United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-85/013
March 1985
Superfund
Record of Decision:
Cross Brothers, IL (IRM)
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. r 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-85/013
'. TITLE AND SUBTITLE 5. REPORT DATE
March 25. 1985
SUPERFUND RECORD OF DECISION 6. PERFORMING ORGANIZATION CODE
Cross Brothers, IL (IRM)-
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Cross Brothers' uncontrolled hazardous waste site is located approximately
14 miles east of the City of Kankakee, Illinois, within Pembroke Township of
Kankakee County. The site consists of a 20-acre parcel of land surrounded primarily
by low density single family housing. Abner and James Cross operated a drum and
pail reclaiming operation at the site from 1961 until 1980. The operation employed
a crude process to incinerate the residue material that was contained in nearly all
of the drums and pails received for reconditioning. Essentially, the operation
consisted of inverting the containers to allow the residue materials to drain out
onto the ground. Then solvent would be added to the containers to dissolve any
remaining residue. Throughout the container reclamation process, the Cross Brothers'
operation was extremely haphazard, allowing the indiscriminant dumping of great
quantities of residues (largely dyes, paints, inks and solvents) .
The selected remedial action includes offsite disposal of surficial and buried
waste materials and visibly contaminated soil. Total capital cost for the selected
remedial alternative is estimated to be $377,728.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSA TI Field/Gr
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EPA Form 2220-1 (Rev. 4-77) (Reverse)
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RECORD OF DECISION
INITIAL REMEDIAL MEASURES SELECTION
Site:
Cross Brothers Pail Recycling Site, Pembroke Township, Kankakee
County, Illinois.
Documents Reviewed
I have reviewed the following documents describing the analysis of cost-
effectiveness of remedial action alternatives for the Cross Brothers
site.
Feasibility Study, Pembroke/Cross Brothers Site
Public comments and recommendations
Responsiveness summary
Description of Selected Remedy
Off-site disposal of surficial and buried waste materials and
visibly contaminated soil.
Declarations
Consistent with the Comprehensive Environmental Response Compensation
and Liabil ity Act of 1980, 42 U.S.C. 9601 et~., and the National
Contingency Plan, 40 CFR Part 300, I have determined that implementing
the off-site disposal of surficial and buried waste materials, and visibly
contaminatd soil is a cost-effective initial remedial measure and provides
adequate protection of public health, welfare and the environment. The
State of Illinois has been consulted and agrees with this recommended
action.
I have also determined that the action has been approved for funding
from the Hazardous Substance Response Trust Fund.
(,
The U.S. Environmental Protection Agency, with the Illinois Environmental
Protection Agency taking the lead, is continuing its remedial investi-
gation/feasibility study (RI/FS) to investigate potential groundwater and
soil contamination in order to evaluate potential remedial actions. If
additional remedial actions are determined to be necessary, a Record of
Dec1sion will be~epa"ed fo" thei"- app"O~-1- ~
1Qf~~!S, 'Itj!~ U«¥V)
Va1das V. Ad mkus
Regional Ad 'nistrator
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SUMMARY OF IIJITIAL REMEUIAL MEASURES SELECTION
CROSS BROTHERS SITE .
PEM~ROKE TOWNSHIP, ILLINOIS
SITE LOCATION AND DESCRIPTION
The Cross Brothers uncontrolled hazardous waste site is located approximately
14 miles east of the City of Kankakee, Illinois, within Pembroke Township
of Kankakee County. The site is located on an approximately 20-acre
parcel. The land use in the immediate vicinity of the site is comprised
of low density single family housing. Outside the immediate vicinity of
the site, agriculture is the predominant land use.
The topography of the area is generally rolling with occasional sand
dunes fo~ming the local topographic highs. ~o surface water bodies
exist within approximately one mile of the site due to the highly
permeable nature of the soil in the area.
The upper geology of the site consists of unconsolidated sand deposits
through which precipitation and groundwater can move freely. Because
this upper sand unit is highly permeable, it is readily susceptible
to contamination from surface activities. The Yorkvi11e Till Member of
the Wedron Formation, a relatively impermeable strata, lies below this
sand unit at a depth of 50 to 70 feet. The Yorkville Till is a gray,
calcareous, silty clay which contains traces of dolomitic pebbles and
sand lenses. The thickness of the Yorkvil1e Till beneath the Cross
Brothers Site varies from 5 to 10 feet. The Yorkvi11e Till mantles
the Silurian-aged bedrock aquifer at a depth of approximately 70 feet.
