...
oJ
United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EPAIRODIR05-921219
September 1992
PB93-964127
&EPA
Superfund
Record of Decision:
Central Illinois Public Service,
IL
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
u . ~. Environmental Protection Agency
Region 1/1 Hazardous Waste.
Technical Information Center
84 1 Chestnut Street, 9th Floor
Philadelphia, PA 19107
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NOTICE
The appendices Hsted in 1he index that ant not found in this document have been removed at the request 01
the issuing agenGy. They contain maf8rt8I which supplement. but adds no funher ~ information to
the content of the document. All suppIementaj matsfiaI is, however. conIUI8d In the admIni81lalNe record
for this site. . .
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REPORT DOCUMENTATION 1" REPORT NO. 1 ~ 3. Recipient'a Acceaalon No.
PAGE EPA/ROD/ROS-92/219
... Title and SUbtitle 5. Report Date
SUPERFUND RECORD OF DECISION 09/30/92
Central Illinois Public Service, IL
6.
First Remedial Action - Final
7. Aulhor(a) 8. 1'I"forming Organization Repl No.
8. Performing OrgalniDllon Nama and Add.... 10. ProjectlT..lclWork Un~ No.
11. Contrac:1(C) or Granl(G) No.
(C)
(G)
1~ Sponaorlng OrganiDlion Nama and Addno.. 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. SUpplalll8ll18ry Not88
PB93-964127
16. Abatract (Umlt: 20D worda)
The I-acre Central Illinois Public Service (CIPS) site is a former manufactured gas
plant in Taylorville, Christian County, Illinois. Land use in the area is
predominantly residential, with Manners Park, a multi-use recreational facility,
located adjacent to the site. Seaman Estate pond, located south of the site, is used
for fishing and swimming. Ground water beneath the site is no longer used as a
drinking water source, and residences have been connected to a municipal water supply.
The CIPS/Taylorville plant, constructed in 1892, was operated by CIPS from 1912 until
1932. The plant produced a low-quality gas from coal, which was used for lighting and
heating. Coal tar, produced as a by-product, was typically disposed of offsite, sold,
or given away to be used for various purposes. After higher quality natural gas became
available in the area, the plant was closed. Onsite contamination by coal tar was
discovered in 1985 during site construction. As a result of state investigations, an
immediate removal action (IRA) was performed by CIPS in 1987 to remove all buried
tanks, contaminated soil, and sediment at the site; to provide an alternative water
supply to affected residences; and to implement institutional controls. This ROD
(See Attached Page)
17. Documanl Analyaia L Daacrlptora
Record of Decision - Central Illinois Public Service, IL
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PAHs, phenols)
b. IdentHleralOpen.Ended Torma
Co COSA n F1eldlGroup
18. Availability Statement 19. Security Clu. (Thia Report) 21. No.ofpagea
None 80
20. Security CI... (Thia Page) 22. Price
None
22(4- 7)
50272-101
(See ANSI-Z38.18)
See Inllttvctions on Rewrse
(Formerty NT1S-35)
Dopart...nt of Comma....
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EPA/ROD/R05-92/219
Central Illinois Public Service, IL
First Remedial Action - Final
Abstract (Continued)
addresses a final remedy for the remaining principal threat posed by ground water
contamination at the site, and also documents the prior 1987 removal action. The primary
contaminants of concern affecting the soil, sediment, debris, and ground water at the
site are VOCs, including benzene, toluene, and xylenes; and other organics, including
PAHs and phenols.
The selected remedial action for this site includes documenting the previously
implemented source control measures which included removal and offsite disposal of the
structures associated with the original gas plant; excavation and offsite disposal of
approximately 9,000 cubic yards of visibly contaminated soil down to the ground water
table level and excavation and offsite disposal of 3,000 cubic yards of soil and sediment
from the drainageway section leading to Seaman Estate pond; backfilling excavated areas
with clean soil from offsite; plugging and abandoning private drinking water wells; and
connecting affected residents to a public water supply. The selected remedial actions to
be implemented now include extracting and neutralizing contaminated ground water prior to
onsite treatment in a liquid phase carbon adsorption column, with onsite discharge of the
treated water to the drainageway downgradient of Seaman Estate pond; transporting
contaminated carbon offsite to a facility for regeneration or incineration; removing
precipitated solids from the treatment process, and testing them for hazardous waste
characteristics, prior to appropriate disposal; conducting long-term ground water and
surface water monitoring; and implementing erosion controls, institutional controls,
including deed and land use restrictions, and site access restrictions, including
fencing. The estimated present worth cost for this remedial action is $9,346,034, which
includes an annual O&M cost of $401,400 for 30 years.
PERFORMANCE STANDARDS OR GOALS:
Chemical-specific ground water clean-up standards, which are based on state and federal
drinking water criteria, include benzene 0.005 mg/l; toluene 1 mg/l; ethylbenzene
0.7 mg/l; xylenes 10 rng/l; anthracene 2.1 mg/l; benzo(a)pyrene 0.00023 mg/l; and
2-rnethylphenol 0.35 mg/l. In addition to meeting the individual ground water objectives
indicated certain toxicity equations as defined in the ROD must be satisfied to protect
against liver tumors and liver, kidney, and blood toxicity.
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@
Illinois Environmental Protection Agency
P. Q. Box 19276. Springfield. IL 62794-9276
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Central Illinois Public service (CIPS) Co.
Taylorville Manufactured Gas Plant (MGP) Site
Christian County. Illinois
STATEMENT OF BASIS AND PURPOSE
This decision document represent~ the selected remedial action for the
CIPS/Taylorvi11e (MGP) Site in Christian County. Illinois. This action was
chosen in accordance with the Comprehensive Environmental Response.
Compensation and Liability Act of 1980 (CERCLA). as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA). and to the extent
practicable. with the National on and Hazardous Substances Pollution
Contingency Plan (NCP). This decision is based on the Administrative Record
for thi s site.
The United States Environmental Protection Agency (USEPA). Region V is
expected to concur wi th the selected remedy.
ASSESSJI£NT OF THE SITE
Actual or threatened releases of hazardous substances from the site. if not
addressed by implementing the response action selected in this Record of
Decision (ROD). may present an imminent and substantial endangerment to public
health. welfare. or the environment.
DESC.RIPTION OF THE REMEDY
An immediate removal action. which constitutes an operable unit for this site,
has been canpleted voluntarily by the responsible party under a state
'.superfund notice. Major elements included:
Excavation of source materials above the water table (9.000 c.y. of
soil; 3.000 c.y. of sediment); disposal of source materials off-site in
a permitted landfill; and backfilling of excavation areas with clean
material s.
Connection of potentially affected residents to the public water supply;
and plugging and abandonment of associated private drinking-water wells.
Monitoring of groundwater. surface water. pond sediment and fisn
downstream of the site; completion of a remedial investigation and
feasibility study for the site.
This final remedial action provides for treatment of the remaining principal
threat at the site. that posed by groundwater contiIDination. The major
canponents of the selected remeqy include:
Construction of an on-si te groundwater pump and treat systen; and
operation and maintenance of the system until Agency cleanup objective~
are met.
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Illinois Environmental Protection Agency
P. Q. 8o" 19276. Springfield. IL 62794.9176
Page 2
Expansion of the monitoring program for untreated groundwater and
treatment system effluent, to supplement current monitoring efforts.
Complete fencing (with signs) of the site; and land use and deed
restrictions, to the extent possible, for the site and affected off-site
areas.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action, and is cost-effective. This
remedy utilizes permanent solutions and alternative treatment technologies to
the maximum extent practicable and satisfies the statuto~ preference for
remedies which employ treatment that reduces toxicity, mobility, or volume as
a principal element.
Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted at least every five
years after commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human heal th and the envi roment.
c'I'~a 1'1"2...
Date ~
~~e~' ~
Director
Illinois Envi romental protec ti on Agency
MAG:KN:dks/rmi/sp/596r
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I.
II.
III .
IV.
V.
VI.
VII.
CIPS/Taylorville Manufactured Gas Plant Site
Decision Summary Table of Contents
Site location and Description
Site History and Enforcement Activities
Community Relations Activities
Scope and Role of Operable Unit
Site Characteristics
Summary of Site Ris~s
VIII. Summary of the Comparative Analysis of Alternatives
Description of Alternatives
IX.
X.
XI.
The Selected Remedy
Statutory Determinations
Documentation of Significant Changes
APPENDIX A
APPENDIX B
APPENDIX C
- Tables and Figures
- Responsiveness Summary
- Administrative Record Index
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1.
RECORD OF DECISION SUMMARY
CIPS/TAYlORVIllE MANUFACTURED GAS PLANT SITE
S,te location and Descr'ption
The Central Illinois Public Service Company (CIPS) Manufactured Gas
Plant (MGP) site is specif'cally located at 217 South Webster Street 'n
Taylorville, Christian County, Illinois. The site itself is bordered by
Manners Park to the east, a CIPS pole storage yard and railroad line to
the west, private residences to the north and a small wooded residential
subdivision to the south. The general site location is shown in Figure
I, followed by a more detailed vicinity map 'n Figure 2.
The site itself is situated on a level parcel slightly less than one
acre in size immediately west of the south extens'on of Webster street
as it enters Manners Park~ Three sides of the site are currently
secured by a six-foot high chain-link fence, with access from the west
being limited by an active rail line. This site is basically located on
a topographic high, with terrain generally sloping to the south as a
series of ravines empty into an intermittent creek section leading to
the South Fork of the Sangamon River approximately one-half mile away.
The history of site manufacturing activities is more fully explained in
the next section. However, it is worthy to note here that an immediate
removal action taKen by the responsible party in 1987 has resulted ~n
demolition of all former gas plant structures above and below ground.
excavation and off-s'te disposal of contaminated source materials and
backfilling of affected areas with clean soils. The surface of the
former plant site has been covered with a foot thick. course of gravel
and is currently used as a storage yard by the utility. The on-site
immediate removal work. limits are shown in Figure 3.
The surrounding residential and recreational land uses can be seen in
Figure 4. It is evident from these figures that there is substantial
human activity immediately adjacent to the secured site-. Manners Park
is the main multi-use facility for Taylorville, a community of
approximately 11,000 people. Typical residential block. arrangements
border the site to the north and further west. In contrast, the Seaman
Estate subdivision directly to the south consists of eight larger wooded
tracts, with single family residences on several. CIPS owns the three
tracts closest to the site, as shown in Figure 5. The intermittent
drainageway leading south away from the site to the Seaman Estate pond,
as well as its extension from the pond to the South Fork. of the Sangamon
River, is on property controlled by CIPS. Use of natural resources on
CIPS' property has been voluntarily curtailed through deed
restrictions. The responsible party has provided alternative public
water supply to potentially affected residents surrounding the site.
This includes those in the Seaman Estate subdivison, whose landowners
have also signed groundwater use restriction agreements with CIPS. and
have had their private wells plugged and abandoned on a voluntary
basis. IEPA will review these agreements and mod'fy if necessary during
the course of signing of the Consent Decree, to ensure that the
res'dents are protected from any potential contaminants. Therefore. all
residences south and southwest of the site in the immediate vicinity of
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the potential groundwater contaminant plume's path have been supplied
with muntcipal potable city water, and the uppermost groundwater
resource ts not being used for human consumption.
The ORty other potentially affected natural resource being used at this
time is the Seaman Estate pond. This private pond is used .
recreationally for swimming and fishing. An annual surface water,
sediment and fish monitoring program has been conducted by the
responsible party since 1989 to.assess health risks and provide data to
support development of the final remedy for the site. Minimal effects
have been recorded in the pond water and fish presently. These levels
do not require remediation of the pond currently, for reasons stated
later In this document. The ponds' monitoring will continue throughout
the remediation process and site monitoring. The pond will have further
work performed If deemed necessary later.
II.
Site History and Enforcement Activities.
The CIPS/Taylorvi11e Manufactured Gas Plant (MGP) was constructed in
1892 and was operated by the Taylorvl11e Gas and Electric Company until
It was purchased in 1912 by CIPS. CIPS operated the HGP from 1912 untIl
1932. The plant produced a low qualIty gas from coal, which was used
for lighting and heating. The coal gasification process that was used
at the plant produced a byproduct known as coal tar. Coal tar is a
mixture of volatile compounds such as benzene and toluene, heavier
compounds such as naphthalene and a class of compounds known as
polynuclear aromatic hydrocarbon (PAHs). Certa'n of these compounds
have been shown, or are suspected to cause cancer in people. The actual
disposal method for the coal tar generated by the Taylorvi11e HGP Is not
known,. but typically coal tar was disposed of off-site, sold or given
away for use as roofing material, weed killer, etc.
The plant was closed in 1932 when higher quality natural gas became
available in the area. When the plant was closed, most of the 'above
ground structures were torn down, and below ground tanks were apparently
filled with soil and miscellaneous materials and left in place.
EnvIronmental contamination was discovered in October 1985 when a
plumbing contractor, making repairs to a septic tank on the property,
dug a trench and found coal tar in the subsurface soils. When the coal
tar was discovered, work on the septic tank was halted and CIPS was
notified. Recognizing its legal liabilities for the site and in order
to protect public health and the environment, CIPS notified the IEPA and
. immediately began an on-site investigation to determine the nature and
extent 0' coal tar contamination.
The IEPA issued a Notice pursuant to Section 4(q).of the Illinois
Environmental Protection Act (the Act) on July 2, 1986. This Notice
explained the Agency's concerns regarding the potential contamination
and set forth those steps CIPS was required to take to address the
situation.
The first response required in the Notice was an Immediate Removal
Action (IRA) (or Operable Unit) to locate and remove all buried tanks
and ptts at the site which contained coal tar or other wastes. Work
plans to guide the construction wor~ and health and safety plans to
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protect on-site workers, as well as the community as a whole were
required to be reviewed and approved by the IEPA Immediate R~moval Unit
before the IRA could begin. The IRA was initiated in January 1987 and
completed in Harch 1987. The excavation was left open for approximately
two years after the completion of the IRA because the Agency and CIPS
were discussing the necessary remedial actions to address soil and
groundwater contamination that remained. These and other completed
actions, including provision of an alternative water supply and
institutional controls. are discussed in greater detail in the
Description of Alternatives section of this decision summary.
The "Phase II Site Investiaation and Remedial Alternative DeveloDment
ReDort. CIPS Gas Plant Site - Tavlorvl1le. Illinois" was completed by
Hanson Engineers, Inc. for CIPS and submitted to the Agency in December,
1986. This report summarized .a11 of the investigative activities up to
that date and recommended very limited remedial action besides that
completed under the IRA.
CIPS submitted four addenda to the original Phase II report. After
several months of discussion and review of the Phase II report and Its
addenda. the Agency and CIPS reached an impasse. CIPS was not willing
to undertake additional remedial action to address contamination that
remains at the site. The IEPA. in an effort to secure private party
funding of a final remedial action. sponsored the site for scoring
under USEPA's Hazard Ranking System (HRS). The CIPS/Taylorville site
initially carried a score of 48.91 when it was proposed to the National
Priorities List on June 27. 1988.
The history of CERCLA enforcement activities for the CIPS/Taylorville
site .1s an outgrowth of the state superfund actions conducted prior to
NPL listing. The Region originally sent a CERCLA 104(e) information
request to CIPS ahead of proposal to the NPL on January 13, 1988. CIPS
submitted responses to this request on January 27th. April 19th and June
22nd. 1988. After proposal to the NPL~ the site was designated as a
"State-Lead" enforcement case through negotiations between IEPA and
USEPA Region V.
IEPA held discussions with CIPS. and the Region as necessary, during the
Spring of 1990 to explain the CERCLA process to the responsible party
and the technical ramifications of c~11ance with the NCP. It was
determined that any necessary study work could be completed under the
terms of the existing State 4q Notice and that a Consent Order would not.
be required. Technical staff met in July 1990 and establtshed the Scope
of Work for supplemental field work, refinement of the risk assessment
and development of the feasibility study to meet current.USEPA program
guidance. The RA/fS Update was finalized in Hay, 1991, and those
findings are .discussed throughout this decision summary.
The state had basically suspended Consent Order negotiations with the.
responsibile party during the fa11 of 1988 after the site's proposal for
the NPL. The parties agreed that negottations toward a Remedta1
Design/Remedial Action (RD/RA) Consent Order would resume once the
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III .
Proposed Plan/ROD had been final'zed by the Agency and rev'ewed and
accepted by USEPA and the publ'c. No formal Special Not'ce Letter was
'ssued by the State during the publ'c comment period because CIPS, as
the on1y potentially respons'ble party, has voluntarily cooperated to
date and has expressed a will'ngness to implement the f'nal remedy be'ng
selected in this decision summary. A draft RD/RA Consent Order w',l be
given to the company in May, 1992 and It Is expected to be finalized and
entered by the court during this winter. This enforcement Agreement
wIll cover construction of the fInal remedy and its long-term operatIon
maIntenance and monitoring. . ,
Community Relations Activities
CIPS and IEPA have been conducting commun,ty relations activities at
this site since late 1986, more than four years before the s,te was
added to the NPL. The early stages of investigation and the 1987
removal action were carried out by CIPS as a private party action, with
IEPA overs'ght. At that time no formal Community Relations Plan (CRP)
had been developed for the site, and public participation activities
were planned and carried out on an id h2t bas's.
During 1986 and 1987, contacts with the public were primarily lim'ted to
local officials, nearby residents, and the press. CIPS representatives
went door-to-door and met with nearby neighbors before the removal
action tooK place. IEPA representatives were not involved with this
process. An early informational publ'c meeting planned by CIPS without
IEPA 'nput drew very low attendance, possibly due to an error 'n the
announced date for the meeting.
