally effective method.

 2.  ARARS:  The following ARARs will be applied:  Clean Air Act
     Sections 101 and 40 CFR 52 (requires design of an odor free
     operation, and filing an air pollution emission notice);  40
     CFR 61 (limits on hazardous air pollutants); 35 IAC 811.311
     (requires active gas control system)  ;  35 IAC 811.312
     (requires treatment of collected landfill gas); and 35 IAC
     211, 212, 214, 215, 216, and 217 (emission regulations).

C.   Excavation and consolidation of contaminated sediments and
surface soils in limited wetland areas exceeding cleanup action
levels:

 1.  Further Description:  It may be advantageous to excavate
     sediments within the main channel of Yeoman Creek and
     wetland sediment as shown in Figure 5  in order to facilitate
     compliance with floodplain/floodway regulations.   In this
     case the excavation can be conducted without preliminary
     sampling provided that the excavation is conducted in a
     manner that will not negatively impact  the wetland
     hydrology.

      Following the excavation,  the sediments shall be
consolidated and contained as described below.

     Otherwise, only sediments within the main channel of Yeoman
     Creek and sediments in the wetland south of Edwards Field
     that exceed the following cleanup action levels (CALs)  shall
     be  excavated,  consolidated on-site,  temporarily contained
     under a temporary site cover to prevent  wind and water
     erosion,  and then permanently contained  under the new site
     cover provided that the excavation is conducted in a manner
     that will not  negatively impact the wetland hydrology.
     Prior to the excavation,  composite  samples should be

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                               58

    collected on every 100-500 feet of stream length and 40,000
    square feet of surface area to evaluate whether the relevant
    portion of the sediment attains the CALs.

    However,  if it is demonstrated to the satisfaction of U.S.
    EPA that a parameter within an area exceeds the CAL for that
    parameter solely because of a source other than the Site,
    then sediment excavation within that area need not be
    performed.

    The excavation, consolidation, and temporary containment
    shall be conducted in a manner that minimizes release of
    contaminants from the Site into Yeoman Creek,  the wetlands,
    or other off-site soils.   It is anticipated that for
    temporary containment,  a berm will be constructed around
    designated areas on the Site.   The excavated sediments will
    be placed within these bermed areas to a depth not expected
    to exceed 1 foot.   After the excavated sediments have
    dewatered to a consistency that can support low ground
    pressure earthwork equipment,  the sediments will be covered
    with at least 6 inches of clean soil.

2.  Definition of CALs':   Following is a list of the sediment
    CALs.   The derivation of these CALs is described in
    Attachment 1.

    For PCBs8:  [A-1242]/2+[A-1248]+10  X  [A-1254] =3.4 mg/kg

    For Lead:  180 mg/kg .

    For PAHs:  26 mg/kg

    For Zinc:  317 mg/kg

3.  ARARs:   The following ARARs shall be applied:   40  CFR 110.6
    (discharge  prohibited);  Water  Quality Standards 35  IAC Part
   .302;  35 IAC 811.103  (run off from disturbed areas);
    Executive  Order 11990 (wetland protection);  40 CFR  6
    Appendix A (wetland protection);  40 CFR 6.302(g)  (fish and
    wildlife protection);  Clean Air Act Section 101;  40  CFR 52;
    8  A- means Arochlor.

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                           59

40 CFR 61.

Regulations relevant to active landfilling operations  such
as  the waste handling requirements of 811.105,  106, and
107, are not ARARs but should be considered.  These
regulations should not be ARARs.because the operations and
conditions for this remedial action are very different from
the operations and conditions at operating landfills.

Some of the excavated sediments may contain PCBs exceeding
50 ppm.  Excavation of these sediments and consolidation on-
site could be considered disposal of PCBs pursuant to 40 CFR
761.Kb).  In this case,  40 CFR 761.60(a)(5) requires
either: disposal of the sediments in an incinerator
complying with 761.70; a chemical waste landfill complying
with 761.75; or by an alternative' method approved by the
Regional Administrator.  Pursuant to 761.75(c)  (4), the
Regional Administrator has determined that for this Site the
requirements in 761.75 (b)(1),(2),(3),(7)  and  (8) are not
necessary to protect human health and the environment,  and
that on-site consolidation,  temporary containment, final
containment under a low permeability cover, long term
monitoring, access restrictions,  and institutional controls
provide adequate protection to health and the environment.
Since the remedy provides for containment of the bulk of the
PCB contamination, which will not be moved, below the new
site cover, no additional protection to the public health or
the environment would be added by requiring the very costly
off-site transport and disposal of the contaminated
sediments exceeding 50 ppm of PCBs in an incinerator
complying with 761.70 or in a chemical waste landfill
complying with 761.75(b).

The written statement of this finding and waiver by the
Regional Administrator, as required in 761.75 (c)(4), is
provided by signing this Record of Decision.

As previously noted in Section X.C,  RCRA and State of
Illinois Solid Waste regulations  will  not be applicable to
the movement of contaminated sediments because the action
constitutes consolidation and not placement or disposal.
Also as noted in Section X.C, regulations relative to
stabilization of hazardous wastes such as 40 CFR 228(a)(2)

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                                60

     are not considered relevant  and appropriate.

     It should be noted that excavated sediments will be allowed
     to dewater on-site.  This will result in seepage of a small
     amount of additional water through the existing site cover
     and generation of some additional leachate.  However, the
     quantity of leachate generated will be very minor compared
     to the total estimated quantity of leachate generated by
     infiltration of precipitation through the site cover (the
     estimated maximum volume of  sediment excavated will be 7,220
     cubic yards, of which possibly 20% will infiltrate through
     the cover, compared to 67,000 cubic yards per year of
     leachate generated under existing conditions).

D.  Actions, including investigations,  modeling, alternative
evaluation, and implementation necessary to comply with the
Illinois Department of Transportation regulations (92 IAC 708)
and the Lake County Storm Water Management Commission Watershed
Development Ordinance.  Compliance may entail:  creation of
compensatory storage for lost flood plain and floodway storage;
use of artificial channels combined with detention facilities or
other technologies to maintain stream capacity without increasing
the average velocity through the Site;  excavation of landfill
wastes and soils at the Site out of the floodway and flood plain
and consolidation and temporary containment on-site  for final
containment under the new Site cover;  approval  of a  variance from
the floodway and flood plain regulations by the regulatory
Agencies.

If excavation and on-site consolidation and temporary containment
of wastes  occurs,  it shall be conducted in the  same  manner as
described in Section X.B for excavation of wastes for the
leachate collection system.

 1.  ARARs:  The following ARARs shall  be applied:   92 IAC 708;.
     Lake  County Watershed Development  Ordinance;  40 CFR
     6.302(g)  (wetlands protection);  35 IAC 811.103  run off  from
     disturbed areas); 35 IAC 311(b)(3);  40 CFR 110.6;  Water
     Quality Standards 35 IAC Part 302; Executive Order 11990;  40
     CFR 6 Appendix A; 40 CFR 230.70;  40  CFR 6.302(g);  Clean Air
     Act Section 101;  40 CFR 52;  40 CFR 61.

     If -excavation and on-site consolidaticn and temporary

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                                61

     containment of wastes occurs, the same ARARs for these
     operations identified in Section X.B shall apply.

E.  Rerouting and sealing storm drains that go through the
    Landfill.

 1.  Further description:  It is expected that two storm drains
     that go through the Yeoman Creek Landfill portion will have
     to be rerouted and sealed  (see Figure 6).  Drains that
     originate on-site will be sealed under the new site cover,
     and so will not need to be relocated or sealed.

 2.  ARARs:  Executive Order 119990; 40 CFR 6, Appendix A; 40 CFR
     and 40 CFR 6.302(g) (fish and wildlife protection).   In
     addition, the Lake County Watershed Development Ordinance
     Article IV.D should be considered.

F.  Actions to minimize the destruction,  loss, or degradation of
    wetlands, including compensation for wetlands that will be
    adversely affected by the selected remedial action.

 1.  Further Description:  This shall include actions to prevent
     or minimize negative impacts on the wetlands due to
     construction activities and the final remedy.  Compensation
     shall be provided for wetlands that are lost or negatively
     impacted by the remedial actions.   A detailed wetland
     mitigation plan is required.

 2.  ARARs:  The following ARARs shall  be applied:  Clean Water
     Act Section 404;   Executive Order  119990; 40 CFR 6,  Appendix
     A; and 40 CFR 6.302(g).   In addition,  the Lake County
     Watershed Development Ordinance Article IV.D should be
     considered.

G.  Attainment of surface water quality standards by control of
the source of contamination.

 1.  Further Description:   No active surface water remediation
     will be conducted,  but surface water quality standards shall
     be attained and the potential risk identified in the
     Remedial Investigation due to detection of cyanide  and
     acetone eliminated (except for parameters that exceed the
     standards because of reasons  not related to  a release from

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                                62

     the Site) 'by controlling the source including construction
     of the new.site cover, and the leachate collection system
     along Yeoman Creek along the northern portion of the
     landfill.

 2.   ARARs:   The  following ARARs shall apply unless the
     exceedance is due to a condition that is not related to a
     release from the Site:  35 IAC 302.  Federal Ambient Water
     Quality Criteria are not ARARs because fish are usually not
     present in Yeoman Creek because it is an intermittent
     stream.

H.   Attainment  of ground water quality standards by control of
the  source of contamination with no contingency for initiating
direct remediation of ground water is included.

 1.   Further Description:  No active ground water remediation
     will be conducted,  but ground water quality standards shall
     be attained  and the potential risk identified in the
     Remedial Investigation due to detection of  vinyl chloride,
     benzene,  bis(2-ethylhexyl)phthalate,  pentachlorophenol,
     arsenic,  beryllium,  and lead shall be reduced or eliminated
     to the  extent that  the contamination is due to a release
     from the Landfill by controlling the source by construction
     of the  new site cover, and operation of. the active landfill
     gas control  system.   No contingency for initiation of active
     ground  water remediation is included for the following
     reasons:

          the ground water is already close to meeting cleanup
          requirements (except for constituents  that may not  be
          Site  related)  -- apparently considerable ground water
          protection is  being provided even without an improved
          cap through natural mechanisms such as biodegradation,
          adsorption onto organic deposits,  and  other attenuating
          mechanisms;

          the ground water is not used in the vicinity of the
          Site  and usage  restrictions are in place;

 2.   ARARs:   Within a three dimensional region of ground water
     that exceeds Illinois Ground Water Quality  Standards in  35
     IAC 620.410  and 620.420 as  appropriate due  to a release  at

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                                63

     the Site, a ground water management zone shall be defined
     consistent with 35 IAC 620.250.  The source containment
     measures implemented under the selected remedy shall
     constitute an approved corrective action for the ground
     water as it relates to 35 IAC 620.250.  Therefore,
     implementation of the selected remedy will satisfy the
     criteria defined in 35 IAC 620.250(a).  Ground water
     management period required pursuant to 620.250(b) shall be
     30 years from the date of completion of construction.  In
     accordance with 35 IAC 620.450, at the end of the 30 year
     period, the ground water standard for each constituent shall
     either be: the IGWQS in 35 IAC 620.410 or 620.420 as
     appropriate if such standard is attained for that
     constituent;, or the concentration as determined by ground
     water monitoring,  if such concentration does not attain the
     relevant IGWQS.

     The remedy shall also attain the Primary Federal Maximum
     Contaminant Levels (40 CFR 141).

I.  Additional investigation to define a ground water management
zone, the extent of sediment excavation,  and baseline wetland
conditions.

 1.  Additional ground water sampling is needed to define the
     three dimensional  area of the ground water management zone.
     Additional sampling may be required to define the required
     extent of sediment excavation,  including collecting
     composite samples  every 100-500 feet of stream length and
     40,000 square feet of surface area in the limited wetland
     areas identified in Figure 5.  The Remedial Investigation
     did not adequately define the baseline quality of the
     wetlands south and east of the Site.   Therefore,  a more
     thorough ecological evaluation shall be conducted,  including
     characterization of water,  habitat,  and vegetative quality
   •  in the wetlands.   These will be used as a baseline for the
     long term monitoring.

 2.  ARARs:  The following ARARs shall be applied:   35 IAC 250.

J.  Enclosing Yeoman  Creek in a corrugated steel semi-arch pipe,
as necessary for construction of the site cover.   ARARs would be
the same as others identified for actions that may impact

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                                64

wetlands and wildlife.

K. Excavation and consolidation under the new cover of limited
soils and wastes potentially contaminated by the Site that will
be outside of the site cover, and that exceed 10 mg/kg
polychlorinated biphenyls.  ARARs are the same as other actions
that involve moving soil that may be contaminated by PCBs.   In
addition, the lOmg/kg action level is from the PCB Spill Cleanup
Policy for non-restricted access areas (40 CFR 761.125 (c) (4) (v) .

L.  Continuation of landfill gas interim measure:  To provide
continued protection from potential landfill gas entry into
adjacent buildings, the landfill gas monitoring and interim  •
actions provided for in the present Amended Consent Order for the
Remedial Investigation/Feasibility Study shall continue until
full operation of the active perimeter gas control system is
initiated.

M. Long term monitoring of ground water,  surface water, surface
sediments, landfill gas emissions,  and wetland conditions to
verify the effectiveness of the remedial action.

 1.  Further Description:   Long term ground water,  surface water,
     surface sediment, landfill gas emissions,  and wetland
     monitoring shall be conducted to evaluate the effectiveness
     of the remedial actions.

 2.  ARARs: Applicable ARARs include 35 IAC 807.318.

N.   Implementation of access restrictions,  including enclosing
     the entire Site in a fence and posting warning signs.

0.   Imposition of deed restrictions prohibiting future usage of
     the Site for purposes that are inconsistent with the
     selected remedy;

P.   Long term maintenance or post-closure care.

 1.  Long term maintenance shall be provided to the site cover,
     the leachate collection system,  and the active landfill gas
     control system.

 2.  ARARs:  Applicable ARARs include 35  IAC 811.Ill(c),  807.318,

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                                65

     811.316.

IX.  STATUTORY DETERMINATIONS

U.S. EPA's preferred alternative  is believed to provide  the best
balance of trade-offs among alternatives with respect  to the
criteria used to evaluate remedies.  Based on the  information
available at this time, therefore, U.S. EPA and the  State of
Illinois believe the preferred alternative would protect human
health and the environment, would comply with ARARs, would be
cost-effective, and would utilize permanent solutions  and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.  The preferred
alternative will not satisfy the preference for treatment as a
principal element.

X.  DOCUMENTATION OF SIGNIFICANT CHANGES

The U.S. EPA Proposed Plan, May 1995,  identified Alternative 4B
as the recommended alternative for Yeoman Creek Landfill.  In
addition to a landfill cover with a composite barrier  layer
consisting of a Flexible Membrane Liner over a Geosynthetic Clay
Liner or a Flexible Membrane Liner over a Compacted Clay Liner
with Active Gas Control, a leachate collection system  was also
proposed.

During the public comment period,  the Yeoman Creek Steering
Committee submitted comments relating to the type of landfill cap
(see Responsiveness Summary for U.S.  EPA responses) and  leachate
collection system proposed by U.S. EPA. ' At a July 30,  1996,
meeting with the Yeoman Creek Steering Committee,  the  committee
again urged U.S. EPA to reconsider the need to construct a
leachate collection system during the initial implementation of
Remedial Action.

The current site conditions indicate  that the Yeoman Creek
portion of the landfill is discharging only limited volume of
leachate (500 gallons per day or 0.3  gallons per minute  into
Yeoman Creek.)   Furthermore,  construction of a composite barrier
cover,  as recommended in the U.S.  EPA Proposed Plan,  will
minimize the production of leachate within the landfill;
therefore,  the volume of leachate  discharging into Yeoman Creek
will be further reduced.

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                                66

Based upon review of the current site conditions,  U.S. EPA has
determined that in lieu of initially constructing the leachate
collection system, a long-term monitoring system shall be
implemented.  The long-term monitoring system will monitor the
leachate production in the landfill and monitor quantity and
quality of leachate discharging into Yeoman Creek.

The sampling and analysis shall include leachate/groundwater
sampling along Yeoman Creek,  sediment and surface water sampling
in Yeoman Creek, and leachate sampling within the landfill.
Furthermore, the installation of additional monitoring wells and
piezometers will be necessary to evaluate whether the
leachate/groundwater from the landfill continues to discharge
into Yeoman Creek.

Action levels for surface water and leachate/groundwater levels
shall be MCLs and 35 IAC 620 standards.   The impact on the
sediments would be determined by comparing the level of
contaminants in the sediments during the monitoring period with
the level of contaminants in the sediments immediately after
sediment excavation in Yeoman Creek.

In the event that the specified standards are exceeded,
construction,  operation and maintenance  of the leachate
collection system shall be required of the parties responsible
for implementation of Remedial Action and long term operation and
maintenance.

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           ATTACHMENT 1 TO THE RECORD OF DECISION SUMMARY
 Attachment 1 to the Record of Decision Summary explains the
 development of sediment cleanup action levels (CALs)  by U.S. EPA.
 The risk calculations for development of these CALs were
 performed -by ICF Kaiser under U.S.  EPA oversight and are
 incorporated into the Remedial Investigation Report.

 I.   Sampling

•Sampling area:  A composite sample  should be collected every 100-
 500 feet of stream length and 40,000  square feet of surface area
 to  evaluate whether this portion of the sediment attains the
 CALs.

 II.   Polychlorinated Biphenyls CAL

 According to the ecological risk calculations,  PCBs may cause a
 toxic  hazard to mink even from the  A-1248 present in the wetland
 soils.   Since we are not excavating the wetland soils,  it would-
 be  unreasonable to require excavation of sediments unless the PCS
 concentrations  significantly exceed that concentration in the
 wetland soils.   The 95% UCL of the  average concentration for A-
 1248 of 3.4 mg/kg will  be used to  indicate that  A-1248
 significantly exceeds concentrations  in the surface soil.   For
 Arochlors other than A-1248,  the CALs should be  adjusted to take
 into account the relative toxicities  of the Arochlors.    The risk
 from 3.4 mg/kg  of A-1248 is equal  to  the risk from 6.8 mg/kg of
 A-1242,  or 0.34 mg/kg of A-1254.  To  take into  account cumulative
 effects in case more than one Arochlor is present,  the following
 equation will be used:

      [A-1242]12 + [A-1248]  + 10  X  [A-1254]  =3.4 mg/kg

 III.   Lead CAL

 According to the ecological risk calculations,  lead may cause a
 toxic  hazard to red-winged black birds even from lead that may be
 present in the  wetland  soils.   Since  we are not  excavating the
 wetland soils,  it would be unreasonable to require excavation of

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sediments unless the lead concentrations  significantly  exceed
that -concentration in the wetland soils.  The  95% UCL of  the
average for lead in surface soil of 180 mg/kg  will be used  to
indicate that lead significantly exceeds'concentrations in  the
soil.

IV.  PAH CAL

According to the calculations, cumulative PAHs may 'cause  a  toxic
hazard to red-winged black birds even from PAHs that may  be
present in the wetland soils.  Since we are not excavating  the
wetlands soils, it would be unreasonable  to require excavation of
sediments unless the PAH concentration significantly exceeds the
concentration in the wetland soils.  The  95% UCL of the average
for PAHs in soil of 10 mg/kg could be used, but the maximum
background stream sediment concentration of 18 mg/kg is larger.
This amount can be adjusted to 26 mg/kg to account for
uncertainty in the analytical method.   Therefore,  the CAL for
cumulative PAHs is 26 mg/kg.

V.  Mercury

According to the calculations, mercury may cause a toxic hazard
to red-winged black birds even from mercury that may be present
in the soils.   Since the maximum mercury concentration  in
sediments is less than the 95% UCL of the average concentration
in the wetland soils,  and the wetland soils are not being
excavated,  no sediment CAL is proposed for mercury.

VI.  Zinc CAL

According to the calculations, zinc may cause a toxic hazard to
red-winged black birds even from zinc that may be present in the
soils.   Since we are not excavating the wetlands soils,  it would
be unreasonable to require excavation of sediments unless the
zinc concentrations significantly exceed concentration in the
wetland soils.   The 95% UCL of the average for zinc in soil of
223 mg/kg could be used,  but the maximum background sediment
concentration of 276 mg/kg is higher.   This value can be adjusted
to 317 mg/kg to account for uncertainty in the analytical method.
Therefore,  the  CAL for zinc is 317 mg/kg.

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           U.S.  EPA RESPONSES  TO PUBLIC COMMENTS ON THE

      EVALUATION OF ALTERNATIVES AND PROPOSED PLAN FOR THE

                    YEOMAN CREEK LANDFILL SITE
I.  RESPONSES TO COMMENTS FROM THE YEOMAN CREEK STEERING
COMMITTEE AND TO COMMENTS MADE DURING THE PUBLIC MEETING BY THE
HONORABLE JAMES F. DURKIN. MAYOR OF THE CITY OF WAUKEGAN
ISSUE 1.

COMMENT IN INTRODUCTION TO COMMENTS IN JULY 15, 1995 LETTER:
U.S. EPA must consider this balance [a practical balance between
protecting human health and environment and the cost of cleaning
up this Site] in determining a practical and effective Site
cleanup.  U.S. EPA must weigh the adverse social and economic
effects...  It is in this context that we respectfully request
that U.S. EPA broaden its consideration of the human health and
environment at Yeoman Creek Site to include the health and
financial welfare of Waukegan's citizens.

COMMENT BY MAYOR DURKIN DURING PUBLIC MEETING:  "The $6 million
you are asking us to pay harms the overall wealth,  health, and
welfare of this City."  "Our citizens should not be asked to give
up essential services so that a landfill plan can be gold plated"

U.S. EPA RESPONSE:

At all Superfund Sites,  the United States Environmental
Protection Agency (U.S.  EPA)  is required by law to select an
alternative that will be protective of human health and the
environment and that meets applicable or relevant and appropriate
State and Federal laws.   The cost of an alternative is also a
very important consideration.   The cost of an alternative is
balanced against its long-term effectiveness and permanence, its
degree of permanent treatment,  its short term impacts, and its
implementability.   It should also be pointed out that U.S. EPA
and Illinois Environmental Protection Agency (IEPA) have made
efforts to take into account specific conditions on this Site to
reduce costs, while still retaining the additional long term
protectiveness of the leachate collection system and the
performance requirements of the site cover barrier layer.  This

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has resulted  in an opportunity  to demonstrate  that  an  alternative
with, a leachate collection  system for only  the northern  portion
of the landfill is not necessary to be protective,  and with a
site cover that does not meet many of the technical items
normally required for hazardous waste landfills, .but are less
important at  this Site.

Besides costs, community acceptance is a consideration that can
lead to a modification of the remedy.  The  information provided
by the officials of the City of Waukegan, Waukegan  School
District #60, and the Waukegan  Park District on their  financial
difficulties, has been taken into account in the remedy
selection, as have comments from a few of Waukegan's citizens
expressing concern about costs.

It should be pointed out that a number of viable private parties
share liabil_cy for costs with the governmental parties; so  the
entire cost of the remedy will not be born  by  the governmental
parties.
ISSUE 2.

COMMENT 1  (July 15, 1995 letter); COMMENT 2  (August 24, 1995
letter):  There is no significant human health risk associated
with the current and foreseeable usage of the site.  COMMENT 2
(August 24, 1995 letter):  Risks associated with Landfill Gas are
being addressed both currently and by the Remedy Recommended in
the Feasibility Study.  COMMENT BY MAYOR DURKIN DURING PUBLIC
MEETING: "These old landfills are presenting no significant risk
to the health of the people."

U.S. EPA RESPONSE:

As documented in the Remedial Investigation  (RI),  there are some
significant risks to nearby residents due to the Site under
current usage conditions (estimated to be 1.6 X 10"5 for the
reasonable maximum exposure assumptions,  and 2.2 X 10~6 for
average exposure assumptions).   These include risks due to off-
site migration of landfill gases.  The off-site migration of
landfill gas presents a fire and explosion risk as well as a risk
from exposure to toxic chemicals.  These risks are temporarily
being addressed by monitoring and operation of a basement
ventilation system in one adjacent building.  In addition, there
is a limited risk to nearby residents under current conditions

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due to potential for contact with polychlorinated biphenyls
 (PCBs) and other hazardous substances in surface soils, surface
water and contaminated sediments from the Site.

U.S. EPA agrees that the ventilation system installed by the
Yeoman Creek Steering Committee combined with periodic monitoring
by the Steering Committee is adequate as a temporary measure to
address the risks from the off-site landfill gas migration.  U.S.
EPA also agrees that the risks from the off-site landfill gas
migration will be addressed in the final remedial action by
construction and operation of an active gas ventilation system.

The RI also documents that ground water contamination from the
Site would make the ground water unacceptable for residential use
due to the human health risk.  Since the Site is surrounded by
residential and commercial developments, it appears likely that
the Site would have been developed for residential or business
use if it had not been used as a landfill.   Future development of
the Site for residential or business usage would be unacceptable
because of the human health risk due to the fire and explosion
hazard and due to potential exposure to hazardous substances.

Standard U.S.  EPA procedures were used to develop the risk
assessment conducted in the RI.
ISSUE 3.

COMMENT 2 (July 15,  1995 letter), and Comment 3 (August 24, 1995
letter):   There is no significant ecological risk associated with
the current and foreseeable usage of the Site.

U.S. EPA RESPONSE:

It should be emphasized that Congress mandates that U.S. EPA
enter agreements allowing potentially responsible parties  (PRPs)
to conduct risk assessments even though the PRPs have a direct
financial interest in minimizing the estimated risks. -To balance
this bias, Congress  also mandates for U.S.  EPA to provide
oversight of the RI/FS to assure that the PRPs'  interests are
properly balanced by public health and the environmental
concerns.  Under these conditions,  it is not surprising that PRPs
and U.S.  EPA have differing points of view regarding risk

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assessment procedures.   In  spite  of  the  disadvantages  of  this
process,  it does have  the benefit  that it  assures  that the risks
were carefully considered during  the process,  since  it is an
issue that is very  important  to PRPs.

The Administrative  Record clearly  shows  that  U.S.  EPA  did suggest
use of breeding red-winged  black birds and mink  as indicator
species for the risk assessment but  did  not  "insist" on using
these species, and  that  the PRPs were encouraged to  suggest
alterative indicators.

