United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
E PA/ROD/ROS-88/069
June 1988
4EPA
Superfund
Record of Decision:
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50272.101
REPORT DOCUMENTATION 11. REPORT NO. 12.
PAGE EPA/ROD/R05-88/069
3. Rec:ipient'l AcC888ion No.
" .t....
: [""""u,>u
...J.. I
4. TI.. and Sub""
SUPERFUND RECORD OF DECISION
Belvidere Landfill, IL
First Remedial Action
7. Autflor(l)
5. Report 0818
6/29/88
a.
8. Perfonning Organization Rept. No.
g. Performing OrgainiDllon ..... and AddNu
10. Projac1lTI8II/Work Unit No.
11. ContraC1(C) or Grant(G) No.
"
(C)
(G)
12. Spoo-w.g Organlullon ..... and AddrH8
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Rapor1 . Period Co.....
800/000
14.
15. SuppI8m8nI8IY No..
1a. Abatrlct (UnlIt: 200 _Ida)
The Belvidere Landfill (BL), occupying 19.3 acres of the 139-acre site, is
located just outside the City of Belvidere, County of Boone, Illinois. The
site is located within the 100-year flood plain of the Kishwaukee River,
which is adjacent to the site. Located within the site boundaries are two
ponds and a drum disposal area. The City of Belvidere owned the landfill
~om 1939 to 1973, operating first as a municipal landfill until 1965 and
nen as an industrial landfill until 1973. In late 1970, the City of
Belvidere applied for a solid waste disposal permit. The application was t
permit the disposal of 52 tons per day of domestic garbage, landscape
wastes, partially dewatered sludge, and demolition material. However, in
1971, the operator disclosed that up to 100 tons per day of wastes were
being deposited. This waste consisted of 35 tons of residential waste, 30
tons of industrial source waste, and 35 tons of commercial source waste.
Approximately 790,000 yd3 of waste were disposed of at the landfill. IEPA
denied the City's permit application in January 1971, and the landfill was
formally closed in 1973. Between 1975 and 1982, IEPA repeatedly cited the
landfill for inadequate cover violations. In the summer of 1979, sand from
(See Attached Sheet)
17. Document Analyala L O88ctIptoN
Record of Decision
Belvidere Landfill, IL
First Remedial Action
Contaminated Media: gw, soil
Key Contaminants: Organics (PAHs,
b. Idantltl8r8lOpan-Endad Tamw
PCBs)
c. COSA 11 FIaIdIGroup
AV8l1lbilty St8tarnant
1 g. Security CII.. (Thll Report)
None
20. Security ClI.. (Thil P8111)
NnnA
21. No. of Plgel
65
I
22. Price
(Sle ANSl-Z3g.18)
SIe 1_lnJClio- on~-
OP110NAL FORM 272 (4-77)
(Formarty Nn8-35)
-------
EPA/ROD/R05-88/06~' ' ,
Belvidere Landfill, 1~
First Remedial Action
16.
ABSTRACT (continued)
.
adjacent areas and prairie plant vegetation were applied as a final cover.
The primary contaminants of concern affecting the soil and ground water
include: organics, PCBs, PARs, metals, and lead.
The selected remedial action for this site includes: RCRA Subtitle C
capping over the 19.3-acre landfill; treatment or containment of soil from
the drum disposal area following resampling to determine the magnitude of
PCB contamination; ground water pump and treatment possibly using air
stripping with discharge to either the Kishwaukee River or the city
treatment plant; ground water monitoring; pond and river fish monitoring;
installation of an upgraded fence; deed restrictions to control
unacceptable onsite activities and construction; and flood control
measures to prevent erosion of the cap and landfill contents. The
estimated capital cost for this remedial action is $5,900,000 with annual
O&M of $271,000.
PERFORMANCE STANDARDS OR GOALS: The ground water extraction and treatment
system will operate until a 10-6 cumulative life-time cancer risk is met
at the point of compliance. PCBs greater than 50 mg/kg will be disposed
of, or incinerated, offsite. PCBs less than 50 mg/kg will be consolidated
on the landfill. Quantitative goals were not specified for other
contaminants.
.NSTITUTIONAL CONTROLS: Access restrictions involve upgrading the
existing fence to prevent recreational use of the landfill and to ensure
the integrity of the cap. Deed restrictions include controlling
unacceptable onsite construction and activities.
KEYWORDS: Air Stripping; ARARS; Capping; Carcinogenic Compounds; Deed
Restrictions; Direct Contact; Flood Plain; Ground Water; Ground Water
Monitoring; Ground Water Treatment; Inorganics; Institutional Controls;
O&M; Offsite Discharge; Onsite Treatment; Organics; PAHs; PCBs; Soil;
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..f
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND lOCATION
Belvidere ~'unicipa1 No.1 Landfill
Belvidere, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action for the
, Belvidere Municipal No.1 Landfill site developed in accordance with the
Comprehensive Environmental Response, Compensation and Li abil ity Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
This decision is based upon the contents of the administrative record for
the Belvidere Municipal No.1 Landfill site. The attached index identifies
the items which comprise the administrative record upon which the selection
of a remedial action is based.
The State of 1111n01s concurs on the selected remedy.
DESCRIPTION OF THE REMEDY
This final remedy addresses the source of the contamination by containing
the on-site wastes and contaminated soils and extracting and treating the
contaminated groundwater. The function of this remedy is to reduce the
risk associated with exposure to the contaminated material and the amount
of infiltration contributing to groundwater contamination, in addition to
reducing the risk associated with exposure to contaminated groundwater.
The major components of the selected remedy include:
o
Flood Control Measures;
o
Deed restrictions;
o
Installing an upgraded security fence around the landfill site;
o
Monitoring to ensure the effectiveness of the remedial action;
o
Capping the 19-acre landfill in accordance with Resource
Conservation and Recovery Act requirements;
o
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.
.
. DEClARATION
The selected remedy is protective of .human health and the environment,
attains Federal and State requirements that are applicable or relevant and
appropriate. and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum extent
practicable for this site. However, because treatment of the principal
threats of the site was not found to be practicable. this remedy does not
satisfy the statutory preference for treatment as a principal element of
the remedy. The size of the landfill and the fact that there are no on-
site hot spots that represent the major sources of contamination preclude a
remedy in which contaminants effectively could be excavated and treated.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted within five years
after commencement of remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
o
t
.:Ju.nt, ;1: ''7 ~]
Date
''''.' .
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. .
RECORD OF DECISION SUMMARY
BELVIDERE MUNICIPAL NO.1 LANDFILL
I. SITE DESCRIPTION
The Belvidere Municipal No.1 Landfill site is located just outside the
western city limits of Belvidere, Illinois (population 15,176) (Figure 1).
The landfill occupies approximately 19 acres of the 139-acre site. The
site is bordered by the Kishwaukee River.to the west, Spencer Park to the
south, by an active gravel pit to the north, and by Appleton Road (a
residential neighborhood) to the east.
The southern and western edges of the site are located within the 100-year
fioodplain of the Kishwaukee River. Located within the site boundaries to
the east of the landfill are two ponds and the drum disposal area
immediately northwest of the landfill (Figure 2). The Boone County Conser-
vation District uses the area as an experimental prairie and for
recreational fishing - swimming is not allowed and violators of this rule
are removed from the site. The ponds are abandoned gravel pits which have
been filled by groundwater with additional contributions of surface water
runoff from the landfill. The Kishwaukee River is also used for
recreational fishing and boating. .
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
The Belvidere landfill was owned and operated by the City of Belvidere from
1939 to 1965 as a municipal landfill. The landfill operations disposed of
waste in a~ old gravel pit from sand and gravel operations prior to 1939.
From 1965 to 1973, the city retained ownership while private contractors
operated the landfill. During this time period (1965 - 1973) industrial
wastes wer~ accepted at the landfill.
In late 1970, the City of Belvidere applied for a solid waste disposal
permit. . The application stated that the waste to be deposited at the
landf1ll consisted of approximately 52 tons per day of domestic garbage,
landscape wastes, partially dewatered sludge and demolition material.
However in 197.1 the operator disclosed that up to 100 tons of waste were
being deposited daily. This waste consisted of 35 tons of residential
waste, 30 tons from industrial sources and 35 tons from commercial sources.
Inspection reports by IEPA personnel indicate that special wastes, some of
which are currently classified by U.S. EPA as hazardous, were disposed of
in the landfill from late 1970 to early 1973. IEPA denied the city's
permit application on January 19, 1971 and the landfill was formally closed
in 1973.
Between 1975 and 1982, IEPA repeatedly cited the landfill for inadequate
cover violations. In the summer of 1979, excavations from the borrow area
south and west of the landfill were applied as a final cover. The cover
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, .
-2-
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FIGURE 1
Site
Location
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Figure 2
landfill Site Hap
"0. 1
.
.
11
A
'.
o
LEO END
I, Looillon
IoU limp I' LOOlllon
W"" S,mp
IUIIIG8
I Laeillon
S.dlm.nl Simp. Ie ,
W ,,, '.mp
LIIOh.,./Pond.d .
W.II Lou lion
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-------
.
-4-
prairie plants. Remedial action also included installation of -10
groundwater monitoring wells, collection and analysis of groundwater,
leachate, river water, and pond water samples by IEPA, and completion of a
site hydrogeologic investigation (IEPA, 1981). In December 1982, the site
was placed on U.S. EPA's National Priorities List (NPL) of abandoned or
uncontrolled hazardous waste sites eligible for investigation and cleanup
under the Superfund program.
B.
Enforcement Activities
u.S. EPA has identified approximately nine potentially responsible parties
(PRPs) for the Belvidere site. As business records for the site are
virtually nonexistent, the PRPs have been identified primarily through
responses to CERCLA Section 104(e) information requests.
A PRP Steering Committee has been established. U.S. EPA has held
discussions with the PRP Steering Committee and has provided them with
technical information as requested.
On May 18, 1988, Special Notice Letters pursuant to Section 122(e) of the
Superfund Amendments and Reauthorization Act (SARA) of 1986 were sent to
all PRPs. The deadline for receipt of a "good faith offer" to conduct the
remedial design and remedial action is July 25, 1988. U.S. EPA is
currently negotiating with PRPs for them to conduct the remedial design and
remedial action discussed in this Record of Decision Summary and the Record
of Decision.
III. COMMUNITY RELATIONS HISTORY
The U.S. EPA and IEPA published the Proposed Plan in accordance with CERCLA
Section 117. This document was made available at the beginning of the five
week public comment period and a pUblic meeting was held during this time.
Comments received and the responses to those comments are contained in the
Responsiveness Summary (Appendix A).
IY. SITE CHARACTERISTICS
During the Remedial Investigation (RI), U.S. EPA installed 26 groundwater
monitoring wells at the Belvidere site. These wells can be broken down
into: three wells representing background; seven wells which were.
installed through the landfill to determine the composition of leachate;
fifteen wells which were installed to determine the composition of
groundwater downgradient from the landfill; and one well which was
installed to collect groundwater from the deep bedrock aquifer. Samples
taken from these wells during drilling indicate that groundwater in the
site area occurs in two distinct aquifers, an upper aquifer and a lower
bedrocK aquifer. Despite this distinction, there is a direct connection
between water in the upper aquifer and water in the lower bedrock aquifer.
The upper aquifer consists of approximately 100 feet of sand and gravel,
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-5-
.
.
which is referred to as the Mackinaw Member of the Henry Formation. The
average groundwater flow rate for the sand and gravel aquifer was found to
be 254 ft/yr. The lower bedrock aquifer i.s represented by the Galena
Dolomite, which has an estimated groundwater flow rate of 9.38 ft/yr.
In the upper portion of the sand and gravel aquifer beneath the site,
groundwater appears to flow in a southwesterly direction toward the
Kishwaukee River. Groundwater flow in the deeper sand and gravel and
bedrock aquifers is al~o to the southwest. Vertical gradients between the
deep and shallow wells are very slight; water levels vary by no more than a
few tenths of feet at the locations measured. These vertical
gradients appear to be, at least in part, a function of the well.s
proximity to the river and seasonal fluctuations in the water table. This
suggests that discharge from the deeper part of the sand and gravel aquifer
to the river may occur during certain times of the year near the river.
However, these data are too limited to say with certainty whether
groundwater in the lower sand and gravel aquifer is discharging to the
river or flowing beneath the river in the vicinity of the site. Monitor
wells on the other side of the river would be needed to better characterize
groundwater flow in the sand and gravel and bedrock aquifers adjacent to
the river.
Average precipitation in the Belvidere area of 35.62 inches per year
eventually reaches surface water bodies via overland runoff or the
groundwater via infiltration. Runoff from the landfill occurs radially
down the slopes influencing the west pond and the river, as well as low
area adjacent to the landfill. Infiltration into the landfill is one of
the primary sources of leachate generation and subsequent groundwater
contamination at the site.
The landf~l' contains approximately 790,000 cubic yards of waste.
covers approximately 19.3 acres and has a maximum thickness of 39
It 1s estimated that the bottom 10~ of the landfill is perennially
saturated with groundwater (Figure 3).
It
feet.
.
laboratory analyses were conducted on groundwater, on-site soil, water in
residential wells along Appleton Road, and surface water and sediments in
the on-site ponds and Kishwaukee River. Results of the groundwater and
surface water analyses are presented in Table 1. Surface soil and sediment
analytical results are presented in Table 2.
V. SUMMARY OF SITE RISKS
A Public Health and Environmental Risk Assessment was conducted to assess
the potential exposure to human population, the environmental fate of the
contaminants and their potential exposure pathways. Of all the compounds
detected at the site, eleven indicator chemicals were identified as the.
compounds which will best represent the overall risk to public health
(Figure 4). Based on an evaluation of site conditions, six potential
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.
Fee.
Above
MSL
780
Soulhwel'
c
MW-14
C' Northeal'
MW-2 Shallow Well
MW-20 Deep Wel
780
720
I
0-
I
Leg.nd
land/ill Cap r=>?~:::::n
La~dlllled Wasle ~
Cahokla Alluvium - c:::J
Upper Sequence
Cahokla Alluvium - r::::J
lower Sequence
Paorla Loe.. ~
Mackinaw Member ~
o
I
200
I
Ho,lIonl.1 Sc""n FII'
400
J
:,
Well Sore en
10X Ve,rtlcal exaggerallon
'Wa ter Leve' In Well.