During the removal action in early 1987, CIPS offered to relocate the
nearest residents to a motel temporarily, because unseasonably warm
weather had resulted 'n some odors near the site, and the increa.sed
truck traffic was an annoyance. .
During the same period IEPA staff met with downgradient (Seaman Estate)
property owners at the'r request to discuss IEPA's stand on whether it
would be safe to construct and use homes and private wells, and whether
they could proceed with planned reconstruction worK on the potentially
contaminated pond shared by their properties. Residents were informed
that IEPA would not recommend install'ng new drinKing water wells 'n the
former Seaman Estate area. The residents had proposed to deepen the
pond by dredging and spreading the dredged sediments on the banks. IEPA
responded that such sediments had a h'gh liKelihood of containing
significant coal-tar related contamination; and dredging might 1)
deposit PAH-contaminated sediments on the shoreline, where people (and
animals) would be more likely to contact them, 2) mobilize existing
contamination by stirring up sediments in the pond, and 3) possIbly alow
any spring-fed sources of PAH contamination to.flow more freely into the
pond.
In March 1987, staff from IEPA and the Illin~is Department of PublIc
Health met with a nearby resident to discuss her beltef that she had
suffered health effects due to odors emanating from the excavation
during the removal action. Over the following months IEPA Community
Relations staff provided cop'es of site air-monitoring reports and
provided answers in response to calls from this individual.
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In August 1987, CIPS proposed an experimental remedial method for the
contamination remaining in the groundwater .at the site, but the trade
secret, proprietary nature of the proposal led to bench-scale tests and
lengthy closed-door discussions that too~ the site out of the public eye
for more than a year. CIPS withdrew its proposal for the novel remedy
roughly a year after it was Introduced. From the completion of the
removal action in early 1987 to April 1989, the excavated area remained
open, but access was restricted.
CIPS met with IEPA Community Relations (CR) staff i" October 1988 (after
the site's proposal for the NPL) and stated the company's intention to
develop and carry out a CRP compatible with Superfund guidance. In
February 1989, CIPS produced a draft Community Relations Plan, a .fact
sheet, and a press release covering only the current project of
backfilling the area excavated in the early-1987 removal action. IEPA's
CR staff reviewed the draft CRP and met with company representatives in
March 1989, informing them that the CRP would require major broadening
of scope and modifications of form before It would satisfy CR guidance.
At that time, IEPA supplied CIPS with a sample CRP meeting the guidance.
CIPS followed through on a number of Agency CR recommendations prior to
the April 1989 backfilling of the excavation, notably the distribution
of a fact sheet (the first to be prepared regarding the site) to all
residents near the site and along the route to be followed by the trucKS
carrying fl.ll material to the site, as well as meeting with local
off'cials, press, and nearby neighbors to discuss planned activities.
At this time, CIPS left the draft CRP In Its Incomplete form, stating
that It was an interim version for the purpose of the backfilling
operation only.
In July 1989, IEPA's CR staff recontacted CIPS' public relations section
to request a revised CRP for the site. In February 1990, IEPA's. CR
coordinator sent a letter. to CIPS underlining the need for an acceptable
CR Plan. In a meeting with the company, IEPA CR staff emphasized that
the long delays between the various phases of the project had left major
. gaps In the community's understanding of the situation. At the very
least, CIPS needed to produce a comprehensive CRP to address the
community's need to be brought up-to-date on the technical findings of
the completed Remedial Investigation (RI) and the forthcoming update of
the Rls~ Assessment and Feasibility Study. IEPA's CR Coordinator
stressed that a fact sheet on the RI findings was long overdue, and that
citizens should not be as~ed to assimilate In too short a period of time
the results of both the RI and the FS... CIPS was urged to obtain the
services of an experienced CR consultant in order to carry out these
needed actions in an expeditious manner. .
During the ensuing months, CIPS Indicated in contacts with IEPA that it
was considering the action of engaging an outside CR contractor. Late In
June 1990, controversy erupted in the community as three area children
were found to have been diagnosed with neuroblastoma, a rare childhood
cancer within about a year's time. An ~ b2k citizens group formed and
successfully sought widespread media attention to this medical problem.
In public meetings and the frequent media interviews that followed.
CIPS's former manufactured gas plant was suggested by some citizens as a
possible cause of these cancers.
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In the absence of a CRP. available fact sheets describing the prior and
existing environmental situation, or even an established site
information repository, IEPA, the Illinois Department of Public Health,
and CIPS initially had difficulty conveying to concerned citizens and
the medta in a clear and convincfng manner that the project to date had
been handled fn such a way that the public had not been exposed to site
contaminants. At this time, CIPS public relations staff informed IEPA
CR staff that hfgh-level corporate approval was being sought to hire an
outsfde CR consultant. .
In addftfon to CIPS representatfves. IEPA technfcal and CR staff and an
IDPH toxicologist attended a July 18, 1991 public meetfng in
Taylorville, called by the local citizens group, and kept in close touch
with the group's leaders by phone and fn face-to-face meetings over the
next several months. Both CIPS and the State Agencies also responded to
numerous contacts from local. regional, and national media regarding
speculation of a connection between the CIPS site and the neuroblastoma
cases.
CIPS established a site information repository in the Tay1orvi11ePublic
Library in late July 1990. On August 21, 1990 IEPA's technical staff
and CR coordinator met with CIPS staff and their newly hired outside
CR-consultant to discuss the urgent CR needs required to meet the
then-contemplated schedule for an RI meeting, an FS-hearing, a public
comment period, and the subsequent record of decision for this site.
On August 28, 1990 the nattonal and local media were tnformed of the
CIPS site's ftnal listing on the NPL, engendering numerous media calls
to IEPA, and adding further urgency to the need for a CRP and fact
sheet~to inform. the community'of the facts regarding the site, past and
present. Because the company had already begun (at IEPA's urging) a
formal CR effort. the IEPA made the decision to leave primary.
responsibility for CR activities in the hands of CIPS. with full IEPA
oversight. In'October, IEPA's CR coordinator provided fnformation to
assist U.S. EPA's TAG staff tn publictztng. the avat1abl11ty of Technical
Assfstance Grants regarding the site.
In late December 1990, CIPS provided a draft CRP and draft RI fact sheet
to IEPA for review and comment. IEPA CR staff provided verbal comments
on both documents in a meeting two days later. IEPA's CR coordinator
circulated the draft CRP to IEPA staff for further written comments and
suggested revisions in late January; and several rounds of in-house
review resulted tn formal written comments being sent to CIPS in
mid-March, 1991.
Late in January 1991, IEPA's CR coordinator contacted U.S. EPA's TAG
program coordinator to ask the status of the local citizen group's
effort to apply for a grant. Finding that the group's application had
not been received, the.IEPA's CR coordinator and Project Manager called
the local group's leader to dtscusswhat sort of consultants the group
could fund with a TAG. and conveyed U.S. EPAls suggestton that the group
submit even a partial application, so that TAG program staff could
advise and assist the group in completing a successful application. In
a March 12th call to U.S. EPAls TAG offtcer, IEPA's CR coordinator
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learned that the local group had sent a 1etter stating that they would
not be applying for a grant. citing as reasons difficulties in
comp1eting the application and their view that IEPA staff were providing
their group with adequate information on the site.
During the first quarter of 1991, IEPA CR staff had numerous phone
contacts and several meetings with CIPS public re1ations staff and its
CR consultant in preparation for the RI-meeting in 1ate March. The
revised RI fact sheet was mailed to the site contact 1ist and made
available in the repository in March, and the RI meeting took place on
March 26, 1991, in Taylorville. CIPS set the agenda for the meeting and
made presentations outlining the methodology and results of the removal
action and the RI. IEPA and Illinois Department of Public Health staff
took an active part in the meeting, answering questions and clarifying
the State's oversight role.
During May and June. 1991 IEPA's CR staff reviewed the RA/FS Update
report for the site and commented on several drafts of the RA/FS fact
sheet from CIPS's CR consultant. The final version of the fact sheet
was released to the public in early June 1991. CIPS submitted a final.
revised CRP to the IEPA in May. and IEPA provided its final review and
written comments in the first week of June 1991. The CRP was added to
the site repository .in June. at the same time that the final version of
the RA/FS fact sheet was sent to the site contact lis~.
In July 1991, IEPA sent (to the entire site mailing list) individual
copies of the public notice of an informational public meeting and the
formal FS public hearing for the site. In addition. IEPA published the
complete publ1cnotice as a display ad three weeks in succession in late
July and early August. in the Tavlorvi11e Breeze - Couri~r, the local.
daily newspaper. The public notice described the background of the
site, past remedial activities. and its status as a Superfund site. with
IEPA providing oversight for CIPS activities. The notice announced that
the Proposed Plan and the c~lete Administrative Record for the site
would be available at the Taylorville Public Library. starting August 5.
1991. including the recently completed Risk Assessment/Feasibility Study
Update for the site. The notice summarized the basic features of the
three alternatives evaluated by the FS. as discussed fully in Section
VII of this decision summary.
The public notice announced the place and time for both an informational
meeting and a formal FS publtc hearing. both in Taylorville and both
events scheduled with afternoon and evening sessions. The nottce
announced a 45-day public comment pertod. commencing August 5
andconttnutng through September 19. 1991. An IEPA mailing address for
comments and contact person for more tnformation were a1so provided.
The IEPA responded to numerous media and citizen calls.
In Ju1y IEPA's technical and CR staff also responded to numerous
detai1ed technica1 questions from representatives of the 10ca1 citizen
group. which was once again discussing a posstble TAG applicatIon with
U.S. EPA staff.
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On August 5, 1991, IEPA staff placed the Proposed Plan and the
Administrative Record, with its associated Index, in the Taylorv111e
Public Library. On'August 8, IEPA mailed complete copies of the
Proposed Plan to the entire site mailing list, again emphasizing the
public comment. period, informational meeting, and FS public hearing for
the project. .
IEPA held the informational meeting (availability session) on the
afternoon and evening of August 12, 1991. About a dozen members of the
general public attended, along with several local officials and a number
of media reporters. IEPA held the formal FS Public Hearing on the
afternoon and evening of August 27, 1991. U.S. EPA technical and CR
staff were also present, and State Public Health Department personnel
were in attendance in case their input was requested. Attendance was
about 30 in the afternoon and about 40 in the evening session. IEPA
prepared an off'c'a1 transcript of the hear'ng and placed it in the
Administrative Record at the library, on September 5, 1991.
IV.
In late November, 1991, two of the Taylorv111e area mothers of children
with neuroblastoma, who were among the founders and prime movers of the
local citizen group ("Taylorv111e Awareness Group"), filed suit against
CIPS and its contractor for the removal action, alleging that they were
responsible for the children's cancers. These suits are still pending.
Scope and Role of Operable Unit
As discussed in detail within Section VII of this decision summary, an
operable 'un1t addressing excavation and off-site disposal of source
materials, provision of an alternate water supply and implementation of
partial land use/deed restrictions has been voluntarily completed by the
responsible party under notice and direct supervision of the Agency.
The response action contemplated by this decision summary to address the
remaining principal threat posed by groundwater contamination is
considered to be the final remedy for the CIPS/Taylorville MGP site.
Therefore, no additional operable units are envisioned at this time.
V.
Site Characteristics
The RisK Assessment and Feas1bilitv Studv (RA/FS) Ucdate, John Mathes
and Associates. Inc., May, 1991 was basically required for this NPL site
to bring decision-maKing documents into compliance with the NCP. The
other equally important purpose of this update, which became Addendum 5
to the Phase II study, was to account for supplemental data generated
since the 1987 r~val action and accurately assess existing site
conditions. The reader is therefore encouraged to consult the Phase I
and II documents by Hanson Engineers, Inc. on initial environmental
conditions after site discovery.
This section is devoted to.establishing the nature and extent of
residual contamination associated with both the former plant site and
off-site areas where contamination has come to rest. Themed1a-speciflc
information 'prov1ded here was concisely summarized in the RA/FS Update.
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and therefore is directly reprinted. This presentation assumes the
reader is familiar with the former plant site's configuratIon and the
removal action as detailed in Section VII of this decision summary.
Nine additional data-collection activities have been performed and
reported to the IEPA regarding the site since the December 1986
submittal of the Phase II report. The activities include:
collection of sediment samples December 10, 1987, from the Seaman
Estate Pond (submitted January 4, 1988);
collection of 1988 groundwater data (submitted November 30, 1988);
ambient air monitoring around the perimeter of the site in 1987,
1988, and 1989;
biological sampling on the South Fork of the Sangamon River near
CIPS site (October '89)
colle~tion of 1989 sediment, surface water, and fish tissue samples
(1989 Seaman Estate Pond Study) .
collection of 1989 groundwater monitoring data (submitted
January 26, 1990);
collection of 1990 sediment, surface water, and fish tissue samples
(1990 Seaman Estate Pond Study, Appendix C of the RA/FS Update);
collection of groundwater samples for cyanide analysis on
January 25; 1991:
collection of on-site soil samples from borehole locations B-10.
6-11, and 8-14 on March 4, 1991; and
collection of 1991 sediment, surface water, and fish tissue samples
(1991 Final Annual Report. Seaman Estate Pond Study).
Post-removal sampling generated data on five off-site media that could
have been affected by historical site activities and the removal
action. These med1a included sediment, surface water, fish tissue (each
in the downgrad1ent receptor-Seaman Estate Pond). groundwater, and air.
In addition, s011 samples were collected and analyzed for VOCs at
on-site locations where 50115 had not been excavated during remova1
activities.
Sediment
On December 10, 1987, sediment sampling was performed at the northern
end of Seaman Estate Pond. Three sediment samples were collected along
each of four separate transects. At each location, sediment samples.
were collected from three separate depth intervals (0 to 0.5 foot, 0.5
to 2 feet. and 2 to 4 feet>. Samples collected along the same transect
and at the same depth interval were composited to form a single sample.
The locations of the four transect lines and corresponding boreholes are
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shown in Figure 6. Evaluation of analytical results Indicates that PAHs
were present In the top six Inches of every transect composite. with
concentrations ranging from 680 to 2.600 ug/kg. The only other sample
from this series that contained PAHs was the 0.5- to 2-foot Interval for
Trans.ct 3. which contained 460 ug/kg.
Sediment data for the 1989, 1990. and 1991 Seaman Estate Pond sampling
efforts are summarized in Table 1. These sediment samples were
collected with a standard ponar dredge and represent materials
approximately zero to six Inches below the top of the sediment layer.
One of nine sediment samples (CS4-B) In the 1989 sampling effort
contained detectable concentrations of PAHs. The highest concentration
detected was 1 ,570 ~g/kg fluoranthene. Eight of nine sediment samples
collected in the 1990 sampling effort contained detectable
concentrations of PAHs. However, detection limits reported were lower
than those for the previous sampling effort. The highest concentration
detected In 1990 was 1489 ~g/kg dlbenzo(a.h)anthracene.
Surface Hater
A comparison of the concentrations of detected PAH compounds found In
the surface water samples collected from Seaman Estate Pond for the
1989. 1990. and 1991 sampling efforts Is presented In Table 2. One PAH
(fluoranthene> was detected In the 1989 sampling effort. Fluoranthene,
acenaphthene. and naphthalene were detected In both surface water.
samples collected In 1990. One PAH (fluoranthene> was detected In both
the sediment samples and surface water samples. No PAHs were detected
in the 1991 surface water samples.
Fi sh Ti ssue
A comparison of the concentrations of detected PAH compounds detected In
the fish tissue samples collected from Seaman Estate Pond during the
1989, 1990. and 1991 sampling efforts is presented in Table 3. Whereas
one PAH was detected in the tissue of a largemouth bass In 1989. seven
PAHs were detected tn the fish tissue samples of bluegill or channel
catfish In 1990. Acenaphthene was detected at concentrations of 440
ug/kg and 1.000 ug/kg in bluegill and channel catfish tissue samples, .
respectively. Fluoranthene and naphthalene were also detected In the
catfish tissue samples at low concentrations. Fluoranthene was detected
in the bluegill tissue samples at low concentrations. No PAHs were
detected In 1991 fish samples. though some detection limits were above
those for earlier years. For comparatjve purposes, Table 4 presents
typical concentrations of PAHs detected in smoked and nonsmoked fish
tissue.
Off-Site Groundwater
A summary of post-removal groundwater monitoring data Is contained in
Table 5. Evaluation of these data indicates that an organic compound
was detected In an off-site monitoring welLon two occasions. In 1988,
benzene was detected at a concentratton of 0.7 ug/L in Well GW-9D. In
1989 acenaphthene was detected at a concentration of 2.4 ug/L 1n Hell
GH-13d. Both of these compounds were detected at concentrations just
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VI.
above the method detection limit. Acenaphthene was not detected in any
other on-site or off-site groundwater samples collected during these
three sampling events. In 1990, no compounds were detected above the
method detection limit in any off-site groundwater samples.
Ai r
Ambient air monitoring along the site fenceline using a portable
photoionization detector continued after removal activities were
completed (until the excavations were backfilled). This monitoring was
performed to assess whether or not these activities had lasting air
quality impacts on the surrounding public. Post-removal air monitoring
results are summarized in Table 6.
On-Site 5011 s
A summary of post-removal on-site soil analytical results is contained
in Table 7. These samples were collected in March of 1991 to assess
whether or not residual VOCs were present in site soils (outside of the
original limits of excavation). An evaluation of these data indicates
that the concentrations of VOCs in borehole samples 8-10, 8-11, and 8-14
are insignificant.
On-Site Groundwater
Groundwater under the CIPS site does have contaminants remaining. Those
compounds that have been found on-site are listed in Table 5.
