United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R05-91/168
December 1990
SEPA Superfund
Record of Decision:
-------
50272-101
REPORT DOCUMENTA110N 11. AEPOATNO.
PAGE EPA/ROD/ROS-91/168
1 ~
3. A8c1pIent'a Acceaalon No.
.. 1IIe and Sub1I1Ie
SUPERFUND RECORD OF DECISION
Acme Solvent Reclaiming, IL
Second Remedial Action
7. AulhOl'(a)
5. Report Date
12/31/90
8.
8. I'8rfonnlng Organlza1lon Aept. No.
I. P8rfonnIng Orgalnbdon Mana and Add....
.
10. Proj8ctITuklWork UnIt No.
11. Contract(C) or Grant(G) No.
(C)
(G)
1~ 8ponaortng 0rpnIDII0n Mana and Addreaa
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of A8PQrt . Period Coyered
Agency
800/000
14.
15. SupplemanWy No"a
18. Abatract (UmIt: 200 _rda)
The 20-acre Acme Solvent Reclaiming site is a former industrial disposal site in
Winnebago County, Illinois. Land use in the area is mixed agricultural and
residential. The site is bounded by an active quarry to the north, farmland to the
south and east, and the Pagel's Pit Superfund site to the west. An onsite stream,
which is a tributary of Kilbuck Creek, eventually drains into the Rock River to the
south. The site overlies two aquifers, which are used by the estimated 400 residents
who live within 2 miles of the site as their drinking water supply. From 1960 to 1973,
Acme Solvent Reclaiming disposed of paints, oils, and still bottoms onsite from its
solvent reclamation plant. Wastes were dumped into depressions created from previous
quarrying and landscaping operations, and empty drums also were stored onsite. State
investigations in 1981 identified elevated levels of chlorinated organic compounds in
ground water. A 1985 Record of Decision (ROD) provided for excavation and onsite
incineration of 26,000 cubic yards of contaminated soil and sludge, supplying home
carbon treatment units to affected residences, and further study of ground water and
bedrock. During illegal removal actions taken by PRPs in 1986, 40,000 tons of soil and
sludge were removed from the site. A 4,000-ton waste pile and 2 tanks containing
(See At~ached Page)
17. DocumInt AnaJyala L, DeacrIpcota
Record of Decision - Acme Solvent Reclaiming, IL
Second Remedial Action
Contaminated Media: soil, sludge, gw
Key Contaminants: VOCs (benzene, PCE, TCE, xylenes), other organics (PCBs), metals
(arsenic, chromium, lead)
b. IdIntifleralOpan-Endad T-
Co COSAl1 R8IdIGroup
18. AYlilabiity SI8I8mant
11. S8cwtty Cia.. (ThIa Report)
None
20. S8cwtty CIaaa (ThIa Page)
N'nn~
21. No. 01 Pages
93
I
n Price
(See ANSl-Z3I.18)
See IfI8f:ruCfi- on ~-
-
'''1
(Formet1y NT1S-35)
-------
EPA/ROD/ROS-91/168
Acme Solvent Reclaiming, IL
Second Remedial Action
Abstract (Continued)
contaminated liquids remain onsite, and since then an additional 2,000 tons of onsite
contaminated soil and sludge has been discovered. This ROD will address waste areas
remaining after the 1986 removal, including soil, bedrock, and ground water, as part of
OU2. A future ROD will address an area of ground water contamination between the Acme
Solvent Reclaiming and Pagel's Pit sites as OU3. The primary contaminants of concern
affecting the soil, sludge, and ground water are VOCs including benzene, PCE, TCE, and
xylenes; other organics including PCBs; and metals including arsenic, chromium, and
lead.
The selected remedial action for this site includes excavating and treating 6,000 tons
of soil and sludge from two waste areas, using low-temperature thermal strippi~g;
treating residuals using solidification, if necessary, followed by onsite or offsite
disposal; treating the remaining contaminated soil and possib1y bedrock using
soil/bedrock vapor extraction; consolidating the remaining contaminated soil onsite with
any treatment residuals, followed by capping; incinerating offsite 8,000 gallons of
liquids and sludge from two remaining tanks, and disposing of the tanks offsite;
providing an alternate water supply to residents with cont~inated wells; pumping and
onsite treatment of VOC-contaminated ground water with discharge to surface water;
monitoring ground water; and implementing institutional controls including deed and
ground water use restrictions. The estimated present worth cost for this remedial
action ranges from $14,633,000 to $16,233,000, which includes an annual O&M cost of
$908,400.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific cleanup goals for soil are based on a
lifetime excess cancer risk level of 1 x 10-5. All waste area soil exceeding
PCBs 10 mg/kg must be excavated and treated. In addition, all soil exceeding 10 mg/kg
above, background levels using a photoionization device will be excavated. Any soils
remaining after excavation and residuals lan~filled onsite must meet the site-specific
VOC cleanup standards including benzene 69 ug/kg, TCE 140 ug/kg, and PCE 1,200 ug/kg.
Chemical-specific cleanup goals for ground water are based on SDWA MCLs and MCLGs, as
well ,as 10-5 excess cancer risk criteria, and include benzene 5 ug/l (MCL), PCE 5 ug/l
-------
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Acme Solvent Reclaiming, Inc.
~innebago County, Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action
for the Acme Solvent Reclaiming, Inc. site in Winnebago County,
Illinois. This action was chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the. extent
.practicable, with the National oil and Hazardous Substances
Contingency Plan (NCP). This decision is based on the
Administrative Record for this site.
The State of Illinois is expected to concur with the selected
remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in. this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
This remedy is the second of three potential operable units at
the site. The first operable unit ROD called for excavation and
incineration of soil, sludge, and other waste materials buried at
the site. Instead, approximately 90 percent of these materials
were excavated and disposed of in a hazardous waste landfill
without the consent of USEPA or IEPA and approximately 10 percent
remains on-site. Home carbon treatment units were provided to
residents affected by site contamination, and additional studies
were performed at the site under that ROD.
This second operable unit remedial action provides for treatment
of the principal threats posed by contaminants in waste areas,
soils, bedrock, and groundwater. Remaining risks at the site are
reduced by engineering controls. A potential third operable unit
will address an area of groundwater contamination between this
and another Superfund site when additional studies have been
completed to determine the source of this contamination.
The major components of the selected remedy include:
- Excavation of soils and sludges in two waste areas and
-------
2
Further treatment of residuals, if necessary, by
solidification and on-site or off-site disposal.
Incineration of the liquids and sludges in two tanks
remaining on the site and disposal of the tanks.
provision of a permanent alternate water supply to residents
with contaminated wells.
- Extraction and treatment of VOC-contaminated groundwater and
discharge to surface water.
- Treatment of remaining VOC-contaminated soils and, if
possible, bedrock by soil/bedrock vapor extraction.
- Consolidation of soils with remaining SVOC, PCB, and lead
contamination and covering these soils and areas where. '
residuals are landfilled on-site with a RCRA Subtitle C,
compliant cap. '
- Long term groundwater monitoring.
- Fencing ~he site and providing, to the extent possible,'~eed
and access restrictions and deed notices or advisories for
residences with contaminated groundwater. '
STATUTORY DETERMINATIONS
The selected 'remedy is protective of human, health and :the
environment, .complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the, ,
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable and satisfies the statutory ,
preference for remedies which employ treatment that reduces '.>'
toxicity, mobility~ or volume as a principal element.
Because this :remedy will ,result in, hazardous substances rema:ining:
on-site above health-based ~levels,' a,r:eview will be' conducted at
least every five years after commencement ,of the remedial action'
to ensure that the remedy continues to provide adequate '
protection of human health and the environment.
I,~ '~-/' ~n
'c-,,/'~ ./ ~
,.' / L)
-------
RECORD OF DECISION SUMMARY
ACME SOLVENT RECLAIMING, INC.
I.
SITE LOCATION AND DESCRIPTION
The Acme Solvent Reclaiming, Inc. site is located at 8400
Lindenwood Road, approximately five miles south of Rockford,
Winnebago County, in northern Illinois (see Fig. 1). The site
consists of approximately 20 acres of rolling uplands in a
predominantly rural area. The only features on the site are a
soil mound remaining from a previous removal operation, two
8,000 gallon tanks containing liquids and sludges, and a fenced
decontamination area built during the site investigation.
Land around the site is used for agriculture, quarrying, and low-
density, single family residences. The site is bounded by an .
active quarry to the north and farmland to the south and east.
Immediately to the west is another Superfund site, Pagel's Pit
Landfill (also known as Winnebago Reclamation Landfill) . . An
ongoing remedial investigation/feasibility study (RI/FS) at
Pagel's Pit is expected to be completed in 1991.
Approximately 400 people live within two miles of the site. The
closest dpwngradient residences to the site are approximately 14
homes on Lindenwood and Edson Roads, with the nearest residence
approximately one quarter mile from waste disposal areas. All
residences in the area use private wells for their water supply.
An intermittent stream runs across and to the south of the site.
The stream is a tributary to Killbuck Creek, which drains to the
Kishwaukee River, then the Rock River. With the exception of the
Rock River, surface waters downstream of the site are not used
for public water supply. There are no floodplains, wetlands,
critical habitats, or endangered species on or near the site.
The site is underlain by a thin layer of unconsolidated deposits.
The unconsolidated deposits overlie the dolomites of the
Platteville and Galena Groups. These dolomites, and the
saturated unconsolidated deposits, comprise the Galena-
Platteville aquifer. The Galena-Platteville aquifer has been
classified as a Class II aquifer under United States
Environmental Protection Agency's (USEPA's) Groundwater
Protection Strategy and is extensively pumped by residential-
supply wells in northern Illinois. The Galena and Platteville
dolomites are underlain by the dolomitic shales and sandstones of
the Glenwood Formation, a semi-confining unit which separates the
overlying Galena-Platteville aquifer and the underlying st. Peter
Sandstone aquifer. The st. Peter Sandstone aquifer is also a
Class II aquifer and is extensively pumped for domestic, .
-------
l Not To Scala ,"'''~E~ ao.ul-""., '" """", ! '
~ : i
I.
N . Rockford Blacktop" .
I /) '~\" r!~;~?:t:~~ "
~,.,~''----i I I ..
rl .-.-.-1' ''''-.-! : '.. I'
--r--< I '
. AFme Solvents Site . ..:..J
e . 0 J ~
. rl..... /8 ~ ',~ .' ,,/. .
jIo~ ,. "'- --./.: \'1 r . ...J-~'--'" .
~. I APPROXIMATE. 0 .. "" APPROXIMATE:~
,-C FENCE LINE' 0 P~OPERTY LIN.E .
- . ;a~~': ;17--- ~ INTE'~'~ITTENT '.
0. APproXlmat..~---=:] Z ", ' TRI. UT AR' TO
~ Boundary' ~ KILLB UCK CREEK.
':...r-~' . ""-- ~,' .
WINN'iB AG 0 pOU .Y . - EDSON AO~~--.-"""" .~
OGLE COUNTY:; A........ur." --
ILLINOIS
.~.~
-
EXPLANATION
I ipl STI Study Area
"
= Hardlftil LaW80ft A"Oclate. Sit. Location Map FIGU
Engineers. Geologists 1
& Geophysicists Acme Solvents Reclaiming, Inc.., Site
Winnebago County, illinois
DRAWN JOB NUIoABER APPROvEO OAn REVISEO CATE
AT' Jr. 17683,010.10 11/86
I
-------
2
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
.
From 1960 to 1973, the Acme Solvents site served as a disposal
site for paints, oils, and still bottoms from the Acme Solvent
Reclaiming, Inc. solvent reclamation plant in Rockford, Illinois.
Wastes were dumped into depressions created from previous
quarrying operations or by scraping overburden from the near
surface bedrock to form berms. Empty drums were also stored at
the site.
In September 1972, the Illinois Pollution Control Board (IPCB)
ordered the operator to remove all drums and wastes from the
site and to backfill the lagoons after the removal. Followup
inspections subsequent to this Order revealed that the wastes and
crushed drums were being left on site and covered. with soil.
Releases from the facility were first documented in 1981 when
downgradient residents complained of poor smelling drinking
water from private wells. Sampling and analysis of well water
showed chlorinated organic compounds at concentrations exceeding
the USEPA's Health Advisories for drinking water. The Illinois
Environmental Protection Agency (IEPA) recommended that these
wells not be used, and in 1981 the owner of Pagel's pit Landfill
agreed to voluntarily supply affected residents with bottled
water.
The Acme Solvents site was proposed to the National Priorities
List (NPL) in 1982 and was included on the final NPL in September
.1983. IEPA completed an RI/FS in 1984, and on September 27,
1985, USEPA signed a Record of Decision (ROD) to excavate an
estimated 26,000 cubic yards (cy) of contaminated soils and
sludges and treat them by on-site incineration. The ROD also
called for provision of home carbon treatment units (HCTUs)to
reside~ts affected by site contamination and for further study of
the groundwater and bedrock.
.
USEPA attempted to negotiate an agreement to implement the ROD
with approximately 65 Potentially Responsible Parties, (PRPs),
including the site owner/operators and several generators. USEPA
and the PRPs were not able to reach an agreement. Instead, a
consortium of 23 PRPs chose to disregard USEPA's ROD and to
excavate and transport sludges and soils to permitted hazardous
waste landfills. This action resulted in the inclusion of a new
provision in the Superfund Amendments and Reauthorization Act of
1986, prohibiting unauthorized remedial actions by PRPs.
The PRP action was terminated in November 1986 when USEPA's Land
Disposal Restrictions (LDRs), which prohibited land disposal of
solvent- and dioxin-contaminated waste without treatment, went
into effect. The PRP action removed approximately 40,000 tons of
soil and sludge from the site, or an estimated 90 percent of the
-------
3
ton waste pile and two tanks containing contaminated liquids and
sludges remained at the site. Since then, an additional waste
.area containing approximately 2,000 tons of soils and sludges has
been discovered.
In December 1986, 23 PRPs
and IEPA to further study
groundwater contamination
affected residents.
entered into a Consent Order with USEPA
the remaining soil, bedrock, and
and to provide HCTUs and monitoring to
Under this Consent Order, Harding Lawson Associates (HLA), a.
consultant .for the PRPs, completed a Supplemental Technical
Investigation (STI) in May 1990, an Endangerment Assessment (EA)
in June 1990, and a Remedial Action Alternatives Evaluation
(RAAE) in September 1990. HLA also completed an Engineering.
Evaluation/Cost Analysis (EE/CA) in August 1990 to evaluate
alternatives to address the remaining waste areas and:the two.
tanks (see Fig. 2). .
USEPA issued general notice letters on June 9, 1990, informing.
PRPs of USEPA's intent to negotiate a remedial action for this
site. Special notice letters will be issued and negotiati.ons
will begin after completion of this Record of Decision.
III.
COMMUNITY RELATIONS ACTIVITIES
USEPA and IEPA have been conducting community relations
activities at the site since early 1983. During the original
RI/FS, IEPA developed a community relations plan, and in .
accordance with that plan, IEPA conducted small group me'et'ings,
public meetings, and issued fact sheets and letters to .
residents. USEPA has conducted community relations activities'
since the start of the STI in 1986.
A proposed plan was released to t'he public on October 5'" 199.0" .
'informing residents, that .th'e STI report, EE/CA, and RAAE, .along
'with. other documents comprising the Administrative Record for ,the
site, were available at the public information repository :at: 't'he .
Rockford Public Library. The Administrative Record dndexis: ,. .
included as Appendix A. A public comment:period was' held from
October 5, 1990, to November 5, 1990, and a public meeting was
held on October 18, 1990, to discuss the proposed remedial'. .
action with residents. Public comments ,and USEPA responses' are
included as Appendix B. .
IV.
SCOPE AND ROLE OF 'RESPONSE ACTION:
This response. action is the second: of: three potenti'al operable
units. The first operable unit, set .forth in the S'eptember 198.5 .
ROD, called for provision of an interim alternate water supply
(HCTUs) to downgradient affected residents, and treatment 'of the
-------
---
--- --------- ----- -----
'...
EXPLANATION
'--
",
Approxlmale Boundary 0' Excevated Wasle Mounds
~
..
Remaining Soli/Sludge Area (Approximate Locations'
Approxlmale locallon 01 Two Tanks Containing Sludga
~
!
Harding tAw.on A..oolet..
Engineering end
: = : = ': Envlronmenlal S,rvlcu
. .....£..
....- .
.... .--
o
I
150
.
Scale In Feet
DR*"
RLB
JOe NUMBER
11683,020.10
75
-.-_._- ----...
o
o
]---
-----------
-_/
APPROXIMATE PROPERTY BOUNDARY
. .
Previous Waate Mound Locations
and Remaining Soli/Sludge Are..
Acme Solvents Reclaiming, Inc., Site
Wlnnebago County, illinois
A-r'? .~
," .....
DATE
2/90
FIGURE
2
-------
4
action has been completed. The waste disposal areas, however,
were not remediated in a manner consistent with USEPA's ROD, and
approximately 6,000 tons of soil/sludge were not addressed during
the PRP cleanup.
This operable unit will address the remaining waste disposal
areas as well as all remaining soil and bedrock contamination
on-site. Contaminated groundwater will also be addressed except
as discussed below. '
The third and final operable unit will address an area of
groundwater contamination at the southeast corner of Pagel's Pit
Landfill if it is determined that Acme Solvents is wholly or
partially responsible for this contamination. Further studies
are needed to determine the source of this contamination, and a,
ROD will address this area as soon as USEPA has determined the
source of this contamination.
v.
SITE CHARACTERIZATION
Results Qf the STI have shown that groundwater, soil, and
subsurface bedrock on and around the Acme Solvent site have been
contaminated. Volatile organic compounds (VOCs)'are the
principal contaminants found in all affected media. Semi-
volatile organic compounds (SVOCs), polychlorinated biphenyls
(PCBs)', and inorganic contaminants have also been detected in',
soils and waste areas.
Waste Areas,
The STI identified two remaining waste disposal areas on~site,
(see Fig. 2). The first waste area consists of approximately
4,000 tons of soil and sludges and is located in approximately
the center of the site. TwC) BOOO-gallon storage tanks ,containing
liquids and sludges are also present near this area. sampling in'
this area was performed during the PRP removal action>in 1986
without USEPA.supervision. Waste area samples showed total VOCs
as high as 14,,700 mg/kg and total PCB's as high as 52 mg/kg.
Sampling of tank contents'showed PCBs' as high as 138 mg/kg,and
lead as high as 2,BOO mg/kg. EP Toxicity testing of tank '"
contents showed levels below regulatory standards. These data
are not included in- the data summary tables because USEPA has 'no"
information about its quality. '
During the course of the STI, a second approximately 200 by',. ,
40-foot waste area :was discovered in the northwest corner, of the -"
Acme site:. Fifty-six samples were collected from 29'test pits
and approximately 100 rusted one-gall~n pails were removed in -
1990. VOCs, SVOCs, and PCBs were detected in test pit samples.
Metals were detected above background levels in all samples (see
-------
-
mmB1
CXJfIMIHAHl'S r)~I"I'J. ~I,)<] J IN oon,
R:RIHiEST ARm
CDrt:aminants JbYi1l811ft F1:equen::y of ~vai~
Detected a... ~1LLcSt..ic;n1 Detecticit2
VCCs (~/kg)
l,l,l-Trichloroethane 10 1/56 NA
l,2-Dichloroethene 44,000 6/56 NA
Carbon Disulfide 0.5 6/56 NA
Chloroform 3 1/56 NA
Chloranethane 2 1/56 NA
Ethylbenzene 290,000 7/56 NA
Tetrachloroethene 31,000 33/56 NA
Total Xylenes 1,500,000 9/56 NA
Trich.loroethene 4,500 11/56 NA
S\IOCs (~/kg)
2-Methylnaphthalene 8,600 3/7 NA
Bis (2-ethy1hexyl) phthalate 1,300,000 7/7 NA
Butylbenzyl phthalate 190,000 4/7 NA
Di -n-wtyl phthalate 480,000 4/7 NA
Isophorone 14,000 1/7 NA
Naphthalene 320,000 4/7 NA
Phenol 180 1/7 NA-
Prns (~/kg)
Total PCBs 290,000 6/7 NA
Inaraanics (Dg/kg)
Aluminum 17,900 6/7 2,500
Arsenic 20.9 6/7 3.5
Barium 1,190 6/7 22
O1rornium 14,500 7/7 5.9
Iron 54,900 NA4 NA
lead 52,500 7/7 9.1
-------
DBI:B 1 (Om't)
AIL OJBER s:>ns
CkI1taminants )l;nn1lllWII Frequen::y of Badcgrourxi".
Detected a.. JLA:2 .LLciti.a1 Detecticn Value
~ (ug/kg) . I',
1,2-Dic::hloroethene 6,000 2/21 NA
(cis and trans)
1, 1, 1-Tric::hloroethane 5.50 1/21 NA
Tric::hloroethene 3,100 1/21 NA
i 4-Methyl-2-pentanone 7,400 2/21 NA
~ Tetrac::hloroethene 3,400 5/21 NA
Ethylbenzene 29, 000 . 2/21 NA
'Ibtal Xylenes 210,000 4/21 NA
S\1CQ; (ug/kg)
Isophorone 1,035 2/21 NA
Naphthalene 170 1/21 NA
Phenanthrene 180 2/21 .NA.
2-Methylnaphthalene 130 3/21 NA
Fluoranthene 7 1/21 NA
Pyrene 62 4/21 NA
Benz 0 (b) fluoranthene 8 .. 1/21 NA
Di-n-b..1tylphthalate 13,000 1/21 NA
Bis (2-ethylhexyl) phthalate 59,000 7/21 NA
PCB; (ug/kg)
Aroclor-1254 4,000 4/21 NA.
Inarclanics (Dg/kg)
Aluminum 6,700 21/21 2,500
Arsenic 8.8 21/21 3.5
Barium 230 21/21 22
Chromium 260 21/21 5.9
Lead 2,800 21/21 9.1
zinc 220 21/21 8.5,
1Data qualifiers, not included .
2For inorganics,' indicates detection above' established background:, . .
3Background established from one soil sanple taken from the eastern portion: of
the site, in an area unaffected by disposal operations'
,4Background value for iron not established
NA = not available:
-------
.
5
An estimated 2,000 tons of soils and sludges is present in the
northwest area. A total of approximately 6,000 tons of soill
sludge material remains on-site in the two waste areas. Most
contaminant concentrations were one to two orders of magnitude
higher in the waste areas than in other site soils.
