United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-86/CW5
August1S86
SEP A
Superfund
Enforcement Decision Document:
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TECHNICAL REPORT DATA
{P/~aJ~ ,~ad 'IIS/rueI/OllS Oil tht ,t~'~f1~ btfort co,""/~IIIIgl
,. REPORT NO. [2. 3. RECIPIENT'S ACCESSION "'0.
EPA/ROD/ROS-86/045
.. TITl.E ANO SUBTITl.E 5. REPORT DATE
ENFORCEMENT DECISION DOCUMENT A110U s t 14, 1986
A&F Materials, IL 6. PERFORMING ORGANIZATION COOE
(Second Remedial Action)
7. AuTHORIS) 8. PERFORMING ORGANIZATION REPORT ,''0
9. PERFORMING ORGANIZATION NAME ANO ADDRESS 10. PROGRAM EI..EMENT NO.
1'1 CONTRACT/GRANT NO.
I
I
12. SPONSORING AGENCY NAME ANO ADORESS 113. TYPE OF REPORT ANO PERIOD COVEREC
U.S. Environmental Protection Agency I Pin",' ROD ~<=>,",,",d'
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
1!5. SUP"I.EMENTARY NOTES
16. ABSTRACT
The A&F Materials site is located on three and three-quarter acres in Greenup, IL.
The. site, or iginally an undeveloped backwater flood zone for the Embarras River, was
first developed for a sawmill operation. Mr. Ken Ault purchased the site for the A&F
Materials recycling plant, which began operations in March 1977 and continued until it
shut down in 1980. The plant processed waste materials (including but not limited to
oil, sludge, caustic and sulfuric acid) into fuel oil and fire retardant chemicals.
During the course of operations, there were numerous violations of the operating pe r m i t
issued to the plant by the IEPA. By Marc h 1978, four storage lagoons became filled and
began to overflow, contaminating the soil and drainage pathway. In addition, thirteen
steel storage tanks containing a mixture of waste oils (contaminated with PCBs and
organics), sludges, spent caustics and acids, contaminated water and other waste
products, were located onsite. The tanks had fa iled on several occasions, releasing
their contents. In March 1980, May 1982, and December 1982, actions were taken at the
site to lower the immediate potential of releases. These actions included lowering the
level of wastes in the lagoons, diking, trenching, cleanup and removal of onsite and
offs i te wastes. In addition, a tempor ary cap was placed on the consolidated sludge in
~arch 1983. In September 1984, the Aluminum Company of America, Northern Petrochemical,
CAM-OR Inc. and Petrolite Corporation entered into a Partial Consent Decree (PCD)
(See attached sheet)
17. KEY WORDS ANO OOCUMENT ANAl.YSIS
a. oeSCRIPTORS b.loeNTIFIERS/OPE'I ENOED TERMS C. COSAr! FII~ldiGroup
Enforcement Decision Document
A&F Materials, IL
(Second Remedial Action)
Contaminated Media: qw
Key contaminants: VOC s, organics, TCE,
metals
18. OISTRIBUTION STATEMENT 19. SECURITY CLASS; Tlus Rtpon) 21. NO. OF PAGES
None 49
20. SECURITY CLASS iT/uS pllgt/ 22. PRICE
None
!PA 'CHIII 2220-1 (R.... 4-77)
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EPA/ROO/R05-86/045
A&F Materials, IL
(Second Remedial Action)
16.
ABSTRACT (continued)
whereby the companies agreed to undertake surface cleanup at the site as an
additional removal and remedial action. Pursuant to this PCD, an RI/FS was
prepared by the consenting defendants which determined the amount of
soil/sludge to be removed and the extent and flow direction of ground water
contamination. Following the soil removal in 1985, only phenols and benzoic
acid were detected above the non-detectable limits. The most significant
contaminants of concern found during the RI/FS include: sulfates,
inorganics, TCE, and metals.
The. selected remedial action for the site includes: ground water
monitoring of the natural purging and dilution of contaminants;
institutional controls; and establishment of procedures for regular review
of monitoring data. There is no estimated capital cost associated with this
remedy, however, the PRPs have agreed to pay the estimated annual O&M costs
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PiFORCE ME ~T OE CIS InN nC)c!J~E NT
REMEnIAL ALTERNATIVE SELECTIO~
Site:
A & F Materials Conpany, ~reenup, Illinois
Documents Reviewed
.- -----
I am basing my decision primarily on the following docu:nents r:lescrihing the
analysis of the cost and effectiveness of remedial alternatives for the A & F
site in Greenup, Illinois:
,- "Remedia1 Investigation Report, A ~ F Materials
Company Site. Greenup. Illinois", EnSjineering-Science.
October, 1934.
. 'f
- "Feas i bi 1 i ty Study Report, A & F t~ateri a1 s Conpany
Site, Greenup, Illinois", Engineering-Science,
January, 1985.
. .
- Sum1Jary of Remedi al A lternat i ve ~el ect ion - Groundwater
- Com~unity Relations Responsiveness Summary - ~roundwater
- Partial Consent Oecree, dated Septern~er 12, 1q~4
- Enforce1\.ent Decision Document, dated .June 14, 19R5
Descript~~~_~~_~elected Alternatives
The selected remedy consists of the following elerrlents:
1. Establish a groundwater monitoring program adequate to test th~ Feasihility
Study Report conclusion that all residual groundwater conta;1inatio1 refT\ai1i1~
after the 1985 surface cleanup will steadily decrease to safe levels hy natural
dilution and purging to the E'nbarras River without causing violation of Uater
Quality standards in the River, or passing IJnder the River.
2. Establfsh institutional controls adequate to assure that drinking wat~r wells
are not placed in contaminated groundwater areas during the period of natural
purging and dilution.
3. Establish procedures for regular review of monitoring data until safe levels
are reached, or until data contradicting the Feasihility Study conclusions
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2
Declarat;ons
Consistent with the Co~prehensive Environmental Response, Compensation and
Liability Act of 19:D (CEqCLA), orJ[j the National Contin:;jency Plan (40 CFR
Part 300) and after consultation with the Illinois Attorney Seneral and the
111;no;s EnvirofJiflenta1 Protection Agency, I flave ,jeter:1ined tI-Jat tf,e above
remedy for the A & F Materi a 1 s site; n GreenlJp, 111 i noi s ; s a cost effect i ve
remedy that provides adequate protection of public health. welfare ani t~e
environment. IA addition. the action will require future 0 eration and
ma:ntenaoce activities to enSure the contin~;ien . ' of t:~
. J Valdas V. Adamku -_-.:.~
. . Re]i ona 1 ~dmi ni s rator
. ,
v
tr
O--~~~q-1-I9~t
ate ~-i1~:?._--
At tachr:1ent s:
Summary of Rer:1edial Alternative Selection
Community Relations Responsiven2ss ~Uf1'rj.1ry
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I.
SUW~ARY OF REMEOIAL AL TERNATlVE SELECTl1N - r,R')lINDWATER
A & F Materials Site, Greenup, 111;no;s
Site Location and Description
----
The A & F Materials site is located o~ three a~d three quarter acres
of lanj on \{est CUlTlberland Street in Greenup, 111;nois (Fig'jre 1).
The site ;s -bounded by open farmland/woodland, the Village of r,reenup
wastewater treatment plant, and private residences (Figure 2).
Ora;nage from the site reaches the E~barras River by a ditch along the
. .; l11ino;s Central Railroad tracks. The site has a pronoiJnce,1 sllJpR
. . toward the Embarras River. The portion of th~ site outside of the
facility fenceline is in the river's lOO-year f1ood~)lain. The City
of Newton occasionally withdraws drinking water fro~ the Embarras
River twenty-one miles downstream of the site. No drinkin9 water
wells are presently located between the site and the EmJarras River,
the presumed discharge point of the shallow groundwater systems.
Geological information indicates that the site is underlain by sandy
deposits associated with recent strea1 developm=1t. T1ese alluvial
sands overlie a sand and gravel deposit of glac~al outwash origin. The
site is located on a hillside which discharyes runoff from rainf~ll
directly onto the site.
II.
Site H; story
This site area was originally an undp.veloped bac~water flood zone for
the Embarras River. The facility's property itself was firs":. de'/elopei
for a sa"""1il1 operation. It was this vacant prr:>perty that r~r. ~~en
Ault first leased and later purchased for th~ operations of the ~~F
Materials recyclin~ plant. The A & F Materials facility began operation
in March 1977 and continued until it shut down in 196J. The operatiQn
processed waste materials (including but not limited to oil, sludge,
caustic and sulfuric acid) into fuel oil and fire retardant che1icals.
During the course of operations, there were nUMerous violations of the
operating per8it issued to A & F Materials by the Illinois En~iro1~ental
Protection Agency (IEPA). By March 1973, four storage lagoons became
filled and began to overflow, conta~;nating the soil and drainage pathways
leading to the Embarras River. In additio~, thirteen steel storayc
tanks containing a mixture of waste oils (contaminated with PCBs a1d
organics), sludges, spent caustics, spent acids, contaminaterl water and
other waste products, were located on the site. The tanks had failej on
several occasions, releasing their contents.
After the closure of the facility in 1980, the site was classified as an
abandoned hazardouS waste site under CERCLA. There have been numerous
preliminary investiyations and short-ter"1 rer'1oval actions sponsored by
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t-11..........t"',::
A&F MATERIALS CO. SITE
Greenup, Illinois
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2
.
.
The A & F Hateri al s Comp 1'1J'
Priorities List of Decenber
original total of 419. The
Sept em)e r 1983.
Si~~ ,'13:> incllJdeJ on the proposed ~ational
1932. The site was r~nked 62 out of an
De.:em:,er 19<32 list was ':Jade final in
I I 1.
Current Site Status
-.--
\)
In March 1980, May 1Q82, and f)ecef'J~er 1912, various actions were taken
at the site to lower the im~ediate potential of releases. These actions
included lowering the level of ~astes in the lagoons, diking, trenching,
: cleanup anj relTJoval of on-site and off-site wastes. In addition, in
: : March 1983 a temporary cap was placed on the con sol idated slu~ge.
On September 12, 1934, a Partial Consent Decree was en~ered into by four
companies, Aluminum Co~pany of ~erica, Northern Petrochemical, CAM-OR
Inc. and Petrolite Corporation. Under the tenns of the Consent ~ecree,
the Co:npanies agreed to undertake surface clean1jp at the A ? F "1a:erial s
site as an additional re"loval and relledial action. As a part of that
removal action, a total of 60,000 gallons of caustic waste a,d 4,010
gallOrts of PCB-contami nated oi 1 frol:] the tanks, 10,000 tons of soi 1 /
s 1 udye from the 1 agoons, and 2J drur:lS have been removed fro" the site.
Pursuant to this Partial Consent Decree, a re.:]edial investigation/~easi-
bility study (RI/FS) was prepared by the Consenting Defenda1ts w~ic1
deternined the amO'jnt of soil/sludge to be rel10ved. Approximat~ly 1,130'")
to:);,; uf sOil/sludge, an estimated 1,332 cubic yards of PC3 contdrlinj~~i
soil, and a process building with conta:ninated equipmen: 'oIie"? ren\l~ I
frQ~ the site pursuant to the EnforceMent Decision Jocument whic~ was
signed ,June 14, nss (see At t~::II: I~f)t 1).
As part of the RI/FS, the Consenting Defendants conducted an inve~tigation
of the A ~ F Materials site to dete~Dine the extent and flo~ direction
of the ground water contamination. The site lies on a varying thic~ness
of alluvium till (3.1 to 21.0 feet thic\() wf1i:iJ overlays a san:J & gravel
zone varying in thickness fr~ 2 feet to 26 feet. Glacial till was
encountered only in the upland area on the east side of the site an~ was
d~teriolined to be 27 feet thick. The whole unconsolidated fOr1J~tiorl
mantles a Pennsylvanian shale of an unconfor~able nature. The be1~)c~ wa~
horizontally layered anrl has fracture Zones at various dept~s. Th~ soil
covering the site is variable in nature anj pro~a~ly represents an erosional
slump feature fror.J the surrounding bluffs or a floodplain depositional
sequence rather than weathered, in situ Illinoian till.
\...
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3
The most significant conta."inants tha~ have hee'1 fou1i in the groVn1v/ater
durin~ the RI/FS are sulfates, high total dissol~ed solids, trichloro-
ethylene, and metals. Tl1es~ conta,,,inants ha~e heen found at ele~ated
le~els were the tanks and lagoons were once located. and diminish in
amounts as the distance increases frolT1 the sitc. ~ll groundwater sa
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(Base map provided by city)
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CONTOUR INTERVAL - 5 FEET
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4
an,j 1321. The Conplaint alle:Ject that thp. ha"dling, treatment, storag'?
and disposal of solid and hazardous wastes at t~e facility presented an
im1ni nent and suhstanti a1 endanyer'1'\ent to healt"! an.j t~-= envi ron:lent.
The CO'1l1J1aint alsl) cited the defe"Jants for violation of Section 111(e)
of the C\~.;, as evic1enced by overflo'.v5 fro, t\,~ ;Ji+;s. The original Co:'1-
plaint did not include generators as defendants.
Letters to all knJ"''l yenerators, dated r4oven)er 3, 19~1, were se"t by the
Assistant U.S. Attorney requestiny their participation in site cleanup.
De~and letters to th~ yenerators for the required re~e1ial action were sent
by the Department of Justice on August 18, 198'2. Four generators w,~r,~
subsequently added to the lawsuit on Fe')ruary 14,19<33. C1ai1s IJ'11>?:" \~.:-
tions 105 and 107 of CERCLA, 4~ I).).C. 960S and 9607, were also a:1jej.
. :On September 12, 1984, a Partial Consent Decree was entered into by thp.
Consenting Defendants. Under the terns of the Partial Consent necre~, :1e
Co~panies agreed to undertake a surface cleanup at t1e ~ ~ F '1a~~ria15
site as an additional removal action. This action consisted of e''1;:>tyiny
and disposing of the steel tanks and e:nptying ann disposing of the sl;Jd::J~S
and soils in the storage lagoons.
