SEPA
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
c.r«/nuu/rvu j-o D/u 1U
March 1985
Superfund
Record of Decision:
Byron/Johnson Salvage Yard, IL
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BYRON SALVAGE YARD, IL
Record of Decision
Abstract
'!he Byron (Johnson) Salvage Yard site is located four miles south-
west of Byron, Illinois and consists of 20 acres of WCXJd1ands in a rural,
agricultural area. The - yard operated during the 1960 I S and early 1970 I S
as a salvage yard and unpermitted landfill. Ibnestic refuse and indus-
trial drums have been collected and sanetimes buried on-site. Ten
surface water sampling points fran nearby Woodland Creek and Rock River,
and three ground water sarrp1ing points have yielded high concentrations
of cyanide and other toxic chemicals including lead, arsenic, halogenated
organics, and low-level PCB's.
The selected remedy for the Byron Salvage Yard site consists of
off-site disposal of all surface and buried drums, off-site disposal
of highly contaminated soils Which exhibit the EP toxicity characteristic,
and in-situ treatment with sodium hypochlorite and arruronia of all contam-
inated soil containing greater than 1 ppTI cyanide. Off-site disposal
YJOu1d include disposal at a lined, RCRA approved landfill and, if possible,
incineration or treatrrent of liquids. Total capital cost for the selected
remedial alternative is estimated to be $1,170,919, and operations and
naintenance costs are estinated to be an additional $6000 per year.
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Record of Decision
Remedial Alternative Selection
Site: Byron/Johnson Salvage Yard, Byron, Illinois
Documents Reviewed:
I have reviewed the following documents describing the analysis of the cost-
effectiveness of the remedial action alternatives for the Byron/Johnson Salvage
Yard, Byron, Illinois
- Remedial Investigation, Feasibility Assessment for Remedial Cleanup at Byron/
Johnson Site, June 1984
- Feasibility Study, Remedial Action Byron/Johnson Site, June 1984
- Byron Salvage Yard Remedial Alternative Cost Estimates, October 1984
- Summary of Remedial Alternative Selection, Byron/Johnson Salvage Yard, Byron,
Illinois, March 1985
- Community Relations Responsiveness Summary for Byron/Johnson Salvage Yard,
Byron, Illinois, October 1984
Description of Selected Remedy;
- Off-site disposal of all surface and buried drums on the Salvage Yard site
- Off-site disposal of highly contaminated soils which exhibit the EP toxicity
characteristic
- In situ treatment with sodium hypochlorite and ammonia of all soil that contains
cyanide over 1 ppm
- Off-site disposal would include disposal at a lined RCRA approved landfill and,
if possible, incineration or treatment of liquids
Declarations:
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), and the National Oil and Hazardous Substances
Contingency Plan (NCR), 40 CFR, Part 300, I have determined that taking an
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off-site disposal action at threshold levels is ~ cos~-effective remedial action
that provides adequate protection of public health, welfare, and the environment.
The State of Illinois has been consulted and agrees with the approved remedial
action. In addttion, the action will require interim future operation and main-
tenance activities to ensure the continued effectiveness of the remedy until the
modified remedial investigation/feasibility study that addresses complete soil and
aquifier cleanup is completed.
I have also determined that the action has been approved for funding from the
Hazardous Substance Response Fund.
Ia~f
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Summary of. Remedial Alternative Selection
Byron (Johnson) Salvage Yard
Byron, III i noi s
SITE LOCATION AND DESCRIPTION:
The Byron (Johnson) Salvage Yard site consists of approximately 20 acres of
wooded land located about 4 miles southwest of Byron, Illinois and about 10
miles southwest of Rockford, Illinois. General domestic refuse and industrial
drums have been collected and sometimes buried on-site. The site is presently
inactive.
The site is in a rural, primarily agricultural area. The Byron (Johnson)
Salvage Yard is located in the Woodland Creek drainage basin and is on uplands
that are dissected by several small ravines trending north and northeast.
Woodland Creek is about two and three-quarters miles long and empties into
the Rock River. The headwater of the "Ravine Waterway", an intermittent tri-
butary of the South Fork of Woodland Creek, lies within the area of this site.
Surface elevations vary between 740 and 860 feet above mean sea level.
The Byron nuclear power plant is situated to the immediate southwest of the
site. The nuclear power plant is under construction ~ the Commonwealth'
Edi son Company.
SITE H I STORY:
The Byron (Johnson) Salvage Yard, formerly called the Johnson Salvage Yard,
operated during the 1960's and early 1970's as a salvage yard and unpermitted
1 andfi 11 .
The Illinois Environmental Protection Agency (IEPA) inspected the Salvage
Yard for the first time on October 23, 1970. Since the early 1970's the IEPA
has conducted field inspections at the Dirk Farm, located west of the Salvage
Yard site, across Razorvi11e Road. This farm was bought by the Commonwealth
Edison Company (CEC) later. Three dead cattle were found on this property in
May of 1974. The c~se of their death was later attri buted to cyanide poison-
ing.
,
Subsequently, the CEC retained Dames and Moore (DM), a consulting firm, to
determine the extent of contamination and to recommend remedial actions which
were later implemented by CEC to remove primarily cyanide in the soils. OM
made a detailed study in the area. Although this study is pri~cipa11y for
the Dirk Farm, it covers all neighboring areas, to some extent, and some of the
findings are also applicable to the Salvage Yard. OM's study indicated that
wastes, containing lethal concentrations of cyanide, arsenic, cadium, and
chromium were dumped and/or buried in containers on and adjacent to the CEC
property, including the Salvage Yard. Blood tissue samples from the dead
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cattle had high concentratlons of cyanide and other toxic chemicals. It was
concluded that local groundwater was not substantially contaminated. On the
other hand,"samp1es from Woodland Creek near the Yard contained an excessive
concentration of cyanide and other toxic chemicals.
Reportedly, cyanide containing plating wastes were sprayed onto Razorvil1e
Road, the roads in the Byron Salvage Yard, and onto the road in the area of
Motosport, Inc., located immediately northeast of the site. Such wastes were
dumped into the ravines (South Waterway and West Waterway) on the north and
east parts of the Yard. Liquid wastes were dumped and barrels were buried
, behind a man-made dam, and around a big tree near the south fence of the
Salvage Yard.
In DM's report (1974), the head of a gully adjacent to the Salvage Yard was
identified as a major contaminant source, which is situated about 900 to
1,200 feet to the east of Razorvi11e Road. This location appears to be the
head of West Waterway and was identified on the basis of numerous barrels
which were lying on the ground or partially buried. It appears that there
were several waste burial locations in the Yard.