Me. lured 10/09/86
FIGURE ,3
GEOLOQIC CROSS SECT'9N-C~C'
. ,
"
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-7-
TAB LE 1
SUMMARY OF GROUNDWATER ANALYSIS
RANGE OF DETECTED SDWA SDWA WQC CRITERIA
COMPOUND Concentrations'" MCL MCLG 10-6 RISK EXCEEDED
ug/l ug/l U97T ug/l
Volatile Organics
4-Methyl-2-Pentanone ND-12 NE NE NE
Benzene ND-26 5 NE 0.7 Yes
Chlorobenzene NO -1. 6 NE 60(P) NE No
Chloroethane NO -8 . 1 NE NE NE
Chl orofonn NO 100 NE NE No
Ethylbenzene ND-32,000 NE 680(P) NE Yes
Toluene ND-15,000 NE NE NE
Total Xyl~nes ND-96,000 NE 440(P) NE Ye~
Trans-l,2-0ich1oroethene NO-II NE 70(P) NE No
Vinyl Chloride ND-3 2 NE.' 0.015 Yes
Se.1-Volatile Organics
1,3-D;chlorobenzene NO-2 NE NE NE
1,4-Dichlorobenzene NO -7 . 8 75 NE NE No
2,4-Dimethylphe~ol NO-170 NE NE NE
2-Methylnaphthalene NO -100 NE NE NE
2-t1ethyl phenol NO-54 NE NE NE
4-Chloro-3-Hethylphenol ND-6 NE NE NE
4-Hethylphenol ND-12G NE NE NE
Acenaphthene NO-52 NE NE 0.0031 Yes
Acenaphthylene ND-200 NE NE 0.0031 Yes
Anthracene ND-340 NE NE 0.0031 Yes
Benzo(a)Anthracene ND-190 NE NE 0.0031 Yes
Benzo(a)Pyrene NO-140 NE NE 0.0031 Yes
Benzo(b)Fluoranthene ND-I06 NE NE 0.0031 Yes
Benzo(g,h,i)Perylene NO-78 NE NE 0.0031 Yes
Benzo(k)Fluoranthene ND-35 NE NE 0.0031 Yes
Benzoic Acid ND-86 NE NE NE
Benzyl Alcohol ND-2 NE NE NE
Butylbenzylphthalate ND-70 NE NE NE
Chrysene ND-180 NE NE 0.0031 Yes
Di-n-Butylphthalate ND-82 NE NE NE
Di-n-Octylphthalate ND-28 NE NE NE
Dibenzo(a,h)Anthracene NO -4 . 7 . NE NE NE
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-8-
TABLE 1 (Continued)
SUMMARY OF GROUNDWATER ANALYSIS
RANGE OF DETECTED SDWA SDWA WQC CR ITER I A
COMPOUND Concentrations* t1CL MCLG 10-6 RISK EXCEEDED
ug/l ug/l U97T ug/l
Semi-Volatile Organics
(Continued)
Dibenzofuran ND-33 NE NE NE
Diethylphthalate ND-26 NE NE NE
Fluoranthene ND-430 NE NE 0.0031 Yes
Fluorene ND-260 NE NE 0.0031 Yes
Indeno(I,2,3-cd)Pyrene ND-62 NE NE 0.0031 Yes
Isophorone ND-2 NE NE NE
N-Nitroso-Di-n-Propylamine NO -1 0 NE NE NE
N-Nitrosodiphenylamine NO -37 ' NE NE 70 No
Napthalene ND-420 NE NE NE
Nitrobenzene ND-17 NE NE . NE
Phenanthrene ND-820 NE NE NE
Pyrene NO-620 NE NE NE
bis(2-Ethylhexyl)Phthatlate NO NE NE NE
Pesticides/PCBs
Alpha-BHC NO-O .01 NE NE NE
Aroclor-1242 NO-O.S NE NE 0.008 Yes
Aroclor-12S4 NO -7 5 NE NE NE
Aroclor-1260 NO-29 NE NE NE
Gamma-BHC (Lindane) NO-0.02 4 NE NE No
Inorgan1cs
Aluminum ND-18,400 NE NE NE
Antimony NO NE NE NE
Arsenic ND-20 50 NE NE No
Barium ND-488 1000 1500 NE No
Beryll ium ND-3 NE NE NE
Cadmium ND-3 10 S NE No
Calcium 59,760-164,000 NE NE NE
Chromium ND-133 50 120 NE Yes
Cobalt ND-27 .. NE NE NE
Copper ND-44 NE 1300 NE No
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-9-
TABLE 1 (Continued)
SU~1ARY OF GROUNDWATER ANALYSIS
RANGE OF DETECTED SDWA SDWA \~QC CRITERIA
COMPOUND Concentrations'" MCL MCLG 10-6 RISK EXCEEDED
ugl1 ug/l iij7T ugl1
Inorgan;cs
(Continued)
Cyani de ND-120 NE NE NE
Iron ND -19 , 500 NE NE NE
Lead ND-16 50 20 NE No
r1agnes i urn 24,900-316,000 NE NE NE
Manganese ND-985 NE NE NE
t1ercury ND-0.5 v 2 3 NE No
Nickel ND -86 NE NE NE
Potassium ND-330,OOO NE NE NE
Selenium ND-8 10 45 NE No
Sil ver ND-37 50 NE NE No
Sodium 4,870-338,000 NE NE NE
Thallium ND NE NE NE
Vanadium ND-33 NE NE NE
Zinc ND -81 NE NE - NE
-
... Range presented includes both downgradient and landfill groundwater
monitoring wells.
(a) Safe Drinking Water Act Maximum Contaminant Level.
(b) Safe Drinking Water Act Maximum Contaminant Level Goals.
(P) denotes proposed MCLG.
(c) Water Quality Criteria for protection of human health from
consumption of water (for 10-6 risk).
NE - Not Established.
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-10-
TABLE 1 (Continued)
SUt~RY OF SURFACE WATER ANALYSIS
COMPOUND
RANGE OF DETECTED
CONCENTRATIONS*
ug/l
Volatile Organics
Benzene
Bromodichloromethane
Trichloroethene
NO -1. 4
No-5
Nu-<5
Semi-Volatile Organics
NO
Pesticides/PCBs
NO
Inorganics
Aluminum
Antimony
Barium
Cadmi urn
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Hagnesium
Manganese
r1ercury
Nickel
Potassium
Sodium
Zinc
37-1270
No-6
No-61
No-9.2
36,000-86,280
No-307
NO-28
NO-19
NO-2040
NO-6
33,800-43,000
NO-132
No-0.29
NO -17 5
1,700-3,700
7,500-74,000
NO-57
1/10
96-HR
Tlm
ug/l
GENERAL
USE
STANDARD
ug/l
AWQC
( FISH
CONSUMPTION )
ug/l
400
NE
NE
45~000
NE
NE
NE
NE
3,433,000
NE
NE
NE
NE
NE
100
0.5
. 1000
NE
NE
NE
* Range presented consists of data from pond nd river water samples.
(a) One-tenth of the concentration represented by the 96-hr median
Tolerance Limit, as defined in 35 lAC 302.210.
(b) Illinois General Use Standards protect the state's water for aquatic life,
agricultural use, primary and secondary contact use, industrial use, and
aesthetic quality, as defined in 35 lAC 302.208.
(c) U.S. EPA Ambient Water Quality Criteria for Protection of Human Health
from Consumption of Contaminated Aquatic Organisms.
NE - Not Established.
NO - Not Detected. Detection limits presented in Tables 5-1, 5-2 and 5-3.
2000
NE
4000
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE'
NE
NE .
NE
NE
NE
NE
NE
NE
NE
NE
NE
NE
5000
50
NE
1000
NE
20
1000
100
NE
1000
0.5
1000
NE
NE
1000
CRITERIA
EXCEEDED
No
No
N
No
No
No
No
Yes
No
Yes
No
.No
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'0
TAllE 2
SUMMA.Y Of suafACE SOilS ANALYSES
IACKCROJIIO DRUM DISPOSAL AREA LAIIOFILl
.............-.-.................... .................................... ......_....~....-.......................
fnctlon Medlin fnctlon Medlen freet Ion Medlen
CHEMICALS '01 "Ipon Conuntntlon "nue POI h.pon Concr'ltnt Ion lang. POI Rupon Concentr.t Ion lang.
...................... .......... ............ .......... ....-..... -........... .......... .......... ............ ........-.....
VOLATilE ORGANICS (ug/lI:g) (ug/lI:g) (\I8/l1:g) Cug/lI:g) (ug/ll:g) (ug/lI:g)
1.1.1-Trlchloroethene 0/1 «5 0 0
Chloroforll 0 «5 2/4 20 18 - 22 0
Ethyl benlene 0 «5 0 1/] 14
T.trlchloroethene 0 «5 4/4 8.68 2.8 - 26 0
ToUI Xylenu 0 «5 0 1/] 150
SEMI-VOLATILES
i,-Wltrophenol 0/1 «1600 0 1/8 41
BenloC.)Anthrecene 0 «]]0 0 ]/8 80 76 - 140
BenzoCa)Pyrene 0 «]]0 0 1/8 110
BenzoCb)fluoranthene 0 e]]O I 0 2/8 125 50 - 200 I
BenzoCg.h.I)Perylene 0 e]]O 0 1/8 110 -
-
BenzoCII:)fluoranthene 1/1 40 0 3/8 63 49 - 140 I
ButylbenJylphthal.te 0 e3]0 315 210 100 ~ 300 1/8 39
Chryaene 0 e]]O 0 3/8 97 4J - 140
DI-n-Butylphthal.te 1/1 61 0 7/8 58 « - 480
DI-n-Octylphth.late 0 e3]0 0 1/8 44
fluonnthene 1/1 44 0 5/8 110 n - ]00
IndenoC1.Z.3-cd)Pyrene 0 e]]O 0 1/8 1Z0
Pentachlorophenol 0 c1600 0 218 145 120 - no
Phenanthrene 0 e]]O 0 Z/8 115.5 81 - 190
Phenol 1/1 140 0 0
Pyrene 1/1 50 0 5/8 67 5] - 180
bIICZ-Ethylh.xyl)'hth.18 1/1 41 ]/5 3Z0 74 - ]100 5/8 370 88 - ]200
PESTICIDES/PCI.
Aroclor-1242 0 e80 0 1/14 100 .
Aroclor-1254 117 ]6 4/4 .Z025 no - 51000 6/14 ]90 ]4 . 3500
-------
.
UIU Z C cont 11'aJed)
SUMMAIY OF SUI FACE SOilS ANALYSES
IAClCGRWWO DRUM DISPOSAL AREA LANDFill
.................................... ............---...................-- ........................................
friction Meet! 11ft Friction Medlen fraet Ion Medlen
CHEMICALS P08 I..pon Concentret Ion langl POI Rupon Concentret Ion lang. POI Respon Concentretlon lang.
...................... .......... -.-.-....... .......... ........... ......._-.-- ........... ............- ............... .......-......
INORGAN I CS (lng/kg) (1Ig/kg) (1IIQ/kg) (1IIQ/Itg) (1IO/kg) (1IO/Itg)
AIUlilfUII '" 4160 loll, 3~0 ]610 . 5650 8/8 21.35 1640 . 6220
Ant IIIIOnY 0 e12 1/4 0.62 0
Araenlc 1/1 1.6 ' loll, 2 1.5 . 1.9 8/1 1.75 1.0 . 2.8
hrlUli 1/1 49.4 loll, 89.6 51.10 . 118 111 1n 64.3 . 1530
8eryU II... 1/1 0.21 "I, 0.11 0.12 . 0.50 5/1 0.11 0.05 - 0.35
C IdIII UII 1/1 1.29 loll. 2.0] 1.41 . 6.11 7/1 2.72 0.8 . 10.5
Cllcll... 1/1 2060 4110 13900 11300 . 60800 8/1 53400 1640 - 80080
Chromh... 1/1 6.16 41' 10.82 5.09 . 30.3 1/8 1.26 3.3 . 60
Cobalt 1/1 4.11 'I' 2.101 1.66 . 3.5' 6/8 1.99 1.55 . 7.2
Copper 1/1 4.95 '110 6.1,] 4.0S . 2'.1 1/1 10.6 1.17 . 14.2
Cyanide 0 e10 0 2/8 1.02 0.84 . 1.2 t
Iron 1/1 58]0 loll, 28550 10100 . 61600 8/8 9085 5540 . 69700 -
lead 1/1 19.1 loll, 56.15 16.4 . 116 8/8 45.1 2.9 . 1000 N
Mignulua 1/1 1080 loll, 8210 4140 . 19800 8/8 11095 5nO . 41920 t
Mlngenel. 1/1 6.46 41' 422.5 2n .' 623 8/8 412.5 146 . 1300
Mercury 0 eO.2 0 1/8 0.1
Nlcht 1/1 5.45 I." 5.61 1.52 . 15.2 8/8 10.75 1.15 . 18.8
Potl..lua 1/1 1020 'I' 295 270 . 170 8/8 ]54 116 . 840
Selenll.. 0 e1 0 1/1 0.4
Silver 1/1 2.01 41' 4.15 2.27 . ".1 ]/1 2.1 1.98 . 5.5
SocH UII 1/1 20.2 loll. 59.55 ".5 . n.' 5/1 129 56.6 . 217
1 h.1 t II.. 1/1 0.19 loll. 0.19 0.02 . O.SIo ]/1 0.19 0.19 . 0.19
Vlned 11111 1/1 10.] '" 8.81 7.09 . 12.6 8/8 9.7 5.71 . 13.8
Zinc '" ]].] 'I' 171.5 38.6 . 565 8/8 1n ".6 . 2160
t'
[;
-------
UIU I (contlRJed)
SUMMA.Y Of SEDIMENT ANALYSES
llVEI UPSYIEAM I'VU DOIo'NSTlEAM PONDS
.....................~.................. .............-.-..........-.......---... .........................................
fraction Median fraction Median fraction Median
CHE"ICAL POI Rupon Cone (ug/kg) I 808 a POI Rupon Cone (UII/kg) hnge POI hlpon Cone (ug/kg) hnge
.................... .......... ............ .............. .......... .---....-... -..........-.... .-.-...... ..-.-....-.- ....--.....-.-
VOLATILE ORGANICS.
SEMI.VOLATllE ORGANICS
'.NI trophenol 0 c1600 2/4 1311.5 87 - 190 4/8 112 66 - 120
BenzoCa)Anthrecene 112 M '" 67 1/8 9'
BenzoCa)Pyrene 212 85.5 61 - 110 1/' M 1/8 96
BenzoCb)fluoranthene 1/2 100 0 1/8 34
8tnzoCg,h,l)Perylene 1/2 98 114 160 0
Chryaene 212 80.5 61 . 100 2/4 114.5 79 - 150 1/8 94
DI.n.Butylphthltlt. 212 "'1.5 79 - 220 2/' '8 45 - 51 6/8 5'.5 31 - 120
f luoranthene 212 129.5 99 - 160 2/' 3]5 170 . 500 2/8 97 2' . 170
IndenoCI,2,3-cd)Pyrene 0 c)]O 114 160 0
Penhch( orophenot 0 c'600 ]/'. '6 42 - 880 2/8 101.5 3] - 170
Phenenthrene 212 87 M - 110 2/' 2]0 110 - 350 1/8 100
pyrene 212 12] 96 ~ 150 2/' 220 140 - 300 2/8 86 22 - 150
bIIC2-Ethyth..yt)Phth. 212 48).5 67 - 900 2/4 1110 120 - 2100 6/8 93 ]9 - )50 I
-
PCBI \..)
