United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/ROS-86/041
August 1986
Superfund
Record of Decision:
LaSalle Electrical Utilities, IL
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TECHNICAL REPORT DATA
(PltUt ,tttd /,UlI'UCIIO"S 0" tht 'tvtnt IHfon co,""ltti",)
'. A.'ORT "'0. r. 3. RECII'IENT'S ACCesSION NO.
~PA/ROD/R05-86/041
.. TITLE AND SU8TITLI 5. REPORT DATE
. AIIt1ust
SUPERFUND RECORD OF DECISION 29. 1986
LaSalle Electrical, IL a. peRFORMING ORGANIZATION CODe
7. AuTHOR!SI 8. peRFORMING ORGANIZATION REPORT NO.
I. peRFORMING DRGANIZATION NAME AND ADORESS 10. PROGRAM eLEMENT NO.
". CONTI'IA<;T/GRANrNO.
12. SPONSORING AGeNCY NAME AND AODRESS 13. Type OF REPORT ANO pel'liOO COVEI'IEC
U.S. Environmental Protection Agency 1:';"",1 t:lr.n ~~nnrr
401 M Street, S.w. 1.. SPONSORING AGENCY COOE
washington, D.C. 20460 800/00
15. SUPPLEMINTARY NOTES
1a. A8STRACT
The LaSalle Electrical Utilities (LEU) site is located in west-central LaSalle County
in the city of LaSalle in north-central Illinois. There are approximately 190 people
and 70 residences located within 1/8 mile of the LEU property. LEU, a former
manufacturer of electrical equipment, began operating prior to World War II. Between
the late 1940s and 197~, PCBs were utilized in ~he production of capacitors.
Undocumenced reports allege the application of PCB-contaminated waste oils as a dust
suppressant both on and off the property until as late as 1969. Following the
regulation of PCBs, manifests document the disposal of PCBs at all regulated
facilities. Beginning in September 1975, numerous government agencies conducted various
inspections and issued numerous complaints and orders to the LEU company as a result of
its manufacturing and handling practices. Soil sampling conducted by the Illinois
Environmental Protection Agency (IEPA) in December 1980 documented onsite PCB
contamination. Continued soil sampling revealed offsite contamination in March and ~ay
1981 and the IEPA ordered the company to cease operatior.s in May 1981. The U.S. EPA
conducted immediate removal actions that involved fencing the LEU property and capping a
portion of the heavily contaminated onsite property: capping contaminated offsite
property to the south of the site: and staging, sampling and packaging PCB waste
material for future disposal. Of the total 28,690 cubic yards of soil contaminated
(See Attached Sheet)
17. I(EY WOROS AND OOCUMENT ANAL VSIS
a. OESCRIPTORS b.IOENTIFleI'lS/OpeN eNoeo TeRMS c. COSA TI F lela. Group
Record of Decision
LaSalle Electrical, IL
Contaminated Media: soil
Key contaminants: PCBs
18. OISTRIBUTION STATeMENT 19. secuRITY CLASS I Tlill RtpO"1 21. NO. OF PAGeS
None 39
20. secuRITY CLASS irlrilpag'l 22. Pi'll ce
Mt'\"~
e,. 'or", 2220-1 (Re.. .-.77)
,""."'OU' IC.TICN " O.'OI..I:TI:
-------
EPA/ROD/R05-86/041
LaSalle Electrical, IL
16.
ABSTRACT. (continued)
above 5ppm, approximately 22,240 cubic yards are offsite on the commercial
property immediately to the south and residential property to the east of
the site with approximately 27 affected property owners. The primary
contaminant of concern is PCB.
The selected remedial action for this site includes: excavation of
approximately 25.530 cubic yards of contaminated residential offsite soil
and replacement with clean fill; incineration of contaminated soils with a
mobile. onsite, thermal destruction unit; and conventional industrial.
cleaning'. which would include vacuuminq, hand washinq. steam jet cleaninq.
and.adsorption of all structures where soil removal activities have taken
place. The estimated present worth cost is $26.400,000 with no annual O&M
costs.
p
"
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REMEDIAL ALTERNATIVE SELECTION
SITE
LaSalle Electrical Utilities Site, LaSalle, Illinois
Documents Reviewed
The foil-owing documents which describe the physical characteristics of the
LaSalle Electrical Utilities Site, and which analyze the cost-effectiveness
of various remedial alternatives have been reviewed by U.S. EPA and form
the basis for this Record of Decision (ROD)".
- Draft Remedial Investigation Report, January 15, 1986
- Phased Feasibility Study for Remediation of PCB [polychlorinated
biphenyl] Contamination at the LaSalle Electrical Utilities Site,
August 18, 1986
- Summary of the Remedial Alternative Selection
- Community Relations Responsiveness Summary
Description of Selected Remedy .
The selected remedy consists-of the-following major components:
t
- Excavation of contaminated residential off-site soils
- Incineration of contaminated soils with a mobile, on-site, thermal,
destruction unit
- Industrial cleaning of all structures where excavation occurs
Cost
The estimated cost of the above actions will not exceed a present worth
cost of $26.4 million as itemized in the attached Summary of Remedial
Alternative Selection.
Declarations
Consistent.with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency Plan
(NCP) (40 CFR Part 300 et. seq., 47 Federal Register 31180, July 16, 1982),
I have determined that excavation of contaminated residential (off-site)
soil; incineration of the contaminated soil with a mobile, on-site,
thermal, destruction unit; and industrial cleaning of all structures
where contaminated soil is removed is a cost-effective interim remedy
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-2-
(operable unit) and provides adequate protection of public health, welfare,
and the environment. The State of Illinois has been consulted and concurs
with this remedy. The action will not require future operation and ..i
maintenance activities.
I have also determined that the actions described herein are cost-effective
when compared to other remedial actions reviewed in accordance with the
National Contingency Plan, and are appropriate when balanced against the
availability of Trust Fund monies.
The State of Illinois, through the Illinois Environmental Protection
Agency (IEPA) is continuing its comprehensive Remedial Investigation/Feasibility
Study (RI/FS) for the LaSalle Electrical Utilities property through a
cooperative agreement with the U.S. Environmental Protection Agency. The
IEPA has already completed a preliminary remedial investigation (RI) which
characterized the site, identified significant sources, and preliminarily
identified the major mig~ation pathways. The IEPA is planning to complete
the remaining tasks of the comprehensive RI/FS in 1986-87 in order to
evaluate potential final remedial actions. A Record of Decision wi 1 be
prepared for approval of the future remedial actions.
;:-
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
LASALLE ELECTRICAL UTILITIES
-" i
SITE LOCATION AND DESCRIPTION
The LaSalle Electrical Utilities (LEU) National Priorities List (NPL)
site is located in west-central LaSalle County, at 2427 St. Vincent
Avenue in the city of LaSalle in north-central Illinois (SE 1/4, SW
1/4 of Section"3, T33N, R1E). The. 1980 census data showed the City of
LaSalle to have a population of 10,347 (Figures 1 and 2).
The topography surrounding the LEU site is nearly level with a relief
of approximately 1 foot in 350 feet. Precipitation runoff is to the
southeast of the facility through a drainage channel which flows to
the Little Vermillion River and ultimately to the Illinois River.
Some areas are served by storm sewers which also drain into the same
rivers. These rivers are used for recreational purposes, including
swimming, boating, and fishing within three miles of the site.
The bedrock in the area consists primarily of shale, sandstone,
dolomite, and limestone. The upper bedrock is a highly weathered
shale found at a depth of approximately 20 to 25 feet. Overlying t.he
bedrock is approximately 10 feet of glacial till. Over the till is an
interbedded unit of sand, silt, and clay.
There are four maj or hyd rogeol ogi c aqui fers whi ch occur in thi s area
of Illinois. The Mt. Simon-Elmhurst aquifer, the deepest of the four,
is not utilized in the LaSalle area due to its extreme depth and its high
mineral content. The next aquifer is the Ironton-Galesville which serves
the three public water supply wells in the nearby community of Peru, Illinoi~.
These wells are approximately 2700 feet deep. The shallow dolomite, and the
sand and gravel aquifers in the area service many domestic and public wells.
Approximately 70 residences are located within 1/8 mile of the LEU
property, or, based on the 1980 census data of approximately 2.7
individuals per household in the area, there are about 190 people.
