United States
Environmental Protection
Agency .
Office 01
Emergency and
Remedial Response
EPAIROD/R05.89/090
June,989
3EPA
Superfund.
Record of Decision:
"
j
"
.~
Galesburg/Koppers, IL
U.S, Environmental Protection Agency
Region III Information Resource
Center (3PM52)
841 Chestnut Street .
Philadelphia, fA 19107 . .' ,.~,;1..
-....~
Hazardous Waste Collection
Information Resource Center
US EP~~3
.~~.:~~~.}~J07
EPA Report Collection
Information Resource Center
US EPA Region 3
. Philadelphia8 PA 19107
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n72-101
REPORT DOCUMENTATION I,. AEPOATNO. II.
PAGE . EPA/ROD/ROS-89/090
I. A8dpi8n1'1 Ace II y' an No.
4. T1\18 IIId SubtItI8
S.-';:RFUND RECORD OF DECISION
( ,sburg/Koppers, IL
First Remedial Action - Final.
7. Autllar(l)
s. AIpart D-
06/30/89
I.
I. Pwfonnng Orgenatlon A8pL No.
l'
~. Plrformlng Orgalnlzlaon NIm8 ... ~
,0. PIojllctlTlIIIIWon UnIt No.
~
". ConInct(C) or GnntCO) No.
(C)
12. SponlOring Orgenlzdon NIm8'" ~
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(~
,1. Type if AIpart . P8ItocI eo--
Agency
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15. s"",,*"*,wy ~
HI. AIIItrKt (Umlt: - w~)
The Galesburg/Koppers site is a lOS-acre area located approximately two miles south of
the city of Galesburg in Knox County, Illinois. The land surrounding the site is
sparsely populated with the Burlington Northern Railroad yard to the north, a landfill
to the east, and four residences and a lumber yard to the south and west. Farmland.
ab"" ~ these areas. .Burlington Northern Railroad. Company operated the site as a railroad
ti reating plant from 1907 to December 1966. In 1966 the Koppers Company, Inc. leased
the production plant from Burlington Northern and resumed operation of the facility.
Treatment operations consisted of pressure treatment of the railroad ties using a
mixture of creosote and coal tar or creosote and fuel oil. From 1971 to 1976
pentachlorophenol (PCP) was. used in the treatment process. Key contaminated areas at
the site include a slurry pond, a northern and southern creosote lagoon, a
PCP-contaminated lagoon, a waste pile storage area, two backfilled drainage ditches,
and two former spray wastewater fields. Contamination has been found in soil, ground
water, surface water, and on- and offsite sediment. This Record of Decision (ROD)
addresses all contaminated media. These actions, in combination with remedial actions
at the Steagall Landfill site, are intended to eliminate offsite surface water and
(See Attached Sheet)
17. DOCUIIIIrIt An81y818 .. 088afpt-
Record of Decision - Galesburg/Koppers, IL
First Remedial Action - Final
Contaminated Media: soil, qw
(i Key Contaminants: organics (PAHs, PCP, phenols)
b.1d8ntI~T-
-
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. .
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R .GPO: 1983 0 - 38'-526 (8393)
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OPTIONAL 'OAM 272 BACK
(4-77)
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EPA/ROD/R05-89/090
Galesburg/Koppers, IL
Firest Remedial Action - Final
6.
Abstract (continued)
sediment contamination as well. The primary contaminants of concern affecting the soil
and ground water are organics including PCP, phenols, and PARs.
:?
The selected remedial action for this site includes excavation and onsite consolidation
of approximately 15,200 yd3 of contaminated soil with onsite biological treatment of soil
and implementation of a biological monitoring program; construction of shallow ground
water interceptor trenches and deep pumping wells with pumping and onsite pretreatment of
shallow and deep ground water using an existing wastewater treatment system to achieve
cleanup objectives, discharging treated ground water to a publicly-owned treatment works
(POTW) for final treatment or onsite treatment should the POTW pretreatment standards not
be achieved; ground water monitoring; and implernention of access and land use
restrictions. The estimated present worth cost for this remedial action is $4,286,844,
which includes an estimated annual O&M of $170,012.
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DECLARATION FOR THE RECORD OF DECISION (ROD)
SITE NAME AND LOCATION
Koppers Wood-Treating facility
Galesburg, Illinois. .
<;
STATEMENT OF BASIS AND PURPOSE
This decision document presents. the selected final remedial action for the
Koppers Wood-Treating Facility site in Galesburg, Illinois. developed in
accordance with the Illinois Environmental Protection Act. Ill. Rev. Stat.
1983, ch. 111 1/2, pars. 1001 et. seq., CERCLA, as amended by SARA, and the
National Contingency Plan (NCP) to the maximum extent practicable. This
decision is based on the administrative record for this site. The attached
Index (Appendix C) identifies the items that comprise the administrative
record upon which the selection of this final remedial action is based.
The U.S. Environmental ~rotection Agency (USEPA), Region V supports the
selected remedy for the Koppers/Galesburg site.
DESCRIPTION OF SELECTED REMEDY
The final remedy at the Kopper's Wood-Treating Facility in Ga1esburg, Illinois
consists of the following:
Excavation of visibly contaminated soils plus a six-inch buffer layer to a
depth that ensures effective mitigation of groundwater contamination from
"hotspots" Identified on-site (north creosote lagoon, drip track,
northeast portion of pentachlorophenol (PCP) lagoon and area east of the
retort building), samp1e~ will be taken to assess these mitigative efforts.
and to confirm final remediation to health-based levels; backfilling of
excavated areas with "clean" soil, regrading of the "area of
contamination" for positive surface drainage; revegetation and maintenance
of the affected areas.
Conduct an on-site field scale biological treatment demonstration study
with a biological monitoring program. Upon successful demonstration of
technology, consolidation of excavated contaminated soils into a full
scale cell through a phased loading approach. Upon treatment of the final
11ft of contaminated soil, implementation and maintenance of management
measures as necessary.. .
Construction and operation of a system of shallow interceptor trenches and
deeper pumping wells to contain and extract contaminated groundwater from
the site. Extraction will continue until established in-situ groundwater
clean-up objectives are met. Extracted groundwater will be pretreated in .
the existing wood-treating facility wastewater system as necessary prior
; to conveyance to the Galesburg Sanitary District publical1y owned
. treatment works (POTW) for final treatment. Treated groundwater will meet
established clean-up objectives for surface water discharge prior to
"-."'hl
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release by the POTH. Maintenance of the groundwater remedial system;
development and implementation of contingency plans for.a1ternative
on-site treatment should the POTH be unable to accept site wastewater in
the future.
Monitoring of groundwater within, and at the perimeter, of 'the "area of
contamination" to assess the effectiveness of the groundwater remedy;
development and implementation of contingency plans f6r collection of
contaminated grqundwater as necessary. Direct monitoring of extracted and
pretreated groundwater prior to release to the POTH for quality compliance
purposes. .
Application and enforcement of access and land use restrictions for the
"area of contamination" in accordance with the terms of the anticipated
Consent Decree with the responsible parties (RPs).
w
"
DECLARA nON
It is the considered opinion of the State of Illinois, through the Illinois
Environmental Protection Agency (IEPA), following consultation with USEPA
Region V, that 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 (or invokes an appropriate
waiver), and is cost-effective. This remedy is consistent with the State
Contingency Plan. This remedy satisfies the federal statutory preference of
CERCLA/SARA 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 maxi~~m
extent practicable.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted by IEPA, in consultation
with USEPA, within five years after commencement of remedial action to ensure
t~at the remedy coritinues to provide adequate protection of human health and
the environment. .
U f? t1t~
Bernard P. Killian, Director
Illinois Environmental Protection
t;t8~~
Da e
Agency
/
......~...
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DEX:1ARATIOO STATEMENl'
~ OF IE:IsICN
SITE NNm 100) IDCATICN
KDpperS Wood.JI'reatiIYJ Facility
Galesburq, Illinois .
ST~'I'D1ml' OF MSIS 100) RJ~
'Ibis decision documerit ser.res as united states Envirorunental Protection
kJercy (U.S. EPA) concurrence with and adoption of the remedial action
decision for the Koppers site, as approved by the Illinois Environmental
Protection}qercy (IEPA), and pursuant to sections 104 (d) an:! 117 of the
~rehensive Environmental Response Compensation and Liability Act
(CERCIA). IEPA approved this remedial action in conformance with:
Illinois Envirorunental Protection Act; and it has provided u.s. EPA with
documentation to dem::>nstrate the state's selection of the remedy conforms
with the requirements of the CERCIA, as amerrled by SUperfund AInenJments
and Reauthorization Act (SARA), and the National Contingency Plan, to the
extent practicable.
'!he State has un:lertaken response action at the Koppers Facility arx:l has
sought u. S. EPA concurrence in adoption of the remedy which has been
selected. The u.S. EPA concurrence with the state's selected remedy is
based upon the items listed in the attachment and the adequacy and
CCJI1i)leteness of those dOClm1ents as represented by the state.
DESa<.l.Yl'l.CN OF ~IAL ACl'ICN
'!be selected Iemedy provides for final cleanup requireIrents related to
the KDpperS site, as provided below:
* Excavation of visibly contaminated soils with a six-inch
OOffer layer to a depth that will ensure effective migration
of groorxl water contamination. Samples will be taken to
confirm final remediation to health-based levels.
* Extraction and treatment of shallow and deep ground water until
grcun;:I water clean-up obj ecti ves are based. .
* Discha.rge of treated groun:i water to the Galesburg rom that
are consistent with pretreatment starx:lards and/or surface water.
* Monitorin; of groun:i water and bioremediation treatment.
./
* ~lication of access ard lard use restrictions for the "area..
of contamination". .
. .;,......,
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-2-
IB:IARATIQi.
'!he selected remedy is protective of human health and the environment,
atta,ins Federal and state requirements that are applicable or relevant
an:! ~VJ:U.late for this remedial action, and is cost-effective. '!his
Ieh-ly' satisfies that statutory preference for remedies that employ
treatment . that reduces toxicity, IOObility, or volume as a principal
element an:! utilizes permanent solutions and al temati ve treatment
ted1rx)logies to the maximum 'extent practicable.
o
Because this IemeJy will result in hazardous substances remaining on-
site, the State is expected to supply infonnation such that the u.s. EPA
can conduct a review no less than five years after cormnencement of
remedial action to ensure that the remedy continues to provide adequate
protection of human health arx:1 environment. .
Based on the infonnation described above, U. s. EPA adopts and concurs
with the decision the IEPA has made in the exercise of the states
authority in selectin:1 this remedy under an agreement between u.s. EPA
an:! IEPA pu1:suant to section 104 Cd) of CERCIA for iJnplementaion of the
I elut:rJy , attached hereto.
Date
t
LUtt' bo ,. (~~q
Attachment
. "".:.....
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A'll.c.Jwa::att to u.s. EPA Declaraticn .
Ri. ~.l:S site
u. s. EPA oversight
Document of state Lead Site
1. Draft RIIFS Work Plans ccmment
2. ()1ality Assurance comment
Project Plan
3. Interim Deliverables File
4. Draft RI + comment
RI M:1endum
5. ~
Asse!;~11t +
M:1endum ~
. 6. Draft FS +
FS M:1endum comment
7. Draft ATStR comment
Health Assessment
8. ~ Technical Negotiation
Meetings with Responsible
Parties comment
9. ~q:osed Plan caMrent
10. PL~ Plan Public
Hearin) (s) Participate
11. Responsiveness ccmment
S\mIDaXY ' .
12. state hiministrative Record File
13. Draft R)I) camnent
14. Final ROD Concur
, . 15. IEPA an::l u.s. EPA
CERCIA 104 (d) }qreement Concur
. .
..,~
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KOPPERS WOOD-TREATING FACILITY
GALESBURG, ILLINOIS SITE
DECISION SUMMARY
1.
SITE NAME, LOCATION, AND DESCRIPTION
Site Description
The Koppers Company. Inc.. (Koppers) Ga1esburg Wood-Treating Facility site ;s
located approximately 2 miles south of the City of Galesburg, Knox County.
Illinois. The location and vicinity maps of the Koppers/Galesburg site are
shown in Figures 1 and 2. Appendix A. respectively. The Koppers site occupies
an area of approximately 105 acres. The active tie treating area uses
approximately 2 acres, with a large portion of the site devoted to railroad
tie storage.
The Koppers railroad tie treating facility is located on land owned by the
Burlington Northern Railroad Company (BN), at the southern end of the BN
railroad yard complex. Operat10nalfacilities and waste treatment/disposal
areas are shown in Figure 3. Current operations;nclude: the treatment.
cylinder building and drip track (A&S); the office building (B); storage tanks
for creosote (D); water (E); wastewater{F and W); the storage yard for
untreated ties (G); and the wastewater treatment system. Wastewater is piped
to a tank where It is.held prior to discharge to the flocculation basin. From
the f10cculatio~ basin. the wastewater passes through the oil/water separator
to the activated sludge treatment unit. The wastewater is discharged from
this unit directly to the Ga1esburg Sanitary District publicly owned treatment
works (POTW).
Southeast of the Koppers site is the Steagall Landfill. This site is also
10ca~ed on BN property and has been included on the Illinois State Remedial
Action Priority List {SRAPU. See Figure 3. Figure 4 gives. additional
Information on the land use of the surrounding area.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
SHe HI story
The railroad tie treating plant. built In 1907. was operated by BN until
December, 1966. At that time. Koppers leased the production plant from BN and
took over operation of the facility. The treating operation consists of
pressure treatment of railroad ties in treating cylinders utilizing a 70:30
mixture of c~eosote and coal tar. Previously. a 50:50 blend of creosote and
no. 6 fuel oil was used. During the period of 1971 to 1976. one of the three
treating cylinders was converted to pentachlorophenol (PCP) use.
The key areas associated with past waste disposal practices are also shown in
Figure 3. These areas include the "BN slurry pond" (also known as the old
creosote lagoon) (J); the north (M) and south (L) creosote lagoons; the PCP
1.a'goon(!); the waste pile storage area (n which has been consolidated in the
north creosote lagoon area; two drainage ditches that have been backfilled and
. ~.:.......
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regraded, the i'1terceptor ditch (R) and the Koppers ditch (P); and two former
spray wastewater fields (H)& (N). The operation history of the plant's waste
disposal areas is summarized in Table 1, .
The Koppers/Galesburg site was announced for inclusion on United States
National Priority List (NPL) in December 1982. The Illinois Envifonmental
Protection Agency (IEPA) accepted lead.responsibilities for condllct of a
Remedial Investigation/Feasibility Study (RI/FS), with. support from the United
States Environmental Protection Agency (U.S. EPA). Negotiations were carried
out with Koppers, and Burlington Northern, throughout 1984 and 1985 toward an
agreement to allow them the opportunity to voluntarily undertake an
appropriate RI/FS. On March 19, 1985, Koppers and BN entered into a Consent
Decree with the State (Docket Number 83-CH-92), Following Work Plan
development, the RI work took place from May, 1985, through April ,1986. The
final report documenting the findings of the. RI was issued on August 8, 1986.
A public meeting was held in April, 1987, to discuss this information.
Additional field work has been conducted since that time to further.
characterize the site, which should also decrease the forthcoming remedial
design period. Supplemental data on groundwater, surface water and sediment
contamination off-site has been provided by the RI conducted by IEPA for the
adjacent Steagall Landfill. .
The public comment FS findings were released on May 22, 1989, as was the.
. Agency's proposed plan. A public comment period was initiated that day and
concluded on June 12, 1989. A Special Notice Letter and draft RD/RA Consent
Decree will be sent to Koppers and Burlington Northern In early July, 1989,
beginning the moratorium period on Remedial Design/Remedial Action (RD/RA)
settlement discussions.. Formal negotiation meetings will then take place
between Koppers, BN, IEPA, and the Illinois Attorney General's Office (IOAG),
with technical support from USEPA.
. III. COMMUNITY RELATIONS
The IEPA has been responsible for conducting a community relations program for.
the site. Interviews with neighbors, concerned citizens and community leaders
indicated a community-wide consensus that environmental contamination
attributed ta Koppers, as well as the adjacent Steagall Landfill site needed
to be investigated. The community relations program emphasized:
a.
Initial visits with site neighbors and community leaders,
b.
Establishment of a local repository of documents,
c. Assistance to news media in Illinois to inform the public of ongoing
activities and the results of the investigation. .
Milestone activities conducted by Community Relations staff during the RIfFS
i nc 1 uded:.
*
,. Interviews with neighbors near the site and with community leaders,
Establishment of a repository of pUblic documents at the Galesburg Public
Lf brary,
..
2 . ~a",~
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*
Development of a mailing list of site neighbors, interested citizens and
organizations, news media, and elected offic.ials in local, county and
state government.
Fact ~heets #1 explaining the results of the Remedial Investigation,
.*
*
Paid newspaper advertisements announcing the RI public meetings and FS
public hearings. . ..
A publiC meeting in February 1~88 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
for~h the proposed plan in accordance with CERCLA Section 117,
Public hearings on feasibility study and proposed plan in May and June
1989. Approximately 20 people attended each of the hearings.
*
A responsiveness. summary addressing comments and questions received during the
public comment period on the RIfFS and proposed plan is attached as Appendix B.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
This is the first and only "operable unit" (or response action) at the site
and addresses all affected media: soils. sediments, air, groundwater. surface
water, and fish.
V.
SITE CHARACTERISTICS
The Remedial Investigation characterized the nature and extent of actual
and/or potential contamination associated with the site. The following
activities were accompltshed as part of the RI. and post RI work:
Review of existing data
Geophysical survey.
Soil sampling . .
Nested groundwater monitoring well installation{s) and sampling of wells;
2 sampling events each with continued monitoring of a baseline network
Surface water.and sediment sampling
Lime sludge sampling
Ai r monitori n9
Steagall Landfill data evaluation
.Private well survey and sampling
Fish sampling in Lake Bracken and Lake Storey (background)
Bench scale bioremediation study. .
Hydrogeologie analyses to assess the capabilities of interceptor trenches
to collect the plume in the shallow till aquifer and pumps to capture the
plume in the deep sand aquifer.
;'
General conclusions about the site and contamination assessment are presented
below:
3 ..;,.~
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Site Conditiuns
The site consistf of unconsolidated glacial materials. Surficial
materials at the site consist of poorly-drained silty clay soils and fill
materials. Glacial till underlies surficial soils and its average'
thickness is 33 feet. The till is anaquitard. The second hydrogeologic
unit is a semiconfined aquifer directly beneath the till aquitard. This
aquifer is composed of sand with an average thickness of 17 feet, and is
used locally as a water supply domestically and for livestock. Underlying
the'sand unit is bedrock which is predominantly shale and siltstone.'
