United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
E PAIROD/ROS-SS/OS1
September 1988
3EPA
Superfund
Record of Decision:
Velsicol Chemical Corporation, IL
U.S. EftviroomentQI Protection Agency
Region III Information Resource
Center (3PM52)
841 Chestnut Street . :;r..t~
Philadelphia, PA 19107 ~~
i;jzardous Waste Collection
Information Resource Center
US EP A Region 3
Philadelphia, PA 19107
~PA Rep~rt t@!!~~~i@!J1J
Iriformatioli RO$@fu1W'~@ C~mt~~
US fPA R,g~o!! 3
P~i~~Hru~~~~i(;JD ~M ~ ~~ (oW
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50272 - 101
REPORT DOCUMENTATION [I. REPORT NO.
PAGE I EPA/ROD/R05-88/081
12.
3. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Velsicol Chemical Corporat.ion, IL
First Remedial Action - Final
7. Author(s)
5. Report Oate
09/30/88
6.
- -
8. Perlormini Orianization Rept. No.
12. Sponsorini Organization Name and Address
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
Agency
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I
1
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I
(G) I
11 ;:y;e of Report & -P~;;~d Covere~- - .\
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10. Proiect/Task/Work Unit No.
9. Perlormlni OI'8_nintion Name and Address
:J
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11. ContracUC) Or GrantCG) No.
(C)
':,
800/000
14.
15. Supplementary Notes
111. Abstract (Limit: 200 words)
The Velsicol Chemical Corporation (VCC) is a manufacturing facility located in
east-central Illinoisr approximately one mile north of the Cit.y of 11arshall, Clark
County, Illinois. The site is bordered by a railroad on the south and by an unnamed
tributary on the southwest. A total of 334 acres onsite are leased for crop farming.
VCC was in operation between the mid-1930s and August 1987, and occupied an area of
approxlmate1y 420 acres, 172 of WhlCh were used for productlon or dlsposal practlces for
petroleum derivatives including resins, solvents, and pesticides, including chlordane
manufacturing. All process wistewater has been deep-well injected onsite since 1965 and
the majority of the waste solids and sludges generated at the facility were disposed of
in Pond 5/6 until 1980 when the firm ceased operations. Accidental and intentional
offsite releases of wastes were noted during the period the ponds were in operat.ion. In
the 1980s, all contaminated soil and visually contaminated sediments were consolidated
and stabilized with cement and fly ash, and covered with a temporary clay cap and
vegetation. The primary contaminants of concern affecting the soil, sediments, surface
water and ground water are VOCs including benzene and other organics including PAHs and
pesticides.
(See Attached Sheet)
--
17. Oocume'l.t An!ll~is -. Oescrlptors
Recora or Declslon
Velsicol Chemical corporation, IL
First Remedial Action - Final
Contaminated Media: gw, sediments, soil, sw
Key Contaminants: organics (PAH, pesticides),
b. Identifiers/Open. Ended Terms
VOC (benzene)
COSATI Field/Group
la. Availability Statement
19. Security Class (This Report)
None
21. No. 0' Pages
94
- --..-- --
20. Security Class (This Page)
None
22. Price
(See ANSI-Z39.18)
See Instruction. on Reverse
OPTIONAL FORM 272 (4-77\
(Formerly NTIS-3S)
Oepartment of Commerce
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EPA/ROD/ROS-88/081
Velsicol Chemical Corporation, IL
First Remedial Action - Final
16.
ABSTRACT (continued)
The selected remedial action for this site includes: excavation of 10,200 yd3 of
contaminated stream and pond sediments and 87,900 yd3 of contaminated soil and
backfilling with clay, and revegetation; and consolidation of all excavated material
onsite with in-place stabilization followed by construction of a RCRA cap; construction
of ground water collection drain with disposal via onsite deep well injection or
treatment using granular activated carbon prior to offsite discharge; ground water and
surface monitoring; and implementation of land use and deed restrictions. The estimated
present worth cost for this remedial action including O&M is $9,080,910.
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Velsicol Chemical Corporation
Marshall, Illinois
Statement of Basis and Purpose
This decision document presents the selected remedial action for the Velsicol
Chemical Corporation site, in Marshall, Illinois, developed in accordance with
CERCLA, as amended by SARA, and the National Contingency Plan. This decision
is based on the administrative record for this site. The attached index
identifies the items that comprise the administrative record upon which the
selection of the remedial action is based.
The State of Illinois has concurred in the selected remedy.
Description of Selected Remedy
The final remedy at the Velsico1 Chemical Corporation's Marshall, Illinois
facility consists of the following:
Excavate 24 inches of contaminated sediments in the unnamed tributary
between the plant site and Velsicol 's western property boundary.
Additional segments in the unnamed tributary will be excavated as
determined on the basis of additional sampling until background
concentrations of chlordane are reached. The on-site section of the
unnamed tributary will be backfilled with clay and revegetated. A new
diversion channel will be constructed.
Excavate contaminated plant production area soils to predetermined
depths, backfill with clean soil, regrade the plant area to provide
effective surface water drainage and establish a vegetated cover over
the entire site.
Excavate six inches of contaminated sediment from the base and sides of
the 2 Pond and 4 Pond, backfill each impoundment with clean soil, grade
the area to provide surface water drainage and establish a vegetated
cover. Decontaminated debris from decommissioning of the facility will
be placed and compacted in the bottom of these ponds.
Consolidate all excavated material from the plant site, the unnamed
tributary and the 2 Pond and 4 Pond on top of the 5/6 Pond, treat the
excavated material by in-place chemical stabilization, and provide a
Resource and Conservation Recovery Act (RCRA) compliant multimedia cap
over the regraded 5/6 Pond. .
Construct a groundwater collection drain east of the 5/6 Pond. Dispose
of extracted groundwater via the on-site deep injection well, in
accordance with the terms of the Consent Decree or treat the extracted
groundwater to established clean-up objectives using primarily granular
activated carbon prior to off-site discharge.
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Monitor groundwater and surface cover conditions.
all remedial systems.
Apply and enforce land use and deed restrictions in accordance with the
terms of the Consent Decree.
Operate and maintain
Declaration
The selected remedy is protective of human health and the environment. attains
Federal and State requirements that are applicable or relevant and appropriate
for this remedial action. and is cost-effective. This remedy satisfies the
statutory preference for remedies that employ treatment that reduces toxicity,
mobility. or volume as a principal element and utilizes permanent solutions
and alternative treatment (or resource recovery> technologies to the maximum
extent practicable.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels. a review will be conducted within five years after
c~encement of" remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
q 13'C/~t
Date
The Illinois Environmental Protection Agency finds the selected remedy to be
appropriate as declared above under the requirements of_CERCLA, a$"amended"by
SARA. and the NCP. The State of Illinois. through the Illinois Environmental
Protection Agency. concurs with the decision the Regional Administrator has
made in the exercise of his authority in selecting this remedy.
!J~ /! ~
State Director .
. f'.u jg&'
Da
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VELSICOL CHEMICAL CORPORATION
MARSHALL, ILLINOIS SITE
ROD DECISION SUMMARY
SEPTEMBER 21, 1988
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I.
II.
VELSICOL CHEMICAL CORPORATION
MARSHALL, ILLINOIS SITE
ROD DECISION SUMMARY INDEX
Site Name, Location and Description
Site History and Enforcement Activities
III. Community Relations
IV.
V.
VI.
VII.
Scope and Role of Operable Unit or Response Action
Site Characteristics
Summary of Site RisKS
Documentation of Significant Changes
VIII. Description of Alternatives
IX.
X.
XI.
Summary of Comparative Analysis of Alternatives
Selected Remedy
Statutory Determinations
Appendix A - Figures and Tables for Decision Summary Discussion
Appendix B - Responsiveness Summary
Appendix C - Site Administrative Record
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'.
1.
II.
Velsicol Chemical Corporation
Marshall, Illinois Site
ROD Decision Summary
SITE NAME, . LOCATION , AND DESCRIPTION
Site Description
This Velsicol Chemical Corporation manufacturing facility is located in
east-central Illinois, approximately one mile north of the City of
Marshall, Clark County, Illinois, along State Highway Route 1.
Interstate Highway 70 is approximately 0.6 miles north of the plant.
The regional location and vicinity maps of the Velsicol site are shown
in Figures 1 and 2 in Appendix A.
Velsicol's property occupies an area of approximately 420 acres, of
which 86 acres are utilized for the production facility and on-site
ponds. The site map is shown in Figure 3. The production facility
occupies 50 acres of the easterly portion of the plant area.
Immediately west of the production facility, 14 acres are devoted to
stormwater management ponds . .
Since 1965 all process wastewater, and since 1974, additionally all
surface water from the facility, has been deep well injected on-site.
The 5/6 Pond occupies an area of approximately 22 acres and contains the
majority of waste solids/sludges generated over the plant's lifetime
until 1980. These wastes were chemically stabilized, temporarily
covered with clay and revegetated by Velsicol in the early 1980's. The
major portion of the remaining 334 acres, owned by Velsicol, is leased
for crop farming. .
A Conrail railroad right-of-way parallels the southern boundary of the
site. A spur of the Conrail track enters the facility from the south
and is used for delivery of raw materials to the plant. An unnamed
tributary to East Mill Creek flows westerly through the southwestern
corner of the site. The tributary travels approximately 2.5 miles prior
to its confluence with East Mill Creek.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Velslcol Chemical .Corporation Site in Marshall, Illinois, was an
active chlordane manufacturing facility until August, 1987 when USEPA
and Velsicol reached an agreement cancelling the registration of
products containing chlordane and heptachlor. The plant had been
operating since the mid-1930's for the production of petroleum
derivatives from petroleum by-products. Finished products included a
variety of resins , solvents and rubber
extenders. Production of chlordane began in the mid-1940's. The.
manufacturing operations at the facility remained essentially unchanged
until 1979. at which time Velsicol withdrew from the resin market.
Manufacture of technical grade chlordane had been the sole product at
this facility since 1980.
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Hazardous wastes generated from various manufacturing activities at the
plant were stored in on-site impoundments in the past. Accidental and
intentional releases of these wastes to East Mill Creek tributaries have
occurred from time to time during the period the ponds were in
operation. All the ponds that were previously used for the waste
storage (Hex Ponds and :5/6 Pond) are no longer in use. The contents of
the Hex Ponds, some contaminated plant area soils and visually
contaminated sediments from Ponds 2 and 4 were transferred to the 5/6
Pond and stabilized with cement and fly ash. This stablization program
was started in 1983 and completed in 1984. A temporary, vegetated clay
cover has been in place over the 5/6 Pond since 1985.
The Ve1sicol/Marshal1 site was proposed for inclusion on the National
Priorities List (NPL) in December, 1982 and finalized in September,
1983. The Illinois Environmental Protection Agency (IEPA) accepted lead
responsibilities for conduct of a Remedial Investigation/Feasibility
Study (RI/FS>, with support from USEPA. Negotiations were carried out
with Velsicol Chemical Corporation throughout 1984 and 1985 toward an
agreement to allow them the opportunity to voluntarily undertake an
appropriate RI/FS. However, these negotiations were unsuccessful and a
state-lead RI/FS was initiated in September, 1985. The remedial
investigation field work took place from May, 1986 through September,
1987. The final report documenting the findings of the RI was issued on
February 19, 1988. The Public Comment Feasibility Study report was
released on July 15. 1988, as was the Agencies' proposed plan. A
Special Notice Letter was also sent to the Ve1sico1 Chemical Corporation
on July 15, 1988, beginning the moratorium period on Remedial
Design/Remedial Action (RD/RA) settlement discussions.
Six formal negotiation meetings have taken place between Velsicol. the
USEPA, the IEPA, the Illinois Attorney General's Office (IOAG) and the
United States Department of Justice (U.S. DOJ). A draft RD/RA consent
decree was issued to Ve1sico1 in late July, 1988. Discussions on legal
issues have been concurrent with technical sessions. A draft good faith
proposal to conduct the Remedial Design and Remedial Action was received
from Ve1sico10n August 31, 1988. A final good faith proposal was
received on September 15, 1988.
III.
COMMUNITY RELATIONS
The Ill1n01s Environmental Protection Agency tIEPA) has been responsible
for conducting a communfty relations program for this site. A Community
Relations Plan was submitted to, and approved by, the USEPA in November
1985. Interviews with neighbors, concerned citizens and community
leaders fndicated a community-wide consensus that environmental
contamination attributed to Velsicol needed to be investigated. The
community relations program emphasfzed:
a.
Initial visits wfth site neighbors and community leaders,
Establishment of a local repository of documents,
b.
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IV.
V.
Assistance to news media in Illinois and Indiana to inform the
public of ongoing activities and the results_of the investigation.
Milestone activities conducted by Community Relations staff during the
RIfFS included:
c.
*
Interviews with neighbors near site and with community leaders.
Establishment of a repository of public documents at' the Marshall
Public Library. .
*
*
Development of a mailing list (150+> of site neighbors. interested
citizens and organizations. news media. and elected officials in
local. county and state government.
.
*
Periodic news releases announcing startup of various levels of
investigation at the site, on-site activities and results of
investigations.
Fact sheet #1 explaining the results of the remedial investigation.
*
*
Paid newspaper advertisements announcing the RI pUblic meeting and'
FS public hearing,
A public meeting in February 1988 to meet concerned citizens and
discuss results of remedial investigation. Approximately 50 people
attended the meeting.
*
*
Fact sheet #2 explaining the results of the feasibility study and
setting forth the proposed plan in accordance with CERCLA Section
117,
*
Public hearing on feasibility study and proposed plan in July,
1988. Approximately 40 people attended the hearing,
Separate meetings with community leaders to discuss feasibility
study and proposed plan.
*
A responsiveness summary addressing comments and questions received
during the public comment period on the RIfFS and proposed plan is
attached as Appendix B.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
This is the first and only operable unit at the site and addresses all
affected media: soils, sediments. groundwater and surface water.
SITE CHARACTERISTICS
The remedial investigation characterized the nature and extent of actual
or potential contamination associated with the site. The following
activities were accomplished as part of the RI:
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Review of existing data
Geophysical surveys in western agricultural land
Surface and stratified sampling of plant soils. agricultural soils,
5/6 pond stabilized sludges and bottom clay. creek sediments, and
on-site pond sediments
Nested groundwater monitoring well installation and sampling
5/6 Pond leachate sampling
Creek and on-site pond surface water sampl~ng
Fish sampling in East Mill Creek and Mill Creek (background stream)
Ambient air sampling of waste impoundment and background areas
General conclusions about the site and this contamination assessment are
presented below:
Groundwater
The extent of groundwater contamination was assessed by the sampling of
40 groundwater monitoring wells screened into both the upper and lower
hydrogeological units at 18 locations. These locations were selected to
define groundwater contamination within the plant area. downgradient of
the existing pond system, and upgradient of the plant area. The general
locations of the monitoring wells are shown in Figure 4. Additional
monitoring wells were installed by Velsicol around the 2 and 4 Ponds as
part of a separate activity. but for which data has been collected and
reviewed.
The direction of horizontal groundwater fJow is basically from east to
west. The velocity of potentially contaminated groundwater flow through
the upper unit west of the on-site ponds is estimated to range from
approximately 2 to 5 feet/year. The corresponding velocity within the
bedrock unit is estimated to range from approximately 3 to 8 feet/year.
The hydrogeologic investigation determined that some component of
groundwater from both hydrogeologic units discharges to the unnamed
tributary west of Pond 2. Preliminary estimates based on horizontal.
flow patterns and vertical gradient directions suggest that about 40 to
60 percent of the water in the upper hydrogeologic unit that has passed
beneath the 5/6 Pond and the Pond 2 could be discharging to the unnamed
tributary. Similarly, about 10 to 30 percent of the water in the lower
hydrogeologic unit that has passed beneath the ponds could be
discharging to the unnamed tributary. Theref~re, the unnamed tributary
is the primary receptor for groundwater discharge and completed pathway
of groundwater migration in the vicinity of the southwestern corner of
the site.
Significant pesticide contamination was not detected in groundwater west
of the existing pond system. Wells screened into the unstabilized spur
east of the 5/6 Pond (well G205M) and in the production area (wells
G217M and G2l8M) were significantly contaminated with volatile and
semi-volatile organic compounds. Volatile and semi-volatile organic
compounds were found in trace amounts in wells west of the existing pond
system. These findings suggest that organic constituents are greatly
attenuated or are not being transported to downgradient wells in
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significant concentrations at this time. Groundwater sampling and
geophysical study indicated that chlorides, which are more mobile than
organics, have migrated west of the pond systems.- The geologic
materials present at the site, clayey soils, appear to act as a barrier
to the movement of organi~ contamination. Inorganic metals
contamination in groundwater was present at low concentrations adjacent
to and west of 5/6 Pond and Pond 2. Table 1 in Appendix A presents the
range of chemicals and their concentrations found during the groundwater
investigation.
Soils
Sampling and analyses of soils was conducted to determine the presence
and extent of residual contamination in that media both on and off
site. Surface soil, three-foot and six-foot soil borings were performed
in the agricultural land, west and north of the Velsicot facility, and
in the general plant production area. Analytical results are summarized
in Table 2 in Appendix A.
The results of pesticide analyses from the soil borings in the
agricultural land indicate that pesticide contamination above background
levels most frequently occurred directly west of the 5/6 Pond and
southwest of Pond 2. Volatile contamination in the agricultural land
soil was minimal. Smaller amounts of semi-volatile contamination were
detected only at one location west of the 5/6 Pond.
The plant area soil characterization focused on the most highly
contaminated areas or suspected areas of contamination. The results
indicate that the plant area soils are significantly contaminated with
organic compounds.
Very high concentrations of pesticides, volatile and semi-volatile
organics were detected in the stabilized waste material in the 5/6
Pond. Leachability testing indicated the pesticide compounds were not
leachable. The leachability of several volatile and semi-volatile
organic compounds were significantly reduced because of the
stabilization treatment.
Permeability testing of so'l samples from the 5/6 Pond bottom showed a
range of permeabilities from 3.4 x 10-8 to 9.3 X 10-9 cm/sec. These
results indicate that the soils directly beneath the 5/6 Pond are highly
impermeable and would minimize vertical migration of contaminants.
However, leachable contaminants can migrate west of the 5/6 Pond as
shown by the low-level groundwater contamination of the wells
immediately west of the 5/6 Pond.
Surface Hater and Sediments
Surface water and sediment sam~les wefe taken to determine the presence.
and magn'tude of contamination in on-site ponds and in the unnamed
tributary to East Mill Creek. Analytical data are summarized 'n Table 3
and 4 for waters and sediments of the ponds and creek, respectively.
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Very low levels of organic and inorganic contamination were detected in
creek water samp1es. Creek sediments were not significantly
contaminated with volatile organics~ However, creek sediments were
significantly contaminated with chlordane and several semi-volatile
organic compounds at con~entrations much higher than those found in
background samples. Pesticide and semi-volatile contamination was found
at the farthest downstream sampling location at the western edge of the
Velsicol property, almost one-half mile west of the facility.
Water from Ponds 2 and 4 and the North Stormwater Pond and sediments
from Ponds 2 and 4 were analyzed to determine the presence and magnitude
of contamination in them from plant runoff. Moderate chlordane
contamination was found only in sediments from Pond 2. Moderately high
volatile and semi-volatile organic compounds were detected in the
sediments from Pond 2 and to a lesser extent, Pond 4.
Fish
Whole and fillet fish samples of the three trophic levels were collected
from three locations ranging to three and one-half miles downstream of
the Velsicol property. The samples were only analyzed for HSL
pesticides and PCBs. Fish samples collected downstream of the facility.
in East Mill Creek are contaminated with alpha-chlordane in higher
concentrations in comparison with similar fish samples from the adjacent
background stream. .
Air
Air sampling around the waste impoundments indicated several volatile
organic compounds, chlordane, and hexachlorocyclopentadiene were present
in air samples at very low concentrations. Volatile organics were
generally also detected at the background location. Due to the very low
concentrations of contaminants present in air sampling. fugitive
emissions from the existing pond system were not considered significant.
VI.