This aquifer is a fractured and creviced dolomite which belongs to the
Hunton Megagroup. Both the unconsolidated sand deposits and Silurian
dolomite serve as a source of water to residential wells in the area.
There are 14 privately owned shallow, sand-point wells within 1/2
mile of the site. Movement of groundwater in the shallow unconfined
aquifer is in a north-northeasterly direction. As a result of the
contaminant plume emanating from the site, two residential wells north
of the site were voluntarily abandoned by their owners. Organic solvents,
phenols and heavy metals were found in these wells.
SITE HISTORY
Abner and James Cross operated a drum and pail reclaiming operation at
the site since 1961. The operation employed a crude process to incinerate
the residue material that was contained in nearly all of the drums and
pails received for reconditioning. Essentially, the operation consisted
of inverting the containers to allow the residue materials to drain out
onto the ground. Then solvent would be added to the containers to
dissolve any remaining residue. Following that, the containers went
through an incineration process to burn out remaining materials, or the
materials were merely ignited in the containers and allowed to burn openly.
Following incineration,"the containers were reconditioned, repainted
and sold. Throughout the container reclamation process, the Cross
Brothers' operation was extremely haphazard, allowing the indiscriminant
dumping of great quantities of residues (largely dyes, paints, inks and
solvents).
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The Cross Brot-hers Site \'las listed on the National Priorities List in
December of 1982. Study of the site began after the entry of a Coope~dtive
Agreernent between IEPA and U.S. EPA on May 4,1983. The Remedidl Investi-
gation and Feasibility Study Reports were finalized in June 1984.
ENFORCEMENT
On July 23, 1980, the Illinois Attorney General's Office and the Illinois
Environmental Protection Agency (IEPA) inspected the site. Based on the
information gained during that inspection, the Attorney Genera1's
Office obtained a court order on August 19, 1980, to close down the
operation and cleanup the site. The order was handed down by the
Kankakee County Circuit Court.
To date approximately 100,000 pounds of scrap metal have been removed
from the site by the Cross Brothe~s. Still on the site are an estimated
10,000 pails and drums, waste material in ten trenches, and significant
areas of contaminated soils.
Under the terms of a subsequent court order, the Cross Brothers are
utilizing a building on-site for off-specification pail/drum reclamation.
Only empty pails/drums are to be processed at the facility. This work
does not take place on the contaminated soils portion of the site. The
original pail and drum recycling process, which the Cross Brothers managed,
was in operation from 1961 until 1980 when the court order previously
described went into effect. Subsequently, the operation was started
again, though in a more limited manner, after the second court order.
The Cross Brothe~s are presently operating under the limited authority
to take only empty containers to the site.
The Illinois Attorney General's Office, with the aid of IEPA and
Department of Criminal Investigation inspectors, is continuing to
monitor the actions at the site. Appropriate legal measures will be
taken should the current court order be violated. Also, action will be
taken to insure that the ongoing pail recycling does not interfere with
site cleanup operations.
The Office of Regional Counsel has made the necessary notification to
potential responsible parties that money from the Hazardous Substance
Response Trust Fund is being expended for remedial actions. The status
of negotiations with the responsible parties should be obtained from the
Office of Regional Counsel.
"
COMMUNITY RELATIONS
The Illinois Environmental Protection Agency (IEPA) has been the lead
agency responsible for conducting community relations at this site.
Community relations efforts began in the Fall of 1982 with activities
needed to develop a community relations plan (CRP). Site visits and
personal interviews with adjacent p~operty owners, health officials, and
county and municipal leaders were the primary pre-community relations plan
activities.
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Following completion of the CRP in April 1983, the IEPA proceeded to
fulfill the objectives of the plan by conducting the activities listed
below during the Remedial Investigation (RI).
News Release
(announcing the start of the Remedial
Investigation/Feasibility Study)
05/83
Notification Letters
(explaining the need for an RI/FS)
02 & 05/83
Local depositories
(established as a source of printed
information in the community)
06/83
Fact Sheet #1
(Site History)
07/83
Fact Sheet #2
(The Remedial Investigation and what follows)
Informal Meeting
(Pembroke Area Health Board)
08/83
08/84
Fact Sheet #3
(cleanup proposals)
08/84
The focus of the IEPA's community relations program has been to recognize
community needs and initiate preventive or corrective action. Recognizing-
community needs required that the IEPA initiate and maintain a two-way
dialogue. This effort resulted in three examples through which the IEPA
established its credibility by assisting property owners adjacent to the
site. These examples are:
Arranging for health surveys and examinations to identify health
problems that might have been caused by drinking contaminated
water;
Establishing a drinking water well sampling program to assure
residents that their water was safe to drink; and
c
Arranging for replacement of a malfunctioning well pump in a well
which provided drinking water for two and sometimes three families.