Major surface water features in the vicinity of the site are Brush Creek
and Cedar Creek. The site lies on a divide between the Illinois River and
Mississippi River watersheds.
Brush Creek is an intermittent stream on the eastern edge of the
Burlington Northern property. It flows to the southeast; from the
southeaster~ corner of the site it is approximately 2 miles to Lake,
Brack~n. Cedar Creek flows to the southwest through the City of Galesburg
and it receives drainage from the extreme west side of the site via an
intermittent tributary. The remaining majority of site drainage enters
the Brush Creek watershed.
Groundwater flow within the confined deep sand aquifer is predominantly
toward the south.
A shallow groundwater divide in the till (aquitard) is present near the
center of the site. This divide is oriented east-northeast from the
office building parking lot to the northeast corner of the treatment
building area. Groundwater in the shallow till aquifer north of the
divide flows to the north and 'east and; groundwater south of the divide
flows to the southeast: '
The deep sand aquifer is recharged from upgradient areas at a higher
evaluation. Additional recharge occurs by infiltration from the shallow
till aquifer because vertical gradients between the shallow till and deep
sand aquifers are consistently downward over the site.
Waste Conditions
Results of the RIperformed at the Koppers site indicate that contamination
exists in soil, groundwater, surface water, and ~ediment onsite and sediments
in Brush Creek off-site. Six classes of compounds are identified as critical'
contaminants. They are dioxins and furans, carcinogenic polynuclear aromatic
hydrocarbons (PNAs), noncarcinogenic PNAs.phenols, pentachlorophenol (PCP),
and naphthalene. The general nature and extent of' contamination is as
follows; a summary of indicator chemical concentrations and distribution over
the site is provided in Table 8 of Appendix A.
, ,Soll
Soil contamination containing observable concentrations of organic
contaminants (phenols, PNAs and PCP is evident in the following areas) and
from the surface to the following depths (unles~ otherwise noted): '
4 . "'......"".
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South and east of the trea~ment building, greater than 20 feet below the
surface.
Drip track area, greater than 20 feet below the surface.
Pentachlorophenol (PCP) lagoon bottom, 3-8.5 feet below the bottom of the
lagoon.
Area immediately north and east of the PCP lagoon.
9.5-11.3 feet below the bottom of the BN slurry pond. 18-24 feet below
the ground surface in the north and south creosote lagoon areas.
10.5-35.5 feet below the ground surface in the BN trestle area.
l1~e sludge is pre1ent in the old spray field soils to a depth of 1.5 to
3.0 feet.
Analytical results indicate the greatest degree of phenols and total PNA
contamination occurs 1n the main drip track area; area east of the
treatment (retort) building; in the north creosote lagoon area, and to a
lesser extent in the south creosote lagoon and the BN trestle area. The
greatest degree of pentachlorophenol is in the bottom of the PCP lagoon.
PCP 1s also present in the creosote lagoons and BN trestle area, but to a
lesser extent.
limited concentrations of furans and dioxins were detected in a sample
from the PCP lagoon bottom.
Groundwater
Groundwater contamination 1s present 1n the shallow till aquifer and the
deep sand aquifer. Figures 5 and 6 indicate current areas of groundwater
contamination in the respective aquifers. .
The distribution.of contamination in the shallow aquifer 1s consistent
with groundwater flow characteristics. "Elevated" (part per million)
levels of phenols, PCP,. and total PNAs are present along the north side of
the treatment building and downgradient ~f the drip track and former PCP
handling areas. Directly downgradient of the PCP lagoon there are
elevated concentrations of pentachlorophenol and PNAs. The north and
south creosote lagoons are source areas of high contamination of phenols,
PNAs, and to a lesser extent, PCP, that have migrated downgradient to the
south and east of these areas. Phenols and pentachlorophenol have
migrated to a greater extent than have the PNAs.
Groundwater contamination in the deep sand aquifer, north of the PCP
lagoon and downgradient of the former creosote lagoons, is present in
"trace" (part per billion) levels beneath contaminated areas in the
/ sha1low till aquifer. This is apparently the result of vertical migration
from the overlying till under the influence of downward vertical gradients.
5 ~~
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Surface" Water, Sediments and Fish
Contamination is present in drainageways leading from the site. This
contamination is indicated by detectable concentrations of PNAs in surface
water and sediment samples from several drainageway locations on-site. The
data collected as part of the Steagall RI shows detectable levels of PNAs in
Brush Creek sediment along its length from the outfall of site drainage to
.Lake Bracken. Fish samples (bottom-feeders) collected in 1987 from Lake
Bracken showed detectable levels of PNAs, while fish samples collected from
Lake Bracken in 1988 did not. Further off-site study is anticipated through
supplemental Steagall Landfill work.
Air
The air samples collected during the RI indicate "low" ambient air
contamination on-site. Additional air monitoring will be conducted during
Remedial Design/Remedial Action to evaluate the necessity for mitigative
measures during construction to prevent adverse impacts to workers and the
.public. Phenol was found in the on-sit~air only at the existing spray..
field. The highest concentration of total PNAs in quantitative air monitoring
samples was in the active drip track areas immediately adjacent to the tie
treatment facility. PNAs were also present in the ambient air around the
treatment building, existing. spray field and PCP lagoon, all on the eastern
portio~ of the site. .
VI.
SUMMARY OF SITE RISKS
At the conclusion of the RI, an Endangerment Assessment (EA) was performed to
define the actual or potential threat from site-related contaminants to human
health and the environment. The results of this assessment indicate that the
greatest threat to human health and the environment under the "no action"
scenario occurs via the groundwater pathway. The no action scenario assumes
that no remedial action will tak.e place. The groundwater pathway includes
actual and potential migration of hazardous contaminants from the shallow
aquifer to the deep sand aquifer and subsequent transport downgradient to
nearby residential wells. The estimated total excess incremental cancer risk
due to consumption of drinking water from the nearest existing well, in the
absence of remedial activities, is between 2.12 x 10-4 and 4.77 x 10-4.
The total hazard index (measure of noncarcinogenic risk) for the nearest well
is estimated to be 0.292, with an upper bound of 62.6.
Other transport pathways that were evaluated in the EA include volatilization
and/or dispersion of hazardous constituents in soil to ambient air. Ambient
air monitoring, including influence from the active facility, revealed
detectable levels of PNAs. The nearest resident downwind is approximately 0.3
miles from the property line. In the assessment, a worse case scenario was
used where a residence was established near the property line. The estimated
overall excess caricer risk level associated with exposure is 1.5 x 10-5.
The data used in this assessment was not taken under ideal air monitoring
conditions, and therefore, additional future air monitoring will be
implemented during remedial design/remedhl action primarily for health and
safety purposes. .
" .
"
-
6 .........
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The State superfund Steagall Landfill RI included surface water and sediment
)amp1ing in Brush Creek, it tributaries through the landfill, and Lake
Bracken. The analyses of these surface water samples did not reveal
detectable concentrations of the Koppers' contaminants of interest. Sediment
contamination of Koppers' site-specific and "landfi11-type" contaminants has
been confirmed through additional sampling by the State and the RPs. An
on-site remedial action is currently in the bid procurement stage for the
landfill project. In addition, on February 9, 1989, the IEPA signed a State
ROD for a focused RI/FS of the Brush Creek ~nd.the sediment deposition area of
Lake Bracken in order to determine necessary action to remedi.ate contaminated
sediments and prevent additional effects from the upstream sites. These
actions, in combination with implementation of an on-site Koppers remedy, will
conceptually eliminate further contamination of Brush Creek. The supplemental
focused study of Brush Creek and Lake Bracken is currently being negotiated
between the. RPs and the State.
Scenarios that were evaluated qualitatively by the RPs and found not to
represent a significant risk include: exposure of "workers" to contaminated
soil and air, exposure.of "visitors" to contaminated soil, exposure through
consumption of potentially contaminated food crops grown off-site and exposure
of wildlife to~ contamin~ted soil and water. Rationale for elimination of
these exposure pathways is as follows. Workers follow plant/OSHA and health
safety procedures to prevent usafe occupational exposures. These measures
were assumed to be protective against incidental exposure to "CERCLA site"
contaminants. Further, the locations of "CERCLA site" contaminants are in
abandoned areas on the eastern portion of the site not routinely used by
~orkers. This site is located in a rural industrial/agricultural area. It is
fenced with a locking gate at the main entrance. This, in combination with
on-site industrial activity (also in BN yard to north) and heavy rail traffic
to the east and south, severely 1imtts "non-worker trespassing" and, to a
1easer extent, wildlife use. (Note: access/use restrictions are proposed as
part of the remedial a.ction plans detailed further into this decision summary
to facilitate elimination of existing and/~r potential direct contact exposure
risks.) Finally, contamination of food crops off-site with potentially
contaminated groundwater was dismissed from consideration because of the lack
of irrigation practices for this region. .
Exposure scenarios that were selected for quantitative analysis in the EA and
EA Addenda include: persons swimming in Brush Creek or Lake Bracken, persons
consuming fish from Lake Bracken, and fish and aquatic life in Lake Bracken.
These scenarios were found not to present a significant human health or
environmental risk by the RPs, given the existing data base. However,
supplemental Steagall Landfill study data collected in 1987 lead IEPA to issue
a fish consumption and upper lake/creek wading "warning". A fish advisory was
recently issued for carp and catfish in Lake Bracken based on observed PCB
levels, not PNAs which are the primary contaminant of concern at the Koppers
site. Additional study of fish in Lake Bracken should be included in the
supplemental "off-site" study previously mentioned.
On. May 10. 1989. the Agency for Toxic Substances and Disease Registry (ATSDR)
c.omp leted a Heal th .As ses sment( HA) of the Koppers NPL site. The HA focused on
:he public health implications resulting from exposure to five major classes
7
;..""...
-------
of contdminants present together at the Koppers and adjacent Steagall Landfill
site: (1) PAHs (or PNAs); (2) phenolic compounds; (3) dioxins/dibenzofurans:
.(4) polychlorinated biphenyls (PCBs); (5) other contaminants (i.e. asbestos.
PCP. and vinyl chloride). ATSDR concludes the following which is an
assessment of the data from both the Koppers and Steagall Landfill sites:
. "This site is a public health concern because of the risk to human health
resulting from probable exposure to hazardous substances at concentrations
that may result in adverse human health effects. As noted in the Human
Exposure Pathways Section [of the ATSDR healt~ ~ssessment]. human exposure
to PAHs and PCBs is probably occurring and has probably occurred in the
past via ingestion of PAH and PCB-contaminated aquatic organisms (e.g..
fish) and dermal contact with contaminated sediments. On-~ite
contamination of soil. surface water and groundwater with PAHs. phenolic
compounds. metals and asbestos at this site is evident. There is also
evidence of off-site groundwater contamination (i.e.. PNAs. phenols,
metals) at levels of concern to public health. The information reviewed
indicates that migration of contamination to off-site soil, at levels of
concern to public health. has not occurred. Consumption of potentially
contaminated plants and game and/or livestock is also of possible concern
to human health. if contaminated surface water is used for the irrigation
of plants and the watering of dome~tic animals. Remediation of the site
is necessary to minimize potential exposure from on-site and off-site
contamination. II
ATSDR will determine at a later time if follow-up public health actions or
studies are appropriate for this site.
VII.
DOCUMENTATION OF SIGNIFICANT CHANGES
The remedial alternative preferred by the Agency remains unchanged from that
proposed to the' pUblfc during the comment period. It is biological soil
treatment in combination with BAT groundwater treatment and access/land use
restrictions (Alternative 2 - FS addendum report for public comment. Mathes.
May, 1989). The details of this alternative will be expanded upon in
subsequent sections of this decision summary. No significant changes have
therefore been identiffed at this time. . .
VIII.
DESCRIPTION OF ALTERNATIVES
The feasibility study process identifies, screens, .then develops remedial,
alternatives to effectively mit~gate existing and/or potential human health
and environmental threats posed by the site. .
Due toex1stfng manufacturing ac'tivfty on:"sfte at th1s time. the primary focus
of the FS was on mi tigation of potenti a 1 contact/t ngestion ri sks from
contaminated groundwater off-site. However. another remedial action goal
advocated' by the Agency was elimination of on-site risks associated with
highly contaminated soi15. Remediation of these soils would minimize future
'groundwater contamination on-site and accelerate the groundwater restoration
process. as well as minimize contact risks should these areas become
accessible.' .
8 ''''~
-------
The following is a summary of the findings of the feasibility studies for the
Koppers/Galesburg. site, as detailed in the proposed plan.
Th~ draft feasibility study for the Koppers/Ga1esburg site was originally
prepared by the RPs during the winter of 1987. Remedial alternatives for
significantly contaminated source areas and groundwater were identified,
screened and developed to mitigate existing and/or potential human health and
envfronmenta1 threats from these affected media, and improve environmental
quality. over the long term. . . .
Tbe feasibility study addendum for the Koppers/Ga1esburg site was prepared by
the RPs during the winter of 1988, summarizing a year of supplemental .field,
laboratory and office work to refine the "engineering details" of the
pref~r~ed remedial alternative conceptually proposed in the original FS
report~ Table 2 of Appendix A, among other things, outlines the subsequent
pre-design work accomplished toward finalization of this site study. The.
findings are discussed further in the following sections.
Development of Alternatives
For the Koppers/Ga1esburg site, the RPs chose to focus initially on
appropriate groundwater remedial technologies to address this significant
exposure pathway. Soi1technol~gies that were compatible with, and enhanced \
the chosen groundwater technology, were then selected. Promising groundwater
and soil technologies were assembled into several remedial alternatives which,
In the professional judgement of the RPs, exceeded applicable or relevant and
appropriate requirements (ARARs>, attained ARARs or attained CERCLA goals
(containment/migration minimization but protective of human health>. The no
action alternative was also carried along as a baseline for comparison.
The groundwater remedial technology chosen for subsequent screening and
development consisted. of conection using a combination of shallow interceptor.
trenches and deeper extraction wells. This system was necessary due to the
contrasting surficial geology of silty clay till over sand and the complexity
of the existing contaminant plume.
"
Once extracted, the original draft FS contemplated on-site pretreatment of.
more "highly" contaminated shallow aquifer water, followed by treatment by the
Galesburg Sanitary District POTW; and direct discharge of "less" contaminated
deep aquifer water to the Brush Creek surface watercourse.
Appropriate soil and "lime sludge" technologies c6nsidered in the original
draft FS included: selective "hotspot" excavation in conjunction with on-site
1andfi11ing, on-site incineration or on-site biological land treatment.
Various combln~tlons of backfilling and/or "capping" of affected material were
identified~ The reader is referred to the revised draft FS ("Draft..Final
Feasibility Study Report, Ga1esburg Wood-Treating Facility; Hunter/ESE; March
.30, 1989) for further detail. The original ten assembled alternatives were
screened based on environmental, public health and cost criteria. All
ortginal ten alternatives were carried forward (including the no action.
~rternative> to the development stage where a detailed analysis was ~erformed
based on Agency evaluation criteria in effect at the time (technical,
9 '........
-------
envi ronmenta 1, instituti ona 1, humanhea I th and cost factors>. The resu1 ts of
this original evaluation are summarized in Table 3 of Appendix A.
As alluded to previously, Agency concerns about the site-specific technical
detafls .of the original draft FS prompted significant developmental. work on
the "preferred" remedial alternative emerging from that evaluatibn. The
remainder of this section is devoted to the finding of the FS addendum
(Mathes. May. 1989) which refines that "preferred" alternative and evaluates
all viable alternatives under current USEPA procedures.
. The additional study work performed by the RPs at the request of the Agency
included: a bench-scale biological soil treatment demonstration using
representative site wastes; installation of two pumping wells in the sand
aquifer and evaluation of their contaminant plume management potential; an
evaluation of the feasibility of interceptor trenches to control shallow till
aquifer contamination; contaminant migration modeling studies for the site
specific groundwater situation (similar work was also performed by an
independentUSEPA consultant); and a best available technology (BAT) study to
identify the most cost effective, treatment option for extracted.
groundwater(s). .
This additional information was used in the FS addendum to supplement the
remedial alternative "data base" and allow for a more refined detailed
analysis. this time using the current programs "nine evaluation criteria".
Six remedial alternatives (including no action) as shown in Table 4 were
re-evaluated by the RPs fn the FS addendum.
However, two of these a1ternatfves proposed by the RPs, Alternative 1 - No
actfon-sofll1fm.e sludge with BAT groundwater treatment and Alternative 5-
capping-sof1/1fme sludge with BAT groundwater treatment are considered
inadequate final remedies for the following reason. A signfficant plume of
primarily PNA compounds has developed on-site due to past waste disposal in
unlfned surface impoundments. Given the nature of these compounds and the
overburden geology, groundwater restoratfon to the 10-b cleanup objective of
2.9 x 10:-6 mg/1 (total carCinogenic PNAs) has been modeled under natural
flushing conditions to take an extraordinarily long time. However, further
analyses performed to assess the impact of source removal on groundwater
restoration indicate that a significant reduction in the estimated remedial
period could be realized through removal and treatment of "grossly
. contaminated" sol1 hotspots. This model is being revised to evaluate the
positive impacts of the proposed ground~ater pump and treat system and the
effects of natural in-situ bioremediation; There is a fundamental difference
of opinion between the Agency and RPs over whether source removal positively
affects the groundwater restoration period in a siqnificant way. It is the
opinion of the Agency that source removal is warranted given site-specific
conditions and therefore the above mentioned alternatives (1 and 5) are not
seriously considered as final remedial action plan candidates. Source
removal/treatment will eliminate contaminants which would otherwise have to be
dealt with in the "very long term" operation and maintenance programs for both
protection from potential direct contact and groundwater/surface water
. .
exposures. .
10 . ........ .
-------
From the Agency's perspective, the remainfng three action alternatives were.
seriously considered. They share a common BAT groundwater remedial component.
in conjunction with a sourc~ component of on-site: biological land treatment,
incineration or landfi1ling.
To preface the discussion of the evaluation of and between alternatives, it Is
important to understand the Agency's conceptual approach toward addressing the
complex, inter-related source material and groundwater situation which exists
at this old facility. .
As outlined in the site characteristics section, wastes from the wood-treating
process were disposed of in impoundments or on spray fields on the eastern
third of the 100 plus acre site. Waste disposal into the lagoons ceased in
the 1970's, and spray field wastewater application ended in 1986. Current
active wood-treating operations utilize a separation/recycling and biological
treatment system for wastewaters. The RPs also have plans to upgrade the drip
track with a full containment/collection system once that area is surficially
remed1ated. Future operations, in compliance with applicable requirements,
would therefore theoretically not impact the existing environmental problems.
