United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/HOD/R05-85/012
June 1985
&EPA
Superfund
Enforcement Decision Document
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1. REPORT NO.
EPA/ROD/R05-85/012
4. TITLE AND SUBTIT~E
ENFORCEMENT DECISION DOCUMENT
A&F Material!t Company,IL
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
3. RECIPIENT'S ACCESSION NO.
\2.
5. REPORT DATE
June 14 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHORCSI
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD ReDort
14. SPONSORING AGENCY CODE
-
800/00
-
115. SUPPLEMENTARY NOTES
16. ABSTRACT
The A&F Materials site is located on three and three quarter acres of lan~pn west
Cumberland Street in Greenup, Illinois. The site is bounded by open farmlan~/Wbodland,
the Village of Greenup Wastewater treatment plant, and private residences. In_addition,
the City of Newton occasionally withdraws drinking water from the Embarras River,. 'whicb
is located twenty-one miles downstream from the site. The A&F Materials facility ~
began operation in March 1977 and continued until it shut down' in 198Q. The operation
proce,ssed waste materials (including, but not limited to oil, sludge, caustic and
sulfuric acid) into fuel oil and fire retardant chemicals. During ,the course of
operations, there were numerous violations of the permit issued to A&F Materials by
. the Illinois Environmental Protection Agency. By March 1978, four storage lagoons be-
came filled and began to overflow, contaminating soil and drainage pathways leading
to the Embarras River. In addition, twelve steel storage tanks containing a mixture of
waste oils, sludges, spent caustics, spent acids, contaminated water and other waste
products, were located on site. These tanks failed on several occasions, releasing
their contents into the surrounding environment.
The selected remedial action includes: removal and disposal of all soils contam-
inated over the recommended action levels, including soils containing greater .than
1 ppm PCBs; monitoring of the ground wa~r; cleaning and removal of on-site equipment
(continued on separate paqe)
DESCRIPTORS
KEY WORDS AND DOCUMENT ANALYSIS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
17.
Record Of Decision
A&F Materials Company, IL
Contaminated Media: soil, sw
~ey contaminants: PCBs, organics
metals
& heavy
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18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tlais Report)
None
20. SECURITY CLASS (Tllis page)
None
21. NO, OF PAG ES
.?
22. PRICE
EPA form 2220-1 (R...4-77)
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Enforcement Decision Document
A&F Materials Gompany
~
Continued
and buildings; testing and disposal of soil underlying the building if it is
found to be contaminated above the recommended action levels; grading of the
and removal of the fence surrounding the site. Total capital cost for the
selected remedial alternative is estimated to be $824,000.
site;
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ENFORCEMENT DECISION DOCUMENT
REMEDIAL ALTERNATIVE SELECTION
Site: A & F Materials Company, Greenup, Illinois
Documents Reviewed
I have reviewed the following documents describing the need for remedial
alternatives at the A & F Materials site:
- "Remedial Investigation Report, A & F Materials
Company Site, Greenup, Illinois", Engineering - Science,
October 1984.
- "Feasibility Study Report, A & F Materials Company
Site, Greenup, Illinois", Engineering-Science,
January 1985.
- Summary of Remedial Alternative Selection
Community Relations Responsiveness Summary
- Partial Consent Decree, dated September 12, 1984
Description of Selected Alternatives
1. Soils/Sediments
- All soils contaminated over the recommended action
levels, including soils containing greater than
1 ppm PCBs will be removed, and disposed of in a
U.S. EPA approved off-site facility.
- Groundwater monitoring will be conducted to confirm
that no further soil removal is required.
2.
Buildings and Equipment
- Equipment and structure of the buildings, including
concrete floors, will be cleaned, dismantled, and
removed from the site for disposal at a U.S. EPA
approved facility.
- Soil underlying the building will be tested and if
found to be contaminated above the recommended
action levels, will be disposed at a U.S. EPA
approved facility.
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3.
Site Grading
Site grading will include filling depressions to
eliminate ponding, covering with sufficient topsoil,
and providing and maintaining a vegetative cover
to prevent erosion.
- The fencing surrounding the site will be removed.
Declarations
Consistent with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), the National Contingency Plan, and the
Partial Consent Decree of September 12, 1984, and after consultation with
the Illinois Attorney General and the Illinois Environmental Protection
Agency, I have determined that the above remedy for the A & F Haterials site
effectively mitigates and minimizes damage to and provides adequate protection
of public health, welfare and the environment. Groundwater issues at this
site will be addressed in a separate document.
I have also determined that the action being taken is a cost-effective alter-
native when cOOlpared to the other remedial options reviewed. In addition, the
off-site transport, treatment, and secure disposition is more cost-effective
than other remedial action alternatives considered and is necessary to
protect public health, welfare and the environment.
V'ld'~k~
Regional Administrator
(~)
o.J-- L I~ I
IflS-
Attachments:
Summary of Remedial Alternative Selection
Community Relations Responsiveness Summary
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
A & F Materials Site, Greenup, Illinois
I. Site Location and Description
The A & F Materials site is located on three and three quarter acres
of land on West Cumberland Street in Greenup, Illinois (Figure 1).
The site is bounded by open farmland/woodland, the Village of Greenup
wastewater. treatment plant, and private residences (Figure 2).