I
Arodor-12U 0/8 caD 0 3/8 44 ]2 - 110
Arodor-125' 0 c'6O 0 3/8 56.5 2' - 140
Aroclor-126O 0 c160 1/3 65 0
INORGANICS
A hnl null 2/2 1054.5 IIIg/k 780 - 132 4/4 "".5 IIIg/k 10)0 - 4850 8/8 1145 IIIg/k 86a - 1652
Aratnlc 2/2 1.08 0.66 - 1.5 4/4 2.4 0.52 - 3.2 8/8 0.79 0.44 . 1.4
8erlUli 1/2 6.52 4/4 18 10.8 . 56.6 6/8 1 4.08 . 11.5
Beryl I hn 1/2 0.17 214 0.12 0.11 . 0.17 6/8 0.11 O. '0 . 0.15
C.anhn 1/2 0.6] ]/4 0.71 0.71 . 4 7/8 0.40 0.34 - 1.1
Calc h.. 2/2 100660 "420 . 123920 4/4 63996 30600 . 12nTO 8/8 70150 154S . 10nOO
ChrcmiUl 212 5.49 327 - 1..7 3/4 3.54 2.8 . 19 8/8 4.16 2.52 . 8.0
Cobe It ,/2 0.6 2/4 0.75 0.74 . 0.16 4/8 0.71 0.62 - 0.79
Copper 212 2.8' 0.91 . 4.1 3/4 5.1 5.19 . 16.3 8/8 3.71 0.57 . 8
Cyanide 0 c10 0 1/8 1.20
Iron 2/2 3336 3492 . 418 4/4 5200 4220 . 15296 8/8 JOOS 2430 . 4345
Lead 2/2 211.1 18.4. 405 4/4. 13.J 2.2 . 21.8 8/8 15.95 4 . 24.1
M.gnallUi 2/2 47940 42900 . 529 4/4 28450 12400 . 51660 8/8 J1400 18700 . nMO
"a09ana.a 2/2 266 171 . 361 'II" 170.5 119 . 1940 8/8 88.65 71 . 14S
Nickel 212 6.19 1.98 . 10.4 4/4 6.54 1.98 . 20.3 8/8 2.3 l.n . 11
Pota..IUI 2/2 116.5 113 . 120 4/4 163.5 140 . 299 8/8 150 94 . 190
Sliver 0 <2 0 2/8 0.51 0.46 . 0.56
SocIlUI 1/2 108 2/4 85.5 62 - 109 6/8 80.95 68 . 11S
VanedlUl 212 6.79 6.3 . 1.28 3/4 4.43 5.99 . 12.3 8/8 4.19 J.19. 8.1
Zinc 2/2 13.1 12.9 . 14.5 4/4 11.61 1.17 . 61.2 8/8 11.22 8.24 . 26.1
-------
- 1 1.-
.,. .,.-
FIGURE 4
INDICATOR CHEMICAlS
Organic
Dimethyl phenol
bis(2-ethylhexyl)phthalate
PAH (noncarcinogenic compounds)
PAH (carcinogenic compounds)
PCBs
Xylene
Chlorofo""
Inorganic
Cadmium
Iron
Lead
5i her
FIGURE 5
POTENTIAl EXPOSURE PATHWAYS
SOIL INGESTION
SOIL
CONCENTRATION
DOSE
DERMAL
SOIL
CONCENTRATION
DOSE
.
GROUNDWATER INGESTION
WATER
CONCENTRATION
DaSE
N
FISH INGESTION
FISH
CONCENTRATION
HUMA~
-------
."
-15-
ingestion, and fish consumption. Of the six exposure pathways, air and
surface water are not considered current exposure pathways. The remaining
five pathways (Figure 5) groundwater, soil contact, soil ingestion and fish
consumption -- create varying levels of noncarcinogenic (Table 3) and
carcinogenic (Table 4) risk, depending on usage and magnitude of
contamination.
The risks associated with exposure to contaminants were determined using
mathematical models. The models calculated an exposure dose in mg/kg/day
for both children and adults based on an assumed frequency of exposure to
indicator chemicals. The average and maximum exposures were based upon
average and maximum contaminant concentrations at points where receptor
co~tact could occur. Also" the average and maximum exposure dosages were
used to evaluate average (most probable) and maximum (worst plausible)
noncarcinogenic hazards and carcinogenic risk levels.
Surface Water
There is a potential for transport of contaminants to the Kishwaukee River
and ponds in Spencer Park adjacent to the landfill as a result of erosion
and surface runoff. Surface water and sediment samples that were collected
from the river and ponds as part of the Remedial Investigation indicate
that surface' water contamination may have occurred. However, these surface
water bodies do not exceed the Illinois Water Pollution Control IIGenera1
Usell water quality standards (Section 301). The general use standards
provide for protection of aquatic life, agricultural use, primary and
secondary contact, and most industrial uses. There is no evidence that the
Kishwaukee River in the vicinity of Belvidere is used as a potable water
supply. Consequently, human exposure due to consumption of drinking water
from the Kishwaukee River (or the ponds) does not represent a pathway of
concern. Because of the low contaminant levels found for the river,
exposure due to primary (swimming) and secondary (boating) contact is
expected to be negligible. No swimming activity has been reported in the
ponds and will not be considered further.
Air
Air is not considered a major pathway for possible contact with site
contaminants. Vaporization of the volatile contaminants from soil or
surface waters would not be expected to result in hazardous ambient air
concentrations even on a chronic basis. The probability of inhaling
contaminated dusts is also considered minimal. The area is well vegetated,
lessening the likelihood of dust generation. If construction were
undertaken sometime in the future where vegetation was removed and the soil
exposed, an exposure hazard might exist temporarily.
Surface Soils
Direct soil contact is a potential exposure pathway for persons entering
-------
Yehle .]
htllll8ted Cont8lllnint DOligel and Nonclrclnogenlc Hlurd Index.. (Including only Downgndlent Veil.)
'...Soll Ingeltlon..-1 I'Den.e1 Absorption'" 'Groundwlter Consumptlon/---'Totll Intlk'-...I
'.....llndflll'...-1 I'...-llndfltl._...' I'Downgrldlent ~ettl" I--'Atl PlthWIYI...1
Indlcltor Avenge MI. Averlge Mill Averelle M8I( Avenlle Mill A1C. '.--Hllird Inde...'1
Chemicil (~/kll/d.V)(~/kll/d.y) (~/k8/d'V)(Mg/kg/daV) (~/kll/d'V)(Mg/kll/d.y) (-u/k8/daY)(~/k8/day) (-U/kg/dlY) Avenlle MI.
........-........- ...................... ............-......... ....................-. .----.-.-.-.........-- ........-.- .----.-.--. -.----.----
Chi tdren
Cedi h.. 4.6E'07 1.8E-06 2.9£-06 1.1£.05 8.1£,06 1.0E-05 1.14£.05 2.29£-05 2.9£,04 ].9£-02 7.9£-02
Chi orofot1l 0 0 0 0 0 0 0 0 1.0E-02 0 0
Dlmethytpllenol 0 0 0 0 1.8E-04 5.TE-(\4 1.82E-04 5.74£-04 5.TE-04 ].2£-01 1.0E+00
Iron 1.5E'0] I .2E .02 9.5£.0] 7.1£-02 4.8£-0] 6.tE-02 1.58E-02 1. 51E-01 1.4£,02 (1) 1.U+00. 1.IE+OI'
leed 7.6E-06 1.1£-04 4.TE-05 I.CE-O] 4.1£-05 4.1£-05 9.5t.E-OS 1.26£-0] 1.4£-0] 6.8E-02 9.0£-01
PAM (Nonclr + Clr) ].OE-08 6.6E-08 1.9£-07 4.1£-01 0 0 2.20£-07 4.7'5£-07 5.U.0] (2) 4.1£-05 8.U-05
PCBe 5.1E-08 5.9£-07 ].2E-07 3.TE-06 2.0E-06 1.3£-05 2.35E-06 1.74£-05 1.6£-04 (]) 1.5£-02 1.1£-01 I
Phth.lltellDEHP 4.7£-08 5.U-01 2.9E-01 3.4£-06 1.8£-05 2.8£'04 1.82E-05 2.81£-04 2.0£-02 9.1£-04 1.U-02 -
0\
Sliver 3.9E-01 9.]E-01 2.4£'06 5.8E-06 1.2E-04 1.2E-04 1.28£-04 1.32£-04 ].OE-03 4.]E-02 4.4£-02 I
xvt en.. 1.U-08 2.5E-08 8.6E-08 1.6E-07 4.2E-OJ 1.4£-01 4.19£'OJ 1.3SE-01 2.0E+00 2.1E'0] 6.8E-02
ActJtt. Tot.I 1.6Etoo. 1.]Et01'
C.dlh.. 1.4£-01 5.3£-07 1.9£-06 7.2E-06 9.8£-06 1.2£-05 1.18E-OS 1.99£-05 2.9£-04 4.U-02 6.9£-02
Chlorofonl 0 0 0 0 0 0 0 0 1.0£-02 0 ' 0
D hnethytpllenol 0 0 0 0 2.2£-04 6.9£-04 . 2.19£-04 6.92£-04 5.7£-04 ].8E-01 1.2£+00 .
Iron 4.6£-04 3.5£-OJ 6.2E-0] 4.8E-02 5.7£-OJ 1.9E-02 1.24£-02 1.]1£-01 1.4£-02 (1) 8.TE-01 9.1£+00 .
Leed 2.3£-06 5.1£ -05 ].1E-05 6.U-04 4.9£-05 4.9E-05 8.21E-05 7.83£-04 I.U-O] 5.9£-02 5.6£-01
PAH (Nonclr + Clr) 9.2E-09 2.0£-08 1.2E'01 2.1E-07 0 0 1.]2E-01 2.86E-01 5.4£'0] (2) 2.5E-05 5.3£-05
PCBe 1.5£-08 1.8£-01 2.1E-01 2.4£-06 2.U-06 1.6E-05 2.62E-06 1.8U -OS 1.6E-04 (]) 1.6E-02 1.2£-01
Phth.I.te./DEMP 1.U -08 1.6£-01 1.9E-01 2.2E-06 2.2E-05 ].3£-04 2.1U'05 ].36£-04 2.0E-02 1.1E-03 1.1E-02
SHver 1.2E-01 2.8£.07 1.6E-06 ].8E'06 1.5£-04 1.5E-04 1.52E-04 1.55E-04 ].OE-O] 5.1E-02 5.2E-02
Xyt en.. 4.2£.09 1.6£-09 5.6E-08 1.0E-07 5.0£-0] 1.6E '01 5.05E-0] 1.6]E-01 : 2.0E+00 2.5E-0] 8.1£-02
Tot.1 I.U+OO. 1.1E+01.
. Hllird Inde. Vltue exceedS 1 Ind ~y Indlclte en 8dver.. heltth effect.
(1) Thl. AIC for Iron I. derived Ind reprelent. 1/10th of the the e.tl~ted ..f. Ind adequatl dilly dlet.ry Intlk. (£SADOI) for Iron (reported In
Goodman & Gllmen, 7th Ed., 1985)-
(2) Derived fr~ the ambient wlter quality criterion of 188 ug/L for ftuorlnthene.
-------
Table]
( con tI fI.I8d)
(Itlmeted Contemlnant 0051gel .nd Noncarcinogenic Hlllrd Indexel (Including only landfill Weill)
1---Soll Ingtatlon'--I I-Dennel Absorptlon--I IGroundwater Consumptlonl----'otal Intakl---'I
1----'landflll'-'--1 I"" -lendf 111-" -,-I 1---llnd'III Wella-'-I I~--AII Pathway'---I
Indicator Averag. "u Average "u Averlgl "u Averlge "1I( AICa I---Hallrd Index---I
Chtllli cal (mg/kg/dIY)(~/kg/day) (~/kg/d.y)(mg/kg/dIY) (~/kg/dtY)(~/kg/dlY) (89/kg/dty)(mg/kg/day) (~/k8/dty) Average "u
-.-............... ...................... ...................... -..................... -.-................... ........-.- ........... .........~.
Children .
ClCtnhn 4.6E'07 1.8£-06 2.9E-06 1.1£-05 2.7E'06 2.1£-06 6.0£-06 1.5(-05 2.9£,04 2.1£-02 5.3E-02
Chlorofor. 0 0 0 0 0 0 0 0 1.0E'02 0 0
Olmethylphenol 0 ° 0 0 1.3£.04 4.1£-04 1.3£.04 4.1£-04 5.1£,04 2.3E-01 7.1£-01
Iron 1.5£-03 1.2E-02 9.5E-0] 7.3£-02 5.3E'OJ 3.2E-02 1.6E-02 1.2E-01 1.U'02 (1) 1.1£+00. 8.2E+00.
leed 7.6E'06 1.1£.04 4.1£-05 1.0E-OJ 2.1£-05 5.4£-05 8.2E-05 1.3£,03 I.U.O] 5.9£-02 9.1£-01 I
3.0£,08 6.6£-08 1.9E-07 4.1£-07 2.U-04 ].4£-0] 2.4£-04 3.U'03 5.U-0] (2) 4.5E'02 6.4£,01 ....
PAN (Moncar . Clr) .......
PCsa 5.1£-08 5.9£-07 ].2£-07 ].1£-06 1.1£ -05 2.5£'04 1.8£-05 2.6£.04 1.6£'04 U) 1.1£-01 1.6£+00 . I
Phthllltea/D£HP 4.1£-08 5.4£-01 2.9£-07 ].4£-06 8.1£-05 I.U-04 8.1£-05 1.4£-04 2.0£'02 4.1£-0] 6.8£,0]
S II ver 3.9£-07 9.]£-07 2.4£-06 5.8£-06 0 0 2.8£-06 6.1£'06 1.0£'0] 9.3£-04 2.2£-03
Xylenea .1.4£ -08 2.5£-08 8.6£-08 1.6£-07 5.1£-OJ 3.2£-01 5.7£-0] 1.2£-01 2.0£+00 2.9£-01 1.6£-01
Ae1Jlta 'otal 1.6£+00. 1.2E+01.
Cednhn. 1.4E'07 5.3£.07 1.9£-06 7.2£-06 ].3£.06 ].]£.06 5.]£,06 1.1£-05 2.9£-04 1.8E'02 ].8E.02
Chlorofor8 0 0 0 0 0 0 0 0 1.0E'02 0 0
Dlmethylphenol 0 0 0 0 1.6E.04 4.ge-04 1.6(-04 4.9£-04 5.7(-04 2.1£-01 8.6(-01
Iron 4.6E-04 ].5£.0] 6.2(-01 4.SE-02 6.4£'OJ 3.9£-02 1.]£'02 9.0£'02 1.4£'02 (1) 9.1£-01 6.U+00 .
lud 2.3£'06 5.1£,05 ].1£.05 6.SE-04 ].3£-05 6.5E'05 6.6£-05 8.0£,04 1.4£-0] 4.7e'02 5.7£-01
PAH (Noncar . ear) 9.2e'09 2.0£.08 1.2£'07 2.7e-07 2.9£-04 4.1£,03 2.9£-04 4.1£-0] 5.4E-0] (2) 5.4E-02 7.7£'01
PCBs 1.5E'08 1.8£.07 2.1£-07 2.4E-06 2.1£-05 ].1£.04 2.1£-05 ]. 1£~04 1.6E'04 (]) 1.3£-01 1.9£+00 .
Phthalatea/D£HP 1.4£-08 1.6£,07 1.9£-07 2.2£'06 9.8£,05 1.6£-04 9.8£-05 1.6£-04 2.0£-02 4.9£-0] 8.1£'0]
S II ver 1.2£-07 2.8£-07 1.6£-06 ].8£-06 0 0 1.7£-06 4.0£-06 ].O£-OJ 5.6E-04 1.]E-O]
Xylenu 4.2£-09 7.6£-09 5.6£-08 1.0£-07 6.9£-OJ ].9£-01 6.9£-OJ ].9£-01 2.0£+00 1.5£-0] 2.0£,01
'otal 1.4£+00. 1.1e+01.
. Hllird Index value exceeda I and..y Indlcat. In adver.. hellth ef'ect.
(1) 'hla Ale for Iron II derived and representa 1/10th of the the eatl..ted .af. and adequ8te dally dletlry Intlt. (£SADOI) for Iron (reported In
Goodmen & Gilman, 7th ed., 1985).
(2) Derived fro. the ambient wlter quality criterion of 1~ ug/l for ftuoranthene.
-------
+
Tebl. 4
E.tl~ted LifetiMe Cancer .I.k.
''''Soll Ingutlon'''' '-Der..t Abaorptlon-., "Groundwlter Coneumptlon-'----Total Intah-...,
Indtntor '-'---Landfltt-----, '-----Llndfltt-----, '---Llndfltt uettl---' '---Atl 'athwaye---,
[hefllnl Average MIX Averege MIX Averege MIX Av.rege Mu ql.
.................. .....---.............. -.-.....-.. -.......... ..-........ ........... ........... ........... ......-....