On June 10, 1981, through August 7, 1981, ten surface water and three ground-
water sampling points were used to collect a total of 101 water samples by
IEPA. Some of these sampling points are in waterways in which the flow is
intermittent, such as after heavy rainfalls. The result of these sample
anay1ses show that cyanide seems to be leaching from the Salvage Yard site
into the surface and subsurface drainage ways of the upland areas. No cyanide
was found in private wells, however, trichloroethylene (TCE) in concentrations
up to 710 ppb in some cases has been found in nearby private residential
drinking water wells to the north and south of the site.
In 1983 a State lead cooperative agreement was signed. A remedial investi-
gation/feasibility study (RI/F,S) was conducted by D'Appo10nia under contract
to IEPA.
Current Site Status:
The approximately 2~-acre site is presently inactive. General rubble and
domestic refuse such as refrigerators, old cars and car parts are scattered
throughout the site. Mos~ of the drums are buried; but some surface drums
can be noted throughout the general area of the site. Most of these surface
drums appear to have been burned at one time. Exposed parts of drums can be
seen.
According to the RI that was done ~ D'Appo1onia there are 504 surface drums
on-site and an estimated 11,400 buried drums. The contaminants in some of
the drums are lead, arsenic, cyanide, halogenated organics, and low level
PCB's. Some of the drums are noted to be flammable according to the closed
cup flash test (under 140 degrees Farenheit). '
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.
A summary of the types of drums identified on the:surface and an estimate of
the nature of buried drums are presented on Table 1 (see page 4). This inform-
ation was generated by D'Appo10nia.
-
The estimates for excessively contaminated soil on-site is approximately
3,600 cubic yards. The ~oi1s are contaminated with lead, nickel, zinc, cya-
nide, and organic halogens according to the RI report.
TCE as high as 710 ppb has been found in some of the nearby residential.
wells. All the .residents in this area have individual home water wells since
there is no c10se-~ town. The affected residents are presently on bottled
water supplies from the U.S. EPA under an immediate removal status. The
source of the TCE is not certain at this time; however, TCE has been found in
at least two test pit locations on the Salvage Yard site. The aquifer of
concern is the Ga1ena-P1attevi11e and possibly the St. Peter aquifer systems.
Most of the private residences that are affected are located northwest of the
site. However, there is one contaminated well that is located directly south
of the site. There appears to be a groundwater divide on the Salvage Yard
that runs from the southeast to the northwest beneath the site, plunging to
the northwest. A RI/FS will be conducted by CH2M-Hi11 to more fully address
groundwater contamination. In addition, the RI/FS will address residual
soil contamination remaining after completion of the action recommended in
this Record of Decision and supplement the State lead RI/FS done ~
D'Appo1onia.
ENFORCEMENT:
State Actions:
In 1974, the IEPA filed a complaint with the Illinois Pollution Control Board
against owners of the Salvage Yard, Wilford E. Johnson and Norma J. Johnson.
The complaint was concerning the water pollution which resulted from the waste
disposal work. The basis for the complaint was field inspections, picture
taking, interviews, and collection and analyses of waste, surface water, and
groundwater samples. These samples were collected until 1981 by the IEPA in
order to monitor the environment in and around the Salvage Yard. This investi-
gative work revealed that cyanide-containing plating waste was sprayed onto
the roads in and around the Salvage yard, and that plating wastes and other
wastes with or withoht containers were dumped and buried in the area of the
Salvage yard. These activ{ties resulted in high concentrations of cyanide and
toxic metals in soils, surface water, and groundwater which have decreased
over time since the Salvage Yard stopped operations. Despite the IEPA filed
complaint, the site still has not been cleaned up. The site has been inactive
since 1973.
The ownership of the property has changed in the past 5 years.
Mr. Wilford E. Johnson, the original owner of the property, failed to pay
property taxes, and the land was transferred to Ogle County. The county sold
the property to Mr. Dean Johnson. Mr. Dean Johnson sold a portion of the
property to CEC. In November of 1980, Mr. Dean Johnson sold the remaining
property to Mr. Bill Schnabel, the present owner of the west 7.5 acres of
the property. Mr. William Mosley owns the east 2.5 acres of the property.
Mr. Delos Blanchard, who in 1984 was placed in a nursing home, own5 the.
southern 10 acres of the site.
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Table 1
Summary of Types of Drums
Type of Drum On Surface1 Buried2 Total
LiquidS 68 77 145
Sludges 17 19 36
Sol i ds 11 7 1.323 1.440
Non-hazardous was tes - 46 520 566
Empty 256 9.461 9.717
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Totals 504 11 .400 11 .904
1 - Inventoried and analyzed
2 - Estimated
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Federal Actions:
At the initiation of the RI/FS and with IEPA concurrence, notice letters were
sent by the U.S. EPA to the present and past operators and owners of the
site Qy certified mail. No negotiations have been scheduled or are antic-
ipated as a result of these notices.
Since the completion of the RI/FS, it was noted that some of the wastes were
on the CEC property.
Also, the IEPA has sent to U.S. EPA some documentation which indicates that
the companies of Roto-Rooter and National Lock were potential disposers of
waste products at the Salvage Yard.
Prior to providing bottled drinking water to the nearby residents, the land
owners and the above mentioned companies were verbally notified by the U.S.
EPA. The verbal notification was given to permit the potentially responsi ble
parties to initiate this immediate removal action. Written letters were sent
by Regional Counsel which re-stated to the potentially responsible parties-
what was verbally read to them over the telephone.
Prior to remedial design/remedial action and with IEPA concurrence, notice
letters were sent to the present and past owners and operators of the site,
Letters were also sent to CEC, Roto-Rooter, and National Lock. Settlement
is not anticipated. The notified parties have not expressed any interest in
negotiating or settling this matter. Many of the notified parties apparently
have insufficient funds to perform the cleanup. Others apparently feel that
they are not responsi b1e for the cleanup or do not choose to participate at
the present time. Based on this assessment of the parties, no administrative
orders wi 11 be sent by Regi ona 1 Counsel.
ALTERNATIVES EVALUATION:
Remedial Objectives:
In accordance with the National Oil and Hazardous Substances Contingency Plan
(NCP), 40 CFR, Secti~ 300.68, the objective of the D1Appolonia RI/FS was to
identify and evaluate reme~ial action alternatives and to provide information
necessary to select the most appropriate, cost-effective, and environmentally
safe method(s) for the prevention of further contamination and mitigation of
existing contamination at the Byron/Johnson site.