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. The portion of the site outside of the
facility fenceline is in the river's lOO-year fioodplain. The City
of Newton occasionally withdraws drinking water from the Embarras
River twenty-one miles downstream of the site. Geological information
indicates that the site is underlain by sandy deposits associated with
recent stream development. These alluvial sands overl ie a sand and gravel
deposit of glacial outwash origin. No drinking water or other production
wells are located downgradient of the site. The drinking water supply for
the Village of Greenup is separated from the site by the Embarras River
which serves as a hydraulic barrier to any ground water flowing from the
site. The site is located on a hillside which discharges runoff from
rainfall directly onto the site.
I I.
Site History
The A & F Materials facility began operation in March 1977 and continued
. until it shut down in 1980. The operation processed waste materials
(including, but not limited to oil, sludge, caustic and sulfuric acid)
into fuel oil and fire retardant chemicals. During the course of opera-
tions, there were numerous violations of the permit issued to A & F
Materials by the Illinois Enviromental Protection Agency. By March
1978, four storage 1 agoons became fi 11 ed and began to overflow ,contami-
~ nating soil and drainage pathways leading to the Embarras River. In
addition, twelve steel storage tanks containing a mixture of waste oils
(contaminated with PCBs and organics), sludges, spent caustics, spent
acids, contaminated water and other waste products, were located on the
site. The tanks had failed on several occasions, releasing their contents.
After the closure of the facility in 1~80, the site was classified as an
abandoned hazardous waste site under CERCLA. There have been numerous
preliminary investigations and short-term removal actions sponsored by
U.S. EPA and IEPA to secure the site and prevent the release of contaninants.
The A & F Material Company site was included on the proposed National
Priorities List of December 1982. The site was ranked 62 out of an
original total of 419. The December 1982 proposed list wa5 made final
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III.. Current Site Status
In March 1980, Hay 1982, and December 1982, various actions were taken at
the site .to lower the immediate potential of releases. These actions
included lowering the level of wastes in the lagoons, diking, trenching,
cleanup and removal of on-site and off-site wastes. In addition, in
Harch 1983 a temporary cap was placed on the consolidated sludge.
On September 12, 1984, a Partial Consent Decree. hereinafter the
"First Consent Decree", was entered into by four companies, Aluminum
Company of America, Northern Petrochemical ,CAn-OR Inc. and Petrolite
Corporation, hereinafter .Consenting Defendants". Under the terms of the
Consent Decree, the Consenting Defendants agreed to undertake surface
cleanup at the A & F Haterials site as an additional removal action. As a
part of the removal action, a total of 5,500 gallons of caustic waste and
4,000 gallons of PCB contaminated oil from the tanks, and 10,000 tons of
soil/sludge from the lagoons have been removed from the site.
Pursuant to the First Consent Decree, an RI/FS was prepared by the Consenting
Defendants which determined the amount of soil/sludge to be removed. Approxi-
mately 86~ of this material, or 10,000 tons, has already been removed. The
only soil/sludge remaining is approximately 1-2 feet of material covering
the entire area of Area A and some material in the two lagoons (Figure 3).
The amount of soil/sludge remaining on-site is estimated to be 1,500 .tons.
The amount of soil contaminated with PCBs which contained levels of 1 ppm or
greater was estimated to be 1,332 cubic yards (Figure 4). Area C has already
been removed. In addition, a s~all area of soil located at the western edge
of the building was found to contain high levels of contaminants, but no
PCBs were detected.
The RI/FS determined that hazardous substances were used in the building
and there is evidence of spills and residues remaining in the equipment and
in the building. The building and equipment were not sampled due to the-
expense involved. Therefore, the RI/FS assumes that the building and equip-
ment are contaminated with residues that are hazardous.
Existing geologic information indicates that the site is underlain by 3-21
feet of sandy alluvium over 2-26 feet of outwash sand and gravel. Prior to
the removal actions already undertaken at the site, a major potential pathway
for contaminant migration was surface runoff from the leaking tanks and over-
flow from the lagoons. Since the removal actions, the most significant
pathway appears to be subsurface movement of contaminants which may be
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IV. Federal Enforcement
A Federal lawsuit to bring about site cleanup at Greenup was initiated
by the filing of a Complaint on September 3. 1980. pursuant to authority
under the Resource Conservation and Recovery Act. 42 U.S.C. Sections 6901.
6973. and the Clean Water Act. 33 U.S.C. Sections 1251.1311.1319 and 1321.
The Complaint alleged that the handling. treatment. storage and disposal of
solid and ~azardous wastes at the facility presented an imminent and substan-
tial endangerment to health and the environment. The C~plaint also cited
the defendants for violation of Section 311{e) of the CWA. as evidenced by
overflows from the pits. The original C~p1aint 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.
Demand letters to the generators for the required remedial action were sent
by the Department of Justice on August 18. 1982. The generators were
subsequently added to the lawsuit on February 14. 1983.
On September 12. 1984. the First Consent Decree ~s entered into by the
Consenting Defendants. Under the terms of the First Consent Decree. the
Consenting Defendants agreed to undertake a surface cleanup at the
A & F aateria1s site as an additional removal action. This action consisted
of emptying and disposing of the steel tanks. and emptying and disposing of
the sludges and so i 1 sin the storage 1 agoons .