(InchJCIlng only landfill "eU.)
Chlorofonll 0 0 0 0 0 0 0 0 8.10£-02
PAN (Carcinogenic) 5.5E-08 1.2£-07 7.U-07 1.6£'06 . 1.2£-0). 8.9£-0). 1.2£-0). 8.9£-0). 1.15E+OI
pcsa 1.2£-07 1.4(-06 . 1.6£-06. 1.8e-05. 1.6E-04. 2.U-0). 1.6£-04. 2.U-0). 7.00e+00
Phthatatel/D£NP 9.6E -12 1.1£'10 1.3£-10 1.5e'09 6.7£-08 1. 1£ -07 6.7£-08 1'.1£-07 6.84e-04
Total. I.U-O). 1.1£-02.
(Including only Oowngr8dlent Uelll)
Cht orof Of'll 0 0 0 0 0 0 0 0 8.10£-02
PAN (Carcinogenic) 5.5E-08 1.2£'07 7.U-07 1.6£-06 . 0 0 7.9£-07 1.7E-06. 1.15e+OI
pcsa 1.2E-07 I.U-06 . 1.6£-06. 1.8£'05. 1.8£,05. 1.2£-04. 2.0£'05. I.U.04. 7.00£+00
'Phthallte,/O£NP 9.6£ -12 1.1£-10 1.3£'10 I. 5£ -09 1.5£-08 2.3£-07 1.5£'08 2.3£.07 6.84£-04
Totll. 2.1£'05. I.U-04.
I
-
Q)
I
(excluding groundwat.r pathway)
Chtorofor.
PAN (Carcinogenic)
PC"
Phthaluea/DENP
o
5.5£-08
1.2£-07
9.6£ -12
o
1.2£'07
I.U.06 .
1.1£-10
o
7.U-07
1.6£-06 .
1.3£'10
o
1.6£-06 .
1.8£-05 .
1.5E-09
o 0 8.10E-02
7.9£'07 1.71-06. 1.15£+01
1.7£-06., 2.0£-05. 7.00E+00
1,U'10 1.6£-09 6.84£'04
Tote II 2.5£'06. 2.1£-05.
. Vatuea reprelent the upper bound eatlMete of an Individual' I rllk (I...; tlkellhood or probability) of dev.loplng cencer aa
. reautt of Ixpolure to .'te cont,,'nant(l) over a TO-year Ilfeapan, abova and beyond naturalty occurring background levetl.
The actual rllk ..y be lell. Tha ~Totat. vatue. rcpr.aent the ,xcela Ilfetl.. caneer rlak a..oclated with tha lit. al a whote.
The,. valuel er. Inftuenced by the allUDed ,xpolura Conditions, frequencies, and cilratlonl.
I
-------
-19-
'f"'"
potenti ally be exposed to contami nants throug;, 's'c/ff.:oth'g'P.:sti on. Both small
and oldpr r.hildren might also absorb contaminants through repeated dermal
contact with contaminated soils while playing.
The two soil exposure pathways, soil ingestion and dermal absorption from
soil contact, were also analyzed for noncarcinogenic and carcinogenic
risks. Risk calculations are limited to the indicator chemicals and assume
a soil ingestion rate of 0.05 g/day for children and 0.025 g/day for
adults, a $oi1 contact area for dermal absorption of arm, hand and leg, and
an exposure frequency for each pathway of 52 days per year.
For noncarcinogenic risks, only iron produced a hazard index above 1.0. It
occurred for the dermal absorption pathway under maximum iron
concentrations. It did not occur under average iron concentrations for
this pathway. For the other pathway, soil ingestion, none of the indicator
parameters produced any noncarcinogenic risks.
For carcinogenic compounds, the calculations show PCBs and PAHs
(carcinogenic) create a cancer risk above 1 x 10-6 for the dermal
absorption pathway, when the maximum concentrations of these compounds are
used. An excess cancer risk from soil absorption also exists when using
the average PCB levels in the soils near the landfill. For the soil
ingestion pathway, an excess cancer risk occurs with PCBs at the maximum
concentration level in the soils.
Groundwater
Use of the upper aquifer downgradient of the site is not well defined.
However, it is a Class II aquifer, that potentially could be a future
source of potable water. A risk analysis of contaminated groundwater was
based on using groundwater from the landfill monitoring wells and
downgradient monitoring wells.
Potential health risks from contaminated groundwater consist of
noncarcinogenic and carcinogenic risks. For the former, a hazard index is
calcu1at~d based on expected dose and qualities of the parameter. A hazard
index above 1.0 indicates a potential risk. Carcinogenic risks are limited
to those parameters that may cause cancer. Cancer risks are expressed as
the probab~lity of excess cancer for an individual over the course of a 70-
year lifetime. A guidance level of 1 in 1 million probability is used to
delineate insignificant from potentially significant cancer risks. For
groundwater risk, the calculations assume consumption of 1 liter per day
for children and 2 liters per day for adults, with consumption occurri~g 52
days/year. .
For noncarcinogenic risks in groundwater, the parameter iron produced a
hazard index of greater than 1 in both the downgradient wells and landfill
wells, when using the maximum concentration of this parameter in their
respective wells. In addition, maximum PCB levels in the landfill wells
produced a hazard index above 1.0. Average levels of these parameters,
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-20-
For carcinogenic risks in groundwater, the parameters PCBs and PAH
(carcinogenic) produced excess cancer risks above 1 in 1 million in
landfill wells for both average and maximum concentrations. In
downgradient wells, PCBs continued to produce excess cancer risk at average
and maximum concentrations, but PAH (carcinogenic) did not. In addition,
benzene and vinyl chloride, suspected carcinogens, were found in the
landfill and downgradient wells, respectively, above their maximum
contaminant level (MCL) for safe drinking water.
Fish
No estimates of actual fish consumption from the Kishwaukee River or the
Spencer Park ponds are available, but it is assumed to be limited to a
small nu~ber of local residents. Sediments in these water bodies contain
PCBs, semi-volatiles and metals, while water column data from the West Pond
shows slightly elevated iron levels. PCB levels in fish from these waters
were below specified detection limits, although detection limits were about
20 times higher than normal due to the high lipid content in the samples.
Accordingly. a final evaluation of risk from consumption of fish from these
waters is not made.
VI. DESCRIPTION OF At TERHATIVES
Nine alternatives were developed to meet the following remedial action
goals:
o
Minimize risk to public health and environment from direct contact
with contaminated material.
o
Control the migration of contaminated material to surface waters.
Control migration of leachate to groundwater via infiltration.
o
Minimize potential risk to public health from future consumption of
contaminated groundwater.
Alternatives 1 and 2 eliminate the need for long-te~ management or
monitoring; Alternatives 3, 4 and 5 employ treatment to reduce toxicity,
mObility or volume of hazardous substances; Alternatives 6, 7 and 8 contain
the wastes; and, Alternative 9 is the No Action Alternative. Alternatives
I, 2 and 4 are also intended to restore the groundwater within five years
to a level meeting the 10-6 lifetime excess cancer risk.
o
All of the alternatives, except no action, include deed restrictions,
upgrade site fencing, flood control measures, and groundwater monitoring.
The nine remedial alternatives under consideration for this remedial action
are described below:
Al ternative 1:
Excavation, On-Site Incineration and Groundwater
Extraction, On-Site Treatment
Alternative 1 provides for destruction of all landfill contents and surface
soils through an incinerator constructed on-site. The work includes
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-21-
excavation of wastes, construction of a 500 ton/day incinerator and
associated waste handling facilities, operation of the incinerator for a
period of up to five years, and disposal of residual ash in an off-site
RCRA 1 andfi 11 .
The groundwater would be extracted by two sets of barrier wells: the first
set located near the Kishwaukee River to prevent contamination of the river
by the migrating plume, and the second set located along the downgradient
border of the landfill to trap highly contaminated groundwater. The total
extracted flow is estimated to be 200 gallons per minute (gpm), and would
be treated, with final disposal of the effiuent to the Kishwaukee River.
Time to complete this remediation is estimated at six years; five years for
incineration with an additional year of groundwater extraction and treat-
ment after all contaminated material has been excavated and incinerated.
Total Cost of Alternative 1:
$127,550,000 (in net present worth)
Alternative 2:
Excavation, Off-Site Disposal and Groundwater Extraction
and On-Site Treatment
Alternative 2 provides excavation of landfill contents and disposal at off-
site RCRA landfills that are in compliance with the U.S. EPA CERCLA Off-
site Policy. The surface soils will be removed off-site for destruction in
an incinerator or disposed of in an off-site RCRA landfill. In addition to
compliance with the Off-site Policy, these facilities will need to have
authority ur,der Toxic Substance Control Act (TSCA) for disposal of PCBs and
disposal of some wastes may be prohibited by RCRA land disposal
regulations.
(~roundwater extraction and treatment would be similar
Alternative 1. In addition, instead of treatment and
Xishwaukee River, the groundwater could be pretreated
Belvidere Wastewater Treatment Plant.
to that in
discharge to the
and sent to the
Time to complete this remediation is estimated at six years, with five
years for excavation and disposal with an additional year of groundwater
extraction and treatment after all contaminated material has been removed.
Total Cost of Alternative 2:
$173,280,000 (in net present worth)
Sanitary Landfill-Type Cap, Soil Remediation, Plume
Barrler Groundwater Extraction and On-Site Treatment
Alternative 3:
The primary intent of this alternative is to provide a source-control
remedy. A sanitary landfill, multilayer cap will be constructed over the
nearly 20 acre landfill site. The surface soils will be treated according
to the following scenario: The soils in the drum disposal area will be
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-22-
o
If the soil samples indicate PCB contamination greater than 50
parts per million (ppm):
- That soil would be taken to an off-site incinerator, thus
ensuring permanent reduction of contaminant toxicity, mObility
and volume or;
o
The soil would be left in place and capped with a soil cover.
If the soil samples indicate PCB contamination less than 50 ppm,
then soils can be consolidated with the landfill material prior to
capping.
For groundwater remediation, Alternative 3 proposes to extract contaminated
groundwater by a plume barrier system located downgradient of the landfill.
The plume barrier system is designed to intercept contaminated groundwater
before it reaches the river. Total flow is expected to be 100 gpm.
Extracted groundwater would be treated on-site with final disposal of the
effluent to the Kishwaukee River. or alternatively. on-site pretreatment
with disposal to the City of Belvidere Treatment Plant for subsequent
treatment.
Groundwater extraction will reduce the movement of contamination beyond the
landfill boundaries. However. groundwater will continue to pass through
the landfill, picking up contaMinants for an indeterminant period of time.
Therefore. groundwater monitoring to determine the long-term effectiveness
of the remedy will continue in perpetuity. However. treatment may be
discontinued if cumulative groundwater contamination levels of indicator
chemicals do not exceed 10-6 life-time cancer risk at the point of
compliance. .
T~ta1 Cost of Alternative 3:
$5.617,000 (in net present worth)
Alternative 4:
RCRA-Type Cap. Soil Remediation. Groundwater Lowering,
Extraction and On-Site Treatment
The primary intent of this alternative is to provide a source-control
remedy. A RCRA-type. multilayer cap will be constructed over the nearly 20
acre landfill site to eliminate direct contact and infiltration. To
achieve compliance with ARARs, the surface soils will be treated according
to the scenario previously described under Alternative 3.
For groundwater remediation. Alternative 4 proposes to lower the
groundwater table to below the level of the buried wastes. Thirteen
extraction wells, sized at 150 gpm. would be placed within the border of
the fill and be located 25 ~. 40 feet into the groundwater aquifer. The
lowering of the groundwater table in combination with the RCRA cap, will
cut off the two sources of groundwater contamination. Extracted'
groundwater will be treated on-site with final disposal to the Kishwaukee
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-23-
Gnm"dwater,:ul'ider and near the landfill is estimated to approach background
levels within one year after installation of the RCRA cap and start-up of
the groundwater extraction and treatment system. Following remediation,
the treatment plant can be abandoned, but the groundwater lowering wells
will operate in. perpetuity to effectively prevent recontamination of the
groundwater. Therefore, long-term management of this site has not been
eliminated. Groundwater extracted after remediation will be of background
quality and can be discharged directly to the river without treatment.
Total Cost of Alternative 4:
S22,860,000 (in net present worth)
Al ternathe 5:
RCRA-Ty~e Cap, Soil Remediation, Slurry Wall Groundwater
Extract10n and Treatment
For remediation of landfill contents and surface soils, Alternative 5 is
the same as Alternative 4.
The two alternatives differ in the means for controlling the spread of
contaminated groundwater. Alternative 5 proposes to place a slurry wall
around the perimeter of the landfill, a distance of about 4,500 feet, in
order to control the migration of contaminated groundwater. The slurry
wall would extend downward 125 feet to be anchored into bedrock. Since the
bedrock is hydraulically connected to the upper aquifer, some groundwater
will pass under the wall. Extraction wells will be located within the
perimeter of the wall to control thi s mi grati on. A flow rate of 50 gpm is
estimated for these wells. Extracted groundwater will be treated in the
same manner as described i~ Alternative 2.
The groundwater will continue to contact buried wastes and, therefore, the
groundwater extraction system will need to operate in perpetuity. However,
treatment may be discontinued if cumulative groundwater contamination
levels of indicator chemicals do not exceed 10-6 lifetime cancer risk at
the point of compliance.
Total Cost of Alternative 5:
S14,410,000 (in net present worth)
Alternative 6:
RCRA-Type Cap, Soil Remediation, Groundwater Monitoring
. .
For remediation of landfill contents and surface soils, Alternative 6 is
the same as Alternatives 4 and 5. For groundwater, Alternative 6 provides
only groundwater monitoring to determine the amount and aerial extent of
groundwater contamination and assess the long-term effectiveness of this
remedy. Alternative 6 allows continued discharge of contaminated
groundwater into the Kishwaukee River, as well as potential migration of
contaminated groundwater beneath the river.
Monitoring of the aquifer, as a remedy, also prevents near-term use of the
groundwater between the landfill and the river. Deed restriction will be
necessary to ensure that the groundwater in this area is not used. A .
significant reduction in infiltration afforded by the RCRA cap may provide
a more stable water level in the landfill allowing flushing to occur in
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-24-
contamination to allow limited use of the groundwater; however, operation
and maintenance (0 & M) will continue indefinitely.
Total Cost of Alternative 6:
$5,990,000 (in net present worth)
Alternative 7:
Sanitary Landfill - Type Cap, Soil Remediation, Groundwater
Monitoring
This alternative is the same as Alternative 6, except that the multilayer
cap over the landfill contents is a sanitary landfill cap rather than a
RCRA cap. The sanitary landfill cover will eliminate surface runoff of
contaminants, but it will only reduce the current rate of infiltration
rather than eliminate it like the RCRA cap. It should be pointed out that
although current sanitary landfill cap regulations are not performance
based, as are the RCRA cap regulations, new sanitary landfill cap
requirements, with an emphasis on cap performance, are expected to be
published in the near future. One cap performance consideration is the
thickness of the frost zone - the zone where freezing and thawing occur on
a seasonal basis, potentially causing expansion and contraction cracks. In
the Belvidere area the frost zone extends to a depth of 36 inches - a
greater penetration than the entire sanitary landfill car thickness.
Therefore, under Alternative 7, as compared to Alternative 6, the decrease
in groundwater contamination will not occur as quickly. Operation and
maintenance of this remedy would be required to continue indefinitely.
~
.