SUMMARY OF SITE RISKS
As part of the remedial investigation for the Velsicol site, a risk
assessment was developed to evaluate actual and potential human health
and environmental threats from the site under a "no action" and an
"abandonment" scenario. The no action scenarto assumed that no remedial
action would take place and the site would continue to function as an
active chemical manufacturing plant. The abandonment scenario assumed
that Velsicol ceased to be an active manufacturing plant with minimal
shutdown procedures. Under that scenario, the potential risks from
unsecured site access and discontinuation of routine maintenance of
plant facilities were evaluated.
The risk assessment identified the exposure pathways in which people can
potentially come into contact with contaminants from the site, under
current site conditions, and exposures that could result from
i
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VII.
abandonment of the site (Table 5). Potential exposure pathways for this
site can be divided into two major categories:
1.
Exposure associated with the migration of contaminants into the
unnamed tributary. including direct contact by aquatic organisms
and/or humans. or .indirect exposure through consumption of fish; and
Exposures associated with trespassing on the site or activities
associated with future site development and use.
2.
Exposure through the use of the shallow groundwater was not considered
under either alternative evaluation because of the limited groundwater
yield and the use of municipal water by nearby residences.
The risk assessment evaluated the potential exposures based on the
contaminant data gathered during the remedial investigation phase.
major results of the risk assessment are summarized in Table 6.
The
Under the no-action alternative. the major pathway of concern is through
fish ingestion. Excess cancer risks were above 1 x 10-0 for chlordane
and heptachlor. The exposure data assumed that adults consumed 3.5
pounds of fish per year for a period of 10 years. During a public
meeting held on 10 February 1988. in Marshall. Illinois. local officials
informed the IEPA and USEPA that East Mill Creek was a popular area for
fishing. Based on this new information. the exposure data was
reassessed and excess cancer risks recalculated for a fish consumption
of 7 pounds per year for a period of 30 years. For comparison. the new
excess cancer risk with these assumptions is calculated to be 2.30 x
10-5 for fish containing maximum levels of chlordane and heptachlor.
The corresponding background cancer risk for fish affected by local
agricultural soil runoff is 2.2 x 10-°.
Under the abandonment alternative. excess cancer risk from fish
consumption is elevated. as is noncarcinogenic risk. Excess cancer risk
is also elevated for trespassers due to direct contact and inhalation of
contaminated soil particles or volatilized compounds. Chemicals of
potential concern. in addition to the pesticides. chlordane and
heptachlor. include hexachlorocyclopentadiene. benzene. chloroform.
phthalates. polycyclic aromatic hydrocarbons. lead. phenol. and toluene.
Another potential environmental risk exists under both alternatives
through recharge of contaminated groundwater into the unnamed tributary.
immediately adjacent to the Velsicol facility. Surface water
contaminant levels in the unnamed tributary did not exceed Federal
Ambient Water Quality criteria based on the RI data; however, the
concentrations of contaminants in the groundwater partially recharging
to the unnamed tributary did exceed these criteria for several metals
and chlordane.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Agency draft feasibility study report was issued on June 10. 1988.
In a pre-negotiation meeting on June 21. 1988. followed by written
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correspondence on June 30. 1988, Velsicol informed the agencies that the
Marshall. Il facility would close no later than August 30. 1988.
The letter stated that it was currently "far too uneconomical to
continue manufacturing operations at the facility," and that the company
had "unsuccessfully spent tremendous effort to find replacement products
which could fi 11 the capacity of the facf1ity. II
The proposed plan, therefore. first recommende~ a modified remedial
alternative which called for complete and thorough excavation of
contaminated soils in the plant production area which would become
accessible due to closure of the plant and removal of all structures and
associated piping. Secondly. the proposed plan pointed out that the
existing deep well injection system might not be cons~dered for
long-term disposal of extracted contaminated groundwater due to the
company's initial position that it was in favor of closure of the two
wells.
This proposed plan was issued on July 15. 1988, as was the Special
Notice letter to Velsicol officially starting the 60 day moritorium on
negotiations toward a voluntary settlement for Remedial Design/Remedial
Action work. As a result of plant closure, the scope of the consent
decree negotiations has been expanded to include RCRA closure of the
regulated units and closure or operational requirements of the deep
injection wells under the UIC program. As of September 21, 1988, six
technical and consent decree negotiation sessions have been held with
the responsible party. A final "good faith" proposal was received on
September 15, 1988.
VIII. DESCRIPTION OF ALTERNATIVES
The feasibility study process identifies. screens. then develops
remedial alternatives to effectively mitigate existing and/or potential
public health and environmental threats posed by the site.
Site-specific remedial action goals included:
Minimization of existing direct contact and ingestion risks from
contaminated soils/sediments on and off-site.
Minimization of potential direct contact, inhalation and ingestion
risks from soils/sediments on-site.
Minimization of direct contact and ingestton risks from
contaminated groundwater off-site.
Minimization of future groundwater contamination on-site;
restoration of existing and future contaminated groundwater.
The following is a summary of the findings of the feasibility study for
the Ve1sicol/Marshal1 site, as detailed in the proposed plan. As
previously noted in Section VII, Documentation of Significant Changes.
modifications in the design and implementation of the preferred
alternative are being considered in ongoing RD/RA negotiations. These
details will be outlined in Section X., Selected Remedy.
\,1
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For the Velsicol site, the Agencies considered at a minimum the
development of: an alternative involving treatme~t as a principal
element to reduce toxicity, mobility or volume of site waste; an
alternative involving containment of site waste with little or no
treatment, but which is protective of human health and the environment;
and a no action alternative as a baseline for comparison.
Engineering judgment was used to assemble alternatives using the best
technologies currently available. Applicable remedial technologies
considered for contaminated soil and sediment included: excavation and
direct containment in an engineered landfill either on-site or off-site;
excavation followed by containment with chemical stabilization in an
on-site landfill; excavation and incineration either on-site or
off-site; and inplace containment and stream relocation for creek
sediments only, in combination with any of the above cited technologies
for other contaminated soils and sediments.
The applicable remedial technologies considered for contaminated
groundwater included: collection either through an interceptor trench
system or extraction well network, followed by either on-site treatment
utilizing physical/chemical systems and then surface water discharge~ or
direct disposal utilizing the existing deep well injection system.
The assembled remedial alternatives were screened based on their
site-specific effectiveness (i.e., protection of human health and the
environment and reliability), implementability (i.e. technical
feasibility and compliance with identified State and Federal
requirements) and relative costs (i.e., capital and operation and
maintenance).
Based on this initial analysis, soils and sediment alternatives
involving disposal in an off-site landfill and on-site or off-site
incineration were eliminated. Chemical stabilization has been
demonstrated to provide significant treatment benefits through
immobilization of site-specific contaminants. Although not equivalent
to the destruction of wastes using incineration, with proper management
of residuals, stabilization technology is considered effective and less
costly, and is consistent with management requirements for the existing
5/6 Pond. Accordingly, off-site landfil1ing was eliminated because
on-site 1andfil1ing provides the same environmental benefits at a lower
cost and without risks or time delays associated with transportation of
wastes off-site.
Seventeen remedial alternatives were developed for contaminated soil and
sediment at the Velsicol/Marshall site, including the no-action case.
These are individually outlined in the attached summary table. Each
source material alternative must be combined with one of the two
. contaminated groundwater action al~ernatives to develop a complete
remedial action plan for this site. long-term groundwater monitoring is
also required to evaluate a remedies effectiveness. The common remedial
components are briefly highlighted here.
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Excavation
Chemical-specific remedial clean-up objectives have been developed
during the feasibility study for plant area and agricultural soils, and
Pond 2/4 sediments and the' unnamed tributary. Excavation volumes have
been estimated after review of RI data, based upon achieving the
site-specific clean-up objectives. The estimated volume used for
comparison of alternatives is 71,000 cubic yards. This amount is
reduced by approximately 4,000 cubic yards in alternatives considering
in-place containment of creek sediments. The FS report documents the
assumptions used in the vol ume estimate-s.
On-Site Containment
Excavated contaminated soils and sediments have two alternative disposal
locations: either on top of the existing 5/6 Pond unit or in a new RCRA
landfill cell immediately west of the 5/6 Pond on land currently used
for agricultural production.
Excavated contaminated soils and sediments can further be subjected to
chemical stabilization through mechanical mixing with pozzolan-type
chemical reagents such as cement kiln dust in conjunction with
containment in either unit. This treatment process was used effectively
for the highly contaminated waste sludges deposited previously in the
5/6 Pond.
Following consolidation on top of the 5/6 Pond. with or without chemical
stabilization treatment. two cover systems are considered, based on
meeting applicable technical requirements of the Resource Conservation
and Recovery Act (RCRA). A capping system for a disposal unit. among
other things. must be as impermeable as its bottom liner. Two
-multilayer capping options are therefore considered. one utilizing a
single clay layer of proper thickness and sufficient compaction. and the
other utilizing less clay in combination with a synthetic liner. The
new RCRA cell would require the latter multimedia cap. due to the
extremely low permeability associated with its engineered liner system.
In-Place Containment of Creek Sediments
As mentioned previously. several alternatives feature excavation of
contaminated soils and on-site sediments. wit" in-place containment and
isolation of creek sediments. These alternatives involve capping creek
sediments with a compacted layer of clay and then clean backfill to
surrounding grade. The unnamed tributary would be realigned to divert
and convey surface water flows. In addition, the contaminated sediments
would be isolated from contact with groundwater through installation of
a shallow subsurface drainage system.
Groundwater Collection
\}
Both groundwater alternatives under consideration in the feasibility
study employed the same collection system. This consisted of
interceptor trench/tile lines within the shallow till aquifer which
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Long-term effectiveness and permanence
Reduction of toxicity, mobility or volume
Short-term effectiveness
Implementability
Cost
Support Agency acceptance
Community acceptance
The IEPA and USEPA identified their preferred alternative in the
proposed plan for the Velsicol/Marshall site as 2A-l, Modified, in
combination with GW-2 based on all information currently available (see
remedial alternatives summary, Table 7). This preferred alternative, or
proposed remedial action plan, included excavation of contaminated plant
area and agricultural soils and pond and creek sediments; consolidation
of these wastes with stabilization on top of the 5/6 Pond followed by
construction of a RCRA compliant, multimedia cap. This source type
action would be combined with collection of contaminated groundwater in
interceptor trenches, followed by treatment in an on-site facility and
discharge to the unnamed tributary. The remedy would then require
regular maintenance and monitoring. These alternatives will therefore
be highlighted in the discussion of the evaluation criteria which
follows.
However, as previously noted, announcement of plant closure by the
company on June 21, 1988 changed or eliminated some of the remedial
alternatives under consideration in the feasibility study. As stated
previously, Velsicol had informed the agencies that it is their
intention to: remove all chemicals from the facility, move or salvage
all equipment, and demolish remaining structures for on-site disposal.
Velsicol had also initially stated it was their intention to properly
plug and abandon the two existing on-site deep injection wells and the
observation well. That action would have eliminated consideration of
the company's deep injection well No.2 as a long-term groundwater
disposal option. It is anticipated that the active deep well may,
however, at a minimum be used in the short-term for disposal of
contaminated surface water generated through construction of the site
remedy.
These changed conditions, known prior to issuance of the proposed plan,
are incorporated into the discussion of alternatives and evaluation.
criteria which follows. Further modifications of the design details of
the preferred alternative (2A-1 modified with GW-2) as given in the
proposed plan are under consideration as the result of RD/RA settlement
negotiations with Ve1sicol. These details are outlined and evaluated in
Section X., Selected Remedy.
Overall Protection
All of the alternatives, with the exception of the no action
alternative, would provide adequate protection of human health and the
environment by eliminating, reducing or controlling risks through
various combinations of treatment and/or engineering controls, and
institutional controls.
12
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The preferred alternative includes excavation/backfilling of
contaminated soil and sediment areas with consolidation on top of the
existing 5/6 Pond unit. This allows for management and monitoring of
only one hazardous waste unit on the site. The consolidation of wastes
on top of the 5/6 Pond is accompanied by treatment through chemical
stabilization. followe~ by capping with a hi.ghly impermeable multimedia
cover system. This preferred source alternative. in combinat10n with
groundwater interceptor trench systems which collect all releases frQm
the disposal unit and plant. areas with residual contamination for
subsequent treatment and discharge, mitigates existing and/or potential
threats from direct contact and groundwater/surface water exposures.
Compliance with ARARs
All alternatives. except the no action alternative, would conceptually
meet all identified applicable or relevant and appropriate State and
Federal requirements which are outlined in Section XI., Statutory
Determinations.
Long-Term Effectiveness and Permanence
The preferred soil and sediment alternative proposes to treat wastes on.
top of the 5/6 Pond through chemical stabilization to significantly
reduce the mobility of the contaminants in conjunction with
consolidation in controlled. compacted lifts on top of the 5/6 Pond.
Mobility is further proposed to be reduced through use of a highly
impermeable multimedia cover system. Additionally. any leachate from
this unit would be collected and treated through the proposed
interceptor trench and treatment/disposal system. This combination of
treatment and engineering control, as well as normal access and deed
restrictions. provides for complete control of the environmental
situation at the site. Permanence would, in effect. be achieved with
proper management of the remedy. which would include operation and
maintenance of the groundwater collection/treatment system, maintenance
of the soil covers/caps. and groundwater and treatment facility effluent
sampling. The other soil and sediment alternatives utilizing the new
RCRA cell would conceivably require additional operation and maintenance
and monitoring activities.
Reduction of Toxicity. Mobility. or Volume
The preferred soil and sediment alternative. a~d others utilizing the
chemical stabilization process. will achieve an estimated greater than
90~ average reduction in mobility of volatile contaminat10n over those
alternat1ves 1nvolving only containment. Semi-volatile and pestic1de
contamination becomes practically unleachable. Toxicity and volume
differences among alternatives are not a significant factor. However,
the addition of reagents in the stabi11zation process will 1ncrease the
volume of materials to be contained on the 5/6 Pond. The 22 acre 5/6
Pond conceptually covers enough area to make feasible vertical expansion
of this unit for the estimated waste volume in the proposed plan of
80.000 cubic yards. If utilized. the groundwater treatment alternative
13
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effectively reduces the toxicity of contaminated groundwater by
primarily adsorbing organic contamination onto granular activated
. carbon. This system will require periodic maintenance by regenerating
or replacing the spent carbon. Use of the deep injection well system
will effectively limit mobility of contaminants by placing them in an
isolated injection zone. .
Short-Term Effectiveness
All of the soil and sediment alternatives present some degree of risk to
laborers, the community, and the environment during the two-to-three
season remedial construction phase. The relative remoteness of the
site, the use of standard health and safety equipment/procedures, and
engineering controls such as dust suppression and clean water diversion,
will minimize these threats. An air monitoring program will be .
implemented during remedial construction to monitor the effectiveness of
controls for worker and public protection. The preferred alternative
will conceptually take less t1me to implement than alternatives
proposing construction of an additional new on-site RCRA landfill cell.
Implementabilitv
All soil and sediment alternatives, and the groundwater alternatives,
propose to utilize proven engineering and construction technologies and
are read11y 1mplementable. Ease of 1mplementab111ty 1s, therefore, not
a significant factor in selection among alternatives.
Cost
The capital eng1neering and construct10n costs, and the present worth
costs for: operation and maintenance, normal replacement. and
monitoring for a nominal 30-year operating life are given 1n the
remedial alternative summary table. The total estimated cost for
implementation of alternative 2A-l, modified, with increased plant s011
excavation as estimated in the proposed plan, is $8,342,510. In
combination with alternative GW-2 wh1ch 1s costed at $738,400, the total
remedial action plan cost 1s estimated at $9,080,910. . Additionally,
. long-term groundwater monitoring costs must be considered.
Support Aqency Acceptance
USEPA, Region V, supports the preferred alternative. The
Illinois/Indiana section of the Remedial Enforcement Response Branch has
been intimately involved in the development and implementation of thii
state-lead RIfFS. Additionally, USEPA and the State are jointly
involved in RD/RA settlement negotiations with Velsicol. The Region is,
therefore, fully informed and supportive of modifications to the
preferred alternative which have taken place as a result of those
negotiations.
Community Acceptance
As noted previously in the Community Relations section (III>, a
comprehensive program has been underta~en for this RIfFS. Project
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information has been distributed to an extensive list of public
officials, the media and concerned private individuals, as well as
Velsicol Chemical Corporation and their representatives. Small group
anQ open public meetings were held at the completion of both the RI and
FS reports.
The responsiveness summary attached to this ROD Decision Summary details
oral comments received at the recent public hearing from citizens and
the Marshall Chamber of Commerce, as well as the only written comments
received, from Velsicol and their consultants. For conciseness and
c,l ari ty, these comments are paraphrased and grouped together where
possible, before a response is given.
'"
In general, no comments were received from the general public which
conceptually disagreed with the components of the agencies' preferred
alternative identified in the proposed plan. Nor were any comments
received which promoted any other remedial alternative developed in the
FS, or variation thereof. Velsicol Chemical Corporation has, however,
submitted extensive comments on the scope of the remedial action
required for this site. These comments have been carefully considered
and promptly addresse.d throughout the study, as well as at this stage in
the responsiveness summary. The technical details of a negotiated
settlement on an approvable responsible party site remedy are the
sUbject of the following section.
x.
SELECTED REMEDY
Before recent remedy discussions from RD/RA settlement negotiations can
be outlined, the agencies' preferred alternative as presented in the
proposed plan should be reviewed. It consisted of soil and sediment
alternative 2A-l, modified, in combination with groundwater alternative
GW-2. The elements of that preferred alternative are highlighted below.
Excavation of all contaminated soils and sediments identified in
the FS, with optimum so11 removal in plant area "hotspots" that
will become accessible due to proper structure demolition and
elimination of unnecessary service roadways. The total soil
excavation quantity under this modified alternative was estimated
to be approximately 80,000 cubic yards.
.(
Bac~filling of excavated areas with cleaR-clay, regrading for
positive surface drainage and establishment of a vegetative cover
to facilitate off-site stormwater runoff:
Consolidation of contaminated wastes on top of the existing 5/6
Pond, with treatment in-place provided by chemical stabilization by
controlled mechanical mixing of reagents and wastes by conventional
construction equipment during placement of lifts of material.
Vertical extension of the existing localized leachate collection
system on the western edge of the unit. Capping of the modified
5/6 Pond with a RCRA compliant multimedia cover system.
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Collection of contaminated ground~ater through installation of t~o
interceptor trench systems in the shallo~ aquifer: one immediately
downgradient of the 5/6 and 2/4 Ponds and one do~ngradient of the
highly contaminated plant process areas.
Treatment of extractetl groundwater in an on-site system and
subsequent discharge to the unnamed tributary. The potential
exists for use of deep injection ~ell No.2 for direct disposal of
contaminated ground~ater, and surface ~ater through the initial
remedial construction phase.
Evaluation of the effectiveness of the remedy through regular
monitoring and reporting on: shallo~ and deeper ground~ater at the
perimeter of the site, effluent from the groundwater treatment
facility, and the cover systems (particularly over the 5/6 Pond
unit); development of contingency plans to'address any
environmental problems.
Access and land use restrictions.
This remedial action plan, with proper operation and maintenance,
permanently reduces primarily the mobility of site contamination through,
a combination of treatment, engineering and institutional controls. The
existing and potential threats associated ~ith direct contact ~ith
~astes or migration through the shallo~ ground~ater and/or surface water
pathways is effectively mitigated. The technologies proposed are well
proven, and the necessary construction, labor, equipment and materials
are readily available.
In summary, the IEPA and USEPA believe this preferred alternative would
be protective of human health and the environment, wouid attain ARARs
and would be cost-effective while implementing a permanent,
environmentally sound solution for the entire Velsicol/Marshall site,
that employs alternative treatment technology.
As indicated previously, modifications to the scope of work of the
various remedial components outlined above have been discussed with
Velsicol in the context of settlement for voluntary implementation of
the selected remedy. Conceptually, the goals of the agencies' preferred
remedial alternative are not compromised. The ensuinq discussion
documents chanqes in the conceptual desiqn and implementation of the
selected remedy from that in the proposed plan, and provides the
rationale for those chanqes. '
Unnamed Tributary and East Mill Creek
The RI identified significant contamination of creek sediments from the
, facility to Velsicol 's western property boundary (see attached site map,
Figure 3). The site-specific clean-up objectives developed for various
media by the IEPA Clean-up Objectives Team (COT) are also attached to
this Decision Summary (Table 8). Additional information on this process
is included in the FS. Sediment sampling further downstream in the
unnamed tributary and East Mill Creek into ~hich it empties ~as not
16
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undertaken during the RI. However, fish analytical results from these
reaches indicate elevated levels of chlordane compared to background
levels established in the adjacent Mill Creek.