The land use to the north of the property is rural with an
agricultural field separating the facility from a residential
development. Immediately south of the site are several commercial
developments, including a furniture store, a gasoline/fuel oil
distributor, and a restaurant. The principal residential area that is
affected lies directly east of the LEU property across St. Vincent
Avenue.
SITE HISTORV
LEU is a former manufacturer of electrical equipment. Operations at
the plant began prior to World War II, and in the late 1940's the
plant began utilizing polychlorinated biphenyls (PCBs) in the
production of capacitors. This manufacturing practice continued until
October 1978. During the 1970's, the company expanded their
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LASALLE ELECTRICAL UTILITIES I
LASALLE, ILLINOIS
,
FIG.2-
SITE
LOCATION
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-2-
operations and opened another plant in Farmville, North Carolina. In
May 1981, the company ceased operations at the LaSalle plant after it
.was ordered to do so by the Illinois Attorney General and the Illinot~
Environmental Protection Agency (IEPA). The LaSalle facility has .been
abandoned since that time.
Information is limited on the waste management practices of the
company both on and off the property. Undocumented reports allege that
PCB-contaminated waste oils were regularly applied as a dust
suppressant both on and off the .property as late as 1969. Following
the regulation of PCBs, manifests document the disposal of PCBs at all
regul ated fac il i ti es.
Beginning in September 1975, numerous government agencies [including the
United States Environmental Protection Agency (U.S. EPA) U.S. EPA, the
IEPA, and the Occupational Safety and Health Administration (OSHA)]
conducted various inspections and issued numerous complaints and orders
to the LEU company as a result of its manufacturing and handling practices
both past and present. The following is a chronological listing of .
those actions:
* September 1975
Ci ted for inadequate PCB storage
facilities by U.S. EPA.
* October 1979
Violation of PCB management practices
documented by U.S. EPA and OSHA.
U.S. EPA issues TSCA complaint.
* July 1980
* December 1980
IEPA soil sampling reveals extensive
PCB contamination on the LEU property.
IEPA soil sampling reveals PCB contam-
ination on ar~a property other than
LEU's.
* March and May 1981
* May 1981
IEPA orders the LEU company to cease
operations.
* June to September 1981
IEPA conducts additional soil sampling
in the area. .
* May 1982
* August 1982
IEPA files a State complaint.
IEPA amends the State complaint and
also files a Federal complaint under
TSC A.
* August 1982
The U.S. EPA Field Investigation Team
installs monitoring wells at the site.
* December 1982
Based on the information gathered to
date, the site is included on the first
publication of the NPL. .
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.-3-
* July 1983
The U.S. EPA conducts an immediate removal
action at the site, fences the LEU
property, and caps a portion of the. LEU:
property that is heavily contaminated
with PCBs.
* July and October 1983
The U.S. EPA conducts additional sampling
south of the LEU property. Results
indicate heavy contamination on the
property immediately. to the south of
LEU.
* June 1984
The U.S. EPA conducts an immediate removal
action at the site and caps the section
of the property south of the LEU site
which was found to be heavily
contamjnated.
* June 1984 to
July 1985
* April 1985
IEPA conducts additional soil and
ground water sampling in the area.
* December 1985
The U.S. EPA conducts an immediate removal
action at the site. PCB waste material
that had been stored on the site is
staged, sampled, and packaged for
eventual disposal.
Due to the fact that no incinerators.
exist which are in compliance with the
U.S. EPA's off-site policy, the U.S. EPA
cannot yet remove the material that was
staged and sampled in April. As a
result, the IEPA elects to spend state
funds to have the material .removed and
incinerated at a nearby facility.
On September 19, 1983, now operating exclusively in North Carolina,
the LEU petitioned for relief under Chapter 11 of the Bankruptcy.Act
in the U.S. Bankruptcy Court, Wilson, North Carolina. On June 26,
1986, the Bankruptcy Court entered an order approving the company's
planned liquidation under Chapter 11.
CURRENT SITE STATUS
The information gathered in the various investigations and sampling
efforts is..being used as part of the site's remedial investigation
(RI) which is being conducted by the IEPA. That task has not been
completed. A draft copy of the RI report was prepared and submitted
by the IEPA to the U.S. EPA in January 1986. The report thoroughly
evaluated the extent of soil contamination both on and off the site,
but it did not adequately evaluate the extent of ground water
contamination originating from the LEU property.
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-4-
Even though there is not enough information to completely assess the
c9ntamination on the LEU property, enough information was gathered to
sufficiently characterize the nature and extent of the contamination -i
off the LEU property in the residential neighborhood. No ground water
contamination due to the off-site, or residential, soil contamination
was identified.
The contaminants of concern in the LEU off-site area are PCBs. No other
materials above normal background levels have been detected in this area.
PCBs are_a family of compounds containing partially or wholly chlorinated
isomers of the biphenyl molecule. Commercial mixtures generally contained
40~60 percent chlorine with over 200 possible isomers, although only about
10 of these isomers were ever distributed in the U.S. using an aroc10r
designation for identification. The PCB mixtures are thermally stable,
have low solubility in water, low vapor pressure, high boiling point, and a
high dielectric constant. Although relatively insoluble in water, PCBs
adsorb strongly to soil, especially those with high organic content.
The specific PCB aroc10rs found at the site have water solubilities of
54 ug/1 for aroclor 1248 and 12 ug/1 for aroc10r1254. Because of
their high affinity to soil, PCBs are unlikely to leach from the
contaminated soil into the ground water. (This is especially true
when the concentrations of the contaminants are further minimized by
excavation.) The natural affinity of the PCBs to soil also limits the
amount of possible contaminant migration from the site. The only
significan~ migration that is likely to occur would be the result of
tracking and/or blowing of the contaminated soil from one location to
another.
Based on the sampling data, the extent of contamination for the off-
site area was determined. The area of contamination includes the
shoulders of St. Vincent Avenue for about 1000 feet to the north and
approximately 1.2 miles south of the LEU property, the residential
area directly east of the site, the small commercial area to the south
of the property, and one residence north of the LEU property.
Concentrations of PCBs in the composite soil samples from these areas.
range from less than 0.20 parts per million (ppm) to as high as 2600 ppm.
(The lower limit is the analytical detection limit.) Additional grab
samples, from the most heavily contaminated residential yard, revealed a hot
spot containing up to 5800 ppm of PCBs. Concentrations typically average
about 75 to 125 ppm in most yards in the area. The depths of contamination
range from 0 to 12 inches in most areas, to as much as 5 feet at a few
heavily contaminated locations. The total volume of soil that is
contaminated above the 5 ppm level is approximately 28,690 cubic yards.
Of this amount, 6,450 cubic yards are along the shoulders of St. Vincent
Avenue; the remainder is on the nearby residential and commercial property
(Figures 3 and 4). .
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LASALLE ELECTRIC UTILITIES SITE
PHASED FEASIBILITY STUDY
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There are 27 property owners who have contamination in their yards above
the 5 ppm level and who will be directly impacted by the phased remeQ1al
alternative which has been chosen to alleviate the contamination. .
RISKS TO RECEPTORS VIA PATHWAYS
PCBs are considered to have slight acute toxicity, but are resistant
to natural biological degradation. The toxicological properties of
PCBs 'appear to vary widely according to various parameters, but they
have been identified as carcinogenic, mutagenic, and teratogenic in
animals. Human toxicological data is limited, but PCBs have been
found to be able to enter the human body by ingestion, inhalation, and
dermal contact. PCBs bio-accumu1ate in lipids and fatty tissues. The
USEPA has documented that chronic exposure to PCBs in humans can cause
skin lesions (chloracne), liver dysfunction and possible permanent liver
damage, and possibly cancer. Other symptoms of systemic PCB poisoning.
include nausea, vomiting, weight loss, jaundice, headaches, edema, and
abdominal pain.
With regard to the ingestion of contaminated soils, the U.S. EPA used
the Carcinogen Assessment Group for PCBs and calculated that the daily
intake of PCBs should be limited to 2.3 ng/kg-bw/day (nanograms per
kilogram of body weight per day) for 1 in 100,000 (10-5) lifetime
cancer risk. This intake level corresponds to an acceptable soil
concentration of 0.5 to 5.0 ppm. If a 10-6 lifetime risk level is
chosen, the acceptable range of soil contamination would be O.O~ to
0.5 ppm. .
