United States
Environmental Protection
Agency
Office of
Emergency end
Remedial Response
EPA/ROa'ROS-83/001
November 1983
Superfund
Record of Decision:
A & F Materials-Greenup
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TECHNICAL REPORT DATA -
(P/tlllt 'tad Ins/fllc/ions 9n the ,e.ent befo,e com,,/e/ing)
I. REPORT NO. I~' 3. RECIPIENT'S ACCESSION NO. , ~
EPA/ROD/R05-83/00l
4. TITLE AND SUBTITLE S. REPORT DATE
SUPERFUND RECORD OF DECISION: 11/23/83
A & F Materials - Greenup Site, IL 6. PERFORMING ORGANIZATION CODE
7. AUTHORCSI B. PERFORMING ORGANIZATION REPORT NO.
8. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT ~O.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COI/ERED
U.S. Environmental Protection Agency Final ROD ReDort
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
115. SUPPLEMENTARY NOTES
16. ABSTRACT
The site, a defunct waste solvent reclaiming/processing facility, is located
(;m three and three-quarters acres of land in Greenup, IL, and includes thirteen
steel storage tanks containing mixtures of waste oils contaminated with PCBs and
organics, sludges, spent caustics, spent acids, contaminated water and waste pro- "
ducts. The tanks have a history of failure, creating a significant threat of
hazardous substance release. In addition, the. site includes four storage lagoons
of contaminated sludge and soil which have a history of overflow problems.
The site is underlain fy ten. feet of silty material with a high permeability;
beneath this silt layer lies a sand and gravel aquifer which has been contaminated.
The site has a pronounced slope toward a river, is in a flood plain, and includes
porous soil and high ground water table.
The cost-effective Initial Remedial Measure (IRM) selected for this site includes:
off-site transportation and disposal of all contaminated bulk liquids, oils and
drums at a RCRA-approved facility. Additional actions will include a cooperative
agreement to conduct an RI/FS for soils, sludges and ground water contamination,
and the preparation of another ROD to address remedial actions necessary to mitigate
problems caused by the remaining contaminants. The capitol cost of the IRM is
esti~t~d to be $111,100.
'.
17. KEY WORDS AND DOCUMENT ANALYSIS
a> DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI field/Group.
Record of Decision
A&F Materials - Greenup, IL
contaminated media: gw, soil, tank wastes
Key contaminants: oils, solvents, PCBs,
chloronated organics, spent acids and
caustics, metals, inorganics
lB. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Report) 21. NO. OF PAGES
None 22
20. SECURITY CLASS (T/lis pagt) 22. PRICE
None
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E'A 1'- 2220-1 (R... 4-77)
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e.
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11, ABSTRACT
Include a brief (200 words or IclS) faclual summary of Ihe mosl sillnilkanl mfurmalilln "UII!".n,'" III II", "'I'"", II ,h,' "'1''''' ,""I""" a
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17, KEY WORDS AND DOCUMENT ANALYSIS
la) DESCRIPTORS. Select from Ihe Thegurus of Enginecrir.. ~nd Seic.lIIfi<' Term.. Ihe pruper auI"..rll"" I"ru" Ihal IlIenlily Ih,' n,ajm
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(c) COSA TI HELD GROUP. Field and 1I'0up assilnmenls ~re 10 be laken from Ihe 1965 ('OS"'d' Suhl",'1 ('al"~"'y Lisl. Sine,' Ihe nla.
jority of doc:umenls are multidisciplinary in nalure, the Primary Held/Group a'Mgnmenlf,' "..II be '1''''",11\' "i""l'hne. arca ."1' human
endeavor, or Iype of physical object. The applicalionh) will be cru..-refereneed wilh ""'unu,,ry l,dll'l ;r""I' ""'I'"lI1enls Ihal "',II 1'"11,,..
the primary poslingls), . '
18. DISTRIBUTION STATEMENT
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RECORD OF DECISION
Initial Remedial Measure
SITE:
A&F Materials, Greenup, Illinois
ANALYSES REVIEWED:
I have reviewed the following documents describing tl e analysis
of cost-effectiveness of remedial alternatives at th~ A&F
Materials - Greenup site:
- Cost estimate for Remedial Action at A&F Materials,
Final Report for Region V, U.S. EPA, GCA/Technology
Division, May 1982,
- Evaluation of Initial Remedial Measures, EPA October, 1983.
- Staff summaries and recommendations.
DESCRIPTION OF SELECTED OPTION:
- Removal and off-site disposal of all contaminated liquids
from tanks
Removal" and'off-site disposal of all hazardous waste in drums
DECLARATIONS:
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the.
National Contingency Plan (40 CFR Part 300), I have consulted
with the State of Illinois prior to determining theappropriat(
remedial action. I have determined that off-site disposal of
the liquid contents of the tanks and the drums is a feasible
and cost-effective remedial action necessary to limit a threat
of exposure to a significant public health and environmental
hazard. I have also determined that the action being taken is
in balance with resources available in the Trust Fund and the'
need to respond at other sites. In addition the chosen remedy
complies with section 101(24) of CERCLA qecause off-site disposal
is more cost-effective than potential on-site actions.
c ~
~~ ~--"""\ ~~
~
'J " "1
l. ' '- .;
tDate
Lee M. Thomas
Assistant Administrat'or
Office of Solid Waste and Emergency Response
. ,. ~ '~": to..,.,
,t1I'\'~"'~1 ,.
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EVALUATION OF INITIAL REMEDIAL MEASURES
Site Name:
A&F Materials
Site Loeation: Greenup, Illinois
I .
Background
The A&F Materials site is located on three and three quarter
acres of land on West Cumberland Street in Greenup, Illinois.
Thirteen steel storage tanks contain a mixture of waste oils
( contaminated with PCBs and organics), sludges, spent caustics,
spent acids, contaminated water and other waste products and
have failed on several occasions releasing their contents.
The tanks have inadequate foundations and are presently
tilted at about a 5 to 10 degree angle from vertical. The
histo~y of past tank failure and poor foundations to support
.the tanks is creating a significant threat of hazardous
substances release. Multiple tank failure could result
since the failure of one tank could cause the failure of
adjacent tanks. Drainage from the site reaches the Embarras
River by a ditch along the Illinois Central Railroad tracks.
The site has a pronounced slope toward the Embarras River
and is in the river floodplain. The City of Newton
periodically withdraws drinking water from the Embarras
River downstream of the site.
The site is underlain by 10 feet of silty material with a
perrneabil i ty of 3xlO -Scm/sec. The s.and and gravel aqui fer
which has been contaminated, is located beneath this silt
layer. The site is located on a hillside which discharges
runoff from rainfall directly onto the hazardous substances.
Operations at the site began during the Spring of 1977 and
were originally intended to reprocess waste oils and sludges
from various generators. Four storage lagoons became filled
by March 1978 and began to overflow, contaminating the
environmental pathways leading to the Embarras River. Samples
of sludge, oil, waste and water have been collected at the
site on at least ten separate occasions by the State of
Illinois and U.S. EPA between May 1978 and March 1983.
Ground water monitoring wells which show PCB contamination
were installed during August 1981. The contamination has
been calculated to be moving toward the Embarras River at a
veloci ty of over.j..2,? ft/day. Poly~hlorinated biphenyls.( 33
ppm) have been found in the tanks. Other contaminants, have
been found in significant concentrations in on-site soils
and liquids including pyrene (23 ppm), flouranthene, (24 ppm),
phenanthrene/anthracene (12 ppm), acenaphthlene (.4 ppm),
napthalene (20 ppm), phenol (226 ppm), trichloroethylene
(.32 ppm), toluene (3ppm), benzene (2.7 ppm), iron (4800 ppm),
aluminum (11,000 ppm), cadmium (3 ppm), chromium (29 ppm),
copper (140 ppm), lead (96 ppm), zinc (760 ppm) and dicyclo-
. pentadiene (1200 ppm). Although there is no specific data on
other contents of tanks, in addition to PCBs, the.contents
are expected to include many of the materials found elsewhere
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The site presently contains about 153,000 gallons of
contaminated liquid waste, 16,000 gallons of contaminated
oil, 800,000 gallons of contaminated sludge and soil, and
20 drums of unknown contents.