Additionally. the First Consent Decr~e provided for the Consenting Defend-
ants to conduct an RI/FS. to reimburse the U.S. for any additional emer-
gency response taken at the site. and to reimburse the U.S. for $340.000,
and reimburse the State for $40,000. Subsequently. McDonnell-Douglas
entered into a Partial Consent Decree (hereinafter the "Second Consent
Decree") with the U.S. and the State. in which McDonnell-Douglas agreed to
pay the U.S. $150.000 as reimburse~ent for past surface response costs at
the site.
V.
Alternatives Evaluation
A.
Soil s/Sediments
In the RI/FS conducted by the Consenting Defendants. several technologies
were screened and eliminated. These included containment. diversion
and grading. solidification. insitu treatment. and no action. The no
action alternative was eliminated because it does not address the issue
of existing contamination on site. S~e action is considered necessary
to remove this contaMination and the threat to human health. welfare
and the environment. Two alternatives were analyzed in detail: 1) .
partial removal with subsequent disposal at a secure off-site facility.
and 2) complete removal of contaminated soils/sediments above background
with subsequent disposal at a U.S. EPA approved facility. The costs
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1) Partial Removal
Partial removal would include removal of the four
contaminated soil zones and any other areas wi th
contaminants at levels of concern. This technology
wOll1d be useful in conjunction with disposal at a U.S.
EPA approved facility. The environmental and public
health risks for this alternative are low.
2)
Co~plete Removal
Complete removal would consist of removal of all contami-
nated soils and sediments. This technology would be used
in conjunction with disposal at a U.S. EPA approved facility.
The enviro~enta1 and public health risks associated with this
alternative would be low.
B. Building and Equipment
In the RIfFS, the no-action alternative,'consisti~g of monitoring and
analysis and site maintenance, was screened and eliminated for the
building and equipment. The no-action alternative was eliminated
because it does not address the issue of existing contamination on
site. S~e action is considered necessary to remove this contami-
nation and the threat to human health, welfare and the environment.
Tr.ree alternatives were analyzed in detail: 1) cleaning and complete
removal, 2) decontamination and complete removal, and 3) cleaningf
decontamination and partial removal.
1 )
Cleaning and Complete Removal
This option consists of cleaning using high temperature,
high pressure equipment, dismantling of the equipment
and the building including the concrete floors, and
disposal at a U.S. EPA approved facility. Effluent from
the cleaning process would be treated, tested and discharged
in a manner approved by U.S. EPA. Soils beneath the building
would be tested and, if contaminated, would be removed, and
disposed of in a U.S. EPA approved facility.
2)
Decontamination and Complete Removal
This alternative involves decontamination, with repeated use of
high temperature and high pressure equipment, until the material
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equipment as described above, would be disposed of in a manner
approved by U.S. EPA. Contaminated water generated.during
decontamination would be treated, tested, and discharged in a
manner approved by U.S. EPA.
3) Cleaning and Partial Removal
This alternative involves cleaning of the equipment
and the structure of the building as described in
Alternative 1, and disposal at a U.S. EPA approved
facility. After the equipment and the building are removed
from the site, the floors and foundation would be decontam-
inated. Core samples of the concrete would be collected
to determine the effectiveness of the qecontamination.
If no contamination is found, the floors and foundation
would retTlain. Contaminated water generated from thi s step
would be treated, tested and discharged in a manner approved
by U.S. EPA.
C.
Surface Water
The surface water at thi s' site is defi ned as the water in the Embarras
River and in the unnamed drainage ditch near the west boundary of the
site.
In the'RIfFS, two alternatives were analyzed for surface water:
1) no action, and 2) continued monitoring and analysis.
VI. Recommended Alternatives
A.
Soils and Serliments
Partial removal is the most cost-effective (least cost
alternative that effectively mitigates and minimizes
damage to human health, welfare and the environment)
alternative for soil and is therefore the recommended
option. This action will comply with the terms of the
First Consent Decree by removing soils found to contain
greater than the Action Levels shown in Table 2, and
disposing of these soils in a U.S. EPA approved facility.
Off-site disposal of the soil is selected because it is
the most cost-effective and because it is necessary to
protect public health, welfare and the environment from
risks created by further exposure to ~ontinued presence
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Figure 4 shows the three areas on the site excluding the lagoons,
that were contaminated with greater than 1 ppm PCBs. The volume
of soils to be excavated at each of these areas was calculated
in the FS as follows:
50 feet wide
100 feet long
4 feet deep
equals 20,000 ft3 or 740 yd3
Area A =
Area B = 30 feet wide
50 feet long
4 feet deep
equals 6,000 ft3 or 222 yd3
Area C =
100 feet wide
100 feet long
1 feet deep
equals 10,000 ft3 or 370 yc3
The total amount of soil to be remcved from the three areas is
36,000 ft3 or 1,332 yd3 as computed in the FS. Area C has
al ready been removed.
In addition, the area along the western edge of the building
was found to be contaminated with PNA compounds. These soils
have also been removed and disposed of with the PCB contaminated
soils (Figure 3).
The remainder of the site apparently contains various areas with
de minimis levels of other compounds. De minimis levels are
comparable to those found to occur naturally in the environment,
and are below levels which would pose a threat to human health,
welfare or the environment. Table 2 shows the background
levels of the compounds of interest found in the soil and
sediments at the A & F site, and the suggested action level
for soil/sediment removal. Soils found to contain levels
greater than those in Table 2 are recommended for disposal at a
U.S. EPA approved facility. Remaining soils beneath the lagoons
will also be removed to levels below those identified in Table
2.
