Environmental Protection
Agency
Emergency and
Remedial Response
May 1984
Superfund
Record of Decision:
Outboard Marine Corp.
Site, IL
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing]
1. REPORT NO.
EPA/ROD/R05-84/007
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION:
Outboard Marine Corp. Site, IL
5. REPORT DATE
05/15/84
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Outboard Marine Corporation (OMC) site is located north of Chicago on
the shore of Lake Michigan. It is the location of an outboard motor manufacturing
plant which used polychlorinated biphenyls (PCBs) in its die cast machines for
about 20 years ending in the early 1970's.. Discharges from the facility resulted
in highly contaminated sediment in Waukgan Harbor and contaminated soil in the
parking lot north of the plant and the "North Ditch," a tributary of Lake Michigan.
The cost-effective option considered for this site was excavation and off-
site disposal of PCB contaminated material. This is the only option that meets
the requirements of TSCA and guarantees the halt of PCB migration. The cost of
this option is more than $75 million. Because of the high cost to implement this
option it was necessary to Fund Balance. Fund Balancing is appropriate where the
alternative that would fully satisfy the technical requirements of other environ-
mental laws is extremely expensive, and another alternative which approaches the
same level of effectiveness can be implemented for a much lower cost. The Fund
Balanced alternative for this site provides for off-site disposal of PCB contaminated
hot-spots and on-site containment of the moderately contaminated materials. The
cost of the Fund Balanced selected alternative is estimated to be $21.57 million.
Key Words: On-Site Containment, PCBs, NEPA, Dredging, Water Quality Standards,Fund
Balancing .
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Croup
Record of Decision
Outboard Marine Corp. Site, IL
Contaminated media: gw, sw, soil, river
sediments, fish, air
Key contaminants : PCBs' hydraulic fluids,
oils
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report/
None
21. NO. OF PAGES
28.
20. SECURITY CLASS (This page)
None
22. PRICE
EPA Form 2220-1 («•». 4-77) PREVIOUS EDITION is OBSOLETE
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ROD ISSUES ABSTRACT
Site; Outboard Marine Corporation, Waukegan, Illinois
Region; V
AA, OSWER
Briefing Date; May 7, 1984
SITE DESCRIPTION
The Outboard Marine Corporation (OMC) site is located north of
Chicago on the shore of Lake Michigan. It is the location of an
outboard motor manufacturing plant which used polychlorinated biphenyls
(PCBs) in its die cast machines for about 20 years ending in the early
1970's. Discharges from the facility resulted in highly contaminated
sediment in Waukegan Harbor and contaminated soil in the parking lot
north of the plant and the "North Ditch," a tributary of Lake Michigan.
SELECTED ALTERNATIVE
The cost-effective option considered for this site was excavation
and off-site disposal of PCB contaminated material. This is the only
option that meets the requirements of TSCA and guarantees the halt of
PCB migration. The cost of this option is more than $75 million.
Because of the high cost to implement this option it was necessary to
Fund Balance. Fund Balancing is appropriate where the alternative that
would fully satisfy the technical requirements of other environmental
laws is extremely expensive, and another alternative which approaches
the same level of effectiveness can be implemented for a much lower
cost. The Fund Balanced alternative for this site provides for
off-site disposal of PCB contaminated hot-spots and on-site containment
of the moderately contaminated materials. The cost of the Fund
Balanced selected alternative is estimated to be $21.57 million.
ISSUES AND RESOLUTIONS
1. Two options for on-site containment of the PCB
contaminated harbor material were considered.
These on-site options were (1) containment in
Slip 13 and (2) containment on the Outboard
Marine Corporation (OMC) parking lot. Both
alternatives are considered to be technically
acceptable. Although containment in the OMC
parking lot was estimated to cost up to $1.9
million more, this cost differential would be
decreased by whatever costs would be incurred
for land acquisition costs in the slip area.
However, this cost differential was outweighed
by added ease of monitoring and implementation
for the parking lot site.
KEY WORDS
. On-Site
Containment
. PCBs
-1-
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Outboard Marine Corporation, Waukegan, Illinois
May 7, 1984
Continued
ISSUES AND RESOLUTIONS KEY WORDS
In the feasibility study/ remedies from . NEPA
several operable units were combined into a
limited number of "assembled alternatives."
During the ROD process, EPA decided to
reassemble the remedies for the operable
units, in response to public comments.
By reassembling the alternatives, the issue
of NEPA compliance was raised. In the
future, it is important to present all
possible combinations of remedies to the
public as potential alternatives. In this
way, EPA ensures compliance with NEPA.
The selected remedy involves dredging all . Dredging
sediments with PCB contamination above 50 ppm. . PCBs
A model supported selection of 50 ppm on the . Water Quality
basis that it provided a margin of safety to Standards
assure that after implementation of the
remedy the harbor water column would meet
ambient water quality standards, and fish
would not accumulate PCB beyond the FDA
standard.
The Fund Balancing provisions in CERCLA and . Fund Balancing
the NCP were used to select an option that is
significantly less expensive and only slight-
ly less reliable than the cost effective
option.
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Record of Decis.iori
Remedial -Alternative Selection
SITE; Outboard Marine Corporation (CMC), Wauke-jan, Illinois
DOCUMENTS REVIEWED;
I have reviewed the following documents describing the analysis
of cost-effectiveness of remedial alternatives. for the OMC bite:
- OMC Feasibility Study, CH2M-Hill, July 14, 1983
- OMC Technical Documentation (a staff summary of the information
collected during sampling, modeling and engineering studies
conducted by Region V as part of tne litigation effort)
- Summary of the Remedial Action Alternative Selection
- Responsiveness summary addressing comments received fror: the
public.
DESCRIPTION OF THE SELECTED ALTERNATIVE:
- The alternative selected for each segment of the site is shown
on the attached Table 1.
DECLARATIONS:
Consistent with CERCLA and the NCP, I have determined that the
source control remedy described in Table 1 is the appropriate
Fund-financed action for this site in accordance with section
300.68(j) and (k) of the NCP. Although the selected remedy does
not meet all the requirements of regulations issued under TSCA
and is somewhat less protective than the cost-effective option
as defined by the NCP, the remedy is expected to be reasonably
effective in preventing the migration of PC3 from the site which
would threaten public health, welfare or the environment. In
addition, this remedy is expected to be significantly less expensive
than any alternative which would be fully consistent with TSCA
regulations and protective of public health. Therefore, I have
determined that the level of protection provided by the selected
remedy is appropriate considering the need for additional protection
at this site and the amount of money available in the Fund to
respond to other sites which present or may present a threat to
public health, welfare or.the environment.
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• • .
The State of Illinois has been consulted and agreesfevi th the
remedy. The action will require future operation aid mainten-
ance activities to ensure the continued effectiveness of the
remedy. These activities will be considered part of the approved
action and eligible for Trust Fund monies for a period of one year,
In accordance with section 104(c)(3), the State is required to
ensure the continued operation and maintenance of the selected
remedy.
In addition, the offsite transport and secure disposition of the
highly contaminated material (see Table 1) is more cost effective
than other remedial action and is necessary to protect public-
health, welfare or the environment.
'•"V—t—"
\
Lee M. Thomas
Assistant Administrator
Office of Solid Waste and Emergency Response
'
Date
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S i I o Soijmont
Wnukegan Harbor
COMPONENTS OK TIIK KlINI) HAI.ANCEI) AI.TKRNAT IVE
Remedy Recommended
1. H tTTrrTy^con tain i na ted material
(hot spots - >10,0000 ppm)
2. Moderately contami nated
material (500 - 10,000 ppm)
3. Loss contaminated material
CiO - 500 ppm)
B. Oval l.acjoon/Crescont Ditch
1. Highly contami nated ma tori a
(>i0,000 ppm)
2. Less cont.imi n.il'.oil tn.itorial
C. North Ditch
1. Material above storm sower
2. .Material below storm sewer
Fxcavation, dewatering, fixation and
olf-site disposal in a PCR landfill.
Excavation, downterimj in laijoon,
fixation to minimi/.e volatilization,
an(J disposal on OMC i>arking lot.
Excavation, IOIKJ term dowatorinq in
layoon, and disposal on OMC parking .lot.
Excavation and off-site disposal in a
PCM landfi11.
Containment on site.
- Slurry walls down to glacial till
Impermeable cap
Excavate and contain in the
Ova 1 Laijoon.
Capped wi tli clean fill and clay cap.
Cost
$ 3.15 Mi Hi on
$10.00 Mi Hi on
$ .74 Million
S 4.21 Million
I). Parking Lot
Contained in place with contaminated
ilri.-dcjo spoil?; from Waukegan Harbor.
Slurry walls down to glacial till
- 1 mpormi'cib 1 o cap
$3.2 Mi llion
TOTAL
$21.30 Million
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/v: :"">. UNITED STATES
ENVIRONMENTAL PROTECTION AGtNCY
• REGION V
CHICAGO :;.. '.0!3 3C5C4
• •
MEMORANDUM
.-•'Ay 4 884
SUBJECT: Recommendation for Remedial Implementation
Alternative Selection - CMC Hazardous Waste Site,
Waukegan, Illinois
FROM: Valdas V. Adamkus
Regional Administrator
TO: Lee M. Thomas
Assistant Administrator
Office of Solid Waste and
Emergency Response
EPA has completed the following remedial CERCLA activities
at the Outboard Marine Corporation (OMC) Site located in
Waukegan, Illinois.
Activity Date
Final Work Plan, Source Control Feasibility
Study 3/28/83
Source Control Feasibility Study Report 7/15/83
Opening of First Public Comment Period 7/15/83
Public Informational Meeting 7/28/83
Public Meeting 8/3/83
Close of First Public Comment Period 9/1/83
Opening of Second Public Comment Period 3/6/84
Public Informational Meeting 3/14/84
Close of Second Public Comment Period 4/4/84
Region V has reviewed the information in the reports and
has given careful consideration to the comments received in the
public comment periods. Pursuant to Section 104(c)(2) of
CERCLA, we have consulted with the State of Illinois before
determining the appropriate remedial action. Based on our
review, Region V recommends that the following actions at the
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OMC Site~effectively mitigate and minimise damage to and prv/i.-io
acceptable protection of public health, welfare, and tthe e-ivir ?'i-
nent. The recommended action included some off-site transport
as such a'ction is nore cost-effective than other remectial
actions and is necessary to protect public health, werfare, n~ 1
the environment from the potential risk which may be created by
further exposure to the continued presence of PCBs at the OMC
Site. As discussed with your staff, the following recommendation
includes fund balanced considerations.
Action
Dredge, Dewater, Dispose, Cap
in Parking Lot
(Slip No.3 and the Upper Harbor)
Estimated Cost
S 9,940,000
Dredge, Remove, Fix and Dispose
5, "00 yd3 of PCB-contarninated
mater ia 1
Excava te
Crescent
Cap
North Ditch, Contain in
Ditch/Oval Lagoon and
Excavate and Dispose 5,500 yd-5 of
PCB-contaminated material
(Crescent Ditch/Oval Lagoon)
Contain and Cap
(Parking Lot)
TOTAL
S 3,150,000
S 4,210,000
S 740,000
S 3,210,000
521,250,000
Operation and maintenance costs for the site are estimated
to be 534,250 annually, or 5800,000 for 30 years on a present
worth basis of 10%. The Illinois Environmental Drotection
Agency will be responsible for the operation and maintenance.
Region V additionally recommends that EPA share in the
costs of operation and maintenance for a period of one year
following completion of the project. This time frame is needed
to allow for settling of the cells and to assure the integrity
of the cells.
Valdas V. Adamkus
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Illinois Environmental Protection Agency • 2200 Churchill Road. Springfield. IL 6^7
217/782-5544
Mr. Basil Ccrstantelos .
Director, Waste Management Division L .
United States Environmental Protection Agency, T
Region V {
230 South Dearborn Street
Chicago, IL 60604
Re: Source Control Feasibility Study
CMC - Waukenan Harbor Site
Dear Mr. Constantelos:
On September 19, 1983, the Agency transmitted to your office a letter
endorsing the alternatives set forth in Secticr. 7 of the Source Control
Feasibility Study for the CMC - Waukegan Harbor site dated July 14, 1983,
as being an approach which is technologically feasible in providing
adequate protection of public health, welfare and the environment. The
Agency also concluded that the approach was cost-effective as long as
the control alternatives were implemented in a phased manner to allow
the flexibility to assess development of new technologies at the various
increments of the project.
On May 1, 1984, members of Region V staff presented to myself, Agency •
staff rerbers, and a representative of the Illinois Attorney General's
Office a proposal which would replace Alternative 63 as set forth in
the July 14, 1983, feasibility study with Alternative 6D as set forth
in a letter, dated April 4, 1984, which was prepared in response to
a request from USEPA - Region V by the authors of the feasibility study.