Alternatives Considered:
The following remedial action alternatives were considered:
1. No Action
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2.
Source Control
- Removal of surface and buried contaminants !nd contaminated soils
to background 1 evels . Di sposa 1 of remO.ved wastes and cant ami nated
soils at a licensed off-site hazardous waste disposal area.
- Removal of surface and buried contaminants and contaminated soils to
threshold levels. Disposal of removed wastes and contaminated soils at
a licensed off-site hazardous waste disposal area.
- Removal of surface and buried contaminants and contaminated soils to
threshold levels. Placement and covering of removed non-liquid wastes
in the east ravine. Incineration of liquid wastes at a licensed
hazardous waste incineration facility.
- Removal of surface and buried contaminants and contaminated soils to
background levels. Disposal of removed wastes and contaminated soil
in an on-site earthen vault.
- Removal of surface and buried contaminants and contaminated soils to
threshold levels. Disposal of removed wastes and contaminated soil in
an on-site earthen vault.
- In situ treatment of surface and buried contamination.
3. Off-site Control
- Relocation of residents to unaffected areas.
- Provision of alternate water supplies for affected
- Treatment of groundwater prior to usage.
Initial Screening of Alternatives:
residents.
As required by the NCP, the above alternatives were initially screened using
the criteria of estimated costs, effects of the alternative, and acceptable
engineering practices. The following alternatives were eliminated from
further consideration:
1.
No Action. This alternative was rejected because it was judged to be
ineffective in preventing further contamination and would nQt mitigate
existing contamination at the site. High concentrations of buried and
surface wastes w&re found at the site. These wastes are situated over
bedrock formations wh;.ch may have enlarged solution openings along joints,
fractures, and bedding'planes along which these wastes could possibly
travel and reach groundwater supplies. TCE has been fo~nd in nearby
residences and may be coming from the site.
In situ treatment of surface and buried contamination. The heterogeneity
of hazardous materials previously dumped at the Salvage Yard, and the
presence of unknown quantities of buried wastes, suggest that in situ
treatment techniques may have very limited applicability. This alter-
native was eliminated from further consideration because no proven appro-
priate physical, chemical, or biological treatment techniques were ident-
ified that could treat all the various wastes of concern. However,
limited in situ treatment of cyanide wastes has been incorporated into
some of the alternatives remaining.
2.
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Off-site control remedial alternatives. Considerable uncertainty still
exists concerning the extent and source(s) Of. groundwater contamination.
The D'Appolonia RI/FS did not address this matter. Therefore. all off-
site control remedial alternatives were ~liminated from further consider-
ation at this time and will be evaluated after a site hydrogeological
investig.ation is conducted (see future actions).
Detailed Description of Remaining Alternatives:
3.
All the alternatives include liquid wastes that may be incinerated. treated. or
solidified to the extent of not releasing liquid under overburden pressure. A
detailed descri~tion of the five remaining alternatives follows:
1. Off-site disposal (background levels). This alternative consists of re-
moval and off-site disposal of surface and buried hazardous wastes. includ-
ing contaminated soil. As per the D'Appolonia RI/FS report. surface soil
on the entire 20-acre site is contaminated above background levels and will
require removal to a depth of 1.5 feet. Buried wastes to be removed con-
sist of those wastes previously placed in the east and west ravines. In
addition. contaminated soil from two test pits would be excavated.
All excavated wastes would be staged at the site. prepared for shipment.
and trucked to permitted hazardous waste treatment, storage, disposal
(TSD) facilities for final disposition. Liquid wastes would be incinerated
(cost estimates are based on the SCA liquid hazardous waste incinerator
located near Calumet City. Illinois). Non-liquid hazardous wastes and
contaminated soil will be removed to an approved landfill (cost estimates
are based on the Chemical Waste Management landfill disposal area, also in
Calumet City). All hazardous wastes will be placed in cells which meet
RCRA requirements. Hauling distance from the Byron site to Calument City
is approximately 100 miles one-way.
2. Off-site disposal (threshold levels). This alternative consists of removal
and off-site disposal of surface and buried hazardous wastes. including.
soils contaminated above a defined threshold level. The EP Toxicity
characteristic, as defined under 40 CFR 261.24. will be used as an indicator
for highly contaminated soils which should be removed as part of the source
control measure. Test methods descri bed in 40 CFR 261.24 will be applied to
soil samples. Soil leachates are to be analyzed for the metal contaminants
listed in 40 CFR ~61.24, Table I. Soils with 1eachates that have metal
concentrations exteeding 100 x drinking water standards will be designated
for removal. This apprQach is adequate to determine a cut-off for highly
contaminated soil because the residual contamination will be evaluated in
the subsequent RI/FS to determine if the residual contamination requires
remedi a 1 act ion. The impact of su bsequent mi grat ion f rom the site will be
reduced due to significant reduction of the on-site contamination. The
next phase of the RI/FS will address residual contamination at the site
which may contribute to the groundwater contamination.
As with the previous alternative, liquid wastes would be incinerated; and
non-liquid wastes and contaminated soil would be 1andfil1ed. Clean fill
would .be placed in excavated areas where contaminated surface soil was
removed and in the two ravines.
In situ treatment would be provided for areas where cyanide contamination
in surface soil exceeds 100 times the level recommended for protection of
human health and aquatic life. i.e.; .01 ppm as defined in the Ambient water
Quality Criteria for Cyanides, EPA 440/5-80-037. October 1980. Tr~atment
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would consist of spreading sodium hypochlorite in these areas and tilling
the upper 6-12 inches of soil. Liquid ammonia would then be sprayed on
these areas, and the soil would be tilled again. A minimum of 2 days
would then be allowed to pass before placement of clean fill over the
areas.
3. On-site disposal -- containment (threshold levels). In this alternative,
only liquid hazardous wastes removed from the surface are hauled off-site
and incinerated. Contaminated surface soil, drummed solid wastes, and the
limited materials in the west ravine would be taken to the east ravine and
used to bring this area to grade. A low-permeability cap of 2 feet of
clay and a synthetic membrane would be placed over this area to minimize
future surface water infiltration and there~ eliminate the mechanism for
groundwater degradation. This would be covered by a 12-inch thick blanket
of clean sand and gravel, or equivalent, which would act as a flow zone to
minimize the hydraulic head on the membrane and allow for a conduit for
discharging infiltrating waters. A 12-inch blanket of topsoil would be
placed above this flow zone as the vegetative growth medium. The surface
would be seeded and mulched to limit potential erosion. A permanent chain
link fence would be constructed around this closure area.