In response to concerns expressed at the December 4, 1984 public
meeting, additional soil samples were taken from two locations
identified by local citizens. These samples were split with
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The lAG analyzed for aliphatic hydrocarbons as well as for the
contaminants of concern. Low levels of aliphatic hydrocarbons
were found in the split samples. Because aliphatic hydrocarbons
are not contaminants of concern, as shown in Table 2, the Consenting
Defendants were not required to analyze for them. Aliphatic hydo-
carbons are compounds found in oil. However, based on review of
.these sampling results by the Centers for Disease Control, aliphatic
hydrocarbons do not present a health threat at this site, particularly
at the low levels found. Both the lAG and the responsible parties
analyzed for the contaminants of concern and no concentrations
above the action levels were found.
The Consenting Defendants will be required to confirm that hazardous
substances above the action levels are not present in these two
areas by conducting additional soil samples in these areas. The
approximate locations of these samples are shown in Figure 5.
Samples will be taken at each of these locations. at depths of
1-2 feet, 2-3 feet, and 3-4 feet, for the purpose of determining
the areal and vertical extent of contamination, if any. These
samples will be analyzed for the hazardous substances shown in
Table 2. If hazardous substances above the action levels are
found in these samples, the soil in these areas will be removed.
Comments received from State agencies and the public regarding soil
removal included the suggestion that additional soil be removed
both to reduce the flushing time of the remaining low levels of
contamination, and to remove the aliphatic hydrocarbons. However,
based on the determination that human health and the environment
will be protected after soil removal to the recommended action
levels. no further soil removal is required. The Centers for
Disease Control concur with this determination. In order' to
confirm that no further soil removal is required, groundwater
monitoring will be conducted. In addition, the Consenting Defendants
will be required to implement further' remedial action if deemed
necessary by U.S. EPA. Additional details and requirements
regarding groundwater remedies will be discussed in a separate
document.
The sediment from the river and the ditch which was analyzed in the
Remedial Investigation Report showed contaminant levels well below
the suggested action levels. Thus, it is not recommended to remove
and dispose of sediments from the drainage pathways at this time.
B.
Building and Equipment
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is cleaning and complete removal. This action is the ~ost cost-
effective because it is assumed, in the absence of sampling data,
that the building and equipment are contaminated with hazardous
substances. Sampling of the building and equipment was not conducted
due to the expense involved. Under this alternative, the ~quipment
and structure of the building would be cleaned, dismantled and removed
from the site for disposal in a U.S. EPA approved facility. Rinsate
from the cleaning process will be treated, tested and discharged in a
manner approved by U.S. EPA. Concrete floors and the foundation will
also be removed and taken to a U.S. EPA approved facility. Soil samples
will be taken from below the south and northwest ends of the building
and analyzed to determine if contamination exists. Soil action levels
will be used to determine if soil beneath the building would need to be
excavated and disposed off-site.
Off-site disposal of the building and equipment is selected because it
is the most cost-effective and because it is necessary to protect
public health, welfare and the environment from risks created by
further exposure to continued presence of the substances.
C.
Surface Water
Based on the analyses of samples collected during the remedial
investigation indicating that surface water is not contaminated.
additional monitoring is not required. Removal of contaminated
soil, site grading and vegetation will remove the potential for
conta~ination of surface water. Therefore, no action is recom-
~ended for surface waters.
D.
Site Grading
Final site grading will be performed for the entire A & F
Materials Company site, as specified in the First Consent
Decree. This will include filling depressions to eliminate
ponding, covering ~th sufficient topsoil, and providing a
vegetative cover to prevent erosion. Areas outside the existing
fence1ine will not be covered ~th topsoil because soil samples
taken off-site did not show significant levels of contaminants
of concern. The fencing will be removed.
After site vegetation, the site will be maintained for three years
to prevent erosion, after which time the Consenting Defendants may
petition U.S. EPA and the State to cease site maintenance.
The cost associated with the recommended alternatives for the soi11
sedi~nts, building and equipment, and site grading are shown in
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VII. Action Levels
The recommended action levels for soils and sediments at the A & F
Materials site are shown in Table 2. These action levels correspond
to the highest concentrations of contaminants presently remaining
in soils outside of the fence1ine of the site and were proposed in
the RIfFS by the Consenting Defendants as levels which would provide
adequate protection of human health. welfare and the environment and
require no further action. These levels have been reviewed by U.S. EPA.
and we agree with this conclusion. The levels for toluene and trichloro-
ethylene were adjusted downward. No trichloroethylene was found outside
of the lagoons above the required detection limits. The only toluene
remaining .is at the bottom of the lagoons. Adopting these action.
levels means that no soil outside the existing fence1ine needs to be
removed; 50i1s within the fenceline above these levels will be removed
to a secure off site disposal facility. These levels represent the
highest levels of contaminants that will remain in the soil at the
fac il ity.
As part of the remedial investigation. soil samples were collected out-
side of the area which could have been potentially impacted by releases
from the facility. These results are generally shown as "background"
levels on Table 2. However. samples of the waste materials in the lagoons
and tanks have shown levels of chromium. cadmium. zinc and iron to be
less then the "background" levels originally derived in the feasibility
study. The" background" 1 eve1 s for these compound s have been rev i sed to
reflect that the levels in soils outside of the fenceline which are
higher than the levels found in the waste are actually "background".
