United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-85/027
September 1985
Superfund
Record of Decision
Wauconda Sand & Gravel, IL
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-85/027
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 30, 1985
6. PERFORMING ORGANIZATION COOE
Wauconda Sand & Gravel, IL
7. AUTHORCS) 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 ReDort
14. SPONSORING AGENCY CODE
401 M Street, S.W.
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Wauconda Sand and Gravel Landfill site is located in Lake County, Illinois,
approximately two miles north of the Village of Wauconda. The 74-acre site is com-
prised of a 43-acre unpermitted landfill, a nine-acre permitted landfill, nine acres
which are excavated but unfilled, and 13 acres of perimeter sit~ area. . Befor~ 1950,
the site property was used as a sand and gravel pit. From 1950 un~il 1977, Wauconda
Sand and Gravel Company operated the northern portion (43. acre~ unpermitted fill) of.. -_. .
the s~ t'e' as.. alandt'l'll. . Landfiii operations during this period consisted of
dumping refuse into the mined~out gravel pit. The refuse deposited at the landfill
consisted of residential garbage, construction debris, some industrial sludges and
drums with undetermined contents. In 1980, a private well adjacent to the eastern
boundary of the landfill was sampled b~' Illinois Environmental Protection Agency and
inorganic, organic and PCB contamination was detected. Additional investigations con-
cluded that PCBs, metals, and organics were contaminating the ground water and surface
water (Mutton Creek) .
The selected remedial action for this site includes: installation of leachate col-
lection drains to stop surface leachate discharge into Mutton Creek; providing for
proper disposal of leachate (either at the Wauconda Sewage Treatment Plant, or a
hazardous waste treatment facility in accordance with Agency policy); regrading settled
(see attached page)
17. KEY WORDS AND DOCUMENT ANAL YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Wauconda Sand & Gravel, IL
Contaminated Media: gw, sw, soil
Key contaminants: inor9an~cs,organics, PCBs,
metals
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Reporr) 21. NO. OF PAGES
None 45
20. seCURITY CLASS (This page) 22. PRiCe
None
EPA Form 2220-1 (Rev. "-77)
PREVIOUS EOIT'''N IS OBSOL.ETE
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number and include subtitle for the specific title.
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6.
PERFORMING ORGANIZATION COOE
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AUTHOR(SI
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utian.
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t.
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16. ABSTRACT
Include a brief (200 words or less) factual summary af the mast sil!!nili.-anl informaliun ,'onlainell in Ih,' H'I"lrl. II Ih.. H,,,,,,I ...".1.."" a
significant bibliagraphy ar literature survey, mentian it here.
Prcpared ill coaperation wilh, Translall"n ..... l're,,'"I,''' OIl ,'..nl""'I1"" ..I'.
17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS - Select fram the Thcsaurus af lnginecrin~ and Scientilk Terms Ihe proper aUlh"ri!.ed I,'rllls Ihal identify Ih,' majm
cancept af the research and are sufficiently specific and precise 113 be used as index enlries for caialol'lnl'.
(b) IDENTIFIERS AND OPEN-ENDED TERMS. Use identifiers far praject nam", code names, eljulpment d,'sil'nators, ell:. U\c ""CI1-
ended terms written in descriptar farm far thase subjects far which na descriptor eJi;ists.
(c) COSA 11 nno GROUP -Field and group assignments are 113 be 101 ken from the 1965 COSI\ 11 Suhi~'.:1 ('al,'~ury Us!. Sincl' th\: nla.
jarity af documents are multidisciplinary in nature, the Primary Held/Graup assignmenlfs) will be SP"" ilk cJisu"linc, an'a III' human
endeavar, or type af physical object. The applicatianls) will be cross-referenced with \c,'ondary I id.I/(;rulll' dsslj!nlllenis "1:11 ..'ill ....II....
the primary pastingls).
'8. DISTRIBUTION STATEMENT
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. '.
"~.'. ..,-~-~-~. .-.
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SUPERFUND RECORD OF DECISION
Wauconda Sand & Gravel, IL
Continued
depressed and eroded areas on the existing landfill soil cover with sufficient
slope to promote rain runoff; revegetating bare and eroded areas to prevent
erosion of soils into Mutton Creek; and fencing. This operable unit only addresses
leachate discharge to Mutton Creek; ground water decisions are being deferred until
additional RI/FS work is completed. Total capital cost of the selected remedial
alternative is estimated to be $1.6 million with annual O&M costs of approximately
$50,000 for a 30-year period.
~
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~ '('
Record of Decision
Operable Unit Remedial Alternative Selection
Site:
Wauconda Sand & Gravel Landfill. Wauconda. Illinois
Documents Reviewed:
I am basing my decision on the following documents describing the analysis
of cost-effectiveness of remedial alternatives for the Wauconda Sand &
Gravel site:
Wauconda Sand and Gravel Remedial Investigation. Data Report
Wauconda Sand and Gravel Remedial Investigation. Analysis/Development
of Alternatives Report
Waucorida Sand and Gravel Remedial Investigation Supplement
Wauconda Sand and Gravel Feasibility Study
Responsiveness Summary
Description of Selected Interim Remedial Measures:
Install leachate collection drains to stop surface leachate discharge
into Mutton Creek.
Provide for leachate disposal at Wauconda sewerage treatment plant. if
acceptable, or at a hazardous waste treatment facility in accordance
with Agency policy.
Regrade settled, depressed and eroded areas on the existing landfill
soil cover with sufficient slope to promote rain runoff. This
will eliminate ponding and reduce infiltration.
Revegetate bare and eroded areas to prevent erosion of soils into Mutton
Creek,and exposure of landfill materials.
Construct a fence around the site to protect landfill cover and to
prevent human contact with gas vents and leachate collection
system.
Declarations:
Consistent with the Comprehensive Environmental Response Compensation. and
Liability Act of 1980 (CERCLA), and the National Contingency Plan (40 CFR
'part 300)~-I have determined that the interim remedial measures listed above
for the Wauconda Sand and Gravel site are cost-effective, contribute to the
protection of pUblic health, welfare and the environment, and are a necessary
component of the total remedy.
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- 2 -
The State of Illinois has been consulted and agrees with the above ljsted
interim remedial measures. In addition. the action will require future
operation and maintenance activities to ensure the continued effectiveness
.of the remedy. These activities will be considered part of the approved
act hm .
I have also determined that the action being taken is a cost-effective
alternative for interim action when compared to the other remedial options
reviewed. In addition. the off-site treatment of leachate is more cost-
effective than other remedial actions. is protective of public health and
the environment, and will be consistent with the final remedy.
Concurrent with the implementation of these interim measures. the U.S. EPA
will undertake a supplemental remedial investigation/feasibility study to .
further evaluate the extent of ground water contamination and recommend an
appropriate final remedy. If additional remedial actions are determined to
be necessary, a Record of Decision will be prepared for approval of the
future remedial action.
~ 3c'/
",. Date
Jr/~
L~~\
Valdas . Adamkus ~
Regional Administrator
Region V
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Summary of Remedial Alternative Sel!ction
Wauconda Sand and Gravel landfill
Site location & Description:
The Wauconda Sand and Gravel landfill site is in the W 1/2 of the NW 1/4 of
Sec~ion 24, T 44N, R9E of the 3rd P.M., lake County, Illinois (Figure 1). The
Site is about 2 miles north of the Village of Wauconda and about 3 miles east of
the Village of Island lake. The area was formerly used as a source of sand and
gravel, then later used as a landfill. The 74-acre site is comprised of a 43 acre
unpermitted landfill, a 9 acre permitted landfill, 9 acres which are excavated but
unfilled, and 13 acres of perimeter site area. This site is bordered on the
east by Garland Road, on the south by Bonner Road, on the north by Mutton Creek,
and on the west by pasture and cropland (Figure 2). Mutton Creek drains into
Island Lake, which is approximately 3-1/2 miles west of the site. Approximately
12 homes are located within one quarter mile north and east of the landfill
perimeter. In addition, a residential development known as the Hillcrest community
is located east of the site. There are approximately 100 homes in this development.
The landfill itself is zoned within the municipal boundaries of the Village of Wauc-
onda, the surrounding homes and Hillcrest community are not located within the
ci ty limits.
"-
An estimated 5.4 million cubic yards of waste material are contained in the 43
acre unpermitted landfill. Nine acres at the southern part of the site was
perm1tted by the l11in01s Environmental Protection Agency (IEPA) as a sanitary
landfill. Both the permitted and unpermitted portions of the site were closed in
1978 and clayey loam soil was placed on top. This site overlies two apparently
separate aquifers in the unconsolidated (glacial drift) materials above bedrock.
The upper 80 to 160 feet of these glacial soils consist mainly of a sand and
gravel outwash deposit, referred to as the upper aquifer. Below the outwash
(i .e. below the upper aquifer) there is a dense clayey to silty till layer that
appears to be horizontally continuous beneath the site. The till layer is
approximately 70 feet thick beneath the landfill's southern portion and 20 feet
thick just east of the landfill's northeast corner. More sand and gravel outwash
lie beneath the till layer and comprises a lower aquifer. Bedrock (dolomites and
sandstones) underlies the lower aquifer at depths of 200 to 300 feet below the
surface. Based on reported landfill bottom elevations, measured groundwater
elevations, and ground surface contours, 40~ of the total waste volume is estimated
to lie below the water table in the upper aquifer. Most residents are believed
to have wells in the deep drift aquifer, or in the bedrock aquifer(s), although
some wells within" 1/4 mUe of the site are of unknown depth.
The site property is presently used for some recreational activities including
rifle practice, model airplane flying and snowmobiling.
Site Hi story
Before 1950, the site property was used as a sand and gravel pit. This pit
covered a major portion of the present site and was excavated to an estimated
maximum depth of 730 feet above sea level, which is about 40 feet below~he
shallow aquifer groundwater table and 40 to 80 feet below adjacent ground surface
contours. Soil borings made at the landfill perimeter, geophysical test results,
and IEPA reports indicate that waste materials were deposited in the landfill at
and above the 730 foot elevation.
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SCALE IN FEET
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300
AERIAL PHOTO TAKE~
, 0:25 '83,
, Bonner- . ----
h__. . '.. .. -.~= ~~,~.~"'-:~~
-- FIGUR~
WAUCONDA LANDFILL
AERIAL PHOTO
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~LAKE M./CH/GAN
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FIGURE l'
SITE LOCATION MAP
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MILES
SCALE
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-2-
In 1950 Wauconda Sand and Gravel Company was incorporated and from 1950 to 1977,
operated the northern portion (43 acres unpermitted fill) of the site as a landfill.