In situ treatment of cyanide contaminated surface soil, as described pre-
viously, would also be provided as part of this alternative.
4. On-site disposal - vault (background levels). This alternative would
consist of construction of an on-site earthen vault for the disposal of
surface and excavated wastes and contaminated soils. Liquid wastes or
other materials not fully amenable to on-site 1andfilling would be trucked
off-site for incineration. The on-site vault would satisfy RCRA require-
ments and include liners, a leachate collection and detection system, and a
multi-layered cap.
An area in the southwest portion of the site would be cleared and exca-
vated for construction of the vault. The removed soil would be used to
construct a surface water runoff diversion dike around the vault area.
The liner would consist of dual synthetic membranes, with an overlying
leachate collection system and leachate detection systems beneath each
membrane.
Contaminated soil.ould be placed in the vault in thin lifts, and compacted
to the extent practical ~o fill the vault area. Drums would be placed
either in single layers ~sandwiched by contaminated 50il) or crushed and
compacted to the extent practical.
A 2-foot layer of compacted clay (permeability not greater than 1 x 10-7
centimeter per second) would be placed atop the waste as the lower com-
ponent of the cap. A synthetic membrane would be placed atop the clay
taken from vault excavation, which will in turn be overlain by a blanket of
sand and gravel to serve as the flow zone and a blanket of topsoil as the
veget at i ve growth .medi um.
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5. On-site disposal - vault (threshold levels). This alternative is similar
to the previous one (on-site disposal - vault .(background levels)) with
the exception that surface soils would 0~1y be" removed if contaminant
concentrations exceed t~reshold levels. The same threshold limits have
been defined for this alternative as for off-site disposal threshold
levels, f.e., 100 times primary drinking water standards.
Detailed Evaluation of Alternatives:
The effectiveness and ramifications of these alternatives were evaluated on
the basis of cost, public health considerations, environmental consider~tions,
technical considerations, and public reaction and acceptability. A compara-
tive evaluation of the alternatives is presented below and summarized in
.Table 2.
Off-site disposal (background levels). Implementation of this alternative may
be impractical or very difficult due to the manner in which waste materials,
both hazardous and non-hazardous, were originally deposited on the site. Con-
sequently, it is estimated that 51,400 cubic yards of contaminated soil would
have to be removed from the site in order to reduce residual concentrations to
background levels.
This is the highest cost alternative evaluated (total estimated cost
$7,257,430). The greatest portion of this cost (approximately $4.2 million)
is associated with transportation and disposal of the removed wastes and con-
taminated soil.
This alternative would achieve the highest level of cleanup of those evaluated
and would most effectively eliminate potential pathways of migration. Because
it entails the greatest amount of off-site hauling, it presents the greatest
possibility of human exposure during transport.
Implementation of this alternative could allow release of the site for future
usage. Although future use (either partial or full) may be possible with.
other alternatives, its chances are considered greatest with this alternative.
Off-site disposal (threshold levels). This alternative entails off-site dis-
posal of the same quantities of hazardous wastes as the off-site disposal
(background levels) alternative, but considerably less quantities of contamin-
ated soil (3,600 cu &ic yards versus 51,400 cu bi c yards). Consequent ly, the
estimated cost to impleme~t this alternative is reduced to $1.170,919.
",
In comparison to the off-site disposal (background levels) alternative, this
option does not present as high a degree of site cleanup or as sure a protect-
ion of groun~water resources, but it does provide for cleanup of highly con-
taminated surface soils. Residual contamination will be addressed in the
upcoming RI/FS along with off-site contamination impacts, if any.
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Jle 2
Summary of Detailed Evaluation of Alternatives
Costs(x$I,OOO) Public Health Environmental Technical Public
A~terna_~i_v!__-Iapita~__O&~-- P. Wort~~~onsiderations ---u- Conside!_atio_n~__--- Consi~~_ati_o!!.s_____~mment ----
Off-site
disposal
( back ground
levels)
Off-site
disposal
(threshold
levels ).
.
On-site"
disposal
containm't.
( background
levels)
On-site
disposal -
vault
( background
I eve 15)
On -s ite
disposal -
vault
(threshold
levels)
$7,257
$1,170
$284
$2,292
$922
$6.0
$6.0
$14.7
$50.4
$21.8
$6,893 - Most effectively
e 11mi nates on-
s He exposure
- Potential exposure
during cleanup
& trucking
$1,179 - Not as effective
as removal to back-
ground levels
- Potential exposure
after cleanup
$409 - Greatest risk of
groundwater con-
tamination
$2,721
- Should effectively
protect against
exposure
$1 , 108
- Should effectively
protect against
exposure
*Basis: 10% annual interest rate; 20-year life
- Achieves highest
site cleanup
- Most effectively
eliminates poten-
tail pathways of
migration
- Major sources of
contamination are
removed
- Achieves lowest
level of cleanup
- No assurance that
wried wastes
won't contaminate
groundwater
- Potential sink
hole problems
- Not as effective
as off-site dis-
posal
- Worst aesthetic~
- Not as effective
as off-site dis-
posal or removal
to background
I eve I s
- Bad aesthetics
- Potential sink
hole problem
- Leas t ri sk of
f ail u re
- No O&M require-
ments
- Shortest time
to implement
No O&M require-
ments
- Greatest risk
of failure
- Design of cap
requ ired
- Inspection &
maintenance
requi rements
~ Longest time to
implement
- Design of vault
requi red
- Greatest inspec-
tion & maintenance
requirements
- Design of vault
required
- Inspection &
maintenance
requ ired
Supported by
cOl1lnuni ty
Supported by
comnuni ty
Least
accepta bl e
alternat ive
less
acceptable
than off-
site
disposal
less
acceptable
than off-
site
disposal
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This alternative offers the advantages of minimal operationaf and maintenance
requirements after implementation, and relative1~.a short time to implement.
Potential threats to public health due to an..accident during trucking to the
disposal site are less than. for the other off-site disposal alternative, but
greater than for any of the on-site disposal options.
. .
This alternative is favored by the local community.
On-site disposal - containment (threshold levels). This alternative is the.
lowest cost of those evaluated. It presents the lowest level of site cleanup
and, hence, the greatest risk of failure. Because it does not include exca-
vation and removal of wastes buried in the east ravine, it offers no long-term
assurance that these contaminants will not eventually be released and migrate
to the aquifer through lateral and vertical migration routes.
The local community has indicated disfavor with this alternative.