These levels are not significantly higher than the previous "background"
levels listed in the feasibility study. Also shown on Table 2 is a range
of e1e~nta1 concentrations in soils for certain metals compiled by the
Centers for Disease Control (CDC). The "background" levels for all of the
- metals except zinc fall within these ranges. .
. The level of 2700 ppm zinc is a probable an~a1y. This value occurred
at a sample from a 1-2 foot depth at a sampling location 1700 feet
from the nearest lagoon. A surface sample collected at the same
location showed 65 ppm zinc. Samples taken at four adjacent sampling
locations averaged 188 ppm zinc. well within the range of normal
elemental concentrations of zinc.
The action levels for trichloroethylene. benzene.. PCBs. phenols. dicyclo-
pentadiene and PAH compounds are at. or below. the standard detection
limits of the analytical methods used to quantify these compounds by
U.S. EPA. and are therefore appropriate for use as action levels at this
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The only action level listed in Table 2 which appears to be above "back-
ground". the detection limit. or levels which would be ~xpected to occur
at similar locations in the undisturbed environment. is for toluene.
Using an analytical approach developed by CDC. U.S. EPA and CDC have
evaluated compounds in Table 2 for their direct contact. inhalation and
direct ingestion health effects. This would include children, or
others who might play on. or otherwise come into contact with the site.
None of the compounds present a health threat at the action levels
shown.
Toluene was also evaluated for its potential effects on ground water..
should toluene be released from the soil into the ground water. Using
conservative assumptions for the release rate and mixing within the
ground water regime. toluene will not cause ground water to be elevated
above those levels which would be fully protective of human health.
welfare and the environment. Table 3 shows the concentration of toluene
in the soil. applicable groundwater quality criteria and the required
mixing to insure that the release of toluene to ground water does not
cause unacceptable levels. The required mixing factor is the action
level in soil divided by the applicable water quality criteria. Since
the required mixing factor is available at the site. and since there are
no human receptors using the ground water at this time. no adverse
impact of these compound~ on ground water is expected due to releases
from the soils which will remain at the site.
However. soil removal to those action levels shown in Table 2 will
be confinmed ~y ground water monitoring. As discussed previously. at a
minimum. ground water monitoring will be required to insure that ground
water contamination will not occur due to these soils. Further remedial
action will be required if so indicated by further ground water monitoring.
Details regarding the ground water remedy and applicable ground water
quality criteria will be presented. in a separate document.
VIII. Consistency with the National Contingency Plan
The National Contingency Plan. 40 eFR Part 300.68(e)(2). states that
source control remedial actions may be appropriate. if a substantial
'concentration of hazardous substances remain at or near the area where
they were originally located. and inadequate barriers exist to retard
migration of substances into the environment. Based upon analysis of
the options. State and Federal environmental requireMents. and the
comments received from the public and the State. the recommended option
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IX. Consistency with Other Environmental Laws
The proposed action will not require on-site treatment, storage, or
disposal of hazardous wastes. Since all compounds will he removed to
background, or the detection limit (except for toluene), the recommended
action is fully consistent with RCRA. The level of toluene to remain
will be fully protective of human health, welfare and the environment,
and therefore is also consistent with RCRA. Although the materials
to he removed are not hazardous wastes as regulated by RCRA, they are
hazardous substances under CERCLA. The transportation and off-site
disposal of wastes will be in accordance with the appropriate and
relevant RCRA regulations for the transportation and disposal of
hazardous wastes. This will include manifesting of wastes and
ship~nt to a U.S. EPA approved facility.'
Anyon-site water treatment and discharge to surface waters will be
in compliance with State of Illinois permit number 1984-EA-1265 and
the substantive requirements of the Clean Water Act. Any necessary
storm water pennits will be obtained.
The recommended alternatives will minimize potential harm to the site,
in accordance with Executive Order 11988, "Floodplain Management", and
Executive Order 11990, "Protection of Wetlands". Although no potential
impacts on the floodplain could be documented in the remedial investigation,
and no further soil excavation will occur in the floodplain, the following
measures will be implemented to minimize potential harm or adverse effects
to the floodplain:
1 .
use minimum grading requiremnts;
2.
return site to natural contours;
3. maintain vegetation;
4.
regulate methods used for grading and filling;
5.
6.
require topsoil protection; and
no structures will be constructed in floodplain.
In accordance with the Toxic Subst8nces Control Act, PCBs will be removed
fr~ the environment at the A & F Materials site to the lowest levels
practicably attainable. This will mean removing all soils above 1 ppm and
disposing of it in a U.S. EPA approved facility.
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X. Operation and Maintenance
The Consenting Defendants are required to submit an operation and main- -
tenance plan to be approved by U.S. EPA. U.S. EPA will require that
the ConseC1ti ng Defendants impl emerlt the approved pl an.
XI.
Community Relations/Responsiveness Summary
Illinois EPA (IEPA) conducted an extensive community relations program
which included several informal meetings in the homes of nearby
residents, written updates, and frequent conversations with'
interested citizens, press, and local officials. The State, with
U.S. EPA support, responded .to their concerns. Public meetings, one
of which was attended by staff from the Centers for Disease Control,
were al so held by IEPA and U.S. EPA at several times duri ng the
RI/FS process.
When the First Consent Decree was filed in June 1984, U.S. EPA assumed
the lead on community relations, although the State maintained an
active cooperative role. Several public comment periods have been
held, accanpanied by p'ublic meetings, briefings, and other notifi-
cation of interested parties. A five-week public comment period was
available for the FS upon which this record is based.