\1
Additionally, the Partial Consent Decree provided for the Consenting
Defendants to conduct an tUfFS, to rei'nburse the U.S. for a'lj a11i:ht1al
e::Jeryency response taken at the site, and to reifTJ~urse t,e !J. S. for
5340,00o, and rei11burse the State for ~4!),l")n0. 5ubsequet1tly, "'c:)::>n'lell-
Douglas entered into a Partial Conse~t necree with the U.S. and the 5t~~~.
in which ~~c')or1nell-0o'Jglas agree:; to pay the :J.5. SlSO,Tl/ as reh"!urs'?:"1e1::
for past surface response costs at the site ani negotia~e on the fin31
re-:Je,j./.
Pursuant to the Partial Consent Decree, the Potentially Responsihle Parties
(PRP's) undertook two seperate s'Jrf~ce clean:Jps of the site w',ich incl:j,1~i
re'noval of 4 la90ons, 1 building, 2{) drums, 13 tanks, and conta'1ina~ei
soil re'noval. The site is presently filled with clean soil, gr3i.:?1, ~t1i
seejed for vegetation. The PRP's are insuring :'1aintenance of this cover
via ~ontnly inspections which are written in a letter for.~ re~jrt anj
nailed to the U.S. EPA Regional office.
The Consenting Defendants performed the RIIFS required by the Partial
Consent Decree and sub~ittej the RI and FS reports in lQ84 and lqQS re-
spectively. Upon written request, the PRP's continue to do groundw~ter
monitorin~ of the site until the details for a final grouniwater re~edy
can be thorou~hly developed. The Consenting Oefendant's ~I/FS was per-
fonned over a 10 week ti;;Jetd~le, and l'!1ore field data is re~;Jirej to confirf'1
the conclusions of the RIfFS. Specifically, more data is required to define
the western edye of the plu8e, and to deternine if the Embarras River is
a recharging or discharging river anj '¥',-=tl1er contarrlinants may travel
under the river bed possibly reaching the town's municipal well.
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5
:
v.
Alternatives Evaluation
The groundwater wells gove varia'Jle results. \Jells in the northern and the
western flow paths from the contaminated site areas showed high sulfates, TDS,
oil & grease values. Several ~etals were dete~te1 at levels higher than back-
ground. Groundwater monitoring indicate; that elevated levels of inorganic
and organic compounds are currently no~ discharging to the E"1barras River.
The Feasibility'.Study predicted that the dilution effect hetween the grou'1':1-
water and surface water prohahly will result in little or no contamination
of the Efobarras River from the ground water (see page 4-5,4-9, 4-1Q, 4-11,
4-12, and 5-1 in the Feasibility Study). The high velocity through the
aquifer will permit flushing of any residual pollutants. The CI)ntd''1;ndterJ
~a~erials and soils that were reMoved from the site eliminated the "lain
source for continuous leaching of contaminants into the grO:Jnrl..la:er. The
primary health concern is with the possible future development of the site
and tappiny of the present groundw~ter sources to be used for potable drinking
water su~plies, therefore, the aq~ifer of concern accord;n] to t~e J.S. ~PA
Ground ~ater Protection Strategy (August, 19q4) is a Class IlR aquifer.
Presently there are no drinkin~ water wells to the north anrl west of the site.
Based on the analysis conducted pursuant to &300.69(c), (d), an1 (e), several
technologies for addressing ground water contamination were initially screene1:
site monitorin~; containment such as capping the site an1 imp~rmeable barrier
walls; pu~ping of the groundw3ter; in-situ treat~ent such as biological tre~t-
Itlent, leaching/extraction, landfar"1niny, and physical/che.nical; collecti'Jn of
dra;nag2 such as interceptor trenc~es and treatment be~s; diversion gra~ing;
alternative drinkin~ water supplies; and no action. To the extent that it
was both possible and appropriate, at least one alternative was developerl in
each of the following categories:
(i) Alternatives for treatment or disposal at an off-site facility as
appropriate; the alternatives in this ~~teg)ry ar~: inter:e~tion
or 'pumpi n'~ of the groun.j.~ater for treatl!1ent on-site an.1 t'1en di scharge
to a drainage ditch off-site; interception or pumping of th2 grJun~water
for treatnent and then discharge to a water treatnent plant; pumping
the water to deep well injection; off-site removal of the residues
from treating the water with ion exchange or reverse osmosis. These
alternatives wOuld recycle the treated water but wJulj not result in
waste miniMization or destruction.
( i i )
Alternatives that attain applicable or relevant and ap~ropriate Federal
publ'ic health and environmental require'1ents; th2 alternatives in this
category are: all of the ab~ve listed alt2rna~ives, including the
natural purge and dilution with groundwater monitoring, with the
exception of using reverse osmosis to treat the-pumped groundwater
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(iii)
( ; v)
. 8:
. .
( v)
f.)
used alone, and the no action alternative. In-situ treatfTIp.nt wolll1
result in waste minimization and de5truction if done properly and
thoroughly.
As appropriate, alternatives that exceed applicable or relevant and
appropriate Federal pu~lic health anj eniiron~ental requirements; the
alternatives in this category are: pimping and treating of the gro'Jnr1-
water, aHernate drinking water supplies. PU"iJing drv1 tredtintj the
groun~water would recycle the water but would not result in waste
minimization or destruction.
\!
1"
As appropriate, alte~natives that do not attain applicable or relevant
and appropriate Federal public health and environmental requirements
but will reduce the likelihood of present or future threat from the
hazardous substances and that provide significant protection to public
health and welfare and t~e environment; the alternatives in this cate-
yory are: capping and diversion grading which would not result in
waste minimization ~r destruction or recycling.
The no action alternative was rejected because there presently ~r~
some contaminants in th~ up~er two aquifers. The contaminan~s are not
biodegradable but s~ould dilninish in strength tl1rough nat'Jral fl,jShi'IY
and dilution of the area.
The prel imi nary screeni ny criteri d used consi stel ()f three different sets of
critera. The first set of criteria was for technical reasons slJCrt a; eff~:tive1ess
anj reliability, site specific phjsical limitations, safety of technology,
time-fra'~e for implementation, and treatability of the wastes at site. The
second set of critera were environ~ental and public health screening criteria
such as danger to wildlife, aquatic life 0" j)lant life, public acceptance of
alternative, potential exposure routes, potential exposure routes, exp~sure
tir1e-frames, irreversible or irretrievable CO'TIl1itJilents of resources, rind
ifTlprOVe;!lellt in resO:.Jrces. The third set of criteria were regu13to:y criteria
SUCh as applicable standards, pennits necessary, and acceptability to o:1er
agenci es. .
Based on prel ;m; nary screen; ng, four a1 ternat; yes for ground water \'iere
developed and analyzed ;n detail: 1) isolation of the conta~inated wa~er,
2) recovery of the contaminated water with subsequent on-site treatfTIp.nt and
discharge, 3) isolation of the contaminated water followed by recovery within
the zone of isolation, treatment and recllarge, and 4) nonitoring.
,..
-------
7
The four alternatives are futher described below:
1.
Isolati0n of the Contaminat~rl Ua:er
-- - --
----- .
. I
. .
The Objective of this alternative is to isolate the
cunta~~nuted water. An impermeable barrier such as
a slurry wall or ~roj": curtain WOJld be used to divert
9rJund water flow away from the site area. A cap
would be used to prevent infiltration of rainw~ter
',-dt",i" t~e area enco1nr>asse1 by the slurry wall. In
addition to li.'\iting the lony-tem Jse of' t"',e la'1d.
this alternative d02~ Mt remove contaminate;j ground
water from the site.
"
2.
Recove r::.Y- _o..~ Cont ami n ated Wat..e r t h.r_oul,i' f)owng rad i ent
welTs. Qn-Slt.,! '.!,t'!,. Tr~Cltllent, and Discharge of
'~(~l.u~:. ~~ Orai nage O'ft'c'h--.. - - - -----
The objective of installin9 reco"e,y wells is to ca;~:jr~,
for treaVnent, contarT1inated water comin9 fro:" the sit~.
.6.. line of 10 wells placed hydrauliCr111y do',.m:jrajient
fro~ the site would be used for this purpose. The water
collecte1 would be treated for oil and 9~~ase, sulfate
and metals removals, and t'1~q dischar~~d to th,~ ,1rair1age
ditch adjacent to the site. This is the ~ost expensive
of the ground water alternatives analyzed.
3.
Isolation a~d Recovery of Ground Hater with subse'lu~r.t
On-Site T-r=eatment -~n..d--~~c:.harge-fo-t'l'~ ,:, ~iJif.:..c. sis:.i!:-~.
A slurry wall would be use,j tJ iSJlate contaf1inated
gro~nj water. A well located near t1e cen:er of the
enclosed area would withdraw co~ta~inateJ wate~ f)r
treatment at an on-site te1ilpJrary treatment facil ity.
The water withdrawn fro~ within the containment area
would be tre3ted for oil and grease, sulfate a~1 metals
removal. The water would be recharged in~1) the contain-
-------
8
4.
Monitoring Existing Wells
The intent of this alternative is to monitor the impact
on ground-water quality created after the r~moval of the
contamination source (oil/slud~e from the layoons and con-
taminated soils). The processes of naturally occurin; flusnin~
and dilution of the residual contamination would ~rovide a
means for improving ground-water quality in the area.
,I
~
- ..
Contami nated water rema i ni n'::j in the aquifer system wou 1 d De
flushed naturally. The level of contaminants in grounG-
water discharginy frQn the alluvium to the outwash ayuifer
should beyin to diminish after cleanup of the site. The
level of contaminants in the outwash should then be~in to
diminish in the site vicinity with a gradual reduction in
contaminant levels through the aquifer system.
Groundwater quality would be monitored quarterly and
monitoriny would continue for approximately 10-15 years
or lon~er. if necessary. until suCh time as the contaminant
levels in the aquifer system are at acceptaDle levels.
The details of the groundwater monitoring plan will need
.to be submitted by the Consenting Defendants to the
U.S. EPA and the State for approval prior to implementation.
See Table 1 for a summary of these alternatives and their respective
costs.
a. Groundwater Impacts
A summary of groundwater data collected at the site during June, July.
and September. 1984. and August. 1Y8S, in comparison witn ap~licaDle
or relevant and appropriate groundwater criteria is provided on TaDle 2.
Only those constituents found at levels above the analytical detection
limits are shown. The locations of the monitorin'::j wells are shown
on Figure 5.
There are currently no drinkiny water or other production wells
located in the area immediately downgradient of the site. The
data were also evaluated assuming future development of the site
of the land between the site and tne Embarras River. If the site
.was used in the future prior to attenuation and diminution of the
-. contaminants through natural actions then the following cancer
'\i
-------
.-
."
.
TIIRI.8 I
8"""1\11' ~ PIIII....,.II!!!) III9UWIIIL IICrllHl8 POll CUIfTMllIlITaJ G1I()(JHIIIIIITIIII
DoIocr 11'11 on
a .Iu...., .all woul4 be .0a4 to "I.a..t
,rou~-.atar 'low awa, 'ro8 tbe con-
t..lnated .,.8. . cap wo,.Id: ... ..ed
to prevent Inlllt..tlon 01 r.lnw.tar
to the ...aa ancloa.d b, tho alarr,
..." .
...co...., ..II. 4ownt..dl.nt c.pta...
cont..lft.l~ -at.f. _.'.r wnutd be
tl..t.d: ror 01' .n~ q'...., autr.ta
anti ..t8t. '..0..'. ...tar woul" be
"I.char,ed to tho "r.ln0ge "Ilch
od)ocont to olto.
A .1...., .all uuul" be aa.4 to lao-
l.ta COtIt.8.lnated qro,.nrt ".".r. ..-
tor wlthdr,wn 'r08 vlthln tho con-
t.lnoant oreo ~.14 be trooted '0"
01' ana ,r...., .utl..e and ..tat. ~.-
.0..1. lI.ta.. woul" be rechor9ed Into
tho contolnaent oroo to .Id In 'Iaoh-
Int 01 cont..lnanl8.
~Itor ..Iatl", veil. In tho .one 0'
conto.ln.llon. 1I..rlo. _I" ... 001-
lacttlct qua,t.rl, uo". th. ("0I11..ln8"\
18.8'8 dRcr.... to arr.eptabt. 1...'8.
.._rt t.
"Inl.I... 019.otlon 0'
oont..tnant..
Conh.ln.IIOft .......84
hoe olt..
. ,
c.... h.1 n. II Oft .......
-------
111 i no is 7
Pollution
Drinking
~ater
Compound
Standard
---...-- -
UC)EPA
Cn ten a
T ri ch1 or..~elhy.1_e.II.J~., .~P-~ - '" --- -- -- 2. A/S. 0
Phenolic_s_,---I?Pb 1.0 3500
Benzene, ppb
T ox, py_'!.-
Sulfates, ppb
Nitrates-:-ppb
Totdl Dissolved
Solids, ppm
Oi ~ .\. greas-e-,--ppm .
Ch onde, PY-!'!.
Conduct i vitv Tohms/ cm)
Copper, ppm
250 ppm
10 ppm
0.7/S.0
Z!J()
10
----
500
TARLE ~
'j}~OIJNnUATER EVALUATION
Sou rce of
IISEPA Cn terl a
P'/f)
3
8/5
f}
1
f)
500
0.1
250 -- --250--- --
0.02 .--- 1.0
------------
Nickel, ppm
Silver, ppb
Aluminwn, ppm
Z i nc, p,j-m. ----
Iron, ppm .
Lead, ppb -
Manganese, pp~--
5
1.0
1.0
50 ------
0.1 S
Chromium, ppb
Cadmium, P.P~---
50
_.- - - - - - ... --
10
l3ari urn ppm
1.0
13.4
/)
-
2 Po 6
--
4
Resu 1t s for
\~ell 1-f)
( Rackgro'Jnt1
< S
41)*
-------
A & F MA T[HIAL.~ cq, ~n E .. .. r1/1- 1 '\ \,
G,t;l;IIIII). ItI..,ul:i I ~ I \:..
. :. ... ~'II" ',' \f..
BORING A~'D f\.,1nt'.'ITOQII\IG I . .. ~\- ~ \ \::, .
WELL LOCA T!ONS' . ... " I (,/ ~-- \ W'~J~,~:~~\.c;') \
.', , . .~"'::i/?~~~/:.(':" ~
" St"rACE ~[~~~M-3 \ .~~ "?'