II. State Activities
An operating permit requiring no discharges from the site
was issued by the Illinois Environmental Protection Agency
(IEPA) on June 23, 1977. The IEPA has inspected the site
on at least 20 separate occasions and continues to monitor
conditions at the site. Administrative enforcement actions
were initiated by the IEPA beginning in 1979, but resul~ed
in little or no action by the site operators. Several
lawsu~ts have subsequently been initiated by the State of
Illinois, the Village of Greenup and residents of Greenup.
On May 31, 1979, Village residents filed a Complaint in
Circuit Court which resulted in a Temporary Injunction
dated June 14, 1979, requiring that no additional wastes
b~ accepted by A&F Materials. A p6rtion of the facility
was sold to Genet Refining and Recovery to apparently
circumvent the court order, and the facility continued to
operate. The Village of Greenup filed Complaints against
A&F Materials and Ken Ault on June 10 and June 16, 1980,
resulting in a Preliminary Injunction being issued on June
23, 1980. This injunction prevented wastes from being
accepted at, or removed from the site ~thout approval by
the Village. The suit was joined by the State of Illinois
and required removal of all wastes and restoration of the
site. A default judgement was entered against Ken Ault and
A&F Materials on October 21, 1981, requiring site cleanup.
No wastes have been received at the site since June 1980.
. .
III. Federal Response Activities
Based on the inspections conducted by IEPA and a detailed
site investigation conducted by U.S. EPA in March 1980,
Federal action was initiated in June 1980, pursuant to
Section 31l(c) of the Clean Water Act. Among the actions
taken were the lowering of the level of wastes in the pits,
diking, trenching, cleanup and removal of on-site and off-
site wastes. About $240,000 was expended for site cleanup
under Section 311.
.
In May and December 1982, expenditures of about $100,000
were required from the Fund for immediate removal actiqns
to lower the level of waste in the lagoons. During March
1983, all of the liquid was removed from the lagoons and
a temporary cap was placed on the consolidated sludges.
This effort required an additional expenditure of approxi-
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3
I
IV. Federal Enforcement
A Federal lawsuit to bring ab')ut site cleanup at Greenup
was initiated by the filing 0 a Complaint on September 3,
1980, pursuant to authority u,der the Resource Conservation
and Recovery Act, 42 U.b.C. S.:tions 6901, 6973, and the
Clean Water Act, 33 U.3.C. Sec~ions 1251, 1311, 1319 and
1321. The Complaint alleged that the handling, treatment,
storage and disposal of solid and hazardous wastes at the
facility presented an imminent and substantial endangerment
to health and the environment. The Complaint also cited
the defendants for violation of Section 311(e) of the CWA,
as evidenced by overflows from the pits. The original
Complaint did not include generators as defendants.
Letters to all known generators, dated November 3, 1981,
were sent by the Assistant u.S. Attorney requesting their
participation in site cleanup. Negotiations have continued
since that time, but have failed ~o result in an agreement
for site cleanup. Demand letters to the generators for
the required remedial action were sent by the Department
of Justice on August 18, 1982. No commitment by the
generators has been made by the September 10, 1982, deadline
provided in the Demand Letters. The generators were
subsequently added to the lawsuit on February 14, 1983.
V. Evaluation of Alternatives~
The following reports have been completed as part of the
investigation of remedial action alternatives:
"Remedial Action Master Plan, A&F Materials," Weston,
February, 1983.
Inc.,
"Cost Estimate for Remedial Action at A&F Materials, Final
Report," GCA/Technology Division, May 1982.
"Ground Water Contamination Potential for the A&F Materials
Site in Greenup, Illinois," E&E Inc., revised June 1982.
"Ground Water Contamination of the A&F Materials Site in
Greenup, Illinois E&E Inc., revised June 1982.
"Meeting on Chemical Fixation Alternative for Sludge and
Sediment Material at A&F Materials, Greenup, Illinois,"
Region V, U.S. EPA, August, 1982.
"Interim Status Report for the Hazardous Waste Sampling at
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"Description of Greenup, Illinois, Facility 6f A&F Materia
Region V, U.S. EPA, January 5, 1982,
"The A&F Materials, Greenup, Illinois, On-Scene Coordinators
Report," Region V, U.S. EPA, May 1982,
"The A&F Materials, Greenup, Illinois, On-Scene Reports,"
Region V, U.S. EPA, 1980,
The GCA report evaluated remedial alternatives to deal with
the site conditions that existed prior to the immediate
removal actions. This analysis evaluated six alternatives
to deal with lagoon and tank liquids, waste oil, sludge and
contamina~ed soil, and final site closure.
Before the remedial action coula be approved and implemented,
the immediate removal actions described in section III were
conducted. The wastes remaining on-site include about 153,000
gallons of contaminated liquids in tanks, 16,000 gallons of
contaminated oils in tanks, 20 drums with unknown contents
and 800,000 gallons of lagoon sludges and contaminated soils.
EPA screened the original GCA alternatives. to evaluate the
elements of e~ch alternative that dealt with the remaining
site contaminants in tanks and drums. The contaminated lagoon
sludge and soils were not included since the State is
evaluating alternatives for those wastes in their on-going
RIfFS. .
The cost-effective analysis is summarized below:
1. Organic Contaminated Liquids in Tanks: The only
technologically feasible alternatives for handling.
contaminated liquids were on-site treatment with activated
carbon adsorption and off-site transport and disposal
at an approved treatment facility. On-site solidification
of liquids contaminated with organics has not been
proven reliable. The site hydrogeology which consists
of porous soils and high ground water (10 feet or less
below the surface) makes landfilling of waste material
unacceptable. The estimated cost for the two feasible
alternatives are:
.
Liguid Disposal
Estimated Cost
On-site treatment
$128,500
Off-site treatment at a
RCRA approved facility
$ 63,000
Therefore off-site disposal is considered the cost-effective
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2. Contaminated Oils in TanKS: On-site treatment alternatives
for contaminated oil, such as incineration or solidification
were not cost-effective. On-site incineration of the
relatively small volume of oil would require an extremely
large capital cost for incinerator construction. EPA's
mobile incinerator is currently undergoing RCRA permit
approval: however the estimated cost for mobile incineration
is $1 million making this option significantly more
expensive than off-site disposal. Methods for solidification
of organics and oils have not been proven reliable for
long-term on-site disposal. The only feasible,
reliable, and cost-effective alternative was off-site
disposal at an approved facility.
3. Dr~ms: The only technologically feasible and reliable
method of dealing with the on-site dru~s was by transport
and off-site disposal at an approved facility. The low
number of drums (approximately 20) and the unknown contents
made the cost of constructing ~nd maintaining an on-site
hazardous waste disposal facility prohibitive. In
addition the hydrogeology of the site made landfilling
unacceptable. Also the site is either in or adjacent
to the Embarras River floodplain. The estimated cost for
off-site disposal is $4,000. .
VI. Community Involvement
In accordance with the Community Relations Plan which has been
. developed for the A&F Materials site, the RAMP, various reports
on ground water contamination and a Fact Sheet was distributed
to the community on August 11, 1983. The Fact Sheet (see
Attachment 2) described the proposed Initial Remedial Measure
and requested comments to be submitted by September 6, 1983.
On September 1, 1983, a public meeting was held with the local
residents in Greenup to describe the CERCLA program, provide a
briefing on the site background and to discuss the proposed
Initial Remedial Measure as well as the RI/FS being conducted
by the State.
Questions and comments by the community provided at the meeting
and in correspondence to the Region are summarized below.
Comment
Why not transport the entire tanks off the site with the
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Response
The storage tanks on the A&F site are not technically
suitable for over-the-road use. They could not meet
Department of Transportation regulations. They also.
leak.
