United States
environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO
-------
TECHNICAL REPORT DATA
(PlellU retld I"structions on the 'e~ene /Hfore completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-85/026
.. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION SeDtember 27. 1985
Acme Solvents, IL 8. PERFORMING ORGANIZATION CODE
7, AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
8. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD ReDort
401 M Street, S.W 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460
800/00
15. SUPPLEMENTARY NOTES "
18. ABSTRACT
The Acme Solvents Reclaiming, Inc. facility is located approximately five miles
south of Rockford, Illinois. From 1960 until 1973, the facility served as a disposal
si te for paints, oils and still bottoms from the solvent reclamation plant located
in Rockford. In addition, empty drums were stored onsite. Wastes were dumped into
depressions created from either previous quarrying activitie~ or by scraping over-
burden from the near surface bedrock to form berms. In September 1972, the Illinois
Pollution Control Board (IPCB) ordered Acme to remove all drums and wastes from the
facility and to backfill the lagoons. Follow-up inspections revealed that wastes and
crushed drums were being left onsite and merely covered with soil. Sampling of the
site revealed high concentrations of chlorinated organics in the drinking water. The
major source of hazardous substances at the facility are the waste disposal mounds.
These mounds contain volatile and semi-volatile organic compounds and concentrations
of PCBs up to several hundred mg/kg.
The selected remedial action includes: a provision for an interim alternate water
supply to affected residences by installation of home carbon treatment units; excava-
tion and incineration of waste materials and contaminated soils, with disposition of
non-incinerable wastes to an offsite RCRA landfill; continued investigation of bedrock
contamination and remediation; continued investigation of contaminated ground water;
(continued on separate page)
17. KEY WORDS AND DOCUMENT ANALYSIS
Ia. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI Field/Group
Record of Decision
Acme Solvents, IL
Contaminated Media: gw, soil
Key contaminant~: VOCs, PCBs, vinyl chlorid e,
TCE, inorganics
. 18. DISTRIBUTION STATEMENT 18. SECURITY CLASS (TlJis R,po"J 21. NO. OF PAGES
None 50
20. SECURITY CLASS (TIJis POI' I 22. PRICE
None
!,~ Po,m 2220-1 (R... ..-n)
P"EYIOUI EDITION II OBIOLETE
..
-... . .-. . '.-
-------
INSTRUCTIONS
1,
REPORT NUMBER
Insert the [PA report number as it appears on the cover of the publk;alion.
LEAVE BLANK
Z.
3.
RECIPIENTS ACCESSION NUMBER
Reserved for use by each report recipient.
TITLE AND SUBTITLE
Title should inditate dearl)' Ind brien)' the subjr.:t cover;a~ 1)( the report, ;and b.: disl,I;!)','d rrulllin.'nll)'. S.'t suhlitk. if uSL'.I, 11\ ~milliL'r
type or otherwise subordinate it to main title. WIleD a report is pn:parN in mor,' than "n,' \'\Ilumc, "'p'ill Ih,' prilllilry litl... iI.ld vuhlll1\'
number and include subtitle for the specific title. .
4,
..
tllPORT DATE
Each report shaD carry a date indicatinl It !eait month" Ind year. Indkate th.. hilsis UII v..hkh it W;I\ ",,'Ic..t,'d (",~,. .}QI., "f in".,. JQI., "f
tlpprowll. dil" 01 ""Ptlftltion. IIC.).
PERFORMING ORGANIZATION CODE
Lea.. blank.
..
7.
AUTHORISI
Give name(s) in conventional order (John R. Doe. J. Rober' Dot', ("c). Li~t iIuthur's iIfliliiltiun if it Jit'l",'rs frum Ih., I,,'rfmlllina: ,,,,;ani-
zalion.
L
PERFORMING ORGANIZATION REPORT NUMBER
Insert if performina orpnization wishes to assign Ihis number,
t.
PER'ORMING ORGANIZATION NAME AND ADDRESS
Give name,strect, dty, stlte, and ZIP code. List no more than two leveli of iIn urpnizilliunill hirear\'hy.
10. PROGRAM ELEMENT NUMBER
Use the propam clement number under which the report WilS prepared. Subordiniltc numbl:r, lIIiI)' bI: ind,,,,...1 ill l'iI"'lIlh.."".
n. CDNTRACTIGRANT NUMBER
Insert contract or pant number under which report Wa5 prepared.
12. IPONIORING AGENCY NAME AND ADDRESS
Include ZIP code.
13. TVPE OF REPORT AND PERIOD COVERED
Indicate interim fmal, etr., and if applicable, dates covered.
14. .-oNSORING AGkNCY CODE
Insert appropriate code,
1.. SUPPLEMENTARV NOTES
Enur information not included elsewhere but useful. such .~:
To be published in, Supersedes, Supplements, etc.
1.. ABSTRACT
Include a brief (200 words or 11$1) factual summar)' of the mosl si~nilkant informillilln .'onlilin,'d III Iii,' f"l'lIrI. IIlh.. f"I'"rI ."".1;'"".1
sisnific:ant bibli08l'aphy or literatwe survey, mention it here,
Prepared in cooperiltion wilh, '1'rill1slilli,," "... l'r""'I1I.." ill "'''''''''''11'''' "...
17. KEV WORDS AND DOCUMENT ANAL VSIS
(a) DESCRIPTORS. Select from the The5lurus of t:nlineerir.1! iInd Sd..nlitk Terms Ihe proper ilulhuri/\'J 11.'1111' IhilllJl.'nlil'y Ih.. llliljur
concept of the research and are sufficiently ipecilic and pred5C to be u5Cd ilS inJc, entries for I:alaluj:,"~,
(b) IDENTIFIERS AND OPEN.ENDED TERMS - Use identifiers for project namLS, cude names, c4u1pm..nt JI."I~nillors, cll:. UW"I'ell-
ended terms written in desc:riptor form for those subjects for which no cleilCriptor ell:isb.
(I:) COSATI HnD GROUP. Field and poup Issipmenturc to be ukcn from the 1965 (,05A11 Sul*1:1 (';11"J!my Usi. Sinc~' the ma-
-jorit)' of documents are multidiKiplinary in nature, the Primary "ield/(iroup assilnmel1tfsl will bI: ,pc,'ilk Ji"'lr'inl.', a"'iI III' human
endeavor. or t)'pe of physical object. The application(s) will be crois-referen\.'Cd with w,'unJilry I il'l,I/( ;ruul' ~"II!"lIIelll' Ihal 10'1111"11..,,
the primary poslinalsl.
18. DISTRIBUTION STATEMENT
Denote releasabilit)' to the publi\' or limitation for reasons other than Sl:l:urity fur I:"amrle "Rclca'\' tillhlll",',I," ('Ill' illIY iI~;lIla'Hh')' I..
the public. with address and price.
1.. II 20. SECURITV CtASSIFICATION '
DO NOT submit dassified reports to the National Technic:allnformation Sl:rvke, ",
21, NUMBER OF PAGES
Insert the total nu!"ber of pases. includina this one and unnumbered pages, bUI udude distributiun list, it ilny.
22. PRICE
Insert the price set by the National rechnicallnformation Service ur the Government Prinling Oml:C, if' knuwn,
E PA ,.,'" 2220-1 (Rn, .-771 (R....,..)
-------
. .
/
,
SUPERFUND RECORD OF DECISION
Acme Solvents, IL
Continued
and performance of pump tests to evaluate the effectivenss and cost of plume
control. Estimated capital costs will be determined during the design phase
once an incineration technology has been selected.
-------
--
REMEDIAL ALTERNATIVE SELECTION
SITE
Acme Solvents Reclaiming Incorporated, Site, Morristown, Illinois
Documents Reviewed
The following documents which describe the physical characteristics of the Acme
Solvents Reclaiming, Inc., Facility and which analyze the cost-effectiveness of
various remedial alternatives have been reviewed by U.S. EPA and form the basis
for this Record of Decision (ROD).
- Field Investigation Team Report, March 1983
- Acme Solvents Remedial Investigation Report, November 1984
- Acme Solvents Feasibility Study, February 1985
- Review of RIfFS work on the ACME Solvents Site, June 1985
- Summary of the Remedial Alternative Selection
- Community Relations Responsiveness Summary
Description of Selected Remedy
The selected remedy consists of the following major components:
;
;,
- Provision of an interim alternate water supply to affected residences by
installation of home carbon treatment units
- Excavation and incineration of waste materials and contaminated soils,
with disposition of non-incinerab1e wastes to an off-site RCRA approved
hazardous waste landfill
- Continued investigation of bedrock contamination and feasibility work
to analyze the effectiveness of bedrock remediation
- Continued investigation of contaminated ground water and performance of
pump tests to evaluate the effectiveness and cost of plume control
Cost
The estimated cost of the above actions will not exceed a present worth cost
of $24.0 million as itemized in the attached Summary of Remedial Alternative
-------
-2-
Declarations
Consistent with the Comprehensive EnvirJnmental Response, Compensation, and
Liability Act of 1980 (CERCLA), and the National Contingency Plan (NCP) (40 CFR
Part 300 et. ~., 47 Federal Register 31180, July 16, 1982), I have determined
that incineratTOn of hazardous materials, disposal of non-incinerable hazardous
wastes at a licensed landfill and installation of home carbon treatment units for
the affected residents is a cost-effective remedy and provides adequate protection
of public health, welfare, and the environment. As part of this decision, bedrock
grouting will be analyzed for its effectiveness in blocking the migration of
contaminants located in the bedrock, the effectiveness of ground water plume
control will be evaluated and further ground water monitoring will be conducted.
The results of this feasibility work will serve as a basis for a future Record of
Decision regarding final remediation of the bedrock and ground water. The State
of Illinois has been consulted and agrees with this remedy.
The action will require future operation and maintenance (DIM) activities which
will be funded by the State of Illinois. EPA will fund 90% of the DIM cost for
the remedial actions approved in this ROD for one year.
"
~' ,
I have also determined that the actions decribed herein are cost-effective when'
compared to other remedial actions reviewed in accordance with the National
Contingency Plan, and is appropriate when balanced against the availability of
Trust Fund monies. Additionally, in the event that a small quantity of soils and
drums or other hazardous materials are not incinerable, the off-site transport
and secure disposition of a relatively small amount of waste has been evaluated
as cost-effective in the feasibility study cited in this ROD.
.9r"o:?1 J 1'15.5
!M-~ ~ ~)
Valdas v. AdamKus
Regional Administrator
-------
.
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
ACME SOLVENTS RECLAIMING, INCORPORATED MORRISTOWN, ILtINOIS
SITE LOCATION AND DESCRIPTION
The Acme Solvents Reclaiming, Inc. Facility is located approximately five miles
south of Rockford, Illinois near Morristown, in Winnebago County, Illinois (Figure
1). The approximately twenty acre parcel is located in an area of broad, rolling
uplands that exhibit 10 to 200 feet of relief and is drained by the Rock River and
its triburaries. The surrounding land use consists of agriculture, quarries, and
low density single family residences.
The access road to the site is adjacent to a private residence. However, the
waste deposits are nearly one quarter of a mile from the nearest residence. A
substantial number of homes exist on lindenwood, Edson, and Baxter Roads (Figure 2).
Horses graze 1n the pasture immediately south of the facility.
An intenmittent stream runs south of the site and cuts across the access road.
This stream is a tributary to Kil1buck Creek which in turn em~ties into the
Kishwaukee River which shortly thereafter empties into the Rock River. With the
exception of the Rock River, surface waters downstream from the facility are not
used as a public water supply.
Directly beneath the site. and even exposed at some locations, is the Galena-
Plattev11le Dolomite. This formation is extensively used for private domestic
water supply wells. Regionally, the Galena-Platteville is hydrologically con-
nected to the lower more productive aquifers that are used for pUblic and in-
dustrial water supplies. Therefore. the lower aquifer is also endangered by the
contamination migrating from the Ac~e facility.
~
.
.
SITE HISTORY
Acme Solvents Reclaiming, Inc. operated the facility from 1960 to 1973. The
facility served as a disposal site for paints, oils and still bottoms from the
solvent reclamation plant located in Rockford, illinois. In addition, em~ty'
drums were also stored on site. Wastes were du~~ed into depressions that were
created from previous quarryin~ activity or by scraping overburden from the near
surface bedrock to form berms.
In September of 1972, the Illinois Pollution Control Board (IPCB) ordered Acme
to remove all drums and wastes from the facility and to ~ackfill the lagaons
after such waste removal. Follow-up inspections subsequent to this Order revea1e1
that the wastes and crushed drums were ~eing left on-site and merely covered with
soi 1.