There was some dissatisfaction among the public during the final months
of the negotiations as some individuals apparently believed that they
were unable to obtain feedback or response to their questions. However,
they are pleased with what has been accomplished and the promptness
of action once the First Consent Decree was signed. Information supplied
by nearby residents has been useful in discovering the full nature of
the contamination and is reflected in the recommendations for the site.
The responsiveness summary is attached.
XI I.
Deletion from the NPL
Implementation of the recommended alternative, in connection with
a ground water remedy (to be discussed in a separate document),
-------
Enforcement (Confidential)
On September 12. 1984. U.S. EPA entered into a Consent Decree.
with four of the A&F Materials Company. Inc. defendants; Aluminum
Company of America. Northern Petrochemical Company. CAM-OR.
Inc.. and Petro1ite Corporation (hereinafter "Consenting Defendantsll).
Pursuant to this settlement. the Consenting Defendants agreed.
in part. to remove contaminated liquids. sludges and nearby
contaminated soils from the site. to monitor groundwater. to
conduct an RIfFS. and following approval of the RIfFS, to implement
the cleanup actions as delineated in the approved RIfFS and'
required Work Plans. U.S. EPA and the State of Illinois were to
respond to the proposed RIfFS by January 7. 1985 and were to
review the Phase III and P~se IV Work Plans by March 4. 1985.
.,
...,
U.S. EPA has met with Illinois Environmental Protection Agency
(IEPA) and the Illinois Attorney General's Office (lAG) to discuss
our response to the Consenting Defendant's submittals. IEPA has
responded to the Consenting Defendants that the proposed soil
cleanup levels are acceptable. The lAG has continued to raise
issues which we feel have been adequately addressed. and has
not issued an approval of this document.
The Consenting Defendants are increasingly concerned that the
delay in our response will increase their cleanup costs. and
perhaps result in delaying the projected cleanup completion
date. U.S. EPA staff is presently discussing this matter with
the Consenting Defendants. In any event. it is U.S. EPA's
~ obligation to respond to the Consenting Defendants as soon as
possible.
The soil cleanup issues discussed herein arise out of commitments
established in the September 12, 1984 Consent Decree and do not
represent the basis for new negotiations. The soil action levels
set forth in this document are founded in site specific concp-rns
and are not and do not intend to be used as. a determination of
the appropriate soil action levels at any other site. The selection
of the proposed cleanup levels are based solely on the technical
review and p.va1uation of the documents attached hereto. the
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--.----
.__.._---_.~-----
.------
FICURE
A&F MATERIALS CO. SITE
Greenup, Illinois
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Tab 1 e 1
Cost of Remedial Alternatives
A & F Materials Site
A lternat he
Cost
COIIIIIents
1) 50i1s and Sediments
- Partial Removal
$ 660,000
Includes excavation, transportation,
disposal and analytical costs.
- Complete Removal
$1,735,000
Includes excavation, transportation, and
disposal; also the construction efforts to
remove and solidify sediments.
2) Building and Equipment
- Cleaning and Complete
Removal
$
120,000
Includes the costs of decontamination of the equipment
and building, collection and treatment of rinsate,
sampling and analysis, and disposal at a U.S. EPA
approved facility.
- Decontamination and
Complete Removal
$
120,000
Same as above, except increased costs of decontami-
nation of the equipment and building, collection an~
treatment of rinsate, and sampling and analysis;
decreased costs for disposal.
- Cleaning and Partial
Removal
$
96,000
Includes dec~ntamination, treatment of rinsate,
collection and analysis of samples of the concrete,
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TABLE 2
SOIL ANO SEDIMENT CONTM1INANT LEVELS
Recommended RecOllll1ended Meduim Elemental
Background Sol1 Background Sediment Concentrations
Soil Level Action Levels Sediment Levels Action Levels i n 5011
Compound s (ug/gm) (ugfgm) (ug/gm) (ug/gm) (ug/gm)
Medium Range
Benzene <1 1.0 <1 1.0
Toluene <1 12.0 <1 12.0
Trichloroethylene <1 1.0 <1 1.0
PCB <1 1 <1 1
Phenols <10 10 0.38 10
Dicyclopentadiene <1 1.0 1 1
Fluoranthene <10 1.0 0.47 2.0
Benzo(a)anthracene <10 1.5 0.21 2.0
Chrysene <10 1.0 0.2 2.0
Pyrene <10 1.0 0.64 2.0
Phenanthrene <10 1.0 0.28 2.0
Acenaphthalene <10 1.0 <10 2.0
Benzo(a)pyrene <10 0.5 <10 2.0
Benzo(ghi)pyrene <10 0.5 <10 2.0
Indeno(1.2.3-cd)pyrene <10 0.5 <10 2.0
Benzo(b)or(k)fluoranthene <10 3.5 <10 2.0
Anthracene <10 1.0 0.9 2.0
Naphthalene <10 2.0 0.33 2.0
.Flourene <10 1.0 <10 2.0
Lead 46 160 53 100 29 1-888
Chromium 80 80 12 40 100 5-3.000
Cadmium 5 5 1.6 3 .5 .01-7
Aluminum 30.000 30.000 2.012 15.000 71.000 10.000-300.000
Zinc 2.700 2.700 102 300 90 1-2.000
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TA~ LE 3
Compound
Water Quality
Criteria (ppb)
Act i on Level
in So il (ppb )
Requi red mi x.1 ng
factor
Toluene
340*
12.000
35
*Safe Drinking Water Act Health Advisory for chronic exposure.