Comment
Will there be terrible odors, as occurred when the A&F
site was operating? If so, are they toxic?
Response
There will be odors. The chemicals in the tanks give off
a strong odor, but this odor does not necessarily indicate
toxicity. Equipment will be utilized to minimize the
release of vapors and air monitoring will be conducted to
detect significant releases of contaminants during the
tank pumping. The Center for Disease Control has reviewed
the data on the tanks and believes the project can be
completed without unacceptable releases of contaminants.
The Center will be available to review the air monitoring
data during the pumping. .
Comment
r-.:J<
Why not dismantle and get rid of the tanks now?
Response
The tanks contain contaminated'sludge material which cannot
be pumped. Once the liquids are removed the potential for
releases of contamination to the environment are minimized.
The sludge left in the tanks, as well as the tanks themselves,
will be evaluated by the State as part of the RI/FS and
can be handled along with the sludge left in the lagoons.
Handling all of the sludge remaining at the site at the
same time is more cost-effective.
In summary, the community concurs in the selected
alternative for, the...;IJ1itial Remedia.l...~easure~ however,
they feel the entire site surface should be cleaned up
now rather than wait for the investigation to be
completed.
VII. Recommended Alternative
The cost estimate br~akdown for the recommended Initial
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Task
Estimated Cost
- Prepare plans and specifications
~orInitial Remedial Measure
$
8,400
- ,.'ff-si te treatment and disposal
'~f tank liquids and oils
$ 81,000
- Off-site disposal of drums
$
$
4,000
- Contract management and supervision
7,600
Subtotal
10% Contingency
S101,000
$ 10,100
Total
$111,100
Alternative technologies will also be considered for specific
on-site wastes. For example off-site incineration of solvents
and contaminated oils will be evaluated to determine if .
incineration cost would not significantly increase total disposal
costs.
VIII.
Additional Action
The State of Illinois has entered into a Cooperative
Agreement with EPA to accomplish the following:
- Remedial Investigation/Feasibility Study
sludges and ground water contamination
- Community Relations Program
- Project Management
for soils,
u.S. EPA will take the lead in accomplishing the Initial Remedial
Measure. The required State assurances for implementation of
the Initial Remedial Measure have been incorporated as a special
condition to the Cooperative Agreement. The following actions
are necessary to implement the IRM:
II': .7;, EQ..;R,I;cemt;:!,nt releqp"~"
- Approve proposed remedy
- Approve procurement request
- Design/Implement IRM
.....\~ .,~9.WPE/OEC
AA OSWER
AA OSWER
EPA/REM/FIT
October 24, ~983
October 31, 1983
October 31, 1983
Nov 1983-Jan 1984
Another Record of Decision will be prepared following
completion of the State's RI/FS. That decision will address
remedial actions necessary to mitigate problems caused by the
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IX.
RCRA Coordination
The proposed Initial Remedial Measure will not require
on-site treatment, storage, and disposal of hazardous wastes.
Therefore, there are no issues involving the consistency of on-
site actions with RCRA. Off-site disposal of wastes will be in
accordance with the appropriate RCRA regulations for the
transportation and disposal of hazardous wastes. This will
include manifesting of wastes and shipment to a RCRA approved
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A & F Materials/
Greenup
Fact ShetH # 1
Cleaning Up an
Dlegal Hazardous
. Waste Site
. .
@
IlIml">
EnvirunJnl'lllal
Protection Aj.{t'm'y
2:.!Ofl t'hurrhlil Hoad
~pTlnj.{fj!.'ld. Illin.,,> lj:lilll;
September 19/\3
Superfund Program
Background
A & F Materials. Inc. operated as a waste
solvent reclaiming/processing facility be-
tween 1977 and 1980- When the site was
operating, waste materials were transported
to the site by truck, temporarily stored in
unlined lagoons. and processed in the building
at the site. By-products were stored in above
ground storage tanks. Liquid alum. No. 2.5
fuel oil and fire retardant chemicals were pro.
duced for resale.
Greenup residents complained to the
Illinois Environmental Protection Agency
(lEP AJ about the A & F Materials operation"
as early as March 1977. IEPA inspectors
verified permit violations and the discharge of
contaminated water into the nood plain of the
Embarras River.
In the sprIng of 1979 city residents filed a
complaint in circuit court. A temporary
injunction was issued requiring A & F
Materiels to cease reclaiming operations.
Waste liquids continued to be delivered to the
site even though the lagoons were full. A year
later another injunction was issued closing
down all operations and ordering all deliveries
and discharges to stop.
The problem
Storage ponds at the A & F site were filled
by March 1978 and had begun to overflow.
During 1979 hundreds of thousands of gallons
of waste oil sludge contaminated the nood
plain during flood stages of the river.
Thereafter the lagoons continued to overflow
and contaminate the area.
What has been done about the
problem?
There were five emergency remedial actions
at the site between June 1980 and March
1983. Oil spills have been cleaned up. berms
have been repaired and raised. and
wastewater treated and discharged. In March
1983 the sludge in the lagoons was consoli-
dated and the lagoons covered to prevent any
further overflow.
Since 1978 U.S. EPA has hired independent
contractors to sample the soil. sludge and
water on and around the site. After analyzing
these samples and assessing the potential for
continued discharge into the surrounding
environment. U.S. EPA listed the site on the
Superfund national priority list.
What kinds of hazardous waste have
been found at the site?
The lagoons have contained a mixture of
waste oils. sludges. spent caustics. spent acids
and contaminated water, along with waste
products. Polychlorinated biphenyl (PCBs)
are also present. In addition. U.S. EPA and
IEP A analyses have identified significant
levels of heav? metals and dicyclopentadiene.
toluene. xylene. naphthalene. "tyrene and
benzene. These solvt:nts were mixed with the
waste oil when delivered to the reprocessing
plant. The storage tanks contain similar
waste material.
Is the water safe to drinl{?
Drinking water for the city of Greenup is
provided by wells across the Embarras River
from the A & F 1
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UNITED STATES ENVIRONMENTAL PROTECTlON AGENC'r'"
. I
REGION V
OA T'E: SEP 2 4 1982
Meeting on Chemical Fixation Alternative for Sludge
and Sediment Material at A&F Materials, Greenup, Illinois
Nonnan Niedergang ~~". ?1~. " --,
On-Scene Coordinator . '~ ~
SUBJECT:
FrlOM=
TO:
File
A meeting was held in Chicago, Illinois on August 5, 1982 to discuss the
subject. A list of attendees is attached. Dr. Philip Malone and Dr. Larry
Jones are authors of USEPA Publication No. SW-872, entitled, "Guide to the
Disposal of Chemically Stabilized and Solidified Waste." dated September 1980.
Robert Cibul ski s is a member of USEPA I S Emergency ResJjonse Te_.
Prior to the meeting Drs. Malone and Jones and Mr. Cibulskis-reviewed the
following document, as well as numerous photographs of the sites.
. b.
a.
Description of Greenup, Illinois Facility of A&F Materials,
USEPA, Region V, January 5,1982' (includes summary of all
analytical data).
Description of Olney, Illinois Facility of A&F Matericrls,
USEPA, R~gion V, January 5, 1982 {includes summary of all
analytical data}.
Closure Plan - Waste Oil Surface Impoundment, Aluminum Company
of Arneri c a I Da ven port Wo rI< s. Ma rch 1 I 1982.
d. . Topographic map of Greenup Site, prepared by E&E Inc.,
March 1982.
c.
In addition, the following description of the Greenup site conditions ~s
pro vi ded:
a.
The Greenup site is partially located within the lOO-year
f100dplain of the Embarras River,
. ...,-.
b.
The site is underlain by 10 feet of clay-silt with a
permeability of 3 x lO.Scm/sec; the sand and gr'avel
aQuifer which has been contaminated, is located beneath'"
the clay-silt layer,
..
The facility is located on a hili-side which discharge.s
rai nfall-runoff di rect ly onto the site,
The sludge is characterized as an oily, organic, spongy
materia 1.
t
c.
d.