A review  of mink habitats indicates  that mink and  related mammals
could occur at this Site and  may be  currently present  in  spite  of.
the limited access  to  appropriate  contiguous  habitats.  In fact,
the limited access  to  appropriate  contiguous  habitats  may
concentrate mink in the  area, leading to higher  than average
numbers of individuals in the smaller area.   Mink  do not  require
fish as a prey source  and,  in fact,  utilize a wide variety of
terrestrial and aquatic prey.

It should be noted that  improvement  of the wetlands  in the
vicinity of the Site may improve the habitat  for various  wildlife
species,  including mink, in the future.  While the mink is a
sensitive indicator, it may be no  more sensitive than  many other
mammals that have not been  adequately tested.

•The red-winged blackbird is not a  particularly sensitive
indicator.  During the breeding season, males  are  very
territorial and are not expected to  travel far from the nest.
Given that the Site is "an  island  of undeveloped habitat",  it is
reasonable to assume the life support requirements for breeding
red-winged black birds (i.e. food, water, etc.)  may all come from
the Site.   Therefore,  while conservative, these  assumptions  may
in fact, be appropriate for this Site.   It should  be noted that,
based on suggested procedures by U.S. EPA, the first draft  of the
RI Report dated August 1993 (p.  181)  used the  assumption  that all
of the food and water was derived  from the Site.

The ecological risk assessment is  intended to determine whether
or not the Site is or may be adversely impacting the environment.
The ecological risk assessment does not evaluate risks  to  only
one individual animal but evaluates risks to  all individuals in
the area surrounding the Site.  Since the ecological risk

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assessment for the Yeoman Creek Landfill Site determined that a
risk exists to red-winged black birds and mink, the Site
contamination may be depressing the populations of birds and
mammals in the area of the Site.

Other issues addressed by U.S. EPA comments provided to the PRPs
required the following changes in the ecological risk assessment:

     Use of standard U.S. EPA procedures for screening background
     concentrations and for determining the exposure point
     concentrations.

     Consideration of seep sediments as an exposure point.

     Consideration of soil ingestion as an exposure route.

     Provision of a more complete explanation of the derivation
     of reference doses.

     Use of uptake factors derived, directly from experimental
     results,  and not adjusted by unsupported distributional
     assumptions.
ISSUE 4.

COMMENT 3 (July 15, 1995 letter):   U.S. EPA should rely on the
stocastic risk assessment because the deterministic risk
assessment relies on default exposure assumptions which are not
reasonably expected to be encountered at the Site.

U.S. EPA RESPONSE:

It is very important that for all  Superfund sites to be addressed
in a consistent manner,  and that  risks be identified and
addressed before adverse affects  occur.  The first step in this
effort is to assure that all risk assessments are conducted in a
consistent manner.  In order to assure this, U.S. EPA requires
that all risk assessments whether prepared by U.S. EPA or by PRPs
be conducted consistent with U.S.  EPA risk assessment guidance.
What the PRPs are requesting in this comment is for U.S. EPA to
approve use of a very different risk assessment procedure just
for this Site.  A second step in  this effort is to identify,

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characterize and address potential  risks  from  the  Site -rather
than waiting for real adverse effects  to  occur.

U.S. EPA risk assessments are not data and  are not  necessarily
designed to be realistic.  Rather,  they are designed  to  identify
and characterize current potential  risks  in a  consistent manner.
Hopefully, the end result of this effort  will  be to identify and
characterize human health and environmental threats so that they
can be addressed before the adverse effects actually  occur.  As a
result, U.S. EPA risk assessment guidance provides  for
calculation of risks based on current  usage of the  Site as well
as based on potential future usage of  the Site.

Generally, U.S. EPA bases Site decisions  on risk estimates-
calculated based on a reasonable maximum  exposure  (RME) estimate
and on conservative toxicity estimates.   The overall  risk
estimate should be reasonably conservative.  U.S. EPA also
considers estimates that are less conservative and  possibly more
likely to occur.

U.S. EPA does not agree that risk estimates calculated in
accordance with its guidance documents is "overly conservative".
The procedure described by the PRPs in the  first two  paragraphs
of this Comment refers to the maximum  or worst case exposure
estimates, not to the RME,  which is now used for decision making
by U.S. EPA.  Specifically according to the HHEM (p.  6-19) :

     For Superfund exposure assessments,   intake,  variable values
     for a given pathway should be selected so that the
     combination of all intake variables results in an estimate
     of the reasonable maximum exposure for that pathway.

U.S. EPA's risk estimates are generally not designed  to reflect
actual risks,  but to estimate the risk under reasonable maximum
exposure conditions.   Furthermore,  the RME  is not tied strictly
to numerical distributions,  as stated  in the HHEM  (p.  6-19):

     As discussed previously,  a determination of "reasonable"
     cannot be based solely on quantitative information,  but  also
     requires the use of professional judgment.

The PRPs state that the ecological risk assessment conducted  by
the PRPs uses "worst  case data points" (apparently referring  to

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the concentration term).   This is not correct.  For the concent-
ration used to estimate exposures, U.S. EPA uses an estimate of
the average concentration called the 95% upper confidence level
(UCL)  of the average concentration.  Normally, the 95% UCL of the
average concentration is not much larger than the calculated
average concentration, unless there are very few samples.  In
cases where the 95% UCL of the average exceeds the maximum
concentration detected, the maximum concentration is used instead
of the 95% UCL of the average.  During the conduct of the RI, the
PRPs showed no interest in collecting additional samples in order
to obtain an improved estimate of the average concentration.

The PRPs state that the factors required in U.S. EPA guidance
documents (we presume this refers to factors such as ingestion
rates for drinking water,  soil and food)  are "derived from single
values for each of a variety of parameters".  This is clearly a
misstatement.   Each of the factors required by U.S. EPA are the
best estimates based on all available information,  including
experimental data and in some cases extensive surveys.

The "stocastic risk assessment" prepared by ICF Kaiser for the
PRPs was reviewed by Karen A. Hammerstrom,  one of U.S. EPA's
foremost experts on use of probabilistic risk assessments.   Ms
Hammerscrom concluded in a memorandum dated July 8, 1994,  that
the ICF Kaiser's stocastic risk assessment was:

     about as bad as such assessments can be.   Confusing,  lack of
     detail,  lack of focus,  insupportable assumptions, next to
     impossible to review.

Ms Hamtr.erstrom made the following comments:

     But many of the input distributions are determined by
     "subjective judgement",  and it is debatable whether these
     distributions encompass the full range of variability....
     In addition,  the distributions assigned to other variables
     are often unsupported by the available data.   Dose
     distributions differing by orders of magnitude can be
     obtained by using different assumptions.

     The assessment makes  no attempt to separate reducible
     uncertainty from interindividual variability.

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     There is a suggestion that uncertainty in the toxicity
     factors is incorporated in the assessment but no  indication
     of how this was done.

     There is no way to tell which pathways are likely to
     contribute the most to exposure without doing an  independent
     assessment that would be so complex that it would be
     equivalent to redoing the risk assessment..

     The support for the input distributions is so poor in almost
     every case that the ranking of risk levels reported in the
     assessment is meaningless.

     The exposed population is not clearly defined ....

Ms Hammerstrom's review makes it clear that probabilistic risk
assessments can be very difficult to review, and can be
misleading unless all assumptions used are accurate and clearly
presented.  Probabilities can not be simply assumed but have to
be based on relevant data.  For some parameters this may entail
collection of site specific information.  As Ms Hammerstrom
pointed out:  "a probabilistic assessment is not necessarily more
accurate than a point estimate.   Accuracy depends on the input
data."

Clearly, based on Ms Hammerstrom's comments, the PRPs'  stocastic
risk assessment did not "maximize use of available,  quality-
assured, site specific data",  as stated by the PRPs.    It should
be noted that data such as "amount eaten" (ingestion rates),  and
frequency of exposure are very time consuming to collect and
normally would not be expected to vary from site to site.
Therefore, the approach taken in the RI of using parameters based
on experimental studies,  surveys,  and professional judgement is
the most reasonable approach.

An alternative would be to conduct an extensive biological study
at the Site to evaluate the actual impact of the contamination
from the Site on biota at the Site.  However,  the cost  of  such a
study is unjustified considering the cost of the sediment
excavation, which is the only portion of the remedy that is
primarily for protection of biota from existing contamination
(estimated cost  is $200,000).  An extensive biological study is
unjustifiably expensive'.

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ISSUE 5.

COMMENT 4  (July 15, 1995 letter): The cover recommended  in  the
approved Feasibility Study  (FS) provides the  same degree of
protection and reliability as the U.S. EPA preferred options.

COMMENT 5  (July 15, 1995 letter):  The U.S. EPA unreasonably
assumes that the FML will be poorly constructed and, hence, will
not provide a reliable leakage barrier.  Adding another  layer is
not the appropriate solution for increasing reliability.

COMMENT 6  (July 15, 1995 letter) :  The virtually identical
performance offered by the U.S. EPA preferred cover does  not
justify the large additional cost.

COMMENT 5  (August 24,  1995 letter):  U.S. EPA's Preferred Cover
Adds Cost Without Any Significant Benefit or Increase in
Reliability.

COMMENT 6  (August 24,  1995 letter):  Composite Barrier Liners and
Covers Are Not Required at Mixed-Waste Landfill Superfund Sites.

COMMENT IN SEPTEMBER 1, 1995 MEMORANDUM FROM RICHARD WILLIAMS:
According to Design and Construction of RCRA/CERCLA Final Covers.
EPA 625 4-91-025,  May 1991, polyethylenes are expected to have a
life of about 750 years at temperature of 90 degrees centigrade.

COMMENT IN SEPTEMBER 1, 1995 MEMORANDUM FROM RICHARD WILLIAMS:
According to an article by Dr.  Rolf Koch, Dr.  Erwin Gaube, Dr.
Joachim Hessel,  Christiam Gondro Ph.D, and Dr. Heiz Heil  in Mull
and Abfall (Refuse and Waste),  August 1988,  Heft 8 (Volume  8),
ISSN 0027-2957,  pages 348-361:   The authors conclude that the
working life of this material [HDPE pipe] could be expected to be
considerably greater than 100 years.

COMMENT IN SEPTEMBER 1, 1995. MEMORANDUM FROM RICHARD WILLIAMS:
According to "Remaining Technical Barriers to Obtaining General
Acceptance of Geosynthetics" by Robert M. Koerner,  Y. Hsuan, and
Arther E.  Lord,  Jr. of the Geosynthetic Research Institute,
Drexel University in Geotextiles and Geomembranes 12 1993),  pp.
1-52,  the projected life of HDPE is in the range of 200 to 750
years.

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                                10

U.S. EPA RESPONSE:

U.S. EPA included the composite flexible membrane  liner  (FML)/
geosynthetic clay  (GCL, cover Option 4A from  the FS)  or  compacted
clay (CC, cover Option 4B) barrier layer in the Proposed Plan
because composite barrier layers  have the potential  to add
considerably to the long-term effectiveness of the remedy in
reducing infiltration of precipitation into the landfill compared
to a site cover with only an FML  barrier layer  (cover Option  4).
These options have been determined to be equivalent  to or more
stringent than the performance of 3 feet of compacted soil, with
a hydraulic conductivity of 10"7 cm/sec.  We note that the ARAR
for the landfill cap has been determined to be 35  IAC Part
811.314.  The basis for this determination is discussed  below
after the technical merits of the questions are addressed.  35
IAC Part 811.314 provides some flexibilty in  designing the cover
requirements, so long as they are equivalent  to or exceed the
perforamnce of 3 feet of compacted soil with  a hydraulic
conductivity of 10~7 cm/sec.

As stated by the Yeoman Creek Steering Committee in  Comment 4,
"any reduction of infiltration reduces leachate production and
potential leachate seepage and serves to provide an  additional
margin of safety in protecting groundwater quality."  Based on
the RI,  the reduction of leachate will also provide  further
protection to the surface waters in Yeoman Creek and  the  wetland
south and east of the Site.

A site  cover with only an FML barrier layer (Option  4),   as
proposed by the PRPs,  can be and often is very effective  in
reducing infiltration.   As stated in the U.S.  EPA  approved FS,
modeling indicates that a cover using only an FML  for the barrier
layer could be very effective in reducing infiltration through
the landfill due to precipitation as long as the FML overall
quality is good.   For example,  if the leakage fraction is 10"5 l,
the HELP modeling included in the Feasibility Study  (FS)  predicts
a 99.4% reduction, in infiltration compared to current conditions.
     1   According  to  Design  and  Construction of RCRA/CERCLA Final
Covers.  EPA/625/4-91/025,  May 1991,  a leakage fraction of lO'5
represents a good or excellent quality FML  (see Table 2-4 and
Figure 9-8).

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                                11

This corresponds to a reduction in total infiltration from
1,800,000 cubic feet to 11,500 cubic feet per year over the
portion of the landfill east of Yeoman Creek.  Some factors argue
for assuming a low leakage fraction, such as the shallow depth of
the landfill, which would limit the amount of settlement due to
decomposition of the wastes.  In addition, through strict quality
control measures,  a good quality FML cap should be constructable
at this Site.  Construction quality assurance measures that will
have to be taken during construction of the Site cover include
those listed in Comment 5.

U.S. EPA agrees with the Yeoman Creek Steering Committee that
FMLs should remain effective for a very long time in site cover
applications.  If this were not so,  FMLs would not be prescribed
for hazardous waste landfill lining and capping applications.
However,  FMLs have only been used for the last 20 years,  so their
long term effectiveness is not well documented.

The documents providing the estimates of the long term
effectiveness of FMLs submitted by the Yeoman Creek Landfill
Steering Committee indicate that there is a large amount of
uncertainty in these estimates.   Indeed the estimates identified
in the documents were performed for applications other than site
covers,  were conducted on materials other than that proposed for
the FML (40 mil very-low density polyethylene),  and did not take
the synergistic effect of stress on the FML into account in the
estimate.   Uncertainties include:

     swelling from exposure to liquid may cause  secondary actions
     that  could lead to other synergistic effects (Design and
     Construction of RCRA/CERCLA Final Covers.  EPA 625 4-91/025,
     May 1991,  p.  36)

     because the temperatures used  in the example [which resulted
     in an estimated lifetime of 752 years for polyethylene
     shielding of  electric cables]  are quite high and quite
     limited (ie.  they are bunched  together),  extrapolation down
     to the site-specific temperature mentioned  may be invalid.
     One  does not  know which,  if any,  of the geomembrane
     properties will be amenable to the Arrhenius approach,  but
     the  various possibilities should be investigated on a
     project-specific basis and as  a general research area.
     (Design and Construction of RCRA/CERCLA Final  Covers,  p.  39)

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                                12

     field feedback is necessary  to establish better  insight  into
     degradation and aging issues involving polymeric geomembrane
     and other related geosynthetic materials.  (Design and
     Construction of RCRA/CERCLA  Final Covers,  p.  40)

     "Regarding synergism of the  different phenomena  [stress,
     temperature, oxidation], the situation is  just beginning to
     be explored."  "One simply does not know what the effect of
     various types, and levels, of stress will  be  on geosynthetic
     degradations.'''  (Koerner, Robert M, Hsuan, Y., and Lord,
     Arthur E. Jr.  "Remaining Technical Barriers  to Obtaining
     General Acceptance of Geosynthetics".   Geotextiles and
     Geomembranes.  12 (1993) 1-52.  Pages 32,  45  )

In spite of construction quality  assurance measures, leaks in
FMLs always occur.  In addition,  as indicated in the documents
submitted by the Yeoman Creek Steering Committee,  leaks can
develop in the FML over time due  to settling and long term
degradation.  It is uncertain how long it would take for long
term degradation to be significant, but some estimates have been
in the vicinity of 200 years.  Any leaks can substantially
increase the quantity of infiltration through an FML if it is
underlain by a highly permeable material.

This is demonstrated in Table 2-4 of Design and Construction of
RCRA/CERCLA Final Covers.  U.S. EPA, May 1991.   As can be seen,
the flow rate through holes in FMLs can increase from 330
gal/acre/day for excellent FMLs to 10,000 gal/acre/day for poor
quality FMLs.  This is also demonstrated using site specific HELP
model assumptions in Table 1,  which predicts that infiltration
would increase from 12,000 cubic  feet per year for a
good/excellent quality FML to 276,000 cubic feet per year for a
poor quality FML.  Table 1 is shown on. the  following page.

It should be noted that there is little possibility of addressing
FML leaks through increased maintenance once the soil cover has
been installed over it,  since leaks likely would not be detected.

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                                13
                             TABLE  1
                COMPARISON OF  INFILTRATION  RATES
          FOR FML AND COMPOSITE FML/CLAY  BARRIER  LAYERS
        FOR GOOD AND  POOR QUALITY FMLS  USING HELP MODEL2
TYPE OF
BARRIER
FML
FML/GCL
FML./2-feet
compacted clay
@ HC=10'7cm/sec
FML/2-feet
compacted clay
@ HC=1"6 cm/sec
INFILTRATION ASSUMING
1CT5 LEAKAGE FRACTION3
% REDUCTION4! CUBIC FT

99.4% 12,000
100.0% 0
100.0% 2
100.0% 14
INFILTRATION ASSUMING
10-3 LEAKAGE FRACTION5
% REDUCTION CUBIC FT

84.9% 276,000
100.0% 15
100.0% 141
99.9% 1,374
     2   Help Model  Assumptions are shown in Appendix B, December
1994 Feasibility Study for the 10"5 leakage  fraction  runs.   The
10"3 leakage  fraction used the  same assumptions  as  the  corres-
ponding .Appendix B run, except for changing the leakage fraction.

        According to  Table  2-4 of Design and Construction of
RCRA/CSRCLA Final Covers. U.S. EPA, May 1991, good to  excellent
quality FML  (or geomembranes) can be characterized by  having one
1 cm2 to 0.1 cm2 hole per acre.   According to  Figure  9-8 of  the
same reference, this corresponds to a leakage fraction in the
vicinity of 10~5.

     '•   Cubic feet  of infiltration using new cap divided by the
cubic feet of infiltration under existing conditions times  100.
Cubic feet of infiltration was estimated using the HELP model.

     -   According to  Table  2-4 of Design and Construction of
RCRA/CSRCLA Final Covers. U.S. EPA, May 1991, poor quality  FMLs
(or geomembranes) can be characterized by having 30  0.1 cm2 holes
per acre.  According to Figure 9-8 of the same reference, this
corresponds to a leakage fraction in the vicinity of 10~3,
assuming a 0.33 foot head.

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                                14

However, if the FML is underlain  by a clay layer,  it  is  likely
that infiltration will be very low even if leaks occur in  the
FML, whether it is due to installation, landfill settling,  or
degradation.  Since it is desired that this remedy be permanent,
it  is desirable for the site cover to remain effective even if
FML degradation starts after 200  years.  The GCL or CC below the
FML complements the FML's capability by essentially plugging
leaks in the FML with a low permeability layer of  clay.  The
potential effectiveness of the composite FML/GCL and FML/CC is
demonstrated in Figure 2-4 from Design and Construction  of
RCRA/CERCLA Final Covers, U.S. EPA, May 1991.  For site  specific
application, it is also demonstrated using the HELP model  in
Table 1, above.

Under these circumstances the Agency's position is that  a
composite barrier layer is worth  the 12-19% increase in  cost
compared to the cost of the site  cover with an FML barrier  layer
(7-11% increase in the cost of the total remedy).  In order  to
obtain the added long term protectiveness of a site cover having
a composite barrier layer at a reduced cost,  U.S.  EPA is allowing
a number of compromises of the normal hazardous waste capping
requirements.   This includes allowing a 2% slope instead of  a 3%
slope in order to reduce the quantity of soil that is needed for
grading, allowing use of  a GCL instead of two feet of CC, allow-
ing use of the existing cover as part of a two foot CC layer, and
allowing the CC 'to have a hydraulic conductivity of as high as
10"° cm/sec rather than the usual  requirement of 10~7 cm/sec.

Footnote 7 advocates use  of a GCL rather than a CC layer for the
composite barrier layer because of short-term impacts of
construction of the 2-foot CC layer.   Use of the GCL  (instead of
CC)  along with an FML in the composite barrier layer is
acceptable to U.S.  EPA.   However,  regarding the concern about
excavation of soils and wastes along the edges of the landfill
for construction of the CC layer,  it should be noted that if
testing indicates that the existing site cover has adequate
properties along the edges,  excavation will not be necessary.  It
is also possible that the cap design can be adjusted to avoid
excavation in the areas where the existing cover needs to be
replaced.  Furthermore,  while excavation of large quantities of
wastes is considered hazardous,  excavation of small quantities is
not expected to present a significant hazard or odor problem
since the excavated material can be quickly covered, and other

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                                15

dust and vapor control measures can be taken including temporary
containment structures, chemical  supressants, temporary covers,
water sprays, and scheduling excavations during cooler and wetter
seasons.

If construction of an Option 4A Site cover is shown to present a
significant hazard that can not be controlled, U.S. EPA will not
allow construction of the Option  4A site cover.  Investigation of
this issue can be addressed during the remedial design phase.

Regarding the increased truck traffic concern in Footnote 7 due
to construction of the 2-foot CC  layer,  it should be noted that
increased truck traffic for transportation of soil and other
materials onto the Site is entailed for construction of either
Option 4, 4A or 4B site covers.  Measures can be taken to reduce
the nuisance of the increased truck traffic by regulating the
time of delivery and the delivery route.   The Yeoman Creek
Steering Committee contends that the CC site cover (Option 4B)
would entail more truck traffic than the Options 4 and 4A site
covers because clay is bulkier than other soils that the clay
would replace in the grading layer.  Although this may be true,
the impact of this incremental increase in truck traffic would be
minor.

An effective Site cover over the Yeoman Creek Landfill Site is
very important.   The Federal government and the State of Illinois
have recognized that even normal household wastes can contain
hazardous substances.   For this reason,  requirements for
landfills accepting even normal household wastes have become much
more stringent within the past few years.   The State of Illinois
now requires that landfills accepting household wastes have a
bottom liner consisting of either 5 feet  of low permeability
compacted earth or a composite barrier layer consisting of a 60
mil FML and a three foot compacted clay layer,  and a low
permeability final cover consisting of 3  feet of low permeability
compacted earth or an FML of equal performance.   The bottom liner
must be overlain by an effective leachate collection system.   The
Yeoman Creek Steering Committee is correct in stating that it is
cost prohibitive to "transform [old municipal landfills]  into a
state-of-the art RCRA hazardous waste landfills."  This is true
also for transforming old municipal landfills into landfills that
meet the new requirements for landfills  accepting only household
wastes.   It would be too expensive to excavate the entire

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                                16

landfill and place it into a landfill having  a bottom  liner  and
leachate collection system.  Therefore, U.S.  EPA  is proposing  to
only install an effective site cover over  the Site.  In  other
words, U.S. EPA is depending on only the Site cover to provide
all of the protection, which under current  regulations would be
provided by a combination of a bottom liner,  leachate  collection
system, and final site cover.  This is true even  though  U.S. EPA
has information indicating that some of the wastes disposed  of in
the Yeoman Creek Landfill Site would not be allowed in municipal
waste landfills under current waste disposal  regulations.  This
includes oily wastes likely containing PCBs,  used laboratory
chemicals, waste solvents, and waste paint.   Some of these wastes
.may have been listed hazardous wastes pursuant to RCRA.

Beyond the technical benefits of a composite  landfill  cover, the
commentors' proposal to utilize a site cover  with only an FML
barrier layer, as proposed by the PRPs, does  not  comply  with the
site cover ARAR.  U.S. EPA has determined  that 35 IAC  Part 811 is
the ARAR for the Yeoman Creek Landfill Site cover.  35 IAC Part
811 requires a site cover of at least 3 feet  of compacted soil
with a hydraulic conductivity of 10"7 cm/sec or less, or  an
alternative which has equivalent or greater performance.  The
performance of an FML barrier,  alone,  is not  expected  to meet
this performance criteria.

ARARs are defined as Applicable or Relevant and Appropriate
Requirements.   35 IAC Part 807 appears to be  directly  applicable
to the Yeoman Creek Landfill due to the date  closure was
initiated and waste was last accepted,  prior  to September 18,
1992.   35 IAC Part 811 standards are not applicable for  the  same
reason.  However,  35 IAC Part 811 standards are relevant and
appropriate for any municipal landfill where  revised
environmental control systems need to be employed.

The Yeoman Creek Landfill was closed and cared for in  substantial
compliance with the requirements of 35 IAC Part 807.   Despite
this,  the Landfill has made the National Priorities List, has had
releases of hazardous contaminants from the Landfill and has had
infiltration of water identified as part of the problem.   In
light of the historically demonstrated inadequecy of 35 IAC Part
807 for this Site,  to specify 35 IAC Part 807 as  setting the
standards for remedial actitivies at the Yeoman Creek Landfill
would not be protective of human health and the environment.

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                                17

Therefore it seems relevant and appropriate to consider the
requirements of 35 IAC Part 811 for effective landfill standards.
The cover requirements of 35 IAC Parts 807 and 811 are not
mutually exclusive; Subpart 811.314 will satisfy Subpart 807
requirements.  35 IAC Part 811 was developed through an
exhaustive process for applications such as the Yeoman Creek
Landfill situation, and are specifically designed to overcome the
shortcomings of 35 IAC Part 807.  It seems particularly
appropriate that a site with identified problems should follow
the latest standards,  such as cap design, to limit infiltration.
It is further supported where the facility does not have any of
the other control features such as a constructed bottom liner and
leachate collection blanket that are now considered a standard
necessity in landfill construction.
ISSUE 6.

COMMENT 7 (July 15, 1995 letter):   The leachate collection system
required in the Proposed Plan is not necessary since the new
landfill cover will virtually eliminate leachate impacts on
Yeoman Creek.

COMMENT 8 (July 15, 1995 letter):   The leachate collection system
is unnecessary because groundwater recharge to Yeoman Creek is
not a significant factor at this Site.

COMMENT 9 (July 15, 1995 letter):   The leachate collection
trenches are not cost effective since they only collect a nominal
volume of leachate.

COMMENT 11 (July 15,  1995 letter):   The proposed leachate
collection trenches have potentially adverse environmental
impacts at this -Site.

COMMENT 7 (August 24, 1995 letter):   The Leachate Collection
System Proposed by U.S. EPA Is Neither Reasonable nor Cost-
Effective for this Site.

U.S. EPA'S RESPONSE:

Current documented conditions at the Yeoman Creek Landfill
portion of the Site demonstrate that leachate is unacceptable.