On-site disposal vault (background levels). This alternative offers cleanup
of the site to the same level as off-site disposal (background levels) with
the exception of that area on the site where the vault would be located. Re-
quired dimensions for the truncated pyramid vault would be approximately 240
feet ~ 240 feet by 20 feet depth. The presence of the vault on-site and
filled with hazardous wastes would limit future use of the site. It could
also have a negative impact on area aesthetics.
Recent geologic studies and evaluations by the Illinois Geological Survey'
indicate that a predominant geologic feature. the Dunleith Formation, encom-
passing an area that includes Byron, Illinois, is heavily fractured, jointed,
and vuggy. The development of sinkholes in the vicinity has been observed.
The geological condition presents a potential risk to locating a hazardous
waste storage vault in the area. Therefore, long-term reliability cannot
be assured.
This alternative would require the most time to implement. An engineering
design of the vault would be required. This alternative presents the great-
est monitoring and operation and maintenance requirements after construction.
The estimated cost to implement is approximately 40 percent of that to remove
contamination to background levels and dispose off-site.
On-site disposal - Yeu1t (threshold levels). This alternative would entail
on-site construction of a ;,75-foot ~ 75-foot ~ 16-foot deep earthen storage
vault for containing surface and buried wastes and surface soil contaminated
above the specified threshold concentrations. While it do~s provide for sur-
face soil cleanup to acceptable EP toxicity levels, as defined by RCRA
regulations, it does. not offer as effective or complete a cleanup as off-sit~
disposal.
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.
Estimated costs to implement this alternative are: only slightly less than for
the off-site disposal (threshold levels) optio~. The same concerns for sink-
hole formation due to unsta'ble geologic conditions, as discussed previously,
apply to' this alternative.
As with the larger vault described in the previous alternative, the.presence
of the on-site vault could detract from area aesthetics, cause depression of
neighboring real estate values, and limit future usage of the site.
The local community has indicated that this alternative is less preferable
than off-site disposal.
. COMMUNITY RELATIONS:
The IEPA has prepared a summary sheet to accompany the release of the RIfFS
to the general public. A pre-meeting with local officials was held by the
IEPA on August 20, 1984, and a public meeting was held by the IEPA on
August 30, 1984, with the U.S. EPA in attendance. The RIfFS has been made
available for public comment during the week of August 13, 1984. A public
hearing was held on September 19, 1984, with the U.S. EPA in attendance. The
public comment period ended on September 26, 1984. The responsiveness summary
is attached, along with a community petition.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS:
The proposed action will not require on-site storage or disposal of hazardous
wastes. Off-site disposal of hazardous solid wastes will be sent to a lined
RCRA-approved landfill; and liquid wastes will be incinerated, treated, or
solidified, if possible.
RECOMMENDED ALTERNATIVE:
The NCP, 40 CFR Part 300.68(e)(2), states that source control remedial
actions may be appropriate, if a substantial concentration of hazardous sub-
stances remain at or near the area where they were originally located, and
inadequate barriers exist to retard migration of substances into the environ-
ment. Based on each proposed option, the comments received from the public and
the IEPA, and the State and Federal environmental requirements, the following
option has been dete~mined to be cost-effective as defined by the NCP Section
300.68 (j) :...
Off-site disposal (threshold levels).
The wastes would be excavated and removed to off-site disposal/incineration
facilities. The closest incineration facilities would be the SCA incinerator
in Calumet City, Illinois. An available lined landfill in the area would be
the Chemical Waste Management Landfill in Calumet City, Illinois. Detailed
cos ts have been broken down and are shown in Ta bl es 3 - 7.
The recommended action is considered a source control remedial action as
defined in Section 300.68(e) of the NCP. The objective of the action is
source control to mitigate against the continued spread of the contaminant
plume, and to remove the present imminent threat to the local health and
welfare of the nearby residents.
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!
13
Table 3
Capital Cost Estimate
Off-sHe Disposal (background levels)
Mobilization and Setup
Surface Contamination
Removal of surface drums to
staging area
Excavation of contaminated
surface soil
Buried Contamination
Excavation of ravines
Segregation and staging of
excavated drums
Sampling and analysis of
drummed wastes
Excavation of test pits
Placement of clean fill in
ravines and test pits
Combi ned Wastes
Transportation and disposal of:
-Empty drums
-Nan-hazardous debris
-Liquids and sludges
-Solids
-Contaminated soil
Seeding and Mulching
Subtotal
Quantity Unit Cost Total Cost
Job
504 drums
48.400 CY
5.700 CY
11 .400 drums
1.419 drums
100 CY
2.000 CY
9.717 drums
566 drums
181 drums
1 .440 drums
51 .400 CY
3,000 SY
Engineering/Construction Management
Contingency--~
SUBTOTAL
"'''.
$40.000 $40.000
20 10.080
3 145.200
5 28.500
20 228,000
50 70,950
3 300
8 16.000
2 19.434
6 3,396
85 15.385
20 28,800
80 4 , 11 2 ,000
0.20
600
$4,718,545
707,8QO
1 .415.600
$6,842,000
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~
14
Requirements needed for 11/84 RCRA Amendment:
Assume that all wastes are to be disposed at. a depth of 20 feet in the landfill.
Quantity Unit Cost Total Cost
Drainage and Gravel 5,300 CY $10.95 $58,035
Synthetic liners (2) 16,000 SY 6.00 96,000
30 mil, hypa 1 on
Geotext 11 e fa br;-cs (5) 40,000 SY 1.85 73,540
Leachate piping for collection 3,780 LF 14.00 52,920
. 4" PVC perforated, installed
8" PVC drainage, installed 300 LF 20.00 6,000
Assume natural clay already in place at landfill
Engineering/Construction Management
Contingency--30%
42.975
85,950
SUBTOTAL
TOTAL
415,430
$7,257,430
~
"
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.
15
Ta b1 e 4
Capital Cost Estimate:
Off-site Disposal (threshold levels)
Quantity Unit Cost Total Cost
Mobi11zati on and Setup Job $30,000 $30,000
Surface Contamination
Removal of surface drums to
staging area 504 drums 20 10,080
Excavation of contaminated
surface soi 1 600 CV 3 1,800
Placement of clean fill in
excavated areas (2 ft) 800 CV 8 6,400
In situ cyanide treatment 3.000 CV 10 30,000
Buried Contamination
Excavation of ravines 5.700 CV 5 28,500
Segregation and staging of
excavated drums 11 ,400 drums 20 228,000
Sampling and analysis of
drulTll1ed wastes 1,419 drums 50 70,950
Excavation of test pits 100 CV 3 300
Placement of clean fill in
ravines and test pits 2,000 CY 8 16,000
Combi ned Wastes .