Releases from the facility were first doculi\ented when 1earby residents experierlc';!d
a sulphide-like smell emanatiny from their drinking water which was o~tained fro~
private wells. Sampling and analyses revea1e~ high concentrations of chlorinated
organics in the drinking water. The concentr3tion of s~ne of these chemicals ~n
four of the private wells exceeded available health advisories set by the U.S.
Environmental Protection Agency (USEPA) Offi:~ of Orinking Water. The IEPA reco~-
mended these wells not be used. An altern~t? water supply (bottled water) has
been supp1ie~ since 19R1 by the owner of Pagel's Pit Landfill which is 10c~te~
-------
"'/ ';..ll~ ~~:~f.:t:~~li:;~'-'.k~~j~~~?~~~~A~(~: }~/~;!~';;:!.1g}J,;::~ ;;~e;:;lf:i.fhl~';"'li";;\:' ~l"-..t' :.'. '
. .. "'" f" \"', .,"" ... ' ,'" .,"'. .,; ,~'... ",," ,'1:' -, .", I ',', ..I.,' '''', . '. . 'Y'" "!.i, I"'. ",...... ""'" '
,.. . ~". . .... ~''''''''-''~~' . .~.. ~.-!t."'" . ""'! r ,I .,~ t.: :'...........' '11?' .:. .,.... #' JtI"..". #.... ...... .
. .. ';'-' :. ..~'.:r,t:-'.~".~...-,,,.~....ot;;..., ....-.~.:",~,.;. ...:.~'. :..."'..::.-:l.;~r~ ~(&"'...,~." ..~. ';i,.,~'1,'1i '-i ...!,".'t....J ", "'..........-.~ .'
:. '., '. ""'.!""""":"2~''''''~'''i\t''' "',:r-:~...".., ":t"~,1:1:""'!'P,..,.~"."..t:,,,,:,,"I...,,,, '~..,'.., '.... ~."'~"""'.4',J:4J-~'N. " ,
'.. ':;., ,,'~,:." -or,,'.' .I,~,t,;y,...'(",......:{ ~i.;,'\";':"~~':r','::.f'~"""'''':~~.r~I''.~",.,~.~..."..~1'''~''~~~':'\I~''''',r'':'''-.'~,-,,:'. ~':,:.:-~,.JL'~"" ,
..~ """, ,:., "~:~!:"~.J~:~:~,~'~"'~~'~::~.?':: ;',~','::'1( ;:;t-~k:-iii"~~!~I:~~t;"~~:.~~~,~::;~;~~~Jtt4;'~:l:..;..~'7:~t)~,~j)~~:';'tijI.(j-':V=:~;;:,: .
~ '':> .. i." ". "'..' :t",~, ' 'f ..~~ , ,.' """", , ~', ;"""',~,. . .'1' ':j.'" ,;;.: ,~,.t.',. ..... ~',.,~ """ ", ""~"" " ~. ~'!.'i~:J.::i.;" ," ..! ,'c"; '.' I
. ;;;:. 9';;'",.; ~ ","'i~~£\;~f~!~~&~~"':~~,'J~'~:;:';,' ::~"~L'J.~;;F::~r.~f."~~::~~!l.~t~:~ !.~~~'t'~!"!iU;Ji,;;,:' ';'" .
~:.:~..;'~~'. " ",;'~....' '" ,,:'::::- ..:~~~~'_£1,~~-~: .-, ~,......~, '" .~::.. !,;~: ,~:., ,~.. "":'., ._:' :=",. ':"'" .'.,.- .'
"~"~,r~' ~' . '~:~,' , . ,- '"..t'.~, "':'('f"I";.~":=-I""d~ :~;.;,."hJ'i<'~!" ~.,f~~ '::'~..I"",~,.!' ~~~rF"'!I:;;~~:''';'ITi'lo~''''''.'f::t ,~:.T.:q:~~. ''':1c:~::' ,', ">,
' 'fir."" 'o!')t. ~ ~ , '~~, .. :. . ~.;.. ~ i~. _I~ ~';".t:':..:""'':''~''''::i'';,~~ \f', ....", T' h'~ ""7~1;:" "~" "I" Ct.~~".-i't'i,?/~>~t~" ~'~. ...-:, '~;>:t:t't :t.4'~'t ..ki~''-' .t:' '..a"'~ .t'; ,
"':':: ~, .' ~'" --:":;;,.~..: t.H;~~~~~~;;;,\'-~;'~:;:;~ ":~ iilitr':~{~::~ ," ~;l,:ii.~;::':~~'<':'~~/::;~:;'~:_'~""'~"~~;'-~" ;J~~;'L :":..,',;',:;" ",,,,:,,,,
". .-... ...., ..'&.t&I.I ....,,~.~.. ... '. It..- ~:.....;.L.e... . .....~~ ",,-' .,IIt.tii&....... ::=:! ....I&...,.........:......'~""""""~. ~ .:...a,~:::....,,~
I\CtJtr:.
'I
#.. ~.~...;:~
'"" . ~,.' -,
w" "';..,'
"6",*i'" ,. '\
1f: . .' ,',f"
. ; ,
,
if'''~,-"", '..;;' &;"'!\',.;rl..~: l ~1'tlC.,.~.a' ,
""'r""" ,.,' -,. 'r", :'.. .-'., 'it"
~ ' ,'::., ..".".:..I.,.~'~' ":',.:", ,~,!~ ..: '::~~ '
, . ,,~";~4. 1',:-';"':'" "S":.:.;i, ~'i ...', ..L', ,.',2io .;, '
- ' ~~~.' . '0" :t'.. ' '.4" I ,a., ~.
6 I! ".'r. :,'~~':.,.~ ",:.~", :":;~!':" "".1 I.
. .
, '
.
..
'~
, .
.'
'. -w' ., :J"l."..~'-'
'.~;"; ,~*":,.~,'
I'". ,I' . "
"" ~ I..~, '~:
.. " 'a '. '"':
.,~
.!.a.,
'..
'"
"
.
.
,. "'.f
'.., ,
..'" - "'," .(
.. ... ~~,~ , .'~.
, 't "
,','"
. , .
, "
.
"
. ,-:!/~.t /' ':',
. . . .;
~:~w
'(;'; '. ..
',',"':
. T j.t~';1 ,I J ~ . : '0\ -!r'
ii.f,:;. ,..,r~\~'
,
,
.. '
/
. .
. ,l... '
", "
I
, .
"
, . '", , ~ .
.. .... .,. , ....
....,~........'~.. "
".' "...--a-
. '
'.'.
"
",.... .. .
~r .. "
... \
, .
"
"t::
"
'," '~
\.
.'
"
.,.'"
.' ,\ ~
''\
-,,1:~, ..~ ';~)",::.,i',
"
'''\.~..'!' ','
i 1:. :-
,,:~~ '
, ,
I"
. ,
,
i
1
, ~
. j
I
i ~
~ ~.J... c..
. e' .
.. ' , '.t,"', 'II
:. ),::'t.tn,
.', ',"" t.'jI
~ !:'~:, ',~'~>::;
", l' "." 'I
',! I ~ ',-.r.' ".' ;
,,' ., .~;,' ,,:
~ ';,,:
II-,"!'
. -' , '.
~
I .
/'~'
'''-'-' "-"-"''''---'.
'; ,',
"',
. .
"
'.
'.
.
,'.~ ~ ,~,~ .
,;,,:,,:< ' " ~~'
~.:~'t~' , '.~,~".;
". ':.~ i . ..
. ,
t'~ of', !...,..~!
iI', ",:' ,'.,1
.a '"
, iJ
'-
"
~.' .
,
,f
-------
, ,
i ;
. '
i i
. "
~ . ~:
.: t
Baxter Road
"
WINNEBAGO
COUNTY
)
"
~
.
.
.
.
PaGe'l
Pit
Klllbuck ~
Cr"k
N
"
o
o
cr
Skeet Club
,
. ,....
..
.
8 I
8.- h .,~
'-I ,.8 -4
Edlon Road
-
($11' Ar,. tOC.IIOll)
FIGURE I. Site Location Map for Acme Solvents
-------
~
across the street from Acme. Pagel's Pit was inclurled on
update to the NPL due to potential and measureable 9round
The relationship between Acme Solvents and Pagel's Pit in
water contamination in the area in not fully understood.
Solvents Remedial Investigation states that there appears
plumes.
thp. second proposed
water contamination.
regard tD the ground
However, the Acme
to be two distinct
.r
CURRENT SITE STATUS
The major source of hazardous substances at the facility are the waste disposal
mounds (i.e., covered lagoons and drums). The primary waste deposits are shown
in Figure 2. These waste disposal mounds contain volatile and semi-volatile
organic compounds in concentrations ranging up to several thousand milligrams
per kilogram (mg/kg) and concentrations of PC~ up to several hundred mg/kg.
. Materials with flash points as low as 25°C were found in some locations within
the mounds. In addition, concentrations of arsenic, lead, cadmium and chromium
above background levels were detected within the upper two feet of surface soil.
The total volume of the contaminated materials is estimated to be approximately
26,000 cubic yards, if cleanup to background were implemented. This estimated
volume was based on contamination measured during the remedial investigations in
the area, depth to bedrock, extent of disturbed soil and height of mounds.
Drummed materials are included in this volume estimate. Based upon inspection
reports prepared by the IEPA, both when the facility was in operation and when
it had been closed, most drums were empty and were crushed prior to burial.
There is no readily apparent pattern to the type, concentration, or distribution
of chemicals in the surface mounds. A summary of concentration data for chemicals
found in the test pit samples is presented in Table 1 in the Appendix.
The type and concentration of the conta~inants as described above pose a high
hazard to any person who would make direct contact with the buried wastes.
Continued weathering of the earthe~ nOJncts covering the buried wastes increases
the chances of exposure and promotes the spread of contamination overland and
into the nearby creek. In a few places the wastes are actualiy exposed. Typic~lly,
the contaminants exhibit a hazard potential as little as two feet beneath the
surface of the mounds. This hazard is expected to increase sharply with deptn
into the mounds. The waste material, then, acts as a constant source for gro~nd
water contamination in the Galena/Platteville aquifer ana eliminates any utility
of the facility for the future. This co~ta~ination, if left unreT~diated c:n
only further degrade the environ~ent.
t
.
.
The highly permeable soils and weathered dolomite bedrock directly underlyi~g
the waste disposal mounds are likely to contain high concentrations of chemical
contaminants due to downward percolation of contaminated aqueous leachate and
organic solvents. The depth of conta~i~~tion in the unsaturated zone 1n the
. bedrock is not documented, but likely ex~ends to the water table, as has been
indicated by the nearest monitoring wel; ~/hich has shown concentrations of
contaminants known to have beer. deposited at t1e Ac~e Facility of several parts
per million. Because of varying topo~r~phy the depth to groun~water varies but
is generally 25 feet. Therefore, the so;1 a~ove t~e bedrock, and ~edrOck itse1f
are contaminated to groundwater. The g~~~~~l horizontal flow directions i~ t~e
area are west, southwesterly with so~e IJca1 radial dispersion.
Off-site contamination consists of a gro~n~dater contalnination plu~e migra:ing
from the facility. The distribution of t~tal volatile or~~nic chemicals affec:s
9 oomestic wells now and possibly 7 more in the near future. Concentration 1~:a
for organic compounds in groundwater is S~0wn in Table 2 in the Ap~e~dix.
-.~. .. .-. -,. .'
-------
Based on the RI data and data provided in the Field Investigation Team
and IEPA Department of Public Health reports. many of the volatile cOlnpounds
provide chronic health risks and some are carcinogens, such as vinyl. chloride
and benzene or suspected carcinogens such as trichlorethylene (TCE). Data
provided in the early 1980.s, from the 111inois EPA show that residential
drinking water had been contaminated by volatile organics similar to those
found at and beneath the Acme Solvent site. Concentrations of vinyl chloride
and TCE have exceeded health risks of 10-5 unit cancer risk level in the
aquifer beneath the site and off-site. This theoretically means that 1 to 2
persons out of 100,000 people drinking this quality of water, 2 liters per
day, over a 70 year period would contract cancer. Trace metals, such as
lead, arsenic, and barium are some of the metals found in the ground water
but not in the drinking water 1n substantial amounts. However, these
inorganic compounds also provide a health risk if they migrate to the
drinking water wells. Some volatile organic compounds were detected in air
samples, especially when test pits were opened. These results are summmarized
in Table 3 in the appendix. There is no threat to public health or the
environment from air releases from the site as it currently exists. However,
during excavation of waste materials air e~issions will need to be monitored
and controlled if necessary.
No surface water or creek sediment contamination was discovered during the
RI, but trace levels of organic compounds were found during the 1983 Field
Investigation Team sampling effort at a spring near Pagel's Pit landfill.
This spring contains water coming through both the Acme and Pagel's Pit
sites and empties into Killbuck Creek.