...
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.
.
.
..
. .
Based on a review of the above information, Drs. Malone and Jones concluded
the following: .
a.
Poor site conditions, in general, are an adequate basis to
exclude on-site chemical fixation with on-site ultimate
disposal. The site conditions existing at the Greenup
site are not appropriate for further consideration of
on-site fixation and disposal of the contaminated sludge
and sediment materials. '. -
b.
.1
Only two known (i rms i ~ the country are experimenting wi th
processes to provide chemical fixation of organic sludges.
No field demonstration of chemical fixation of organic
51 udges has 'been attempted.
c.
The pr~cess used by Alcoa at Bettendorf, Iowa, on similar
types of sludges, was not acceptable for several reasons:
1 .
The fixative agent contained significant amounts of
sulphur trioxide, wh.i ch readi 1y converts to sulphuric
acid in the field, which would tend-to mobilize
contami nant s,
2.
Phenols were found to be readily released from the
so 1 i d1 f1 ed s 1 ud ge s,
3.
Oua1ityccontrol during the fixi~g process was probably
inadeQuate, based on the information provided. Oils
and moist organic materials were noted at the bottom
of so;1 borings taken in the field of the fixed
sludges, and
":".;J
4.
The EP-Toxicity test is not an acceptable test as the
sole indicator of the potential for release of con-
taminants from fixed material. Other tests such as
the Maximum Possible Concentration Test and the Uniform
Leaching Procedure sho~ld have been performed.
d.
Chemical f1 xation, then transportation to an off-site disposal
facility close to the site, may be a feasible cost-effective
a lternat i ve.
. ..,.
Based on the above conclusions, on-site chemical fixation of the Jludg~
and sediment materials at the Greenup site of A&F Materials is not con-
sidered to be a reliable alternative worthy of detailed laboratory studies
and field experiments. Bob Cibulskis concurred in ,this assessoent.
t
Attachment
.... .
-------
. .
, .
, ~
NAME
Eileen Bloom
Nann Ni ede rga ng
Philip G. Halone
Larry W. Jones.
R. W. Cibuhlds
Bil 1 Busch.
R. E. Dieffenbach
Robert Mue 11 er
Howard O. Chinn
Tom Borecki
"
ATTENDEES LIST
A&F Materia 1 s
Chemical Fixation Alternative
August 5, 1982
ORGANIZATION
Attorney, USEPA, Regi on V
OSC, USEPA, Region V
U.S. Army Corps of Engineers, WES
U.S. Army Corps of Engineers, WES
USEPA/ERT, Edi son, N.J.
IEPA, Springfield, IL
. USEPA, Chi ca~o, I L
Attorney, IL Atto~ey General
Engineer, IL Attorney General
Engineer, IL Attorney General
,.
... . ,. - ...
. .r'
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~----
---- ----- -----+-- ------~-
TECHNICAL REPORT DATA
(Please read Instructions on the revene before completing)
1. AEPO"T NO. 12. 3. RECIPIEN.T'S ACCESSION NO.
EPA/ROD/ROS-83/00l
4. TITLE AND SU8TITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION: 11/23/83
A & F Materials - Greenup Site, IL 6. PERFORMING ORGANIZATION CODE
4.
,. AUTHORISI 8. PERFORMING ORGANIZATION REPORT NO'
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT 1)10.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M street, S.w. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800100
15. SUPPLEMENTARY NOTES
18. ABSTRACT
The site, a defunct waste solvent reclaiming/processing facility, is located
on three and three-quarters acres of land in Greenup, IL, and includes thirteen
steel storage tanks containing mixtures of waste oils contaminated with PCBs and
organics, sludges, spent caustics, spent acids, contaminated water and waste pro-
ductS. The tanks have a history of failure, creating a significant threat of
hazardous substance release. In addition, the site includes four storage lagoons
of contaminated sludge and soil which have a history of overflow problems.
The site is underlain by ten feet of silty material with a high permeability;
beneath this silt layer lies a sand and gravel aquifer which has been contaminated.
The site ha's a pronounced slope toward a river, is in a flood plain, and includes
porous soil and high ground water table.
The cost-effective Initial Remedial Measure (IRM) selected for this site includes:
off-site transportation and disposal of all contaminated bulk liquids, oils and
drums at a RCRA-approved facility. Additional actions will include a cooperative
agreement to conduct an RI/FS for soils, sludges and ground water contamination,
and the preparation of another ROD to address remedial actions necessary to mitigate
problems caused by the remaining contaminants. The capital cost of the IRM is
estimated to be $111,100.
11. KEY WORDS AND DOCUMENT ANAL YSIS
a. DESCRIPTORS b.IDENTIFIERSiOPEN ENDED TERMS C. COSATI Field/Group.
Record of Decision
A&F Materials - Greenup, IL
Contaminated media: gw, soil,
Key contaminants: oils, solvents, PCBs,
chlorinated organics, spent acids and.
caustics, metals, inorganics
18. DISTRIBUTION STATEMENT 19. SECURITY CL.ASS ,T/lis Reportl 21. NO. OF PAGES
None 22 i
20. SECURITY CL.ASS iTlI;S pagel 22. PRICE
None
EPA Po,,,, 2220-1 (Rn.4-77)
-------
. /.,:
. ,., -::
UNITED ST A TES EN VIRONMENT AL PROTECTION AGENCY
WASHINGTON, D.C. 20460
~._? :'
OFFICE OF
SOLIC WASTE AND EMERGENCY RESPONSe:
MEMORANDUM
fROM:
,Initial Remedial Measure for A&f Materials-Greenur
William N. Hedeman, Jr., Director\D~ ~~'\)u..~
Office of Emergency and Remedial Response
Site
SUBJECT:
TO:
Lee M. Thomas, Assistant Administrator
Office of Emergency and Remedial Response
Background
On June 23, 1983, EPA awarded $277,272 to the State of
Illinois to undertake a Remedial Investigation/feasibility Study
(RI/fS) at the A&F site. The Stat~ has selected a contractor to
conduct the RI/FS and work is expected to start in November or
early December. In 1982-1983 EPA also expended approximately
$290,000 of immediate removal funds to remove liquids and
temporarily cap four lagoons. The site presently contains
approximately 153,000 gallons of contaminated liquid waste in
tanks, 16,000 gallons of contaminated oil in tanks, 800,000
gallons of contaminated sludge and soil, and 20 drums.
The State is taking the lead on the RI/fS that will evaluate
remedial actions to deal with contaminated sludge, soil, and
ground water. In order to alleviate the threat posed by the
contaminated liquids and oils contained in the tanks and drums,
an Initial Remedial Measure (IRM) has been proposed by Region 5
and the State. The State has requested that EPA take the lead
in implementing this IRM. The estimated cost for removing and
disposing of the...drums and tankwC',antents is $111,100. The
attached Record of Decision (ROD) and briefing material describes
the evaluation of alternatives and proposed measure in more
detail. Since the estimated cost is less than $250,000, I am
prepared to sign the procurement request authorizing the REM/FIT
-------
2
I
RECOMMENDATION
I recommend that you sign the attached ROD for this action.
The existing cooperative agreement includes the State's assurance
fIr the required cost share. The attached memoranda from OWPE and
O(~ contain the enforcement release and OGC concurrence for the
p'- )ject.
:. ~ 'I~ Ii ',,,,
". \... ~ ~,.
'4}, Fi""" II
~ (\~ .!~'"
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Statement of Work
A&F Materials-Greenup Site
Initial Remedial Measure
Task 1:
Prepare Plans and Specifications
The Engineer shall prepare the necessary subcontract
documents to implement the Initial Remedial Measure. The
IRM shall include off-site transportation and disposal at a
RCRA approved facility of aproximately:
a. 153,000 gallons of contaminated liquids
b. 16,000 gallons of contaminated oil
c. 20 drums
Where appropriate the documents shall include alternative
costs for innovative disposal technologies such as
incineration for oils, solvents, and chlorinated organics.