Transportation and disposal of:
-Empty drums
-Non-hazardous debris
-Liquids and sludges
-Solids
-Contaminated 50i1
9,717 drums
566 drums
181 drums
1 ,440 drums
3,600 CV
3,000 SY
Seeding and Mulching
Su btota 1 '
,
Engineering/Constructi~n Management
''',
Contingency--30%
SUBTOTAL
2 1 9 , 4 34
6 3,396
85 15,385
20 28,800
80 288,000
0.20 600
$777 ,645
116,650
233,300
$1,127,600
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16
Requirements needed for 11/84 RCRA Amendment:
Assume that all wastes are to be dhposed at, a depth of 20 feet in the landfill.
Quant Hy Unit-Cost Tota1 Cost
.
Drainage and Gravel 520 CY $10.95 $5.700
Synthetic liners (2) 1 ,560 SY 6.00 9,360
30 mil, hypa 1 on
Geotextile fabric (5) 3 ,900 SY 1.85 7.215
Leachate piping for collection 400 LF 14.00 5,600
4" PVC perforated, installed
8" PVC drainage, installed 100 LF 20.00 2,000
Assume natural clay already in place at landfill
Engineering/Construction Management
4.481
8,963
Contingency--30%
SUBTOTAL
TOTAL
43,319 ,
,$1.170,919
\
"
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17
Ta bl e 5
-Capital Cost Estimat"e
On-site Disposal--Containment (threshold levels)
Mo bil i zat i on and Setup
Surface Contamination
Removal of surface drums to
staging area
Placement of surface drums in
east ravine
Transportation and disposal of
liquid wastes
Excavation of contaminated
surface soil and placement in
east ravine
Placement of clean fill in
excavated areas (2 ft)
In situ cyanide treatment
West Ravine and Test Pits
Excavation of fill material
and placement in east ravine
Placement of clean fill
East Ravine Cap
Clay cap (24 in)
Synthetic membrane
Flow zone (12 in)-sand/grave1
Top soil (12 in)
Seeding and mulching
Perimeter fencing
Interceptor ditch
Su btota 1
~,
Quantity Unit Cost Total Cost
Job $30.000 $30.000
504 drums 20 1 0 .080
436 drums 4 1 .744
68 drums 85 5.780
600 CV 7 4.200
800 CV 8 6.400
3.000 CV 10 30.000
300 CY
200 CV
5 1.500
8 1.600
5 12.500
9 34.200
10 19.000
8 1 0 . 400
0.20 800
14 1 6 .800
3 11 . 1 00
$196.104
29.400
58.800
$284,300
2.500 CY
3.800 SV
1.900 CV
1 . 300 C V
4,000 SY
1.200 LF
3.700 CV
Engineering/Constructio.~- Management
Cant i ngency--30t.
TOTAL
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!
18
Table 6
-.
.
Capital Cost Estimate:
On-site Di~posal--Vau1t (baexground levp.ls)
Quantity Unit Cost Total Cost
Mobil i zat i on and Setup
Surface Contamination
Removal of surface drums to
staging area
Excavation .of contaminated
surface soil and placement in
vault
Buried Contamination
Excavation of ravines
Placement of ravine soil in
vault
Segregation and staging of
excavated drums
Excavation of test pits and
placement in vault
Placement of clean fill in
ravines and test pits
Drums
Sampling and analysis of
excavated drummed wastes
Transportation and disposal of
liquid wastes
Crushing of empty drums and
placement in vault
Placement of drummed wastes
in vault
Vault
Clearing and grubbing
Excavation
Leachate system--sand/gravel
Leachate system--manholes
Leachate system--piping
Synthetic membr~ne (2)--
under fill
Geotextile filter fabric
Clay cap (24 in)
Synthetic Membrane (cap)
Flow zone (12 in)--sand/gravel
Top soil (l2 in)
Seeding/mulching
Perimeter fencing
Su btota 1
Engineering/Construction Management
Contingency--30%
TOTAL
Job
504 drums
48.400 CY
5.700 CY
2.850 CY
11 .400 drums
100 CY
2,000 CY
1.419 drums
145 drums
9.717 drums
2.042 drums
11 .400 SY
49.300 CY
10.700 CY
3 eacn
1 6.400 LF
22,800 SY
11 .400 SY
6.850 CY
11 .400 SY
3.450 CY
3.450 CY
11 ,400 SY
1.300 LF
$50,000
20
20
4
$50,000
1 0 ,080
6
5
290,400
28.500
2.850
228.000
8
400
16,000
50 70.950
85 12.325
2 1 9,434
2 4,084
1 11 .400
3 147.900
10 107,000
1500 4,500
8 131 .200
9 205,200
1.85 21 .090
5 34.250
9- 102,600
10 34,500
8 27,600
0.20 2.280
14 18,200
$1,580,743
237 , 1 00
474,200
$2,292,000
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~
19
Table 7
Ca~tia1 Cost Estimate
On-site Disposa1--Vau1t (threshold levels)
Quantity Unit Cost Total Cost
Mob11ization and Setup
Surface Contamination
Removal of surface drums to
staging area
Excavation of contaminated
surface soil and placement in
vault
Placement of clean fill in
excavated areas (2 ft)
In situ cyanide treatment
Buried Contamination
Excavation of ravines
Placement of ravine soil in
vault
Segregation and staging of
excavated drums
Excavation of test pits and
placement in vault
Placement of clean fill in
ravines and ~est pits
Drums
Sampling and analysis of
excavated drummed wastes
Transportation and disposal of
11 qui d wastes
Crushing of empty drums and
placement in vault
Placement of drummed wastes
in vault
\
.
Vault
C1 eari ng and gru bbi ng "'
Excavation
Leachate system--sand/grave1
Leachate system--manho1es
Leachate system--piping
Synthetic membrane (2)--
under fill
Geotexti1e filter fabric
Clay cap (24 in)
Job
$40.000
504 drums
20
600 CY
800 CY
3,000 CY
5,700 CY
2,850 CY
11 ,400 drums
20
100 CY
2,000 CY
1,419 drums
50
85
145 drums
9,71 7 drums
2,042 drums
2,400 SY
8,100 CY
2,025 CY
2 each
3,720 LF
4,050 SY
2,025 SY
1 ,240 CY
1
3
10
1500
8
9
1.85
5
$40,000
10,080
6
8
10
3,600
6,400
30,000
5
1
28,5.00
2,850
228,000
4
400
8
1 6 ,000
70,950
1 2,325
2
2
19,434
4.084
2,400
24,300
20,250
3,000
29,760
36,450
3,746
6.200
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!