Community relations activities continued through the Feasibility Study (FS).
Complete copies of the FS were made available on August 14, 1984. Fact
Sheet #3, a summary of the cleanup options under consideration, has been
distributed. IEPA issued a news story on August 11 and August 14 to the
Kankakee Daily Journal and WKAN Radio, which announced the availability
of the FS, the start of the public comment period, and the date and
location of the public hearing. A paid legal notice announcing the
hearing date and public comment period ran August 15, 22, and 29. Two
informal meetings were held at the beginning of the public comment
period. Attendees at tne first meeting included the Mayor, Adminis-
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trative Assistaot, Towns~ip Supervisor, School Superintendent, Editor of the
Pembroke Weekly Post, neporter from the Kankakee Daily Journal, an~
Village Health OT1TCer. T~e second ~eeting was before the Pe~bro~e Area
Health Roard. The public hearing was held on September 13, and the
public comment period ended on Septe~ber 21. A responsiveness su~ary
is included as Attachment 1.
CURRENT SITE STATUS
Of the 20-acre site, ~PDroximately In acres have been contaminated
by hazardous substances. The esti~ated volume of hazardous waste on
site is shown in Table 1. The estimated volume for visibly contaminaterl
soils is approximately 1000 cubic yards. Highly contaminated soil is
estimated to be 42,000 cubic yards.
The existing waste/contamination at the Cross Brothers site, represents a
potential environmental or human health threat via the following pathways:
Direct contact,
- Airborne emissions, and
- Groundwater contamination.
Toxic and hazardous materials are openly exposed at the site, anrl there
are no barriers to prevent direct contact with the waste by people
and/or wildlife.
ALTERNATIVE EVALUATION
Before a discussion of alternatives can be meaningful, it should be
noted t,at the alternatives evaluated do not address the possible
groundwater contamination proble~ at the Cross Brothers Site. Source
removal was the major issue of the first feasibility study, and several
source control actions were developed. However, only land disposal
alternatives were developed and evaluated. There are several data limita-
tions and assumptions that make the development of a comprehensive
remedial action for the Cross Brothers Site impossible. The study identified
several informational deficiencies relating to groundwater contamination.
Therefore, remedial action for groundwater contamination has been deferred
until those deficiencies can be adequately addressed. The informational
deficiencies in relation to groundwater include:
Lack of groundwater analyses at or near the water tahle to
detect contaminants less dense than water,
- The detection level of the organic analyses were not low
enough to show contaminants at levels which may pose a threat
to public health (i.e., tetrachloroethylene - the detection
level was 1 ppm when the OD\~ Chronic Health Advisory level is
.02 ppm),
- The parameters analyzed were indicators, ~nd did ~ot include
suhstances which were previously identified in the groundwater.
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TABLE 1
S\Jt1t1ARY \~fl.SH: I NVPJTORY
DESCR I PTI ON OUANTITY
SURFICIAL DRUMMED WASTE
Individual Drums
- Liquids and sludges 45
- Solids 136
- Debris/garbage 42
- Empty 31
254 drul'ls
Two Drum P 11 es
- Liquids and sludges 5
- Solids 20
- Debris/garbage 5
- Empty 270
300 drums
BURIED WASTE IN TRENCHES
Drummed Waste (Intact)
- Li au; ds 10
- S01 ids 290
- Nonhazardous debris gO
- Empty 710
1,100 drums
Bulk solids and Debris 1AO cubic yards
MATERIALS WITHIN VEHICLES
Empty Containers (crushed) 200 cubic yards
Drummed Wastes
- Liquir1s and slurlges 11
- So 1 ids 32
- Nonhazardous dehris 10
- Empty 7
50 drul'lS
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Additional testing is also needed to determine the leachability of
contaminants present in the soil. This inforMation will ena~le estiMates
of future groundwater conta~ination to he made. It is anticipated that
a second feasibility study will be undertaken to investigate groundwater
contamination and integrate the cleanup of wide spread soil contamination
with groundwater restoration.
A second area in which the feasibility study does not give conclusive
information relates to the estimate for the amount of soils that- will need
to be excavated. The completed feasibility study uses certain criteria
for defining contaminated soil. The definition of contaminated soil
recommended by the contractor was:
- Metals and cyanides - ~O times the respective drinking water
or toxic pollutant water quality criteria.
- Organics - levels based on precedent from other remedial
action at Superfund sites.