WA,m /' ,,/ \;P '»)\("~ '
, "" ,. Ina4l)1" ~. R-1 \~ ".'
/ R-2 "0l1li, ~~ M-4 ""
.' ,--M-o ~ '/'~ -5 ~ ~~\.'/:/
/~~ 1/ /;-
\;:P 0-:) ~t~'~'
. .~-2 ~ ,.i)Q-5
/ M-6~~~
M-1rO ..~~
~ M-9 C"Y"II- ~ ~ \
I '. ,-&w. ;;;;.~ <$\~::T\
/ ' 0,t.-9 .",,' ..~~'HL~I~!l.NL'"
. ~(!':\z.. ~"I.r (liSe,
. 0-10.,"r' . -~..; c!~I/!i1. '.If.!l
. ~,\~ ~i '0-0 .Y- ~
I ';'.. /7:/~~. ----, -,
~ f) ;'.') , ~-- SCAli V IY:11 LI
..~" 't\.// LI'OIIiU
~ "", I /,'l' VII A.... III 101,11"" M_-
----- _--;-.-'1' ".J ;/'" :.I.WA.iI 1I.IAU,tI.II'IA.,oCM ..-.-,-- '.ISII"I'INII;
IM.II."AI..,t- \' ,"/':
,.t" \.,.I~\ 0-7 //y. 0 :"OIlA..1 ."Nt<
\~' /' //" - - - :lUU'I,,;AI..AS
M 11 /" /- G ":"llIl/t.~.I"\ftl.I'I/IIA:'''tI
- "/,, ~/ (.II:.IIIV..III II. Will.' SO\'" "110 . "10\~11
L \9} . ( ..!. C'":;I''''AI~'''VII'' ,.../"1/""
.;: ~)),.".." \~
':; \.'\ al SA,.II Ma' I JI..vt I
I"r'ft ",.:/."(,, ~ ~ 11:11l1li111.51:1111'"11..
~. ./ " "''' " :.",." AU" ..IIA\I' I
I~I ."1,.'."'1111,""111 ~,"""t\~
IIIIU".' ,'/ / :.. III t 11111'" U I IAI.UVUIa..
\,,~,"/ Ipi ......I,~"""""III "/I"
,)", 'I :..1111111 II.' :;AI.' Ala"~IA"1/
, ;'n 1f'\1 III."" Will rto"'"ltlH,.N
II ,,/ '\ 1110\1.""111'"111:1\
TEST
"
n
(~
;.0
In
£.It
._-~.._-_.- --- _.- --.---- __.__0- __.0_"'.___"'.'__0'....__"''', . -_.-.--
-------
9
risk levels would be presented in the drinkin~ water:
.
Compound
Risk level
trichloroethylene
benzene
lead*
chromium
.barium
"thallium
4 x 1U-5
9 x 10-5
NA
NA
NA
NA
(14.4 times proposed MCl)
(7 times proposed MCL)
(16 tim~s proposed RMCL)
(1.4 times pruposed MCL)
(6.8 times MCL)
(3.2 times human health
criteria)
,
. .
. .
NA - not available
MCl - Maximum Contaminant Level under Safe Drinkiny Water Act
RMCL - Recom,nended Maximum Contaminant Level under Safe Drinkin9
\tIater Act
* - background exceeds 10-6 risk level
The followin~ Illinois Pollution Control Board (IPC8) standards would
also be exceeded if the ~rounawaters were withdrawn from the site for
distribution as a potable supply or for food processing:
Compound
Risk Level
phenolics
sulfates*+
total dissolved solidS+o
oi 1 & :jrease**+o
1 ead**
chromium
cadmium
barium
18.5 times IPCB standard
15.7 times IPCB standard
10.9 times IPC~ standara
60U times IPCS standard
6.5 times IPC8 standard
3.4 times IPCB standard
1.4 times IPC8 standard
6.8 times IPC8 standard
* - existiny concentrations in deeper rock wells also exceed
standard
** - background equals or exceeds standard
+ - not hazardous substances as defined by CERCLA
o - significant levels of 0;1 & grease found to be naturally
occurring in lower aquifers beneath the site
Since the groundwaters at the site pose a cancer risk greater than
10-6 if tnose waters were consumed at a rate of 2 liters per day
. .by a 70 kg person for 70 years, institutional controls wi 11 be
- required to prevent consumption of this water.
-------
10
b. Surface 'Water Impacts
All organic constituents for surface Wnters were helow detect;o~
limits except phenol which was found to probably originate fro~ an
upstream locatio1. r~p.tals were all at exp~cte~ levels except for
a~ elevated lead level from an upstrea~ sa~ple. There was an
elevated lead level in the ctitch that runs on the wAst s;rle of
the study area, but a municipal sewage tre~tment la900~ is locate1
;m~e~iately west of the ditch with a treatment plant discharge
line at the points where the elevated lea1 levels were fo~nd
(see page 6-20 in the Remedial Investigation).
. The cost-effective rer:ledy reco:nmended by the PRP's is monitoring of the grO'Jnct-
. water after removal of the source of conta~inntion to 01serve the effectiveness
of the natural flushing of the site and would cost approximately $~4,181 not
including installation and nonitoring of a'~ extra w~lls. The other t~re~
alternatives were: capping and isolation of yrounjwater at an approximate
capital plus operati~g and maintenanco. costs of $1,404,000; recovery of conta-
minat~j water from wells place1 dO~1~radient from the site at an approximate
capital plus operation and ~aintenance costs of $4,~25,n~n; and isolation and
recovery of groJn1water at an approximate capital plus operation and maintenance
costs of $3,325,000. (See table 3 for present value costs.) Since the pri~ary
sources of the conta~inants have been previously removed inclurling the process
building, its foundation, and the contaminated soil 311 the contaminants foun1
in the groundwater were primarily at elevated levels near the prQcessing areas
with diminishing contaminant levels further away from the sitp, the Agency
agrees that groundwater Monitoring should be the alternative of choice, hilt
the monitoring MJst be done on a broa1er scale than the proposal by the DQPs,
and institutional controls will be necessary. These provisions will increase
the cost of the selected alternative over the $~4,onn figure, but this altp.:na-
tive will still be far less costly th~n the other evaluated alternatives.
The contaminants of inte~est are those listed in ta~le 2.
c. Action Levels.
Action levels will be followed at selecte1 groundwater well(s)
; n order to provi de protect i 0'1 for human health and the en"i r01.1~1t.
Until a more field data can be collect~j ani a ~ore rletailed ground-
water plan can be developed by the Consenting Defe~dants which will
include more monitoring wells to the north and Wp.st and since there
~re no drinking water wells immediately downgradient of the site, the
interim monitoring points for the area north of t,e site should be
well M-11. This well is located at the approxi~ate point that the
-------
..
... ....
'1'/\111," 3
t'II~'" !:tI~'1r''''IIV ""III (;111111"" \-11\"",:11 111':'11:11'1\1. AI.1"':"III\'rIVf.~;
----- ----------------------- --.-
Remedi~l Allernative
---...---------
Capllitl C,)gt.
Operi\tlon and
H'll nt.enitnce Cost
- ------ -.- --.------------------------------.-
V 1 ( 1 )
Present it ue
----------------.-----------------------
1\1 terniltlve 1\:
Cr1ppil\q/IlDpprm~ithle Rilrrier
J.
I
r I
1"
Alternative B:
Oown!Jradi~nt. Rerovery Wp.ll"
and 'I'reft t.ment
1\lternitltve c:
Ir;.)).tlion, R,>rovf>ry and
Treatment
1\lt~rniltive 0:
Monitoring
$1,lno,onn
$24,000
$1,525,000(2)
$J,700,OOO
$1, I 2'J, 000
$fJ,oon,ooo
" I
$~,f)~5,OOO
$7(1),000
$5,250,000
$0
$24,000
$150,000(2)
( 1 )
( 2 )
- - - ------ ---- ---.- ----- - --.- --- --- -----------------------
J\R9umed intere!Jt rat.e of 10,.
lIit!Je.i on a 1J31~ fill I i Fe of I I) yea rq.
(.
Olher al'l"rllrltlves are hrl!Jf!.i on it life of five years.
~
Annlla 1 Cos t ( I
-------------
$ 275 , 000 ( 2 )
$2,100,000
$1,400,000
$24,000
-------
.. ~\;
~._, \\ v:,
I: . /- _oVO--:..~-\ \:~~ y;
1/ /, ' ') ~." ,
.~~ ~
. ~ \ 0 ~'
/" " . I //"~' . - t..---
,/ . . ,/ ~
/" v .t-~'#'
M-6 ?/
/'." M 9 "..:~O?/.
" -"#
/ ~'1!~7~.::~~''''"~
/' \.\~I/
~' V",~/./ /Y---' :'LAll;- -"Y;'ul
t)t\) .. "y---. ...." ~,
-- ~\,. .r/. V"IAld"(lf"la'~II~n'
--... _--r.1 \,1.\ /'~!" StW"'UI: ,'II\; A "'liH I/,',Ot)t~ UIlLIlU
O'~j~"AI"&t: ,t" /'/'
.. ..\\ -- -. ._- ('Oll111...) f(N(.~
\ . / / - - - D,""'1.'14U ',h~"
~ M--~ 1 ..Y / '. ./' 1v1-69 ~";':'~:;:~o"""'"
~ ,.." \\
UIIM...\ .y j.
~¥"I/!!
-.} < .
IT'
JJ
./'
"11- ",,\-'--""," <:' CO ('I"
1\0.1- ''.11-\ i L. "ALv . v ..-
G(CCII~P. 1::;l\ub
L" ~ ~ "'r~;-" ~J """ V- .... , (' t\. I~ ")'4.("\ ~ ~ ~ . ,r"",
f rf . l~ , ,.~! " ,- "J" ,~"\, . "~-{ ~:,\., ..,.
'-" ",,:J - . ....... ....., Ii . ... . - II .. ~ -" .... ..-.
'" WELL SITES
',,"'
,
"
ff
.
L
r
"
'1
-------
11
fore provide possibl~ warni1g if hig~ levels of conta~ina"ts
are about to enter, or pass under, the River. The action levels,
will be the U.S. EPA. Criteria listed in table ~ which includes
the lO-n cancer risk criteria. The monitoring points to the
w~st of the site will nee1 to be determined after the installation
of wells that are re~uired in order to define the western e1ge
of the plume. A contigency plan needs to be pre~arej ani rea1j
to im~le''1ent if the action levels are exc:e,::1eJ.
VI.
Commu n itj Re 1 at ions I Res pons i venes s Sumf11a ry
,
. .
. .
l11inois EPA (IEPA) conducted an extensive CO'Tl'Tlunity relations progra"1
which includerl several informal meetings in the homes of nearby
residents, written updates, and frequent conversations with intereste1
citizens, press, and local officials. The State, with II.S. EPA support,
respond~d to their concerns. PIJblic meetings, O:1e of ,~',ich was i\tten1~1
by staff from the Agency for Toxi c Suhstances and ni sease Regi stry, '.-/Ar,,=
also held by lEPA and U.S. EPA at several tilTles during the RI!=')
proc=ss. .
When the Pa rt i al Cortsent Decree was fil ed in .June 1984, IJ. S. EPA assuf'le1
the lead on com~unity relations, althoug~ the State maintained an
active cooperative role. Several public comment periods have been
held, acco'71panie1 I:>y pu')lic meetings, briefin':)s, and other n)tifi-
cation of interested parties. A five-week public CO'TP1<:1t p.:rio1 ~/a5
available for the FS upon which this record is based.
There was some dissatisfaction among the public during the final months
of the negotiations as some individuals apparently op.lievej tllat thej'
were unable to obtain feedback or response to t~eir questions. HQwever,
they are pleased with what has been accom;Jlished and the prrr1pt:less of
action once the Partial Consent necree ~as signed. Info~Tlation supplie1 ~j
nearby residents has been useful in discovering the full nature of the
contamination and is reflected in the recor.l!nendations for the site.
The responsiveness summary is attached (see Attachment 3).
VI!.
Cons;st~:1~j. ~~th Other Environme~~~~_~~~~
Prior removal and remedial actions at the site have ensured C~Tlp'~31:~ ~i~~
the CWA, RCRA, and Executive Qrder 11933, "Floodplain Manage:rent".
-------
12
~hen the levels of hazardous constitJents retJrn to below the applicable
Federal standards, the action level limits will no longer be require:1.
The proposed option Of ~r')tj'1J water !'1onitoring is consistent with U.S.
Ground-liater Protection Strategj of August, 19.14.
'="..,-,-
'- ., .::>
.
The provisior\.s of RCRA :oost closely addressing the type of remedial actio'l
undertaken at the Site are the regulations C0v~ring closure of surface i~-
pound'1ents. The surface cleanup perfor:ned by the PR~s i n p~::; const i tIlted
:an atte11pt t.) "clean close", in RCRA terminol09J', under 4') CF~ ?55.2?8(h).
, .Jf at site closure all contaminants are re~aved to background, the site
. .is no longer subjected to RCRA require~ents. However, ~onitoring data
shows that the soils left in the botto~ of the lagoon, wherl it WdS refille1
with clean soil, contained residual contamination (see ite~ III above).
If a su rface impound.nent owner d02s not rel~ove all contami nated soi 1,
40 CFR 265.22R(c) requi res a closure that includes grounj...ater '1onito"iny
dnd plaCel~r1t uf a final cover. The groundwater monitoring require.j "Jy
the selected rerledy at the MF Greenup site satisfies the purp'Js-=s (')f
trtP. RCR.\ 9roundwater monitorin~ requireiT1ent. The previously selecte.i
remeij for laguon closure required clean backfill in the lago)1. 112
over allows passa9~ of liquids, w~ich is apprJp;iatf~ ~~re, pro:!1oting the
predicted natural dilution and purgin~ t~at is the basis for selection
of the groundwater remedy.
TSCA was relevant to the surface cleanup o~ this site. Its prrwisions
were considered in requiring the PRPs to excavate and jisp)s~ of sluige
and soils contaminated at one part per million or higher of polyc~lorin-
ated biphenyls (PCBs). Due to this level of cleanup of the surface, the
selected groundwater remejy is fully consistent with TSC~.