20
Table 7 (continued)
".
Synthetic Membrane (cap)
Flow zone (12 in}--sand/grave1
. Top 501-1 (12 in)
Seeding/mulching
Perimeter fencing
Su btota1
Engineering/Construction ManageMent
Contingency---30%
TOTAL
"',
,
2 .025 SY
620 CY
620 CY
2.025 SY
540 LF
9 18.225
10 6,200
8 4.960
0.20 405
14 7,560
$636.079
95.400
190.800
$922.300
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.'
21
Operations and Maintenance:
Each option was evaluated for the operation aod maintenance as shown in Table
8. The operations and maintenance (O&M) costs were estimated on an annual
basis. Since the remedial design and remedial action will be a State lead
project, the.cooperative agreement will include the O&M assurances regarding
this site.
SCHEDULE:
Approve Remedial Action (sign ROD)
Award Amended Cooperative Agreement for
Remedial Design
12/30/84
Complete Design
1/30/85
4/15/85
Complete Construction
9/30/85
FUTURE ACT! ON S:
A hydrogeological investigation will be needed to address the residual soil
contamination and the off-site domestic well water contamination with volatile
organic contaminants to determine if this site 1s the main contributor of the
contamination. If the wells are contaminated due to migration from the Salvage
Yard, a FS will be conducted to evaluate alternatives for a more permanent
water supply will need to be addressed, as the residents are presently receiving
bottled water supplies from the U.S. EPA under an immediate removal action.
Th is study is to be' done by CHZM-Hill.
.,
:'...
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22
Table 8
Annual Operating and Maintenance Cost Estimates
Annual
Quantity Unit Cost Total Cost
Offsite Disposal (Background Levels}
Site inspection
Groundwater monitoring (4 wells)
Total
Offsite Disposal (Threshhold Levels)
Site inspection
Groundwater monitoring (4 wells)
Total
Onsite Disposal-Containment
(Threshhold Levels)
Site inspect i on
Groundwater monitoring (4 wells)
Surface water monitoring (2 locations)
Clay cap inspection
Fence maintenance
Clay cap maintenance
2
4
2
4
$1 ,000
250
1 ,000
250
2 1 ,000
4 250
4 250
2 1,000
S~ of construction cost
S~ of construction cost
Total
Onsite Disposal--Vault
(Background Levels)
Site inspection
Vault inspection
Groundwater monitoring (4 wells)
Leachate systeim testing
. Fence mai ntenance... 5~ of
Vault maintenance 5~ of
Total
Onsite Disposal--Vault
(Threshhold Levels)
Site inspection
Vault inspection
Groundwater monitoring (4 wells)
Leachate system testing
Fence maintenance
Vault maintenance
4
4
4
4
construction
construction
4
4
4
4
51 of construction
5~ of construction
Total
1 .000
1 .500
250
500
cost
cost
1 ,000
1 .250
250
500
cost
cost
12,000
4'000
S6,OOO
2,000
4,000-
$6,000
2,000
4,000
2.000
2,000
840
3,850
$14,690
4,000
6,000
4,000
2,000
910
33,510
$50.420
4.000
5,000
4.000
2.000
380
6,460
$21 .840
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~
@
Illinois Environmental Protection Agency' 2200 Churchill RC?a.d, Springfield, IL 62706
COffl1UNITY RElATIONS RESPONSIVENESS SlMMARY
, BYRON SALVAGE
BYRON, ILLINOIS
The Illinois Environmental Protection Agency (IEPA) has been responsible for
conducting a community relations program for this site. Community relations
activities have been conducted throughout the remedial investi gation and
feasibility stu~. During the feasibility study a six week public comment
period which included a public meeting and a public hearing was held to
receive public comment. This Cclftnu.IIity Relations Responsiveness Sununary
documents milestone comm:nity relations activities along with citizen conments
and questions received before and during the public comment period and the
IEPA response.
COMMUNITY RELATIONS
Remedi a 1 I nves ti ga ti on
A cOlllllUnity relations plan was submitted to the United States Environmental
Protection Agency (USEPA) in April, 1983. The emphasis of this first phase of
the conmunity relations program was directed at informal meetings with local
officials and citizens responding to community concern about drinking water.
A sampling and analysis of private drinking water wells was coordinated
between the Ogle County Health Department, the Illinois Department of Public
Heal th, and the tEPA. As a resul t bottl ed drink 1ng water is being provided to
10 residences. Milestone activities conducted during the remedial
investigation include:
Not; fi ca tion letters
News release
(announcing th, start of the remedial investigation and feasibfl ity study)
.
Local
-------
~
A public meeting was hel d at the Byron Cul tural Center on August 30 to discuss
the cleanup options. Approx1l111tely nine of the 35 attendees asked questions
and provided cOl8ents regarding the proposed options.
On Septemer 19, the Byron Cul tural Center was the s1 te of a second meeting,
this time a pub1fc hearing. A pUblic hearing was hel d to meet State
regula tions for sol1 ci ting public cCIIIlftents and to provi de ampl e opportW'i ty to
discuss cleanup options for those residents who nnght have missed the first
meeting. Approximately s1 x of the attendees asked questions and provi ded
conments at this hearing.
Four written statements were received by.the IEPA. Two of these statements
opposed disposal of hazardous waste at the BFI 1 andfi11 in nearby Davis
. Junction. The other two conaents expressed support for cl eanup option '1.
CITIZEH ~ESTIONS AN) CONCERNS
Issue: Drinking water
QUESTION: What are the compounds found in drink 1ng water well s near the
site?
RESPONSE: Tr1chloroethy1 ene is the primary compound.
Tetrachl oroethyl ene, di chl oroethane, di ch1 oroethy1 ene, carbon
tetrachloride, 1,1 ,l-trichloroethane, and their isomers were found in
trace amounts.
QUESTION: How often will drinking water wells be tested?
RESPONSE: A sampling schedule is being prepared by the Illinois
Department of Public Heal th. Whf1 e bottl ed drink ing water is being
provided, few samples, if any, will be needed. . However, quarterly or
semi -annual sampl ing seellls likely.
~ESTION: Hew large of an area is being sampled?
RESPONSE: Drinking water wells in an approximately one square mile area
have been sampled. Most of the contamination appears to be concentrated
in two wells on the wests1de of the site and in wells on Acorn Road.