Remediation of this off-site area will include excavation of
contaminated sediment in the unnamed tributary from the southeastern
edge of the facility to Velsicol 's western property line. Initially, a
boundary survey will be completed on this section of the creek to
establish its exact course through the property. The approach to
excavation will be construction oriented. The depth of excavation will
be six inches below the 18 inch depth of'contamination observed in the
RI. This would result in approximately 2,200 c.y. of creek sediment to
be consolidated and stabilized in-place on top of the 5/6 Pond.
In order to minimize downstream impacts associated with excavation of
the creek, and then to eliminate surface water flow through that
section, a permanent diversion channel will be constructed prior to
excavation of contaminated sediments (see final remedy conceptual plan,
Figure 5). This side channel would parallel the existing one, crossing
. it at midpoint through this section due to the given facility and stream
configuration. Any clean stormwater during construction would be pumped
across this intersection. Contaminated water collected in the existing.
creek excavations would be dealt with as other on-site stormwater is.
Excavated clayey soil from the new channel will be used to backfill the
existing one in discrete, compacted lifts to meet the surrounding field
grade. Positive drainage patterns will be established and the entire
affected area revegetated or farmed. Sensitive sections of the new
channel will be protected with appropriately sized rock.
A conservation dry dam exists on East Mill Creek approximately three
miles downstream of Ve1sicol 's western property boundary. This man-made
feature acts as a sediment trap and appears to be a likely end pOint for
contaminant build-up. The FS proposes additional sediment sampling in
this section at 1,000 ft. intervals with three depth composites (0-6",
6"-12" and 12"-18") for the primary contaminant of concern, chlordane,
during remedial design. Samples will be taken at each interval in local
areas of sediment deposition, as opposed to swift moving channel areas.
It is also proposed that background stream sediment chlordane
concentrations be established in East Mill Creek, above its confluence
with the unnamed tributary. Available data suggests that the average
concentration of chlordane in local stream sedJments ranges from 10-20
ug/kg. Any sediment excavation beyond Velsico11s western property
boundary will focus only on stream sections with sediment build-up, as
opposed to sections of exposed bedrock. Additionally, consideration
will be given when evaluating the limits of the scope of this work to
minimizing damage to the stream and the surrounding property. Velsicol
has assumed an excavation quantity of approximately 8,000 c.y. from this
section in their RDIRA technical proposal. This sediment would also be
consolidated and stabilized in-place on top of the 516 Pond.
Aqricultural Land Soils
An extensive sOil sampling program was implemented in agricultural lands
west and north of the facility during the RI. Clean-up objectives based
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on protection of human health and the environment have been established
for off-site soils, as for other media, by IEPA COT (see attached
summary, Table 8). However, the background concentration of chlordane
in central Illinois agricultural soils has been observed at 50 ppb.
The proposed plan advocated removal of surface soils to a depth of one
foot (10,000 c.y.) for 'soil borings with chlordane concentrations above
background, and consolidation of these soils with stabilization in-place
on top of the 5/6 Pond. The impacted area would then be regraded for
positive drainage and revegetated or placed back into crop production.
The selected alternative instead of excavation of these minimally
contaminated soils involves in-situ management with crop restrictions
for the fields controlled by Ve1sicol. A regular program of pH testing
and amendment wi~h agricultural ground limestone to maintain a minimum
pH of 6.5 will be implemented. Conservation practices such as
no-fa11-ti11ing will be used to minimize surface erosion. Additionally,
land use restrictions as agreed, will allow growth of only corn,
soybeans or wheat. No vegetable crops for direct human consumption will
be grown. The land may also be used for forage crop production, but no
direct grazing of livestock will be allowed. This management program
will effectively mitigate contaminant transport through groundwater or
surface water and limit translocation to crops.
2/4 Ponds
The 2 Pond ultimately receives all stormwater runoff from the plant
area. The 4 Pond currently serves as a back-up to the 2 Pond, being
connected by a culvert. These ponds were visibly "cleaned" to the
underlying natural clay liner in preliminary reclamation work performed
by Velsicol in the early 1980's.
The RI sampling indicated some contamination above established clean-up
levels in the bottom six-inch sediment layer. There was also
contamination of similar constituents observed in the pond waters and
on-line oily-water separator. This contamination appears to be the
result of plant production area runoff subsequent to recent cleaning
activities.
The 2 Pond will be the logical impoundment in which stormwater should be
collected during remedial construction. As such, work will be sequenced
around its use until the initial remedial action is complete, and
surface water runoff is of a quality to directly discharge off-site.
The remedial action identified for this area in the proposed plan
assumed continued plant use of this impoundment to contain stormwater
prior to deep well pretreatment and injection. The plan included
excavation of the six-inch contaminated sediment layer below the high
water-line, plus an additional six-inches (one foot total depth) which
amounted to approximately 15,200 c.y. This material would then be
consolidated and stabilized in-place on top of the 5/6 Pond.
However, Velsicol has indicated in recent settlement discussions that
these ponds (as well as the north stormwater pond which requires no
18
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An alternative to this intensive sampling process is adopted in
conjunction with the proposed groundwater restoration program. In lieu
of verification sampling. each plant area will be excavated to the
observed depth of significant contamination plus an additional
six-inches to insure removal of gross contamination. The exception to
this plan is area 4. wher~ excavation will be to a depth of six feet as
the saturated zone will have been encountered. Residual contamination
left in-place at this depth will be addressed by the groundwater
interceptor trench system.
This excavation scheme yields approximately 86.000 c.y. of source
material. Velsicol asked the agencies to consider partial excavation
credit in plant areas 4 and 6 where preliminary remedial action was
taken during the initial 5/6 Pond stabilization work. Preliminary
information provided indicates that soil removal has occurred from
approximately 16.500 s.f. in area 4 along an abandoned railroad spur.
and 120.000 s.f. in area 6 which was formerly used for tanks. Volume
calculations using corresponding depths for each area result in a total
excavation reduction of 8.100 c.y. Minimal soil sampling will be
included in the RD for these areas only. to confirm this previous
removal of significant contamination. An additional 10.000 c.y. of
excavation will be available during the remedial action to remove other
significantly contaminated pockets. most likely around former process
areas. A total of approximately 87.900 c.y. of source materials may
therefore be excavated from the plant production area and consolidated
and stabilized in-place on top of the 5/6 Pond (see attached removal
volume summary. Table 9). Disturbed plant production areas will be
backfilled to grade with clean clay from other Velsicol property.
regraded to drain. topsoil added and vegetation established.
p
5/6 Pond
A site total of approximately 97.700 c.y. (without consideration of
off-property creek sediments) of contaminated soils/sediments
originating from the unnamed tributary. 2/4 Ponds and plant production
area are currently identified for consolidation with in-place
stabilization on top of the existing 22 acre 5/6 Pond. This disposal
unit contains approximately 300.000 c.y. of wastes from previous
manufacturing activities. These highly contaminated sludges were
subjected to chemical stabilization with cement-type materials and
fly-ash and temporarily covered with 18 inche~_of clay with vegetation
by Ve1sicol between 1982 and 1985.
\!
The scope and sequencing of excavation. incorporation of stabilizing
agents and compaction in controlled lifts on top of the pond will be
developed in the RD workp1an. Extensive testing of admixtures and
mechanical mixing procedures was completed by Velsicol in their original
sludge stabilization effort. An abbreviated field pilot program will be
completed during the RD to tailor the optimum proportion of reagents.
moisture and mixing sequence for the specific soils and sediments to be
stabilized during this final remedy.
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It is estimated that addition of stabilizing agents to contaminated
soils/sediments on top of the 5/6 Pond will result in a 20 percent
increase in the volume of material to be accommodated by the 5/6 Pond.
Assuming that maximum compactive effort is used to eliminate any
excavation "swell". final placement of the stab11ized waste would amount
to an increase of approximately 3.5 ft. to the existing pond elevation.
It has been determined by Velsicol that the integrity of the impoundment
berms will be maintained under this load plus that of the final cap. and
that direct runoff can be handled properly.
The proposed plan called for a RCRA Subtitle C compliant final cap to be
constructed over the completed 5/6 Pond. A multimedia cap provides the
greatest degree of protection among caps from the elements over this
above-grade impoundment by minimizing infiltration into the stabilized.
waste. With the stabilization treatment providing further protection by
severely limiting the leachability of contaminants. minimal groundwater
releases can be expected from the unit. What leachate that will be
generated will be addressed through the groundwater interceptor trench
system.
The proposed plan recommended the following geographical region-specific
RCRA model cap cross-section:
24" of compacted clay
overlain by minimum 20 mil thick synthetic liner
overlain by 12" drainage layer
overlain by filter fabric
overlain by 24" of topsoil
graded to drain (2-41 slope) and finished with low maintenance
vegetation
The selected modification of this cap design involves reducing the
thickness of the drainage layer (by six inches). and increasing the
thickness of the upper soil layer (by six inches) while substituting a
lesser quality soil material for topsoil. These changes reduce the
estimated cost of this cover system but maintain the proper freeze-thaw
protection over the bottom clay layer. while allowing for proper
internal drainage.
The profile for the modified multimedia cap 1s therefore as follows:
24" of compacted clay
overlain by minimum 30 mil thick (HOPE) synthetic liner
overlain by 6" drainage layer
overlain by filter fabric
overlain by 24" of clean so11 fill
overlain by 6" of topsoil
graded to drain (2-41 slope) and finished with low maintenance
vegetation
An operation and maintenance program for the 5/6 Pond cover will be
developed in the RO work plan. It will include regular inspection and
erosion repair. as well as optimal liming. fertilization. reseeding and
mowing by the Velsicol maintenance crew present on-site.
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On-Site Groundwater
An extensive groundwater monitoring well network was installed and
sampled during the RI. Two areas of contamination were observed.
Groundwater within the plant production area is significantly
contaminate.d in comparison to site-specific IEPA COT clean-up/discharge
objectives. This contamination is generally limited to the uppermost
aquifer below the surface. as it moves westward with upgradient flows
toward recharge of the unnamed tributary. No actual measurements of
groundwater quality were taken beneath the 5/6 Pond. nor was a transport
modeling effort undertaken as part of this study. Groundwater
immediately west of the impoundments was found to be contaminated with
low level organics and inorganics. compared to COT objectives. A plume
of mobile chlorides has been tracked several hundred feet away from that
area. The FS estimated 40-60 percent of water from the upper
hydrogeologic unit in the vicinity of the 5/6 and 2 Ponds would
discharge to the unnamed tributary based on horizontal flow patterns and
vertical gradients. Therefore. the potential for contaminant release
from shallow groundwater to surface water has been established and
should be addressed.
The primary goal of the groundwater remedial action is to prevent the
release of contaminated groundwater from the site. The other goal is to
restore the affected environment beneath the facility. with use of
institutional controls until restoration is achieved. .
The groundwater collection plan developed in the FS and recommended in
the proposed plan involved interception of contaminated water from each
of the areas identified. through the use of shallow pipe and gravel
backfilled trench drains. One trench would be located immediately
downgradient of the 5/6 and 2 ponds. being approximately 2.450 ft. long
and 15 ft. deep (bottom of till layer). An estimated steady-state flow
rate of 1.870-3.000 gallons/day was expected. The other trench was
proposed to be located immediately upgradient of the 5/6 and 4 ponds.
being approximately 940 feet long and 15 feet deep with an expected flow
rate of 600 to 1.350 gallons/day. These two trench systems would be
sloped to drain by gravity toward sumps in the center of each. with
transmission pumps and lines from the sumps to the treatment system.
The on-site treatment system conceptually designed for the FS and
proposed plan relied primarily on carbon adsorption to meet the IEPA/COT
clean-up objectives prior to controlled discharge to the unnamed
tributary (see attached list of. and rationale for. chemical-specific
objectives for groundwater and surface water. Table 8). The storage
tank and treatment columns were tentatively located next to the creek in
a diked containment area in agricultural land west of the 5/6 and 2
Ponds. The combined groundwater influent. and effluent. would be
regularly monitored to evaluate the effectiveness of the system. The FS
costed operation and maintenance of this system is over a nominal thirty
year period. although the actual lifetime will be dictated by the field
effectiveness of the system to restore the quality of groundwater to
below the established objectives.
\!
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XI.
presence throughout plant decommissioning and remedial activities. The
plant perimeter fence. with controlled access points. will remain; with
adjustments made during and after construction. The groundwater remedy
will conceivably require routine inspection and maintenance. This
factor. coupled with the potential liabilities associated with the site
and a desire to protect the sensitive cover systems. will most likely
lead Velsicol to permanently employ a small resident staff at the former
facility.
The details of land use restrictions will be finalized in the Consent
Decree. A notation on the deed to the facility will indicate that the
land has been used to manage hazardous waste and its use is restricted
according to 40 CFR Subpart G regulations. In addition. Velsico1 owns
and controls a large amount of agricultural land around the plant.
particularly to the north and west. They have indicated that they do
not intend to sell any of those holdings at this time. However. the
potential exists for industrial/commercial development to the north near
Interstate 70 where several businesses have recently located. The
Agencies will recommend. through the Consent Decree. that an adequate
buffer zone be maintained by the company around the site. Of particular
concern would be control of the agricultural lands identified with
special in-situ management requirements. and the capped Quarter-mile
long section of the unnamed tributary to the current western Velsicol
property boundary.
Summary of Selected Remedy
Conceptually. the selected remedy put forth in this Decision Summary is
identical to that recommended in the proposed plan. The technical
details of some of the remedial components have been modified, without
compromising their environmental purpose. These modifications are
logical outgrowths of that originally developed in the feasibility study
as presented for public comment. The agencies believe this final
alternative will be protective of human health and the environment. will
attain ARAR's and will be cost-effective while implementing a permanent,
environmentally sound solution for the entire Velsico1/Marsha11 site,
that employs alternative treatment technology.
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The selected remedy reduces risks to human health and the environment by
excavating contaminated soils and sediments, treating them through
chemical stabilization. and then covering them with an impermeable
multimedia cap. Collection of groundwater through a trench system will
prevent off-site migration and reduce the threat of direct contact with
contamination in surface water.
Health based chemical specific clean-up objectives for groundwater,
soils and sediments were developed by IEPA's Clean-up Objectives Team
(COT). As previously noted, clean-up objectives are listed for each
contaminant found on-site in Table 8. Appendix A.
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The 111inots Environmental Protection Agency has developed a process tn
which the agency'S various dtvisions follow procedures similar to
classfc rfsk assessment/risk management fn order to develop.
chemical-specific clean-up objectives for contaminated sites whtch the
agency addresses through its vartous programs. Two teams of
specialists. the Clean-upObjecttves Team (COn and. the Coordinated
Permit Review CORIIIittee- (CPRC). establish site-speciftc health-based
clean-up objectives for types of regulated clean-ups such as RCRA
closures. clean-up of spills and leaks and remediation of Superfund
Sites. The COT/CPRC process was used to establish site-specific
clean-up levels for the following media that will be addressed in this
remedial action:
1.
2.
Plant soils and 2/4 Pond sediments;
Unnamed tributary sedtments and surface water;
3.
Groundwater
Since all remediation activities will take place within a secure area
owned by Velsicol. it is believed that the general Marshall community
will not be affected in the short term by the remedial action. Prudent
construction and operation practices such as dust suppression. air
monitoring. and clean water diversion and sediment trapping during
remediation will minimize off-site migration of contaminants via the air
or surface water pathways. .
. \
Attainment of Applicable or Relevant and Appropriate Requirements
Section l2l(d) of SARA requires that remedial actions meet legally
applicable or relevant and appropriate requirements (ARARs) of other
~nvironmenta1 laws. These laws may include: the Resource Conservation
and Recovery Act (RCRA). the Clean Water Act (CWA). the Clean Air Act
(CAA). the Safe Drinking Water Act (SDWA). and any state law which has
stricter requirements than the corresponding Federal law. A Illegally
applicable" requirement is one which would legally apply to the response
action if that action were not taken pursuant to Section 104 or Section
106 of CERCLA. A "relevant and appropriate requirement" is one that.
while not legally applicable to the remedial action. addresses problems
or situations sufffciently similar to those encountered at the site that
their use is well suited to the remedial actiOA.
\I
Non-promulgated advisories or guidance documents' issued by federal or
state governments do not have the status of ARARs; however. where no
applicable or relevant and appropriate requirements exist. or for some
reason may not be sufficiently protective. non-promulgated advisories or
guidance documents may be considered in determining the necessary level
of clean-up for protection of human health and the environment.
The clean-up levels identified by COT for the tributary surface water
and groundwater are also ARARs -- i.e. promulgated State water quality
standards and Federaf Ambient Water Qual ity Criteria which are
26
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applicable or relevant and appropriate to the remedial action. However,
there are no State or Federal ARARs for the contaminants found in the
soils and sediments at the Velsicol site. The COT/CPRC clean-up levels
for these soils and sediments fall into the category of non-promulgated
advisories, which were considered by the Agencies in determining the
volumes of soils and sedi'mentsto be excavated from the unnamed
tributary,' 2 and 4 Ponds and plant production area to assure protection
of human health and the environment. '
The following is a description of the ARARs for the different components
of the remedy and an explanation of how this remedial action meets those
requirements:
Soils and Sediment Excavation
The selected alternative calls for the excavation of contaminated
soils from the plant production area and sediments from the unnamed
tributary and 2 and 4 Ponds for consolidation and in-place
stabilization on the 5/6 Pond. The ponds, tributary and plant
production area are contiguous to the 5/6 Pond and constitute a
single area of contamination.
RCRA Subtitle C closure requirements are applicable to areas of a
site that contain RCRA characteristic or listed hazardous waste and
that waste was received or managed after November 19, 1980, the
effective date of RCRA. If the 2 and 4 Ponds, unnamed tributary
and plant production area meet this definition they must be closed
in accordance with RCRA closure requirements.
The 2 and 4 Ponds are used to collect and store storm water prior
to its disposal by deep well injection. The storm water is not
considered a "hazardous waste" as defined under RCRA. The unnamed
tributary sediments became contaminated prior to the effective date
of RCRA from discharges of plant process waste and storm water
runoff. Thus, the RCRA closure requirements are not applicable to
the 2 and 4 Ponds or the unnamed tributary. The plant production
area includes hazardous waste storage and pretreatment tanks, a
drum storage area, former tank farm and chemical manufacturing
facilities. Soils beneath the production area are contaminated
with hazardous constituents. This contamination is due to leaks
and spills from these facilities over the history of plant
operation. It is not known whether contamination occurred before
or after the effective date of RCRA; nor was the soil contamination
attributable to any specific hazardous waste management unit. The
RCRA Subtitle C closure requirements are applicable to the
RCRA-regulated hazardous waste management facilities in the plant
production area, such as the storage and pretreatment tanks; these
requirements would not be applicable to those portions of the plant
production area not used for management of RCRA hazardous waste.
Nevertheless, the entire production area as well as the 2 and 4
Ponds and tributary sediments contain RCRA hazardous constituents
that have been released, or have the potential to be released to
27
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groundwater or surface water offsite. Therefore, the Agencies
determined that RCRA closure requirements are relevant to
remediation of these areas. After consideration of RCRA Subtitle C
closure requirements, it was determined that "clean closure" is the
appropriate standard for the unnamed tributary. The on-site
portion of the tributary and the off-site portion of the tributary
will be excavated until background levels of chlordane and
heptachlor in Illinois streams has been attained. For the plant.
production and the 2 and 4 Pond areas, "clean closure" is not
possible because of existing groundwater contamination beneath the
facility. "Closure in-place" is not deemed appropriate because the
contaminants in the plant area soils and 2 and 4 Pond sediments are
the primary source of this groundwater contamination, and one of
the goals of CERCLA is removal to the maximum extent practicable of
source materials. Leaving these materials in-place would greatly
increase the time necessary for groundwater remediation. It was
determined that a "hybrid closure" approach is more appropriate
under the circumstances at the facility. This approach combines
certain appropriate aspects of RCRA "clean closure" with
appropriate aspects of RCRA "closure in-place." At this site, all
equipment and structures in the production area will be
decontaminated or disposed of as hazardous waste; contaminated
soils as identified by sampling in the RI will be removed to the
5/6 Pond and a grou~dwater collection and treatment/disposal system
will capture and treat/dispose of contaminated groundwater. The
excavation of plant soils and 2 and 4 Pond sediments will remove
the threat to human health from exposure through contact, as well
as minimize the source of groundwater contamination to be
remediated.