Total Cost of Alternative 7:
$3,170,000 (in net present worth)
Alternative 8:
Limited Actions
Alternative 8 provides only limited actions for meeting remedial action
goals. Limited actions include deed restrictions to control unaccepted on-
site construction and activities, upgrade site fencing to restrict public
contact with exposed waste, flood control measures to prevent erosion of
those portions of the existing cover located in the 100-year nood plain,
and groundwater monitoring, on-site as well as across the river from the
site, to measure and locate the spread of groundwater contamination. These
actions are also used in Alternatives 3, 4, 5, 6, and 7, in conjunction
with their other remedial responses. However, here in Alternative 8, th~
limited actions are the only remedial response. Therefore, 0 & M of this
remedy will continue indefinitely.
Total Cost for Alternative 8:
$624,000 (in net present worth)
Alternative 9:
No Action
Under the "No Action" alternative, IEPA and U.S. EPA would take no further
action at the site to reduce contamination levels. Under this alternative,
site wastes and contaminated soils, routes of off-site contaminant
migration, and human and environmental exposure pathways will all remain
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. .
'"
groundwater via the infiltration of precipitation and the leaching of
hazardous constituents. This alternative would not reduce the risks to
human health and the environment. The No Action Alternative is always
evaluated to provide a baseline of comparison for the other alternatives.
Total Cost for Alternative 9:
$0
VII. SUrt4ARY OF THE COMPARATIVE ANALYSIS
The nine criteria used for evaluating the remedial alternatives listed
above include: overall protection of human health and the environment;
compliance with ARARs; long-term effectiveness; reduction of toxicity,
mobility. or volume; short-term effectiveness; implementability; cost;
State of III i noi sand Conmuni ty of Bel vi dere acceptance. Based on these
nine criteria. the Agencies. believe that the preferred alternative for
remedial action at the Belvidere Municipal Landfill site is a variation of
Alternative No.3 - RCRA Subtitle C Cap. Soil Remediation. Plume Barrier
Groundwater Extraction and On-Site Treatment (referred to hereafter as <
modified Alternative 3 with RCRA cap). The RCRA Subtitle C cap replaces
the sanitary landfill cap because IEPA has determined that the hazardous
waste landfill closure regulations of RCRA are relevant and appropriate at
this site given that hazardous waste was disposed of and is being released
from the landfill.
Overall Protection of Human Health and the Environment
Modified Alternative 3 with a RCRA Subtitle C cap would be protective of
human health and the environment. Capping of the landfill contents and 4
soil remediation will eliminate the direct human contact threat. It will
also significantly reduce infiltration. prevent migration of contaminated
materials to the Kishwaukee River and ponds. In addition. groundwater
extraction and treatment will ensure that the groundwater is protective of
the river. Deed restrictions would provide assurances that the groundwater
between the landfill and the. river will not be consumed. Groundwater
monitoring wells would gauge the protectiveness of the extraction/treatment
system on both sides of the river.
Alternatives I, 2. 4. 5. 6 and 7 would also be protective; however.
Alternatives 8 and 9 would not be adequately protective and are therefore
not eligible for selection.
Compliance with ARARs
Modified Alternative 3 with a RCRA Subtitle C cap. soil remediation. and
'groundwater treatment and discharge system would meet all applicable or
relevant and appropriate State and Federal environmental regulations.
Alternatives 1. 4. and 5 would also be compliant with the same ARARs under
RCRA Subtitle C landfill closure and groundwater corrective action
regulations. TSCA PCB disposal regulations. and Illinois' General Use Water
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ARARs except that these alternatives do not address clean up of releases to
the groundwater. Therefore, RCRA groundwater corrective action
requirements are not met.
In addition, Alternative 7 (and Alternative 3) only requires a sanitary
landfill cap. However, since the site did accept hazardous waste while in
operation and hazardous constituents are currently being released from the
landfill to the groundwater, RCRA, Subtitle C capping requirements are the
ARAR. Therefore, Alternatives 3 and 7 are not compliant with ARARs. .
Alternative 2 would be ARAR compliant except that disposal of some
untreated wastes may be prohibited by RCRA land disposal regulations.
Long-Term Effectiveness and Permanence
Modified Alternative 3 with a RCRA Subtitle C cap is comparable to
Alternatives 4 and 5 in the long-term effectiveness and permanence it
affords. All remedies involve possible treatment of any PCB contaminated
soils identified, containment of remaining material and long-term treatment
of groundwater.
Modified Alternative 3 with a RCRA Subtitle C cap provides long-term
effectiveness and permanence greater than Alternative 6 and 7, which treat
source material the same but do not treat groundwater; but less than
Alternatives 1 and 2 which would eliminate site risks through treatment or
disposal of source material and groundwater. Although Alternative 2 would
provide long-term effectiveness and permanence in terms of removal of the
source material, it would not meet these goals it viewed on a broader
scale. Transfer of untreated waste to a regulated RCRA facility also
transfers the need for long-term monitoring and does not provide a
permanent solution.
Alternative 1 does provide both long-term effectiveness and permanence
through incineration of source material. However, this alternative also
requires that residual ash be disposed at another facility.
Current sanitary landfill cap regulations are not performance based, as are
the RCRA cap regulations. Therefore, Alternative 3 with a RCRA Subtitle C
cap includes a greater degree of control with the RCRA Subtitle C cap than
those Alternatives utilizing a sanitary landfill cap.
Reduction of Toxicity, Mobility, or Volume
Modified Alternative 3 with a RCRA Subtitle C cap uses treatment to reduce
mobility and volume of hazardous substances in the groundwater and
toxicity, mObility and volume of PCB contaminated soils above 50 ppm which
are incinerated. The level of treatment is comparable to other treatment
alternatives with the exception of Alternative 1, which would significantly
reduce toxicity, mobility and volume through incineration of the source
material. Although Alternaive 2 would involve removal of the source
material, it does little to reduce toxicity, mObility and volume of the
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~
-27-
Alternative 6 and 7 do little to reduce toxicity, mobility and volume of
the wastes. Although the RCRA Subtitle C cap does not afford a reduction
in toxicity, mobility and volume through treatment, it does significantly
reduce infiltration (more than a sanitary landfill cap) and the production
of leachate that could migrate off-site.
Short-Term Effectiveness
Alternatives 3-8 will take approximately one year to implement; however,
the groundwater portion of the remedy will require continued operation for
an extended period of time. Although Alternatives 1 and 2 require more
time for implementation (6 years), long-term operation and maintenance is
not requir2d. .
During cap co~struction and soil remediation some wastes will be exposed
due to surface regrading. However, this can be effectively mitigated by
careful construction techniques to minimize the working face of the
regrading operations. The workers on-site will also have appropriate
personal protection.
In general. capping of the landfill will pose much less short-term risk to
the.community during construction than the excavation of landfill contents.
The five year period required for excavation could result in increased
noise, noxious odors, exposure of wastes to transport via wind and water,
and traffic disturbances.
Implementability
Alternatives 1 and 2 involve excavation of the entire landfill with
disposal at an on-site incinerator or off-site landfilling, respectively.
Implementation concerns associated with off-site landfilling involve
availability of off-site disposal capacity and prohibition of disposal due
to land disposal regulations. On-site incineration implementation may be
hampered by the variability and relatively high metal content of the waste.
Disposal of incinerator ash at a licenced RCRA facility will be necessary;
however. disposal capacity is limited and may impede the implementability
of this action.
Alternatives 3, 4, 5, 6 and 7 involve capping the landfill. Construction
of the cover is technically feasible, although there will be some minor
concerns about waste disturbance during construction. Construction of a
RCRA Subtitle C cap instead of a sanitary landfill cap will provide a
greater challenge if synthetic liners or membranes are required. These
concerns can be effectively mitigated by careful construction techniques.
Groundwater lowering and a slurry wall were considered in Alternatives 4
and 5, respectively, as part of the groundwater extraction system. The
groundwater lowering system would lower the water table below the base of
the landfill. However, induced infiltration from the west pond, makes it
uncertain that this lowered elevation can be maintained under all areas of
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,.
-28-
The site conditions make implementation of a slurry wall uncertain. In
particular, the subsurface sands, shallow groundwater, large depth to
bedrock, and lack of an impermeable barrier between the bedrock and the
contaminated aquifer raise questions as to the implementability of
Al ternative 5.
The plume barrier system of the modified Alternative 3 with a RCRA Subtitle
C cap extracts groundwater which is then treated prior to discharging into
the Kishwaukee River. The groundwater treatment system would be designed
with conventional treatment technology to meet appropriate. discharge
limits. Design approvals will be required from several Federal and State
offices in order to ensure that technical requirements are met. Once
design is complete, construction is expected to take only one construction
season.
Cost
Alternatives 1 and 2, excavation of all landfill contents, are by far the
most costly alternatives with present worth costs estimated at $127,550,000
and S173,280,000, respectively.
To determine the cost of modified Alternative 3 with the RCRA Subtitle C
cap instead of the sanitary landfill cap, one must subtract the cost of the
sanitary landfill cap (51.913 million) from the present worth cost and add
to it the cost of the RCRA Subtilte C cap (54.241 million) to get a present
worth cost of 57,948,480.
Modified Alternative 3, RCRA Subtitle C cap and plume barrier system,
Alternative 4, RCRA Subtitle C cap and groundwater lowering system, and
Alternative 5, RCRA Subtitle C cap and slurry wall system offer somewhat
more comparable costs at $7,948,480, S22,860,000, and $14,410,000,
respectively.
Capping and groundwater monitoring under Alternatives 6 and 7 would cost
$5,990,000 and S3,170,000, respectively. Limited action under Alternative
8 would cost $624,000.
Community Acceptance
This site has not seen a significant amount of community involvement.
Since the City of Belvidere ;s a Potentially Responsible Party (PRP), the
citizens seemed particularly concerned with the cost of the remedy.
Comments provided by the PRPs suggest that the actions proposed by the
Agency in this Record of Decision are reasonable, but expensive. Instead
of on-site groundwater treatment and discharge to the Kishwaukee River,
they suggest that extracted groundwater be discharged to the Belvidere
POTW. In addition, they suggest that the RCRA Subtitle C compliant cap can
be provided more cheaply and as effectively by means other than the design
provided in the FS. This Record of Decision specifies a performance based
response to the RCRA Subtitle C compliant cap. The PRPs can offer
alternative means of achieving the goal in the design phase. All
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State Acc~ptance
The Illinois Environmental Protection Agency (IEPA) played a major role in
the RIfFS proc~ss as the lead agency, and concurs on the selected remedy.
IEPA also recognizes their 50% cost share and 0 & M responsibilities.
IEPA believes that the modified Alternative 3 - RCRA cap, soil remediation,
and groundwater extraction and treatment via a plume barrier system -
presents the best balance among the nine evaluation criteria.
VI II. SElECTED REMEDY
Based on current information U.S. EPA and IEPA prefer a variation on
Alternative 3 -- RCRA Subtitle C cap, soil remediation, groundwater
extraction and treatment via a plume barrier system, monitoring, access
restriction and flood protection -- as the most appropriate final solution
for the Belvidere Municipal Landfill site. (This final remedy is referred
to as; modified Alternative 3 with a RCRA Subtitle C cap.)
RCRA Subtitle C Cap
This cap will be designed in compliance with RCRA Subtitle C landfill
closure requirements (40 CFR ~264.310 (a)). A gas venting system may also
be required to relieve pressure due to gas buildup beneath the cap. The
venting system would need to be assessed to ensure that it did not present
a risk to human health or the environment.
Waste, which is currently uncovered or protruding from the landfill, would
be covered in the course of regrading the surface. A minimum working face
will be maintained during surface regrading in order to minimize the
potentia1 airborne release of contaminants. This will ensure that work
completed at the site would be done in a manner that would minimize risks
to workers and nearby residents.
This component of the remedy has a capital cost of approximately $3.57
mi 11 ion. .
Soil Remediation
Soils in the drum disposal area, adjacent to the northwest edge of the
landfill will require remediation. These soils will be resamp1ed to
confirm existing data on PCB concentrations.
o If the soil samples indicate PCB contamination greater than 50 parts
per million (ppm):
- That soil would be taken to an off-site incinerator, thus.
ensuring permanent reduction of contaminant toxicity, mobility
and volume or;
- The soil would be left in place and capped with a soil cover.
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o If the soil samples indicate PCB contamination less than 50 ppm, then
soils can be consolidated with the landfill material prior to
capping.
The capital cost for this portion of the remedy is estimated to be $28,800.
This cost is based on the most expensive alternative of excavating to soil
and transporting it off-site for incineration.
Groundwater Extraction and Treatment
Extraction of contaminated groundwater will occur through a plume barrier
system of wells located downgradient of the landfill. This system will be
designed to intercept contaminated groundwater before it reaches the
Kishwaukee River. Total flow of extracted groundwater is expected to be
100 gpm; however, specific parameters of the extraction system will be
determined during design.
Extracted groundwater would be treated on-site with final disposal of the
effluent to the Kishwaukee River, or alternatively, on-site pretreatment if
necessary, with disposal to the City of Belvidere Treat~ent Plan for
subsequent treatment. Pilot and bench scale treatment plants will be
developed to determine actual system design and performance.
.
. If extracted groundwater is to be discharged to the Kishwaukee River, the
effluent must meet State of Illinois NPDES permit conditions. If extracted
groundwater is to be discharged to the Belvidere POTW, the effluent must
meet the POTW local limits.
If an air stripper is included in the treatment system, a risk assessment
will be performed to ensure the effluent is protective of human health and
the environment. Treatment may be discontinued if cumulative groundwater
contamination levels of indicator chemicals do not exceed 10-6 lifetime
excess cancer risk at the point of compliance. The boundary of the waste
management unit -in this case the landfill boundary - is considered the
point of compliance for groundwater.
The capital cost of this portion of the remedy is estimated to be $407,000.
Monitoring
o Groundwater/Surface Water
The purpose of groundwater monitoring is to track the location of
contaminated groundwater and to measure the effectiveness of remedial
measures. The FS suggests eighteen sampling sites for monitoring.
They consist of thirteen existing monitoring wells located in the fill,
downgradient in the plume, upgradient for background and in bedrock; two
sites in the West Pond; and three new monitoring wells located on the
west side of the Kishwaukee River. These latter wells are intended to
determine whether or not contaminated groundwater is passing under the
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.3iamT~ .r~- J>e taken from the sampling sites twice per year.
~i.~ .r-:- De analyzed for a list of parameters that will be
IE~~ JIiUMng the design phase.
7ne ~ ~ lItOnitoring is estimated to be $1 ,350/sample. For the 18
s:~.,. ~c::-- ~d twice per year, the total annual cost is estimated to be
~.~: . ~truction of the three new monitoring wells is estimated to
tine :. =:a::f~l cost of $17,000. Should the groundwater results remain
~1~~1~ ::Dnsistent over time, monitoring may not need to be as ex-
-:eftS: ..e-.
Each
I)
Fis:=-
:.a~ :-: =re lack of quality fish analysis data, conclusions regarding
!"i sk3 =:;:S::c7 ~ed wi th the consumpti on of fi sh coul d not be made.
Ad~i~C7T~l ~itoring of the fish in the two ponds and the Kishwaukee
R~Y~ ~ n~ssary. Sampling and analysis of the fish should occur 0"
an ~l ~s.
If ~7" _vses 7.T1dicate that fish consumption poses. little or no risk to
N8a::: .'Tealt:!., sampling and analysis could be discontinued.
Ac:::es s i~_r'i ~ - -. :m
Th'e ac~ reS-:-; cti ons i ncl ude an upgraded fence to preserve the i ntegri ty
(;: 'the ~ anc: ~event recreational use of the landfill, and deed
~tricti.=rns t:: t:ontrol unacceptable on-site construction and activities.
Camita1 c::::sU r:,.- the fence and deed restriction will be $64,000 and.