TOX
Benzene
Ethyl Benzene
Toluene
- 25 ppm
- 12 ppm
- 15 ppm
- 15 ppm
These criteria need to be evaluated as part of a second feasibility
study to determine if the levels will adequately protect the public
health and environment.
The volume of contaminated soil was calculated. based upon the area
encompassinq all areas within 50 feet of surficial sample locations
(taken on lOa-foot centers) where heavy metals. or organic parameters
exceed the above criteria to the depth of the groundwater surface. The
volume of soil estimated is 42.000 cubic yards. Soil sampling. however.
was only conducted at the 1 foot depth level. Therefore. no data
exists to substantiate approximately 33.600 cubic yards (approximately
4 feet of soil below the depth for which analytical results are
availa~le) of soil labelled contaminated.
With the two points made immediately above as preface. the specific
source control options are listed below:
1.
Off-site removal and disposal of wastes and contaminated
soils. ($6.9 million)
2.
Capping of contaminated soil areas with lateral groundwater
flow cutoffs (slurry walls) to a depth of 20 feet or keyed
into the Yorkville Till at a depth of about ~5 feet. ($1.2
or $2.2 million)
3.
Gonstruction of an on-site vault in addition to lateral flow
cutoffs keyed into the Till. (~1.8 million)
4.
On-site containment of contaminated soil wit~ a shallow slurry
cut-off wall arid cap system. ($1.2 million)
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5.
(deeMec1
Treatment/detoxification of the wastes at the site.
not feasible)
6.
No action.
As a part of each of these source control remec1ial actions, it is recommende~
that off-site disposal of waste materials be undertaken.
The present state of containerization and heterogeneity of the waste
materials suggests that on-site treatment or detoxification would have
limited applicability. Treatment of thp. drummed wastes (either surfi-
cial or buried) is not viewed as cost-effective.
The no action alternative is dismissed from further consideration because
it does not accomplish the response objective. The response objective
is to select the most appropriate, cost-effective, and environmentally
sound method(s) for the prevention of further contamination and mitigation
of existing contamination at the Cross Brothers Site. Cost-effective
remedial action alternatives for the control of waste materials
are available.
It is recommende~ that none of the source control alternatives be
implemented at this time. However, initial remedial measures that
include the off-site disposal of waste materials and visibly contaminated
s011s should be carried out at this time. This recornmenrlation is based
on the following reasons:
1.
the 1ac~ of data substantiating the volume of contaminated
soi 1 ,
2.
3.
the lack of data regardin9 groundwater contamination,
the hydrogeologic unsuitability of the site for disposal of
hazardous wastes,
4.
the need for additional corrective actions, should release of
hazardous substances occur from any of the land disposal
options,
the 1 arge vol ume of contami nated soil in rel ati on to the
capacity for hazardous waste disposal in the State.
The lack of soil sampling data to substantiate the estimatp. of contaminated
soil makes the expenditure of a million or more dollars to dispose of
contaminated soils a questionable action. A limited number of additional
soil samples are needed to verify the assumption regarding the volume of
contaminated soil.
5.
The lack of definition of the groundwater contamination does not allow
for a total site remedial action to he developed. By first co11ectinq
the necessary soil and groundwater data, a comprehensive site remedial
action can be developed. This action may well be more cost-effective
and more environmentally .acceptab1e than the course of action that is
laid out in the feasibility study.
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Because the sit~ is situated on hig~ly permeable sand deposits wit1
rapid groundwater velocity, and the reliance on the ~roundwater as a
source of drinking water hy nearby residents, the site is not suitahle
for on-site disposal options.
In addition, the t~ickness of the sand layer mal
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/
I
ACTIVITY
ESTIMATED SCHEDULE
Preparation of bidding documents
Advertise for competitive bids
Open bids
Award Contract
Completion of implementation
30 days
4S days
105 days
l2() days
330 days
SUMMARY
This Record of Decision supports a recommendation that initial remedial
measures he undertaken at the Cross Brothers Site. Those measures would
consist of:
l.
2.
Removal of surface containers,
Excavation of buried trenches, and
Excavation of visibly conta~inatert soils.
3.
The estimated cost of the project ;s $377,728.0(), and it should be accomplished
in just under one year1s time.
FUTURE ACTIVITIES
A feasibility study to address groundwater and soil conta~ination will
be conducted. A Cooperative Agree~ent (CA) application will be submitted
for this action concurrently within the CA for the IRM. Procurement will
proceed as quickly as practical. The study should be co~pleted by late
1985.