RCRA Section 3004(u) and 3004(v) and 40 CFR Part 264, Subpart F
require corrective action for releases of hazardous wastes or
constituents from any "solid waste management unit" (SMU) at
facilities requiring a RCRA operating permit, including a
post-closure permit. Velsicol operated under RCRA interim status
until August 30, 1988, and SMUs at the facility are sUbject to
these corrective action requirements as a part of closure of the
facility. The 2 and 4 Ponds are not SMUs because the storm water
runoff is not a "solid waste" under RCRA. The tributary is a SMU,
which is defined by USEPA as "any d1scernable waste management unit
from which hazardous constituents may m1g~ate, irrespective of
whether the unit was intended for the management of solid or
hazardous waste." Prior to 1964, and during uncontrollable storm
events thereafter, the unnamed tributary was used to receive
discharges from waste management units. USEPA has also interpreted
the term "solid waste management unit" to include areas associated
with production processes at facilities which have become
contaminated as a result of "routine and systematic" release of
wastes or hazardous constituents from wastes." A product may
become a waste if it is abandoned or discarded. The production
area soils at the Velsicol site have become contaminated from
releases from production processes; it is not known whether these
28
"
'J
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releases were "systematic" or "routine." Nevertheless, RCRA
corrective action authorities are relevant and appropriate to the
remediation of the plant production area because releases of
hazardous constituents to the soils and groundwater in this area
have occurred which threaten human health and the environment. and
releases to the groundwater will continue to occur unless the
source material i~ removed. In conformance with these authorities.
contaminated soils in the tributary and plant production area are
being removed and contaminated groundwater under the plant area
will be remediated (see discussion below pertaining to groundwater
collection and treatment/disposal).
Groundwater Collection and Treatment/Disposal
This component of the remedial action consists of collection of
groundwater in a trench system situated between the plant.
production area and the 5/6 Pond. This system will capture
contaminants migrating from the 5/6 Pond, as well as the plar.t
production area. As stated above, RCRA Section 3004(u) and Subpart
F regulations apply to releases from solid waste management units
at RCRA facilities.
The RCRA Subpart F regulations require the establishment of
concentration limits for hazardous constituents released from solid
waste management units and the treatment of groundwater exceeding
those limits at the "point of compliance" as defined at 40 CFR
264.95. The "point of compliance" for groundwater migrating from
the plant production area is its western boundary. The COT
health-based clean-up levels for the groundwater were determined by
the Agencies to constitute appropriate alternate concentration
limits (ACLs). USEPA/IEPA may adopt an ACL as the groundwater
protection standard in 1 ieu of "background levels" or "maximum
concentration 1 imftstl if the ACL "wi 11 not pose a substantia 1
present or potential hazard to human health or the environment as
long as the (ACL) is not exceeded". Groundwater collected from the
trench system at the point of compliance will be treated to achieve
the COT levels. Since the affected groundwater is not used for
drinking water. Maximum Contaminant Levels (MCLs) and Maximum
Contaminant Level Goals (MCLGs) under the Safe Drinking Hater Act
are not "applicable" standards. Further, since there is no
potential for future use of the affected groundwater as drinking
water between the source of contamination and the point of
discharge to the unnamed tributary. MCLs and MCLGs are not
lire levant and appropr ia te" standards.
The discharge of treated groundwater to the unnamed tributary is
regulated by the Clean Water Act (CWA) National Pollutant Discharge
Elimination System (NPDES). Discharge to the tributary is an
on-site action; as such the site is exempt from the procedural aMd
administrative requirements of the NPDES (including the requirement
to have a discharge permit from the state). However. substantive
requirements of the Clean Water Act must be complied with. Thus.
29
-------
for this site. discharge limits must be established which are based
"on application of Best Available Technology (CWA Section 301(b» or
more stringent limits. if necessary. to assure that the receiving
water meets applicable state water quality standards (CWA Section
302). The CWA also requires monitoring of the discharge to assure
that the discharge limits are being met (40 CFR Part 122.44(1».
The COT clean-up levels for "groundwater referred to above satisfy
the CWA requirements for discharge limits for the discharge of
groundwater to the unnamed tributary. Since the COT levels are
based on the state water quality standards. where available. and.
Federal Ambient Water Criteria. they will ensure that the general
use water quality standards are maintained in the unnamed tributary.
(An alternative to treatment of contaminated groundwater and
discharge to the unnamed tributary proposed by Velsicol. is to
discharge the groundwater directly to deep injection well No.2
on-site. In this case that injection well must meet the operating
requirements of the Safe Drinking Hater Act. Underground Injection
Control (UIC) Program, 40 CFR Parts 144-147. Also. the disposal of
the groundwater in injection well No.2 must be in compliance with
all land disposal restrictions promulgated in 40 CFR Part 148 which
are currently in effective or may become effective during the
course of the groundwater remediation process).
Section 303 of the CHA requires States to promulgate state water
quality standards for surface bodies of water in the state, based
on designated uses of the water bodies. The state water quality
standards are based on Federal Ambient Hater Quality Criteria
developed by USEPA. CERCLA remedial actions involving surface
bodies of water must ensure that applicable state water quality
standards are met. CERCLA also provides that Federal Ambient Hater
Quality Criteria should be met where relevant and appropriate to
the circumstances at the site. The unnamed tributary and East Mill
Creek are designated general use waters under Illinois
Administrative Code (lAC) Section 303.201 and must meet general use
water quality standards specified in 35 lAC Section 302. Subpart
B. (The general use standards protect aquatic life from toxic
substances but do not apply to waters used for public water
supplies.) Thus, the general use water quality standards are
applicable clean-up standards for remediation of the tributary,
where available. and are supplemented by ~mbient Water Quality
Criteria for protection from consumption of fish which were
determined to be relevant and appropriate;
Consolidation of Contaminated Soils and Sediments on Existing 5/6
Pond
Excavated soils and sediments will be consolidated and stabilized
in-place on top of the 5/6 Pond. Hazardous waste was manag.d ~n
the 5/6 Pond after July 26, 1982; therefore, the 5/6 Pond i~ a RCRA
"regulated unit" subject to all Subtitle C requirements. The 5/6
Pond will be closed leaving previously disposed wastes and the
30
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excavated soils and sediments from this CERCLA action in place.
Therefore, pursuant to 40 CFR 264.310, the 5/6 Pond must have a
final cover which minimizes liquid migration~ minimizes
maintenance, promotes drainage, accommodates subsidence and has a
permeability less than or equal to the permeability of the natural
subsoils present. This remedial action provides for a final cover
with a synthetic liner that meets these requirements, having a
permeability of 10-1 I em/sec. This permeability is much greater
than that of the bottom clay layer of the 5/6 Pond.
In addition to a final cover, the regulation requires long-term
maintenance and monitoring to maintain the cap's integrity, ensure
collection of leachate, prevent damage from run-on and runoff and
ensure operability of a RCRA-complaint groundwater monitoring
system. RCRA land disposal restrictions govern the disposal of
hazardous wastes in landfills. Because contaminated soils and
sediments will be consolidated and stabilized within the same area
of contamination, specifically on top of the 5/6 Pond, "disposal"
will not occur and these requirements would not be applicable to
this remedial action. Moreover, the concentration of the hazardous
constituents in the soils and sediments to be consolidated and
stabilized on the 5/6 Pond is significantly lower than that of the"
hazardous wastes previously disposed of and stabilized in the 5/6
Pond. Therefore, the addition of this remedial volume of
stabilized material will have no significant effect on the mobility
of contaminants from the unit. For this reason any land disposal
restrictions affecting hazardous constituents found in these 50;ls
and sediments, which may become effective prior to completion of
this remedy, are determined not to be relevant and appropriate to
consolidation of the CERCLA soils and sediments on the 5/6 Pond.
RCRA Subpart F groundwater protection regulations also apply to the
5/6 Pond. When hazardous constituents are detected at the "point
of compliance", a groundwater monitoring system must be maintained
and groundwater protection standards established and met.
For the 5/6 Pond the "point of compliance" is the western boundary
of the 5/6 Pond. Since hazardous constituents have been detected
at this boundary, existing" groundwater monitoring wells will
continue to be used for compliance monitoring pursuant to 40 CFR
264.99. This existing system complies with the requirements of 40
CFR 264.91. The ACL levels identified above are the concentration
limits that will trigger corrective action "if monitoring shows they
are being exceeded. At the present time, these levels have not
been exceeded.
The groundwater collection trench located between the 5/6 Pond and
the plant production area is calculated to create a zone of capture
which will include any releases from the 5/6 Pond. However, the
monitoring wells on the western boundary of the 5/6 Pond will
identify any migration of contaminants that might evade capture in
the trench system. If such migration occurs at levels exceeding
the ACLs, appropriate corrective action will be implemented.
31
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Cost Effectiveness
The total present worth cost of the preferred alternative in the
proposed plan was $9,080,910. The cost of the selected remedy as
negotiated with Velsicol in their good faith proposal has not been
calculated, but is comparable to the preferred alternative. This
preferred alternative was selected over less expensive alternatives
which do not provide for treatment of soils and groundwater because the
additional protection provided by treatment was jUdged to outweigh the
cost. The more expensive alternatives, including construction of a new
on-site RCRA compliant cell for disposal of treated soils, were not
jUdged to be significantly more protective than use of the existing 5/6
Pond as proposed in the selected remedy.
Utilization of Permanent Solutions and Alternative Treatment
Technoloqies or Resource Recovery Technoloqies to the Maximum Extent
Practicable
. The selected remedy includes treatment of excavated soils with chemical
stabilization and provides for treatment of collected groundwater prior
to discharge from the site. This remedy was judged to provide the best
balance of protectiveness, effectiveness and cost. It was selected and
has been modified to be compatible with overall plans for closure of the'
site. This remedy utilizes treatment technologies to the maximum extent
practicable for this site and offers a greater degree of permanence than
capping without treatment.
Preference for Treatment as a Principal Element
The selected remedy treats both contaminated soils and groundwater under
an off-site discharge scenario; thus, it utilizes treatment to address
the principal threats posed by the site.
KN:jab/sp2047j/1-36
\!
32
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\
TABLE 6
~ OF RISK ASSES.SHEm'
VEISIcm. SITE
~ Pathwav
Risk ~cterization
Fish. CcnsumBrs
~Acticn Alternative
~s c:ancer risk tor ~ levels ct
c:::cntaminants is 6.00 x 10 tor adults.
Sensitivity analysis in1i~ this risk
may be as high as 2.3 X 10 . Ncn::ar-
cincgenic risks wre ~ elevated.
Dcons cancer risk tor ~ 18Y8ls ot
c::cntaminants 18 7.23 x 10 tor adul t.S.
Ncncarcincqenic risks ware significantly
8levated..
~ Altematiw
Trespassers un;jer
Aban:1cnment Alt.ernati ve
~- cancer risks tor ,.v1'1'11~1evel.s
ot c:::cntaminants were 1.25 x 10:5 tor
dermal absorption an:! 1.0 x 10 tor
inhalation exposures.
Ncnca.rcin:x;enc risks W8r8 net elevated.
-------
. '..'
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"
'c.
c
t TABLE 7
'., c
t' ,: ....,
i~~" SUMMARY Of DEYELOPED REM£DIAl AlTERNATIYES
C FOR THE YELSICOL/MARSIIAlL SITE
Ii L AND SEDIMENT Al TERNATlY(S (41 RDlEOY DESCRIPTION
C.
P1ant son Estt..ted ( 1 htt..ted
~':i Ag. Son RetWdta1 Contat...nt Cover S11tell Cover 511te11 Tota1 Cost 1 11IIp1Mentation
(': !!!!!!!! 2/4 Pond Sedf..nt Creek Sedt.nt CoIIponent Location 5/6 Pond New RCM te11 U Present Vortll 1 Pertod (Months)(21
..' , 1A-1 ExcavaUon Excavatton Contat...nt on 516 pond "'1 ttlledt a 5.554.800 24
'.. C Eng. Controh
I "
." , 1A-2 . Stng1e LQer 4.692.100 (61 24
;1:..:.
, If ("- C1Q
18-1 New on-stte "'1tt..dta Mu1 ttlledfl 7.128.000 36
... I ( RCM ce 11
18-2 . Sfng1e 1~er Mu1tt.edfl 6.265.300 36
~,i" r c1~
~ 1C-1 tn-phce on 5/6 pond _1tt..dta 5.677.500 24
r contat,...nt
and creelt
dlverston
r
1C-Z' Itng1e 1Qer 4.814.600 24
c1~
'
10-1 New on-sfte 1lU1tt..dta _1ttlledt. 7.250.600 36
RCRA ce 11
f
10-2 . stng1e 1Qer _1tt.edta 6.387.800 36
- c1~
r
ZA-1 Exc.v.tton Treawnt on 5/6 pond Mu1tt.dta 7.584.100 (5) 24
cllNtca1
r stabU hatton
2A-Z . Itng1e 1~er 1.711.600 24
r c1Q
" 28-1 New on site Mu1 tt..df. Multt..dt. 9.932.600 36
" ~
RCM ce11
28-2 . Itng1e 1Qer Mu1ttllfdt. 9.069.400 36
( c1Q
". Zt-1
tn-phce on 516 pond _1tt..dta 7.'44.000 24
(" contal,...nt
and creelt
(" dherlton
~- (
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TABLE 7 (continued)
- "'- "v
2C-2 1 1 1 . single layer 15.781.200
clay
2D-l new on site .,1 tI lied I I mul tllledil 9.992.300
RCRA ce11
2D-2 . stngle layer multt_dla 9.129.300
c lay
3 (No left tn pllce left tn-phce none none
Ictlon
source)
Nl8Iber
GV-I
GV-2.
GV-3
(0
(2)
(3)
(4)
(5)
(15)
.: ...:
.'
24
315
315 .,
.-
~
Groundwlter
col1ecUon
french
drltns
ReIII!dtll
COIIfonent
dhposil tn
exhUng deep
w11
Estt..ted Totll Cost(l)
($ Present Worth)
310.300
Estt..ted l.,l..e~tltton
Pertod (Months)el,
15
co11ectlon
french
drllns
on site
treltlll!nt:
off-site
dhchlrge
738.400
15
(no Ictlon left tn-
groundwater) pllce
none
110.700
-(])
Estt..ted totll remedtll costs tnclude capltll construction costs Ind the present worth costs 'or: operltton Ind ..tntenlnce. no,..1 repl8Cf8Rftt
Ind 8Onttortng for In Issu.ed 30 yelr operlttn~ Itfe. The fS report should be consulted for further detltls.
Estl..ted t-,Ie.entatton pertod ts for Ictual constructton of re.edtll c08ponents followtng detatled destgn and contrlctor procu~nt acttwtttes
Involves no reMedtal wort but regullr groundwlter ~nttorfng of stte pert_ter.
Totll relll!dtil Ictton plln tnwolwes cOlbfnltton of one source Ictton wtth one groundwlter Ictton alternlttwe.
The costs of 11temattwe lA-I. 80dtfted for Iddtttonal plant sotl exclwltton estt..ted tn the proposed plln due to re80wII of flcfltttes ts
$8.342.510.
The costs for Ilternlttves uttltztng I stngle layer Clp hive been re,tsed fF'08 those presented tn the proposed plln due to matsston of the cost ~
I geotechntcil ftlter flbrtc ltner.
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INTRODUCTION TO TABLE 8
~nNrTt) OBJE\.;J,'.l'lFS AATICNME
'Ihis case c:x:n::ern8 an NPL site tar which a ~al Investiqation (1U:)
and ~ Ass-~ (FA) have }:)een sublUtted by an }qert::y.
CXIntractor. 'Iha c:ase has been reterrec1 to a:tr tor the establish1re.nt
ot ARMs and ''To be CXI'1Sidarea" cleanup objectives in cmjer to pt. "eel
with the Feasibility StLx!y. 'lb8 RI has dcoJmented SCID8 areas ot heavy
oontaminatien within the bomdari. ot tn. still-op8ratin; plant and
areas ot m.:incr or::nt:am.inatien within the tacility's bomdaries Which
are net part ot the plant's dailyoperatiaw. ott-site areas ot
oontaminatien also exist, mainly as a result ot past bnac:hes in the
water ccnta.irJment system. It is P'-~ that all R:::RA and CDaA
c:x:n:cns be addressed in c:nI RecoN ot Decisien tor tha site.
'Ih8retcre, clearlJp objctives tor clean closure are ~~~ tor
cn-site and ott...ite areas ot OOI-m (soils, ....." 1ft8!Ptts, surtac:a
water, and grcun:1water) .
S1nc8 tha site is net 1 ....-pCatiaw tor cleanup cbjectives will be
lwtac1 to: (1) tha 1n:ticatar chemicals Mlectec1 tor the FA; (2)
these chemicals tOJnd in the RI to be within ~ orders ot magnit1D
ot previously-establish8:1 ~ use cleanup objectives or AW;Cs tor
prot8Ction ot irqutien ot oontaminatec1 aquatic o~; (3) these
chsm1c:al8 tant 1n th8 RI VUc:n hav8 net prwiously be8n addressed by
cr:tr (qiwn tor CPR:'. c:awidaraticn, 8V8n it the c:ha1cal may net
CIOC'eed the ,...¥~ cl-.nJP ClCjct.1W); and, (4) tar ~c:::s, these
c:h8micala tant 1n thI RI to be Da:'8 than Mea th8 bada;rounr:1
o:::n:entnticn 1n thI ... 1Z8dium or to be above Illino18 gerwral UN
water quali~ 8tanSarda. ~ 54' ~Md cbject.1v. are belew
Aa:~t.aCle C8t8ct1en L1.1IIita (~), th8 ACL 18 91"., tor ~.
P.alevant data waa not tan! to pemit I-.:'" .....oM ¥Un; c:leanJp cbjectiw
tor 2-h8xanc::n8, di--n-octylphthalate, ~oturan, alpha- ard
dalta-EtfC, W- ard tzww-ncNChlor, an:1 cxyc:hlardan8. a:1t ~
that it th8M 0. -'I''''~ are d8tec:t.8r:1 a:t8r th8 other cl88n.1p
cbject1V88 haw b88n achi8V81, the aw.~iata cbject.1v. 1IhcuJ.c1 be
d8tamin8d at that time.
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I
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J TAIL! '8
CH~ICAL-SPECIFtC OBJECTIVES FOR GROUNDWATER AND SURFACE WATER
I VtLSICOL SITE:
Ob;ecthe 0lc1s;on AOL
J PI "lme ter (uq/I) hs;, ~Jlq/11
3,,,:,,,,1 2.tJOO 1/10 Tlm-96 ,'fAZ,
I Sr~mom.t~.ne 1.100 1/10 TLm- 96 ~A
c. rtlon Ohu 1 'i de 13,500 1/10. Tlm- 96 ~A
J C.rbon Tetrachlor1~e 4,300 1/10 TLm-96 ~A
J' CPt 1 0 robenzene 1.600 and Mhture 1 . 1/10 TUI-96 ~A
Cn lorofonnl 15.1 (Off 5i te) AWQC, 10-6 NA
Risk Leve 1
I 1. 300 (On Site) 1/10 Tlm-96 NA
Et!lylbe"zene 3.200 (On' Off Site) 1/10 t1.m-96 NA
J Z.Heunone NOJ .--
2 4-Methyl-Z.Pentanone 50,900 1/10 Tlm-96 NA
Styrene4 Z.505 (On' O'f Site) 1/10 Tt.m- 96 NA
1 Toluene 1.300 (On' Off Site) 1/10 TLat-96 NA
Xylenes (ToU 1) 2.100 (On' Off Site) 1/10 Tlm-96 NA
J S,"zoic Acid 18,000 1/10 TLm-96 ~
J. 31nZ11 A1C:Oh014 1 .000 1/10 TLm-.96 ~A
Bis(Z.Eth11hexyl)Phthilit. 69 (On' Of' Site) 1/10 T1Ja- 96 NA
]" !utylbenzyl PhthilAte 232 ,;,... 1/10 TUi-96 NA
~;.".butyl Phthi Ii t. 7 3 (On , Off S i tt.) 1/10 TLm-96 NA
J Oi.n-oc:tl1 Phthi Ii tt NO --- .--
Oibenzofuran4 NO --- ._-
]
01nitro.ortnocresol 23 1/10 TLm-96' 50
] (4.6-0initro.2.~tnylphenol)
1,Z.~iC:hlorObenzene 560 and Mixture 1 1/10 TL1I-96 NA
J 1.J-OiC:hlorooenzene SZO and Mixture 1 1/10 TL1I-96 NA
1.:.~ic~lorooenzene 430 and ~1x~ure 1 1/10 TL.lI- 96 ~A
I
-------
TA!U 8 (Continued)
CHEMICAL-SPECIFIC OBJECTIVES FOR GROUNDWATER &'m SURFACE WArn
VELSICOL SIn
Object;." - :J,c 11 ; 0" AOl
~ ( ~q/l )
Pa "Imet.,. 9. s 1 s i~;/!l
H'~.c~loroclcJoD."t'd1.n.1.4 0.1 1/10 TLm.96 4.0 ..