The CH~, and t1e analagous state law provisions, set Water Quality sta'l.j-
ard~ for the Embarras River. The RIfFS predicts that the sele:terl re1e1y
will not cause violations of these standards in t,e ~iver, anj I!1Or1ito,iny
will be perfonned to specifically confirm this conclusion.
The Safe Drinking Water Act, and analagous state law provisions, set sta~j-
ards for water to be used for hu~an consumption. If drinkin9 wat2r wells
were to be placed into the contaminated yro~ndwater, these stan1ards would
be yiolaterl. The selected remedy prevents such violations by requiring
institutional controls to prevent construction of such drinKing water wells
until trie levels of contamination in the ground~ater have a~tentuate1 t~
-------
I :
-
-
13
VIII.
Recrnnmended Alternative
The Agency recommends that a groundwater monitor;n~ alternative, com-
bined with institutional controls and appro~riate reo~ener provisions,
be implemented to deal with ground water at the A & F Materials Greenu~
site. T~is alternative is the lowest cost alternative which is
technoloyically feasible and reliable, which effectively miti~ates
and minimizes damage to the environment, and which provides aaeyuate
protection of public health, welfare, and the envirornnent. The
remedy of monitoring the natural purginy and dilution of contaminants
from the yroundwater will in part depend on the future use of the
land and groundwater. "Institutional controls", meaning the limitation
on the use of the groundwater for potable uses, must be established.
Several acceptable methods to accomplish this include:
1) deed restrictions,
2) State or County Ordinances,
3) the Department of Mines & Minerals has the authority to approve
the installation of new drinkin~ water wells in Illinois and
will be contacted by tne U.S. EPA for restrictiny the developinent
of new drinkin~ water wells in this area,
4) Prohibit the installation of wells throuyh purchase of easements
from pro~erty owners,
5) Pay the difference for a city hOOk-UP
instead of drilliny any new wells in the affected area.
Institutional controls will be re4uired until groundwater quality
returns to background levels or below the State and Federal criteria
shown in Table 2. .
The monitoring alternative recommended by the Consentin~ Defendants
proposes monitoring from 4 existin9 monitoriny wells on a quarterly
basis, for 10-15 years, for a limited number of parameters (see
figure 6). However, a more comprehensive monitorin~ ~ro9ram than
the one proposed by the Consenting Defendants is required. More
monitoring wells to the north and west of the site must be installed.
An additional background monitoring well(s) must be installed
since the present upgradient well, M-1, is showing some signs of
contamination as of the August, 1985, groundwater monitoring done
by the Consenting Defendants. The reasons for this contamination
in well M-l are not clear at this time. The listing of contaminants
from table 2 must be monitored. The details of the monitoring
program will be discussed in the Groundwater monitoring plan that
will be submitted by the Consenting Defendants to U.S. EPA and the
State pursuant, to Phase IV of the Partial Consent Decree.
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..
14
IX.
Ope rat i on _'!.T1..:~.,~:.!_.,te'1a"ce
The Consentiny Defendants are re~~ired to submit an operatio'1 ani ~ain-
tenar'lce plan to be approved by U.S. EP~. U.S. E?A will req'Jire that t~e
Consenting Defendants imple~ent the approved plan.
.
~
x. Schedule of Future ~ctions
-------
Negotiate a9ree~ent for PRP's to imple~ent
I this £Or)
. .
Ilithin ~1 jays after
after t~is En1 is sig'1~j.
PRPs subnit revised plan, if _"e:essary
IJill be negotiat~j or,
if negotiations are
uns'Jccessf'Jl, a ""'ltil)'1
for trial will b~ ~a1e
to the court for a
trail date withi" 1~~
days of signir'lJ this
EfY).
PRPs submit Grounjwater ~onitoriny Plan a"i
Operation & Maintenance Plar'l (including
plan for institutional controls)
E?A/State review
EPA/State approval of plan
Be~in if1l~lerne1tin9 grolJndwater plan a'lj i:1pose
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. .
. .
A.TTA.CI-IMENT 1
Enforc~~e~t ~ecision ~ocument
-------
1 2 JUN 1985
RecOM"len
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ENFORCEMENT DECISION DOCUMENT
REMEDIAL ALTERNATIVE SELECTION
Site:
A & F Materials C~pany, Greenup, Illinois
Documents Reviewed
I have reviewed the following documents describing the need for r~ed;al
alternatives at the A & F Materials site:
URemedi~l Investigation Report, A & F Materials
CCJ!1pany Site, Greenup, Illinois", Engineering - Science,
Octobe'r 1984.
. "
UFeasibility Study Report, A & F Materials COMpany
Site, Greenup, Illinois", Engineering-Science,
Janua ry 1985.
Sumnary of Remedial Alternative Selection
Comnunity Relations Responsiveness Summary
Partial Consent Decree, dated September 12,1984
Description of Selected Alternatives
1.
Soil s/Sediments
- All 50ils contaminated over the recOMMended action
levels, including soils cont~infng greater than
1 ppn PCBs will be removed, and disposed of in a
U.S. EPA approved off-site facility.
Groundwater monitoring will be conducted to confirm
that no further soil removal is required.
2.
Buildings and EquipMent
. Equipment and structure of the buildings, including
concrete floors, wi'l be cleaned, dismantled, and
removed from the site for disposal at a U.S. EPA
approved facility.
- So;1 underlying the building will be tested and if
found to be contaMinated above the recomMen~ed
.action levels, will be disposed at a U.S. EPA
. -approved facility.
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2
3.
Site Grading
Site grading will include filling depressions to
eliminate ponding, covering with sufficient topsoil,
and providing and maintaining a vegetative cover
to prevent erosion.
....
The fencing surrounding the site will be removed.
Declarations
Consistent with the Comprehensive Environmental Response, COJT1pensation and
Liability Act of 1980 (CERCLA), the National Contingency Plan. and the
Partial Consent Decree of September 12, 1984, and after consultation with
.!-h~ Illinois Attorney General and the Illinois Environnental Protection
Agency, I have determined that the above remedy for the A & F ~1aterials site
effectively mitigates and minimizes damage to and provides arlequate protection
of public health, welfare and the environment. Groundwater issues at this
site will be addressed in a separate document.
1 have also determined that .the action being taken is a cost-effective alter-
native when CQT1pared to the other remedial options reviewed. In addition. the
off-site transport, treatment, and secure disposition is more cost-effective
than other remedial action alternatives considered and is necessary to
protect public health, welfare and the environment.
~~
Valdas V. Adamk s
Reg i onal Admi n i strator
L/ld!...j)
~~I~'
a e I
/~?S-
.
Attachments:
SUl11T1ary of Remedial Alternative Selection
Comnunity Relations Responsiveness Summary
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, .
SU~~ARY OF REMEDIAL ALTERNATIVE SELECTION
A & F r~terials Site, Greenup, Illinois
1.
Site Location and Description
:.
The A & F Materials site is located on three and three quarter acres
of land on West Cumberland Street in Greenup, Illinois (Figure 1).
The site is bounded by open farmland/woodland, the village of Greenup
. wastewater treatment plant, and private residences (Figure 2).
DrainagefrCJT1 the site reaches the Ernbarras River by a ditch along the
Illinois Central Railroad tracks. The site has a pronounced slope
toward the Embarras River. The portion of the site outside of the
facility fenceline is in the r1ver's lOa-year floodplain. The City
of Newton occasionally withdraws drinking water from the Embarras
River twenty-one miles downstream of the site. Geological infor~ation
: indicates that the site is underlain by sandy deposits associated with
, recent stream development. These alluvial sands overlie a sand and gravel
deposit of glacial outwash origin. No drinking water or other production
wells are located downgradient of the site. The drinking water supply for
the Village of Gieenup is separated from the site by the Embarras River
which serves as a hydraulic barrier to any ground water flowing fron the
site. The site is located on a hillside which disc~arges runoff fron
rainfall directly onto the site.
'.
II.
Site History
The A & F Materials facility began operation in Harch 1977 and continuej
until it shut down in 1980. The o~eration processed waste materials
(including, but not limited to oi", sludge, caustic and sulhric acid)
into fuel oil and fire retardant chemicals. During the course of opera-
tions, there were numerous violations of the permit issued to A & F
Materials by the Illinois Enviromental Protection Agency. By March
1978, four storage lagoons became filled and began to overflow, contami-
nating soil and drainage pathways leading to the Embarras Ri'ver. In
addition, twelve steel storage tanks containing a mixture of waste oils
(contaMinated with PCBs and organics). sludges, spent c,austics, spe'1:
acids, contaminated water and other waste products, were locat~d on the
site. The tanks had failed on several occasions, releasing their conter:ts.
After the closure of the facility in 1980, the site was classified as an
abandoned hazardous waste site under CERCLA. There have been numerouS
preliminary investigations and short-term removal actions sponsored by
U.S. EPA and IEPA to secure the site and prevent the release of contaninants.
.
The A & F Material Company site was included on the proposed National
Priorities List of December 1982. The site was ranked 62 out of an
original total of 419. The Dec~ber 1982 proposed list was Made final
in September 1983.
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.
II I.
. .
. .
2
Current Site Status
In '\arch 1980. '1ay 1982. and December 1982, various actions were taken at
the site to lower the immediate potential of releases. These actions
included lowering the level of wastes in the lagoons. diking, trenching,
cleanup and removal of on-site and off-site wastes. In addition, in
March 198! a temporary cap was placed on the consolidated sludge.
On September 12, 1984, a Partial Consent Decree. hereinafter the
8First Consent Decree", was entered into by four companies, Aluminu~
Company of America, Northern Petrochemical, CAI1-0R Inc. and Petrolite
Corporation, hereinafter MConsenting Defendants". Under the terms of the
Consent Decree, the Consenting Defendants agreed to undertake surface
cleanup at the A & F Materials site as an additional removal action. As a
part of the removal action, a total of 5,500 gallons of caustic waste and
4,000 gallons of PCB contaminated oil from the tanks, and lO,OO~ tons of
soil/sludge from the lagoons have been removed from the site.
Pursuant to the First Consent Decree, an RI/FS was prepared by the Consenting
Defendants which determined the amount of soil/sludge to be removed. Approxi-
mately 86: of this material, or 10,000 tons, has already been removed. The
only soil/sludge remaining is approximately 1-2 feet of material covering
the entire area of Area A and some material in the two lagoons (Figure 3).
The amount of soil/sludge remaini~g on-site is estimated to be 1,500 .tons.
The amount of soil contaminated wi~h PCBs which contained levels of 1 ppm or
greater was estimated to be 1,332 cubic yards (Figure 4). Area C has already
been removed. In addition, a small area of soil located at the western edge
of the building was found to contain high levels of contaminants, but no
PCBs were detected.
The RI/FS determined that hazardous substances were used in the building
and. there is evidence of spills and residues remaining in the equipment and
in the building. The building and equipment were not sa~pled due to the
expense involved. Therefore, the RI/FS assumes that the building and equip-
ment are contaminated with residues that are hazardous.
Existing geologic information indicates that the site is underlain by 3-21
feet of sandy alluvium over 2-26 feet of outwash sand and gravel. Prior to
the removal actions already undertaken at the site, a major potential pat1w:j
for contaminant migration was surface runoff from'the leaking tanks and over-
flow' ~rom the lagoons. Since the removal actions, the most significant
pathway appears to be subsurface movement of contaminants which may be
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3
IV.
Federal Enforcement
A Federal lawsuit to bring about site cleanup at Greenup was initiated
by the filing of a Complaint on September 3, 1980, pursuant to authority
under the Resource Conservation and Recovery Act, 42 U.S.C. Sections 6901.
6973, and the Clean Water Act, 33 U.S.C. Sections 1251, 1311, 1319 and 1321.
. The Complaint alleged that the handling, treatment, storage and disposal of
solid and hazardous wastes at the facility presented an imninent and substan-
tial endangerment to health and the environment. The C~p'aint also cited
the defendants for violation of Section 31l(e) of the CWA, as evidenced by
overflows from the pits. The original COMplaint did not include generators
a s defendants.
Letters to all known generators, dated November 3, 1981, were sent by the
! Assistant U.S. Attorney requesting their participation in site cleanup.
:: Demand letters to the generators for the required remedial action were sent
by the Department of Justice on August 18, 1982. The generators were
subsequently added to the lawsuit on February 14, 1983.
On September 12, 1984, the First Consent Decree was entered into by the
Consenting Defendants. Under the terms of the First Consent Decree, the
Consenting Defendants agreed to undertake a surface cleanup at the
A & F ;1aterials site as an additional removal action. This action consis:ed
of emptying and disposing of the-steel tanks, and emptying and disposing of
the sludges and soils in the storage lagoons.
Additionally, the First Consent Decr~e provided for the Consenting Defend-
ants to conduct an RI/FS, to reimb.urse the U.S. for any addi t ional ~er-
gency response taken at the site,"and to reimburse the U.S. for 5340,000,
and reimburse the State for $40,OOG. Subsequently, McDonnell-Douglas
entered into a Partial Consent Decree (hereinafter the "Second Consent
Decree") with the U.S. and the State, in which McDonnell-Douglas agreed to
pay the U.S. $150,000 as reimburse~ent for past surface response costs at
the site.
v.
Alternatives Evaluation
A.
Soi1s/Sediments
In the RI/FS conducted by the Consenting Defendants, several technologies
were screened and eliMinated. These included containment, diversion
and grading, solidification, insitu treatment, and no action. The no
action alternative was eli~inated because it dges not address the issue
of..existing c()nta~ination on site. SOMe action is considered necessary
to remove this contanination and the threat to hunan health, welfare
and the environment. Two alternatives were analyzed in detail: 1)
partial removal with subsequent disposal at a secure off-site facility,
and 2) cOl'1plete refl10val of contar1inated soil s/sediments above background
with subsequent disposal at a U.S. EPA approved facility. The costs
of all the evaluated alternatives are shown in Table 1.
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:'
.. f.
4
1}
Partial Removal
..
Partial renoval would include removal of the four
contaninated soil zones and any other areas wi th
contaminants at levels of concern. This technology
would be useful in conjunction with disposal at a U.S.
EPA approved facility. The environmental and public
health risks for this alternative are low.
2)
COl"lplete Removal
Complete removal would consist of removal of all conta;1i-
nated soils and sediments. This technology would be used
in conjunction with disposal at a U.S. EPA approved facility.
The environMental and public health risks associated with t~is
alternative would be low.