Soil Investigation
Immediately after the 1986 removal, soil samples were collected
(without USEPA or IEPA supervision) from sidewalls, stockpiled
soils, backfilled soils, and exposed bedrock. Analytical results
of soil samples indicated total VOC concentrations from 0.6 - 275
mg/kg; and total SVOC concentrations from 0.1 - 330 mg/kg. .
Results of bedrock samples for total VOCs ranged from 0.6 - 1600
mg/kg and for total SVOCs from 180 - 5320 mg/kg. . The primary
VOCs identified in these soil and bedrock samples were
tetrachloroethene (PCE), 1,1,1 trichloroethane (lll-TCA),
trichloroethene (TCE), total xylenes, toluene, and ethylbenzene.
The primary SVOCs identified were isophorone, naphthalene, and
phenol. These data were not included in Table 1 because USEPA
has no information about its quality.
In 1988, 21 composite and discrete soil samples were collected
within and adjacent to the waste areas excavated in 1986.
Results are summarized in Table 1. Nine VOCs, seven SVOCs, and
PCBs were detected. Six metals exceeded background
concentrations.
Bedrock Gas
Twelve bedrock gas probes were installed in five angled coreholes
beneath previously excavated waste areas. Probes were sampled
quarterly for one year to determine VOC concentrations in the
bedrock gas. Nine VOCs were detected. PCE, TCE, and TCA were
detected in the highest concentrations and greatest frequency in
all 12 bedrock gas probes (see Fig. 3). .
Hvdroqeoloav
The following geologic units exist below the Acme Solvents site
and surrounding area:
.
Unconsolidated deposits
Galena-Platteville Dolomite
Glenwood Formation
St. Peter Sandstone Formation
Unconsolidated deposits range from 0 to 6 feet in thickness under
the Site, increasing to about 85 feet south of the Acme Site, and
are unsaturated under the site. The Galena-Platteville aquifer,
which is approximately 220 feet thick, and the st. Peter
-------
C"'-
PCE
TCE
TCA
8H ID lIP
0." 0.14 0.38
0.31 0.27 0.35
0.31 0.10 0.35
~
j
o '00
CIo- -
Approll"'.'. Sco'O If! FO"
i5 C'::1c8I
TCE
TCA
AC-4
[!}--
..--./--
PCE
TCE
T.Ir8C_-~- --.{!)
T,Ic__-
1. I. I-Trtc-_-
TCA
~
ltW
--...... ",
r.v-mo ..,
--
Df'AIIIN
RLB
.
..
..
~
.ID8 ..........
t7881.020.10
lit IHIID I DI DI' lIP
1.1 0." I.' 1.0
0.11 O.OUJ,D 1.011 0."
0.11 o. liD 0.10 0."
EVC......1eo1
. PCE
AC..S TCE
, TCA
lit
U
0.:11
1.0
DI'
10
1.7
4.1
---
.---
I!XPLANAnOH
18droOtI Care Halo lOC8ttOll _'''11 DI,octIOll of Drilling
Approo''''at. I'lol""811, Nloctod "'.. IIoundI"H
lit
ID
""1"" DopI~ Inl..81
1fItorrn8CII818 D8Pt~ Int..81
lIP
D
Doop D8Pt~ Inl...81
~ound DoIoctod
AI' Vop.. PlIo.. ~I..dOllI 'n pp"".'.'
J
EII''''atod concont,otlon II .. 1>8''''' ,... CAOl
88drocll Cor. Hol. LoC8t1on. wI'"
V.pot Conconlr.'I- o' VOC.
Acm8 SoIvenl. Roc:IalminG Inc.. SI'. .
Wlnnlb8ao Coun'y. IIUnoll
AI'PfIIOV(O . DATI "EYlnD DA ,.
I..:. ...... . 4110 .
. 111
-------
6
are considered the two major hydrostratigraphic units (HSU)
beneath the site. The Galena-Platteville HSUand st. Peter
Sandstone HSU are separated by the Glenwood Formation. The
Glenwood Formation is comprised of interbedded dolomitic shale
and quartz sandstone. It has an average thickness of 40 feet and
is moderately to little fractured, with the exception of the
basal beds, which are highly fractured. The Glenwood Formation
partially restricts flow between the two HSUs. Unconfined flow
within the Galena-Platteville aquifer is generally to the west
and south through fractures and solution features. Such flow can
be difficult to characterize and is generally complex. Confined
flow in the st. Peter Sandstone aquifer is intergranular. A
typical water table map for the Galena-Platteville aquifer is
shown in Fig. 4.
Beginning in 1988, groundwater samples were collected from new
and previously installed monitoring wells. These included 28
wells completed in the Galena-Platteville aquifer, and four wells
completed in the st. Peter Sandstone aquifer. Additionally,
beginning in 1987, groundwater samples were taken from private
water supply wells at 16 residences, including the five
residences where HCTUs were installed. .
Twelve VOCs, seven SVOCs, and three metals (above background)
were detected in the Galena-Platteville monitoring wells (see
Table 2). Figure 5 shows the distribution of 1,2-dichloroethene,
the contaminant found most extensively in the Galena-Platteville
aquifer. Ten VOCs were detected in the residential water supply
wells (see Table 2). Of the four wells completed in the st.
Peter Sandstone aquifer, only MW201A showed VOC contamination.
This well is screened mostly through the Glenwood Formation; the
screen extends only a few feet into the st. Peter aquifer. Only
low levels of VOCs were found in MW210A, and no VOC contamination
was found in any of the other St. Peter wells (see Table 2).
contaminant Miaration
Sampling data verified that sludge material in waste areas has
contaminated near-surface soils. Additionally, the bedrock gas
sampling program conducted in Galena-Platteville subsurface
fractures has documented bedrock gas contamination from either
the leaching of contaminants through ~oils into fractures or
diffusion and volatilization of contaminated groundwater into
fractures, or both. Bedrock gas VOC concentrations were
somewhat higher than would be predicted by volatilization of VOCs
from groundwater, indicating that VOCs in bedrock gas may
contribute to groundwater contamination.
Subsequent leaching of VOCs has affected groundwater in the
Galena-Platteville aquifer and produced contaminant plumes which
are migrating off-site. Elevated levels of SVOCs.and metals were
-------
..
8.~ "L.
~
o
"
1:"'
.~
"-
'\ .
'\:
'\
'10.
"
\
- \.
\
:=t-
\
,
. -=-- )
---
-~-
...." ---~----
. I11III ----
,
=--
--
'--
....... ... ....o4.M8I
--
--..
---,.
-
--
-
~
.-
...
-. .
-~~ _...
-------
~2
cnn»fiNANI'S Dtan:J.'.W IN GR:X.IUrlATER
~-PI.ATIEVIIZE
amtaminants ~1111'811 FrequED;:y of Bat~~
Detected a.. ~1l.Lat.i.crt1 Detect.im
VCCs (uq/l)
Vinyl Chloride 1000 13/118 NA
1,2-Dichloroethene 2400 40/118 NA
1,1-Dichloroethene 28 18/118 NA
1,1-Dichloroethane 405 23/~18 NA
1,2-Dichloroethane 42 5/.1.18 NA
1,1, 1 ~ichloroethane 265 32/~18 NA
1,2-Dichloropropane 29 14/118 NA
Trichloroethene 260 3~/118 NA
Benzene 39 12/118 NA
Tetrachloroethene 480 39/118 NA
Ethylbenzene 170 9/118. NA
Total Xylenes 1100 1/118 NA
SVOQ; (u;J/l)
Phenol 35 ~/118 NA
1,4-Dichlorobenzene 15 8/118 NA
1,2-Dichlorobenzene 1 2/118 NA.
Isophorene 4 3/118 NA
Benzoic Acid 2 1/118 NA
Naphthalene 13 8/118 NA
N~Nitrosodiphenylarnine 1 1/118 NA
Inarclanics (1II}/1)
Arsenic 0.038 55/118 <0.001 - 0.008
Barium 0.396 40/118 <0.05 - 0.13
au-omium . 0.032 1/118 <0.01 - 0.032
Iron 11.0 23/118 <0.10 - 0.26
Lead 0.015 10/118 <0.005 - 0.005
-------
~illFm'IAL nJfIRFATfD)
cmtaminants
Detect-m
VCCs CUl/l)
Vinyl Chloride
1, 1-Dic::hloroethene
1,1-Dic::hloroethane
1,2-Dich10r0ethene
1, 1, 1-Tric::hloroethane
1,2-Dic::hloropropane
Tric::hloroethene
Benzene
, Tetrac::hloroethene
Chlorobenzene
Imraanics
Arsenic
Barium
C1ramium
Iron
lead
Zinc
CDI1/l)
fIr. PEI'ER
VCCs CUl/l) ,
1,2-Dichloroethene
Trichloroethene
Inr::1rcJani.cs
Arsenic
Barium .
Zinc
CDI1/l)
TABL£ 2 CCD1't)
)1;:n';1181111
a.. ~ .lulticn
8
2.5
14
170 .
12
2
13
2
10
1
0.002
0.198
0.010
0.921
:0.033
0.593
8
6
. 0.003
0.104
1.69
Frequen::y of
Detecticn
14/75
4/75
28/75
58/75
42/75
15/75
42/75
6/75
58/75
4/75
1/46
30/46
1/46
13/46
5/46
22/46
4/22
4/22
2/22
6/22
17/22
1Data.qualifiers'not included.' .
2'Ihe backgroun:l range for the Galena-Platteville aquifer was . .
established from samples takenfran the STI-1, STI-3, and SI'1-4"
well clusters (see Fig. 5) .
NA = not available'
-------
....nlll ......
""'"'
......" WEt&.
..:;:--
....
~
--,-_..f
~..-_...!
",
I
8ft .~.......
~~-
nt-..
-
'.'
PllGEL'S "" ~y
nt.l. m-ID
-...-
nt-.
-
r(J
~
~::- ..
---ID-
,------
~L S "" lIOLIOUIy
..n
...
,
o
"
...
..~~--
I . -'---...
....' ~I - Itr-g°
1- ) .."" ... iii"
/'"
..' "'-"',,-
,.....
.101 NUMIER
17883.012.10
........ .....- A_18te8
£nvO-rinD -
~..~
DRAWN
AT Jr,
.
..
f
I
.. ..
..~
.........,.-
. ..............., --
. ""'."-"'-' -....-........ ...
. ............ .......... ....
. :-::- -=--0::..-- c... '"- ...
D ....... --.. .. -.. o.-t-
o ~:=-....................... 001
.. --
.. -...... -- t_..... ...... ..... -........
- -...... - -- ...... .......... ,...
-t- ~o-.....".,.
.,,-..
Il1O' t"-tD
t,,_.k-
110
:-~-Q"
'"
"'-
GrOund-W8t.r Distribution 0
1,2-Dlchloro.then.
08Ien8-Pf811.vllI. Dolomlt.
Acme sn
Wlnnebago County. IlUnal.
APPROVED DAn
10188
FIOURE
5
-------
7
migrated to groundwater. Sampling has-indicated that the st.
Peter Sandstone aquifer has not been adversely affected.
Based on the specific physical characteristics of the site and
the known contaminant distribution, groundwater flow is
considered the primary migration pathway.
Surface water samples were not collected because the intermittent
stream that crosses the site was dry during the STI. It is ,
believed that any past and future flow in the nearby stream'
channel would recharge the groundwater system rather than
provide a conduit for groundwater discharge. Therefore,
contaminated groundwater is not believed to have migrated off-'
site through this intermittent stream channel.
VI. ,SUMMARY OF SITE RISKS
An endangerment assessment (EA) was developed for the Acme
Solvents site in accordance with USEPA's 1989 Risk Assessment
Guidance for Superfund (RAGS). The purpose of an EA is to
analyze the potential adverse health effects, both current 'and
future, posed by hazardous substance releases from a site ,if no
action were taken to mitigate such a release. The EA consists of
data evaluation and selection of contaminants of concern, ,
toxicity assessment, exposure assessment, ~nd risk
characterization.
Selection of contaminants of Concern
Groundwater and soil data were evaluated and contaminants of, ,
concern were selected 'based on carcinogenicity, detectio~
frequency, comparison with background concentrations, toxicity,
physicochemical properties, concentration, and grouping, '
chemicals by similar characteristics. Based on this analys.is,
the following chemicals were selected as..contaminants of concern.
at the Acme site:
GROUNDWATER
SOILS:
.
VOCs
1, 1, 1-trichloroethane
1,1-dichloroethene
1,2-dichloroethene (cis and
1,1-dichloroethane
benzene
chloroform
tetrachloroethene
trichloroethene
vinyl chloride
VOCs ,
. 1,1,1-trichloroethane , '
. 1,~-dichloroethene (cis and
trans)' tetrachloroethene
.trichloroethene
ethylbenzene
total xylenes
trans)
SVOCs
nal?hthalene
SVOCs .
-------
8
Pesticides/PCBs
none
Pes~icides/PCBs
Arochlor 1254
Inorqanics
none
Inorqanics
lead
Toxicitv Assessment
The purpose of the toxicity assessment is to weigh available
evidence regarding the potential for~articular contaminants to
cause adverse effects in exposed individuals and to provide, where
possible, an estimate of the relationship between the extent of
exposure to a contaminant and the increased likelihood and/or
severity of adverse effects, including carcinogenic and
noncarcinogenic effects.
Ten of the fifteen contaminants of concern are carcinogens.
USEPA's Guidelines for Carcinogen Risk Assessment uses a two-part
evaluation in assessing the toxicity of carcinogens, first
assigning a weight of evidence classification, which evaluates the
sufficiency of data regarding a contaminant's carcinogenicity, and
then developing a cancer potency factor (CPF) based on available
information about dose response relationships for that carcinogen.
CPFs, which are expressed in (mg/kg/day)-l, are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to
provide an upper bound estimate of the excess lifetime cancer risk
associated with exposure at the intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. CPFs are derived from
results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied. The weight of evidence classification
and CPF for each of the indicator contaminants is shown in Table
3.
Ten of the fifteen contaminants of concern have noncarcinogenic
toxic effects. USEPA has developed chronic reference doses (RfDs)
to indicate the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media can be
compared to the RfD. . RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied. These uncertainty factors help ensure that the RfDs will
not underestimate the potential for adverse health effects to
occur. RFDs for noncarcinogenic effects for the contaminants of
-------
'mB[B 3
'lUXICI.'lY 1A-~~~
Aam S][,VEN!' REX::[AIKDC, INC. ~ OF ~
Weight of evidence Oral CPF oral RfD
CX>NrAMINANl' classificationl (rrq/kg/day) -1 rrq/kg/day
VOCs
benzene A 2.9 x 10-2
chloroform B2 6.1 x 10-3
1, l-dichloroethane B2 9.1 x 10-2 0.1
1,1-dichloroethene C 0.6 9 x 10-3
1,2-dichloroethene 0.022
(cis and trans)
ethylbenzene 0.1
tetrachloroethene B2 5.1 x 10-2 0.01
1,1,1-trichloroethane D 9 x 10-2
trichloroethene B2 1.1 x 10-2
vinyl chloride A 2.3
total xylenes 2
SVOCs
bis(2-ethylhexyl)phthalate B2 0.014 ' 0.02
naphthalene 0.4
Pesticides/PCBs
Arechlor 1254 B2 7.7
Inoraanics
lead B2 NA NA
J: USEPA's weight of evidence system classifies carcinogens as follows:'
A: Hl.Dnan carcinogen '
Bl: Probable human carcinogen (limited 'human data available) ,
B2: Probable human carcinogen (sufficient ,animal data, inadequate':,;'
human data) ,
c: Possible human carcinogen
D: Not classifiable as to human carcinogenicity
2 derived fram an adjusted acceptable daily' intake of, 350 ug/l:-,
-------
9
It is important to note that risks due to exposure to lead in
soils and waste areas were not evaluated because USEPA has not
developed a CPF or RfD for lead. untii a CPF or RfD is developed,
USEPA is using the Agency for Toxic Substances and Disease
Registry's finding that lead levels of 500 to 1,000 mgjkg in soils
can cause increased blood lead levels in children as a basis for
assessing risks due to lead. Lead concentrations in waste areas
and in some other site soils exceed 1,000 mgjkg and thus may
result in adverse health effects under the scenarios discussed
below.
ExDosure Assessment
The exposure assessment identified potential pathways for .
contaminants of concern to reach the receptors and the estimated
contaminant concentration at the point of exposure. Estimated
exposures to soil and groundwater were calculated based on a .
reasonable maximum exposure (RME) scenario, in accordance with the
National Contingency Plan (NCP, 40 CFR Part 300), and an average
exposure scenario, under both current and projected future land
use conditions. The exposure pathways evaluated in the EA are
summarized in Table 4.
current-Use Conditions - Residentia1 and Aqricu1tura1
Land around the Acme site is predominately used for. agriculture
and low-density, single-family homes. Twenty-four homes have been
identified along Baxter, Edson, and Lindenwood Roads near the Acme
site (see Fig. 5). All use private wells for water supply, and
those along Lindenwood and Edson Roads are downgradient of waste
disposal areas. Five residences have well water contaminated with
VOCs at levels exceeding USEPA's Health Advisories. These
residences were supplied with bottled water in 1981 and with
HCTUs in 1987. Two residences with HCTUs also continue to
receive bottled water under a voluntary agreement with Pagel's Pit
Landfill operators.
The current-use exposure assessment evaluated dermal, oral; and
inhalation exposure to groundwater for cooking, drinking water,
and other domestic uses such as showering. Use of water for
lawns, agricultural land, fruits and vegetables, and care of
domestic livestock was also evaluated. Use of well water with and
without treatment by HCTUs was evaluated.
CUrrent-Use Co~ditions - Recreational
The exposure assessment evaluated migration of contaminated
groundwater to Killbuck Creek and potential dermal contact
through swimming and fi~hing, or oral exposure through incidental
ingestion of surface water or consumption of fish. Trespassing
on-site would result in dermal, inhalation, and ingestion
-------
~ '
!'
TABLE \ 4
POTENTIAL EXPOSURE PATHWAYS QUANTIFIED UNDER:
THE CtJRRENT- AND FUTURE-USE SCENARIOS
~xposure Pathway
=====================================---=========z::======: "
Exposure Medium
Exposure Route;'
; Residential Setting
Untreated Drinking Water
Domestic Untreated Water Use
Aqricultural Settinq
Beef Consumption
Dairy Consumption
Recreational Setting
Swimming in Kishwaukee:River
Swimming in Kishwaukee' River
Fish.From Killbuck Creek
On-Site Setting
Airborne VOC and Particulates
Airborne Particultes
5011 .
Soil
Untreated Drinking Water*
Domestic: Untreated Water, Use* i
Water
Air
Ingestion
Inhalation "
Food
Food
Ingestion: d,
Ingestion:
Water
Water
Food
Ingestion' ' ,
Dermal, Contact
Ingestion'
Air'
Air
Soil
Soil
. Water
Air' ,
Inhalation'
Ingestion
Dermal Contact,
Ingestion
Ingestion
Inhalation:' '
====================================================='========:::::==="'.
* for future-use scenarios only;
.
TBLES-l.vw .
-------
-
10
Future-Use Conditions
The future-use scenario evaluated future migration of contaminants
to the existing homes through a groundwater model using the same
exposure scenarios described above. In addition, potential
dermal, inhalation, and ingestion exposures to on-site soil and
groundwater if a residence were constructed on the site were
evaluated. This future-use scenario is consistent with current
land use near the site and zoning restrictions, which allows one
single family dwelling per 40 acres.
Chronic daily intakes of contaminants were calculated for the
exposure pathways. described above using methods described in RAGS
and further detailed in the Acme Solvents EA.
Risk 'Characterization
The risk characterization combines the chronic daily intakes
developed in the exposure assessment with the toxicity' information
collected in the toxicity assessment to assess potential human
health risks from contaminants at the site. For carcinogens,
results of the risk assessment are presented as an excess lifetime
cancer risk, or the probability that an individual will develop
cancer as a result of a 70-year lifetime exposure to site
contaminants. These risks are probabilities that are generally
expressed in scientific notation (e.g. 1 x 10-6 or 1E-06). An
excess lifetime cancer risk of 1 x 10-6 indicates that, as a
plausible upper bound, an individual has a one in one million
chance of developing cancer as a result of exposure to conditions
at a site. '
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from' the
contaminant concentration in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated.
The HI provides a useful reference point for gauging the potential
significance of multiple exposures within a single medium or
across media.
Results of the risk characterization are detailed in Table 5 and
discussed below. Although both reasonable maximum exposure (RME)
and average case scenarios were developed for the EA, only the RME
will be discussed, because the NCP requires that the RME be used
in developing protective exposure levels.
current-Use Conditions
The greatest calculated potential risk under current-use
-------
TABLE
SUMMARY OF POTENilAL RISKS
THEORETICAL UPPER-BOUND EXPOSURE
5
-------------------------------------------------------------------------------------------------------------------....-----
Risk frOlll Risk frOlll Risk frOlll Total Chronic: Sourc:e
Exposure Pathway Exposure Route A 82 C Canc:er Hazard Risk
Carc:inogen Carc:inogen Carc:inogen Risk Index Table
---------------------------------- ---------------- ------------ -----------. ------------ ------------ -----...--- ---......---
RESIDENTIAL -- OJRRENT
-====::=====:==::.-::=
Drinking Untreated Supply Ingestion SE-OS 8E-06 4E -,06 6E-OS 1. SE -01 5-'
Domestic Untreated Supply Use Inhalation 1E-0I, 2E-OS 8E-06 1E-()I, 3.0E-01 NA
AGRICULTURAL -- OJRRENT
---------------------------------------..-----------------------------------------------------------------------------------
-==============---=====
Beef cons"",t i on
Dairy Cons"",tion
Ingestion
Ingestion
---.------------------------------------------------...............--..--..----.---.---..-.--....--.-.....-..-----....------...---....---------
RECREATION -- QJRRENT DRAFT
---==c...aCKca.............
Swhrming in ICfshwaukee
Swimming in lCishwaukee
Fish from ICflltu:k
Ingestion
Denne I Contact
Ingestion
ZE-,10
8E-11
SE-1S
3E-1S
2E-09
1E-09
,5E-10
3E-13
2E-13
3E-07
9£-12
4E -11
2E-09
7E-10
2.0E-OS
8.7E-03
5.S
5-6
MAR
MAR
NAR
3E -13
2E-13
3E-07
1.1E-08
1.9£-09
2.'E-02
5-8
5-9
S-10
-------_._--------_.__._-------.._.._~-_.._-----_.._--------....----......------....-----------..-----..-----......---..----..-'-------..------
ON-SITE -- QJRRENT
===...==:=.......=
A;rborne VOC/Part;culates Inhalation MAR 6E-09 MAR 6£-09 9.BE-03 S-12
Airborne Particulates Ingestion MAR 3E-08 NAR 3E-08 1.8E -05 S-13'
Soil Denne I Cont8ct NAR 1E-06 NAR 1E-06 1.2E-03 S-11,
Soil Ingestion NAR 3E-07 MAR 3E-07 7.0E-0I, S-15
COMBINED ' RESIDENTIAL -- CURRENT*
----.-----.-...-.......---------------.---.---------.-------..---------------....--...-.-..--..-...---.-.-...-..---------.