H'~'chloro't~.".4 98 1/10 TLm.96 U
[sopl'loron.4 14 . 500 1/10 Tu..96 r,
NA
N.p"th.1.n. 230 (0" I Off Site) 1/10. TLm.96 ~A
Z.Met"yl N.phth.l.n. 900 (On' Off S1te) 1/10 Tlm-96 ~A
Carcinogenic PNAs (Totall1.S 0.031 (O'f Stte) AWQC. 10.6 .--
Risk leve'
Benzo(a)anthracene 1. 0 ( On Site) 1/10 TLm- 96 0.13
Benzo(a)pyrene O. S (On S fte) 1/10 TLm.96 0.23
eenzo(b)fluoranthene NO -... 0~18
Chrysen, NO -.. 1.5
Oibenzo(a,").nthracenl NO .... 0.3
Ncn.carcfno enic P~As Tota 1 S4 (Off Sttt) AWQC ..-
if "0 carc1ncgenic N S
.. de tee ted J:'l. 6
-
Non-carcfno ,n;c P~s Tot.1 5.4 (Off Sft.) 1/10 AWQC .-..
l' ot",r ca,.tinOQen1c NAs
detec ted [1, 6
Ac.n.ghth,n, 60. 8 ( On S fte) 1/10 TLm-96 18
Ac.n.pl'lth.lene ND .... 10
cr
Antftrac'"1 2. 3 (On Site) 1/10 TUi-96 6.6
Be"Zo(i.",i)ge~yle". NO .... 0.16
Senzo(k)fluoranthene ~O --. 0.17
Fluo"ant~ent 398 (On Sit.) 1/10 TLm-9a PeA
Fluor'n, ~O ... 2.1
Ind,no(l.Z,J-c,d)py,.en. NO ... 0.43
P~tn.nt"r.". 10 (On Site) 1/10 T1..1I.96 6.4
P y ~'''e HO ... Z.1
-------
-
J
]
]
J
I
].
I
J
I
J
I
J n
r ~
TAiL! 8 (Continued)
CHDIICAL-SPECIrIC OBJECTIVES roa caOUNDWATER Alm SUllFACI WATER
VELSlCOL SIT!
, Objt~t;Yt CtCiS~Qn AO'"
\
i'.r.mettr ( ~Q/t L S. S' S J~q/l )
H1trOOlnZlnl4 4,300 1/10 TI..1I.96 ~A
N.~1t"oSOd1~~ln11.minl 15.1 (0" SHt) .aWQC, 10.6 10
Risk ll'lll
S8S (On SHt) 1/10 Tlm-96 ~A
P.ntlc~lorop~tnol 2.4 (On I Off Sftt) 1/10' Tlm.96 36
Phlnots (Totll)1,7 100 35 lAC NA
302.208
Ch 1 ordlne 1 0.00048 (Off Sttt) AWQ(, 10-6 0.5
Risk 'levll
0 . Z (On Sf te) 1/10 TIJD.96
A'~h..BHC4 NO 0.03
Oel U.SHC4 NO ..- 0.09
t.Non.c:~lor4 NO ... --.
al r1 WII 5,000 35 lAC ...
302.208
80 ron 1,000 35 lAC ..-
302.208
Coppe r 20 35 lAC'
302.208
"'lacS 1 100 35 lAC --.
302.208
Zfnc 1 ,000 35 lAC -..
.302.208
Milture 1: In ord.r to prot.ct aqultic 1if. ag.fnst pot.nti.l .dditive
tOlicity, no comoouncS shoutd .xcctd its ;nd;vidu.l cleanup oOjt~tfv.. In
add; tion, tl\e fol1owing equltton should Ilso be Sitt sfitd (.1.1 v.lues in
\.&g/l ) :
(ChlorObtnZene] . (1.Z.0ic~1~robenzenl) . (1.3-0ic~1orObenzen.] +
1,600 560 6Z0
(1.4-0i~h1or~enze"e] < 1.0.
4JO -
-------
TABLE 8 (Cont1nued)
CHEMICAL-SPECIFIC OBJECTIVES FOR GROUNDWATER &~
VlLSICOL SIT!
SURFACE ~IAT£R
Not.S: .
1 Stttctlt .1 indicator C~tm1c.l.
I
i
i.
2 Not '0011c.0It; ct.,nup ~b;.ctive gr"Ctr tn.n AOL.
J Noc 4et.~ined; .qultic toxicicy dltl not found.
a
. Chem1CII not previously .ddressed 01 COT.
S Clelnup oOJlctive for off-sitt surface wlttrs 15 for the
trlt10ns 0' t1sttd c.rcinogenic PHASe Cle.nop obJlct1ve
wlClr and ~urflCI w.ters .re c~e aqu.t1c toxicity vllues
c.rc1nogln1c PNAs.
6 Cleanup object1vl 'or off-site surface wlters is for the SU8 0' the
concentrations 0' Ifsted non-carcinogenic PNAs l' no carcinogenic PHAs
are detected at a~propriate ACls. If carcinogenic PNAs are detected.
cteanup objective will incorporate. 10-'014 safety 'actor to protect
aglinst 'ddit1ve efflcts of non-carcfnogenic PNAs (cleAnup oOJective .
5.. ~9/1). Cleanup objective for on-site groundwlttr Ind surfac. wlters
.re the .qult1c toxicity vatues 'or listed non-carcinogenic PHAse
su. 0' the concen-
'or On-sfte ground-
'or tis ted
7 Totat ph.nols includes phenol (indicator chemica1), Z-methylphenot, .nd
Z,4-dimethy1phenol.
. - .
-------
I TAIL! 8 (cnntinued)
1./ CHEMICAL-SPECIFIC OBJECTIVES FOR SOiL AND SEDlKENT
. VELSICOL SIn
~
J ODjIC~1v, CIc1s~o.. AOt.
PI ".""U" ( "'4/~' L s. , " i"'4/k;'
J. 1''''1",1 2.0 1/10 T\..1I.9I ~,\2
Uftl1 Dt" lI"t 3.2 1/10 iUI.9I ~,\
10
To1u'"tl 1.3 1/10 .rUl.g, ~A
I Stl..t"tJ 2.5 1/10 rlm.g, ~A
%11t"ts (Tou 1) 2.1 1/10 1\:1.96 ~A
I ~ Ifs(2.Et~11~tll1) P~t~.I.tt 0.069 1/10 1\:1-9' 0.330
9uty1benZjl P~th.l.t. 0.ZJ2 1/10 rlm.g, 0.330
I Of-n-butl1 P"'t".1.t. 0.013 1/10 TUI.g, 0 . 3 30
Df.n-oetl1 PP,t". 11 tt NO. --. _-
I
Oitthl1 Pht".1itl NO ... -..
I Of b'"Zofur.n 3 NO -e. -..
HtllcII1orOOutld1t". 0.45 1/10 TUi.9' 0.230
I H.llc"1orOClc1oD."tld;.,,.1.3 0.00015 1/10 rUl-g, 0.330
N.N1troSOdf~",nl1.m;"1 O. 5aS 1/10 rUl-" O. 330
I NIDht".1.", 0.230 1/10 TUI-" 0.330
I 0 2.M8Cftl1".Ohc".1t"l 0.900 1/10 TUI.9' 0.330
CI"~i"04."t~ ~HAs (Tot.ll1
0.010 20 I TCL' ---
I ~ SI"ZO(i)lftth"IC.", 0.020 20 I rc~p O.~81
St"ZO(.)Dy..t". 0.010 20 x rc~p . 0.0 lS
S'''Z,(b)'1uorl"tn.". "0 ..- 0.012
C~r1S.'" HO ..- o. ~OO
Dibt"lo(..n)lnthracI". "0 .-. I). .:2'j
-------
TABU' &- (COftt1nu8d)
08JECTIVES FOR SOIL AND SEDIMENT
VELSICOL SIT!
ODj.eCivt
("'0/19 L
CllE.'UCAL-SPCCIFIC
,. r...,. t. r
Mo~.c.rci~oq.nic PN~S
-:rroC11 .' 1
A,,".O'H"f"f
Ac,n.gncrt.t'"t
,Aft cr,,..,,,,,
Sf"ZO(g.ft,f)gtryl,"t
. S'"ZO(k)'Tuorant~f'''
Fluora"tnene
FI yore"t
In~'''o(l.2.J.C.d)cyr'''t
pp,e"." t~r.n.
Pyre".
P~.nols (ToC.t)l,5
CP,tordan.s (iout)l.6
~,pclcn t 0,.1. 3.1
CaYCr! lord.'" J
CiS., ir."s.~on.c~lo,.J
8. ,..; WIt
80l"Q"
C:C)C)'"
I.u~ 1
Zinc:
O.cis;o"
8. S T ,
AO\,.
tl"lqlkq)
0.0'"
20 I TClP
...
1. 215 20 JI rCL.it 1. Z~O
NO ... ...
0.0'" 20 I TClP 0.66C
NO ... 0.051
~O ... 0.011
1.960 20 JI rc\,.p O. 140
NO ... O.l40
NO ... 0.029
NO ... 0.560
NO ... O. la~
100 ug/ T (Eit Tox) 35 lAC 302.208 .~A
0.0002 1/10 TL1I.9' o.~ao
O. 00 13 1/10 Tl.m-9' 0.008
~O ..- ...
~D ... ..-
5.000 wg/1 ([it Tox) J5 tAC J02. 208 -..
1.000 Y9/1 (EP TOI) 35 lAC 302.208
20 ug/1 (E~ TOI) . J5 lAC 302. ,08
100 ~9/1 (E~ TOI) 35 [AC J02.2~8
1.000 ug/1 (EP To I) 35 lAC 302.208
HCTES ;
1 S';t~t.d .s i"QiC:I:~r :~.m'c:al.
, H~t dpplicabrt. Crf1nug ~Cject'yt 9r.lttr t~.n ACL.
-------
I
J
J
~
~
J
~.
I
I
J
I
I
J .
J "
,
,
TABLE 8 (Continued)
CliDaCAL-SPECIFlC OBJECTIVES FOR SOIL AND SEDIMENT
J C~em;c.1 not Ortv1ous1y iddrtss.d by COT.
~ Hot dtt,rmin'di Iquit1C toxic;ty diti not found.
S ToUI D"lnoh fncludls Q"lnol (indicltor C"11II1cI1). Z-lIIet"yID"lnol. Ind
2.4-d1met"yID",nol.
, TOtil ,,,lordinIS fnclud's cis Ind trlns fsomers. aAckground rlsfdulS
Ire IDOVI cleAnup ODJlctivls.
7 lickground reSfduls mty be ADoVI cllAnup oDJectfvlS.
-------
AREA
~
(1)
(2)
-
-
-
---
.....
IiiiiiiiiiI
IiiiiiiIII . -
.......
Iiiiiiii
IiiIiiiII
IIiiiiiiiI
TABLE 9
.,..,
PLANT SITE SOIL EXCA V A 11 ON VOLUMES
MARSHALL PlANTSrm
,
(1)
GROSS SURFACE AREA
TO BE EXCA V A TED
(S.F)
NET SURFACE (2)
SURFACE AREA AREA TO BE DEPTH OF VOLUME OF SOIL
PREVIOUSLY REMEDIATED EXCAV ATED EXCAVATION EXCAVATION
(Fr.) (C.Y.)
83,300 1.0 3.0'14
213,000 1.0 1,889
71,000 3.5 9,981
16,500 168,500 6.0 31,444
158,000 2.0 11~1(M
120,000 100,000 1.0 3,1OC
54,000 2.0 4.000
1
2
3
..
5
6
1
83,000
213,000
71,000
185,000
158,000
220,000
54,000
SUBTOTAL
CONTINGENCY
71,196
IWm
TOrAL VOLUME OF SOIL EXCA V A110N
81,196 (87,800)
'tE~ F\c.dL
(87.Qco ')8. )
Surface areas taken from Table A-3 of Public Comment Feasibility Study by Roy ,F. Weston, Inc., July IS, 1988
Table from CRA RD/RA SOW August 29, 1988.
-------
APPENDIX B
RESPONSIVENESS SUMMARY
VELSICOL/MARSHALL, ILLINOIS SITE
-------
IN THE MATTER OF
VELSICOL CHEMICAL CORPORATION
REMEDIAL INVESTIGATION.
FEASIBILITY STUDY AND
PROPOSED PLAN
PUBLIC HEARING
APPENDIX B
)
)
)
)
)
)
IEPA File 9048
Responsiveness Summary
RESPONSIVENESS SUMMARY OVERVIEW
The Illinois Environmental Protection Agency (IEPA) and the U.S. Environmental
Protection Agency (USEPA) recently held a pUblic comment period from June 23.
1988 through August 12. 1988 for interested parties to comment on the Proposed
Plan and the Remedial Investigation/Feasibility Study (RI/FS) for resolving
contamination problems at the Velsicol/Marshall site. The required pUblic
hearing on July 27. 1988 focused on the results of the FS and the Agencies'
preferred remedial alternative (proposed plan). The public comment period was
held in accordance with the Federal Superfund Law (CERCLA Section 117) and
applicable Illinois state law.
The purpose of this responsiveness summary is to document the agencies'
responses to comments received during the public comment period. These
comments were considered prior to selection of a final remedy for the
Velsico1/Marshall site which is detailed in the agencies. Record of Decision
(ROD).
BACKGROUND ON COMMUNITY INVOLVEMENT
As the lead agency for the RI/FS. the IEPA was responsible for conducting the
community relations program for this project. A community relations plan was
approved by USEPA for this site in November 1985. It established a process to
develop a two-way flow of project information between local officials.
concerned citizens. the media and the IEPA. A comprehensive information
repository was maintained at the Marshall public library with the assistance
of their staff. Numerous press releases and fact sheets were issued to
announce fie1d activities and the findings of both the RI and the FS. The
local media were instrumental in responsibly reporting these details. A
pUblic meeting on the findings of the RI was held in- Marshall in February
1988. Community relations activities are summarized in the ROD. if additional
information is desired.
PUBLIC HEARING
The required public hearing on the proposed plan was held from 6:30 p.m. -
9:00 p.m. on July 27. 1988. at the Colonial Kitchen Restaurant on the
northwest side of Marshal~. Illinois. Approximately forty persons attended
(not counting governmental officials) including several local officials or
their representatives. Velsicol officials and members of the press (television
and newspaper).
-------
SUMMARY OF SIGNIFICANT COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCIES' RESPONSES
Questions and comments received during the public comment period are
paraphrased and organized into t~o discrete sections ~ithin this summary:
those received at the hearing and the ~ritten comments from Conestoga-Rovers
and Associates Limited for Velsicol. The agencies' response is given after
each individual question or comment.
Responses to Comments and Questions Received at Public Hearinq
Question 1:
What are the agencies going to do for the plant employees no~ that the
facility is closing?
Response:
The agencies can do nothing to directly compensate employees for either loss
of employment or job related health problems. Concerns should be directed to
Velsicol. The agencies are proceeding ~ith a Remedial Action program to.
mitigate current and potential risKs associated ~ith the site.
Question Z:
Why was off-site landf11l1ng considered as a remedial alternative?
Response:
The Feasibility Study process revie~s a ~ide range of technologies to address
. the identified environmental problems. Off-site landfilling of hazardous
substances in a compliant, permitted facility is a viable disposal option. In
this specific case, other on-site remedial technologies ~ere available at a
much lo~er cost ~ithout potential risKS from transportation of these ~astes to
such a facility.
Question 3:
Why should people of the community believe the agencies' study (particularly
the RisK Assessment) when plant employees have not shown adverse health
effects?
Response:
The Risk Assessment completed for the site did not calculate exposures for
plant employees. It is assumed they are healthy individuals ~ho follo~
company health and safety protocol in carrying out their job functions. The
site-specific assessment focused on involuntary exposures to the public
(youth/adults) and the environment under a plant operation and abandonment
scenario.
Z
-------
Question 4:
Why don't the agencies spend funds at more hazardous sites, rather than the
Velsicol/Marshall facility?
Response:
There is a rigorous process for scoring sites and placing them on the National
Priority List (NPL). Once finalized on that list, a Remedial Investigation
(RI) and possibly a Feasibility Study (FS) is required. The Velsicol/Marsha11
site was among the first eleven in Illinois to be placed on the NPL and is
currently being addressed along with these others in an orderly manner.
Question 5:
Are there any chemicals associated with the site that are acutely toxic to a
passerby?
Response:
Without consideration for releases from the active manufacturing operations,
the contaminants at their concentrations identified in the study promote
long-term chronic health effects from repeated direct exposures. Therefore,-
acute effects from inhalation exposures off-site are highly unlikely.
Question 6;
Why couldn't the agencies have directed Velsicol to undertake Remedial Actions
a long time ago?
Response:
Over the years, several agencies have identified deficiencies in the Velsicol
plant operation and have directed the company to take action to protect the
environment. In 1972, the Illinois Pollution Control Board (IPCB) ordered
Velsicol to deepwell inject all plant process waste following discharges of
contaminants to the East Mill Creek system. In 1973, the IPCB ordered
Velsicol to deepwel1 all waters that collect on the site following more
-incidents of contamination of the creek. The Superfund program which gives
the agencies authority to negotiate settlements with responsible parties or
undertake actions themselves came into existence in 1980. No superfund
activities can be initiated until a site is placed on the NPL. Superfund
discussion on this site with Velsicol began in 1984~ Velsicol had the
opportunity to undertake the remedial investigation in 1985 but the company
was unwilling to meet the state and federal regulatory requirements.
Thereafter in late 1985, the IEPA began fund-financed investigation at the
site.
3
-------
Question 7:
Is it possible for Velsicol 's Marshall facilIty to remain open and also
complete this Superfund remedial action?
Response:
Yes. the Remedial Investigation and Feasibility Study was completed on the
premise that the plant would remain in operation. The preferred alternative
recommended in the proposed plan was only modifIed to account for addItional
plant production area soils after Velsicol confirmed plant closure In a letter
to the Agency dated June 30. 1988. This letter stated that the company, "had
unsuccessfully spent tremendous effort to find replacement products which
could fill the capacity of the facility. As a consequence. we have come to
the conclusion that it is far too uneconomical to continue manufacturing
operations at the [Marshall] facility."
Question 8:
Is Velsicol responsible for all costs associated with the remedial action even
if the agencies perform the work?
Response:
Yes. the principal responsible parties (PRPs) at a Superfund site, in this
case the Velsicol Chemical Corporation. are ultimately responSible for all
response costs in accordance with CERCLAfSARA and the National Oil and
Hazardous Substance Pollution Contingency Plan (NCP). Under a fund-lead
action. the government usually completes the study and implements the remedy,
then seeks recovery of costs (with an option for treble damages) from the
responsible party. The responsible party has limited opportunity to take over
the response action at the conclusion of the RIfFS. which is the pOint at
which the VelsicolfMarshall project is currently at. providing they have the
resources and capabIlIty to implement the selected remedy and reImburse
government costs.