Summary of Site Risks
The Risk Assessment and Feasibility Studv (RA/FS) Ucdate, John Mathes
and Associates, Inc., May, 1991 characterizes existing and future health
and environmental risks posed by residual contamination associated with
current, Dost-removal site conditions. This baseline risk assessment
evaluates risks presented by impacted soil/sediment, surface water and
groundwater media both on and off of the manufactured gas plant site.
This risk assessment was performed by the responsible party under the
close technical supervision of IEPA and IDPH, with input from USEPA,
using the current methodology and techniques described in the Interim
Final Risk Assessment Guidance for SUDerfund - Human Health Evaluation
Manual. Part A, USEPA, 1989 and the Risk Assessment Guidance for
Sucerfund - Environmental Evaluation Manual, USEPA, 1989. The reader is
referred to the RA Update itself for discussion of the hazard
identification, exposure assessment and toxicity .evaluation leading up
to the current risk characterization for the CIPS/Taylorville site.
What follows is the risk characterization and impact evaluation directly
taken from the RA/FS Update. This analysis attempts to quantify chronic
human health exposures and carcinogenic risks while qualitatively
evaluating environmental impacts. The exposure scenarios, human
health/environmental factors and risk calculations used were approved by
the Interagency reviewers through a series of information exchanges and
scoping meetings/calls. Human health risks are characterized first by
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looking at potential on-site (former HGP area) and off-site use
followed by the assessment of environmental concerns and a disc~ssion of
sources of uncertainty.
Human Health
To evaluate the endangerment, if any, that is created (currently or in
the future) by the site, risk estimates (hazard and carcinogenic) were
developed for the following human exposure scenarios:
dermal contact during bathing with site groundwater by future
hypothetical on-site residents;
ingestion of site groundwater by future hypothetical on-site
residents;
ingestion of fish caught in Seaman Estate Pond by local residents;
inhalation of volatile contaminants from Area A and on-site
subsurface soils by local residents;
dermal contact with site-impacted sediments at Seaman Estate Pond,
Area A, and Area B by local residents;
inadvertent ingestion of Seaman Estate Pond water by local
residents during swimming; and
dermal contact with Seaman Estate Pond water by local residents
during swimming. .
In the risk characterization for the scenarios listed above, the risks
of exposure to chemicals resulting in carcinogenic (nonthreshold) and
noncarcinogenic (threshold) effects were assessed separately. The
carcinogenic rhk values for dermal exposure to sHe groundwat.er by
future hypothetical residents exceeded 10-2. According to the USEPA
guidance, carcinogenic risks above this level are nonlinear with respect
to dose (USEPA. 1989). The gUidance recommends that an alternate risk
calculation be used in these circumstances. Table 8 is a list of the
original and adjusted risk values for this pathway. The cancer risk
level and total hazard index estimates calculated from these values for
each pathway are presented in Table 9. A qualitative evaluation of the
risks associated with the inhalation of volatile contaminants from Area
A and on-site subsurface soils can be found in Appendix E of the RAfFA
Update. .
Future HVDothetical On-Site Residents
,
Incremental cancer risk levels (CRLs) for ingestion of site-impacted
groundwater by future hypothetical on-site residents range from 1.23 x
10-2 for the Upper Bound Exposure (UBE) for adults using the
one-to-one potency method to 9.01 x 10-4 for Average Exposure (AE) to
children using the relative potency method. All of the carcinogenic
risk estimates for this pathway exceed the USEPA's range of acceptable.
risk which ts defined as 10-6 to 10-4 (USEPA, 1990).
. .
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The total hazard index for the groundwater ingestion scenario"is
calculated to be 17.2 for children and 17.3 for adults under AE
conditions, which indicates that noncarcinogenic healtheff@cts may
result from chronic ingestion of site-groundwater by future hypothetical
on-site residents.
The carcinogenic ris~s associated with dermal exposures during bathing
represent the greatest potential ris~ to future hypothetical on-site
residents. The carcinogenic ris~ estimates range from 9.53 x 10-1 for
adults using the one-to-one potency approach under UBE conditions to
5.01 x 10-2 for adults under AE conditions using the relative potency
approach. As with the groundwater ingestion scenario. all of the
carcinogenic risk estimates exceed USEPA's range of acceptable risk.
The total hazard index for dermal contact with site groundwater Is
calculated to be 39.4 for children and 25.8 for adults under AE
conditions. which indicates that noncarcinogenic health effects may
result from chronic dermal exposure to site groundwater by future
hypothetical on-site residents.
Seaman Estate Residents
The carcinogenic risks to Seaman Estate residents who may inadvertently
ingest surface water in Seaman Estate Pond during swimming ranged from
3.55 x 10-8 for adults under USE conditions using the one-to-one
potency approach to 1.95 x 10-10 for adults under AE conditions using
the relative potency approach. All of the carcinogenic risk estimates
for this pathway are less than USEPA's point of departure ris~ level of
10-6. The hazard indexes for this pathway are all well below unity
(one). which indicated that noncarcinogenic health effects are not
anticipated. "
The carcinogenic risks to Seaman Estate residents through dermal contact
with surface water in Seaman Estate Pond during swimming ranged from
4.29 x 10-4 for adults under USE conditions using the one-to-one
potency approach to 2.36 x 10-6 for adults under AE conditions using
the relative potency approach. All of the carcinogenic ris~ estimates
for this pathway except for the USE and Reasonable Maximum Exposure
(RME) estimates for adults and RHE conditions for children using the
one-to-one potency approach are within USEPA's acceptable risk range.
The hazard indexes for this pathway are all below unity, which indicates
that noncar~inogenic health effects are not anticipated.
The carcinogenic risks to Seaman Estate residents who may ingest
contaminated fish caught in Seaman Estate Pond range from 2.72 x 10-5
for adults under USE conditions using the one-to-one potency approach to
2.16 x 10-8 for adults under AE conditions using the "relative potency
approach. All of the carcinogenic ris~ estimates for this pathway are
either within USEPA's acceptable risk range or less than USEPA's point
of departure risk level of 10-6. The hazard indexes for this pathway
are all below unity, which indicates that noncarcinogenic health effects
are not anticipated. .
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Additional calculations were performed using the fish tissue results to
provide more Information pertaining to the potential carcinogenic risks
to Seaman Estate residents from the Ingestion of contaminated fish
caught in the Seaman Estate Pond. The results of the Seaman Estate Pond
Study indicate that the contaminant levels detected varied considerably
by species. The highest contaminant concentration (1.0 mg/kg
acenaphthene> was found In a channel catfish sample. The highest
carcinogenic PAH concentration detected in any fish tissue sample was
0.009 mg/kg of benzo(a)anthracene. also in a channel catfish sample. In
contrast, none of the PAHs analyzed for were detected at quantifiable
levels In largemouth bass tissue samples during the 1990 Investigation.
Therefore, to provide more Information regarding the relative risk
associated with the ingestion of individual species, carcinogenic risk
estimates were calculated using the total concentration of the two
carcinogenic PAHs, [benzo(a)anthracene and chryseneJ for each species.
These calculations are based on the assumption all of the fish from the
Seaman Estate Pond consumed by an individual are the same species (for
example, catfish).
The calculations used for this review are presented In Appendix E of the
RA/FS Update. Both average and reasonable maximum exposure conditions
were considered. The one-to-one potency approach was used In the
calculations for conservatism. The results of this review are
summarized below.
Seec i"es
Carclnoaen1c Risk
Average Exposure Reasonable Maximum
Conditions EXDosure Conditions
Largemouth Bass
7.56 x 10-7
4.20 x 10-8
9.24 x 10-7
1. 37.x 10-5
7 .60 x 10- 7
Bluegill
Channel Catfish
1 . 67 x 10- 5
As suspected, the highest est'mated carcinogenic risk Is associated with
the Ingestion of channel catfish caught In Seaman Estate Pond, followed
by bluegill, then largemouth bass.
Another ser'es of calculations was performed to calculate the
concentration of carcinogenic PAHs that corresponds to a carcinogenic
risk estimate of 1.0 x 10-5. The calculations used for this analysis
are presented in Appendix E of the RA/FS Update. The exposure
assumptions used for this analysis are presented In the RA/FS Update for
fish ingestion. The concentrations used In the calculations were the
sum of all the carcinogenic PAHs. The PAH concentration calculated
under average exposure conditions that corresponds to a carcinogenic
risk of 1.0 x l()-S Is 0.119 mg/kg. The PAH concentration calculated
under reasonable maximum exposure conditions that corresponds to a
carcinogenic risk of 1.0 x 10-5 is 6.60 x 10-3 mg/kg.. .
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Local Residents
The eKposure pathways considered for this potential receptor group
involved dermal contact with sediments at Seaman Estate Pond, Area A,
and Area B. In addition, a qualitative evaluation of the potential
impact associated with the Inhalation of VOCs from the subsurface soil
In the excavated portions of the site and Area A was also performed.
All of the carcinogenic risk estimates, for the pathways that Involve
dermal contact with sediments, are less than USEPA's target risk range
of 10-6 to 10-4. None of the carcinogenic risk estimates for this
path~ay exceed USEPA's point of departure risk level of 10-6 under AE
conditions. Seven of the 30 carcinogenic risk values calculated for
this pathway are within the same order of magnitude as USEPA's point of
departure risk level. However, It should be noted that these slightly
higher risk estimates are calculated using the overly conservative
one-to-one potency approach. The hazard indexes for the dermal contact
path~ay are all below unity, which Indicates that noncarcinogenic health
effects are not anticipated. The results of the qualitative evaluation
of the potential risks associated with the inhalation of VOCs from the
subsurface soils, described In Appendix E of the RA/FS Update, indicate
that adverse health effects are not anticipated.
Environmental
The National Wetlands Inventory map (produced jointly by the Il1in01s
Department of Conservation and the U.S. Fish and Wildlife Service)
classifies the majority of Area B as a palustr1ne forested wetland.
This wetlands classification is characterized by deciduous trees that
experience brief periods of flooding during the growing season according
to the publication, A Field Guide to the Hetlands of Illinois (Willman
and Frye, 1979>. This particular wetlands classification is not unique
in Illinois. A letter to the Rock Island U.S. Army Engineer D1strict
from the U.S. Department of the Interior (USDOI, 1989) states that, of
the 5,000 acres of wetlands in the Sangamon River Basin, 4,900 acres
have been classified .as palustrine forested.
Only two federally listed endangered species have been historically
listed In Christian County: the Indiana bat and the bald eagle. There
is no critical habitat for either species in Christian County (USDOI,
1989>. Of the four state endangered species listed for Christian
County, two are not native to wetlands and include buffalo clover and
the upland sandpiper. The remaining species on the state list are
American gInseng, typically found 1n cool, moIst woodlands, and
heart-leaved plantain. Both species are eKtremely rare and are
reportedly not found in the Area B wetlands.
The most plaustble potential risk to envtronmental receptors are the
aquatic species tn the South Fork and Seaman Estate Pond. PAH
contamination was detected in the fish tissue of largemouth bass,
bluegill, and channel catfish caught in Seaman Estate Pond. Even though
the potenttal risks associated wtth the ingest'on of ftsh by local
residents was found to be within acceptable 1: .'ts, the potential
adverse impacts of the contamination on aquat' species '" the pond
cannot be dismissed.
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The only direct comparison that can be made between monitoring results
and environmental criteria indicates that the concentrations of
contamination detected in the surface water are well below applicable
AWQC concentrations for the protection of aquatic life. For example.
the highest concentration of acenaphthene detected in Seaman Estate Pond
was 0.000553 mg/L while the AHQC for fresh water chron1c effects is 0.52
mg/L. likewise. the maximum level .of naphthalene detected in the pond
. was 0.000132 mg/L. while the AHQC for naphthalene is 0.62 mg/l.
However: bottom-dwel11ng species. such as channel catf1sh, may be more
susceptlble to contaminants that tend to bind to sediments. such as
PAHs. The analysis of the fish tissue samples tends to support this
view. The highest contaminant concentrations were found in the channel
catfish tissue samples.
A rev1ew of informat10n obtained from the U.S. Department of Interior
(USDOI. 1989) does not provide an 1nd1cat10n that sensitive
environmental habitats or endangered species are being threatened by
site-related contaminat10n. .
Sources of Uncerta1ntv
The procedures used to assess potential human.health risks are subject
to a number of uncertainties. There are four sources of uncertainty in
this RA:
selection of chemtcals of interest;
estimat10n of exposure-point concentrat10ns;
exposure parameters used to charactertze frequency. duration. and
mode of exposure: and
toxicological data.
Selection of a subset of all the chemtcals detected for quantitative
analysis in the RA is a potenttal source of uncertainty in the final
risk estimates. Although use of a subset of chemicals for detailed
evaluat10n may result tn an under-estimatton of risk, it is anticipated
that this underestimation is small.
The models employed in this RA are conservative in approach. mean1ng
that they tend to overestimate the exposure-point concentrations.
Because these models are simplified representations of complex
phenomena. it is not p01sible to provide an absolute description of
model conservatism. As reasonably conservat1ve assumptions are employed
in the modeltng. the bias would be tn the directton of overestimating
exposure-point concentrations. and consequently the associated risks.
There are 1nherent uncertainties in determining the exposure parameters
that are combined with toxicological information to assess risks.
Assumptions regarding current and future land use are believed to be
reasonably accurate. No significant alterations 1n land use are
anticipated in the foreseeable future. Exposure scenarios associated
with anticipated land use are based on a number of assumptions about
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exposure frequency, duration, and mode. Of particular note in this
assessment are assumptions about average body weight and surface area
and average tnha1ation rate. as well as drtn~ing water. surface water,
and ftsh tngestion rates and absorptton rates. The parameters employed
may underesttmate or overesttmate exposure dependtng on the actual
charactertsttcs of the exposed popu1attons. To mitigate thts source of
uncertatnty . all parameter values employed are based on standard USEPA
assumptions, where available. andre1table reference materials.
Toxicological data are a primary source of uncertainty 1n this and all
RAs. For example, this uncertainty is reflected in the extrapolation
from animals to humans and from high to low doses. There are also
considerattons made concerntng upta~e, metabolism, distributton, species
and stratn differences in suscepttbt1ity, and variability in the
individual response to a toxic agent. In accounting for these.
uncertainties. RfDs and CSFs are derived by the USEPA in a conservative
fashion. RfDs are based on NOAEl reduced by generally consistent
application of order-of-magnitude uncertainty factor~.In general. the
RFD is an estimate of a daily exposure of a human population, including
sensitive subgroups, that is likely to be without an appreciable risks
of deleterious effects. CSFs are 95 percent upper-bound statistical
estimates of carcinogenic potency. For these reasons, actual risks of
health effects are not likely to be higher than these estimates
indicate, but could be considerably lower.
Conclusions
Based on the information collected during the site tnvestigattons and
post-removal activities, the site, in its current condition, does not
present a short-term hazard to human health.
Health risks for future hypothetical on-site residents, Seaman Estate
residents, and local residents that may trespass at the site ~re
summarized in the following subsections.
Potential long-term risks can be postulated based on the current
condition of the site associated with the ingestion of groundwater.
Future HVDothettcal On-Site Restdents
The most signtficant long-term rts~ can be postulated for thts
hypothetical receptor group based on the evaluation of potentta1
exposures through ingestion and dermal contact with on-site
groundwater. All the calculated carctnogenic risk values associated
with exposures to on-site groundwater exceed USEPA's target risk range
under all of the exposure condtttons considered. LiKewise. all the
hazard indexes calculated for these exposure pathways exceed unity (a
value of one), which indicates that noncarcinogenic effects are also
posstb1e.
Seaman Estate Restdents
The pathways evaluated for this receptor group involved potential
recreational exposures to Seaman Estate Pond that tnc1uded: tnadvertent
ingestton/derma1 contact during swimmtng and tngestion of contaminated
fish.
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VII.
None of the calculated hazard indexes exceed un'ty for this receptor
group, wh1ch1ndtcates that noncarcinogenic effects are unlikely. All
of the calculated carctnogentc risk values for the inadvertent tngest10n
exposure pathway' were less than USEPA's point of departure rtsk level.
Howev~, the carc'nogenic rtsks through dermal contact with the surface
water dur'ng swtmm'ng sltghtly exceed USEPA's target rtsk range under
RME cond1t'ons for children and UBE/RME conditions for adults. The
potent'al carc'nogen1c r'sk to ch'ldren was calculated by assuming that
a child could swim in the pond 53 times per year for an average of two
hours per event. Thts risk value was calculated using the one-to-one
potency approach for carcinogenic PAHs, which is widely recognized as
providing overly conservative estimates. The carcinogenic risk to
adults swimming In Seaman Estate Pond was calculated based on an
individual swimming 47 times per year for 32 years under RME conditions,
and 52 years under USE conditions. The carcinogenic risks calculated
for the ingestion of contaminated fish caught in Seaman Estate Pond were
less than USEPA's point of departure risk level under all exposure
conditions when the relative potency approach was used. The three
carcinogenic risk values that exceeded the USEPA's point of departure
risk level were st'll within USEPA's target risk range.
Local Res'dents Hho Mav TreSDass on the Site
The potential exposure evaluated for local residents who may trespass on
the site 'ncluded dermal contact with the sediments at Seaman Estate
Pond, Area A, and Area B. None of the calculated hazard indexes exceed
unity for this receptor group, which indicates that noncarctnogentc
effects are not likely. .
All of the carcinogeni.c risk estimates, for the pathways that involved
dermal contact with sediments. were less than USEPA's target risk
range. None of the carcinogenic rtsk estimates for this pathway.
exceeded USEPA's point of departure risk level under AE conditions.
Seven of the 30 carcinogenic r'sk values calculated for this pathway
were with'n the same order of magnitude as USEPA's point of departure
risk level. However, it should be noted that these sl'ghtly h'gher risk
estimates were calculated using the overly conservat've one-to-one
potency approach. .