=================-=c============
OFF-SITE RESIDENTIAL -- FUTURE
Untreated Supply Multiple 2E-0I, 3E-OS 1E-OS' 2E-0I, '.BE-01 NA
; ----------------------------------------------------------------------------------------------.----------------------------
a.==a===:==::=::_:::=========:
Drinking Untreated Supply
Domest;c Untreated Supply Use
Ingestion
Inhalation
----......-.--.-.-....-......-.---..-------------------------------------.--------------------.----------------------------------
OFF-SITE AGRICULTURAL -- FUTURE
c======::===::::::::::::=::=:::
Beef Consumption
Dairy Cons"",tion
Ingestion
Ingestion
--.--..-------..--.----.-.--.-----..--...-....---------..------.---------..-------------------------------------------------
OFF-SITE RECREATION -- FUTURE
.===.==:=============....~...
Swimming in Kishwlukee
Swimming in lCishwaukee
Fish from Killtu:k '
Ingestion
Dermal Contact
Ingestion
SE-OI,
1E-03
2E-09
8E-10
1E-11
7E-12
1E-05
1E-OS
2E-OS
2E-09
7E-10
1E-12
6E-13
" 1E-06
2E-06
'E-06
SE - 01,
- 1E-03
2.6E-01
5.2E-01
S-16
NA,
'E-12
1E-11
'E-09
1E-Q9
2.7E-05 '
1.1E-02 -
5~17
S-18
MAR'
NAR
NAR
1E -11' 6.2E-OS
SE-12 1.0E-08
1E-OS' 1.'E-Or
5-19':
5-20
, 5-21
c===.c==============.........'
-. ..... -.. -.. -.. - - .. .... .... -. - -.. . _,- .. - - ...- - - - . - - - - - - - - . - - - - - - - - - - - - - - - - - - - .. -- -. - - - - - - - - - e.. - - - e -.. - - - - - - e'... - e'e ..e - - - -.. - e.. -.. - _... - e - . -
ON-SITE RESIDENTIAL -- fUTURE
Airborne VOC/Particulates Inhalation NAR 3E-06 NAR 3E-06 6.7E-02 5-22'
Airborne Particulates Ingestion NAR 1E-OS', NAR 1E-OS 'S..OE-03, - 5-23
Soil Dermal Contact NAR 3E-05 NAR 3E-05, 3.7E-02 5-2'.
Soil Ingest ion NAR, 9£-06' NAR 9£-06 '2.1E-02 ' 5-25,
Drinking Untreated "'ater" Ingestion 1E-02 : SE-OI,' 1E-()I, 1E'-02 9.6E+00 5-26-
Domestic Untreated "'ater Use Inhalation 2E-02 1E-03' 2£-01, 2E-02 1.9E+01 NA
---....-...-.--..-.---------------------------.------------------_._--_.._---__..e___~___._---__.._~e____._....----------..
COMBINED RESIDENTIAL -- FUTURE-
===::::=:===:=:===:=:=:=:=::=:=
Untreated Supply -- Off-Site
Untreated Supply -- On-Site
Multiple
Multiple
---------.--.--...-------------.----------.---.-------.---------"--------.--.----------.-------------"--------.------.---.
2E-03
3e-02
3E -OS '
2E-03
* Combined pathways include all residential + agricultural. fish c:onsumptiQn.
NA = Not applic:able
NAR = No applicable risk
(1335)ES-2.wkq
Page 1
6£-06
3E-0'
2E-03
3E-02
9.3E-01
2.9E+01
NA
NA'
-------
11
groundwater at the homes along Lindenwood Road. Inhalation and
ingestion exposures to contaminated well water result in a
lifetime excess cancer risk of 1.6 x 10-4. vinyl chloride
contributes more than 81 percent of this risk, with the remaining
VOCs accounting for the remaining risk.
For on-site (trespassing) exposures, incidental ingestion and
dermal contact with soil contribute more than 98 percent of the
total lifetime excess cancer risk of 1.3 x 10-6, primarily because
of exposure to PCBs. Inhalation exposure pathways were
insignificant.
Risks from swimming and fishing in Killbuck Creek were
insignificant, as were risks from consumption of agricultural
products.
Future-Use Conditions
If no action were taken to prevent exposure to or migration of
contaminated groundwater (i.e., the HCTUs were discontinued), the
lifetime excess cancer risk from ingestion and inhalation
exposure would increase to 1.5 x 10-3 for the homes along
Lindenwood Road. Again, most of this risk is from viny~
chloride.
If a home with a private well were built on-site, residents would
be exposed to a lifetime excess cancer risk of 3 x 10-2, mainly
from ingestion and inhalation exposure to groundwater
contaminated with vinyl chloride. Potential risks from dermal
. contact and incidental ingestion of soils would result in a
lifetime excess cancer risk of 4.9 x 10-5, mainly from exposure
to PCBs. Future on-site residents would also be exposed to
noncarcinogenic adverse health effects, particularly from
inhalation exposure to 1,2-dichloroethene during household use of
well water.
Consumption of agricultural products and swimming in ~illbuck
Creek result in insignificant risk, however, the lifetime excess
cancer risk for ingestion of fish caught in Killbuck Creek if
contaminated groundwater continues to migrate towards the creek is
1 x 10-5.
Risks due to Waste Areas
Risks due to exposure to the waste pile left from the 1986 cleanup
(see Fig. 2) were developed separately using the methods described
above. Exposure scenarios and risk calculations are shown in
Table 6. The lifetime excess cancer risk due to dermal contact
and incidental ingestion of soils is 3.8 x 10-5 for the current
use (trespassing) scenario and 1.2 x 10-3 for the future-use
(residential use of site) scenario, mainly due to exposure to
-------
. .
TAmE 6
WASI'E AREA RISK ASSES9mlr ~
EXPOSURE PATHWAYS ~ tmER
. 'mE CJRRENl'- AND ~~'U(t;-am sc::mmRIaS
EK:IsrIR; af-SlTE WASTE KUm oons
~ Pat:tMIy
~,
Exposure Ib1te :: '.'
~ )bIt;,-
Airborne VOC and Particulates
Airborne Particulates
Soil
Soil
Air
Air
Soil
SOil
Inhalation
Ingestion
Dermal Contact ~
Ingestion
. .
"
\ j~ ~
~ OF PCIl'fNI'IAL RISRS
EXISl']N; W-SITE WASI'E KUm oons
~CAL UPPER B:nID EXPOSORE
Exposure Patmlay
Total
Cancer
Risk
Exposure Ib1te
Chralic
.8azaJ:tl . .
Index
Cfi-SITE - UII:
-------
12
greater than one order of magnitude higher than those for other
on-site soils. Under both scenarios, inhalation exposure to
airborne contaminants from the waste areas (particularly xylenes)
could result in noncarcinogenic adverse health effects.
Risks from exposure to northwest area soils were not evaluated
because analytical data were not available at the time the EA was
written but are expected to be similar to those for the waste
pile. Risks due to the approximately 8,000 gallons of liquids and
sludges in the tanks on-site were not evaluated. The tanks are
securely closed, so the potential for human or animal exposure to
the contents is low. However, the tanks are partially buried, and
the potential for leaks or ruptures is unknown.
Environmental Risks
Two types of ecosystems are found around the Acme Solvents site,
the tall prairie grassland ecosystem (comprising most of the Acme
Solvents site) and the riparian forest ecosystem (including the
ecosystem around Killbuck Creek). Chemicals detected in surface
soils at the Acme Solvents site may enter into the food chain of
the grassland ecosystem via ingestion by earth burrowing
organism, such as earthworms, and/or uptake by grass roots, and
may bioaccumulate. Information necessary to assess potential
adverse environmental effects due to direct or indirect exposure
to contaminants was not available. However, the lack of large
quantities of remaining chemical-affected soils indicates that the
potential for environmental risk is low. Also, groundwater.
mOdelling data indicate that concentrations of contaminants
entering Killbuck Creek from groundwater are low, therefore,
adverse effects to the aquatic ecosystem are also expected to be
low.
According to information from the Winnebago County Forest
Preserve, no threatened, rare, or endangered species and/or
associated habitats are known to exist on or near the Acme
Solvents site.
The results of the EA show that actual or threatened releases of
hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health,
welfare, or the environment.
VII.
DESCRIPTION OF 'ALTERNATIVES
Based on the'findings of the STI and EA, the following remedial
action objectives were developed for the Acme Solvents site:
- Reduce human health risks due to dermal, ingestion, or
inhalation exposure to contaminants in the two 8,000-gallon
-------
13
and to the soils/sludges in the northwest area of 'the site,
as well as all other contaminants ~emaining in soils after
the 1986 cleanup.
- Reduce the potential for mobile contaminants, especially
VOCs, in soils and waste areas to migrate and further,
contaminate groundwater.
Remediate contaminated groundwater outside of waste areas' to:,
meet ARARs and health-based levels, and provide a long-term'
alternate water supply to homes with contaminated wells.:
- Reduce the potential for migration of VOCs from bedrock ,g~s
to groundwater.
Remedial action alternatives to meet these objectives were
developed in two documents: an EE/CA addresses the tanks and waste'
areas; and a RAAE addresses all other site contamination. Two
documents were written because USEPA and IEPA intend to remediate,;"
the tanks and waste areas as quickly as possible, prio~ to the
'remediation of other less highly contaminated areas. The two sets,
of alternatives are discussed separately below. Alternatives
involving' the waste areas and tanks will be refe.rred to as Phase
alternatives, and alternatives involving other areas will be .
referred to as Phase II alternatives. '
Phase I:
Waste Area Alternatives.
The eight remedial alternatives that were considered for the. waste
pile, the two tanks, and the sludges in the northwest area'
("source area:s") of: the site (see Fig. 2) are descr,ibed below.
Detailed information about the alternatives is presented in the h
EE/CA. Approximately 6,000 tons of soils and sludge arepr.esent
in the two waste areas, and 8,000 gallons of liquid and sludge are,
present in the tanks. All out'lined c.1eanup alternative~ can be
constructed within 1 year of: startup.
The tanks and waste areas meet the conditions set for.th in the NCP
for a non time-critical remova,l action, and' were intended to be
addressed as a removal prior to ROD signature. In~accordance with:
the NCP, an EE/CA was written ,to evaluate cleanup a'lternatives.
Because the EE/CA was not completed until August 19'90, the'
Agency's selected remedy for this waste area has been'
incorporated into this ROD. . .
-
Common Elements
All Phase:I alterna,tives, except no action, include .treating the' .
liquid and sludge conta'ined in the two tanks by off-.site
incineration and 1andfilling of the tanks. Both the landfill an~
-------
~..
,
"
I
14
and Recovery Act (RCRA).
is $379,000.
estimated cost of the tank removal
The
Under all alternatives except those that call for off-site
disposal of treatment residuals, surface water diversions, such as
trenches and berms, would be constructed to reduce water runon and
infiltration. All Phase I alternatives can be constructed in one
year.
Wastes originally disposed of at Acme Solvents, and now mixed with
soil and debris, include still bottoms from a solvent reclaiming
operation. Although all disposal occurred prior to the enactment
of RCRA, if the wastes were generated today, they would be
classified as FOOl - FOOS listed waste. In addition, some of the
highly contaminated soils and sludges may be RCRA characteristic
due to TCLP toxicity. RCRA regulations are therefore applicable
to remedial action alternatives which would constitute placement
of a RCRA waste, but are not applicable to alternatives which
treat waste in-situ.
Because existing and available data do not demonstrate that the
treatment processes under consideration can consistently attain
RCRA LDR standards for all soil and debris wastes to be addressed
under Phase I, the alternatives will comply with LDRs through a
Treatability Variance. The treatment level range established
through a Treatability Variance that these technologies would
attain for Acme indicator parameters is shown in Table 7.
No Action
As described in the EA and EE/CA for the Acme Solvents site, the
presence of high levels of VOCs, SVOCs and PCBs in the waste areas
could present an appreciable health risk if left unremediated.
The exposure pathways contributing most significantly to the risk
are: inhalation of VOCs, dermal contact with PCBs, and incidental
ingestion of PCBs. VOCs would also continue to migrate to
groundwat~r if the waste areas were not remediated.
Alternative 1:
Soil vapor extraction, RCRA cap, surface water
diversions.
.
Alternative 1 provides for extracting VOCs using in-situ soil
vapor extraction (SVE). SVE would consist of drilling a series of
wells into the soil mound and in the northwest portion of the
site, to bedrock (approximately 25 feet). Extracted air would be
vented through activated carbon to remove VOCs. When the SVE has
eliminated 90 to 95 percent of the VOCs, the SVE system would be
removed. A RCRA Subtitle C compliant cap would then be installed
over the areas to prevent direct contact with residual
contamination, including SVOCs, PCBs, and metals, and to reduce
-------
TABLE 7
TREATABiliTY VARIAICE lEVELS FOR ACME SOil AID DEBRIS'
Struetur.l Ae.e Site ...i.u. .8nlle to be
Funetion.l Group Cont..in.nt Cone- (.II/kll) Achieved
PCBs PCBs 290 90 - 99.9 X reduction
Halolleneted 1,2-0ichloroethene 44 95 - 99.9 X reduction
A l i phet i cs Trichloroethene 4.5 0.5 2 mg/kg
Tetrachloroethene 31 0.5 - 2 mglkll
Non Polar Aromatics Ethylbenzene 290 90 - 99.9 X reduction"
and Heterocyclics Total Xylenes 1,500 90 - 99.9 X reduction"
Other Polar Bis(2-ethylhexyl) 1,300 90 - 99.9 X reduction
Orllanics phthalate
Inorllanic' Arsenic 20.9 0.27 - 1 mg/l (TCLP)
Barium 1,190 0.1. 40 mg/l (TCLP)
Chromium 54,900 0.5 - 6 mg/l (TCLP)
Lead 52,500 0.1 . 3 mg/l (TCLP)
'source: OSWER Oirective No. 9347.3-06FS. Treatability variance levels were
calculated based on STI sampling data. These levels should be recalculated if
predesign sampling shows different contaminants of concern or maximum
-------
15
Because soils would not be excavated, RCRA subtitle C closure
requirements would not be applicable; however, a RCRA Subtitle C
compliant cap is proposed to maximize infiltration reduction.
Total present net worth' (PNW) cost of Alternative 1:
$1,036,000
Alternative 2:,
Soil vapor extraction, in-situ solidification,
surface water diversions.
Alternative 2 includes installation of an SVE system, as described
in Alternative 1, to eliminate 90 to 95 percent of the VOCs.
Alternative 2 would then use in-situ solidification to immobilize
PCBs, SVOCs, and metals such as lead. A specifically designed
drilling rig would inject solidification materials through the
center of the augers and mix them with contaminated soils.
Treatability studies would be necessary to determine the
effectiveness of solidification on organic contaminants.
As in Alternative 1, RCRA closure requirements would not be
considered applicable to this action because all materials would
be treated in-situ.
Total PNW cost of Alternative 2:
$1,173,000
Alternative' 3: Excavation, chemical oxidation, solidification,
followed by (a) off-site disposal or (b) on-site
placement and surface water diversions.
Alternative 3 provides for excavating soils and sludges and then
treating the wastes by ~hemical oxidation to destroy VOCs, SVOCs,
and PCBs. The chemical oxidation system being ~valuated, for
which a preliminary treatability test has been conducted, uses
hydrogen peroxide and a catalyst to break down organic chemicals.
This oxidation process would be performed in a reactor equipped
with vapor-phase activated carbon to capture emitted volatiles.
The remaining treatment residue would then be solidified to
immobilize metals such as lead. Further treatability studies
would be required to' determine whether these technologies would be
effective on site contaminants, especially PCBs.
Following solidification, the treated waste would be disposed of
using one of two alternatives. Alternative 3a calls for off-site
disposal of treated material at a RCRA-permitted hazardous waste
landfill. Alternative 3b, on-site placement and surface water
diversions, calls for leaving treated material on-site and
imposing run on and infiltration controls to minimize the potential
for contaminant migration.
Because Alternative 3 calls for excavation and treatment and
disposal of soil contaminated with RCRA waste, RCRA LDRs would be
applicable. Thus, this alternative must, at a minimum, meet the
-------
16
RCRA Subtitle C closure requirements must also be met in Phase II
if treatment residuals are placed on-s~te (Alternative 3b).
Total PNW cost of Alternative 3a:
Total PNW cost of Alternative 3b:
$7,990,000
$6,390,000
Alternative 4:
Excavation, soil washing, off-site treatment' and
disposal of washing liquids and contaminants.,
followed by (a) off-site soil disposal or (b), on-
site placement and surface water diversions.,'
Alternative 4 provides for the excavation of soils and sludges,
followed by a multistage soil-washing treatment process to remove
VOCs, SVOCs, PCBs, and metals. Batches of contaminated soil would
be mixed with surfactants and washing fluids. Washing liquids.
would be treated and cohtaminants would ultimately be taken off~
site for treatment or disposal in. compliance with RCRA Subtitle C.
Treatability studies would be necessary to determine the
effectiveness of the soil-washing process.
Two alternatives were evaluated for disposal of washed soils.
Alternative 4a, off-site disposal, calls for off-site disposal of ~,
washed soils at a RCRA-permitted hazardous waste landfill. " '
Alternative 4b calls for placing washed soils on-site and
implementing run on and infiltration controls to minimize the
potential for residual contaminant migration. Applicability ~f
RCRA requirements would be the same as for Alternative 3 .' .,
Total PNW cost of Alternative 4a:
$6,080,000
$4,680,000
.' ,
Total PNW cost of Alternative 4b:
Alternative 5: Excavation, followed by (a) off-site disposal "or'
(b) low-temperature thermal stripping and off~site:
disposal.
, Alternative 5 provides for excavating soils and sludges. .
Alternative Sa, off-site disposal, calls for transporting
contaminated soils and sludges directly to a RCRA permitted
hazardous waste~ landfill. Alternative 5b calls for :volatil'iza'tion
of organic cont'aminants through a low-temperature thermal'
stripping (LTTS) process and then off-site transport and disposa"l
of the treated waste. Soils and sludges would be he'ated' to ' "
approximately 3500 to 8000 F to volatilize VOCs and ,SVOCs., Units,
operating at temperatures at the high end of that range can also'
volatilize PCBs. Offgases resulting from the thermal treatment . ;
process would either be collected and condensed or passed through,'
a high-temperature afterburner. Treatability studies would .be
required to evaluate the efficiency ,of the process in 'removing
-------
17
Under Alternative 5b, treated soils would be placed on-site, and
runon and infiltration controls would be implemented to minimize
the potential for residual contaminant migration.
As in Alternative 3, RCRA LDRs would be applicable to this
alternative. Alternative 5a would not meet RCRA LDR requirements.
If Alternative 5b is selected, RCRA subtitle C closure will be
required in Phase II.
Total PNW cost of Alternative 5a:
$1,900,000
Total PNW cost of Alternative 5b:
$3,400,000
Alternative 6: Excavation, on-site incineration, surface wate~
controls, and (a) on-site placement or (b)
solidification and on-site placement.
Alternative 6 provides for excavating contaminated material and
incinerating materials on-site to destroy PCBs, VOCs, and SVOCs.
After incineration, residuals would be placed on-site. (Alternative
6a), or residuals would be solidified to immobilize metals and
then placed on-site (Alternative 6b). Surface water controls
would be' installed to reduce water runon. A mobile incinerator
would be brought on-site, and a trial burn would be performed to
demonstrate compliance with RCRA and the Toxic Substances Control
Act (TSCA), including a 99.9999 percent destruction removal
efficiency for PCBs. Treated soils would be placed on-site, and
runon and infiltration controls would be implemented to minimize
the potential for residual contaminant migration. Because most
metals cannot be destroyed through incineration, residuals placed
on-site under Alternative 6a would contain some metals; however,
solidification (Alternative 6b) should effectively immobilize
heavy metals.
RCRA LDRs and subtitle C closure requirements' must be met for
Alternatives 6a and 6b. Alternative 6a may not meet these
requirements, depending on the level of metals remaining in
residuals.
both
Total PNW cost of Alternative 6b:
'$13,000,000
$14,000,000
Total PNW cost of Alternative 6a:
Alternative 7: Excavation, off-site incineration.
Alternative 7 provides for excavating contaminated material,
loading contaminated material into drums, and transporting drums
off-site to a RCRA- and TSCA-permitted hazardous waste'
incinerator. Residuals would be placed in an off-site RCRA-
permitted hazardous waste landfill. Excavated areas would be
-------
18
As in Alternative 3, RCRA LDRs and Sub~it1e C closure
requirements will also be applicable for this alternative.
Residuals may have to be solidified off-site to meet RCRA
requirements.
Total PNW cost of Alternative 7:
$13,000,000
Alternative 8:
Excavation, low-temperature thermal stripping,
solidification, followed by (a) off-site disposal
or (b) on-site placement and surface water
diversions. ' ,
Alternative 8 provides for excavating soils and sludges. and then
treating them through the LTTS system described under Alternative:
Sb.. Residuals would then be solidified, if necessary, to'
immobilize metals.
Alternative 8a, off-site disposal, calls for off-site disposal of~
treatment residuals at a RCRA-permitted hazardous waste' ,landfill...'.'
Alternative 8b calls for on-site placement of treatment. residuals "
and imposing runon and infiltration controls to minimize the'
potential for contaminant migration.,' ,
As in Alternative 3, RCRA LDRs'and Subtitle C ciosure
requirements would be applicable for Alternative 8b. Thus this~
alternative must, at a minimum, meet the Treatability Var.iance
standards for soil and debris (see Table 7).
Total PNW cost of Alternative 8a:
$4,300,000
, $2,700,000
Total PNW'cost of Alternative 8b:
Phase II:
Remaininq Soil. Bedrock. and Groundwater Alternatives, ..
six remedial alternatives are being considered :for ,cle'aningup the
remaining soil, bedrock, and groundwater .contaminat:ion'. In "
general, the alternatives become increasingly complex and build
upon previous alternatives to provide more comprehensive ' .
approache's to: site re1r.ediation. Further .in:formation' about the'se'
alternatives is presented in the RAAE.i. '
Common Elements
.