Question 9:
If Velsicol committed the resources to implement the selected remedy. could
they stay in operation at the facility?
Response:
Yes. as emphasized i~ a previous response. the RIfFS was completed under the
premise that the facility would remain in operation. Even if Velsicol elected
not to directly participate In the Superfund remedIal action, the facility
could have continued to operate. The work would be completed by the agencies,
and cost recovery actions pursued.
4
-------
Question 10:
Does the Superfund program address environmental problems associated with
municipal landfills and other types of sites?
Response:
Yes, the Superfund program addresses a wide range of sites that possess
significant existing or potential threats to public health or the
environment. However, as stated in a previous response, these sites are
subjected to a rigorous scoring system once a preliminary assessment and site
investigation has been completed. If they score above a cutoff point of 28.5,
they are eligible for inclusion on the NPL and subsequent superfund monies
(assuming the responSible parties do not take the lead). If they score below
that cutoff point they will be addressed on a priority basis by state
Superfund programs. if available. Illinois has a very active state Superfund
program.
Question 11:
~
What agencies/departments are responsible for responding to releases from a
low level nuclear waste site, such as the one under consideration for Clark
County?
Response:
The owner/operator of such a facility is ultimately responsible for corrective
actions at their site. They are regulated by specific federal and state
entities, namely the nuclear regulatory commission and the Department of
Nuclear Safety, respectively. It is assumed that these programs would provide
assistance in emergency response actions.
Question 12:
If additional soil contamination is found through the sampling work planned
during the remedial design phase, will there be sufficient funding to address
it?
Response:
Yes, under the scenario that the agencies would undertake the remedial action
work, excavation and other quantities would be refined during the remedial
design phase, and appropriate funds. including construction contingency
montes, would be allocated to address actual field conditions. The FS only
attempts to develop order of magnitude costs so that comparisons can be made
among the range of remedial alternatives under consideration.
5
-------
Question 13:
Should Velsicol be held accountable for contaminant exposures to plant workers?
Response:
Thfs f5 not an appropriate question for the agencies, but rather should be
taken up between the employer and employee. Velsicol has offered employment
to workers, who have voluntarily accepted it. Velsicol has implemented a
site-specffic health and safety program to protect them to the level the
company feels necessary, and the worker presumably have at the minimum
followed that plan.
Question 14:
Wfll Velsicol be compensated for two years of lost prOductivity in their
agreement to withdraw chlordane from the U.S. market?
Response:
USEPA Region 5 and IEPA have limited knowledge of the voluntary agreement on
chJordane between Velsicol and USEPA. Thfs information is being sought, and a
response will be provided at a later time. To our knowledge the agreement
only allowed Velsico1 to use up existing stocks of chlordane, but did not
compensate them for future lost production.
Comment 15:
The Marshall area Chamber of Commerce urged the agencies to:
1.
Conduct hazadous waste training for local contractors, costs to be
absorbed by IEPA/USEPA.
2.
Use local contractors, when available and practical, during the clean-up
process.
3.
Remafn cognizant of current and former Velsicol employees with hazardous
waste training and utilize their talents fn the clean-up process.
Response:
Response actfons at Superfund sites contafning hazardous wastes/substances
requires specialty construction contractors. They must possess the proper
equipment to carry out such work, as well as a staff that is highly trained in
personal/site safety procedures and fs physically fit and under medical
surveillance. The agencies cannot directly fund these training activities.
If thfs project proceeds using Superfund monies, the agencies will be required
to competitively let a construction contract following federal procurement.
regulations. The selected lowest responsible, responsive contractor would be
awarded the job. That firm would be able to utilfze local subcontractors as
appropriate, if so desired. Under this arrangement, it would seem logical to
utilize former plant employees with hazardous waste training in some labor
positions, if possible.
6
-------
Under the scenario where Velsicol carries out the remedial action, the company
would not be constrained by federal procurement regulations, however, health
and safety requirements would still apply. Velsicol has told the agencies
that they remain committed to utilizing former employees and local services
where possible, if they implement the selected remedy.
Question 16:
What will the agencies do with the product that is going to replace chlordane?
Response:
Those products will also be regulated by USEPA. requiring proper registration
and use.
Question 17:
Isn't the replacement product for chlordane acutely toxic?
Response:
Yes, this product has been shown in laboratory testing to be more acutely
toxic than chlordane, however, its persistance in the environment is much less
than chlordane.
Question 18:
Isnlt this replacement product significantly more expensive than chlordane?'
Response:
Yes. at this time it apparently is more expensive.
Question 19:
Does the government allow chlordane, or a variation thereof, to be imported
for use in the U.S?
Response:
USEPA Region 5 and IEPA have no knowledge of this activity at this time. An
inquiry has been made to USEPA headquarters. and any other information will be
made available at a later time.
7
-------
RFSFONSES 'ro VELSIa:>L' S o::MMEN'IS ON 'mE FUBUC cx:J.1MENI'
FEASIBILITY S'IUDY
COnnestoga-Rovers & Associates (eRA) on behalf of Velsicol O1emical
Corporation submitted the only written technical cc:munents to the
Public Camnent Feasibility Study report arxl proposed plan.
Velsicol arxl the regulatozy agencies exchanged draft information
regularly throughout the RI/FS process. VeJ sicol received an agency
draft copy of the FS report on 15 June 1988, arxl provided cxmnents on
that version of the FS report on 30 June 1988. Velsicol 's preliminary
~lImeJ'1ts made on the agency draft FS are similar to those made on the
public cormnent FS arxl therefore are not addressed in this adden:ium.
'!he following is a point-by-point response to the comments submitted
by eRA on the Public Camnent FS report. Eacll camment is briefly
recapped, referenced to its location in the original transmittal, an:!
followed by the agencies' response.
ccmment 1:
After the plant is dE =ormnissioned, the abarxionment scenario will be
cnanged entirely. As a consequence, risks will be far lower. (pp.
1-3, item a)
Response :
'!he site remediation is based on reducing r:.sks associated with
existing contamination at the site for.both the no-action arxl abarx:ion-
ment conditions. Although increased risks ,~ proj ecte:i urx:ler the
abandonment scenario, IEPA has determined ~ .3.t reduced remedial effort
will not result fran the proposed plant closure. 'therefore, it is not
necessazy to revise the risk assessment as SUC]9'ested by Velsicol.
Comment 2:
'!he unnamed trib..rt:ary arxl East Mill Creek contain few fish large
enough to eat am ccuJ.d not sustain a yield of seven pounis of fish
per person per year for local residents. (!=p. 3-4, item b)
Response :
It is tnIe that the fish caught during the RI in the Ul'U"1aIned tributarj
an:! East Mill Creek are generally small, however of edible size.
COnversations with Marshall Community officials an:! the public during
A0010
8.
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the public meeting on 10 FebnJaly 1988 am actual observation of
fishermens' debris during fish sampling in:ticates that the unnamed
tributary is a viable spot for fisl'1irq. As presented in the RI
report, it is likely that larger fish may not have been cx>llected due
to the limited width of seine net am obstnlctions within the tribu-
tary. '!he matter of sustainable yield fran the tributary is net
relevant to the risk assessment because risk is calculated on a
per-person basis. Even if only a limited pcp.Uation were eatin:; the
contaminated fish, the risk fran that exposure t«:W.d be equal to the
reported value. COnsulrption of seven poJrXis of fish per year was used
in the sensitivity analysis to detemine what additional risk \tw'OUld
result by fish CX>nSlIIIption of approximately twice the amount con-
sidered for the lC7.i average intake in the risk assessment. Seven
pounds of fish CX>nSlIIIption per year per person is cx>nsideI-ed reason-
able given the fishin;J activities in the unnamed tributary.
Ccmment 3:
'!here is no proof that grourrlwater cx>ntaminates the unnamed tributary.
(p.4, item c)
Response :
'!he grourrlwater near the stream is known to be contaminated, (See
Table 6-4 of the FS) an:i the contaminants are known to leach an:i
migrate. '!he tributary's status as a lC7.i-f.' r:M intermittent stream
prevents rigorous calculation of a mass flu>: of cx>nta:minant into the
stream, but the lC7.i flC7.i of the stream guarantees that contaminants
that enter the tri.butary by grourrlwater recharge have a lC7.i dilution
factor.
Comment 4:
'!he FS ImJSt consider the effect of the di~ntlirq of the facility am
securement of the property. (p 5, item a)
Response :
'!he implications of deoamnissioninq the plant an:i on-site remediation
are presented in Section 2.0 of the ~lic Canment FS adderx:lum report.
Camnent 5:
'!he chlorides in the grourrlwater west of th( 5/6 pon:l may have come
from abov~ rel,:.-ases. (p 5, item b)
Response :
Ollorides in grourrlwater are related to past waste disposal activities
in the 5/6 pond prior to stabilization am could also be attributed to
A0010
n
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intentia'1aJ. ani acx:idental releases of ~ !ran storage pords 11XJSt
recently during 1976 and 1,979. '!he EM survey also ccnfi.rmed the
preserre of an irregular plume" of elevated c:x:muctivities in gioon:i-
water west of Pend 2 ani 5/6 Pend. If this oa1tam:inatiCl'1 was due to
CI'1ly surface infiltratiat, the c:x:t'1taminant fra1t t«W.d DrIVe down-
gradient a1ly frau the defined surface water ocurse to \t'hidl it was
rel~sed. .
~-I1t 6:
'lhe gran::lwater oontam.i.natiat is a1ly ootential: transport is not
deIoonst:rated: ani only infrequent mcni.tarirg is ~. (p. 5, item
c)
Response:
At the time of RI sanpling, gran::lwater west of the pc:n3s exhibits
levels of oa1tam:ination. Lead1able oxganic oa1tam:inatiCl'1 is present
within the 5/6 Pcrd, and the gran::lwater flows ~ beneath the
5/6 Pcrxi. 'n1erefore, reference to potentially oa1tam:inated grcun:i-
water is ~ropriate. '!he observed elevated oontam.i.nation in grcun:i-
water (especially east of the 5/6 Pond) am the ~ gran::lwater
movement strcrqly indicate the need for gra,D'Xiwater remecliation, and
therefore consideration of "no-actiat" alternative with infrequent
lon:J tenn m:mitoring as St.9;1ested by Velsic:cl is net ~riate.
l'hnrnPTTt 7:
No ~~ling evidence indicates that the agria1ltural soil oa1tam:ina-
tion came fran the facility. (p. 6, item d)
Response :
'!be agria1ltural soil, especially at several cxmtigucus lc:cations west
of the 5/6 Pon:l, had higher levels of pesticides than typically faJrXi
in agria1ltural soils in central Illinois. In additicrt, these soils
have oon-pesticide oa1tam:inatiat, as presentecfin Table 1-3 and
Appen:tix A of the FS report. 'lberefore, Velsic:cl's cxn:::lusion that
residn;lJl1!11 in agricultural soils are the CXI'1SE!qUel1Ce of typical agri-
cultural practices is net SlJRX)rted by the results of soil scmpling.
ChTmPnt 8:
'!he lack of sediment sanples downstream !ran the Velsic:cl prqm-ty
prevents adequate analysis of risk and invalidates the selected
cleanup area. (p. 7, item e)
Respa~:
'!he RI clearly established that the sediJnents up to Velsic:cl' s western
prc:perty bourmry are highly oontam.i.nated. '!he FS clearly states that
AOO1 0
10.
-------
the extent of cxmtam:i.nation further dcwnst:ream fran the Velsicol
property nee:Js to be ::I~t'~sed by scmplin:J (Sectiat 6.4, Page 6.23 of
FS l~rt). '!he R:)[) will address the need to semple creek ~;~?1ts
beytni Velsicol's prcperty, as ~l as to establish lcxal bac:J
-------
Comment 11:
'!he deccmmissionirq of the manufacturing fac.i1ity invalidates the
asstmptions of the abandonment scenario's r::.sk assessment. (p. 8-9,
item h)
Response :
'!his ~IIUtt:l1t is addressed in response to c:xmnent 1.
Camnent 12:
'!be effect of contaminated grourxiwater on surface water 1m.1St be
rigorously calculated. (p. 9-10, item i)
Response :
'!he technical obstacles to rigorous calculation of o:mt.aminant flux
arxl the c:orrpel1ing reasons to expect contamination for the pt1IpOses of .
the FS were discussed previously in response to camnent 3.
O::amnent l3A:
It is ~le to 1nc:rease the assumed fish COl'1SIJnption frau 3 to
7 poun:js for risk assessment. (p. 10, first part of item j) .
Response :
'!he st.an:1ard mathematicalwwYIelinq practice of sensitivity analysis
requires that input variables (such as fish COl'1SIJnption) be varied to
determine their influence on the output variables (such as risk).
~ion of seven pounds of fish by an irxtividual durin; the period
of one year is considered reasonable.
C'anment 13B:
'!he fish in East Mill creek are too small an:1..too few for people to
eat. (p. 11, second part of item j)
Response :
'!he fish size arxl quantity issues were diSt'USsed in response to
"-11I1.ent lOB. It mJSt be stressed that risk is calculated on an
in:Uvidual basis, an:1 the quantity of fish that would be necessazy to
feed the entire local c::amnuni.ty is irrelevant.
Ccrmnent 13C:
Access to East Mill creek is limited.
(po 12, third part of item j)
A0010
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Response :
Easy access to the stream is available at bridges. '!be field crew,
for instance, required no exceptional effort to reach the creek at the
.loc:ations sanpled. '!he presence of pop cans an::i fishermen's debris .
demonstrates that people do fish in the creek.
Ccmment 14:
Rigorous evaluation of contam.i.rJant flux from grourxiwater to the
unnamed tributaIy is needed. (p. 12-13, item k)
Response :
'!he issue of transport of contaminants from grourxiwater to the tribu-
taIy was previously addressed in response to ~,uct1t 3. Risks have
been identified only for fish cons1..In'ption due to contaminated sedi-
ments in the U1'11'1amed tributaIy. No risks have been identified for
surface water wi thin the U1'11'1amed tributary although there is a
theoretical contribution.
~lil~t 15:
Monitorin;', not remeC.iation is ~ed for grourxiwater from the site.
(p. 13, item 1) .
Response :
Remediation an::i monitorin;' are required by CERC!A regulations, given
the extent of contamination an::i potential tlCU'1SpOrt in grourxiwater.
Ccmment 16:
'!he agenC':{ has no factual basis to assume that sediments wst of the
Velsicol property are CCI1"1taminated. (p. 14, item m)
Response :
'Ihese isSl10CJ were previaJSly d i c:russed in response to Q..auua:nt 8.
Camnent 17:
Groundwater does not CCI1"1taminate the creek.
(p. 14, item n)
Response :
Groundwater recharges the unnamed tributary. Althalgh the CCI1"1tamina-
tion is lcw at the present time, the contaminant movement through the
grourdwater an::i subsequent recharge of the unnamed tributary has the
potential for significant contaminant rel~~.
AOOIO
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Camnent 18:
'!he abamcnment scenario'.is iJrpossible.
(p. 15, item 0)
Response :
'!he ocntamination present in the plant area soil requires remediation
regardless of abandonment scenario. If remedial action doesn't c:x:x:ur,
am off-site surface water am on-site access is allowed, the abandon-
ment scenario would be realized.
Camnent 19:
'!he 2 am 4 Porxis are not demonstrated to contaminate grourxiwater or
surface water. (p. 15, item p)
Response :
'!he pond sec:Wnents contain hazardous substances as does the water, am .
the bottom of the porxIs are not lined. Contamination is obserJed
immediately down;radient of the porxjs. 'Ihese factors taken together
Wicate that Penis 2 ani 4 have at a minimum the potential to release
c::ontamimnts to the grourxiwater. '!he issue of adversely impactin;J
human health and the environment on their Ot:'1 is not appropriate. As
considered in the FS evaluation, the remcva.-. of pon:l sediments would
eliminate this potential pathway.
Camnent 20:
If barrier walls are eliminated in the technology screeni.n;, then they
must be eliminated fran the extraction system. (p. 16, item q)
Response:
'!he reference to barrier walls used in extraction system d i oc:cussion in
Table 3-4 is not correct. '!here is no barrier wall in the proposed
extraction system.
Ooulll.ent 21:
GroJrXiwater need not be evaluated for collE<~ion and treatment/
disposal. (p 16, item r)
Response :
'!he need for grourxiwater treatment has been addressed in response to
OQillluent 6.
A0010
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Camnent 22:
Diversion should;be carried' forward to the detailed analysis of
alternatives. (p. 16, item s)
Response :
'!his technology is OOilllllCJnly used as part of cappinq of the site anj
should not be considered an applicable technology by itself.
Ccmment 23:
cappinq of the entire plant site is a reasonable technology to c0n-
sider. (p. 17, item t)
Response :
cappinq of the entire site, although possible, has not been considered
due to the clear technical superiority anj regulatory preference of
consolidation of wastes in a single location. Also, the presence of
an existing waste disposal unit requirinq cappinq (the 5/6 Pon:i)
provides a sourx:l t.edmical basis to consolidate anj cap c::ontamiJ'lated
materials at a sinqle location.
Comment 24:
In-situ stabilization of the plant soils anj creek anj pon:l sediments
is a reasonable technology to consider. (p. 17, item u)
Response :
Stabilization is considered, but only after consolidation. SUccessful
stabilization requires a hatcgeneous, intimate anj c:xmplete mixture of
soil with a stabilizinq aqent. SUch a mixt:t.,J:'e is far easier to
achieve in a ~ct reworked soil mass than in the. spatially dis-
persed native state.
~nt 25:
Based en the precedinq ccmments, the table for sC:reeni.rq available
retur::I.lial technologies should be revised. (p. 17, item v)
Response :
~5ed on the prece:tirq responses, the table does ~ require revision.
A0010
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Ccmment 26:
'the FS states there ~ "no significant human health risks identified
for the grcurXlwater west of the ~ts." 'therefore, there is no
need to evaluate grcurXlwater technologies. (p. 18, item w)
Response :
Actually, the FS states, "No present significant human health risks
are identified for groun::iwater west of the ~ts. However.
miqration of contami.na.nts from the 1X)nds has been obseJ:ved. '!he
priIra.zv remediation action aoal for arol1n:1water will ~revent
recharae of contaminated cn'OUndwater to the unnamed tr' . II
(E:rrph.asis added.)
~Ilil.e:nt 27:
'!he Assembled Alterm.tives should include in-situ treatment ani
tributary realignment. (p. 18, item x)
Response :
In-situ treatment was, and should be, screened out at the preliminazy
screening as discussed earlier. Tributary realignment with in-situ
cappirq of secllinents in the unnamed tri1::lUtaJy was carried through
detailed evaluation of alterm.tives.
Camnent 28:
Screeninq of soil and secllinent must include in-situ treatment and
diversion of the tributary. (p. 18, item y)
Response :
In-situ treatment was, and should be, screened out as discussed above.
Diversion of the tributary with in-situ cappin:J of the sediment was
carried forward through detailed evaluation. --
Camnent 29:
a:tr criteria have been elevate:I to the level of ARAR's. SUch an
elevation is inconsistent with CERCIA guidelines (p. 19, item z)
Response: .
'the a::tr criteri~lb. not ARAR's but instead objectives to be con-
sidered. '!hey are used because there are I1'.J federal standards or
criteria for soil and secllinent contamination remediation. '!he
criteria are not arbitrary, but instead the result of an established
(1) Reference to COT sOil/sediment objectives only
AOOlO
-------
p~s within IEPA that develc:ps site spec:ific objectives for all
affected ~i:=-. 'n1e criteria inherently receive peer review because
they are the consensus of. several. offices within IEPA. Additionally,
they have been reviewed am ~ for use by tm:PA ~ the FS
~~s. 'n1e public has been given an CRX'rtunity to c.........nt at the
d1emicaJ. specific cleanup objectives ~ the FS public o....-nt
prrv-;s. Velsicol has been given that same ~bmity, as ~l as
advan:e review duri.rr;J the aqeu....-j draft FS pericxl. No specific
c."'.'-uts have been received at the ~iateness of the established
criteria or alternatives, therefore, no I"eSpa'ises are r---se.'U'Y.