ENFORCEMENT
Present information does not disclose that there are any financially
viable parties from which the U.S. EPA could seek reimbursement of
costs associated with the investigation and removal of contamination
at this site.
The responsible company (LEU) was sold by order of the Bankruptcy
Court on January 20, 1984, to Heede Industries for $800,000. The sale
did not include .the LaSalle plant or property. All proceeds from the
sale went to the Lake Shore National Bank in Chicago who had a valid
security interest in all of LEU's assets in the amount of approximately
$1,908,000. Lake Shore National Bank not only found the purchaser for
the LEU Farmvi11e, North Carolina facility, but they also financed the
purchase by advancing the purchase price of $800,000 in return for two
promissory notes from Heede Industries in the amount of $400,000 each.
Lake Shore National Bank also retained its security interest in the LEU
accounts receivable to the date of sale, and in the LaSalle, Illinois
property. .
The U.S. EPA and the State of Illinois both filed claims in the
bankruptcy action for past and future costs associated with their
removal and remedial actions at the site. There was no money in the
estate, however, to pay these costs. The only assets which could be
applied toward these costs, was the value of the LaSalle, Illinois
property after cleanup. Hence, the amended plan approved by the
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-6-
Bankruptcy Court on June 26, 1986, provides that the LaSalle, Illinois
.property first will be offered to secured lien holders (Lake Shore
National Bank, Realtor Developers, and Equity Research). If the -,'
secured lien holders refuse to accept title, their claims will become
unsecured claims, and LEU will retain title to the property. The
amended order would then give the U.S. EPA.and the State of Illinois
liens on the property for the costs of their cleanup work at the site
(a lien to the U.S. EPA for 90% of the costs, and a lien to the State
of Illinois for 10% of the costs).
ALTERN~TIVES EVALUATION
(1) Contaminated Soil
In response to the health threat posed by the site, a Phased
Feasibility Study (PFS) was initiated to evaluate the contamination
that was found on the residential, or off-site, property. This approach
effectively divided the site into two areas; 1) the highly contaminated and
fenced LEU property, and 2) the areas of lesser contamination in the resi-
dential area and along St. Vincent Avenue north and south of the property.
The two areas were separated so that the contamination that is not presently
controlled and isolated from the public, but which has been sufficiently
characterized and defined, can be addressed while further investigations are
completed on the heavily contaminated source area. The high levels of
contamination on the LEU property and the property directly to the south
warranted the construction of a fence and a temporary cap to secure those
respective areas. Similar isolation of the contaminated soils in the
residential area was not feasible. Although these soils contain far lower
concentrations of PCBs than are on the LEU property, they still present a
significant threat to the health of the people in the neighborhood who are
regularly exposed to theM.
-
Specifically, the objectives of the alternatives evaluation were: 1)
to identify remedial alternatives that would reduce or eliminate the
threat to human health and the environment which is present as a
result of the PCB-contaminated soil in the residential area, and 2) to
identify and evaluate alternatives for cleaning and decontaminating
structures on the PCB-contaminated property. To this end, remedial
alternatives (as defined in the National Contingency Plan (NCP), 40
CFR Part 300.68 and the U.S. EPA Guidance on Feasibility Studies Under
CERCLA) were examined in detail.
Ground water contamination was not addressed in the PFS because the RI
data did not show that the residential area contained contaminated
ground water or that the area was acting as a possible source of
ground water contamination. Even though ground water on the property
directly adjacent to and south of the LEU property was found to be
contaminated, the RI data identified the LEU property as the source of
the contamination. This problem will be further addressed and
examined during the final phase of the RI at the site.
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Technology Screening and Evaluation
Using the response objective of source control to eliminate the di~ect\
contact routes of exposure, potential remedial objectives were
assembled and screened. The following technologies were eliminated in
the early screening process because they did not meet the NCP criteria
of acceptable engineering practices, cost, and/or effectiveness at
addressing and remediating the contamination problems at the site.
1. Capping was not examined in detail because it requires long
term-maintenance and it would be very difficult, if not
impossible, to implement in a residential area. Land use.
restrictions would be required to prevent breaching of the cap;
these would be hard to implement and difficult to enforce.
2. Biological deg~adation of the contaminated soils was not
thoroughly evaluated because this process is still considered
experimental, and the time required for complete degradation
cannot be determined. Also the high chlorine content of the PCBs
at the site makes them more resistant to biodegradation.
3. Ch10ro1ysis (a reactive process utilizing chlorine gas) was
not examined in detail because it has not yet been proven for
. large scale applications such as this one.
4. Ozone oxidation (an oxidation process that utilizes a six-to
eight-fold excess of ozone gas) was not examined in detail because
it has not yet been proven for large scale applications.
5. Ultravtolet radiation was not examined in detail because it
has not yet been proven for large scale applications on
contaminated soils. Most of the experimental work with this -
process has been on oils and waste water. Also, this process
would require that the PCBs be extracted from the soil before they
would be treated.
6. Dechlorination processes were eliminated from the detailed
screening because they have not yet been proven for large scale
applications on contaminated soils. The only process that is
currently available commercially can be used only on oils. This
process.a1so would require that the PCBs be extracted from the
soil before treatment.
7. Multiple hearth incinerators and electric pyrolysis incinerators
were not retained for the detailed evaluation because they are not
commercially available at this time, or they could not effectively
destroy the PCBs. .
8. Three other types of incinerators were also not retained for
in-depth evaluation because they have not yet been used and proven
on a large scale application. These are: 1) high temperature
fluid wall reactor, 2) molten salt incinerator, and 3) plasma arc
torch.
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-8-
9~ Solidification/stabilization/encapsulation was not evaluated
in detail because these types of processes are not proven in large
scale applications to soil, and they often result in a substaRtiai
increase in the weight and volume of material that will need to be
1 and fi 11 ed .
10. In situ stabilization was eliminated from further screening
because it has not been proven, especially for long-term
effectiveness.
11: On-site landfilling was not considered appropriate due to the
residential nature of the area, the lack of a suitable location,
and problems which would be encountered due to the citing
requirements of the Resource Conservation and Recovery Act (RCRA).
Alternative Screening and Evaluation
After the technology screening process was completed, five
alternatives were examined in detail G In conformance with the
the FS guidance specifications, the alternatives were put into
general compliance categories as follows:
NCP and
five
1.
2.
The "no action" alternative.
Alternatives that attain applicable and relevant Federal and
Sate public health or environmental standards,. guidance,
and/ or ad vi so ri es.
3.
Alternatives that exceed applicable and relevant Federal and
State public health or environmental standards, guidance,
and/or advi sories.
4.
Alternatives that meet CERCLA criteria for preventing or
minimizing the threat to human health and the environment, but
which may not attain all relevant or.applicable standards.
5.
. .
Alternatives that treat or dispose of the hazardous substances
at an off-site facility.
With the e~ception of the no action alternative, all the alternatives
would involve soil removal from the residential site area. The soil
removal process would be the same for each of these four alternatives.
It would include the excavation of soil over the appropriate area and
depth in order to achieve the specified cleanup level. The following
are brief descriptions of the five alternatives which were evaluated:
Alternative 1: No Action.
This alternative provides a baseline against which the adequacy of
the other actions can be measured. Under this alternative, the
site would be left in its existing state and no funds would be
expended for monitoring, controlling, or cleaning up the PCB-
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-9-
contaminated soil. As a result, there would be no reduction in.
the contaminant migration from the site, and the potential conta~t
hazards associated with the contamination would not be minimized
or eliminated.
Alternative 2: Off-Site Landfill
This alternative would involve the excavation of the soil and the
shipment of that contaminated material to a UoS.EPA-approved PCB
landfill. This facility would provide long~term containment of
the waste material. Following the removal, the site would be
returned to its original elevation and grade with clean soil,
which would be revegetated or resurfaced as appropriate.
Alternative 3: Off-Site Incineration
In terms of management .of the contaminated soils in the
residential' area, this alternative closely resembles the off-site
landfill alternative. This alternative would excavate the
contaminated material and the replace it with clean fill, but
instead of being stored for an unspecified period of time at a
landfill, the material would be shipped to a U.S.EPA-approved
commercial incineration facility where it would be destroyed. The
residual material could then be used as cover for a sanitary
landfill, or as fill for a nearby construction project.