Descrtpt'on of Alternatives
As discussed earHer in -this decision sunmary, the PRP's have completed
several phased stud'es on the CIPS/Taylorville site under the direction
of IEPA to assess the nature and extent of contam'nat'on present. The
results of tn'tial investigat've efforts can be found tn the: Phase I
SHe Invest'9ation ReDort. Gas Plant Stte.Tavlorv111e. III 'no's'
(Hanson, March, 1986) and the Phase II SHe Invesft9ation and Remedial
Alternative Development ReDort. CIPS Gas Plant Site. Tavlorvtlle.
111tnots (Hanson, December, 1986). These documents reflect site
conditions prior to the implementation of the "source control" operable
unit discussed 'n detail later in thts Section. Additional groundwater,
surface water, sed'ment and ftsh data have been col1ected since 1987 to
assess rema'ning risks posed by the site. These data have been
incorporated into the techn'cal document dr'v'ng the remedy selection
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process; that being the Risk Assessment and Feasibilitv Studv UDdate.
Addendum 5 to the Phase II Site Investiaation and Remedial Alternatives
DeveloDment Reoort. CIPS Gas Plant Site. Tavlorville. Illinois (John
Mathis and Associates, May 1991). The RA/FS Update summarizes site
risks Hsing current risk assessment guidance and then assembles, screens
and evaluates remedial technologies and subsequent alternatives in
accordance vith Section 121 of CERCLA/SARA, the NCP (40 CFR 300.430) and
USEPA Guidance for Condu~tina Remedial Investiaations and Feasibilitv
Studies under CERCLA, (October, 1988).
From the beginning of response activities on this project in 1985. the
responsible party has maintained that their general remedial action
objective for this site has been to minimize threats to, and provide
adequate protection of, public health, welfare, and the environment.
Remedial action objectives were refined in the RA/FS to address the
principal remaining threat at the site posed by groundvater .
contamination. The analysis concluded that, "site-related constituents
~ontairgd in the ground~ater should be treated to applicable ARAR's [or
to-be-considered (TBC) levels vhere ARAR's are not available] to protect
future hypothetical residential users of this groundvater. Residual
subsurface site-related constituents should be prevented from migrating
off-site. Access to the site and performance of intrusive work on site
should be restricted."
To accomplish these objectives, the responsible party vas directed by
the Agency to revisit the nine remedial alternatives evaluated in the
Phase II report. The three alternatives listed belov emerge~ from this
focussed re-analysis: .
Alternative 3 -- Soil/Sediment removal and institutional controls
Alternative 5 -- Soil/sediment removal, institutional controls and
groundwater treatment
Alternative 10 -- No action (renamed from original alternative 1 --
basel'ne)
Descriptions of the components of each of these remedial alternatives
follovs:
Alternative 3 -- Soil/sediment removal and institutional controls
This alternative has been implemented by the responsible party as an
immedtate response action, or operable unit, to limit potential exposure
of the publ'c to site contaminants and minimize the spread of
groundwater contamination, as a source control measure. This vork was
completed by the RP's during 1987 under the technical guidance and
direction of IEPA's state hazardous vaste remediation unit, in response
to a notice pursuant to the Illinois Environmental Protection Act.
Environmental problems vere encountered on the- site during the fall of
1985. . The investigations referenced above were completed over the next
year. Samples of contaminated soil/sludges were determined to be
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characteristically non-hazardous under the Resource Conservation and
Recovery Act (RCRA) criteria in effect at the time. Finally. the
responsible party completed repurchasing of the s,te, as well as
affected parcels immediately to the south, in November of 1986.
Starting in mid-January of 1987 "structures associated with the original
gas plant were removed and properly disposed of off-site. These
structures included the gas holder, the two separators. the sept1c tan~.
the sidewalk and the brick building (as shown in Figure 7)".
This was fol.lowed by excavation of approximately 9.000 cub1c yards of
v1sibly contaminated soil down to the seasonal groundwater table level.
The average depth of excavation was ten feet and as deep as twelve feet
below the original ground surface in the grossly contaminated area
occupied by the gas holder and separators. The excavation zone is shown
in Figure 7 along with approximate locations of post-removal grab
samples. The sample results from the bottom of the excavation area are
given in Table 10; followed by soil sample results from site areas
outside of the 11mits of excavat10n 1n Table 7 which were collected in
the Spring of 1991.
The ma'n surface drainageway 1ead1ng away from the site to the south was
also ident1f1ed as a source "hotspot" dur1ng early 1nvestigative work.
Approx1mate1y 3.000 cub1c yards of contam1nated soil and sed1ment were
removed from a 50 foot w1de by 600 foot long drainageway section leading
to the Seaman Estate Pond, k.nown as "Area A". The Area A excavation
zone is shown in Figure 8 along with approximate locations of
post-removal grab samples. The sample results from the bottom of the
excavated dratnageway are given 1n Table 11.
All contam1nated s011s excavated from the gas plant s1te and the Area A
dra1nageway were loaded in 11censed truck.s and transported 1n bulk as
"spec 1 a 1 was tes" to Peor i a D1sposa 1 Company Landf111. an 1111 n01 s
perm1tted fac111ty for disposal of Illinois Special Haste.
Following removal activ1t1es in Area A. the excavated drainageway
section was backfilled with clean off-site soils. graded for proper
drainage and revegetated for erosion control. On the gas plant site.
chain link fencing was installed along portions of the perimeter to
limit access. The main excavation area, however, remained open from
March of 1987 onward while the responsible party and the state were
negotiating the details of a second operable unit to address remaining
environmental concerns. The decision was subsequently made to backfill
this area with clean off-site soils to surrounding grade, and this work
was accomplished during April/Hay of 1989. The entire surface of the
former gas plant site was then covered with a layer of gravel and
currently serves as a utility pole and equipment storage yard.
In conjunction wtth the removal action. several institutional controls
were implemented by the responsible party to "further protect the public
health and the environment until a long-term remedy can be selected and
executed."
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A watermatn loop was constructed ~nd connecttons made durtng
September/October of 1987 to supply muntctpal potable water from
Taylorvtlle to potenttally affected restdents wtthtn approxtmately
one-half mtle of the stte tn the general southerly dtrectton of
groundwater flow.
In addtt10n to the repurchasing of the gas plant stte and three parcels
of land tmmedtately south to factlttate the Area A removal, two parcels
from the Seaman Estate pond downstream to the Sangamon River {whtch have
come to be known as "Area B" throughout the investigations> were bought
by the responsible party to restrict development or other land uses.
All of these controlled parcels were fenced with woven wtre and posted
with "No Trespasstng" signs. The responsible party has voluntartly
placed deed restrtcttons on the use of groundwater for consumptton on
the site and all of these downgradient parcels. They have also obtained
agreements with the ftve existtng property owners in the Seaman Estate
development prohtbiting the use of groundwater for consumption and have
properly plugged and abandoned resident's prtvate wells if they so
desired when connections were made to the pUblic water supply. The
scope of these Instituttonal controls ts graphically depicted in
Figure 5.
Finally, to assess the protectiveness of Alternattve 3 and provtde
additional data for the design of a final remedy. the responsible party
has implemented an annual monitoring program since 1989 focussing on a
subset of existing groundwater wells and surface water, sediment and
fish tissues from the Seaman Estate pond.
The capital costs for construction of the remedial elements described
under Alternative 3, as well as the engineering design and oversight
costs and institutional control transaction and legal costs have been
reported to total $3.404.071. The annual operation, maintenance and
monitoring costs for Alternative 3 are reported to be $67.200. The
total present worth costs for this alternative over the chosen common
life of the project, in this case 30 years at a discount rate of ten
percent. is $4.037.560.
With all this said and done. guidance requires an analysis of the major
appltcable or relevant and appropriate requirements (ARAR's). risk.-based
levels. and other "to-be-considered" (TBC) factors being ~t/uttlized
for the spectftc components of this remedial alternative.
The Resource Conservation and Recovery Act (RCRA) and its amendments
normally provtde a complex set of actton-spectftc requirements for
consideration within Superfund projects. Determinations mu~t be made to
classify various contaminated media as "listed" or "characteristically"
hazardous waste to evaluate vartous transport. storage. treatment and/or
dtsposal requirements and their appl1cabtltty or relevance.
For this particular case. the range of RCRA requirements is narrowed
because of completton of the source removal activities as part of the
operable unit. Significantly contaminated sludges. soils and sediment
have been excavated and properly tested, shipped and disposed of in a
permitted off-site landfill in accordance with the regulations and
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remedial philosophies tn place at the time of the removal in 1987. The
excavated area within the former coal gas plant site was backfilled with
a minimum of ten feet of clean off-site fill and surfaced with grave1.
Post-operable unit soil sampling in on-site areas where excavation did
not taKe place indicated that volatile contamination is not present
above detection limits in the unsaturated zone above the groundwater
table. Residual contamination below the groundwater table is the
subject of the groundwater remedy proposed in Alternative 5; RCRA
action-specific ARAR's for groundwater are appropriately left for
discussion within the description of that alternative.
Since residual contamination remains in the saturated zone are above the
state's drinKing water standards, the facility has not been clean closed
according to RCRA regulations 35 lAC: Subtitle G, Section 724.
Post-closure care and monitoring of this unit will therefore be required.
Analyses have not been performed to determine if solid waste residual
materials would qualrfy as RCRA characteristically hazardous waste under
the toxicity characteristics leaching procedure (TCLP) currently in
use. Testing of highly contaminated coal tar sludges during 1987 using
the extraction procedure (EP) toxicity test required at that time
indicated the material was not hazardous by characteristic. Regardless,
the responsible party has aCknowledged the same position the Agency
holds on this matter in their RA/FS update. That is, that RCRA closure,
post-closure care and monitoring requirements are certainly relevant to
the c~nstituents remaining in site soils (and groundwater) in the
saturated zone.
In focusing on the appropriateness of these requirements, consensus has
been reached by both the Agency and the responsible party that
substantive post-closure care and monitoring requirements would be fully
considered/attained if Alternative 3 (or for that matter Alternative 5)
were to become the final remedy for the site.
However, closure "cover" requirements have been determined to be
technically inapproprtate for this site given the current environmental
condtt1ons and the disposition of remaining contamination. "Capping" in
the context of a RCRA cover meeting minimum technology requirements. is
normally utilized to contatn source materta1 tn cells, 1tm1ting its
impact on groundwater and also serving to prevent dtrect contact with
wastes on the surface. At this site the source material has already
been removed and replaced by clean fill, thereby eliminating the
necessity for a low permeable cover. In fact, given the groundwater
remedial action proposed in Alternative 5, a low permeable cover over
the site would inhibtt the progress of a pump and treat system by
minimizing rainfall/run on percolation through residual subsurface
material directly below the former "unit". For these reasons closure
cover requirements are deemed relevant but tnappropr1ate for this site.
It is at this potnt tn the discusston that it becomes apparent in the
Agency's opinion that further remedial worK ts necessary beyond what was
accomplished under the "source control" operable unit, to address the
remaining principal threat from this site posed by existing groundwater
contamination. It is therefore important to discuss Alternative 3 in
relation to various environmental requirements associated with the
groundwater impacted by the site. .
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This boils down to an evaluation of the chemical-specific ARAR's for the
site, as well as consideration of aquifer protection and restoration
goals associated with the Illinois Groundwater Protection Act and the
USEPA Groundwater Protection Strategy and guidance on Remedial Actions
for Contaminated Groundwater at SUDerfund Sites (USEPA, 1988).
The ARAR's associated with the groundwater medium are outlined within
the description of Alternative 5. Compliance with ARAR's as discussed
in the summary of the comparative analysis of alternatives section is a
thre1hold criterion which must be met (or waivers invoked) for an
alternative to be considered for selection as a final remedy. In this
case, a suite of chemicals have consistently been detected in the
groundwater above chemical-specific ARAR and to-be-considered
-------
The aquifer impacted by the site is considered Class I, Potable Resource
Groundwater, as defined by the Illinois ~roundwater Protection Act. To
prevent contaminant plume migration to potential users during the
groundwater long-term remedial action (LTRA), the groundwater table will
be locally depressed by withdrawing between 200 gallons per minute (GPH)
and 500 GPM of contaminated water from a twelve inch diameter extraction
well located near the former tar holder in the center of the site. This
extraction well would be screened the full depth of the aquifer, from
approximately 15 feet below the surface (5 foot above the water table)
to bedrock at 90 feet. It is anticipated that a similarly constructed
backup well would be located approximately 50 feet west of the primary
we11 to .a11ow for a1ternating extraction cycles. The exact
configuration of the pumping system will be refined, based on plume data
collected during the design, to hydraulically capture contaminated
gr.oundwater from the site.
Preliminary treatability studies were performed in 1989 to identify
technologies to effectively treat the primary contaminants of concern:
volatiles (benzene, toluene, ethyl benzene and xylene (BTEX) were
focussed on) semi-volatiles (polynuclear aromatic hydrocarbons (PNA's)
were focussed on) and various inorganics (such as iron). System
influent concentrations were based on actual worst-case contaminants
levels found in groundwater monitoring wells at the time of the study.
It was determined that adequate removal of the contaminants of concern
could be achieved with activated carbon in a single (approximately 10
foot diameter) liquid phase carbon adsorption column. It is anticipated
that influent groundwater will require pH adjustment downward prior to
carbon treatment to remove solids and prevent scaling of process
equipment and "fouling" of the carbon bed in the treatment column. The
carbon adsorptton column will be backwashed periodically to remove those
solids that accumulate on top of the carbon bed. Solids resulting from
this process will be periodically removed, tested and disposed of.
properly in a permitted landfill. Analytical work will be completed on
these solids to determine their characteristics for manifesting and
disposal purposes. The type of landfill will be determined by the
analytical data required prior to disposal of the pollution control
equipment. Failure to pass Method 1311 of SH-846 third edition for TCLP
organics and metals will require all materials being disposed of to be
taken to a hazardous waste landf111. All others wi 11 go to a spech 1
waste landfill. The preliminary treatability studies indicate the
initial carbon supply schedule will be every two months. Actual carbon
usage will be confirmed through the effluent monitoring program
discussed below. The treatment system will be shut down for changeout
of used to regenerated carbon via a tank truck pumping system.
Contaminated carbon will be properly transported to a licensed treatment
facility where the material will be recycled and adsorbed contaminants
will be permanently and irreversibly destroyed" through thermal treatment.
This pump and treat system will .be designed for continuous (24 hr./day;
seven days a week) operation. Automatic telephone dialing alarm systems
will monitor significant operational parameters which will be recorded.
It is anticipated that an attendant will visit the facility daily to
make operational adjustments. maintain equipment and perform routine
monitoring/testing and reporting as required.
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Preliminary designs anticipate that treated groundwater will be
discharged by gravlt~ In a controlled manner to the stream section below
the Seaman Estate Pond dam via a burled eight-Inch PVC line which will
be approximately 1,200 feet long. Erosion control measures will be
implemented to ensure this surface water discharge does not
signlficantly.erode the stream section as It ma~es Its way to the South
For~ of the Sangamon River. Schematic diagrams of the preliminary
extraction well locations, extraction well design and pump and treat
process are attached as Figures 9, 10, and 11, respectively.
Groundwater modeling and the system's design Indicate that the remedial
action process should not have any impact on the level of water In the
downgradient Seaman Estate pond. However, CIPS and the Agency have
assured the pond's owners and users that, if an unexpected reduction in
the pond's level were to occur due to the remedial activity, necessary
steps would be taken to restore the pond's level.
The components of the groundwater pump and treat system have been
effectively used to remove contaminants reported In site groundwater at
other hazardous waste and Industrial sites. Equipment to be utilized Is
common to those applications; and the extraction wells, treatment system
and discharge line can be constructed concurrently If so desired using
standard construction methods. No long lead times will be required for
procurement or fabrication of the treatment system components.
Therefore, it is estimated that following approval of the remedial
design pac~age, this alternative could be bid within two months and be
constructed and "on-l1ne" within a subsequent 10 to 12 month period.
Operation and monitoring of the system Is discussed later in this
section as the groundwater clean-up objectives are described.
The capital costs for,construction of 'the components of Alternative 5,
which essentially adds a groundwater remedial program to source control
wor~ already accomplished under Alternative 3, Is estimated as
$5,562,071. This figure also includes engineering design and
construction oversight costs and Institutional control transaction and
legal costs. The estimated annual operation, maintenance and monitoring
costs for the groundwater pump and treat system Is $401,400. The total
present worth cost for comparison purposes, using the chosen 30 year
project life at a discount rate of ten percent, is $9,346,034. As
discussed next In this section, actual operation, maintenance and
long-term remedial action (LTRA) and post-LTRA monitoring will be
revisited regularly and adjusted based on the actual field performance
of the groundwater remedy.
The following discussion of major ARAR's, rls~-based levels and TBC
factors associated with Alternative 5 will serve to tie together the
components of the groundwater remedy as proposed and the regulatory
requirements surrounding Its Implementation and performance.
The aquifer which has been Impacted by contaminants from the former gas
plant site Is a potential drinking water resource. Steps were taken
during the Implementation of the operable unit by the responsible party
to protect public health and minimize further degradation of this
aquifer. The Agency has maintained the position throughout this project
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that, with the given site conditions, it is both feasible and beneficial
to restore this groundwater resource to acceptable health based
contaminant levels.
The new changes to the IEPA groundwater regulations have been included
in the ROD since these regulations are an ARAR for this site. These
requirements are listed in Table 12. Surface water discharge levels
have also been revisited in light of current National Pollutant
Discharge Elimination System (NPDES) program requirements and are set as
given in Table 13. It is appropriate to note here that remediation
goals will be regularly revisited as part of the Superfund five-year
review process to ensure they remain protective to human health and the
environment.