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TARLE 2
REL~TIVE MERITS OF ALTERNATIVE TECHNnLOGIES
cnNTROL OF WASTE SOURCES(')
ALTERNATIVE (2)
EVALUATION OFF-SITE ON-SITE CONTAINMENT(3) TREATMENT/
FACTOR CRITERIA DISPOSAL DISPOSAL(3)A(4) ~(4) DETOX I FI CATI mJ
Technical Proven 4 3 2 2 0
Performance Technology
Degree of Ground 4 3 1 2 4
Water Protection
P rovi ded
Elimination of 4 4 4 4 4
Di rect Contact
and Airborne
Dispersion
Pathways
Comparative Capital Cost 3 4 4 3
Cost
Operation and 4 3 3 3 4
Maintenance Cost
Cost Certai nty 2 3 ~ 4 1
Implementation Effort Required 4 3 1 2
for Design/
Approval
Time Required 4 2 3 2 1
to IMpleMent
Constructability 4 3 4 3 1
Risk Long-Term 4 3 1 2 3
Assessment Liability
Risk of Failure 4 3 1 2
Envi ronmental Future Site Use 4 3 2 2 3
Impact
Potential Health/ 3 2 4 4 1
E nvi ronmenta 1
Impacts During
Construction
Public Acceptance 4 3 1 2
TOTAL SCREENIN~ SCORE 52 42 35 37
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TABLE 2 (CONTINUED)
(l)Sources defined as surficial drummed and burie~ wastes in trenches,
and visibly contaminated soil.
(2)Legend (relative scores):
4 - Most Favorable
3 - Favorable
2 - Intermediate
1 - Unfavorable
o - Abortive
(3)Assume facility/system concurrently developed to handle contaminated
50ils.
(4)Subalternative A - Extend cutoff to trap organics near water table.
Subalternative B - Extend cutoff to aquiclude (Yorkville Till).
u
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TABLE 3
CONSTRUCTIml COST ESTI~ATE
WASTE qEMOVAL AND OFF-SITE DISPOSAL
( 1 )
UNIT TOTAL
ITEMS UNITS QUANTITY COST COST
($ ) ($)
Mobilization, Setup, and Other LS Job 55,000.00 55,000
Fixed Costs (2)
Excavation of Buried Trenches CY 500 (3) 20.00 10,000
Excavation of Visually Conta- CY 1,000 3.00 3,000
mi nated Soil s
Segregation and Staging of DruM 1,714(3) 15.00 25,710
Surficial and Buried Drummed
Wastes
Sampling and Analysis of Each 500 25.00 12,500
Drun1lT1ed Wastes
Sa~p1ing and Analysis of Each 45 200.00 9,000
Contaminated Soil and Debris
Transportation and Disposal of DruM 1,018 2.00 2,036
Empty Drums
Transportation and Disposal of Drum 147 4.00 588
Drums of Nonhazadous Debris
Transportation and Oisoosal of Gal 10 ,000 (4) 0.25 2,500
Liquid Wastes
Transportation and Disposal of Drum 478 55.00 26,2QO
Drummed Solids and Contaminated
Soil
Transportation and Disposal of CY l,4RO 100.00 1413,000
Bulk Solids
~ Grading and Placement of Clean CY 1,500 9.00 13,500
Fill
SUBTOTAL
30~, 124
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TABLE 3 (CONTINUED)
UNIT TOTAL
I TEt~S U~IITS QUANTITY COST COST
($) ($ )
Engi need n9 LS Job 13,500.00 13 ,500
Construction Management LS Job 15,400.()t) 15.400
TOTAL
337,024
(1)
Waste defined as surficial drummed materials, materials in buried
trenches, and visibly contaminated so;ls.
(2 )
Includes fencing, site security. health and safety. and environ-
mental monitoring.
(3 )
(4 )
Includes buried druMs encountered during trench excavation.
Includes drummed liquids and decontaminated water
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CO~1t-'IJNITY RELATIf1NS RESPONSIVENESS SUm1ARY
CROSS RROTHERS PAIL RECYCLING SITE
PEMBROKE, ILLINOIS
PREPARED 8Y ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
The Illinois Environmental Protection Agency (IEPA) has been responsi~le for
conducting a community relations program for this site. ComMun{ty relations
activities have been part of the remedial investigation and feasibility
study (~I/FS). During the feasibility study, a 4-week public co~ent period,
which included two meetings and a public hearing, were held to receive
public cOMments on proposed cleanup options. This Community Relations
Responsivness Summary docUll1ents milestone comMunity relations activities
along wit~ citizen questions and concerns raised before and during the
public comment period and the IEPA's response.