~nt 30:
'!he FS does net acx:amt for prior ~al activities in Areas 4 and
. 6 of the plant. (p. 20, item aa)
Respa~:
Prior l.A._ij
-------
Response :
As stated. in the FS, the mul tidiscipli1w:y ror group considers ''what
must be protected..., whether there is an especially sensitive popula-
tion to be protected, whether contamination in one medium may pose a
problem in another medium, ani whether there is enough information to
plO~ cleanup objectives." Tables 6-7 of the FS ~licitly state
the "decision basis" for each criterion with a site-specific rationale
provided in Appe1xiix c.
COmment 34:
In-situ sta}:)ilization shcW.d be carried fonlar'd for further analysis.
(p 21, item ee)
Response :
As previously discussed, in-situ stabilization of plant soils ani .
pond/stream sediment was el:iJninated frcm detailed consideration, ani
therefore there is no need to identify the associated processes ani
costs .
Comment 35:
'!he caver design should be m:xlified to include a less expensive mix of
locally available materials. (p. 21-22, item ff)
Response :
It is acceptable to alter the precise ~11t-'V'~jition of the multilayer
cap to use ~ive, locally available m.\terials, provided that the
~ility of the cap ani establishment of a protective vegetative
caver is not cha.n:1ed. '!he revised cap design prop::>sed by Velsicol
will be considered ani could be used instead of the ''mxiel'' nul tilayer
cap specified in the FS report if it is detemined to be applicable.
Camnent 36:
'!he ~ter treatment system requires bench-scale tests, a pre-
treatment system, air stripping, an:l possibly pretreatment for iron
ani man;anese removal. Also, the FS makes no provision for monitoring
ani control. (p. 22-23, item 99)
Response :
'!be conceptual design for the FS determined.. by CCIt'Iparison of the
level of contaminants present in ~W~ with the clean up
objectives, that the prop::>sed treatment SYS.'.:1U utilizinq activated
carlx;)n is adequate. Factory-assembled acti"ated carbon units are
~nmn
-------
equipped with proper controls arrl moni torirt~ instrumentation such as
pressure gauges. Based on the contaminant ) ~els arrl cleanup obj ec-
tives, air. stripping is not determined to n~("..essaIy. Extracted
. grourxlwater is not likely to have high suspt;'rded solids warrantinq .
filtration prior to activated carbon absorption.
COmment 37:
No grourxlwater collection system should be built, but if one must be
built, it should eliInir1ate the proposed western. French drain. '!'he .
western drain would irrluce migration of contaminants from beneath the
5/6 Ford arrl contaminate the areas west of the ponj. (p. 23, item hh)
Response :
'!he grourxlwater interception system does influence grourdwater con-
taminant migration. It cannot be true, however, that the western
trench can mbilize contaminants which are otherwise .imnd;:)ile. Like
the eastern trench, the western trench only captures mobile, liquid-
phase contaminants. It also cannot be true that the western trench
cculd UxhJce additional grourxlwater contamiration west of the 5/6 Pcrx:l
and the trench itself which would be located iImnediately adjacent to
the waste unit, in an area already affected by contaminant migration.
'!he trench 'NCUld create a local grourxlwater divide, across which
contaminants would not travel. As for the proposal to build a single
trench only to the east of the 5/6 Pcrx:l, it has not been demonstrated
by Velsicol at this tilne that the east trench could capture con-
taminants fram the west side of the 5/6 Pcrx:l.
Comment 38:
FS cost estwtes shc'uld show quantities an:l unit cost for each line
item. Costs should reflect the local prices for local labor am
materials rather than national averages. (p. 23-24, item ii)
Response:
At the ~al design stage it will Weed be necessary to show
explicit quantities, unit costs, an::! local pri~. For the FS stage,
however, such an exercise would contriblte :.ittle to the alternative
sc:reenin1 process. 'Ihe goal in the FS is to develop order-of-magni-
tu::ie costs to assist in relative cx::rrparison of the al temati ves. A
refined cost analysis would not be necessary to achieve the goal of
the FS.
Ccmment 39:
'!he Cleanup Objectives are not sufficiently docume.nte:!,
jj)
(p. 24, item
AOOIO
-------
u
Response:
Cleanup CiJjectives preseJ'1t.Sd in Table 6-7 am 6-8 am the. raticnale in
' ~ C are based on the evaluatia'1 of site CXI"1tamina.tia1 by the
CJ:1r am ~PA groups within IEPA. '!he decision basis for each
c::hemical is cited in these tables.
Q...8..-PJt 40:
HazardaJs substances - not M7'.ardous waste - is the pl~ tezm for
the materials at the Velsicol site. (p. 81, item 1)
Response:
'!he more general tezm is hazaroous substances. No dete1:minatian has
been made for the p.u:p::ses of this CERCIA study if soil/sed. contamination would
qualify as "hazardous waste". RCRA IIHazardous Wastesll have been util ized, gen-
erated and dis~osed of within the plant area.
~~41: .
'!be pl~ reference to CERCIA is not SUbcart F Section 300.66, bIt
instead Section 300.68. (p. B2, item 2)
Response:
'!be CYlaIa::nt is correct,. ~ B ccntains correction pages for the
affected pages.
a....'¥I~ 42:
Velsicol will no lager be a chlordane productia'1 facility, so refer-
ences to active mamfacture will not be Wll..,ct. (p. B2, item 3)
Respa~:
At the time the FS was written, the facility was to remain open. It
W1CUld require ~saIy expen:titures of resoaroes arxl time to retro-
actively prepare an altered FS to reflect the closin;. Instead, this
addendum, the RX>, am the ~j al design will, address the iJIpact of
the plant closin;. ,
o .,~.~nt 43:
Proc::-cs wastes, not hazardous wastes, were stored in the pc:II'X3s.
83, Item 4)
(p. .
Response:
'!he p~ wastes mayor may not be hazardous wastes, bIt clearly
are hazardous su1:stances for the p.u:p::ses of this CERC:!A study.
AOOIO
?n
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Comment 44:
'!be 'NOrd significant is. an unduly vague description of soil con1:alnir1a-
tion. (p. B3, item 5) .
.Response :
Table 1-3 of the FS contai11S quantitative measures of the extent of
soil cont:am.i11a.tion.
Comment 45:
'!be 2 am 4 Ponds are not RCRA hazardous waste porx:Is, even if they
have RCRA~ll!Jliant nmitori.t'q wells. (p. 53, item 6)
Response :
Regardless of whether the penis are RCRA hazardous waste penis, their
zrcni toring system does conform to RCRA c:crrpliance mni tori.t'q require-
ments. '!he RCRA mni toring requirements are relevant am appropriate.
Comment 46:
'!he excavated soil will not contain haZardOl"S waste, so it need not be
stored in a RCRA cell. (p. 84, item 7)
Response :
'!be agency could offer arguments for classification of these soils as
hazardous waste, but in any case, the RCRA requirements are relevant
am appropriate, reg?rdless of applicability.
Comment 47:
'Ihe soils are not hazardous waste, so RCRA lam bans 'NCUld net apply.
(p. 84, item 8)
Response :
'!he refereJ lea to lam ban restrictions is included as a C01"ISideration
for acceptanc:e of wastes by an off-site larxi disposal facility.
Lan::ifill operators may tend to be cautious in their inte%pretation of
lam ban regulations.
O:nmnent 48:
'!he soils are not hazardous waste, so RCRA larxifill grourx1water
mnitorin:] requirements would not apply. (p. 84, item 9 )
ADDID
-------
Response :
'Ihe RCRA requirements are relevant ani appropriate.
o:amnent 49:
'Ihe soils are not hazardous waste, so RCRA landfill mini:mum technology
requirements would not apply. (p. BS, item 10)
Response :
'Ihe RCRA requirements are relevant ani appropriate.
0::Imment 50:
'Ihe soils are not hazardous waste, so RCRA landfill requirements 'NCUld
not apply. (p. BS, item 11)
Response :
Again, the RCRA requirements are relevant ani appropriate for con-
sideration of the new on-site cell.
Ccmnent 51:
'!he soils are not hazardous waste, so RCRA landfill grourxiwater
mnitorinq requirements would not apply. (p. BS, item 12)
Response :
Again, the RCRA requirements are relevant ani appropriate ani can be
used as a basis for grourxiwater mcnitorin;.
Ccmunent S2:
'!be soils are not haza.rc:!aJS waste, so RCRA r.equirements 'NCUld not
apply. (p. B6, item 13)
Response:
'!his has been addressec1 previously in response to several camnents.
'!be RCRA requirements are relevant an::! appropriate.
camnent S3:
Regulato%)' uncertainty is no reason to view deep well injection
unfavorably. (p. B6-B7, item 14)
AOOIO
??
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Res1xmse :
Deep W'ell injectiOl1 has historically fallen un:ier OC1rri'lex restric-
tions. BeCause the grcurxiwater treatment scheme is envisioned to last
at least 30 years, it is Prudent to c:x:msider whether the ~lemented
solution will remain feasible for many years into the future. More
specifically in the near-tem, there are concems about the integrity
of the existirg injection wells at the Velsicol facility. If the
wells are not secure, their regulatory accept'..ability for permitted
operation could not be guaranteed.
Ccmment 54:
'n1e 'words heavy and minor are vague.
(p. B7, item 15)
. Res1xmse:
....
Table 1-3 of the FS contains quantitative measures of soil contamina-
tion.
AOOlO
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* * * * * * * * * * * * * * *
* * * * * * . * . *
* * * * * * * *
* * . * * * *
Copies of this responsiveness summary were mailed in October 1988 to those who
registered at the hearing, to all who sent in written comments and to anyone
who requested a copy.
The following items are available for examination and review:
1.
2.
3.
4.
5.
6.
Copies of the Public Hearing Notice,
Proposed Project Plan,
Transcript of Hearing,
Public Hearing Attendance Record,
Hearing Record Exhibit List of all letters, documents and notices, and
All letters, documents and notices contained in the Hearing Record.
For Further Information
Questions about the hearing process and about access to exhibits should be
directed to the IEPA Hearing Officer, John Williams, 217/782-5544.
Questions about the RI (Remedial Investigation>, the FS (Feasibility Study> .
and the Proposed Plan should be directed to the IEPA Project Manager, Kurt
Neibergall, 217/782-6760.
Copies of the transcript of the July 27, 1988, hearing can be purchased from
Maninfior Reporting, 1612 Lafayette, Box 1036, Mattoon, Illinois 61938, or
phone 800/346-2986.
Additional copies of this responsiveness summary are available from Bill
Hammel, IEPA Community Relations, 217/782-5562.
Signed:
Signed:
Agency
Date:
cl1 Lii.,J;,- J. 6)
, 1988
Illinois Environmental
2200 Churchill Road
Post Office Box 19276
Springfield, Illinois
Phone: 217/782-3397
Protection Agency
62794-9276
BH:bjh/sp/2666j/l,8
24
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APPENDIX C
ADMINISTRATIVE RECORD
VELSICOL/MARSHALL, ILLINOIS SITE
-------
APPENDIX C
ADMINISTRATIVE RECORD
As of September 21, 1988
The following lfst of documents were available for publfc inspection at the
Superfund publ'c repository located at the Marshall Public Library fn Marshall
and at the IEPA Community Relations Offfce in Springfield. Draft documents
that were shared with Velsicol (responsible party) were also placed in the
public repository. Draft documents in the repository were subsequently
replaced with final documents.
TITLE
Various Background Articles
SIte Maps
Site Inspection Report
Velsicol Chemical
Site Visit June 17, 1983
Why Velsicol?
Newscllp Series
. Marshall Independent
Review of Velsicol materials
re CappIng Program for 5/6 Pond
Preliminary Assessment
Letter to W. Child - IEPA re:
Review of S,te Activities
re 5/6 pond
Hydrogeologic Study
Monitor Well Installation
Velsicol SIte Marshall, IL
Il1;nois F'sh ContamInant
Monftoring Program
Memorandum of Agreement
Memo to fIle re:
Vels;col - Technical Reports
4/16/85 Meeting
AUTHOR
DATE
00/00/00
00/00/00
CEMays - USEPA
Me Toole
82/09/07
83/06/27
Greenpeace
GGravem1er
84/00/00
PAGES
8
4
14
2
84/05/07-24 15
JPGibb - IENR
84/08/27
RLang - IEPA
JSBrown - Velsicol
84/09/20
84/10/03
85/00/00
85/05/00
MNienkerk - IEPA
85/05/01
4
28
9
113
38
3
-------
TITLE AUTHOR DATE PAGES
Statement of Work for a IEPA 85/05/1 0 31
RI/FS at Ve1sico1 Chemical
Corp. Attachment I
Memo to file re: Agency Position JFrank - IEPA 85/09/26 13
regarding Disposa1 Water from
IEPA Well Insta11ation Activities
at Ve1sico1
Newsc1ips from GGravemier 85/1 0/03 4
Marsha11 Independent
Personnel Safety Plan IEPA 85/10/28 96
Ve1sico1 Chemical Pla~t
Revision 2
Community Relations Plan BHanvne1 - IEPA 85/1 0/29 19
with cover letter
Hydrogeological Work Plan IEPA 85/11/01 16
RI/FS Ve1sico1 Site
Letter to WRad1inski-IEPA re: KDYeates - USEPA 85/11/05 2
Approval of Site Safety Plan
with minor changes
Fie1d Sampling Protocols 86/02/00 12
Newsclip from 86/05/05
Marshall Independent
Press Release: Start BHanvnel - IEPA 86/05/06 2
of geophysical i~vestigations
Geophysical Survey Report RFWeston, Inc. 86/06/00 200
Ve1sico1 Chemical
Work/QA Plan Short Form RFWeston, Inc. 86/07/18 61
Ve1sicol Chemical Corp.
Health and Safety Plan RFWeston, Inc. 86/07/25 129
for Ve1sicol Site
Project Outline and Proposal RFWeston, Inc. 86/07/30 66
Report for RI/FS at Ve1sicol
Chemical, Marshall, IL
-------
TITLE AUTHOR DATE PAGES
Preliminary Report for RFWeston, Inc. 86/07/30 108
Velsicol, Marshall, IL
Sampling and Analysis Plan RFWeston, Inc. 86/1 0/00 S4
Velsicol Chemical Corp.
Marsha 11, IL
QAPP Velsicol Chemical Corp. RFWeston, Inc. 87/01/08 196
Marshall, IL Site
Press Release: Start BHanmel - IEPA 87/02105 2
of phase II of
environmental investigation
Chlordane IEPA 87/03/00 2
Chemical Information Sheet
Phase I Hydrogeological RFWeston, Inc. 87/04/09 185
Memorandum for Velsicol
Marshall Site
QAPP Addendum for Air Sampling IEPA 87/06/00 22
and Analysis
Velsicol Chemical Corp.
Marshall, IL Site
Press Release: BHanunel - IEPA 87/06/18 2
Final phase of
environmental investigation
QAPP Addendum for Fish Sampling RFWeston, Inc. 87/07/24 82
and Analysis
Velsicol Chemical Corp.
Marshall, IL Site
Phase II Technical Memorandum RFWeston, Inc. 87/07/31 192
for Velsicol, Marshall Site
Mini-air QAPP RFWeston, Inc. 87/08/25 31
Environmental Risk USEPA 87/11/00 50
Fact Sheet #1 RI report BHanunel - IEPA 88/01/00 2
Press Release: BHanunel - I EPA 88/02103 2
RI Public Meeting
Remedial Investigation RFWeston, Inc. 88/02119 300
Report, Velsicol Site,
Marsha 11, III i noi s
-------
TITLE AUTHOR DATE PAGES
Remedial Investigation Report, RFWeston, Inc. 88/02119 300
Velsi col Site, Appendices
Request for Applicable, RFWeston, Inc. 88/03/03 42
or Re1evant and Appropriate
Requirements for Remedia1
Alternatives, Velsic01 Site,
Marshall, Illinois
Addendum to Remedial RFWeston, Inc. 88/03/10 60
Investigation Report,
Section 8, Velsic01
Site, Marsha11, Illinois
Newsc1ips from GGravemier 88/06/16 2
Marshall Independent
Newsclip from TBear 88/06/22
Paris Beacon News
Newsc1ip from RHarrison 88/06/23 1
Casey Reporter
Fact Sheet #2 BHammel - IEPA 88/07/00 12
Proposed Plan
Proposed Plan KNeibergal1 - IEPA 88/07/12 22
Public Comment Feasibility RFWeston, Inc. 88/07/15 165
Study, Velsicol Site
Marsha 11, I11 I noi s
Newscl1p from GGravemier 88/07/18 2
Marshall Independent
Press Release: BHarme1 - IEPA 88/07/19 2
FS Publ'c Hearing
Transcript of 88/07/27 58
FS Hearing
Newscl1p from SLough1i" 88/07/28'
Tribune Star
Comments on RI from 88/08/12 122
Conestoga-Rovers and
Associates Limited with
Responses from RFWeston,
Inc., 9 documents, beginning
January 12, 1988.
-------
TITLE AUTHOR DATE PAGES
Newsclip from RHarrison 88/07/28 2
Marshall Independent
Draft Statement of Work- CRA, Ltd. 88/08/29 36
RD/RA, Velsicol Plant Stte
Marshall, IL
Proposed Groundwater Collection CRA, Ltd. 88/08/29 23
Drain Design Calculations
Vels1col Plant Stte,
Marsha 11, I L
Addendum to Public RFWeston, Inc. 88/09/02 72
Comment Feasibility Study,
Velsicol Stte. Marshall, Il
CRA Drain Design Evaluation- RFWeston, Inc. 88/09/02 2
Velsicol/Marshall Site
Final Statement of Work- CRA, ltd. 88/09/12 38
RD/RA, Velsicol Plant Site
Marsha 11, I l
-These documents are not tn Marshall Repository but are available for
inspection at IEPA (Springfield) and USEPA (Chicago).
WH:dls/2656j.sp
-------
APPENDIX A
FIGURES AND TABLES
FOR
ROD DECISION SUMMARY
VELSICOL/MARSHALL. ILLINOIS SITE
-------
~
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.FlGURE 1
.
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MtoNgln
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0. (' - 111 -- AMIII 11.. a II'f .
o 80 '00
J ... I ill .. . .. .. t . ..
. I , Y' .
o » II
0.... ...... AMlllIU ..
KENTVCKY
r;;) Le."'"
~. In"" HIghw81
Gu.s.AoutI
[!] Stall Ao8d
LOCATION MAP. VELSICOL CHEMICAL CORP.. MARSHALL IL.
-------
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FIGURE 2
'"
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... a z . I:
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leale
I
'OOD 2000 3000 .. 50lIO IOCIO ?OaO'rn WI'
VICINITY MAP. VELSICOL CHEMICAL CORP., MARSHALL, IL
-------
~
..::.. :.:.. ..::~~::~:::.:.. V8flicol Chemical Corporation........"
:~ ,,::/~, , '\ " -- ~
: :~...."~-~. - .
1;' ~,o
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;1. ProdUcti~;, F.Cilit/:';;'~, ~ .. ,
I' ;: if, '/':8: -.. ~ : ; '~t:l;;!:f > h
II 5/6 Pond 00 F. ..: . i .'~ii~ >:.
:; ~ 8 8 . 0 0 ... o:! . ; .'
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: 1/
o Legend
o 0 AboveoGround Storage Tanks
DC Buildings
Site Boundary
- -
~
CD
0,
a:,
~'
c. '
~
<3
-:
o 400 800'
~ ,
Sea'e In Feet
.
N
Source: FranCI. AaIOC. Pin., IL.
FIGURE J-t. SITE MAP VELSICOl CHEMICAL CORPORATION.
.. - .. - _. . . . .
-------
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'nter.tate 70 / i/'"
..~n,;aL~
...-.... . ...- ,
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G218M'/:J !! "::,,).0 : ~':~.\ ~ I MI
i " I:. . 1:1:~ . Q. ,.. L L --
;iG20SM ~ l2"7~:" :.1. ~ii.~oJ::
Li'0J ..f:: 0 '
G214:e G2~~ -- .dt!:'~~if."".:
G208M ii ! ....~' "~,:.>,,,.. ::
eD ~G215M /Ja~: /! ~~. ,
"')')~~ _~G203~'" ,..~;":",, :::.i'", ~<-~~
"c7 Tributary L - . - .,...' ~qf#
G211M D ,.,,' ~~I
~ D G209Mwnmrr:~ ,..., ~~
it L -- ~.!.. ~e
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'. ~
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.' ....:,:_...::~~;..::,Val8iCOI ChemicaJCorporation-.....(
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Legend
~ Locations of Monltortng Wells
'nstalled and Sampled as Part
of Thl. CERCLA Investigation
"
o . .00 800
~ 1
, Scal. In FHt
..