;
a
The most obvious receptors of any release of hazardous substances from the
facility are the nearby residences located within 1/2 mile from the site.
Currently, there are nine affected private wells with the potential of
nine additional private wells becoming conta~inated. Most or all of these
wells draw water from the contaminated upper aquifer. Also, the highly
productive aquifer beneath the shallow aquifer may potentially be a receptor
of contaminants migrating with the ground water thus damaging future use of
that aquifer. .
In addition, humans and wildlife may com~ i~to direct contact with the
hazardous waste materials on-site and in the creek if this becomes contami-
nated in the future.
Similarly, at least 20 acres of the Galer.a/Platteville (surficial) aquifer,
off-site, is now documented as contaminated and could be much more (higher
than 100 acres) if the contamination around pagel's Pit is attributable to
the Acme Solvent site. This will be better understood with further ground
water investigation.
Because of the above hazards the site scored 31.98 on the Hazard Ranking
System.
ENFORCEMENT ANALYSIS
There have been over 60 Potentially Respo~sib1e Parties (PRP) identified for
this site. A group of approximately fJrty of these have organized for the
purpose of negotiations. Factors that seem encouraging in reg~rd to reaching
a settlement are the number and financial reso~rces of the PRP. Currently.
negotiations are underway and a decision to settle or provide fund fi~ancing
on the ROO response objectives seems possi~le within a short time. The
negotiations status is Attacment 2 to the ~p~e~dix to the RO~ and is
enforcement confidential.
--'.-'.'-."'.-"-".' ".,0 ..
-------
RESPONSE OBJECTIVES
~,x response objectives to be met by the remedial action proposed by this ROD
for the Acme Solvents site are:
(1) To provide drinking water that meets appropriate Federal drinking
water criteria in the surficial aquifer.
(2) To ensure that drinking water quality, that satisfies objective 1,
will be maintained at the currently affected homes along Lindenwood
and Edson Roads and other nearby residences not currently affected
by the contaminant plume
(3) To prevent degradation of the deeper aquifer in the area, chiefly
the St. Peter sandstone and the Eau Claire formation
(4) To maintain the surface water quality in Killbuck Creek at levels
designated by the State of Illinois
(5) To eliminate health risks associated with contacting hazardous
materials on the surface and in subsurface soils for current receptors
and possible future onsite receptors
(6) To maintain ambient air quality for on-site and off-site receptors
To meet these 6 response objectives, a variety of remedial alternatives were
developed to meet the response objectives by combining technologies that had
passed an initial screening process. Com~ining different technologies was
necessary because individual technologies would not in themselves remediate the
release of hazardous substances from the site. The alternatives that remained
after the initial screening and went through the detailed evaluation are shown
in Table 5 in the appendix. The initial screening and the detailed evaluation
processes are consistent with 40 CFR Part 300.68 (g), (h) and (j). The detailed
evaluation process consisted of cost and non-cost analyses. The first step of
the cost analysis was to develop cost estimates within a range of -30 percent
to +50 percent. Cost estimates were broken down into capital and operating
costs. All costs were expressed on a present worth basis, which considered the
technical and monetary cost-effectiveness. Non-cost related evaluations included
three major factors; technical, environmental and institutional. Ten specific
parameters were identified as evaluation criteria and evaluated for effectiveness
in meeting site response objectives. This detailed analysis is provided in the
FS. The final step of the evaluation process was to combine the results of. the
cost and non-cost evaluation to develop an overall ranking ~f cost-effectiveness.
The combination of source control and migration management remedial alternatives
that most effectively comply with the National Contingency Plan (NCP) and is
cost competitive with other alternatives is considered the most cost effective
remedial action.
--.
-------
ALTERNATIVES ANALYSIS
A number of aTternatives. were analyzed to meet the response objectives and to
comply with the NCP and pertinent environmental laws. Various combinations
of alternatives were evaluated for source control including treatment of
the soils, sludges and drum contents; the ground water beneath the site;
and the residences' wells.
1)
No Action Alternative
The No-Action alternative would essentially condemn future land use at the
facility by allowing a continued release of contamination into the environment;
provide a hazard to a receptor by direct contact with wastes that would
through weathering, become exposed over time; and would adversely affect the
ground water quality such that expansion of the plume with time would further
degrade the drinking water quality to a chronic health risk level exceeding a
10-5 unit cancer risk for users and potential users of the aquifer. This
health risk is higher close to the site boundary. Also, within time, the area
surrounding the facility may become less rural and more suburban; thus,
future population would be exposed to the health risks exhibited in the
aquifer. The tributary to Killbuck Creek which runs by the site may have
been slightly contaminated runoff from the Acme FaciJity and with the passage
of time due to weathering the probability of contamination will increase.
The tributary feeds into Killbuck Creek, about 4000 feet away from the site, at
which point surface water quality criteria apply.
Residential Well Contamination (Interim Measure)
2)
Four of the nine affected residences in the vicinity of the Acme Facility
have been receiving bottled water from Pagel's Pit. The FS evaluated three
viable alternatives that would remedy drinking water for the currently
affected users and the 7 potentially affected residences. The alternatives
are: (1) extension of the City of Rockford's water main to service the
residences, (2) home carbon treatment units for treatment of water for all
domestic uses for 9 currently affected residences and ground water monitoring
and (3) construction of a deeper or appropriately located community well.
The carbon units are less costly than the water main but the water main
provides a permanent remedy for all future users and is a reliable source of
acceptable drinking water quality. Carbon units can remove organic compou~ds
properly but are dependent on individual home owner's knowledge and operation.
Institutional controls are necessary to ensure acceptable operation of the
carbon units to meet drinking water quality.
The Winnebago County Health Department has the responsibility to monitor
. private well water quality and is aware of the proposal to install carbon
. treatment units in the County. The County is aware of the range of Volatile
Organic Compounds (VOC) in the drinking water supplies and has the
instrumentation necessary to monitor these compounds shown in Table 2 in the.
Appendix, at levels that will assure compliance with appropriate Federal
water quality standards or ambient water quality triteria. Due to the cost
difference between the Rock ford water lI~ai;'1 and the maximum of 16 home treat:r,e;;t
units, estimated as potentially contaminated, the Agency has decided to fund
the home units until a pennanent water supply in the locally affected area is
implemented. A permanent water supply alternative may be selected after
additional ground water i"formation is obtahed.
""".-"~,--"""'-"""".:
-------
- ,
-6-
COSTS OF RESTORATION OF RESIDENTIAl WATE~ SUPPLY
Cap_i tal.f~st
Operat i n9
~os t ..2!!l'_.1ea r
Total Present Worth
Comment
A] Installation of Carbon Home
Treatment Units, (for 9 23,625 15,500 146,103 Publicly acceptable.
contaminated residences) but uncertain for
IJ Development of Upgradient
Well and New Community
Water Supply System 388,730 8,710 467,120 Publicly acceptable,
easier to monitor and
thus more reliable to
operate and maintain.
C) Extension of Rockford Water
Supply System 915,000 560 920,000 Most reliable but also
most expensive alter-
native. Requires 4
mile force main.
NOTE: Present Worth is determined on a 30 year basis at 10%.
Operating cost for Alternative A includes monitoring
costs for nine affected wells and seven potentially
affected well s.
. J
, 1
. ,
-------
3)
Groundwater Contamination (Feasibility -~~~qy)-
Off-site contamination has been well documented through sampling by the IEPA,
E.C. Jordan (RI), FIT, and recently by U.S. EPA. The groundwater requires
field studies to test the cost-effectiveness of a pump and treat option. The
containment protection provided by slurry walls are not practical for the
site because no continuous clay substratum or confining bed exists that would
allow a foundation for the slurry wall. Pump and treat options allow contain-
ment of the plume by hydraulically controlling its spread. Pumping also
desorbs the organic contaminants attached to the aquifer interstices, thereby
removing contaminants that would otherwise have a longer residence time in the
aquifer. The RIfFS could not evaluate the hydraulic flow regime in sufficient
detail to optimally locate pump-out wells. This effort is time-consuming and
costly and can be accomplished'with further on-site work at which time more
intense field work possibly including drilling additional wells and performing
pump tests of sufficient duration can be accomplished. This effort will
provide sufficient information to determine the location of wells, sizes of
pumps and range of .concentrations to hydraulically control and remove the
plume at or near the source (on site). A comprehensive ground water remedy
for the entire contaminated aquifer in the vicinity will be deferred until
further study is completed. This Record of Decision provides for funding
further feasibility study and the necessary field work attendent to optimally
locating those wells; determining their proper depth as required for pump
tests; Ind, the chemical analyses provided by steady state values of chemical
concentrations for measurement of compliance with criteria developed in
accordance with the Clean Water Act. This will provide the necessary documen-
tation for selection of a unit treatment process or processes for treatment
of the water.
.
.
.
.
.,
Bedrock Contamination (Feasibility Study)
There is a direct relationship between the chemicals deposited in the bedrock.
their release to the ground water, and the length of time required for the
~round water should become clean. Ground water contamination is well documented.
The rate of release of contamination from the bedrock can be estimated from
literature sources provided by the RCRA program. The volume of contaminants
and particularly the depth of contamination in the nonaqueo~s phase located
in the bedrock itself is not known. Since the groundwater be~eath the facility
is contaminated the bedrock beneath the waste must serve as a conduit for the
. transport of organic phase liquids and aqueous phase contamination into the.
.Iquifer. The bedrock also serves as a storehouse for future contamination as
the ground water and infiltration penetrate the fractures ftnd dissolve and-
disperse the contamination.
. As discussed previously. a slurry wall is not feasi~le to contain the contami-
nants at the site; however. using a cement grout, the bedrock could be solidi-
fied in such a manner as to prevent migration of wat~r into the co~taminated.
zones and thus isolate the contaminants. This concept is theoretically
plausible but must be further eval:Jated. rf prove11 feasible, and necessary;
and. later implemented. the release of contaminat;o~ into the environment
should be measureably decreased by the grout. Thus, this ROD recommends that
~ . .. .~'~.~r>"".""\~--.~.
-------
further feasibility work be conducted that would analyze and estimate the
depth and volume of contamination in bedrock which will determine the depth
and volume of grout, if found necessary and cost-effective to restrain migration
of water into the contaminated zone. That contamination already solubilized
and migrating beneath the highly contaminated zone of bedrock will be conCurrently
evaluated through further ground water feasibility study previously describej.
Further study of the bedrock, which will be performed by the IEPA under the
existing Cooperative Agreement (CA) with U.S. EPA, will determine the follow-
ing: (1) estimated depth and volume of dense contamination, (2) estimated
volume of grout necessary to contain contaminants, (3) the efficacy of grouting
the bedrock, (4) the analysis of the compatibility of the grout and contaminants.
(5) the estimated effect of grouting'on the duration of pumping on the site,
(6) the estimated reduction of costs associated with grouting versus the
duration of pumping the aquifer. The IEPA will amend the CA to fund this
on-site investigation. By performing the above tasks, the contractor can
define the cost-effective trade-off between the costs to remediate the bedrock
to the costs for treatment of the aquifer.
If shown effective, the grout will serve as an impermeable layer to retard
both horizontal and vertical flow of water infiltrating through the site. If
grouting is determined to be infeasible as a result of the tests performed in
the feasibility study, longer term ground water remediation, or other options'
would be considered for treatment of the ground water.
Surface Contamination
5)
With respect to the solid contamination existing above the bedrock on the site.
the greatest amount of treatment permutations exists. The combinations of
treatments for the source material were related to compliance with other
environmental laws. .
~
.
.
Special consideration is given to the analysis of alternatives pertinent to
treatment of the source, primarily, the waste pits and lagoons. Removal and
containment methods were considered for source control. No action and site
capping were eliminated since either action prolonged the problem and health
risks in the area. Costs for off-site landfilling and off-site incineration
were compared to on-site landfilling and on-site incineration. The quantities
of source material to be treated are not precisely known since it would be
necessary to remove the mounds where contamination was measured and excavate
the material beneath the mounds. Therefore, volume of contamination was
. calculated by measuring the physical volume of the mounds containing hazardous
wastes above the bedrock. Thus, the quantity of 26,000 cubic yards repr~sents
the physical volume of the mounds and contaminated soils.within the mounds
and appear to be a worst case estimate for the quantity of contamination.
For calculation purposes 26,000 cubic yards is used in the feasibility study.
Only during the removal process will exact quantities be known. A more
precise estimate will be determined during the design phase. Costs will be:
reduced proportionately if the actual amount of waste found at the site is
less than this estimate. . :
- . . .-.- -. ""~ '''-.-
-------
5)
5)
(a) Sit.~,.Cappi n..9.