COMMUNITY RELATIONS
Remedial Investigation
Since the fall of 1932, the IEPA has Met with residents and local officials to
discuss citizen concerns and steps in the cleanup process for the Cross
Brothers site. In addition, the TEPA completed the following activities
during the course of the remedial investigation (RI).
Notification letters
(explaining the need for a remedial investigation
and feasibility study)
02/83, 05/83
News release
(announcing the start of the RIfFS)
05/83
Local depositories
(established as a source of printed information
in the community)
05/83
Fact Sheet #1
(si te hi story)
Fact Sheet #2
(the remedial investigation and what follows)
07/83
08f83
Informal Meeting
(Pembroke Area Health Board)
OR/84
F act Sheet #3
(cleanup proposals)
08/84
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During the rem~dial investigation, t~e IEDA also arranged for replacement of a
malfunctioning drinking wat~r well pump; esta~lished a drinking water well
sampling prograM for nearby wells; and arranged for health surveys and
examinations to identify health probleMs that might have been caused by
drinking contamfnatp.d water.
Feasibility Study
Complete copies of the feasibility study (FS) were made availab1e on August 14,
1984. IEPA issued a news story to the Kankakee Daily Journal and WKA~J Radio
which announced the availability of the FS, the start of the public comment
period, and the rlate and location of the public hearing. A paid legal notice
announcing the hearing date and public comment period was published on
August 15, 22, and 29 and posted at the village hall. Fact Sheet 13, a
summary of the cleanup options, was placed in the depositories and mailed to
those on the IEPA mailing list.
Two informal meetings were held at the beginning of the public comment
peri ode Attendees at the fi rst meeti ng i ncl uded the t1ayor, Admi ni strati ve
Assistant, Township Supervisor, School Superintendent, editor of the Pembroke
Weekly Post, reporter from the Kankakee Daily Journal, and the Village Health
Offfcer:--The second meeting was before the Pembroke Area Health ~oard.
A public hearing was held at the Village Hall on September 13 to present the
feasibility study and to solicit public comment. Approximate attendance was 50,
13 of whom were from Kankakee. Twelve attendees made public statenents, and
three written statements were received regarding the proposed cleanup
options. Off-site removal of the waste was unanimously supported by the
audience. Two of the written statements supported the c1eanu~ option
preferred by the IEPA. One of the written statements was a petition signed by
17 residents of Pembroke, some of WhOM live adjacent to the site. The other
written statement supported complete excavation.
CITIZEN QUESTIONS & CONCERNS
Issue:
Operation of the Cross Brothers site
QUESTION:
the soil?
Why is the site heing cleaned up and how did the waste get into
RESPONSE: Waste entered the soil when the Cross ~rothers emptied the
contents of buckets and barrels in different locations on the site. Waste
also leaked into the soil from several hundred containers buried by the
Cross Brothers. While the site does not appear to present a public health
threat from exposure on the surface of the site, waste seepinq through t~e
soil could cause continued groundwater contamination. Therefore,
containers must be removed, and the waste which is still in the ground must
be prevented from reaching drinking water wells.
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QUESTIO~: When IEPA first learned of the site in 1980, did they ~now what
chemicals were there?
RESPONSE: Initial IEPA inspections found more than ~,noo containers
scattered across the 20-acre site. Preliminary sampling of waste from the
containers and drinkin9 water wells indicated the presence of paints,
inks, and solvents. The Agency recognized the need for a thor~ugh
investigation of the site to determine what was buried and its location.
The investigation, referred to as the remedial investigation~ was
completed in October 1983. This investigation uncovered the presence of
benzen~, xylene, and toluene. There were also small quantities of
tetrachloroethylene, lead, nickel, and cyani~e identified at the site.
QUESTION:
the site?
Could James and Abner Cross be held liable for dumping waste at
RESPONSE:
Yes.
QUESTION: A court order had stopped the Cross Brothers from operating,
but shipments of containers are now beinQ unloaded at the site. Why?
RESPONSE: The Cross Brothers requested permission to accept only empty
containers at their Pembroke location. This request was granted by the
Twelfth Judicial Circuit Court on July 8, 1983. If the Cross Brothers
violate this order by accepting containers with hazardous waste or if they
violate the Environmental Protection Act in the process of painting empty
containers, the Attorney General's staff feels that another court order
halting the Cross Brothers' operations co~ld be obtained.
QUESTION: Is anyone checking on the Cross Brothers operation to determine
if they are complying with the latest court order by accepting only empty
containers?