Landfill operations during this period consisted of dumping refuse i~to the
mined-out gravel pit. No efforts were made to control leachate migration (e.g.,
by placing a liner in the bottom of the pit). The refuse deposited at the landfill
consjsted of residential garbage, construction debris, some industrial sludges
and drums with undetermined contents.
In 1980, a private well adja,ent to the eastern boundary of the landfill was
sampled by IEPA and fnorganic, organic and PCB contamination was detected. As a
result, the well owner drilled a deeper well into an uncontaminated aquifer.
Following this sampling the IEPA and the Lake County Health Department conducted
additional monitoring of several water supply wells in the area, Mutton Creek (a
creek on the northern boundary of the landfill) and several groundwater monitoring
wells around the perimeter of the landfill. The investigations concluded that
PCBls, metals, and organics were contaminating the ground water and Mutton Creek.
In 1981, the Wauconda Landfill was .scored at 53.42. The site was subsequently
listed on the 'Nationa Priorities List, and designated for investigation under
the CERCLA (Superfund) program.
Current Site Status
U.S. EPA conducted a remedial investigation in 1983 (Phase I), the results of which
were released in the fall of 1984. Thereafter, the Wauconda Task Group (WTG), a
group formed by several potentially responsible parties (PRP's) requested the
opportunity to develop supplementary data. Both the WTG, by their consultants,
Conestoga Rovers and Associates, and U.S. EPA performed additional investigatory
work during the spring of 1985. This investigation included resamp1ing of some
existing monitoring wells (Phase II) and installation and sampling of eight
additional monitoring wells (Phase III). These additional results were set forth
by U.S. EPA in the Remedial Investigation Supplementary Report dated August 1,
1985. Conestoga Rovers also issued two reports dated May 1985 and July 1985.
A feasibility study completed in August, 1985 was intended for selection of an
appropriate final remedy. However, because of the need to obtain further data to
more accurately characterize the extent of ground water contamination and to
predict possible future endangerment as the result of ground water contamination,
a cost effective final remedy for ground water cannot be determined at this time,
and additional RIfFS tasks are reco~nended. In as much as the remedial invest-
igation has documented a release of hazardous substances from the Wauconda Sand
and Gravel site into Mutton Creek via leachate seeps, the selected alternative
recommends repair and maintenance of the existing site cap to eliminate this
occurrence.
The results of the site investigations to date are summarized in three sections;
1) Mutton Creek, 2) Site Use, and 3) Ground ~ater.
Mutton Creek
Mutton Creek receives contaminants from the Jandfil1 by one or more of the
following pathways: surface water runoff and erosion of contaminated soils,
leachate seeps that discharge into the creek, and ground water migration
through the landfill recharging the creek. Since ground water decisions are
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TO ISLAND LAK E
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LAKE'REDEEN
..---f?1
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WS301
WS101
WAUCONDA
LANDFILl;
WS601
WSOOl
~o
LEGEND:
.
SAMPLE LOCATIONS
~
WSS01
CONSTITUENTS DETECTED IN
CONCENTRATIONS
EXCEEDING CRITERIA:
6
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ORGANICS
'ESTICIDES
INORGANICS
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1000
.
SCALE IN FEET
2000
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NOTES:
1. WSOO',002. ANO"O' ARE LANDFILL
LEACHATE SAMPLES. THE REMAINING
SAMPLES ARE SURFACE WATER ICREEK
OR 'ONOI.
~ SEETAILE3-2FORTYPESAND
CONCENTRATIONS OF CONTAMINANTS
FOR EACH LOCATION.
FIGURE 3
SAMPLING I CONTAMINATION
LOCATIONS SURFACE WATER
PHASE I DATA
. ".'.. -'.-'.'"'' - .-~'I"'-
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Sample :
Locati~n Parameter
Concentrationa 24 hr.
WS002
WSOOI
WS401
SS401
; .
, .
,
. ,
Cadmi um
Chromium
Cyanide
Lead
Nickel
Zinc
Lead
Nickel
Zinc
2-Butanone
1.1
30.0
43.0
47.0
220.0
271.0
27.0
204.0
326 .0
Nickel 60.0
Zinc 799.0
. Silver. 49.0
1,2-0ichloropropane 190.0
Toluene 330.0
4-Nitrophenol 90.0
P-Chloro-m-cresol 20.0
Oi-N-Butyphthalate 26.0
4-Methylphenol 9.8
2 Hexanone 380.0
4-Methyl-2-pentanone 490.0
2-8utanone' 22000.0
Trans-l,2-0ichloroethene 710.0
1,1-0ichloroethane 63.0
4 methyl-2 pentanone
Toluene
Xylene
Chloromethane
Acetone
2-Butanone
ganlna RHC
20.0
33.0
5.0
13.0
922.0
304.0
9.0
Table 1: Applicable Criterta
Freshwater Aquattc Ltfed
Ingestton (10-6)
1980
1985 Water & Aquatic
4 day avg.---One hour avg Aquatic Water Organisms
Once 1n 3 vr Once in 3 yr Organisms Only Only
Anytime
.09 10.31
.29 21.0
3.5 52.0
59.8 716.9
232.4 4485.7
47.0 848.0
59.8 716.9
232.4 4485.7
47.0 848.0
232.4 4485.7
47.0 848.0
.12b 30.3
5700.0b
17500.0c
230.0c
30.0c
2.84 14.67 10.0
11.00 16.00 50.0
5.2 22.0
14.1 363.0
13.4 15.4 100.0
14.1 363.0
13.4 15.4 100.0
15.4
13.4
50.0
100.0
14300.0
.56
424000.0
. I
.
r
a. water samples (WS) in ug/l; sediments sampl
b. available data indicate chronic toxicity me
,.. ~vai hhlp ti.lt..l indicate "cllte toxicity may '-
~) ,in ug/kg.
r at concentrations as low as this value.
at concentrations as low as this value.
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being deferred, this section addresses only the potential for contamination
of the creek via erosion of contaminated soils and leachate seeps. Contamination
of Mutton Creek is a concern because it flows into Island Lake, a rec~eational
lake (fishing, swimming) located approximately 3.5 miles to the west, The
source of Mutton Creek, Mud Lake (also known as Lake Bredeen), is located
approximately 1/4 mile northeast of the landfill. The area around the creek
is rural and agricultural. The creek varies in width and depth as it passes
north of the landfill site. The width varies from one to three feet, and it
is a perennial stream. The creek is large enough to sustain invertebrate
forms of aquatic life, but is probably too small to support fish life.
Test results from surface water and sediment samples taken on and around the
landfill during the RI have documented a release of contaminants from the
landfill to the creek. Sampling locations are shown on Figure 3. Leachate
seeps discharging to Mutton Creek are identified as WS401 and WS002. The
other leachate seep WS001, is on the southwest side of the landfill. The
corresponding sediment samples are denoted with an "S$" before the sample location
number. Table 1 shows the concentrations of contaminants in leachate samples and
indicates which concentrations exceed the cancer risk, health or fresh water
aquatic life criteria. New water quality criteria have recently become
available for some metals, and have been incorporated in the table..
Table 1 shows that the discharges exceed fresh water aquatic life criteria
levels for the metals: cadmium, zinc, lead, silver and chromium. Cyanide
exceeds freshwater aquatic life criteria and the State of Illinois standards
for general use. In addition, five metals are found in higher concentrations
at downstream sampling location WS301 than upstream location WS101 (Barium,
iron, nickel, zinc, and lead). All other compounds (principally the organics)
detected do not have criteria to which to compare these leachate discharge
concentrations or were below criteria levels.
No pesticides were detected upstream (BHC, however, was found in leachate
sediment 5S401). Pesticides were found in the creek downgradient of the site at
WS301. Pesticides have also been found in the monitoring wells on both sides
of the creek. The presence of pesticides in the creek may be due to both the
landfill and the agricultural practices in the area. 5ince this is an agricul-
tural community it is impossible to separate the contributions of pesticides
made to the creek by the landfill versus the adjacent agricultural field.
Consequently, the pesticide data has been deleted from table.
The leachate stream sediment sample 55401 contains seven organic contaminants.
The downstream sediment sample SS301 has three of the same contaminants as
55401 (Toluene, Acetone, 2-Butanone). The landfill is the likely source of
these contaminants. .
Site Use
The landfill has experienced some subsidence. This has created depressions where
ponding occurs, thus increasing infiltration. Unvegetated ereas are eroding,
which may result in exposure of landfill materials and leachate seepage. Some
waste materials (tires, etc.) are protruding from the surface. Leachate seeps
along the north perimeter of the landfill area discharge to Mutton Creek. Leachate
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-4-
seeps along the southern end of the landfill do not discharge to any body of
water, but may be a direct contact threat. This site is readily accessible and
is used as a recrea~ional area. The southern 18 acres are used for model airplane
flying and rifle practice. In the winter, the entire surface is USed for snow-
mObiling.
Ground water
Ground water flows through this site from the south to the north and northeast in
the shallow aquifer (Figure 4). The toxic compounds of principal interest (i.e.
detected in ground water above applicable criteria) in the ground water are
nickel. lead, chromium, cadmium, vinyl chloride, benzene, trichlorethene, N-
nitrosodiphenylamine, bis (2 choroethyl) ether and tetrachlorethene. The pesticides
heptachlor, dieldrin and BHC have also been detected above relevant criteria,
however, their presence may also be due to nearby land use. Arsenic was detected
at levels exceeding the 10-6 cancer risk criteria but below drinking water criteria.
PCBs detected during the initial site investigation were not detected during the RI.
Other contaminants have been detected but are below relevant criteria or have no
established criteria.
During Phase I of the remedial investigation 21 residential homes ~nd 25 monitoring
wells were sampled. Three residential wells were found to contain at least one
organic contaminant above the 10-6 cancer criteria, or inorganic contaminant above
health criteria. A total of 13 out of 25 monitoring wells contained at least one
organic contaminant above the 10-6 cancer criteria. Numerous inorganic contaminants
were also detected.