Closure of thi~ particular area will then be subject to RCRA regulations in
effect at that time.
The remedial action plan then, must address several source hotspots which: 1).
are physically located in close proximity to each other within an approximate
800 foot rad1us of the treatment building, 2) have received similar wastes
containing primarily PNAs. phenols .and PCP and 3) contribute to common
groundwater contaminant plumes migrating in a southeasterly direction away
from the area.
The Agency advocates a comprehensive environmental approach of area
contamination "hotspot" excavation and on-site remediation using one of the
three technologies proposed (land treatment. i~cineration or 1andfil1ing) in
combination with area-wide collection/treatment/discharge of contaminated
groundwater. which includes appropriate operation. maintenance and monitoring
activities. This alternate. or "hybrid" remedial action approach, which
consolidates and "manage~" the surfic1al contaminants potent1al1y having the
greatest impact on the groundwater restoration program within this "area of
. contamination", is a logical approach to dealing with this uncontrolled site
and is consistent w1th current guidance for such situations. It is IEPA's and
USEPA's posit10n that RCRA requirements are applicable to some of the waste
management areas within this "area of contamination". The CERCLA program is
envoking an appropr1ate waiver of portions of these requirements to allow
implementation of a more "effective" remedy. This waiver is discussed in
detail in the statutory determinations section of this decision summary.
Outside of the drip track which is an integral part of the facility and
subject to operational regulations, the remainder of the "area of
contamination" can be separately managed and monitored without disturbance
once remedial construct10n 1s complete and the long term groundwater
restoration program 1s underway.
The IEPA cleanup objectives team (COT)/coord1nated permit review committee
(CPRC) process was used to establish site-specific "clean-closure" objectives
for primary constituents of concern in soils in waste- disposal areas and
11 ~-
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associated contaminated groundwater. Objectives were also established for
discharge of extracted groundwaters to surface waters in the Brush Creek
system. Cedar Creek system or from the Galesburg Sanitary District POTW.
However. because of the significant groundwater problem present. the "clean
closure" approach is deemed infeasible. with "alternate closure" providing a
protective. action-oriented solution. With that in mind. "clean closure"
objectives for soil were dropped in favor of a more obvious. construction
oriented measure of contaminant removal with positive impacts for this
situation. Objectives for groundwater (both in-situ and for discharge) remain
the same and are shown in Table 5 with the associated narratives. These
chemical-specific applicable or relevant and appropriate requirements (ARARs)
and other considered advisories/guidance are discussed in detail in the
statutory determinations section.
For wood-treating wastes. the RPs conducted a site specific evaluation of
contaminant mass removal using "visual" criteria for these highly identifiable
wastes. Si~nificant reductions in contaminant mass. on the order of 80
percent of contamination present in key hotspots targeted as "major
contributors" to groundwater problems, can be removed using an objective
method based on visual criteria plus a six-inch buffer layer to a depth that
will ensure ~ffective mitigation of contaminants to the groundwater. Samples
will be taken to assess these mitigative efforts and to confirm final
remediation to health-based levels. This source removal would result in
excavation of approximately l5.000cubic yards of contaminated soil from the
north creosote lagoon. drip track area. area east of the retort b~ilding and
the northeast portion of the PCP lagoon which would optimally benefit the
groundwater restoration program. See Appendix A. Figure 7 and associated
Table 6 which estimates removal volumes for cost purposes. These excavated
wastes would be consolidated within the "area of contamination" and remediated
using one of the three soil technologies identified. Excavated hotspot areas
will be backfilled with "clean" soil from off-site areas. regraded for
positive drain~ge and vegetated. (A waiver for a portion of the closure
requirements is discussed in the statutory determinations section.)
. Similarly. former waste management areas not targeted for excavation will not
be "capped". Instead. a site-wide plan for grading and revegetation of all
. inactive land within the "area of contamination" is anticipated. This would
include appropriate "closure" and "post-closure" care of other areas of .
concern identified by the RCRA program. The visual criteria approach and
resulting hotspot contaminant removal is therefore common to the action
remedial alternatives discussed shortly.
Similarly. as mentioned earlier. the groundwater component is common among the
action remedial alternatives and can be briefly discussed here and not
repeated in the alternative summary section.
Preliminary design hydrogeologic work indicates that the contaminated
groundwater plumes can be effectively captured through a system of pumping
wells in the deep sand aquifer and "french-drain" type interceptor trenches in
the shallow till aquifer. with a combined estimated steady flow rate of 120
gpllt. See Figures 8 and 9 attached for a conceptual plan of this system. The
RPs propose pretreatment of extracted south shallow till water in the existing
on-site plant oily/water separation and biological aeration system prior to
discharge to the Galesburg Sanitary District POTW. Studies by the RPs
12 ...:...,.
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indicate that the north shallow till aquifer water and the deep sand aquifer
w~'''. can be effectively treated directly by the POTH. Di scharge to the POTH
m~ meet pretreatment regulations and not cause upset or interference to the
POTH. The Agency is still evaluating the necessity of pretreating north
shallow till water on-site prior to release to the POTH because contaminant
levels are an order-of-magnitude higher than that observed in the deep sand
~~ter. Additionally, a potential asbestos problem in groundwater must be .
further studied during the remedial design period, and address.d as necessary
in'the treatment proc~ss outlined. It is anticipated that a limited program
of soil and groundwater sampling will be conducted to characterize the nature
and extent of asbestos contamination initially observed in the RI in the east
central portion of the site. However, the Agency also advocates contingency
plans which include on-site "storm management" and compliance monitoring of
CERCLA wastewaters to prevent negative site-related impacts on the POTH. The
RPs have had discussions with the Galesburg POTH concerning acceptance of the
CERCLA wastewaters, and have also used actual treatment plant
influent/effluent samples in their BAT analysis. This groundwater remedy has
therefore progressed past the conceptual stage to a point where there is
engineering confidence that the POTH'can treat the quantity and quality of
wastewater estimated, and has expressed a willingness to the RPs to do so. If
discharge to the POTH for treatment was found to be infeasible during the
remedial design phase, on-site treatment of contaminated groundwater and
discharge to surface water would be pursued, as the BAT study would be
revisited. . '
In conjunction with this groundwater collection and treatment program, a
p~-~~eter groundwater monitoring, operation and maintenance and contingency
p for the "area of contamination" is necessary to assess and maintain the
system's protectiveness. Although no specific program was proposed by the RPs
in the FS addendum, a nested network of permanent wells monitored on a regular
basis for primarily organic contaminants of concern will be developed during
RD/RA, settlement negotiations and in subsequent remedial design which is '
consistent with relevant RCRA regulations. Monitoring of the quality of
wastewater from the collection system, as well as monitoring of
pretreated/combined wastewater prior to discharge to the POTH is also ,
desirable. Because residuals are 1eft on-site after this final remedy is
operational, SARA requires five year performance reviews. Therefore, the
regular reporting from the groundwater compliance monitoring program will be
supplemented as needed to assess the progress of the remedial action at five
year intervals.. '
R-amedial Alternative Summary
The alternatives considered in the FS addendum are summarized here prior to
~valuation.
..
- '
Alternati~e 1 includes only BAT groundwater treatment as discussed
previously. Soil and lime sludge are not treated (inadequate alternative
in Agency's opinion).
, Estimated Total Remedial Cost: $2,505.738 (present worth over 30 years)
~stimated Years to Design and Construct (prior to remedy O&M): 2
1 3 '~.:.w
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Alternative 2 includes access/1and use restrictions, BAT groundwater
treatment and on-site biological land treatment of contaminated 50il
excavated from hotspots and previously excavated contaminated lime sludge
stored in three gondola cars in the maintenance shed. Contaminated lime.
sludge previously excavated and stockpiled on a tarp in the old spray
field area will be used as an amendment for biological soil treatment.
'It is important to note at this pOint that this technOlogy has been
successfully evaluated in the laboratory using site-specific wastes.
Details are currently. being finalized for an on-site field scale
biological test cell which wil.1 be constructed within the «area of
contamination" in the "old spray field" area as shown in Figure 10,
Appendix A. A rigorous toxicity testing program has been developed by
IEPA to assess the effectiveness of contaminant toxicity and mobility
reductions over a three year test period. The bioassay program will
directlj assess toxicity impacts on representative plant and animal
species. Bioassays are an alternative method to assessing risks based on
reductions in chemical concentrations of the contaminants of concern.
Full scale application of this technology in the (old and/or existing> .
spray field areas depends on successful demonstration of physical control
of the wastes within. the test cell and significant reductions in toxicity
in rel~tion to initial toxicity, with site background toxicity as the
treatment goal. The design of the full scale cell will be consistent with'
appropriate RCRA regulations. Management options which include seeding,
fencing and capping/revegetation have been developed for use depending on
the degree of significant contaminant toxicity reduction. Should toxicity.
not be significantly reduced in the test program, contingency plans will
be developed which call for a focused FS of viable soil treatment.
technologies at that time, and implementation of the most promising one.
'.
, "
"
Estimated Total Remedial Cost: $4,286.844 (PH) ,
Estimated Years to Design and Construct (prior to remedy O&M):
(includes 3 year demonstration study period) .
Alternative 3 includes access/land use restrictions, BAT groundwater
treatment and on-site incineration of contaminated soil and gondola car
lime sludge. ,Contaminated lime sludge stockpiled tn the old spray field
is proposed by the RPs to be used di rectl y as backfi 11 for excavated
areas. The Agency maintains that the stockpiled lime sludge contains
levels of contaminants that warrant "treatment" byincineratton.
Incineration would be.consistent with RCRA regulationS. Treatment of lime
sludge would increase the estimated cost of this remedy somewhat above the
RPs quoted figure. The RPs: propose that incinerator ash could be
backfilled on-site. Disposal of ash would be consistent with relevant
RCRA regulations.
9
'd,
. .4. .
.
Estimated Total Remedial Cost: $18,266,871 (PH)
Estimated Years to Design and Construct (prior to remedy O&M):
, .
",'!II.
4
v'
- ,/ Alternative 4 includes accessl1and use restrictions, BAT groundwater
. treatment and on-site landfil1ing of 'contaminated soil and gondola car
lime sludge. Contaminated lime sludge stockpiled in the old spray field
.....
14 ~.-
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is proposed by the RPs to be used directly as backfill for excavated
areas. As in Alternative 3. th~ Agency maintains "treatment" of this lime
sludge would be necessary, or in this case, containment. TheRPs have
proposed to design this "unit" as a single, bottom lined cell in the
southeast portion of the site within the "area of contamination,". The
Agency maintains that this cell and cap be designed to meet minimum
technology requirement~ of the RCRA Subtitle C Hazardous Waste
Regulations.' These modifications would increase the cost of this remedy
somewhat above ,the RPs quoted figure.
Estimated Total Remedial Cost: $5.243.432 (PW)
Estimated Years to Design and Construct (prior to remedy O&M):
3
Alternative 5 includes access/land use restrictions, BAT groundwater
treatment and "capping" of soil and lime sludge. The RPs propose that
contaminated soil from the drip track area. gondola cars and old spray
field lime sludge area would be consolidated in the PCP lagoon. The PCP
lagoon. the area east of the retort building and the north creosote lagoon
would be covered with clay (no thickness specified) and revegetated. The
drip 'track area WOUlD be backfilled ,with off-site soil prior to
construction of a new spill/drip containment system. (The Agency deems
this an inadequate remedy for several reasons, foremost of which is its
failure to benefit the groundwater remedial program as previously
mentioned and'SARA states "consistency with other actions" in which
excavation and treatment of "hotspot" soil areas would enhance the
groundwater remedy.>
Estimated Total Remedial Cost: $2.867.774 (PW)
Estimated Years to Design and Construct (prior to remedy O&M):
2.5
Alternative 6. The CERCLA program requires that the "no-action"
. alternative be considered at every NPL site. In this instance, th~ RPs
have included routine monitoring on-site of the till and sand aquifers to
assess contaminant migration off-site. '
Estimated Total Remedial Cost: $632.857 (PW)
Estimated Years to Design and Construct (monitoring well network prior to
assessment program initiation): 0.5
IX.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives that were developed in the Koppers/Galesburg FS
addendum were evaluated by the RPs and by the Agency using the following nine
criteria. Advantages and disadvantages of each alternative were then compared
to identify the,preferred alternative that provides the best balance among
these nine criteria. '
-1.
Overall Protection of Human Health and the Environment addresses whether
or not the remedy provides adequate protection and describes how risks are
, eliminated. reduced or controlled through treatment. engineering controls.
, or institutional controls. ' .
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2.
Compliance with ARARs addresses whether or not the remedy will meet all of
the applicable or relevant and appropriate requirements or provide grounds
for invoking a waiver. .
Long-term Effectiveness and Permanence refers to the ability of a remedy
to maintain reliable protection of human health and the environment over
time once cleanup objectives have been met. .
3.
4.
Reduction of Toxicity. Mobility. or Volume is the anticipated performance
of the treatment technologies a remedy may employ.
Short-term Effectiveness involves the period of time needed to achieve
protection and any adverse impacts on human health and the environment
that may be posed during the construction and implementation periOd until
cleanup objectives are achieved.
5.
Implementability is the technical and administrative feasibility of a
remedy, including the availability of goods and services needed to
implement the chosen solution. .
7. Cost includes capital and operation and maintenance costs.
6.
8.
Support Agency Acceptance indicates whether, based on its review of the
RI/FS and proposed plan, the support agency concurs. opposes, or has not
commented on the preferred alternative.
9. Community Acceptance is assessed in the decision summary following a
review of the public comments received on the RI/FS report and the
proposed plan.
The IEPA and USEPA identified their preferred alternative in the proposed plan
for the Koppers/Ga1esburg site as Alternative 2 - biological soil treatment,
BAT groundwater treatment and access/1and use restrictions. The strengths and
weaknesses of .the action-oriented remedial alternatives that were under
consideration by the Agency are outlined below, focusing on the qualities of
the preferred alternative. .
Overall Protection
All of the action alternatives (Nos. 1-5) would provide protection of human
health and the environment by elimtnating. reducing or controlling risks
through various combinations of treatment, engineering controls and/or
institutional controls.
Protection from exposure to contaminated groundwater is achieved for the
preferred alternative, as well as the other action alternatives. by
implementing and maintaininq a hydraulic groundwater containment system that
slowly flushes contaminants from the overburden aquifers. Collected.
groundwater is pretreated as necessary on-site in the modified active
fa.C'ilit1es' wastewater treatment system, followed by final treatment and
discharge at the Galesburg Sanitary District POTW. The key to overall
protection for this long-term groundwater action is a compliance monitoring
16 ~-~
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plan in conjunction with an established contingency and operation and.
maintenance program. The reality of the situation is that the maintenance of
this system becomes less certain as the restoration period increases.
Therefore. the Agency supports remedies which would reduce additional source
contributions to groundwater and prolong aquifer restoration. The preferred
alternative 2 and alternatives 3 and 4 provide for source .remedia1 work to
compliment their groundwatet component and also eliminate/reduce risk from
direct exposure to contaminants of concern~ The presence of the active
wood-treating facility, coupled with deed and access restrictions anticipated
to be self-imposed by the RPs, also enhances protection from contaminated
groundwater or soils, as long as these controls are enforced.
Compliance with ARARs
It is the Agency's position that all of the action alternatives do not meet
identified.app1icab1e or relevant and appropriate federal. state and local
requirements. It appears without further technical justification that
alternative 4 - 1andfi11ing and alternative 5 - capping do not meet potential
action-specific technology based ARARs for. source remedial components as
proposed. Chemical-specific groundwater ARARs may be met under alternatives 1
and 5. however restoration times would conceptually far exceed that estimated
for alternatives 2, 3, and 4. . The Agency's analysis of ARARs for the.
preferred alternative is discussed in the statutory determinations section.
All ARARs are met. or a waiver justified, for the preferred alternative.
Lonq-term Effectiveness and Permanence
As discussed previously. given the site-specific conditions. a very long term
groundwater remedial action is inevitable. The long term effectiveness and
"permanence" of the qroundwater remedy in the preferred alternative, as well
as that component of other action alternatives, hinges on the implementation
and maintenanc~ of the engtneered collection/treatment systems, compliance
monitoring and contingency programs and on-site institutional access and land
use restrictions. Therefore, because long-term management of wastes is
necessary, "permanence" is only "artificially" achieved through an effective
operation and maintenance program. .
The differences among the long term effectiveness and permanence of the
various source remedies under consideration is the key to selection of the
preferred alternative for this site. Landfi11ing physically isolates the
contaminant mass from the groundwater, however operation and maintenance
a.ctivities and eventual replacement requirements are "heavy". Management of
the biological land treatment cell could consist only of standard
cover/vegetation management, as it is anticipated that wastes will be
significantly, irreversibly treated and not require leachate control as in the
landfill option. Incineration would conceivably destroy all contamination in
the soil, obviously constituting irreversible treatment. If direct
backfilling on-site of incinerator ash is allowed, minimal maintenance would
be necessary. Alternative 3 - incineration, followed by the preferred
alternative, 2 - biological soil treatment, offer the most long term
~f'ectiveness and permanence by eliminating or treating wastes and limiting
future operation and maintenance work, with respect to the source remedial
component. ..
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Reduction of Toxicity. Mobility or Volume
Of the source action alternatives, 3-lncineration will completely destroy the
organit contaminants of concern in the source material to be remediated.
Toxicity, mobility and volume are therefore optimally reduced. However. the
preferred alternative. 2- biolOgical land treatment is also effective in
significantly reducing primarily the mobility and toxicity of that contaminant
mass. Landfilling, alternative 4 and in-situ capping, alternative 5 do not
treat the source material but rather rely on physical containment measures to
on 1 y 11 mi t mobl1i ty to the groundwa ters.
The common groundwater remedial component of the action alternatives provides
a significant reduction in toxicity, mobility and volume of contaminant mass
in that media by physically limiting migration of the plume (mobi 1 ity), then
over time extracting and biologically degrading the Organic contaminants in
the wastewater treatment train previously outlined (toxicity and volume
reduction) .
The preferred alternative is therefore action oriented, utilizing treatment
technologies for both soil and groundwater components, to breakdown the wastes
to non-toxic residuals.. .