Alternative 4: On-Site Incineration .
This'alternative also involves the excavation of contaminated'
material from the site and the replacement with clean fill.
However, unlike either of the previous alternatives, the materials.
that would be removed during the excavation would not be
transported off the site over great distances to a disposal or
destruction facility. Instead the materials would be thermally
treated on the LEU property with a mobile incinerator which would
be set up at that location. Provided that analysis of the
residual material proves that it is uncontaminated, it could be
used as cover material at a sanitary landfill or as fill in
roadway and construction projects.
Alternative 5: Temporary On-Site Storage
This alternative involves excavating the contaminated soil,
stockpiling that material on the LEU property, placing a synthetic
liner over the stockpiled soil, and covering the liner with a
layer of clean soil and vegetation. These actions would represent
temporary mechanisms to isolate the contaminants from direct human
and environmental contact. It is assumed that the stockpile would
remain in place only for one to five years until an alternative
could be selected and implemented that would permanently manage
all of the contaminated material on the LEU property.
The detailed screening process used to select the remedy was performed
consistent with the NCP, 40 CFR Part 300.68, U.S.EPA's most recent
guidance concerning the selection of remedial alternatives, and other
Agency guidance as appropriate. The NCP criteria used in the detailed
alternative analysis were:
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-10-
1. Consideration of established technology and, innovative and
. alternative technology where appropriate.
- i
2. Detailed cost estimation, including operation and maintenance
(O&M) costs.
3. Evaluation of engineering implementation, reliability, and
constructability.
4. An assessment of the degree of protection afforded by a given
alternative, including the attainment of relevant federal and
state standards.
5.
An analysis of any adverse environmental impacts.
With the exception. of no action (Alternative 1) and temporary on-site
storage (Alternative 5), all the alternatives would effectively and
permanently minimize the danger to public health and the environment
in the residential site area through the removal of the contaminated
material.
The off-site landfill alternative (Alternative 2) is conventional,
easy to implement, and transfers the operation and maintenance, as
well as the long-term safety responsibilities to the owner/operator of
the landfill. The most significant disadvantage of this option is
.that it does not permanently destroy the contaminants. It also may be
difficult to maintain the long-term integrity of hazardous waste
landfills as required in the U.S. EPA's off-site policy.
The off-site incineration alternative (Alternative 3) offers the
advantage of permanently destroying the contaminants in the soil. It
is a proven technology that transfers operation and maintenance, along
with the safety responsibilities, to the owner/operator of the
incinerator facility. The most significant disadvantage of this
alternative is that implementation would be very difficult and time
consuming. The material must be packaged in small steel or fiber
drums for transportation. The facilities available have commitments
to their regular clients; therefore, only a small fraction of the
monthly operating time could be allocated for destroying the
contaminated material from this site. As a result, material would
have to be stored on the site and regularly transported to the
incineration facility for possibly as long as 10 to 15 years.
As with the off-site incineration alternative, the on-site
incineration alternative (Alternative 4) would utilize a proven
technology to permanently destroy the contaminants in the soil. The
advantages of this alternative are that the transportation and
packaging requirements necessary for off-site landfilling or
incineration of the contaminated material would be avoided, and all
material could be processed in one year or less once the incinerator
begins operation. This alternative also follows the U.S. EPA's Off-Site
Policy of implementing a remedial action which incorporates treatment,
reuse, or recycling rather than land disposal where practical.
. -
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-11-
A disadvantage of the on-site incineration alternative (Alternative 4)
is ~hat anyon-site unit would first have to undergo a trial burn before
it could be certified for operation. This burn is defined by, and - ;
conducted under the supervision of the Toxic Substances Control Act.
(TSCA) staff. Although this would not be an official permit application,
all substantive requirements of the permitting process would have to be
addressed. It is quite possible that this certification process may delay
the actual operational date of the incinerator.
Another disadvantage of this alternative is even though the
contaminated soil would not have to be transported off-site, the
residual "clean" ma"terial which remains after incineration would still
require transportation off-site. Depending on the analytical results
of the residual, the material would have to be disposed of in some
manner. It is likely that it would not have to be sent to an approved
hazardous waste facility, but rather, it could be used for cover
material at a sanitary landfill or as fill material on a con'struction
project. Finally, short-term safety hazards associated with
incinerator operation would also be introduced into the site area.
Although removal of the contaminated soil would minimize immediate
dangers to the public health and the environment in the residential
site area, stockpiling of this material on the LEU property
(Alternative 5) would provide only temporary and moderately effective
isolation of the soil. The technologies associated with on-site
storage are conventional, and the operation and maintenance
requirements would involve only monthly inspections 'to check the fence
and cap. The most significant disadvantages of this technology
are that further management of the wastes would eventually be
required, the stockpile may create some short-term safety hazards,
and this alternative may not be consistent with the final remedy
which is ultimately s~lected for the contaminated ~EU property.
A comparison of the alternatives on the basis of environmental health
reveals that the beneficial impact of all but the no action
alternative (Alternative 1) would be the same, namely, the removal of
the contaminated soils from the residential area. Removal of the soil
would reduce the continued exposure to the area residents and the
environment, and also the possible future migration of contaminants
from the area. There would be no beneficial impacts associated with
the no action alternative.
The detrimental environmental effects associated with the soil removal
operations would essentially be the same for all the alternatives
(Alternatives 2-5). Short-term negative impacts associated with the
excavating,.~oading, and transporting could be minimized by using
proper construction methods such as dust suppressants and traffic
cont ro 1 s.
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Compliance with TSCA and Department of Transportation regulations
'would minimize the likelihood of any accidental release during -.,
transportation to an off-site facility. The detrimental effects'
associated with the facility itself (fire, explosion, release to the
environment, etc.) could be.minimized by observing proper safety
procedures.
The present worth costs, the annual operation and maintenance
requirements, and the implementation times associated with each of
these alternatives are presented in the following tables. These costs
and tmplementation times do not account for the time necessary to
select and sign a contract with a design firm, or the time required to
develop, review, and finalize the design itself. Even though these
are merely estimations of the time required to complete the actual.
site work, they do include contingencies for start-up requirements as
well as down time for general maintenance.
Alternative
Total Present Worth Cost
(Millions of 1986 Dollars)
5 ppm . 10 ppm 25 ppm 50 ppm
0.0 "0.0 0.0 0.0
19.5 13.4 8.6 7.4
176.4 120.5 77.0 66.6
29.6 20.3 13.0 11.2
1.3 1.0 0.8 0.8
1) No Action
2) Off-site
Landfi 11 .
3) Off-site
Incfneration
4) On-site
. Incineration
5) On-site
Storage
-----------------------------------------------------------------------
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-13-
Alternative ~otal Operation & Maintenanc~ _. i
(Thousands of 1986 Dollars)
5 ppm 10 ppm 25 ppm 50 ppm
1) No Action NA NA NA NA
2) Off-site
Landfill NA NA NA NA
3) Off-site
Incineration NA NA NA NA
4) On-site
Incineration NA NA NA NA
5) On-site
Storage 21.6 21.6. 21.6 21.6
----------------------------------------------------------------------
Alternative Tota 1 Implementation Time
(Months)
5 ppm 10 ppm 25 ppm 50 ppm
1) No Action NA NA NA NA
2) Off-site
Landfill 8 7 6 6
3) Off-site
Incineration 168 120 72 60
4) On-site
I nci nerat ion 12 12 6 6
5) On-site
Storage 4-6 4-6 4-6 4-6
----------------------------------------------------------------------
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-14-
As evaluated in. the FS, off-site incineration is the most costly alternative.
Furthermore, the length of time and the number of trucks necessary to haul
the wastes to an off-site incinerator or to a landfill make this alternative
impractical for a large amount of waste. More than 1500 truckloads of wastes
would be hauled away if 26pOOO cubic yards of contamination exist at the
site. Because of the logistical difficulty and cost-disadvantage of the off-
site incineration or disposal alternative, on-site incineration was screened
in more detail. .
The State of Illinois, and the U.S. EPA expressed preference for remedial
actions tnat would provide complete destruction of hazardous wastes in lieu
of transporting the wastes to a different RCRA approved location. The U.S.