Task
2: Subcontract Award
The Engineer will:
a. Solicit and review bids.
b. Sign a subcontract as approved by the
c. Administer subcontract requirements.
d. Prepare progress payment requests.
e. Schedule and ~oordinate subcontractor
with others in the overall project.
f. Develop a site schedule.
EPA.
activities
Task 3:
IRM Implementation
The Engineer will furnish the general man3gement and
supervision of the removal and off-site disposal of all
drums and contaminated bulk liquids and oils.
Task 4:
The
project Engineer Services
Engineer will:
a. Ensure compliance of the subcontractor to the
appropriate Resource Conservation and Recovery Act
(RCRA) regulations pertaining to transportation,
treatment, storage, and disposal of hazardous waste
from the site.
b. Oversee subcontractor activities to determine
compliance with EPA procedures such as the health
and safety plan.
-------
W)R!( ASSIGNMENT
A.
Contractor:
CH2M H.ill
1941 Roland Clarke Place
Reston, VA. 22091
B.
Contract Numt:er:
68-01-6692
C.
SITE/Title:
MF Materials, Greenup Illinois
D.
Assig~nt Number
... .
9"':3. 5 ~. \i
E.
Statement of Work:
Attached
F. Level of Effort (Work hours):
300 hours
G.
1?eriod of 1?ertonnance:
12 ~ks
Contracting Officer
Dorothy Tyler PHONE 382-3199
Environmental Protection Agency (PM-214-F)
401 M Street, s.w.
Washington, D.C. 20460
Contracting Officer Approval
Date
Project Officer
Signature
Paul Nadeau PHONE 382-2346
Environmental Protection Agency (WH-548-E)
401 M Street, S.W.
Washington, D.C. 20460
~~~f~
Date
i /Iz-
-------
'niS form IS designee for an ~1I[e typewriter (12.pItCni.
. PROCUREMENT REQUEST/REQUISITION
(P!ecufl read i1UtnJcti01l~ 011 ,.elJene before completinlt the form.)
1. OATE
Z. OAT~ Rt:;""UI...."u
11/02/83
PAGE
ASAP 1
sa. PROJECT MANAGER ("'amei
B. Bixler/P. Nadeau
OF :
,
:
a. ORIGINATOR (,"' amei
Becky Kennedy
, PHONE NO. d. MAIL. CODE
o. PROG EL.EM 4. DEL.IVER TO:
TFAY9A
US EPA Superfund
401 M St sw
Washinaton DC ?o4~n 382-2339
PURCHASE AUTHORITY/CONTRACT NUMBER
b. PHONE NO.
6. PROCUREMENT OFF:
e. OIVISION
. .
WH548D HSCD
..CUREMENT OFFICE USE ONL.Y
'-8100
Wash.
:-
DISCOUNT TERMS
nORAL. ORDER-ORDER NO.
VENDOR NAME AND ADDRESS
68-01-hhQ2
PERSON TAKING ORDER/QUOTING
FOB POINT
. FINANCIAL. DATA
(a). APPROPRIATION
68/20X8145
Dorothv Tvler
NOTE: ITEM SIc) DOCUMENT TYPE - Contract a "C"
Purchase Order a "P" IGA .. "A" Other (misc.) .. "X'"
382-3199
I
i
I
I
I
I
I
CH2M Hill
1941 Roland Clark
Fcston, VA 22091
DATE
TEI..£PHONE NO.
DELIVERY
Place
CONTRACTING/ODERING OFFICER
TELEPHONE NO.
.... ......... FMO USE .........- 0
. T
(b) (e)
DOCUMENT
CONTROL. NO.
(d)
r
I
o
o
01
o
o
o
OBJECT AMOUNT (g) ~
ACCOUNT NO. CLASS I....
(e) (f) DOL.I..ARS c-rs.
3233343536 37 3a 39404142 43444546474849505152153 54 55Is6'.'~
CE~HOClq4TF:A72'SRli?'~~~ 1111000jQ~
I~
. I ~
I ~ I 3 4 5
:: I
: I i
: I i
6 7 8 I 9 10 II 12 13 14 15 16 17 I a 19 20 31
I
. SERVICING FINANCE OFFICI!:
22
10. AMOUNT OF !\/IONEY SHOWN IS COMMITTEe
AS.
o ORIGINAL
n INCREASE
11. PL.ANNING 1.0. NO.
o DECREASE
STOCK OR ITEM NO.
(121
DESCRIPTION
(131
QUANTITY
(141
'UNIT OF
ISSUE
(151
UNIT
COST
(161
AMOUNT
( 17)
Increrrental funding
A & F Materials, Greenup II..
Initial Rerredia1 ~sures
$111,100
:
I
a. SUGGESTED CONTRACTOR/VENDOR
%0. SIGNATURE ;;J:;IGINATOR
~/u-.. ' " UG!Li..'-v
21. SIGNAT"'.E OP' PROP. MGMT.c pFP'ICER/DESIGNEE
v '.-/
DATE
/;/~/~3
DATE
9. RECOMMENDED PROCUREMENT METHOD
Z~ACCOUNTA8L£PROPERTY
23. NOT AVAIL.A8L.£ FROM
EXCESS
o INITIALS
o NONCOMPKTITIVE (Judlffeat1on attached) 0 INITIALS
. u. APPROVALS
I. ;::~~IO;;~CE Q ~::) ~~ ~ ;J!j! ~:3 d. FINANC: ;
). OIVI~IO~EY... ..,//.-b ./ k. ~ATJ-/; J /;..- e. OTHER ~ .' - I
h::ting A- : cor, ~ ~ r/~4 /~ Di?ector~ OrnR'" . ','. ..~
~~JZ:D~;U~~:;::'~AND Ji:~r!f-Cj,-~ ~.~, '~ ~ k~
'OMPETITIVE
-
DATE
DATE
-------
,to $'4',.
.J" I.
; '~ ';
:..~~
~~ .
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c.'
"( "Il1O,,-
UNITEO STATES ENVIRONMENTAL PROTECT10N AGENCY
WASHINGTON, D.C. %0.410
@~
~/'
.~~
~t~
hPR 2 6 1983
OllfllCi OF
SOLID WASTe AHD EME"aENCY "ESPONSE
MEMORANDUM
SUBJECT:
FROM:
TO:
A & F - Greenup, Illinois .
Gene A. Lucero, Director ~ A\ L~
Office of Waste Programs Enforcement
William N. Hedeman
Office of Emergency and Remedial Response
At a meeting on April 11, 1983 with Lee Thomas and Courtney
Price and their staff, Lee decided t~.go ahead with a Fund financed
cleanup of the A & F Greenup site4
I hereby give you an enforcement
release for the feasibility study and the concurrent remedial
action.
Please keep my office informed on the progress at the
site and the feasibility study since there is an ongoing law suit.
cc:
K. Sn iff
J. Muys
R. Wyer v
K. Taimi
J. Schulteis
N. Niederganq
-------
,~~O.sT,,~
,,'" 01'.
;~"G
. iLA z
~~
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~.;' C"",,,,
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MEMORANCUM
SUBJEcr :
FOOM:
W:
UNITED STATES ENVIRONMENTALPRQTECTION AGENCY
WASHINGTON, C.C. 20460
r,'n\! I /1
1\_1 ~
OFFICE OF
SOLIO WASTE ANO EMERGENCY RESPONSE
Record of recision for A£F Materials, Greenup Illinois
J;j.sa K. Friedman, Associate General Counsel ~£t- ~
SOlid Waste and Eirergency Response Divisionrn-131)
William N. Hedeman, Jr. Director
Office of Eirergency and Remedial Response
(WH-548)
The Record of recision for the Initial Remedial Measure at A£F Materials
"
has ~en reviewed by rrrj staff.
Camrents:
'i
/1-/7
v' .~--:;1.
I conOJr
~:J
r do not concur
I cona.lr with the attached condi tions
1.//
Date
!'Yi.J-(t-<- (l LL <(.J -2-c
~:J'!f J-. ..