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                                18

However, some conditions argue against the need  for measures  to
further  isolate Yeoman Creek  from the leachate beyond  the
protection provided by the new Site cover.  The  new Composite
Barrier  Site cover will cover all of the wastes  and extend  into
the ground water.  This design will eliminate surficial  leachate
seeps to a high degree of confidence in long-term effectiveness;
so the only mechanism for leachate recharge of the Creek
following cover installation would be through migration  through
the subsurface.  It also may reduce the rise in  the water table
within the landfill during flooding by increasing the  flow  path.
This may reduce backflow of this ground water back into  the Creek
when the water level in the Creek drops.  A low  permeability
cover will nearly eliminate leachate generation  due to
precipitation, which will result in a gradual decrease in the
leachate mound in the landfill, and therefore, a gradual decrease
in the driving force for leachate recharge to the Creek.

Even after the leachate mound is dissipated,  leachate can be
generated by movement of ground water through the portion of
landfilled waste that will remain below the water table.
However, shallow ground water recharge to the Creek is apparently
limited since the base flow of the Creek is zero during parts of
the year.

Water level measurements also indicate that discharge of ground
water to the Creek occurs only locally.   Furthermore,  the ground
water data indicates that there is significant natural
attenuation between the leachate and ground water,  which may also
apply to the leachate recharge of the Creek.   Finally,  it can be
argued that any problems caused by migration of contaminants
through the ground water into Yeoman Creek can be addressed by
monitoring and implementation of a remedial action,  if a problem
is detected.

On the other hand,  further isolation of  the Creek using a
leachate collection system or an artificial channel along the
Yeoman Creek Landfill portion of the Site would provide
significant additional insurance that leachate from the landfill
would not have a continuing effect on the Creek.   The primary
concern is that landfilled wastes are within a few feet of the
Creek along much of the Yeoman Creek Landfill portion.   Some of
this landfilled waste may contain high concentrations of
hazardous substances.   Even though the flow rate of leachate into

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                                19

Yeoman Creek may be small, if the leachate contains high
concentrations of hazardous substances, it could recontaminate
the sediments and result in a significant detrimental effect on
the ecology.  Measurement from leachate monitoring wells
indicates that the leachate exceeds industrial pretreatment
standards for chemical oxygen demand, ammonia, cyanide, iron,
lead and zinc.  A number of chemicals detected in leachate may
have an adverse effect on ecological receptors based on the
ecological risk assessment in the RI, including PCBs, lead, zinc,
acetone, and cyanide.  The attenuation mechanisms that are
protecting the ground water may not be effective over the few
feet between the landfilled waste and Yeoman Creek.  Although the
leachate is too contaminated for discharge without treatment into
a sewer, the Yeoman Creek Steering Committee indicates no concern
about its release without treatment into Yeoman Creek.

The leachate collection system will provide Yeoman Creek with
protection from impacts of landfill leachate during the
dissipation of the leachate mound.  In Comment 9,  the Yeoman
Creek Steering Committee states that they estimate that the flow
into the leachate collection system will be 500 gallons per day.
Although Comment 8 states that the base flow in Yeoman Creek is
negligible,  in the FS,  Colder Associates,  Inc. estimated that the
maximum ground water flow through the west side of the landfill
would be 5 gpm,  which corresponds to approximately 350,000 cubic
feet per year and 16% of the estimated flow through the landfill
due to infiltration of precipitation under existing conditions.
Since 30-40% of the landfill wastes will remain below the water
table even after the leachate mound in the landfill dissipates,
the ground water flow through the west side of the landfill will
generate leachate,  which would eventually recharge the lower
aquifer and possibly Yeoman Creek.  Although the Yeoman Creek
Steering Committee has proposed anchoring the FML barrier layer
below the water table,  this would not be expected to
significantly reduce ground water flow into the Creek due to the
ground water flow gradient within the shallow aquifer.

Ground water flow into Yeoman Creek can also be generated as a
result of the rise and fall in the level of Yeoman Creek.   As
stated on page 63 of the RI:

     During the Spring,  the potential for discharge will be
     areatest at the time when the creek level,  which fluctuates

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                                20

     on a short time scale in response to precipitation  and
     freeze-thaw cycles, is lower than the adjacent groundwater
     levels which respond much slower to precipitation events.

Anchoring the FML liner below the water table may  reduce this
effect to some degree by increasing the length of  the flow path
between the waste and Yeoman Creek.  However, because the wastes
are so close to Yeoman Creek, groundwater flow to  and from Yeoman
Creek due to the rise and fall of the water level -in Yeoman Creek
could be significant.

Neither the potential impact of ground water flow  through the
west side of the landfill nor the impact of the fluctuating water
tables in response to water levels of Yeoman Creek are taken into
account in the estimated volume included in Comment 9.
Furthermore, there is a high level of uncertainty  in the  volume
estimate in Comment 9 principally because the average hydraulic
conductivity of the waste is unknown.  Preferential pathways
could exist within the waste that would result in  a much  higher
hydraulic conductivity than 10"4 cm/sec.  A higher  flow rate
would result in higher operation and maintenance costs until the
leachate mound dissipates.

Because of the proximity of the landfill to Yeoman Creek  and the
potential variability in leachate quality and migration,   it
appears that only a costly ground water monitoring program could
detect leachate before it enters Yeoman Creek.   Simply monitoring
the surface water and sediments in the Creek would not be
acceptable because it would be difficult to determine the source
of the contamination,  and because it would not detect
contamination until after the stream is contaminated.

If a contamination problem is detected due to leachate migration,
it would be expected to be considerably more expensive to address
at that time.   The Yeoman Creek Steering Committee estimates that
it would cost an additional $40,000 to $70,000 to  "retrofit" the
site cover after'construction of the leachate collection system.

Although the Yeoman Creek Steering Committee did not provide a
basis for their cost estimate,  it is clear that they did not
include the cost of the repeated sediment excavation to remove
contaminated sediments.   At that time,  the sediments would
probably have to be disposed of off-site,  and,  if contaminated

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                                21

with PCBs at concentrations of 50 ppm or more, would have to be
disposed of in a permitted chemical waste landfill, or by
incineration.

Besides the cost savings, the design of the system can be made
more effective by integrating the leachate collection system into
the site cover design.  For example, recharge of the leachate
collection system by Yeoman Creek can be minimized by extending
the Site cover over the leachate collection system and into the
ground water.6

Finally, addressing the leachate collection system will be
administratively more difficult and may even be administratively
unimplementable in the future, depending on the Agency's funding
and priorities at that time.

The estimated costs for implementing the leachate collection
system including treatment and disposal concurrent with the cap
construction is summarized below:

  CONSTRUCTION COSTS FOR LEACHATE COLLECTION : $   390,000
  ADDITIONAL ANNUAL O&M COSTS                : $   115,000
  ADDITIONAL PRESENT WORTH                   : $ 2,000,000

This adds 9% to the estimated total cost of the alternative
proposed by the PRPs.   The major portion of the present worth
cost is for operation and maintenance.   It is expected that as
the leachate mound dissipates that the  flow into the leachate
collection system will decrease,  and,  as a result,  operation and
maintenance costs will also decrease.

Comment 11 expresses a concern regarding the potential for the
leachate collection system to negatively affect the ecology of
Yeoman Creek and the adjacent wetlands  due to seepage of water
from the stream into the leachate collection system.   In Comment
     6   It  should be  noted  that  the diagram  of  the  leachate
collection system in Figure 3 of the  Yeoman Creek Steering
Committee's July 15,  1995 comment letter,  is defective.   This
diagram indicates that drainage from  the site cover would flow
into the leachate collection system.   As stated previously,  the
site cover could extend over the leachate collection system.

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                                22

11, the PRPs estimate that 270 gpd, which  is  100,000 gallons per
year, could seep from the Yeoman  Creek  into the  leachate
collection system.

Section 4.5 of the FS provides information on the potential for
the remedial action to impact the nearby wetlands.  Although
Section 4.5 of the FS voices no concern about seepage of water
from Yeoman Creek into the leachate collection system  (nor was
any concern about this affect expressed in any portion of the FS,
which was prepared by the Yeoman  Creek  Steering  Committee's
consultant),  it includes an estimate that  the total annual runoff
into the wetlands within the Yeoman Creek  basin  is 486,.000,000
gallons per year.  The estimated  approximately 100,000 gallons
which may be removed by the leachate collection  system is only
0.02% of the total flow entering  the basin that  recharges the
wetlands.  Section 4.5 also includes an estimate of increased
drainage from the landfill due to the improved site cover of
8,200,000 gallons per year (the 8,200,000  gallons is partially
off-set by a decrease in recharge of Yeoman Creek and the wetland
by ground water,  but the FS concludes that most  of the ground
water migrates into the lower aquifer,  not into  Yeoman Creek or
the wetland).   Therefore,  the increased drainage due to the new
site cover will more than make up for the  small  amount of water
removed by the leachate collection system.  As stated in Section
4.5,  the drainage from the site cover can  be  controlled to
eliminate adverse environmental impacts.   It  should also be noted
that flow into the leachate collection  system from Yeoman Creek
will primarily occur during periods of  high flow in Yeoman Creek,
when the surface water flow into the wetlands would already be
high.  Collection of the seepage from Yeoman  Creek during the
high flow periods would have the beneficial effect of preventing
a rise in the landfill water table and  subsequent seepage of the
water back into the Creek after it is contaminated by the wastes
in the landfill.

In conclusion,  for various reasons,  the commenters expressed
confidence that the leachate collection and treatment system is
unnecessary^   While EPA concurs that leachate will be reduced by
the Site cover,  concern remains that leachate will continue to be
generated at  levels containing high concentrations of hazardous
substances, or otherwise adversely affecting the Creek.

This ROD allows the opportunity to demonstrate that the leachate

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                                23

 collection and  treatment  system does  not  need to be implemented.
 This  determination  was  made  based upon  th'e  required monitoring
 program,  the  composite  Site  cover,  and  the  risks and obligation,
 if  determined necessary after  construction  of the Site cover is
 completed,  to construct,  implement  and  operate a leachate
 collection system,  and  to remediate contaminated soils and
 sediments.
 ISSUE  7;

 COMMENT  10  (July  15,  1995  letter):  U.S.  EPA has  failed to
 consider short-term  risks  due  to waste  excavation required in the
 construction of the  leachate collection system.

 U.S. EPA RESPONSE:

 U.S. EPA has considered short-term risks  of  waste excavation  for
 the  leachate collection system.  Uncontrollable risks  can  be
 caused by excavation  of large  quantities  of  wastes (such as
 excavation and removal of  the  contents  of an entire  landfill).
 However,  risks from excavation of relatively small quantities of
 waste  should be controllable.  This is  indicated  in  Section 5.5.5
 of the FS prepared by Colder Associate,  Inc., which  states that:

     However, it  is anticipated that construction of leachate
     collection trenches along Yeoman Creek  would require  a
     limited amount of excavation of waste at the southern end of
     Yeoman Creek Landfill.  Consequently, additional  worker
     health and safety precautions would  be  required.

 Note that the FS, which was prepared by the  PRP contractor,
 states that the quantity of waste excavated  would be limited,  and
 indicates that additional  risks to workers can be addressed by
 taking health and safety precautions.   The FS goes on  to state
.that similar risks are involved in the  excavations for the active
 gas  collection system.  However, the PRPs have made  no comment
 about  risks due to construction of the  active gas collection
 system.

 U.S. EPA also believes that measures can  be  taken so that  the
 excavation for.the leachate collection  system can be completed
 without  discharging leachate to Yeoman  Creek.  Roy F.  Weston,

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                                24

Inc.  (Weston) states in a letter dated August 23, 1995 that
"leachate from the wastes during construction can be contained
from going into Yeoman Creek by sound construction practices."
Weston suggests use of leachate sumps to dewater the excavation.
If a small quantity of leachate does discharge to Yeoman Creek,
it will be less important than eliminating the long term seepage
of leachate into the Creek.

Landfill gases are presently seeping through the site cover and
into the ambient air at the Site although it has been determined
that the health impact of this emission is negligible.  Opening a
trench along Yeoman Creek may temporarily increase landfill gas
emissions somewhat, but because the trench will be open for only
a limited period of time and the trench will not be near
residences,  the health effects would be negligible.

Measures such as construction of temporary containment
structures,  use of chemical suppressants,  use of temporary cover,
use of water sprays, and conducting work during seasons of lower
temperature,  can be used to reduce emissions of dusts and vapors
from excavation.
ISSUE 8t

COMMENT 12 (July 15, 1995 letter):   It is inappropriate to
conduct additional investigation of soil contamination as part of
pre-design activities.

U.S. EPA RESPONSE:

PCBs were detected at 90 mg/kg at  a leachate seep near the
northern boundary of the Site.  There were no samples collected
between the leachate seep and residences and businesses located
north of the Site.  Although run-off from the leachate seep is
apparently not directed towards the residences and businesses, it
is prudent to collect a number of  samples to confirm that surface
soils at the residences and businesses have not been affected.
This will involve no delay in the  project since other tasks such
as sampling of Yeoman Creek sediments can be conducted at the
same time.  In addition, the. cost  of this effort will be minor
compared to the total cost of the  remedy.

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                                25

ISSUE 9;

COMMENT 13  (July 15, 1995 letter):  U.S. EPA's Proposed Plan  is
ambiguous in the discussion of PCB action levels and related  site
remedial activities.

COMMENT 14  (July 15, 1995 letter):  There is no information in
the Feasibility Study which justifies the establishment of PCB
action levels for soils as set forth in footnote 5 of the
Proposed Plan.  In addition, the suggested action levels of 10
ppm in non-residential areas and 1 ppm in residential areas is
inappropriate for this Site.

U.S. EPA RESPONSE:

U.S. EPA has clarified the applicability of the various action
levels for PCBs in the ROD.   The action level of 1 ppm for
residential areas was meant to apply to residential and
commercial areas as defined in 40 CFR 761.123, while the action
level for non-residential areas was meant to apply to undeveloped
property.  It should be noted that these action levels are being
set as a precaution, and it is not expected that any PCBs from
the Site are present on residential properties.

U.S. EPA agrees that the proposed 1 ppm action level for PCBs is
more stringent than is required under U.S.  EPA's,  PCB Spill
Cleanup Policy (40 CFR 76-1.125).   Under the PCB Spill Cleanup
Policy,  1 ppm is the criteria for "clean soil", but the criteria
for requiring excavation and replacement of soil contaminated by
PCBs is 10 ppm (761.125 (c) .(4) (v) ).  1 ppm of PCBs is also
identified as a "starting point action level" in "Guidance on
Remedial Actions for Superfund Sites with PCB Contamination",
OSWER Dir. 9355.4-01,  p.  26.  According to this guidance
document, a 1 ppm PCB concentration corresponds to a 10"5
lifetime incremental cancer risk level,  using standard U.S. EPA
exposure assumptions,  while a 10  ppm concentration corresponds to
a 1C"" risk.

Since the soil action levels for protection of human health are
higher than the sediment action levels for protection of
ecological receptors,  U.S.  EPA agrees that it is unnecessary to
set separate action levels for non-residential soils,  residential
soils,  and sediments.   Inasmuch as contamination in non-resident

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                                26

and residential area soils also may impact ecological  receptors
such as red-winged black birds, the action level  for non-
residential areas and residential soils, is changed to the  same
action levels used for sediments  (Arochlor-1242 =6.8  mg/kg,
Arochlor-1248 = 3.4 mg/kg, and Arochlor-1254  - 0.34 mg/kg).
Therefore, any soil exceeding this action level  (other than
extensive wetland areas) must be excavated to a depth  of 10
inches and replaced with clean soil (containing less than 1 ppm
of PCBs).   This should provide protection to human health to more
than the 10'5 risk level, since the portion of any property
having a concentration between 1 ppm and 3.4 ppm, if any, will be
very limited.

PCBs of 50 mg/kg is an action level that triggers disposal
regulations under the Toxic Substances Control Act (TSCA) for
excavated sediments,  soils, and wastes.  If sediments,  soils or
wastes are excavated and contain PCBs concentrations equal  to or
exceeding 50 mg/kg,  then TSCA regulations become  applicable and
require disposal of these contaminated sediments, soils or  wastes
in a Chemical Waste Landfill or by incineration,   unless a waiver
is approved.  The relevant chemical waste landfill requirements
have been waived.  See response to Issue 13.
ISSUE 10.

COMMENT 15 (July 15, 1995 letter):  U.S. EPA's proposed sediment
action levels are inappropriately based on unrealistic hypo-
thetical risks to red-winged black birds and non-existent mink.

U.S. EPA RESPONSE:

It should be noted that the proposed sediment action levels have
been available to the PRPs since the fall of 1994, but this is
the first comment from them specifically criticizing the
procedures for deriving these action levels.

The sediment action levels were -derived using the following
procedures:

 1.  Reference doses were derived for the chemicals of concern
     for mink and red-winged black birds.   Reference doses were
     set- at  exposure rates that are reasonably expected to result

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                                27

     in no adverse effects on the animal based on scientific
     toxicity studies and application of protection factors.

 2.  Exposure rates to mink and red-winged black birds were
     estimated based on feeding rates, contaminant
     concentrations, and other considerations.

 3.  Plots -were prepared of total hazard index to mink and red-
     winged black birds versus assumed sediment concentrations
     (see letter from ICF Kaiser to Richard Boice, U.S. EPA dated
     August 15,  1995)  for each chemical of concern.  The hazard
     index is the ratio of the estimated exposure rate divided by
     the reference dose.  If a hazard index exceeds unity for a
     chemical, that chemical should be evaluated to determine
     whether it may be causing an adverse impact on wildlife in
     the area.  For both mink and red-winged black birds, it was
     assumed that 100% of the diet came from the area near the
     Site.  For calculation of the hazard index for the plots,  it
     was assumed that 75% of the diet came from the areas
     represented by the soil data.  At a sediment concentration
     of 0, the hazard index is represented by the risks due to
     the soils alone without any contribution from the sediment'
     contamination.   It was assumed that 20% of the diet came
     from areas represented by the sediment data (5% of the
     exposure, previously represented by the seep soil data,  was
     assumed to be eliminated by construction of the site cover
     over the seep soils).   The plots show how the hazard index
     increases in response to assumed increases in concentrations
     of chemicals in the sediments.

 4.  U.S.  EPA staff intended to evaluate whether the sediment
     concentrations of each chemical that resulted in a hazard
     index of unity or above should be used to establish sediment
     cleanup action levels.   However,  it was found that for PCBs,
     lead, PAHs,  and zinc the hazard indexes exceeded unity
     either for mink or red-winged black birds for exposures to
     soils even without consideration of exposures to sediments.

U.S. EPA ecologists had already advised that the concentrations
of contaminants  in the wetland soils were not high enough to
justify excavation,  which would damage the wetlands.   However,
the ecologists felt that excavation of stream sediments would not
cause significant ecological damage.  Under this situation,  U.S.

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                                28

EPA reviewers recommended setting the sediment cleanup action
levels at concentrations based on the higher of either the
upstream sediment concentrations, which were considered
background, or on concentrations being left in the adjacent
wetlands.  For PCBs and lead the recommended cleanup action  level
is based on the 95% confidence level of the average concentration
in the soil samples.  Since only Arochlor-1248 was detected  in
the soil samples, U.S. EPA staff recommended that the action
levels for the other Arochlors be adjusted from the level for
Arochlor-1248 based on their relative toxicities.  For PAHs  and
zinc, the recommended cleanup action level is based on upstream
sediment concentrations since these concentrations were higher
than the upper 95% confidence limit .of the average concentration
in the wetlands.

As described in item 3 above, the exposure rates were multiplied
by 0.75 for the fraction of food from the soils,  and by 0.2  for
the fraction of food from sediments.  Therefore,  adding the
hazard indexes for soils and sediments will not increase the
estimated risk by a factor of three as stated in paragraph 2 of
Comment 15.  The soil concentrations used for the 0.75 fraction
will not be covered by the new site cover as indicated in
paragraph 2 of Comment 15.  As explained in item. 3 above,  the 5%
fraction of food from the seep soil area was assumed to be zero
because the new site cover would cover these areas,  but it will
not cover the wetlands or other soil areas that were sampled.

In contrast to statements in paragraphs 3 and 5 of Comment 15,  it
should be emphasized that the hazard indexes for the different
Arochlors of PCBs and different polyaromatic -hydrocarbons (PAHs)
should be added since all the Arochlors have the same mechanism
of toxicity.   Therefore,  their ecological impact is additive.  As
a result,  it was proper to depict the baseline risk from soils
due to PCBs or PAHs as the sum of the hazard indexes from all of
the types of these compounds.  It is not clear why it is stated
that adding the hazard indexes for Arochlor-1242,  Arochlor-1243
and Arochlor-1254 results in an over-estimation by a factor of
three.   As stated previously the hazard indexes of the three
should be added to obtain the total hazard index for PCBs.   In
addition,  the RI assumed that the hazard indexes for the differ-
ent Arochlors and PAHs should be added.   Similarly,  for PAHs a
single reference dose was used for all of the PAH compounds,  and
the effects of different PAHs were assumed to be additive.

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                                29

The concentrations used in calculation of the hazard  indexes are
actually a conservative estimate of the average concentration
called the upper 95% confidence level  (UCL) of the average.  When
large numbers of samples are collected the 95% UCL of the average
will be reasonably close to the average concentration.  However,
to control costs, usually only a limited number of samples are
collected and analyzed at Superfund Sites.  In these  situations
where only a limited number of sample results are available, the
95% UCL of the average can be larger than the maximum detected
concentration for a parameter.  In this case the maximum detected
concentration was used instead of the 95% UCL of the average.

Other comments that the PRPs make regarding the sediment cleanup
action levels have already been addressed in U.S. EPA's response
to Comments 2 and 3.
ISSUE 11.

COMMENT 16 (July 15, 1995 letter):  U.S. EPA's proposed sediment
remedial action levels are unnecessarily costly to implement as
part of a remedial action.

U.S. EPA RESPONSE:

It is anticipated that the first phase of the sampling will be
conducted before construction is mobilized,  and, as a result, the
laboratory turn-around time will not be disadvantageous.  U.S.
EPA will consider use of field screening techniques to determine
the extent of excavation in the field. " However, these will have
to be followed up by confirmatory laboratory analysis meeting the
necessary quality assurance/quality control criteria.  It should
be noted that the sediment cleanup action levels also apply to
lead, zinc,  and PAHs.   All of these parameters will require a
laboratory analysis in addition to PCBs.
ISSUE 12.

COMMENT 17 (July 15,  1995 letter):   In accordance with the
criteria outlined in the NCP,  U.S.  EPA should carefully weigh the
protection of non-threatened individual animals against the other
environmental and human health risks associated with extensive

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                                30

excavation of soils and sediments.

U.S. EPA RESPONSE:

Mink and breeding red-winged black birds were used as  indicator
species to detect potential adverse affects of contaminants on
wildlife in the area.  Protection for these species should also
protect other wildlife in the area (see response to Issue 3).

U.S. EPA has already stated that its ecologists recommended that
the contaminant levels in the large wetland south and  east of the
site were too low to justify excavation (although limited
excavation was felt to be acceptable).   Prior to excavation of
the sediments, an evaluation of the impact of the proposed •
sediment excavation on the large wetland south and east of the
Site will have to be completed.  U.S.  EPA agrees that  sediment
excavation should be limited or be conducted in accordance with
procedures that will not: have a significant impact on  the large
wetland south and east of the Site.   For example, if the
excavation may result in dewatering part of the wetlands, the
excavated sediments may have to be replaced by clean soil.


ISSUE 13.

COMMENT 18 (July 15, 1995 letter):  The TSCA regulations dealing
with PCB disposal are not applicable to the proposed remedial
action.

U.S. EPA RESPONSE:

Although the TSCA regualtions dealing with disposal of PCBs at or
exceeding 50 ppm have been determined to be applicable or
relevant and appropriate,  the relevant  chemical waste landfill
requirements,  40 C.F.R.  §761.75, have been waived to allow these
PCB contaminated materials to be consolidated under the Site
cover.
ISSUE 14.

COMMENT 19 (July 15, 1995 letter):   Even if U.S. EPA considers
the TSCA PCB disposal regulations relevant and appropriate,

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                                31

consolidation of PCB-containing materials on-site is appropriate,
whether or not the level of PCBs  exceeds 50 ppm.

U.S. EPA RESPONSE:

See Response to Issue 13, Comment 18.


ISSUE 15.

COMMENT 20 (July 15, 1995 letter):  Wetlands mitigation should be
limited to the areas defined in the approved FS Report.

U.S. EPA RESPONSE:

The FS provided an estimate of the quantity of wetlands that will
be eliminated as a result of construction of the new site cover.
In addition to this, based on the FS certain limited wetland
areas may be adversely impacted by sediment excavation, and
limited wetland areas may be adversely impacted by diversion of
storm sewers and other actions taken during the remedial action.

Therefore,  U.S.  EPA will defer the determination of the exact
quantity of wetlands that will be adversely affected until a
later stage in the project when the wetland impacts are better
defined.


ISSUE 16.

COMMENT 21 (July 15, 1995 letter):  The cost estimate presented
in the Proposed Plan appears to be incorrect.

COMMENT 4 (August 24, 1995 letter):   U.S. EPA has failed to
account for contingency and engineering cost of the remedial
action.

COMMENT FROM MAYOR DURKIN DURING PUBLIC MEETING:  "The two pieces
would cost $ 6 million more ..."

U.S. EPA RESPONSE:

The difference between the cost for U.S.  EPA's preferred

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                                32

alternative identified in the Proposed Plan and  that  identified
by the Yeoman Creek Steering Committee is approximately
$1,200,000.  This difference is primarily because U.S. EPA
assumed that the•less expensive Option 4B cover  (FML  underlain by
2-feet of CO  would be implemented rather than the somewhat more
expensive Option 4A cover (FML underlain by a GCL).   However, in
the Proposed Plan, U.S. EPA proposed that either the  Option 4A or
4B site cover would be acceptable.  Following is a list of the
components that account for the larger cost estimate  by the
Yeoman Creek Steering Committee:

  +•  $800,000: the Yeoman Creek Steering Committee assumed use of
     an Option 4A instead of an Option 4B cover.

  +  $134,000:  the Yeoman Creek Steering Committee assumed
     higher compensatory storage/wetland mitigation costs than
     used in the FS.