Short-term Effectiveness
The short-term effectiveness of the five action alternatives are similar in
that they present a threat to construction workers, facility staff, the
immediate public surrounding the site and the environment. The action
alternatives that do not propose contaminated soil excavation. handling and
treatment/containment (alternatives 1 and 5) would conceptually pose less of a
short-term risk because there is less chance for exposure from contaminant
volitalization or wind/water erosion off-site and the implementation periods
are shorter. However the relative remoteness of this site in an
industrial/agricultural area, the use of standard health and safety
equipment/procedures, construction monitoring and engineering controls such as
dust suppression and clean water diversion will minimize these threats. The
preferred alternative, 2 - biological soil treatment takes the longest of the
action alternatives to implement, however, site control is established through
the presence of the wood-treating facility and therefore implementation of the
CERCLA remedial action is consistent with routine plant activities, posing a
"minimal" additional operation and maintenance burden for the source
component. All of the action alternatives would require similar operation and
maintenance attention for the groundwater pump and treat system over the long
term.
ImDlementabtlity
All action alternattves.propose to utilize proven remediation. technologies and
standard construction equipment and procedures and are thus technically .
feasible. Incineration would require a site-specific technology demonstration
. before allowing full-scale operation. The biological land treatment
t,echnology has been successfully demonstrated in a bench scale study for
site-spectfic wastes, as well as in the field for similar wastes at other
18 ~.;..~
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sites. A demonstration field study has also been fashioned for the
Koppers/Galesburg site, as previously discussed. The common groundwater
remedial component utilizes standard industry technologies for wastewater
treatment. Site-specific application has been demonstrated through the BAT
study. There will however be administrative requirements that must be .
fulfilled, such as a modification to the facilities. existing NPDES permit to
account for CERCLA wastewater prior to implementation of the remedy.
Cost
The estimated capital cost for design and construction of each alternative,
and the associated operation and maintenance, normal replacement and
monitoring present worth costs over a nominal 30 year period (for cost
estimating purposes only) for a 10 percent discount rate are given in
Table 7. The total estimated cost for the preferred'alternative, 2 -
biologi'cal land treatment/BAT groundwater treatment is $4,286,844. The costs
for the only other treatment oriented remedy, alternative 3 - on-site
incineration/BAT groundwater treatment is approximately four times greater
than the preferred alternative. Post 30 year long-term groundwater treatment,
and monitoring/contingency costs will obviously be required based on the
complexity of the groundwater restoration process for this site.
Support Aqency Acceptance
USEPA, Region V supports the preferred alternative. The Illinois/Indiana
section of the Remedial and Enforcement Response Branch, Waste Management
Division, has been involved in the technical review of this state-lead
enforcement RI/FS and the development of the proposed plan and this ROD.
Community Acceptance
A comprehensive community relations program has been impleme'nted for this
site. Several informational meetings have been held, as well as the recent
public hearings. Fact sheets have been distributed to an extensive list of
. public officials, the media, concerned private individuals and groups, as well
as the'RPs and. their engineering consultants.
The responsiveness summary, Appendix B to this decision summary, details oral
comments received at the public hearings, as well as written comments received
from the RPs' consultant and the public. For conciseness and clarity, these
comments are paraphrased and grouped together where possible, prior to the
Agency's response.
No comments were received which conceptually disagreed with the components of
the Agency's preferred alternative as identified in the FS addendum and
proposed plan. The RPs' consultant submitted comments on the technical scope
of the remedial action plan proposed by the Agency. All comments have been
carefully considered in the selection of the final remedy for the
Koppers/Galesburg site.
19 '"....~ .
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x.
SELECTED REMEDY
Based on exi~ti~g site information. the RI/FSby the RPs and the analysis of
remedial alternatives using the nine evaluation criteria. the Agency has
selected Alternative 2 "':' biological soil treatment. BATg'roundwater. treatment
and access/land use restrictions as the final remedy for the Koppers/Galesburg
site. In brief. this remedy consists of: .
Demonstration of the biological treatment technology in an on-site
field-scale cell.
Excavation of visibly contaminated soils plus a six-inch buffer zone from
"hotspot" areas to a depth that ensures effective mttigation of
groundwater contamination. Samples will be taken to assess these
mitigative efforts and to confirm final remediation to health-based levels.
Backfilling of excavated areas with "clean" soil; regrading/revegetation
of affected areas.
Phased biological treatment of excavated contaminated soils in an on-site
"engineered" cell.
Long-term management of treated soils in-place.
Collection of contaminated groundwater from the site.
Pretreatment of contaminated groundwater on-site as necessary; final
treatment at POTW. .
Routine monitoring of groundwater collection/treatment systems.
Access and land use restrictions for affected areas.
Five year evaluations; contingency plans implemented as necessary.
In summary. this remedia.1 action plan. with proper operation and maintenance.
permanently reduces the toxicity. mobility and volume of site source and'
groundwater contamination through a combination of treatment. engineering and
institutional controls.
The existing and/or potential risks associated with direct contract of source
materials and migration of contaminated groundwater are effectively
mitigated. Highly contaminated soils are potentially treated to background
toxicity levels and managed on-site over the long-term. Contaminated
groundwaters are contained at the eastern and southern edge of the site in
areas under the control of the RPs. and eventually treated over the long-term
to thel0-~ excess carcinogenic risk goals at the "compliance points". the
downgradient boundaries of the identified waste management areas.
Thi's fi na 1 remedy is therefore protecti ve of human health and the environment.
at'tains ARARs or invokes an appropriate waiver. and is cost-effective while
20 '''':''''''
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providing a permanent, environmentally sound solution for .the entire site that
employs treatment and/or resource recovery technologies to the maximum extent
practicable. .
XI.
STATUTORY DETERMINATIONS
Section 121 of CERCLA requires that the selected remedy:
Be protective of human health and the environment;
. ,
Attain ARARs{or provide grounds for invoking a waiver);
Be cost-effective;
utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable; and
Address whether the preference for treatment that reduces toxicity,
mobility or volume as a principle element ;s satisfied, or provide an
explanation tn the decision summary why it is not satisfied.
The selected remedy for the Koppers/Galesburg site, Alternative 2 - biological
soil treatment, BAT groundwater treatment and access/land use restrictions is
briefly summaried below in relation to each of the statutory requirements.
Protection of Human Health and the Environment
The selected remedy effectively reduces risks to human health and the
environment from contaminated soil and groundwater by:
1.
Excavating highly contaminated so;ls, treating them biologically on-site
in an engineered cell followed by management. in-place as necessary; and
Collecting contaminated groundwater through a trench/well system; treating
it biologically on-site as necessary prior to final treatment by the POTW;
monitoring aquifer restoration and modifying the program as necessary.
2.
Direct contact and inhalation (dust) soil risks are reduced by the source
remedy. while the .groundwater remedy prevents off-site contaminant migration
and associated contact and ingestion risks in the short-term and eliminates
these risks through treatment tn the long-term.
Health-based chemical-specific clean-up objectives have been developed by IEPA
for site, groundwater, surface water, soils and sediments (see Appendix A.
Table 5, plus supporting information) through its COT/CPRC process. Since
"clean closure" of contamination "hotspots" is infeasible. health-bas~d
soil/sediment clean-up objectives will not be initially used. Instead. a
. visual criteria will be .imp1emented to remove and sUbsequently treat highly
contaminated soils. However, groundwater. surface water and soil clean-up
objectives that are protective of human health and the environment will be met
through tmplementation of the selected remedy.
, ,
".
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The selected remedy will' be implemented on-site in ar~as owned and controlled
by the RPs. It is believed the surrounding rural community will not be
adversely affected in the short term by remedial activities because of the use
of prudent construction practices such as erosion control/clean water
diversion and dust suppression to minimize contaminant migration through the
surface water and air pathways. Monitoring activities will be implemented to
assess contaminant control. with contingency plans utilized as necessary. No
cross-media impacts are anticipated because det~iled engineering plans will be
implemented with a high degree of control of excavated soils and extracted
groundwater to minimize interaction with "c1ean" areas/medtas. Additionally,
data suggests that there will be limited volatilization of contaminants of
concern during handling. due to their chemical nature. This quality will aid
. in minimizing air impacts from contaminants that will be consolidated and
treated. .
Attainment of Applicable or Relevant and Appropriate Requirements
Section l21
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- . with respect" to a State standard, requirement, crrteria, or limitation,
the State has not consistently applied (or demonstrated the Intention to
consistently apply) the standard, requirement, criteria, or limitation in
similar circumstances at other remedial actions within the State; or
in the case of a remedial action to be undertaken solely under section 104
using the Fu~d, sele~tion of a remedial action that attains such level or
standard of control will not provide a balance between the need for
protection of public health or welfare or the environment at the facility
under consideration, and the availability of amounts from the Fund to
respond to other sites which present or may present a threat to public
health or welfare or the environment, taking into consideration the
relative immediacy of such threats. .
.The selected remedy for the Koppers/Galesburg site, Alternative 2 - biologic~l
soil treatment, BAT groundwater treatment and access/land use restrictions
will attain ARARs described below, or utilize a waiver, in this case for a
portion of the action-specific ARARs identified.
The following chemical-specific, location-specific and action-specific ARARs
and other. cons i dered adv i sori es/ gui dance are outl i nedfor the groundwater and
source components of the selected remedy. Justification for the ARAR waiver
is also provided. .
Chemical-specific ARARs and other considered advisories/guidance describe the
"level" at which the contaminants could safely be found in the environment.
The clean-up levels identified by the previously described COT/CPRC process
for groundwater and surface water are ARARs in the opinion of the Agency, a
position not shared by the RPs. The objectives are derived from promulgated
state water quality standards, and, for contaminants where no standards exist,
federal ambient water quality criteria are used as relevant and appropriate to
the remedial action. To continue this general train of thought, there are no
state or federal ARARs for the contaminants found in the soils and sediments
on-site. The original COT/CPRC "clean-closure" clean-up levels for these
soils and sediments fall in the category of non-promulgated advisories, which
were initially considered by the Agency in the development of the source
remedial action. However, excavation to these levels on-site h4s been
demonstrated to be infeasible. Instead, a visible removal criteria has been
adopted which, when implemented in "hotspot" contaminant deposition areas,
will optimally benefit the groundwater remedy and contribute to the protection
of human health and the environment in an efficient manner.
Various RCRA requirements appear to be either applicable or relevant at this
old.manufacturing facility. Before applying (or waiving) those requirements
it is necessary to discuss the Agency's a~sessment of the regulated Hazardo~s
Waste Management Units (HWMUs) and the Solid Waste Management Units (SWMUs)
on-site.
RCRA requirements are applicable to areas of a site that contain RCRA listed
~ characteristic hazardous waste and that waste was received or significantly
23 . ~.- .
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lnaged after November 19. 1980. the effective date of RCRA. The first point,
Ie classificat~on of wastes present. within the "area of contamination" is in
spute between the IEPA/USEPA RCRA programs and the RPs.Taking the position
, the Agencies that this waste is listed. the second point can be addressed.
: appears the following areas received waste before the effective date of
:RA and have not. been significantly managed since (ie. RCRA regulations are
,levant): . . . .
North creosote lagoon
South creosote lagoon
Old spray field area
. Area east of the retort building
appears the following areas have been managed to various degrees by the RPs
part of their plant operations 'since the effective date of RCRA (ie. RCRA
gulations are applicable):
Drip track area.
PCP lagoon.
Existing spray field area
Waste .pile (relocated to north
Interceptor ~itch
ap~ears the following areas have been significantly managed by the RPs
der the terms of the 1985 state superfund Consent Decree (ie. RCRA
gu1ations are possibly applicable): .
creosote lagoon)
BN slurry pond (with excavated lime sludge stored in a tarped pile and in
three 1tned gondola cars on-site)
e facility also contains a drum storage area inside the treatment building
ich temporarily holds currently generated waste prior to off-site
ipment/disposal. .
e point of this exercise is to show the complexity of the waste management
tuation at the site. The CERCLA position is that soils within all of these
~as contain "RCRA hazardous constituents" that have been released. or have
~ potential to be released to primarily the groundwater media. RCRA
~uirement are therefore at least relevant to all remedial efforts (HWMUs and
~Us within the CERCLA "area of contaminat10n").
return to the chemical-specific ARAR issue. RCRA section 3004(u) and
J4(v) and 40 CFR.Part 264. Subpart F require corrective action for releases
hazardous waste or constitutents from "units" requiring a RCRA operating
rm1t. Corrective action goals are s1milar to CERCLA remed1al object1ves.
JTE: The drip ~rack area is currently considered a SWMU. however. proposed
~A rules currently under consideration would classify this area as a HWMU.
~. selected remedy is intended to satisfy corrective action concerns for the
ip track area. however. active operat10ns would be sUbject to other RCRA
julations under a future permit. .
24 . ~......
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foremost of which is to be protective of human health and the environment.
The selected remedy has been shown to achieve that goal through the CERCLA
evaluation documented in this decision summary. '
First, to address the reclamation of the affected aquifers, the RCR,A Subpart F
regulations require the establishment of concentration limits for hazardous
constituents ~e1eased from waste management "units" and the treatment of
groundwater exceeding those limtt~ at the "potnt of compliance" as defined at
40 CFR 264.95. The "potnts of compltance" for groundwater migrating from the
"area of contaminatton" are the downgradient boundartes of the fo~mer waste
management areas. Maxtmum Contamtnant Levels (MCLs) established under the
Safe Drinking Water Act (SDWA) are potentially applicable or relevant and
appropriate standards for Class I or II aquifers. The shallow till unit would
generally be considered a Class III aquifer under modern criteria, due to its
low yte1~. One shallow well has been identified east of the Kopper's site,
adjacent to the northeast corner of the Steagall Landfill, that utilizes that
aqutfer. Contamination has been observed 1n that well and the residents have
voluntarily discontinued its domestic use. The State is pursuing proper
closure of this well as part of the implementation of the Phase I Steagall
Landftl1 on-site remedy.
In contrast, the deep sand unit on the Koppers/Ga1esburg site would be
considered as Class II, being currently used as a source for drinking water.
Although this aquifer is not currently used as a pub1tc water supply, MCLs
would be relevant because the groundwater is used individually by local
residents. However, MCLs are not appropriate in this case as COT/CPRC
clean-up levels have been established to be protective of human health and the
environment. Contaminated groundwater from the site has the potential to
recharge to Brush Creek. The COT/CPRC clean-up levels are based on state
general use water quality standards, where available, and supplemented by
federal ambient water quality criteria to ensure the water quality
requirements in the sensitive Brush Creek system are maintained in the future.
Next, to address the handling of contaminated groundwater during the
restoration process, it is again noted that the selected remedy utilizes a
combination of pretreatment of a portion of the extracted groundwater on-site
followed by final treatment by the local POTH. '
The discharge of extracted groundwater to either a surface water body or to
the local POTH is regulated by appropriate sections of the Clean Water Act
(CWA) and 111inois water pollution control rules (35 Illinois Admtnistrative
Code (lAC) Subtitle C). COT/CPRC levels were developed to meet these
requirements for two potential situations, direct discharge to intermittant
streams (both Cedar and Brush Creeks) and also from the POTH. The RPs have
completed a best available technology (BAT) assessment on the groundwater(s)
from the site. Discharge limits are' established based on application of BAT
or more stringent limits. if necessary, to assure the receiving water meets
applicable State water quality requirements.
Th~discharge of tr.ated, groundwater to the preferred locatton, the Cedar
Creek system, will meet the substantive requ1rements of the CWA National
Pollutant Discharge Elimination System (NPDES). Discharge of groundwater to
25 ,~......
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the,POTW will meet the substantive requtrements of applicable federal
pretreatment standards, DWPC rules and local o~dinances. It ~ppears from the
.studies conducted by the RPs that the selected groundwater action will meet
these requirements and the Agency c1ean~up1eve1s. .
No location-specific ARARs or other considered advisories/guidance were
identified by the RPs or IEPA/USEPA for the selected on-site remedy. (RCRA
location-specific requirements are addressed in the context of the treatment
technology discussion which follows). .. . .
. Action-specific ARARs and other considered advisories/guidance usually
describe the method or level of control under which the contaminants shdu1d be
managed in the environment; . .
For the selected remedy which calls for excavation, consolidation and
treatment of highly contaminated soils and stored lime sludge within the
defined "area of contamination", substantive RCRA SubtitleC closure,
post-closure (monitoring, maintenance and reporting) and land treatment unit
requirements are the primary ARARs to be addressed. As .pointed out
previously, these requirements appear to be applicable to several waste areas,
and relevant to the rest. RCRA land ban requirements were not determined to .
be ARARs based on the concept as previously defined of consolidation,
treatment and final deposition within the CERCLA "area of contamination"
on-site. This source remediation would not constitute IIplacementli under RCRA
which is a prerequisite to the consideration of land ban requirements.
IIClean closure" of the affected areas is infeasible due to the existing
complex groundwater problem. IIClosure in-place" is not deemed appropriate due
to the adverse impact that unremediated source materials would have on the
groundwater restoration period. It has therefore been determined by the
Agency that a IIhybrid" or lIalternate closurell approach is the most appropriate
for the given site circumstances. .
The se 1 ected CERCLA remedy therefore util i zes appropri ate aspects of both RCRA
IIclean closure" and "in-place closure". A key aspect of RCRA closure that was
determined not to be appropriate was installation of a RCRA compliant cap over
excavated "hotspots" or other waste areas.
Pursuant to RCRA, closed "units" should 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
its bottom liner (in this case no liners were used). It is necessary to waive
. this final cover ARAR for the Koppers/Ga1esburg site for the following reasons..
The compliant remedial action [with RCRA caps] poses greater risks to human
health and environment in the sense that the risks are more long lasting; and
these prolonged risks could cause additional, lIirreparable" damages. The
alternative, the selected remedy for the Koppers/Galesburg site)is a
backfilled IIlooseli clean cover that allows flushing into the two aquifers, the
aquitard and the sand aquifer. This active recharge system is necessary to
increase infiltration through the restdual contaminated material and
1eachabi11ty tnto the groundwater collection system capture zone. In
26 ~.-
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addition, the alternative selected remedy promotes flushing into contaminated
horizons which creates an oxidized state necessary for natural biodegradation
of those contaminants. The compliant remedy would prevent infiltration of
water into contaminated horizons which would decrease leaching of contaminants
toward the groundwater collection points and also create an oxygen reduced
state that h1nder~ naturali~-situ bioremediation and. progress of the remedial
action. Modeling has demonstrated that the compliant remedy could
significantly increase the predicted remediation time and duration of adverse
aquifer impacts. The risks posed by the selected remedy are signficantly less
than the risks posed by the compliant remedy because the selected remedy
decreases remediation time, promotes treatment to the maximum extent
practicable, and reduces toxicity of the contaminants through infiltration and
leaching of residual contaminants into th~ groundwater collection system.and
in-situ bioremediation of the residual contaminants.
In addition to a final cover, .RCRA regulations require long-term maintenance
and monitoring to ensure the covers integrity. The selected remedy .
conceptually includes such operation, maintenance, reporting, financial
assurance and contingency planning to protect th.e cover implemented, as well
as the groundwater collection and pretreatment systems.