B.
Building and Equipment
In the RIfFS. the no-action alternative, consist;'lg of monitoring and
analysis and site maintenance. was screened and eliminated for the
building and equipment. The no-action alternative was el iminated
because it does not address the issue of existing contamination on
site. SOI"Ie action is considered necessary to remove this contami-
nation and the threat to human health. welfare and the environne~t.
Three alternatives were analyied in detail: 1) cleaning and cOMplete
removal. 2) decontamination and.. corr1plete removal, and 3) cleanin;/
. decontamination and partial removal.
1 )
Cleanina and Conolete Removal
~
This option consists of cleaning using high tenperature,
high pressure equipment, dismantling of the equipment
and the building including the concrete floors, and
disposal at a U.S. EPA approved facility. Effluent froM
the cleaning process would be treated, tested and discharges
in a manner approved by U.S. EPA. Soils beneath the building
would be tested and, if contaMinated, would be removed, and
disposed of in a U.S. EPA approved facility.
2)
Deconta~ination and Complete Removal
.: This alternative
high temperature
is determined to
.
involves deconta~ination, with repeated use of
and high pressure equip~ent, until the material
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5
equipment as described above, would be disposed of in d ~anner
approved by U.S. EPA. Conta~inated water generated during
decontamination would be treated, tested, and discharged ~n a
manner appr oved by U. S. EP A.
3 )
Cleaning and Partial Re~oval
This alternative involves cleaning of the equipment
and the structure of the building as described in
Alt~rnative 1, and disposal at a U.S. EPA approved
faci~ity. After the equipment and the building are re~oved
fr~ the site, the floors and foundation would be deconta~-
inated. Core samples of the concrete would be collected
to deterMine the effectiveness of the decontamination.
If no contamination is found, the floors and foundation
would remain. Contaminated water generated fr~ this step
would be treated, tested and discharged in a manner approved
by U.S. EPA. .
, .'
. .
C.' Surface Water
The surface water at this site is define& as the water in the Embarras
River and in the unna~ed drainage ditch near the west boundary of the
5 ite.
In the RIfFS, two alternatives were analyzed for surface wa:er:
1) no action, and 2) continued ~~nitoring and analysis.
VI. Recommended Alternatives
A.
50i15 and Serliments
Parti al rE!l1oval is the most cost-effect i ve (least cost
alternative that effectively mitigates and minimizes
damage to hunan health, welfare and the environment)
alternative for soil and is therefore the reco~ended
option. This action will comply with the terms of the
First Consent Decree by re~oving soils found to contain
greater than the Action Levels shown in Table 2, and
disposing of these 50ils in a U.S. EPA approved facility.
Off-site disposal of the soil ;s selected because it is
the most cost-effective and because it is necessary to
protect public health, welfare and the env;ro~ent from
risks created by further exposure to continued presence
of the substances.
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6
Figure 4 shows the three-areas on the site excluding the lagoons,
that were contaminat~ with greater than 1 ppm PCBs. The vol~me
of soils to be excavated at each of these areas was calculated
in the FS as follows:
.f
Area A = 50 feet wide
100 feet long
4 feet deep
. eq u a 1 s 20,000 ft3 or 740 yd3
Area B = 30 feet '#i de
50 feet long
4 feet deep
equals 6,000 ft3 or 222 yd3
Area C = 100 feet wi de
100 feet long
1 feet deep
equa 1 s 10,000 ft 3 or 370 yc3
,I .'
The total amount of soil to be remcved frOfT1 the three are3S is
36,000 ft3 or 1,332 yd3 as cCfT1puted in the FS. Area C has
already been removed.
In addition, the area along the-western ~ge of the building
was found to be contaminated with PM ccxnpounds. These 50;15
have also been removed and disposed of with the PCB conta~inated
soils (Figure 3).
The remainder of the site apparently contains various areas with
de minimis levels of other ccxnpounds. De min;~is levels are
c~paraD1e to those found to occur naturally ;n the environ~e~t,
and are below levels which would pose a threat to hu~an health,
welfare or the environment. Table 2 shows the background
levels of the compounds of interest found in the soil and
sediments at the A & F site. and the suggested action level
for soil/sediMent removal. Soils found to contain levels
greater than those in Table 2 are recOMmended for disposal at a
U.S. EPA approved facility. Re~aining soils bBneath the lagoons
wi.11 also be removed to levels below those identified in Table
2.
In response to concerns expressed at the December 4, 1984 publ ic
meeting, additional soil samples were taken from two locations
identified by local citizens. These saMples were split with
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. .
7
The lAG analyzed for aliphatic hydrocarbons as well as for thp.
contaminants of concern. low levels of aliphatic hydrocarb&ns
were found in the split samples. Because aliphatic hydrocarbons
are not contaminants of concern, as shown in Table 2, the Consenting
Defendants were not required to analyze for them. Aliphatic hydo-
carbons are compounds found in 011. However, based on review of
these sampling results by the Centers for Disease Control, aliphatic
hydrocarbons do not present a healtr. threat at this site, particularly
at the low levels found. Both the lAG and the responsible parties
analyzed for the contaminants of concern and no concentrations
above the action levels were found.
~
The Consenting Defendants will be required to confirm that hazardous
substances above the action levels are not present in these two
areas by condu~ting additional soil samples in these areas. The
approximate locations of these samples are shown in Figure 5.
Samples will be taken at each of these locations, at depths of
1-2 feet, 2-3 feet, and 3-4 feet, for the purpose of deter~ining
the areal and vertical extent of contamination, if any. These
samples will be analyzed for the hazardous substances shown in
Table 2. If hazardous substances above the action levels are
found in these samples, the soil in these areas will be remQved.
Comments received from State agencies and the public regarding soil
removal included the suggestion that additional soil be removed
both to reduce the flushing time of the remaining low levels of
contamination, and to remove-the aliphatic hydrocarbons. However,
based on the determination that h~man health and the enviranment
will be protected after soil removal to the recommended action
levels, no further soil removal is required. The Centers for
Disease Control concur with this determination. In order to
confirm that no further soil removal is required, groundwater
monitoring will be conducted. In addition, the Consenting Defendants
will be required to implement further remedial action if dee~ed
:necessary by U.S. EPA. Additional details and require~ents
regarding groundwater remedies will be discussed in a separate
document.
\
The sediment from the river and the ditch which was analyzed in the
Remedial Investigation Report showed contaminant levels well below
the suggested action levels. Thus, it is not recommended to remove
and dispose of sediments from the drainage pathways at this time.
B.
Building and Equipment
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I . I
. .
8
is cleaning and c()'T\plete renoval. This action is the !!'ost cost-
effective because it is assumed. in the absence of sampling data,
that the building and equipment are contaminated with hazardouS
substances. Sa~pling of the building and equipment was not conducted
due to the expense involved. Under this alternative, the ~quip~ent
and structure of the building would be cleaned, dismantled and removed
from the site for disposal in a U.S. EPA approved facility. Rinsate
from tAe cleaning process will be treated, tested and discharged in a
mannel'.approved by U.S. EPA. Concrete floors and the foundation will
also be removed and taken to a U.S. EPA approved facility. Soil sa~~les
will be taken from below the south and northwest ends of the building
and analyzed to deternine if conta!!'ination exists. Soil action levels
will be used to determine if soil beneath the building would need to be
excavated and disposed off-site.
Off-site disposal of the building and equipment is selected because it
is the !!'ost cost-effective and because it is necessary to pr~tect
public health, welfare and the environment from risks created by
further exposure to continued presence of the sujstances.
c.
Surface Water
Based on the analyses of samples collected during the remedial
investigation indicating that surface water is not contaninated,
additional monitoring is not required. ReJT\oval of contar.1inated
soil, site grading and vegetat"ion will remove the poter)tial for
contar1ination of surface water... Therefore, no action is recom-
!!'ended for surface waters.
D.
Site Gradi n9
Final site grading will be perforfT1ed for the entire A & F
Materials Company site, as specified in the First Consent
Decree. This will include filling depressions to elifT1inate
ponding, covering with sufficient topsoil, and providing a
vegetative cover to prevent erosion. Areas outside the existing
fence';ne will not be covered with topsoil because soil sar.iples
taken off-site did not show significant levels of contaninants
of concern. The fencing will be removed.
After site vegetation, the site ~ill be maintafned for three years
to prevent erosion, after which time the Consenting Defendants may
petition U.S. EPA and the State to cease site !!'aintenance.
The cost associated with the rec~ended alternatives for the soill
sedi!'lents, building and equipment, and site grading are shown i.n
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9
VII.
Action levels
The reccnmended action levels for soils and sediments at the A & F
Materials site are shewn in Table 2. These action levels correspond
to the highest concentrations of contaminants presently remaining
. in soils outside of the fenceline of the site and were proposed in
the RIfFS by the Consenting Defendants as levels which would provide
adequate protection of hUMan health, welfare and the environment and
require no ~urther action. These levels have been reviewed by U.S. EPA,
and we agree with this conclusion. The levels for toluene and trichloro-
ethylene were adjusted downward. No trichloroethyle~e was found outside
of the lagoons above the required detection limits. The only toluene
: remaining is at the bottom of the lagoons. Adopting these action
: : levels means that no soil outside the existing fenceline needs to be
removed. Soil s withi n the fencel i ne above these 1 evel s wi 1 1 be removed
to a secure off site disposal facility. These levels represent the
highest levels of contaminants that will remain in the soil at the
facility.
,,0
As part of the remedial investigation, soil saf"1ples were collected out-
side of the area which could have been potentially impacted by releases
frCXT1 the facil ity. These results are generally shown as "background"
levels on Table 2. However, samples of the waste materials in the lagoons
and tanks have shown levels of chrCXT1ium, cadmium, zinc and iron to be
less then the Mbackground" levels originally derived in the feasibility
study. The "background" level s for these COfT1pounds have been rev; sed to
reflect that the levels in soils autside of the fenceline which are
higher than the levels found in the-waste are actually "background".
These levels are not significantly higher than the previous "background"
levels listed in the feasibility study. Also shown on Table 2 is a range
of elef"1enta1 concentrations in soils for certain metals c~piled by the
Centers for Disease Control (COC). The "background" levels for all of the
'metals except zinc fall within these ranges.
The level of 2700 ppm zinc is a probable anoMaly. This value c:curred
at a sample from a 1-2 foot depth at a sampling location 1700 feet
from the nearest lagoon. A surface sample collected at the sarle
location showed 65 ppm zinc. Samples taken at four adjacent sampling
locations averaged 188 ppm zinc, well within the range of normal
elemental concentrations of zinc. .
The action levels for trichloroethylene, benzene, PCBs, phenols, dicyclo-
pentadiene and PAH compounds are at, or below, the ~tandard detec:ion
limits' of the analytical methods used to quantify these compounds by
U.S. EPA, and are therefore appropriate for use as action levels at this
site.
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, ,
. .
VIII.
10
The only action level listed in Table 2 which appears to be above "back-
ground", the detection limit, or levels which would be expected ~o occur
at similar locations in the undisturbed environment, is for toluene.
Using an analytical approach develope-j by CDC, U.S. EPA and CDC have
. evaluated CnMpounds in Table 2 for their direct contact, inhalation and
direct ingestion health effects. This would include children, or
others who might play on, or otherwise COMe into contact with the site.
None of the compounds present a health threat at the action levels
s ho wn .
Toluene was also evaluated for its potential effects on ground wate:,
should toluene be released From the soil into the ground water. Using
conservative assumptions for the release rate and mixing within the
ground water regime, toluene will not cause ground water to be elevated
above those levels which ~ould be fully protective of human healt1,
welfare and the environment. Table 3 shows the concentration of toluene
in the soil, applicable groundwater quality criteria and the required
mixing to insure that the release of toluene to ground water does not
cause unacceptable levels. The required mixing factor is the action
level in soil divided by the applicable water quality criteria. Since
the required mixing factor is available at the site, and since there are
no human receptors using the ground water at this time, no adverse
impact of these compounds on ground water is expected due to releases
from the soils which will remain at the site.
However, soil removal to those act-ion levels shown in Table 2 will
be confirmed t.y ground water monitoring. As discussed previously, at a
minimum, ground water monitoring will be required to insure that ground
water conta~ination will not occur due to these soils. Further r~e~ial
action will be required if 50 indicated by further ground water monit~ring.
Details regarding the ground water remedy and applicable ground water
qual ity criteria will be presented in a separate document.
Consistency with the National Contingency Plan
The National Contingency Plan, 40 CFR Part 300.68(e)(2), states that
source control remedial actions may be appropriate, if a substantial
concentration of hazardous substances remain at or near the area whe:e
they were originally located, and inadequate barriers exist to retard
migration of substances into the environment. Based upon analysis of
the options, State and Federal environmental requir.e~nts, and the
comments received from the public and the State, the recom~ended option
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11
IX.
Consistency with Other EnvironMental Laws
.
The proposed action will not require on-site treatMent, storage, or
disposal of hazardouS wastes. Since all co~pounds will he reMoved to
background, or the detection liMit (except for toluene), the recomM~nded
action is fully consistent with RCRA. The level of toluene to re~ain
will be fully protective of hUMan health, welfare and the environMent,
and therefore is also consistent with Rr:RA. Although the Materials
to he r~oved are not hazardouS wastes as regulated by RCRA, th~y are
hazardous:substances under CERCLA. The transportation and off-site
disposal of wastes will be in ~ccordance with the appropriatp. and
relevant RCRA regulationS for the transportation and disposal of
hazardouS wastes. T:1is will include manifesting of wastes and
shipf'T1ent to a U.S. EPA approved facility.
(\
Of
Anyon-site water treatMent and discharge to surface watp.rs will be
in compliance with State of 111inois permit nu~ber 19R4-EA-1265 and
the substantive requir~ents of the Clean Water Act. Any necess~ry
storM water penr,its will be obtained.
The recOMMended alternatives will Minimize potential ha~ to the site,
in accordance with Executive Order 11988, "Floodplain ManageMent", and
Executive Order 11990, "Protection of Wetlands". Although no potential
impacts on the floodplain could be documented in the remedial investigation,
and no further soil excavation will occur in the floodplain, the following
measureS will be implemented to r"inimize potential nar1T1 or adverse effects
to the floodplain:
. .