The Phase II sampling effort was undertaken to address a concern, articulated by
WTG, that collection of unfiltered samples during Phase I resulted in an overesti-
mation of metal contamination. Therefore, fifteen wells were resampled for
filtered and unfiltered metals analysis. Samples were split with the WTG. The
Phase III effort consisted of constructing eight new wells (by WTG). During
this phase of investigation, all eight new wells were sampled, and six existing
wells were resampled. The ground-water data from all phases are summarized on
Table 2. All RI sampling efforts are summarized on Table 3.
Summary of Ground water Data
A review of extsting data shows a release of some contaminants to the ground water.
However. the low levels of contaminants and limited amount of data make drawing
conclusions about the ground water and areal extent of the release impossible at
this time. Due to the low levels of contaminants a statistical approach to data
evaluation is recommended. However, application of these methods requires more
data points than"exist at present. Therefore. additional ground water sampling
and inYestfgat~ons are being included in the additional RIfFS tasks. "
Enforcement Analysis
See Attachment A.
- . -. .,' _. ...~. .
-------
. /";~:~:30~:>
0303A "" 768.9 ',' :
~~~'~~~i;
".:;, ' 769.7 .:"
...~..~.\y
--lAKF
''''1'''[ f N
03059
766,9 "'0
(;"'1
0,,-
('1
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-
leGEND
0(;302
72.3
o MONITORING WELL lOCATION
.-.r7DIRECTION OF GROUNOWATER
\./'" FlOW
GH2 ./MEASUREDWATER leVEL
767.5' OF WEll
, OW401
l(}~t
,0 G103 ;'::,
, ..' 773.8"'"
. I'
- 769- GENERAUZfD POTENTIOMETRIC
SURFACE IN FUT ABOVE
MEAN SEA LEVEL,
BONNER ROAD
.
767.3
SURVEYED WATER SURFACE
elEVATION OF MUTTON CRUK
NOTE:
DIRECTION OF GROUNDWATER FLOW
OfVElOPEO fROM PHASE III RI WATER
lEVel MEASUREMENTS,
~
'"..-.'
o 700
L-!
SCAle IN FEET
.00
FIGURE 4
GROUNDWATER FLOW DIRECTlr;,'
IN UPPER AQUIFER
, '
':
!
-------
Table 2
SAMPLED WELLS INDICATING PRIORITY POLLUTANTS
AT OR ABOVE USEPA CANCER RISK OR HEALTH CRITERIA
PHASE 1. PHASE II. OR PHASE III
Reported Concentration (ug/L)
Phase II Phase I I 1-
Sample Phase 1 Unfiltered/ Unt; 1 tered/ Criter; a
ID. Contaminant Name Unfil tered Fi ltered Fi ltered (ug/L)
GI02 Arsenic 186 27/15 NS 50C(2.5 ng/L)a
Chromium 207 5.3/l?dl 50c
Lead 4.000 1.490' /bdl. 50c
Nickel 436 bdl/bdl 15.4b
Tetrachlorethene 21 .881
G103 Lead 98 23i/bdl 68/bdl 50c
Chromium 21 65/5.3 621bdl SOc
Nickel bdl bdl/bdl 38/6 15.4b
Arsenic 16 bdl/bdl 30/bdl 50C(2.5 ng/L)a
N-Nitrosodiphenylamine 47 NA bdl 4.91 .
Trichlorethene 51 NA bdl 2.8a
GI04 Cadmium 14 bdl/bdl NS 10c
Chromium 87 73/3.~ 50c
lead 225 bdl/9.8' 50c
Nickel 364 123/bdl 15.4b
GI05 Chromium 51 21/bdl NS "
Lead 126 361/bdl
Nickel 131 21/bdl 15.
GI06 Tetrachlorethene 18 NS NS .881
G112 Chromium 53 37/6.3 NS 50c
Lead 86 7.31/bdl 50c
Nickel 117 19/11 15.4b
Tetrachlorethene 14 .88a
G1120 lead 12.5i/NS 50c
Nickel 31/NS 15.4b
G1l3 Arsenic. 78 NS NS SOtt2.S ng/l)a
Tetrachlorethene 6 .88a
Benzene 9 .67a
G114 Lead 55 bdl/bdl 40/bdl 50c
Nickel 85 34/32 65/32 15.4b
Arsenic 44 26/23 40/25 50C(2.5 ng/L)a
Chromium 42 . 9.2/4.0 49/bdl 50c
Dieldrin 0.006 0.0011 ng/LI
Heptachlor 0.10 0.01121
Vinyl Chloride 27 2.01
N-Nitrosodiphenylamine 9 4.91
Benzene 4e 0.67a
-------
<.. , '.
Table 2
(continuea)
SAMPLED WELLS INDICATING PRIORITY POLLUTANTS
AT OR ABOVE USEPA CANCER RISK OR HEALTH C~ITERIA
PHASE I. PHASE II. OR PHASE III
Reported Concentration (ug/L)
Phase II Phase IlL
Sample Phase I Unfilteredl Unfilteredl Criteria
10 Contaminant Name Unfiltered Fi ltered Fi ltered (ug/l)
G1140 Lead 68 50c
Nickel 104 15.4b
Arseni c 52 50C(2.S ng/L)a
Chromium 49 SOc
Vinyl Chloride 30 2.0a
N-Nitrosodiphenylamine 10 4.9a
Tetrachlorethene 7 .88a
G1l5 Lead 50 NS 43/bdl sac ~
Nickel bdl 35/9 15.4b
Arsenic bdl 24/bdl 50C(2.5 ng/L)a
Heptachlor 0.012 bdl 0.01l2a
N-Nitrosodiphenylamine 52 bdl 4.9a
G116 Nickel 42 NS 42/33 1S.4b
G117 Nickel 43 bdl/bdl NS 1S.4b
Tetrachlorethene 8 .BSa
"
203A Lead 153 72i/bdl 68/bdl 50c
Nickel 20.7 bdl/bdl 43123 1S.4b
Bis(2-chlorethyl)ether 5.6 NA O.03a
Benzene 4.6 NA O.67a
203AO Lead bdl 50/35 sac
Nickel bdl 25/23 15.4b
Bis (2-chlorethyl) ether 5.7 bdl O.03a
Benzene 4.4 11j O.67a
G2S0 Vinyl Chloride 3.8 NS NS 2.0a
G301 Nickel 45 bld/bdl NS 15.4b
Vinyl Chloride bdl 5e 2.0a
Tetrachlorethe~e 26 .88a
G3010 Vinyl Chloride 4.Se 2.0a
T ri ch 1 orethene . 2.5e 2.8a
303A Nickel 47 NS 38/20 1S.4b
Lead bdl 88/7 sac
N-Nitrosodiphenylamine 14 bdl 4.9a
Benzene .bdl . -l6j O.67a
Gamma-BHC (Lindane) 0.0025 0.018a
-------
Table 2
(corlL i nu~d)
SAMPLED WELLS INDICATING PRIORITY POLLUTANTS
AT OR ABOVE USEPA CANCER RISK OR HEALTH C~ITERIA
PHASE I, PHASE II, OR PHASE III
Reported Concentration U!.9..ill
Phase II Phase lIt
Sample Phase 1 Unfiltered/ Unfiltered/ Cri teri a
ID Contaminant Name UnfO tered Filtered Filtered -( ug/L)
303~ Chromium 125 1901bdl NS 50c
Lead 219 182.5'bdl 50c
Nickel 149 162/bdl 15.4b
G304 Arsenic 87 142114 NS 50(2.5 ng/L)ad
lead 69 118.5i/bdl 50c
Nickel 102 192119 15.4b
Chromium bdl 44/bdl SOc.
Benzene 6 NA 0.67a .
Tetrachlorethene 10 .88a .
G306 Lead 52 bdl/bdl NS 50c
Tetrachlorethene 10 .888
G307 lead 52 17i /bdl NS 50c
Nickel 49 53/bdl 15.4b
Benzene 7 NA 0.67a
G308 Nickel 63 bdl/bdl NS }'
Arsenic 34 31128 50C(2.5 n~
G308D Arsenic 321bdl 50C(2.5 ng/L)a
G310 Lead 109 bdl/bdl NS sac
Chromium 63 bdl/bdl 50c
Nickel 103 bdl/bdl 1S.4b
Vinyl Chloride 4.Se 2.0a
G310D Lead 105 50c
Chromium 62 50c
Nickel 110 15.4b
G309 Trichlorethene 6 NS NS 2.Sa
Chromium 85 50c
Alpha-SHC .01 .0092
G311A Benzene 22 NS NS 0.678
Trichlorethene 28 2.8a
Tetrachlorethene 17 .88a
OW401 Benzene llj 0.67a
OW402 Nickel 48/32 15.4b
Arsenic 9/bdl . 50C(2.5 ng/L)a
Benzene 4J 0.67a
-------
~. .'
Table 2
(continued)
SAMPLED WELLS INDICATING PRIORITY POLLUTANTS
AT O~ ABOVE USEPA CANCER RISK OR HEALTH CRITERIA
PHASE I, PHASE II, OR PHASE III
Reported Concentration (ug/L) .
Phase II Phase III
Sample Phase I Unfiltered/ Unfil tered/ Criteri a
10 Contaminant Name Unfiltered Fil tered Filtered (ug/L)
OW403 Vinyl Chloride 1.9f 2.0a
OW404 Nickel 38/6 15.4b
Arseni c 23/bdl 50C(2.6 ng/l}a
OW406 Nickel 30/10 lS.4b
Arsenic 13/bdl 50C(2.5 ng/L}a .
-
OW406D Nickel 30/14 15.4b
Arsenic ll/bdl 50C(2.6 ng/L)a
OW407 Nickel 18/8 15.4b
Vinyl Chloride 2.0f 2.0a
OW408 Nickel 30/28 15.4b
"
IUSEPA assigned carcinogen risk level of 10-6; one additional case of cancer in a popula-
tion of 1.000.000 exposed for a lifetime.
bUSEPA health criteria (noncarcinogen; no adverse health effect level).
cUSEPA primary drinking water standard.
dArsenic carcinogenicity is currently being re-evaluated by USEPA;
water standard and cancer risk criteria are shown.
therefore both drinking
eEstimated value.
fpresence indicated but less than detection limit.
90etectable, but low quantifiable levels.
hHi9h laboratory data. fluctuations for arsenic, results could be high- or low-biased.
1Laboratory matrix spike measurements show low recoveries for lead (70 percent); thus. the
data are low-biased.o
jBenzene detected in.field sample blanks and laboratory blanks; thus, this could be an
. add it ive contami nant .