The Agency does not object to substitution of alternative 6D as long
as alternative 6D and the remaining Section 7 alternatives are imple-
mented in a phased manner which recognizes the fiscal constraints on
the State of Illinois in raising its matching share, and which allows
the flexibility to assess the development of new technologies at the
various increments of the project.
Richardi J.J Carlson
Director
cc: Jim Frank
Roger Kanerva
Gary King
RJC:GPK:kam
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Summary of Remedial Alternative
Selection - CMC Hazardous Vfeste Site,
Waukegan, Illinois
I. Site Location and Description
The Outboard Marine Corporation site (OMC) is located near the intersection
of Grand Avenue and Sheridan Road on the west shore of Lake Michigan in
Waukegan, Illinois, about 37 miles north of Chicago and 1Q miles south
of the Wisconsin state border. See diagram on next page.
Waukegan Harbor is an irregularly shaped harbor about 37 acres in area.
The two areas of concern are Slip No. 3 and the Upper Harbor. PCB
concentrations -in Slip No. 3 are greater than 500 parts per million
(ppm). In the Upper Harbor, PCB concentrations are between 50 and 500
ppm. Water depths in the harbor generally vary from 14 to 25 feet with
sane shallower depths in Slip No. 3. The harbor sediments consist of 1
to 7 feet of very soft organic silt (muck) overlying typically 4 feet
of medium dense, fine to coarse sand. A very stiff silt (glacial tilH
that typically ranges from 50 to more than 100 feet thick underlies the
sand. The entire harbor is bordered by 20- to 25-ft-long steel sheet
piling, except at the Waukegan Port District boat launching areas and
at the retaining wall near the harbor mouth. The sheet piles generally
extend into the sand layer above the glacial till.
The North Ditch is a small tributary of Lake Michigan that drains
surface runoff from about 0.11 square miles of OMC and North Shore
Sanitary District property. The ditch also drains surface runoff from
an area west of OMC property and the railroad tracks. The North Ditch
includes the 600-ft-long, 20-ft-wide Crescent Ditch; the 240-ft-long,
10- to 20-ft-40-ft-wide Oval Lagoon; and a 2,000-ft-long, 10-to 20-ft-
wide east-west portion of the North Ditch. PCB concentrations are
between 50 and 5,000 ppm in the North Ditch/Crescent Ditch/Oval Lagoon
area. The U.S. Department of the Interior measured the mean daily
discharge of the ditch between March and September 1979 as 1.8 cubic
feet per second (cfs), with a maximum discharge of 5.3 cfs. They
calculated the 5-year storm event to be 23 cfs.
The Parking Lot area is located north of CMC's Plant No. 2 and 'is about
9 acres in area. PCB concentrations are between 50 to 5,000 ppm.
There are three entrances to the lurking Lot area: two fenced entrances
in the northwest corner of CMC's property and one fenced entrance
southeast of CMC's new die-cast complex at the intersection of CMC's
private road and Seahorse Drive.
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The generalized subsurface conditions in the North Ditch/Parking Lot
area consist of- typically 30 feet of cctrpact, very fiiie to fir.e Si.-.d
overlying a stiff too very stiff silt (glacial tilD.feThe thickness of
'the glacial till typically ranges fron 50 to more thallOO feet.
The presence of high levels of PCBs in soil and harbor sediments in the
vicinLty of the CMC plant was discovered in 1976. In Slip No. 3,
approximately 10,900 yd3 of material are contaminated by PCBs (exceeding
50 ppm). Available data indicates that approximately 305,200 Ib of
PCBs exist in the contaminated slip. Currently no barriers exist to
retard migration of the materials into the Upper Harbor and potentially
Lake Michigan. This is exaserbated by continual boat traffic in the
harbor. Approximately 35,700 yd3 of muck in thc> Upper Harbor are
contaminated by about 5,000 Ib of PCBs (exceeding 50 ppm). See Exhibit
C pq 1-6. In the North Ditch/Parking Lot area, approximately 175,800
yd^ of material are contaminated by PCBs (exceeding 50 ppm). Currently
available information indicates that approximately 771,200 Ibs of PCBs
exist in this contaminated area. See Exhibit C pg 1-6. Currently no
barriers exist to retard migration of the substances into the environment.
It is currently estirrvated that 7 to 20 Ib of PCBs are discharged annually
into Lake Michigan from the North Ditch. The groundwater is within 3
feet of the surface of the Parking Lot area, resulting in contamination
of this water. It is estimated that the slowly moving water will begin
releasing some 8 Ib/day of PCBs into Lake Michigan in approximately f
years. Existing air contamination from the North Ditch waters is
estimated at 15 Ib/yr. Any additional movement of the soil, currently
under the paved parking lot, could cause additional volitalization of
PCBs. See Exhibit C pg 6-16. Approximately 98.4 percent of the PCBs
now found in the Slip/Harbor area are located in Slip No. 3, 1.6 percent
have migrated into the Upper Harbor. See Exhibit C, pg 8-9.
Site History
Discharges of process water cooling water, and water from floor drains,
from CMC are the major source of PCB contamination to the area. About
9 million pounds of PCB's were purchased from the Monsanto Company from
the early 1950's to 1971. These PCB's were used as hydraulic fluids in
die casting machines and related equipment.
Because the hydraulic systems in which the hydraulic fluids were used
leaked routinely, the fluids containing PCB's escaped from die-cast
machinery onto the surrounding floor area. CMC has advised U.S. EPA
that 10 to 15 percent of all PCB's purchased may have escaped through
floor drains and an oil interceptor system. The floor drains discharge
to Waukegan Harbor and the North Ditch Drainage. U.S. EPA has estimated
that the discharge could have been as high as 20%.
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Release of PCB's from the sice is frccn Surface Vsater, feriatil 12.2 tier.,
Groundwater, and the Food Chain. Possible receptors include the
biological community of the harbor, North Ditch, and Nearshore Lake
Michigan Area. People are exposed or potentially exposed through fish.
consumption, potentially through the drinking water supply, and by
direct contact.
The official 1980 Census figure for the City of Waukegan is 67,653.
The Harbor area, however, is zoned for industrial use. Fifteen businesses
are located in the irradiate Haroor area and provide jobs to approximately
3,500. The local Port Harbor for primarily recreational use. Long
term plans additionally include a development of the Upper Harbor. See
Exhibit C pgs 6-12, 6-13.
The population is exposed to PCS through three medias; air, water, and
the food chain (pri.-rarily fish). It is currently estimated t.-.at 22 Ib
of PCBs are released into Lake Michigan each year fron Waukegan Harbor
water (based on a steady state model). Approximately 12 to 40 ID of
PCBs are released from the Harbor into the local airshed eacn year."
Existing air contamination from the North Ditch waters is esti.Tated at
15 Ib/yr. See Exhibit C pgs 6-16 through 6-17. Total PCB concentrations
vary fron 0.6 parts per billion (ppb) in Waukegan Harbor to less than
0.01 ppb in Lake Michigan directly offshore from Waukegan Haroor.
There is an emergency water supply intake for Waukegan near the mouth
of the harbor, although it is rarely utilized. See Exhibit C pg 6-20.
In U.S. EPA studies on Lake Michigan fish, results ranged frcm
concentrations of 2.7 ppm to 187 ppm PCB in fatty tissue for all
species.
Enforcement
U.S. EPA filed suit against the CMC and Monsanto Companies in 1976.
The suit is still in effect, not being brought to trial. The existing
suits may be dismissed and reinstated as a Superfund Cost Recovery
Action following implementation of the cleanup. U.S. EPA has conducted
several years of negotiations with OMC to try and reach an agreement
regarding a cleanup plan. Since no agreement could be reached over a
long period of time, Region V recommended to Headquarters that the Fund
be accessed for the cleanup.
Alternatives Evaluation
The feasibility study began with an evaluation of over 70 unit processes
or methods to determine their potential for contributing to PCB removal.
The processes retained from preliminary screening were assembled into
21 alternatives. Finally 17 alternatives and two subalternatives were
selected for more detailed evaluation. Final alternative selection was
based upon the Feasibility Study, input from the community relations
program, and input from various headquarter's offices.
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Community Relations . '.
•
Prior to the selection of the appropriate remedial action at the CMC
site the-following actions were taken and the documents identi&ed were
reviewed by the Regional staff: T
A. On March 28, 1983, a Final Work Plan, Source Control Feasibility
Study, CMC site, Waukegan, Illinois was authorized. U.S. EPA Work
Authorization 13-5M28.0.
B. On July 14, 1983, a Source Control Feasibility Study, CMC
Hazardous Waste Site, Waukegan, Illinois (FS) was completed.
C. On July 15, 1983, a public comment period to evaluate and
comment on the FS began. A public informational meeting was held in
Waukegan on July 28, 1983, to respond to any questions by the public.
On August 3, 1983, a public meeting was held in Waukegan to receive
formal public comment on the FS. Finally, on September 1, 1983, the
extended public comment period was closed.
D. Twenty-five written comments in addition to the comments
received during the public hearing were received and responded to by
the Region.
E. On March 6, 1984, a second public comment period to evaluate
and comment on two issues in addition to the FS began. A public
informational meeting was held in Waukegan on March 14, 1984, to respond
to any questions by the public. On April 4, 1984, the public comment
period closed.
F. Over 250 public conments were received during the public
comment period and responded to by the Region.
G. As affected Agencies, the Illinois Environmental Protection
Agency and the U.S. Corp of Engineers were informed of and involved in
the preparation of the FS. Additionally, pursuant to 16 U.S.C. 662(a),
the U.S. fish and Wildlife Service, Department of Interior was informed
about the FS. No adverse comments were received by U.S. EPA fron these
Agencies.
Consistency with other Environmental Laws
U.S. EPA conducted the feasibility stu-y process in accordance with the
National Contingency Plan, and to the greatest extent possible, in
compliance with the National Environmental Policy Act. U.S. EPA
developed a cost effective alternative which is consistent with other
environmental laws applicable to the site. Since a Fund-Balanced
alternative is under review a Superfund waiver from TSCA requirements
may be needed.
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Recorrended 'Alternative '.
In accordance with Part 300.68(J) U.S. EPA conducted a complete cost
effective analysis concerning a wide range of alternatives.' The
alternative presented below also contains fund balancing considerations.
Slip No. 3 and Upper Harbor: Hot Spot Removal
PCB-ccntaminated sediment, sand and silt would be dredged from the
localized area near the former OMC outfall (drainage pipe). This
material contains the greatest PCS concentrations in. the harbor and
represents 92 percent of all the PCBs now found in Slip No. 3 and the
Upper Harbor. This alternative would remove, fix, and dispose of
offsite an estimated 5,700 yd3 of PCS contaminated material, containing
about 286,500 Ib of PCBs. The material would be disposed of in an off-
site licensed chemical waste landfill. The estimated cost for this
alternative is 53,150,000.
Slip a 3 and Upper Harbor; Dredge, Dewater, and Dispose in Parking Let
A sediment dispersal control device would be installed at the southern
end of the Upper Haroor. A clay-lined dewatering lagoon will be con-
structed an the OMC vacant foundary property. Sediments in excess of
50 ppm PCS will be removed frcn the harbor by hydraulic dredging. Sedi-
ment slurry will be pumped to the dewatering lagoon. Supernatant would
be decanted, treated to 1 ppb PCB's and returned to the harbor.
Solids would be treated in two fashions
1) Highly contaminated material from slip:
dredge > initial dewatering > fixation
2) Less contaminated material from the harbor:
dredge > initial dewatering > mechanical dewatering
Solids will be periodically removed by dragline and hauled by truck for
disposal in the parking lot. This will be codisposed with the existing
contamination in the parking lot.
Approximately 46,600 yd^ of sediments containing about 24,700 Ibs of PCB's
would be removed from the harbor, dewatered, and disposed in the parking
lot. Contaminated lagoon material would also be brought to the parking
lot. This alternative is estimated to cost 59,940,000.
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North Ditch Area: Hot Spot Removal
PCS contaminated soil would be excavated fron the localized areas in
the Cresent Ditch and Oval Lagoon. This material contains aobut 89
percent of all the PCB's now found in the North Ditch area, 'and
about 57 percent of all the PCB's now found in the North Ditch
parking lot areas.^ This alternative would remove and dispose of an
estimated 5,500 yd3 of soil containing about 440,500 Ib of PCB's.
The soil would be disposed of in an offsite licensed chemical waste
landfill. The estimated cost is 3740,000.
North Ditch Area: Install Bypass Sewer and Contain Onsite Contaminated
N.D. Material
PCB-contaminated soil would be ccr.tained and capped in the Cresent Ditch/
Oval Lagoon area. The North Ditch would be partly excavated to install
a bypass drainage pipeline. The PCB-contaminated soil fron the bypass
excavation would be placed in tr.e Cresent Ditch/Oval Lagoon area before .
cappinng the area. This alternative would contain about 492,100 Ib of
PCB's in 51,400 yd3 of soil. The estimated cost is $4,210,000.