. .
use miniMun grading requ~r€'fT1-nts;
1.
2.
return site to natural contours;
3.
Maintain vegetation;
4.
regulate methods used for grading and filling;
5.
require topsoil protection; and
6.
no structures wi1l hp' constructed in floodplain.
In accordance with the Toxic $uhstJnces Control Act, PCBs will be re~oved
fr~ the environment at the A & F Materials site to the lowest levels
practicably attainable. This will JT\ean removing~a" soils above 1 ppM and
disposing of it in a U.S. EPA approved facility.
"
-------
12
x.
Operation and Maintenance
The Consenting Defendants are required to submit an operation and ~ain-
tenance plan to be approved by U.S. EPA. U.S. EPA will require that
. the Consenting Defendants imple~e~,t the approved plan.
X1.
COmMunity Relations/Responsiveness Summary
111inois E?A (IEPA) conducted an extensive c~unity relations progra~
which included several informal meetings in the hones of near~y
residents. written updates, and frequent conversations with
interested citizens, press, and local officials. The State, with
U.S. EPA support, responded .to their concerns. Public J11eetings, one
of which was attended by staff from the Centers for Disease Control,
were also held by IEPA and U.S. EPA at several ti~es during the
RIfFS process.
. .
. .
When the First Consent D~cree was filed in June 1984. U.S. EPA assume:
the lead on ComMunity relations, although the State naintained an
active cooperative role. Several public comment periods have bee~
held, accompanied by public meetings, briefings. and other notifi-
cation of interested parties. A five-week public c~ment period was
available for the FS upon which this record is based.
There was some dissatisfaction am~g the public during the final months
of the "negotiations as some individuals apparently believed that they
were unable to obtain feedback or response to their questions. Howeve-,
they are pleased ~ith what has been accomplished and the promptness
of action once the First Consent Decree was signed. Information su~?lie:
by nearby residentS has been useful in discovering the full nature of
the contamination and is reflected in the recOMmendations for the si:e.
The responsiveness summary is attached.
XII.
Oeletion from the NPL
Implementation of the recommended alternative, in connec:ion wi:h
a ground water remedy (to be di scussed in a separate docu~ent).
-------
FICL'RE
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T ah 1 e 1
Cost of Remedial Alternatives
A & F Materials Site
. .
A lternat he
Cost
COlTIffients
1) Soils ancl Sediments
- Partial Removal
$
660.000
Includes excavation. transportJtion.
disposal and analytical costs.
- Complete Removal
$ 1 . 13 5 . 000
Includes excavation. transportation. and
disposal; also the construction efforts to
remove and solidify sediments.
'. .
2)
Ruilding and Eqll1pmp.nt
- Cleaning and Complete
Removal
$
120.000
Includes the costs of decontamination of the equipment
and building. collection and treatment of rinsate.
sampling and analysis. and disposal at a U.S. EPA
approved facility.
- Decontamination anCL
Complete Itemoval
$
120.000
Same as ~hove. except increased costs of decontami-
nation of the equipment and building. collection and
treatment of rinsate, and sampling and analysis;
decreased costs for eli sposal .
- Cleaning ancl Partial
Removal
$
9f) .000
Includes clec~ntamination. treatment of rinsate.
collection and analysis of samples of the concrete.
-------
.. .
TAB LE 2
-
SOIL AND SEOIHENT CONTNtlNANT LEVELS
Compounds
Background
son level
( ug/gm)
Recol1uJw.nded
Soil
Acti on Levels
(ug/gm)
Background
Sediment levels
(ug/gm)
Recommended
Sediment
Action levels
(ug/gm)
t-1eduim Elemental
Concentrations
i n $0 11
(ug/gm)
Hedium
Range
Benzene <1 1.0 <1 1.0
Toluene <1 12.0 <1 12.0
Trichloroethylene <1 1.0 <1 1.0
PCB <1 1 <1 1
Phenols <10 10 0.30 10
Oicyclopentadiene
-------
TABU 4
. .
COST OF RECm.'1f.1ENOrO AL TERNf\TlVES
A A F MATERIALS SITE
, .
Recomm~nded
A lterna t he
. Cost
CO:mm!nts
1) Soils and Sediments
- Partial Removal
$660,000
Includes excavation, transportation, disposal
and Bnalytical costs. The volume to be exca-
vated is estimated to be 6,000 y~3.
. I
2) Building and Equipment
-Cleaning and complete
removal
,
$120,000
Inclurles the costs 01 decontaminatfon of the.
equfpment and buil~in9, collection and treat-
m~nt of rfnsate, snmp11ng and analysis, anrl
df!posal at a U.S. EPA aspproved facility,
3) S He grad f ng
$44,000
Includes costs for fillfng depressions to
elfminate ponding, covering with topsofl,
and providfng a vegetatfve cover to prevent
erosion. This will he done for the entire
~ & F Materfals site.
. .
-------
Section 1
PURPOSE OF THIS RESPONSIVENESS SUMMARY
This document has two purposes. The first ;s to report ver~al and written
C:()r.'1ne~ts on the various remedial actions suggested for the MF r~:erials
hizardous waste site. The second is to docume~t U.S.EPA's responses to t~ese
COC1nents. The remedial action options, inclllding a reconfiended altern~:;ve.
were outlined in a draft Feasibility Study (FS) which waS completed in
October 1984. . A revised FS was submitted on January 18, 1985.
,
,
. ,.
. .
. .
-------
Section 2
FEASIBILITY STUDY OVERVIEW
SITE BACKG?OUND AND HISTORY
In 1977, the A&F Materials company began recycling industrial waste
materials--oil"S. sludge. caustic and sulfuric acids-- into fuel oil
and fire retardant chemcals.
The l11inois Environmental Protection Agency (1EPA) received cOlT1plaints
'.&bout the recycling facility soon after it start~ operations. IEPA
. i'nvestigated and found the ccrnpany violating numerous permit regula~ion:=..
The facility ~s shut down and abandoned in 1980. ~aste materials we~e
left in storage tanks, lagoons. and in the processing equi~ment.
As part of Comprehensive Environmental Response. Cor.pensation. anc
Liability Act (CERClA). the ~aste generators who had storer
their materials at the A&F site were required to clean up the site
themselves and/or reimburse the state and federal governmp~ts fo~ any
governnent cleanup actions.
.
Several containme~t actions were taken by tEPA and U.S.EPA to preven:
Migration of contaminants into the Embarras River. A consent orde~
was finalized after a public c~ent'perioq in June 198A. In it four
cC;r.1panies--Aluminum Ccn;::any of America -(ALCOA). Northern Petroche:.~cal,
C.6J1-OR 1nc.. and Petrolite Corporation -- agreed as part of a partial
consent decree ~th U.S.EPA and IEPA to do a complete surface cleanup.
These four companies (Consenting Defendants) are not the only res~on-
sible waste generators; they are the firms that have consented to
undertake the cleanup. The cleanup. which the four cOIT1panies paid for
themselyes. is scheduled to be finished in August 1985.
-
CLEANUP ACTIVITIES
All sludge and visibly contaMinated $oils frc~ the lagoons have been
taken offsite for di sposal. All liquid material frOM the tanks has
been either treated onsite or disposed of offsite. The tanks wer2
cleaned and removed from the site. Contaminated soil areas outside
of the la_goons ~ere also excava~ed and disposed of offsite. The FS
~as needed to d2termine the best course of corrective action for the
remaining contaninated 50;ls.
-------
FS SUMMARY
:
The FS prepared by the Consenting Defendants reco~nenMed continued non i-
toring of grounctwater. No other actions for groun~water were dee~e4
necessary because no groundwater wells are affected by the site and,
th~refore, no health risks can be currently attributed to groundwater.
Furthermore. the high costs for operation an~ maintenance of grouncwa~er
treatment systems do not appear to be justified.
The Rer'ledial Iflvestigation (RI) determined that the aquifer under-ne~:'
the site is flushed naturally every 10 to 15 years. The RI precicted
that conta~inant levels would remain near their present values for a
two to four year period and would then decline. A program of ground-
w~'ter monitoring \-4ould verify or dispute these predictions.
. ,
.
. The FS prepared by the Consenting Defendants recommended "Alternative
AN, the partial soil removal option, for dealing with remaining s011
contamination. According to Alternative A, soils in the four nost
contaninated areas would be removed and transported to a U.S.EPA
approved facility. Soils found to contain greater than 1 part per-
million (ppm) of PCBs would also be 'removed and disposed of offsite.
The remaining soils and sediments contain
aromatic hydrocarbons (PNAs). Levels are
found naturally in the environment and do
or public health risks.
low levels of polynucle~r
comparable to concentrations
not present environnental
The FS also set various guidelines called action levels that w~1l
guide soil removal activities. Soil that has concentrations at o~
higher than these action levels ~il1 be disposed of offsi~e at a
U.S. EPA approved facility.
The sediment data in the RI showed concentrations well below the
suggested action levels. Therefore, sediment ~i1l not be renoved.
All buildings and equipment onsite ~ill be r~oved and disposed of
offsite. The concrete foundation will also be removed and soil under-
neath will be sampled to determine if any contaMination exists there.
PUBLIC COMMENTS/U.S.EPA RESPONSES
The draft A~r Feasibility Study ~as issued in October 1984. A public
meeting ~asheld on Decer.1ber 4,1984, in the TO'iin of Greenup, Illinois.
A three \;tfeK c~nt period fo"o~e
-------
The verbal and written c~ents can be divided into the following
categor,ies:
..
o
Soil and sediment
Q
Buildings and equipnent
o
Groundwater
C~ents that required a response by U.S.EPA are su~arized in this se~tion.
Public comnents are edited and sometimes paraphrased so s;mil~r c~ne~~s
can be cOMb; ned. The intent has been to present the full range of topi cs
\ltithout lengthy repetition. Groundwater issues will be addressed in a
separate docUMent.
. "
\ "
SOIL AND SEDIMENT
CQfTT\ent:
~The RI/FS missed ~;despread areas of soil conta~ination because of errors
in the soil sampling progra~. A 1980 renedial action covered up cO'i:ani-
nated soil offsite with clean soil from a nearby hillside. The RIfFS
sampling program failed to sample and analyze this ,ontaninated soi' be'ow
the hillside."
U.S. EPA Response:
Originally, three areas of highly contaminated soils were found onsi:e.
They are cal led "highly contar1inated" because they contained contanina'its
at levels that were significantly above levels normally found in the
environment. These highly contaminated areaS were in the two tanK farns
and around the western edge of the processing section of the builcing.
Additionally, a small area of soil conta~inated ':lith 1 ppm of P':Ss west
of lagoon 1 ~as identifi~d. 50il5 in all of these areas have been or will
be removed from the site and disposed of offsite at a U.SoEPA approved
facility.
There were several areas of lightly contaminated soils found generally
~st of the ~ste lagoons. The tem -l ightl y contaM; n9ted" refers to
soil that contains low levels or traces of contaninants that have no
h;i!alth or"environmental concernS ~ssociated ..:/ith thrn. In other \oIords.
lightly contaminated areas have concentrations of chemicals that Might
naturally occur in the environ~nt.
-------
~
In 1980. 1 foot of soil was removed from the west part of the site and
covered with clean soil. Sar1ples for the RI/FS were taken in that area,
including samples at depths of one to two feet, that \;dould pick up any
conta",ination under the clean soil. The Consenting Defendants and the
Illinois Attorney General's office also resa~pled the soil in Dece~Der
1984 to depths of 4 feet. Hazardous substances were not found in the new
samples; howewer, aliphatic hydrocarbons were found at low levels. The
Centers for Disease Control has reviewed these results and found no heal~~
probleM. The 'Consenting Defendants will be required to resample this
area at various depths. up to 4 feet. If this area is contaninatej
~th hazardous substances, the soil will be removed.
, ,
. U.S. EPA, therefore. believes that samples were take~ deep enough to find any
existing contamination. U.S. EPA believes that the RI/FS sanpling progra0. was
sufficient.
u.s. EPA believes there are no data to support that remaining soils present a
threat to public health or the environ~nt.
C:>rrrnent:
Leaving soils may present odor problems. particularly in the sunner months
and during wet weather.
U.S.EPA Response:
Buried contaminated soil should not be an odor problen. There appears,
however, to be an indication that decomposition of organic materials that
produce methane and other odor-causing compounds, comnon in Mars~y areas,
coul d present an occas i on al odor prob 1 S"1. In any event. accord i n9 to
the recommended alternative, the site ~il1 be graded. depressiv~s will
be filled to prevent ponding, and topsoil will be added. This ~ay or
may not affect possible odors from the site. The odor problem whicn
was present at the site in the past ~;11 have been el;~;nated by t1e
removal of the lagoons. tanks and highly contaminated soil frcxn the
surface of the site.
Ccmment:
Is the soil underneath the building foundation contaminated?
u.S. EPA Response:
-------
When the foundation is removed. the soil will
contaminated. it will be removed and disposed
action levels stated in the FS will determine
levels in soils t:li11 justify their removal.
be saT'1j)led. If the soil is
of offsite. The vari'ous
whether the contamination
Cor-rnent:
.
U.S. EPA sho~ld make sure the topsoil between the site and the r;ve~ is r~,cye~
because groundwater flows through thi~ area and could then becoT'1e co~:a~i-
t'ated.
. .
. !
. .
U.S. EPA Response:
The soil in the field does not contain levels of contaminan~s tha: would
present any threats to public health or the environment. Therefore. re~ov;ng
the soil in the field between the site and the rive~ is not necess~~j.
Cor.ment:
One letter said that Hblack yuck" was du~~ej on th~ field be~wee~ t~e
river and the site and that no crops grew there until clean dir: was put
there.
U.S. EPA Response:
-
The soil in this area was removed and placed west of the fenceline in
1980. .The area has been sampled to de?ths of 4 feet. No c~ntaT'1in3tion
t:las found. Toluene at 0.8 parts per million (ppm) ~as found I but SJch
levels do not pose health or environmental threats. (U.S.EPA water quality
criteria state that 3S ppm ;s the level that would present env;ronnen:al
threats. In addition, level S of toxic chemei als in soil ean be orders c.
magnitude higher than the levels in groundwater before they become health
threats.) .
Ccmen t :. .
Sediment in the drainage ditch should be removed.