Notes:
o = dyplicate sample.
bdl = below detection limit.
NA = not analyzed; only three wells tested
6301, and 6310).
NS = not sampled.
Criteria Source: Ambient Water Quality Criteria for Water. U~EPA. 1980
for organics during Phase II (G114,
- ,,-0.. _.0 .
-------
Table 3
.
Sampling Phases
Monitoring
Well
Remedial Investigation
1983
Supplemental"
Investigation, 1985
Phase I
Phase II
Phase I II
G102
G103
GI04
GIOS
GI06
G1l2
G113
G1l4
Gl1S
G116
G117
G301
G302
G303A
G303B
G304
G305A
G30SB
G306
G307
G308
G309
G310
G311A
G311B
OW401
.OW402
OW403
OW404
OW40S
OW406
OW407
OW408
Residential Wells2
x
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Xl
X
X
X
X
X
Xl
X
X
X
X
X
X
Xl
X
X
X
X
X
X
X
X
X
G201
G203A
G2S0
X
X
X
Xl
X
1. These are the only .three wells which had organic and inorganic analysis
in Phase II; all others sampled in Phase II had analysis for metals only.
2. 21 residential homes were sampled; only those listed here identified
some type of contaminant.
-------
j, ". .
-5-
Alternative Evaluation -- Summary of Feasibility Study.
The Feasibility Study proposed several source control and containment alternatives.
These alternatives were screened and a preliminary selection of the most feasible
alternatives were submitted for public review and comment in the Remedial Investi-
gation Analysis/Development of Alternatives Report (November 1, 1984). This
report identified the following site problems:
o
contaminated materials within the landfill
o
high ground water in contact with contaminated material
contaminated shallow aqu~fer ground water migrating north
and east from the landfill
o
o
precipitation infiltrating through the existing soil cover
of the landfill to form leachate
leachate discharging from the landfill to Mutton Creek
This operable unit addresses only the last problem listed above: leachate discharge
to Mutton Creek. Because the FS discusses all other problems at the site, a review
of each of the seven alternatives discussed is briefly presented here. Since the
groundwater remedy i5 being deferred, Alternatives 2, 3, 4, and 5 are still under
review and consideration for future action. The operable unit recommended at the
present time is addressed by Alternatives 1, 6, and 7.
o
A list of potential technologies for controlling surface and ground water contami-
nant migration at Wauconda was developed by geotechnical and industrial waste
process engineers and a hydrogeologist. The following is a list of technologies
reviewed and the screening criteria:
Technologies Reviewed
o Excavation
o Emission control
o Solids/semi solids treatment
o liquids treatment
o Insitu treatment
o Solids disposal (untreated wastes)
o Capping
o Vertical containment barriers
o Horizontal containment barriers
o Ground water pumping
o Subsurface drains
o liquids disposal (untreated wastes)
o Gas collection systems
o Recovery/reuse/recycling
o Alternative water supply
Screening Criteria
o Applicability
o Status of technology
o Implementability
o Reliability
o Operation and maintenance
o Cost requirements
~ -" . "--.. \. F- '.".~~.
-------
... ~ # ~.
-6-
Based on this screening process, the feasibility study thoroughly investigated
7 alternatives. Table 4 is a cost summary for these alternatives. This feasibility
study was submitted for public review and comment on August 12, 1985. The remainder
of this section describes the alternatives evaluated in the Feasibiljty Study based
on existing data.
Alternative' 1:
New Cap
This Alternative would eliminate leachate discharge to Mutton Creek and reduce
ground water contaminant migr.ation by minimizing infiltration of water through
the waste due to precipitation. The cost and effectiveness of a 2-foot thick
clay cap was compared to a 30-mil-thick PVC plastic liner. The plastic liner was
selected as the most reliable. effective means of reducing the present infiltration
estimated to be 3.5 million gallons per year by 98 to 100 percent. However, this
alternative alone does not address the estimated 5.3 million gallons of ground
water that is estimated to flow horizontally through the landfill annually. The
present worth of this alternative is estimated to be 10.4 million dollars. .
Alternative' 2:
New Cap and Vertical Barrier (Slurry Wa"t
This alternative would reduce ground water contaminant migration and surface
leachate discharge by minimizing infiltration due to precipitation and reducing
ground water flow through the site. The PVC liner cap as described in Alternative
1 is included in this alternative. In addition. an impervious vertical barrier
in the ground around the site called a slurry wall would be constructed. The
slurry wall should divert ground water around the landfill. The present worth of
Alternative 2 is estimated to be 18.7 million dollars.
Alternative' 3:
New Cap, Ground water Pumping, and Liquids Treatment
This Alternative would reduce surface leachate discharge and ground water contam-
inant migration by minimizing infiltration due to precipitation and redirecting
contaminated ground water flow to a pump out system. The PVC liner capas described
in Alternative 1 is included in this alternative. Although the cap would not
prevent ground water from flowing through the landfill and leaching contaminants
from wastes buried beneath the groundwater table. the pumping of ground water
around the site directs the groundwater flow direction toward the pump out wells.
As a result, a hydraulic barrier is created. The alternative includes pumping of
off-site groun~ water in areas where contaminants have been identified. Because
the on-site contaminant removal times are so slow, the pumping wells would probably
have to be operated ~ndefinitely 1n order to prevent future release of contaminants.
The present worth of this alternative is 21.6 million dollars based upon treatment
for metals removal on site with effluent discharge to Wauconda Sewage Treatment
Plant for COD removal;
Alternative' 4:
reatment
New Ca
Vertical
Alternative 4.-combines Alternatives I, 2, and 3. These alternatives have been
previously described. The present worth of this alternative is 28.2 million
dollars.
-------
Table 4
A lternat he
Cost Summary (million dollars)
Capital
Cost
1. .New Cap
2. New Cap and Barrier Wall
9.4
17 .7
Annual P res.ent a
o & M Wor.th
0.10 10.4
0.10 18.7
0.83 21.6
3. New Cap, Groundwater
Pumping, and Liquids Treatment 13.7
4. New Cap, Barrier Wall,
Groundwater Pumping, and
Liquids Treatment
22.0
7. Cap Repairs and Fence
1.6
0.65 28.2
0.83 12.2
0.0 0.0
0.05 - 2.1
5. Groundwater Pumping and
Liquid Treatment
6. No Action
4.3
0.0
a. Present worth is estimated over a 30 year period.
. .. ~_..~ -~ ...
-------
-7-
Alternative' 5:
Ground water Pumping and Liquids Treatment
This alternative is the same as Alternative 3 except that the new cai would not
be included. The present worth of this alternative is 12.2 million dollars.
Alternative' 6:
No Action
The no action alternative would leave the site as it is; i.e., no action
would be taken to reduce infiltration or migration of leachate and contaminated
ground water off-site. No action with respect to the leachate discharge to
Mutton Creek is unacceptable because there is a documented release of hazardous
constituents to the creek via leachate streams. While the effect of leachate
discharges to Mutton Creek cannot be fully evaluated at present, the discharge of
leachate at levels in excess of freshwater aquatic life criteria may have an
adverse effect on Mutton Creek and Island Lake in the future. Human exposure to
the leachate is limited to direct contact threat for which there is no standard
or method to assess health effects. Potential contact at the site also results
from exposure to the existing gas vents.
Alternative '7:
Cap Repair and Security Fence
This alternative would eliminate discharge of contaminated leachate to Mutton
Creek and erosion of contaminated soils. The cap repair also eliminates exposure
of landfill materials in settled and eroded areas. Proper sloping and grading
reduces ponding and promotes rain run off. The cap repairs include draining
leachate seeps, filling in settled and eroded areas, regrading the surface. The
fence insures safety to the public and protects the cap repair actions.
This alternative is a preparatory task required for implementation of any of the
above alternatives. This.is not a stand alone alternative, but must be used in
conjunction with a final determination of ground water releases. This alternative
meets the CERCLA goals of minimizing present hazards and protecting pUblic health
and the environment. The present worth of this alternative is 2.1 million dollars.
Summary of alternatives evaluated
Alternatives 2, 3, 4, and 5 include remedial technologies to address ground water
contamination. Since groundwater remedies have been deferred, further evaluation
of alternatives .2, 3, 4, and 5, is not needed. Alternatives 1 and 7 address only
surface discharges.
Alternatives 1 and 7 meet the stated objective of eliminating discharge of
leachate to surface water. The plastic liner in Alternative 1 reduces infiltration
to nearly zero. However, this alternative is costly and may not be consistent
with the final ~emedy. Implementation of Alternative 7 is a necessary component
of any foreseeable remedial activity undertaken to address groundwater contamination.
It represents the least extensive remedial activity consistent with the objective
of eliminating contaminated leachate discharge and is considered basic maintenance
for closed landfills. Alternative 7 is therefore considered a cost effective
interim measure which will be consistent with the final remedy.
-------
-8-
Recommended Alternative
It is recommended that Alternative 7 be implemented as an interim remedial measure.
Alternative 7 includes:
Installing leachate collection drains (ie: ground blanket and/or
buried, perforated pipe drains) in seep areas to stop surface
leachate discharge into Mutton Creek.
o Providing for proper disposal of leachate; either at the Wauconda Sewage
Treatment Plant, or a hazardous waste treatment facility in accordance
with Agency policy.
o
o Regrading settled, depressed and eroded areas on the existing
landfill 50il cover with sufficient slope to promote rain runoff.
This will eliminate ponding and reduce infiltration.
o Revegetating bare and eroded areas to prevent erosion of soils into
Mutton Creek.
o Constructing a fence around the site to prevent human contact with
gas vents and leachate collection system.
Community Relations
There are approximately 12 residents living within a quarter mile of the Wauconda
Sand and Gravel site. Their participation in the RI/FS process has been limited
to attending the RI data review meeting and FS meeting. The village of Wauconda
officials have followed the study, but have not actively participated in, nor
commented on any aspect. This community has not organized in any fashion to
oversee the investigation. In fact, they have relied on the Agency's study
approach and have appreciated periodic project updates. This is evident from
the brief responsiveness summary attached.
Consistency with Other Environmental Laws
.
Since the Agency is deferring selection of a ground water remedy for this site,
no further discussion concerning consistency with other laws is needed. Alternative
1, new cap, has been eliminated from further review since it may not be consistent
with the final remedy. The operable unit, Alternative 7, cap repair, will be
reviewed. Two 'environmental laws are potentially involved under this alternative.