Parking Lot: Contain and Cap
Approximately 277,700 Ibs. of PCB's in 105,000 yd3 of soil occur in the
CMC parkling lot. 46,600 yd3 of dredge material fron the harbor will be
brought to the site, graded and compacted.
The total contamination will be contained with slurry walls andd capped
in place. The elevation of the parking lot will increase 14 feet. This
portion of the project is estimated to cost $3,210,000.
The total estimated cost to implement the above recommended cleanup action
i e- f\r\ ^en nnn
is «J^\f j t Jv | ^W.
ion and Maintenance
According to our memo concerning predicted O&M requirements of the
proposed project, O&M will inv^i -e mo»ing of vegatative containment v
cell covers and sampling monitoring wells. The design life of the
structures is 30 years. Annual OiM costs are estimated to be 84,250.
This is also estimated to be $800,000 for 30 years on a present
worth basis at 10%.
The Illinois Environmental Protection Agency is identified as the
State Agency responsible for 0&M.
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Schedule Cate of Implementation
Key Milestones (after RCD signature)
Complete Enforcement Negotiations 30 days
Aware/AG for Design Coord. Corrpleted
Superfund State Contract 45 days
Award IAG to initiate design 40 days
Start Design 45 days
Complete Design 6 months
Award Cooperative Agreement for 8 months
Construction
Award Superfund State Contract for 8 months
Construction
Start Construction 10 months
Ccrplete Construction 3.5 years
Future Actions
Following construction, U.S. EPA will be responsible for O&M for one
year. At that point long term OiM will revert to State responsibility.
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CMC Technical Documentation
TABLE OF CONTENTS
fPage
•
.-,. s^wv. ^-v... ...^v.iw.. 1
B. EPA work at the OMC site 2
C. Concentrations of PCB found in the soil/sediment 5
D. Mechanisms of PCB Release from OMC 6
1. Air 6
2. Water and Sediment 7
3. Ground Water 8
E. Impact of PCB on Use of Waukegan Harbor • 9
II. Toxicity of PCB 14
III. Threats to Public Health and the Environment Posed
by PCB f ran OMC
A. Threats to Public Health 16
1. Drinking Water '. . 16
2. Ingestion of Contaminated Fish 16
3. Dermal Exposure 17
4. Inhalation 18
B. Threats to the Environment 18
TV. Evaluation of "No-Action" Alternative 22
V. Feasibility Study
A. Extent of Remedy 23
B. Screening of Alternatives - 24
C. Excavation and Off-site Disposal 25
D. Containment on-site 27
VI. The Cost-Effective Remedy 30
VII. Fund Balancing 32
VIII. The Fund - Balanced Alternative 34
A. Development Process 35
B. Waukegan Harbor 41
C. Oval Lagoon/Crescent Ditch 43
D. North Ditch 44
E. Parking Lot 46
F. Evaluation of Threat Under Fund Balanced
Alternative 47
IX. TSCA 48
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BRIEFING MATERIAL ON CMC REMEDIAL ACTION
• • • ' .
I. BACKGROUND F
A. Site Description
The Outboard Marine Corporation site (CMC) is located near the intersection of
Grand Avenue and Sheridan Road on the west shore of Lake Michigan in Waukegan,
Illinois, about 37 miles north of Chicago and 10 miles south of the Wisconsin
state border. The site may be divided into three areas: Waukegan Harbor, the
North Ditch and the OMC parking lot. See Figure 1.
Waukegan Harbor is an irregularly shaped harbor about 37 acres in area. The
two areas of the Harbor of concern to this project are Slip No. 3 ana the
Upper Harbor. Water depths in the Harbor generally vary from 14 to 25 feet
with some shallower depths in Slip No. 3. The Harbor sediments consist of 1
to 7 feet of very soft organic silt (muck) overlying 4 feet of medium dense,
fine to coarse sand. A very stiff silt (glacial till) that typically ranges
from 50 to more than 100 feet thick underlies the sand. The entire Harbor is
bordered by 2O- to 25-ft-long steel sheet piling, except at the Waukegan Port
District boat launching areas and at the retaining wall near the Harbor mouth.
The sheet piles generally extend into the sand layer above the glacial till.
The North Ditch is a small tributary of Lake Michigan that drains surface
runoff fron about 0.11 square miles of OMC and North Shore Sanitary District
property. -The ditch also drains surface runoff from an area west of OMC
property and the railroad tracks. The North Ditch includes the contain the
6OO-ft-long, 20-ft-wide Crescent Ditch; the 240-ft-long, 1O- to 40-ft-wide
Oval Lagoon; and a 2,000-ft-long, lo-to 20-ft-wide east-west portion of the
North Ditch. The U.S. Department of the Interior measured the mean daily
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North Ditch Area
/N
Parking Lot Area
Upper Waukegan
Harbor Area
PCB CONCENTRATIONS
OVER 500PPM
PCS CONCENTRATIONS BETWEEN
50 AND 500 PPM
Site Map
r•au
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- 2 -
discharge of the ditch between March and September 1979 as 1.8 cubic feet per
second (cf.s), with a maximum discharge of 5.3 cf.s. They calculated the 5-year
• •
storm event to be 23 cfs. fc •
The Parking Lot area is located north of OMC's Plant No. 2 and is about '•)
acres in area. There are three entrances to the Parking Lot area: two fenced
entrances in the northwest corner of OMC's property and one fenced entrance
southeast of OMC's new die-cast conplex at the intersection of OMC's private
road and Seahorse Drive.
The generalized subsurface conditions in the North Ditch/Parking Lot area
consist of typically 3O feet of compact, verv fine to fine sand overlying a
stiff to very stiff silt (glacial till). The thickness of the glacial till
typically ranges from 5O to more than 10O feet.
B. EPA Work at the CMC Site.
High levels of PCBs in soil and harbor sediments in the vicinity of the OMC
plant were discovered in 1976 and 'were found to have originated in the OMC
outfalls. With this discovery, EPA and State of Illinois began a series of
attempts to force OMC to cease discharging PCB and remove the PC3 contaminated
sediments from Waukegan Harbor and the North Ditch area. These attempts
culminated in a suit filed against OMC by EPA to force OMC to dispose of North
Ditch soils and dredge/dispose of contaminated Harbor sediments and a countersuit
by OMC against EPA. As a result of these suits, EPA conducted a series of
studies to assess the nature and extent of environmental problems in air,
surface water, ground water, soils and sediments of Waukegan Harbor and North
Ditch areas and southern Lake Michigan.
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- 3 -
These studies included sarrpling studies:
An Engineering Studv for the Removal and Disposition of PCS Contamination
in the Waukegan Harbor and North Ditch at Waukeqan Harbor, Addendum to
Final Report. Prepared for USEPA Region V, Chicago, Illinoiir. Lexington,
Kentucky: Mason & Hanger—Silas Mason Co., Inc., May 1981. |
Hydrogeologic Investigation, Outboard Marine Corporation, Waukegan, Illinois.
Prepared for USEPA Region V and JRB and Associates. Madison, Wisconsin:
Warzyn Engineering, Inc., September 20, 1979.
CMC Technical and Witnessing Case Support Hydrological Studv. of Ground
Water, Final Report. Prepared for USEPA Oftice of Water Enforcement,
Washington, D.C. McLean, Virginia: JRB Associates, Inc. February 10, 1981.
Sediment and Shore Sample Collection, Waukegan Harbor Slip #3. Prepared
for USEPA Region V, Chicago, Illinois, and Mason & Hanger—Silas Mason
Co., Inc. Madison, Wisconsin: Warzyn Engineering, Inc., May 26, 1981.
Kamauskas, Robert J. Subsurface Investigation, North Ditch Area Outboard
Marine Corporation, Waukegan, Illinois. Prepared for USEPA Region V,
Chicago, Illinois. Madison, Wisconsin: Warzyn Engineering, Inc., July 29,
1980.
Outboard Marine Corporation, Waukegan Harbor Boring, Waukegan, Illinois—
C 9791. Prepared for Mason & Hanger—Silas Mason Company, Inc., and USEPA
Region V, Chicago, Illinois. Madison, Wisconsin: Warzyn Engineering,
August 5, 198O.
Sand Sample Collection, Waukegan Harbor Slip No. 3, Waukegan, Illinois—C
956O. Prepared for Mason & Hanger-Silas Mason Company, Inc., and USEPA
Region V, Chicago, Illinois. Madison, Wisconsin: Warzyn Engineering,
Inc., January 6, 1981.
Sediment and Shore Sample Collection, Waukegan Harbor Slip No. 3, Waukegan,
Illinois—C 9729. Prepared for Mason & Hanger—Silas Mason Company, Inc.,
and USEPA Region V, Chicago, Illinois. Madison, Wisconsin: Warzyn
Engineering, Inc., May 26, 1981.
Mathematical Modeling Studies;
Thcmann, R.V., and M.T. Kontaxis. Mathematical Modeling Estimate of
Environmental Exposure Due to PCB-Contaminated Harbor Sediments of Waukegan
Harbor and North Ditch. Prepared for USEPA, Cincinnati, Ohio. Mahwah,
New Jersey: HydroQual, Inc., February 1981.
Thcmann, R.V., and M.T. Kontaxis. Mathematical-Modeling Estimate of
Environmental Exposure Due to PCB-Contaminated Harbor Sediments of Waukegan
Harbor and North Ditch. Prepared for USEPA, Cincinnati, Ohio, Mahwah,
New Jersey: HydroQual, Inc,, February 1981.
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- 4 -
An Estimate of Sediment Movement in North Ditch, Waukegan, Illinois.
Prepared fos USEPA Region V, Chicago, Illinois. Champaign, Illinois:
United States Department of the Interior, Geological Survey^ 1980.
Roberts, S.A. Waukegan Harbor Slip No. 3—PCS Loading RatesT Prepared
for USEPA Region V, Chicago, Illinois. Vihite Plains, New York: Maicol.T
Pirnie. July 21, 1982.
Volatilization. Prepared for USEPA Region V, Chicago, Illinois. White
Plains, New York: Malcolm Pirnie., August 5, 19B2.
Biological Studies;
Harris, Rosalind Mason. Waukegan Harbor PCS Fish Levels. Prepared
for USEPA Region V, Chicago, Illinois. White Plains, New York:
Malcolm Pirnie, July 9, 1982.
- Study titled, "Outboard Marine Corporation Biological Studies Report,
"February, 1979, prepared bv USEPA, Region V, Central Regional Labora-
tory. (This report is not a public document).
- Study titled, "Effects of PCB's on Plankton," September 8, 1981, pre-
pared by Donald C. McNaught.
- Study titled, "Health Risks Posed to Consumers of Fish Contaminated
with PCB's from Lake Michigan," February, 1981, prepared by Clement
Associates.
Engineering Studies:
An Engineering Study for the Removal and Disposition of PCS Contamination
in the Waukegan Harbor and North Ditch at Waukegan, Illinois, Final Report.
Prepared for USEPA Region V, Chicago, Illinois. Lexington, Kentucky:
Mason & Hanger—Silas Mason Co., Inc., January 1981.
An Engineering Studv for the Removal and Disposition of PCS Contamination
in the Waukegan Harbor, and North Ditch at Waukegan, Illinois. Prepared
for USEPA Region V, Chicago, Illinois. Lexington, Kentucky: Mason & Hanger--
Silas Mason Co., Inc., January 1981.
Volatilization of PCBs During Planned Waukegan Harbor Cleanup Operations,
Literature Review. Prepared for USEPA Region V, Chicago, Illinois.
Lexington, Kentucky: Mason & Hanger—Silas Mason Co., Inc., May 1981.
An Engineering Studv for the Removal and Disposition of PCS Contamination
in the Waukeqan Harbor and North Ditch at Waukegan, Illinois. Prepared
for USEAP Region V, Chicago, Illinois. Lexington, Kentucky: Mason & Hanger-
Silas Mason Co., Inc., January 1981.
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- 5 -
The numerous investigations conducted over the years allowed EPA to accurately
define the'site i/i terms of the.extent and quantity of contamination. The
studies show that the OMC site is the largest uncontrolled potentpi source of
PCB to Lake Michigan. More than one million pounds of PCb are present on
site. The PCB is shown to be bioaccumulating in the fish in Waukegan Harbor
and Lake Michigan. The modeling studies demonstrate that the PCB is leaving
the site through movement of the surface water and ground water, volatilization
to the air and transport of the sediment.