  +  $167,000:  the Yeoman Creek Steering Committee apparently
     double counted certain active gas control inspection costs,
     which were not included in Alternative 4 of the  FS.

  +  $40,000:   U.S. EPA did not adjust health and safety costs to
     1% of construction capital costs.

If it is assumed that the less expensive FML/CC site  cover is
constructed,  but correcting U.S. E-PA's estimate for the health
and safety costs to 1% of construction costs,  the cost estimate
for the selected remedy would still be $ 25.7 million, which is
$ 3.7 million more than the cost estimate for the remedy
including a site cover with only an FML barrier layer and without
a leachate collection system.
ISSUE 17.

COMMENT 8 (from August 24, 1995 letter):  No ground water
management zone is necessary nor should one be imposed at this
Site.

U.S. EPA RESPONSE:

U.S. EPA agrees that the State of Illinois Ground Water

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                                33

Management Zone regulations should not be considered applicable
or relevant and appropriate to this action.  However, the ROD has
addressed this concern and has prescribed only adequate ground
water monitoring.
II.  RESPONSES TO COMMENTS FROM EVOY. KAMSCHLUTE. JACOB & COMPANY
(EVOY). AND FROM HARRY HOOKER
ISSUE 1;  U.S. EPA MUST EITHER REMOVE THE LANDFILL WASTE FROM
EVOY'S PROPERTY OR DETERMINE AND PUBLICLY STATE THAT SUCH
REMEDIATION IS UNNECESSARY.  (July 14, 1995 letter from Evoy)

U.S. EPA RESPONSE:

U.S. EPA has reviewed this matter and concluded that landfilled
residential wastes are present on the Evoy property and are
contiguous to the landfilled residential wastes on the Waukegan
School District property.  As a result,  that portion of the Evoy
property where the landfilled residential wastes are located has
been properly identified as part of the Yeoman Creek Landfill
Site.  However, U.S.  EPA is willing to be flexible in
implementing the remedy to allow excavation and consolidation of
wastes from the fringes of the Landfill, such as this property,
and alternative site cover designs.   This is expanded below.

It should be noted that the action level for PCBs in soils
applies to surface soils where it may be contacted by people and
not to the landfilled waste.

At the Yeoman Creek Landfill Site,  it is known that residential
wastes were co-disposed with industrial wastes.  The best
information we have is that the industrial wastes were simply
buried along with the residential wastes wherever the filling was
occurring at the time of disposal.   Therefore,  it is believed
that" industrial wastes are spread throughout the landfill.   A
number of hazardous substances were detected in leachate from the
landfill, including:   chloroethane;  methylene chloride;  acetone;
1,2-dichlorcethylene; 2-butanone; trichloroethylene; benzene;  4-
methyl-2-pencanone; tetrachloroethylene; toluene; chlorobenzene;
ethylbenzene;  xylene; phenol; 1,4-dichlorobenzene;  1,2-
dichlorobenzene;  2-methylphenol;  4-methylphenol; isophorone; 2,4-

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                                34

 dimethylphenol;  benzole acid;  naphthalene;  4-chloro-3-
 methylphenol;  2-methylnapthalene;  diethylphthalate;  n-
 nitrosodiphenylainine;  butylbenzylphthalate;  bis(2-
 ethylhexyl)phthalate;  polychlorinated biphenyls;  and lead.   The
 leachate testing is the best indication we  have of the contents
 of  the  landfill.   We do not know  the distribution of these
 chemicals within the landfill,  but we assume that hazardous
 substances  could be distributed throughout  the landfill.   In
 general,  chemical analyses of  the  wastes themselves  are not very
 useful  since  the composition of wastes can  vary dramatically from
 location to location.   Furthermore,  residential wastes require
 proper  disposal  regardless of  their chemical make-up.

 Figure  8 from the RI,  appears  to  indicate that the following
 borings on  the Evoy property contained landfilled residential
 wastes:  WD-224U,  WD-251B through WD-251G, WD-252C,  andWD-252D.
 The logs for  these borings described the waste as:  metal  pieces,
 paper,  cloth, glass,  wet-black-decomposed paper and  cloth,  pieces
 of  aluminum foil,  paper-black-wet-decomposed,  copper wire,  wire,
 plastic,  plastic bag,  plastic  wrap,  wood, hose,  and  piece of
 concrete.   These descriptions  are  typical of landfilled
 residential wastes.   In addition,  in the judgement of  the
 personnel who observed the cuttings  from the borings (from  Colder
 Associates, Inc,  and Roy F.  Weston,  Inc)  the wastes  were
.landfilled  residential wastes.  Chemical analyses would be  of no
 value in this determination since  there is  no chemical definition
 of  landfilled residential, wastes.   As stated previously,  based on
 available information,  we have  assumed that  hazardous  substances
 could be present  within the landfilled residential wastes.   It
 follows  that  the  landfilled wastes  on the Evoy property should be
 considered  part  of the Yeoman  Creek  Landfill Site, and should be
 addressed in  the  same  manner as the  rest of  the landfill  --  that
 is  by containment under an effective site cover.

 On  properties where  the extent  of  landfilling and the  impact of
 the proposed  site cover is limited,  it may be possible to
 excavate  wastes  from the  property  and consolidate it onto the
 main part cf the  Site,  or to implement an alternative  site  cover
 design  that would better  accommodate use of  the property.
 However,  because  of  the potentially  significant costs  involved,
 the potential health and  safety problems, and the uncertainty
 regarding the results  of  negotiations and litigation that may
 occur among the parties of concern on this matter, the decision

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                                35

regarding whether any excavation  or alternative site cover design
should be conducted will be deferred to a later date.  Therefore,
U.S. EPA has included the following provision in the ROD:

     For the northern portion of  the site in locations where
     wastes were disposed of outside of the boundaries of the
     Waukegan School District property, or where the site cover
     will extend onto otherwise unaffected properties, it will be
     acceptable to U.S. EPA for wastes to be excavated from these
     properties and consolidated  on the Site, or to implement an
     alternative cap design that  will better accommodate use of
     the property.  This is subject to the following:
          determination by U.S. EPA that the alternative site
          cover design will meet  an equal standard of performance
          with respect to reduction in infiltration over the long
          term,  and will not require excessive maintenance.
          if excavation is conducted,  followup sampling will be
          required to assure that excessive levels of hazardous
          substances are not being left behind.
          determination by U.S. EPA that the costs to the federal
          government of implementation of the excavation or
          alternative design will not be excessive; and
          determination by U.S. EPA that the action can be
          conducted in a manner that will be protective of human
          health and the environment.

The actual allocation of"costs for implementation of the remedy
will depend on the results of negotiations or litigation.
ISSUE 2;   U.S. EPA MUST ADDRESS THE EFFECT OF DRAINAGE AND RUN-
OFF ONTO THE SURROUNDING PROPERTIES (July 14, 1995 letter from
Evoy).

"My comment would be that whatever plan is adopted that the
drainage and impact on the drainage and the impact on the
property owners north .... needs to be seriously evaluated."
(Harry Hooker during public meeting)

U.S. EPA RESPONSE:

U.S. EPA agrees that drainage onto surrounding properties is an
important consideration.   It-would be unacceptable for the new

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                                36

site cover to cause flooding or other hazards  to  the  residents  of
the surrounding.properties.  Therefore, U.S. EPA  has  added  the
following performance standard for construction of  the  drainage
system to the ROD:  drainage from the site  cover  onto adjacent
properties and  into storm sewers will be adjusted to  levels that
will result in  no increased potential for flooding  or other
adverse effects.

The drainage from the site cover can be adjusted  to flow  into the
wetland south of the Site, into Yeoman Creek,  into  storm  sewers,
or onto adjacent properties and streets.  The  run-off could be
either totally  diverted from adjacent properties  and  storm
sewers, or adjusted to levels that result in no adverse effects.
Another performance requirement is that the run-off should  not
have an adverse effect on the ecology of the wetland  south  of the
site.  U.S. EPA believes that these performance requirements for
the drainage system can be met.  The details of the drainage
system will be worked out during the design phase.  U.S. EPA
believes that after the preliminary design is  completed, a
meeting with adjacent property owners should be held  to assure
that their concerns are addressed.

Another flooding concern is the impact of the  site  cover in
filling a portion of the floodway and floodplain  in Yeoman Creek.
This concern is preliminarily evaluated in Section  4.4 of the FS.
Although the preliminary evaluation indicates  that  the impact of
the site cover on the floodway and floodplain  of Yeoman Creek
will be minor,  U.S.  EPA's Proposed Plan includes provisions for
creation of compensatory floodway and floodplain storage and
other mitigation measures that may be necessary to assure that
construction of the new site cover will not cause problems due to
loss of floodway and floodplain capacity in Yeoman Creek.
III. RESPONSE TO COMMENT FROM JAMES D. GRIFFITH. DIRECTOR. LAKE
MICHIGAN FEDERATION

"Plan 4B seems to be sound.  I do not believe that five year
reviews are sufficient.  Perhaps initially this should be a
review after the first and third year."

U.S. EPA RESPONSE:

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                                37

Mr. Griffith stated that the actions in U.S.  EPA's  Proposed  Plan
seem sound.  Regarding the sufficiency of the  five  year  reviews,
since annual monitoring of the ground water,  surface water,
sediments, and wetlands will be required, U.S. EPA  will
essentially be monitoring the performance of  the  remedy  every
year.
IV.  RESPONSE TO COMMENTS FROM THE LAKE COUNTY STORM WATER
MANAGEMENT COMMISSION

ISSUE 1;  It is unclear from the information I have available who
the permit applicant will be.  If it is the City of Waukegan or
if the city is a co-applicant a Watershed Development Permit
(WDP) will be required from the Lake County Stormwater Management
Commission.  There is no mention of a WDP in the USEPA
information.  I would encourage a meeting with the design
engineers as soon as possible.  The issue of cost may be moot if
one option or another is not permissible under the WDO.

U.S. EPA RESPONSE:

It is very important that the remedial actions at the site do not
cause or increase flooding problems.   Therefore,  U.S. EPA agrees
that a meeting is needed between the design engineer, and the
Lake County Storm Water Management Commission as well as the
Illinois Department of Transportation (IDOT)  to work out methods
to implement the remedial actions in a manner that will not
significantly increase flooding potential,  and that will comply
with the substantive requirements of applicable or relevant and
appropriate State and Federal laws (ARARs).   However, it should
be emphasized that,  under federal law,  federal,  state or local
permits are not required for on-site actions conducted under the
Comprehensive Environmental Response Compensation and Liability
Act. (CERCLA)  (see 40 CFR 300.400(e),  and Sections 104,  106,  120,
121,  and 122 of CERCLA).   Therefore,  only the substantive
requirements of ARARs have to be complied with.

It should be noted that to the extent that the substantive
requirements of the Lake County Storm Water Management Commission
Ordinance exceeds the requirements of IDOT floodway and
floodplain regulations,  the provisions of the Ordinance will not
be considered mandatory because chey are not State requirements.

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                                38

This  includes the provision  for creating  compensatory  storage  for
loss  of floodplain storage.  However,  the- need  for  this
provision, as well as other  provisions of  the Ordinance will be
seriously considered in the  design of  the  remedial  action,  in
order to avoid significantly increasing the potential  for  damage
due to flooding.

It is also very important that remedial actions at  the Site
comply with applicable or relevant and appropriate  federal  and
state laws.  U.S. EPA and IEPA have determined  that the Illinois
Department of Transporation  (IDOT) floodway and floodplain
regulations are applicable to this action; however, to the  extent
that  the Lake County Storm Water Management Commission ordinance
exceeds the IDOT requirements, it is not considered applicable.
V.  RESPONSE TO COMMENTS FROM ILLINOIS CITIZEN ACTION   "In
reviewing the EPA's proposed plan for the cleanup we see one
glaring omission: protection of the groundwater currently being
contaminated with the leachate from the landfill.  The proposal
acknowledges that groundwater is being contaminated, and that
contamination presents a risk, but the recommended solution does
not address this issue, focusing only on the direct contamination
of Yeoman Creek.  Our concern is twofold: the highly dangerous
nature of the contaminants  (PCBs)  leaching into the groundwater,
and the ultimate impossibility of reclaiming the groundwater once
it is contaminated.  The US Department of Health and Human
Services report TP-92/16 Public Health Statement 1.7 states 'for
the maximum protection of human health the possible cancer
effects of drinking water or eating fish or shellfish that
contain PCBs in lakes and streams be not more than 0.001 parts of
PCBs per billion parts of water (0.001 ppb).'   The Superfund
Study by the Congress1 office of Technology Assessment (OTA)
reveals that once the groundwater is contaminated it cannot be
cleaned up.  On a normal human timescale, groundwater
contamination must be considered permanent.  The pump and treat
system of cleaning contaminated ground water will go on forever.
Illinois Citizen Action respectfully requests that you recommend
Alternative 5 in the cleanup of the Yeoman Creek Landfill.   It is
the only alternative listed that prevents further contamination
of the groundwater.

We are sensitive to the economic burden this alternative places

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                                39

on Waukegan, the Superfund and the responsible parties.  We
cannot in good conscience, however, permit a hazardous situation
to continue.  The protection of public health must be addressed
and federal money may well have to be taken from projects where
health is not an issue.  This site has already been the focus of
corrective actions in the past; it is unlikely that the ultimate
solutions will become cheaper by being postponed.  And in the
meantime, the pollution of the ground water continues."

U.S. EPA RESPONSE:

U.S. EPA agrees that it would be desirable to completely contain
the contaminated ground water as proposed in Alternative 5, which
includes an effective site cover,  an active landfill gas
ventilation system, deep slurry walls around the entire landfill,
and ground water/leachate pumping within the slurry wall to
prevent off-site migration of contaminated ground water.
However,  the cost of this additional protection is estimated to
be high compared to Alternative 4B: $ 16 million in additional
construction costs and $430,000 in additional annual operation
and maintenance costs.   Please note that the extent of ground
water contamination from the Site is limited,  the ground water is
not used for residential or commercial purposes in the vicinity
of the site,  ground water monitoring will be conducted that will
be able to detect off-site migration of contaminants,  and five-
year reviews will be conducted to evaluate whether the selected
remedial action continues to be protective.   If it becomes
apparent that ground water contamination from the Site is a more
serious concern,  an alternative for containment or remediation of
the contaminated ground water can be selected and implemented
before any human exposure to the ground water occurs,  and before
the contaminated ground water reaches Lake Michigan.

It should be noted that part of the reason U.S. EPA selected
implementation of a leachate collection system along the northern
portion of the landfill,  preventing leachate seepage into Yeoman
Creek,  is because of the potential adverse ecological and human
health effects resulting from even very low concentrations of
PCBs in surface waters.   The Ambient Water Quality Criteria
(AWQC)  for Protection of freshwater aquatic  life is 0.014 ug/1,
while the AWQC for protection of human health from cancer at the
10"s risk level due to lifetime exposure to drinking water and

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                                40

ingestion of aquatic organisms  is 0.01 ug/1.7  The maximum
concentration of PCBs in the leachate wells of 190 ug/1  is  far
above these levels, as is the detection limit for the analysis
used in the RI of 0.5 ug/1.  In addition, PCBs were detected as
high as 90 mg/kg in leachate seep soils in the northern  portion
of the landfill.  Although the predominant amount of PCBs
detected in leachate wells is probably associated with solids and
would probably be filtered out  in ground water before reaching
the Creek, even low levels of PCBs and even levels below the
detection limit that reach Yeoman Creek could have an adverse
effect.

On the other hand,  in the southern portion of the landfill  (the
Edwards Field portion),  the highest PCB concentration detected in
leachate was 0.51 ug/1,  and no PCBs were detected in the leachate
seep soils.  This lower PCB concentration, combined with the 30
foot buffer between the landfill and the Creek and the indication
that ground water discharge to the Creek may not be significant,
is why a leachate collection system is not recommended between
the southern portion of the landfill and Yeoman Creek.

Please note that the effects of PCBs on human health are not
magnified when exposure is strictly through drinking water usage
(not including exposure to aquatic organisms exposed to a given
level of PCBs)  as evidenced by the somewhat higher standard level
of 0.5 ug/1,  which is the Maximum Allowable Concentration (MCL)
under the Safe Drinking Water Act.  The MCL for PCBs is equal to
the detection limit for PCBs attained in the RI.   Inasmuch as
PCBs were not detected above the MCL even in monitoring wells
near the Site,  the RI indicates that if any migration of PCBs is
occurring through the ground water from the Site,  it is very
limited.  If migration of PCBs from the Site increases,  it will
be detected during the ground water monitoring.   Since  ground
water is unused in the vicinity of the Site,  because ground water
will be monitored near the Site, because PCBs migrate very slowly
in the ground water,  and because there is an approximately two
mile distance between the Site and Lake Michigan,  there will be
plenty of time to implement a ground water action to contain or
remediate PCB contamination before it reaches Lake Michigan or
     7   U.S.  EPA.   Quality  Criteria  for  Water  1986.   EPA 440/5-
 16-001,  May 1,  1986.

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                                41

any ground water receptor.
VI. RESPONSE TO COMMENTS FROM CITIZENS URGING THAT ACTION BE
TAKEN TO ADDRESS THE CONTAMINATION AT THE YEOMAN CREEK LANDFILL
SITE

     "We urge you to contain landfill wastes --liquid & solid --
& clean up this 'blotch' on the environment once and for all to
prevent any more damage to the ground water & big lake & the
health of the residents of the area plus all the areas where the
gases & water will migrate.

Protect our children, PLEASE resist the 'E-Z way out!1 & do a
thorough workman-like job of containment."

     "I respectfully urge the USEPA to take whatever measures are
necessary to protect the health of local citizens by protection
of the ground water and Lake Michigan from contamination.  Yeoman
Creek contamination puts at risk local wetlands through hazardous
chemicals.  Heavy metals found in ground water results in risk to
us all.  We the citizens of the area look to EPA to protect us."

     "Please stop the contamination of Yeoman Creek and clean up
the entire 'mess'  as soon as possible.  Its a disgrace that it
stayed open all these years endangering all of us especially the
children.  The terrible contents should be carefully removed and
deposited w/ hazardous materials in some remote, safe, protected
area, to eliminate an explosion in this densely populated area."

     "It is important that the EPA continue the action necessary
to protect both the people and the Lake.  The Lake is a beautiful
natural resource."

     "I urge you to do anything possible to expedite cleaning up
the Yeoman Creek Landfill.  As residents (over 20 years)  of this
area, we are concerned with the human health risks,  in addition
to the ecological risks.  The value of our property is also
affected, as home buyers will avoid the landfill's surrounding
area homes.  I respectfully urge the U.S.  EPA to take all
measures necessary to protect the ground water and Lake Michigan
from contamination.  Additionally, the lives of local residents
must be protected."

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                                42

     "I feel that whatever action is decided to be  taken  should
be done as quickly as possible so that the least amount of damage
can be done to our drinking water."

     "I am very concerned with this situation if not taken care
of soon, will lead to addition problems with our leak.  Also more
risk to future generations.  Not knowing how these  situations are
remedied, your options seen feasible."

     "I am now an adult and think it is EPA's responsibility to
clean this mess up, I guess this is our reason for  paying taxes.
I am particularly concerned about the water supply  being
contaminated with toxic heavy metals and just the overall safety
of the site.  Your.urgent attention to this matter  would be
greatly appreciated by all residents in the area and the whole
town."

     "It goes without saying that the EPA must take the steps
necessary to preclude contamination of ground water or Lake
Michigan by leachate of materials in the dump."

     "I respectfully urge the U.S.E.P.A. to do everything
necessary to protect the ground water & Lake Michigan from
contamination.   Please protect the health of local  residents."

     "I urge immediate, thorough action to remedy the hazards
from these two sites.   The remedial action must confine the
hazardous toxic gases to the sites * their controlled release
must be carefully monitored."

     "We are pleased that steps are going to be taken to clean up
this landfill."

     "I respectfully urge the United States EPA to  implement all
cleanup action necessary to preserve the purity of  our
groundwater and Lake Michigan water."

U.S. EPA RESPONSE:

U.S. EPA agrees that an action should be taken to address
contamination at the Site.   U.S.  EPA believes that  this action
should include  construction of an effective site cover,
construction and operation of an active landfill gas ventilation

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                                43

system, construction and operation of a leachate collection
system along Yeoman Creek for the northern portion of the
Landfill, if necessary, and excavation of contaminated sediments
and consolidation on the landfill.  These actions will remove
contaminated sediments from Yeoman Creek, will nearly eliminate
leachate seepage into Yeoman Creek, and will substantially reduce
leachate seepage into the ground water.  Complete containment of
contaminated ground water from the site was not selected because
the degree of ground water contamination is limited, because the
site cover will substantially reduce leachate generation, and
because the cost of ground water containment is very high.
VII. RESPONSE TO COMMENTS FROM CITIZENS SUPPORTING U.S. EPA'S
PROPOSED PLAN;

     "What was done in the past cannot be undone but we must work
together to ensure that the best alternative is taken so we don-t
make another error in judgement.  Doing it the best way we know
how the first time will be less expensive and cause us less grief
in the long run.  I am also concerned about the cost  (since I'm a
Waukegan taxpayer) but I think that we need to follow the EPA's
recommendation as the minimum (alternative 4B with a composite
barrier layer and leachate collection) unless there is data to
conclusively show that the EPA's standards are not realistic and
that their proposal is an overkill.

In my opinion on cases like this where there are many unknowns,
it is better to err on the conservative side rather than do patch
up jobs later.  We need to protect the homes and people who live
around the landfill site or do business around the site (homes,
fast food, etc.).  More importantly, we should not allow the
leachate and whatever is released from the landfill to
contaminate more land, the water supply and other yet to be
discovered things."

  -  "We would like Waukegan to follow the EPA's recommendations
.(Alternative 4B with a composite barrier layer and leachate
collection system).  We believe the EPA has dealt with many
landfills and has the best interests of our environment and
people in mind.

As taxpayers of Waukegan,  we realize that there will be a cost

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                                44

associated with  the  landfill.  However,  if we have  already  spent
'millions of dollars to learn about  the  environment of  the  Yeoman
Creek site1, it  seems like we should ba  able to budget  an
additional 6 million dollars for  the EPA plan.  Doing it the best
way the first time will ultimately be  less expensive in the long
run. "

     "Mayor Durkin's comments at  the meeting are almost
frightening -- he is obviously not willing to spend what it take
to clean up a mess that, contrary to his comments is harmful to
the citizens."

U.S. EPA RESPONSE:

U.S. EPA agrees  that the added long  term protectiveness of  a site
cover with a composite barrier layer,  and of the proposed
leachate collection system is worth  the  additional  costs.
VIII. RESPONSE TO COMMENTS FROM CITIZENS OPPOSING PORTIONS OF
U.S. EPA'S PROPOSED PLAN:
ISSUE 1;  "My idea is to do the minimal work at the site and
continue to monitor what is happening.  At the public hearing
Rick Boice stated that there was limited groundwater
contamination, risks were very limited and there is no
significant amount of landfill gas coming from the site.  Again
according to Rick Boice, he can smell no landfill gas at the site
as opposed to the smell at other landfill sties he has visited.
What scares me the most is when the government gets involved
spending millions of dollars, ruining peoples lives, property,
and businesses only to find out their grand ideas didn't quite
work and then we have to spend even more millions to straighten
out the 1st and second mess."

U.S. EPA RESPONSE:

The technologies selected by -U.S.  EPA (namely construction of a
r.ew site cover,  an active landfill gas collection system,  a
leachate collection system,  and sediment excavation and
consolidation under the new site cover)  are standard
technologies.  The risks from implementing these technologies is

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                                45

low and controllable by use of proper construction, and worker
safety procedures.

Because landfilled residential wastes were found on properties
adjacent to the Waukegan School Board property, or in some cases
come close to the boundary of the property, the new site cover
will impact these adjacent properties.  However, U.S. EPA is
willing to work with these property owners to reduce the impact
on their use of the property while still obtaining the objectives
of the remedial action.

During the RI,  landfill gas emissions to the ambient air were
monitored and found to be insignificant.  However, landfill gases
were found to be migrating off Site in the subsurface, and
apparently are entering a building near the Site.  This was
causing a fire, explosion and toxic risk in this building.  In
addition,  there is potential for landfill gas entry into other
buildings near the Site.   The parties conducting the RI have,
with U.S.  EPA oversight,  taken interim measures to address the
these risks by installing a basement ventilation system in one
building and by periodic monitoring in other buildings.  However,
U.S.  EPA does not consider these to be acceptable measures for
the long cerm.   Instead measures should be taken to assure that
the landfill gas does not migrate off-site in the subsurface.
This will be accomplished by construction of a new site cover and
operation of an active landfill gas ventilation system.

No action other than monitoring at the Site and access
restrictions,  is also unacceptable because without improvements
to the sire cover and a leachate collection system, leachate will
continue to be released to Yeoman Creek and the adjacent wetland.
This release is causing an ongoing threat to wildlife in the area
as demons-rated in the ecological risk assessment.  In addition,
ground warer will continue to be contaminated to levels exceeding
drinking water standards  (Maximum Allowable. Concentrations under
the Clean Water Act),  and there will be some risks to .nearby
residents of contact with contaminated sediments.
ISSUE 2;   "I feel that the recommendations of the City are
appropriate at this time.   The City of Waukegan has other
problems beside Yeoman Creek and must use its funds cautiously.
From the information presented at the meeting the risks from the

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                                46

leachate do not appear that great.  The trench around the Creek
may not be necessary at this time."

"I feel that the clean up in Yeoman Creek should not be the plan
proposed by the PEA but the one proposed by the City of Waukegan.
The taxpayers of the City can not afford the plan proposed by the
PEA.  The Waukegan School System does not have funds to pay for
any portion of the clean up."  "Is it fair?  I don't think so.
Public health is an important issue, but the costs of the clean
up should be keep to only what is necessary to insure public
health."

U.S. EPA RESPONSE:

Please refer to U.S. EPA's response to Issues 1, 2, 3,  5, and 6
to the comments from the Yeoman Creek Landfill Steering
Committee.  It should be noted that a number of private companies
are PRPs; so only a fraction of cost of the remedial action will
be born by the City of Waukegan, Waukegan School District #60,
and the Waukegan Park District.
    RESPONSE TO OTHER COMMENTS AND QUESTIONS FROM CITIZENS
ISSUE 1;  Concern was expressed about development by an
organization called "Rebound".   Rebound plans to build a large
facility with a retention pond which would drain to a ditch,
which drains long the south fence of the portion of the Site
north of Greenwood Terrace before entering Yeoman Creek.