First, under RCRA policies, cap repair will not meet the RCRA closure requirements,
as a stand alone action. Secondly, the Executive Order on Wetlands and Floodplains
is involved due to Mutton Creek. The northern portion of the landfill slopes as
it meets Mutton Creek~ Part of this slope area is within the 100 year flood.
elevation level. However, cap repairs will occur above this level. A review of
these issues are presented below. . . .
Resource Conservation and Recovery Act (RCRA)
Under the proposed National Contingency Plan (February 12, 1985), Section 300.68
and in the Administrator's memorandum entitled IICERCLA Compliance With Other
Environmental Stautues." compliance with other statues for interim response
measures is not necessary. Although Alternative 7 does not comply with RCRA, the
Agency considers it an interim remedy, and a necessary first step prior to imple-
menting any of the other alternatives.
-------
-9-
Flood Plain Assessment
The northern portion of the landfill is bordered by Mutton Creek. T~ere is a
100 year flood elevation level. which on the southern side (borderin~ the
landfill) is estimated at between 775 and 780 feet (mean sea level) according
to tbe survey conducted for this site investigation (Figure 5). The current
creek elevation is at 766.3 feet. The Illinois State Water Survey has been
asked to confirm the Agency's estimate for flood elevation. Their letter of
concurrence is contained in Appendix C.
All cap repair actions will occur above the estimated 100 year flood plain
elevation. In addition. a border (e.g.; rip-rap) will be considered (during
the design phase) for placement adjacent to Mutton Creek for long-term
protection of the cap repair actton against excessive erosion due to storm
events.
Operation and Maintenance
O&M costs are anticipated for 30 years for this operable unit. These costs
are estimated at $50.000 annually. This includes periodic inspecti~n. maintenance
and repair of the cap to insure its integrity. and leachate disposal costs.
The leachate would need to be tested prior to disposal to determine a
suitable disposal location. This surface leachate flow has not been through1y
quantified but is estimated to generate approximately 1500 gallons per month
of waste. Based on the levels of biodegradable organics and metals present in
the seeps. it is likely that BOD. COD. and total suspended solids will be the
major waste characterization parameters. It is recognized that chemical leachate
characteristics will be variable. If. based on waste characterization or Agency
policy. the Wauconda Sewage Treatment Plant can not accept the waste. a local
hazardous waste treatment facility will be used. These disposal costs would
vary between 15 cents and 2 dollars per gallon. For cost estimating purposes.
the high~r figure has been used. .
Schedule (subject to change pending availability of funds upon reauthorization
of CERCLA)
Aprove~ 9perable unit
Amend lAG for USACE selection of AlE
09/30/85
09/30/85
Cooperative Agreement State of Illinois
for oversight. of federal lead design
Corp. selects AlE
12/31/85
12/31/85
Start Design
12/31/85
01/01/86
Amend lAG for USACE Design
Complete Design
Amr.nd lAG for USACE Construction
06/30/86
06/30/86
-------
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-------
-10-
Amend Cooperative Agreement State
of 111inois for Construction
Start Construction
06/30/86
07/01/86
End Construction
10/30/86
Future Actions
Concurrent with the-remedial actions being recommended now, additional
RI/FS work will be required at the Wauconda Sand & Gravel site. The major
objectives are to better define water quality in the upper aquifer and to
better quantify current and potential endangerment to any receptor. The
current data base must be supplemented in order to answer those objectives.
Additional RI/FS work will include: .
1) Determine the depth of 14 residential wells within 1/4 mile north
and east of site in direction of groundwater flow. Also inspect the
well for integrity and potential for acting as a conduit between the
upper and lower aquifers.
2) Determine the limits of the upper aquifer, and confining layer
north and east of the site. This will likely require additional soil
borings or'monitoring wells.
3) Detennine the migration potential of identified compounds. This will
include additional sampling for a statistically significant database.
4) Locate offsite background wells to determine ambient background ground
water quality.
Based on additional data, alternatives for the final remedial actions will be
reevaluated, and additional alternatives reviewed if necessary.
- -- - ... . ..... -.-
-------
. '.,..
A~p~nc.i,). B:
Co:m,unitj RelatIons Kespullsive'1tss ~ummdry
Community Relations Responsiveness Summary
Wauconda Sand and Gravel Landfill
Wauconda. Illinois
Irrtroduction
This community relations responsiveness summary documents citizens' concerns.
and issues addressed to U.S. EPA during the execution of RIfFS activities at
the Wauconda Sand and Gruel site. It also documents. for the pUblic record.
the U.S. Environmental Protection Agency's (USEPA) response to the comments
presented during the public comment period for this operable unit.
Concerns Raised Prior to the Feasibility Study Comment Period
Concern: During the initial remedial investigation. three residential wells
were found to be contaminated. This was brought out in the public meeting
held after the first phase of field investigations (September 27. 1984).
The 12 residents living within one quarter mile of the site were concerned
about the quality of their drinking water. In response to that concern. the
Agency resampled all the homes again. No contaminants were found. and the
residents were notified of these results.
Concern: The Potentially Responsible Parties (PRPs) formed a task group after
RI results were released. They hired a technical consultant to review the
Agency contractor's work. In response to their concerns that the amount of
contamination caused by the landfill was overestimated. two additional phases
of sampling were completed. The Record of Decision presents the results of
these additional investigations. Other comments raised by the PRPs are
11 s ted be low.
Concerns Raised During the Comment Period
Copies of the Feasibility Study were made available to the public on August
12. 1985. A public meeting was held on August 14. 1985. to present the
actions proposed in the operable unit. Approximately 25 people attended the
meeting. Although the attendees had several questions. comments were not
submitted at the meeting. A summary of the questions and answers from the
meeting is attached. The comment period closed on August 30. 1985.
The Agency subsequently received written comments from two parties. One
letter was received from a resident living across the street from the site.
The other comments ~ere submitted by the PRPs. These comments are addressed below.
Comments and ~esponses
1. Tom and Jane Brown
Comment: They were hoping for more definitive actions at the site. but accept
EPA's need for additional data (see attached letter).
Response: The Brown's letter seemed to reflect the views of the community.
They feel that some limited action is a positive step; further. they understand
why additional investigation is necessary before a final remedy can be selected.
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2. Wauconda Task Group / Connestoga-Rovers and Associates (PRPs)
The WTG/CRA submitted a 21 page report which they feel supports their 8
co~nents on the RI/FS activities to date. In this summary, their-comments
are paraphrased to shorten the text, however, a copy of the specific comments
ar.e attached.
Comment 1: "The conditions at the Wauconda landfill are typical of sanitary
landfills throughout the country."
Response: CERClA authorizes the Agency to take appropriate action, inter
alia, where there has been a release of hazardous substances. Accordingly,
the Agency is authorized to respond to the situation at the site. WTG/CRA's
comment, therefore, must be interpreted as a statement that the situation at
the site does not present an unusual or serious situation. Based upon the
data in the RI report and supplemental RI report, the Agency does not agree
with that comment.
Comment 2: "The data collected to date does not support the conclusion that
a hazardous 'contaminant plume' is emanating from the Wauconda site."
Response: The landfill contains a very large volume of waste materials.
Waste types, quantities, and waste burial locations within the landfill are
unknown. The glacial geology and hydrologic conditions at the site are varied'
and unpredictable. Given these conditions, ground water inconsistencies
between widely-spaced monitoring wells in the off-site locations is not
unexpected. Hence, no attempt was made to map the limits of a plume for eac~
compound detected. This does not negate the fact that chemical constituents
are migrating with the ground water flow. low levels of priority pollutants
and other tentatively identified compounds are identified in on-site and off-
site wells. A leachate plume is migrating off-site. This release is vaguely
characterized by low levels of priority pollutants, of which, only a few
exceed the 10-6 cancer risk level. The Agency recognizes that the inorganic
and organic releases from the landfill need further quantification. Thus,
the Agency has postponed all decisions relative to groundwater remedial
actions at the site.
Comment 3: "Based on existing data, landfilled waste appears not to be buried
1 n the upper- aqui fer"
Item 1: Groundwater in the upper aquifer flows through the landfill.
Item 3: . The bottom of the landfill is at 730 ft. AMSL.
Item 4: The volume- of waste (5.4 million yds3) is based on assumed bottom
elevation of 730 ft. AMSL.
Response: These comments are combined since they address the same issue. '
CRA contends that waste materials-are located above elevation 776 feet, and
that a silty clay layer separates the waste materials from the underlying
sand and gravel aquifer.< CRA supports their position with the following:
a) a statement by the landfill owner, b) information from the landfill vents,
c) the presence of mounded leachate, and d) the absence of dewatering records-
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-3-
Data supporting the Agency's position that waste materials are buried within
the shallow aquifer are: a} an ISGS report dated April 13, 1970, which states
that waste materials extend approximately 40 feet into the aquife~, b} the
boring log for monitoring well G307 which indicates that waste materials
extend to elevation 657 feet, or lower. Well G307 was drilled at the northern
e~d of the landfill and may be in the side slope of the original pit rather
than the bottom of the pit, and c) electrical earth resistivity data reported
by D'Appo10nia and Associates in the RI Data Report.
Regarding CRA's landfill vent information, it would be important to know the
following: a) how and when the vents were installed, b) what measures were
taken to log the materials that were encountered in the boreholes used to install
the vents; c) which documents state that the bottom of the vent pipes corresponds
with the bottom of the landfill; and d} whether or not there is any heave
material or debris in the lower portion of the vent pipes.
Regarding the leachate mounding issue, it is not possible to credit CRA's con-
tention absent additional information on the vents, and whether water levels
measured in the vents are representative of leachate levels within the landfill.
Furthermore, the presence or absence of a "leachate mound" within the landfi 11
has no direct bearing on how deep waste materials are buried.
Because of the leachate mound, CRA concludes that the bottom of the landfill
is lined with silty clay. We believe that, based upon known information.
a more plausible explanation for the leachate mound is that the existing soil
cover over the landfill is not impervious and allows infiltration. leachate
could also be perched within the landfill over zones of less pervious waste
materials.
Evidence that there is no silty clay layer beneath the landfill is contained
in a 1974 report by Testing Engineers, Inc. (TEI) entitled "Report of
Investigation, Obenauf Disposal Company, Wauconda landfill." The TEl Report
includes the following statements: .