Similarly, the selected remedy conceptually includes monitoring plans to meet
the substantive RCRA Subpart F groundwater monitoring, maintenance and
reporting requirementi and contingency measures which are relevant and
appropriate to all waste areas and applicable to some. However, because of
the "common nature" of the groundwater contaminant plumes, it is anticipated
that this network will monitor the perimeter of the "area of contamination",
focusing on the downgradient "points of compliance" of former waste management
areas to ensure the established clean-up levels are met until the groundwater
restoration is confirmed as complete. .
Finally, with r.espect to on.-site biological treatment of highly contaminated
soils, RCRA Subpart M, land treatment design and. operating requirements must
be addressed~ .
The selected remedy calls for a field-scale demonstration study using a
biological monitoring program over a three year time frame. Successful.
site-specific bench-scale studies have already been completed. This pilot
program will be conducted within the "area of contamination" in the general
location of the old spray field area in a controlled, "engineered" .
quarter-acre unit. This unit will approximate full scale waste loading
characteristics and operating conditions, with the flexibility for mid-test
. modifications as necessary. The Agency will closely monitor this treatment
demonstration, looking both at toxicity and mobility reductions of
contaminants. Site-specific full scale design and operating parameters for a
three to five acre treatment cell will be developed based on the results of .
this Dilot study. .
RCRA land treatment requirements have been considered in the preliminary
de~ign of the selected remedy. The most appropriate area in which to locate
t,ITh treatment cell is in the vicinity of a former affected area, the old
spray field. which is remotely located near the major excavation area, the
27 ~~
-------
north creosote lagoon. . Studies in this area have shown the potential for a
high water table. condition i~ the till soils. The RPs have proposed .to
install a high density polyethylene (HOPE) liner in the pilot cell to avoid
adverse affects on the treatment zone by groundwater intrusion. At the same.
time. monitoring will be conducted within the pilot cell to look at migration
of contaminants into a representative lift of the subsoil.
RCRA requirements that must be addressed in the remedial design include a
provision that. "the maximum depth of the treatment zone must be: 1) no more
than 5 feet from the initial soil surface; and 2) more than 3 feet above the
seasonal high water table." Unsaturated zone monitoring requirements are also
re levant to the bi 01 ogi ca 1 treatment ce 11 . . .
Treatment zone depth to water table limitations will be assessed in the pilot
study findings. If water table conditions present a significant problem they
could be artificially controlled by a liner under the full scale cell, a
subsurface drainage tile system beneath the cellar placement of a clean soil
subbase layer prior to initialization of the treatment zone. The depth
limitations for the treatment zone should not present a problem as adequate
area is available to properly size the treatment cell. It is anticipated
given the site surficial geology and nature of the waste contaminants that
significant leaching from the treatment cell will not be realized. However,
groundwater monitoring needs for the treatment cell will be dictated by the
results of the pilot study.
Other operating, maintenance. reporting, closure and post-closure requirements
of Subpart M will be substantively complied with under the selected remedy.
No food chain crops will be grown in or on the treatment unit during or after
remediation is complete. Final cover requirements will be dictated by the
degree of treatment achieved by the unit. No wind dispersion will be allowed,
with vegetation establishment being the minimal cover management option.
Post-closure care will most likely be added to the routine responsibilities of
on-site wood-treatment facility personnel. .
Cost Effectiveness
The total present worth cost of the selected remedy. as estimated by the RPs.
is $4.286.844. The selected remedy was chosen over less expens.ive remedial
alternatives because the additional "protection" provided by biological
treatment of highly contaminated soils was judged to outweigh additional costs
above that for the baste groundwater remedy. Two alternatives were more
expensive then the one selected. Development of an on-site landfill as a
source remedy was judged to be .less "protective" than biological treatment by
the Agency. . Incineration conceptually provides greater "protection" than
biological treatment through total .destruction of source materials. However,
the significant additional cost of incineration over biological treatment was
judged to be unwarranted by the Agency with respect to the additional
"protection" achieved by that technology.
/~.
28. ~.;....
-------
Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy includes biological treatment of both contaminated soils
and groundwaters. A portion of contaminants in collected shallow till
groundwater will be recovered in the on-site pretreatment process using the
active facilitie~' system. This remedy was judged by the Agency to provide
the best balance among tradeoffs between the nine evaluation criteria, while
uti1i"zing treatment technologies to the maximum extent practicable.
This remedy offers a greater degree of "permanence" with respect to the source
action than the other developed alternatives, except incineration.
Stgnificant reductions in contaminant toxicity and mobility are expected from
biological treatment which, with proper minimal management, would provide
similar "permanence" at a much lower remedial co~t. The groundwater remedy,
common to all alternatives, treats contaminated waters to health-based risk
levels over the long-term. An effective operation and maintenance program is
required to "artificially" achieve "permanence" for this groundwater action.
However, the Agency believes that this program can be successfully implemented
under the terms of the anticipated RD/RA Consent Decree with the RPs.
Preference for Treatment as a Principal Element
The selected remedy treats both highly contaminated soils on-site, and"
contaminated groundwaters on-site as necessary, followed by off-site final
treatment by the POTH. Thus, this remedy satisfies the statutory preference
for utilization of treatment technologies to address the principal threats
posed by the Koppers/Galesburg site.
2 9 ~.:-
-------
KOPPERS/GALESBURG DECISION SUMMARY
APPENDIX A -- FIGURES AND TABLES
,"""..
-------
StJR""4"O
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SCALE: ,..= 25.6 MilES
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KOPPERS GALESBURG SITE
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.....~...
-------
2-
. Table .K
CHRONOLOGY
.J1'
GALESBURG"WOOC-TREATING FACILITY SITE
Date
Activity Description
03-Mar-87
Ol-Apr-87
Ol-May-87
27-May-87
OS-Jun-87
Ol-Jun-87
16-Jun-87
26-Jun-87
20-Jul-87
21-Auq-87
30-Sep-87
06-0ct-87
04-Nov-87
13-Nov-87
04-Jan-88
20-Jan-88
ESE issues Draft FSdated 27-Feb-87.
IEPA issues initial IEPA/USEPA comments (66) on Draft FS.
ESE issues ESE. BNRl!. and Koppers' collective itemized responses
to initial IEPA/USEPA comments.
Technical meetin9 at IEPA to discuss Draft FS comments.
The main discuss~on topics were:
- duration of qroundwater remediation.
- treatment technoloqies for. contaminated soil and qroundwater.
and .
quantities of soil to be remediated and IEPA's interest in
establishment of soil cleanup criteria.
IEPA issued second round of comments on the Draft FS.
Meetinq at ESE' (St. Louis) to discuss qroundwater model.
Presentation on bioloqical treatment of contaminated soils was
made at IEPA by Keystone and ReTee.
Keystone issued responses to consent order comments issued by
IEPA 01-Apr-87. .
ESE received preliminary summary of IEPA's survey of surface
water use by Lake Bracken residents.
ESE submitted a supplemental report to IEPA. IOAG. and USEPA
detailiAq the results of additional modelinq of the dynamics of
the miqration of contaminants .fromthe laqoon source area. into
the shallow till aquiler. deep sand aquifer. and the interceptor
trenches. .
ESE submitted letter requestiAq chanqesto qroundwater monitori~q
proqram.
IEPA responded formally to request for chanqes to qroundwater
monitorinq proqram. APiroved elimination of Wells 21. l07A. and
105 and chanqe in samp inq frequency from quarterly to
semiannually. .
. .
Meetinq at IEPA with representatives from IEPA. IOAG. USEPA,
B01l, Koppers,. ReTec. and ESE wherein aqencies presented their
plan for remediation of the site. .
Test pit survey conducted on. site to evaluate the characteristics
ot contaminated soils within the former creosote and penta laqoon
areas and evaluate various source removal strateqies. Eleven
samples were collected from eiqht test pits.
A res~onse to IEPA, IOAG. and USEPA's 04-Nov-87 plan for
remed~ation was submitted to the aqencies by ESE. A report
presentinq the results of the test pit survey was submitted for
review by IEPA,IOAG, and USEPA by ESE.
A meetinq was held between the aqencies and the PRPs to discuss
ap~roaches to remediation of the site. Disaqreement remained on
s011 removal criteria. The PRPs aqreed to:
.;.,."'..,
OS/89/3302e(3017)3
-------
....-
2-
Table ~C6ntinued
,
CHRONOLOGY
GALESBURG"WOOD-TREATING FACILITY SITE
Date
Activity Description
lS-~ar-88
22-Mar-88
26-Apr-88
May-88
02-May-88
09-May-88
lO-May~88
Ol-Jun-88
27-Jun-88
Ol-Jul-88
OS-Auq-88
" 08-Auq-88
~1-Sep-88
l2-Sep-88
19-5ep-88
model reinjection scenarios for the shallow till and deep sand
aquifers, . "
- evaluate the ability of the Galesburg POTW to treat the
proposed discharge from the eztraction trenches.
evaluate the sensitivity of remedial costs, soil volume
removals~ and risk factors to changes in soil removal criteria.
- prepare counterproposal to tozicity testing of biological
treatment, and" .
- prepare financial assurance proposal.
A meetin9 was held between the agencies andPRPs to discuss
remediat~on alternatives. The PRPs presented new groundwater
modelin9 work which concluded that source removal and reinjection
had ins~qnificant impact on qroundwater remediation timinq. The
PRPs presented ABABs interpretation. PRPs aqreed to reevaluate
endanqerment assessment based on results of Brush Creek and Lake
Bracken studies. . "
Public meetinq in Galesburq concerning Lake Bracken.
Meeting in Springfield between the agencies and PRPs to discuss
groundwater, source removal, biological testing, Brush Creek and
" Lake Bracken risk assessment, and financial assurance issues.
Keystone issued two reports: Evaluation Treatment System's
Capacity (Keystone, 1988a), and Biological Degradation of Wood
Treating Chemicals of Interest (Keystone, 19S8b). "
COT/CaOPA cleanup levels sent to paps.
During this week, samples from 6 private wells were collected and
split with IEPA.
Additional biological samples were collected from Lake Storey and
Lake Bracken and split with IEPA.
Aquifer testing beqaza during this month.
Meeting with IEPA to discuss test plot"desiqn.
During July, a summary of the April 1988 Steagall landfill
surface, sediment, and leachate sampling results was forwarded
IEPA by the PRPs and ESE received IEPA's results for this same
sampling event. .
to
Met with IEPA on site to present practicality of visual criteria
for source removal, to locate test plot, and to obtain samples
for the test plot. Mathes provided draft visual criteria
guidance document to IEPA.
Mathes met with Galesburg Sanitary District to discuss
acceptance of groundwater. .
. . .
During September, the PRPsissued the aquifer test report for
agency use.
During this week, PRPs attempted a trench test, but test was
impeded because of low groundwater elevations in the till unit.
During this week, backgro~d samples were collected from the
GaleSburgSanitary Distric~~treatment plant.
~
OS/89/3302e(30l7)3
-------
.'2.
Table ~, . Continued.
CHRONOLOGY
,
GALESBURG'WOOD-TREATING FACILITY SITE
Date
Activity Description
22-Sep-S8
ll-Oct-88
20-0ct-88
02-Nov-88
07-Dec-S8
l3-Dec-S8
20-Dec-88
20-Dec-88
to
22-Dec-SS
lO-Jan-S9
31-Jan-S9
. OS-Feb-89
23-Feb-S9
03-Mar-S9
03-Mar-S9
l3-Mar-S9
30-Mar-S9
07-Apr-S9
.' ll-Apr-S9
l3-Apr-S9
PRPs met with IEPA and IOAG in Sprinqfield to discuss
proqress. Reached aqreement in principle on visual criteria.
PRPs met with IEPA,IOAG, and USEPA in Sprinqfield. Major
topic biomonitorinq.
Issued ~eystone preliminary test plot drawinqs.
Mathes met with IEPA and USEPA in Sprinqfield to discuss
preparation of the FS addendum and schedule. Notified IEPA that
proposed test plot location may be flawed.
PRPs met with IEPA, USEPA, and IOAG in Sprinqfield to
continue neqotiations. Results of limited-success trench test
were issued by Mathes. Confirmed that pro?osed test plot
location appears to be technically impract1cal, due to hi~h
qroundwater elevations. Committed to check water levels l.n
northwest corner of the site. .
Mathes issued E!OTW backqround samplinq report.
Results of PRP-collected fish samples from Lakes Storey and
Bracken were issued to IEPA by Mathes.
Installed four monitorinq wells in northwest corner of site
to investiqate suitabilitr of area for use as a bioloqical soil
treatment test plot locat1on.
PRPs m.t with.IEPA and IOAG in Sprinqfield to discuss
bioloqical soil treatment test plot monitorinq.
Issued Best Available Technology (BAr) report discussinq
qroundvater treatment and disposal options.
PRPs met with IEPA in Sprinqfield to discuss all remaininq
sit. issues. .
Ma~es issued Draft 2 of FS Addendum to USEPA, IEPA, IAOG,
BNKH, and Beazer Materials and Services for simultaneous review.
IEPA issued proposal for evaluation of ~e performance of
bioloqical treatment of site soils.
PRPs issued Addenda to Endanqerment Assessment.
Ma~es issued letter to Hunter/ESE describinq resolution of
comments on Draft FS. Copies were sent to IEPA, USEPA, IOAG,
aDd PRPs. .
Hunter/ESE issued Draft Final Feasibility Study Report.
Ma~es met with IEPA and USEPA to discuss aqency comments on
Draft 2 of the FS Addendum.
PRPs met with IEPA, USEPA, and IOAG to continue workinq toward
resolution of issues.
Teleconference between Mathes, IEPA, and USEPA to discuss the
aqency's comments on Draft 2 of the FS Addendum
. .;..~...
05/89/3302e(3017)3
-------
O~c;.'M~ rS
- DRAFT 2
~
Table ~
ALTERNATIVES EVALUATED BY ESE
)II!
GALES BURG WOOD-TREATING FACILITY SITE
ESE
Alternative Treatm~t Technoloaies Cateaorized bv Environmental Medium
Number Soil Groundwater Lime Sludge
2A Ezcavation Deep Aquifer:. On-site landfill
On-site landfill Extraction.
NPDES discharge
Shallow Aquifer:
InterceEtor
trenc es
Treatment at
POTW
2B Ezcavation Deep Aquifer: Backfill
On-site incineration Eztraction
Backfill Ash NPDES discharge
Shallow Aquifer:
InterceEtor
trenc es.
Treatment at
POTW
2C Ezcavation Deep Aquifer: Biological soil
Land treatment Eztraction treatment as
NPDES discharge amendment to 50-
Shallow Aquifer:
InterceEtor
trenc es
Treatment at
POTW
3A Ezcavation Deep Aquifer: Backfill
On-site incineration Extraction
Backfill Ash NPDES discharge
Shallow Aquifer:
InterceEtor
trenc es
Treatment at
POTW
3B EzcavatiOD Deep Aquifer: On-site landfill
On-site landfill Eztraction
NPDES discharge
Shallow Aquifer:
InterceEtor
trenc es
Treatment at
POTW .;
3C Excavation Deep Aquifer: Biological soil
Biological soil . Extraction treatment as
treatment NPDES discharge amendment to soil
Shallow Aquifer:
InterceEtor
trenc es .
Treatment at
POTW
Note:
These alternatives are not evaluated in this FS addendum.
. ""'--"~
02/89/3302e(3017)2
-------
- DRAFT 2 -
Table ~, Continued
~
ALTERNATIVES EVALUATED BY ESE
GALES BURG WOOD-TREATING FACILITY SITE
ESE
Alternative Treatment Technoloqies Cateqorized bv Environmental Medium
Number Soil Groundwater Lime Sludge
4A Excavation Deep Aquifer: Backfill
Biological soil Extraction
treatment .NPDES .discharge
Grade. and cover Shallow Aquifer:
InterceKtor
trenc es
Treatment at
POTW
4B Excavation Deep Aquifer: Backfill
B1ological soil Extraction
treatment NPDES discharge
Shallow Aquifer:
InterceEtor
trenc es
Treatment at
POTW
4C Excavation Deep Aquifera Backfill
Bioloqical soil Extraction
treatment NPDES discharqe
Caps - Multimedia Shallow Aquifer:
- Concrete InterceEtor
trenc es
Treatment at
POTW
SA No action No action No action
Note I
These alternatives are not evaluated in this FS addendum.
;'
. ..."""",
02/89/3302e(3017)2
-------
- DRAFT 2 -
.. 4
Table ~
ALTERNATIVES EVALUATED IN THIS ADDENDUM
~
GALESBURG WOOD-TREATING FACILITY SITE
A.lternative
Nwnber
Soil
Groundwater
Lime Sludge
1
2
No action
BAX.
BAX.
No action
Gondola cars:
Biological soil
treatment
Old spray field area:
Amendments
Biological
3
On-site incineration
BAX.
Gondola cars:
On-site incineration
Old sprar field area:
Backfi 1
Gondola cars:
On-site landfill
Old sprar field area:
Rackfi 1
4
On-site landfill
BAX.
5
6
Capping
No action
BAX.
Capping
No action
No action
.
Best available technology includes:
o
deep sand aquifer - direct discharge to POTW;
north till aquifer - direct discharge to POXW; and
o
o
south till aquifer - oil/water separation and
aeration prior to discharge to POTW. ..
biological
.....""....
02/89/3302e(3017)2
-------
~
~
tI.mA:
~ water
~il ~ticn
,-reat.ed Soils
TN3IB 5
a.FM-UP CD1S
I
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-------
@
ILLINOIS E~VIRON'IENT AL PROTECTION AGENCY.
I)A TE:
Decem~er 6. 1988
ro:
F R 0~1:
Jim O'Brien
SUBJECT:
8AQ(.~ Pd.. 1ML:L .
C9
~.
~IE~IORANDC'I
7}j-
During OCS's review of Koppers' comments on the Generic PNA Cleanup Guidance
memo of February 8. 1988 it has come to our attention that new information
is available for naphthalene and anthracene. This information enables
us to propose a cleanup objective for naphthalene for the protection of
human health and to update the cleanup objective for anthracene for protection
against aquatic toxicity.
Naphthalene - In the February 8. 1988 memo it was stated that inadequate
toxicity data exists for naphthalene to recommend a cleanup level for protection
of' human health. The August 11, 1988 update of the risk characterization
tables of the Superfund Public Health Evaluation Manual contains an Acceptable
Intake - Chronic (Ale) value for naphthalene of '0.4 mg/kg/d. based on the
Health Effects Assessment (HEA) for naphthalene. This value has been used
to calculate an acceptable lifetime intake from water, using standard USEPA \ . .
techniques and assumptions for "body weight (70 kg) and drinking water ingestion
rate. (2 lId). The calculated'acceptable lifetime intake from drinking
water is:
By: Thomas C. Hornshaw
lene and Anthracene Cleanup Objectives
0.4 mq/k~ 70 kg . 14.0 mg/l.