Assuming complete vertical mixing. no lateral dispersion or diffusion. and an instantaeous release of all
the toluene to the groundwater. the required mixing would be obtained within 9 feet of the s011 containing
toluene.
Required mixing factor depth of soil
Distance from source to obtain required mixing = porosity x depth of aquifer x containing toluene
Where.
Required mixing factor = 35
Porosi ty = .2
Depth of aquifer = 20 feet
Depth of soil containing toluene
= 1 foot
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TABLE 4
COST OF RECOMMENDED ALTERNATIVES
A & F MATERIALS SITE
Recommended
Alternative
Cost
Comments
1) Soils and Sediments
- Partial Removal
$660,000
Includes excavation. transportation, disposal
and analytical costs. The volume to be exca-
vated is estimated to bp. 6.000 yd3.
2) Building and Equipment
-Cleaning and complete
removal
$120,000
Includes the costs of decontamination of the
equipment and building. collection and treat-
ment of rinsate, sampling and analysis, and
di~posal at a U.S. EPA aspproved facili~y.
3) Site grading
$44,000
Includes costs for filling depressions to
eliminate ponding. covering with topsoil,
and providing a vegetative cover to prevent
erosion. This will be done for the entire
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ATTACHMENT
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Section 1
PURPOSE OF THIS RESPONSIVENESS SUMMARY
This document has two purposes. The first is to report verbal and written
comments on the various remedial actions suggested for the A&F Materials
hazardous waste ~ite. The second is to document U.S.EPA's responses to these
comments. The remedial action options, including a recommended alternative,
were outlined in a draft Feasibility Study (FS) which was completed in
October 1984. A revised FS was submitted on January 18, 1985.
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Section 2
FEASIBILITY STUDY OVERVIEW
SITE BACKGROUND AND HISTORY
In 1977, the A&F Materials company began recycling industrial waste
materia1s--oi1s, sludge, caustic and sulfuric acids-- into fuel oil
and fire retardant chemca1s.
The Illinois Environmental Protection Agency (IEPA) received complaints
about the recycling facility soon after it started operations. IEP~
investigated and found the company violating numerous permit regulations.
The facility was shut down and abandoned in 1980. Waste materials were
left in storage tanks, lagoons, and in the processing equi~ment.
As part of Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), the waste generators who had store~
their materials at the A&F site were required to clean up the site
themselves and/or reimburse the state and federal governments for any
government cleanup actions. .
Several containment actions were taken by IEPA and U.S.EPA to prevent
nigration of contaminants into the Embarras River. A consent order
was finalized after a public comm~nt period in June 1984. In it four
companies--Aluminum Company of America (ALCOA), Northern Petrochemical,
CAM-OR Inc., and Petrolite Corporation -- agreed as part of a partial
consent decree with U.S.EPA and IEPA to do a complete surface cleanup.
These four companies (Consenting Defendants) are not the only respon-
sible waste generators; they are the firms that have consented to
undertake the cleanup. The cleanup, which the four companies paid for
themselves, is scheduled to be finished in August 1985.
CLEANUP ACTIVITIES
o
All'sludge and visibly contal'!inated soils from the lagoons have been
taken offsite for disposal. All liquid material from the tanks has
been either treated onsite or disposed of offsite. The tanks wer2
cleaned and removed from the site. Contaminated soil areas outside
of the lagoons were also excavated and disposed of offsite. The FS
was needed to determine the best course of corrective action for the
remaining contal'!inated soils.
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FS SUMMARY
The FS prepared by the Consenting Defendants recommended continued moni-
toring of groundwater. No other actions for groundwater were deemed
necessary because no groundwater wells are affected by the site and,
therefore, no health risks can be currently attributed to groundwater.
Furthermore, the high costs for operation and maintenance of groundwater
treatment systems do not appear to be justified.
. .
The Remedial Investigation (RI) determined that the aquifer underneath
the site is flushed naturally every 10 to 15 years. The RI predicted
that contaminant levels would remain near their present values for a
two to four year period and would then decline. A program of ground-
water monitoring would verify or dispute these predictions.
The FS prepared by the Consenting Defendants recommended "Alternative
A", the partial soil removal option, for dealing with remaining soil
contamination. According to Alternative A, soils in the four most
contaMinated areas would be removed and transported to a U.S.EPA
approved facility. Soils found to contain greater than 1 part per
million (ppm) of PCBs would also be removed and disposed of offsite.
The remaining soils and sediments contain low, levels of polynuclear.
aromatic hydrocarbons (PNAs). Levels are comparable to concentrations
found naturally in the environment and do not present environmental
or public health risks.
T~e FS also set various guidelines called action levels that will
guide soil removal activities. Soil that has concentrations at or
higher than these action levels will be disposed of offsi~e at a
U.S. EPA approved facility.
The sediment data in the RI showed concentrations well below the
~ggested action levels. Therefore, sediment will not be removed.
All buildings and equipment onsite will be removed and disposed of
offsite. The concrete foundation will also be removed and soil under-
neath will be sampled to determine if any contamination exists there.
()
'J
PUBLIC COMMENTS/U.S.EPA RESPONSES
The draft A&F Feasibility Study was issued in October 1984. A public
meeting was held on December 4, 1984, in the Town of Greenup, Illinois.