C. Concentrations of PCB Found in the Sediment;
Sampling data from Slip #3 showed PCB in concentrations up to 520,000 parts
per Trillion (ppm). It is estimated that more than 3OO,OOO pounds of PCB are -
contaminating 1O,000 cubic yards of sediment in Slip #3. Data fron the upper
harbor areas of Waukegan Harbor also shew PCB contamination. It is estimated
that approximately 5,OOO Ibs of PCB are present in 35,700 cubic yards of sediment
in the upper harbor. The concentrations found in these sediments are much
smaller than those found in the sediments of Slip 3; the highest concentration
is 5OO ppm PCB. _ Figure 2 shows the average concentration of PCB found in the
various segments of Slip #3 and Waukegan Harbor.
North of the OMC plant, the North Ditch area contains sediments with concen-
trations of PCB exceeding 35,000 ppm. It is estimated that 495,000 pounds of
PCB are present in 7O,8OO cubic yards of sediment and soils in the North Ditch
area. Finally, the area of the OMC parking lot contains approximately 277,700
pounds of PCB in 105,800 cubic yards of soil. The concentrations found in
this soil range up to 5,COO ppm. Figure 3 shews the areas north of the OMC
plant with concentrations of PCB greater than 50 ppm.
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- 6 -
D. Mechanisms for PCB Release from OMC:
The sampling and modeling studies showed that PCB's are being released from
the OMC si-te to the surrounding environment. Lake Michigan is thF ultimate
receptacle tor most of the PCbs. The mechanisms by which the PCBs are being
released include the air, through volatilization of the pollutant; the sur-
face water, through the flushing of Waukegan Harbor and runoff through the
North Ditch; the ground water, through the slow movement of the ground water
towards Lake Michigan; and sediment transport, through the movement of sediment
with surface and ground water. The rates of release of PCB through each of
these mechanisms were explored in the investigations conducted by EPA.
1. Air
Although no air -nonitoring for the presence of PCB's was conducted at the
site, modeling was used to estimate rates of volatilization of PCB from UMC.
The concentration of PCB expected in solution at the sediment/water interface
was estimated by mixing contaminated sediment in water, decanting the mixture
and analyzing for the PCB concentration of the water. This concentration was
used with transport rate equations to estimate the rate of volatilization from
the site. A volatilization rate of 3.8 mg/m 2 / hr frcm a saturated solution
(based on experiments conducted by General Electric in New York) was assumed.
If volatilization is considered proportional to the concentration of PCB in
solution, calculations based on the volitilization rate and the area of the
site show that approximately 3.3 pounds of PCB per month are leaving the harbor
portion of the OMC site through the atmosphere. Because that rate would vary
positively with temperature, EPA estimates a total of 12 to 40 pounds per year
of PCB are volatilizing from the harbor. In addition, it is estimated that
the North Ditch contributes 15 pounds of PCB to the atmosphere per year.
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OVTTFALL
Average
oo PCS
Total Ai-Ao (Mucki
31
32
33
34
35
AVERAGE ?C3 CCNCENTSATION
IN ^AUKESAN HARBOR 3Y SEGMENT.
133.2
132.1
36. a
103.2
30.3
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NOftYH
01YCH
NORTH SHORE SANITARY DISTRICT
PARKINGL6tV
FORMER 'CRESCENT
OUIFALLS 0|TCM
LAKE
MICHIGAN
SCALE;i">340*
OUTBOARD MARINE CORP
JOHNSON OUTBOARDS OIV
PLANT NO. 2
FIGURED
NORTH DITCH AREA
LEGEND
OVER 5O PPMPCB
EXTENT
OF PCB CONTAMINATION
OVER 5O PPM
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- 7 -
2. Water & Sediment:
*
A great deal of monitoring was conducted to determine the concentrations of
•
•
PCB found in the water column and sediments of both the harbor anfi .the North
1
Ditch. In Waukegan Harbor, concentrations in the water column rafcged fr~jm a
mean of approximately 6 parts per billion (ppb) about 3GO feet from Slip 3 to
a mean of .07 (ppb) at the mouth of the harbor. The concentrations in the
sediments of the harbor are discussed above and shown in Figure 2. These
water column concentrations were used with a mathematical model of the
hydrodynamics of the Harbor to estimate the release of PCB to Lake Michigan
resulting fron PCB's dissolved in the water column and the transport of PCB-
contaminated sediment under steady state conditions. The estimated rate of
release is 22 Ibs per year.
Sampling in the North Ditch shows the water column concentration, both dissolved
and particulate, in that area to average 7 ppb. Again, this concentration was
used with a mathematical model of the hydrology to estimate the PCB loading to
Lake Michigan through the North Ditch. The rate of release from the North
Ditch due to both dissolved PCB's and PCB-contaminated sediment is estimated
to be about 7-20 Ibs. per year. The results of the sampling of the soils
and sediment is discussed above and shown in Figure 3.
In addition to monitored sediment data at the site itself, sampling of the
surficial sediments in Lake Michigan indicate the presence of a "plume" of
contaminated sediments moving from Waukegan. The shape of the "plume" strongly
suggest that Waukegan is contributing to the contamination of Lake Michigan
sediments. See Figure 4.
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JWUJU
air
Figure 1-6.
Generalized discribucion of PC3 concancracions ia the
surficial sediaen:s of the southern basin of Lake
ilichigan. Derived from daca gathered bv Arrasrong
(1980).
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- 8 -
3. Ground Water:
Extensive ground water contamination was documented in t.vo comprehensive ground
water monitoring projects conducted in 1979 and 1980. The studiefc showed PCB
in the ground water in concentrations up to 35,000 ug/1. This studies showed
the contaminated ground water is moving slowly toward Lake Michigan and «dll
become a significant source to the Lake in 30 - 60 years.
The annual rates of release through each media from both the harbor and the
North Ditch areas is shown in Table 1.
In addition to the annual release of PCB's from OMC due to normal transport
mechanisms, the site represents a hazard to environment due of the possibi-
lity of a large, catastrophic-type release due to extreme storms. The modeling
of steady PCB movements lakeward and the assumptions concerning summer season
meteorological and hydrologic events do not take into account the potential of
the violent Lake Michigan storms of late fall or winter which cannot, practically
speaking, be measured and modeled. The lakeward movement of PCBs out of the
Harbor during the winter may be underestimated and hence the range of annual
PCB flux presented should be viewed as conservative.
In addition, the models cannot account for commercial navigation and recreational
boating have the potential to disturb and expose highly contaminated materials,
directly, through turbulence induced by propellers, These disturbances and
the major storm events which generate turbulence in the Harbor may sustain the
continued' exposure of highly contaminated bottom sediments to the water colummn
and hence will promote the surficial redistribution of PCBs throughout the
Harbor.
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Annual Rates of Release of PCB
from OMC
(Pounds/year)
•
Ait-
Surface Water
&
Sediment
Ground Water
Harbor
12-40
22
N/A
North Ditch
15
. 7-20
N/A
Parking Lot
N/A
N/A
Future Release
of 8 Ibs/year
Table 1
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E. Impact" of the PCBs on the Use of Waukegan Harbor;
1. Generally
The presence of high levels of PCBs has prevented the dredging of the harbor
since 1969 when they were discovered. Over the years, the harbor has continued
to silt in, and its uses have deteriorated. Sailboat keels are hitting botton.
The Cement Company has indicated that its ore boats must travel with a half
load in order to access the Harbor. Without removal of the sediment the Harbor
will continue to lose value to businesses which depend upon it.
In contrast to the dim prognosis for the future, both the City of Waukegan and
the Port Authority have massive development plans for the harbor area. This
includes condominiums, boat ramps, new streets and a total upgrading of the
area. Currently, the City is completing a new 750 slip marina.
Conversations with the Port Authority have indicated that the issue of uncontrolled
PCBs had had adverse impacts on economic development. Implementation of a
PC3 control will allow the development plan to proceed.
The Corps of Engineers, the Waukegan Port Authority and U.S. EPA are interested
in implementing individual projects, which together will result in a program
that addresses all areas of the harbor and will offer a long term resolution
to the problem. The Corps of Engineers wants to establish a regular maintenance
dredging program for the harbor where open lake disposal of dredge spoils can
be utilized in future years. Unless the contamination is removed above their
project 'area, this goal cannot be realized because PCB contaminated sediments
will continue to migrate into the area that the Corps dredges. The high levels
of PCBs in the harbor is preventing the Corps of Engineers from implementing a
maintenance dredging project which is needed to bring the harbor back to its
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E. Impact- of the PCBs on the Use of Waukegan Harbor:
1. Generally
The presence of high levels of PCBs has prevented the dredging of the harbor
since 1969 when they were discovered. Over the years, the harbor has continued
to silt in, and its uses have deteriorated. Sailboat keels are hitting botton.
The Cement Company has indicated that its ore boats must travel with a half
load in order to access the Harbor. Without removal of the sediment the Harbor
will continue to lose value to businesses which depend upon it.
In contrast to the dim prognosis for the future, both the City of Waukegan and
the Port Authority have massive development plans for the harbor area. This
includes condominiums, boat ramps, new streets and a total upgrading of the
area. Currently, the City is completing a new 750 slip marina.
Conversations with the Port Authority have indicated that the issue of uncontrolled
PCBs had had adverse impacts on economic development. Implementation of a
PC3 control will allow the development plan to proceed.
The Corps of Engineers, the Waukegan Port Authority and U.S. EPA are interested
in implementing individual projects, which together will result in a program
that addresses all areas of the harbor and will offer a long term resolution
to the problem. The Corps of Engineers wants to establish a regular maintenance
dredging program for the harbor where open lake disposal of dredge spoils can
be utilized in future years. Unless the contamination is removed above their
project area, this goal cannot be realized because PCB contaminated sediments
will continue to migrate into the area that the Corps dredges. The high levels
of PCBs in the harbor is preventing the Corps of Engineers from implementing a
maintenance dredging project which is needed to bring the harbor back to its
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- 10 -
full use. This is having an adverse effect upon", the welfare of the local
• - •
community.
2. Socio-economic |
A cursory survey of the employers in the Harbor area indicates that much of
the economic activity either is water-dependent or water-related. The Outboard
Marine Corporation (manufacture of non-electrical machinery), Larsen Marine
(rarine sales and services), Falcon Marine (marine contractor), Waukegan Port
District (transportaion services), the Waukegan Yacht Club (recreation) and
the Waukegan Water Filtration Plant (public water supply) depend upon the
Harbor and Lake Michigan for their operations. Huron Cement, and Gold Bond,
both of which are Divisions of National Gypsum; Larsen Marine; Falcon Marine;
the Waukegan Port district and the Waukegan Yacht Club depend upon a working
harbor for their operations.
The Waukegan Port District operates the Waukegan Harbor. The Port District's
gross revenues during 1980 totalled 5286,950. The sources of there revenues
are shown below:
Gasoline $13,000
Land leases 64,000
Slip rental 78,000
Dry moorings 35,000
Wet moorings 8,200
Slip hopping 14,000
Parking lot fees 16,000
Boat launching 31,000
Charter Boat permits 6,500
Temporary docks 7,800
Interest 7,500
Miscellaneous 5,950
TOTAL $286,950
During 1980 there were approximately 43 conmercial ship dockings at Waukegan
Harbor (By telephone Mr. Bruce Lawson, Deputy Director, Waukegan Port District
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- 11 -
and Ms. Susan Du Bois, Gold Bond to WAPORA, Inc."; 19 October 1981). Shipping
• - * '
activity in che Harbor varied widely fron 1969 to 193U. The number of tons of
cargo hauled over the 11-year period ranged from 538,866 in 1971 po 282,500 in
1930 (US Army COE n.d. and Waukegan Port District 1981). The decline in shipping
activity during 1980 reflects the nature of the Port shipping activity during
1980 reflects the nature of the Port District's commercial clients.
The Port District currently serves two commercial clients: Huron Cement and
Gold Bond. Huron Cement is located on the northwest side of the Harbor between
Slip #3 and Slip #1. 'Gold Bond is located south of Slip #1 (Figure 1-2).
During 1930, 282,500 tons of bulk csment and gypsum rock were hauled into the
Harbor for these two clients, respectively. Because Huron Cement and Gold
Bond both supply building materials for the construction industry in the Chicago
metropolitan area their need for raw materials is directly related to the
level of construction activity taking place. During 1980 and 1981, construction
activity in the Chicago area was relatively slow, and shipping activity at
Waukegan Harbor likewise declined. Huron Cement and Gold Bond both dock at
Slip #1 to unload cargo. Depending upon the size of the ship, Gold Bond's
ships either back out of the Harbor or back around into Slip #3 to swing the
bow around. Huron Cement's ships back around into Slip *3 and leave the Harbor
bow first.
Falcon Marine is located on the east side of the Harbor adjacent to the Waukegan
Water Filtration Plant. Falcon Marine docks between four and eight barges
along the seawall. The barges are between 30 and 42 feet wide and 100 to 120
feet long.