~.OOC. ~sp~vely.
F7IDod P,.-.- -==ti~
F;IDOd cc~l ~sures are needed to prevent erosion of the cap material
arnd lan:. 11 ~ents. This feature will be designed and constructed to
Jll':i11imi~ -:rmpa~..s on the floodplain and adjacent wetlands. For the purposes
rrF cos~ ~;::la~Dn. it is anticipated that extra layers of compacted clay
~d vege~ed 5:;1 along the northwest and southwest borders of the cap are
~i~ '=:;:) proTide protection to the underlying material. The FS .
es1:ima~ 'that ~e extra layers woul d extend outward 10 feet from the toe
ar the s1 =r;>e f=- approximately 2,800 feet along the western edge of the
1.zmdfi11. Capi::al costs are estimated to be $80,700.
i:~;s al~atiy~ is believed to offer the best balance of tradeoffs among
t:ne ni ne =ri ter-f a in afford; ng prompt protecti on of human health and the
e!nvironmC:I.t through readily implementable means at reasonable costs. The
cap; tal <:::,st fer- this remedy is S5. 9 mill ion, the annual operati on and
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.
.
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designed to apply to landfills. The Belvidere Municipal landfill
has similar characteristics to Subtitles C and D such that both
laws are considered relevant.
The State of Illinois has jurisdiction for Subtitle D, sanitary landfill
operation and closure laws. This is covered by the Illinois
Administrative Code (lAC) Title 35: Environmental Protection Subpart G:
Waste Disposal. This regulation applies to those facilities which
operated in accordance with the .stated requirements and did not accept
hazardous waste. The existing regulation is fairly general and relies
on guidance and final approval of the permit writer. This cap seeks to
minimize infiltration by specifying clay type, and promote drainage by
specifying sloping and topsoil requirements.
RCRA Subtitle C requirements for caps are applicable to those hazardous
waste disposal facilities which operated after promulgation of the
regulation in 1980 and/or were granted interim status to operate in the
manner provided by the regulation. This regulation requires that the
cap minimize liquid migration, minimize maintenance, promote drainage,
accommodate subsidence and be less permeable than the bottom liner. In
addition, guidance and permit writer approval will determine the final
cap design based on site-specific characteristics. Since waste from
regrading and possible soil remediation will be consolidated on-site,
placement will not occur and thus RCRA Land Ban Requirements will not be
triggered.
Q
Distinguishing which cap regulation is most appropriate when both are
relevant, requires. a review of site-specific characteristics. Although
the Belvidere site has been referred to as a municipal landfill, the
site did accept hazardous waste while in operation. . Also, hazardous
constituents are currently being released from the landfill to the
groundwater. Hazardous constituents, although not uncommon in
relatively low levels, typically do not occur in sanitary landfills at
the relatively high concentrations found at the Belvidere site.
Therefore, the Subtitle C, RCRA capping requirements are the most
appropriate.
o Soil Remediation
This portion of the remedy is driven by the Toxic Substances Control Act
(TSCA). TSCA 40 CFR 761.60(a)(4) requires that materials disturbed or
excavated which contain 50 ppm or greater PCBs be disposed at a landfill
authorized under 40 CFR ~761.75 or an incinerator authorized under 40
CFR ~761.70.
For those materials containing 50 ppm PCBs or greater, disposal will
occur at a TSCA compliant facility. However, if subsequent analysis
determines that the soils contain less than 50 ppm PCBs then the
contaminated material will be consolid~ted on the landfill prior to
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o Groundwater Extraction and Treatment
RCRA Subpart F regulations apply to releases from solid waste management
units (SWMU). Given that RCRA Subtitle C landfill closure has been
determined to be relevant and appropriate and the Belvidere municipal
landfill (SWMU) is currently releasing hazardous constituents to the
groundwater, it has been determined that RCRA Subpart F is also relevant
and appropriate. The point of compliance (40 eFR S264.95), at which
groundwater cleanup standards are to be applied is the 19.3 acre
landfill boundary. The groundwater extraction and treatment system will
operate until groundwater no longer exceeds a 10-6 cumulative life-time
cancer risk at the point of compliance.
RCRA Section 3008(h} and Section 3004(u} and (v), provide U.S. EPA the
authority to order corrective action at a facility operating pursuant to
RCRA from which a release of hazardous waste or hazardous waste
constituents has occurred. The RCRA corrective action authority is
relevant and appropriate to the site, as groundwater sampling has
documented releases from the hazardous waste landfill.
Groundwater treatment and subsequent disposal will be regulated by the
National Pollutant Discharge Elimination System. Discharge of treated
groundwater to the Kishwaukee River shall not exceed applicable Illinois
General Use Standards (lAC 35: S302.208) and one-tenth 96-hour TLm
criteria (lAC 35: S302.210) at the 10-5 cancer risk level. Discharge
to the Belvidere POTW must meet the requirements of the City of
Belvidere's sewer use ordinance, which includes general prohibitions
,and numerical limits covering various organics, ammonia and metals.
o Floodplain and Wetlands Protection
U.S. EPA has a fioodplains and wetlands policy which regulates
construction in a floodplain (similar to RCRA 40 CFR 270.14(b)(ii)(iv»
and filling of wetlands (40 CFR Part 230). The impacts that
Alternatives may have on wetlands, located in the borrow area west of
the landfill, and the fioodplain, which ends at the western edge of the
landfill, are expected to be minimal -- less than 0.5 acres and will not
require mitigation. Impacts to both the wetlands and fioodplain will be
considered and minimized to the maximum extent practical during the
design phase of this project.
a Endangered Species
The Belvidere Municipal Landfill site adjacent to the Kishwaukee River
is a potential summer habitat for Indiana Bats. The Indiana Bat is a
Federal Endangered Species and is therefore protected under the Federal
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,,' ..
To determine the presence or absence of the Indiana Bat on the Belvidere
site, a bat survey will need to be performed. If bats are found to use
the area as a summer habitat - they tend to live 1n dead or dying trees
along small river corridors - then construction involving removal of
trees could not be performed between May 1 and September 1. However, if
no bats are found on the site, construction can continue without
interruption.
Cost Effectiveness
Although this remedy leaves behind material that poses risKs that must be
managed, the more permanent solutions -- on-site incineration or off-site
disposal -- are so much more costly, contain technical uncertainties and a
greater chance of posing short-term risks for the Belvidere site that they
are not preferred. Modified Alternative 3 with a RCRA Subtitle C cap also
offers an advantage over other containment alternatives in that it provides
for protection of the river and groundwater for the least cost.
Utilization of Permanent Solutions and Alternative Treatment Technologies
to the Maxlmum Extent Practicable
This alternative offers the best balance of tradeoffs among the nine
criteria in affording prompt protection of human health and the environment
through readily implementable means at reasonable costs. This remedy
represents the maximum extent to which permanent solutions and treatment
can be practicably utilized.
Preference for Treatment as a Principal Element
Treatment of the principal threats of the site was not found to be
practicable. Therefore, this remedy does not satisfy the statutory
preference for treatment as a principal element of the remedy. The size of
the landfill and the fact that there are no on-site hot spots that
represent the major sources of contamination preclude a remedy in which
contaminants effectively could be excavated and treated.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted within five years
after commencement of remedial action to ensure that the remedy continues
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.
APPENDIX A
BELVIDERE MUNICIPAl NO.1 LANDFILL
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BELVIDERE MUNICIPAL NO.1 LANDFIll
BELVIDERE. IllINOIS
RESPONSIVENESS SUMMARY
I.
RESPONSIVENESS SUMMARY OVERVIEW
In ac.ccrdance with CERCLA Section 117, the United States
Environmental Protection Agency (U.S. EPA) and the Illinois
Envi ronmental Protecti on Agency (IEPA) recently hel d a public
comment period from May 2, 1988 to June 6, 1988, for interested
parties to comment on U.S. EPAls Proposed Plan and Feasibility
Study for addressing contamination problems at the Belvidere
Municipal Landfill site. At the public meeting, held on June 2,
1988, u.s. EPA and IEPA presented their Proposed Plan for the
Belvidere Municipal Landfill site.
The purpose of this responsiveness summary is to document U.S.
EPAls and IEPAls responses to comments, criticisms and new data
received during the public comment period." All of the comments
summarized in this document were considered prior to U.S. EPA and
IEPA's final decision.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT
The Illinois Environmental Protection Agency (IEPA) has been
responsible for conducting a community relations program for this
site. A community relations plan was submitted to and approved by
the U.S. EPA in June. 1984. The emphasis of this first phase of
the community relations program was directed at one-to-one contact
and informal meetings with local officials and citizens responding
to community concerns about groundwater contamination of private .
wells along Appleton Road and migration of hazardous waste to other
areas of the environment that may threaten the public health and
the environment. Periodic sampling and analyses of non-community
source wells and private drinking water wells were coordinated
between the Ci ty, County, State and Federal agenci es incl udi.ng U.S.
EPA and IEPA.
Early in the Remedial Investigation, the Community Relations
Coordinator identified the need to provide strong coordination
between the City and County agencies. The coordinator acted as
liaison between the Mayor, Boone County Conservation District
Executive Director, and the County Public Health Administrator who
represented the County and public health concerns of the residents.
Because of the cooperation with public officials, public concerns
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-2-
Roger Gustafson, Executive Director of the Boone County
Conservation District, voiced concerns about the drinking water
quality in Spencer Park which is southeast of the landfill. Mr.
Gustafson was concerned that users of the park might not be aware
that there may be contamination in these wells coming from the
landfill. IEPA sampled all three wells in the park and found low
levels of contamination in one of them. Although only one toxic
chemical was found in this well, it was not one of the hazardous
chemicals found at the landfill.
Appleton Road residents are extremely concerned about contamination
of their well water from the landfill. Discussions with residents
revealed the origin for this concern. In 1962, the Illinois
Department of Public Health found that some of the wells along
Appleton Road were contaminated. The source of contamination may
be coming from another site located upgradient of Appleton Road and
the park. The IEPA has initiated a preliminary assessment of the
site and soon the site will be scored for possible future action.
Milestone activities conducted by Community Relations during the
remedial investigation include:
Notification letters
Press briefings to explain site history and Superfund
program
News release announcing the start of the remedial
investigation and feasibility study
Informal meetings with area residents and local City
and County officials .
Fact Sheet #1 explaining history and problems at the
si te
Public meeting to discuss cleanup process -early in
Remedi.al I nvesti gati on phase
Fact Sheet #2 explaining Drum Removal
Informal Meetings with various community group to
introduce RI results
Proposed Plan
Public Hearing to receive comments on Administrative
Record'
Approximately 40 people attended the public hearing. Formal
comments were given by Mayor Ter~ Gratz, Robert Wilson, Louise
Miles, and Bud Heinz. The oral response to each comment or
question is provided in the official meeting transcript.
All formal wri tten comments were received from the Appl eton Road
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III.
-3-
SUMMARY OF SIGNIFICANT COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND U.S. EPA AND IEPA RESPONSES
The comments are summarized and organized into the following
categories:
1.
Summary of Public Hearing Comments
A.
B.
C.
D.
Comments on the Remedial Investigation
Comments on the Feasibility Study and Proposed Plan
Comments on Enforcement Issues
Miscellaneous
II. Summary of Significant Written Comments
A.
B.
C.
D.
Comments on the Remedial Investigation
Comments on the Public Health and Environmental
Assessment
Comments on the Feasibility Study and Proposed Plan
Miscellaneous Comments
The comments are paraphrased in order to effectively summarize them
in this document. The reader is referred to the actual reports and
comments available at the public repository.
I.
A.
SUMMARY OF PUBLIC HEARING COMMENTS
COMMENTS. ON THE REMEDIAL INVESTIGATION
COffENT:
Which way is the groundwater moving from the site?
RESPONSE:
The groundwater is moving in a southwesterly direction from
the site towards the river and does not effect private wells
along Appleton Road.
COM-tENT:
How did the contractor determine which way the groundwater is
flowi ng?
RESPONSE:
Weston installed several monitoring wells and measured the
groundwater levels in each one. The direction of groundwater
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-4-
levels. In the case of the Belvidere Landfill No.1,
monitoring wells indicate that the groundwater moves from the
northeast to the southwest toward the Kishwaukee River.
COfI(EHT :
How long will the groundwater moving from the landfill to the
river have to be pumped and treated?
RESPONSE:
The groundwater from the landfill will have to be pumped and
treated until the concentration levels of hazardous waste.are
reduced to an acceptable cancer risk level for humans. The
exact amount of time cannot be determined at this time.
COIt4EHT :
Has the groundwater from the fill reached the river?
RESPONSE:
Surface water samples confirm that hazardous constituents have
already reached the river. The shallow groundwater moves
approximately 254 feet per year which means it takes 4 1/2
years for the contaminated leachate under the landfill to
reach the river. .
COMMENT :
How much cover is currently over the landfill?
-RESPONSE:
The current sand cover ranges from 2 to 3 feet on the top of
the landfill. The edges of the landfill are covered with
approximately 0 to 6 inches of sand cov~r. The type and
amount of cover material currently on the landfill is not
adequate to prevent surface water from infiltrating through
the landfill and contaminating the groundwater.
COtI1ENT :
Is the landfill in Spencer Park?
RESPONSE:
No. The landfill is northwest of Spencer Park. Since the
groundwater flow is to the southwest, the Belvidere Municipal
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-5-
COtI€JfT :
Does the EPA know what kinds of chemicals are in the landfill?
RESPONSE :
We can't be sure that we know everything that's in the
landfill, but a full battery of tests were conducted by Weston
to determine the hazardous constituents in the landfill.
These tests included sampling and analysis of the groundwater
on three separate occasions. The hazardous chemicals that
were identified, have been considered in the remedial action
decision. .
B.
COMHTS ON THE FEASIBILITY STUDY AND PROPOSED PLAN
cmt4EJfT :
How feasible is the proposed remedy?
RESPONSE:
The proposed remedy is very feasible. All technologies to be
used are proven and are currently being utilized at numerous
State and Federal Superf~nd sites.
COMEJlT:
What is the maintenance cost on the proposed remedy?
RESPONSE:
Present worth cost of the proposed remedy includes capital
costs on construction, and maintenance and operation costs for
the next 30 years. These cost figures have been
conservatively set to allow for unforseen events. The
estimated annual operation and maintenance cost is $ 271,000.
COfolENT:
Will the groundwater be monitored all around the site?
RESPONSE:
Yes. A number of existing monitoring wells will be utilized
on and around the site., and additional wells will be put in
across the Kishwaukee River to determine if the groundwater is
flowing under the river.
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.
-6-
COMENT :
Will the houses along Appleton Road be sampled to see if their
wells have become contaminated?
RESPONSE :
At this time there are no plans to sample residential wells
along Appleton Road since it has been determined that the
Bel vi dere Landfi 11 si te does not impact the upgradi ent area
along Appleton Road. However, monitoring of groundwater on
the west side of Appleton Road will continue. .
COM4EtIT :
Has the Agency looked at biological degradation for volatile
organics as one of their alternatives?
RESPONSE:
Although biological degradation of organic waste is
technically feasib1e and was considered in the FS, the
landfill also contains other types of waste which can't be
treated by this method.
I
C.
COMMENTS ON ENFORCEMENT ISSUES
COlt4ENTS:
Who will pay for the cleanup at the Belvidere Municipal No.l-
Landfill?
RESPONSE:
The U.S. EPA expects that all identified potentially
responsible parties including generators and transporters of"
hazardous waste as well as owners and operators of the
landfill will pay for the cleanup. However, if negotiations
are unsuccessful, U.S. EPA and IEPA will proceed with their
remedy and pursue cost recovery at a later date.