U.S. EPA RESPONSE:

Measures will have to be taken to assure that drainage from the
new site cover does not adversely affect drainage from the new
development.   The effect of drainage from the new site cover,
will be evaluated during the remedial design phase,  and may have
to take into account or coordinate with the drainage from the new
development.   U.S. EPA suggests that a meeting be held with
adjacent property owners following completion of the preliminary
design to discuss their concerns.

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                                47

ISSUE 2;  Who is paying for this?  "If the federal government can
pay for the cleanup of Love's Canal, why can't they pay for the
cleanup of Yeoman Creek?"

U.S. EPA RESPONSE:

The RI/FS was paid for by a group of PRPs including:  Browning-
Ferris Industries; Outboard Marine Corporation; The Dexter
Corporation; T.K. City Disposal; the City of Waukegan, Goodyear
Corporation; and the Waukegan School District #60.  In addition,
these parties have reimbursed U.S. EPA's expenses for oversight
of the studies.

U.S. EPA has identified a number of additional PRPs.  Following
issuance of the ROD,  U.S. EPA will attempt to negotiate an
agreement with a group of PRPs to implement the remedy.  U.S. EPA
may issue an order or use litigation to compel an agreement.  If
this is unsuccessful,  U.S. EPA may implement the remedial action
using money from a trust fund, which is supported primarily by
taxes on chemical feed stocks.

U.S. EPA is mandated by Congress to attempt to reach an agreement
under which costs for cleanup of hazardous waste sites are born
by parties that caused the pollution.  This includes owners and
operators of the site,  companies who generated hazardous
substances that were disposed of at the site,  or persons who
arranged for transport of hazardous substances to the site.  The
City of Waukegan owned and operated the site and,  therefore, is
potentially liable for cleanup costs.  However, they are not
solely liable for the costs as implied by a number of statements.
There are a number of private parties who are also liable for the
cleanup.
ISSUE 3;   Has the landfill owner been fined?  Does he own any
other landfills.  If so, where, and what is their status?

U.S. EPA RESPONSE:

The owners of the landfill have been notified by U.S. EPA that
they are  potentially liable for costs for cleaning up the Site.
The owners of the major portions of the landfill during its
period of operation were the City of Waukegan and the Waukegan

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                                48

School District #60.  The City of Waukegan operated a number of
municipal waste landfills within the City of Waukegan, including
the Yorkhouse Municipal Landfill #1, and the Adelphi Municipal
Landfill #2.  All of these municipal landfills have been closed,
and none of the other landfills are Superfund sites.  These
closed landfills are being monitored by the Lake County Health
Department and the Illinois Environmental Protection Agency.  The
City of Waukegan was subject to a legal action by the Illinois
Environmental Protection Agency in the late 1970s and early
1980s.  An agreement was reached under which the City of Waukegan
added additional cover soil to the landfill, constructed a fence
at the landfill, and conducted stream monitoring.
ISSUE 4:  Are there storm sewers emptying into Yeoman Creek?

U.S. EPA RESPONSE:

There is at least one storm sewer that appears to go through the
landfill and into Yeoman Creek.  This storm sewer and any other
storm sewers found to go through the landfill will be rerouted
and plugged.
ISSUE 5;   Will an effective leachate collection system so drain
the wetlands that our water supply will be affect?

U.S. EPA RESPONSE:

The leachate collection system should have no significant impact
on water supplies or on the ecology of the nearby wetland.  Mayor
Durkin and the Yeoman Creek Steering Committee expressed concern
regarding the potential for the leachate collection system to
negatively affect the ecology of Yeoman Creek and the adjacent
wetlands  due to seepage of water from the stream into the
leachate  collection system.  In Comment 11,  the Yeoman Creek
Steering  Committee estimated that 270 gpd, which is 100,000
gallons per year, could seep from the Yeoman Creek into the
leachate  collection system.  Section 4.5 of the FS provides
information on the potential for the remedial action to impact
the nearby wetlands.  Although Section 4.5 of the FS voices no
concern about seepage of water from Yeoman Creek into the
leachate  collection system (nor was any concern about this effect

-------
                                49

expressed in any portion of the FS, which was prepared by the
Yeoman Creek Steering Committee's consultant), it includes an
estimate that the total annual runoff into the wetlands within
the Yeoman Creek basin is 486,000,000 gallons per year.  The
estimated approximately 100,000 gallons which may be removed by
the leachate collection system is only 0.02% of the total flow
entering the basin that recharges the wetlands.  Section 4.5 also
includes an estimate of increased drainage from the landfill due
to the improved site cover, of 8,200,000 gallons per year (the
8,200,000 gallons will be partially off-set by a decrease in
recharge of Yeoman Creek and the wetland by ground water, but the
FS concludes that most of the ground water migrates into the
lower aquifer,  not into Yeoman Creek or the wetland).   Therefore,
the increased drainage due to the new site cover will more than
make up for the small amount of water removed by the leachate
collection system.  As stated in Section 4.5, the drainage from
the site cover can be controlled to eliminate adverse
environmental impacts.  It should also be noted that flow into
the leachate collection system from Yeoman Creek will primarily
occur during periods of high flow in Yeoman Creek,  when the
surface water flow into the wetlands would already be high.
Collection of the seepage from Yeoman Creek during the high flow
periods would have the beneficial effect of preventing a rise in
the landfill water table and subsequent seepage of the water back
into the Creek after it is contaminated by the wastes in the
landfill.
ISSUE 6:   From the amount of pollution present, should the
wetlands be drained to prevent contamination.

U.S. EPA RESPONSE:

Ecologists working for the U.S.  EPA have reviewed the data, and
concluded that the level of contamination in the wetlands south
and east of the Site are not 'high enough to warrant excavation of
the contaminated soils,  or other actions that may damage the
wetland as a habitat.
ISSUE 7:    "Where will the run-off go after all this money is
spent?  Will the adjacent property owners be saddled with the
runoff mess?"

-------
                                50

"We are concerned about potential problems with flooding of our
apartment units should work be done on the 'landfill that
negatively impact Yeoman Creek.  This property experienced a
severe flood in 1986 that cost in excess of one million dollars
to clean up.  We are formally requesting that we be consulted
during the design phase of the cleanup, once the final decision
on which option is made."

U.S. EPA RESPONSE:

U.S. EPA agrees that drainage onto surrounding properties is an
important consideration.  It would be unacceptable for the new
site cover to cause flooding to the residents of the surrounding
properties.  Therefore, U.S. SPA has added the following
performance standard for construction of the drainage system to
the ROD:  drainage from the site cover onto adjacent properties
and into storm sewers will be adjusted to levels that will result
in no increased potential for flooding or other adverse effects.
The drainage from the site cover can be adjusted to flow into the
wetland south of the Site,  into Yeoman Creek,  into storm sewers,
or onto adjacent properties and streets.   The run-off could be
either totally diverted from adjacent properties and storm
sewers,  or adjusted to levels that result in no adverse effects.
Another performance requirement is that the run-off should not
have an adverse effect on the ecology of the wetland south of the
site.  U.S. EPA believes that these performance requirements for
the drainage system can be met.  The details of the drainage
system will be worked out during the design phase.   U.S.  -EPA
believes that after the preliminary design is completed,  a
meeting with adjacent property owners should be held to assure
that their concerns are addressed.

Another flooding concern is the impact of the site cover in
filling a portion of the floodway and floodplain in Yeoman Creek.
This concern is preliminarily evaluated in Section 4.4 of the FS.
Although the preliminary evaluation indicates that the impact of
the site cover on the floodway and floodplain of Yeoman Creek
will be minor,  U.S.  EPA's Proposed Plan includes provisions for
creation of compensatory floodway and floodplain storage and
other mitigation measures that may be necessary to assure that
construction of the new site cover will not cause problems due to
loss of floodway and floodplain capacity in Yeoman Creek.

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Page No.      1
02/12/92
                                                                                         FINAL
                                                         ADMINISTRATIVE RECORD IMOEX
                                                         YEOHAM CREEK LANOFIU SITE
                                                            UAUKGAM, ILLINOIS
PAGES  DATE
TITLE
                         AUTHOR
                                                  RECIPIENT
                                                                                                  DOCUMENT TYPE       OOCMUM8ER
2     61/09/25
Letter re:  Reply  to
request relative  to
information concerning
possiblt pollution of
Yeoman Creek with
brief results included
E. Theios-LCHO
                         J.  Vendervald-Nat'l Disp.
                                                                                                  Correspondence      1
1     69/06/06
Letter re:  Location
Data Water  Samples
J. Bolster-LCHO
L. Henlty-ISVS
                                                       Correspondence      2
1     69/06/12
Letter forwarding
copies of the analyses
made on samples  of
water collected  June
3, 1969 fro* a creek
in Weukegen
L. Henley-Illinois
State Water Survey
J. Bolster-LCHO
                                                                                                  Correspondence      3
1     69/07/24
Letter re:  The refuse
disposal site owned
and operated by the
City, was inspected
on July 14, 1969, by
Sanitary Inspector
Gary Brashear
F. Yoder-IDPH and
C. Klassen-tDPH, Chief
Sanitary Engineer
Mayor I Council-Waukegan
                                                                                                  Correspondence      4
1     69/08/21
City of Ueukegen
Data and Correspondence
File
City of Uaukagan
IOPH
Correspondence      S
1     70/02/17
Letter re: In the
August 21, 1969,  it
was advised that
final cover would be
applied to the now
completed landfill
site located on Lewis
Avenue in Waukagan
F.Yoder-Illinois
Oept. of Health
E.Santh-City of Waukegan
Correspondence      6
 1     70/07/17
Letter re: Cheaical
Analyses of two
samples of water in
YeoMen Creek
E.Theios-LCHO
L.Henley-1SUS
Correspondence      7

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Page Mo.      2
02/12/92
PAGES DATE
                   TITLE
                          AUTHOR
              ADMINISTRATIVE RECOW INDEX
              YEOMAN CREEK LANDFILL SITE
                  WAUKEGAM,  ILLINOIS

                          RECIPIENT
                                                                                                      DOCUMENT TYPE       OOCNUM8ER
1      70/08/10
Letter forwarding the
partial analyse* mad*
on samplea of water
collected fro* Ytoaan
Creek near Waukegan
L. Henley-Illinois
State Water Survey
E. Theios-LCHO
                                                                                                      Correspondence      3
1     70/09/25
Letter re: Reports
of investigations
including sample
reports; the results
of this investigation
are being considered
                          C. Klassen-IEPA
                          Mayor I Council-Ueukegan
                                                                                                      Correspondence      9
1     71/08/04     Letter re: Results of     L. Henley-Illinois
                   the boron datenainiations State Water Survey
                   mad* on saaples of water
                   collected July 20, 1971
                   at the Waukegan (Nat'I)
                   Landfill site
                                                    C. Clark-IEPA
                                                                                   Correspondence      10
1     71/08/13
Letter re: Results of
the boron determinations
mada on saaples of water
collected August S, 1971
at the Waukegan Municipal
Landfill
L. Henley-Illinois
State Water Survey
C. Clark-IEPA
                               Correspondence      11
1     71/08/25
Letter forwarding a
copy of the article
that appeared In
Waukegan's August
24th issue concerning
the City's plan to
install a clay barrier
between tht filled
site and Yecwan Creek
E.Theios-LCHO
T.Cavanagh-lEPA
Correspondence      12
      72/02/22     Letter forwarding a
                   copy of peg* six of
                   tha City Waukegan
                   official  Minutes for
                   the Coumcil Meeting
                   of January 31,  1972
                          R.Rhoades-LCHO
                          C.Clark-IEPA
                               Correspondence      13

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Page No.      3
02/12/92
PAGES DATE
TITLE
                          AUTHOR
              ADMINISTRATIVE RECORD INDEX
              YEOMAN CREEK LANDFILL SITE
                  UAUKEGAN, ILLINOIS

                          RECIPIENT
                                                                                                      DOCUMENT TYPE       DOCNUHBER
1      72/04/17     Letter r«: Reinspection   C. Clark-IEPA
                   of your property located
                   east of Lewis and south
                   of Sunstt Avenues was
                   made by a technical
                   representative of this
                   Agency on April 5, 1972
                                                    Mayor I Council-Uaukegan
                                                         Correspondence      14
1     72/04/18
Letter re: A conplaint
regarding YeoMan Creek
may be sent to IEPA;
suggestion mention that
leachata fro* leachata
fro* the Uaukegan Sani-
tary Landfill is pollut-
ing the creek
R.Criit-LCHO
D.Miller
                                                                                                      Correspondence      15
1     72/08/18
Letter re: Reinspaction
of your property
located on on North
Lewis Avenu* was
mada by a technical
representative of this
Agency on Juna 27, 1972
C. Clark-IEPA
Mayor I Council-Uaukegan
                                                                                                      Correspondence      16
2     72/09/08
Letter re: Old Uaukegan
Landfill Site
Buck Avenu* East of
Lewis
R.Rhoades-LCHO
S.Sidler-IEPA
                                                         Correspondence      17
1     72/10/27
Letter re: Old Sanitary
Landfill Buck and Lewis
Uaukegan
R.Rhoades-LCHO
C.E.Clark-IEPA
Correspondence      18
1     73/03/13
Letter re: Observation
by LCHO that the
portion of land owned
by you is being used
as a public duap
J. Patrick Conaway-LCHD   Arthur RubIoff I Co.
                               Correspondence      19
 1     73/03/21
Letter re: Uaukegan
Shopping Plaza
R. Findeisen-Arthur
Rubloff I Co.
 J. Patrick Conaway-LCHD
Correspondence      20

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Page No.      4
02/12/92
PAGES DATE
TITLE
                                             AUTHOR
              ADMINISTRATIVE RECORD INDEX
              YEOMAN CREEK LANDFILL SITE
                  UAUKEGAN, ILLINOIS

                          RECIPIENT
                                                                                                      DOCUMENT TYPE       OOCNUHBER
1      73/03/22
Letttr re: Uaukegan
Shopping Plaza
R. Findeisen-Arthur
Rubloff ( Co.
J. Patrick Conaway-LCHO
                                                                                                      Correspondence      21
1     73/03/29
Letter ra: Waukegan
Shopping Plaza
Lewis I Clan Flora
Aves.
R. Findaiaan-Arthur
Rubloff I Co.
J. Patrick ConawayLCHO
Correspondence      22
1     73/04/23
Lettar ra: Waukegan
Shopping Plaza
Laka County-Land
Pollution Control
R. Findaiaan-Arthur
Rubloff ( Co.
J. Patrick Conaway-LCHO
Correspondence      23
3     73/05/15
Lattar ra: Response
to lattar datad 4/17/73
which requaatad that
tha Agancy review and
report to you on tha
statua of four Laka
County problaa)
environmental situatlona
W. Pye-IEPA
E. Thaioa-LCHO
                               Correspondence      24
 1     73/05/25
Lattar ra:  Illegal
Dumping
J. Patrick Conaway-
LCHO
L. Myart
Correspondence      25
2     73/06/12     Lattar ra: Clarification  U. Pye-IEPA
                   of tha ownership atatua
                   of tha inactive T-K
                   Disposal Landfill Eaat
                   of Lewi a Avanua and
                   South of Sunaat Avanua
                   with rtsulta  included
                                                    E. Thaioa-LCHO
                                                         Correspondence      26
 1     73/07/09
 Lettar  forwarding  a
 copy of tha  Engineer-
 ing report that  nakaa
 racoMMandationa  for
 controlling  tha  leach-
 ate problaai  presently
 existing on  school
 board property behind
 the Waukegan shopping
 plaza
E.Thaios
G.SaHttle-wauekegan COM*.
Correspondence      27

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Page No.      5
02/12/92
                                                           ADMINISTRATIVE RECORD INDEX
                                                           YEOMAN CREEK LANDFILL SITE
                                                               UAUKEGAN,  ILLINOIS
PAGES DATE
                   TITLE
                          AUTHOR
                          RECIPIENT
                                                                                                      DOCUMENT TYPE
                                                                                                                          DOCMUM8ER
1     73/10/10
Ltttar re: Illegal
Dumping Buck Avenue
Sitt, Uaukegan
J.Patrick Conway-LCHD     D.J.  LaCroast
                                                                                                      Correspondence
                                                                             28
1     73/10/10
Lettar re: Illegal
Dumping Buck Avenue
Site, Waukegan
J.Patrick Conway-LCHO
                                                                       L.Wanzal
                               Correspondence
                    29
1     73/11/07
Letter re: An
investigation of an
alleged violation of
the Environmental
Protection Act waa
made on October 9,
1973 with results
included
                          C. Clark-IEPA
                          Mr.  t Mrs.  Danny lacrosse
                               Correspondence
                    30
2     73/11/07
Letter re: An
investigation of an
alleged violation of
the Environmental
Protection Act was
made on Sept. 26, 1973;
The purpose of the.
investigation waa to
make the appropriate
people aware of certain
conditions that exist at
the subject site with
results Included
C. Clark-IEPA
Uaukegan School Oiat. *60
Correspondence      31
 1      74/04/16
 Letter  re:  Refuae
 disposal  facility
 located east of Bank
 of  Waukegan, along
 Yeoman  Creek was
 inspected on April
 4,  197* with results
 included
C. Clark-IEPA
J.Hlada-Waukegan Park Ois
Correspondence      32

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Page No.     6
02/12/92
PAGES DATE
                   TITLE
                          AUTHOR
              AOMIMISTRATIVE RECORD INDEX
              YEOMAN CREEK LANDFILL SITE
                  UAUKEGAN, ILLINOIS

                          RECIPIENT
                                                                                                      DOCUMENT TYPE
                                                                                                                          DOCMUMBER
1     74/07/22
Letter re: Your refuse
disposal facility
located behind the
Bank of Uaukegan was
inspected on -line 24,
1974 by Rene Van
SoMren of I EPA
C.E. CIirk-!EPA
                                                                       «.  Findeisen-A.  RubIoff
                                                                                                      Correspondence
1     74/07/22
Letter re: Refuse
disposal facility
located east of Lewis
Avenue and south of
Sunset Avenue in
Uaukegan was inspected
on June 24, 1974 with
results included
C. Clark-IEPA
R. Miller-UPS I R. Kramer-CU   Correspondence
                                                                                                                         34
      74/10/04     Letter re: Refuse
                   disposal facility
                   located east of Lewis
                   Avenue was inspected
                   on Sept. 17, 1974
                   with results included
                          R. Van Soneren-IEPA
                          R.  Miller-UPS I R.  Krs«er-CW   Correspondence
                                                                                                       35
1     74/12/04
Letter re: Your
refuse disposal
located behind the
Bank of Uaukegan
was inspected on
Oct. 21, 1974 by
Pat Coneway of the
Lake County Health
Oept. and Robert
UengroM of IEPA
R. Van Soaeren-IEPA
R. Findeisen-A. Rubloff
                                                                                                     Correspondence
      74/12/04     Letter re: Refuse
                   disposal facility
                   located east of Lewis
                   Avenue was inspected
                   on October 21, 1974
                   with results included
                          R. Van Soawren-IEPA
                          R. Miller-UPS t R.  Kraner-CU   Correspondence
                                                                                                       37
1     76/03/25
Letter re: Your
W. Chi Id-IEPA
                                                    Arthor Rubloff I Co.
                               Correspondence
                                                                                                                          38

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                                U.S.  EPA  ADMINISTRATIVE  RECORD
                                           REMEDIAL  ACTION
                                   YEOMAN  CREEK  LANDFILL  SITE
                                          WAUKEGAN,   ILLINOIS
                                                UPDATE #2
                                                  05/03/95
DCCI   DHTE      AUTHOR                RECIPIENT             T!TL£/OE5CRi:T::N


   1   -;1.'OC.'"   ':•/ f, «»3':",  inc.    U.5. E53              Resort: Sve'ii;^. ;'  r;»;J  Investigation *o<-
                                                            Saseient Sas ^cnitarng

   I   ;::::"   = :•• F, «s3-,:«,  Ire.    Heiier, E., a.5.  E?A  Letter ranu-ii-g Attac-sd  suieary Tables re:
                                                            il) Exposure ^adgi  'sr *IM; (21 Life History
                                                            Inforiatior *sr Red Hinged Blackbirds; (3)
                                                            Data on Dietary Tox:cit» of PCBs to Nink; and
                                                            (4) the Canreltor IRF 'eoort

   3   ';;/13/"   a^jan, T.  and "ate!,  Boice,  R.,  U.S. EPA    Letter re:  Indoor Air Risk fcsessient
                 ].,  »cy F. Keston,
   4   ••i/01''"   »:::», R., 'j.3. EPA   Patterson, R.,        Letter re:  Csiients frst tht BTA6 Utttiaq         13
                                      Solder  Associates,    'Concerning  the Ecolcqical Risk  Asstssunt and
                                      Inc.                  Identification of Patnvays That Can  b«
                                                           Screened Out Fall wing a Pnliiinary
                                                           Screening;  i/Attachwnts

   S   Ci/14/73   ^s>1iii, A. and       Boice,  R., U.S. EPA   Letter re:  Landfill Sas Control  Design            6
                 iiihais, R., Solder  and Nussbaui, S.,     Schedule
                 Associates, Inc.       IEPA

   6   OS/1?/"   =jt3!( 3., Roy F.      Boice,  R., U.S. EPA   Letter re:  Heston's Revin Cotients on the        2
                 iieston, Inc.                                PRP's Proposid Responst to tht Landfill Sas
                                                           Rigration

   7   06/22/93   Scice, R., U.S. EPA   Hilhais, R., Solder  Letter re:  Proposal for Addressing Off Site       5
                                      Associates, Inc.      Landfill Sas and tht Effect of Deed
                                                           Restrictions on tht Risk  Assessment
                                                           Procedures; i/Attachients

  S   07/01/93   fteyer, 9., U.S. EPA   Boice, R., U.S. EPA   Iteiorandui  re: AMfis for  tht Yeotan Cretk         2
                                                           Landfill

  9   07/12/'!   rjshiii,  A. ard       Boice, R., U.S. EPA   Letter re:  Analytical  Results for Lead in         2
                 ?atterscn, R.,        and Nussbaui, S.,     Hater
                 Sclder Associates.     IE?A
 13   ;7/:::"   ::::?.  5,,  j.3. E?A   Hilliats, R..  Solder  Letter re: il; Coiaieticn sf the RI; (2!'
                                     Associates. Inc.       Additional Saesling; ari i3i Resoondenfs
                                                           ite-rjest for a- ixt3--s:r :f tie Scaeduia far
                                                           Subussion :' t^e  ?uoli: health Evaluati:n;
                                                           »/Attacuierts

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 ;:    ."::'"   «.::;*;;.  :.,  Z;;;*'1   3c;:». «., J.3. £:*   Letts'-  't:  I.-.te-:i  ?is  Irtnl  "ea3.' = -:
                 -33::iites.  .r-c.       and  lusstiui. S..
03/00/93   Solder 4ss:::jte3.    U.s. £?«
           Inc.
                                                            Design 3ocuee"t: Ccibustiiis 5as
                                                            *"d Virt:iat:sn S.stsi ';' :<(U-!
                                                            •So if

:«   Ol-'OO/"   3:^sr is3s:;a:9s,     U.S. EPH
                IT:.

if   5S/00/93   Sciisr Asscciites,     U.S. £FA
                inc.

14   OS/00/93   Sclder Associates,     U.S. EPA
                In:,

!'   32/04/93   Boira,  R., ".:. c?A    File
                                                      Draft RI «exrt: voi-ae 2 sf * lA^eriicas
                                                      fl-H)

                                                      Draft RI ffeccrt: Voiuit 3 of 4 (Text:
                                                      Sections 6-7,  Tallies and Figures)

                                                      Draft R! Seocrt: VoiuM 4 of 4 (Text:
                                                      Sections 6-7,  Enclosures)

                                                      Wetorandui  rs:  Calculations  Used to  De.-?iop
                                                      an Action Level  
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           2:   := U "   3:1:3,  s.. 'j.j.  EPA   =R?  Aii-snsss        Letts'1 -e:  .;-::i-.:r  :'  -.-3  ::ns?--.  jr:a"
           2a   09/22/"   Sc::5,  R.,  U.S.  EPA   File                  Attendant*  ~>::r:  '-r  :e;-.siter  22.  I":          3

                                                                      Nates

           27   09/22'9*   Glister,  i.  and        Boice, R., J.S. E?A   Latter r;:  :o:t3"'5 Res;rse  to  U.S. EPA's        9


                                                                      Socuaert

           2:   Or'23''!   Soic?,  R., :J.3.  EPA    rfilliais. :.,  Solder  Letts'- -a: :3=.:-.i of a :j:'tn! 4jd;t 3^ tie      5
                                                 Associates,  Lie.       RI  Data .il::ati:.-, ana -*rs'.-s~,

           2"   10/01/93   Hiiliais, R., Solder   3oice, R., 'j.S. EPA   fit  Transmission re: Coisustible 5as             26
                           Associates,  inc.       and Musssaui,  3.,      Detectior  and Air Exchange and Ventilation
                                                 !E?A                  Systee at  1401 - 1451 (Test Solf Road Building

           30   10/01/93   Sraan,  T. and Patel,  Boice, R., U.S. EPA   Letter r«j ite,ton's Review Ccnents on            3
I' '       .                  0., Roy :. Keston,                          Sectisn  5  ;-u:l:: Heaif:  Evaluation)  of  the
                           Inc.         .                               August 1S9I >a*t 91 Report

           31    10/07/93    Cuhn, II., Lake        Boice, R., U.S. EPA   Letter re: LC3*'s Coiients on  the Source          2
                           County Health                               Characterization Technical Keiorandui
                           Departient

           32    10/14/93    Silbertsen,  R. and    Boice, R., U.S. EPA   Letter re:  tfeston's Review Coeeents of the       13
                          Patel, 0., Roy F.                          Draft  RI Report
                          Ueston,  Inc.