A three week cormnent period followed. It was extended an additional
two weeks to enable the public to more closely study the document. A
final FS was submitted to U.S. EPA on January 18, 1985.
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The verbal and ~ritten comments can be divided into the following
categor.i es:
o Soil and sediment
o Buildings and equipment
o Groundwater
Comments that required a response by U.S.EPA are summarized in this section.
Public comments are edited and sometimes paraphrased so similar comments
can be combined. The intent has been to present the full range of topics
without lengthy repetition. Groundwater issues will be addressed in a
separate document.
SOIL AND SEDIMENT
Coimlent:
"The RIfFS missed widespread areas of soil contamination because of errors
in the soil sampling program. A 1980 remedial action covered up contami-
nated soil offsite with clean soil from a nearby hillside. The RIfFS
sampling program failed to sample and analyze this contaminated soil below
the hillside.1I
u.S. EPA Response:
Originally. three areas of highly contaminated soils were found onsite.
They are called "highly contaminated" because they contained conta"ninants
at levels that were significantly above levels normally found in the
~nvironment. These highly contaminated areas were in the two tank farms
and around the western edge of the processing section of the building.
Additionally. a small area of soil contaninated with 1 ppm of PCBs west
of lagoon 1 was identified. Soils in all of these areas have been or will
be removed from the site and disposed of offsite at a U.S.EPA approved
facility.
There were several areas of lightly contaminated soils found generally
west of the waste 1 agoons. The term "1 ight1 Y contami nated" refers to
soil that contains low levels or traces of contaminants that have no
health or environmental concerns associated with them. In other words.
lightly contaminated areas have concentrations of chemicals that might
naturally occur in the environment.
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. .
In 1980, 1 foot of soil was removed from the west part of the site and
covered with clean soil. Samples for the RIfFS were taken in that area,
including samples at depths of one to two feet, that would pick up any
contamination-under the clean soil. The Consenting Defendants and the
Illinois Attorney General's office also resampled the soil in December
1984 to depths of 4 feet. Hazardous substances were not found in the new
samples; however, aliphatic hydrocarbons were found at low levels. The
Centers for Disease Control has reviewed these results and found no health
problem. The Consenting Defendants will be required to resample this
area at various depths, up to 4 feet. If this area is contaminated
with hazardous substances, the. soil will be removed.
U.S. EPA, therefore, believes that samples were taken deep enough to find any
existing contamination. U.S. EPA believes that the RIfFS sampling program was
sufficient.
U.S. EPA believes there are no data to support that remaining soils present a
threat to public health or the environment.
COI1I11ent:
Leaving soils may present odor problems, particularly in the summer months
and during wet weather.
U.S.EPA Response:
Buried contaminated soil should not be an odor problem. There appears,
~owever, to be an indication that decomposition of organic materials that
produce methane and other odor-causing compounds, common in marshy areas,
could present an occasional odor problem. In any event, according to
the recommended alternative, the site will be graded, depressions will
be filled to prevent ponding, and topsoil will be added. This mayor
may not affect possible odors from the site. The odor problem which
was preseAt at the site in the past will have been eliminated by the
removal of the lagoons, tanks and highly contaminated soil from the
surface of the site.
Comment:
Is the soil underneath the building foundation contaminated?
U.S. EPA Response:
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. .
I '
When the foundation is removed, the soil will
contaminated, it will be removed and disposed
action levels stated in the FS will determine
levels in soils will justify their removal.
be sampled. If the soil is
of offsite. The various
whether the contamination
Conrnent:
U.S. EPA should make sure the topsoil between the site and the river is removed
because groundwater flows through thi~ area and could then become contami-
nated .
U.S. EPA Response:
The soil in the field does not contain levels of contaminants that would
present any threats to public health or the environment. . Therefore , removing
the soil in the field between the site and the river is not necessary.
Conrnent:
One letter said that IIblack yuckll was dumped on the field between the
river and the site and that no crops grew there until clean dirt was put
there.
U.S. EPA Response:
-:
The soil in this area was removed and placed west of the fenceline in
1980. The area has been sampled to depths of 4 feet. No contamination
was found. Toluene at 0.8 parts per million (ppm) was found, but such
levels do not pose health or environmental threats. (U.S.EPA water quality
criteria state that 35 ppm is the level that would present environmental
threats. In addition, levels of toxic chemcials in soil can be orders of
magnitude higher than the levels in groundwater before they become health
threats. )
COI1II1ent:
Sediment in the drainage ditch should be removed.
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~
~
U.S. EPA Response:
The suggested action levels do not pose a threat to biota. Therefore.
sediment removal and disposal is not recommended at this time.
BUILDINGS AND EQUIPMENT
Comment:
Buildings should be completely removed because therre is always'the
risk that sampling might have missed some contamination.
U.S. EPA Response:
The building and its foundation and all equipment will be removed and
disposed of offsite. Soil under the building foundation will be sampled
and if there is any contaminated soil or other materials found they will
be removed.
MISCELLANEOUS
Many letters and verbal comments expressed concern and a desire for a total
cleanup. Many letters said the site should be returned to the same condi-
tion it was bedore A&F Materials began operations.
U.S. EPA wholeheartedly agrees that the site should be left in a condition in
~hich it presents no danger to the public and the environment. The Agency
believes that the recommended alternative accomplishes this goal.
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