\
c;tJESTION: "'at is th~ depth of the wells being sampled?
RESPONSE: The depth of the wells range from 40 to slightly over 300 feet.
~ESTION: Are there any pl ans to construct more water testing
1 aboratories?
RESPONSE: The 1 aboratory capac1 ty of both the IEPA and the IDPH is
strained. Some of the money set aside by Governor Thompson for the "Clean
Illinois" program will be used for groundwater II1)nitoring.
2
-------
(JJESTION: How long will it take to cleanup .the groa.mdwater?
RESPONSE: Considering the concentrations that currently exist in the
groa.mdwater. it nay take at least several more years for the contamination
alrea~ in. the groundwater to dissipate. It is illlpOrtant to note that
grollldwater contamination has declined significantly since the mid-1970's
and shoul d continue to decline once the source of contamination is removed.
Issue:
Si te backgroa.md
~ESTION: . Wasn't Wil ford Johnson operating a landfill at this site in
canpl iance wi th existing 1 aws?
RESPONSE: No. Johnson elf d not have a permi t to operate a disposal
facili ty and was tol d to cover the waste wi th sol1.
OJESTION: What is the depth to bedrock at this site?
RESPONSE: The depth to bedrock at this si te varies in range from 10 feet
fo 80 feet.
QUESTION: How I18ny barrel s are still intact?
RESPONSE:' Approximately 300.
Issue: Cleanup options
QUESTION: How I18ny truckloads of waste will be removed from the site if
cleanup option 11 is selected?
RESPONSE: Approximately 400 truckloads of waste and contaminated soil
woul d 1 eave the site. .
QUESTION: Would the leachate collection system proposed in cleanup option
n run through the interior of the on-site vault? .
RESPONSE: No. The leachate collection system would run around the sides
and benea th the bottom of the vaul t.
COMMENT: The ~ology of this area lends groundwater susceptible to
contamination. Sinktt.~les and cracked limestone are draw:»acks to cleanup
option 12.
RESPONSE: The IEPA shares this concern. A substantial quanti ty of
relatively impermeable so11 would have to be transported to the site with
additional layers of protection between the vault and the groundwater
before an environmentally acceptable on-site vault could be construct!rl.
4
-------
!
~ESTION: Will sol1 samples betaken "'l1e !!xcavation is Wlderway?
RESPONSE: Yes. So11 samples will be used to determine exactly how IIIJch
sol1 shoul d be treated' and lIIOVed. The resul ts of the remedial
investi,gation indicate approximately 3,300 cubic yards contain sLbstantial
contamination. If IRore contaminated so11 is found, it will be treated or
moved.
QUESTION: Does the state own the site now, and if not, will the state
become the o","er after the cl eanup is cOllpleted?
RESPONSE: The State of 111 ino1s does not presently own any portion of
this si te nor does it intend to purchase the property after cl eanup is
compl eted. The IEPA and USEPA will need access to the property to conduct
monitoring activities after cleanup is finished regardless of Wlich option
is sel ected.
QUESTION: Can USEPA take action in 1984 against haul ers or other parti es
who were responsible for dunping at the si te years ago?
RESPONSE: Yes. Federal regulations allow legal action on Superfund
cl eanups on a retroactive bas is; however, the courts wl1 1 determine the
degree of responsibility and penalties.
~ESTION: After cleanup is canpleted, how can we (the community) be sure
that the site will not be used for hazardous waste disposal?
RESPONSE: Before a hazardous waste disposal site can be developed, the
owner or operator IIIJst obtain local approval, usually from municipal
offi cials or the county board. If local approval is obtained, then a
permi t applicati on IIIJst be submt tted to the IEPA. It is unlikely that
local approval or a permit coul d be obtained to develop a hazardous waste
facil ity at this site.
If "mi dnight haul ersll are observed dumping waste at this si te or any other
location in the county, the county sheriff or the IEPA should be contacted.
QUESTION: Wi" area residents be exposed to the hazardous waste while it
is bei ng remove~ fran the sf te?
,
RESPONSE: ExpOsure skoul d be m1 n 1mal or none. The IEPA will sel ect a
contractor WlO is experienced wi th transporting and handl ;ng hazardous
substances. Safety precautions, including a safety plan, and proper
equipment wfll be discussed between the IEPA and the contractor. All
environmental and transportation regul ati ons nus t be fol lowed during
removal of the waste. In addition, the IEPA's Emergency Response Unit and
State Police will be on standby should any accidents occur involving the
trucks carrying hazardous waste frcn the site.
G1: rd/sp1821D/1-6
6
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..... . '"',
~~
.:.~tt Greg N1chaud
2200 Ctuch1l1 Rd.
Sprlngflela III 6,7'"~
Th1s pet1t1on 1s signed by res1den~s and land owners l1v1ng currentl)
1n the Rockvale town$h1p area( close to the'Byron Salvage Yard").
!
.::ept :.. 7, ~9E4
The "undersigned pet1tioners have read the" attached Fac\ Sheet #2
put out by tre"IBPA, and teel that the only proper way to deal with
the Byron salvage yard 1s to support the 'Proposal#l' 8pproach.
(Proposal number 1 est. cost $1,609,660)
The follow1ng names support the Iepa 1n us1ng every resou~ce to comDletel
remove the wasre material and assoslated hazards.
- ;e 12. d£ r:J.. ~ (),U. (,IOCt!
-/2£.-dd; ~ (,/OCL/
If (
" "
II If
/I II
Ie I I
I' "(,
I ( It
I ( I'
~
~ - ~ /? #"..;< - ~~ / etf/~ 6"/Q~
0(;2-' .-C;?£ >9' "'--~-~ ?~
~ ;tV- ~ ~~, ~--t.
0/ ~J - 0/f/( .t:f--z-. ~/J,Q. '1o"
,~' "",v-r'--C?{J? ~ &~'" 3&'. c'/6c.(
- ..~,~ ~ f( 2- 6..:: I :Le,.. 6/ 06)
II. '/./'~:. 'R K 2... Q-~, Je '10'1
[7r~ ~ .f?/€ PJ, {L;&~/ k ~/tltb[
~;~~' IlrL .atcfJiZ a/Obj
1(tUpY ~bt/' -- Ii ~ t?U ' P t111'6'/
p"v.--- J~~ 1"(... (]l/ rJ (,I()~(
. CkK.., ~~~. St. Co!()(ol
. .. . . r (
~~( ~~ i2£dL a~,~ &/~(,/
RECEIVED
OCT 09 1984
IEPA.OLPc .
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