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- 12 -
Many types of recreation facilities and opportunities are available in the
Waukegan Harbor "area; the foremost of these is fishing. The Illinois
of Conservation, Division of Fisheries and Wildlife has estimate* that Waukegan
Harbor and offshore areas experience the heaviest fishing pressure of any area
along the Illinois coastline of Lake Michigan. Although the majority of the
recreational uses of the Harbor are related to fishing, a substantial amount
of pleasure boating, sailing, picnicing, and other water-related activities
also take place.
The 10 public boat launching ramps at the Harbor are open for use on April 1
each year and the 117 slips and 41 mooring cans are open by 1 May. There also
are 75 dry parking spaces for boats. Demand for the boat moorings is quite
high, and the current waiting listed contains more than 600 applications.
A considerable amount of boat-launching activity occurs at the Harbor. During
the period April 1931 through 31 July 1981, 5,755 boat launching tickets were
sold (a S3 fee is charged). This does not account, however, for the approximately
450 season-pass holders who have unlimited boat launching privileges.
Larsen Marine Service, Inc. , is located adjacent to Slip *3 at the north end
of Waukegan Harbor and is the largest lakefront yacht dealer in the Chicago
metropolitan area. Because Waukegan Harbor is the only protected public harbor
along the northern Illinois shoreline, a large amount of recreational boating
activity is concentrated there. Larsen Marine is the only marine sales and
services' company located directly on Waukegan Harbor. The company provides
yacht brockerage for new and used power boats and sailboats and offers complete
marine repair services. A crane operated . boat hoist is also available for
removal and storage of all size. classes of boats. These services are of
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- 13 -
considerable importance to recreational boaters -in the region because there
are no similar commercial facilities on the'northern Illinois coastline.
nuroer
Currently, the Illinois Department of Conservation limits the nurter of charter
boats which operate out of Waukegan Harbor to 35. Of this total, 27 are members
of the Waukegan Charter Boat Association; members include eight 4-passenger
boats and nineteen 6-passenger boats. The Charter Boat Association estimates
that its 27 boats have between 12,000 to 15,000 paying clients.
This boating activity results in substantial fishing pressure. There are 14
public boat access points along the Illinois shoreline to serve the entire
metropolitan region. Although Waukegan is 40 miles north of Chicago, the
major population center of the region, the Waukegan area experienced the greatest
fishing pressure along the entire Illinois shoreline of Lake Michigan. This
estimation is based on a 1979 sport fishing creel survey conducted along the
Illinois portion of Lake Michigan by the Illinois Department of Conservation.
The results of the creel survey indicated that the heaviest pier/breakwater
fishing pressure was experienced at the Waukegan Harbor and that the heaviest
boat fishing pressure.was experienced offshore from the Waukegan Harbor. The
survey personnel estimated that a total of 222,918 angler hours were expended
for pier/breakwater fishing along the Ilinois shoreline. At the Waukegan
Harbor, the 1979 estimate of angler hours was 45,974, or 21% of the total.
However, the average number of fish caught per hour at the Waukegan Harbor was
the second lowest rate of the 14 sites listed.
The estimates for the trolling fishery also indicated that more angler hours
were expended in the Waukegan Harbor area than at any of the other locations.
Of the total 601,426 estimated angler hours spent trolling, 184,554 (31%) were
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- 14 -
•
allocated to Waukegan Harbor. As for the pier/breakwater fishery, the number
• - •
of fish caught per hour was relatively low. The majority of the iish caught
by both pier/breakwater and trolling fishing *>ere coho salmon. Hilf of all
the coho caught from the pier/breakwater fishery were from Waukegan Harbor.
The Waukegan Harbor trolling fishery accounted for 34% of all the coho salmon
caught along the Illinois shoreline in 1979.
Although significant fishing activity took place on the Waukegan breakwater
and from boats in 1979, relatively little shore fishing occurred at the Waukegan
Harbor. Of the 285,374 angler hours estimated for the 1979 shore fisher/,
only 1,179 (0.4%) were allocated to the Waukegan Harbor.
II. TOXICITY OF PCBS
The toxicity of PCBs to humans was demonstrated graphically and tragically in
1963 when rice oil in Yosho, Japan, was accidentally contaminated with PCBs.
Since then, extensive information has been collected concerning the toxicity
of the different types of PCB compounds in varying concentrations. The compounds
have been found to be toxic and uniquely persistant in the environment and the
human body.
The best summary of the information available on the toxicity of PCB was compiled
in August 1982 by the Health and Environmental Review Division within the
Office of Toxic Substances for the TSCA rulemaking on PCB. This summary of
health information concludes that PCBs are linked to a myriad of health and
environmental problems, including the following:
o carcinogenic effects in rodents - especially liver cancers.
o immunosuppressive activity.
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- 15 -
o Tremendous bioaccumulation of PCB occurs in the food chain Fish flesh
often contains several thousand times the concentration of PCB found in
the a*nbient water.
o ambient exposure impairing reproduction potential of coimierqhal fisheries
and mink. |
o high PCB levels found in birds, especially in gulls and other carnivorous
birds.
o chloroacne - a painful, scarring disease that is frequently accompanied
by other problems including deformity of bones and teeth,
headaches, dizziness, fatigue, abdominal pain and vomiting.
o adverse affects on the menstrual cycle of rhesus monkeys.
o changes in menstruation in humans.
o reduction in rate of conception, reduction in implantations, difficulty
in carrying offspring to term.
o PCBs are inducers of hepatic microsomal enzymes (role of producing sex
steriods).
o increase production of androgen and testosterone in rats.
o increased liver to body weight ratios in rabbits.
o the uteri of 1,254 rabbits were about 1/2 the size of the control group
after exposure to PCBs.
o Reproduction in mink appears to be extremely sensitive to PCBs; reproduction
was totally inhibited at an exposure of 5 ppm for 10 months.
o PCBs have been shown to cause adverse effects to test animals in all
four areas of tertogenicity, which includes 1) death to the developing
organism, 2) structural abnormalities, 3) growth retardation and 4)
development of functional deficiencies.
o PCBs have been found in mothers milk. Infants PCB concentrations increase
with exposure time and may cause morphological alterations of the
liver at the ultracelluar levels and increased susceptability to viral
infections because of increased innnunosupressive activities of PCBs.
o Infant monkeys have died prior to weaning when exposed to PCBs because
of rudimentary thymuses, small spleens and lyrtph nodes.
o excess liver cancer deaths observed in workers exposed to PCBs at high
concentrations.
o PCBs induced lesions in the digestive tract which may be precursors to
carcinomas.
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III. THREATS TO PUBLIC HEALTH AND THE ENVIRONMENT POSED BY PCBS AT THE OMC
SITE
i.
A. Threats to Public Health;
A toxic ccrpound or chemical poses a threat to public health only^to the extent
that the public is exposed to the compound or chemical. Risk is always a
function of toxicity and exposure. PCBs have been shown to be toxic. There
are several routes by which the public is exposed to this toxic compound at
the OMC site and by which is released to Lake Michigan. These routes of public
exposure are discussed below.
I. Drinking Water
The City of Waukegan maintains an emergency drinking water intake in Waukegan
Harbor. Although this intake is rarely used and has been used only six times
in the last fifteen years, it is an integral component of the Waukegan Water
Supply. Should the City need to utilize the emergency intake, PCB contaminated
sediment and water may be introduced into the drinking water system. The City
has its main drinking water intake about 1 mile off shore in Lake Michigan.
At the request pf the Lake County Health Department, USEPA conducted a survey
of the water supply for PCB's. USEPA sampled the raw water, finished water,
and drinking water sludges. Low concentrations of PCB's were found in the
drinking water sludge samples. This indicates that PCB's are getting into the
system, but are being adequately removed by the treatment system.
2. Ingestion of Contaminated Fish
The waters of Lake Michigan are heavily fished for both commercial sale and
sport. The near shore area adjacent to the OMC site is often fished. A 1979
sport fishing creel survey by the Illinois Department of Conservation indicates
that the Waukegan Harbor area accounts for 21% of the angler hours expended in
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- 17 -
Illinois for pier/breakwater fishing (45,000 hoars). Even Waukegan Harbor
itself, although""No Fishing" signs are displayed, has occasionally been used
for fishing". All fishing near the site, both in Waukegan Harborffind Lake
Michigan presents a potential public exposure to PCB oecause PCBs are bio-
accumulated by fish from the water in which they live and from the insects and
plants they ingest. It has been demonstrated that fish bioaccumulate PCBs by
. 100,000 or more ti;nes the ambient water concentrations.
In USEPA studies on Lake Michigan fish, results ranged from concentrations of
2.7 ppm to 187 ppm PCB in fatty tissue for all species. Although it is impossible
to determine the exact source of these PCB's, clearly PCB in Lake Michigan
fish is a problem and clearly the CMC site is a source of PCB to the Lake.
It is very difficult to calculate the extent of human exposure to PCBs through
the consumptions of contaminated fish because the levels of PCBs in fish differ
significantly as does the amount of fish consumed by different persons. Based
on a study conducted by the Michigan Department of Public Health (Cordle, et.
al., 1978), it is considered likely that persons who consume large amounts of
contaminated Lake Michigan fish are exceeding the recommended daily limit.
Based on the Clements Associates study on the "Health Risks Posed to Consumers
of Fish Contaminated with PCB's from Lake Michigan" (1981), heavy consumers of
Lake Michigan fish contaminated with PCB may be exposed to a one in one thousand
excess risk of developing cancer with a lifetime of exposure. Obviously,
those who consume fish from the highly contaminated Waukegan Harbor area are
also likely to be exceeding the recommended daily limit for PCB consumption.
3. Dermal Exposure
Another route of public exposure to the PCBs at the OMC site is related to the
recreational and commercial activities conducted around the site. Pleasure
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- 18 -
boats moored, launched and then removed from Waukegan Harbor are coated with
• - "
contaminated harbor muds and silts. Boat owners and workers areiexposed to
PCBs when they work on the boats. Boats may be removed from theEiarbor, brought
to the owner's home and washed, spreading PCB contaminated material to the
owner's property.
In addition, the North Ditch discharges to a beach area, meandering across the
sand until it reached Lake Michigan. The public has access to this beach for
walking or playing.
Because of the level of public activity in and around the OMC site, public
exposure to PCBs through the skin is likely.
4. Inhalation
As was discussed above, PCBs are volatilizing from the OMC site in significant
quantities. These volatile PCBs present yet another route of public exposure.
Twelve percent of Waukegan's work force is employed adjacent to the harbor.
In addition, many people utilize the harbor for recreational boating about
eight months per year, with numbers peaking in the hot summer months when
volatilization is highest. A recreational beach is located due east of harbor.
The prevailing winds blow east and thus beach users are likely to be exposed
to PCB contamination.
B. Threats to the Environment:
In addition to the threats to public health posed by the site, the PCB's at
the OMC site present a significant threat to the environment of Waukegan Harbor
and Lake Michigan. As described above, water samples taken from Waukegan
Harbor and the North Ditch have mean concentrations of PCB of 0.6 ppb and 7.0
ppb, respectively. The USEPA Ambient Water Quality Criteria for the protection
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of fresh water aquatic life from chronic toxicitydue to PCB is 0.014 ppb.
Water column concentrations at the site far exceed the ambient watir quality
criteria, the concentrations found in water samples taken in Lake Michigan
offshore frcm Waukegan Harbor showed PCB concentrations at 0.01 ppb, slightly
less than the water quality criteria.
Research has shown that small amounts of dissolved PCB's, such as those found
in Lake Michigan, can inhibit phytoplankton photosynthesis (McNaught et al.
1981). Because phytoplankton are at the base of the Lake Michigan food chain,
inhibition of phytoplankton photosynthesis will limit the poundage of sport
fish that can be produced in the Lake. In one experimental study, PCB concen-
trations of 5 ng/1 inhibited nanoplankton photosynthesis by 5.7% (McNaught
et al. 1981). Concentrations of 100 ng/1 and 500 ng/1 inhibited nanoplankton
photosynthesis by .8.9% and 18.9%, respectively (McNaught et al. 1981). PCB
concentrations of 5 ng/1 are comparable to the levels found in the open waters
of Lake Michigan, and concentrations of 500 ng/1 are corparable to present
levels in Waukegan Harbor.
The PCB's in-Waukegan Harbor present a special danger to immature fish.
To ensure a self-sustaining community of fish, a certain critical percentage
must survive from the larval stage to maturity. If the critical percentage
that must reach maturity is not attained, fish population will decline and a
stocking program will be required to maintain the population. If the cause of
the decline is not corrected, a continual stocking program is required. Wilford
(1980) found a direct correlation between fish fry mortality rates in Lake
Michigan lake trout and PCB and DDE levels in the water column.