2.0 /d
,
This value assumes .that there. is no contribution of naphthalene to the
daily intake from other routes of exposure. However,it has been well
documented that exposure to volatile compounds in drinking water can be
increased by the inhalation route and possibly the dermal route as well.
Using USEPA's standard assumption of 20S of the total exposure coming just
from drinking water. the acceptable lifetime concentration of naphthalene
in drinking water is:
20S x 14.0 mg/l . 2.8 mg/l . 2.800 ~g/l.
Anthracene: oes has received a paper entitled MThe photoenhanced toxicity
of anthracene to juvenile sunfish {~Spp.)8 (James T. Oris and John
P. Giesy. Jr. AQuatic ~XiC01~qy 6:~, 1985) in which the toxicity
of anthracene to severa spec es of juvenile sunfish was assessed under
conditions of simulated natural sunlight. This reseatch was conducted
to examine the potential for enhanced toxicity of anthracene. a well-known
phototoxic compound. u~der simulated natural light versus standard laboratory
. light conditions. The study was reviewed by oes to determine its degree
of reliability using the rating criteria of the AQUIRE database. and was
found to have the most reliable rating of 1. The reported 96-hour LCSO
,,'value for hatchery-rai sed juvenile sunfi sh under simul ated natural li ght
, conditions was 2.78 ~g/l. This value is used as the 96-hr TLm in the proposed
revision of 'the aquatic toxicity value. incorporating the standard 1/1nth
safety factor for chronic toxicity protection. The proposed value for
anthracene is 0.3 ~g/l. This value sho~ld replace the currently-referenced
value of 2.3 ~g/l. and the new value fo~~he total of non-carcinogenic
PNAs (which is based on the most toxic individual PNA in the group) should
likewise be changed to 0.3 ~g/l.
Il 'n'.ft!l7ft
-------
I'LLINOIS ENVIRON\IENT AL PROTECTION AGENCY
~IE~IORANDU~1
Nove~ber 1, 1988
~~
('
Kurt Neibergall, RPMS/DLPC
Tim Kl uge, Permi ts/DWPC 72£-
:CT: NPDES Limits for Koppers Di scharge
During the October 11, 1988 negotiation meeting with Koppers, we discussed
potential effluent limits for discharges of groundwater to a small unnamed
tributary of Cedar Creek. The discharge point was reported to be approx.
1t miles upstream of the confluence with Cedar Creek. The seven day-ten
year low flow of the stream:is assumed to be zero.
With two modifications, the preliminary limits shown in my April 6, 1988
memo remain applicable. A typographical error in the acenaphthene limit
has been corrected. Also, OCS has suggested that the additive nature of
toxicity of the individual PNA's should be addressed. This has been done
by the addition of a whole effluent toxicity limit. 'The effluent limits,'
therefore, would be as follows: .
",
Parameter
Limit* (ug/l "exc. as noted)
Total phenols
Pentachlorophenol
Benzo(a)pyrene
Benzo(a)anthracene
Naphthalene
Phenanthrene
Acenaphthene
Anthracene
Fluoranthene
pH
BOD
Suspended Solids
NOEC**
100
2
0.5
1
230
10
60.8
2.3
398
6.5-9.0 (std. units)
20mg/l (lOmg/l mo. avg.)
24 mg/l (12 mg/l mo. avg.)
>100% effluent
*Daily maximum concentration
**No Observable Effect Concentration based on a chronic effluent toxicity
test
These limits should still be considered subject to modification pending the
results of the BAT study Koppers is undertaking.
TRK:md
cc:
Tom McSwiggin
NPDES File
Planning Section/DWPC
RECEIVED
NO'!
4 ;988
fEPA.DLPC
'.........
570
-------
..e.
U..\ TE:
\.
FRO":
, SlJ~JECT:
I LL1:\OIS E:\ VIRO~\IE:"4T"\LPROTECTIO~ "\GE~CY
\1 E\IORA:\ DC
tLb>N
n t4.Arl- .
~t.
February 8, 1988
CPRC
COT
.
I ~:
. . I ,,",'"
. ... kt. 'v"
. -.
Gene.ri c PNA Cl eanup Gu i dance
Due to continuing uncertainty concerning what are appropriate cleanup objectives
for polynuclear aromatic hydrocarbons (PNAs) under various environmental
scenarios, OCS has reviewed federal documents, review articles, and recent
studies in the literature in order to compile generic PNA cleanup guidance
for certain of these environmental scenarios. This memo presents a brief
review of PNA toxicity, proposed cleanup guidance for specific scenarios,
and the reasoning for the guidance for those scenarios. The user of this
material should keep in mind that a resource person is available in OCS
for further information and guidance on PNAs.
PNA Toxicity
PNAs are products of the incomplete combustion of carbon-containing material.
As a result of natural and anthropogenic combustion sources, PNAs are nearly
ubiquitous in the environment. They have been reported in soils, waters,
sediments, air, and biota in numerous studies, at generally low (sub-ppm)
concentrations, from around the world. Localized areas of high "background"
PNA concentrations can be found near more-or-less continuous combustion
sources such as coal-burning plants, major roadways, railroad yards, etc.
Ambient PNA concentrations also reflect nearby population density, with
urban samples generally containing more PNAs than rural.
'.
The primary toxicological endpoint of concern with PNA exposures is the
initiation and growth of tumors. Several individual PNAs have been shown
in laboratory tests to be among the most potent carcinogens known, capable
of producing tumors in some laboratory animals from a single exposure to
microgram quantities of the PNA. Many animal and a few plant species have
been shown to have carcinogenic or teratogenic responses to individual
PNAsand mixtures of PNA compounds in the laboratory. Several studies
have shown greatly increased incidences of tumors or birth defects in wild
populations of certain species living in contact with media containing
high (tens to hundreds'of ppm) levels of PNAs. PNAs were ~he first group
of compounds shown to be epidemiologically associated with an increased
tumor incidence in humans, having been shown by Potts in 1775 to be associated
with an increased incidence in scrotal tumors among chimney sweeps. Since.
then, numerous epidemiological studies have shown a clear association between
tumor incidence. and exposure to PNA-containing mixtures such as soots,
coal tars, creosoting mixtures, and certain oils. More recent work has
shown that many PNA compounds (even if they are not carcinogenic themselves)
are capable of promoting the carcinogenic activity of another cancer-causing
i compound (including the carcinogenic PNAs). For instance, the non-carcinogens
. fluoranthene, pyrene, benzo(e)pyrene. and benzo(g,h,i)perylene, when applied
simultaneously with the carcinogen benzo(a)pyrene, resulted in an increase
in the total number of tumors when compared to only benzo(a)pyrene application.
In addition to the tumor-producing action of the PNAs, other toxicological
endpoints of concern have been associ&ted with PNA exposures. Several
I L 532.0570
E'A.90 (R.... en5-20MI
-1-
-------
. . ~2
of the lower molecular weight PNAs (which are slightly water-soluble) are
acutely toxic to aquatic lif~ or produce deleteriou~ effects at low concen-
trations. PNA mixtures have been shown to be immunotoxic in several species.
of aquatic and terrestrial life, and have been shown to impair reproductive
capabi1iti~s in aqu.atic and terrestrial species as well. PNAs have been
shown to be potent inducers of metabolizing enzymes, and thus are capable
of upsetting the normal metabolic pathways of endogenous and exogenous
substances within an organism. .
PNA Cleanup Objective Guidance
For scenarios' where prolonged human exposure is currently or potentially
possible, such as sites where surface waters or groundwater is or may be
. used for drinking water, where consumption of contaminated aquatic organisms
is a possibility, or where direct contact with contaminated soils is possible,
it is recommended that cleanup objectives be based on Ambient Water Quality
Criteria (AWQCs). COT's recommendation is to treat separately the carcinogenic
PNAs, the non-carcinogenic PNAs, and naphthalene. Parameter values will
be specified for protection against consumption of contaminated water,
contaminated aquatic organisms, or contaminated water plus aquatic organisms,
as appropriate for the specific site's known or projected water use patterns.
For the carcinogenic PNAs, the recommended cleanup guidance is the 10-5
or 10-6 risk level from the AWQC for benzo(a)pyrene for the protection
of consumption of the appropriate contaminated medium (water, aquatic organisms,
or water plus aquatic organisms). Specifically, the sum of the carcinogenic.
PNAs should not exceed the appropriate AWQC ri~k level concentration in
the medium to be protected.
For the non-carcinogenic PNAs (excluding naphthalene) COT guidance is provided
for two cleanup scenarios depending on whether carcinogenic PNAs are also
present in the medium to be protected or not. These .are based on the AWQC
for fluoranthene. If no carcinogenic PNAs are detected at the most sensitive
detection limit practicable, the recommendation is the AWQC for fluoranthene
to protect against consumption of the appropriate contaminated medium. .
However, if any carcinogenic PNAs are detected, then the appropriate AWQC
value for fluoranthene will incorporate a safety factor of ten to protect
against the additive and/or cocarcinogenic effects of the non-carcinogenic
PNAs on the carcinogenic PNAs. In either case, the sum of the concentrations
of the non-carcinogenic PNAs should not exceed the appropriate AWQC level.
For naphthalene, inadequate toxicity data exists to recommend a level for
protection of human health. Therefore, the recommendation for naphthalene
for all scenarios is based on aquatic species toxicity from the AWQC for
naphthalene.
For scenarios where prolonged human contact is not expected, the recommendations
are based on aquatic toxicity data for those PNAs for which adequate aquatic
toxicity data are available. Due to the limited aquatic toxicity data
base for most o.f the PNAs, values for the carcinogenic PNAs and non-carcinogenic
PNAs are based on the most toxic.components of the group (benzo(a)pyrene
.and anthracene, respectively). The guidance is for the sums of the carcinogenic
' and non-carcinogenic PNAs not to exceed one-tenth the acute toxicity level
for the most toxic member of the group in the medium to be protected.
-Z'''''~
-------
~i.
COT recognizes that individual component~ of PNA mixtures display a range
of environmental mobilities and persistence. and that different media at
the same site may contain different mixes of the PNAs. Therefore. it may
be appropriate at certain sites for recommendations to be "tailored" to
each medium at a site. depending on the natur~ (and quality) of the analytical
results. The following tables summarize the human health and aquatic toxicity
i nfonna ti on gathered to d~te for the pri ority PNAs. The "generi C" recommenda ti ons
for waters and soils are listed at the bottom of Tables 1 and 2. respectively.
The values in Table 2 for soils incorporate a 20-fo1d dilution factor.
as in the TClP test. A fonnu1a to calculate site-specific cleanup levels
for sediments is presented in Table 3 with examples using 1% and 10% total
organic carbon contents in sediment.
TCH/psf
-3~~"
-------
, .
Table 1. Water Quality GuidaQce for Priority PNAs.
CAGI AW~(i!g/1)' 1/10 Tlm-96 hr PQl3
Priority PNA Rank Fish & Water Fish Water Chronic Aquatic ~ ~
Acenaphthene N04 N04 N04 520 60..8 18
Acenaphthalene 10
Anthracene 2.3 6.6
8enzo(a)anthracene 82 . 1.0 0.13
Benzo(a)pyrene 82 .00265 .03115 .00315 N04 0.5 . 0.23
8enzo(b)fluoranthene 82 0.16
8enzo(g,h,i)perylene 0.76
8enzo(k)fluoranthene 0 0.17
,. .
J Chrysene 82 1.5
'
OibenzO(a,h)anthracene 82 0.3
Fluoranthene C 42 54 200 N04 398 2.1
Fl uorene 2.1
Indeno(1,2,3-c,d)pyrene C 0.43
Phenanthrene 0 10 6.4
Pyrene 2.7
Carcinogenic PNAs .00285 .03115 .00315 0.57
-4- £
~
-------
Table 1. Water Quality Guidance for Priority PNAs.
CONTINUED
CAG1 AW~ 1/10 Tlm-96 hr PQl3
Priority PNA Rank fish & Water fi sh Water Chronic Aquatic ~ liJQ/l t
Non-Carcinogenic PNAs 42 54 200 2.37
.(no carcinogenic.
PNAs detected)
Non-Carcinogenic PNAs 4.2 5.4 20.0 2.37
(other carcinogenic
PNAs detected)
Naphthalene ND4 rm4 ND4 NA6 230 10
/. .
t
-5-
~
~
-------
I'
'., .
Tab1e 2. Total Soil Concentration Cleanup Guidance for Priority PNAs.
"
CAGI AW0IAg/ kg) 1/10 Tlm-96 hr PQl3
Priority PNA Rank Fish & Water Fish Water Chronic Aquatic ~ _(lAg/kg t
Acenaphthene N04 N04 N04 10,400 1216 1200
Acenaphtha1ene .660
Anthracene 46 660
Benzo(a)anthracene 82 20 8.7
8enzo(a)pyrene 82 0.0565 0.6225 0.0625 N04 10 15
. 8enzo(b)f1uoranthene 82 12
Benzo(g,h,i)pery1ene 51
Benzo(k)f1uoranthene 0 11
.,. .
t Chrysene 82 100
Dibenzo(a,h)anthracene 82 20
F1 uo ran thene C 840 1080 3760 N04 7960 140
F1 uo rene 140
Indeno (1,'2,3-c,d)pyrene C 29
Phenanthrene 660
Pyrene 180
Carcinogenic PNAs 0.0565 0.6225 0.0625 107
-6- ~
~
-------
(joule~. IULOI ,)UII I..OIlt;~II.LrcHlon 1.Ieanup bUldance for Priority PNAs.
CO' IUfO
CAG~ AWQ~(iJg/kg) 1/10 Tlm-96 hr PQl3
Priority PNA Rank Fish & Water Fish Water Chronic Aquatic ~ J iJg/kg t
Non-Carcinogenic PNAs 840 1080 4000 467
(no carcinogenic
. PNAs detected)
Non-Carcinogenic PNAs 84.0 108.0 400.0 467 ---
(other carcinogenic
PNAs detected)
Naphthalene N04 N04 N04 NA6 4600 660
,. .
t
~
~
-7-
. ~.'
.- .'
. ',', :: ' I
. .t' .
-------
. '
Table 1 & 2 Footnotes
1 USEPA's Carcinogen Assessment Grou~: 82 signifies a compound has been
shown to be carcinogenic in laboratory animals, but there ii inadequate
evidence for human carcinogenicity (=, probably human carcinogen); C
signifies limited evidence of carcinogenicity in animals but an absence
of data in humans; 0 signifies inadequate a~imal evidence of carcinogenicity.
1911.
2 Ambient Water Quality Criteria for the protection of consumption ~f
aquatic organisms plus water, for consumption of aquatic organisms only,
for consumption of water only, and'the protection against chronic aquatic
toxicity.
3 Lowest Practical Quantitation Limit for analytical methods listed in
SW 846.
4 Not detennined; insufficient data to pennit establishing a criterion.
5Yaluelisted corresponds to a 10-6 risk level. Yaluesfor soil correspond
to a 10-6 risk level multiplied by a 20-fold dilution factor as specified
in TCLP tgst. ' .
6 Not applicable; criterion developed for saltwater species, inadequate
data for freshwater species criterion.
.7 Aquatic toxicity val~es for total carcinogenic and non-carcinogenic
PNAs reflect values for the most toxic of the individual carcinogenic
(= 82) and non-car~inogenic PNAs.
.
. :tJ
I
-8- ~.
....~
-------
e
ILLINOIS ENVIRON~IENTAL PROTECTION AGENCY
~IE~IORA~D'
DATE:
June 19, 1987
I k2..
TO:
CROPA
$~
FROM:
SUBJECT:
COT/Sharron LaFollette
Ga1esburg Koppers Cleanup Objectives
. On 11 June 1987 COT reviewed information regarding the proposed remedial
alternative at the railroad crosstie treating facility of Koppers Company
Inc. south of the city of Galesburg. This site has been evaluated under
CERCLA and placed on the US EPA's National Priority List. To date Koppers
has completed the Remedial Investigation (RI), Endangerment Assessment
(EA), and Feasibility Study (FS).
The remedial alternative suggested by Koppers focuses on groundwater
management (deep and shallow aquifers) with an estimated 75 year reclamation
time to reach the 10-6 excess unit health risk based on criteria for
polycyclic aromatfc hydrocarbons (PAHs). Koppers has proposed minimal
source excavation and then only in drip track and storage pad areas located
adjacent to the operating facility. The excavated soil would undergo
biological land treatment on the southwest corner of the property. The
drip track and storage pad areas would then be capped with concrete.
The lagoon areas would not be excavated but would be backfilled and covered
with a multi-media 50il cap. .
After careful review of data provided by Koppers and that collected during
the Steagall landfill investigation, COT recommends quantitative, health-based
cleanup objectives for water and soil. The water objectives apply to
both the shallow and deep aquifers which are currently used by nearby
residents and surface water which drains via Brush Creek to Lake Bracken'
from which some residents draw their water. The soil objectives apply
not only to the drip track and storage pad areas, but also to lagoon
areas, gondola car contents. and lime sludge piles. If the Agency agrees
to the use of biological land treatment at the Ga1esburg Kopper site.
COT also recommends that the soil objectives apply to the biological
land treatment unit as a means for judging completeness of th~ biodegradation.
COT also recommends that water objectives apply to any leachate collected
from the biological land treatment unit.
Koppers remedial alternative focuses on the cleanup of PCP. phenols.
and PAHs. Since stockpiled lime sludge is being considered for backfill
in the lagoons and soil amendment for the biological land treatment unit.
COT also recommends a pH objective to enhance revegetation.
The remedial alternative predicts a minimum groundwater cleanup time.
. of 75 years.' COT recommends that the cleanup objectives are reviewed
every five years. If additional health information or cleanup objective
guidance has been compiled. the cleanup objectives may be revised at
,this time. .
. ""~'"
II. 532.0570
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. ,
. .-
~Ct-1~
~p~
~ '5
';'z.