COMtIT:
If the u.S. EPA regulations change for the multi-layer
hazardous waste cap, will the taxpayers have to pay for the
. upgrade of the cap?
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RESPONSE:
As long as the cap does the job of preventing surface water
from penetrating into the landfill contents, there will be no
need to upgrade it. However, the cap will require continued
maintenance to keep it in good condition.
COMMENT:
What happens to people who don't respond to the gl04 notice
letters?
RESPONSE:
The U.S.' EPA Enforcement Section is actively engaged in
pursuing info~ation on Potentially Responsible Parties
Belvidere landfill site. The Enforcement Section will
continue to investigate the people who may have prior
knowledge of the owners, operators, transporters and
generators of hazardous waste brought to the landfill.
g104 notice inquiry letter is just one way this can be
accomplished.
at the
The
COMMENT:
Is the list of people who were sent the 104 inquiry notices
dvailable to the public?
RESPONSE:
Yes. Under the Freedom of Information Act, this list of
people is available to the public by sending a letter to the
U.S. EPA requesting this information.
D.
MISCELLANEOUS COHHEHTS
COMMENT:
Is the County liable if there is a private well permit issued
to a resident, and there is contaminated water found in th~t
well?
RESPONSE:
The Boone County Health Department issues well permits and
inspects the construction of the well to see that it is
constructed according to State and .local codes, but this is no
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II.
-8-
. COtt1ENT:.
How will the current property owner's concerns be addressed by
U.S. EPA during the design phase?
RESPONSE:
The Boone County Conservation District should voice their
concerns to the Agencies during the design phase of the
cleanup. Their concerns will be considered during the design
and remedial action phases.
~
SUMMARY OF SIGNIFICANT WRITTEN COMMENTS
A.
COMMENTS ON TIfE REMEDIAL INVESTIGATION
1. COMMENTS ON SITE GEOLOGY
COMMENT :
A vertical cross-section illustrating the geological
interpretations developed by ARC was provided, including the
suggestion that the lower portion of the sand and gravel
aquifer represents Winnebago or Glasford Till Formations.
RESPONSE:
The commentors interpretation of the geologic cross-section is
similar to that found in the RI. The only significant
variation is ARC's interpretation of the lower portions of the
sand and gravel aquifer. Given that the interpretation of
this portion of the aquifer is based on data from one bore
hole, any interpretation is subject to uncertainty. The RI
appendix shows that some portions of the lower sand and gravel
aquifer are characterized by poorly sorted sandy gravels and
gravelly sands. Poor sorting is a characteristic of glacial
tills commonly found in the Belvidere area. Therefore, it is
possible that the lower portion of the sand and gravel aquifer
is made up of Winnebago and/or Glasford Formation glacial till
and outwash deposits.
COl1KENT:
The Troy Bedrock Valley is present in the area beneath the
site (Berg et al, 1984, Figure 10). The dimensions and
orientation of the tributary valley beneath the site are
unknown, although regional data indicates that the valley
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-9-
.
RESPONSE:
The Belvidere Municipal landfill site sits over the eastern
edge of the Troy BedrocK Valley. According to Berg et al.
(1984, page 11), the bedrocK valley trends south - southwest,
not northwest. The valley is approximately 2-3 mi 1 es wi de and
has up to 400 feet of vertical relief.
RESPONSE: .
2. COMHTS ON SITE GEOHYDROLOGY
COtK:NT :
ARC states that there is an upward vertical component of
hydraulic gradient, measured from the bedrock to the water
table, indicating that the river is a discharge zone for the
upper aquifer and at least the upper portion of the Tower
bedroCK aquifer.
RESPONSE: '
This statement 1s not supported by the RI. The RI states on
page 7-18 that vertical gradients between the deep and shallow
'wells are very slight; water levels vary by no more than a few
tenths of a foot at the locations measured. These vertical
gradients appear to be, at least in part, a function of the
wells' proximity to the river and seasonal fluctuations in the
water table. This suggests that discharge from the deeper
part of the sand and gravel aquifer to the river may occur
during certain times of the year near the river. However,
these data are too limited to say with certainty whether
groundwater in the lower sand and gravel aquifer is
discharging to the river or flowing beneath the river in the
vicinity of the site. The RI does not suggest that any.
portion of the bedrock aquifer discharges to the KishwauKee
River. The RI does suggest that monitor wells be placed on
the opposite si.de of the Kishwaukee River to better define the
flow characteristics of the lower sand and gravel aquifer.
COMMENT:
The upward vertical hydraulic gradient would act to maintain
contaminants at, or near, the groundwater surface. This would
tend to keep contaminants from entering the fractured bedrock
where extraction would be difficult, and reduces the depth to
which extraction wells would have to be installed in the upper
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-10-
RESPONSE :
The presence of chromium in the bedrock well indicates that
the bedrock is not acting as an aquaclude and that vertical
migration of the contaminated groundwater may occur.
Contamination has been detected in wells completed to a depth
of 40 feet into the upper aquifer. Therefore, extraction
wells will need to be installed deep enough to intercept this
contami nati on.
q
COJKNT:
Several minor errors were made in the analysis of test results
presented in the RI. The value of L should be the length of
well screen below the water table, not necessarily the total
length of screen which is shown in Appendix L of the RI.
Also, Bouwer and Rice (1976) state that the analysis is semi-
empirical and that the value of the term In[(D-H)/r] should
not be all owed to exceed 6. Ivery val ue of thi s term
presented in Appendix L exceeds 6 and the larger value shown
in the table was erroneously used to compute hydraulic
conductivity. However, the impact of these errors on test
results was small.
RESPONSE:
The agencies.agree that value of L should be the length of the
well screen below the water table, not necessarily the total
screen length as described in Appendix L of the RI. The
agencies also.acknowledged that the value of the term
In[(D-H)/r] should not exceed 6.
Some of the values of l used in the RI were larger than the
saturated screen length by one or two feet. In addition, the
values used for [(D-H)/r] all exceed 6, ranging from 6.54 to
7.20. The values utilized for these parameters varied only
slightly from the actual, therefore, the agencies agree with
ARCs conclusion that the impact of these errors on the test
results is minimal.
COMNT:
The bail-down test has the advantage of providing a rapid
means of estimating hydraulic conductivity in a small diameter
monitoring well. However, due to the limitations of the test
method and the simplifying assumptions made by Bouwer and Rice
(1976) in developing the analysis, the hydraulic conductivity
and related travel time values presented in the RI should be
considered approximate. They are expected to be of the
correct order of magnitude and are considered adequate for the
purposes of the RI and FS, but are not expected to be adequate
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-11-
RESPONSE :
As the commentors have stated, the purpose of the bail-down
test is to provide a rapid and inexpensive means of estimating
hydraulic conductivity. The agencies agree that the method
has some limiting assumptions, as do most test methods in the
field of hydrogeology. However, the results are considered
sufficient for the purposes of the RIfFS. If more specific
hydraulic conductivity data is needed it can be determined
during design.
3. Coments on Site Geochelistry
COJI4EHT:
ARC commented that there was no discussion in the RI on
duplicates, laboratory qualifiers, cation exchange, capacity
and percentage of organic carbon in soils. However, the
commentors concluded that the chemical analyses, particularly
those performed by Weston, and the final reporting of
chemistry data are of a high standard.
RESPONSE:
The percentage of organic carbon in soil and cation exchange
capacity were not part of the Quality Assurance Project Plan.
The Agencies feel that although the laboratory qualifiers were
not discussed in the text, they were adequately defined on the
analytical data tables. The Agencies believe that the absence
of these QA/QC discussions has no effect on the quality of the
data presented in the RI. and agrees with ARC that the
chemistry data are of a high standard. .
COM4ENT:
Because the reported detection of xylenes at MW-03 was not
confirmed by the subsequent phases of sampling and analysis
and because of the lack of other organic compounds in that
well, there is a possibility that this reported detection was
due to an artifact of sampling or analysis and not of
groundwater contamination.
RESPONSE:
Although it may be possible that the xylene in MW-03 was due
to an Uartifact of sampling or analysisU, the Agencies believe
it is likely that the xylene detected in MW-03 ;s due to
groundwater contamination. Xylene was detected in other
shallow wells (HW-07 and MW-19) immediately upgradient from
MW-03 during phase 1. Therefore, the relatively low level
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-12-
. .
..
COfI£HT :
4-methyl-2 pentanone was not reported in either the duplicate
of the sample or in the Udilutedll aliquot obtained fran the
same well (MW-09) during the first phase. The presence of
this ketone is not supported by the duplicate or Adiluted"
aliquots and should therefore be ignored.
RESPONSE:
Al though the dupl i cate and "di 1 uted" ali quots for GW-09 phase
1 did not detect 4-met~1-2 pentane, the actual sample (GW-09-
01) did detect this constituent. The laboratory did not
qualify this data therefore, the presence of this ketone will
not be ignored.
COJf4EHT :
Chloroform is listed in Table 5-16 of the R~ among the other
volatile organics, but no detection of chloroform was reported
in any of the groundwater samples. This compound should
therefore be ignored as a constituent of the groundwater at
this site.
.
RESPONSE:
The RI does not state that chloroform is a constituent of the
groundwater at this site.
COMMENT:
Trans-l,2-dichloroethene was only found in well HW-25 during
phase 2 and 3 sampling. The canpound was not reported in any
other well or matrix during this investigation. Although it
may have been transported through the groundwater from the
site as trans-1,2-dichloroethene or a parent compound, a more
likely explanation is that its occurrence has been caused by
an isolated spill and its presence is therefore not indicative
of contaminant migration from the landfill. The possibility
also exists that this contaminant is associated with the river
.rather than the landfill.
RESPONSE:
The RI addressed the fact that vinyl chloride and trans-1,2-
dichloroethene was detected only in HW-25 at this site. The
RI states that there are three possible explanations of the
presence of trans-1,2-dichloroethene and vinyl chloride in
well MW-25: 1) it is the trailing edge of a plume that
originated in or near the landfi11: 2) it has the same origin
as the tetrachloroethene, trichloroethene and 1,1,1-
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-13-
it has the same origin as the tetrachloroethene,
trichloroethene, and l,l,l-trichloroethane that is present in
the Spencer Park wells and it has migrated to MW-25 in
groundwater and by way of the Kishwaukee River.
The first explanation, that the chlorinated compounds in MW-25
originated in or near the landfill, is supported by the
presence of chlorinated aliphatic compounds in soils at the
drum disposal area. However, the other groundwater data
weaken this explanation. Trans-l,2-dichloroethene and vi~l
chloride have not been detected in any of the other monitoring
wells, including MW-24, the shallow well nested with MW-25.
The approximately rate of groundwater flow, 254 ft/yr, is such
that the compounds in MW-25 could be the trailing edge of a
plume. This hypothesis implies substantially different
mobilities for vinyl chloride and trans-l,2-dichloroethene
than those compounds detected below and just downgradient of
the landfill (i.e., benzene, toluene, xylene).
The second explanation, that the compounds in MW-25 are
degradation products of the contamination in Spencer Park and
that they migrated to MW-25 solely in groundwater, is
supported by the nature of the Spencer Park contamination;
but, ;t is weakened by the data regard;ng the nature and
di recti on of groundwater f1 ow is essenti ally straight toward
the river. This is probably the flow direction at Spencer
.Park. Thus, if the contaminants were to migrate northwest
from Spencer Park to well MW-25 , the migration would have to
occur in a different, deeper flow system within the outwash
deposits. However, data from wells in the vicinity of the
landfill at a depth comparable to that of MW-25 also indicate
flow essentially straight to the river. Overall, this
explanation is not considered to be very likely.
The first explanation appears to be best supported by the data
and by reasonable interpretations of possible migration
pathways.
COJIM:NT :
The VOCs of demonstrated significance for the site, and those
for which groundwater cleanup objectives should be developed,
are those found within the landfill itself: benzene,
ethyl benzene, toluene and total xylenes.
RESPONSE:
The Agencies agree that benzene, ethylbenzene, toluene and
total xylenes present a problem at the site. Cleanup
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detected at the site. These objectives call for continued
extraction of groundwater until it no longer presents a 10-6
excess cancer risk. The risk will be based on indicator
chemicals including, but not limited to: benzene,
ethylbenzene, toluene, and total xylene.
COtI4ENT :
Certain semivolatile organic compounds (PAHs and PCBs) are
associated with the landfill. Concentrations reported in
groundwater are artificially high due to the sorption of the
compounds onto soil particles which are then analyzed along
with (unfiltered) groundwater.
RESPONSE:
PCB and PAH groundwater samples were not filtered. This
procedure is generally followed under typical PCB and PAH
sampling plans and should not result in significant higher
concentrations in samples with relatively low total suspended
sol ids (TSS).
However, the samples CMW1S-02 and MW-1S-03) with the most
significant concentrations of PAHs do not have any detectable
amounts of TSS although some PCB samples have appreciable
amounts of TSS, there are samples with none. Finally, the
Agencies agree that under optimal conditions drinking water
wells are completed in such a way as to reduce or eliminate
TSS. However, one cannot assume that this is always the case.
Therefore, the Agencies believe that the concentrations of
PCBs and PAHs reported in groundwater are representative of
actual contamination in the groundwater.
COff4ENT:
Bis(2-ethylhexyl) phthalate was reported in background and.
blank samples and should be eliminated from consideration of
downgradient groundwater contamination at the site.
RESPONSE:
The RI does not state that this compound is con~idered in
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COtI£tlT :
A concentration of 0.01 microgram per liter was reported for
Alpha-BHC in sample GS-11-02, and a concentration of 0.02
microgram per liter was reported for Gamma-BHC in GW-25-01.
These pesti ci des were reported duri ng the phase 2 sampling
effort and qualified by the laboratory as estimated values.
They were not detected in any other sampling matrix at the
site and should not be given any further consideration.
RESPONSE:
The single detection of Alpha-BHC, in sample GS-11-02, was
qualified as "estimated" and "duplicate not within control
limits". Therefore, the Agencies believe that this parameter
is not considered significant to the site. Gamma-BHC was also
qualified as "estimated" and did not show up in subsequent
sampling events and as a result is not considered significant
to the site.
COMENT :
Contrary to the statement on page 5-76 of the RI, PCBs were
not reported in well MW-25 as indicated in Table 5-22 on page
5-74 of the RI. The statement on page 5-76 of the RI that
"This is an indication that there is horizontal migration of
PCBs from the landfill to the river, since PCBs are not
present in upgradient river samples" is greatly weakened by
the lack of PCBs being reported in any well adjacent to the
river.
The lack of any PCBs being reported in the groundwater during
the first phase of sampling and the lack of reported PCBs in
phase 3 groundwater sampling except in or adjacent to the
landfill further weakens the hypothesis that PCBs are
migrating to the river.
RESPONSE:
The Agencies agree that PCBs were not detected in MW-25.
However, PCBs were detected during phase 2 and 3 in
downgradient wells. Although significant groundwater
transport of PCBs to the river is unlikely, overland flow and
transport of PCB contaminated site soils to the river (and
ponds) has occurred.
COrtotENT :
Manganese, chromium and cyanide are mentioned on page 5-96 of
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RI. The concentrations of manganese and chromium reported in
all filtered groundwater samples are below 1000 micrograms per
liter. There ;snot sufficient evidence to include cyanide
for remediation at present.
RESPONSE:
The RI states that manganese exceeds its secondary MCL of 50
micrograms per liter and chromium exceeds its primary MCL of
50 micrograms per liter. The RI does not state that cyanide
exceeds any drinking water standards.