"The soils beneath the refuse consist primarily of granular materials
which have limited capabilities for retarding the flow of or attenuating
leachate.",
"Some 1ea~h~te is probably entering the gravel aquifer",
"It is recommended that any refuse placed in the future not be allowed to
release detrimental quantities of leachate to the groundwater or surface
water systems. This can probably be accomplished by lining future fill
areas with.c1ay~ such as that found in the northeast corner of the property."
Item 2: Ground water quality which discharges to Mutton Creek is not defined.
Response: Mutton Creek receives contaminants via several pathway;-direct -_.
discharge of leachate, erosion of sediments containing contaminants and
recharge via the groundwater flowing through the site in the northerly direction.
Since contaminants have been identified in the groundwater, it is expected
that the creek will become a receptor. Hydrologically, Mutton Creek is
considered a 'gaining' stream.
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. .,
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Comment 4: "The interpretation of ground water flow direction in the feasibilit)
study is not supported by the data base."
Item 1: Figure 3-5 of the F$ shows a water level of 760.0 for OW404; G302
shows a water level of 72.3; the 773 contour line should be drawn south of
G302; the 400-Series well locations are located inaccurately on Figure 3-5
and all other figures in the FS.
Response: The water level measurement for OW404 should show 76B.0; the water
level measurement for G302 should show 772.3. These typographic errors can
be corrected. The contour line shown as north 0' G302 can be drawn south of
this well. These are not substantive changes which would effect groundwater
flow interpretation.
Item 2: Conductivity measurements (> 1000 mhos) shown in Figure 3-14 are
consistent with groundwater f10wpaths defined by CRA, and inconsistent with
Figure 3-10 of the FS.
Response: Conductivity measurements are not inconsistent with CH2M Hill
ground water flow paths. Conductivity measurements show groundwater flow to
be to the north and northeast. Both CH2M Hill and CRA flow figures show this
general direction.
Item 3: The existence of a 'plug' of impervious material in the northeast
corner of the site is not supported by boring logs for OW406 and OW407.
Response: 80ring OW406 shows clay from the ground surface (elevation 785.2)
to 49.6 feet deep (elevation 735.6). 80ring OW407 shows clay from the ground
surface (elevation 773.0) to 46.5 feet deep (elevation 726.5). Thus there is
no inconsistency between these borings and the FS statement that "s011 borings
confirm that such a plug 1s present above elevation 740 in this area".
. Comment 5: The overall presentation of data in the ground water quality data
base is misleading.
Item 1: Table .3.3 states that dieldrin, 4,4-DDD and endrin were detected in
groundwater samples from wells OW408, OW40~, OW404, OW405 and OW406. These
compounds were not "found.
Response: The pesticides referred to in Table 3-3 were found by CRA as
explained 1n the last paragraph of FS page 3-21. USEPA detection limits were
not low enough to detect the pesticides during phases II and III. CH2M Hill
explained how pesticides were detected in phase I due to lower detection
limits, but not in $ubsequent sampling phases.S1nce CRA had lower detection
limits, the compounds were det~.cted.
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Item 2: Turbid and unfiltered samples are presented for assessment in Table
3-1; sample clarity is not reported.
CRA contends that all monitoring well samples for metals analysis should be
filtered in the field prior to preservation with nitric acid. CRA also cites
two EPA documents (March, 1983, and October, 1983) which support their view.
Response: A more recent USEPA document, "Groundwater Technical Enforcement
Guidance Document", (dr~ft) March 21, 1985, includes the following statement:
MSometimes metals of concern are bound to sediments in the groundwater.
When samples for metals are filtered, these sediments and the bound metals
are removed from the sample. In these instances, the samples are not
representative of the groundwater quality. Therefore, when owner/operators
sample for metals, they must split each of the 4 replicates into two
aliquots. One aliquot must be filtered and analyzed for dissolved metals.
The other aliquot must not be filtered and it must. be analyzed for total
recoverable metals."
RI phases II and III included both filtered and unfiltered data for monitoring
wells so that comparisons could be made between these data and.the clarity of
the water that represents "consumabl e" water qual ity. However, the data are
not sufficient to draw these conclusions.
All data was presented adequately in Table 3-1. Since the release of metals
from the landfill has not been quantified, and ground water investigations
have not been concluded, there is no reason to eliminate data from summary
tables at this time. The FS discusses the manner in which turbid samples can
affect data interpretation on page 3-11. Since ground water issues have been
deferred for further study, it would be premature to eliminate ground water
data from future interpretation at this time.
Item 3: The EPA primary drinking water standard of 50 ug/l should be used as
the acceptable level of arsenic in ground water.
Response: In the July 23, 1985 memo by William N. Hedeman, Jr., Office of
Emergency and Remedial Response, arsenic is still listed as a carcinogen by
ingestion at the 10-6 level of 2.5 ng/1. However, this compound is being
reevaluated for carcinogenicity. The RI supplement discusses the problems
associated with interpretation of arsenic data on page 7-14. The Agency will
defer a final decision on this issue until background concentrations of
arsenic are established. CRA's report also takes exception to listing TCE as
a carcinogen. The. Agency's Cancer Assessment Group defines TCE as a carcinogen
at the 10-6 level of 2.8 ug/l. ..
Item 4: Wells G102, G105, G305A, G306, G307 and G308 do not monitor ground
water quality in the upper aquifer, but monitor water quality within the
silty clay formation above the aquifer.
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Response: There is no data which shows that these wells are located in a
"significantly" less permeable material (referred to by CRA as an aquitard).
Existing data on page A-I8 of the RI supplement Report shows that ~ell G306 .
has a lower permeability than other upper aquifer wells by one orqer of
magnitude. Therefore. the Agency concludes that these wells are in a less
p~rmeable portion of the upper aquifer.
Items 5,6,8: These items refer to two problems; a) less than detection limit
data. b) "representativeness" of the ground water data with respect to Table
3-1 and the associated f1gures.
Response: The figures (3-8 through 3-10) were based on data presented in
Table 3-1. The existing data base is extremely limited and a final groundwater
remedy is being deferred. Any editing of the data (for representativeness)
presupposes an interpretation (without the presence of the additional data
needed to support it), and therefore directs the selection of a final remedy
on the groundwater. The FS adequately presents the limitations of the data
which should be considered when reviewing Table 3-1.
CRA contends that analytical data that are qualified as "estimated values".
"presence indicated, but less than detection limit'l, and 'Idetectable, but
below quantifiable levels" should be excluded from the data base.
Response: The "Groundwater Technical Enforcement Guidance Document" (draft)
March, 21, 1985, includes the following statements regarding pollutants that
are measured at less than (LT) detection limits:
liThe owner/operator must explain and follow the protocol for determining
and reporting low concentration values.'1
lilt is unacceptable to report only
values that were measured below a
must ensure that numerical values
are available for analysis."
qualitative information such as LT for
limit of detection. The enforcement officer
accompany the LT designation so that data
NLT values should not be deleted from the analysis.
should be analyzed at half their reported value."
Elimination of LT values from the data summary table. as was done by CRA in
Table 5 of-their Phase II Report, and Table 4 of their Phase I Report, gives
a false presentation of groundwater quality in the aquifer. To eliminate
this problem, lower detection limits must be reached in the future.
Instead, LT values
Item 7: OW401 should be considered as representing background water quality.
CRA objects to the RI Supplement's dismissal of well OW401 as representative
of "background" water quality. .
- - . -
Response: In the course of the RIfFS, several attempts were made to establish
representative background well locations. However, in viewing the total data base,
it appears that the three wells placed upgradient (but on-site) are still within
. .
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the influence of the landfill. In addition. CRA now states that water in the
landfill is mounding (thus radial flow is likely). Considering these factors.
it is difficult to accept anyon-site upgradient monitoring well as representing
true background water quality. .
I\em 9: Presentation of 'Significant Findings' is misleading since it does
not consider the representativeness of the data.
Response: The 'significant findings' are single statement summaries regarding
all the data to date. These findings put into perspective the types and amounts
of contaminants found; filtered data is distinquished from unfiltered data.
and the number of wells containing the contaminants are listed. Therefore,
the summaries are not misleading.
Item 10: The data assessment makes no attempt to evaluate the impact of the
Wauconda landfill on groundwater quality. Concentrations upgradient and
cross gradie~t are not differentiated.
Response: CRA also states that background levels and other sources of contaminants
were not investigated. CRA points out that mounding within the landfill is
occuring. thus they offer a possible explanation for identifying contaminants
within upgradient and cross gradient wells. Further investigation of the
ground water is recommended such that the actual releases from the landfill
will be distinguished from ambient water quality.
~
Item 11: EPA should note that wells GI04 and G311A are not downgradient of
the landfill and therefore contaminants found in these wells should be considered
as background water quality.
Response: G104 and G311A are not downgradient according to the groundwater
flow paths which have been defined. As pointed out. they may be subject to the
landfill's influence, or the influe~ce of other. not yet defined sources.
Item 12: The FS uses pesticides data generated by CRA for pesticide analysis.
but excludes remaining data.
Response: The RI supplement and FS were intended to present only the Agency's
data. The refere~ce to the pesticide data was made only because CRA had
lower detection limits for pesticides than did EPA. Also see response to
comment 5, item 1, page 4. .
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Item 13: CH2M Hill refers to samples 'split' with CRA, when the word
'duplicate' should be used.
Response: tRA's ~omment is noted, but- is inrnaterial to the decision being
made at this time by the Agency.
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Item 14: Further documentation of surface water contamination was not done
in supplemental investigations. Based on Table 3-2, only nickel is impacting
Mutton Creek.
Response: Supplemental work was conducted to address concerns raised by CRA,
it was not intended that the entire RI should be redone. Table 3-2 is not
c6mplete since it does not list all contaminants detected in surface water samples
which exceed freshwater and aquatic life criteria. This data has been included
in the ROD. Barium, iron, nickel, zinc, and lead are found in concentrations
higher downstream than upstream. Nickel and iron exceed applicable criteria.
Item 15: The FS discusses contamination of Mutton Creek via erosion of
contaminated soils. It also states that levels of inorganics are insignificant,
and that that volatile organic contaminants may have originated from Highway 12.
Response: The Contaminated surface soils referred to in the paragraph cited by
WTG/CRA refers only to sample SS401 in which seven volatile organic compounds
were detected, three of which are also found at low levels in downstream
sed1ment sample SS301. The FS states that inorganic contaminants in sediment
samples cannot be distinguished from ambient concentrations of inorganics in
natural s011s, and therefore are not considered significant. Th~ statement
about the influence of Highway 12 on organics in sediment refers only to
sample SS108, which 1s taken right under the Highway.