-------
U.S. EPA Response:
The suggested action levels do not pose a threat to biota. Therefore,
sediment removal and disposal is not re~omme~ded at this time.
8UILDINGS AND EQUIPMENT
C 0!T'/ff1'2 n't :
B,uildings should be completely ref1'1oved because the"re is always the
. ijsk that sampling might have missed some contanination.
.. ."
U.S. EPA Response:
The building and its foundation and all equip~e~t will be remove~ an:
disposed of offsite. Soil under the building foundation will be sa~~le:
and if there ;s any contaminated soil or other materials found tney wi: 1
be removed.
MISCELLANEOUS
Many letters and verbal cor.ments expresse"J concer:. anc a des~re f:;r a :::':.a1
cleanup. Many letters said the site s~ould be returnee to the sa~e c:rc~-
tion it was bedore A&F Materials began operationS.
U.S. EPA wholeheartedly agrees that the site should be left in a con:~':.io:, i~
which it presents no danger to the public and the environment. The Agency
believes that the recor7'!71ended alternative accQ(T1plishes this goal.
-------
.
;
. .
, \
A.TTA.CH'1F:NT 2
-------
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LABORATORIES, INC.
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A~ALYTICAL REPORT
LAGOO~ 11 and 14
Engineering Scipnce
Atlanta, Geo"g~a
Presented to:
Su£an Minicucci
Vice
ALERT, INC.
ll~~aJ N~
Marvin ~. Step~ens, Ph.D. ~
President & Technical Director
-------
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" "
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WADSWORTH/ALERT
LABORATORIES, INC.
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This
inc1 udes
the analytical results for
s:,i~
report
sub~itted by Engineeri~g Science.
The incividwal report
detail the a~alytica: p2,ame~er5 an: res~lts f~r each sc~~l~.
re::;\;es~ed
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sa~rle~ neares: :~e
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de~e:te~ i~ one of the sa~~les an: none i~
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WADSWORTH.'ALERT
LABORATORiES. INC.
ALERT. 1 S':.
P:B C~~~?J~'~~~S A~,;~Y::CAl..
R:::?')~.:
..
CC/?',pany: Engineering Scie:1:e
.~ap,?le Identification: LaS:c~ #~ Top
Laboratorv Identifica~ion: 9110:
. . -
Sa~?le Matrix: Soil
Da:e rec'~: 9'10!55
Date extra::e~: 9':0:~S
Date analyze~: ;;12!ES
PCB-I016 t\J PC:E-:2~S ~.-
J,_I
PCB-l:::21 t\D P"'- i" - , ~:
~,:)-.";;)-
PCB-1232 t\) PCB-126Ci ?\::
PCB-12':'2 ~:)
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(~one de:e:te~, lo~er dete:ta~le li~it z 1
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WADSWORTH/ALERT
LABORATORIES. INC.
--
,
AU:;T, 1\:.
POLY~lCLEAR A?C~ATIC HYD~8CARSO~S RE?O~~ S~EE7
.)
Co~ra~y: En~~neeri~5 Science
S2~Fle Identificatio~: Lagoo~ #~ Top
~boratory Identification: 91102
" ','
D2:e re:' c: ~"l= '::
Da tee x t :- a :: tee: 9 " l S .. :. :,
Date analyzej: 9/1:/::
A::e:i2?:::::e:-.e ~.... C~i:-ysene \.....
j -' .,.J
Ace:-.a?~.thylene ~.... Dibe~zo(a,h)an:~race~e ,.-
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~,!1t~race~e t-;) 3,3'-D::h:o"o~e~z:::~e ~:.,.
Be~zo(a)anthracene 1\J Fluora:1:hene ~:J
Be:-.zo( b) fl u,:,rar.thene ~J -. ,.....
: - '...::::-e:"'.e "-
BQ~~-(k)&'uor---~p-e ~: I~:~~:(lt2,3-c:)~y:~~e ~::
- .......... .. .. Co:..... .I - l~
Be~zc(ghi)peryle~e t~J 1\a;:.:-.thalene ,.-
.'..
Be!izo(a)pyrene KD Phenar.:hrene \'-,
2-Chloronaptthalene 1\D Pyrene ~;:,
~
SD (~one detected, lower detectable limit ~ 1 u~!£)
ND* (None detected, lower detectable li~it ~ 5 u~/~)
-------
\ .
,
~ ~ j
WAD SWORT HI' AL E RT
LABORATORIES. INc.
---
A:"Ei\7. I~C.
ACID CO~?O~'~~5 A\.~.:..::'T~':.~.:" R::FO?:-
.
C~~any: Er.£in~e:in£ Science
t6~~rle Ider.:ific2tion: L2~~on #~ Do~n l'
Laboratory Identification: 91103
Sa~p1e Hat:~x: Soil
A~AL:SlS ~O: R~Q~:~::)
.~
..
Date rec'~: 9/10'~5
Date extT2c.te::
-------
WADSWORTH! ALERi
LABORATORIES. INC.
S."'~"~Q "5"~~
CO"I,,,,n,nG moO,l. ist>S
ORGASIC ANALYT1CAL REPORT
i!
0-
.~ f.
~;;;':'r.:::
::I:;!::""
ZO:. ~ -
-"Z-r
::. ["? ~
:!! 3' !:
~~~
~~=.
.- ~
:;: :-~
- "-
C-
C""' ,...
»-'
f;
--
Q
L,ABOAATOCilY
212' Feu".' St'H: S E
C'''\10. OM 44701
(216) 4~,1703
-
t;',
.-'
,?,
...---
";:.: ': .
c:-:- ~-: ,
r":':"
~:'
~
C::::;..:
~:::.,
:.::-::
'p,
'C -'
~
H£A?O'..:~~'rERS A""
L.A8""AT 0::< ,
1600 F"""'" 5,,"\ S E
p 0 ac. ~
w"\to' Q;"I44"01
(216, .~ ~:>;
..--
..--'
~
ALCOA, GREE~P, ILL. PROJECT
SOWT HE A5TE Rio,
REGIO"'Af.. C)"F'ICE
744 5~,,\\IQ' ~~lo.a'O
W~s'~~mo.s SC 29169
(OO3~7Dof.62!;1
REGIONAL
L,ABQRATORY
F\e~' 3 - 80. 23!;
B. "0" F'L 3383J
(8',3, ~3.2'!;:
(Sn,po."\; 80d'u~)
Ave"'lwf' :: ~o"'!"1
88"10" ~u"\':IPB Airport
BD"O" F.. 3363:
PRESt:i'ITED TO:
21..HOlJr ALE..T I,ne
(216) 4>4.83~
In OhiO Cal!
000.5404.5585
En£ineering Science
Susan M.i n i cucc i
A1..ERT. INC.
7J7~~;:U~~
f"!..ar'll:1 Y. Stephens, Ph.D.
Pl'esident & Technical Director
Vice
September 12. lSS5
-------
Iw~
WADSWORTH,' ALERT
LABORATORIES. INC,
..\:"::1'7, I;';C.
1 :;TKo;:r~C7IO\
,
,
This
includes t~e analytical res~lts for t.Q 5::1 s2~~le~
report
. .
. ':
Gree:-:'.;; ,
111.
sub~itted by Engineerin~ Scie~ce fro~ t~e
Alc03,
. .
ba se /;-0 e ''; :. ral
site.
The
sa~ples
aroal YZ':?G
for
p!ienols,
were
extractables
(include::
F~;.; , .: ) ,
polyc~:orinate:::
b: :;~.e~~yls
8:1:
(PC3's).
,.~-.... .
l.. :::-r..r."\
Methods 625 a~c 60:.
respectively, .ere use: i~
the
8:-,alyses.
The
sa~~:es .ere include:
in t~e
co;,,?re':,e:-os: \'e
laboratory QA/QC pro~;?~
1, 1",..' ,...: &>..:
..-.10.1....- ....
.:t~ this repcrt.
Bo:h
sa;r.?les
5:-:0....e:::
10'..'
level
CO:lce:-:::-a':io~s
c:
-~Q--'-
I- ..- ,. ~-::>.
-------
. .
, .
~i~
W ADS\VORTH' ALE RT
LABORATORIES. INC.
~
A:"Er:7, I~C.
ACIJ
CO>~?Ot.~~~:;3 A\.;:- Y1: CP.:'"
R:.?~~j
.'
u
Co~?a~y: E~ginee:ing Scie~ce
S~ffip1e Ide~tification: Tank Far~
~ La~oratory Identification: 91016
Sa~ple ~atrix: 50i1
Date rec'~: 9!6.'~5
Date extra-::tec: 9';;':5
Date anal:ze~: 9!S!~5
4-Ch!cro-3-~et~ylphe~~1
2-Chl or vp !-ie:;o 1
};:-.
L.-~i t::='?:-ie~:.l
~~:!-::.
K:;
Pe~ta:tlo~Q;he~.::
~~:.~.
2,~-Dimethylphenol
KD
~:)
P:-1 e :1: 1
C.SO J
2,4-Dich!c:~;~e:;~l
2.k.6-Tri:~loro~~=~:~
"-,
., _/
2-~e':.hyl-L.6-dinitrophencl
}; :: .;.
};:y'
:.~-D:~:t~up~e~~l
2-~~i trop~enol
"'""\
1\"';
};ote:
~D (Sone detecte:, lo~er de:ec:a:le li~:t = 1 u~!~)
};~ * (Svne detected, lower de:ect3~le Jirnit = 5 ug!g~
J (";'-r;"'-~e..1 V-1, e
. _:...._111::'1- \..I c...J,
belo..'
dete::~c:2e
li~: ':.)
-------
WADSWORTH/ALERT
LABORATORIES. INC.
AL~?T. ISC.
B~SE/~E~T~AL CO~~O~~~S A\ALYTICA~ R~PO~T
Co~?any: E~ginee~ing Science
Sa~ple Iden~lflca:lcn: Tank f3~~
La'~ratory Iden:if:cation: ~:O~6
Sam?le Matrix:~Soil
Ace:\3?hther.e
Acenaphthylene
"
I. A'O t hr acene
. .
Benzidine
Benzo(a)an:hracene
Benzc(b)fl~ora~:hene
Benzo(k)fluoranthene
Benzo(g~i)pe~ylene
Benzo(a)pyre::e
Bis(2-chloroethoxy)methane
Bis(2-chlcroe:hyl)ether
BiS(2-ch:~roisCrr~py:)ether
Bis(2-ethylhexyl)ph:hala:e
k-Ero~cphe~:l phenyl ether
Butyl benzyl phthalate
2-Chlcronaphthalene
-
~-Chlcrophenyl ptenyl ether
Chryse!'H~
Dibenzo(a,h)anthracene
Di-n-bu:yl phthalate
112-Dichlorobenzene
113-Dichlorobenzene
1,4-Dich~o'robenzene
3,3'-Dichlorobenzidine
Date rec'~: S!6!~S
Da tee x:' r c:: c t e:: <;. ~ . ~:
Da tea n a 1 y z e: : <;.' 9:' S:.
r\:J
Die~r,\'l
ph~hala:e
K:J
Di~ethyl phtha:a:e
K~
2,4-Dinitrotoluene
KD'~
2.6-Dinitrotcluene
KD
Dl-n-octyl p~:ha:a:e
K:J
K)
KJ
F:uo~an:~ier.e
Flu?rer.e
Hexachlorobe~z~~~
KD
Hexachlorob~:ac:e~e
t\D
KD
Hexachlorocyclope~ta::e~e
Hexachloroe:~o~e
};)
In~e~o(1,2,3-c:)~Y~E~e
\.-
n;)
Isop!iorone
~aphtha:e!'Le
~D
KJ
~itrober.=ene
};D
N-Kitrosodi~~thyla~:~e
?\D
t-:D
~-~it~osod~?~e~y:a~~~e
KD
N-Sitros0~:-n-propyla~:ne
Phena~thre!'Le
ND
ND
!\D
ND
ND'--
Pyre!".e
1,2,4,Trichlorobe~ze"e
ND (~one detected, lo~er detectable limit =-1 ug!g)
N.D-~. (~one detected, lo~er detectable lirr.it II: 5 ug/g)
,'-"
;, -'
'"
,.-
.'-
~:
,....,
.' ~,
,....,
.''''
'--j
.'w
,....,
.'w
~:
,.-,
" -'
-
S)
'--I
.'-
,.-
.'...1
,._,
"..,
:c'
t\)
~;J
s:
\"~
1,,-,
'''''1
j\ -
,'....
.".1
};D
-------
j ~ ]
-
WADSWORTH:'ALERT
LABORATORIES. INC.
:
ALEi\T. 1\:.
peE CO~FO~~JS A\A~YTICA~ RE?J~:
.II
;;
....
Cc~?a~y: En~:neerir.g Science
~ gz~?le Identificati~n: Tank F2r~
Labo~o~ory Ide~:jficaticn: 91016
Sa~ple Matrix Soil
Dc.:.e rec;d: 9:61:5
Da:e extract"':: 9 '8 '~:'
Date a;-,alyz::: 9:'9,'E:
PC3-1J16 };:; PCB-12':':: };:-.
PCB-:221 t\J PC3-12S':' ,',...
.'-
PC3-1232 ?\"" PCB-12~J ~:.
""
PCE-12':'2 \'"'
. ..,
};o:e:
~J
(Sone detectec, lo~er de:ec:a:le li~:t =
1 ~~/~;
-------
--'
}; :.~.
1:. I.:~ I~
" ..,
l' -'
-------
~ I ~
---
J
WADSWORTH' ALERT
LABOP,ATORIES, INC.
A:"'ERi. l\C.
PCE co~:?,j:.:~~:'3. A\A:" Y71C,;L
C~~~~~)" En~"n~~rl'n~ ~~l'e~~e
j"'1"r""'. ~.. ~ -. !> -... ,J-
: S,a::.;:le Identification: Lagoon 411
La~oratory Identification: 910~i
Sa~;:le Matrix Soil
PCB-I016 t\D
PCc-122I ti~
PCS-1232 t\D
PCE-12':'2 ~-
~J
-,T--"'--
1\ .:. ;"..H. .
Date re:'d: 9/6 '~:
tote ex:ra:te:: 9'5 ~:
Date ana::'yze:: 9/9:::.