COMNT:
During a spot check of inorganic results the analysis of
sample GW-03-03 ~as reviewed. The reporting of silver in that
sample in Table 5-25 is erroneous. The Gulf Coast
Laboratories Corrective Action Report dated 10/15/86 shows
that an asterisk should be included for this metal on Table 5-
25 indicating that the original duplicate was not within
control limits. Comparison of the silver result with the.
duplicate and unfiltered samples shows that silver should be
reported as not detected. Silver has, therefore, not been
detected in filtered groundwater at this site.
RESPONSE:
The detection of silver for MW-03 was qualified in the RI as
.spike recovery not within control limHs." The qualifier
does not necessarily mean that silver was not detected.
Furthermore, silver was detected in an unfiltered sample from
MW-13.
COft4:ENT :
The ARC concurs with the conclusion in the RI that surface
water, associated sediments, and biota are not an issue at
this site. .
RESPONSE:
The RI does not state that biota (fish) are not an issue at
this site. The RI states that conclusions regarding adverse
affects to human health from consumption of fish cannot be
made due to problems with analytical detection limits.
COMHT:
Information on soil gas measurement techniques was requested
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supplement the data presented in the RI, but did not arrive in
s~fficient time to permit a.thorough review. Such a review
should be conducted as part of final remedial design.
RESPONSE :
B.
U.S. EPA received ARC's request for information on soil gas
measurement techniques on May 16, 1988.. ARC was notified that
those documents could be picked up on May 26, 1988. The
documents were picked up by ARC's messenger on May 31, 1988.
The public comment period ended June 6, 1988.
Comments on Public Health and Environmental Assessment (PH&EA)
COM£NT:
ARC commented that the groundwater exposure scenario is
unrealistic. Deed restrictions and other institutional
controls as well as the nature and knowledge of the Boone
County Conservation District regarding the site make such well
placement so remote as to void any risk calculation based on
this scenario.
RESPONSE:
The shallow aquifer located beneath the site would be
classified as a Class II aquifer and, in fact, is used for
drinking water in the area. Contaminants from the Belvidere
Municipal Landfill site have been released to the shallow
aquifer, making it unacceptable for drinking water use. U.S.
EPA guidance states that an exposure assessment should present
the 'worst probable case' exposure scenario. The PH&EA
therefore illustrated the impact of site contaminants to the
shallow aquifer with a scenario in which humans drink the
contaminated groundwater. This scenario considered current
site use and assumed only recreational visitor would consume
groundwater for 6 months out of the year on weekends only. In
addition, Region V policy states that an aquifer should not be
considered "undrinkablell merely because there are no current
or projected plans to use the aquifer for drinking water or
because of contamination caused by the site. Therefore, such
an ingestion scenario is an appropriate means to evaluate
human health and environmental risks posed by the site.
Contrary to ARC's comment, deed restrictions are not in place
at this time. It should also be recognized that deed
restrictions may be very difficult to enforce and provide no
protection to those persons consuming potentially contaminated
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COfIH:NT :
Neither silver nor chloroform should be considered in the
groundwater portion of the PH&EA.
RESPONSE:
They were not considered for the groundwater pathway.
COtI4ENT :
The actual dissolved concentrations, particularly of PCBs and
PAHs. need to be determined for a more accurate assessment of
public health risks from the consumption of contaminated
groundwater.
RESPONSE:
As discussed previously. the Agencies believe that the actual
dissolved concentrations of PCBs and PAHs have been adequately
determined. and that the PH&EA provides a sufficiently
accurate assessment of groundwater risk.
C.
Comments on the Feasfbilf~ Study and Proposed Plan
1. Comments on Groundwater Extractfon and Treatment
COlKNT :
ARC questions the need for groundwater remediation but later
agrees that "mi ti gati on" of groundwater is appropri ate. ARC
presents an arguement which suggests that groundwater needs
only be cleaned to a level such that it will not cause the
exceedance of ambient water quality criteria in the river.
RESPONSE:
~
The Agencies believe the ARC's logic is questionable in that
it may rely upon dilution of the groundwater with river water
to reach desired levels. It also ignores the inherent'
groundwater problem on-site and leaves open the possibility of
contaminated groundwater passing under the river.
COffttENT :
The ARC further states that chromium does not require an
action level since it was not detected above Hthe stated
criterion of 1000 ug/l."
RESPONSE:
The value ARC referenced is an Illinois General Use Standard
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for surface water. not groundwater. The HCL for chromium is
50 ug/l. a level which was exceeded in several groundwater
samples.
C!l4HEHT :
The ARC states that discharge of treated groundwater to the
B~lvidere POTW is desireable based on its technical
feasibility and cost effectiveness. They also state that the
Belvidere POTW f1anager indicated (to ARC) that pretreatment
would not be required.
RESPONSE:
The Agencies agree that discharge to the Belvidere POTW is
both technically feasible and cost-effective. However. the
Agencies questioned the administrative feasibility of this
alternative (i.e.. the willingness of the Belvidere POTW to
accept extracted groundwater from the site). The Belvidere
PCTW Manager indicated to U.S. EPA that he didn't feel
comfortable accepting the waste. but he would consider our
request once we had more detailed data on the wastewater
composition and volume. This data would be developed during
design. If all local limits are met and it is acceptable to
the ~elvidere POTW. extracted groundwater from the Belvidere
site can be directly discharged to the Belvidere POTW.
However. as part of the RA. a sewer line from the landfill
site connecting up existing lines will be required.
COHHEHT :
The ARC has serious concerns about the practicality and
achievability of the action levels proposed in Table 5-3 of
the FS.
RESPONSE:
The title of Table 5-3 of the FS is misleading. It is not the
Agencies' intention to apply ambient water quality criteria to
the groundwater at this site. Groundwater action levels are
to be risk based for the site. Primary HCLs shall not be .
exceeded. If there are no MCLs then indicator chemicals shall
not exceed a cumulative excess cancer risk of 10E-06.
C(H1EHT:
The ARC states that the point of compliance should be at MW-06
and MW-07. Once the levels are satisfied. pumping can be
suspended. Routine groundwater monitoring would be used to
determine if action levels are exceeded. If levels are
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RESPONSE :
The point of compliance is the landfill boundary. The
monitoring wells used to determine whether the groundwater has
reached the cleanup levels at the point of compliance will be
determined in the design phase. The Agencies agree that
pumping can be suspended once cleanup levels are satisfied.
The extraction system would be reactivated if groundwater
monitoring indicates that the levels are exceeded.
'I
COMNT:
The ARC proposed a different set of wells to be used for
groundwater monitoring at the Belvidere Landfill site.
RESPONSE:
The actual placement of monitoring wells will be determined
during design. However, three additional monitoring wells
will be placed on the west side of the Kishwaukee River to
determine if contaminated groundwater is flowing beneath the
ri ver.
2. Comments on Cost
COfwl4ENT:
The ARC commented that the cost estimates are generally
appropriate for the purposes of the FS, but are not
appropriate for purposes of funding. The ARC states that
inflation was not considered in cost estimates, making
alternatives with long-term operation and maintainence appear
less expensive.
RESPONSE:
In accordance with U.S. EPA costing guidance, inflation is
typically not included in the present worth cost. However,
FS cost estimates are purposely made conservative (+ 50~ -
30~) to ensure sufficient government funds are available for
. RA. It is possible that ARC can perform the RA for less than
the FS estimates. Since FS cost estimates are based on the
assumption that the federal government will conduct the RA,
certain costs (bid contingencies) must also be included that
may not be included if ARC was to perform the RA.
COM4ENT:
The ARC suggests that the cost for venting gases generated by
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RESPONSE :
The cost of a passive venting system is included in the
capping cost for each of the containment alternatives.
3. Comments on the RCRA Subtitle C Compliant Cap
COIf£NT :
The ARC states that the meaning of a "RCRA-typeu cap must be
further defi ned. They in turn propose a cap whi ch vari es
somewhat from the RCRA Subtitle C cap recommended in the
Proposed Plan. In support of their recommendation they cite
Illinois Environmental Protection Act Subtitle G Section
807.305. which states that only 2 feet or more of compacted
material is needed to cover a landfill.
RESPONSE:
It should be pointed out that Section 807.305 deals with
minimum requirements for the closure of sanitary landfills.
Because hazardous constituents were disposed of in the
landfill and are curr.ently being released to the groundwater,
it has been determined that RCRA Subtitle C closure
requirements are both relevant and appropriate at this site.
Therefore, the cap to be placed over the Belvidere Landfill
must be compliant with RCRA Subtitle C capping requirements.
These requirements are performance based. Capping contruction
is not required to be exactly as presented in the FS. The
exact characteristics of the cap will be determined during
design.
COJ+1ENT:
The ARC questioned the need for an active gas extraction'
system for the landfill cap.
RESPONSE:
The recommended alternative calls for a passive vapor
extraction system. not an active system.
COtH:NT:
The ARC' suggests that the thickness of the frost protection
layer be increased to 36 inches and consider that this will
provide an additional level of flood protection.
RESPONSE:
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-22-
Therefore, a 36 inch frost protection layer is a minimum
thickness. Additional cap thickness would be necessary to
ensure the cap 's perfonnance duri ng a 100- year f1 ood event.
4. Genera 1 Ccmuents
")
COtI£HT :
The ARC commented that there were a number of shortcomings in
the RI and FS documents. They conclude, however, that these
problems do not materially effect the decision for the need
for remediation on-site. However, ARC does suggest that most
of the data generated during the RI/FS process should not be
used for the final design of the adopted remedy.
RESPONSE:
The Agencies feel that this is not actually a shortcoming of
the data. The primary purpose of the data generated during
the RI is for use in developing a PH&EA and remedial
alternatives; it is assumed that additional analyses will be
necessary to aid in the design of the adopted remedy. These
additional studies may include a pump test to better define
.the aquifer characteristics and treatability studies to
detennine compatibility of the waste stream with the treatment
plant.
COff4ENT :
The ARC states that the available documentation for the
Belvidere MuniCipal Landfill site was reviewed over the period
of June 2 to June 6, 1988.
RESPONSE:
The Agencies woul d 1 i ke to poi nt that all of the data for this
site was made available for pUblic revf.ew and cOl11Tlent from
May 2 to June 6, 1988.
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ADDENDUM TO TIiE RESPONSIVENESS SUr-tCARY
"
The public comment period for the Belvidere Municipal Landfill site started
May 2, 1988 and ended June 6, 1988. The ARC was made aware of this cOlt111ent
period through the publication of the Proposed Plan and in an April 15, 1988
letter from U.S. EPA (Mr. Tim Conway) to the ARC (Mr. Jerry Homsy). However,
on June 23, 1988, The ARC submitted an additional set of comments on the
Belvidere Municipal Landfill Proposed Plan. These late comments serve to
clarify previous comments made by the ARC on their choice of a cap for the
landfi 11 .
Although U.S. EPA is under no obligation to review these comments, a review
was made by the Agency. In response, the Agencies stand by the decision
expressed in the ~ecord of Decision (page 32) and in the Responsiveness
Summary (page 21) which states that the cap will be RCRA Subtitle C compliant.
The specific design characteristics of this cap will be determined in the -
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APPfH)IX B
BELVIDERE rotJNICIPAL 00. 1 tm)FIIL
'AD1INIS'l'RATIVE RFIDRD Dl)EX
as of June 27. 1988
~~
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,
APPENDIX C
BElYIDERE.MUNICIPAL NO.1 LANDFILL
STATE OF ILLINOIS LETTER OF CONCURRENCE.
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.
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Illinois Environmental Protection Ag~ncy
2200 Churchill Road. Springfield. IL 62706
217/782-6761
.
Refer to: . L0070050001 -- Boone County
Belvidere Municipal No. 1 Landfil~ - Belvidere
Superfund - Enforcement
June 22, 1988
STATE OF ILLINOIS - RECORD OF DECISION
Site Name and Location
Belvidere Municipal No.1 Landfill
Belvidere, Boone County, Illinois
Statement of Basis and Purpose
This decision document represents the State of Illinois' decision, through the
Illinois Environmental Protection Agency, to select the remedial action as
outlined in the Record of Decision and the Declaration for the Record of
Decision issued in connection with the above-captioned matter. The selected
remedial action for the above reference site ~as developed in accordance with
the Comprehensive Environmental Response. Compensation and Liability Act
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA). and to the extent practicable. the National Oil and Hazardous
Substances Pollution Control Act (NCP). The attached Index identifies the
documents which comprise the administrative record upon which the selection of
the remedial alternative is based.
Description of the Remedy
This remedy addresses the source of the contamination by containing the
on-site wastes and contaminated soils and extracting and treating the
contaminated groundwater. The function of this remedy is to seal off the
surface of the Belvidere Landfill to reduce the risk associated with contact
and exposure to the contaminated material and reduce the amount of water
infiltration throu~h the surface which would otheniise contribute to
groundwater contamlnation. In addition the selected remedy will reduce the
risk associated with exposure to contaminated groundwater.
The major components of the selected remedy include:
Capping the 19-acre landfill in accordance with the Resource Conservation
and Recove~ Act (RCRA) requirements;
Installation of a plume barrier groundwater extraction and treatment
system;
Installation of a security fence. around the perimeter of the site;
Groundwater monitoring to ensure the effectiveness of the remedial action;
Deed restrictions. .
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Illinois Environmental Protection A~ency
2~OO Chun"hill Road. Springfield. IL 62706
Page 2
Decl arati on
The selected remedy is protective of human health and the environment, attains
federal and State requirements that are applicable or relevant and appropriate
(ARARs), and is cost-effective. This remedy utilizes pennanent solutions and
alternative treatment technologies to the maximum extent practicable for this
site. However, because treatment of the principal threats at the site was
found not to be practicable, this remedy does not satisfy the statutory
preference for treatment as a principal element of the remedy. The size of
the landfill and the fact that there are no on-site hot spots that represent
the major sources of contamination preclude a remedy in which contaminants
effectively could be excavated and treated.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted within five years (as
mandated by CERCLA and SARA) after commencement of the remedial action to
ensure that the remedy continues to provide adequate protection of human
health and the environment.
In the event that the.negotiations conducted by the USEPA and IEPA with the
pctentially responsible parties fail to achieve the desired result, a
fund-financed remedial action may be unavoidable. In this event, the
cost-effectiveness of the selected remedy enables the State to favorably
consider a 50% match fund financed remediation. The State's final position on
this subject will be formulated at the close of the PRP negotiations period. -
~f-~/8g
Date '
Mf?~ .
Actlng Dlrector -
Illino;s Environmental Protection Agency
JL/jab/1B24j/42-43
Attachment:
Administrative Record Index
)
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~
Illinois Environmental Protection Agency. P.O. Box 19276, Sprinctleld,lL 62794.9276 .
INDEX OF THE ADMINISTRATIVE RECORD
\.
. Preliminary Assessment Report (PA)
. Site Investigation Report (SI)
Removal Documents (on-scene coordination report)
. QA/QC Date from Laboratory (at IEPAt LPC files)
. Date Summary Sheets (Refer to Remedial Investigation)
. Chain of Custody forms (at IEPAt LCP files)
. Quality Assurance PrOject Plan (QAPP)
. Supplemental QAPP Private Wells
. Supplemental QAPP Fish Flesh
Initial Work Plan (Initial Scope of Work)
. Amendments to SOW
. Remedial Investigation (RI)
Feasibility Study (FS)
. ARARs Array
Community Relations Plan
Public Health and Environmental Assessment
. ATSDR Health Assessment
PRP Notices and Information
Public Comment (RI/FS) - Illinois Department of Public
Response to Public Comment - Responsiveness Summary
. Transcript of Public Meeting
Record of Decision (ROO)
. Amendments to ROO (if applicable)
. Administrative Order
. Consent Decree
. Affidavits
Health
JL:pss
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