Item 16: The landfill caused chromium contamination of Mutton Creek based
on sample WS108 (downstream of landfill).
Response: Chromium was only found in samples WS002 and WSI08. Since WSI08
is located downstream of the landfil" and at the Highway 12 intersection, it's
prese~ce is associated with the highway. Sample WS002, on the other hand, is
the surface water seep at the landfill, hence it's presence is associated with
the landfill.
Item 17: It is unusual that high levels of total dissolved solids do not
correlate with high levels of Specific Conductivity.
Response: The-TDS figure represented data from the phase II sampling effort.
The conductivity data was from phase I1I~ As previously mentioned, the same
wells were not sampled in each phase. In fact, only 3 wells were in common
between the two phases. Therefore, these figures do not correlate well
because of insufficient data.
Item 18: Conductivity from Figures 4-3 and 3-14 are inconsistent.
Response: The limits shown in Figure 4-3 are approximate areas of high
conductivity based on specific conductivity measurements in phase I, and
the geophysical work also completed in phase I. Figure 3-14 shows conductivity
for specific well locations. It also incorporates additional well locations
(400 series) not present in phase I.
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Item 19: The FS states that lake Bredeen (Mud lake) could be imp~cted
by the Wauconda site. This is unlikely because it is 1500 feet upstream
of the landfill.
Response: Mud lake is northeast of the site in the direction of ground water
flow. Mud lake is the upstream source of Mutton Creek. but it is down~radient
of the site based on ground water flow. There is a potential that contaminated
ground water could recharge this lake.
Comment 6: WTG/CRA concur with the conclusion of the FS that the existing data
base does not suport implementation of alternatives '1 through 15.
Item 1: Alternatives 3. 4. and 5 involve ground water pumping and treatment
to address organic compounds in ground water, yet the treatment methods are
not for the organics, but for high iron which is naturally occuring.
Response: The need to pump and treat is based on creation of a hydraulic
barrier around the fill to prevent future contaminant migration. and the
need to withdraw from the groundwater the contaminants already identified.
The treatment process emphasizes metals removal to meet State of 111ino1s
discharge requirements. The biological treatment is needed to remove the
high levels of COD identified at the site.
:
Item 2: Table 1-1 does not define the level of benefit of positive aspects
or the cost of a negative aspect.
Response: Table 1-1 is only an overview of major points which each alternative
must be reviewed against. This review is required by current FS guidance.
Cost/Benefit analysis comes in selecting the most cost effective alternative.
Item 3: The FS states that perimeter wells must be used to measure the
effectiveness of capping on reducing contaminant migration. yet many of the
compounds detected were only slightly above detection. Hence. data obtained
from a performance monitoring program will not likely provide evaluation of
remedial performance.
Response: long term monitoring will always be required regardless of
the chosen alternative. Should the alternative fail, the monitoring of
ground water will detect any problems.
Item 4: A slurry wall is not a technically effective solution unless it can
be keted into the aquiclude. Thi$ is recognized by EPA in-the FS.
Response: The Agency recognizes the shortcommings of this alternative.
It was still important to review if reduction in groundwater flow due to a
slurry wall is cost effective compared to other alternatives.
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Item 5: Figure 4-3 shows a ground water recovery system based on conductivity.
Since conductivity does not represent a public "health concern, the recovery
system should be based on chemical compounds which pose an unaccep.table
risk to human health and/or the environment.
Response: The health risk posed by contaminants in ground water is what
triggers the ground water pump and treat alternatives. They minimize any
future release by creating a hydraulic barrier. Figure 4-3 shows general
well locations around the site perimeter, and off-site in areas where
contaminants are suspected~ This is a generalized figure. The FS further
explains that during the design phase, refinements would be required such
that the figure would be altered.
Item 6: The conventional treatment technologies presented do not address
the organic compounds. They are treated only through conventional treatment
mechani sms. .
Response:
This point has already been covered in item 1 above.
COllJl1ent 7:
hThe FS ignores other potential sources of groundwater contamination.h
CRA states in their report that other sources of contamination may be a) an
abandoned dump southeast of the site, b) cOllJl1ercial operations on the landfill
site property, c) argicultural areas, d) residences (self-contaminated wells).
Response: The scope of the original RI was to determine the releases as a
result of the landfill. However, the Agency will establish suitable background
wells in the subsequent investigation phase.
/
"
COlTlllent 8: hAlternative #7 consists of typical closure measures required of
sanitary landfill operators. Cap repairs are the construction of a security
fence are not justifiable interim response measures if the leachate seeps are
repaired and maintained.h
Response: CERCLA allows the Agency to take any measures which are protective
of public health. welfare and the environment. The actions recommended are
minimal measures which must be taken regardless of the final ground water
remedy. It is a Cbntradiction to say that these measures are required
practices, but then to say that they are not justified. The FS further
describes the justification and benefits of these actions at this time.
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Attachment 1:
Summary of pUblic meeting for Feasibility Study
On August 14, the public meeting was held to review the feasibility s~udy
and recommended interim remedy. No formal comments were made during ~he
meeting. The following questions were answered.
Q: Why not just connect us to the municipal water supply since good
water quality (drinking water) canlt be guaranteed?
A: Since no one is currently drinking contaminated water there is no
justification for extention of municipal water supply. If, in
completing the groundwater investigation, safe drinking water
cannot be insured, the municipal system may be extended.
Q:
A:
What if we don't want municipal water?
Residents will not be forced to hook up if municipal water is
extended; however, individual monitoring of homes will be
discontinued.
Q: How often will homes be tested?
A:
Every 6-8 months while investigation continues. This means at
least twice before the investigation is complete.
Q:
Has the pump station on Barbara Lane been tested?
A: There are several monitoring programs going on within the community.
The water in the pump station is part of the municipal system.
As such it is subject to routine monitoring under drinking water
regulations. The Lake County Public Health Department also has a
drinking water monitoring program for residents in the area on
groundwater.
Is funding available for further work?
Q:
A:
The project may be slowed down due to problems with reauthorizing
the program.
Q: About two years Igo there was an article about a resident having
contam~nated_water in this area, was it due to the landfill?
The resident in question would not allow access for resampling to
confinmany contamination. Since then, the resident has sealed the
well, and constructed a deep well. We will never know if the
problem.was site specific or related to the landfill.
Q: How long before contamination problems develop in the deep aquifer?
A:
A:
. - . .. .
Contaminants are not yet well defined in the upper aquifer. Geologic
relationships between the upper and lower aquifer need additional
investigation in order to completely answer that question.
--. _. -.-....-,.-
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.--.;.
- z..
Q:
Is anyone being sued for this problem?
landfU 1 exi s t?
How can an unpermitted
A:
Solid waste disposal regulations did not exist when this landfill
began operation. The newer portion of the landfill (9 acres~ was
permitted. However, during the cost recovery process, the owner
and generators will be held liable for costs.
.
Q: What is the priority on this site?
A: There isn't a particular order for site investigations. As fundS
become available investigations begin on new sites.
Q: Why do investigations take so long? The beauacratic process is so
frustrating for residents living near the site.
Before taking any action there must sufficient data to justify the
action. The "operable unit" interim remedy is a limited action
which can be taken now. Since the potential costs of remediation
are so high, the additional investigation will be time well spent.
Q: Can the site be fenced before winter?
A:
A:
The Corp of Engineerings is responsible for design. They won't
have a constractor procured by winter. The process of bidding
contracts to insure fair business practices is a slow but necessary
step. The proposed actions will not be visible at the site until
the summer of 1986 at the earliest.
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APPENDIX A
SPECIFIC COMMENTS
.
The following presents specific comments on the FS which are
r~lated to the comments discussed within the text of this report.
THE CONDITIONS AT THE WATJCONDA LANDFILL ARE TYPICAL OF SA...~lTkRY
LANDFILLS THROUGHOUT THE COUNTRY
1.
Page 10-1 - EPA state "The problems at Wauconda are not seve!:'\:!
(i.e. low levels of contaminants in the groundwater and fe~
people affected or threatened by contaminated groundwater)
when compared to other NPL sites". These conditions represe~t
a typical Sanitary landfill.
THE DATA COLLECTED TO DATE DOES NOT SUPPORT THE CONCLUSION THAT A
HAZARDOUS 'CONTAMINANT PLUME' IS EMANATING FROM THE WAUCONDA SITE
1.
Page 1-4 - The second paragraph identifies a "contaminant
plume". This comment should be addressed as per Section 3.2
of the text of this report.
2.
Page 1-8 - "contaminated groundwater plume area" (see Section
3.2 of text).
The above comments are further supported by co:n~e~ts dis~usse=
hereafter.
BASED ON EXISTING DATA, LANDFILLED WASTE APPEARS NOT TO BE BURIED
IN THE UPPER AQUIFER
1.
Page 1-2 - "groundwater in the upper aquifer generally flows
through the landfill" (see text Section 3.3)
Page 1-2 - CH2M-Hi11 contend that contaminated groundwater is
. discharged to Mutton Creek. However, the groundwater quality
which discharges to Mutton Creek is not defined.
2.
3.
Pages 3-1 and 3-11 - CH2M-Hill contend that the bottom of the
landfill is 730 ft. AMSL (See text Section 3.3)~
Pages 1-1 and 3-1 - The volume of waste of 5.4 million C.Y. is
based on an assumed bottom elevation of 730 ft. AMSL a~d is
su_bject to revision (see text Section 3.3).
4.
.. . -.., ~ ~ -. .
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4
- 2 -
THE INTERPRETATION OF GROUNDWATER FLOW DIRECTIOt~ I~ T:~
FEASIBILITY STUDY IS NOT SUFPORTED BY THE DATA BASE -
1-
.
Page 3-10 - Figure 3-5 shows a water level of 760.0 for OW~04.
This should be 768.0 based on Table B-9 of the RI Supplement.
Similarly, well G302 shows a water level of 72.3. This should
be 772.3. The 773 contour should be drawn south of G302. The
400-Series well locations are inaccurately located on
Figure 3-5 and all other figures. The proper location of
these wells will alter the groundwater contours presented.
The date which water levels were taken are not noted on the
figure.
2.