Except for the no action alternative, all alternatives 'conta'in
common elements, as. discussed below. All alternatives' pr.ovidefor,.
tw,o types of cap, a RCRA Subtitle C compliant cap or, a 12-inch
soil cover. These options are provided because the' 'selection of
Phase I c1eanuv alternative will, in part, determine whether. or. '
not RCRA ARARs are triggered and 'Subt'it1e' C closur.e' 'is required.
All Phase II alternatives include site fencing :to :ensure'the '
integrity of the cap or cover and deed notices or 'advisories. to
-------
19
contaminated groundwater until cleanup levels are attained. Under
all alternatives, the affected residences would be provided with a
permanent alternate water supply from the Pagel's Pit deep well or
from a new water supply well in the st. Peter Sandstone aquifer
(see Fig. 5). All alternatives, including no action, include long
term groundwater monitoring.
All cost estimates are based on 30 years of operation and
maintenance. For Alternatives 2 through 6, a cost range is given
in the RAAE, depending on the type of cap chosen (as discussed
above) and the level of protection chosen, which ranges from a
lifetime excess cancer risk of 1 x 10-4 to 1 x 10-6. In the
discussion below, a range from the least to.~ost expensive option
is given. .
Groundwater soil areas and volumes used in cost estimates for the
various levels of protection and bedrock gas mass estimates are
shown on Figures 6 and 7 and Table 8. These estimates are based
on limited data; further sampling will be necessary to refine
these estimates.
Alternative 1: No further action.
Under Alternative 1, no action would be taken to clean up the
contaminated soil, bedrock, and groundwater remaining after the
Phase I cleanup. Groundwater monitoring wells would be sampled
at least twice a year for a minimum of 5 years. At least every 5
years, a risk analysis would be performed to evaluate the site's
. threat to public health and the environment.
Total PNW cost of Alternative 1:
$2,900,000
-
Alternative 2: Soil cover or RCRA cap, permanent alternate water
supply, and long-term monitoring.
Alternative 2 involves consolidating soil contaminated with lead,
SVOCs, and PCBs (approximately 33,000 ft2; see Figures 6 and 7)
and covering it with a 12-inch soil cover or RCRA subtitle C
compliant cap. The capped areas would be revegetated, and the
site would be fenced. Deed restrictions would also be imposed.
Groundwater and VOC-contaminated soils would not be treated under
this alternative. As in Alternative 1, monitoring wells would be
sampled for at least 5 years to estimate contaminant attenuation
and migration.
The total PNW cost of Alternative 2 ranges from $3,700,000 (to
achieve 10-4 risk using a soil cover) to $6,830,000 (to achieve
-------
'mB[E 8
GIUJNDolATER, 9:>IL AND ~ GAS VOIlJo!E ESTIMATES
risk level
Groundwater volume 10-4 10-5 10-6
area (ft2) 1.4 X 105 4.3 x 106 6.3 x 106
volume (gallons) 5.8 x 106 1.8 x 108 2.6 x 108
Soil volume
immobile contaminants1
(lead, BEEP, PCBs)
area (ft2) 28,000 33,000 33,000
IrCbile am. immobile
contarn:inants2
(BEEP, PCBs, VOCs)
volume (yd3) 4,800 8,600 9,100
Bedrock aas (mass~
bedrock gas (lls)
average case est.iJnate4
391
worst case estilnate
6800
1 used for cap am soil cover cost estilnates
2 used for treatment cost estilnates
3 estilnated mass of VOCS in bedrock gas
-------
X
001
Figure 6
Esttm8ted Extent of Residu81 5011 Exceeding Action leve1s for the 5urfici81 P8thw8Y
Acme 501vents Rec18iming, Inc.
APPROXI MATE SITE BOUNDARY
EXPLANATION
Soi1 Cor. Ho 1.
Location and Number
:::::::::::. Border for area of
........,.. Lead greater than or equa1 to 500 mg/kg
.:..:..: -4
:..~..~c 10 Risk Leve1 (for PCBs and/or BEHP)
1110 -5 Risk Len1 (for PCBs and/or BEHP)
(includ..:s to'" r..~
10 -6 NCP-Point of Departure (for PCBs and/or BEHP)
(includ..:s to'" ...d 10 -5 rM:S)
:::::
I,','
',','
,,,,,
. . ~ . .
011
X
009
X
X
016
-~..
~
N
j NOTTO SCALE
..-
---.-,- --...
007
X
006
Xe~
002 .,
005 X .::"::~:"..
X r. X "i).J3
. 003-D%:)(:::::;':: 001
. . X
(Background)
--~-- .. -.
- -..--/ APPROXIMATE SITE BOUNDARY
Please note: Estimated areas intended to
support cost .stimations; verification samp1t's
during the design phast' win bt' nt'cessary to
-------
F~~ure 7
Est1mated Extent of Residual 5011 Exceeding Action Levels for Groundwater Chemicels of Concern
Acme Solvents Reclaiming, Inc. . .
. . . .
APPROXIMATE SITE BOUNDARY .
~------------~--~~~---~-~--~~~-----
...
--~------
017
cg)
009
Ci)
cg) 007
006
0eooe
005 002
Ci> t) .8P3
003-~
018
~
001
(i)
(Background)
.. --.-,-- .... --
- -..-./ APPROXIMATE SITE BOUNDARY
~
001
son Cor. Ho 1e
location and Number
Risk le'(el
(i~~1udIP5 10"" "IP~
~~
N
j NO
. NOTE: NCP point of departure, 1 0 -~ consists of
-4 -5
the same ar~as as 10 and 10 risk levels.
Ctlemicals of concern inc1ude Indica~or volatne
organic compound~ ~ ~stimate~ areas in~'flded to
support cost estimations; verification samples
during the design phase' yi11 be necessarll to
r:.vist' the dt'pth and arealestimatt'S. .
n 10-4
II 10-5
Risk It'vel
3CAlE
-------
20
Alternative 3: Soil cover or RCRA cap, permanent alternate water
supply, long-term monitoring, and low-temperature
thermal stripping.
Alternative 3 includes all components of Alternative 2 and adds
LTTS to treat VOC-, SVOC-, and PCB-contaminated soil. The volume
of soil to be treated ranges from 4,800 to 9,100 cy, depending on
the level of protection chosen (see Table 8 and Figs. 6 and 7). .
The LTTS process is described on page 16 under Phase I Alternative
5. Although this technology has been proven effective for
removing VOCs, treatability studies would be conducted to evaluate
its efficiency in removing SVOCs and PCBs. Metals such as lead
would not be treated. Treated soil would be disposed of off-site
in a RCRA subtitle C compliant landfill or returned to the.
excavated areas. .
Because Alternative 3 calls for excavation and treatment of soil
contaminated with RCRA waste, RCRA Subtitle C closure
requirements would be applicable if residuals are disposed of on-
site. Thus, this alternative must include a RCRA Subtitle C
compliant cap to comply with ARARs if soils are disposed on-site
but may include a soil cover if materials are disposed off-site,
and if the selected Phase I alternative does not include on-site
disposal. Also, treatment by LTTS must, at a minimum, meet the
Treatability Variance standards for soil and debris (Table 7), in
order to comply with RCRA LDRs. . .
All components of Alternative 3 can
The total PNW cost of Alternative 3
10-4 risk and off-site disposal) to
off-site disposal).
be completed within one year.
ranges from $9,400,000 (for
$14,210,000 (for 10-6 risk and
Alternative 4: Soil cover or RCRA cap, permanent alternate water
supply, long-term monitoring, groundwater pump and
treat, and discharge of treated effluent.
Alternative 4 includes all components of Alternative 2 but adds
extraction and treatment of VOC-contaminated groundwater.
Volumes of groundwater to be remediated to achieve various levels
of protection are presented in Table 8. Extracted water would be
treated by air stripping or an equivalent technology and
discharged to Killbuck Creek or the intermittent stream that
crosses the site. Treatability studies may be required to design
the groundwater treatment system. Offgasses would be treated if
emissions from the air stripper exceeded health-based levels or
ARARs. Soils would not be treated under this alternative but
would be consolidated and covered with a soil cover or RCRA cap.
The area of remediation~for groundwater pump and treat extends
from the boundary of the waste areas (essentially equivalent to
the site boundary) to the edge of the VOC plume. Groundwater
-------
f'
21
would be excluded, as discussed in Sect~on IV. Groundwater cleanup
would meet or exceed maximum contaminant levels (MCLs) set under
the Safe Drinking Water Act (SDWA) and non-zero MCL Goals (MCLGs).
Discharge of treated groundwater must meet National Pollutant'
Discharge Elimination System (NPDES) limits set under the Clean ~.
Water Act (CWA).
Groundwater pump and treat would require 15 to 30 (or more) ,years,
to achieve remediation goals. All other components of Alternative: :
4 can be completed within one year. The cost of Alternative 4
ranges from $5,780,000 (for soil cover and 10-4 level of
protection) to $10,203,000 (for RCRA cap and 10-6 level of
protection) .
Alternative 5: Soil cover or RCRA cap, permanent alternate water
supply, long-term monitoring, groundwater ,pump and.;',
treat, and soil and bedrock vapor extraction.. ','
Alternative 5 includes all components of Alternative 4 but adds
vapor extraction to remove VOCs from soil and bedrock. Vapor
extraction uses pumps connected to extraction wells to draw VOCs
through the air spaces between soil particles and in bedrock. T
vacuum established by the extraction wells draws VOC-contaminate~
air from the soil pores and draws fresh air from the soil ,surface
down to the soil. The areas and volumes of soil and ,bedrock to be',
remediated are shown in Figure 7 and Table 8. If air emissions:
from the vapor extraction system exceeded health-based levels
(based on the 10-4 to 10-6 carcinogenic risk range) or ARARs,
'offgases would be treated. Vapor extraction is a proven
technology in .soils, but pilot:studies would.be needed to "
determine its effectiveness in' bedrock. ' Soils contaminated with
SVOCs, PCBs, and lead would not be treated under this alternative
but would be consolidated and covered with the soil cover or.RCRA
cap.
Because this alternative involves in-situ treatment, RCRA .LDRs and,
closure r.equirements would only be' applicable if requJred by the
selected Phase I alternative.i '
-
It is. estimated that the soil/bedrock vacuum extraction system.
would be operated for two to five years. The groundwpter pump and
treat system would require 15 to 30 (or, more) years,.of operation
to achieve remediation goals. All other components of Alternative,'
5 can be complet~din one year. The PNW cost of Alternative 5 '
ranges from $7,948,000 (for a 10-4 level of protection and soi1
cover) to $'12.,475,0.00 (for a 10-6 level. of .protection andRCRA '
-------
22
Alternative 6:
Permanent alternate vater supply, groundwater pump
and treat, soil and bedrock vapor extraction, and
(a) lov-temperature thermal stripping or (b) off-
site incineration and disposal.
Alternative 6 includes all components of Alternative 5 but adds
treatment of SVOC- and PCB-contaminated soils by two' alternative
treatment technologies. In Alternative 6a, soils exceeding the
selected risk level would be treated by LTTS as in Alternative 3.
Residuals would be disposed of on-site and covered with a RCRA cap
or disposed of off-site in a RCRA-permitted hazardous waste
landfill. In Alternative 6b, soils exceeding the selected risk
level would be incinerated off-site in a RCRA-permitted
incinerator. Residuals would be disposed of off-site in a RCRA-
permitted hazardous waste landfill.
Because Alternative 6 calls for excavation and treatment of soil
contaminated with RCRA waste, RCRA subtitle C closure
requirements would be applicable if residuals are disposed of on-
site. Thus., this alternative must include a RCRA subtitle C
compliant cap to comply with ARARs if soils are disposed on-site
but may include a soil cover if materials are disposed of off-
site and if the selected Phase I alternative does not include on-
site disposal. Also, treatment by LTTS must, at a minimum, meet
the Treatability Variance standards for soil and debris (Table 7)
in order to comply with RCRA LDRs. Treatment by incineration must
achieve a 99.9999 percent destruction removal efficiency for PCBs
as required under RCRA.
The vacuum extraction system would be operated for two to five
years. The groundwater pump and treat system would require 15 to
30 (or more) years to achieve remediation goals. All other
components of Alternative 6 can be completed in one year.
The cost of Alternative 6a ranges from $13,335,000 (to achieve a
10-4. risk level with off-site disposal of residuals) to .
$19,186,000 (to achieve a 10-6 risk level with off-site disposal
of residuals).
The cost of Alternative 6b ranges from $25,406,000 (to achieve a
10-4 risk level with off-site disposal of residuals) to
$42,140,000 (to achieve a 10-6 risk level with on-site disposal of
residuals).
-
VIII.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The NCP requires that alternatives be evaluated on the basis of
nine criteria: overall protection of human health and the
environment; compliance with applicable, or relevant and
appropriate, requirements (ARARs); long-term effectiveness and
permanence; reduction of toxicity, mobility, and volume (TMV)
-------
23
cost; state acceptance; and community acceptance. This section
compares Phase I and Phase II alternatives with respect to these
criteria.
Threshold Criteria
OVerall Protection of Human Health and the Environment.
Phase I: All source area alternatives meet the CERCLA minimum
requirement for protecting human health and the environment.:
Those alternatives that involve off-site landfilling of treated or
untreated wastes and sludges (Alternatives 3a, 4a, Sa, Sb, 7, and
Sa) provide the best overall protection because contaminants are
completely removed from the site. Those alternatives that treat
all contaminants before on-site landfilling (Alternatives 3b, 4b, ,
6, Sb) provide slightli less overall protection, although risk
based cleanup levels must be met pefore treated material could be
landfilled on-site. Those alternatives that treat only a.. portion' .
of the contaminants (Alternatives 1 and 2) provide less .overall"
protection.
Phase II: All Phase II alternatives (except no action) protect
human health and the environment by providing a permanent
alternate water supply to affected residents and treating. or.
containing remaining contaminants in soil. The alternatives
providing for both soil and groundwater treatment (Alternatives' S .
and 6) provide the best overall protection. Alternatives 2 and 3:
provide little protection to future groundwater users because no .
groundwater treatment is included.
For both Phase I and Phase II, the no action alternative is 'not
protective of human health and the environment. The no action
alternative will not be considered further in this analysis~
Compliance with ARARs
. .
Phase I': The most important ARARs associated with .the Phase r.,:
cleanup' are RCRA and TSCA requirements. All alternatives meet'.'
these requirements except Alternative Sa, as discussed below. '..
RCRA LDRs (40 CFR Part 26S) require .treatment of h'azardous '.
substances before landfilling. LDR requir.ements wl.ll be met
through a Treatability Variance. All alternatives' requiring' .
excavation and treatment (Al ternati ves 3. through S',) require.
treatability testing to ensure that RCRA LDR Treatability Variance
standards (see Table .7) can be met. Alternatives that include
on-site landfilling of residuals (Alternatives 3b,4'b, 6a, 6b, and
Sb) also.require RCRA Subtitle Cclosure as part of thePhaseII'
cleanup'.:. Alternatives which include off:-site landf.illing of:.
residuals, (Alternatives 3a, 4a, Sa, and Sa) must meet all 'Federal
and State permit requirements for 'landfilling hazardous .waste.
Alternatives :1 and 2 are not required to meet RCRA LDR standard'
-------
24
not meet LDRs because the materials would be landfilled off-site
without treatment. This was prohibited after expiration of the
national capacity extension for CERCLA soil and debris on November
8, 1990.
The TSCA PCB spill cleanup policy (40 CFR 761) is a "to be
considered" (TBC) criterion for this cleanup. This policy
requires that spills resulting in PCB contamination of greater
than 50 ppm be cleaned up to'a level of 10 ppm and covered with at
least 10 inches of clean soil. All alternatives except 1 and 2
meet this criterion; however, treatability studies will be
required to ensure that residuals from some of the treatment
technologies can meet the 10-ppm cleanup.level.
Phase II: RCRA and TSCA regulations are also important ARARs for
the Phase II cleanup, as are MCLs and MCLGs set under the Safe
Drinking Water Act (SDWA) (40 CFR 141 and 143) and NPDES limits
set under the CWA. All Phase II alternatives will meet MCLs and
non-zero MCLGs at the point of exposure through provision of an
alternate water supply; however, Alternatives 2 and 3-will not
meet these ARARs in the aquifer. Alternatives 4, 5, and 6 must
meet NPDES limits, and utilize the best available demonstrated
control technology (BAT) for treatment and discharge of
groundwater to surface water.
RCRA requirements will dictate which of the site capping options
(soil cover or RCRA Subtitle C compliant cap) is selected, and
LDRs will set minimum standards for excavated and treated
materials. Alternatives 3 and 6, which include excavation and
treatment of soils, must meet Treatability Variance standards for
soil and debris in order to meet the requirements of RCRA LDRs.
If, under the Phase I or Phase II cleanup, treatment residuals are
to be landfilled on-site, the RCRA compliant cap option must be
selected under Phase II in order to meet RCRA Subtitle C closure
and post closure requirements.
All Phase II alternatives meet the requirements of the TSCA PCB
spill cleanup policy, as discussed above.
Primary Balancina Criteria
Long-Term Effectiveness and Permanence
Phase I: Alternatives 6 and 7 (on- and off-site incineration)
provide the best long term effectiveness and permanence. All
other Phase I alternatives require treatability studies to assess
this criterion; however, the alternative that relies on capping to
prevent exposure to some.contaminants (Alternative 1) provides
less permanence than those that treat all contaminants. Because
Phase I is not intended to provide the final solution for the
site, this criterion is more important for Phase II than for Phase
-------
25
Phase II: All alternatives include a soil cover or RCRA compliant
cap that provides adequate long-term effectiveness'.for
contaminants in surface soils as long as the cover or cap is
maintained. Those alternatives providing for treatment of
contaminants in groundwater, soils, and bedrock, in addition to
the soil cover or cap (Alternatives 5 and 6) 'provide the :best
long-term effectiveness and permanence. Alternative 2 with the'
soil cover option provides the least permanence because the soil
cover would be largely ineffective in preventing migration .of VOCs
to groundwater.
Reduction of Toxicity, MObility, or Volume Through Treatment.
Phase I: Those alternatives involving technologies that treat all
site contaminants (VOCs, SVOCs, PCBs, and metals), Alternatives
3, 4, 6, 7, and 8, provide the best reduction of TMV.. ,
Alternatives that treat only some of the contaminants, such as.
Alternatives 1, 2, and 5b, provide less reduction of TMV.
Alternative Sa provides no reduction of TMV.
Phase II: Of the Phase II alternatives, Alternative 6 best
reduces TMV through treatment because all contaminants that
exceed risk-based levels would be treated. Alternative 5 provides'
slightly less reduction of TMV because remaining SVOCs and PCBs.
would be capped rather than treated.. Alternatives 4, 3, and.2
provide progressively less reduction of TMV. ' .. ,
Short-Term Effectiveness
Phase I: All source area alternatives can be completed within' 1
year. The alternatives that do not involve soil excavation" .
(Alternatives. 1 and 2) provide the best protection, of workers ,and
the community during the remedial action. For alL other. .
alternatives that involve soil excavation, emissioncontro:ls, and, -'.
dust suppression would be used if necessary to protect workers and
the community during implementation.
Pha'se II:, All.alternatives can !be. constructed: in less.' ,than 1 '
year; however, groundwater cleanup under Alternatives 4, 5,"'and 6
requires 15 to 30 (or more) years to complete.: Soil vapor'.
extraction may take 2 to 5 years to complete. As with the source
area alternatives, the Phase II alternatives that do~ not require a
large amount of excavation (Alternatives 2, 4, and 5) provide the
best protection of the community and workers during ,construction; ,
however, emission controls and. other measures would be used as
-------
26
Implementability
Phase I: Many alternatives, including Alternatives 2, 3, 4, 5b,
and 8, require treatability studies to ensure their effectiveness
in treating the contaminants at the site. Incineration
(Alternatives 6 and 7), if followed by solidification of the ash,
is a proven technology for treating the site contaminants;
however, a trial burn is required by RCRA regulations prior to use
of an on-site mobile incinerator. No treatability studies would
be needed for Alternatives 1 and Sa. Most of these technologies
are readily available, although the capacity of on-site and off-
site incinerators is limited, as is the capacity of RCRA-permitted
landfills.
Phase II: Most Phase II alternatives under consideration use well
established, conventional, and widely available technologies.
However, treatability studies would be required for alternatives
that include LTTS (Alternatives 3 and 6a). Also, vacuum
extraction of bedrock contaminants has not been widely
implemented. Bedrock vapor extraction requires pilot studies to
assess its feasibility before this technology could be implemented
at the Acme Solvents site.
Cost
Phase I: The source area alternatives can be ranked by cost as
follows: Alternative 1 is least expensive, followed by
Alternatives 2, Sa, 8b, 5b, 8a, 4b, 4a, 3b, 3a, 7, and 6.
,Technology costs range from $1,040,000 for SVE followed by
capping, to $13,100,000 for on-site incineration.
Phase II: Phase II alternatives can be ranked by cost as follows:
Alternative 2 is least expensive, followed by Alternatives 4, 3,
5, 6a, and 6b. Costs range from $4,173,000 for Alternative 2 at
the 10.4 cleanup level to $42,140,000 for Alternative 6b at the
10-6 cleanup level.
Modifvina Criteria
state Acceptance
IEPA has been involved throughout this and previous
investigations of the Acme Solvents site and supports the
selected remedies (discussed below) for both the Phase I and
II cleanups.
Phase
Community Acceptance
Community acceptance of~the Phase I and II selected remedies is
discussed in the Responsiveness Summary, which is attached as
-------
27
:IX.
THE SELECTED REMEDY
Based on the information collected and developed in' the STI, EA,
EE/CA, and RAAE, and using the comparative analysis, of '
alternatives described above, USEPA and IEPA have se~ectedPhase I
Alternative 8 and Phase II Alternative 5 as the mostappr.opriate
remedial actions at the Acme Solvent Reclaiming, Inc.: site. This'
section contains a detailed description of the components of 'the
selected remedies. A flow chart showing the basic elements of: the
Phase I and Phase II remedies is shown in Fig. 8. '
PHASE :I:
SOURCE AREAS
The approximately 4,000 tons of soil and sludge in the waste
areas and the approximately 2,000 tons of soil and sludge in the'
northwest area will be excavated and treated on-site by LTTS,. ,
Residuals from offgas treatment will be treated or disposed of as :
RCRA hazardous waste. Offgases from the LTTS process will be '
collected and condensed, or destroyed in a high temperature' ,
a,fterburner, if necessary to meet emissions standards discussed'"
on page 31-
The two tanks remaining on-site will be emptied and disposed~f
a RCRA Subtitle C compliant landfill' or decontaminated and:'
disposed of ' as nonhazardous waste. Soils under and around~the,
tanks will be tested and treated by LTTS if they exceed the'
cleanup standards set forth in the following paragraph. , 'The'
approximately 8,000 gallons of liquids and sludges in the tanks'
will be sent for treatment to an off-site RCRA- and TSCA-permitted'
incinerator. The incinerator operator will be responsible: for
disposing of the residuals in a manner consiste~t .with RCRA'
subtitle C.