The least cost alternative that. arguably. may comply with the Resource
Conservation and Recovery Act closure regulations. 40 CFR 264 Subpart G.
is site capping, monitoring and pumping ground water to an Alternate Concen-
tration Limit (ACL). This alternative is only slightly better than No-Action
for the surface since it limits future use of the site and prolongs the duration
of hazardous wastes in the environment. Also, due to the presence of PCB con-
centrations greater than 50 parts per million, the Toxic Substances Control Act
requires disposal in a facility designed in accordance with criteria that would
not allow simple site capping. Due to the location of the facility - directly
'above fractured bedrock, it is likely that capping would minimally affect the
horizontal and hydraulic transport of contaminants. The Federal ground water
policy provides guida~ce for protection of this aquifer as a class II aquifer
for the protection of current and future drinking water use. Additionally,
the State of Illinois policy discourages the placement of unsuitably sited
landfills which the Acme Solvent facility would become if closure would take
place. It places a burden on the State to monitor the facility for contamina-
tion and would defer a permanent remedy to a later date. Also, with closure,
the land at the facility would remain hazardous, thus posing a threat to
human health, welfare, and the environment.
Therefore, alternatives other than capping were developed to meet the response
objectives previously stated that would comply with the RCRA landfill require-
ments, including proper siting, (not directly atop of bedrock).
~ Incineration/Disposal in RCRA Facility
~
io
5(b)(1) Costs of Incineration vs. RCRA Facility Disposal
The costs for a range of technically viable on-site alternatives are shown
on the next page. It can be seen that an on-site RCRA facility is the least
cost alternative but due to the technical limitations resulting from the geology,
limiting the construction of an on-site facility, it is unlikely that this
alternative could be implemented. However, given the dictates of recent U.S. EPA
off-site policy for CERCLA remedial actions the costs to implement an i1cine~atic~
alternative are comparable to off-site waste disposal at a RCRA approved
landfill or one that will exist in a short time. Therefore, these alternatives
were considered in more detail by the IEPA and U.S. EPA due to their 10n9 ter~
environmental soundness.
As evaluated in the FS, off-site incineration is the most costly alternatjve.
Furthermore, the length of time and the number of trucks "necessary to haul
the wastes to an off-site incinerator or to a landfill make these al~ernatives
impractical for a large amount of waste. More than 1500 truckloads of was~es
would be hauled away if 26,000 yds3 of contamination exists at the site.
Because of the logistical difficulty and cost-disadvantage of the off-site,
incineration or disposal alternative, on-site incineration was screenec in '
more detail. However, for a relatively small a~ount of selected waste, off-
site incineration or disposal may be practical.
. -- -r--~~~~--:-
-------
, \
.10-
COSTS FOR ON-SHE SOURCE CONTROL, ACME SOLVENT RECLAIMING SITE,
MORRISTOWN, ILLINOIS
TOTAL CAPITAL TOTAL OPERATION TOTAL PRESENT
ALTERNATIVE DESCRIPTION COST AND MAINTENANCE WORTH COMMENT
J Excavation, on-site
Jandfi 11 (RCRA facility)
1,776,500 3,668,000 5,444,500 Unfavorable siting;
co","uni ty di sfavors
a1ternative; land use
is agricuHural;
vio1ates IEPA 1andfi11
po1icy.
Excavation, on-site
infrared incineration
8,719,000 .116,000 8,835,000 Mobile incinerator;
pUb1ic acceptance:
Excavation, on~site rotary complete treatment.
ki1n incineration
21,587,000 116,000 21,703,000 Same as above with
more proven incinerator
techno10gy.
Excavation, off-site
disposal (RCIM faci ltty)
8,166,000 116,000 From 8,282,000 Cost dependent on
to 10,600,000 avai1 abi1 i ty of
nearby faci1 ity.
; , Excavation, off-site
incineration
33,000,000 116,000 ,33,116,000 Time consuming to
remove and transport
1 ' : NOTE: Present worth is detenmined for 100 years, ~. 10%, for comparison of total destruction aHernat~"es to
~ . -'1 permanent disposal alternatives. Costs ar ~rmined for maximum quantities.
:" I
.; i
.; "I
-------
The Illinois EPA has been seriously pursuing methods for procuring an i~cin~rator
for cleanup of the site and has met with vendors who are capable of providing the
technology necessary to screen the waste, crush it, feed it into the incinerator
and burn it in compliance with environmental regulations. Along with the State
of Illinois, the U.S. EPA has expressed the preference for remedial actions
that would provide complete destruction of hazardous wastes in lieu of transpor-
ting the wastes to a different RCRA approved location. The costs of incineration
vary widely with respect to quantities of wastes and type of incinerator used.
These costs are shown in the attached chart provided by the Feasibility Study
engineers. This cost variation requires that a careful analysis be done during
the design stage so that proposals for cleanup adequately address the existing
contamination proble~ and provide costs with substantial confidence. It also
follows that EPA set forth the rationale for implementation of an incinerator
alternative that is more costly but provides more environmental benefits than
the least cost alternative.
The RCRA compliant alternative for landfilling all of the 26,000 cubic yards
of the hazardous substances found at the Acme Facility is approximately $5.4
million. This cost includes an on-site, double lined landfill with monit~ring
wells and pump-out wells for 100 years. This cost does not include bedrock
grouting. In developing this figure, siting requirements were not considered
and it is not likely that the geology at the site would be suited for a landfil)
due to the near surface penetration of fractured bedrock. The co~unity near
the site would also prefer not to have a hazardous waste landfill. Hauling to
a double lined landfill off-site, providing that an existing facility can
construct a RCRA compliant cell, would range in cost from approximately $8.3
million to $10.6 million.
;
.
.
Therefore, the most optimistic cost for landfilling, complying with tOday's
requirements would be about $5.4 million. By comparison, the Feasibility
Study shows that it would cost about $8.8 million to incinerate all of the
26,000 cubic yards of wastes by an infra-red incinerator and $21.7 million for
incineration of the wastes by the more proven rotary kiln method. Therefore,
the highest cost to incinerate the wastes is about 1.6 to 4.0 times greater
than the most optimistic cost to build an on-site RCRA compliant landfill if it
were implementable.
However, the disposal alternatives that more likely could be implemented vlo~ld
be those that haul the hazardous Inaterials to an off-site RCRA landfill. The
costs for these alternatives are dependent on many variables some of which are
still unknown, such as whether sufficient capacity exists and whether the
facilities are in compliance with new RCRArequ1rements. The costs for off-s;~e
disposal range from $8.3 million to $10.6 million.
. The costs for incineration range from $8.8 million for an infrared ;nci~erator
to $21.7 million for a rotary kiln incinerator. Infrared inc;nerat;o~ is
equivalent to costs of off-site disposal and is, therefore, equivalent t~ the
least cost, implementable alternative. However. this alternativeprovices ..
substantially higher benefits as discussed later i~ this ROD. The ratio of
costs for rotary kiln incinerator tech'1ology to off-sit~ disposal ~s b~t~./I:>-=;1
2.0 to 2.6. Thus the highest cost to incinerate the material found at t~e site
;s between 2 to 2.6 times greater than the off-site disposal alternativ~. T!~e
'-0. '..-,....-.,,,... .."'."-' '-..-
-------
EPA's enunc1dted pOlicy with ,'espect to the use of tt"(~at"cnt oVet' land
disposal "elT1erlial optfons (see ~'elT1o f"om Jack I.l. McGt,~W rlated "1ay F)t 1<:185
entitled, "P,'ocerlut'es fat' Planning and Il1plementing nf~-Site ~~s:>onse I\ctions")
state!> that, to the gt'eatest extet1t p'-actic~hle, consistent witt, CEP.CLA t.e-
quft'eJTIents fo,- cost-effective ,'e,,~lji al acti onl), E?A pu,'sue ,'esP9rJse a.:t i o~s
that use t,'eatl1'lent, ,'euse 0," ,'ecycling OV~r land disposal. Tt,e policy stH~s
fu"th~,' that t,'eatment, ,'euse, and ,'ecycling options shoult1 not he sCt'ee'led
out on the basis of cost alone hut s"tould be considered if their- cost lioes r'tot
exceed an o,'de,' of magnitude above t~~ cost of the othe,' alter'natives. In
thf s case, whO e costs woul d not ,'ange I>eyond two to th,'ee times the cost of
lan1 disposal, and may fn fact be equfvalent to such costs, substantially
g,'eate,' p,'otection of hUJTlan health, welfa,'e, and the envft'onfT1ent tlo:Jld "esult
f,'om the pe"!lanent dest,'uctfon of on-site contamir,ants if the inciner'ation
option ,'ecomended in this ROD 15 1mple:nented.
The followfng conside,'at1ons should he r'eviewed wfth ,'espect to funding t.-.fs p,'oject:
1)
Du,'1ng the design stage some, 0" ooss1b1y all, of the mounds should be
furthe,' analyzed to dete,'nine the depth of haza,'dous wastes, the;"
quality, quantity and physical appea"ance (dr'uJTIS, sludges, liquids, Ot
soils). The objective is to 1ete,mine bette,' quantity esti'nates and
quality esti:lIates fo,' the pu,'pose of bfd specifications so that ove,'all
costs fo,' ,'emediatfon can be developed with less unce,'tainty. Additionally,
test bu,'ns of the waste matedal should be pe"fm'med at an existing,
fncine"ato,' that would be similiu' to one that \'iould be used to in~ine"ate
the hazar'dous nate,'fals at the site in accor-dance with ~CR~ ,'equirements.
The data acquh'ed th,'ough these test bu,'ns sf10ul d p,'ovi tie t"e as"
char'actedstics for' the pu,'pose of del1sting pur'suant to applicable
RC~A ,'equh'ements. Physical pa"a"1ete"s of the wastes are necessa,'y to
be asce,.tai ned due to the potential alTlount of p,'ef nci ne"ati on pt'o~esses
needed to pr'epar'e the haza,'dous lT1atet'i al s fo,' i nci ne"ati on. T~e State
will submit a JH'og,'am fo,' fu,.the,' in-depth h::\t'in9S and chef1ical a".?lysE:
to be pe,'fo"lTIetj on the mounds at the site.
As a result of I, above, it may b~ shown that some of t~e co"taninatiJ"
cannot and sl10uld not be i"cinet'atec1 0" that the tlsh ca"not be d~lfsted
and anothe,' method of treatment 0" di sposa' eval u5ted in the FS as
being cost-effective fa" a selecter:1 waste \>/ou1d"e e:'1t)loy~rJ. ihe ~S
shows, as does t1is RJO, t~at off-site disposal at ~ ~C~~ como1iant
landfill is app,'oximately equivalent in cost 0" less thar't the cost
estimates fo,' on-sf te i nci n~,'ati 0". Ttte,'efo,'e if sOfTIe of t~e haBdous
wastes a,'e ext,'emely dfffi cul t to i nci ne,'ate rtue to their- fo,n 0" text~"~.
and the costs to bu,'n these wast~s ar'e al $0 extr'eme cOf!1par-ed to the
pt'eliMinat.y cost estimates, a' disposal option may he necessat.y..
~
r
.
2)
3) 3id docu'llents can then be develc~ed \-/it!\1'Ior'e !)t'~ci510" ~/it'1 ,'espect
to specifications for' cle;Jn!Jp, thus ,'educing t'"te unce,'tai"ty of costs.
Du,'ing the design, value enginee,'ing screening snO:J1d ~;? cor.ducted in
accor'a1ance with Sup:t'f'und ~'=:'!'Iediai Design and ~e~\edidl ~ctio~ '~uidance.
Feb,'ua,'y 1~95 in o,'de,' to assess .the total cost OF t;,~ incin~"at1o" in
detail. TI1e sensitive pa,.c!:otetet.s that '~I)st aHe.:t t.le c:ost;s ShOLl' t1 b:
analyzed fo,' best case d!\1 "/O"St c~se sit'Jat'ions. T"e wO"S"; CH~,
thotJ,h, should not exceed t"e est,i:,ate I)f i!!)!H'oxi:'!'lat~'y Sn.7 :t1111io'\
p,'ovi der.f in the FS.
~(b)(2) Envir'onmer.tal Conside,'ations of lricin-:,'ation v:; AC~A. ~acility 1;sp.nai
Section 101(24) of CERCLA shtes that. t'f~M~d;al actions shoulrl not i'lci.,,1e t1,?
off-site tt'anspor't of hazardous s:lhst~1C~,), 0" t'le Ho"~qe. tlea~"1~r.t, '1~~~'-;'IC-
ti on 0" seC1J,'e .1i S110S; ti on off- site of ~~C:\ :Hza",j::>,!,; 5;1"5 tar\Ce5 ')1' ,:on"; ~,; r'ta te'1
-------
materials unless the President determines that such actions (A) are more cost-
effective than other remedial actions, (B) will create new capacity to m~nage,
in compliance with subtitle C of the Solid Waste Disposal Act, hazardous
substances in addition to those located at the affected facility, or (C) are
necessary to protect public health or welfare or the environment from a present
or potential risk which may be created by further exposure to the continued
presence of such substances or ffiaterials.