C~~
///D/q3
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¥tVJI~ It l (4../13
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. . ,
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RECORD OF DECISION
Initial Remedial Measure
,
SITE:
A&F Materials, Greenup, Illinois
ANALYSES REVIEWED:
I have reviewed the following documents describing tie analysis
of cost-effectiveness of remedial alternatives at th~ A&F
Materials - Greenup site:
- Cost estimate for Remedial Action at A&F Materials,
Final Report for Region V, U.S. EPA, GCA/Technology
Division, May 1982,
- Evaluation of Initial Remedial Measures, EPA October, 1983.
- Staff summaries and recommendations.
DESCRIPTION OF SELECTED OPTION:
- Removal and off-site disposal of all contaminated liquids
from tanks
Removal' and' off-site disposal of all hazardous waste in drums
DECLARATIONS:
Consistent with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), and the
National Contingency Plan (40 CFR Part 300), I have ,consulted
with the State of Illinois prior to determining the appropriate
remedial action. I have determined that off-site disposal of
the liquid contents of the tanks and the drums is a feasible
and cost-effective remedial action necessary to limit a threat
of exposure to a significant public health and environmental
hazard. I have also determined that the action being taken is
in balance with resources available in the Trust Fund and the
need to respond at other sites. In addition the chosen remedy
complies with section 101(24) of CERCLA because off-site disposal
is more cost-effective than potential on-site actions.
c-f~ ""~~~
"
, / '/ ~
, '
! / '- ..-'
IDa te
Lee M. Thomas
Assistant Admini~ti~i~f
Office of Solid Waste and Emergency Response
:. ~ ' ~": t " ,...
. ,,,.\. ~~.~,..
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EVALUATION OF INITIAL REMEDIAL MEASURES
.S i te Name:
A&F Materials
Site Location: Greenup, Illinois
I .
Background
The A&F Materials site is located on three and three quarter
acres of land on West Cumberland Street in Greenup, Illinois.
Thirteen steel storage tanks contain a mixture of waste oils
( contaminated with PCBs and organics), sludges, spent caustics,
spent acids, contaminated.water and other waste products and
have failed on several occasions releasing their contents.
The tanks have inadequate foundations and are presently
tilted at about a S to 10 degree angle from vertical. The
histo~y of past tank failure and poor foundations to support
.the tanks is creating a significant threat of hazardous
substance~ release. Multiple tank failure could result
since the failure of one tank could cause the failure of
adjacent tanks. Drainage from the site reaches the Embarras
River by a ditch along the Illinois Central Railroad tracks.
The site has a pronounced slope toward the Embarras River
and is in the river floodplain. The City of Newton
periodically withdraws drinking water from the Embarras
River downstream of the site.
The site is underlain by 10 feet of silty material with a
permeability of 3xlO -Scm/sec. The s.and and gravel aquifer
which has been contaminated, is located beneath this silt
layer. The site is located on a hillside which discharges
runoff from rainfall directly onto the hazardous substances.
Operations at the site began during the Spring of 1977 and
were originally intended to reprocess waste oils and sludges
from variou~ generators. Four storage lagoons became filled
by March 1978 and began to overflow, contaminating the
environmental pathways leading to the Embarras River. S~mples
of sludge, oil, waste and water have been collected at the
site on at least ten separate occasions by the State of
Illinois and u.S. EPA between May 1978 and March 1983.
Ground water monitoring wells which show PCB contamination
were installed during August 1981. The contamination has
been calculated to be moving toward the Embarras River at a
velocity of over".,2,? ft/day. Poly~hlorinated biphenyls.( 33
ppm) have been found in the tanks. Other contaminants, have
been found in significant concentrations in on-site soils
and liquids including pyrene (23 ppm), flouranthene, (24 ppm),
phenanthrene/anthracene (12 ppm), acenaphthlene (.4 ppm),
napthalene (20 ppm), phenol (226 ppm), trichloroethylene
(.32 ppm), toluene (3ppm), benzene (2.7 ppm), iron (4800 ppm),
aluminum (11,000 ppm), cadmium (3 ppm), chromium (29 ppm),
copper (140 ppm), lead (96 ppm), zinc (760 ppm) and dicyclo-
. pentadiene (1200 ppm). Although there is no specific data on
other contents of tanks, in addition to PCBs, the. contents
are expected to include many of the materials found elsewhere
-------
"
2
The site presently contains about 153,000 gallons of
contaminated liquid waste, 16,000 gallons of contaminated
oil, 800,000 gallons of contaminated sludge and soil, and
20 drums of unknown contents.
II. State Activities
An operating permit requiring no discharges from the site
was issued by the Illinois Environmental Protection Agency
(IEPA) on June 23, 1977. The IEPA has inspected the site
on at least 20 separate occasions and continues to monitor
conditions at the site. Administrative enforcement actions
were initiated by the IEPA beginning in 1979, but resulted
in little or no action by the site operators. Several
lawsutts have subsequently been initiated by the State of
Illinois, the Village of Greenup and residents of Greenup.
On May 31, 1979, Village residents filed a Complaint in
Circuit Court which resulted in a Temporary Injunction
dated June 14, 1979, requiring that no additional wastes
be. accepted by A&F Materials. A p6rtion of the facility
was sold to Genet Refining and Recovery to apparently
circumvent the court order, and the facility continued to
operate. The Village of Greenup filed Complaints against
A&F Materials and Ken Ault on June 10 and June 16, 1980,
resulting in a Preliminary Injunction being issued on June
23, 1980. This injunction prevented wastes from being
accepted at, or removed from the site ~thout approval by
the Village. The suit was joined by the State of Illinois
and required removal of all wastes and restoration of the
site. A default judgement was entered against Ken Ault and
A&F Materials on October 21, 1981, requiring site cleanup.
No wastes have been received at the site since June 1980.
"
III. Federal Response Activities
Based on the inspections conducted by IEPA and a detailed
site investigation conducted by u.S. EPA in March 1980,
Federal action was initiated in June 1980, pursuant to
Section 311(c) of the Clean Water Act. Among the actions
taken were the lowering of the level of wastes in the pits,
diking, trenching, cleanup and removal of on-site and off-
site wastes. About $240,000 was expended for site cleanup
under Section 311.
In May and December 1982, expenditures of about $100,000
were ~equired from the Fund for immediate removal actions
to lower the level of waste in the lagoons. During March
1983, all of the liquid was removed from the lagoons and
a temporary cap was placed on the consolidated sludges.
This effort required an additional expenditure of approxi-
-------
3
,
IV. Federal Enforcement
A Federal lawsuit to bring ab0ut site cleanup at Greenup
was initiated by the filing 0 a Complaint on September 3,
1980, pursuant to authority u,der the Resource Conservation
and Recovery Act, 42 U.~.C. S~ :tions 6901, 6973, and the
Clean Water Act, 33 U.3.C. Sec:ions 1251, 1311, 1319 and
1321. The Complaint alleged that the handling, treatment,
storage and disposal of solid and hazardous wastes at the
facility presented an imminent and substantial endangerment
to health and the environment. The Complaint also cited
the defendants for violation of Section 311(e) of the CWA,
as evidenced by overflows from the pits. The original
Complaint did not include generators as defendants.
Letters to all known generators, dated November 3, 1981,
were sent by the Assistant U.S. Attorney requesting their
participation in site cleanup. Negotiations have continued
since that time, but have failed to result in an agreement
for site cleanup. Demand letters to the generators for
the required remedial action were sent by the Department
of Justice on August 18, 1982. No commitment by the
generators has been made by the September 10, 1982, deadline
provided in the Demand Letters. The generators were
subsequently added to the lawsuit on February 14, 1983.
V. Evaluation of Alternatives~
The following reports have been completed as part of the
investigation of remedial action alternatives:
"Remedial Action Master Plan, A&F Materials," Weston,
February, 1983.