In addition to chemical-specific requirements, the Resource Conservation
and Recovery Act (RCRA) program has substantive requirements for design,
operation, maintenance and monitoring of remedial components involving
RCRA "hazardous wastes". In September of 1990, new regulations were
adopted to determine if a waste is "characteristically" RCRA hazardous
using the toxicity characteristics leaching procedure or TCLP. Testing
on representative site groundwater has not been completed to date to
determine if it should be classified as "TCLP hazardous". This analysis
would be performed during the remedial design phase. It is the Agency's
position that substantive RCRA action-specific requirements will be
incorporated into the design, operation, maintenance and monitoring of
the remedial action if the groundwater is found to be characteristically
hazardous. This includes compliance with all handling, transportation
and regeneration or disposal requirements associated with the used
carbon and solids from the treatment process.
Whether or not contaminated groundwater is determined to be
characteristically hazardous, RCRA design, post-closure care and
groundwater monitoring requirements are certainly relevant. Appropriate
40 CFR 264 and/or 35 lAC Subtitle G requirements will be incorporated
into the remedial design operation and maintenance (O&M) documents to
assess the effectiveness of contaminant plume capture, compliance with
the treatment/discharge objectives and progress being achieved toward
aquifer restoration.
For sites such as this where remedial actions are being undertaken in
cooperation with the Agency, the Illinois Groundwater ~rotection Act
requires the establishment of a groundwater management zone (GMZ). It
is anticipated that the GMZ would formally be defined as supplemental
plume analyses are completed during the remedial design phase. It would
initially encompass the area impacted by groundwater contamination above
remediation goals. The groundwater remedial goal is to actively restore
quality within that zone for groundwaters downgradient of the "point of
compliance". The point of compliance is defined in 35 lAC Subtitle G
724.195 as the vertical physical boundary of the waste management
unit/area. In this case, given the small size of the former gas plant
site and close proximity of the system of waste disposal tar holders,
tanks and piping network, the downgradient point of compliance can
effectively be established as the southern perimeter of this waste
management area. Although not specifically developed within the RA/FS
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Update, a nested network of existing (as appropriate) and new stainless
steel groundwater monitoring wells will be designed and constructed as
necessary during the remed'al des'gn phase to assess the quality of
background water, groundwater pass'ng the unit's "point of comp11ance"
and groundwater within and at the perimeter of the management zone. The
des'gn, construction and sampling and analysis program for this
long-term mon,toring effort w'll be consistent with CERCLA, RCRA and
IGPA requirements. The remediation levels are required to be obtained
throughout the affected area since the source material has been removed.
as required by 40 CFR 300. Defining the boundaries of the plume will be
established from the remediation design.
Additionally, the Agency w'll require a representative groundwater
solute and transport computer model, based on current site conditions,
to be developed during the remedial design. This has not been completed
to date. However, once in place it will allow for analyses of the
effectiveness of the pump and treat system over time, based on
comparisons of modeling to actual performance. Given the part per
billion clean-up objectives for PAH's, which are as a class difficult to
remove from saturated soils within the aquifer of concern (rendering
them less mobile than volatile contaminants); the groundwater
restoration time could span several decades. The computer modeling of
this dynamic situation and evaluation within the five-year mandatory
review increments will provide opportunit'es to modify the system to
restore groundwater quality in a "reasonable timeframe" as USEPA
Groundwater Protection Strategy guidance suggests. Once groundwater
cleanup objectives have been reached with'n the management zone, and
statistically confirmed over a defined period, the pump and treat system
will be allowed to be shut down. It is the Agency's position that an
appropriate post-LTRA groundwater monitoring program will continue for a
period yet to be determined, to insure that restoration is complete
before a proposal to delist the site from the NPL is supported. That
"post-closure" monitoring program could be shortened in conjunction with
a site-w'de boring plan to confirm that no residuals remain on-site
above water quality contaminant levels.
Alternative 10 -- No Action
The no action alternative is required by feasibility study guidance as a
baseline against which to compare "action" alternatives. Within the
RA/FS Update, Alternat1ve 10 assumes sHe conditions to be those prior
to operable unit work in 1987 to allow for comparative analysis of
Alternutive 3. That is, conditions were deemed to be similar to those
when environmental problems were discovered in 1985. Near surface
soils/sediments were highly contaminated with volatiles and PAH
compounds posing potential direct contact and inhalation threats and,
most significantly, a continuous source for groundwater contamination
which, if unremedied, posed a threat through ingestion/inhalation.
However, the responsible party chose to include the current, ongoing
groundwater and Seaman Estate Pond annual monitoring program within the
"no action" alternative outlined in the FS.
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Therefore, with the groundwater monitoring wells being used (four
on-site and six off-site) already in-place, there are no estimated
capital construction costs for this alternative. However, there are
lump sum engine~ing and legal fees specified, presumably for plan
imple..ntation and and/liability assessment purposes, whtch total
$230,630. The esttmated annual monitoring cost is $67,200. The total
present worth cost, using the 30 year project life at a discount rate of
ten. percent, becomes $864,119.
VIII. Summary of the Comparative Analysis of Alternatives
The Illinois Environmental Protection Agency's state superfund program
has fully utilized its technical oversight authorities under a voluntary
agreement with the responsible party to develop and implement the
operable unit, Alternative 3. Furthermore, IEPA, as the designated
"lead" Agency for the CIPS/Taylofville site after listing on the NPL,
has overseen the refinement of the Ris~ Assessment and Feasibility Study
Update to 'comply with CERCLA/SARA, the NCP and associated guidance. The
Agency has therefore been directly involved in the formulation and
streamlining of remedial alternatives for this site and has formally
solicited input from the community on completed studies through the
mandated public comment process.
The NCP currently requires that alternatives be evaluated and compared
in relation to the established "nine criteria". These criteria are
commonly categorized in three groups which are briefly referenced below:
The two threshold criteria must be satisfied for an alternative to be
eligible for selection. These are:
Overall protection of human health and the environment
Compliance with applicable or relevant and appropriate requirements
(ARAR's) (unless a specific ARAR is waived)
The five primary balancing criteria are used to weigh major tradeoffs
among alternatives. These are:
Long term effectiveness and permanence
Reduction of toxicity, mobility or volume
Short-term effectiveness
Implementability
Cost
The two modifying criteria are solicited through the public comment/ROD
process. These are:
through treatment
Government (support agency) acceptance
Community acceptance
Detailed information on the nine criteria and the alternative evaluation
process can be found in Section 300.430 of the NCP (Harch 8, 1990) and
the USEPA Guidance for Conductina Remedial Investiaations and
FeasibilitvStudies under CERCLA, (October, 1988).
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What follows is a summary of the comparison of Alternative 3.
Alternative 5 and the No Action Alternative (10), developed for the
CIPS/Taylorville si~e. in terms of the nine criteria.
By des'gn, the development of remedial alternatives and this ensuing
evaluation has been greatly simplified by the completion of operable
unit work, addressing the source component for this site. The
responsible party, under the direction of the Agency. has systematically
studied and addressed potential human health and environmental problems
for the CIPS/Taylorville site as they have been identified. The
responsible party had early on expressed the opinion that Alternative 3,
as implemented. was protective of human health and the environment. The
Agency has, since site discovery and initial investigation, maintained
that a groundwater remedial component would be necessary to ensure.
continued protection of human health. as well as to restore and preserve
the local groundwater resource. The summary of the Superfund evaluation
process utilizing the nine criteria clearly confirms the necessity of an
additional groundwater response action to address remaining risks
associated with this site.
Threshold Criteria
Upon examination of the limited alternatives under consideration it
becomes apparent that Alternative 5 -- Soil/sediment removal.
institutional controls and groundwater treatment is the only one which
offers short and long-term protection of human health and the
environment through an active containment and treatment program to
permanently eliminate unacceptable risks posed by contaminated
groundwater. The groundwater remedial component proposed in Alternative
5 would be operated using the present cleanup objectives listed in Table
12. Similarly. all action-specific requirements associated with the
design. operation, maintenance and monitoring of the proposed
groundwater remedy would be met under the direction of the Agency.
In contrast. Alternative 3 -- Soil/sediment removal and institutional
controls, and likewise Alternative 10 -- No action. do not propose to
aggressively treat risks associated with groundwater contamination from
the site. Protection from potential human exposure rests solely on the
voluntary compliance with land use and deed restrictions set up as
institutional controls. The present levels of contaminants in
groundwater are above regulatory and risk based chemical-specific ARAR's
and TBC's established by the Agency for this site. Through risk
analysts tt has been shown that any future users of site groundwater,
and possibly those downgradient of the site. would not be adequately
protected in the absence of a groundwater remedy. Instead of an active
groundwater component. Alternative 3 (and Alternative 10) would rely on
the natural processes of contaminant dilution, attenuation and
biodegradation over time to achieve some unknown degree of aquifer
restoration. For these reasons the Agency believes Alternative 3 and
Alternative 10 do not meet etther of the required threshold criteria for
serious consideration as a final remedy for .the CIPS/Taylorville site.
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Primarv Balanc1na Cr1teria
The pr1mary balancing criteria are normally ut1lized to draw out the
strengths and w~aknesses of remedial alternatives that meet the
threshold criteria to allow the dec1sion-maker to ident1fy the
alternative that provides the best balance of tradeoffs among them. For
this focussed effort only three alternat1ves have been carried through
the. evaluation process and it has been shown that only Alternative 5
complies with the threshold criteria. However, in order to emphasize
the appropriateness of Alternative 5, it will be compared here to
Alternative 3 on a criterion by criterion basis.
Long-Term Effectiveness and Permanence
Actions were taken under the operable unit, Alternative 3, to eliminate
the potential for direct contact, inhalation and ingestion ris~s
associated with grossly contaminated source material. However,
Alternative 3 stopped short of effectively seeking to eliminate or
minimize risks associated with current or future ~se of contaminated
groundwater. The groundwater component added to Alternative 5 would be
designed to first, arrest the contaminant plume, and then remove
contaminants over time through a treatment process until remediation
goals are met and confirmed. The proposed pump and treat system
therefore affords reliable protection of human health and the
environment with proper operation, maintenance and monitoring. It .
offers a sense of permanence, in effect, by operating unt1l aquifer
restoration or"clea,; closure" is achieved and the site requires no
further special attention.
Reduction of Toxic1ty~. Mobility or Volume Through Treatment
Through implementation of Alternative 3. the statement can be made that
the volume of the site's overall contaminant mass was significantly
reduced, wh1ch in turn reduces potential contaminant mobility, through
the removal action and subsequent placement of source material in a
secure landf'll. Th's accompl'shment can be viewed as an 'ntegral
component in mitigat'ng env'ronmental concerns at this site, though
these reducttons were not treatment or1ented (which was not a high
program prior'ty at the time) and residual source/groundwater
contam'nation was not addressed.
The groundwater pump .and treat system proposed in Alternat've 5 then
becomes the .'5s'n9 element in the remedial program for this site to
actively reduce both contam'nant mob'lity and volume through the plume
capture, extraction and treatment/removal processes. Contaminant volume
and toxic,ty are permanently and irreversibly eliminated in the
inc'nerat'on process used to regenerate the used granular activated
carbon mater'als.
Short-Term Effectiveness
Source removal act'v,t'es were completed by the responsible party In
accordance with approved workplans and under the d'rect superv'sion of
the Agency. It's anticipated that any future construction, operation,
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maintenance and monitoring work such as that proposed in Alternative 5
would be performed through an enforcement agreement. This includes
compliance with health and safety and contingency measures designed to
ensure pubic and worker protection during and after remedial
construction.
The actual installation of the groundwater extraction system is
relatively nonintrusive activity, which should take less than a month to
complete. Because of concerns expressed by one of the nearby neighbors
to the north of the site, who was particularly sensitive to the odors
emanating from the site during the excavation, CIPS has expressed a
willingness to relocate the neighbors in the four homes Immediately
north of the site during the installation of the pumping wells, if they
50 wish. Installation of the pumping system, treatment facility and
discharge lines will take several months, but will not disturb site
residuals until process startup. Air and water quality monitoring and
contingency measures will be included in the operation and maintenance
plan to insure there continue to be no adverse impacts on human health
and the environment during the extended long-term remedial action period
until remediation goals are attained and confirmed and the system is
shutdown and decomissioned. .
Imp1ementabillty
The equipment proposed for the groundwater pump and treat system in.
Alternative 5 is common to the environmental industry. SIte-specific
application will require only proper design, procurement, fabrication
and then construction of the customized facility. Construction
techniques employed will involve standard civil/geotechnical and
mechan.1 ca 1 methods with attention to normal operati ng procedures for
hazardous waste sites. The exchange. transport.and regeneration of
carbon materials will be performed respectively by a permitted waste
hauler and treatment facility. .
Cost
The construction costs of Alternative 3 have already been borne by the
responsible party. The operation and maintenance costs for the current
program are being similarly funded. The cost estimate for design and
implementation of the groundwater remedy proposed in Alternative 5 has
been updated to reflect 1991 prices for the fairly detailed preliminary
design completed in 1989. These present worth capital costs should
therefore be accurate. In contrast to the usual uncerta1n1t1es
associated with excavation work. The present worth cost for long-term
system operation, maintenance and upgraded monitoring is an estimate
because of the unknowns associated with actual sae conditions and
aquifer response.
Modifvina Criteria
Government (Support Agency> Acceptance
USEPA Region V, as the designated support agency for this site, has been
technically involved in this' project since its proposal to the NPL. In
- 31 -
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that role they initially received copies of all project documentation
prior to their involvement and were given the opportunity to comment on
that material. Since that time the region has been involved tn the
developMent of the RA/FS Update, the Proposed Plan and the Agency
sponsored pUblic comment period. Region V has indicated it supports
Alternative 5 as a final remedy for the CIPS/Taylorville site for the
. same reasons as the Agency. Regional staff have expressed technical
con~erns about: .1) the ability of the groundwater containment system to
capture shallow contamination; and 2) the ability of the groundwater
treatment system to remediate cyanide as detected in some groundwater
monitoring work. Commitments have been made to address both of these
concerns during the remedial design phase.
Community Acceptance
IX.
As detailed elsewhere In this decision summary, the public has been
given extensive opportunities to interact with the responsible party,
their engineering consultants and the Agency during the development of
this project. A public meeting to discuss the removal action and the
findings of the RI was held in Taylorville about six months before the
FS hearing. The formal hearing on the RA/FS and Proposed Plan was
preceded by an availability session involving Agency staff. In general,
the community, including the responsible party, was supportive of the
preferred alternative (5). Several public comments that were received
will allow the IEPA and CIPS to "fine-tune" the remedy, within the basic
framework of Alternative 5. Community input received during the public
comment per10d 1s contained in the Responsiveness Summary, which is
attached to this decision summary as Appendix B.
The Selected Remedy
Based on information gathered from studies, implementation of the
operable unit, and. the focussed comparative analysis of alternatives
described in the previous section, IEPA, in consultation with USEPA
Region V, has selected Alternative 5 -- Soil/Sediment removal,
institutional controls and groundwater treatment -- as the appropriate
final remedy for the CIPS/Taylorville Manufactured Gas Plant site. The
components of this remedial action are briefly reiterated below.
The selected final remedy for this site is the same preferred
alternative presented in the Proposed Plan developed and issued by the
Agency. PrelIminary engIneering work has been completed for the
groundwater component as outlined below, but it must be stressed that
these system details may be altered as a result of the remedial design
and field condItions encountered during construction and facility
startup. It Is' anticipated, however, that the Agency will continue to
provide direct oversight of the design, construction and long-term
groundwater remedial action phases and any modIfIcations therein.
As noted throughout this decision summary, the source remedial component
of the selected remedy has already been implemented by the responsible
party under the direction of IEPA. It basically consisted of: removal
of grossly contaminated s011s down to the water table on the former gas
- 32 -
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plant site, as well as removal of highly contaminJted sediments In a
drainageway serving the site; disposal of those contaminated materials
in a permitted off-site landfill; and backfilling and regrading of
excavation areas with clean off-site soils, followed by application of a
surfae. gravel course or revegetation, as appropriate. This source
control action to eliminate a. portion of potential human health risks
and minimize groundwater problems was accompanied by provision of public
water to downgrad1ent residents, Implementation of a groundwater and
surface water/pond monitoring program and land use/deed restrictIons, as
practicable, on potentially affected properties. The above measures
effectively serve to mitigate potential human health threats from the
site in the absence of a permanent remedy to address residual
contamination.
Toward this goal, the selected remedy includes a groundwater component
which complements and builds upon operable unit work to address the
remaining pr~ncipal threat posed by groundwater contamination through an
active treatment program.
This groundwater component has been the focus of supplemental study
since implementation of the operable unit. Preliminary engineerIng and
treatability work indicate that the existing contaminant plume can be
contained and extracted over time by one pumping well (and Its backup>
screened over the entire depth of the aquifer to bedrock, operating at a
rate of approximately 200 gallons per minute. The main extraction well
would be located at the downgrad1ent edge of the small area of former
tar holders and tanks comprising the "waste management unit", which is
also the designated point of compliance for this long-term remedial
action.
Conceptual designs project that contaminants of concern are best treated
by pH adjustment to remove solids, followed by carbon adsorption. There
will be no expected cross-media impacts associated with this closed
treatment process. . Treated groundwater will be piped by gravity flow
and discharged in a controlled manner to the drainageway downgradient of
the Seaman Estate Pond. Analyses will be completed during the remedial
design to Insure that there are no negative impacts on pond recharge
capacity. Precipitated solids from the treatment process will be .
periodically removed, tested, treated If nec~ssary and appropriately
landfilled. Spent carbon will be changed out as necessary through
routine operation, matntenance and monitoring of the system, and
properly transported to a licensed off-site facility for regeneration
through Incineration.