. The area to be excavated will be delineated in' the: .fie1d . using' a
; photoionization device (PID). A reading of 10 ppm -,above
background will define the ~limits of excavation. All waste ar.ea
materials exceeding 1:0 ppm PCBs must also be excavated and " ,
treated. Additional characterization of the waste ar.ea:s will be
performed to show whether the field delineation method des'cr.ibed
above will meet the 10 ppm PCB criterion or whether additional ",'
measures will be' necessary to delineate areas ,contaminated above
10 ppm PCBs.
-
Residuals from the LTTS process must, at: a minimum;: meet the' ,
Treatability variance standards for soil: and debris. set under RCRA, .
LDRs (40 CFR 268) and listed in Table 7. Residual~ will be
further treated by solidificationlstabilization, if necessary, to
meet these standards.: Treatability studie,s will be perfor.med' 'in, "
the design phase to :e'nsure that these .standards can be met ',by this
technology. Residuals that meet these standards can be '
-------
FIGURE 8
ACME SOLVENTS PHASE I AND PHASE II
SELECTED REMEDIES
PHASE I
WASTE AREA SOILS
AND SLUDGES
LIQUIDS AND SLUDGES
IN TANKS
TREAT BY
LTTS AND
SOLIDIFY
IF NECESSARY
TREAT BY
OFF-SITE
INCINERATION
RESIDUALS TO
OFF-SITE
SUBTITLE C
LANDFILL
RESIDUALS
LEFT ON-SITE
UNDER
RCRA CAP
RESIDUALS TO
OFF-SITE
SUBTITLE C
LANDFILL
PHASE II
CONTAMINATED
GROUNDWATER
VOC CONTAM.
BEDROCK
VOC CONTAM.
SOILS
Pb, SVOC & PCB
CONTAM. SOILS
ALT. PUMP & PILOT TEST SOIL VAPOR SOLIDIFY
WATER TREAT BEDROCK IF Pb LEVELS
SUPPLY G.W. VAPOR EXTRACTION EXCEED TCLP
EXTRACTION STANDARD
DISCHARGE COVER WITH CONSOLIDATE
. TO RCRA CAP & COVER WITH
SURFACE IF CLEANUP RCRA CAP OR
WATER STD NOT MET SOIL COVER
BEGIN COVER
VAPOR WITH
EXTRN - RCRA
-------
28
waste landfill, as long as all other State and Federal
requirements for landfilling hazardous.waste are met.
If residuals are landfilled on-site, Treatability Variance-
standards must be met, as well as additional standards to ensure
protection against direct contact threat and to prevent migration
of contaminants remaining in residuals to groundwater. In
addition, residuals must be covered by a RCRA Subtitle C compliant
cap to meet RCRA ARARs. The column entitled "multimedia cap with:
FML" in Table 9 shows VOC cleanup standards for LTTS residuals. to '
be landfilled on-site. In addition, PCBs must be treated to 1,0
mg/kg.
Table 10 provides a detailed cost estimate for the Phase I:
cleanup. The total cost of the Phase I selected remedy ranges
from $3,079,000 to $4,679,000.
PHASE II:
REMAINING SOILS, BEDROCK, AND GROUNDWATER
The selected Phase II remedy includes a RCRA compliant- cap~
permanent alternate water supply, long-term monitoring,
groundwat,er pump and treat, and soil and bedrock vapor extract'io'",
Groundwater
A wate~ main will be extended from the Pagel's Pit water supply
well or from a new deep well to the residences within the 10-5
carcinogenic risk plume and those whose wells may become
contaminated in the future. The HCTUs will be removed when the
water main is completed. .
A groundwater pump and treat system will be installed' to capture
all groundwater outside the site boundary that exceeds MCLs, .
proposed MCLs, or non-zero MCLGs. The MCL for 1,1-dichloroethen.e
(1,1 DCE) was not used, for the reasons discussed below~ A
cumulative carcinogenic risk of 1 x 10-5 or a cumulative, HI : 'of. 1
were used to develop cleanup standards for 1,,1 DCE and
contaminants without MCLs. Table 11 :shows. cleanup standards for
indicator .parameters. . MCLs and a 10-:5 risk level were 'selected
because concentrations at the: 1'0-6 and 10-5 levels :'are~bel'ow .
reasonably achievable detection levels for many of:the:
contaminants of ~oncern and because of the technical difficulties
associated with :aquifer restoration in fractured bedrock.
The NCP calls for use of MCLs and MCLG's. when setting standards for
aquifer restoration, except in cases where the MCLG is zero, or
where the attainment of MCL's would result in a cumulative'. .
carcinogenic risk 'outside of the 10-4 .to 10-6 risk "range. If the'
MCL for 1,1 DCE were used, the cumulative carcinoge'nic risk. for
all contaminants would be greater than '3 x 10-4. Therefore, the:
cleanup standard for 1,1 DCE was set at the 10-5 risk level. Tr.
use of MCLs and 10-5 risk as discussed above results in a .
-------
TABU!: 9
S>n. a.FANOP ~ FtR vccs
Soil QM!r M.1lH~;~ nm with FML
~ (u;fkg) (ugfkg)
1, 1, 1-Trich.loroethane 7,300 64 , 000
1,1-Dich.loroethene 0.8 6.9
1, l-:-Dich.loroethane 2.4 21
1, 2-Dich.loroethene 1,430 13,000
. Benzene 7.9 69
Tetrach.loroethene 140 1,200
Trich.loroethene 16 140
Vinyl Olloride 0.6 .52
4-Methyl-2-pentanone 723 6,100
Naphthalene 4,550 40,000
Notes:
FML
= Flexible membrane liner
Soil cleanup standards wer~ developed using the SUmmers Leach Mcx:lel to
determine a vex: concentration in soils that would ensure vex: concentrations in
groundwater would not exceed a 1 x 10-5 carcinogenic risk level. USEPA' s .
Hydrologic Evaluation of Landfill Performance (HELP) model was used to calculate
the infiltration reduction provided by the soil cover.and multimedia cap.
Further infonnation is provjded in the RAAB. Cleanup standards for the
multi1nedia cap have been reduced by a factor of 10 because the HELP model
assumes perfectperfonnance of the multimedia cap and has not been field
verified.
Soil cleanup standards below detection levels (DIs) using USEPA approved
-------
TAmE 10
page 1 of 3
asr EST1MATE RR 'IBE ~JLIDIFICATIaf/OP'F-srJE D:r.sEaiAL
Capital. Q:Ist
Technolcav QJsts
Soil EXcavation
Off-Site RCRA landfill
Transportation to Off-Site landfill
Low-Tenperature'Ihennal StrippinJ
Solidification
SUbtotal
Site QJsts
site Preparation
Site Administration
Insurance am Permit Renewal
SUbtotal
Indirect QJsts
Administration
, Contingencies
SUbtotal
Construction SUbtotal
Bid Contingencies
S90pe Contingencies
Construction Total
Permitting am Legal Costs
Services During Construction
SUbtotal
Total amital Q]st:
Total AnrIJa1 Q:Ist:
TotalPNW Q:Ist(1year) : $ 4,300,000
Notes :,
$ 170,000
$ 950,000
$ 330,000
$ 750,000
$ 510.000
$ 2,700,000
$ 20,000
$ 18,000
$
38,000
Anrual QJst
$ 200,000
$ 200,000
$ 30.000
$ 30,000
$ 35,000
$ 35.000'
$ 70,000
$ 300,000
Costs developed 'by USEPA's Cost of Remedial Action (CX>RA) model, '
$ 2,700,000
$
$
540,000
670,000
$ 3,900,000
$ 61,000
$ 75.000
$, 140,000
$ 4,000,000
All costs are rourxled to two significant figures'.
.',
'D1e cost estimates shawn are based on the data input to the program and cost '
algorithms developed for generic corxtitions.'Ihe final costs will depend on
actual size, design, and market conditions. As a result, the final project
-------
'mBLE 10
Page2af3
asr ESTIMATE PtR 'mE ~ H'!I"Iin HIASE I REMEDY
JJrl'S/s:n.mIFICATIaf/arsrrE P1AI::3mfr
CAPITAL asr
ANNUAL asr
'l'ec::t1n)lcav ~~
Soil EXcavation
Solidification
Low-Tenperature 'Iherrnal StriJ:Pin;J
SUrface Water Diversion/Cqllection
SUbtotal
$ 170,000
$ 510,000
$ 750,000
$ 24.000
. $ 1,500,000
$ 200,000
$ 700
$ 200,000
site 0Jsts
site Administration
Insurance am Permit Renewal
SUbtotal
$ 20,000
$
20,000
$ 30.000
$ 30,000
Indirect 0Jsts
Administration
Contin;encies
$ 35,000
. $ 35.000
$ 70,000
Construction SUbtotal
$ 1,500,000
Bid Contingencies
Scope Contin;Jencies
$
$
300,000
460,000
Construction Total
$ 2,300,000
$ 36,000
$ 50.000
$ 86,000
Permitting am Legal Costs
Services D.lrin;J Construction
SUbtotal
Tat:al ~nita1 0Jst:
$ 2,400,000
Tat:al Anrual 0Jst:
$ 300,000
Tat:al PNW 0Jst (1 year): $ 2,700,000
Notes:
Costs deVeloped using USEPA's Cost of Remedial Action (OORA) model.
All costs are rounded to two significant figures.
'!he cost estilrates shown are based on the data input to the program and cost
algorithms developed for generic conditions. '!he final costs will depend on
actual size, design, am market conditions. As a result, the final project
-------
..
TABLE 10
page 3 of 3
Harding L8w8on "aodat..
Engineering Cost Estimate for Incineration of
Tank Materials and Tank Disposal
Site preparation $ 1 0,000
Packing 120,000,
Transportation 1,000
Incineration 180,000
Tank disposal 6,000
Plans, permits, and regulatory fees 62.000
$ 379,000 "
Assumptions for cost:
Site preparation will be concluded within four days and includes labor, rental equipment,
and chemical stabilization.
, Packing will be concluded within 15 days and includes labor, rental equipment, health and
, safety equipment, decontamination procedures and disposal, and drum costs.
Transportation will be concluded within one day and includes labor and transportation for
three truckloads to CID.
Incineration will include 60 tons of material, as estimated from 8000 gallonswith:a density,
of 1.8 grams per cubic centimeter. '
Tank disposal will be concluded within tWo days and includes labor, rental equipment,
disposal, and transportation costs to CID.
Plans, permits, and regulatory fees includes management of task operatioDS;fina1izi~g"
documents necessary to task actions, and negotiations with regulatory agencies.,.', '
.
17683,019.10 - EE/cA
-------
r
I
~
'mBIE 11
.GRUDiATER aFANCP ~
.
Cleamp
St:amard
ug/1
Basis
l,l,l-Trichloroethane
l,l-Dichloroethene
l,l-Dichloroethane
l,2-Dichloroethene
Benzene .
Tetrachloroethane
Trichloroethene
Vinyl chloride
4-Methyl-2-pentanone
Naphtbalene
Notes:
200
0.2
2
70
5
5
5
2
125
20
MCL
1 x 10-5 carcinogenic risk
1 x 10-5 carcinogenic risk
MCLG far cis-1,2-OCE
MCL .
Prcposed MCL
MCL .
MCL
cumulati va HI of 1
cumulative HI of 1
'!his table shows cleanup starrlards for in:licator parameters only.
The general cleanup standards described in the text must be met
for all groun::iwater contaminants.
Groundwater cleanup standards below DIs using USEPA approved methods for
analysis of drinking water may be m:xiified.
-------
29
cumulative carcinogenic risk within the 10-4 to 10-6 risk range
required by the NCP.
The cleanup standard selected for the alternate water supply (10-5
carcinogenic risk) is more stringent than the standard selected
for the groundwater pump and treat system (10-5 risk only for 1,1
DCE and contaminants without MCLs) because the alternate water
supply addresses actual exposures, while the groundwater ~umpand
treat system addresses potential exposures. MCLs and 10- .
carcinogenic risk represent practically achievable cleanup.
standards for the groundwater pump and treat portion of the: remedy
given the difficulties of aquifer restoration in fractured.
bedrock. .
The area of attainment for groundwater cleanup levels extends from
the downgradient site boundary (the point of compliance) to the
downgradient edge of contamination. Groundwater will. be treated
by air stripping, followed by carbon adsorption, if necessary (or <
an equivalent technology), and then discharged in accordance with.
NPDES discharge limits to Killbuck Creek or the intermittent.
stream that crosses the site.
The Galena-Platteville aquifer has been classified as: a Class .I1
aquifer under USEPA's Groundwater Protection strategy and .is .
widely used as a source of drinking water. . The proposed.
remediation is consistent with USEPA'sgoal of returning usable
aquifers to their beneficial uses within a reasonable time frame... ..
However, because the Galena-Platteville Dolomite is a fractured.
bedrock formation, an extended period will be required to achieve
aquifer remediation; the actual time required for remediation :is: .
uncertain. Groundwater modelling. has estimated that remediation
can be achieved in 15.to 30 years,. however, experience at 'other .'
Superfund sites indicates that models underestimate aquif'er.' .
remediation times; the actual remediation time may be longer.
During the 15 to 30 (or more) years of .aquifer: remediation,' the
groundwater pump and treat system will be monitored 'and adjusted
as warranted by the performance data collected during .oper.ation.'
Adjustments to the operating system may include discontinuing
operation of extraction wells in areas 'where cleanup goals have.
been attained; alternating pumping at wells to eliminate
,stagnation points; and pulse pumping to allow aquifer.
equilibration and encourage adsorbed contaminants to partition
into groundwater.
Soil and Bedrock
Soil/Bedrock Vapor Extraction
VOCs remaining in soil:and bedrock after the Phase ,I cleanup will.
be treated by vapor extraction. A pilot test will.be performed +-... .
-------
30
tests are successful, bedrock vapor extraction will be implemented
under former waste disposal areas. Soil vapor extraction will be
implemented in areas where VOCs in soi~ exceed the cleanup
standards set forth in Table 9. As with the groundwater pump and
treat system, the vapor extraction system will be monitored and
adjusted as warranted by performance data collected during its
operation. Adjustments may be similar to those cited for pump and
treat.
Solidification
Lead-contaminated soils will be tested. for leachability and will
be solidified if the extract exceeds the 5 ppm RCRA TCLP lead
standard. Disposal of solidified material' will be as described
for Phase I residuals.
RCRA Compliant Cap or Soil Cover
All areas in where materials are treated and backfilled on-site
under the Phase I or Phase II cleanups will be covered with a RCRA '
Subtitle C compliant cap. In addition, any soils which exceed the
VOC standards entitled "soil cover" in Table 9 after completion of
SVE must be covered with a RCRA compliant cap. A RCRA compliant
cap may also be required over all former waste areas if pilot
testing shows that bedrock vapor extraction will not be effective
in removing VOCs from bedrock. Soils which pose a direct contact
threat will also be covered, as discussed below.
If no residuals are landfilled on-site (or if residuals can be
delisted under RCRA), and if SVE is successful in treating VOCs in
soils to levels at or below the standards set forth in the "soil
cover" column in Table 9, a 12-inch soil cover may be placed on
the site, rather than a RCRA compliant cap.
Soils containing contaminants that may pose a threat through
direct contact will also be consolidated and capped. Because
these contaminants are relatively immobile, a RCRA compliant cap
is required only if the conditions set forth in the preceding
paragraphs are not met. If those conditions are met, a 12-inch
soil cover may be placed over these soils. The cleanup standards
for direct contact threat are based on the 10-5 carcinogenic risk
level developed in the Acme Solvents EA and the USEPA policies for
PCB and lead action levels (OSWER Directive No. 9355.4-01 and
9355.4-02). Cleanup standards for contaminants which pose a
direct contact threat are as follows: bis (2-ethylhexyl) phthalate
- 58 mg/kgi PCBs - 1 'mg/kgi and lead - 500 mg/kg.
Because the success of the treatment technologies and further
testing in the design phase will determine the type and location
of the RCRA cap, the exact location of the cap will not be
specified in this ROD. Figure 9 is a conceptual drawing showing
-------
-
AC'" 'oea
A'.. 01 ConIlllllnallon (AOC,
.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-._._._.~_._._._._._._._._._.-
f
i
""=.
-"::'''''
..........
..........
.""'"
"''''''''
''''''""
'''''''''''''
.................... .-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-..
'-"""--.....-.........-.-.-.-,/
Hollo Scale
EXPLANATION
o
@
.".........leatioft.. "'... AdI:h8..,
..... EE.cA;"''' E._..........-, ,-
-........... ~.."'-_...
""'~E;- E'_""'~I_,
"'..c-_~ ~..-...-;"'..
~.....olOd."-""'''''ioir 1-
,-. To"~"" lot c:...,...
== ~L8W....Aa_...
E..--..., - ,
: I ffj ~ E_--_.
0811&." J08 NU".,,,
RlD 17683.028. to
- . , .
9190
y
Conceptual Conilgurilion. HoI lor DlsIgn
EEICA Ind RAAE A"II 01 Coneern
~ SoIvtrlll RIClalming. Inc.. SHI
\VlMlblgo Coullly. lliinoll
.~~
0&11
.......--..-..
"GUlli.
9
-------
31
A 10-5 cumulative carcinogenic risk level was selected for all
portions of the soil cleanup because many VOCconcentrations at
the 10-6 risk level are below reasonably achievable detection
levels. The VOC cleanup standards in soils are based on achieving
10-5 cumulative carcinogenic risk in the aquifer, a more stringent
standard than for aquifer remediation. Because of the
difficulties associated with aquifer remediation in fractured
bedrock, a higher level of treatment of soil contaminants which
may migrate and further contaminate groundwater is necessary to
ensure protection of the aquifer.
Air Emissions. Monitorina. and Institutional Controls
Air emissions from excavation and ~reatment processes will be
monitored. These processes include air stripping, soil and
bedrock vapor extraction, soil excavation and consolidation, and
the Phase I LTTS process. Offgas treatment or other corrective
actions will be used if total air emissions from the site exceed
an excess cancer risk of 1 x 10-5 for downgradient residences or
workers at Rockford Blacktop Quarry, the nearest receptors.
The remedy will also include (1) long-term groundwater monitoring
to ensure that action levels are being met, (2) . site fencing and
deed restrictions to prevent use of shallow groundwater under the
site and to protect the soil cover, and (3) to the extent .'
possible, deed notices or advisories will be provided to protect
off-site users of groundwater until cleanup levels are met.
Construction of the water main can be started while the Phase I
cleanup is being implemented. All other construction will start
after Phase I is completed. The Phase II construction may take
less than 1 year. Approximately 2 to 5 years may be required to
remove contaminants through SVEi however, the groundwater cleanup
may continue for 15 to 30 (or more) years. A cost estimate for
the remedy is provided in Table 12. The total present worth cost
for the Phase II cleanup is estimated at $11,933,000. .
The total present worth cost for the Phase r and Phase II
cleanups ranges from $15,012,000 to $16.,612,000.
x.
DOCUMENTATION OF SIGNIFICANT CHANGES
A Proposed Plan, which described USEPA's and IEPA's preferred
alternative for remediation of the Acme Solvents site, was
released for public comment in October 1990. The Agencies
reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, it was
determined that no significant changes to the remedy, as described
in the Proposed Plan, were necessary. However, a few minor
changes were made to the proposed remedy were made, as discussed
-------
TAmE 12
cun' ESTIMATE FtR 'mE ~JOMm PHASE II REMEDY
RCRA CAP, p{H) AND ~, SVE
rrEM CAP1'mL a:sr ,ANNtW:. cun', ,-
Mobilization $ 201,500 $ 8,600
Alternate Water SUpply $ 85,600 $ 6,000 "
Grourx!water MonitorirxJ $ 247,400',,' .
Mul t:i.medi.a Cap $'1,800,000 $ 38,000,
Grounjwater Treatment (60 gpn) $ 257,700 $ 88',400',
: Soil/Bedrock Vapor Extraction
'I , Shallow Soils $ 130;000 $ 70,000,
, Bedrock $ 531,400 $ 142,000,
" Pilot TestirxJ $ 65,000
Total Vapor Extraction $ 726,700 $ 212,0001 ,
Groundwater Extraction Wells ' $ 24,000 $ 8,000'
Demobilization $ 42.000
SUbtotal Capital Costs $ 3,134,500
EnqineerirxJ am Design (17%) $ 532,900
Construction Management (10%) $ 313,500
ContirxJency (30%) $ 940.500
Total O:!Inital. Chst: $ 4,921,400
Total Anrual Chst: $ 608,400
Total RM Chst (30 years): $ 11,933,000
1
SVE - 5 years maximLnn operation
Note::
Actual costs rray vary fran -30 to +50 percent of valueS 'presented
because of uncertainties in rate am cost factors. Additional
variations in costs rray also be realized because of uncertainties,
related to estirrates of volume or area. . Verification sampling .
comucted durirxJ the remedial i design phase will be necessary to, refine' .
these estimates. "
-------
32
The P~oposed Plan stated that for the Phase I remedy treatment
residuals must meet RCRA TCLP standards in addition to meeting
Treatability Variance standards. Further analysis of these
standards indicated that Treatability Variance standards are
nearly equivalent to TCLP standards, so the requirement that
residuals meet TCLP standards was eliminated.
The Proposed Plan stated that, for the Phase II remedy,
groundwater would be remediated if it exceeded a cumulative
carcinogenic risk of 10-5, and MCLs or non-zero MCLGs for non-
carcinogens. Further analysis of cleanup standards indicated that
MCLs, proposed MCLs, or non-zero MCLGs provided a more appropriate
cleanup level than the 10-5 cumulative carcinogenic risk level,
for the reasons discussed in Section IX. The cleanup standards
for aquifer remediation were changed accordingly.
XI.