RESPONSE: The Illinois Department of Criminal Investigation has been
notified of the Cross Brothers operation, and the IEPA will continue to
conduct inv~stigations of the site. If anyone in the area observes
dumping of waste, they should note the date and time of day and report
this to the Mayor, Pembroke Area Health Department or the IEPA.
Issue:
Drinking water
~
QUESTION:
RESPONSE:
I~hich way does the groundwater flow from the site?
The groundwater flows to the north and northeast.
QUESTION: Have chemical wastes from the site a~peared in drinking water
wells south of the site?
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RESPONSE: Qrinking water wells and ~onitoring wells locaterl south of t~e
site do not show chemical contamination associatert with the site.
Problems-observed in Prince Phillips' well are not related to waste frOI~
the Cross Brothers site.
QUESTION: Area farmers located north of Pembroke are using water for
irrigation. This water use is drawing down deep wells used by PeMbroke
Township residents. Is this practice drawing conta~inated groundwater from
the site into deep wells used by Pembroke Township residents~
RESPONSE: Samples have been taken by the IEPA from residential wells
located between the Cross Brothers site and deep wells used by farmers.
Analyses of these sa~ples do not show contamination.
QUESTION: Which drinking water wells have been contaminated by waste from
the Cross Brothers site?
RESPONSE: Shallow drinking water wells serving the Roy Clybourn and
George Robinson families have been contaminated. New wells drilled to
deeper depths have been installed and sa~pled. Both of these new wells
are providing safe drinking water.
QUESTION:
If I want my drinking water checked, who should I contact?
RESPONSE: You should contact Jeanette Swan, Pembroke Health Officer; the
Pembroke Area Hea1t~ Department; or the Illinois ~epartment of Public
Health (IDPH).
Issue:
Cleanup options
QUESTION: Would any of the proposed cleanup options affect the
construction or operation of a sewage treatment project planned for this
area?
RESPONSE:
No.
COMMENT: Cleanup option #4, on-site vault with slurry walls, is
inadequate without a synthetic layer or leachate collection system.
~
RESPONSE: The IEPA agrees that this change would be needed in the design
of cleanup option #4.
COMMENT: Support for cleanup option #5 which is complete excavation of
the contaminated soil and containers, was announced by f1ayor Haney,
Township Supervisor Hays, and Jim Yoho who represents Concerned Citizens'
Coalition for a Better Com~unity.
~
QUESTION:
Why can't the conta~inated soil be moved off the site?
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RESPONSE: ~ovi~g the conta~inatp.~ soil off the site would require that
42.000 cubic yards of soil be excavated from this site and buried in a
landfill at another location. This is not a permanent solution. '1oving
contaminated soil to another location only moves the threat of release of
hazardous substances to another communtiy, it does not eliminate the
threat. This is also impractical because of the large volume of soil.
Over 2,000 truck shipments would be needed to move this much soil.
This Agency prefers to evaluate flushing the soil as described i~ cleanup
option #6. Flushing the soil will remove the hazardous substance from
the soil and concentrate the pollutants into a much smaller volume that
can be detoxified.
QUESTION: If cleanup option #6 is such an easy answer, why does our
society have the disposal prob1e~s with hazardous waste that it is
experiencing?
RESPONSE: There are thousands of different types of substances that can
be classified as hazardous. Hazardous wastes have heen improperly dumped
at a variety of locations each with different geological conditions. If
organic hazardous wastes, such as those found at the Cross Brothers Site,
are in the soil, they cannot be easily treated. However. if the same
organic wastes are in water, they can be more easily treated than in
50i1. Therefore, one particular disposal method cannot be applied to
every type of hazardous waste in every situation.
Cleanup option #6 is not an easy solution that is adaptable to every
situation. Although this solution has been successfully used at other
sites. it appears that it is more effective at some sites than at others.
Factors such as the type of soil and contaminants present suggest that
this solution will be effective at this site.
Recent Federal legislation has changed the economics of hazardous waste
disposal. Landfilling has historically been one of the least expensive
methods of waste disposal, and was heavily relied upon by private
industry. Chemical treatment and incineration are only now ~ecoming cost
competitive with landfil1ing. Landfilling is still less expensive in most
instances, but is not the most environMentally suitable choice.
~
QUESTION: If a treatment facility is built as proposed in cleanup option
#6. where would it be built, and could it be constructed while the Cross
Brothers are operating?
RESPONSE: The treatment facility would be built on the Cross Brothers
Site, not on adjacent property. The IE?A is not sure whether this
facility could be built if the Cross 8rothers are still operating. The
Cross 9rothers may have to stop operations if this facility is constructed.