The quantity of residuals to be removed through the groundwater
treatment process has not been estimated. As further plume
characterization and groundwater contaminant flow modeling are completed
during the remedial design, and refined based on actual system
performance, these data will be collected and continually re-evaluated.
In a similar manner, the aquifer restoration timeframe, which has not
been accurately estimated to date, will be modeled during the RD/RA and
tracked against actual pump and treat system effectiveness. Adjustments
to the groundwater remedial components can thereby be made and evaluated
accordingly. The present worth costs for the design, construction and
operation and maintenance of the entire selected remedy, including the
- 33 -
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completed operable unit. are broken out In Table 14 for the estimated 30
year proje~t lifespan.
Through risk analyses it has been shown that the dominant potential
human health risk associated with this site would come from residential
use of contaminated groundwater for drinking or bathing purposes.
Calculated lifetime intake levels exceeded the established USEPA range
of 10-4 to 10-6 excess cumulative carcinogenic risk. Calculated
hazard indices also indicated the potential for noncarcinogenic health
effects exists for these exposures. Lesser carcinogenic risks were
calculated for dermal contact with Seaman Estate Pond water and
Ingestion of pond fish. However. dredging of the sediments in the pond
might mobilize existing contamination by stirring up sediments in the
pond and possibly allow any spring-fed sources of PAH contamination to
flow freely into the pond. Therefore. the excavation and removal of the
sediments would likely create greater risks than the sediments currently
pose. Continued monitoring of the sedime"ts and water quality in the
pond will identify the need for any future actions.
As this project has evolved. lEPA has Internally set groundwater
treatment and surface water discharge objectives for this site through
Its COT/CPRC process. These objectives. based on a combination of
ARAR's/TBC's or risk calculations to the 10-6 risk target level. were
last revisited In July. 1992 and are referenced in Table 12. They
consist of a combination of ARAR's and TaC's for contaminants of concern
in a drinking water class aquifer. based on the regulatory status of
each chemical-specific criter'on at that time.
The NCP calls for use of MCL's and non-zero MCLG's for setting aquifer
restoration objectives. except where attainment of MeL's would result In
a cumulative carcinogen'c r'sk outside of the established 10-4 to
10-6 excess r'sk range. This evaluat'on has been complicated by the
recent promulgation of Illinois groundwater quality standards and
criteria as part of the Illinois Groundwater Protection Act.
-------
.
x.
institutional controls and groundwater treatment -- offers an
environmentally sound solution to the problems posed by the
CIPS/Taylorville Manufactured Gas Plant site.
Statutory Det~rminations
Protection of Human Health and the Environment
The source control component of the selected remedy has already been
implemented by the responsible party. It has essentially eliminated
dermal contact and inhalation risKs associated with contaminated
materials on the former gas plant site. The operable unit has also
served to limit potential ingestion and inhalation risks associated with
the groundwater medium by removing and properly disposing of highly
contaminated wastes off-site; thereby drastically decreasing the
contaminant mass available for continual leakage to the aquifer. In
addition, short-term measures have been taken to insure protection of
human health until a final remedy can be implemented for this site.
These include hoOk-up of potentially affected residences to the public
water supply and voluntary imposition of land use restrictions by the
responsible party for the former plant site and downgradient properties
under their control.
The groundwater component of the selected remedy will be designed and
implemented following finalization of the ROD and a comprehensive
enforcement agreement between the State and the responsible party. It
will reduce carcinogenic risks to within the 10-4 to 10-6 range and
non-carcinogenic risks to less than the established hazard index of one
for contaminants of concern. This will be achieved through a long-term
groundwater extraction. treatment and surface water discharge program.
This will be accompanied by appropriate monitoring and contingency plans
as overseen by the Agency to ensure protection of human health-and the
environment and restoration of the affected aquifer in a timely manner.
There are no unacceptable short-term risks or cross-media impacts
foreseen from construction or long-term operation of this groundwater
remedy.
Comoliance with ApDlicable or Relevant and ADoropriate Reauirements
The selected remedy will meet all identified applicable or relevant and
appropriate federal and state/local requirements. A summary of ARARs
(and TBCs) are listed below:
Chemical-Specific (As identified elsewhere for each
~ contaminant of concern for in-situ groundwater restoration and for
surface water discharge following extraction and treatment)
SDWA Nat'-onal Primary Drinking Hater Standards (40 CFR 141),
MCLS-Applicable
CHA Ambient Hater Quality Criteria. AWQC-Applicable (40 CFR 122)
and NPDES Requirements - Applicable (40 CFR 125)
- 35 -
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Air.
.s.lli
Illinois .Env1ronmental Protection Act (35 lAC Para. 1001 et. seq.)
- General
Illinois Groundwater Quality Standards (35 lAC Subtitle F)' Surface
Hater Quality Standards (35 lAC Subtitles B & C) - Applicable or
relevant and appropriate on contaminant basis
CAA National Ambient Air Quality Standards (40 CFR 50) - Applicable
and National Emissions Standards for Hazardous Air Pollutants (40
CFR 61) - Applicable
Not established due to completion of source component in 1987.
Action-Specific
RCRA definition and identification of hazardous wastes (40 CFR 261)
and (lAC, Subtitle G)
RCRA requirements for generators of hazardous wastes lAC; Subtitle
G, Section 722
RCRA requirements for transporters of hazardous wastes lAC;
Subtitle G, Sectton 723
RCRA requirements for owners and operators of hazardous waste
treatment,"storage and disposal facilities lAC; Subtttle G, Section
724 (for destgn, operation, maintenance and monitoring of
groundwater remedy)
OSHA regulations for workers involved in hazardous waste operations
(29 CFR 1910) and general constructton regulattons (29 CFR 1926)
Illinois requirements for NPDES discharges lAC, Subtitle B,
Chapter I
Illinois requtrements for air pollution prevention ~- organic and'
fugtttve/particulate em1sstons lAC Subtttle B
Location-Spectftc
None tdenttfted
To Be Constdered Crtteria
SOWA proposed maximum contaminant levels (pMCL's) and final and
proposed goals (MCLG's and pMCLG's) (40 CFR 141)
Rtsk-der1ved levels for drinking water or discharge exposures for
contaminants with no ARARs or TBCs
- 36 -
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Cost Effectiveness
Within the normal remedy selection process, where a range of
alternatives have been developed, the relative relationships between
cost and effectiveness are normally explored between the selected remedy
and the other alternatives. However, this site has already seen the
implementation of the source control operable unit, and the actual costs
and perceived benefits have been outlined in this decision summary. The
groundwater component of the selected remedy has been streamlined
through the preliminary design process, as performed by the responsible
party and directed by this Agency. This groundwater remedy was the only
one designated to accomplish the remedial objectives that have been set
for this site. It is therefore implied that the monies to be spent on
implementation of the groundwater remedy are considered reasonable to
achieve the required restoration benefits.
Utilization of Permanent Solutions and Alternative Treatment
Techno1oaies or Resource Recoverv Technoloaies to .the Maximum Extent
Practicable
The Agency believes that the selected remedy -- Soit/sediment removal,
institutional controls and groundwater treatment -- meets the statutory
preference to utilize permanent solutions and treatment technologies to
the maximum extent practicable at the CIPS/Taylorvitle site. The source
removal component of the remedy was implemented before this site was
placed on the NPL. This removal action was carried out under. state
superfund authorities in 1987, with no emphasis placed on use of
innovative treatment technologies or resource recovery technologies.
However, the groundwater remedial component employs a treatment
technology which addresses residual contamination in a permanent,
cost-effective manner. Although not considered innovative, the
groundwater remedy, as enhanced with institutional controls, becomes the
logical solut10n to rema1n1ng env1ronmental concerns, and is ~heonly
alternative focussed on that has been determined to meet threshold
criteria and compare favorably when judged aga1nst each of the balancing
criter1a. Finally, the selected remedy appears to have been endorsed by
the community and local government, USEPA Region V and the responsible
party itself. .
In summary, the selected remedy, by design~ has been developed and
refined to sat1sfy the statutory preferences for utilization of
permanent solutions and alternative treatment technologies to the
maximum extent practicable. It is simply the right solution; to
permanently restore the affected aquifer to a useable resource within a
reasonable timeframe.
Preference for Treatment as a PrinciDal Element
The selected remedy includes a groundwater component. that addresses the
remain1ng principal threat. posed by existing site conditions through
treatment. The statutory preference for a treatment oriented solution
is satisfied by the extraction of contaminated groundwater, its
treatment through carbon adsorption and ultimate contaminant destruction
- 37 -
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XI.
via the carbon regeneration/Incineration process. This long-term
groundwater remedial action will continue until water quality objectives
are met and confirmed, completing restoration of the aquifer.
Documentation of Significant Changes
The Risk Assessment/Feasibility Study Update for public comment was made
available to the community .by the responsible party in late June of
1991. The Proposed Plan for the CIPS/Taylorvil1e Manufactured Gas Plant
site was issued for public comment by the Agency on August 5, 1991. "
That Proposed Plan Identified Alternative 5 -- Soil/sediment removal,
institutional controls and groundwater treatment -- as the preferred
alternative. The public comment period ended on September 19, 1991.
The Agency has reviewed all written and oral hearing comments submitted
during the public comment period as discussed elsewhere in this decision
summary and the attached responsiveness summary (Appendix B). Upon
review of these comments, it was determined that no significant changes
to the remedy as it was identified "in the Proposed Plan were necessary.
- 38 -
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CIPS/Taylorville Manufactured Gas Plant Site
Decision Summary
Appendix A
Tables and Figures
-------
~ - a.n.188 .....-
,~1~~.19
9'19'1
TABLE 1 C0'"J'8P'~ of Ccna:nrrations ~Cikg-dry) of Dc1GCtCQ Priority P Mis FoW1d in Sediment
Samp!a COUec:t.ed from the Seaman Eswc Pond Augllu 1989. Au~ust 1990. and
August 19918
?ftmact Year en.A C$1--8 CloC ~A c.... cu.c: CS6-A C$6.8 CS'-C
':"unaJ!/ltbaleT :919
-------
?riIuO 011 a.c..:.a ...
;..u 1~"".11
3/6/!n
7A8LE 2
Conqmison of Concentrations (uglL) of Detected Priority P AHs Found in
Warer Samples Collected from the Seaman Estate Pond August 1989,
August 1990. ana August 1991
Parameter CSI-B CS4-B
1989 1990 1991 1989 1990 1991
Acenaphthene <0.6444 0.553 <10 <0.644 0.547 -<10
Fluoranmene 0.915 0.039 <0.1 0.315 0.023 <0.1
Naphthalene < 0.254 0.097 <10 < 0.254 0.132 < 10
Source: ESE. 1991.
-------
?rimed OG RecYCled P8!Ier
'oCC51-&lic:ipHIII.18
517/92
Table :3
Comparison of Concentrations (ug/kg-wet) of Detected Prioriry P AHs and
Pesticides Found in Fish Tissue Samples Collected from the Seaman Estate
Pond August 1989, August 1990. and August 1991*
Largemouth Channel
Parameter ~4IC: Blue2:ill Catfish
1989 1990 1991 1989 1990 1991 1989 1990 1991
Acenaphthene <60 01 OJ <60 440 OJ <60 1000 OJ
AnthIacene <1 01 OJ <1 01 OJ <1 3 OJ
Benzo(a)anthracene < 20 OJ 01 <20 7 OJ <20 9 OJ
Chrysene <3 01 01 <3 2 01 <3 2 OJ
Fluoranthene <8 01 01 <8 40 01 <8 90 OJ
Fluorene 6 OJ OJ <6 30 01 <6 OJ OJ
Naphthalene <30 01 OJ <30 OJ OJ <30 40 OJ
Phenanthrene <2 2J 2J <2 OJ OJ <2 10 OJ
Dieldrin 239 OJ OJ 101 01 OJ
A-Chlordane 8J 88 OJ 60J 01 361
.. In 1989 1 values were not calculated, therefore, values are presented as values below the
quantitation limit calculated from the low standard. In all study years after 1989.
J values are reported for all concentrations below the reporting limit.
Source: ESE, 1991.
18
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TABLE 4
PAil CONCEN'J'HA'J'lOtIS J N ~jNOKI::O AND NON~;r'lul,ED F J $11
CJI'S GAS PLANT SITE
'I'AYI.OHVILLE, ILLINOIS
----
--. -----..- -_.. ...h
Fish
fluorene Anthracene
J'yrcllc
!;Q!!fenl[f!t!~ JI!9'~91
Bpnw( ~) .
anrhn.u:t:l\c
...--- -.--------- ----
--.----
Phenanlhrene f luuranlhene
Smoked eel.
Smoked lunpf ish.
Smoked trout'
SnlOked herring"
Smoked herring" (dried)
Smoked salmon"
Smoked sturgeon"
Smoked whitefish"
Smoked whl I lng'
Smoked redl Ish"
Smoked cocf .
Electric snlOked mackerel"
Gas.smoked mackerel"
Nonsmoked haddock" .
Nonsmoked herring" (sailed)
NOllsmoked salmon
9.0
5.0
67.0
2.6
8.2
1,.0
I
26.0
1.5
1.9
2.3
37.0
10.0
52.0
1,.1
9.0
11.0
1,.0 6.0
2.0 1.0
12.0 5.0
3.0 2.2
1.8 1.8
3.2 2.0
2.1, 1,.1,
1,.6 1,.0
0.5
1,.0 3.0
0.6
5.2 3.6
2.6 4.0
1.6 0.8
0.8 1.0
1.8 1.4
\./
0.5
1.2
0.6
. ------
BeOlo( c) .
pyr"n"
Ut..'UIJ
(g,h, i)
r>erylcnc
Ucnzo( d)'
pyr"""
PclylCIIL:
---- -"
I" I.U
0
I.l 1.0. \.IJ
0.1,
0.11
1,.3
6.6 0./ 2.1,
0.3 0.3
1,.0 0.1, 2.2
0.5 0.2 t 0.2
0.2 0.3 t 0.3
PAH
t
jig/kg
Thorsteinsson, 1969; Dungal, 1961.
Howard, et al. 1966a.
Malanos~I, el al. 1968.
Masuda and Kuratsune. 1971.
Polynuclear a,'00181 ic hydrocarbons.
Trace.
Micrograms per kilogram.
05/91/122259/SHOKANDN.TAB/6
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'l'able f
GROUNDWATER ANALY1'ICAL HESUL'l'S - l'OS'J'-IHA MOUI'J'OHIUG
CIPS GAS PLAN'l' SI'fE
TAYLORVILLE, ILLINOIS
'.'--:";11""' .~_. 141
) .