EPAls enunciated policy with respect to the use of treatment over land disposal
remedial options (see Memorandum from Jack W. McGraw dated May 6, 1985,
entitled, NProcedures for Planning and Implementing Off-Site Response Actions")
states, "...that, to the greatest extent practicable, consistent with CERCLA
requirements for cost-effective remedial actions, EPA pursue response actions
that use treatment, reuse or recycling over land disposal. II The policy
states further that, N...treatment, reuse; and recycling options should not
be screened out on the basis of cost alone but should be considered if their
cost does not exceed an order of magnitude above the cost of the other
alternatives." In this case, the incineration costs are only 50 percent
greater than the costs for landfilling the material at an off-site RCRA
facility. However, substantially greater protection of human health, welfare,
and the environment would result from the permanent destruction of on-site
contaminants if tbe incineration option recommended in this ROD is implemented.
Section 101(24) of CERCLA states that remedial actions should not include the
off-site transport of hazardous substances, or the storage, treatment,
destruction or secure disposition off-site of such hazardous substances or
contaminated materials unless the President determines that such actions (A) .
are more cost-effective than other remedial actions, (B) will create new
capacity to manage (in compliance with subtitle C of the Solid Waste Disposal
Act) hazardous substances in addition to those located at the affected
facility, or (C) are necessary to protect public health or welfare or the
environment from a present or potential risk which may be created by further
exposure to the continued presence of such substances or materials.
Thus, U.S. EPA emphasizes the need to consider treatment, recycling and reuse
before off-site land disposal of hazardous substances from CERCLA sites is
used. In addition, Section 300.68(h)(1) of the NCP provides that remedial
alternatives should not be eliminated on the basis of cost alone. Therefore,
other longer term benefits should be analyzed when comparing alternatives. .
Environmental benefits which accrue as a result of selecting an incineration
option over-disposal of waste materials in a RCRA Facility are:
1)
at least 99.9999~ removal from the environment, of the PCBs found
in the waste,
2)
3)
a project that would terminate within 2 years after start-up,
elimination of the risk of release of hazardous substances to the
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environment and consequently the complete reduction of the health
risk associated with this exposure, and. ..r
4) elimination of the need for governmental authorities to perform the
environmental monitoring that would be necessary if the wastes were
contained on-site or relocated to another site.
The August 19, 1986 memorandum (entitled: "Utilization of Advanced Technologies
in CERCLA Remedial Actions") from the U.S. EPA Acting Administrator,
J. Winston Porter to Basil G. Constante1os, states that the use of alternative
technologies that treat or destroy hazardous wastes is encouraged. The
memorandum further states that precedent for this policy can be found in the
following documents: 1) the 1984 Hazardous and Solid Waste Amendments, 2) NCP
preamble at 50 FR 47921, and 3) the CERCLA settlement policy at 50 FR 5034.
Finally, a review of the CERCLA.reauthorization bill out of the House/Senate
Conference Committee, indicates that the new law will emphasize a preference
for technologies that treat, reuse, recycle, or otherwise destroy the contam-
inated material. The recommended alternative would be consistent with these
provisions of the reauthorized legislation.
(2) Structural Contamination
After the contaminated soil has been removed and replaced with clean
soil, it will be necessary to clean or decontamin~te the structures
. (ie. ~omes, offices, and businesses) in that area. Tw~ factors
substantiated the need for such cleaning/decontamination: Not only do
previous RI samples document low levels of PCBs in the houses and
commercial buildings (see table below), but excavation activities may
cause additional contaminated particles to be blown or tracked into
the structures.
Location of Structure
(Grid Number)
Interior Sampling Results
Location and Type of Sample PCB Concentration
E/F3 Wipe sample from furnace 0.58 ug/100 cm2
duct.
H/I3 Wipe sample from furnace <0.3 ug/100 cm2
duct.
J/KO Wipe sample from water <0.5 ug/100 cm2
heater.
N1 Sample of vacuum cleaner 13 ppm
dust.
---------------------------------------------------------------------
-
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~16-
All homes or businesses that have excavation work done on their
.properties will be eligible for structural cleaning at the discretion:
of the owner. The number of structures will vary based on the the
soil cleanup level which is chosen. Because of this, the PFS prepared
cost estimates for cleaning/decontamination based on the number of
structures which correspond to each of the soil cleanup levels
evaluated.
Technology Screening and Evaluation
The PFS evaluated various cleaning technologies for the affected
buildings. Based on one or more of the following reasons, many
technologies were eliminated during the screening process:
* Not applicable to media or structural surfaces of
* Not proven for PCB-contaminated structures.
* Creates new disposal problems.
* Not a proven technology or still being developed.
* Not applicable to PCBs.
* Long-term effectiveness is unknown.
concern.
Alternative Screening and Evaluation
The technologies that were retained after the screening are vacuuming,
hand washing, steam cleaning, absorption, and partial dismantling.
These technologies were then combined to. form three c1eaning/ .
decontamination alternatives. The no action alternative was retained
to supply a comparison baseline. The remaining two alternatives
consist of conventional industrial cleaning and specialized cleaning
with replacement of some household items. With one exception, these
two alternatives involve the same technologies. However, additional
personnel safety equipment will be required for the specialized
cleaning with replacement alternative. The following are brief
descriptions of the technologies which were evaluated:
Alternative A: No Action
Under the no action alternative, the structures would be left as
they are, with no funds expended for cleaning/decontaminating or
sampling of the buildings in the contaminated area. Cleaning of
the structures would be left to the owners or residents. This
alternative presents a baseline against which the adequacy of the
other actions can be measured.
Alternative B: Conventional Industrial Cleaning
This ~lternative would include vacuuming, hand washing, steam jet
cleaning, and adsorption. This alternative would address all
structures (basements and garages included) where soil removal
activities would have taken place. The entire building, including
the heating/air conditioning ducts, would be vacuumed.
Afterwards, floors and walls would be hand scrubbed and wiped with
adsorbent cloths. Other hard surfaces, such as counter tops,
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table tops, ceilings, and vertical surfaces of cabinets would be
, wiped with a damp cloth. Wood floors would be waxed after they
are cleaned, and any surfaces that are damaged by the cleaning
processes would be refinished or replaced. Carpeting and
upholstery would be steam cleaned, while drapes and bedspreads
would be dry cleaned under controlled conditions. The exterior
walls and the gutters of the structures wQuld be washed by hand.
After all affected buildings are cleaned, samples will be
collected from a representative number of locations to ensure that
the cleaning process was successfully completed.
Alternative C: S ecialized Cleanin With Re lacement
This a ternat1ve wou d lnvo ve proce ures t at are 1 entlcal to
the conventional industrial cleaning alternative, with two
exceptions: 1) workers in this alternative would wear Level C
personnel safety protective equipment due to the elevated levels
of contaminants, while workers in the preceding alternative would
, work in Level 0, and 2) all fabric and adsorptive materials such
as carpeting, couches, chairs, drapes, and bedspreads would be
replaced rather than steam or dry cleaned.
_. :
The same detailed screening process which was used to evaluate soil
contamination alternatives was used to evaluate the structural
contamination alternatives.
Cleaning the houses would protect the inhabitants from possible
adverse health effects associated with direct PCB contact. The
detrimental effects of these procedures are those associated with
disposal of the contaminated filters and cleaning materials used.
These items would be considered contaminated, and as such, their
handling and disposal would require special precautions. The method
of disposal selected for these cleaning materials would be consistent
with management of the contaminated soil.
In order to minimize exposure to the occupants of the house, as well
, as to simplify excavation and cleaning activities, all affected
residents would be given the opportunity to stay in a nearby
hotel/motel while the cleanup activities were being conducted on their
property.
The detailed present worth costs associated with all cleaning/
decontamination alternatives are presented in the following table.
Because this would be a one time activity,'there are no operation and
maintenance costs associated with the cleaning/decontamination
procedures. The time required to implement this task is approximately
3 to 7 days 'per home for either of the cleaning alternatives.