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QUESTION:
completed?
RESPONSE: Regardless of which option the United States Environ~ental
Protection Agency (USE~A) selects, cleanup will be conducted in two
phases. T~e first phase involves removal of all the containers, both on
the surface and buried. A1t~0llgh weather conditions will affect how
quickly this phase progresses, all the containers should be removed before
the end of next summer. The second phase of the cleanup, ha~d1ing
contaminaterl soil, would take between 2-5 years, depending upon which
option is selected by USEPA.
~ow long will it ta~e from now (Sept~mber 13) until cleanup is
QUESTION:
Who would pay for the cleanup option ultimately selected?
RESPONSE: Before the State and Federal Governments proceed with spending
money for cleanup, the Cross 8rothers and other responsible parties will
be requested to undertake the cleanup. If they decline, then State and
Federal money will be used to finance cleanup. In certain limited circum-
stances, responsible parties may be liable for daMages equal to three
times the government's cleanup cost.
Issue:
Public hea1t~
QUESTION: I have a garden and live near the site.
the Cross Brothers affecting my crops?
Is the waste dUMped by
RESPONSE: Waste dumped at this site is moving off the site primarily
through the groundwater. As long as the root system of the crops planted
in your garden do not tap into the groundwa~er, there is no danger. SOMe
crops whose root system does tap into groundwater, will not necessarily
draw contaminants into the plant. If you are in doubt as to whet~er your
crops tap into the groundwater, you should check with your local
agricultural extension service in Kankakee County.
QUESTION: Is there any info~ation from our office or IDPH that
discusses health problems related to waste at this site?
~
RESPONSE: The IEPA requested IDPH to conduct a health survey and
examinations for the Clybourn and Robinson families since they had
consumerl contaminated drinking water. Health examinations were conducted
and evaluated by the Cook County Hospital, Division of Occupational
Medicine. Their findings concluded that no evidence of any significant
health problems as a result of possible toxic exposure, were found. Seven
of the individuals tested had elevated levels of liver enyzymes, hut this
is unrelated to toxic exposure.
QUESTION: Has any health study been conducted to determine if there is a
correlation between death rates in Pembroke Township and waste dumped at
the Cross Brothers Site?
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RESPONSE: ~o. Inquiries about further health studies should be addressed
to health organizations such as the Center for Disease Control or IDD~.
QUESTION: What are the short and long-term health effects from exp~sure
to wastes dumped at the site?
RESPONSE: The concentration of waste and length of exposure are key
determinants as to what kinds of health effects, if any, people in
Pembroke would experience.
Short-term health effects include skin rash, nausea, and
eyes, ears, nose and throat. Some of these symptoms may
initial exposure. Long-term exposure to wastes found at
affect the central nervous system, liver and kidneys.
irritation of the
disappear after
this site may
Since virtually all of the waste is in containers and underground, the
primary way in which residents could become exposed to this waste is
through the drinking water. Shallow wells serving the C1ybourn and
Robinson families have been the only wells found to be affected by waste
from this site. Monitoring wells are being used to make sure that the
contamination does not reach other drinking water wells.
Issue:
Cleanup process
COMMENT:
stuck.
If it (the cleanup option) doesn't work, the community will be
QUESTION: After the cleanup is finished, will any contamination remain
that could contaminate drinking water?
RESPONSE: The State of Illinois and any responsible parties will be
responsible for monitoring and maintaining the site. Additional
monitoring wells will be installed to check the groundwater. If
contamination is found in these monitoring wells, appropriate follow-up
work will be initiated.
QUESTION:
selected?
Who will make the final decision as to which cleanup choice is
RESPONSE: The IEPA will recommend a choice, but the USEPA will decide
which cleanup choice is used.
QUESTION:
option?
RESPONSE: Yes. Community Questions and concerns are evaluated along with
geologic, environment~l, and other technical factors when the IEPA
recommends a cleanup option. These same Questions and concerns are
forwarded to USEPA who will make the final decision.
Does the community have any voice in the selection of a cleanup
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Additional Comments
COMMENT: This part of the State has taken hazardous waste from allover
the country.
RESPONSE: No permitted hazardous waste disposal facilities exist in
Kankakee County.
COMMENT: There is no conceivable amount of hazardous waste that anyone
should be exposed to.
RESPONSE: Small quantities of hazardous substances are found in many
households. Drain opener, spot and fingernail" polish remover, hair care
products, paint thinner, septic tank cleaner, insect repellent, and
television sets are some of the items that contain hazardous substances.
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