Concentration t~g/~----------- , -______n___- -..-
Sun~le 10t.1 lotal
lIurber Yeer Benlene Toluene Uhylbenlene Xylenes Naphthal tne Acenaphthylene fI uorene Phenanlhrenc AnlhralCIIC
-..-----.-
GU-l 1988 /10(0.5) /10(0.5) /lOtO.5) /10(1.0) /10(2.0) /10(2.0) /lOtO.2) /10(0.6) N[J(O.I)
1989 /IT /IT NT NT NT liT /IT /IT /IT
1990 liT III liT III III III Nf /If /If
GU.2 1988 110(0.5) /10(0.5) /10(0.5) 110(1.0) 110(2.0) /10(2.0) /10(0.2) /10(0.6) NO(O.I)
1989 IT IT IT IT liT /IT /IT . /IT NT
1990 IT III III IT III III /If /If /II
GU'] 1988 290 ] ,700 no 8,900 ] ,700 /10(200) /10(20) ~5 1.1i
1989 IIf IIf liT liT IIf III /If /II Nf
1990 III IIf IT III III III III III /II
GU'4 1988 60,000 20,000 1,200 7,400 8.600 /10(200) IYO 100 18
1989 In IIf Nr IT III III /II /II /II
1990 IT . III liT liT III III III If III
GW-5 1988 110(0.5) 110(0.5) 110(0.5) IIO( 1.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) /10(0.1)
1989 110(0.5) 110(0.5) 110(0.5) If IID(2.0) 110(2.0) IID(0.2) I 11010.6) NOIO.7)
1990 110(0.5) 110(0.5) 110(0.5) /l0(~.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
GW'6d 1988 NO(0.5) /10(0.5) 110(0.5) lIot 1.0) 110(2.0) 110(2.0) NO(0.2) 110(0.6) /lDIO.I)
1989 IT liT IT "' liT liT /IT liT III
1990 III III III II' III III III III III
GW-6s 1988 /10(0.5) /10(0.5) /10(0.5) /1011.0) /10(2.0) /10(2.0) /10(0.2) /1010.6) /10(0.1)
1989 IT IT NT IT lIT /IT /IT liT liT
1990 III III /II /IT /IT III III III III
GW-7 1988 4.5 7.4 17 1,6 930 1101200) 80 59 9.8
1989 2.7 2 2.2 III 160 19 13 29 4.5
1990 2.9 1 2.2 6.2 12 ND(50) 110(50) 21 4.2
GW'8D 1980 110(0.5) 110(0.5) /10(0.5) /1011.0) /10(2.0) 110(2.0) 11010.2) /10(0.6) NO(0.7)
1989 /IT /IT liT IT NT NT /IT NT /IT
1990 III III III III III III III III III
05/91/122259/TABI2-15.TAB/6
-------
'l'able S' Contillued
GROUNDWATER ANALYTICAL RESUL1'S - POS'I'- I HA MON I 'I'OR I UG
CIPS GAS PLANT SITE
'I'AYLORVILLE, ILLINOIS
s:te Toul Concentration (~g/~) "------
Total
II r rear lenrene 'oluene Ethylbenune Xylenes lIaphthalene Acenephthylene Fluorene Phenanthrene Anthracene
GII-8. 1988 110(0.5) 110(0.5) 110(0.5) 1100.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.1)
1989 liT NT liT 111 liT liT liT NT liT
1990 liT NT lIT liT III III III III III
GII-9d 1988 0.7 110(0.5) 110(0.5) 110(1.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0./)
1989 110(0.5) 110(0.5) 110(0.5) II' 110(5.0) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
GII-9a 1988 110(0.5) 110(0.5) 110(0.5) IIO( 1.0) 110(2.0) 110(2.0) 110(0.2) NO(0.6) 110(0./)
1989 110(0.5) 110(0.5) II' IT 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) IIO(Z.O) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
GW-11 1988 110(0.5) 110(0.5) 110(0.5) 110(1.0) IIOCZ.O) 110(2.0) 110(0.2) 110(0.6) NO(O.I)
1989 110(0.5) 110(0.5) 110(0.5) lIT IIO(Z.O) 110(2.01 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) IIO(Z.O) IIO(Z.O) 110(0.2) 110(0.6) 110(0.7)
GII-1Z 1988 110(0.5) 110(0.5) 110(0.5) 110(1.0) IIOCZ .0) 110(2.0) 110(0.2) 110(0.6) 110(0.1)
1989 110(0.5) 110(0.5) 110(0.5) 111 IIO(Z.O) IIO(Z.O) 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) IIO(Z.O) IIO(Z.O) 110(0.2) 110(0.6) 110(0.7)
GII' Ud 1988 110(0.5) 110(0.5) 110(0.5) 110(1.0) 110(2.0) 110 a .0) 110(0.2) 110(0.6) NO(O.I)
1989 110(0.5) 110(0.5) 110(0.5) lIT IIO(Z.O) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) IT lIT liT liT liT
GII-Ua 1988 110(0.5) 110(0.5) 110(0.5) 110 ( 1.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 1111(0.1)
1989 110(0.5) 110(0.5) 110(0.5) lIT 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
G-10h 1988 110(0.5) 110(0.5) 110(0.5) 110(1.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 1111(0.1)
1989 110(0.5) 110(0.5) 110(0.5) II' IIO(Z.O) 110(2.0) 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) 110(2.0) IIO(Z.O) 110(0.2) 110(0.6) 110(0.7)
G-10Zd 1988 110(0.5) 110(0.5) 110(0.5) 110(1.0) 1I0el. 0) 110(2.0) 110(0.2) 110(0.6) 1111(0.71
1989 110(0.5) 110(0.5) 110(0.5) lIT 110(2.0) 110(2.01 110(0.2) 110(0.6) 110(0.7)
1990 110(0.5) 110(0.5) 110(0.5) 110(1.0) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.71
G-iOZa 1989 NO(0.5) NO(0.5) NO(0.5) III 110(2.0) 110(2.0) 110(0.2) NO(0.6) 1111(0./)
1990 110(0.5) 110(0.5) 110(0.51 No(I.O) 110(2.0) 110(2.0) 110(0.2) 110(0.6) 110(0.71
0)/9i/122259/TABl2-15.TAB/6
2
-------
'I'able f, continued
GROUNDWATER ANALV'l'ICAL RESUL'I'S - POS'I'-IHA MONI'l'OIHNG
CI PS GAS PLAN'.' Sl'I'E
TAYLORVILLE, ILLINOIS
Concentration lpg/I)
------
s~. 'ot.1 'oul
. r Ycar lenlene Toluene Uhylbenlcne lIylenes Naphthalene
G-1OJd 1988 IIOCO.5) IIOCO.5) IIOCO.5) IIOC 1.0) 110(2.0)
1989 lIT liT liT II' II'
1990 III III II' lIT II'
G-1038 1988 110(0.5) 110(0.5) 110(0.5) 110 ( 1.0) 110(2.0)
1989 lIT lIT liT II' II'
1990 III II' .., II' ",
.IA Immediate remov.1 .ctlon.
110 Not detected abova method detection limit indicated in parenthese~.
N' Not tested.
jlg/L Micrograms per liter.
Acenaphthylene fluorene Phenanthrene
110(2.0) 110(0.2) 11010.6)
II' liT II'
II' III II'
11012.0) 110(0.2) 11010.6)
"' lIT II'
", lIT ..I
Anthracene
110(0.7)
"'
"'
110(0. II
liT
III
05/91/122259/1A8l2-15.1A8/6
3
I'
Ii
I'
-------
'l'.:sule S I Con t i IHwd
GROUNDWATER ANALYTICAL RESlJUI'S - POST-IRA MONI'I'ORI fiG
CIl'S GAS PLAIn 51'1'£
'l'A YLORVILLE I ILLINOIS
Concentrat !2!1..JllilL_...___-- ,I
Seaple len,oll) lenlolb) Bemol k) BelllO('; )----. ...-- '"''''''''''
lillber Yeer fluor.nthene pyrene Inthrecene Chrysene fluorlnthene fI uorlnthene pyrene Acena,Allhcne
___h.__'- d -- ------
GII-1 1988 NOIO.2) 11010.3) 110(0.08) IIDIO.2) NO(0.02) NO(0.02) NO(0.05) NU(l.U)
1989 NT liT NT liT liT NT NT NI
1990 IIf Nr Nf Nf Nf IIf Nf III
GII-2 1'188 NOIO.2) 110(0.3) NO(0.08) 11010.2) NO(O.O.!) NO(0.02) NO(0.05) NU(2.U)
1989 NT NT NT liT liT liT liT liT
1990 liT liT liT liT liT III III III
GII.3 1988 3.1 3.1 110(0.8) 11012.0) ND(0.2) NO(0.2) NO(0.5) NO (2un )
1989 liT liT lIT NT NT NT liT NI
1990 III liT liT liT NI NI NI NI
GII-4 1988 14 16 5.1 4.1 1.6 1.2 4.5 N(JUlln)
1989 III IIf NT NT Nf Nf NT NI
1990 II' "' II' If IIf III III III
GII'S 1988 110(0.2) 110(0.3) 110(0.08) 110(0.2) IIDIO.02) 110(0.02) 11010.05) 11012.0)
1989 110(0.2) 110(0.3) 110(0.08) 110(0.2). 110(0.02) 110(0.02) 110(0.05) 11012.0)
1990 110(0.2) 110(0.3) 110(0.08) 110(0.2) 11010.02) 110(0.02) 110(0.05) 110(2.0)
1i1l.6d 1988 11010.2) 110(0.3) 110(0.08) 11010.2) 110(0.02) NOIO.02) NO(0.05) No(2.0)
1989 II' liT liT lIT NT NT liT IIf
1990 IIf Nr II' NT IIf Nf liT III
GII-65 1988 110(0.2) 11010.3) 110(0.08) 11010.2) 11010.02) 11010.02) 110(0.05) NO(2.U)
1989 lIT IT liT .T liT IT liT Nf
1990 II' Nr III III "' III III III
GII.7 1988 3.5 3.7 110(0.8) 110(2.0) 11010.2) NO(0.2) 11010.5) NO(203)
1989 3.5 5.4 110(0.5) 0.22 NOIO.02) NO(0.02) 110(0.05) 110(120)
1990 2.2 2.7 0.18 NOI0.5) 11010.02) 110(0.02) 110(0.05) 110(100)
1i1l,80 1988 NOIO.2) NOIO.3) NIIIO.08) NOI0.2) NDIO.02) NOIO.02) NO(0.05) NII(2.0)
1989 NT liT NT NT NT NT NT II'
1990 N' NT N' .., N' III NI NI
05/91/122259/TABL2'15.TAB/6
4
-------
5°"1,1.
Ihllber
GII.8s
GII-9d
GII-9s
GII-11
GII-12
GII-1]d
GII.1].
G.10b
G.102d
G.102s
Year
1968
1989
1990
1988
1989
1990
1988
1989
1990
1988
1989
1990
1988
1989
1990
1968
1989
1990
1988
1989
1990
1988
1989
1990
1988
1989
1990
1989
1990
'I'aulc $, COJltinul!u
GROUNDWATER AUALY'l'ICAL RESUL'l'S - l'OS'I'-lI
-------
'i'able ,,1', Conti oiled
GROUNDWATER ANALYT lCAL RESULTS - l'O~'1'-II(A MOtl 1 TOHillG
CIPS GAS PI~NT SITE
TAYlnRVILLE, ILLINOIS
Concent r !!Jlp11-t! 911 1 ._------- . -..-- - - -----
Sa~le 8enI0(8) 8enlo(b) Benzo( ~ I B",uo(al
NLilbr Year fluorlnthene Pvrene Inthrlcene Chrysene fluorlnthene II uor Inl hene pyrene ACC'MI ,,-, hl"'C
_._---- ___n______--
G-103d 1988 110(0.2) IIIi(O.]) 110(0.08) 110(0.21 110(0.02) 110(0.021 IID(0.051 IIO(2.UI
1989 liT liT liT liT NT NT NT liT
1990 liT III NT liT liT III III NI
G-10J!! 1988 110(0.2) 110(0.3) IID(0.08) ND(0.2) ND(O.O~I IW(O.Oll HIJ(O.O~I Hila .UI
1989 liT NT NT NT NT NT NT NT
1990 III NT Nl III NI NI liT NI
IRA
Immediate removal action.
110
lIot detected above method detection limit indicated in parenlhe~es.
NT
Not tesled.
/lg/L
Micrograms per liter.
05/91/122259/TABL2-15.TAB/6
6
-------
TABLE 5
?OST-:::~'!MEDIATE ::='=:SPONSE ACTICN AMBIENT
AIR ?HOTOIONIZ~TICN DETECTOR (?ID) RESULTS
CIPS G~S PLANT SITE
TAYLORVILLE, .:ILLINOIS
::ate
"..inua
~t!SUI t
(~)
~ate
"ax i nun
ReSUL t
(ppu)
Oate
!o1u.i_-
~es"Lt
(P!DI)
.:.ill
:8/20
::9/11
:9/18
:;121.
'')/02
. ~/11.
: 0/23
:'')/29
: 1/05
: ~ /13
; 1/25
: Zl03
lZ/11
1 Z/21
:z/29
').1
0.2
J.O
:.0
:).1
J.I.
0.3
'0.2
0.0
C.2
0.3
0.3
0.2
0.2
0.3
~
:1/22
'02/12
:3/01.
:3/18
03/31
:1./22
05/12
06/02
06/24
07/14
G8/05
'J8/25
09/16
:0/07
11/04
"/23
12/19
2.W!
~ote: Six parts per million was establiShed as tne level of concern using the portable PIC at ~~e Tenceline.
0.2
0.2
0.1.
0.3
0.2
0.2
0.1.
0.2
0.2
0.2
0.1
0.2
0.2
0.6
0.2
0.3
0.2
01/20
03/03
03/23
Unaatea
0.2
0.2
0.3
0.2
pj:llll
O~rts per million.
OSf91/122259fPOSTIRAT.TAB/6
-------
-,;BLE 7
:::OS7-::'!MEDI.;TE: ?ESFONSE .:,CT:C~1
':O="":"'T::'Z CRGAlHC ::~1POUNDS iJ:::TEC:'ED I:;
SOl:'
'::?S ~.;s t=LAllT S:1'E
:'AY:'::JRVE.LE. :LLr~mIS
:'!ARCH
,
~ .
:'991
, J
:;ncentration (;.t<;/lco)
'1etnYlene
,~lor'ce ~cetone Z-8utanone
. ..a ~ .8 ~D(13)
~ 3 :y a Ja
- 5 ':0 a ..3
: 3 ':0 8 2 ~
. .3 00 a ~D(11)
. .8 ~Y a ~D (12)
3 JS :8 S SO(11)
~ a :8 8 ~0(13)
3 J8 :0 8 ~0(12)
3 JB :20 a 3 J
Xylene
~umcer or Tentatively
::entIT'eo C:mcounas8
50renOle 'umer
: eatn
.Feet)
;- iQ
. ~
sO(6)
SO(6)
~0(6)
'0
,
'J (t:eIC CUCIICate)
'5
5 J
NO(6)
'10(6)
NO(6)
. '
5-1~
'5
NO( 7)
NO(6)
ND(6)
J
.j
;:ource:
-anson, ;;87a.
5
:na,cates tne c:meouna was cetecteo 1n tne clanlc and tne samele.
:naicates an est'matea value tnat :S less tnan tne method aetect10n limit.
..0
~ot cetectea at a concentrat,on aOOve tne metnoa detection limit snown in parentneses.
..g/leg
w'crcgrams oer kilogram.
:entat,velY iOentlfied ccmcounas are tnose comcounos ident,fiea Dv mass scectral liorarv searcn tnat
"ao concentratlcns greater t~an 10 oercent at the nearest ,nternaL s:anaaro. '~is:s eXCLUsIve OT
:arget :cmgounas, surrogates, or ,nternaL Stanoaros.
:S/911122259/POSTIRAT.TAB/6
POO,~ Q.UAL";"Y
0"1'''''''' r . .
." ~IJ\"\;
\..' "~:..e
-
-------
fAUl.t U
AIJ.JlJS'I'ED CAl.CIII,A'I'ED J NCHI~NEII'I'AI. 1.1 FL'I' IIH: t:t"'L'LH H I ~;I;
UPS GAS PL.AUT SI'I't;
'1'/\ YLOHVILLE, ILJ.INOI S
Rcceptor Group
E "ptJ~.1II l."
!.eve!
.---.-..--...-.
._---_._----._-~_._--
!!!!!!!L!!Y{!Q!!!£! !S!L On .~i !!L!!!!Ji i.!k!H~~!!
IIcIIII~1 Ourlll~ U..IIIIII~
A~
RM~
UOE
loldl
AI.
RM~
UDE
!!!!ure IIVIIO!b!:!i8!!.!!!l: ~!!£ !!£1!jdcn!~L~.fbi!g
Dc' ilia I 0111'1119 IIdihill9
AI.
RMI.
10lal
A(
RM~
-a.- ....--. ------...-....--....--..-..
AE
RHt
UDE
Original
Adjusted
Average exposure.
Rea~onal>le maximulII c'l'u~urc.
Upper bOllnd exposllle.
lJ~e 01 equal ion to call1ll.llc flS~ Icve! Ihdl arc
Use 01 onc'hit I:qll~ti"n 10 cal(uldle cancer I isk
0.. igilloll
Lintel Ri~.k 11'\1:1
"Relativ;----- -"-----(j;I~-IU.O'u:
PotCIIl':Y Putc.u.:y
- -----" - - . - ---
2
~ . 08 , 10 1
2.21 x 10 1
J . 60 x 10
2
~.I/.1U1
2.25 , 10 1
J.66 x 10
2
7.7~ x 101
1.90 x 10
1.1I~ . 10 2
1. 91 x 10 1
-._..a._._.
RcI"llve
PutC'11 Y
Ad"",lcd
!:~!!~~.:!". !H~:t ! ~ .:~:!
Onc III III It:
"t.( l~r1t:Y
l ~8 . )I, I
108
1./6
~.tll.l11~
2.10 , 10 1
1.29 . 10
)" I 1
L.".J A II I
7.24 . III
9.~! . 10 1
..' ..1:. " III 1
7. J I . III I
9.65 . 10 I
S. ~t, . III :
6.55 . 10
S.,'II , III I
6. ~y . III I
, .- .~_.-_.
I incar with respecl 10 du>~.
levels that are within the '(JH~e lit V.lIIII..:. lIulI "Ie Ihlullnl:.11 ~I(h "':'1,,:11 III d.,".,.,
U~/YI/1222~9/PII'S/CIPSAUJI/6
.!" ~U ... lu 1
1.09
1.77
5. 1'1 . III .'
,
2.11.101
1.54 x 10
I
1.79,1111
9.11 . 10
I.c.l . III ~
1.82 x 10
i.1I1 . III :
9.1~ x 10
1./n . III .'
1.84 . 10 1
POOP OJ 1\: ;'~-V
. , .'., '-'. . ., , ~
01"..'-.'.'." .
b~i\.;;.i .<. ~:,
-------
'I'ubl c
'I
CALCULATED IUCHEt-IEII'I'AI. LIFE'I'U1E CAUCEH I
-------
'I'db J e ,
Cant i J1IU,.j
CALCIJLATED
I NCHEMENTAL 1.1 FETIME CAIICI~I< H I ~I\ AlIIJ IIAZAIW
IIWEXI:::..;
CIPS GA~ PLAUT ~ITE
'l'AYI.OHVILLE, ILLTNOI:..;
Rcceptor (,ro"p
~ XpU:"UI t:
level
Cancer Risk l£~! . ~,~!!!.
'-RclaiIY';-- (. . lo'(.nc
r.Oll:'IIl:Y Pl11l.'n.."(
Adull
lIal." II
IIKlc,l(
Lm..,'r R hk ! !:II!:! .: ~!,! I!!
-tiiL1ti~;.-- One-to (!I,e
I'U(L'IIl:Y P(llt~'II:Y
[hlld
11,.0.'''1('
1111'1',0(
------ -------. --+---_. ----
----~------ ------
l!!!:i!L.B£J£!!.!£!!!!i
Dermal Exposure 1o Scdllllcnl IIh II e Al 3.12 . 10 . I. I~ . IU " ~.!t, . III I 1 - 2.1) X 11..1'11 I. III k III " ; II I" "
.