           33    10/25/93   Boice, R., U.S.  EPA   File                  Conversation  Record w/Ed Karecki  (U.S. Fish       1
                                                                     and Mildlife  Service) re:  the  Draft RI and
                                                                     Risk Assessment

          34   11/03/93   Clark, J., U.S. EPA   Boice, R., U.S. EPA   Jletorandoi re: Inclusion of flonte Carlo Risk       2
                                                                     Analysis

          35   11/15/93   Clark, J., U.S. EPA   Boice, R., U.S. EPA   Heeorandui re: Health and Science Advisor's        2
                                                                     Prelmna-y Review of the RI Report

          36   11/17/93   Korobka, L. and        Boice, R., U.S. EPA   Letter re:  «estan's Audit of the Data           10
                          Patel, 0., Roy F.                          Validation  Perforied by Solder Associates for
                          Xeston,  Inc.                                the Round 2 Saiples Collected During the  RI

          37   11/18/93   Helier,  £., U.S.  EPA   Boice, R., U.S. EPA   fleeorandut  re: Technical Support Section's         2
                                                                     Review C:iients en the Draft RI Report

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IJ
*.,  -i'?
                                       3oi:e,  ?•.,  ..;.  :c-
 "9    11/24/93    Sprrger, I1., :j.5.    ?c::s
                 EPA/SR3
                                                                     ;'»j-:;-; 4tU;-«:  .^oratory  Results     '"
                                                                     *'.* :«s;iss ~;i;;:*.2J *-:i t"?
                                                                      luni::;a: II  mi  »2 Landfills

                                                                     ui r;;  Ecai:g::ai  Risk  Assessient          2
                                                                    Dct.srt:  «ir Excki-ge  and  Ventilation    12
 41    IZ/OZ/?'    ••crap. :., U.S. E?A   Boice,  R.,  :J.:.  E:-
 42   12/03/93    Traub, J., U.S. EPA   3Iei»ei3S, 5.,        Letter rs: fldiiristrative Crisr by Canssnt        1
                                      HcJeriott, Kill I     Assasseent of 3t:;ulated Penalties
                                      Eiery

 43   12/15/93    rorobka, L. and       Boice, R., U.S. EPA   Letter re: Kes tan's ?srf3run:s of Additional     3
                 Patei, 0., Roy F.                            Tasks in the Revisn tf the Data Validation
                 Ueston, I.ic.                                 e»rf3ried b» Sclier Asscciaiss

 44    12/li/93    Silbertsar,, R. and    3ci:a, R., :-'.3. ErA   Lettai- -e: »est:n"3 Revisn Clients on  the         5
                 ?atei, 0., Roy F.                            Retedial Alternatives Array  Docuient
                 Vestsn, Inc.
45   12/20/93   Boice,  R.,  U.S.  EPA    File
                                                            Conversation Record i/A.  Hashiii (Solder)  re:      1
                                                            Source of the Fill Located tear the Edxard's
                                                            Field Landfill
46   12/20/93   Boice, R.,  U.S.  EPA   Wilhais,  R.,  Solder  Letter Forwrding Attached  'J. 5.  EPA  Couents     60
                                      Associates,  Inc.       on the August 1993 Sraft  R!  Resort »/
                                                            Additional Attachments

47   12/30/93   Jiang, V. and  Patel,   Boice,  R., li.5.  EPA   Letter re: Mestsn's Revien Couents  on the    -.2
                0., Roy F.  leston,                           Design Oocuient  for Air Exchange and
                Inc.                                        Ventilation Systet

48   01/05/94   Boice, R.,  U.S.  Ef A   Nil liais, R.,  Solder  Letter re: U.S.  EPA's Approval •/                 2
                                      Associates,  Inc.       Modifications of the Design  Oocuient for the
                                                            Air Exchange and Ventilation Systei  for 1401
                                                            -  1451 Nest So If Road

*9   01/05/94   Hruski, S.,  U.S. EPft   Boice,  R., U.S. ESA   fleiorandui re: RCRA's Revie» of the               1
                                                            Alternatives Srray  fsr lierti'ication of
                                                            ARAFs  Docuient
50   31/07/94   Zar,  H.,  'J.S. EPA     saice, ?.., U.S.  '.'•-    «eioi'jr,dui  'e:  T»c^::al Advisor's Coiients
                                                            a.id  Idsntificitisn :f Ar:A"3 ':r tue Reiedial
                                                            Alternatives  A"3» Jo:uje^:

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            51    ):'1"':4    r;-,;.,  v,  _j
-------
                                       RECIPIENT             n;i£/3€3C3I?T;jH
 :i   :i ": '•*   it:.::/ rj     •      J.3. EPA              Site  issessien:  *e;:-t                           :*
                 •i,;.'5rse"t,  I".

 j;   ;:';i/'4   "-i-,3,  J.. U.S.  EPA   rfilliais,  S.,  Solder   Letter  re:  j.S.  EPA  s Review  of  the  FeSruar?      :
                                       Associates,  Ire.       17, i?'«  rorce fajeure  Request  and Approval
                                                             for an  Extension 3f  fie  Schedule  for
                                                             SuSussior  of the Risk  Assessment Portion of
                 -i".j;.  -.  -.-:        3:::?,  '.,  .'.:.  i5^   Letts' r;-»ir:-5 A'.taz'eS Sesscrses t; !J.S.      7
                 4i'.:.i83,  i.,  •:'.:'.'   5--  s.isca.i,  -,,     -SA ; C:i«frj;3Si'.           U.3.  EPA              Ar.notatK j.S. E?A C:«ient3 on the Auqast        17
                                                            1?93 iaseline Risk Assessment

 33    :j/ia/94    :C-  Tiisar             J.3.  E?A              Stochastic Risk Assessment: Voluie 1 of 2       110
                                                            (Text, Tables, and Figures)

 5?    o:/14/?4    I"  (iisar             U.S.  E?fl              Stochastic Risk 4sjessient: Voluie 2 of 2      3W
                                                            (E/iciuSuriS A-Hj

 73    •;3/17:'?4    3o::3, S., U.S. EPA    rile                 'Record of Conference  Call  re:  Couents  on the     1
                                                            Alternatives Array Docuatflt

 71    03/24/94    3r:ehoskkie, C.,       Nilliais,  R.,  Solder  Letter re:  Coepletion of tht Met land  /            2
                 u.S. EPA              Associates, Inc.       FloodplaiJi  Assessmt

 72    03/31/94    iilliais, S., solder  801:3, R., j.S.  EPA    Letter re:  Additional  Investigations  and          4
                 Associates, .'".      and Nussaaui,  5.,      Analysis  Required  by  the U.S.  EPA's Contents
                                       IEPA                  on  tne Retedial Alternatives Array Dooutnt

73    54/04/94    Bcica. R., iJ.S. EPA   Killiais,  R.,  Solder  Letter r»:  Solder's Request  for an Extension      2
                                      Associates, Inc.       to  the Subiittai of the FS  (UNSIGNED)

74   04/05/94   Xil!ia»s, R., Solder  Soice, R., ;J.S.  EPA    FAI  Transmission Fomarding  Solder's Request      3
                Asscciatss, I^c.      and Mussbaut,  5.,      for  Extension  to the FS Schedule
                                      IEPA

75   04/05/94   Street, K., U.S, EPA  Hilliais,  R.,  Solder  Letter re:  U.S. EPA's Disapproval of Solder's     1
                                      Associates, Inc.       Request for  an Extension to  the Sutwittal of
                                                            the  Draft ?S (UNSISNEO)

"6   •J4/H/94   fcran, E.. U.S. EPA   Boice, R.. 'J.S.  EPA    leiorar.cai  re: Technical Supoort Section's        2
                                                            Revie» [clients on the Baseline Risk
     :*;:i/?i   :w.3".i.-,  =.,           Boies,  '.,  :J.1. EPA   Letter r:r»arding Attached Vaukeqan Park
                •ii:;a-.  rar*:li,      ard  lusstaui,  S.,     District's Seciarat::n :f Restrictions on'
                illr 4 "is:-          I EPS                 ?^::s'tv Use

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            "3   I1 1? :i   Hi'.iiiis. R., Solder  Boies, '.,  ::.:.  E:A    Letter  rg:  ]c3'it::r  r:  "K-'e^ircs »Un ';r     L
                            Associates,  lie.                            the  A;'  E-c^se arj  '.*•-.Ration Systee

            "9   .;4/i5/94   3atal,  0..  Roy F.     Boice, R..  J.3.  EPA    _ettar  re:  tester s »«.;;« Clients :n tie        '
                            Hasten,  Inc.                                 >ab'uary 19^4 »! Resort

            S)   14/15'''*   fi.-eck:,  £.,  a.3.     3oi:a, R.,  U.S.  E'A    Seiorandui  "•: Tgchninl  Suoport Section's        3
                            EPS                                          Review Ccice-ts 3« tks E::!:<;:cil Portion af
                                                                        t.^e  Jasair? ';=< 15333=191:

            •'.'   '.- '.'-'-t   5:::5, ^., J.:.  :;i   H:i::i,is, '., oQliie'   ?Al  T'jrsnttal ?cr»irc;-; U.S. EPA's flpr;l        3
                                                  issouiatas.  Inc.       a, 1994 .leiorjsdui re; -.-s Statistical
                                                                       Scraeiunq Procedure

            ?2   •:*-'21/94   Cruis, <•. iCF         Lubin.  A., :J.5.  EPA   Letter Poniarding Atta:*»d ICF Kaiser Letter      12
                            i'ais?'                                      of Aonl 20, 1994 rt:  Sc^an and Slippage
                                                                       Tests «/Attachients

            53   .'i !:/94   Dclia'^iia, J.,  J.a.   Boice,  R., 'J.5.  EPA   fleiorandui  carwarding  Attacfttd Risk               3
/"                          E-4/"S3                                     Assessient  Paoer  for:  'Sfvie*  of PRP
                                                                       Discussion  af  PCBs  Slaw  Factor for the
                                                                       Yeoian Creek ,' Ediards r:eid Landfill'
                                                                       (DRAFT)

            94   04/28/94    Boi:e, R., U.S. EPA    Hilhais, R., Solder   Baselint  Rist AssessMiit  Sisapproval Letter      42
                                                  Associates,  Inc.       and 'Deficiencies and  Required Itadifications
                                                                       for the RI'  i/Additional  Attachments

            35   •"5/00/94    Soiiar Associates,     U.S. EPA/IEPA         Honthly Progress Reports  for the Period Hay      92
                            lie.                                         1W3  Through Hay 1W4

            3a   ;5;0!/94   Baice, R., U.S. EPA   Hilliais, R., Solder   Letter re: Subt-ittal of tht Draft FS              1
                                                 Associates,  Inc.

            87   05/09/94   Kar;Cki,  E.,  U.S.     Boice, R., U.S. EPA    Newrindm re: Technical Support Section's        1
                           EPA                                         Revin Couents on the 9raft FS

'            33   05/16/94   Netil, C.,  (I.S. EPA    Boice, R., U.S. EPA    Netorjndui re: Kttlands Regulatory Unit's          1
                                                                       ReviH Coiecnts an tht Iraft FS

            89   05/25/94   Pate!, 0., Roy P.     Boice, R., U.S. EPA    Letter re: ttston's Revie* Coitents on the        7
                           Union.  Inc.                                 April 27, 1W4 Draft FS

            90    !:'03/94   Shi;o, A., ICF        Bcice, R., U.S. EPA    fleeorandui rt: Clarification of U.S. EPA's        2
                           Uisar                                      Ccmnts

            = 1    !: ::;S4   LuS:-. *., L'.S.  E.BA   Boica. R.. J.5. EPA    Neeorandui re: Honitor:.-;  and  Quality              1
                                                                       Assurance Branch's Caeents an  the Hay 20,
                                                                       1994 Letter froi 'Dr. Karriy S.  Kruio
                                                                       Pertaining to Ki.idsar::;-:a the  Data  far the

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DCC»
  'I   06'T/94   :a::?,  ".,  j.3.  E:i   ?:!e                   Conversion Sec:-; n/74'y -:ar'.'  ,;;"; re:      '.
                                                              ricoi ?lil" A55S53I?-*.

  93   06/10/94   Boice,  R.,  U.S.  E?H   ~i\>.                   feting Recsrd re: ?refi-al Inaction of t^     :
                                                              Ventilatian Systse it f!« Y»siai C>-ee<
                                                              Landfill Site

  9*   06/13/94    83i:».  R.. e:  Noise Levels  F'am t^e  Ventilation       1
                 "cSe-iott,  'till  4                            System at 1401  - 1*51  test  Self Road
                 Eisry

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           I.';   ;i.'I*. :*   ::;:;, *., j.5. E:A   Julius,  R.,  ::!ier   '.stter re:  -e:c'siis'it;:-  :'  :-:;.=:;n of        I
                                                  Associates,  :-,:.       "§-209 in  tr-e »isi  isssssirt  ar-J  ^iri'ici'.-
                                                                        i:n  of F'::9d*-es  *cr  •ir:;cri:irg  ttie Data

           106   06/17 •''*   Rat!i<\ 5.,  IE?*     3oi:e,  3., U.:.  EPA    Letter .-e:  :-?v3 C:iis-:s  :n  the Jraft F5

           107   06/25/94   Sake. *., L'.S. ErA   Hiihais, 9.,  Ssider   Letter rg:  U.S.  Er*'3  -::-:vii  of the Draft      le
                 Oa/2!'/?4   3o::»,  ?.,  '.'.5.  ErA   fiie                   rorversatian Seccrd »••'., :at«i ana 5.
                                                                                 (Scl3»r! rs: '3s:l:s 3^ »8«
-------
                                 .  J.  and          33;:e, '., ..3. EPA   .9tt3' .'?: "esvii-at::- :•  :/r.n ;?3i;n i-d       2
                                ^iii,  3,, Solder                         :=^:'ia-:9 »:- E-rar.-e an Ve^;:at;:n
                               sjciatBs,  Inc.                            3/stsi *Q.- 1*01-14!.; «?5t Sol' »aad Building

            120   •;* Zl/'*   Bcice,  '..  U.S. EPA    ::-J                  C:r/?.'sjt:Gn flec^j »/a. "J3.L:ii (Sclder!  re:      1
                                                                        '<3o*iP Creek Ve-,tiiiti:n S/stsi

            i::   :"::.-=*   la:1:?'. 5,.  ;CF        :c;ce, ;,, :.:, E3-   Letter -«: "eta: ^1^1 I'sed  .- Ciicuiatian  c'  •     2
                             I'ils?"                                      CI31"51Z3. "ill-'d ."jltrS

            I"   .";22il?*   *'jub,  J.,  U.S. EPA    Diver, J., Je"       '.ett9r -s: H.:j:-:r.rit;.e C';er Sy  Censer*.         :
                                                   Jiver 5r3u" ••' :s?     -;3553ie-Tt :'  frii':; =
                                                   Steering  Csuittee

            123   07'27/94   ICF  Kaiser             :J.3. EPA               Baseline  'isk  Assjssient:  Peiedial              1:4
                                                                        Investigation   Chapter 6.  Voluie  I of 3
                                                                        (Text,  Taoie?  and Figures)

            124   07'27;'r4   ICF  Raiser            U.S. EPA               Baseline  9isk  Assesseert:  Reiidial              222
(~                                                                     Investigation   Chapter 6,  Voluit  2 of 3
                                                                        iEnclosure A)

            125   07/27/94    ICF  Kaiser            U.S. EPA               Baseline  Risk  Assessment:  feiedial              295
                                                                        Investigation   Chapter  4,  Volute  3 of 3
                                                                        (Enclosures 3«H)

            126   07/27/94   Shipp, A., ICF        Boice,  R.,  U.S. EPA    Letter Fomardinq Attached Response to U.S.       7
                            Kaiser                and  Ratliff,  5.,       EPA's Annotated Coiients on  the June 17,  1994
                                                  :EPA                  Draft Baseline  Risk Assessient

            127   07/27/'*   Miliiais,  R., Solder  Boice,  R.,  U.S. EPA    Letter Forwarding Attached Revised Pages  to       6
                            Associates,   Inc.       and  Ratliff,  5.,       the Final  RI Report
                                                  ;EPA

            128   07/26/94   U.S. EPA                                    Handwritten Notes of July 28, 1994 Meeting         a
                                                                  "      i/Attached Sign-is Sheet

            129    08/M/94   Daly, J.,  Solder       Boice,  R.,  U.S. EPA    Letter re: Confination of August 3,  1994         1
                            Associates,  Inc.                             Telephone  Conversation Concerning Air
                                                                        Exchange and Ventilation Systei at 1401-1451
                                                                        Kest Solf  Road Building

            130    08/09/94   Pate!, 0., Roy F.      Soice,  R.,  J.5. EPA    Letter Fsmardiag Attached Oversight Report      15
                            Kest:n, Inc.                                of Meekly  sassier,t faritsring at 1401-1451
                                                                        3o:f 3:ad  Building

            131    03/10/r4   likiris, J., Solder   Beice,  R.,  U.:. E.e«    Lsttsr -9: tjsvisa: Craft F5 Resort                '.
                            Associates,  Inc.       ard  Ratliff.  S.,
                                                  :EPA

-------
                                                                                                   Assessient
                                                                                                   o<  Cidum,
           ;::   OS/ie/9*   Diver,  J.,  ;»*<       3ci:e.  R.,  'J.3. £?a    Lette--  re:  C:fc.r  :f  li^.s^a.i's  Concerns  >ith      65
                            Dusr :r:.:                                 the  Finai  5:t» 'eiedy  »/Attachient$

           • -<    »,q  •?.'?!   »:::s.  '..  .'.:. :.:'j   •":!»                   C;-v=';it:c-  :;::':  •  a,  -35^111  (Solder! r«:     3
                                                                        ''ecsip  :-5=:  .r'tiij-.;:-  :.-:'.3i »/"-ia,-i»r;t*.sr!
                                                                        •Nctes

           :"!    03/19/94   >iub,  J.,  U.S. £?A   3:vs',  J.,  Je^        Letts-  '»\  ..-. I'-  3  i;:':val if -xtension       1
                                                  Siver 5r:us -' ^F      'or S^Jiss.r :f f« c:  ;UNSI6NED)
           1*4    06/26/94    Sraan, T. and Fatsi,  3ci:e, R., U.S. £?ft   Letts' rs: «e3t:^'s 'SVISK Ccuents on the RI     13
                            3., Ra? :. Keston,                          Rsaort
                            inc.
           17"    39/'51/'4   '-
-------
                                       ISCIPIEXT             TITIE/KSCRIPT::*


                                       •:::», R., J.5. E?A   Letter re: iCHD's Rev;s» :' 3>-4:*.e
                  Department

 ;r    i:/o4 ••?*    -i3f;n, i., Solder   3c:;e, 9., il.S. EPA   Letter re:  Fence Construction at 'er^ace
                  Ccrstru:ti:->                                Nursing Hoie
                                       ::::=,  :., J.3. £.:^   :.5tter r8:  LCHC's *ev:a» C:uent3 an tfie F5       2
                                       3:::s,  '.,  J.3.  E:^   wStta'-  re:  Output  Fi:»s  :f  '.".s
                                                                      »/fittacnier;t
 150   10/11/94   3ur»:a, V.,  City of   aaice,  I?.,  U.S.  EP*   Letter  re: Citinn's Cancens »ith  the Site       2
                 Kauiegin                                    Retedr  Selection

 151   10/l*/'«   Pate!, C.,  '••/  r.      :5i:e,  i?.,  :J.S.  ErA   Letter  re: Mestw's «»v;eii Conents on tne        5
                 jiestcn's,  inc.                               Septeiber 1994 C3 •/'Attachunt

 1:2   10/17/94   rath", :.,  IE?fl      3c::e,  «.,  J.S.  EFA   Letter  re: iEPA's Revie« of the Revised FS        i

 153   10/17/94   U.S.  EPA              Respondents           Second  Aiendeent to the Administrative Order     28
                                                             by Consent

 1?4   10/19/94   Has-ni, «.,  Solder   soics,  R.,  U.S.  EFA   FAI Transeission re: Requested Calculation*       9
                 Associates,  It:.                             for the FS

 155   10/20/94   Jereb, 6.,  I3GT        Soice,  R.,  U.S.  EPA   Letter re: IDOT's Review Coments on the FS       3

 156   10/20/94   Ratiiff, 5.,  IEPA      Boice,  R.,  U.S.  EPA   Letter re: IEPA's Couents on  the Supplement       1
                                                             to the RI

 157   10/21/94   Hashiei, A.,  Solder   Joice,  RM  U.S.  EPA    FAI Transmission re: Buestions About              1
                 Associates,  Inc.        •  '                   Floodplain Analysis

153   10/21/94   Patel, 0., Roy F.      Boice,  R.,  U.S.  EFA    Litter re: Results of Honthly  Monitoring  of        4
                 West on,  Inc.                                 the Basements North of  the Landfill

159   10/24/94   Boice, R., U.S. EPA   File                   Conversation  Record i/Don  Simbel  (IEPA)  re:        i
                                                             I DOT Floodoay Regulations

1:0   lfl/25/9*   Boica, R.. 'J.S. E?4   F;;a                   Convsrsatisn  Record •/Jahn Tak re:                1
                                                             applicability of the Uetsnsion Requirements
                                                             in the LC3K"C Ordinance

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:::«  , ;•«"       :/-:?                 RECIPIENT             TITL-OSSC* :?'::*
                                                                                     j
           1-1    '   ?"  "^    ^" ' ~a i * • .  w . 5 • " * ^   H11 1 i 1S  9.  5 C 1 - 8 r  ' 8 * * 8 r r 8 J  j. 5 i  " * -i
                                                 Assccntes. ;",:.      Oisa::r:va;  :'  4."e  ;»:'.»«:sr  1994  v9rsi:n o*
                                                                       tie ?5

           162    11/00/94    Solder Construction   U.S. EPA              Quarterly Ir«:ect::n  re;s't:  Air Exclange and    30
                            Services,  lie.                              Ventilation Systei  f-r  1401-1451 Solf Road
                                                                       Bulling (July  - Seoteiter  199*)

           1:!    11 •'.'  :1    •:::?.  ;,.  j.5. E5J   Hilliiis,  ^.,  Solder  Letter re: !1!  'roscssd  "esign Revisions to       i
                                                 *«:::ates.  I.-:.       5eet the 100 ::i Criteria 'cr Ccifcustiile
                                                                       n^cae  il  '< 7-i"  •'""  l,i*-«3*--
                                                                       udasa  tb  AT.'I C'g.' "w3«i  , ^;  •U^wiaiAk
                                                                       Hiring  Systei; and :.1':  S-snttal of a Design
                                                                       ]o:a»ent  for a  /emulation Systei at 1615
                                                                       Self Road; N/Attachients

           I:*    il/ll/54   Albert, ?.,  Faisy  t   Saice, R.,  !J.3.  EPA    Letter re: Dtitw Corporation's Response to        5
                           Lirirsr                                      U.S. EPA's 104(e) Request for Suppleiental
                                                                       Inforeation

/"-.      vj*   :i/;:/?4   Hiiiiats, ?., Solder   Boice, R., 0.5. EPA   Letter re; Sereric  Plan  to Stockpile Soil         4
 -                         J3;::nt33,' I*:.       and  Rathff, 5.,
                                                 IEFA

          166   11/16/94   Mashiii, A. and        Boice, R., U.S. EPA   Letter re: Solder's  Response to U.S.  EPA's       11
                           Dikinis, J., Solder    and Ratliff, S.,      Kovetbir 2,  1994 Letter  Conaminq:  (1)
                           Associates, Inc.       IEPA                  Aibient Air Readinqs at  14S1 lest Solf Road;
                                                                      (2) the Automatic Dialer Located in  the Fan /
                                                                      Thereal Conditioner Building;  and (3) Aebient
                                                                      Air Readings at  1615 Solf Road

          167   11/21/94   Keller, L., Outboard   Boice, R.,  U.S. EPA   Letter re: QIC's Response to U.S. EPA's         ' 44
                           "arire Corporation                          104fe)  Request for Supplemental Infonation
                                                                      •/Attacheents

          Ii3   ll''21/«4   Patel, 0.,  Roy F.      Bcice, R.,  U.S. EPA   Letter  re: Results of  RontMy  Honitorinq of      10
                           i9st:n, Inc.                                 the Baseients North of Yeoun Creek Landfill

          169   11/30/94   Sackett,  J.,  Jeff     Boice, R.,  U.S. EPA   Letter  Forwardinq Signed  flqrteeent «ith           2
                           3iver Sroug                                 Terrace Nursing How re:  No Oiqqinq in
                                                                      Backyard

          17C   12/00/94   Solder Associates     U.S.  EPA/IEPA         Feasibility Study                               506
                           Inc.