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-18-
Alternative
Total Present Worth Costs
(Thousands of 1986 Dollars)
_. ;,
A) No Action
B) Convent i ona 1
Industrial
Cle-aning
C) Spechlized
Cleaning With
Replacement
5 ppm
000
10 ppm
0.0
25 ppm
0.0
50 ppm
0.0
78.4
64.3
53.0
43.4
883.6
747.5
605.5
500.8
----------------------------------------------------------------------
Due to the fact that the structural contamination was primarily caused by
fugitive dust and other tracking from contaminated areas, the levels found
indoors were relatively low. Of the three wipe samples collected, only one
was above the selected cleanup level of 0.5 ug/100 cm2. For these reasons it
would not be cost-effective to select the specialized cleaning with replacement
alternative (Alternative C). However, because PCB contamination was found
indoors, and because the excavation activities will cause a significant
increase in dust migration into the structures, cleaning is necessary and the
no action alternative (AUernative A) would not"e"ffectively protect the health
and welfare of the residents at risk. ' "
- ~
RECOMMENDED ALTERNATIVE
The National Oil and Hazardous Substances Contingency Plan (NCP) [40
CFR Part 300.68(j)] states that the appropriate extent of remedy shall
be determined by the lead agency's selection of the remedial measure
that is determined to be cost-effective and that effectively mitigates
and-minimizes damage to the the public health, welfare, and" the
environment. Based on the evaluations conducted during the PFS, the
comments received from the public, and the State and Federal
environmental requirements, the recommended alternative for this site
was chosen. The alternative which was determined to most effectively
remedy the contamination problem at this site, consists of on-site
incineration (Alternative 4) with subsequent, industrial cleaning of
the affected buildings (Alternative B).
Both of these alternatives are consistent with, would not interfere with,
and would.not adversely effect any final remedy selected for the contaminated
LEU property.
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The selection of an appropriate cleanup level was complicated for this
'site because of the cleanup alternative which was chosen; namely -.r
excavation of the contaminated soil. Once the contaminated soil is
excavated to the chosen level. the area would be filled with clean,
uncontaminated material. So in essence. the chosen cleanup level
would not only result in the removal of all contaminated material
above that level. but it would also result in the placement of clean
fill over the remaining minimally contaminated material. This clean
fill would further reduce the potential risk to the health of the
reside~ts in the area.
Currently, there are no set cleanup standards for PCBs in soils.
However, there are two policies in draft form which address this
issue. These are as follows:
1} The Draft National TSCA cleanup policy for PCB Spills
recommends 10 ppm in high contact soils such as those in
residential areas. That same policy document specifies that low
contact soils which are normally found in isolated areas may
contain PCB concentrations up to 500 ppm.
2} The U.S.EPA Office of Research and Development's advisory
levels for PCB cleanups at Superfund sites are based on a May 1986
study by the Office of Health and Environmental Assessment (OHEA).
The OHEA study concludes that for some spill scenarios. for a 1 to
10 day 4ngestion and inhalation exposure to the contaminated
soils. the PCB concentration may need to be limited to about 1 to
2 ppm tQ protect against non-carcino~enic effects. For lifetime
carcinogenic risks not exceeding 10- . exposure to the same
material may need to be limited to 0.8 to 2.0 ppm. The OHEA
assessment also notes that with about 10 inches (25 cm) of cover,
these levels could be increased about 2 to 10 fold.
In order to meet the requirements of the developing cleanup policies,
the LaSalle operable unit should utilize a 5 -ppm soil cleanup level.
However. in order to meet the intent of those requirements, and due to
the nature of the composite sampling methods which were used during
the field investigation, a minimum of 3 inches of soil must always be
excavated when the 5 ppm contamination level is exceeded in the
surface soils.
In areas where contamination greater than 10 ppm still exists after
the excavation of 12 inches of soil. the excavation should be
continued until a 10 ppm level in the soil is attained. This
approach..which is based on the developing policies and advisory
levels, will 1imi~ the amount of deep excavation required, while it
will ensure that that the entire area has a minimum of 12 inches of
clean fill material above soil that is contaminated by 10 ppm or less
PCBs. As a result of this approach. there will typically be 12 inches
of clean fill over soil contaminated by about 5 ppm PCBs.
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.Only those residential yards that have soil contamination levels above
the chosen cleanup level would be excavated and filled with clean. -.
material 0 As a result~ a number of homes in the area would be left
with contamination in the soil which is neither removed or covered
with clean fill. The levels in the soil of these homes would be below
the excavation level~ but above the 1 ppm level. The risks to these
residents would be greater than to the residents who would, have had
excavation and fill work done in their yards.
In those few instances where no excavation work is done on the
property, the PCB levels in the top three inches of soil (surface
soil) would typically be in the 1 to 3 ppm range. The risks to these
property owners would be greater than the risks where the excavation
has occurred, but it will not be significantly higher than the level
associated with the OHEA recommended contamination level of 0.8 ppm.
The actual excavation depths for the project would be determined
during the design phase by the selected Architect/Engineering firm.
The design depths would be determined on a house-by-house or grid-by-
grid basis. In order to ensure that the selected cleanup levels are
met, the excavation plans will be approved by the U.S.EPA prior to
work being performed at the site.
On the issue of decontamination of high contact surfaces within the
affected homes, the most recent draft TSCA PCB spill policy has
proposed a decontamination target of 0.5 ug/100 cm2. High contact
areas in homes or commercial areas are defined as floors, 'doors, walls
below six feet, and vertical surfaces of cabinets and counters. The
same policy has targeted a cleanup level of 10 ug/100 cm2 for other
surfaces having infrequent contact, such as the exteriors of the
buildings. These will be the cleanup levels that will be used for the
cleaning/decontamination of the affected buildings.
The costs associated with the recommended alternatives were evaluated
during the Final editing of the PFS. Previous versions of that study
only evaluated discrete cleanup levels and not a composite cleanup
level which was finally selected. The actual costs associated with
this cleanup level are approximately 10 percent less for all
alternatives evaluated. This can easily be seen by comparing these
costs to the costs as previously presented. Likewise the total soil
removed will also be reduced by approximately 10 percent when the
recommended cleanup level is evaluated. Instead of having 'to excavate and
incinerate 28,690 cubic yards of material to achieve a totalS ppm cleanup,
only 25,530 cubic yards will have to be handled with the selected cleanup
level. .
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.;.21-
Alternative Total Present Worth Cost
(Millions of 1986 Dollars) _. "
5/10 ppm * 5 ppm 10 ppm 25 ppm 50 ppm
~ Off-site
Landfill 17.5 19.5 13.4 8.6 7.4
Off-site
I nci nerat i on 157.1 176.4 120.5 77.0 66.6
On-site
I nci nerat i on 26.4 29.6 20.3 13.0 11.2
On-site
Storage 1.2 1.3 1.0 0.8 0.8
No Action 0.0 0.0 0.0 0.0 0.0
* Note: 5/10 ppm is the recommended cleanup level of 5 ppm up to 12
inches, and 10 ppm at depths greater than 12 inches.
---------------~--------------------------------------------~----------
Section 104(c)(3) of CERCLA sets forth the State fi~ancia1
responsibilities in remedial actions provided under CERCLA. The State
of Il1inois'financia1 responsibilities in the proposed remedial
action would include payment, or assurance of payment, of 10% of the
costs of the remedial action.
OPERATION and MAINTENANCE
The recommended alternative involves no operation and maintenance in
the residential area where the soil removal and building cleaning
would be conducted. Once these activities are completed, no further
work would be required. However, there would be some maintenance and
operating costs associated with the start-up (including the trial
burn) and operation of the mobile incinerator on the LEU property to
destroy the contamination in the excavated soils. These costs would
be limited to the period of time when the incinerator would be
operating, which has been estimated to be only one year, and are
included in the present worth cost estimate.
COMMUNITY RELATIONS
The Superfund activities at the LaSalle site have been followed
closely and consistently by the local press. Interest in the
activities at the site has been high because the residential area is
directly affected. Local and state elected officials; as well as the
local news media representatives, have maintained a constant and
serious interest in both the activities at the site and the future
work plans for the area.
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.During the first week of June 1986, all the residents in the area that
could potentially be affected by the selected alternative were -.i
interviewed by representatives of the IEPA and the U.S.EPA. The
purpose of the interviews was to gather information from the residents
concerning their feelings and concerns about the proposed work in
their neighborhood and, in most cases, their homes. At the same time
all of the residents were brought up-to-date on the status of the site
and the alternatives that were being considered during the PFS.