EPA emphasizes the need to consider treatment, recyling and reuse before off-
site land disposal of hazardous substances from CERCLA sites is used. However,
as provided in Section 300.68(h)(1) of the NCP, remedial alternatives should
not be eliminated on the basis of cost alone. Therefore, other longer term
benefits should be analyzed,when comparing alternatives.
Environmental benefits which accrue as a result of selecting an incineration
option over disposal of waste materials in a RCRA Facility are:
I} at least 99.9999% removal from the environment, of Polychlorinated
Biphenyls {PCB) found in the waste at the facility,
2} at least 99.99% removal of all other RCRA classified organic
hazardous wastes found at the facility,
3)
4)
a project that would terminate within 3 years after start-up, and
elimination of the risk of release of hazardous substances to the
environment and consequently the complete reduction of the health
risk associated with this exposure, and
;
.
5) elimination of the need for governmental authorities to perform the
environmental monitoring that would be necessary if the wastes were
contained on-site or relocated to another site.
5(b)(3) Administrative and Technological Benefits of Incineration vs
RCRA Facility Disposal .
In addition to the above environme~tal benefits of incineration, various
administrative and technological benefits are to likely to accrue.
These are:
1) The establishment 1n U.S. EPA, Region V, for the first time of a
complex administrative process to implement the requirements of
RCRA, CERCLA, TSCA. and Air Quality programs at an incineration project
on an NPL site. The Acme project can further establish a long-term
program for the review and approval of other inci~eration projects
that are expected to be carried forward in the next several years.
Thus, the Agency will have begun to esta~lish criteria to fund the
design and construction of future in~inerator projects in an expedi-
tious manner.
2)
The cost-effectiveness analysis for fut~re incineration projects will
be determined with much more confidence once we complete test hurns a~
the site during the design stage. If the inci~erator performs well at
a reasonable cost there is an extremely good possibility that t~e
-------
24 110c:.
21110'
18810'
I~ 110'
en
II:
C
.J
.J
o
C
12. 10'
9.10'
8 . 10'
'.10'
,
1
. .. .- - --. - ...
---
ESTIMATED COSTS FOR ROTARY KILN INCINERATION
ESTIMATED COSTS FOR INFRARED FURNACE INCINERATION
/
/
/
0./
f4.'l
...,
~~
~
o~,
-/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
//
/
/
/
/
/
/
//
.. ...~\O"
t.\"t:
\\. \"
.0
"... '''C".!''A~ ---
D v ---
-- .....-
----
----
----
---
----
m:CEIVED
:-t9 131985
0""" INCUlt""TION
;~'::\.DlPC
4000
8000
12.000: . 16.000
CUBIC YAROS OF SOIL. .
20.000
24,000
2000
4000
6000.
NUMBER OF DRUMS
8000
10,000
12,000
GRAPH OF VOLUME Ys. COSTS FOR ON-SITE INCINERATION
EC.JORDANCO
J
- '.. ...._,,~ ...,~~"'........-.~
-------
concept will apply to many other CERCLA sites. The liability to the
Agency is minimal since a relatively small amount of the total project
cost will be spent up to the test burn stage. At that time the techno-
logy can be reassessed. if necessary.
3)
Implementation of this technology along with a few other incineration
projects throughout the country will advance the state of the art so
as to make this technology cheaper in the future.
~
;.
~. '.-." ~....~ ....-....~ .-.-7
-------
J -
UEGREE OF TREATMENT FOR SURFACE WASTES
-.----
The total extent of the cleanup for soil and ground water need~
continually evaluated, as more data are generated during design
Criteria for the determination of the extent of cleanup must be
to protect public health.
to be
and cleanup.
developed
There are many methods to dete~ine the safe concentration of substances that
can remain at the site. One method, which is still tentative but likely to be
of value is the Soil Contaminant Evaluation Methodology (SOCEM). Using this
model, ultimate clean-up levels on the site may be determined. Due to their
persistence in the soil environment PCB are thought to be the compound that may
determine the safe level of cleanup in the soil. Vinyl chloride, methylene
chloride, benzene and trichloroethylene are four more organic compounds that
will be evaluated to determine the safe level of residual wastes that can
remain in the 50il. The metals arsenic, lead, cadmium and hexavalent chromium
are also considered in the SOCEM model since these compounds as the afore-
mentioned organic compounds theoretically exhibit chronic health risks to a
receptor 'fho ingests the ground water in the vicinHyof the site. The appendix
to this ROD explains the levels selected by the SOCEM model which are derived
to comply with drinking water criteria off-site. These levels are target
levels of treatment and will be further analyzed and amended as necessary when
excavation occurs or when more analytical data are provided.
The RI documents that the concentrations of hazardous wastes in the mounds are
high enough to be toxic upon direct contact or ingestion at the source on the.
site. The wastes are also highly flammable and ignitable in the dense distri-
bution inside the mounds. Similarly, the wastes appear more consolidated
toward the deeper portion of the mounds and likely have a relatively high heat
value. Due to the above reasoning, the waste disposal mounds containing highly
contaminated soils, sludges, liquids, drums and their contents will be
incinerated.
Existing chemical data and company records indicate that an estimated minimum
of 8,600 cubic yards of hazardous wastes will be incinerated. This number
represents about 1.77 acres contaminated to a depth of three feet, which is a
reasonable volume considering the area of the site used for burial of drums a"d
volume of lagoons storing liquid solvents. The area was determined from a
photo taken from a flight over t'.e site in 1970.
The feasibility study calculates that as much as 26,000 cubic yards of contami-
nation exists at the site. This number serves as an upper bound, and tbe
difference between the 26,000 cubic yards and 8,600 cublc yards represents the
maximum amount of material that will be evaluated for health risks by SOCEM.
As stated previously, the ROD presents the worst case, 26.000 cubic yards of
contamination, for which incineration costs are determi~ed. In the feasibility
study a 26,000 cubic yard quantity was used for comparison of all treatme~t.
technologies evaluated for cost effectiveness.
-------
-16-
SUMMA~Y OF RECOMMENDED ALTERNATIVES AND FURTHER ACTION
Source Control
On-site incineration of contaminated materials will not exceed a quantity of
~6,OOO cubic yards. For this quantity, rotary kiln incineration is estimated
at a present worth cost of $21.7 million and infra red incineration is estimated
at a present worth cost of $8.8 million dollars. Costs and type of incinerator
will be determined in the design phase of this project at a precision of - 10
to + 15% of estimated value and will include off-site incineration estimates.
Bedrock will be evaluated by the State in further RI/FS work to measure the
effectiveness, the amount and the type of remediation necessary for blocking
the migration of contaminants found in the unsaturated bedrock and the impact
of this measure on ground water treatment. The decision for funding the
bedrock remediation is deferred until the study is complete.
Continued RI/FS of ground water beneath the source is recommended at this time.
During the feasibility study a deeper well recently constructed will measure
the extent of vertical contaminant migration, if any, and will monitor the
deeper portion of the aquifer thereafter. Also, pump tests will be performed
to hydraulically stress the aquifer to determine optimum location of pump-out
wells and the need for treatment of the pumped water. Costs will be determined
with a - 10/+ 15 percent precision of the estimated value developed in the
design phase. The decision for funding a ground water remedy is deferred
until completion of this study.
.
Off-site Treatment
A comprehensive program for treatment of contaminated ground water is deferred
until additional data are provided.
Restoration of drinking water quality will occur by installing 9 home car~on
treatment units as an interim measure to the 9 affected residences as well as
future homes if necessary over the next 3 to 5 years. Monitoring of drin~i~g
water supplies in the vicinity of the site will continue.
Community Relations .
The Illinois Environmental Protection Agency (IEPA) has been responsible for
conducting a community relations program at this site beginning in February,
1983. U.S. EPA acted as advisor and coordinator, attending public meetings
and hearings, and providing oversight.
During t~e Remedial Investigation/Feasibility Study, IEPA conducted 3
"livingroom" small group meetings, 1 public meeting and 1 public hearing.
This was supplemented by nearly 70 phone calls tb citizens and the news rne~i!.
and approximately 12 one-to-one contacts with area residents and local offi:ials.
Written materials (news releases, letters and fact sheets) and other acti~i~1es
identified in the Commuriity Relations Plan.were cJ~pletej as schedule1.
-------
The pdmat.y conce,'ns of the cOl'rlunity a"e ar.:cp.ss to a safe rlt"inkfnq wate,-
supply and r'emoval of contdl!1i natf on fr'o:TI the site. Pub1i c water- Supply
connections a,'e not available to ,'esidents of l inden\l/oorl and Erls?n Road;
hence, those ,'esidents desit'e ;>,'ovisions fo,' safe dt'in~ing wate,'. :1~vel~ping
the site fnto a RCnA-pennitterl disposal facility, even if only fo,- the waste
on-site, is not acceptahle. HOllteve,', "esidents indicatel1 they would accept
on-site fnciner'ation 0" chemical tt'eatl'lent. The p,-esence of Pagels Pit
landfill ac,'oss the st,'eet f,'OJJJ the Acme Solvents site also conce"ns "esidents
of the fmmediate vfcinity. They feel that Pagels Pft is cont,'fbuting to the
g,'oundwate,' contamfnatfon. T"at site was recently added to the National
Ptfor'ftfes List. The successful completfon of technica1 activftfes and
cOfllllunfcatfons du,'ing the. RIfFS has estahl1shed c,'edibility in the cOf!JTIunfty.
It a1so p,'ovides a st,'ong foundation for the connunfty ,'elatfons o"og"am fo,-
design and const,'uctfon of the Acme Solvents sfte as wel1 as futur'e wor'k on
Pagel sPit. -
Consistency With Othe,' Envft'onmenta1 laws
The r-ecornmended alte,'native will r'equft'e sOU"CP. cont,'01 and ,'estor'ation of
dr'f nki ng water' supp1 fes as r'emedhl actf ons. Seve,'al environmenta1 statutes,
apart fr'om CERClA, fnc1udfr'g, the Resou,'ce Conse,'vatfon and Recove,'y Act
(RCRA), the Toxic Substance Control Act (TSCA) an~ the Clean Ait Act (CAA),
ate applicable to the ,'e:nedfal action.
"RCRA - The requirell1ents of RCRA a"e applicable with ,'espect to the tf'eatment
of haza,'dous wastes on-sfte and to disposal off-site, fn which case RCRA
ttanspo,'tation ,'egu1ations apply. Contal1linated soils and wastes will be
excavated, incine,'ated in a RC~~ app,'oved facility. Haza,'dous su::>st.\nces
remaf n f n the unsatu"ate~ zone of the f,'actu"ed bed,'ock and the g,'ound../ater'.
The "emedy for these poterttial "elp.ases will be evaluated fn the futu"e F'~
wo,'k fo,' bed,'ock and g,'ound water' r'emed; ati on.
;
.
.
Ash c"eated by the fncine,'atfon of hazardous mate,'fals at the facility win
comp1y with deli sti ng ,'equit'ements of 40 CFR 260. If, after' test bur'F'lS a"e .
pe,'fo,'med, ft appear's that delisting the incf'1et'ato,' as~ will not be possible,
the Agency wil1 reevaluate its p,'opose1 action to dete,'mine \'/het~er' to pu"sue
the fncfne"ato" option 0" whether' to ta"e othe,' actions. If, at that poir.t,
the fncine,'ation alter'native is selected, iiFty as!, not able to be delisted
will be deposited in an acceptable off-site RCRA facflity, tr'eatec1 so as to
"ende" it non-haza,'dous, or' cover'ed on-site wit!, a pr'ovfsion fo,' g,'ound water'
monitoring in accordance with 40 CFR 264 Subpart G.
The RCRA ,'egu1ations fo,' hazar'dous waste incfne,'atfon. 41) CF'R 264.343, l!r'e
applicable to o!1-sfte inciner-ation. These ,'equfr'ei!ter»ts include a r'lest,'u:tion
Rellloval Efffciency ()PE} of 99.9q~, qq~ hyd,'ochlot'ic acid (HCL) "~movcl
efficiency 0" less than 4 pounds pe,' hour' of J.fCL emfssiorts, pa"ticulate
emissions less than 1~1lT'1;l1ig"aMs pe,' day standa,'d cuhfc :Tleter' (...,ith a"L>o:H'.ia~e
co,.,.ectfon factot') and tr'f.11 bu,'n cr-ftet'fa. .In addition ther'e a"e op~,'atin:J
and monitl)r'ing ,'equhements that will be f01lowed.- Costs fo,' incine"ation
we"e based on these ,'equi ,'el!tents and ,'equi re:1e:,ts of TSCA.