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The EA developed for the Acme Solvents site showed that ingestion
and inhalation of contaminated groundwater and dermal exposure to
and incidental ingestion of site soils in waste a~eas pose the
greatest risks associated with the site. provision of an
alternate water supply to residents downgradient of the site,
extraction and treatment of contaminated groundwater, and
imposition of access restrictions to contaminated groundwater
until aquifer remediation is attained will address risks from
groundwater. Implementation of LTTS treatment of waste area soils
and sludges, SVE treatment of remaining contaminated soils and
bedrock gas, and capping of all contaminated areas will protect
against risks from direct contact with soils. In addition,
.removal of VOCs from soils and bedrock through SVE and LTTS will
reduce the source of VOCs to the aquifer and will thereby
decrease the overall time required to remediate the aquifer. All
risks resulting from exposure will be reduced to MCLs, a 1 x 10-5
carcinogenic risk level or an HI of less than one.
Use of emissions controls will protect against short term exposure
to contaminants during the remedial action. No environmental
impacts due to site contamination have been identified, and
discharge of treated water to Killbuck Creek will be regulated by
NPDES to ensure that the remedial action does not affect aquatic
life.
Attainment of ADDlicable. or Relevant and ADDro~riate.
Reauirements
The selected Phase I and Phase II remedial actions will meet all
-------
33
more stringent state requirements.
remedies are listed below.
ARARs for the selected
Chemical Specific
- SDWA National Primary Drinking Water Standards (40 CFR 141)
- Clean Air Act (CAA) National Ambient Air Quality Standards
(NAAQS, 40 CFR 50)
- CAA National Emission Standards for Hazardous Air Pollutants
(NESHAPs, 40 CFR 61)
- Illinois General Use Water Quality Standards, and Public and
Food Processing Water Supply Standards (35 IAC 302) .
Illinois General Effluent Standards ~35 IAC 304)
Action Specific
- CWA NPDES Standards (40 CFR 125)
- RCRA Definition and Identification of Hazardous Waste (40 C
261)
- RCRA Standards for Generators of Hazardous Waste (40' CFR 262:.).
- RCRA Standards for' Transport of Hazardous Waste (40 CFR 263) . .
- RCRA Standards for Owners and Operators of Hazardous Waste
Treatment, Storage and Disposal Facilities (~Q CFR.264). .
- RCRA Land Disposal Restrictions (LDRs, 40 CFR268) (LD.R
requirements will be met through a Treatability Variance..)
- Occupational Safety and Health Act. (OSHA) Regulations for
Workers Involved in Hazardous Waste Operations; (29CFR 191.0)'
- Illinois.Regulations for Prohibition ox Air PoTlution (35
IAC 201) :
- Illinois Regulations for Emissions of Fug:itive~ 'and'
Particulate Matter Emissions (35.IAC 212) .
- Illinois Organic Air Emission Standards (35 IAC 215)
- Illinois.NPDES Permit Regulations (3'.IAC 309);.
Location Specific
-------
34
To Be Considered criteria
- TSCA PCB Spill Cleanup Policy (40 CFR 761)
- SDWA Maximum Contaminant Level Goals (40 CFR 141.50)
Cost-Effectiveness
Phase I Alternative 8 and Phase II Alternative 5 achieve
significant risk reduction at a total PNW cost of $15,012,000 to
$16,612,000. Alternatives involving incineration (Phase I .
Alternatives 6 and 7 and Phase II Alternative 6b) offer a somewhat
higher degree of permanence but at a significantly higher cost.
The volume of soils and sludges in waste areas has been reduced by
90 percent since incineration was selected as the most appropriate
remedial action for the site in 1985. Presently, the volume of
soils and sludges is too small for cost-effective treatment by a
mobile incinerator, but too large for cost-effective treatment at
an off-site incinerator. -
other alternatives are less costly than the preferred
alternatives, but provide less treatment. Phase I Alternatives 1,
2, and 5a are two to three times less expensive than the selected
alternative, but provide for treatment of only VOCs, only VOCs and
metals', and no treatment, respectively. Phase II Alternatives 2
and 3 sacrifice groundwater treatment, and Phase II Alternative 4
sacrifices treatment of mobile VOCs in soils for lower cost. The
selected Phase II alternative is approximately three times more
expensive than the least expensive action alternative, which only
provides for a soil cover or RCRA cap and an alternate water
supply with no treatment of contaminants.
utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recoverv Technoloqies to the Maximum
Extent Practicable .
USEPA and IEPA believe that the selected Phase I and Phase II
remedies represent the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective
manner at the Acme Solvents site. Of those alternatives that are
protective of human health and the environment and that comply
with ARARs, USEPA and IEPA have determined that the selected
remedy provides the best balance of long-term effectiveness and
permanence, reduction of TMV through treatment, short term
effectiveness, implementability, and cost, taking into
consideration the statutory preference for treatment as a
principal element and State and community acceptance.
Several innovative treatment alternatives were considered for
Phase I. USEPA and IEPA selected LTTS followed by solidification
-------
35
remedial action goals for all contaminants than some of the less
established technologies considered, such as SVE followed by
solidification, and chemical oxidation. .
Of the alternatives that provided for aquifer treatment,. USEPA
and IEPA selected Phase II Alternative 5 over Alternative 4
because Alternative 4 would not treat VOCs in soil and bedrock.
Treatment of the source of groundwater contamination has been
found to reduce aquifer remediation time. Alternative 6. was' not
selected because it only adds treatment of very low levels of
relatively immobile contaminants such as BEHP, PCBs, and lead
(which can be effectively contained) at almost double the cost of.
Alternative 5.
Preference for Treatment as a Princioa1 Element
The selected remedy provides for treatment of the principal
threats at the site. The Phase I remedy treats the highest
concentrations of VOCs, SVOCs, PCBs, and lead in the waste areas
and tanks by LTTS and incineration, respectively, followed 'by
solidific~tion, if necessary. Phase II provides for additional
treatment of VOCs, the most mobile of the remaining contaminants
by soil/bedrock vapor extraction and by extraction and treatment
of groundwater. The only contaminants that will remain to be
contained by the soil cover will be low levels of relatively.
immobile contaminants such as BEHP, PCBs, and lead. The selected
alternatives thus satisfy the statutory preference for treatment.
as a principal element.
-------
APPENDIX A
PI"e No. ADMINISTRATIVE RECORD INDEX
12/21/90
ADMINISTRATIVE RECORD INDEX - UPDATE 13
ACME SOLVENT RECLAIMING INC. SUPERFUND SITE
WINNEBAGO COUNTY, ILLINOIS
.
fiCHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
9 83/04/15 Letter Roger J. Ruden I.Favero, IEPA CORRESPONDENCE
Re: results of semples ILLINOIS DEPARTMENT
tlken on Mlrch 8, 1983 OF PUBLIC HEALTH
from two privlte wells
with Ittlchments
7 89/09/01 Letter Frld Mlrlnell I , A.MIltner. USEPA CORRESPONDENCE 2
Re: Scope of work HARDING LAWSON
developed for ASSOCIATES
conducting aquifer
tests
" 90/05/11 Letter Brien D.LIFlemme A.Hiltner, USEPA CORRESPONDENCE 3
Re: Residential Michlel J. Malley
Wlter-Supply HARD I NG LAWSON
Analyticll DIU ASSOCIATES
with IttlChments
" 90/11/02 Letter Andrew Fletsch S.tllser/A.Hiltner, CORRESPONDENCE "
Re: Proposed Plln THE TESTOR CORPORATION USEPA
October 1990
17 90/11/05 Letter Steven J. LIIIIon 1."lfser, USEPA CORRESPONDENCE 5
Re: Admlnlstrltlve WINSTON & STRAWN
. Record
Ifl th IttlCtunent
3 90/11/05 Letter Glry Letcher A.HIltner, USEPA CORRESPONDENCE 6
Re: Proposed Plen THE HARKER FIRM
" 90/11/05 Letter John Holmstrom III A.HIltner, USEPA CORRESPONDENCE 7
.
Re: Comnents on WINNEBAGO RECL~TIOII
Supplementll Technical SERVICE, INC.
Investi"ltlon Report
(STI) Ind Proposed PI In
54 90/10/18 Public Hearin; USEPA MEETING NOTES 8
on the
Proposed Plln
-------
Pege No.
12/21/90
2
ADMINISTRATIVE RECORD INDEX - UPDATE 13
ACME SOLVENT RECLAIMING INC. SUPERFUND SITE
WINNEBAGO COUNTY. ILLINOIS
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE Doc;NUMBER
Re: Residential HARD I NG LAWSON
Water-Supply ASSOCIATES
Well Analytical
Data
with attachments
" 90/08/20 MIIIIO Irien D. LaFl.... A.Hiltner. USEPA MEMORANDIIC 10
Re: Residential HARDING LAWSON
Water-Supply ASSOCIATES
Well Analytical
DaU
with attachments
7 90/11/07 MIIIIO Irian D. LaFlemme A.Hiltner. USEPA MEMORANDIIC 11
Re: Residential HARDING LAWSON
Water-Supply ASSOCIATES
Well Analytical
Data
with attachments
14
85/09130
Response. to
nurbered conclusions
from Npert one.N QAJQC
Progrllll Revi eM
E.Jordin
OTHER
12
2 90/12/15 Treatment Systea Carla lurik. A.Hiltner, USEPA: . OTHER 13
.Net Present Worth PLANNING RESEARCH
(NPW) CORPORATION (PRC)
with fax Transmittal
attachment
-
7 86/',/07 Progress Report Enviromental .' USEPA REPORTS/STU)IES 14
on Clean-Up Resources Management!
Activitie. North Central, Inc.
-
98
90/10/1'
Northwest Area
Investigation
Final Report
Brian D. LaFlemme.
Michael J. Malley
HARDING LAWSON
ASSOCIATES
AS Steering
COIIIIIi tt ee
REPORTS/STUDIES
-------
Page No.
12/21/90
3
FICHE/FRAME PAGES DATE
80
12/90/00
TITLE
Record of Decillon
(ROO)
ADMINISTRATIVE RECORD INDEX - UPDATE 13
ACME SOLVENT RECLAIMING INC. SUPERFUND SITE
WINNEBAGO COUNTY, ILLINOIS
AUTHOR
RECIPIENT
Valdal Adamkus
USEPA
DOCUMENT TYPE
DOCNUMIIER
REPORTS/ST\J)IES
-------
)39t JIJ.
'0/01/90
ADKIJISrRArlfl RICORD 1'011 . UPDArl 11
ACll SOLVI.r RICLAINI.' I'C. SUPlR1U.D SIrl
fI'.,BAGO cou.rr. ILLI'OIS
Ical/1«ANI PAGIS DArl rrru ureOR IECIPIlir DOCUNlNr rm DOCJlUNBlR
3 ,o/OUU Letter '",bu, D. 'orea A.liltaer - US'PA Correspoadeace. 1.
AddeadUi to 'udia, £....oa
Deeeiber 15. 1989, Anoei'tu
fod '1111
'orthest Aru
laresti,uioa
Z 'O/OUlf Letter Alli.oa .iltller I.I,riaelli - 'LA Correspoadeaee 2
Ie, 'orthest IISIPA
Are, la1e,ti"tioa
Aeu Solreat.
Supertuad Si te
23
90104113
Letter
'e, ldeatitic,tioa
ot Applicable, or
'eIeraat
IIId Approprl.ce
Reiuiruut.
tor t6e ACle Solreat,
Supertuad Site
rit6 'tt,cheat.
Alli.oa L. .iltaer
BSln
I.Kariaelli . ILA
Correspoadeace
3
Ii
B 90/04123 Letter Alli,oa £. liltaer 1.I,riaelli - ILA Corrupoadeace .
Ie, St,te Applic'ble, BSIPA
or 'eleraat IIId . .
Appropri,t, "iaireleat.
tor. t6e Acu Sol rut.
Sapertuad ,it'
rltb ,tt,cb,d Jetter
J 'o/OUU Letter Aat60a, I. 'otb,cbild' A.BUttler. USfPA Corrupoaduce' 5
Ie, Di,po"l ot 'atler, 'ubia, 'ereol,r,
'el,iaia, Soil .ad $.lt,r,lli, '0,4 , . .
Ddri. trol th lruur
Aeu $olrutt
"cl,llla" lac.
51 '0107/20 Letter Aatboa, I. 'otb.cbil4' $.l,i"r. IISIPA' Corrup'oaduce' .
Ie, Propo,,1 to. 'utler, labla, 'er~o.er,
dispose of t6e re.,iala, $,lt,relll, '0,4 ,
coat'lialted .011 ,a4 lruaor
-------
Page '0. 2
.0/02190
AONI.ISrRArIVI RICORO 1.011 - UfOArr 12
ACrE SOLVI.r ',CLAIKI.G I.C. SUPIRIUIO SIrE
'1.."ACO cou.ry. lLLI.OIS
lICBE/lRAKI PAGIS DArE rULI AureOR RlpPIllr OOCUNlBr fYPE OOC'UNBn
r1tb attaeb.eat.;
iaeladiag,
'eeord ot Dee1.10a
('001 4
3 'O/OB/U ,Litter Stne P. lailfr A.'otbJebild - Corrupoadeaee 7
Re, Dl,poul Alll.oa L. 'iltaer II.SBl
ot 'e.alalog So11 fSlPA
lid Debrl.
leu SolFfat
'eelal.lo" lac.
23 89/12/2J fort '110 lo.h. D. 'OIeD USIPA Rtports/Scuiiu B
'orthut Aru 'ardiag Lar.oa A..oeiate.
rarutigltioa
Aeu Solreot.
'ee1.1Iiag, lac.
206 '0/OB/06 fagiaeeriag 'ud1a, Ln.oa USIPA Rrport./Stu~iu '
fralrlatloa/ Anoelltu
Colt Aul,.1.
liaal 'eport
Aeu SolreaU
Supertuad S1te
Volue II ot II
27' '0/OBI06 fa,1aeer1a, 'r1u f. 'on. USIPA Reports/Studies JO
fralultioa/ Oeaai. f. S.itb
Co.t Aul,.18 'ud1a, Lenoa
11ul 'eport A"oe1u"
Aeu Solreau
Supertuad Slte
folale 1 ot II
JB' fD/0f/20 'ned1al Aetioa 'r1aa D: Lalla..e USIPA 'eport./Studiu 11
Alterut1ru loba r. 'optiu .
,,,lau10a Deu1,'f. SI1U '
1iaal Report '.rd1ar Larsoa A..oe1ate.
Ae.e Solreat, S1te
Volult 1 ot 11
U5 '0/0f/20 '"ed11l Aet10a '.rdiar La,.oa A.soc1ate. US"A Report./Studies J2
Alteruttru
-------
Fagt 'J.
JO/02/90
3
lIcel/fRANE PAGES DArE
10
'OIlO/OO
37
'0/07/06
-
fIfLE
liul Report
Acte 501 rut.
Volute II ot II
Propo.ed Plaa
tor rbe ACle Solreat
Reclailiag, lac.
Supertud Site
Preliliury aad
. ralidated grouad-rater
ebeli.try re.ulr. tor
..Iple, obt.iDed duriag
tbe 'ortbre.t Are.
IDrutiguioa
{SUpliDg Dat.1
ADNIJISrRArlVI RICORD 11011 - UPDArE 12
ACNE SOLVI,r RICLAINIIG I.e. SUPIR1U'D SIrE
fIIIIB!GO courrr. lLL1'0IS
AureOR
II~IPIUr
'SIP!
1.'ar1aeJli
'ardiag LanOD
Anoeiatu
A.BiItDer - US'PA
DOeUHINr rm
Reports/Studiu
5npliDg Data
Doe'UKBER .
13
-------
J9t Mo.
6114/90
ADKl11SfRAflVI RECORD I1DEI - UPDAfE IJ
ACKE SOLVElf RICLAINI1G IMC. SUPIRIU,D 51fB
rl'.EBAGO COUlfr. ILLI101S
lCHB/IRANB PAGBS DAfB rULl AUfHOR ilCIPUIr DOCUNENf fm DOCNUKBBR
18 '0/06/08 Letter Joba .. rell" Se, Att.cbleDt B Corrtspoodtnc,
'e, 'taer.J DSfPA
'otie, ot PoteatiaJ
Li.biJ i ty
Aele Solfeat
',cl.iliag, lac.
Supertuad Si tt
'iao,b.go Couaty,
Illiooi,
ritb .tt.cbl,at,
(A,B,C, , DI
6 '0/05/00 Aele Solfeat DsrU 'act Sbett' 1
',el.iliog, lac.
Site Supe rtuod
laet Sbut
Update
15 87/0"00 liaaJ J.cob. .. DSIPA Report'/Studies 3
COlluaity ',latioa, lagia,eriag Group, lac.
Plaa
Ael' Solreat Site
.od P.g,l', Pit Site
Roettord, 111iaoi,
433 '0/02113 SuppJutat.J 'ardiag Lanoa Aclt Sturiag Itport,/Studi"
'feboic.l Iarf,tlg.tloa A"oci.tu COll1 ttu
liaaJ Itport
Aele SoJreot, Site
'iooeb'90 Couot"
IUlool,
foJue 2,
jpptadicu
H1 '0/02123 Suppl neo tal 'ardJog L.mo Aclt Sturlog . Rtport,/Studiu 5
'eehical A"ociuu COIIHcu
Iarutlgatloo
lJaal hport
Aele SoJreae, SJte
'laaeb.go Couat"
Illlaol,
VoJule 3,
-------
agt Mo. 2
6/14/90
ADII'ISrlArIrl RICORD I'DII - UPDArl 11
ACII SOLVI.r .,CLAIII'G I.C. SUPIRIOID SIr!
fI..,BAGO cou.rr, ILLI'OIS
ICI!/IRAN! PAGIS DArB fULl AUrBOI IIcnIlrr DOCUNur rrPB DOCIUNBBR
.
J88 '0/03/11 'nedi.l ActioD IndiDg £U'OD ACIe SturiDg Report,/StudiU 6
AlterDatirt. Arr'T Auoc i it" COllitcu
Dratt Itport
AClt SOlrtDt. Sict
fiDaeb.go CouatT,
l11iD01.
24 '0/03/20 Be.lt. A..e..leDt I.S. US". 'eporu/Stadi" 7
tor ,Gbl1c Bealt.
ACIe SolreaU Serrict
'tCl.l.cioD, I.C.
fiDDeb.go CouDtr,
IlliDOi.
188 90/05/29 Suppltleatal 'ec.Dic.l Indiag £.noD ACIe scuriag Btport'/Scudiu. B
IDruCigatioD A"ociit" COIIJtCU
'lul hporc
AClt Solreat. Sice
fiDDeb.go CouDtr,
l11iaoi.
Volule I:
laia fuc
442: 90/U/DB tiul "riDe' 'rich ! ACIe Settlon Rtporu/Studiu, 9
ladaagttleDt Coall cioa
Au"nut
AClt Solrtat. Sict
..cloa.l Priori tie.
£i.t IUlber HZ
fiDDeb,go CouDtr,
l11i8Oi.
Volu~t ODe
4U 'O/U/OI 'iuJ' £"iDe "rich ACIe. Settlon Rtportl/Studit'. 10
fadaagttltat CoaJitioa
Au"neat
ACle SolreDt. Ilte
- l.tioa.J 'rioritie.
£i.t IUlbtt HZ
'iDaeb.go CouDtT,
l11iaoi.
Volule fwo
Appeadlc"
-------
P~9t 10.
D7/IJ/89
JDIr,rS"j,rVI "COID IIDII
jC', SOL VI., IICLAI,r.C, r.c.
'I""jCO COD"t,
ILU'OrS
IreNI/IRAKK PACIS DA', frrn UfiO, UeIlIrrr DOCUlfli' WI DDClU/fB
2 At J 7JIOJ/U 'oc/c, cb.c "c/.t.ccor, C.l.rlnt-UPA fico lu.lII.-Aelr Corrupoodroee
,rovr,.. I. b,/oV ..dt Sol rea c
r/cb cb, rt.cor.c/oo
01 tbt ./ct.
2A2 I 7J/DI/U 'oc/et tb.c tbt l.eli/ef C.I.ClIrt-Uu rico IUIIII.-jclt Corrupoodtact 1
A., 6ttl ,.el.t,ecorJJ, SoIruc
clo"d ud cOflrd.
2A3 1 '1107/01 'teetr ot cooe,ra Ira. ,. 'r.. '.r,1 'bo.,.o. . III' Corrupolldtaet J
D,.r6, r,.14,.e o"r
,0..lbI, eooc..la.e/oD at
b,r ,,11 r.e,r .od .
r'fur.t to eb, IlIA tb.t
t6" Ct.e 6tr r.etr.
Act.cbtd I. ,. .t,.,.,tr
.relelt e,aettala,
"VtI'.
lit.
2A6 J BII07Ilf. 't.,oo.t co 10c.1 'ob,re C.,ettl-lI1A 'r., D.r,1 fbo.p.oo Corr'.poodeoce ,
rul4tOC '.
cooctro. o,tr 6tr rtll
'lett,
2 A7 I "/UIlB 'otlet cb.e r.etr b.. 'obtrt 'tovror-III' Su eIcIt Corrupoodracr S
btt. detled 1...lt tor
drlatlo,. ',ee,r.
..lltd co e6t "torI.,
'.,etr. .od e6, £la4..
2A8 Z ,mllll 'oclct e6.e tb, ,Ie, IUlteod.'1 , le,6.ld-lI1' fico Iu.lll,-'e.t Corr"poadcael f
I' I. ,/ol.e/o. lor SoIrue
.ot cOI,I,lo, rlc6
.. Ill, loll.e/o.
Cooerol 'o.rl Ord,r.
2 AtO I BJ/DlIU 'oelc, e6.e r.etr I. 106tre reavra'-111A 1.'rrrict~Joct/orJ eorr"pooduee 1
80tlc lor 61... nlte
cOlla.pc/ol.
2 Att " I/DUU 'oeiet eb.e ebt 'S',. ,..il Coo.e.ac,lo'-'SII' 'Clt liP'. CorrupOOdtDCr B
coo.ller. eb, r,ci,ltle.
at c6i. l,ce,r .., bt
rt,,00./61, ,.reit. '04
.., bt li.61, tor e6,
co.c. '.,oel.c,4 rlcb.
-------
"9' j~. 1 , .
D7/JJ/89
jDII.IlrljrI', ,'CDID 1'0"
JCII SOL".r "CLjIII.', lIe.
'l11'UGO COUlIr,
ILLI.OlS
'Ie61/1'AI' 'jG'S DAr, fULl UfiOI IICIIIII' DDeD.,,, m, DOCIUIiB.
,eclol. &,ce" ,1'0
.oeltl,. l,cl,l,ac.
ot c6, ""'1" ct.c
.111 b, c.t,a ,..
cb.c a., b, C.t,a
.c c6, .le, .1' ..t.
cb,a ,6.c a'..II'. et.c
e6" a., b, ,Jllll'
Co uI"IUh.