N
Sourc.: Francia AaIOe.. Plri..IL
-.... .-- n
-------
Velsicol C. C. Marshall, IL Site
~ELEc:rEt:> Alternative
Conceptual Plan
"
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~.. 1 ~-..: 1 ~ Consolidation of Stabilized Wastes:
'/:. ~ /:.;- Cover With RCRA Multimedia Cap
Groundwater Interceptor Trench;
On-site Treatment and Discharge
-------
VEl.SICOl. CHEMICAl. CORPORATION
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LEGEND
8 SURFAce SOIl. SAMPLE
. 8-FT SOIL BORING
,
,
.
N
'..333'
FlaURE 6
DIVISION OF PLANT AREA FOR SOILS ReMOVAL
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FIGURE 6 - EXPLANATION
DIVISION OF PL\NI' AREA sons
~le Taken
Section Descri'C'tion From Section
1 ~ Area 55108, 55110
2 central Prcduction Area 55106, 55107, SB7-7
J QUoreane Prcducticn Area SS112, SB76
4 R.esirVBlend.inq,lStc~ SB72, SB73, SB7 4, SB78
5 Fcmner ~ Storage Tanks SB79
6 D1cyclo Storaqe an:! Fomer iH: 55109, 55111
Storage Area
7 BF3Area SB7S.
I
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J : MANAGEMENT I
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G21SM 81 I
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I 1 I G20IS.M,L.,D
.~ 1 FOAMEA ~ G20SM,L.
I WASTE ',G217M
~ I L.AGOON ~-~. 8G218M
I ' G214M,08. I '
I L jG207M,L. ~ /'
L:.-\:, 1 . I / /
r~A. ~G208M.~.O L-- /
'" G213M,O. . I ,,/ / l
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A-6A,8~MANAGEMENT, '. N -
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LEGENO
--- PAOPERTY L.INE
-...-... STAEAM
8
o
PAOPOSED PIEZOMETER IN
. O\lEA8UACEN
EXISTING AI MONITORING
WEL.L. NEST
EXISTING ACAA MONITORING
WEL.L. NEST
.
figure '7
HYDRAULIC MONITORING
-------
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v
---
G220M,L @ II
-ll
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o 100
300ft
L.EGENO
@ :~~S:fSTMONITORING
., ~~~IN:E;'NITORING
f
WATE Igure n
R QUALITY MONITORING
-------
\
TABLE 1
IW«Z OF SEUX:rm Q!EMICAL o:mTI'It1mrS
LJII"I'1'.L;a;u 1a 'IHE VELSICCL SI'm IN ~
West: of Plant. Area. Plant. ArM..
Shallcw w.u. Ceep Wells Shallcw Well8 Deep Wella
Volatile ~ (\:all) (\:all) (\XtIl) (\Xl /1)
1,2-oic:hlar08t:hen8 He ND' ND-l5J' ND
1,2-Cic:hlcrcethane ND ND ND-14J ND
Benzene ND-U NI>-2J ND-280,000 NI>-3. 3J
&; L.IIla ~than8 ND ND ~7 Nt)
2-a.rtancne ND NI>-66 ND-120 NI>-210
carbon Cisulfide ND ND ND-1300 ND
Caz1::)cn Tetrachloride ND ND-1J NI>-210,000 Nt)
Ollorobenzena ND-2.SJ ND-2.lJ ND-UOO ND
Ollorofcrm -. NI>-4.9 NI>-6 NI>-14,000 ND
EthylJ:enzena He ND ND-UOO NI>-l.lJ
2-Hexancne ND Nt) ND-130 Nt)
4-Methyl-2-pentancne He ND ND-470 ND
Stynna ND He NI>-1800 He
Toluene ~.7 ND-2J ND-12 , 000 ND-1. ~
Tric:hlcroet.hylene ND He ND-6. SJ Nt)
Xylenes (Total) ND ND ND-3000 Nt)
e
AcemJ:ht:hen8 1m He NI>-6J' He
Seczo (a) pyrena He He ND-2 1m
Benzoic Acid ND Nt) ND-220J' He
Benzyl Alechel He ND-12 ND-170 , Nt)
Bis (21thyl h8Xyl) phthalate NI>-890 (1) ND-430 (1) ND-14J ND-2J
aztyJbenzylphthalate ND-22 ND-2S NI>-4J ND-2.lJ
Cibenzoturan 1m ND ND-3J He
1, 2-oic:hlQt~lZena He Nt) ND-56 Nt)
1, 3-Cic:hl~~!.Zena NO Nt) NI>-12 Nt)
1, 4-Cic:hlQl~", He NO ND-UO ND
2, 4-Cim8t.'1yl~ He ND ND-4J ND
Cimthylphthalata ND-1J Nt) ND ND-19
4, 6-Cinitro-2-methylphenol Nt) ND-6 Nt) ND
Ci-n-aztylpht:halata ND-2J NI>-2J ~ ND
Di -n-octylphtM.late ~ NI>-lS ND-14 ND-2l
Fluorene Nt) Nt) ND-S1 Nt)
HeY'I("'hlorocyclopentadiene ND He ND-100 ND
Hexac:hloroethaM He . ND ND-13 ND
2-Methylnaphthalene ND ND ND-UOO ND-2J'
Iscphcrone ND lID ND-220 ND-2J'
Na;hthalena Nt) NI>-O. SSJ ND-2200 ND-SJ'
Nitrobenzene Nt) Nt) NI>-40 Nt)
-------
I
)
J
r
r
P8ntachlorophsnol
I~
\
TABLE 1 (continued)
IWa:aE OF ~~~ OiEMICAL ~
Cl:;UJ ~I Po:]) Kr 'mE VEtSICDL srm IN ~
W8£ ot Plant: ArM.
ShallCM Wells Deep Wella
(al/l) (u:r/l)
Plant: ArM*.
Shallcw Walls Deep Wells
luall} (u:r/l)
NO
NO
Nt)
ND
NO
NO
~3J
~
ND-610
~2J
NO
He
I Pesticides NS NO NI>O. 25.1 ND-O.65
. ChlorCans
A-EHC NS NO NI>-9.7 NO
I D-EHC NS 0.18 ND-85 NO
T.ransnanoc:hlcr 1m NO Nt) ND-O.23
I Inoraanics Nt) NO Nt) Nt)
. Antimcny
Ar-~ ND-2.8 ND-25 NO ND
!! JID ~32S ND-192 ND-586 ND-51
BeryUium ND-2.2 ND-3.1 ND-2.S NO
a... ...1 ND-41,700 ND-4SS ND-lS7 ND-179
o.~ium ND-5.S ND-3.0 Nt) NO
Qu:'aUum ND-18 ND-ll ND-lS NI>-14
CCbalt NI>-O. 6 ND-6.0 ND-60 1m
~l" ND-32 ND-14 ND-12 ND-12
Lead ND-13 . ND-18 ND-7.7 NO
Mercury ND-O. 4 ND-O. 3 ND-O. 4 NO
N~l ND-9. 9 ND-104 ND-300 ND-104
Selenium ND-6. 3 NO 1m 1m
':hall1um 1m ND-!5.! ND-2.0 ND
VaMd1u:za ND-14 ND-10 ND-13 ND-4. 4
Zinc ND-2160 ND-148 ~U4 ND-1l4
u
Nan:: ~ter mcnitorin;J WUs west 01 the plant area 1:x:l\Xla the tollcwinq W'ell
locations: <:8202, G203, G206, <:8207, G209, G211, G212, G213, G214, G2lS an:!
G216.
**Gro.n1water mcn1torin; walls in the plant area 1:x:lude the tollcwinq
locaticns: G201, G204, G20S, G208, G210, G217 and G218.
NS - Not saupled.
ND - Not c!etec:tecI.
J - Value reported is greater than the instroment detect.1on limit, bJt less tl1an
. the required ccntract detection limit.
e.. -l14M and D wells had high val\JeS only durin; one Ii1ase ot ~lin; and was net
c!etec:tecI durin; the other round ot saD;)1in;. High values obtained may be due. to
smrpJ,e CXlntamimtion.
-------
\
\
TABLE 2
IW«Z OF ~~ 'J.!!LJ amaCAI. a::tS1'I'ItJ!Nr
11Jt~I'''I ..'..:1 J ~ '%HE VEtSIan. srm IN SOTT~
IqriaUtural land
0-1.5 tt >1.5 tt
(ualka) CuaIka)
VolatjJ.e ~
Benzene
2-axtancna
CarDon Disulfide
Ethylbenzene
Tet:rachloroethylene
Toluene
Styrene
Xylenes (Total)
NO
ND
NO
NO
ND
NO
NO
ND
Acenapthene
Acenapthylene
Anthracene
Benzo (a) anthracene
2-Q1lcrcph8ncl
D1-Ethylphthalata
Hexad1lcrc::t:ut.aa1ene
bis (2-ethylh8xyl) phthalate
1\1tylbenzylphthalata
~
D1J::Ienzotunn
D1-n-tJutojlphthalata
Di-n-octylphthalate
Flucnnth8n8
Flw._. .
~hlcra::ycl~
2-Methylnapthalene
2-Methyl~
Naphthalene
N-Nitroeod1~lamine
ibenant:hrena
ihenol
Pyrena
ND
ND-61
ND
1m
ND
ND
ND
NO
NO
NO
ND .
ND-170
Nt)
ND
NO
ND
ND-160
ND
~300
NO
ND-200
NO
NI>-98
1
ND
ND
NO
ND-l
ND-2.1
ND
NO
ND
NO
NO
1m
ND
ND
ND
ND
NO
ND
NO
~130
ND
-ND
Nt)
NO
ND-79
ND
ND-160
ND-96
ND-UO
ND
~51
I
I
B
C
Plant Area I
0-1.5 tt >1.5 tt M...
Cualkq) Cu:Y3a:r~ ill
ND-180,000
~14J
ND-2J
ND-340,000
ND
ND-710,000
ND-180,000
ND-280,000
ND-5700
ND-86CJ M.:
ND-7 U
ND-5200
:'8800 a
ND-6600
~lO,O I
ND NI>-970 I
ND ND-800
ND ND-28CJ
1m Nt>-19Q] I
ND-82J ND-82J
ND ND-1SQJ'
NO ND-S7J
ND-22aJ' ND-4600 I
~2SaJ' ND-23o.J
ND NI>-99CJ
ND ND-lSOO "I
ND-21OJ ND-32CJ
NC-3201 ND-860.
ND-81J ND-14Q]
ND-52J ND-3600 I
NO ND-1600
ND-760 ND-30,0
ND ND-UQ] f
ND-120,OOOJ 670-52K
ND-200,OOOJ ND-42J
ND-37aJ' ND-10K I
ND Nt):
ND-13aJ' ND-l'~Q
-------
TA8LE2 (continued)
~ OF m:'T'~:1~ a!EHICAI. cx:tmI'I'UENIS
" Ut;JOl'A,;' ~ AT 'IHE VEtSIan. srm IN SOIlS
Agria1ltural Iand Plant Area
0-1.5 tt >1.5 tt 0-1.5 tt >1.5 tt
~ (uaIka) (ual1-10,~0
Heptachlor ND-17 ~18 ND-4300 ND-370
Heptachlor Epcxide ND-56 ND-17 ND-UOO ND-240
Alpha ~ordan8 ND-9. 6 ND-13 720-4200 ND-6400
~ ~0rdan8 ND-25 ND-5.3 860-7200 NI>-4S00
0Xychlarc1ana ND-3J 1m 1m NO
Cis-nancc:hlcr ND-93.J ~.3J ND-1000 ND-lS~
TransnanCChlcr ND-9. 3 ND-16 280-4400 ND-UOO
~~at'1. B1ph~ls (~)
Haw dstected
~L~ (traJ)(a) (traJ)(a) lm:rll67 X 21-83
~"UZI ND-6.3 0.3-U X 1-7.2
" O'1rc:ID1um 4.4-30 ND-41 X ND-23
CcbUt ND-28 ND-19 ND-8.9 ND
~C" 7.2-13 5-20 . X 5.6-19
Lead 13-15 10-15 X X
Me:a:y ~.38 0.1-0.2 0.12-1.2 NtH).42
Nidcal ND-21 3.7-22 X 9.6-25
Selenium ND-2.4 2-4 1m NO
Silver 1m 1m 1m 1m
'Ihallium NO 0.3-0.5 NO NO
. vanadium 13-47 24-44 X 16-49
Zinc 20-54 16-61 X 40-125
K- Moatiply the results by 1,000.
NO - Not dstected.
J- Value reported 15 ;reatar than the i.nstNDBnt detection limit but less tbar:
required o::Int:raCt detection limit.
X- bsUlts are invalid due to spika and duplicate analyses net within ~.Iut...\'/l
limits.
-------
TABLE 3
JWm OF ~J\;j,1:;U amlICAL a:tmI'lUENIS
Vt;TV:~I"}O:U Nr ':tHE VEISIa:n. SITE IN
P.:H) WAXER AND SECIMENrS
PI:n1 2 Pend 4
Watar ~i1ft8'tt Water ~i WIA"lt
Volat:Ue ~ (u::r/l) (ualJa::) (u::r/l) (uaJka)
Benzene 8.2-8.8 UO NO 3J-7J
Carton Disulfide NO NO NO ND-2S
O1larofam 1.JJ-1.2J NO NO ND
EthyJJ::8nzene 1m 120 NO ND
ToJ.uena 4-4.2 NO NO NO
Xy1enes ('l'ctal) 1m 350 NO ND
Ac8napthsne 1m 380J' Nt) NO
Bis (2-et:hylhexy1) Pltnalata JJ-4J Nt) Nt) ND-7JJ
Onysena NO ND 1m ND-5SJ'
Di-n-tuty1phthalata Nt) 1m 1m 4JJ-48J
Flucranthsne 1m ND Nt) 38J-5JJ
Flu.....118 1m 760J' 1m ND-53J
2-Mst:hy1napbthalene ND 4600 Nt) ND-220J'
Naphthalerw Nt) 15000 1m 440J'-920
~ ND 1400 1m 96J'-17o.!
Hwnol 1m 1m 1m NO
Pyr8na ND 340 1m 83-UO
~
~arcan. 45-50 24,OOQJ' ND NO
Ir LJ-L '-'C:aJU.SaI (m:r/l) (m:r/1
-------
TABLE 3 (continued)
R»GE OF m:!TJi ~I."~LJ a!E2aCAL a::tmI'It.1!Nl'
(,
Ul:iJ.:t'A; I 'P:U AT 'I'HE VEISIcx)L SIT!: IN
tam ~ AND smIMmIS
Pond. 2 Pend 4
Water ~i~ Water ~ i 'PftAPlt
!no,,- '-Ianics (u::r/l) CuaJm) Cu::r/l) luaJ)(];)
~ ND 19 ND 14
!sad ND 30 ND Nt)
Mercury ND ND ND Nt)
Nickel ND ND Nt) 25
Selenium ND NO Nt) NO
SUver ND 1m NO Nt)
'nW.lium NO ND NO Nt)
Z.1nc NI>-31 76 NO NO
"
ND - Not c1etected.
J - Value reported .is greater than the 1nst:ument detect.iat limit b.:t less
than the required CXI1tract d8tecti~ limit.
..
-------
TABLE 4
JWIZ OF ~]:'j "IUJ amaCAL ~
tII:i!V: I'J'I-D AT 'IHE VEISICCL SI'IE :m tJNN»!!D U-98 ND
Toluene ND ND N1>5. ~ 2J
Tet:rachlcr0ethen8 ND Nt) ND 2.1
~lenes (Total) ND ND ND-100 1m
-
SemivoJ.AW.e ~
Acenapt:hene ND ND 2100"-4600 Nt:
.
Anthracen8 1m Nt) S3J-560 ND
Senzo (a) anthracene ND ND 53J-560 ND
Senzo (b) flucranthene ND ND 72.1-1800" 56J'-lOc.:
Sis (2-et:hy1.~1) phthalate ND-41 N1>18 N1>310 N1> 11 OJ'
~ ND ND Nt>-97J NI>- 3SJ'
C1benzoturan ND ND NI>-2500" ND
Di-n-b.1tylphthalate ND-132 ND 1J-132 UQJ'-31(
Ci.,~lph.thalata ND-2J ND ND-4SJ N1>56J'
Fluaranth8n8 Nt) ND ND-28QJ' ND-82.1
Flu...aI~ ND Nt) ND-4300 Nt)
2-Methylphanol ND 1m Nt>-910 Nt)
Naphthalene NO ND NI>-99K NO
N-Ni~phenylamine Nt>-4J' ND-JJ ND-750 52J-92]
P8ntachl~ ND-s:T -- ND ND Nt)
ihenanthren8 Nt) Nt) ND-5500 Nt)
Hwncl ND-51 NO ND NO
Pyrena ND-1J ND N1>2300 NO
~
QUordane ND ND ND-250,000 350-63:
-------
I
'..
1
,
\
F8uibUit:y ~
V8laicol slta
S8:ticn: 1
Data: 1.5 July 1988
P8g8: 1-27 ot 27
<,
TABLE : 4 (0:r1tUIJ8d)
RNIZ OF ~ J:'J: ~.1.1:.1J QlEMIC'AL a:::NSTI'IUENrS
U:;.U:A.:.1.1:.1J Kr '!HE VEtSIcx)L SITE IN tHW4m ~
WATER AND smnmns
Creek
Water Bac::kI;rc:I.1r ~ i 1NM"ft BadcgraJrd
Inoraanic:s (\1:1/1) (\J:J/l) * (m:r 1m) (rralka)..
Ant.imrty ND NO ND ND
Arsenic ND NO NI>-11 ND
Barium NI>-13~ NO 42-196 111-196
Beryllium NO ND ND Nt>-l. 3
Borc:r1 ND-56l NO ND-80 ND-60
~]um NO ND 3.9-11 ND-9. 2
Olranium ND NO ND-31 ND
()X)al t ND ND ND-32 ND-9. 3
O~ ND ND 6.5-20 9.7-24
Lead ND-4. 6J' NI>-3.2J NI>-21 NO
Mercmy ND-O.21 ND-O.26 ND-O. 13 .ND
NicJce1 NO ND NI>-42 12-26
Selenium ND NO ND ND
Silver NO ND-IO ND-1.5 NO
'Iballium NO NO ND ND
Vanadium NO ND 1C>-49 34-210
Zinc ND-123 21-53 NI>-105 58-82
,
'.
NO - Not detectecl.
J - Value reported is greater than the instrument detecticn limit b1t
less than the required c:aJtract detecticn limit.
* - Upstream of Velsiccl site (semple swaO).
** - Upstream ot Velsiccl site (sanpl8 SD93).
K - ~ tiply the results by 1000.
-------
TABLE 5. .
.uauM. EJfQUIE ...IIIAYS
m51a1. SIIE
CaUIIrwc ~
ec.c..innt I'd... InnPIrt [JDJan fIolnt E.coue lied. . fQIj ..IG'I
0.1-.4811 IIanI
I
........1iItM .do.~ Sedi ti to .... cIDIwn c:r.t ... u.-t trlbUy . ...... tClilrvllltlcn an--. .... c:hllct.
18fi.,. In cred:
SIdi8Ina to ..ter cIDIwn flsIt itnIIIId trlbUy 'fWllltlarvbt~ AlJMlc 0f"IIIr\1- ....
tratlen pqII. .... m.- fl.
CcIrC8II..... .11. Direct antlCt If" r 11''8 0. .It. 'fWllltIClidin81 lrespuen .... adw
II8arplen ~ .ite UIief'I
Wi... or 8IdYniC8t lI'OIiien Air 0. .it. 'lNIatlen II""" ."" other
.Ite U&If'S
Im-Off Sohbill" ItnnId trlbUy l...tla'Vbl~ AIJM Ic 0f"IIIr\1- ....
In ..t.. .... tnt len ,... lID anue filii
........ In
..t..
~-'
------- |