Chemical Wa te r Soil Comments
PAH (excluding .0028 ~g/l .0028'~g/1 US EPA Water Quality Criteria
naphthalene) (TClP) Based on 10-6 Risk level'
Phenols 1 ~g/l 1 ~g/l 35 IAC 302.304
(EP Tox)
PCP 220 ~g/l 220 ~g/l 20% USEPA H.A. 9-30-85
(TClP)
naphthalene 230 ~g/l 230 ~g/l 1/10 TLm 96-hr
( TC lP )
pH 6.5 - 9.0
SEL/psf/039
~ ) N '"Al.. o~a1 '-t{.<; -- ~u.6~t.s' ~6.M.'Tt,.."r' ~ rs.b
. .;".",,~
-------
- DRAFT 2.-
~
Table ~
ESTIMATED VOLUMES OF SOIL CONSIDERED FOR REMEDIATION
y
GALESBURG WOOD-TREATING FACILITY SITE
Location
Estimated
. Area (ftl)
Penta Lagoon
North Creosote Lagoon
7,500
1.,740
Estimated Estimated
.Depth (ft) ~ .Volume (yd3)
3 830
9 4,920
6 6,160
3 760
Drip 'Tracle Area
East of Retort Building
27,720
6,810
Subtotal
Swell Factor (20')
12,660
2,532
TOTAL
15,192
Note: These estimated soil volumes are considered for remediation as part"o'f
Alternatives 2, 3, and 4 only) Afo4,b ~~ 1L~"t1N'IJ> ~~ c.DS1 P~E:S.
....""""...
-------
,
Table ~
~'\
9:-~ SUIflARY OF = ESTI!!I\:rn; FOR ALTERNATIVES
Q
GALESBURG tmD-TREATrnG FACILITY SITE
Total
Construction and Annual
Implementation. O&M Present
Alternative Cost Cost WJrth
1 BAT groundwater $913,419 $168,912 $2,505,-38
treatment
2 Biological soil $2,684,155 $170,012 $4,286.':44
treatlrent,
BAT groundwater
treatlrent
3 On-site $16,664,182 $170,012 $18,266,371
.: "i.neration,
groundwater
treabnent
.1 On-site landfill, $3,574,755 $177,012 $5,243,~32
BAT gr01..tl'ldwater
treatlrent
5 Cappinq, $1,261,315 $170,412 $2,867,:74
. BAT groundwater
treatment
; No action $74,784 $59,200 $632,857
'~:
rhe present \ooOrth calculation was performed according to the method shown lJ1
. \ppendix A at a discount rate of 10 percent over 30 years.
"'......
~
. .
.. "
. .
"": "
. .
. ..
-.. .
. .
. .
. .'
.. .
.' .
. . ....
. .
.... . '.
. .
-. .
-------
~&v.c6- ~~ ~~6ttt&tr ~
. .
~ IH~.~ ~ F~ 1cD'PU.~ (t]: ~l-'f
~.'~I'~B'.
,,~
ItUPPI!ItS.1/EA":IITIZZ.I,Z
iZ/04/86
Table S'
Sua8Ar, of Oo.lte COncentration. and Olatrl~tlon of loppar. Indicator thealcal.
Indlrator Chealr.1
or Cia..
PCP 1.81000
Drip Trarlr.
1.8aoon Araa.-
Plant
Area
lIorthar. Drip
Traelr. Area
lal.tln, Spra, '1.ld-
Soil Concentration. (aa/...)
PNA.
Toul Carrlno,enlc PIIA. 41.1 - 469 15 - 6.4 . 105 110 - 1.9 . 10 , 4.2 - 1.9 . 104 4 - )I 1.41 - ).6 8104
Toul Nonrarrlnoaaolr PIIAa 141 - 2.4 . 104 2.1 . 10) - 6.S . 106 lID - 1.4 . 101 1.0 - 6 . 10S 10 - ]9 1.2 . 101 - 2.8 . 104
'henol. : 11 - 105 126 - 1 . 101 110- 1.6 . 106 .NO - 1.1 . 101 lID - In 58 - Z.\ a 101
PCP NO - 2.1 . 101 liD - 690 110 - 1.6 . 101 II) - 540 liD NO - )8
Naphthalena 121 - 186 119 - I . 106 110 - '.8 . 106 NO - 8.1 . 10S 44 - I, SSO NO- 81
01081 n.
H"udloatn. 0.0058 NO IIA NA iliA NA
Heptadlodn. 0.112 NO NA NA iliA NA
OCUdl"dn. 0.201 NO ItA NA IIA NA
'uran.
lIeufu,ana 0.016 110 NA NA itA N~
l' ' Heptdurana 0.064 110 NA NA NA NA
t Octafurana o.nz 110 IIA NA NA NA
;
Ground Watar Concentratlona (ua/L)
PNAa
Total Carrlnogenlr PNAa
Shallow TI II NO - 11.4 IIA liD - 4.6 . 105 NO - 0.95 110 - 1.0 NO
Deep Aqul fer 110 - 0.16 NA NO - 48 NO - 0.16 t NO
Total Nonrarclnogenlc PltAa
Shallow TII I 110 - 841 NA 110 - 6.1 . 106 NO-li liD - 1.1 . 10' NO
Deep Aqul fer 0.04' - )2 IIA 110 - 1.4 . ,101 NO t 0.0) - 0.21
I'henola ;
Shallow Till NO - 180 ..... NO - 1.5 . 104 NO-I)
Deep Aqul fer NO - 10 NA NO - 160 NO NO - no NO
, NA
-------
1r'z.
&OPP&IS.l/EA-HTI22.1.4
12/04/86
Tabl.
Sua..r, o~ OoalC8 Cane.atraClona and DlatrlbuClon of lopp.ra ladlearor Cbealeala (Continued. 'al. Z of Z)
Indltaror Che.leal 'bpr llarthero Drl,
or Ch.a .cr ""000 Drip Tradt Laloon .r.aa- "r.a TraelL .r.a ItdaUnl Spra, FhU.
.CP
ShaUo" Till liD - ).2 . 10) IIA NO - 8.4 . 104 liD - n.7 MD - 4 . 10) ND - 46.9
Deep Aqul fer liD - I.) IIA NO - 146 NO I NO
"aphthalana liD - I.S . 104 NO - 6.9 . 106
ShaU- Till IIA NO - 6.1 liD - ) . 10) NO
Deep Aqul fer lID - )67 8IA lID - S.7 . 10) O.lS - 0.)1 I NO - 0.21
Air Coneentrarlona (011/.))
'HA.
Toul C.rclnogealc 'MAa 0.011 0.0098 NO 0.0021 II' 0.026
Tara' Nontartlnol.nle 'MAe I.S8 ).u 0.186 I.s) 8IA 1.~61
'henola liD lID KD NO II. 127.7
.J"'CP liD lID 110 NO II. 110
, .
,
"aphrhalene 0.0898 O.U lID NO MA 0.296
110 . not deretred.
IIA . not anal,&.d.
011/.) . "erolra. per cubic ..t.r.
-In Secrlon ).4. Far. and T~aD.port. Anal,al., lalooa araaa aad ..I.tla, apra, fl.ld ar. ,rouped tOI.rher and tr..tad aa a CQ880a
lourc:a area.
INo vella In.ralled.
Source:
ES&, 19868.
-------
KOPPERS/GALESBURG DECISION SUMMARY
APPENDIX B -- RESPONSIVENESS SUMMARY
. ....~...
-------
KOPPERSfGALESBURG SITE
RESPONSIVENESS SUMMARY FOR DECISION SUMMARY
Overview
The IEPA recently held a public comment period for the KoppersfGalesburg
project from May 22. 1989 through June 12. 1989 for interested parties to
comment on the voluntary Remedial Investigation and Feasibility Study (RIfFS)
prepared by the Responsible Parties (RPs) and the proposed plan prepared by
IEPA, in consultation with USEPA. This public comment period was held in
accordance with federal Superfund law (CERCLA Section 117) and applicable
Illinois state law. For this project two public hearings were held; the first
took place on May 23, 1989 at which primarily site and study background
information was presented along with the Agency's preferred alternative; the
second .was held on June 8. 1989 which focused on the preferred alternative and
public comment on the project.
. The purpose of this responsiveness summary is to document the Agency's
responses to verbal and written questions and comments received during the
public comment period. These questions and comments were considered prior to
selection of the final remedy for the Koppers/Galesburg site which is
documented in the ROD declaration and decision summary. The Community
Relations section of IEPA will formalize this responsiveness summary for
distribution to parties on the extensive site mailing list in the near future.
Responses to Questions and Comments Received at the Public Hearinqs
The following questions are paraphrased from verbal comments received at the
KoppersfGalesburg public hearing(s).
Question 1.:
Were contaminants in the sediment and water of Brush Creek evaluated during
the RI?
Response:
Sampling performed by the Responsible Parties (RPs) as part of the original RI
in 1985 did not include sediment and water in Brush Creek "off-sitell.
However. supplemental off-site data collected in several phases by IEPA as
part of the Steagall Landfill investigation (some of which have been
split-sampled by the RPs) has been utilized in the development of the
KoppersfGa1esburg endangerment assessment (EA>, EA addendum and subsequent.
feasibility study. Further study of Brush Creek and Lake Bracken is
anticipated under the Steagall Landfill project in the near.future.
Question 2:
Du~1ng the past winter (1988-89), there appeared to be an unusual build-up of
ice in Brush Creek. as well as an incident with discolored surface water in
February. Were these conditions due to discharges from the KoppersfGa1esburg
site?
. ~"""...
-------
Response:
Samples of the surface water in February by IEPA contained trace levals of a
couple of volatile organic compounds. While the selected remedy for the
Koppers/Galesburg site has not been implemented. (and contaminant releases to
surface waters existing conditions are possible. although not likely) the
observed water contaminants are not characteristic of Koppers' wastes and are
probably associated with the Steagall Landfill or another source. As stated
in the response to Question 1. further study of Brush Creek is planned.
Question 3:
How does the biological treatment process in the experimental cell function?
Response:
Several background documents on the'biological degradation of wood-treating
wastes have been developed by the responsible parties and can be reviewed by
interested parties at lEPA's central office upon request. Basically. microbes
which are present in. and acclimated to. contaminated soils on-site will be
optimally managed in a controlled environment within the pilot cell by
additions of water. nutrients and oxygen to maximize their population growth
and use of contaminants as a "food source". Wastes will be added in
consistent ratios and volumes of contaminants to maintain this optimal level
of biological activity. For the full scale on-site cell. once treatment of
each discrete layer of contaminated soil is complete. (i.e. significant
toxicity reductions achieved) a new layer will be added to the cell and the
process will be repeated. This cycle will continue over several years until
all identified grossly contaminated soils are remediated. Long-term
management measures to prohibit access to the cell and erosion of the final
vegetative cover will then be implemented.
Question 4:
How will surface water run-off be collected once the preferred (selected)
remedy has been constructed?
Response:
It should first be noted that during remedy construction. contaminated surface
water and sediment generated during excavation of "hotspots" will be
effectively contained on-site and treated/disposed of in a proper manner.
Those measures will be implemented while phased excavation. backfilling.
regrading and revegetation of each affected area is ongoing. and continue
until that surface work is complete and approved. Measures to be taken would
most likely include clean water diversion and collection of contaminated water
through construction of temporary open ditch systems and properly sized
sedimentation ponds. Collected water would most likely be pumped back to the
fac'lity wastewater system for pretreatment as necessary. followed by
d~scharge to the POTH for final treatment.
. .
'.
2
. "',""""
-------
]9"
'~
~ to Written Questions and Comments Received Durinq the Public Comment
ee letters were received at the close of the public comment period. two
m counsel representing private parties and one from the environmental
su1ting firm retained by the responsible parties. Those questions and
'ments are paraphrased here for conciseness of this summary.
stion 5:
, ,
inquiry was made concerning procedures for individuals to file claims with
Agencies for reimbursement of damage to property affected by a
taminated site.
ponse:
re are no provisions within CERCLA/SARA or state environmental law for
ividua1s to file claims with the regulatory ~gencies to recover damages
m a Superfund site. However, ,individuals could pursue damage claims
ough private legal actions against the responsible parties for a site.
stion 6: '
inquiry was made concerning consideration by the Agency of technical
]ents on the Koppers/Galesburg RI/FS after the close of the public comment
lor
ponse:
le remedy selection in the Record of Decision is based on public comment
~ived throughout the development of the study and its formal comment
lod, the Agency will accept and consider comments in subsequent phases of
,project., Such comments would be placed in the masterfl1e and become part
the site administrative record. Responses to comments received would be
~ by the Agency as appropriate. '
1nical questions and comments received from the RP's on the proposed plan
as follows:
stion 7:
Jestion was raised on revision of the groundwater r-~s10ration computer
~ 1 ..
ponse:
'. .,
results of the groundwater computer model being revised by an independent
sultant to USEPA will be available in July 1989. This model is being
ined to account for positive impacts to the existing groundwater pollution
Jlem from both the selected remedy (i.e. source removal and groundwater
le~. '?n/flushing) and in-place natural biological degradation of residual
1 tamination during groundwater ,remedy implementation.
. "
3 . ~....~
-------
Comment.8:
A comment was received from the responsible parties concerning Resource
Conservation and Recovery Act CRCRA) Applicable or Relevant and Appropriate
Requirements CARARs). They maintain that RCRA is ~ot applicable to the waste
areas being addressed or the activities planned under the selected remedy.
Response:
The IEPA and USEPA position on RCRA ARARs is detailed in the decision summary
for this site. It is the opinion of the Agencies that RCRA action-specific
requirements are relevant to all activities performed pursuant to the selected
remedy, and directly applicable to a portion thereof. .
Comment 9:
A comment was received from the responsible parties concerning the conceptual
approach by the Agency for long-term groundwater monitoring.
Response:
The Agency believes RCRA groundwater monitoring requirements are at least
relevant to given site conditions and the selected remedy. At the same time,
the CERCLA program advocates tailoring a monitoring program to site-specific
characteristics and will be working toward that during Remedial
Design/Remedial Action (RD/RA) settlement negotiations with the RPs.
Comment 10: .
A comment was received from the responsible parties concerning the
siqnificance of a reduction in the final toxicity of wastes in comparison to
their initial toxicity in the successful demOnstration of the biological
treatment technology. . .
Response:
While final toxicity of treated wastes will be assessed in comparison to
initial toxicity, long-term management measures will also be determined by
toxicity reductions in relation to the goal of attainment of background
toxicity qualities because remedial actions must be protective of human health
and the environment. The other focal point of the demonstration study will be
to establish the leachabtlity characteristics of waste soils to be treated.
Full scale application of this technology must effectively control leachate
from the cell so that it doesn't contribute additional contamination of the
groundwater.
Question 11:
A question was received from the RPs concerning USEPA Region V's level. of
a~ceptance of the preferred alternative (currently the selected remedy).
4 . ~a~...
-------
1sponse:
The support Agency for a project (in this case USEPA for the Koppers/Galesburg
site) provides technical and policy comments on the lead Agency's preferred
alternative through the Record of Decision (ROD) process. USEPA, Region V is
supportive of the preferred alternative (and at this stage, the selected
remedy) and will express this position of concurrence in the ROD.
Question 12:
A question was received from the RPs concerning the significance of the
identification of additional waste areas to a table in the final proposed plan.
Response: The areas added (interceptor ditch and waste pile) have been
previously noted as former waste management areas by the RCRA program and were
recounted here for completeness in identifying all areas of potential
concern. Discussions on additional RCRA requirements, if any, for these and
other areas to satisfy RCRA program concerns through a CERCLA enforcement
agreement will take place during forthcoming RD/RA settlement negotiations.
Comment 13:
A comment was received from the responsible parties concerning their position
on groundwater chemical-specific ARARs to be met and confirmed prior to
certification of the remedy as complete.
)sponse:
The IEPA's and USEPA's position on chemical-specific "clean-up" objectives for
groundwater is documented in detail in the decision summary of the ROD. This
position ;s based on protection of human health and the environment for the
conditions present at the Koppers/Galesburg site.
KN:rd/sp2239kJl-S
5~M
-------
. KOPPERS/GALESBURG DECISION SUMMARY
APPENDIX C -- SITE ADMINISTRATIVE RECORD
~.~
-------
.
."
p.
v
DATE
OS/29/81
06/1 0/83
09/23/83
02102/83
01/20/83
11/30/83
12102183
Dec-83
01/18/84
Jan-85
Jan-aS
Mar-85
Mar:"85
04/19/85
'J4/30/85
05/01/85
QS/OZ/85
05/02185
ADMINISTRATIVE RECORD
GALESBURG/KOPPERS
Thr6ugh May 16,1989
TI TLE
Hydrogeologic Investigation of the
Koppers Comcany Plant
Draft Remedial Action Master Plan
Remedial Action Master Plan
Me~o re: sampling of residential
we II s
Letter re: sampling of residential
we 11 s
le:ter r~: same1 ing cf p1ant
'perimeter '"ells'and results
letterre: sampling of plant
drinking water ~ell and results
Total Microbial Detoxification
of Pentachlorophenol
Memo re: acceptable groundwater
concentrations of PAH's
Technical Memorandum -
Prelimtnary Evaluation
Project Health and Safety Plan
Geophystcal Survey Work Plan
Hydrogeologtcal Work Plan
Draft Review Comments on
Saine» 1 i n9 Plan
Memo re: 3/25/85 meeting
Project Health and Safety Plan
Phase I! ~rk Plan -
Immediate Remova1
Memo re: draft comments on Phase II
Work Plan
. ..;............
AurHOA
JAQuagllotti -
Koppers
CH2M Hill - USEPA
CH2M Hill - USEPA
SRao - rDPH
MAFranck - Koppers
I~AFranck
Koppers
MAFranck - Koppers
JGSteiert. et al.
UMtnnesota
Center For Disease
Contro 1, HHS'
ESE
Environmental Sc. &
Engineering (ESE)
ESE
ESE
DCrandall - IEPA
DCrandall - IEPA
ESE
ESE
DCrandall - IEPA
PAGES
88
94
97
3
.3
5
12
41
31
4
14
2
3
33 .
25
3
-------
DATE II TLE AUTHOR P.~GES
05/03/85 Ph~se II Project Health and ESE 33
Safety Plan
05/03/85 Techntcal Memorandum - ESE 67
Preliminary Evaluation
. Os/J0/8S Geophystcal Survey Work Plan ESE 4
OS/J 3/8S RIfFS Work Plan ESE 40
Os/24/8S Letter. re: comments on DCranda 11 - r EPA 3
Hydrogeologi C Work :)1 an
OS/28/85 Phase II Air Monit:ring Plan ESE 9
06/03/8S Hydrogeological.Wcrk. Plan ESE 17
Jun-8s RI/FS Project Cua! ':y Assurance ESE 104
P1an
Jun-8s Draft RI/FS Project Quality. ESE 105
Assurance Plan
Jun-8S Second DraftRI/FS Project QualIty ESE 104
Assurance Plan
07/01/8S Memo re: soi 1 sampling DCrandall - IEPA 2
07/09/8S Letter re: QAPP comments DFavero - USEPA
07/11/8S Draft Work Plan for On Site Env. Research & 59
Sotl TreatabIlity Study Technoloqy (ERn
07/24/8S Letter re: comments on Sampling DCrandall - IEPA 3
Plan
07/24/85 Draft RI/FS St~tement of Work I EPA/RPMS 34
07/26/8S RI/FS Sampling Pl~n ESE 40
07/29/8S Letter re: comments on Phase II DCrandall - IEPA 6
Work Pl~n ~nd Project Health and "
Safety PYan .. .