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- 20 -
Concentrations of PC3s in Waukegan Harbor are not evenly represented by
•
the water column levels. PCBs tend to concentrate at levels abovfe .those found
in the water column in two sections: the surf icial bottom sedim^t and the
air/water interface. Increased concentrations in these sectors result from
the tendency of PCBs to partition into organic compounds by adsorption. The
organic fraction can move PCBs downward with settling particulate matter or
upward into the plankton, oil, and foam at the air/water interface, and held
there by what is generally referred to as "the surface film effect." Bottcm
sediments are used as a food source for bottom feeding fish and are ccmmonly
the depository for developing eggs and larvae when used as a spawning ground.
In addition, the surface film is a rich food source to many types of young
fish (Wangersky 1976). Although documentation does not yet exist, it is
speculated that an increased biological hazard exists for fish feeding on
bottcm dwelling organisms of Waukegan Harbor and outlying water, or using the
Waukegan area sediments as a spawning ground.
In the central Waukegan Harbor area, fish would encounter PCB concentrations
in the surficial sediments that range from 8 to 3,600 ppm (Armstrong 1980) and
which are more than 20,000 times more concentrated than the levels typically
found in the Waukegan Harbor water column. Although no PCB concentration data
are available for the surface film sector of the Harbor, the known affinity of
PCBs to become adsorbed into organic compounds and the increased presence of
such ccnpounds at the air/water interface suggests that PCBs may have an
increased adverse impact on the biota through this sector.
Only twenty-nine fishes (9 total species, 6 game species) have been captured
in Waukegan Harbor for the purpose of determining bioconcentration factors
for PCBs. The relative scarcity of sane fish in the Waukegan vicinity as
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- 21 -
evidenced by the low number of species captured may be related to the high
•
levels of PCBs and other pollutants found in the area. i
In an effort to show the environmental inpact of the OMC site of take Michigan,
the movement of PCB's from the project area to the Lake was compared for the
input of PCB's to the Lake from other sources. The vast size of the lake
makes this sort of analysis misleading; Lake Michigan is so large even 55 Ibs
or so per year from a single source does not appear significant. A nearshore
sector with a 10 kilometer radius was selected as an area of localized impact
outside Waukegan Harbor.
Although the 10-kilometer radius area was selected arbitrarily, it represents
a reasonable-sized area that excludes possible influences from other sources.
such as the City of Chicago to the south. The area of the Lake within this
radius also coincides roughly with the eastward extent of the unstratified,
nearshore zone of Lake Michigan. The long-term average PCB mass load from the
combined Waukegan Harbor/North Ditch system to Lake Michigan may be conservatively
estimated to be 22 to 44 pounds per year (modeling of water and sediment only).
If it is assumed that the dry deposition load of PCBs to the entire Lake is
approximately 550 to 1,100 Ib/yr and that rainfall and dry deposition are
uniform over the Lake (USEPA 1981), then the 22 to 44 Ib/yr PCB load from the
Waukegan Harbor/North Ditch area could represent frcm 49% to 80% of the total.
load to the near-shore (10 km) sector. See Figure 5.
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INPUT
INP'J'
•.:-••
,'.; . • -.' •:.../»•??:».\. ,
The rar.gs asd di s t rib u t
the searshors 3«ctar c:
•aukegaa '-arior ('iycrc^
er c: the tctai ?C3 leads :
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- 22 -
IV. EVALUATION OF THE "NO ACTION" ALTERNATIVE ";
• *
Studies conducted by EPA have shown that high concentrations of P(3 'exist in
all segments of the CMC site (Waukegan Harbor, North Ditch, and the OMC parking
lot). In addition, sampling and modeling studies have shown that the PCB's
are leaving the site through the flushing of water from the Harbor and the
North Ditch, the movement of ground water toward lake Michigan, the transport
of sediment into Lake Michigan ana the volatilization of PCB's to the atmosphere.
Under the NCP, source remedial actions are appropriate if a substantial con-
centration of hazardous substances remain at or near the area where they were
originally located and inadequate barriers exist to retard migration of sub-
stances into the environment.
A source control action is appropriate at the OMC site because the investigations
regarding the human health and environmental impacts of exposure to PCB's have
shown that PCB's are both toxic and uniquely persistant. The release of PCS
from the site was evaluated and it was determined that the release is resulting
in a public exposure to PCB. These evaluations showed that the public is
being exposed or potentially exposed to the PCB's released frcm OMC though the
drinking water supply, consumption of contaminated fish, skin contact with
contaminated material, and inhalation of volatilized PCB's.
In addition, the PCB's being released frcm OMC are having a negative impact on
the environment of Waukegan Harbor and the nearshore area of Lake Michigan.
Finally, a no action alternative may result in indefinite postponement of the
dredging of the navigation channel. If routine channel dredging were precluded,
deep draft shipping activity would eventually cease as a result of sedimentation
at the Harbor mouth.
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- 23 -
Although the economic contribution of the Harbor industries that are dependent
on a working harbor for their operations to the overall economy of jthe area
has not been-quantified, the impacts associated with a further curtailment in
use of Harbor would be substantial. Such a curtailment would be expected if
no action was taken to abate PCS contamination in the Harbor because of the
potential hazards associated with Harbor maintenance activities.
Because of the known and potential threats to public health, welfare and the
environment specified above and associated with the release of of PCB's from
the QMC site, remedial action has been determined to be necessary to provent
and mitigate the migration of PCB's from the site and the spread of PCBJs to
Lake Michigan and the food chain.
Under CERCLA, the remedial action taken to control the PCB's must be determined
to be cost effective based on engineering, environmental and economic criteria.
EPA conducted a feasibility study to evaluated the potential remedies for the
site.
V. FEASIBILITY STUDY
A. Extent of Remedyt
Before assessing the various options, it is necessary to consider the quantity
of contaminated soil or sediment to be controlled. The quantity is dependent
on the concentrations of PCB which must controlled to protect the public health
and environment. EPA has determined that all soil and sediment contaminated
to 50 ppm or greater must be controlled. This limit was based upon modeling
of the Harbor done by Hydroqual (1980). Using a hydrodynamic model of water
and sediment transport, Hydroqual estimated the flux of PCB to Lake Michio--
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- 24 -
if sediments in the Upper Harbor and Slip No. 3 are contaminated with 500,
*
100, 50, 10 and 1 ppm PCB. The modeling studies-showed that if all sediments
contaminated to greater than 100 ppm are contained or removed frcji the Harbor
and steady state conditions ar-a assumed, the flux of ?CB to Lake flichi^an will
approach zero, the water column concentrations in the Harbor itself will be
reduced to less than 0.02 ug/1, the ambient water quality standard, and fish
residing in the Harbor will not accumulate PCB to greater than 5 ppm, the FDA
standard.
These modeling studies did not address the turbulence introduced into the
Harbor by boat traffic and heavy storms, however, and this turbulence may
introduce as much as 2 pounds per year of PCB would be released to Lake Michigan
if the sediments are contaminated to 100 ppm. To lower the estimated release
of PCB from the Harbor and provide some margin of safety for the fish in the
Harbor, it is necessary to dredge so that the sediments remaining will have
concentrations of PCB less than 50 ppm. Although there is no modeling available
for the area north of the CMC plant, considerations similar to those regarding
the Harbor area suggest that 50 ppm is an appropriate level of cleanup for the
whole site. In addition, such a level of cleanup would ensure that the material
excavated as part of construction of the slurry walls would not require off-site
disposal at a chemical landfill. Finally, a 50 ppm level of cleanup provides
a consistant objective for the cleanup of the entire site.
B. Screening of Alternatives
To determine the most effective way to clean up the sediments contaminated to
greater than 50 ppm PCB. EPA evaluated more than fifty treatment alternatives
and technologies. These alternatives included in place destruction of the PCB
with UV/ozonalysis, biodegradation and oxidation; in-place fixation with
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- 25 -
sorbents and seals; in-place separation of the PCB and removal; removal of the
•
contaminated =oils and sediment; alternatives to bypass the contaminated material;
water treatnent technologies; onsite storage and offsite disposalFor storage/
disposal.
Although there is a lot of research on innovative methods of destroying or
fixing PC3's and several alternatives are potentially promising, there are
relatively few technologies that have been proven to be effective on PCB
contaminated soil and sediment. In reality, the only proven feasible technologies
approaches available are the traditional alternatives of (1) excavation and
offsite disposal or incineration and 2) containment of the material on site.
The offsite option of incineration was screened out because it was judged to
be an order of magnitude more expensive than land disposal. Thus, the two .
options evaluated in detail were offsite disposal in a landfill, and onsite
containment. The variations on these primary alternatives were evalutated in
detail to determine the best way of accomplishing each option. The combination
of treatment technologies considered most appropriate for each of the two
generic alternatives is described below.
C. Excavation and Offsite Disposal;
If implemented in Waukegan Harbor, an offsite disposal option would require
several steps. A sediment dispersal control device would be installed across
the south end of the upper Harbor to ensure that sediment disturbed during
dredging does not escape to Lake Michigan. Sediments contaminated with PCBs
would be removed with a hydraulic dredge (a suction line) and the sediment
slurry pumped through a pipeline to an initial solids dewatering lagoon.
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- 26 -
Because the hydraulic dredge cannot penetrate the area of deep contaminated
sand and silt near the OMC outfall, a mechanical dredge inside a single shee
pile cofferdam would be used to remove this material.
The dredged solids would be dewatered, fixed and transported to a disposal
site meeting TSCA standards for PCB's. All removed water and process water
would be routed to a water treatment plant for suspended solids and PC3 removal
(to 1 ppb PCBs, an effluent standard based on Best Available technology from .
the Mason and Hanger analysis), then discharged to the harbor or to a sanitary
sewer. During excavation and dewatering, volatiliation of PCB's is likely to
increase because the highly contaminated sediments will be exposed. This
volatilization will be temporary and will be minimized by using best management
practises.
In the areas north of the OMC plant, the excavation and off-site disposal
would be somewhat simpler because underwater dredging would not be necessary.
A bypass would be constructed to divert surface water flow around the highly
contaminated areas of the Crescent Ditch and Oval Lagoon directly to Lake
Michigan. The soils would be dewatered in place using well points and pumps,
excavated with a backhoe or front end loader, fixed with portland cement or
another fixing agent, cured and transported to a disposal site meeting TSCA
standards. Well water would be routed to an onsite water treatment plant for
suspended solids and PCB removal (to 1 ppb PCBs), then discharged to the lake
or to a sanitary sewer. Because the material in the Parking Lot area is not
expected to be flowable, the intermediate step of hydrating the soil with a
fixing agent is considered unnecessary. During excavation, the volatilization
of PCB's is likely to increase beause the highly contaminated soils will be
exposed. This volatilization will be temporary and will be minimized by
using best management practises.
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- 27 -
The excavation and offsite disposal options are the most reliable remedial
•
alternatives for the OMC site. The CMC site is located immediately adjacent
L
to Lake Michigan. The Waukegan Harbor portion of the site is hycffologicaliy
connected to Lake Michigan and the northern are^s of tne site have ground
water only three feet below the surface. Sediment and soil from the area is
continuously transported to the Lake. By excavating and removing the PCS
contaminated material from the site, the transport of PCS to the Lake, and the
accompanying threat to public health and the environment is stopped. There
will no longer be high concentrations of PCB adjacent to the lake so all of
the threats described earlier are eliminated. Under this alternative, the PCB
contaminated material would be disposed of in a chemical landfill as defined
under the PCB regulations (40 CFR 761). This type of landfill is designed
specifically to contain hazardous material and is located so that the physical
environment will not act to deteriorate the containment cells. The EPA, by
promulgating the PCB regulations, has established that chemical landfills as
defined in the PCB regualtions are safe, reliable receptacles for PCB contaminated
material.
D. Containment On-Site
The other generic type of alternative available for dealing with the PCB
contaminated material involves containing the material on-site in such a way
that the release of PCB's to Lake Michigan is prevented. There are two basic
ways to contain the material onsite; a lined landfill meeting the requirements
of TSCA onsite or a containment cell using the existing glacial till as a
bottom.
Upon analysis of the TSCA landfill option it became apparent that it is impossibl
to build a disposal facility meeting all of the TSCA requirements and it is
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- 28 -
complicated and expensive to build one approximating those requirements. It
is impossible to"build a TSCA landfill because such a facility must be placed
"above the-historical high ground water table." In addition, "fl
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- 29 -
inpermeable clay cap. Ground water monitoring"-welIs would be installed around
• -
the site for detection of any future PCB migration.
fpass would b
In the area north of the OMC plant, a gravity pipeline bypass would be con-sir-cte-
to divert surface water flow around the highly contaminated areas, the Crescent
Ditch and Oval Lagoon. This bypass would collect drainage from the storm.
drain (that flows north at the west edge of CMC's property), from OMC plant
roof drains, and from regraded areas north and south of the Crescent Ditch and
discharge it to Lake Michigan.