....!-_.~.~~
-------
-18-
TSCA - Because of the presence of PCB in the waste, the incinerator must be
able to meet a ORE of 99.9999% for the PCB and approved by EPA. Similarly,
requirements for disposal of PCB greater than 50 ppm apply.
CAA - The emission control requirements of the CAA may be applicable to emissions
from the incinerator depending on the magnitude of the emissions. Parameters
of concern are sulphuric (SOx). nitric oxides (NOx) gases and particulates.
Cost for air pollution control equipment have been included in the total cost
for the recommended remedial action.
Based on review by the State, no control, besides fugitive emissions control.
would be necessary during excav;.tion.
OPERATION AND MAINTENANCE (0 & M)
o & M activities requfred during and after the on-site remedy include health a~d
safety monitoring and maintenance over a thirty year period. Total present
worth cost for these activiti~s is $116.220.
The IEPA is the designated State Agency that is responsible for 0 & M. The
State currently has two sources for funding 0 & M. The first is a Hazardous
Waste Fund. The fund is generated from taxes on the disposal. treatment. and
injection of hazardous waste'. The second funding source is a state approp- .
iation of general revenue fu :~ for $9 million that is to be used for matching
Federal funds on Superfund a istance projects.
;
.
.
EPA will fund the O&M for si ,cleanup for one year.
this period is estimated to $6.200.
The total O&M cost for
This discussion of O&M requi
of current policy that woulc
as a part of construction cc
~nts and costs is based on the interpretation
1clude the O&M costs for on-site incineration
FUTURE ACTI ONS :
1 )
2)
3)
4)
5)
Feasibii ,ty Study for evaluating effectiveness of
groutiny the bedrock
Feasibility Study for optimizing the effectiveness
of ground water pumping on plume control
Remedial Action using i~cineration
Interim Remedial Action for resto~ing drinking
water quality
Final Remedial Action for Restoration of Drinking
Water
.. '9~"",~----.""--,,
-------
-19-
SCHEDULE
The following is a projected schedule for key milestones for project im-
plementation :
Milestone
ROO Approval
CA approved
Start design on incinerator, and
carbon treatment units
Complete remedial action for home units
Complete RI/FS on bedrock and ground
water
Complete ROD on RI/FS
Start remedial action
Complete remedial action for source control
Responsiveness Summary
Projected Date
September, 1985
October, 1985
December, 1985
June, 1986
June, 1986
August, 1986
June, 1986
December, 1988
The Community Relations Responsiveness Summary is included as Attachment 1.
.
t
r
.
-------
Table 1
Tab1e.2
Table 3
Table 4
. Attachment 1
Attachment II
Attachment III
-20-
Appendix
Concentration Data for Chemicals Detected in Subsurface Exploration
Concentration Data for Chemicals Detected in Ground Water
Concentration Data for Chemicals Detected in Air
List of Alternatives Considered in Detail (in FS)
Community Relations Responsiveness Summary
Negotiation Status Report (Enforcement Confidential)
Soil Contamination Evaluation Methodology for this site
NOTE: Data are presented for demonstration purposes. The tables are not a
comprehensive data display, they represent data collected during the
remedial investigation only.
-------
T A8l E 1
CONCENTRATION DATA fOR CHE~ICAlS DETECT EO
IN SUBSURFACE EXPLORATIONS (TEST PITS)
Maximum Total Number' ofa Ave"age~
Concentnti on Sampling Contaminated Con cent,. ~ t
Class Compound (mg/kg) Points Samples (mg/k9)
Volnf1es ,-et1Iylbenzene 420 54 27 79.4
. ..tlenzene >4,400 54 16 685
1.2 dfchlor'oethylene 54
1.1 d1ehlor'oethane 30 54 5 12
1,1,1 tf"1 chl or'oethane 83 54 23 18.7
'~ylene ehlor1 de 20.000 54 20 1,132
..1.1.2 tr1 chl or'oethane 1.0 54 1 1.0
~etraehloroethlylene 220 54 23 21.1
~1Ch1oroethylene 120 54 19 30.7
'"toluene 4,200 54 37 >398
. . «y 1ene >5,000 54 28 >907
V-..a1lS .1..2 dichlor'o- 6.5:
ethylene 20 54 4
.
1,1 1I1chlooethylene 2.0 54 1 2.0 ~
, . 'Vi ny1 eft' od de .45 1)4 1 .4;'
- 1:tI11)f1)bemene 54
Semi - fsophor'one IJ3.000 54 2q 1,FiQ6
VoLltl- b1st2-ethylhexyl)
1'tItt.alate 7.1;00 54 44 349
~u1yl benzyl phtha-
late 1.100 54 3 512
1IIpttta 1 ene 2.300 54 29 413
di-n-butyl phtha-
late 780 54 33 123
PCB . . '«8-1254 274 54 16 87
-~.. TDt81....mHr of samples Showfng Quantiffable concentr'ations.
b. S8t'lp1uvl-ttt non-Quanti fi able concentt'ati ons wet'e not i ncl uded in computati 01'1 of cvet'a:Je
con~~~ion.. :
N ote:mg/tg .. mi11i gt'ams pet' k i1 ogt'am
-------
TABLE 2
CONCENTRATION DATA FOR CHEMICALS
DETECTED IN GROUNDWATER
Maximum Tot a 1 Number ofa Average b
Concentration Sampling Contaminated Concentration
Class Compound ~ Points Samples (ppb)
Volatiles ethyl benzene 31 46 2 21
benzene 7.9 46 1 7.9
1,2 dichloroethylene 46
1,1 dichloroethane 150 46 17 18.8
1,1,1 trichloroethane 240 46 12 32.2
'methylene chloride 46
1,1,2 trichloroethane 46
tetrachloroethlylene 470 46 10 63
trichloroethylene 170 46 15 24.7
toluene 40 46 1 40
xylene 280 46 1 280 ;
;
trans 1,2 dichloro- -.
ethylene >2,400 46 23 143.4
1,1 dichlooethylene 13 46 1 13
vinyl chloride 160 46 1 160
chlorobenzene 46
Semi- isophorone 46
Volatile bis(2-ethylhexyl)
phthalate 220 46 10 52.9
butyl benzyl phth-
alate naphtalene
di-n-butyl 22 1 22
phthalate
PCB PCB-1254 46
a. Total number of samples showing quantifiable concentrations.
b. Samples with non-quantifiable concentrations were not included in computation of average
concent rat i on.
-------
TABLE 3
. tONt£mAilT'lN DATA fOR CHHlICAL S
DETECTED IN AI R
Total
Max i~UI'I Averageh Avera;eb
" tv"cntY' It ion S."'pl i n9 NUMber of Concef'ltraU
Cl ass :(-1'P1I\') Points Cont.ninated ( ppTTlV }
Compound ~G/Tpc BG/Tpc Samples eG/Tpc.
Volatiles ethylbenzene
benzene .fJ7/3Sd 16/17 2/6 .06/5.~
1,2 dichloroethylene <1/2,. soad 11;/17 0/1 --12. 5~:1
1,1 dichloroethane <..5J25~a 16/17 011 --/25~
1,1,1 trichloroethane -- 16/17
~thylene chloride .1.'8150011 16/17 5/2 1.24125~.1!
1,1,2 trichloroethane .- 16/17
tetrlchloroethly1ene 1.6/400 d 16/17 719 .77/45.9
trichloroethylene -- 16/17
tol uene .6n.50od 16/17 6113 .47/121.9
xylene "3915tm 16/17 6/13 9.5/57.5
trlns 1,2 dichloTO-
ethyl ene 16/17 -- ~
1,1 dichloroet~ylene 15/17 ..
-
vi nyl chloride 16/17
chl orohenzene 1.01 Se 16/17 613
Semi i sophorone
Volatil es bis2-ethylhexyl)
phthllate
butyl benzyl
phthalate
n.phtal ene
talate
nlpht.l ene
d1-n-buty1 phtha-
'Ite
PCB PCB-12S4
. Total number of samples showi~ quantifiable concentrations.
. Samples" with non-quantifiable amcen'tt"-trti1tns were not includec1 in computation of aver,,;e
concentration.
. RG~ Background
Tp. Test Pit Analyses
from soil headspace an~'ys1s.
. From spoils pile analysis.
, "
-------
LIST OF ALTERNATIVES CONSIDERED IN DETAILED EVALUATION
SOURCE CONT~OL REMEDIAL ALTE~NATIVES
1. No Action.
2. Site Capping and Monitoring.
3. Soil and Drum Excavation, Off-Site Land Disposal (RCRA Approved Facility)
. and Bedrock Grouting.
4. Soil and Drum Excavation, Off-Site Incineration and Bedrock Grouting.
5. Soil and Drum Excavation, ~nd On-Site Land Disposal (RCRA Approved Facility)
and Bedrock Grouting.
6. Soil and Drum Excavation, On-Site Incineration and Bedrock Groutimg.
7. Soil and Drum Excavation, On-Site Incineration, Bedrock Grouting and On-
Site Ash Disposal in a RCRAApproved Facility.
8. Soil and Drum Excavation, On-Site Land Disposal of Soils (RCRA Approved FaCility),
and Off-Site Land Disposal of Drums (RCRA Approved Facility) Bedrock Grouting.
9. Soil and Drum Excavation, On-Site Incineration of Soils, Off-Site Land Jisposal
of Drums (RCRA Approved Facility), and Bedrock Grouting.
;
.
10. Soil and Drum Excavation, On-Site Incineration of Soils, Off-Site Land Disposal
of Drums (RCRA Approved Facility). Bedrock Grouting and On-Site Ash Disposal
in RCRA Approved Facility.
MIGRATION MANAGEMENT REMEDIAL ALTERNATIVES
1. Installation of Home Water Treatment Units.
2. Development of Upgradient Well and New Community Water Supply Syst€~.
3. Groundwater Extraction and Treatment by Air-Stripping.
4. Groundwater Extraction and Treatment by Activated Carbon.
5. Groundwater Extraction and Treatment with Home Water. Treatment Units:
6. Groundwater Extraction and Treatment with Installation of Upgradient
Wells and New Community Water Supply System.
7. Groundwater Extraction and Treatment with Extension of the Rockford
Public Water Supply system.*
8~ Extension of the Rockford Public Water Supply.*
*Thi s a lternat i ve is i ncl uded based upon th.~ recamme"dat i on of the State.
-------
ATTACHMENT 1
-------
"'-. .
~
JlllnOl~ F.n\"lfllnm,'nt.tl Prlttn t ,..r. A;':"III \
~;!"" ,'h,,', t.:ii fo<....d ~prlr.~~I..lc
11.. ...:-:......
. ,
COMMUNITY RELATIONS RESPONSIVtNtSS S~RY
ACt€ SOLVENTS
MORRISTOWN, ILLINOIS
The I,'1nois Environnenta' Protection Agfncy (1EPA) has been responsible for
conduct'ing a cCllllTlunity relations program for this sitf. tCJll'llunity relations
activities hive b~n cond~ted throughout thf r~d;al investigation and
feasibiHty study. During the feasibiHty stu~1 a seven week pUbHc conrne"t
,er10d which inc'uded informa' 8eetings Ind a pub'ic hearing were he'd to
~ce1ve pub'ic comment. This Community Relations Responsivfness Summa~y
doc~nts mi'estone community re'ations activities ,'on9 with citizen commen~s
and questions and the tEPA response.
COMMUN!TY RElATIONS
Remedia' Investigation
A community relations p'an was submitted to and approved by the United S~ates
Environmenta' Protection Agency (USEPA) in May, 1963. The emphasis of this
first phase of the community re'ations program was directed at one-to-one
contact and informa' meetings with 'OCI' offici a's and citizens responding to'
'''connunity conce",s about drinking water. Ouarter'y sampHng and ana'yses of
private drinking water we"s was coordinated between the 1"1no;5 Departmen~
of Pub'ic Health and the IEPA. Milestone activities conducted during the
r.emedia' investigation inc'ude:
;
.
Mot1fication 1etters
Mews re'ease announcing the sta~ of the remedial ;nvest;gl~ion I~d
fels1~;'ity study)
1nfo~' .eetings with area residents
fact Sh.et f1 exp1aining history and prob'~S at the site
Pub'ic 8eeting to discuss c1eanup process/early in Rl phase
Feas1bi11ty Study
The start of the pub'ic comment period In~ the date Ind 'ocltion of I public
hea~ing was announced through I paid 'ega' notice, Tlews re1ease, fea~ure sto~y
appearing in the Rockford Register Star, and fact Sheet '2.