Ju 1-85. Work Plan for On Site Soil ERT 58
TreatabIlIty Study
.Aug-8S The Land Treatability of Creosote I ERT 142
Pentachlorophenol Wastes
09/13/8S Phase II A I r Mon itor t ng Plan ESE 9
. "'."",,~
2
-------
i\A TE
09118/85
09/18/85
..;
1 'J/08/85
11/15/85
11/18/85
12/18/85
12/26/85
':' 1/08/36
'':1/14/36
01/24/86
1.11/28/86
02106/86
02/07/86
02/19/86
02124/86
02/26/86
v
02/27/86
02/28/86
""'28/86
03/04/86
TI TLE
AUTHOR
Run-On/Run-Off Control Plan
ESE
ESE
Contingency Plan
AIr Monitoring Data
ESE
Land ireatment Evaluation Plan
DKerschner -
Koppers
Chapters 1-3. Draft RI Report
ESE
Technical Memorandum - Air
~onitoring Results
SCarter - ESE
letter re: c~mments of Land
Treatment E~aluation Plan
8Bradley - USE?A
:raft RI Report
ESE
~.Iemo r-e: comments on I and trea tmen t
lab study
Plan For Continued Groundwater
Mon Hor i ng
OCr-andall - iE?A
ESE
Letter re: comments on Draft RI
Report
BBradley - USEPA
FS Work Plan
ESE
Letter re: comments on Land
Treatment Evaluation Plan
KNeibergall - IEPA
~es~its. - Ground Water Flow MOdel
DKerschner
Koppers
OKi rschner -
Koppers
Revised RI/FS Schedule
Letter re: comments on draft RI
Report
BBradley - USEPA
Me80 re: comments on draft RI
Re:ort
Me~ re: comments on draft RI
Recort.
OCrandall - IEPA
RTurpin - IEPA
TeChnical Memorandum - FS Goals
SCarter - ESE
KHelbergall - IEPA
Letter re: comments on draft RI
Report
'';'.~
3
PAGES
9
30
48
25
143
18
1
56~
-
.
7
2
9
4
10
2
5
5
2
Z
9
-------
DA TE
03/04/86
03/05/86
03/11/86
03/J Jl86
TI TLE
Letter re: comments on draft RI
Report
Memo re: RI/FS Schedu)e Revision
Letter re: comments on FS Work Plan
Letter re: comments on FS Work Plan
03/J 1/86 . Memo re: Qua Ii ty As surance Data
Evaluation
03/J7/86
03/J 8/86
03/24/86
.) 3/2 6 / 8 6
03/31/86
04/17/86
04/22/86
04/30/86
05/13/86
05/J9/86
05/21/86
OS/22/86
06/06/86
06/06/86
06/09/86
06/1 1/86
.Memo re: plant well contamination
letter re: comments on FS Goals
letter re: comments en FS Goals
Letrer re: response tJ comments
on draft RI Report
Plan For Continued Ground W~ter.
Monitoring
Letter re: 4/4/86 meeting
Memo re: Quality Assurance Data
Letter re: scheduling of remaining
work
Letter re: RI Report and FS
cOlIIJ)letlon
Letter and drip track construction
drawtngs
Letter re: comments on draft RI
Report
Letter re: comments on draft RI
Report
Technical Memorandum"- Surface
Water Monitoring
Memo re: review of QA/QC Data
Final RI Report
Groundwater Treatability Study
Report
.....~~
4
AUTHOR
HChinn - IAGO
KNeibergall - IEPA
KNeibergal1
BBradley - USEPA
SCarter - ESE
DBennett - : E?A
BBradley - USEPA
KNeibergal' - rEPA
SCarter
- ;Sc:
ESE
SCarter - ESE
RTurpin - rEPA
DKerschner ~
Koppers
KNeibergall - IEPA
DKershner -
Koppers
BBradley - USEPA
KNelbergall - IEPA
SCarter - ESE
RTurpin - IEPA
ESE
DKerschner -
Koppers
PAGES
4
2
3
2
"
oJ
7
4
3
3
2
4
7
22
-------
DATE
06/12/86
Jun-87
07/03/86
07/09/86
07/1 5/86
07/16/86
07/25/86
08/08/86
10/29/86
Oct-86
11/18/86
12/02/86
12/1 5/86
12/17/86
12/14/86
12/30/86
Dec-86
D"ec-86
02/1 2/87
Feb-87
TITLE
Technical Memorandum - Potential For
Migration Into Bedrock Aquifers.
Bench-Scale E,BDS Demonstration
Letter re: comments on Final RI
Report
Letter re: groundwater gradient
control
Letter re: response to comments on
Final RI Report
Technical "iemorandum - Asbestos In,
Ground ~ater
Letter re: comment~ on addendum
to RI Report
Addendum No. I to RI Report
Memo re: request for cleanup
objectives review
Draft Endangerment Assessment
Letter re: comments on draft
endangerment assessment
Letter re: response to comments on
draft endangerment assessment
Letter re:comments on final
endangerment assessment and
Incineration Info
Memo re: comments of draft
endangerment assessment
letter re: applicability of SARA
letter re: use of Incineration
Second Draft Endang. Assessment
Final Endangerment Assessment
Letter re: Brainerd EDD
Draft Feasibility Study
.;,..........
5
..\UTHOR
SCarter - ESE
Keystone Environ.
Resources. I nc.
SBradley - USEPA
DKerschner -
Koppers
SCarter - ESE
SCarter - ESE
<~eibergal 1 - IEPA
ESE
KNeibergall - IEPA
ESE
KNeibergall - IEPA
SCarter - ESE
KNeibergall - IEPA
VGupta - IEPA
SCarter - ESE
JFrank - IEPA
ESE
ESE
Jlynch - RETEC
ESE
PAGES
21
2
6
3
5
:1
10
, 9
9
9
7
39
-------
DATE
Mar-a7
04/01/87
04/21/87
Apr-87
05/01/87
06/05/87
06/08/87
:6/26/87
08/03/87
08/21/87
09/30/87
Oct-a7
01/04/88
01/07/88
01/07/88
02/08/88
04/20/88
04/26/88
04/29/88
May-88
06/07/88
Jun-88
;- I iLE
Brainerd Annual Monitoring Report
Letter re: comments on Draft FS
Letter re: response to comments on
Draft FS
Eva)u~tion of Blodegredation System
Letter re: response to comments on
Ora ft FS
Letter re: second comments on
Draft RI
Letter re: 5/27/87 meeting
Letter re: respon}e :0 comments on
Jraft FS
Progress Rpt. - Groundwater Results
Supplemental Report - Ground Water
Contaminant Transport Modeling
Letter re: changes to monitoring
program
Steagall RI Report
Letter re: comments on Draft
Remedial Action Plan
Letter re: comments on praft FS
Memo re: lagoon pit sampling
Memo re: PNA cleanup guidance
Letter re: comments on fish
study QA/QC
Memo re: soil cleanup 1 eve Is
Letter re: 4/26/88 meeting
Statement of Work - EBDS Pilot
Unit
Memo re: comments on monitoring
proposal for treatment pilot
Review of Proposed Cleanup
Guidance for PAH's
..;..........
6
AUTHOR
RET EC
KNeibergall - IEPA
DKerschner -
Koppers
Keystone
SCarter - ESE
KNeiberga11 - IEPA
SCarter - ESE
DKenchner -
Kop~ers
ESE
ESE
SCarter - ESE
Envirodyne Eng.
DKerschner. TPatno
Koppers, Glacier Park
BBradley - USEPA
KNetbergal1 - IEPA
COT - IEPA
TPatnode - Glacier
Park
Mathes
KNeibergall - IEPA
Keystone
KNeibergall - IEPA
Mathes
PAGE$
10
2
8
11
:1
J.
6
14
2
5
3
7
9
4
"
21 .
3
22
3
18
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r')ATE TITLE AUTHOR PAGES
Jun-88 Work. Plan for Aquifer Testing ~athes 33
Jun-88 BIologIcal Degredation of Woed Keystone
Treating Chemicals
07/03/86 Letter re: fInal comments on RI KNeibergall -I EP.I\ 2
Report
Jul-88 GuIdelInes for Field Imp. of Visual Mathes 19
Cleanup Standard
08/09/88 Solute Transport Modeling of PNA MOK Consult.
arid Phenol in Deep Sandy Aquifer
08/09/88 Addendum to Solute Tran~port MOK Consult.
Mode1 Ing
':' a / 1 a / a 8 Letter re: dis:har;e to ?OTW JBrowning - GSD
Aug-B8 Hydrogeologic Evaluation of Aquifer John Mathes & Assoc.
Testing of the Sand Unit
09/28/88 Letter re: 9/22/88 meet1 ng KNe1bergall - IEPA 5
/05/88 Letter re: toxicity testing THlppe - Mathes 2
10/06/88 Letter re: review of ARAR's KNeibergall - IEPA 3
10/24/88 Letter re: water quality for THlppe - Mathes 3
use In SAT mode I I ng
10/31/88 Memo re: prelIm. natural USDept. of 2
resources survey Interior
11/10/88 Letter re: surface water discharge KNe i berga 11 - IEPA 4
1 I mits
11/17/88 Letter re: Mathes conflict of RSchutz - BN
interest
11/17/88 Letter re: toxicity testing KChristensen - IEP 5
.. -
"
11/30/88 Letter re: response to Mathes BHutton - IEPA 1
conflict of Interest
12/06/88 Memo re: PNA cleanup objectives JO'B.rien - IEPA 3
12/07/88 Letter re: RCRA land ban GVonStamwitz - 3
Koppers
12/20/88 Le tter re: 12/07/88 meeti n9 RSchutz - BN 7
BH:rlc/0283kl-7 "'.""...
. 7
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DATE TITLE AUTHOR ' PAGES
Dec.-88 IDPH Health Assessment IDPH 143
12/27/88 Letter Re: RPC Designation B. Noonan-BN 1
01/05/89 Package Re: RP Financial Statement R. Schutz-BN 36
01/30/89 Letter-Schedule K. Nei berga 11 2
01/31/89 Report-BAT Analysis. Mathes 101
Jan.-89 Report-EA Addendum ESE 83
02/22/89 . Letter Re: 2/8/89 Meeting R. Schutz-BN 3
Feb.-89 Draft FS Addendum Report Mathes 102
.03/03/89 Letter Re: Bi omonitori ng B. Hutton-IEPA 5
03/14/89 Letter Re: FS Comment-Responses T. Hippe-BN 6
03/28/89. Package Re: FS Addendum Comments K. Neibergall-IEPA 24
03/29/89 Letter Re: USEPA Air Comments P. Pearce-USEPA 4
03/30/89 Draft Final FS Report Mathes 236
03/31/89 Package Re: Draft FS Addendum Comments K. Neibergall-IEPA 6
04/03/89 Letter Re: Financial Assurance G. VonStamwitz-BMS 2
04/10/89 Letter Re: Biotreatment Cell T. Hippe-BN 20
04/26/89 Letter Re: 4/11/89 Meeting R. Schu'tz-BN 3
05/01/89 Letter Re: Public Comment Period T. Hippe-BN 2
05/01/89 Hearing Notice K. Luly-IEPA 1
05/04/89 Letter Re: BAT Comment-Responses T. Hippe-BN 5
05/10/89 ATSDR Health Assessment ATSDR 20
May-89 FS Addendum Report. Mathes-BN 123 \:
05/16/89 Letter Re: Air Data-Wood Treat Sites RETEC-BN 15
05/18/89 Additional Hearing Notice K. Luly-IEPA 1
05/19/89 Proposed Plan K. Neibergall-IEPA 55
. "-.:,-,,,,,
8
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DATE TITLE AUTHOR. PAGES
06/05/89 Proposed Plan Fact Sheet K. Luly-IEPA 7
06/06/89 Letter Re: BAT Comments T. Kluge-IEPA 3
06/09/89 Letter Re: RI/FS Comment T. Hi ppe-BN 26
06/09/89 Letter Re: RI/FS Comment Z. Lucus 2
06/09/89 Letter Re: RI/FS Comment D. Rosenfeld 1
06/16/89 Draft ROD K. Neibergall-IEPA 88
....~...
9
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ENFORCEMENT AGREEMENT
between the
Illinois Environmental Protection Agency
and the .
United States Erivironmental Protection Agency, Region V
for the
Koppers State Enforcement-Lead Site in Illinois
under the.
Comprehensive Environmental Response, Compensation and Liability Act
as amended by the Superfund Amendments and Reauthorization Act of 1986
PURPOSE
The United States Environmental Protection Agency (USEPA) has determined
that the Illinois Environmental Protection Agency (IEPA) on behalf
of the State of Illinois has the capability to carry out the selection
and implementation of the response actions necessary at the Koppers
facility in Galesburg,. Illinois, including related enforcement actions.
Therefore, the following contract between USEPA and IEPA is agreed
to pursuant to Section 104 (d) of the Comprehenslve Environmental
Response, Compensation and.Liability Act (CERCLA) as amended by the
Superfund Amendments and Reauthorization Act (SARA), 42 U.S.C.s9604.
The Agreement outlines the roles of the respective agencies, with
r 'rd to the Remedial Investigation (RI), Feasibility Study (FS),
~ .osed Plan, Record of Decision (ROD), and implementation of the
ROD during the Remedial Design/Remedial Action (RD/RA) for the Koppers
Galesburg Facility.
BACKGROUND
The IEPA has been the lead enforcement agency for the purpose of
obtaining an enforceable agreement or decision with the responsible
parties to clean up this site consistent with the National Contingency
Plan and a ROD adopted by the IEPA and concurred in by USEPA. Although
the State of Illinois was not formally designated as the lead agency
in an earlier cooperative agreement, cooperative efforts have occurred
during the RI/FS/ROD process between the two agencies, with the IEPA
as the lead agency and the USEPA as the support agency. The USEPA's
,letter dated January 8, 1988, concurred with IEPA's approach to prepare
,the Koppers' ROD and to select the remedy~ and the USEPA's January
5, 1989 letter stated that the Remedial Project Manager would recommend
cthat the Regional Administrator sign the ROD as long as it met USEPA
regulations and policies. USEPA and IEPA have worked closely in
the development of the remedy for the site. The following lists
the work products and significant activities that were available
to USEPA for oversight of the Koppers Galesburg State Lead NPL Site:
....""...
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Page -2
DOCUMENT
USEPA OVERSIGHT
OF STATE LEAD SITE
1.
2.
Draft RIfFS Work Plans
Comrrent
Comment
Quality Assurance Project Plan
Interim Deliverable
File
3.
4. Draft RI + RI Addendum
Comrrent
5.
Draft Endangerment Assessment +
EA Addendum
ComlTent
6.
7.
Draft FS + FS Addendum
ComlTent
Draft ATSDR Health Assessment
Comment
8.
Key Technical Negotiation Meetings
with Responsible Parties
Comment
9~
Proposed Plan
ComlTent
10. Proposed Plan Public Hearings
Participate
ComlT:ent
11. Responsiveness SumlTary
12. State Administrative Record
File
13. Draft ROD
14. Final ROD
ComlTent.
Concur
The IEPA agrees that it will continue its best efforts to obtain
from responsible parties, a cleanup at the facility that is consistent
with the ROD concurred in and adopted by the Regional Administrator
of USEPA. USEPA will continue to provide technical and policy oversight.
IEPA agrees to seek USEPA's written concurrence on any modification
to the remedy provided in the ROD, whether by action amending the
State's ROD, settlement or decree, if such modification differs in
any significant respect from the remedy concurred in and adopted
by USEPA. Should USEPA not agree to any such significant change,
and IEPA proceeds with the significant chahge, USEPA may proceed
to take appropriate action under CERCLA to implement the final plan
adopted and concurred in under the ROD by USEPA.
"
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Page -3
USEPA agrees to infonn IEPA in writing and in a timely manner if
it finds that the remedial action is not being implemented consistent
wi~h'the ROD or any significant modifications concurred in by USEPA.
IEPA agrees to provide USEPA with a written explanation for the matter
of concern and/or to take action, which will be verified in writing
to USEPA, to ensure compliance with the ROD. Should USEPA detennine
that IEPA'sresponse and/or actions continue to be inconsistent with
the ROD, it shall infonn IEPA in writing and may take appropriate
action to implement the approved response actions after full di~cussions
with the respective chains of command.
IEPA agrees to review the remedial action selected for this facility
no less often than each five years after the initiation of the selected
remedy to assure that human health and the environment are being
protected by the remedy being implemented. IEPA shall provide to
USEPA for comment a written copy of such reviews before they are
finalized. USEPA shall provide written comments on the State's review
in order to assur~ that the requirements of 42 U.S.C. 9621s(c) are
satisfied. IEPA shall address USEPA's comments as appropriate in
its final review document. Nothing herein, shall prevent USEPA from
conducting its own review pursuant to Section 121(c) of CERCLA.
If USEPA finds that the selected remedial action at the Site needs
to be modified in any significant respect. it shall notify IEPA in
writing and provide the State an opportunity for com"ent and to make
any necessary changes in the State ROD and submit it for final concurrence
by USEPA. Should IEPA not agree to modifications deemed necessary
by USEPA, USEPA may proceed to modify the remedy pursuant to Section
117 of CERCLA, 42 U.S.C. 9617. .
Nothing in this Cooperati~e Agreement shall prevent USEPA from taking
any necessary response actions, pursuant to Section 104 of CERCLA,
or enforcement actions pursuant to Section 106 of CERCLA, to protect
welfare, human health or the environment.
Any IEPA expenditures on the Koppers Galesburg Site can not be considered
as State match for additional actions taken pursuant to CERCLA/SARA
by USEPA, without written approval by IEPA.
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Page -4
EXECUTION
This agreement shall become effective upon execution by USEPA and
IEPA. It shall remain in effect for the duration of the CERCLA Program
addressed herein unless terminated by mutual agreement by the two
(2) Agencies. .
For the Illinois Environmental Protection Agency
-;
wP~
_~/a1
Date
Bernard P. Killian
Director
IEPA
For the United States Environmental Protection Agency
Valdas V. d mkus
Regional Administ ator
u. S. EPA, Region V
Da
"
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