I resl,ass i ny 81 Scam~n Estate Pond RHl 1.15 . 10 I 8.39 . 10 I 7.85 10 ' 2.71 10 I I.JO, 10 ' ].2~ 111 s
" .
liMe 2.85 . 10 I 1. J6 . 10 " 7.85 , 10 "
Oermal lJl{pu~urt: 10 5cllIIllCf1t~ Al ~.uu k 10 ' ~ .1:' . 111 .. .! .UI . III '. 1.<'0 . I" " I . 'I~) . III U. ,:'J I"
.
IIhlle 1respassiny at Area A RHE Z.14 x 10 ' 2.01 . 10 . Z. 41 . 10 . 3.31 x 10 ' J. II 10 u 1.02, IU .,
,
USE 3.47 x 10 I 3.26 x 10 " 2.H . 10 .
OCI1II81 fxpu~urc lu 5clIIIIICIIIs IIhi Ie Af '.04 x 10 . 4.1I~ x HI " 2(~ . III " 2.YI . 111 " 2 01 . III ' \. Ii III
k
Irespassing at Area B RHf 2.e6 x 10 ' 2.02 x 10 " 3.74 10 . 4.'2 K 10 / 3.B 10 ' I. 54 IU '
x x x
use '.64 x 10 ' 3.28 x 10 . 3.74 x 10 .
lotal Al 1. ~2 10 " 1. IS , It) I ~.N x )I) " ~.IIII . IU " ~.611. III ~ . III III
. .
RHt 6.75 x 10 I '.87 . 10 " 7.00 " IU . 1.04 10 " 7.53 10 " 5.110 10 I
K . .
use 1.10. 10 . 7.91 " 10 h 7.00 , 10 .
- .....--.--.
AE
Average exposure.
IIHE
Reason..hle ""IX Inun e'posure.
IIUf
lippeI' tJuund C"'''.I"III C.
l': ';
U~/\l1/ 122259/PI I I SIC I PSSUH/6
2
-------
TABLE JO
ON-SI'I'E BOREIIOL!:: SOIL AflALYSIS RESIJL1'S - POS'l'- J!JU I HEf-IEUl A'I' lOti SMU'LI lit;
Cll'S GAS PLAN'I' 51'1'1:;
'I'AYLORVILI.E, ILLINOIS
March 1987
PerenlCter
R-1
R-l
-------,- - - !;~!i!!!ri!U!!!l.I~!I/~!I} .---
R-3 R' k-~ --Nt.
-H I
H U
--.-. ...- - -- ---------------- - ~ -......
Vo I a HI e _Qrsan i c COfr(>OlIncis
Benrene 120,000 110(50) IIO(~O) 1\10 HII(~U) l,lUIi l~iI NIIOII)
Chiorobclliene 110(5,000) 110(50) 110(50) 110(200) 110(50) 110(50) No(50) 110(50)
Dichlorobenzene (tolat) 110(5,000) 110(50) 110(50) 110(200) 110(50) 110(50) 110(50) 110(50)
Ethyl benzene 7,600 110(50) 110(50) 690 110(50) 1,100 290 110(50)
'oluene 190,000 110(50) IIOISO) 5,500 110(50) 1,200 no 110(50)
Xylene (tolat) 107,000 110(50) 110(50) 12,500 110(50) 1,5'0 1,2JO 110(50)
t21cv~llc Aromati~ Hydrocarbons
Acenllphthylene 1101400,000) 110 ( 100) IIO( 100) 110(40,000) 110(100) 110('0,000) HO(',OOIJ) 1/11 ( "II»
ACenlphthene 110(400,000) 110(200) 110(200) 110140,000) 110(2001 110(40,0001 11014,000) 110('00)
Anthrlcene J], 000 110(4) 35 4,500 110(4) 2,800 3,700 100
lenzo(l)anthrecene 23,000 110(10) 71 5,800 110(101 2,000 820 65
lenzo(b)fluorlnthene 7,800 110(5) 31 1,900 110(5) 7,800 36 31
lenzo(k)'luor.nthene 5,000 110(5) 20 1,200 110(5) 380 220 U
Ienzo(8,h,1 )perylCl,e 5,100 110(20) 20 110(1,600) 110(201 1I0( 1,600) 380 29
IenroCI Ipyr.ne 17 ,000 110(10) 57 5,300 1I0ClO) 1,600 760 72
Chrysene 110(40,0001 110(10) 110(100) 4,100 1I0ClO) 1,400 110 ,,"(';00)
OJ benzoC e, h lanthraccne IIOC40,OOO) IIO(40) IIO(40) 110(4,000) 110((0 I 11014,000) HlJ14(10) HOI'O)
fluorenthene 34,000 110(10) 120 9,200 110(101 3,300 1,500 20IJ
fluorene 89,000 110(20) 180 23,000 110(201 5,800 1,400 80
Indeno(I,2,3-c,d)pyrene 5,600 110(10) 35 IIO(4000) 110(10) 110(4,000) 460 N1J(40)
lIapllth.lene 400,000 IIO( 100) 150 100,000 110(1001 19,000 1,600 NOI'OO)
Phenanthrene 110,000 110(8) 1'0 16,000 110(81 11,000 2,900 520
pyrene 56,000 110(201 160 15,000 H0(201 5,200 2,100 280
Source: Hanson, 1987,
110 Not detected al a cOllcentratiun awve Ihe method udediunlllilit :.hown in "aleflthc~e>.
jig/kg Micrograms per U logram.
U5/YI/122259/[i,,~.Tub/6
12
-------
:'.3.ble
:.FF-5::-:::
20REHOL~ :0 ~~ - ?OOT) ~OIL ;~AL~S:S R~S~L~S -
'?OST-l987 ?E:MEDIATICN' SAMPL:~;G
::PS GAS PLANT SITE
:'AYLORVr:.:.z, ::'L::~IOIS
~1arch 1987
:~rameter
A-1
:cnce"t~atic~ (UQ/ko)
A-2
A-3
:~lat'l~ Oroanl~ r~unas
::enzene
:~ lorocenzene
: : ~rll orccenzene
":~Vlcenzene
.:~uen@
('\ene (:Otal)
(r:)tal)
~0(50)
.0(50)
.,0(50)
-0(50)
-0(50)
'0(50)
'IO(50)
'IO(50)
IIO(50)
'IO(50)
NO(50)
'IO(50)
'10(50)
'10(50)
'10(50)
'IO(50)
'IO(50)
330
=,.,lc"'Ctt-: ~~~"'IC!t;c ~VC!roc:a"oon~
Acenacntnvlene
Acenacntnene
Anthracene
5enzoCa)antnracene
3enZOIC)fluorantnene
3enZOI~)fluorantnene
SenzoI9,h,i)cerYlene
SenZOla)cyrene
Ch~ene
JibenzoCa,h)antnracene
F I uorantnene
Fluorene
inaeno(1.Z.3-c.c)pyrene
Nacntnalene
~"enantnrene
=yrene
'IOCl,OC)
'O(l,O:J)
'10(11.0)
NO(16)
'lOCI.)
'10(4)
NO(16)
NO(10)
N0(40) .
'10(40)
NO(40)
N0(40)
'10(40)
'10(400)
1/0(120)
NO(60)
'10(1.00)
NO(400)
NOC11.0)
NO( 160)
21.0
110
480
490
130
'10(400)
130
'10(1.0)
'10(400)
120
76
300
NOCIoOO)
110(400)
IIO(140)
'10(160)
Z,O
110
1.80
1.90
130
'10(400)
,30
'10(40)
'10(1,00)
,20
76
300
>ource:
Hanson, ,987.
I/O
..;/lI:g
~icrogr8m8 cer Kilogram-
Not aetectea It a concentration alXlve the llletllOG detection limit indica tea in parentneses.
:S/91/1ZZ2;9/Cios.Tab/6
~3
-------
@
Illinois Environmental Protection .-\g~n.:y
P. O. Box 19~76. Springfield. IL 62794.9: 76
Table 12. Cleanup Objectives for Class I Groundwater
for CIPS - Taylorvil1e
July 14, 1992
Class I
Groundwater
Objective
(mg/l )
Paralleter
Acenaphthene
0.42. a .
Ni xture 1
I -
Anthracene
Benzo(a)anthracene
2.1
0.00013
Benzo( a )pyrene
Benzo(b)f1uoranthene
0.00023
0.00018
8enzo(k)f1uoranthene
Chrysene
0.00011
0.0015
Dibenzo(a,h)anthracene
0.0003
Fluoranthene
0.28. a
Mixture 1
Fluorene
0.28. a
Mtxture 1
0.00043
Indeno(1,2,3-c,d)pyrene
Naphthalene
0.025
Pyrene
. 0.21, a
Mixture 1
ADL
(ag/1 )
0.01
0.0066
0.00013
0.00023
0.00018
0.00017
0.0015
0.0003
0.0021
0.0021
0.00043
0.0006
0.0027
Parueter
~
~1ass 1 Standard
'.!Sill
0.005
1.0
Benzene
Toluene
Ethyl benzene
~lenes
0.7
10
trans-l.1-dichlaroe~lene
0.1
. '..,
...~:.
.~~
ADL
(8g/1 )
.002
.002
.002
.002
..005
-------
Class I
Groundwater
Objective ADL
Parameter mall ( ma 11 )
Other Non-Carcinogenic PNAs 0.21
Acenaphthylene 0.01
Benzo(g,h,i)pery1ene 0.00076
Phenanthrene 0.0064
2-Methy1phenol (1) 0.35 0.01
4-Methylphenol (1) 0.35 0.01
Dichloromethane 0.0002, & 0.0002
Mixture 2
Bromoform 0.0002 0.0002
Di-n-butyl phthalate 0.7 0.0033
Bis(2-ethylhexyl)phthalate 0.0027, & 0.0027
Mixture 2
ADL:
Acceptable Detection Limit; lowest Practical Quantitation Limit (PQL)
from SH846.
Objectives Basis: 35 lAC 620 Subpart F: Title 35: Environmental Protection
Subpart F: Public Hater Supplies
Subpart F: Health Advisories
(1) Sum of concentrations of 2-methylphenol plus 4-methylphenol is not to
exceed 0.35 mg/1.
Mixture 1: In addition to meeting the individual Class I groundwater
objectives indicated in Table 12 above, the following equation must be
satisfied to prote~~. against liver, kidney, and blood toxicity.
[acenaphthene] + [f1uoranthene] + [fluorene] + [cyrene ] ~ 1.0
0.42 mg/l 0.28 mg/l 0.28 mg/l 0.21 mg/l
Mixture 2: In addition to meeting the individual Class I groundwater
objectives indicated in Table 12 above, the following equation must be
satisfied to protect agatnst ltver tumors.
[dichloromethaneJ + [bis(2-ethylhexyl)phthalateJ ~ 1.0
0.0002 mg/l' 0.0027 mg/l
The Nondegradation Provisions of 35 lAC 620 Subpart C may also be applicable
at this site.
TF:jab/1978rll
-------
Q
~
:ABLE :2
:;;iIlOIS E::,vlrOnmenl31 P:-otecuon A~t:nc....
? O. Box d~7~. 5;mn~li~iu. IL o':794-Q:76
:houid C:?S choose to discnarae treateo arounowa~er to the Soutn ForK of the
~an~amon River as previousiy aiscusseo. an NPDES perm1t wiil be reQuirea. The
~ollow1n9 NPDES discharge limits ~lll appiy.
Parameur
limit- 'Ila/l)
aenzo( a )pyrene
3enzota)antnracene
Napntha 1 ene
?henan~rene
AcenaDtnene
Anthracene
F1 uorantnene
Total Phenol s
Toluene
3enzene
::thylbenzene
t-l ,2 Oiehloroethene
Oi chI orometnane
Xvlenes
2:':~tnyl pneno1
"-/.lethy 1 ?heno i .
01-n-butyl phthalate
~lOECn
~ 1 00':
O~5
1
i90
10
60~8
2~3
398
100
2~400
2.200
3,200
1 4,000
1 9,300
~.Q90
1 I 900
1 ,900
73
effl uen~
*Daily Maximum Concentration
~No Observable Effect Concentration based on chronic toxicity test.
7ne above limits assume no dilution is available in the receiving strealll and
:hat technology-pased limits are less restrictive than water quality-based
: i mi ts.
3M:j as/1956k ,I 08-1 09
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2111132~~~O
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~"I~ ,~ .,IU2e is aQe~.t. ~~ COfttl'~ t~~ c~atePts ~f t,~ ta"t, tt
~'d ~~t .II~ fo~ na~trI11rltf,~ of . soil1.
4.
S~ling ~f 11tl 1~i~ate5 t~t t~e ~1s'~I~~ ~1 @xcee1 effl~~ftt o~
"at... aoItl i ty n.rt'2/1rds fo,. t r3". : IPS sno" 1 (j add",ss --t~.. tile ~,..,1t
1f~'ts c.n ~ 'C~1~wed.
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~LTERNAT!~E ~ - SOIL/SEDIMENT RL~OVAL,
:~ST!T~~ICNAL C=NTROLS. AND
GROt,.NDWATER TREATMENT COST :::STIMATE SW11MARY
CIPS GAS PLANT SITE
TAYLORVILLE, ::"LIUOIS
Construction Annual ::>resent
Cost CQI1'I)Onet1t Costs O&M COSts -ortn
~oil Removal, OisDCsal ana Backfill $1,1006,016
2. .ater MaIn ConstrUCt10n ana ConnectIon $1610,956
3. Seaman Estates Dam ana Settlements $249,T79
.cn9 rerm Mon1torln9 567,2:0
.. :xtraCtlon Wells ana D;scnarge ~loin9 $393,1.00
,. ;~~cess BUIlo1ngs $192.900
,'te wore S69,OOO
, ::luu:ment $265.300
" °rocess Pilling $39,800
'0, : nstrLnentat 10n $32,500
'1. :bservatlon ana Startue $133,100
'2. :oeratlng Personnel $11,1090
~3. :oeratlng Mater1alS $200.000
~ i.. MaIntenance $12.600
~S. 'J: i lit; es $34,830
~6. Sol; as D ISDCSaL $2,I0Io0
17, :uarterly ana Annual Reoortlng S60,OOO
18. Samollng ana Analvtlcal $12,8100
19. ~Odi ti onal Samaling ana Analvtlcal 'st Tear $28.260
Construct10n suctotal 12, 97'S .011
~obll i Zat1 on, OOnclS, insurance (5,.) $148,7'50
"ealtn ana saTety (~) 1208,250
aid contIngency (15%) $446,250
Scooe contingency <20%) 5595,000
Construct10n management (5%) 5148,7:0
:onstruct10n total $4.522,011
Engineering tees <10%) $452,200
cegal fees (5%) $226.100
SerV1ces auring conStruct10n C8X) 1361,760
'otal cacltal ana imolementat;on cost 55,562,071
Annual 0&" cost $401,1000
;>..esent "ortn 53,783 .963
~otal present wortll 59,346.034
~ote: T~e o..esent wortn calculation was ~erTonneo accoroing to tne metnoo snown in Acpeno;x E at a discount
cate 0; 10 percent over 30 years.
:5/91/1222S9/SECT6.TAB/6
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122259
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TYPICAL EXTRACTION WELL DESIGN
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~PR'NGFIEL.C.IL. . peORIA,IL. . ROCKFORD.IL.
U,2. WELL DIAMETER
GAS PLANT SITE
CIPS
TAYLORVILLE, ILLINOIS
J::>B NO. 85S3086J
Fi£ure :
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ACID
STORACE
GRANU~R
ACTIVATED
CARBON
BACKWASH
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ALTERNATIVE 5
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, WELL. AND F'UWP I
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John Mathes Ie Associates, Inc.
GRANULAR ACTIVATED CARBON
GROUNDWATER TREATMENT SYSTEM
F1.0W DIAGRAM
CIPS GAS PLANT
T AYLORYlW. IWHOIS
, 222~!J .
Figure 11
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO. IL 60604.3590
S Q $EP 1992
REPlY TO THE ATTENTION OF:
R-19J
Ms. Mary A. Gade
Director
Illinois Environmental
2200 Churchill Road
Springfield, IL. 62706
Protection Agency
Dear Ms. Gade:
The United States Environmental Protection Agency (U.S. EPA) is
providing you with this letter to document U.S. EPA's concurrence
with the final remedy selected for the Central Illinois Public
Service Company (CIPS) site in Taylorville, Illinois. The
proposed remedy, as outlined in the August 1991 Proposed Plan,
includes the following:
A.
Construction .of an on-site ground water pump and treat
system.- .
B.
Operation and maintenance of the system until Illinois
Environmental Protection Agency (IEPA) 's cleanup objectives
are met.
C.
Expansion of the monitoring program for untreated ground
water and treatment system effluent to supplement current
monitoring efforts.
D.
Complete fencing (with signs) of-the site.
E.
Land use and deed restrictions, to the extent possible, for
the site and affected off-site areas.
In addition, an immediate removal action has already been
completed by the responsible party under a state superfund
notice. This action included the following:
1.
Excavation of contaminated source materials above the water
table (9,000 cubic yards of soil; 3,000 cubic yards of
sediment; disposal of source materials off-site in a
permitted landfill; and backfilling of excavation areas with
clean materials.
Printed 011 RscycIBd Paper
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"
2.
Connection of potentially affected residents to the public
water supply; and plugging and abandonment of associated
private drinking water wells.
3.
Monitoring of ground water, surface water, pond sediment,
and fish downstream of the site.
The U.S. EPA concurs with the selection of the final remedy for
the CIPS Site as described above and in the IEPA's Record of
Decision Summary for the CIPS Site, a copy of which is enclosed
and made part of this letter. Because this remedy will result in
hazardous substances remaining on-site above health-based levels,
u.S. EPA expects IEPA to conduct five-year reviews after
commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment. Thank you for your support and cooperation in
addressing the contamination problem at the CIPS Site.
Sincerely yours,
~,~Ii.ltfb
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