          171   i:/':;-;9*   ?;XIJR. J.,  Ross t    Boice, R.,  U.S. EPA   Letter  re: Vestvaca's  Ressonse to U.S. EPA's       6
                           rardiss                                     104(8)  Request »/Attachient

          I*'   i:.-:3;'4   ?atliff,  3.,  lira     Hashui.  A..  Sslder   Latter  ?oriiariir,g Attached IEPA August 10.         9
                                                &s5::iates.  In;.       1994  neeorandui re: Sroundwter Infonation
                                                                      Excersted  frs* the Seiadijl Investigation

-------
                  3c-u9-9ia^. .'.,       ?:::».  *.,  :..:.  l-A    Letter rj;  :;-5 =5;;,;-=;
                  Coral inte'-ati^ai                         l';4;e>  I-
  :i   lM-);'4   Kilhats, R., icider  So::?.  P..  J.S.  EPA    Letts'-  F:r»ar::r;  Attac-ei C?>ar,ced Paces 'or      fc
                  Associates.  !-:.       i^  ratl:^, 5..       the  FS
  "    12.'1C'S4    Diver,  J..  Ja"        3:::;. R., :-:.S. E1^   Lettsr  '•:  '•:•** Greet  C:tiittee's ^esrors?
                  :i.Br  •:':u:.-"'3:si,i                          to U.S. EP«'s  :u::ieiert ta the Bra" PI
       ::".:  ~-i    Du'kin,  ».,  City :f   s:i:». *., U.S. E8*:  Letts- re: Pnaial aitr-.ati/es
                        an:  et il.      3t ii.
 1"    1Z/15;'4   Her?',  !.,  'J.:i EPA   3o::3. R., U.S. EPfl   Hetorandui re: Air Toxics and Radiation           2
                                                             Branch's Couefits on tht F5

 L"3    ::-':9/s*   Kleiian,  I., J.S.     3o::;. R., J.S. EPA   Heiorandai re: RCRA's Reviei of  the FS,           2
                 EPA                                         Proposed Plan, and Record of Decision for
                                                             ARARs

 :'3    11/21.''*   Patei,  0..  Pcy '.     8oi:e, R., U.S. EPA   Letter re: Solder's Quarterly  Inspection          1
                 UBS ten,  Inc.                                Report for the Air Exchange and  Ventilation
                                                             Systu

 180    12/21/74   Pattl, 0., Roy F.     Boice, R., U.S. EPA   Letter re: Results of  Nootkly Nonitorinq of       7
                 Meston,  Inc.                                the Basewnts North of Yeouti Creek Landfill

 131    12'23/T4   Sreens'By. J.,  J.S.   Bci:e.  R., U.S.  EPA   Heiorandui re:  PC! Control  Section's Couents     4
                 EPA                                         on  the Draft  FS,  Draft Proposed Plan,  and
                                                             Draft Record  of Decision

152    12/30/94   ffeyer, D., U.S.  EPA   Boice,  R., U.S.  EPA   Betorandui r»:  Air  Action Levels •/Attachment     3

133   •)!. "W/?5   Solder Associates,     U.S. EPA               Monthly  Progress  Reports for June IW4           53
                 Inc.                                         through  December  1994

134   01/00/95   Solder Construction   U.S. EPA               Quarterly  Inspection Report: Air Exchange and    42
                 Services, Inc.                               Ventilation Systei  for  1401-1451 lest  Solf
                                                             Road  Building (Octabtr  - Otcetbtr 1994)

1S5   01/03/95   Tuggle, B.,  U.S.       BOICB, R.,  U.S.  EPA    Letter re: U.S. DOl's CotJtnts on the  Draft       21
                 DOI/Fish and                                FS, Draft  Proposed Plan, and tht Draft Record
                 HiliJIife Service                             of  Decision •/Attacnunts

1::   01 '1C •"!   Ji»:«:33, S.,         3oi:B, R.,  U.S.  EPA    Letter Foriarding Attached Deoosition             35
                 ,":re'i:tt, X;ll i                            Transcrist of Hilliai Shuiski in  the Yeoean
                 :i2'v     •                                  Crseii/EdHrjs J:eld Private Cost  aecovery /
                                                             Contribution  Lansuit

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 .:"   :i I! ;!   5-::e.  '  ,  J.S.  E?4    H:;l:i»s.  '..  Eclae-  Letter '?: a 'se-3':: :'.i-  t:  :t::'::ls :::'.'     T
                                        As3:::ate;.  I":.

 1:S   01/17/95   .Vei,  S.,  !COr        Boies,  R., L'.S.  -FA   Letter r?: IDG1"3 ?ev;s«  Iciae-ts " tke     ,     1
                                                             Drift F3 w/Attac'ee^ts

 IS3   01/13/95   Williaits, r., Solder   3ci:s,  R.. 'J.3.  :P«   Letter re: Lesci-ate Ccllectian Sxstsi             I
 ...    ::/;=.'=5    53:3:. T,, R.;y -.     3c;:e, •?., 'J.3. EFA   Letter '9: Sbiier's I-a*:e'plr I:s:s:t::n          :
                  Kes::r.,  I^c.                                Peoort *:r t^s 4:- t.»:La::e ari Ventilstian
                                                             S/stei

 I'l    o:/.}0/95    Sclier Sssacutes,    U.S. EPA              Honthly Progress Reoort ^or January i?95        ::
                  Inc.

 1':    02/00/95    Sal:'- Associates     U.S. EPA/IEPft         RI Report: Voluie 1 of  3 (Text,  Tables  and      ^7
                  Inc.                                        Figures)

 1"    o:/00/95    Saidar Associates     L'.S. EPA/IEPA         RI Recort:  Valuie 2 af  3 iAopendices A-E!       576
                  inc.

 194    02/00/95    Solder Associates     U.S. EPA/IEPA         RI Report:  Voluac 3 of  3 (Appendices F-H)       3*8
                  Inc.

 195    02/00/95    U.S. EPA                                    Supplement to  the RI Resort i/Attacluents        75

 19i    02/01/95   Pate!, 0., Roy F.     Boict,  R.,  U.S.  EPA    Letter  rtt  fcston's  Revien Couents far the       5
                  Keston, Inc.                                 Decetbtr 1994  FS  Report

 197    02/15/95    Boice, R., U.S. EPA   Villiais, R., Solder   Letter  Forwrdinq  Attactud Februanr 1995         58
                                       Associates,  Inc.       Suppleient  to  tht  FS Report

 199    02/27/95   Patil, 0., Roy F.     Boice,  R.,  U.S.  EPA    Letter  re:  Results of Bonthly Hooitorinq of       9
                 Xestan, Inc.                           .      the Baseients North of Teotan Creek Landfill

 199   03/00/95   Solder Associates     U.S.  EPA           -    Flooplain / Floodwy Study n/Attachtd Harch     i34
                                                             21, 1W5 Cavtr Letter

200   03/00/95   Solder Associate,     U.S.  EPA               Honthb Progress Rtport for February 1995        &
                  Inc.

:01   0!/n/??   UUliau, R.,  Soldir  Boice,  R.,  U.S.  EPA    Letter  re:  Solder's Reswnses to U.S. EPA's       23
                 Associates,  Inc.                             Oeceiber 22, 1994 CciKrts an the FS
                                                             •/Attachients

-------
ut
r  4

-------
C
                                         U.S.  EPA  ADMINISTRATIVE  RECORD
                                            YEOMAN  CREEK  LANDFILL  SITE
                                                  WAUKEGAN,   ILLINOIS
                                                         UPDATE  #1
                                                          08/11/93
         OOCt   DATE      AUTHOR               RECIPIENT            TITLE/DESCRIPTIM                             PAKS
  1   03/13/89   Roeine, I.,           Bohlen, C., U.S.  EPA  Browning-Ferris  Industries'  Response  to 104       9
                Browiinq-Ferris                           (e) Information  Request DitH February 7,
                Industries                                1989

  2   06/27/89   Naher, N., McKenna,    Bohlen, C., U.S.  EPA  Hilliai Shulski's Response to 104(e)              5
                Storer, Rtwe^ Unite                        Infortation  Request Dated June 6, 1989
                4 Farrug

  3   07/20/89   Sulley, R.,           Bohle*, C., U.S.  EPA  Bromine-Ferris  Industries'  Response to 104      IB
                Browning-Ferris                           (e) Information Request Received June 19,
                Industries                                1989

  4   08/07/89   Fishian, D.,  Abbott    Bohlen, C.. U.S.  EPA  Abbott Laboratories'  Response  to Request  for      7
                Labsratories                               Intonation  Dated June 14, 1989

  5   11/15/90   troop, R., City of    Bryant, E., U.S.  EPA  City of Kaukegan's Response  to the July 13,      23
                Naukegan                                  1990 Request for Intonation

 &   12/03/90   Kleiner, N. and      Boice,  R.,  U.S. EPA   Construction Oversight SueMry for Security      28
                Test, F.,  teston                           Fence  Installation

 7   08/00/91   Patterson, R.,        U.S.  EPA and IEPA     Monthly  Progress Report for July  1991             2
                Solder Associates
                Inc.

 8   08/20/91    Patterson, R.,        Boice,  R.,  U.S. EPA   Letter  re: Brass  Fire                            1
                Solder Associates
                Inc.

 9   09/00/91   Patterson, R.,        U.S.  EPA and IEPA     Monthly  Progress  Report  for Auqust  1991           4
               Solder Associates
                Inc.

10   09/09/91   Boice, R., U.S. EPA   File                  Conversation Record re:  the Biota Study and       1
                                                         Mctlands Delineation Uith J. Miller, Solder
                                                         Associates)

11   09/14/91   Miller, J., Solder    Boice,  R.,  U.S. EPA   Letter  re: the Metland  and Biota                  1
               Associates Inc.                            Investigations

12   10/00/91   Patterson, R.,        U.S.  EPA and IEPA     Monthly  Progress  Report  for September 1991        3
               Solder Associates
                Inc.

13   10/31/91   Boice, R., U.S. EPA   File                  Conversation Record re:  Telephone                1
                                                         Conversation Kith John  Zygokostas

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            OOCI    DATE       AUTHOR                RECIPIENT             TITLE/KSCSIPTIOH                              ?A6€S
             14    11/00/91   Patterson, R.,        U.S. EPA and  [EPA     Honthly Progress Reoort for October 1991          4
   '                          Solder Associates
                             Inc.

             15    11/20/91   Patel, 0. and Test,   Boice, R., U.S. EPA   Oversight of RI Field Work Reoort, October       21
                             F., Meston                                  2-4,  1991

             14    12/00/91   Patterson, R.,        U.S. EPA and IEPA     tanthly Progress Resort for Koveiber 1991          3
                             Solder Associates
                             Inc.

             17    00/00/92   Carter, J., IEPA      Boice, R.,  U.S. EPA   lEPA's  CoMents on  the Ecological  Assessment       1

             18    01/00/92   Patterson, R.,        U.S. EPA and IEPA     Hontkly  Progress Report for Decetber 1991          2
                             Solder Associates
                             Inc.

             19    01/03/92   Test, F., Keston      Boice, R.,  U.S. EPA   Oversight of RI  Field  Nork  Report, October 7,    36
(                                                                        1991 - Novetber  1,  1991

             20   01/15/92   Patterson, R.,        Boice,  R.,  U.S. EPA   Letter Report Suwarizing tht Procedures Used     3
                             Solder Associates     and  Carter,  J.,  IEPA   to Delineate Hater
                             Inc.

             21   01/17/92   Boice, R., U.S.  EPA   File                  Conversation Record ret Results of the            2
                                                                         Landfill Delineation Kork

  \          22   01/17/92   Patel, 0. and Test,    Boice,  R.,  U.S.  EPA   Oversight of RI Field Work Report, Novnbtr      28
                             P..  Neston                                  4-30, 1991

             23   01/24/92   Patel, 0. and Test,    Boice,  R.,  U.S.  EPA   Oversight of RI Field Kork Report, Oeceiber      15
                             F.,  Meston                                  2-19, 1991

             24   01/27/92   Patterson, R.,         Boice,  R.,  U.S.  EPA   Letter re: Possible Changes to the SOP            1
 f                          Solder Associates     and  Carter,  J.,  IEPA
 V         '                 Inc.

             25   01/28/92   Patel, 0. and Test,    Boice,  R.,  U.S.  EPA   Heston's Couents on the Haste Delineation         5
                             F.,  Heston                                  Report

             26   02/00/92   Patterson, R.,         U.S. EPA and IEPA      Ronthly Progress Report for January 1992          3
                             Solder Associates
                             Inc.

             27   02/03/92   Carter, J.,  IEPA      Boice,  R.,  U.S.  EPA   Facsinle Tei Locations for the Sas Probes         3

             28   02/11/92   Boice, R., U.S.  EPA    Patterson,  R.,         Letter re: Results of the Landfill                4
                                                   Solder  Assoc. I       Delineation and the Proposed Relocations of
                                                   Bleiiieiss,  S.,         Leachate Nells, Monitoring Nells and Sas
                                                   NcDenott...           Probes

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DOCI   DATE       AUTHOR
                       RECIPIENT
                       TITl£/0€SCaiPTIO«
  29   02/13/97   Carter,  J.,  IEPA
  30    02/1R/92   Patterson,  R.  and
                  Miller,  J.,  Solder
                  Associates  Inc. •

 •31    02/28/92   Patel, 0. and  Test,
                  F.,  Meston

  32    03/00/92   Patterson, R.,
                  Solder Associates
                  Inc.
                       Boice,  R.,  U.S.  EPA   lEPA's Coeicnts on the Haste Delineation          4
                                             Investigation

                       Boice,  R.,  U.S.  EPA   Letter re:  Location of a Second Bedrock Nell      2
                      Boice, R., U.S. EPA   Oversight  of  RI  Field  Hork  Report,  January       49
                                            b-31,  1992
                      U.S. EPA and IEPA     Monthly Progress Report  for February  1992
                                                                         4
  33    03/10/92    Boice, R., U.S. EPA   File
 34   03/11/92
 35   04/00/92
f~       34   04/00/92
 37   04/01/92
 38   04/02/92
Patterson, R.,
Solder Associates
Ir.c.

Patterson, R.,
Solder Associates
Inc.

Patterson, R.,
Solder Associates
Inc.

Patterson, R.,
Solder Associates
Inc.

Patterson, R.,
Solder Associates
Inc.
 39   04/06/92   Patel, 0., Meston
 40   04/22/92   Patel, 0., Meston
 41   OS/00/92   Patterson, R.,
                 Solder Associates
                 Inc.
                                            Conversation Record re: Location of  the
                                            Northern Off-Site fell Cluster  (tilth R. Mill-
                                            iats, Solder Associates)
                      Boice,  R.,  U.S.  EPA   Oversight of  RI  Field  Hork  Report,  March
                                            2-13,  1992

                      U.S.  EPA and  IEPA     Monthly  Progress Report  for Nay  1992
                                                                                                              25
Boice, R., U.S. EPA   Letter re: Location for Second Donngradient
                      Monitoring Hell Cluster
U.S. EPA and IEPA     Monthly Progress Report for April 1992
Boice, R., U.S. EPA   Monthly Progress Report for March 1992
Boice, R., U.S. EPA   Letter re: Monitoring Hell Installation
                      Procedures
Boice, R., U.S. EPA   Letter re: Revising RI/FS Schedule Once
                      Property Access is Provided
                      Boice,  R.,  U.S.  EPA   Oversight  of  RI  Field Hork  Report,  February      79
                                            3-28,  1992
                                                                       45

-------
           DOCI   DATE       AUTHOR                RECIPIENT              TITLE/OCSCRIPTIOII                              PA6ES
           332:1   ::s3       12=222                Z323U3M              iau2»xa23su2sn                              rxxra

             42   05/12/92   Boice, R.,  U.S. EPA    File                   Conversation Record re:  Solder Associates'         1
                                                                         Progress (nth j. fliller,  Solder  Associates)

             43   05/12/92   Boice, R.,  U.S. EPA    File                   Conversation Record re:  Oversight of  the RI        2
                                                                         (•ith  0.  Patel, eeston)

             44   05/15/92   Boict, R.,  U.S. EPA    File                   Conversation Record re:  Heston's  Oversight         1
                                                                         Report (with J. Miller,  Solder Associates)

             45   05/18/92                         U.S. EPA               Determination of Volatile Organic Compounds       12
                                                                         By Carbon Itolecular Sieve Absoptiom and  6C/NS

             46   05/18/92   Patterson, R. and      Boice, R., U.S. EPA   Letter re: Results  of the Supplemental Haste       4
                             Hi Her, J., Solder     and Carter, J., IEPA  Delineation  Investigation
                             Associates  Inc.

             47   05/21/92   Niedergang, N., U.S.   Patterson, R.,        Letter  re: Revised  Schedule                       3
                             EPA                   Solder Associates
("                                               Inc.

             48   05/22/92   Patel, 0., Meston      Boice, R., U.S. EPA   Oversight of RI Field Hork Report, Nay 18         9
                                                                        19,  1992

             49   05/27/92   Patterson, R.,         Boice, R.,  U.S. EPA   Letter re: Investigating Haste in  Off            10
                             Solder Associates      and Carter, 1., IEPA  Site Areas,  Hith Attachments
                             Inc.

  \          50   05/29/92    Boice, R., U.S.  EPA   File                  Conversation Record re:  Discussion of             1
                                                                        Comments on  the Ecological  Assessment Report
                                                                        (•ith E. Helmcr, U.S. EPA)

             51    05/29/92    Boice, R., U.S.  EPA   File                  Conversation Record re:  Review of  Ecological       1
                                                                        Assessment («ith H. Kuhn, LCHO)

  ,           52    05/29/92   Heleer, E.,  U.S. EPA   Boice,  R.,  U.S. EPA   U.S.  EPA Technical Support  Section's  Reviev        1
 V                                                                     of the  Ecological Assessment

             53    05/30/92   Patterson, R.,         Boice,  R.,  U.S. EPA   Lettsr  re: Revised SOP for  Analysis of PCBs        2
                            Solder Associates      and Carter, J., IEPA  in LNAPL
                             Inc.

             54    06/02/92   Kuhn, «.,  Lake         Boice,  R.,  U.S. EPA   LCHD's  Review of the Ecological Assessment        1
                            County Health                               Report
                            Department

             55   06/08/92   Boice, R., U.S.  EPA   Patterson,  R.,         U.S.  EPA and lEPft's Review  of  the  Ecological       3
                                                  Solder Associates      Assessment Report
                                                  Inc.

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           DOCI   DATE       AUTHOR               RECIPIENT             TITLE/DCSMIPTIQH                              PA6C5
                             ;S
             56    04/10/97   Bout,  R.,  U.S. EPA   Patterson, R. and     Attach«ent for  the Ecological AssessMflt         LO
                                                  Niller, J., Solder    Report - "Regional Suidance for Conducting E-
                                                  Associates Inc.       coloqical Assessments,1 Draft

             57    06/16/92   Boice,  R.,  U.S. EPA   File                  Conversation Record re: Permission for Access     2
                                                                        for the Last Monitoring Hell Cluster (mtlt J.
                                                                        Hitler and R. Patterson, Solder Associates)

             58    06/16/92   Patterson,  R.,        Boice, R., U.S. EPA   Letter re: June 10, 1992 Telephone                I
                             Solder  Associates                           Conversation on Scheduling of tht Ambient  Air
                             Inc.                                        Survey

             59    06/17/92   Boice,  R.,  U.S. EPA   File                  Conversation Record re; Ambient Air  Sapling       1
                                                                        for Landfill  Gas Emissions ditn 6.  Prince
                                                                        and A. Smith, ERT)

             60    06/17/92   Boice,  R.,  U.S. EPA   File                  Conversation  Record re« Health  and Safety          1
                                                                        Training  for  tforkers frith A. laumu, U.S.
C                                                                      EPA and R. Patterson,  Bolder  Associates)

             61    06/24/92    Carter, J., IEPA      Boice,  R.,  U.S.  EPA   lEPA's Contents  Pertaining to the Results of      2
                                                                        the Supplemental Haste Delineation
                                                                        Investigation

             62   06/24/92    Boice, R., U.S. EPA   Patterson,  R.,         Letter rei the Haste Delineation and Propose*     2
                                                  Solder  Associates      Fence  Location
  /""                                            Inc.
  v                                                                                                      .
             63   06/2S/92   Niller, J. and        Boice,  R.,  U.S.  EPA   Letter re: U.S.  EPA Letter Dated Nay 21, 1992     9
                            Patterson, R.,                              Concerning the Schedule and Possible
                            Bolder Associates                            Technical Deviations From  the Procedures
                             Inc.

             64   06/21/92   Schupp, 6., U.S. EPA   Karl, R., U.S. EPA     Review of tht First Revision SOP for the QAPP     4

 (          65   06/26/92   Patterson, R.,        Boice,  R.,  U.S.  EPA   Letter re: THO Proposed Modifications to the      7
                            Solder Associates                            RI/FS  Mork Plan
                             Inc.

            66   07/00/92    1DPM                                        Interia Preliminary Public Health Assessment    49

            67   07/00/92   Patterson, R.,        U.S. EPA and  IEPA      Monthly Progress Report for June 1992           13
                            Bolder Associates
                             Inc.

            68   07/01/92   Boice, R., U.S. EPA   Patterson,  R.,         Letter re: Use of  the Brundfos Pump               1
                                                  Solder  Associates
                                                  Inc.

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           OOCI   DATE       AUTHOR                RECIPIENT             TITLE/OESCRIPTIW                              ?A€£5
             49   07/01/92   Boict,  R.,  U.S.  EPA   Patterson,  R.,        U.S.  EPA's Reviw of the Proposed Supplement      3
                                                   Solder Associates     to the RI/FS tort PUn
                                                   Inc.

             70   07/07/92   Niller,  J.  and         Boice,  R.,  U.S.  EPA   Letter re: Fence Construction                     5
                             Patterson,  R.,         and Carter, J.,  IEPA
                             Solder  Associates
                             Inc.

             71   07/15/92   Boice,  R.,  U.S. EPA   File                   Conversation  Record  re:  Hater Hell  Survey          1

             72   07/15/92   Patterson,  R.,         Boice,  R.,  U.S.  EPA   Letter re: Revise* Standard Operating            30
                             Solder  Associates      and Carter,  J.,  IEPA  Procedures  (SOPs)
                             Inc.

             73   07/16/92   Boice,  R.,  U.S. EPA    Patterson,  R.,         U.S. EPA's Re vie* of tht Letter Dated July 7,     1
                                                   Bolder  Associates      1992
£>•                                                '"Ct

             74   07/20/92   Boice, R.,  U.S. EPA    Fatainski, L., ATSDR    Letter re: RPN's Review of the Interii            2
                                                                         Preliminary Health Assessment

             75   07/20/92   Traub, J., U.S. EPA    Patterson, R.,        U.S. EPA's Reviea of the Proposed Schedule        9
                                                  Solder Associates     Revisions for the RI/FS
                                                   Inc.

    ("'       76   07/23/92   Patterson, R.,        Boice, R., U.S. EPA   Letter re: Proposed Notification  to the            2
                            Solder Associates     and Carter,  J., IEPA  Sroundnater Sampling Procedure
                             Inc.

             77   07/27/92   Boice, R., U.S.  EPA   Patterson, R.,        Letter Responding to the June  1992 Monthly        6
                                                  Solder Associates     Proqress Report,  the Intern Preliminary
                                                  Inc.                   Health Assessment, and  the  Technical
                                                                        Memorandum for the Mater Supply Hell Survey

 \           79   07/27/92   Killer,  J. et al.,     Boice, R., U.S. EPA   Revised Ecological Assesseent  Report           122
                            Solder Associates     and Carter,  J., IEPA
                            Inc.

             79    07/30/92   Boice, R., U.S.  EPA   File                  Conversation Record re: Leachate Hell             1
                                                                        Sampling  (»ith R. Patterson, Solder
                                                                        Associates)

             80    08/00/92   Patterson, R.,        U.S.  EPA and IEPA     Monthly Progress  Report for July  1992            33
                            Solder Associates
                            Inc.

             31    06/03/92   Patterson, R.,        Boice, R., U.S. EPA   Letter Confirming Telephone Conversation m       2
                            Solder Associates                           July 29 and 30,  1992
                            Inc.

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            50CI   DATE       AUTHOR                RECIPIENT             TITLE/OCSCRIPTIW                              PASES
            1333
              82    08/05/92   Patterson,  R.,         Boice.  R.,  U.S.  EPA   Letter re: Changes Me to the Revised            3
                              Solder Associates     »nd Carter,  J.,  IEPA  Schedule
                              Inc.

              33    08/07/92   Boice, R.,  U.S.  EPA   File                  Conversation Record ret Landfill  Sas              1
                                                                          Monitoring in February (with T. Pritchett,
                                                                          ERT)

              34    08/07/92   Boice,  R.,  U.S.  EPA   File                  Conversation Record re: the  Proposed Schedule      1
                                                                          (Kith  R.  Patterson  mi i.  Miller,  Solder
                                                                          Associates)

              35    08/18/92   Patterson,  R.,         Boice, R., U.S. EPA    Response  to  U.S. EPA's Letter Dated  July 27,       7
                              Solder  Associates      and  Carter, J., IEPA   1992
                              Inc.

              86    08/24/92   Traub,  J.,  U.S.  EPA   Patterson, R.,         Letter re: Approval of  Revised Schedule            5
                                                    Bolder Associates
C                                                  Inc.

              87    08/27/92    Boice,  R.,  U.S.  EPA   Patterson, R.,         Letter re: Proposed Schedule and Procedures,      b
                                                    Solder Associates     Along Kith Contents on  the Revised Ecological
                                                    Inc.                  Assessient Report Kith Attachments

             88    08/27/92   Hashiii, A. and        Boice, R., U.S. EPA   Letter re: Scheduling of Landfill  Sas             1
                             Patterson,  R.,                              Screening
  /                         Solder Associates
  {-                           Inc.

             89    09/00/92   Patterson,  R.,         U.S. EPA and IEPA     Monthly Progress Report for August 1992          28
                             Solder Associates
                              Inc.

             90    09/01/92   Patel, 0., Meston      Boice, R., U.S. EPA   Oversight of Rt Field Mork  Report,  June B         51
  *-••                                                                     30, 1992

             91   09/18/92   Boice, R., U.S.  EPA   File                  Conversation Record re: Delay in Sending Out      1
                                                                         Letters for the Basetent Ronitoring (with R.
                                                                         Parson, City of Uaukegan)

             92   09/23/92   Traub, }., U.S.  EPA   Patterson, R.,         Letter  re: Conducting the Initial  Phase of         1
                                                   Solder Associates     Basetent/Craul Space Monitoring for Landfill
                                                    Inc.                  Sases As Soon As Possible

             93   09/24/92   Patel, 0., Meston     Boice, R., U.S. EPA   Oversight of RI Field Nork  Report,  July 1992    116

           .  94   09/29/92   Hashiei, A.  and        Boice, R., U.S. EPA   RI/FS Uork Plan Addenda* for  Sutp  Assessment      9
                             Patterson, R.,        and Nussbaum,  S.,
                             Solder Associates      IEPA
                             Inc.

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           DOCI    DATE       AUTHOR                RECIPIENT             TITLE/DCSCRIPTIQM                             P(W€3
           3sxa    sax*       szszza                =*aasxxx*             —*-—"T——»"'-                             zaaaa

            9)    09/30/92   Boui, R., U.S. EPA   File                  Conversation Record rei CSI  Readings («itH A.     2
                                                                        Hishiii and R.  Patterson,  Solder Associates)

            96    09/30/92   Hashiei, A. and       Boice, RM U.S. EPA   Preliminary Screening for  Ecotoiicoloqicai       33
                            Patterson, R.,        and Mussbaui, S.,     Risks,  Draft
                            Solder Associates     IEPA
                            Inc.

            97    10/00/92   Patterson, ft.,        U.S. EPA and IEPA     Honthly Progress  Report for  Septnber  1992       33
                            Golder Associates
                            Inc.

            98    10/05/92   Boice, R., U.S. EPA   File                  Conversation Record  ret  CSI  Readings (»ith A.     1
                                                                        Hashiei, Solder Associates)

            99    10/05/92   Boice, R., U.S. EPA   File                  Conversation Record  re:  Report of the             1
                                                                        Landfill Sat (vith Lt. Hilewki, Maukegai
                                                                        Fire Dept.)

