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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
-------
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
-------
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,
-------
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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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
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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?"
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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
-------
;: ."::'" «.::;*;;. :., 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
-------
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
-------
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^:
-------
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
-------
"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
-------
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«
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. 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
-------
:::« , ;•«" :/-:? 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
-------
.:" :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
-------
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
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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
-------
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
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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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