On June 30, 1986, draft copies of the PFS report were made available
to the residents and any other interested parties for their review and
comment. A press release by the IEPA announced the availability of
the report, the locations in the community where it was available for
viewing, the dates of the official public comment period (June 30 -
July 30, 1986), and the July 17, 1986 public hearing.
During the week of July 7, 1986, the IEPA again visited with residents
and local officials from the area to discuss the results of the PFS
and the alternative that was being recommended for implementation.
These small informal talks were held with two to eight people at a
time, 50 that the residents and officials could discuss the project
and their concerns in detail.
On July 17, 198~, a public hearing was held at the nearby Howard
Johnson Motor Lodge conference room. The meeting. was attended by some
of the area residents, a few members of the local media, and some
state and local elected officials. The.IEPA presented the results of
the PFS; recommended the removal of the contaminated soils and the use
of an on-site, mobile incinerator to destroy the contamination in
those soils; answered questions; and accepted public comments.
The residents' major concern was that the project should begin soon,
and that it should be completed once it is started. Some people were
concerned that the yard excavation would begin, and then be left
unfinished if funding ran out. The IEPA assured the residents that
the work would not begin until sufficient funds were available to
complete it. A few of the residents questioned the safety of the
ground water, and how these actions would affect its quality. The
IEPA informed the residents that ground water contamination in this
project area was currently not a problem, and that they (IEPA) would
thoroughly determine the exact extent of this problem during the
remainder of the remedial investigation. The City of LaSalle'
expressed its support for the recommended alternative.
.~
The Responsiveness Summary to the formal public comments which were
received during the public comment period is attached to this summary
(Attachment 1). I
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CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
" .
All the alternatives examined in detail were designed to be fully
compliant with applicable environmental laws. The Toxic Substances
Control Act (TSCA) entered most prominently into the analysis. These
regulations require that PCB contaminated soil in concentrations
greater than 50 ppm must be taken to a TSCA regulated disposal
facility (landfill or incinerator). Therefore, all off-site facilities
would require compliance with TSCA. TSCA also requires that incineration
of PCB waste must be able to meet a destruction removal efficiency of at
least 99.~999 percent.
The emi ssion. control requirements of the Clean Air Act may be applicable tq
emissions from the incinerator depending on the magnitude of the emissions.
Parameters of concern are sulphuric oxides (SOx), nitric oxides (NOx) gases
and particulates. Costs for air pollution control equipment have been
included in the total cost for the recommended remedial action.
- .
The CERCLA Off-Site Policy as published in the Federal Register on
November 5, 1985, prohibits the use of any facility that has
significant Resource Conservation and Recovery Act (RCRA) or TSCA
violations, or other environmental conditions that effect the
satisfactory operation of the facility. Therefore, all off-site
facilities would have to be in confonmance with this policy.
The recommended alternati~e for this site meets the cleanup "criteria
set "by the State of Illinois, and would fully comply with all
applicable federal standards.
SCHEDULE*
.
The following schedule of activities for the recommended alternative has been
supplied by the IEPA, the lead agency for the site.
" Approval of"Remedia1 Action (ROD)
Design Award (notice to proceed iss~ed)
08/29/86
09/26/86
Design Completion
12/19/86
03/13/87
Award Contract For Construction
Begin Cleanup Work
Complete Cleanup Work
(Excavation and Building Cleaning)
05/13/87
08/01/87
Complete Cleanup Work
(Incineration of Excavated Soils)
05/16/88
* This schedule will be effective only if funds are available for this
site. If new funding is not available, a new schedule will have to
be developed.
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-24-
FUTURE ACTIONS
_. "
A work plan detailing the additional RI work necessary will be
developed and implemented by mid-September. This work will address
the ground water contamination problem which is the result of the
severe soil contamination problem on the LEU property. A Feasibility
Study of alternatives to remedy those problems will be developed, and
then one alternative will be chosen and implemented. The recommended
alternative for dealing with the LEU source area should be chosen by
approx1mately September 1987.
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ATTACHMENT 1
_. ,"
z.
Community Relations Responsiveness Summary
Electrical Utilities Company
LaSalle, Illinois
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@
Illinois Environmental Protection Agency. .
2200 Churchiil. Road. Springfield. (L 6:2706
August 1986
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
ELECTRICAL UTILITIES COMPANY
LASALLE, ILLINOIS
_. "
The Illinois Environmental Protection Agency (IEPA) conducted the
community relations program at this site. Community relations activities
continued throughout the remedial investigation and feasibility study.
During the phased feasibility study, a three week public comment period
(July 8 -- July 29) was established to receive public comment about remedies
for managing cQntamination found in residential areas. A public hearing was
held on July 17 to discuss these remedies. This responsiveness summary
documents citizen concerns expressed during the comment period and IEPA's
response to those concerns.
Another public hearfng and public cOOlllfmt period w'fll be held to discuss
remedies' for managing contamination found 0" the Electrical Utilities
property. The additional hearing and comment period will be held after the
feasibility study for the EUC property is complete. A separate responsivepess
summary will be prepared and distributed following that comment period.
Introduction
Polychlorinated biphenyls (PCBs), used in the manufacture of electric
capacitors, are present in the soil of a portion of the residential area east
of the EUC plant, in the coomercial property south of the plant, and in a
small portion of the farm field to the north.
son north and south along St. Vi ncents Road.
In addition, PCBs are in the
1
.".
~. . "., .
.. ..... ."':.."
t., I
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@
Illinois Environmental Protection Agency
. 2200 Churchill Road. Springfield. lL 6~i06
Five remedies are proposed for managing this PCB contaminated soil:
- .
landfill; on-site incineration; off-site incineration (outside LaSalle
County); temporary storage; and no-action.
"
Community sentiment is virtually unanimous in support of the remedy
preferred by IEPA--mobile incineration. A question expressed by several in
the community, including city officials, regards the level of noise that will
be generated when the incinerator is in operation.
Residents are not opposed
to off-site incineration, but are skeptical that USEPA would approve this
reme~ because of the high cost.
Two of the other remedies, landfill and "no action," received no support
.and would not be accepted by the community judging from verbal comments from
residents during the remedial investigation and feasibility study.
Temporary storage was not supported by the community.
However, thi s
remedy might be acceptable if stora~e did not exceed six months.
Primary
community concerns are for residential property values and for attracting a
new business to the EUC site.
Landfill and "no-action" conflict with these
community concerns.
Community Involvement
Community relations commenced with a joint presentation by IEPA and USEPA
officials at a City Council meeting in January, 1984. Through personal
interviews, "living-room meetings, II and public meetings, the following issues
were identified as concerns of the citizens during the remedial investigation.
2
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~
Illinois Environmental Protection Agency'
2200 Churchill Road. Springfield. I L 6~706
Effect on business--Several small businesses are located in the immediate
vicinity of the EUC site.
Business owners are concerned about how p~esent and
potential customers are reacting to the news that PCB contamination exists in
the area.
One businessman has been refused liability insurance.
Insurance companies
are citing PCB contamination and underground storage tanks as the reason.
Property values - According to residents, residential property values have
diminished in one area near the EUC site.
Residents feel that once cleanup at
the EUC site is canpleted, property values will increase.
Remova 1 of
approximately 260 fifty-five gallon drums containing PCB and drainage of a
tank containing trichloroethylene in February, 1986, did not affect property
values according to residents.
Health effects--PCB contamination in residential yards raised questions
about potential health effects to'both present and future generations.
Officials from the Illinois Department of Public Health and the IEPA went
door-to-doorwhen PCB levels were identified to discuss the impact of the PCBs
in residential yards.
During the public comment period, a public hearing was held to discuss
each of the proposed remedies. The hearing was held on July 17, at the Howard
Johnson Motor Lodge, Route 80 & 51, in LaSalle beginning at 7:00 p.m. A
written statement was presented from the City of LaSalle. Approximately 15 of
the 35 in attendance asked questions. Beginning two weeks before this
hearing, six small group meetings were held with residents, elected officials,
.
and the news media to discuss specific questions about.the proposed remedies.
3
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~ l1Iinai. Environmental Protoctlon A~ency
Summary of Comments and IEPA Response
2200 Churchill Road. SprIngfield. IL 62'7Ub
- i
Issue:
Superfund Program
(,
QUESTION: Are the residential yards considered part of the EUC site listed
on the National Priority List?