           100   10/05/92   Boice, R., U.S. EPA   File                  Conversation Record  re:  Reported Levels of       1
                                                                        Landfill Sas (Nith R. Nickle, ATSOft)

           101   10/06/92   Boice, R., U.S. EPA   File                  Conversation Record  re: ATSDft's                  1
                                                                        Recomndations (mth R. Parson and Mayor
                                                                        Paravonian, City of Maukegan)

  s*--     102   10/06/92   Boice, R.,  U.S. EPA   File                  Conversation Record re: Basetint Landfill Sas    1
 (                                                                      flonitoring (Nith A. Hashiei and R. Patterson,
  -  •                                                                   Solder Associates)

           103   10/06/92   Boice, R.,  U.S. EPA   File                  Conversation Record re: Clarification of          1
                                                                        ATSM's Evaluation of the Landfill Sas  (Kith
                                                                       R. Nickle,  ATS Mi)

           104   10/06/92   Patel, 0.,  Ucston      Boice, R., U.S. EPA   Oversight of RI  Field Mork  Logbook Sheets,        &
(                                .                                    October 2,  1992

           105   10/07/92   Boice, R.,  U.S. EPA   File                 Conversation Record re: BatCMnt Landfill Sas     1
                                                                       Monitoring  («ith 0. Patel,  Kestonl

           106   10/07/92   Boice, R.,  U.S. EPA   File                 Conversation Record re: Conference Call           2
                                                                       Concerning  Basetent Sas Bonitoring

           107   10/07/92   Boice, R.,  U.S. EPA   File                 Conversation Record re: Response and             2
                                                                       Monitoring  for Landfill Bases in Basetents
                                                                        (•ith T. Pntchett, ERT, R. Parson,  City  of
                                                                       Waukegan and R.  Patterson t A.  Hashiti,
                                                                       Solder Associates)

-------
            3QCI    DATE       AUTHOR                RECIPIENT             TITLE/OESCRIPTIOI                              pftfi€5


             108    10/13/92   Boice, R.f U.S. EPA   File                  Conversation Rtcord re: Confirmee Call           2
                                                                         Concerning tht Basttmt Sat Itaiitonni.

             109    10/13/92   Patel, 0., tfeston     Boi», R.,  U.S.  EPA    Lttttr rn SuMiry of Bameit Information        3

             110    10/14/92   Boice. R., U.S. EPA   File                  Conversation Record re: Retediation of            1
                                                                         Landfill Sas Entry (with T. Pritchett, ERT)

             111    10/20/92   BltiMisi, SM        Hersh, S.,  U.S.  EPA    Letter re: tht PKP Conittee's Proposal to        2
                             KcDenott, Mill I                           Add Traps to lasMtnt Suiot
                             Eiery

             112    10/20/92   Patel, 0., Heston     Boice, R.,  U.S.  EPA   Oversight of RI Field tori  Report,  August        26
                                                                         1992

             113    10/27/92   Hashiii,  A. and       Boice, R.,  U.S.  EPA   Letter rit tht Subtittals Schefclt                1
                             Patterson, R.,        and  Nussbaui, S.,
                             Golder Associates     IEPA
f                            Inc.
            114   10/27/92   Hashiii,  A.  and       Boice, R., U.S. EPA   Technical  Httorandui for  Reduced Parameter       38
                             Patterson, R.,        and Nussbaui, S.,     List
                             Solder Associates     IEPA
                             Inc.

            115   10/29/92   Boice, R., U.S. EPA   File                  Conversation  Record  re: Remedial Action in        2
                                                                        Response to Landfill  Sat  in Basennt (oith A.
  t                                                                      Baunn, U.S.  EPA  and  A. Hashiii, Solder
                                                                        Associates)

            lib   10/29/92   Hashiii,  A.  and       Boice, R., U.S. EPA   Letter re: BasetMt Suip  Remedial Action Plan      3
                             Patterson, R.,        and Nussbaui, S.,
                             Solder Associates     IEPA
                             Inc.

 (          117   10/29/92   Hashiii,  A.  and       Boice, R., U.S. EPA   Revised Technical Hetorandui for the Nater      101
                             Patterson, R.,        and Nussbaui, S.,     Supply fell Survey
                             Solder Associates     IEPA
                             Inc.

            118   10/30/92   Boice, R., U.S. EPA   File                  Conversation  Record re: Reduced Parameter         1
                                                                        List (»ith Solder Associates and IEPA)

            119   11/00/92   Patterson, R.,        U.S. EPA and IEPA     Nonthly Proqress Report for October 1992        27
                             Solder Associates
                             Inc.

            120   11/02/92   Hashiii,  A.  and       Boice, R., U.S. EPA   Litter re: tht Reduced Parameter List             2
                             Patterson, R.,        and Nussbaui, S.,     Technical Hstorandui
                             Solder Associates     IEPA
                             Inc.

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          JOCI   DATE       AUTHOR                RECIPIENT             TITLE/DCSCRIPTIOH
 121    11/03/72   Hashiei, A. and       Boice, R., U.S.  EPA   Letter  re:  tht  Basement  Suto Remedial  Action       4
                 Patterson, R.,        and Nussbaut, S.,     Plan
                 Solder Associates     IEPA
                 inc.

 122    11/04/72   Boice, R., U.S.-EPA   File                  Conversation Record re:  Installation of  Traps      I
                                                             in Sumps  (vith R. Patterson,  Solder
                                                             Associates)

 123    11/04/72   Patterson, R.,        Boice, R., U.S. EPA   Letter re: Health and Safety  Training  for         2
                 Solder Associates     and Nussbaut, S.,     Plutbtrs
                 Inc.                  IEPA

 124    11/17/72   Boice, R., U.S. EPA   File                  Conversation Record re: Additional Landfill       1
                                                             Sas Monitoring (mth T. Pritchttt, ERT)

 125    11/17/72   Boice, R., U.S. EPA   Patterson, R.,        U.S. EPA's Comments on tht RI/FS Hork Plan        3
                                       Solder Associates     for Additional  Landfill Gas Monitoring and
                                       Inc.                   tht Preliminary Screening for
                                                             Ecotoiicological Risks

 126    11/23/72   Patel, 0., tfeston     Boice, R., U.S.  EPA   Oversight of RI  Field  Hork Report, September     66
                                                             1772

 127    12/00/72   Patterson,  R.,         U.S. EPA  and  IEPA     Monthly  Progress Report for November  1772        24
                 Solder Associates
                 Inc.

 128    12/01/72   Hashimi,  A. and       Boice, R., U.S.  EPA   Revised  Figure  1  for the  Revised  Technical         9
                 Patterson,  R.,         and Nussbaut,  S.,      Mecorandut for  tht Hater  Supply Hell Survey
                 Solder Associates     IEPA                   Dated  October 27, 1772
                 Inc.

 127   12/04/72   Hashiii,  A. and       Boice, R.,  U.S.  EPA   Letter re: Additional Landfill Sas Monitoring      3
r                 Patterson,  R.,         and Nussbaut,  S.,
                 Solder Associates     IEPA
                 Inc.

130   12/08/72   Boice,  R.,  U.S. EPA    File                   MCM re:  Concerns About the  July  1772 Monthly      1
                                                             Progress  Report

131   12/07/72   Boici,  R.,  U.S. EPA    Fill                   Conversation Record re: Additional Landfill        5
                                                             Sas Monitoring Kith Attachment (nith R.
                                                             Patterson, Solder Associates)

132   12/11/72   Patterson,  R.,         Boice, R.,  U.S.  EPA   Letter re:  Installation of  Traps  to Prevent        2
                 Solder Associates     and Nussbaut,  S.,      tht  Inflow of Sas Through  tht  Basement  Sumps
                 Inc.                  IEPA
r
                                                                 10

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            DOCI   DATE       AUTHOR                RECIPIEMT             nTLE/KSCRIPTIW                              PA5€S
            133*
             133   12/14/72   Sriw, T. and Patel,  Boice,  R.,  U.S. EPA   Heston « Review of the Haitian Pathway          3
                              0., ttcston                                  Assessment Technical Memorandum and
                                                                          Preliminary Screening for Ecotoiicoloqical
                                                                          Risks

             134   12/13/92   Nussbaum, S., IEPA    Boice,  RM  U.S. EPA   lEPA's Comments on the Preliminary Screening      4
                                                                          for Ecotojticoloqical Risks

             135   12/15/72   Hashiii,  A.,  Solder   Boice,  R.,  U.S.  EPA   Letter re:  Pond Sediment Sampling                  1
                              Associates IRC.

             134   12/15/72   Hashiii,  A.  and        Boice,  R.,  U.S.  EPA   Letter re:  the  Migration Pathway Assessment       2
                              Patterson^. R.,         and Mussbaum, S.,      Technical Memorandum
                              Solder Associates      IEPA
                              Inc.

             137   12/21/72   Hclier, E., U.S. EPA   Boice,  R., U.S.  EPA   Comments on  the Preliminary Screening for         2
                                                                          Ecotoxicological Risks Report
o
             138   12/30/72   Nussbaim,  S., IEPA     Boice,  R., U.S.  EPA    lEPA's Comnts  on the Migration Pathway          4
                                                                         Assessment Technical Netorandum

             13?   01/00/73   Patterson, R.,         U.S. EPA and IEPA     donthly Progress Report  for December 1772        22
                              Solder Associates
                              Inc.
  r
140   01/05/73   Boice, R.,  U.S.  EPA   Patterson, R.,        U.S. EPA  and  lEPA's  Responses to the              3
                                      Solder Associates     Technical Memorandum on  the Migration Pathway
                                      Inc.                  Assessment Dated October  1772 and the
                                                            Preliminary Screeninq.for Ecotoxicoiogical
                                                            Risks Dated September  1772

141   01/15/73   Patel, 0.,  Ucstoo     Boice, R., U.S. EPA   Oversight of  RI Field  Hork Report. November      83
                                                            1772

142   01/15/73   Patel, 0.,  Neston     Boice, R., U.S. EPA   Oversight of  RI Field  Mork Report, October       64
                                                            1772

143   01/13/73   Hashimi,  A. and       Boice, R., U.S. EPA   Revised Addendum for Additional Landfill Sas     22
                 Patterson,  R.,        and Nussbaum, S.,     Monitoring
                 Solder Associates     IEPA
                 Inc.

144   01/21/73   Elly, CM U.S. EPA    Boice, R., U.S. EPA   Review of CLP Data,  Case  I PRP 7637               7
                                                            (Inorganic)

145   01/21/73   Elly, C., U.S. EPA    Boice, R., U.S. EPA   Review of CLP Data,  Cast  * PRP 7637 (Organic)    87

146   01/22/73   Patei, 0.,  Meston     Boice, R., U.S. EPA   Oversight of  RI Field  Nork Report, December      18
                                                            1772
                                                                   11

-------
              OOCI   DATE       AUTHOR                RECIPIENT              TITLE/OESCRIPTIMI                              PflSES
                     irrr
r
 147    01/26/93    Boice,  R., U.S. EPA   Hashiei,  A., Solder   Facsieile  re;  Additional  Sampling Points and      2
                                       Associates  Inc.       Transects

 148    01/26/93    Boice,  R., U.S. EPA   Milliaes, R., Solder  Letter re: Approval of Addendu* to  the RI/FS      3
                                       Associates  Inc.       Mart Plan, Results of January 21, 1993
                                                             fleeting and Response to Letter Dated January
                                                             29, 1993

 149    01/27/93   Patel,  0., Heston     Boice, R., U.S. EPA   Letter re: Off-Site iligration of Landfill   -     1
                                                             Sas and Addendum to RI/FS dork Plan

 150    01/29/93   Hishm, A. and       Boice, R., U.S. EPA   Letter re: Proposed Source Characterization       3
                 Hilhais, R., Solder  and Nussbaue, S.,     Technical  Netorandu*
                 Associates Inc.       IEPA

 151    02/00/93   Patterson, R.,        U.S. EPA and IEPA     Monthly Proqress Rtport  for January  1993         49
                 Solder Associates
                 Inc.

 152    02/04/93   Boice, R., U.S. EPA   Nilliais,  R., Solder  Letter  re:  Approval  of the RI/FS Work Plan         5
                                       Associates Inc.        Addendum for  Additional  Landfill Sas
                                                             Nonitonng, Along Kith a Response  to the
                                                             Letter  Dated  January  29, 1993

 153   02/04/93   Hashiei, A.  and       Boice, R., U.S.  EPA   Letter  re:  Suep Vent Installations                 3
                 Patterson, R.,
                 Solder Associates
                 Inc.

154   02/08/93   Boice, R., U.S.  EPA    File      '            Conversation Record  re: Proposed Changes to        1
                                                             the Landfill Sas Sampling  Procedures (with R.
                                                             Patterson,  A. Hastuei and  II. Daley, Solder
                                                             Associates)

155   02/08/93   Patterson, R.,        Boice, R., U.S.  EPA   Letter  re:  Modification of Land Sas Probe         3
                 Solder Associates                            Sampling Plan
                 Inc.

156   02/10/93   Boice, R., U.S.  EPA    File                  Conversation Record re: tht Steering              1
                                                             Com t tee's Actions Concerning the Landfill
                                                             Sas (»ith R. Patterson and A. Hashin, Solder
                                                             Associates)

157   02/10/93   Hashiei, A.  and       Boice, R.. U.S.  EPA   Letter  re: (Modifications to the Parameter        30
                 Patterson, R.,        and  Mussbaue, S.,      List for the Third Round Sroundwater Sampling
                 Solder Associates      IEPA                  Event,  nith Analytical Results for the Second
                 Inc.                                        Round of Sroundnater Sampling
                                                                     12

-------
           OOCI   3ATE        AUTHOR                RECIPIENT             TITLE/DCSCRIPTIQ*                             PA5£S
c
 138   02/17/93   Hashiii, A. in*       3oice, R., U.S. EPA   Letter re: Additional  Transects  for Landfill      2
                 Patterson, R.,        and Nussbaui S.,      Sas Investigation
                 Solder Associates     IEPA
                 Inc.

 159   02/17/93   Boice, R., U.S. EPA   Patterson, R.,         Letter re: Clarification  of  Data  Reporting        2
                                       Solder Associates     Requirements and Request  for Intonation on
                                       Inc.                  Data  Generation and  Validation

 160   02/19/93   Boice, R., U.S. EPA   File                  Conversation Record  re: Request for Reduced       1
                                                             ParaMter  List  (nith A. Hashiii and R.
                                                             Patterson,  Bolder Associates)

 141   02/19/93   Hashiii, A. and       Boice,  R.,  U.S.  EPA    Technical  Nctorandue. for Feasible Remedial        17
                 Patterson, R.,        and Nussbaui, S.,      Technologies
                 Solder Associates     IEPA
                 Inc.

 162   02/23/93   Hashiii, A. and       Boice,  R.,  U.S.  EPA    Letter re: ParaMter List Reduction Request       3
                 Patterson,  R.,                              for the Third Sroundnater Sampling Event
                 Solder Associates
                 Inc.

 143   02/23/93   Hashiii, A. and       Boice,  R., U.S.  EPA    Technical Nnorandu*. for the Suip Assessment     83
                 Patterson,  R.,        and Nussbaui, S.,
                 Solder Associates     IEPA
                 Inc.

 164   02/25/93   Nussbaui,  S.,  IEPA     Boice,  R., U.S.  EPA    lEPA's Coinnts to the Modifications to tht       3
                                                            Parameter List for the Third  Round Sround"
                                                            Mater Saipling Event

 165   03/00/93   Patterson,  R.,         U.S. EPA and IEPA     Monthly Progress Report for  February 1W3         6
                 Solder Associates
                 Inc.

166   03/00/93   Hashiii. A.  et  ah,    Boice,  R., U.S. EPA   Technical Nworandui for Source                 258
                 Solder Associates     and  Nussbaui, S.,     Characterization, Voluie I of IV  (Teit,
                 Inc.                  IEPA                 Tables and Figures)

167   03/00/93   Hashiii, A.  et  al.,    Boice,  R., U.S. EPA   Technical Hworandui for Source                 598
                 Solder Associates     and  Nussbaui, S.,     Characterization, VoluM II  of IV  (Appendices
                 Inc.                  IEPA                 A Through E)

168   03/00/93   Hashiii, A.  et al.,    Boice,  R., U.S. EPA   Technical Hetorandui for Source                 639
                 Solder Associates     and  Nussbaui S.,      Characterization, Voluu HI  of IV ( Append u
                 Inc.                  IEPA                 F)
                                                                 13

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DOC*
 AUTHOR
 RECIPIENT
  TITLE/OeSCRIPTIOM
  XX3333ZXS3XUZ3U
 149   03/00/93
 170   03/23/93
 Hashiii, A. (t il.,
 Solder Associates
•Inc.

 Hashiii, A., Solder
 Associates Inc.
 Boice, R., U.S. EPA    Technical feiorandu* for Source                  64
 and Nussbaui, S.,      Characterization, VoluM IV of IV (Appendices
 IEPA                   6 and H)

 Boice, R., U.S. EPA    Letter re: Additional Sas Bonitoring Schedule     1
 171    03/23/93   Hashiii,  A.  and
                  Patterson, R.,
                  Solder Associates
                  Inc.

 172    03/23/93   Boice, R., U.S. EPA
                       Boice,  R.,  U.S.  EPA   Letter re: Reduced Parameter List for Surface    37
                       and Nussbaui,  S.,      Mater and Sediecnt Saiples,  Kith Analytical
                       IEPA                   Results for Surface later and SediMnt
                                             Saeples Collected in Previous Rounds
 Patterson,  R.,         Letter re: Respondents Attempt to Address the
 Solder Associates     Landfill Sas Entry
 Inc.
                                                                                              3
 173    03/24/93
 Hashiii, A. et al.,
 Solder Associates
 Inc.
 Boice, R.,  U.S.  EPA   Letter in Response to U.S. EPA  Letter  Dated
                       February 17,  1993 re: Sroundnater Analytical
                       Data and Oati Validation Results
 174   03/24/93
Hashiii, A. and
Patterson, R.,
Solder Associates
Inc.
Boice, R., U.S.  EPA    Letter re:  Analytical Results for Second
                       Round  Sroundvater Saipling Event
175   03/24/93
176   04/00/93
177   04/00/93
Hashiii. A. and
Patterson, R.,
Solder Associates
Inc.

Patterson, R.,
Solder Associates
Inc.

Solder Associates
Inc.
Boice, R., U.S. EPA   Letter re: U.S. EPA Validation of First Round     1
                      Sroundnater Data
U.S. EPA and IEPA     Monthly Progress Report for (larch 1993
U.S. EPA and IEPA
17S   04/02/93   Boice, R., U.S. EPA   File
179   04/05/93   Boice, R., U.S. EPA   File
Technical Netorandua for Preliminary
Migration Pathway Screening,  Revised

Conversation Record re: Reduction in    .
Parameters for the Third Round of Sround
Mater Sampling (nth A. Hashiii,  Solder
Associates and S. Nussbaui,  IEPA)

Conversation Record re: Data  Validation
Addressed in 3/24/93 Letter  («ith A. Hashiei
and R. Patterson, Solder Associates)
180   04/13/93
Hashiei, A. and
Patterson, R.,
Solder Associates
Inc.
Boice, R., U.S. EPA   Letter re: Reduced Parameter List for Surface
and Nussbaui, IEPA    Mater and Sedieent Saiples
37
                                                       14

-------
OOCI   OflTE
                 AUTHOR
RECIPIENT
Z333SS33X
 T!TL£/D€SCRIPTIO*
P«6€5
181   04/16/93   Patel, 0., fcston
182   04/22/93   Nussbaua), S., IEPA
                                        Boice,  R.,  U.S.  EPA   feston's Reviev Coeamts on the Source
                                                             Characterization Technical Hetorandua)

                                        Boict,  R.,  U.S.  EPA   lEPA't Review CotMfttf on tin Source
                                                             Characterization Technical Nttorandue
 183   04/24/93   Boice, R., U.S. EPA    File
 184   04/28/93   Boice, R., U.S. EPA
                                       Patterson, R.,
                                       Solder Associates
                                       Inc.
185   04/30/93   Patel,  0.,  Heston
                                       Boice, R., U.S. EPA   Heston's Review CotMflts on  the Hiqratio*
                                                             Pathway Ass«sst«nt  and Feasible Rewdial
                                                             TechnoloqiN  Technical HetoranduM
186   OS/12/93   Boice, R., U.S. EPA   File
187   OS/14/93   Boice,  R.,  U.S.  EPA
                                       Patterson, R.,
                                       Solder Associates
                                       Inc.
Conversation Record rei Landfill  Sas Problet
(Nith A.  Hashili, Solder Associates)

Hetorandui re: U.S. EPA's Conents  on the
Suip AssessMtt Technical Netorandui Dated
February  1993, the Feasible Retedial
Technologies Technical  Netorandui,  and  the
Prelicinary Pathway Screening  Technical
Betorandui
                                                                      13
                     Conversation Record re: Baseient Monitoring       1
                     Results (with A. Hashili and R. Patterson,
                     Solder Associates)

                     Letter re: U.S. EPA and lEPA's Approval  of       13
                     Source Characterization Technical  Hetorandui
                     and Conents for Suidance in Preparing Future
                     Documents
                                                                      4
                                                                     41
                                                       IS

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                              U.S.  EPA  ADMINISTRATIVE  RECORD
                                       GUIDANCE  DOCUMENTS
                                 YEOMAN  CREEK  LANDFILL  SITE
                                       WAUK:EGAN.  ILLINOIS
                                             UPDATE  *2
                                               05/03/95
                                    RECIPIENT
                     TITlE/:E3CRIP*;uN
                                             PASES
  ;   00/00.37   :Vta-, •:. m
                Tn63;<3. J.
     00/00/34   K;i5roush, R.,  at
                il:
 3   04/24/35   U.S. EPA/Versir Inc.  U.S. EPA
 4   00/00/86   'J.S. EPA/OURS        U.S. EPA
 5   04/00/96   U.S.  EPA/QRD         U.S. EPA
                     ;,.,.,_ ir:::!?: 'E.'ii.j:::- of !*odei3 'cr       5
                     3radi:tir.j 'sr'sstrul  r::; Chjin  Bsravisr of
                     lar.cijiatics1 itrvirr.  ;•::. "echrci.l

                     J::rral Art::ie: '^ejiti :i:l::ati3as :'  2,      «T
                     3,  7, a-Tet'acMsradiieruaezoxin (TCDD! Cant-
                     aiiratisr sf Residsrtial 3::i'  (Journal of
                     Toxicology ana  Er.vircnienui He*aith)

                     Excerpts Fraa:  Exoosure Assassient far          3
                     ?;iycMo.r;na*9d  sishenyls ^"Ss!.
                     ?ciychicrnatsj  C:ia"2Dfura«s (PCDFs), and
                     ?clr:!>::r:";itsd  ]::er:3d;cx:ns IPCDDs)
                     ^=;?j5s; wuri^;  Trirsfariir Fire (Final
                     Report)

                     Excerpts Fru Technical  Support Oocuaent:         2
                     Land Applications and Distribution  and
                     flartetinq  af Sevagc Sludge

                     Hydrolaqic Evaluation of Lirdfill perfsriance   237
                     (HELP) Model (Update)
 4   00/00/88   Travis, C. and Aris,
               A.
 7   10/11/88   Federal Register
 8   00/00/39   Pausttnbach, D.
 9   32/00/91   [J.S.  EPA/ORD
'J.S.  EPA
Journal Article: "Bioconcentration  af            4
Qrqanics in Beef, Silk,  and Vegetation*
(Environ. Sci. Techncl.l

J.S.  EPA Rules and Regulations:  Statistical      29
Methods far Evaluating Srcwd Mater
Monitoring Data Frot Hazardous Maste
Facilities (Vol. 53, Ko. 1961

Excerpts Froa Journal Article: 'Dioxin in        2
Sludqe  Used for Mine Reclamation*

rac*ir:cal Suidascs:  Radon Rasistant            47
Cinitnction Tecfcnisues  fcr fen  Residential
1?   05/01/91   M.S. epfl/GP.3
'J.S.  EPA
:sn-!»^ Pui5l::a:;:n:  Jasisr jnd  Cor.structior    203
of -W.A / CERCLA Final C:vjrs
                                    .5. Eri
                    Statistical inalYsis of :':.rd Xatar           H3
                    *:rit:-:.".: Data at "M ra:::it:ss :Ai:s«dui

-------
                                                            Envirorientai  Iicact,  Biccfieiical  and  Tex;:
                                                            'asucnses  a->d  Imitations  for  Risk
                                                                     t'  ;*9X4=  441 Jniversitr)
13   07;'TO/93   Silbert. R., Batslls  3ai3!», ?.,           Lettar  igjo^t:  Descriation  of  a  Recoiitndad      43
                pjcif:: ''c'tiwe^t     r-stssa*.::           Prccsss  ^:r  Iioieientation  by  Rocky Flats
                .ib:'a::r:3s          *a-a:;j=-t ??'-vic=s1  °'.3.-t  t: C:a;i-a  Eavironientai Restoration
                                      :-:.                 5its 4.-i;yt;:al Results  cf  Saioled
                                                           -.ivi'ori8'%:al 'e1:a  Ostained :r,  0;era51e
                                                           Lnit:  :•: 5aC«-:'C!;rfi  C:r:=-trations

14   0?'"j/?3   'J.S. EPA/SSrS         '-.:. ::^              A:r/Sucerfuri S'at::^al T8c'in:cai Suidancs       16T
                                                           Study Series: Gotisrs for Developing and
                                                           E/aiuatirg ^itig3t:;n Strategies for Indoor
                                                           Air Ii:acts at CERCLA Sitss

15   09/00."'3   'J.S. EPA/GRD          J.3. E1-              'schrica! Saidafi-9 Socunnt: Quality            324
                                                           Assurance ir: aUiI:ty lartrol for Kaste
                                                                   e-t :K:k:;9S it?A/400/R-93/182l
ia   09/01/^3   Cruic, K.. I".r        'J.:.  Er-              Retort: Evauatior.s of Reccwendations by  Or.     19
                raiser                                     Richard gilbert for Coiparing Environiental
                                                           Restoration Site Results to Background
                                                           Concentrations

17   00/00/94   Safe, 3.                                    Journal Article: 'Polychlorinated Biphwyls       63
                                                           (PCSs): Environiental Iioact, BiochMical  and
                                                           "oxic Resoorses, and Iiplications .for  Risk
                                                           Assessient* (Critical Reviews in  Toiicoloqr)

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