PCS-12L.S
\'~
1\_/
PCB-125~
~::,
PC3-:26:;
~;)
r\:J:e:
~D
(,.~r." de~e-te-1 1,",""- det-ert"""e 1...."t -
j'~'- I. '- '..., 'wi"'...... ... '- r;;...,. ..I.~II... -
-------
j ~ ~
..-
WADSWORTH/ALERT
LABORATORIES. INC.
A:...::?J. I\C.
BASE/~ElTRAL CO~?:lSDS ASALYT:CAL R::?OR:
Company: Enginee;ir.~ Science
Sa~ple Identification: Lagocr. #1
L!,oratory Identification: 9101i
Sa~ple M~trix: Soil
¥
Acenapr.:hene
ACe!1c3rhthylene
Al"It~racel"le
..
~ JDenzidine
Ber.zo(a)al"lthracer.e
Benzo(b)fluoral"lthene
Bel"lzo(k)fluoral"lthene
Benzo(ghi)peryle!1e
cenzo(a)pyrene
Bis(2-chloroethoxy)me:ha~e
Bis(2-chloroethyl)ether
Bis(2-chlo:oisopropyl)et~e:
Eis(2-ethylhexyl)p~t~a!a:e
'-Erornopher.yl phenyl ether
B~tyl benzyl phthalate
2-Chloronaphthalene
4-Chlorophenyl phenyl ether
Chryser.e
Dibenzo(a,h)anthracene
Di-n-butyl phthalate
l,2-Dichlorobenzene
l,3-Dichlorobenzene
l,4-Dichlorobenzene
3,3'-Dichlorobenzidine
:
Dc: t ere c ' d : 9;' 6 " ~ :
Date extracted: 9 5 '~)
De'.€' a:-:e::;:e:: C;,~,'~.:
~D
Dierhyl phthalate
~D
Di~ethyl pht~a!e:E
~D
rm"
?\!)
t.::J
?\J
2,4-Dinitroto:ue~e
2,6-Dinitro:oluer.e
Di-n-octyl phthalate
Fluoranthel"le
Fl uorer,e
\.:n
:,L
Hexachlorobe:-:zene
\.'~
I' -
Hexac~lcrc:~:2::e~e
~~
Hex2chlo,o:yclcpe~:e::~~~
Hexac~loroe:~ane
, t\D
\0""
i''';
1"''''''''0(1 ., '":) -':\-"-"-0
..__1~ ...;..,.J---Ir:. _..'-
~0
Isop:-.o,:>ne
\'T"\
" .J
~a~:-.::-.a:er.e
~D
ND
KD
?-;D
~itrobe:;ze;;e
N-~itrosodi~e:~yla~:~e
N-~:troso~iphe~Y:2~:~e
N-Si:roso~i-;;-~:o~y:e~:~e
ND
ND
Phenan:hre7",e
P:::e~e
ND
ND
!\!)
l'm'~-
l,2,',Trichlorobe:.zene
ND (None detected, lo.er detectable limit = 1 ug/g)
ND.;~ (~one detected, lo.er detectable limit>; 5 ug/g)
"~
,'-
,"
.OJ
N)
:\J
~)
~D
\"-
.,_1
~:'
~:
!\~,
t\~
~J
~;J
\'",
.'-
Ie'
!\J
\'T"\
" oJ
\' ""\
.'....
SJ
1\:1
,'T"\
.' oJ
-------
...
IT
. .
~TTACH'1E'n 3
Respo~s i veness 5IJrnna ry
., e,
"
-------
Section 1
PURPOSE Of THIS RESPONSIVENESS SUt.H~ARY
This docunent has two purposes. The first is to report verbal and written
COMnents on the various remedial actions suggested for the A & F Materials
hazardous waste site. The secono is to docunent U.S. EPAts responses to thes~
(()(TInents. The ref'ledial action options. including a reconnende<1 alternative.
were outlinerl in a draft Feasibility Study (FS) which was (onpleted in
October 1984.: A revised FS was subnitted on January 18. lY85.
, '.
" -
-------
Section 2
FEASIBILITY STUDY OVERVIE~
SITE BACKGROUND AND HISTORY
In 1977, the A & F t1aterials cOf'lpany began recycling industrial waste
~aterials--oils. sludge, caustic and sulfuric acids-- into fuel oil
and fire retar.dant chemcals.
-
,
The Illinois Environ~ental Protection Agency (IEPA) received con~laints
about the recycling facility soon after it started o~erations. IEPh
investigated and found the company violating numerous ~ennit regulations.
. The facility was shut down and abandoned in 198U. ~aste materials were
. .1eft in storage tanks. lagoons, and in the processing equipment.
. .
As part of Comprehensive Environmental Response. Conpensation, and
Liability Act (CERCLA), the waste generators who had stored their
materials at the A & F site were required to clean u~ the site thenselves
and/or reimburse the state and federal yovernnents for any gover~lent
cleanu~ actions.
Several containment actions were taken by IEPA and U.S. EPA to prevent
migration of conta~inants into the Embarras River. A consent order was
finalized after a public comment period in June 1984. In it four
companies--Alum;nun C~pany of A~er;ca (ALCOA), Northern Petrochenical,
CM~-OR Inc., ann Petrolite Corporation -- agreed as ~art of a partial
consent decree with U.S. EPA and IEPA to do a conplete surface cleanup.
These four conpanies (Consenting Defendants) are not the only respon-
sible waste genprators; they are the firms that have consented to
undertake the cleanup. The cleanup, 'rlhich the four ccnpanies paid for
themselves, was completed in September 1985.
CLEANUP ACTIVITIES
All sludge and visibly contaminated soils from the lagoons have been
taken offsite for disposal. All liquid material frcm the tanks has
been either treated onsite or disposed of offsite. The tanks were
cleaned and renoved fron the site. Contaminated soil areas outside
of the lagoons ~ere also excavated and disposed of offsite. The FS
was needed to dete~ine the best course of corrective action for the
remaining contaminated soils.
~
-------
FS SlHlIlAPY
The FS prepared by the Consenting Defendants recom~endeO continued ~ani-
toring of groundwater. No other actions for groundwater were deer-led"
necessary because no groundwater wells are affected by the site and,
therefore, no health risks can be currently attributed to ground water.
Furthermore, the high costs for operation and maintenance of ground water
treat~ent systems do not a~pear to be justified.
The Remedial Investigation (RI) determined that the aquifer underneattl
the site is fly'shed naturally every lU to 15 years. The RI ~redicted
that contaminant levels would remain near their present values for a
two to four year periOd and would then l1ecline. A proyrarl of ~round
water Monitoring would verify or dispute these predictions.
T~e FS prepared by the Consenting Defendants reconnended "Alternative
"'All. the partial soil rerlOval olJtion, for dealing with refT'aininSJ soil
contar1ination. In accordance with Alternative A, soils in tile four !"1ost
contaminated areas were removed and transported to a U.S. EPA a~~roved
facility. 50ils found to contain greater than 1 part lJer million
(ppl"1) of PCBs were also renoved anrl disposed of offsite.
The FS also set various guidelines called action levels that ~uidcd
soil renoval activities. Soil that harl concentrations at or hiQher
than thesp action levels were disposed of offsite at a U.S. EPA
approved facility. The soils and sedinents that remain onsite contain
very low levels of polynuclear arOfldtic hydrocarbons (PN,A,s). These levels
are below the action levels, and do not present environrllental or ~ublic
health ri sks.
The sediment data in the RI showed concentrations well below the suSgested
action levels. Therefore, sedinent ~as not renoved.
All huildings and equipment onsite were renovpd and dis~osed of
offsite. The concrete foundation were also renoyed and soil under-
neath was san~led to verify that no conta~ination exists there.
--
PUBLIC CQlmENTS/U.S. EPA RESPONSES
The draft A & F Feasibility Study was issued in October 1984. A ~uhlic
meeting was held on Decenber 4.1984, in the Town of Greenup, Illinois.
A three week comnent period followed. It was extended an additional
two weeks to enable the public to More closely study the document. A
final FS was submitted to U.S. EPA on January let 1985.
-------
The verbal and written cnnnents can be divided into the followin~
categories:
o
Soil and sedinent
o
Building and equipnent
o
Ground water
COnr"ents that required a response by U.S. EPA are sunnarized in this section.
Public c~nents are edited and so~et;mes para~hrased 50 similar C01nents
can be c~biped. The intent has been to ~resent the full ranye of to~;cs
without lengthy repetition. Issues related to soil and sedinent. and
building and equip~ent have been addressed in a se~arate document. This
responsiveness sun~ary wi" address only ground water issues.
I
I
. .
. , GROUNO\JATER
. .
COO1nent:
If the ground water is going to be monitored. soils shoula also be renovec.
u.S. EPA Response:
Soils containing a~ounts of contaninants greater than the action levels
have already been renove0..
Comr1ent:
The feasi~ility study's claim that dilution reduces yround water conta~ina-
iion to near background levels is unsup~orted.
U.s. EPA Response:
Additional support that dilution does cause ground water contanination to
be reduced to near back~round levels was documented in the revised FS.
While additional monitoring would be conducted und2r the requirenents of
the Partial Consent Decree, the existing levels of conta~inants do not
pose a threat to hunan health, ~elfare or the environment.
Comment:
Contamination in ~ells H-SO and 11-60 are probably the result of soil
contamination north and west of the site.
-
u.s. EPA Response:
Lagoons were excavated to the depths of the aquifer in ~hich the wells
received water. Leaching frOM lagoons while the site was in operation is
-------
a More 1 i kely source of contani nat ion because areas west and norUI of the
site are not believed to be conta!"1inated.
..
Con!"1ent:
If. after the soil ;s r~oved, ground water monitorin~ shows that contani-
nation is not declining, what will U.S. EPA do?
U.5. EPA Response:
The action levels that will be used for ~round w?ter are different
than those used for soils. A plan will be prepared to see what shoulc be
done in the event that groundwater contanination levels increase above
,'the groundwater action levels, although this is not expected to happen.
. "
" "
Connent:
A lO-year ground water nonitoriny ~royraM is insufficient.
ll. 5. EPA Res ponse:
u.s. EPA agrees that 10 years is not long enougll to monitor yrounJ water.
The actual length of ground water monitorinQ will be detHI:1inea hy the
Groundwater monitoring plan which will be pre~ared by the res~nnsible
parties and subMitted to U.S. EPA and the State for atJprovdl. However,
30-year and beyond Monitoring ~royrans are not unconmon.
C DrlMe n t :
During a floOd, could contaMinants back up into city wells?
are located across the Embarras River.)
( City we 11 s
U.S. EPA Response:
Soil contanination that presents any puhlic or environnental threat has
been reMoved. Therefore. flooding should present no danyer to ~ublic
wells, but additional f11onitoring wells may be needed to monitor for any
possible water gradient reversal and resulting contamination transport
that may occur as a result of the flooding.
~1l SCELLANEOUS
Many 1 e"tters and verbal comments expressed concern and a desi re for a
total cleanup. Many letters said the site should be returned to the
same condition it was before A & F Materials began operations.
U.S. EPA wholeheartedly agrees that the site should be left in a condition
-------
which it presents no danyer to the public and the environr.ent. The A~ency
believes that the rec~r€nded alternative acconplishes this goal.
. I'
I
. '
. .
(,
y
-------
!~ ~ ~
WADSWORTH/ALERT
LABORATORIES, INC.
-:.
ALE::\7. J;--;:.
ACI D CO~:?~),:\:~ A\A:.:ni C.:"!.. R~F~r::
Company: En~ine~rins Science
.S~~?le Identification: Lagoon ~l
~a~oratory Identification: 91100
Sa~p1e ~latrix: 50i1
'-C~loro-3-~e:hylp~e~c~
2-Cr,l or ophe :-.c.}
2,4-Dichlorophenol
2,4-Dimethylphenol
2,~-D~nitro~~e~ol
2-Mettyl-4,6-dinitro~~e~cl
2-~i"t,o?hen':)1
Do""n l'
Date re:'~: 9.'lJ!E5
Da:e ex:racte,:: 9,!E./~5
Date ana:yzeC:: 9,'12,'~5
,,'n
I\~
4-~::' t,o~.C.,enol
Pe~:ac~~orc~~e~~:
~:::.>
,,0'"
~, ....
~:'"
KD
t\J
Phe~cl
3.3
2,4,6-irichloro?Ge~c:
K:J
?\:> ~.
Be:::c:: A::.c.
-. -
K"'"
KJ
Note:
t\D (~one detected. lo~er cetecta~:e li~::'t = 1 ug/g)
-------
.'
~ ~ ]
~ ~~ ~~~
WADSWORTH :ALERT
LABORATORIES. INC.
A~:::\T. r,c.
ACID CO~?Q~\DS A~A~YTICA~ R::?C?7
Co~pan:: Enginee;ing Science
6a~rle Identification: Lagoon #1
~a'oratory Identification: 91101
Sa~ple Mat,ix: Soil
"
DO'.T. 2'
A\.';:...YS!5
~OT R::Q:~'IR::;)
Da:e re:'~: ~!lS'~S
Date eX::-c:te::
-------
:1 ~~
WADS\'VORTH': ALE RT
LABORATORIES, INC.
-- -
.
ALE:; -;, 1\(.
ACID CO~?aC~DS A~A~Y7ICAL RE?OR7
.'
..
'~q~?any: Engineering Science
Sa~?le Identification: Lag~o~ #~ Top
Laboratory Identification: 91102
Sa:7.?1e ~!atrix: Sou.
Date rec'~: 9./1~:~5
Dc: tee x ~ :- c:::. e ~: 9,': ~ '~5
Date a~a:yze~: 9'1:.1~~
4-Ch1orc-3-~e:hylphe~~1
t\~
4-\: t:-oj::--.e:-,:l
'0- .>
.'-
2-Chlorophe~ol
2,4-Dichlorophenol
t\J
t\J
Fentach~o;c~~e~::
~~::.:.
Pr.er.ol
\'-,
j, -
2,'-D:ffieth~lphe~o!
KJ
2,~,6-Tri:~:o;c~~e:-:~
~:
2,'-Dlnitrop~e:-0:
~'T"\.~.
1"-.1 ..
2-~eth:1-4,6-dir.itro?her.ol
N:;*
2-~~ trophe::ol
ND
Note:
~D (~one detecte:, lo~e, detectable limit: 1 ug/g)
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