Inc.,
"Cost Estimate for Remedial Action at A&F Materials, Final
Report," GCA/Technology Division, May 1982.
"Ground Water Contamination Potential for the A&F Materials
Site in Greenup, Illinois," E&E Inc., revised June 1982.
"Ground Water Contamination of the A&F Materials Site in
Greenup, Illinois E&E Inc., revised June 1982.
"Meeting on Chemical Fixation Alternative for Sludge and
Sediment Material at A&F Materials, Greenup, Illinois,"
Region V, U.S. EPA, August, 1982.
"Interim Status Report for the Hazardous Waste Sampling at
-------
4
"Description of Greenup, Illinois, Facility 6f A&F Materials
Region V, u.s. EPA, January 5, 1982,
"The A&F Materials, Greenup, Illinois, On-Scene Coordinators
Report," Region V, U.S. EPA, May 1982,
"The A&F Materials, Greenup, Illinois, On-Scene Reports,"
Region V, U.S. EPA, 1980,
The GCA report evaluated remedial alternatives to deal with
the site conditions that existed prior to the immediate
removal actions. This analysis evaluated six alternatives
to deal with lagoon and tank liquids, waste oil, sludge and
contaminated soil, and final site closure.
Before the remedial action could be approved and implemented,
the immediate removal actions described in section III were
conducted. The wastes remaining on-site include about 153,000
gallons of contaminated liquids in tanks, 16,000 gallons of
contaminated oils in tanks, 20 drums with unknown contents
and 800,000 gallons of lagoon sludges and contaminated soils.
EPA screened the original GCA alternatives to evaluate the
elements of each alternative that dealt with the remaining
site contaminants in tanks and drums. The contaminated lagoon
sludge and soils were not included since the State is
evaluating alternatives for those wastes. in their on-going
RI/FS. .
The cost-effective analysis is summarized below:
1. Organic Contaminated Liquids in Tanks: The only
technologically feasible alternatives for handling
contaminated liquids were on-site treatment with activated
carbon adsorption and off-site transport and disposal
at an approved treatment facility. On-site solidification
of liquids contaminated with organics has not been
proven reliable. The site hydrogeology which consists
of porous soils and high ground water (10 feet or less
below the surface) makes landfilling of waste material
unacceptable. The estimated cost for the two feasible
alternatives are:
Liguid Disposal
Estimated Cost
On-site treatment
$128,500
Off-site treatment at a
RCRA approved facility
$ 63,000
Therefore off-site disposal is considered the cost-effective
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5
2. Contaminated Oils in Tanks: On-site treatment alternatives
for contaminated oil, such as incineration or solidification
were not cost-effective. On-site incineration of the
relatively small volume of oil would require an extremely
large capital cost for incinerator construction. EPA's
mobile incinerator is currently undergoing RCRA permit
approval; however the estimated cost for mobile incineration
is $1 million making this option significantly more
expensive than off-site disposal. Methods for solidification
of organics and oils have not been proven reliable for
long-term on-site disposal. The only feasible,
reliable, and cost-effective alternative was off-site
disposal at an approved facility.
3. Drtims: The only technologically feasible and reliable
method of dealing with the on-site dru~s was by transport
and off-site disposal at an approved facility. The low
number of drums (approximately 20) and the unknown contents
made the cost of constructing and maintaining an on-site
hazardous waste disposal facility prohibitive. In
addition the hydrogeology of the site made landfilling
unacceptable. Also the site is either in or adjacent
to the Embarras River floodplain. The estimated cost for
off-site disposal is $4,000.
VI. Community Involvement
In accordance with the Community Relations Plan which has been
. developed for the A&F Materials site, the RAMP, various reports
on ground water contamination and a Fact Sheet was distributed
to the community on August 11, 1983. The Fact Sheet (see
Attachment 2) described the proposed Initial Remedial Measure
and requested comments to be submitted by September 6, 1983.
On September 1, 1983, a public meeting was held with the local
residents in Greenup to describe the CERCLA program, provide a
briefing on the site background and to discuss the proposed
Initial Remedial Measure as well as the RI/FS being conducted
by the State.
Questions and comments by the community provided at the meeting
and in correspondence to the Region are summarized below.
Comment
Why not transport the entire tanks off the site with the
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6
Response
The storage tanks on the A&F site are not technically
suitable for over-the-road use. They could not meet
Department of Transportation regulations. They also.
leak. .
Comment
Will there be terrible odors, as occurred when the A&F
site was operating? If so, are they toxic?
Response
There will be odors. The chemicals in the tanks give off
a strong odor, but this odor does not necessarily indicate
toxicity. Equipment will be utilized to minimize the
release of vapors and air monitoring will be conducted to
detect significant releases of contaminants during the
tank pumping. The Center for Disease Control has reviewed
the data on the tanks and believes the project can be
completed without unacceptable releases of contaminants.
The Center will be available to review the air monitoring
data during the pumping.
. .
Comment
':_0,J
Why not dismantle and get rid of the tanks now?
Response
The tanks contain contaminated' sludge material which cannot
be pumped. Once the liquids are removed the potential for
releases of contamination to the environment are minimized.
The sludge left in the tanks, as well as the tanks themselves,
will be evaluated by the State as part of the RI/FS and
can be handled along with the sludge left in the lagoons.
Handling all of the sludge remaining at the site at the
same time is more cost-effective.
In summary, the community concurs in the selected
al ternat ive fo.r. the...l..ni tial Remedial..Measure; however,
they feel the entire site surface should be cleaned up
now rather than wait for the investigation to be
completed.
VII. Recommended Alternative
The cost estimate br.~akdown for the recommended Initial
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,
7
Task
Estimated Cost
- Prepare plans and specifications
~orInitial Remedial Measure
$
8,400
- l.ff-site treatment and disposal
'.f tank 1 iquids and oils
$ 81,000
- Off-site disposal of drums
$
$
7,600
4,000
- Contract management and supervision
Subtotal
10% Contingency
S101,000
$ 10,100
Total
S111,100
Alternati~le technologies will also be considered for specific
on-site wastes. For example off-site incineration of solvents
and contaminated oils will be evaluated to determine if
incineration cost would not significantly increase total disposal
costs.
VIII.
Additional Action
The State of Illinois has entered into a Cooperative
Agreement with EPA to accomplish the following:
- Remedial Investigation/Feasibility Study
sludges and ground water contamination
- Community Relations Program
- Project Management
for soils,
u.S. EPA will take the lead in accomplishing the Initial Remedial
Measure. The required State assurances for implementation of
the Initial Remedial Measure have been incorporated as a special
condition to the Cooperative Agreement. The following actions
are necessary to implement the IRM:
1\') t7, Et;},(~.~ce~.~n t releq;?,~;, "-to'.'
- Approve proposed remedy'
- Approve procurement request
- Design/Implement IRM
".9WPE/OEC
AA OSWER
AA OSWER
EPA/REM/FIT
October 24, ~983
October 31, 1983
October 31, 1983
Nov 1983-Jan 1984
Another Record of Decision will be prepared following
completion of the State's RI/FS. That decision will address
remedial actions necessary to mitigate problems caused by the
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8
IX.
RCRA Coordination
The proposed Initial Remedial Measure will not require
on-site treatment, storage, and disposal of hazardous wastes.
Therefore, there are no issues involving the consistency of on-
site actions with RCRA. Off-site disposal of wastes will be in
accordance with the appropriate RCRA regulations for the
transportation and disposal of hazardous wastes. This will
include manifesting of wastes and shipment to a RCRA approved
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r. . F Materials/
Greenup
Fac.;t Sh~~t :t I
Cleaning Up an
Illegal Hazardous
\Vaste Site
'.
~ [lllnOl"
Environlnl'nlal
PrOlt!t:lion A~t!nl'Y
:!:.!oo (,hUIT h Ii I !{oad
~pr1 nj.(fit!ld. Illinoi~ lj:liOH
St!plt!mbt!r 19!'!3
Sup~rfund Program
Background
A & F Materials. Inc. operated as a waste
solvent reclaiming/processing facility be-
tween 1977 and 1980. When the site was
operating, waste materials were transported
to the site by truck, temporarily stored in
unlined lagoons. and processed in the building
at the site. By-products were stored in above
ground storage tanks. Liquid alum. No, 2.5
fuel oil and fire retardant chemicals were pro-
duced for resale.