2 81 J "/JUDD COilflU oa U, J,ee, /061'01-&""'01'0". C~lrupoadeae'"
'rel1.1..r, fate"
"..16111c, 'Cad,.
2 82 1 "/J1/ll 'ollo,-u, la 'Ilcll, Co /. DIC60,t'I-'III.C..D"c.ol 'I', 'lcb.ud-I,pj C~rru,oldeac' 11
eoal'le. 1.4, .e c6, 'ulc6
,u6lJe 6"111' t'ld
11/6/11.
284 2 "/J1/Zi CO.I'le. 0. c6, cl'.lu, 'te,hl 'r,g'le6.u4-1IPj, COlru,oldeae, 11
'10'0..1. 11.ea..,4 .c Ire6a,-'eD,rloce,rlll"C .1
cb, ,ublle t'.lll, 01
12/6/".
286 ' ''"1/17 CO..'le. 01 c6, DI.lc rluU, Cr" 'le6.ud-ll'A Corru,oodeae" 12
',.,di.l "..16111c, '.It,r-l.ll.01,,,.,I,,r,...
Seudy.
2810 J "/JZIZ' t'OIlUU 01 eh &..I'le, le'u,6-loot','lec., Cr" 'lc6,ud-lIPA Corru,oad,ae, U
Iluruelre l08le
cl,.au, ,ro,o..I,.
2813 , IS/OJ/II 'oeltlclcl01 .1 ,0c'lel., ,..11 '''...e..e,'"."", ", "rrle, II.e 'Corru,old,ael II
11.61Jlc, t., ct, ,Ie,
.04 ,.colr'f,.,aC co
l,cl,I,.e. e. .11,re.t,
,olulc.r, el'I.I,
.ecl,lel". It 10
1"'01" c. e61, I,ee'l
IICI",. Ie 'III b,
...u.,4 e6.e c6,
II,I,ll1c
4,cl11" 1.,ol""ae I.
.a, cll"u, .eel0., .Id
'" b, a..,d la I co.e-
I,co"r, .eel01 111,1
la ,a ."lo,l.e, coure.
-------
-
Pavt '0.
D7/J3189
3
AD'I.Isr.JrI', I.CD.D ,.D.,
ACI. SOLVI.r ..CLAI'I.G, I'C.
'II.,'J'O cau.rr,
lLLI.01S
IICBI/IRAI' PAGIS DArl
rULI
ur,ol
IIC1'1I"
DOCUI"r mr
DOCIUI"
1111S 'or} 01 Cbt Aelt
Solr'lt. 11t,. Iitbortl
b, eOlcraecor '1,10'"
b, Cbt ,., COllict".
2D9
, 'UOJlJS
Ob"r,.UOIII 114
eOle,rl. 01 Ca, ".1"
III Ilpl'.'ICIClol ot
tbt bOlt earbol cr,aCltlC
laic.. ACtaeb,1 1. II
Irtlel, rblea cb, IICbor
b,ll,r,. Illerllle. cbe
11,ortalet ot "'O'lr'
to 'OC'. b, "'1' oCb,r
chi 11,,,Clol.
1.',leblt ',eo.-'I..,bI,o
Co lit,
Da" 'uno-USEPA
Corrupood"c,
16
2 E4 Z '6105130 Ilecor. CblC .a.C b, Doa, Crllllll-Il1A '.llcoI-'lDD,bagoCo Corrt,poDdtact 17
eoo.il,rel b,tore JulU
coo.il,rltl01 1.
,irel to allorlo,
cb, 10.tI11,Clol ot
a r,ll SOD Co J'OO
t,'t trot tb, .1Ce tor
,rarel ,"611'.
2 E6 , IfIJJIZS 'otIc, thc c6t Ilr,ro-USI1A 'Crlldill-IIPA f.lr,alc-'.rdio, Corrupoad,oc, 11
Ulili.traU" 11"01
Orl,r " COI.eDC 1. .or
,tteeclre 1. lc. or1,l111
tori. Attlcb,1 1. a CO"
at tbt 'Ill!
''''01111 "If"
'Glllr,.
2 E14 J B1IU/U '"eat,1 Cert1tlcate ot .ll'l Clrp'Dttr-USIPA 1,." COIrupoDd'lC' U
COlpl,tio. a.d Cor'IIIC labla-'at1,r,lablD,
lot to ,...
2 F3 4 14 IJJ II' Ilct 'buC U IliA llct Sbuc 20
Cltllap lro,o.,l.
2 F7 4 B111D1U Saptr!aa' Ilct Ib,eC 'SIU Ilct Sbut 2J
ACI' Solr'Dt lIe, AI'
11,'1'. lIt 'Ie,.
-------
',g, 'p.
07/l3/89
.
'Ical/"AII IAGIS DA',
2 F13
2 G1
2 G2
2 G8
2G9
383 :
385
2 72103/13
J 75/l0/U
5 13/D&l2J
J "/J2m
11 15/02115
2 15/15/2'
. ,
J Um/JZ,
'ULI
Ac., 101".tll.,,1'.
11t '01.., 0".
ADII.IS'.A'I', "CO.D I.DII
AC., 10£"" .,C£AI.I.G, I.e.
'I'.,'AGO COU"',
1££11015
nflo.
'"ort .. ."tla, b,t."a '.al '.rrr-ll'A
'lto '1.111, ..1 'ob,rt
locb. .t ti, II'A
eOlc,ral., .1.1"
11"0..1 ,r.etlct.
"I ,0tt.ti,l ,roblt...
Atur , 'lltt t. tit
.ict, tbt .Itbor
b,ll"e. tb.t tbe
.1ce b.. , ,ote.tl.1
to b,co.e . ..10r ,roble.
..1 .a",.t. tb.t tbe
..tter b, reo".tl.
Doca.eat,tloa .t ,
."tla, .1tb tit
'111er., I.l.er.,
.ad 'bo.,.oa.{.re.
tlllll", .
',t,a,loa ot ,ablle
CO.I,.t ,erl01 .atl1
J2I2"".
lecoll,ad,d ',.edl,l
Actloa tor tAt AC.t
101,nt ,itt.
lea.etA lecb,lr-IIIA
,." '."ro-llPA
'lorl. Cr.,ea-II'A
'.,e '.,ero-ll'A
'o.ltloa .t.t,.,.t ot tAe 'ob,rt lart,ad.ll-II'A
Il'A .a"ortl., tAe
Itcorl
ot D,cl.10a .1,atl '/J/'5
br 11cb.rl C.rl.o. .t tie
IliA {"itA-.at
IttlchntJ.
".0 tr.a..lttla, .a
.tt.cAel ,abl1c eo..eat
l,tc,r oa cAe Coa.eat
Ord,r. 'bt l,tt,r 1. trot
lettr 106a.o. ot t6t .
L,.,a, ot fO.la "Cer.
lid 1. d.ted 11/"16.
'.r"ret 'cCae-'SI'A
IICl1I'"
11,..t f.Ctt
IoU.CoaCrol
Docur", rrPI
DOClU'"
'norad.1 .
23
D,aai. loba.oa-IIPA ',.or.adol.
111,
24
Inoraodol.
15
All "Ior,alul
,re.,ac-Publicae.ri
If
.ob COlllu-IIIA
.' "ffett, et .1.
"IIA
Zi
Inoraoln
27
Inoraodn .
11
.nor..d.l,
-------
P.g, '0. ~
D7/13189
.Dll'IS".fl', ',COID I'Dll
.C" SOL VI" ',CLAlI1'G, I'C.
'1",'AGO COO'ff,
lLU'OIS
l1CII/IIAII 'AGIS DA', fULl UffO' IIClIIIIf DOCDll" rr1l DOC'DIII
3 BB 3 "/U/10 '0.5.1'. s"t, 'ablle 'SIP. "" Releu, 30
CGII'lt Oa .el' S1t,
lu"U,1t1ea.'
3 B11 J' 7/OfI2. ,'A fa .a,r,r ga"t1al' 'SI'. 'n. "lull 31
01 ACI' $ol"lt All
,.,,1', 'It 'a"rtall
su".
3 B12 J "IJZ/Of ',.rll, Ottle,r', 0"111' 'lGrl,'Cr"'I-l~P. Ot6li 32
St.t'.'lt .t 12/f/'.
,abl1e IUU".
3 B13 1 "/1Z/Of .,'Id. Gt 12/f/'. ,ablle ",. Otb,r 3J
",til, .al .otlee ot
ullnt ,,,lGI.
3 B14 5 "106100 Co.,l,t,d ",ld'lti.l .ru r"ldeaU Otber 3.
Sarff' tor...
3 C5 153 U/09tH Ad.111,tr.t1" Ord,r I, 'SIU .CII PIP', Pl,.diog,/Orl,r, 35
COI"lt rlt6 .tt.e6.,at,.
4 GB 7 00/00/00 COIIGI1t, "l.tlol' III. R"ottl/Studi" 36
""01.1"1'" 'a...r,.
6A1 18 72105llf 11,11 11",tl,.t101 ',r.ll ,,60,-I"A III. Be,ort,IStudi" 31
",art
6 B7 1 12/JZ/U 11",etlGa ",Grt. 'ocb. , Irlc6.rl-I". R,portl/Stodi" 38
5 B8 5 7SID6Ilf 'LIe 'ulo,1nl f6G'., I. Cl.rt.'L1C, II. R,port,IStudl" 3f
11",tl,.t10. "port.
6 813 J 7~/07/21 la.p,etloa '"ort. 'JU' . 1"1. .R,port.IStudi,. 40
5 B14 14 82/J0/2S Sit' II.p,ct101 ",art fOI loe6-'eolo" , 'l,lro..'lt OSI'A R"art,IStudi" U
5 C14 5 '2112121 Ir,ll.I.,r, 1."""'1£ ',al S6"-Ieolo,, , OSf" ReporU/Studi" 41
,.,Iroullt
505 11 83/0Z/00 .".,dl.J Actlol ,..t,r '0' 1. ".tol, "e. DSIPA R,portl/Studi" 43
-------
"
P'9' 'e,
07/J31B9
i
ID.I.Isr,&rI', IICO'D I'Drl
IC., SOLfl" ',CLII.I.G, I'C.
'I.,I'&GO cou.rf,
lLLIJOlS
lIC',/l,&.r llGIS Ilrr
rrru
JUr,o,
IICIll11r
Docunlf 1m
: DOC'UfBlR
6 C11
II( 83/03/00
'rC,ac ot $olr~" ot
'naalr.t,r
CoatuJutl/ID-
A~I' 'olr,at, ,.,,1',
lJt Ar,. ',.r 'orrJ,Cora,
IIHlloJ,.
I~olo'r , larJroal'at,Ia~.
'Sill
',port,/Stali,. " . '4
,
7'F7
10 83/U/D9
COllallltr 1,1.CJolI'
l1i11.
I.,6a, "11111-'Sr'l
"1 10r,k.,-USrPA ',port,/Stadl"
45'
7 G3 74 14/00/00 .',olo,r lor 11.lIaJII, la 'tt"luptoll' ',port,/Studi" 46
'ooa, A,d '11111,6"0 'C,erk-Il.D,pt.la,r,
Coaatln..
8 E8 114 14/0IlZ7 Qa.lJtr A"ar.'~' lrol'~t I.C. lord.a Co. IlIA iIIl USIPA "port,/Stadi"" '1
11.11 tor t6, II/IS.
10 F1 ZU '4107100 1'I,dl.1 lar"tJ,.tJoll I.C./orlaa Co. 1111 "port,/Studi" "
folal' 11, Ipp'adJ~".
14 A2; f 14/07/J7 lropo'll tor AIIJtJoa.l D.rJd 'rtr-I.C./ordla D.r, '.r,ro-ISI'& ",portl/Stadi,,' ",
S.lpJla, .al Aa.Jr'"
"I,dlI1 IDr"tl,.tlo,/
"..J6JIJt, 'tad,.
14 A8 IU '4I0J/00 l'I,ll.J l,r"Cl,.tJoll I.C./orln Co. 1111 ',port,/Studi" 50.
. foJaIl 1 r,~hJ~al
'"orc.
15 E9 ZZZ BS/U/U 1r,lJIJII.r, "..J6JIJtr I.C./orln Co. 1111 ',portt/Studi" 5J
Stadr - r,~611e.J "port
,88", IU, IS/Df/U. I"J" ot U, IIIIS ,'a,'IIIA, "l~hk 'Alloe. .AcI' r,c6aJe.J. -~: ",port,/Studi" 52
'"ort 011 ta, J~I' COli,
SoJrut, 'lee.
19 F7 ZlJ 15/01/2' $oJl .04 r"t IJt Cll. 1111 USIPA , R,port,/Stuli" . 53
- 'uplJII,.
22 C8 7 IS/Of/OS L'tt,r "port - D"p , 'orlek "rtr-I.C./ord.a,Co. 'tlt',1I' Duaa -lIPA -. ),port,/Stadi". 54
GroGa4r.t,r A""'I,at.
22 D3 58 1S/0f/Z7. ',cord ot ',cJ.Joa (IODI. Al.1 £,rJa tor r.ld., "portl/Studi,.,
Uuh,-USIPI
-------
Pigt It. 7
07/J3/S9
ADII'IS"A'I', .,CO'D IID.,
AC., 60L'," ',CLAI.I'G, IIC.
'I','BA'O COD"',
ILLIIDIS
IICB,/IRA., 'AG'S DA', fULl UfBOI IIC11IlIf Docun" fm DOCIU'"
DUl,a 'uoc. 'utl.,Cnl"..
23C5 U "/OS/U D.t. Aa.l"I, Aad Sa...rl '.C.lord.a Co. IliA Rtport,/Studies S7
'tport lor '"p Croaad
,.t,r A"""tat
23 F1 JD If/OS/22 App,adlr 11r, - '01' ',pOtUIStlldin sa
C.rbo. fr,.t.,.t 'alt,.
23 F 12 H 16/D8I20 'ro,rt" 't,ort oa "'-'ortb C,atr.l B,pott./Stadin H
Cl'.I-a, Actlrltl,.
.t 'bt ACI' Solrtat
SIt' 'octtord, 1111'01,.
24 D3 Sf If/U/OJ lro,r", ."ort oa "'-'ortb Ctatr.l Btport,/Studies fa
Clu.-a, ActJrHlu
.t rb, JCI, 'ol"at
SH, 'octiod,
IJllaol..
25A4 U 16/09123 'ro,r", '"ort oa "'-'ortb C,atr.l 'tport./Studi" fJ
Cl,.a-ap Actlrltl"
At 'bt Ae., Solr'lt Slt'
'octtord, l111aol..
25 F5 10 '6109125 lro,r,.. "port oa "'-'ortb C,atr.l B,port./Studi" n
Clt.a-ap Aetlrltl,.
.t 'b, Ael' 101r,at
11tt 'oettord, 1111101..
25G3 f1 16/JO/IJ lro,rt,. '"ort oa "'-'ort6 C,atr.l R,portl/Studi" U
Clt.a-a, Actlrltl" .t
'b, Ae., Solr,at SIt'
'octtord, 1111.01..
26 G2 7 86m/tO '",oa,lr,a,.. Sall.rl '$IrA ',port,/Studi" H
26 G9 3U 16/J2/30 Su...rl ot f.,t J - ',rdl., £.,.oa A..oc. Aell Sturia, 'tport,/Studi" U
laltl.1 Actlrltl" Co..JeUe'
Sa,plt'tat.l f,c6alc.l
lcruU,.tJoa.
30 G5
. 3' 17/01/0G
'tr.lttla, Aad Co.,11.lc, '.rt 'rr'IC-B.rdll' £"'01
'1'1 tor eb, SI'flt.tIC.1 A..oc.
ftcbllc.J Ilft,e ,.Clol.
D.rt I.rtto-USEPA 'tportl/Studie,
GG
31 C3
71 '7/01/08
ga.llcr A"at.lct Ptojtce ',r411, £1"01 A"oc.
Am SturlDg
Btpott,/Studi"
-------
',g, '0.
07/13189
8
IICBI/IRAII 'AGIS DA"
3288
35 D10
39 G2
40G5
41 E10
216 17/11/01
40D .7/DSIU
as .7IDGlD4
: il '71D7ID2
iT '71l1l2S
fULl
11 JIJ .
fola., 11 - 'a.llt,
j..ar..ee 'roJeet 'l.a
A"eaI1ee. j , ..
AD.I.IS',AfIfl .,COID I.Dll
jC., SOL',., ',CLAI.I.', I'C.
.I..'BAGO COU"',
lLLI.OlS
Aff'OI
'.rll., £"'0' j..oe.
'a,llt, A..ar.lee 'roJeet f,lle"et .1.-',rlll, £".oa
'l.a -tor tb, 'a"l,.,at,l A..oe.
feebale.l 11,e.tl"tl0..
laelal,. eo,er letter.
.ad tna..Htll let tell. .
',tlol,le lor fbe
'ro,o.,1 '011 jal
',Iroct la,e.tl"tlol.
JCII Solmu leel.i.i."
lac., Slte 'l.aeb"o
Coa.tl, l111a01..
le,l.el 'ort 11'1
'ork ,1,a (1,'l.el
'ortder 1117}
Supple.eat.l fecbaie.l
la".ti"tloa - Ac.e
.SolrtlU SHe 'ialth,o
CoaatT, 1111.oi,.
f,lle,iBI,at-',rlla, £"'01
hlOe.
'rT,at i 'o".co-l,rlia,
£..101
'"r,iBrT.ot-',rlia, £",oa
jlloc.
"CIll'"
DOCUIE" ,m
DOC'Ul"J
COllitW
jell 'wrla,
COIIHt"
',port,IStudi"
.is
Ae.e Iteeria, Co... R"ort,IStadi"
n
jc.e Ste,riog Co... ',port./Stadi".
70
'If' '"ero-USE'A - '"ort,/Stadi"
7r
Ac., St"ria, Co,.. ',port.IStadi,..
-------
Page No.
12/21/90
DATE
TITLE
00/00/00 Rlw dati .
and chlfn-of-custody
f~M18 IVlillble for
review
ADMINISTRATIVE RECORD SAMPLING/DATA INDEX
ACME SOLVENTS SITE, WINNEBAGO COUNTY, ILLINOIS.
DOCUMENTS ARE NOT COPIED, BUT MAY BE REVIEWED AT THE USEPA
REGION V OFFICES. CHICAGO. IL..DI OTHER LOCATIONS
AUTHOR
RECIPIENT
DOCUMENT TYPE
-------
Page No.
12/21/90
GUIDANCE DOCUMENTS INDEX - UPDATE f3
ACME SOLVENT RECLAIMING INC. SUPERFUND SITE
GUIDANCE DOCUMENTS ARE AVAILABLE fOR REVIEW AT
USEPA REGION V - CHICAGO, ILLINOIS'
TITLE
AUTHOR
DATE
Deter'llining When L8nd
Disposal Restrictions
(LORI) Are Appl ieable
to CERCLA Response
Actions
Superf~ LOR Guide IS
(4 pgs.)
USEPA OSWER Dir. ,
9347.3-05FS
89/07/00
Obtaining a 5011' and Debris
Treatability Variance for
Remedial Actions
Superf~ LOR Guide tI6A
(6 pgs.)
USEPA OSWER D I r. ,
9347.3-06FS
89/07/00
Overview of RCRA USEPA P~lication' 89/07/00
Land Disposal 9347.3-01FS
Restrictions (LDRs)
Superfund LDR Guide '1
(4 pgs.)
Interim Guidance USEPA OIlIER Dir. , 89/09/07 .
on Establ ishlng 9355.4-02
5011 Lead Cleanup
Levell at Superf~
Sftes
(4 Pgs.)
RCRA ARARs.: USEPA OSWER Dir. , 89/10/00
focus on Closure 9234.2-04F5
RIqIri rementl
(6 pgs.)
.
Guidance on Remedial USEPA OMR Dir. , 90/08/15
Actions for Superf~~ 9355.4-01
Sites with PCB
Contami nat i on
Superf~ Management
. Review
Reconmendation 23
(158 pgs.)
-------
. .
",t '0.
07/J3/89
'OIOA'CI Ooco".rs IIOI'-SO"LI',', 10 rll AOII'ISr.ArIVE
"CO'O 1'01' 10. "I ACII SOL".r "CLAIKI'G, I.C. SIrE,
'I..,SAGO coo.r" lL£I.0IS. ooco".rs 'AVI lor "" CO'IIO,
,or A" AVAILA'LI 10. "VI" A' IS"A "G.r OIIICIS,CIGO.IL.
'IrL'
AurlOB
OA',
el.CL. Off-Sttt lolte,;
1"a" 00 tbt Oft-,tt,
lolte, Att.eb,d
DO/DO
e.RCL' O,l",ttoa, of
'atborit, - 'J4-J-A
't.o,,1 jetloa, Co,tla,
Up to $1,'00,000
OS,.. Oir. '9260.2-0J-'
.41D4
CIBCLA Oel".tJoa, ot
!gtbority - 'J4-2
OS"R Oir.'9260.2-02
"'D'
CIRCLA O,l".tloo, at
!gtbarlty - '1'-J4-!
0,ter.l0.tioo, at 1..ioeot
.ad Sub,t.oti.l 'Dd'D"r-
.tot
OS',R Oir. '9260.2-J'-'
.4ID.
C.RCL' Otle,.ttao. at
.atborit, - 'JI-JI~B
Ab,te.tot Aetioo. 'broa,b
Uail.ter.l Order.
OS"R Oir. '9260.2-14-'
-------
. ~ .
.
Pege No.
12/21/90
ACRONYM GUIDE FOR THE ADMINISTRATIVE RECORD. UPDATE 13
ACME SOLVENTS RECLAIMING INC. SUPERFUND SITE
WINNEBAGO COUNTY, ILLtNOIS
; ACRONYM
DEFINITION
AS;
ACIIIe Sol vents
IEPA
Illinois
Environnental
Protection Agency
IPW
let Present Worth
PRC
Plaming Research
Corporation (PRC)
PRP
Potentially
Responsible
Party
CIA/QC
Quality Assurance/
Quality Control
511
S~lelllel.'tal
Technical
Investigation
Report
USEPA
United States
Environnental
Protection
Agency
-------
APPENDIX B
RESPONSIVENESS SUMMARY
ACME SOLVENT RECLAIKI:NG, INC. SITE
WIHHEBAGO COUNTY, ILLINOIS
I.