Page 3-22 - CH2M-Hill indicate that "when leachate mixes an~
migrates with groundwater, the direction and extent of
migration can often be investi9~ted by measuring the
conductivity of groundwater". The elevated conductivity
measurements (>1000 mhos) presented on Figure 3-14 are
consistent with groundwater flowpaths defined by CRA in t~e
Phase II Data Assessment Report and are inconsi~tent with the
groundwater flowpaths presented by CH2M-Hill in Figure 3-10 of
the FS.
3.
Page 5-5, 5-6 - The existence of a 'plug' of impervious
material in the northeast corner of the site is not supporte
by the geologic data. Borings locate1 at 406 and 407 indica~
that the Upper Aqui fer is cont inuous through this area an.;!
will permit unrestricted movement of groundwater in a
northerly direction.
THE OVERALL PRESENTATIO~ OF DATA IN THE GROUNDWATER QUALITY OATA
BASE IS MISLEADING
1.
Page 3-9 - Table 3.3 states that dieldrin, 4,4-000 and endrin
were detected in groundwater sampled from wells OW~08, OW403,
OW404, OW40S and OW406. These pesticide compounds were not
found at these wells.
Page 3-11- - CH~~-Hill recognize that turbidity of groundwater
samples can potentially exaggerate contaminant concentrations.
However, turbid, unfiltered samples are used for data
assessment in Table 3-1. Also, the RI Supplement report does
not report the clarity of samples taken.
2.
3.
Page 3-18 - Table 3-1 - The EPA primary drinking water
standard of 50 ug/L should be used as the acceptable level of
a=senic in groundwater.
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,
4
- 3 -
4.
Page 3-13 - Figure 3-6 - Wells GI02, GlOS, G30SA,_G306, G307
and G308 do not monitor Upper Aquifer groundwate~ quality.
These wells monitor groundwater within the silty clay
formation which overlies the Upper Aquifer.
Page 3-17 - Figure 3-10 erroneously includes OW403 ar.~ Gl14 as
having organic contamination above the 10-6 cancer risk
criteria.
5.
6.
Page 3-18 - On Table 3-1 CH2M-Hill have erroneously included
the following compounds which were below criterion. These
are:
(a)
(b)
(c)
Gl14-Vinyl Chloride
G301D-Trich1oroethene
OW403-Vinyl Chloride
Also, eligibility for many of the listed compounds and wells
shown on Table 3-1 is questionable (see Section 3.5 of text). .
7.
Page 3-18 - Table 3-1 should note that well OW401 is
upgradient of the landfill. EPA indicate in the Rl Supplement.
Report that OW401 is not representative of bacKground
groundwater quality. It was originally intended to drill
OW401 south of the landfill site. However, property access
was not available. EPA have failed to note that prior to
drilling well OW401 EPA verbally agreed to the location i~ the
field and agreed that it would be representative of background
water quality.
Page 3-18 - Table 3.1 presents many compounds which are above
cancer risK or health criteria. The table is misleading since
it includes any compound which exceeded a criteria d~ring only
one of the three sampling rounds. If Table 3.1 were to be
rewritten in consideration of the representativeness of t~e
data, more than half of the entries could be eliminated (also
see Section 3.5).
:
8.
9.
Page 3-21 - CH2M-Hill's presentation of 'Significant Findings'
(specifically the last four points on the page) is misleading
since it does not consider the representativeness of the data
(see Section 3.5 of text). .. .
10. Page 3-21 - The CH2M-Hill data assessment makes no attempt to
evaluate the impact of the Wauconda landfill on groundwater
quality. For example, contamination at downgradient wells are
not differentiated from contamination at cross-gradient or
upgradient wells.
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....... ;
. ~
- 4 -
11. Page 3-21 - EPA should note that contamination found at wells
G104 and G3llA are not downgradient from the Wauc~nda Landfill
and are representative of background groundwater'
concentrations. It should be further noted that w~ll G3llA is
potentially downgradient of an abandoned dump site located
south of Bonner Road and east of Garland Road.
12. Page 3-21 - CH2M-Hill use data generated by CRA for pesticide
analysis. o. However, the remaining data generated by CRA has
been selectively excluded.
13. Page 3-21 - CH2~-Hill refer to samples 'split' with CRA.
These samples should'be referred to as 'duplicate' samples
since they were collected independently of CRA sa~ples but at
the same time. '
14. Page 3-27 -CH2M-Hill contend that surface water contamination
is occurring based on Phase 1 data but failed to further
investigate surface water during the supplemental RI. Based
on Table 3-2, the only compound impa~ting Mutton Creek which
could possibly be associated with the la~dfill is Nickel.
15. Page 3-29 - CH2M-Hill contend that contamination of Mutton
Creek could be generated by erosion of contaminated surface
soils. On the same page it is indicated that sediment sa~plE
contain insignificant levels of inorganics. On Page 3-30 it
is concluded that volatile organic contamination of sedi~ents
may have originated from Highway 12.
/
""
16. Page 3-29 - CH2M-Hill contend that the landfill caused
Chromium contamination of Mutton Creek based upon sample
WSI08. This is not supported by samples WSI09 or WS301 or
WSIIO which were collected in Mutton Creek at the landfill ~~d
immediately downstream of the landfill.
17. Page 3-25 - It is unusual that high levels of total dissolved
solid do not correlate with high levels of Specific
Conductivity.
18. Page 4-12 - The area of elevated conductivity (greater than
1,000 umhos) shown on Figure 4-3 is inconsistent with
Figure '3-14.
19. Page 5-16 - CH2M-Hill conten~ that Lake Bredeen could
potentially be impacted by the Wauconda site. This is
unlikely since Lake Bredeen is located 1500 feet upstrea~ of
- the landfill.
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'"
. . ,'~ . ~_.. . .
- 5 -
WTG/CRA CONCUR WITH THE CONCLUSION OF THE FS THAT THE EXIST!~:~
DATA BASE DOES NOT SUPPORT IMPLEMENTATION OF ALTERNATIVES ~l
THROUGH 15 .
l~
Page 1-4 - Alternatives 3, 4 and 5 involve groundwater p~~pi~g
and liquids treatment. The motive to recover and treat
groundwater is to address organic compounds in groundwater.
However, the proposed treatment method does not specifically
address treatment of organic compounds. The treatment syste~
primarily involves removal of iron from groundwater which is
present at high background concentrations and is unrelated to
the landfill site.
2.
Page 1-8 - Table 1-1 does not define the level of be~efit of
positive aspects or the cost of a negative aspect. .
3.
Page 4-6 - In the fourth paragraph EPA indicate that perime~er
groundwater monitoring wells will be used to measure the .
effectiveness of capping on reducing contaminant migration.
In order to evaluate the effectiveness of any r~medial actio~
. a firm baseline must be established of the chemical para~eters
in groundwater. Many of the chemical compounds detected were
only slightly above detection or were below limits of accur~t~
quantification. Hence. data obtained from a performance
monitoring program will most likely be unable to provide a~
evaluation of remedial performance.
4.
Page 4-6 - Alternative 2 which involves a slurry wall is no~ a
technically effective solution unless the slurry wall can be
keyed into the Aquiclude. This is recognized by the EPA on
page 4-10 where the EPA indicate that "contaminants could
escape beneath the proposed slurry cutoff on the northern.
western and eastern ends of the landfill".
s.
Page 4-12 - Figure 4.3 provides a schematic illustratio~ of
the groundwater recovery system. The area of groundwater
recovery proposed is based on an assumed contaminant plu~e
defined on the basis of specific conductance. The groundwa~e~
recovery And treatment alternative should have, as an
objective, the recovery and treatment of chemical compoun=s
which pose an unacceptable risk to human health and/or the
environment. Specific conductance does not represent a publi:
health concern.
6.
and 4-15 - The conventional treatment technologies
do not address organic. compounds. The only
provided occurs indirectly through conventional
mect.anisms.
Page 4-14
presented
treatment
treatment
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Appendix C:
Met~ls calculations for Freshwater and Aquatic
Life Criteria a
1. Cadmium 1980 24 hr. maximum: e(1.05(ln (Hardness»-8.53)
2. Cadmium 1980 Anytime maximum: e(I.OS(ln (Hardness»-3.73)
3. Cadmium 1985 4 day ave.: e(.7852(ln (Hardness»-3.490)
4. Cadmium 1985 one hour ave.: e(1.128(ln Hardness»-3.828)
5. lead 1980 24 hr. maximum: e(2.35(ln (Hardness»-9.48)
6. lead 1980 Anytime maximum: e(I.22(ln (Hardness»-.47)
7. lead 1985 4 day ave.: e(I.266(ln (Hardness»-4.661)
8. lead 1985 one hour ave.: e (1.266(ln (hardness»-1.416)
9. Nickel 1980 24 hr. maximum: e(.76{ln (Hardness»+1.06)
10. Nickel 1980 Anytime maximum: e(.76(ln (Hardness»+4.02)
11. Zinc 1980 Anytime maximum: e(.83{ln (Hardness»+1.95)
12. Silver 1980 Anytime maximum: e(I.72(ln (Hardness»-6.S2)
a.
Hardness. 322.0 mg/l
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c.
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,
4 September 1985
Ms. Cfnd)' No} ;:m
U.S. EPA - Region 5
2::'0 SOlltt-. Dearborn
Chica9~, IL ~060~.
Deio.r ME'o. No1 C'n:
J am returning your topographic map of the landfill site in
Wauconda. The flood-prone areas shown at and near the ~ite on the
Flood Insurance Rate Maps for Wauconda and unincorporated areas of
Lake County are drawn from the Hydrologic InvesliQations ~tla5
HA-207, Floods in Wauconda QU9drangle, Northeastern Illinois,
~llen, 1966. I am enclosinQ copies of the pertinent portion of
that map and of the profile for Mutton Creek printed with the map.
The profile correspond~ to the flood of record on Mutton"Creek
which occurred in April 1960. My best estimate of the flood
elevation along the northern bound.ry of the landfill site ranges
from 767 feet at the northwest corner to 768 feet at the middle
and then to 778 feet at the north~ast corner. Comparison of these
flood elevation$ to the site topography demonstrates that there i=
no flood hazard for the landfill site. If you need additional
inforffiation or a more formal response, please let me know.
Respectfully yours,
#M~
G. Michael Bender
Associate Engineer
Illinois State Water
2204 Griffith Drive
Champaign, IL 61820
Phone: (217)333-0447
Survey
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