Greenup residents complained to the
Illinois Environmental Protection Agency
(IEPAJ about the A & F Ylaterialsoperations
as early as ~Iarch 197i. IEPA inspectors
verified permit ';iolations and the discharge of
contaminated water into the flood plain of the
Embarras River.
In the spnng of 1979 city residents filed a
complaint in circuit court. A temporary
injunction was issued requiring A & F
Materials to cease reclaiming operations.
Waste liquids continued to be delivered to the
site even though the lagoons were full. A year
later another injunction was issued closing
down all operations and ordering all deliveries
and discharges to stop.
The problem
Storage ponds at the A & F site were filled
by March 1978 and had begun to overflow.
During 1979 hundreds of thousands of gallons
of waste oil sludge contaminated the flood
plain during flood stages of the river.
Thereafter the lagoons continued to overflow
and contaminate the area.
What has
problem?
been
done about
the
There were five emergency remedial actions
at the site between June 1980 and March
1983. Oil spills have been cleaned up, berms
have been repaired and raised. and
wastewater treated and discharged. In March
1983 the sludge in the lagoons was consoli-
dated and the lagoons covered to prevent any
further overflow.
Since 1978 U.S. EP A has hired independent
contractors to sample the soil. sludge and
water on and around the site. After analyzing
these samples and assessing the potential for
continued discharge into the surrounding
environment. U.S. EPA listed the site on the
Superfund national priority list.
What kinds of hazardous waste have
been found at the site?
The lagoons have contained a mixture of
waste oils. sludges. spent caustics, spent acids
and contaminated water. along with waste
products. Polychlorinated biphenyl (PCBs)
are also present. [n addition. U.S. EPA and
IEPA analyses have identified significant
levels of heav? metals and dicyclopentadiene.
toluene. xylene. naphthalene. styrene and
benzene. These solvents were mixed with the
waste oil when delivered to the reprocessing
plant. The storage tanks contain similar
waste material.
Is the water safe to drinl\:?
Drinking water for the city of Greenup is
provided by wells across the Embarras River
from the A & F Materials site and they are
no't polluted. No private.wells used for drink-
ing water are contaminated either.
The primary source of water for the city of
Newton is deep wells. They are not contami-
nated. but :-iewton does withdraw drinking
water from the Embarras River in emergen-
cies or during periods of drought, four to six
days each year. Low levels of contaminants
have been found in the river.
But is any of the drinking water
threatened?
The contamination at the A & F. Materials
:>ite could spread into the :>urrounding area by
movement of either surface water or ground-
water. To help prevent this. the sludge in the
lagoons is protected from surface water runoff
by plastic covers. Monitoring wells were
installed to detect the direction and speed
that contaminants move in underground
water. Any change in groundwater con-
tamination is detected by analyzing samples
from monitoring wells.
What is going to be done next?
U.S. EPA has determined that the liquid in
the aboveground storage tanks should be
removed. A qualified contractor will be
:>elected to drain the tanks and transport the
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I
UNITED STATES ENV1RONMENTAL PROTECTION AGa«:'r
REGION V
OA TE: SEP 2 4 1982
Meeting on Chemical Fixation Alternative for Sludge
and Sediment Material at A&F Materials, Greenup, Illinois
Nonnan Niederqang ~~~
On~Scene Coordinator
J8..1cCT:
Fr10M:
TO:
Fil e
'-71??
A meeting was held in Chicago, Illinois on August 5,1982 to discuss the
subject. A list of attendees is attached. Dr. Philip Malone and Dr. larr"J
Jones are authors of USEPA Publication No. 5W-872, entitled, "Guide to the
Disposal of Chemically Stabilized and Solidified Waste," dated September 1980.
Robert Cibulskis is a member of USEPA's Emergency Res~onse Te~.
Prior to the meeting Drs. Malone and Jones and Mr. Cibulskis'reviewed the
following document, as well as numerous photographs of the sites.
a.
Description of Greenup, Illinois Facility of A&F Materials,
USEPA, Region V, January 5, 1982" (includes summary of all
a n a 1 yt i c a 1 da t a ) .
b.
Description of Olney, Illinois Facility oJ A&F Materials,
USEPA, Region V, January 5, 1982 (includes summary of all
analytical data).. .
c.
Closure Plan - Waste Oi1 Surface Impoundment, Aluminum Company
of America, Davenport Works, March 1,1982.
Topographic map of Greenup Site, prepared by E&E Inc.,
March 1982.
d.
In addition, the following description of the Greenup site conditions ~s
pro vi ded:
a.
The Greenup site is partially located within the 100-year
floodplain of the Embarras River,
. .7..
b.
The 3ite is underlain by 10 feet of clay-silt with a
permeabi lity of 3 x 10.5 cm/sec; the sand and gr'avel
aqui fer which has been contami nated, is located beneath ""
the clay-silt layer,
The facility is located on a hil1-side which discharge"s
rainfall-runoff directly onto the site,
,.
c.
d.
The sludge is characterized as an oi1y, organic, spongy
mater; a 1.
...
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. .
2
Based on a review of the above information, Drs. Malone and Jones concluded
the fo 11 owi ng:
a.
b.
c.
d.
Poor site conditions, in general, are an adequate basis to
exclude on-site chemical fixation with on-site ultimate
disposal. The site conditions existing at the Greenup
site are not appropriate for further consideration of
on-site fixation and disposal of the contaminated sludge
and sediment materials. -.
Only two known (inns ill the country are experimenting with
processes to provide chemical fixation of organic sludges.
No field demonstration of chemical fixation of organic
sl udges has -been attempted.
The process used by Alcoa at Bettendorf, Iowa, 0 n simi 1 ar
types of sludges, was not acceptable for several reasons:
1.
The fixative agent contained significant amounts of
sulphur trioxide, wh-i ch readi ly converts to sulphur;c
acid in the field, which would tend to mobilize
contami nant s,
2.
Phenols were found to be readily released from the
so 1 i di fi ed sl udges,
3.
Quality-control during the fixing process was probably
inadequate, based on the information provided. Oi1s
and moist organic materials were noted at the bottom
of soil borings taken in the field of the fixed
s 1 u d ge s, a nd
~
4.
The EP-Toxicity test is not an acceptable test as the
sale indicator of the potential for release of con-
taminants from fixed material. Other tests such as
the Maximum Possible Concentration Test and the Uniform
Leaching Procedure sho~ld have been performed.
Chemical fixation, then transportation to an off-site disposal
facility close to the site, may be a feasible cost-effective
alternative.
. ..,-.
Based on the above conclusions, on-site chemical fixation of the sludge
and sediment materials at the Greenup site of A&F Materials ;s not con-
sidered to be a reliable alternative worthy of detailed laboratory studies
and field experiments. Bob Cibulskis concurred in ,this assessment.
Attachment
.~
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NAME
Ei1een Bloom
Nonn N; ede rgang
Philip G. Malone
Larry W. Jones
R. W. Cibulslds
Bill Busch.
R. E. Oi effenbach
Robert Mue 11 er
Howard O. Chi nn
T om Bored, i
.. .
ATTENDEES LIST
A&F Mater; a 1 s
. Chemical Fixation Alternative
August 5, 1982
, . - ...
ORGANIZATION
.1
Attorney, USEPA, Region V
ose, USEPA, Reg;on V
U. S. Army Co rps 0 f En g1 neers, WE S
U.S. Anny Corps of Engi neers, WES
USEPA/ERT, Edison, N.J.
IEPA, Springfield, IL
. USEPA, Chica~o, IL
Attorney, IL Attorney General
Engineer, IL Attorney General
Enqineer, IL Attorney General
. .r.
,.
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