RESPONSE: Yes
QUESTION:
RESPONSE:
QUESTION:
RESPONSE:
Who pays for the remedies implemented as part of the EUC cleanup?
The federal government will provide 9~ of the cost through the
Superfund program and the State of Illinois will pay the
remaining lOS. There will be no charge to homeowners and
residents of LaSalle. The Electrical Utilities Company has
filed bankruptcy, and no further assets exist.
Property values have decreased as much as 30' at some residences
near the EUC site. Does the Superfund program provide relief
for those who are trying to sell their property before the
cleanup is completed?
A home buyout, similar to the one in Times Beach. Missouri. is
not likely. Furthermore, there is no language in the federal
law that provides reimbursement for declining property values.
QUESTION: Once. yard excavation begins would the project stop?
RESPONSE: No, When USEPA approves a remedy, it will allocate sufficient
funds before the project begins to complete it.
QUESTION:
RESPONSE:
When wi 11 Superfund money be avai 1 abl e for the EUC project?
Superfund is presently depleted. Superfund must be reauthorized
by Congress before federal money would be available for the EUC
site.
Is sue:
Soil Contamination
QUESTION:
RESPONSE:
QUESTION:
RESPONSE:
Is yard excavation mandatory?
No. Each homeowner who has significant concentrations of PCB
will be offered yard excavation and internal housecleaning as an
option. IEPA encourages all affected homeowners to take
advantage of this offer.
What is the smallest concentration of PCB that will be removed
from residential yards?
The IEPA and USEPA considered four different concentrations.
Each concentration is measured in parts per million. These
concentrations are 50. 25. 10 and 5 ppm. PCB concentrations
that equal or exceed 5 ppm will be excavated.
4
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~
Illinois Environmental Protection Agency
2200 Churchill Road. Springfield, IL 6~706
How many ton s of contami nated so i 1 wi 11 be removed from
res; dent; al yards? - I'
Approximtely 29,000 cubic yards (equivalent to 36,000 tons) will
be excavated. -
QUESTION: Do any homes south of 23rd Street have excessive concentrations
of PCB.
RESPONSE: No.
QUESTION:
RESPONSE:
QtfESTI ON:
RESPONSE:
QUESTION:
RESPONSE:
How did PCB .contamination reach residential yards?
PCBs were probably transported on the bottom of shoes worn by
EUC employees and on tires of vehicles leaving the EUC
property. Some PCBs were carried by the winds from the EUC
parking lot. However, wind deposition alone does not account
for the concentrations found in residential yards. The IEPA ;s
not sure how all the PCBs reached residential yards. If oil was
sprayed on roads, this m~ ~e contributed to the problem.
To what depths were residential yards sampled to determine the
extent of contamination? .
Five feet, but virtually all measurable concentrations of PCBs
were found in the top 10 inches of soil.
How were residents first notified about the resul ts of PCB
sampling in yards?
Officials from the I11ino;s Department of Public Health and the
IEPA went door-te-door in Marchi 1985, to inform residents about
the results of PCB sampling.
Internal House Cleaning
QUESTION:
RESPONSE:
Issue:
How many homes are eligible for the internal house cleaning
option?
Approximately 20 homes. All homes that have soils excavated
will be eligible for the cleaning.
QUESTION: If homeowners of each eligible home request internal house
cleaning, what would be the total cost?
RESPONSE: The combined cost for all of the homes would be about $80,000.
QUESTION:
RESPONSE:
QUESTION: How did PCBs get into homes?
RESPONSE: Most likely from blowing dust and on the bottom of shoes.
Issue:
Remedies
QUESTION: What will happen to dirt from residential yards if it is
; nci nerated?
5
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@
Illinois Environmental Protection Agency
2200 Churchill Road. Springfield. I L 62i06
RESPONSE:
If contaminated dirt is incinerated, the ash would probably be
used as clean fill for a construction project. It.may :also be
suitable for landfill cover. The dirt would not be used in the
yards from where it is excavated. After incineration, the dirt
would not contain sufficient quantities of nutrients needed to
grow grass or crops. The incinerated dirt would be thoroughly
analyzed to ensure that it no longer contains contamination.
QUESTION: Would contaminated soil be 1andfi11ed in LaSalle County?
RESPONSE: No.
~
If a mobile incinerator is approved by USEPA, would the State of
Illinois own the incinerator?
No. The State would .contract this service through competitive
bidding from firms experienced in the use of mobile incinerators.
QUESTION: What is the burn rate of mobile incinerators?
RESPONSE: Five tons per hour, but this rate can vary depending on the size
of the incinerator.
QUESTION:
RESPONSE:
QUESTION:
RESPONSE:
How long are the mobile incinerators?
The primary chamber is approximnate1y 25 to 30 feet in
and the secondary chamber, which does not rotate, is
approxi~ately 30 to 40 feet in length.
length
Q~STION: Where is the c10s~st stationary incinerator capable of safely
burni ng PCB? . .
RESPONSE: The SCA Incinerator in Calumet City, Illinois.
QUESTION:
RESPONSE:
QUESTION:
RESPONSE:
What is emitted from an incinerator when PCB material is burned?
An ai r p11J11e contai ni ng carbon and water vapor wi 11 be vi si b-1 e
from the surrounding neighborhood. PCB concentrations in this
air plume will be less than .0001 parts per million.
How will air emissions be monitored?
Air emissions will be monitored automatically while the
incinerator is in operation by equipment designed to analyze the
contents of the air plume before it reaches the atmosphere. In
addition, a person trained in reading air emissions and
operating air monitoring equipment will be on-site to make sure
that the air monitoring equipment is functioning properly.
Issue:
Groundwater
QUESTION: Has contamination been found in the groundwater?
RESPgNSE: Yes. Trichloroethylene, an industrial degreaser, ~as been found
in groundwater under and near the site.
6
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~
Illinois Environmental Prot~ction Agency' 2200 Churchill Road. Springfield. IL 6~706
QUESTION:
RESPONSE:
QUESTION:
RESPONSE:
How did trichloroethylene (TCE) get into the groundwater?
TCE was either spilled or dumped onto the ground when the EUC
site was in operation. A tank on the EUC property' contained TCE
which was drained and hauled off-site in February, 1986, to
prevent additional quantities of TCE from reaching groundwater.
Is our drinking water safe?
Yeso Virtually all the residents in the vicinity of the EUC
site have hook-ups to the LaSalle public water supply which is
not endangered by TCE or PCB from this site. A survey conducted
by the IEPA identified J wells on Edwards Street still used for
drinking water. These wells, and any other wells within 1/2
mile of the EUC site, will be sampled. Residents living within
1/2 mile of 'the EUC site who still use their private well are
urged to contact the IEPAo
If a deeper well is drilled, would it be safe from TCE
contamination?
A groundwater study is being conducted by Black & Veatch. When
the study is complete we should know if deeper aquifers are
protected or connected to shallow groundwater in this vicinity.
Remaining Concerns
QUESTION:
RESPONSE:
IEPA anticipates a variety of questions and concerns to arise during yard
excavation.
Some of these questions and concerns may be resolved before
excavation begins.
For example, a particular bush may have sentimental value
or special appeal, therefore, the IEPA should communicate this concern to .the
contractor so that plans can be made to protect this bush during excavation.
In an effort to identify these special concerns, the IEPA is planning a
door-to-door meeting with affected property owners during the design phase.
Some questions and concerns will arise unexpectedly during excavation.
These include access to homes, weather delays, transportation routes, and
accommodations.
News media coverage of the excavation may extend beyond
LaSalle County, and is likely to involve video-taping for television stations
1
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eg
Illinois EnvirGnmental Protection Agency
2~OO Churchill Road. Springfield. lL 6~7Uo
as well as still photographs for newspapers.
A news conference will be
planned for the start of excavation.
- i
During the excavation, community
(/
relations staff will be in LaSalle to assist residents with special needs.
news release and personal letter will be distributed which provides the
A
location and telephone number where IEPA staff can be reached in LaSalle.
Groundwater will continue to be sampled to determine the extent of
contamination. The results of this additional work will be available at the
LaSalle Courthouse after analyses of groundwater sampling is complete, and
will be discussed at the ~ext public hearing about remedies for on-site
contamination.
GM:jd/1665F/54-6l
8
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