RESPONSIVENESS SUMMARY OVERVIEW
In accordance with CERCLA Section 117, 42 U.S.C. Section 9617, the
United States Environmental Protection Agency (USEPA) and Illinois
Environmental Protection Agency (IEPA) held a public comment
period from October 5, 1990, to November 5, 1990, to allow
interested parties to comment on the Supplemental Technical
Investigation (STI), Engineering Evaluation/cost Analysis
(EE/CA), Remedial Action Alternatives Evaluation (RAAE), anq
Proposed Plan for remedial action at the Acme Solvent Reclaiming
Inc. (Acme Solvents) site. USEPA and IEPA presented the Proposed
Plan to the public at an October 18, 1990, public meeting, where
questions were answered and comments accepted from the public.
The purpose of this responsiveness summary is to document
comments received during the public comment period and USEPA's
responses to these comments. All comments summarized in this
document were considered in USEPA's final decision for remedial
action at the Acme Solvents site.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The residents near the site on Lindenwood and Baxter Roads have
been concerned about Acme Solvents site contamination since the
. initiation of USEPA and IEPA community relations activities in
1983.
Since 1983, USEPA and IEPA have conducted small. group meetings
and public meetings, and have issued several fact sheets and
letters to residents. Approximately 30 people attended the
October 18, 1990 public meeting, which focused on the results of
the STI and the Proposed Plan for remedial action.
Residents expressed concern at the October 1990 public meeting
about potential health effects from the use of contaminated
groundwater. Although residences have been monitored since 1981,
and bottled water, and subsequently home carbon treatment units,
have been supplied to residents with contaminated well water, some
residents remain concerned. Residents are also concerned about
the declining property value of their homes, however, this concern
seems to derive more from the Pagel's Pit Landfill than the Acme
Solvents site. Residents also expressed frustration at the
Government's apparent inability to stop the 1986 unauthorized PRP
cleanup and in the length of time that.'-has passed from initiation
of a remedial investigation/feasibility study (RI/FS) in 1984 to
-------
2
Residents affected by the proposed water main were invited to a
small group meeting prior to the full public meeting to discuss.
their concerns. They were mainly concerned that the operators of
Pagel's Pit Landfill would have influence over the use of their
well, and might not provide a clean or reliable water supply.
III. SUMMARY OF SIGNIFICANT COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND USEPA RESPONSES
The comments are organized in~o the following categories:
A.
Summary of comments from the local community
1. Comments from residents
2. Comments from Winnebago Reclamation Landfill
, ,
B.
Summary of comments from Potentially Responsible Parties
The comments are paraphrased in order to effectively summarize
them in this document. The reader is referred to the public
meeting transcript and written comments available at the public
repository for further information.
A.
SUMMARY OF COMMENTS FROM THE LOCAL COMMUNITY
1.
COMMENTS FROM RESIDENTS
COMMENT: The residences on Edson Road directly south of the site,
should be hooked up to the water main. Since the contamrnation
comes close to these areas, residents are concerned. that the
contaminants will eventually reach these wells.
RESPONSE: The final decision regarding which residents', will be
hooked up to the water main will be made during the design phase.
and additional sampling will be performed to ensure that all'
residents with contaminated br potentially contaminated water at.
levels exceeding those set forth in the ROD are hooked up.
Residents who are not hooked up will be protected from migration
of contaminants by the pump, and treat system', which will'draw
contaminated water away from residences.
COMMENT: How can USEPA and IEPA be' sure th'at the Pagel's Pit.
water supply will not become contaminated? Pagel's ,Pit operators
have purchased a farm to the north of - the Landfill.:, What will.
happen if they expand the landfill to the north and: contaminate
the water supply well?
RESPONSE:: Water from the Pagel' s: Pit well ',h;as been- tested in the.
past and- has been found to be uncontaminated. However, USEPA'and
IEPA intend to negotiate an agreement with Potentially - -
Responsible Parties (PRPs) which contains standards for the
quality of the water provided to residents. The PRPs will be :-',
-------
3
standards are being met. If the wate~ from the Pagel's Pit well
does not meet these standards, the PRPs must drill a new well away
from contaminated areas which meets these standards. If the
Agencies' enforcement actions are unsuccessful, they will fund the
construction of the water main and make sure it meets these
standards.
COMMENT: The operators of Rockford Blacktop Quarry (north of
Acme Solvents) are blasting the fractured bedrock. This could be
causing further groundwater contamina~ion. The Federal or State
EPA should check on this.
RESPONSE: Some of the wells drilled and sampled for the Acme
Solvents investigation are near the Rockford Blacktop Quarry.
Analyses of samples collected from these wells to date have not
shown any groundwater contaminat~on in this area. USEPA and IEPA
will try to make further inquiry about the extent of blasting
during the design phase to see if these activities may affect the
groundwater, but the information we have collected to date
indicates that this is unlikely. .
COMMENT: USEPA and IEPA should purchase the houses in the area,
rather than spending money remediating the Acme Solvents site.
RESPONSE: CERCLA requires that permanent solutions and treatment
technologies be used to remediate Superfund sites to the maximum
extent practicable. If the Agencies purchased homes rather than
treating the contaminants at the site, contaminants would
continue to leach to the Galena-Platteville aquifer and render a
large portion of the aquifer unusable. USEPA's goal as stated in
the NCP is to restore aquifers to their beneficial uses in a
reasonable timeframe, as well as to prevent harm to future users
of or trespassers on the site due to contact with hazardous
substances. Purchase of the homes surrounding the site, as an
alternative to remediating the site, would not meet these goals.
USEPA's policy is to purchase property as part of a Superfund
remedial action only when the property is needed to perform the
cleanup or when inhabitants cannot be adequately protected from
site contaminants by other means. In this case, inhabitants are
protected from contaminated groundwater through home carbon
treatment units as an interim measure, and an alternate water
supply as a final measure, making the purchase of these homes
unnecessary.
COMMENT: USEPA and IEPA appear to be ineffective in addressing
the problems associated with the Acme Solvents site. They have
done little to clean up~the site. since it was discovered and were
ineffective in stopping the 1986 unauthorized PRP cleanup.
RESPONSE: The 1986 unauthorized PRP cleanup was an unprecedented
-------
..
4
provision was written into the Superfund law to prevent such a
situation from occurring in the future~ The Agencies' dispute
with the PRPs was over the disposal of the contaminated materials.
However, the PRPs' action did result in a net benefit to residents
in that approximately 40,000 tons, or 90 percent of the highly
contaminated soils and sludges were removed from the site. These
materials were not transported to Pagel's-Pit Landfill, as some;
residents suspect. They were transported to permitted hazardous' "
waste landfills in Indiana and Alabama.
In addition, the Agencies have, s~nce ~981, ensured that: residents
received bottled water, then home ~a~bon treatment units, to
protect them from contaminated groundwater. The Agencies have
also provided regular monitoring to ensure that no additional
residential wells have become contaminated. Thus, a large portion
of the needed remediation of the Acme Solvents site has already
been accomplished and the Agencies have assured that residents
have been protected from site contaminants in groundwater since ' -~
1981. -
COMMENT:
Someone should monitor health problems in the: area.
RESPONSE: The Agency for Toxic Substances and Disease Registry
(ATSDR) has established a national exposure registry for personE
exposed to trichloroethene (a contaminant of concern at Acme
Solvents) in drinking water. . Currently, residents in Michigan,
Indiana and Illinois are enralled. There are no plans to 'expand
the registry at this time, however, if the registry is expahded in
the future, residents around the Acme site could be considered.
'COMMENT: Residents near the site observed that during the 1986
cleanup the trucks were not lined to prevent leakage. of
contaminants out of or onto the trucks.
RESPONSE: The persons responsible for the 1986 cleanup have
stated that the trucks used were properly decontaminated. Any
future cleanups at the site will be done with USEPA 'and IEPA -
oversight to ensure that trucks are lined and/or decontaminated.'
, 2.
COMMENTS FROM WINNEBA~RECLAKATION SERVICE,!NC.. .
..
COMMENT: The STI Report for the Acme Solvents: site concludes that-
there are two separate sources of volatile organic chemicals
(VOCs) in the area's groundwater: (1) unremediated soil/sludge
located at the Acme Solvents site; and (2) an unident'ified source
located along the eastern boundary of the Winnebag6 Reclamati'on
Landfill (WRL), or Pagel's Pit, Superfund site, which is located
immediately to the west and downgradient of the Acme Solvents'
site. That finding is not based ,on empirical ,evidence but on
interpretation of .chemical distributions in groundwater.
Winnebago Reclamation Services (WRS) submits that the most
-------
~
5
that location is that it migrated with. the groundwater from the
Acme Solvents site. Acme Solvents disposed of hazardous
materials, including VOCs, in unlined lagoons having direct access
to groundwater. The bedrock underlying the site is highly
fractured and the hazardous substances were ,disposed of in an area
of groundwater recharge. Seasonal variations in recharge and the
change in source concentrations due to various remedial
activities, and the complex behavior and flow of dense solvents
in a fractured medium make it virtually impossible to pinpoint the
source of VOCs without any speculation. However, WRS feels that
the Acme Solvents site is a more plausible source than WRL. The
detection of VOCs in two of three additional wells drilled on the
Acme site and between the two sites further supports WRS's claim
that the source of contamination at the eastern boundary of the
Pagel's Pit site is Acme Solvents. In fact, the evidence suggests
that Acme Solvents is the sole source of VOCs in groundwater in
that area.
RESPONSE: USEPA has stated in several conversations and
correspondence with both Acme Solvents and Pagel's pit PRPs that
additional studies are needed to determine the source of
contamination at the eastern boundary of the Pagel's Pit site.
Review of the Acme Solvents STI Report and the 'pagel's ,Pit draft
RI report shows that arguments can be made for a source at the
Acme site or at the eastern boundary of the landfill. Acme
Solvents PRPs have been cooperative in drilling and sampling
additional wells in an effort to determine the source of
contamination. The Acme Solvents PRP's Northwest Area
Investigation report, available as part of the Administrative
Record for the site, argues that the presence of VOCs in the
additional wells does not indicate that Acme Solvents is the
source of the contamination at the landfill.
USEPA and IEPA are currently evaluating the additional information
provided by the Acme Solvents PRPs in an effort to determine the
source of this contamination. However, Pagel's Pit PRPs have been
quite uncooperative in refusing to perform additional studies as
requested by USEPA. It has been and will continue to be quite
difficult to evaluate WRS's claim that Pagel's Pit is not the
source of this contamination without the cooperation of Pagel's
pit PRPs in performing additional studies.
COMMENT: WRS expects the Acme Solvents site PRPsto fund any
remedial measures that may be required in the areas of the WRL
site attributable to substances originating at the Acme Solvents
site, including but not limited to the VOC plume which extends
under the WRL site. Any Covenant Not to Sue in connection with
any Consent Decree for work performed at the Acme Solvents site
must therefore be strictly limited to work actually done, and
limited to the area where the work is done, and must not purport
to release any claims for remedial action in areas outside those
-------
.
6
RESPONSE: Since this ROD specifically'excludes the contamination
at the eastern boundary of Pagel's Pit Landfill, USEPA .and :IEPA
anticipate that this area of contamination will also be excluded
from Consent Decree negotiations. USEPA and IEPA do not in~end to
relaease Acme Solvents PRPs (or Pagel's Pit PRPs) from any',
potential liability associated with this area of gro,und:water.
contamination at this time. ~
COMMENT: WRS urges that the remedy chosen in the Record of'"
Decision (ROD) regarding the Acme Solvents site be no less " ,
stringent than that proposed in EPA's Proposed Plan for the' s'ite.
The WRL site is downgradient of Acme Solvents. If the WRL site
were not a waste disposal facility, the remedies selected at Acme
Solvents would undoubtedly attempt to eliminate any downgradient
contamination attributable to Acme Solvents as promptly an~ as:
thoroughly as possible. Instead,.however, the PropClsed Plan
indicates that because the WRL site is a landfill, addition"al
study and delay in implementing remedying the impact of Acme ,
Solvent on WRS are acceptable. The Acme Solvents remedy should.be
implemented to address the entire area impacted by the Acme" '
'Solvents site, including the area southeast of the WRL facility.
RESPONSE: The delay in implementation of a remedial action ,at the.
southeast corner of Pagel's Pit is' not because the area in
question is a landfill. This delay is solely due to thef~ct that
addi tional time is needed to better identify the sources of this'
contamination. In fact, Pagel's Pit PRPs have played a large part
in causing this delay by refusing to perform additional studies
necessary to determine the source.
COMMENT: WRL urges that the design and implementa:tion of remedies
at Acme Solvents be coordinated with ongoing inves:tigation 'or
remediation at the WRL and with the ongoing operat'ion of theWRL.
Th~ well locations~ recharge points, access controls, water'
supplies, ongoing monitoring', pilot tests, and vir.tually 'every,
other element of the Acme Solvents remedy will be ,more effective
if open cooperation and communicationwith:WRS (and the Pagels'
Landfill 'Steering Committee) are encouraged by' your agency.
RESPONSE:,. USEPA and IEPA agree with 'this comment and continue to
encourage cooperation and communication between Acme Solvents'
PRPs, Pagel's Pit PRPs, and the Agencies regarding.. matters that
affect both sites. .
.
B.
COMMENTS FROM POTENTIALLY RESPONSIBLE:PARTIE~
COMMENT: Many former' customers of Acme have not received a' copy
of the Proposed Plan for remedial action and have not been.
participating in discussions with the Agencies regarding, the'pla~
USEPA appears to be targeting for enforcement actions only a sma
-------
7
companies are being asked to shoulder a disproportionately large
.share.of the response costs.
RESPONSE: USEPA intends to send Special Notice Letters informing
PRPs of the start of negotiations for implementation of the
remedial action to all known PRPs. USEPA sent a General Notice of
Potential Liability to approximately 65 PRPs on June 8, 1990 and
sent the Proposed Plan on October 5, ~990 to the same group. The
current PRP service list for Acme Solvents is attached to the
June 8, 1990 letter. Several PRPs did not receive this letter or
the Proposed Plan because USEPA. has no, incorrect, or incomplete
addresses. USEPA is currently attempting to update this
information and welcomes information from the public or PRP
community which would allow us to supplement our PRP list.
COMMENT: The Acme Solvents. Settlors Coalition generally endorses
USEPA's identification of preferred alternatives for cleaning up
the Acme site. In particular, the Coalition believes that the
bifurcated approach identified by USEPA for cleaning up source
areas in Phase I and contaminated soils, bedrock and groundwater
in Phase II is appropriate. The Coalition agrees, in general,
that the preferred response alternatives identified by USEPA would
protect human health and the environment, would comply with ARARs,
would be cost effective, and would use permanent solutions and
alternative treatment technologies to the maximum extent
practical.
RESPONSE:
No response necessary.
/ .
COMMENT: USEPA has employed a residential future use scenario in
arriving at a groundwater cleanup level of 10-5 lifetime excess
cancer risk (LECR). The Settlors Coalition remains convinced that
employment of a non-residential future use scenario would be more
appropriate. Given such a scenario, coupled with institutional
controls, alternative water supply, and a RCRA cai' groundwater
clean-up levels of 10-4 (or something between 10- and 10~5) LECR
would be justified, sufficiently protective, and more cost
effective. Maximum contaminant levels (MCLs) should be used as
the clean-up level for substances having MCLs.
-
RESPONSE: USEPA and IEPA disagree that a residential future-use
scenario is inappropriate for the Acme Solvents site.' The
residential future-use scenario is consistent with current land
use near the site and existing zoning restrictions, which allow
for one single-family home per 40 acres. .In addition, the NCP
states that "groundwater that is not currently a drinking water
source, but is potentially a drinking water source in the future
would be protected to levels appropriate to use as a drinking
water source." There are residential wells drawing from the
Galena-Plattville aquifer in and near the contamination plume,
making ~he aquifer unquestionably a current and potential source
-------
8
.
Aside from the residential use issue, USEPA and IEPA have
considered the comment that MCLs set under the SDWA-should be
used to set cleanup levels in groundwater. Because: the
concentrations of many of the contaminants of concern at the 10-5
LECR are well below analytical detection levels, and because of
the technical difficulties associated with aquifer remediation in
fractured bedrock, the Agencies have determined that this comment
has technical merit. Accordingly, aquifer remedia:tion goals have
been set at 10-5 LECR (or a hazard index of 11 for 1,1-DCE and
contaminants without MCLs, ~nd MCLs, proposed, MCLs, or non-z.ero
MCLGs for contaminants wit~ MCLs and MCLGs. ' ,
COMMENT: The preferred alternative for source areas (Phase'I)
calls for residuals left over from low-temperature thermal'
stripping (LTTS) to be solidified if TCLP standards for metals are
exceeded, then covered by a RCRA cap (if landfilled on-site). '
Solidification and capping would be unnecessarily redundant,: not
optimally cost-effective, and not required under the NCP.
Solidification or capping of residuals would be sUfficiently
protective, cost-effective and otherwise consistent with the'BCP
RESPONSE: The wording of the ROD has been changed slightly from
that of the Proposed Plan. The Proposed Plan required that metals
in residuals landfilled on-site meet both RCRA TCLPstandards and-
RCRA Treatability Varia~ce standards for soil and debris. Since'
these two sets of standards are very similar for metal,s, and the
Treatability Variance standards are frequently lower than TCLP ,
standard, USEPA has determined that requiring that only
Treatability Variance standards be met will be sufficiently
protective. .
Attainment of Treatability Variance standards is required under
RCRA Land Disposal Restrictions (LDRs, 40 CFR Part 268)., , The'se'
regulations set treatment standards that must be achieved be~ore '
any land disposal of hazardous substances. Since either ,'on-site -
or off-site disposal of LTTS residuals constitutes "land
disposal", Treatability Variance standards mUst be met in order to
comply with RCRA ARARs. These standards are required under, the
NCP and CERCLA, as they both require that all ARARsbe met, unless
a waiver is obtained. '
Also, since the ROD does not require that a liner b~ constructed
under materials landfilled on-site, and no cap is 'clOO% effective,
these standards and the additional standards provided 'in the ROD
will provide further assurance that contaminants will not, leach to'
groundwater. : '
COMMENT: Implementation of many of the,: particulars of the
preferred alternatives will depend upon the results of
treatability studies, pilot testing, and selection of appropria~
-------
~
9
of remedial design. Accordingly, the Record of Decision should
not attempt to answer questions that are more appropriately
addressed in the remedial design phase of th~ clean-up. In
particular:
a.
The disposition of residuals from treated source materials
depends on the result of TCLP testing. Whether source
material residuals are to be solidified, landfilled on site
or landfilled off-site should not be specified in the ROD.
b.
The cleanup levels applicable to the delineation of source
materials, and selection of a methodes) for measuring such
cleanup levels should be left to remedial desi~n.
Delineation of areas to be covered by a RCRA cap depends upon
the disposition of source material residuals and efficacy of
soil and bedrock vapor extraction, among other factors, and
should be left to the remedial design.
c.
d.
Where and how the efficacy of soil and bedrock vapor
extraction is measured depends on pilot testing, delineation
of areas to be capped, and potential for groundwater
contamination, among other factors, and should be left to
remedial design. The Settlors Coalition recognizes that
USEPA believes the efficacy of soil vapor extraction should
be measured in the soil matrix (as opposed to the off-gas
stream). However, the point of measurement should not be
specified in the ROD, but would be better determined in the
remedial design and as the remedial action progresses.
e.
The need for and methods of off-gas treatment, and disposal
of residuals from off-gas treatment, from low temperature
thermal stripping of source materials and soil/bedrock vapor
extraction should be left to the remedial design.
The source of a permanent water supply for nearby residences
should be left to the remedial design.
RESPONSE: Responses are provided in the sam~ order as the
comments above:
f.
a.
The ROD allows for on- or off-site disposal of treatment
residuals.
b.
USEPA and IEPA disagree with this comment. Cleanup levels
for source materials have been specified in the ROD in order
to ensure an adequate cleanup of the source areas.
c.
USEPA and IEPA agree that further study is needed to
delineate areas to be covered by a RCRA cap. These areas are
-------
.
10
d.
A cleanup standard set in the soil matrix is necessary. to
ensure that the soil vapor extraction is adequately designed
and implemented to protect human health and the environment
by preventing further migration of VOCs to groundwater.
USEPA and IEPA do not favor measurement of VOCs in the off- .
gas stream because it provides little information a~out the
concentrations remaining in the soils and available to leach
to groundwater. USEPA and IEPA recognize, however, the
difficulty in setting and achieving cleanup standards in soil
for vapor extraction and have set two cleanup standa~ds, a
less stringent standard, which will require a RCRA cap, and
more stringent standard, which will not require a RCRA. cap.
The ROD does not specify whether or what type of off-gas
treatment will be required for any of the treatment
technologies. It does state minimum air emissions standards
which may not be exceeded during the remedial action, in .
order to ensure that the remedial action does not result in .
an increased health risk to downwind residents and workers. :
In addition all Federal, state, and local ARARs regulating
air emissions must be met. Off-gas treatment will be
required if any of these standards maybe exceeded'. during. t
remedial action.
e.
f.
The ROD provides two options for an' alternate water supply
well: the Pagel's Pit water supply well or a new well drilled
into the st. Peter Sandstone upgradient of site'
contamination.
COMMENT:
that 129
the Acme
included
The Acme Solvents PRP Steering Committee has requested
documents be included in the Administrative' Record for
Solvents site (a complete index of these documents is
in the Administrative Record).
.
RESPONSE: USEPA, consistent with the guidance set forth in. .the'
NCP, has reviewed the documents submitted by the PRPs. The.NCP '.
counsels,' "The lead agency shall establish an administrati~e
record that contains the documents. that form the basis for the
selection of a response action......' It goes' on to strte, . liThe
lead agency is not required to: include documents in the' .
administrative record file which do not form: a basis: for the
selection of the response action. Such documents include, but are
not limited to, draft documents, internal memoranda,: and day-to~
day notes of staff unless such documents contain information that.
forms the basis of selection of the response action :and the'
information is not included in any other. document in the" .
administrative record file.~
Many of. the docments submitted for inclusion were draft documents
which were not relied upon for the selection of a remedy. other
documents contained information which could be found in document
-------
11
.r ..
documents .included in the index are already in the Administrati¥e.
Record (see Appendix A.) still other documents chronicled events
which were irrelevant to the process by which the remedy ~as' _.
selected.
. . .
Some documents, however, were relevant to the remedy selection::
. . ..."
process and, to date, had not been 1ncluded 1n the Adm1n1str.at~ve
Record.. These documents were added to the Administrative Recora.
Specifically, the following documents were added:
September 1, 1989 letter to Allison Hiitner from Fred Marineii~~
re: additional aquifer tests. . .t
August 11, 1990 Northwest Area Investigation Final Report by
Harding Lawson Associates.
August 20, 1990 letter to Allison. Hiltner from Brian LaFlamme r~:
residential water supply analytical data.
------- |