Fact Sheet '2, a summar,y of the c'eanup options, was ~a1'ed to those on the
community relations plan 8a1'1n; '1st and was avai'ab'e .'on; with a copy o~
the f.asibi11ty study at the lEP~'s Rockford fie1d Office. iwc mee:ings with
interested groups were he'd before the pubHc hea~ing.
The ,ub'1c 'hel~ing was he'd It the Howard Johnson Motor Lodge Route 251, o~
Thursday, December 6, '984, to discuss the c1eanup optio~s. Ap~~Dximate'Y 50
,eop'e were in attendance. Fo"owing 30 minutes of presentations, I£P~ staff
responded to conrnents° .n~ questions. °
. ..~- --:.. .'-'":"'(~-"~~-'..--
-------
~
JIJJnC1l~ En\ IfllnnH"nt.tI I'ftttt"l' lun AO:"IH'.l
:!':I"I("huut..~: k"..c ~~'.r,~~...It: I: .-,-.-
In response to I request, the public c~nt period wat eltended to fr1dlv
Dec..ber 28, 1~, and notifications were .ailed to those who attended t~~'
MIring. JE'A received seven sUtellents. Five of the seven Ire from leg8~
fi~s ~presenting responsib'e parties. The Vinneblgo Public Health
Depal"'tlftent and tne League of Women Voters provided the other two wM~tfn
statements.
CITIZEN QUESTIONS ,AND tON:ER~S
Questions and comments are grouped together by issue.
Issue: Drinking Water and Ground~ter
QUESTION: What are the major contrminants found in the groun~wate~~
RESPONSE: The major contaminants a~ 'arge'Y c'eaning end de9~ees1n;
solvents which include trich'oroet~lene, tetrachloroet~lene, traMS 1.2
dichloroet~lene, ',1 dich10roet~1ene 1,',' trichloroethane.
QUESTION: What Ire the concentration 'eve's found in dr1nking wa~e.
.11s?
- .
RESPONSE: Drinting water we"s direct'y Iffected by the underg"oLm~ ~'G1Ie' .
have concentrations as high as several hundred parts per bi"ion (~~).
whi'e we"s near the edge of the p1ume show trice 'eve's between 1 .~ 13
ppb.
QUESTION: Are most of the contaminants water solub'e?
t
..
.
-.
R!SPOtlSt:
Al' of the cont~~inants are water solub'e to va~ious de;-ee,.
oUtSTION: How 'on; cou'd it take for contaminants in the grouncht~:.r't:
reach I wider area?
RESPONSE: The conta~nants wi" continue to spread if no action i~
taken. Based upon estimates by the contractor conducting the Reme~ie:
Investigationl Feasibi'ity Study, E.C. Jorden Company, S;9n~fican~
concentrations could reach drinking water we"s on Edson Road with~r, ~~~
next 50 yeerft.
QUESTION: If buried wastes Ire f'eIIIoved, wi" the ~ontaminate~ p1U111E be
stopped?
R!SPONS~: No. Conteminants a' ready in the ground~ater, .n" d;ss~~~
whi1e continuing U migrate in 8 wester1y dire:tiof).
, .
QU£STION: Whe"! "n, contaminants I' ready ,in the groundlli!te" u'~~a-:'~~y
travei? Are thej' rea:hing K111buc:k Creek? '
,
-------
@
"
f
, ,
Jllanon. F.n\ Irunmt"nt.\ 1 Pr,,',-,' I"r~ .-\':"11\.'
:!;:'tI. (,t._. \ tolll F.....d ~prlnrr,..IG IL ,:,~:..~
RESPONSE: Some contaminants f~om Acne So'vents appear to be enteping
K1"buck Creek; howe~er, the bu'k of the contamination is .~ving undep
K1l'buck Creek and ..y u'timate'y di$ch.~e into the Rock River.
QUESTION: Which direction is ground-ater f'o.ing in this lrea~
RESPONSE: The genera' direction of groundwater r,o. is wester)y to.ep~s
Ki"buck Creek. Some mounding occurs at the site .h;ch resu1ts in
Iround~ter f'0_1n9 rldil"y for severa' hundred feet before chan;'n; to e
wester'y di recti on.
tOMM[Ni: Recent ground~~er 80n1toring dltl indiclte that off-s~te
contlminat1on of drinking .ater we'" has decreased from that ref1e~te:! in
earlier .onitoring.
RESPONSE: Chemica' concentrations in groun~ter can change due to I
variety of factors. Recent ground.-ater IIOnitonng is insufficient !)y
itself to conclude that contamination in groun~ater .1" continue to
decrease. Remedia' Ict10n should be taten IS soon IS poss1b'e to prov~de
safe drinking ~ter Ind prevent the re'ease of .o~ contaminants into the
ground-ater because of the presen:e and concentration of chemi:.'
contaminants found on-site.
QUESTION: What is the maxi~ or minimum concentration of chemica's foun~
at this site a"owed by the federl' government in drinking .-ater~
;
.
",
RESPONSE: For the major contaminants found in these we"s, the fedep~~
IOYe~nment does not hive any regu'ations. U.S. EPA gu1de1ines provide
procedures to ca'cu'ate acceptab'e concentrations of substances found in
drinking water .1th no expected adverse effects. Some ~siden~s werE
notified by the tEPA not to use their drinking water. These no~if'ca~ions
were based on U.S. EPA guide';nes and information the IEPA hes on
ground.ater f10.-, arel geology, Ind site histo~.
Issue:
Cleanup Options
tOMM[Ni: Taxpayers shou'd no~ be stuck paying fo~ the c'eanu~ of the A:~
S01vents site.
QUESTION: Who .111 pay for the c1eanup options selected by the USEPA?
RESPONSE: The respons1b'e pa~ies ~ay participate in the cleanup:
'espon~1b'e parties 1nc1ude generators, hau'ers, as ~" a$ the owneps.
However, shou'd the responsib'e pa~ies decline to vo'unta~;'y
participate, Superfund money would be used to finance the c'ean~?
ihrough the Superfund prog~~. 9~ of the cleanup money wou'd be fe~e~a~
and ,~ wou1d come fr~~ the State Ha%a~ous Waste ~und. Supe~fun~
1egis'ation provides that up to th~e time"s th! cost of the c'eanu: t:'.!y be
assessed against the Y"esponsible parties. '
.-,"."," -,.~--:",,----:,
-------
@
~..-
1I1JnIl'~ I':nnfllnnWnt.tI }""h-d ,un A.''''H \
~.lltll("huh:o::o k....c ~~f.~.~"...I~ I: ..--.-
How deep under the surf.ce of the site wi" thr .contsm~na~~s be
QUESTIO. :
reao v.cS.,
RESPONSE: The blrrels and sludges art within severa' feet of the su~.ce, .
but the contractor proposes to use wlte~ pumps to extract contlm~nate~
,round.-ater down to approx1lUte'y .00 feet.
15 there a~ experience e'sewhere with the use of high pressup~
QUESTION:
grouting?
RESPONSE: Yes, it hiS been used successfu"y at various 'o:ations
throughout the nation. High pressure grouting is one method of building a
.a" in the so1' to prevent contamination from .oving. In this instan:e,
the contractor recommends injecting a portland cement mix into the bedro:(
to prevent '1quid ~ste from entering the groundwater.
QUESTION: 15 there Iny threat of the grout p~cess Clusing ad~itiona'
conumi nation?
RESPONSE: Yes. A short-term "'eese of conumi nants .ay occur because 'of
the high pressure used to fo~e the grout into the cracks an~ fractu~s of
the bedrock. If used, the contractor proposes that grouting begin beyond
the perimeter of the waste de~osits, working toward the cente~, to ~ou:e
the possibility of contaminants being fo~ed ..~ from the si~e.
QUESTION: Mas above ground storage b~en eva'uated?
~
.
,
RESPONSE: Yes. It was di sm ssed because t.he~ was no adeQuate way t~
sto~ these wastes ebove ground over a 10n; pe~~od of time, above 9~o~~c
storage; S on'y a temporaT)' lneas.u~. "'u~he""o~, the 1EPA p~fe~s
options designed to detoxify the waste rather than on-site storage 50 tha~
the site tan be eventua"y returned to some productive use.
QUESTION: Wou'd an on-site portab'e incinerator be purchased or ren~e~~
RESPONSE: No decision has been Foade on the finan:ing or o~er!~ion of a~
incinerator.
QUESTION: Whit is the procedure to dispose of ash generated by
incineration?
RESPONSE: The ash w~" be tnalyzed to oeterm~ne con~ent. A de:;sicn .r~1
then be made IS to disposa1 p~o:ed~res. It mDY remain on-site an~
cove~ed. or it may haye to be t~8~sportec off-s;~e.
tOMM[Ni: Capp~ng 15 not effe:~ive option.
RESPONSE: The tEPA 89~ees that coppin;, by 1tse'f. wou'd not preve~:
buried waste from contaminating 9~oundw!te~ in the future. Capp1r.; sh~J;=
on'y be used in co~inat1on w1tn seme o~ner a'te~a~;Ye.
-------
~
- .
...
.',
, .
IJlanul:o- En\"lrunmt'nt.d Prllt,,( t lOIn ,.1.':"111.\
:::.!ltlt I'hurt tll~1 t-(1I..d ""'p"lr...-'".c Ilt,.'-',,,
tOMM[WT: So8e of the evidence in the ~d1.' investigation tends to
indicate thit excavation of the conta~i"'ted 501' could 1nc~e.se t~e
enyiron8enta' hazards and p~sent seve~ Questions of safety for wo~e~s
perfo~ing the cleanup.
RESPONSE: Air emissions .~ the potentia' environmental hala~ from
.excavation. However. no adverse hea1th effects to .~a residents f~, .~r
emissions .~ e~pected either durin; or after site cleanup. Ambient I~~
80nitor1ng wi" be conducted durtng excavation and safety provisions wi"
be made before excava~ion begins in case concentrations of chemica's in
the air were to exceed safe levels. Any off-site effects from eX:'YI~1on.
if they occur, are. expected to be sporadic and temporary. but shou'd not
pose a health threat to area residents. A safety plan wi" be deve'ope~
to protect .orters .t the site. tEPA intends to hire . fi~ experienced
in waste ex:avation and w11 1 "qui re "orters to wear proper safety
equipment and fo'low mutua'ly agreeab'e procedu~s. In addition. tEPA's
"presentat1ves w11' be on-site for the duration of the excava~;on.
COMH!Ni: The Question of the influence of 'age"s Pit on the g~oundw!~e~
beneath and adjacent to the Acme So, vents site has not been adequately
detenni ned.
COHHENT: Without knowing the extent to which Page"s Pit contr;bu~es to
groundwater that may .'50 be conteminated by the A-~ So'ven~s site an~
w1thout differentiating the cont~ibu~ion from the t.o sites, EPA w~" be
unab'e to choose In appropriate f1na' remedy for the Acme Sc;ven~s s~~e
that would adequately Iddress the groundwater problem.
OUES7ION: Is contamination in the g~ound.ater under the A:~e So'ven~s
site worse than that under Page' '$ Pit?
;
j,
..
RtSPONSE: As I resu't of the Remedia' InYestigat;on~ees1b;1i~y Study,
IEPA has considerab1y more 1nfo~t~on on the A:me So'vents site than
'age' 's Pit. Page' 's Pit "as not pa~ of the RIfFS ~!:ause i~ .as no~ o~
the Nationa' PrioMty List w!ten the roemedia' 1r.yestigation began. IEc,t.
does not have enough infonmat;on on Plge' 's Pit to con:'usive1y sa~ t~!~
con~minet1on It this site is IS ba~ or ~rse than at A:me So1ven:s.
It is apparent from the ~ed1.' 1nyes~1gat1on thl~ the A~~ So, vents site
is contannnating groundW!ter which is ~1gr.ting beyond the bounda~ies of
~he site. The underground chemica' p'~ from this site has ccn~~T;~!~e~
~a~y drinking water we"s and the potentia' ex1st~'fo~ this pi~~ ~o
contaminate deeper .qu;fe~s and we"s serving homes on Edso~ noac.
Therefore, safe d~1nk;ng water and groundwater restoretion w~1' be
recommended independent of I:t;on taken at Page' 's Pit.
It is poss1b'e groundw!te- trea~nt w111 ~oye con~a~~nan~s cont-i~~~e~
by Page' 's Pit. When.n Rtrs is com~'eted on Page' '$ Pit, it ~ay be
pcssib'e to apportion the costs ~etW!en the ~wo sites.
-------
.
~
JI1JnIlI~ En\,lrllnnh'nt..1 I'rll"", '"11 .~':"IH,'
::~III' Churl t.1~; k'hlC:
"'LJ!' '~'f:" . iC :: .. -'II
~Ni: This p~posed .ia of remedia' actions 8aY not sat~sfy th~
require8tnts of the Nationa' Contingency P1.n.