It would be constructed south of the sheet piling just north of the east-west
portion of the North Ditch. The Parking Lot area would be regraded to divert
surface water flow to catch basins.
Containment will -effectively control the major mechanisms for the release of
PCB from the OMC site. The volatilization of PCB will be prevented because
the containment cells will be capped with several •" ^t of impervious material.
The transport of contaminated sediment will be eliminated because the sediment
will contain behind impermeable slurry walls. Finally, the contamination of
surface water with PCB will be eliminated because the water will no longer be
in contact with PCB contaminated sediment.
Because no slurry wall is completely impermeable, the containment cells will
release very small quantities of PCB very slowly to the ground water. Based
on an overall permeability of 10"^ on/sec, migration of PCB's through 2 ft
slurry, walls around the containment cells will disperse about 0.003 Ibs of PCB
per year. Assuming the same permeability for the glacial till, migration
through a one foot layer of glacial under all the containment areas will disperse
about .03 Ibs per year. If cracks occur in the slurry wall or if pockets of
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- 30 -
perrreable material are present in the glacial till, this dispersion will occur
faster. These rates of dispersion, however, are much less than tfte 55 - 1'j'j
Ibs per year EPA models shows are being released under present conditions.
VI. THE COST EFFECTIVE REMEDY
Because of the problems of reliability of containment cells built in proximity
to Lake Michigan, containment is considered less effective than offsite transport
and disposal of the PCB contaminated material at a chemical landfill as defined
by the PCB regulations.
The Environmental Protection Agency has consistently held that the public
health risks associated with PCB's, particularly high concentrations of PCB's,
are such that the release of PCB's into the environment must be strictly
controlled. Because it is impossible to build a TSCA landfill on a site adjacent
to and in Lake Michigan, containment on site is not consistent with the Agency's
basic regulatory position regarding PCB's or EPA's definition of cost-effective-
ness in the National Contingency Plan. Thus, the excavation and offsite
disposal option is considered the only remedial action for the OMC site which
effectively mitigates and minimizes risk to public health and the environment.
In defining the most cost-effective technique for accomplishing excavation
and offsite disposal, several options were evaluated. These options involved
alternative methods of dewatering the material dredged and excavated from
Waukegan Harbor and the area north of the site. The options available for the
dredged sediments in the Harbor are:
1. Dredge - Dewater in Lagoon - Fix - Dispose
2. Dredge - Dewater in Barges - Fix - Dispose
3. Dredge - Dewater in Lagoon - Dispose
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- 31 -
Option 2, which requires dewatering of the sediments in barges is not a feasible
option for' the extremely large quantities of material which will oe dredyed
from the Ugper Harbor area. The minimal savings in dewatering thL dredged
sediments from Slip 3 in barges would be offset because the simplicity of one
technique and economies of scale attained by treating the sediments in the
Slip and the Upper Harbor in the same fashion would be lost.
. Option 3, would depend upon evaporation to dewater the dredged sediments.
Although this is technically feasible, the evaporation would result in
significant quantities of PCB being volitilized from the highly contaminated
sediments. It is estimated that as much as 63 pounds/day PCB would volitilize
during dewatering. The public health and environmental impacts of this remedy
are too significant to consider it any further.
The most cost-effctive remedy for the excavation and disposal of material from
the Waukegan Harbor is to Dredge -Dewater in Lagoons - Fix and Dispose.
For the contaminated material north of the site, there are options for excavating
and dewatering the material. These options are:
Excavate - Dispose
Excavate - Fix - Dispose
The fixation step is necessary to ensure that the material is not flovable,
that is, that it will not spill as a liquid. The materials to be removed from
the Oval Lagoon/Crescent Ditch area are expected to be as wet a dredge spoils
and, as such, the material will need to be dewatered or "fixed" before it is
safe to transport it in trucks, etc.
On the other hand, the material in the parking lot expected to be dry after
the ground water is drawn down with pumping wells and it will not spill as a
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liquid, even without fixation. Therefdre for material in the parking lot the
fixation st3|.-- is not considered necessary. '
Based on the above analysis, the cost-effective remedy for the 01C site is:
Dredge - Oewater in Lagoons-Fix-Dispose for
Waukegan Harbor $35,500,000
North Ditch Area
Excavate - Fix - Dispose $26,820,000
Parking Lot
Excavate - Dispose $12,570,000
Total ' $74,890,000
This remedy would have no adverse impacts on the future use of the land
because all contaminated material will be removed from the site. All areas
would be filled with clean material and graded to preproject elevations.
VII. FUND BALANCING
Under section 300.68(k) of the National Contingency Plan, EPA is required
to balance the need for protection of public health, welfare, or the environment
against the amount of money available in the Hazardous Substance Response
Trust Fund (Fund) in selecting a remedy. EPA must preserve its ability to
respond to other sites which present or may present a threat to public health
or welfare or the environment, taking into account the need for immediate
action. -In evaluating the appropriate extent of remedy for OMC, EPA must
consider the need to respond to other releases with Fund monies.
Because the estimated cost to implement the cost-effective remedy for the
CMC site identified above exceeds $70 million, EPA has conducted an analysis
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of Fund assets in which expected .Fund receipts'are. compared with expected
future needs- for remedial actions at sites curr-jntly listed on the Rational
Priority List. In addition, we have considered the expected experxlit'jres for
immediate and planned removals and other program neaJs. These analyses have
shown that implementation of the cost-effective remedy at the CMC site will
have serious impacts on EPA's ability to respond at other hazardous waste
sites.
EPA's Superfund budget prepared for FY 84 allocated $3.4 million for remedial
construction at the OMC site. The difference between this allocation and the
$75 million necessary to fund the cost-effective remedy is $72 million or
more than one half of the $ 130 million FY 84 budget for remedial investigation,
feasibility studies and construction. EPA's analysis shows that it" all material
contaminated to more than 50 ppm is disposed offsite, approximately 1UO other
projects currently underway or planned for FY 34 would have to be cancelled.
The situation is not expected to improve in FY 85. The FY 85 budget for the
entire Superfund program including immediate and planned removals, expected to
be approximately $510 million. EPA's analysis show that this FY 85 budget
will essentially consume all of the monies left in the Trust Fund. Of that
$510 million, an estimated $300 million will be available for remedial actions.
The cost-effective remedy for OMC would require 10% of the entire program
budget and 22% of the dollars planned for remedial action. The program has
identified'more than 60 remedial construction projects which will be ready for
implementation in FY 85. The total costs of those construction projects will
exceed the $300 million expected to be available. Thus, if the cost-effective
remedy of OMC is implemented, approximately 8 other construction projects must
be cancelled, assuming an average cost of $6 to $8 million for each project.
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•
In light of the high cost of ths remedy for the OMC site, both in tS^rms of
r
dollars and other actions which would have to be foregone, the Agency has
decided to consider other remedial actions for the OMC site. If the PCB
contaminated material at the site can be controlled to the extent that the
annual release of PCB from the site approaches zero with some reliability and
the relative risk of public exposure to PCB is minimal, then Fund balancing
may be appropriate. In evaluating other remedial alternatives, the Agency's
objective was to find the least cost alternative which controls the PCB
contaminated material on-site such that the release of PCB's from the site
will approach zero.
VIII. FUND BALANCED ALTERNATIVE - RECOMMENDED FOR IMPLEMENTATION
In evaluating remedial options for Fund-balancing at the OMC site, on-site was
considered. As stated above, there are problems associated with the reliability
of onsite containment. It is impossible to build =» containment cell at the
OMC site that is equivalent to PCB landfills defined in the PCB regulations.
In looking at options for Fund balancing, therefore, the Agency tried to
developed a balanced combination of options that takes into account the lesser
reliability of the onsite containment cell yet minimizes the very expensive
offsite transport and disposal. Accordingly, the option recommended for
implementation includes both offsite disposal and onsite containment components.
In addition, the recommended option includes extensive post closure monitoring
of the containment cells to ensure their continued integrity. The multistage
process for developing the fund balanced alternative is described below.
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A. Development Process
1. First Public'Garment Period
In July 1983, EPA proposed five cleanup actions for the three PCifc contaminated
areas of the O1C site. The actions included both offsite disposal and on-site
containment components. Actions 1 and 2 concern Slip No. 3 and the Upper
Harbor.
Action 1:
In conjunction with Action 2, below, PCB-ontaminated sediment, sand and silt
would be dredged from the localized area near the former OMC outfall in Slip
No. 3. An estimated 5,700 yd3 of PCB contaminated material, containing
about 286,500 Ib of PCBs would be removed, fixed and disposed offsite in a
licensed chemical landfill. The estimated cost is $3,150,000.
Action 2:
A containment wall would be constructed around the perimeter of the western
portionof Slip No. 3, part of the Upper Harbor sediments would be dredged into
the contained area; the con- inment area would be capped. Approximately 306,900
Ib or PCBs in 21,100 yd3 of sediments would be contained. The estimated
cost is $6,100,000.
Actions 3 and 4 concern the North Ditch Area.
Action 3:
PCB-contaminated soil would be contained and capped in the Crescent Ditch/Oval
Lagoon area. The North ditch would be partly excavated to install a bypass
drainage pipe. The PCB-contaminated soil from the bypass excavation would be
placed in the Cresent Ditch/Oval Lagoon area before capping the area.
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Approximately 492,100 Ib of PC3s in 51,400 yd3 of soil would be contained.
The estimated cost is §4,210,000.
The total estimated cost or the five actions is 517,410,000. |
2. Second Public Comment Period
Upon further review of the proposed remedial alternative and the comments
vnerated djring the first public comment period, EPA decided to reexamine
the Slip *3/Upper Harbor portion of the five cleanup actions. The initially
proposed action provided for containment of all Sediment contaminated to 150
ppm in the Upper Harbor.
The Agency decided consider an alternative which would contain all sediments.
contaminated to 50 ppm remaining in the Upper Harbor. With the addition of
this material, approximately 310,OOU Ibs of PCBs in 46,600 yd3 of sediments
would be contained in a larger containment cell. The larger cell would esentialiy
eliminate the water frontage portion of Larsen Marina. The estimated cost of
Action 2 described above with the increased control to 50 ppm is $9,300,00.
This increased the total cost for the five actions to $20,610,000. The change
to Action 2 resulted in all of the five cleanup actions providing for containment
or off-site removal of all materials contaminated to 50 ppm. At the same tine
the Agency decided to consider the possibility of building a containment cell
in the Slip/Harbor area without constructing a replacement slip.
Previously, all of the alternatives in the Feasibility Study regarding the
construction of a containment cell in the Slip/Harbor area included the
construction of a replacement slip.
In March 1984, EPA again opened a public conmsnt period regarding the Feasibility
Study soliciting comment on all of the alternatives. In addition public comment
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was solicited regarding increasing the scope of -the Slip/Harbor containment
cell to contain PCB contaminated sediments to 5U ppm and not building a rep
•
slip. • - £ •
3. Final Selection Process
After the close of the second comment period in April of 1984, EPA re-examined
the feasibility study and public comments in order to determine the best approach "
for a Fund-balanced remedy for the OMC site. This examination focused on the
contaminated material in slip 43 and the Upper Harbor.
During this re-examination the Agency again reviewed all costs and all possible
technologies available in the matrix of cleanup actions addressed in the feasibility
study. It became apparent that EPA would assume a risk of greater than expected
costs for contament in slip *3 and that a different combination of alternatives
regarding the Slip #3/Upper Harbor area and the Parking Lot might provide
substantially equivalent environmental benefit at approximately the same cost.
4. Review of Alternatives
The feasibility study included an alternative to dredge, dewater in lagoons
and remove offsite all sediments with concentration of PCB greater than 50
ppm. The cost of the alternative is estimated at 321,300,000 and would result
in returning the Slip #3/Upper Harbor area to its original use upon completion
of the action. There are two primary concerns regarding this alternative; the
cost of the option and the volatilization rate from the sediments during the
two year dewatering period. Variations in this alternative to provide essentially
equivalent environmental protection at approximately the same cost as the
alternative previously recomended are described belcw.
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Similar Cost:
The major difference is cost between containment in slip *3 and the alternative
to dredge~dewat-=r in lagoons and dispose ot't'site resulted from thdTthir-1 corporent;
the offsite disposal of the material. It the material could be disposed onsite,
the cost of the two alternatives is similar. If, in addition, EPA considers
the potential risks of costs associated with aquiring access to Slip «3 and
the Upper Harbor to build a containment cell, the costs of the two are essentially
the same.
Two possible locations for the final disposal of the solids could be the Parking
Lot area and the North Ditch area of the CMC site. Soth of these areas contain
PCB contaminated sediments and a number of alternatives had been developed
which contemplate the construction of containment cells in these areas. The
addition of material to either of the cells will not substantially increase
the cost to build the containment cell. As the Parking Lot containment cell
proposed during the public comment period is larger than the North Ditch area
cell, the Parking Lot area is considered more suitable for containment of the
dredged solids from the Slip and Harbor. Instead of containing 100,000 cubic
yards of material and being 5 feet above grade, as it was proposed, this cell
would contain 140,000 cubic yards and be 14 feet above grade, if the material
from the Harbor is added.
The present worth of this option if the material is disposed on site is
approximately $10,000,000. Although this is significantly less than the cost
of this alternative if the material is disposed offsite, it is still more than
the cost of containing the material in Slip 3. EPA previously estimated the
cost of containment of all harbor wastes above 50 ppm in Slip 3 at S9.3 mi1
including SI.2 million for construction of a slip to replace Slip 3.
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construction without these replacement costs .would be $8.1 million, or SI.9
• - "
million less than the parking lot. However, if EPA did not build such a slip,
•
it might be required to compensate Larser Marine and the other sMp owner f'^r
the property interest needed to build a containment cell in the slip. For a
varietty of reasons, including the fact that the exact size of the coantainnent
cell cannot be determined prior to final design, EPA has been unable to obtain
any accurate assessment of the cost of acquiring the necessary property interest.
However, based on a review of all the data in the record the Agency has believes
that the costs of acquiring these rights may be substantial and may, therefore,
significantly reduce the apparent SI.9 million difference between the parking
lot and slip options.
Environmental Factors:
An option to dredge, dewater-in-lagoons and contain on the parking lot presented
the same environmental concerns during the dewatering phase as the option
presented when the material was to be disposed offsite. The dewatering in
lagoons will depend on evaporation to dewater the sediments and will take two
years. During this dewatering, a great deal of PCB could volatilize from the
sediment. To minimize the risks of PCB volatilization from the dewatering
lagoons, the more highly contaminated sediments from Slip 3 (1,000 ppm - 10,000
ppm) would be dewatered and fixed in a much faster process. This will lower
the concentration of PCB in the dewatering lagoons to below 1,000 ppm and
lower the estimated volatilization from the ponds to less than 1.4 Ibs per
day. -(The hot spots in Slip 3, with concentration of 10,000 ppm - 300,000
ppm, would be disposed offsite as described in Action 1. This discussion
relates only to the sediment handled as part of Action 2.) The step of "fixing"
the higher concentration of PCB contaminated reduces the risk of environmental
harm from volatilization.
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In addition to the environmental effects of the.dewatering of the sediments,
EPA considered the effects of using the parking lot containment cell to contain
* •
the Harbor"-sedi.Tents. One effect is an increase in size of the cfcntairjtient cell
on the CMC parking lot. The volume of tnis cell will oe expanded*by raising
the top an additional 10 feet above grade. The impacts of the expansion of
the cell were judged to be minor. The sell was already proposed to be 5 feet
above grade, the additional 10 feet presented no additional conplications.
Another example of the type of effects considered was a longer construction
time for the parking lot containment cell which could not be conpleted until
the sediments are dewatered (up to two years). This effect was considered to
have a minimal impact, too.
Finally, because the parking lot containment cell for the Harbor materials-is
above grade, any leakage of materials and the integrity of the cell itself could
be more easily monitored. Based on analysis of the environmental impacts,
dewatering the Harbor sediments and containing them in a cell on the CMC parking
lot presents similar environmental benefits to containment of the sediments in
Slip #3.
Selection of Containment Site
Based on the analysis of the cost presented above, the difference in costs is
less than SI.9 million, possibly substantially less. However, the parking lot
option may result in some environmental benefit due to ease of monitoring. In
addition, the parking lot option has advantages in terms of ease of implemen-
tation.
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A containment cell .Tuat be built under the OMC parking lot to contain the
contaminated souls in that area. Long term access to that property it necessary
for that cell regardless of where the Harbor material is contained. Jf a
containment cell is built in Slip 3, long term access to property owned by
Larsen and EJ & J Railroad is also necessary.
Containment of the Harbor material in the containment cell on the parking is
easier for EPA to implement because it will require long term access to only
one parcel of property instead of three parcels. On this basis, EPA has
concluded that the potential cost difference is outweighed by potential monitoring
advantages and reduction of implementation advantages of containing these
wastes in the parking lot area.
B. Waukegan Harbor
1. Hot Soots
In some portions of the site, the concentrations of PCB are so high that off-
site disposal is considered to be the minimally acceptable protection of the
public health. This is the case for those highly contaminated sediment
identified in Slip No. 3. The extremely high concentrations of PCB's in a
relatively small volume of material mandates that this material be handled
with great care and placed in a highly reliable a chemical landfill, which is
designed to protect public health to the greatest extent possible.
As identified in the feasibility study and previous work prepared by Mason and
Hangar Company, the presence of extreme high concentrations of PCB's exerts
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an unacceptable diffusionary pressure on underlying sediment or towardfany
slurry wall which would be built to contain such material. Removal offtrie
most highly contaminated material for offsite disposal is necessary to control
the driving force that is causing the PCB's to spread into the underlying
clay. This is demonstrated by the core data from the slip which shows that in
areas of highest contamination, PBC's have moved downward into the clay and in
areas of lesser contamination the PCB's have not penetrated the underlying
clay. Thus, if the material is not removed, the containment cell would be
much more prone to leakage.
In addition, the feasibility study demonstrates that after two years the
containment cells will begin to leak a small quantity of water, based on a
permeability coefficient of 10"7 centiineters/minute. if the highly contaminated
•aterial is not removed, the leachate will considerably more contaminated and
thus present a larger threat to public health and the environment.
There is no alternative less costly than the cost-effective remedy that approaches
the effectiveness of off-site disposal. The costs of off-site disposal of
•these sediments is $3,150,000.
2. Less Contaminated Portions of Slip 3 and
Upper Harbor
The less contaminated sediments in Slip No. 3 and Upper Waukegan Harbor may be
1
Contained onsite. Because the sediments in this area are contaminated with
'CB's in lower concentrations, the glacial till which is beneath the OMC site
ill act as an effective seal. No PCB's have been found in the till under
oderately contaminated sediments and soils. Therefore, adequate containment
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onsite is possib-le for these moderately contaminated materials.
This containment will effectively control the major mechanisms for the release
of PC3 from the CMC site. The volatilization of PCB will be prevented because
the containment cells will be capped with several feet of impervious material.
The transport of contaminated sediment will be eliminated because the sediment
will contain behind impermeable slurry walls. Finally, the contamination of
surface water with PCB will be eliminated because the water will no longer be
in contact with PCB contaminated sediment.
EPA evaluated two ways to contain this material onsite; dredging the Upper
Harbor to contain the contaminated material in Slip 3 and dredging both the
Upper Harbor and Slip 3, dewatering the material and containing it on CMC
property. Based on the analyses presented in the discussion in Section A, the
latter option is recommended.
Upon completion of this project the harbor, Slip 3, and the vacant property
can be returned to its existing use.
C. Oval Lagoon and Crescent Ditch
Some of the sediments in the Crescent Ditch/Oval Lagoon area of the site are
as highly contaminated as those in Slip #3. Fund balancing is not appropriate
for these sediments for the same reasons as it was inappropriate for the Slip
#3 sediments; containment does not provide adequate protection of public health
and the environment because the glacial till has been shown to be unable to
adequately prevent migration of that material.
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•
Off-site removal and disposal in an landfill as defined in the PCS regulations
is necessary to ensure the reliability of the containment cell bottcn^and
sidewalls and to prevent the leachate from the cell from becoming more concen-
trated due to the highly contaminated material within the cell.
.Contaminated material remaining after hotspot removal will be contained in
"place through the use of slurry walls and a clay cap. In addition, the material
generated as a result of sewer installation will be contained on site.
This containment structure is necessary to bring annual rates of release rate
to zero from this portion of the site. Surface water and ground water flows
will be removed from contact with the contaminated material. The containment
~°11 will be more reliable because the most highly contaminated material will
.- removed for off site disposal. The mechanisms of release of the PCB's will
be essentially halted by implementation of this alternative.
a. Some increased volatilization will take place while the
construction is underway, but once the clay cap is in place,
volatilization will be reduced to zero.
b. Ground water flows will be diverted around the containment site
by the slurry walls.
c. The underlying till will prevent the release of PCB contaminated
sediment because of its thickness and impermeability.
i
d. Surface water will be diverted around the cell by the impermeable
clay cap. Contaminated material will no longer be in contact
with surface water and surface water dispersion of PBC's will be
'halted.
e. Sediment transport will be stopped because the material will be
contained in a cell.
D. North Ditch
.ider this alternative, the North Ditch will be partially excavated in order
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<3S
e h ^
a
Contaminated soil in the f°r 'Jeali^ with
^ the parking iot ,.
APProxi,7iatelv •>-,-, ,n Evolves in Place .
Cel^ 27?,70U pounds of PCS-, - lncaPSulation.
of
C
to the
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c.
*
as sufficient* to protect public health, but less effective t •
than the cost effective remedy which would require complete F
sediment removal and backfilling prior to sewer construction.
Volatilization - This will be significantly reduced
because the entire area will be capped.
:. Parking Lot
The recommended fund-balanced approach for dealing with the large volume of
contaminated soil in the parking lot involves in place incapsulation.
1
„ Approximately 277,700 pounds of PCB's in 105,000 yd3 of soil would be contained
and capped in the parking lot area. Slurry walls would be constructed around
the perimeter of the major contamination and tied into the underlying glacial
till. The underlying till would be relied upon to contain the downward movement.
A clay cap would seal the top preventing surface water percolation into the
cell. Riprap would protect the east edge of the cell from wave or other errosion
.ions. Encapsulation was chosen as the fundbalanced alternative over excavation
;nd removal, the costeffective alternative, because it provide a high degree
f protection of public health and the environment for substantially less
>ney. The PCB's in the parking lot have been shown to be moving slowly toward
iKe Michigan. The fund-balanced alternative will further slow or contain
at release of PCB's to the lake environment. The fund-balanced alternative
itrols the mechanisms which were causing the PCB's to leave the site.
1. Ground Water - Ground water movements are the main driving
force here, causing the PCB enclaves in soil to move slowly
toward Lake Michigan. Surrounding the contamination mass
with slurry walls will divert the ground water flows away.
2. Surface Water - Surface water currently percolates through
the surface and sand exerting pressures on the PCB masses to
move down gradient. The surface water route will be eliminated
because of the cap.
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3. Volatilization - Currently, volatilization is rather smalfe
because of soil cover and the site is partially paved. |
However, the cap will aid in further reducing ulitization
.r
Technical components and costs of the remedial alternative recommended for
implementation of, given Fund Balancing considerations are summarized in
Table 2.
F. Evaluation of Threat Under Fund Balanced Alternative;
In sections I and III of this documentation it was shown that the uncontrolled
PCB's at the CMC site were being released from that site in significant
quantities and were posing a threat to public health and the environment
as a result of that release. The alternative described above will sucessfully
control the PCB's at the site and bring the release of PC3s to almost
zero. In doing so the threat to public health and environment posed by
the site will be mitigated so long as the containment cells function as
they are designed. Because the cells would not comply with TSCA requirements
of PCB landfills and the Agency has concerns about the long term reliability
of the cells, off site transport and disposal is considered the minimum adequate
alternative and the cost-effective alternative.
The fund balanced alternative which includes both off site disposal and on
site contamination is only slightly less than fully adequate, however. The
very highly contaminated material is removed frcm the site and the threat
posed by the moderately contaminated material is mitigated because material is
contained with a relatively high degree of reliability.
The threat posed to public health and the environment by the site after
this option is implemented will be small. Because this alternative provides
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almost as much protection for significantly less cost than the cost •
7C '
effective option, Fund balancing is considered appropriate at this site.
IX. TSCA
As the recommended fund-balanced alternative includes the construction of two
on-site containment structures for the disposal of PCS dredge material and
soils, the Region evaluated this action in light of the Toxic Substances Control
Act (TSCA) regulations (40 CFR Part 761).
Pursuant to 40 CFH Part 761.60(5), all dredged materials that contain PCBs
must be disposed of in one of three ways: I. in an incinerator which complies
with 40 CFR Part 761.65; or 2. in a chemical waste landfill which complies
with 40 CFR Part 761.65; or 3. upon application, using a disposal method to
be approved by the Regional Administrator in the Region where the PCBs are
located.
The Regional Superfund Office applied to the Regional Administrator for the
approval of an alternate disposal method. The Regional Administrator denied
the application. The decision was based upon the failure of the proposed
landfill to meet a number of technical requirements traditionally required for
approval of an alternate disposal method. The denial cited the following
issues as its basis: the lack of a synthetic membrane liner for the containment
cells; the fact that the landfill was not 50 feet from the historic high water
table; the .lack of an internal leachate collection system; and the lack of a 6
foot woven mesh fence surrounding the landfill.
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