COMMENT: On-site land disposa' was appa~nt'y rejected for the
contaminated soil.
tOMM[NT: The~ is no basis ;n the feasibility study for the ap~a~!nt
rejection of on-site landfilling.
RESPONSE: The feasibi'ity study evaluates the advantages and potent;a~
problems with each remedia' action. The evaluation process d!ve'o,e~ ~y
the t.t. Jordln tOllpany 1'$ consistcmt with the criteria in the Ha~ione~
Contingency "an for dett~ining Ippropriate ~edil' Ic~ion. A~tep a"
the factors .e~ considered, the tEPA de~eMmined that the on-sit!
inciner.tion option w1" be recommended to the USEPA.
OUESTION: In how many homes would carbon treatment units be use~~
RESPONSE: Based upon the 10cltion of the underground chemica' p'~e an~
drinking water criteria, approximate'y 6 to B homes WDu'd immediate1y
receive home carbon treatment units if this opt'on is se'ected.
~onitor1ng ~'1 be conducted on othep drinking water wells. 1f
significant concentrations of contem1nants a~ detected. those homes w~u'd
I'SO receive these units.
~
i
QUESTION: Cou'dn't the manufacturers who generate~ the was~e a~ th~s s~~e
treat or dispose of this waste themse'ves?
RESPONS£:
cleanup.
tOMM[h~: If indeed incineration is an option, the~e is every poss~~;'1ty
that the 10ca' 1ntergovernmenta' Solid Waste CGm"-ittee would ~e mos~
w1"1ng to discuss cost sharing of an adventure of this SO~ be:euse
indust~ in Winnebago County generates a 'a~e Quantity of h!za~ooJS
waste. Maybe In inc1nerato~' cou, d have 1h~' t1 p'e uses.
Yes.
Responsib'e pa~t1es wi" be reQuested to concu:~ the
RESPONSE: A1though respons1b'e parties w1'l be requested to ~;nan:e s~~e
c1elnup, 1t 15 un11ke'Y that they.wou'd be w1"1ng to negotiate ,1e!nup
costs for In option that wou'd hand'e wastes from other sites.
If Superfund 80ney is used to finance the incinepator, fede~ai 'eg;s1a~io~
~rec'udes Superfund financed options from han~'in9 wastes fro~ ot~e~
sourtes.
'Issue: Site Background
QUESTION: How much higher in e'evatior. is the A:me So, vents site ~n!~
Kn1buc:k Creek?
IESPONSE:
About 80 fHt.
-------
'. .
-
@
Jlllnol:" F.r,\"Jfonm,'nt.aI Prill"\"! Illn A~,'nl'.\
:.!~II(' rhuflhdl R...c! ~prln~r,t"ie I L ~..'7....
OUESTIOl: In "72. the I"1no1s Po"ut1on Control B08~ orde~d A~
So'vents to c'eanup the site. Between 1975 and '980 it appe.~s tha~ no
c'eanup action ..5 taken. Whit actions .ere tlken by the JEPA to monitor
the site?
RESPONSE: The JEPA conducted ~sistivity surveying and installed two
ground.,lter .O~itOMng we"s.
tongress responded to the need to tlte action .t hazardous waste sites
11ke the Ac8e So1vents site by enacting the tomp~hensive Environmenta'
Response. tODPensat1on. and L11b11ity Act (CERCLA) in "80. tommon'y
known as the .SuperfundR 1aw. CERCLA fi1'ed a gap by p~v1ding 1ega' .n~
financia' neans to federl' and state goverftnents to ~spon~ to c'ose~ or
abandoned hazardous waste sites. Superfund is supported 1a~e'y bj tl~es
on producers and importers of petroleum and 42 basic chemica's.
QUESTION: Did Acme So, vents eyer pay a fine imposed during the '97C's~
RESPONSE:
IEPA ~cords indicate that Acme So, vents paid $2,000 in fines,
Misce".neous
QUESTION: Wi" potentia' buyers of the site be warned or restricted 85 to
future uses of this site?
R!SPONSE: A question of 'oca' zonin9 or other restriction on the use o~
the site shou1d be directed ':0 the Winnebego toun~y Board and 'oca' :Or1~n;
offic;a1s. In Iddition. sta~e 'aw reQuires tha~ the owner Of the p~ope~y
.ust ~co~ info~ation on the deed to the prope~y that the 'end has bee~
used to dispose of hazardous waste.
;
.
.
. '
OUESTION: What is the cause of the concentration of contamina~ior. fou"~ 1n
the 9round~ater southeast of Pagel's Pit?
RESPONSE: The cause is uncertain. The contamina~ion cou1d be fr~~ the
Acme So'yents site. Page' 's Pit, or both. Howey,,,,. it appears t,'\at
contamination CODeS from Plge"s Pit ~th some contribution from A:me
So1vents. .
QUESTION: Was PIge"s Pit 8On1tored after I permit. by the IEPA was.
1 ssued~
RESPONS£: Yes. ~ r.onitoring system was estab1ished unde~ t~e o~;;in!~
per.!1t, but the info~ation obtained from this system. ;s 'im;te~. .
SM :jd/O' 35£"8-:4.
-------
ENFORCEMENT CONFIDENTIAL
ATTACHMENT I I
-------
ATTACHMENT II I
Soil Contamination Evaluation Methodology
.
.
;,
- .
-------
'. "...J~ 'I. '...
J..u;J;':' ...\...*--~..~~ ;"."..: '.-.'
: ~ .".~. "t
J(; ,'('D. ,;.u.c
A prop:>sed rule to 40 crn Part 261 publlshed in the Federal Register Voll.:T1e
50, NO. 38, Tuesday February 26, 1985, presents a two dimens~onal ground ~ater
flow model, called the Vertical Horizontal Spread (VHS) model. ~ ~as p~~l~shed
by P.A. Domenico and V.V. Palciauskas in Groundwater magazine, MaY-June 1982
issue. The Superfund Offlce will apply thls model for determining
levels of cleanup for contamInated soil at Superfund sItes. Tb do this, a
leachate equation Is also necessary and together these two equations constl~~te
the Soil Contamination Evaluation Methodology (S
-------
These values, then, represent the dilution of a contaminant in the
horizontal and vertical directions as the contaminant is transported d~~-
gradient from the source. Dispersion is essentially dilution by a mix~ng
process caused by the physical characteristics of the aquifer. Longitun~nal
dispersion is an indicatIon of the spread of the contaminants in the direct~o~
of flow and Is generally high compared to transverse dispersion. However,
longitudinal dispersion Is not considered in the VHS model, thus providing a
degree of conservatism, in this case, to wells B-4 on the sIte boundary and
8-16 and 8-9, sanewhat west of the site as shown on the map on the next page.
Fbr"purposes of utilizing the model, thIs analysis of contaminant migration
" assumes that the wastes are located in the ground water. Since the wastes
are pr~rily above the ground water table this assumption on first impression
may seem invalid and a pulse loading model may appear to be more appropriate.
However, since bedrock. is highly fractured and likely acts as a conduit for
contaminant migration to the aquifer, there is little retardation of the
organic and inorganic solute as it wdgrates downward. This a~lysis assumes
that bedrock beneath the site is saturated with hazardous substances because cf
the contaminant migration which has occurred over the years. Additionally,
it is assumed that the contaminated bedrock which is in contact with the
ground water serves as a continual source of contamination. Since the source
of contamination Is the hazardous material in the pits and this contamination
is incorporated into the soil above the bedrock, the values obtained by the
vas model for Co will be applied to the soil leachate, not to the bedrock.
Since it is difficult to measure or monitor bedrock contamination,
monitoring wells must be used to provide access for measurement of ground
water quality, beneath the bedrock. Thus, it is conceivable that although
levels of contaminants in the soil ~ay be decreased, in accordance with
values for ground water generated by the VHS model, contamination in
the bedrock may still be higher than soil contamination levels for an as yet
undetermined period of time. The FS for ground water and bedrock
remediation will consider this in the determination of cost-effectiveness
of treatment alternatives.
.
R
Tables 1 and 2 on the following page indicate the values used in the 'lHS
equation to determine Co, the allowable concentration for the target list of
contaminants in the ground water. The values generated by the VHS model for
Co are tentative and based on available Infor~ation but are as precise as the
assumptions used in the SOCEM model presently allow. The r.odel can be furthe~
refined as more data are generated at the site.
,......"""
--..- ."-.' .-, -. '.'~
-------
TABLE 1. Concentrations Allowed at Source to protect B-4
Contaminant Proposed 8-4 (X) 8-4 (Y) (Z) Co (source)
MCL (ppb)* Meters Meters Meters ppb
Lead 50 15 30 3 332
Arseni c 50 15 30 3 332
Chromium 50 15 30 3 332
Cadium 10 15 30 3 66
8enzene 5 15 30 3 33
Vinyl Chloride 1 15 30 3 7
Trichloroethylene 5 15 30 3 33
l.l-Dichloroethylene 7 15 30 3 46
TABLE 2. Concentrations Allowed at Source to Protect 8-9 and B-16 ;
r
.
-
Contaminant Proposed 8-10 (X) B-10 (Y) (I) Co (sourc
MCL (ppb)* Meters Meters Meters ppb
Lead 50 250 30 3 4,431
Arsenic 50 250 30 3 4,431
Chromium 50 250 30 3 4,431
Cadium 10 250 30 3 886
. Benzene 5 250 30 3 443
Vinyl Chloride 1 250 30 3 89
Trich-oroethylene 5 250 30 3 443
l,l-Dichloroethylene 7 250 30 3 ' 620
Note: 8-9 has approximately the sa~e values as those provided for 8-16. Therefore,
Co for protection of 8-16 = Co for prot~ction of 8-9.
0 = transverse dispersion = 5 meters.
*to be published in the Federal Register
.. ..,..-.-.....-.... - no"
-------
The results of Tables 1 and 2 show allowable contamlnant levels at the source--
the area beneath the mounds--that should protect drlnk';'ng water use-at 8-4,
B-9, and B-16. At this time it is more crltical to protect the drinking
water at the distance closer to 8-9 and 8-16 s';'nce those wells are in the
proximity of resldential wells. well 8-4 may not be a representative dr';'nk';'ng
water monitoring well due to its proximity to the site and due to other means
of contaminant migration to that well whlch may not be simulated by the VHS
model. The means of migration may also be through diffusion processes and
the assumption of steady state flow may not apply here due to apparent local
perturbations in the grounwater hydrology. Therefore, well B-4 is stil~
under consideration as a monitoring well, and wells 8-9 and B-16 are tentatively
used in this analysis as compliance rnonitoring wells.
If the soils are saturated down to bedrock with hazardous waste then the CD
values are those values that also apply to the MCL in the soil. HOwever,
other means of determining the leachate from the soil into the groundwater
should be tested during the design phase. The soil will be distrubed and
substantially mixed during excavation. SOil that is not-visually contaminated
or by some sensing device (such as, a photo ionization meter, portable GC or
other instruments) is determined to be suitable for retention on the site,
should be analyzed by a leaching test that simulates natural conditions at
the site. '!be results of the leaching test i.e., the leachate concentrations,
should be compared for compliance purposes to ~~ose values determined by
VIiS, i.e., Co, for each canpound of concern. If the leachate values exceed
the values generated by VHS, then more soil must be removed or incinerated.
The leachate test will be developed by u.s. EPA and IEPA as part of the
design Scope of WOrk. The values of Co determined herein are not final
values. The compounds are the target list of compounds and others may be
added as the mounds on the site are further evaluated and the ground water
further analyzed as specified in this ROD. The Y values used in VHS are
particularly subject to change as new data are produced, and thus CO would
also change. Nevertheless, the values produced herein represent the precision
available to interpret the data, and the precision allowable by the assumptions
in the VHS mode 1.
;
. -
-------
.
i
)
Rockford
Blacktop
(:) - /J A'
8.. 2 / B-1
SOLVENTS
-- -
ACME
[] 8554
, '
. "
. i
: '.1
. , I
< " ~
8811
'V
g
.
c
o
'V
-
8-.8
08800 \
o
8-5
..,
a
o
0::
I.""" ,
-------
, .
,
.
J
.
,
1
j
i
1..., "
.1 ".1
"1 "" :\~;:i
-....
.~.
\
\
\
\
f ,.,
LEGEND
~
~
8
ARf'AS WHERE DRUMS ACTUALLY FOUND BY JORDAN
MAGNETIC ANOMALIES (Fit COfttroclor)
J
---....- ."",.
--- --- ...-'
...."~
STRONG MAGNETIC ANOMALIES (fit Contractor)
u
~CTE
~C rOOT GRID LABELED A THROUGH I AND I THROUGH 24
. ...... .
------- |